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HomeMy WebLinkAbout01-04820FEDERMAN AND PHELAN, LLP By: FRANK FEDERMAN, ESQUIRE IDENTIFICATION NO. 12248 ONE PENN CENTER AT SUBURBAN STATION 1617 JOHN F. KENNEDY BOULEVARD SUITE 1400 PHILADELPHIA, PA 19103-1814 (2151 563-7000 GMAC MORTGAGE CORPORATION 3451 HAMMOND AVENUE P.O. BOX 780 WATERLOO, IA 50704 Plaintff v. TERM NO. ©I - 40~® C1~1 1 CUMBERLAND COUNTY JEFFREY L. FLTHRMAN LAURIE A. FUHRMAN 430 CROSSROADS SCHOOL ROAD CARLISLE, PA 17013 Defendant(s) CIVIL ACTION -LAW COMPLAINT IN MORTGAGE FORECLOSURE NOTICE CUMBERLAND COUNTY CUMBERLAND COUNTY BAR ASSOCLATION 2 LIBERTY AVENUE CARLISLE, PA 17013 (717)249-3166 **THIS FHtM IS A DEBT COLLECTOR ATTEMPTING TO COLLECT A DEBT AND ANY INFORMATION OBTAINED WILL BE USED FOR THAT PURPOSE. IF YOU HAVE PREVIOUSLY RECEIVED A DISCHARGE IN BANKRUPTCY AND THIS DEBT WAS NOT REAFFIItMED, THIS CORRESPONDENCE IS NOT AND SHOULD NOT BE CONSTRUED TO BE AN ATTEMPT TO COLLECT A DEBT, BUT ONLY ENFORCEMENT OF A LIEN AGAINST PROPERTY. ** You have been sued in Court. If you wish to defend against the claims set forth in the following pages, you must take action within twenty (20) days after this Complaint and Notice are served, by entering a written appeazance personally or by attorney and filing in writing with the court your defenses or objections to the claims set forth against you. You are warned that if you fail to do so the case may proceed without you and a judgment maybe entered against you by the court without further notice for any money claimed in the Complaint or for any other claim or relief requested by the Plaintiff. You may lose money or property or other rights important to you. YOU SHOULD TAKE THIS PAPER TO YOUR LAWYER AT ONCE. IF YOU DO NOT HAVE A LAWYER OR CANNOT AFFORD ONE, GO TO OR TELEPHONE THE OFFICE SET FORTH BELOW TO FIND OUT WHERE YOU CAN GET LEGAL HELP. Loan #:306764324 ATTORNEY FOR PLAINTIFF COURT OF COMMON PLEAS CIVIL DNISION v~ IF THIS IS THE FIRST NOTICE THAT YOU HAVE RECEIVED FROM THIS OFFICE, BE ADVISED THAT: PURSUANT TO THE FAHt DEBT COLLECTION PRACTICES ACT, 15 U.S.C. § 1692 et seq. (1977), DEFENDANT(S) MAY DISPUTE THE VALH)ITY OF THE DEBT OR ANY PORTION THEREOF. IF DEFENDANT(S) DO 50 IN WRITING WITHIN THHtTY (30) DAYS OF RECEIPT OF THIS PLEADING, COUNSEL FOR PLAINTIFF WILL OBTAIN AND PROVIDE DEFENDANT(S) WITH WRITTEN VERIFICATION THEREOF; OTHERWISE, THE DEBT WILL BE ASSUMED TO BE VALID. LIKEWISE, IF REQUESTED WITHIN THIRTY (30) DAYS OF RECEIPT OF THIS PLEADING, COUNSEL FOR PLAINTIFF WILL SEND DEFENDANT(S) THE NAME AND ADDRESS OF THE ORIGINAL CREDITOR, IF DIFFERENT FROM ABOVE. THE LAW DOES NOT REQUIRE US TO WAIT UNTIL THE END OF THE THIRTY (30) DAY PERIOD FOLLOWING FIRST CONTACT WITH YOU BEFORE SUING YOU TO COLLECT THIS DEBT. EVEN THOUGH THE LAW PROVIDES THAT YOUR ANSWER TO THIS COMPLAINT IS TO BE FILED IN THIS ACTION WITHIN TWENTY (20) DAYS, YOU MAY OBTAIN AN EXTENSION OF THAT TIME. FURTHERMORE, NO REQUEST WILL BE MADE TO THE COURT FOR A JUDGMENT UNTIL THE EXPIRATION OF THIRTY (30) DAYS AFTER YOU HAVE RECEIVED THIS COMPLAINT. HOWEVER, IF YOU REQUEST PROOF OF THE DEBT OR THE NAME AND ADDRESS OF THE ORIGINAL CREDITOR WITHIN THE THIRTY (30) DAY PERIOD THAT BEGINS UPON YOUR RECEIPT OF THIS COMPLAINT, THE LAW REQUIRES US TO CEASE OUR EFFORTS (THROUGH LITIGATION OR OTHERWISE) TO COLLECT THE DEBT UNTIL WE MAIL THE REQUESTED INFORMATION TO YOU. YOU SHOULD CONSULT AN ATTORNEY FOR ADVICE CONCERNING YOUR RIGHTS AND OBLIGATIONS IN THIS SUIT. „v Plaintiff is GMAC MORTGAGE CORPORATION 3451 HAMMOND AVENUE P.O. BOX 780 WATERLOO, IA 50704 2. The name(s) and last known address(es) of the Defendant(s) are: JEFFREY L. FUIIRMAN LAURIE A. FUHRMAN 430 CROSSROADS SCHOOL ROAD CARLISLE, PA 17013 who is/are the mortgagor(s) and real owner(s) of the property hereinafter described. 3. On 8/27/99 mortgagor(s) made, executed and delivered a mortgage upon the premises hereinafter described to ACCUBANC MORTGAGE CORPORATION which mortgage is recorded in the Office of the Recorder of CUMBERLAND County, in Mortgage Book No. 1569, Page 479. By Assignment of Mortgage dated 5/8/00 the mortgage was assigned to PLAINTIFF which Assignment is recorded in Assignment of Mortgage Book No. 647, Page 629. 4. The premises subject to said mortgage is described as attached. 5. The mortgage is in default because monthly payments of principal and interest upon said mortgage due 3/1/01 and each month thereafter are due and unpaid, and by the terms of said mortgage, upon failure of mortgagor to make such payments after a date specified by written notice sent to Mortgagor, the entire principal balance and al] interest due thereon are collectible forthwith. A copy of such notice is attached as Exhibit "A." 6. The following amounts are due on the mortgage: Principal Balance $127,788.57 Interest 5,416.32 2/1/01 through 8/1/01 (Per Diem $29.76) Attorney's Fees 4,000.00 Cumulative Late Chazges 39.38 8/27/99 to 8/1/01 Cost of Suit and Title Search 750.00 Subtotal $137,994.27 Escrow Credit 0.00 Deficit 196.98 Subtotal $ 196.98 TOTAL $138,191.25 7. The attomey's fees set forth above are inconformity with the Mortgage documents and Pennsylvania Law, and will be collected in the event of a third party purchaser at Sheriffs Sale. If the Mortgage is reinstated prior to the Sale, reasonable attorney's fees will be chazged. 8. This action does not come under Act 6 of 1974 because the original mortgage amount exceeds $50,000.00. 9. The Combined Notice has been sent to the Defendant(s) by regular and certified mail as required by 35 P.S. § 1680.403c on the date(s) set forth in the true and correct copy of such notice(s) attached hereto as Exhibit "A." 10. The Temporary Stay as provided by the Homeowner's Emergency Mortgage Assistance Program, Act 91 of 1983, has terminated because either: (i.) Defendant(s) have failed to meet with the Plaintiff or an authorized Credit Counseling Agency in accordance with Plaintiffls written Nofice to Defendants, a true and correct copy of which is attached hereto as Exhibit "A"; or (ii.) Defendant(s) application for assistance has been rejected by the Pennsylvania Housing Finance Agency. WHEREFORE, PLAINTIFF demands an in rem Judgment against the Defendant(s) in the sum of $138,191.25, together with interest from 8/1%Ol at the rate of $29.76 per diem to the date of Judgment, and other costs and charges collectible under the mortgage and for the foreclosure and sale of the mortgaged properly. ~~~ /s/ Frank Federman FRANK FEDERMAN, ESQUIRE Attorney for Plaintiff First Mgrtgagc Loan Servicing PO Box 85071 San Diego CA 92186-5071 3451 Hammond Ave PO Box 780 Waterloo fA 50704-0780 ~ li/iGit"~:~~~C' Date: June 12, 2001 1~C7' 91 l~Orl'1C1~, F®~~~~~ J~~~~~ This is an official iioticc lhai tP~c mm•tgagc. mi your home is in dcfauli, anti (hc Iciidcr iiitciids to fm•cciosc, Specific infm•mation about the nature of the. dcfauli is provided in the attached pages, The I101171bOW'Nb;K'S MOR'1'(:AGA; ASSIS'I'ANCI+,1'kOGKAM (111+.MAl') may be able to hclli to save ,your homc._This Notice explains how the program works. To sec. if II>';h1Al' can help,,you must MRA;T WI'1'}I A CONSUMF,K CRN;I)I'I' COUNS>';LING AGENCY \3'1'17UN 30 DAYS OF'1'11 Y; ]L177? OF'I'1llS NO'1'ICY;. '1'akr. this Notice with y0U N'heli y'OU ISiCM N'Itb thr Counseling Agency. The name, address and phone number of Consumer Credit Comiseling Agencies serving your Comely arc listed at the end of tliis Notice.. If you Lave any qucslimis, you may call the Pennsylvania Dousing Finance Agency loll free at ]-800-342-2397. (Persons whir impaired hearing can call (7)7) 780-78G9). This Nolicc. contains inilim•fanl Icgal infm•matim~. If you have any questions, represcntalives al tLe Consmncr G•cdit Coiuitetiug Agcaicy may be able /o help cslilai~i it. You niay also want to contacf aii atim•ncy iii yoor area. The local bar association may be able. to help you find a lawyer. l,A V0'1')1~ICAC)ON J?N AllJUN'1'O U;S 1)1<: Sl1itIA)nhJ'Ok'J'ANC;IA,1'IJJ±S AJ~1±C'1'A SU Al?JLb;C170 A CON'J']NUAIt VIVJI+,NDO P;N SU CASA. SI NO COM)'kI+,NDI? ISI. CON'1'N;NIllO llP;1?5'I'A NO'1'11~1CA(:10N Oli'1'1<:NCA I1NA T1tADUCCION 1MMP;J)lA'1'AMp,N'I'h;1,I,AMANDO 1~;5'1'A AG1?NC1A (1'A;NNSYI.VANIA HOUSING FINANCA; AGl?NCY) SIN CAKCOS Al. NUMF,KO M1CN(:IONADO AK1tlIfA. )'IIF.l)1<',S SA;)t A;1J?(:))i1,A;1'AItA t1N 1'kl?S'1'A1190 TOIL h;l.)'ROCkA\1,t ),J,A19AA0 "BO\11±OW'NP;k'S A;MF.k(:P;NCY MOIL'1'GAGT; ASSIS'1'ANCI+, I'ILO(:kAM" KL CIIAJ, J'UP;J)J± SAI,VAI( Sll CASA 1»S I,A PISkJ» I)A DPSI, DN;ILl±CIIO A R)~;J»MJJt SU }ll)'O'17~:CA DoMro~~:~l';k's Nn;,II~;(s): 1'k01'A;IYJ'Y A])1)RL;SS: LOAN ACCT. NO.: Okl(:JNAIJ,ISN1» bk: CUkk)~;N'1' I,KNDN;klSI;RI'1Cb;k: JEFN'k}':Y 1.. FUHkMAN 930 CROSSkOAllS SCHOOL kll CARLISLE, PA 17013 306769329 N/A GMRC Mortgage Corporation EXHIBIT A First Idvrtgvkv l van Svrvioing PO Box 85071 San Diego CA 9?t 86-5U i 1 3455 Namri~ond Ave PO Box 780 Waterloo IA 50704-0780 ~.~~~ ~4RGt'L~~:~C. Date: June 12, 2001 ~.C7C 41 1`T~T'I C~: FO~~J~~./V U.A. 