HomeMy WebLinkAbout01-05374~~
FEDERMAN AND PHELAN, LLP
By: FRANK FEDERMAN, ESQUIItE
IDENTIFICATION NO. 12248
ONE PENN CENTER AT SUBURBAN STATION
1617 JOHN F. KENNEDY BOULEVARD
SUITE 1400
PHILADELPHIA, PA 19103-1814
(Z) s~a_~nnn
GMAC MORTGAGE CORPORATION
500 ENTERPRISE ROAD, SUITE 150
HORSHAM, PA 19044
v.
Plaintiff
AUDREY A. SWEENEY
1146 WEST TRINDLE ROAD
MECHANICSBURG, PA 17055
Defendant(s)
TERM
NO. d I -s.~7y l..~tc~~(, l~i~.r-l
CUMBERLAND COUNTY
**THIS FIItM 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 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 Nofice 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 aze warned that if you fail to
do so the case may proceed without you and a judgment maybe entered against you by the court
without further notice for any money claimed in the Complaint or for any other claim or relief
requested by the Plaintiff. You may lose money or property or other rights important to you.
YOU SHOULD TAKE THIS PAPER TO YOUR LAWYER AT ONCE. IF YOU DO NOT
HAVE A LAWYER OR CANNOT AFFORD ONE, GO TO OR TELEPHONE THE OFFICE
SET FORTH BELOW TO FIND OUT WHERE YOU CAN GET LEGAL HELP.
CUMBERLAND COUNTY
CUMBERLAND COUNTY BAR ASSOCIATION
2 LIBERTY AVENUE
CARLISLE, PA 17013
(717) 249-3166
ATTORNEY FOR PLAINTIFF
COURT OF COMMON PLEAS
CIVIL DIVISION
Loan #:306028550
IF THIS IS THE FIRST 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
THH2TY (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 EXPHtATION 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.
1. Plaintiff is
GMAC MORTGAGE CORPORATION
500 ENTERPRISE ROAD, SUITE 150
HORSHAM, PA 19044
2. The name(s) and last known address(es) of the Defendant(s) are:
AUDREY A. SWEENEY
1146 WEST TRINDLE ROAD
MECHANICSBURG, PA 17055
who is/are the mortgagor(s) and real owner(s) of the property hereinafter described.
On 12/12/97 mortgagor(s) made, executed and delivered a mortgage upon the premises
hereinafter described to ACCUBANC MORTGAGE CORPORATION which mortgage
is recorded in the Office of the Recorder of CUMBERLAND County, in Mortgage Book
No. 1422, Page 182. Said Mortgage was re-recorded on 5/20/98 in Mortgage Book No.
1454, Page 72. By Assignment of Mortgage recorded 7/21/98 the mortgage was assigned
to PLAINTIFF which Assignment is recorded in Assignment of Mortgage Book No. 583,
Page 262.
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 3/1/01 and each month thereafrer are due and unpaid, and by the terms of
said mortgage, upon default in such payments for a period of one month, the entire
principal balance and all interest due thereon are collectible forthwith.
6. The following amounts are due on the mortgage:
Principal Balance $87,255.03
Interest 3,946.89
2/1/01 through 9/1/01
(Per Diem $18.53)
Attorney's Fees 4,000.00
Cumulative Late Charges 154.56
12/12/97 to 9/1/01
Cost of Suit and Title Search Z$Q_QO
Subtotal $96,106.48
Escrow
Credit 0.00
Deficit i,35n ~n
Subtotal $], t 54 70
TOTAL $97,461.18
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. The mortgaged premises is vacant and ahand~ned.
WHEREFORE, PLAINTIFF demands an in rem Judgment against the Defendant(s) in the sum of
$97,461.18, together with interest from 9/1/01 at the rate of $18.53 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.
~~~
/c/ Frank Federman
FRANK FEDERMAN, ESQUIRE
Attorney for Plaintiff
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AlL THOSE CERTAIN tracts of land situate in the Township of Silver Spring,
County of Cumberland and State of Pennsylvania, bounded and described as follows:
TRACT N0. 1
BEGINNING at a point in the center line of the Trindle Road at corner of lands
of J. M. Buffington; thence along the center line of said 7rindIe Road, South
72 degrees 45 minutes West, one hundred sixty-one and six-tenths (161.6} feet to
a point in said center line, being also in the Eastern line of a proposed fifty
(50) foot wide street; thence along the Eastern line of said proposed fifty (50)
foot wide street, North t6 degrees 15 minutes West, two hundred (200}.feet to a
stake; thence along the line of other lands of Forrest S, Brenneman, of which
this is a part, North 72 degrees 45 minutes East, one hundred eighty-two and
three tenths (182.3) feet to a stake in the line of lands of J. M. Buffington;
thence along said line of lands of J. M. Buffington, South 13 degrees 15 minutes
East, two hundred and twenty-seven one-hundredths (200.27) feet to a point in
the center line of the Trindle Road aforesaid, at the place of BEGINNING.
BEING the same premises which Forrest 5. Brenneman and Helen Brenneman, his wife,
by Deed dated November 5, 1959 and recorded December 1, 1959 in the Office of the
Recorder of Oeeds in and for Cumberland County, Pennsylvania, in Deed Book "N",
Volume 19, Page 459, granted and conveyed unto Percy S. Wiliic.ms and Sarah Ruth
Williams, his wife.
TRACT N0. 2
BEGINNING at a point marked by an iron pin in the Northwes;e:r~ corner of other
land of Percy S. Williams and Sarah Ruth Williams, the same being also in the
line dividing said other land of Percy S. Williams and Sarah Ruth Williams r"rom
the Lot herein described, thence extending along the line ~~~ other land of the
Forrest S. Brenneman Estate, of which this is a part, Nor~.h 16 degrees 15 minutes
West, 200.00 feet to an iron pin; thence along the line of land of the same,
North 78 degrees 45 minutes East, 148.67 feet to an iron pin in the line of land
of Coit Plumbing Company, Inc.; thence along the line of said land of Co it
Plumbing Company, Inc., South 32 degrees 34 minutes 20 sec:onr.is East, 132.21 feet
to an iron pin; thence along the line of land of the same: S~:~uth 13 degrees 15
minutes East, 57.06 feet to an iron pin at the Northeastei'r ~:orner of other land
of Percy 5. Williams and Sarah Ruth Williams; thence aloncl t'ie line of said other
land of Percy 5. Williams and Sarah Ruth Williams, South '~I' degrees 45 minutes
West, 182.30 feet to an trot pin in the Northwestern corrner of said ether land cf
Percy S. Williams and Sarah Ruth Williams, at the point anti place of BEGINNING.
BEING Lot No. 2 on the final subdivision plan for Forrest; ~. Brenneman, which
said Plan is recorded in the Cumberland County Recorder's Office in Plan Book
No. 40, at page 98.
BEING the same premises which The Commonwealth National Bc,n<, by Deed dated
September 15, 1981 and recorded October 22, 1986 in the ~;umherland County Recorder
of Deeds Office in Deed Book "P", Volume 29, Page 89, granted and conveyed unto
Percy S-Williams and Sarah Ruth Williams. The said Sarah Ruth Williams died
January 19, 1991 at which time title in fee simple vested by survivorship in
Percy S. Williams, the Grantor herein.
UNDER AND SUBJECT, nevertheless, to easements, restrictions, reservations,
conditions and rights-of-way of record.
PRElIISES: 1146 WEST TRINDLE ROAD
VERIFICATION
KRISTINE WILSON 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.
DATE: "1 ~ ~ ~ ~V
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CASE NO: 2001-05374 P
SHERIFF'S RETURN - REGULAR
COMMONWEALTH OF PENNSYLVANIA:
COUNTY OF CUMBERLAND
GMAC MORTGAGE CORPORATION
VS
SWEENEY AUDREY A
RICHARD SMITH
Sheriff or Deputy Sheriff of
Cumberland County,Pennsylvania, who being duly sworn according to law,
says, the within COMPLAINT - MORT FORE was served upon
SWEENEY AUDREY A
DEFENDANT
the
at 2050:00 HOURS, on the 18th day of September, 2001
at 111 SOUTH CHESTNUT ST
MECHANICSBURG, PA 17055 by handing to
AUDREY SWEENEY
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
Service
Affidavit
Surcharge
So Answers:
18.00 ~~~~
6.50
.00
10.00 R. Thomas Kline
nn
JY .:JV
09/19/2001
FEDERMAN
Sworn and Subscribed to before By:
methis 1$~ day of
r/.~~: .2or~J A.D.
roth~ ota'
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~ GMAC MORTGAGE CORPORATION
Plaintiff,
v.
AUDREY A. SWEENEY
Defendant(s).
CUMBERLAND COUNTY
COURT OF COMMON PLEAS
CIVIL DIVISION
NO.Ol-5374 CIVIL TERM
AFFIDAVIT PURSUANT TO RULE 3129
(Affidavit No. 1)
GMAC MORTGAGE CORPORATION, Plaintiff in the above action, by its attorney, FRANK
FEDERMAN, ESQUIRE, sets forth as of the date the Praecipe for the Writ of Execution was filed the
following information concerning the real property located at ,1146 WEST TRINDLE ROAD,
MECHANICSBURG, PA 17055 .
1. Name and address of Owner(s) or reputed Owner(s):
Name
AUDREY A.SWEENEY
Last Known Address (if address cannot be
reasonably ascertained, please indicate)
111 SOUTH CHESNUT STREET
MECHANICSBURG, PA 17055
2. Name and address of Defendant(s) in the judgment:
AUDREY A. SWEENEY
111 SOUTH CHESNUT STREET
MECHANICSBURG, PA 17055
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)
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None.
4. Name and address of last recorded holder of every mortgage of record:
Name Last Known Address (if address cannot be
reasonably ascertained, please indicate)
CITIFINANCIAL, INC. 6520 CARLISLE PIKE, STE. 155
MECI=IANICSBURG, PA 17055
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
1146 WEST TRINDLE ROAD
MECHANICSBURG, PA 17055
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.
October 29, 2001
DATE FRANK FEDERMAN, ESQUIRE
Attorney for Plaintiff
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FEDERMAN and PHELAN
By: FRANK FEAERMAN
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
Plaintifff,
v.
AUDREY A. SWEENEY
Defendant(s).
