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Home My WebLink About01-07002 , ~, \. lit' .' FEDERMAN AND PHELAN, LLP By: FRANK FEDERMAN, ESQUIRE IDENTIFICATION NO. 12248 ONE PENN CENTER AT SUBURBAN STATION 1617 JOHN F. KENNEDY BOULEVARD SUITE 1400 PHILADELPHIA, PA 19103-1814 (215) 563-7000 WELLS FARGO HOME MORTGAGE, INC. 5024 P ARKW A Y PLAZA BOULEVARD CHARLOTTE, NC 28217-2407 ATTORNEY FOR PLAINTIFF COURT OF COMMON PLEAS CIVIL DIVISION Plaintiff TERM NO. 0\ - 7CX>J..... C? l ~ll ( ~ CUMBERLAND COUNTY v. DEBBIE J. DETWILER 252 MCALLISTER CHURCH ROAD CARLISLE, PA 17013 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 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 TmS PAPER TO YOUR LAWYER AT ONCE. IF YOU DO NOT HAVE A LAWYER OR CANNOT AFFORD ONE, GO TO OR TELEPHONE THE OFFICE SET FORTH BELOW TO FIND OUT WHERE YOU CAN GET LEGAL HELP. CUMBERLAND COUNTY CUMBERLAND COUNTY BAR ASSOCIATION 2 LIBERTY AVENUE CARLISLE, PA 17013 (717) 249-3166 Loan #: 4133317 ""f-<''''~~,,~_~. ",.,,,.""', .,. , , "~ """ ....-.~ .~~..~~ ~ , ~ ~~,~ - ~ ,~M",'~"" . ... ~",'"o;i,W~~"~",~~,, ,,"1. " .,.-., ~~ IF TIDS IS THE FIRST NOTICE THAT YOU HAVE RECEIVED FROM TIDS 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 AFfER 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. "". '" ,'""....~~... ~~"-~ ~" ~ . ~""""; --. --~ ." -",'''',w,"~~",~"~ I. Plaintiff is WELLS FARGO HOME MORTGAGE, INC. 5024 PARKWAY PLAZA BOULEVARD CHARLOTTE, NC 28217-2407 2. The name(s) and last known addressees) of the Defendant(s) are: DEBBIE J. DETWILER 252 MCALLISTER CHURCH ROAD CARLISLE, P A 17013 who is/are the mortgagor(s) and real owner(s) ofthe property hereinafter described. 3. On 10/8/96 mortgagor( s) made, executed and delivered a mortgage upon the premises hereinafter described to SIGNET MORTGAGE COMPANY which mortgage is recorded in the Office of the Recorder of CUMBERLAND County, in Mortgage Book No. 1346, Page 681. PLAINTIFF is now the legal owner of the mortgage and is in the process of formalizing an assignment of same. 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 8/1/01 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. ", . "~.. , ,W,"" , W"~ =~~~, lfi~iil;.; ;;e"n ,~~..,"~_e'~'~ . 6. The following amounts are due on the mortgage: Principal Balance Interest 7/1/01 through 1111/01 (Per Diem $15.41) Attorney's Fees Cumulative Late Charges I 0/8/96 to 11/1/01 Cost of Suit and Title Search Subtotal $67,223.25 1,910.84 1,225.00 79.23 550.00 $70,988.32 Escrow Credit Deficit Subtotal 0.00 384.98 $ 384.98 TOTAL $71,373.30 7. The attorney's fees set forth above are in conformity with the Mortgage documents and Pennsylvania Law, and will be collected in the event of a third party purchaser at Sheriffs Sale. If the Mortgage is reinstated prior to the Sale, reasonable attorney's fees will be charged. 8. This action does not come under Act 6 of 1974 because the original mortgage amount exceeds $50,000.00. 9. The Combined Notice has been sent to the Defendant(s) by regular and certified mail as required by 35 P.S. ~1680.403c. 10. 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 $71,373.30, together with interest from 11/1/01 at the rate of $15.41 per diem to the date of Judgment, and other costs and charges collectible under the mortgage and for the foreclosure and sale of the mortgaged property. Jr-J:-~~ Isl Frank Federman FRANK FEDERMAN, ESQUIRE Attorney for Plaintiff "'""','>""" ~., ~ ~""~" ", ") .'~,.,......, ,~ ~ " llIll'___' ~~._.~~ " J " At.L t.hole certain lots ot grotlOd in We.:s't llennsboro T,.,wnshi~~r CurnbeJ:land County, pe.nn~ylva,n.ia,. bounded a.nd descrlbe.ct As fQll()ws~ 'rPA~ 1: BEGiNNtNG -at a point in the- center- at the publ ic road. le.ading trom the state Ro-ad. by E1U.ot5.on 5tAt.l\,)l\ to th~ 1'urnplke; thence in a West~ardly dtrection by prope~tYr now or fot~erly of John Uipt>t'llltee:l, a dista.no,e of one hundred sevent.een (l17) feet, tnoce Ot: le3.$, to a poSt1 thence i,t'J. a so-utherly dlrect10n along property, now or to~merly of Cutti~ Xelter, a di~c~n~e of eighty- seven {Bil feet, mo~e oc le~s, to a post; thenc~ by the same in an Eafotwal:dly dir(!lctj,o~, a distance of one hundred ar'ld seventeen (1l.7) feet, mQt:e: 0% lesa, to the centll!!1; of aai.d public road; thence alonq the center ot aaid pub~it; road, in 4 Nocthw.u'dl y dh;ec:tion, a di5tance of t:lghty-seven (87) f~~t t::o a point, th,e place of Ueqinl1ing. COl/'l'AIII!liG forty thereon ere.eted lmprQvt'..meo.llt.s.. (40) perches of land, more or lesBI' ~Hld having a two-story frame dwellin~ hou$e and othe~ ~MC'1' 2: BEGINNING at 8 point in the cast.ern :!!ide of it i'lublie c;oad, which po1nt i, ht line: of pro-p~rty (lOW at fot:m.erly of RobeIt Meherlig; th'l!nce in a.n f'.astw.u:aly direction along: -land nOW' or f:ormerly of the :ta:l.~ .Hebe.;d1.g, a diata,nce of ;o.ixty-nine (59} feet. 1:0 "" post; tht.!nce in A s~thw.ardly direction along land#, I10W or formetly of' ,Mrs. Amy Roc:kcy, i\ dlst4nce of :lh(tY.