'J This is an official notice that tlic. ma•tgage mi your hmiie. is iii default, and lhc. Iciider iiitciids iv foreclose, Specific irifoe•iiiat:mi about the uat,irc of thr default is lirovided iii ihr. attached l;agcs. The IIO\1T,0\\'NI?lt'S MOR'I'GAGI+, ASSISTANCP; I'120GRAh1(IiAMAI') may lie able to help to save your horoc. This Notice cxplaiiis how llic.ln•ograiii works. To sec if 11T,MAP can help, you must MP;1~;1' WIT}) A CONSUMI+,R CRN;DI'1' COUNSAI,ING AGN;NCY Vh7T111N 30 DAYS OP Tll>'; DATN; 01+T}11S N0T1Cb;. Take this Notice with ,you when you meet with the. Counseling Agency. The name, address and phone number of Consumca• Credil Comiscliiig Agencies seining yom• Comely arc listed at the end of this Notice. If you have any qucslimis, you may call the Pennsylvania IIousing Tinance. Agency toll free. al ]-800.342-2397. (Persmis with imliaired hearing caii call (717) 780-I869). This Notice contains iiiiliortant legal information. If you have. any questions, representatives at the Consmncr Credit Counseling Agency may be able. to helli exlilaiii it. You may also wain to cmitacf au aiim•iicy iii your area, The loc.:d bar association Wray hr. able to hells you find a lawyer. I,A NO'1'1F1CAClON 1?N AllJUN'1'O I+,S DI7, SUMA Ih11'Olt'I'ANCIA, PUI+,S APF.C'1'A SU lll?l0';CIlO A CON'1'INUAIt YIYIP;NDO ISN SU CASA. SI NO COMYRA;NI» S b;l. CON'I'A;N71)O Dh: b:STA NO'1'll+1CAC10N Oli'1'1+,NCA UNA'1BADUCCION IMMP7)IATAMN;N'!'A; I,I,AMANDO I+,S'1'A AGN;NCIA O'P;NNS1'1.\'ANIA liOl1S)NC TINANCI+, AG1?NCY) S]N CARGOS AL NUh1P;R0 MI?NC10NAll0 Ak1tllIA. I'17A7>I';S SIdR A;).A:(:))D.>•; YARA 11N I'RISSTAMO 1'OR )';]. YROGRAMA ).).AMADO "1:OA11+,0\\'NP;1t'S h;MP;lt(:F,NCY MOIt'I'GAGI± ASSIS'1'ANCP;1'RO(:RAM" b;l, C1JAL I'lJl±1)P; SAL\'Alt Sll CASA lll? I,A )'T+;RI)1))A DEI, llF,12P;C110 A RP;D11.111t Sll Illl'O'1'P;CA tlo;,n~.owNVars Na;,n~;(s): 1'k01'P7t'I'Y A1)llP.P;SS: 1,OAN ACCT. NO.: O1tH;INA1, IJ?NIN~;It: Cl1R1t1CN'1' 1.P;N1)T;R/SPaiVICN;R: LAURI F: A, F'UkIRMAN 930 CROSSROADS SCHOOL, Rll CARLI SLF:, PA 1%013 306769329 N/A GMAC Mortgage Corporation EXHIBIT A IiONIP:O\V'Nh;1t'S 1?R~lh;lt(:1?V'C)' MOIt'1'CA<:1~; ASS1S'1'ANCl? 1')LO(:kA\h YOU MAY 13A;1?Ll(;11i],1+, ROk FINANCIAL, ASSIS'1'ANCh; WI31CR CAN SAVI± YOUR }IOMP: FILOD9 FOIO~;CI,OSURY; AN]) IIF.1.)' YOII MAK)t 1~U'1'UItF, MO1Z'TCAGY: l'AYnII?N'1'S 11' YOU CO1311'1,Y \\'1'1'll'17D+, 1'kOVIS1ONS OF'1'liA; )lOA1P:0\4'NAat'S P:MP;It(:P:NC:Y MOItTGACI? ASSIS'fANCb: ACT OF 1483 (T}ih; "AC7"'),YOU MAY RF, P:I,IGI1s1,A: FOk N:MA;kGNNCY MOkTGA(:N: ASSIS'1'ANCK: 1F YOUk DA:FAUIJ' HAS 13N;N:N CAUSN:1)1SY CIkGUMS'1'ANCNS YOUk CON'I'kO1., IF YOU 11AVN: A kILASONAIiI.I? YROS)'1+,CT Oh ]iP;ING A1SI,1?'1'O YAY YOUk MOkT(:AGN;1'AYM)};N'1'S, AND Ih YOU M1Ch°I' O'1'li1Sk I+I,IG)lill,l'1'Y kA:QU1kA:MP:N'I'S F.STA]31,1SR1?ll ]iY T}IA: )'}?NNSYI,VANIA }LOUSING FINANCb: ACN;NCY, 77±Dh1'OkAkY S"1'AY Ol' 1+Oltl?C;I,OSUKP: --Lander the Act, you are entitled to a tempmaty stay of foreclosure on your mmigage fm thirty (30) days from the date ofthis Notice. During that time you must arrange and attend a 'Pace-to-face" meeting with one of the consumer credit counseling agcncies listed at the end o1-this Notice. T111S hUSl+;1')NC MUST OCCUk Wl'1'111N'1'}1F, NA;Y'1' (30) llAYS, I)' YOt1 ll0 NOT Al'1'L}' FOIL ]SM]±RG11NC'l' h1Ok'1'(iAGI~: ASS1S'I'ANCP:,1'OU MUST Blt]NCi l'OUK;v1OR'1'CiACi]': Ul' 7'O ]hi"I'1S.'1'11h:1':1R'1' OP T1llS NO7'1C1i CAI"1,1sll "11OR' 7'O C111t1i YO111t 1v1OJ2"PCiACi1i ll1i]'A111:1"', };XPI,AINS 110\\' 7'O}31t1NCi 1'OIiR MOR"1'CiACili lit' "I'O DA"17?. ('ONSUMA;1t CHP;DI'1' COUNSI?I,INC ACP:NCI1?S -- ]f you meet with one of the consumer credit counseling agcncies listed at the end ofthis notice, the Lender may NO7' lake action against you for thity (30) days after the date ofthis mceting.The names, addresses and telephone numbers of designated consumer credit counseling agencies for the. county in which the }» npetly is located are set fmLh at the end ofthis Notice. It is only necessary to schedule mte face-to-face meeting. Advise your lender immediately of your intentions. Al'1'1,1CA'I7ON FOR MOIa'(:AGN; ASS1S'1'ANCT: --Your mortgage is in defmdt fm'the reasons set fmih later in this Notice (see following pages for specific information about the nature of your default.) If you have tried and are tenable to resolve this problem with the lender, you have the right. to apply for financial assistance from the llonteowner's P.mergency Mortgage Assistance Program. To do so, you nntst 1i16 out, sign and file a completed llomeowner's P,mergency Assistance Program Application with one of the designated cmtsumer credit counseling agencies listed at the end ofthis Notice. Only consumereredit counselfng agencies have applications forthe pmgmm and they will assist you in submitting a complete application to the Pennsylvmtia 3lousing Pinaitce Agency. Yourapplication MUST be filed orposdnarked within thirty (30) days ofyou face-to-face meeting. YOU MUST hll,l? YOUR AlT],1CA'17ON )'kOMI''1'l,Y. ll~ YO'U FA1L'1'O DO SO Olt D~' YOU ll0 N0T 101,1.0\V' T]ll? O'1'}]h7t'1'IMh;1'FJt1O1)S SF; 1' TOkT}I 1N'1'13151,1?7"1'P:1L,F0}tP:C],OSUItI+, MAY )'}tOCP7<:b AG,11NS'1' YOllk )IOMP:ln9nh)?lllA'17?1.Y AND YOUR A)'TI,ICA'1'lON P'Olt MOR'1'CACA: ASS1S"1'ANCA: \Vll,l. )iA; llP:NIP;ll. ACh;ti(:Y ACTION -- Available. fiends lbremcrgency nxtrtgage assist;nn:c arc. very limited. They will he dishutzed by lhc. Agency underthc eligibility criteria established by the Act. "17ta J'ennsylvmtia ]lousing Finance Agency has sixty (60) days ut make. a decision after it receives yourapplication. lluring that time, no fwedosure. proceedings will he putsucd against you if you have met the time requirements set forth above. 1'ou will he notified directly by the Pennsylvania llousing Finance Agency of its decision mt your application. EXHIBIT A NO'1'P;: 11' YOU Altl? CllltltlSN'1'1,Y I'ROTP:C'17?ll l1Y 771 N; TILING OI+ A 1'1':1'1'170N 1N BANKRU)''1'CY, 77i)? TOld,Oq'ING I'A)tT OI+77315 NO'1'1CP;15 rOR INI+OItMAT)ON I'l))tl'OSl?5 ONLY AND S110UI,D NOT 151± CONSII)P:IiPa) AS AN A'1"1'1?Pr11''1"I'O CO1,1,F,C'1"1')1P:1)P:)f1'. (If you have filed ba~ikrulitcy you eau still alrply fm• I+,mergc~icy D9m•tgagc Assistance.) AO\4''1'O CUlO? YOUR MOlf1'GA(:A; Dr:rnul,7' Oaring it up to date). NA'l'l]Rl? Oh'1'11P:1)1?hAlll,]' --'1'hc. M0127'GAG1S debt held by the above Icndca is on your ]nnpcaiy located at 930 Crossroads School Rd Carlisle, PA 7'/013 ]S S}':X]OUS1~Y 7N llA:P'AU1,9~ because: YOIJ 11AV1? NOT MAllI' b10N'1'll],Y MORTGAGh:1'AYbUtN'1'S for the following mmrihs and the f o]]owi ng amounts are now past. due: Mar<:h ], 200] through June 1, ?007. Sce attached Exhibit. for payment breakdown. Monthly I'aymcnts 9 , 988.2£3 late Charges 39.38 NSl' 0.00 Inspections 0.00 Other Suspense 5 4 2. 9 5 TOTAL, AhtOUN'1' I'A5T DUI':: 3,984.71 l;. }'OlJ I L1Vli 1+A11,1{ll •1'O'1'AKl'. 7'llli POLI,OW 1NG AC770N (Dq ngh~se if not applicable): }IO\\''1'O CU)t)?'1'lll+, b1+,1~A111,1' --You may cure the defmdt within TI]1R7Y (30) DAYS of the date of this notice 1SY )'AY1NG T}lA'1'O'I'Al, Ah10UN'I' l'AS'1' llUP:'1'O T}IP; I,N;NI)PJ2, W}17(;11IS $ 3, 989. "/1 ,1'L1JS ANY MOR•1'GACiP:1'AYM]?N'1'S ANll I,A'17': Cll~U2G1?S W11K;U 1i1iCOM]': lll;]•: ll1JK]N(i 7'111! 771112"1'1' (30) llAY 1'1'RIOll. Payments must he made either by cash, cashier's check, ccriilicd check m' mmieY order made payable and sent to: Payment Processing GMAC Mortgage Corporation PO Box 780 Waterloo, IA 50'/09-0780 You cmi cure any other dofatdt by taking the following action within "1')11R'1'l' (0) DAYS of the. date of this letter: (Do not use ifnotapplicablc') Not App] i cab] e 1h YOU ll0 N0T CUILA;'1'IIP; I)1~:FAUL'1' -- ]f you do not cure the default within T7llA1'Y (30) llAYS of the date of this Notice, the lender intends to exercise its rights to accelerate the nrm•tgage debt. This means that the entire outstanding balance of this debt will he considered due innnediately and you may lose the chance to pay the mortgage in monthly installments. ]f fill payment ofthe total amount past due is not made within 7711RTY (30) llAl'S, the lender also intends to instinct its attorneys to start legal action to foreclose upon yom• mortgaged propcrcy. IF'171P; MOR'1'CACh: IS TOILF,CI,OST,D UPON -- The mortgaged pmper<y will he sold by the Sheriff to pay off the moris;afc de}rt. Ifthc haidci ~CScis your case to its attorneys, but you our the. delinqucauy bcfm~: the. Icndca begins Icgal proceedings against you, you will still he required to pay the reasmtahle attorney's fees that were actually incurred, up to $50.00. I]owevcr, if legal proceedings are started against against you, you will have to pay all reasonable atorney's foes actually ineurn:d by the Icndca• oven ifthcy exceed $>0.00. rlny atunncy's fees will be added to the anunmt you owe the lender, which may also include other ~t:asonahlc costs. If yon cure the default witiiin llic T1{)R'1'Y (30) DAYS period, you will not be required to pay a/iorucy's fecs• EXHIBIT A O'17ilSR 1.15N1)P;It lOSMP:DIP:S --'1'hc lender may also