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HomeMy WebLinkAbout01-06493 _c,,,..l~, '" ,. ~" ''-j ,r - ~ "'~, '-'--; "'i'~~ ~i'Ji.i:~:'-: ~ ~ ~ FEDERMAN AND PHELAN, LLP By: FRANK FEDERMAN, ESQUIRE IDENTIFICATION NO. 12248 ONE PENN CENTER AT SUBURBAN STATION 1617 JOHN F. KENNEDY BOULEVARD SUITE 1400 PHILADELPHIA, PA 19103-1814 (71 'i) 'ifi,-7000 ATTORNEY FOR PLAINTIFF COURT OF COMMON PLEAS CNIL DNISION WELLS FARGO HOME MORTGAGE, INC., FIKIA NORWEST MORTGAGE, INC. 5024 PARKWAY PLAZA BOULEVARD CHARLOTTE, NC 28217-2407 TERM Plaintiff Q'C:;ll/~ v. NO. DI - 1..4Q3 CUMBERLAND COUNTY DARRELL R. GORDON EDITH L. BROWNA WELL 431 MOUNTAIN ROAD NEWVILLE, P A 17241 Defendant(s) CTVIl. ACTTON - l.A W COMPT,A TNT TN MORTr.Ar.F, FORRCT .OSTTRF, 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 THIS PAPER TO YOUR LAWYER AT ONCE. 1F 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, P A 17013 (717)249-3166 Loan #: 3104048 .It.. -"" -, , "",,= "~. ~ o ~ -; "I, . : j 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 V ALInITY 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, ", }'. .- ,,~ ,,,,, ,; ,~v,: "',:~, 'I- t -" > '0 " . . . .,. ~." ,',- '-,~ ,,~,'" - I'~' 1. Plaintiff is WELLS FARGO HOME MORTGAGE, INC., F/K/ A NORWEST MORTGAGE, INC. 5024 P ARKW A Y PLAZA BOULEVARD CHARLOTTE, NC 28217-2407 2. The name(s) and last Imown addressees) of the Defendant(s) are: DARRELL R. GORDON EDITH L. BROWNA WELL 431 MOUNTAIN ROAD NEWVILLE, P A 17241 who is/are the mortgagor(s) and real owner(s) of the property hereinafter described. 3. On 05/30/95 mortgagor(s) made, executed and delivered a mortgage upon the premises hereinafter described to CONSUMER FIRST MORTGAGE, INe. which mortgage is recorded in the Office of the Recorder of CUMBERLAND County, in Mortgage Book No. 1264, Page 1038. By Assigmnent of Mortgage recorded 05/30/95 the mortgage was assigned to PLAINTIFF which Assignment is recorded in Assignment of Mortgage Book No. 497, Page 114. 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 06/01/01 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. ,~'__'d''''__ ~~~........~ . .,.., 01-',:"11 . , ,-,~w -~"- \l~--_ ;lf~A:~' 6. The following amounts are due on the mortgage: Principal Balance Interest 05101/01 through 11/01/01 (Per Diem $20.43) Attorney's Fees Cumulative Late Charges 05/30/95 to 11/01/01 Cost of Suit and Title Search Subtotal Escrow Credit Deficit Subtotal TOTAL $8],736.12 3,779.55 1,250.00 163.60 5..iOJl{) $87,479.27 0.00 5.3.1Ji8. ~ ';17 IlR $88,016.95 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 = Judgment against the Defendant(s) in the sum of $88,016.95, together with interest from 11/01/01 at the rate of $20.43 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;:,/ Fr~nk F~il~rm~n FRANK FEDERMAN, ESQUIRE Attorney for Plaintiff -, ~ ~ ~ :~- ,1_') I _ "_ -- ~ ,,' <-" ,- '- '';'':~' - ",~ ..~~,;"~:,-",,, "f'" ALL THAT CERTAIN tract of land situate in Lower Mifflin Township, Cumberland County, Pennsylvania, being Lot #4 of a Subdivision of Samuel D. Shenk, as set forth in Plan Book 60, page 113, more particularly bounded and described as follows: BEGINNDIG at a set railroad spike situate on the centerline of Lower Mifflin Township Road T-383, also known as Mountain Road, said railroad spike being locatBd south 86 degrees 59 minutes 31 seconds West 75.46 feet from an existing nail and washer situate on the centerline of said Mountain Road; thence along other lands now or formerly of Samuel D. Shenk, South 08 d~grees 33 minutes 05 seconds East 286.76 feet to a set iron pin; thence along other lands now or formerly of Samuel D, Shenk, North a8 degrees 17 minutes 22 seconds West 357.44 feet to a set iron pin; thence along lands now or formerly of Samuel D. Shenk, North 02 degrees 11 minutes 19 seconds East 257.07 feet to a set railroad spike on the centerline of Mountain Road; thence along the centerline of said Mountain Road, North 86 degrees 59 minutes 31 seconds East 305.24 feet to a set railroad spike, the Place of BEGINNING. CONTAINING 2.0547 acres of land including the right-of-way area. BEING the same premises Samuel D. Shenk and Barbara husband and wife, by their deed dated the 30th day of and recorded in the Office at the Recorder of Deeds, Cumberland County, Pennsylvania, in Deed Book , granted and conveyed unto Steven L. Shenk and Tammy husband and wife, the Grantors herein. J. Shenk, June, 1990, in and for Page , s. Shanle, TOGETHER with all the buildings, improvements, ways, streets, alleys, passages, waters! water-courses, rights, liberties, privileges, herediments, and appurtenances whatsoever, thereunto belonging or in any way appertaining and the reversions, the remainders, rents, issues and profits thereof, and all the estate, right, title, interest, property, claim, and re~and WhatsoeVer of the sqid Grantors, in laW, equity, or otherwise howsoever, of, in, to, or out of the same. And the said Grantors hereby covenant and agree that they will warrant specialLy the property hereby conveyed. PREMISES: 431 MOUNTAIN ROAD " ,t_ I~, ,j "'~ ,,~' ",', "mt~M_s. .( . . VERIFICATION TAMMY JOHNSON hereby states that she is ASSIST ANT VICE PRESIDENT of WELLS FARGO HOME MORTGAGE, INe. rn0l1gage servicing agent for Plaintiff in this matter, that she is authorized to take this Verification, and that the statements made in the foregoing Civil Action in Mortgage Foreclosure are true and correct to the best of her knowledge, information and belief. The undersigned understands that this statement is made subject to the penalties of 18 Pa. C.S. Sec. 4904 relating to unsworn falsification to authorities. DATE: \-Wl\ 0\ - ;~~~'ft;~:I'J,:!j-,'i'l~"ilidi:-':~~ii""0I,"n,li<hii,';:~Y-'-",1h:!!"',<d'"",,.j,,,,,,, ~,;-'<h ";~,""",,,~?,j'';:''''>'1,,~:ihQd\;~l!ilfj~~1ID~ih~~ ~ "~ ,-<.;.',- "IiiIi,.. -'"" ..