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HomeMy WebLinkAbout01-04842~' CASE NO: 2001-04842 P SHERIFF'S RETURN - REGULAR COMMONWEALTH OF PENNSYLVANIA: COUNTY OF CUMBERLAND GMAC MORTGAGE CORP OF PA VS THUMMA RICHARD L ET AL DAVID MCKINNEY Sheriff or Deputy Sheriff of Cumberland County,Pennsylvania, who being duly sworn according to law, says, the within COMPLAINT - MORT FORE was served upon CLARK KIMBERLY A the DEFENAANT at 2058:00 HOURS, on the 27th day of August 2001 at 17 A WEST GLENWOOD DR CAMP HILL, PA 17011 KIMBERLY A CLARK 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 6.00 Service .00 Affidavit .00 Surcharge 10.00 .00 16.00 Sworn and Subscribed to before me this ~,Z~ day of ~~~. ~~at'~ A . D . -~ ' 'Prothonotary 'T- So Answers• ~~~ R. Thomas Kline 08/28/2001 FEDERMAN & PHELAN By ~ .c r/!/~4 ~~~ Deputy Sherif SHERIFF'S RETURN - NOT FOUND ,, CASE NO: 2001-04842 P COMMONWEALTH OF PENNSYLVANIA COUNTY OF CUMBERLAND MORTGAGE CORP OF PA VS THUMMA RICHARD L ET AL R. Thomas Kline ,Sheriff or Deputy Sheriff, who being duly sworn according to law, says, that he made a diligent search and inquiry for the within named defendant, DEFENDANT THUMMA RICHARD L but was unable to locate Him in his bailiwick. He therefore returns the COMPLAINT - MORT FORE , NOT FOUND as to the within named DEFENDANT THUMMA RICHARD L RICHARD THUMMA LIVES AT 5252 OAKLAND ST PHIL~A, PA. RETURNED PER JASON RICCO. Sheriff's Costs: So answer Docketing 18.00 Service 9.75 Not Found 5.00 R. homas Kline Surcharge 10.00 Sheriff of Cumberland County nn 00/00/0000 Sworn and subscribed to before me this Ia-~ day of x~`"' ,2-rro / A . D . ~~ n Prothonotary FEDERMAN AND PHELAN, LLP By: FRANK FEDERMAN, ESQUIItE IDENTIFICATION NO. 12248 ATTORNEY FOR PLAINTIFF ONE PENN CENTER AT SUBURBAN STATION 1617 JOHN F. KENNEDY BOULEVARD SUITE 1400 PHILADELPHIA, PA 19103-1814 (215) 563-7000 COURT OF COMMON PLEAS CNII. DNISION GMAC MORTGAGE CORPORATION OF PA 401 MII.E OF CARS WAY NATIONAL CITY, CA 91950 v. Plaintiff TERM RICHARD L. THUMMA KIMBERLY A. CLARK 17 A WEST GLENWOOD DRNE CAMP HII.L, PA 17011 Defendant(s) CUMBERLAND COUNTY CIVIL ACTION -LAW COMPLAINT IN MORTGAGE FORECLOSURE NOTICE **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 THIS DEBT WAS NOT REAFFHtMED, THIS CORRESPONDENCE [SNOT 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 appearance personally or by attorney and filing in wrifing 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 may be 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. CUMBERLAND COUNTY CUMBERLAND COUNTY BAR ASSOCIATION 'Nle hereby certify the v~itnin t® be a true and correct copy of th® original filed of record ~~®~R>viAN ~~®~t~~tAN Loan #:450184908 2 LIBERTY AVENUE CARLISLE, PA 17013 (717) 249-3166 TRUE COPY <lrRpp~ REOORD m Tea~ny wtMreot,l [~ unto ~aet ny ba+M antl ore seM of aalG~~. Pe, tn~ ~ ~y ~ ~ ~~ . IF THIS IS THE FHtST NOTICE THAT YOU HAVE RECEIVED FROM THIS OFFICE, BE ADVISED THAT: PURSUANT TO THE FAIR DEBT COLLECTION PRACTICES ACT, 15 U.S.C. § 1692 et seq. (1977), DEFENDANT(S) MAY DISPUTE THE VALIDITY OF THE DEBT OR ANY PORTION THEREOF. IF DEFENDANT(S) DO SO IN WRITING WITHIN THIRTY (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. Plaintiff is GMAC MORTGAGE CORPORATION OF PA 401 MILL OF CARS WAY NATIONAL CITY, CA 91950 2. The name(s) and last known address(es) of the Defendant(s) are: RICHARA L. THUMMA KIMBERLY A. CLARK 17 A WEST GLENWOOD DRNE CAMP H1LL, PA 17011 who is/are the mortgagor(s) and real owner(s) of the property hereinafter described. On 7/28/95 mortgagor(s) made, executed and delivered a mortgage upon the premises hereinafter described to PLAINTIFF which mortgage is recorded in the Office of the Recorder of CUMBERLAND County, in Mortgage Book No. 1276, Page 75. 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 4/1/01 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 all 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 $57,367.99 Interest 1,784.86 3/1/01 through 8/1/01 (Per Diem $11.59) Attorney's Fees 2,868.00 Cumulative Late Charges 48.92 7/28/95 to 8/1/01 Cost of Suit and Title Search 550.00 Subtotal $62,619.77 Escrow Credit 0.00 Deficit 127.07 Subtotal $ 127.07 TOTAL $62,746.84 7. The attorney's fees set forth above are in conformity 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 charged. 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 Plaintiff's written Notice 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 $62,746.84, together with interest from 8/1/O1 at the rate of $11.59 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 property. /s/ Frank Federman FRANK FEDERMAN, ESQUIl2E Attorney for Plaintiff 08. 1J-'OJ. 18: ~~: F.~1.Y 215 682 19~F0 G;t[ACK - CORP DEFAULx F'srsi Mortgage Lwn Servicing -3451 Nammnnd Ave P.o. BoX 780 GMAC iNor~gage Waterloo, IA 50704-0780 ~~ ~ Dace: June 12, 2001 ACT 91 NOTICE TAKE ACTION TO SAVE YOUR HOME FROM FORECLOSURE This is otScial notice that the. o a e o onr home is in defa and the lender intends to foreclose. Sne ' m information abontthe nature of the defanh:id provided in the attached peace The HOMEOWNER'S MORTGAGE ASSISTANCE PROGRAM (HEMAP) may be abk to help to save your home. This Notice eznlains bow the nroeram worlof. This Notice contains importaatlegal informatioa.IFyoa have any questions, representatives atthe Consumer Credit Counseling Agency maybe ahk to help explain it. You may also want to coact an attorney in your area. The local her association maybe abk to help yon find a lawyer. LA NOTIFICACION EN ADJUNTO ES DE SUMA IMPORTANCL4, PUES AFECTA SU DERECHO A CONTINUAR ~TVIENDO EN SU CASH. SINO COMPRENDE EL CONTENIDO DE ESTA NOTIFTCACION Ol1TENGA UNA TRADUCCIQN I1-n1IEDIATAIIIENTE LLAMANDO ESTA AGENCIA (PENNSYLVANIA gOIISING FINANCE AGENCY] SIN CARGOS AL N171YtER0 MENCIONADO ARRIBA. Pi7EDES SER ELEGIBLE PARA UN PRESTAMO POR EL FROGRAMA LLAMADO "HOMEOWNER'S EMERGENCY MORTGAGE ASSISTANCE PROGRAM" EL CUAL PUEDE SALV_AR SU CASA DE LA PERDIDA DY+I, DERECHO A REDIb1IIt SU HIPOTECA HO~IEO~YVi ER'S NAbIE(S): KIMBERLY A. CLARK 17A W GLE.7WOOD DR PROPERTX ADDRESS: CAMP HILL, ?A 17011-1139 LOA.Y ACCT. NO.: ORIGINAL LENDER: CURRENT LENDERJSERVICER: 450184905 N/A GatAC Mortgage Corporation ~J6~1tl6.~~ ! ~~°. First Mortgage Loan Servicing FO Box 85071 San Diego CA 92186-5071 3457 Hammond Ave PO Box 780 Waterloo IA 50704-0780 GM1~C Mortgage Date: June 12, 2001 ACT 91 NOTICE TAKE ACTION TO SAVE YOUR HOME FROM FORECLOSURE Phis is an official notice that the mortgage on your home is in default, and. the lender intends to foreclose. Specific_information about thepature of the default is provided in the_attacLed pages. The HObiROR'NN;R'S ~IORTGAGF, ASSISTANCF, YROGRA;Vt_(AF.iV1AP) maybe able to help to save your home. This_Notice explains how thc_program works. To see if HA;bL1P can help, you must ~tF,E.T W ITH A CONSUM1IE,R CREDIT COUNSELING AGF,NCY WI'I'II.1_N 30 HAYS OE THN; DATF. OF THIS NOTICP;. Take this Notice with you when you meet with the Counseling Agency. The name, address and phooc cumber of Consunicr G•cdif Cow~scliuk Agcucics scrviug your Couoiy arc listed at the end of this Notice. If you have any questions, you may call the Pennsylvania Housing }finance Agency toll free at }-800-342-2397. (Persons with impaired hearing can call (777) 780-1869). This Notice contains important legal infonnalim~. If you have any questions, representatives at the Consumer Credit Counseling Agency may be able to help explain it. You may also want to contact an attorney in your •area. 7'he local bar association may be able to help you rnd a lawyer. LA N01'll+1CACION EN ADJUNI'O F,S DF, SU~9A Ib1YOR1'ANCIA, PUSS AFP;CTA SU I)F,RECHO A CONTINUAR VIVIb;NDO EN SU CASA. SI NO CO)V1YRb:N1)E P;I. CON'I'ENIDO DE P;S1'A NOTIEICACION OATENGA UNA TRADUCCION IID1M1lEDIATAAIE,N1'F; I,LA~IANDO F,STA AGF.NCIA (PA;NNSYI,VAMA HOUSING TINANCF. AGENCY) SIN CARGOS AI. NUAIF,RO ~fENCIONADO ARRI1fA. 1'Ub;Db;S SER N;LRGIRLA; YARA UN YRESTAb10 YOR EI. YROGRA~1,1 LLA~fADO "HOivIEOWNER'S N:tifERG1'iNCY iV}OR'1'GAGE ASSIS'I'ANCN; YROGRA~1" N;1. CUAI. YUEllN; SALVAR SU CASA DF; LA YN;RDIDA DEI, DF.Rb;CHO A RF,DI~IIR SU HIYOTECA Ho~lr:ow:vr;x~s Nr~~1E(S): rxorEx•rY ,v)nR}ss: LOAN ACCT. NO.: oRl(aNnl, l.r;Nnr;R: cuxxl~:N•r Lr;Nnr;xisr:R~'ICr:R: RICHARD L. THUMMA 17A W GLENWOOD DR CAMP HILL, PA 17011-1139 450189908 N/A GMAC Mortgage Corporation IIOVIN;OWNN;R'S N;VIN;RGN;NCY V10R'I'GAGE ASSISTANCN; YROGkaVI YOU ~L1Y 13N; N;L1G11SLN; FOR FINANCLU. ASSISTANCN; R'HICH CAN SAVN; YOUR HOVIN; FROM FORN;CLOSURN; AND IIN;LY YOU V1AKN; FU'1'URN; V10RTGAGN; YAYVIN:N'I;S IF YOU COVIYI,Y N'I'I'}I THN PROVISIONS Or THA HOVIN;OW'NN;k'S N;ti1N;kGN;NCY bIOkTGA(:N; ASSISTANCN; ACT OR 1983 (T}IN; "ACT"), YOU Vi,tY 13F, F.LIGIHLR FOR F,V1N;kGN;NCY VIORTGAGN; ASSISTANCN;: 1P YOUIL Dl?FAUI;I' IL1S ]3I':I':N CAUSI?ll 1fY CIkCU~15'IANCI?S YOUR CONTROI„ IF YOU HAVN; A kEASONA131,F,1'ROSYN;C'I' Oh ISN:ING AI3LN; TO YAY YOUR V10RTGAGN YAYVIN;N'I'S, AND IF YOU ViNET OT}IN;k FIdGIISIId'IY kFQUIRFVINN'I'S ES1'A131,1SHN;1) BY THN Y$NNSYLVANIA HOUSING FINANCN; AGENCY. T1':Vtl'ORAkY STAY Oh 1~ORECIASURN; -- lender the :1ct; yon are entitled to a temporary stay of lbrzclosure. on your mortgage for thirty (30) days from the dale ofthis Notice. During that time you must arrange and attend a "face-to-face" meeting with one ofthe consumer credit counseling agencies listed at the end ofthis Notice. THIS V1F_I•;77NG V1UST OCCUk WITHIN THI: NEXT (30) HAYS. IP YOIJ DO NOT APPLY POR.}i~fIiRGENCt' MORTGAGE. ASS]STANCP., YO(J MIDST BRING YOUR MORTGAGE (JP TO DaTF.. T}Ili P:1RT OP TI11S N077(T C::11_I,Tip " 1]OW TO ClJ](r YOUR MORTGAGP. DEE:1iJI.T'; FXPI,AINS 110W TO BRING TOLJk MORTGAGr LJP TO DA7T:. CONSUb1r;k_CI2Fnl'1'_COUNSF.LINC AGENCIES -- If you meet with one of the consumer credit cotmseling agencies listed at the end ofthis notice, the lender may NOT take action against you for thirty (30) days alter the date ofthis meeting.The names, addresses and_ telephone numbers of designated consumer credit counseling agencies fir the county in which the property is located are set forth at the end ofthis Notice It is only necessary to schedule one face-to-face meeting. Advise your lender immediately of your intentions. _AI'1'1.ICA'1'lOV FOR V10kTGAGE ASSISTANCN; --Your mortgage is in default for the reasons set forth later in this Notice (see following pages for specific infomration shout the native of your default.) ]f you have tried and are unable to resolve this problem with the lender, you have the right to apply for Snancial assistance form the Ilmncownc>'s P,mergcncy Vfortgage Assistance Program. To do so, you must fill out, sign and file a completed l lomcownet's I?mergency Assistance Program Application with one of the designated consumer credit cotmseling agencies listed at the end ofthis Notice. Only consumer credit cotmseling agencies have applications for the pmgmm and they will assist you in sttbmitting a complete application to the Pennsylvania housing Finance Agency. Your application \1L`ST he filed or postmarked wiA»n thirty (30) days ofyou face-to-face meeting. YOU V1UST FILM; YOllR APPLICATION PkOV1YTLY. II' YOU FAIL. TO DO SO OR IF YOU ll0 NO'1' FOLI,OR' TI1N; OTHN;k TIV1N; YNkIODS SF.T FOR1'}l IN THIS LE7"1'N;R, FORN;CI,OSURN; VIAY YROCEN;A AGAINST YOUR HOVIN;1V1V1N;DLtTN;LY ANll YOUR :U'I'LICATION 1~03t V10RTGAGN: ASSISTANCN: tV'll.l. RN; DN;VIN;1). A(N;NCY ACT10\ -- Available fiords for emergency mortgage assistarce are very limited. They will he disbursed by the Agency under t]re eligibility criteria established by the :1ct. The Pennsylvania housing Finance Agency has silty (60) days to make a decision after it receives your application. Ihving that time, no foreclosure proceedings will he pursued against you ifyou have met the time requirements set forth above. }'ou will he notified directly by the Pennsylvania housing Finance agency of its decisimt on your applicatimr. ~°~~'IA~P~ ~~,~ NOTE: II' YOU ARb; CURRF;N'I'1.Y YRO'1'N;C"I'ED HY 1'Hb; I+11.ING OF A PP;'I'I'1'10.~' Iti 13AVKRUI'TCY, 1'111+. FO1.1.OR'INC PART OF THIS NO'17CN; IS FOR INTOR~1AT10\ 1'URI'OSF:S ONLY :AND SHOULD NOT HE CONSIDERN;D AS AY ATTN;~IPT TO COLI,F,C'1"I'HN; DNR'1'. (If you have filed bankruptcy you can still apply for Emergency ~9ortgage Assistance.) HO~V'I'O CUKA; YOUR ~IOR'1'GAGA; lll?FAUI;I' (llring it up to date). N;1TURl? OF'1')1N: DA;F:~UI.I' -- The JIOK7'GA(ili debt held by the shove lender is mt your property located at: 17a W Glenwood Dr Camp Hill, PA 17011-1139 IS SERIOUSLY IN DEFAULT because: l'Oi; ll:1VP. N0T MADP. AION1'lI1,Y ;vIORT(IAGT: P:1YMF.NTS for the following months and the following amounts are now past due: April 1, 2001 through June 1, 2001. See attached Exhibit for payment breakdown. Monthly Payments 1, 6 5 2 . 9 0 late Charges 92 • 28 NSF o .oo Inspections 0 . 0 0 Other Suspense 14 .5 0 TOTAL, A~fOUN'1' PAST DUE: 1, 68 0.18 Il. YOI` }I:1VE F:111.P,D TO 1'AKP. Tlll', FOI,LO\~'ING ACTION (Do not use if_ngt_applicahle): HOW TO CURE 1'HA;1)N;FAUL7_' --You may cure the default within T}]IR'1'Y (30) DAYS of the date ofthis - _. _.. - notice RY PAYING THE TOTAL, AbIOUNT PAST DUE TO THE LENDER, WI llCl1 1S $ 1, 680.18 ,PLUS ANY isfORTCiAGIi P:1YMP.NTS :1ND I,:~TF. CIIAR(irS N'lI1Cll BF.COMI? Dl'P. DlJ](ING T]lli TIIIR7'Y (30) DAY P1iR10D. Pavntems must 1?e made either by cash, cashie>'s check, certified check or money order made payable and sent to: Payment Processing GMAC Mortgage Corporation PO Box 780 Waterloo, IA 50704-0780 ~'ou can sire any other default by taking the following action within ThIR7Y (30) DAYS of the date of tl»s letter: (I)gnotuseifnotapplicahle') Not Applicable IF YOU DO N01' CURE 1'HN; DEFAULT -- If you do not cure the default witJtin TIllKTy' (30) D:1~'S of the date ofthis Notice, the_Icnder intends to exercise its rights to accelerate the mortgage debt 'this means that the antic outstanding balance ofthis debt will he considered due immediately and yon may lose the chance to pay the mortgage in monthly installments. ]f fill payment of the total amount past due is not made wit]»n TI IIR7Y (30) D:1YS, the lender also intends to instnict its attomeys to start legal action U> foreclose upon yom• mm•igaged propc~4y. 11' 'I'}iA; ;v10RTGAGE IS hORECLOSF,D UPON --1'he mortgaged property will he sold by the Sheriff to pay off the mortgage debt. If the lender refers your case to its attorneys, but you cure the delinquency before the lender begins legal proceedings against you, you will still he inquired to pay the reasonable attorney's fees that were actually incurred, up to $0.00. however, if legal proceedings are started against against you, you will have to pay all reasonable attorney's fees achtally inatrred by the lender even if they exceed $0.00.:1ny attomeys fees will he added to the amount you owe the lender, which may also inch~de other reasonable costs. If you cm•e the default within the THIRTY (30) DAYS period, you will not he required to pay attorney's fees. ~~~~d~ tabu _OTHN;k I,N:NDN:k kAb1N:DIN:S -- The lender may also sue you personally for the unpaid principal balance and all other sums due wider the mortgage. _kIG}1'1"1'O CUkN; THN: DN;FAULT YKIOk TO SHN;KIhh'S SAI,N; -- If you have not cured the default within the TIJIR'I'\' (i0) DAY period and foreclosure; pmcecdings have begun, ov ii still_have the right fo cure the dcfa~dt and prevent the sale at any time up to one hour before the Sheriffs Sale. ~'ou may do so by payinP, the total amount then past due, plus any late or other charges then due, reasonable attomey's fees and costs connected with the foreclosure sale and any other costs connected with the Sheriffs Sale as specified in writing by the lender and by perforating any other requirements under the mortgage. Curing your default in the manner set forth in this notice will restore your mortgage to the same position as if you had never defaulted. F,AKI,IN:ST YOSSIRI,F, SAN;kIFF'S SAI,F. DATN: -- It is estimated that the earliest date that such a Sheriffs Sale of the mortgaged property could be held would be approximately six (6) months from the date of this Notice. A notice of the actual date of the Sheriff s Sale will be sent to you before the sale. Of course, the amount needed to cure the default will increase the longer you wail You may find out at any time exactly what the required payment or action will he by contacting the lender. HOW TO COY'1'AC7"I'AN; I,N;NDN:K: Name of Lender: GMAC Mortgage Corporation Address: 401 Mile of Cars Way National City, CA 91950 Phone Number: (800) 850-4622 Fax Number: (619) 470-5579 Contact Person: Collection Department _F,_FFN:C'I' OF SAN;KIFF'S SAI,F, -- ~'ou should realize that a Sheriffs Sale will end your ownership of the mortgaged pmperty and your right to occupy it. Ifyou continue to live in the property after the Sheriffs Sale, a lawsuit to remove you and your fitmishings and other helwtgings could he started by the lender at any time. ASSU~A'770N OF ~10kTCACF, --You may or may not sell or transfer your home to a htryer or transferee who will assume the mortgage debt, provided that all the outstanding payments, charges and attorney's fees and costs are paid prior to or at the sale and that the other requirements of the mortgage are satisfied. YOU ~fAY ALSO AAVN: THN kIGH'I': TO SP.LI, TIIP.I'ROPIsR7l' TO OIIT:\IN bfONP.Y TO PAY OPP 1'}I}'. ~IORTG:\Gli DP11'1' OR TO HORROR' `IONP,1' PROA1 :\NOTFIP.R ITNDING INS77TL'"I'ION'1'O I':\l' OPP 1'1llS DP.B'I'. T'O ]1:AVI'.'f}]1S DI•TA1;LT CIJRRD BY :A;VY T1llRD I':V27'Y ACTING ON YOi'R II]ill:AL1'. TO 11:1Y7i 7']l]', bfORTCiAGIi RPS1'ORP.ll TO 7111: S:A~fl'. POS]'fION :AS IF NO DIiI~A1:1,T 11:AD O('CIIKRT?D, Ih YOIJ Cl,'RIi 77ll? DIiPAIII,T. (]IOW1iV1iK, l'Ol; DO NO"1' ] ]:\VF'I']IIS RKi] 1'1' TO CI;RI? YOI;R Dl?1'AI71.T J'[ORIi 1']3:1N T11RIl]' TIMftS IN :1NY CAI,P.Nll:\R Yb;:1R.) 