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Home My WebLink About01-06843 FEDERMAN AND PHELAN, LLP By: FRANK FEDERMAN, ESQUIRE IDENTIFICATION NO. 12248 ONE PENN CENTER AT SUBURBAN STATION 1617 JOlIN F. KENNEDY BOULEVARD SUITE 1400 PHILADELPHIA, PA 19102.1814 (215) 563.7000 ASSOCIATES CONSUMER DISCOUNT COMPANY 1111 NORTHPOINT DRIVE COPPELL, TX 75019 ATTORNEY FOR PLAINTIFF COURT OF COMMON PLEAS CIVIL DIVISION TERM v. NO. 01- hf~3 ~ Plaintiff CUMBERLAND COUNTY' OLEN JUMPER AIK/ A OLEN E. JUMPER 230 WEST DAUPHIN STREET ENOLA, P A 17025 Defendant(s) CIVIL ACTION. LAW COMPLAINT IN MORTGAGE FORECLOSURE NOTICE **THIS FIRM IS A DEBT COLLECTOR ATTEMPTING TO COLLECT A DEBT AND ANY INFORMATION OBTAINED WILL BE USED FOR THAT PURPOSE. IF YOU HAVE PREVIOUSLY RECEIVED A DISCHARGE IN BANKRUPTCY AND TillS 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 Y01,l by the court without further notice for any money claimed in the Complaint or for any other claim or relief requested by the Plaintiff. You may lose money or property or other rights important to you. YOU SHOULD TAKE THIS PAPER TO YOUR LAWYER AT ONCE. IF YOU DO NOT HAVE A LAWYER OR CANNOT AFFORD ONE, GO TO OR TELEPHONE THE OFFICE SET 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 #: 013703360208597 ''''I~J;<ijC', .~ ",,' IF TillS IS THE FIRST NOTICE THAT YOU HAVE RECEIVED FROM TillS 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. I ""'~"""": "'",--..,.- , " ~", '-" " ~t' ~ - , ~ . -, ,..," 1. Plaintiff is ASSOCIATES CONSUMER DISCOUNT COMPANY 1111 NORTHPOINT DRIVE COPPELL, TX 75019 2. The name(s) and last known addressees) of the Defendant(s) are: OLEN JUMPER OLEN E. JUMPER 230 WEST DAUPHIN STREET ENOLA, P A 17025 who is/are the mortgagor(s) and real owner(s) of the property hereinafter described. 3. On 3/2/98 mortgagor(s) made, executed and delivered a mortgage upon the premises hereinafter described to PLAINTIFF which mortgage is recorded in the Office ofthe Recorder of CUMBERLAND County, in Mortgage Book No. 1435, Page 774. 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 3/15/01 and each month thereafter are due and unpaid, and by the terms of said mortgage, upon failure of mortgagor to make such payments after a date specified by written notice sent to Mortgagor, the entire principal balance and all interest due thereon are collectible forthwith. ~i)~ Tr- ---~"'- (..' ""I~::,"_""" " 6. The following amounts are due on the mortgage: Principal Balance futerest 2/15/01 through 11/15/01 (Per Diem $17.13) Attorney's Fees Cumulative Late Charges 3/2/98 to 11/15/0 I Cost of Suit and Title Search Subtotal $44,660.60 4,693.62 800.00 0.00 550.00 $50,704.22 Escrow Credit Deficit Subtotal 0.00 0.00 $ 0.00 TOTAL $50,704.22 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, The Combined Notice has been sent to the Defendant(s) by regular and certified mail as required by 35 P.S. ~1680.403c. 9. The Temporary Stay as provided by the Homeowner's Emergency Mortgage Assistance Program, Act 91 of 1983, has terminated because either: (i.) Defendant(s) have failed to meet with the Plaintiff or an authorized Credit Counseling Agency in accordance with Plaintiffs written Notice to Defendants; or (ii.) Defendant(s) application for assistance has been rejected by the Pennsylvania Housing Finance Agency. WHEREFORE, PLAINTIFF demands an in rem Judgment against the Defendant(s) in the sum of $50,704.22, together with interest from 11/15/01 at the rate of$17.13 per diem to the date of Judgment, and other costs and charges collectible under the mortgage and for the foreclosure and sale of the mortgaged property. ~~~~ FRANK FEDERMAN, ESQUlRE Attorney for Plaintiff ,,= ., '-~~" " ~~~ T.'. ,)))\1> 'A .' ,. Au.. THAT CEm'AIN' lot or piec,," of: land with buildj,ngs and improvement.s t.he>"!ton erect.ed situate in E;>st Pennsboro Township, Cumberlsnd County, Penn- sylvania, bounded and de$cr1bed as rollaws, to ~t: ' rJEr.II,JN!:'IG at a point in the southern B.ne of: Dauphin St:reet at or opposite th~ center cr t~e partition wall di~ding properties known, as No. 230 and 232 Dauphin Street, :!aid point being two hundred twenty-nine and three hunc:1red eighty-nine one-thousands (229.389) !:eet east o!: the southeast corner of: Brick Church Road and Dauphin St~et; thence along the southern line of: Dauphin ,St.reet, North 79 degroes 40 minutes East, 1'ort:r-su (46) .reet to a point; thence South 10 degrees 20 minutes East, one hundred seventeen and !:ive hundred .ri.ve one-thous"ndths (111.505) !:eet to a point; thence South 19 degrees 40 minutes West, forty-su (46) roet to a point at or opposite the centor or the partition wall dividing propertie" lmown as No. 230 and 232 Dal~phin Street; thonco North loO dep;rees 20 minutes I<lest through the center or th.. part:l:tion wall di"'iding prc'perties known as No. 230 and ,No. 232 Dauphin Street. and te- yond one hundred seventeen and ~ive hundred f:1ve ene-thousandths (117.S05) f:e"t t.o a point, at. the place or aEGINlIING. Hi\ 'liNG the noon erected the eas"tern one-hall 01: a two story dwelling known as No. 230 D~uph1n Street, Enola, Pennsylvania. ,'3EING the same premise" which r-finn;1e M., Z1nn and. RaJIton J. Zinn, her hUSband, by their Deed datad Decsmber 18, 196~, and recorded 1.n the Of:f'ice 01' the 1'l:I- corder oJ: Deeds in and ror CumberJ.and County, Pennsylvania, in Deed So ok "J", Volwne 20, at Page 1135. granted and conV&78d unto Theodore E. Sgr:1gnoli and "J1ni!:~d E. Sr:rignoli. his wUe, 'the grantors heno1-n. ,-', ..,-- ,~ """ , VERIFICATION MICHAEL GRAHAM hereby states that he is ASSIST ANT VICE PRESIDENT of CITIFINANCIAL MORTGAGE COMPANY, INC. mortgage servicing agent for Plaintiff in this matter, that he 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 his knowledge, information and belief. The undersigned understands that this statement is made subject to the penalties of 18 Pa. C.8. Sec. 4904 relating to unsworn falsification to authorities. ,.. ~:D1~ DATE: 11/21!o/ '" ~ -!Ii: "''''f.,.o.".l. , ~I ,--, ~. 1 "~~fq<-< t'\ ~ i - ", ',_=0. ",,"~ """,.,,,. ,<!.~ C,, ,!.!_~,"_PJjlTJ ~._.. -. ,_ " ',' ~__"V~ _ , ~Q? ---- r ~' i..N~ \.N::f'> ----.. ~ ~ '->-.; ~ ~ ~ ";;> ~ ~ ~ I ", - - -.. -"'";-.., 'A.U d ~ oC). - ) "d Q C;" -<;.- -of:: ~~:~-. ~~ f" ~g-. ~(-:, ~c) >~'; J'~_ :::! "-~-= ~ ~ f -'i-:-1 1 ,:") C,-' ::-;- -i~:) -.!::;....-l '>~~J C~ 11 ~ :0 -< f',) t:'" Ul L ,,,,f . rl . ;;.' \. i -:'t _. Z: ....~: ~:" : J:""'~:. 1 '~O:~!. o >" > ::Ii ~~t;~ '\ r 1!!IIm1ii':m~~J_~ ~J" '; _ l~II"*~W~M_~_WP;!:l'l\,i'!"-11'\';'hi~"B'.;-:"-~-"-"'?-" :""';'j;t1.!'A'''"WWIlf.~jliH~~"'if:&1~Mf~~~~IIfi1Wi~~ift''-' SHERIFF'S RETURN - NOT FOUND CASE NO: 2001-06843 P COMMONWEALTH OF PENNSYLVANIA COUNTY OF CUMBERLAND ASSOCIATES CONSUMER DISCOUNT VS JUMPER OLEN E R. Thomas Kline ,Sheriff or Deputy Sheriff, who being duly sworn according to law, says, that he made a diligent search and inquiry for the within named defendant, DEFENDANT JUMPER OLEN E but was unable to locate Him in his bailiwick. He therefore returns the COMPLAINT - MORT FORE , NOT FOUND , as to the within named DEFENDANT , JUMPER OLEN E DEFENDANT DOES NOT LIVE AT ADDRESS PROVIDED. Sheriff's Costs: Docketing Service Not Found Surcharge 18.00 9.75 5.00 10.00 .00 42.75 ~~ s:;:we : // ;.. Thomas Kllne Sheriff of Cumberland County FEDERMAN & PHELAN 12/13/2001 Sworn and subscribed to before me day of ~.~ ,."'qn"'!~ A ~~/!l!1'l"_ _. ,",' "T- "~ "-~-~ ~~"'""" ""'" .. 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 19102.1814 (215) 563.7000 ATTORNEY FOR PLAINTIFF COURT OF COMMON PLEAS CIVIL DIVISION ASSOCIATES CONSUMER DISCOUNT COMPANY I I I 1 NORTHPOINT DRIVE COPPELL, TX 75019 Plaintiff TERM NO, DI to y--43 ~ v. CUMBERLAND COUNTY OLEN JUMPER AlKJA OLEN E. JUMPER 230 WEST DAUPHIN STREET ENOLA, PA 17025 Defendant( s) CIVIL ACTION. LAW COMPLAINT IN MORTGAGE FORECLOSURE NOTICE **THlS 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 attomey and filing in writing with the court your defenses or obj ections to the claims set forth against you, You are warned that if you fail to do so the case may proceed without you and a judgment may be entered against you by the court without further notice for any money claimed in the Complaint or for any other claim or relief requested by the Plaintiff. You may lose money or property or other rights important to you. YOU SHOULD TAKE THIS PAPER TO YOUR LAWYER AT ONCE. IF YOU DO NOT HAVE A LAWYER OR CANNOT AFFORD ONE, GO TO OR TELEPHONE THE OFFICE SET 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 We hereby canny lhe wtlttinto be a true and ~~~of~ ~ngmal filed of record O::DEP,~~I\" '~,n '>UI::I ^' Loan #: 013703360208597 TRuE COPY FRqM ReCORD :JestImony Whereof, I here unto set my hand fleal of sald, at CarUSI8, Pa, fhl t: ,d ~r-rJ ( , - "'1IIl<i~~~""1_~'-' --,~ ;~ J;J:~ ."~,,-~, - T""-:"~-- . %~ "~ ,~,.~ , ._0, IF THIS IS THE FIRST NOTICE THAT YOU HAVE RECEIVED FROM THIS OFFICE, BE ADVISED THAT: PURSUANT TO THE FAIR DEBT COLLECTION PRACTICES ACT, IS 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. .-." "-. t':""'., - :, .~ ]~ ,~ . ~ ., ~ ,~ . 1. Plaintiff is ASSOCIATES CONSUMER DISCOUNT COMPANY IIII NORTHPOINT DRIVE COPPELL, TX 75019 2, The name( s) and last known address( es) of the Defendant( s) are: OLEN JUMPER OLEN E, JUMPER 230 WEST DAUPHIN STREET ENOLA, PA 17025 who is/are the mortgagor(s) and real owner(s) of the property hereinafter described, 3. On 3/2/98 mortgagor(s) made, executed and delivered a mortgage upon the premises hereinafter described to PLAINTIFF which mortgage is recorded in the Office of the Recorder of CUMBERLAND County, in Mortgage Book No. 1435, Page 774, 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 3/15/01 and each month thereafter are due and unpaid, and by the terms of said mortgage, upon failure of mortgagor to make such payments after a date specified by written notice sent to Mortgagor, the entire principal balance and all interest due thereon are collectible forthwith. "'~_~f ,,, 1'-' .,'-~" . ~. 1'"' "' 6, The following amounts are due on the mortgage: Principal Balance Interest 2/15/0 I through 11/15/0 I (Per Diem $17.13) Attorney's Fees Cumulative Late Charges 3/2/98 to 11/15/0 I Cost of Suit and Title Search Subtotal $44,660.60 4,693,62 800.00 0,00 550,00 $50,704,22 Escrow Credit Deficit Subtotal 0.00 0.00 S 0.00 TOTAL $50,704.22 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 ofa third party purchaser at Sheriffs Sale. If the Mortgage is reinstated prior to the Sale, reasonable attorney's fees will be charged. 8, The Combined Notice has been sent to the Defendant(s) by regular and certified mail as required by 35 P.S. ~1680.403c. 9, The Temporary Stay as provided by the Homeowner's Emergency Mortgage Assistance Program, Act 91 of 1983, has terminated because either: (i.) Defendant(s) have failed to meet with the Plaintiff or an authorized Credit Counseling Agency in accordance with Plaintiffs written Notice to Defendants; or (ii,) Defendant(s) application for assistance has been rejected by the Pennsylvania Housing Finance Agency. WHEREFORE, PLAINTIFF demands an in rem Judgment against the Defendant(s) in the sum of $50,704.22, together with interest from 11/15/01 at the rate of $17.13 per diem to the date of Judgment, and other costs and charges collectible under the mortgage and for the foreclosure and sale ofthe mortgaged property. / s/ Frank Federman FRANK FEDERMAN, ESQUIRE Attorney for Plaintiff """-~-'. '" - ~~~~ -. I .' , ,~~. '-"'~ I ALL '!"H^T CE:ITA-=~ lot or piec",", of .Land ....r'ith 'oui~d..:1.ngs and .improvement.s t..he~on ~rect.ed ~ituate in .F...ast Pennaboro Township, Curnbe:-land County, Penn- sylvar.~3, bounded and described as ~ollowg, to ~t: . 3Er;1N'NI~G at a poi.nt in the southern l.in~ of Dauphin St~et. at or opposite th~ center cf t~e pa~ition wall di~ding properties known as No. 2)0 and 2)2 Dauphin Street, ::;aid polnt. being two hundred twenty-nin.. and three hundred eight.y-nine one-thousands (229.389) feet. east. or the sout.heast. corn..r or Brick Church Road and Dauphin StMet; thence along t.he sout.hern line or Dauphin S'."",et, North 79 degroea 40 minutes East., i'ort7-su (46) !"eet. t.o a point; thence South 10 deKreos 20 minutes East, one hundred sevent.een and five hundred !"ive one-thous"ndths (117.505) reet. to a point; thence South 79 deg~es 40 minut.es ~e$t, rorty-six (46) feet to a point at or opposite the center o!" the p"rtit:l.on wall dividing properties known as No. 230 and 232 Oa'~phin Stre..t; thence North 10 deo;""es 20 minutes \olest through the cent.er or th" pa rti tion wall di'riclin~ prc'pertie" known as No. 2)0 and ,No. 232 Dauphi" St....et and t;.e- yond one hundred sevente~n and J:ive hundred r1'~ one-t.housandths (117.S05) 1"e"t to a point, at. the place o~ dEGINTUNG. HA V:rNG ther'9on erect.ed the "a9tern one-half' o/: a two "tory dwelling known as No. 2)0 O~uph1n Street., Enola, Pennsylvania. 3EING the same premises wtlich l-fintUe M.. Z1nn and Ranlon J. Zinn, her husband, by their Deed datod December 18, 1961, and recorded in the Of!"ice of the He- corder ot: Oeeds in "nd ~or CWl\berland County, Pennsylvania, in Oeed aook "J", Volume 20, at. Page 113$', granted and con~d unto Theodore E. Sr;;r1gnoli and 'dini~""d E. Sr:rtgnoli, his wile, the grant.ors he",:!.n. ,.-,"~~, ., "11"""__ -] ~l_~ " - ~- f:. ,:l,_)" ,4'_ VERIFICATION MICHAEL GRAHAM hereby states that he is ASSISTANT VICE PRESIDENT of CITIFINANClAL MORTGAGE COMPANY, INe. mortgage servicing agent for Plaintiff in this matter, that he 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 his 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. ~~/ >>z~ DATE: 11/'1/0/ -":-, ~, '"", ' l"" -;'~irnt~~~Iii;;~JW~.k~JID,~li\i~illi~_i>""~,,,,,,,;,,!,,,jr;',,,,,~:.>&,,i.':",_",~~;~,'0jf;-;;~~didj.f - ",,","-"'~--- ,,,j~ '~:"',<'- < . if -f~-''''' , . Offlll~ or rilE lililflllf'F CjJ~~E~i!.Mli~ (;{)!lIlT" DEe 3 3 4a PH 'OJ ('Af"l.' If;j ': 'IV ,\"'" .,v.....1:. PENNSYLVANIA ~.~ ~~ ~) lb!!dl ~ IOE. 1!.l::!!dl @0 - ,,~-~" "-,,~.- -~- . - FEDERMAN AND PHELAN BY: FRANK FEDERMAN, ESQUIRE Identification No. 12248 1617 John F. Kennedy Boulevard Suite 1400 Philadelphia, PA 19103-1814 (71 'i) 'i6,. 7000 Attorney for Plaintiff ASSOCIATES CONSUMER DISCOUNT COMPANY COURT OF COMMON PLEAS l?laintiff CIVIL DIVISION vs. OLEN JUMPER A/K/A OLEN E. JUMPER Cumberland County Defendants No. 01-6843 CIVIL PRAECIPE TO REINSTATE CIVIL ACTION/MORTGAGE FORECLOSURE TO THE PROTHONOTARY: Kindly reinstate the Civil Action in Mortgage Foreclosure with reference to the above captioned matter. ~2~~~IRE-- Attorney for Plaintiff Date: December 31, 2001 CZC, SVC DEPT -""'""")'Ji'",,"_>,>,,, . , ~, - ." :1 ~ ~ """' f"""""""'ff"""""- ~> ~'"-~. ,. '.'^ -' "n' ^"~ ~_ ,. (j t.-;::r c: 1'0 ~ um .c:~... mrTJ '.,"'P , , 2:::,(' -. Z ,- ~~t ---..1 :.c-\...i ,] );;::r, Z\.~ ",,".(3 ;J> C ;..,>..1 "7 :;:l ..~ ~ - . " ~, ,,"'^" <""""'f-'T,':"~ ,1!~.:,''''~~'~~~r." ".,.,w,~~"";,_,,:~~jm1!I~""\O'lP~'T':'~W:'" '1f~ f._-:;~~iit",~\#'W.~'l~41)~~~~"!t; j < ' ~ J FEDERMAN AND PHELAN BY: Michele M. Bradford, Esq. Atty. !.D. #69849 1617 John F. Kennedy Boulevard Suite 1400 Philadelphia, PA 19103-1814 (? 1 'i) 'il'i"l- 7000 ASSOCIATES CONSUMER DISCOUNT COMPANY ATTORNEY FOR PLAINTIFF COURT OF COMMON PLEAS CIVIL DIVISION Vs. CUMBERLAND COUNTY OLEN JUMPER NKIA OLEN E. JUMPER NO. 01-6843 CIVIL CF,RTTFTCATTON OF SRRVWR I, Michele M. Bradford, Esquire, herby certiJ)' that a copy of the Motion for Service Pursuant to Special Order of Court has been sent to the individual( s) as indicated below by first class mail, postage prepaid, on the date listed below. OLEN JUMPER NKI A OLEN E. JUMPER at: 230 WEST DAUPHIN STREET ENOLA P A 17025 The undersigned understands that this statement is made subject to the penalties of 18 Pa. C.S. g4904 relating to unsworn falsification to authorities. Date: n"""mh"r "II 7001 , ~ Michele M. Bradford, Esquire Attorney for Plaintiff CZC, Svc Dept. H:/Main Forrns/motionsfcounty.comp """'-"\?-1'WO..", I:.~"- - "".' ~, ~_, - . - ~'~..~.--"l!'l-__'" ~~ c ~<<, fJJi!rll~~~ ",=c<,."IIJ.".. "~'r, '- ,. ~]!~"",,""__"'" ~ _,~~lW+""O\v""i"I"~:''''-''''cii''T;' C) ~~ n..CC' ;?! !!:; 6ft ;:$-- ~c:.) :r;: zc:: j3~ 1i :.< r,) r C:) f", , .::"2: ",.~ ...-"!"- .....; '-' " ,. ~) ";""" <-"!:1t-"$'~~~~~;~~:~~_~t " ... JAN I) .8 2002 ~~ . FEDERMAN AND PHELAN BY: Michele M. Bradford, Esq. Atty. !.D. #69849 1617 John F. Kennedy Boulevard Suite 1400 Philadelphia, P A 191 03-1814 (71 ~) ~h1-7000 ATTORNEY FOR PLAINTIFF ASSOCIATES CONSUMER DISCOUNT COMPANY COURT OF COMMON PLEAS CML DIVISION vs. CUMBERLAND COUNTY OLEN JUMPER AlK/A OLEN E. JUMPER NO. 01-6843 CML AND NOW, this I 7-r:h ORDER day of J}i1Nt.lPtd , 20~upon consideration of Plaintiffs Motion for Service Pursuant to Special Order of Court and the Affidavit of Reasonable Investigation attached thereto, it is hereby ORDERED that Plaintiff may obtain service of the Complaint on the above captioned Defendant(s) OLEN JUMPER AlKJA OLEN E. JUMPER, by mailing a true and correct copy of the Complaint by certified mail and regular mail to the Defendant's last known address, and to the mortgaged premises located at 230 WEST DAUPHIN STREET,ENOLA,P1\.lJO~,-t ~ ~....;.