-' . . '). "JO ~ ~ ~ 1L (') 0 ('} C '. - !'19 s % r- B -om 0 " 9 ~ :::::- 8 a mrT; ."..,.: t,~ C/} Z~:r) ~ zc,:; t.r, -~~;d t W I I ~";~ t)).., ~ t ~C) ".( \&", f: ~ -u ~r: -Ti :Pc J~ '. ) c'" z-:' b~ ....u s::: l- )>c -I t z ~) ~ ::< {TI -< '-( .iJ4..L Il~L. ... J"~"__" ",0 ,,^,, e"~",,,,> "-'" ,,,,",_,=~,,," ,_ w=, " "~ .,',.' ~-'>Jf1;{iJililli,;" -~ .~~~ '''"'''__,..m&i'" oIaI-.-,.......' ~,". I' , . ~. '-~~... ""'~, ",J..- .~... ~'!I.:d" u ~""""! a ~"-'t:ti1i:lllK~~",.__d j . SHERIFF'S RETURN - REGULAR CASE_NO: 2001-06493 P COMMONWEALTH OF PENNSYLVANIA: COUNTY OF CUMBERLAND WELLS FARGO HOME MORTGAGE ETAL VS GORDON DARRELL R ET AL 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 GORDON DARRELL R the DEFENDANT at 1859:00 HOURS, on the 30th day of November, 2001 at 431 MOUNTAIN ROAD NEWVILLE, PA 17241 by handing to DARRELL GORDON 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 6,50 .00 10.00 .00 34.50 ?,~n'~~~ R, Thomas Kline 12/03/2001 FEDERMAN & PHELAN me this /3 te day of Sworn and Subscribed to before By: Atn_L, c20<r1 A.D. ~o.~L~ rothonotary , ,"l~'-'" ,- -'.~ "" I,~,,:. i~ j ~. .J.lif~ ,>~" ^ '- ~ ,$tM,,""!W:' . r , . . SHERIFF'S RETURN - REGULAR . CASE NO: 2001-06493 P COMMONWEALTH OF PENNSYLVANIA: COUNTY OF CUMBERLAND WELLS FARGO HOME MORTGAGE ETAL VS GORDON DARRELL R ET AL 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 BROWNAWELL EDITH L the DEFENDANT , at 2038:00 HOURS, on the 30th day of November, 2001 at 14 BETTY NELSON TRAILER PARK CARLISLE, PA 17013 by handing to EDI TH BROWNAWELL a true and attested copy of COMPLAINT - MORT FORE together with and at the same time directing Her attention to the contents thereof. Sheriff's Costs: Docketing Service Affidavit Surcharge So Answers: 6.00 3.90 ,00 10.00 .00 19.90 r~:-1~~ R. Thomas Kline . 12/03/2001 FEDERMAN & PHELAN Sworn and Subscribed to before By: ~~ ~ Sheriff me this /.3t. day of f...tu~jLl" o2/YOl A.D. ~~ Q. M<d<.-.~ prothonotary j~lf';" ,}n~il&~,;;<j;j,jv';;":di;,;h~H c'oo~.ITlo'*'_"~ ,;~:i; 41'jf"hi.""~I~oik;F.i<IIl-'-,"'''''ih\;\,, ':mifti:J",Hd;,'fdffilr9';~i,* \,~,j'>i-:,,~;j",,'L~Mlj;;ltilr:i&i~ii~IiJ;,:;ri~i~W~~~ ~ ~'il!Ji1.Mati ~litail - ,_ ,',~,"',"~">:"'~l"""'~,",,, "" '~p ,~" "~~. - ",,-, -lIl:.r"'-=""~' ~~~j Bil!:: J." I- o~ 13// ;;:~ , "" ."'~ . ~-'-'"- ,- -~"'"~ ~".~, -"~'~ , " ~....... ",,",",,'^" - -~--'"~"l'iI1~-':~;; , 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 WELLS FARGO HOME MORTGAGE, INC" FIK/A NORWEST MORTGAGE, INC, 5024 PARKWAY PLAZA BOULEVARD CHARLOTTE, NC 28217-2407 CUMBERLAND COUNTY COURT OF COMMON PLEAS CML DMSION Plaintiff, v, NO. 01-6493 CIVIL TERM DARRELL R. GORDON EDITH L. BROWNA WELL 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 DARRELL R. GORDON and EDITH L. BROWNA WELL, 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 11/01/01 to 01/16/02 TOTAL $88,016.95 $1,573.11 $89,590,06 I hereby certify that (1) the addresses ofthe Plaintiff and Defendant(s) are as shown above, and (2) that notice has been given in accordance with Rule 237.1, copy attached. ~J iJ FRANK FEDERMAN, ES"QUIRE Attorney for Plaintiff DAMAGES ARE HEREBY ASSESSED AS INDICATED. . k} ~ DATE: ~ h. \. n ;;l.o:;' ~ ~ 7/.$/ \ ( PRO PROTHY *""'. >,~' V'__ ~ ,... ~ -, ,1~, ,..;"",. , .,~"'~~ . -- (Rule of Civil Procedure No. 236) - Revised , IN THE COURT OF COMMON PLEAS OF CUMBERLAND COUNTY, PENNSYLVANIA CIVIL ACTION - LAW WELLS FARGO HOME MORTGAGE, INC" FIK/A NORWEST MORTGAGE, INC. 5024 P ARKW AY PLAZA BOULEVARD CUMBERLAND COUNTY COURT OF COMMON PLEAS CIVIL DIVISION Plaintiff, v. NO. 01-6493 CIVIL TERM DARRELL R. GORDON EDITH L. BROWNA WELL Defendant(s). Notice is given that a Judgment in the above-captioned matter has been entered against you on J:0 '7 200l.. ~y: dO? (/"P (5j~ DEPUTY If you have any questions concerning this rnatter, please contact: FRANK FEDERMAN, ESQUIRE Attorney for Plaintiff ONE PENN CENTER AT SUBURBAN STATION 1617 JOHNF. KENNEDY BLVD., SUITE 1400 PHILADELPHIA, PA 19103-1814 (215) 563-7000 "THIS FIRM IS A DEBT COLLECTOR 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.' . '..........."",""""""'" '''IV'If',.,J. _PiJilo.- I ' ",'''~ , , J "' Lo;'~ ' >,' ,- .:..' _"',' ,"" "-~'_$tillllib-0,~;,:; , FEDERMAN AND PHELAN '~ Frank Federman, Esquire Identification No. 12248 One Penn Center Plaza at Suburban Station, Suite 1400 Philadelphia, PA 19103-1799 (215) 563-7000 ATTORNEY FOR PLAINTIFF COURT OF COMMON PLEAS WELLS FARGO HOME MORTGAGE, INC., F/K/A NORWEST MORTGAGE, INC. Plaintiff CIVIL DIVISION CUMBERLAND COUNTY vs. NO.01-6493 CIVIL DARRELL R. GORDON EDITH L. BROWNAWELL Defendant TO: EDITH L. BROWNAWELL 431 MOUNTAIN ROAD NEWVILLE,PA 17241 DATE OF NOTICE: DECEMBER 21,2001 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, P A 17013 (717) 249-3166 k<k.{ ~<-c>- Frank Federman,Esquire Attorney for Plaintiff - '"",". ~'m''It'.~ ,- ~'..........__.........._,., '-,',< ..-'.1 _ '.""",.:,',J'.' '~: . 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 WELLS FARGO HOME MORTGAGE, INC" F/K/A NORWEST MORTGAGE, INC. Plaintiff CIVIL DIVISION CUMBERLAND COUNTY vs. NO. 01-6493 CIVIL DARRELL R. GORDON EDITH L. BROWNAWELL Defendant(s) TO: DARRELL R, GORDON 431 MOUNTAIN ROAD NEWVILLE,PA 17241 DATE OF NOTICE: DECEMBER 21,2001 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, P A 17013 (717) 249-3166 .~,>~ )cI~ Frank Federman, Esquire Attorney for Plaintiff """" It:;......' "~"'-~~~'"'>" --~-,~,,'- ,~, "..~ I, ~ , _I.