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Home My WebLink About01-06134 'F ' ,-~- FEDERMAN AND PHELAN .. . By: FRANK FEDERMAN Identification No. 12248 Attorney for Plaintiff ONE PENN CENTER AT SUBURBAN STATION 1617 JOHN F. KENNEDY BLVD., SillTE 1400 PHILADELPIDA, PA 19103-1814 (215) 563-7000 GMAC MORTGAGE CORPORATION 500 ENTERPRISE ROAD, SillTE 150 HORSHAM, PA 19044 CUMBERLAND COUNTY COURT OF COMMON PLEAS Plaintiff, CIVIL DIVISION v. NO. 01-6134 CIVIL DANIEL K. KULIG JILL ANN KULIG 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 DANIEL K. KULIG and JILL ANN KULIG, Defendant(s) for failure to file an Answer to Plaintiff's Complaint within 20 days from service thereof and for Foreclosure and Sale of the mortgaged premises, and assess Plaintiff's damages as follows: As set forth in Complaint Interest from 10/1/01 to 12/6/01 TOTAL $164,314.47 $1,915.98 $166,230.45 I hereby certify that (1) the addresses of the Plaintiff and Defendant( s) are as shown above, and (2) that notice has been given in accordance with Rule 237.1, copy attached. L1k FRANK FEDERMAN, ESQUIRE Attorney for Plaintiff DAMAGES ARE HEREBY ASSESSED AS INDICATED. DATE: /)... 14>--9' Cuvetu K f tM-cJ. PRO PROTHY ~ r ';'Jl-tl;~__ __, ,. ."'-"1 -, I~ I . "1 ~~ -11 ~~- __. ",",' , ." ,'. '~'" r~~"~ ~ ~ ~- - '"' - "'~ .., "',...>-'~~ .- .- ,,-!'!!!",rr_ "'~"'r-"'""" _~"__~-,J!!I!l'J'1I,I~"<l '~''''~'''~n' , . '$~~""'"I~iiI..f'l,li111II:il111i ''']:t''ij'r'lfm'''M'M o ~. -r~! ,,'" iTlr'l~ ~{ ~,9'!;~ C,-::C:- ~>:'''-' t~(~:' 'Pfi ."" -<: c C:J rrt ':'-) .,. ", .. ,_:"!!~_~'-'\l"f'l!W"_"'~"?~'P"'"'?'\il"",~-,"",w"I$l;ff1fI'l:1~~lI~~~~~fjfl!I!Ir~t~H~~f 21:11(" ~ .,~~~ _ -~ .-' . . (Rule of Civil Procedure No. 236) - Revised IN THE COURT OF COMMON PLEAS OF CUMBERLAND COUNTY, PENNSYLVANIA CIVIL ACTION - LAW GMAC MORTGAGE CORPORATION 500 ENTERPRISE ROAD, SUITE 150 CUMBERLAND COUNTY COURT OF COMMON PLEAS Plaintiff, CIVIL DIVISION v. NO. 01-6134 CIVIL DANIEL K. KULIG JILL ANN KULIG Defendant(s). Notice is given that a Judgment in the above-captioned matter has been entered against you on j J. ~ ttl 2001. By: t-h. EPUTY If you have any questions concerning this matter, please contact: FRANK FEDERMAN. ESOUIRE Attorney for Plaintiff ONE PENN CENTER AT SUBURBAN STATION 1617 JOHNF. KENNEDY BLVD., SUITE 1400 PHILADELPHIA, PA 19103-1814 (215) 563-7000 "THIS FIRM IS A DEBT COLLECTOR ATTEMPTlNG TO COLLECT A DEBT AND ANY lNFORMATION OBT AlNED WILL BE USED FOR THAT PURPOSE. IF YOU HA VB 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 AGAlNST PROPERTY." ""!%~j~T:J, ,___. ',,, .~ - ,~ --I"""" ' , " ',-' - *-- FEDERMAN AND PHELAN, L.L.P. Frank Federman, Esquire 'Identification No. 12248 One Penn Center Plaza at Suburban Station, Suite 1400 Philadelphia, PA 19103-1799 (215) 563-7000 ATTORNEY FOR PLAINTIFF COURT OF COMMON PLEAS GMAC MORTGAGE CORPORATION CIVIL DIVISION Plaintiff CUMBERLAND COUNTY vs. Defendant(s) NO. 01-6134 CIVIL FILE COpy DANIEL K. KULIG JILL ANN KULIG TO: DANIEL K. KULIG 905 MAPLEWOOD LANE ENOLA,PA 17025 DATE OF NOTICE: NOVEMBER 23. 2001 THIS FIRM IS A DEBT COLLECTOR ATTEMPTING TO COLLECT A DEBT. THIS NOTICE IS SENT TO YOU IN AN ATTEMPT TO COLLECT THE INDEBTEDNESS REFERRED TO HEREIN, AND ANY INFORMATION OBTAINED FROM YOU WILL BE USED FOR THAT PURPOSE. IF YOU HAVE PREVIOUSLY RECEIVED A DISCHARGE IN BANKRUPTCY, THIS CORRESPONDENCE IS NOT AND SHOULD NOT BE CONSTRUED TO BE AN ATTEMPT TO COLLECT A DEBT, BUT ONLY AS ENFORCEMENT OF LIEN AGAINST PROPERTY. IMPORTANT NOTICE You are in default because you have failed enter a written appearance personally or by attorney and file in writing with the court your defenses or objections to the claims set forth against you. Unless you act within ten (10) days from the date of this notice, a Judgment may be entered against you without a hearing and you may lose your property or other important rights. You should take this notice to a lawyer at once. If you do not have a lawyer or cannot afford one, go to or telephone the following office to find out where you can get legal help: CUMBERLAND COUNTY CUMBERLAND COUNTY BAR ASSOCIATION 2LIBERTY AVENUE CARLISLE, P A 17013 (717) 249-3166 1AlUL!G~ ;b1f){fj,{{ ~ Frank Federman, Esquire Attorney for Plaintiff i'~__~,~""r', ,'"~' __,.._~ ,,-,",~""_, c'= d';-- 1--, ,0 , ~~~. , ~'~~' 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 ATTORNEY FOR PLAINTIFF COURT OF COMMON PLEAS GMAC MORTGAGE CORPORATION CIVIL DIVISION Plaintiff vs. CUMBERLAND COUNTY DANIEL K. KULIG JILL ANN KULIG NO.01-6134 CIVIL Defendant FILE COpy TO: JILL ANN KULIG 1225 SOUTH MARKET STREET MECHANICSBURG, PA 17055 DATE OF NOTICE: NOVEMBER 23. 2001 THIS FIRM IS A DEBT COLLECTOR ATTEMPTING TO COLLECT A DEBT. THIS NOTICE IS SENT TO YOU IN AN ATTEMPT TO COLLECT THE INDEBTEDNESS REFERRED TO HEREIN, AND ANY INFORMATION OBTAINED FROM YOU WILL BE USED FOR THAT PURPOSE. IF YOU HAVE PREVIOUSLY RECEIVED A DISCHARGE IN BANKRUPTCY, THIS CORRESPONDENCE IS NOT AND SHOULD NOT BE CONSTRUED TO BE AN ATTEMPT TO COLLECT A DEBT, BUT ONLY AS ENFORCEMENT OF LIEN AGAINST PROPERTY. IMPORTANT NOTICE You are in default because you have failed enter a written appearance personally or by attorney and file in writing with the court your defenses or objections to the claims set forth against you. Unless you act within ten (10) days from the date of this notice, a Judgment may be entered against you without a hearing and you may lose your property or other important rights. You should take this notice to a lawyer at once. If you do not have a lawyer or cannot afford one, go to or telephone the following office to find out where you can get legal help: CUMBERLAND COUNTY CUMBERLAND COUNTY BAR ASSOCIATION 2 LlBERTY AVENUE CARLISLE, P A 17013 (717) 249-3166 ~~;(f;(jlLIL:+ Jlj{iJVlUM~ rank Federman,Esquire Attorney for Plaintiff !"%1!!Gll/i14l"1l'F_.:J '''_, ,~ --.Y ~ I, ,,'. ~~ ~-.,"!' ~ --~- ;[ FEDERMAN and PHELAN By: FRANKFEDERMAN Identification No. 12248 ONE PENN CENTER AT SUBURBAN STATION 1617 JOHN F. KENNEDY BLVD., SUITE 1400 PIDLADELPHIA, PA 19103-1814 (215) 563-7000 ATTORNEY FOR PLAINTIFF GMAC MORTGAGE CORPORATION 500 ENTERPRISE ROAD, SUITE 150 CUMBERLAND COUNTY COURT OF COMMON PLEAS Plaintiff, CIVIL DIVISION v. NO. 01-6134 CIVIL DANIEL K. KULIG JILL ANN KULIG 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 DANIEL K. KULIG is over 18 years of age and resides at , 905 MAPLE WOOD LANE, ENOLA, PA 17025. (c) that defendant JILL ANN KULIG is over 18 years of age, and resides at , 1225 SOUTH MARKET STREET, MECHANICSBURG, P A 17055. This statement is made subject to the penalties of 18 Pa. C.S. Section 4904 relating to unsworn falsification to authorities. U1J - FRANK FEDERMAN, ESQUIRE Attorney for Plaintiff f~"'~"" 7, ~, 'C(__ ~ I. ,-, "- ~~ - c, ~ , C., .- ~ ~^", \', ~ " Cf'\ !:'\ ~ II ~' ~ ~. (" ^ I1JII'!r,." '-li~~'::1fi: '---T" ff ,~" "..~ ". ~ ~~.""" ~~~ -. ,~'~" " .. .. . -""NJ~<Hr -;j~:""_-~<,,, "- _.. ....,. ,1--.d_v,""'" ~~~ "~...... ---- -.\:'\ ~ -.s i" "'" ~ ~ ~ ~ ~ W N ~ J ....s::. ::t o f::: C; ~!~~ c;" ~-~ l~jj .~ ;2 ~.~J f ~ :< T ...-.**1t'MIfr11'n" .'C:) r ~"'i -' . , '--~~ 15- -:S l3l; ~,....~~ ~~~:f;;;;''''''''''" ilJ'~-'S'..'1~;-, 0;"" fj~W~"iI!l;",,;W;;'l'n'il'<l~jM'~~n~ ."t'i"ii;~~~l~ iW Jt ~ ., PRAECIPE FOR WRIT OF EXECUTION - (MORTGAGE FORECLOSURE) P.R.C.P.3180-3183 GMAC MORTGAGE CORPORATION Plaintiff, v. No. 01-6134 CIVIL DANIEL K. KULIG JILL ANN KULIG Defendant(s). TO THE DIRECTOR OF THE OFFICE OF THE PROTHONOTARY: Issue writ of execution in the above matter: Amount Due $166,230,45 v' Interest from 12/6/01 to 3/6/02 (per diem -27.33) $2,459.70 and Costs TOTAL $168,690.15 U1L- FRANK FEDERMAN, ESQUIRE One Penn Center at Suburban Station 1617 JohnF. Kennedy Boulevard, Suite 1400 Philadelphia, PA 19103-1814 Attorney for Plaintiff Note: Please attach description ofproperty.No. ,",-~~_i.~.J\t(~ ',,<,< 1-, i' -.." .![4 -, ., .~, , I ~'"-~ '"~ <~, '"-"~"'~_'''o '-"'~~;'''''"V'~' '" '" 0 r-- .... 0( ~ ~ = 00 "'u ~~ ....= f;l;,o( o(u OZ ~~ oo~ Z Z ""'... o(~ 0 0 0>01 ~ .... .... ~~ ~ E-< ~oo 8 ZZ ~E-< >0100 OZ 0 :e" ~'"" ~E-< ~~ ~ "Ci ""'.... >01 ; it: i~ Q) ~:; ~~ f;I;, ~ ~ OE-< U oCj '.g '" uz ~ ~ ~z E-< ~ 'lil Q) f;I;,>;l - ..0 ~~ ~ ~ 00 r;5~ ;..., ~ ... >01= os E-<U <8 "",E-< S i:l:i~ ~ ...."'" i:l:i os ;..., ~5 e:: 5~ ~"'" oN' Q) S ~oo Q) 0 ~::; f;I;, ~ ~ g. U;j ~ ~6 ",'" P.. --..... to( ON >01>01 U Q\:::l ~ tl Q) == 0( ~ E-<~ ~ ~ OJ Z>;l oi::J '" Q) ....u ~ :g ~ .~ ~ 0( ,_, . '!"'T-,"~' .~iflrin~~~ iW*b'1"""~-N" ' ",,=~ml~ : " - " ".-_..";'"'"",~~f:tfflJji7Jj'!'4~~R",,~,,\j,;,, .-.. """"IIIllf'rlit ,_" llo ~;,' , ^ ~ '- ..-/ ALL TH.-\ T CERTAIN lot or piece of ground siruate in the Township of East Permsboro, Cumberland County, Permsylvania bounded and described according to a certain final Plan for Penn Valley Phase r. prepared by Hartman and Associates, Inc., Engineers and Surveyors, Camp Hill, Pennsylvania, dated June 23, 1993 and last revised September 9. 1993 and recorded on November 5, 1993 in Plan Book 6i. Page 20, as follows, to wit: BEGINNING at a point on the Northwest side of Mapiewood Lane and a corner of Lot 01'0. 52 on said Pian; thence extending along said Lot North 9 degrees 45 minutes 15 seconds West 101.61 feet to a point in line of Lot No. 47 on said Pian; thence extending along said Lot and continuing Norrh 80 degrees 14 minutes 45 seconds East 80.00 feet to a point, a corner of Lot No, 49 on said Plan: thence extending along said Lot and continuing South 9 degrees 45 minutes 15 seconds East 129,98 feet to a point on the Northwest side of Maplewood Lane; thence extending along said lane along a curve having a radius of 200.00 feet, the arc distance of 85.53 f~et to the point and place of beginning. BEING Lot No. 51 CONTAINING 9,005.33 square feet. Tax Parcel #13-0999-094 TITLE TO SAID PREMISES IS VESTED IN _Daniel K. Kulig and Jill Ann Kulig, his wife by Deed from Perm Valley CorporatIon, a Pa. Corp. dated 1/1//9/ and'recorded 1/29/97 in Record Book 152, Page 754. : ,-,,~ "".