~ ~ pc... R...c...!. ~ '?Ie> \P)ll). Service of the aforementioned mailings is effective upon the date of mailing and is to be done by Plaintiffs attorney, who will file with the Prothonotary's Office an Affidavit as to the mailing. CZC, Svc Dept. lfe:de.rrno.J'l- P'he.La.J LLP J. top\es fu,\J OI-J7.0J., 'RXS H:lMain Forms/motions/county.comp ;""""-"~:_!i(l. "'''',1;>,..,.1" I "'~- ~ " "'1111.!I"i!I!!~I'''!.!J!''V ",~~_~';'i..,.J.-"'"'~'m"""'W'"""""",o,'j,j,"'">""""""C0''''''ilIIii1liliilii", ,.h,' '''''lilt'''' ,_ [",lfY" ." b'"" , __ ,. - ..,," S~fl ~ .. I ' 'c' Cl~1 !j~:_t I '/ p~; I: S. ~5 ,T_ ,"_,,_,.1, l. . ,f . {'UI,/,e,,:,:!, ':',," ({II ji\IT'( l.J ,'~,1\,_' IW '" lU \)....J.., PENNSYLV!\NIfl, , " .. ,~ , FEDERMAN AND PHELAN BY: Michele M. Bradford, Esq. Atty. LD. #69849 1617 John F. Kennedy Boulevard Suite 1400 Philadelphia, PA 19103-1814 (71 'i) 'i1i,.7000 ATTORNEY FOR PLAINTIFF ASSOCIATES CONSUMER DISCOUNT COMPANY COURT OF COMMON PLEAS CIVIL DMSION vs. CUMBERLAND COUNTY OLEN JUMPER NK/A OLEN E. JUMPER NO. 01.6843 CIVIL THIS FIRM IS A DEBT COLLECTOR ATTEMPTING TO COLLECT A DEBT, ANY INFORMATION OBTAINED WILL BE USED FOR THAT PURPOSE. IF YOU HA VB PREVIOUSLY RECEIVED A DISCHARGE IN BANKRUPTCY AND THIS DEBT WAS NOT REAFFIRMED, THIS CORRESPONDENCE IS NOT AND SHOULD NOT BE CONSTRUED TO BE AN ATTEMPT TO COLLECT A DEBT, BUT ONLY ENFORCEMENT OF A LIEN AGAINST PROPERTY, MOTION FOR SERVICE PURSUANT TO SPErT AT. ORnF,R OF COTJRT Plaintiff, by its counsel, Michele M. Bradford, Esquire, moves this Honorable Court for an Order directing service of the Complaint upon the above.captioned Defendant(s) by Certified mail and regular mail to the Defendant's last known address and mortgaged premises located at 230 WEST DAUPHIN STREET, ENOLA, P A 17025 and in support thereof avers the following: 1. Attempts to serve Defendant(s) with the Complaint have been unsuccessful, as indicated by the Sheriffs Return of Service attached hereto as Exhibit "A". 2. Pursuant to Pennsylvania Rule of Civil Procedure 430, Plaintiff has made a good faith effort to locate the Defendant(s). An Mfidavit of Reasonable Investigation setting forth the specific inquiries made and the results is attached hereto as Exhibit "B". CZC, Svc Dept. H:/Main Fonns/motions/county.comp '.i'_4iW"fi\>::~'q__,~ ,"- , .,' "'~""r ~'''" -r . " . 3. Internal records reviewed by Plaintiff and has not been contacted br defendant as of n""p.mhp.r ::11, 2001 to bring loan current. 4. Plaintiff submits that it has made a good faith effort to locate the defendants, but has been unable to do so. WHEREFORE, Plaintiff respectfully requests this Honorable Court enter an Order pursuant to pennsylvania Rule of Civil Procedure 430 directing service of the Complaint by certified mail and regular mail. ~ Michele M. Bradford, Esqwe CZC, Svc Dept. H:/Main Forms/moti011s/county.comp . "'Z'!'-Wm;;;;,,:,,, ,. "~_"IF~1I!!i!J I' . ,~" ~~ ._~ .~,=..",.o". ,_~,"","" FEDERMAN AND PHELAN ATTORNEY FOR PLAINTIFF BY: Michele M. Bradford, Esq. Atty. !.D. #69849 1617 John F. Kennedy Boulevard Suite 1400 Philadelphia, PA 19103-1814 (71 "i) "i1i1- 7000 ASSOCIATES CONSUMER DISCOUNT COMPANY vs. COURT OF COMMON PLEAS CNIL DMSION CUMBERLAND COUNTY NO. 01.6843 CNIL OLEN JUMPER AIK/ A OLEN E. JUMPER MF.MORANllTTMOFT.AW Pennsylvania Rule of Civil Procedure 430( a) specifically provides: (a) If service cannot be made under the applicable rule, the plaintiff may move the Court for a special order directing the method of service. The Motion shall be accompanied by an Affidavit stating the nature and extent of the investigation which has been made to determine the wbereabouts of the Defendant(s) and the reasons why service cannot be made. Note: A Sheriffs return of ''Not Found" or the fact that a Defendant has moved without leaving a new forwarding address is insufficient evidence of concealment. ('........,'7~lp<: V<l Pn1i<l, 238 Pa. Super. 362, 357 A.2d 580 (1976). ''Notice of intended adoption mailed to last lmown address requires a good faith effort to discover the correct address." Anoptinn nfWQ11cP.T, 468 Pa. 165,360 A.2d 603 (1976). An illustration of good faith effort to locate the defendant includes (1) inquires of postal authorities including inquiries pursuant to the Freedom of Infonnation Act, 39 C.F.R Part 265, (2) inquiries of relatives neighbors, friends and employers of the Defendant and (3) examinations of local telephone directories, voter registration records, local tax records, and motor vehicle records. As indicated by the attached Sheriff's Return of Service, attached hereto and marked as Exhibit "A", the Sheriff has been unable to serve the Complaint. A good faith effort to discover the whereabouts of the Defendant(s) has been made as evidenced by the attached Affidavit of Reasonable Investigation, marked Exhibit "B". WHEREFORE, Plaintiff respectfully requests service of the Complaint by certified mail and regular maiL Respectfully submitted: ~ Michele M. Bradford, Esquire H:lMain Forms/motions/county.comp ""W!$'-\l;~!"V',_, ^ ~~-=. ,,-~~~-"""'''''~~ - ~----i ~~ ,of M~ -- ~ -~... ~,. o'II')""'~'lf1""'~-C ...........~.$.'-...L...j..... ..... .L\.~.J.. U.l.\...L'I - - .L.\lv.l r VUl.\lLJ CASE NO: 2001-06843 P . COM~ONWEALTH OF PENNSYLVANIk COUNTY OF CUMBERLAND ASSOCIATES CONSUMER DISCOUNT VS JUMPER OLEN E R. Thomas Kline ,Sheriff or Deputy Sheriff, who being duly sworn according to law, says, that he made a diligent search and inquiry for the within named defendant, DEFENDANT JUMPER OLEN E but was unable to locate Him in his bailiwick. He therefore returns the COMPLAINT - MORT FORE , NOT FOUND , as to the within named DEFENDANT , JUMPER OLEN E DEFENDANT DOES NOT LIVE AT ADDRESS PROVIDED. Sheriff's Costs: Docketing Service Not Found Surcharge So answe_rs', 18.00 9.75 5.00 10.00 .00 42.75 - , -~ ",?::~~~;;;';-:'::;;;~~~-~;1;~;~'t:-o;;, R.' Thomas Kline Sheriff of Cumberland County FEDERMAN & PHELAN 12/13/2001 Sworn and subscribed to before me this day of A.D. Prothonotary 'EXHIBIT A '-H"'",~~, .-t'_, '''''_~_ , ,),,..,,- " 1."',-'< r,',' " ,~, "'" > - .' <. ' _~" -"--'"'''-l_'_~O' EKL nATA, INC . AFFIDAVIT OF GOOD FAITH INVESTIGATION Loan Number: File Number: Attorney Firm: Federman & Phelan Subject: Olen Jumper Property Address 230 West Danphin Street Enola, P A 17025 Last Known Address; P.O. Box 9 Enola, P A 17025 Current Address; 230 West Dauphin Street Enola, P A 17025 Last Known Number; George H. Lewis, III, being duly sworn according to law, deposes and says; I, I am employed in the capacity of researcher for EKL DATA, INC. 2. On September 12, 2001, I conducted an investigation into the whereabouts ofthe above named defendant(s). The results of my investigation are as follows: 1. Credit Information A. Social Security Number 1. Olen Jumper: 162.22-1583 B. Employment Search: Could not locate any employment information for the above named subject at this time. C. Inquiry of Creditors: The creditors indicated that Olen Jumper resides at 230 West Dauphin Street, Enola, PA 17025. II. Inquiry of Telephone Company A. Directory Assistance Search: The Telephone Company has no listing for the above named subject at this time. III. Inquiry of Neighbors Could not locate any neighbors for the above named subject at this time. IV, Inquiry of Post Office A, National Address Update: As of September 13, 2001tbe National Change of Address has no forwarding record for Olen Jnmper listed at P.O. Box 9, Euola, PA 17025. V, Inquiry of DMV The Peunsylvania Department of Motor Vehicles has Olen Jnmper listed at 230 West Dauphin Street, Enola, P A 17025. EXHIBIT "B" --i~'.).___~~_<,~". 0..' ~~ "-,~ '1--' "'" ~',' "_'7_ _' - -" " , ~~,~ .,~-~_.=' EKL DATA, INC AFFIDAVIT OF GOOD FAITH INVESTIGATION VI. Other Inquiries A, Death Records: As of September 12,2001 the Social Security Death Index bas no deatb record on file for Olen Jumper under his social security number. B. Public Licenses None Found C. County Voter Registration: The county does not have Oleo Jumper listed as a registered voter with an address of 230 West Dauphin Street, Enola, PA 17025. D. D,O.B.: Olen Jnmper: 07/00/1930 E. Miscellaneous Information None i I L Suhscribed and sworn before me on September 12, 2001. ~~&AAh Notary Public i----:~ ,', ' I I 'fotanal Seal I I Ellen K. Lewis, NotGry Public 1 I' Lower Merj~n !WP;.r M,ontgoillBry County' j , My Co.mmlsSlon l:.xpres Feb 24, 2003 ! --'~~~""'-~._"--'",~--~-"",,~,---- EKL DATA, INe. e 66 Brookline Boulevard e Havertown, PA 19083 Tel.: 1.888-829-5768 e Fax: 610-446.2779 e email: ekl-data@home.com EXHIBIT "Bit ",1!ii';;k~___ JI!ll~""_., " A,,_~. "':."," "- ., ~'I' .~ ',1" _~ I' - ._,~_ FN"l . ' Vii: R TFTC A TTON Michele M. Bradford, Esquire, hereby states that she is the Attorney for the Plaintiff in this action, that she is authorized to take this Affidavit, and that the statements made in the foregoing MOTION FOR SERVICE PURSUANT TO SPECIAL ORDER OF COURT are true and correct to the best of her knowledge, information and belief. The undersigned understands that this statement herein is made subject to the penalties of 18 Pa. C.S. Sec. 4904 relating to unsworn falsification to authorities. Date: n,,""mh"T 11 ?001 . ~ Michele M. Bradford, Esquire H:lMain Fonns/motions/county.comp "',f';t-:t,l"r,.,-_,_~ ",~_.....__~.,_ r- ,~-. , ,~-~ ~r ~,_ ~ - ~ ~" ~- - ~"l"'!;"""'~"- Cl ~ ~r~, ~~~i: 2:; t~ ~ "l> ~, bb J>'c:: :z -<! r' f::) '" ~~ -"-)C~J '-- ~:; ~~} v 3-:: _'-:: 'I ~~~ ~~:) i-.) :-;;! :::-0 -< tf! f0 ~_ ~ ,_ ."_ __q,_~~""<,~__~~,,,,_"'~~'" ,__,~~)~~l!8~-'ii\1),.!I[,,_ ,-_~ll. J-~~~,<:,;,__"_I. ,_ If~_~~~j;!'ifIF%':-"H/'1;"'~-"''-~]:'W-','s"F<1;:P;-;'l{M~~~~g;:]N!ft~~B.r1~~[\j~~~~J '!!I!!II!,., ,~~"~~, ~ - FEDERMAN AND PHELAN BY: FRANKFEDERMAN,ESQUIRE Identification No. 12248 1617 John F. Kennedy Boulevard Suite 1400 Philadelphia, PA 19103-1814 (? 1 'i) 'i1l,.7000 ASSOCIATES CONSUMER DISCOUNT COMPANY Plaintiff vs. OLEN JUMPER A/K/A OLEN E. JUMPER Defendants "~" ",,~:,,~;,p \-,C' Attorney for Plaintiff COURT OF COMMON PLEAS CIVIL DIVISION Cumberland County No. 01-6843 CIVIL PRAECIPE TO REINSTATE CIVIL ACTION/MORTGAGE FORECLOSURE TO THE PROTHONOTARY: Kindly reinstate the Civil Action in Mortgage Foreclosure with reference to the above captioned matter. Date: February 22, 2002 CZC, SVC DEPT , 1;fu!ji. 'c', ,~__. , , ~< [, " - '1 '~ ~ FRANK FEDER~SQUIRE Attorney for Plaintiff 1"" I " ""~jmrr (') 0 C f\.:> 0 ;s:: """l " [Rm 1"'1 ,.-.--t zQ:l OJ T z-.::! N i'-:iJ~1 \ 8:? ~~ (J) <iF? r-: d." ~C::'l -.:' ::,j<;) Po 2(."' :Jr. g~~ )> " ~ c: :2: --I :;;;I .:J1 $ , \,0 -< Es $I . "," ,.n-'. ,','" _.",.~,,",,~_, "_ c}'"'f. ','.","""_ _,:,'f'm'c'""': - ',~ -.'" ~ ,__,,.\,_y,_:o.:_".,_,~._~,~!;.,,,,,~,,._,~~_~!i!t;Pi1:~;;iWt"'{",HJ;;W"!');';T,)c,?':--?'~"*~::!M~~,_ _, .'<' ~J,0'l-\",;'r!lI'~f,~_, <~,~,,~~~i-' rr~. r. FEDERMAN AND PHELAN By: FRANK FEDERMAN, ESQUIRE Attorney I.D. No. 12248 Suite 900 - Two Penn Center Plaza Philadelphia, PA 19102 (215) 563 -7000 Attorney for Plaintiff ASSOCIATES CONSUMER DISCOUNT COMPANY COURT OF COMMON PLEAS CIVIL DIVISION vs. CUMBERLAND COUNTY No. 01-6843 CIVIL OLEN JUMPER A/K/A OLEN E. JUMPER AFFIDAVIT OF SERVICE BY PUBLICATION IN ACCORDANCE WITH COURT ORDER I hereby certify that service of the Civil Action Complaint in Mortgage Foreclosure was made in accordance with the attached Court Order dated JANUARY 17,2002 as indicated below: By publication as provided by Pa. R.C.P. Rule 430(b) in the Sentinel on Februarv 2.2002 and Cumberland Law Journal on Februarv 8.2002. Proofs of the said publications are attached hereto. The undersigned understands that this statement is made subject to the penalties of 18 Pa. C.S. Section 4904 relating to unsworn falsification to authorities. ~~- FRANK FEDE ,ESQUIRE DATE: February 22, 2002 ~ g.;,!,Y# '#)\;~"~'~ '. "'-, -~= 11!l' "-1 ,. ,~, . ""e.~ . ~ "'1~-"~'~ :: FEDERMAN AND PHELAN . BY: Michele M. Bradford, Esq. Atty. !.D. #69849 1617 John F. Kennedy Boulevard Suite 1400 Philadelphia, PA 19103.1814 (? 1 ~) ~()1. 7000 ATTORNEY FOR PLAINTIFF ASSOCIATES CONSUMER DISCOUNT COMPANY COURT OF COMMON PLEAS CIVa DIVISION vs. CUMBERLAND COUNTY OLEN JUMPER NKJA OLEN E. JUMPER NO. 01.6843 CIVIL ---.." ~ ~ --"- '".. AND NOW, this I 7-r:h ORDER day of J.MN HAd ,20~upon consideration of Plaintiff's Motion for Service Pursuant to Special Order of Court and the Affidavit of Reasonable Investigation attached thereto, it is hereby ORDERED that Plaintiff may obtain service of the Complaint on the above captioned Defendant(s) OLEN JUMPER AfKIA OLEN E. JUMPER, by mailing a true and correct copy of the Complaint by certified mail and regularmailto the Defendant's last known address, and to the mortgaged premises located at 230 WEST DAUPIDN STREET,ENOLA,PA,.:Q02;;,-.{ ~ ~....:.~ ~ p Co . fL.(,.!. tf "; () I...b) (1'\ . Service of the aforementioned mailings is effective upon the date of mailing and is to be done by Plaintiffs attorney, who will file with the Prothonotary's Office an Affidavit as to the mailing. CZC, Svc Dept. TRUE COpy' FROM . RECOR~ nd In Testimony whereof, \here un!? set ,my a." ' and the seal of sa'd court~arh~:.pa'~;~g T~l 17., ,f.........l...CJ!,. . 'fff In "0"." .... . . . . ....... ' ......... rothonotary H:!Main Fonnslmotions!county.comp , PROOF OF PUBLICATION State of Pennsylvania, County of Cumberland. Lori Saylor, Classified Advertising Manager of THE SENTINEL, of the County and State aforesaid, being duly sworn, deposes and says that THE SENTINEL, a newspaper of general circulation in the Borough of Carlisle, County and State aforesaid, was established December 13th, 1881, since which date THE SENTINEL has been regularly issued in said County, and that the printed notice or publication attached hereto is exactly the same as was printed and published in the regular editions and issues of THE SENTINEL on the following dates, viz Copy of Notice of Publication ____'_m_~~. NOTICE OF ACTION IN MORTGAGE FORECLOSURE IN THE COURT OF COMMON PLEAS OF , .CU.'Ji'SERLAND COUNTY, PENNSYLVANIA '.:'.... CIVILACTION-LAW,' NO. 01-6843 CIVIL - ASSOC'IATES CONSUMER DISCOUNT ,COM,PANY, PLAINTIFF GLEN JU~PER AlK/A GLEN E. JUMPER, DEFENDANT' .... NOTICE TO GLEN JUMPER NKlA OLEN E. JUMPER: You ar:e 'hereby notified that on December ~ 2001, Plaintiff, ASSOCiATES CONSUMER DISCOU~T . COMPANY, filed a Mortgage Foreclos~re Complaint endo~ed with a Notice to Defencl, against you In the Courfbf Common Pleas of CUMBERLAND County, . Penn'sylvania, docketed to No. 01-6843 CIVIL 'Wherein Plaintiff seeks to foreclose on the mortgage se- cured .on your property located at 2.30 WEST DAU. ,: PH IN ,STREET, ENOLA, PA 17025, ,:"hereupon your "p'rOP.~'r:1y would 'be sold by the Sheriff .of CUMBER- LAND' County. You are hereby notified to plead to the above reference:d . Compiaint on or before 20 days from the da~e of thiS publication or a Judgment will be entered agamst you. ['" NOTICE . Vou hav'e been sued in Court. It you wish to defend, you must enter a written appearance personally.or b~ .at- torney,. and file your defenses or o~jectlons: In ~rltlng , with lhe court. You are warned that If you fall to do so, .the'case may proceed without you and JUdQment may be ehtered against you without further notice for the ,reliefrequ8.sted by the: Plai~tift Yournay lose money, ('" 'the' p,roperty or ather nghts Important to you. . You sh~tdd take this notice to your lawyer at once. If you , do ITot have a lawyer or cannot afford .ona"go to or telephone the office set forth below to fmd out wh."i!re you can get legal help_ CUMBERLAND COUNTY CUMBERLAND COUNTY BAR ASSOCIATION 2 LIBERTY AVENUE CARLISLE, PA 17013 (717) 249-3166 FRANK FEDERMAN 'Attorri"ey- for Plaintiff , FEDER'MAN & PHELAN, LL.p 'One Penn Center, Suite 1400 Philadelphia, PA 19103 {215) 563.7000 FAhrllAry ::>, ::>00::> Affiant further deposes that he is not interested in the subject matter of the aforesaid notice or advertisement, and that all allegations in the foregoing statement as to time, place and character of publication are true. ~1'~/JAA~ February 6, 2002 Sworn to and subscribed before me this 6th day of February , 2002. ~{ 0 ~1/J1.VYJ I Notary Public _______L My commission expires: NOTARIAL SEAL SHIRLEY O. DURNIN, Notary Public Carlisle Bore" Cumberland County M Commission Expires Au ,9, 2003 J r , . , .. , y , PROOF OF PUBLICATION OF NOTICE IN CUMBERLAND LAW JOURNAL (Under Act No. 587, approved May 16, 1929), P. L.1784 STATE OF PENNSYLVANIA : ss. COUNTY OF CUMBERLAND : Roger M. MorgenthaI, 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, Viz FEBRUARY 8, 2002 Affiant further deposes that he is authorized to verifY this statement by the Cumberland Law Journal, a legal periodical of general circulation, and that he is not interested in the subject matter of the aforesaid notice or advertisement, and that all allegations in the foregoing statements as to time, place and character of publication are ~ Roger M. Morgenthal, Editor SWORN TO AND SUBSCRIBED before me this 8 day of FEBRUARY. 