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- GE CAPITAL MORTGAGE SERVICES, INC.
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CUMBERLAND COUNTY
Plaintiff,
v.
COURT OF COMMON PLEAS
SARA JANE CREELMAN
CIVIL DIVISION
Defendant(s).
NO.01-6453 CIVIL
AMENDED AFFIDAVIT PURSUANT TO RULE 3129
(Affidavit No.1)
GE CAPITAL MORTGAGE SERVICES. INC., Plaintiff in the above action, by its attorney,
FRANK FEDERMAN, ESQUIRE, sets forth as of the date the Praecipe for the Writ cifExecution was
filed the following information concerning the real property located at . 12 SHIRLEY LANE,
BOILING SPRINGS. PA 17007.
1. Name and address ofOwner(s) or reputed Owner(s):
Name
Last Known Address (if address cannot be
reasonably ascertained, please indicate)
SARA JANE CREELMAN
12 SHIRLEY LANE
BOILING SPRINGS, P A 17007
2. Name and address ofDefendant(s) in the judgment:
SARA JANE CREELMAN
12 SHIRLEY LANE
BOILING SPRINGS, P A 17007
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.
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r ..4. Name and address oflast recorded holder of every mortgage of record:
PNC BANK NATIONAL ASSOCIATION
CITIFINANCIAL INC.
2730 LIBERTY AVENUE
PITTSBURGH, PA 15222
5520 CARLISLE PIKE, SUITE 155
MECHANICSBURG, PA 17055
5. Name and address of every other person who has any record lien on the property:
None.
Last Known Address (if address cannot be
reasonably ascertained, please indicate)
6. Name and address of every other person who has any record interest in the property and whose
interest may be affected by the sale.
Name
COMMONWEALTH OF PENNSYLVANIA
BUREAU OF INDIVIDUAL TAX
INHERITANCE TAX DIVISION
ATTENTION: JOHN MURPHY
INTERNAL REVENUE SERVICE
FEDERATED INVESTORS
TOWER
DEPARTMENT OF PUBLIC WELFARE TPL
CASUALTY UNIT ESTATE RECOVERY
PROGRAM
Last Known Address (if address cannot be
reasonably ascertained, please indicate)
6TH FLOOR, STRAWBERRY SQUARE
DEPT. 280601
HARRISBURG,PA 17128
13 TH FLOOR, SUITE 1300
1001 LIBERTY AVENUE
PITTSBURGH, PA 15222
P.O. BOX 8486
WILLOW OAK BUILDING
HARRISBURG, P A 17105-8486
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
Tenant/Occupant
Domestic Relations of Cumberland County
Commonwealth of Pennsylvania
Department of Welfare
Last Known Address (if address cannot be
reasonably ascertained, please indicate)
12 SHIRLEY LANE
BOILING SPRINGS, P A 17007
13 North Hanover Street
Carlisle, PA 17013
PO Box 2675
Harrisburg, PA 17105
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. 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.
April 19.2002
DATE
/; AMi C)IJJ~
FRANK FEDERMAN, ESQUIRE
Attorney for Plaintiff
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IN THE COURT OF COMMON PLEAS OF CUMBERLAND COUNTY,
PENNSYLVANIA
RE: GE CAPITAL MORTGAGE SERVICES, INC.
) CIVIL ACTION
)
vs.
SARA JANE CREELMAN )
)
CIVIL DIVISION
NO. 01-6453 CIVIL
AFFIDAVIT OF SERVICE PURSUANT TO RULE 3129
COMMONWEALTH OF PENNSYLVANIA
COUNTY OF CUMBERLAND
)
)
SS:
I, FRANK FEDERMAN, ESQUIRE attorney for GE CAPITAL
MORTGAGE SERVICES, INC. hereby verify that on 1/16/02 & 4/19/02 true and
correct copies of the Notice of Sheriff's sale were served by certificate of mailing
to the recorded lienholders, and any known interested party see Exhibit "A"
attached hereto. Notice of Sale was sent to the Defendant(s) on 4/19/02 by
certified mail return receipt requested see Exhibit "B" attached hereto.
DATE: Mav 2.2002
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F K FEDERMAN, ESQUIRE
Attorney for Plaintiff
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7160 3'ID1 "I8~".&528:1bb8
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TO: SARA JANE GREELMAN
12 SHIRLEY LANE
BOILING SPRINGS, P A 17007
SENDER:
TEAM 5
; REFERENCE: CREELMAN, SARA JANE
PS Form 3800 June 2000
RETURN Postage
RECEIPT Certified Fee
SERVICE
Return Receipt Fee
Restricted Delivery
Total Postage & Fees
US Postal Service
Receipt for
Certified Mail
No Insurance Coverage provided
Do Not Use for International Mail
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, GE CAPITAL MORTGAGE SERVICES, INC.
r
CUMBERLAND COUNTY
Plaintiff,
v.
COURT OF COMMON PLEAS
SARA JANE CREELMAN
CIVIL DMSION
Defendant(s).
NO.01-6453 CIVIL
AFFIDAVIT PURSUANT TO RULE 3129
(Affidavit No. I)
GE CAPITAL MORTGAGE SERVICES. INC., Plaintiff in the above action, by its attorney,
FRANK FEDERMAN, ESQUIRE, sets forth as ofthe date the Praecipe for the Writ of Execution was
filed the following information concerning the real property located at .12 SHIRLEY LANE.
BOILING SPRINGS. PA 17007.
I. Name and address ofOwner(s) or reputed Owner(s):
Name
Last Known Address (if address cannot be
reasonably ascertained, please indicate)
SARA JANE CREELMAN
12 SHIRLEY LANE
BOILING SPRINGS, P A 17007
2. Name and address of Defendant(s) in the judgment:
SARA JANE CREELMAN
12 SHIRLEY LANE
BOILING SPRINGS, PA 17007
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.
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4. Name and address oflast recorded holder of every mortgage of record:
PNC BANK NATIONAL ASSOCIATION
2730 LIBERTY AVENUE
PITTSBURG, PA 15222
None.
5. Name and address of every other person who has any record lien on the property:
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
12 SHIRLEY LANE
BOILING SPRINGS, P A 17007
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.
January 15, 2002
DATE
~~~
FRANK FEDERM , SQUIRE
Attorney for Plaintiff
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FEDERMAN and PHELAN
~y: FRANK FEDERMAN
Identification No. 12248
ONE PENN CENTER AT SUBURBAN STATION
1617 JOHN F. KENNEDY BLVD., SUITE 1400
PHILADELPHIA, PA 19103-1814
(215) 563-7000
ATTORNEY FOR PLAINTIFF
GE CAPITAL MORTGAGE SERVICES, INC.
Plaintiff,
CUMBERLAND COUNTY
COURT OF COMMON PLEAS
v.
CML DMSION
SARA JANE CREELMAN
NO. 01-6453 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.
'~--J/ 11 ,
FRANK FEDERMAN, ESQUIRE
Attorney for Plaintiff
"
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FEDERMAN AND PHELAN
By: ~FEDE~AN
Identification No. 12248
Attorney for Plaintiff
ONE PENN CENTER AT SUBURBAN STATION
1617 JOHN F. KENNEDY BLVD., SillTE 1400
PHILADELPIDA, P A 19103-1814
(215) 563-7000
GE CAPITAL MORTGAGE SERVICES, INC.
5024 PARKWAY PLAZA BOULEVARD
BUILDING 7!F/C
CHARLOTTE, NC 28217-2407
CUMBERLAND COUNTY
COURT OF COMMON PLEAS
CIVIL DIVISION
Plaintiff,
v.
NO. 01-6453 CIVIL
SARA JANE CREELMAN
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 SARA JANE CREELMAN and,
Defendant(s) for failure to file an Answer to Plaintiffs Complaint within 20 days from service thereof
and for Foreclosure and Sale of the mortgaged premises, and assess Plaintiffs damages as follows:
As set forth in Complaint
Interest from 01/16/02 to 06/05/02
TOTAL
$58,595.11
$1373.94
$59,969.05
I hereby certify that (I) 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.
~~ 1;"
FRANK FEDERMAN, ESQUIRE
Attorney for Plaintiff
DAMAGES ARE HEREBY ASSESSED AS INDICAC; .
DATE:.....h ') I'"{ ;;l..OO,,"- '/l i;; .J 7.,
PRO PROTHY
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(Rule of Civil Procedure No. 236) - Revised
IN THE COURT OF COMMON PLEAS OF CUMBERLAND COUNTY, PENNSYLVANIA
CIVIL ACTION - LAW
GE CAPITAL MORTGAGE SERVICES, INC.
5024 PARKWAY PLAZA BOULEVARD
BUILDING 7!FIC
CUMBERLAND COUNTY
COURT OF COMMON PLEAS
CIVIL DIVISION
Plaintiff,
v.
NO. 01-6453 CIVIL
SARA JANE CREELMAN
Defendant(s).
Notice is given that a Judgment in the above-captioned matter has been entered against you on
J:J..J [7 200a.,.
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DEPUTY
If you have any questions concerning this matter, please contact:
FRANK FEDERMAN. ESQUIRE
Attorney for Plaintiff
ONE PENN CENTER AT SUBURBAN STATION
1617 JOHN F. KENNEDY BLVD., SUITE 1400
PHILADELPHIA, PA 19103-1814
(215) 563-7000
"THIS FIRM IS A DEBT COLLECTOR ATTEMPTING TO COLLECT A DEBT AND ANY INFORMA nON
OBTAINED 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 AGAINST PROPERTY."
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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
GE CAPITAL MORTGAGE SERVICES,
INC.
Plaintiff
CIVIL DIVISION
CUMBERLAND COUNTY
vs.
NO. 01-6453 CIVIL
SARA JANE CREELMAN
Defendant(s)
TO: SARA JANE CREELMAN
12 SHIRLEY LANE
BOILING SPRINGS,PA 17007
DATE OF NOTICE: DECEMBER 18. 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 UBERTY AVENUE
CARLISLE, PA 17013
(717) 249-3166
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Frank Fed{rman,~qUire
Attorney for Plaintiff
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By: FRANK FEDERMAN
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
GE CAPITAL MORTGAGE SERVICES, INC.
5024 P ARKW AY PLAZA BOULEVARD
BUILDING 7!FIC
CUMBERLAND COUNTY
COURT OF COMMON PLEAS
CIVIL DIVISION
Plaintiff,
v.
NO. 01-6453 CIVIL
SARA JANE CREELMAN
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 ofthe Soldiers' and Sailors' Civil Relief Act of Congress
of 1940, as amended.
(b) that defendant SARA JANE CREELMAN is over 18 years of age and resides at ,
12 SHIRLEY LANE, BOILING SPRINGS, PA 17007.
(c) that defendant is over 18 years of age, and resides at , , .
This statement is made subject to the penalties of 18 Pa. C.S. Section 4904 relating to
unsworn falsification to authorities.
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FRANK FE ERMAN, ESQUIRE
Attorney for Plaintiff
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GE CAPITAL MORTGAGE SERVICES, INC.
Plaintiff,
CUMBERLAND COUNTY
v.
No.01-6453 CIVIL
SARA JANE CJ{F;ELMAN
Defendant(s).
January 15, 2002
TO: SARAJANECREELMAN
12 SHIRLEY LANE
BOILING SPRINGS, P A 17007
**THIS FIRM IS A DEBT COLLECTOR A TTEMPTlNG TO COLLECT A DEBT AND ANY INFORMATION
OBTAINED WILL BE USED FOR THAT PURPOSE. IF YOU HA VE PREVIOUSLY RECEIVED A DISCHARGE IN
BANKRUPTCY AND THIS DEBT WAS NOT REAFFIRMED, THIS IS NOT AND SHOULD NOT BE CONSTRUED TO BE
AN AITEMPT TO COLLECT A DEBT, BUT ONLY ENFORCEMENT OF A LIEN AGAINST PROPERTY. **
Your house (real estate) at, 12 SHIRLEY LANE, BOILING SPRINGS, PA 17007. is
scheduled to be sold at the Sheriffs Sale on JUNE 5. 2002 at 10:00 a.m. in the Cumberland County
Courthouse, South Hanover Street, Carlisle, P A 17013, to enforce the court judgment of 59,969.05
obtained by GE CAPITAL MORTGAGE SERVICES, INC. (the mortgagee) against you. If the
Sheriff s sale is postponed, the property will be relisted for the Sheriff s Sale.
NOTICE OF OWNER'S RIGHTS
YOU MAY BE ABLE TO PREVENT THIS SHERIFF'S SALE
To prevent this Sheriffs Sale, you must take immediate action:
1. The sale 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
can: (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.)
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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. Ifthe 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 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 the money which was paid for your house. A schedule of
distribution of the money bid for your house will be filed by the Sheriff within 30 days of the sale. This
schedule will state who will be receiving that money. The money will be paid out in accordance with
this schedule unless exceptions (reasons why the proposed distribution is wrong) are filed with the
Sheriff within ten (10) days after the distribution is filed.
7. You may also have other rights and defenses, or ways of getting your home back, if you act
immediately after the sale.
YOU SHOULD TAKE THIS PAPER TO YOUR LAWYER AT ONCE. IF YOU DO NOT HAVE
A LAWYER OR CANNOT AFFORD ONE, GO TO OR TELEPHONE THE OFFICE LISTED
BELOW TO FIND OUT WHERE YOU CAN GET LEGAL HELP.
CUMBERLAND COUNTY ATTORNEY REFERRAL
CUMBERLAND COUNTY BAR ASSOCIATION
2 LIBERTY AVENUE
CUMBERLAND COUNTY COURTHOUSE
CARLISLE, PA 17013
(717) 249-3166
(800) 990-9108
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Township, C~"-~r1and Co~.ty,
anee with a survey by Thomas
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A. Neffl R. S. dated A~gust 13, 197v, as O..C.3~
. 5' . . / . a~e or. p"e
.- 'n+- 0"" the Ncrthe=n side 0: ~~:..Le~.i..J... ,. ...... '1
DEGIN:n:NG a~ a pol. ~:' 19 and 20 on t:'e hereinafter ment;.oned P".an
dividing lin~ be~~een Lot~ NOS'SS9 24 feet West of the Westa~ right of way
of Lots, Solid po~n':. also el.ngl 't~e Nor""'ern s'de 0" Shi=le'/ ..ana South
.21008' TH"NC2 a ong .. I ~.. p. _ p ,. . .
line of L, R.. ,. -. d W st 100 feQp to a po' nt at t..:e d::.'/~dJ.ng
68 dogrees 49 minutes 50 Ge:o~9s nesa;d p'an7-TH"NC~ aiong last said line
line bet'Jeen Lots No:;. ,18 anolO' 0 d; We;t' i20' f~et to a j:Qint~ T"Z::CZ bv
North 21 degrees La mlnutes' seeon
the O~Vl.ding line between Lots Nos, 19 and 31 on said plan North 63 degrees
49 minutes 50. seconds East 100 feet to a point; THENCE by ~'e dividing line
between Lots Nos. 19 and 20 aforesaid South 21 degrees 10 mL.utes 10 seconds
East 120 feet to a point, ~1e place of BEGINNING.
BEING Lot ~o. 19 on the Plan of Lots ~'own as Clifton Heigh~s as
recorded in Plan Book 17, Page 59,
/lAVING erected ~'lereon a masonry and alumi.""ll.l;n sidi.,g ra.""leh ho\:Se.
BEING part of the same premises whi~~ Roy D. Gotshall and Pearl W.
Gotshall, his wife by Deed dated May 22, 1964 and recorded in 'C~~erland
County, in Deed Book F, Vol. 21, Page 336, conveyed ~,to Clifford L. 'Heis~ ~
and Ethel S. Heishman,his wife. &~D being ~~e undivided One-half interest in
and to the s~s premises ,which Clifford L. Heishman and Ethel E., his wife by
Oeed dated November 1, 1967 and recorded in C~~erland County ~ Deed Book 0,
Volume 22, Page 279 conveyed IJ:lto William s. Wert and Lois A. Wert, his wife.
PREMISES: 12 SHIRLEY LANE
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FEDERMAN AND PHELAN, LLP
By: FRANK FEDERMAN, ESQUIRE
IDENfIFICATIONNO.12248
ONE PENN CENTER PLAZA, SUITE 1400
PHILADELPHIA, PA 19103
(71 S) SI1,-7000
ATTORNEY FORPLAmTIFF
COURT OF COMMON PLEAS
CIVIL DIVISION
GE CAPITAL MORTGAGE SERVICES, INe.
5024 P ARKW A Y PLAZA BOULEVARD
BUILDING 7/F/C
CHARLOTTE, NC 28217-2407
Plaintiff
TERM
NO. b\ -1.l./S3 CiuLc... JEA.."\.
CUMBERLAND COUNTY
v.
SARA JANE CREELMAN
12 SHIRLEY LANE
BOILING SPRINGS, PA 17007
Defendant(s)
CTVIl. ACTTON - T,AW
COMFT ,A TNT TN MORTr.Ar.R FORRCT ,OSTTRR
NOTTCF,
**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 warned 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 #: 0022099485/KXM
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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.
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1. Plaintiff is
GE CAPITAL MORTGAGE SERVICES, INe
5024 P ARKW A Y PLAZA BOULEVARD
BUILDING 7/F/C
CHARLOTTE, NC 28217-2407
2. The name(s) and last known addressees) of the Defendant(s) are:
SARA JANE CREELMAN
12 SHIRLEY LANE
BOILING SPRINGS, P A 17007
who is the mortgagor and real owner of the property hereinafter described.
3. On 06/30/98, mortgagor, SARA JANE CREELMAN, made, executed and delivered a
mortgage upon the premises hereinafter described to HOMEGOLD, INC. which
mortgage is recorded in the Office of the Recorder of CUMBERLAND County, in
Mortgage Book No. 1465, Page 388. By Assignment of Mortgage recorded 05/19/99, the
mortgage was assigned to PLAINTIFF which Assignment is recorded in Assignment of
Mortgage Book No. 613, Page 350.
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 07/06/01 and each month thereafter are due and unpaid, and by the terms
of said mortgage, upon default in such payments for a period of one month, the entire
principal balance and all interest due thereon are collectible forthwith.