sue you personally for the unpaid principal balance and all otJter sums due under the nuirlgage. R1Cli'1")'O CURL+,'171151» ?TAlJl;1' 1'RlOlt'1'O SIIA;RIRF'S SALN: -- If you have not cured the default within the "1'l]IR7'1' (30) DAl' period acid foreclosure proceedings have begun, kou still have the right to cure the default and prrvenl the sale at any time up to one hour bcfm•e the Sheriffs Sale. You may do so by paying the total amount then past due, plus any late or other chames then due, reasmtable attorney's fees and costs connected with the }'oreclostne sale and any othcrcosts connected wit7t the Sheriffs Sale as specified in writing, by the lender and Ity pcrforn»ng any other requirements under the morigaee. Cm•ing your default in the mariner set fm•tli in flits notice will resim•e your ~rim•fgage to the sa~ue position as if you had never defaulted, Y:A1t1.1155'1' 1'OSS1111,R, 511P7UTF'S SAI,1? DATA -- ]t is estimated that the earliest date that such a Sheriffs Sale ofthe nunigaged properly could be held would he apltroxiuiately six (6) mm~ths koiti the date of tills Nolicc. A notice. of the actual date of the Sheriffs Sale will be sent to you before the sale. Of course, the amount needed to cure the default will increase Ote IonPCryou wail You may find out at any time exactly what the required payment or actimi will he by contacting the lender. 11OVY'PO CON'7'AC"1"1'11 L;1.)SNl)P7t: Name of Lender: GMAC Mortgage Corporation Address: 901 Mile of Cars Way National City, CA 97950 Phone Nwnber: (800) 850-9622 Fax Nwnbcr: (619) 9'/0-55'!9 Contact Person: Collection DepartmenC Rh1~P:C"1' OT 5111+,)t1171'S SA1J? --You should realize that a Sheriffs Sale will end your ownership of the mortgaged property and your right to ocagty ii. If you continue to live in the property after the Sheriffs Sale, a lawsuit to remove you and your fi~mishings and other belongings could he started by the lender at any time. ASS_ UIDiI"1'lON 01~ MOR'fGACA; --You may or may not sell or transfer your borne to a buyer or transferee who will assume the mortgage debt, provided that all the outstanding payments, chames and attorney's fees and costs are paid prior to or at Ote sale and that the other requirements of the mortgage are satisfied. YOU MAY ALSO RAVR 71115 RICH'1': 7~ SP7.). "I'HI(1'KOPI Jt"1'Y '1'O OBTAIN b1ON1'.Y 7'O I'AY O1T '1'11): MOK'1'(iAGI' 1»iB7' OK TO BO1tkOW MONK}' P1tOM ANOTllP,K 1,]iNllING 1NS'1T1'tl'17ON TO 1'AY 017 THIS ll1?BT. '1'O HAVIy; "17]]S ll]?pAlJl;l C1JKI?ll BY ANY'I']]lltll ]'ARTY ACTING ON YOlJK 111i11~U.F. 7'O llAVli 7711± MOR7'GACJIi kl?S7bR)?ll TO Tlll{ SAMh: POSI'17ON AS 1)' NO DP.PAIII:I' HAD OCCIJItItI'.ll,1F YOli CIAt]S'1711L ll1SFAl71a'. (I]OWh:Vh7i, YOL' ll0 NO"f 11AVP:'I'HIS KKilI'f'fO CUKIi YOl1K llb7~A171;1' MOKh:'f11AN "1'HKP7'.'17MP:S IN ANY CAI,I±NDAK YI?AK.) 'f0 ASS77t'1"1'11]', NONI'.X1S"1'P;NC]! Ol' A ll]'TA111:1' ]N ANY FO1O'C].OSUKI•;1']tOCI'.1~aING OK :1NY O'17ll'7Z I.AWSI'1'1'1X~S'1'I'I'l''17':D l'Nl)1'R'I'111' MOR'I'(iAG7':llOC'l'?vAl'N'fS, 1'O ASSI!K'1' ANY O'1'lI1;K llltp]•.NSb:l'Oli R]'.l.ll(VI', YOIi MAC' IL1Vli'1'O SliCll AC'17ON BY 7']ll~. ],b:Nll]iR. "I'O S13){K ]'KO77~;(:'17ON I;NllSK 77ID; ]7(ll](K;11. BANKKIJI''1'CY LAW. CONSUM)';lt CRP7»'1' COUNSISI,ING AGN;NC115S S151tV1NG YOUR COUN'T'Y 1S 14NCLOSISD EXHIBIT A. PENNSYLVArYIA HOUSING FINANCE AGENCY HOMEOWNER'S EMERGENCY ASSISTANCE PROGR,4~I CONSUMER CREDIT COUNSELING AGENCIES (REV. S/00) CL[NTON COUNTY Lycoming-Clinton Counties Commision for CCCS ofNOriheastem PA Cornmuniry Action (STEP) 1631 South Atherton St., Suite 100 2138 Lincoln Stree[ P.O. Boz 1328 State College, PA 16801 Williamsport, PA 17703 (Sl4) 238-3668 FAX (814) 238-3669 (570) 326-0587 FAX (570) 322-2197 CCCS of Northeastern PA 201 Basin Street Williamsport, PA 17703 (570) 323.6627 FAX (570) 323.6626 3l ~ W. Market Street POB 1127 Wilkes-Bane, PA 18702 (570) 821-0837 or (800) 922-9537 FAX (570) 821-1785 COLUAIBIA COL^~"PY Commission on Economics Opportunity of Luzeme County 163 Amber Lane Wilkes-Bane, PA 18702 (570) 326-0510 or (800) 822-0359 FAX (570) 829-1665-(Call Before Faxing) (570) 4553994 Haultown FAX (570) 455-5631-(Call Before Faxing) (570)836-4090 Tunkhannock CRAWFORD COUNTY Booker T. Washington Center 1720 Holland Center Erie, PA 16503 (814) 453-5744 FAX (814) 5749 John F. Kennedy Center, Inc. 2021 East 20'" Stmt Erie, PA 16510 (8!4)898-0400 FAX (814) 898-1243 CCCS of Western Pennsylvania, Inc. 2000 Linglestown Road Harrisburg, PA 17102 (717)541-1757 Urban League of Metropolitan Harrisburg N. 6'" Sveet Harrisburg, PA 17101 (717) 234-5925 FAX (717) 234-9459 Community Action Comm of the Capital Region 1514 Deny Street Harrisburg, PA 17(04 (717) 232-9757 FAX (717) 234-2227 CUMBERLAW COUNTY 1400 Abington Executive Pazk Suite I Clarks Summit, PA 1841 I (570) 587.9163 or (800) 922.953 i FA3C (570) 587-9134.9135 Grearer Erie Community Action Committee IS West 9'" Street Erie, PA 16501 (814) 459-4581 FAX (8(4)156-0161 Shenango Valley Urban League, inc. 601 Indiana Avenue Farrell, PA 16121 (412)981.5310 Financial Counseling Services of Franklin 31 West 3`°Street Waynesboro, PA 17268 (717)762-3285 YWCA of Carlisle 301 "G" Street Carlisle, PA 17013 (717) 2433818 FAX (717) 731-9589 Adams Cowry Housing Authority 139-143 Carlisle St. Gettysburg, PA 17325 (717) 334-1518 FAX 334-8326 PEYNSYLVANL\ BULLETIN, VOL. 29, N0.23, JUNE S, 1999 EXHIBIT A ALL that ceilain a•act of land with improvements dtereon erected statue in West Pennsboro Township, Cumberland County, Pennsylvania, more fully bounded and described in accordance with a plan prepared by Rodney Lee Decker, R.P.[..S., dated January 22, 1993 and recorded in the Office of the Recorder of Deeds for Cuntbertand County in Plan Rook 66, Page f U4, as follows: BEGINNING at a point nn soudtern right-of-way line of Cross Road Schnul Road, T- a33 at line of Lot No. SZ; theme along Lot No. 52, Suudt 32 dcgreus 50 minutes UO seconds West 353.91 feet to a point; thence along Phase 3 of Q'oss Road School Road Lstates, North G7 degrees 04 minutes 45 seconds West 112.U5 feet to a point in southern edge of Watson Drive; thence along southern edge of Watson Drivt: by a curve to lire Icli having a radius nF 2t1U.00 kct and an arc distance of 99.02 feet (v a point; !hence still along southcm edge of Watson Drive by a curve to the right having a radius of 150.00 and mt arc distance of 191.63 feet to a point thence sti11 along Watson Drive North 44 degrees US minutes 05 seconds Gast 332. to a point creating the intersection of Watsou Drive and Cross Road School Koad; ptt:nce along seta fntcrsccuun uy a curve to the right having a radiw of ?5.00 feet and an arc distance of 35.51 Feet «t a pouts in western edge ol'Cross Road School Road; thence along western edge ol'Cros's Road School Raad ty a curve to the Teti having a radius of I,ICG.00 and an etc distance of 149.65 feet In a point AND the said Grantor hereby eovenam and agree that it will wun•ant specially the property hereby conveyed. 'fHE Grantor doth hereby constitute and appoint John I~t. pox and E•!v'ry I•I. fox, Jr., to be its attorney for it, and in its name and as and for its cor(toratc oct and Jeed to acknowicdgc this Deed hcfore any person having authority by the Taws of the Commonwealth of Pennsylvania to take such acknowledgment, to the intent that the same may be duly recorded. 1N WITNLSS \VIiEREOi,, the said Grantors has caused this Deed to he signed in its coritorate names by its President and has caused to be affixed hareanto the common and corpo+ate seal of the said coq>orttions, attested by its Secretary, the day and year first above a~riucn. PREMISES: 430 CROSSROADS SCHOOL ROAD VERIFICATION KRISTINE'iVII,SON hereby states that she is FORECLOSURE SPECIALIST of GMAC MORTGAGE CORPORATION mortgage servicing agent for Plaintiff in this matter, that she is authorized to take this Verification, and that the statements made in the foregoing Civil Action in Mortgage Foreclosure are true and correct to the best of her knowledge, infom~ation and belief. The undersigned understands that this statement is made subject to the penalties of 18 Pa. C.S. Sec. 4904 relating to unswom falsification to authorities. DATE: / Q p C~ ~ ~ ~~ -~- _ - , ~i ~' v \r 1_/I ~ 1 ~~ r~ -; = c::: __ t ~' ~ ~, ~_~`' =_ ~ _, J N! ~l SHERIFF'S RETURN - REGULAR rASE IVO: 2001-04820 P COMMONWEALTH OF PENNSYLVANIA: COtjNTY OF CUMBERLAND GMAC MORTGAGE CORPORATION VS FUHRMAN JEFFREY L ET CPL. MICHAEL BARRICK Sheriff or Deputy Sheriff of Cumberland County,Pennsylvania, who being duly sworn according to law, says, the within COMPLAINT - MORT FORE was served upon FUHRMAN JE DEFENDANT the at 2108:00 HOURS, on the 21st day of August 2001 at 430 CROSSROADS SCHOOL ROAD CARLISLE, PA 17013 LAURIE FUHRMAN by handing to a true and attested copy of COMPLAINT - MORT FORE together with and at the same time directing Her attention to the contents thereof. Sheriff's Costs: Docketing 18.00 Service 5.20 Affidavit .00 Surcharge 10.00 .00 33.20 Sworn and Subscribed to before me this 3b ~ day