2002 cI.vv >>---'~"~ NOTARIAL 'SEAL LOIS E. SNYDER, Nolary Public Carlisle 80m, Cumberland County My Commlsslon Expires Marolt 5, 2005 ".,,,,K"""~_~~,,,,,~'!'"=___" - V'M .,- ,-,- -~ Rl!ilIIR _'A""""',~_, =~ ,..~ ~,_ ~''''"_."_ " ~ . - , . . CUMBERIAND lAW JOURNAL NOTICE OF ACTION IN MORTGAGE FORECLOSURE In the Court of Common Pleas of Cumberland County. Pennsylvania Civil Action-Law No. 01-6843 ASSOCIATES CONSUMER DISCOUNT COMPANY, PLAINTIFF vs. OLEN JUMPER. a/k/a OLEN E. JUMPER, DEFENDANT NOTICE TO OLEN JUMPER, a/k/a OLEN E. JUMPER: You are hereby notified that on December 3, 2001, Plaintiff, ASSO- CIATES CONSUMER DISCOUNT COMPANY. filed a Mortgage Fore- closure Complaint endorsed with a Notice to Defend. against you in the Court of Common Pleas of Cumber- land County. Pennsylvania. docket- ed to No. 01-6843 Civil. Wherein Plaintiff seeks to fore- close on the mortgage secured on your property located at: 230 West Dauphin Street, Enola. PA 17025. whereupon your property would be sold by the Sheriff of Cumberland County. You are hereby notified to plead to the above referenced Complaint on or before 20 days from the date of this publication or a Judgment will be entered against you. NOTICE You have been sued in Court. If you wish to defend, you must enter a written appearance personally or :,~-- ~~ ....~," .'"..'.''''<'_1.,' 'c- ,.,r=' by attorney, and file your defenses or objections in writing with the court. You are warned that if you fail to do so, the case may proceed without you and Judgment may be entered against you without further notice for the relief requested by the Plaintiff. You may lose money. the property or other rights important to you. You should take this notice 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 fmd out where you can get legal help. CUMBERLAND COUNIT CUMBERLAND COUNTY BAR ASSOCIATION 2 Liberty Avenue Carlisle, PA 17013 (717) 249-3166 FRANK FEDERMAN FEDERMAN & PHELAN, L.L.P. Attorneys for Plaintiff One Penn Center Suite 1400 Philadelphia, PA 19103 (215) 563-7000 Feb. 8 3 -,~ ^.-, ~_. -,-~-, '>""-, ,<-,' - " .... ,. ~. ~~ , <' . ~.,~-,~", , \,-. , " , () -C) () ~ I',", --l-~ ~~ "T1 ---1 ""'On:! f"1 (l1rT) '.']J Z::l.. 1'0 :zc:: ~2: (ji r:c; -0 <: ~o ...<:~ 2=5M C - , i.:'? ::Pee: P-4 -,.. :; :3 , r" -< ff; ~ ~ ,~_~ !~~~~~ ~ ,. n[~.J!j!~~II~ffl>~,",'YJ{..@ift4'-"~i;n"j'0"r"if\'~'W+1'--"\'}J-")'K"i@.~~ill'11i'<!'Mi.~1i_4'~f~~i?>V\\l_~_%!'l~_~'~~!!iW~~'Mi_!\!i W' FEDERMAN AND PHELAN "BY: FRANKFEDERMAN,ESQUlRE Identification No. 12248 One Penn Center at Suburban Station 1617 John F. Kennedy Boulevard Suite 1400 Philadelphia, PA 19103-1814 (71 'i) 'ilil-7000 Attorney for Plaintiff ASSOCIATES CONSUMER DISCOUNT COMPANY : COURT OF COMMON PLEAS Plaintiff : CIVIL DIVISION vs. : CUMBERLAND COUNTY OLEN JUMPER, AlK/A OLEN E. JUMPER : NO,01-6843-CIVIL Defendant( s) ~DA~TOFSER~CEOFCOMPLAThIT RV MATT, PIJRSTJ A NT TO COTJRT ORmm I hereby certifY that a true and correct copy of the Civil Action Complaint in Mortgage Foreclosure in the above captioned matter was sent by regular and certified mail, return receipt requested, to the following persons, to OLEN JUMPER, A/KJA OLEN E. JUMPER at 230 WEST DAUPHIN STREET, ENOLA, PA 17025 on MlIreh 1,2002, in accordance with the Order of Court dated JANUARY 17,2002. The undersigned understands that this statement is made subject to the penalties of 18 Pa, C.S, g4904 relating to unsworn falsification to authorities. Date: March 1, ?002 ~1 P;jl/l)jYfJJK -/ FRANK FEDERMAN, ESQUIRE Attorney for Plaintiff CZC, Svc Dept. ;';;rrg;_~_,_,_ .0 '" ,,,,,'\i,i',,,-- ~~~;,_ .~,,"., ''- i" '-='",'., '., - ~,,_" ~"_-;'. ,,'_~' " - " .",'._;c__ "0. ---..__".-,.~~. -~",,_ " ,~"'~_~'" _ "~_'_.~',_er-"-"" '~_~ o c. <' -ni':-c rn (--r< ?-:E! Zl_ ~~i ~~:: ~~ :2:_ -< -< C r'0 ~? 0'--"" .~-~ :::u I ~~ " ~_.i -c r:'2 ;'..) (51 ES 131/ l.;t!!!"","~_.."~ ,..,~, 1!4~II'Jl!!!_r'1!'~llr, _:_,~_,,, ~t';:_ __~_~~~~1~''iFNy,~"~,*-~q,'1'l'K,,w;'!W:if:'':-:;-I''t'''1~~im''~;~,~~~IJlf~_'r~r~-,~~ FEDERMAN AND PHELAN, LLP By: FRANK FEDERMAN Identification No. 12248 Attorney for Plaintiff ONE PENN CENTER AT SUBURBAN STATION 1617 JOHN F. KENNEDY BLVD., SmTE 1400 PHILADELPHIA, PA 19103-1814 (215\ 563-7000 ASSOCIATES CONSUMER DISCOUNT COMPANY 1111 NORTHPOINT DRIVE COPPELL, TX 75019 CUMBERLAND COUNTY COURT OF COMMON PLEAS CIVIL DIVISION Plaintiff, v. NO. 01-6843 CIVIL OLEN JUMPER AfI(,/A OLEN E. JUMPER 230 WEST DAUPHIN STREET ENOLA, PA 17025 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 OLEN JUMPER AlK/A OLEN E. JUMPER, Defendant(s) for failure to file an Answer to Plaintiff's Complaint within 20 days from service thereof and for Foreclosure and Sale ofthe mortgaged premises, and assess Plaintiff's damages as follows: As set forth in Complaint Interest from 11/16/0 I to 412/02 TOTAL $50,704.22 $2,363.94 $53,068.16 I hereby certify that (I) 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, rorvJ~^~ RANK FE ERMAN, ESQUIRE Attorney for Plaintiff DAMAGES ARE HEREBY ASSESSED AS INDICATED, DATE 4,;L 4,:JC0"- ~",--b , ?~ PRO PROTHY ,,\;~;'!t:'.i)@:l;~~'r "",,, )"-. ~,.."..- " !t'",,'" !l. ~- ; FEDERMAN AND PHELAN BY: Michele M. Bradford, Esq. Atty. LD. #69849 1617 John F. Kennedy Boulevard Suite 1400 Philadelphia, PA 19103-1814 (71 ~) ~fl1- 7000 , ATTORNEY FOR PLAINTIFF ASSOCIATES CONSUMER DISCOUNT COMPANY COURT OF COMMON PLEAS CIVIL DIVISION vs. CUMBERLAND COUNTY OLEN JUMPER NKI A OLEN E. JUMPER NO. 01-6843 CIVIL -', -". -,"",'-"- AND NOW, this / 7-r:h ORDER daYOfJJANHAtt.Y , 2~ upon consideration of Plaintiffs Motion for Service Pursuant to Special Order of Court and the Affidavit of Reasonable Investigation attached thereto, it is hereby ORDERED that Plaintiff may obtain service of the Complaint on the above captioned Defendant(s) OLEN JUMPER AlK/A OLEN E. JUMPER, by mailing a true and correct copy of the Complaint by Gertified mail and regular mail to the Defendant's last known address, and to the mortgaged premises located at 230 WEST DAUPHIN STREET,ENOLA,P1\.l.:zOZS~ ~ ~ c-:.~ ~ pc.., R,,(,...I. tt ~() \.b)(n, Service of the aforementioned mailings is effective upon the date of mailing and is to be done by Plaintiffs attorney, who will file with the Prothonotary's Office an Affidavit as to the mailing. . . T~UECOPY . FROM Rf.COR~and '. '!lJ%t\mony\,,pereof,lhefe\!~t~ setra: '. an~.the seal ofsa'd cou:':.J~j:., ..Q;g Jbi ......1.:1.- . '. .:....~ ___ not;YTl CZC, Svc Dept. H:lMain FomtS/motions/county.comp -,~ . , FEDERMAN AND PHELAN BY: FRANK FEDERMAN, ESQUIRE Identification No. 12248 1617 John F. Kennedy Boulevard Suite 1400 Philadelphia, PA 19103-1814 (71 ~) ~hi 7000 ASSOCIATES CONSUMER DISCOUNT COMPANY Attorney for Plaintiff COURT OF COMMON PLEAS CIVIL DIVISION Plaintiff vs. CUMBERLAND COUNTY OLEN JUMPER, A/K/A OLEN E. JUMPER NO. 01-6843-CIVIL Defendant(s) TO: OLEN JUMPER, A/K/A OLEN E. JUMPER 230 WEST DAUPHIN STREET ENOLA, PA 17025 COipy DATE OF NOTICE: MARCH 22. 2002 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 _?lJ\fLM..t- --' ~..e.tleA~ Prank Federman, Esquire Attorney for Plaintiff -~'#~, ,n_l, "~ ~,'~' ,c,_~ ~Ir -n =~ FEDE~ANandPHELAN,LLP By: FRANK FEDERMAN Identification No. 12248 ONE PENN CENTER AT SUBURBAN STATION 1617 JOHN F. KENNEDY BL YD., SUITE 1400 PIDLADELPIDA, PA 19103-1814 (215) 563-7000 ATTORNEY FOR PLAINTIFF ASSOCIATES CONSUMER DISCOUNT COMPANY 1111 NORTHPOINT DRIVE COPPELL, TX 75019 CUMBERLAND COUNTY COURT OF COMMON PLEAS CIVIL DIVISION Plaintiff, NO. 01-6843 CIVIL v. OLEN JUMPER AfKJA OLEN E. JUMPER 230 WEST DAUPHIN STREET ENOLA, PA 17025 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 OLEN JUMPER AlKJA OLEN E. JUMPER is over 18 years of age and resides at, 230 WEST DAUPHIN STREET, ENOLA, PA 17025. This statement is made subject to the penalties of 18 Pa, C.S. Section 4904 relating to unsworn falsification to authorities. ~~Q>.~~l'-. RANK F DERMAN, ESQUIRE Attorney for Plaintiff ,i'"'iJ,,._ '''t-'"~- ',._,,! ',' ,'co _ '''~_"~ -'l'1"I-' 1 ~-,-- ~', 'c" ,-.. - ~--~"""~-"-",,,",.,,>' (Rule of Civil Procedure No. 236) - Revised IN THE COURT OF COMMON PLEAS OF CUMBERLAND COUNTY, PENNSYLVANIA CIVIL ACTION - LAW ASSOCIATES CONSUMER DISCOUNT COMPANY 1111 NORTHPOINT DRIVE COPPELL, TX 75019 CUMBERLAND COUNTY COURT OF COMMON PLEAS CIVIL DIVISION Plaintiff, NO. 01-6843 CIVIL v. OLEN JUMPER AfK1A OLEN E. JUMPER 230 WEST DAUPHIN STREET ENOLA, PA 17025 Defendant(s). Notice is given that a Judgment in the above-captioned matter has been entered against you on ~'I(~ 200.;:1. ~y: 40/><.1/ DEPUTY P71;~ If you have any questions concerning this matter, 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 INFORMA nON OBTAINED WILL BE USED FOR THAT PURPOSE. IF YOU HA VE 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." ,'!,~rn: -T"!' __ __ o_~ "' ~-""-I-' ,."- ,", - f - ~f ,- - =" ~,... ,~~~~_t\-filrv;; i I :~ h ~'""~""_" - ,.,. , c ~ r ~ PJ' ~ ~' -, -~- ~~~ -' ~~ .-~ ~ :-0 8 ........ C\::: ~ \;J--U f-~~ v'\:.,~ ---Z:- -: o N :::- ., :::0 I ~ () '""::t fiii~ -0 IT! ::;'9 ~::~6 ;~~S~ ~5rn ;::,- ~ -< ::v(:) ~~, o c: R ""Ot"'>f; m-W ..,,(1::: ~-'-' 2;;: W~ ~4 ;<0 :s> 28 >c:: 2 =< V :JI: ~ w (,Xl ~J!!:rt~.,.. ~__~"_ '__~~~_"".~:' _ "~~ ,_ ,!Mi~~'!lf~W'R~'~""'i(,j)'g"::'i<l"';:'''''}."'''Fy'1t0, 'A;ji2J~jii>'!j!"l~O;t~~~iWi~i\:f<<~~Jiil_~~~~"J.i < , PRAECIPE FOR WRIT OF EXECUTION - (MORTGAGE FORECLOSURE) P.RC.P.3180-3183 ASSOCIATES CONSUMER DISCOUNT COMPANY Plaintiff, v. No. 01-6843 CIVIL OLEN JUMPER A1KJA OLEN E. JUMPER Defendant(s). TO THE DIRECTOR OF THE OFFICE OF THE PROTHONOTARY: Issue writ of execution in the above matter: Amount Due $53,068.16 Interest from 4/2/02 to 9/4/02 (per diem -$8.72) $1,351.60 and Costs TOTAL $54,419.76 f~~AMNR~ RANK F ERMAN, 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, '~i!f'~J:; _, , =-,-. - "elt .;~ .~ ~-"~=,~ ,..> '-m.'W;j;';,\~iJk&~:W;~'i~W"'c - ',,,., . '>~mJTi~n:;li:~~i!J.'~' ~ j-J>01l~iltu'!-4,,~HW~" _ _ f'I;::J (J #:- ~ ~ ~ (' f" V\0 . ' . , '~~-, . '~*dJ]dJ' tmM '." ~,,'~:'~ ~~~",;-"))(;cjj~i*",,i:f\i,*,dJl.itiJI "'" "iUIL!! ~ - ~ -4 ~ '- '- lC ~ c!j. t10 ~ <.:t :-t: :--.. ~ ~ g ~ ~t> d D ~ D &) () D- I , I p~ ~ 0 ~ ~ ~ N "- ~ :t>o --! ~ , ~ ~ ;3; :n ~ -0 OJ -0 ~ ;Xj p"r- ro,n ...."m , Z:.::f' I >>j:? ~ , ~ Z~ .1='" n -., ...) ~ cq? ::.1!-"-1 ~CJ -0 . -n ::ll: Qo ~8 N iSm )>c .. ~ ~ W 0:> :..<: ~.... 0 :> i~ 00 ="'" ~ r- oo l"'J== 'Tl l"'J 0 >- -. ~ ~ ?::!~ - <1> l"'J ... 8: p,.. ~ d ~ ~g (;l ... ~ '" j;;il l"'J t:l~ ::E ~ "= 00 Q ~ l"'J ~~ ~O ::r to> := 00 O"'l <1> .... e:= ~ (;l 0 ~~ ~~ "0 ~ :6~ ~ -< "=00 .g ~i:! S" ~; ""'0 l"'J ~~ til 00 S; "'" 0 ;;ilS "'" 3 t:l ~ 0 r- := ~ 6''''l l"'J t:l ~~ ~ '" l"'J ~ ... ~"= cr 00 <1> "= ~ >< t"I 8 ~r- '" == el"1 ... r-1"1 <1> =2 .... ~ c: c: ~~ ~ ~ c: ~ z 00 "'" ;;il "'" "'" .... "''''l g; 0 :> ~ := 1"1 :' 1"1 ~ 0 r- ~ "= :> .... -..J 0 to> Ul ~~~- - ,~~~ .,~.~, ~. , "~-'--~ " ""'- '-- , -~~, ~'" .- ~--- -~. . , ALL THAT CERTAIN lot or piece of land with buildings and improvements thereon erected situate in East Pennsboro Township, Cumberland C~unty, Pennsylvania, bounded and described as follows, to wit: BEGINNING at a point in the Southern line of Dauphin Street at or opposite the center of the partition wall dividing properties known as No. 230 and 232 Dauphin Street, said point being Two Hundred Twenty-Nine and Thfee Hundred Eighty-Nine One-Thousands (229,389) feet East of the Southeast corner of Bri 'Church Road and Dauphin Street; thence along the Southern line of Dauphin Street, North 79 grees 40 minutes East, Forty-Six (46) feet to a point; thence South 10 degrees 20 minutes East, 0 Hundred Seventeen and Five Hundred Five One-Thousandths (117.505) feet to a point; thence Sou 79 degrees 40 minutes West, Forty-Six (46) feet to a point at or opposite the center of the partition wall dividing properties known as No. 230 and 232 Dauphin Street; thence North 10 degrees 20 minutes West through the center of the partition wall dividing properties known as No. 230 and No. 232 Dauphin Street and beyond One Hundred Seventeen and Five Hundred Five One-Thousandths (117.5005) feet to a point, at the place of beginning. . HAVING thereon erected the Eastern One-half of a two story dwelling known as No. 230 Dauphin Street, Enola, Pennsylvania. TAX PARCEL # 09-14-0832-201 Premises: /230 DAUPHIN STREET, TOWNSHIP OF EAST PENNSBORO I CUMBERLAND COUNTY PENNSYLVANIA TITLE TO SAID PREMISES IS VESTED IN Olen E. Jiimper, widower by reason of the following BEING THE SAME premises which Theodore E. Sgrignoli and Winifred E. Sgrignoli, his wife by Deed dated 8/29/63 and recorded 8/29/63 in the County of Cumberland in Deed Book Y, Volume 20, Page 737 conveyed unto Olen E. Jumper and Romaine M, Jumpef, his wife, . . AND THE SAID Romaine M. Jumper died on 7/20/99 whereby title to said premises became vested in Olen E. Jumper by fight of survivorship. (~.,.c , ~ ~ I','. . , ' -~. ~, -. .~~,,~" JJ! FEDERMAN and PHELAN, LLP By: FRANK FEDERMAN Identification No. 12248 ONE PENN CENTER AT SUBURBAN STATION 1617 JOHN F. KENNEDY BLVD., SUITE 1400 PHILADELPmA, PA 19103-1814 (215) 563-7000 ATTORNEY FOR PLAINTIFF ASSOCIATES CONSUMER DISCOUNT COMPANY CUMBERLAND COUNTY COURT OF COMMON PLEAS Plaintiff, v. CIVIL DIVISION OLEN JUMPER AIKIA OLEN E. JUMPER NO. 01-6843 CIVIL Defendant(s). CERTIFICATION FRANK FEDERMAN, ESQUIRE, hereby verifies that he is attorney for the Plaintiff in the above-captioned matter, and that the premises are not subject to the provisions of Act 91 because it is: o an FHA mortgage () non-owner occupied () vacant (X) Act 91 procedures have been fulfilled This certification is made subject to the penalties of 18 Pa, C.S. Section 4904 relating to unsworn falsification to authorities. 't~Q^^^~ RANK F . ERMAN, ESQUIRE Attorney for Plaintiff ,;"JlF(.~*, - ~ '" ~I - ~.- ., _,~4..._. "", .~~ =- . .- ~,__~" ,^.,~" 'o''''.H-"_~ "<~,,-~- ~ -"',.~" " ,."-'''-' ~ j 'j ~ - " "~"F__ _ .-f!VI1ifl!_~,l('~_!1!-:"M~!'l\!, '-7"-~"~ ,.' ""-.~,,.~M_ __"'__ (") 0 0 C N -n s:: "" .-1 ~~ " :..:~~ ;;0 :z~: I +- ~'i"~'O (f).c. O:l -<2 ~O ::::::;ie)- -0 1 -1";; )>0 3 j~-:D '''Hl 60 z )>c ~ 0' ~ V.) ?5 (Xl '< ~_~,l)jl!~;W!!I.;;iJi<-@_,';1";\~j1~j(_'~(i'-"~F;;f'"r""'_",,'~'4'Jf'!f~~;;P!ijm:~"~W1.'!l'i!~~~~~ii ASSOCIATES CONSUMER DISCOUNT COMPANY CUMBERLAND COUNTY Plaintiff, COURT OF COMMON PLEAS v. CIVIL DIVISION OLEN JUMPER AIKIA OLEN E. JUMPER NO. 01-6843 CIVIL Defendant(s). AFFIDAVIT PURSUANT TO RULE 3129 (Affidavit No.1) ASSOCIATES CONSUMER DISCOUNT COMPANY, 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 .230 WEST DAUPHIN STREET. ENOL^- P A 17025 . 1. Name and address ofOwner(s) or reputed Owner(s): Name Last Known Address (if address cannot be reasonably ascertained, please indicate) OLEN JUMPER AlKJA OLEN E. JUMPER 230 WEST DAUPHIN STREET ENOLA, PA 17025 2, Name and address ofDefendant(s) in the judgment: Same as above 3. Name and last known address of every judgment creditor whose judgment is a record lien on the real property to be sold: Name Last Known Address (if address cannot be reasonably ascertained, please indicate) None 4. Name and address of last recorded holder of every mortgage of record: Name Last Known Address (if address cannot be reasonably ascertained, please indicate) None :,~~~_iOO!J.~:~'U, _ , 'Co " 0'f'11 ,,- "..r .r ,--~ - ~ T _.~~ 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) EAST PENNSBORO TOWNSHIP 98 S. ENOLA DRIVE ENOLA, P A 17025 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) COMMONWEALTH OF PA BUREAU OF INDMDUAL TAX INHERITANCE TAX DMSION ATTN:JOHNMURPHY ~HFLOO~STRAWBERRYSQUARE DEPT. 280601 HARRlSBURG,PA 17128 DEPARTMENT OF PUBLIC WELFARE TPL CASUALTY UNIT ESTATE RECOVERY PROGRAM P.O. BOX 8486 WILLOW OAK BUILDING HARRlSBURG,PA 17105-8486 INTERNAl- REVENUE SERVICE FEDERATED INVESTORS TOWER TIDRTEENTH FLOO~ SillTE 1300 1001 LIBERTY AVENUE PITTSBURGH, PA 15222 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 230 WEST DAUPHIN STREET ENOLA, PA 17025 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 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, March 27. 2002 DATE ltP>",-~Q~ RANK FE ERMAN, ESQUIRE Attorney for Plaintiff ;~_1;;~lY;;"""",,~, ,',-." _'-'-I'r"" ., ,.r -~~; .,.,-"" _u ~- ~"~ ,~~ '",' "'-','" ,....,,~-< ,. , 2 0 0 N -n s:: .;t>o -age, -0 ,~ IT}.", :;0 !'-~i;Q Z:::t} '~-Jl-n Zi- t 0))> ..,. -US: ~b C'~U -0 .:;.I ~1"; )> ::a: i:S-~ ZO ';;.'() -0 ~ Om ~~ ,(..) ~ :n eo -< .~,_, ~..,,~"_)1'1:'"' jU:J. .-=.,,~~_i! ,~'j!,_,,,,,~~~~Jlfiit~~lf.@;ll1i~~?;r,",!