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6. The following amounts are due on the mortgage:
Principal Balance
Interest
06/06/01 through 10/06/01
(Per Diem $13.47)
Attorney's Fees
Cumulative Late Charges
06/30/98 to 10/06/01
Cost of Suit and Title Search
Subtotal
$51,099.06
1,656.81
1,000.00
89.04
55Jl.illl
$54,394.91
Escrow
Credit
Deficit
Subtotal
0.00
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$4 ?OO ?O
TOTAL
$58,595.11
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 Temporary Stay as provided by the Homeowner's Emergency Mortgage Assistance
Program, Act 91 of 1983, has terminated because 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".
10. By virtue of the death of ARTHUR N. CREELMAN on 03/25/93, SARA JANE
CREELMAN became the sole owner of the mortgaged premises as surviving tenant by
the entireties.
WHEREFORE, PLAINTIFF demands an in = Judgment against the Defendant(s) in the sum of
$58,595.11, together with interest from 10/06/01 at the rate of $13.47 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.
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FRANK FEDERMAN, ESQUIRE
Attorney for Plaintiff
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P.O. Box 1225
Charlotte, NC 28201-1225
September 10, 2001
Sara Jane Creelman
12 Shirley LIl.
Boiling Springs PA 17007
0022099485/001035/936Act91
RE: Wells Fargo Home Mortgage, Inc. Loan Number 0022099485
Mortgagor(s):
Mortgaged Premis""
Sara Jane Creelman
12 Shirley Ln.
Boiling Spr, PA 17007
ACT 91 NOTICE
TAKE ACTION TO SAVE
YOUR HOME FROM
FORECLOSURE
This is an official notice that the mortgage on vour home is in default, and the lender intends to
foreclose. Specific information about the nature of the default is provided in the attached pages.
The HOMEOWNER'S MORTGAGE ASSISTANCE PROGRAM (BEMAP) mav be able to help to
save vour home. This Notice explains how the program works.
To see if HEMAl' can help, you must MEET WITH A CONSUMER CREDIT
COUNSELING AGENCY WITHIN 30 OA YS OF THE OA TE OF THIS NOTICE. Take this Notice
with vou when vou meet with the Counselin~ Agency.
The name, address and phone number of Consumer Credit Counseling Agencies serving vour
County are listed at the end of this Notice. If vou have anv Questions, vou mav call the Pennsvlvania
Housing Finance Agencv toll free at 1-800-342-2397. (Persons with impaired hearing can call
(717) 780-1869).
This Notice contains important legal information. If you have any questions, representatives
at the Consumer Credit Counseling Agency may be able to help explain it. You may also want to
contact an attorney in your area. The local bar association may be able to help you find a lawyer.
LA NOTIFICACION EN ADJUNTO ES DE SUMA IMPORTANCIA, PUES AFECTA SU DERECHO
A CONTINUAR VIVIENDO EN SU CASA. SI NO COMPRENDE EL CONTENDO DE ESTA
NOTIFICACION OBTENGA UNA TRADUCCION INMEDITAMENTE LLAMANDO ESTA
AGENCIA (PENNSYLVANIA HOUSING FINANCE AGENCY) SIN CARGOS AL NUMERO
MENCIONADO ARRIBA. PUEDES SER ELEGIBLE PARA UN PRESTAMO POR EL PROGRAMA
LLAMADO "HOMEOWNER'S EMERGENCY MORTGAGE ASSISTANCE PROGRAM" EL CUAL
PUEDE SAL V AR SU CAS A DE LA l'ERDIDA DEL DERECHO A REDIMIR SU HIPOTECA.
EXH\B\T A
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HOMEOWNER'S NAME(S):
Sara T ane Creelman
PROPERTY ADDRESS:
12 Shirley I n
Boiling Spr, PA 17007
0022099485
LOAN ACCT. NO.:
ORIGINAL LENDER:
CURRENT LENDER/SERVICER:
WELLS FARGO HOME MORTGAGE, INC.
HOMEOWNER'S EMERGENCY MORTGAGE ASSISTANCE PROGRAM
YOU MAYBE ELIGIBLE FOR FINANCIAL ASSISTANCE
WHICH CAN SAVE YOUR HOME FROM FORECLOSURE AND
HELP YOU MAKE FUTURE MORTGAGE PAYMENTS
IF YOU COMPLY WITH THE PROVISIONS OF THE HOMEOWNER'S EMERGENCY
MORTGAGE ASSISTANCE ACT OF 1983 (THE "ACT"), YOU MAY BE ELIGIBLE FOR EMERGENCY
MORTGAGE ASSISTANCE:
. IF YOUR DEFAULT HAS BEEN CAUSED BY CIRCUMSTANCES BEYOND YOUR CONTROL.
. IF YOU HAVE A REASONABLE PROSPECT OF BEING ABLE TO PAY YOUR MORTGAGE
PAYMENTS, AND
. IF YOU MEET OTHER ELIGIBllJTY REQUIREMENTS ESTABLISHED BY THE PENNSYLVANIA
HOUSING FINANCE AGENCY. '
TEMP~RAR Y STAY OF FOREfoL~SURE -- Under the Act, you are entitled to a temporary stay
of forec osure on your mortgage or t irry (30) days from the date of this Notice. Durmg that time
you must arrange and attend a "f~ce-to-face" meetin with one of the consumer credit counsclin
agencies listed at the end of this Notice.
UO! DAYS. If YOU DO NOT AI'I'L Y fOR EMERGENCY MORTGAGE ASSIST ANCE~ YOU
I ST BRING YOUR MORTGAGF IlPTODATF THF PART OF THIS NOTI"E "AI lED
"HOW TO CURE YOUR MORTC;A(;r IWrAtH T" EX!'I AINS HOW TO BRINC; YO{IR
MORTGAGE UP TO DATE.
CONSUMER CREDIT COU~SEL!~r AGENCIES -- If you meet with one of the consumer credit
counseling agencies listed at t e end 0 this notice, the lender may NOT take action against you
for thirty (30) days after the date of this meeting. The names. addresses and teleohone numbers
of desi nated on lmer credit COt n lin enctes for the coun in whi h the ro er is
r n i i I is on y necessary to sc e u e one ,ace-to-face
meeting. Advise your lender immediatelv of your intentions.
A!'PLT~ATTON FOR MORTGAGE ASSISTAN~E -- Your mortgage is in default for the reasons
set fort later in this Notice (see following pages or specific information about the nature of your
default.) If you have tried and are unable to resolve this problem with the lender, you have die
right to apQ.ly for financial assistance from the Homeowner's Emergency Mortgage Assistance
Program. To do so, you must fill out, sign and file a comj)leted Homeowner's Emergency
ASSIstance Program Application with one of the designatea consumer credit counseling agencies
listed at the end of this Notice. Only consumer cred,t counseling agencies have applicationsfor
the p~ogram and they will assist you in submitting a co,?plete apphcation to ~he. Pennsylvama
Housmg Fmance Agency. Your apphcatlon MUST be f,ied or postmarked wlthm thIrty (30) days
of your lace-to-face meeting.
YOU M1lSI FILE YOUR APPLICATION PROMPTLY. IF YOU FAIL TO DO SO OR IF YOU
DO NOT FOLLOW THE OTHER TIME PERIODS SET FORTH IN THIS LETTER, FORECLOSURE
MAY PROCEED AGAINST YOUR HOME IMMEDIA TEL Y AND YOUR APPLICATION FOR
MORTGAGE ASSISTANCE WILL BE DENIED.
EXH!BIT A
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001035/936
A('dE~CY A~TT~N -- Available funds fa; ~l)lergency. mortgage assistance are very limited. They will
be IS. ursed y t e Agency under the elIgIbIlIty cntena established by the Act. The Pennsylvania
Housmg Fmance Agency lias sIxty (60) days to make a decIsIon after It re~elves your applIcation.
Dunng that tIme, no foreclosure proceedmgs wIll be pursued agamst you If you have met the time
requirements set forth ahove. You WIll he notifIed directly hy the Pennsylvania Housing Finance
Agency of its decision on your application.
NOTE: IF YOU ARE CURRENTLY PROTECTED BY THE FILING OF A PETITION
IN BANKRUPTCY, THE FOLLOWING PART OF THIS NOTICE IS FOR INFORMATION
PURPOSES ONLY AND SHOULD NOT BE CONSIDERED AS AN ATTEMPT
TO COLLECT THE DEBT.
(If you have filed bankruptcy you can still apply for Emergency Mortgage Assistance.)
HOW TO CURE YOUR MORTGAGE DEFAULT (Bring it up to date).
NATURE OF THE DEFAULT - - The MORTGAGE debt held by the above lender on your propertv
located at: 1? SJ,irlp.y Tn'
IS SERIOUSr~I~~~Fj:u2fO~~cause:
A. YOU HAVE NOT MADE MONTHLY MORTGAGE PAYMENTS for the following months and
the following amounts are now past due:
Jl1ly )001 - Septemher )001 ~,O,,, R,
Late Char es
$0.00
$2,463.34
TOTAL AMOUNT PAST DUE:
B. YOU HAVE FAILED TO TAKE THE FOLLOWING ACTION
HOWT~ CURE THE DEFAULT - - You may cure the default within THIRTY (30) DAYS of the
date of t is notice BY PAYING THE TOTAL AMOUNT PAST DUE TO lHE LENDER WHICH
IS $ 2,463.34, PLUS ANY MORTGAGE PAYMENTS AND LATE CHARGES WHICH BECOME
DUE DURING THE THIRTY (30) DAY PERIOD. paJments must be made either by cash, cashier's
check, certified check or money order made payable an sent to:
WELLS FARGO HOME MORTGAGE, INe.
1 HOME CAMPUS
X2501-01H
DES MOINES, IOWA 50328
You can cure any other default by taking the following action within THIRTY (30) DAYS of the date
of this letter:
IF YO~ DO NOT CURE THE DEFAULT - - If you do not cure the default within THIRTY (30) DAYS
at the ate at this Notice, the lender intends to xerci e its ri hts to accelerate the mort a e debt. ThIS
means that the entire out~tan mg a ance 0 t IS e t WI e cons I ere ue Imme Ia.te y an you may
lose the chance to pay' the mortgage in monthly installments. If full payment of the total amount pasr
due is nor made wlthm THIRTY (30) DAYS, the lender also intcnds to instruct its attorncys to srart
legal action to foreclose upon vour mOrll!al!ed propertv.
IF THE M~RTGAGE I~ FORECL~SED I J~N - - The mortgaged property will be sold by the Sheriff
to pay ott t e mortgage ebt. It the ender re ers your case to Its attorneys, liut you cure the delinquency
betore the lender begins legal llroceedings against you, you will still be reqnired to pay the reasonable
attornev's fees that were actually incurred, up to $50.00. However, if legal proceedings are started.
againsfyou, you will have to pay all reasonable attorney's fees actually incurred hy the lender even If
they exceed $50.00. Any attorney's fees will be added to the !l~ount you owe the lender, whl~h may
also include other reasonahle costs, If vou cure the default wlthm the THIRTY (30) DA Y period, vou
will not be required to pav attornev's lees.
OTHFR I ~1JPFR RFMFTS - - The lender may also sue you personally for the unpaid principal
balance an a lather sums ue under the mortgage.
EXHIBIT A
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_"i~.{
001035/936
RIGHT TO CURE THE DEFAULT PRIOR TO SHERIFF'S SALE -- If you have not cured the default
wlthm the THIRTY (30) DAY penod and foreclosure proceedings have be un, VOll still have the right
r fir v n h n im n r f r h riff' I Y m
do so h' a'in the total amollnt then ast lle Ius an ' late or other char es then due reasonahle
attornev's ees and costs connecte wit the orec osure sa e and anv ot er costs connected with the
Sheriff's Sale as s eeified in writin b the lender and b erformin an other re uirements under the
mortgage. Curin~ your de au t in t e manner set ort in t is notice wi restore your mortgage to the
same position as If you had never defaulted.
FARLlFST POSSIRI E SHFRIFF'S SA! F DATF -- It is estimated that the earliest date that sllch a
Sheriff's Sale of the .mortgaged prorerty could be held would be approximately six (6) months from
the date of thIS Notice. A notice 0 the actual date of the Sheriff's Sale will be sent to YOll before the
sale. Of course, the amount needed to cure the default will increase the longer you wait. You may find
out at any time exactly what the required payment or action will he hy contacting the lender.
HOW TO CONTACT THF I HffiFR'
Name of Lender:
Address:
Wells Fargo Home, Mortgage, Inc.
5024 Parkway Plaza Blvd.
Charlotte, NC 28217
1-800-766-0987
704-423-4016
T anisha Robinson
Phone Number:
Fax Number:
Contact Person:
EFFECT OF SHERIFF'S SAI E -- You should realize that a Sheriff's Sale will end your ownership of
the mortgaged property and your 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 -- You _ mayor _ may not sell or transfer your home to
a buyer or transferee who will assume the 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:
o TO SELL THE PROPERTY TO OBTAIN MONEY TO PAYOFF THE MORTGAGE DEBT
OR TO BORROW MONEY FROM ANOTHER LENDING INSTITUTION TO PAY OFF
THIS DEBT.
o TO HAVE THIS DEF AUL T CURED BY ANY THIRD PARTY ACTING ON YOUR BEHALF.
o TO HAVE THE MORTGAGE RESTORED TO THE SAME POSITION AS IF NO DEPAUL T
HAD OCCURRED IF YOU CURE THE DEFAULT. (HOWEVER YOU DO NOT HAVE
THIS RIGHT TO (~URE YOUR DEfAULT MORE THAN THREE TIMES IN ANY
CALENDAR YEAR.)
o TO ASSERT THE NONEXISTENCE OF A DEFAULT IN ANY FORECLOSURE
PROCEEDING OR ANY OTHER LAWSUIT INSTITUTED UNDER THE MORTGAGE
DOCUMENTS.
o TO ASSERT ANY OTHER DEFENSE YOU BELIEVE YOU MA Y HAVE TO SUCH
ACTION BY THE LENDER.
o TO SEEK PROTECTION UNDER THE FEDERAL BANKRUPTCY LAW.
Ey,...1I '3 ~T A
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PE:'INSYL V.~'IIA HOUSING FINA.'1CE AGE:'ICY
HOMEOWNER'S E:\1ERGENCY ASSISTA.'1CE PROGR.UI
CONSUMER CREDIT COUNSELING AGE:'iCIES
(REV. 8100)
PERRY COt",,'"
cccs OrWd<':"~ ?::r:n3:~I...:mi:l.., lnc.
2000 LinglestOwn Road
H:!tt'isbW'J. PA 17t02
(i17) S.U~(7Si FA.Xti1j 54!-4670
Finar.c::ll C.J:.:.....s.:!ir:j ~~.:;;:! cf::~~:l
3t Wc:stj....SC':::t
Wa.Yncsboro. PA 17:63
(il7) 76:.3'!S:!
Urb:J.n ~ue o( :Vlctrepolit:ln H:1rrisbUCi
2101 :--.tanh 6<31 Strc:et
H:1tT'IsbUfl.,PAlitol .
(717) ZJJ-59~S F.~X (71'7) 23.:.-9.159
We:uhcriz:ttion Offic:
9t7 Mifflin S~t
Huntingdon. PA t 666::
(St..t) 6434::::..1:
y\VCA oEC.1tHsl::
301 -G- 5'''"'
C.:rlislc. P.-\. I iO lJ
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C.:::rr...-nunity Ac::cn CJr:"..7.lssicr:..::f
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Acorn HOUjmg COrp'CQUcn
:5..16 ~ort., 8ro~d SU'e:=':.
Phll:u!e;:!phl:L l'A t9UO
{:15} :"6J-Z::r
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Phli.c.lph',," PA 19107
(2L~) 563-5663 FA..,,({115) 36.1.:666
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P!ul:l.IleJph1a. p,,,, 19!40
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Hcu.sin~ Asscd::mcn JJ..:e::.\"'o:: '1:::..i:~'
t 500 WJ.!nut S~_ 514:..: :') 1
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EXHIBIT A
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, . ' 1 d . t te in South Middleton .'
~ll 'that certain piece or parcel ~f ~ ~~du:nd described in accord-
T~n8hip, Cl11llberla.n:d county, penns~~v~J,.as ~:ed August 13, 197D, ,as fo+lOws:
ance with a survey by Thomas, A. 1(e , . . '
, th side of Shirley Lane on the
. BEGINNING at a point on the Nord e~on the hereinafter mentioned Plan
.dividing li~~ be~w:en Lot~ ~os'5~:.~ f:et West of the Western right of way
of Lots, sa~a po~n~a~l;~EN~~nilOng the Northern 'side of Shirley La~e.S~uth.
line of L. R. 12100 , t 100 feet to a point at the d~v~d~ng ,
?B dogrees 49 minutes 50 secon~soWe~aid plan: THENCE along l~st said line
l~ne between Lots No~. .18 and 1, n d West 120 feet to a po~nt; THENCE bV
North 21 degrees 10 m~nutes'lO secon s
tne CllV:i.ding line between Lots Nos. 19 and 31 on said plan North 68 degrees
49 minutes 50. seconds East 100 feet to a point 1 THENCE by the dividing line
between Lots Nos. 19 and 20 aforesaid South 21 degrees 10 minutes 10 seconds
East 120 feet to a point, the place qf BEGINNING.
BEING Lot No. 19 on the Plan of Lots known as Clifton Heights as
recorded in Plan Book 17, Page 59..
HAVING erected thereon a masonry and aluminum siding ranch house.
BEING part of the same premises which,Roy D. Gotshall and' Pearl W.
GotShall, his wife by Deed dated May 22, 1964 and recorded in' Cumberland
County, in Deed Book F, Vol. 21, Page 336. conveyed unto Clifford L. . Heishman ,an
and Ethel E. Heishman,his wife. AND being the undivided one-half interest in
and to the same premises ,which Clifford L. Heishman and Ethel E., his wife by,
Deed dated November 1, 1967 and recorded in Cumberland County in Deed BOok 0,
Volume 22, Page 279 conveyed unto William S. We:r:t and LobA. Wert, his wife.