-, ... .,,,<"-,,,~ --,. -" ~. ,-~ '1"; , ;1 ~ ",~"~ '. ." ,_."".__,.","J",. c".J~'" f~ ^ -, ~J: I . -~. ~. v-.> ~ ,~ ~~. ~~ "~~=,'''''''''~ "'~". . .~,'~ ""'-""'o"'~~"l'f1l-'O' .".. 1l1Jn~~,TI ..t~l'r~'r ~ <:':--. (? ~,\ -.e ~ \' G\ ~\" ~ ;!:' <.)J ,-..J ...J -'\ o ~..:; iff r::;(' ;6 J>C' ~~ ~'J -<.: :::tJ ,..i.''; .. ~~';J .r:- 6s" IfJJ C'::J c:-J "'j 'J " ' --< '- , (0'1 (~) ~n ) (-) :~;:! ,J llif'll~~~~ : ",,_Ilm.~~ ,,~ ~;w~%,~,,.7"'f,::r:5;""")' :'C-,'C,""";!""- ~...." "-W"'1"1N<"\'Wll;:~;!-~~~<W'i"'i[~"":<"~iJ'''''''--"-;;jml'''MiiJW~.f.'1~#j'- ::: r- F~1': . _. ',,," '. GMAC MORTGAGE CORPORATION CUMBERLAND COUNTY Plaintiff, COURT OF COMMON PLEAS v. DANIEL K. KULIG JILL ANN KULIG CIVIL DIVISION NO. 01-6134 CIVIL Defendant(s). AFFillA VIT PURSUANT TO RULE 3129 (Affidavit No.1) GMAC MORTGAGE CORPORATION, Plaintiff in the above action, by its attorney, FRANK FEDERMAN, ESQUIRE, sets forth as of the date the Praecipe for the Writ of Execution was filed the following information concerning the real property located at .905 MAPLEWOOD LANE. ENOLA. PA 17025. L Name and address ofOwner(s) orreputed Owner(s): Name Last Known Address (if address cannot be reasonably ascertained, please indicate) DANIEL K. KULIG 905 MAPLEWOOD LANE ENOLA, PA 17025 JILL ANN KULIG 1225 SOUTH MARKET STREET MECHANICSBURG, P A 17055 2. Name and address ofDefendant(s) in the judgment: DANIEL K. KULIG 905 MAPLEWOOD LANE ENOLA, P A 17025 JILL ANN KULIG 1225 SOUTH MARKET STREET MECHANICSBURG, P A 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. ',~r"" ~-I ' IT -~., );;;'"""' ""-'.;:o'Rn:;, )\i!');Jl'!._ ~ ,~_, _, -. 4. Name and address oflast recorded holder of every mortgage of record: Name Last Known Address (if address cannot be reasonably ascertained, please indicate) TMS MORTGAGE, INC. 1770 TRIBUTE RD., SUITE 109 SACRAMENTO, CA 95815 5. Name and address of every other person who has any record lien on the property: Name Last Known Address (if address cannot be reasonably ascertained, please indicate) None. 6. Name and address of every other person who has any record interest in the property and whose interest may be affected by the sale. Name Last Known Address (if address cannot be reasonably ascertained, please indicate) None. 7. Name and address of every other person of whom the plaintiff has knowledge who has any interest in the property which may be affected by the sale: Name Last Known Address (if address cannot be reasonably ascertained, please indicate) Tenant/Occupant 905 MAPLEWOOD LANE ENOLA, P A 17025 Domestic Relations of Cumberland County 13 North Hanover Street Carlisle, P A 17013 Commonwealth of Pennsylvania Department of Welfare PO Box 2675 Harrisburg, P A 17105 I verify that the statements made in this affidavit are true and correct to the best of my personal knowledge or information and belief. I understand that false statements herein are made subject to the penalties ofl8 Pa. C.S. Sec. 4904 relating to unsworn falsification to authorities. t t rL FRANK FEDERMAN, ESQUIRE Attorney for Plaintiff December 7.2001 DATE -I' ~ " rr- ~ ""T " ~---"- -~""~ ~ " ~" ",- , ""~"~M - "~'Q 'lfill~ouliii'~'" o ? -Dr:,\~.' ~?[}i ~~ S~~.- ~:i~. " ...:,:- ~;[;~ L:~. =< , Cj ":'J ,"i" ~ <:~') _n;:-l ~,.lL ::Ji) ,Es 8# " ry",~_ "'_~""'" "'~s,'" ~~ --__._ ~. I-~~ ~~M~~lf~Jii!JIj~_!!IlI!~- -'; r',<'f;i_~.i!''''!f'''y';'N''""'"'''3''''~"'''''''C'''!''','f ''?f\;!l?i;'fl~~:rl'[it::m~))Ii~'';lfjlj~1l;lf'~!'JftH!':1'~*~' P'}'" , - FEDERMAN and PHELAN By: FRANK FEDERMAN Identification No. 12248 ONE PENN CENTER AT SUBURBAN STATION 1617 JOHN F. KENNEDY BLVD., SUITE 1400 PHILADELPffiA, PA 19103-1814 (215) 563-7000 ATTORNEY FOR PLAINTIFF GMAC MORTGAGE CORPORATION Plaintiff, CUMBERLAND COUNTY COURT OF COMMON PLEAS v. CIVIL DIVISION DANIEL K. KULIG JILL ANN KULIG NO. 01-6134 CIVIL Defendant(s). CERTIFICATION FRANK FEDERMAN, ESQUIRE, hereby verifies that he is attorney for the Plaintiff in the above-captioned matter, and that the premises are not subject to the provisions of Act 91 because it is: o an FHA mortgage () non-owner occupied () vacant (X) Act 91 procedures have been fulfilled This certification is made subject to the penalties of 18 Pa. C.S. Section 4904 relating to unsworn falsification to authorities. -l~/ tk FRANK FEDERMAN, ESQUIRE Attorney for Plaintiff "'~,i"~-'J- --~o ~-_~'__~__"" ;~~' 0'. -1-" r ,- , . 11 '..", '~.', "',,<" '" "J.,,,,,_,,,_ ,~~ ~-, ~ .""~,"",,,," !__^,,"""""f]-_c' -~""~'-"~ ~ I"v~ =~~-. " ~--~ _~:"i~""r"" ,".,.,,~, ",." -'''''''''''''~''-'''',''''"''~''--- '~^,'''''",^~~-,,' ,-j~"" [D ~ ;;;'''''''~'l''rr~'/'r.~~rlllrr-[1't ~ :':;~,. "'r-,c'~_ S2~~} ~~} ~i:c:' 5~?: ::~~ :?, c:: C" .-f\ ':-:J ,on r:; -l:\ .-"~ , " ":';' t:- 1='5 81/ ~ ,~m,""_~",.",,J~11/!~!i'~'-m[;(!'\'!(,~"_!'f'-""'''~''''''''';'~f'i'('',-"!H!,,,w.g;->f'IliE~"'~1').~l'il'l,lfi'ij'l?if~,Ii'!1'~ ,,,,~i!tt'~'~'lI1l~)ir.'__~~'I'~"~f''!i$'W~;;:1': 1r~:-i ~- .. GMAC MORTGAGE CORPORATION Plaintiff, CUMBERLAND COUNTY v. No. 01-6134 CIVIL DANIEL K. KULIG JILL ANN KULIG Defendant(s). December 7, 2001 TO: DANIEL K. KULIG 905 MAPLEWOOD LANE ENOLA, PA 17025 JILL ANN KULIG 1225 SOUTH MARKET STREET MECHANICSBURG, PA 17055 "THIS FIRM IS A DEBT COLLECTOR ATTEMPTING TO COLLECT A DEBT AND ANY INFORMATION OBTAINED WILL BE USED FOR THAT PURPOSE, IF YOU HAVE PREVIOUSLY RECEIVED A DISCHARGE IN BANKRUPTCY AND THIS DEBT WAS NOT 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. 905 MAPLEWOOD LANE. ENOLA. PA 17025. 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, P A 17013, to enforce the court judgment of 166.230.45 obtained by GMAC MORTGAGE CORPORATION (the mortgagee) against you. If the Sheriffs sale is postponed, the property will be relisted for th~ 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: L The sale will be cancelled if you pay to the mortgagee the back payments, late charges, costs and reasonable attorney's fees due. To find out how much you must pay, you may call: (215) 563-7000. 2. You may be 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.) !',i,'iJ,J;Ji)~J'if "__"" "_ ,.. , ~I' :!-"- ", , , --r"'.... F,'" ~~ o;''''''ftliY!!1!r'trT' '"-'~'~ . ~ YOU MAY STILL BE ABLE TO SAVE YOUR PROPERTY AND YOU HAVE OTHER RIGHTS EVEN IF THE SHERIFF'S SALE DOES TAKE PLACE. 1. If the Sheriff's Sale is not stopped, your property will be sold to the highest bidder. You may find out the price bid by calling (215) 563-7000. 2. You may be 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 ifthe buyer pays the Sheriff the full amount due in the sale. To find out if this has happened, you may call (717) 240-6390. 4. If the amount due from the Buyer is not paid to the Sheriff, you will remain the owner of the property as if the sale never happened. 5. You have the right to remain in the property until the full amount due is paid to the Sheriff and the Sheriff gives a deed to the buyer. At that time, the buyer may bring legal proceedings to evict you. 6. You may be entitled to a share oftlre 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 UBERTY AVENUE CUMBERLAND COUNTY COURTHOUSE CARLISLE, PA 17013 (717) 249-3166 (800) 990-9108 ii-';'h~_'_"~""_'" -,- ~' , " I! '1 , II ,- '"'.11"1'''.''''' ,,,. .-/ ALL TH.\ T CERT.\I~ lot or piece of ground sirume in the Township of East Pennsboro. Cumberland Coumy, Pennsylvania bounded and described according to a certain Final Plan for Penn Valley Phase I. prepared by Hartman :md Associates. Inc., Engineers and Surveyors, Camp Hill, Pennsylvania. dared June 23. 1993 and last revised September 9. 1993 and recorded on ~ovember 5, 1993 In Plan Book 67. Page 20, as follows. to wit: BEGI~i'lING at a poim on the Northwest side of Maplewood Lane and a corner of Lot 'io, 52 on said Plan: thence extending along said Lot North 9 degrees 45 minutes 15 seconds \Ves[ lO1.61 feet ro a poim in line of Lot No, 47 on said Plan: thence extending along said Lot ami continuing 00rth 80 degrees 14 minutes 45 seconds East 80.00 feet to a poim, a corner of Lot No, 49 on said Plan: thence extending along said Lot and continuing South 9 degrees 45 minutes 15 seconds East 129.98 reee [0 a point on the Northwest side of ~Iaplewood Lane; thence extending along said lane along a curve having a radius of 200.00 feet, the arc distance of 85.53 f~et to the point and place of beginning. BEING Lot No. 51 CONTA.INI~G 9,005,33 square feet. Tax Parcel #13-0999-094 TITLE TO SAID PREMISES IS VESTED IN Daniel K. Kulig and Jill Ann Kulig. his wife bv Deed from Penn Valley Corporation, a Pa. Corp. dared 1/11/')7 and'recorded 1/29/97 in Reco~d Book 152, Page 754, ,,-~ f,t -_4_ '__ _ 0, _, r ,~~ ,''''''I) " ~.," - -~ !fll ~-'"-"- ~ '~ 'I '~" m ". " , . "~. ~'""''' '" c. 'n~* ""'-",,, ^" """ ,,",V.". , ^'A \trL:rrfi~TIrl ""l)jf:f~j[1iif'n- "hr!'lffll1-~lIrIT~"TI~;;51:r~'f~Vtrt'~~ ," ~~~.~~l~~f'!iI'!'~~Ni""C'P;~_"!P"-p"",- """~'" r::J -c :-q IT, CJ 2:. Z (j~ E'~~:- ~f~ 7"': -< ii,',',.""" c:) \_, ,~-..... ~~~ E- Y# """-1'<'f',l:C'''')ll-AH\'i'''TI-'~~'''f;I~'''''''';i' 8";"-"',!' ,-":"..ni!"W"'~~J'^%B1f.ll(*1m1: ~= ,--,- .,...