~,*~;"fjj;".W,;<"f"'''['''4V*'F{~~Jiill~~~~~~~Il'f.i\- ~ ASSOCIATES CONSUMER DISCOUNT COMPANY CUMBERLAND COUNTY Plaintiff, No. 01-6843 CIVIL v. OLEN JUMPER AIKIA OLEN E. JUMPER Defendant( s). March 27, 2002 TO: OLEN JUMPER AlKlA OLEN E. JUMPER 230 WEST DAUPHIN STREET ENOLA, PA 17025 "THIS FIRM IS A DEBT COLLECTOR A TTEMPTING TO COLLECT A DEBT AND ANY INFORMA 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 NOTBE CONSTRUED TO BE AN A TTEMPT TO COLLECT A DEBT, BUT ONL Y ENFORCEMENT OF A LIEN A GAINST PROPERTY. " Your house (real estate) at. 230 WEST DAUPHIN STREET. ENOLA. PA 17025, is scheduled to be sold at the Sheriffs Sale on 9/4/02 at 10:00 a,m. in the CumberllU1ld County Courthouse, South Hanover Street, Carlisle, PA 17013, to enforce the court judgment of$53,Q68.16 obtained by ASSOCIATES CONSUMER DISCOUNT COMPANY (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: 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,) ',~!!F,!!i~~li!i' :<'",",," "~""c~,"c .>< l ", , ~,., 'f'.~ ~_ ~l>.,,_ ._,~~ ~~~ YOU MAY STILL BE ABLE TO SAVE YOUR PROPERTY AND YOU HAVE OTHER RIGHTS EVEN IF THE SHERIFF'S SALE DOES TAKE PLACE. I. If the Sheriff's Sale is not stopped, your property will be sold to the highest bidder. You may find out the price bid by calling (215) 563-7000. 2. You may be able to petition the Court to set aside the sale ifthe 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 ofthe money which was paid for your house. A schedule of distribution of the money bid for your house will be filed by the Sheriff 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 immediately after the sale. YOU SHOULD TAKE THIS PAPER TO YOUR LAWYER AT ONCE. IF YOU DO NOT HAVE A LAWYER OR CANNOT AFFORD ONE, GO TO OR TELEPHONE THE OFFICE LISTED BELOW TO FIND OUT WHERE YOU CAN GET LEGAL HELP. CUMBERLAND COUNTY ATTORNEY REFERRAL CUMBERLAND COUNTY BAR ASSOCIATION 2 LIBERTY AVENUE CUMBERLAND COUNTY COURTHOUSE CARLISLE, PA 17013 (717) 249-3166 (800) 990-9108 ;':'~lm:['i!f! ~~,",_ , J\ .-~" , 'P <' '''"1''- ., " , < ~~ ~-"" ., ALL THAT CERTAIN lot or piece of land with buildings and improvements thereon erected situate in East Pennsboro Township, Cumberland County, Pennsylvania, bounded and described as follows, to wit: ' BEGINNING at a point in the Southern line of Dauphin Street at or opposite the center of the partition wall dividing properties known as No. 230 and 232 Dauphin Street, said point being Two Hundred Twenty-Nine and Thfee Hundred Eighty-Nine One-Thousands (229.389) feet East of the Southeast corner of Bri "Church Road and Dauphin Street; thence along the Southern line of Dauphin Street, North 79 grees 40 minutes East, Forty-Six (46) feet to a point; thence South 10 degrees 20 minutes East,O Hundred Seventeen and Five Hundred Five One-Thousandths (117.505) feet to a point; thence Sou 79 degrees 40 minutes West, Forty-Six (46) feet to a point at or opposite the center of the partition wall dividing properties known as No. 230 and 232 Dauphin Street; thence North 10 degrees 20 minutes West through the center of the partition wall dividing properties known as No. 230 and No. 232 Dauphin Street and beyond One Hundred Seventeen and Five Hundred Five One-Thousandths (117.5005) feet to a point, at the place of beginning. . HAVING thereon erected the Eastern One-half of a two story dwelling known as No. 230 Dauphin Street, Enola, Pennsylvania. TAX PARCEL # 09-14-0832-201 Premises: /230 DAUPHIN STREET, TOWNSHIP OF EAST PENNSBORO / CUMBERLAND COUNTY PRNNSYL VANIA TITLE TO SAID PREMISES IS VESTED IN Olen E. JUmper, widower by reason of the following BEING THE SAME premises which Theodore E. Sgrignoli and Winifred E. Sgrignoli, his wife by Deed dated 8/29/63 and fecorded 8/29/63 in the County of Cumberland in Deed Book Y, Volume 20, Page 737 conveyed unto Olen E. Jumper and Romaine M. Jumper, his wife. . . AND THE SAID Romame M. Jumper died on 7/20/99 whereby title to said premises became vested in Olen E. Jumper by right of survivorship. "'-",,!"4.-'W<1!?>~_ -,. , ." ^. I) , - -~ ~"~~ - ~_~~",A-",~~.~ _ .1_ ..,. '0""'" ,-,'", <'"~ ~ .,....,."-"."~.. '''",oe."",,,' ,-,''''''' "'.-... .,~.-~ (") 0 0 C, N -n g: ;co. --I f -ucp -u i{i;1? mrn Al -,. :l:! I -V1f11 Z'c ,.,0 m"",,~ .r.- :"'~ ~e -0 :~~ ~ ::T- IJC) 52 Z-rn ~ 0 ~ z w 55 ::<! <:0 -< -- .~~:~~f~~:l..~ i"~Sq'%i''li-~~~W~_- _~",It;.;"(Il;.~<;""~>80:&~'''':;('''1'it':1''i1.'-;Y''!F.l~''"T"''''i' ffW~I_"="..~_. __' _ ' i','- WRIT OF EXECUTION andlor ATTACHMENT COMMONWEALTH OF PENNSYLVANIA) COUNTY OF CUMBERLAND) TO THE SHERIFF OF CUMBERLAND COUNTY: To satisfy the debt, interest and costs due ASSOCIATES CONSUMER DISCOUNT COMPANY, NO 01-6843 Civil CIVIL ACTION - LAW Plaiutiff (s) From OLEN JUMPER A!KIA OLEN E. JUMPER, 230 WEST DAUPHIN STREET, ENOLA, PA 17025 (I) You are directed to levy upon the property ofthe defendant (s)and to sell SEE LEGAL DESCRIPTION. (2) You are also directed to attach the property of the defendant(s) not levied upon in the possession of GARNlSHEE(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 defeudant (s) and from delivering any property of the defendant (s) or otherwise disposing thereof; (3) If property of the defendant( s) not levied upou an subj ect to attachment is found in the possession of anyone other than a named garnishee, you are directed to notify hirnlher that he/she has been added as a garnishee and is enjoined as above stated. Amount Due $53,068.16 L.L. $.50 Interest FROM 4/2/02 TO 9/4/02 (PER DIEM - $8.72) $1,351.60 AND COSTS Atty's Conun % Due Prothy $1.00 Atty Paid $114.75 Plaintiff Paid Date: APRIL 4, 2002 Other Costs CURTIS R. LONG Prothonotary, Civil Division <...Bv: an~ 0 ~p . 7r;(/I/)/r. J--:U~ L '(j REQUESTING PARTY: Name FRANK FEDERMAN, ESQUIRE Address: ONE PENN CENTER AT SUBURBAN STATION 1617 JOHN F. KENNEDY BOULEVARD, SIDTE 1400 PHILADELPHIA, PA 19103-1814 Attorney for: PLAINTIFF Telephone: 215-563-7000 Supreme Court ID No. 12248 "~~"'~ ,~" ~ - ~ - '1-' - - '7'''' ""~'" T~1llm'ij >~4~~~~t~.,ffl:j;~~~~i1lif;Sit,~;(Jj!~1il!B>s2",JM'~''':;^f;-,'''fu,,_,,!-;,.;,rl~:;~M;"'>"'"S".;j,";,ki,1WJ:JiI;:I!1in~ _6",=~ -'--'-R~~~.di~;'~ ~~ ,~~)~,J.,vH ..1.M~L_"..~...ql.... ,'......,...,...." ....._.... , 'L''; '<f\"', O\,..,,'~l,\'- t\J'\-- " ~' 'J' "_0,_ .v_"_.~,,,.^~____~_"c, ..-~,M '::-\\~\\\{'~ r.<;,-\':\,' .,' ,t'~')' "'\ '\)I- '5",=,1.\\\ '_',I ....1;- ",' ,-;\','-, t:.\\\\.. ;-) ",1 ~ ,\ - . ~ \ \ h t\\-~ \, !\... "'..lIuti- .d' -....., "'"'= WRIT OF EXECUTION and/or ATTACHMENT COMMONWEALTH OF PENNSYLVANIA) COUNTY OF CUMBERLAND) NO 01-6843 Civil CIVIL ACTION - LAW TO THE SHERIFF OF CUMBERLAND COUNTY: To satisfy the debt, interest and costs due ASSOCIATES CONSUMER DISCOUNT COMPANY, Plaintiff (s) From OLEN JUMPER AfKIA OLEN E. JUMPER, 230 WEST DAUPHIN STREET, ENOLA, PA 17025 (I) You are directed to levy upon the property ofthe defendant (s)and to sell SEE LEGAL DESCRIPTION. (2) You are also directed to attach the property of the defendant(s) not levied upon in the possession of GARNISHEE(S) as follows: and to notify the garnishee(s) that: (a) an attachment has been issued; (b) the garnishee(s) is enjoined from paying any debt to or for the account of the defendant (s) and from delivering any property of the defendant (s) or otherwise disposing thereof; (3) If property of the defendant(s) not levied upon an subject to attachment is found in the possession of anyone other than a named garnishee, you are directed to notify lrirnlher that he/she has been added as a garnishee and is enjoined as above stated. Amount Due $53,068.16 L.L. $.50 Interest FROM 4/2/02 TO 9/4/02 (pER DIEM - $8.72) $1,351.60 AND COSTS Ally's Comm % Due Prothy $1.00 Ally Paid $114.75 Plaintiff Paid Date: APRIL 4, 2002 Other Costs CURTIS R. LONG Prothonotary, Civil Division ~ a(J~ 0 P 7f/?/uv. r,fJr4:7 REQUESTING PARTY: Name FRANK FEDERMAN, ESQmRE Address: ONE PENN CENTER AT SUBURBAN STATION 1617 JOlIN F. KENNEDY BOULEVARD, SmTE 1400 PHILADELPHIA, PA 19103-1814 Attorney for: PLAINTIFF Telephone: 215-563-7000 Supreme Court ID No. 12248 TRUE COPY FROM RECORD l" 'f68tlmonywherllOf, i hera unto set my 118M t,,;(1 the seal of said COlIn at Carlisle, PI. ~~daYOf~ ~ ~ n/).o P. ..~ .' -'~!?!'(;,~'i!~$~"""",,,_ _.,," 'ffl""lr, .~~ '~'''I ~ .. '" ~"'.~" ~ ~ "',!'W!~ . t~;i~~~~$oJ!M;'W!iit,,~~ki,:r~~A5iOll:Wijij~Hloj"Jt-,M~I~I' \,"?.;k,:"',;c'cO"",,i ,"!~~",,'~'.W:"' ",'",,,,;:";r~tilii1i~~~~'jjj;ii.~iL~M!iIili1i1;,~~~'" : ,< ,.,~~.u'i~1!i!lilli \)'iY:~"c (,\j\.\':'.' i.w~ (",,\-;:Ii\\rt .",- 1i ;.. -,''.\~\' ~ 'J c;, ~\\t j S\\ \1 . . \ "'~ J ?t-'h\": ..'\ '< \ - - . \" :,",'\ "", 1\' ' "';;""~ >.~=- , -,.., ~... It[ .,>, WRIT OF EXECUTION and/or ATTACHMENT COMMONWEALTH OF PENNSYLVANIA) COUNTY OF CUMBERLAND) TO THE SHERIFF OF CUMBERLAND COUNTY: To satisfy the debt, interest and costs due ASSOCIATES CONSUMER DISCOUNT COMPANY, Plaintiff (s) From OLEN JUMPER A!K/A OLEN E. JUMPER, 230 WEST DAUPIDN STREET, ENOLA, PA 17025 NO 01-6843 Civil CIVIL ACTION - LAW (I) You are directed to levy upon the property of the defendant (s)and to sell SEE LEGAL DESCRIPTION. (2) You are also directed to attach the property of the defendant(s) not levied upon in the possession of GARNISHEE(S) as follows: and to notify the garnishee(s) that: (a) an attachment has been issued; (b) the garnishee(s) is enjoined from paying any debt to or for the account of the defendant (s) and from delivering any property of the defendant (s) or otherwise disposing thereof; (3) If property of the defendant(s) not levied upon an subject to attachment is found in the possession of anyone other than a named garnishee, you are directed to notify himlher that he/she has been added as a garnishee and is enjoined as above stated. Amount Due $53,068.16 L.L. $.50 Interest FROM 4/2/02 TO 9/4/02 (PER DIEM - $8.72) $1,351.60 AND COSTS Atty's Comm % Due Prothy $1.00 Atty Paid $114.75 Other Costs Plaintiff Paid Date: APRIL 4, 2002 CURTIS R. LONG Prothonotary, Civil Division ~/r-f .r}.7rJr/?~ A 1- L r~~ REQUESTING PARTY: Name FRANK FEDERMAN, ESQIDRE Address: ONE PENN CENTER AT SUBURBAN STATION 1617 JOHN F. KENNEDY BOULEVARD, SIDTE 1400 PHILADELPmA, PA 19103-1814 Attorney for: PLAINTIFF Telephone: 215-563-7000 Supreme Court ill No. 12248 TRUE COPV FROM RECORD , ';;ml'l!m;my woorr;of. 11",,~f\'! l.ll1tQ set mybaM , ,ij ttifl seal of S<lid Cwrl al Carlisle. PI. ~ I~~Y~~~ Y;f~"'i;'"",-~"n" , ~'~~I' , ~~~, n. ~_,,~ _. --,. ._,J ~~\':\ \)."0'- \~, \) ") ~,?v. ;,~~,7j'~ ,i._,-fN"",!,-,'Y::;Jbl1-1lJ ':,tjh"0SMiiIDf~.i>ti~~~4!~!' "f'r ~~!Ltf-'am 'I '. " ~ c- f) f" t\ ,) J" ,,,,I'I' "\\'1'""-"",, :':";\\' \ '\' \; ", ':~ ~ \ ~ .. ~:",-_:,J)~,',~Qi 111[,,, _~ .,' "_""".__,,-i!',",,,~,_ ,_ ,fl_,~<, ,,"' ,~, ~,_ ~,__~~, "'" ,'~ -<0, _"".,",'.,~ ,',__~ _~ , -- " \? y~.\\ \'\ ';-..:' , .~" - ~-- ,--~". ;~ >;" ,-;,. r'jjiiliii:"'~" ,. ' """"-<""-ili~ r WRIT OF EXECUTION and/or ATTACHMENT COMMONWEALTH OF PENNSYLVANIA) COUNTY OF CUMBERLAND) NO 01-6843 Civil CIVIL ACTION - LAW TO THE SHERIFF OF CUMBERLAND COUNTY: To satisfy the debt, interest and costs due ASSOCIATES CONSUMER DISCOUNT COMPANY, Plaintiff (s) Prom OLEN JUMPER A/KJA OLEN E. JUMPER, 230 WEST DAUPHIN STREET, ENOLA, PA 17025 (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 issned; (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 him/her that he/she has been added as a garnishee and is enjoined as above stated. Amount Due $53,068.16 L.L. $.50 Interest FROM 4/2102 TO 9/4/02 (PER DIEM - $8.72) $1,351.60 AND COSTS Atty's Cornm % Due Prothy $1.00 Atty Paid $114.75 Plaintiff Paid Date: APRIL 4, 2002 Other Costs CURTIS R. LONG Prothonotary, Civil Division '-By: d~p _ [2 ~/)/l~J;'~ REQUESTING PARTY: Name FRANK FEDERMAN, ESQUIRE Address: ONE PENN CENTER AT SUBURBAN STATION 1617 JOHN F. KENNEDY BOULEVARD, SUITE 1400 PHILADELPIDA, PA 19103-1814 Attorney for: PLAINTIFF Telephone: 215-563-7000 Supreme Court ill No. 12248 TRUE COPY FAOM RECORD In Testimony whereof, IllfJre unto set my hand .~ld tI'l8 . 01 said COii'.... al Carlisle. Pa. T da 0 ;: ----'J,~)7n_;,)'*H~ ~~~ ~ ~,4'_!1f ,< "~,. -]" -~ ~-. .~ '''"''1 ' -~ ~!~'~'.(!('I~!1illitklli:,f,(tl-~~~i4\if~(i!';:".oc~~;h"fi:,r.",\ :_h.,__,-.":_";,,,,,.t:).,ni.(-.~,,"-"-,b;,,,;.,,,,,i!;,,,,,~i"I,,Hi'1!~~~~'l!i~w-iHt:i!.LliiM.B1Z1i11:iIl~,[!!I1"""'.""""""">~~W'~lILi'itIi!i!i{]fi' lTI - ~'i' () \,\:' I'u' 'J \1.11'1. J~,l~~,:~,Jm,~!J~" _.,.",~ 11 ""'""_,0,,," ~~ _;,,,"":'_~_ "'.,"""," .,. ''?'_'''' """, ~.. ~,._ _ '","" ,,""'^ __ .~.'- -, <\\"Ii ."\,~-~~\~\'t\,'\ " r, -:-,0. ""\ .~- " , , \\\ :-j \: '. ~ \ . , ~- ",- -- :W.~ WRIT OF EXECUTION and/or ATTACHMENT COMMONWEALTH OF PENNSYLVANIA) COUNTY OF CUMBERLAND) NO 01-6843 Civil CIVIL ACTION - LAW TO THE SHERIFF OF CUMBERLAND COUNTY: To satisfy the debt, interest and costs due ASSOCIATES CONSUMER DISCOUNT COMPANY, Plaintiff (s) From OLEN JUMPER AlKl A OLEN E. JUMPER, 230 WEST DAUPHIN STREET, ENOLA, P A 17025 (I) You are directed to levy upon the property of the defendant (s)and to seil SEE LEGAL DESCRIPTION. (2) Yon 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 gatnishee(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 bimlher that he/she has been added as a garnishee and is enjoined as above stated. Amount Due $53,068.16 L.L. $.50 Interest FROM 4/2/02 TO 9/4/02 (PER DIEM - $8.72) $1,351.60 AND COSTS Atty's Comm % Due Prothy $1.00 Atty Paid $114.75 Other Costs Plaintiff Paid Date: APRIL 4, 2002 CURTIS R. LONG Prothonotary, Civil Division "-By: Ao~ ~ P 7?;/?/J/Y-S;'Dp<t- REQUESTING PARTY: Name FRANK FEDERMAN, ESQIDRE 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 10 No. 12248 TRUECOPV FROM RECORD III Tli8timony wherMf, Iliflra lmfu set my hand ",(I tile of SIlld Coo i lit Cart/sill. Pa. n . yo of . ;:~?~0'~~~_ ~<_ _ _,It,~. "'?~ ~. ~I~" . l' - 1 " . .' <~ >,C "T~' ~ ",,'''''''' 'I: '!-~';,i!miiiJi~Hi,;,~~l%j~j);!t<lj:fiJiw.M'if!',lYi&>mi,Mk#4:r,~i*",4" ._:.,;:,s,,(.:" "t:' ", Q~~'.\:: r:}j\'-' " ,,~~ '~ ,;,-f'" '-''''''ic::~'''b'>:F,-J-~~i-l''!.iJ~!NJi1i~~IiIi~~_~~,f:_M_U--i''~'''-'"~-'",,; - """,,- 'lW~-.,-- m- \~I).\~t c,'.' ".\," ..(' , ., ,i'\ J ,-" '. I'. ',) 'J\.\ ,-',' \: i~._: ' ; \' ~J~,~),;~~lj~~"",_""I t Jft,,<,-,-__S',,.,,..,,-,.f;o,,, ."1," __ -- 1'7_.;,'. '_'5"" .">< 'c.._., , v.",_.... ,"'_.~, __.~,,''''_.., ,___ '__~ . ,"- -- ,"~ . -~-~ ~ ~. -- " .~ ~"",... -~.,~ '];:....- o. _ .- WRIT OF EXECUTION andlor ATTACHMENT COMMONWEALTH OF PENNSYLVANIA) COUNTY OF CUMBERLAND) NO 01-6843 Civil CIVIL ACTION - LAW TO THE SHERIFF OF CUMBERLAND COUNTY: To satisfy the debt, interest and costs due ASSOCIATES CONSUMER DISCOUNT COMPANY, Plaintiff (s) From OLEN JUMPER A/KIA OLEN E. JUMPER, 230 WEST DAUPHIN STREET, ENOLA, PA 17025 (1) 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 gatnishee( s) that: ( a) an attachment has been issued; (b) the garnishee( s) is enj oined from paying any debt to or for the account of the defendant (s) and from delivering any property of the defendant (s) or otherwise disposing thereof; (3) Ifproperty of the defendant(s) not levied upon an subjectto attachment is found in the possession of anyone other than a named garnishee, you are directed to notify himlher that helshe has been added as a garnishee and is enjoined as above stated. Amount Due $53,068.16 L.L. $.50 Interest FROM 4/2/02 TO 9/4/02 (pER DIEM - $8.72) $1,351.60 AND COSTS Atty's Connn % Due Prothy $1.00 Atty Paid $114.75 Plaintiff Paid Date: APRIL 4, 2002 Other Costs CURTIS R. LONG Prothonotary, Civil Division <;.Jly: L2ChJ 9 7?zC/?/VJt~IJ~ REQUESTING PARTY: Name FRANK FEOERMAN, ESQmRE 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 TRUE COPY FROM RECORD III TtstImooy wlwra.'JY, I nf:8 lllitO set my hand llOO ' ! t\; '..i!. ,Garlisl8. Pa. day (l c.:t!'iQf;k,{;MI'!0'iWJ'~~~ IT _ . __ < J ~,n_ -~ ~"~-::I- - -"'1~' , .~ '" -~" , _ o_~~_" "-~ - .._-,~ c,"~~#il.ib'&i::t;mfiuli&'f"t~'i!I'*-"~,*i!W"W"_'~"';"'JJ-j;_"., 1',1:': - ()~~\. < ;~,\:", \;.f~, "k<f~'''_''o'_;k,j~'_ ,,:' \-- ,j ',~-, \:. "~,,-,,; '-!;''''fi''~F:~'-o~":~j'H11l\!m,mji-ll~lilIM'~~~~i.ll'~I:lf;:~_. .,\~~ <,.\\'C.1'<,\ "~'. d\>" \ 't\ \ \'\ ., J , ,. ~ - - \ Jk,!,.J!~,C~l!\.!.l!fJ1R.!/)k_"~J\'IL,~"",,,.,. ~'. . ".N ''''''_.'.. _,_ N .. .. '. '" _.1" I1lJr~-- _'-'""'""';-~~'-'-l ~ "'-~ "(, :~~'" "'\:_'",~~~"'~" " WRIT OF EXECUTION and/or ATTACHMENT COMMONWEALTH OF PENNSYLVANIA) COUNTY OF CUMBERLAND) NO 01-6843 Civil CIVIL ACTION - LAW TO THE SHERIFF OF CUMBERLAND COUNTY: To satisfy the debt, interest and costs due ASSOCIATES CONSUMER DISCOUNT COMPANY, Plaintiff (s) From OLEN JUMPER AIKIA OLEN E. JUMPER, 230 WEST DAUPHIN STREET, ENOLA, PA 17025 (1 ) You are directed to levy upon the property of the defendant (s land to sell SEE LEGAL DESCRIPTION. (2) Yon 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 ofthe 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 bimlher that he/she has been added as a garnishee and is enjoined as above stated. Amount Due $53,068.16 L.L. $.50 Interest FROM 4/2/02 TO 9/4/02 (PER DIEM - $8.72) $1,351.60 AND COSTS Atty's Comm % Due Prothy $1.00 Atty Paid $114.75 Other Costs Plaintiff Paid Date: APRIL 4, 2002 CURTIS R. LONG Prothonotary, Civil Division '-J:ly: 4~ ,P 7f/?/?fi(.