'f0:\SSP.RT TI]I'. NONI?X1S77',NCI'. OP A D1?P:\L']:1' IN :\NY I'OR]?CLOSI'RE I'KOCLLDING OR AN\' 07X7?R LAWSUIT I\S1']T1;TI•a UNDIiR T11]'. ~10RT(iAGP. DOCI:~I]iNTS, 7'O:\SSI',R'I' AN}' O'1'll]?k DP7~1'.NSI! 1'Ol; Bl?I,IHV]', ~'Ol; ~IAI' I]ACI'. TO SL'C}] AC770N II}' 77ll'. I LNDP.R. TO SP.]'.K 1'R077'.C7'ION isAllI?R 77ll{ PSllP.R:AI.I3:ANKRI:]'7Y:Y I .4R'. CONSU~IHk CKN;DI'1' COU\SN:LIN(: AGN:NCIN:S SN;kVING YOUk COUNTY IS N:NCLOSN:D ~~~~~ u~n PEYNSYLV?.NIA HOUSING FINANCE AGENCY HOMEOWNER'S EMERGENCY ASSISTANCE PROGRAM COYSUMER CREDIT COUNSELING AGENCIES (REV. 8100) CLINTON COUNTY LycomingClintan Counties Commision far CCCS of Northeaztem PA Community Action (STEP) 1631 South Atherton St, Suite 100 2138 Lincoln Sveet P.O. Box 1328 State College, PA 16801 Williamsport, PA 17703 (814) 238-3668 FAX (813) 238-3669 (570) 326-0587 FAX (570) 322-2197 CCCS ofNortheastem PA 201 Basin Sveet Williamspor; PA 17703 (570) 323.6627 FAX (570) 323.6626 3l W. Market Sveet POB 1127 Wilkes-Barre, PA 18702 (570) 821-0837 or (800) 922.9531 FAX (370) 821-1785 COLUMBL4 COL~TY Commission on Economics Opportunity of Luzeme County 163 Amber Lane Wilkes-Barre, PA 18702 (570) 526-0510 or (800) 822-0359 FAX (570) 329-1665-(Call Before Faxing) (510) 455.3994 Hanltown FAX (570) 455-5631--(Call Before Fazing) (570)836-1090 Tunkhannock CRAWFORD COUNTY Booker T. Wazhington Center 1720 Holland Center Erie, PA 16503 (814) 453-3734 FAX (814) 5749 John F. Kennedy Center, Inc. 2021 East 20i° Sveet Erie, PA 16510 (814)398.0400 FAX (814) 398-1233 CCCS of Westam Pennsylvania, Inc. 2000 Linglestown Road Hartisburg. PA 17102 (717)541-1757 Urban League of Mevopolitan Hamsburg N. 6i° Sveet Harrisburg, PA 17101 (717) 234-5925 F.4X (717) 233-9459 Community Action Comm of the Capita Region lU t4 Derry Sveet Harrisburg, PA 17104 (717) 232-9757 FAX (717) 234-2227 CUMBERLAW COL^iTY 1300 Abingron Executive Park Suite I Clarks Summit PA 1841 I (570) 587.9163 or (800) 92t-953 i FASC (570) 387-9133-9135 Greater Erie Community Action Commiaee l8 Wes[ 9rd Svee[ Erie, PA 16501 (813) 459-3581 FA,X (814) 356-0161 Shenango Valley Urban League, Inc. 601 Indiana Avenue Farrell, PA 161'_ I (412)91 (-5310 Financial Counseling Services of Franklin 31 West 3i° Sveet Waynesboro, PA IT_68 (717) 762-3285 YWCA of Carlisle 301 "G" Sveet Carlislq PA 17013 (717) 243-3813 FAX (717) 73 t-9589 Adams County Housing Authority 139.143 Carlisle St. Gemsburg, PA ITi25 (717)334-1513 FA.Y 334-8326 PENNSYLVA.NL1 BCLLETIN, VOL. 29, NO. 23, .TUNE 5, 1999 ~J THAT CERTAIN trot( or parcel oj(and and premises, situate, lying and being in the Township o/ East Pennsboro in the Counry of Cumberland and Commonwealth of Pennryivartia, mare particularly described as faiiows: In Accordance with survey of Gerrit J. Betz Associates, Inc., Engineers and Surveyors, dated August 29, 1977, as follows, to wit: BEGINNING at a point on the westerly line of Glenwood Drive (West), which point is 332.56 feet North of the norhwesterly corner of Erford Road (West) and Glenwood Drive (West) and at dividing line between Lot Numbers 4 and 4X, Block "H" on the hereinafter mentioned Plan of Lots; thence along said dividing line, North 63 degrees 30 minutes West and through the center of a partition wall and beyond 115.0 feet to a point; thence along dividing line between Lot Nos. 22X and 23, and 4X, Block "H", North 26 degrees 30 minutes East 37.5 feet to a point at dividing line between Lot Nos. 4X and 5, Block "H" on said Plan; thence along said dividing line, South 63 degrees 30 minutes East 115 feet to a point on the westerly line of Glenwood Drive (West) aforesaid; thence along same, South 26 degrees 30 minutes West 37.5 feet to a point, the place of BEGINNING. BEING Lot Number 4X, Hlock "H", on Plan No. 10, Ridley Park, which Plan is recorded in the Office of the Recorder of Deeds in and for Cumberland County, Pennsylvania, in Plan Book 18, Page 47. HAVING THEREON erected a dwelling house known and numbered as 17 A Glenwood Drive (West). UNDER AND SUBJECT, nevertheless, to easements, restrictions, reservations, conditions and rights-of-way of record. VERIFICATION KRISTINEjNILSON 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, information 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. ~iLt~lT.~'.. ~.~cLQ~}t? DATE: ~ - I ~ ' 0 I ,, - , -~ ? r A3 ,, dda~ k = ~'' .,_ ., a„'i'~j3 Gr"~ . v ammsrznws~c sq~a'~~iixs+~ ze,~usrwrM~~~n~ w+s~.eiaw =5~,•.o.L. o .x~ .i~_~~ n x~a = ..n ... -'%«.m ~+~,a~yz~pg `FEDERMAN AND PHELAN, LLP By: FRANK FEDERMAN, ESQUII2E IDENTIFICATION NO. 12248 ATTORNEY FOR PLAINTIFF ONE PENN CENTER AT SUBURBAN STATION 1617 JOHN F. KENNEDY BOULEVARD SUITE 1400 PHII,ADELPHIA, PA 19103-1814 (215) 563-7000 COURT OF COMMON PLEAS CIVIL DIVISION GMAC MORTGAGE CORPORATION OF PA 401 MILE OF CARS WAY NATIONAL CITY, CA 91950 v. Plaintiff TERM RICHARD L. THUMMA KIMBERLY A. CLARK 17 A WEST GLENWOOD DRNE CAMP HILL, PA 17011 Defendant(s) NO. (7 I - y B Y~- U.~ ~~ CUMBERLAND COUNTY CIVIL ACTION -LAW COMPLAINT IN MORTGAGE FORECLOSURE NOTICE **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 THIS DEBT WAS NOT REAFFH2MED, 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 appearance 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 may be 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 Plaintff. 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. CUMBERLAND COUNTY CUMBERLAND COUNTY BAR ASSOCIATION 2 LIBERTY AVENUE CARLISLE, PA 17013 (717)249-3166 Loan #: A50184908 IF THIS IS THE FIIiST NOTICE THAT YOU HAVE RECEIVED FROM THIS OFFICE, BE ADVISED THAT: PURSUANT TO THE FAIR DEBT COLLECTION PRACTICES ACT, 15 U.S.C. § 1692 et seq. (1977), DEFENDANT(S) MAY DISPUTE THE VALIDITY OF THE DEBT OR ANY PORTION THEREOF. IF DEFENDANT(S) DO SO IN WRITING WITHIN THIRTY (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 PROVH)ES THAT YOUR ANSWER TO THIS COMPLAINT IS TO BE FILED IN THIS ACTION WITHIN TWENTY (20) DAYS, YOU MAY OBTAIN AN EXTENSIION 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. Plaintiff is GMAC MORTGAGE CORPORATION OF PA 401 MILE OF CARS WAY NATIONAL CITY, CA 91950 2. The name(s) and last known address(es) of the Defendant(s) are: RICHARD L. THiJMMA KIMBERLY A. CLARK 17 A WEST GLENWOOD DRIVE CAMP HILL, PA 17011 who is/are the mortgagor(s) and real owner(s) of the property hereinafter described. On 7/28/95 mortgagor(s) made, executed and delivered a mortgage upon the premises hereinafter described to PLAINTIFF which mortgage is recorded in the Office of the Recorder of CUMBERLAND County, in Mortgage Book No. 1276, Page 75. 4. The premises subject to said mortgage is described as attached. The mortgage is in default because monthly payments of principal and interest upon said mortgage due 4/1/01 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 all 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 $57,367.99 Interest 1,784.86 3/1/01 through 8/1/01 (Per Diem $11.59) Attorney's Fees 2,868.00 Cumulative Late Chazges 48.92 7/28/45 to 8(1(01 Cost of Suit and Title Search 550.00 Subtotal $62,619.77 Escrow Credit 0.00 Deficit 127.07 Subtotal $ 127.07 TOTAL $62,746.84 The attorney's fees set forth above are inconformity with the Mortgage docurnents 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. This action does not come under Act 6 of 1974 because the original mortgage amount exceeds $50,000.00. 9. The Combined Notce 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 Plainriff's written Notice to Defendants, a true and correct copy of which is attached hereto as Exhibit "A"; or (ii.) Defendant(s) applicafion 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 $62,746.84, together with interest from 8/1/01 at the rate of $11.59 per diem to the date of Judgment, and other costs and charges collecfible under the mortgage and for the foreclosure and sale of the mortgaged property. ~~..~~~~ /s/ Frank Federman FRANK FEDERMAN, ESQUIltE Attorney for Plaintiff 08itai0l 18:3A FAX 215 682 7.94.0 G1fACM - CORP DEPALrLT 0002/006 uu nvc 50,o4.~,ao GMAC Mortgage ..__ Date: June 12, 2001 ACT 91 NOTICE TAKE ACTION TO SAVE YOUR HOME FROM FORECLOSURE This is an official notice th t the mo a e o your home is m defank. and the lender intends to foredose. Snecdlc nsforma on about the nature of the default is nrovlded in the atlnched paces. The HOriIEOWNER'S MORTGAGE ASSISTANCE PROGRAM [HEMAPI maKbe a61e to help to save corer home. This Notice eznlains bow the uroesgm works. This Notice contains importantlegsl information.IFyon have aqc questions, representatives atthe Consumer Credit Conasetimg Agenry may be able 6u help axph:m it. yon may also want to coact an attorney in your area. The local bar association may be able to help you End a lawyer. LA SALVAR SU CASA HOMEOWNER'S NAME(S): PROPERTY ADDRESS: LOAN ACCT. NO.: ORIGINAL LENDER: CURRENT LENDER/SERVICER: DEL DERECHO A A REDIRQR SII KIMBERLY A. CLARK 17A W GLENWOOD DR CAMP HILL, pA 17011.1139 450184903 x1/A GMAC Mortgage Corpozation r./~~BI~ a/~a EN Abi[TNTO ES DE NDO EN SII CASH. Sl TENGA UNA TRADU First Mortgage Loan Servicing PO Box, 85071 San Diego CA 92186-5071 3451 Hammond Ave PO Box 780 Waterloo IA 50704-0780 GMAC MOrtgagE Date: June 12, 2001 ACT 91 NOTICE TAKE ACTION TO SAVE YOUR HOME FROM FORECLOSURE This is an ofScial notice that the mortgage on your home is in.default, and the lender intends to_foreclose. Specific information about the nature _of the default is provsded in the attached pa8es, The F10iVtF;OWNI?R'S N10RTGAGF, AS$ISTANCF YROGRAM_(AFMA_P) maybe able to help to save your home, This Notice explains how the program works. To see if AEMAP can help, you must_N1_F,FT WITH A CONSUIVIF,R I;RF,DIT COUNSF,I.ING AGENCY WITHIN 301)AYS O_ F TAF 1)ATF, OF THIS NOTICF„_Take_t6is Notice with you when you meet with the Counseling Agency, 1'hc panic, addresx and_phunc qu~uher of Cm~sun~ex Credit Cowiscliug Agencies serving yow Comity arc listed at the end of this Notice. If you have any questions, you may call the Pennsylvania Housing Finance Agency toll free at 7-800-342-2397. (Persons with impaired bearing can call (777) 780-1869), This Nolicc cm~tains important Icgal information. If you Gave any questions, representatives at the Consumer Credit Counseling Agency may be able to help explain it, You may also want to contact an attorney in your area. The local bar association may be able to help you Snd a lawyer. I.A NOTIFICACION F,N ADJUN7'O F,S DE SUMA IMYORTANCIA, PUF,S AFF,CTA SU DF,RF;CHO A CONTINUAR VIVIB;NI)O F.N SU CASH. SI NO COMPRF,NI)F. F,I. CONTENIDO I)F, F,STA NOTIFICACION ORTENGA UNA TRADUCCION IMMEDIATAMF,NTF. LLAMANDO F,STA AGF,NCIA (PF,NNSYLVANIA HOUSING FINANCE. AGENCY) SIN CARGOS AL NUMF,RO MF.NCIONADO ARRIIIA. PUEDF.S SF,R F.LF.GIRLF. PARR UN PRF,S1'A1V10 POR F.I. PROCRAMA I,I,Ab1A1)O "HOMP;ON'NER'S E)ViISRGENCY ]V10RTGA(:E ASSIS•I'ANCE PROGRAM" F,L CUAI, YUEDE SAI,VAR SU CASA 1)F, LA PF.RDIDA DF,I, I)F,RECI)O A RF,DIMIR SU IIIYOTECA IlOh1N;OW'NN;R'S NAMP;(S): RICHARD L. THUMMA 17A W GLENWOOD DR PROPERI'YAI)DRF,SS: CAMP HILL, PA 17011-1139 LOAN ACCT. NO.: 450189908 ORIGINAL, LA;NDN;R: N/A CURRI?NT1.b;NDF,R/SERVICN;R: GMAC Mortgage corporation HOMEOWNP:K'S F,MN:KGENCY MORTGAGE, ASSISTANCF, PKOGKAM YOU MAY 13F, F,hIGIAI,F, FOR FINANCIAh ASSISTANCF WHICH CAN SAVE, YOUR AOiViF, FROM FORF,CLOSUKF, AND HP:I,Y YOU MAKE FU'1'URb: MOKTGAGE YAYMEN'I'S IF YOU COMPhY WITH 1'HE PROVISIONS OF 1'HE HOMF:OWNF,K'S F,MF,RGF,NCY M11ORTGAGF, ASSISTANCF: ACT OF ]983 (THN; "ACT"), YOU MAY IIF, F,hIGIBhF, FOR F,MEKGF,NCY MORTGAGE ASSISTANCE: IF YOUR DF,FAUL1' 11AS Ih?I±\ CAUSEll lIY C1RCU~iS'1'ANCI±S YOUR CONTKOI„ IF YOU HAVN; A KF;ASONARI,E PKOSYECT Oh RN;ING AALF, TO PAY YOUR MORTGAGE YAYMEN'I'S, AND IF YOU MF,F,T OT}IEK F,hIGIRIhI'1'Y RF,QUIRB:MEN1'S F,STA)SI,ISHED BY THE PF,NNSYhVANIA HOUSING FINANCE, AGF,NCY. 1'EMI'OKAKY STAY OF FOREChOSURb; -- lhmderthe Act, you are entitled to a temporary stay of foreclosure on your mortgage for thirty (30) days from the dale of this Notice. During that time you must arrange and attend a "face-to-face" meeting with one of the consumer credit counseling agencies listed at [he end of this Notice. THIS b1hb;77NG ;vfUS1'_O_CCUR WI1 HIN THT', NF_X1' (30) HAYS, IF YO_iJ DO NOT APPI Y FOR EMFRGENCY_ MORTGAGE ASSISTANCF, YOU MIDST BRING 1'OlJR MORTGAGIi UP TO DATE. TIIP. PART OF THIS NOTICIs CAI_LP,D "HOW TO CIJRF YOUR MORTGAGE, I)FEA(JI T', EXPI AINS_}IOW TO II_RING ~'OUK MORTGr1GF, UP TO DATTi. CONSUMF,K CKF,n1TCOUNSF,hING AGENCIES -- ]f you meet with one of the consumer credit counseling agencies listed at the end of this notice, the lender may NOT take action against you for thirty (30) days after the date of this meeting.The names addresses and telephone mimbers of designated consumer cred_ it cotnseling agencies for the county_inwhich the properly is located are set fortlm at the end of this Notice. It is only necessary to schedule one face-to-}ace meeting. Advise youv tender immediately of your intentions. AYYI,ICATION NOR iV1ORTGAGN: A$SIS1'ANCN: -- Youv mortgage is in default for the reasons set forth later in this Notice (see following pages for specific information shout the native of your default.) ]f you have tried a»d are unable to resolve this problem with the lender, you have the right to apply for rnancial assistance from the homeowner's Panergency Mortgage Assistance Program. To do so, you numst SII out, sign and file a completed ] Imneowner's Emergency Assistance Program Application with one of the designated consumer credit counseling agencies listed a[ the end of this Notice. Only consumer credit counseling agencies have applications for the pmgranm and they will assist you in submitting a complete application to the Pennsylvania housing Finance agency. Your application MUST he filed or postnmarked within thirty (30) days of you face-to-face meeting. YOU MUST FILE YOUK APPLICATION PROh1Y'I7.Y. II+ YOU FAIL, TO DO SO OK IF YOU DO NO1' FOhhON' T`HE O1'HEK TIME, PERIODS SF,T FORTH IN THIS hE1"I'EK, FORECLOSUKF: M1fAY PROCEED AGAINST YOUK HOME, IMMEDIATN:I,Y AND YOUK AYI'I,ICATION I+OK MOR'PGAGh; ASSISTANCE W'll,l, IIN; DENIED. AGENCY AC77ON --Available funds for emergency mortgage assistance are very limited. They will be disbursed by the Agency minder t]me eligibility criteria established by the Act. The Pennsylvania ]]ousing Finance Agency has sixty (60) days to make a decision after it receives your application. Ihving that time, no foreclosure proceedings will be punned against you if you have met the time regwrements set forth above. You will be notified directly by [he Pennsylvania housing Finance Agency of its decision on your applicatimu. ~~~~~ ~~~ NOTE: IF YOU AItE CURREN'17,Y YROTN;C1'A;D BY THE FILING OI+ A PbPI'1'1'ION IN IIANKRUY'1'CY, THb; EOI,LOWING PART OT T}IIS NOTICE, IS FOR INFOR)VIA770N YURPOSF,S ONLY AND SHOULD NOT BE CONSIDAItFD AS AN A7TN;MYT 1'O COI,LI?C'I' THN; DEBT. (If you have filed bankruptcy you can str71 apply for Emergency Mortgage Assistance.) IiOW TO CUKN; YOUR ~IOR'1'GAGE llA;hAUI,I' (Bring it up to date). NATU$E OI?'I'HN; DEEAUI,'1' -- The hIORTGAGP, debt held by the above lender is on your property located at: 17a W Glenwood Dr Camp Hill, PA 17011-1139 IS SERIOUSLY IN DEFAULT because: YOIJ IIAVF N0T MADP. MONTIII,Y MORTGA(iB PAYMENTS for the following months and the following amounts are now past due: April 1, 2001 through June 1, 2001. See attached Exhibit for payment breakdown. Monthly Payments 1, 652.40 I ate Charges 9 2.2 8 NSF o.00 Inspections 0 . 