~". . ,~ . ~~'-'~ -.", " :.ii{Jijrnlf~",j ." FEDERMAN and PHELAN '. By: FRANK FEDERMAN Identification No. 12248 ONE PENN CENTER AT SUBURBAN STATION 1617 JOHNF, KENNEDY BLVD" SillTE 1400 PHILADELPHIA, PA 19103-1814 (215) 563-7000 ATTORNEY FOR PLAINTIFF . WELLS FARGO HOME MORTGAGE, INC" FfKlA NORWEST MORTGAGE, INC. 5024 P ARKW AY PLAZA BOULEVARD CUMBERLAND COUNTY COURT OF COMMON PLEAS CIVIL DIVISION Plaintiff, v, NO,OI-6493 CIVIL TERM DARRELL R. GORDON EDITH L. BROWNA WELL Defendant(s), VERIFICATION OF NON-MILITARY SERVICE FRANK FEDERMAN, ESQUIRE, hereby verifies that he is attorney for the Plaintiff in the above-captioned rnatter, and that on information and belief, he has knowledge ofthe 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 DARRELL R. GORDON is over 18 years of age and resides at, 431 MOUNTAIN ROAD, NEWVILLE, PA 17241. (c) that defendant EDITH L. BROWNA WELL is over 18 years of age, and resides at , 431 MOUNTAIN ROAD, NEWVILLE, PA 17241. This statement is made subject to the penalties of 18 Pa. C.S. Section 4904 relating to unsworn falsification to authorities. {~ FRANK FEDE , ESQUIRE Attorney for Plaintiff '1~~j(~jj~,iij>;~~t:"*,li"".l',W,'Ji1Cl'l.~%t*",~,,(i(i~\,,<,;t",,,;,;,~~-,1"'';'''iJiX,:,,",.fH-;t;'kl;~'\l~I!+t:m'' ,~~-~ ~~~n~t'."",~,,~- ~-~ ~ "If'" ~"1liII -11;-'. .' . ". . ~ffi ~ <(l ~ 7V (0 ~ t- ..() 0 CJ t e f"'-.' 0 - , -c'-,- ::,;. n"II' -,--~ - C> :-7-~ r- ....... .......... L: ~ 'iJ --J ~ 2~;,- ~ :.:::--\...-" u j \J -V ~p "-' r: . , 0..:: rv 0- -....) ~. (.'.) )< ,... =< (=:I :::0 fV)- -< ~ n . r--, ~ ~~ o ~"-~--< "<~ ,"_, ,~=," ^~, -. '- ~-~- -,.......,~ ~ ^~ ~._ i - ,I. ~ilI:ilWlj.~~ " ~ "',.'" , "., ~r ,,'i ~.\WliJ!I,-""","I,c ,flit, ~" ,.~ WELLS FARGO HOME MORTGAGE, INC., FIK/A NORWEST MORTGAGE, INC, CUMBERLAND COUNTY Plaintiff, COURT OF COMMON PLEAS v. CIVIL DIVISION DARRELL R. GORDON EDITH L, BROWNA WELL NO,01-6493 CIVIL TERM Defendant(s). AFFIDAVIT PURSUANT TO RULE 3129 (Affidavit No.1) WELLS FARGO HOME MORTGAGE. INC.. F/K1A NORWEST MORTGAGE. 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 .431 MOUNTAIN ROAD, NEWVILLE. PA 17241, 1. Name and address ofOwner(s) or reputed Owner(s): Name Last Known Address (if address cannot be reasonably ascertained, please indicate) DARRELL R. GORDON 431 MOUNTAIN ROAD NEWVILLE, P A 17241 EDITH L. BROWNA WELL 431 MOUNTAIN ROAD NEWVILLE, P A 17241 2. Name and address of Defendant(s) in the judgment: DARRELL R. GORDON 431 MOUNTAIN ROAD NEWVILLE, P A 17241 EDITH L. BROWNA WELL 431 MOUNTAIN ROAD NEWVILLE,PA17241 3. Name and last known address of every judgment creditor whose judgment is a record lien on the real property to be sold: Narne Last Known Address (if address cannot be reasonably ascertained, please indicate) None. -'-~~~.. -, c"'_ l,~ Hill' ,.,"'," L-', l, ~!Iiti"''''"'';'- '" p..' " ... 4. Name and address oflast recorded holder of every mortgage of record: Narne AMERICAN GENERAL FINANCE, INC Last Known Address (if address carmot be reasonably ascertained, please indicate) 6 SOUTH HANOVER STREET CARLISLE, P A 17013 5. Name and address of every other person who has any record lien on the property: Name Last Known Address (if address carmot 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 rnay be affected by the sale. Name Last Known Address (if address carmot be reasonably ascertained, please indicate) None. 7. Name and address of every other person ofwhorn the plaintiff has knowledge who has any interest in the property which may be affected by the sale: Name Last Known Address (if address carmot be reasonably ascertained, please indicate) Tenant/Occupant 431 MOUNTAIN ROAD NEWVILLE, P A 17241 Domestic Relations of Cumberland County 13 North Hanover Street Carlisle, PA 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 rny 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 16, 2002 DATE ~~~, tL FRANK FED RMAN, ESQUIRE Attorney for Plaintiff !J:'I]"m~t!j''-'\.~);;:';>'-'--~:.B;i~u~~_~J'l'~~&'~,'" .~ .~ - ~:i1>' ,""'"')jl'<;:";""<'~'i)A~\i\~lN~~~'" ~'iiMll~~ .. ==.'," ~,-, .J "",,,ctdililiiil ~ ,rt () C <:'"' ~~1 ~~-. r:;::t:_ ;l;C', ~2 ~ !:J l~..) ~, '.._J '-~ " ~'.- "~~. :-,. ,~ u :::) C0 c;::J -i' .1:. Q~ -- I',;.', ~ - J. ~-' ,-' '" -' ....~..-"'_. , ~ -;'~~~~ / . \ \ WELLS FARGO HOME MORTGAGE, INC., F/K/A NORWEST MORTGAGE, INC. Plaintiff, CUMBERLAND COUNTY No,OI-6493 CIVIL TERM v, DARRELL R, GORDON EDITH L, BROWNA WELL Defendant(s). January 16, 2002 TO: DARRELL R. GORDON 431 MOUNTAIN ROAD NEWVILLE, PA 17241 EDITH L. BROWNA WELL 431 MOUNTAIN ROAD NEWVILLE, PA 17241 "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, 431 MOUNTAIN ROAD, NEWVILLE. PA 17241, is scheduled to be sold at the Sheriffs Sale on JUNE 5, 2002 at 10:00 a.m. in the Curnberland County Courthouse, South Hanover Street, Carlisle, PA 17013, to enforce the court judgment of 89,590.06 obtained by WELLS FARGO HOME MORTGAGE. INC.. F/K/ A NORWEST MORTGAGE, INC. (the mortgagee) against you. ,In the event the sale is continued, an announcement will be rnade at said sale in cornpliance 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 Sheriffs Sale, you must take immediate action: I. 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 rnay call: (215) 563-7000. 2. You rnay be able to stop the sale by filing a petition asking the Court to strike or open the judgment, if the judgment was irnproperly 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.) U" , i- ' -"-.," ,'; - ,'"" "itoikl(l;l,iM"'~K~""'--- " "'" 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 rnay 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 arnount due in the sale. To find out if this has happened, you may call (717) 240-6390. 