HomeMy WebLinkAbout01-05457
STATE OF PENNSYLVANIA, t
COUNTY OF CUMBERLAND j ss.
Robert P Ziegler
I~--------------------------------
---°------------------------ Recorder of
Deeds in and for said County and State do~hercby certify that the Sheriffs Deed in which ________________
Citifinancial Mtg Co
---------------------°-------------------------------------------------------------isthe grantee
the same having been sold to said grantee on the _______ 6th------------------------------------ day of
March 2002
---------------------------------------- A. D.,? _----, under and by virtue o(a writ-------_------
29th
----Execution --------------------------issued on the -------------------------------
October 2001
day of __________________________ A. D., _____y out of the Court of Comman Pkac of said County as of
Civil 2001
---------------°--------------...-------------------------------------------------- Term,: .-----
5457 Associates Home Equity CDC Inc
Number--------------~atthesuit of---------------------------------------------------------------
Donna Lee ~cl~grmot~ ~ur}l~a L Pensinger
-----------------------------------against--°-°---------1-- iam---- onic-er---------------- 's
273
dulyre~rdedinSheriffaDeedBookNo._______ 252, Page____________.
IN TESTIMONY WHEREOF, I have hereunto
set my hand and sea{ of said office this ___ ~ ___- day
of --------~~~ --~f------------- A. D., ~ ~"~
--- ----- ----- - -- - - - ------
'`/''~ v Recorder of Deeds
Associates Home Equity Consumer
Discount Company, Inc.
VS
Donna Lee McDermott, Lurilla L.
Pensinger and William E. Donicker
In The Court of Common Pleas of
Cumberland County, Pennsylvania
Writ No. 2001-5457 Civil Term
Michael Warrick, Deputy Sheriff, who being duly sworn according to law, states
that on Povember 06, 2001 at 11:28 o'clock A.M., EST, he served a true copy of the
within Real Estate Writ, Notice and Description, in the above entitled action, upon one of
the within named defendants, to wit: Donna Lee McDermott, by making known unto
Donna Lee McDermott personally, at 1501 Williams Grove Rd., Lot #4, Mechanicsburg,
Cumberland County, Pennsylvania, its contents and at the same time handing to her
personally the said true and correct copy of the same.
Michael Warrick, Deputy Sheriff, who being duly sworn according to law, states
that on November 06, 2001 at 11:44 o'clock A.M., EST, he served a true copy of the
within Real Estate Writ, Notice and Description, in the above entitled action, upon one of
the within named defendants, to wit: Lurilla L. Pensinger, by making known unto Lurilla
L. Pensinger personally, at 9 Walnut Lane, Mechanicsburg, Cumberland County,
Pennsylvania, its contents and at the same time handing to her personally the said true
and correct copy of the same.
Michael Warrick, Deputy Sheriff, who being duly sworn according to law, states
that on November 06, 2001 at 11:44 o'clock A.M., EST, he served a true copy of the
within Real Estate Writ, Notice and Description, in the above entitled action, upon one of
the within named defendants, to wit: William E. Donicker, by making known unto
Lurilla L. Pensinger, adult in charge, at 9 Walnut Lane, Mechanicsburg, Cumberland
County, Pennsylvania, its contents and at the same time handing to her personally the
said true and correct copy of the same.
I{enneth Gossert, Deputy Sheriff, who being duly sworn according to law, states
that on January 03, 2002 at 4:55 o'clock P.M., E.S.T., he posted a true copy of the within
Real Estate Writ, Notice, Poster and Description, in the above entitled action, upon the
property of Donna Lee McDermott, Lurilla L. Pensinger and William E. Donicker
located at 1330 Williams Grove 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: Donna Lee McDermott, by regular mail to her last known address of
1501 Williams Grove Rd., Lot #4, Mechanicsburg, PA 17055. This letter was mailed
under the date of Januazy 18, 2002 and never returned to the Sheriff's Office.
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: Lurilla L. Pensinger, by regulaz mail to her last known address of 9
Walnut Lane, Mechanicsburg, PA 17055. This letter was mailed under the date of
January 18, 2002 and never returned to the Sheriff s Office.
K. 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: William E. Donicker, by regular mail to his last known address of 9
Walnut Lane, Mechanicsburg, PA 17055. This letter was mailed under the date of
January 18, 2002 and never returned to the Sheriff's Office.
r. Thomas Kline, Sheriff, who being duly sworn according to law, says that after
due and legal notice had been given according to law, exposed the within described
premises at public venue or outcry at the Court House, Carlisle, Cumberland County,
Pennsylvania, on March 6, 2002 at 10:00 o'clock A.M., EST. He sold the same for the
sum of $1.00 to Attorney Frank Federman for Citifinancial Mortgage Company. It being
the highest bid and best price received for the same, Citifinancial Mortgage Company of
1111Northpoint Drive, Coppell, TX 75019, being the buyer in this execution, paid Sheriff
R. Thomas Kline the sum of $1,000.00, it being costs.
Sheriffs Costs:
Docketing $30.00
Poundage 3.93
Posting Bills 15.00
Advertising 15.00
Acknowledging Deed 30.00
Auctioneer 10.00
Law Library .50
Prothonotary 1.00
Mileage 18.85
Certified Mail 2.32
Levy 15.00
Surcharge 40.00
Law Journal 395.60
Patriot News 347.10
Share of Bills 24.20
Distribution of
Proceeds 25.00
Sheriffs Deed 26,50
$1,000.00
paid by attorney
5/29/02
Sworn and subscribed to before me S~s eri~~ ~~.iu"t"'r
This ~ day of
R. Thomas Kline, Sheriff
2002, A.D. - Y~~~~ (~C,(.t,` ~lV~li~
r honotary B
Real Es ate Deputy a ~ „d
~o ~a ~ tom" I
s,SSOCIATES HOME EQUITY CONSUMER
~ISCOUNT: COMPANY, INC.
~"' ~
Plainiiff,
v.
DONNA LEE MCDERMOTT
LURILLA L. PENSINGER,AND WILLIAM E.
DONICKER
Defendant(s).
CUMBERLAND COUNTY
COURT OF COMMON PLEAS
CIVIL DIVISION
NO.Ol-5457 CIVII. TERM
AFFIDAVIT PURSUANT TO RULE 3129
(Affidavit No. l)
ASSOCIATES HOME EOUITY CONSUMER DISCOUNT COMPANY. INC., 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 1~ 330
WMS GROVE ROAD. MECHANICSBURG, PA 17055.
1. Name and address of Owner(s) or reputed Owner(s):
Name
DONNA LEE MCDERMOTT
LURILLA L. PENSINGER
WILLIAM E. DONICKER
Last Known Address (if address cannot be
reasonably ascertained, please indicate)
1330 WMS GROVE ROAD
MECHANICSBURG, PA 17055
9 WALNUT LANE
MECHANICSBURG, PA 17055
9 WALNUT LANE
MECHANICSBURG, PA 17055
2. Name and address of Defendant(s) in the judgment:
DONNA LEE MCDERMOTT
LURILLA L. PENSINGER
WILLIAM E. DONICKER
1330 WMS GROVE ROAD
MECHANICSBURG, PA 17055
9 WALNUT LANE
MECHANICSBURG, PA 17055
9 WALNUT LANE
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.
~n ,
f .-
.-.
~""`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 6y 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)
TenanUOccupant
Domestic Relations of Cumberland County
Commonwealth of Pennsylvania
Department of Welfare
1330 WMS GROVE ROAD
MECHAlYICSBURG, PA 17055
13 North Hanover Street
Carlisle, PA 17013
PO Box 2675
Harrisburg, PA 17105
I verify that the statements made in this affidavit aze true and correct to the best of my personal
knowledge or information and belief. I understand that false statements herein aze made subject to the
penalties of 18 Pa. C.S. Sec. 4904 relating to unswom falsification to authorities.
October 25, 2001
DATE FRANK FEDERMAN, ESQUIRE
Attorney for Plaintiff
ASSOCIATES HOME EQUITY
' DISCfJUNT•COMPANY,INO.
Plaintiff,
v.
DONNA I.EE 1VICDERMOTT
LURILI:A L. PENSINGER AND WILLIAM E.
D01vICKER
Defendant(s).
CUMBERLAND-COUNTY
No. 01-5457 CIVIL TERM
October 25, 2001
TO: DONNA LEE MCDERMOTT
1330 WMS GROVE ROAD
MECHANICSBURG, PA 17055
LURILLA L. PENSINGER AND WILLIAM E. DONICKER
9 WALNUT LANE
MECHANICSBURG, PA 17055
* *THIS FIRM IS A DEBT COLLECTOR ATTEMPTING TO COLLECT A DEBT AND ANYINFORMATION
OBTAINED WILL BE USED FOR THAT PURPOSE. !F YOU HAVE PREVIOUSLYRECEIVED A D/SCHARGE IN
BANKR UPTCYAND THIS DEBT WAS NOT REAFFIRMED, THIS IS NOT AND SHOULD NOT BE CONSTRUED TO BE
AN ATTEMPT TD COLLECT A DEBT, BUT ONLY ENFORCEMENT OF A LIEN AGAINST PROPERTY.
Your house (real estate) at ,1330 WMS GROVE 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, Carlisle, PA 17013, to enforce the court judgment of 177,541.08 obtained by '
ASSOCIATES HOME EQUITY CONSUMER DISCOUNT COMPANY, INC. (the mortgagee) against you. ~',
If the Sheriff's sale is postponed, the property will be relisted for the JUNE 5, 2002 Sheriffls Sale. -
NOTICE OF OWNER'S RIGHTS
YOU MAY BE ABLE TO PREVENT THIS SHERIFF'S SALE
To prevent this Sheriffs Sale, you must take immediate action:
The sale will be cancelled if you pay to the mortgagee the back payments, late charges,
costs and reasonable attorney's fees due. To find out how much you must pay, you may
call: (215) 563-7000.
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.)
s
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 X215) 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 THAT CERTAIN piece or parcel of ground, situate in the Township of Momrce, County of
Cumberland and State of Pennsylvania, more particu]arly bounded and described as follows, to wit:
BEGINNING at a point on the Western right-of-way line of the Williams Grrove Road, at corner of
Green Lane, as shown on the Plan of Lots hereinafter mentioned; thence by the right-of-way Iiae of
the Williams Grove Road, South 00 degrees II minutes I1 seconds West, two hundred twenty-five
and twenty-four hundredths (225.24) fees to a point; thence by the dividmtg line between Lots Nos. 1
and 2 on said Plan, South 87 degrees 32 minutes 12 seconds West, nine hundred eighty and fifty-
one hundredths (980.51) feet to a point; thence North 00 degrees 28 minutes 00 seconds East, two
hundred twenty-five and nvenry-nine hundredths (225.29) feet w a point oa the Southern line of
Green Lane; thetue by the Southern tine of Green Lane, North 87 degrees 32 minutes 12 seconds
East, nine hundred seventy-nine and forty hundredths (979.40) feet to a point, the place of
BEGINNING.