of A.D. othonotary So Answers: ~~~~ R. Thomas Kline 08/21/2001 FEDERMAN & PHELAN By: Dep y eriff „ _ SHERIFF'S RETURN - REGULAR CB.SE NO: 2001-04820 P COMMONWEALTH OF PENNSYLVANIA: COUNTY OF CUMBERLAND MORTGAGE CORPORATION VS FUHRMAN JEFFREY L ET AL CPL. MICHAEL BARRICK Sheriff or Deputy Sheriff of Cumberland County,Pennsylvania, who being duly sworn according to law, says, the within COMPLAINT - MORT FORE was served upon FUHRMAN LAURIE A DEFENDANT the at 2108:00 HOURS, on the 20th day of August 2001 at 430 CROSSROADS SCHOOL ROAD CARLISLE, PA 17013 by handing to LAURIE FUHRMAN a true and attested copy of COMPLAINT - MORT FORE together with and at the same time directing Her attention to the contents thereof. Sheriff's Costs: Docketing 6.00 Service .00 Affidavit .00 Surcharge 10.00 .00 16.00 Sworn and Subscribed to before me this .?o ~ day of Pr onotary ~ So Answers: ~~~~ R. Thomas Kline 08/21/2001 FEDERMAN & PHELAN By: Deputy Sheriff ~~ FEDERMAN AND PHELAN By: FRANK FEDERMAN Identification No. 12248 One Penn Center at Suburban Station Suite 1400 Philadelphia, PA 19103-1814 (215) X63-7000 GMAC MORTGAGE CORPORATION 3451 HAMMOND AVENUE, P.O. BOX 780 WATERLOO, IA 50704 Plaintiff vs. JEFFREY L. FUHRMAN LAURIE A. FUHRMAN 430 CROSSROADS SCHOOL ROAD CARLISLE, PA 17013 Defendant(s) Attorney for Plaintiff :CUMBERLAND COUNTY COURT OF COMMON PLEAS CIVIL DIVISION NO. 01-4820 CIVIL PRAECIPE FOR JUDGMENT FOR FAILURE TO ANSWER AND ASSESSMENT OF DAMAGES TO THE PROTHONOTARX: Kindly enter judgment, in rem, in favor of the Plaintiff and against JEFFREY L. FUHRMAN and LAURIE A. FUHRMAN, Defendant(s), for failure to file an Answer to Plaintiffs Complaint within 20 days from service thereof and for foreclosure and sale of the mortgaged premises, and assess Plaintiffs damages as follows: As set forth in Complaint $138,191.25 Interest 8/1/01-9/28/01 $1,755.84 TOTAL $139,947.09 I hereby certify that (1) the addresses of the Plaintiff and Defendant(s) are as shown above, and (2) notice has been given in accordance with Rule 237.1, copy attached. FRANK FEDERMAN, ESQiJIRE Attorney for Plaintiff DAMAGES ARE HEREBY ASSESSED AS INDICATED DATE: PRO PROTI~ **TH[S FAtM IS A DEBT COLLECTOR ATTEMPTING TO COLLECT A DEBT AND ANY INFORMATION OBTAINED WILL BE USED FOR THAT PURPOSE. IF YOU HAVE PREVIOUSLY RECENED A DISCHARGE IN BANKRUPTCY AND THIS DEBT WAS NOT REAFFII2MED, THIS CORRESPONDENCE IS NOT AND SHOULD NOT BE CONSTRUED TO BE AN ATTEMPT TO COLLECT A DEBT, I3UT ONLY ENFORCEMENT OF A LIEN AGAINST PROPERTY. ** a' "~ FEDERMAN AND PHELAN, L.L.P. Frank Federman, Esquire Identification No. 12248 One Penn Center Plaza at Suburban Station, Suite 1400 Philadelphia, PA 19103-1799 (215) 563-7000 ATTORNEY FOR PLAINTIFF GMAC MORTGAGE CORPORATION Plaintiff vs. JEFFREY L. FUHRMAN LAURIE A. FUHRMAN Defendant(s) TO: JEFFREY L. FUHRMAN 430 CROSSROADS SCHOOL ROAD CARLISLE,PA 17013 DATE OF NOTICE: SEPTEMBER 11,2001 THIS FIRM IS A DEBT COLLECTOR ATTEMPTING TO COLLECT A DEBT. THIS NOTICE IS SENT TO YOU IN AN ATTEMPT TO COLLECT THE INDEBTEDNESS REFERRED TO HEREIN, AND ANY INFORMATION OBTAINED FROM YOU WILL BE USED FOR THAT PURPOSE. IF YOU HAVE PREVIOUSLY RECEIVED A DISCHARGE IN BANKRUPTCY, THIS CORRESPONDENCE IS NOT AND SHOULD NOT BE CONSTRUED TO BE AN ATTEMPT TO COLLECT A DEBT, BUT ONLY AS ENFORCEMENT OF LIEN AGAINST PROPERTY. IMPORTANT NOTICE You are in default because you have failed enter a written appearance personally or by attorney and file in writing with the court your defenses or objections to the claims set forth against you. Unless you act within ten (10) days from the date of this notice, a Judgment may be entered against you without a hearing and you may lose your property or other important rights. You should take this notice to a lawyer at once. If you do not have a lawyer or cannot afford one, go to or telephone the following office to find out where you can get legal help: CUMBERLAND COUNTY CUMBERLAND COUNTY BAR ASSOCIATION 2 LIBERTY AVENUE CARLISLE, PA 17013 (717)249-3166 COURT OF COMMON PLEAS CIVIL DIVISION CUMBERLAND COUNTY NO. 01-4820 CIVIL Frank Federman, Esquire Attorney for Plaintiff • •' FEDERMAN AND PHELAN Frank Federman, Esquire Identification No. 12248 One Penn Center Plaza at Suburban Station, Suite 1400 Philadelphia, PA 19103-1799 (215) 563-7000 GMAC MORTGAGE CORPORATION Plaintiff vs. JEFFREY L. FUHRMAN LAURIE A. FUHRMAN Defendant TO: LAURIE A. FUHRMAN 430 CROSSROADS SCHOOL ROAD CARLISLE,PA 17013 DATE OF NOTICE: SEPTEMBER 11,2001 THIS FIRM IS A DEBT COLLECTOR ATTEMPTING TO COLLECT A DEBT. THIS NOTICE IS SENT TO YOU IN AN ATTEMPT TO COLLECT THE INDEBTEDNESS REFERRED TO HEREIN, AND ANY INFORMATION OBTAINED FROM YOU WILL BE USED FOR THAT PURPOSE. IF YOU HAVE PREVIOUSLY RECEIVED A DISCHARGE IN BANKRUPTCY, THIS CORRESPONDENCE IS NOT AND SHOULD NOT BE CONSTRUED TO BE AN ATTEMPT TO COLLECT A DEBT, BUT ONLY AS ENFORCEMENT OF LIEN AGAINST PROPERTY. IMPORTANT NOTICE You are in default because you have failed enter a written appearance personally or by attorney and file in writing with the court your defenses or objections to the claims set forth against you. Unless you act within ten (10) days from the date of this notice, a Judgment may be entered against you without a hearing and you may lose your property or other important rights. You should take this notice to a lawyer at once. If you do not have a lawyer or cannot afford one, go to or telephone the following office to find out where you can get legal help: CUMBERLAND COUNTY CUMBERLAND COUNTY BAR ASSOCIATION 2 LIBERTY AVENUE CARLISLE, PA 17013 (717) 249-3166 ATTORNEY FOR PLAINTIFF COURT OF COMMON PLEAS CIVIL DIVISION CUMBERLAND COUNTY : NO.O1-4820 CIVIL Frank Federman,Esquire Attorney for Plaintiff SHERIRg~cTURN - REGULAR .. CASE NO: 2001-04820 P COMMONWEALTH OF PENNSYLVANIA: COUNTY OF CUMBERLAND GMAC MORTGAGE CORPORATION VS FUHRMAN JEFFREY L ET AL CPL. MICHAEL BARRICK Sheriff or Deputy Sheriff of Cumberland County,Pennsylvania, who being duly sworn according to law, says, the within COMPLAINT - MORT FORE was served upon FUHRMAN JEFFREY L the DEFENDANT at 2108:00 HOURS, on the 21st day of August 2001 at 430 CROSSROADS SCHOOL ROAD CARLISLE, PA 17013 by handing to LAURIE FUHRMAN a true and attested copy of COMPLAINT - MORT FORE together with and at the same time directing Her attention to the contents thereof. Sheriff's Costs: Docketing 18.00 Service 5.20 Affidavit .00 Surcharge 10.00 .00 33.20 Sworn and Subscribed to before me this day of Prothonotary A.D. So Answers: R. Thomas Kline 08/21/2001 FEDERMAN & PHELAN /-} Byc r !!/ ~ /./+ i L "" Deputy~yS-heriff ~ ~' - 'CASE N0: 2001-04820 P SHERIFF'S RETURN - R$GULAR COMMONWEALTH OF PENNSYLVANIA: COUNTY OF CUMBERLAND GMAC MORTGAGE CORPORATION . VS FUHRMAN JEFFREY L ET AL CPL. MICHAEL BARRICK Sheriff or Deputy Sheriff of Cumberland County, Pennsylvania., who being duly sworn according to law, .says, the within COMPLAINT - MORT FORE FUHRMAN LAURIE A was served upon the DEFENDANT at 2108:00 HOURS, on the 20th day of August 2001 at 430 CR05SROADS SCHOOL ROAD CARLISLE, PA 17013 by handing to LAURIE FUHRMAN a true and attested copy of COMPLAINT - MORT FORE together with and at the same time directing Her attention to the contents thereof. Sheriff's Costs: Docketing 6.00 Service .00 Affidavit .00 Surcharge 10.00 .00 16.00 Sworn and Subscribed to before me this day of A.D. So Answers: R. Thomas Kline 08/21/2001 FEDERMAN & PHELAN ~~~ By ~/~_ _~ ' ~ ~ DeputyL'Sherif f ' ~, Prothonotary FEDERMAN and PHELAN By: FRANK FEDERMAN Identification No. 12248 One Penn Center at Suburban Starion Suite 1400 Pluladelphia, PA 19103-1814 (2151563-7000 GMAC MORTGAGE CORPORATION Plaintiff vs. Attorney for Plaintiff CUMBERLAND COUNTY Court of Common Pleas CIVIL DIVISION JEFFREY L. FUHRMAN : NO. 01-4820 CIVIL LAURIE A. FUHRMAN Defendant(s) VERIFICATION OF NON-MILITARY SERVICE FRANK FEDERMAN, ESQUIRE, hereby verifies that he is attorney for the Plainfiff in the above-captioned matter, and that on information and belief, he has lmowledge of the following facts, to wit: (a) that the defendant(s) is/are not in the Military or Naval Service of the United States or its Allies, or otherwise within the provisions of the Soldiers' and Sailors' Civil Relief Act of Congress of 1940, as amended (b) that defendant JEFFREY L. FUHRMAN is over 18 years of age and resides at 430 CROSSROADS SCHOOL ROAD, CARLISLE, PA 17013. (c) that defendant LAURIE A. FUHRMAN is over 18 years of age, and resides at 430 CROSSROADS SCHOOL ROAD, CARLISLE, PA 17013. This statement is made subject to the penalties of 18 Pa. C.S. Section 4904 relating to unswom falsification to authorities. ~~ ~ ~i~ FRANK FEDERMAN Attorney for Plaintiff (Rule of Civil Procedure No. 236 -Revised) GMAC MORTGAGE CORPORATION Plaintiff vs. JEFFREY L. FUIIRMAN LAURIE A. FUHRMAN CUMBERLAND COUNTY Court of Common Pleas CIVIL DIVISION NO. 01-4820 CIVIL Defendant(s) Notice is given that a Judgment in the above captioned matter has been entered against you on OCTOBER ~ , 2001. ~ R~~ fl / /,(".0/l/+I.I llEPUTY If you