ATTORNEY FOR PLAINTIFF
CUMBERLAND COUNTY
COURT OF COMMON PLEAS
CIVIL DIVISION
NO. 01-5374 CIVIL TERM
CERTIFICATION
FRANK FEDERMAN, ESQUIRE, hereby verifies that he is attorney for the Plaintiff in
the above-captioncd matter, and that the premises aze not subject to the provisions of Act 91
because it is:
() an FHA mortgage
() 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
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- GMAC MORTGAGE CORPORATION
-klaintiff,
v.
CUMBERLAND' COUNTY
No. 01-5374 CIVIL TERM
AUDREY A. SWEENEY
Defendant(s).
October 25, 2001
TO: AUDREY A. SWEENEY
111 SOUTH CHESNUT STREET
MECHANICSBURG, PA 17055
* *THIS FIRM /S A DEBT COLLECTOR ATTEMPTING TO COLLECT A DEBT AND ANY INFORMATION -~
OBTA/NED W/LL BE USED FOR THAT PURPOSE. IF YOU HAVE PREVIOUSLYRECEIVED A D/SCHARGE IN ~.
BANKRUPTCY AND THIS DEBT WAS NOT REAFFIRMED, THIS !S NOT AND SHOULD NOT BE CONSTRUED TO BE
ANATTEMPT TO COLLECT A DEBT, BUT ONLYENFORCEMENT OF A LIENAGAINST PROPERTY. *
Your house (real estate) at ,1146 WEST TRINDLE ROAD, MECHANICSBURG. PA 17055,
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, Cazlisle, PA 17013, to enforce the court judgment of
98.461.18 obtained by GMAC MORTGAGE CORPORATION (the mortgagee) against you. If the
Sheriff's sale is postponed, the property will be relisted for the JUNE 5, 2002 Sheriff's Sale.
NOTICE OF OWNER'S RIGHTS
YOU MAY BE ABLE TO PREVENT THIS SHERIFF'S SALE
To prevent this Sheriffs Sale, you must take immediate action:
The sale will be cancelled if you pay to the mortgagee the back payments, late chazges, -;
costs and reasonable attorney's fees due. To find out how much you must pay, you may »y
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 STILLBE:ABLE TO:BA.VE YOUR-PROP"ERO'Y A,ND YOU HAVE•OTHER
RI'(3HTSEVEN-IF'I*TFIE"S'H!E~IFF'SSAI;E;DOES:Tt1KE PLACE
1. If the Sheriffs Sale is not stopped, your property will be sold to the highest bidder. You may
fmd out the price bid by calling (2151563-7000.
2. You maybe able to petition the Court to set aside the sale if the bid price was grossly
inadequate compazed to the value of your property.
3. The sale will go through only if the buyer pays the Sheriff the full amount due in the sale. To
find out if this has happened, you may call (717) 240-6390.
4. If the amount due from the Buyer is not paid to the Sheriff, you will remain the owner of the
property as if the sale never happened.
5. You have the right to remain in the property until the full amount due is paid to the Sheriff
and the Sheriff gives a deed to the buyer. At that time, the buyer may bring legal proceedings to evict
you.
6. You maybe entitled to a share of the money which was paid for your house. A schedule of
distribution of the money bid for your house will be filed by the Sheriff within 30 days of the sale. This
schedule will state who will be receiving that money. The money will be paid out in accordance with
this schedule unless exceptions (reasons why the proposed distribution is wrong) 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
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ALL TFiOS13 CERTAI:^I tracts ofland situate in=tlie Township of Silver Spring, County .of Cumberland
and State 6f °Pcwisglvaaia; <bounded :arid desr3ribed as :follows:
TRACT:NO. 1
BEGINNING aca point irr the°center-line of the Ttindle Road at comer of lands ofl.M. Buffington;
thence along-the center line of..said Trindle Road, South 72 degrees 45 minutes West, one hundred
sixty-one and six-tenths (161.6) feet to a:point in said center line, being also in the Eastern line of a
proposed fifty (50) foot wide street; thence along the Eastern Une of said proposed fifty (50) foot wide
street, North 16 degrees 15 minutes West, two hundred (200) feet to a stake; thence along the line of
other lands of Forrest S. Brenneman, of which this is a part, North 72 degrees 45 minutes Fast, one
hundred eighty-two and three-tenths (182.3) feet to a stake in the line of lands of J. M. Buffington;
thence along said line of lands of J. M. Buffington, South 13 degrees 1S minutes East, two hundred and
twenty-seven one-hundredths {200.27) feet to a point in the center line of the Trindle Road aforesaid,
at the place of beginning.
BEING the same premises which Forrest S. Brenneman and Helen Brenneman, his wife, by Deed dated
November S, 1959 and recorded December 1, 1959 in the Office of the Recorder of Deeds is and for
Cumberland County, Pennsylvania, in Deed Book "N", Volume 19, Page 459, granted and conveyed
unto Percy S. Williams and Sarah Ruth Williams, his wife.
TRACT NO, 2
BEGINNING at a point marked by as iron pin in the Northwestern corner of other land of Percy S.
Williams and Sarah Ruth Williams, the same being also is the line dividing said other land of Percy
S. Williams and Sarah Ruth Williams from the Lot herein desrn'bed, thence extending along the line
of other land of the Forrest S. Brenneman Estate, of which this is a part, North 16 degrees 15
minutes West, 200.00 feet to an iron pin; thence along the line of land of the same, North 78
degrees 45 minutes East, 148.67 feet to an iron pin in the line of Colt Plumbing Company, loc.;
thence along the line of said land of Colt Plumbing Company, Inc., South 32 degrees 34 minutes 20
seconds East, 132.21 feet to an iron pin; thence along the line of land of the same, South 13 degrees
15 minutes East, 57.06 feet to as iron pin at the Northeastern corner of other Land of Pezcy S.
Williams and Sarah Ruth Williams; thence along the tine of said other land of Percy S. Williams
and Sarah Ruth WiUiatns, South 72 degrees 45 minutes West, 182.30 feet to an iron pin in the
Northwestern corner of said other land of Percy S. Williams and Sarah Ruth Williams, at the paint
and place of beginning.
BEING Lot No. 2 en the feral subdivision plan far Forrest S. Brenneman, which said Plan is
recorded in the Cumberland County Recorder's Office in Plan Book No. 40, at page 98.
Map #09-0539-012
TITLE TO SAID PREMISES IS VESTED IN Audrey A. Sweeney, single by Deed from Percy S.
Williams, widower dated 12/12/97, recorded 12/17/97, in Record Book 169, Page 493.
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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
PHILADELPHIA, PA 19103-1814
(2151 563-7000
GMAC MORTGAGE CORPORATION
500 ENTERPRISE ROAD, SUITE 150
HORSHAM, PA 19044
Plaintiff,
v.
AUDREY A. SWEENEY
Defendant(s).
CUMBERLAND COUNTY
COURT OF COMMON PLEAS
CIVIL DIVISION «;
,„
• ~,i.,
NO. 01-5374 CIVIL TERM µ..,
PRAECIPE FOR JUDGMENT FOR FAILURE TO
ANSWER AND ASSESSMENT OF DAMAGES
TO THE PROTHONOTARY:
Kindly enter judgment in favor of the Plaintiff and against AUDREY A. SWEENEY and ,
Defendant(s) for failure to file an Answer to Plaintiffs Complaint within 20 days from service thereof
and for Foreclosure and Sale of the mortgaged premises, and assess Plaintiffs damages as follows:
As set forth in Complaint
Interest from 9/1/01 to 10/25/01
TOTAL
$97,461.18
$1,000.62
$98,461.18
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 Rule 237.1, copy attached.
"~
FRANK F DERMAN, ESQUIltE
Attorney for Plaintiff
DAMAGES ARE HEREBY ASSESSED AS INDICATED. ,~
DATE: ;, ~x r ~ 2pa/ ~ J~-•
PRO PROTHY
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(Rule of Civil Procedure No. 236) -Revised
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IN THE COURT OF COMMON PLEAS OF CUMBERLAND COUNTY, PENNSYLVANIA °~°•
~,,,.
CIVIL ACTION -LAW
GMAC MORTGAGE CORPORATION
500 ENTERPRISE ROAD, SUITE 150 CUMBERLAND COUNTY
COURT OF COMMON PLEAS
Plaintifff, CIVIL DIVISION
v.
NO. 01-5374 CIVIL TERM
AUDREY A. SWEENEY
Defendant(s).
Notice is given that a Judgment in the above-captioned matter has been entered against you on
~~~nr~ . 1 2001 .
DEPUTY
If you have any questions concerning this matter, please contact:
FRANK FEDERMAN, ESQUIRE
Attorney for Plaintiff
ONE PENN CENTER 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 BEAN ATTEMPT TO COLLECT A DEBT, BUT ONLY ENFORCEMENT OF A ~«
LIEN AGAINST PROPERTY.** ;
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
Plaintiff
vs.
AUDREY A. SWEENEY
Defendant(s)
TO: AUDREY A. SWEENEY
111 SOUTH CHESTNUT STREET
MECHANICSBURG,PA 17055
DATE OF NOTICE: OCTOBER 11,2001
ATTORNEY FOR PLAINTIFF
COURT OF COMMON PLEAS
CIVIL DIVISION
CUMBERLAND COUNTY
NO. 01-5374 CIVIL
~ A ~ ,ti, .~ ~ r .,
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
' By: FRANK FEDERMAN
Identification No. 12248
ONE PENN CENTER AT SUBURBAN STATION
1617 JOHN F. KENNEDY BLVD., SUITE 1400
PHILADELPHIA, PA 19103-1814
(2151563-7000
GMAC MORTGAGE CORPORATION
500 ENTERPRISE ROAD, SUITE 150
ATTORNEY FOR PLAINTIFF
CUMBERLAND COUNTY
COURT OF COMMON PLEAS
Plaintiff,
v.
AUDREY A. SWEENEY
Defendant(s).
CIVIL DIVISION
• „~; '
NO.Ol-5374 CIVIL TERM
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VERIFICATION OFNON-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 AUDREY A. SWEENEY is over 18 years of age and resides at ,
111 SQUTH CHESNUT STREET, MECHANICSBURG, PA 17055 .
This statement 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
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PRAECIPE FOR WRIT OF EXECUTION - (MORTGAGE FORECLOSURE)
P.R.C.P.3180-3183
GMAC MORTGAGE CORPORATION
Plaintiff,
v.