BEING Lot No. 1 im rite Plan of Lots of Frank E. Stoner, as recorded in Plan Book Q36, at Page
106, Cutnberlaad County Recorder of Deed's Office.
SUBJECT to setback lines as shown on said Plan.
HAVING thereon erected a dwelling kmawn as 1330 Williams Grove Road.
TAX PARCEL NUIv1BER: 22-11-0278-078
~,~TO SAID PREMISES IS VESTED IN Ltrrillia L. Pensiitger and Donna Lee McDermott, as
joint tenants with right of survivorship by reason of the foAowiag:
BEING the same premises which Rosemary Marie Stoner, a single person by Deed dated 9!24!98
and recorded 12/2!99 im the County of Cumberland in Record Book 212 Page 490 conveyed unto
William E. Dotriciter and LuriIIa L. Pensiuger, both single persons as joint tenants and Dattna Lee
McDermott.
AND ALSO BEING the same premises which William E. Donicker and Luril~a L. Pensinger and
Donna Lee McDermott by Deed dated 10/25/00 and recorded 10125/00 In the County of
Cumberland in Record Book 232 Page 278 conveyed unto Ltnillia L. Pensinger and Donna Lee
McDermott, as joint tenants with right of survivorship.
WRIT OF EXECUTION: andlor ATTACHMENT
COMMONWEALTH OF PENNSYLVANIA) NO. O1-5457 CIVIL 1~ TEId~I
COUNTY OF CUMBERLAND) CIVIL ACTION -LAW
TO THE SHERIFF OF Cturtberland COUNTY:
To satisfy the debt, interest and costs due nccnn; ataa u,,,,P F.,,,; tv nn r Discount
rw,,,..,~.a~r~lATc .-_ PLAINTIFF(S)
from Donna Lee McDermott, 1330 Williams Grove Road, Mechanicsburg, PA 17055
Lurilla L. Pensinger and William E. Donicker, 9 Walnut Lane, Mechanicsburg, PA 17055
DEFENDANT(S)
(1) You are directed to levy upon the property of the defendant(s) and to sell See Legal Description
(2) You are also directed to attach the property of the defendant(s) not levied upon in the possession of
GARNISHEE(S) as follows:
and to notNy 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 directedto notify him/herthat he/she has been added as agarnishee and is enjoined asabove
stated.
Amount Due 5177,541.08 L.L. $.50
Interest frcrn 10/25/01 to 3/6/02 (per deim - Due Prothy $1.00
8g29.18) $3,851.76 and Costs
Atty's ComM % Other Costs
Atty Paid $t 44 35
Plaintiff Paid
Date: October 29, 2001 Curtis R. Lopg
REQUESTING PARTY:
Name Frank FederFnan Esq.
One Penn Center at Suburban Station
Address: _ -_a-. a....,,..,-,.a site 1400
:=
Philadelphia, PA 19103-1814
Attorney for: Plaintiff
Telephone: 215-563-7000
Supreme Court ID No.
Prothonotary. Civil Division
,. :ii„ _ _ ..~ _-..,c ,~~..~.. n .~,-.. .... ~ ,~s~su ss-~.,~~4maTe~bserm4~_ „~,er.M
REAL ESTATE SA~.~ ~o. ~~
On November Ol, 2001, the sheriff levied upon the
defendant's interest in the real property situated in
Monroe Township, Cumberland County, PA,
known and numbered as 1330 Williams Crrove Road,
Mechanicsburg, and more fully described on Exhibit "A" Q
ac"7n
filed with this writ and by this reference incorporated herein. ~ir,l
c
Date: November O1, 2001 By: S.
Real Estate Deputy
v„ ~ - ~~ ;
~~
~,•i i'ti ~,~ r~' ~~ 1~~
3 +. v 4.. (.".
al> ;I:i
dJ~'n:` ij~0
_ _ _
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
Joumal on the following dates,
viz:
JANUARY 25, FEBRUARY 1, 8, 2002
Affiant further deposes that he is authorized to verify this statement by the Cumberland
Law Journal, a legal periodical of general circulation, and that he is not interested in the subject
matter of the aforesaid notice or advertisement, and that all allegations in the foregoing
statements as to time, place and character of publication are true.
Roger M. Morgenthal, Editor
SWORN TO AND SUBSCRIBED before me this
8 day of FEBRUARY. 2002
L(gS E. ER, tdokary Public
Ga~las~'e , C
5,
IirEAi. ESTATE SALE NO. 15
Writ No. 2001-5457 Civil
Associates Home Equity Consumer
Discount Company, Inc.
vs.
Donna Lee McDermott
Li,u~illa L. Pensinger and
William E. Donicker
Atty.: Frank Federman
ALL THAT CERTAIN piece or par-
cel of ground, situate in the Town-
ship of Monroe, County of Cumber-
land and State of Pennsylvania.
more particularly bounded and de-
scribed as follows, to wit:
BEGINNING at a point on the
Western right-of--way line of the Wll-
liams Grove Road, at corner of
Green Lane, as shown on the Plan
of Lots hereinafter mentioned:
thence by the rightof-way line of
the Williams Grove Road. South 00
degrees 11 minutes 11 seconds West,
two hundred twenty-flue and twenty-
four hundredths (225.24) feet to a
point: thence by the dividing line
between Lots Nos. 1 and 2 on said
Plan, South 87 degrees 32 minutes
12 seconds West, nine hundred
eighty and fifty-one hundredths
(980.51) feet to a point; thence North
00 degrees 28 minutes 00 seconds
East, two-hundred twenty-flue and
twenty-nine hundredths (225.29)
feet to a point on the Southern line
of Green Lane: thence by the South-
ern line of Green Lane, North 87
degrees 32 minutes 12 seconds
East, nine hundred seventy-nine
and forty hundredths (979.40) feet
to a point, the place of BEGINNING.
BEWG Lot No. 1 in the Plan of
Lots of Frank E. Stoner, as recorded
in Plan Book Q36, at Page 106,
Cumberland County Recorder of
Deed's Office.
SUBJECT to setback lines as
shown on said Plan.
HAVING thereon erected a dwell-
ing known as 1330 Williams Grove
Road.
TAX PARCEL NUMBEER: 22-11-
'1278-078
TITLE TO- SASD FREM~I6;~3 IS
VESTED FAI Lurtfilia L. Pensinger and
Donna Lee McDermott, as joint ten-
ants with right of survivorship bS
reason of the following:
BEING the same premises whickt
Rosemary Mazie Stoner, a single
person by Deed dated 9(24/98 and
recorded 12(2/99 in the County of
Cumberland in Record Book 212
Page 490 conveyed unto William E.
Donicker and Lurilla L. Pensinger,
both single persons as joint ter~ants
and Donna Lee McDermott.
AND ALSO BEING the same
premises which William E. Donieker
and Lurllla L. Pensinger and Donna
Lee McDermott by Deed dated 10/
25/00 and recorded 10/25/00 in
the County of Cumberland in Record
Book 232 Page 278 conveyed unto
Luriiiia L. Pensingei and Donna Lee
McDermott, as joint tenants with
rig'h# of survivorship.
e
THE PATRIOT NEWS
THE SUNDAY PATRIOT NEWS
Proof of Publication
UnderAct No. 587, Approved May 16,1929
Commonwealth of Pennsylvania, County of Dauphin] ss
Michael Morrow being duly sworn according to law, deposes and says:
That he is the Asst. Controller of The Patriot News Co., a corporation organized and existing under the laws
of the Commonwealth of Pennsylvania, with its principal office and place of business at 812 to 818 Market Street, in
the City of Harrisburg, County of Dauphin, State of Pennsylvania, owner and publisher of The Patriot-News and The
Sunday Patriot-News newspapers of general circulation, printed and published at 812 to 818 Market Street, in the
City, County and State aforesaid; that The Patriot-News and The Sunday Patriot-News were established March 4th,
1854, and September 18th, 1949, respectively, and all have been continuously published ever since;
That the printed notice or publication which is securely attached hereto is exactly as printed and published in
their regular daily and/or Sunday/ Metro editions which appeared on the 29th day(s) of January and the 5th and
12th day(s) of February 2002. That neither he nor said Company is interested in the subject matter of said printed
notice or advertising, and that all of the allegations of this statement as to the time, place and character of
publication are true; and
That he has personal knowledge of the facts aforesaid and is duly authorized and empowered to verify this
statement on behalf of The Patriot-News Co. aforesaid by virtue and pursuant to a resolution unanimously passed and
adopted severally by the stockholders and board of directors of the said Company and subsequently duly recorded in
the office for the Recording of Deeds in and for said County of Daup in in Miscellaneous Book "M",
Volume 14, Page 317. i ~ f /)~ .
PUBLICATION
COPY
SALE#75
VWI~
...........................................
22nd
2002 A.D.
Nolarlel Seal /
Terty L. Rusa@II, Notary PubllC /
HaMsburg, 08uphin County
My COmmisslpi6yires JUne e, 2002 N TARY PUBLIC
Member,PepnsyNaniaassoGatlonorNOtaries My commission expires June 6, 2002
CUMBERLAND COUNTY SHERIFFS OFFICE
CUMMBERLANDCOUNTYCOURTHOUSE
CARLISLE, PA. 17013
Statement of Advertising Costs
To THE PATRIOT-NEWS CO., Dr.
For publishing the notice or publication attached
hereto on the above stated dates $ 345.60
Probating same Notary Fee(s) $ 1.50
Total $ 347.10
Publisher's Receipt for Advertising Cost
The Patriot News Co., publisher of The Patriot-News and The Sundav Patriot-News, newspapers of general
circulation, hereby acknowledge receipt of the aforesaid notice and publication costs and certifies that the same have
been duly paid.
By ....................................................................
