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Home My WebLink About01-05302Martha E. Von Rosenstiel 16 South Lansdowne Avenue P.O. Box 457 Lansdowne, PA 19050 (610) 623-2660 Attorney I.D. #52634 Attorney for Plaintiff/Movant Manufacturers & Traders Trust Company, trustee Plaintiff vs. Pamela Stofko Defendants TO THE PROTHONTARY: Kindly mark the above captioned judgment COURT OF COMMON PLEAS Cumberland COUNTY Case No: 01-5302 Civil Term Martha E. Von Rosenstiel Attorney for Plaintiff Dated: Apri14, 2002 M ~,atn~x.~~~si ,i~at .--..~z_~_.rx rzL.r-~-.+.._.. F ~~.~+_ .. v :.> , ,..-~~-;+~kSii~€~.kw.rw.e~vAS,!uaa~.~u'erossasms~+we.~u3t - d n ~ y?; ZrT ~ r. ~ ~~ Z~ o cn, :;; ~ C iv ~ M 1' its -< (-S B~ f. Martha E. Von Rosenstiel, P.C. Martha E. Von Rosenstiel 16 South Lansdowne Avenue P.O. Box 457 Lansdowne, PA 19050 610 623-2660 Attorney I.D.# 52634 Manufacturers & Traders Trust Company, trustee One M & T Plaza Buffalo NY 14203-2399 Plaintiff vs. Pamela Stofko 730 Franklin Street Carlisle, PA 17013 Defendants Attorney for Plaintiff COURT OF COMMON PLEAS CUMBERLAND COUNTY No: 01-5302 Civil Term #8324 1_ AFFIDAVIT OF SERVICE OF NOTICES PURSUANT TO RULE 3129.1 COMMONWEALTH OF PENNSYLVANIA: COUNTY OF DELAWARE SS MARTHA E. VON ROSENSTIEL, attorney for the plaintiff in the above action, hereby certifies that service of the Notice under Rule 3129.1, in the above matter was made on the defendants via certified mail, return receipt requested (unless otherwise stated) and on all interested parties, set forth below, by regular first class mail, postage prepaid, as evidenced by the attached certificates of mailing: 1. Name and address of o,vners(s) or reputed owner(s) Pamela Stofico 730 Franklin Street Carlisle, PA 17013 2. Name and address of defendant(s) in the judgment: Pamela Stofko 730 Franklin Street Carlisle, PA 17013 3. Name and address of every judgment creditor whose judgment is a record lien on the real property to be sold: NONE 4. Name and address of the last recorded holder of every mortgage of record: q The Pacesetter Corporation / 7487 Whitepine Road Chesterfield, Buisness Center Richmond, VA 23237 5. Name and address of every other person who has any record lien on the property: 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: Family Court/Domestic Relations Office '~ One Courthouse Square Carlisle, PA 17013 Dept. of Public Welfare / 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. Section 4904 relating to unsworn falsification to authorities. Martha E. Von Rosenstiel Attorney for Plaintiff ~, ,, i ti RJ Postage (U ~ Cenlfled Fes 0 Realm Reaelpt Fes (End°reementi~9etretl) O ~ (EridoreeinentDaRequ@ed) ~ tblal Poelagea Faea U.S. POSTA SERVICE 'C RTIFI ATE ' F' AIIINBG -MAY aE USEOFOR DOMESTIC ANO INTEhNAT10NAl MAIL. DOES NOT PROVIDE FO '~ ANCE-POS T M A S T ER- • -- ~ 77 ~ 1 S ~ dry Received Fram: ENrv nuJ Sn`MPri. i6 S. lANSDOWNE AVE. p n ®D~ 4b~ LANSDOWNE, PA 19050. O ~Oq One piece of ordinary mall Addressed ta: Z PAMELA STOFKO j 11 730 FRANKLIN STREET ~'~~ CARLISLE, PA. 17013 PS Form 3817, Mar. 1989 Affix fee here in stamps or meter postage and post mark. Inr•uire of P r ~r current '~O N w ~o ~o >• ~o purar~ O s ~~ 9 m 't, v1 ~ ~ J > O I L '0 a_ m l oD a ~~o ~~~ o a vI O W ~ Complete Items ],~2;'an0's.:wso Gompisro - cc d ~' ~'% - i ~ !-.- ~ -- ~ n ~ - ° ` '~ N ~\ *:- s desire 'item 4'If Restricted Delivery ,, ^ Print your name and address on the reverse o stgnatu 1 ' I -so that we can return the card to you r v .~ ~' ~ ~ ~ ~ ~ ~ Attach this card to the back of the mallpiece ' :x~- t. ' a~ ~ ~ ` . or on the from if space'permits. -~:„ i' ~~' t4;,~;Yas =_ , D. Is,delNen/ addresp dlRerant 1. Article Addressed to 'r'a :. _ ..M YES, enter dent ;,o-. P _ ~W. ~. ^ No G ~~1 ~ ~~ PAMELA STOFKO ~N `; " ~ 730 FRANRLIN STREET 14 ' CARLISLE, PA. 17013 3. `Sesrvlce Type ~, j H'Certihed Mag •ES4fail' /^` Registered ^ Return Receipt for Merchandise ~! ^ Insured Mail ^ C.O.D. 4. Restricted Degverl'! (Extra fee) ^ Yes 2. 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Robert P Ziegler I+--°°-----------------------------------------------°------------------------ Recorder of Deeds in and for said County and State do'hercby certify that the Sheriff's Dced in which ________________ --- Manufacturers & Traders Tr Co, Tr --------°-------•-------------------------°°----------------------------isthe grantee the same having been sold to said grantee on the __ 6th--------------------°------------------- day of March 2002 ----°---°-°--------------------------- A. D., i --__-, under and by virtue of a writ--------_----- Execution ___________~ued on the ____ 1st ~y ~ __,jf,Qygj~er______________ p, D,~ 2001 ____, out of the Court o[ Comman Pleas of said County as of Civil 2001 ------------------------------...-----°------------------------------------------- Term,: .----- 5302 Manufacturers & Traders Tr Co, Tr Number---------°---,atthesuitof--------------°----------------------------------------------- Pamela Stofko ----°---°___________________°--- against----°-------------------------------------°------- ss 250 4741 dulyrawrdedinSberifCsDeedBookNo.____________, Page_____:______. IN TESTIMONY WHEREOF, I ha~vye hemunto set my hand and seal of said office this al_~__ day Manufacturers & Traders Trust Company, Trustee VS Pamela Stofko In The Court of Common Pleas of Cumberland County, Pennsylvania Writ No. 2001-5302 Civil Term Douglas Donsen, Deputy Sheriff, who being duly sworn according to law, states that on November 7, 2001 at 4:55 o'clock P.M., EST, he served a true copy of the within Real Estate Writ, Notice and Description, in the above entitled action, upon the within named defendant, to wit: Pamela Stofko, by making known unto Dean Stofko, adult in charge, at 730 Franklin Street, Carlisle, Cumberland County, Pennsylvania, its contents and at the same time handing to her personally the said true and correct copy of the same. Brian Barrick, Deputy Sheriff, who being duly sworn according to law, states that on January 03, 2002 at 8:48 o'clock A.M., E.S.T., he posted a true copy of the within Real Estate Writ, Notice, Poster and Description, in the above entitled action, upon the property of Pamela Stofko located at 730 Franklin Street, Carlisle, Pennsylvania, according to law. R. Thomas Kline, Sheriff, who being duly sworn according to law says 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 one of the within named defendants to wit: Pamela Stofko, by regular mail to her last known address of 730 Franklin Street, Carlisle, PA 17013. This letter was mailed under the date of January 18, 2002 and never returned to the Sheriff's Office. R. Thomas Kline, Sheriff, who being duly sworn according to law, says that after due and legal notice had been given according to law, exposed the within described premises at public venue or outcry at the Court