4. rfthe arnount 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 horne 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 "' ", ~ " . ~i '0' , ",~ ",,- ~'"'.";'~" '/"U '- Eifi'\ . "" ALL THAT CERTAIN tract of land situate in Lower Mifflin Township. Cumberland County, Pennsylvania, being Lot #4 of a Subdivision of Samuel D. Shenk, as set forth in Plan Book 60, Page 113. more particularly bounded and described as follows: - BEGINNING at set railroad spike situate on the centerline of Lower Mifflin Township Road T-383, also known as Mountain Road, said railroad spike being located South 86 degrees 59 minutes 31 seconds West 75A6 feet from an existing nail and washer situate on the centerline of said Moumain Road; thence along other lands now or formerly of Samuel D. Shenk, South 08 degrees 33 minutes 05 seconds East 286.76 feet to a set iron pin; thence along other lands now or formerly of Samuel D, Shenk, North 88 degrees 17 minutes 22 seconds West 357.44 feet to a set iron pin; thence along lands novo or formerly of Samuel D. Shenk, North 02 degrees II minutes 19 seconds East 257.0'; feet to a set railroad spike on the centerline of Mountain Road; thence along the centerline of said Mountain Road, North 86 degrees 59 minutes 31 seconds East 305.24 feet to a set railroad spike. the place of beginning. CONTAINING 2.0547 acres of land including the right-of-way area. Tax Parcel #5-0411-027 ,~~~(j,;'ifJt!I*m~j,<, ""~~JM""'L\il~"~~;_l-.MMjjfuf,:!JWt\lfkim~\d!J;~t,,,:';-'~i<il\i{oki\,b-"]!~J<!.~~IIi!~jj]jJjf~j__~. ",;. (") C :-? ~\r ;~~; 5~ ~-', -< - ',,, ~,' o tv ,.:. , tJ~ o -,-; , ::~;;,. :7C .-J .-;...1 c:? ; .~ C> ~ - ~"- ~ , . ;l........;.... - """,".' ~,- .,'..--: , liiiilii:l<<:ur-;t.o,: FEDERMAN and PHELAN By: FRANK FEDERMAN Identification No, 12248 ONE PENN CENTER AT SUBURBAN STATION 1617 JOHNF, KENNEDY BLVD" SUITE 1400 PIDLADELPIDA, PA 19103-1814 (215) 563-7000 ATTORNEY FOR PLAINTIFF WELLS FARGO HOME MORTGAGE, INC., F/KIA NORWEST MORTGAGE, INC. CUMBERLAND COUNTY COURT OF COMMON PLEAS Plaintiff, v, CIVIL DIVISION DARRELL R. GORDON EDITH L, BROWNA WELL NO, 01-6493 CIVIL TERM Defendant( s). CERTIFICATION FRANK FEDERMAN, ESQUIRE, hereby verifies that he is attorney for the Plaintiff in the above-captioned rnatter, and that the premises are not subject to the provisions of Act 91 because it is: (X) an FHA mortgage () non-owner occupied () vacant o Act 91 procedures have been fulfilled This certification is rnade subject to the penalties of 18 Pa. C.S. Section 4904 relating to unsworn falsification to authorities. 1~~ FRANK FEDERMAN, ESQUIRE Attorney for Plaintiff ,~.ar~-t,J~';ilf;l!I~gglirJ!IM,*'~1i""H,lt,j~1'I,~,;;:""";",,,i11"0l,",,~;i~1~~~~__~~iUili!'&i.. t " .~ d ~. _.< ~- n' -~~ (") s;:; < a1fr ~r:-~ '-.1,) -< r' ;s ~~- , ~~r-"\ >c: ~ ~ e, r--.--.J ....j (....) ':.) '-' ~~ ~\'\ \i;r,w ~..-~ ",I. '~;;Ji!ii!~"",-, ~~~ L ~ -,~. -. > ^~ ,,~- PRAECIPE FOR WRIT OF EXECUTION - (MORTGAGE FORECLOSURE) P.R.C.P.3180-3183 WELLS FARGO HOME MORTGAGE, INC., FIKJA NORWEST MORTGAGE, INC. Plaintiff, v, No.01-6493 CIVIL TERM DARRELL R. GORDON EDITH L. BROWNA WELL Defendant(s). TO THE DIRECTOR OF THE OFFICE OF THE PROTHONOTARY: Issue writ of execution in the above matter: Amount Due $89,590.06 Interest from 01/16/02 to 06/05/02 (per diern -14.73) $2,062.20 and Costs TOTAL $91,652.26 ~~);JU FRANK FEDERMAN, ESQUIRE One Penn Center at Suburban Station 1617 John F. Kennedy Boulevard, Suite 1400 Philadelphia, PA 19103-1814 Attorney for Plaintiff Note: Please attach description of property.No. _t.] !-lMid'~~M.i;(~,j:!~~,,'-iWi1i)r~i~~i~W!'h~m<;",,~jJ""'~"'--,"'-i'i.',',I'A"i&;"*,ji!~,.___~~~.L.o,'"""'~'~iOj><'-'-"~~lllj$r_~.ii1U --, ,~ ... ... ""'''''' N N r-r- ... ... << ~~ ~~ ...<...< ~;:$ ...<...< ~ ~~ OZ U z ~~ Z' 0 .....U ..... r-lr-l -Z ,... ZZ r-l"'< r-l..... ~ ~~ ...<>< " . ...< u .,,; ~'" ~rs z...< ZZ Or-l ~'E' Q) OZ ,...~ ~~ r-l = ~ ~~ ~ ~!e '" 1~ '" r:;.=:,... ~ Q ZZ Q) ~ - O~ OZ 0<: << ,!:J oi: ~O ,,~ Q) ~ E-< .. E-<E-< UZ r-l~ .; ~O ;~ <B ~~ S ~~ ~,... > ..<~ ~~ 4i ~ 00 0", '""~ 00 Q) ,...U =r-l ~~ ~~ ~~ go ~~ o~ ot: p., ~ Q ~ ... ... ~ 5~ ~~ r-l6 .., .., ""'''''' Q) U~ ~Z ~~ ~ ~ r-l ..... ;,; r-lr-l ~~ U '" == ~ .;;; Q) E-<~ ..<f;;:; Q) ~ - z~ .~ .....u ~ ~ ~ ,". ~"~ .'. ~."' ./1 .v,", ~'_ = ", _,", - ~, " ,~~~ - - : ~" -'I,. " w~' ~ ,I_.~ -,. .""""1",,-~,Uili,,,''''',,''':'o -, - . '\iIJ"~W'!f .4 .. ALL THAT CERTAIN tract of land situate in Lower Mifflin Township, Cumberland Couney. Pennsylvania, being Lot #4 of a Subdivision of Samuel D. Shenk, as set fonh in Plan Book 60, Pa2e 113, more particularly bounded and described as follows: BEGINNING at set railroad spike situate on the centerline of Lower Mifflin Township Road T-383, also known as Mountain Road, said railroad spike being located South 86 degrees 59 minutes 31 seconds West 75.46 feet from an existing nail and washer situate on the centerline of said Mountain Road: thence along other lands now or formerly of Samuel D. Shenk, South 08 degrees 33 minutes 05 seconds East 286.76 feet to a set iron pin; thence along other lands now or formerly of Samuel D. Shenk, North 88 degrees 17 minutes 22 seconds West 357.44 feet to a set iron pin; thence along lands now or formerly of Samuel D. Shenk, Nonh 02 degrees 11 minutes 19 seconds East 257.07 feet to a set railroad spike on the centerline of Mountain Road; thence along the centerline of said Mountain Road, , Nonh 86 degrees 59 minutes 31 seconds East 305.24 feet to a set railroad spike, the place of beginning. CONTAINING 2.0547 acres of land including the right-of-way area. Tax Parcel #5-0411-027 , "-"-'il~~iliifi~~-- :~''; .- ,a,U>"'(""'-'-' -<w-jrt'J~(.\i,,..Ulr~e.\::lt,,,~,1~'fl'0iJ*~.l!~b<ib--,,:ij,""'''',,,,,,,,k,:,,W:'ji,;"'l;;i;1j!l',,Jl(k____~ < <- -"''^'i@lt < ~ ~ ~ ..... Iv ~ "s- f'" ...... ~ -<- () ~ ...... ...0 ~ ~ ~ .....(I:) C; d , .c: , 0 0 (~) ?i "i & 0 ..() VJ ~ c; & & c I':, '"T, \) () "~ I'._ G c 92$ ,,'.',-> I ..... I I ~~ ~S~ VV ......... f [) I --1 ?1 0(, ~ ~ ~~r) -0 , ~ ~ , , ;, --- , "-.J ~ , ':::"" ,I ,.J>(~ :..J t,,) 7V - ?5 , ~ ::".) "-J -~,t ~ .... . --< r~ , '"\ . -< ~ .... ',-"'-,"'~ _.,,",'"~~_ _"",<"-"J,, "L'_ ~~'_'" ^,"~ '''^,<, '.~,f"""" ,,", ~ = ~", 0,.. _~~"~~" ,~ ~ , _: . a.. ~~ - --~~ - ~ ~ ~ . I J .