EAL ESTATE5AlE No. 75
Writ No.20015457
Clvilrerm
?* AsaoclBtes Home
'"~~Equtty Conaomer
Dlsco_untCo.~lnc. __
- T ova -- = - _
Donna Lee lA:Oermok
-Wrilla L Petratnoer and
HIZT CERTABV piece or parcel of gmund,
m the Township of Monroe, Count' of
i7ahd and State of Permsylvania, mon:
asly bounded and descdbed as folbws, m
NDVG at a paint on the Western rightof-
e ofthe Williams GNve Road, at comer of
Lane, as_slsowo .on the Plan of Lots
fret mentioned; thence 6t' the righ4of-way
the Williams Grove Road. South Oll
a point' themx by the dividing line
toes Nos, t and 2 on said Plan, Scuih 87
32 minutes,l2 seconds Wes4 nine
eighty a~ fifty-0ce 6undmdihs (980.51)
a poinC thence NoNs 00 degrees 28,
b seconds EuS two hundredtwenty-five
t~-nine hundredths (22529). feet to a
fhe Soutliem sine of Green Lane: thence
ECG Lot No. l in the Plan of Lots of Fmnk E
-$ as recorded in Plan Book Q36, at Page
~~,((OG~Cumberland County Recorder of Deed's
~Gfhc6
;~UBIECL to setbacklines as shmvn on said Plan.
thereon erected a dwelling known as
30 Williams Grove Road.
(~[. NUMBER. 22-11-0278-078.
=1TTLE to said premises is vested in [.millia L.
-_ Pensinger-and_Donva Lee McDermott, as joint
tenantcwithnght ofsurvivorship by reason of the
~uBowing:
~IDVG the same premises which Rosemary
_A~arie Stoner, a single person, by Deed dated
~1dA(98 and recorded 1219N9 in the County of
~ mberjand sp, Resmd Book 212 Page 490
~~m'"r reytd unto WitliaalE. Donicker a~ Lurilla L.
~P£nsinger,. hadr_singfe persons, as joint tenants
E. Donicker and Lorilla L. Pensinger and
:e McDermott by Deo3 dated 1OR5100
:orded ]0251W in the County of
and :m Rerord Book 232 Page 278
3 unto ~Lurillia L. Pensinges amt Donna
Demrott, as joint tenants with right of
itiio- -
FEDERMAN AND PHELAN, LLP
By: FRANK FEDERMAN, ESQUIRE
IDENTIFICATION NO. 12248
ONE PENN CENTER AT SUBURBAN STATION
1617 JOHN F. KENNEDY BOULEVARD
SUITE 1400
PHILADELPHIA, PA 19103-1814
(215) 563-7000
ASSOCIATES HOME EQUITY CONSUMER
DISCOUNT COMPANY, INC.
1111 NORTHPOINT DRIVE
COPPELL, TX 75019
Plaintiff
v.
DONNA LEE MCD$RMOTT
LURILLA L. PENSINGER
WILLIAM E. DONICKER
1330 WMS GROVE ROAD
MECHANICSBURG, PA 17055
Defendant(s)
TERM
CUMBERLAND COUNTY
CIVIL ACTION -LAW
COMPLAINT IN MORTGAGE FORECLOSURE
NOTICE
**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 REAFFIRMED, THIS
CORRESPONDENCE IS NOT AND SHOULD NOT BE CONSTRUED TO BE AN ATTEMPT TO COLLECT
A DEBT, BUT ONLY ENFORCEMENT OF A LIEN AGAINST PROPERTY. **
You have been sued in Court. If you wish to defend against the claims set forth in the following
pages, you must take action within twenty (20) days after this Complaint and Notice are served,
by entering a written appearance personally or by attorney and filing in writing with the court
your defenses or objections to the claims set forth against you. You 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 #:033753860312110
IF THIS IS THE FIItST 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
NDGMENT UNTIL THE EXPIRATION OF THIRTY
(30) DAYS AFTER YOU HAVE RECEIVED THIS
COMPLAINT. HOWEVER, IF YOU REQUEST
PROOF OF THE DEBT OR THE NAME AND
ADDRESS OF THE ORIGINAL CREDITOR WITHIN
THE THIRTY (30) DAY PERIOD THAT BEGINS
UPON YOUR RECEIPT OF THIS COMPLAINT,
THE LAW REQUIRES US TO CEASE OUR
EFFORTS (THROUGH LITIGATION OR
OTHERWISE) TO COLLECT THE DEBT UNTIL
WE MAIL THE REQUESTED INFORMATION TO
YOU. YOU SHOULD CONSULT AN ATTORNEY
FOR ADVICE CONCERNING YOUR RIGHTS AND
OBLIGATIONS IN THIS SUIT.
1. Plaintiff is
ASSOCIATES HOME EQUITY CONSUMER
DISCOUNT COMPANY, INC.
1111 NORTHPOINT DRIVE
COPPELL, TX 75019
2. The name(s) and last known address(es) of the Defendant(s) are:
DONNA LEE MCDERMOTT
LURILLA L. PENSINGER
WILLIAM E. DONICKER
1330 WMS GROVE ROAD
MECHANICSBURG, PA 17055
who is/are the mortgagor(s) and real owner(s) of the property hereinafter described.
On 11/19/99 mortgagor(s) made, executed and delivered a mortgage upon the premises
hereinafter described to PLAINTIFF which mortgage is recorded in the Office of the
Recorder of CUMBERLAND County, in Mortgage Book No. 1585, Page 467.
4. The premises subject to said mortgage is described as attached.
5. The mortgage is in default because monthly payments of principal and interest upon said
mortgage due 12/1/00 and each month thereafter are due and unpaid, and by the terms of
said mortgage, upon failure of mortgagor to make such payments after a date specified by
written notice sent to Mortgagor, the entire principal balance and all interest due thereon
are collectible forthwith. A copy of such notice is attached as Exhibit "A."
6. The following amounts are due on the mortgage:
Principal Balance $155,956.53
Interest 13,001.30
11/1/00 through 8/1/01
(Per Diem $47.45)
Attorney's Fees 4,000.00
Cumulative Late Charges 0.00
11119!99 to 8/1101
Cost of Suit and Title Search 550.00
Subtotal $173,507.83
Escrow
Credit 0.00
Deficit 0.00
Subtotal $ 0.00
TOTAL $173,507.83
The attorney's fees set forth above are in conformity with the Mortgage documents and
Pennsylvania Law, and will be collected in the event of a third party purchaser at
Sheriffs Sale. If the Mortgage is reinstated prior to the Sale, reasonable attorney's fees
will be charged.
8. This action does not come under Act 6 of 1974 because the original mortgage amount
exceeds $50,000.00.
The Combined Notice has been sent to the Defendant(s) by regular and certified mail as
required by 35 P.S. § 1680.403c on the date(s) set forth in the true and correct copy of
such notice(s) attached hereto as Exhibit "A."
10. The Temporary Stay as provided by the Homeowner's Emergency Mortgage Assistance
Program, Act 91 of 1983, has terminated because either:
(i.) Defendant(s) have failed to meet with the Plaintiff or an authorized Credit
Counseling Agency in accordance with Plaintiff s written Notice to Defendants,
a true and correct copy of which is attached hereto as Exhibit "A"; or
(ii.) Defendant(s) application for assistance has been rejected by the Pennsylvania
Housing Finance Agency.
WHEREFORE, PLAINTIFF demands an in rem Judgment against the Defendant(s) in the sum of
$173,507.83, together with interest from 8/1/01 at the rate of $47.45 per diem to the date of
Judgment, and other costs and charges collecfible under the mortgage and for the foreclosure and
sale of the mortgaged property.
/s/ Frank Federman
FRANK FEDERMAN, ESQUIRE
Attorney for Plaintiff
no foreclosure proceedings will be pursued against you if you have met the time requirements set forth
above. You will be notified directly by the Pennsylvania Housing Finance Agency of its decision on your
application.
lvu rE: iP Yuu AxE CU1tREN1'LY PROTECTED BY THE FILING OF A PETITION IN
BANKRLrPTCY, THE FOLLOWING PART OF THIS NOTICE IS FOR INFORMATION
PURPOSE ONLY AND SHOULD NOT BE CONSIDERED AS AN ATTEMPT TO COLLECT
THE DEBT.
(If you have filed bankruptcy you can still apply for Emereencv MorteaQe Assistance.) I
HOW TO CURE YOUR MORTGAGE DEFAULT (Brine it up to datel
\':~TURE OF THE DEF.4L'LT-The MORTGAGE debt held by the above lender on your property located
at: 1330 Williams Grove Road, Mechanicsburg, PA 17055 IS SERIOUSLY IN DEFAULT because:
A. YOU HAVE NOT MADE MONTHLY MORTGAGE PAYMENTS for the following months and the
following amounts are now past due: Start/End: 12/1/00 thru 8/1/01 at $1,490.16 per month.
Monthly Payments Plus Late Charges Accrued $13,411.44
NSF: $0.00
L[spec [iuua: $0.00
Other: $0.00
(Suspense): $0_00
Total amount to cure default $13,411.44
B. YOU HAVE FAILED TO TAKE THE FOLLOWING ACTIONS (Do not use if not applicablel: N/A
HOW TO CURE THE DEFAULT-You may cure the default within THIRTY THREE (33) DAYS of the
date of this notice BY PAYING THE TOTAL AMOUNT PAST DUE TO THE LENDER, WHICH IS
$13,411.44, PLUS ANY MORTGAGE PAYMENTS AND LATE CHARGES WHICH BECOME DUE
DURING THE THIRTY THREE (33) DAY PERIOD. As of the date of this letter, you owe the amount
specified above. Because of interest, late charges, and other charges that may vary from day to day, the
amount due on the day that you pay may be greater. Hence, if you pay the amount shown above, an
adjustment may be necessary after we receive your check, in which event we will inform you before
depositing the check for collection. For further information ,write the undersigned or call (215) 563-7000
and ask for the Reinstatement Department. Payments must be made either by cash, cashier's check.
certified check or money order [Wade payable and sent to: Federman & Phelan, LLP, One Penn Center
at Suburban Station, Suite 1400. Philadelphia, PA .]9103-1914. Attention: Reinstatment Department.
1'ou can cure any other default by taking the following action within THIRTY THREE (33) DAYS of [he
date of this letter (Do not use if not annlicable.l N/A.
[F YOU DO NOT CURE THE DEFAULT-[f you do not cure the default within THIRTY THREE(33)
DAYS of the date of this Notice, the lender intends to exercise its riehts to accelerate the mortgage debt.
The means that the entire outstanding balance of this debt will be considered due immediately and you may
lose the chance to pay the mortgage in monthly installments. If full payment of the total amount past due is
not made e~ithin THIRTY THREE (33) DAYS, the lender also intends to instruct its attorney to start legal
action to foreclosure anon your mortgage property.
IF THE MORTGAGE IS FORECLOSED UPON- The mortgage property will be sold by the Sheriff to pay
off the mortgage debt. If the lender refers your case to its attorneys, but you cure the delinquency before
the lender begins legal proceedings against you, you will still be required to pay the reasonable attorney's
fees that were actually incurred, up to $50.00. However, if legal proceedings are started against you, you
will have to pay all reasonable attorney's fees actually incurred by the lender even if they exceed $0.00.