~l>i~ (66)'::feet to a stak.e: Ulenoe .in a Wes't.wardly d1r-e~tion alonq other land !lOW or; fOrIl\f!c.l..y of John R. snyder am1 Genevieve S. Snyderj a dist.ance of sh::ty-nine CG9} teet to 3. point (.a 3-take} in the ea:stat:n -:ol.cte ol the afol;esaid publio road; thence .in a Not'thw&rtjly direotion alonq the ea:lte.r;n side of said public ~o-ad a. di.stance of sixt,y-a.i.x (€iG} ;:tt~l~~~~~~~'~~~~~~~'l!a~~~~~~,~i%ng known and ntUl"be<e<l . VERIFICATION TAMMY JOHNSON hereby states that she is ASSISTANT VICE PRESIDENT of WELLS FARGO HOME MORTGAGE, INC. mortgage servicing agent for Plaintiff in this matter, that she is authorized to take this Verification, and that the statements made in the foregoing Civil Action in Mortgage Foreclosure are true and correct to the best of her knowledge, information and belief. The undersigned understands that this statement is made subject to the penalties of 18 Pa. C.S. Sec. 4904 relating to unsworn falsification to authorities. DATE: /Z-IO-o/ '~'~:"'!.!jlt, \~",.""',",-' TIll! . ,~,.,,"~, ~ , ',' <~ "~ ~ ;: !JjLUL ~JJt,<,=,,. _ ,=' ,~ ' ~ , ,. ~. ItfllllflJ!!i1!j ,,,,",,,,~#l-~Ijl{! ',;"~< ,'---~ " '-^ ",,'-,~, '-~. ,- ~ "', ,<,,~ ' '~"". ",.' ""'.-'~''''S'''~' ,., ,~,.,",",',,' ., ,C.,"... "III'~""'"r''' 'fjrlfiillmrlmrurtftiW' \f~ ........ '- :() ~ ~ () w 8~ i<l. ~ ~ C); Flf ~t- 0 C':~ c:: f:! r',J -;:) , nl ['! , l ~. ""; " ~2 , c.. r-::; ,. , :::..., , ce--:"' i i :..> " '::::1 " C"~ ., . , .,,~ 8 '" ",.', -, "~ijil_~ftl@!H;,'&W0'-*.t~'~!m'liMlr4!W!.11!,ljijJtJlJJft; , ~'-''';W'~'\.'"~;-''W0N'',"~iWc,,;8--~W~ ..,~,;.IHiIl!!!~~5~Q',;a.,_ -g .: , FEDERMAN AND PHELAN, L.L.P. BY: FRANK FEDERMAN, ESQUIRE Identification No. 12248 ONE PENN CENTER AT SUBURBAN STATION 1617 JOHN F. KENNEDY BLVD. STE 1400 PHILADELPHIA, PA 19103-1814 (215) 563-7000 ATTORNEY FOR PLAINTIFF WELLS FARGO HOME MORTGAGE, INC. COURT OF COMMON PLEAS CUMBERLAND COUNTY No. 01-7002-CIVIL TERM, 2001 Plaintiff Vs. DEBBIE J. DETWILER Defendant(s) SUGGESTION OF RECORD CHANGE RE: PLAINTIFF'S NAME TO THE PROTHONOTARY: FRANK FEDERMAN, ESQUIRE, attorney for the Plaintiff, hereby certifies that, to the best of his knowledge, information and belief the plaintiff' was erroneously listed in the complaint as: WELLS FARGO HOME MORTGAGE, INC. The correct name for the Plaintiff is: MORTGAGE ELECTRONIC REGISTRATION SYSTEMS, INC. Kindly change the information on the docket. Date: December 26, 2001 '~,()'~ Frank Federman, Esquire Attorney for Plaintiff ""'F~ii.0>l~~ '!i;M~U Y,'~ " ~, '" e, --".-"""', "",;;,,; e.,. e ".Y#'~" ~",.,'Ph' '"e"c.,' '.. , . ,..,,#_,_ ' TUIlIIJK ee" 'llnllt'I'lfftiifuj!i~ 0 0 0 c: ~T1 ~' Cl ~-- -00:' ,'I 1] r<1r" n r-- Z::C f',~ :'~~\;? 2r- 0~ 0' ':.~;-l ~C:; --0 ~;~ .~-'" 2?;o -'~ ~C' r~ 5c --I Z ~~ -- (.fl :< -< fS BH ..IIl" ,~,' r"~"''''''~'' I ",,_":,"",l'lJ1l~~,~~ii;'i'ii.1~~W,;r,J'J',,~~--,",'!~"n' n_',__,"'_,., ;"J.,,,,,,S'g~~Wi~i'~i1;JJJ!lVllW!i-lff:i~~~~~~;:~,t~!jl,jH~~' FEDERMAN AND PHELAN, L.L.P. BY: FRANK FEDERMAN, ESQUIRE Identification No. 12248 Suite 1400, One Penn Center at Suburban Station 1617 John F. Kennedy Blvd. Philadelphia, PA 19103-1814 (215) 563-7000 ATTORNEY FOR PLAINTIFF Plaintiff COURT OF COMMON PLEAS CUMBERLAND COUNTY No. 01-7002-CIVIL TERM, 2001 WELLS FARGO HOME MORTGAGE, INC. Vs. DEBBIE 1. DETWILER Defendant(s) STJ~~RSTTON OF RRCORn CH AN~F. RF.' PARA~RAPH#l OFTHR COMPT.ATNTTNMORT~A~R FORRCT.OSTJRR TIlJ'HF PROTHONOTARY: FRANK FEDERMAN, ESQUIRE, attorney for the Plaintiff, hereby certifies that, to the best of his knowledge, information and belief that the information in paragraph #3 of the Complaint in Mortgage Foreclosure IS: On 10/8/96 mortgagor(s) made, executed and delivered a mortgage upon the premises hereinafter described to SIGNET MORTGAGE CORPORATION which mortgage is recorded in the Office of the Recorder of CUMBERLAND County, in Mortgage Book No. 1346, Page 681. PLAINTIFF is now the legal owner of the rnortgage and is in the process offormalizing an assignment of same. Kindly change the information on the docket. Date: December 26,2001 1:~;;rdL- Frank Federman, Esquire Attorney for Plaintiff '" """""'~, " . " ,~ ~~. . ~ "1:" ,~"~ 'T,,,,",, ~l~_l " '" ~,)n,." '"', ." . ~-- ' "".' '~'~,"--"~" -. &~, '"',",,''''''''' ",(,' " ~f'"",,,..',nrJ"'<,"" ';I< 't,";'~_,"""~b~"'~'""> ',~ -",,""" ""r~I"',"'"':'<"t';-rf'r~P''' o c S. -001 mrn :z::rJ Z.e' <;9 ':2: =..., ~L~' :;':;:0 "'-c S;;c ~ o - o rn C) N CP ~:. .-.:) ::l!:. N .. o -n .--A;. ~j;~ (2:t:i ':c :j~ ~~ c~) Om ;c.; .~ :\:1 :< - Cf' &:5 ~ ""111 .1,.0,/, ,,,' ,~it- ----,.~~l1i'i!!l, ~..~~~!llJlr_~,,~, ,!""i,~~!fii"!i!-,"'l',g,i0l)JJj'(:<';-:;-!"!"!"