-- -. SHERIFF'S RETURN - REGULAR CASE NO: 2001-06134 P COMMONWEALTH OF PENNSYLVANIA: COUNTY OF CUMBERLAND GMAC MORTGAGE CORPORATION VS KULIG DANIEL K ET AL DAVID MCKINNEY , Sheriff or Deputy Sheriff of Cumberland County,Pennsylvania, who being duly sworn according to law, says, the within COMPLAINT - MORT FORE was served upon KULIG JILL ANN the DEFENDANT , at 1120:00 HOURS, on the 1st day of November, 2001 at BOOKSPAN 1225 SOUTH MARKET ST MECHANICSBURG, PA 17055 by handing to JILL ANN KULIG a true and attested copy of COMPLAINT - MORT FORE together with and at the same time directing Her attention to the contents thereof. Sheriff's Costs: Docketing Service Affidavit Surcharge So Answers: 6.00 6.50 .00 10.00 .00 22.50 .r~~<~ R. Thomas Kline 11/05/2001 FEDERMAN & PHELAN Sworn and Subscribed to before By: tJ~1 ~ . Deputy Sh ri~ ,.,,=- me this 7 day of fLo..,,,,~ .26<J( A. D . ~U2~ rothonotary ,~ -;'j'*~~ '"; , ~ '"" 1-; , , '~'" _~,_ ~"'eo ~'''~ ":~ ~= - ~, '"- . SHERIFF'S RETURN - REGULAR CASE NO: 2001-06134 P COMMONWEALTH OF PENNSYLVANIA: COUNTY OF CUMBERLAND GMAC MORTGAGE CORPORATION VS KULIG DANIEL K ET AL GERALD WORTHINGTON , Sheriff or Deputy Sheriff of Cumberland County,Pennsylvania, who being duly sworn according to law, says, the within COMPLAINT - MORT FORE was served upon KULIG DANIEL K the DEFENDANT , at 1846:00 HOURS, on the 2nd day of November, 2001 at 905 MAPLEWOOD LANE ENOLA, PA 17025 by handing to DANIEL K KULIG 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: 18.00 9.75 .00 10.00 .00 37.75 r~-/<:~ R. Thomas Kline 11/05/2001 FEDERMAN & PHELAN Sworn and Subscribed to before 9~ day of By: ~D^~LLA~* Deputy Sh lff me this ~ .2MJ/ A.D. o t2~ - ~othonotary ff '-"l'~~!I!i'f,.T;"'I' . ~~ - .""-,,.., I'! ". - ,""""",...!"!,-,""",~",,, "'I"~-~ '""~,"""'",' : _ n ) "J_r-' ~- \-;~W!'3"_'" , 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 GMAC MORTGAGE CORPORATION 500 ENTERPRISE ROAD SUITE 150, HORSHAM, PA 19044 COURT OF COMMON PLEAS CIVIL DIVISION ATTORNEY FOR PLNNTITF TERM Plaintiff - ~ v. NO. tJ/~ /#/31/ CUMBERLAND COUNTY DANIEL K. KULIG JILL ANN KULIG 905 MAPLEWOOD LANE, ENOLA, P A 17025 Defendant( s) CIVIL ACTION - LAW COMPLAINT IN MORTGAGE FORECLOSURE NOTICE **THIS FIRM IS A DEBT COLLECTOR ATTEMPTING TO COLLECT A DEBT AND ANY INFORMATION OBTAINED WILL BE USED FOR THAT PURPOSE. IF YOU HAVE PREVIOUSLY RECEIVED A DISCHARGE IN BANKRUPTCY AND THIS DEBT WAS NOT 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 are wamed that if you fail to do so the case may proceed without you and a judgment may be entered against you by the court without further notice for any money claimed in the Complaint or for any other claim or relief requested by the Plaintiff. You may lose money or property or other rights important to you. YOU SHOULD TAKE TillS PAPER TO YOUR LAWYER AT ONCE. IF YOU DO NOT HAVE A LAWYER OR CANNOT AFFORD ONE, GO TO OR TELEPHONE THE OFFICE SET FORTH BELOW TO FIND OUT WHERE YOU CAN GET LEGAL HELP. CUMBERLAND COUNTY CUMBERLAND COUNTY BAR ASSOCIATION 2 LIBERTY AVENUE CARLISLE,PA 17013 (717) 249-3166 Loan #: 493472609 ., - I~ r'" 1",- r-r I =,~ ~"" ~ :I'~ ~ ,'-"'!'-'" '1 HI][ -"I'. i "_L IF THIS IS THE FIRST NOTICE THAT YOU HAVE RECEIVED FROM THIS OFFICE, BE ADVISED THAT: PURSUANT TO THE FAIR DEBT COLLECTION PRACTICES ACT, 15 U.S.C. ~ 1692 et seq. (1977), DEFENDANT(S) MAY DISPUTE THE VALIDITY OF THE DEBT OR ANY PORTION THEREOF. IF DEFENDANT(S) DO SO IN WRITING WITHIN THIRTY (30) DAYS OF RECEIPT OF THIS PLEADING, COUNSEL FOR PLAINTIFF WILL OBTAIN AND PROVIDE DEFENDANT(S) WITH WRITTEN VERIFICATION THEREOF; OTHERWISE, THE DEBT WILL BE ASSUMED TO BE VALID. LIKEWISE, IF REQUESTED WITHIN THIRTY (30) DAYS OF RECEIPT OF THIS PLEADING, COUNSEL FOR PLAINTIFF WILL SEND DEFENDANT(S) THE NAME AND ADDRESS OF THE ORIGINAL CREDITOR, IF DIFFERENT FROM ABOVE. THE LAW DOES NOT REQUIRE US TO WAIT UNTIL THE END OF THE THIRTY (30) DAY PERIOD FOLLOWING FIRST CONTACT WITH YOU BEFORE SUING YOU TO COLLECT THIS DEBT. EVEN THOUGH THE LAW PROVIDES THAT YOUR ANSWER TO THIS COMPLAINT IS TO BE FILED IN THIS ACTION WITHIN TWENTY (20) DAYS, YOU MAY OBTAIN AN EXTENSION OF THAT TIME. FURTHERMORE, NO REQUEST WILL BE MADE TO THE COURT FOR A JUDGMENT UNTIL THE EXPIRATION OF THIRTY (30) DAYS AFTER YOU HAVE RECEIVED THIS COMPLAINT. HOWEVER, IF YOU REQUEST PROOF OF THE DEBT OR THE NAME AND ADDRESS OF THE ORIGINAL CREDITOR WITHIN THE THIRTY (30) DAY PERIOD THAT BEGINS UPON YOUR RECEIPT OF THIS COMPLAINT, THE LAW REQUIRES US TO CEASE OUR EFFORTS (THROUGH LITIGATION OR OTHERWISE) TO COLLECT THE DEBT UNTIL WE MAIL THE REQUESTED INFORMATION TO YOU. YOU SHOULD CONSULT AN ATTORNEY FOR ADVICE CONCERNING YOUR RIGHTS AND OBLIGATIONS IN THIS SUIT. p''''-,_", -, ~ . '.' ,<^, _ "_~.' ',;"'_i",- ~ I "'"1 ~ 'If "~-r~~ ," -, -. "~ 1. Plaintiffis: GMAC MORTGAGE CORPORATION 500 ENTERPRISE ROAD SUITE 150, HORSHAM, PA 19044 2. The name(s) and last known addressees) of the Defendant(s) are: DANIEL K. KULIG JilL ANN KULIG 905 MAPLEWOOD LANE, ENOLA, P A 17025 who is/are the mortgagor(s) and real owner(s) of the property hereinafter described. 3. On 6/12/98 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 COlmty, in Mortgage Book No. 1461, Page 488. 4, The premises subject to said mortgage is described as attached. 5. The mortgage is in default because monthly payments of principal and interest upon said mortgage due 3/1/01 and each month thereafter are due and tmpaid, 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." ,'''~": - - "'-" , ~ ," '-,' r-""" I""" ~"" ."~,. s~:~"" -. <, ,,, '1" ,J,~,__~",,_, ='- 6. The following amOlmts are due on the mortgage: Principal Balance Interest 2/1101 through 10/1/01 (Per Diem $29.03) Attorney's Fees Cumulative Late Charges 6/12/98 to 10/1101 Cost of Suit and Title Search Subtotal $151,392.89 7,054.29 4,000.00 248.64 750.00 $163,445.82 Escrow Credit Deficit Subtotal 0.00 868.65 $ 868.65 TOTAL $164,314047 7. The attorney's fees set forth above are in conformity with the Mortgage documents and Pennsylvania Law, and will be collected in the event of a third party purchaser at Sheriffs Sale. If the Mortgage is reinstated prior to the Sale, reasonable attorney's fees will be charged. 8. This action does not come under Act 6 of 1974 because the original mortgage amount exceeds $50,000.00. 9. The Combined Notice has been sent to the Defendant(s) by regular and certified mail as required by 35 P.S. g16800403c 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 $164,314.47, together with interest from 1011101 at the rate of$29.03 per diem to the date of Judgment, and other costs and charges collectible under the mortgage and for the foreclosure and sale of the mortgaged property. ~L~ /s/ Frank Federman FRANK FEDERMAN, ESQUIRE Attorney for Plaintiff i <Je;.,_,,~,. _ __"" _, '0;' . ^, po'"~ ,"~___"~,~, 1-[" - . r-- 1"'-- ~ ".~:"~" ,!'I-": 10/23/01 11:00 F~X I4J 008/012 --~--,-\~------ --,--, Rr$.l Morlgage Coan Servicing 3451 Hammond I"'ve P,Q,Box 780 . Waterloo, IA 50;'04.0780 '-J '-'GMAC Mortgage - Date: May 24, 2001 ACT 91 NOTICE TAKE ACTION TO SAVE YOUR HOME FROM FORECLOSURE This is an otlkial notice tltat the momal!e on vonr home is in default. and the lender intends to foredose. 80edfie information about the natore of the default is provided in the attached oa!!es. The HOMEOWNER'S MORTGAGE ASSISToV'ICE PROGRAM IHEMAP) DIlIv be able to helo to save vour home. Tlds Notice exolains how the llro@ram works. To see ;~HEMAP can helo. vou must MEET WITH A CONSUMER CREDIT COUNSELING AGENCY WI'I'BlN 30 DAYS OF THE DATE OF THIS NOTICE. Take this Notice with vou wheu vou meet with the Counselinl! Al!8ncv. The llalll1e. address and nhonenumber of Consumer Credit Counselin!! A\!endes servin vour County are listed at the end.ofthis Notice.. U vouhave anv qnestions. Vall maveaUthe Pennsylvania Honsinl! Finance A!I!encv toB free at 1.800.342.2397. aenon. with Imoaired hearin!! ean caB (717) 78(}.l86!1). This Notice contain. important legal information. Uyou have any questions, representatives at the Consumer , Credit Couns"ling Agency may be able to help explain it. You may also WllDt to contact an attorney in your area. The local bar association may be able to help you find a lawyer. LA NOTIFICACION EN ADJUNTO lS DE SUMA IMPORTANCIA, PUJES AFECTA SU DERECHO A CON11NUAl!. VIVIENDO EN SU CASA. SI NO COMPRENDE EL CONTENIDO DE ESTA NOTlFICACION OBTENGA UNA TRADUCCION IMMEDIATAMENTE LLAMANDO ESTA AGENCIA (PENNSYLVANIA HOUSING FINANCE AGENCY) SIN CARGOS AL NUMERO MENCIONADO ARRIBA. PUIEDES SER ELEGlBLE PARA UN PRESTAI'-fO POR EL PROGRAMA LLAI'-fADO "HOMEOWNER'S EMERGENCY MORTGAGE ASSISTANCE PROGRAM" EL CUAL PUEDE SAL V AR SU CASA DE LA PERDIDA DEL DERECHO AREDIMIR SU BIPOTECA HOMEOWNllR'S NAME(S): PROPERTY ADDRESS: JILL A. KULIG 905 MAP1,EWOOD LANE ENOLA, PA 17025-2069 LOAN ACCT. NO.: ORIGINAL LENDER: CURRENT LENDERlSERVICER: 493472609 N/A GMAC Mortgage Corporation 'XHBTA. i A"-~n:'W!f "" 'i"~- _~_ " ~ 'T'''1' " _.o,~,_... '0/23/01 10:58 FAX I4J 003/012 --_.~----~-----'_. Fir:;1 Marlgag8 il.oan Servicing 3451 Hammond' Ave P.Q;, Box 780 Waterloo, IA 50704.0780 '--./ '-' GMAC Mortgage - Dare: May 24. 2001 ACT 91 NOTICE TAKE ACTION TO SAVE YOUR HOME FROM . FORECLOSURE This is aD official Dotice that the lUOmal!e on vour home is In default. and the lender intends to loreclose. Specitic mlormatioD about the nature olthe delault is provided in the attached paees. The ROl\11EOWNER'S MORTGAGE ASSISTANCE PROGRAM tIlIEMAP) ma\l be able to help to Sllve vour home. This Notice explains how the pro2J'llm works. To see .fREMAP can help. vou must MEET WITH A CONSUMER CREDIT COUNSELING AGENCY WITHIN 311 DAYS OF THE DATE OF THIS NOnCE. Take thit Notice wilJJ \IOU wheJl vou meet with lJJe CouJlsellJle Al!encv. The naPI!!. address and Dhone number 01 COBsumer Credit Coanseliinl! Aunties serviu vour Countv are listed at the end or this Notice. If \IOU i\;l\le an.. questions,v01l IDaV eaII the Pennsvl"D!a R01ldDe FInance Aeenev toB lree at 1.800..342.23!1'1. IPenons with imllaired heariJ12 ean call (7171780.1869). This Notice contains important legal inlormation. If fOU have any questions, representatives at the Cons1llDer Credit CounseUng AgeuC)' may be able to help expbnn it Y01l may also waDt to contact aD attorney in Y01lr area. The local bllJ' associatioD may be able to help you find a lawyer. LA NOTIFICAClON EN ADJUNTO ES DE SUMAlMPORTANCIA, PUES AFECTA SU DERECHO A CONTINUAlll VIVIENDO EN SU CASA. SI NO COMPl,mNDE EL CONTENIDO DE EST A NOTIFICAaON OBTENGA UNA TRADUCCIONIMMEDIATAMENTE LLAMANDO ESTA AGENCIA (pENNSYLVANIA HOUSING FINANCE AGENCY) SIN CARGOS AL NUl\tERO MENCIONADO ~A. PUEDES SER ELEGmLE PARA UN PRESTAMO POR EL PROGRAMA LLAMADO "HOMl;:Q\VIllER'S EMERGENCY MORTGAGE ASSISTANCE PROGRAM" EL CUAL PUEDE SALV AR SU CASA DE LA PERDIDA DEL DERECHO A REDIMIll SU HIPOTECA HOMEOWNI~.R'S NAME(S): PROPERTY ADDRESS: DANn:L K. KULIG 905 MAPI,EWOOD LANE ENOLA, PA 17025,2069 LOAN ACC1l'.NO.: ORIGINAL LENDER: CURRENT LENDER/SERVlCER: 493472609 N/A GMAC Mortqage Corporation IKHBT A " . ~ '11 ,- r ~ ~. - ~~~.