AIJDREY A. SWEENEY
No. 01-5374 CIVIL TERM
Defendant(s).
TO THE DIRECTOR OF THE OFFICE OF THE PROTHONOTARY:
Issue writ of execution in the above matter:
Amount Due
Interest from 10/25/01 to 3/6/02
(per diem -16.19)
TOTAL
$98,461.18
$2,136.49 and Costs
$100,597.67
~~
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.
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d~L T~iOSE CERTAIN tracts bf land°situate in the Township of Silver Spring, County of Cumberland
attd State of Penusylvania, bounded and described as.follows:
TRACT NO. 1
BEGINNING at a point in the centerline of-the Trindle Road at corner of lands of J.M. Buffington;
thence along the ce~ttet line of said Trindle Road, South 72 degrees 45 minutes West, one hundred
sixty-one and six-tenths (161.6) feet to a point in said center line, being also is the Eastern line of a
proposed filly (50) .foot wide street thence along the Eastern line of said proposed fifty (50) foot wide
street, North 16 degrees 15 minutes West, two hundred (200) feet to a stake; thence along the line of
other lands of Forrest S. Brenneman, of which this is a part, North 72 degrees 45 minutes East, one
hundred eighty-two and three-tenths {182.3) feet to a stake in the line of lands of 7. M. Buffington;
thence along said line of lands of J. M. Buffmgton, South 13 degrees 15 minutes East, two hundred and
twenty-seven one-hundredths (200.27) feet to a point in the center line of the Trindle Road aforesaid,
at the glace of beginning.
BEING the same premises which Forrest S. Brerneman and Helen Brenneman, his wife, by Aeed dated
November 5, 1959 and recorded December 1, 1959 in the Office of the Recorder of Deeds in and for
Cumberland County, Pennsylvania, in Deed Book "N", Volume 19, Page 459, granted and conveyed
unto Percy S. Williams and Sarah Ruth Williams, his wife.
TRACT NO. 2
BEGINNING at a point marked by an iron pin in the Northwestern corner of other land of Percy S.
Williams and Sarah Ruth Williams, the same being also in the line dividing said other land of Percy
S. Williams and Sarah Ruth Williams from the Lot herein described, thence extending along the line
of other land of the Forrest S. Brenneman Estate, of which this is a part, North 16 degrees 15
minutes West, 200.00 feet to an iron pin; thence along the line of land of the same, North 78
degrees 45 minutes East, ] 48.67 feet to an iron pin in the line of Colt Plumbing Company, Tnc, ;
thence along the line of said land of Colt Plumbing Company, Inc., South 32 degrees 34 minutes 20
seconds East, 132.21 feet to an iron pin; thence along the line of land of the same, South 1.3 degrees
15 minutes East, 57.06 feet to an iron pin at the Northeastern corner of other land of Percy S.
Williams and Sarah Ruth Williams; thence along the line of said other land of Percy S. Williams
and Sarah Ruth Williams, South 72 degrees 45 minutes West, 182.30 feet to an iron pin in the
Northwestern corner of said other land of Percy S. Williams and Sarah Ruth. Williams,. at the point
and place of beginning.
BEING Lot No. 2 on the final subdivision plan for Forrest S. Brenneman, which said Plan is
recorded in the Cumberland County Recorder's Office in Plan Book No. 40, at page 98.
Map #09-0539-012
TITLE TO SAID PREMISES IS VESTED IN Audrey A. Sweeney, single by Deed from Percy S.
Williams, widower dated 12/12!97, recorded 12/17/97, in Record Book 169, Page 493.
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' -AFFIDAVIT OF SERVICE
PLAINTIFF ;GMAC "MORTGAGE CORPORATION
DEFENDANT(S) AUDREY A. SWEENEY
SERVE AUDREY A: SWEENEY AT
111 SOUTHCHESNUTSTREET
MECHANICSBURG, YA 17055
CUMBERLAND COUNTY
No. 01-5374 CIVIL TERM
ACCT=
Type'of Action
-Notice of Sheriff s Sale
Sale Date: MARCH 6, 2002
}~ I SERVED ]~ ~ "„;
Served and made known to l~ 0 C` ~ e J ~ . Sw ~~ N ~. { ,Defendant, on the ~ day of / "" V , 200 1, .iu.-
at/('0~2 ,o'clock,~.m., at ~~ ~ s. ~~e s<uu~ ~ ~ ~~ Ck~. N ~ CS !o U-tK. ~i ,Commonwealth ~---
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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:
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Description: Age (9 ~ Height,L~ Weight~i~ Race~Sex~ Other ~~a'~~S y ~tCer ~^-'Yt
I, l ~D R e N c C. F.. ~2 rt ~y, ~~a competent adult, being duly sworn according to law, depose and state that I personally handed
a true and correct copy of the No 'ce of Sheriff s Sale in the manner as set forth herein, issued in the captioned case on the date and at
the address indicated above.
Sworn to and subscribed AflNE ~' 80H
before me this ~ day ChamDersburp f
of ede~,200ef_ MyC~m~Slatt
Notary: ~ftaa~Jb .-~d,_onO,ai,.s~
On the
Moved
Other:
day of
By:
NOT SERVED
200_, at o'clock _.m, Defendant NOT FOUND because:
Unlmown _ No Answer Vacant
Sworn to and subscnbed
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
Philadelphia, PA 19103-1814
(215)563-7000
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SALE DATE: MARCH 6, 2002
IN THE COURT OF COMMON PLEAS OF CUMBERLAND COUNTY, PENNSYLVANIA
CNIL ACTION -LAW
GMAC MORTGAGE CORPORATION
No.: 01-5374 CIVIL TERM
vs.
AUDREY A. S WEENEY
AFFIDAVIT PURSUANT TO RULE 3129.1
AND RETURN OF SERVICE PURSUANT TO
Pa. RC.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:
1146 WEST TRINDLE ROAD, MECHANICSBURG. PA 17055.
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) ancUor Certified Mail Return Receipt stamped by the U.S. Postal Service is attached
for each notice.
F~ FEDE AN, ES
Attorney for Plaintiff
February 25, 2002
C~MAC MORTGAGE CORPORATION ,
Plaintifff, ,
v.
AUDREY A. SWEENEY
Defendant(s).
CUMBI;RLANI) COUNTY
COURT OF COMMON PLEAS
CIVIL bIVISION
NO.Ol-5374 CIVIL TERM
AFFIDAVTT PURSUANT TO RULE 3129
(Affidavit No. 1)
GMAC MORTGAGE CORPORATION, Plaintiff in the above action, by its attorney, FRANK
FEDERMAN, ESQUIRE, sets forth as of the date the Praecipe for the Writ of Execution was filed the
following information concerning the real property located at ,1146 WEST TRINDLE ROAD,
MECHANICSBURG, PA 17055 .
1. Name and address of Owner(s) or reputed Owner(s):
Name
AUDREY A. SWEENEY
Last Known Address (if address cannot be
reasonably ascertained, please indicate)
111 SOUTH CHESNUT STREET
MECHANICSBURG, PA 17055
2. Name and address of Defendant(s) in the judgment:
AUDREY A. SWEENEY
111 SOUTH CHESNUT STREET
MECHANICSBURG, PA 17055
3. Name and last known address of every judgment creditor whose judgment is a record lien on the real
property to be sold:
Name
None.
Last Known Address (if address cannot be
reasonably ascertained, please indicate)
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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)
CITIFINANCIAL, INC. 6520 CARLISLE PIKE, STE. 155
MECHANICSBURG, PA 17055
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
1146, WEST TRINDLE ROAD
MECHANICSBURG, PA 17055
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.
October 29.2001 .
DATE FRANK FEDERMAN, ESQUIRE
Attorney for Plaintiff
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DATE:
TO: ALL PARTIES IN INTEREST AND CLAIMANTS
NOTICE OF SHERIFF'S SALE
OF REAL PROPERTY
OWNER(S) AUDREY A. SWEENEY
~;u„.,.
PROPERTY: 1146 WEST TRINDLE ROAD ~~
MECHANICSBURG, PA 17055
Improvements: Residential Property
CUMBERLAND COUNTY
The above-captioned property is scheduled to be sold at the Sheriffs Sale on MARCH 6,
2002, at 10:00 a.m. in Cumberland County Courthouse, South Hanover Street, Carlisle, PA . Our
records indicate that you may hold a mortgage or judgment on the property, which maybe extinguished
by the sale. You may wish to attend the sale to protect your interests.
A schedule of Distribution will be filed by the Sheriff on a date specified by the Sheriff
not later than 30 days after sale. Distribution will be made in accordance with the schedule unless
exceptions are filed thereto within 10 days after the filing of the schedule.
LH
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SALE DATE: MARCH 6, 2002
IN THE COURT OF COMMON PLEAS OF CUMBERLAND COUNTY, PENNSYLVANIA
CIVIL ACTION -LAW
GMAC MORTGAGE CORPORATION
(. rry No.:~^0~.1-5374C((!!}}ttIVIL TERM
AUDREY A. SWEENEY
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:
1146 WEST TRINDLE ROAD. MECHANICSBURG, PA 17055.
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) andlor Certified Mail Return Receipt stamped by the U.S. Postal Service is attached
for each notice.
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FRA FEDE AN, ES
Attorney for Plaintiff
February 25, 2002
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IN THE COURT OF COMMON PLEAS OF CUMBERLAND COUNTY,
PENNSYLVANIA
RE: GMAC MORTGAGE CORPORATION ) CIVIL ACTION
vs.
AUDREY A. SWEENEY ) CIVIL DIVISION
NO. 01-5374 CIVIL TERM
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 10/31/01 true and correct copies of the
Notice of Sheriffs sale were served by certificate of mailing to the recorded
lienholders, and any known interested party see Exhibit "A" attached hereto.
Notice of Sale was sent to the Defendant(s) on 10/31/01 by certified mail return
receipt requested see Exhibit "B" attached hereto.