0 0 Other Suspense 19.5 0 7'o7'nl, AMOUNT PnsT nuE: 1,680.18 II. YOU IIAVFi PAILP,D TO TAKE TIIP, FOLLOWING ACTION (Do not use if not applicable): HOW 1'O_ CUItF, THE DEI+AULT --You may cure the default within 1'IIIR'1'Y (30) DAYS of the date ofthis notice BY PAYING THF. TOTAL AMOUNT PAST DUF. TO THE LF,NDER, WIllCI11S $ 1, 680.18 ,PLUS ANY MORTGAGP. PAYMENTS AND LATE. CHARGES WHK;H HFCOM}: DlJP. DURING T}II'. T}I1RTY (30) DAY PP,RIOD. Payments _mitst he_made either by cash, cashier's check, ceriired check or money order made payable and sent to: Payment Processing GMAC Mortgage Corporation PO Box 780 Waterloo, IA 50709-0780 You can acre arry other default by taking the following action within TI ARTY (30) DAYS of the date of [his letter: (Don~tuseifngtapplicable.) Not Applicable II' YOU DO N0T CURE THE DEFAUI,1' -- If you do not care the default within Tll1RTY (30) DAYS of the date ofthis Notice, the lender intends to exercise its rights to accelerate the mortgage deb6 'T'his means that the entire outstanding balance of this debt will he considered due immediately and you may lose the chance to pay the mortgage m monthly installments. If fill payment of the total amount past due is not made wit]rin THIRTY (30) De1YS, the lenderalso intends to instmd its attorneys to start legal action to foreclose_uponyouurmortgaggd property. ll~ T}il? bl_QkTGA(:1'; IS_I?OItFC1.OSF1)_ 11YON -- The mortgaged property will be sold by the Sheriff to pay off the mortgage debt If the lender refer your case to its attorneys, but you clue the delinquency before the lender begins legal proceedings against you, you will still he required to pay the reasonable attomey's fees that were actually incurred, up to $50.00. However, if legal proceedings are started against against you, you will have to pay all reasonable attomey's fees actually ina~rred by the lender even if [hey exceed $50.00. Any attorney's fees will he added to the amount you owe the lender, which may also include other reasonable costs. If you cure the default within the THIRTY (30) DAYS period, you will not be required to pay attorney's fees. GA1-Alf 1 ee~eF OT}1NIt I,ENI)ER REMF.I)IF.$ -- T7ie lender may also sue yon personally for the unpaid principal balance and all other sums due under the mortgage. RIGHT TO CURE T}lE DEFAULT PRIOR TO SHKRIFF'S SALT -- If you have not cured the default within the 7711R7'Y (30) DA}' period and foreclosure proceedings have begin, you still have the right tg cure the default and prevent the sale at any time up to one hour before the Sheriffs Sale. You may do so by payine, the total amount then past due, plus any late or other charges then due, reasonable attorney's fees and costs connected with the foreclosure sale and any other costs connected with the Sheriffs Sale as specified in writing by the lender and by ~rfomiing any other requirements under the mortgage. Curing your default in the manner set forth in this notice will restore your mortgage to the same position as if you had never defaulted. F,ARLIF,ST POSSIBLE SHERIFF'S SALT DATE, -- It is estimated that the earliest date that such a Sheriff's Sale of the mortgaged property could be held would be approximately six (6) months from the date of this Notice. A notice of the ach~al date of the Sherill c Sale will be sent to you before [he sale. Of cow•se, the amount needed to acre the default will increase the longer yon wait. You may find out at any time exactly what the required payment or action will be by contacting the lender. HOW TO CONTACT TNb;1,ENDER: Name of Lender: GMAC Mortgage Corporation Address: 401 Mile of Cars Way National City, CA 91950 Phone Number: (800) 850-9622 Fax Number: (619) 470-5579 Contact Person: Collection Department F,FPNCT O_ F SAI?RIFT'$ SALE. --1'ou should realize that a Sheriff s Sale will end your ownership of the mortgaged property and your right to occupy it. If you continue to live in the properly after the Sheriff s Sale, a lawsuit to remove you and yoiv furnishings and other belongings could he started by the lender at any time. ASSUM]'1'1 ON OT MORTGAGE, --You may or may not sell or transfer yoiu home to a huger or transferee who will assume the mortgage debt, provided that all the outstanding payments, charges and attorney's fees and costs are paid prior to or at the sale and that the other requirements of the mortgage are satissed. YOU iy1AY ALSO AAVF: THE RIGA'I': TO SP,I,I.7TIP, PROPP,RTY TO O}ITAIN MONEY TO PAY OPP TH}i MORTGAGE DE}31' OR TO BORROW MONPY PROM :1NOTIIPR I,P.NDING INS177'l17'ION 7'O PAY OPP T}IIS DPRT. TO HAVE -f}11S DP.1'AlII,T CURRD I3Y AiVY Tl]]Rll PART2' ACTING ON YOlJR I31i11A1,P. TO HAVE T}Ili MORTGAGE RESTORP,ll TO TllE SAMP, POSIT}ON AS 1P NO DEFAIi].T MAD OCCURRED, IF YOU C1JRE 171Ii DP,PAIJI,T. (]IOWIVP.R, YOU DO NOT HAFT T'IllS ffiGII1' TO CI;R}i YOUR DEPAlJLT MOKE TI IAN TI1REli TIMES IN ANY CAI,P.NDAR YP.AR.) TO ASSERT TI1P, NONEXISI'IiNCE. OP A DEI'AlILT IN ANY FORECLOSlJRE PROCEP.DING OR AN}' OTHER LAWSUIT INSTITIJTF.D IJNDP,R T}lli MORTGAGP, DOCUMENTS, TO ASSP.RT ANY OTIll?R D}'.PI?NS]i YOII }3EI,ll?V7? YOII MAY ]IAVP, TO SUC}I ACTION }IY 771F. I,ENDP.R. TO SP.EK PRO77C-I7ON li\DP,R 77ll? E}ill}iKAI, IIANKR(Il'TCY LAW. C_ONSUiVIF;R CREI)I'1' COUNSF,I,ING AGENCIES SERVING YOUR COUNTY 1S F,NCI,OSED ~~f~f~ aAn PENNSYLVANIA HOUSING FINSuYCE AGENCY HOMEOWNER'S EMERGENCY ASSISTANCE PROGRAM CONSUMER CREDIT COUNSELING AGENCIES (REV, 8/00) CLINTON COUNTY Lycoming-Clinton Counties Commision for CCCS ofNonheastem PA Community Action (STEP) 1631 South Atherton St., Suite 100 2138 Lincoln Street P.O. Box 1328 State College, PA 16801 Williamsport, PA 17703 (814) 238-3668 FAX (814) Z38-3669 (570) 326-0567 FAX (570) 322-2197 CCCS of Northeastern PA 201 Basin Sueet Williamsport, PA 17703 (570) 323-6627 FAX (570) 3236626 3l W. Market Street POB 1127 Wilkes-Barn, PA 18702 (570) 821-0837 or (800) 922-9537 FAX (570) 821-1785 COLUMBIA COUNTY Commission on Economics Opportunity of Luume County 163 Amber Lane Wilkes-Barre, PA 18702 (570) 326-0510 or (800) 822-0359 FAX (570) 829-1665-{Call Before Faxing) (570) 455-7994 Hazeltown PAX (i70) 455-563I~CaI1 Before Faxing) (570)836-4090 Tunkhannock Booker T. Washington Center 1720 Holland Center Erie, PA 16503 (814) 453-5744 FAX (814) 5749 John F. Kennedy Center, Inc. 2021 East 20i° Street Erie, PA 16510 (814) 898-0400 FAX (814) 898-1243 CCCS of Western Pennsylvania, Inc. 2000 Linglestown Road Hartisbbrg, PA I7I02 (717)541-1757 Urban League of Menopolitan Harrisburg N. 6r° Sneet Harrisbu„ PA 17101 (717) 234-5925 fAX (717) 234-9459 Community Action Comm of the Capital Region 1514 Derry Street Harrisburg, PA 17104 (717) 232-9757 FAX (717) 234-2227 CRAWFORD COUNTY CUMBERLAND COUNTY 1400 Abington Executive Park Suite I Clarks Summit PA 184(1 (570)587.9163 or (800)922.9537 FAX (570) 587.9134-9135 Gremer Erie Community Action Committee l8 West 9"Street Erie, PA 16501 (814) 459-1581 FAX (814) 456-0161 Shenango Valley Urban League, Inc. 601 Indiana Avenue Farrell, PA 16121 (412)981-5310 Financial Counseling Services of Franklin 31 West 3i° Street Waynesboro, PA 17268 (717) 762-3285 YWC?.ofCazlisle - 301 "G"Street Carlislq PA I70I3 : (717) 243.3818 FAX (717) Ti I-9589 Adams County Housing Authority 139-143 Carlisle S[. Gemsburg, PA 17325 (717) 334-1518 FAX 334-8326 PENNSYLVA,YW BULLETIN, VOL. 29, N0.23, NNE 5, 1999 ~,717~6I~I D ~8'R~ ~I THAT CERTAIN tract or parcel ojfand and premises, siruotc, lying and being in the Township of East Pennsboro in she Coanry of Cumberland and CommonweaGh of Pennrylvania, more pariicu(arly descriGed as follows: In Accordance with survey of Gerrit J. Betz Associates, Znc., Engineers and Sufiveyors, dated August 29, 1977, as follows, to wit: BEGINNING at a point on the westerly line of Glenwood Drive (West), which point is 332.56 feet North of the norhwesterly corner of Erford Road (Westland Glenwood Drive (West) and at dividing line between Lot Numbers 4 and 4X, Block "H" on the hereinafter mentioned Plan of Lots; thence along said dividing line, North 63 degrees 30 minutes West and through the center of a partition wall and beyond 115.0 feet to a point; thence along dividing line between Lot Nos. 22X and 23, and 4X, Block "H", North 26 degrees 30 minutes East 37.5 feet to a paint at dividing line between Lot Nos. 4X and 5, Block "H" on said Plan; thence along said dividing line, South 63 degrees 30 minutes East 115 feet to a point on the westerly line of Glenwood Drive (West) aforesaid; thence along same, South 26 degrees 30 minutes West 37.5 feet to a point, the place of BEGINNING. BEING I,ot Number 4X, Block "H", on Plan No. 10, Ridley Park, which Plan is"recorded in the Office of the Recorder of Deeds in and for Cumberland County, Pennsylvania, in Plan Book 18, Page 47. FIAVING THEREON erected a dwelling house known and numbered as 17 A Glenwood Drive (West). UNDER AND SUBJECT, nevertheless, to easements, restrictions, reservations, conditions and rights-of-way of record. VERIFICATION KRISTINE~JIL5ON 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 aze true and correct to the best of her knowledge, information and belief. The undersigned understands that this statement is made subject to the penalties of 18 Pa. C.S. Sec. 4904 relating to unsworn falsification to authorities. DATE: ~ - I o - d I ,;,.,„~ C ~ ' : Y -~. _, ~ _~ ~ - ~.. Gr'_. -,', it C-" 'u \a y '~ ~,` ~R v5~~ra?N+n~ ~rywt*Mxca~Frt+vas~ma~nsw ~-'~..u sz -a v n ,..-,a° r , -c.. w =any. r nva=~ ~~~ AFFH)AVIT OF SERVICE PLAINTIFF GMAC MORTGAGE CORPORATION OF PA DEFENDANT(S) RICHARD L. THUMMA KIMBERLY A. CLARK SERVE KIMBERLY A. CLARK AT 17 A WEST GLENWOOD DRIVE CAMP HILL, PA 17011 No. 01-4842 CUMBERLAND COUNTY Type of Action - Notice of Sheriff s Sale Sale Date: MARCH 6, 2002 SERVED Served and made known to ~~ t,~.t(OeK~~I ~ ' e 18tek ,Defendant, on the ~ day of ~~~ , 200 [ , at ; ~~ ,o'clock~.m., at ~ 7 A ~ ~ GIQNwoo~ fJtf , t ~aN^~~'~~1 ,Commonwealth of Pennsylvania, in the manner described below: X 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: Description: Age ,~~ Height ~ t Weight ~a ~ Race X14 Sex ~ Other [, ~,~(eNCt ~-~ e-Q~~Y ~n. , a competent adult, being duly sworn according to law, depose and state that I personally handed a tme and correct copy of the Notice of Sheriffls 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 15 day of C ,200 . Notary: n . A n ~ My NOT SERVED On the 'remunc r~ays~i}ania gssociaaon of Notaries 200_, at Moved Unknown No Answer Other Sworn to and subscribed before me this day of , 200 Notary: By: A[[arnev for Plaintiff Frank Federman, Esquire - I.D. No. 12248 One Penn Center at Suburban Station 1617 John F. Kennedy Boulevard, Suite 1400 Philadelphia, PA 19103-1814 (215)563-7000 o'clock _.m., Defendant NOT FOUND because: Vacant ~S a ._ ...~mce IAnMPoaR"~ah3ta.: x.m`~ax „ P r F, w.9 _ia., ;t* nom'..-.._e... y. , , , .r, yr . .era ,~ FEDERMAN AND PHELAN By: FRANK FEDERMAN Identii'ication No. 12248 Attorney for Plaintiff ONE PENN CENTER AT SUBURBAN STATION 1617 JOHN F. KENNEDY BLVD., SUITE 1400 PHILADELPHIA, PA 19103-1814 (215) 563-7000 GMAC MORTGAGE CORPORATION OF PA 401 MILE OF CARS WAY NATIONAL CITY, CA 91950 Plaintiff, v. RICHARD L. THUMMA KIMBERLY A. CLARK Defendant(s). CUMBERLAND COUNTY COURT OF COMMON PLEAS CIVIL; DIIVISION NO. 01-4842 PRAECIPE FOR JUDGMENT FOR FAILURE TO ANSWER AND ASSESSMENT OF DAMAGES TO THE PROTHONOTARY: Kindly enter judgment in favor of the Plaintiff and against RICHARD L. THUMMA and KIMBERLY A. CLARK, Defendant(s) for failure to file an Answer to Plaintiff s Complaint within 20 days from service thereof and for Foreclosure and Sale of the mortgaged premises, and assess Plaintiff s damages as follows: As set forth in Complaint Interest from 8/1/01 to 10/2/01 TOTAL $62,746.84 $718.58 $63,465.42 I hereby certify that (1) the addresses of the Plaintiff and Defendant(s) are as shown above, and (2) that notice has been given in accordance with Ruh 237.1, copy attached. ESQUIRE for DAMAGES ARE HEREBY ASSESSED AS INDICATED. DATE: /p-o7~ .Q/ /5/ ~%~~ ,~ PRO PROTHY ~~ ~ ~ F ~~ 1~ e~ e , +~ f~ -~ _ \\\\VV\\\] 1 ~ { i. ,~ rid ~< <.- ,`v _ ~/~ `~~ •~ ~<. J FEDERMAN AND PHELAN, L.L.P. Frank Federman, Esquire Identification No. 12248 One Penn Center Plaza at Suburban Station, Suite 1400 Pha.ladelphia, PA 19103-1799 (215) 563-7000 GMAC MORTGAGE CORPORATION OF PA Plaintiff vs. RICHARD L. THUMMA KIMBERLY A. CLARK Defendant(s) TO: RICHARD L. THUMMA 5252 OAKLAND STREET PHILADELPHIA,PA 19142 ATTORNEY FOR PLAINTIFF COURT OF COMMON PLEAS CIVIL DIVISION CUMBERLAND COUNTY NO. 01-4842 CIVIL " ~ ~,. ~-a^n Qa i, ` , ~ 9 - _. ~ ;, DATE OF NOTICE: SEPTEMBER 19,2001 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 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 OF PA Plaintiff vs. RICHARD L. THUMMA KIMBERLY A. CLARK ATTORNEY FOR PLAINTIFF COURT OF COMMON PLEAS CIVIL DIVISION CUMBERLAND COUNTY N0.01-4842 CIVIL Defendant TO: KIMBERLY A. CLARK 17 A WEST GLENWOOD DRIVE CAMP HILL, PA 17011 ~~ e~, DATE OF NOTICE: SEPTEMBER 19.2001 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 Frank Federman, Esquire Attorney for Plaintiff ' 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 GMAC MORTGAGE CORPORATION OF PA Plaintiff vs. RICHARD L. THUMM.~ KIMBERLY A. CLARK ATTORNEY FOR PLAINTIFF COURT OF COMMON PLEAS CIVIL DIVISION CUMBERLAND COUNTY NO. 01-4842 CIVIL Defendant(s) TO: RICHARD L. THUMMA 5252 OAKLAND STREET PHILADELPHxA,PA 19142 r_ ~ DATE OF NOTICE: SEPTEMBER 19,2001 THIS FIRM TS A DEBT COLLECTOR ATTEMPTING TO COLLECT A DEBT. THIS NOTICIJ 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 Frank Federman, Esquire Attorney for Plaintiff f .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 OF PA Plaintiff vs. RICHARD L. THUMMA KIMBERLY A. CLARK ATTORNEY FOR PLAINTIFF COURT OF COMMON PLEAS CIVIL DIVISION CUMBERLAND COUNTY N0.01-4842 CIVIL Defendant TO: KIMBERLY A. CLARK 17 A WEST GLENWOOD DRIVE CAMP HILL, PA 17011 J ~~ ~ d~, DATE OF NOTICE: SEPTEMBER 19,2001 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 CLTNIBERLAND COUNTY BAR ASSOCIATION 2 LIBERTY AVENUE CARLISLE, PA 17013 (717) 249-3166 Frank Federman, Esquire Attorney for Plaintiff ~ c_~ ~ ~ ~, -- ror v" (^ "'°d _ v;. ,> ...; , .,, ;.? i ll*?Ei~rttT. .. ... _ "~ :.._. _ ~.mawsmuc~s3Po~wmM arv ars * s ='~+s ~ ~ ,~ - ~, ~ ~.*- w++ azm»=sv~ u ~ <. a. "'+a-'a~I3si.... FEDERMAN and PHELAN By: FRANK FEDERMAN Identification No. 12248 ATTORNEY FOR PLAINTIFF ONE PENN CENTER AT SUBURBAN STATION 1617 JOHN F. KENNEDY BLVD., SUITE 1400 PHIIADELPHIA, PA 19103-1814 (215)563-7000 GMAC MORTGAGE CORPORATION OF PA 401 MILE OF CARS WAY CUMBERLAND COUNTY COURT OF COMMON PLEAS Plaintiff, v. RICHARD L. THUMMA KIMBERLY A. CLARK Defendant(s). CIVIL DIVISION NO.O1-4842 VERYFICATION OF NON-MILITARY SERVICE FRANK FEDERMAN, ESQUIRE, hereby verifies that he is attorney for the Plaintiff in the above-captioned matter, and that on information and belief, he has knowledge 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 RICHARD L. THUMMA is over 18 years of age and resides at , 17 A WEST GLENWOOD DRIVE, CAMP HILL, PA 17011 . (c) that defendant KIMBERLY A. CLARK is over 18 years of age, and resides at , 5252 OAKLAND STREET, PHILADELPHIA, PA 19142. This statement is made subject to the penalties of 18 Pa. C.S. Section 4904 relating to unsworn falsification to authorities. ' c --- ~ ~: rs ~f, __ " 7 ~ nu y c,~ c -~ _j _, . ,° -c y li ~ .,,, ~" PR~ECIPE FOR WRIT OF EXECUTION - (MORTGAGE FORECLOSURE) P.RC.P.3180-3183 GMAC MORTGAGE CORPORATION OF PA Plaintiff, v. No. 01-4842 RICHARD L. THi7MMA KIMBERLX A. CLARK Defendant(s). TO THE DIRECTOR OF THE OFFICE OF THE PROTHONOTARY: Issue writ of execution in the above matter: Amount Due Interest from 10/2/01 to 3/6/02 (per diem -10.43) TOTAL .