Any attorney's fees will be added to the amount to the lender, which may also include other reasonable
costs. If you cure the default within the THIRTY THREE (33) DAY period, you will not be required to
~?y attorney's fees.
EXFd1~e~° tt~~
m __
ACT 91 NOTICE
TAKE ACTION TO SAVE
YOUR HOME FROM
DATE: August ~5, 200 FORECLOSURE
TO: Donna Lee McDermott Lurilla L. Pensinger
1330 Williams Grove Road 1330 Williams Grove Road
Mechanicsburg, PA 17055 Mechanicsburg, PA 17055
William E. Donicker
1330 Williams Grove Road
Mechanicsburg PA 17055
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 ENFORCEMENT OF A LIEN AGAINST PROPERTY.
This is an official notice that the morteaee on vour home is in default and the lender intends to foreclosure.
Specific information about the nature of the default is provided in the attached pa es.
The HOMEOWNER'S MORTGAGE ASSISTANCE PROGRAM (HEMAP) may be able to help to save
vour home. This Notice explains how the proeram works.
To see if HEMAP can help, you must MEET WITH A CONSUMER CREDIT COUNSELING AGENCY
WITHIN 33 DAYS FROM THE DATE OF THIS NOTICE. Take this Notice with you when you meet the
Counseling Agency.
The name, address and phone number of Consumer Credit Counseling Agencies serving vour County are
listed at the end of this Notice. If you have any questions, you may call the Pennsylvania Housing Finance
Agency toll free at 1-800-342-2397. (Persons with impaired hearing can call (717) 780-1869).
This Notice contains important legal information. If you have any questions, representatives at the
Consumer Credit Counseling Agency maybe able to help explain it. You may also want to contact an
attorney in your area. The local bar association may be able to help you find a lawyer.
LA NOTIFICACION EN ADJiJNTO ES DE SUMA IMPORTANCIA, PUEDE AFECTA SU DERECHO
A CONTINUAR VIVIENDO EN SU CASA. SI NO COMPRENDE EL CONTENIDO DE ESTA
NOTIFICACION OBTENGA UNA TRADUCCION INMEDITAMENTE LLAMANDO ESTA
AGENCIA (PENNSYLVANIA HOUSING FINANCE AGENCY) SIN CARGOS AL NUMERO
ME:~CI0NAD0 ARRIBA. PUEDES SER ELEGIBLE PARR UN PRESTAMO POR EL PROGRAMA
LLAMADO "HOMEOWNERS EMERGENCY MORTGAGE ASSISTANCE PROGRAM" EL CUAL
PUEDE SALVAR SU CASA DE LA FERDIDA DEL DERECHO A REDIMAR SU HIPOTECA.
EXHIBIT "A"
STATEMENTS OF POLICY
HOMEOWNER'S NAME(S): Donna Lee McDermott, Lurilla L. Pensinger, and William E. Donicker
PROPERTY ADDRESS: 1330 Williams Grove Road, Mechanicsburg, PA 17055
LOAN ACCT. NO.: 033753860312110
ORIGINAL LENDER: Associates Home Equity Consumer Discount Company
CURRENT LENDER/SERVICER: CitiSnancial Mortgage Company, Inc.
HOMEOWNER'S EMERGENCY MORTGAGE ASSISTANCE PROGRAM
IF YOU COMPLY WITH THE PROVISIONS OF THE HOMEOWNER'S EMERGENCY MORTGAGE
ASSISTANCE ACT OF 1983 (THE "ACT"), YOU MAY BE ELIGIBLE FOR EMERGENCY MORTGAGE
ASSISTANCE.
• iF YOUR DEFAULT HAS BEEN CAUSED BY CIRCUMSTANCES BEYOND YOUR CONTROL,
• IF YOU HAVE A REASONABLE PROSPECT OF BEING ABLE TO PAY YOUR MORTGAGE
PAYMENTS, AND
• IF YOU MEET OTHER ELIGIBILITY REQUIREMENTS ESTABLISHED BY THE
PENNSYLVANIA HOUSING FINANCE AGENCY.
TEMPORARY STAY OF FORECLOSURE-Under the Act, you are entitled to a temporary stay of
foreclosure on your mortgage for thirty three (33) days from the date of this Notice. During that time you
must arrange and attend aface-to-face meeting with one of the consumer credit counseling agencies listed
at the end of this Notice. THIS MEETING MUST OCCUR WITHIN THE NEXT (33) DAYS. IF YOU
DO NOT APPLY FOR EMERGENCY MORTGAGE ASSISTANCE .YOU MUST BRING YOUR
MORTGAGE UP TO DATE. THE PART OF THIS NOTICE CALLED "HOW TO CURE YOUR
MORTGAGE DEFAULT" EXPLAINS HOW TO BRING YOUR MORTGAGE UP TO DATE.
CONSUMER CREDIT COUNSELING AGENCIES-If you meet with one of the consumer credit
counseline aeencies listed at the end of this notice the lender may NOT take action against you for thirty
three(33) days after the date of this meetine. The names, addresses and telephone numbers of designated
consumer credit counseline aeencies for the county in which the property is located are set forth at the end
of this Notice. It is only necessary to schedule one face-to-face meeting. Advise your lender immediately
of your intentions.
APPLICATION FOR MORTGAGE ASSISTANCE-Your mortgage is in a default for the reasons set forth
later in this Notice (see following pages for specific information about the nature of your default.) If you
have tried and are unable to resolve this problem with the lender, you have the right to apply for financial
assistance from the Homeowner's Emergency Mortgage Assistance Program. To do so, you must fill out,
sign and file a completed Homeowner's Emergency Assistance Program Application with one of the
designated consumer credit counseling agencies listed at the end of this Notice. Only consumer credit
counseling agencies have applications for the program and they will assist you in submitting a complete
application to [he Pennsylvania Housing Finance Agency. Your application MUST be Filed or postmarked
within thirty three (33) days of your face-to-face meeting.
YOU MUST FILE YOUR APPLICATION PROMPTLY. IF YOU FAIL TO DO SO OR IF YOU
DO NOT FOLLOW THE OTHER TIME PERIODS SET FORTH IN THIS LETTER,
N'ORECLOSURE MAY PROCEED AGAINST YOUR HOME IMMEDIATELY AND YOUR
APPLICATION FOR MORTGAGE ASSISTANCE WILL BE DENIED.
AGENCY ACTION-Available funds for emergency mortgage assistance are very limited. They will be
disbursed by the Agency under the eligibility criteria established by the Act. The Pennsylvania Housing
Finance Agency has sixty (60) days to make a decision after it receives your application. During that time.
EXHIBIT "A"
OTHER LENDER REMEDIES-The lender may also sue you personally for the unpaid principal balance
and all other sums due under the mortgage.
RIGHT TO CURE THE DEFAULT PRIOR TO SHERIFF'S SALE-If you have not cured the default
within the THIRTY THREE (33) DAY period and foreclosure proceedings have begun, you still have the
right to cure the default and prevent the sale at anv time uu to one hour before the Sheriffs Sale You may
do sob a in the total amount then ast due lus an late or other char es then due. reasonable
atturnev's fees and costs connected with the foreclosure sale and anv other costs connected with the
Sheriff s Sale as specified in writine by the lender and by nerfomaina anv other requirements under the
morteaee. Curing your default in the manner set forth in this notice will restore your mortgage to the same
position as if you had never defaulted.
EARLIEST POSSIBLE SHERIFF'S SALE DATE-[t is estimated that the earliest date that such a Sheriffs
Sale of the mortgage property could be held would be approximately SIX (6) MONTHS from the date of
this Notice. A notice of the actual date of the Sheriffs Sale will be sent to you before the sale. Of course,
the amount needed [o cure the default will increase the longer you wait. You may find out at any time
exactly what the required payment or action will be by contacting the lender.
HOW TO CONTACT THE LENDER: Attorney Representing Lender:
FEDERMAN & PHELAN, LLP
One Penn Center at Suburban Station
Suite 1400
Philadelphia, PA 19103-1814
(215) 563-7000 Contact Person: Janette Mahoney
EFFECT OF SHERIFF'S SALE-You should realize that a Sheriff s Sale will end your ownership of the
mortea,ed property and your right to occupy it. If you continue to live in the propetty after the Sheriff s
Sale, a lawsuit to remove you and your furnishings and other belongings could be started by the lender at
any time.
ASSL`MPTION OF MORTGAGE-You may orX_may not (CHECK ONE) sell or transfer
your home to a buyer or ttansferee who will assume the mortgage debt, provided that all the outstanding
payments, chazge and attorney's fees and cost are paid prior to or at the sale and that the other requirements
of the mortgage are satisfied.
YOU MAY ALSO HAVE THE RIGHT:
• TO SELL THE PROPERTY TO OBTAIN MONEY TO PAY OFF THE MORTGAGE DEBT OR TO
BORROW MONEY FROM ANOTHER LENDING INSTITUTION TO PAY OFF THIS DEBT.
• TO HAVE THIS DEFAULT CURED BY ANY THIRD PARTY ACTING ON YOUR BEHALF.
• TO HAVE THE MORTGAGE RESTORED TO THE SAME POSITION AS IF NO DEFAULT HAD
OCCURRED, IF YOU CURE THE DEFAULT. (HOWEVER, YOU NOT HAVE THIS RIGHT TO
CURE YOUR DEFAULT MORE THAN THREE TIMES IN ANY CALENDAR YEAR.)
• TO ASSERT THE NONEXISTENCE OF A DEFAULT IN ANY FORECLOSURE PROCEEDING
OR ANY OTHER LAWSUIT INSTITUTED UNDER THE MORTGAGE DOCUMENTS.
• TO ASSERT ANY OTHER DEFENSE YOU BELIEVE YOU MAY HAVE TO SUCH ACTION BY
THE LENDER
• TO SEEK PROTECTION L'NDER THE FEDERAL BANKRUPTCY LAW.
CONSUMER CREDIT COL"NSELING AGENCIES SERVING YOUR COUNTY IS ATTACHED
EXHIBIT "A°
If this is the first notice that you have received from this office, be advised that: You may dispute the
validity of [he debt or any portion thereof. If you do so in writing within thirty three (33) days From
the date of this letter, this firm will obtain and provide you with written verification thereof;
otherwise the debt will be assumed to be valid. Likewise if requested within thirty three (33) days
from the date of this letter, the firm will send you the name and address of the original creditor if
different from above.
Very truly yours,
FEDERtMAN AND PHELAN, LLP
Cc: Citifinancia] Mortgage Company, Inc.