~~~
DATE: April 25, 2002 F ANK FED RMAN, ESQUIRE
Attorney for Plaintiff
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7106 4575 1294 4117 U291
TO: AUllREY A.SWEENEY
11 I SOUTH CHESNL?T STREET
MECHANICSBURG, PA 17055
SENDER: LEO
REFERENCE: SALES (306028550)
RETURN
RECEIPT
SERVICE
Total Pastege R Fees
US Postal Service
Receipt for
Certified Mail
No Insurance Coverage Provided
Do Not Use far International Mail
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GMAC Mortgage Corporation
VS
Audrey A. Sweeney
In The Court of Common Pleas of
Cumberland County, Pennsylvania
Writ No. 2001-5374 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.
Sheriffs Costs:
Docketing
Surcharge
Posting Handbills
Law Library
Prothonotary
Share of Bills
Mileage
Levy
Advertising
Certified Mail
Poundage
Postpone Sale
Law Journal
Patriot News
30.00
20.00
15.00
.50
1.00
24.20
11.70
15.00
15.00
1.63
21.32
20.00
507.20
404.70
$1087.25 paid by attorney
6/06/02
Sworn and subscribed to before me S~ ss ei~ ~,..~F
This '1 `~ day of ~~
R. Tho rmas Kline(,' ~S~he~r~i[ff~
2002, A.D. ' ~ BY ~J ~Jy~u•~"1
Prothonotary Real Estate Deputy
l . J"U
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PROOF OF PUBLICATION OF NOTICE
IN CUMBERLAND LAW JOURNAL
(Under Act No. 587, approved May 16, 1929), P. L.1784
STATE OF PENNSYLVANIA
COUNTY OF CUMBERLAND
ss.
Roger M. Morgenthal, Esquire, Editor of the Cumberland Law Journal, of the County
and State aforesaid, being duly sworn, according to law, deposes and says that the Cumberland
Law Journal, a legal periodical published in the Borough of Carlisle in the County and State
aforesaid, was established January 2, 1952, and designated by the local courts as the official legal
periodical for the publication of all legal notices, and has, since January 2, 1952, been regularly
issued weekly in the said County, and that the printed notice or publication attached hereto is
exactly the same as was printed in the regular editions and issues of the said Cumberland Law
Journal on the following dates,
viz:
JANUARY 25, FEBRUARY 1, 8, 2002
Affiant further deposes that he is authorized to verify this statement by the Cumberland
Law Journal, a legal periodical of general circulation, and that he is not interested in the subject
matter of the aforesaid notice or advertisement, and that all allegations in the foregoing
~r°'* +~~> ~ ~a' :'1a:° ~publicationaretrue.
./'~~,
Roger M. Morgenthal, Editor
SWORN TO AND SUBSCRIBED before me this
8 day of FEBRUARY. 2002
I.~IS E„ ER, May PubOk
Carlisle Paws
My Cornanissbn PASrCh 5,
statemeClts as to tiny, place and c~*actei of .
> asTn't'$ sates lvo. as _
Writ No. 2001-5374 Civil - ~ __, _
GMAC Mortgage Corporation ; - - - _ _ _ ~ -~
vs.
Audrey A. Sweeney
Atty.: Frank Federman
ALL THOSE CERTAIN tracts of
land situate in the Township of Sil-
ver Spring. County of Cumberland
and State of Pennsylvania, bounded
and described as follows:
1RftC'1' NO. 1
BEGINNING at a point in the cen-
ter Itne of the Trlndle Road at cor-
ner of lands of J.M. Buffington;
thence along the center line of said
Trindle Road, South 72 degrees 45
minutes West. one hundred sixty-
one and six-tenths (161.6) feet to a
point in said center line, being also
in the Eastern line of a proposed
fifty (50) foot wide street: thence
along the Eastern line of said pro-
posed fifty (50) foot wide street,
North L6 degrees 16 minutes West.
two hundred (200) feet to a stake:
thence along the line of other lands
of Forrest S. Brenneman, of which
this is a part, North 72 degrees 45
minutes East, one hundred eighty-
two and three-tenths (182.3) feet to
a stake in the line of lands of J. M.
Buffington; thence along sold line
of lands of J. M. Buffington. South
13 degrees 15 minutes East. two htm-
dred and twenty-seven one-hun-
dredtha (200.27) feet to a point in
the center line of the Trindle Road
aforesaid, at the place of begimvng.
BEING the same premises which
Forrest S. Brenneman and Helen
Brenneman, tus wife, by Deed dated
November 5, 1959 and recorded
December 1. 1959 in the Office of
the Recorder of Deeds m and for
Cumberland County. Pennsylvania.
~ in Deed Book "N". Volume 19. Page
459, granted and conveyed unto
Percy S. Williams and Sarah Ruth
_ Wlllsams, his wife.
~aingIe by Deed from Percy 3. Wil-
liama, widower dated 12/12/97,
recorded 12/17/97. in Record Book
169, Page 493.
TRACE NO. 2
BEGINNING at a point mazked
by an stun pin m the Northwestern
corner of other land of Percy S.
Williams and Sarah Ruth Williams,
the same being also in the line di-
viding said other land of Percy S. -
Williams and Sarah Ruth Williams
from the Lot herein described,
thence extending along the Line of
other land of the Forrest 5. Brenne-
man Estate, of which this is a part. _ -
North 16 degrees 15 minutes West.
200,00 feet to an iron pin: thence
along the line of land of the same,
North 78 degrees 45 minutes East.
148.67 feet to an iron pin in the
line of Colt Pltrmbtng Company,
Inc.; thence along the line of said ,
land of Coit Plumbing Company,
Inc., South 32 degrees 34 minutes
20 seconds East. 132.21 feet to an
iron pin: thence along the Iine of
Iand of the same. South 13 degrees
15 minutes East, 57.06 feet to an
iron pin ai the Northeastern corner
of other land of Percy S. Williams
and Sazah Ruth Williams: thence
along the line of said other land of
Percy S. Williams and Sarah Ruth
Williams. South 72 degrees 45 min-
utes Weat, 182.30 feet to an iron
pin in the Northwestern corner of
said other land of Percy S. Williams
and Sarah Ruch Williams, at the
paint and place of beginning.
BEING Lot No. 2 on the final aub-
divlsion plan for Forrest 5. Brenne-
man, which said Ptan is recorded
in the Cumberland County Record-
ers Otfice 1n Plan Book No. 40, at
page 98.
Map #09-0539-0I2.
TITLE TO SAID PREMISES IS
VESTED IN Audrey A. Sweeney.
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
unday 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 Dauphin in Miscellaneous Book "M",
Volume 14, Page 317. 9 e ~ ~ _ _
PUBLICATION
COPY
SALE #26
22nd day of Feblue>•Y 2002 A.D.
Notarial Seal i
Terry L. Ruse@II, Notary Public
Hamsburg, Dauphin County "
bty Gommissiori Expires June a, 200f N TARY PUBLIC
Member, Pennsylvania association or Notarie(~y commission expires June 6, 2002
CUMBERLAND COUNTY SHERIFFS OFFICE
CUMBERLAND COUNTY COURTHOUSE
CARLISLE, PA. 17013
Statement of Advertising Gosts
To THE PATRIOT-NEWS CO., Dr.
For publishing the notice or publication attached
hereto on the above stated dates $ 403.20
Probating same Notary Fee(s) $ 1.50
Total $ 404.70
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 ....................................................................
G(~"pC Mort9a9e Cory.
x rig
N ~ _ ~ of land situate in
CER'fg1Rd tractt Comfy of
p of~SBver 8pdng' bouvded
and Stan of Pennsylvania,
d as follows:
i. S: BEGINNING at a 4oirt in the
tf the Tdndle Road at comet of lands
,Rtngton, thence along the center Bne
d¢dle Road, South~7 qae send six
'est, anc hu¢dredt ins d center line.
t,~ teet to a t" sed fiR,
in the Fasterv Ime oho Pgr ~ ten
wide street; duce
Idegee~,s 5 minutes W two 6und ee
:t to i stake; thence along the line '
ids of Foment S. Brenneman, of whi
RaR: North 72 degree? 45 min„- f182
hty-two nun ~~-- --
wthe line of lands of I.
s South gl3azdehgrees f Smminuus
mdred and- twemY ,seven o¢e. .
D.277 feet to a point m Urel~ of
Idle Road aforesaid' at We p
same Pmmrses ~ w~ hFs°~t yY
dd Ilelen Btoa X59 and rec°tded
November 5,
-{959 m We OEBcz of aWndRCau~rr
t-n -and for Cumber) Volume i9,
s, in Decd Bock "N:u~ Percy S.
~~R WWdli ,his wife.
):2: BEG[NNIN~at a point marY~
tof1°~, $eWilliWaru a°d Sarah Ruth
die sainebein6 also in the lineaod Sdrarah
-land oY Peuy S. Wdliams ~•
hams from the >A,t h~ lmd of
Fending alon6 We hne of other
st 5. Bmmemm Esmu, of which lids is
p.lH1 feet ro m iron pin; Wince along We
,and of the same. North 78 degrees 45 _
pas4 148.67-feet to an uon pin in the
"Colt PlumhinB Cor°panY' f°c.; thence .
he lice rof said lmd of 34 tdinutmcbs 20
Wc„ South 32 degrees i thence
s~ast, 13221 Ecet to m iro¢eP ~nW l3
ter"e' line of land of the sam . iron pin _
315 minutes Eas4 57.06 fcet ro m
illiams and Sarah RnW~Ydlaiams;fWe°ce -.
"'t7ie'line of said other lmd of Pent S.
curs and Sarah Ruth Wdliaivs; South 72
dea 45 mi¢ut~ West, 182.38 feet ro m tro¢
m tTie NoNtwcum comer of ~ Wdliams~at
~p.ronY S. WtWams aal Sarah Ru
BOO ipt No~2 on Wye final subdivision plan
`Poirest S.-Brmtuman, which said Plan u
....,,t t'.omty Recorder's
y~Deed sfrom AYetcy S.
fated 12112~9'I,erewrded
Book l69, Pag
„~, _ _ . i
~ffi,..
GMAC MORTGAGE CORPORATION
Plaintiff,
v.
AUDREY A. SWEENEY
Defendant(s).