have any questions concerning this matter, please contact: FRANK FEDERMAN. ESQUIRE Attorney for Filing Party One Penn Center at Suburban Station Suite 1400 Philadelphia, PA 19103-1814 (215) 563-7000 **THIS FIRM IS A DEBT COLLECTOR ATTEMPTING TO COLLECT A DEBT AND ANY INFORMATION OBTAINED WILL BE USED FOR THAT PURPOSE. IF YOU HAVE PREVIOUSLY RECEIVED A DISCHARGE IN BANKRUPTCY AND TffiS DEBT WAS NOT REAFFIRMED, THIS IS NOT AND SHOULD NOT BE CONSTRUED TO BE AN ATTEMPT TO COLLECT A DEBT, BUT ONLY ENFORCEMENT OF A LIEN AGAINST PROPERTY. ** °4 AFFIDAVIT OF SERVICE CUMBERLAND COUNTY PLAINTIFF GMAC MORTGAGE CORPORATION No. 01-4820 DEFENDANT(S) JEFFREY L. FUHRMAN LAURIE A. FUHRMAN ACCT. #306764324 SERVE LAURIE A. FUHRMAN AT Type of Action 430 CROSSROADS SCHOOL ROAD -Notice of Sheriff s Sale CARLISLE,PA 17013 Sale Date: MARCH 6, 2002 n SERVED 1 /i~ Served and atade known to l e ti t P A • {-~c g h( YY~'~l(l, Die^fepn_da_nt,'on then~i day of, f~Yk.1r"dt~ , 20~, at ~~, o'clock~.m, at ~~ ~ ~ OSS~ ~ C'~c-<< ~V 7~J~ YY' Q~ 11 t~ Cottun~onwealth of Pennsylvania, in the manner described below: Defendant personally served. q- J ~` ~~~f N~cll\ Adult family member with whom Defendant(s) reside(s). Relationship is f IIAS~ c~ \ - 32 '}~- l 2 <i Adult in charge of Defendant(s)'s residence who refused to give name or relationship. Manager/Clerk of place of lodging in which Defendant(s) reside(s). Agent or person in charge of Defendant(s)'s office or usual place of business. an officer of said Defendant(s)'s company. Other. Description: Age~Q~~ Height ~(( Weight Race~Sex~,Odter 1, ,~~P'I~P l~U , a competent adult being duly sworn according to law, depose and state that I personally handed a true and correct copy of the Notice of Sheriffs Sale in the maaner as set forth herein, issued in the captioned case on the date and at the address indicated above. Sworn to and subscribed before me this _ day of , 200_. Notary: By: PLEASE ATTEMPT SERVICE AT LEAST 3 TIMES. INDICATE DATES & TIMES OF SERVICE ATTEMPED. NOT SERVED On the day of , 200_, at o'clock _ m, Defendant NOT FOUND because: Moved _ Unlmown ~ No Answer Vacant Other: Sworn to and subscribed before me this ~~ day of , 200 Notarial Seal No ByLisa M. Careason, Notary Public Carlisle Boro, Cumberland County me for Plai tff MY Commission Expires Sept. 9, 2002 Frank Federma , Es i - I.D. No. 12248 One Penn Center at urban Station 1617 John F. Kennedy Boulevard, Suite ]400 Philadelphia, PA 19103-1814 (215)563-7000 ;a , e ` ~--, =+ c~ c4a : i G ^R {Tt i t, "';,;_' 4 G7= ~' L.- J ~. -' C.:S ~; .c C_ ;`i .:_a ' - ~, "~ } 4r- "vL/ 1~0.F9tY~n*zua~.g,,aw ,.,,:,., -.-:;wuswm3~wx~l:rv;t. f i %+!NiM'tl ~~ ~ PLAINTIFF DEFENDANT(S) AFFIDAVIT OF SERVICE GMAC MORTGAGE CORPORATION JEFFREY L. F'UHRMAN LAURIE A. FUHRMAN SERVE JEFFREY L. FUHRMAN AT 430 CROSSROADS SCHOOL ROAD CARLISLE,PA 17013 Served and made known to ~ at,y~, y tom, o'clocl~ .m., at of Pennsylvania, in the manner described below: SERVED CUMBERLAND COUNTY No. 01-4820 ACCT. #306764324 Type of Action -Notice of Sheriff s Sale Sale Date: MARCH 6, 2002 on theme day of 200., ~(k> ~ ~ d B.{ I1 SI'~ .Commonwealth l~ Defendant personally served. Adult family member with whom Defendant(s) reside(s). Relationship is Adult in charge of Defendant(s)'s residence who refused to give name or relationship. Manager/Clerk of place of lodging in which Defendant(s) reside(s). Agent or person in charge of Defendant(s)'s office or usual place of business. an officer of said Defendant(s)'s company. Other: Descripti+on~: ,,i ~ Age ~~ I .~H,,eigh r ~ ~ Weight r v~u Race ~ Sex ,~ Other I, 1 ~ . M 1 LY\~ P _~ N', a competent adult, being duly sworn according to law, depose and state that I personally handed a true and correct copy of the Notice of Sheriff s Sale in the manner as set forth herein, issued in the captioned case on the date and at the address indicated above. Sworn to and subscribed before me this day of , 200_. Notary: By: PLEASE ATTEMPT SERVICE AT LEAST 3 TIMES. INDICATE DATES & TIMES OF SERVICE ATTEMPED. NOT SERVED On the day of , 200_, at o'clock _.m., Defendant NOT FOUND hecause: Moved Unlmown No Answer Vacant Other: Swom to and subscribed before me this ~ day f~~-~..a~_=..,,n ~„~,n, of, 200 2. Notarial Seal Lisa M. treason, Notary Public Not B7Garlisle C3oro, Cumberland County P/!y Cernmi;a;~on Expire: S~,~L 5, 20!;?~ ore or PI mt' f '-""` Frank Feder ti, s uire - I.D. No. 12248 One Penn Ce ter uburban Station 1617 John F. Kennedy Boulevard, Suite 1400 Philadelphia, PA 19103-1814 (215) 563-7000 ~ C.i ('i ~- CV "1 _S '~ : ~' 5'~ S ~.r~ ~ ~ ~.. T - y L.i_ . . 4 ~ L 2! c_,) F ~ C+ :~7 pi7 ~ =-~'': ~Yi• ~ :~ i'~ .. - j `~ w e ~~ (3U SALE DATE: MARCH 6, 2002 IN THE COURT OF COMMON PLEAS OF CUMBERLAND COUNTY, PENNSYLVANIA CIVIL ACTION -LAW GMAC MORTGAGE CORPORATION No.: 01-4820 vs. JEFFREY L. FUFII2MAN LAURIE A. FUHRMAN AFFIDAVIT PURSUANT TO RULE 3129.1 AND RETURN OF SERVICE PURSUANT TO Pa. R.C.P. 405 OF NOTICE OF SALE Plaintiff in the above action sets forth as of the date the Praecipe for the Writ of Execution was filed the following information concerning the real property located at: 430 CROSSROADS SCHOOL ROAD. CARLISLE, PA 17013. As required by Pa. R.C.P. 3129.2(a) Notice of Sale has been given in the manner required by Pa. R.C.P. 3129.2(c) on each of the persons or parties named, at that address set forth on the attached Affidavit No. 2 (previously filed) and Supplemental Affidavit No. 2 on the date indicated, and a copy of the notice is attached as an Exhibit. A copy of the Certificate of Mailing (Form 3817) and/or Certified Mail Return Receipt stamped by the U.S. Postal Service is attached for each notice. ~~ FRANK FEDERMAN, ESQUIRE Attorney for Plaintiff February 27, 2002 GMAU MORTGAGE CORPORATION v. Plaintiff, JEFFREY L. FUHRMAN LAURIE A. FUHRMAN Ci :MBERLAND COUNTY COURT OF COMMON PLEAS CIVII. DIVISION NO.Ol-4820 Defendant(s). AFFIDAVIT PURSUANT TO RULE 3129 (Affidavit No. l) GMAC MORTGAGE CORPORATION, Plaintiff in the above action, by its attorney, FRANK FEDERMAN, ESQUIRE, sets forth as of the date the Praecipe for the Writ of Execution was filed the following information concerning the real property located at 430 CROSSROADS SCHOOL ROAD. CARLISLE. PA 17013 . 1. Name and address of Owner(s) or reputed Owner(s): Name JEFFREY L. FUHRMAN LAURIE A. FUHRMAN Last Known Address (if address cannot be reasonably ascertained, please indicate) 430 CROSSROADS SCHOOL ROAD CARLISLE, PA 17013 430 CROSSROADS SCHOOL ROAD CARLISLE, PA 17013 2. Name and address of Defendant(s) in the judgment: JEFFREY L. FUHRMAN 430 CROSSROADS SCHOOL ROAD CARLISLE,PA 17013 LAURIE A. FUHRMAN 430 CROSSROADS SCHOOL ROAD CARLISLE, PA 17013 3. Name and last Irnown address of every judgment creditor whose judgment is a record lien on the real property to be sold: Name None. Last Known Address (if address cannot be reasonably ascertained, please indicate) „~ . 4. Name and address of last recorded holder of every mortgage of record: Name Last Known Address (if address cannot be reasonably ascertained, please indicate) None. 5. Name and address of every other person who has any record lien on the property: Name Last Known Address (if address cannot be reasonably ascertained, please indicate) None. 6. Name and address of every other person who has any record interest in the property and whose interest may be affected by the sale. Name Last Known Address (if address cannot be reasonably ascertained, please indicate) None. 7. Name and address of every other person of whom the plaintiff has knowledge who has any interest in the property which maybe affected by the sale: Name Last Known Address (if address cannot be reasonably ascertained, please indicate) Tenant/Occupant Domestic Relations of Cumberland County Commonwealth of Pennsylvania Department of Welfare 430 CROSSROADS SCHOOL ROAD CARLISLE, PA 17013 13 North Hanover Street Carlisle, PA 17013 PO Box 2675 Harrisburg, PA 17105 I verify that the statements made in this affidavit are true and correct to the best of my personal knowledge or information and belief. I understand that false statements herein are made subject to the penalties of 18 Pa. C.S. Sec. 4904 relating to unswom falsification to authorities. December 7.2001 DATE FRANK FEDERMAN, ESQUIItE Attorney for Plaintiff _..~, _. =o rz ~~ a~ m 6 u ~; ~z °~ ~~ Oro mF R"s Vro O ~. w ~' o.s"^~ =~s~A u p ~' ~ @ L 6~~,Q ~. ~~~°~ o ~.o~ w ~. ~. 8 0 ~. _~ o.a~Qrv H~~gE. ~" ~ EE, c ~tnn$7 3N~=°' oo ~1F- A°~n°~ K .3 3 ~ ~' ~3 ~ _c 0 6 pp~ppp ~ ~. ~.~pQ n q ~ y ~~ F ~~~. ~~~~ O ~ ~ 6 ~'~'g~ =~ E~~~~ n m °~ ~ 3 R`~ o~&Ng ~. ~ ~ ~. ~g8w 3 c,'.o € A° in A W N O b 00 V O~ ~ A W N ~ W a a ~ a A ~ W A Z C cr Q W z ° ~ O a ~ ~ c~ r n ~i y, ~ a ~ m O ~ d O o ~ ~ '~7 a 0 ~ l) ~ 6 o r a `~ ~ x a ° ~ o r 0 ~b o w z ~ ~ o ~ a O o ~ O W N °~ m ~ 0y ~ by b a o ~_ w a~ ~~ ` ` 5. -.. ~~~~ ~ w p' A ,U.SPUSikGE // ~ // __ n v pf.C 10'01 ~1 . .