~\""'f"(,,,,,,>;:j""'~'i'jTfi--"V "":"'''1S?,~'lf;),1rA'"~'!iiWo/iir~?:,N-''in,~&';;:p'r.'';;;*,*!;l)~~~4!ti'M~~; ii?;t'~~" SHERIFF'S RETURN - REGULAR Cl\.SE NO: 2001-07002 P COMMONWEALTH OF PENNSYLVANIA: COUNTY OF CUMBERLAND WELLS FARGO HOME MORTGAGE INC VS DETWILER DEBBIE J RICHARD SMITH , Sheriff or Deputy Sheriff of Cumberland County,Pennsylvania, who being duly sworn according to law, says, the within COMPLAINT - MORT FORE was served upon DETWILER DEBBIE J the , at 1945:00 HOURS, on the 28th day of December, 2001 DEFENDANT at 252 MCALLISTER CHURCH ROAD C~LISLE, PA 17013 DEBBIE DETWILER by handing to a true and attested copy of COMPLAINT - MORT FORE together with and at the same time directing Her attention to the contents thereof. Sheriff's Costs: Docketing Service Affidavit Surcharge So Answers: 18.00 3.25 .00 10.00 .00 31. 25 r~--t:~=u, R. Thomas Kline 01/02/2002 FEDERMAN & Sworn and Subscribed to before By, PM ! Deputy Sheriff i me this ~ day of ,........'\ (tunA.'! ;u.q.J- A.D. Qr~Q In.d.L in Prothonotafy ^""V'0%i",!l'ff'~..""." >" ,",. ,~ :-,.,- ~ -~, l~ ""',~~ "_"__'"_'"""l'.,~"--",,,,,,,,,,~,,,,,,,,",,, \ \ FEDER:.'\'IAN AND PHELAN By: FRANK FEDERMAN Identification No. 12248 Attorney for Plaintiff ONE PENN CENTER AT SUBURBAN STATION 1617 JOHN F. KENNEDY BLVD., SIDTE 1400 PHILADELPffiA, PA 19103-1814 (215) 563-7000 WELLS FARGO MORTGAGE, INC. 5024 P ARKW AY PLAZA BOULEVARD CHARLOTTE, NC 28217-2407 CUMBERLAND COUNTY COURT OF COMMON PLEAS Plaintiff, CIVIL DIVISION v. NO. 01-7002 DEBBIE J DETWILER 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 DEBBIE J DETWILER and , 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 11/1/0 I to 2/7/02 TOTAL $71,373.30 $1,525.59 $72,898.89 I hereby certify that (1) the addresses of the Plaintiff and Defendant( s) are as shown above, and (2) that notice has been given in accordance with Rule 237.1, copy attached. FRANK FEDE Attorney for Plaintiff QUIRE DAMAGES ARE HEREBY ASSESSED AS INDICATED. DATE: .{-JI-W-. (7~..Jt€'-~ PRO PROTHY (j ~ '-"""'~!""".re~~~!Il"'" - ""'" ,~,-. ~ ~, ~ .~, ~ , "~,~.~ ;i.;~'''''''l', r",,~~ ~ ~:".,L"~"'~~r"~ ~" .e .." - > ~ ~"- ~,~' ~,-" ~ '=,,,,,,,-,_,."",,...~"""".c., <~'~",<'.'<='O""""~~-r~"'~'< ~"""'''''''''''"''''''~>'Kr~~111.r-~".'J1'<-'-P:~ o r ~:";..' q}f~':, "-~",- ~;-;., ~ gt,. ~~~ -'j _--r._ # -"'1 ,-:; "".,:1 ("'-" ,< ~"',.~,"'~! ",,<, '","""".",_.'<'-'- :f'~" .LR':;;'~~<l1'iWI1-t.~'i"t?~~;~"''\T''--'';'f!~~N''''''~''=~'''''~~'<,,~,~:r,fU!4!AJ,i~1,IJ~~jl!:I!l!l~~ln,t~>>;f:f,.'~~V' FEDE~Jll~ ~~ PHELfu~, L.L.P. } Fran~ Fede~~an, 3squiye Identificacion No. 12248 One Pen~ Center P:aza at Suburban Station, Suite 1400 Philadelphia, PA 19103-1799 (215) 563-7000 AT~ORNEY FOR PLAINTIFF COURT OF COMMON PLEAS WELLS FARGO HOME MORTGAGE, INC. Plaintiff CIVIL DIVISI01\[ CUMBERLAND COUNTY vs. NO. 01-7002-CIVIL DEBBIE J. DETWILER Defendant(s) TO: DEBBIE J. DETWILER 252 MCALLISTER CHURCH ROAD CARLISLE,PA 17013 DATE OF NOTICE: JANUARY 18, 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: CUMBERLA.J.'ID COUNTY CUMBERLAND COUNTY BAR ASSOCIATION 2 LIBERTY AVENUE CARLISLE, P A 17013 (717) 249-3166 ?J) QAA /I? /"1 p j).K /7Vl'\Av" Frank Federman, Esquire Attorney for Plaintiff ct"'''l1<j;:~ ^N'? J, "~; ~, '" ..," " ,C " m ~ ,. l~!II,,_, " ""'""~- ,,',/ . . "" ~V"~~'~ ~^__~'_'" '--"~-,-"-",~-",,""~~""''-''-''''''-^",''',"'''_J''',,'<~'4'~"'M"",'~'"' "lrrrn'lf'r n'=j ;-~ ..c:"_ (I} ~~~;( , ;):; ,('= >. ! (::..~, 1"'-,;, -'1 :---" " "'., , .< .',"', {;:, ,~,,,,,,,~,,.rW;:~~~~j:'romi'f:"".f-1'-'\7>="'''''~''''''('''~'' ";';:'J':\;','r'i--',wR*~~~~~~~~~~~~1r ;~ , FEDERMAN~and PHELAN By: FRANK FEDERMAN Identification No. 12248 ONE PENN CENTER AT SUBURBAN STATION 1617 JOHN F. KENNEDY BLVD., SUITE 1400 PIDLADELPHIA, PA 19103-1814 (215) 563-7000 ATTORNEY FOR PLAINTIFF WELLS FARGO MORTGAGE, INC. 5024 P ARKW AY PLAZA BOULEVARD CUMBERLAND COUNTY COURT OF COMMON PLEAS Plaintiff, CIVIL DIVISION v. NO. 01-7002 DEBBIE J DETWILER 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 ofthe United States or its Allies, or otherwise within the provisions of the Soldiers' and Sailors' Civil Relief Act of Congress of I 940, as amended. (b) that defendant DEBBIE J DETWILER is over 18 years of age and resides at , 252 MCALLISTER CHURCH ROAD, CARLISLE, P A 17013 . This statement is made subject to the penalties of 18 Pa. C.S. Section 4904 relating to unsworn falsification to authorities. -1~~ ' FRANK. FEDE ~SQUlRE Attorney for Plaintiff ":;;"""4i"@'i\~, _~ "^, "",,..,~~ ;--~ ~ ^ ," ~ , ~. .__ia< - ~, .""'~~.,."!'"., II! A.m.\\ :!'l, 0...... "cO >~""',~~..'.>,' ' . "'T "" ,... "",I,,','~'..,' ",,'." -- """-'''''''''''11I"11T1T'')trm'''''' (") c;:; " --'::Jh~ ?:~ ~,-'" 7"1 if;> --( ~ S; " ~{1 ~=~J f',,\ ( ,.~, IrI~ ,< l~ ~rj)!Jl :"1'''''''[-'~;''''~'I\f( '_'~o,r'T~~~'''*'!,,~~'''''J'~'',!J'''''''.,,.Wt:p.~~;;<"~,-~~,1l[lliji;]1--,JijiW,fT1:!Mf!