-.i...' -...._~~ ~ ~~_ ~''"_ ' '0 'S'j~'i!ig; " AFFIDAVIT OF SERVICE J1'(r PLAINTIFF , CUMBERLAND COUNTY WELLS FARGO HOME MORTGAGE, INC" F/KJA NORWEST MORTGAGE, INC. No.01-6493 CIVIL TERM DEFENDANT(S) DARRELL R. GORDON ACCT. #3104048 EDITH L. BROWNA WELL SERVE EDITH L, BROWNA WELL AT 431 MOUNTAIN ROAD NEWVlLLE,PA 17241 Type of Action - Notice of Sheriff's Sale Sale Date: JUNE 5, 2002 SERVED Served and made known to ;: c!... "^ l. t3 It. " tJ ~ "'" ILl) , Defendant, on the ,;J {9 ,f~ at ?: '!, (, ,0'c!ockA.m., at 1-:3 ( J4lJvt'~; " K' 4) VII. W v, (/ ~ dayof ~"'u""'(,2003 , Commonwealth of Pennsylvania, in the manner described below: Defendant personally served. , b f .L X Adult family member with whom Defendant(s) reside(s). Relationship is Co - Ill'" ; t'3 IV,- 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. ~(\~t.1t It G-01<- ~ov Other: r rf ~ Description: Age 1!) Height ~ Weight! ,jrf Race Jtfl Sex L Other ~ )",.,S<:" 5" !, C!oo/tel\lc.. l. (',.If, \'( (f~ competent adult, being duly swom according to law, depose and state that! personally handed a true and correct copy of the Notice of Sheriff s Sale in the manner as set forth herein, issued in the captioned case on the date and at the address indicated above. TIMES OF SERVICE ATTEMPED, Swom to and subscri.ll.ed before me this ~ day of -5,,,..,,.( .200.2- Notary:<c.4~in b\.-0..M.u0 By: PLE'uE ATTEMPT SERVICE AT LEAST 3 TIMES, INDICATE D 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 One Penn Center at Snburban Station 1611 John F, Kennedy BonIevard, Suite 1400 Phih.delphia, PA 19103-1814 (215) 563-7000 /\? ~ 1-.)" -'. , ,t~~<j!i~~Ji'~;9.:'!;'~~i!-!b&~:l!tf.\H~~~,,"li~kSi!,~~:,",_,"",'!!,"l'l.:Ht8~m.~\~fi''!;:~''''\l,ili!.~iLi';W~r.mtlit~ilIl,~~'iW~;.ffi"",I.., , --, ~ " ",", q 110 "'..' - )t 0 0 CI c: f-,,) -,: .".,.. -0 ~ --" ,-',' 01 rn iT: GJ :D ~t,; (~ ~,J,:" en _.----~, ,-,,~ r,;.:c: ~v :r> [; .. ~- ~._. (~ .0-' c,:: L-V '.-"' ~ :.:::::1 L_ 7'--.1 ~ -.;, -< " -< E"s IJ/j -"\<:l- " " '" 1 -~~, "~--' "',-J,., c',,- '~':U\'~~' " AFFIDAVIT OF SERVICE P'-AlNTIFF WELLS FARGO HOME MORTGAGE, INC., FIKJA NORWEST MORTGAGE, INC. No,OI-6493 CIVIL TERM CUMBERLAND COUNTY VEFENDANT(S) DARRELL R. GORDON ACCT. #3104048 EDITH L, BROWNA WELL SERVE DARRELL R. GORDON AT 431 MOUNTAIN ROAD NEWVILLE, PA 17241 Type of Action - Notice of Sheriff's Sale Sale Date: JUNE 5, 2002 SERVED Servedandmadeknownto 001(\/1...\\ R, &o~H.r ,Defendant, on the d<pJ.t.. dayof "J;"'1)""'1,200~ at 7:'> (; ,o'clock .:a.m., at 13 I UV~ J" ... <<'''-1 It~:w v; 1\ ~ , 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 ofDefendant(s)'s office or usual place of business. an officer of said Defendant(s)'s company. Other: I II tbT Description: Age J~ Hei?ht sa Weight 130 Race Wl. Sex fI Other ,\,,'"......, I, ~-;J(l.e fU t \... l. Gl\.i.-y. ;;{6'mpetent 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 Sa . er as set forth herein, issued in the captioned case on the date and at the address indicated above. NOTARIAL SEAl. ,. "WTH M, JOHANSSON, NoI8ry PubIc Sworn to and subscrilled GI'll8I!8 Twp., Franklin CountY before me this ~(i "'day IfyCommisslon Expires 19. 2005 of -;rwv.....t ,2002. /)/J. - D NOtary:~ .J<r), ~ By: ~ (f-- PLE~E ATTEMPT SERVICE AT LEAST 3 TIMES, INDICATE DAT IMES 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 - I.D, No. 12248 One Penn Center at Suburban Station 1617 John F. Kennedy Boulevard, Snite 1400 Philadelphia, PA 19103-1814 (215) 563-7000 r' : q...~~ -L.J'-- "- " ~~']-[~:Jfi~ 'IlM:ifi!i!!~~_~;-,t>f.;U0i;;):~\.~cj'(~~i;i.;~;i'B'I.>6,,'$~~~.~~~~i..-""~'""'';'' , , ._~,","'-~" ~- --.. ~, "~H n ~, 0)"' '-~ "'-J "' , , 0 0 ~ C N :::-;:: .." 'U \:C; n,"l rn n r-..,:.v -7 ::I. ~- -:'"..-"\-- ~~ ~~~ C"', r:: c__~ ."0 ~~, _1lo" :,) - ::::.~ ~ ';.......' ~L ~ ~ 6ft, ""'_. ".~ ~ - _~ _.w._1 ,F,; " J~~_ -....:..:......' , -~-, ;. --""'i- ,',..,' , ~ ^ -, ~ '~i:i~,GI I 't IN THE COURT OF COMMON PLEAS OF CUMBERLAND COUNTY, PENNSYLVANIA RE: WELLS FARGO HOME MORTGAGE, INC. F/KJA NORWEST MORTGAGE, INC. ) CIVIL ACTION ) vs. DARRELL R. GORDON EDITH L. BROWNAWELL ) ) CIVIL DIVISION NO. 01-6493 AFFIDAVIT OF SERVICE PURSUANT TO RULE 3129 COMMONWEALTH OF PENNSYLVANIA COUNTY OF CUMBERLAND ) ) 55: I, FRANK FEDERMAN, ESQUIRE attorney for WELLS FARGO HOME MORTGAGE, INC. F/K/A NORWEST MORTGAGE, INC, hereby verify that on 1/16/02 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 1/16/02 by certified mail return receipt requested see Exhibit "B" attached hereto. DATE: April 18. 2002 ~~ ;101 ~ AAMJJ,^ F NK FEDER :A.N, ESQUIRE Attorney for Plaintiff ""i "* ~.O' ~ . ~ 0_ :;;: ~ . Z '" w ;::; ~ ~ O>Z , i~ ~ 0 '-0 00 " '" t"' '" ., w ~r ...~., -0' N ~ 0.0 [('~~ ",' ~ 0 = '" en ~ ~"'., 0 tH 8 '" '" =' ~ .... )> .. ~ = ::I. .... ~ c;' = .... iD 00 0 _z z '" ~ 3 IT ~O' CD ~ o . ~. z )> @ () tJ z "C....~"rj ~I s:: ~ 0 " g:g; tr1 m ~ ~ ~ ~-...J(Dt:l 0 ;0 0 ~5"~1 . 0 ~ - ~ 0 ,. 0'" !:::! ~ ~ 81m" )> 0- 0- J.~Q 8 g ~ ~ Z 0 () G:> () tti f:l . () !' ~~~~ m ~ ~ en Z ~ ~ . \O~a m . ,. ~ " 0 ~ ll. 8~~~ r '" '" .tJj[ ." ., ~ (I) ~ "'''' w ....0 ~ ~ Z ~ ~ 0 ~E.cT~ o~ ~ s:: iiI .... ~ ~ ~ . 'fii ~ 0 (I) ,. ~~r.n ,",0 () ~ ><: 0. -' :rp..g '" JTl ~ ~ ~ ~ = " z >';(1)8 ~ z ~ ., " () e. ::+' 0 ~ C'l" ~ OJ ~ tJ e..... en ~.... 0 tti ., 0 <" 0 ~ () .. 0 jJ" C .~ :r ~ '" -I ... I ~ Q;t,;~s-~ I ~ )> gg~:::("I z ~ ~ 12~~g~ 0 w ~... ~ iii fr < ~ Z "1_:10 m ..., ~ 8. . ~:a. $" ;0 > ~ [.I) .... 0 ~ le ~ g, ~ g" en ~ tti -I " t"' ::I: a;[~8g, N .~ ;0 ., ~ :'(1lP!3-~ m ~ _"g 0 - S.__ 8~ Ii m S"Q"'t:l::t.r;;" .-1 ~ 15''2 ~ ~ @ () ..., ~~ g G..o 0 o 0'" n o.~' )> 1:0 :>0 8~~g~ ;0 ~ (I) ~ v. ~ ~ = r ,~ Jt ~ti:;...., a ~ en N ... o::r' . 0. r '" . 0'" 5 0 m " ;;~g.~ . ,'" o ". -0 @ . tt1 g. ~ ~ ~ ~.f;l ~ )> ", 3 @ i5.. ~ s' [:l S' .... p.o.:s:;s 0 il ~ ~il ~ (I) F.....g-g. W 1:0 j;; ~~n~ .~ o " ~ - ..., -~ ~ ~.g afG. > ~ ~ g ~ ~ ~ " 't:l ::l 0 <'II 0 .:. tr:1 ~ p.. ~.f;l ~ ~ ~ ~ " w _ fil n _. ~ ~. ~ g. ~ 0 ~ s:: J:l (f) '" g ~~. ~ o il ~ -" VOl a ~ g '" ~ I:T (Il ~ or; t;;"_. " ~ ft-t,;~ ~ 0 .,....Og ~. ~'g- <> ~ ~Q' ~::l 8] =- ~ "g '< is::tii''; g ~ -.... 