House, Carlisle, Cumberland County, Pennsylvania on March 6, 2002 at 10:00 o'clock A.M., E.S.T. He sold the same for the sum of $1.00 to Attorney Martha E. Von Rosenstiel for Manufacturers & Traders Trust Company as trustee for Securitization Series 1948-2, Agreement dated 6f1f98, its successors and assigns. It being the highest bid and best price received for the same, Manufacturers & Traders Trust Company as trustee for Securitization Series 1998-2, Agreement dated 6/1198, its successors and assigns of One M & T Plaza, Buffalo, NY 14203-2399, being the buyer in this execution paid Sheriff R. Thomas Kline the sum of $742.08, it being costs. Sheriffs Costs: Docketing $30.00 Poundage 14.55 Advertising 15.00 Posting Handbills 15.00 Acknowledging Deed 30.00 Auctioneer 10.00 Law Library .50 Prothonotary 1.00 Mileage 6.50 _ _ ~~. _; :~ Certified Mail Levy Surcharge Law Journal Patriot News Share of Bills Distribution of Proceeds Sheriff's Deed 1.63 15.00 20.00 256.10 251.10 24.20 25.00 26.50 $742.08 Paid 3/12/02 Swom and subscribed to before me So Answers• This u,'~' day of ~" " ""~ ~~~ R. Thomas Kline, Sheriff 2002, A.D. ~ j~ ~ ~ ~-/ ~ othonotary ~ BY V.~1 Vyt~:1 Real Estate Deputy 30 ~ I . ~ 35"J'9~f ~. ~~~~q~ Martha E. Von Rosenstiel, P.C. Martha E. Von Rosenstiel 16 South Lansdowne Avenue P.O. Box 457 Lansdowne, PA 19050 610 623-2660 Attorney LD.# 52634 Manufacturers & Traders Trust Company, trustee One M & T Plaza Buffalo NY 14203-2399 Plaintiff vs. Pamela Stofko 730 Franklin Street Carlisle, PA 17013 Defendants Attorney for Plaintiff COURT OF COMMON PLEAS CUMBERLAND COUNTY No: 01-5302 Civil Term AFFIDAVIT OF NOTICE PURSUANT TO RULE 3129.1 COMMONWEALTH OF PENNSYLVANIA: SS COUNTY OF DELAWARE MARTHA E. VON ROSENSTIEL, attorney for the 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 730 Franklin Street, Carlisle, PA 17013. 1. Name and address of owners(s) or reputed owner(s) Pamela Stofko 730 Franklin Street Carlisle, PA 17013 2. Name and address of defendant(s) in the judgment: Pamela Stofko 730 Franklin Street Carlisle, PA 17013 3. Name and address of every judgment creditor whose judgment is a record lien on the real property to be sold: NONE 4. Name and address of the last recorded holder of every mortgage of record: The Pacesetter Corporation 7487 Whitepine Road Chesterfield, Buisness Center Richmond, VA 23237 5. Name and address of every other person who has any record lien on the property: 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: NONE 7. Name and address of every other person of whom plaintiff has knowledge who has any interest in the property which maybe affected by the sale: Family Court/Domestic Relations Office One Courthouse Square Carlisle, PA 17013 Dept. of Public Welfare Box 2675 Hamsburg, 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 aze made subject to the penalties of 18 Pa. C.S. Section 4904 relating to unsworn falsification to authorities. 1VIARTHA E. VON ROSENSTIEL, P.C. ATTORNEY AT LAW 16 SOUTH LANSDOWNE AVENUE P.O. BOX 457 LANSDOWNE, PA 19050 PHONE(610)623-2660 FAX(610)623-2745 October 24, 2001 TO: The Pacesetter Corporation 7487 Whitepine Road Chesterfield, Buisness Center Richmond, VA 23237 RE: NOTICE OF SALE OF REAL PROPERTY: 730 Franklin Street Carlisle, PA 17013 Amount of Judgment: $83,560.97 Date of Judgment: October 26, 2001 Court Term and Number: Court of Common Pleas of Cumberland County, Docket# 01-5302 Civil Term Plaintiff: Manufacturers & Traders Trust Company, trustee Defendants: Pamela Stofko pear Sir/Madam: Please be advised that the property and residential dwelling, located at and known as 730 Franklin Street Cazlisle, PA 17013 will be sold by the Sheriff of Cumberland County on March 6, 2002 at 10:00 a.m. in the Cumberland County Court House, One Court House Squaze, Cazlisle, PA 17013. This notice is being sent to you because my records indicate that you hold a lien on the property secondary to the first mortgage, which is being foreclosed. This property and improvements aze being sold pursuant to a judgment entered as indicated above in favor of the above named plaintiff, and against the above named defendants. The name of the owners, real owners, and reputed owners of the aforementioned property aze Pamela Stoflco. A schedule of distribution will be filed by the Sheriff on a date specified by the Sheriff no later than 30 days after said sale, and distribution will be made in accordance with the schedule unless exceptions are filed thereto within ten (10) days after the date of the filing of said schedule. Xou should check with the Sheriff s Office by calling 717 240-6391 to determine the actual date of the filing of the schedule. Sincerely yours, Von Rosenstiel MARTHA E. VON ROSENSTIEL, P.C. ATTORNEY AT LAW 16 SOUTH LANSDOWNE AVENUE P.O. BOX 457 LANSDOWNE, PA 19050 PHONE(610)623-2660 FAX(610)623-2745 October 24, 2001 TO: Family Court/I)omestic Relations Office One Courthouse Square Cazlisle, PA 17013 RE: NOTICE OF SALE OF REAL PROPERTY: 730 Franklin Street Carlisle, PA 17013 Amount of Judgment: $83,560.97 Date of Judgment: October 26, 2001 Court Term and Number: Court of Common Pleas of Cumberland County, Docket# 01-5302 Civil Term Plaintiff: Manufacturers & Traders Trust Company, trustee Defendants: Pamela Stofko Deaz Sir/Madam: Please be advised that the property and residential dwelling, located at and known as 730 Franklin Street Carlisle, PA 17013 will be sold by the Sheriff of Cumberland County on March 6, 2002 at 10:00 a.m. in the Cumberland County Court House, One Court House Square, Cazlisle, PA 17013. This notice is being sent to you because my records indicate that you hold a lien on the property secondary to the first mortgage, which is being foreclosed. This property and improvements are being sold pursuant to a judgment entered as indicated above in favor of the above named plaintiff, and against the above named defendants. The name of the owners, real owners, and reputed owners of the aforementioned property aze Pamela Stoflco. A schedule of distribution will be filed by the Sheriff on a date specified by the Sheriff no later than 30 days after said sale, and distribution will be made in accordance with the schedule unless exceptions are filed thereto within ten (10) days after the date of the filing of said schedule. You should check with the Sheriff s Office by calling 717 240-6391 to determine the actual date of the filing of the schedule. MARTHA E. VON ROSENSTIEL, P.C. ATTORNEY AT LAW 16 SOUTH LANSDOWNE AVENUE P.O. BOX 457 LANSDOWNE, PA 19050 PHONE(610)623-2660 October 24, 2001 TO: Dept. of Public Welfare Box 2675 Harrisburg, PA 17105 RE: NOTICE OF SALE OF REAL PROPERTY: 730 Franklin Street Carlisle, PA 17013 Amount of Judgment: $83,560.97 Date of Judgment: October 26, 2001 Court Term and Number: Court of Common Pleas of Cumberland County, Docket# 01-5302 Civil Term Plaintiff: Manufacturers & Traders Trust Company, trustee Defendants: Pamela Stofko Dear Sir/Madam: FAX(610)623-2745 Please be advised that the property and residential dwelling, located at and known as 730 Franklin Street Cazlisle, PA 17013 will be sold by the Sheriff of Cumberland County on March 6, 2002 at 10:00 a.m. in the Cumberland County Court House, One Court House Square, Cazlisle, PA 17013. This notice is being sent to you because my records indicate that you hold a lien on the property secondary to the fust mortgage, which is being foreclosed. This property and improvements aze being sold pursuant to a judgment entered as indicated above in favor of the above named plaintiff, and against the above named defendants. The name of the owners, real owners, and reputed owners of the aforementioned property aze Pamela Stoflco. A schedule of distribution will be filed by the Sheriff on a date specified by the Sheriff no later than 30 days after said sale, and distribution will be made in accordance with the schedule unless exceptions are filed thereto within ten (10) days after the date of the filing of said schedule. You should check with the Sheriff s Office by calling 717 240-6391 to determine the actual date of the filing of the schedule. Sincerely yours, on Rosenstiel Martha E. Von Rosenstiel, P.C. Martha E. Von Rosenstiel 16 South Lansdowne Avenue P.O. Box 457 Lansdowne, PA 19050 610 623-2660 Attorney I.D.# 52634 Manufacturers & Traders Trust Company, trustee One M & T Plaza Buffalo, NY 14203-2399 Plaintiff vs. Pamela Stofko 730 Franklin Street Carlisle, PA 17013 Defendant Attorney for Plaintiff COURT OF COMMON PLEAS CUMBERLAND COUNTY No: 01-5302 Civil Term THIS IS AN ATTEMPT TO COLLECT A DEBT ANY INFORMATION OBTAINED WILL BE USED FOR THAT PURPOSE NOTICE OF SHERIFF'S SALE OF REAL PROPERTY TO: Pamela Stofko 730 Franklin Street Carlisle, PA 17013 Your house and/or real estate at 730 Franklin Street, Carlisle, PA 17013 is scheduled to be sold at Sheriff s Sale on March 6, 2002 at 10:00 a.m. to enforce the court judgment of $82,560.97 obtained by Manufacturers & Traders Trust Company, trustee against you. NOTICE OF OWNERS RIGHTS YOU MAY BE ABLE TO PREVENT THIS SHERIFF'S SALE To prevent this Sheriff s Sale you must take IMMEDIATE action: 1. The sale will be cancelled if you pay to Manufacturers & Traders Trust Company, trustee the back payments, late chazges, costs and reasonable attorney's fees due. To find out how much you must pay, you may ca11610 623-2660. 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 contact 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 Sheriff s Sale is not stopped, your property will be sold to the highest bidder. You may find out the bid price by calling 610 623-2660. 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 the 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 ca11610 623-2660. 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 a 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 on a date to be announced by the Sheriff. 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 Schedule of Distribution is posted. 7. You may also have other rights and defenses, or ways of getting your house 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. COURT ADMINISTRATOR 4T" FLOOR CUMBERLAND COUNTY COURT HOUSE CARLISLE, PA 17013 Telephone: 717 240-6200 CLAIM FOI2 EXEMPTION To the Sheriff: I, the above named defendant, claim exemption of property from levy or attachment: (1) From my real property in my possession which has been levied upon, (a) I desire that my $300.00 statutory exemption be set-aside in kind (specify real property to be set-aside in kind): I request a prompt court hearing to determine the exemption. Notice of the hearing should be given to me at (Address) (Telephone Number) I verify that the statements made in this Claim for Exemption are true and correct. I understand that false statements herein are made subject to the penalties of 18 Pa. C.S. Section 4904 relating to unsworn falsification to authorities. Date: Signature THIS CLAIM TO BE FILED WITH THE OFFICE OF THE SHERIFF CUMBERLAND COUNTY COURTHOUSE CARLISLE, PA 17013 717 240-6391 WRIT OF EXECUTION _ (MORTGAGE FORECLOSURE) P.R.C.P. 3180 to 3183 and Rule 3257 Manufacturers and Traders Trust Company, trustee IN THE COURT OF COMMON PLEAS OF CUMBERLAND COUNTY, PENNSYLVANIA vs. Pamela Stoflco WRIT OF EXECUTION (MORTGAGE FORECLOSURE) Commonwealth of Pennsylvania: County of TO THE SHERIFF OF CUMBERLAND COUNTY, PENNSYLVANIA: To satisfy the judgment, interest and costs in the above matter you are directed to levy upon and sell the following described property (specifically describe property below): PREMISES: 730 Franklin Street Carlisle, PA 17013 Amount Due Interest from 10/26/01 to Sale Date @ $32.31per diem Attorney's fees Costs Total No. O1-5302-Civil Term Term, 20. _ _E.D. No. Term, 20-_ _ _A.D. g 83,560.97 as endorsed. Dated Prothonotary, Common Pleas Court of Cumberland County, Penna. (SEAL) By: ` Deputy DESCRIPTION ALL THAT CERTAIN parcel of real estate located in the Besough of Carlisle, County of Cumberland, State of Pennsylvania, more paiiculazly bounded and described in accordance with z survey by Stephen G. Fisher dated September 27, 1588, a copy of which is attached hereto, as follows: BEGINNING u an iron pin in the Western right of way Line of Franklin Street, which pin is located 65 feet South of the Southern curb line of "D" Street; Chence along the said right of way lice South 06 degrees 13 mimates QO seconds West, 85.00 feet to an iron pin is the Northern line of a lfi feet wide alley; thence along said alley North 83 degrees 47 taim:tes 00 seconds West 130.50 feet to an iron pia; thence along lands now or formerly of Theodore H. Hogan, North 06 degrees 13 minutes Da seconds East, 83.68 feet ro an iron pia at the corner of lands nnw or forneriy of Harry A. Gill; thence along the Southern line of said lands South 84 degrees 02 minutes 13 seconds East 44.52 feet to an iron pin; thence continuing along said line South 84 degrees 3i minutes 45 sends East, a distance of 85.98 feet to an iron pia, the place of beginning, IiAVIiIG erected thereon a frame garage and dwelling being known as No. 730 Franklin Stra°t. Tax Parcel a 06-19-1643-331 WRIT OF EXEtrUTION andlor ATTACHMENT COMMONWEALTH OF PENNSYLVANIA) NO. 01-5302 CIVIL 1~ TEPM COUNTY OF CUMBERLAND) CIVIL ACTION - tAW TO THE SHERIFF OF Cumberland COUNTY: To satisfy the debt, interest and costs due Manufacturers & Traders Trust Ccxnpany, trustee PLAINTIFF(S) trnm Pamela Stofko, 730 Franklin Street, Carlisle, PA 17013 (1) You are directed to levy upon the property of the defendant(s) and to sell See Legal Description (2) You are also directed to ariach the property of the defendant(s) not levied upon in the possession of GARNISHEE.