PREMISES: 12 SHIRLEY LANE
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VERIFICA nON
TAMMY JOHNSON hereby states that she is ASSISTANT VICE PRESIDENT of
WELLS FARGO HOME MORTGAGE, INe. 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, CS. Sec, 4904
relating to unsworn falsification to authorities.
~J
-
DATE: /1/5/01
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PRAECIPE FOR WRIT OF EXECUTION - (MORTGAGE FORECLOSURE)
P.R.C.P.3180-3183
GE CAPITAL MORTGAGE SERVICES, INC.
Plaintiff,
v.
No.01-6453 CIVIL
SARA JANE CREELMAN
Defendant(s).
TO THE DIRECTOR OF THE OFFICE OF THE PROTHONOTARY:
Issue writ of execution in the above matter:
Amount Due
$59,969.05
hlterest from 01/15/02 to 06/05/02
(per diem -9.86)
$1,390.26 and Costs
TOTAL
$61,359.31
-+~' t~
FRANK FEDERMAN, E~
One Penn Center at Suburban Station
1617 John F. Kennedy Boulevard, Suite 1400
Philadelphia, PA 19103-1814
Attorney for Plaintiff
Note: Please attach description of property. No.
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O~ arcel of l~,d situate in So~th M~adleton.__
that cer~ain piece - P d d b d ~n ~ccora-
Curnberlartd County, Pennsylv~~ia, bo~,ded an ~e~~r~1~7J, as follows:
by Thomas A lIeft, R. S. dated Augus~, , '
a survey , .
int on the Northern side of Shirley Lane o~ the
BEGINNING at a po 19 d 20 on the hereinafter mentloned ~1an
dividing li~e be~w~en Lot~ ~oS'589.~ feet West of the Western right of ~ay
of Lots, sald po~n~ ~l;~EN~~nirong the Northern side of Shirley La~e.s~u_~
line of L. R. #21008, 0 d West 100 feet to a point at the dlvldlng
68 degrees 49 minutes 5 se~o~9son said plan: THENCE along last said line
line betWeen Lots No~..la an'lO'seconds West 120 feet to a point~ THENCE bv
North 21 degrees 10 mlnutes
All
TO'Nnship,
ance ",ith
the a~Vlding line between Lots Nos. 19 and 31 on said plan North 68 degrees
49 minutes 50. seconds East 100 feet to a point; THENCE by ~~e dividing line
between Lots Nos. 19 and 20 aforesaid South 21 degrees 10 minutes 10 seconds
East 120 feet to a point, ~'e place of BEGINNING.
BEI~G Lot No. 19 on the Plan of Lots ~'own as Clifton Heights as
recorded in Plan Book 17, Page 59.
HAVING erected thereon a masonry and a1umi.~um sidi.,~ ranch house.
BEING part of the same premises whi~~ Roy D. Gotshall and' Pearl W.
Gotshall, his wife by Deed dated May 22, 1964 and recorded in 'Cumberland
County, in Deed Book F, Vol. 21, Page 336. conveyed unto Clifford L. . Heishman an
and Ethel E.' Heishman,his wife. AND being ~'e undivided One-half interest in
and to the same premises ,which Clifford L. Heishman and Ethel E., his wife by
Oeed dated November 1, 1967 and recorded in Cumberland County io1 Deed llook O.
Volume 22, Page 279 conveyed unto William S. Wert and Lois A. Wert, his wife.
PREMISES: 12 SHIRLEY LANE
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SHERIFF'S RETURN - REGULAR
CASE NO: 2001-06453 P
COMMONWEALTH OF PENNSYLVANIA:
COUNTY OF CUMBERLAND
GE CAPITAL MORTGAGE SERVICES
VS
CREELMAN SARA JANE
JASON VIORAL
, Sheriff or Deputy Sheriff of
Cumberland County, Pennsylvania, who being duly sworn according to law,
says, the within COMPLAINT - MORT FORE
was served upon
CREELMAN SARA JANE
the
DEFENDANT
, at 2056:00 HOURS, on the 26th day of November, 2001
at 12 SHIRLEY LANE
BOILING SPRINGS, PA 17007
by handing to
SARA CREELMAN
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
18.00
3.25
.00
10.00
.00
31.25
So Answers:
r~~
R. Thomas Kline
11/28/2001
FEDERMAN & PHELAN
Sworn and Subscribed to before
By:
~~f
me this
3{)~ day of
1L~ J.kQ( A.D.
~Q~,~
rothonotary ,
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AFFIDAVIT OF SERVICE
.:Yf' (,-
PLAINTIFF
GE CAPITAL MORTGAGE SERVICES,
INC.
CUMBERLAND COUNTY
,,'
No. 01-6453 CIVIL
DEFENDANT(S)
SARA JANE CREELMAN
ACCT. #0022099485
SERVE SARA JANE CREELMAN AT
12 SIllRLEY LANE
BOILING SPRINGS, P A 17007
Type of Action
- Notice of Sheriff's Sale
Sale Date: JUNE 5, 2002
SERVE~
Served and made known to 5 01 ~ a 0'Ol1V e. C~ ~ ~ D;:d;~n the :J.. 7 ~L day of d31J , 200":"1'--
at 5:S-0, o'clock .f'..m., at If}... -st. i "- [~/ L-./V I I Go; (; 1'<~ 9 f K I N,S9 , Commonwealth
of Pennsylvania, in the manner described below:
)(
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 of business.
an officer of said Defendant(s)'s company.
Other:
I II 1'-" - I
~ S (""'/' /.'/ f- '&s'5c::S'
Description: Age...E.!:? Height ~ Weight .-:!!::! Race ~ Sex _ Other '3
I, <.1 (lj(.,,-IV c"- l, C<l f1.. -\: 1 ' ~~ompetent adult, being duly sworn according to law, depose and state that I personally handed
a true and correct copy of the Notice of Sheriff's Sale in the manner as se!forth herein, issued in the captioned case on the date and at
the address indicated above.
Sworn to and subscr*,ed
before me this ~fiJ day
of T'iJ-f"V....".2001> Q,,-hJ,
Nota~1Y\/,y ~~
PLE ATTEMPT SERVICE AT LEAST 3 TIMES. INDICATE
NOT SERVED
On the day of
,200_, at
o'clock _.m., Defendant NOT FOUND because:
Moved Unknown
No Answer
Vacant
Other:
Sworn to and subscribed
before me this _ day
of , 200 _'
Notary:
By:
Attornev fOT Plaintiff
Frank Federman, Esquire - I.D. No. 12248
One Penn Center at Suburban Station
1617 John F. Kennedy Boulevard, Suite 1400
Pbiladelphia"PAi 19103-1814
(215) 563-7000,:
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GE Capital Mortgage Services, Inc.
VS
Sara Jane Creelman
In The Court of Common Pleas of
Cumberland County, Pennsylvania
Writ No. 2001-6453 Civil Term
R. Thomas Kline, Sheriff, who being duly sworn according to law, states this writ
is returned STAYED pursuant to instructions from Attorney Frank Federman.
Sheriffs Costs:
Docketing
Surcharge
Law Library
Prothonotary
Mileage
Levy
Advertising
Posting Handbills
Share of Bills
Poundage
Law Journal
Patriot News
Certified Mail
Postpone Sale
30.00
20.00
.50
1.00
6.90
15.00
15.00
15.00
25.20
14.64
330.50
251.35
1.72
20.00
$746.81 paid by attorney
09/03/02
Sworn and subscribed to before me So ~
This q1e. day of J?r;.....~ M. ~~
rl R. Thomas Kline, Sheriff
2002, A.D. \. l't~..j}~ ~ ByvocivJrWJ:.h
Prothonotary Real Estate Deputy
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GE CAPITAL MORTGAGE SERVICES, INC:
'.
CUMBERLAND COUNTY
,
Plaintiff,
v.
COURT OF COMMON PLEAS
SARA JANE CREELMAN
CIVIL DMSION
Defendant(s).
NO.01-6453 CIVIL
AFFIDAVIT PURSUANT TO RULE 3129
(Affidavit No. I)
GE CAPITAL MORTGAGE SERVICES. INC., Plaintiff in the above action, by its attorney,
FRANK FEDERMAN, ESQUIRE, sets forth as of the date the Praecipe for the Writ of Execution was
filed the following information concerning the real property located at .12 SHIRLEY LANE.
BOILING SPRINGS. PA 17007.
1. Name and address of Owner(s) or reputed Owner(s):
Name
Last Known Address (if address cannot be
reasonably ascertained, please indicate)
SARA JANE CREELMAN
12 SHIRLEY LANE
BOILING SPRINGS, P A 17007
2. Name and address ofDefendant(s) in the judgment:
SARA JANE CREELMAN
12 SHIRLEY LANE
BOILING SPRINGS, P A 17007
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.
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4. ,Name and address of last recorded holder of every mortgage of record:
~
.
PNC BANK NATIONAL ASSOCIATION
2730 LIBERTY AVENUE
PITTSBURG, PA 15222
None.
5. Name and address of every other person who has any record lien on the property:
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
12 SHIRLEY LANE
BOILING SPRINGS, P A 17007
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
1 verify that the statements made in this affidavit are true and correct to the best of my personal
knowledge or information and belief. 1 understand that false statements herein are made subject to the
penalties of 18 Pa. C.S. Sec. 4904 relating to unsworn falsification to authorities.
January 15. 2002
DATE
~~~
FRANKFEDE , SQUIRE
Attorney for Plaintiff
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GE CAPITAL MORTGAGE SERVICES, INC.
Plaintiff,
CUMBERLAND COUNTY
v.
No. 01-6453 CIVIL
SARA JANE CREELMAN
Defendant(s).
January 15, 2002
TO: SARA JANE CREELMAN
12 SHIRLEY LANE
BOILING SPRINGS, PA 17007
"THIS FIRM IS A DEBT COLLECTOR ATTEMPTING TO COLLECT A DEBT AND ANY INFORMATION
OBTAINED WILL BE USED FOR THAT PURPOSE. IF YOU HA VE 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, 12 SHIRLEY LANE, BOILING SPRINGS, PA 17007. is
scheduled to be sold at the Sheriffs Sale on JUNE 5. 2002 at 10:00 a.m. in the Cumberland County
Courthouse, South Hanover Street, Carlisle, P A 17013, to enforce the court judgment of 59,969.05
obtained by GE CAPITAL MORTGAGE SERVICES, INC. (the mortgagee) against you. If the
Sheriff s sale is postponed, the property will be relisted for the Sheriff s Sale.
NOTICE OF OWNER'S RIGHTS
YOU MAY BE ABLE TO PREVENT THIS SHERlFF'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 mOf" ehanc~
you will have of stopping the sale. (See notice on page two on how to obtain an attorney.)
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YOU MAY STILL BE ABLE TO SAVE YOUR PROPERTY AND YOU HAVE OTHER
RIGHTS EVEN IF THE SHERIFF'S SALE DOES TAKE PLACE.
I. 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 maybe able to petition the Court to set aside the sale if the bid price was grossly
inadequate compared to the value of your property.
3. The sale will go through only if the buyer pays the Sheriff the full amount due in the sale. To
find out if this has happened, you may call (717) 240-6390.
4. If the amount due from the Buyer is not paid to the Sheriff, you will remain the owner of the
property as if the sale never happened.
5. You have the right to remain in the property until the full amount due is paid to the Sheriff
and the Sheriff gives a deed to the buyer. At that time, the buyer may bring legal proceedings to evict
you.
6. You may be entitled to a share of the money which was paid for your house. A schedule of
distribution of the money bid for your house will be filed by the Sheriff within 30 days of the sale. This
schedule will state who will be receiving that money. The money will be paid out in accordance with
this schedule unless exceptions (reasons why the proposed distribution is wrong) are filed with the
Sheriff within ten (10) days after the distribution is filed.
7. You may also have other rights and defenses, or ways of getting your home back, if you act
immediately after the sale.
YOU SHOULD TAKE THIS PAPER TO YOUR LAWYER AT ONCE. IF YOU DO NOT HAVE
ALA WYER 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
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ance ...ith a survey by ThoU'"""
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0... pa._ce 'l., d i"" accc..,......-
?ennsylva..,ia, bO\:"'l,ced and desc::-:.....e " u _ :;-; WI .
~- R 5 datpd Au~ust 13r 197u, a~ fo~.c 3.
A. Me....t:: I . - __ J
h ~ -h - .....;.Je 0':: S...;.....iev Lane on t:1e
~ .... info. on t.. e ..'lor..... e...__ ~....... ... H.............. . d "1
OEGINNkNG a~ a po -. 19 ar.d 20 on the hereinafter ment~one _~ an
dividing 1i~~ be~~een Lots ~05'539.24 feet West of the Western right ot ~ay
0: Lots, s..~d pOl.nt also bec:ngl the Nor""'e- s;de o~ Shi::le', ..ane South
'21008' TH"N l:: a ong . . .u ... -.. '.. 'd'
line of L. R.. " . -' d . W st 100 feg;. to a "'oint at: t:"e c::.'n. l.ng
40 mi "es 50 Gecon 5 e --.. "d l'
68 dogrees J nU~ d '19 sa;d p1an' TH"NC~ along last sal. l.ne
N 18 an on - .... .~. - . '" _",....,. b
line bet....een Lots 0:;.. . d West 120 f~et to a j:O~nt~ .H"",,,'-"'o v
North 21 degrees 10 m~nute510 secon s
:~e alV~ding line between Lots Nos. 19 and 31 on said plan Nor~h 63 degrees
49 minutes 50. seconds East 100 feet to a point; THENC~ by ~~e dividing line
between Lots Nos. 19 and 20 aforesaid So~th 21 degrees 10 mL.utes 10 seconds
East 120 feet to a point, ~le place qf BEGINNING.
BEING Lot ~o. 19 on the Plan of Lots ~'own as Clifton Heights ~s
recorded in Plan Book 17, Page 59.
!L\VING erected thereon a masonry and alumi:lu:n sidL,g ra.'1ch ho~e.
BEING part of the same premises whi~~ Roy O. Gotshall and Pearl W.
Gotshall, his wife by Deed dated May 22, 1964 and recorded in 'C~~erland
County, in Deed Beok F, Vol. 21, Page 336, Conveyed unto Clifford L. 'Heis~ ~
and Eehel B. Heishman,his wife. &~D being the undivided one-half interest in
and to the s~s premiseswnich Clifford L. Heishman and Ethel ~., his wife by
Deed dated November 1, 1967 and recorded in Cumberland County 1;, Deed .Book 0,
Volume 22, Page 279 conveyed unto William s. l-ie:rt and Lois A. Wert, nis ...iie.
PREMISES: 12 SHIRLEY LANE
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WRIT OF EXECUnON and/or ATTACHMENT
,
COMMONWEALTH OF PENNSYL VANIA)
COUNTY OF CUMBERLAND)
NO 01-6453 Civil
CIVIL ACTION - LAW
TO THE SHERIFF OF Cumberland COUNTY:
To satisfy the debt, interest and costs due GE CAPITAL MORTGAGE SERVICES, INe.
PLANTIFF(S)
From SARA JANE CREELMAN, 12 SHIRLEY LANE, BOILING SPRINGS, PA 17007
(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 gamishee(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 anYOl)e other than a named garnishee, you are directed to notify him/her that he/she has been added as a
garnishee and is enjoined as above stated.
Amount Due $59,969.05 L.L. $.50
Interest FROM 1/15/02 TO 6/5/02 (PER DIEM - 9.86) $1,390.26 AND COSTS
Arty's Comm % Due Prothy $1.00
Arty Paid $103.25 Other Costs
Plaintiff Paid
Date: JANUARY 17, 2002
CURTIS R. LONG
Prothonotary, Civil Division
By.:.
a~p P.7rfR/llv.;:Dffy-
REQUESTING PARTY:
Name FRANK FEDERMAN, ESQUIRE
Address: ONE PENN CENTER AT SUBURBAN STATION
1617 JOHNF. KENNEDY BOULEVARD, SUITE 1400
PHILADELPHIA, PA 19103-1814
Attorney for: PLAINTIFF
Telephone: 215-563-7000
Supreme Court ID No. 12248
TRUE COPY FFK)M RECORD
If'! Testimony wlleroof, IlIere unto set my hand
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DEAL ESTI'ITE' c;M (!\In (?
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On February 6, 2002, the sherifflevied upon the
defendant's interest in the real property situated in
South Middleton Township, Cumberland County, P A,
known and numbered as 12 Shirley Lane, Boiling Springs,
and more fully described on Exhibit "A" filed
with this writ and by this reference incorporated herein.
Date: February 6, 2002
By: Joch S~
Real Estate Deputy
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PROOF OF PUBLICATION OF NOTICE
IN CUMBERLAND LAW JOURNAL
(Under Act No. 587, approved May 16,1929), P. L.1784
STATE OF PENNSYL VANIA :
ss.
COUNTY OF CUMBERLAND :
Roger M. Morgenthal, Esquire, Editor of the Cumberland Law Journal, ofthe 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 regnlar editions and issues ofthe said Cumberland Law
Journal on the following dates,
VIZ:
APRIL 26, MAY 3, 10, 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.
----
.
\
SWORN TO AND SUBSCRIBED before me this
10 day of MAY. 2002
\
,
N SEAL
LOIS E. SNYDER, NoIaIy NlIIc
Catl\sie Bom. CunIbel\8lld CcIIIlY.
My Cornlllisslon Expires Man:h 5.2005
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IlEAL ESTATE SALE NO.8
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Writ No. 2001-6453 Civil
GE Capital Mortgage
$.ervices. Inc.
vs.
Sara Jane Creelman
Atty.: Frank Fedcnnan
ALL that certain piece or parcel
of land situate in South Middleton
Township. Cumberland County.