- ~"..~, ,",' "'~ .~"-'""', ,lO/23/01 10:59 FAX @J004/012 '--" '-...-. HOMEOWNER'S EMERGENCY MORTGAGE ASSISTANCE PROGRAM YOU MAY BE ELIGIBLE FOR FINANCIAL ASSISTANCE WHICH CAN SAVE YOUR H~ME FROM FORECLOSURE AND HELP YOU MAKE FUrURE MORTGAGE PAYMENTS IF YOU COM:l'LY WITH THE PROVISIONS OF THE HOMEOWNER'S EMERGENCY MORTGAGE ASSISTANCE ACT OF 198~ (THE" ACr), YOU MAY BE ELIGmLE FOR EMERGENCY MORTGAGE ASSISTANCE: IF YOUR DEFAULT HAS BEEN CAUSED BY CIRCUMSTANCES YOUR CONTROL, IF YOU HAVE A REAsONABLE PROSPECT OF BEING ABLE TO PAY YOUR MORTGAGE PAYMENTS, AND IF YOU MEET OTHER ELIGmD.J.TY REQUIREMENTS ESTABLISHED BY THE l'ENNSYLV ANIA HOUSING FINANCE AGENCY. ~:] TEMPORARY STAY OF FORECLOSURE -- Under the Act, YOll are entitled to a tempomy slay of forecloSUIll on your mortgage for thirty (30) days from the date of this Notice. During that time you must arnmge and attend a "face-to-face" Ineeling with one of tho coDStll11er credit COl\l1SOIing agencies listed at the end oflhis Notice. THIS MEETING MUST OCCUR WITHIN THE NEXT (30) DAYS. IF YOU DO NOT APPLY FOR EMERGENCY MORTGAGE ASSISTANCE. YOU MUSt BRING YOUR MORTGAGE UP TO DATE, TIlE PART OF TIllS NOTICE CALLED "HOW TO CURE YOUR MORTGAGE DEFAULT". EXPLAINS HOW TO BRING YOUR MORTGAGE UP TO DATE. CONSUMER CREDIT COUNS11.T ,ING AGENCIES -- Ifyoll meet with one of the consumer credit counseling . agencies listed at tho end of this notice, the lender may NOT take action against you for thirty (30) days after the date . ofthis meeting.The names. addresses and telenhone numbers of desitmated consmner cxedit cOllnseling agencies for the co\ in which the ro is located aIll set forth at the end of is Notice. It is only necessary to schedule one face-to-face m"eting. A vise yo\U, lender.immediatelv ofyo\1r intentions, APPLICATION FOR MORTGAGE ASSISTANCE -- Y Oll1'mortgage is in default for the :reasons set forth later in this Notice (see following pages for specific infonnation about the nahlIe of YOlI1' defa\1It.) 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 Homeowners Emergency Mortgage Assistance Program. To do so, YOll must fill out, sign and file a completed Homeownets Emergency Assistance Program Application with one of the designated conS\uner credit cmlnseling agencies listed at the end of this Notice. Only consumer credit counseling agencies have applications for the program and they will assist YOll in submitting a complete application to the Pennsylvania Housing Finance Agency. Y 0\11' application MUST be filed or postmarked within thirty (30) days of yo \I face-to-face meeling. YOU MUST IFILE YOUR APPLICATION PROMP1LY.1F YOU FAIL TO DO SO OR IF YOU DO NOT FOLLOW TElE OTHER TIME PERlODS SET FORTH IN THIS LETTER, FORECLOSURE MAY PROCEED AGAINST YOUR HOME IMMEDIATELY AND YOUR APPLICATION FOR MORTGAGE ASSISTANCIE WILL BE DENIED. ;,:,1 \", AGENCY ACTION -- Available funds for emergency mortgage assistance are very limited. They will be dis buzsed b,Y the Agency under the eligibility criteria established by the Act. The Pennsylvania Housing Finance Agency has s~ty (60) day. to make a decision after it receives your application. During that time, no forecLoS\1Ie proceedings Wlll be pursued agamst YOll if you have met the time requirements set forth above. You will be notified directly by the Pennsylvania Housing Finance Agency ofits decision on your application. FXHtBlT A' t'ik~'l'J'l1r.,<_ }. "."'~" '1--1 141005/012 ;_0/23/01 ].0:59 FAX '-" '-./ NOTE' xFYOU ARE CURRENTLY PROTECTED BY THE FILING OF A PETITION IN BA1~RUPTCY, rim FOLLOWING PART OF TIDS NOTICE IS FOR INFORMATION PURPOSES ONLY AND SHOULD NOT BE CONSIDERED AS AN ATIEMPT TO COLLECT THE DEBT. (If you have med bankruptcy you can stDl apply for Emel'll,ency Mortgage Assistance.) HOW TO CURE YOUR MORTGAGE DEFAULT (Brio" it UD to date). NATURE OF THE DEFAULT .- The MORTGAGE debt held by the above lender is on your property located at: 905 Maplewood Lane Enola"PA 17025-2069 IS SERIOUSLY IN DEFAULT because: YOU HAVE NOT MADE MONTHLY MORTGAGE PAYMENTS for the following months and the following amounts are now past due: March 1, 2001 through May 1, 2001. attached Exhibit for payment breakdown. Monthly Payments Late CbaIges NSF Inspections Other Suspense See 3,780.69 124.32 0.00 0.00 0.00 TOTAL AMOUNT PAST DUE: 3,905.01 B. YOU HAVE FAILED TO TAKE TIlE FOLLOWING ACTION (Do not use unot applicable); HOW TO CURE mE DEFAULT -- YoullllIY cure the default within relRTY (30) DAYS of the date of !his . notice BY P A'IING THE TOT AI.. MIOUNT PAST DUE TO THE LENDER, WHICH IS . $ 3,905.01 ,PLUS ANY MORTGAGE PAYMENTS AND LATE CHARGES WHICH BECOME DUE DURING TIlE TIllRTY (30) DAY PERIOD. Pavments nmst be made either bv cash. cashiers check. certified check ormonev omermade pavable and sent to: Payment Processing GMAC Mortgage Corporation PO Box 780 Waterloo, IA 50704'0780 You can cure mny other default by taking the following action within TIllRTY (30) DAYS of the date of this letter. (Do not use if not applicable.) Nt' l' bl o npp 1ca e IF YOU DO NOT CURE THE DEFAULT n If you do not cure the default within TIlIRTY (30) DAYS of the date oflhis Notice, the lender intends to exercise its ri"hts to accelerate the mortea"e debt, This means that the entire outstand~ balance o!this debt will be considered due innnediately and you may lose the chance to pay the .mortgage m monthly InStallments. Iffull payment of the total amolmt past <hie is not made within THlRTY (30) DAYS, the lender also intends to insmact its attorneys to start legal action to fondose upon vour mortueed propertv. IF THE MORTGAGE IS FORECLOSED UPON -- The mortgaged property will be sold by the Sheriff to payoff the mortgage ,lebllfthe lender refers yom case to its attorneys, but you cure the delinquency before !he lender begins Ie.gal p'Xlceedings against you, you will still ha required to pay the reasonable attorney's fees that were actually mcun"d, up to $50.00. However, iflegal proceedings are started against against you, you will have to pay all reasonable attorney's fees actually inclarred by the lender even if they exceed $50.00. Any attorney's fees will be added to the ammmt you owe the lender, which may also include other reasorulble costs. Ifvou cure t1J,e default within the THIRTY (30) DAYS period. vau wiD 1II0t be required to nav attome,"s fees. 8t A ~ 1'~!J'! -, _'_"'i:'-~'"';' '1_' '__. , "'1- " . ~. '" ~.,~~~,,~_, _~ ~ '_''1~ 10/23/01 ~l:OO FAX 141006/012 '. '--' '-/ OTHER LENDER REMEDIES -- The lender may al,o ,ue you personally for the unpaid principal balance and all other sums due under the mortgage. RIGHT TO CURE THE DEFAULT PRIOR TO SHERIFF'S SALE --If you have not =d the default within the THIRTY (31l) DAY period and foreclo,me prooeedings ha~e begun, vou still have the riEht.to Clare the default and prevent the sale at anv time UP to one hour before the Shenfi', Sale. You mav do so bv llaVlne: the total amolmt then ~t dUe, ll/u$ anv late or other ohanzes then.due. reason.able attorney's ~s I1l!d co~~ cOIDleoted with the . forealp&lu:C sale and any other costscoIDleoted \V1th the Shei:ifl's Sale as slle~ed m writinE bv the lend~r an~ by :perfolming any other reOlUrements under the mOrll!a~e. Cunng your default m the manner set forth In thiS notice wiD restore your mortgage to the saID'! pos tion as if you had uever defaulted. EARLmST POSSIBLE SHERIFF'S SALEDATE -- It is estimated that the earliest date that &llch a Sheriff's Sale of the mortgaged property could be held would be approximately six (6) montl1ts from the date of this Notice. A notice of the aclual date of the Sheriff's Sale will be sent to you before the sale. Of course, the amount needed to cure the defatut will increase the longer you wait Yon may find out at any time .xactly what th. reqlUred payment or action will b~ by contacting the lender. HOW TO CONTACT THE LENDER: Name of Lender: Address: GMAC Mortgage Corporation 401 Mile of Cars Way National City, CA 91950 Phone Nwnber: Fa" Number: Contaot Person: (800 I 850 -4622 (619) 470-5579 Collection Department ,"~! ;':i :\ EFFECT OF SoHERIFF'S SALE -- You sholud realize that a Sheriff's Sale \vill end your ownership of the mortgaged property and YOlII right to occupy it. If you continue to live in the property 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. ASSUMPTION OF MORTGAGE -- Y Oll my or may not sell or tmnsfer your home to a buyer ormmsferee who will assume th" mortgage debt, provided that all the outstanding payments, charges and attorney's fees and costs are paid prior to or at the sale and that the other requirements of the mortgage are satisfied. ;;;; YOU MAY ALSO HAVE THE RIGHT: TO SaL THE PROPERTY TO OBTAIN MONEY TO PAY OFF THE MORTGAGE DEBT OR TO BORROW MONEY FROM ANOTHER LENDING INS1TIUTION TO PAY OFF THIS DEBT. TO HAVE THIS DEFAULT CURED BY ANY THIRD PARlY ACTING ON YOUR BEHALF. TO HAVE THE MORTGAGE RESTORED TO THE SAME POSITION AS IF NO DEFAULT HAD OCCURRED, IF YOU CURE THE DEF AULT. (HOWEVER, YOU DO NOT HAVE THIS RIGHT TO CURl, YOUR DEFAULT MORE THAN THREE TIMES IN ANY CALENDAR YEAR.) TO ASSERT THE NONEXIS1ENCE OF A DEF AUL T IN ANY FORECLOSURE PROCEEDING OR ANY OTHER LAWSUIT INSTI11JTED UNDER THE MORTGAGE DOCUMENTS, TO ASSERT ANY OTHER DEFENSE YOU BELIEVE YOU MAY HAVE TO SUCH ACTION BY THE LENDER. TO SEEK PROTECTION UNDER THE FEDERAL BANKRUPTCY LAW. , CONSUMER CREDIT COUNSELING AGENCIES SERVING YOUR COUNTY IS ENCLOSED EXHIBlT A ;i~__~...,.,""""""_,,,, ,,' '''~,. r_'. 