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Home My WebLink About01-06416 -....._--.-~ _~.r .' -... MARTHA E. VON ROSENSTIEL, ESQUIRE MARTHA E. VON ROSENSTIEL, P.C. 16 SOUTH LANSDOWNE AVENUE PO BOX 457 LANSDOWNE, PA 19050 Attorney ID # 52634 IMC Mortgage Company a/k/a Industry Mortgage Company, L.R. d/b/a Core West Bank d/b/a Core West Mortgage Company d/b/a NLG Mortgage Company 5901 E. Fowler Avenue Tampa, FL 33617 Plaintiff vs. James E. Pedrick 6214 Whitehall Drive Mechanicsburg, PA 17055 Defendants J ,c ' ~L J ,~ ~~ , ;"""" "'iii.mt~j #9231 Attorney for Plaintiff COURT OF COMMON PLEAS Cumberland COUNTY Case No: 01 - I."'h Clu~tT~ CIVIL ACTION - MORTGAGE FORECLOSURE THIS IS AN ATTEMPT TO COLLECT A DEBT ANY INFORMATION OBTAINED WILL BE USED FOR THAT PURPOSE NOTICE ADVISO You have been sued in court. If you wish to defend against the claims set forth in the following pages, yon 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 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. Le han demandado a usted en la corte. Si usted quiere defenderse de estas demandas expuestas en las paginas siguientes, usted tiene veinte (20) dias de plaw al partir de la fecha de la demanda y la notificacion. Hace falta a sentar una comparencia escrita 0 en persona 0 con un abogado y entre gar a la corte en forma escrita sus defensas 0 sus objeciones alas demandas en contra de su persona. Sea a visado que si usted no se defiende, la corte toma ra medidas y puede continuar la demanda en contra suya sin previo aviso 0 notificacion. Ademas, la corte puede decidir a favor del demandante y requiere que usted cumpla con todas las provisiones de esta demanda. Usted puede perder dinero 0 sus propiedades 0 otros de rechos importantes para usted. LLEVE ESTA DEMANDA A UN ABOGADO INMEDIA T AMENTE. SI NO TIENE ABOGADO 0 SI NO TIENE EL DINERO SUFICIENTE DE PAGAR TAL SERVICIO. V AYA EN PERSONA 0 LLAME POR TELEFONO A LA OFICINA CUY A DIRECCION SE ENCUENTRA ESCRlTA ABAJO PARA A VERlGUAR DONDE SE PUEDE CONSEGUIR ASISTENCIA LEGAL. CUMBERLAND COUNTY BAR ASSOCIATION 2 LIBERTY AVENUE CARLISLE, P A 17013 717-249-3166 800-990-9108 "",. , ~ ~~ --~ J' , 0" ], , 0 ';-'-,,'" ..d.:" " .--,', '4-""~~~,~; , ,., , #9231 MARTHA E. VON ROSENSTIEL, ESQUIRE MARTHA E. VON ROSENSTIEL, P.C. 16 SOUTH LANSDOWNE AVENUE PO BOX 457 LANSDOWNE, PA 19050 Attorney ID# 52634 Attorney for Plaintiff IMC Mortgage Company a/k/a Industry Mortgage Company, L.R. d/b/a Core West Bank d/b/a Core west Mortgage Company d/b/a NLG Mortgage Company 5901 E. Fowler Avenue Tampa, FL 33617 Plaintiff COURT OF COMMON PLEAS Cumberland COUNTY Case No: 01- {..'It<.:, (?;~L '-r~ vs. James E. Pedrick 6214 Whitehall Drive Mechanicsburg, PA 17055 Defendants CIVIL ACTION - MORTGAGE FORECLOSURE THIS IS AN ATTEMPT TO COLLECT A DEBT ANY INFORMATION OBTAINED WILL BE USED FOR THAT PURPOSE 1. Plaintiff is IMC Mortgage Company a/k/a Industry Mortgage Company, L.R. d/b/a Core West Bank d/b/a Core West Mortgage Company d/b/a NLG Mortgage Company, a corporation organized and existing under state law, with offices for the conduct of business at 5901 E. Fowler Ave., Tampa, FL 33617. 2. Defendant, James E. Pedrick are the mortgagor and real owner of premises 6214 Whitehall Drive, Mechanicsburg, PA 17055, hereinafter described, whose last known address is listed in the caption. 3. Plaintiff brings this action in mortgage foreclosure against defendant, mortgagor and real owner, to foreclose a & ..............."."..,-- "' .,~ ~ ' I ; " ,,' ',",,' ""~",--~,, F" .. certain indenture of mortgage made, executed and delivered by the above named defendant, mortgagor and real owner to FHB Funding Corp. on January 21, 1997, which mortgage is recorded in the Office of the Recorder of Deeds of Cumberland County in Mortgage Book 1363, page 448, secured on premises 6214 Whitehall Drive, Mechanicsburg, PA 17055 a true and correct description of which is attached hereto as Exhibit I. 4. The mortgage has since been assigned to IMC Mortgage Company a/k/a Industry Mortgage Company, L.R. d/b/a Core West Bank d/b/a Core West Mortgage Company d/b/a NLG Mortgage Company; recorded November 22, 1999 in Miscellaneous Book 631, page 163, the plaintiff herein. 5. Plaintiff alleges each and every term, condition and covenant in the aforesaid mortgage, and hereby incorporates them herein by reference thereto. 6. The aforesaid mortgage is in default in that monthly installments of principal and interest have not been made conformity with the terms of the mortgage, from June 27, 2001 and each month thereafter, up to and including the present time. 7. Under the terms of the aforesaid mortgage, upon default of payments set forth in the mortgage documents, the entire principal balance and all interest due thereon are collectible forthwith. 8. The following is an itemized statement of the amount due plaintiff under the terms of the aforesaid mortgage: .~' 'MIllii J" " Principal Balance Interest from 5/27/01 to 11/1/01 At $41.27 per diem Accrued late charges to 10/3/01 Late charges due to 10/12/01 At $68.39 per month Accrued Escrow deficit to 10/3/01 Monthly escrow deposits from 10/27/01 At $115.37 per month Corporate Advances Monthly Inspections from 6/27/01 To 10/27/01 at $15.00 per month Attorney's Fee Title Information Certificate Photostats and Postage Notarizations TOTAL ~ J h ._~~ ,,'ol,",' ,"','C' , ",',;,<,'".,",'-", ';~Lii~ $150,794.00 $ 6,479.39 $ 478.14 $ 68.39 $ 2,768.90 $ 115.37 $ 22.74 $ 75.00 $ 7,500.00 $ 350.00 $ 45.00 $ 10.00 $168,706.93 9. Plaintiff sent to defendant, mortgagor and real owner a combined Notice and WarniQg of Intent~on to Foreclose and Notices of Homeowners' 'Emergency Mortgage Assistance Act of 1983 advising of rights available under, the statutes. To date payments have not been received and Act 91 assistance has not been granted although the app1'icable time periods provided by statute have expired. WHEREFORE, plaintiff demands judgment for $168,706.93, plus per diem interest at $41.27 from 11/2/01 to the date of judgment plus monthly late charges of $68.39 from 11/2/01 to the date of judgment plus monthly escrow deposits of $115.37 from 10/28/01 to the date of judgment plus monthly inspection costs of $15.00 of the mortgaged premises from 10/28/01 to the date of judgment and forecl // ,/ ~ ha E. Von Rosenstiel ~ Attorney for Plaintiff re ancf'sa1e Ii!! ;'!il,:ii>>fj,\:h~"{.\tJG~';;;,:tl";"",,::.:<l,, ":h;;"JtU::;'''';"''''~t'-~';;''''''1&1j,~~",)~-!,:-j";,;,:,);i~''0,,J-i'~;\.~-F!jJhi''';' "",,'V.;,,''''iI,,*,''''~'M.k'llIk~~~j~~ -- " ~ 7f ~ ~ "(q. 0 ~ (") (..1 C -i! ~ .~ :s: :;!: G ~ "'I:;!o:J 0 ;'~,~ -,1 6 [!; tIj .<>=".::. 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SHERIFF'S RETURN - REGULAR CASE NO: 2001-06416 P COMMONWEALTH OF PENNSYLVANIA: COUNTY OF CUMBERLAND IMC MORTGAGE COMPANY ET AL VS PEDRICK JAMES E HAROLD WEARY , , I,.~~""," , ',~""I!i<'-,hi,o;" , Sheriff or Deputy Sheriff of Cumberland County,Pennsylvania, who being duly sworn according to law, says, the within COMPLAINT - MORT FORE PEDRICK JAMES E was served upon the DEFENDANT , at 0015:40 HOURS, on the 21st day of November, 2001 at 6214 WHITEHALL DRIVE MECHANICSBURG, PA 17055 JAMES PEDRICK by handing to a true and attested copy of COMPLAINT - MORT FORE NOTI CE together with and at the same time directing His attention to the contents thereof. Sheriff's Costs: Docketing Service Affidavit Surcharge 18.00 6.50 .00 10.00 .00 34.50 Sworn and Subscribed to before me this J6-::::: day of ~ ,2mJJ A.D. ~,,(l~A~ othonotary . So Answers: ~~~~~~, R. Thomas Kline 11/26/2001 MARTHA VON ROSENSTEIL By: 7ku 4J. Deputy Sh~ ~" .---~ -' .~ "-~- I" ~ ' "' .",', !1iJ!;J~.ib,: ~ #9231-SF Martha E. Yon Rosenstiel, P.C. Martha E. Von Rosenstie1 16 South Lansdowne Avenue P.O. Box 457 Lansdowne, PA 19050 610 623-2660 Attorney LD.