{S) as tolbws: and to notHy the garnishee(s) that: (a) an attachment has been issued; (b) the garnishee(s) is/are enjoined from paying any debt to or for the account of the defendant(s) and from delivering any property of the defendant(s) or otherwise disposing thereof; (3) Itpropertyofthedetendant(s)notlevieduponansubjecttoariachmentisioundinthepossessionotarryoneother than a named garnishee, you are directedto noti4y him/herthat he/she has been added as agarnishee and is enjoined as above stated. Amount Due $83,560.97 L.L. $.50 fran 10/27/00 to sale ate at Interest $33 3? -per d;~ Due Prothy 51.00 Ariy`s Comm Ariy Paid $103.25 Plaintiff Paid Date: November 1 2001 REQUESTING PARTY: Name Martha E Von Rosenstiel, Esq. Address: 16 South Lansdowne Avenue Lansdowne, PA 19050 Ariorney for: Plaintiff ., Telephone: 610-623-2660 Supreme Court ID No. 52634 Other Costs Curtis R. Long ~ Prothonotary, C~ivyil)D/i)vision br Y,//1 nom, ~.~ C / ' /i~iil3i6~ -_~-_-- Deputy ~,~ ~~~sg ~ ~ y; ~ u On November 07, 2001, the sheriff levied upon the defendant's interest in the real property situated in Carlisle Borough, Cumberland County, PA, known and numbered as 730 Franklin Street, Carlisle, and more fully described on Exhibit "A" filed with this writ and by this reference incorporated herein. Date: November 07, 2001 By~o~ S. ~~~ Real Estate Deputy ~ ~- :;.. ,~f ~`- ~~ - ~ f ~r ~i~<~ ski"~i~-'- ;(`-:..` '-~.,, } , .~1. ,. _._ 1 __... I I ..... __. _ .... $- l , , V - ~ vy 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 Dauphi in Miscellaneous Book "M", Volume 14, Page 317. ~' ~ n }~ c>\ PUBLICATION " - "` "" - - ............................................................................................... COPY No~AatS~l n 22nd d of Fe ary 2002 A.D. SAL E #25 Terry L Rusegq, Notary P~IIc HeMabu~g, Dauphin CourNy ~_ My Commisslon Expires June g,~ NOTARY PUBLIO Member, PennsyNenia Association of Notaries My commission expires June 6, 2002 CUMBERLAND COUNTY SHERIFFS OFFICE CUMMBERLANDCOUNTYCOURTHOUSE CARLISLE, PA. 17013 r Statement of Advertising Costs To THE PATRIOT-NEWS CO., Dr. For publishing the notice or publication attached hereto on the above stated dates $ 249.60 Probating same Notary Fee(s) $ 1 .50 Total $ 251.10 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 .................................................................... ~ REAL ESTATE SALE No.25 -~ Writ Na 9HOfu302 7, ° ~3`Clvll Term Manufacturers &Tradera - -`-T7FUSf~omppany, trustee Atty: Martha E - a1Af r`ER'.fAIN parcel of real estate in the Borough of Carlisle, County of Sand, Stge of Pennsylvania, more irly buu.7ded and described iri aawrdanx survey by B[ephen G.~isher dated ser =L 1988, a copy of wldch is attach 41N'G of ao yon pin on the Western righ fine_of Franklin Street which pin r i5 f~f South of the soulhem wrb line of 'M; hence along the said right of way !h_0!_degrces 13 minutes 00 unmds ;OOSeeI Win iron pin in the Northam I6,jeet wide alley; thence along said Nr 83 degrees 47 minutes 00 seconds 1,SD fee[1o ao iron pin; thence along . b'. or, formerly of Thmdorc EL Hogan,' degrees !3 minutes W seconds East, [ to ap iron pin at the comer of lands lrfnuiy of Harry q, Gill; thentt along cm line of raid (ands South 84 degrees s 13 samnds East 44,52 feet to an iron e. condnuing along said Gne SouW 64 '„~nutes_~seconds East, a dis[ancx of 't . k an iron pin, the place of NG. erected [hereon a frame garage and eingkrau~n as No. 73H FrankBn Street dU~-19-1643- i -, 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 Cazlisle 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 regulazly issued weekly in the said County, and that the printed notice or publication attached hereto is exactly the same as was printed in the regulaz 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. ~er M. Morgenthal, Editor SWORN TO AND SUBSCRIBED before me this 8 day of FEBRUARY. 2002 E. SNYDER, Notary pudic a Soto, Maebtl ~ Mand15 REAL ESTA1~ SALE MO. 28 Writ No. 2001-5302 Civil Maztufacturers & Traders Trust Company, trustee Vs. Pamela Stofko Atty.: lOlartba E. Von Rosenstiel ALL THAT CERTAIN parcel of real estate located in the Borough of Carlisle, County of Cumberland, State of Pennsylvania, more particu- larly bounded and described in ac- cw~dance with a survey by Stephen G. Fisher dated September 27, 1988. a copy of which is attached hereto, as follows: BEGINNING at an iron pin in the Western right of way line of Franklin Street, which pin is located 65 feet South of the Southern curb line of 'D"Street; thence along the said right of way line South 06 degrees 13 minutes 00 seconds West, 85.00 feet to an iron pin In the Northern line of a 16 feet wide alley; thence along said alley North 83 degrees 47 min- utes 00 seconds West 130.50 feet to an iron pin: thence along lands now or formerly of Theodore H. Hogan. North 06 degrees 13 min- utes 00 seconds East, 83.68 feet to an iron pin at the corner of lands now or formerly of Harry A. Gill; thence along the Southern line of said lands South 84 degrees 02 minutes 13 seconds East 44.52 feet to an iron pin; thence continuing along said line South 84 degrees 31 minutes 45 seconds East, a distance of 85.98 feet to an iron pin. the pierce of beginning. RAVING erected thereon a frame gazage and dwelling being known as No. 730 Franklin Street. Tax Pazcel # 06-19-1643-331. } 4 #8824 MARTHA E. VON MARTHA E. VON 16 SOUTH LANS PO BOX 457 LANSDOWNE, PA Attorney ID # ROSENSTIEL, ROSENSTIEL, ~OWNE AVENUE 19050 52634 Manufacturers & Traders Trust Company, trustee One M & T Plaza Buffalo, NY 14203-2399 Plaintiff, vs. Pamela Stofko 730 Franklin Street Carlisle, PA 17013, Defendant(s) COURT OF COMMON PLEAS Cumberland COUNTY Case No: Ql- S3C`~o~~~LUiI,~~{Li-t-~ CIVIL ACTION -MORTGAGE FORECLOSURE THIS IS AN ATTEMPT TO COLLECT A DEBT ANY INFORMATION OBTAINED WILL BE USED FOR THAT PURPOSE NOTICE Anvlso 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 aze 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 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. Le ban demandado a usted en la Corte. Si usted quiere defenderse de estas demandas expuestas en las paginas siguientes, usted tiene veinte (20) dias de plazo al paz[ir de la fecha de la demanda y la notification. Hate falta a sentaz una compazencia escrita o en persona o con un abogado y entregaz a la Corte en forma escrita sus defensas o sus objeciones a las demandas en contra de su persona. Sea a visado que si usted no se defiende, la cone toms ra medidas y puede continuaz la demanda en contra suya sin previo aviso o notification. Ademas, la torte puede decidir a favor del demandante y requiere que usted cumpla con todas las provisioner de esta demanda. Usted puede perder dinero o sus propiedades o otros de rechos importantes paza usted. LLEVE ESTA DEMANDA A UN ABOGADO INMEDIATAMENTE. SI NO TIENE A$OGADO O SI NO TIENE EL DINERO SUFICIENTE DE PAGAR TAL SERVICIO. VAYA EN PERSONA O LLAME POR TELEFONO A LA OFICINA CUYA DIItECCION SE ENCUENTRA ESCRITA ABAJO PARA AVERIGUAR DONDE SE PUEDE CONSEGUIIt ASISTENCIA LEGAL. 