CUMBERLAND COUNTY
COURT OF COMMON PLEAS
CIVIL DIVISION
NO.Ol-5374 CIVIL TERM
AFFIDAVIT PURSUANT TO RULE 3129
(Affidavit No. 1)
GMAC MORTGAGE CORPORATION, Plaintiff in the above action, by its attorney, FRANK
FEDERMAN, ESQUIRE, sets forth as of the date the Praecipe for the Writ of Execution was filed the
following information concerning the real property located at ,1146 WEST TRINDLE ROAD,
MECHANICSBURG, PA 17055 .
1. Name and address of Owner(s) or reputed Owner(s):
Name
Last Known Address (if address cannot be
reasonably ascertained, please indicate)
AUDREY A. SWEENEY
111 SOUTH CHESNUT STREET
MECHANICSBURG, PA 17055
2. Name and address of Defendant(s) in the judgment:
AUDREY A. SWEENEY
111 SOUTH CHESNUT STREET
MECHANICSBURG, PA 17055
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)
None.
4. N~lne and address of last recorded holder of every mortgage of record:
Name Last Known Address (if address cannot be
reasonably ascertained, please indicate)
CITIFINANCIAL, INC.
6520 CARLISLE PIKE, STE. 155
MECH?,1`IICSBURG, PA 17055
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
1146 WEST TRINDLE ROAD
MECAANICSBURG, PA 17055
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.
October 29.2001
DATE FRANK FEDE1tMAN, ESQUIRE
Attorney for Plaintiff
y
GMAC 1VIORT:GAGE CORPORATION
Plaintiff,
v.
AIJDREY.A. SWEENEY
Defendant(s).
'CUMBERLAND COUNTY
No: Ol"-5374 CIVIL TERM
October 25, 2001
TO: AUDREY A. SWEENEY
111 SOUTH CHESNUT STREET
MECHANICSBURG, PA 17055
* *THIS FIRM IS A DEBT COLLECTOR ATTEMPTING TO COLLECT A DEBT AND ANY INFORMATION
OBTAINED WILL BE USED FOR THAT PURPOSE. IF YOUHAVE PREVIOUSLYRECElVED ADISCHARGE IN
BANKR UPTCY AND THIS DEBT WAS NOT REAFFIRMED, THIS /S NOT AND SHOULD NOT BE CONSTRUED TO BE
ANATTEMPT TO COLLECT A DEBT, BUT ONLYENFORCEMENT OFA LIENAGAINST PROPERTY **
Your house (real estate) at ,1146 WEST TRINDLE ROAD, MECHANICSBURG, PA 17055,
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, Cazlisle, PA 17013, to enforce the court judgment of
98.461.18 obtained by GMAC MORTGAGE CORPORATION (the mortgagee) against you. If the
Sheriff's sale is postponed, the property will be relisted for the Ji1NE 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: (2151563-7000.
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 STILTy BE.ABLE:TO>SAVE YO- UR'ARrDPERTY AND.YOU'HAVE OTHER
R`IXrFITS'EVEN:'IF THE ~HERIFF'S`iSALE:DOES` TAKE PLACE.
M~
Y11.
~i.
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 (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.
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 m,
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
r
ALL THOSE`CERTAIN:trasts of:landsitu~e in,the Township of Silver Spring, County of Cumberland
and Stafe of l3errnsylvaaia:.bouiided ahd`described as follows:
TRACT NO. 1
BEGINNING. ata: pointain'the center line of the Trindle Road at corner~of..lands of J.M. -Buffington;
thence along the center line. of said> Trindle Road, South 72 degrees 45° minutes West, one hundred
sixty-one and six-tenths (161.6) feetxo a point in said center line, being also is the Eastern line of a
proposed fifty (50) foot wide street; thence along the Eastern line of said proposed fifty (50) foot wide
street, North 16 degrees 15 minutes West, two hundred (200) feet to a stake; thence along the line of
other lands of Forrest S. Brenneman, of which this is a part, North 72 degrees 43 minutes East, one
hundred eighty-two and three-tenths (182.3) feet to a stake in the line of lands of 7. M. Buffington;
thence along said line of lands of 7. M. Buffington, South 13 degrees 15 minutes East, two hundred and
twenty-seven one-hundredths (200.27) feet to a point in the center line of the Trindle Road aforesaid,
at the place of beginning.
BEING the same premises which Forrest S. Brenneman and Helen Brenneman, his wife, by Deed dated
November S, 1959 and recorded December 1, 1939 in the Office of the Recorder of Deeds in and for
Cumberland County, Pennsylvania, in Deed Book "N", Volume 19, Page 459, granted and conveyed
unto Percy S. Williams and Sarah Ruch Williams, his wife.
TRACT NO. 2
BEGINNING at a point marked by as iron pin is the Northwestern corner of ocher land of Percy S.
Williams and Sarah Ruth Williams, the same being also in the line dividing said other land of Percy
S. Williams and Sarah Ruth Williams from the Lot herein described, thence extending along the line
of other land of the Forrest S. Brenneman Estate, of which this is a part, North 16 degrees 13
minutes West, 200.00 feet to an iron pin; thence along the line of land of the same, North 78
degrees 45 minutes East, 148.67 feet to an iron pin in the line of Colt Plumbing Company, Tnc.;
thence along the line of said land of Colt Plumbing Cotnpaay, Inc., South 32 degrees 34 minutes 20
seconds East. 132.21 feet to an iron pin; thence along the lice of land of the same, South 13 degrees
15 minutes East, 57.06 feet [o an iron pin at the Northeastern cower of other Iand of Percy S.
Williams and Sazah Ruth Williams: thence along the line of said outer land of Percy S. Williams
and Sazah Ruth Williams, South 72 degrees 45 minutes West, 182.30 feet to an iron pin in the
Northwestern corner of said other land of Percy S. Williams and Sarah Ruth Williams, at the point
and place of beginning.
BEING Lot No. 2 on the fnral subdivision plan for Forrest S. Breinteman, which said Pian is
recorded in the Cumberland County Recorder's Office in Plan Book No. 40, at page 98.
Map ff09-0539-012
TITLE TO SAID PREMISES TS VESTED IN Audrey A. Sweeney, single by Deed from Percy S.
Williams, widower dated 12/12/97, recorded 12/17/97, in Record Baok 169, Page 493.
WRIT OF EXECUTION and/or ATTACHMENT
COMMONWEALTH OF PENNSYLVANIA)
COUNTY OF CUMBERLAND)
TO THE SHERIFF OF Ctunberland
L.L.
To satisfy the debt, interest and costs due C~'IAC Mortaaae Corporation
from Audrey A. Sweeney 111 South Chestnut St. Mechanicsburg, PA 17055
DEFENDANT(S)
(1) You are directed to levy upon the property of the defendant(s) and to sell_~P r_,agal Description
(2) You are also directed to ariach the property of the defendant(s) not levied upon in the possession of
GARNISHEE{S) 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) Ifpropertyofthedefendant(s)notlevieduponansubjecttoattachmentisfoundinthepossessionofanyoneother
than a named garnishee, you are directed to notify him/herthat he/she has been added as a garnishee and is enjoined as above
stated.
AnauntDue 598,461.18
Interest frart 10/25J01 to 3/6J02 (per
-n=-war-=?m~-`,x-$2,136.49 -Fssts--
Atty's Comm
Atty Paid $106.50 _
Plaintiff Paid
NO. 01-5374 CIVIL ~ TERM
CIVIL ACTION -LAW
$.50
Due Prothy ~ -00
Other Costs
Date: nv,<xa.»nA,- 7., ~nt11 i_ Curtis R. Long
Prothonotary~,-Cyivi~l Division
by ~ o r ~ / ~/(.P2i1er~~-'
Deputy
REQUESTING PARTY:
Name Frank Fedezmatt. Esp.
One Penn Center at Suburban Station
Address: -rE~~-~ohrt F~~~~=~,,...=,a mite 1400
Philadelphia, PA 19103-1814
Attorney for: Plaintiff
Telephone: 215-563-7000
Supreme Court ID No. 12248
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AREAL E~A~ '~~. ~~`c~o2~
On November 14, 2001, the sheriff levied upon the
defendant's interest in the real property situated in
Silver Spring Township, Cumberland County, PA,
known and numbered as 1146 West Trindle Road,
Mechanicsburg, and more fully described on Exhibit "A"
filed with this writ and by this reference incorporated herein.
Date: November 14, 2001
~S
BY~ o d~ ~ ,~m~~n
Rea state Deputy
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PRAECIPE FOR WRIT OF EXECUTION - (MORTGAGE FORECLOSURE)
P.R.C.P.3180-3183
GMAC MORTGAGE CORPORATION CUMBERLAND COUNTY
P-aintiff, ,
v No. 41-5374 CIVII, TERM
AUDREY A. SWEENEY ,
Defendant(s). .
TO THE DIRECTOR OF THE OFFICE OF THE PROTHONOTARY:
Issue writ of execution in the above matter:
Amount Due $98,461.80
Interest from 10/26/01 to 9/4/02 $5,083.66and Costs
(per diem - $16.19)
TOTAL $103,545.46
~~~~~.~~
RANK FED RMAN, ESQUIRE
ONE PENN CENTER at SUBURBAN STATION
SUITE 1400
PHILADELPHIA, PA 19103
Attorney for Plaintiff
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ALL TI3OSE CERTAIN"tracts.of lahd'sitnateiti:the To'wttship:of Silver-Spring, County of Cumberland
and State of Penusylvania;=boundedRattd°desCribed.as follows:
TRACT N0. 1
BEGINNING-at a point in the=center line of the: Trindle Road at corner 'of lands of LM. Buffington;
thence along the center line of said Trindle Road; South 72 degrees 45 minutes West, one hundred
sixty-one and six-tenths (161.6) feet to a point in said center line, being also in the Eastern line of a
proposed fifty (50) foot wide street; thence along the Eastern line ofsaid proposed fifty (50) foot wide
street, North 16 degrees 15 minutes West, two hundred (200) feet to a stake; thence along the line of
other lands of Forrest S. Brenneman, of which this is a part, North 72 degrees 45 minutes East, one
hundred eighty-two and three-tenths (182.3) feet to a stake in the line of lands of J. M. Buffington;
thence along said line of lands of 7. M. Buffington, South 13 degrees 15 minutes East, two hundred and
twenty-seven one-hundredths (200.27) feet to a pointin the center line of the Trindle Road aforesaid,
at the place of beginning.