- d ~~~ _a.z5-. \ PBNESER ~~P A 6069360 ~ m ~aw ~; ,~ 3 ~~~ ~ ~' o 1 0. a ~ h7 ~~~ ~ v m !z7 ~ ~x~ a~~ .. o~~~ m ao~p~~9 A < R z O ~ ~ ~ a~ ro ~ a° m w p c m T y: onGy u;: c~ 12: Wd E~`/ DATE: TO: ALL PARTIES IN INTEREST AND CLAIMANTS NOTICE OF SHERIFF'S SALE OF REAL PROPERTY OWNER(S) JEFFREY L. FUHRMAN LAURIE A. FUHRMAN PROPERTY: 430 CROSSROADS SCHOOL ROAD CARLISLE, PA 17013 Improvements: Residential Property CUMBERLAND COUNTY The above-captioned property is scheduled to be sold at the Sheriffs Sale on MARCH 6, 2002, at 10:00 a.m. in Cumberland County Courthouse, South Hanover Street, Carlisle, PA . Our records indicate that you may hold a mortgage or judgment on the property, which maybe extinguished by the sale. You may wish to attend the sale to protect your interests. A schedule of Distribution will be filed by the Sheriff on a date specified by the Sheriff not later than 30 days after sale. Distribution will be made in accordance with the schedule unless exceptions are filed thereto within 10 days after the filing of the schedule. LH r . :.~(,r :_p ASl~di'a4~~e ?"I~~i i.r~ p9~d'dW ).,,.1°i 4i~'~ P~r~~~ ~6~°~'1.€Ett~ SALE DATE: MARCH 6, 2002 IN THE COURT OF COMMON PLEAS OF CUMBERLAND COUNTY, PENNSYLVANIA CIVIL ACTION -LAW GMAC MORTGAGE CORPORATION No.: 01-4820 vs. JEFFREY L. FUHRMAN LAURIE A. FUHRMAN AFFIDAVIT PURSUANT TO RULE 3129.1 AND RETURN OF SERVICE PURSUANT TO Pa. R.C.P. 405 OF NOTICE OF SALE Plaintiff in the above action sets forth as of the date the Praecipe for the Writ of Execution was filed the following information concerning the real property located at: 430 CROSSROADS SCHOOL ROAD. CARLISLE. PA 17013. As required by Pa. R.C.P. 3129.2(a) Notice of Sale has been given in the manner required by Pa. R.C.P. 3129.2(c) on each of the persons or parties named, at that address set forth on the attached Affidavit No. 2 (previously filed) and Supplemental Affidavit No. 2 on the date indicated, and a copy of the notice is attached as an Exhibit. A copy of the Certificate of Mailing (Form 3817) and/or Certified Mail Return Receipt stamped by the U.S. Postal Service is attached for each notice. ~~~ ~~¢~~ ~R,~ d~99~~'~ ~ r kl ,-. y~, E ~`dl~a~ AG"~~t~ YFl`i~t'~°~~FRANK FEDERMAN, ESQUIRE ^ t °~ `~' ° ~ ~;C~P°t" Attorney for Plaintiff February 27, 2002 A § Tu'rn' ~ ~ , ~ C"a ~~~ ~ PLEA~~ ~~ ~ ~_.. T~~h% -"~ ~ n ..t,. ;;~~ i, 4 ~~,,~,,', ...,. __ (,.- L : _-i (X) 'j7 ~ F-~ GMAC Mortgage Corporation VS Jeffrey L. Fuhrman and Laurie A. Fuhnnan In The Court of Common Pleas of Cumberland County, Pennsylvania Writ No. 2001-4820 Civil Term R. Thomas Kline, Sheriff, who being duly sworn according to law, states this writ is returned STAYED pursuant to instructions from Attorney Frank Federman. Sheriff s Costs: Docketing 30.00 Surcharge 30.00 Posting Handbills 15.00 Law Library .50 Prothonotary 1.00 Share of Bills 24.20 Mileage 10.40 Levy 15.00 Advertising 15.00 Certified Mail 2.32 Poundage 16.58 Law Journal 386.30 Patriot News 299.10 $ 845.40 paid by attorney 3-08-02 Sworn and subscribed to before me So Answers: This ~~'da of ~.~,~,~ y R. Thomas Klilr~f~'"~ 2002, A.D.~ /1n. a0, ~ ~ - 66'' ~~ ~ BY Q Prothonotary Real Estate Deputy 1.~ Cfi. 3S~S~ /7d k'3 S r , GMAC MORTGAGE CORPORATION Ci?MBERLAND COUNTY JEFFREY L. FUHRMAN LAURIE A. FUHRMAN NO.Ol-4820 v. Plaintiff, COURT OF COMMON PLEAS CIVIL DIVISION Defendant(s). AFFIDAVIT PURSUANT TO RULE 3129 (Affidavit No. l) GMAC MORTGAGE CORPORATION, Plaintiff in the above action, by its attorney, FRANK FEDERMAN, ESQUIRE, sets forth as of the date the Praecipe for the Writ of Execution was filed the following information concerning the real property located at ,430 CROSSROADS SCHOOL ROAD, CARLISLE, PA 17013 . 1. Name and address of Owner(s) or reputed Owner(s): Name JEFFREY L. FUHRMAN LAURIE A. FUHRMAN Last Known Address (if address cannot be reasonably ascertained, please indicate) 430 CROSSROADS SCHOOL ROAD CARLISLE, PA 17013 430 CROSSROADS SCHOOL ROAD CARLISLE, PA 17013 2. Name and address of Defendant(s) in the judgment: JEFFREY L. FUHRMAN 430 CROSSROADS SCHOOL ROAD CARLISLE,PA 17013 LAURIE A. FUHRMAN 430 CROSSROADS SCHOOL ROAR CARLISLE, PA 17013 3. Name and last lrnown address of every judgment creditor whose judgment is a record lien on the real property to be sold: Name Last Known Address (if address cannot be reasonably ascertained, please indicate) None. 4. Name and address of last recorded holder of every mortgage of record: Name Last Known Address (if address cannot be reasonably ascertained, please indicate) None. 5. Name and address of every other person who has any record lien on the property: Name Last Known Address (if address cannot be reasonably ascertained, please indicate) None. 6. Name and address of every other person who has any record interest in the property and whose interest maybe affected by the sale. Name Last Known Address (if address cannot be reasonably ascertained, please indicate) None. 7. Name and address of every other person of whom the plaintiff has knowledge who has any interest in the property which maybe affected by the sale: Name Last Known Address (if address cannot be reasonably ascertained, please indicate) Tenant/Occupant Domestic Relations of Cumberland County Commonwealth of Pennsylvania Department of Welfare 430 CROSSROADS SCHOOL ROAD CARLISLE, PA 17013 13 North Hanover Street Carlisle, PA 17013 PO Box 2675 Harrisburg, PA 17105 I verify that the statements made in this affidavit are true and correct to the best of my personal knowledge or information and belief. I understand that false statements herein are made subject to the penalties of 18 Pa. C.S. Sec. 4904 relating to unsworn falsification to authorities. December 7.2001 DATE FRANK FEDERMAN, ESQUIRE Attorney for Plaintiff .,.,~~ GMAC MORTGAGE CORPORATION Plaintiff, v. JEFFREY L. FUHRMAN LAURIE A. FUHI2MAN Defendant(s). CUMBERLAND COUNTY No. 01-4820 December 7, 2001 TO: JEFFREX L. FUHRMAN 430 CROSSROADS SCHOOL ROAD CARLISLE,PA 17013 LAURIE A. FUHRMAN 430 CROSSROADS SCHOOL ROAD CARLISLE, PA 17013 * *THIS FIRM IS A DEBT COLLECTOR ATTEMPT/NG TO COLLECT A DEBT AND ANY INFORMATION OBTAINED WILL BE USED FOR THAT PURPOSE. IF YOU HAVE PREVIOUSLY RECEIVED A DISCHARGE IN BANKRUPTCYAND THIS DEBT WAS NOT REAFFIRMED, THIS IS NOT AND SHOULD NOT BE CONSTRUED TO BE AN ATTEMPT TO COLLECT A DEBT, BUT ONLY ENFORCEMENT OF A LIENAGAINST PROPERTY. Your house (real estate) at 430 CROSSROADS SCHOOL ROAD CARLISLE PA 17013 is scheduled to be sold at the Sheriffs Sale on MARCH 6, 2002 at 10:00 a.m. in the Cumberland County Courthouse, South Hanover Street, Carlisle, PA 17013, to enforce the court judgment of $139,947.09 obtained by GMAC MORTGAGE CORPORATION (the mortgagee) against you. If the Sheriff s sale is postponed, the property will be relisted for the JUNE 5, 2002 Sheriff s Sale. NOTICE OF OWNER'S RIGHTS YOU MAY BE ABLE TO PREVENT THIS SHERIFF'S SALE To prevent this Sheriffs Sale, you must take immediate action: The sale will be cancelled if you pay to the mortgagee the back payments, late charges, costs and reasonable attorney's fees due. To find out how much you must pay, you may call: (215) 563-7000. 2. You maybe able to stop the sale by filing a petition asking the Court to strike or open the judgment, if the judgment was improperly entered. You may also ask the Court to postpone the sale for good cause. 3. You may also be able to stop the sale through other legal proceedings. You may need an attomey to assert your rights. The sooner you contact one, the more chance you will have of stopping the sale. (See notice on page two on how to obtain an attomey.) 1. If the Sheriff s Sale is not stopped, your property will be sold to the highest bidder. You may find out the price bid by calling (2151563-7000. 2. You maybe able to petition the Court to set aside the sale if the bid price was grossly inadequate compazed to the value of your property. 3. The sale will go through only if the buyer pays the Sheriff the full amount due in the sale. To find out if this has happened, you may call (717) 240-6390. 4. If the amount due from the Buyer is not paid to the Sheriff, you will remain the owner of the property as if the sale never happened. 5. You have the right to remain in the property until the full amount due is paid to the Sheriff and the Sheriff gives a deed to the buyer. At that time, the buyer may bring legal proceedings to evict you. 6. You maybe entitled to a share of the money which was paid for your house. A schedule of distribution of the money bid for your house will be filed by the Sheriff within 30 days of the sale. This schedule will state who will be receiving that money. The money will be paid out in accordance with this schedule unless exceptions (reasons why the proposed distribution is wrong) aze filed with the Sheriffwithin ten (10) days after the distribution is filed. 