2 LIBERTY AVENUE CARLISLE, PA 17013 717-249-3166 800-990-9108 ESQUIRE Attorney for Plaintiff P.C. i t i MARTHA E. VON ROSENSTIEL, ESQUIRE MARTHA E. VON ROSENSTIEL, P.C. 16 SOUTH LANSDOWNE AVENUE PO BOX 457 LANSDOWNE, PA 19050 Attorney ID# 52634 Manufacturers & Traders Trust Company, trustee One M & T Plaza Buffalo, NY 14203-2399 Plaintiff, vs. Pamela Stofko 730 Franklin Street Carlisle, PA 17013, Defendant(s) Attorney for Plaintiff COURT OF COMMON PLEAS Cumberland COUNTY Case No: ~(-~p~ CIVIL ACTION - MORTGAGE FORECLOSURE THIS IS AN ATTEMPT TO COLLECT A DEBT ANY INFORMATION OBTAINED WILL BE USED FOR THAT PURPOSE 1. Plaintiff is Manufacturers & Traders Trust Company, trustee, a corporation organized and existing under state law, with offices for the conduct of business at One M & T Plaza, Buffalo, NY 14203-2399. 2. Defendant, Pamela Stofko is the mortgagor and real owner of premises 730 Franklin Street, Carlisle, PA 17013, hereinafter described, whose last known address is listed in the caption. 3. Plaintiff brings this action in mortgage foreclosure against defendant, mortgagor and real owner, to foreclose a certain indenture of mortgage made, executed and delivered by the above named defendant, mortgagor and real owner to Ivy Mortgage Corp. on May 29, 1998, which mortgage is recorded in the Office of the Recorder of, Deeds of Cumberland County in Mortgage Book 1459, page 152, secured on premises 730 Franklin Street, Carlisle, PA 17013 a true and correct description of which is attached hereto as Exhibit I. 4. The mortgage has since been assigned to the plaintiff herein. 5. Plaintiff alleges each and every term, condition and covenant in the aforesaid mortgage, and hereby incorporates them herein by reference thereto. 6. The aforesaid mortgage is in default in that monthly installments of principal and interest have not been made conformity with the terms of the mortgage, from March 29, 1001 and each month thereafter, up to and including the present time. 7. Under the terms of the aforesaid mortgage, upon default of payments set forth in the mortgage documents, the entire principal balance and all interest due thereon are collectible forthwith. 8. The following is an itemized statement of the amount due plaintiff under the terms of the aforesaid mortgage: Principal Balance Interest from 02/28/01 to 09/11/01 At $32.31 per diem Accrued late charges to 07/11/01 Late charges from 07/15/01 to 08/15/01 At $32.73 per month Corporate Advances Monthly Inspections from 03/29/01 To 08/29/01 at $15.00 per month Attorney's Fee Title Information Certificate Photostats and Postage Notarizations $69,378.00 $ 6,300.45 $ 317.00 $ 65.46 $ 2,102.96 $ 90.00 $ 3,400.00 $ 350.00 $ 45.00 $ 10.00 ,~ r TOTAL $82,058.87 9. Plaintiff sent to defendant, mortgagor and real owner a combined Notice and Warning of Intention to Foreclose and Notices of Homeowners' Emergency Mortgage Assistance Act of 1983 advising of rights available under the statutes. To date payments have not been received and Act 91 assistance has not been granted although the applicable time periods provided by statute have expired. plaintiff demands judgment for $82,058.87, plus per diem interest at $32.31 from 09/12/01 to the date of judgment plus monthly late charges of $32.73-from 09/15/01 to the date of judgment plus monthly inspection costs of $15.00 from 09/29/01 to the date of judgment and foreclosure and sale of the mortgaged premises plus costs thereon. Martha E. Von Rosenstiel Attorney for Plaintiff ~1 j ~ ~ , VERIFICATION Y verify that the statements made in the foregoing Complaint in Mortgage Foreclosure are true and correct. I understand that false statements herein are made subject to penalties of .l8 Pa C.S. Section 4904 relating to unsworn falsification to authorities. .- by: ~~ Tara Thomas Title: ~p,QEC~L0~5l~/2E' ~ ~y~C/13LI,ST- Dated: ~~~/ T~ J ALI. THAT CERTAIN parcel of real estate located in the Borough of Carlisle, County of Cumberland, State of Pennsylvania, more particularly bounded and described in accordance wiw a survey by Stephen G. Fisher dated September 27, 1988, a copy of which is attached hereto, as follows: IiEGTNNI?r'G at an iron pin in the Western right of way line of Franklin Street, which pin is located 65 feet South of the Southern curb line of "b" Street; thence along the said right of way litre South 06 degrees 13 minutes OD seconds West, 85.00 feet to an iron pin in rho Northern line of a lb feet wide alley; thence along said alley North 83 degrees 47 nunutes 00 seconds 'West 13D.SD feet to an iron pin; thence along lands now or formerlyof Theodore ~H. Hogan, Narth O6 degrees 13 minutes 00 seconds East, 83.68 feat to an iron pin at, the, earner of,lands now or formerly of Harry A. Glll; thence along the Southern line of skid lauds South 84 degrees 02 minutes l3 seconds East 44.52 feet to an iron pin; thence continuing along said line South 84 degrees 31 minutes 45 seconds East, a distance of 85.98 feet to an iron pin,'the plax of beginning, ~, HAVING erected therwn a frame garage and dwelling biting known as No. 730 Franklin Street. Tax Parcel/f 06-19-1643-331 ~3~`~'#ii ~~ ••wa.i BN ~ ffi4Nu v y ,.'- cy _ rt34~ ~~s, i~dl~~&4' --' ` I r ~ '~ ~ ~ o /~~ ~ ~ ~~ ~ `Li {iil ~' t~ ~ J Z ~ ~~ ~ 3r Tv a:1z. ~..... .. _. I __... ,. I, I ,. . t ~ + #8824 Martha E. Von Rosenstiel, P.C. Martha E. Von Rosenstiel 16 South Lansdowne Avenue P.O. Box 457 Lansdowne, PA 19050 610 623-2660 Attorney I.D.# 52634 Manufacturers & Traders Trust Company, trustee One M & T Plaza Buffalo NY 14203-2399 Plaintiff vs. Pamela Stoflco 730 Franklin Street Carlisle, PA 17013 Defendants Attorney for Plaintiff COURT OF COMMON PLEAS CUMBERLAND COUNTY No: 01-5302 Civil Term PRAECIPE TO THE PROTHONOTARY: Enter judgment in the sum of $83,560.97 of the above named plaintiff and against the above named defendants for failure to file an answer the above action in Mortgage Foreclosure within twenty (20) days from date of service of the Civil Action, and assess damages. I hereby certify that the correct addresses of plaintiff and defendants are as follows: Plaintiff: One M & T Plaza Buffalo, NY 14203-2399 Defendants: 730 Franklin Street Carlisle, PA 17013 Martha. Von Rosenstiel Attomey for Plaintiff :~ LL . s .~ Martha E. Von Rosenstiel, P.C. Martha E. Von Rosenstiel 16 South Lansdowne Avenue P.O. Box 457 Lansdowne, PA 19050 610 623-2660 Attorney I.D.