PennsylvanIa. bounded and de-
scribed in accordance With a sur-
vey by Thomas A Neff. R S. dated
August 13. 1970. as follows:
BEGINNING at a .point on the
Northern side of ShIriey Lane on the
dividing line between _~ts Nos. 19
and 20 on tile hereinaftcr.inentioued
Plan of Lots. said point ~so being
589.24 feet West of the Western
right of way line of L. R. #21008:
llIENCE along the Northern side of
Shirley Lane South 68 degrees 49
minutes 50 seconds West lOa feet
to a poInt at the dIviding line be"
ween Lots Nos. 18 and 19 on said
plan: TIlENCE along last said line
North 21 degrees 10 minutes 10
seconds West 120 feet to a point;
THENCE 0,1 the dividing line bc~
tween, Lots.T'Jos. 19 a,.'1d 31 on said
plan North '38 degrees 49 minutes
50 seconds East 100 feet to a point;
TIlENCE by the dividing line be.
tween Lots Nos. 19 and 20 afore-
said South 21 degrees 10 minutes
10 seconds East 120 feet to a point.
the place of BEGINNING.
BEING Lot No. 19 on the Plan of
Lots knO\\'l1 as Clifton Heights as
recorded in Plan Book 17. Page 59.
HAVING erected thereon a IDa ~
BOmy and alwnInum siding ranch
house.
BEING part of the same premIses
which Roy D. Gotshall and Pearl W.
Gotshall. his wife by Deed dated
May 22. 1961 and recorded in
Cumberland County. in Deed Book
F. Vol. 21. Page 336 conveyed unto
Clifford L. Heishman and EUlel E.
Heishman. his wife. AND being the
undivided one-half interest in and
to the same premises which Clifford
L. Heislunan and Ethel E,. his wife
by Deed da ted November 1. 1967
and recorded in Cumberland CoWlty
in Deed Dook O. Volwne 22. Page
279 conv'.:yed unto William S. Wert
and Lois A Wert. his wife.
PREMISES, 12 SHlRLEY LANE.
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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
Frank J. Epler being duly sworn according to law, deposes and says:
That he is the Controller of The Patriot News Co., a corporation organized and existing under the laws of the
Commonwealth of Pennsylvania, with its principal office and place of business at 812 to 818 Market Street, in the
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 published ever since;
That the printed notice or pUblication which is securely attached hereto is exactly as printed and pUblished in
their regular daily and/or Sunday/ Metro editions which appeared on the 23rd and 30th day(s) of April 2002 and the
7th day(s} of May 2002. That neither he nor said Company is interested in the subject matter of said printed notice
or advertising, and that all of the allegations of this statement as to the time, place and character of publication are
true; and
That he has personal knowledge of the facts aforesaid and is duly authorized and empowered to verify this
statement on behalf of The Patriot-News Co. aforesaid by virtue and pursuant to a resolution unanimously passed and
adopted severally by the stockholders and board of directors of the said Company and subsequently duly recorded in
the office for the Recording of Deeds in and for said County of Dauphin in Miscellaneous Book "M",
Volume 14, Page 317.
PUBLICATION
COpy
s ALE #8
~...~...................................................
Sworn to' 17th &.0 y 200 D.
Notarial Seal
rony L. RUSSfU; Notaoy PuDIIc TARY PUBLIC
HalTlsburg. Dauphin County
My Comlllisslon E""iros June 6, mission expires June 6, 2002
Member, PennsylVania ASSOOlalion Of Nota~es
CUMBERlAND COUN1Y SHERIFFS OFFICE
CUMBERlAND COUN1Y COURTHOUSE
CARLISLE, PA. 17013
Statement of Advertising Costs
To THE PATRIOT-NEWS CO., Dr.
For publishing the notice or publication attached
hereto on the above stated dates $
Probating same Notary Fee(s) $
Tm~ $
249.60
1.75
251.35
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....................................................................
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~:3cBW. ESl:AfE $ALE No. S' _~n_
~!: ,~,~~, WdlN..~l-6453
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I~~ ;- ., G~'COpltal Mortgage
~.. ~~Mces, Inc.
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" . ......J... Creelman
. .-- ~ : 'Frank federm8!1
~l~~q~eJ ?.t:i.~_~I~ ~_.:
. .ip, Cumberland c;ounty, ,
, <m ..o,_de'li!iiJ!lj ,
,t. ,iiiij& ~Yi1lom" net.-
guSlJ3.I~Jo. as follows: _
.IJEGlNNING ~at a MIl on the Northern side of
~r.ane. oidlii_~vidin.&..line between Lots
,][os. !9 aod 20 on the he.reinafter mentioned Plan
...oILofs..said point also being 589.24 feet West of
~'fh..._ 'Y~Aibti>i-way lice of L.R. #'21008;
:'rgENt.:?illq ihf Nqrtbem skk of Shirle,y.Lane
~49minu.~50~ndsWest 100
~poinl at: the diViding [me ~tween Lots _
~JB..and 19 on said plan; TIIENCE aloug last
~onh21 degrees IOminu", lO""",ds
,_,.:)10 .f<ct- ill a point, THENCE by llie
~iDe.betweenLotsNos,19and31onsaid ,
filiii North 68 degrees 49 minutes SO seconds East
~JOO-iectto a point; THENCE by the dividing line
t-OOfW~-----r.o.ts N~, 19.and 20 afop:~aid South 21
- degrees 10 .minutes 10 seconds East 120 feet 10 a
'JlOint, thel'!aceofBEGlNNlNG.
=tEINOl:orWo:19 on-'he Plan of Lcts known ~
;:gmon~ls as~OJ:ded in Plan Book 11. Page
~;.,""'-"-.
~G .erected thereon.. a masonry and
~i:IfusiainirahchhouSe. .
'BElIC PART OF TIlE SAME PREMISES
, W!lItltll<ly D. Go"hall aDd Pearl W, Gotshall,
? bi> wJk.bJ 1l<ed dated Moy 22, 1964 aDd
~C;UlJl\!erla~.County. in Deed,Book F,
:-VOl.. ~(Paie' 336. ~veyed unto Oifforo L.
l1.H"""''' ",d Etbel E. Hei>hman. Iili wif" AND
-'beiligthe uodivided one+haIf interfst in and to the
~~).re~ which Clifford L., Heishman and
. wJk. bl( D,ed diol<II No". I,
J967 and recotded in Cumberland County in
: ~.Rook .O~ Volume 22, p."ie 279 COI!-ve)'cd
~-:WIil1iim~. WettaodLoaA. Wert,1ili wif,.
; l.'JrnMISES: 12 Shwy Ume.
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FEDERMAN AND PHELAN LLP
,
By: FRAJiKFEDERMAN,ESQUIRE
IDENTIFICATION NO. 12248
ONE PENN CENTER PLAZA, SUITE 1400
PHILADELPHIA, PA 19103
(11,) ,"1-7000
ATTORNEY FOR PLAINTIFF
COURT OF COMMON PLEAS
CIVIL DIVISION
GE CAPITAL MORTGAGE SERVICES, INC.
5024 P ARKW A Y PLAZA BOULEVARD
BUILDING 7/F/C
CHARLOTTE, NC 28217-2407
Plaintiff
TERM
NO. CI- t..l/~ Ciu-(C- l€IL"'l
CUMBERLAND COUNTY
v.
SARA JANE CREELMAN
12 SHIRLEY LANE
BOILING SPRlNGS, P A 17007
Defendant( s)
CTVIT. ACTION - LAW
rOMPI.A TNT TN MORTQAQR FORF.n .OSTTRR
NOTTCR
**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 warned 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 THIS PAPER TO YOUR LAWYER AT ONCE. IF YOU DO NOT
HAVE A LAWYER OR CANNOT AFFORD ONE, GO TO OR TELEPHONE THE OFFICE
SET FORlH 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 #: 0022099485/KXM
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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.
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1. Plaintiff is
GE CAPITAL MORTGAGE SERVICES, INC.
5024 P ARKW A Y PLAZA BOULEVARD
BUILDING 7/F/C
CHARLOTTE, NC 28217-2407
2. The name(s) and last !mown addressees) of the Defendant(s) are:
SARA JANE CREELMAN
12 SHIRLEY LANE
BOILING SPRINGS, P A 17007
who is the mortgagor and real owner of the property hereinafter described.
3. On 06/30/98, mortgagor, SARA JANE CREELMAN, made, executed and delivered a
mortgage upon the premises hereinafter described to HOMEGOLD, INC. which
mortgage is recorded in the Office of the Recorder of CUMBERLAND County, in
Mortgage Book No. 1465, Page 388. By Assignment of Mortgage recorded 05/19/99, the
mortgage was assigned to PLAINTIFF which Assignment is recorded in Assignment of
Mortgage Book No. 613, Page 350.
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 07/06/01 and each month thereafter are due and unpaid, and by the tenns
of said mortgage, upon default in such payments for a period of one month, the entire
principal balance and all interest due thereon are collectible forthwith.
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6. The following amounts are due on the mortgage:
Principal Balance
Interest
06/06/01 through 10/06/01
(per Diem $13.47)
Attorney's Fees
Cumulative Late Charges
06/30/98 to 10/06/01
Cost of Suit and Title Search
Subtotal
$51,099,06
1,656.8/
1,000.00
89.04
55iLOQ
$54,394.91
Escrow
Credit
Deficit
Subtotal
0.00
4,700 70
~4 700 70
.
TOTAL
$58,595,1 1
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
Sheriff's 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 Temporary Stay as provided by the Homeowner's Emergency Mortgage Assistance
Program, Act 91 of 1983, has terminated because 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".
10. By virtue of the death of ARTHUR N. CREELMAN on 03/25/93, SARA JANE
CREELMAN became the sole owner of the mortgaged premises as surviving tenant by
the entireties.
WHEREFORE, PLAlNTIFF demands an in = Judgment against the Defendant(s) in the sum of
$58,595.11, together with interest from 10/06/01 at the rate of $13.47 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,
:r~ ~dL..-
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FRANK FEDERMAN, ESQUIRE
Attorney for Plaintiff
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P.O. Box 1225
Chari one, NC 28201-1225
September 10, 2001
Sara Jane Creelman
12 Shirley Ln.
Boiling Springs PA 17007
0022099<l8S/0Q1035/936ActS!1
RE: Wells Fargo Home Mortgage, Inc. Loan Number 0022099485
Mortgagor(s):
Mortgaged Premises:
Sara Jane Creelman
12 Snidey Ln.
Boiling Spr, PA 17007
ACT 91 NOTICE
TAKE ACTION TO SAVE
YOUR HOME FROM
FORECLOSURE
This is an official notice that the mormage on your home is.in default. and the lender intends to
foreclose. Specific information about the nature of the default is proyided in the attached pages.
The HOMEOWNER'S MORTGAGE ASSISTANCE PROGRAM (HEMAl') may be able to help to
saye your home. This Notice exolains how the program works.
To see if HEMAl' can help, you must MEET WITH A CONSUMER CREDIT
COUNSELING AGENCY WITHIN 30 DAYS OF THE DATE OF THIS NOTICE. Take this Notice
with YOU when yOU meet with the Counseling Agency.
The name, address and phone number of Consumer Credit Counseling Agencies serving your
County are listed at the end of this Notice. If you have any Questions, vou may call the Pennsylvania
Housing Finance Agencv toll free at 1-800-342-2397. (Persons with impaired hearing can call
(717) 780-1869).
This Notice contains important legal information. If you have any questions, representatives
at the Consumer Credit Counseling Agency may be able to help explain it. You may also want to
contact an attorney in your area. The local bar association may be able to help you find a lawyer.
LA NOTIFICACION EN ADJUNTO ES DE SUMA IMpORTANCIA, pUES AFECTA SU DERECHO
A CONTINUAR VIVIENDO EN SU CASA. SI NO COMpRENDE EL CONTENDO DE ESTA
NOTIFICACION OBTENGA UNA TRADUCCION INMEDITAMENTE LLAMANDO ESTA
AGENCIA (PENNSYLVANIA HOUSING FINANCE AGENCY) SIN CARGOS AL NUMERO
MENCIONADO ARRIBA. pUEDES SER ELEGIBLE PARA UN pRESTAMO pOR EL PROGRAMA
LLAMADO "HOMEOWNER'S EMERGENCY MORTGAGE ASSISTANCE PROGRAM" EL CUAL
l'UEDE SAL V AR SU CASA DE LA PERDIDA DEL DERECHO A REDlMlR SU Hil'OTECA.
EXHIBlT A
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HOMEOWNER'S NA1\1E(S):
Sara Jane Creelman
PROPERTY ADDRESS:
12 Shirley T.n
Bailin!! Spr, pA 17007
0022099485
LOAN ACCT. NO.:
ORIGINAL LENDER:
CURRENT LENDER/SERVICER:
WELLS FARGO HOME MORTGAGE, INC.
HOMEOWNER'S EMERGENCY MORTGAGE ASSISTANCE PROGRAM
YOU MAY BE ELIGIBLE FOR FINANCIAL ASSISTANCE
WHICH CAN SAVE YOUR HOME FROM FORECLOSURE AND
HELP YOU MAKE FUTURE MORTGAGE PAYMENTS
IF YOU COMPLY WITH THE PROVISIONS OF THE HOMEOWNER'S EMERGENCY
MORTGAGE ASSISTANCE ACT OF 1983 (THE" ACT"), YOU MAYBE ELIGIBLE FOR EMERGENCY
MORTGAGE ASSISTANCE:
. IF YOUR DEFAULT HAS BEEN CAUSED BY CIRCUMSTANCES BEYOND YOUR CONTROL.
. IF YOU HAVE A REASONABLE PROSPECT OF BEING ABLE TO PAY YOUR MORTGAGE
PAYMENTS, AND
. IF YOU MEET OTHER ELIGIBILITY REQUIREMENTS ESTABLISHED BY THE PENNSYLVANIA
HOUSING FINANCE AGENCY. .
TEMp~RARY STAY OF FOREfoLOSURE - Under the Act, you are entitled to a temporary stay
of foree osure on your mortgage or lhit1}' (30) days from lhe date of this Notice. Durmg that time
you must arrange and attend a "face-to-face" meetin~th one of the consumer credit counscli~
a!!encies listed at the end of this Notice. THIS MER G MT 1ST ocn JR WITHIN THE NE T
~Oj DAYS. 11' YOU DO NOT APPLY fOR EMERGENCY ,tlORTGAGE ASSIST ANCK YOU
{ ST BRING YOUR MORTGAGF UP TO DATE THE P T OF THIS N<JTICF CAI I FD
"HOW TO CORE YOllR MORTC;AGE DEFAlIl T" EXPI.AINS HOW TO I-lRIN(; YOllR
MORTGAGE UP TO DATE.
CONSUMER CREDIT COlJNSELl~f AGENCIE~ -- If you meet with one of the consumer credit
counseling agencies listed at the end 0 this notice, t e lender may NOT take action against you
for thirty (30) davs after the date of this meeting. The names addre ses and tele hone numbers
f de i nated on' m r r di c I nselin a Ie t n in w ic t r is
. . I is on y neeessary to sc e ule one ace-to-face
meeting. Advise your lender immediately of your intentions.
APPLT~All0N FOR MORTGA~E ASSISTAN~E -- Your mortgage is in default for the reasons
set fort later in this Notice (see fo lowing pages or specific information about the nature of your
default.) If you have tried and are unable to resolve this problem with the lender, you have die
right to apJl.ly for financial assistance from the Homeowner's Emergency Mortgage Assistance
Program. To do so, you must fill out, sign and file a comQleted Homeowner's Emergency
ASSIstance Program Application with one of the designatea consumer credit counseling agencies
listed at the end of this Notice. Only consmner credIt counseling agencies have applicationsfor
the p~ogra!TI and they will assist you in s~bmittinza cOl?plete apphcation to ~he. Pen!lsy]vama
Housmg Fmance Agency . Your apphcatlon MUST be flied or postmarked wlthm thirty (30) days
of your face-to-face meeting.
YOU MllSI FILE YOUR ApPLICA nON PROMPTLY. IF YOU FAIL TO DO SO OR IF YOU
DO NOT FOLLOW THE OTHER TIME PERIODS SET FORTH IN THIS LETTER, FORECLOSURE
MAY PROCEED AGAINST YOUR HOME IMMEDIA TEL Y AND YOUR ApPLICA nON FOR
MORTGAGE ASSISTANCE WILL BE DENIED.
EXll-IIRI,j .'i
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001035/936
AG~~CY A~TT~N -- Available funds for e,!,ergency' mortgage assistance are very limited. They will
be d]s. urs~d y t e Agency un~er the elIgibilIty cntena est~qhshed by the Act. The Pennsylvania
Ho~sl11g FI11<l;nce Agency lias sIxty (60) days to make a deCISIOn after It receIves your applIcation.
Durmg that nme, no foreclosure proceedings will be pursued against you if you have met the time
requIrements set forth ahove. You will he notified directly hy the Pennsylvania Housing Finance
Agency of its decision on your application.
NOTE: IF YOU ARE CURRENTLY PROTECTED BY THE FILING OF A PETITION
IN BANKRUPTCY" .1lIE FOLLOWING PART OF THIS NOTICE IS FOR INFORMA TION
PURPOSES OI'lL Y AND SHOULD NOT BE CONSIDERED AS AN ATTEMPT
TO COLLECT THE DEBT.
(If you have filed bankruptcy you can still apply for Emergency Mortgage Assistance.)
HOW TO CURE YOUR MORTGAGE DEFAULT (Bring it up to date).
NATTTRF OF THE DFFAIJI T - - The MORTGAGE debt held by the above lender on your property
located at: 1 J Shirley Tn'
IS SERIOUSr~lif;f tljffAt2fO~:ca use:
A. YOU HAVE NOT MADE MONTHLY MORTGAGE PAYMENTS for the following months and
the following amounts are now past due:
Jnly J001 - Septemher J001 $~ o,~ R,
Other charl(es (explain/itemize\:
Drhpr :8:e." (if ::Ipplir::lh1e\
TOTAL AMOUNT PAST DUE:
B. YOU HAVE FAILED TO TAKE THE FOLLOWING ACTION
Late Charges
$0.00
$000
$2.463.34
~OWT~ CURE THE DEFA8fT - - You may cure the default within THIRTY (30) DAYS of the
ate of t is notice BY PATIN HE TOTAL AMOUNT PAST DUE TO THE LENDER WHICH
IS $ 2,463.34 PLUS ANY MORTGAGE PAYMENTS AND LATE CHARGES WHICH BEcOME
DUE DURiNG THE THIRTY (30) DAY PERIOD.. paJments must be made either bv cash. cashier's
check, certified check or money order made payable an sent to:
WELLS FARGO HOME MORTGAGE, INe.
