The URL can be used to link to this page

Home My WebLink About01-06460 "~ . ~~~=--_." ~~~ ~ ~ 1 L", ," <"C'"" c ,,,."-, 1_",,;.. -~"Li~~~Lr.,." ,.. , . PRAECIPE FOR WRIT OF EXECUTION - (MORTGAGE FORECLOSURE) P.R.C.P. 3180-3183 COUNTRYWIDE HOME LOANS, INC. Plaintiff, v. No. 01-6460 TIMOTHY S. CLIPPINGER TRACIE A. CLIPPINGER Defendant(s). TO THE DIRECTOR OF THE OFFICE OF THE PROTHONOTARY: Issue writ of execution in the above matter: Amount Due $77,480.92 I Interest from 12/20/01 to 6/5/02 (per diem -13.14) $2,486.63 and Costs TOTAL $79,967.55 1J1~ FRANK FEDERMAN, ESQUIRE One Penn Center at Suburban Station 1617 John F. Kennedy Boulevard, Suite 1400 Philadelphia, PA 19103-1814 Attorney for Plaintiff Note: Please attach description of property. No. , , ~~Wii;jjji~!&<!!f*\':\"';;''-,'i'-"di,'O-;d'~'''--'''''-''''''-F'_"kW''''J''''J''',",fi_C"-,'<",,, i",_,~"t;.~_~"~i';';;i,.,(<n [C"."i.,;!!&L[:!i~_w,~~lliwJilIItflt,~)$JiitWrt!~ -'~1t!I;' ~ _ ,." "IT "' II~'.'~" ,~ ...< OZ oo~ <"", "'~ ""'00 ~Z Zz 0", ::s~ ::s ~ O~ UZ ...~ 00 ""U ~~ O~ U~ "'", === ""::S Z~ ....U "",'..,.."->""""",,,,,,..,,, u z .... 00 ~ o "'" '" ::s o == '" ~ .... ~ "" Z ~ o U .; ;.. ..::..:: ~~ =Sz ~.... ~~ ....~ ""'.... U"'" .U 00 . ~< =='" "".... OU ::s~ ...."" "" z o .... "" ~ U ~'E' '" = ... ~ Otl "" :: Sl~ ~~ ..:: .. 0101) ...'g "'::S ~'-' .... U ~ ~ ~ .~ - .13 .. - 1~ a o ~ -i:i OJ - ~ ~-~-"'~~"'_"'",,'''''''''''''''',''Y-"l_,,---~~",,~,~__~ ~, ,-"~"~,,-<,,~,"_,,,'~'=" ~_, ~ ,~~;,_~,' ,_''_ ., '" '" .... .... == r--r-- .... .... << ~~ ~~ "",..l 0000 ~~ UU ...... "'~ ~~ ""E-< 0000 UU QO IX> '" '" '" '" '" '" OJ -l:l "0 < o c Z \:J c~ mr:' Z:r ZC ~~~: k'C:; ~C) .L-r-, J:;"c: -,. <- =< ~,tlIW~Ut1l.irr- "!ilIik-" o -" _1\iI;~\'~ '.. . ..,,; OJ ~ '" OJ .!:J ~ S '" ~ g- o.. I '--I -n o ,"'1 ,-, G:J :n ,..,,'" .~~ ~~l -L, -<. -0 J;: N r:- . .#,.. . , , LEGAL DESCRIPTION :r: "", ALL that certain tract of land with the improvemems thereon situate in the Borough of C3.Ilisle. Cumb~~I;:J1d County, ?enm:;~vania, bounded and described. as follows: .;g.'-- (In the North: by "e" S:reet; on the East by property now or forrner!y of Carlisle Trust Company; on the South by property t10W or fr:rmerly of Edward Brownaweil and Rebecca E~ Brownawell; and on the West by properry now or formerly of S. L Diven, Said lot having a frontage on "C" Street of 48,85 reet and on [he Soml1 or' 49,95 feet. and a depth of lOL4Q feet and being made up ofp= of Lots Nos, 37 and 38, Block 14, of the Carlisle Land and Improvement Company, and being known.,. 338 "C" Street, Carlisle. Pennsylvania, BEING the =e premises whieh Raymond C. Bobo, 'II .md Deborah, \, Bobb, hi, wife. by their Deed dated November 3. 1994 and recorded November 4, 1994 in the Office of the Recorder of Deeds 01 Cumberland County in Deed Book 114, Page 563, grantea and conveyed untl' John A. Bobb, single man, Grantor herein. , ";-;;k_,t;;~'IWtiOifl~;i5;,~,,,,(J!."-+; i~r~k~jN,lii*,"".r~r':'~@I"'ik\",'f;1#i ~@~ ~ is' , "c",__",._,.,~ ,~'''"~ ~, _ _ C"~ -J 1- "" ....r-, - ~-"-"'~ --"", ,<,,"'-~' ";3,_"~iJ_';, '''NiP;tG~~~L'&'~' ([ ~ilOO~,jgy '"'ii:litIl~ji!l,~~'7lf,..;'""'.J"lloiilL ~ ~0 - c-[J ..5) ~ \' >IS; j I I ~- ; +:::-- ,/ C>J - ~ (;J - ~ -,E::---, , 0, ~I '-d ~/ ~ 0 l; C' C- D ,,",,-,, "" ,-~ -, ~ ~ , ,. ,0 -~" , ,." '4_,. ~;o;j.flll!!O;,i' o C s: ~'Ow fllr11 ;~p,' ~~?r !CD -,,;; zQ -'~L' :PC ~ -,- ~~'[ o '=' r'\l c., :,) 'I'!!ll" ~ ~'- , , ~ C) -n -1~ r". r--: -u 3 r;.: "'" ;Z, ~;) ~~l BIn 'j;' ::0 =< ':;:l..Jo'''~''''''''.~ '~ , -~ "~~ --"- 10 ..L.,~ .~- - ~ -"'11_' '--''':'~^~ '<';,'-""~X"'ilI.-.! "' . FEDERMAN AND PHELAN By: FRANK FEDERMAN Identification No. 12248 Attorney for Plaintiff ONE PENN CENTER AT SUBURBAN STATION 1617 JOHN F. KENNEDY BLVD., SIDTE 1400 PHILADELPIDA, PA 19103-1814 (215) 563-7000 , COUNTRYWIDE HOME LOANS, INC. 7105 CORPORATE DRIVE PLANO, TX 75024-3632 CUMBERLAND COUNTY COURT OF COMMON PLEAS Plaintiff, CIVIL DIVISION v. NO. 01-6460 TIMOTHY S. CLIPPINGER TRACIE A. CLIPPINGER Defendant(s). PRAECWEFORJUDGMENTFORFMLURETO ANSWER AND ASSESSMENT OF DAMAGES TO THE PROTHONOTARY: Kindly enter judgment in favor of the Plaintiff and against TIMOTHY S. CLIPPINGER and TRACIE A. CLIPPINGER, 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 11/1/01 to 12/20/01 TOTAL $76,736.42 $744.50 $77,480.92 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, FRj~N~ Attorney for Plaintiff DAMAGES ARE HEREBY ASSESSED AS INDICATED. DATE: I J.. - 3(-01 ~ PRO PROTHY J: 'cJ~ !JkA , - " M~dlfii&ill__"il!fHe;J1t:ili,YJ!',jj;lliill;'>;[\':*,~'&i!~H_J"il'1J'li.'i[,,!,,.~w,-_<,-,";'I~,,~~,j_"lA"""'~!"i";"";;-;'.'V'~i";~i');fW;?~lti~'-'; 'v '':'-iii~noi iIi-'~ ,,""'~'~";h".., ,. .', "",""" ,>_,' ",,^,- ""'~"'"''''~~'~''0-''''''~''' cZ-t, ,_/0. "'" ,'"" ", " .',_" - ,;c,. '. ':~ - ~,,,"".,,,""',.._'"""',.~_~< ~~~Il!ijl(JslMl -~ ',- .. i , 0 CJ s;; ,- ~ c:J -00.:1 Pl -n ron; (~"') ~- Z:C', (AI -":'~~ ZC cnv ~:~(:) ~:Z: .!:2.C":- ""U /~jj ZO 3: .,-.....c t'~.. ::/~'l-:: ",-0 ~ i51' J;>c: '''-\ z: c:- ~ -I c:> ...., ----- .- _. ,,~, = ~,_. ,_ __ ,>~ ",,0 ~~_..~~ - ....""~ -",... _.'.""-,.~. - ~' -~ -.---> , ~ j., u ,~, -"'-- "-"'"~"' ~h;."~';'tmi~L:'~E:" .." 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 COUNTRYWIDE HOME LOANS, INC. CIVIL DIVISION Plaintiff CUMBERLAND COUNTY vs. NO. 01-6460 CIVIL TIMOTHY S. CLIPPINGER TRACIE A. CLIPPINGER Defendant(s) ..~. - -.-,:j "~'. TO: TIMOTHY S. CLIPPINGER 338 C STREET CARLISLE,PA 17013 t ,. ...:.._", ..:a , ~, ~ ' .'" ' , DATE OF NOTICE: DECEMBER 7,2001 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 ~A/L~?~~' Frank Federman, Esquire Attorney for Plaintiff """""",,,,",'" , .~~ ^'~"'~.M~~'~'='Nlii1IN'_ U~ __...'~"" , , ~'"- .J_... --10'"-', - ~"'.~'i...'i'Jt_i_ ~ FEDERMAN AND PHELAN ~ Frank Federman, Esquire Identification No. 12248 One Penn Center Plaza at Suburban Station, Suite 1400 Philadelphia, PA 19103-1799 (215) 563-7000 ATTORNEY FOR PLAINTIFF COURT OF COMMON PLEAS COUNTRYWIDE HOME LOANS, INC. CIVIL DIVISION Plaintiff vs. CUMBERLAND COUNTY TIMOTHY S. CLIPPINGER TRACIE A. CLIPPINGER NO,01-6460 CIVIL Defendant ~> ":"'c ~ TO: TRACIE A. CLIPPINGER 338 C STREET CARLISLE,PA 17013 DATE OF NOTICE: DECEMBER 7,2001 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 ASSOClA TION 2 LIBERTY AVENUE CARLISLE, PA 17013 (717) 249-3166 ~cu~ /;)d~- Frank Federman,Esquire Attorney for Plaintiff > . .