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Home My WebLink About01-07070 ,~u'"~'.~r__rrF' . ."-~i~~~fttn":'o" . " e " MARTHA E, VON ROSENSTIEL, ESQUIRE MARTHA E, VON ROSENSTIEL, P,C, 16 SOUTH LANSDOWNE AVENUE PO BOX 457 LANSDOWNE, PA 19050 Attorney ID # 52634 GMAC Mortgage Corporation 500 Enterprise Road Horsham, PA 19044-0963 Plaintiff vs. Joan Appleton-Costanza 53 Honeysuckle Drive Mechanicsburg, PA 17055 Defendant(s) . #7531 Attorney for Plaintiff COURT OF COMMON PLEAS Cumberland COUNTY Case No: Ct - 7076 c;u ~ l ~n.-., CIVIL ACTION - MORTGAGE FORECLOSURE THIS IS AN ATTEMPT TO COLLECT A DEBT ANY INFORMATION OBTAINED WILL BE USED FOR THAT PURPOSE NOTICE ADVISO 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 by the court without further notice for any money claimed in the complaint or for any other claim or relief requested by the plaintiff, You may lose money or property or other rights important to you. YOU SHOULD TAKE TIDS PAPER TO YOUR LAWYER AT ONCE. IF YOU DO NOT HAVE A LAWYER OR CANNOT AFFORD ONE. GO TO OR TELEPHONE THE OFFICE SET FORTH BELOW TO FIND OUT WHERE YOU CAN GET LEGAL HELP, Le han demandado a usted en la corte. Si usted quiere defenderse de estas demandas expuestas en las paginas siguientes, usted tiene veinte (20) dias de plazo al partir de la fecha de la demanda y la notificacion. Hace falta a sentar una comparencia escrita 0 en persona 0 con un abogado y entregar a la corte en forma escrita sus defensas 0 sus objeciones alas demandas en contra de su persona. Sea a visado que si usted no se defiende, la corte toma ra medidas y puede continuar la demanda en contra suya sin previo aviso 0 notificacion. Ademas, la corte puede decidir a favor del demandante y requiere que usted cwnpla con todas las provisiones de esta demanda. Usted puede perder dinero 0 sus propiedades 0 ottos de rechos importantes para usted. LLEVE ESTA DEMANDA A UN ABOGADO INMEDIATAMENTE. SI NO TIENE ABOGADO 0 SI NO TIENE EL DINERO SUFICIENTE DE PAGAR TAL SERVICIO. VAYAEN PERSONA 0 LLAME POR TELEFONO A LA OFICINA CUYA DIRECCION SE ENCUENTRA ESCRITA ABAJO PARA A VERIGUAR DONnE SE PUEDE CONSEGIDR ASISTENCIA LEGAL. CUMBERLAND COUNTY BAR ASSOCIATION 2 LIBERTY AVENUE CARLISLE, P A 17013 717-249-3166 800-990-9108 ""i'1-r.,.~~ _..,~, "" ~~ o. .^_ ~'o ,. "1,_ ,-, 1 ,. '~"~-'- ~ .~~ .,_m -,"'" '~~"~"'I"'~ ;.,,.,..,w:'.'..r " " MARTHA E. VON ROSENSTIEL, ESQUIRE MARTHA E. VON ROSENSTIEL, P,C. 16 SOUTH LANSDOWNE AVENUE PO BOX 457 LANSDOWNE, PA 19050 Attorney ID# 52634 Attorney for Plaintiff GMAC Mortgage Corporation 500 Enterprise Road Horsham, PA 19044-0963 plaintiff COURT OF COMMON PLEAS Cumberland COUNTY vs. Case No: Ol- '1610 Ct~~L y~ Joan Appleton-Costanza 53 Honeysuckle Drive Mechanicsburg, PA 17055 Defendant(s) CIVIL ACTION - MORTGAGE FORECLOSURE THIS IS AN ATTEMPT TO COLLECT A DEBT ANY INFORMATION OBTAINED WILL BE USED FOR THAT PURPOSE 1. Plaintiff is GMAC Mortgage Corporation, a corporation organized and existing under state law, with offices for the conduct of business at 500 Enterprise Road, Horsham, PA 19044- 0963. 2. Defendant, Joan Appleton-Costanza is the mortgagor and real owner of premises 53 Honeysuckle Drive, Mechanicsburg, PA 17055, hereinafter described, whose last known address is listed in the caption. 3. Plaintiff brings this action in mortgage foreclosure against defendant, mortgagor and real owner, to foreclose a certain indenture of mortgage made, executed and delivered by the above named defendants, mortgagors and real owners to PHH US Mortgage Corporation on August 21, 1995, which mortgage is recorded in the Office of the Recorder of Deeds of Cumberland '.'i"""l'%fl':' .~~.. .. """".,, I ~ --I"''''''''''" ," ~= ~ ,~ .:..".,.. I' --~ ~~J>tj6~"'*";"^'~i:'''''K ' "-'-'::,"W" ,,-< :'ri''''- ,.',",. . " County in Mortgage Book 1278, page 673, secured on premises 53 Honeysuckle Drive, Mechanicsburg, PA 17055 a true and correct description of which is attached hereto as Exhibit I. 4. The mortgage has since been assigned to the plaintiff herein. 5. Plaintiff alleges each and every term, condition and covenant in the aforesaid mortgage, and hereby incorporates them herein by reference thereto. 6. The aforesaid mortgage is in default in that monthly installments of principal and interest have not been made conformity with the terms of the mortgage, from June 1, 2000 and each month thereafter, up to and including the present time. 7. Under the terms of the aforesaid mortgage, upon default of payments set forth in the mortgage documents, the entire principal balance and all interest due thereon are collectible forthwith. 8. The following is an itemized statement of the amount due plaintiff under the terms of the aforesaid mortgage: Principal Balance Interest from 05/01/00 to 12/14/01 At $26.24 per diem Accrued late charges to 09/18/00 Late charges from 09/30/00 to 11/30/01 At $46.74 per month Accrued Escrow deficit to 09/18/00 Monthly escrow deposits from 10/01/00 To 12/01/01 at $255.38 per month Monthly Inspections from 06/01/00 To 12/01/01 at $15.00 per month Attorney's Fee Title Information Certificate Photostats and Postage ''''';:''11_ " - ","'" I'"' -,," I"" '"~ , , $125,586.32 $ 15,560.32 $ 186.84 $ 701.10 $ 212.76 $ 3,319.94 $ 270.00 $ 6,200.00 $ 350.00 $ 45.00 - .. ""i~"'~ ';,-.>;:"-\\,"~" ':.~( t'ftfW'"'~'~"~ , "" . . Notarizations $ 10.00 TOTAL $157,742.28 9. Plaintiff sent to defendant, mortgagor and real owner a combined Notice and Warning of Intention to Foreclose and Notices of Homeowners' Emergency Mortgage Assistance Act of 1983 advising of rights available under the statutes. To date payments have not been received and Act 91 assistance has not been granted although the applicable time periods provided by statute have expired. WHEREFORE, plaintiff demands judgment for $157,742.28, plus per diem interest at $26.24 from 12/15/01 to the date of judgment plus monthly late charges of $46.74 from 12/30/01 to the date of judgment plus monthly escrow deposits of $255.38 from 01/01/02 to the date of judgment plus monthly inspection costs of $15.00 from 01/01/02 to the date of judgment and foreclosure and sale of the mortgaged premises plus costs the:reon, Martha E. Von Rosenstiel Attorney for Plaintiff "~,""l-'U\1". --, '.,"'-< _."r . ,~. I' ,-- ," ~~, - ,- "~, ~. < ~ T'I~~' '""""'ftiT"i".O~' M,"'_ ... "'*ft.."