1 HOME CAMPUS
X2501-01H
DES MOINES, IOWA 50328
You can cure any other default by taking the following action within THIRTY (30) DAYS of the date
of this letter:
IF YOU DO NOT CU E DE AUL T - -If you do not cure the default within THIRTY (30) DAYS
o t e ate 0 t is Notice, teen er mt exercise its ri hts to accelerate the mort a e debt. This
means that the entire out.tan mg a ance 0 t IS e t WI e consl ere ue Imme late y an you may
lose the chance to pay the mortgage in monthly installments. If full payment of the total amount past
due is not made wlthm THIRTY (30) DAYS, the lender also intends to instruct its attorneys to start
legal action to foreclose upon vour mortl!al!ed property.
IF THE M~RTGAGE I~ FORECL~SED lJ~N - - The mortgaged proper\}' will be sold by the Sheriff
to pay otf t e mortgage ebt. It the ender re ers your case to Its attorneys, out you cure the delinquency
before the lender begins legal woceedings againstyoubyou will still be required to pay the reasonable
attornev's fees that were actually incurred, up to $50. O. However, if legal proceedings are started.
against"you,you will have to pay all reasonable attorney's fees actually incurred hy the lender even If
riley exceed $50.00. Any attorney's fees will be added to the ~~ount jlou owe the lender, whl~h may
also include other reasonable costs. if vou cure the default wlthm the THIRTY (30l DA Y penod. vou
will not be required to pav attornev's tees.
OTHFR T F~FR RFMFDTES - - The lender may also sue you personally for the unpaid principal
balance and al other sums due under the mortgage.
EXHIBIT A
."J;'
001035/936
RIGHT TO CURE THE DEFAULT PRIOR TO SHERIFF'S SALE -- If YOll have nor cured the def,wlt
wIthm the THIRTY (30) DAY period and foreclosure proceedings have begun, vou still have the right
I r v h I n i h r f r h h riff' I Y v
do so h' a 'in the total amount then asl ue Ius an lale or other char es then due reasonahle
attornev's ees and costs connecte wit the oreclosure sa e an anv ot er costs connected with the
Sheriff's Sale as s ecified in writin b the lender and b erlormin an other re uirements under the
mortgage. Curin\\ your de au I in t e manner sel or in t . s notice wi restore your mortgage to I e
same position as If you had never defaulted.
FARI.TFST POSSTRT F SHFRIFF'S SAT I' DATI' -- Ir is estimared that the earliest date thar such a
Sheriff's Sale of rhe mortgaged property could be held would be approximarely six (6) months from
the date of this Notice. A notice of the actual date of the Sheriff's Sale will be sent to you before the
sale. Of co~se, the amount needed to cure rhe default will inc;ease the longer you wait. You may find
out at any tIme exactly what the reqUIred payment or actIon WIll he hy contacting the lender.
HOW TO CONTACT THF T FNDFR.
Name of Lender:
Address:
Wells Fargo Home, Mortgage, Inc.
5024 Parkway Plaza Blvd.
Charlone, NC 28217
1-800-766-0987
704-423-4016
T anisha Robinson
Phone Number:
Fax Number:
Contact Person:
EFFECT OF SHERIFF'S SALE -- You should realize that a Sheriff's Sale will end your ownership of
the mortgaged property and your right to occupy it. If you continue to live in the propelty 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 -- You _ mayor _ may not sell or transfer your home to
a buyer or Iransferee who will assume the 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 SELL THE PROPERTY TO OBTAIN MONEY TO PAYOFF THE MORTGAGE DEBT
OR TO BORROW MONEY FROM ANOTHER LENDING INSTITUTION TO PAY OFF
THIS DEBT.
. TO HAVE THIS DEFAULT CURED BY ANY THIRD PARTY ACTING ON YOUR BEHALF.
. TO HAVE THE MORTGAGE RESTORED TO THE SAME POSITION AS lFNO DEFAULT
HAD OCCURRED IF YOU CURE THE DEFAULT. (HOWEVER YOU DO NOT HAVE
THIS RlGHT TO (~URE YOUR DEFAULT MORE THAN THREE TlMES IN ANY
CALENDAR YEAR.)
. TO ASSERT THE NONEXISTENCE OF A DEF AUL T IN ANY FORECLOSURE
PROCEEDING OR ANY OTHER LAWSUIT INSTITUTED UNDER THE MORTGAGE
DOCUMENTS.
. TO ASSERT ANY OTHER DEFENSE YOU BELIEVE YOU MAY HAVE TO SUCH
ACTION BY THE LENDER.
. TO SEEK PROTECTION UNDER THE FEDERAL BANKRUPTCY LAW.
EY~\'3!T A
PE:"iNSYL V ..L'IIA HOUSING F1N..L'ICE AGE:"iCY
HOMEOWNER'S E.."\1ERGEI'ICY ASSISTAJ.'lfCE PROGR.UI
CONSUMER CREDIT COUNSELING AGE:'ICIES
(REV. 8100)
PERRY COt"NTY
ceo "nVdt::."'n ?::r,ns:(v;:mi:1., [nc,
2000 linglcstown Read
H:1rtisburg. PA 17102
(717) 54]-1'i5i F.~'(tiI15oL''''':6i'O
Financ::1 C.J:J.i"seHni S'C"'.:':::::s cf::-~~'l
:H West j" St:::t
W.ynesboro. PA 17:63
(71;') i6:.j23!
U~ ~c of Metropolitan H:ltrisburi
2!O1 ="'orth 6110 S~=t
fbm,burJ, PA 17101 .
(it:') :!J.1..59:S F.J...~ {71:"} :!J.L.9.J.:9
We:u;h~on omc:
9 t --; MifflIn Sr:=:
Huntinldon. PA ! 666;::
(3IJ) 6J}.!:;J}
y\VCA ofCJrlish:
3D l' \J Sue:t
C.:rlislc. PA 170t3
(ii 7) 2.t3..3813 FA...'< (71") :.:13..3943
C.::rr-.munit: .-\c::c" CJtn.-::tssicn ~f
The C.lpic.J.! ;t~cn
Ii I J D....' SL..,.,
H=i.sbuti, PA I; I OJ
C" ~ i)Z;:.g-:- f..~..X '1-; Z;..:.::::-
P1iIL~DEtPHt~ COl"'TY
A.:om HOU:ill'l:1 Carper-lOon
.t...6 ~orth 8ro;;td Sue:::
Phd.1llc:lphl~ P.-\. 191JO
(:[5) 76$..1::1
NoJr..n\lo.,:s: CJu.".:i~J:ni Sc:". :~~
'500 t ~oJr...'" 3l'Q:Id St:~
P~ai:1~:::!;:h:.l. ?,.:.. !<;l::':'~
(FAX 1 :1,', J:J.,-,3
CCCSofDe:::twatl; VJJlc:-
lS I ~ :Vfarket Stm::t, SIJlteD2'
P~il.c.lp~l:1. P....1911l7
(215) 563-5665 ,..\..'<(2\,) 36"-:666
c:-cs of:)~i.J.""':!r: V.ll::;..
Cn~ Ch.:r.:: Hill. SUIte'::" ~
C1~ HiH. ~r 08eO:
t::l!) 563-5665
HACE
t6i Wdt .-\llezhcny Avc::n;t:.::!- N.
P~llodcJp~i:1. P.... 191"0
(:l5j ~:S...sO:~ FA'( ,:~:: ~:'5_o__t::.
Hcusiflf .~scci::1ri"n .J[=e:..:w~ V=.il::y
1500 WJ.!nut Str~L S~ :.)!
P!':.ll~c!;:,h::.. ?; 19~1):
r:r5' ~':'5-1Cl,J F.J.':C_:'::",~:: ~:]:
~{~i~ F~lowS'll1p Hc~e-
30:' Sout.1.1ackson Su-::::
Mcii;I., PA 19063
(6:!}) 56:-08':'6 F..~,X ~6;O' :iJ5-d567
H'c;U:S;:":I..\"U':'::~:c~ J{::::='\\':"~ ....:..:~:
6;3 ~~r"_1. '.V.l["..{ St:~:
?!i:i:lce:ph::l. ?,J", [9::::
PCCA
lOa >icr.h t -;-<II Sue::
SUIte: :WO
.Phl!~elphl.2. P.-\. 191:)]
{2t~ :67.7303 FA.'{I::::)96.3..~9J.l
C,JIr.::lum::. J:e\::! CJt; .::: :-r:!r.....::-.::-.:
Group ~lln:5~-::
.16:0 0nsc.::-~ St:~:
P~:i.~f=i':..t. ?A. ; ~ ::...:-
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.-\menC:::1l1 Credit Coun5eHn... rf1~rirure
3..:5 C~~ Sr:=-t
C-';.J.t::~/_Il:<:.?;. :93:-:
[SS3; :t.:...-;:".q
I":";' :.JSf aex=!b ?1ke
K...~.; jf?:-.:.sSi::1. ?A :9-J.C,
F.-(X(iiTOl ~6:C'~3[.t
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1_i." .:..-:-:;:::~:::~ ?::.. :.t: ~ ~
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PE:'i:'iSYLV......'iL... BI.:LLETL'If. VOL 29. :'i0. 2.3. K:'iE:. lOqO
EXHIBIT A
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"-.'".:".,;."',;, '""'rr~l<".",;
. .. 1 f 1 d . tuli.te in South Middleton .'
i\lt . that certain piece o~ pa~ce ~ ~ ~~d and described in acco~d-
Township, c~rl~d county, penns~iv~J.as ~:ed August 13, 1970 I .as fo+lOws:
ance \olith a sur/ey by Thomas. A. I:le , . . .
. . he side of Shirley Lane on the
. BEGINNING at a point on the Nor~ 2~on the hereinafter mentioned Plan.
.dividing 1i~~ be~ween Lot~ ~oS'si:.~ feet West of the Western right of way.
of Lots, sa~a po~nt ~ls~EN~inilOng the Northern'side of Shirley La~e.S~uth.
line of L. R. 121008. T t 100 feet to a point at the dJ.v~d~ng .
68 dogrees 49 minutes 50 seconds we~aid lan: THENCE along last said line
line bet...~en Lots NOS..lS and l~ on d w~st 120 feet to a point~ THENCE bV
North 21 degrees 10 m~nutes'lO secon s
tlle CU.V:i.ding line betw(!en Lots Nos. 19 and 31 on said plan North 68 degrees
49 minutes 50. seconds East 100 feet to a point; THENCE by the dividing. line
between Lots Nos. 19 and 20 aforesaid So~th 21 degrees 10 minutes 10 seconds
East 120 feet to a point, th~ place Qf BEGINNING. .
BEING Lot No. 19 on the plan of Lots known as Clifton Heights ~s
~ecorded in Plan BOok J.7, Page 59..
HJl.VING erected thereon a masonry and aluminum siding ranch house.
BEING part of the sallie premises which. Roy D. Gotshall.and. Pearl W. .
Gotsball, his wife by Deed dated May 22, 1964 and recorded in' Cumberland
County, in Deed Book F, Vol. 21, Page 336.eonveyed unto Clifford L. 'HeishmaQ.nn
and Ethel E. Heishman,his wife. AND being the undivided one-half interest in
and to the same premises which Clifford L. Heishman and Ethel E., his wife by.
Deed dated November 1, 1967 and recorded in CUl'llbe.r1and County in Deed Book O.
Volume :U, Page 279 conveyed unto William S. Wert and Loi:SA. Wert, his wife.
PREMISES: 12 SHIRLEY LANE
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VERIFICATION
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TAMMY JOHNSON hereby states that she is ASSISTANT VICE PRESIDENT of
WELLS FARGO HOME MORTGAGE, INC. m0l1gage servicing agent for Plaintiff in this malter,
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.
DATE: 11/5(01
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GE CAPITAL MORTGAGE SERVICES, INe.
CUMBERLAND COUNTY
Plaintiff,
v.
COURT OF COMMON PLEAS
SARA JANE C:REELMAN
CIVIL DIVISION
Defendant( s).
NO.01-6453 CIVIL
AMENDED AFFIDAVIT PURSUANT TO RULE 3129
(Affidavit No. I)
GE CAPITAL MORTGAGE SERVICES. INC., Plaintiff in tile 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, 12 SHIRLEY LANE,
BOILING SPRINGS. PA 17007.
1. Name and address ofOwner(s) orreputed Owner(s):
Name
Last Known Address (if address cannot be
reasonably ascertained, please indicate)
SARA JANE CREELMAN
12 SHIRLEY LANE
BOILING SPRINGS, P A 17007
2. Name and address ofDefendant(s) in tile judgment:
SARA JANE CREELMAN
12 SHIRLEY LANE
BOILING SPRINGS, P A 17007
3. Name and last known address of every judgment creditor whose judgment is a record lien on tile real
property to be sold:
Name
Last Known Address (if address cannot be
reasonably ascertained, please indicate)
None.
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4. Name and address oflast recorded holder of every mortgage ofrecord:
PNC BANK NATIONAL ASSOCIATION
CITIFINANCIAL INC.
2730 LIBERTY AVENUE
pmSBURGH, PA 15222
5520 CARLISLE PIKE, SUITE 155
MECHANICSBURG, P A 17055
5. Name and address of every other person who has any record lien on the property:
None.
Last Known Address (if address cannot be
reasonably ascertained, please indicate)
6. Name and address of every other person who has any record interest in the property and whose
interest may be affected by the sale.
Name
COMMONWEALTH OF PENNSYLVANIA
BUREAU OF INDNIDUAL TAX
INHERITANCE TAXDNISION
ATTENTION: JOHN MURPHY
INTERNAL REVENUE SERVICE
FEDERATED INVESTORS
TOWER
DEPARTMENT OF PUBLIC WELFARE TPL
CASUALTY UNIT ESTATE RECOVERY
PROGRAM
Last Known Address (if address cannot be
reasonably ascertained, please indicate)
6TH FLOOR, STRAWBERRY SQUARE
DEPT. 280601
HARRISBURG,PA 17128
13TH FLOOR, SUITE 1300
1001 LIBERTY AVENUE
PITTSBURGH, P A 15222
P.O. BOX 8486
WILLOW OAK BUILDING
HARRISBURG, P A 17105-8486
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 fue sale:
Name
Tenant/Occupant
Domestic Relations of Cumberland County
Commonwealth of Pennsylvania
Department of Welfare
Last Known Address (if address cannot be
reasonably ascertained, please indicate)
12 SHIRLEY LANE
BOILING SPRINGS, P A 17007
13 North Hanover Street
Carlisle, P A 17013
PO Box 2675
Harrisburg, PA 17105
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.. I verify tl1at tl1e statements made in this affidavit are true and correct to the best of my personal
knowledge or information and belief. I understand tl1at false statements herein are made subj ect to the
penalties of18 Pa. C.S. Sec. 4904 relating to unsworn falsification to authorities.
Aori119.2002
DATE
/1 AM} ()uJJAnJA ~
FRANK FEDERMAN, ESQUIRE
Attorney for Plaintiff
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IN THE COURT OF COMMON PLEAS OF CUMBERLAND COUNTY,
PENNSYLVANIA
RE: GE CAPITAL MORTGAGE SERVICES, INC.
) CIVIL ACTION
)
vs.
SARA JANE CREELMAN )
)
CIVIL DIVISION
NO. 01-6453 CIVIL
AFFIDAVIT OF SERVICE PURSUANT TO RULE 3129
COMMONWEALTH OF PENNSYLVANIA
COUNTY OF CUMBERLAND
)
)
55:
I, FRANK FEDERMAN, ESQUIRE attorneyforGE CAPITAL
MORTGAGE SERVICES, INC. hereby verify that on 1/16/02 & 4/19/02 true and
correct copies of the Notice of Sheriffs sale were served by certificate of mailing
to the recorded lienholders, and any known interested party see Exhibit "A"
attached hereto. Notice of Sale was sent to the Defendant(s) on 4/19/02 by
certified mail return receipt requested see Exhibit "B" attached hereto.
DATE: Mav 2. 2002
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F K FEDERMAN, ESQUIRE
Attorney for Plaintiff
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SARAJANE GREElMAN
12 SHIRLEY LANE
BOILING SPRINGS, P A 17007
SENDER:
TEAM 5
CREELMAN, SARA JANE
REFERENCE:
PS Fonn 3800 June 2000
RETURN Postage
RECEIPT Ceitified Fee
SERVICE
Retum Receipt Fee
Restricted Delivery
Total Postage & Fees
US Postal Service PQS
Receipt for
Certified Mail
No Insurance Coverage Provided
Do Not Use for International Mail
.
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GE CAPITAL MO:RTGAGE SERVICES, me.
CUMBERLAND COUNTY
Plaintiff,
v.
COURT OF COMMON PLEAS
SARA JANE CREELMAN
CIVIL DIVISION
Defendant(s).
NO.01-6453 CIVIL
AFFIDAVIT PURSUANT TO RULE 3129
(Affidavit No. I)
GE CAPITAL MORTGAGE SERVICES. INC.. Plaintiff in the above action, by its attorney,
FRANK FEDERMAN, ESQUIRE, sets forth as of the date the Praecipe for the Writ of Execution was
filed the following information concerning fue real property located at .12 SHIRLEY LANE.
BOILING SPRINGS. PA 17007 .
Name
Last Known Address (if address camlOt be
reasonably ascertained, please indicate)
1. Name and address of Owuer(s) orreputed Owner(s):
SARA JANE CREELMAN
12 SHIRLEY LANE
BOILING SPRINGS, P A 17007
2. Name and address ofDefendant(s) in the judgment:
SARA JANE CREELMAN
12 SHIRLEY LANE
BOILING SPRINGS, P A 17007
3. Name and last known address of every judgment creditor whose judgment is a record lien on fue real
property to be sold:
Name
Last Known Address (if address cannot be
reasonably ascertained, please indicate)
None.