~"'" " " 1 - ~a ~ ~~" . -,,~ , r ""'illl'!:[-::: ..u~"~N '~' __,,,,,,,",,,,,,,, , J ~ FEDE~ANandPHELAN By: FRANK FEDERMAN Identification No. 12248 ONE PENN CENTER AT SUBURBAN STATION 1617 JOBNF. KENNEDY BLVD., SUITE 1400 PHILADELPHIA, PA 19103-1814 (215) 563-7000 ATTORNEY FOR PLAINTIFF COUNTRYWIDE HOME LOANS, INC. 7105 CORPORATE DRIVE CUMBERLAND COUNTY COURT OF COMMON PLEAS Plaintiff, CIVIL DIVISION v. NO. 01-6460 TIMOTIIY S. CLIPPINGER TRACIE A. CLIPPINGER Defendant(s). VERIFICATION OF NON-MILITARY SERVICE FRANK FEDERMAN, ESQUIRE, hereby verifies that he is attorney for the Plaintiff in the above-captioned matter, and that on information and belief, he has knowledge of the following facts, to wit: (a) that the defendant(s) is/are not in the Military or Naval Service of the United States or its Allies, or otherwise within the provisions of the Soldiers' and Sailors' Civil Relief Act of Congress of 1940, as amended. (b) that defendant TIMOTHY S. CLIPPINGER is over 18 years of age and resides at , 338 C STREET, CARLISLE, PA 17013 . (c) that defendant TRACIE A. CLIPPINGER is over 18 years of age, and resides at, 338 C STREET, CARLISLE, P A 17013. This statement is made subject to the penalties of 18 Pa. C.S. Section 4904 relating to unsworn falsification to authorities. ~~ 41 FRANK FEDERMAN, ESQUIRE Attorney for Plaintiff .""""_.............,"~~oD.Id.... I, r - J .lll~' ~.' . ..~ ~- .-~ ',-.;~... {,-, --. I!i;:'f~ . , , .~ (Rule of Civil Procedure No. 236) - Revised IN THE COURT OF COMMON PLEAS OF CUMBERLAND COUNTY, PENNSYLVANIA CIVIL ACTION - LAW COUNTRYWIDE HOME LOANS, INe. 7105 CORPORATE DRIVE CUMBERLAND COUNTY COURT OF COMMON PLEAS Plaintiff, CIVIL DIVISION v. NO. 01-6460 TIMOTHY S. CLIPPINGER TRACIE A. CLIPPINGER Defendant(s). Notice is given that a Judgment in the above-captioned matter has been entered against you on 11.--3J. 2001. BY6~4r~ If you have any questions concerning this matter, please contact: FRANK FEDERMAN. ESQUIRE Attorney for Plaintiff ONE PENN CENTER AT SUBURBAN STATION 1617 JOHNF.KENNEDYBLVD., SUITE 1400 PHILADELPHIA, PA 19103-1814 (215) 563-7000 "THIS FIRM IS A DEBT COLLECTOR ATTEMPTING TO COLLECT A DEBT AND ANY INFORMATION OBTAINED WILL BE USED FOR THAT PURPOSE. IF YOU HAVE PREVIOUSLY RECEIVED A DISCHARGE IN BANKRUPTCY AND THIS DEBT WAS NOT REAFFIRMED, THIS CORRESPONDENCENDENCE IS NOT AND SHOULD NOT BE CONSTRUED TO BE AN ATTEMPT TO COLLECT A DEBT, BUT ONLY ENFORCEMENT OF A LIEN AGAINST PROPERTY." "i~~'j,'M~~~ii-l~,~Rifmrt,.!;]{"JiE~",,~.-~-,;-tt;j;,:iilli~M'#"'%""~~:',-&-.:;o.,-,_",,",,-M-';!"'~'P;'':''''''''~'t,;''.;J~,,\"~1l,~~~~l@ii;~~':''' '....." ,''':- ~.,""O;~=" "' ""';iiimlj(!l"l)l"~~"">.~' ~ L - ~ C) ~ V-' ?b~~ I I I~ II' . ~ t' r- l,'r'~~'" ".~~_ "~ "'--"-''''--''~"- "- ~= = "" "..J ~~ , "'" ....... < '.~~ U r - ~ ~ ( ---- G-. 't-- J 'LJ<) <:!- -- C) ----, it , . ~. . C> c::> 0 C '"1'1 ;s: 0 ""'UClJ rrt ~: mer; n z._.~_, GoJ .,,"["":t ZC;,~ ~~~ "2Cj :::, ...:~- ~c.) -0 -..:S;, ZO -~ /"''' ~,c, is; (jrn ::t"c '--l z: ~~ =::: c:- :D (::> -< ,~ ~ ~ "._""""''''~- ,_,I, - ~." ~""-",,;_->.',i,,, - '\1.:.,.,."",_";/-\ - ~. ;""-ii~~, , . . FEDERMAN AND PHELAN, LLP By: FRANK FEDERMAN, ESQUIRE IDENTIFICATION NO. 12248 ONE PENN CENTER AT SUBURBAN STATION 1617 JOHNF. KENNEDY BOULEVARD SUITE 1400 PHILADELPHIA, PA 19103-1814 (71 'i) 'i/l,-7000 ATTORNEY FOR PLAINTIFF COURT OF COMMON PLEAS CIVIL DIVISION COUNTRYWIDE HOME LOANS, INC. 7105 CORPORATE DRIVE PLANO, TX 75024-3632 TERM Plaintiff v. NO. 01 - "4~O Co~L Ik~ CUMBERLAND COUNTY TIMOTHY S. CLIPPINGER TRACIE A. CLIPPINGER 338 C STREET CARLISLE,PA 17013 Defendant(s) CIVIl. ACTION - l.A W COMPI .AINT TN MORTC.AGF. FORF.rr ,OSTJRF. NOTTeR **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 TIDS 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 wan #: 59099S4 .~= - ,=""......~" ~ ...... "-' ~ "",.'", '~',,_U'.' --, ' -, " "-~Y,i'UJ.1ii&'!~'" , 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. o ~" ~-~. '~--' , 1 ,,~ , '~~ . . J ~ " ' "~-,, ;'r '-",- -,- " ~;fi;,; 1. Plaintiff is COUNTRYWIDE HOME LOANS, INC. 7105 CORPORATE DRNE PLANO, TX 75024-3632 2. The name(s) and last known addressees) of the Defendant(s) are: TIMOTHY S. CLIPPINGER TRACIE A, CLIPPINGER 338 C STREET CARLISLE, PA 17013 who is/are the mortgagor(s) and real owner(s) of the property hereinafter described. 3. On 10/29/96 mortgagor(s) made, executed and delivered a mortgage upon the premises hereinafter described to PROVIDENT MORTGAGE CORP. T/A CONSOLIDATED MORTGAGE CORP. which mortgage is recorded in the Office of the Recorder of CUMBERLAND County, in Mortgage Book No. 1348, Page 818. By Assignment of Mortgage recorded 10/29/96 the mortgage was assigned to PROVIDENT BANK OF MARYLAND which Assignment is recorded in Assignment of Mortgage Book No. 533, Page 702. By Assignment of Mortgage recorded 2/14/97 the mortgage was assigned to PLAINTIFF which Assignment is recorded in Assignment of Mortgage Book No. 540 , Page 809 . 4. The premises subject to said mortgage is described as attached. 5. The mortgage is in default because monthly payments of principal and interest upon said mortgage due 3/1/01 and each month thereafter are due and unpaid, and by the terms of said mortgage, upon default in such payments for a period of one month, the entire principal balance and all interest due thereon are collectible forthwith. ~- .-....-: ~ ~ .