# 52634 Attorney for Plaintiff IMC Mortgage Company a/k!a Industry Mortgage Company, L.R. d/b/a Core West Bank d/b/a Core West Mortgage Company d/b/a NLG Mortgage Company 5901 E. Fowler Ave. TampaFL33617 COURT OF COMMON PLEAS CUMBERLAND COUNTY No: 2001-6416 Plaintiff vs. James E. Pedrick 6214 Whitehall Drive Mechanicsburg, P A 17055 Defendants PRAECIPE TO THE PROTHONOTARY: Enter judgment in the sum of $172,052.35 in favor of the above named plaintiff and against the above named defendants for failure to file an answer in the above action in Mortgage Foreclosure within twenty (20) days from date of service of the Civil Action, and assess damages. I hereby certify that the correct addresses of plaintiff and defendants are as follows: Plaintiff: 5901 E. Fowler Ave. Tampa, FL 33617 Defendants: 6214 Whitehill Drive Mechanicsburg, P A 17055 M a. Von Rosenstiel Attorney for Plaintiff "~ ,;lJoGl;" .,-, ~"~- ".~-- . , ;:" . J ~ ,,~ '.' " ,-~, ".. ~~'\i's" Martha E. Von Rosenstiel, P.C. Martha E. Von Rosenstiel 16 South Lansdowne Avenue P.O. Box 457 Lansdowne, PA 19050 610 623-2660 Attorney LD.# 52634 Attorney for Plaintiff !MC Mortgage Company a!kIa Industry Mortgage Company, L.R. d/b/a Core West Bank d/b/a Core West Mortgage Company d/b/a NLG Mortgage Company 5901 E. Fowler Ave. Tampa, FL 33617 COURT OF COMMON PLEAS CUMBERLAND COUNTY No: 2001-6416 Plaintiff vs. James E. Pedrick 6214 Whitehall Drive Mechanicsburg, P A l7055 Defendants ASSESSMENT OF DAMAGES TO THE PROTHONOTARY: Kindly assess damages against the above named defendants as per Civil Action in Mortgage Foreclosure, as follows: Total per complaint Additional interest on unpaid balances from 11/02/01 to 01/06/02 at $41.27 per diem Additional late charges from 11/12/0l to 01/12/02 at $68.39 per month Additional monthly inspections from 10/28/01 to 12/28/01 at $15.00 per month $168,706.93 $ 3,095.25 $ 205.17 $ 45.00 Total assessment $172,052.35 Martha E. Von Rosenstiel Attorney for Plaintiff AND NOW, to wit, this .7Jpe::-Jmy of Ja.v. ,2001, damages are assessed as above. CAA~? I<.~ Pro Prothy TI " "~ . '0' -. " " #9231 Martha E. Von Rosenstie1, P. C. Martha E. Von Rosenstiel 16 South Lansdowne Avenue P.O. Box 457 Lansdowne, PA 19050 610 623-2660 Attorney LD.# 52634 Attorney for Plaintiff !MC Mortgage Company, etc. COURT OF COMMON PLEAS Cumberland COUNTY Plaintiff vs. '. No: James A. Pedrick Defendant( s) AFFIDAVIT OF NON-MILITARY SERVICE COMMONWEALTH OF PENNSYLV ANlA: SS COUNTY OF DELA WARE ilL /JJAI,)j,-,,-~cL. (representative of the servicer for the Plaintiff, being duly sworn according to law deposes and says 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 ofthe Soldiers' and Sailors' Civil Relief Act of Congress of 1940, as amended; That James A. Pedrick is over 21 years of age and resides at 6214 Whitehall Drive, Mechanicsburg, P A 17055. This verification is made subject to the penalties of a8 Pa.C.S. 94904 relating to unsworn falsification to authorities.. , ~ - '~, , '" . ' ' , J.c-..-lf~ "% ~ --~_..- ~".. - .~~' ~~~ J""'" I "...:,.." ; I ._c. --,,",,' (jin~;ll':;'.~;' , MarthaE. VonRosenstiel,P.C. Martha E. Von Rosenstiel 16 South Lansdowne Avenue P.O. Box 457 Lansdowne, PA 19050 610 623-2660 Attorney I.D.# 52634 Attorney for Plaintiff IMC Mortgage Company a!k! a Industry Mortgage Company, L.R. d/b/a Core West Bank d/b/a Core West Mortgage Company d/b/a NLG Mortgage Company 5901 E. Fowler Ave. Tampa FL 33617 COURT OF COMMON PLEAS CUMBERLAND COUNTY No: 2001-6416 Plaintiff vs. James E. Pedrick 6214 Whitehill Drive Mechanicsburg, PA 17055 Defendants CERTIFICATION OF SERVICE MARTHA E. YON ROSENSTIEL, ESQUIRE, hereby certifies that she is the attorney for the plaintiff herein, and that service of the Notice under Rule 237.5 in the above matter was made on the defendants on December 20, 200l, as evidenced by the attached postal receipts. This verification is made subject to the penalties of 18 Pa. C.S. Section 4904 relating to unsworn falsification to authorities. Martha E. Von Rosenstiel, Esquire Attorney for Plaintiff DATED: January 15, 2002 ~~~.....,.~'""'" ,.~ "--.,~~ .- Martha E. Von Rosenstiel, P.C. Martha E. Von Rosenstiel 16 South Lansdowne Avenue P.O. Box 457 Lansdowne, PA 19050 610 623-2660 Attorney I.D.# 52634 _'~ """....J,~I-- ~ ~.-<N" ~illi".~" i,"~~_ '".:l!;'U,;,;1Ii~"'i #9231 SF Attorney for"Plaintiff IMC Mortgage Company a/k/a Industry Mortgage Company, L.R. d/b/a Core West Bank d/b/a Core West Mortgage Company d/b/a NLG : Mortgage Company COURT OF COMMON PLEAS Cumberland COUNTY Plaintiff Case No: 2001-6416 vs. James E. Pedrick Defendant TO: James E. Pedrick 6214 Whitehall Drive Mechanicsburg, PA 17055 Date of Notice: December 20, 2001 IMPORTANT NOTICE YOU ARE IN DEFAULT BECAUSE YOU HAVE FAILED TO ENTER A WRITTEN APPEARANCE PERSONALLY OR BY ATTORNEY AND FILE IN WRITING WITH THE COURT YOUR DEFENSES OR OBJECTIONS TO THE CLAIMS SET FORTH AGAINST YOU. UNLESS YOU ACT WITHIN TEN DAYS FROM THE DATE OF THIS NOTICE, A JUDGMENT MAY BE ENTERED AGAINST YOU WITHOUT A HEARING.. MID.. YOU, MAY LOi3E. YOUR PROPERTY OR OTHER IMPORTANT RIGHTS. AT ONCE. IF YOU DO NOT 10 TO OR TELEPHONE THE N GET LEGAL HELP: AUtK.tee.bere-f1 stamps ON1EdlBtJ<Postage and P'W iIl'l!l\. \!loul,. of Pt!I'e.'ster for current fee. '" ~ fit " !/) OUN/reO ~ O~ ~~; ..,?:~._::; ~i ~It)) f ,or '~;~~ 19) ~ ~I~ \ ;>-,,-S>y~ : ~II '....,';~..-"" ..00""" "-- 0 (7'. "'OW O~W .S. POSTAL SERVICE ER IFICA TE OF MA LING MA V BE USED FOR DOMESTIC AND INTERNATIONAL MAll. DOES NOT pROVIDE FOR INSURANCE-POSTMASTER Rece; d FromMARTHA E. VON ROSENSTlEl \ 15 S. LANSDOW ' P.C. P. O. BOX 457 I-NJSDO'NNr, PA 19050 One piece of ordin81'Y mail addressed to: James E. Pedrick 6214 Whitehall Drive Mechanicsburg, PA 17055 PS Form 3817. Mer. 1989 9~!3/ ","1"; 'CATION / iel f <~t!:~~~I1i'Sitfi!l'tt"'Sj;j'!t~!;;i'!i}j~",'L",;;j!t\~%i:Mt'lbid;;;,;iti~i'.-",~J;;",'f,i~1i?)i'FP};,""i,~~.;j!;""Ui>:';'i"'ld~'''J''''''"""",,g~ffi<,@!iii(Hil;i~~,,",~l>!Mi1a.OIlS~il1lli ",' (-:70 ~jk F ~ ~ ~ ~o \..~~ ~~i ....., (.J ~ 'iO () g s: "'One' mn~; ~e ({) -- -<:r,~,. ~C; :p.-. Z\. .J )>8 ~ - ij'- V1 -.. f! J ~ ,".',""""'",,'" ,~,' ""","~,,"""4-""'~;'~_"',,~..v ,,' _ "", ,~" ,,~, ~ ". _,,",w ,.",--,1.,._ ,,=~~. '~,~ ~, "- 0',"' " '~~,,"", ".- .~.".",. ,~""',.~, ~~~~- -~';" -. o fv <- ):;:. z o -n ,~ .~ foil]] r- -...,m ~iSX S::lu ",- t. "".", ~O Orn ~ -< N N """ :::it '!? w Ul ~=~,~._,..._,o, ~,'"", _,'," M~.1h.. ~ ~lIilllF. ='" -" , n - ! ' " ", ~'w.i.;, "4~Jejlll.,i;,~~" Martha E. Yon Rosenstiel, P.C. Martha E. Yon Rosenstiel l6 South Lansdowne Avenue P.O. Box 457 Lansdowne, P A 19050 610 623-2660 Attorney LD.# 52634 Attorney for Plaintiff IMC Mortgage Company a/kIa Industry Mortgage Company, L.R. d/b/a Core West Bank d/b/a Core West Mortgage Company d/b/a NLG Mortgage Company 5901 E. Fowler Ave. Tampa FL 33617 COURT OF COMMON PLEAS CUMBERLAND COUNTY No: 2001-6416 Plaintiff vs. James E. Pedrick 6214 Whitehall Drive Mechanicsburg, P A 17055 Defendants CERTIFICATION I hereby certifY that I am the attorney of record for the plaintiff in this action against real property, and further certifY that the property is: ( ) FHA Tenant Occupied or Vacant ( ) Commercial ( ) As a result of a Complaint in Assumpsit (X) That the plaintiff has complied in all respects with Section 403 of the Mortgage Assistance Action Including but not limited to: (a) Service of the notice on defendants (b) Expiration of 30 days since service of the Notice (c) Defendants failure to request or appear at the meeting with the mortgagee or Consumer Counseling Agency (d) Defendants failure to file application with the Homeowners Emergency Assistance Program. I further agree to indemnifY and hold harmless the Sheriff for any false statements given herein. . Von Rosenstiel Attorney for Plaintiff Dated: October 24, 200l :1 ~1;~!tit~~Icli:j!~!Im.!!W~~!t1-;l!1,i~~~:o:]!ll~!~i'11ii~M~d!J:ll~:!!i'ik)!ii~il~~mK'l,I~,'~~~~'''';hiH&",:",j;"-~,-,;';~j,j.i",,j;;}:;>;i~'iOOill\;iJ;~Jjjiii:~''~ -'~MlIiJOll!Yfrr lisJIl,jj 'i Ifl^~'" < ~1L;~ ~~.- 0 C> 0 c: N -n s: to- ._.~ -OCO ;p. ~:o rnrn % ' ",-- Z:I:1 N -::tm zS; -,')0 ~L~ N C~Jo k'Ci ",. .;i!~ >c :x 0' z J iM --0 ill >c: U Z w ~ ~ CJ1 -< g; t;;} ,.