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4. Name and address oflast recorded holder of every mortgage of record:
PNC BANK NATIONAL ASSOCIATION
2730 LffiERTY AVENUE
PITTSBURG, PA 15222
None.
5. Name and address of every oilier person who has any record lien on ilie property:
Last Known Address (if address Ca1illot be
reasonably ascertained, please indicate)
None.
6. Name and address of every oilier person who has any record interest in the property and whose
interest may be affected by the sale.
Name
Last Known Address (if address Ca1illot be
reasonably ascertained, please indicate)
None.
7. Name and address of every oilier person of whom ilie plaintiff has Imowledge who has any interest in
ilie property which may be affected by the sale:
Name
Last Known Address (if address Ca1illot be
reasonably ascertained, please indicate)
Tenant/Occupant
12 SHIRLEY LANE
BOILING SPRINGS, P A 17007
Domestic Relations of Cumberland County
13 North Hanover Street
Carlisle, P A 17013
CommonwealthofPenns~vania
Department of Welfare
PO Box 2675
Harrisburg, PA 17105
I verify that ilie statements made in this affidavit are true and correct to the best of my personal
Imowledge or information and belief. I understand iliat false statements herein are made subject to ilie
penalties ofl8 Pa. C.S. Sec. 4904 relating to unsworn falsification to auiliorities.
January 15. 2002
DATE
~~~
FRANK FEDE ,SQUIRE
Attorney for Plaintiff
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FEDERMAN and PHELAN
By: FRANK FEDERMAN
Identification No. 12248
ONE PENN CENTER AT SUBURBAN STATION
1617 JOHN F. KENNEDY BLVD., SUITE 1400
PHILADELPHIA, P A 19103-1814
(215) 563-7000
ATTORNEY FOR PLAINTIFF
GE CAPITAL MORTGAGE SERVICES, INC.
Plaintiff,
CUMBERLAND COUNTY
COURT OF COMMON PLEAS
v.
CIVIL DMSION
SARA JANE CREELMAN
NO. 01-6453 CML
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.
'4~/ 11 ,
FRANK FEDERMAN, ESQUIRE
Attorney for Plaintiff
~
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
PHILADELPHIA, PA 19103-1814
(215) 563-7000
....,
GE CAPITAL MORTGAGE SERVICES, INC.
5024 PARKWAY PLAZA BOULEVARD
BUILDING 7!FIC
CHARLOTTE, NC 28217-2407
CUMBERLAND COUNTY
COURT OF COMMON PLEAS
CIVIL DIVISION
Plaintiff,
v.
NO. 01-6453 CIVIL
SARA JANE CREELMAN
Defendant(s).
PRAEC~EFORJUDGMENTFORFMLURETO
ANSWER AND ASSESSMENT OF DAMAGES
TO THE PROTHONOTARY:
Kindly enter judgment in favor of the Plaintiff and against SARA JANE CREELMAN and.
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 01116/02 to 06/05/02
TOTAL
$58,595.11
$1373.94
$59,969.05
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.
~~U~QUIRE
Attorney for Plaintiff
DAMAGES ARE HEREBY ASSESSED AS lNDICAa
DATE:~h ') I~ ;;too^,-- .. /? i:;; 'J '2
PRO PROTHY
-
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(Rule of Civil Procedure No. 236) - Revised
IN THE COURT OF COMMON PLEAS OF CUMBERLAND COUNTY, PENNSYLVANIA
CIVIL ACTION - LAW
GE CAPITAL MORTGAGE SERVICES, INe.
5024 PARKWAY PLAZA BOULEVARD
BUILDING 7/F/C
CUMBERLAND COUNTY
COURT OF COMMON PLEAS
CIVIL DIVISION
Plaintiff,
v.
NO. 01-6453 CIVIL
SARA JANE CREELMAN
Defendant(s).
Notice is given that a JudgnIent in the above-captioned matter has been entered against you on
J~17
200a...
B,ji;
4()--,p_2-7{~
DEPUTY
If you have any questions concerning this matter, please contact:
FRANK FEDERMAN. ESOUlRE
Attorney for Plaintiff
ONE PENN CENTER AT SUBURBAN STATION
1617 JOHN F. KENNEDY BL YD., SUITE 1400
PHILADELPHIA, PA 19103-1814
(215) 563-7000
"THIS FIRM IS A DEBT COLLECTOR ATTEMPTING TO COLLECT A DEBT AND ANY INFORMATION
OBTAINED WILL BE USED FOR THAT PURPOSE. IF YOU 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 AGAINST PROPERTY."
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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
GE CAPITAL MORTGAGE SERVICES,
INC.
Plaintiff
CIVIL DIVISION
CUMBERLAND COUNTY
vs.
NO. 01-6453 CIVIL
SARA JANE CREELMAN
Defendant(s)
TO: SARA JANE CREELMAN
12 SHIRLEY LANE
BOILING SPRINGS,PA 17007
DATE OF NOTICE: DECEMBER 18. 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 LIBERTY AVENUE
CARLISLE,PA 17013
(717) 249-3166
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Frank Fed rman,~quire
Attorney for Plaintiff
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FEDERMAN and PHELAN
By: FRANK FEDERMAN
Identification No. 12248 ATTORNEY FOR PLAINTIFF
ONE PENN CENTER AT SUBURBAN STATION
1617 JOHN F. KENNEDY BLVD., SUITE 1400
PHILADELPHIA, PA 19103-1814
(215) 563-7000
GE CAPITAL MORTGAGE SERVICES, INC.
5024 PARKWAY PLAZA BOULEVARD
BUILDING 7/F/C
CUMBERLAND COUNTY
COURT OF COMMON PLEAS
CIVIL DIVISION
Plaintiff,
v.
NO. 01-6453 CIVIL
SARA JANE CREELMAN
Defendant(s).
VERIFICATION OF NON-MILITARY SERVICE
FRANK. FEDERMAN, ESQUIRE, hereby verifies that he is attorney for the Plaintiff in
fue above-captioned matter, and that on information and belief, he has knowledge offue following facts,
to wit;
(a) fuat the defendant(s) is/are not in the Military or Naval Service offue United States
or its Allies, or ofuerwise witlUn the provisions of the Soldiers' and Sailors' Civil Relief Act of Congress
of 1940, as amended.
(b) fuat defendant SARA JANE CREELMAN is over 18 years of age and resides at ,
12 SHIRLEY LANE, BOILING SPRINGS, P A 17007 .
(c) fuat defendant is over 18 years of age, and resides at , , .
This statement is made subject to fue penalties of 18 Pa. C.S. Section 4904 relating to
unsworn falsification to authorities.
1~ 11 /
FRANK. FE ERMAN, ESQUlRE
Attorney for Plaintiff
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GE CAPITAL MORTGAGE SERVICES, INC.
Plaintiff,
CUMBERLAND COUNTY
v.
No. 01-6453 CIVIL
SARA JANE CREELMAN
Defendant(s).
January 15, 2002
TO: SARA JANE CREELMAN
12 SHIRLEY LANE
BOILING SPRINGS, PA 17007
"THIS FIRM IS A DEBT COLLECTOR A TTEMPTING TO COLLECT A DEBT AND ANY INFORMATION
OBTAINED WILL BE USED FOR THAT PURPOSE. IF YOU HA VE 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 .12 SHIRLEY LANE. BOILING SPRINGS. PA 17007. is
scheduled to be sold at the Sheriffs Sale on JUNE 5. 2002 at 10:00 a.m. in the Cumberland County
Courthouse, South Hanover Street, Carlisle, P A 17013, to enforce the court judgment of 59.969.05
obtained by GE CAPITAL MORTGAGE SERVICES. INC. (the mortgagee) against you. If the
Sheriff s sale is postponed, the property will be relisted for the Sheriffs 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 actiou:
1. The sale will be cancelled if you pay to the mortgagee the back payments, late charges,
costs and reasonable attorney's fees due. To find out how much you must pay, you may
call: (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, th::: more ChJl,C~
you will have of stopping the sale. (See notice on page two on how to obtain an attorney.)
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YOU MAY STILL BE ABLE TO SAVE YOUR PROPERTY AND YOU HAVE OTHER
RIGHTS EVEN IF THE SHERIFF'S SALE DOES TAKE PLACE.
1. If the Sheriffs Sale is not stopped, your property will be sold to fue highest bidder. You may
find out the price bid by calling (215) 563-7000.
2. You may be able to petition fue 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 fue 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 fue money which was paid for your house. A schedule of
distribution offue money bid for your house will be filed by the Sheriffwifuin 30 days of the sale. This
schedule will state who will be receiving that money. The money will be paid out in accordance wifu
this schedule unless exceptions (reasons why the proposed distribution is wrong) are filed wifu fue
Sheriff within ten (10) days after fue 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
ALA WYER OR CANNOT AFFORD ONE, GO TO OR TELEPHONE THE OFFICE LISTED
BELOW TO FIND OUT WHERE YOU CAN GET LEGAL HELP.
CUMBERLAND COUNTY ATTORNEY REFERRAL
CUMBERLAND COUNTY BAR ASSOCIATION
2 LIBERTY AVENUE
CUMBERLAND COUNTY COURTHOUSE
CARLISLE, PA 17013
(71 7) 249-3166
(800) 990-9108
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that certai~ piece
C1J..~'"'erla..::ld COU.:1ty,
a survey I:>y Thomas
. So' . / -a-e On -~e
.- ~ not- 0"" the No:rthe~ side 0: ."l:.r..Lt2: <.J... .~ ....... -1
llEGINNI:-lG a~ a po~ ~:. 19 and 20 on the herei:J.a:ter ment.:.oned ..~a::'l
dividing li~~be~w:en Lot~ ~os'S39.24 feet West 0: the Westa~ r.ight ~f w~y
of Lots, sa.:.d po~n~ ~lS~~N~~n~lOng the Northern side of Shirley ~~~e.~?~~.
Hr\<a of L. R. ;2100a, TS'O-' d Wes- 100 "eo- to a "'oint at t.~e c::.'I~d~ng
49 mi U~es flecon s ~ - -~... '.'d l'
~8 degrees n ~ 9 on said plan: THEllC::: along l~St sa~ _,. :ne
lJ.ne bet'''een Lots No~. .la andl~' cands West 120 f~et to a pnnt.~ T:!.:..iCZ bV
North 21 degrees 10 m~nutes se
All
Township,
ance with
1 . l~~~ ~~tua~~ ;~ Sou~~ Micc:et~n
o~ pa-c~ 0... ......I.,O,~... _"" -.... _
p;nns~l;~'ia, bo~,ded and desc~ibed in accc:~-
.. ~ S d t d Au~ust 13, 197~, as fc~lc.3:
A. Mei:~, "-. . a e ,
~~e ~~VJ.ding line between Lots Nos. 19 and 31 on said plan North 63 degrees
49 minutes 50. seconds East 100 feet to a point; THZNCE by ~~e dividing line
between Lots Nos, 19 and 20 aforesaid South 21 degrees 10 mL.utes 10 seconds
East 120 feet to a ?Oi~t, ~,~ place of BEGINNING.
B~I~G Lot No. ~9 on the Plan of Lots ~'own as Clifton Heights ~s
recorded in Plan Book 17, Pa.ge 59.,
!lAVING erected ~'lereon a masonry and alumi."'l\l:n sidi.,S" ra..ch hou.se.
BEING part of the same premises whi~'l ~oy D. Gotshall and Pearl W.
Gotshall, his wife by Deed dated May 22, 1964 and recorded in 'C~~erland
County, in Deed Book r, Vol. 21, Page 336. conveyed ~,to Clifford L. 'Heis~ ~
and Ethel S. Heishman,his wife. &~o being ~'e undivided one-half interest in
and to ~'le s~~ premises ,which Clifford L. Heishman and E~'lel E., his wife by
Oeed da~ed November 1, 1967 and recorded in C~~erland County ~ Deed Book 0,
Volume 22, Page 279 conveyed tulto William s. liert and Lois A. Wert, his wife.
PREMISES: 12 SHIRLEY LANE
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PRAECIPE FOR WRIT OF EXECUTION - (MORTGAGE FORECLOSURE)
P.R.C.P. 3180-3183
GE CAPITAL MORTGAGE SERVICES, INe.
Plaintiff,
v.
No. 01-6453 CIVIL
SARA JANE CREELMAN
Defendant(s).
TO THE DIRECTOR OF THE OFFICE OF THE PROTHONOTARY:
Issue writ of execution in the above matter:
Amount Due
$59,969.05
Interest from 01/15/02 to 06/05/02
(per diem -9.86)
$1,390.26 and Costs
TOTAL
$61,359.31
4~~J .
FRANK FEDERMAN, E~
One Penn Center at Suburban Station
1617 John F. Kennedy Boulevard, Suite 1400
Philadelphia, PA 19103-1814
Attorney for Plaintiff
Note: Please attach description of property. No.
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~ areel of l~~d situate in South M~ddleton_
~ll that certain piece ~;~sYlvania, bo~,ded and described 1n ~ccora-
Township, Cumberland County, N ff R S dated August 13, 1970, as follows:
ance ~ith a survey hy Thomas,A. e . . ,
, them side of Shirley Lane on tile
. 3EGINNING at a point on the9N~d 20 on the herei~after mentioned Plan
.dividing li~e be~w:en Lots ~os'5~9,24 feet West of the Western right of way
of Lot,., sil:l.d pO:l.n~ also be~ng 1" the Northern side of Shirley La~e. S,?uth
line of L. R. 121008; THENC~ a on~ t 100 feet to a point at the d:l.v:l.d:l.ng
68 dogrees 49 minutes 50 secon~sone:aid plan: THENCE along last said l~ne
line between Lots Nos. .18 and 1, ds West 120 feet to a point~ THENCE bv
North 21 degrees 10 m:l.nutes'10 secon
the CUVi.cl.ing line between Lots Nos. 19 and 31 on said plan North 68 degrees
49 minutes 50. seconds East 100 feet to a point; THENCE by ~'e dividing line
between Lots Nos. 19 and 20 aforesaid South 21 degrees 10 minutes 10 seconds
East 120 feet to a point, ~,c place of BEGINNING.
BEING Lot No. 19 on the Plan of Lots known as Clifton Heights ~s
recorded in Plan Book 17, Page 59,.
/lAVING erected thereon a masonry and alumL,um sidil'l~ ranch house.
BEING part of the Same premises whi~~Roy D. Gotshall and Pearl W.
Gotshall, his wife by Deed dated May 22, 1964 and recorded in 'Cumberland
County, in Deed Book F, Vol. 21, Page 336. conveyed unto Clifford L. . Heishman ~
and Ethel E.' Heis~an,his wife. &~D being ~~e undivided one-half interest in
and to the same premises .which Clifford L. Heishman and Ethel E.. his wife by
Deed dated November 1, 1967 and recorded in Clli~er1and County in Deed Book 0,
Volume 22, Page 279 conveyed unto William s. Wert and Lois A. Wert, his wife.
PREMISES: 12 SHIRLEY LANE
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SHERIFF'S RETURN - REGULAR
CASE NO: 2001-06453 P
COMMONWEALTH OF PENNSYLVANIA:
COUNTY OF CUMBERLAND
GE CAPITAL MORTGAGE SERVICES
VS
CREELMAN SARA JANE
JASON VIORAL
, Sheriff or Deputy Sheriff of
Cumberland County,Pennsylvania, who being duly sworn according to law,
says, the within COMPLAINT - MORT FORE
was served upon
CREELMAN SARA JANE
the
DEFENDANT
, at 2056:00 HOURS, on the 26th day of November, 2001
at 12 SHIRLEY LANE
BOILING SPRINGS, PA 17007
by handing to
SARA CREELMAN
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
18.00
3.25
.00
10.00
.00
31.25
S~~~
R. Thomas Kline
11/28/2001
FEDERMAN & PHELAN
Sworn and Subscribed to before
By:
t!!}t~f
me this
3/)~ day of
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~ a. f'vLJR-t-J. ~
rothonotary ,
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AFFIDAVIT OF SERVICE
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CUMBERLAND COUNTY
PLAINTIFF
GE CAPITAL MORTGAGE SERVICES,
1Ne.
No. 01-6453 CIVIL
DEFENDANT(S)
SARA JANE CREELMAN
ACCT. #0022099485
SERVE SARA JANE CREELMAN AT
12 SIDRLEY LANE
BOILING SPRINGS, PA 17007
Type of Action
- Notice of Sheriff's Sale
Sale Date: JUNE 5, 2002
SERVEIl J I
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Served and made known to O! ~"O u ~ tJ e. I'- , Defendant, on the d- day of d a'l0 . 200.$-.
at 51S"O,0'clock.f2..m.,at /g.. sf" , t<..liV /....I.J, I Gal (;1-.1", 9f(Zi NS5 ,Commonwealth
of Pennsylvania, in the manner described below:
x
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 ofDefendant(s)'s office or usual place of business.
an officer of said Defendant(s)'s company.
Other:
I ./ I bs - 1 '5 SO
Description: Age 5"0 Height seW eight I Jo Race tv k Sex L Other .:; -oS e
I, Gl a~e", t "-- L 1 C'<:\td:j' ~~ompetent adult, being duly sworn according to law, depose and state that I personallyhand"d
a true and correct copy of the Notice of Sheriff s Sale in the manner as set forth herein, issued in the captioned case on the date and at
the address indicated above.
NOTARIAl. SEAl. .
EUlABETH M. JOHANSSON, NoI8ry PubIIo
Greene Twp., Franklin County
11II ,2005
Swom to and subscribed
before me this .#I..@ iioday
of "T~rvv"""J,' 200.1- \?-.1
Nota :J' 1Y\rU~
PLE ATTEMPT SERVICE AT LEAST 3 TIMES. INDICATE
NOT SERVED
On the day of
,200_, at
o'clock _.m., Defendant NOT FOUND because:
Moved Unknown
No Answer
Vacant
Other:
Swom to and subscribed
before me this _ day
of , 200 _'
Notary:
By:
Attornev for Plaintiff
Frank Federman, Esquire - I.D. No. 12248
Oue Penn Center at Suburban Station
1617 John F. Kennedy Boulevard, Suite 1400
Philadelphia,.PA 19103-1814
(215) 563-7000"
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GE Capital Mortgage Services, Inc.