1--"~""" "I " " " " ~ ~.m!, "" " TI n I ' ~ r '^"- .' " PENNSYLV AI'lIA HOUSING FINAl 'iCE AGE:-lCY HOMEOWNER'S EMERGENCY ASSISTAI'lCE PROGRA.'o1 CONSUMER CREDIT COUNSELING AGE:-lCIES (REV. 8/00) CLINTON COUNTY Lycoming-Climon Counties Commision for Community Action (STEP) 2138 Lincoln Street P_O. Box 1328 Williamsport, PA 17703 (570) 326.0587 FA-'< (570) 322.2197 CCCS of Northeastern PA 20 I Basin Street Williamsport. P A 17703 (570) 323-6627 FA-'< (570) 323-6626 COLUMBIA COL';'lTY 31 W, Market Street POB 1127 Wilkes-Barre. PA 18702 (570) 821-0837 or (SOO) 922,9537 FAX (570) 821.1785 Commission on Economics Opportunity of Luzeme County 163 Amber Lane Wilkes-Barre, PA 18702 (570) 826-05 to or (800) 822.0359 FAX (570) 829. I 665-{Call Before Faxing) (570) .55-199. Hazeltown FAX (570) .55-5631-{Call Befnre Faxing) (570) 836-4090 Tunkhannock CRAWFORD COL'NTY Booker 1. Washington Center 1 no Holland Center Ene, PA 16503 (SI.) .53-5744 FA-'< (SI.) 5749 John F. Kennedy Center, Inc. 2021 East 20th Street Ene. PA 16510 (81.) 898,0400 FAX (81.) 898-12.3 CUMBERLAND COUNTY CCCS of West em Pennsylvania, Inc. 2000 Linglestown Road Harrisburg, P A 17102 (717) 541-1757 Urban League of Metropolitan Harrisburg N. 6th Street Harrisburg, PA j7101 (717) 23.-5925 FAX (717) 23.,9459 Community Action Comm of the Capital Region IS 14 Derry Street Harrisburg, PA 17104 (717) 232,9757 FAX (717) 234-2227 CCCS of Northeastern PA 1631 South Atherton St, Suite 100 State College, PA 16801 (81.\) 238-3668 FAX (814) 238.3669 1400 Abington Executive Park Suite 1 Clarks Summit. PA 18411 (570) 5S7,9163 or (800) 922,9537 FAX (570) 587-9134~9135 Greater Erie Community Action Committee 18 West 9th Street Erie. PA 16501 (SI.) 459-1581 FAX (814) .56.0161 Shenango Valley Urban League, Inc. 601 Indiana Avenue Farrell, PA 16121 (412)981,5310 FinanCial Counseling Services of Franklin 31 West3rdStreet Waynesboro, P A 17268 (717) 762.3285 YWCA of Carlisle 301 "G" Street Carlisle, PA 17013 . (717) 243-3818 FA-'< (717)-731.9589 Adams County Housing Authority 139-143 Carlisle St. Gettysburg, PA 17325 (717) 334.1518 FAX 334.8326 PENNSYLVA.'l1A BULLETIN, VOL. 29, :'110. 23, JlJ"'NE 5, 1999 r-<>:i~~~i\ . '71F'!,,-', i-1~ . '''''",I , n ~\TA . '~."I"'r_~_~~""'< ~ =~>'1"" ~,,_ ALL THAT CERTAIN lot or Ieee of ground situate in the Township of East Pennsboro. , Cumberland County, Pennsylv nia bounded and described according to a cerrarn Final Plan for Penn Valley Phase I, prepared by H rtman Be Associates, Inc., Enginecrs and Surveyors, Camp Hill, , Pennsylvania, dated June 23. 1 93 and last revised September 9, 1993 and recorded on November 5, 1993 in Plan Book 67 page 20, as follows, to wit: , BEGINNING at a point on the orthwcst side of MapIewood Lane and a corner of Lot No. 52 on said Plan; thence extending along d lot north 09 degrees 45 minutes 15 seconds west 101.61 feet to a point in line of Lot No. 47 on id plan; thence extending along said lot and continuing north 80 degrees] 4 minutes 45 seconds st 80.00 feet to a point, a corner of Lot No..49 on said plan; thence extending along said lot and co dnuing south 09 degrees 45 minutes 15 seconds east 129.98 feet to a point on the northwest side of Ntaplewood Lane; thence extending along said lane along a curve having a radius of 200.00 feet, the arc distance of 85.53 feet to the point and place of beginning. I , , I BEING Lot No. 51 i CONTAINING 9,005.33 SQU4.RE FEET BEING PART OF THE SAME!PREMISES which James A. Acri, as Executor of the Estate of Edith Loretto Acri, and as Trustee of the Testamentary Trust of Ovidio Acri, and James A. Acri, individually, by Deed dated Notember 22, 1993 and recorded in the Office for recording of Deeds in and for Cumberland County in peed Book IDa, Page 148, and Deed Book R36, Page 155, granted and conveyed unto Penn Valley iCorporation, a Pennsylvania corporation, in fee. ,- PREMISES ON: i.' '''-'''"~'f'?'~'''', 1_' .-"- -.., I, ,-' , , fr, , . ~ . -~~.... ~ ~,,-<--~ ':'f.~~~"4_ '-'f;"\'~?" 'k~ ,':'t~-''-:'"'r._U' ~'~'I VERIFICATION KRISTINE-WILSON hereby states that she is FORECLOSURE SPECIALIST of GMAC MORTGAGE CORPORATION mortgage servicing agent for Plaintiff in this matter, that she is authorized to take this Verification, and that the statements made in the foregoing Civil Action in Mortgage Foreclosure are true and correct to the best of her knowledge, information and belief. The undersigned understands that this statement is made subject to the penalties of 18 Pa. C.S. Sec. 4904 relating to unsworn falsification to authorities. C)0.wr;" () - Ui.f/wiU DATE: /0/73/01 . I / :;')~,:.}",);),.,,,, ,_,F -.~, ",'_r_ -, -I -,-,'" " i&f 'h '~"~"~,,_' '^" Ie..... ." Jf'i ''-'~'-lirn''':iJj'~::~'&rr"\'''tn~t.:~~W'Y:;t'':.' i"~'. ~ ltf"i'i;ie'~~1gfPl~:::'\r'ifi.Ei'1'$''4."0;,,,,;S'''>''~'''''' ^' " " ,.'Im"., :rr>-;~,~v~~Stk9 "" ~~ ~ ~ ~. ~. ....... ~ ~ ~ ~ ~ ~ ~ ''', ~ ,~~ .~~lr ,LJN":='~[ft':,_ !,;\_",,, ""_r~,,~~_~llW"'''''~I''''~_,~!!IF:~~~;:~'!ii1ll~F<''!1'2-m~,~;:""~ .'-',C",,,) :',,, ,-e~__ ~ 'f'~T-.?l/!-r'I:![iQ!"J1f'i'!l)c':r~jlr-'",,!_~l"~-lf"i'""~'";~ "'''''!!i'-f'<.r<~",'I'~!!W1''~f~'F.1 (') C ~F ri3 r% """- ,I' ~~i: ~~'"-) ~f: ):;> -.. C 7::' :::;! ~ C) (1; co n -.4 N cr., :~n ."'" ~'~ ~D -< ',e)~T~'''"lTtlm''fI(rr'Jt'' c - ,~"-- :3PU- AFFIDAVIT OF SERVICE CUMBERLAND COUNTY PLAINTIFF GMAC MORTGAGE CORPORATION No. 01-6134 CIVIL DEFENDANT(S) DANIEL K. KULIG JILL ANN KULIG ACCT. #493472609 SERVE JILL ANN KULIG AT 1225 SOUTH MARKET STREET MECHANICSBURG, PA 17055 Type of Action - Notice of Sheriff's Sale Sale Date: MARCH 6, 2002 Served and made known to at do: 0 ~" o'clock em., at SERVED ~ , Defendant, on the 11.0 e+5+. day OfJi'WIUNi f 20Q . (. Commonwealth of Pennsylvania, in the manner described below: ..t.-Defendant personally served. Adult family member with whom Defendant(s) reside(s). Relationship is Adult in charge ofDefendant(s)'s residence who refused to give name or relationship. Manager/Clerk of place oflodging in which Defendant(s) reside(s). Agent or person in charge of Defendant( s)' s office or usual place ofbusiness'I\lO+-e: '\ h -e 6l'o~v€... an officer of said Defendant(s)'s company. _"'\... .l~'l~~ 'IS Ji 1\ s. plaCe. Other: ..,.,00 = . I I' ~ D+ \au.~'I()e.s.s: Agea'8"L3d-.-Height~ Weighd~-1I5Racew::Lsex~ Other 6cD~~ ( I, & a true and correct copy of the the address indicated above. , a competent adult, being duly sworn according to law, depose and state that I personally handed otice of Sheriff s Sale in the manner as set forth herein, issued in the captioned case on the date and at Sworn to and subscribed before me this _ day of ,200_. Notary: By: PLEASE ATTEMPT SERVICE AT LEAST 3 TIMES. INDICATE DATES & TIMES OF SERVICE ATTEMPED. NOT SERVED On the day of ,200_, at o'clock _.m., Defendant NOT FOUND because: Moved Uuknown No Answer Vacant Other: ~~~---" , By: Notarial Seal US2. M. Greasor., Notary Pubiic em'lis!':; 80,0. C1.!rr:bf.:riand Cc, (,,',,",' .-;r,"I";-,:-,I,h'_ii;-)I; :'~- , or e forPI . tiC Frank Feder Ii, E uire - I.D. No. 12248 One Penn C er at Suburban Station 1617 John F. Kennedy Boulevard, Suite 1400 Philadelphia, PA 19103-1814 (215) 563-7000 !ct1'~b;;~_~,_ .'" ,. '. r< --1 ,-- , "-,~ "", ~l,! ~~'l)WlP!J\~ .'11",. ,~ ~ ",~," , I'''' '" ~.", " < ,',,, "~h'<, "<l,' -"""~"''-'<'J;it\;iG{;i>~''i&J~ 'l:i'VA!ld ~~"\~rlti,">\Pij""-ll1'If'Mi rrjf~'Jfl[ti;rjfl~r-"JTt1li''fo')lft !f-1;'rr~'(~~if"1t~;,};t: ~._ "_.~tI!!l!~ 0 ~"~.. () C ['., T: ~ ::'::,-, "tl 'Pm ,." r nn-' C-:-'J 'z: =-~H zr~ ~~~E co ~(_:'} *\) 5= C) =:: "-{J 5>(~ !,;,' Z :J =<: to ~ ~p(tlli'i:~?-l\"iJ"4\i'!"'~'''''T>V"'''7'!,,,;,,,",-,,,,n::';;''W\''Hr''~';''':t-!f''g.'''''~F~m)'!r'm;lC-Wi'!%,(\'Wi',~!l'!'1"!i~~J11"~*~t "",__,r",,,' ", '" __',~-,-'~I"_. '^ ^ _ FEDERMAN AND PHELAN By: FRANK FEDERMAN, ESQUIRE IDENTIFICATIONNO.12248 ONE PENN CENTER AT SUBURBAN STATION, SUITE 1400 PHILADELPHIA, PA 19103-1814 (/1~) ~hi-7000 ATTORNEY FOR PLAINTIFF COURT OF COMMON PLEAS CNIL DMSION GMAC MORTGAGE CORPORATION CUMBERLAND COUNTY vs. No.: 01-6134 DANIEL K KULIG JILL ANN KULIG AFFIDAVIT OF SERVICE OF NOTICE OF SHERIFF'S SALE PI JR STJ A NT TO P R c: P , 404(/)/401 FRANK FEDERMAN, ESQUIRE, Attorney for Plaintiff, hereby certifies that service of the Notice of Sheriff's Sale was made by sending a true and correct copy by certified mail to Defendant, at 905 MAPLEWOOD LANE, ENOLA, P A 17025, which notice of Sheriffs Sale was received by Defendant, on 12/17/01 as evidenced by the attached return receipt. The undersigned understands that this statement is made subject to the penalties of 18 P A C.S. s 4904 relating to unsworn falsification to authorities. 9- ~ 9:;-"/?-,, . FRANK FEDERMAN, ESQUIRE Date: Fp,hm~ry h. ?om or""',!!'1!'i Ie" ~ . ~~ '-I " ~ , ~ --'~'t'- rl!l"'_'~"""" J. ~;-..!>;'3 '_"_'~ ,--.-.--------.--....-.---.-.---.----.-.-----.---.--.-..........-.......-...-. 2. Article Number 1111111 ?J.bD 3'1]1 'taqq t.S3D q'l'll 3. Service Type CERTIFIED MAIL 4. Restricted Delivery? (Extra Fee) Yes 1. Article Addressed to: DANIEL K. KULIG 905 MAPLEWOOD LANE ENOLA, P A 17025 SALES (493472609) PS Form 3811, July 2001 D. Is delivery address different from Item 17 If YES, enter delivery address below: Domestic Return Receipt JPG ,. " ),- . ,-,- -H o Agent OA_. o v,. QNo ~'41~" ,'". K' ~""' ,~- , ,,-.'