~ $63,465.42 ~/ $1,616.65 and Costs $65,082.07 Penn Center at S~ 1 7 John F. Keened Philadelphia, PA 191 Attorney for Plaintiff Note: Please attach description of property.No. Durban Station Boulevard, Suite 1400 3-1814 4 w ~ o w O Wa O ~" z z ~a o O H ~ U 00 ~~" F„ U ~ ~~ H ~ Oa ~ FW ~ ~ U ~~ ~v H d a~ ~~ ~~ ~ ~ ~ I /-~ '~ U ~ ...~ O N .-a 7 Q O~ a ,..i a j ~ x~ a ~ a U W z ~x O A a., q F` ~ W .. ~ O DC ~ w y ~ ~ ~ ~ A ~ F c ~, W `° ~ ~~ o 30 o ~ GTr 50,E ~ .~ d ~ N ~ vNi U `~ w p a °~' ~" x~(I THA^_ cERTA:rr Townsh_p Cumberland vacr or parcel aj (and and premises, sitaatr, lying and being in the of East Pennsboro in the Coanry of and Cammon weaLh of Ptnnr/ivania, mort par:ic~(ar;y des_rtbed as fo/lows: In Accordance with survey of Gerrit 3. Betz Associates, Znc., Engineers and Surveyors, dated August 29, 1977, as follows, to '.~'_t: BEGINNING at a point on the westerly line of Glenwood Drive (Westj, which point is 332.56 feet North of the norhwest'erly corner of Erford Road (West) and Glenwood Drive ('Rest) and at dividing line betweer. Lot Numbers 4 and 4X, Block "H" on the hereinafter mentioned Plan of Lots; thence along said dividingf line, P7orth 63 degrees 30 minutes West and through the center of a partition wall and beycnd 115.0 feet to a point; thence along dividing line between Lot Nos. 22X and 23, and 4X, Block "H", North 26 degrees 30 minutes East 37.5 feet to a point at dividing line between Lot Nos. 4:t and 5, Block "H" on said Pian; thence along said dividing line, South 63 degrees 30 minutes East 115 feet to a point on the westerly line of Glenwood Drive (West} aforesaid; thence along same, South 26 degrees 30 minutes West 37.5 feet to a point, the place of BEGINL7ZNG. HE_TNG Lot Number 4X, Block "H", on Plan No. 10, Ridley Park, which Plan is recorded in the Office of the Recorder of Deeds in and for Cumberland County, Pennsylvania, in Plan Book 18, Page 4?. fIAVING THEREON erected a dwelling house known and numbered as 17 A Glenwood Drive (West). UNDER AND SUBJECT, nevertheless, to easements, restrictions, reservations, conditions and rights-of-way of record. .~ o, ~ ~ ` c(J~\ ~~ ~ ~ ;-, ni,-, ~ ~ ~ ~ ~ ~ ~ e ~ F ~ 2.x: ~ U~ ` ~ ~s ,~ _~ ~- -~ t ~ ~~.~ , z ,,, ~V /~ ~. °~, ~ ,~ v \tl~9` ~. AR4ME1`~1. __ iRV~ -.. .. .. ~StlsiY N9F[A4~nN~IF~R eKa~iei^ _ d.r s. ~.. - ~.4-hsq' !rc ~e3'n3~~5r i ':=rnT'~ TrvwwK~S7J4i; GMAC MORTGAGE CORPORATION OF PA Plaintiff, v. RICHARD L. THUMMA KIMBERLY A. CLARK CUMBERLAND COUNTY COURT OF COMMON PLEAS CIVIL DIVISION NO.Ol-4842 Defendant(s). AFFIDAVIT PURSUANT TO RULE 3129 (Affidavit No. l) GMAC MORTGAGE CORPORATION OF PA ,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 ,17 A WEST GLENWOOD DRIVE, CAMP HILL, PA 17011 . 1. Name and address of Owner(s) or reputed Owner(s): NAME LAST KNOWN ADDRESS (If address cannot be reasonably ascertained, please so indicate.) RICHARD L. THUMMA 5252 OAKLAND STREET PHILADELPHIA, PA 19142 KIMBERLY A. CLARK 17 A WEST GLENWOOD DRIVE CAMP HILL, PA 17011 2. Name and address of Defendant(s) in the judgment: NAME LAST KNOWN ADDRESS (If address cannot be reasonably ascertained, please so indicate.) Same as above 3. Name and 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 so indicate.) None 4. Name and address of the last recorded holder of every mortgage of record: NAME LAST KNOWN ADDRESS (If address cannot be reasonably ascertained, please so indicate.) None 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 so 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 so indicate.) None Name and address of every other person 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 so indicate.) Tenant/Occupant 17 A WEST GLENWOOD DRIVE CAMP HILL, PA 17011 Domestic Relations of 13 North Hanover Street Cumberland County Carlisle, PA 17013 Commonwealth of p0 Box 2675 Pennsylvania Department of Welfare 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 1 October 2, 2001 DATE ,. ~J 4`y [~ ~: -_ -n ~~ J,., p - ~Z~f~~ l~ _ __ j C. m~ -i <' _ (~- C..' . _ L, G ~ .s. C % . C i4 n J .L .. ;~ -! r,3 ,~, -~ ~/ i ra~sFCs~u~mm.. ~~ .~.ra[ ~ ~,:r~i _-~v= °+~ . {n.~e=na ,'~~ns~s^~rJrt~ _ _..~ FEDERMAN and PHELAN By: FRANK FEDERMAN Identification No. 12248 ONE PENN CENTER AT SUBURBAN STATION 1617 JOIIN F. KENNEDY BLVD., SUITE 1400 PHILADELPHIA, PA 19103-1814 (215) 563-7000 GMAC MORTGAGE CORPORATION OF PA Plaintiff, v. RICHARD L. THUMMA KIMBERLY A. CLARK Defendant(s). ATTORNEY FOR PLAINTIFF CUMBERLAND COUNTY COURT OF COMMON PLEAS CIVIL DIVISION NO. 01-4842 CERTIFICATION FRANK FEDERMAN, ESQUIRE, hereby verifies that he is attorney for the Plaintiff in the above-captioned matter, and that the premises are not subject to the provisions of Act 91 because it is: Q an FHA mortgage O non-owner occupied () vacant (X) Act 91 procedures have been fulfilled This certification is made subject to the penalties of 18 Pa. C.S. Section 4904 relating to unsworn falsification to authorities. C> c~ ,,-> ~- '- _;, ~ ~ ~~~ ~ n?r- _s - .~° ~ ~ .~ - q>': C: ' r" C: c-: %r ~_ "`-: 9 _ - `- f V } j -~: ~ ::'t7 » ~~/ ii ea~rta~ ~erse»mwww:akt~~. _ R~3~Rel~a w --,~_~-+m^r , . ^°ne am.,•:rw m e. g!N,-~. + _ n~m^y« »rars~uttr~' _ GMAC MORTGAGE CORPORATION OF PA Plaintiff, v. RICHARD L. THUMMA KIMBERLY A. CLARK Defendant(s). CUMBERLAND COUNTY No. 01-4842 October 2, 2001 TO: KIMBERLY A. CLARK 17 A WEST GLENWOOD DRIVE CAMP HILL, PA 17011 RICHARD L. THUMMA 5252 OAKLAND STREET PHILADELPHIA, PA 19142 **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 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 LIEN AGAINST PROPERTY.** Your house (real estate) at ,17 A WEST GLENWOOD DRIVE, CAMP HILL, PA 17011, 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 $65,082.07obtained by GMAC MORTGAGE CORPORATION OF PA (the mortgagee) against you. If the Sheriff's sale is postponed, the property will be relisted for the JiJIVE 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 chazges, 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. You may also be able to stop the sale through other legal proceedings. You may need an attorney 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 attorney.) YOU MAY STILL BE ABLE TO SAVE YOUR PROPERTY AND YOU HAVE OTHER RIGHTS EVEN IF THE SHERIFF'S SALE DOES TAKE PLACE. 1. If the Sheriffs Sale is not stopped, your property will be sold to the highest bidder. You may find out the price bid by calling (215) 563-7000. 2. You maybe able to petition the Court to set aside the sale if the bid price was grossly inadequate compared 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. i 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 may be 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) are filed with the Sheriff within 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 HAVE 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 1~( THa': CERTa_PI true or pared of land and prcmist;, sicJatt, :yir.3 snd kiting :n :he Township of East Pennsboro in~heCaunryof Cumberland ^nd Commortweafth of Ptnnr/fvania, mart pcriular;y ~es_rtbed at jo(7aw:. In Accordance with survey of Gerrit J. Betz Assecia*_es, I,^.c., Engineers and Surveyors, dated August 29, L977, as fcilows, to w1t: BEGINNING at a point on the westerly line of Glenwood Drive (West), which point is 332.56 feet North of the norhwest-eriy corner of Erford Road (West) and Glenwood Drive ('Rest) and at dividing lire between Lot Numbers 3 and 4:{, Block "H" on the hereinafter mentioned Pian of Lots; thence along said dividingl!line, North 63 den_ees 30 minutes West and through the center of a partition wall and beyond :.5.0 feet to a paint; thence along dividing line between Lot ifcs. 22:{ and 23, and 4:{, Block "H", :forth 26 degrees 30 minutas East 37.5 faa~ to a paint at dividing line between Lot Nos. 4Y and 5, 21ock "H" on said Piar.; thence along said dividing line, South 63 degrees 30 minutas East 115 feet to a point on the westerly line of Glenwood Drive (West; aforesaid; thence along same, South 25 degrees 30 minutas ;Jest 3', .5 feet to a paint, the place of BEGINPlI:7G. BEING Lot Number 4:{, Hlcck "H", on Plan No. 10, Ridie:r Par<, which Plan is recorded in the Office of the Recorder of Deeds in and for Cumberland County, Pennsylvania, in Plan Boak l8, Page d?. HATING THEREON erected a dwelling house known and numbered as 17 A Glenwood Drive (West). UNDER AND SUBJECT, nevertheless, to easements, restrictions, reservations, conditions and rights-of-way of record. c. 2 ~c. t ~r, `> :- G{ ;; G <_ ~= -'G_ .~ 0 --i ~~~ ti~ ~.J ~: ~~ ~, , - ~i ~- -~ _. mix,- ~-. e,_~ .: vrnr ~. rxe+.ag~w .. niiM- '~"~*nuRNNi3a. _ J4, (Rule of Civil Procedure No. 236) -Revised IN TAE COURT OF COMMON PLEAS OF CUMBERLAND COUNTY, PENNSYLVANIA CIVIL ACTION -LAW GMAC MORTGAGE CORPORATION OF PA 401 MILE OF CARS WAY CUMBERLAND COUNTY COURT OF COMMON PLEAS Plaintiff, v. RICHARD L. THUMMA HIMBERLY A. CLARK Defendant(s). CIVIL DIVISION NO. 01-4842 Notice is given that a Judgment in the above-captioned matter has been entered against you on OC~ ° ~!0 2001 . By: /S/ Gu+iGr ~ o ~- ~o`~ ~/ If you have any questions concerning this matter, please contact: ~ A ttorney for P ntiff NE PENN C ER AT SUBURBAN STATION 1617 JOHN F KENNEDY BLVD., 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 THIS DEBT WAS NOT REAFFIRMED, THIS CORRESPONDENCENDENCE IS NOT AND SHOULD NOT BE CONSTRUED TO BE AN ATTEMPT TO COLLECT A DEBT, BUT ONLY ENFORCEMENT OF A LIEN AGAINST PROPERTY.** } AFFIDAVIT OF SERVICE -PHILADELPHIA PLAINTIFF GMAC MORTGAGE CORPORATION OF PA NO. 01-4842 DEFENDANT RICHARD L. THUMMA KIMBERLY A. CLARK TYPE OF ACTION XX Mortgage Foreclosure XX Civil Action SERVE AT 5252 OAKLAND STREET PHILADELPHIA, PA '19142 SERVED Served and made kno to ~~ C~1GYQ ~. IllulllrTlG Defendant on the dad of 200 at _ o'clock, ~. M. , at `J'~`J'~. GkIQ ~1'l2~'~' City in the manner described below: Defendant personally served. Adult family member with whom Defendant(s) reside(s). Relationship is ~_Adult in charge of Defendant's residence who refused to give name/relationship. Manager/Clerk of place of lodging in which Defendant(s) reside(s) Agent or person in charge of Defendant's office or usual place of business. Other: and officer of said defendant company. I,A~}~~ C;~H a competent adult, being duly swo~jn according to law, depose and state that I personally handed to '~1(fp~ I Ce~USc'~ -}~ BjVe ~rrMe) _ a true and correct copy of the `¢l~p~C,k;~~ ~xQ~~iV~l'e issued in the captioned case on the date~~ the address indicated above. Sworn to and subscribed Before me this ~J O day ' Of ~J~ 200 f Notary~~~._~ ~ By: _~.- c~ NOT SERVED On the ~ ~day~of~ 200_ at o'clock _ .M., Defendant NOT FOUND because: Moved Unknown No Answer Vacant Other: 1(-1 ~.~ , k'~, ~ln rhCL~aY. ~.h~ Ati- g-~.~-ol- r~h~y gas a Sworn to and subscribed / Before me the day Of 200_ Notary: By: ATTORNEY OF PLAINTIFF FRANK FEDERMAN, ESQUIRE - I.D.#12248 One Penn Center at Suburban Station Suite 1400 ~f Philadelphia, PA 19103 \x ~(, )~ (215) 563-7000 (~,\M~ VVU L '\ ~fjlR SHERIFF'S RETURN - REGULAR -r- CASE NO: 2001-04842 P COMMONWEALTH OF PENNSYLVANIA: COUNTY OF CUMBERLAND GMAC MORTGAGE CORP OF PA VS THUMMA RICHARD L ET AL DAVID MCKINNEY Sheriff or Deputy Sheriff of Cumberland County,Pennsylvania, who being duly sworn according to law, says, the within COMPLAINT - MORT FORE was served upon CLARK KIMBERLY A DEFENDANT the at 2058:00 HOURS, on the 27th day of August , 2001 at 17 A WEST GLENWOOD DR CAMP HILL, PA 17011_. by handing to KIMBERLY A CLARK 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: ~~ 1 .~ R. Thomas Kline 08/28/2001 FEDERMAN & PHELAN Deputy Sherif Prothonotary FEDERMAN AND PHELAN By: FRANK FEDERMAN, ESQUIRE IDENTIFICATION NO. 12248 ONE PENN CENTER AT SUBURBAN STATION, SUITE 1400 PHILADELPHIA, PA 19103-1814 (2151 563-7000 GMAC MORTGAGE CORPORATION OF PA vs. RICHARD L. THUMMA KIMBERLY A. CLARK ATTORNEY FOR PLAINTIFF COURT OF COMMON PLEAS CIVILDIVISION CUMBERLAND COUNTY No.: 01-4842 ORDER AND NOW, this ~ day o , 2001, upon consideration of Plaintiff s Motion and the Affidavit of Good Faith Investigation attached thereto, it is hereby ORDERED that Plaintiff may obtain service of the Notice of Sale on the above captioned Defendant(s), RICHARD L. THUMMA and KIMBERLY A. CLARK, by mailing a true and correct copy of the Notice of Sale by certified mail and regular mail to Defendant's last lrnown address and the mortgaged premises. Service of the aforementioned mailings is effective upon the date of mailing and is to be done by Plaintiffs attorney, who will file with the Prothonotary's Office an Affidavit of service. ~ ~~i~;v~r~~.x,r~~~,~~° 1,i.~~1 ~:i ...._ ., ~ _ _... !s7' •~ ~ .. '4..,::. k."SUa,Fes KSA 3~99?bl.:tS,V e+n '; <.. .... AfI~.X::l:. 1f. vskTWJNKiFkYA3. FEDERMAN AND PHELAN By: FRANK FEDERMAN, ESQUIItE IDENTIFICATION NO. 12248 ONE PENN CENTER AT SUBURBAN STATION, SUITE 1400 PHILADELPHIA, PA 19103-1814 (2151 563-7000 GMAC MORTGAGE CORPORATION OF PA vs. RICHARD L. THUMMA KIMBERLY A. CLARK ATTORNEY FOR PLAINTIFF COURT OF COMMON PLEAS CIVIL DIVISION CUMBERLAND COUNTY No.: 01-4842 MOTION FOR SERVICE PURSUANT TO SPECIAL ORDER OF COURT Plaintiff, by its counsel, Frank Federman, Esquire, moves this Honorable Court for an Order directing service of the Notice of Sale upon the above captioned Defendant(s) by certified mail and regular mail to Defendant's last known address. 1. Attempts to serve Defendant with Notice of Sale have been unsuccessful, as indicated by the Affidavit of Service attached hereto as Exhibit "A." 2. Pursuant to Pennsylvania Rule of Civil Procedure 430, Plaintiff has made a good faith effort to locate the Defendant. An Affidavit of Good Faith Investigation setting forth the specific inquiries made and the results therefrom is attached hereto as Exhibit "B." WHEREFORE, Plaintiff respectfully requests this Honorable Court enter an Order pursuant to Pennsylvania Rule of Civil Procedure 430 directing service of the Notice of Sale by certified mail and regular mail to Defendant's last known address. F FEDERMAN, ESQUIRE ATTORNEY FOR PLAINTIFF r~~r 1'LA-NTIFF DEFENDANT(S) 99 ~~ AFFIDAVIT OF SERVICE . CUMBERLAND COUNTY Cb1AC bIORTGAGE CORPORATION OF PA No. 01.4842 ' RICHARD L. THUMMA KIMBERLY A. CLARK Type of Action - Notice of Sheriff's Sale SERVE RICHARD L. THUMMA AT 5252 OAKLAND STREET PHILADELPHIA, PA 19142 Served and made known to a[ ,o'clock _ m., at of Pennsylvania, in the manner described below: Defcndantpersonallyserved. ^°`"°°` Adult family member with whom Defendant(s) reside(~parih~p°lis Adult in charge of Defendant(s)'s residence who reftiseiTto give name or relafionship. Manager/Clerk oY place of lodging in which Defendant(sj`feside(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 _ Height _ Weight _ Race Sex _ Other J r- ~r Sale Date: MARCH 6, 2002 SERVED Defendant, on the day of , 200_, Commonwealth 1, , 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 dale and at the address indicated above. Sworn to and subscribed before me this day of , 200_. Nutan : By: NOT SERVED On the 10th day of Oct obp r , 200 1, at 5:50 o'clock Vim., Defendant NOT FOUND because: % Moved Unknown No Answer Vacant Other: Neighbor at 5254 stated that Richard moved out yesterday via U-Haul. Sworn to and subscribed befom me this LOhh day of Oct . 