Attn: Account No.: 03 3 753 8603 12 1 1 0
Mailed by I~` Class mail and by certified Mail No:
+:
77006 4575 1294 4772 1381
1!'~_ ~;
~~
?1~6 4575 b294 4772 1367
,~ '~
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~eftifie~ article l~~s~~~"°
' SEA®~67~ R~~~l3
~CHIBIT "A'
PENNSYLVANLI HOUSING FINANCE AGENCY
HOMEOWNER'S E.rIERGENCY ASSISTANCE PROGR.tuVt
CONSUMER CREDIT COUNSELING AGEYCIES
(REV. 8/00)
CLINTON COUNTY
Lvcoming-Clinton Comties Commision for CCCS of Vortheas¢m PA
Communiry Action (STEP) 1631 South Atherton Sc, Suite 100
2138 Lincoln Street P.O. Box 1328 Stale College, PA 16801
Williamsport, PA 17703 (811) 238-3668 FAX (811)'u'8-3669
(570) 326-0587 FAX (570) 322.2197
CCCS ofNOrtheaztem PA
201 Bazin Street
Williamsport, PA 17703
(570) 3236627 FAX (570) 323-6626
3I W. Market Street
POB 1127
Wilkes-Barre, PA 18702
(570) 821-0837 oc(800) 922-9537
FAX (570) 321-1785
OOLUMBIA COUNTY
Commission on. Economics Opportunity of Luwtte County
163 Amber Lane
Wilkes-Barre, PA 18702
(570)326-OS IOror (800)322-0359
FA7C (570) 829-1665-(Call Before Faxing)
(570) 455-4994 Hazeltown
FAX (570) 455-5631-(Call Before Faxing)
(570)836-i090Tunkhannock
Booker T. Washington Center
1720 Holland Center
Erie, PA 16503
(814)153-5744 FAX (814) 5749
John F. Kennedy Center, Inc.
2021 East 201° Sveet
Erie, PA 16510
(814)398.0400
FAX (811) 898-1243
CCCS of Western Pennsylvania, inc
2000 Linglestown Road
Harrisburg, PA 17102
(717) 541-1757
Urban League of Metropolitan Harrisburg
N. 6° Sveet
Harrisburg, PA V IO I
(717) 234-5925 F.4X (717) 234-9459
Communiry Action Comm of the Capital Region
IS l4 Deny Street
Harrisburg, PA V 104
(717) 232-9757 F.4X (717) 234-2?27
CUb1BERLAYD COUNTY
1100 Abine an Executive Park
Suite !
Clarks Summit, PA 1841!
(570)58 i-9163 or (500) 922-953%
F.4X (570) 587-9134-9135
Greaur Erie Community Action Commiaee
i 8 West 9i° SUeet
Erie, PA 1650!
(814) i59-1181 FAX (811)156-0161
Shenango Valley Urban League, Inc.
601 Indiana.4venue
Farrell, PA 16121
(112) 981-53(0
Financial Counseling Services of Franklin
31 West 3"Street
Wavnesbaro, PA 17268
(7I~) 762-3285
YWCA of Carlisle
301 "G" Street
Carlisle, PA 17013 =
(717) 243-3818 E.4}C (717) 731-9589
Adams County Housing Authority
139-143 Carlisle St.
Gemsburg, PA 17325
(7t7)334-1513 FAX 334-8326
PENNSYLVANIA BULLETIN, VOL. 29, N0.23, .TUNE 5, 1999
EXHIBIT °A°
ALL THAT C>rRTAIN piece or parcel of ground, situate in the Township of Monroe,
County of Cumberland and State of Pennsylvania, more particularly bounded and
described as follows, to wit:
BCGINNING at a point on the western right-of--way line of the Williams Grove Road, at
corner of Green Lane, as shown on the Plan of Lou hereinafter mentioned; thence by the
right-or-way fine of the Williams Grove Road, South 00 degrees 11 minutes 11 seconds
West, two hundred twenty-Cve and twenty-four hundredths (225.24) feet to a point;
thence by the dividing tine between Lots Nos. 1 and 2 on said Plan, South 37 degrees 32
minutes l2 seconds West, nine hundred eighty and f fty-one hundredths (980.51) feet to a
point; thence North 00 degrees 28 minutes 00 seconds East, two hundred twenty-five
ands twenty-nine hundredths (225.29) feet [o a point on the southern line of Green Lane;
thence by the southern line of Green Lane, North 87 degrees 32 minutes 12 seconds East,
nine hundred seventy-nine and forty hundredths (979.40) feet to a point, the place of
B1rGINNING.
BEING Lot No. 1 in the Plan of Lots of Frank );, Stoner, as recorded in plan Book
Q36, at Page 106, Cumberland County Recorder of Deed's Office.
SUB3ECT to setback lines as shown on said Plan.
HAVING thereon erected a single dwelling house known and numbered as 1330
Williams Grove Road, Mechanicsburg, PA.
BEING the same premises which Rosemary Marie Stoner, by her deed dated the
24"' day of September, 1998, and recorded in the Office of the Recorder of Deeds in and
for Cumberland County in Deed Book 5 O ,Page ~, Vol. ,granted and
conveyed unto William E. Donicker, LuRilla L. Pensinger, and Donna Lee McDermott,
Grantors herein.
.r
VERIFICATION
MICHAEL GRAHAM hereby states that he is ASSISTANT VICE PRESIDENT of
CTTIFINANCIAL MORTGAGE COMPANY, INC. mortgage servicing agent for Plaintiff in this
matter, that he 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 his Imowledge, infom~ation and belief.
The undersigned understands that this statement is made subject to the penalties of 18 Pa. C.S. Sec. 4904
relating to unswom falsification to authorities.
DATE: ~ _ , ~ - b
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SALE DATE: MARCH 6, 2002
IN THE COURT OF COMMON PLEAS OF CUMBERLAND COUNTY, PENNSYLVANIA
CIVIL ACTION -LAW
ASSOCIATES HOME EQUITY CONSUMER
DISCOUNT COMPANY, INC. No.: 01-5457 CIVIL TERM
vs.
DONNA LEE MCDERMOTT
LURILLA L. PENSINGER AND WILLIAM
E. DONICKER
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:
1330 WM5 GROVE 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) and/or Certified Mail Return Receipt stamped by the U.S. Postal Service is attached
for each notice.
F ~ FED , ES UIRE
Attorney for Plaintiff
February 26, 2002
.- ,
`ASSOCIATES HOME° EQUITI' CONSUMER
DIS~QUNT=COMPt~IyY;INC~ ,
-Rlaintiff,
v.
DONNA LEE MCDERI~'IOTT
LURILLA L. PENSINGER AND WILLIAM E.
DONICKER
Defendant(s).
CUMBERLAND COUNTY
`COURT OF COMMON PLEAS
CIVIL DIVISION
NO.Ol-5457 CIVII~ TERM
AFFIDAVIT PURSUANT TO RULE 3129
(Affidavit No. l)
ASSOCIATES HOME EQUITY CONSUMER DISCOUNT COMPANY. INC., Plaintiff in the
above action, by its attorney, FRANK FEDERMAN, ESQUIltE, sets forth as of the date the Praecipe for
the Writ of Execution was filed the following information concerning the real property located at 1= 330
WMS GROVE ROAD, MECHANICSBURG. PA 17055 .
1. Name and address of Owner(s) or reputed Owner(s):
Name
DONNA LEE MCDERIVIOTT
LURILLA L. PENSINGER
WILLIAM E. DONICKER
Last Known Address (if address cannot be
reasonably ascertained, please indicate)
1330 WMS GROVE ROAD
MECHANICSBURG, PA 17055
9 WALNUT LANE
MECHANICSBURG, PA 17055
9 WALNUT LANE
MECHANICSBURG, PA 17055
2. Name and address of Defendant(s) in the judgment:
DONNA LEE MCDERMOTT
LURII,LA L.
WILLIAM E. DONICKER
1330 WMS GROVE ROAD
MECIiANICSBURG, PA 17055
9 WALNUT LANE
MECHANICSBURG, PA 17055
9 WALNUT LANE
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. 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 Imowledge 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
1330 WMS GROVE ROAD
MECHATTICSBURG, PA 17055
13 North Hanover Street
Carlisle, PA 17013
PO Box 2675
Harrisburg, PA 17105
I verify that the statements made in this affidavit aze true and correct to the best of my personal
l~towledge or information and belief. I understand that false statements herein are made subject to the
penalties of l8 Pa. C.S. Sec. 4904 relating to unsworn falsification to authorities.
October 25, 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) DONNA LEE MCDERMOTT
LURILLA L. PENSINGER AND WILLIAM E. DONICKER
PROPERTY: 1330 WMS GROVE 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, µ•
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
ASSOCIATES HOME EQUITY CONSUMER
DISCOUNT COMPANY, INC. No.: 01-5457 CIVIL TERM
vs. ~ ~aCi
,_ ~
DONNA LEE MCDERMOTT ,, c'?'G' i~roa~, __"f' i ~ ~~ ~ K~,r'~1;~'
LURILLA L. PENSINGER AND WILLIAM ~,I ~~,, ~,~_ Ilk T`a~,""; jiL~
E. DONICKER
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:
1330 WMS GROVE 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. 3L9.2(c) on each of the persons or parties named, at that address set forth
on the attached Affidavit No. 2 (previously filed) and Supplemental Affidavit No. 2 on the date
indicated, and a copy of the notice is attached as an Exhibit. A copy of the Certificate of Mailing
(Form 3817) and/or Certified Mail Return Receipt stamped by the U.S. Postal Service is attached
for eachnohce-= ,t ~"~?~~~"~~, , ,u~,uh> ratQL~,:~n~
~~'.,~.ii1F'f~~
. ,... Y~ N~ic-., -1 r~~311 ,L"
F FED , ES UIltE
Attorney for Plaintiff
February 26, 2002
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FEDERMAN AND PHELAN
By: FRANK FEDERMAN, ESQUIRE
IDENTIFICATION NO. 12248
ONE PENN CENTER AT SUBURBAN STATION,
SUITE 1400
PHILADELPHIA, PA 19103-1814
(~i5~ 5~~-7nnn
ASSOCIATES HOME EQUITY CONSUMER
DISCOUNT COMPANY, INC.
ATTORNEY FOR PLAINTIFF
COURT OF COMMON PLEAS
CIVIL DIVISION
CUMBERLAND COUNTY
No.: 01-5457 CIVIL TERM
vs.
DONNA LEE MCDERMOTT
LURILLA L. PENSINGER AND WII,LIAM
E. DONICKER
AFFIDAVIT OF SERVICE OF NOTICE OF SHERIFF'S SALE
PT TRST TANT Tn P R _l' .P_, 4n4(~/4n3
FRANK FEDERMAN, ESQUIRE, Attorney for Plaintiff, hereby certifies that service of the
Notice of Sheriffs Sale was made by sending a true and correct copy by certified mail to Defendant,
DONNA LEE MCDERMOTT at 1330 WMS GROVE ROAD, MECHANICSBURG, PA 17055,
which notice of Sheriffs Sale was received by Defendant, DONNA LEE MCDERMOTT on
11/Ol/Ol as evidenced by the attached return receipt. The undersigned understands that this
statement is made subject to the penalties of 18 PA C.S. s 4904 relating to unsworn falsification to
authorifies.