~",~"~."W . . .. p'~,,,, ~"",,,,o,,,,~""'.' ",''',"''''~\l1-_ ~ __""~'_ ",'<>=.""'~ ."b' ",~ -''''.' "1",,,,,>-,, "''''''. ,,~~~<~"", ,"v'","'''"'<,. -,,,,i,,Y. ''''.\,-'"'_" ;,""r,'"''' _",'. , "~0." ~.. .." ,.'.'~ "," :~ --..._",.- '~"-'.""""",",,,,,"~~,, ""'___'1"~~ ,~ ~ PRAECIPE FOR WRIT OF EXECUTION -.-oJ COMMONWEALTH OF PENNSYLVANIA !MC Mortgage Company aJk/a Industry Mortgage Company, L.R. d/b/a Core West Bank d/b/a Core West Mortgage Company d/b/a NLG Mortgage Company v. James E. Pedrick COUNTY OF CUMBERLAND NO. 2001-6416 Praecipe for Writ of Execution TO THE PROTHONOTARY: Issue Writ of Execution in the above matter: . AMOUNT DUE INTEREST from 01/17/02 to SALE DATE At $41.27 per diem (Costs to be added) Martha E. Von Rosenstiel Attorney for Plaintiff $172,052.35 $ $ ." ,',", -~"ili"~: ~:;;:~,~~Mill(t;E~~'it'0c;o'H(;~;:&~!;:;'_:r;;ii;(h"',j;'i!';N-;.,""",,".i'~~:""l:",j",_n:~:\1i;'~f'I1l'}&'@f;MH~Oik:@aj#Ml;:w~~ft~~~~' r w~~-_lli~~ ,nill.Mllili "'Hh/!rtdrl'''' -. ):JG () ~ UJ lQ. () Cl 0 r- !U :-0 N --n rt~ ~~ . ~ ~ C- .-I s:: '- B ~ Q . ~ :T~-n ~ -om -lIP d G ~ () ~fn .om 0 ~ N -. -. 0' me;;; :nx () N ,~ 10 ~ ~S;:, I I =<,:.. _'",~ r, ~ ! kG' "'" ).---r1 I I rp:! ~o :;!:: ~o ........ ~~ 5'>0 \D orn --.) ....., ---l 0 ~ w ~ .. '. .. =< U1 .. " ~~ .. .. ., ~ ~ .... G:l ('1\ .:J:::::V1 ,'$'$;', ..>, ~.~~~c"~~~_ _ =W"""'. "__,."",."""~~~""".,,w,,~,~,;," "'.= _,,~~~ .= "~""''''7''''',' __' ',-' ">' . ~~ ,~~ . ~,~'" ,--, '" .~" ;l" >< ~~-~w,jr' , .~ "~ .. ~" ~ ,.,1 ,^' ""'"'Wi,\'b,:, . Martha E. Von Rosenstiel, P .C. Martha E. Von Rosenstiel 16 South Lansdowne Avenue P.O. Box 457 Lansdowne, PA 19050 610 623-2660 Attorney LD.# 52634 Attorney for Plaintiff IMC Mortgage Company a/k!a Industry Mortgage Company, L.R. d/b/a Core West Bank d/b/a Core West Mortgage Company d/b/a NLG Mortgage Company 5901 E. Fowler Ave. TampaFL33617 COURT OF COMMON PLEAS CUMBERLAND COUNTY No: 2001-6416 Plaintiff vs. James E. Pedrick 6214 Whitehall Drive Mechanicsburg, P A 17055 Defendants AFFIDAVIT OF NOTICE PURSUANT TO RULE 3129.1 COMMONWEALTH OF PENNSYLVANIA: SS COUNTY OF DELAWARE MARTHA E. YON ROSENSTIEL, attorney for the plaintiff in the above action, sets forth as of the date the praecipe for the Writ of Execution was filed the following information concerning the real property located at 6214 Whitehall Drive, Mechanicsburg, PA 17055. 1. Name and address of owners(s) orreputed owner(s) James E. Pedrick 6214 Whitehill Drive Mechanicsburg, P A 17055 2. Name and address of defendant(s) in the judgment; James E. Pedrick 6214 Whitehill Drive Mechanicsburg, P A 17055 3. Name and address of every judgment creditor whose judgment is a record lien on the real property to be sold: NONE 4. Name and address of the last recorded holder of every mortgage of record: r:~ it ".._, -"-' ~ ~'"'l~~~~ ~= ... I '~ " ~'!L '" ,j,~,...:.. . ,,i.~"-"~C" c l~--~!@lM:~!00illl;; " NONE 5. Name and address of every other person who has any record lien on the property: NONE 6. Name and address of every other person who has any record interest in the property and whose interest may be affected by the sale: NONE 7. Name and address of every other person of whom plaintiff has knowledge who has any interest in the property which may be affected by the sale: Family CourtlDomestic Relations Office One Courthouse Square Carlisle, P A 17013 Dept. of Public Welfare 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 of 18 Pa. C.S. Section 4904 relating to unsworn falsification to authorities. / . on Rosenstiel ~ Attorney for Plaintiff Jl -..... "....".~-..,., - ~" " , "", 'J,; , ;",J...-'",-^, "-'_~"'~ 1",-', __,,~ .. , MARTHA E. VON ROSENSTIEL, P.C. ATTORNEY AT LAW 16 SOUTH LANSDOWNE AVENUE P.O. BOX 457 LANSDOWNE, PA 19050 PHONE(61 0)623-2660 FAX(61 0)623-2745 January 15, 2002 TO:. Family CourtlDomestic Relations Office One Courthouse Square Carlisle, PA 17013 RE: NOTICE OF SALE OF REAL PROPERTY: 6214 Whitehall Drive Mecll1anicsburg, PA 17055 Amount of Judgment: $172,052.35 Date of Judgment: January 16, 2002 Court Term and Number: Court of Common Pleas of Cumberland County, Docket# 2001-6416 Plaintiff: IMC Mortgage Company alkJa Industry Mortgage Company, L.R. d/b/a Core West Bank d/b/a Core West Mortgage Company d/b/a NLG Mortgage Company Defendants: James E. Pedrick Dear SirIMadam: Please be advised that the property and residential dwelling, located at and known as 6214 Whitehall Drive Mechanicsburg, P A 17055 will be sold by the Sheriff of Cumberland County on June 5, 2002 at 10:00 a.m. in the Cumberland County Court House, One Court House Square, Carlisle, P A 17013. This notice is being sent to you because my records indicate that you hold a lien on the property secondary to the first mortgage, which is being foreclosed. This property and improvements are being sold pursuant to a judgment entered as indicated above in favor of the above named plaintiff, and against the above named defendants. The name of the owners, real owners, and reputed owners of the aforementioned property are James E. Pedrick. A schedule of distribution will be filed by the Sheriff on a date specified by the Sheriff no later than 30 days after said sale, and distribution will be made in accordance with the schedule unless exceptions are filed thereto within ten (10) days after the date of the filing of said schedule. You should check with the Sheriffs Office by calling 717 240-6391 to determine the actual date of the filing of the schedule. Sincerely yours, ( a E. Von Rosenstiel _'1 ~ -"~~'""'..l -..I......,... ---- " " 1 . '.' ;- _.i ''-~~--~'~-,u.i,i,!l:od';: , . . MARTHA E. YON ROSENSTIEL, P.c. ATTORNEY AT LAW 16 SOUTH LANSDOWNE AVENUE P.O. BOX 457 LANSDOWNE, PA 19050 PHONE(610)623-2660 FAX(610)623-2745 January IS, 2002 T~ Dept. of Public Welfare Box 2675 Harrisburg, P A 17105 RE: NOTICE OF SALE OF REAL PROPERTY: 6214 Whitehall Drive Mechanicsburg, P A 17055 Amount of Judgment: $172,052.35 Date of Judgment: January 16, 2002 Court Term and Number: Court of Common Pleas of Cumberland County, Docket# 2001-6416 Plaintiff: IMC Mortgage Company a/k/a Industry Mortgage Company, L.R. d/b/a Core West Bank d/b/a Core West Mortgage Company d/b/a NLG Mortgage Company Defendants: James E. Pedrick Dear Sir/Madam: Please be advised that the property and residential dwelling, located at and known as 6214 Whitehall Drive Mechanicsburg, P A 17055 will be sold by the Sheriff of Cumberland County on June 5, 2002 at lO:OO a.m. in the Cumberland County Court House, One Court House Square, Carlisle, P A 17013. This notice is being sent to you because my records indicate that you hold a lien on the property secondary to the first mortgage, which is being foreclosed. This property and improvements are being sold pursuant to a judgment entered as indicated above in favor of the above named plaintiff, and against the above named defendants. The name of the owners, real owners, and reputed owners of the aforementioned property are James E. Pedrick. A schedule of distribution will be filed by the Sheriff on a date specified by the Sheriff no later than 30 days after said sale, and distribution will be made in accordance with the schedule unless exceptions are filed thereto within ten (10) days after the date of the filing of said schedule. You should check with the Sheriffs Office by calling 717 240-6391 to determine the actual date of the filing of the schedule. Sincerely yours, / -\;9 I '>-<i.,i" :h\';'~^!&MI~.,aJjj;,,,~tlr~~_,"~"""""""w"lm~NI-' ."",~,,,; ,.. '~l' "'~~,<r.i' ""'-"~r I!!ill -'It_li.~ - e c:> 0 N -.-. g. ~ :::} -OeD ,",. ~'?;p2 ~g) -~ - N -::J'LI :z~ ~oO 0:12, N '=-~ (L" ,"<" !.2 c~j ~ ;";::..J-(; 0o;,:!} ~O .... ':;::O:-() "c:-n'1 :;;;0 '!? 0 c: s;! ~ w ~ U1 ~ <P '-.i' ~ L ~"' ,"''''''_~''''''''''_~ .'"' '" ^__",'~', <_."',", -- ~_ "J" '~,<;__,,' .~)"',~ ",~~ _. ,.- ''C'''''''< ,-_ ~," f"-,'_' _', --"~.. ~~~~~~,~",-". ,";~,~ ,"',<> -,- _._.~'" '.. ._~~ '" " . . ; ! ,"';':;'-C:l,;' <,j.," ",~.-" .'....' 'iT~;ii~J: .... Martha E. Von Rosenstie1, P.C. Martha E. Von Rosenstiel 16 South Lansdowne Avenue P.O. Box 457 Lansdowne, PA 19050 610623-2660 Attorney LD.