~~_ __,,-,;- ~~' . (Rule of Civil Procedure No. 236) - Revised IN THE COURT OF COMMON PLEAS OF CUMBERLAND COUNTY, PENNSYLVANIA CIVIL ACTION - LAW WELLS FARGO MORTGAGE, INC. 5024 P ARKW AY PLAZA BOULEVARD CUMBERLAND COUNTY COURT OF COMMON PLEAS Plaintiff, CIVIL DIVISION v. NO. 01-7002 DEBBIE J DETWILER Defendant(s). Notice is given that a Judgment in the above-captioned matter has been entered against you on ;z - ;u 2002. ~~ By' . . EPUTY' 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 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 CORRESPONDENCENDENCE IS NOT AND SHOULD NOT BE CONSTRUED TO BE AN ATTEMPT TO COLLECT A DEBT, BUT ONLY ENFORCEMENT OF A LIEN AGAINST PROPERTY." ""''''._'~",,'--~ JIIIS." " "", '" ,~- .. ,. .,r. ~ ~ _ ~~," ""'-'"!'m' > ~." ~. '_"J"-'= ,,~" '<'.o"~ .~ "" - -._II\i[TIlJlm' , . r Q ~ fD I ~~; '" ; - ~ V '-,--1 ~ ....... C~,J ~"i ""<' -:; C;\ 1V \J. 7-:'- "',., Cf-' D (J, -, c1 t~ r--O 'C u.., ..~- ~ t ~ ........ ~~; c-:' .....'- r-~ -- .. ::) "'. " (.;.; ~.'-' 1 r ~~ E- ;:; ~ ~ ~ \ ~ - \ ~ 'c'I!I ," '- . ,",~ _ c^_, .~; "?,o" > f"'> '_'-<,,~ ".lln~ i <l~, - ~,=.~~u., "ll~~l,m .,?,,~'ll#i!WfW'fo1:;!_S~ii"';'-!Fi!'%-9i'P""'B'~,;,*~~Q~~~ilI!_~~I~I~~~~~' if PRAECIPE FOR WRIT OF EXECUTION - (MORTGAGE FORECLOSURE) P.R.C.P.3180-3183 WELLS FARGO MORTGAGE, INC. Plaintiff, v. No. 01-7002 DEBBIE J DETWILER Defendant(s). TO THE DIRECTOR OF THE OFFICE OF THE PROTHONOTARY: Issue writ of execution in the above matter: Amount Due $72,898.89 I Interest from 2/7/02 to 6/5/02 (per diem -11.98) $1,413.64 and Costs TOTAL $74,312.53 ~ ---Lu FRANK. FEDERMAN, ESQlJi:RE One Penn Center at Suburban Station 1617 John F. Kennedy Boulevard, Suite 1400 Philadelphia, PA 19103-1814 Attorney for Plaintiff Note: Please attach description of property. No. 'C-'F!J''''tWl\'~~ ", '"'- , ,..- 11"II ~ ~~"-- ", --~ ~ ~'~-'~ .;<J_~" ~,,--, ."~~^"",,,,,,, __~,.. ".__, .~," _oJ",," -~ ""'l1irti''''f '" .... Q l'- .... ~ r-i "" 00 .... ~ < U ~ ...;:$ Z ~ OZ oo~ 0 = <.... U .... ~ ... r-lt-l Z ;;:l "".... .... U ;;:l =-00 r-i = -d Z~ ~ ~'F U Q) C r-l i;:: t: ~~ ~ "" r-l = ~ Q) .~ '" ~ '" 1:i r-l ... Q Q) ~;.< ... O<:l '<a ... ~ ~ ... Q) - 00 ~ 0... ... .. il, .... 0 <Ii r-l ;l~ .. "" s uz ~ .. t:I ,.s ~ ...j;;) ... ~~ ;>. '" ~8 0 r-l Q) U il ~ ... ~~ Ei ~ ~ = 0.... 0 p. 8~ ~ = ... E; < N ~ r-l r-l6 Vl N Usa 00 t:I =- ~ "" .... U '" r-lf;l;1 "" '" ~ Q) = ~ -i:j -tJ ...~ Q) - '"<:i .~ < Zj;;) =- ~ ....U :~'jI.'__ ,^ ,,~ ~ .,.. ,nJ'Il@T",,,,, "'""'I' ".li:U~~~ljiIit.\$fi.~~" 'W''l'''~'_~'"""",!,'''R_''''!''_L, --,,!~C '_~':, ,~W;~";'iW,:'r,--!',~,,,,,'~i';<:""c",,',,,n::';,"l''''-'-'';;''''':'??.R''~~~,!i:Iif~~,1lt~~~~~~~ DESCRIPTION ALL THOSE CERTAIN lors of ground in West Pennsboro Township, Cumberland County. . Pennsylvania. bounded and described as follows: TRACT 1: BEGINNING at a point in the center of the public road leading from the State Road by Elliorson Station to the Turnpike: thence in a Westwardly direction by property, now or formerly of John Hippensteel. a dista:Jce of one hundred seventeen (117) feet, more or less. to the center of said public road; thence along the center of said public road in a Northwardly direction, a distance of eighty- seven (87) feet to a point, the place of Beginning. CONTAINING forty (40) perches of land, more or less, and having thereon erected a twO-Story frame dwelling house and other improvements. TRACT 2: BEGINNING at a point in the Eastern side of a public road, which point is in line of property now or formerly of Robert Heberlig; thence in an Eastwardly direction along land now or formerly of the said Heberlig, a distance of sixty-nine (69) feet to a post: thence in a Southwardly direction along land, now or formerly v; :,lr3. Amy Rockey, a distance of sixty-six (66) feet to a stake; thence in a Westwardly direction along other land now or formerly of John R. Snyder and Genevieve B. Snyd(:r, a distance of sixty-nine (69) feet to a point (a stake) in the Eastern side of the aforesaid public road; thence in a Northwardly direction along the Eastern side of said public road a distance of sL'Cty-six (66) feet to a point. the place of Beginning. Being known and numbered as 252 McAllister Church Road, Carlisle, PA. Tax Map #19-1659, Parcel #015 'i0",J:'"ii, , , -,',^ '- ~-- " -, 1,- ,r ",.' "~ ~, ~~- ~e ',~'~,h .... ." .".,......'~'". ,.,. ,., ~,,~., ~.~ jl~.!J\l~~, "'. u ,'" ',h.." "~,."""~."'.,.",..'~=~'lillliIIlIiil~enlilr"mT1!l!f~r~ridill,.'!j~r,qrJlf'}1"' \E2) ;v 0 co') (' 8 c:, ;>-,) r - -' 0 -;:'1;", in [~ G0 -'/ .-, J "',...-', ...J -/? 1-' C!~ }~ \.9--> .-:.... ~ r;';::':=-: ~ ~:6: ;"-, .-. ~~z::.', "'~-C~ ~, "',;..-' ...... , .~ LN ~ - -e, ~_i R, ..''-,. ~ ~' - <J'\ :f:, - ~ ~ ~ ""\ c! F'''''''' ,\Il;U::;~1fu~~~.m:%'!l'W"J>f)'j""';;"Yi~""~"11:''''-1'''ffl'i'}';\-.'''~~I1I<ffi'''<!~'W;i"1?;;-1,"~''!7~,~;'t'''?'F","oIl;;ji!IIfWilII'i"'<f~\1I-lh' >~ WELLS FARGO MORTGAGE, INC. CUMBERLAND COUNTY Plaintiff, COURT OF COMMON PLEAS v. DEBBIE J DETWILER CIVIL DIVISION Defendant(s). NO. 01-7002 AFFIDAVIT PURSUANT TO RULE 3129 (Affidavit No. I) WELLS FARGO MORTGAGE. INC., Plaintiff in the above action, by its attorney, FRANK FEDERMAN, ESQUIRE, sets forth as of the date the Praecipe for the Writ of Execution was filed the following information concerning the real property located at .252 MCALLISTER CHURCH ROAD. CARLISLE. P A 17013 . 