?J!~,~' """T",~ ~ "'" '" -'~.J1f11 VERIFICATION I verifY that the statements made in the foregoing Complaint in Mortgage Foreclosure are true and correct. I understand that false statements herein are made subject to penalties of 18 Pa .C.s. Section 4904 relating to unsworn falsification to authorities. By: ~Ola~ Title: Default Snecialist Dated: ~ ,~ ~r ~ ~~.~~ "''1' ',"-~' -.'r .~"'".. - " "--.."~ ,.,".. DESCRIPTION ALL THAT CERTAIN piece or parcel of land situate in Silver Spring Township, Cumberland County, (erroneously referred to in prior deed as Dauphin County) Pennsylvania, as set forth on a final Subdivision Plan for Mulberry Crossing, Section Three, Wynnewood West Development Company, as prepared by Ganett Fleming Civil Engineers, Inc., and recorded in the Recorder of Deeds Office of Cumberland County, Pennsylvania, in Plan Book 49, Page III, and more particularly bounded and described as follows, to wit: BEGINNING at a point on the right-of-way line of Honeysuckle Drive at the dividing line between Lots Nos. 167 and 168 as shown on the aforementioned Subdivision Plan; thence along said right- of-way line of Honeysuckle Drive by a curve to the left having a radius of 175,00 feet, an arc distance of 59.50 feet with a chord bearing North 52 degrees 18 minutes 24 seconds East, a distance of 159.11 feet to a point at the dividing line between Lots Nos, 168 and 169; thence along same South 47 degrees 39 minutes 2 seconds East 151.40 feet to a point; thence South 25 degrees 16 minutes 2 seconds West a distance of 63.36 feet to a point at the dividing line between Lots Nos. 168 and 154; thence along same South 79 degrees 20 minutes 46 seconds West, a distance of 60.77 feet to a point at the dividing line between Lots Nos. 168, 154 and 167; thence along the dividing line between Lots Nos. 168 and 167 North 28 degrees 10 minutes 12 seconds West, a distance of 152.17 feet to a point, the place of beginning. BEING Lot No. 168 on the aforeII),ep.tionedfinal,'Subdivision Plan for Mulberry Crossing, Section Three, W ynnewood W est De~elopment Company. CONTAINING 14,159 square feet, more or,[ess:. . UNDER AND SUBJECT to se!back lines, easements and conditions as shown on the aforementioned Final Subdivision Plan and restrictioJ1s and conditions as set forth in the Declaration of Wynnewood West Development Company that is recorded in Cumberland County Miscellaneous Book 308, Page 260. Tax Parcel # 38-22-0144-118 "''''%\1<'11 _ _,' ~,',' ,~,,,,,,",",",,< """,, ~.> - " "" , '<0. ... ~ ,"~"- ~~ " = ~ i~ .a~.~" '--" ~ ~ -0 ~ "-.t: ~, ">,-"",""""" ,~~ """'"",W""'1!T' Tili~Ji['>'fIrr:ITC Tlil'rfflli"TTTi' ~ ~ .tQ. .f,) ~ ~ d 0 ~ , D cy f fl/J J~ f~ - "- D ~ ~[ _ ~'^'", <~,""'_,'''':'~ ~~,n~..~ __,A. ^,""", ,-~Tl!flJ;.7Wi~~~~~!iW!~'~~l*~~~~;lf!lIl!.~~li'~~!~",,"'1":"'" L~.; ~"j -, .', 1j ~.,..,. -, _..J .~C~ c_'; -:-) :~"', i I J r.-~ C5 ~ .." ::JJ .< ~'WnT( T C -.. ' , ~, W UNITED STATES BANKRUPTCY COURTFOR THE MIDDLE DISTRICT OF PENNSYL VANIA dB INRE: Frank J. Costanza Joan Appleton Costanza Bk. No. 01-01564 RJW Debtors Chapter No, 13 GMAC Mortgage Corporation Movant Harrisburg, PA FILED TIME~fM-PM. 11 D.S.C. ~ 62 NOV \ 5 200\ v. Frank J. Costanza Joan Appleton Costanza and Cia per Charles J. Dehart, III, Esquire (Trustee) Respondents -iN ORDER _. I.... AND NOW, this 10 day of ~ c::JN\UCf" ,2001, upon consideration of the Motion for Relief and Motion for Default of Movant, GMAC Mortgage Corporation, it is hereby ORDERED that the Order for Relief be entered by default with respect to premises at 53 Honeysuckle Drive, Silver Springs, P A 17055, to allow the Movant to foreclose on its mortgage, which mortgage was recorded in Cumberland County, in Mortgage Book 1278, Page 673, and allow the purchase of said premises at Sheriffs sale (or purchaser's assignee) to take any legal action for enforcement of its right to possession of said premises. B(f)~ ~ )~~ Robert J. Woodside, Bankruptcy Judge cc: Judith T. Romano, Esquire One Penn Center at Suburban Station 1617 JohnF. Kennedy Blvd., Suite 1400 Philadelphia, PA 19103-1814 Frank J. Costanza Joan Appleton Costanza 53 Honeysuckle Drive Mechanicsburg, P A 17050 James M. Bach, Esquire 352 South Sporting Hill Road Mechanicsburg, P A 17050 Charles J. Dehart, III, Esquire (Trustee) P,O. Box 410 Hummelstown, P A 17036 o?l-.:n ,y~. -'--=. "". " '-1' - ~ , - , . - LO~, .- -.... SHERIFF'S RETURN - REGULAR CASE NO: 2001-07070 P COMMONWEALTH OF PENNSYLVANIA: COUNTY OF CUMBERLAND GMAC MORTGAGE CORPORATION VS COSTANZA JOAN APPLETON JASON VIORAL , Sheriff or Deputy Sheriff of Cumberland County, Pennsylvania, who being duly sworn according to law, says, the within COMPLAINT - MORT FORE was served upon COSTANZA JOAN APPLETON the ,-- ".... ..... ..... DEFENDANT , at 2049:00 HOURS, on the 20th day of December, 2001 ."- at 102 FRANKLIN SQUARE MECHANICSBURG, PA 17055 by handing to - ~, JOAN APPLETON COSTANZA a true and attested copy of COMPLAINT - MORT FORE together with NOTICE and at the same time directing Her attention to the contents thereof. Sheriff's Costs: Docketing Service Affidavit Surcharge So Answers:~~~, ~ ~~ r~:rn;'"'-t:f~ -- .... -- 18.00 5.85 .00 10.00 .00 33.85 ",- R. Thomas Kline ~ .. 12/26/2001 MARTHA VON ROSENSTIEL Sworn and Subscribed to before By: '6 /~ t%0~ )'5fiuty Sheriff 1/ me this ?~ day of QUA u ~'T dJ-b1JJ..