~ ". ;,"";' ',...._""-..:<':-, 6. The following amounts are due on the mortgage: Principal Balance Interest 2/1/0 I through 11/1/0 I (Per Diem $14.89) Attorney's Fees Cumulative Late Charges 10/29/96 to 11/1/01 Cost of Suit and Title Search Subtotal $67,009.45 4,079.86 3,350.00 211.84 .iiOJlQ $75,201.15 Escrow Credit Deficit Subtotal 0,00 1 Sl~ ')7 . $l,Sl~ ?7 TOTAL $76,736.42 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. WHEREFORE, PLAINTIFF demands an in rem Judgment against the Defendant(s) in the sum of $76,736.42, together with interest from 11/1/01 at the rate of$14.89 per diem to the date of Judgment, and other costs and charges collectible under the mortgage and for the foreclosure and sale of the mortgaged property. j--~1-~ /~/ Fr::tnk F~il~1i11::tn FRANK FEDERMAN, ESQUIRE Attorney for Plaintiff 1'i , . ,-\LL 'hat ':;.e,"'..J.,i~ :::..::--: ,): :~.::: '..v1~~. .;:~ Il"':1~ml,.~rr.enL<; ';h!:'e..>(l ,;p.u:ste '1 ~tlc :3or:-''';,~1 d ',:,Hd~ic, '~...lnJ.>.'::';;wo;;. C_~~_~'.t... P';....~.:;:f.'i;:..'1lL. '::,)~;':1Gec ,:....".c :.1~i.:;'i:)~C. ::..::. :C::::''\'':';. n ..'lC ''',:::~,~ ~"~V .'''......., "Y1 :;',:e ~: '.;y :~'j'Jpe:":y ~:',;'k Jr ;'.:J:-':r.-~r:;.- ~){ :::.ll..;';,t ;-,lst C~)lTlp<1.n;r, ,~li :;-:e S(::J~l: :)r:)~-.:::.."".'; :-;';;'_v ~,-; :'or:i1cr:y ;J( '::'':':'I,ivc.~: 3r::wrle.....-ve:: .ir.d R..-:tt:::..:.: ::. Sro\v';"::,::wei1. ;'mG an 'De ',V:::;l ')V .:rop~:" ~,:;w ::)r ~cr.r.e....jy :,H' S ~. :Ji....'cn ~.::JO 1m ;"\;;'-~ll~r; 1. :';\lntage: :';0 "(~" Slre~~ (~;" -1~ ~5 r~ ",n.:J 01\ ~~le SlJu:h .Jf.49 9S ;'c:::, -"no ~ ;.~~'.~; Jf' : ':;: ~':' .1nc )C'U'i!I ,1~JJe ..:~' .J." :Jdf:.$ r)t ::""J15 >;05. :;- .1r:d 38, a:oc:.: ;4, ,Jf rill" C.:..:il~ie =...:w:: .lr:~ :':,~DI ::l....e:-;>'~n~ .._....)\71..,3.,;' .~:.. ~c'~.; ,,~,..:w~ ~ : ::,g 'C~ :5r;-er.:, '::~;,sie. :'~~(1nS:I'o.-;;:"l~, I3CL"IG :,';e :a.T,~ :Jrco~.: "N~ich ic-\ ':"\10~"D C BOB8. Lll :iod DS30R...\~~ ,.\" 3C3R ,"II;': ",vd'e. sr::tr.t;:ci ~rld _JfrT-:::Yce :0 JCH--o:N A 30BB.. :;;:nc \,If :he :;rJ!l~ors ncreir., .:ry' jeed Jared S',jvemDer 3,1994 :inc rec.."J.ded :n the OfRc~ af:hc R=ccider ::Jf Dee:::s fer C~:nlJe7;z.nd C~L:r;tY, ~~~:1s,:t"'J.m.'l, in. :)~C Seck ~ >~ ?~,I.~!.: ~:6}, PREMISES ON: 338 C STREET ,'-0,- _", _,J '- -- ','-;,;,,, "J'_' -'-~~, VERlFICATION FRANK FEDERMAN, ESQUIRE hereby states that he is attorney for Plaintiff in this matter, that Plaintiffis outside the jurisdiction of the court and/or the verification could not be obtained within the time allowed for the filing of the pleading, that he is authorized to make this verification pursuant to Pa. R. C. P. 1024 (c), and that the statements made in the foregoing Civil Action in Mortgage Foreclosure is based upon information supplied by Plaintiff and is true and correct to the best of its knowledge, information and belief. Furthermore, it is counsel's intention to substitute a verification from Plaintiff as soon as it is received by counsel. 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. ~~r~ Frank Federman, Esquire Attorney for Plaintiff DATE: I//i"/O/ _. ~__,m~);M:ih:gj~ddlW5",l'H','l%1"'''''''ffi,'#i'WIJ~,~I'l>AW']J''''"')>'-';-""'<l;,-':J',',,"~;:":\;'<A,.-..:iA~"L,=-~~~~r.i",ilUj&liiii/;lll.\ll!iI' < ,'7'~'w.'" IEW" ~ ~ --at. ~ ). ~ frt ~ n 0 0 C ,j 3 . s:: :% @ ~ ~ ..... () ""'- ~ ""00::; C~ ~) rn,rT\ .c \) ~ ~ (} Z~. ;~\~~ j ..iL-' t);' ~ I J':: .;:- '~ ~ "<""- p: ~ r::CJ "'"' ~o ..". g~ - ~2 S' -{ z w 55 =< tD -< '< !~;~,i!,~lll!nr:nl ..~,-"",,",~~ "_o'7""Cl,<,",,,{<,_~,",~"""-'__"'",o;s,_, ~,~ "'~,?_ ~~" ," _.""'"', y V,-,,",,~ ~, - _"",""","",-"",,,,,,,,,,,,,,,-,,,,"U,,_,, .~1t=~' .& ~~'_,"~'" ~~ .," J, ~_, ~ -., r" """,_.~'O "',' '<';~";"i~~ ~'~~~'\'i":" SHERIFF'S RETURN - REGULAR ., CASE NO: 2001-06460 P COMMONWEALTH OF PENNSYLVANIA: COUNTY OF CUMBERLAND COUNTRYWIDE HOME LOANS INC VS CLIPPINGER TIMOTHY S ET AL RICHARD SMITH , Sheriff or Deputy Sheriff of Cumberland County,Pennsylvania, who being duly sworn according to law, says, the within COMPLAINT - MORT FORE was served upon CLIPPINGER TIMOTHY S the DEFENDANT , at 2105:00 HOURS, on the 16th day of November, 2001 at 338 C STREET CARLISLE, PA 17013 by handing to TIMOTHY CLIPPINGER a true and attested copy of COMPLAINT - MORT FORE together with and at the same time directing His attention to the contents thereof. Sheriff's Costs: Docketing Service Affidavit Surcharge So Answers: 18.00 3.25 ,00 10.00 .00 31.25 r~~~<=~~ R. Thomas Kline 11/19/2001 FEDERMAN & PHELAN me this .;u.. &e- day of Sworn and Subscribed to before By: ~ ;2.bV( A.D, ~ t1 /vrdil.-')~~' Prothonotary _"_"L=,"....~_-'~......."'"'. - " ~~ !>.!IJ'"""~ ~..l ~ -~..~,' .""--'-'~,;,1:, SHERIFF'S RETURN - REGULAR '., ~ . CASE NO: 2001-06460 P COMMONWEALTH OF PENNSYLVANIA: COUNTY OF CUMBERLAND COUNTRYWIDE HOME LOANS INC VS CLIPPINGER TIMOTHY S ET AL RICHARD SMITH , Sheriff or Deputy Sheriff of Cumberland County,Pennsylvania, who being duly sworn according to law, says, the within COMPLAINT - MORT FORE was served upon CLIPPINGER TRACIE A the DEFENDANT , at 2105:00 HOURS, on the 16th day of November, 2001 at 338 C STREET CARLISLE, PA 17013 by handing to TIMOTHY CLIPPINGER, HUSBAND a true and attested copy of COMPLAINT - MORT FORE together with and at the same time directing His attention to the contents thereof. Sheriff's Costs: Docketing Service Affidavit Surcharge 6.00 .00 .00 10.00 .00 16.00 So Answers: rfJk~<.,:ff~ R. Thomas Kline 11/19/2001 FEDERMAN & Sworn and Subscribed to before By: ~ Sheriff h' ~ me t 1S o1~ ~ day of '7Lm;u... Ii.. _ .;LhP I A . D . ~1J.~2L,~ ' rothonotary .._.....,,, ,- . , '~ J. ~ " ~ ,'"' ""'''1'' --tJi~~{ ... .. COUNTRYWIDE HOME LOANS, INC. CUMBERLAND COUNTY Plaintiff, v. COURT OF COMMON PLEAS TIMOTHY S. CLIPPINGER TRACIE A. CLIPPINGER CIVIL DIVISION NO. 01-6460 Defendant(s). AFFIDAVIT PURSUANT TO RULE 3129 (Affidavit No, 1) COUNTRYWIDE HOME LOANS. 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 .338 C STREET. CARLISLE. P A 17013 ~ 1. Name and address ofOwner(s) or reputed Owner(s): Name Last Known Address (if address cannot be reasonably ascertained, please indicate) TIMOTHY S. CLIPPINGER 338 C STREET CARLISLE, P A 17013 TRACIE A. CLIPPINGER 338 C STREET CARLISLE, PA 17013 2. Name and address ofDefendant(s) in the judgment: TIMOTHY S, CLIPPINGER 338 C STREET CARLISLE, PA 17013 TRACIE A. CLIPPINGER 338 C STREET CARLISLE, PA 17013 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. .~~~" ~ -=~~ ~ ~ ,~ ~--~~ -. -,; '. ,-. q -"';' .