5 ~ 0' _ 0" r ;;i'_'~7f~~_~".. ~''''-'<:'1''''~''''''"'''~ ~r " . , I""" ~c . :,~"~"-~---""""",,,",,,,,-~..,,,,,,,,,,,,, . ._.,.= -~"" ~ . , . ~"- "~~-~-~- ,...;..~,-~"~ "~~~Ill' "'~ '-"-'<-'"'~-;~wJ~_T"""",i;-' 7160 3901 ~~~ 6S2& 79~1 TO: DARRELL R GORDON 43 I MOUNTAIN ROAD NEWVILLE, PAl 724 I SENDER: REFERENCE: GORDON, DARRELL TEAM 5 PS Form 3800 -June 2000 RETURN Postage RECEIPT Certified Fee SERVICE Return Receipt Fee Restricted Delivery Total Postage & Fees US Postal Service Receipt for Certified Mail No Insurance Coverage Provided Do Not Use for International Mail '~~..:~':r~OO5i+Mil<r'i-,;:~y',iUi*":'i')'ii',"4d~",-..no.'"$i<"M__'~"_hiO'-",:r<)~",-i"'!':f;iti"'~--'>"1\~'&,'-,1i",,,;s:-{'b-;\,"',,,~_'bli",<!_,-;!~&...w::!i!I'~'iMfu~'i;ilWMl,j9;tf~~!-lHI 0 ,-- ,,,"~- ~ - ".~---~ "~~,j ".e_.'_. o ~ -oct" !I'll" M? .":_' ZC~- ~~ ZC..::;. """,( , PC -/ =< '::0 r'v ~ ~:J N 1'0 IIMJIj I . .-0 n ''''n ,:j i}~ i_~~(~) --,--.' -,j .-p ,--- ?C) C")rTl ~ -< N .-1 ~ B// -...........- ~ ~L I'. '. " ~ " ~"=.~ . ./ STATE OF PENNSYLVANIA, COUNlY OF CUMBERLAND } 55. Robert P Ziegler I, ____________________________________________________~________________________Ileoordero( DeccIs in and for said County and State do 'hereby certi(y that the Sherifrs Deed in which ________________ WElls."Fargo Home Mtg Ine fka Norwest Mtg Ine ___________________________.________________________________________________________ u thegtantee 5th the same having been sold to said grantee on the _____h________________________________________ day o( . June" 2002 ________________________________________ A. D., ; _____, under and by virtue of a writ______________ 17th Execution . ____________________________________ _____ __ _____ ISSued on the _____________ ___ ____ ____ _____________ clay of ________J_-:'l_______________ A. D., Civil ______________________________,",_________________ _________________________________ Tenn, : ._____ "6493 Wells Fargo Home Mtg Ine fka Norwest Mtg Ine Number ____________"_, at the suit of _______________________________________________________________ Darrell R Gordon & Edith L Brownawell ________._____________________.____ against_ _______ __ ____.. ____________ ...______...... _____ ________ _..... is 252 2802 duly recorded in Sherirrs Deed Book No. ____________, Page ____________. 2001 . _____, ollt of the Court of Cornman Pleas of said County as of 2001 IN TESTIMONY WHEIlEOF, I haV;le~unto set 7)han.J d a and seal of said office this __~_______ day of -Yf/-fj--------------- ~ ~-~ ---1V4Jr;; -- --~;;..~-~ ..... ..~ I!'~~.~,."L ~~~ " __ ~.. ",.,.,1 . ~ ,,~<. ._~ .. -- ~'"~ . Wells Fargo Home Mortgage, Inc. flkIa In The Court of Common Pleas of Norwest Mortgage, Inc. Cumberland County, Pennsylvania VS Writ No. 2001-6493 Civil Term Darrell R Gordon and Edith L Brownawell Dawn Kell, Deputy Sheriff, who beipg duly sworn according to law, states that on March 28,2002 at 2:32 o'clock pm, EST, she 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: Darrell R Gordon, by making known unto Edith Brownawell, adult in charge, at 431 Mountain Road, Newville, Cumberland County, Pennsylvania, its contents and at the same time handing to her personally the said true and correct copy of the same. Dawn Kell, Deputy Sheriff, who being duly sworn according to law, states that on March 28, 2002 at 2:32 o'clock pm, EST, she 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: Edith L Brownawell, by making known unto Edith Brownawall, personally, at 431 Mountain Road, Newville, Cumberland County, Pennsylvania, its contents and at the same time handing to her personally the said true and correct copy of the same. Jason Vioral, Deputy Sheriff, who being duly sworn according to law, states that on April 4, 2002 at II :36 o'clock A.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 Darrell R Gordon and Edith L Brownawelllocated at 431 Mountain Road, Newville, 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: Darrell R Gordon, by regular mail to his last known address of 431 Mountain Road, Newville, P A 17241. 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: Edith L Brownawell, by regular mail to her last known address of 431 Mountain Road, Newville, PA 17241. 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 Wells Fargo Home Mortgage, Inc. f/kla Norwest Mortgage, Inc.. It being the highest bid and best price received for the same, Wells Fargo Home Mortgage, Inc., flkIa Norwest Mortgage, Inc. of 5024 Parkway Plaza Blvd., Charlotte, NC 28217-2407, being the buyer in this execution paid SheriffR Thomas Kline, the sum of $738.26, it being costs. ~" ~;;;,"",*",Jk~,*,~' t~ ~'d' .~ ~- =.~ ~ Sheriff s Costs: Docketing Poundage Posting Bills Advertising Acknowledging Deed Auctioneer Law Library Prothonotary .. Service Certified Mail Levy Surcharge Law Journal Patriot News Share of Bills Distribution of Proceeds Sheriffs Deed - -" I, . ~',,'"- ~-,--~, 'i:riW~~'<1 I_.I!'"~'" ~ """'- <~ . - ~ ~~ $30.00 14.48 15.00 15.00 30.00 10.00 .50 1.00 22.08 1.80 15.00 30.00 260.75 212.95 25.20 25.00 29.50 $738.26 paid by attorney 6/28/02 Sworn and subscribed to before me S()~~ r..l -~~ . - ~ This III oe: day of94 . . ~. _ ..ft. Thomas Klme, Shenff 2002, AD. 0 '7'k..t.L . ~ J~ r ~ C Pro honotary BY ~ Real Estat eputy wX'~ 3o.(Jt) 1.~1l Ck. 37 J1i) fJ I" 12'3""j (0-<.0. "'f! ~-~ ~'"'""'- 1- , ,I.