~~ REQUESTING PARTY: Name FRANK FEDERMAN, ESQIDRE Address: ONE PENN CENTER AT SUBURBAN STATION 1617 JOHN F. KENNEDY BOULEVARD, SIDTE 1400 PHILADELPHIA, PA 19103-1814 Attorney for: PLAINTIFF Telephone: 215-563-7000 Supreme Court ill No. 12248 TRUE COPY FROM RECORD III T&9tlmon, WMf60f, ! hereullto set my hand ..~"d tM ... of Sl!id 1::0011 <It Carlisli. Pa. day a - +'. r~1 -r; )1_-7, "' " c_. _~ ~ -,- ,~- ~ .' ~-~ "~,~,,~ ....r, l:t",~Wi~~t~i!R"lir,i""";.,~"k"ii!l~"g'l~tr,~,,j~.1ii!<..~k/'_"f,\fli.<"<~-""'/_-_,_,I"">,,,,,,,,",',i.,,,)'<,,tJ.,;;'1fi;-~:I';;_"""'-~,1,~,'''''-i\B!\i;',"ill'",,"f.mQllii_~~i!],i1':ii~~~~til' -;,,-, '~"'''ii'~ -~:' "b'd' - ".;,,~ nrf;~: .....("1'. h~~ ~) ~; \"- ;-." '.' ';H(JJ'1"Jy{j"4L,"",L__~,~~"~"="~.\"':e:r^"""",~,,,,, ~---; .,e' ", ",. ~o~,_,_" ,_c ,_, '~,,, \f-"R.\.t'f L ( .~ ': ;~l~.l'(' ", :) ". v... ',i1'" . ,~"",.^, ~~i ,,---~, --'"~,-. -~~ , '"'",--.0' ';f'\W:#:~l" FEDE~ANandPHELAN,LLP By: FRANK FEDE~AN Identification No. 12248 ONE PENN CENTER AT SUBURBAN STATION 1617 JOHN F. KENNEDY BLVD., SUITE 1400 PIDLADELPIllA, PA 19103-1814 (215) 563-7000 ATTORNEY FOR PLAINTIFF ASSOCIATES CONSUMER DISCOUNT COMPANY CUMBERLAND COUNTY COURT OF COMMON PLEAS Plaintiff, v. CIVIL DIVISION OLEN JUMPER A/KJA OLEN E. JUMPER NO. 01-6843 CIVIL Defendant(s). CERTIFICATION FRANK FEDERMAN, ESQUIRE, hereby verifies that he is attorney for the Plaintiff in the above-captioned matter, and that the premises are not subject to the provisions of Act 91 because it is: o an FHA mortgage () non-owner occupied () vacant (X) Act 91 procedures have been fulfilled This certification is made subject to the penalties of 18 Pa, CoSo Section 4904 relating to unsworn falsification to authorities. 'r~QJJ\^f\.O\JV'-. RANK F ERMAN, ESQUIRE Attorney for Plaintiff " <,. .,.,.,. <I" ~ - , ~ " ,~= ASSOCIATES CONSUMER DISCOUNT COMPANY CUMBERLAND COUNTY Plaintiff, COURT OF COMMON PLEAS v. CIVIL DIVISION OLEN JUMPER AlKJA OLEN E. JUMPER NO. 01-6843 CIVIL Defendant(s). : SHE AFFIDAVIT PURSUANT TO RULE 3129 coR' F F' S (Affidavit No.1) p Y ASSOCIATES CONSUMER DISCOUNT COMPANY, 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 ,230 WEST DAUPHIN STREET, ENOLA, PA 17025. 1. Name and address ofOwner(s) or reputed Owner(s): Name Last Known Address (if address cannot be reasonably ascertained, please indicate) OLEN JUMPER AlK/A OLEN E. JUMPER 230 WEST DAUPHIN STREET ENOLA, PA 17025 2. Name and address of Defendant(s) in the judgment: Same as above 3. Name and last known address of every judgment creditor whose judgment is a record lien on the real property to be sold: Name Last Known Address (if address cannot be reasonably ascertained, please indicate) None 4. Name and address of last recorded holder of every mortgage of record: Name Last Known Address (if address cannot be reasonably ascertained, please indicate) None ";~~I~~ffiiN, _~_"_; _ C":-'_ ~. ,', ~-.,-. 'r ,-~. ), .-" ~,~ ~ ~ I' ,~~iI4I'l; 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) EAST PENNSBORO TOWNSHIP 98 S. ENOLA DRIVE ENOLA, PA 17025 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) COMMONWEALTH OF PA BUREAU OF INDIVIDUAL TAX INHERITANCE TAX DIVISION ATfN: JOHN MURPHY 6TH FLOOR, STRAWBERRY SQUARE DEPT. 280601 HARRISBURG, P A 17128 DEPARTMENT OF PUBLIC WELFARE TPL CASUALTY UNIT ESTATE RECOVERY PROGRAM P.O. BOX 8486 WILLOW OAK BUILDING HARRISBURG,PA 17105-8486 INTERNAL REVENUE SERVICE FEDERATED INVESTORS TOWER TillRTEENTH FLOOR, SUITE 1300 1001 LffiERTY AVENUE PITTSBURGH, PA 15222 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 230 WEST DAUPHIN STREET . ENOLA, PA 17025 Domestic Relations of Cumberland County 13 Nortb Hanover Street Carlisle, PA 17013 Commonwealtb 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 of18 Pa, C,S. Sec, 4904 relating to unsworn falsification to authorities. March 27. 2002 DATE l;v"'-~~CkJ\!'\. RANK FE ERMAN, ESQUIRE Attorney for Plaintiff '-.,-j;t.",W!U\I'''l'~.l:~" ~. - - eO" ...,"'","""'" ~~-'~I- , ," - ~" ~ ........ "-'Tn ASSOCIATES CONSUMER DISCOUNT COMPANY CUMBERLAND COUNTY Plaintiff, COURT OF COMMON PLEAS v. CIVIL DIVISION OLEN JUMPER AlKlA OLEN E. JUMPER NO. 01-6843 CIVIL Defendant(s). AFFIDAVIT PURSUANT TO RULE 3129 (Affidavit No. I) ASSOCIATES CONSUMER DISCOUNT COMPANY, Plaintiff in the above action, by its attorney, FRANK FEDERMAN, ESQUIRE, sets forth as ofthe date the Praecipe for the Writ of Execution was filed the following information concerning the real property located at ,230 WEST DAUPHIN STREET, ENOLA, PA 17025. L Name and address ofOwner(s) or reputed Owner(s): Name Last Known Address (if address cannot be reasonably ascertained, please indicate) OLEN JUMPER A/KJA OLEN E. JUMPER 230 WEST DAUPHIN STREET ENOLA, PA 17025 2. Name and address ofDefendant(s) in the judgment: Same as above 3. Name and last known address of every judgment creditor whose judgment is a record lien on the real property to be sold: Name Last Known Address (if address cannot be reasonably ascertained, please indicate) None 4. Name and address oflast recorded holder of every mortgage ofrecord: Name Last Known Address (if address cannot be reasonably ascertained, please indicate) None J}~1'17 ~ .--, " " ~'I -.. '-, "' -~ " c_o_, ~ "~.- ~~-,.,..~...-.. f~ 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) EAST PENNSBORO TOWNSHIP 98 S. ENOLA DRIVE ENOLA, PA 17025 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) COMMONWEALm OF PA BUREAU OF INDIVIDUAL TAX INHERITANCE TAX DIVISION ATTN:JOHNMURPHY ~HFLOO~STRAWEERRYSQUARE DEPT. 280601 HARRISBURG, PA 17128 DEPARTMENT OF PUBLIC WELFARE TPL CASUALTY UNIT ESTATE RECOVERY PROGRAM P.O. BOX 8486 WILLOW OAK BUlLDlNG HARRISBURG, PA 17105-8486 lNTERNAL REVENUE SERVICE FEDERATED INVESTORS TOWER TIDRTEENTH FLOO~ SUITE 1300 1001 LIBERTY AVENUE PITTSBURGH, P A 15222 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 230 WEST DAUPHIN STREET ENOLA, PA 17025 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 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. March 27. 2002 DATE ~~ Ail'"^- kJ. CA;-J'\.. RANK FE ERMAN, ESQUIRE Attorney for Plaintiff ;:j~l;,.* 'q "-r' "p. "' ~ . e"-'"lUT ASSOCIATES CONSUMER DISCOUNT COMPANY CUMBERLAND COUNTY Plaintiff, : COURT OF COMMON PLEAS v. CIVIL DIVISION OLEN JUMPER AlKlA OLEN E. JUMPER NO. 01-6843 CIVIL Defendant(s). AFFIDAVIT PURSUANT TO RULE 3129 (Affidavit No, 1) ASSOCIATES CONSUMER DISCOUNT COMPANY, 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 ,230 WEST DAUPHIN STREET, ENOLA, PA 17025. 1. Name and address ofOwner(s) orreputed Owner(s): Name Last Known Address (if address cannot be reasonably ascertained, please indicate) OLEN JUMPER A/KJ A OLEN E. JUMPER 230 WEST DAUPHIN STREET ENOLA, PA 17025 2, Name and address ofDefendant(s) in the judgment: Same as above 3, Name and last known address of every judgment creditor whose judgment is a record lien on the real property to be sold: Name Last Known Address (if address cannot be reasonably ascertained, please indicate) None 4. Name and address of last recorded holder of every mortgage of record: Name Last Known Address (if address cannot be reasonably ascertained, please indicate) None ?j*,~~",-",~","~-," ,..- ., F -It ., - , ,~"--"~~~ .~ -~-"1 ".~,~ '~'I 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) EAST PENNSBORO TOWNSHIP 98 S. ENOLA DRIVE ENOLA, PA 17025 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) COMMONWEALTH OF PA BUREAU OF INDIVIDUAL TAX INHERITANCE TAX DIVISION A'ITN: JOHN MURPHY 6TH FLOOR, STRAWBERRY SQUARE DEPT. 280601 HARRISBURG, P A 17128 INTERNAL REVENUE SERVICE FEDERATED INVESTORS TOWER P.O. BOX 8486 WILLOW OAK BUILDING HARRISBURG, PA 17105-8486 THIRTEENTH FLOOR, SUITE 1300 1001 LffiERTY AVENUE PITTSBURGH, P A 15222 DEPARTMENT OF PUBLIC WELFARE TPL CASUALTY UNIT ESTATE RECOVERY PROGRAM 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 230 WEST DAUPHIN STREET ENOLA, PA 17025 Domestic Relations of Cumberland County 13 North Hanover Street Carlisle, PA 17013 Commonwealth of Pennsylvania Department of Welfare PO Box 2675 Harrisburg, P A 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, March 27. 2002 DATE fP~~O-~ RANK FE ERMAN, ESQUIRE Attorney for Plaintiff 0i~,~-,~~ _ _ _~" ,,~ 0_ -"'. -~ 1- J._,. . , . "~ ~ ,-."__~,,,,4_ "0 L ~ lffT ASSOCIATES CONSUMER DISCOUNT COMPANY CUMBERLAND COUNTY Plaintiff, No. 01-6843 CIVIL v. OLEN JUMPER AIKIA OLEN E. JUMPER Defendant(s). March 27, 2002 TO: OLEN JUMPER AlK/A OLEN E. JUMPER 230 WEST DAUPHIN STREET ENOLA, PA 17025 "THIS FIRM IS A DEBT COLLECTOR A1TEMPTING TO COLLECT A DEBT AND ANY INFORMATION OBTAINED WILL BE USED FOR THAT PURPOSE. IF YOU HA VE PREVIOUSLY RECEIVED A DISCHARGE IN BANKRUPTCY AND THIS DEBT WAS NOT REAFFIRMED, THIS IS NOT AND SHOULD NOT BE CONSTRUED TO BE AN A1TEMPT TO COLLECT A DEBT, BUT ONLY ENFORCEMENT OF A LIEN AGAINST PROPERTY." Your house (real estate) at. 230 WEST DAUPHIN STREET. ENOLA. PA 17025. is scheduled to be sold at the Sheriffs Sale on 9/4/02 at 10:00 a,m. in the Cumberland County Courthouse, South Hanover Street, Carlisle, PA 17013, to enforce the court judgment of $53.068.16 obtained by ASSOCIATES CONSUMER DISCOUNT COMPANY (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: 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.) ~~; ~^' , '[ I~;" ^. "- ~~ IJI!I ",~~ ~ -,l;,~'1:'rnl!\'lt!!W~!~~.__ YOU MAY STILL BE ABLE TO SAVE YOUR PROPERTY AND YOU HAVE OTHER RIGHTS EVEN IFTDE SHERIFF'S SALE DOES TAKE PLACE. 1. If the Sheriffs Sale is not stopped, your property will be sold to the highest bidder. You may find out the price bid by calling (215) 563-7000. 2. You may be able to petition the Court to set aside the sale ifthe 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 ofthe 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 ofthe money which was paid for your house. A schedule of distribution ofthe money bid for your house will be filed by the Sheriff within 30 days of the sale, This schedule will state who will be receiving that money, The money will be paid out in accordance with this schedule unless exceptions (reasons why the proposed distribution is wrong) are filed with the Sheriff within ten (10) days after the distribution is filed. 7. You may also have other rights and defenses, or ways of getting your home back, if you act immediately after the sale. YOU SHOULD TAKE THIS PAPER TO YOUR LAWYER AT ONCE. IF YOU DO NOT HAVE A LAWYER OR CANNOT AFFORD ONE, GO TO OR TELEPHONE THE OFFICE LISTED BELOW TO FIND OUT WHERE YOU CAN GET LEGAL HELP. CUMBERLAND COUNTY ATTORNEY REFERRAL CUMBERLAND COUNTY BAR ASSOCIATION 2 LIBERTY AVENUE CUMBERLAND COUNTY COURTHOUSE CARLISLE, PA 17013 (717) 249-3166 (800) 990-9108 . r ~ ._T"" I-~'~" n ~~._- ~ "- --~~""~=I~ ~ '~'''''''''"~ ill''-'n''''o'~ ,_."" ,~- W' ,. ! , ALL THAT CERTAIN lot or piece of land with buildings and improvements thereon erected situate in East Pennsboro Township, Cumberland County, Pennsylvania, bounded and described as follows, to wit: ' BEGINNING at a point in the Southern line of Dauphin Street at or opposite the center of the partition wall dividing properties known as No. 230 and 232 Dauphin Street, said point being Two Hundred Twenty-Nine and Three Hundred Eighty-Nine One-Thousands (229.389) feet East of the Southeast corner of Bri 'Church Road and Dauphin Street; thence along the Southern line of Dauphin Street, North 79 grees 40 minutes East, Forty-Six (46) feet to a point; thence South 10 degrees 20 minutes East,O Hundred Seventeen and Five Hundred Five One-Thousandths (117.505) feet to a point; thence Sou 79 degrees 40 minutes West, Forty-Six (46) feet to a point at or opposite the center of the partition wall dividing properties known as No. 230 and 232 Dauphin Street; thence North 10 degrees 20 minutes West through the center of the partition wall dividing properties known as No. 230 and No. 232 Dauphin Street and beyond One Hundred Seventeen and Five Hundred Five One-Thousandths (117.5005) feet to a point, at the place of beginning. HAVING thereon erected the Eastern One-half of a two story dwelling known as No. 230 Dauphin Street, Enola, Pennsylvania. TAX PARCEL # 09-14~0832-201 Premises: /230 DAUPHIN STREET, TOWNSHIP OF EAST PENNSBORO I CUMBERLAND COUNTY PFNNSYL VANIA . TITLE TO SAID PREMISES IS VESTED IN Olen E. Jumper, widower by reason of the following BEING THE SAME premises which Theodore E. Sgrignoli and Winifred E. Sgrignoli, his wife by Deed dated 8/29/63 and recorded 8/29/63 in the County of Cumberland in Deed Book Y, Volume 20, Page 737 conveyed unto Olen E. Jumper and Romaine M. Jumper, his wife. . . AND THE SAID Romame M. Jumper died on 7/20/99 whereby title to said premises became vested in Olen E. Jumper by right of survivorship. :!'M:i~~~['~._ .., " - '.' .~ .~~- ~,...". ., """~ _I ~l;~~_, fcll1iJ ASSOCIATES CONSUMER DISCOUNT COMPANY CUMBERLAND COUNTY Plaintiff, No. 01-6843 CIVIL v. OLEN JUMPER AlKlA OLEN E. JUMPER Defendant(s). March 27, 2002 TO: OLEN JUMPER AlKJA OLEN E. JUMPER 230 WEST DAUPHIN STREET ENOLA, PA 17025 "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. 230 WEST DAUPHIN STREET. ENOLA. PA 17025. is scheduled to be sold at the SherifPs Sale on 9/4/02 at 10:00 a.m. in the Cumberland County Courthouse, South Hanover Street, Carlisle, P A 17013, to enforce the court judgment of $53.068.16 obtained by ASSOCIATES CONSUMER DISCOUNT COMPANY (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 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.) ";'I~~_';!r'=--_'w>-~ ~ l.-..,W --. I"" .~ . ~ ~ r~ " ~_L YOU MAY STILL BE ABLE TO SAVE YOUR PROPERTY AND YOU HAVE OTHER RIGHTS EVEN IF THE SHERIFF'S SALE DOES TAKE PLACE. I, If the Sheriffs Sale is not stopped, your property will be sold to the highest bidder. You may find out the price bid by calling (215) 563-7000. 2. You may be able to petition the Court to set aside the sale if the bid price was grossly inadequate compared to the value of your property. 3. The sale will go through only if the buyer pays the Sheriffthe 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 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 ^'ii'l"'~,1~. - - 'Ih-~ _ ":" ~ "I .* ".~_<l>.~~".-- 4"1"1"((1'" " . ALL THAT CERTAIN lot or piece of land with buildings and improvements thereon erected situate in East pennsboro Township, Cumberland C~unty, Pennsylvania, bounded and described as follows, to wit: BEGINNING at a point in the Southern line of Dauphin Street at or opposite the center of the partition wall dividing properties known as No, 230 and 232 Dauphin Street, said point being Two Hundred Twenty-Nine an,d Three Hundred Eighty-Nine One-Thousands (229.389) feet East of the Southeast comer of Bri Church Road and Dauphin Street; thence along the Southern line of Dauphin Street, North 79 grees 40 minutes East, Forty-Six (46) feet to a point; thence South 10 degrees 20 minutes East, 0 Hundred Seventeen and Five Hundred Five One-Thousandths (117.505) feet to a point; thence Sou 79 degrees 40 minutes West, Forty-Six (46) feet to a point at or opposite the center of the partition wall dividing propefties known as No. 230 and 232 Dauphin Street; thence North 10 degrees 20 minutes West through the center of the partition wall dividing properties known as No. 230 and No. 232 Dauphin Street and beyond One Hundred Seventeen and Five Hundred Five One-Thousandths (117.5005) feet to a point, at the place of beginning. . HAVING thereon erected the Eastern One-half of a two story dwelling known as No. 230 Dauphin Street, Enola, Pennsylvania. TAX PARCEL # 09-14~0832-201 Premises: /230 DAUPHIN STREET, TOWNSHIP OF EAST PENNSBORO / CUMBERLAND COUNTY PRNNSYL VANIA TITLE TO SAID PREMISES IS VESTED IN Olen E. Jumper, widower by reason of the following BEING THE SAME premises which Theodore E. Sgrignoli and Winifred E. Sgrignoli, his wife by Deed dated 8/29/63 and recofded 8/29/63 in the County of Cumberland in Deed Book Y, Volume 20, Page 737 conveyed unto Olen E. Jumper and Romaine M. Jumper, his wife. . AND THE SAID Romaine M. Jumper died on 7/20/99 whereby title to said premises became vested in Olen E. Jumper by right of survivorship. :~!~l!V~_", _~,"!ILJ. _ - 'I ',~, ".,.,. ~ ,~ ~ ~ ~, - ~- , ASSOCIATES CONSUMER DISCOUNT COMPANY CUMBERLAND COUNTY Plaintiff, No. 01-6843 CIVIL v. OLEN JUMPER AIKIA OLEN E. JUMPER Defendant(s). March 27, 2002 TO: OLEN JUMPER AlKJA OLEN E. JUMPER 230 WEST DAUPHIN STREET ENOLA, PA 17025 "THIS FIRM IS A DEBT COLLECTOR A TTEMPTlNG TO COLLECT A DEBT AND ANY INFORMA TlON 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 PROPER IT.' Your house (real estate) at, 230 WEST DAUPHIN STREET, ENOLA, PA 17025. is scheduled to be sold at the Sheriffs Sale on 9/4/02 at 10:00 a.m. in the Cumberland County Courthouse, South Hanover Street, Carlisle, P A 17013, to enforce the court judgment of $53.068.16 obtained by ASSOCIATES CONSUMER DISCOUNT COMPANY (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: 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,) ,,--~"''''~-'''I"'''''J!.'lW~l?<l_~__ .,,, .,..,.. r' I" ",,, ""'- ~ ,~,.- <,'-.' -'I]""_4;-.