-"i[{~LG: ''" 'I. 4. Name and address oflast recorded holder of every mortgage of record: Name Last Known Address (if address cannot be reasonably ascertained, please indicate) IRWIN UNION BANK AND TRUST COMPANY 500 WASHINGTON STREET COLUMBUS, INDIANA 47201 5. Name and address of every other person who has any record lien on the property: Name Last Known Address (if address cannot be reasonably ascertained, please indicate) None. 6. Name and address of every other person who has any record interest in the property and whose interest may be affected by the sale. Name Last Known Address (if address cannot be reasonably ascertained, please indicate) None. 7. Name and address of every other person of whom the plaintiff has knowledge who has any interest in the property which may be affected by the sale: Name Last Known Address (if address cannot be reasonably ascertained, please indicate) Tenant/Occupant 338 C STREET CARLISLE, PA 17013 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. December 20.2001 DATE 4JU FRANK FEDERMAN, ESQUIRE Attorney for Plaintiff ,'t\i~ic.,t,.,,~IjJ.:~~i1fiii"i4_,'iki<(,";,.;;.j~\';~ll;'''#''ill''ti<lliR!~i;-':~)''' -"_':_'M"hI,_j''''i_,,;_.y~>"''';.S';'''',",;'i0:tf.',J.'';;;;.,'''ljllrlfJijI'il'~~iII~m_~~i~:iHM:I~ ....~-'1i"iOOur ~~ ....,.,; .. j (") C) C. -' C -Ti S 0 ""OCo C"1 ..:; ~IJ I:::e.. !:DC (-) Z..)....' ,- 'c: ~: zc w ~ , , (j).l-:;> 0 -<:~~. -~() !;: CJ -0 " ~() 31: (-:~;;;.~. --.~, , 0 N r~frl >c ~ z ~ 55 =<! -< ~, ~~~~ ""'_~~ Jw~=~ __l ""~ ...; ,J...-.. _0 ~ q C -' - ","J ~ "o.:~ ' ':J: FEDERMAN and PHELAN By: FRANK FEDERMAN Identification No. 12248 ONE PENN CENTER AT SUBURBAN STATION 1617 JOHN F. KENNEDY BLVD., SIDTE 1400 PHlLADELPIDA, PA 19103-1814 (215) 563-7000 ATTORNEY FOR PLAINTIFF COUNTRYWIDE HOME LOANS, INC. Plaintiff, CUMBERLAND COUNTY COURT OF COMMON PLEAS v. CIVIL DIVISION TIMOTHY S. CLIPPINGER TRACIE A. CLIPPINGER NO. 01-6460 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: (X) an FHA mortgage () non-owner occupied () vacant () Act 91 procedures have been fulfilled This certification is made subject to the penalties of 18 Pa. C.S. Section 4904 relating to unsworn falsification to authorities. FRANK FEDERMAN, ESQUIRE Attorney for Plaintiff ,_..i;ivj<Jr,w!;i$.fH_-lli"~0bH_1.'J"",,:>,,,)!'d;d':~~\'i~'f,ic1ii4;;;,lfEg~ihi;.\Hhjli,;"",'i~h';k",,,'C,_,_~~ ;"::'i;,0~'i","JIW$"11""'tIfi~W-""'= """~" ( ,!';'-''':''''~' _~M _~c ,~ " -- -, -~ -, ~lIiiiliiill' ~ ~~~ " (') C S': -n(f,} m1'~.' -;i"l..':-} ~::c'~.. Z'-.~_. 9:t ~~:;:' _n '.C- ~C) =0 ..vC ~ IBil:iliill~~Ir~'~~"- '~ o o ~4''1. 'c-:. II!W' C) -n w - ~~;~, I;'~~~ qrn ~ -0 :~ ~ t;:"' ,,- -'~'='o~~"""-m ,. "~~M.;, , '-^"'--~"""~:: COUNTRYWIDE HOME LOANS, INC. Plaintiff, CUMBERLAND COUNTY v. No. 01-6460 TIMOTHY S. CLIPPINGER TRACIE A. CLIPPINGER Defendant(s). December 20,2001 TO: TIMOTHY S. CLIPPINGER 338 C STREET CARLISLE, PA 17013 TRACIE A. CLIPPINGER 338 C STREET CARLISLE, P A 17013 * *THIS FIRM IS A DEBT COLLECTOR A TTEMPTING TO COLLECT A DEBT AND ANY lNFORMA TION 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 , 338 C STREET, CARLISLE. P A 17013, is scheduled to be sold at the Sheriff's 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 77,480.92 obtained by COUNTRYWIDE HOME LOANS, INC. (the mortgagee) against you. If the Sheriffs sale is postponed, the property will be relisted for the SEPTEMBER 4,2002 Sheriffs Sale. NOTICE OF OWNER'S RIGHTS YOU MAY BE 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. 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.) - '~---~ ~"~ ~ ~~ -liII1i:liII:K ~"-' "N--""-'hIT@~fr YOU MAY STILL BE ABLE TO SAVE YOUR PROPERTY AND YOU HAVE OTHER RIGHTS EVEN IF THE SHERIFF'S SALE DOES TAKE PLACE. 1. Ifthe 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 if the buyer pays the Sheriff the full amount due in the sale. To find out ifthis 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 ofthe 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 inunediately after the sale. YOU SHOULD TAKE THIS PAPER TO YOUR LAWYER AT ONCE. IF YOU DO NOT HAVE A LAWYER OR CANNOT AFFORD ONE, GO TO OR TELEPHONE THE OFFICE LISTED BELOW TO FIND OUT WHERE YOU CAN GET LEGAL HELP. CUMBERLAND COUNTY ATTORNEY REFERRAL CUMBERLAND COUNTY BAR ASSOCIATION 2 LIBERTY AVENUE CUMBERLAND COUNTY COURTHOUSE CARLISLE, P A 17013 (717) 249-3166 (800) 990-9108 -"Ii' LECrAL DESCRIPTION \ , / ALL tfla.t .:e:--..aln tme: of land wi..t..I-t tile tmprovemer:ts thereon situate in me oorcugh of C3.rlisie. C..1mbe:t~.j.JC County, Penm:"('.'Cl,nia, bounded and descf.bed as follows: no the Nor:h hy "C" S .reet; on the E;1st by property now or former!y of Ca.riist-e Tr..lst Cvmpany, ;)rt :he S0U:~ oy property now O( tC'cmerLy of Edward Brownawell and Rebecca E, Brownawe!l; and on th.e \Vest b~ inoper::; now <)'i formerly of S. L. Dlven, Said lot having a frontage on "C" Stree! of :48.35 6:et and on ~he SvUUi ,j~' lQ.95 feet. and J. depth of iQI.40 feet -and being made up ofp:ms of Lecs ~OS, 37:lild 38. 3!oc~ ;-\.. of ~~:: CJJ'iisie L.1nd and tmprcvemem Company, and being known;b. 338 ~C" Screet. C.:trilsle. Penmylvo.r.ta.. BEING the:;.ame pr~mises which Raymond C. Bobn 'T~ -d.!':d Deborah .\. ooob, ~llS ',litfe. by H:etr Dc=.~d cac.::.t November 3. t994 and recorded November';'~ 1994 in the Office of the Recoreer of D~s of CJmberia..~c County in Deed Boo\< 114, Page 563, grantea and conveyed' unto John A, Boob, ,ingle man. Gramor herem. cp ~c/ "r^~< . "~","~ ,<,,,,,,,;"~""""o4~"l'.-i~<r-Ji1'1&i;t%iM~liliiMh~~L'M<l'M'lflljll;Op";;"- -.'Qi,- o o , G, ,"" -oCC \Tm::: ~f (}) ?~. ::< /C, <;2G )":0 7-0 5c ~ o '"" 'C' W -",.,., .,. - r_"._ ^_~ _, e,' IIiIlIirl~ ._..11" o -;1 -'Q .", .~ T -n ~\ 9 'ss ~< r;? "" .- ~ ~ ~-, ~_";i',,,,.,,,,,,,,.iI"J ~J,...",...-- 'iJIL" - ~"'-J":'; , -~ '~"n_ilk AFFIDAVIT OF SERVICE :TpCr CUMBERLAND COUNTY PLAINTIFF COUNTRYWIDE HOME LOANS, INC. No. 01-6460 DEFENDANT(S) TIMOTHY S. CLIPPINGER TRACIE A. CLIPPINGER ACCT. #5909984 SERVE TRACIE A. CLIPPINGER AT 338 C STREET CARLISLE, PA 17013 Type of Action - Notice of Sheriff's Sale Sale Date: JUNE 5, 2002 Served and made known to~/ t: at ;:5'5"" , o'clock~,m., at :? :3$ SERVED J ((I ifri~ere.... , Defendant, on the C :if" Ckd \:5/ L , ex1'#' day of (l-,c , 200t , Commonwealth of Pennsylvania, in the manner described below: Defendant personally served. r t u '><' Adult family member with whom Defendant(s) reside(s). Relationship is f\,/o~ - 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, . Tac.