# 52634 Manufacturers & Traders Trust Company, trustee One M & T Plaza Buffalo, NY 14203-2399 Plaintiff vs. Pamela Stofko 730 Franklin Street Carlisle, PA 17013 Defendants Attorney for Plaintiff COURT OF COMMON PLEAS CUMBERLAND COUNTY No: 01-5302 Civil Term ASSESSMENT OF DAMAGES TO THE PROTHONOTARY: Kindly assess damages against the above named defendants as per Civil Action in Mortgage Foreclosure, as follows: Total per complaint Additional interest on unpaid balances from 09/12/01 to 10/15/Ol at $32.31 per diem Additional late charges from 09/15/01 to 10/15/Ol at $32.73 per month Additional monthly inspections from 09/29/01 at $15.00 per month Total assessment AND NOW, to wit, this day of $82,058.87 $ 1,421.64 $ 65.46 $ 15.00 E. Von Rosenstiel Attorney for Plaintiff Pro Prothy 2001, damages are assessed as above. Martha E. Von Rosenstiel, P.C. Martha E. Von Rosenstiel 16 South Lansdowne Avenue P.O. Box 457 Lansdowne, PA 19050 610 623-2660 Attorney LD.52634 Manufacturers & Traders Trust Company, trustee One M & T Plaza Buffalo NY 14203-2399 Plaintiff vs. Pamela Stofko 730 Franklin Street Carlisle, PA 17013 Defendant(s) Attorney for Plaintiff COURT OF COMMON PLEAS Cumberland COUNTY No: 01-5302 Civil Term AFFIDAVIT OF NON-MILITARY SERVICE COMMONWEALTH OF PENNSYLVANIA: SS COUNTY OF MONTGOMERY Alvin Siler, being duly sworn according to law deposes and says that the defendants 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; That Pamela Stofko is over 21 years of age and resides at 730 Franklin Street, Carlisle, PA 17013. This verification is made subject to the penalties of 18 Pa.C.S. §4904 relating to unsworn falsification to authorities. 1 n Siler Foreclosure Specialist ~ ~• Martha E. Von Rosenstiel, P.C. Martha E. Von Rosenstiel 16 South Lansdowne Avenue P.O. Box 457 Lansdowne, PA 19050 610 623-2660 Attorney LD.# 52634 Manufacturers & Traders Trust Company, trustee One M & T Plaza Buffalo NY 14203-2399 Plaintiff vs. Pamela Stolko 730 Franklin Street Carlisle, PA 17013 Defendants Attorney for Plaintiff COURT OF COMMON PLEAS CUMBERLAND COUNTY No: 01-5302 Civil Term CERTIFICATION OF SERVICE MARTHA E. VON ROSENSTIEL, ESQUIRE, hereby certifies that she is the attorney for the plaintiff herein, and that service of the Notice under Rule 237.5 in the above matter was made on the defendants on October 4, 2001, as evidenced by the attached postal receipts. This verification is made subject to the penalties of 18 Pa. C.S. Section 4904 relating to unsworn falsification to authorities. Martha E. Von Rosenstiel, Esquire Attorney for Plaintiff DATED: October 24, 2001 .. ...... ._. .._...,.~ _ ,. .___.. ...e i..f -_ p.. r ~~ Martha E. Von Rosenstiel, P.C Martha E. Von Rosenstiel 16 South Lansdowne Avenue P.O. Box 457 Lansdowne, PA 19050 610 623-2660 Attorney I.D.# 52634 Manufacturers & Traders Trust Company, trustee One M & T Plaza Buffalo, NY 14203-2399 Plaintiff vs. Pamela Stofko 730 Franklin Street Carlisle, PA 17013 Defendant Attorney for Plaintiff COURT OF COMMON PLEAS Cumberland COUNTY Case No: 01-5302 Civil Term TO: Pamela Stofko 730 Franklin Street Carlisle, PA 17013 „ Date of Notice:- October 3, 2001 IMPORTANT NOTICE YOU ARE IN DEFAULT BECAUSE YOU HAVE FAILED TO 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 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 S$OULD 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 BAR ASSOCATION U.S. POSTAL S RVICE CERTIFICATE OF MAILING MAY BE USED POR DOMESTIC AND INTERNATIONAL MAIL, DOES NOT PROVIDE FOR INSURANCE-POSTMASTER Received Fr ~RTHAE.VONROSENSTIEI-,P.C. oo~~NF . LANSDOWNE AVE. a~ -0Cj P. 0. BOX 457 J 4 r701 One piece of ordinary mail addressed to: P S PAMELA STOFKO 730 FRANKLIN STREET CARLISLE, PA. 17013 PS Form 3817, I/lar. 198y 7J O~'~ Affix fee herein stamps or meter postage and post mark. Inquire of Postmaster for current (~~ ~~o, ~ N w >~ a Quw>£o 1 ~ s ~. ~ ~ m ~~~ 9 ~] ~Y D tl Q ~~ n lA ~x Q. mac ~r_~ ~. o _ a r - -- -. I_~,. ~.L~ ~ a ., ti Martha E. Von Rosenstiel, P.C. Martha E. Von Rosenstiel 16 South Lansdowne Avenue P.O. Box 457 Lansdowne, PA 19050 610 623-2660 Attorney I.D.# 52634 Manufacturers & Traders Trust Company, trustee One M & T Plaza Buffalo NY 14203-2399 Plaintiff vs. Pamela Stofko 730 Franklin Street Carlisle, PA 17013 Defendants Attorney for Plaintiff COURT OF COMMON PLEAS CUMBERLAND COUNTY No: 01-5302 Civil Term CERTIFICATION I hereby certify that I am the attorney of record for the plaintiff in this action against real property, and further certify that the property is: ( )FHA Tenant Occupied or Vacant ( )Commercial ( ) As a result of a Complaint in Assumpsit (X) That the plaintiff has complied in all respects with Section 403 of the Mortgage Assistance Action Including but not limited to: (a) Service of the notice on defendants (b) Expiration of 30 days since service of the Notice (c) Defendants failure to request or appear at the meeting with the mortgagee or Consumer Counseling Agency (d) Defendants failure to file application with the Homeowners Emergency Assistance Program. I further agree to indemnify and hold harmless the Sheriff for any false statements IVlarthfd"1~. Von Rosenstiel Attorney for Plaintiff herein. Dated: October 24, 2001 _ _ ~~ _ .. ~ ,. r ~~ ~ ,_ 0 ~, ~ y C -~ -~_ ,~ F -~ :~ ar ~'? ~'~ :'- ' -, -~ w~ ~_ L; r ~~ ~ _.J ~~, /S!-JL'~ ~ to ~ ~.s ~~ r PRAECIPE FOR WRIT OF EXECUTION COMMONWEALTH OF PENNSYLVANIA COUNTY OF CUMBERLAND Manufacturers & Traders Trust Company, trustee v. NO. 01-5302 Civil Term Pamela Stofko Praecipe for Writ of Execution TO THE PROTHONOTARY: Issue Writ of Execution in the above matter: AMOUNT DUE $83,560.97 INTEREST from 10/27/00 to SALE DATE At $32.31 per diem $ (Costs to be added) Martha E. Von Rosenstiel Attorney for Plaintiff IIESCRIPTTON ALL THAT CERTAIN parcel of real estate Jocated in the Borough of Cazlisle, County of Cumberland, State of Pennsyivania, more particulazly bounded and described is accordance wirh a survey by Stephen G. FisAer dated September 27, 1988, a copy of which is attached hereto, as follows: BEGINNING az an iron pin in the Western right of way line of Franklin Street, which pin is located 65 feet South of the Southern curb tine of ^T)" Streit; thence along the said right of way lice South 06 degrees 13 minutes OD seconds West, 85.00 feet to as iron pia in the Northern line of a lb feet wide alley; thence along said alley North 83 degrees 47 minutes OD seconds West 130.SD feet to an iron pia; thence along lands now or formerly of Theodore ;i. Hogan, North 06 degrees 13 minutes tXl seconds East, 83.68 feet to an iron.pindt the, corner pf;;lends now or formerly of Harry A. Gill; thence along the Southern line of said lands South 84.degrees 02 minutes 13 seconds East 44.52 feet to an Iran pin; thence continuing along said line South 84 degrees 3I minutes 45 seconds East, a distance of 85.98 feet to ao iron pin, the places of beginning. HAVING erected thereon a frame garage sad dwelling being }sown as No. 730 Franklin Street. Tax Parcel k Ob-19-1643-331 i, (J 7U~ ~~ ^. 1^~y V .~ ~ ~g 1 ~~ 1 ' 1 I= 1 n 1 ~ 1 • "1 ~w ~ ~ ~ ~ ~ „ ~ ~ ~ ~1 1 ~ !