~ .~~~,.. ,"""'--,~ ;o":J,.';>' '"""'-"*,,,v,v"-'Y'w{rii~Jrn~"~:- 'ID~JmTIrrif:j~lf''r~;';i o c:: 2~_ "ofe rntOL Z:i_' [~S.-: :~~~-, \"""'..-' --... c. ~~! 2"-:, _O'J -, Cl j"J- -n "~1 ~c:o .liS ll/ .... "''il , " ;:..- I Cf) ~',E, '.' -___cJ '-1" .-:) C> , 1":" '.::~ :;:l -<. -,:. r:0 C:I I _ ,~" .. ," I"'_~"~"~ ~,_j,.1- ,!li', n,)iI'l.\~,"'fff'~!@:l'I'l~~!ffl'~'_F'1""",~,r~"-__-o;i.,'Y.-;1"_,,,~,,~,o-.~"t<!"""';~W:'!':~~~'>>O~'~il'~fP;~'1i'f'1<;'"'<""-'c;:''f'~itlilW'ffl.'f~~~1': ''")l~''''r~-''rr''r'' -,' I'~, ,.~ .< ., SALE DATE: MARCH 6. 2002 IN THE COURT OF COMMON PLEAS OF CUMBERLAND COUNTY, PENNSYLVANIA CNIL ACTION - LAW GMAC MORTGAGE CORPORATION No.: 01-6134 CNIL vs. DANIEL K. KULIG JILL ANN KULIG 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: 905 MAPLEWOOD LANE. ENOLA. PA 17025. 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. 3l29.2(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. J, ~ ~ / FRANK FEDERMAN, ESQUIRE Attorney for Plaintiff February 25, 2002 ,hWlif~'," . , '1 ~- ,I ~~" ~~,~ ~:;.;f/'t;,,-;,~:~,'-' >, ~.~ " GMAC MORTGAGE CORPORATION CUMBERLAND COUNTY Plaintiff, COURT OF COMMON PLEAS v. DANIEL K. KULIG JILL ANN KULIG CIVIL DIVISION NO. 01-6134 CIVIL Defendant(s). AFFIDAVIT PURSUANT TO RULE 3129 (Affidavit No.1) GMAC MORTGAGE CORPORATION, Plaintiff in the above action, by its attorney, FRANK FEDERMAN, ESQUIRE, sets forth as of the date the Praecipe for the Writ of Execution was filed the following information concerning the real property located at ,905 MAPLE WOOD LANE, ENOLA, PA 17025. L Name and address ofOwner(s) orreputed Owner(s): Name Last Known Address (if address cannot be reasonably ascertained, please indicate) DANIEL K. KULIG 905 MAPLEWOOD LANE ENOLA, P A 17025 JILL ANN KULIG 1225 SOUTH MARKET STREET MECHANICS BURG, P A 17055 2. Name and address of Defendant(s) in the judgment: DANIEL K. KULIG 905 MAPLEWOOD LANE ENOLA, P A 17025 JILL ANN KULIG 1225 SOUTH MARKET STREET MECHANICSBURG, PA 17055 3. Name and last known address of every judgment creditor whose judgment is a record lien on the real property to be sold: Name Last Known Address (if address cannot be reasonably ascertained, please indicate) None. t,;':l_~~[I\'1'~.'o,O"'I_"" ,.,,,. ',>.O"~~_"'", ,,"" _'1,'_ ,'oj' '-'1 " - ~ "~ ~~ ~~~~- If - , ....... N;j',:ti';f,*l'0\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) TMS MORTGAGE, INC. 1770 TRIBUTE RD., SUITE 109 SACRAMENTO, CA 95815 5. Name and address of every other person who has any record lien on the property: Name Last Known Address (if address cannot be reasonably ascertained, please indicate) None. 6. Name and address of every other person who has any record interest in the property and whose interest may be affected by the sale. Name Last Known Address (if address cannot be reasonably ascertained, please indicate) None. 7. Name and address of every other person of whom the plaintiff has knowledge who has any interest in the property which may be affected by the sale: Name Last Known Address (if address cannot be reasonably ascertained, please indicate) Tenant/Occupant 905 MAPLEWOOD LANE ENOLA, P A 17025 Domestic Relations of Cumberland County 13 North Hanover Street Carlisle, PA 17013 Commonwealth of Pennsylvania Department of Welfare PO Box 2675 Harrisburg, P A 171 05 I verify that the statements made in this affidavit are true and correct to the best of my personal knowledge or information and belief. I understand that false statements herein are made subject to the penalties of18 Pa. C.S. Sec. 4904 relating to unsworn falsification to authorities. t ~ rJ~ FRAJ{KFEDERMAN,ESQUIRE Attorney for Plaintiff December 7.2001 DATE ,F;,,-?Iill: " I "', "~-'\ ,~ I~-'CT." " 'rn' ' . "~ ~il ~ -" " ::9."" ~ ~ . . - - ::z 'J< ... - - - " g w tv - - 0 '" o a CO -.} ~. 0- '" ro' ... t"" ,< 0 w tv ~. w~ - 0 ~ ... ~ > \C> "" ::I. ... ..., c;' N P ijj <7\ 0 ::' z \C> c: "'.; 3 o 0 . - cr g '" ClI " Z ... ~o 0 ..., a& ..., 8 ci'~ ~ ~ tj z . 0 CIl ~ . 0:; ~ a ~ :> . ., ~~. 0 z I m So . m ':::l CIl > " !:1 ..., .. "tl 0 (i !;- ;t. ~ () ~ .P B ~ . " "" Cl '" i; sn ..., ~ ~ :>- Z ~ ::l ~ - . \C r 0 0 0 - fJ'd' .. 0 ~ >-n Z .., v.> .. . '" _0 -. ..., CIl ~ , o " -.) c tT1 - ~ . '" n 0 00 . . -.} ~ . ~ 0 ~ '"' 3 - -" ... ~ ..., () ~ ~ ~ ~ ..., ~ c:: > '" 11 e;; ~ .. " tJ:I !;- or . 0 I ~ ~ tJ:I ~ " . ~ m "" Q CIl m 8 ~ ~ c: ~ .:> _. . ,El tj ~M.Ft :;:" t"" 0 " - ~. tj !!.... CIl ~ m -0 c:: ..., () ~ 0 :=1 o~ ~ or " ~t::;g:;'-l m ~ ~ ... ~~*@~ ..., ;a;i~8S 0 0 ~ .>< .'" t"" _(II S::l - .?> - ;;;,~~~g CIl w ;:l :.. -. '" - :> ..., 0 B ~ 3' ~. g. [ () :> >-n ~ 3 s, 6 g' ~ - ~ !:1 ~ . O':r t:;;;' 0 -.) "\ ~ 0 m . < ... R- g g :;' tv t"" ::I: 320~a- I '" ~ ~ ,." _.:::. 8l/Q ... Z g~"'d:a rh" ..., 'c '; --' . ~ fog ~ g:;:; ,0 B '" ~ g ...g . 0" . S,k2 g@' () ..., <: , , . .- g tn' ~ ;: ~ :> 0 m ?-~~:::~~,:;. ~ bOO g ~ ::l '" tJ:I '" u~.~;f. ~ 0" '" 0 CIl " . g ii 5 g- co X ~ - O'gli"~ '" tv ... ><... '" 0 0- @ 3' ~;:;. -.} ~. c:"'d '" , .'" .'" 1i ~. ~ S- o:: ~ @ ::l '" ::r :> e-li"$:iS" ~ a 2!..3 ~ o -. :::; _. ~... ~ ~ is f;j' - CIl ~ ::l '" ~ e. tJ:I ~~ ::l <i c:: ,m g;~~~' .ES :; o 0 g <'II 1!. o 0 " 0; .miil 0- :; - 0 ~ ~ ~ ..., "- H~I 0 . - :;; 0 ..., ~ f;~' a - 0 '" . ~ ~ e. ! I '" ~ x ~ ~ i? ..-----:::::;.; ~=~J 4 I go L .'__ _ 1 ~...,~__.r'" ""~_ ~,-.....:"~....=-,,,,==4' s . , 7',>-""-(, . . jJ;,\,1 >. i}nSl~bt \: \l 3:' .'../ .( 'if '" ~\..." : . ~ _. 0 f _ ..' -:;..,.7 JI \" ~~ ....... me.,.)' ;' '!':" a; ~ - \ f"! n ::. ,- . . \.> " . . ';. \:: ,0 '- -:: ~ . /:'3'10''- ~:" \... P>' /00030;'0----'-"'" ! ---,/ . I I I i " ~ , I , , . = ,""" ..'" " y ?i<"~"'" I ]f, ,,", - I~ o>z ...,co.., ~:;-a = '" '" co."''' '" '" = ... co. ""-~- :T <7\.' :::.0...... tI:1 ...,"0 o......>tlm -~g~ 'rjrl"- . 11l Z ?:~~ ::I ... ~ !a ~go"<:l g;[@ "crt'"' (5"'Cll> ;;,Z o.S' :l'. g .,;;0"'" .~~ l :6\ j _, I .'''~ -, -'--~~rr~ .....,~ (~.7 DATE: TO: ALL PARTIES IN INTEREST AND CLAIMANTS NOTICE OF SHERIFF'S SALE OF REAL PROPERTY OWNER(S) DANIEL K. KULIG JILL ANN KULIG PROPERTY: 905 MAPLEWOOD LANE ENOLA, PA 17025 Improvements: Residential Property CUMBERLAND COUNTY The above-captioned property is scheduled to be sold at the Sheriff's Sale on MARCH 6, 2002, at 10:00 a.m. in Cumberland County Courthouse, South Hanover Street, Carlisle, PA. Our records indicate that you may hold a mortgage or judgment on the property, which may be 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 I__!',r' ,,~'~_'I_ r ~ " , I ' - II r~1 ~~_.,..... 0Th',it"if;'i.~~~S',;.!i\-w""hli'id" "--.~-- ~- ~~--""'''-'.<'~.''-' . ~, ~' SALE DATE: MARCH 6. 2002 IN THE COURT OF COMMON PLEAS OF CUMBERLAND COUNTY, PENNSYLVANIA CNIL ACTION - LAW GMAC MORTGAGE CORPORATION No.: 01-6134 CIVIL vs. " DANIEL K. KULIG JILL ANN KULIG J.filUHNEY FilE COpy PLEASE RETURN 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: 905 MAPLEWOOD LANE. ENOLA PA 17025. As required by Pa. RC.P, 3l29.2(a) Notice of Sale has been given in the manner required by Pa. RC.P. 3l29.2(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. 1 ~ , J.:\ I I UiiNc:.Y f!l:~ copy February 25, 20<i'lEASE RE ,URN FRANK FEDERMAN, ES UIRE Attorney for Plaintiff ;~"Ilffi"l1'~_. -"..", .., ,'I J "-"~ =" . ,~~" --" ~- ~.. 1'''- ","' ',"",'-'N ";:i''''-,,'~.:;.r--''c~Tr''lt'fflt~Ir:':'''''Jtr>;;''~rr ~~, T~ rfl~-"~.I~~jjir~f""c;""_'~":"'rr-rn-rl;~1:~P*j.~~?il ., (') c> '__I C l''V <" -" -0 a] Pl ., nlr--;-i c:a -;" -,--, . t;~c~ !'., ~_:, CO - . !.-::,) r<CJ "'" .- ~.' )>c~ _L ,. Z ~ .:-~I 5>(") 9 ;~~)f"n C S;! z ~" =< ~:D (..J -< c-y 8>1 ~ ~. ~c~-'''"''''r-''~-'''' 'Ill!_~~~~!!!IJ~I'lp!~~w.mo:"~l!e-"'?FI'Y-"~,~""",:;,~",,,;,;,,,'-o." i'~:'""i')~'11fift"'#'f-'"'I\ffi~""'F~lifi"'"'l%'l!"CI''''-'''i'''!;Ol'l'>':i!l~~~,in!o? g-'~'1"'''---' ,.~ Corrected Deed ".I STATE OF PENNSYLVANIA, COUNTY OF CUMBERLAND } SS. Robert P Ziegler I, ______________________________________________________________________________Ilecorderof Deeds in and for said County and State do 'hereby certify that the Sheriff's Deed in which _________n.U__ Secretary of Veterans Affairs . ___________________________.________________________________________________________ ~ thegr.antee 6th the same having been sold to said grantee on the ___._______________n__________n______._______ day of March . 2002 " __u__________________n_______n__n___ A. D., , n___' under and by virtue of a wnt______________ 11th Execution . _______________________ __________ .__u ___ __n__ _ ISSued OIl the ___ _____ _ ____ _____ ____ ____ ________ ___ 2001 __no' out of the Court of Cornman Pleas of said County"as of 20'P . December day of __________________________ A. D., Civil ------------------------------... _____u _ .______ __ ____ _____ ___ u____ ________ __ _n__ Term, : 6134 GMAC Mtg Corp Number ______________, at the suit of ------u----_________nn___n_______________.____n________n_ DAniel K Kulig & Jill Ann ----------_________________________against____________________________________________________ 6 duly recorded in Sheriffs Deed Book No. ___::~______, Page _____!_~~=.._. IN TESTIMONY WHEREOF, I have hereunto * set my hand and seal of said office th~ __j~____u day ""~""'-__o ,~ '-, M r'-<~~ ill "'I ri. - "~~ , , -~,,',,~' " "",.~" '''''-.;,~'' ""h--""""-""'~-'~- .-' '" - '1'1"'"Ilm'miiiii''Iilil:r"rit'',I''''\ 1I'I,~"""""_"!lI,_lt>~,,,", ~_'ft',-;,~1:<i.'1tK~i.:'i_'1it:~~''''~'f'i ~ '~ ~, ,~ - '~~~'-<"'~"'~-"~ ,~,.__,!1-I$1~~~~~~~"'~U;'''':.;!