7. You may also have other rights and defenses, or ways of getting your home back, if you act immediately after the sale. YOU SHOULD TAKE THIS PAPER TO YOUR LAWYER AT ONCE. IF YOU DO NOT HAV1: A LAWYER OR CANNOT AFFORD ONE, GO TO OR TELEPHONE THE OFFICE LISTED BELOW TO FIND OUT WHERE YOU CAN GET LEGAL HELP. CUMBERLAND COUNTY ATTORNEY REFERRAL CUMBERLAND COUNTY BAR ASSOCIATION 2 LIBERTY AVENUE CUMBERLAND COUNTY COURTHOUSE CARLISLE, PA 17013 (717)249-3166 (800) 990-9108 ALL THAT CERTAIN tract of land with the improvements thereon erected situate in West Petmsboro Township, Cumberland County, Pennsylvania, more fully bounded and described in accordance with a plan prepazed by Rodney Lee Decker, R.P.L.S., dated 3anuary 22, 1993 and recorded in the Office of the Recorder of Deeds for Cumberland County in Plan Book 66, Page 104, as follows: BEGINNING at a point on southern right-of--way line of Cross Road School Road, T-438 at line of Lot No. 52; thence along Lot No. 52, South 32 degrees 50 minutes 00 seconds West 353.91 feet to a point; thence along Phase 3 of Cross Road School Road Estates, North 67 degrees 04 minutes 45 seconds West 112.05 feet to a point in southern edge of Watson Drive; thence along southern edge of Watson Drive by a curve to the left having a radius of 200.00 feet and an arc distance of 99.02 feet to a point; thence still along southern edge of Watson Drive by a curve to the right having a radius of 150.00 and an azc distance of 191.63 feet to a paint thence still along Watson Drive North 49 degrees OS minutes 05 seconds East 332 to a point creating the intersection of Watson Drive and Cross Road School Road; thence along said intersection of Watson Drive and Cross Road School Road; thence along said intersection by a curve to the right having a radius of 25.00 feet and an arc distance of 38.51 feet to a point in western edge of Cross Road School Road; thence along western edge of Cross Road School Rcad by a curve to the left having a radius of 1,166.00 and an azc distance of 149.68 feet to a point: thence still along western edge of Cross Road School Road T-438, South 51 degrees 15 minutes 00 seconds East 50.28 feetto a point, the place of beginning. CONTAINING 2.014 acres and designated as Lot 19 on Plan for Cress Road School Rcad Estates. 'Tax Parcel #46-OS-0587-093 TYTLE TO SAID PREbIISES IS VESTED IN Jeffrey L. Fuhrman and Laurie A. Fuhrttran, his wife by Deed from Harmon Graves Company and Kimba Iric. dated 7/29/98, and recorded 10/21/98 in Record Book 187, Page 613. BEING RNOGN AS: 430 CROSSROADS SCHOOL ROAD, CARLISLE, PA 17013 WRIT OF EXECUTION and/or ATTACHMENT COMMONWEALTH OF PENNSYLVANIA) NO. 01-4820 CIVIL f9 COUNTY OF CUMBERLAND) CIVIL ACTION -LAW TO THE SHERIFF OF CUMBERLAND _ JCOUNTY: To satisfy the debt, interest and costs due _GMAC Mortgage Corportion from PA _ _ PLAINTIFF`S) Jeffrey L. & Laurie A. Fuhrman~ 430 Crossroads School Road, Carlisle 17013. __ _ DEFENDANT(S) (t) You are directed to levy upon the propeny of the defendant(s) and to sell Real estate located at 430 Crossroads School Road, Carlisle PA 17013. (See attached legal description.) (2) You are also directed to attach the property of the defendant(s) not levied upon in the possession of GARNISHEE(S) as follows: and to notify the garnishee(s) that: (a) an attachment has been issued; (b) the garnishee(s) is/are enjoined from paying any debt to or for the account of the defendant(s) and from delivering any property of the defendant(s) or otherwise disposing thereof; (3) If property of the defendant(s)notlevieduponansubjecttoattachmentisfoundinthepossessionofanyoneother than a named garnishee, you are directed to notify him/her that he/she has been added as a garnishee and is enjoined as above stated. Amount Due $139,947.09 Interest9/29JO1 to 3/6/02 $3,657.00 Atty's Comm Atty Paid Plaintiff F 20 Date: __ December 11, 2001 REOUESTING PARTY: Name Frank Federman, Esq. Address. 1617 JFK Blvd. , Ste 1400 L.L. S • 50 Due Prothy- Other Casts CURTIS R. LONG ProthonQtar Civil Division t ~, „tI/ f Deputy Philadelphia PA 19103 1814 Attorney for: Plaintiff Telephone: (21`_ Supreme Court ID No. 563 7000 12248 $1.00 REA~~ ESTATE SAFE No. ~~ On December 12, 2001, the sheriff levied upon the defendant's interest in the real property situated in West Pennsboro Township, Cumberland County, PA, known and numbered as 430 Crossroads School Road, Carlisle, and more fully described on Exhibit "A" filed with this writ and by this reference incorporated herein. Date: December 12, 2001 By: eal tate Deputy ~~ ~~ ~!a ~~ ~ 14 ~ , : +ry~ a3~u3N~'~~~ ~j ~a~~~o THE PATRIOT NEWS THE SUNDAY PATRIOT NEWS Proof of Publication Under Ac[ No. 587, Approved May 16,1929 Commonwealth of Pennsylvania, County of Dauphin} ss Michael Morrow being duly sworn according to law, deposes and says: That he is the Asst. Controller of The Patriot News Co., a corporation organized and existing under the laws of the Commonwealth of Pennsylvania, with its principal office and place of business at 812 to 818 Market Street, in the City of Harrisburg, County of Dauphin, State of Pennsylvania, owner and publisher of The Patriot-News and The Sunday Patriot-News newspapers of general circulation, printed and published at 812 to 818 Market Street, in the City, County and State aforesaid; that The Patriot-News and The Sunday Patriot-News were established March 4th, 1854, and September 18th, 1949, respectively, and all have been continuously published ever since; That the printed notice or publication which is securely attached hereto is exactly as printed and published in their regular daily and/or Sunday/ Metro editions which appeared on the 29th day(s) of January and the 5th and 12th day(s) of February 2002. That neither he nor said Company is interested in the subject matter of said printed notice or advertising, and that all of the allegations of this statement as to the time, place and character of publication are true; and That he has personal knowledge of the facts aforesaid and is duly authorised and empowered to verify this statement on behalf of The Patriot-News Co. aforesaid by virtue and pursuant to a resolution unanimously passed and adopted severally by the stockholders and board of directors of the said Company and subsequently duly recorded in the office for thg Recording of Deeds in and for said County of D~upfiii in Miscellaneous Book "M", Volume 14, Pa a 317. ~ ~ /fj,A PUBLICATION .......................(/...!~........... ~'.'.."".`..!................................ COPY Sworn to and subscribed be ore me this 22nd day of February 2002 A.D. SALE #45 Notarial Seal Terry L. Ruscgll, Notary Public HaMSburg, DaupMn County My Commission Expires June 6, 2U02 N TARY PUBLIC Member, Pennsylvania association a Notaries My commission expires June 6, 2002 CUMBERLAND COUNTY SHERIFFS OFFICE ~ CUMBERLAND COUNIY COURTHOUSE CARLISLE, PA. 17013 Statement of Advertising Costs To THE PATRIOT-NEWS CO., Dr. For publishing the notice or publication attached hereto on the above stated dates $ 297.60 Probating same Notary Fee(s) $ 1 .50 Total $ 299.90 Publisher's Receipt for Advertising Cost The Patriot News Co., publisher of The Patriot-News and The Sunday Patriot-News, newspapers of general circulation, hereby acknowledge receipt of the aforesaid notice and publication costs and certifies that the same have been duly paid. By .................................................................... -.: - R_ ESTATE SALE No.45 5lJrit No.2007-0820 - _ -O vilTerat_ _ - `GMA~ Mortgage _ - _ - Corporatiop - Vs. _ == -~ ~deffrey L: F;Srman -= -Antl Laurie A. Fuhrman = - ~ Atty: Frank Federman aDESCRIPTION ~., ~9LL THAT CERTAIN tract of land with the ~mipmvemed~thereon Stetted siwate in West boro Township, Cumberland Cauvty, ~y]vania, more fully bounded and ~eacdbed is acco{dance with a plan prepared 6-y Roduey Lee Decker, R.P.L.S, dated fanuaty - 2?-1993 and recorded in the Office of the liecorder of Ceeds for Cumberland County in at a point on ~. 52; thence ~C,toss. Road Schoo] 1,tQad Estates, North 67 d`e~greeg Qd min~tec 45 seconda West 11205 ~o a pom~in-swthern edge of Watson _~rive; thence along southern edge of Watson Drive by a curve to the ~ft having a radius of 100.00 feetand anaSC distance of 99.02 feet w _ a'pomt;~ thence. sdl] along soathern edge of- -t;ats~on Dirve by a curve to the right having a tus of 1$0,00 and-agirc dis<tagce of 19L.fi3 to a point ffience sWl along Watson Drive orih A9 degrees QS minutes OS se~ronds East to_a_ point ~ civzting the intersection of ats~on Drive and Cross Road School Road; °~ftence along said inetsection of Watson Ddve t°at£d Cross Road School Road; thence along -said mt'ersecdon by a curve to the right having ~r+dius of 25.00 fee[ and an azc distance of -38.51 feet m a point in western edge of Crou ~ad~choo] Road; thence along western edge ~oP Cross Road Sohoo] Rved by a wive to the left hoeing a radius of 1,166.00 and an arc -distance of 149.68 feet to a point; thence still along wes[em edge of Crass Road Schoo] =Road T-438, South 51 degrees 15 mimnes CO ~secoods East SD.28 feet to a point, the place of 2.014 acres and designated as `ur Cmu Road School Road is vested in Jeffrey Fuhanaa, his wife, aver Company and and recorded 1D(21t ;e 613. Crossroads School Road, Carlisle, PA 17013. PROOF OF PUBLICATION OF NOTICE IN CUMBERLAND LAW JOURNAL (Under Act No. 587, approved May 16, 1929), P. L.1784 STATE OF PENNSYLVANIA COUNTY OF CUMBERLAND ss. Roger M. Morgenthal, Esquire, Editor of the Cumberland Law Journal, of the County and State aforesaid, being duly sworn, according to law, deposes and says that the Cumberland Law Journal, a legal periodical published in the Borough of Carlisle in the County and State aforesaid, was established January 2, 1952, and designated by the local courts as the official legal periodical for the publication of all legal notices, and has, since January 2, 1952, been regularly issued weekly in the said County, and that the printed notice or publication attached hereto is exactly the same as was printed in the regular editions and issues of the said Cumberland Law Journal on the following dates, viz: JANUARY 25, FEBRUARY 1, 8, 2002 Affiant fitrther deposes that he is authorized to verify this statement by the Cumberland Law Journal, a legal periodical of general circulation, and that he is not interested in the subject matter of the aforesaid notice or advertisement, and that all allegations in the foregoing statements as to time, place and character ofpublicaton are true. -~. Roger M. Morgenthal, Editor SWORN TO AND SUBSCRIBED before me this 8 day of FEBRUARY. 