# 52634 Attorney for Plaintiff IMC Mortgage Company a!k!a Industry Mortgage Company, L.R. d/b/a Core West Bank d/b/a Core West Mortgage Company d/b/a NLG Mortgage Company 5901 E. Fowler Ave. Tampa, FL 33617 COURT OF COMMON PLEAS CUMBERLAND COUNTY No: 2001-6416 Plaintiff vs. James E. Pedrick 6214 Whitehall Drive Mechanicsburg, P A 17055 Defendant THIS IS AN ATTEMPT TO COLLECT A DEBT ANY INFORMATION OBTAINED WILL BE USED FOR THAT PURPOSE NOTICE OF SHERIFF'S SALE OF REAL PROPERTY TO: James E. Pedrick 6214 Whitehill Drive Mechanicsburg, P A 17055 Your house and/or real estate at 6214 Whitehall Drive, Mechanicsburg, PA 17055 is scheduled to be sold at Sheriffs Sale on June 5, 2002 at 10:00 a.m. to enforce the court judgment of $172,052.35 obtained by IMC Mortgage Company a!k!a Industry Mortgage Company, L.R. d/b/a Core West Bank d/b/a Core West Mortgage Company d/b/a NLG Mortgage Company against you. NOTICE OF OWNERS RIGHTS YOU MAY BE ABLE TO PREVENT THIS SHERIFF'S SALE To prevent this Sheriffs Sale you must take lMMEDIATE action: 1. The sale will be cancelled if you pay to IMC Mortgage Company alk!a Industry Mortgage Company, L.R. d/b/a Core West Barile d/b/a Core West Mortgage Company d/b/a NLG Mortgage Company the back payments, late charges, costs and reasonable attorney's fees due. To find out how much you must pay, you may call 610 623-2660. 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 "j .. - '--_......-"" ~~ 'j 0" ~.' 0". ~ ~ "~. .,'f'., .<''''ilk",: .- for good cause. 3. You may also be able to stop the sale through other legal proceedings. You may contact an attorney to assert your rights. The sooner you contact one, the more chance you will have of stopping the sale. (See notice on page two on how to obtain an attorney) YOU MAY STILL BE ABLE TO SAVE YOUR PROPERTY AND YOU HAVE OTHER RIGHTS EVEN IF THE SHERIFF'S SALE DOES TAKE PLACE. 1. If the Sheriff s Sale is not stopped, your property will be sold to the highest bidder. You may find out the bid price by calling 610 623-2660. 2. You may be able to petition the Court to set aside the sale if the bid price was grossly inadequate compared to the value of the property. 3. The sale will go through only if the buyer pays the Sheriff the full amount due in the sale. To find out ifthis has happened you may call 610 623-2660. 4. If the amount due from the buyer is not paid to the Sheriff, you will remain the owner of the property as ifthe sale never happened. 5. You have a right to remain in the property until the full amount due is paid to the Sheriff and the Sheriff gives a deed to the buyer. At that time, the buyer may bring legal proceedings to evict you. 6. You may be entitled to a share ofthe money, which was paid for your house. A schedule of distribution of the money bid for your house will be filed by the Sheriff on a date to be aunounced by the Sheriff. This schedule will state who will be receiving that money. The money will be paid out in accordance with this schedule unless exceptions (reasons why the proposed distribution is wrong) are filed with the Sheriff within ten (10) days after the Schedule of Distribution is posted. 7. You may also have other rights and defenses, or ways of getting your house back, if you act immediately after the sale. YOU SHOULD TAKE TmS PAPER TO YOUR LAWYER AT ONCE. IF YOU DO NOT HAVE A LAWYER OR CANNOT AFFORD ONE, GO TO OR TELEPHONE THE OFFICE LISTED BELOW TO FIND OUT WHERE YOU CAN GET LEGAL HELP. COURT ADMINISTRATOR 4TH FLOOR CUMBERLAND COUNTY COURT HOUSE CARLISLE, P A 17013 Telephone: 717 240-6200 .- "'~ . ~ .Co'",.' .' '"'~~, ,., "-,~,, '~~ ~ CLAIM FOR EXEMPTION To the Sheriff: I, the above named defendant, claim exemption of property from levy or attachment: (I) From my real property in my possession which has been levied upon, (a) I desire that my $300.00 statutory exemption be set-aside in kind (specify real property to be set-aside in kind): I request a prompt court hearing to determine the exemption. Notice of the hearing should be given to me at (Address) (Telephone Number) I verify that the statements made in this Claim for Exemption are true and correct. I understand that false statements herein are made subject to the penalties of 18 Pa. C.S. Section 4904 relating to unsworn falsification to authorities. Date: Signature THIS CLAIM TO BE FILED WITH THE OFFICE OF THE SHERIFF CUMBERLAND COUNTY COURTHOUSE CARLISLE, PA 17013 717 240-6391 "" 1liIIIiIilt~ .,- ..... ~~~~~ .........,;0.". " .'" " I , "~' , , ..--" "j'-"':i~fJ:m-w,Jl; WRIT OF EXECUTION _ (MORTGAGE FORECLOSURE) P .R.C.P. 3180 to 3183 and Rule 3257 !MC Mortgage Company, a/k/a Industry Mortgage Company, L.R., d/b/a Core West Bank, etc. IN THE COURT OF COMMON PLEAS OF CUMBERLAND COUNTY, PENNSYLVANIA YS. No. 2001-6416 Term,20.. .E.D. No. Term, 20-.. A.D. James E. Pedrick WRIT OF EXECUTION (MORTGAGE FORECLOSURE) Commonwealth of Pennsylvania: County of TO THE SHERIFF OF CUMBERLAND COUNTY, PENNSYLVANIA: To satisfy the judgment, interest and costs in the above matter you are directed to levy upon and sell the following described property (specifically describe property below): PREMISES: 6214 Whitehall Drive Mechanicsburg, PA 17055 Amount Due Interest from 01/16/02 to Sale Date@ $41.27per diem Attorney's fees $ 172,052.35 Total $ $ $ $ Costs as endorsed. Date~ Prothonotary, Common Pleas Court of Cumberland County, Penna. (SEAL) By: Deputy '"'1 ii'JMiill!~:ifiiilt@i~,0h~0'[f\nj;~,b; ,i;.::,~:Ali'",,'j ,j~'<:h.wH%f,',8;.~&a'jjij.P[t.{c",~,:i,,;-,,",,;;"{) i,i"~A' . "'--"'~""'" ,~,,'!L-;.0:~E...,~1f~~tl!ti!i!l~i~tfjlilliji!:M~~""'''~'f " Jl!.liltU~~lil\I,~~.",..,'^"'''''-'DM~J~';;;;,~A I I <:::> <:::> '" '" "" '""' '<f' "" , '""' o o N o 0 Z Z Q r:i ~ ...: ~<<: 0- Z "'<<: -<> ~H ...1:>< p-<en ZZ OZ ~~ ~:-: Ob UZ ~::> 00 u b ~Q ::>Z 0<<: Co) ...1 ~ ~~ ::r::P'I b::2i Z::> ~.U " :;r ~ o ::Es S". ~~ .g '" 00:1 - ~ '" ~ ~~ . " >>~ o 0 ",U E~ (loa ~~ "'...:l ~. o >> ::E g 0. uS ::E 0 _u " ;. ."'i u ~ ~ 0.. ~ ifl ~ S C':l >-, ,~~, ~....." ,,",""'",.W"''''H~_=' ,\"""''''''~_~,~ z,-.. o ~ _ ::l b '" ::>..9 u ~ ~ 0 :><~ ~ OJ ~ bJl O~ <-<1:: - 0 ~6 '" - '" o U -0 p-< o .... p-< OJ OJ ~ oil -0 ::l >-, .... u _ _ ~,,,,,,,,,__.~,,,J",>'''''''''''r',''',,',',',, '~,' ,,,~,,.,,,-. ,'.~"_" ''-'_''''" ~~ 0- '" ~ - '" '" 0) OJ .~ ~ 0 ~~g ~OJ--' ::l~o 8~P-<"" > 0 . "" ~l!)~ . ::l 1= M ~ '" ~ N "'....l 0 "" ..<:: -0 ,-.. '\ii","'O "'''''~::o ,4...........4'-" ~ ~ ,~ ~ " .~ '" - '" H o ~ >-. " " H o ~ ~ "" ...." ~ > .- Q V) V) o t'-", _ <U > -<t:: :;; 0.. ~ , on~ .... ;:l >> ~ ~ U ~ .- H 8 g. ""'" '" U 0. ~ <U ::;E :;; .c '" - - ~ ~ .... :.E ~ "1' - N '" ~ ~ <U H '" '" '" ...~u. - .,- ~ ___-~~-L- :..l .. _ '._ .'=" " wt,~ i,"';_., "~"liIWlli' .- :. DESCRIPTION ALL THAT CERTAIN lot of land with improvements thereon erected situate in Hampden Township, Cumberland County, Pennsylvania, mote particularly described as follows: BEGINNING at a point on the Southwestern line of Whitehill Drive, which point is the line dividing Lots Nos. 68 and 69 on the hereinafter mentioned Plan of Lots; thence along the said line South 35 degrees 41 minutes West 120 feet to a point On other lands now or formerly of Pennsboro Homes, Inc.; thence along the said lands North 54 degrees 19 minutes West 85 feet to a point on the line dividing Lots Nos. 69 and 70; thence along the said line North 35 degrees 4l minutes East 120 feet to a point on the Southwestern line of Whitehill Drive; thence along Whitehill Drive South 54 degrees 19 minutes East 85 feet to a point the place of BEGINNING. BEING Lot No. 69, Plan 2, Village of Westcover as set forth in Plan Book 22, Page 41. BEING No. 6214 Whitehill Drive. . TAX PARCEL NUMBER: 19-1604-004 ~~ ;~41-iw~d:~!4, L ';"!i$,k;;.,,:y',,,~,,,i;?~,",l;t>E-Wi1h;-;J;lrt&oii,~',c4,,,j;P~i!