200 -J, NOTARI,9~ SEA ` Notary: L(~ OMIC~yNotar~~ J. Cre n, Jr. ~~ i o iladelphia, Phila. County At[ornev fo% r Plaintiff M Commission Ex fires Oct. 29, 2001 Frank Federman. Esquire - LD. No. 12248 O[te Penn Center at Suburban Station 1617 Joltn F. Kennedy Boulevard, Suite 1400 Philadelphia, PA 19103-1814 (215) 563-7000 From Bud Carty To' Mary Scrocca Date: Time: 9:04:20 PM Page ~ of ? FLA1N fIEF GMAC OF SERVICE ~f ~(a CU•MBERL•AND COUNTY <J TION OF PA No. 01-0842 DEFENDANT(S) RICHARD L. T'. KIMBERLY A. SERVE: RICHARD L. THUMMA AT 17 A WEST GLENWOOD DRIVE CAMP HILL, PA 17011 Served and made known to _ at _, o'clock _ m., at of Pennsylvania, in the manner described below: Type of Action - Notice of Sheriff s Sale Sale Date: MARCH 6, 2002 SERVED Defendant, on the day of , 200_, Commonwealth ,__ Defendant personally served. Adult family member with whom Defendant(s) reside(s). Relationship is Adult in chazge 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 _ Height ^ Weight _ Race _ Sex _ Other I, _ , a competent adult, being duly sworn according to law, depose and state that I personally handed a true and correct copy of the Notlce of Sheriff's Sale in the manner asset forth herein, issued in the captioned case on dte date and at the address indicated above. Sworn to and subscribed before me this _ day ~° _ of , 200_. ~~~ ^` ~'" .. a ,_ Notary: By: NOT SERVED On the -/ Jam" day of L' Cfic+bt"it- ; 2001, at ~yo'clock ~m., Defendant NOT FOUND because: ,~ Moved Unlmown No Answer Vacanlt 1 ` Other: ~-G'Ce R`~~~.1 ~ ~~'~:SNF-% ~ ~'•~s i C~e W `t' ,~ t~t+~ l~Y T1C`'l'•~ ~'r ~l9-YC I~ ~ ~' 1 1~ 1 ,, r1V w~ w.'3, ~'J ~ IU ` ,~- t l V e c~ ~ ~e-+C e V'~ ~ ~ ~ R _ Sworn to and subscribed before me this _ day Of' , 200 ~. Notary: gy; Attorney for Plaintiff Frank Federman, Esquire - I.D. No. 12248 One Penn Center at Suburban Station 1617 John F. Kennedy Boulevard, Suite 1400 Philadelphia, PA 19103-18]4 (215) 563-7000 ll~a`~ ." ASM PANJ, INC. AFFIDAVIT OF GOOD FAITH INVESTIGATION File Number: 01-1912 Attorney Firm: Federman & Phelan Subject: Richard L. Thumma Current Address: 17 A. West Glenwood Dr. Camp Hill, PA 17011 Property Address: 17 A. West Glenwood Dr. Camp Hill, PA 17011 Mailing Address: 17 A. West Glenwood Dr. Camp Hill, PA 17011 I Steven M. Ruffo, being duly sworn according to law, do hereby depose and state as follows, I have conducted an investigation into the whereabouts of the above-noted individual(s) and have discovered the following: I. CREDIT INFORMATION ~ " ' , A. SOCIAL SECURITY NUMBER Richard L. Thumma - 199-56-5651 cn^Y'n` B. EMPLOYMENT SEARCH ,1i" Richard L. Thumma -unknown `'.. C. INQUIRY OF CREDITORS - The creditors indicate that Richard L. Thumma reside(s) at: 17 A. West Glenwood Dr. Camp Hill, PA 17011 II. INQUIRY OF TELEPHONE COMPANY A. DIItECTORY ASSISTANCE SEARCH indicated that Richard L. Thumma reside(s) at: 17 A. West Glenwood Dr. Camp Hill, PA 17011 - 717-732-6139 III. INQUIRY OF NEIGHBORS Jerome Jones 13 A. W. Glenwood Dr and he verified that Richard L. Thumma reside(s) at: 17 A. West Glenwood Dr. Camp Hill, PA 17011 IV. INQUIRY OF POST OFFICE A. NATIONAL ADDRESS UPDATE Richard L. Thumma -17 A. West Glenwood Dr. Camp Hill, PA 17011 V. MOTOR VEHICLE REGISTRATION A. MOTOR VEHICLE & DMV OFFICE Per the Pennsylvania Department of Motor Vehicle Richard L. Thumma reside(s) at: 17 A. West Glenwood Dr. Camp Hill, PA 17011 VI, OTHER INQUIRIES A. DEATH RECORDS As of Oct. 1, 2001 Vital Records has no death record on file for Richard L. Thumma. B. PUBLIC LICENSES (PILOT, REAL ESTATE, ETC.) none .,~ C. COUNTY VOTER REGISTRATION The Cumberland Cnty Voter reg has a registration for Richard L. Thumma residing at: 17 A. West Glenwood Dr. Camp Hill, PA 17011 VII. ADDITIONAL INFORMATION OF SUBJECT A. DATE OF BIItTH Richard L. Thumma -YOB -1966 B. A.K.A. none The undersigned understands that this statement herein is made subject to the penalties of 18 Pa. C.S. Sec. 4904 relating to unswom falsification to authorities. I hereby verify that the statements made herein are tme and correct to the best of my knowledge, information and belief and that this affidavit of investigation is made subject to the penalties of 18 Pa. C.S. Sec. 4904 relating to unsworn falsification to authorities. .Steve~z 'nL. ,~u~a AFFIANT Steven M. Ruffo ~~ ,. PANJ, INC. President ~ ~, c, _,i~ f\y +~ ,..~" a ` jvU ~"° Sworn to and subscribed before me this _15_day of_Nov 2001 NOTARIAL SEAL Luz M. Arango, No[ary Public Philadelphia, Philadelphia County My Commission Expires Oct. 30, 2004 PANJ, INC 43 WILSONDRIVE SICKLERVILLE, NJ 08081 PHONE: (856) 264-7806 PANJINC@AOL. COM ::~> FEDERMAN AND PHELAN By: FRANK FEDERMAN, ESQUIRE IDENTIFICATION NO. 12248 ONE PENN CENTER AT SUBURBAN STATION, SUITE 1400 PHILADELPHIA, PA 19103-1814 (215L63-7000 GMAC MORTGAGE CORPORATION OF PA vs. RICHARD L. THUMMA KIMBERLY A. CLARK ATTORNEY FOR PLAINTIFF COURT OF COMMON PLEAS CIVIL DIVISION CUMBERLAND COUNTY No.: 01-4842 MEMORANDUM OF LAW Pennsylvania Rule of Civil Procedure 430(a) specifically provides: (a) If service cannot be made under the applicable rule, the plaintiff may move the Court For a special order directing the method of service. The Motion shall be accompanied by an Affidavit stating the nature and extent of the investigation which has been made to deternrine the whereabouts of the Defendant and the reasons why service cannot be made. Note: A Sheriff s return of "Not Found" or the fact that a Defendant has moved without leaving a new forwarding address is insufficient evidence of concealment. Gonzales vs. Polis, 238 Pa. Super. 362, 357 A.2d 580 (1976). "Notice of intended adoption mailed to last known address requires a good faith effort to discover the correct address." Adontion of Walker, 468 Pa. 165, 360 A.2d 603 (1976). An illustration of good faith effort to locate the defendant includes (1) inquires of postal authorities including inquiries pursuant to the Freedom of Information Act, 39 C.F.R. Part 265, (2) inquiries of relatives neighbors, friends and employers of the Defendant and (3) examinations of local telephone directories, voter registration records, local tax records, and motor vehicle records. As indicated by the attached Affidavit of Service, marked hereto as Exhibit "A", the Sheriff has been unable to serve the Notice of Sale. A good faith effort to discover the whereabouts of the Defendant has been made as evidenced by the attached Affidavit of Good Faith Investigation, marked Exhibit "B." WHEREFORE, Plaintiffrespectfully requests service of the Notice of Sale by certified mail and regular mail to Defendant's last known address. Respectfully submitted: S FRANK FEDE , ESQL1IltE ATTORNEY FOR PLAINTIFF VERIFICATION FRANK FEDERMAN, ESQUIRE, hereby states that he is the Attorney for the Plaintiff in this action, that he is authorized to take this Affidavit, and that the statements made in the foregoing MOTION FOR SERVICE OF TIIE NOTICE OF SALE PURSUANT TO SPECIAL ORDER OF COURT are true and correct to the best of his knowledge, information and belief. The undersigned understands that this statement herein is made subject to the penalties of 18 Pa. C.S. Sec. 4904 relating to unswom falsification to authorities. F FEDE ,ESQUIRE ATTORNEY FOR PLAINTIFF FEDERMAN AND PHELAN By: FRANK FEDERMAN, ESQiIIItE IDENTIFICATION NO. 12248 ONE PENN CENTER AT SUBURBAN STATION, SUITE 1400 PHILADELPHIA, PA 19103-1814 (215) 563-7000 ATTORNEY FOR PLAINTIFF COURT OF COMMON PLEAS CIVIL DIVISION GMAC MORTGAGE CORPORATION OF CUMBERLAND COUNTY PA No.: 01-4842 vs. RICHARD L. THUMMA KIMBERLY A. CLARK CERTIFICATION OF SERVICE I, FRANK FEDERMAN, ESQUIRE, hereby certify that a copy of the Motion for Service Pursuant to Special Order of Court has been sent to the individuals indicated below on December 5, 2001. RICHARD L. THUMMA KIMBERLY A. CLARK 17 A WEST GLENWOOD DRIVE CAMP HILL, PA 17011 F FED ,ESQUIRE Attorney for Plaintiff Date: December 5, 2001 l Y' - I+ i _ ~ _ c ~ = T~ •. ' © }D ~ c ~ - r t _ :. i -~' ® c. -<< ~x ~'"''e~3i:d~.~'`~s.. ^x e.~,.'.,~ `~'3.,.~,.'<r'#'s% .,_~~ _ _;a "`~S.,z~,~3x ~ rs~'xE.~:e~~'= ~~ ? z ~~ ? ¢ W G ^ ~ W L` r f¢ •F ~~" ._ ~' a2~¢LL ~ c\\\' ~F=JW ..._. ,. WyC1WJ w: %FyOZ +~..T. f, ?~oZG~ ~~0~ ~ Q U VJ N ~~ rry ~ •r'+ ~w~ ~3~ .,..~ c, y ~ ] ~ w ''?~ ~,.. ;~ ~-~~ ~ Q ~ tYY ~~. .a ~ w I =- '. Zs Q i a c.~ x ~ ~^, a. ~~ ~,l :~ ~ i v ~o s+ o mx u u o s~ 0 0 ~ ,.G v v m u ro .i o p, s, o ' ~,u~~ R+ p m .~ v o N i ~ U D W I W ~ ~ o ro ro v - ~ x ,~ ~ s~ ~ ~a~~ w ~ o m OU V] U (Rule of Civil Procedure No. 236) -Revised IN THE COURT OF COMMON PLEAS OF CUMBERLAND COUNTY, PENNSYLVANIA CIVII, ACTION -LAW GMAC MORTGAGE CORPORATION OF PA 401 MILE OF CARS WAY CUMBERLAND COUNTY` COURT OF COMMON PLEAS Plaintiff, v. CIVIL DIVISION NO. 01-4842 RICHARD L. THUMMA KIMBERLY A. CLARK ~ ~~ c_- `-=' -:, ~~ •-~ ' -c~ ~r~ -~ - . _~. Defendant(s). ~ ~. _ _ ~r _ - `1-'~ i -• a:~j ~ ~ .. __3 Notice is given that a Judgment in the above-captioned matter has been entered aga~st ybCi ~~ one JG><- a7lo 2001 . By: /S/ ucitis ~y~d`/Ll. ~- , .~~: If you have any questions concerning this matter, please contact: A x ttorney for P ntiff NE PENN C TER AT SUBURBAN STATION 1617 JOHN F/KENNEDY BLVD., SUITE 1400 PHII.ADELPHIA, 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 THIS DEBT WAS NOT REAFFIRMED, THIS CORRESPONDENCENDENCE IS NOT AND SHOULD NOT BE CONSTRUED TO BEAN ATTEMPT TO COLLECT A DEBT, BUT ONLY ENFORCEMENT OF A LIEN AGAINST PROPERTY.** ~ ~, -,~ ~ ~,,~~,,,-.,R,~~. ~,P~ ~~~ AFFIDAVIT OF SERVICE PLAINTIFF GMAC MORTGAGE CORPORATION OF PA DEFENAANT(S) RICHARD L. THUMMA KIMBERLY A. CLARK SERVE KIMBERLY A. CLARK AT No. 01-4842 CUMBERLAND COUNTY Type of Action -Notice otSheriff s Sale 17 A WEST GLENWOOD DRIVE Sale Date: MARCH 6, 2002 CAMP HILL, PA 17011 SERVED Served and made known to Kt M1, ~~~`~ C~R~ .Defendant, on the G ~ day of ~ 200 ~ , at , l0 , o'clocke.m., at of Pennsylvania, in the manner described below: 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: Commonwealth D tion: Age _ Height _ Weight _ Race _ Sex _ Other I, ~~f~~ - S-L-t? , 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 ~l~ve. C' r.~."rn'weat4~c~ 1M~I t~n.r'~ tlu Yr tat0 ~ ~ Sworn to and sub~s~cnb~ed JUANITA Kam. SAMFCKB ~ ry Public before me this to day Suaqueharura Twp., Dauphin County of 172 G 200 ~., / My Cammiaelat Expires Nov. 15, 2003 l,(~7 ~ , _ ,t ~ ~~y Notary ~~~cY1~il~ By: .__ / ~ ~'~"~v ~' l1 NOT SERVED Un the day of , 200_, at Moved Unlmown No Answer Other: Swom to and subscribed before me this day of .200 _. Notary: By: Attorney for Plaintiff Frank Federman, Esquire - I.D. No. 12248 One Penn Center at Suburban Station 1617 John F. Kennedy Boulevard, Suite 1400 Phi-adelphia, PA 19103-1814 (215)563-7000 o'clock _ m., Defendant NOT FOiJND because: Vacant Z B~ r z.. .. t~wfiPJ~ _ ._ ~'~S~rro :ice+° '~~^} ~ -a -vim ~.~'i~mgm29~b{. ._ !3 FEDERMAN AND PHELAN By: FRANK FEDERMAN, ESQUIRE IDENTIFICATION NO. 12248 ONE PENN CENTER AT SUBURBAN STATION, SUITE 1400 PHILADELPHIA, PA 19103-1814 (215 Sfi~-7000 GMAC MORTGAGE CORPORATION OF PA vs. RICHARD L. THUMMA KIMBERLY A. CLARK ATTORNEY FOR PLAINTIFF COURT OF COMMON PLEAS CIVIL DIVISION CUMBERLAND COUNTY No.: 01-4842 I hereby certify that a true and correct copy of the Notice of Sheriff Sale in the above captioned matter was sent by regular mail and certified mail, return receipt requested, to RICHARD L. THUMMA on 12/18/01 at 17 A WEST GLENWOOD DRIVE, CAMP HILL, PA 17011 and at 5252 OAKLAND STREET PHILADELPHIA PA. 19142, in accordance with the Order of Court dated 12/13/01. The undersigned understands that this statement is made subject to the penalties of 18 PA C.S. s 4904 relating to unsworn fafalsification~to authorities. L nnA.c -TPvenr~vrn,/~ FRANK FEDERMAN, ESQUIRE Date: T)e~Pmher 24,E ~~I~ ~ ~ ~On>, ~ , FEDER.'~IAN :4ND PHELAN .~ By: FRANK FEDERNIAN, ESQUIRE IDENTIFICATION NO. IZ248 ONE PENN CENTER AT SUBURBAN STATION, SLtITE 1400 PHIL.4DELPHL4, PA 19103-1814 j21~1 563-7000 GNL4C ibIORTGAGE CORPORATION OF PA ~s. RICHARD L. THUMiv1A KLVIBERLY A. CLARK ATTOILNEY FOR PLAINTIFF COL12T OF COMtiION PLEAS CNIL DIVISION CLi4IBERLAN~ COL1,T~' No.:al-4s4~ ORDER AND NOW, this ~ day of 1 ~~2001, upon consideration of Plaintiffs Motion and the Affidavit of Good Faith Investigation attached thereto, it is hereby ORDERED that Plaintiff may obtain service of the Notice of Sale on the above captioned Defendant(s), RICHARD L. THUMMA and KIMBERLY A. CLARK, by mailing a true and correct copy of the Notice of Sale by certified mail and regular mail to Defendant's last known address and the mortgaged premises. Service of the aforementioned mailings is effective upon the date of mailing and is to be done by Plaintiffs attorney, who will rile kith the crothonotary s Office an AfSdavi*. ~f seR.ic°. BY THE COURT: ~?'~~ ~^~~Y F2~tY! RED'';' ~n T;="c~_•: :,rof, I here unto set m~ nsrd and h szal of sa d Co at Carlisle, Pa. Th' ......1,~....~~~~~ _ ~ s js J. - -: o-6 •xk_ - C hF3 .'.~ --.y.y.H~ .rte -~- qy t" _ Dam ~-- - >~~~_ ~' ~~ U .A W.~`iJ r!'+ C b Ao mot. Ae to A W N _p ry'~~@ ~p - _ _ _ x - - Gy 7!a ~ ~ O ~~~_., a,';r~~~ -~ ~ {^~~ Q ~ti a~e~ x ~ =°, o `° ~ j _ . -. a ~a ° x .. ~-_ ., .~ ~' ~; ~ o~ ~.b. ~. ~. d ~ ~ ~ ~~~ .- ~ ~ ro ~ ~ 0 0 .:} N ~ ~~ 4' -M~ ~f 'H`M may, Y ~- - ~~ ~ ~'~j~j cys~ ~ - ' y. ~~°-`g"y.- 4 ~ • ~ ~ `era ~~ W C 'Q O Q ddddddo...... ~-D'~~J ~'~~a s $~~ b ~tl~~ ^~^y . : ~ ' _ 8 a'~ ~ y ~ a ~_~~ ~'-- Y \ .. ,~ {) ~. fi _, 7160 3901 9844 6532 2086 „~ TO: RICfLARD'I'FIUNIIvIA ~ _ 17 A WEST GLENWOOD DRIVE CAMP HILL, PA: 17011 ~ t SENDER ~ J REFERENCE: ~b~ ____ PS FOntl 3800 June 2000 ---~ RETURN ~- Posta9e - - - .. - . -~ _ - Z, RECEIPT Cedifred Fee 1 AI SERViCc ce.~~.., oe..e~.,. cee ~ r. -7160 3901x9844 6532 2U93 ~TO: RICHARD THUNIMA 5252 OAKLAND STREET PHILADELPHIA, ~A. 19142 SENDER: A ~ ` ' ) REFERENCE: SC~.lei~ PS Form 3800. June 2000 - ' RETURN ' Postage. -. - RECEIPT Cettifled Fee - ~ 1 90 SERVICE - --~ Retum Receipt Fee - I 7 SO j Restricted Deliver 0,00_ n~~~ue~~~ve~ { Total Postage & Fees Total Postage 8: Fees ,,p$d l ~ `YT US Postal Service - KO i .~ US Postal Service q ~ o Receipt for ~ 18 ~ ~ f Receipt for z 18 = Certified Mail ~1p~1 sa ~ Certified Mail: dz~s` daS No insurance Coverega Provided ~ ; _ ~B~ ~d ~ - Na Insurance CoveBge Pmvtdad ~ . Do Na~Use fir Intematfonal Mal ,_ - Do Not Use for IrRemational MaA - - - y Y '~~G • _ ,y s~,yi2.1y .~. `+~¢~ 9 w~, ' ~ ., < @` _ - 4 ~ 9 ~'~, ~ i .. . r~ mss., ~y~l@-~ . S ~ -~~ ~ fZr.L. un~{. Y. c ==} ~ ;; '- n -~ ~ -.' I ~ ~ ~~ .; `Gl ""] l i ~~ V'~9 ~ j~r~ __ 4P ~ ,?FVfl2T .,-~F^aza .°~,~'?aFa?+s'N-~`AYaB~Tf!s'rf'-x ~: -+Er-wPy~s~an3-. SALE DATE: MARCH 6, 2002 IN THE COURT OF COMMON PLEAS OF CUMBERLAND COUNTY, PENNSYLVANIA CIVIL ACTION -LAW GMAC MORTGAGE CORPORATION OF PA No.: 01-4842 vs. RICHARD L. THUMMA KIMBERLY A. CLARK 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: 17 A WEST GLENWOOD DRIVE. CAMP HILL. PA 17011. 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, ESQ Attorney for Plaintiff February 27, 2002 CUMBERLAND COUNTY GMAC MORTGAGE CORPORATION OF PA No.: 01-4842 vs. RICHARD L. THUMMA KIMBERLY A. CLARK SUPPLEMENTAL AFFIDAVIT PURSUANT TO RULE 3129 (Affidavit No. 2) 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 17 A WEST GLENWOOD DRIVE, CAMP HILL, PA 17011: 3. Name and last known 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) WANDELL NIANIVE 365 PETERSBURG RD. CARLISLE, PA 17013 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 None. Last Known Address (if address cannot be reasonably ascertained, please indicate) 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 None. Last Known Address (if address cannot be reasonably ascertained, please indicate) 7. Name and address of every other person of whom the plaintiff has knowledge who has any interest in the property which may be affected by the sale: Name None. Last Known Address (if address cannot be reasonably ascertained, please indicate) 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. FRANK FEDERMAN, E DIRE Attorney for Plaintiff February 27, 2002 ~~.