~i~ Skee.\s Other: I ;/ /#S . . Description: Age 55". HeightM Weight/;)5 Race~SexL Other :;1<>66'c,< I, c\.$~e.t-->G'<- ,^, ~"-*J~ a competent adult, being duly sworn according to law, depose and state that I personally handed a true and correct copy of the' . , as set forth herein, issued in the captioned c.ase on the date and at the address indicated above. NOtarial Seal Debra K. Kauffman, Notary Public Chambersburg 8010, Franklin County Sworn to and subs~ribed My Commission Expires ,pL 2, 2003 be~ me tips -.2l..!!day Member, PIlnnsylvanlaA 01 Otarlesp of Vel:.' \~ <1.,200,1. Notary:lJII-ft----" By: ,~. ^ PLEASE ATTEMPT SERVICE AT LEAST 3 TIMES. INDICATE DATES ~ES OF SERVICE ATTEMPED. " 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 for Plaintiff FrankFederman, Esquire - I.D. No. 12248 One Penn Center at SubJlrban Station 1617 John F. Kennedy Boulevard, Suite 1400 Philadelphia, PA 19103-1814 (215) 563-7000 """'_,<,"_;"-C",_","'''<''''_-;i~'"''ji''hfb~i~iill~""ltIii1/.l'it\~,,!~~}~-'.'"''''''''''''" < -- JU Ii__ _"""'" ""~ __ "~"" -~,,- ,.,>. - ~..,- -~-' , ~ ",--,- ,~ , "~ ,,~ ~1iH&!~~ 0 <::) C) C Iv -,"1 -:.~'r ~~~ ,~ -:c-# ;~ :;:-::: 0J ;~~ _z', :;::CJ ~.l 21~~\ :::,~ ~~~ L~) .....<. =:> _.~ .<:. (.0 -,~" a 0~ ~~ """""".~."",~ '-"U"'" ~"~~..~._~ ,I .- ... __.L-~~_~ ~"'"ttiil~J";~~\-~-~>-',- -.' '""'''''''''Jt.~iri~ AFFIDAVIT OF SERVICE CUMBERLAND COUNTY PLAINTIFF COUNTRYWIDE HOME LOANS, INC. No. 01-6460 DEFENDANT(S) TIMOTHY S. CLIPPINGER TRACIE A. CLIPPINGER ACCT. #5909984 SERVE TIMOTHY S. CLIPPINGER AT 338 C STREET CARLISLE, PA 17013 Type of Action - Notice of Sheriff's Sale Sale Date: JUNE 5, 2002 Served and made known to '7TiMO +kf S, at q!S' ,o'clock~.m.,at :33& C SERVED Cfi ry' ~ f- , Defendant, on the '5J: , GKl-6f<:..- , cJ1~ day of {'Jec ,2001, , Commonwealth of Pennsylvania, in the manner described below: Defendant personally served. AI rt I _ )t Adult family member with whom Defendant(s) reside(s). Relationship is IYOt"'eK ,'~ y..:o.. j,<J 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. J3-ckie Skeels Other: ,- , II ;;5 , Description: Age .:)5 Heightll Weightm- Race ~J SexL Other j~:5e5- I, da"(et-J:.~ L, C,,--l; J ~ a com nt adult, being duly sworn according to law, depose and state that I personally handed a true and correct copy of the Notice f Sheriff's rth herein, issued in the captioned case on the date and at the address indicated above. ~. 1III.,NllIary Public My Ctlfflffiilllltoft t;:.. Fiantdfn ColJll\y Sworn to and subscribed Member, PShn Sepl 2, 2003 befo e me this ~\-day aI~ 9 ~otary: "lOi/"'- By: eV j li~ PLEASE ATTEMPT SERVICE AT LEAST 3 TIMES. INDICATE DA S & TIMES OF SERVICE ATTEMPED. 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 for Plaintiff Frank Federman, Esquire - J.D. No. 12248 One Penn Center at Suburban Station 1617 John F. Kennedy Boulevard, Suite 1400 Philadelphia, PA 19103-1814 (215) 563-7000 ~'1i1l&~~~#ru!;;;1ii~(~"j,S'!'~N,ks'l.i!~'''1ii\'h-!lltril,E-rOi'J,~.;it\t,,''+j,k::!;;--""'~"""","~j' "__',"""!;,ili"",;r'W'ti""-,"'-~""MiI94i!:!t~",ill>~'Wl!ililli!}jj'~iiIt.~@~i.~~~~I!!Ii~ '!lIii&" ,I!!!t C) t-=} c:: l"""'::'J' $, r._ -0'-- :r~~ 9.2 ~rj ~- "7 S en -< _c_ ~ C,; &~) ~ C' -" ~,;f, )> C) w ,-' :~ :z; -' .~ y =< ::'0 C..) -<.::. EJ 8f/ ,~",-, - =~~~~"'-"--' --"-"-- "'"',,, ""~ .,." ',-, -', .,,,"" ,~" . , __~'_, "f,'_ -, ^,' ~- 1,'1 . J" <~ ,'-'; c--;i";";,,o,,,;,.,'''''--;-m'''''-liii1~~;,; - t'-- . ,.. IN THE COURT OF COMMON PLEAS OF CUMBERLAND COUNTY, PENNSYLVANIA RE: COUNTRYWIDE HOME LOANS, INC. ) ) CIVIL ACTION vs. TIMOTHY S. CLIPPINGER TRACIE A. CLIPPINGER ) ) CIVIL DIVISION NO. 01-6460 AFFIDAVIT OF SERVICE PURSUANT TO RULE 3129 COMMONWEALTH OF PENNSYLVANIA COUNTY OF CUMBERLAND ) ) 55: I, FRANK FEDERMAN, ESQUIRE attorney for COUNTRYWIDE HOME LOANS, INC. hereby verify that on 12/21/01 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 12/21/01 by certified mail return receipt requested see Exhibit "B" attached hereto. DATE: April 29. 2002 ~N~AF~E~~QUIRE Attorney for Plaintiff "'j ,,;Or ;,m ~.. :-~~,~ T'; :9.;3 t-< ~ ~ - - - - o _ :;;: - '" 00 -.J S' ~Z '" W tv - 0 0, '" -"" W tv - " "' !i 00- ~O CO" '" g )> ~8, ~ '" ;:!. 0 CO " '" (;. it \0 ~ CD 00 ... Z ~ '" j<I 3 >-l C" -. CD ~ ., "'..., I- o 0 ; t;j () z Kg. ~ . < Z ~ e ~~ s:: 0 m 8, ",0 ~ ~ Cf) ~ o " >-l . 0 ~ !;- -~ 0 0'" 0 ~ alii' ~ () f:i . o R ~ " o . ~ ~ I:C ~ ~ ~ 0 ~ '" . fii ~ ~ .. ~ . ~ w "d Cf) w ~ fii 0 00 81 "'d' ~ () . () . .1l . Cf) Cf) ~ ,. o~ ~ j ~ ~ ~~ Cf) S -!!-~ >-l '" () .~ m ~ ! ~ ~ ~ ~ 0 0 ~ ~ ~ - () .", Cf) ~ ~ 0 J;; <' 0 ~. 0 ~ ~ .>< Cf) - ~ -.J - ~~&~i( ! 0 w - 0 Z w ~~a8~ >rJ 0 ;:;n~5lg- ~ ~ . il _~ 0 ~ ~ = :><~. ;- '" 0. s' .g. p! ~ sa, 6 g' Cf) ~ ~ .... ...(,0'>...., 0 ~ 3>g.g5"'" :.. (1l ~ 51 ~ 0 ".g 0 (1l a- m "d tii iL.8'llo .>-l 0 S~'d ::t.";' g.'O ~ ~rt () I:C ~ iil ~ g ~~ 0 0 Cf) 0' no.' ~ ~ ~ ~~~go. ~ :i'.~ 3 g '" 0, tyj' !!l N(1l g I>' -.J l>> ~v.;.., /;j = .'" .>-l ~o::r[o. J~ . 0 (II 0 i ~ ~ ~ ~ ~ @ s' ~ g. ~ ~'S ~ [ g... ~ ,S- ~ Cf) Cf) [~s::~ I:C t-< il ~ ~il .~ JT1 _. .o.::t, -"" "d r-< 00 :>- .'d~. -.J g. - tv ~ - .... '-<:: n 0 -.J :!i.g;a~. - 0 So (II n g - - .g g 8 n -.J w ::to tI1 ~ 0. - ii ~ [ --,. .P ~.~ g.;..., - - . S::l:lif , ~, ~ ~ilil "~ . '. .. ('I Ii g 3 ~ ?:!. ... . OE~4jl~ .' '1\1, I~~ ~ a ~ ~ g ::r (1l. tDEOZI'OI~jy7~~1 tJ.S.paSTA~ tl g Iii ... '.. ~1.\\ gt o&.t;;6. ~W~on 0... ..... .h r..4~ ~ . il 0 ~ '"PJ;. . ':';';"1::: I .0 (I :;:;.. tl~ u~ ::to 0 . n 5 ~~ ~::> 8-g _.:-- 6068360 .- :::.:g'g'p;i . s:: -.... 0- ~ . 'd- I J>> ...('0 ~ g 3' I I . - 0" I I .' " ~, ~'" ~ " ',' ~ ~~~ -""'" ~-~-" o>z """"., 00""3 .. .. .. == ~ ~ ~~= .. "" " '"O-O"r1 e: ~::J tI1t;1 -,," '" '"Om i~~~ l'S' "r1 (J . . " '"O~a~ >g'l -:; '" \0,,- -""00 0.... .(::.