1. Name and address ofOwner(s) orreputed Owner(s): Name Last Known Address (if address cannot be reasonably ascertained, please indicate) DEBBIE J DETWILER 252 MCALLISTER CHURCH ROAD CARLISLE, PA 17013 2. Name and address ofDefendant(s) in the judgment: DEBBIE J DETWILER 252 MCALLISTER CHURCH ROAD CARLISLE, PA 17013 3. Name and last known address of every judgment creditor whose judgment is a record lien on the real property to be sold: Name Last Known Address (if address cannot be reasonably ascertained, please indicate) None. """'I"i'i~~ "' ' "'~ WJ~ ' ~ " . ~ iC' ~ ~~-=,,.....~~ '.~.."""- :--.~~ 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. 5. Name and address of every other person who has any record lien on the property: Name Last Known Address (if address cannot be reasonably ascertained, please indicate) None. 6. Name and address of every other person who has any record interest in the property and whose interest may be affected by the sale. Name Last Known Address (if address cannot be reasonably ascertained, please indicate) None. 7. Name and address of every other person of whom the plaintiff has knowledge who has any interest in the property which may be affected by the sale: Name Last Known Address (if address cannot be reasonably ascertained, please indicate) Tenant/Occupant 252 MCALLISTER CHURCH ROAD CARLISLE, P A 17013 Domestic Relations of Cumberland County 13 North Hanover Street Carlisle, PA 17013 Commonwealth of Pennsylvania Department of Welfare PO Box 2675 Harrisburg, P A 171 05 I verify that the statements made in this affidavit are true and correct to the best of my personal knowledge or information and belief. I understand that false statements herein are made subject to the penalties of 18 Pa. C.S. Sec. 4904 relating to unsworn falsification to authorities. Februarv 7.2002 DATE ~~/~, FRANK. FEDERMAN, ESQUIRE Attorney for Plaintiff '-'Yii'i."'m~~ "," ,,\!,~ ~ " - ~ , ~< ~ ~l - < ,~",~,~"" -- ~'" 'I"""":'~'~~' ~~,~ ,~~ '" ~'",",""v'_'''' 'M~,'" '.'"'""'i~lil.fw:tr C) C :;::"~ ~l ,",1 . J r-....) ~.,', ::::) -> "-' .~ - JrwI, ~_ "_."~-_,.,-,J!Jl1,,,, ,,_~" t"',' _""<", .,~~I",,^~.. ," ,h,,~. ." ~,lo'1~,J,~J~ml1fMJWi<~~;;'''-'I''!F'F''~W;~,1[''!"'':;;''';'''&if,,11i1M~~~!~fl\lf~~~_~~~';' FEDERMAN a.nd PHELAN By: FRANK FEDERMAN Identification No. 12248 ONE PENN CENTER AT SUBURBAN STATION 1617 JOHN F. KENNEDY BLVD., SUITE 1400 PHILADELPIDA, PA 19103-1814 (215) 563-7000 ATTORNEY FOR PLAINTIFF WELLS FARGO MORTGAGE, INC. Plaintiff, CUMBERLAND COUNTY COURT OF COMMON PLEAS v. CIVIL DIVISION DEBBIE J DETWILER NO. 01-7002 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: () 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 -LJA_, FRANK FEDERMAN, ESQUIRE Attorney for Plaintiff \ """O'''''.~'''*'1!"~~ , ~, -. '~'"O - '" . "'f j = ~, 1M ,...,...., .-=-- , ~ . ..-. .. ..'"''..0''' ,~ _'," "[ _"A 1 ,1 ;,f."., ~~_... ~~'~~"""'''T'''Ol ,,' -~".,. "I """'''''''''''''''''. ..,.,'" '''''''''-''''lIll111lliICtlTl' , _~!!, :,J -'JU,m!lfflt~~"'W:We':i"-'~:f'I"''fj:;;':,-;UU'''''}''#':#"~!W-il~-'''''''''''''';<:9!;,"...d!<!~~~~~~~;" Y"-""~">~ .,,-~ WELLS FARGO MORTGAGE, INC. Plaintiff, CUMBERLAND COUNTY v. No. 01-7002 DEBBIE J DETWILER Defendant(s). February 7,2002 TO: DEBBIE J DETWILER 252 MCALLISTER CHURCH ROAD CARLISLE, P A 17013 **THIS FIRM IS A DEBT COLLECTOR A TTEMPTING TO COLLECT A DEBT AND ANY INFORMATION OBTAINED WILL BE USED FOR THAT PURPOSE. IF YOU HAVE PREVIOUSLY RECEIVED A DISCHARGE IN BANKRUPTCY AND THIS DEBT WAS NOT REAFFIRMED, THIS IS NOT AND SHOULD NOT BE CONSTRUED TO BE AN ATTEMPT TO COLLECT A DEBT, BUT ONLY ENFORCEMENT OF A LIEN AGAINST PROPERTY. ** Your house (real estate) at. 252 MCALLISTER CHURCH ROAD, CARLISLE, PA 17013, is scheduled to be sold at the Sheriffs Sale on JUNE 5, 2002 at 10:00 a.m. in the Cumberland County Courthouse, South Hanover Street, Carlisle, PA 17013, to enforce the court judgment of 72,898.89 obtained by WELLS FARGO MORTGAGE, INC. (the mortgagee) against you. In the event the sale is continued, an announcement will be made at said sale in compliance with Pa.R.C.P., Rule 3129.3. NOTICE OF OWNER'S RIGHTS YOU MAY BE ABLE TO PREVENT THIS SHERIFF'S SALE To prevent this Sheriffs Sale, you must take immediate action: 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,~~, 'T,;'~" <., ~~ ! . ~ -. -,- -- .1Ii YOU MAY STILL BE ABLE TO SAVE YOUR PROPERTY AND YOU HAVE OTHER RIGHTS EVEN IF THE SHERIFF'S SALE DOES TAKE PLACE. 1. If the Sheriffs Sale is not stopped, your property will be sold to the highest bidder. You may find out the price bid by calling (2IS) 563-7000. 2. You may be able to petition the Court to set aside the sale if the bid price was grossly inadequate compared to the value of your property. 3. The sale will go through only if the buyer pays the Sheriff the full amount due in the sale. To find out if this has happened, you may call (717) 240-6390. 