~~ ~ ~ -
FEDERMAN,
Date: Nnvemher 27, ~nm
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AFFIDA7~?3T OF SERVICE t'-
CUMBHRLAND COUNTY l~
PLAINTIFF ASSOCIATk;S HOME EQUITY
CONSU!1YI ~I; IAISG~TNT~(J~'IPANY, IN.C. No.92~54'S9 CIi~II:1'ERM
DEFENDANT(S) DONNA LEE MCDERMOTT 1kCC7 ?!«033.Z53&61131?110
' LURII.LA L. PENSI1+iGER.AND
WILLIAM E. DONICKER Type of:Action
-'Notice of Sheriff s.Sale
SERVE LURILLA L. PENSINGER AT
9 WALNUT LANE
MECHANICSBURG, PA I7055
Sale Date: MARCH 6, 2002
SERVED /~ 0/' ,~ r
Served and made known to /~ u RR'l \ar, , ~- • ~e.NS' N^J e.K , Drefendant, on the ~ day of '' "~ ~ ~ 200 t
at 7 ~ ~0 ,o'clock ~.m., at ~~+9-~N ~ ~ ~--N. ~ ~ C t V~ a W ~ e5 ~ ~ 1~`~ ,Commonwealth
of Pennsylvania, in the manner described below:
Defendant personally served. r
Adult family member with whom Defendant(s) reside(s). Relationship is C o - ~ b i ~ a r.J
Adult in charge of Defendan[(s)'s residence who refused to give name or relationship. w N^ 'n
Manager/Clerk of place of lodging in which Defendant(s) reside(s). I~ N i c ~c e ((
Agent or person in chazge of Defendant(s)'s office or usual place of business.
an officer of said Defendant(s)'s company.
Other: __ -_ , ,
>'FS .~
Description: Age '~ Height r8 Weight ~~d Race f~_Sex ~ Other gRey l,ai R
I, ~ari a N~ e- ~.. Ca.t~y . ~K. , a competent adult, being duly sworn according to law, depose and state that I personally handed :.
a true and correct copy of the Notice of Sheriff's Sale in the manner as set forth herein, issued in the captioned case on the date and at
the address indicated abov . NOTAiIIA! SEA! "'
iuvnc u. nun r ~wE+, cauaai r r avow
Sworn to and subscribed ChambBfSbUrg BOrO, Franklin
before me this ~ day My COnN1~lOt1 Elfplf88 DB
of d devr.bti~, 2001 .
Notary: yt ~ ~ ~ By:
NOT SERVED
On the day of 200_, at o'clock - m, Defendant NOT FOUND because:
Moved Unknown 4 No Answer Vacant
Other:
Sworn to and subscribed
before me this day
of 200
Notary: By:
Attorney for Plaintiff _,
Frank Federman, Esquire - I.D. No. 12248 '
One Penn Center at Suburban Station ~~
1617 John F. Kennedy Boulevard, Suite 1400 ~;
Philadelphia, PA 19103-1814 -
(215) 563-7000
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AFFIDAVIT OF SERVICE
PLAINTIFF ASSOCIATE6 HOME EQUITY
CONSUMER DISCOUNT COMPANY, INC.
DEFENDANT(S) DONNA LEE MCDERMOTT
LURILLA L. PENSINGER AND
WILLIAM E. DONICKER
SERVE WILLIAM E. DONICKER AT
9 WALNUT LANE
MECHANICSBURG, PA 17055
CUMBERLAND COUNTY
No. 01~ 5457`CIVIL'' TERM
ACCT. ~U33753$6031`2119
. d'~ '
Type of Action
-Notice of Sheriff's Sale
Sale Date: MARCH 6, 2002
SERVED /
II,,,, r- F
Served and made known to W ~ ~ ~ Il /Q u ~ C'~e ~ ,Defendant, on the _~ day of ~ ~ , 200 t,
at •~b , o'clock ~.m, at
of Pennsylvania, in the manner described below:
_~Defendant personally served.
Adult family member with whom Defendant(s) reside(s). Relationship is
Adult in charge of Defendant(s)'s residence who refused to give name or relationship.
Manager/Clerk of place of lodging in which Defendant(s) reside(s).
Agent or person in charge of Defendant(s)'s office or usual place of business.
an officer of said Defendant(s)'s company.
Other:
Commonwealth
rM1f ,O ,~ ws
Description: Age 6~ Height ~ o Weight /~~ Race W Sex ~ Other f ReY 1`^ 'ti
I ~atee N ce_ ~.., ~2~/ , J y~, a competent adult, being duly sworn according to law, depose and state that I personally handed
a true and correct copy of the Notice of Sheriff s Sale in the manner as set forth herein, issued in the captioned case on the date and at
the address indicated abov NOT,r,„ ~"
ANNE G. BOi4Ys~,:l, ..;..;, y p0 'C
Sworn to and subscribed ChamberSbltrg Bcro, Franklin
before me this 9~day My Comrok{sioii Expires 15,
of 4d 200~1.3,~~,~
Notary: n n-f'/~~ ""- !J ~ By:
NOT SERVED
On the day of 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:
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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FEDERMAN AND PHELAN
By: FRANK FEDERMAN, ESQUIRE
IDENTIFICATION NO. 12248
ONE PENN CENTER AT SUBURBAN STATION,
SUITE 1400
PHILADELPHIA, PA 19103-1814
(~~ 5~~_7nnn
ATTORNEY FOR PLAINTIFF
COURT OF COMMON PLEAS
CIVIL DIVISION
ASSOCIATES HOME EQUITY CONSUMER CUMBERLAND COUNTY
DISCOUNT COMPANY, INC.
No.: 01-5457 CIVIL TERM
vs.
DONNA LEE MCDERMOTT
LURILLA L. PENSINGER AND WII,LIAM
E. DONICKER
AFFIDAVIT OF SERVICE OF NOTICE OF SHERIFF'S SALE
PT TR CT TANT Tn P.R.(' .P-, 4~4(2~/403
FRANK FEDERMAN, ESQUIRE, Attorney for Plaintiff, hereby certifies that service of the
Notice of Sheriffs Sale was made by sending a tme and correct copy by certified mail to Defendant,
DONNA LEE MCDERMOTT at 1330 WMS GROVE ROAD, MECHANICSBURG, PA 17055,
which notice of Sheriffs Sale was received by Defendant, DONNA LEE MCDERMOTT on
11/Ol/Ol as evidenced by the attached return receipt. The undersigned understands that this
statement is made subect to the penalties of 18 PA C.S. s 4904 relating to unswom falsification to
authorities.
Date: Nnvemher 29,E
miuRi~F~s&a~ssnes5~saasud~de;d au ss~cHa~m~~ ~ ,.v,...,
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SHERIFF'S RETURN - REGULAR
Y
• CASE NO: 2001-05457 P
COMMONWEALTH OF PENNSYLVANIA:
COUNTY OF CUMBERLAND
ASSOCIATES HOME EQUITY CONSUME
VS
MCKERMOTT DONNA LEE ET AL
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
MCDERMOTT DONNA LEE
DEFENDANT
the
at 1745:00 HOURS, on the 19th day of September, 2001
at 1330 WILLIAMS GROVE RD
MECHANICSBURG. PA 17055
by handing to
DONNA MCDERMOTT
a true and attested copy of COMPLAINT - MORT FORE together with
and at the same time directing Her attention to the contents thereof.
Sheriff's Costs:
Docketing 18.00
Service 5.85
Affidavit .00
Surcharge 10.00
.00
33.85
So Answers:
~~~~~
R. Thomas Kline
09/20/2001
FEDERMAN
Sworn and Subscribed to before By:
methis ,q~p'~ day of
~iA Q d~
rothonotary 7 ~
SHERIFF'S RETURN - REGULAR
v
CASE NO: 2001-05457 P
COMMONWEALTH OF PENNSYLVANIA:
COUNTY OF CUMBERLAND
ASSOCIATES HOME EQUITY CONSUME
VS
MCKERMOTT DONNA LEE ET AL
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
PENSINGER LURILLA L the
DEFENDANT at 1908:00 HOURS, on the 19th day of September, 2001
at 9 WALNUT LANE
MECHANICSBURG, PA 17055
WILLIAM DONICKER BOYFRIEND
by handing to
a true and attested copy of COMPLAINT - MORT FORE
together with
and at the same time directing His attention to the contents thereof
Sheriff's Costs:
Docketing
Service
Affidavit
Surcharge
So Answers:
6.00
6.50
.00
10.00 R. Thomas Kline
.00
22.50 09/20/2001
SHERIFF'S RETURN - REGULAR
• CASE NO: 2001-05457 P
COMMONWEALTH OF PENNSYLVANIA:
COUNTY OF CUMBERLAND
ASSOCIATES HOME EQUITY CONSUME
VS
MCKERMOTT DONNA LEE ET AL
CHARD SMI
Sheriff or Deputy Sheriff of
Cumberland County,Pennsylvania, who being duly sworn according to law,
says, the within COMPLAINT - MORT FORE was served upon
DONICKER WILLIAM E the
DEFENDANT at 1908:00 HOURS, on the 19th day of September, 2001
at 9 WALNUT LANE
MECHANICSBURG, PA 17055 by handing to
WILLIAM DONICKER
a true and attested copy of COMPLAINT - MORT FORE together with
and at the same time directing His attention to the contents thereof
Sheriff's Costs:
Docketing 6.00
Service .00
Affidavit .00
Surcharge 10.00
.00
16.00
Sworn and Subscribed to before
me this d€~ _ day of
Prothonotary
So Answers:
~~
R. Thomas Kline
09/20/2001
FEDERMAN & PHELAN
By:
ep ty Sheriff
I .+'
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
(215) 563-7000
ASSOCIATES HOME EQUITY CONSUMER
DISCOUNT COMPANY, INC.
1111 NORTHPOINT DRIVE
COPPELL, TX 75019
Plaintiff,
v.
CUMBERLAND COUNTY
COURT OF COMMON PLEAS
CIVIL DIVISION
NO. 01-5457 CIVIL TERM
DONNA LEE MCDERMOTT
LURILLA L. PENSINGER AND WILLIAM E.
DONICKER
Defendant(s).