~ GMAG MORTGAGE CORPORATION OF PA v. Plaintiff, RICHARD L. THUMMA KIMBERLY A. CLARK Defendant(s). COURT OF COMMON PLEAS CIVIL DIVISION NO.Ol-4842 AFFIDAVIT PURSUANT TO RULE 3129 (Affidavit No. 1) GMAC MORTGAGE CORPORATION OF PA ,Plaintiff in the above action, by its attorney, FRANK FEDERMAN, ESQUIRE, sets fortes as of the date the Praecipe for the Writ of Execution was filed the following information concerning the real property located at ,17 A WEST GLENWOOD DRIVE, CAMP HILL, PA 17011 . Name and address of Owner(s) or reputed Owner(s): NAME LAST KNOWN ADDRESS (If address cannot be reasonably ascertained, please so indicate.) RICHARD L. THUMMA 5252 OAKLAND STREET PHILADELPHIA, PA 19142 HIMBERLY A. CLARK 17 A WEST GLENWOOD DRIVE CAMP HILL, PA 17011 2. Name and address of Defendant(s) in the judgment: NAME LAST KNOWN ADDRESS (If address cannot be reasonably ascertained, please so indicate.) Same as above 3. Name and 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 so indicate.) CUMBERLAND COUNTY None 4. .Name and address of the last recorded holder of every mortgage of record: NAME LAST KNOWN ADDRESS (If address cannot be reasonably ascertained, please so indicate.) None 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 so 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 so indicate.) None Name and address of every other person 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 so indicate.) Tenant/Occupant 17 A WEST GLENWOOD DRIVE CAMP HILL, PA 17011 Domestic Relations of 13 North Hanover Street Cumberland County Carlisle, PA 17013 Commonwealth of PO Box 2675 Pennsylvania Department of Welfare 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 t October 2, 2001 DATE c to -0. W N O V ~ J ~' U A V N ~ A ~ m' a N D ~ o .. n ^ A _ ~ V' O Z ~ ~ 3 a m z ~ ~ ~ z a ~ ~ O . ~ z a ~ a C' fS O S ~N ~ lzf N c n ~n a ~ K d O m C7 e~~X~ 8 $ R 'A ~ - ~ Y "' $ e .. 'a o a v p 8 ~'ga w . ^= `- ° N - e __ ~^ B ~ A ~ _C C s C. 3.~O (i ceR~' ~~8ec O P ~ A 6 D ~ ' ~ °^°o~~n ~°6X a 3 : ^ 6a'~] m ~ d a y ~ O i ~ i~ ~$. ~ ^ ~ i p 9_ ~ ~ tl F.mZ ~ oo-~S; ~ ? ~ E ~ ~ ~ O ~ vl s a ~ 3 oat=. o n ,~_ s ~ ~ E ~,o s ~s.-~` =. 'j ~~ U.S. t POS~ ~ A6~ _ r=a m $~ ~~ ~ (~ 606 8360 n~ ~ ( ~ a~,~ a O 6 ~ y C 4 = N N ~. m 6 z c C4 ~ ti ~ O d ^1 ~ z a~ ~ z ~~~e array o ~ ~° r - v a AG ~z ~~ ~: o;, a -, °o ~; r . `0 to A W N O `O W J CT U A W N ~ 3 'm o ,A H D ~ Ci p ~ N ~ a 2 z ~ Q z c A6 ~-1 m (~ o ~ o z a ~ z y ° ~ o `\ '~ o ~. ~R O ~ ~ ;y ~ r w x ~ d O ~ o D ~o ~ ~ ~ ~ ~ r ~ ~ < v~ ~ r ~ ~, ~ d z ~ o O ~ ro n d ~ n =: d zzC m z ,_, AN~-= ~~~ ~ a ~ o . w z oo ~~ ~B7 ~ b ~ ~' o H a g= d~~ ~ r x . a'-'.3.= a ` ' r r" 'n ° ° ° ~~~ ~ ~ Y O _'-~' h ~ O ran oo ~~~= o ~ ~ u d ~ i P~ 6~ p k ' y ~ A n ~ o N T `NRM e u y u, H ~ y= ~ ~ ~ 6 ~ 9 T G y .~ ! y 4( d 3' 'T m J Se ' C' ao c % y ~ a l I - ~ ~-+ ~ ~ ~ _. ~ 9 i . . o° _. .E ?~3~ ~ 5a A ~ b a J E~~~ ~~. ;- o _ y t r J W ~ ~ o ~ 0. ~ O q p n ? VI 3 ~ / c 'i ~ q 3 ` _. ~t7 g i~ a w n % _ as ~ iL.~ ~'~j'('~9~ ~ ~ ~ ~ J ~i" y . .lp_:50 ;____ ~i n oaz -~av A a~ 'm m m °i O -e a -o~+ a~- ~ a~b~ rn Ri ~ w ?7 ~ z a~~~ ~~ o ~ ~ ~ ~ ~ d D A~ ~z ad A ~ s' a~~ ~ ~. o- 0 DATE: TO: ALL PARTIES IN INTEREST AND CLAIMANTS NOTICE OF SHERIFF'S SALE OF REAL PROPERTY OWNER(S) RICHARD L. THUMMA KIMBERLY A. CLARK PROPERTY: 17 A WEST GLENWOOD DRIVE CAMP HILL, PA 17011 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 a8er the filing of the schedule. LH ATp®EASE RETURN ~ SALE DATE: MARCH 6, 2002 IN THE COURT OF COMMON PLEAS OF CUMBERLAND COUNTY, PENNSYLVANIA CIVIL ACTION -LAW GMAC MORTGAGE CORPORATION OF PA No.: Ol -4842 vs. RICHARD L. THUMMA KIMBERLY A. CLARK 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: 17 A WEST GLENWOOD DRIVE. CAMP HILL. PA 17011. 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, ~_ a ATTl1RN~~~ FILE 7~~P Y PLEASE RETURN FRANK FEDERMAN, ESQ Attorney for Plaintiff February 27, 2002 a ~ ~„ -~ sC1 .. r7 _,. ~.'' y ~-. ~^ ' Z G : ~~ cx~ -{ "" ! :..-,-,-~ae~~ «rrvw~~.nme;rsimw~w+rm~rp~r~~+~[m, ' - I~ GMAC Mortgage Corporaiton of PA VS Richard L. Thumma and Kimberly A. Clark In The Court of Common Pleas of Cumberland County, Pennsylvania Writ No. 2001-4842 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 19.50 Levy 15.00 Advertising 15.00 Certified Mail .82 Poundage 17.45 Out of County 9.00 Philadelphia County 116.00 Law Journal 316.55 Patriot News 279.90 $ 889.92 paid by attorney 3-07-02 Sworn and subscribed to before me ~ sweii .r.~~ This /y ~ day of ~?'ha,,.~~ l R. Thomas Kline, Sheriff 2002, A.D. ~1,1,~~ ~ ~Yr.>/, ~ ~ BY ~~ Prothonotary Real Estate Deputy I.Bv ~ 3S~„~ ~,,, ta,z~3~ ~~~ ~` ,~~~ .~.~ GMAC MORTGAGE CORPORATION OF PA v. Plaintiff, RICHARD L. THUMMA KIiVII3ERLY A. CLARK Defendant(s). CUMBERLAND COUNTY COURT OF COMMON PLEAS CIVIL DIVISION NO.Ol-4842 AFFIDAVIT PURSUANT TO RULE 3129 (Affidavit No. 1) GMAC MORTGAGE CORPORATION OF PA , Plaintiff in the above action, by its attorney, FRANK FEDERMAN, ESQUII2E, sets forth~as of the date the Praecipe for the Writ of Execution was filed the following information concerning the real property located at ,17 A WEST GLENWOOD DRIVE, CAMP HILL, PA 17011 . Name and address of Owner(s) or reputed Owner(s): NAME LAST KNOWN ADDRESS (If address cannot be reasonably ascertained, please so indicate.) RICHARD L. THUMMA 5252 OAKLAND STREET PHILADELPHIA, PA 19142 KIMBERLY A. CLARK 17 A WEST GLENWOOD DRIVE CAMP HILL, PA 17011 2. Name and address of Defendant(s) in the judgment: NAME LAST KNOWN ADDRESS (If address cannot be reasonably ascertained, please so indicate.) Same as above 3. Name and 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 so indicate.) None 4. Name and address of the last recorded holder of every mortgage of record: NAME LAST KNOWN ADDRESS (If address cannot be reasonably ascertained, please so indicate.) None 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 so 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: I NAME LAST KNOWN ADDRESS (If address cannot be reasonably ascertained, please so indicate.) None 7. Name and address of every other person 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 so indicate.) Tenant/Occupant 17 A WEST GLENWOOD DRIVE CAMP HILL, PA 17011 Domestic Relations of 13 North Hanover Street Cumberland County Carlisle, PA 17013 Commonwealth of pO gox 2675 Welfarelvania Department of 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 aze made subject to the penalties of l8 Pa. C.S. Sec. 4904 relating t October 2.2001 DATE ~..~~, _„ i ~I-1 ,.;~:; 331;1.:x; GMAC MORTGAGE CORPORATION OF PA Plaintiff, v. RICHARD L. THUMMA KIMBERLY A. CLARK Defendant(s). CUMBERLAND COUNTY No. 01-4842 October 2, 2001 T0: KIMBERLY A. CLARK 17 A WEST GLENWOOD DRIVE CAMP HILL, PA 17011 RICHARD L. THUMMA 5252 OAKLAND STREET PHILADELPHIA, PA 19142 **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 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 LIEN AGAINST PROPERTY. ** Your house (real estate) at ,17 A WEST GLENWOOD DRIVE, CAMP HILL, PA 17011, 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 $65,082.07obtained by GMAC MORTGAGE CORPORATION OF PA (the mortgagee) against you. If the Sheriff's sale is postponed, the property will be relisted for the NNE 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: 1. 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. 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. You may also be able to stop the sale through other legal proceedings. You may need an attorney 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 attorney.) YOU MAY STILL BE ABLE TO SAVE YOUR PROPERTY AND YOU HAVE OTHER RIGHTS EVEN IF THE SHERIFF'S SALE DOES TAKE PLACE. I . 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 compared 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. 1 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 shaze 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) are filed with the Sheriff within 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 HAVE 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 t~1 THA": CE:2TA=Pi :~uc: ar parcel aj land anJ p~emesu, siae;t, :yir.3 snd tieing :n Tire Towr.s5'_p aj East Pennsboro in the CUUnry of Cumberland and CornmonweaLh of Penn;yfvurtia, mort perau/ar:y des_n6at os fo(fow:: In Accordance with survey of Gerrit J. Betz Associates, Zrc., Engineers and Surveyors, dated August 29, 1977, as follows, to •~+it: BEGZNNZNG at a point on the westerly line of Glenwood Crive ('AastJ, which point is 332.56 feet North of the norhwesteriy corner of Erford Road (West) and Glenwocd Drive ('AestJ and at dividing line between Let Numbers 4 and 4:{, Block "H" on the hereinafter mentioned Piar, of Lots; thence along said dividinAidine, North 63 degrees 30 minutes West and through the center of a partition wall and beycnd 1.5.0 feet to a point; thence along dividing line between Lot Ncs. 22X and 23, and 4X, Block "H", :7orth 26 degrees 30 minutes East 37.5 feat to a point at dividing line between Lot Nos. 4X and 5, Block "H" on said Piar.; thence along said dividing line, South 63 degrees 30 minutes East 115 feet to a point on the westerly line of Glanwccd Drive (West, aforesaid; thence along same, South 25 degrees 30 minutes West 37.5 feet to a point, the place of BEGINtIIitG. BEING Lot Number 4:{, BLcck "H", on Plan No. 10, Ridley Park, which Plan is recorded in the Office of the Recorder of Deeds in and for Cumberland County, Pennsylvania, in Plan Book 18, Page 4?. FIAVZNG THEREON erected a dwelling house known and numbered as 17 A Glenwood Drive (West). UNDER AND SUBJECT, nevertheless, to easements, restricticns, reservations, conditions and rights-of-way of record. _A~ WRIT OF EXECUTION and/or ATTACHMENT COMMONWEALTH OF PENNSYLVANIA) NO. 01-4842 CIVIL 19 COUNTY OF CUMBEflLAND) CIVIL ACTION - tAW TO THE SHERIFF OF r +."b .-~ and COUNTY: To satisfy the debt, interest and costs due OMAC Mortcage Corporation of PA from Richard L. Thumma Kimberly A. Clark (1) You are directed io levy upon the properly of the defendant(s) and to DEFENDANT(S) see legal decrription of gr~erty (2) You are also directed to attach the property of the defendant(s) not levied upon in the possession of as follows: and to not'rfy the garnishee(s) that: (a) an attachment has been issued; (b) the gamishee(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) It propertyofthedefendant(s)notlevieduponansubjectto attachmentisfoundinthepo&sessionofanyoneother than a named garnishee, you are directed to notify himlherthat he/she has been added as a garnishee and is enjoined as above stated. Amount Due $63, 465.42 L.L_ $.50 from 10/2/01 to 3/6/02 (per diem-10.43) Interest tl_616 65 a_d r sts Due Ptothy_~,l Atty's Comm % _ Other Costs Atty Paid Plaintiff F Dale: October 26, 2001 Curtis R. Long Prothonotary, Civil Division ~~ ~ Deputy REQUESTING PARTY: Name Frank Federman, Esq. Address: One Penn Center at Suburban Station 1617 John F. Kennedy Boulevard, Suite 1400 -Fhi3.-adelgkia, FR '"}03-8'4 Atlotney tot: Plaintiff Telephone: 215-563-7000 Supreme Court ID No. 12248 REAL ESTATE SA~.E o. t~ On November O1, 2001, the sheriff levied upon the defendant's interest in the real property situated in East Pennsboro Township, Cumberland County, PA, known and numbered as 17 A West Glenwood Drive, Camp Hill, and more fully described on Exhibit "A" filed with this writ and by this reference incorporated herein. Date: November O1, 2001 By~~'~ S _~~, Real Estat Deputy ~~~;-~,~,~-_ '`.fir,' ICi,; ?',' ~'" Z 67, lip ~~ h:: a;. .~. c~ w~u~.~r. _ .wx ~na+a x. ,_,,, ...q~~FN."~Aonaavsn ,<,a~~ o. ~a.+w7` i. THE PATRIOT NEWS THE SUNDAY PATRIOT NEWS Proof of Publication Under Act 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 authorized 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 the Recording of Deeds in and for said County of Daupf~n in ceflaneous Book "M", Volume 14, Page 317. r f , ~„ PUBLICATION COPY Swo to SALE#18 of Februarv 2002 A.D. „,~w~ egxrea Juna PennaylvenlaassxlatbnorNOfeHee ARY PUBLIC My commission expires June 6, 2002 CUMBERLAND COUNTY SHERIFFS OFFICE CUMMBERLANDCOUNTYCOURTHOUSE 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 $ 278.40 Probating same Notary Fee(s) $ 1.50 Total $ 279.90 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 .................................................................... rr.e~;~ REAL ESTATE SALE No. 18 ' -... Wrli No.2001d892 CIvB Temi GMAC Marl_gega Corp. o} A -- vs ._ _ - RlchaM LThumtna and _ _ IGmberiy A. Clark _ __ and of Iand and wmmanwemm or rennsytvanm, more cularly described az follows; ta-Accordance _survey of Gent S. Betz Associates, inc., beefs and Suaeyom, dated August 29, 1977, lbws, to wit: pNNING at a point on the westerly lioe of wood Drive (West), which point is 332.36 North of the nmthwesmrly comes of Erford I (Wes[) and Glevwcod Drive (Wes[) and m ing.]ine between Lot Numbers 4 and 4X, k "E" on dre 6ereinaker mendoned Plan of thence along said dividing line, North 63 :es 30 minutes West avd through the center of ~ ~ - ~ " tition wall and beyond 115.0 feet m a point; ' :e slang dividing line between Lo[ Nos. 22X !3, and 4X, Block "H", North 26 degrees 30 tes East 375 feet m a point at divid'mg line een Lot Nos. 4X and 3, Block "H" w said ';Vence, along same, South 26 degrees 30 minutes West 375 tee;, to a point the place of BEGINNING. "BEING Lot Number 4X, Block "H", on Plan No. lq Ridley Park, which Ptan is recorded in the Office of the Recerder of Deeds in and for Cu dand_CQUnty Pehnsylvaoia,,in Play Book $,Yage 47. ILIVEVG TPIEREON erected a dwelling house known and numbered as 17A Glenwood Drive (Wes,. UNDER AND SUBIECI; meverdre3ess, m eas<eivenfs,_ttsUicfioos, reservations, conditions avd tightsbf-way of rccard. e 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 further 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 of publication are true. Rog/ger M. Morgenthal, Editor SWORN TO AND SUBSCRIBED before me this 8 day of FEBRUARY, 2002_ 1BEp, Wotaay Pubi6c Carr;siand Expires INarch 5, Ir°E[17. EBTAT& $9LE NO. 18 Writ No. 2001-4842 Civil GMAC Mortgage Corporation of PA vs. Richard L. Thumma and Kimberly A. Clazk Atty.: Frank Federman ALL THAT CERTAIN tract, or parcel of land and premises, situ- ate, lying and being in the Town- ship of East Pennsboro in the County of Cumberland and Com- monwealth of Pennsylvania, more paztieularly described as follows: In Accordance with survey of Gerrit J. Betz Associates, Inc., En- gineers and Surveyors, dated Au- gust 29, 1977, as follows, to wit: BEGINNING at a point on the westerly line of Glenwood Drive (West), which point is 332.56 feet North of the northwesterly corner of Erford Road (West) and Glenwood Drive (West) and at dividing line between Lot Numbers 4 and 4X. Block "H" on the hereinafter men- tioned Plan of Lota; thence along said dividing line, North 63 degrees 30 minutes West and through the center of a partition wall and be- yond 115.0 feet to a point; thence along dividing line between Lot Nos. 22X and 23, and 4X, Block "H", North 26 degrees 30 minutes East 37.5 feet fo a point at dividing line between Lot Nos. 4X and 5. Block "H" on said Plan; thence along said ~ dividing line, South 63 degrees 30 ' minutes East 115 feet to a point on the westerly line of Glenwood Drive (West) aforesaid; thence along same. South 26 degrees 30 minutes West 37.5 feet to a point, the place of BEGINNING. BEING Lot Number 4X, Block "H", on Plan No. 10, Ridley Pazk, which PIan is recorded in the Of- fice of the Recorder of Deeds in and for Cumberland County, Pennsylva- nia, in PIan Book 18, Page 47. HAVING THEREON erected a dwelling house known and num- bered as 17 A Glenwood Drive (West). UNDER AND SUBJECT, never- theless, to easements, restrictions, reservations, conditions and rights- of-way of record. FEDERMAN AND PHELAN, LLP BY: FRANK FEDERMAN, ESQUIRE Identification No. 12248 One Perin Center at Suburban Station 1617 John F. Kennedy Boulevard, Suite 1400 Philadelphia, PA 19103-1814 (2151563-7000 GMAC Mortgage Corporation of PA ATTORNEY FOR PLAINTIFF Court of Common Pleas Civil Division Plaintiff v. Richard L. Thumma Kimberly A. Clark Defendants Cumberland County No. 01-4842 STATEMENT OF INTENTION TO PROCEED TO THE COURT: The above-referenced foreclosure action is protected by the automatic stay provisions of the Defendants, Kimberly Ann Clark's Chapter 13 Bankruptcy filed on February 19, 2002 at Docket No. 02-00873 RJW in Middle District of Pennsylvania. Plaintiff intends to proceed with its above foreclosure action should the Defendant's Bankruptcy be dismissed or Plaintiff receives relief from the automatic stay. Date: 3 ~ ~Gn/l f!~~1'~vV~"----- Frank Federman, Esquire Attorney for Plaintiff n ' i~ l {^ ~ 6sJ O Tti~j -T)-..- r : ; ~_ '-: c T ._ _~ LL r ' J _ - ;..{ €~ ~~ '~iW .. ~A~V __ .._ _. iSW'£~J:+G.sr•m m.-$ r .-3)~-H- _eYVrzm+ .,x sn 1r-r.%`ti1+.. -L ~vs~JP C.kiFAY ~!