BEING the same premises which Forrest S. Brenneman and Helen Brenneman, his wife, by Deed dated
November 5, 1959 and recorded December 1, 1959 in the Office of the Recorder of Deeds in and for
Cumberland County, Pennsylvania, in Deed Book "N", Volume 19, Page 459, granted and conveyed
unto Percy S. Williams and Sarah Ruth Williams, his wife.
TRACT NO. 2
BEGINNING at a point marked by an iron pin in the Northwestern corner of other land of Percy S.
Williams and Sazah Ruth Williams, the same being also in the line dividing said other land of Percy
S. Williams and Sarah Ruth Williams from the I.ot herein described, thence extending along the line
of other land of the Forrest S. Brenneman Estate, of which this is a part, North 16 degrees 15
minutes West, 200.00 feet to an iron pin; thence along the line of land of the same, North 78
degrees 45 minutes East, 148.67 feet to an iron pin in the line of Colt Plumbing Company, Inc.;
thence along the line of said land of Colt Plumbing Company, Inc., South 32 degrees 34 minutes 20
seconds East, 132.21 feet to an iron pin; thence along the lice of land of the same, South 13 degrees
15 minutes East, 57.06 feet [o an iron pin at the Northeastern corner of other land of Percy S.
Williams and Sarah Ruth Williams; thence along the line of said other land of Percy S. Williams
and Sarah Ruth WiAiatns, South 72 degrees 45 minutes West, 182.30 feet to an iron pin in the
Northwestern corner of said other land of Percy S. Williams and Sarah Ruth Williams, at the point
and place of beginning.
BEING Lot No. 2 on the final subdivision plan for Forrest S. Brenneman, which said Pian is
recorded in the Cumberland County Recorder's Office in Plan Book No. 40, at page 98.
Map #09-0539-012
TITLE TO SAID PREMISES IS VESTED IN Audrey A. Sweeney, single by Deed from Percy S.
Williams, widower dated 12/12/97, recorded 12/17/97, in Record Book 169, Page 493.
i II,
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FEDERMAN and PHELAN
By: FRANK FEDERMAN
Identification No. 12248
Suite 1400
One Penn Center at Suburban Station
Philadelphia, PA 19103
(215) 563-7000
GMAC MORTGAGE CORPORATION
Plaintiff, .
v.
AUDREY A. SWEENEY
Defendant(s).
ATTORNEY FOR PLAINTIFF
CUMBERLAND COUNTY
COURT OF COMMON PLEAS
CIVIL DIVISION
NO.Ol-5374 CIVIL TERM
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 unswom
falsification to authorities.
FRANK F DERMAN, ESQ
Attorney for Plaintiff
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GMAC MORTGAGE CORPORATION
Plaintiff,
v.
AUAREY A. SWEENEY
Defendant(s).
NO.Ol-5374 CIVIL TERM
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 1146 WEST TRINDLE ROAD
MECHANICSBURG, PA 17055
1. Name and address of Owner(s) or reputed Owner(s):
NAME LAST KNOWN ADDRESS (If address cannot be
reasonably ascertained, please so indicate.)
AUDREY A. SWEENEY 111 SOUTH CHESTNUT STREET
MECHANICSBURG, PA 17055
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
COURT OF COMMON PLEAS
CIVIL DIVISION
None
'4.
5.
6.
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.)
CITIFINANCIAL, INC. 6520 CARLISLE PIKE, SUITE 155
MECHANICSBURG, PA 17055
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
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 1146 WEST TRINDLE ROAD
MECHANICSBURG, PA 17055
Domestic Relations of Cumberland 13 North Hanover Street
County Carlisle, PA 17013
Commonwealth of Pennsylvania p0 Box 2675
pepartment 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 to unsworn falsification to authorities.
June 2002
DATE RANK FE ERMAN, ESQUIltE
Attorney for Plaintiff
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GMAC MORTGAGE CORPORATION
Plaintiff,
v.
AUAREY A. SWEENEY
Defendant(s).
CUMBERLAND COUNTY
No. 01-5374 CIVIL TERM
June 5, 2002
TO: AUDREY A. SWEENEY
111 SOUTH CHESTNUT STREET
MECHANICSBURG, PA 17055
**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 REAFFIl2MED, 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 1146 WEST TRINDLE ROAD, MECHANICSBURG, PA 17055is
scheduled to be sold at the Sheriffs Sale on 9/4/02 at 10:00 a.m. in the Cumberland County Courthouse,
South Hanover Street, Carlisle, PA 17013, to enforce the court judgment obtained by GMAC
MORTGAGE CORPORATION (the mortgagee) against you. If the Sheriff's sale is postponed, the
property willbe relisted for the 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 willbe 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: X215) 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 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
ALL TfIOSE'CERTAIIV.;tracts of`tand. situate in the Township ofSiiver Spring, County of Cumberland
and States of Pennsylvanian: boundetY anYl: descrt'beci: as:follows;
TRACT NO. 1
BEGINNINCr at a point in•the-center line of the Trindle::Road ai corner of lands of J.M. Buffington;
thence along. the center line of said Triadle Road;-South'72 degree's 45 minutes West, one hundred
sixty-one and six-tenths (161.6) feet to a point in said center line'; being also in the Eastern line of a
proposed fifty {50) foot wide street; thence along the Eastern line of said proposed fifty (50} foot wide
street, North 16 degrees 15 minutes West, two hundred (200) feet to a stake; thence along the line of
other lands of Forrest S. Brenneman, of which this is a part, North 72 degrees 45 minutes East, one
hundred eighty-two and three-tenths (182.3) feet to a stake in the line of lands of 7. M. Buffington;
[hence along said line of lands of I. M. Buffington, South 13 degrees 15 minutes East, two hundred and
twenty-seven one-hundredths (200.27) feet to a point in the center line of the Trindle Road aforesaid,
a[ the place of beginning.
BEING the same premises which Forrest S. Brenneman and Helen Brenneman, his wife, by Deed dated
November 5, 1959 and recorded December 1, 1959 in the Office of the Recorder of Deeds in and for
Cumberland County, Pennsylvania, in Deed Baok "N", Volume 19, Page 459, granted and conveyed
unto Percy S. Williams and Sarah Ruth Williams, his wife.
TRACT NO. 2
BEGINMNG at a point marked by an iron pin in the Northwestern corner of other land of Percy S.
Williams and Sarah Ruth Williams, the same being also in the line dividing said other land of Percy
S. Williams and Sarah Ruth Williams from the Lot herein described, thence extending along the line
of other land of the Forrest S. Brenneman Estate, of which this is a part, North 16 degrees 15
minutes West, 200.00 feet to an iron pin; thence along the line of land of the same, North 78
degrees 45 minutes East, 148.67 feet to an iron pin in the line of Colt Plumbing Company, Inc.;
thence along the line of said land of Colt Plumbing Company, Inc., South 32 degrees 34 minutes 20
seconds East, 132.21 feet to an iron pin; thence along the line of land of the same, South 13 degrees
15 minutes East, 57.06 feet to an iron pin at the Northeastern corner of other land of Percy S.
Williams and Sarah Ruth Williams; thence along the line of said other land of Percy S. Williams
and Sarah Ruth Williams, South 72 degrees 45 minutes West, 182.30 feet to an iron pin in the
Northwestern comer of said other land of Percy 5. Williams and Sarah-Ruth Williams, at the point
and place of beginning.
BEING Lot No. 2 on the final subdivision plan for Forrest S. Brenneman, which said Plan is
recorded in the Cumberland County Recorder's Office in Plan Book No. 40, at page 98.
Map N09-0539-012
TITLE TO SAID PREMISES IS VESTED 1N Audrey A. Sweeney, single by Deed from Percy S.
Williams, widower dated 12/12/97, recorded 12/17!97, in Record Book 169, Page 493.
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WRIT OF EXECUTION and/or ATTACHMENT
COMMONWEALTH OF PENNSYLVANIA) NO 01-5374 Civil
COUNTY OF CUMBERLAND) CIVIL ACTION -LAW
TO THE SHERIFF OF Clunberland COUNTY:
To satisfy the debt, interest and costs due GMAC MORTGAGE CORPORATION PLANTIFF(S)
From AUDREY A. SWEENEY, 111 S. CHESTNUT ST, MECHANICSBURG PA 17055.
(1) You are directed to levy upon the property of the defendant(s) and to sell REAL ESTATE
LOCATED AT 1146 W. TRINDLE ROAD, MECHANICSBURG PA 17055 (SEE ATTACHED 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/aze 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 98,461.80 L.L.
Interest 10./26/01 - 9/4/02 @ $16.19/DIEM $5,083.66 Due Prothy $1.00
Atty's Comm % Other Costs
Atty Paid $1206.25
Plaintiff Paid
Date: JiINE 7, 2002 CURTIS R. LONG
Prothonotary, Civil Division
('
By: ~
12EQUESTINGPARTY: p, ,~
SUITE 1400, PHILADELPHIA. PA 19103 - J
Name FRANK FEDERMAN, ESQ.
Address: ONE PENN CENTER @ SUBURBAN STATION
Attorney for: PLAINTIFF
Telephone: (215)563-7000
Supreme Court ID No. 12248
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AFFH)AVIT OF SERVICE
PLAINTIFF GMAC MORTGAGE CORPORATION CUMBERLAND COUNTY
No.01-5374 CIVIL TERM
DEFENDANT(S) AUDREY A. SWEENEY
Type of Action
SERVE AUDREY A. SWEENEY AT -Notice of Sheriff s Sale
111 SOUTH CHESTNUT STREET
MECHANICSBURG, PA 17055 Sale Date: 9/4/02
SERVED
Served and made known to ~ Defendant, on the ~~~ day of ~~~, 200
at _ ~, o'clock~.m., at ~ ` ` L A ~~ ~/~D 11.Y~t t~' ,ilk . M•p(~ ~ ~n~l(1 ~ (`~l Commonwealth
of Pennsylvania, in the manner described below:
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 relationslu
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:
~~'~ •~ n
D1es'cription: Ag/c'~V_~ Height ~ ~~ Weight ~ Race W Sex ~! 1 Other
I, 1J\ • ~C~ l ~ ~ a competent adult, being duly sworn according to law, depose and state that I personally handed
a trne and correct copy of a Notice of Sheriff s Sale in the manner as set forth herein, issued in the captioned case on the date and at
the address indicated above.