4. If the amount due from the Buyer is not paid to the Sheriff, you will remain the owner 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 of the money which was paid for your house. A schedule of distribution of the money bid for your house will be filed by the Sheriff within 30 days of the sale. This schedule will state who will be receiving that money. The money will be paid out in accordance with this schedule unless exceptions (reasons why the proposed distribution is wrong) are filed with the Sheriff within ten (10) days after the distribution is filed. 7. You may also have other rights and defenses, or ways of getting your home back, if you act immediately after the sale. YOU SHOULD TAKE THIS PAPER TO YOUR LAWYER AT ONCE. IF YOU DO NOT HAVE A LAWYER OR CANNOT AFFORD ONE, GO TO OR TELEPHONE THE OFFICE LISTED BELOW TO FIND OUT WHERE YOU CAN GET LEGAL HELP. CUMBERLAND COUNTY ATTORNEY REFERRAL CUMBERLAND COUNTY BAR ASSOCIATION 2 LIBERTY AVENUE CUMBERLAND COUNTY COURTHOUSE CARLISLE, P A 17013 (717) 249-3166 (800) 990-9108 "",~1~_~:, ",,:","," ,--T ';<' i' >,. '" ,-- ~~_.. . . DESCRIPTION ALL THOSE CERTAI~ lots of ground in West Pennsboro Township, Cumberland County. Pennsylvania. bounded and described as follows: TRACT I: BEGINNING at a point in the center of the public road leading from the State Road by ElIiorson Station to the Turnpike; thence in a Westwardly direction by property, now or formerly of John Hippensteel, a dist3...'1ce of one hundred seventeen (117) feet, more or less. to the center of said public road; thence along the center of said public road in a Northwardly direction, a distance of eighty- seven (87) feet to a poim, the place of Beginning. CONTAINING forty (40) perches of land, more or less, and having thereon erected a two-story frame dwelling house and other improvements. TRACT 2: BEGINNING at a point in the Eastern side of a public road, which point is in line of propeny now or formerly of Robert Heberlig; thence in an Eastwardly direction along land now or formerly of the said Heberlig, a distance of sixty-nine (69) feet to a post; thence in a Southwardly direction along land, now or formerly c: !,irs. Amy Rockey, a distance of sixty-six (66) feet to a stake; thence in a Westwardly direction along other land now or formerly of John R. Snyder and Genevieve B. Snyder, a distance of sixty-nine (69) feet to a point (a stake) in the Eastern side of the aforesaid public road; thence in a Northwardly direction along the Eastern side of said public road a distance of sixty-six (66) feet to a point. the place of Beginning. Being known and numbered as 252 McAllister Church Road. Carlisle, PA. Tax Map #19-1659, Parcel #015 """t''-I''','''-''''~~~ ." "' 0_ ~ .. ,';l~ " ~, ' ~ ~ i!Re,.,.,"H""," ".Ut", "','" e,"" ],'fb-~ <~> ,"c 0', ~ ,....,...--,-J\l!UI__ ~ ^' T< ~ ~""""~ ><'".Co',,>fI-" "- ",'<;,..'--,/, '''O\'~''''l'll'''''' '~'-:ci, 'ni\M'"1.'''W0'f'Ir''1,ITC'~j'Klr1fG~,''i''' "--"'l'i'~<1" ~~) i: " L_."' ::;';-':'",' <J~ l::l .,' ' ,_' ",' ,~,",Ji!~~If~;::'~~,?'IS~,'!"lF~1:i""!''-"ff'1'i'\i;;)j!i'i-''f!'''''!;;C-liii~~~ l' CJ c: "~<I p,,, ~~"~~'FlQ~lfli~". ,~;;,,' ~:~~~ ,"?o,.,~,",~,," 7Ptr AFFIDAVIT OF SERVICE CUMBERLAND COUNTY PLAINTIFF WELLS FARGO MORTGAGE, INC. No. 01-7002 DEFENDANT(S) SERVE DEBBIE J DETWILER AT 252 MCALLISTER CHURCH ROAD CARLISLE, P A 17013 DEBBIE J DETWILER ACCT. #4133317 Type of Action - Notice of Sheriff's Sale Sale Date: JUNE 5, 2002 Served and made known to ~.tbi e3 at~ll, o'clockQ.m., at SERVED I'Y \-\..0', \e(Defendant, on the ~ day of kh UNli 200q C . , Commonwealth of Pennsylvania, in the manner described below: ~ Defendant personally served. Adult family member with whom Defendant(s) residers). Relationship is Adult in charge of Defendant(s)'s residence who refused to give name or relationship. Manager/Clerk of place oflodging in which Defendant(s) residers). Agent or person in charge of Defendant(s)'s office or usual place of business. an officer of said Defendant(s)'s company. . '_ d~--Rod~ Description: HeightQ9" Weight V-ld-. Race ~ Sex.-r: Other !, ~ competent adult, being duly sworn according to law, depose and state that! personally handed a true and correct copy of the Notice of Sheriffs Sale in the manner as set forth herein, issued in the captioned case on the date and at the address indicated above. Other: Sworn to and subscribed be~~~e this~ day of . , 200;/-. ?: By: SERYlC;E AT LEAST 3 TIMES. INDICATE DATES & TIMES OF SERVICE ATTEMPED. N arial .al Us,~ M. Greason N"A'.q,'v Pllh~i~ ; C~~t;:;:;~~,.;;~fg:'i ~~~~~i~~~"[~~~ '?:,E'~:y ,. On the .--.... d.yor NOT SERVED ,200_, at o'clock _.m., Defendant NOT FOUND because: Moved Unknown No Answer Vacant Other: Sworn to and subscribed before me this _ day of , 200 _' Notary, By, Attornev for Plaintiff Frank }'ederman, Esquire - I.D. No. 12248 One Penn Center at Suburban Station 1617 Jobn F. Kennedy Boulevard, Snite 1400 Pbiladellphia, PA 19103-1814 (215) 56,3-7000 (cohr~~hl'$f,,,:' ~,~1i1f, "'_,~. . , - '~ " " ,~~ ,~ ~, .h "..,..