2002_ LdS E. SNYDER, Nol~y PuW~ 9000, C _ .. ,.x-w REAL ESTATE SALE NO. 45 Writ No. 2001-4820 Civil GMAC Mortgage Corporation vs. Jeffrey L. Flihnnazi and Laurie A Fuhiman AttV.: Frank Federman ALL THAT CERTAIN tract of land with the improvements thereon erected situate in West Pennsboro Township. Cumberland bounded Pem'isylvania. more fully and described in acco Rodney Lee plan prepared by Y Decker, RP.L.S., dated January 22. 1993 and recorded in the Office of the Recorder of Deeds for Cumber- land County in plan Book 66. Page 104, as follows: BEGINNING at a point on south- ern righf-of-way line of Cross Road School Road. T-438 at line of Lot No. 52: thence along Lot No. 52, South 32 degrees 50 minutes 00 seconds West 353.91-feet td a point: thence along phase 3 of Cross Road School Road Estates. North 67 degrees 04 minutes 45 seconds West 112.05 feet to a point m south- ern edge of Watson Drive: thence along southern edge of Watson Drive by a curve to the left having a ra- dius of 200.00 feet and an azc dis- tance of 99.02 feet to a point; thence still along southern edge of Watson Drive by a curve to the right having a radius of 150.00 and an azc dis- tance of 191.63 feet to a point thence still along Watson Drive North 49 degrees 05 minutes 05 seconds East 332 to a point creating the in- tersection of Watson Drive and Cross Road School Road: thence along said fntersection of Watson Drive and Cross Road School Road: thence along said intersection by a curve to the right having a radius of 25.00 feet and an arc distance of -38.51 feet to a point inwestern edge . of Cross Road School Road; thence along western edge of Cross Road having a~radms of 11 66.00 andlan azc distance of 149.68 feet to a point: thence still along western edge of Cross Road School Road T-438. South 51 degrees 15 minutes 00 seconds East 50.28 feet to a point. the place of beginning. CONTAINING 2.014 acres and CrossnRoad School Road Estatesor Tax Parcel #46-OS-0587-093. TITLE TO SAID PREMISES IS V FS'fED IN Jeffrey his wifDeed Laurie A. Fuhiman. from Harmon Gmves Company and corded110/21/987in Record Book 187, page 613. BEING KNOWN AS: 430 CROSS- ROADS SCHOOL ROAD. CARLISLE, PA 17013. PRAECIPE FOR WRIT OF EXECUTION -(MORTGAGE FORECLOSURE) P.RC.P. 3180-3183 GMAC MORTGAGE CORPORATION Plaintiff, v. No. 01-4820 JEFFREY L. FUffitMAN LAURIE A. FUHRMAN Defendant(s). TO THE DIRECTOR OF THE OFFICE OF THE PROTHONOTARY: Issue writ of execution in the above matter: Amount Due Interest from 9/29/01 to 3/6/02 (per diem -23.00) TOTAL $139,947.09 $ 3,657.00 and Costs $143,604.09 FRANK FEDERMAN, E QUIItE One Penn Center at Suburban Station 1617 John F. Kennedy Boulevard, Suite 1400 Philadelphia, PA 19103-1814 Attorney for Plaintiff Note: Please attach description of property.No. o `~" z ~~ G ~ ~, F "7 az WUW Cz O w a ~ w ~~ W ~ ~~ o ~ .a pp d ~~ H~ ~ ~~ w A o~ ~ ~a U U ~~ ~ ~ U d ~, H d w o~ .~ w 0 M ti O r .~ d a W .a ti .. U d O a 0 O U a° a U 0 d a'bi ro a. r _._.. ~ Ki°e"E;„~ ~ .a...., .-.'= .. ._ c~raa~se ax mx, ti~a;~ ~ ~r, . ,~,mara.~g,~m-at ti ALL THAT CERTAIN tract of land with the improvements thereon erected situate in West Pennsboro Township, Cumberland County, Pennsylvania, more fully bounded and described in accordance with • a plan prepared by Rodney Lee Decker, R.P.L.S., dated Januazy 22, 1993 and recorded in the Office of the Recorder of Deeds for Cumberland County in Plan Book 66, Page 104, as follows: BEGINNING at a point on southern right-of--way line of Cross Road School Road, T-438 at line of Lot No. 52; thence along Lot No. 52, South 32 degrees 50 minutes 00 seconds West 353.91 feet to a point; thence along Phase 3 of Cross Road School Road Estates, North 67 degrees 04 minutes 45 seconds West 112.05 feet to a point in southern edge of Watson Drive; thence along southern edge of Watson Drive by a curve to the left having a radius of 200.00 feet and art arc distance of 99.02 feet to a point; thence still along southern. edge of Watson Drive by a curve to the right having a radius of 150.00 and an arc distance of 191.63 feet to a paint thence still along Watson Drive North 49 degrees 05 minutes OS seconds East 332 to a point creating the intersection of Watson Drive and Cross Road School Road; thence along said intersection of Watson Drive and Cross Road School Road; thence along said intersection by a curve to the right having a radius of 25.00 feet and an arc distance of 38.51 feet to a point in western edge of Cross Road School Road; thence along western edge of Cross Road School Road by a curve to the left having a radius of 1,166.00 and an azc distance of 149.68 feet to a point; thence still along western edge of Cross Road School Road T-438, South 51 degrees 15 minutes 00 seconds East 50.28 feet to a point, the place of beginning. CONTAINING 2.014 acres and designated as Lot 19 on Plan for Cross Road School Rcad Estates. 'Tax Parcel #46-08-0587-093 TITLE TO SAID PREMISES IS VESTED IN 7effrey L. Fuhrman and Laurie A. Fuhrman, his wife by Deed from Harmon Graves Company and Kimba Iuc. dated 7/29/98, and recorded 10/21/98 in Record Book 187, Page 613. BEING RNOIiN AS: 430 CROSSROADS SCHOOL ROAD, CARLISLE, PA 17013 .~ 9 ~ ,1 -~. . ~'' c , . ~~ - cYl ~ s_ "` ~ cJ~ - 1 _y GMAC MORTGAGE CORPORATION v. Plaintiff, JEFFREY L. FUHRMAN LAURIE A. FUHRMAN Ci?MBERLAND COUNTY COURT OF COMMON PLEAS CIVIL DIVISION NO.Ol-4820 Defendant(s). AFFIDAVIT PURSUANT TO RULE 3129 (Affidavit No. 1) GMAC MORTGAGE CORPORATION, Plaintiff in the above action, by its attorney, FRANK FEDERMAN, ESQUIRE, sets forth as of the date the Praecipe for the Writ of Execution was filed the following information concerning the real property located at ,430 CROSSROADS SCHOOL ROAD. CARLISLE, PA 17013 . 1. Name and address of Owner(s) or reputed Owner(s): Name JEFFREY L. FUHRMAN LAURIE A. FUHRMAN Last Known Address (if address cannot be reasonably ascertained, please indicate) 430 CROSSROADS SCHOOL ROAD CARLISLE, PA 17013 430 CROSSROADS SCHOOL ROAD CARLISLE, PA 17013 2. Name and address of Defendant(s) in the judgment: JEFFREY L. FUHRMAN 430 CROSSROADS SCHOOL ROAD CARLISLE,PA 17013 LAURIE A. FUHRMAN 430 CROSSROADS SCHOOL ROAD CARLISLE, PA 17013 3. Name and last known address of every judgment creditor whose judgment is a record lien on the real property to be sold: Name None. Last Known Address (if address cannot be reasonably ascertained, please indicate) 4. Name and address of last recorded holder of every mortgage of record: Name None. Last Known Address (if address cannot be reasonably ascertained, please indicate) 5. Name and address of every other person who has any record lien on the property: Name Last Known Address (if address cannot be reasonably ascertained, please indicate) None. 6. Name and address of every other person who has any record interest in the property and whose interest maybe affected by the sale. Name Last Known Address (if address cannot be reasonably ascertained, please indicate) None. 7. Name and address of every other person of whom the plaintiff has knowledge who has any interest in the property which maybe affected by the sale: Name Last Known Address (if address cannot be reasonably ascertained, please indicate) Tenant/Occupant Domestic Relations of Cumberland County Commonwealth of Pennsylvania Department of Welfare 430 CROSSROADS SCHOOL ROAD CARLISLE, PA 17013 13 North Hanover Street Carlisle, PA 17013 PO Box 2675 Harrisburg, PA 17105 I verify that the statements made in this affidavit aze true and correct to the best of my personal knowledge or information and belief. I understand that false statements herein are made subject to the penalties of 18 Pa. C.S. Sec. 4904 relating to unsworn falsification to authorities. December 7.2001 DATE FRANK FEDE1tMAN, ESQUIRE Attorney for Plaintiff