~ ( YOU MAY STILL BE ABLE TO SAVE YOUR PROPERTY AND YOU HAVE OTHER RIGHTS EVEN IF THE SHEluFF'SSALE DOES TAKE PLACE. 1. If the Sheriffs Sale is not stopped, your property will be sold to the highest bidder. You may find out the price bid by calling (215) 563-7000. 2. You may be able to petition the Court to set aside the sale ifthe bid price was grossly inadequate compared to the value of your property, 3. The sale will go through only if the buyer pays the Sheriffthe full amount due in the sale. To find out if this has happened, you may call (717) 240-6390, 4, lfthe amount due from the Buyer is not paid to the Sheriff, you will remain the owner of the property as ifthe sale never happened, 5. You have the right to remain in the property until the full amount due is paid to the Sheriff and the Sheriff gives a deed to the buyer. At that time, the buyer may bring legal proceedings to evict you, 6, You may be entitled to a share of the money which was paid for your house. A schedule of distribution of the money bid for your house will be filed by the Sheriff within 30 days of the sale. This schedule will state who will be receiving that money. The money will be paid out in accordance with this schedule unless exceptions (reasons why the proposed distribution is wrong) are filed with the Sheriff within ten (10) days after the distribution is filed, 7. You may also have other rights and defenses, or ways of getting your home back, if you act immediately after the sale. YOU SHOULD TAKE THIS PAPER TO YOUR LAWYER AT ONCE. IF YOU DO NOT HAVE A LAWYER OR CANNOT AFFORD ONE, GO TO OR TELEPHONE THE OFFICE LISTED BELOW TO FIND OUT WHERE YOU CAN GET LEGAL HELP. CUMBERLAND COUNTY ATTORNEY REFERRAL CUMBERLAND COUNTY BAR ASSOCIATION 2 LIBERTY AVENUE CUMBERLAND COUNTY COURTHOUSE CARLISLE, PA 17013 (717) 249-3166 (800) 990-9108 -"i';h~:OO!i<~ .~._. _ ~ ~""'" '-1' . - ~".l, > _r~ ~" , ~"""1~"'~,_",.m:,j r""'''-"'-='''"'~'' "'...-- - ~ -- . ALL THAT CERTAIN lot or piece of land with buildings and improvements thereon erected situate in East Pennsboro Township, Cumberland C~unty, Pennsylvania, bounded and described as follows, to wit: BEGINNING at a point in the Southern line of Dauphin Street at or opposite the center of the partition wall dividing properties known as No. 230 and 232 Dauphin Street, said point being Two Hundred Twenty-Nine and Three Hundred Eighty-Nine One-Thousands (229.389) feet East of the Southeast comer of Bri "Church Road and Dauphin Street; thence along the Southern line of Dauphin Street, North 79 grees 40 minutes East, Forty-Six (46) feet to a point; thence South 10 degrees 20 minutes East, 0 Hundred Seventeen and Five Hundred Five One-Thousandths (117.505) feet to a point; thence Sou 79 degrees 40 minutes West, Forty-Six (46) feet to a point at or opposite the center of the partition wall dividing properties known as No. 230 and 232 Dauphin Street; thence North lOdegrees 20 minutes West through the center of the partition wall dividing properties known as No. 230 and No. 232 Dauphin Street and beyond One Hundred Seventeen and Five Hundred Five One-Thousandths (117.5005) feet to a point, at the place of beginning. HAVING thereon erected the Eastern One-half of a two story dwelling known as No. 230 Dauphin Street, Enola, Pennsylvania. TAX PARCEL # 09-14-0832-201 Premises: /230 DAUPHIN STREET, TOWNSHIP OF EAST PENNSBORO I CUMBERLAND COUNTY PENNSYLVANIA TITLE TO SAID PREMISES IS VESTED IN Olen E. Jumper, widower by reason of the following BEING THE SAME premises which Theodore E. Sgrignoli and Winifred E. Sgrignoli, his wife by Deed dated 8/29/63 and recofded 8/29/63 in the County of Cumberland in Deed Book Y, Volume 20, Page 737 conveyed unto Olen E. Jumper and Romaine M. Jumper, his wife. . AND THE SAID Romaine M. Jumper died on 7/20/99 whereby title to said premises became vested in Olen E. Jumper by right of survivorship. ,,";W(i\'i''''''''''''~''''' ~~ ,11 , .'--"1 , - ~- ~ " 'y .IY -. 'i"1iCC"fV'" ....,...,'..".... . ALL THAT CERTAIN lot or piece of land with buildings and improvements thereon erected situate in East PelU1Sboro Township, Cumberland County, PelU1Sylvania, bounded and described as follows, to wit: BEGINNING at a point in the Southern line of Dauphin Street at or opposite the center of the partition wall dividing properties known as No. 230 and 232 Dauphin Street, said point being Two Hundred Twenty-Nine and Three Hundred Eighty-Nine One-Thousands (229.389) feet East of the Southeast comer of Bri "'Church Road and Dauphin Street; thence along the Southern line of Dauphin Street, North 79 grees 40 minutes East, Forty-Six (46) feet to a point;. thence South 10 degrees 20 minutes East, 0 Hundred Seventeen and Five Hundred Five One-Thousandths (117..505) feet to a point; thence Sou 79 degrees 40 minutes West, Forty-Six (46) feet to a point at or opposite the center of the partition wall dividing propeities known as No.. 230 and 232 Dauphin Street; thence North 10 degrees 20 minutes West through the center of the partition wall dividing properties known as No.. 230 and No. 232 Dauphin Street and beyond One Hundred Seventeen and Five Hundred Five One-Thousandths (117.5005) feet to a point, at the place of beginning. . HAVING thereon erected the Eastern One-half of a two story dwelling known as No. 230 Dauphin Street, Enola, Pennsylvania. TAX PARCEL # 09-14-0832-201 Premises: /230 DAUPHIN STREET, TOWNSHIP OF EAST PENNSBORO I CUMBERLAND COUNTY PFNNSYL VANIA TITLE TO SAID PREMISES IS VESTED IN OIen E. Jumper, widower by reason of the following BEING THE SAME premises which Theodore E.. Sgrignoli and Winifred E. Sgrignoli, his wife by Deed dated 8/29/63 and recorded 8/29/63 in the County of Cumberland in Deed Book Y, Volume 20, Page 737 conveyed unto Olen E. Jumper and Romaine M. Jumper, his wife. . AND THE SAID Romaine M. Jumper died on 7/20/99 whereby title to said premises became vested in Olen E. Jumper by right of survivorship. :;,,~l"i~ ~. ~ ^ '~^ '"n_ ,_ ',n .~ " '.' ," " ~~ - 1'~ ..,..-,-",,' '1'1" ",_.' ' .- , ALL THAT CERTAIN lot or piece of land with buildings and improvements thereon erected situate in East Pennsboro Towrnhip, Cumberland County, Pennsylvania, bounded and described as follows, to wit: . BEGINNING at a point in the Southern line of Dauphin Street at or opposite the center of the partition wall dividing properties known as No. 230 and 232 Dauphin Street, said point being Two Hundred Twenty-Nine an.<i Three Hundred Eighty-Nine One-Thousands (229.389) feet East of the Southeast, comer of Bri Church Road and Dauphin Street; thence along the Southern line of Dauphin Street, North 79 grees 40 minutes East, Forty-Six (46) feet to a point;.thence South 10 degrees 20 minutes East,O Hundred Seventeen and Five Hundred Five One-Thousandths (117.505) feet to a point; thence Sou 79 degrees 40 minutes West, Forty-Six (46) feet to a point at or opposite the center of the partition wall dividing properties known as No. 230 and 232 Dau~hin Street; thence North 10 degrees 20 minutes West through the center of the partition wall dividing properties known as No. 230 and No. 232 Dauphin Street and beyond One Hundred Seventeen and Five Hundred Five One-Thousandths (117.5005) feet to a point, at the place of beginning. , HAVING thereon erected the Eastern One-half of a two story dwelling known as No. 230 Dauphin Street, Enola, Pennsylvania. TAX PARCEL # 09-14-0832-201 Premises: /230 DAUPHIN STREET, TOWNSHIP OF EAST PENNSBORO I CUMBERLAND COUNTY PENNSYLVANIA TITLE TO SAID PREMISES IS VESTED IN Olen E. Jumper, widower by reason of the following BEING THE SAME premises which Theodore E. Sgrignoli and Winifred E. Sgrignoli, his wife by Deed dated 8/29/63 and recorded 8/29/63 in the County of Cumberland in Deed Book Y, Volume 20, Page 737 conveyed unto Olen E. Jumper and Romaine M. Jumper, his wife. . AND THE SAID Romaine M. Jumper died on 7/20/99 whereby title to said premises became vested in OIen E. Jumper by right of survivorship. ';"?Il!'~,~~_tlI:llli~, -1' , " 1- ~~ " "~C ", --, - -~ .".,~~ 'r""~"':-~"'~ ,.. , ALL THAT CERTAIN lot or piece of land with buildings and improvements thereon erected situate in East PelUlSboro Township, Cumberland County, PelUlSylvania, bounded and described as follows, to wit: . BEGINNING at a point in the Southern line of Dauphin Street at or opposite the center of the partition wall dividing properties known as No. 230 and 232 Dauphin Street, said point being Two Hundred Twenty-Nine an,d Three Hundred Eighty-Nine One-Thousands (229.389) feet East of the Southeast comer of Bri "Church Road and Dauphin Street; thence along the Southern line of Dauphin Street, North 79 grees 40 minutes East, Forty-Six (46) feet to a point;. thence South IO degrees 20 minutes East, 0 Hundred Seventeen and Five Hnndred Five One-Thousandths (117.505) feet to a point; thence Sou 79 degrees 40 minutes West, Forty-Six (46) feet to a point at or opposite the center of the pafiition wall dividing properties known as No. 230 and 232 Dauphin Street; thence North IO degrees 20 minutes West through the center of the partition wall dividing properties known as No. 230 and No. 232 Dauphin Street and beyond One Hundred Seventeen and Five Hundred Five One-Thousandths (117.5005) feet to a point, at the pla(;e of beginning. . HAVING thereon erected the Eastern One-half of a two story dwelling known as No. 230 Dauphin Street, Enola, PelUlSylvania. TAX PARCEL # 09-14-0832-201 Preinises: /230 DAUPHIN STREET, TOWNSHIP OF EAST PENNSBORO I CUMBERLAND COUNTY PFNNSYL VANIA TITLE TO SAID PREMISES IS VESTED IN Olen E. Jiimper, widower by reason of the following BEING THE SAME premises which Theodore E. Sgrignoli and Winifred E. Sgrignoli, his wife by Deed dated 8/29/63 and fecorded 8/29/63 in the County of Cumberland in Deed Book Y, Volume 20, Page 737 conveyed unto Olen E. Jumper and Romaine M. Jumper, his wife. . AND THE SAID Romaine M. Jumper died on 7/20/99 whereby title to said premises became vested in Olen E. Jumper by right of survivorship. :~.I'l'-~~." 10" ,"".'~~_, _"_'_ . ~ , ~ .~,n""_."'__ ~~~ em I ,. .< _",,"-,1 ., ~.,- .-,..-"' - ., ; ALL THAT CERTAIN lot or piece of land with buildings and improvements thereon erected situate in East Pennsboro Township, Cumberland County, Pennsylvania, bounded and described as follows, to wit: . BEGINNING at a point in the Southern line of Dauphin Street at or opposite the center of the partition wall dividing properties known as No. 230 and 232 Dauphin Street, said point being Two Hundred Twenty-Nine an,d Three Hundred Eighty-Nine One-Thousands (229.389) feet East of the Southeast comer of Bri - Church Road and Dauphin Street; thence along the Southern line of Dauphin Street. North 79 grees 40 minutes East, Forty-Six (46) feet to a point;.thence South 10 degrees 20 minutes East, 0 Hundred Seventeen and Five Hundred Five One-Thousandths (117.505) feet to a point; thence Sou 79 degrees 40 minutes West, Forty-Six (46) feet to a point at or opposite the center of the partition wall dividing propeities known as No. 230 and 232 Dauphin Street; thence North 10 degrees 20 minutes West through the center of the partition wall dividing properties known as No. 230 and No. 232 Dauphin Street and beyond One Hundred Seventeen and Five Hundred Five One-Thousandths (117.5005) feet to a point, at the plao;:e of beginning. . HAVING thereon erected the Eastern One-half of a two story dwelling known as No. 230 Dauphin Street, Enola, Pennsylvania. TAX PARCEL # 09-14-0832-201 Premises: /230 DAUPHIN STREET, TOWNSHIP OF EAST PENNSBORO / CUMBERLAND COUNTY PENNSYLVANIA TITLE TO SAID PREMISES IS VESTED IN Olen E. Jiimper, widower by reason of the following BEING THE SAME premises which Theodore E. Sgrignoli and Winifred E. Sgrignoli, his wife by Deed dated 8/29/63 and recorded 8/29/63 in the County of Cumberland in Deed Book Y, Volume 20, Page 737 conveyed unto Olen E. Jumper and Romaine M. Jumper, his wife. . . AND THE SAID Romarne M. Jumper died on 7120/99 whereby title to said premises became vested in Olen E. Jumpef by right of survivorship. -,'T;W~"'?t~~-f"'ilW, _,_~'"'''' ,-,'IT_ ~. -1" ~ 0 ~_, ~,,- ~_.{l'IIl"~,,~ ~,.__~ -=""'" " " -I~"""''''- ~~,-- ,,, ,,"'."'~ .. ALL THAT CERTAIN lot or piece of land with buildings and improvements thereon erected situate in East Pennsboro Township, Cumberland County, Pennsylvania; bounded and described as follows, to wit: . BEGINNING at a point in the Southern line of Dauphin Street at or opposite the center of the partition wall dividing properties known as No. 230 and 232 Dauphin Street, said point being Two Hundred Twenty-Nine and Three Hundred Eighty-Nine One-Thousands (229.389) feet East of the Southeast cornef of Bri 'Church Road and Dauphin Street; thence along the Southern line of Dauphin Street, North 79 grees 40 minutes East, Forty-Six (46) feet to a point;. thence South 10 degrees 20 minutes East, 0 Hundred Seventeen and Five Hundred Five One-Thousandths (117.505) feet to a point; thence Sou 79 degrees 40 minutes West, Forty-Six (46) feet to a point at or opposite the center of the partition wall dividing properties known as No. 230 and 232 Dau~hin Street; thence North 10 degrees 20 minutes West through the center of the partition wall dividing properties known as No. 230 and No. 232 Dauphin Street and beyond One Hundred Seventeen and Five Hundred Five One-Thousandths (117.5005) feet to a point, at the place of beginning. HAVING thereon erected the Eastern One-half of a two story dwelling known as No. 230 Dauphin Street, Enola, Pennsylvania. TAX PARCEL # 09-14~0832-20l Premises: /230 DAUPHIN STREET, TOWNSHIP OF EAST PENNSBORO I CUMBERLAND COUNTY PENNSYLVANIA TITLE TO SAID PREMISES IS VESTED IN Olen E. Jiimper, widower by reason of the following BEING THE SAME premises which Theodore E. Sgrignoli and Winifred E. Sgrignoli, his wife by Deed dated 8/29/63 and recorded 8/29/63 in the County of Cumberland in Deed Book Y, Volume 20, Page 737 conveyed unto Olen E. Jumper and Romaine M. Jumper, his wife. . AND THE SAID Romaine M. Jumper died on 7/20/99 whereby title to said premises became vested in Glen E. Jumper by right of survivorship. '/#"~'i;i"I?,,l'JYJI,~_,.,., "' . _~ . ""'~-'I', - . . ~"=. ~ ~ ~ fi_~TI",W<'-"-"r-. w' -"--",...~.,,,.- - ~ ~ 1-- . ALL THAT CERTAIN lot or piece of land with buildings and improvements thereon erected situate in East Pennsboro Township, Cumberland County, Pennsylvania, bounded and described as follows, to wit: BEGINNING at a point in the Southern line of Dauphin Street at or opposite the center of the partition wall dividing properties known as No. 230 and 232 Dauphin Street, said point being Two Hundred Twenty-Nine an~ Three Hundred Eighty-Nine One-Thousands (229.389) feet East of the Southeast comer of Bri 'Church Road and Dauphin Street; thence along the Southern line of Dauphin Street, North 79 grees 40minutes East, Forty-Six (46) feet to a point;, thence South 10 degrees 20 minutes East, 0 Hundred Seventeen and Five Hundred Five One-Thousandths (117.505) feet to a point; thence Sou 79 degrees 40 minutes West, Forty-Six (46) feet to a point at or opposite the center of the pattitioo. wall dividing properties known as No. 230 and 232 Dauphin Street; thence North 10 degrees 20 minutes West through the center of the partition wall dividing properties known as No. 230 and No. 232 Dauphin Street and beyond One Hundred Seventeen and Five Hundred Five One-Thousandths (117.5005) feet to a point, at the place of beginning. . HAVING thereon erected the Eastern One-half of a two story dwelling known as No. 230 Dauphin Street, Enola, Pennsylvania. TAX PARCEL # 09-14-,0832-201 Prenllses: /230 DAUPHIN STREET, TOWNSHIP OF EAST PENNSBORO I CUMBERLAND COUNTY PRNNSYL VANIA TITLE TO SAID PREMISES IS VESTED IN Olen E. Jumper, widower by reason of the following BEING THE SAME premises which Theodore E. Sgrignoli and Winifred E. Sgrignoli, his wife by Deed dated 8/29/63 and recorded 8/29/63 in the County of Cumberland in Deed Book Y, Volume 20, Page 737 conveyed unto Olen E. Jumper and Romaine M. Jumper, his wife. . , AND THE SAID Romame M. Jumper died on 7120/99 whereby title to said premises became vested in Olen E. Jumper by right of survivorship. --'lV'~'!