--tc1 Y'o;,tr'gJ -o~r< ~E.g'> ~~PZ '-<l!lOO [p. g. "'dr/18 .. '" = _. -ft C'l_ e!...,. -0 J8 co =- .. " ... - , " 'S ~ ~ ."~ --,",- 7160 3'ID1,81f1f b532'ObDD TO: TIMOTHY S, CLIPPINGER 338 C STREET CARLISLE, PA17013 SENDER: REFERENCE: JPG SALES(CLIPPINGER) I ,; PS-Fonn 3800 June 2000 RETURN Postage RECEIPT Certified Fee SERVICE Return Receipt Fee Restricted Delivery Total Postage & Fees I i I I J I J No lnsuranc~ Coverage Provided I Do Not Use for International Mail I ,__"___m_________.__________.m___m.m-------------------'-----------------------------i I I , I US Postal Service Receipt for Certified Mail I I i I } TO: J, ~' ,,-,<, ,,-',- "~--"",;:,= '- - '11 ';~"yt;,,;j 71bO 3'01 '!BIIII b532 Obb2 TRACIE A. CLIPPINGER 338 C STREET CARLISLE, PA 17013 JPG REFERENCE: SALES(CLIPPINGER) . -~-- - --,-- u un _._.._____ ____n._ b __n u _n_. SENDER: PS Form 3800 June 2000 RETURN Postage RECEIPT ' SERVICE Certified Fee 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 ---.---_.--~--;-q,.-----~-.,._._-~ '----" -- - -- ,--' -- " 't~~~~l'~~~W':\iil..""H'h,ulij0~ldt~'$<!ll;..,-'!!~d'~'''i'''' ''_'''is';;';,;-~2,",h ~!"r,.,~;;,,;c;,;1M&.w~~,ii~ --~""Wl'~~ ~~.~ .'~ ~. .~ " .~, '" "~'-'- o ~~ -Or.::: rnJ-, -7-'- ~-- --"- L_C (n_~ -<"'- ~g 2: ::J " ~H."~IIS.__ C') r',.) ~. -~... .:-~:<<' ..,,,.:;: I r..,) -~:'i --I" :n ..-I ~'r ..' ~~ ~ -, cs g4 - k ,_. ~~...... -, ,-,"-;.",~' ,/ ~""'i STATE OF PENNSYLVANIA, COUNIY OF CUMBERLAND } 55. Robert P Ziegler I, ______________________________________________________________________________ilecorderof Deeds in and for said County and Slate do 'hereby certify that the Sheriff's Deed in which ________________ Countrywide Home Loans Ine --------------------------- .-----"-------------- -------_____________________________ is the grantee 5th the same having been sold to said grantee on the ------____________________n_____n_n_nn____ day of June 02 --______________________________________ A. D., r ___n' under and by virtue of a wriL_____n______ 31st Execution . --------------------------------- ___ - ____ -_ _____ ISSued on the ___________ _____ ____ ____ __n____ __ ___ December day of __________________________ A. D., 01 . -----, out of the Court of Cornman Pleas of said County as of Civil 01 ------------------------------...-- ----- ----- - ---- -- -----__ --___________ __ ____ __ ___ Term, : '6460 Countrywide Home Loans Inc Number --------------, at the suit of --- ---_______________n_______n_______________________n_n___ Timothy S Clippinger & Tracie A -------------------------______ __ __ against_ ___...... ____ _______________ ______ __ __ __ __ ______ _______ is 252 1618 duly recorded in Sherifrs Deed Book No. _________n_' Page ___n_______. IN TESTIMONY WHEREOF, I have hereunto ~ setmpJand and seal of said office this ~_____ day of ~/l~~------- ------ Q .- ci?_ --7ft>>- ---~ ------- --- ~,o~""'-"'''''''~ ..~ _. .....'"~; l~v.J ~ ~- . " "~ " ~;;;, ~, "'I:" ' - " -~ 1 lm,'1-,~J""~",'", . , Countrywide Home Loans, Inc. VS Timothy S. Clippinger and Tracie A. Clippinger In The Court of Common Pleas of Cumberland County, Pennsylvania Writ No. 2001-6460 Civil Term Michael Barrick, Deputy Sheriff, who being duly sworn according to law, states that on February 25,2002 at 9:13 o'clock am, EST, he served a true copy ofthe within Real Estate Writ, Notice and Description, in the above entitled action, upon the within named defendant, to wit: Timothy S. Clippinger, by making known unto Jacqueline Skeel, mother-in-law of defendant, at 338 C Street, Carlisle, Cumberland County, Pennsylvania, its contents and at the same time handing to her personally the said true and correct copy of the same. Michael Barrick, Deputy Sheriff, who being duly sworn according to law, states that on February 25,2002 at 9:13 o'clock am, EST,he served a true copy of the within Real Estate Writ, Notice and Description, in the above entitled action, upon the within named defendant, to wit: Tracie A. Clippinger, by making known unto Jacqueline Skeel, mother of defendant, at 338 C Street, Carlisle, Cumberland County, Pennsylvania, its contents and at the same time handing to her personally the said true and correct copy of the same. Gerald Worthington, Deputy Sheriff,who being duly sworn according to law, states that on April 5, 2002 at 2:57 o'clock P.M., E.S.T., he posted a true copy of the within Real Estate Writ, Notice, Poster and Description, in the above entitled action, upon the property of Timothy S. Clippinger and Tracie A Clippinger located at 338 C Street, Carlisle, Pennsylvania, according to law. R. Thomas Kline, Sheriff, who being duly sworn according to law says he served the above Real Estate Writ, Notice, Poster and Description in the following manner: The Sheriff mailed a notice of the pendency of the action to one of the within named defendants to wit: Timothy S. Clippinger, by regular mail to his last known address of 338 C. Street, Carlisle, PA 17013. This letter was mailed under the date of April 04, 2002 and never returned to the Sheriff s Office. R. Thomas Kline, Sheriff, who being duly sworn according to law says he served the above Real Estate Writ, Notice, Poster and Description in the following manner: The Sheriff mailed a notice of the pendency of the action to one of the within named defendants to wit: Tracie A Clippinger, by regular mail to her last known address of 33 8 C. Street, Carlisle, PA 17013. This letter was mailed under the date of April 04, 2002 and never returned to the Sheriff s Office. R. Thomas Kline, Sheriff, who being duly sworn according to law, says that after due and legal notice had been given according to law, exposed the within described premises at public venue or outcry at the Court House, Carlisle, Cumberland County, Pennsylvania, on June 5, 2002 at 10:00 o'clock AM.. He sold the same for the sum of $1.00 to Attorney Frank Federman for Countywide Home Loans, Inc.. It being the highest bid and best price received for the same, Countrywide Home Loans, Inc. of7105 Corporate Drive, PTX-B35, PIano, TX 72024, being the buyer in this execution, paid SheriffR. Thomas Kline the sum of $654. 