PRAECIPE FOR JUDGMENT FOR FAILURE TO
ANSWER AND ASSESSMENT OF DAMAGES
TO THE PROTHONOTARY:
Kindly enter judgment in favor of the Plaintiff and against DONNA LEE MCDERMOTT and
LURILLA L. PENSINGER AND WILLIAM E. DONICKER, 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 8/1/01 to 10/25/01
TOTAL
$173,507.83
$4,033.25
$177,541.08
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 FEDERMAN, ESQUIRE
Attorney for Plaintiff
DAMAGES ARE HEREBY ASSESSED AS INDICATED.
DATE: ~ 2~9~ ~U I /< .
PRO PROTHY
«~
i~
(Rule of Civil Procedure No. 236) -Revised
IN THE COURT OF COMMON PLEAS OF CUMBERLAND COUNTY, PENNSYLVANIA
CIVIL ACTION -LAW
ASSOCIATES HOME EQUITY
DISCOUNT COMPANY, INC.
1111 NORTHPOINT DRIVE
CUMBERLAND COUNTY
COURT OF COMMON PLEAS
Plaintiff,
v.
DONNA LEE MCDERMOTT
LURILLA L. PENSINGER AND WILLIAM E.
DONICKER
CIVIL DIVISION
NO. 01-5457 CIVIL TERM
`w:.
Defendant(s).
Notice is given that a Judgment in the above-captioned matter has been entered against you on
('ac% ~ 2001 .
B~, Ci~~~vi~/
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 BE AN ATTEMPT TO COLLECT A DEBT, BUT ONLY ENFORCEMENT OF A
LIEN AGAINST PROPERTY.**
ii
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
ASSOCIATES HOME EQUITY
CONSUMER DISCOUNT COMPANY,
INC.
Plaintiff
vs.
DONNA LEE MCDERMOTT
LURILLA L. PENSINGER
WILLIAM E. DONICKER
Defendant(s)
T0: DONNA LEE MCDERMOTT
1330 WMS GROVE ROAD
MECHANICSBURG,PA 17055
DATE OF NOTICE: OCTOBER 10,2001
ATTORNEY FOR PLAINTIFF
COURT OF COMMON PLEAS
CIVIL DIVISION
CUMBERLAND COUNTY
NO. 01-5457 CIVIL
. _n .. '4.~ `5
.•, 4d
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
~~ ~GC/~'_,r~, a
Frank Federman, Esquire
Attorney for Plaintiff
~ FEDERMAN AND PHELAN
' 'Frank Federman, Esquire
Identification No. 12248
One Penn Center Plaza at
Suburban Station, Suite 1400
Philadelphia, PA 19103-1799
(215) 563-7000
ASSOCIATES HOME EQUITY
CONSUMER DISCOUNT COMPANY,
INC.
Plaintiff.
vs.
DONNA LEE MCDERMOTT
LURILLA L. PENSINGER
WILLIAM E. DONICKER
Defendant
TO: WILLIAM E. DONICKER
9 WALNUT LANE
MECHANICSBURG, PA 17055
DATE OF NOTICE: OCTOBER 10,2001
ATTORNEY FOR PLAINTIFF
COURT OF COMMON PLEAS
CIVIL DIVISION
CUMBERLAND COUNTY
NO.O1-5457 CIVIL
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 WIS~L 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 ASSOCLATION
2 LIBERTY AVENUE
CARLISLE, PA 17013
(717)249-3166
~- r ~ .~~-
Frank Federman,Esquire
Attorney for Plaintiff
' FEDERMAN AND PHELAN
'~ •Frank Federman, Esquire
Identification No. 12248
One Penn Center Plaza at
Subux'ban Station, Suite 1400
Philadelphia, PA 19103-1799
(215) 563-7000
ASSOCIATES HOME EQUITY
CONSUMER DISCOUNT COMPANY,
INC.
Plaintiff
vs.
DONNA LEE MCDERMOTT
LURILLA L. PENSINGER
WILLIAM E. DONICKER
Defendant
TO: LURILLA L. PENSINGER
9 WALNUT LANE
MECHANICSBURG, PA 17055
DATE OF NOTICE: OCTOBER 10.2001
ATTORNEY FOR PLAINTIFF
COURT OF COMMON PLEAS
CIVIL DIVISION
CUMBERLAND COUNTY
NO.O1-5457 CIVIL
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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
PHILADELPEIIA, PA 19103-1814
(215)563-7000
ASSOCIATES HOME EQUITY CONSUMER
DISCOUNT COMPANY, INC.
1111 NORTHPOINT DRIVE
Plaintiff,
v.
ATTORNEY FOR PLAINTIFF
CUMBERLAND COUNTY
COURT OF COMMON PLEAS
CIVI. DIVISION
NO.Ol-5457 CIVIL TERM
DONNA LEE MCDERMOTT
LURILLA L. PENSINGER AND WILLIAM E.
DONICKER
Defendant(s).
VERIFICATION OF NON-MILITARY SERVICE
FRANK FEDERMAN, ESQUIRE, hereby verifies that he is attorney for the Plaintiff in
the above-captioned matter, and that on information and belief, he has knowledge of the following facts,
to wit:
(a) that the defendant(s) is/are not in the Military or Naval Service of the United States
or its Allies, or otherwise within the provisions of the Soldiers' and Sailors' Civil Relief Act of Congress
of 1940, as amended.
(b) that defendant DONNA LEE MCDERMOTT is over 18 years of age and resides at
1330 WMS GROVE ROAD, MECHANICSBURG, PA 17055 .
(c) that defendants LURILLA L. PENSINGER AND WILLIAM E. DONICKER are
over 18 years of age, and reside at , 9 WALNUT LANE, 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
ASSOCIATES HOME EQUITY CONSUMER
DISCOUNT COMPANY, INC.
Plaintiff,
v. No. 01-5457 CIVIL TERM
DONNA LEE MCDERMOTT
LURILLA L. PENSINGER AND WII,LIAM E.
DONICKER
Defendant(s). ^^^^
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TO THE DIRECTOR OF THE OFFICE OF THE PROTHONOTARY: "'
Issue writ of execution in the above matter:
Amount Due $177,541.08
Interest from 10/25/01 to 3/6/02 $3,851.76 and Costs
(per diem -29.18)
TOTAL $181,392.84
,ti
FRANK FEDE , ESQUII2E
One Penn Center at Suburban Station ~,«:
,„, .
1617 John F. Kennedy Boulevard, Suite 1400 ~'
Philadelphia, PA 19103-1814 '„:
Attorney for Plaintiff
Note: Please attach description of property.No.
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ALL THAT CERTAIN piece or parcel of ground, situate in the Township of Monroe, County of
Cumberland and State of Pennsylvania, more pamcularly bounded and described as follows, to wit:
BEGINNING at a point on the Western right-of-way line of the Williams Grove Road, at corner of
Green Lane, as shown on the Plan of Lots hereinafter mentioned; thence by the right-of-way line of
the Williams Grove Road, South 00 degrees 11 minutes 11 seconds West, two hundred twenty-five
and twenty-four hundredths (225.24) feet to a point; thence by the dividing line between Lots Nos.
and 2 on said Plan, South 87 degrees 32 minutes I2 seconds West, nine hundred eighty-and fifty-
one hundredths (980.51) -feet to a point; thence North 00 degrees 28 minutes 00 seconds East, two
hundred twenty-five and twenty-nine hundredths (225.29) feet to a point on the Southern line of
Green Lane; thence by the Southern line of Green Lane, North 87 degrees 32 minutes 12 seconds
East, nine hundred seventy-nine and forty hundredths (979.40) feet ro a point, the place of
BEGINNING.
BEING Lot No. 1 in the Plan of Lots of Frank E. Stoner, as recorded in Plan Book Q36, at Page
206, Cumberland County Recorder of Deed's Qffice.
SI7BJECT to setback lines as shown on said Plan.
HAVING thereon erected a dwelling Imawn as 1330 Williams Grove Road.
TAX PARCEL NU1vIBER: 22-i1-0278-078
TITLE TO SAID T');tEMISES I$ VESTED IN Lurillia L. Pensinger and Donna Lee McDermott, as
joint tenants with right of survivorship by reason of the following:
BEING the same gremises which Rosemary Marie Stoner, a single person by Deed dated 9/24/98,
and. recorded 12/2/99 in the County of Cumberland in Record Book 212 Page 490 conveyed unto
William E. Donicker and Lurilla L. Peasingcr, both single persons as joint tenants and Donna Lee
McDermott.
AND ALSO BEING the same premises which William E. Donicker and Lurilla L. Pensinger and
Donna Lee McDermott by Deed dated 10/25/00 and recorded 10/25!00 in the County of
Cumberland is Record Book 232 Page 278 conveyed unto Lurillia L. Pensinger and Donna Lee
McDermott, as joint tenants with right of survivorship.
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ASSOCIATES HOME EQUITY CONSUMER
DISCOUNT COMPANY, INC.
Plaintiff,
v.
DONNA LEE MCDERMOTT
LURILLA L. PENSINGER AND WILLIAM E.
DONICKER
Defendant(s).
CUMBERLAND COUNTY
COURT OF COMMON PLEAS
CIVIL DIVISION
NO.Ol-5457 CIVIL TERM
AFFIDAVIT PURSUANT TO RULE 3129
(Affidavit No. 1)
ASSOCIATES HOME EQUITY CONSUMER DISCOUNT COMPANY, INC., Plaintiff in the
above action, by its attorney, FRANK FEDERMAN, ESQUIItE, sets forth as of the date the Praecipe for
the Writ of ]Execution was filed the following information concerning the real property located at 1
WMS GROVE ROAD. MECHANICSBURG, PA 17055 .
1. Name and address of Owner(s) or reputed Owner(s):
Name
DONNA LEE MCDERMOTT
LURILLA L. PENSINGER
WILLIAM E. DONICKER
Last Known Address (if address cannot be
reasonably ascertained, please indicate)
1330 WMS GROVE ROAD
MECHANICSBURG, PA 17055
9 WALNUT LANE
MECHANICSBURG, PA 17055
9 WALNUT LANE
MECHANICSBURG, PA 17055
2. Name and address of befendant(s) in the judgment:
DONNA LEE MCDERMOTT
LURILLA L. PENSINGER
WILLIAM E. DONICIiER
1330 WMS GROVE ROAD
MECHANICSBURG, PA 17055
9 WALNUT LANE
MECHANICSBURG, PA 17055
9 WALNUT LANE
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)
Nl
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. 15S
MECHANICSBURG, PA 17055
5. Name and address of every other person who has any record lien on the property:
Name
None.
Last Known Address (if address cannot be
reasonably ascertained, please indicate)
6. Name and address of every other person who has any record interest in the property and whose
interest maybe affected by the sale.