~I!ltli'l'~ ___ ~, ~,_w~" _. r'. (~-,~ ~', 'i:< ,)~~" - ~, ~-~. , ALL THAT CERTAIN lot or piece of land with buildings and improvements thereon erected situate in East Pennsboro Township, Cumberland County, Pennsylvania, bounded and described as follows, to wit: BEGINNING at a point in the Southern line of Dauphin Street at or opposite the center of the partition wall dividing properties known as No. 230 and 232 Dauphin Street, said point being Two Hundred Twenty-Nine and Three Hundred Eighty-Nine One-Thousands (229.389) feet East of the Southeast cornef of Bri 'ChUfCh Road and Dauphin Street; thence along the Southern line of Dauphin Street, North 79 grees 40 minutes East, Forty-Six (46) feet to a point;, thence South 10 degrees 20 minutes East, 0 Hundred Seventeeil and Five Hundred Five One-Thousandths (I 17.505) feet to a point; thence Sou 79 degrees 40 minutes West, Forty-Six (46) feet to a point at or opposite the center of the partition wall dividing properties known as No. 230 and 232 Dauphin Street; thence North 10 degrees 20 minutes West through the center of the partition wall dividing properties known as No, 230 and No, 232 Dauphin Street and beyond One Hundred Seventeen and Five Hundred Five One-Thousandths (117.5005) feet to a point, at the place of beginning. . HAVING thefeon efected the Eastern One-half of a two story dwelling known as No. 230 Dauphin Street, Enola, Pennsylvania. TAX PARCEL # 09-14-0832-201 Premises: /230 DAUPHIN STREET, TOWNSHIP OF EAST PENNSBORO I CUMBERLAND COUNTY PFNNSYL VANIA TITLE TO SAID PREMISES IS VESTED IN Olen E. Jumper, widower by reason of the following BEING THE.SAME pfemises which Theodore E. Sgrignoli and Winifred E. Sgrignoli, his wife by Deed dated 8/29/63 and recofded 8/29/63 in the County of Cumberland in Deed Book Y, Volume 20, Page 737 conveyed unto Olen E. Jumper and Romaine M. Jumper, his wife. , AND THE SAID Romaine M. Jumper died on 7/20/99 whereby title to said premises became vested in Olen E. Jumper by right of survivorship. ",;>?,~"""!lIlJ_~"",, ~ _ ~ ~~,~ =1 rr ,_ ," "--or r' " . . - f~ ;C:'-,,\']Jh"""-'" -~" -,-- - ~ . ALL THAT CERTAIN lot or piece of land with buildings and irnprovementsthereon erected situate in East Pennsboro Township, Cumberland County, Pennsylvania, bounded and described as follows, to wit: BEGINNING at a point in the Southern line of Dauphin Street at or opposite the center of the partition wall dividing properties known as No. 230 and 232 Dauphin Street, said point being Two Hundred Twenty-Nine and Thfee HundredEighty-Nine One-Thousands (229.389) feet East of the Southeast comer of Bd Church Road and Dauphin Street; thence along the Southern line of Dauphin Street, North 79 grees 40 minutes East, Forty-Six (46) feet to a point;,thence South 10 degrees 20 minutes East, 0 Hundred Seventeen and Five Hundred Five One-Thousandths (117.505) feet to a point; thence Sou 79 degrees 40 minutes_ West, Forty-Six (46) feet to a point at or opposite the center of the partition wall dividing properties known as NO.230 and 232 Dauphin Street; thence North lOdegrees 20 minutes West through the center of the partition wall dividing properties known as No. 230 and No. 232 Dauphin Street and beyond One Hundred Seventeen and Five Hundred Five One-Thousandths (117.5005) feet to a point, at the place of beginning. . HAVING thereon erected the Eastern One-half of a two story dwelling known as No. 230 Dauphin Street, Enola, Pennsylvania. TAX PARCEL # 09-14-0832-201 Premises: /230 DAUPHIN STREET, TOWNSHIP OF EAST PENNSBORO I CUMBERLAND COUNTY PENNSYLVANIA TITLE TO SAID PREMISES IS VESTED IN Olen E. Jiimper, widower by reason of the following BEING THE SAME pfemises which Theodore E. Sgrignoli and Winifred E. Sgrignoli, his wife by Deed dated 8/29/63 and recorded 8/29/63 in the County of Cumberland in Deed Book y, Volume 20, Page 737 conveyed unto Olen E. Jumper and Romaine M. Jumper, his wife. , AND THE SAID Romaine M. Jumper died on 7/20/99 whereby title to said premises became vested in Olen E. Jumper by right of survivorship. ',<'\i;r~jit}1if:"W,.. _~ . , " " .,,~ .u.~ r. ~ "';'-bC"i:./-Y''C. .,~ "._-,~~, ,-."-~- - ~~ , ALL THAT CERTAIN lot or piece of land with buildings and improvements thereon erected situate in East Pennsboro Township, Cumberland C~unty, Pennsylvania, bounded and described as follows, to wit: BEGINNING at a point in the Southern line of Dauphin Street at or opposite the center of the partition wall dividing properties known as No. 230 and 232 Dauphin Street, said point being Two Hundred Twenty-Nine and Three Hundred Eighty-Nine One-Thousands (229.389) feet East of the Southeast corner of Bri . Church Road and Dauphin Street; thence along the Southern line of Dauphin Street, North 79 grees 40 minutes East, Forty-Six (46) feet to a point;, thence South 10 degrees 20 minutes East, 0 Hundred Seventeen and Five Hundred Five One-Thousandths (117.505) feet to a point; thence Sou 79 degrees 40 minutes West, Forty-Six (46) feet to a point at or opposite the center of the pariition wall dividing propeities known as No. 230 and 232 Dauphin Street; thence North 10 degrees 20 minutes West through the center of the partition wall dividing properties known as No. 230 and No. 232 Dauphin Street and beyond One Hundred Seventeen and Five Hundred Five One~ Thousandths (117.5005) feet to a point, at the place of beginning. HAVING thereon erected the Eastern One-half of a two story dwelling known as No. 230 Dauphin Street, Enola, Pennsylvania. TAX PARCEL # 09-14-0832-201 Premises: /230 DAUPHIN STREET, TOWNSHIP OF EAST PENNSBORO I CUMBERLAND COUNTY PENNSYLVANIA . TITLE TO SAID PREMISES IS VESTED IN Olen E. Jiimper, widower by reason of the following BEING THE SAME premises which Theodore E. Sgrignoli and Winifred E. Sgrignoli, his wife by Deed dated 8/29/63 and recorded 8/29/63 in the County of Cumberland in Deed Book Y, Volume 20, Page 737 conveyed unto Olen E. Jumper and Romaine M. Jumper, his wife. , AND THE SAID Romaine M. Jumper died on 7/20/99 whereby title to said premises became vested in OIen E. Jumper by right of survivorship. "M~b?f,"'--~ ,~ ~ y-- _e' " "~- ~- ,~", '-1~ "'i~'""'"-~'-'''~''"~'""-'~ --- ., --I , ALL THAT CERTAIN lot or piece of land with buildings and improvements thereon erected situate in East Pennsboro Township, Cumberland County, Pennsylvania, bounded and described as follows, to wit: . BEGINNING at a point in the Southern line of Dauphin Street at or opposite the center of the partition wall dividing propefties known as No. 230 and 232 Dauphin Street, said point being Two Hundred Twenty-Nine an,d Three Hundred Eighty-Nine One-Thousands (229.389) feet East of the Southeast comer of Bri Church Road and Dauphin Street; thence along the Southern line of Dauphin Street, North 79 grees 40 minutes East, Forty-Six (46) feet to a point; thence South 10 degrees 20 minutes East, 0 Hundred Seventeen and Five Hundred Five One-Thousandths (117.505) feet to a point; thence Sou 79 degrees 40 minutes West, Forty-Six (46) feet to a point at or opposite the center of the partition wall dividing properties known as No. 230 and 232 Dauphin Street; thence North 10 degrees 20 minutes West through the center of the partition wall dividing properties known as No. 230 and No. 232 Dauphin Street and beyond One Hundred Seventeen and Five Hundred Five One-Thousandths (117.5005) feet to a point, at the place of beginning. . HAVING thereon erected the Eastern One-half of a two story dwelling known as No. 230 Dauphin Street, Enola, Pennsylvania. TAX PARCEL # 09-14-0832-201 Premises: /230 DAUPHIN STREET, TOWNSHIP OF EAST PENNSBORO I CUMBERLAND COUNTY PENNSYLVANIA TITLE TO SAID PREMISES IS VESTED IN Olen E. Jumper, widower by reason of the following BEING THE SAME premises which Theodore E. Sgrignoli and Winifred E. Sgrignoli, his wife by Deed dated 8/29/63 and recofded 8/29/63 in the County of Cumberland in Deed Book Y, Volume 20, Page 737 conveyed unto Olen E. Jumper and Romaine M. Jumper, his wife. . AND THE SAID Romaine M. Jumper died on 7/20/99 whereby title to said premises became vested in Olen E. Jumper by right of survivorship. .-j:!,,-,_>!i;l~.., _Tl ^' ~ - "I, ,.., ~"~ ,~~ If"'. ""'"' ".1 C-- llii,U,,~,),i'.I"'gX....iU FEDERMAN AND PHELAN By: FRANK FEDERMAN IDENTIFICATION NO. 12248 ONE PENN CENTER PLAZA, SUITE 1400 PHilADELPHIA, PA 19103 (215) 563-7000 ATTORNEY FOR PLAINTIFF ASSOCIATES CONSUMER DISCOUNT COMPANY : CUMBERLAND County : Court of Common Pleas Plaintiff : CIVIL DIVISION vs. : NO. 01-6843 OLEN JUMPER Defendant(s) PRAE€IPETO VACATF .JUDGMENT WITHmiT PREJUDICE TO THE PROTHONOTARY: Kindly vacate the Judgment, which was entered on 4/4/02 against OlEN JUMPER, Defendants, in the amount of $53,068.16 relative to the instant matter, without prejudice, upon payment of your costs only. ~L' :54 FRANK FEDERMAN, ESQUIRE Attorney for Plaintiff -- Dated: 4/8/02 !>:;J~, i. "~'_. '_"F - - - -:'" ~I~.''''~~"' - ,~ '" . ~ . ,- - ~- ~, .,"~" ~"~" " i;t~~~(Rw1FiA,zr~*,;;tM, " '""'".", " ." ~,m_ r~.Q!I~J., -",,'_~ . ,. ~~~ ""- ~ ~ "- f' ~ " >i-'",-,-, ."^'''--'-....'-',''-';;''''"''"''''--,'.{,0;.?,''-lC~-~~,j-~' ""''f~-;j~)ii~'2-~-jj"-'-"'-'jla1\~jfll ;'11 ~Wt'rltiW_;'"'\'fil~:ft'''r' 1t (.:) ~ ~ o c -:s: --0 o.~t f1Jf" :2:;:,' Zr :Q~~ ~c_: ~~~~') :v~c -/ 3.. o ,,-) ". -1:) -:;0 - c' S:--J, 'CJ (-0) ,-,-;-,,:;-r;"' "6Q. .~ o o '<l -c) ~ P- O =t? ~~ -- :1: N '.-'- ::2~ ''- / ~ ([1 1=5 81-/ (m:\!W'Q:~m~fl-1j--!~,-.\:~_;-~C:Li-.)lti\l,Il~lrn-___,r;,,!_,,;1~)!;ti'!'~~;;I\'t't1~q;~:~!"'''~-~0~-'' ,*",.tr-,';-lr""ftii'~i'oi'$l~~~;5'; FEDERMAN AND PHELAN By: FRANCIS S. HALLINAN, ESQUIRE IDENTIFICATION NO. 62695 ONE PENN CENTER AT SUBURBAN STATION SUITE 1400 PHILADELPHIA, PA 19103 (215) 563-7000 ASSOCIATES CONSUMER DISCOUNT COMPANY ATTORNEY FOR PLAINTIFF COURT OF COMMON PLEAS CIVIL DNISION Plaintiff v. NO.01.6843-CNIL CUMBERLAND COUNTY OLEN JUMPER, NKI A OLEN E. JUMPER Defendant PRAECIPE TO REINSTATE COMPLAINT PURSUANT TO RULE PA R.C-P. 401(b)(2) TO THE PROTHONOTARY: Kindly reinstate the complaint in the above-captioned civil action in accordance with Pa R.C.P. 401 (b)(2), which allows a complaint to be reinstated at any time and any number of times. A new party defendant may be named in a Reinstated Complaint. Pursuant to Rule PA R.C.P. 401 (b) (2), the new party defendants shall be KATHY JO BROWNA WELL, AlKJA KATHY JO BROWNSWELL, AND MARLEY S. BECK, JR. DATED: If5/rJ) ,/". FRANCIS S. HALLINAN, ESQUIRE . Attorney for Plaintiff ~;,,~~ - ,- ~,-~-. ,-, -~=- . =, ~, "'.~,,~, '-', ,_.. -, """ "if~'" ',- '>1>.-"'--"-t.""l',~ -,-"'~~' 1>:]'",","'" "-' ,""",~,V-'r_':tlAY'-'::-t-' j"" o ~ -or;--, rn,,-:, 2: 2~ UJ " r;; -.;; ~2 '"7 ~3 -, C) P0 C) -T! ':"::J ";""'l ~") '0 .'<(1 c:;> GO ff{;;/ ~ ~_,~ _.."~._~!1i~~ffl&J!';!!Pt~1If""''!f1!!W~;'''!~'i'F'f;i'','-S'-''!I;-;;.;,,,,,w,..,,'''i;;''i$'~]i!'i.'*''tE{f.~!i''!j,'''''"''i~_:0;''~~lli'WIjkiYi1'(,'f.~~~ .,,;',_~_\. .,-~ r.T v ilU, Dri~. FEDERMAN AND PHELAN, LLP By: FRANK FEDERMAN, ESQ., Id. No. 12248 LAWRENCE T. PHELAN, ESQ., Id. No. 32227 FRANCIS S. HALLINAN, ESQ., Id. No. 62695 ONE PENN CENTER PLAZA, SUITE 1400 PHILADELPHIA, PA 19103 (? 1~) ~1i,-7000 ATTORNEY FORPLMNTWF COURT OF COMMON PLEAS CIVIL DIVISION ASSOCIATES CONSUMER DISCOUNT COMPANY 1111 NORTHPOINT DRIVE COPPELL, TX75019 TERM Plaintiff v. NO. 01-6843-CIVIL CUMBERLAND COUNTY KATHY JO BROWNAWELL, NK/ A KATHY JO BROWNSWELL 230 WEST DAUPHIN STREET ENOLA, P A 17025 MARLEY S. BECK, JR. 230 WEST DAUPHIN STREET ENOLA, P A 17025 Defendant( s) RRTNST A TF.D CIVIl, AcnON - I,ll. W COMPI ,A TNT IN MORTr,cAr,cR FORF,CI,OSITRF. NonCR "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. W YOU DO NOT HAVE A LAWYER OR CANNOT AFFORD ONE, GO TO OR TELEPHONE THE OFFICE SET FORTH BELOW TO FIND OUT WHERE YOU CAN GET LEGAL HELP. CUMBERLAND COUNTY CUMBERLAND COUNTY BAR ASSOCIATION 2 LIBERTY AVENUE CARLISLE,PA 17013 (717) 249-3166 ""-.. Loan #: 0000650337/JNR ',~~ ~" - ~. r' - ~" ~ '," ".,~. , ""T' -r '.' 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;*"",w ~"",' ,,-~ ~~ - .'1 . '" <'r . . 'r 1. Plaintiff is ASSOCIATES CONSUMER DISCOUNT COMPANY 1111 NORTHPOINT DRNE COPPELL, TX 75019 2. The name(s) and last known address(es) of the Defendant(s) are: KATHY JO BROWNAWELL, AlKJAKATHY JOBROWNSWELL 230 WEST DAUPHIN STREET ENOLA, P A 17025 MARLEY S. BECK, JR. 230 WEST DAUPHIN STREET ENOLA, P A 17025 who islare the real owner(s) of the property hereinafter described. 3. On 3/2/98, mortgagor(s), OLEN JUMPER AND ROMAlNE JUMPER, made, executed and delivered a mortgage upon the premises hereinafter described to PLAINTIFF which mortgage is recorded in the Office of the Recorder of CUMBERLAND County, in Mortgage Book No. 1435, Page 774. 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 3/15/01 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. ''''r,~~1l: -,., '-"~- '-I, "-",)- -^ . -~, , --" . , - ~ --~ ~-" ,~ -"" "~'~.t,'C:"'-]H-- "1". , ~ - ,'~ 6. The following amounts are due on the mortgage: Principal Balance Interest 2/15101 through 12/2/02 (Per Diem $17.13) Attorney's Fees Cumulative Late Charges 312198 to 12/2/02 Cost of Suit and Title Search Subtotal $44,660.60 17,214.41 800.00 0.00 5.5.lLOQ $63,225.01 Escrow Credit Deficit Subtotal 0.00 llilll $!LOll TOTAL $63,225.01 7. The attorney's fees set forth above are in confonnity with the Mortgage documents and Pennsylvania Law, and will be collected in the event of a third party purchaser at Sheriffs Sale. If the Mortgage is reinstated prior to the Sale, reasonable attorney's fees will be charged. 8. The Combined Notice has been sent to the Defendant(s) by regular and certified mail as required by 35 P.S. SI680.403c. 9. The Temporary Stay as provided by the Homeowner's Emergency Mortgage Assistance Program, Act 91 of 1983, has terminated because either: (i.) Defendant(s) have failed to meet with the Plaintiff or an authorized Credit Counseling Agency in accordance with Plaintiffs written Notice to Defendants; or (ii.) Defendant(s) application for assistance has been rejected by the Pennsylvania Housing Finance Agency. ..-%):1,,,-'10.. '--I' . r '." - .~ 10. Plaintiff hereby releases OLEN JUMPER AND ROMAINE JUMPER from liability for the debt secured by the mortgage. WHEREFORE, PLAINTIFF demands an in = Judgment against the Defendant(s) in the sum of $63,225.01, together with interest from 12/2/02 at the rate of$17.13 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. FED~ AND PHE1JJtLP By: ~t-j 1jJ, FRANK FEDERMAN, ESQUIRE LAWRENCE T. PHELAN, ESQUIRE FRANCIS S, HALLINAN, ESQUIRE Attorneys for Plaintiff , ;""'4~A~ILL-Jl, - ~~ ~, ", " : ,~ ~,"-~ "~y' ~O'" , ~. '<a'-' _"~ _,,~. ~ W "'0 ALL THAT CERTAIN lot or piece of land with buildings and improvements thereon erected situate in East Pennsboro Township, Cumberland County, Pennsylvania, bounded and described as follows, to wit: BEGINNING at a point in the Southern line of Dauphin Street at or opposite the center of the partition wall dividing properties ia10wn as No. 230 and 232 Dauphin Street, said point being Two Hundred Twenty-Nine and Three Hundred Eighty-Nine One-Thousands (229.389) feet East of the Southeast corner of Brick Church Road and Dauphin Street; thence along the Soutben1line of Dauphin Street, North 79 degrees 40 minutes East, Forty-Six (46) feet to a point; thence South 10 degrees 20 minutes East, One Hundred Seventeen and Five Hundred Five One-Thousandths (117.505) feet to a point; thence South 79 degrees 40 minutes West, Forty-Six (46) feet to a point at or opposite the center of the partition wall dividing properties known as No. 230 and 232 Dauphin Street; thence North 10 degrees 20 minutes West through the center of the partition wall dividing properties known as No. 230 and No. 232 Dauphin Street and beyond One Hundred Seventeen and Five Hundred Five One:Thousandths (117.5005) feet to a point, at the place of beginning. HAVING thereon erected the Eastern One-half of a two story dwelling known as No. 230 Dauphin Stre~,Enilla,P~YNanm. TAX PARCEL # 09-14-0832-201 " :0'>:,", L~, _ _,' _ ' "" ',,^,,, .."".n.,__ '_"'" ~ ~_' -" I' - ,"-', ~ ," 'l- ,_ ~ ".~'- --_:c~-l ~ _'._ ,,",w,,' . _". . VERIFICATION TERESA SKINNER hereby states that she is NORTHEAST REGIONAL MANAGER ofCITIFINANCIAL MORTGAGE COMPANY, INC., mortgage servicing agent for the 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 TERE~.d~ DATE)aJ~foo . 'O,~- ,.' - -1 - . -~., ~ " ,...~~ l-"~"-'F"~ ~ ~- -" ~- - ,__,~, - ',.c--'" ~,.-,__' -~,-~-~ ~ , .. .. 'IID 1 .i lJln".iliiili"~ITt" "ftJ ~~ ~t: ~~ ,,",.m... _ __"""'~_' ^_~_ ,,.,,,^_~' ,L,_~_ .,' _~_ ,-4",1l_~, _ ,lJIIl;~~~I!Illi!~!JB!~~I$'t"""~"\"7&M-!N'!1,,,::~':<-"_:'~';r,,!qi"W~I!'!f''''_<[~~ff!~fli~jif~;!,,,,:gpj)<!\1tI~~~~ l~;;.i:;,(:;i'i'J;~;';i~,,:;~}~fi"~ SHERIFF'S RETURN - NOT SERVED GASE NO: 2001-06843 P COMMONWEALTH OF PENNSYLVANIA COUNTY OF CUMBERLAND ASSOCIATES CONSUMER DISCOUNT VS JUMPER OLEN E R, Thomas Kline , Sheriff , who being duly sworn according to law, says, that he made a diligent search and inquiry for the within named DEFENDANT , to wit: BROWNAWELL KATHY JO A/K/A KATHY JO BROWNSWELL but was unable to locate Her in his bailiwick. He therefore returns the COMPLAINT - MORT FORE NOT SERVED , as to the within named DEFENDANT , BROWNAWELL KATHY JO A/K/A KATHY JO BROWNSWELL NOT SERVED PER FAX FROM NAISHA LANIER AT FEDERMAN & PHELAN. Sheriff's Costs: Docketing Service Affidavit Surcharge 18.00 ,00 .00 10.00 ,00 28,00 COUNTY FEDERMAN & PHELAN 12/27/2002 Sworn and subscribed to before me this oM( day 0/1 AU ~ J d403 A.D. Cl L Q ~.t..v pr;:;th6~tary , ~ ,'~R_~iiilt", 7_, . ~"l'''' -'- ~-~, " I ........... ~~il".'.,.m""'ij'....,,,..".""'F=..