VS
Sara Jane Creelman
In The Court of Common Pleas of
Cumberland County, Pennsylvania
Writ No. 2001-6453 Civil Term
R. Thomas Kline, Sheriff, who being duly sworn according to law, states this writ
is returned STAYED pursuant to instructions from Attorney Frank Feden:nan.
Sheriff's Costs:
Docketing
Surcharge
Law Library
Prothonotary
Mileage
Levy
Advertising
Posting Handbills
Share of Bills
Poundage
Law Joumal
Patriot News
Certified Mail
Postpone Sale
30.00
20.00
.50
1.00
6.90
15.00
15.00
15.00
25.20
14.64
330.50
251.35
1.72
20.00.
$746.81 paid by attorney
09/03/02
Sworn and subscribed to before me
so.~~?<
This Ij~.dayof ~r.~.I... > ~ ~
G R. Thomas Kline, Sheriff
2002, A.D. '1~.A-o. ~ ~ ,I J' f /
. BYvocLL( ructYl
Prothonotary Real Estate Deputy
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GE" CAPITAL MORTGAGE SERVICES, INC.
'.
CUMBERLAND COUNTY
Plaintiff,
v.
COURT OF COMMON PLEAS
SARA JANE CREELMAN
CIVIL DMSION
Defendant(s).
NO. 01-6453 CIVIL
AFFIDAVIT PURSUANT TO RULE 3129
(Affidavit No. I)
GE CAPITAL MORTGAGE SERVICES. INC., Plaintiff in the above action, by its attorney,
FRANK FEDERMAN, ESQUIRE, sets forth as of the date the Praecipe for the Writ of Execution was
filed the following information concerning the real property located at .12 SHIRLEY LANE.
BOILING SPRINGS. PA 17007.
1. Name and address of Owner(s) or reputed Owner(s):
Name
Last Known Address (if address cannot be
reasonably ascertained, please indicate)
SARA JANE CREELMAN
12 SHIRLEY LANE
BOILING SPRINGS, P A 17007
2. Name and address ofDefendant(s) in the judgment:
SARA JANE CREELMAN
12 SHIRLEY LANE
BOILING SPRINGS, P A 17007
3. Name and last known address of every judgment creditor whose judgment is a record lien on the real
property to be sold:
Name
Last Known Address (if address cannot be
reasonably ascertained, please indicate)
None.
~
4. Naro.e and address oflast recorded nolder of every mortgage of record:
PNC BANK NATIONAL ASSOCIA'TlON
2730 LIBERTY AVENUE
PITTS BURG, PA 15222
None.
5. Name and address of every other person who has any record lien on the property:
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
12 SHIRLEY LANE
BOILING SPRINGS, PAl 7001
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 of 18 Pa. C.S. Sec. 4904 relating to unsworn falsification to authorities.
January 15.2002
DATE
~~/~-
FRANKFEDE ,SQUIRE
Attorney for Plaintiff
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oGE CAPITAL MORTGAGE SERVICES, INC.
Plaintiff,
CUMBERLAND COUNTY
v.
No. 01-6453 CIVIL
SARA JANE CREELMAN
Defendant(s).
January 15, 2002
TO: SARAJANECREELMAN
12 SHIRLEY LANE
BOILING SPRINGS, PA 17007
"THIS FIRM IS A DEBT COLLECTOR A1TEMPTING TO COLLECT A DEBT AND ANY INFORMATION
OBTAINED WILL BE USED FOR THAT PURPOSE. IF YOU HA VE PREVIOUSLY RECEIVED A DISCHARGE IN
BANKRUPTCY AND THIS DEBT WAS NOT REAFFIRMED, THIS IS NOT AND SHOULD NOT BE CONSTRUED TO BE
AN A1TEMPT TO COLLECT A DEBT, BUT ONLY ENFORCEMENT OF A LIEN AGAINST PROPERTY ,.
Your house (real estate) at, 12 SHIRLEY LANE, BOILING SPRINGS, PA 17007, is
scheduled to be sold at the Sheriffs Sale on JUNE 5, 2002 at 10:00 a.m. in the Cumberland County
Courthouse, South Hanover Street, Carlisle, P A 17013, to enforce the court judgment of 59,969.05
obtained by GE CAPITAL MORTGAGE SERVICES, INC. (the mortgagee) against you. If the
Sheriff s sale is postponed, the property will be relisted for the Sheriffs Sale.
NOTICE OF OWNER'S RIGHTS
YOU MAY BE ABLE TO PREVENT THIS SHERIFF'S SALE
To prevent this Sheriffs Sale, you must take immediate action:
1. The sale will be cancelled jfyou 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 Ol1e, the mOt; dlJ.nc~
you will have of stopping the sale. (See notice on page two on how to obtain an attorney.)
" ~=~
.-cit,;
YOU MAY STILL BE ABLE TO SAVE YOUR PROPERTY AND YOU HAVE OTHER
RIGHTS EVEN IF THE SHERIFF'S SALE DOES TAKE PLACE.
1. If the Sheriffs Sale is not stopped, your property will be sold to the highest bidder. You may
find out the price bid by calling (215) 563-7000.
2. You 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 ilie owner of ilie
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 ilie 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 ilie sale. This
schedule will state who will be receiving that money. The money will be paid out in accordance wiili
this schedule unless exceptions (reasons why the proposed distribution is wrong) are filed wiili the
Sheriff within ten (10) days after the distribution is filed.
7. You may also have oilier 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
ALA WYER 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 LffiERTY AVENUE
CUMBERLAND COUNTY COURTHOUSE
CARLISLE, P A 17013
(717) 249-3166
(800) 990-9108
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- - 1 o' l~~c s~tuate ~~ OU~. n~~ _ __ .
th. r.'i~ p'ece 0_ pa_ce .... .... d '~ '000---
. a~ ce ~~.. : ,. bo....~ded and d"so~::.~e ~.. _ __
C -"--l>~d Co"~:r Penns'J.....va.."11.a,. ....... _ f "CH..
u.:~.. """"""'" _.t. , II ... R S dat5lld Aug'.1st. 1.J, 1971.1, a~ OJ.. "....
a survey by Tho~~3 A. e_~, w. _
, . ~ int on the ~c:the=n side 0= 5~irle: Lane o~ ~~e
OEGIN.,~llG a. a po . . 19 ar.d 20 on the he=eina:ter mentloned ?lan
dividing li~~ be~w:en Lot~ ~os'5S9 24 fe~t West of the Weste~ ri~ht of w~y
of Lots, s3.~d po~n~ also el.n9"1 'th Nor""ern s;de 0" Shi-l.w !.ane sout.':
Ii f L R i2100a. 'I'H"lICE a ong .e, .u.. - . -- ; .. 'd. ""
ne 0 ... .. -. d W ... 100 feet to a point a~ t~e c;:.v~ ~::-;:l
68 dogrees 49 minuees 50 Gecon s eS~'d 'an' 'I'H"lIC~ a'ong last said line
. L N l> 18 ancl 19 on sa.. p... .~. ~. . _"...... ...
IJ.ne bet',Jeen ots 0.. . ds West 120 fee: to a pol.nt~ TH,;;,......:. ..v
North 21 degrees 10 ml.nutes'lO secco
1\[[
Township,
ance with
:ne alVlding line between Lots Nos. 19 and 31 on said plan North 63 degrees
49 minutes SO. seconds East 100 feet to a point: TMENCE by t.~e dividing line
between Lots Nos. 19 and 20 aforesaid South 21 degrees 10 mL,utes 10 seconds
East 120 feet to a point, t.~c place of BEGINNING.
BEIlIG Lot ~o. 19 on the Plan of Lots ~'own as Clifton Heights ~s
recorded in Plan Book 17, Page 59.,
!L\VING el:ect;ed t.hereon a masonry and alUI:li..,= sidi..,S' ra..ch h01;.5e.
.:
B~ING part of the same premises whi~~ Roy D. Gotshall and Pearl W.
Cotshall, his wife by Deed dated May 22, 1964 and recorded in 'C~~erland
County, in Deed Sook F, Vol. 21, Page 335. conveyed unto Clifford L. 'Heis~ ~
~,d Ethel s. Heishman,his wife. ~~D being ~~e undivided One-half L,terest in
and to the s~s premises which Clifford L. HeiShman and Ethel E., his wife by
Deed dated November 1, 1967 and recorded in Cu:::berland County i:l Deed Book 0,
Volume 22, Page 279 conveyed unto William S. Wert and Lois A. Wert, his wife.
PREMISES: 12 SHIRLEY LANE
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WRIT OF EXECUTION andlor ATTACHMENT
COMMONWEALTH OF PENNSYLVANIA)
COUNTY OF CUMBERLAND)
NO 01-6453 Civil
CIVIL ACTION - LAW
TO THE SHERIFF OF Cumberland COUNTY:
To satisfy the debt, interest and costs due GE CAPITAL MORTGAGE SERVICES, INe.
PLANTIFF(S)
From SARA JANE CREELMAN, 12 SHIRLEY LANE, BOILING SPRINGS, P A 17007
(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 upou in the possession
of
GARNISHEE(S) as follows:
and to notify the gamishee(s) that: (a) an attachment has been issued; (b) the garnishee(s) is 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 $59,969.05 L.L. $.50
Interest FROM 1/15/02 TO 6/5/02 (pER DIEM - 9.86) $1,390.26 AND COSTS
Atty's Cornm % Due Prothy $1.00
Atty Paid $103.25 Other Costs
Plaintiff Paid
Date: JANUARY 17,2002
CURTIS R. LONG
Prothonotary, Civil Division
~
/b;fV>1 p p. 7r;cvzJV.;-: VrtJ
REQUESTING PARTY:
Name FRANK FEDERMAN, ESQUIRE
Address: ONE PENN CENTER AT SUBURBAN STATION
1617 JOHNF. KENNEDY BOULEVARD, SUITE 1400
PHILADELPHIA, PA 19103-1814
Attorney for: PLAINTIFF
Telephone: 215-563-7000
Supreme Court ill No. 12248
TRuE COPY FROM RECORD
If! T~wil&tMf. I 1ler6 !.Into set my hand
i\I"ld me sa.al of saki CllijFt at CarlSla Pa..
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PROOF OF PUBLICATION OF NOTICE
IN CUMBERLAND LAW JOURNAL
(Under Act No. 587, approved May 16, 1929), P. L.1784
STAll!: OF PENNSYL V ANlA
COr"" : ss.
Ul~TY OF CUMBERLAND :
lUld 8 Roger M: Mor.genthal, Esquire, Editor oftl1e Cumberland Law Journal, of the County
La tate afores31d, bemg duly sworn, according to law, deposes and says that the Cumberland
afoW Jo:unal, a legal periodical published in the Borough of Carlisle in the County and State
p~es~d, was established January 2, 1952, and designated by the local courts as the official legal
issQ odiCal for the publication of all legal notices, and has, since January 2, 1952, been regularly
el( ed Weekly in the said County, and that the printed notice or publication attached hereto is
Jo actly the same as was printed.in the regular editions and issues of the said Cumberland Law
,,' Urnal on the following dates
VI;:' ,
"'--
APRIL 26, MAY 3,10,2002
:-
----
----
-----
-----
~
Affiant further deposes that he is authorized to verifY this statement by the Cumberland
:Caw Journal, a legal periodical of general circulation, and that he is not interested in the subject
lQatter of the aforesaid notice or advertisement, and that all allegations in the foregoing
8tatements as to time, place and character of publication are true.
'. . ~ ESTATE SAl:.;E NO.8
Writ No. 2001-6463 Civil
GE~~~~~~~
v..
Sara ane Creelman
Atty.: Fedennan
.ALL that certain .
of" land 't :p~ece or parcel
'")-., S~uatei:nSo th .
-lo.wnship C b U Middleton
:p . urn e~l d C
~nnsylvania b an ounty.
&<:'ribed in ac;' OLl.:nded and de-
""y by Th roan <::e With a sur.
August i;~7~ N"ff. R S. dated
. . ~ follo\VS:
BEGINNiNG
:Northern side of ~~~ point on the
dividing Une be~-- ey Lane on the
. "".... ". <'''V'een Lots Nos. 19
~
SWORN TO AND SUBSCRIBED before me this
10 dayof MAY. 2002
t lid?; SEAL
'LOIS E. SNYDER, NofaIy NlIIG
ClIrIlalb Ilom CumberiIlnd
MY~~lUMllIl:h~
--
. -
f
,
THE PATRIOT NEWS
THE SUNDAY PATRIOT NEWS
Proof of Publication
Under N:J. No. 557, Approved May 16, 1929
Commonwealth of Pennsylvania, County of Dauphin} 55
Frank J. Epler being duly SWorn according to law, deposes and says:
That he is the Controller of The Patriot News Co., a corporation organized and existing under the laws of the
Commonwealth of Pennsylvania. with its principal office and place of business at 812 to 818 Market Street, in the
City of Harrisburg, County of Dauphin, State of Pennsylvania, owner and pubiisher of The Patriot-News and...Ihll
SundRv 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 estabiished 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 andlor Sundayl Metro editions which appeared on the 23rd and 30th day(s) of April 2002 and the
7th day(s} of May 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 pubiicatIon are
true; and
That he has personal knowledge of the tacts aforesaid and is duly authorized and empowered to verify this
statement on behalf of The Patriot-News Co. aforesaid by virtue and pursuant to a resolution unanimously passed and
adopted severally by the stockholders and board of directors of the said Company and subsequently duly recorded in
the office for the Recording of Deeds in and for said County of Dauphin in Miscellaneous Book "M",
Volume 14, Page 317.
TARY PUBLIC
mission expires June 6, 2002
PUBLICATION
COpy
,~id" \1=' All .,
~~JiEAL ESTATE SALE No.8
,~ WrnNo.~l-6453
~ c~...",.. .ClvllTerm .
":--O-""--OE Capital Mort;.g.
i-'!,~~~"~";~,, ~"~':' In~..
~ ,~_:. ->--n-JaneCraehnan
.::c.. .Atty: Frink Fed.rmap
.. .ON .'
cwi. orparcd of land situale in
, Cumberlond Connty. I
Ioun and ,dcscri~ in I
. .iybY_A.Neff,!
'.',. __. AUgwI13. 7.0. as follOW. ':, I
'_.~_INGa1t 't'OnthcNorthemsidcof (
.5.eJU,ane DO the dividing line between Lots tI
.:!tp< 19 .od,O. the hereitulfWr menlloned Plm ,
.!'[Lo!o..uid poitl also being 589.24 feet West pr 1 i
JM,_Westem right~f-way line of L,R. #21008; r I~
1]!EN:CE alOJli '" NortIJ,rn ,id, of Shirley Lon, !;
~o.t:!tI?- ~~grees49 minutes 50 seconds West 100 ,
. feet to 4i point I.llhe dividing tine between Lots J j
}:\~c+8....;J9~..~dplan,THENCEa10Jlija,t Publisher's Receipt for Advertising Cost
.Jiif4llne.North2Idegree:; 10 mmntes 10 seconds I
. West J.211letl. a jlOint;"fI!ENg:.hy ~ IPublisher 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.
Swo
I
Notarial Seal
Teny L RUS$~ll, Notary Pic
Harrisburg, Dauphin County
My COmmIssion ExpiTes June e. 2
Member, Pennsylvania Ass<x:lalion ot 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 publication attached
hereto on the above staled dates
Probating same Notary Fee(s)
Total
$
$
$
249.60
1.75
251.35
By............................__.................._................
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(800) 990-9108
PRAECIPE FOR WRIT OF EXECUTION - (MORTGAGE FORECLOSURE)
P.R.C.P.3180-3183
GE CAPITAL MORTGAGE SERVICES, INC.
Plaintiff,
v.
No. 01-6453 CIVIL
SARA JANE CREELMAN
Defendant(s).
TO THE DIRECTOR OF THE OFFICE OF THE PROTHONOTARY:
Issue writ of execution in the above matter:
Amount Due
Add'l cost
Interest from to DECEMBER 6, 2006
(per diem -$9.86)
$59,969.05
$3,677.00
$01/15/02 TO 12/6/06 and Costs
TOTAL
$17,609.96
"\)~ />~ '
DANIEL G. SCHMIEG, ESQUIRE)
One Penn Center at Suburban Station
1617 John F. Kennedy Boulevard, Suite 1400
Philadelphia, PA 19103-1814
Attorney for Plaintiff
Note: Please attach description of property. No.
IMPORTANT NOTICE: This property is sold at the dire9tion of the
plaintiff. It may not be sold in the absence of "a representative of
the plaintiff at the Sheriff's Sale. The sale must be postponed or
stayed in the event that a representative OI the plaintiff is not
present at the sale.
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'.ALL ::fHAT CERTAIN piece or parcel of land situate in South Middleton Township, Cumberland
County, Pennsylvania, bounded and described in accordance with a survey by Thomas A. Neff, R. S.
dated August 13, 1970, as follows:
BEGINNING at a point on the Northern side of Shirley Lane on the dividing line between Lots Nos.
19 and 20 on the hereinafter mentioned Plan of Lots, said point also being 589.24 feet West of the
Western right of way line of L. R. #21008; thence along the Northern side of Shirley Lane South 68
degrees 49 minutes 50 seconds West 100 feet to a point at the dividing line between Lots Nos. 18 and
19 on said Plan; thence along last said line North 21 degrees 10 minutes 10 seconds West 120 feet to
a point; thence by the dividing line between Lots Nos. 19 and 31 on said Plan North 68 degrees 49
minutes 50 seconds East 100 feet to a point; thence by the dividing line between Lots Nos. 19 and 20
aforesaid South 21 degrees 10 minutes 10 seconds East 120 feet to a point, the place of beginning.
BEING Lot No. 19 on the Plan of Lots known as Clifton Heights as recorded in Plan Book 17, Page
59.
HA VING erected thereon a masonry arid aluminum siding ranch honse.