17, it being costs. "1."",-";,.."",,,,'ill-:oi!<t""~ .- Sheriff s Costs: Docketing Poundage Posting Bills Advertising Acknowledging Deed Auctioneer Law Library Prothonotary Mileage Certified Mail Levy Surcharge Law Joumal Patriot News Share of Bills Distribution of Proceeds Sheriffs Deed " =" o~ Sworn and subscribed to before me S~~ _ .....~ _ ~...c.f" This ~ day of Cf-. p ~ ~ I, R. Thomas Kline, Sheriff 2002, A.D. ~..D ~,~ P othonotary ~ !tt-A 1/~ ~;alE;~eputy $30.00 12.83 15.00 15.00 30.00 10.00 .50 1.00 6.90 .84 15.00 30.00 232.85 174.55 25.20 25.00 29.50 $654.17 paid by attorney 06/19/2002 V O.J'-' JP.tfJ , .~/Q Ut-. ~- ~ '701'/ j) 7.231 .,' ~<;~.-' ~ '"-, c' . j" MT:ll,1",,. ~,~ "',",,0 _ ",. ....'_ ~ ~. "-" ~-'" j-.,- ; ~ ,-, - ",- -'~,,, .Jtllllilj."'''\w''~',,~ COUNTRYWIDE HOME LOANS, INC. ..' . ~ CUMBERLAND COUNTY Plaintiff, v. COURT OF COMMON PLEAS TIMOTHY S. CLIPPINGER TRACIE A. CLIPPINGER CIVIL DIVISION NO. 01-6460 Defendant(s). AFFIDAVIT PURSUANT TO RULE 3129 (Affidavit No.1) COUNTRYWIDE HOME LOANS. 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 ,338 C STREET, CARLISLE, P A 17013 : 1. Name and address ofOwner(s) orreputed Owner(s): Name Last Known Address (if address cannot be reasonably ascertained, please indicate) TIMOTHY S. CLIPPINGER 338 C STREET CARLISLE, P A 17013 TRACIE A. CLIPPINGER 338 C STREET CARLISLE, PA 17013 2. Name and address ofDefendant(s) in the judgment: TIMOTHY S. CLIPPINGER 338 C STREET CARLISLE, P A 17013 TRACIE A. CLIPPINGER 338 C STREET CARLISLE, PA 17013 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. ._-,. "'~.' ""- " .l~....... " I ~ , , h8-..;''''..,,-__~ 4. Name and address of last recorded I'JOlder of every mortgage of record: Name Last Known Address (if address cannot be reasonably ascertained, please indicate) IRWIN UNION BANK AND TRUST COMPANY 500 W ASHlNGTON STREET COLUMBUS, INDIANA 47201 5. Name and address of every other person who has any record lien on the property: Name Last Known Address (if address cannot be reasonably ascertained, please indicate) None. 6. Name and address of every other person who has any record interest in the property and whose interest may be affected by the sale. Name Last Known Address (if address cannot be reasonably ascertained, please indicate) None. 7. Name and address of every other person of whom the plaintiffhas 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 338 C STREET CARLISLE, P A 17013 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 of 18 Pa. C.S. Sec. 4904 relating to unsworn falsification to authorities. December 20.2001 DATE 4~U FRANK FEDERMAN, ESQUIRE . Attorney for Plaintiff . . ,--'"~ -'" -'"~ , ' ,~- /",'" .1- ~,,>.!--",~,;,,_o'-'-~-~~-'~~f:i , . COUNTRYWIDE HOME LOANS, INC. Plaintiff, CUMBERLAND COUNTY v. No. 01-6460 TIMOTHY S. CLIPPINGER TRACIE A. CLIPPINGER Defendant(s). December 20, 2001 TO: TIMOTHY S. CLIPPINGER 338 C STREET CARLISLE, P A 17013 TRACIE A. CLIPPINGER 338 C STREET CARLISLE, PA 17013 **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 , 338 C STREET, CARLISLE, P A 17013, 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, PA 17013, to enforce the court judgment of77,480.92 obtained by COUNTRYWIDE HOME LOANS, INC. (the mortgagee) against you. If the Sheriffs sale is postponed, the property will be relisted for the SEPTEMBER 4,2002 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 if you pay to the mortgagee the back payments, late charges, costs and reasonable attorney's fees due. To find out how much you must pay, you may call: (215) 563-7000. 2, You may be able to stop the sale by filing a petition asking the Court to strike or open the judgment, if the judgment was improperly entered. You may also ask the Court to postpone the sale for good cause. 3. You may also be able to stop the sale through other legal proceedings. You may need an attorney to assert your rights. The sooner you contact one, the more chance you will have of stopping the sale. (See notice on page two on how to obtain an attorney.) ,-~""W'__='_"~ J. _ ,-- - .. ~ ~ ~~ ,~. . ~'.' ~ , - '-""''', - :^::-~--~-:>:-'jili;.; Y , 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 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 A LAWYER OR CANNOT AFFORD ONE, GO TO OR TELEPHONE THE OFFICE LISTED BELOW TO FIND OUT WHERE YOU CAN GET LEGAL HELP. CUMBERLAND COUNTY ATTORNEY REFERRAL CUMBERLAND COUNTY BAR ASSOCIATION 2 LIBERTY AVENUE CUMBERLAND COUNTY COURTHOUSE CARLISLE, P A 17013 (717) 249-3166 (800) 990-9108 . . LEGAL DESCRiPTION \ 1 / ALL .that :e:"";lln tract of land with the: lmprovemer:ts thereon situat~ In the Boroug.h of Carlisle. CJmbe:t:..:c County, ?enn~:..t'f::tnia, bounded J.nd desc:ibed as follows: ~jn the :-lor:h by "C" S:reet: on the E.ut by property now or former!y of w.rlisie "iru~t CJmpany. 0n :he: Scu::-J ~,)y p-roper::y flOW or ti.~tm~rlY of Edward Srowl1.aweH and Reb~'3. E. Browna'We!t; J.!'!d on dl~ \V~:St oy ?fOpoer::, now or formerly or S. L. Diven. Sard lot having a frontage on "C" Street of 4-3,35 feet and 0n ~he SoJutr: 0;" ':'9>'.}) feet. and J depth of iOl.40 feet and being made up of ru"..s of LotS ~05. 3-:'" ;md 38. Sfc-ck l~, of ::-::.: CarUsle Land and Imprcve'mem Company, and being known J.~ 338 "C" Street. C:tiiiSle. PennsY('I,ar.i..L BEL'l'G the sarr.e premises which ib.ymond C. Bobh 'r: i.i..~d Deborah ,\. Bobb. his ,.;.,tfe. by ~'1~lr De:!j L~J.rec November 3, 1994 and recorded November 4, 1994 in the Office of the Recoreer of Deeds of Cornoer!:!r.c County in DeedBoak tl4, Page 563, grant"" and conveyed unto John A. Bobb, single man. Gramor here:;l. ~~. ""'"'-~-""'-- ~"-"'~!i>iL 6o^"~"----~ff~" 'l !~~__'_~'o_ "l!!o.