- ~ " ~ " '~, ~_"",A~0""i!r,'" . EqlS FARGO HOME MORTGAGE, INC.. fl'KtA NORWEST MORTGAGE, mc. ,'t CUMBERLAND COUNTY Plaintiff, COURT OF COMMON PLEAS v. CIVIL DIVISION DARRELL R. GORDON EDITH L. BROWNA WELL NO.01-6493 CIVIL TERM Defendant(s). AFFIDAVIT PURSUANT TO RULE 3129 (Affidavit No.1) WELLS FARGO HOME MORTGAGE, INC., F/K/A NORWEST MORTGAGE, INC., P1aintiffin 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 ,431 MOUNTAIN ROAD. NEWVILLE, PA 17241. L Name and address ofOwner(s) or reputed Owner(s): Name Last Known Address (if address cannot be reasonably ascertained, please indicate) DARRELL R GORDON 431 MOUNTAIN ROAD NEWVILLE, P A 17241 431 MOUNTAIN ROAD NEWVILLE, P A 17241 EDITH L. BROWNA WELL 2. Name and address ofDefendant(s) in the judgment: DARRELL R GORDON EDITH L. BROWNA WELL 431 MOUNTAIN ROAD NEWVILLE, PA 17241 431 MOUNTAIN ROAD NEWVILLE, PA 17241 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 l'm ~.M#:~' " .4. Name arid address of last recorded hold~r of every mortgage of record: Name AMERICAN GENERAL FINANCE, INC Last Known Address (if address cannot be reasonably ascertained, please indicate) 6 SOUTH HANOVER STREET CARLISLE, PA 17013 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 431 MOUNTAIN ROAD NEWVILLE, P A 17241 Domestic Relations of Cumberland County 13 North Hanover Street Carlisle, P A 17013 Commonwealth of Penn sylvania Department of Welfare PO Box 2675 Harrisburg, P A 171 05 I verify that the statements made in this affidavit are true and correct to the best of my personal knowledge or information and belief. I understand that false statements herein are made subject to the penalties of18 Pa. C.S. Sec. 4904 relating to unsworn falsification to authorities. January 16. 2002 DATE -+---l ~ FRANKFED RMAN, ESQUIRE Attorney for Plaintiff I " . . I .. ';""';"'.''''-'"-'"''-"f'-;>I~",;; . , WELLS FARGO HOME MORTGAGE, INC., FfKJA NORWEST MORTGAGE, INC. Plaintiff, ~ CUMBERLAND COUNTY , No.01-6493 CIVIL TERM v. DARRELL R. GORDON EDITH L. BROWNA WELL Defendant( s). January 16, 2002 TO: DARRELL R. GORDON 431 MOUNTAIN ROAD NEWVILLE, P A 17241 EDITH L. BROWNA WELL 431 MOUNTAIN ROAD NEWVILLE, PA 17241 **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, 431 MOUNTAIN ROAD, NEWVILLE, PA 17241, 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 of 89,590.06 obtained by WELLS FARGO HOME MORTGAGE, INC.. F/K/A NORWEST MORTGAGE, 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 MAY BE ABLE TO PREVENT THIS SHERIFF'S SALE To prevent this Sheriffs Sale, you must take immediate action: L The sale will be cancelled if you pay to the mortgagee the back payments, late charges, costs and reasonable attorney's fees due. To find out how much you must pay, you may call: (215) 563-7000. 2. You may be able to stop the sale by filing a petition asking the Court to strike or open the judgment, ifthe judgment was improperly entered. You may also ask the Court to postpone the sale for good cause. 3. You may also be able to stop the sale through other legal proceedings" You may need an attorney to assert your rights. The sooner you contact one, the more chance you will have of stopping the sale. (See notice on page two on how to obtain an attorney.) . - , I~ ..,: i_-~, '" ~-~"""'''"'''' .; . , YOU MAY STILL BE ABLE TO SAVE YOUR PROPERTY AND YOU HAVE OTHER RIGHTS EVEN IF THE SHERIFF'S SALE DOES TAKE PLACE. 1. 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 - -1-, ~-~" 1. .1.........' " "~ ',"~ - - ,,- 1ii -"'!iiI.~"" .. ALL THAT CERTAIN tract of land situate in Lower Mifflin Township. Cumberland COUnty, Pennsylvania, being Lot #4 of a Subdivision of Samuel D. Shenk, as set forth in Plan Book 60, Paee 113. more particularly bounded and described as follows: - BEGINNING at set railroad spike situate on the centerline of Lower Mifflin Township Road T-383, also known as Mountain Road, said railroad spike being located South 86 degrees 59 minutes 31 seconds West 75.'16 feet from an existing nail and washer situate on the centerline of said Mountain Road; thence along other lands now or formerly of Samuel D, Shenk, South 08 degrees 33 minutes 05 seconds East 286.76 feet to a set iron pin; thence along other lands now or formerly of Samuel D" Shenk, North 88 degrees 17 minutes 22 seconds West 357.44 feet to a set iron pin; thence along lnnds now or formerly of Samuel D. Shenk, North 02 degrees 11 minutes 19 seconds East 257.0'; fee: [0 a set railroad spike on the centerline of Mountain Road; thence along the centerline of said Mountain Road, North 86 degrees 59 minutes 31 seconds East 305.24 feet to a set railroad spike, the place of beginning" CONTAINING 2.0547 acres of land including the right-of-way area. Tax Parcel #5-0411-027 ~~ u >'~~." .." ,...""~.~~"~ ~~ ""'T~",,~_''''''''''''' ".- =~ , ~ " "I "~, ~ ~"" ~'--'m!; ~).".."l.,- WRIT OF EXECUTION and/or ATTACHMENT d COMMONWEALTH OF PENNSYL V ANIAr) , COUNTY OF CUMBERLAND) NO 01-6493 Civil CIVIL ACTION - LAW TO THE SHERIFF OF Cumberland COUNTY: To satisfy the debt, interest and costs due WELLS FARGO HOME MORTGAGE, INC., FIKIA NORWEST MORTGAGE, INe PLANTIFF(S) From DARRELL R. GORDON, EDITH L. BROWNA WELL, 431 MOUNTAIN ROAD, NEWVILLE, P A 17241 (I) You are directed to levy upon the property of the defendant(s) and to sell SEE LEGAL DESCRIPTION (2) You are also directed to attach the property of the defendant(s) not levied upon in the possession of GARNISHEE(S) as follows: and to notify the garnishee(s) that: (a) an attachment has been issued; (b) the garnishee(s) is enjoined from paying any debt to or for the account of the defendant (s) and from delivering any property of the defendant (s) or otherwise disposing thereof; (3) Ifproperty of the defendant(s) not levied upon an subject to attachment is found in the possession of anyone other than a named garnishee, you are directed to notify himlher that he/she has been added as a garnishee and is enjoined as above stated. Amount Due $89,590.06 L.L $50 Interest FROM 1/16/02 TO 6/5/02 (PER DIEM - 14"73) $2,062.20 AND COSTS Atty's Comm % Due Prothy $1.00 Atty Paid $126.40 Other Costs Plaintiff Paid Date: JANUARY 17,2002 CURTIS R. LONG Prothonotary, Civil Division ~. 4/~, 2 7pR/7~r:~ REQUESTING PARTY: Name FRANK FEDERMAN, ESQUIRE Address: ONE PENN CENTER AT SUBURBAN STATION 1617 JOHN F" KENNEDY BOULEVARD, SUITE 1400 PHILADELPHIA, PA 19103-1814 Attorney for: PLAINTIFF Telephone: 215-563-7000 Supreme Court ill No. 12248 :i,1~~l~iA$)~'.!.''kW~,",~ii&X;'-L. ':-"", \ , ,_ : .,."""