Sworn to and subscribed ~//
befor me this ~~ day ~/~/^`,-
of ~ 200. „ e
Notaiy~~jyln ~r, By: r (~'
NOT SERVED
s, 2ooz ~
200_, at o'clock _.m., Defendant NOT FOUND because:
Moved _ Unknown _ No Answer Vacant
Other:
Sworn to and subscribed
before me this ~ day
of ,200 -
Notary: By:
Attorne For Plaintiff
Frank Federman, Esquire - I.D. No. 12248
One Penn Center Suburban Station, Suite 1400
Philadelphia, PA 19103
(215)563-7000
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IN THE COURT OF COMMON PLEAS OF CUMBERLAND COUNTY,
PENNSYLVANIA
RE: GMAC MORTGAGE CORPORATION ) CIVIL ACTION
vs.
AUDREY A. SWEENEY ) CIVIL DIVISION
NO. 01-5374 CIVIL TERM
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 6/6102 true and correct copies of the
Notice of Sheriffs sale were served by certificate of mailing to the recorded
lienholders, and any known interested party see Exhibit "A" attached hereto.
Notice of Sale was sent to the Defendant(s) on 6/6/02 by certified mail return
receipt requested see Exhibit "B" attached hereto.
DATE: July 18.2002 FRANK FEDERMAN, ESQUIRE
Attorney for Plaintiff
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gp; AUDREY A. SWEENEY
i I I 1 SOUTH CHESTNUT STREET
1 MECHAlVICSBURG, PA 17055
SENDER: KMD
REFERENCE: SALES
PS Farm 3800 .lone 2000
RETURN Poste e
RECEIPT Certified Fee
SERVICE
Retum Receip[ Fee
Restricted Detive
Total Postage & Fer
US Postal SeMce
Receipt for
Certified Mail
No Insurance Coverage Provided
Do Not Use for International MaJ
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COMMONWEALTH OF PENNSYLVANIA
COUNTY OF CUMBERLAND } SS:
I, Robert P. Zieeler, Recorder of Deeds in and for said County and State do hereby certify that
the Sheriff s Deed in which Veterans Affairs, Sec is the grantee the same having been sold to said
grantee on the 4th day of Seat A.D., 2002, under and by virtue of a writ Execution issued on the 7th day
of June, A.D., 2002, out of the Court of Common Pleas of said County as of Civil Term, 2001 Number
5374, at the suit of GMAC Mtg Corp against Audrey A Sweeney is duly recorded in Sheriff's Deed
Book No. 253, Page 3693.
IN TESTIMONY WHEREOF, I have hereunto set my hand
and seal of said office this o'( ~O day of
A.D.2002
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GMAC Mortgage Corporation
Vs
Audrey A. Sweeney
In the Court of Common Pleas of
Cumberland County, Pennsylvania
Writ No. 2001-5374 Civil Term
Jason Vioral, Deputy Sheriff, who being duly sworn according to law, states that on June
17, 2002 at 3:11 o'clock PM, 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: Audrey A.
Sweeney, by making known unto Audrey A. Sweeney personally, at 111 South Chestnut Street,
Mechanicsburg, Cumberland County, Pennsylvania, its contents and at the same time handing to
her personally the said true and correct copy of the same.
Robert Bitner, Deputy Sheriff, who being duly sworn according to law, states that on July
10, 2002 at 2:30 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 Audrey A. Sweeney,
located at 1146 West Trindle Road, Mechanicsburg, 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:
Audrey A. Sweeney, by regular mail to her last known address of 111 South Chestnut Street,
Mechanicsburg, PA 17055. This letter was mailed under the date of July 17, 2002 and never
returned to the Sheriff s 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, exposed the within described premises at
public venue or outcry at the Courthouse, Carlisle, Cumberland County Pennsylvania, on
September 4, 2002 at 10:00 o'clock A.M. He sold the same for the sum of $1.00 to Attorney
Frank Federman for Secretary of Veterans Affairs, an Officer of the United States of America. It
being the highest bid and the best price received for the same Secretary of Veterans Affairs, an
Officer of The United States of America of Varo Cleveland (MDP 262 PHI), P.O. Box 99640,
Cleveland, OH 44199, being the buyer in this execution paid Sheriff R. Thomas Kline, the sum
of $1,189.75, it being costs.
Sheriffs Costs:
Docketing $30.00
Poundage 23.32
Posting Handbills 30.00
Advertising 30.00
Acknowledging Deed 30.00
Auctioneer 20.00
Law Library
Prothonotary 1.00
Mileage 13.80
Certified Mail 2.83
Levy 30.00
~ ,
Surcharge 30.00
Law Journal 502.55
Patriot News 366.55
Share of Bills 25.20
Distribution of
Proceeds 25.00
Sheriffs Deed 29.50
$1,189.75 paid by attorney
9/17/02
Sworn and subscribed to before me
This ~ ~-" day of ~ rr.,/,,.
2002, A.D._ ~„ ~~
i thonotary
S~o Answer
"R. hoT " mas Kline, e 2
BY~D
Real Estate eputy
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GMAC MORTGAGE CORPORATION
Plaiptitf,
v. .
AUDREY A. SWEENEY
Defepdapt(s).
CUMBERLAND COUNTY
NO.Ol-5374
AFFIDAVIT PURSUANT TO RULE 3129
(Affidavit No. l)
PLEAS
'S
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 1146 WEST TRINDLE ROAD.
MECHANICSBURG. PA 17055
1. Name and address of Owner(s) or reputed Owner(s):
NAME LAST KNOWN ADDRESS (If address cannot be
reasonably ascertained, please so indicate.)
AUDREY A. SWEENEY 111 SOUTH CHESTNUT STREET
MECHANICSBURG, PA 17055
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.)
CITIFJ[NANCIAL, INC. 6520 CARLISLE PIKE, SUITE 155
MECHANICSBURG, PA 17055
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 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 1146 WEST TRINDLE ROAD
MECHANICSBURG, PA 17055
Domestic Relations of Cumberland 13 North Hanover Street
Connty Carlisle, PA 17013
Commonwealth of Pennsylvania p® gox 2675
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 to unsworn falsification to authorities.
June 5, 2002
DATE RANK FE ERMAN, ESQUIRE
Attorney for Plaintiff
' GMAC MORTGAGE CORPORATION CUMBERLAND COUNTY
Plaintiff, .
~• No. 01-5374 CIVIL TERM
AUDREY A. SWEENEY
Defendant(s).
June 5, 2002
TO: AUDREY A. SWEENEY
111 SOUTH CHESTNUT STREET
MECHANICSBURG, PA 17055
**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 REAFFIl2MED, 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 1146 WEST TRINDLE ROAD, MECHANICSBURG, PA 17055is
scheduled to be sold at the Sheriffs Sale on 9/4/02 at 10:00 a.m. in the Cumberland County Courthouse,
South Hanover Street, Carlisle, PA 17013, to enforce the court judgment obtained by GMAC
MORTGAGE CORPORATION (the mortgagee) against you. If the Sheriff s sale is postponed, the
property will be relisted for the Sheriff s Sale.
YOU MAY BE ABLE TO PREVENT THIS SHEIfIFF'S SALE
To prevent this Sheriffs Sale, you must take immediate action:
I. 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.
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
fmd 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 TffiS 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
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ALL'Y"IIO~Z'CERT:41N`tratts oflhdri_sinrate inthe Toavhship af-Silver Spring, County of Cumberland
and State of Pennsylvania,-~botinderY~and:descn'bed:as Follows: '_ "
TRACT NO. 1
BEGINNING at a point ia~thesxenter line of the Tr-indle::Road at corner of lands of J.M. Buffington;
thence along. [he center line of said Trindle Road`,• Soutli`72. degree's 45 minutes West, one hundred
sixty-one and six-tenths (161.6) feet to a point in said center line, being also in the Eastern line of a
proposed fifty (50) foot wide street; thence along the Eastern line of said proposed fifty (50) foot wide
street, North 16 degrees 15 minutes West, two hundred (200} feet to a stake; thence along the line of
ocher lands oP Forrest S. Bremmeman, of which this is a part, North 72 degrees 45 minutes East, one
hundred eighty-two and three-tenths (182.3) feet to a stake in the line of lands of J. M. Buffington;
thence along said line of lands of J. M. Buffington, South 13 degrees IS minutes East, two hundred and
twenty-seven one-hundredths (200,27) feet to a point in the center line of the Trindle Road aforesaid,
at the place of beginning.
BEING the same premises which Forrest S. Brenneman and Ilelea Brenneman, his wife, by Deed dated
November 5, 1959 and recorded December 1, 1959 in the Office of the Recorder of Deeds in and for
Cumberland County, Pennsylvania, in Deed Book "N", Volume 19, Page 459, granted and conveyed
unto Percy S. Williams and Sarah Ruth Williams, his wife.
TRACT NO. 2
BEGINNING at a point marked by an iron pin in the Northwestern corner of other land of Percy S.
Williams and Sazah Ruth Williams, the same being also in the line dividing said other land of Percy
S. Williams and Sarah Ruth Williams from the Lat herein described, thence extending along the tine
of other land of the Forrest S. Brenneman Estate, of which this is a part, North 16 degrees 15
minutes West, 200.00 feet to an iron pin; thence along the line of land of the same, North 78
degrees 45 minutes East, 148.67 feet to an iron pin in the line of Colt Plumbing Company, Tnc.;
thence along the line of said land of Colt Plumbing Company, Inc., South 32 degrees 34 minutes 20
seconds Eas¢, 132.21 feet to an iron pin; thence along the lice of land of the same, South 13 degrees
15 minutes East, 57.06 feet to an iron pin at the Northeastern corner of other land of Percy S.
Williams and Sarah Ruth Williams; thence along the line of said other land of Percy S. Williams
and Sarah Ruth Williams, South 72 degrees 45 minutes West, 182.30 feet to an iron pin in the
Northwestern corner of said other-land of Percy S. Williams and Sarah-Ruth Williams, at the point
and place of beginning.
BEING Lot No. 2 on the final subdivision plan far Forrest S. Brenneman, which said Plan is
recorded in the Cumberland County Recorder's Office in Plan Book No. 40, at page 98.