-\!hl'{;~;;Jitj.O<i-,i'"'H__~"""'.,0<i,,;;ki:';!1i~~~~~~i!i\ii,fi:U 7~nl!iii~_""j <Q-.. e-J> ?Y ~~,< " ,",'" ,,,,"W<~."p,,~, ,'~" ",C ,^ ,_ ._~, 1.""""",>..," '" .. J "17'" ~,' , """~~"'~'" '"",; "':~'.. ""'0, "P ... h~'''''r~IWl_ () c:> n c: N ~n s:: '- ...; -oOJ p .,~ mrr; z c:~~ Z:D N t;11)";: N -,<2 ~&~ ~'C) ;po ~O -,~ ~ :;;g '!? CSrn Si ~ ~ U1 ~ .. ...' -~,~~ I I MRRTHR VON ROSENSTIEL LRW OFFICE ~ 17172406397 ~ . --~ '-,~_'li"'-<k,' 01/22/2002 15:52 NO. 802 Gl01 I . < MARTHA E. VON ROSENSTIEL, P.C. ATTORNEY.AT-LAW 16 SOlJ11i L^NSDOWNE AVENUE - POST OFFICE BOX 457 LAJ'SDOW1':E, P A 19050 Telephone: 610-623-2660 Facsimile: 610-623-2745 January 22, 2002 Sheriff of Cumberland County Real Estate Sales Cou rt House Carlisle, PA 17013 FAX: (717) 240-6397 RE: SALE DATE: MORTGAGOR: PREMISES: CRT./TRM, #: OUR FILE #: 06/05102 James E. Pedrick 6214 Whitehall Drive 2001-6416 9231 Dear Jody: The paperwork to schedule this sale was just sent to the prothonotary on 01/15102. I am not even sure you have received your papers to schedule it for 06J05/02 50 if you did, please 5T A Y the Sheriff Sale scheduled on the above captioned matter per the mortgage company, Kindly send refund (if applicable) as soon as possible, along with a breakdown showing amounts expended. Thank you for your assistance in this matter, Sincerely yours, 5 LA.e/ f vlM;t Sue Fruit JRN 22 2002 16:18 6106232745 PAGE.Ol ~ ----"". ~--~~ ......, ._, ~~ ,~,->;J..""'-m.i" ~~' I "'~~;Je.~.b~ WRIT OF EXECUTION and/or ATTACHMENT COMMONWEALTH OF PENNSYL VANIA) COUNTY OF CUMBERLAND) NO 01-6416 Civil CIVIL ACTION - LAW TO THE SHERIFF OF Cumberland COUNTY: To satisfy the debt, interest and costs due!MC MORTGAGE COMPANY NK/A INDUSTRY MORTGAGE COMPANY, L.R. D/B/A CORE WEST BANK D/B/A CORE WEST MORTGAGE COMPANY D/B/A NLG MORTGAGE COMPANY PLANTIFF(S) From JAMES E PEDRlCK, 6214 WHITEIDLL DRIVE, MECHANICSBURG, P A 17055 (I) 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 notify the garnishee(s) that (a) an attachment has been issued; (b) the garnishee(s) is enjoined from paying any debt to or for the account of the defendant (s) and from delivering any property of the defendant (s) or otherwise disposing thereof; (3) Ifproperty of the defendant(s) not levied upon an subject to attachment is found in the possession of anyone other than a named garnishee, you are directed to notify himlher that he/she has been added as a garnishee and is enj oined as above stated. Amount Due $172,052.35 L.L. $.50 Interest FROM 1/17/02 TO SALE DATE AT $41.27 PER DIEM Atty's Comm % Ally Paid $106.50 Plaintiff Paid Date: JANUARY 22,2002 Due Prothy $1.00 Other Costs CURTIS R. LONG Prothonotary, Civil Division __By: d~. 2 ~~/W. tLf? REQUESTING PARTY: Name MARTHA E. VON ROSENSTIEL, ESQUIRE Address: 16 SOUTH LANSDOWNE AVENUE P.O.BOX 457 LANSDOWNE, PA 19050 Attorney for: PLAINTIFF Telephone: 610-623-2660 Supreme Court ill No. 52634 " ~" .'. ", _ "", "~~,,. ,. ~o~ ","-," ~~-'-, ~~" '" .'~' "'-Q' 'J,~",""" I"'~' " .',0, 7' '" "~H - ,,-, . "'"' ","*~ OFFICE OF THE SHERIFf ClJHPY;',! "",": c';UrnY J~M Z4 \ I 06 All 'GZ , . Ij f'~ ,~. ',.' .- ,. PE N N S\;LV i'dilA _~ ..~[tlOO ; ~,~~~@l!l1"",,,,,,,~=,,,'~~~~"iW;".''?"i!,,,:;:,~j,,'q:i''''''''''''~~''j','-":."-' ',';"i,-"<--- <"." ''''t''"-'ff.,j;~';-'/'i<;';1:';;:;@,i"~;q'''in''o:'' "'1';':5'P;'!1I"'i"<*iNi'~r",%,;;;,~~~';j ----_.'~~ aIiIlIIIIII ~ Lil-lt'il~'d._ -~~"" ~ ., ~~.i . ~'" ,~< ~ c -"_0!~"'1"'b~,,,-*.t,;,~ WRIT OF EXECUTION andlor ATTACHMENT COMMONWEALTH OF PENNSYLVANIA) COUNTY OF CUMBERLAND) NO 01-6416 Civil CIVIL ACTION - LAW TO THE SHERlFF OF Cumberland COUNTY: To satisfy the debt, interest and costs due IMC MORTGAGE COMPANY NK/A INDUSTRY MORTGAGE COMPANY, L.R. D/B/A CORE WEST BANK D/B/A CORE WEST MORTGAGE COMPANY D/B/A NLG MORTGAGE COMPANY PLANTIFF(S) From JAMES E PEDRlCK. 6214 WHITEHILL DRlVE, MECHANICSBURG, P A 17055 (1) You are directed to levy upon the property of the defendant(s) and to sell SEE LEGAL DESCRlPTION (2) You are also directed to attach the property ofthe defendant(s) not levied upon in the possession of GARNISHEE(S) as follows: and to notify the gamishee( s) that: (a) an attaclunent has been issued; (b) the garnishee( s) is enj oined 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) Ifproperty of the defendant(s) not levied upon an subject to attaclunent is found in the possession of anyone other than a named garnishee, you are directed to notify hiroIher that he/she has been added as a garnishee and is enjoined as above stated. Amount Due $172,052.35 L.L. $.50 Interest FROM 1/17/02 TO SALE DATE AT $41.27 PER DIEM Atty's Corum % Due Prothy $1.00 Other Costs Arty Paid $106.50 Plaintiff Paid Date: JANUARY 22, 2002 CURTIS R. LONG Prothonotary, Civil Division ____By: Z::L_ 27f~h~J,~ REQUESTING PARTY: Name MARTHA E. VON ROSENSTIEL, ESQUIRE Address: 16 SOUTH LANSDOWNE AVENUE P.O.BOX 457 LANSDOWNE, PA 19050 Attorney for: PLAINTIFF Telephone: 610-623-2660 Supreme Court ID No. 52634 TRUE COPY FROMR~ 'n T8StiIIlODYwt.... 'benl uJllti- my- and.. ....~~~ -~~oP . _ ~?:$i '-- --.~~ '~~"""~~'~<~'__',"C"',," '<h'.",","^,..'" '~""~-'^~',""" '<'-""'1'"'" ,':;',,~,"'.~"' ""~,,-<-"'~~ ' "fIERIH OfF\tt ,OJ: 1;~,~ ~,:;~\~,.'( C\jf"~ 2,:"' , j~\t N \ \ 06 H\:) iL. ., '" " ",:. " ,a., \ A rOIH:',iUi\" p, ~~- ~ 'lW~~'!i'~""l!l':"iill$i~~'.!~Jli~fIlfJWC,!ffl!'l!~"~'mi."W"'dF'''''!?''V: tiT,,,__ !'." . -, ., '" ~'~ ".r -~-_...............,-~"=' .,'~'* 'j;;jill_~ I I , ..~,,~ , , .' ~~ .'':' L" 'h ~" -t{~i\Yi_6,,, WRIT OF EXECUTION andlor ATTACHMENT COMMONWEALTH OF PENNSYLVANIA) COUNTY OF CUMBERLAND) NO 01-6416 Civil CNIL ACTION - LAW TO THE SHERIFF OF C\nnberland COUNTY: To satisfy the debt, interest and costs due IMC MORTGAGE COMPANY AlK/A INDUSTRY MORTGAGE COMPANY, L.R. D/B/A CORE WEST BANK D/B/A CORE WEST MORTGAGE COMPANY D/B/A NLG MORTGAGE COMPANY PLANTIFF(S) From JAMES E PEDRICK, 6214 WHITEHILL DRIVE, MECHANICSBURG, P A 17055 (I) 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 notify the garnishee(s) that: (a) an attachment has been issued; (b) the garnishee(s) is enjoined from paying any debt to or for the accountofthe defendant(s) and from delivering any property of the defendant (s) or otherwise disposing thereof; (3) Ifproperty of the defendant(s) not levied upon an subject to attachment is found in the possession of anyone other than a named garnishee, you are directed to notify hirnlher that he/she has been added as a garnishee and is enjoined as above stated. Amount Due $172,052.35 L.L. $.50 Interest FROM 1/17/02 TO SALE DATE AT $41.27 PER DIEM Atty's Comm % Due Prothy $1.00 Other Costs Atty Paid $106.50 Plaintiff Paid Date: JANUARY 22, 2002 CURTIS R. LONG Prothonotary, Civil Division ~y: tL, 2 ~,*M' r,-~ REQUESTING PARTY: Name MARTHA E. VON ROSENSTIEL, ESQUIRE Address: 16 SOUTH LANSDOWNE AVENUE P.O.BOX 457 LANSDOWNE, PA 19050 Attorney for: PLAINTIFF Telephone: 610-623-2660 Supreme Court ID No. 52634 TRUE COPY FROM RECORD. lfl Testlmonywllereof. I berlluntoset myila1\d &I\d. tie. seal. ~~~.' Pa. ) '---- lllltA7]~ . ::;~~ '"~~~" - ",>., . ~ ~ ~"n~ "I'" ''>'',_r.''> lk_,'l:'l;" <, ",~ '~,- ,~- ~' - . ^'< "--""'''''' IWI!;.: ;",...11 ",,'rr-\'li,c \J'\~' - Q.\rf" IT - I'f~~~~ 3;\ftI~t1'\l' ,>y-,~'t~,~ .\61\ N \ \ QI:, II;:' .~t , '. -.- \ "r' . . ....1" 'I \ h E""c I'; , p.1 I P 1'1 r, ,) ,. a'IIM ~.- m~.~~"!f~,WJ;ljffi~~ji~~-:'~iif1l'~)~;R'7',~P'''''':'<'' ""<",!"~c";,,,''';,"'''',';F. :;'-"';"''''1',%,:;:'-'';11>:''-' ''''F-'i:;'''''';'.o'i;!!c~'''>;''fF)~~JJi~i,:''''.fr;;~~,,*,~~,:1 _...._ _~._~m"~r...""'" --~'.1"""" , ,~' ~, Ll '."(> "'<'~~~j: WRIT OF EXECUTION and/or ATTACHMENT COMMONWEALTH OF PENNSYLVANIA) COUNTY OF CUMBERLAND) NO 01-6416 Civil CIVIL ACTION - LAW TO THE SHERIFF OF Cumberland COUNTY: To satisfy the debt, interest and costs due IMC MORTGAGE COMPANY NKJA INDUSTRY MORTGAGE COMPANY, L.R. D/B/A CORE WEST BANK D/B/A CORE WEST MORTGAGE COMPANY D/B/A NLG MORTGAGE COMPANY PLANTIFF(S) From JAMES E PEDRICK, 6214 WHITEHILL DRIVE, MECHANICSBURG, P A 17055 (I ) 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 notify the garnishee(s) that: (a) an attachment has been issued; (b) the garnishee(s) is enjoined from paying any debt to or for the account of the defendant (s) and from delivering any property of the defendant (s) or otherwise disposing thereof; (3) If property of the defendant(s) not levied upon an subject to attachment is found in the possession of anyone other than a named garnishee, you are directed to notify himlher that he/she has been added as a garnishee and is enjoined as above stated. AmountDue $172,052.35 L.L. $.50 Interest FROM 1117/02 TO SALE DATE AT $41.27 PER DIEM Atty's Comm % Atty Paid $106.50 Plaintiff Paid Date: JANUARY 22, 2002 Due Prothy $1.00 Other Costs CURTIS R. LONG Prothonotary, Civil Division ~y: ao~, 2. 