- A. D. ('t 'A-' O^~,"","" % '-1irrothonotary 1 ..m:)lf,I":V'1'3!f" ., ',~, , .. . ,. "" ~ ,~ . ~..,1!!l'l'\ ",_" ~'_'''C'_' ",_ #7531-SF Martha E. Von Rosenstiel, P .C. Martha E. Von Rosenstiel 16 South Lansdowne Avenue P.O. Box 457 Lansdowne, P A 19050 610 623-2660 Attorney 1.D,# 52634 Attorney for Plaintiff GMAC Mortgage Corporation 500 Enterprise Road Horsham P A 19044-0963 COURT OF COMMON PLEAS CUMBERLAND COUNTY Plaintiff vs. Joan Appleton-Costanza 53 Honeysuckle Drive Mechanicsburg, P A 17055 Defendants No: 01-7070-Civil Term PRAECIPE TO THE PROTHONOTARY: Enter judgment in the sum of $160,976.52 in favor ofthe above named plaintiff and against the above named defendants for failure to file an answer in the above action in Mortgage Foreclosure within twenty (20) days from date of service of the Civil Action, and assess damages. I hereby certify that the correct addresses of plaintiff and defendants are as follows: Plaintiff: 500 Enterprise Road Horsham, PA 19044-0963 Defendants: 53 Honeysuckle Drive Mechanicsburg, P A 17055 ( Martha E. Von Rosenstiel Attorney for Plaintiff .",,'!.-<j\-"!1.'''''~,r' __ ., ~~.O .. , .~ ,~,~. ~ -,- ~ -~"""""- 00" Martha E. Von Rosenstiel, P.C. Martha E. Von Rosenstiel 16 South Lansdowne Avenue P.O. Box 457 Lansdowne, P A 19050 610 623-2660 Attorney I.D.# 52634 Attorney for Plaintiff GMAC Mortgage Corporation 500 Enterprise Road Horsham, P A 19044-0963 COURT OF COMMON PLEAS CUMBERLAND COUNTY Plaintiff vs. Joan Appleton-Costanza 53 Honeysuckle Drive Mechanicsburg, P A 17055 Defendants No: 01-7070-Civil Term ASSESSMENT OF DAMAGES TO THE PROTHONOTARY: Kindly assess damages against the above named defendants as per Civil Action in Mortgage Foreclosure, as follows: Total per complaint Additional interest on unpaid balances from 12/15/01 to 03/12/02 at $26.24 per diem Additional late charges from 12/30101 to 02/28102 at $46.74 per month Additional escrow deposit 01/01/02 to 03/01/02 at $255.38 per month Additional monthly inspections from 01/01/02 to 03/01/02 at $15.00 per month $157,742.28 $ 2,282.88 $ 140,22 $ 766.14 $ 45.00 Total assessment Martha E. Von Rosenstiel Attorney for Plaintiff AND NOW, to wit, this /~ay of ~ 2002, damages are assessed as above. C.<n-+-3 ) l~ Pro Prothy ;' ,.:'C'~Y~~~.!fIl: . ".~,,,",,"'" ~ " . r "'.'~-'"""""'r,~~"" , - .. ~~~,-..,. ~" ~ "''I'''''~ r;m Jf ~_2/!.4/200!. 11:15 MA~T~A VON ~OSENST!EL LAW OFFICE 7 12156821940 NO. 569 1]02 #7531 MarUla E. Yon Rosenstiel, P,C. Martha E. Von Rosenstiel 16 South Lansdowne Avenue P.O, BOK 457 Lansdowne, P A 19050 610623.2660 Attorney !.D,# 52634 Attorney for Plaintiff GMAC Mortgage Corporation Plaintiff COURT OF COMMON PLEAS Cumberland COUNTY vs. No: 0/- 7670 - C /VIi-- Ti-/i!.N Joan Appleton-Costanza Defendant(s) AFFIDAVIT OF NON-MIJ~ITARY SERVICE COUNTY OF Pk M~o~c{ ~L ~ <<S , (representative of the setvicer for the Plaintiff, being duly sworn aCcording t law deposes and says 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; S8 STATE OF That Joan Appleton-Costanza is over 21 years of age and resides at 53 Honeysuckle Drive, Mechanicsburg, PA 17055. This verification is made subject to the penalties of a8 Pa.C.S. ~4904 relating to unsworn falsification to authorities. .J)jJ Foreclosure Speci list "~f1;1""""'*,1 ~" '_':::-1" , 1'''- .' -- " ~ Martha E, Von Rosenstiel, P.C. Martha E. Von Rosenstiel 16 South Lansdowne Avenue P.O. Box 457 Lansdowne, PA 19050 610623-2660 Attorney 1.D.# 52634 Attorney for Plaintiff GMAC Mortgage Corporation 500 Enterprise Road Horsham P A 19044-0963 COURT OF COMMON PLEAS CUMBERLAND COUNTY Plaintiff vs. Joan Appleton-Costanza 53 Honeysuckle Drive 11echanicsburg,pj\ 17055 No: 01-7070-Civil Term Defendants CERTIFICATION OF SERVICE MARTHA E. YON ROSENSTIEL, ESQUIRE, hereby certifies that she is the attorney for the plaintiff herein, and that service of the Notice under Rule 237.5 in the above matter was made on the defendants on January 18, 2002, as evidenced by the attached postal receipts. This verification is made subject to the penalties of 18 Pa. C.S. Section 4904 relating to unsworn falsification to authorities. Martha E. Von Rosenstiel, Esquire Attorney for Plaintiff DATED: March 11, 2002 'V'^,"-'>mw .~ , ~ ^ --,..,- ~~ _~",,""~,.r__,~ ~'>""'1"-~r'OI1'~_ #7531 SF Martha E. Von Rosenstiel, P.C. MarthaE. Von Rosenstiel 16 South Lansdowne Avenue P.O. Box 457 Lansdowne, PA 19050 610 623-2660 Attorney I.D.# 52634 Attorney for Plaintiff GMAC Mortgage Corporation COURT OF COMMON PLEAS Cumberland COUNTY Plaintiff vs. Case No: () /- 7/J 7()- ('/1M. U/l1'J Joan Appleton-Costanza Defendant , TO: Joan Appleton-Costanza 53 Honeysuckle Drive Mechanicsburg, PA 17055 Date of Notice: January 18, 2002 IMPORTANT NOTICE YOU ARE IN DEFAULT BECAUSE YOU HAVE FAILED TO 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 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'!'!'l wnm I"lr"" 1=""~~ .M.. --;r GET LEGAL HELP: u.s. POSTAL SERVICE CERTIFICATE OF MAl ING MAY BE USED FOR DOMESTIC AND INTERNA TfONAl. MAIL, DOES NOT PROVIDE FOR INSURANCE POSTMASTER p~ I=t"\rm ::tR17, Mar, 1989 """,,:w.,,!,'!I;ltn ~', ~'. "",_ ,'".~,_~' ,""" ;~,~"," J". ,.,!IIIll' Affix fee here in stamps or meter postage and post mark. Inquire of CATION Postmaster for current f~...... .. N'>O'" .Ji-....l'" * ...... . .. lOUNllro "O~~" i ~ ~I;") ) " V1 '~4' > ~Oci'~ ~ ; ~"I / One piece of rdinary meil addressed to: JOAN APPLETON COSTANZA 53 HONEYSUCKLE DRIVE MEClWj.IC~WJRC, PI.. 17055 el ,,,..,../Ij,, ~ O_."=',"~ ~ . ~.,- ~~~_. ~ , " ~~<" '"""''''"'''''''h"''i:I!I.WIII"'"''i:nr~TIliiIII1Wflr'i1fiflfi'i!t'~ t7O(J~ t ~ 7-. ' ~- '- & 1'),J N j~ ~ r ~ ~ i? R J: (') ~,; ~ -Ocr: n-lrr -;-?--", ::"C;";;: (f)Y; -<...:'. k::: (') .J.-~ ,---- z>c~ PC z: ::2 ~J~ ~, ,UUJ-I .__",>,~IlliI~i1\\.)1[,-f'" ",," _~T~f1!1-;{~~~~*,~'9~JU!!~~':W''''-''''~:""''-!-'''",,,p, C) ""., . '" 3: '-"" ~.,---< ,."J - .._~ 1'.) "-;:J . , ~J ;;js~ ;;n -< .- .~ ,-;011'][ _r ~--r:,'""'"ir'r".' r- PRAECIPE FOR WRIT OF EXECUTION COMMONWEALTH OF PENNSYLV ANlA COUNTY OF CUMBERLAND GMAC Mortgage Corporation v. Joan Appleton-Costanza NO. 01-7070-Civil Term Praecipe for Writ Qf Execution " ,; TO THE PROTHONOTARY: Issue Writ of Execution in the above matter: AMOUNT DUE INTEREST from 03012/02 to SALE DATE At $26,24 per diem (Costs to be added) : '}""'''~''''''''v.