Map #09-0539-012
TITLE TO SAID PREMISES IS VESTED IN Audrey A. Sweeney, single by Deed from Percy S.
W illiatns, widower dated 12112/47, recorded 12/ 17/97, in Record Book 169, page 493:
_,~_ ,...
-_ WRIT OF EXECUTION and/or ATTACHMENT
• ,r
COMMONWEALTH OF PENNSYLVANIA) NO O1-5374 Civil `
COUNTY OF CUMBERLAND) CIVIL ACTION -LAW
TO THE SHERIFF OF Gtimiberland COUNTY:
To satisfy the debt, interest and costs due GMAC MORTGAGE CORPORATION PLANTIFF(S)
From AUDREY A. SWEENEY, 111 S. CHESTNUT ST, MECHANICSBURG PA 17055.
(1) You aze directed to levy upon the property of the defendant(s) and to sell REAL ESTATE
LOCATED AT 1146 W. TRINDLE ROAD, MECHANICSBURG PA 17055 (SEE ATTACHED LEGAL
DESCRIPTION.)
(2) You aze 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 gamishee(s) that: (a) an attachment has been issued; (b) the garnishee(s) is/aze 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 aze directed to notify him/her that he/she has been added as a
garnishee and is enjoined as above stated.
Amount Due 98,461.80 L.L.
Interest 10./26/01 - 9/4/02 @ $16.19/DIEM $5,083.66 Due Prothy $1.00
Atty's Comm % Other Costs
Atty Paid $1206.25
Plaintiff Paid
Date: JUNE 7, 2002 CURTIS R. LONG
Prothonotary, Civil Division
By:
REQUESTING PARTY:
Name FRANK FEDERMAN, ESQ.
Address: ONE PENN CENTER @ SUBURBAN STAT..,..
SUITE 1400, PHILADELPHIA PA 19103
Attorney for: PLAINTIFF
Telephone: (215) 563-7000
Supreme Court ID No. 12248
.3§a''9'x>rtrt::: $s9~A~~3s~[,......; ,F. ';: ,,. er:~_'. ,n -r.'itc_:b~:4.aifc't3~GFw`~t'~xT'e~~h~.~' '-s~:~£u&g&~16~B1d'N6 ..... ...
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Real Estate Sale # 54
On June 14, 2002 the sheriff levied upon the
defendant's interest in the real property situated in
Silver Spring Township, Cumberland County,
PA, Known and numbered as 1146 West Trindle
Road, Mechanicsburg, and more fully described on
Exhibit "A" filed with this writ and by this reference
incorporated herein.
Date: June 14, 2002 By: °I ~ ~~ ~ Q
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:11f f3
THE PATRIOT NEWS
THE SUNDAY PATRIOT NEWS
Proof of Publication
UnderAd No. 587, Approved May 16,1929
Commonwealth of Pennsylvania, County of Dauphin} ss
Frank J. Epley being duly sworn according to law, deposes and says:
That he is the 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
Ciiy of Harrisburg, County of Dauphin, State of Pennsylvania, owner and publisher of The Patriot-News and T ie
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 publishrd in
their regular daily and/or Sunday/ Metro editions which appeared on the 23rd and 30th day(s) of July and the 6th
day(s) of August 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 Dauphin in Miscellaneous Book "M",
Volume 14, Page 317.
PUBLICATION ... ..........,~f...`~........................................................
COPY swo ~ f latn day Au a 2002 A.D.
SALE #54 Terry L. Russell, Notary Pu
City Of Hanisburg, Dauphin ,~
My Commission6cpiresJune NCSTARY PUBLIC
lvtember. Pennsylvania Association Of Notaries
My commission expires June 6, 2006
CUMBERLAND COUNTY SHERIFFS OFFICE
CUMBERLAND COUNTY COURTHOUSE
• CARLISLE, PA. 17013
~ Statement of Advertising Costs
To THE PATRIOT-NEWS CO., Dr.
For publishing the notice or publication attached
hereto on the above stated dates $ 364.80
Probating same Notary Fee(s) $ 1.75
Total $ 366.55
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 ....................................................................
Corp. __ __ _
~reY A Sweeney
Frank Federman
._ _. ._ _
ERTAW tracts of land situate N
af', Silver Spring, Couuty o{
Slate of Pennsylvania, bonded
rbLow's:
3EGB`NING at a point in the -
Trindfe Road at comer of lands
a; thence along (he censer line of
4 Saulh 72 degrees 45 mirmtcs
'ted sixty-one and six-tenths
paint in said center line, being _
n line o£ a proposed fifty (50)
h_euce alpng the Fasten line of
(FO) toot wide aheG, North 16
mat. two hundred (200) Feet .
iluug the line of other lands of _
emau, of which thb is a pan,
43. minutes East, one hundred
afendu (182.3) feet to a stake
s of 1. M. BuB'mgton; drenne
-° - L ,ugs. cast two hundred and
vsh one-6~ndredths (200.27) feet m a
the: center line of the Trind(e Road
aktGeplaaaf BEGWNWG.
hc_same_ premises which Forsest S:
u Helen Brcmeman, his wife, by
Id-lbr'ember 5, 1959 and recoMed
L 1959 in the Office of the Recorder of
Land for Cumberland- -County,
da; m Dced Boot. "N', Volume 19, -
gtan(ed and conveyed auto Percy S.
t~~SanJt Ruth Williams, hhs wife,
7.~.-BEGINNWG at a point marked
~pim_the Northwestw comer of other
;rey„5.. Williams and Sarah Ruth
u~ s~ a,a''"e being aLwlulhc line dividing
an~'of Pcry Se_WiBiams and Sarah
ms from the Lot herein described,
iyng along the line of other laud of
Bn:nneman estate, of which this u a
t6 degrcea_IS minutes West, 200,00 -
o pin; thence along the line of land of
Leah 78 degrees 45 minuts East,
to an hoe pin in du Bue of Colt _
mpany, /nc.;_Wcnec along the line of
?m; mcnce along the line of land of
!th _13 degrees 15 minutes FasS ,
tan icon pin at the Northeastern
"find of Percy S. Willams and
dams; thence along We line ofsaid
ucy S. Williams and Sarah Ruth
hJ2 dcgrces 45 minmes West,
au~rpn pin m the Notthwestem
~r~er land of Percy S. Williams and
Lams. a( the point and place of
? °n the Leal subdjrisioo plan for
nnemvr, which said Plan is
Cumberland County Recorder's
Kok No. 40, of page 98,
premises is vested in.4udrey A.
Sy Deed from Pery S, Williams,
.1112/97, recorded 11L17N7, m
~ <
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:
JULY 26, AUGUST 2, 9, 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.
R ger M. Morgenthal, Editor
SWORN TO AND SUBSCRIBED before me this
9 day of AUGUST, 2002®
Ld3 E: SNY
C~Nsie fro,
__ ,
R~i]~I. ESTttiTE SA~i,E NO. 64
Wilt No. 2001=574 C
GMAC Mortgage Corporation
vs.
Audrey A. Sweeney
Atty.: Frank Federman
ALL THOSE CERTAIN tracts of
land situate in the Township of Sil-
ber Spring, County of Cumberland
and State of Pennsylvania; bounded
and described as follows:
TRACT NO. 1
BEGINNING at a point ht the cen-
ter line of the Trindle Road at cor-
ner of lands of J. M. Buffmgton;
thence along the center line of said
Trindle Road, South 72 degrees 45
minutes Weat, one hundred sixty-one
and six-tenths (161.6) feet to a point
in said center line, being also in the
Eastern line of a proposed fifty (50)
foot wide street; thence along the
Eastern line of said proposed fifty
(50) foot wide street, North 16 de-
grees 15 minutes West, two hun-
dred (200) feet to a stake; thence
along the line of other lands of
Forrest 5. Brenneman, of which this
is a part, North 72 degrees 45 min-
utes East, one hundred eighty-two
and three-tenths (182.3) feet to a
stake in the line of lands of J. M.
Buffmgton; thence along said line
of lands of J. M. Buffmgton, South
13 degrees 15 minutes East, two hun-
dred and twenty-seven one-hun-
dredths (200.27) feet to a point in
the center line of the Trindle Road
aforesaid, at the place of begimnng.
BEWG the same premiaea which
Forrest S. Brenneman and Helen
Brenneman, his wife, by Deed dated
November 5, 1959 and recorded De-
cember 1, 1959 in the Office of the
Recorder of Deeda in and for Cum-
berland County, Pennsylvania, in
Deed Hook "N", Volume 19, Page
459, granted and conveyed unto
Percy S. Williams and Sarah Ruth
Williams, h+s wife.
TRACT NO. 2
BEGINNNG at a point mazked
by an iron pia 1n the Northwestern
corner of other land of Perey S.
Williams and Sarah Ruth Williams,
the same being also in the line di-
viding said other land of Percy S.
Williama and Sarah Ruth Williams
from the Lot herein described,
thence extending along the line of
other land of the Forrest S. Brenne-
man Estate, of which this is a part,
North 16 degrees 15 minutes West,
200.00 feet to an iron pin; thence
along the line of land of the same,
North 78 degrees 45 minutes East.
148.67 feet to an iron pin in the
line of Colt Plumbing Company,
Inc.; thence along the line of said
land of Colt Plumbing Company,
Inc., South 32 degrees 34 minutes
20 seconds East, 132.21 feet to an
iron pin; thence along the line of
land of the same, South 13 degrees
15 minutes East, 57.06 feet to an
iron pin at the Northeastern toner
of other land of Percy S. Williams
and Sarah Ruth Williams; thence
along the litre of said other land of
Percy S. Williams and Sarah Ruth
Williams, South 72 degrees 45 min-
utes Weat. 182.30 feet to an iron
pin in the Northwestern corner of
said other land of Percy S. Williams
and Sarah Ruth Williams, at the
point and place of beginning.
BEING Lot No. 2 on the fmal
subdivision plan for Forrest S. Bren-
neman, which said Plan is recorded
in the Cumberland County Record-
er s Office in Plan Hook No. 40, at
page 98.
Map #09-0539-012.
TITLE TO SAID PREMISES IS
VESTED IN Audrey A. Sweeney,
single by Deed fmm Percy S. Wil-
liams, widower dated 12/12/97,
rewrded 12/17/97, in Record Book
169, Page 493.