~ '11\11I., " ,'~'~ ~',f';";"',",=--- ,,"'_" r, '",' _ .1 _'~!:::"~ . ,".'," ~ij;l "H '~'~"d~"'.' , ~~"'^ ~"' ",. . o C '2".-" --a Co tTlr-;-:, ;-~, ::r,' Z:C U)~e--:- -</;, ~C.) ~~~i "PC:: 7..:': ::2 C) i') - ~,;!" S; p:s e;-/ j IIlTll1i: r! 'i( --;:1. '""'10,- r:-;.) .~'-.-, (.)1 r"~",,~,.-I]!f1,1.~_m~~~~f"!~"':S'ffiiF,~t.,7,'iI'''f,'''',9fi-'!''~''?&i~~~~~~~j~~~": 1 FEDERMAN AND PHELAN By: FRAJ{KFEDERMAN,ESQlmRE IDENTIFICATION NO. 12248 ONE PENN CENTER AT SUBURBAN STATION PHILADELPHIA, PA 19103 (215) 563-7000 ATTORNEYFORPL~F COURT OF COMMON PLEAS CIVIL DMSION WELLS FARGO MORTGAGE, INC. 5024 P ARKW A Y PLAZA BOULEVARD CHARLOTTE, NC 28217-2407 v. NO. 01-7002 DEBBIE J DETWILER CUMBERLAND COUNTY PRAECIPE TO MARK JUDGMENT SATISFIED TO THE PROTHONOTARY: Kindly markjudgrnent in the above captioned matter "Satisfied" upon payment of your costs only. ~?-~ FRAJ{K FEDERMAN, ESQlmRE ~ March 7, 2002 :-;'~"i'\'f.\~~"" ,?, ~~ "-.,.,.'"~ ,,,,,,""""""- ~", = "~ ", " ~'"' .-'''''~'''''1 ',-< ~^,",' ~~~'" ".1 ""&" ',""";;'0'_" . ''''C~:'' ","~" " <"",' ~~. '".;~"--,~""",,,,,,,,,,,,,, "'~"!tr"~'TiJ":1~-"')C'"~', "':.".<o,,~~; (') fi "DOC QJ.t"t. t9'5~1;:' ~~C' ~~ -3 -, C) P,j C) -q ,--, -;" :T'; , i':-:,~ . ~Ti :,r; " :jii:i fZ) c)") ']'~ 5J ~~ cs CI/ '!",,,:,, , ,:",_-,:" ~ ""-',":,'?,f'!"', ->~r' ~. ~'~!Of,~, ~"^~"~ .~"'", ~ ~!I!m,~,,~~=O~0;;E2:'}f~~~'f~__~'!!lm~~fi~~~~~'~.!1$~~.t;,,{-, ,),~,!~,,~~ji,' """"'" '7''''"'~'~ ".- "'.- Wells Fargo Mortgage, Inc. VS Debbie J. Detwiler In The Court of Common Pleas of Cumberland County, Pennsylvania Writ No. 2001-7002 Civil Term R. Thomas Kline, Sheriff, who being duly sworn according to law, states this writ is returned STAYED pursuant to instructions from Attorney Frank Federman. Sheriff s Costs: Docketing Surcharge Posting Handbills Law Library Prothonotary Share of Bills Mileage Levy Advertising Certified Mail Poundage Law Journal Patriot News 30.00 30.00 .50 1.00 1.23 $ 62.73 paid by attorney 3-13-02 Sworn and subscribed to before me This 11~d~of~J 2002, A.D.c]"f' ()~~~ Prothonotary ';-""'1 '~'1""w.iI~ff~~_"" ~ _ ~ , ",~ -. So Answers: r~ ~<: ~ R. Thomas Kline, shZiff 'C.f' BAA~~ Real Estate Deputy I.st> '*- 3SQ/:2.J ~ /..);l y:; I M ,,~ ~ ,,~~" ,-"'~'" ~~,.~"~'~~ ,,'f'!l ~< .11 WELLS FARGO MORTGAGE, INC. CUMBERLAND COUNTY Plaintiff, v. COURT OF COMMON PLEAS DEBBIE J DETWILER CIVIL DIVISION Defendant(s). NO. 01-7002 AFFIDAVIT PURSUANT TO RULE 3129 (Affidavit No. I) WELLS FARGO MORTGAGE, INC., Plaintiff in the above action, by its attorney, FRANK FEDERMAN, ESQUIRE, sets forth as of the date the Praecipe for the Writ of Execution was filed the following information concerning the real property located at ,252 MCALLISTER CHURCH ROAD, CARLISLE, PA 17013. 1. Name and address of Owner(s) or reputed Owner(s): Name Last Known Address (if address cannot be reasonably ascertained, please indicate) DEBBIE J DETWILER 252 MCALLISTER CHURCH ROAD CARLISLE, P A 17013 2. Name and address of Defendant(s) in the judgment: DEBBIE J DETWILER 252 MCALLISTER CHURCH ROAD CARLISLE, P A 17013 3. Name and last known address of every judgment creditor whose judgment is a record lien on the real property to be sold: Name Last Known Address (if address cannot be reasonably ascertained, please indicate) None. ;'ii~;o1il~ '~_~"1 _1{'_ ",,~ ,"~ '1--'-" '1'" . . , ,~ ., -~~ ~~, "' ;,,"'~'<~ ~'."-"",-.+ "'. ' ,. . ~ 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. 5. Name and address of every other person who has any record lien on the property: Name Last Known Address (if address cannot be reasonably ascertained, please indicate) None. 6. Name and address of every other person who has any record interest in the property and whose interest may be affected by the sale. Name Last Known Address (if address cannot be reasonably ascertained, please indicate) None. 7. Name and address of every other person of whom the plaintiff has knowledge who has any interest in the property which may be affected by the sale: Name Last Known Address (if address cannot be reasonably ascertained, please indicate) Tenant/Occupant 252 MCALLISTER CHURCH ROAD CARLISLE, PA 17013 Domestic Relations of Cumberland County 13 North Hanover Street Carlisle, P A 17013 Commonwealth of Pennsylvania Department of Welfare PO Box 2675 Harrisburg, 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. February 7.2002 DATE l----A 4. FRANK FEDERMAN, ESQUIRE Attorney for Plaintiff :,,,,';'-.-\-''f9~'~f"' ," <~,,_ . ,-< ~'--'- f' ' " ~, ~"'..' ., , ~~ ,T""<>' ...