~ ' .1, "" '1" <~ ~ Martha E. Von Rosenstiel Attorney for Plaintiff -~ $160,976.52 $ $ ( ~_.,.~ ,=~~~ 'l~~ ,.,.,..,.,,, II , '~..' ,.,^" ='.' '.' ',<,,,,~ >,~~~'w.""""'hC~>%'-''' uffC<,!l6if~itif1'1)~~!~Il:i>Jtirf""(CC'f"'Ytr~!t~t~f;r~i3~~ ...... ~ (J 0 ..tJ <- Uv ~ ~ ~ !"t ..c 0 c:::; c', ~ !'l 6.J ~ C 1',,-, , ,- q . -..:;.." o"'r--'" ~ ","" '7 , ~ 0 ~ 0 .VCC' :J~'l ". D C rnrri ~XI Z~' ...... - c: 0 l) 65S: j 1') JU ~ t I , -</ -,.- ~._, JJ !<c> '':.r:-' -V ..::; ,-"---:::.:c,; ~ ~ 'I'- .. r J;C) :J~: ,--:;.: C-) (jJ , , p::: =C~l _rc' F" oll: ... ... :;r:..C ,~,I r- ... ~ Z ':,.) :;:::~ ::;J ~ rv~ '. .... =<: .. , ... '" .. , - -. ~ I,~,c~', " __ ,~ , ~ ' _ "'.',"_.' ! .~ R~~ ,,~~,~<'~'''~~'~''''~''1' C'rg!'ill'!:~T~..~~rrl,jlJ:F.1-lI~_~~::"";"C:~.""'''''''f'''-; ~"'-lI;-;',:~~..~,m-'i',\Ii~%J!ffl<-;O;)j:'iJr<H''=W-"":~'f'''f';9!''lf0rM;'l!i!llJ~~~'' ""1'- mc" 1"'.'" -iJUiT r_ DESCRIPTION ALL THAT CERTAIN piece or parcel of land situate in Silver Spring Township, Cumberland County, (erroneously referred to in prior deed as Dauphin County) Pennsylvania, as set forth on a Final Subdivision Plan for Mulberry Crossing, Section Three, Wynnewood West Development Company, as prepared by Ganett Fleming Civil Engineers, Inc., and recorded in the Recorder of Deeds Office of Cumberland County, Pennsylvania, in Plan Book 49, Page III, and more particularly bounded and described as follows, to wit: BEGINNING at a point on the right-of-way line of Honeysuckle Drive at the dividing line between Lots Nos. 167 and 168 as shown on the aforementioned Subdivision Plan; thence along said right- of-way line of Honeysuckle Drive by a curve to the left having a radius of 175.00 feet, an arc distance of 59.50 feet with a chord bearing North 52 degrees 18 minutes 24 seconds East, a distance of 159.11 feet to a point at the dividing line between Lots Nos. 168 and 169; thence along same South 47 degrees 39 minutes 2 seconds East 151.40 feet to a point; thence South 25 degrees 16 minutes 2 seconds West a distance of 63.36 feet to a point at the dividing line between Lots Nos. 168 and 154; thence along same South 79 degrees 20 minutes 46 seconds West, a distance of 60.77 feet to a point at the dividing line between Lots Nos. 168, 154 and 167; thence along the dividing line between Lots Nos. 168 and 167 North 28 degrees 10 minutes 12 seconds West, a distance of 152.17 feet to a point, the place of beginning. BEING Lot No. 168 on the aforementioned Final Subdivision Plan for Mulberry Crossing, Section Three, Wynnewood West Development Company. CONTAINING 14,159 square feet, more or less. UNDER AND SUBJECT to setback lines, easements and conditions as shown on the aforementioned Final Subdivision Plan and restrictions and conditions as set forth in the Declaration of Wynnewood West Development Company that is recorded in Cmnberland County Miscellaneous Book 308, Page 260. Tax Parcel # 38-22-0144-118 ,. "'''~,,'.''''',*Ji''; .~ ",' -C'" , , r," "',- . ~~ - -- " - ~r- >,. , ."",.,.~,,,,--;;-: _"""W''''''~ ,.',"'" '. Martha E. Von Rosenstiel, P .C, Martha E. Von Rosenstiel 16 South Lansdowne Avenue P.O. Box 457 Lansdowne, PA 19050 610623-2660 Attorney LD.# 52634 Attorney for Plaintiff GMAC Mortgage Corporation 500 Enterprise Road Horsham PA 19044-0963 COURT OF COMMON PLEAS CUMBERLAND COUNTY Plaintiff vs. Joan Appleton-Costanza 53 Honeysuckle Drive Mechanicsburg, P A 17055 Defendants No: 01-7070-Civil Term AFFIDAVIT OF NOTICE PURSUANT TO RULE 3129.1 COMMONWEALTH OF PENNSYLVANIA: SS COUNTY OF DELAWARE MARTHA E, VON ROSENSTIEL, attorney for the plaintiff in the above action, sets forth as of the date the praecipe for the Writ of Execution was filed the following information concerning the real property located at 53 Honeysuckle Drive, Mechanicsburg, P A 17055. 1. Name and address of owners(s) orreputed owner(s) Joan Appleton-Costanza 53 Honeysuckle Drive Mechanicsburg, PA 17055 2. Name and address of defendant(s) in the judgment: Joan Appleton-Costanza 53 Honeysuckle Drive Mechanicsburg, P A 17055 3. Name and address of every judgment creditor whose judgment is a record lien on the real property to be sold: NONE 4. Name and address of the last recorded holder of every mortgage of record: <0'""', ~ ," _ ""'"' _ _ r' --"""!' - . ~'!~"~ '",." n' < ,< '=W'^ Ford Consumer Finance Co., Inc. 11311 Cornell Park Dr., Ste. 300 Cincinnati, OH 45242 Ford Consumer Finance Co., Inc. 3220 Tillman Dr., Ste. 101 Bensalem, PA 19020 Commerce Bank NA 100 Senate Ave. P.O. Box 8599 Camp Hill, P A 17011 5, Name and address of every other person who has any record lien on the property: 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: NONE 7. Name and address of every other person of whom plaintiff has knowledge who has any interest in the property which may be affected by the sale: Family CourtlDomestic Relations Office One Courthouse Square Carlisle, P A 17013 Dept. of Public Welfare 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. Section 4904 relating to unsworn falsification to authorities. Martha E, Von Rosenstiel Attorney for Plaintiff ( ',' ~""":,.-""""'" ~7'., ^,,~=~ _'~< . " ~ , ~~".,~- 'l'I~:ilIIl_I!..""'='F"'~' '~r'>m,~ i"r--r:1r--,~",.t7"--i.