71;~=. f~ REQUESTING PARTY: Name MARTHA E. VON ROSENSTIEL, ESQUIRE Address: 16 SOUTH LANSDOWNE AVENUE P.O.BOX 457 LANSDOWNE, PA 19050 Attorney for: PLAINTIFF Telephone: 610-623-2660 Supreme Court ID No. 52634 TRUE COPY FROM RECORD In Testimony whereof. I hero unto set my band :. u.~ "" ~._!"" '- ~;~a.~ , . ~.;y~1r~ "",,~o~' ,~, '.'U .' "',.0".",,",', . ... ,-- ~'",<--," "', '"""", "" .. ... F,.'"n OFf\~::: ;t CU~;'2~ Jnll 24 ~ 'o<C,^"--_',_,,' ~'" >' ~, ^ ('I . . ,"'1"";''';'''''' "HERIFf . >J~1Y \'\ocf\'ro Q .,,1 Ul- PEIHi 2)\' LV All \A , ',}i'" ~JJJi~" , ' ,!l9h'~I>i')1~~~1 "~-~ '.,>_,' _"'""'....O_P _... '~^'.,,~,,"'\'W''''-- . n. ,,_.. 'JW',i"-,' -~~~^._~ wr: l!f-' ~~~'r;);~.,!7',,: >.,,-,,,,,, ^""'F)"",,.,~Pi' ,~~,~~~., '0 - H_."' "L""4 C'""""". "'-l-,"il\'~"N~"'''~T*''li''fJr,''F;i'",~"'i ';1:-"''':,. """'_'}"'~''','F$\,:~ii)-;;~':?"...""W-li',(~ -""- .. -~ "--"""-N~ 'j ~",~,-" "'" ;,J,,;.,," '~~i;i WRIT OF EXECUTION and/or ATTACHMENT COMMONWEALTH OF PENNSYL VANIA) COUNTY OF CUMBERLAND) NO 01-6416 Civil CIVIL ACTION - LAW TO THE SHERIFF OF Cumberland COUNTY: To satisfy the debt, interest and costs due IMC MORTGAGE COMPANY NKlA INDUSTRY MORTGAGE COMPANY, L.R. D/B/A CORE WEST BANK D/B/A CORE WEST MORTGAGE COMPANY D/B/A NLG MORTGAGE COMPANY PLANTIFF(S) From JAMES E PEDRICK, 6214 WHITEHILL DRIVE, MECHANICSBURG, PA 17055 (I) 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 notify the garnishee(s) that: (a) an attachment has been issued; (b) the garnishee(s) is enjoined from paying any debt to or for the account of the defendant (s) and from delivering any property of the defendant (s) or otherwise disposing thereof; (3) If property of the defendant(s) not levied upon an subject to attachment is found in the possession of anyone other than a named garnishee, you are directed to notify himlher that he/she has been added as a garnishee and is enjoined as above stated. Amount Due $172,052.35 L.L. $.50 Interest FROM 1/17/02 TO SALE DATE AT $41.27 PER DIEM Atty's Comm % Atty Paid $106.50 Plaintiff Paid Date: JANUARY 22, 2002 Due Prothy $1.00 Other Costs CURTIS R. LONG Prothonotary, Civil Division --....lly: .tZ.=< 2 t?dM. ;,'--4? REQUESTING PARTY: Name MARTHA E. VON ROSENSTIEL, ESQUIRE Address: 16 SOUTH LANSDOWNE AVENUE P.O.BOX 457 LANSDOWNE, PA 19050 Attorney for: PLAINTIFF Telephone: 610-623-2660 Supreme Court 1D No. 52634 . COpY FROM RECORD TRUE where-ot, I her'.111~t!l ~ my band ~=~~~.~ ,,-~g:~o e. ~ ~ ,'''''~ "~ ~~ ." ~ "', '.w~' ."",,",",, "'-"""""t,,,' " "" -- ,,--,' ~' ,~~; ="'<~' ,"',,-; ,.-,--,,,--"' ,__ ~'''-I_' --- ~'c"-,,, ."_"'~"'j " "'-'~','''" ,~;;;""'.>M".___'"" .~"___,~ ~,' ~ -- ~ -" ',.._" .'~"I=~ ..~'~~o < ~ "': OFFICE OF THE SHERIFF CUM3' :,::"., :':WNTY JnN Z4 1106 All '02 "" , \))'-', " ' . ., ' , ' " .. l_ ! '~i ~.. L. PEHHSYLVMilA IllIliIlllim!l;n..~#,i.~t;~"m~.~lr.$= 1!<<U~i~I!~,!!!~l!fl!l1f~i!';';;~~"~':"': '~'"Y''' """f,",' ","'f;;' .",---',':'!C" " ''''/i'''';__I!'''P'''f~T''''r'Y''Y'',"1'''''''''''-:';'.''''Ti!'ipl''-~~'''''!'~fC-Y''.\~~'&lV """""" ......... ~ ,," '~_~~__."..;;.L - , "",,~~,~.'~ J ~"O~ .' "'" IL''',j"'~"",~,&,~;",-., WRIT OF EXECUTION and/or ATTACHMENT COMMONWEALTH OF PENNSYLVANIA) COUNTY OF CUMBERLAND) NO 01-6416 Civil CIVIL ACTION - LAW TO THE SHERIFF OF Cumberland COUNTY: To satisfy the debt, interest and costs due IMC MORTGAGE COMPANY A/KJA INDUSTRY MORTGAGE COMPANY, L.R. D/B/A CORE WEST BANK D/B/A CORE WEST MORTGAGE COMPANY D/B/A NLG MORTGAGE COMPANY PLANTIFF(S) From JAMES E PEDRICK, 6214 WHITEHILL DRIVE. MECHANICSBURG, P A 17055 (I) You are directed to levy upon the property ofthe 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 notify the garnishee(s) that: (a) an attachment has been issued; (b) the garnishee(s) is enjoined from paying any debt to or for the account ofthe defendant (s) and from delivering any property of the defendant (s) or otherwise disposing thereof; (3) Ifproperty of the defendant(s) not levied upon an subject to attachment is found in the possession of anyone other than a named garnishee, you are directed to notify himlher that he/she has been added as a garnishee and is enjoined as above stated. AmountDue $172,052.35 L.L. $.50 Interest FROM 1/17/02 TO SALE DATE AT $41.27 PER DIEM Atty's Comm % Atty Paid $106.50 Plaintiff Paid Date: JANUARY 22,2002 Due Prothy $1.00 Other Costs CURTIS R. LONG Prothonotary, Civil Division ---...J3y: iZOM 2 ~neM' iLF, REQUESTING PARTY: Name MARTHA E. VON ROSENSTlEL, ESQUIRE Address: 16 SOUTH LANSDOWNE AVENUE P .O.BOX 457 LANSDOWNE, PA 19050 Attorney for: PLAINTIFF Telephone: 610-623-2660 Supreme Court ID No. 52634 TRUE COpy FROM RECORD hi T8Stlmonywher~!)f, I hers unto set my hand n ~ ~.jd c.~. ~rlisIe.. '....Pa.. '- ~ yt3f .., ~~;;~ .,--~ - ~. H." ~ ~_" ",' -', -"- "-,' 'eO .bo"" - I'''''' -.. ,.~"-", ,-,,'- ',~ ~. ...~..,~,~ -. ., OfF\C((),~ :~f CUtJ:U~ ,'. SI1E\\\H ,."U"n 311\114 \\ 06 M\ 'Gl ..,.t, ',1-- PE.~ ~S1 \\,1 Ai~ 11\ __ "l3iM^~~~,=",;~~~~~'~!~JIWI:!)!!l{,!!;w>,-jJl;:>tt:lW;;;,,~'llw.i,,;V;,.'"-:j',0,'-,,0Y'~ "T-'T''''-'- "y,";',-,:"i"";'_19"",-~",i1'lf,f,,'1J';jf,;;,;;4--'Wif_;;>~,'i,t~?!Bl!l;'ij[~r~<!'!i!* _lJ,p1~_if ""......~. ~.........~- ~- " ~ - " " .' - ~ ~ -~~ ,~ -"I""'-W41:iin-t$Sl.~t""k .- MARTHA E. VON ROSENSTIEL, P.c. ATTORNEY AT LAW 16 SOUTH LANSDOWNE AVENUE P.O. BOX 457 LANSDOWNE, PA 19050 PHONE (610) 623-2660 FAX (610) 623-2745 October 24, 2001 Office of the Sheriff Real Estate Cumberland County Court House 1 Courthouse Square Carlisle, P A 17013 RE: IMC Mortgage Company a/k/a Industry Mortgage Company, L.R. d/b/a Core West Bank d/b/a Core West Mortgage Company d/b/a NLG Mortgage Companyv. James E. pedrick 6214 Whitehall Drive Mechanicsburg, PA 17055 Docket# 2001-6416 Our File# 9231 Dear Sir or Madam: Enclosed please find the documents necessary to schedule the above property for the 6/5/02 date. I have also enclosed an extra copy of the documents and I would appreciate it if you would these copies and return them to me in the enclosed envelope for my files. Thank you for your assistance in this matter. If you have any questions, please do not hesitate to call. Sincerely yours, SUhFvuM: Sue Fruit - =~""~--... ~"'- ........- : I - ~L:'-->'~-'....,,~,,~ii " MARTHA E. VON ROSENSTIEL, PoCo ATTORNEY AT LAW 16 SOUTH LANSDOWNE AVENUE P.O. BOX 457 LANSDOWNE, PA 19050 PHONE (610) 623-2660 FAX (610) 623-2745 October 24, 2001 Office of the Sheriff Real Estate Cumberland County Court House 1 Courthouse Square Carlisle, P A 17013 RE: IMC Mortgage Company a/k/a Industry Mortgage Company, L.R. d/b/a Core West Bank d/b/a Core West Mortgage Company d/b/a NLG Mortgage Companyv. James E. Pedrick 6214 Whitehall Drive Mechanicsburg, PA 17055 Docket# 2001-6416 Our File# 9231 Dear Sir or Madam: Enclosed herewith please find a Complaint in Mortgage Foreclosure in the above matter, which I would like to have served personally on the following defendant(s): James Eo Pedrick 6214 Whitehill Drive Mechanicsburg, P A 17055 Please serve the defendant(s) personally at all addressees) indicated OR serve any adult in possession of premises and note name and relationship to the defendant(s) on service return. I have enclosed a self-addressed stamped envelope for your convenience in returning the service form. Thank you for your assistance in this matter. Sincerely yours, Sue,< FvlNit: Sue Fruit q)&~1_,:tf~~~~~i'iSlf:~;K~gi;:_Y~I€LW~%~;}!;;:~'Z'}-;j~"-,,;~. ,~ _ ,~ , " " i .'