~i!f.'" WRIT OF EXECUTION and/or A IT ACHMENT . . COMMONWEAL TH OF PENNSYLVANIA) COUNTY OF CUMBERLAND) NO. 01-6460 CIVIL 19 CIVIL ACTION - LAW TO THE SHERIFF OF CUMBERLAND To saltsfy the debt, interest and costs due --CGUII-~'; ,,<> COUNTY Home Loans, Inc. PLAINTIFF(S) from Timothy S. and Traci A. elippinger, 338 C. St., Carlisle PA 17013. (1) at.338 DEFENDANT(S) You are directed to levy upon the property 01 the defendant(s) and to sell Real es taeel.iboeaeed Cst., Carlisle PA 17013. (See attached legal description.) (2) You are also directed to attach the property of the defendant(s) not levi~d upon in the possession of GARNISHEE(S) as follows: and to notify the garnishee(s) that: (a) an attachment has been issued: (b) the gamishe,e,(~l islareenjoined from paying any debt to or for the account of the defendant(s) and from delivering any property bf the defendant(s) or otherwise disposing thereof; . (3) II property of the defendant(s) not levied upon an subject to attachment is foun<Hn the possession of anyone other than a flamed garnishee, you are directed to notify himlherthat he/she has been added as agarnishlle and is enjoined as above stated, Due Prothy Other Costs $.50 $1.00 Amount Due $77,480.92 Interest 12/20/01 - 6/5/02 $2,486.63 ($13.14 per d~em) Ally's Comm % L.L. Ally Paid Plaintiff Paid $119.25 Date: December 31, 2001 CURTIS R. LONG Protho otary, Civil Division by Deputy REQUESTING PARTY Name Address: Frank Federman, Esq. 1617 JFK Blvd., Ste 1400 Philadelphia PA 19103 Plaintiff 1814 AtlOrney tor: Telephone ( 215 ) Supreme Court ID No. 563 7000 12248 _.,-1,";"""""")';__"-"''-''''''''''-'':''::''''''''' ,','I.: ,,""', ,_,___ "-,,~',L'_,i~t-:dl~TI$,llt~0-'j,,,,~a:~''lI!iil~IDli&~iMli~WiMl~IJi.~~I!~lilIi.i1ill,;if&rumm;;:tmi!!!! . REAL ESTATE SALE NO.1 L On February 6, 2002, the sherifflevied upon the defendant's interest in the real property situated in Borough of Carlisle, Cumberland County, P A, known and numbered as 338 C Street, Carlisle, and more fully described on Exhibit "A" filed with this writ and by this reference incorporated herein. Date: February 6, 2002 By: Jortv S~ ReaiEs~ate Deputy ~ 5ilj .~ :~ -~.. ..;0( /J~ iJ', ':jd '. , i, " NUr All\1 :. .:U1t!~i 14:;lj 'U:1G - >~, ~ "'= "', .,,'-~ . ,) -,.-,--, .,' ;;'-~:'-).;~i\' PROOF OF PUBLICATION OF NOTICE IN CUMBERLAND LAW JOURNAL (Under Act No. 587, approved May 16, 1929), P. L.1784 STATEOFPENNSYLVANIA : ss. COUNTY OF CUMBERLAND : Roger M. Morgellthal, 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 regular editions and issues of the 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 NOli PublIc lOlSE.SNYDE~~ ' CllI1is!e 80m. c...;.- ......... 5 . , My CammIsalon.........- ........ . I _~ lU!AL ESTATE SALE NO. 12 Writ No. 2001-6460 Civil Countrywide Home Loans, Inc. VS, Timothy S. Clippinger and Tracie A. Clippinger Atty.: Frank Federman LEGAL DESCRlPTlON ALL that ceriaJn tract of land with the improvements thereon situate in the Borough of Carlisle. Cumber- land County, Pennsylvania. bound- ed and described as follows: On the North by "e" Street; on the East by properly now or for- merly of Carlisle Trust Company; on the South by property now or for- merly of Edward Brownawell and Rebecca E. Brownawell: and on the West by property now or formerly of S. L. Diven. Said lot having a frontage on "c" Street of 48.85 feet and on the South of 49.95 feet. and a depth of 101.40 feet and being made up of parts of Lots Nos. 37 and 38. Block 14, of the Carlis1eLand and Improvement Company. and being known as 338 "C" Street, Carlisle. Pennsylvarua. BEING the same premises wWch Raymond C. Bobb, l1i and Deborah A Bobb, his wife. by their Deed dat- ed November 3. 1994 and recorded November 4. 1994 in the Office of the Recorder of Deeds of Cumber- land County in Deed Book 114, Page 563. granted and conveyed unto John A Bobb, single man. Grantor herein. ---- ~- . -,;,.. .J.,:~ ~, ,: "'-0' ",_ ~'.<i. C".; ~-'2 ,,__", ;"'';-' ...~ ,-,' "- 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 IflJL, Patriot:News and..IbJl S,unday PatriQ.t:-.~ newspapers of generai 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 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 inferested in the subject matter of said printed notice or advertising, and that ali 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 duiy 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 1112 __._~:-- ~<_J ~~~ --:-,....-. '~""~-"';l~...A/1 '~.;,yP';:...- v' /.~~~.........~::~~~~~~..--........... ..~~j;~;~~.~ft.~~ip.~:.. " Terr;l.Ru..,II,NotatyPubllc _.' ( "/ .':. ).. -~ -'r" "o'r-::C.____'-( HarTIsburg. Dauphin County' , .......__ My Commission Expires June 6, 2002 NOTARY PUBLIC Member, Pennaylvania Association of Notari commission expires June 6, 2002 i'!'IEAL ES1ATE SALE ~. 12 . . . Writ No. 2001,6460 Clvllrerm Cqon1rywlde Home lOll"" Inc. VI Tlmothy S. Clippinger and '" 'li'acre A. Clippinger . . Ally: FmaIc Fedarman DESCRIPJ'lON ALL : ita!. certain tmct of lal1_d with the hnjlrpY~DlS thereon situilte _in the_ Horou,gh of t:-:-CadiSJ~,., - Cun:(tierlIDid:_ _County, Pet:Ul~y1v-.mia. (:~_aad deSCriOOJ_1iS fr.dlo~s: On !be North by "(" Street; "n the ",,' by 'Property now _()t formerly of Edward Brownawel1 .uw_Rebec-ea E. Brownawel); and on the West.bv p~ -no,", ..or_ tCItiierlY SL. :t)jv.en. Said lOt b,",~_A frontage on ,"C' 1:I'treet of 48,85 feel and 'onJhe_Suuthot49.95 feet._ imd~.:depth of 1Ol.40[eet-and being made: up of p$fi _of LOts NQS. 37 ami J8,_Block 14, of l&e -CarlIsle _ La_n4 and Improvement Company, and beIn,f:Kl1Own llli 338 "COO, Street, Carlisle. f'eii;iS.ylvania, . >>~G Ihe ~me t"emhes WIDen Raymond C_ Rnbb.lI1, and lJelxmib A. Rubb, /lis wife, by ti!eir l:Je<<I..daled NownbeI 3. 1994 in the Office uf the ~r of Deeds. of Cumberland County_ in ~JJook 114. Page %3, granted and conveyed unto John A. Bobb. !ill1g1e man, Grantor !Jereln. CUMBERlAND COUNTY SHERIFFS OFFICE CUMBERLAND COUNTY COURTHOUSE CARLISLE, PA. 17013 Statement of Advertising Costs To THE PATRIOT-NEWS CO., Dr. For publishing the notice or publication attached hereto on the above stated dates Probating same Notary Fee(s) Total $ $ $ 172.80 1. 75 174.55 Publisher's Receipt for Advertising Cost , publisher of The Patriot-News and Il1ft..~undav Patriot-News, newspapers of general e receipt of the aforesaid notice and publication costs and certifies that the same have By...............on..................................................