-' ~,'." MARTHA E. VON ROSENSTIEL, P.c. ATTORNEY AT LAW 16 SOUTH LANSDOWNE AVENUE P.O. BOX 457 LANSDOWNE, PA 19050 PHONE(610)623-2660 FAX(610)623-2745 March 11,2002 TO: Ford Consumer Finance Co., Inc. 11311 Cornell Park Dr., Ste. 300 Cincinnati, OH 45242 RE: NOTICE OF SALE OF REAL PROPERTY: 53 Honeysuckle Drive Mechanicsburg, P A 17055 Amount of Judgment: $160,976.52 Date of Judgment: March 12, 2002 Court Term and Number: Court of Common Pleas of Cumberland County, Docket# 01-7070-Civil Term Plaintiff: GMAC Mortgage Corporation Defendants: Joan Appleton-Costanza Dear Sir/Madam: Please be advised that the property and residential dwelling, located at and known as 53 Honeysuckle Drive Mechanicsburg, P A 17055 will be sold by the Sheriff of Cumberland County on June 5, 2002 at 10:00 a.m. in the Cumberland County Court House, One Court House Square, Carlisle, P A 17013. This notice is being sent to you because my records indicate that you hold a lien on the property secondary to the first mortgage, which is being foreclosed. This property and improvements are being sold pursuant to a judgment entered as indicated above in favor of the above named plaintiff, and against the above named defendants. The name of the owners, real owners, and reputed owners ofthe aforementioned property are Joan Appleton-Costanza. A schedule of distribution will be filed by the Sheriff on a date specified by the Sheriff no later than 30 days after said sale, and distribution will be made in accordance with the schedule unless exceptions are filed thereto within ten (10) days after the date of the filing of said schedule. You should check with the Sheriffs Office by calling 717 240-6391 to determine the actual date of the filing ofthe schedule. ( ~:~"~'-?'-"_W'f'l'",,'~ "'~~ ,~,~"'" .~._ ,"', ,,_ , , ~^ ~ ~- -I ,",.i;'~'1~.11".~1''''---j'l'r--':--''':''' .-(''1 ,,' --, MARTHA E. VON ROSENSTIEL, P.C. ATTORNEY AT LAW 16 SOUTH LANSDOWNE AVENUE P.O. BOX 457 LANSDOWNE, PA 19050 PHONE(610)623-2660 March 11, 2002 TO: Ford Consumer Finance Co., Inc. 3220 Tillman Dr., Ste. 101 Bensalem, PA 19020 RE: NOTICE OF SALE OF REAL PROPERTY: 53 Honeysuckle Drive Mechanicsburg, P A 17055 Amount of Judgment: $160,976.52 Date of Judgment: March 12,2002 Court Term and Number: Court of Common Pleas of Cumberland County, Docket# 01-7070-Civil Term Plaintiff: GMAC Mortgage Corporation Defendants: Joan Appleton-Costanza Dear Sir/Madam: FAX(610)623-2745 Please be advised that the property and residential dwelling, located at and known as 53 Honeysuckle Drive Mechanicsburg, P A 17055 will be sold by the Sheriff of Cumberland County on June 5, 2002 at 10:00 a.m. in the Cumberland County Court House, One Court House Square, Carlisle, PA 17013. This notice is being sent to you because my records indicate that you hold a lien on the property secondary to the first mortgage, which is being foreclosed. This property and improvements are being sold pursuant to a judgment entered as indicated above in favor of the above named plaintiff, and against the above named defendants. The name ofthe owners, real owners, and reputed owners ofthe aforementioned property are Joan Appleton-Costanza. A schedule of distribution will be filed by the Sheriff on a date specified by the Sheriff no later than 30 days after said sale, and distribution will be made in accordance with the schedule unless exceptions are filed thereto within ten (10) days after the date of the filing of said schedule. You should check with the Sheriffs Office by calling 717240-6391 to determine the actual date of the filing of the schedule. urs, "'--':';":7',""'% , __ .' .. ,.~, iiill"!M~ :;;;"~*rriir.r:''@ ""', '"1' "1 . - MARTHA E. VON ROSENSTIEL, P.c. ATTORNEY AT LAW 16 SOUTH LANSDOWNE AVENUE P.O. BOX 457 LANSDOWNE, PA 19050 PHONE(61O)623-2660 FAX(610)623-2745 March 11, 2002 TO: Commerce Bank NA 100 Senate Ave. P.O. Box 8599 Camp Hill, PA 17011 RE: NOTICE OF SALE OF REAL PROPERTY: 53 Honeysuckle Drive Mechanicsburg, P A 17055 Amount of Judgment: $160,976.52 Date of Judgment: March 12, 2002 Court Term and Number: Court of Common Pleas of Cumberland County, Docket# 01-7070-Civil Term Plaintiff: GMAC Mortgage Corporation Defendants: Joan Appleton-Costanza Dear Sir/Madam: Please be advised that the property and residential dwelling, located at and known as 53 Honeysuckle Drive Mechanicsburg, P A 17055 will be sold by the Sheriff of Cumberland County on June 5, 2002 at 10:00 a.m. in the Cumberland County Court House, One Court House Square, Carlisle, PA 17013. This notice is being sent to you because my records indicate that you hold a lien on the property secondary to the first mortgage, which is being foreclosed. This property and improvements are being sold pursuant to a judgment entered as indicated above in favor of the above named plaintiff, and against the above named defendants. The name ofthe owners, real owners, and reputed owners ofthe aforementioned property are Joan Appleton-Costanza. A schedule of distribution will be filed by the Sheriff on a date specified by the Sheriff no later than 30 days after said sale, and distribution will be made in accordance with the schedule unless exceptions are filed thereto within ten (10) days after the date ofthe filing of said schedule. You should check with the Sheriffs Office by calling 717 240-6391 to determine the actual date of the filing of the schedule. Sincerely yours, / _o"-""';i,"'="'~"" ",.",' ,.'e' '~. ' 1"'" 'I' " - , .,. ,~ I ~ """ ~T -. T J:r-"--"- MARTHA E. VON ROSENSTlEL, P.C. ATTORNEY AT LAW 16 SOUTH LANSDOWNE AVENUE P.O. BOX 457 LANSDOWNE, PA 19050 PHONE(61O)623-2660 FAX(61 0)623-2745 March 11, 2002 TO: Family Court/Domestic Relations Office One Courthouse Square Carlisle, P A 17013 RE: NOTICE OF SALE OF REAL PROPERTY: 53 Honeysuckle Drive Mechanicsburg, P A 17055 Amount of Judgment: $160,976.52 Date of Judgment: March 12,2002 Court Term and Number: Court of Common Pleas of Cumberland County, Docket# 01-7070-Civil Term Plaintiff: GMAC Mortgage Corporation Defendants: Joan Appleton-Costanza Dear Sir/Madam: Please be advised that the property and residential dwelling, located at and known as 53 Honeysuckle Drive Mechanicsburg, P A 17055 will he sold by the Sheriff of Cumberland County on June 5, 2002 at 10:00 a.m. in the Cumberland County Court House, One Court House Square, Carlisle, PA 17013. This notice is being sent to you because my records indicate that you hold a lien on the property secondary to the first mortgage, which is being foreclosed. This property and improvements are being sold pursuant to a judgment entered as indicated above in favor of the above named plaintiff, and against the above named defendants. The name of the owners, real owners, and reputed owners of the aforementioned property are Joan Appleton-Costanza, A schedule of distribution will be filed by the Sheriff on a date specified by the Sheriff no later than 30 days after said sale, and distribution will be made in accordance with the schedule unless exceptions are filed thereto within ten (10) days after the date of the filing of said schedule. You should check with the Sheriffs Office by calling 717 240-6391 to determine the actual date of the filing of the schedule. Sincerely yours, "',3_i''''-''''W'-'''' . , " - , H --v . ~" . . '" r .