Name
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
Tenant/Occupant
Domestic Relations of Cumberland County
Commonwealth of Pennsylvania
Department of Welfare
penalties of 18 Pa. C.S. Sec. 4904 relating to unsworn falsification to authorities.
October 25, 2001
DATE FRANK FEDERMAN, ESQI)IRE
Last Known Address (if address cannot be
reasonably ascertained, please indicate)
1330 WMS GROVE 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
Attorney for Plaintiff
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FEDERMAN and PHELAN
By: FRANK FEDERMAN
Identification No. 12248
ONE PENN CENTER AT SUBURBAN STATION
1617 JOHN F. KENNEDY BLVD., SUITE 1400
PffiLADELPHIA, PA 19103-1814
(215)563-7000
ASSOCIATES HOME EQUITY CONSUMER
DISCOUNT COMPANY, INC.
Plaintiff,
v.
DONNA LEE MCDERMOTT
LURILLA L. PENSINGER AND WILLIAM E.
DONICKER
Defendant(s).
ATTORNEY FOR PLAINTIFF
CUMBERLAND COUNTY
COURT OF COMMON PLEAS
CIVIL DIVISION
NO. 01-5457 CIVIL TERM
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:
U an FHA mortgage
O non-owner occupied
O vacant
(X) Act 91 procedures have been fulfilled
This certification is made subject to the penalties of 18 Pa. C.S. Section 4904 relating to unsworn
falsification to authorities.
~~~
FRANK FEDERMAN, ESQUIRE
Attorney for Plaintiff
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ASSOCIATES'H+DME ~~TJITY CONSII1fIER
DISCOUNT COMPANY, INC.
rx"Plaifitiff,
v.
DONNA LEE MCDERMOTT
LURILLA.L. YENSINGER'AND WILLIAM E.
DONICKER
Defendant(s).
CUMBERLAND COUNTY
.Nd: 01-5457;CIVIL TERM
October 25, 2001
TO: DONNA LEE MCDERMOTT
1330 WMS GROVE ROAD
MECHANICSBURG, PA 17055
LURILLA L. PENSINGER AND WILLIAM E. DONICKER
9 WALNUT LANE
MECHANICSBURG, PA 17055
* *TH/S FIRM IS A DEBT COLLECTOR ATTEMPT/NG TO COLLECT A DEBT AND ANY INFORMATION
OBTAINED WILL BE USED FOR THAT PURPOSE. IF YOUHAVE PREVIOUSLYRECEIVED ADISCHARGE IN
BANKRUPTCYAND THIS DEBT WAS NOT REAFFIRMED, THIS /S NOT AND SHOULD NOT BE CONSTRUED TO BE
AN ATTEMPT TO COLLECT A DEBT, BUT ONLY ENFORCEMENT OF A LIEN AGA/NST PROPERTY. *
Your house (real estate) at , 1330 WMS GROVE 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, Carlisle, PA 17013, to enforce the court judgment of 177,541.08 obtained by
ASSOCIATES HOME EQUITY CONSUMER DISCOUNT COMPANY. INC. (the mortgagee) against you.
If the Sheriff's sale is postponed, the property will be relisted for the JUNE 5, 2002 Sheriff's Sale.
NOTICE OF OWNER'S RIGHTS
YOU MAY BE ABLE TO PREVENT THIS SHERIFF'S SALE
To prevent this Sheriffs Sale, you must take immediate action:
The sale will be cancelled if you pay to the mortgagee the back payments, late charges,
costs and reasonable attorney's fees due. To find out how much you must pay, you may
call: (2151563-7000.
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 L2151563-7000.
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 UR CANNOT AFFORD ONE, GO TO OR TELEPHONE THE OFFICE LISTED ,;
BELOW TO FIND OUT WHERE YO'U CAN GET LEGAL HELP.
CUMBERLAND COUNTY ATTORNEY REFERRAL
CUMBERLAND COUNTY BAR ASSOCIATION
2 LIBERTY AVENUE
CUMBERLAND COUNTY COURTHOUSE
CARLISLE, PA 17013
(717) 249-3166
(800) 990-9108
..
ALL THAT CERTAIN piece or parcel of ground, situate is the Township of Monroe, County of
Cumberland and State of Pennsylvania, more pardcuiarly bounded and descn'bed as foIIows, to wit:
BEGINNING at a point an the Western right-of-way line of the Williams Grove Road, at corner of
Green Lane, as shown on the Plan of Lots hereinafter mentioned; thence by the right-af-way line of
the Williams Grove Road, South 00 degrees 11 minutes 11 seconds West, two hundred twenty-five
and twenty-four hundredths (225.24) feet to a paint; thence by the dividing line between Lats Nos. 1
and 2 as said Plan, South 87 degrees 32 mirttrtes 12 seconds West, nine hundred eighty and fifty-
one hundredths (980.31} feet to a point; thence North 00 degrees 2$ minutes 00 seconds East, two
hundred twenty-five and twetty-nine hundredths (225.29) feet to a point on the Southern line of
Green Lane; thence by the Southern line of Green Lane, North 87 degrees 32 minutes 12 seconds
East, nine hundred seventy-nine and forty hundredths (979.40) feet to a point, the place of
BEGINNING.
BEING Lot No. 1 in the Plan of Lors of Frank E. Stoner, as recorded in Plea Book Q36, at Pagc
106, Cumberland County Recorder of Deed's Office.
SU$JECT to setback lines as shown on said Plan.
HAVING thereon et~ected a dwelling known as 1330 Williams Grove Road.
TAX PARCII. NUIvIBII2: 22-11-0278-078
T -TILE TO SAID PREMISES IS VESTED IN Ltnillia L. Pensinger and Donna Lee McDermott, as
joint tenants with right of survivorship by reason of the following:
BEING the same premises which Rosemary Marie. Stoner, a single person by Deed dated 9124/98
and recorded 12/2/99 in the County of Cumberland in Record Book 212 Page 490 conveyed unto
William E. Donicker and Lurilla L. Pensingcr, both single persons as joint tenants and Donna Lee
McDermott.
AND ALSO BEING the same premises which William E. Donicker and LuriI~a L. Pensinger and
Doane Lee McDermott by Deed dated 10!25!00 and recorded 10!25!00 in the County of
Cumberland in Record Book 232 Page 273 Conveyed unto Lurillia L. Pensinger and Donna Lea
McDermoa, as joint tenants with right of survivorship.
__
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.ASSOCIATES:-HOME` EQUITY' CONSUMER
DISCOUNT COMPANY, INC.
'.: P,Iaintiff,
v.
CUMBERLAND'COUNTY
No. 01=5457CIVIT. TERM
DONNA`LEE. MGDERMOTT
LURILLA L. PENSINGER AND WILLIAM E.
DONICKER
Defendant(s).
October 25, 2001
TO: DONNA LEE MCDERMOTT
1330 WMS GROVE ROAD
MECHANICSBURG, PA 17055
LURILLA L. PENSINGER AND WILLIAM E. DONICKER
9 WALNUT LANE
MECHANICSBURG, PA 17055
* *THIS FIRM IS A DEBT COLLECTOR ATTEMPTING TO COLLECT A bEBT AND ANYINFORMATION
OBTAINED WILL BE USED FOR THAT PURPOSE. IF YOUHAVE PREVIOUSLYRECEIVED ADISCHARGE IN
BANKRUPTCY AND THIS DEBT WAS NOT REAFFIRMED, THIS IS NOT AND SHOULD NOT BE CONSTRUED TO BE
AN ATTEMPT TO COLLECT A DEBT, BUT ONLY ENFORCEMENT OF A LIEN AGAINST PROPERTY.
Your house (real estate) at ,1330 WMS GROVE 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, Carlisle, PA 17013, to enforce the court judgment of 177,541.08 obtained by
ASSOCIATES HOME EOUITY CONSUMER DISCOUNT COMPANY. INC. (the mortgagee) against you.
If the Sheriffls 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 fmd out how much you must pay, you may
call: (215) 563-7000.
2. You maybe able to stop the sale by filing a petition asking the Court to strike or open the
judgment, if the judgment was improperly entered. You may also ask the Court to
postpone the sale for good cause.
3. You may also be able to stop the sale through other legal proceedings.
You may need an attomey to assert your rights. The sooner you contact one, the more chance
you will have of stopping the sale. (See notice on page two on how to obtain an attomey.)
e y
YOU MAY STILL BE ABLE TO SAVE YOUR PROPERTY AND YOU HAVE OT$ER
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 X215) 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) aze 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 THAT CERTAIN piece or parcel of ground, situate iA the Township of Monroe, County of
Cumberland and State of Pennsylvania, more garticularly bounded and descn'bed as follows, ro wit:
BEGINNING at a point on the Western right-of--way line of the Williams Grove Road, at corner of
Green Lane, as shown on the Plan of Lots hereinatler mentioned; thence by the right-of-way line of
the WiIIiams Grove Road, South 00 degrees it aiiautes 11 seconds West, two hundred twenty-five
and twenty-four hundredths (225.24) feet to a point; thence by tte dividing line between Lots Nos. '.
and 2 en said Plan, South 87 degrees 32 mimttes 12 seconds West, nine hundred eighty and fifcy-
one hundredths (980.51) feet to a point; thence North 00 degrees 28 minutes 00 seconds East, two
hundred twenty-five and twenty-nine hundredths (225.29) feet to a point on the Southern line of
Green Lane; thence by the Southern line of Green Lane, North 87 degrees 32 minutes 22 seconds
East, nine hundred seventy-nine and forty hundredths (974.40} feet to a point, the place of
BEGIlYNING.
BEING Lot No. 1 in the Plan of Lots of Frank E. Stoner, as recorded in Plan Book Q36, at Page
106, Cumberland County Recorder of Deed's Office.
S17B7ECT m setback lines as shown on said Plan.
HAVING thereon erected a dwelling Itnawn as 1330 Williams Grove Road.
TAX PARCEL NU1vIBER: 22-11-0278-078
T~,'j~TO SAS PREMISES TS VESTED IN Lurillia L. Pen~+ngcr and Donna Lee McDetmotL, as
joint tenants with right of survivorship by reason of the fallowing:
BEING the same premises which Rosemary Marie Stoner, a single person by Deed dated 9/24/98
and recorded 12/2/99 in the County of Cumberland in Record Book 212 Page-490 conveyed unto
William E. Donicker and Lurilla L. Pensinger, both single persons as joint tenants and Dottaa Lea
McDermott.
AND ALSO BEING the same premises which William E. Donicker and Lurilla L. Pensiager and
Donna Lee McDermott by Deed dated 10/25/00 a~ recorded IO/ZS/QO in the County of
Cumberland in Record Book 232 Page 278 conveyed unto Lutillia L. Pensinger and Donna Lee
McDertnotr, as joint tenants with right of survivorship.
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