~ PRAECIPE FOR WRIT OF EXECUTION - (MORTGAGE FORECLOSURE) P.R.C.P.3180-3183 GMAC MORTGAGE CORPORATION Plaintiff, v. RICHARD L. THUMMA KIMBERLY A. CLARK Defendant(s). No. 01-4842 CIVIL TO THE DIRECTOR OF THE OFFICE OF THE PROTHONOTARY: Issue writ of execution in the above matter: Amount Due $63,465.42 Interest from 10127/01 to SEPTEMBER 8, 2004 $10,930.64 and Costs (per diem -$10.43) TOTAL $74,396.06 -~ ~~~~~ FRANK FEDERMAN, ESQUII2E 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. ,~ ~ ~~; w~ oz~ w~ az oz ~a O H ~z 00 ~~ o~ U W'rL" W F~ ~ ~ U z O H aO~ a O U CW,7 a d C~7 ~~ 5 U ~a E~ ~ a~ ~~ ~~ z 0 U wy k, o O~ F ~ 0 ~w 3 °' x~ 00 ~~ U ' ` V ~ :+ ~ ~. ~~ : . , ~ ~ ~ a ~ ~~ ~ P I : ,,, ~ ~ ~ ~ 01 ~ a ~ ~ IM Q ^ct w w .~ w w 0 ~~ d .o ro w 1'f -,-- ~~ ~~ ~~ ~` ~~ N U _ _ ,. -. 'FM3'RB.Y 9f#Ip'~RiF3Piallq",TES `.'_ _=VH~o [',.?Ix^lY.miM2&Q'.'~+Tr §:'~. iRfiik iP•Fi:Ve9@°.r'x~M°P.!~u'{~MVR4'. 1 N ALL THAT CERTAIN tract or parcel of land and premises, situate, lying and being in the Township of East Pennsboro in the County of Cumberland and Commonwealth of Pennsylvania, more particularly described as follows: In accordance with survey of Gerrit J. Betz Associates, Inc., Engineers and Surveyors, dated August 29, 1977, as follows, to wit: BEGINNING at a point on the westerly line of Glenwood Drive (West), which point is 332.56 feet North of the northwesterly comer of Erford Road (West) and Glenwood Drive (West) and at dividing line between Lot Numbers 4 and 4X, Block "H" on the hereinafter mentioned Plan of Lots; thence along said dividing 1'me, North 63 degrees 30 minutes West and through the center of a partition wall and beyond 115.0 feet to a point; thence along dividing line between Lot Nos. 22X and 23, and 4X, Block "H" North 26 degrees 30 minutes East 37.5 feet to a point at dividing tine between Lot Nos. 4X and 5, Block "H" on said Plan; thence along said dividing line, South 63 degrees 30 minutes East 115 feet to a point on the westerly line of Glenwood Drive (West) aforesaid; thence along same, South 26 degrees 30 minutes West 37.5 feet to a point, the place of Beginning. BEING Lot Number 4X, Block "H", on Plan No. 10, Ridley Pazk, which Plan is recorded in the Office of the Recorder of Deeds in and for Cumberland County, Pennsylvania, in Plan Book 18, Page 47. HAVING THEREON erected a dwelling house known and numbered as 17 A Glenwood Drive UNDER AND SUBJECT, nevertheless, to easements, restrictions, reservations, conditions and rights-of-way of record. TAX PARCEL # 09-16-1050-286 TITLE TO SAID PREMISES IS VESTED IN Richard L. Thumma and Kimberly A. Clark, joint tenants with the right of survivorship by Deed from Michael W. Weaver and Gaii P. Weaver, husband and wife dated 7/28/95, recorded 8!9/95, in Deed Book 126, Page 516. ~~ O p~ 4 a w S~ ~~ WRIT OF EXECUTION and/or ATTACHMENT COMMONWEALTH OF PENNSYLVANIA) COUNTY OF CUMBERLAND) NO O1-4842 Civil CNIL ACTION -LAW TO THE SHERIFF OF CUMBERLAND COUNTY: To satisfy the debt, interest and costs due GMAC MORTGAGE CORPORATION, Plaintiff (s) From RICHARD L. THUMMA AND HIMBERLY A. CLARK (1) You aze directed to levy upon the property of the defendant (s)and to sell SEE LEGAL DESCRIPTION . (2) You aze 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 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) not levied upon an subject to attachment is found in the possession of anyone other than a named garnishee, you are duetted to notify him/her that he/she has been added as a garnishee and is enjoined as above stated. Amount Due $63,465.42 L.L. Interest FROM 10/27/01 TO 9/8/04 (PER DIEM - $10.43) - $10,930.64 AND COSTS Atty's Comm % Due Prothy $1.00 Atty Paid $1033.17 Other Costs Plaintiff Paid Date: APRIL 26, 2004 CURTIS R. LONG Prothonot/~ (Seal) ~ Bv' /~/ /1'l~° .._ ~~L2~ ~Y• Deputy REQUESTING PARTY: Name FRANK FEDERMAN, ESQUIItE Address: ONE PENN CENTER AT SUBURBAN STATION 1617 JOHN F. KENNEDY BOULEVARD, SUITE 1400 PHILADELPHIA, PA 19103-1814 Attorney for: PLAINTIFF Telephone: 215-563-7000 Supreme Court ID No. 12248 ~,,~ FEDERMAN and PHELAN, LLP By: FRANK FEDERMAN Identification No. 12248 ONE PENN CENTER AT SUBURBAN STATION 1617 JOHN F. KENNEDY BLVD., SUITE 1400 PHILADELPHIA, PA 19103-1814 (215)563-7000 GMAC MORTGAGE CORPORATION Plaintiff, v. RICHARD L. THIJMMA KIMBERLY A. CLARK Defendant(s). ATTORNEY FOR PLAINTIFF CUMBERLAND COUNTY COURT OF COMMON PLEAS CIVIL DIVISION NO. 01-4842 CIVIL, CERTIFICATION FRANK FEDERMAN, ESQUIRE, hereby verifies that he is attorney for the Plaintiff in the above-captioned matter, and that the premises are not subject to the provisions of Act 91 because it is: Q an FHA mortgage O non-owner occupied O vacant (X) Act 91 procedures have been fulfilled This certification is made subject to the penalties of 18 Pa. C.S. Section 4904 relating to unsworn falsification to authorities. FRANK FEDERMAN, ESQUIRE Attorney for Plaintiff FEDERMAN AND PHELAN By: FRANK FEDERMAN, ESQUIRE IDENTIFICATION NO. 12248 ONE PENN CENTER AT SUBURBAN STATION, SUTTE 1400 PHILADELPHIA, PA 19103-1814 (2151 563-7000 GMAC MORTGAGE CORPORATION OF PA vs. RICHARD L. THUZvIMA KIMBERLY A. CLARK ATTORNEY FOR PLAINTIFF COURT OF COMMON PLEAS CNIL DIVISION CUMBERLAND COUNTY No.: 01-4842 ORDER AND NOW, this ~ day of f~2001, upon consideration of Plaintiffs ~~c ~. ~ xoo~ I,,a Motion and the Affidavit of Good Faith Investigation attached thereto, it is hereby ORDERED that Plaintiff may obtain service of the Notice of Sale on the above captioned Defendant(s), RICHARD L. THUMMA and KIMBERLY A. CLARK, by mailing a true and correct copy of the Notice of Sale by certified mail and regular mail to Defendant's last Imown address and the mortgaged premises. Service of the aforementioned mailings is effective upon the date of mailing and is to be done by Plaintiffs attorney, who will file with the Prothonotary's Office an Affidavit of service. BY THE COURT: J. TR!!~ C*~PY FROM RECC'~. s In Ta- ~mary }„-h-r of, I here unto set my hand end t seal of sa~ Coq~ri~at Carlisle, Pa. .~ IN THE UNITED STATES BANKRUPTCY COURT FOR THE MIDDLE DISTRICT OF PENNSYLVANIA IN RE: Kimberly Ann Clazk GMAC Mortgage Corporation Movant VS. Kimber]y Ann Clark Debtor(s) and Charles J. DeHart, III, Esquire Trustee RESPONDENTS CHAPTER 13 CASE N0.02-00873 MDF 11 U.S.C. SEC. 362 ORDER 14IODIFYING SECTION 362 AUTOMATIC STAY c~w~ ~~~µ~ DU56)~~D~ C~~ AND NOW, -this day of f - ." ~ i . ~'- , 20 ; ~[ , it is ORDERED AND DECREED that: " The Automatic Stay of all proceedings, as provided under Section 362 of the Bankruptcy Reform Act of 1979, as amended (The Code), 11 U.S.C. 362, is modified with respect to premises: 17 A W Glenwood Drive Camp Hill, PA 17011 as to allow the Movant fo foreclose on its mortgage and allow the purchaser of said premises at Sheriffs Sale {or purchaser's assignee) to take any legal action far enforcement of its right to possession of said premises. The relief granted by this order shall survive the conversion of this bankruptcy case to a case under any other Chapter of the Bankruptcy Code. $ankruptcy Judge , ~~~t~ t:\Wp51\BKY\2002\0235609cod. wpd ---~-~.~ Gt:r ; [l.S. E °:~:krt;a;cr Court l.+~' : ', 1'. ~. ' ~tllm _ .~- ~ GMAC MORTGAGE CORPORATION Plaintiff, v. RICHARD L. THUMMA KIMBERLY A. CLARK CUMBERLAND COUNTY COURT OF COMMON PLEAS CIVIL DIVISION NO.Ol-4842 CIVIL Defendant(s). AFFIDAVIT PURSUANT TO RULE 3129 (Affidavit No. I) 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 ats 17A WEST GLENWOOD DRIVE, CAMP HILL, PA 17011 . 1. Name and address of Owner(s) or reputed Owner(s): Name RICHARD L. THUMMA KIMBERLY A. CLARK Last Known Address (if address cannot be reasonably ascertained, please indicate) 17A WEST GLENWOOD DRIVE CAMP HILL, PA 17011 17A WEST GLENWOOD DRIVE CAMP HILL, PA 17011 2. Name and address of Defendant(s) in the judgment: Same as above 3. Name and last known 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) WANDELL JUTANNE 365 PETERSBURG ROAD CARLISLE, PA 17013 ~~. 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 17A WEST GLENWOOD DRIVE CAMP HILL, PA 17011 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. Anri123, 2004 ~ Q ~ (j DATE FRANK FEDERMAN, ESQUIlZE Attorney for Plaintiff 'p 7 3D !b ~) ~ n.~.n~na.. ~~w~. ~ Pt #s- ._ GMAC MORTGAGE CORPORATION Plaintiff, v. RICHARD L. THUMMA KIMBERLY A. CLARK Defendant(s). TO: RICHARD L. THUMMA 17A WEST GLENWOOD DRIVE CAMP HILL, PA 17011 CUMBERLAND COUNTY No. 01-4842 CIVIL Apri123, 2004 KIMBERLY A. CLARK 17A WEST GLENWOOD DRIVE CAMP HILL, PA 17011 * *THIS FIRM IS A DEBT COLLECTOR ATTEMPTING TO COLLECT A DEBT AND ANY INFORMATION OBTAINED WILL BE USED FOR THAT PURPOSE. IF YOUHAVE PREVIOUSLYRECEIVED ADISCHARGE IN BANKRUPTCYAND THIS DEBT WAS NOT REAFFIRMED, THIS IS NOT AND SHOULD NOT BE CONSTRUED TO BE ANATTEMPT TO COLLECT A DEBT. BUT ONLY ENFORCEMENT OF A LIEN AGAINST PROPERTY. Your house (real estate) at,17A WEST GLENWOOD DRIVE, CAMP HILL, PA 17011, is scheduled to be sold at the Sheriffs Sale on SEPTEMBER 8, 2004 at 10:00 a.m. in the Cumberland County Courthouse, South Hanover Street, Carlisle, PA 17013, to enforce the court judgment of $63,465.42 obtained by GMAC MORTGAGE CORPORATION (the mortgagee) against you. In the event the sale is continued, an announcement will be made at said sale in compliance with Pa.R.C.P., Rule 3129.3. 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: 1. 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. You may also be able to stop the sale through other legal proceedings. You may need an attorney 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 attorney.) YOU MAY STILL BE ABLE TO SAVE YOUR PROPERTY AND YOU HAVE OTHER RIGHTS EVEN IF THE SHERIFF'S SALE DOES TAKE PLACE. 1. If the Sheriffs Sale is not stopped, your property will be sold to the highest bidder. You may find out the price bid by calling (215) 563-7000. 2. You maybe able to petition the Court to set aside the sale if the bid price was grossly inadequate compared 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) are filed with the Sheriff within 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 HAVE 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 M ALL THAT CERTAIN tract or parcel of land and premises, situate, lying and being in the Township of East Pennsboro in the County of Cumberland and Commonwealth of Pennsylvania, more particularly described as follows: In accordance with survey of Gerrit 3. Betz Associates, Inc., Engineers and Surveyors, dated August 29, 1977, as follows, to wit: BEGINNING at a point on the westerly line of Glenwood Drive (West), which point is 332.56 feet Narth of the northwesterly corner of Erford Road (West) and Glenwood Drive (West) and at dividing line between Lot Numbers 4 and 4X, Block "H" on the hereinafter mentioned Plan of Lots; thence along said dividing line, North 63 degrees 30 minutes West and through the center of a partition wall and beyond 115.0 feet to a point; thence along dividing line between Lot Nos. 22X and 23, and 4X, Block "H" North 26 degrees 30 minutes East 37.5 feet to a point at dividing line between Lot Nos. 4X and 5, Block "H" on said Plan; thence along said dividing line, South 63 degrees 30 minutes East 115 feet to a point on the westerly line of Glenwood Drive (West) aforesaid; thence along same, South 26 degrees 30 minutes West 37.5 feet to a point, the place of Beginning. BEING Lot Number 4X, Block "H", on Plan No. 10, Ridley Park, which Plan is recorded in the ,. Office of the Recorder of Deeds in and for Cumberland County, Pennsylvania, in Plan Book 18, Page 47. HAVING THEREON erected a dwelling house known and numbered as 17 A Glenwood Drive (West). UNDER AND SUBIECT, nevertheless, to easements, restrictions, reservations, conditions and rights-of--way of record. TAX PARCEL # 09-16-1050-286 TITLE TO SAID PREMISES IS VESTED IN Richard L. Thumma and Kimberly A. Clark, joint tenants with the right of survivorship by Deed from Michael W. Weaver and Gail P. Weaver, husband and wife dated 7!28(95, recorded 8/9/95, in Deed Book 126, Page 516. ..,, ~~' ,~- '.. »a~.. .~~~.>i"._~y, r., .,~..,~, ..~-~uae=`~a~w~,.as;;~z u*~.'s~R;e IN THE COURT OF COMMON PLEAS OF CUMBERLAND COUNTY, PENNSYLVANIA GMAC MORTGAGE CORPORATION vs. RICHARD L. THUMMA KIMBERLY A. CLARK CIVIL ACTION CIVIL DIVISION NO. 01-4842 CIVIL AFFIDAVIT OF SERVICE PURSUANT TO RULE 3129 COMMONWEALTH OF PENNSYLVANIA ) COUNTY OF CUMBERLAND ) SS: I, FRANK FEDERMAN, ESQUIRE attorney for GMAC MORTGAGE CORPORATION hereby verify that on Apri127.2004 true and correct copies of the Notice of Sheriff s sale were served by certificate of mailing to the recorded lienholders, and any known interested party see Exhibit "A" attached hereto. DATE: Au¢ust 16.2004 ~~~ FRANK FEDERMAN, ESQUIRE Attorney for Plaintiff ~~ -o r ~~ ;z U A ~.> N O ~ m J ~ U A W N ~ ~~ d~ ~, o D a ~ z 3 1 zo ~ ~ H C~ d z a~ ~ ~ z ~ ~ h7 y ' r., _ ~ y a o C" C" O '" C1 ~ A " '~ ~ ~ r A a x ~ ~ ° o W ° z ~ J ~ O O '7 'rI ~ ~~!! C M v 3 ~ ` -] Cil ° ' ° ~ ~ V] ~ '` ~ a ~U C 3 o O O d 'A m ~[ p, V d a ~' y~~ i~- ~ ~ ~' z z C7 a w ~a~~~ ~ o z e~so- Y ro 7y a ~~~ J x ~ m N=~. o~o ~ r r x V'C ~ Q o ~ o o a ZO w ..~ 'OO ~' ~. 5 0 0 v o b O C~ y y ~ ~ 7 ~, o "~ ~ a ~ N a~° = o c'a ~ o~ `° ° ° ~ o d K ~ "~" D C l '~ Mo" b ~'3 ~c r ~ " y aad ~ C m d 6S. ~ ~ . _ m ~ ~ ~ v a E _ .b ~- a o o ~~as E'P`~ra ~ ~ ~ `" g d+ ~ o ,, ~ ITN Y IiOV rES o N = ~ C $ Q7 20° q , ~ ~ 02 1A ° i 0008360377 AP P.27 2^G~t & ~ `-~ MAILED FRONT ZlP GQDE 19103 d- 5 a ~5'os . ~~s; °-'.^ro ~ `k `a »v a oaz »~aw ~ p. ".~. ~ ~ m ~ ~ ~ ~, a Ib "' O ~~~ d " ~ [=1 o w !~1 C7 a~~~ w ~~ o~°<-~'ro ~~~~ ~~~~ A 4 ro ~• m ~C.C' 4 ~ ~ ro A ~ ~n o M ~ ~ tt ~~ti L~ FEDERMAN AND PHELAN BY: FRANK FEDERMAN IDENTIFICATION NO. 12248 SUITE 1400 -ONE PENN CENTER PHILADELPHIA, PA 19103 215)563-7000 GMAC MORTGAGE CORPORATION vs. RICHARD L. THUMMA KIMBERLY A. CLARK ATTORNEY FOR PLAINTIFF CUMBERLAND COUNTY COURT OF COMMON PLEAS CIVIL DIVISION NO.OI-4842 CIVIL I hereby certify that a true and correct copy of the Notice of Sheriff s Sale in the above captioned matter was sent by regular mail and certified mail, return receipt requested, to the following person(s) RICHARD L. TI-IUMMA and KIMBERLY A. CLARK on Maw fi,~ at 17A WEST GLENWOOD DRIVE, CAMP HILL, PA 17011, in accordance with the Order of Court dated, Decemhc>r 1 x,'001. The undersigned understands that this statement is made subject to the penalties of 18 PA. C.S. s4904 relating to unsworn falsificaton to authorities. FRANK FEDERMAN, ESQUIRE ATTORNEY FOR PLAIlVTIFF DATE: August 18, 2004 { FEDERMAN AND PHELAN By: FRANK FEDERMAN, ESQUIItE IDENTIFICATION NO. 12248 ONE PENN CENTER AT SUBURBAN STATION, SUITE 1400 PHILADELPHIA, PA 19103-1814 ' 215 Sb3-7000 GMAC MORTGAGE CORPORATION OF PA vs. RICHARD L. THUZvtMA KIMBERLY A. CLARK ATTORNEY FOR PLA[NTIFF COURT OF COMMON PLEAS CIVIL DIVISION CUMBERLAND COUNTY No.: 01-4842 ORDER AND NOW, this ~ day of ~~l~2001, upon consideration of Plaintiffs o~c i i zoot ~-~> Motion and the Affidavit of Good Faith Investigation attached thereto, it is hereby ORDERED that Plaintiff may obtain service of the Notice of Sale on the above captioned Defendant(s), RICHARD L. THUMMA aad KIMBERLY A. CLARK, by mailing a true and correct copy of the Notice of Sale by certified mail and regular mail to Defendant's last known address and the mortgaged premises. Service of the aforementioned mailings is effective upon the date of mailing and is to be done by Plaintiffs attorney, who will file with the Prothonotairy's Office an Affidavit of service. BY THE COURT: J. T~IJE COPY FROM RECC'4=; In 7~° ~mony va;,~r of, I here unto set my hand end I seal of sa~ Coyrt~at Carlisle, Pa. ~~ 77,x(1 390y'9$4$ .4533 35'16. - ~ TO: KIf34BEI~LY A. CLARE: 17A`VPEST ~LENWOOD DRIVE ~, ;~ CA11IP HILL, PA 17b11 ~'~~~: TEAIGI2 SRL -- p~iENCE: RICIYARD L, THiJM'MA Postage ~ ~ It ~e fied Fee - ,~ ~8 kelurn I~eat'ip"[ @e¢ Fiestr~ded Delrvpiy - - TotalPtlstag¢;&: F¢as, - ~st@I ~erblQe ~ POST ~ OH iil~l~Et °e ~F~ ~ for E 1~ ~~~~~ 'TEe~ NI2 S,PL '~E RTGIIA~iD I~ T~L71~I , . ~~ ~ SER\<ICE' 4.gn ~Q . ~ ~r~ s~ pet Ftd tF e ~~t ~ n ,~ P ~ ~,, ~ - .Tn}pl CncYei`5i9r C.me ... ~ ~ A\~ ~. l1S'P~tal Se~ice R1~S a~ '' ~~.u~~.~: ~~._ ;= f Brie ,r ~~x~~,.~~-a- __. ~,~ {-~ ._ c ,+ '_ 2 : ~;. _.