~. ~ '" t"' 0 > C Z ..., '" :I: O"t"' 00> ~' Z Z~cn m>:O - 0 ~ti~ "Z :;; m ~ ~ o m z c m 3': ", ;0 ~ --< ~ (,T)::I: en en'" O:-o~f"1 00>< ~. ZO Zrocn2 tnOo::o _.,XOO >-t:la:Ecn tn 20m -""""mZ <D >en o <-< U't mn; C or =" p o md..... ,.. OloO--..j NOll OC l!- Oll'" ,- III . " tl OUN/IfJ) i ;:' t) ''\ i tl:~1 ~~~ ~~~~ ON\)I ~. ~ ~ ~l'1 0< ~~ ~ild ~~ t"'i'l ~~ .., .... i'l r :tI (l j: ; i~ ". i~ .1, i" it ! ; ~ I~ II ~'idf.;gq.'f~:A!f,~<t;;};$i~{i:'~1t;'t-iBJ,;f'&:g;:;;~~:;$ti~!Si~;~%i.f~;)j;:.~~1,11 _..~'"' ~. :it.:Ji>' ~- 1",,1iIIItli& ~.~""""" ~ ~~ I~~~~" "J - '- ~"~~"",~-",i~' ~(}; Martha E. Von Rosenstiel, P.C. Martha E. Von Rosenstiel 16 South Lansdowne Avenue P.O. Box 457 Lansdowne, PA 19050 610 623-2660 Attorney LD.# 52634 Attorney for Plaintiff IMC Mortgage Company alkZa Industry Mortgage Company, L.R. d/b/a Core West Bank d/b/a Core West Mortgage Company d/b/a NLG Mortgage Company 5901 E. Fowler Ave. Tampa FL 33617 COURT OF COMMON PLEAS CUMBERLAND COUNTY No: 2001-6416 Plaintiff vs. James E. Pedrick 6214 Whitehall Drive Mechanicsburg, P A 17055 Defendants AFFIDAVIT OF NOTICE PURSUANT TO RULE 312901 COMMONWEALTH OF PENNSYLVANIA: SS COUNTY OF DELA WARE MARTHA E. VON ROSENSTIEL, attorney for the plaintiff in the above action, sets forth as of the date the praecipe for the Writ of Execution was filed the following information concerning the real property located at 6214 Whitehall Drive, Mechanicsburg, PA 17055. 1. Name and address of owners(s) orreputed owner(s) James E. Pedrick 6214 Whitehill Drive Mechanicsburg, P A 17055 ,t 2. Name and address of defendant(s) in the judgment: James E. Pedrick 6214 Whitehill Drive Mechanicsburg, P A 17055 3. Name and address of every judgment creditor whose judgment is a record lien on the real property to be sold: NONE 4. Name and address of the last recorded holder of every mortgage of record: '~"="'~ ----,;,y''''''-<- ~" 0.: < "- , , , I _ ___~ , '_ ',~,':"~ ' .~, J,,-,-,~ ___., ~~,~ , NONE 5. Name and address of every other person who has any record lien on the property: NONE 6. Name and address of every other person who has any record interest in the property and whose interest may be affected by the sale: NONE 7. Name and address of every other person of whom plaintiff has knowledge who has any interest in the property which may be affected by the sale: Family Court/Domestic Relations Office One Courthouse Square Carlisle, P A 17013 Dept. of Public Welfare 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 of 18 Pa. C.S. Section 4904 relating to unsworn falsification to authorities. . on Rosenstiel Attorney for Plaintiff , ~j ~"A."""""'DI!llIllI - '~"Ii_ ' I ~j "d I ,~".....,,- IU~.~~~'" MARTHA E. YON ROSENSTIEL, P.C. ATTORNEY AT LAW 16 SOUTH LANSDOWNE AVENUE P.O. BOX 457 LAt'\lSDOWNE, PA 19050 PHONE(61 0)623-2660 FAX(6 I 0)623-2745 January 15, 2002 TO: Family CourtlDomestic Relations Office One Courthouse Square Carlisle, PA 17013 RE: NOTICE OF SALE OF REAL PROPERTY: 6214 Whitehall Drive Mechanicsburg, P A 17055 Amount of Judgment: $172,052.35 Date of Judgment: January 16, 2002 Court Term and Number; Court of Common Pleas of Cumberland County, Docket# 2001-6416 Plaintiff: IMC Mortgage Company aJk/a Industry Mortgage Company, L.R. d/b/a Core West Bank d/b/a Core West Mortgage Company d/b/a NLG Mortgage Company Defendants: James E. Pedrick Dear SirlMadam: Please be advised that the property and residential dwelling, located at and known as 6214 Whitehall Drive Mechanicsburg, P A 17055 will be sold by the Sheriff of Cumberland County on June 5, 2002 at 10:00 a.m. in the Cumberland County Court House, One Court House Square, Carlisle, PA 17013. This notice is being sent to you because my records indicate that you hold a lien on the property secondary to the first mortgage, which is being foreclosed. This property and improvements are being sold pursuant to a judgment entered as indicated above in favor of the above named plaintiff, and against the above named defendants. The name of the owners, real owners, and reputed owners ofthe aforementioned property are James E. Pedrick. A schedule of distribution will be filed by the Sheriff on a date specified by the Sheriff no later than 30 days after said sale, and distribution will be made in accordance with the schedule unless exceptions are filed thereto within ten (10) days after the date of the filing of said schedule. You should check with the Sheriffs Office by calling 717 240-6391 to determine the actual date of the filing of the schedule. Sincerely yours, ( a E. Von Rosenstiel 1% ,ca ,,~"= ~.~-~ "'--~_.. '~ , ,L.. :J'\j~-i';;>~1'~' , , MARTHA E. VON ROSENSTIEL, P.c. ATTORNEY AT LAW 16 SOUTH LANSDOWNE AVENUE P.O. BOX 457 LANSDOWNE, PA 19050 PHONE(6 I 0)623-2660 FAX(610)623-2745 January 15, 2002 TO, Dept. of Public Welfare Box 2675 Harrisburg,PA 17105 RE: NOTICE OF SALE OF REAL PROPERTY: 6214 Whitehall Drive Mechanicsburg, PA 17055 Amount of Judgment: $172,052.35 Date of Judgment: January 16, 2002 Court Term and Number: Court of Common Pleas of Cumberland County, Dockeffl 2001-6416 Plaintiff: IMC Mortgage Company a/kla Industry Mortgage Company, L.R. d/b/a Core West Bank d/b/a Core West Mortgage Company d/b/a NLG Mortgage Company Defendants: James E. Pedrick Dear Sir/Madam: Please be advised that the property and residential dwelling, located at and known as 6214 Whitehall Drive Mechanicsburg, P A 17055 will be sold by the Sheriff of Cumberland County on June 5, 2002 at 10:00 a.m. in the Cumberland County Court House, One Court House Square, Carlisle, PA 17013. This notice is being sent to you because my records indicate that you hold a lien on the property secondary to the first mortgage, which is being foreclosed. This property and improvements are being sold pursuant to a judgment entered as indicated above in favor of the above named plaintiff, and against the above named defendants. The name of the owners, real owners, and reputed owners of the aforementioned property are James E. Pedrick. A schedule of distribution will be filed by the Sheriff on a date specified by the Sheriff no later than 30 days after said sale, and distribution will be made in accordance with the schedule unless exceptions are filed thereto within ten (10) days after the date of the filing of said schedule. You should check with the Sheriffs Office by calling 717 240-6391 to determine the actual date of the filing of the schedule. Sincerely yours, / ( , '-- " ."~ t~~ --==0Iji! - oiiIiiiiiiioi--'-"'" '. " ~'. ~ ' '";-, ',-<_c if1"i!l-fliJihI'jLl , , .',," Martha E. Von Rosenstiel, P.C. Martha E. Von Rosenstiel 16 South Lansdowne Avenue P.O. Box 457 Lansdowne, P A 19050 610 623-2660 Attorney LD.# 52634 Attorney for Plaintiff IMC Mortgage Company aIkIa Industry Mortgage Company, L.R. d/b/a Core West Bank d/b/a Core West Mortgage Company d/b/a NLG Mortgage Company 5901 E. Fowler Ave. Tampa, FL 33617 COURT OF COMMON PLEAS CUMBERLAND COUNTY No: 2001-6416 Plaintiff vs. James E. Pedrick 6214 Whitehall Drive Mechanicsburg, P A 17055 Defendant THIS IS AN ATTEMPT TO COLLECT A DEBT ANY INFORMATION OBTAINED WILL BE USED FOR THAT PURPOSE NOTICE OF SHERIFF'S SALE OF REAL PROPERTY TO: James Eo Pedrick 6214 Whitehill Drive Mechanicsburg, P A 17055 Your house and/or real estate at 6214 Whitehall Drive, Mechanicsburg, PA 17055 is scheduled to be sold at Sheriffs Sale on June 5, 2002 at 10:00 a.m. to enforce the court judgment of $172,052.35 obtained by IMC Mortgage Company aIkIa Industry Mortgage Company, L.R. d/b/a Core West Bank d/b/a Core West Mortgage Company d/b/a NLG Mortgage Company against you. NOTICE OF OWNERS RIGHTS YOU MAY BE ABLE TO PREVENT THIS SHERIFF'S SALE To prevent this Sheriffs Sale you must take IMMEDIATE action: 1. The sale will be cancelled if you pay to IMC Mortgage Company aIkIa Industry Mortgage Company, L.R. d/b/a Core West Bank d/b/a Core West Mortgage Company d/b/a NLG Mortgage Company the back payments, late charges, costs and reasonable attorney's fees due. To find out how much you must pay, you may call 610 623-2660. 