TITLE TO SAID PREMISES IS VESTED IN Sara Jane Creelman by reason of the following:
BEING THE SAME premises which Clifford L. Heishman and Ethel E. Heishman, his wife an~
William S. Wert and Lois A. Wert, his wife by Deed dated 8/31/1970 and recorded 9115/1970 m
the County of Cumberland in Deed Book Volume 23, Page 385 conveyed unto Arthur N. Creelman
and Sara Jane Creelman, his wife.
AND THE SAID Arthur N. Creelman died on 3/25/93 whereby title to said premises became vested
in Sara Jane Creelman by right of survivorship.
Tax Map #27-1921, Parcel 2
Premises:
12 SHIRLEY LANE, TOWNSHIP OF SOUTH MIDDLETON
CUMBERLAND COUNTY
PENNSYLVANIA
~~"~
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GE CAPITAL MORTGAGE SERVICES, INC.
CUMBERLAND COUNTY
Plaintiff,
v.
COURT OF COMMON PLEAS
SARA JANE CREELMAN
CIVIL DIVISION
Defendant(s).
NO. 01-6453 CIVIL
AFFIDAVIT PURSUANT TO RULE 3129
(Affidavit No. I)
GE CAPITAL MORTGAGE SERVICES. INC., Plaintiff in ilie above action, by its attorney,
DANIEL G. SCHMIEG, ESQUIRE, sets forth as of the date ilie Praecipe for the Writ of Execution was
filed the following information concerning the real property located at .12 SHIRLEY LANE.
BOILING SPRINGS. PA 17007 .
1. Name and address ofOwner(s) or reputed Owner(s):
Name
Last Known Address (if address cannot be
reasonably ascertained, please indicate)
SARA JANE CREELMAN
12 SHIRLEY LANE
BOILING SPRINGS, PA 17007
2. Name and address ofDefendant(s) in the judgment:
Same as above
3. Name and last known address of every judgment creditor whose judgment is a record lien on ilie real
property to be sold:
Name
Last Known Address (if address cannot be
reasonably ascertained, please indicate)
None
, 'WI
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4. Name and address of last recorded holder of every mortgage of record:
Name
PNC BANK NATIONAL ASSOCIATION
Last Known Address (if address cannot be
reasonably ascertained, please indicate)
2730 LIBERTY AVENUE
PITTSBURGH. P A 15222
5520 CARLISLE PIKE STE 155
MECHANICSBURG. P A 17055
CITIFINANCIAL INC.
5. Name and address of every otiler person who has any record lien on tile 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 otiler person of whom tile plaintiff has knowledge who has any interest in
tile property which may be affected by the sale:
~
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,_ '-...Name
" \
Last Known Address (if address cannot be
reasonably ascertained, please indicate)
Tenant/Occupant
12 SHIRLEY LANE
BOILING SPRINGS, P A 17007
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
Commonwealth of Pennsylvania
Bureau of Individual Tax
Inheritance Tax Division
Attention: John Murphy
6th Floor, Strawberry Square
Dept. 280601
Harrisburg, PA 17128
Internal Revenue Service
Federated Investors Tower
13th Floor, Suite 1300
1001 Liberty Avenue
Pittsburgh, PA 15222
P.O. Box 8486
Willow Oak Building
Harrisburg, PA 17105-8486
Department of Public Welfare
TPL Casualty Unit
Estate Recovery Prog ram
I verify fuat fue statements made in this affidavit are true and correct to fue best of my personal
knowledge or information and belief. I understand fuat false statements herein are made subject to fue
penalties of18 Pa. C.S. Sec. 4904 relating to unsworn falsification to aufuorities.
August 25. 2006
DATE
~A~Ii~ ~C~EG~E*;ffiE ~
Attorney for Plaintiff
j':
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PHELAN HALLINAN AND SCHMIEG, L.L.P.
By: DANIEL G. SCHMIEG
Identification No. 622q5
ONE PENN CENTER ^T SUBURBAN STATION
1617 JOHN F. KENNEDY BLVD., SUITE 1400
PHILADELPHIA, PA 19103-1814
(215) 563-7000
ATTORNEY FOR PLAINTIFF
GE CAPITAL MORTGAGE SERVICES, INC.
Plaintiff,
CUMBERLAND COUNTY
COURT OF COMMON PLEAS
v.
CIVIL DMSION
SARA JANE CREELMAN
NO. 01-6453 CML
Defendant(s).
CERTIFICATION
DANIEL G. SCHMIEG, 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.
"\7~: ..t A ~~o.. .
DANIEL G. SCHMIEG, ESQU@E
Attorney for Plaintiff
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GE CAPITAL MORTGAGE SERVICES, INC.
Plaintiff,
CUMBERLAND COUNTY
v.
No. 01-6453 CIVIL
SARA JANE CREELMAN
Defendant(s).
August 25, 2006
TO: SARA JANE CREELMAN
12 SHIRLEY LANE
BOILING SPRINGS, P A 17007
"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. 12 SHIRLEY LANE. BOILING SPRINGS. P A 17007. is
scheduled tobe sold at the Sheriffs Sale on DECEMBER 6. 2006 at 10:00 a.m. in the CUmberland
County Courth(j:use,. SouthHanover Street, Carlisle, P A 17013, to enforce the court judgment of
$59.969.05 obtained by GE CAPITAL MORTGAGE SERVICES. INC. (the mortgagee) against you.
In the event the sale is continued, an announcement will be made at said sale in compliance with
Pa.R.C.P., Rule 3129.3.
NOTICE OF OWNER'S RIGHTS
YOU MAYBE ABLE TO PREVENT THIS SHERIFF'S SALE
To prevent this Sheriff's Sale, you must take immediate action:
1. The sale will be cancelled if you pay to 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.
"I,
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You may need an attorney to assert your rights. The sooner you contact one, tl1e more chance
you will have of stopping tl1e 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 tl1e Sheriffs Sale is not stopped, your property will be sold to tl1e highest bidder. You may
find out the price bid by calling (215) 563-7000.
2. You may be able to petition tl1e Court to set aside the sale if tl1e bid price was grossly
inadequate compared to tl1e value of your property.
3. The sale will go tl1rough only iftl1e buyer pays tl1e Sherifftl1e full amount due in tl1e sale. To
find out if this has happened, you may call (717) 240-6390.
4. Iftl1e amount due from tl1e Buyer is not paid to tl1e Sheriff, you will remain tl1e owner oftl1e
property as if tl1e sale never happened.
5. You have tl1e right to remain in tl1e property until tl1e full amount due is paid to tl1e Sheriff
and tl1e Sheriff gives a deed to tl1e buyer. At that time, tl1e buyer may bring legal proceedings to evict
you.
6. You may be entitled to a share of tl1e money which was paid for your house. A schedule of
distribution of tl1e money bid for your house will be filed by tl1e Sheriff within 30 days of tl1e sale. This
'schedule will state who will be receiving tl1at money. The money will be paid out in accordance witl1
this schedule unless exceptions (reasons why tl1e proposed distribution is wrong) are filed witl1 tl1e
Sheriff within ten (10) days after the distribution is filed.
7. You may also have otl1er rights and defenses, or ways of getting your home back, if you act
immediately after the sale.
YOUSHO.ULDTAKE.. THIS PAPER TO YOUR LAWYER AT ONCE. IF YOU DO NOT HAVE
A LAWYER OR CANNOT AFFORDoNii; GO TO OR iELEPHONETHE Oi?FIcELisTED
BELOW TO FIND OUT WHERE YOU CAN GET LEGAL HELP.
IMPORTANT NOTICE: This property is sold at the direction of the plaintiff. It may not be sold
in the absence of a representative of the plaintiff at the Sheriff's Sale. The sale must be
postponed or stayed in the event that a representative of the plaintiff is not present at the sale.
CUMBERLAND COUNTY ATTORNEY REFERRAL
CUMBERLAND COUNTY BAR ASSOCIATION
2 LmERTY AVENUE
CUMBERLAND COUNTY COURTHOUSE
CARLISLE, P A 17013
(717) 249-3166
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,
f ~ ALL mAT CERTAIN piece or parcel of land situate in South Middleton Township, Cumberland
County, Pennsylvania, bounded and described in accordance with a survey by Thomas A. Neff, R. S.
dated August 13, 1970, as follows:
BEGINNING at a point on the Northern side of Shirley Lane ort the dividing line between Lots Nos.
19 and 20 on the hereinafter mentioned Plan of Lots, said point also being 589.24 feet West of the
W:~tern right of way line of L. R. #21008; thence along the Northern side of Shirley Lane South 68
degrees 49 minutes 50 seconds West 100 feet to a point at the dividing line between Lots Nos. 18 and.
19 on said Plan; thence along last said line North 21 degrees 10 minutes 10 seconds West 120 feet to
a point; thence by the dividing line between Lots Nos. 19 and 31 on said Plan North 68 degrees 49
minutes 50 seconds East 100 feet to a point; thence by the dividing line between Lots Nos. 19 and 20
aforesaid South 21 degrees 10 minutes 10 seconds East 120 feet to a point, the place of beginning.
BEING Lot No. 19 on the Plan of Lots known as Clifton Heights as recorded in Plan BC;lOk 17, Page
59.
HAVING erected thereon a masonry arid aluminum siding ranch honse.
TITLE TO SAID PREMISES IS VESTED IN Sara Jane Creelman by reason of the following:
BEING mE SAME premises which Clifford L. Heishman and Ethel E. Heishman, his wife an~
William S. Wert and Lois A. Wert, his wife by Deed dated 8/31/1970 and recorded 9/15/1970 m
the County of Cumberland in Deed Book Volume 23, Page 385 conveyed unto Arthur N. Creelman
and Sara Jane Creelman, his wife.
AND THE SAID Arthur N. Creelman died on 3/25/93 whereby title to said premises became veSted
, in Sara Jane Creelman by right of survivorship.
Tax Map #27-1921, Parcel 2
Premises:
12 SHIRLEY LANE, TOWNSHIP OF SOUTH MIDDLETON
CUMBERLAND COUNTY
PENNSYLVANIA.
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WRIT OF EXECUTION andlor ATTACHMENT
COMMONWEALTH OF PENNSYLVANIA)
COUNTY OF CUMBERLAND)
NO 01-6453 Civil
CIVIL ACTION - LAW
TO THE SHERIFF OF CUMBERLAND COUNTY:
To satisfy the debt, interest and costs due GE CAPITAL MORTGAGE SERVICES, INC.,
Plaintiff (s)
From SARA JANE CREELMAN
(I) You are directed to levy upon the property of the defendant (o)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 hlln/her that he/she has been added as a
garnisbee and is enjoined as above stated.
Amount Due $59,969.05
L.L.
Interest FROM 1/5/02 TO 12/6/06 (pER DIEM - $9.86) -- $3,677.00 AND COSTS
Ally's Comm % Due Prothy $1.00
Ally Paid $862.56 Other Costs
Plaintiff Paid
~
Date: AUGUST 28, 2006
(Seal)
Prothonotary
By:
Deputy
REQUESTING PARTY:
Name DANIEL G. SCHMIEG, ESQUIRE
Address: ONE PENN CENTER AT SUBURBAN STATION
1617 JOHN F. KENNEDY BOULEVARD, SUITE 1400
PHILADELPHIA, PA 19103-1814
Attorney for: PLAINTIFF
Telephone: 215-563-7000
Supreme Court ID No. 62205-
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Phelan Hallinan & Schmieg, LLP
Suite 1400
One Penn Center Plaza
Philadelphia, PA 19103-1418
Phone (215) 563-7000
Main Fax (215) 563-5534
Pat Wilkins
Legal Assistant
Representing Lenders in
Pennsylvania and New Jersey
October 6, 2006
Office of the Protl1onotary
Cumberland COlmty
No. 01-6453
Notice of sale
Dear Sir/Madame:
Enclosed are Affidavits of Service for the above captioned matter for filing with
your office. We have forwarded copies ofthe same to the Sheriff
If you have any questions regarding this matter, please do not hesitate to contact
this office. Thank you for your cooperation.
Sincerely,
Pat Wilkins
Pat Wilkins
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AFFIDAVIT-OF SERVICE
PLAINTf,FF ...
GE CAPITAL MORTGAGE SERVICES,
INC.
CUMBERLAND COUNTY
CQS
DEFENDANT(S)
SERVE SARA JANE CREELMAN AT
12 SHIRLEY LANE
BOILING SPRINGS, PA 17007
SARA JANE CREELMAN
No. 01-6453 CIVIL
ACCT. #0022099485 Pl-\S*"S~(Q5t
Type of Action
- Notice of Sheriff's Sale
Sale Date: DECEMBER 6, 2006
SERVED
Served and made known to 5C<f q -;:fa..,e uee/I<>I."'" . Defendant, on the
at t / 'f . O'c1ockf!..m., at /2- Sh; I' ley I a n e
J ~j-
day of 5. f ~e", 1><>1' , 2004:,
I Commonwealth
of Pennsylvania, in the manner described below:
~fendant personally served.
Adult family member with whom Defendant(s) reside(s). Name and Relationship is
Adult in charge ofDefendant(s)'s residence who refused to give name or relationship.
Manager/Clerk of place of lodging in which Defendant(s) reside(s).
Agent or person in charge of Defendant(s)'s office or usual place ofbusioess.
an officer of said Defendant(s)'s company.
Other:
Description: Age $"""0-&" Height S>S" Weight~ Race}c,.,L Sex L Other
I, ~ at I'- d IZo bM'!- r . a competent adult, being duly sworn according to law, depose and state that I personally handed
a true and correct copy of the Notice of Sherifrs Sale in the manner as set forth herein, issued in the captioned case on the date and at
the address indicated above.
- By:
Q~ -/U--.
'E SERVICE AT LEAST 3 TIMES. INDICATE DATES & TIMES OF SERVICE ATTEMPTED.
State of New ~!r ,sey
PATRiCI!'. E. HARRIS NOT SERVED
Commission Expires June 16,2008
On the day of , 200~ at o'clock _.m., Defendant NOT FOUND because:
Moved ~ Unknown ~ No Answer
Vacant
1st Attempt:
/
/
Time:
2nd Attempt:
/
/
Time:
3rd Attempt:
/
/
Time:
Sworn to and subscribed
before me this _ day
of .200 .
Notary:
By:
Attornev for Plaintiff
Daniel G. Schmieg, Esquire - I.D. No. 62205
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PHELAN HALLINAN & SCHMIEG, LLP
By: DANIEL G. SCHMIEG, ESQUIRE
Atty. !.D. No. 62205
One Penn Center Plaza, Suite 1400
Philadelphia, P A 19103
(215) 563-7000
ATTORNEY FORPLMNTITF
GE Capital Mortgage Services, Inc.
5024 parkway Plaza Boulevard
Building 7/F/C
Charlotte, NC 28217-2407
COURT OF COMMON PLEAS
CIVIL DIVISION
v.
NO. 01-6453 Civil
Cumberland County
Sara Jane Creelman
12 Shirley Lane
Boiling Springs, P A 17007
PRAECIPE TO MARK JUDGMENT TO USE OF PLAINTIFF
TO THE PROTHONOTARY:
Please mark judgment in the above-captioned matter to the use of:
Wells Fargo Bank, N.A.
I Home Campus
Des Moines, IA 50328
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DANIEL G. SCHMIEG, ESQ
ATTORNEY FOR PLAINTIFF
DATED: Fridav. November 03. 2006
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SALE DATE: DECEMBER 6.2006
IN THE COURT OF COMMON PLEAS OF CUMBERLAND COUNTY, PENNSYLVANIA
CIVIL ACTION - LAW
WELLS FARGO BANK, N.A.
No.: BOILING SPRINGS, P A 17007
vs.
SARA JANE CREELMAN
AFFJ[DA VIT 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 tl1e following information concerning the real property located at:
. 12 SHIRLEY LANE.
As required byPa. R.C.P. 3l29.2(a) Notice of Sale has been given in tl1e manner
required by Pa. R.C.P. 3l29.2(c) on each of the persons or parties named, at that address set forth
on tl1e attached Affidavit No.2 (previously filed) and Amended Affidavit No.2 on the date
indicated, and a copy of the notice is attached as an Exhibit. A copy ofthe Certificate of Mailing
(Form 3817) and/or Certified Mail Return Receipt stamped by the U.S. Postal Service is attached
for each notice.
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DANIEL SCHMIEG, ESQUIRE
Attorney for Plaintiff
November 3, 2006
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Phelan I lallinan & Schmieg, UP
1617 JFK Boulevard, Suite 1400
One Penn Center Plaza
Philadelphia, PA 19103
215--?63-7000
Attorney For Plaintiff
INC.
GE CAPITAL MORTGAGE SERVICES,
Court of Common Pleas
Plaintiff
Civil Division
IV s
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CUMBERLAND Cmuy
SARA JANE CREELMAN
Defendant No. 01-6453
PRAECIPE
-
TO THE PROTHONOTARY: 77
Please vacate the judgment(s) entered and mark the action discontinued and ended
wil:hout prejudice.
Date: September 23, 2010 PI 1F1, AN HAI.LLNAN-&--StC W IEG. 1,1 P
By:
III--4 4? '(>58
Lawrence T. P elTn Esq., !Id. No. 32227
Francis S. alIinan, Esq., Id. No. 62695
Dani ° ,. Schmieg. Esq., Id. No. 6220>
M' cle M. Bradford, Esq.., Id. No. 69849
Judith T. Romano, Esq., Id No. 58745
Sheetal R. Shah-Jan], Esq., Id. No. 81760
Jenine R. Davey. Fsq.. Id. No. 87077
Lauren R. "babas. Esq., Id. No. 93337
Vivek Srivastava, Esq., Id. No. 2023 31
Jay 13. Jones. Esq., Id. No. 8667
Peter J. Mulcahy, Fsq., Id. No. 61791 --' ?-Andrew L. Spivack, I sq., Id. No. 84439
Jairne McGuinness.. Fsq., Id. No. 90134
Chrisovalante P. Fliakos, Esq., Id. No. 94(,20
Joshua 1. Goldman. Esq., Id. No. 2030-47
Courtenay R. Dunn, Esq., Id. No. 206779
Andrew C. Bramblett, Lsq., Id. No. 208,75
Altorncvs for Plaintiff
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