-Jlj~:-j''2~''';:''S'''''''''''-;;'-':C,~ "~-",,,,' ;:'Ji",;\""~"1fo;'3'-;q""i'"'fV)P~"-'C"'r!':1''f,,"~-,t''JAjfr~(~.ffiff~{ 'w')""" ft'r,Ti' lJrC'flM "'..,," STATE OF PENNSYLVANIA, COUNTY OF CUMBERLAND } ss. Robert P Ziegler I, _____________________________________________________~________________________Flecorderof Deeds in and for said County and State do 'hereby certify that the Sheriff's Deed in which ________________ GMAC Mtg Corp ---------------------------.---------------------___________________________________ ~ the grantee 6th the same having been sold to said grantee on the -______________________________________________ day of March ' .2002 " ________________________________________ A. D., , _____, under and by vIrtue of a wnL____n_______ Dee day of __________________________ A. D., Civil ------------------------------,. ------- - -- ------- -- ---------- n________ ____ ____ ___ T enn, : 6134 GMAC Mtg Corp Number ______________, at the suit of ________________________________..______________________________ Execution . 11 th -------------------------_______________________~uedonthe_____________________________________ 2001 -----, out of the Court of Cornman Pleas of said County'as of 2001 ---------------------------- ------- against____ ______n___ ___ __ n___ ____ ____ __ ____ ______ _______ is Daniel K Kulig & Jill Ann duly recorded in Sherifrs Deed Book No. _______:_~~_, Page ____________~9 IN TESTIMONY WHEREOF, I have hereunto set my hand and seal of said office this ___L______ day /Tr"" f of ____________n________________ A. D., ~::_-~----------------- Recorder of Deeds 2<n' z.--- , ""'" ~ - ,..."., '<~.'~ '. ~. , GMAC Mortgage Corporation VS Daniel K. Kulig and Jill Ann Kulig In The Court of Common Pleas of Cumberland County, Pennsylvania Writ No. 2001-6134 Civil Term Timothy Reitz, Deputy Sheriff, who being duly sworn according to law, states that on January 17, 2002 at 7:33 o'clock pm, EST, he served a true copy of the within Real Estate Writ, Notice and Description, in the above entitled action, upon, the within named defendant, to wit: Daniel K. Kulig, by making known unto Daniel K. Kulig, personally, at 905 Maplewood Lane, Enola, Cumberland County, Pennsylvania, its contents and at the same time handing to him personally the said true and correct copy of the same. Jason Vioral, Deputy Sheriff, who being duly sworn according to law, states that on December 21,2001 at 4:41 o'clock pm, EST, he served a true copy of the within Real Estate Writ, Notice and Description, in the above entitled action, upon the within named defendant, to wit: Jill Ann Kulig, by making known unto Jill Ann Kulig, personally, at 1225 S. Market Street, Mechanicsburg, Cumberland County, Pennsylvania, its contents and at the same time handing to her personally the said true and correct copy of the same. Gerald Worthington, Deputy Sheriff, who being duly sworn according to law, states that on January 08, 2002 at 1:40 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 Daniel K. Kulig and Jill Ann Kulig located at 905 Maplewood Lane, Enola, 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: Daniel K. Kulig, by regular mail to his last known address of 905 Maplewood Lane, Enola, P A 17025. This letter was mailed under the date of January 28, 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: Jill Ann Kulig, by regular mail to her last known address of 1225 S. Market Street, Mechanicsburg, P A 17055. This letter was mailed under the date of January 28,2002 and never returned to the Sheriffs 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 Courthouse, Carlisle, Cumberland County, Pennsylvania on March 6, 2002 at 10:00 o'clock A.M., EST. He sold the same for the sum of$l.OO to Attorney Frank Federman for GMAC Mortgage Corporation. It being the highest bid and best price received for the same, GMAC Mortgage Corporation of 500 Enterprise Road, Suite 150, Horsham, PA 19044, being the buyer in this execution paid SheriffR. Thomas Kline the sum of $761.50, it being costs. r;Himf;,Wf}~ "1",-'-- ,,,' ,""" , I' " ~", - ="""""~~, i~ t ~~ ~..,." , ~J'<""d'~< '"^,.,,,,--,"' 'r""jl.,.-,;!i"",,!$'il2!;:_~~L~ ~ , Sheriff s Costs: Docketing Poundage Advertising Posting Handbills Acknowledging Deed Auctioneer Law Library Prothonotary Mileage Certified Mail Levy Surcharge Law Journal Patriot News Share of Bills Distribution of Proceeds Sheriff s Deed $30.00 14.93 15.00 15.00 30.00 10.00 .50 1.00 17.25 .82 15.00 30.00 284.00 222.30 24.20 25.00 26.50 $761.50 Sworn and subscribed to before me This ~ day of () k1<,JJ , 2002, AD. ~ a. ~/#' Pro onotary ~~ ""<:~.4 R. Thomas Kline, Sheriff BY ~ eLl J~-bbc Real Estate Deputy ~~ .Jo,vv p-v Ck....3f-Olf~ ~. j).37/ 'i ~< - ~ 1!!!11Ml'i!lol r e~~~"_'~" " 7"4'Bj''[('''''~'''" . - == . ,~ - .~I GMAC MORTGAGE CORPORATION CUMBERLAND COUNTY . Plaintiff, COURT OF COMMON PLEAS v. DANIEL K. KULIG JILL ANN KULIG CIVIL DIVISION NO. 01-6134 CIVIL Defendant(s). AFFIDAVIT PURSUANT TO RULE 3129 (Affidavit No.1) GMAC MORTGAGE CORPORATION, Plaintiff in the above action, by its attorney, FRANK FEDERMAN, ESQUIRE, sets forth as of the date the Praecipe for the Writ of Execution was filed the following infonnation concerning the real property located at ,905 MAPLEWOOD LANE, ENOLA. PA 17025. L Name and address ofOwner(s) orreputed Owner(s): Name Last Known Address (if address cannot be ,reasonably ascertained, please indicate) DANIEL K. KULIG 905 MAPLEWOOD LANE ENOLA, P A 17025 JILL ANN KULIG 1225 SOUTH MARKET STREET MECHANICSBURG, P A 17055 2. Name and address of Defendant(s) in the judgment: DANIEL K. KULIG 905 MAPLEWOOD LANE ENOLA, P A 17025 JILL ANN KULIG 1225 SOUTH MARKET STREET MECHANICSBURG, P A 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. ,",W\~&1~-,o"", _I J ,.,", ''',~ ~_, '. ~~ -~ "~ r~""&'^ ~""'-=" ._~'''O' ,'^ ^ 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) TMS MORTGAGE, INC. 1770 TRIBUTE RD., SUITE 109 SACRAMENTO, CA 95815 5. Name and address of every other person who has any record lien on the property: Name Last Known Address (if address cannot be reasonably ascertained, please indicate) None. 6. Name and address of every other person who has any record interest in the property and whose interest may be affected by the sale. Name Last Known Address (if address cannot be reasonably ascertained, please indicate) None. 7. Name and address of every other person of whom the plaintiff has knowledge who has any interest in the property which may be affected by the sale: Name Last Known Address (if address cannot be reasonably ascertained, please indicate) Tenant/Occupant 905 MAPLEWOOD LANE ENOLA, P A 17025 Domestic Relations of Cumberland County 13 North Hanover Street Carlisle, P A 17013 Commonwealth of Pennsylvania Department of Welfare PO Box 2675 Harrisburg, PA 17105 I verify that the statements made in this affidavit are true and correct to the best of my personal knowledge or information and belief. I understand that false statements herein are made subject to the penalties ofl8 Pa. C.S. Sec. 4904 relating to unsworn falsification to authorities. December 7.2001 DATE t ~(rJ~ FRAJ{KFEDERMAN,ESQUIRE Attorney for Plaintiff ')i--OJ ~u, '~n ~_ .~__,," <,1,'" . ,-" .,. - o q-r - ==~ ;;''')(11'''''- ,- , -~ ~ ~, . ~~" GMAC MORTGAGE CORPORATION Plaintiff, CUMBERLAND COUNTY v. No. 01-6134 CIVIL DANIEL K. KULIG JILL ANN KULIG Defendant(s). December 7, 2001 TO: DANIEL K. KULIG 905 MAPLEWOOD LANE ENOLA, PA 17025 JILL ANN KULIG 1225 SOUTH MARKET STREET MECHANICSBURG, PA 17055 ..THIS FIRM IS A DEBT COLLECTOR ATTEMPTING TO COLLECT A DEBT AND ANY INFORMATION OBTAINED WILL BE USED FOR THAT PURPOSE. IF YOU HAVE PREVIOUSLY RECEIVED A DISCHARGE IN BANKRUPTCY AND THIS DEBT WAS NOT REAFFIRMED, THIS IS NOT AND SHOULD NOT BE CONSTRUED TO BE AN ATTEMPT TO COLLECT A DEBT, BUT ONL Y ENFORCEMENT OF A LIEN AGAINST PROPERTY... Your house (real estate) at, 905 MAPLEWOOD LANE, ENOLA, PA 17025, 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, P A 17013, to enforce the court judgment of 166,230.45 obtained by GMAC MORTGAGE CORPORATION (the mortgagee) against you. Ifthe Sheriffs sale is postponed, the property will be relisted for th~ 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: L The sale will be cancelled if you pay to the mortgagee the back payments, late charges, costs and reasonable attorney's fees due, To find out how much you must pay, you may call: (215) 563-7000. 2. You may be 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.) 'f',~~:_J '", ,'.e " ,. '"1'11'>'"-" " I'; I,,: ;,1 !"j , " i,J 1.1 , Ii I-! " :; !; ~,~~,~"". "~,I, YOU MAY STILL BE ABLE TO SAVE YOUR PROPERTY AND YOU HAVE OTHER RIGHTS EVEN IF THE SHERIFF'S SALE DOES TAKE PLACE. 1. Ifthe Sheriffs Sale is not stopped, your property will be sold to the highest bidder. You may find out the price bid by calling (215) 563-7000, 2. You may be able to petition the Court to set aside the sale if the bid price was grossly inadequate compared to the value of your property. 3. The sale will go through only if the buyer pays the Sheriff the full amount due in the sale. To find out if this has happened, you may call (717) 240-6390. 4. If the amount due from the Buyer is not paid to the Sheriff, you will remain the owner of the property as if the sale never happened. 5. You have the right to remain in the property until the full amount due is paid to the Sheriff and the Sheriff gives a deed to the buyer. At that time, the buyer may bring legal proceedings to evict you. 6. You may be entitled to a share of tIre 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, P A 17013 (717) 249-3166 (800) 990-9108 ,.. "--,,' ,. . _or - i--'" "f- """"'("""""'_"'_"."e'" . -, . ,0-'- -"', ..--/ ALL TH.-\ T CERT.