~ - ~~ ~ _ ~ -_ , - -~:E~ ~ - ~_ ~ _ _ - ~ Gis I ~ U"~: = __ _ : r ( ..i 1 it ~7 5 -i _ -~ , .A:1 } z:~. j -G Cc~ { ~S ~g .. Martha E. Von Rosenstiel, P.C. Martha E. Von Rosenstiel 16 South Lansdowne Avenue P.O. $ox 457 Lansdowne, PA 19050 610 623-2660 Attorney I.D.# 52634 Manufacturers & Traders Tmst Company, trustee One M & T Plaza Buffalo, NY 14203-2399 Plaintiff Attorney for Plaintiff COURT OF COMMON PLEAS CUMBERLAND COUNTY No: 01-5302 Civil Term vs. Pamela Stofko 730 Franklin Street Carlisle, PA 17013 Defendant TIIIS IS AN ATTEMPT TO COLLECT A DEBT ANY INFORMATION OBTAINED WILL BE USED FOR THAT PURPOSE NOTICE OF SHERIFF'S SALE OF REAL PROPERTY TO: Pamela Stofko 730 Franklin Street Carlisle, PA 17013 Your house and/or real estate at 730 Franklin Street, Carlisle, PA 17013 is scheduled to be sold at Sheriff's Sale on Mazch 6, 2002 at 10:00 a.m. to enforce the court judgment of $82,560.97 obtained by Manufacturers & Traders Trust Company, trustee against you. NOTICE OF OWNERS RIGHTS YOU MAY BE ABLE TO PREVENT THIS SHERIFF'S SALE To prevent this Sheriff's Sale you must take IMMEDIATE action: 1. The sale will be cancelled if you pay to Manufacturers & Traders Trust Company, trustee the back payments, late charges, costs and reasonable attorney's fees due. To find out how much you must pay, you may ca11610 623-2660. 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 contact 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 Sheriff s Sale is not stopped, your property will be sold to the highest bidder. You may find out the bid price by calling 610 623-2660. 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 the 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 ca11610 623-2660. 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 a 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 on a date to be announced by the Sheriff. 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 Schedule of Distribution is posted. 7. You may also have other rights and defenses, or ways of getting your house 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. COURT ADMINISTRATOR 4Tn FLOOR CUMBERLAND COUNTY COURT HOUSE CARLISLE, PA 17013 Telephone: 717 240-6200 r CLAIM FOR EXEMPTION To the Sheriff: I, the above named defendant, claim exemption of property from levy or attachment: (1) From my real property in my possession which has been levied upon, (a) I desire that my $300.00 statutory exemption be set-aside in kind (specify real property to be set-aside in kind): I request a prompt court hearing to determine the exemption. Notice of the hearing should be given to me at (Address) (Telephone Number) I verify that the statements made in this Claim for Exemption are true and correct. I understand that false statements herein are made subject to the penalties of 18 Pa. C.S. Section 4904 relating to unswom falsification to authorities. Date: Signature THIS CLAIM TO BE FINED WITH THE OFFICE OF THE SHERIFF CUMBERLAND COUNTY COURTHOUSE CARLISLE, PA 17013 717 240-6391 ...J~ . .._.. .., I I a.. u¢ - Lz:: , WRIT OF EXECUTION - (MORTGAGE FORECLOSURE) P.R.C.P. 3180 to 3183 and Rule 3257 Manufacturers and Traders Trust Company, trustee IN THE COURT OF COMMON PLEAS OF CUMBERLAND COUNTY, PENNSYLVANIA vs. Pamela Stofko Commonwealth of Pennsylvania: County of No. O1-5302-Civil Term Term, 20_ _ _E.D. No. Term, 20-___A.D. WRIT OF EXECUTION (MORTGAGE FORECLOSURE) TO THE SHERIFF OF CUMBERLAND COUNTY, PENNSYLVANIA: To satisfy the judgment, interest and costs in the above matter you are directed to levy upon and sell the following described property (specifically describe property below): PREMISES: 730 Franklin Street Carlisle, PA 17013 Amount Due Interest from 10/26/01 to Sale Date @ $32.31per diem Attorney's fees Costs Total as endorsed. Dated e 83,560.97 By: (SEAL) Prothonotary, Common Pleas Court of Cumberland County, Penna. Deputy ~~Y .r-AYf~88u+'fr.I~SS sl.~ ~'-~~ ,-._ . ne <kh n 4ffi~1 4S14~A~N3.~Y kbN.31~°Y v ~Sn Q ~. I oz 0 ~' °' ~ o ~ ~, z ~ a w ~.. ~, ~ ~ pW `~ ~, / N ~, H o ~ w v C ~ ~ o ~ --i v A N ti ~, 7" 't7 W N N ~ o ~ ~ >, ~ ~ F ~ ~ w ~ ~ ~ ~ ~ .~ ~ E U ~ ~ ~ N ~ b-0 ~ r. F~ ~ ~ b ~: M CL G-1 F. ~ ~ "~ O + ~ 3 G4 ~ ~ C~ S. a. ~ ~n ;] Z d ~ .. O ~ ~ 3 O ~ b ai cV M ~ v v s, o ~ ~ .. ~ ~ M ~ s ~ O O z W W ~, w ~ ~ ~. ^' ~ .b a W ~.a o~ .~ b r, ~' v z x C! C ~ b1l t.. V] ~ O si Q Q z U ~ U R er V] ~ ~ ~ W ~ '~ ~ . p . U DESCRIPTION ALL THAT CERTAIN parcel of tea! estate located in the Borough of Cazlisle, County of Cur`berland, Stare of Pennsylvania, more parciculazly boandrd and described is accordance with a survey by Stephen G. Fisher dated September 27, 1988, a copy of which is attached hereto, as follows: BEGINNING at an iron pin in the Western right of way line of Franklin Street, which pin is located 65 feet South of the Southern curb line of "D" Street; Chence along the said right of way lira South 06 degrees 13 mimttes 00 seconds West, 83.00 feet to an iron pin in the Northern line of a 16 feet wide alley; thence along said alley Notch 83 degrees 47 minutes 00 seconds West 130.50 fectto an iron pin; thence along lands now or formerly of Theodore II. Hogan, North O6 degrees 13 minutes 00 seconds East, 83.68 feet to an iron pin at the corner of lands now or formerly of I3atry A. Gill; thence along the Southern line of said lands South 84 degrees 02 minutes 13 seconds East 44.52 feet to as iron pin; thence coatiauing along said line South 84 degrees 31 minutes 45 seconds East, a distance of 85.98 feet to an iron pin, the places of beginning. HAVIr`IG erected thereon a frame garage and dwelling being known as No. 730 Franklin Stra°t. Tax Parcel !{ Qb-19-1643-331 :d§wux.'z:!"~- ~~~,.i~k9kil~va 4 he.,x,=, s .:....,-:n ,<.~.,,,.u.-Nr= ... ~ - CJ C3 r-j _" ~4% r.•ir~ _ :~ -, - ,._, _ r C~i -i ~ ~,` ~ '~ =i C ~ -G , ~J .o- { r~r^ VJ Martha E. Von Rosenstiel, P.C. Martha E. Von Rosenstiel 16 South Lansdowne Avenue P.O. Box 457 Lansdowne, PA 19050 610 623-2660 Attorney I.D.# 52634 Manufacturers & Traders Trust Company, trustee One M & T Plaza Buffalo NY 14203-2399 Plaintiff vs. Pamela Stofko 730 Franklin Street Carlisle, PA 17013 Defendants Attorney for Plaintiff COURT OF COMMON PLEAS CUMBERLAND COUNTY No: 01-5302 Civil Term AFFIDAVIT OF NOTICE PURSUANT TO RULE 3129.1 COMMONWEALTH OF PENNSYLVANIA: SS COUNTY OF DELAWARE MARTHA E. VON ROSENSTIEL, attorney for the 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 730 Franklin Street, Carlisle, PA 17013. 