~ ~.ti, .. [-,' ,, m :, 4, - ~ ~,~, ~S ~~ COMMONWEALTH OF PENNSYLVANIA COUNTY OF CUM$ERLAND ~ SS: I, Robert P. Ziegler, Recorder of Deeds in and for said County and State do hereby certify that the Sheriff s Deed in which Gmac MtQ Corp is the grantee the same having been sold to said grantee on the ~ day of Sept A.D., 2004, under and by virtue of a writ Execution issued on the 26th day of Aril, A.D., 2004, out of the Court of Common Pleas of said County as of Civifl Term, 2001 Number 4842, at the slut of GMAC Mte Corp against Richard L Thumma & Kimberly A Clark is duly recorded in Sheriff's Deed Book No. 265, Page 2606. IN TESTIMONY WHEREOF, I have hereunto set my hand and seal of said office this ~~ © , A.D2004 day of Recorder of Deeds ~r«~'~e GMAC Mortgage Corporation VS Richard L. Thurnma and Kimberly A. Clark In The Court of Common Pleas of Cumberland County, Pennsylvania Writ No. 2001-4842 Civil Term R. Thomas Kline, Sheriff, who being duly sworn according to law, states that he made a diligent search and inquiry for the within named defendant, to wit: Richard L. Thumma, but was unable to locate him in his bailiwick. He therefore returns the within Real Estate Writ, Notice of Sale and Description as NOT FOUND. The defendant moved from 17A West Glenwood Drive, Camp Hill, PA 17011 more than four years ago. Kenneth Gossert, Deputy Sheriff, who being duly sworn according to law, states that on July 15, 2004 at 8:41 o'clock PM, he served a true copy of the within Real Estate Writ, Notice of Sheriffs Sale and Description, in the above entitled action, upon the within named defendant, to wit: Kimberly A. Clark, by making known unto Kimberly Clark, personally, at 34 Mallard Court, Mechanicsburg, Cumberland County, Pennsylvania, its contents and at the same time handing to her personally the said true and correct copy of the same. Kenneth Gossert, Deputy Sheriff, who being duly sworn according to law, states that on July 15, 2004 at 8:22 o'clock P.M., he posted a true copy of the within Real Estate Writ, Notice, Poster and Description, in the above entitled action, upon the property of Richard L. Thumma and Kimberly A. Clark located at 17A West Glenwood Drive, Camp Hill, Pennsylvania, according to law. R. Thomas Kline, Sheriff, who being duly sworn according to law, states he served the above Real Estate Writ, Notice, Poster and Description in the following manner: The Sheriff mailed a notice of the pendency of the action to the within named defendant, to wit: Kimberly A. Clark, by regular mail to her last known address of 34 Mallard Court, Mechanicsburg, PA 17055. This letter was mailed under the date of July 16, 2004 and never returned to the Sheriffs Office. R. Thomas Kline, Sheriff, who being duly sworn according to law, states that after due and legal notice had been given according to law, he exposed the within described premises at public venue or outcry at the Courthouse, Carlisle, Cumberland County, Pennsylvania on September 08, 2004 at 10:00 o'clock A.M. He sold the same for the sum of $1.00 to Attorney Frank Federman for GMAC Mortgage Corporation. It being the highest bid and best price received for the same, GMAC Mortgage Corporation of 500 Enterprise Road, Suite 150, Horsham, PA 19044-0969 being the buyers in this execution, paid to Sheriff R. Thomas Kline the sum of $922.91. Sheriffs Costs: Docketing $30.00 Poundage 18.10 Posting Bills 15.00 Advertising 15.00 Acknowledging Deed 30.00 Auctioneer 10.00 Law Library Prothonotary 1.00 Mileage 19.24 Levy 15.00 Surcharge 30.00 Law Journal 335.15 Patriot News 309.43 Share of Bills 30.49 Distribution of Proceeds 25.00 Sheriffs Deed 39.50 $ 922.91 Sworn and subscribed to before me So Answers: I This $ ~ day of ~n~',/~~-. ~ ~ f",~(.f~//`~.G ~ R. Thomas Kline, Sheriff 2004, A.D. ((11~~~~~ P othonotary ~ ~ BY ~ ;~i'Y~ Real Est e eputy lam' u~ ~^~' 3~ ,rc 1S6a3~ ~~ r GMAC MORTGAGE CORPORATION Plaintiff, v. RICHARD L. THUMMA KIMBERLY A. CLARK Defendant(s). CIVIL DIVISION NO.Ol-4842 CIVII, 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,17A WEST GLENWOOD DRIVE. CAMP HILL, PA 17011 . 1. Name and address of Owner(s) or reputed Owner(s): Name RICHARD L. THUMMA KIMBERLY A. CLARK CUMBERLAND COUNTY COURT OF COMMON PLEAS Last Known Address (if address cannot be reasonably ascertained, please indicate) 17A WEST GLENWOOD DRIVE CAMP HILL, PA 17011 17A WEST GLENWOOD DRIVE CAMP HILL, PA 17011 2. Name and address of Defendant(s) in the judgment: Same as above 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) WANDELL JUTANNE 365 PETERSBURG ROAD CARLISLE, PA 17013 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: rlar.e Last Known Address (if address cannot be reasonably ascertained, please indicate) Tenant/Occupant Domestic Relations of Cumberland County Commonwealth of Pennsylvania Department of Welfare 17A WEST GLENWOOD DRIVE CAMP HILL, PA 17011 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. Anri123, 2004 ~ ~ Q~ J~, DATE FRANK FEDERMAN, ESQUIRE Attorney for Plaintiff GMAC MORTGAGE CORPORATION Plaintiff, v. RICHARD L. THUMMA KIMBERLY A. CLARK Defendant(s). TO: RICHARD L. THUMMA 17A WEST GLENWOOD DRIVE CAMP HILL, PA 17011 CUMBERLAND COUNTY No. 01-4842 CIVIL Apri123, 2004 HIMBERLY A. CLARK 17A WEST GLENWOOD DRIVE CAMP HILL, PA 17011 * *THIS FIRM IS A DEBT COLLECTOR ATTEMPTING TO COLLECT A DEBT AND ANYINFORMATION OBTAINED WILL BE USED FOR THAT PURPOSE. IF YOUHAVE PREVIOUSLYRECEIVED ADISCHARGE IN BANKRUPTCYAND THIS DEBT WAS NOT REAFFIRMED, THIS IS NOT AND SHOULD NOT BE CONSTRUED TO BE ANATTEMPT TO COLLECT A DEBT, B UT ONLY ENFORCEMENT OF A LIENAGAINST PROPERTY. Your house (real estate) at,17A WEST GLENWOOD DRIVE, CAMP HILL, PA 17011, is scheduled to be sold at the Sheriffs Sale on SEPTEMBER 8, 2004 at 10:00 a.m. in the Cumberland County Courthouse, South Hanover Street, Carlisle, PA 17013, to enforce the court judgment of $63,465.42 obtained by GMAC MORTGAGE CORPORATION (the mortgagee) against you. In the event the sale is continued, an announcement will be made at said sale in compliance with Pa.R.C.P., Rule 3129.3. 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 attorney 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 attorney.) YOU MAY STILL BE ABLE TO SAVE YOUR PROPERTY AND YOU HAVE OTHER RIGHTS EVEN IF THE SHERIFF'S SALE DOES TAKE PLACE. 1. If the Sheriffs Sale is not stopped, your property will be sold to the highest bidder. You may find out the price bid by calling (215) 563-7000. 2. You maybe able to petition the Court to set aside the sale if the bid price was grossly inadequate compared 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 may be 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) are 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 HAVE 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 or parcel of land and premises, situate, lying and being in the Township of-East Pennsboro in the County of Cumberland and Commonwealth of Pennsylvania, more particularly described as follows: In accordance with survey of Gerrit J. Betz Associates, Inc., Engineers and Surveyors, dated August 29, 1977, as follows, to wit: BEGINNING at a point on the westerly line of Glenwood Drive (West), which point is 332.56 feet North of the northwesterly corner of Erford Road (West) and Glenwood Drive (West) and at dividing line between Lot Numbers 4 and 4X, Block "H" on the hereinafter mentioned Plan of Lots; thence along said dividing line, North 63 degrees 30 minutes West and through the center of a partition wall and beyond 115.0 feet to a poiht; thence along dividing line between Loi Nos. 22X and 23, and 4X, Block "H" North 26 degrees 30 minutes East 37.5 feet to a point at dividing line between Lot Nos. 4X and 5, Block "H" on said Plan; thence along said dividing line, South 63 degrees 30 minutes East 115 feet to a point on the westerly line of Glenwood Drive (West) aforesaid; thence along same, South 26 degrees 30 minutes West 37.5 feet to a point, the place of Beginning. BEING Lot Numbet 4X, Block "H", on Plan No_ 10, Ridley Pazk, which Plan is recorded in the Office of the Recorder of Deeds in and for Cumberland County, Pennsylvania, in Plan Book 18, Page 47. HAVING THEREON erected a dwelling house known and numbered as 17 A Glenwood Drive {West). __,__ UNDER AND SUBJECT, nevertheless, to easements, restrictions, reservations, conditions and rights-of--way of record. TAX PARCEL /{ 09-16-1050-286 TITLE TO SAID PREMISES IS VESTED IN Richard L. Thumma and Kimberly A. Clark, joint ,. tenants with the right of survivorship by Deed from Miehael W. Weaver and Gail P. Weaver, husband and wife dated 7/28/95, recorded 8/9/95, in Deed Book 126, Page 516. WRIT OF EXECUTION and/or ATTACHMENT COMMONWEALTH OF PENNSYLVANIA) COUNTY OF CUMBERLAND) NO 01-4842 Civil CIVIL ACTION -LAW TO THE SHERIFF OF CUMBERLAND COUNTY: To satisfy the debt, interest and costs due GMAC MORTGAGE CORPORATION, Plaintiff (s) From RICHARD L. THUMMA AND I{iMBERLY A. CLARK (1) You are directed to levy upon the property of the defendant (s)and to sell SEE LEGAL DESCRIPTION. (2) You are also duetted 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 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) not levied upon an subject to attachment is found in the possession of anyone other 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 $63,465.42 L.L. Interest FROM 10/27/01 TO 9/8104 (PER DIEM - $10.43) - $10,930.64 AND COSTS Atty's Comm % Due Prothy $1.00 Atty Paid $1033.17 Other Costs Plaintiff Paid Date: APRIL 26, 2004 CURTIS R. LONG Prothonota (Seal) ~~~c ~_T~~ v`r- Deputy REQUESTING PARTY: Name FRANK FEDERMAN, ESQUIRE i Address: ONE PENN CENTER AT SUBURBAN STATION 1617 JOHN F. KENNEDY BOULEVARD, SUITE 1400 PHILADELPHIA, PA 19103-1514 Attorney for: PLAINTIFF Telephone: 215-563-7000 Supreme Court ID No. 12248 Real Estate Sale #12 On May 14, 2004 the sheriff levied upon the defendant's interest in the real property situated in East Pennsboro Township, Cumberland County, PA Known and numbered as 17A West Glenwood Drive, Camp Hill, more fully described on Exhibit "A" filed with this writ and by this reference incorporated herein. Date: May 14, 2004 By:,~G Real Est e Deputy ""!h3~ f'~A~~h2~ ~~ ,~~RN~~'Rlls rt~)~i71~41 0 - ~tamav WEYx,y:. ti- ..,.r m~er.e G*3fT5.~, "~.,f~Ti:B/.~RR, -_ r, t THE PATRIOT NEWS THE SUNDAY PATRIOT NEWS Proof of Publication Under Act No. 587, Approved May 16, 1929 Commonwealth of Pennsylvania, County of Dauphin} ss Joseph A. Dennison, being duly sworn according to law, deposes and says: That he is the Assistant Controller of The Patriot News Co., a corporation organized and existing under the laws of the Commonwealth of Pemnsylvania, with its principal office and place of business at 812 to 818 Mazket 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 Mazket Street, in the City, County and State aforesaid; that The Patriot-News and The Sunday Patriot-News were established Mazch 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 exacfly as printed and published in their regulaz daily and/or Sunday/ Metro editions which appeazed on the 27th day(s) of July and the 3rd and 10th day(s) of August 2004. 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 aze true; and That he has personal knowledge of the facts aforesaid and is duly authorized and empowered to verify this statement on behalf of The Patriot-News Co. aforesaid by virtue and pursuant to a resolution »nan;mnusly passed and adopted severally by the stockholders and boazd of directors of the said Company and subsequently duly recorded in the office for the Recording of Deeds in and for said County of Dauphin in Miscellaneous Book "M", Volume 14, Page 317. PUBLICATION .....................~'%/~~~~~.. COPY Swom to and subscribed before me s 3rd day of Au st 20 SALE #12 NOTARY Terry L. Russell, Not Ciry of Harrisburg, Do pUBL C My Commission Fxpires June 6, Member, Pennavlventa Aaeo lyafi6l>tl6iyq&rgn expires June 6, 2006 CUMBERLAND COUNTY SHERIFFS OFFICE CUMBERLAND COUNTY COURTHOUSE CARLISLE, PA. 17013 Statement of Advertising Costs To THE PATRIOT-NEWS CO. For publishing the notice or publication attached hereto on the above stated dates 309.43 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 .................................................................... EAL ESTATE SALE No. 12 VJrlt No,2001.4842 _ ~ '= Civil Term GI4~O~141brtgage Corporation _- Vs - =Richard L. Thumma end - - __ Klmb®rN A. Clark ~~ "Arty: Frank Federman a= OESGRIPTION z~LL 11LfTCERTAIN tract w parcel of ]and -aod premises, sima'e, lyieg and being in ~theabsyslship of Fast I'ennsboro in the County of - -Cumbe$and and Commonwealth of _ °_ Peh¢4ylvania, more particdlafly de-scribed as follows: In accordance with survey of Gem[, J. "~9e_L__Associa[es, Ine., Eng~'neers and Surveyors, daLedAugus[?9.1977, ss follows, to wit: ~- -, H$GIIJNING a; n point on the westerly fine _ of Glenwood Drive (Wa[l. which oomt is 332.56 edae along-said_dividing line,-Noah 63 3U minutes west and d¢ohgh the center rtitibn w_alf_a_nd~4od 135.0 fcet to a thence'a7orig divsding fine between Lot d 23, and 4X, Block iEB NoM 26 30 minutes Eas[ 37.5 feet to a poim az ,'line between Lot Nos. 4X and 5, Black said Plan; thence along said dividing line, i3 degrees 30 minutes East 1l5 feet to a 'u the westerly Gne of Glenwood Drive aforesaid; thence along same, South 26 ~Dlninyta R'at_31.5 feetlo a pow4 the of Deeds m and for t-svlvdnia, in Plan Book RAVING THEREON ettcted a dwelling -muse kootm and numbered as 17A Glenwood ~hive(Wes[). _ _UNDEt; AND 5t1BIECT, never-theless, [o <asemehis, res[ricfions, reservations, conditions wand n'ghis-of-way of record. -=-Te1X PARCEL H09-16-f050-286. TfA'LE TO SAID PRENllSFS is vested in ~Richazd L..'Lhumma and Kimberly A. Clazk, joint ten=ants-with the right of survivotsidp by Deed tram-Ntichae( W. Weaver and Gait P. Weever, }iusltand and wife, dazed 7I28N5, recorded 8N/95, in Deed Book l2G, Page Sl6. , 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. Lisa Marie Coyne, 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, JULY 16, 23, 30, 2004 Affiant further 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 of publication are true. a Marie Coyne Editor SWORN TO AND SUBSCRIBED before me this 30 day of JULY 2004 NOT71FffAC SEAL ~ LOTS E. SNYDER, Notary Public Carlisle Boro, Cumberland COUrdy My Commission Expires March S, 2005 READ ESTATE BAi,E NO. 12 Writ No. 2001-4542 Civil GMAC Mortgage Corporation vs. Richard L. Thumma and Kimberly A. Clark Atty.: Frank Federman ALL THAT CERTAIN tract or paz- cel of land and premises, situate, lying and being in the Township of East Pennsboro in the County ofCum- berland and Commonwealth of Penn- sylvania, more particularly de- scribed as follows: In accordance with survey of Gerrit J. Betz Asso- ciates, Inc., Engineers and Survey- ors, dated August 29, 1977, as fol- lows, to wit: BEGINNING at a point on the westerly line of Glenwood Drive (West), which point is 332.56 feet North of the northwesterly comer of Erford Road (West) and Glenwood Drive (West) and at dividing line between Lot Numbers 4 and 4X, Block "H" on the hereinafter men- tioned Plan of Lots thence along said dividing line, North 63 degrees 30 minutes West and through the cen- ter of a partition wall and beyond 115.0 feet to a point; thence along dividing line between Lot Nos. 22X and 23, and 4X, Block "H" North 26 degrees 30 minutes East 37.5 feet to a point at dividing line be- tween Lot Nos. 4X and 5, Black "H" on sazd Plan; thence along said di- vlddng line, South 63 degrees 30 minutes East 115 feet to a point oa the westerly line of Glenwood Drive (West) aforesaid: thence along same, South 26 degrees 30 minutes West 37.5 feet to a point, the place of Beginning. BEING Lot Number 4X, Block "H", on Plan No. 10, Ridley Pazk, which Plan is recorded in the Of- fice of the Recorder of Deeds in and for Cumberland County, Pennsylva- nia, in Plan Book 18, Page 47. HAVING THEREON erected a dwelling house known and num- bered as 17 A Glenwood Drive (West), UNDER AND SUBJECT, never- theless, to easements, restrictions, reservations, conditions and rights- of-way of record. TAX PARCEL #09-16-1050-286. TITLE TO SAID PREMISES IS VESTED IN Richard L. Thumma and Eimberly A. Clark, joint tenants with the right of survivorship by Deed from Michael W. Weaver and Gail P. Weaver, husband and wife dated 7/28/95, recorded 8/9/95, in Deed Book 126, Page 516.