~ . . r -:.~ "nr ,,^.' ,- MARTHA E. VON ROSENSTIEL, P.c. ATTORNEY AT LAW 16 SOUTH LANSDOWNE AVENUE P.O. BOX 457 LANSDOWNE, PA 19050 PHONE(610)623-2660 FAX(610)623-2745 March 11, 2002 TO: Dept. of Public Welfare Box 2675 Harrisburg, PA 17105 RE: NOTICE OF SALE OF REAL PROPERTY: 53 Honeysuckle Drive Mechanicsburg, P A 17055 Amount of Judgment: $160,976.52 Date of Judgment: March 12,2002 Court Term and Number: Court of Common Pleas of Cumberland County, Docket# 01-7070-Civil Term Plaintiff: GMAC Mortgage Corporation Defendants: Joan Appleton-Costanza Dear Sir/Madam: Please be advised that the property and residential dwelling, located at and known as 53 Honeysuckle Drive Mechanicsburg, P A 17055 will be sold by the Sheriff of Cumberland County on June 5, 2002 at 10:00 a.m. in the Cumberland County Court House, One Court House Square, Carlisle, P A 17013. This notice is being sent to you because my records indicate that you hold a lien on the property secondary to the first mortgage, which is being foreclosed, This property and improvements are being sold pursuant to a judgment entered as indicated above in favor of the above named plaintiff, and against the above named defendants. The name of the owners, real owners, and reputed owners of the aforementioned property are Joan Appleton-Costan2a. A schedule of distribution will be filed by the Sheriff on a date specified by the Sheriff no later than 30 days after said sale, and distribution will be made in accordance with the schedule unless exceptions are filed thereto within ten (10) days after the date of the filing of said schedule. You should check with the Sheriffs Office by calling 717 240-6391 to determine the actual date of the filing ofthe schedule. Sincerely yours, ~'.'-":n',,~>"''''''''1rn . , ~ '" ' '"~ ~ ,.' ~ "" - " ~ ~1"~!"~ I " .... .. . ""'''~'''''''''''''"''''''''~1iI'1'ij~!iIilli.ITr~''WjIKIlITI1iim'r[rr'" 0 c, C '--'." '-7l . ~ -, ~: ::It w tT :.t.'~ rn r'7" "7> --;::;0 7 C0 I'''; ~ r~ .. <- c:; "-0 <> -'COo C".' .'-:," -, L... () )> C (') Z :~ -.j ':"'J )::.~ '-c ,,- ::0 ,~ -< ~''''''tll' , '" ?~ liI'1 " ,,~~~~!!lMl!lI$~~!RJ"<~~1~'-*"!~1'*,':;;!C"""~:1-""'-"""',,~t'_pr_'-1'-"'W~if";"'J:'l~~',~;:r;t;-'W~\ij,1W'~~~RlljJf, ~~~H~:~~'rTI(. ' '] '- '",,''''.-' Martha E. Von Rosenstiel, P.c. Martha E. Von Rosenstiel 16 South Lansdowne Avenue P.O. Box 457 Lansdowne, PA 19050 610 623-2660 Attorney 1.D.# 52634 Attorney for Plaintiff GMAC Mortgage Corporation 500 Enterprise Road Horsham, P A 19044-0963 COURT OF COMMON PLEAS CUMBERLAND COUNTY Plaintiff vs. Joan Appleton-Costanza 53 Honeysuckle Drive Mechanicsburg, P A 17055 Defendant No: 01-7070-Civil Term THIS IS AN ATTEMPT TO COLLECT A DEBT ANY INFORMATION OBTAINED WILL BE USED FOR THAT PURPOSE NOTICE OF SHERIFF'S SALE OF REAL PROPERTY TO: Joan Appleton-Costanza 53 Honeysuckle Drive Mechauicsburg, P A 17055 Your house and/or real estate at 53 Honeysuckle Drive, Mechanicsburg, P A 17055 is scheduled to be sold at Sheriffs Sale on June 5, 2002 at 10:00 a.m. to enforce the court judgment of $160,976.52 obtained by GMAC Mortgage Corporation against you. NOTICE OF OWNERS 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 GMAC Mortgage Corporation the back payments, late charges, costs and reasonable attorney's fees due. To find out how much you must pay, you may call 610 623-2660. 2. You may be able to stop the sale by filing a petition asking the Court to strike or open the judgment, if the judgment was improperly entered. You may also ask the Court to postpone the sale for good cause. 3. You may also be able to stop the sale through other legal proceedings. '".'i""'"'~,.""'"",< ;,; ~.~ . _~ r " ,- = " ,- - '''''''''.''''' _ "'__"'''WI''"'_'' _ -~-J[ r .IT T~ ':<'~-." ' You may contact 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) 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 bid price by calling 610 623-2660. 2. You may beab'le to petition the Court to set aside the sale ifthe bid price was grossly inadequate compared to the value of the property. 3. The sale will go through only ifthe buyer pays the Sheriff the full amount due in the sale. To find out ifthis has happened you may call 610 623-2660. 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 a 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 on a date to be announced by the Sheriff. 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 Schedule of Distribution is posted. 7. You may also have other rights and defenses, or ways of getting your house 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. COURT ADMINISTRATOR 4TH FLOOR CUMBERLAND COUNTY COURT HOUSE CARLISLE, PA 17013 Telephone: 717 240-6200 -'T..'<,<"'""",,,",,,,,,, , I -" ,~~ ,..~ - 1. , ~, 'I - ~~", ",- ."