-\I:-i 1m or piece of ground siruate in the Township of East Pennsboro. Cumberland Coumv. Pennsylvania bounded and described according to a certain Final Plan for Penn Vallev Phase .. ~ ..... ~ 1. prepared by Hartman and Associates. Inc" Engineers and Surveyors. Camp Hill, Pennsylvania. datd June 23. 1993 and last revised September 9. 1993 and recorded on ;.iovember 5. 1993 in Plan Book 67. Page 20, as follows. to wir: BEGIXNING at a poim on the Northwest side of Maplewood Lane and a corner of Lot '\0. 52 on said Plan; thence extending along said Lor North 9 degrees 45 minutes 15 seconds \Vest 101.6l feet to a poim in line of Lot No. 47 on said Plan: thence extending along said Lot ami continuing :'Iorth 80 degrees 1-1- minutes 45 seconds East 80.00 feet to a poim, a corner of Lot :'la, 49 on said Plan: thence extending along said Lot and conrinuim: South 9 degrees 45 minutes 15 seconds East 129.98 Ieee [0 a - '-' .......... point on the Sorthwest side of Maplewood Lane; thence extending along said lane along a curve having a radius of 20000 feet, the arc distance of 85,53 f~et to the point and place of beginning. BEING Lor ;.io. 5l CONTA.INL'lG 9,005,33 square feet. Tax Parcel #13-0999-094 TITLE TO SAID PREMISES IS VESTED IN Daniel K. Kulig and Jill Ann Kulig. his wife bv Deed from Penn Valley Corporation, a Po.. Corp. dated 1/ 111'9~ and'recorded 1/29/97 in Reco~d Book 152. Page 754. ,,~\,~ -'_'_';7~"~,,o, ,,,,~~,"-. .-',,<'_ -''"''--'--' " ~ - " ,~--,"'"'''"'" " ~. WRIT OF EXECUTION.and/or ATTACHMENT . COMMONWEAL TH OF PENNSYLVANIA) COUNTY OF CUMBERLAND) NO. 01-6134 CIVIL 19 CIVIL ACTION, LAW CUMBERLAND TO THE SHERIFF OF COUNTY To satisfy the debt, inferest and costs due _~MAc:...tJl()rtgage Corporation from,_. Danie.:': K. Kulig, 905 Maplewood Lane, Kulig, 1225 S. Market St., Mechanicsburg Enola PA 17025 PA 17055. PLAINTIFF(S) and Jill Ann DEFENDANT(S) Real estate located (1) You are directed to levy upon the property of the defendant(s) and to sell at 905 Maplewood Lane, Enola PA 17025. (See attached legal descript6n. ) (2) You are also directed to attach the property of the defendant(s) not levied upon in the possession of __ GARNISHEE(S) as tollows and to notify the garnishee(s) that: (a) an attachment has been issued: (b) the garnishee(s) is/are enjoined frorn paying any debt to orJor.the account of the defendant(s) and from delivering any property of the defendant(s) or otherwise disposing thereof; (3) If propertyofthe defendant(s) not levied upon an subject to attachment is found inthe possession of anyone other than a named garnishee, you are directed to notify him/herthat he/she has been added as a garnishee and is enjoined as above stated. Amount Due Interest 12/6/01 $166,230.45 to 3/6/02 $2,459.70 L.L. $.50 $1.00 Atty's Comm Atty Paid Plaintiff Paid % Due Prothy Other Costs $132.25 Date: December 11, 2001 CURTIS by Deputy REQUESTiNG PARTY: Name Address: Frank Federman, Esq. 1617 JFK Blvd., Ste 1400 ~-- PA 19103 1814 Attorney for: Telephone: Philadelphia Plaintiff (215) 563 7000 12248 Supreme Court 10 No. h!t-w"~,'tJ'~l' _ _" "", ~~ ;;: , < I I ~ , ~~l ~., rf _L~ I -- 0 _~ -"" - '<<~' ,-- ,~ "" ,.", '" '.'-nr;llmrn1'<1.1t"T""#I'~ . REAl ESTATE SALE No. 55 On December 13,2001, the sherifflevied upon the defendant's interest in the real property situated in East PennsboroTownship, Cumberland County, P A, known and numbered as 905 Maplewood Lane, Enola and more fully described on Exhibit "A" filed with this writ and by this reference incorporated herein. Date: December 13,2001 By: q6~-Srni1h Real Estate Deputy V"IN'f'^l^S~HI3d :1-1 C:_;": H';':) 10. Wd ZE 8 ZI 330 A1Nnco G~,!\i -1~.J'U~no ':!':!1~3HS 3!1l JO 3al~~O ~ ~ ~ ~ Co" -,;,,:, '-C-'C'"_'; ,'y,~,,"C:I, ',",^ "','-"<:r-'-f-~~'S":ii'l'i0%~~~'~J!li!WI~t7; ,;"',,- _ ~ ,~,.,....",!m!1L,".,,_~.'lfm-fE!l16J!llrn_~ ~, _;;>'o/'~~'l'"!'W'j~l~r~l$r~~-R,*~___'>'''imw-:;r,;;~t;!~Wi'4l'l!~~'ff1f'':!t';>F.-W'''-P~!_'I''''"1"'.'-",'-,,,,,, ,:wo ~ -n r , PROOF OF PUBLICATION OF NOTICE IN CUMBERLAND LAW JOURNAL (Under Act No. 587, approved May 16, 1929), P. L.l784 STATE OF PENNSYL VANIA : ss. COUNTY OF CUMBERLAND : 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 ofthe said Cumberland Law Journal on the following dates, VIZ: JANUARY 25, FEBRUARY 1, 8, 2002 Affiant further deposes that he is authorized to verify this statement by the Cumberland Law Journal, a legal periodical of general circulation, and that he is not interested in the subject matter of the aforesaid notice or advertisement, and that all allegations in the foregoing statements as to time, place and character of publication are true. } Roger M. Morgenthal, Editor ~ SWORN TO AND SUBSCRIBED before me this 8 day of FEBRUARY. 2002 NOTARIAL LOIS E.SNYD1~\.~:'~1c CarliSIEI Boro. "U1...."a'N My Commisalon Expires Man:h 5. ':"''''~f,j'!*'<W::~7, '1', . . "'~~~'~~JlO'."-''''1~--.' -~~. ~1"'V 11 [Ii' , __'l!':'-"11-'I"',TIi -,,<. "'i"'"" ~ ,~, ~, , - I" REAL ESTATE SALE NO. 55 Writ No. 2001,6134 Civil GMAC Mortgage Corporation vs. Daniel K. Kulig and Jill Ann Kulig Atty.: Frank Federman ALL TIiAT CERTAIN lot or piece of ground situate in the Township of East Pennsboro. Cumberland County, Pennsylvania botulded and described according to a certain Fi~ na1 Plan for Penn Valley Phase I. prepared by Hartman and Associ- ates. Inc.. .Engineers and Survey- ors, Camp Hill. Pennsylvania. dated Jnne '23. 1993 and last revised Sep- tember 9, 1993 and recorded on November 5. 1993 in Plan Book 67, Page 20. as follows. to wit: BEGINNING at a point on the Northwest side of Maplewood Lane and a corner of Lot No. 52 on said Plan; thence extending along said Lot North 9 degrees 45 minutes 15 seconds West 101.61 feet to a point in line of Lot No. 47 on said Plan; thence extending along said Lot and continuing North 80 degrees 14 minutes 45 seconds East 80.00 feet to a point, a comer of Lot No. 49 on said Plan; thence extending along said Lot and continuing South 9 degrees 45 minutes 15 seconds ~ast 129;98'feet to a point on the Northwest side of .Maplewood Lane; thence extending along said lane along a curve having a radius of 200.00 feet. the arc distance of 85.53 feet to the point and place of beginning. BEING Lot No, 51. CONTAINING 9,005,33 square feet. Tax Parcel # 13,0999,094. TITLE TO SAID PREMISES 18 VES1ED IN Daniel K. Kulig and Jill Ann Kulig. his wife by Deed from Penn Valley Corporation. a Pa. Corp. dated 1/17/97 and recorded 1/29/ 97 in Record Book 152. Page 754. ,,-,--. 'I ..~ . ... ~~_ ~h THE PATRIOT NEWS THE SUNDAY PATRIOT NEWS Proof of Publication Under Act No. 587, Approved May 16,1929 Commonwealth of Pennsylvania. County of Dauphin} ss Michael Morrow being duly SWOrn according to law. deposes and says: That he is the Ass!. 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 Sundav 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 pubiished 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 countYlD . phin in Miscellaneous Book "M", Volume 14, Page 317. PUBLICATION .................... .. .. ...... COpy Sworn to and subscribe SALE#55 Notarial Seal Terry L Ru..~I, Notary Public Harrlsburg,OauphlnCounty ARY PUBLIC My Comrll's.'on Expires June 6 2002 , commission expires June 6, 2002 Member, P6nnsylvanla Assocletion 01 Notaries CUMBERLAND COUNTY SHERIFFS OFFICE CUMBERlAND COUNTY COURTHOUSE CARLISLE, PA. 17013 Statement of Advertising Costs To THE PATRIOT-NEWS CO., Dr. For publishing the notice or pubiication attached hereto on the above stated dates $ Probating same Notary Fee(s) $ Total $ 220.80 1.50 222.30 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.................................................................... 1'tffi~!l!I_ ,~, ,p. ~,~ e, " I .... ~~ ".- , ,~ , l'" REAL ESTATE SALE No. 55 writ No, 2i)llHl.134 CMITerm GMACMorlgago COipo_ration vo Osnial K.l(ulig and -Jill. Ann Julig ;::.'tty:~::Fr.al1k Federmin f::).>ES('lutmJN~,:- :.-_--:---- :_.-'_ "'-:_--':':,,--: ~:xA;l;.I~:.-1~fl...r.. J:::J):.K1:~\~ JQt" 9r,:_ p,itx;~f~~f-:~:CiuQ;:t.: ': ;:::::::::~~::<:rii_::the;::':'l~n~hiii:::~f:,#itili:-\l~ti..*~~_;-, t::.;.':::~$'ffli.',' ~li'iiif::{,':P:rilifj~_,:_:Pe...,-_itii~,YN;tUI~,,::.)Nii.'~'~fulf r::':':::~a.a.3~t9l'l~_ ~~oP,rdinK t<;:r:,.l'cC~.i:t 'l'l:n,~::'pllw "'''f<~'::~~: Yall~,ji "PIifu~-l; prepa!i...:t h)" fIartmaij find .Ai\:m\:;hu~, '1m:.; -F!lIsrineerii ttui1 Sun";~'(}t~, Camp Hill. Pennsylv-.:mia._ d;tled hme 23, 19:(, Hild .IllS! :r~'li!i<:q.: :SL'PrelIrl"'~r 9, 1993. and -recorded ()n-_.N()~'tmil:>l.';t s; rmn_lll Phm BOl)k , :Q1. Pag;e20~ as follm.'Zi,.tn 1ir1t" , .s.mprNNrNG ;!t,_1l Jl_oilit :Ofi_ the_Nf11fb\\-'t~t ~lde ::-'fjfM'Wlew~i(l!ll4iti~ ~D_Q;i ~!i1;l~i'_(lf Lot No, 52 , ;:;ii--~:jld P!im-;-t1i~ii~i-~,irtliiLitkt.;:--a:kl1l!J_~;tld 1.,)t Nm:ili 9_lk,grel."s.45 minutes J.'i-_~~,Jttd~-W~~t '---HH.f,l focj'tl'-il-pl)j:rifhdiite-~!fLiltNQ. .~7 Oil ::W~l PI.dl:; tl1en1::e:_e,~,:tefl,jin:g- Il!Cl(l,g I'jild-_Lot _and ,c(intlnatIlE_-NIJ.rtk S.o .dew.-':S': 14_ minute-!o 45 li~'()ndsE3~t Sr.LOO fe.eU~) l-l point,_H ~;{H't'ler.of J~!).t_ No, A.-9 ml s.aW Plaa; thcru;c. l:xtend_G;Lg ;::,alollg ~llirJ"LQL.md_<Clmtblliltlg Souttl_9 deW:f-e~ 'is-minute!;; _l3.!<<([ltd~ East 129.98 fed to a 't>_Cthit _Oil_ .the:-- NCI[t11~\e.~t ,.;ide, _91' M~4....vrJl;;.d L&TJe; thence ex!tmdln;g_aIOTIl.t_,~J.lld hlne ,tllmg ill Cti:tife:-,li'lf\:-j-tlj(a nUlla..; of :lOO.DO_ fect:, tl1J:: art' :di.'iUltll.."e_ of85,53 fee:t 1,(1 tbe pnlnt.ll.rn~ place "f -,bc.gilm1tlg. ,- 'BETNG:L~(nil, j.l 'C;aNTAmJN.G_9:005J3 ;;quare f~t. '-:-,Taj;-PakeJ #1 3'()9,9ft.H94. .TlTL.E'fOSAlD PREMISES IS ya'.TED IN '::Datlid K.: f[lJ.Ii$~ imd,_li1l.Atln_J{ullg, hi!' wifi:: 'by 'D~-fmrn f~,'t1t1- Vli11t'.)'_-CIll]l!ltittion~ Ii_ P:it. Corp.' dated lfl1.!91 and Wl.,"lm1t.'Ii 1119/91 ill .~:~~l.I~"_~OQ~ _I?J_~ _~~~~~~:____ __"___