_""",_,;,,,,,~,:,,#i<-6~~"d!j,:ij.r!i:i!"'.iiffi<'""ti\!:..~ki1:~',~:t:"'''''F,-,k-,;:..,;V-,:.0""""",,'L~!{:3".h'''L~*,'~1:.t;l%'jfj/t-:t{''l\I~:n~:._~ --"': <" REAL ESTATE SALE No. q On February 6, 2002, the sherifflevied upon the defendant's interest in the real property situated in Lower Mifflin Township, Cumberland County, P A, known and numbered as 431 Mountain Road, Newville, and more fully described on Exhibit "A" filed with this writ and by this reference incorporated herein. Date: February 6, 2002 By: Jo d4 j' VV\A....~ Real Estate Deputy ~, c:;ri) · r:;:;:a \ c-.:l <::n:) ) 1.t\iiL. \;IIN\lI\I,lSNHjd ,., --". :"' : - ~ ",1'--:' n, 20\ \'\1 SO \ I rZ HUr ','rl'-' ~,UW~,~ ".'" jLH'~1 v ,:W\l3I\B :\f\l JC 3(\IJ:l() _ J.""".."~,",,-~.., .'"'",...""". .""'~, _ "n'~ '"~'~',, ~ ~--,' -," ""'''''~'''''''~'''''' ~""","""" --. , ~ .... "-~"" -- I. . ,J~ ....~ "_~t_"yo~(;.<'.'_"C,-~'''' " . "'- THE PATRIOT NEWS THE SUNDAY PATRIOT NEWS Proof of Publication Under Ad 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 Pennsyivania, 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 #9 oan su scn e eo Notarial eal Tony L RUS$~II. Notary Public Harrisburg, Dauphin County My Coml'Plssion Expires June 6. 2 Member, Pennsylvania Assoc:mtion Of Notaries My commission expires June 6, 2002 t CUMBERLAND COUNTY SHERIFFS OFFICE CUMBERLAND COUNTY COURTHOUSE CARLISLE, PA 17013 r Statement of Advertising Costs To THE PATRIOT-NEWS CO., Dr. For publishing the notice or publication attached hereto on the above slated dates $ Probating same Notary Fee(s} $ Total $ 211.20 1.75 212.95 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.....................""."""................................."."."""" .... 'REACESTATESAlE No: 9' - . "'WrIINo.2001-6493 Clvlllerm Wells Fargo Home . -'-' Mortgage. Inc. ~..:-'-=- fka 'NolWest Mortgage, Inc. V> .-: --=-=-~ Darrell R. Gordon and ~::: . Edlth(...Brownawell ~. ..- :> A!tl': Frank federm,n ~ uJ;SCRlPTION . ~ THAT CERTAJN ~tract of land situate in i.J;Q~ei'lWllrin Township, Cumberland County, "iepnsylvani!l, being to: #4 of a Sulxlivisioll of ~lfeI D. Shenk. as set forth in Plan Book 60, ",Fagc1l3, more P'rticula<ly bounded and i-de.<!cribed aslollows: ~BEG1NNING at- set railroad spike: situate on the = -~terline qf Lower Mifflin Township Road T- ~Kr,-aJso kiiown as Mountain Road, said railroad ~plke being located South 86 degrees 59 minutes ::-Sl ~~eonds West 75.46 feet from an existing nail ~ ~d washer situate on the centerline of said ;-Mountain Road; thence along other lands now or ~fq@etty of Samuel D. S~_ so.ut1tOS .<legrees ~l_JDinu!es 05 seConds East 286.16 feet to a set ~.iron_piu; thence_ along other lands now or formerly ~ofSa:muel D. Shenk, North 88 degrees 17 minutes ~? s~nds West 3051.44 Jel;Uo JU_et iron pin; rtbe~e along rands llOW Monnerly of SamueLD. ~henk,_North 02 degrees lLmiDtltes 19 seconds =:J~ast 257m feet to;a set railroad spike on the ~Ci:!1imfrfue-"of Mountait Road; thence along the ~tl.terline of said Mcuntain Road, North 86 ~Qegrees-59 minutes 31 s~onds East 305.24 feet to ~.t:,.railroad spike, the !...ace of BEGINNING. ~~G2.0547 aiiesof)and.including the _ ~g.b"tOf;wayarea. ~cl-#5{14l1-027. ..-~""'iJj ~..oiI~~ ~... I J -~-I ; ~~I -" - -~- ~-""'~~""I<i&.,.r'.-~ PROOF OF PUBLICATION OF NOTICE IN CUMBERLAND LAW JOURNAL (Under Act No. 587, approved May 16,1929), P. 1.1784 STATE OF PENNSYLVANIA : ss. COUNTY OF CUMBERLAND : Roger M. Morgenthal, Esquire, Editor of the Cumberland Law Journal, of the County and State aforesaid, being duly sworn, according to law, deposes and says that the Cumberland Law Journal, a legal periodical published in the Borough of Carlisle in the County and State aforesaid, was established January 2, 1952, and designated by the local courts as the official legal periodical for the publication of all legal notices, and has, since January 2, 1952, been regularly issued weekly in the said County, and that the printed notice or publication attached hereto is exactly the same as was printed in the regular editions and issues of the said Cumberland Law Journal on the following dates, VlZ: 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 LOIS E. SNYDER, NoIary PubI1c CarlIsle Boro, Cumberland County My Commi88Ion ExpAs Man:h 5. 2005 " ...~~..J I'., I .'-' ~ REAL ESTATE SALE NO. 9 Writ No" 2001-6493 Civil Wells Fargo Home Mortgage. Inc.. f/k/a Norwest Mortgage. Inc. vs. Darrell R. Gordon and Edith L. Brownawell Atty.: Frank Federman ALL THAT CERTAIN tract of land situate in Lower Mifflin Township. Cumberland County". Pennsylvania. being Lot #4 of a SubdMsion of Sam- uel D. Shenk, as set forth in Plan Book 60, Page 113, more particularly bounded and described as follows: BEGINNING at set railroad spike situate on the centerline of Lower Mifflin Township Road T-383, also known as Mountain Road, said rail- road spike being located South 86 degrees 59 minutes 31 seconds West 75.46 feet from an existing nail and washer situate on the centerline of said Mountain Road: thence along other lands now or formerly of Samuel D. Shenk, South 08 degrees 33 minutes 05 seconds East 286.76 feet to a set iron pin; thence along other lands now or formerly of Samuel D. Shenk, North 88 degrees 17 minutes 22 seconds West 357.44 feet to a set iron pin; thence along lands now or formerly of Samuel D. Shenk. North 02 degrees 11 min- utes 19 seconds East 257.07 feet to a set railroad spike on the centerline of Mountain Road: thence along the centerline of said Moun- tain Road, North 86 degrees 59 min- utes 31 seconds East 305.24 feet to a set railroad spike. the place of beginning. CONTAINING 2.0547 acres of land including the right -of-way area. Tax Parcel #5-0411-027" ~ ! _ .-,,~;'1._, 'C-~.;"" '.';;;- "" ;~, ,-'., , _ , . . -~[~~!': i::