- CLAIM FOR EXEMPTION To the Sheriff: 1, the above named defendant, claim exemption of property from levy or attachment: (1) From my real property in my possession which has been levied upon, (a) I desire that my $300.00 statutory exemption be set-aside in kind (specify real property to be set-aside in kind): I request a prompt court hearing to determine the exemption. Notice of the hearing should be given to me at (Address) (Telephone Number) I verify that the statements made in this Claim for Exemption are true and correct. I understand that false statements herein are made subject to the penalties of 18 Pa. C.S. Section 4904 relating to unsworn falsification to authorities. Date: Signature THIS CLAIM TO BE FILED WITH THE OFFICE OF THE SHERIFF CUMBERLAND COUNTY COURTHOUSE CARLISLE, P A 17013 717 240-6391 . c;t.;''''''',''';~i:>''''''''~, ~':' , " ,1",'" 1~ - - , r r_ WRIT OF EXECUTION _ (MORTGAGE FORECLOSURE) P.R.C.P. 3180 to 3183 and Rule 3257 GMAC Mortgage Corporation IN THE COURT OF COMMON PLEAS OF CUMBERLAND COUNTY, PENNSYLVANIA vs. No. OI-7070-Civil Term No. Term,20....E.D. Term, 20-. .A.D. Joan Appleton-Coztanza WRIT OF EXECUTION (MORTGAGE FORECLOSURE) Commonwealth of Pennsylvania: Counly of TO THE SHERIFF OF CUMBERLAND COUNTY, PENNSYL VANIA: To satisfy the judgment, interest and costs in the above matter you are directed to levy upon and sell the following described property (specifically describe property below): PREMISES: 53 Honeysuckle Drive Mechanicsburg, P A 17055 Amount Due $160,976.52 Interest from 03/13/02 to Sale Date @ $26.24 per diem Attorney's fees Total $ $ $ $ Costs as endorsed. Date~ Prothonotary, Common Pleas Court of Cumberland County, Penna. (SEAL) By: Deputy .~,';r.-"~,,,,,,,,~<w,'~ .. "1 " - ," , , .. ~ ~. ~~ ..", ----~, -- - "",,"', ~ I" . - -,~"""c-;-,' ,';" '~,W-,",,,,;-,,, ,'-V- ,"[,."",,,,'{J'""fJ~;"-~""'"mJl!llUr B -~' tt:'t-,,;,'-">\<f'''r~ "" ""'r ~~ en (') ~ "C p. "'po a :-< '" ....., Q (')~ p. ~::; ~~ p.. ? 0 c::Z 'i 0", C!" >0 ~ ro 2::::>-3 '" '--'p.. . ::r "C ~ '" "'0 rpo ~ p.. >- >- tD::r: '" N;:E ~ " trltI:I "" ~ Vl 'T'::; ~ " '0 n ~(') ro '" 'i VJ N." p.. <: ""'::8 '0 s;: "0 ro C1> "''1:100 ~~ - :zc () ::r: "'>;:E::; C1> 0 '" o ~ ..... '" ::r' 0 o ::; ::1.>-3 0 .., o~ ..... '" ~ ~ " ~ (Jq 9 [JQ >-3 ro ~>o 0 'i C1> cffl >0 (')0 '" (S' ~ '" '" >rj n [JQ 0<:" n O>rj CIJ CIJ "" V> " ::; " tI:I 0 C1> 3 V C ~ o~~ 0 N < c:: '" ~ on >rj~ " n zn '" c () >' _. ~ ..... 0 ::; tI:I >0 -10 tJ"'" " 'i " " on 0 CD gq cr " .:-- " n ~ -8 .:< s::: ro t"d Sc , '" >0 >-os::: >-0 tJ on ~ >-3 0 '" ~ ..p .., trlo ro >- .., 0 E; ~ >0 'i _. 'i 0 ..... ~Z < <: ~ ~Z _. ro - C1> ~ 0 <Zl "C p. -J '" ~ -<:" 0 ~. "tI:I " Vl ~ <;J> Vl ~. ~ >en ~ 30 >>rj ;^'~1~f~JlI!~lt!11J1'1J!1l!~Jr__~~r~ji~: ~. _ ,F",~~,,~.\f ~~"'*''1i,,",,"-mv.~f;?liI~!fl:~ff!~~;!m~f'.ry!'t<'IT!IW.''fQ~'D'"''''~-;<:-''- .' ;J> tI:I b 0 Z Z ? ? 0 ~ , -..l 0 -..l 0 , n _. :5. - >-3 " a to..> to..> <:> <:> I I ." .~i1 rfTT"'~l..:-"_ f)i1'~"-"- 'f" - '"~~~ '. DESCRIPTION ALL THAT CERTAIN piece or parcel of land situate in Silver Spring Township, Cumberland County, (erroneously referred to in prior deed as Dauphin County) Pennsylvania, as set fonh on a Final Subdivision Plan for Mulberry Crossing, Section Three, Wynnewood West Development Company, as prepared by Ganett Fleming Civil Engineers, Inc., and recorded in the Recorder of Deeds Office of Cumberland County, Pennsylvania, in Plan Book 49, Page III, and more particularly bounded and described as follows, to wit: BEGINNING at a point on the right-of-way line of Honeysuckle Drive at the dividing line between Lots Nos. 167 and 168 as shown on the aforementioned Subdivision Plan; thence along said right- of-way line of Honeysuckle Drive by a curve to the left having a radius of 175.00 feet, an arc distance of 59.50 feet with a chord bearing North 52 degrees 18 minutes 24 seconds East, a distance of 159.11 feet to a point at the dividing line between Lots Nos. 168 and 169; thence along same South 47 degrees 39 minutes 2 seconds East 151.40 feet to a point; thence South.25 degrees 16 minutes 2 'seconds West a distance of 63.36 feet to a point at the dividing line between Lots Nos. 168 and 154; thence along same South 79 degrees 20 minutes 46 seconds West, a distance of 60.77 feet to a point at the dividing line between Lots Nos, 168, 154 and 167; thence along the dividing line between Lots Nos. 168 and 167 North 28 degrees 10 minutes 12 seconds West, a distance of 152.17 feet to a point, the place of beginning, BEING Lot No. 168 on the aforementioned Final Subdivision Plan for Mulberry Crossing, Section Three, Wynnewood West Development Company. CONTAINING 14,159 square feet, more or less, UNDER AND SUBJECT to setback lines, easements and conditions as shown on the aforementioned Final Subdivision Plan and restrictions and conditions as set forth in the Declaration of Wynnewood West Development Company that is recorded in Cumberland County Miscellaneous Book 308, Page 260. Tax Parcel # 38-22-0144-118 '..~'>_!i"".!!tI:'WfC' ~ " """'-'..' '" ~ ..I~ , r ,~ '-' ~ ~~~ '" i ~ ~ i!!~,~ ,- "'~,,"' '".%'-""'<<~, "'''''', "~V', ""~~"~i\'H';;,"',"'''' , b "~~lt~~~'?Ti~tr~:"'''fff:"!Q]''':0.,>r%O\''lt~ttl~~:~>rrr1i;J rn ~ iiftlfiJ~'iI~F~'f~ 0 C"J () <;:; ,." ,1 ~':::... ~ " ...:',," "1:) C] ,-"" m lei ,'::J , , ~ ~~;: "'~- (f) ['0 / ~ .. () ~ () ~ ."'- ':".) ~~ '-;J ~ '., .t:" -, ,'" ~1I_~1TTm:JI)~.~'~'~E~~lilI!;lli~~_~,~t<lJI~f~ijh'lfi;~':jl!~f#E1?J.."l'!'i;~'-"'i","iR "'''-''~P-<T~)-w.:~,~~~e.~jO<{''~<%1i:':+~",'e',;;rriH''M!~~;y,llj~'\: { :"'j:-'TJJ] ~"'-"r"r:~' '-~.~.~-~. il ~ ',.4 ~ #7531-SF Martha E. Von Rosenstiel, P .C. Martha E. Von Rosenstiel 16 South Lansdowne Avenue P.O. Box 457 Lansdowne, PA 19050 610623-2660 Attorney 1.D.# 52634 Attorney for Plaintiff GMAC Mortgage Corporation 500 Enterprise Road Horsham P A 19044-0963 COURT OF COMMON PLEAS CUMBERLAND COUNTY Plaintiff vs. Joan Appleton-Costanza 53 Honeysuckle Drive Mechanicsburg, P A 17055 Defendants No: 01-7070-Civil Term SUPPLEMENTAL AFFIDAVIT OF SERVICE OF NOTICES PURSUANT TO RULE 3129.1 COMMONWEALTH OF PENNSYLVANIA: COUNTY OF DELAWARE SS MARTHA E. VON ROSENSTIEL, attorney for the plaintiff in the above action, hereby certifies that service of the Notice under Rule 3129.1, in the above matter was made on the defendants via certified mail, return receipt requested and by regular first class mail (unless otherwise stated) and on all interested parties, set forth below, by regular first class mail, postage prepaid, as evidenced by the attached certificates of mailing: 1, Name and address of every judgment creditor whose judgment is a record lien on the real property to be sold: Bureau of Compliance / Dept. 280946 Harrisburg, P A 17128 2. Name and address of every other person who has any record interest in the property and whose interest may be affected by the sale: Silver Spring Township Authority! 