~' .,' ~- . WELLS FARGO MORTGAGE, INC. Plaintiff, CUMBERLAND COUNTY v. No. 01-7002 DEBBIE J DETWILER Defendant(s). February 7, 2002 TO: DEBBIE J DETWILER 252 MCALLISTER CHURCH ROAD CARLISLE, PA 17013 **THIS FIRM IS A DEBT COLLECTOR A TTEMPTING TO COLLECT A DEBT AND ANY INFORMATION OBTAINED WILL BE USED FOR THAT PURPOSE. IF YOU HAVE PREVIOUSLY RECEIVED A D1SCHARGEIN BANKRUPTCY AND THIS DEBT WAS NOT REAFFIRMED, THIS IS NOT AND SHOULD NOT BE CONSTRUED TO BE AN A TTEMPT TO COLLECT A DEBT. BUT ONL Y ENFORCEMENT OF A LIEN AGAINST PROPERTY. ** Your house (real estate) at, 252 MCALLISTER CHURCH ROAD. CARLISLE, PA 17013, is scheduled to be sold at the Sheriffs Sale on JUNE 5, 2002 at 10:00 a.m. in the Cumberland County Courthouse, South Hanover Street, Carlisle, P A 17013, to enforce the court judgment of 72,898.89 obtained by WELLS FARGO MORTGAGE. INC. (the mortgagee) against you. In the event the sale is continued, an announcement will be m~de 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.) --'~'--;-"".-iY.'>F,,'i'-"'_!ll!I! ""':" I"~' or 1"_~~_~ ,~ "~ ~ ' 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 ifthe buyer pays the Sheriff the full amount due in the sale. To find out if this has happened, you may call (717) 240-6390. 4. rfthe 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 LmERTY AVENUE CUMBERLAND COUNTY COURTHOUSE CARLISLE, P A 17013 (717) 249-3166 (800) 990-9108 ,f!g~!~f'" '," _ ~~, ':' , ^-~ . ."'"'^, ... ",,= , ,~-,,,"- ~~.. DESCRIPTION ALL THOSE CERTAI:-.i lots of ground in West Pennsboro Township, Cumberland COGnty. Pennsylvania. bounded and described as follows: TRACT 1.: BEGINNING at a point in the center of the public road leading from the State Road by Elliot5on Station to the Turnpike: thence in a Westwardly direction by property, now or formerly of John Hippensteel, a distance of one hundred seventeen (117) feet, more or less. to the center of said public road; thence along the center of said public road in a Northwardly direction, a distance of eighty- seven (87) feet to a point, the place of Beginning. CONTAINING forty (40) perches of land, more or less, and having thereon erected a two-story frame dwelling house and other improvements. TR..'\CT 2: BEGINNING at a point in the Eastern side of a public road, which point is in line of property now or formerly of Robert Heberlig; thence in an Eastwardly direction along land now or formerly of the said Heberlig, a distance of sixty-nine (69) feet to a post thence in a Southwardly direction along land, now or formerly;:;; l,lrs. Amy Rockey, a distance of sixty-sL'C (66) feet to a stake; thence in a Westwardly direction along other land now or formerly of John R. Snyder and Genevieve B. Snyder, a distance of sixty-nine (69) feet to a point (a stake) in the Eastern side of the aforesaid public road; thence in a Northwardly direction along the Eastern side of said public road a distance of sixty-six (66) feet to a point. the place of Beginning. Being known and numbered as 252 McAllister Church Road. Carlisle, PA Tax Map #19-1659, Parcel #015 "''''<t!<:'''?'iil']>l,~~""~,,,,,,,,,,~ ", .". , ,I', ,"~ ~1'" Ole"<" -"'l~~ ~ ,~- $'""' ~.="' WRIT OF EXECUTION and/or ATTACHMENT COMMONWEALTH OF PENNSYLVANIA) . COUNTY OF CUMBERLAND) NO 01-7002 Civil CML ACTION - LAW TO THE SHERIFF OF Cumberland COUNTY: To satisfy the debt, interest and costs due WELLS FARGO MORTGAGE, INC. PLANTIFF(S) From DEBBIE J. DETWILER, 252 MCALLISTER CHURCH ROAD, CARLISLE P A 17013. (1) You are directed to levy upon the property of the defendant( s) and to sell REAL ESTATE LOCATED AT 252 MCALLISTER CHURCH ROAD, CARLISLE PA 17013. (SEE ATTACHED 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/are 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 lrimIher that he/she has been added as a garnishee and is enjoined as above stated. Amount Due $72,898.89 L.L. $.50 Interest 217102 - 6/5/02 @$11.98/DIEM $1,413.64 Due Prothy $1.00 Atty's Comm % Other Costs Atty Paid $103.25 Plaintiff Paid Date, FEBRUARY 21, 2002 CURTIS R. LONG Prothonotary, Civil Division B,~J)r~ REQUESTING PARTY: Name FRANK FEDERMAN, ESQ. Address, ONE PENN CENTER@SUBURBAN STATION 1617 JFKBLVD, STE 1400 PHILADELPHIA PA 19103-1814 Attorney for: PLAINTIFF Telephone: (215) 563-7000 Supreme Court ID No. 12248 '.')>' "-"'":"'''''''"~,\!1!;;~_~~ _. """"~~, _, n [, r' ~ w.r ,,~ " ''''''~'''"'''~ ..'< " ." ~-- .,.",'0',",'_ '~O-,,'I" ,,,,~,," .",-,.-.-,,",,~,,,;,,,.,~,,,,",,,.~,. ~"'=~'''''"'<''',iIl(''~'~]TIIJr<'''~'r',~(lr~l . REAL ESTATE SALE No. 31 On March 11, 2002 the sherifflevied upon the defendant's interest in the real property situated in West Pennsboro Township, Cumberland County, P A, known and numbered as 252 McAllister Church Road, Carlisle and more fully described on Exhibit "A" filed with this writ and by this reference incorporated herein. ~ Date: March 11,2002 By: '01 CJ~ .JVVliih Real Estate Deputy tit U l,tA '7 I ;"f'J]d . 111, Iii; 90 G SZl13J ,,1.,/.1'\';. ;jJllI:l-ii$ .\, "ilno ~ .J, ,;i .?~}f.;3.-~O ,~:m,w.!J'Ilj;, p ,~_,W !,,,.~rJ!1'~] ~'_L'r.~Ji\lW1!i~!ij)'~~l)\lt'i-P"~~'<f,"#''1tnp,'{-ffi}'<'!F~~-l\l'''N~\;''~b'''n,;;-;'~;'t,"-F"'4~i'!i1i"'~~'J."~'fr'.,,;j"!W'" ~ ~ t;:::::; ~ lrlr11