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 " -- ~ , ,l " h..,,-. :]iHw%~i,;.JIit'~i r for good cause. 3. You may also be able to stop the sale through other legal proceedings. You may contact an attorney to assert your rights. The sooner you contact one, the more chance you will have of stopping the sale. (See notice on page two on how to obtain an attorney) YOU MAY STIIGL 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 bid price by calling 610 623-2660. 2. You maybe able to petition the Court to set aside the sale if the bid price was grossly inadequate compared to the value of the property. 3. The sale will go through only if the buyer pays the Sheriff the full amount due in the sale. To find out if this has happened you may call 610 623-2660. 4. If the amount due from the buyer is not paid to the Sheriff, you will remain the owner of the property as if the sale never happened. 5 . You have a right to remain in the property until the full amount due is paid to the Sheriff and the Sheriff gives a deed to the buyer. At that time, the buyer may bring legal proceedings to evict you. 6. You maybe entitled to a share of the money, which was paid for your house. A schedule of distribution of the money bid for your house will be filed by the Sheriff on a date to be announced by the Sheriff. This schedule will state who will be receiving that money. The money will be paid out in accordance with this schedule unless exceptions (reasons why the proposed distribution is wrong) are filed with the Sheriff within ten (10) days after the Schedule of Distribution is posted. 7. You may also have other rights and defenses, or ways of getting your house back, if you act immediately after the sale. YOU SHOULD TAKE THIS PAPER TO YOUR LAWYER AT ONCE. IF YOU DO NOT HAVE A LAWYER OR CANNOT AFFORD ONE, GO TO OR TELEPHONE THE OFFICE LISTED BELOW TO FIND OUT WHERE YOU CAN GET LEGAL HELP. COURT ADMINISTRATOR 4TH FLOOR CUMBERLAND COUNTY COURT HOUSE CARLISLE, P A 17013 Telephone: 717240-6200 l1i - ----. ~""~ - ~ "'~. -,~, .L "~, .""...,.. . . , -.". 1;'~'lWIij~J;:j-"#J,,,,:, CLAIM FOR EXEMPTION To the Sheriff: I, the above named defendant, claim exemption of property from levy or attachment: (1) From my real property in my possession which has been levied upon, (a). I desire that my $300.00 statutory exemption be set-aside in kind (specify real property to be set-aside in kind): I request a prompt court hearing to determine the exemption. Notice of the hearing should be given to me at (Address) (Telephone Number) I verify that the statements made in this Claim for Exemption are true and correct. I understand that false statements herein are made subject to the penalties of 18 Pa. C.S. Section 4904 relating to unsworn falsification to authorities. Date: Signature THIS CLAIM TO BE FILED WITH THE OFFICE OF THE SHERIFF CUMBERLAND COUNTY COURTHOUSE CARLISLE, PA 17013 717 240-6391 " ~--~-- ~ , ~'~.~, ,1 "" ,'-. ";""[0.,, ,.'1- ';_""'"~~ WRIT OF EXECUTION - (MORTGAGE FORECLOSURE) P.R.C.P. 3180 to 3183 and Rule 3257 IMC Mortgage Company, a/k/a Industry Mortgage Company, L.R., d/b/a Core West Bank, etc. IN THE COURT OF COMMON PLEAS OF CUMBERLAND COUNTY, PENNSYLVANIA vs, No. 2001-6416 Term, 20... .E.D. No. Term, 20-. ' ,A.D. James E. pedrick WRIT OF EXECUTION (MORTGAGE FORECLOSURE) Commonwealth of Pennsylvania: County of TO THE SHERIFF OF CUMBERLAND COUNTY, PENNSYLVANIA: To satisfy the judgment, interest and costs in the above matter you are directed to levy upon and sell the following described property (specifically describe property below): PREMISES: 6214 Whitehall Drive Mechanicsburg, P A 17055 Amount Due Interest from 01/16/02 to Sale Date @ $41.27per diem Attorney's fees $ 172,052.35 Total $ $ $ $ Costs as endorsed. Dater! Prothonotary, Common Pleas Court of Cumberland County, Penna. (SEAL) By: Deputy ~~ '~-",:_~,-:;..M';k~"",',,*k~~il!HJ( ~~illli" ~L,'-"l!u!t1l:~ - " -~ ~< ~ O~ " ~ V) Z 00 ,~ C/:J< '" w V) 00 = = <> ~ " 0 '" '" .~ t-- ~H 0 '" '0 ....1>- ~" ~ .-. Q) z ~ ~ <l) > ~'" S"" " H :> --< H ZZ 0 .... 0 .- Q) ~-'" " 0- .... "' OZ .g a ~ ~ Po< f-< "' "' c::l :2:g: 0 ~ "- , "I'l ;:J " Q) - ^ Q) -- u " ca Oll", :2:;:;..:- '" ~ " ] " H .... ~si! ~ .... ~ " 0 ...<:: ~ "- Of- :>< 0 - - 5 0 w .D '" uZ ,; "' ~ w <l) " " " > ~.... 0 5 .,.., '" .... rJ:l ~ >.~ U ~ 0 .- () " 0 " ...<:: "' 'D ~'O ~ ~ 00 "' 0'> .- H "'U @ ~ Ou e~ () 0 '" ~ ..... ~ Q) '<T .- 00 " p. 'D t-' .t3 f-< 1:: 1':-<0 ...<:: '" 8:a '<j' p. , ~CI ~ 0 I': :;:~'D () ~ ;:JZ <l) ~::2 0 .-. <l) Q) 0 ~~ Po< >- o ^ 'D N ~ H 0 0< ;S:V ",,,<'1 Q) <'1 UH gJ,""' ~ "' I': ' \0 -" ~ ~ ,:; ~ " g:;:~ "' 0 0 ~>Ll 0 " '" ....:iO'D "' a rJ:l "d .... "' Z z ::c~ ~ <l) ~ ~ "d ~ Q) p. biJ . "' f-<::E u E: ~ C/:J I': 0 H CI CI 0 "d ~ '0 -< z~ ~ 0 ~ " ...: <0;; ::2 'D '" 'D '0 >Ii ~<u _u -, ~ ...... u C/:J .........:1 v '" ~c ~ ~- , ,,,,,,,,",-"--~_,~",_ ~,~" ",-'e~-'~ '_0 -<""_,-,,. -,'"' , , ~ =~ - - ~ j , -"~ &~lMi~:' : DESCRIPTION ALL THAT CERTAIN lot of land with improvements iliereon erected situate in Hampden Township, Cumberland County, Pennsylvania, more panicularly described as follows: BEGINNING at a point on the Sonthwestern line of Whitehill Drive, which point is the line dividing Lots Nos. 68 and 69 on the hereinafter mentioned Plan of Lots; thence along the said line South 35 degrees 41 minutes West 120 feet to a point on other lands now or former I y of Pennsboro Homes, Inc.; thence along the said lands North 54 degrees 19 minutes West 85 feet to a point on the line dividing Lots Nos. 69 and 70; thence along the said line North 35 degrees 41 minutes East 120 feet to a point on the Southwestern line of Whitehill Drive; thence along Whitehill Drive South 54 degrees 19 minutes East 85 feet to a point the place of BEGINNING. BEING Lot No. 69, Plan 2, Village of Westcover as set forth in Plan Book 22, Page 41. BEING No. 6214 Whitehill Drive. . TAX PARCEL NUMBER: 19-1604-004 ~ - ~ -. " j I ~ < .'.~ --" '..-L' " j'L"' "':"'l0L~,k,,:, DESCRIPTION ALL THAT CERTAIN lot of land with improvements thereon erected situate in Hampden Township, Cumberland County, Pennsylvania, mote panicularly described as follows: BEGINNING at a point On the Southwestern line of Whitehill Drive, which point is the line dividing Lots Nos. 68 and 69 on the hereinafter mentioned Plan of Lots; thence along the said line South 35 degrees 41 minutes West 120 feet to a point on other lands now or formerly of Pennsboro Homes, Inc.; thence along the said lands North 54 degrees 19 minutes West 85 feet to a point on the line dividing Lots Nos. 69 and 70; thence along the said line North 35 degrees 41 minutes East 120 feet to a point on the Southwestern line of Whitehill Drive; thence along Whitehill Drive South 54 degrees 19 minutes East 85 feet to a point the place of BEGINNING. BEING Lot No. 69, Plan 2, Village of Westcover as set forth in Plan Book 22, Page 41. BEING No. 6214 Whitehill Drive. , TAX PARCEL NUMBER: 19-1604-004 :2i~: ._~~~ '.- _ _~" ,_ J-' .",~ ,.c .1. ""-;"-h~~i;; DESCRIPTION ALL THAT CERTAIN lot of land with improvements thereon erected situate in Hampden Township. Cumberland County. Pennsylvania. more particularly described as follows: BEGINNING at a point on the Southwestern line of Whitehill Drive, which point is the line dividing Lots Nos. 68 and 69 on the hereinafter mentioned Plan of Lots; thence along the said line South 35 degrees 41 minutes West 120 feet to a point on other lands now or formerly of Peoosboro Homes, Inc.; thence along the said lands North 54 degrees 19 minutes West 85 feet to a point on.the line dividing Lots Nos, 69 and 70; thence along the said line North 35 degrees 41 minutes East 120 feet to a point on the Southwestern line of Whitehill Drive; thence along Whitehill Drive South 54 degrees 19 minutes East 85 feet to a point the place of BEGINNING. BEING Lot No. 69, Plan 2, Village of Westcover as set forth in Plan Book 22, Page 41. BEING No. 6214 Whitehill Drive. . TAX PARCEL NUMBER: 19-1604-004 m