>1'~~~ r;f:~";;';;'T';;;,~;2,~~,",;e: SHERIFF'S RETURN - NOT SERVED CASE NO: 2001-06843 P COMMONWEALTH OF PENNSYLVANIA COUNTY OF CUMBERLAND ASSOCIATES CONSUMER DISCOUNT VS JUMPER OLEN E R. Thomas Kline , Sheriff , who being duly sworn according to law, says, that he made a diligent search and inquiry for the within named DEFENDANT , to wit: BECK MARLEY S JR but was unable to locate Him in his bailiwick, He therefore returns the COMPLAINT - MORT FORE NOT SERVED , as to the within named DEFENDANT , BECK MARLEY S JR NOT SERVED PER FAX FROM NAISHA LANIER AT FEDERMAN & PHELAN. Sheriff's Costs: Docketing Service Affidavit Surcharge 6.00 .00 ,00 .00 10.00 16,00 ~ . T MA KLINE SHERIFF OF CUMBERLAND COUNTY FEDERMAN & PHELAN 12/27/2002 Sworn and subscribed to before me this 3M day of (l,..",." '::f f ;Lfro3 A.D. ~L . (J Ivt..PP"-', ~ P 0 honotary "',1?""'~~!!!lf,l_ ~ .,"__ n ~ I ~ ,~ 1J!!!ll!I",~ ~ "~~",,,,_~ ~.~~~1 'h~ ,,". r FEDERMAN AND PHELAN, LLP By: FRANK FEDERMAN, ESQ., Id. No. 12248 LAWRENCE T. PHELAN, ESQ., Id. No. 32227 FRANCIS S. HALLINAN, ESQ., Id. No. 62695 ONE PENN CENTER PLAZA, SUITE 1400 PHILADELPHIA, PA 19103 (71 'i) 'i1i1-7000 ATTORNEY FOR PLAINTIFF COURT OF COMMON PLEAS CNIL DNISION ASSOCIATES CONSUMER DISCOUNT COMPANY IIII NORTHPOINT DRNE COPPELL, TX 75019 TERM Plaintiff v. NO. 01-6843-CNIL CUMBERLAND COUNTY KATHY JOBROWNAWELL, AIKIA KATHY JO BROWNSWELL 230 WEST DAUPHIN STREET ENOLA, P A 17025 ~ RMeby certify the '\l>Jithin to be a true and ;orrect copy of the original tiled of record FEDERMAN AND p~ MARLEY S. BECK, JR. 230 WEST DAUPHIN STREET ENOLA, P A 17025 Defendant( s) RF.TNSTATlm r.TVn, ACTION - LAW COM]>T ,A TNT TN MORTGAGE FORRr.T ,OSTTRF. NOTWR **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, TillS CORRESPONDENCE IS NOT AND SHOULD NOT BE CONSTRUED TO BE AN ATTEMPT TO COLLECT A DEBT, BUT ONLY ENFORCEMENT OF A LIEN AGAINST PROPERTY. ** You have been sued in Court. If you wish to defend against the claims set forth in the following pages, you must take action within twenty (20) days after this Complaint and Notice are served, by entering a written appearance personally or by attorney and filing in writing with the court your defenses or objections to the claims set forth against you. You are warned that if you fail to do so the case may proceed without you and a judgment may be entered against you by the court without further notice for any money claimed in the Complaint or for any other claim or relief requested by the Plaintiff. You may lose money or property or other rights important to you. YOU SHOULD TAKE THIS PAPER TO YOUR LAWYER AT ONCE. IF YOU DO NOT HAVE A LAWYER OR CANNOT AFFORD ONE, GO TO OR TELEPHONE 1HE OFFICE SET FORTH BELOW TO FIND OUT WHERE YOU CAN GET LEGAL HELP. Loan #, 0000650337/JNR CUMBERLAND COUNTY CUMBERL~~~~~~~sOf~wpy FROM RECORD CARLISLE, PA 17013 ." Te&Umony wher8Of, I here unto set my hand (717) 249-3166 and. UlJ....." said COO~.lsle. Pa :~ay~. ~~ othllllotarv ~ u ,..,. '1," ~ ~I .--~ ....,'. - , - "~ ~ "~~. r"'''''''''- t,.~ 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 WITmN TmRTY (30) DAYS OF RECEIPT OF TmS PLEADING, COUNSEL FOR PLAINTIFF WILL OBTAIN AND PROVIDE DEFENDANT(S) WITH WRITTEN VERIFICATION mEREOF; OTHERWISE, THE DEBT WILL BE ASSUMED TO BE VALID. LIKEWISE, IF REQUESTED WITmN TmRTY (30) DAYS OF RECEIPT OF Tms 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 TmRTY (30) DAY PERIOD FOLLOWING FIRST CONTACT WITH YOU BEFORE SUING YOU TO COLLECT Tms DEBT. EVEN THOUGH THE LAW PROVIDES THAT YOUR ANSWER TO THIS COMPLAINT IS TO BE FILED IN Tms ACTION WITmN 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 TmRTY (30) DAYS AFI'ER YOU HAVE RECEIVED Tms COMPLAINT. HOWEVER, IF YOU REQUEST PROOF OF THE DEBT OR THE NAME AND ADDRESS OF THE ORIGINAL CREDITOR WITmN THE THIRTY (30) DAY PERIOD mAT BEGINS UPON YOUR RECEIPT OF Tms COMPLAINT, THE LAW REQUIRES US TO CEASE OUR EFFORTS (THROUGH LITIGATION OR OTHERWISE) TO COLLECT mE DEBT UNTIL WE MAIL THE REQUESTED INFORMATION TO YOU. YOU SHOULD CONSULT AN ATTORNEY FOR ADVICE CONCERNING YOUR RIGHTS AND OBLIGATIONS IN THIS SUIT. "_'r4~!': ..;'d' I " :!", . l.!il - ;;i~' -'".~. o~_ I. Plaintiff is ASSOCIATES CONSUMER DISCOUNT COMPANY 1111 NORTHPOINT DRIVE COPPELL, TX 75019 2. The name(s) and last known addressees) of the Defendant(s) are: KATHY JO BROWNA WELL, AlKI A KATHY JO BROWNSWELL 230 WEST DAUPHIN STREET ENOLA, P A 17025 MARLEY S. BECK, JR. 230 WEST DAUPHIN STREET ENOLA, P A 17025 who islare the real owner(s) of the property hereinafter described. 3. On 3/2/98, mortgagor(s), OLEN JUMPER AND ROMAINE JUMPER, made, executed and delivered a mortgage upon the premises hereinafter described to PLAINTIFF which mortgage is recorded in the Office of the Recorder of CUMBERLAND County, in Mortgage Book No. 1435, Page 774. 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 3/15/01 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. ':;::-t~Blf,_,_~., ,_ .'- T~ ,';- _ .'1' '" _'d _. ,. , ., J _,~ ,,,_,.~ .,_, ,.,~ ", . . ~1 -"" ~:j . 6. The following amounts are due on the mortgage: Principal Balance lnterest 2/15/01 through 12/2/02 (Per Diem $17.13) Attorney's Fees Cumulative Late Charges 3/2/98 to 12/2/02 Cost of Suit and Title Search Subtotal $44,660.60 17,214.41 800.00 0.00 5.iO.illl $63,225.01 Escrow Credit Deficit Subtotal 0.00 .oJill $O..illl TOTAL $63,225.01 7. The attorney's fees set forth above are in conformity with the Mortgage documents and Pennsylvania Law, and will be collected in the event of a third party purchaser at Sheriffs Sale. If the Mortgage is reinstated prior to the Sale, reasonable attorney's fees will be charged. 8. The Combined Notice has been sent to the Defendant(s) by regular and certified mail as required by 35 P.S. ~1680.403c. 9. The Temporary Stay as provided by the Homeowner's Emergency Mortgage Assistance Program, Act 91 of 1983, has terminated because either: (i.) Defendant(s) have failed to meet with the Plaintiff or an authorized Credit Counseling Agency in accordance with Plaintiff's written Notice to Defendants; or (ii.) Defendant(s) application for assistance has been rejected by the Pennsylvania Housing Finance Agency. "'O~, --,,"-~-,' ,- - ,~ .,.," , ''''~I,_~ _.k ,-, ," ,~ -- l - ~~"".~ i;. Plaintiff hereby releases OLEN JUMPER AND ROMAINE JUMPER from liability for the debt secured by the mortgage. ",' rJi ':REFORE, PLAINTIFF demands an in rem Judgment against the Defendant( s) in the sum of $63,225.01, together with interest from 12/2/02 at the rate of$17.13 per diem to the date of ludgcnent, and other costs and charges collectible under the mortgage and for the foreclosure and ,'ale of the mortgaged property. FED~ AND PHE):2tLP By: Y-UCIA.U- t-! 1) . FRANK FEDERMAN, ESQUIRE LAWRENCE T. PHELAN, ESQUIRE FRANCIS S. HALLINAN, ESQUIRE Attorneys for Plaintiff :","'.~t'\Ii~,'~_ ,V' ,_,_,,~_, "'1_"1'_"."< U """f I'~ -'" " ~."-- "'"'"'''''''''''''; ",,,-,,"-" "+.~l;lii ALL THAT CERTAIN lot or piece of land with buildings and improvements thereon erected situate in East Pennsboro Township, Cumberland County, Pennsylvania, bounded and described as follows, to wit: BEGINNING at a point in tbe Southern line of Dauphin Street at: or opposite the center of the partition wall dividing properties known as No. 230 and 232 Dauphin Street, said point being Two Hundred Twenty-Nine and Three Hundred Eighty-Nine One-Thousands (229.389) feet East of the Southeast corner of Brick Church Road and Dauphin Street; thence along the Southern line of Dauphin Street, North 79 degrees 40 minutes East, Forty-Six (46) feet to a point; thence South 10 degrees 20 minutes East, One Hundred Seventeen and Five Hundred Five One-Thousandths (117.505) feet to a point; thence South 79 degrees 40 minutes West, Forty-Six (46) feet to a point at or opposite the center of the partition wall dividing properties known as No. 230 and 232 Dauphin Street; thence North 10 degrees 20 minutes West through the center of the partition wall dividing properties known as No. 230 and No. 232 Dauphin street and beyond One Hundred Seventeen and Five Hundred Five Ouc:Thousandths (117.5005) feet to a point, at the place of beginning. HAVING thereon erected the Eastern One-haIf of a two story dwelling known as No. 230 Dauphin Street, Enola, Pennsylvania. TAX PARCEL # 09-14-0832-201 " . ,- ~. -I,' ,_<.e_"_ . ~ ." I' ."'~~ ~ ~~ VERIFICATION TERESA SKJNNER hereby states that she is NORTHEAST REGIONAL MANAGER ofCITIFINANCIAL MORTGAGE COMPANY, INC., mortgage servicing agent for the 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 TF1lE~.d~ DATE)A J!i 100 . '.~~H~'",,'1',-""1!' "._~,<_."~-~-~",,,-~,~,,-_..~c-' 1.,1 -< "'" "'It _~ , . - "- r"~"- - .', . ,,"",. _. d... c<, ._...,B. " "''''' ~, _' ,P,:!l:J ~''''''''''~I .a:,~. , """'1iIITrr1ImllliJi,jjlliijn~,!fI" '~ "'~ ">",, ';~~:;'-':" \:p;r.:1 !"~flRf.!t!~'1fl';t~~'ll'''';1%:''~O*;:fI!il<F '''-'':i.%l::''';'!?;t~~~!\l!~~j;{~~~_~~i11It~JIl{li~,~q~~~; , 'I'~~l ,,>; , FEDERMAN AND PHELAN, LLP By: FRANK FEDERMAN, ESQ., Id. No. 12248 LAWRENCE T. PHELAN, ESQ., Id. No. 32227 FRANCIS S. HALLINAN, ESQ., Id. No. 62695 ONE PENN CENTER PLAZA, SUITE 1400 PHILADELPHIA, PA 19103 (7.1S) ~6,- 7000 ATTORNEYFORPLAlNT~ COURT OF COMMON PLEAS CIVIL DIVISION ASSOCIATES CONSUMER DISCOUNT COMPANY 1111 NORTHPOINT DRIVE COPPELL, TX 75019 TERM Plaintiff v. NO. 01-6843-CIVIL CUMBERLAND COUNTY KATHY 10 BROWNA WELL, AfKJA KATHY 10 BROWNSWELL 230 WEST DAUPHIN STREET ENOLA, P A 17025 ~ '!ereby certify the \ll\!lthm to be a true anc correct copy of the onginal filed of record FEDERMAN AND PHELAl't MARLEY S. BECK, JR. 230 WEST DAUPHIN STREET ENOLA, P A 17025 Defendant( s) RRTNSTATIW CIVIl, ACTION - I ,A W COMPI ,AINT TN MORTGAGR FORRCI ,OSTTRF. NOTlCF, "TillS FIRM IS A DEBT COLLECTOR ATTEMPTING TO COLLECT A DEBT AND ANY INFORMATION OBTAINED WILL BE USED FOR THAT PURPOSE, IF YOU HAVE PREVIOUSLY RECEIVED A DISCHARGE IN BANKRUPTCY AND THIS DEBT WAS NOT REAFFIRMED, THIS CORRESPONDENCE IS NOT AND SHOULD NOT BE CONSTRUED TO BE AN ATTEMPT TO COLLECT A DEBT, BUT ONLY ENFORCEMENT OF A LIEN AGAINST PROPERTY. ** You have been sued in Court. If you wish to defend against the claims set forth in the following pages, you must take action within twenty (20) days after this Complaint and Notice are served, by entering a written appearance personally or by attorney and filing in writing with the court your defenses or objections to the claims set forth against you. You are warned that if you fail to do so the case may proceed without you and a judgment may be entered against you by the court without further notice for any money claimed in the Complaint or for any other claim or relief requested by the Plaintiff. You may lose money or property or other rights important to you. YOU SHOULD TAKE THIS PAPER TO YOUR LAWYER AT ONCE. IF YOU DO NOT HAVE A LAWYER OR CANNOT AFFORD ONE, GO TO OR TELEPHONE THE OFFICE SET 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 #: 0000650337/JNR l'RUE COPY FROM RECORD I" Tee&\nIOny wllel'IlII. IlIere unto set my haM ~~!~Coo~'~ ~. u.~if1 ~~ Prathonotg'- -',~ ^ ~ ~, <" ,~ - - -"I~, - "',~ ,~~~, r~ m. ~":' . 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. :;;j~.'M!! . ""~'-_,'_"__7',-_,_,,; ___~ -__ ~I _ ~"1""- I~ , " '"' f 1. Plaintiff is ASSOCIATES CONSUMER DISCOUNT COMPANY 1111 NORTHPOINT DRIVE COPPELL, TX 75019 2. The name(s) and last known addressees) of the Defendant(s) are: KATHY JO BROWNA WELL, AIKJ AKA THY JO BROWNSWELL 230 WEST DAUPHIN STREET ENOLA, PA 17025 MARLEY S. BECK, JR. 230 WEST DAUPHIN STREET ENOLA, P A 17025 who islare the real owner(s) of the property hereinafter described. 3. On 3/2/98, mortgagor(s), OLEN JUMPER AND ROMAlNE JUMPER, made, executed and delivered a mortgage upon the premises hereinafter described to PLAINTIFF which mortgage is recorded in the Office of the Recorder of CUMBERLAND County, in Mortgage Book No. 1435, Page 774. 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 3/15/01 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. ;,''Cjm!'if'UJii!,< ~1"' _ '?_ -",^~ '''''I, ~~ ,,'~-= :"'.' .~~~~_, .. "~'^' ,_ u 6. The following amounts are due on the mortgage: Principal Balance Interest 2/15/01 through 12/2/02 (per Diem $17.13) Attorney's Fees Cumulative Late Charges 3/2/98 to 1212102 Cost of Suit and Title Search Subtotal $44,660.60 17,214.41 800.00 0.00 .i5flilll $63,225.01 Escrow Credit Deficit Subtotal 0.00 Jl.ill) $fiJlQ TOTAL $63,225.01 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. The Combined Notice has been sent to the Defendant(s) by regular and certified mail as required by 35 P.S. ~ I 680.403c. 9. The Temporary Stay as provided by the Homeowner's Emergency Mortgage Assistance Program, Act 91 of 1983, has terminated because either: (i.) Defendant(s) have failed to meet with the Plaintiff or an authorized Credit Counseling Agency in accordance with Plaintiffs written Notice to Defendants; or (ii.) Defendant(s) application for assistance has been rejected by the Pennsylvania Housing Finance Agency. ~'f'l~:.~. 1 .~, ,'d',; ">..1_ 1'_. <,,,.. ,n_.' ,__, ~'p_ ~~,'~_'~_ .-~ ,"'C ~ ., ~~~ :~t" "<. -,_.'- ] O. Plaintiff hereby releases OLEN JUMPER AND ROMAINE JUMPER from liability for the debt secured by the mortgage. WHEREFORE, PLAINTIFF demands an in rem Judgment against the Defendant(s} in the sum of $63,225.0], together with interest from 12/2/02 at the rate of $17.13 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. FED~AN AND PHEMLLP By: ~t-/ 1J. FRANK. FEDERMAN, ESQUIRE LAWRENCE T. PHELAN, ESQUIRE FRANCIS S. HALLINAN, ESQUIRE Attorneys for Plaintiff ^"i'~~',<,~~ " . "'__,~ ' > - -'~I' " . l' '","~'- 'T""" ~-'. ',.. ,\LL THAT CERTAIN lot or piece of land with buildings and improvements thereon erected situate in East Pennsboro Township, Cumberland County, Pennsylvania, bounded and described as follows, '0 wit: BEGINNING at a point in tbe Southern line of Dauphin Street at or opposite the center of the partition wall dividing properties Imown as No. 230 and 232 Dauphin Street, said point being Two Hundred Twenty-Nine and Three Hundred Eighty-Nine One-Thousands (229.389) feet East of the Southeast (;Orner of Brick Church Road and Dauphin Street; thence along the Southem line of Dauphin Street, North 79 degrees 40 minutes East, Forty-Six (46) feet to a point; thence South 10 degrees 20 minutes East, One Hundred Seventeen and Five Hundred Five One-Thousandths (117.505) feet to a point; thence South 79 degrees 40 minutes West, Forty-Six (46) feet to a point at or opposite the center of the partition wall dividing properties Imown as No. 230 and 232 Dauphin Street; thence North 10 degrees 20 minutes West through the center of the partition wall dividing properties known as No. 230 and No. 232 Dauphin Street and beyond One Hundred Seventeen and Five Hun<lFed Five One:Thousandths (117.5005) feet to a point, at the place of beginning. HAVING thereon erected the Eastern One-half of a two story dwelling known as No. 230 Dauphin Street, Enola, Pennsylvania. TAX PARCEL # 09-14-0832-201 I'Y<~~ ,_, "_'. ,.,,,.. >. _~ - ~,_ "."'1' ~" ~ , ,4<JJL ,I;:" ~~ C^'~j~"-li" VERIFICA nON TERESA SKINNER hereby states that she is NORTHEAST REGIONAL MANAGER of CITIFINANCIAL MORTGAGE COMPANY, INC., mortgage servicing agent for the 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 TERE~.J~ DATE)i) J5'fOo . ,-':;;.,#j,trM.'J?...,.,.,, ":_ ,$~ . '.." ,__ n, . '. IIIIIr ,", ~.~ '."'~= ~. :Eq " ).,' ,I"';' , ,- ,,,.'~ .~. ~,-~H~ -"~" ~. '-^'-~"' " v, ,,^, Tf~tffirtrt'J''"'"'"'- "~:'-" 'i7"Utl'::if'1lm"""r'''r.1e;,~ii .~ .~ -:';-:-":-'" -;;-~:: <~,~.~.) ..~.;,~ \if'P " jS r lli,w,J~jl~ """""~ _~~m.t~i','~\i!jw,r_'Il'!J!]io;i~""i-~""1i"ff;! :"~;'-\~~~tf"""'ll'ifi,,~iH\l'~@f~,,~~>w.l~:\liilf":iF_,g.::t~!;iIiI~~~~t< FEDERMAN AND PHELAN, LLP By: 'Frank Federman, Esquire 1.0, No. 12248 Lawrence T. Phelan, Esquire 1.0. No. 32227 Francis S. Hallinan, Esquire 1.0. No. 62695 One Penn Center at Suburban Station Suite 1400 Philadelphia, PA 19103-1814 (215) 563-7000 Attorney for Plaintiff ASSOCIATES CONSUMER DISCOUNT COMPANY Plaintiff Court of Common Pleas CUMBERLAND County No. 01-6843-CIVIL Vs. KATHY JO BROWNAWELL, AfKIA KATHY JO BROWNSWELL MARLEY S. BECK, JR. Defendant(s) PRAECIPE TO WITHDRAW COMPLAINT, WITHOUT PREJUDICE TO THE PROTHONOTARY: Kindly withdraw the complaint filed in the instant matter, without prejudice, upon payment of your costs only. A Chapter 13 bankruptcy was filed on 12/03/02, which invalidated the complaint. /-13-6.3 )~.s. ~ Frank Federman, Esquire Lawrence T. Phelan, Esquire Francis S, Hallinan, Esquire Attorneys for Plaintiff Date <~~...t:!F - ~ '0'-" ,,~ .,,, . ":;";:,;:-,'A" Jd" "",-";~fV"" Mlii~Jr '"'<<~ i'd"1"1f" ;, j?lr';:'_~~'i; c-:; t..> o ,- ~.~ (}~,~- ,,-<~ .,-- ~>; (-';:-" )-~ '~~;~ :-,;3 -, -',t, C', ~';:-I c~- 8\, ::6 -< :;..J (-~ .J ~\~ -11, ~ .IJ.(JJn~,,,,".,. ~ .J'n, _ fif_,,:ijIW.hlL!~:~n:iffil\!'j1_IMI$~Hi~~_~!~~~'I!%"$"fj""'''M)!'-!.f'W*-:",-i~~'<~",~'_C~""'''_.,'''_',: ;tm:'-""',,:,;<!y::-'l'___,m"/ik,Fi'R~1~i-:!tJ"~f:lm~~W~l"H!~~~~l!'<i/