1. Name and address of owners(s) or reputed owner(s) Pamela Stofko 730 Franklin Street Carlisle, PA 17013 2. Name and address of defendant(s) in the judgment: Pamela Stolko 730 Franklin Street Carlisle, PA 17013 3. Name and address of every judgment creditor whose judgment is a record lien on the real property to be sold: NONE 4. Name and address of the last recorded holder of every mortgage of record: The Pacesetter Corporation 7A87 Whitepine Road Chesterfield, Buisness Center Richmond, VA 23237 5. Name and address of every other person who has any record lien on the property: 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: NONE 7. Name and address of every other person of whom plaintiff has lrnowledge who has any interest in the property which maybe affected by the sale: Flmily Court/Domestic Relations Office One Courthouse Square Carlisle, PA 17013 Dept. of Public Welfare Box 2675 Harrisburg, PA 17105 I verify that the statements made in this affidavit are true and correct to the best of my personal lrnowledge or information and belief. I understand that false statements herein are made subject to the penalties of 18 Pa. C.S. Section 4904 relating to unsworn falsification to authorities. ~r MARTHA E. VON ROSENSTIEL, P.C. ATTORNEY AT LAW 16 SOUTH LANSDOWNE AVENUE P.O. BOX 457 LANSDOWNE, PA 19050 PHONE(610)623-2660 October 24, 2001 TO: The Pacesetter Corporation 7487 Whitepine Road Chesterfield, Buisness Center Richmond, VA 23237 RE: NOTICE OF SALE OF REAL PROPERTY: 730 Franklin Street Carlisle, PA 17013 Amount of Judgment: $83,560.97 Date of Judgment: October 26, 2001 Court Term and Number: Court of Common Pleas of Cumberland County, Docket# 01-5302 Civil Term Plaintiff: Manufacturers & Traders Trust Company, trustee Defendants: Pamela Stofko Dear Sir/Madam: FAX(610)623-2745 Please be advised that the property and residential dwelling, located at and known as 730 Franklin Street Cazlisle, PA 17013 will be sold by the Sheriff of Cumberland County on Mazch 6, 2002 at 10:00 a.m. in the Cumberland County Court House, One Court House Squaze, Cazlisle, PA 17013. This notice is being sent to you because my records indicate that you hold a lien on the property secondary to the first mortgage, which is being foreclosed. This property and improvements are being sold pursuant to a judgment entered as indicated above in favor of the above named plaintiff, and against the above named defendants. The name of the owners, real owners, and reputed owners of the aforementioned property are Pamela Stofko. A schedule of distribution will be filed by the Sheriff on a date specified by the Sheriff no later than 30 days after said sale, and distribution will be made in accordance with the schedule unless exceptions are filed thereto within ten (10) days after the date of the filing of said schedule. You should check with the Sheriff s Office by calling 717 240-6391 to determine the actual date of the filing of the schedule. Sincerely yours, Von Rosenstiel MARTHA E. VON ROSENSTIEL, P.C. ATTORNEY AT LAW 16 SOUTH LANSDOWNE AVENUE P.O. BOX 457 LANSDOWNE, PA 19050 PHONE(610)623-2660 October 24, 2001 TO: Family Court/Domestic Relations Office One Courthouse Square Carlisle, PA 17013 RE: NOTICE OF SALE OF REAL PROPERTY: 730 Franklin Street Carlisle, PA 17013 Amount of Judgment: $83,560.97 Date of Judgment: October 26, 2001 Court Term and Number: Court of Common Pleas of Cumberland County, Docket# 01-5302 Civil Term Plaintiff: Manufacturers & Traders Trust Company, trustee Defendants: Pamela Stofko Deaz Sir/Madam: FAX(610)623-2745 Please be advised that the property and residential dwelling, located at and known as 730 Franklin Street Cazlisle, PA 17013 will be sold by the Sheriff of Cumberland County on Mazch 6, 2002 at 10:00 a.m. in the Cumberland County Court House, One Court House Square, Carlisle, PA 17013. This notice is being sent to you because my records indicate that you hold a lien on the property secondary to the first mortgage, which is being foreclosed. This property and improvements are being sold pursuant to a judgment entered as indicated above in favor of the above named plaintiff, and against the above named defendants. The name of the owners, real owners, and reputed owners of the aforementioned property are Pamela Stofko. A schedule of distribution will be filed by the Sheriff on a date specified by the Sheriff no later than 30 days after said sale, and distribution will be made in accordance with the schedule unless exceptions aze filed thereto within ten (10) days after the date of the filing of said schedule. You should check with the Sheriff's Office by calling 717 240-6391 to determine the actual date of the filing of the schedule. i - i MARTHA E. VON ROSENSTIEL, P.C. ATTORNEY AT LAW 16 SOUTH LANSDOWNE AVENUE P.O. BOX 457 LANSDOWNE, PA 19050 PHONE(610)623-2660 October 24, 2001 TO: Dept. of Public Welfare Box 2675 Harrisburg, PA 17105 RE: NOTICE OF SALE OF REAL PROPERTY: 730 Franklin Street Carlisle, PA 17013 Amount of Judgment: $83,560.97 Date of Judgment: October 26, 2001 Court Term and Number: Court of Common Pleas of Cumberland County, Docket# 01-5302 Civil Term Plaintiff: Manufacturers & Traders Trust Company, trustee Defendants: Pamela Stofko Dear Sir/Madam: FAX(610)623-2745 Please be advised that the property and residential dwelling, located at and known as 730 Franklin Street Carlisle, PA 17013 will be sold by the Sheriff of Cumberland County on March 6, 2002 at 10:00 a.m. in the Cumberland County Court House, One Court House Square, Carlisle, PA 17013. This notice is being sent to you because my records indicate that you hold a lien on the property secondary to the first mortgage, which is being foreclosed. This property and improvements aze being sold pursuant to a judgment entered as indicated above in favor of the above named plaintiff, and against the above named defendants. The name of the owners, real owners, and reputed owners of the aforementioned property aze Pamela Stofko. A schedule of distribution will be filed by the Sheriff on a date specified by the Sheriff no later than 30 days after said sale, and distribution will be made in accordance with the schedule unless exceptions are filed thereto within ten (10) days after the date of the Filing of said schedule. You should check with the Sheriff s Office by calling 717 240-6391 to determine the actual date of the filing of the schedule. Sincerely yours, on Rosenstiel c_ ~, c? ~~ -'.: '~ !' i ~ _~, ~: ~s ~s v m.~ . _ ~~~~~.; SHERIFF'S RETURN - REGULAR CASE N0: 2001-05302 P COMMONWEALTH OF PENNSYLVANIA: COUNTY OF CUMBERLAND MANUFACTURERS & TRADERS TRUST VS STOFKO PAMELA GERALD WORTHINGTON Sheriff or Deputy Sheriff of Cumberland County,Pennsylvania, who being duly sworn according to law, says, the within COMPLAINT - MORT FORE was served upon PAMELA the DEFENDANT at 1253:00 HOURS, on the 12th day of September, 2001 at 730 FRANKLIN STREET CARLISLE, PA 17013 by handing to PAMELA STOFKO a true and attested copy of COMPLAINT - MORT FORE together with and at the same time directing Her attention to the contents thereof. Sheriff's Costs: Docketing 18.00 Service 3.25 Affidavit .00 Surcharge 10.00 .00 31.25 Sworn and Subscribed to before me this ~ day of ~: Ov ~ ~Cro ~ A . D . ~"'" d ~ ~~~~ Pr ~onotary ~ So Answers: ~~~~ ~~~~ R. Thomas Kline 09/13/2001 MARTHA VON ROSENSTIEL By . n~~ ~ l n / Deputy 5 iff