6415 Carlisle Pike Mechanicsburg, P A 17055 "_.","""'i-'!1"W~':"", ., ,-: -" --, ~--~ " 1-'- , ~ ~,. - .. . ~ .. ~ ,"~\i'iI!I!!'!!I ."i".'14l~'."':T"" ~: ,,' , : -.6< , " " . 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. Section 4904 relati to unsworn falsification to authorities. Martha E. Von Rosenstiel Attorney for Plaintiff "'9ii',-"~""""--'f"h".""",I'?-~_ >_ ',-"-- - '1.,-, ,- . .. ., - ~,-,'-""- ~~ ="_. 1- ~ '."ni'liIIIr..".v - -~- ','.". . . - LL-::CF- "'NO l--r?!. 9~ 'It ~e:; 4"~~ 0: ,\'t ~ 0 0- 0 ," O~~O "';,1:::., J i 'D ,9- (j) ,"" ~ ~ ~ ~ 0,~ '~'~0/ H ~~ "(viY\l~ ,- OS ,... c:lPI= 2.<:' Iii W , . .J ~ ~!1l'lilna "'s IE 1::'" ,-" <( ~~ .... '.. il r"Q)I'. N 15 <<go- co ~.., ~[!!'f"'" co $ ~- .~ ::::.5-m c.. cu-o o ::E~o. 8: i~~ ~ al WJ::,gc ~ ii)=:=:[!! ~ .ij)~ ~ ~ t3.e~OD.E :9-Q) 1j.!!! 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Box 457 Lansdowne, P A 19050 610623-2660 Attomey LD.# 52634 Attorney for Plaintiff GMAC Mortgage Corporation 500 Enterprise Road Horsham P A 19044-0963 COURT OF COMMON PLEAS CUMBERLAND COUNTY Plaintiff vs. Joan Appleton-Costanza 53 Honeysuckle Drive Mechanicsburg, P A 17055 Defendants No: 01-7070-Civil Term AFFIDAVIT OF SERVICE OF NOTICES PURSUANT TO RULE 3129,1 COMMONWEALTH OF PENNSYLVANIA: COUNTY OF DELAWARE SS MARTHA E. VON ROSENSTIEL, attorney for the plaintiff in the above action, hereby certifies that service of the Notice under Rule 3129.1, in the above matter was made on the defendants via certified mail, return receipt requested and by regular first class mail (unless otherwise stated) and on all interested parties, set forth below, by regular first class mail, postage prepaid, as evidenced by the attached certificates of mailing: 1. Name and address of owners(s) orreputed owner(s) Joan Appleton-Costanza 53 Honeysuckle Drive Mechanicsburg, P A 17055 2. Name and address of defendant(s) in the judgment: Joan Appleton-Costanza 53 Honeysuckle Drive Mechanicsburg, P A 17055 3. Name and address of every judgment creditor whose judgment is a record lien on the real property to be sold: NONE 4. Name and address of the last recorded holder of every mortgage of record: ""i"'-"';'~I''"'"",,,,,~1 1 IJ, ~ ,~ . '. ll~,gjr" rlffL U """, c. .~~- ~.I>f\II~ ~~"-~.~ I" '~ '] ri"___"~'rr'__. Ford Consumer Finance Co., Inc, V 11311 Cornell Park Dr., Ste. 300 Cincinnati, OH 45242 Ford Consumer Finance Co" Inc.1 3220 Tillman Dr., Ste. 101 Bensalem, P A 19020 Commerce Bank NA I 100 Senate Ave. P,O. Box 8599 Camp Hill, P A 17011 5. Name and address of every other person who has any record lien on the property: 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: Family Court/Domestic Relations Office,/ One Courthouse Square Carlisle, PA 17013 Dept. of Public Welfare ./ 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. Section 4904 relating to unsworn falsification to authorities. Martha E. Von Rosenstiel Attorney for Plaintiff ,~,"-~"H~i'J;l. -'" ) , " ", - ~-"."""' "~'~F-~ '1'""""""""'-,'"'0''.''' "" U,S, POSTAL SE~VICE ATE MAY BE USEO FOR DOMEST OF MAILING PR,9yrdE FO$ INSURANCE_~~:f~~~~:~NA TIONAl MAil, DOES NOT R"';ved F,oMARTHA E. VON ROSENSrlEL P.C 16 S. LANSDOWNE AVE' . . P. O. BOX 457 . One piece of ordinary mail addressed to: JOAN APPLETON COS~ 53 HONEYSUCKLE DRIVE MECHANICSBURG, PA, 17055 PS Form 3817, MBr, 1989 7.53 ~- Postage $ Affix fee here in stamps I' ~~err- p~tage and P06hmark. Inquire at P~stQJa8terJor Current 15."_.. ' ~ .., '" OUNt~Q 80~' /:>-<; ~. f~) ',,,, ?(n ~ lf~, o ~ :'~ ~ ~ fIll \Jtow 1 ON", , ! -;t: Certlflod Fee CJ _m ReceIpt Fee CJ (I!ndolsament Rsqlliled) ~ _cledDel!veJyFee (&1dorsement RecjuJred) ~ _ PosIage a Fees $ IT'SentTO ' "'" 'JOAN APPLETON COSTANZA ""'_Apt.No., - ~ 0' PO 80Jt No. 53 HONEYSUCKLE DRIVE I'- CJI)\ State, Z/I'> ,4 '." ," "",' ,MECHANICSBURG P . . " ,', - ~ - _, - , - - -,' : ' - ' '_, _~ c', _' ' ,," . dcimpleieltemS 1.2. and 3. Also ciompl~" f \;;1;; item' 4 ~ Resirtcttld Delivery Is de$jl!ld, " , ' ,,,' '; ',' i" . Print your name and address on the reverse - so that we can return the card to you. . Attach this card to,ll:!~ back oUhe mailpiece, , or on the front If space permits. 1. Article Addressed to: i, D. 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"''''^''ft"'''~'v''O'T';'V"",v,;;..~. 1"-r,',s~; '0, )('''it'Yfl~Q:~'i,.:~~trf1(,i'IHtr'~''tniWt.'};:T''I'-~:.i'''l'l1f;~'~~~~ n c ~~" ~IF CO _t' i!-; PC::::::: :2: -I -< ~""'" ., ,_~~.-~'1!Il!W~ "~,"~~!H!tm~~_,,-~ r_.'~ '3-#l!!I~tt~i';Wm'1';~m;!il!iJ'~I~'i"""'1:(""~O-&9,,,&'l""'?:W:'~'i;~c'~,-:,-~.,,' '"'"-~".' "".~"'~"~;Tqg"'~1tIi"F~.\~~!j:,)'i;W-"-'1~t""~;i.!'lIU:!f'ff.~I~!!I.I~'t,ijUIJ-f fs !3Ij . . c:< 1'1 _~lJIo -\..1 ::~(J f)') .......~) - ~";:l ,::j :~'l 7<) ''"'-SfTl ~ :D -< f\.,) :/1 ~,!%'itr,"':"I"~f,[ . '_""""""'-,""'"' '>r~ -,--- "','T"~'W' , COMMONWEALTH OF PENNSYLVANIA COUNTY OF CUMBERLAND } SS: I, Robert P. Ziegler, Recorder of Deeds in and for said County and State do hereby certify that the Sheriff's Deed in which Alan Ball & Kevin Craig is the grantee the same having been sold to said grantee on the 5th day of June A.D., 2002, under and by virtue of a writ Execution issued on the 12th day of March, A.D., 2002, out ofthe Court of Common Pleas of said County as of Civil Term, 01 Number 7070, at the suit of GMAC Mtg Corp against Joan Appleton-Costanza is duly recorded in Sheriffs Deed Book No. 252, Page 4132, IN TESTIMONY WHEREOF, I have hereunto set my hand and seal of said office this .2 4- day of'Jv'lA.D. 20~?--- ~ Y Recorder of Deeds '.j:.p;;"l'K""""'r'?!"~Ff"."""",,, !J__ ::<" 1-"- ri ! ,~,.- "":r-T~ liW"T:T]I GMAC Mortgage Corporation VS Joan Appleton-Costanza In The Court of Common Pleas of Cumberland County, Pennsylvania Writ No. 2001,7070 Civil Term David McKinney, Deputy Sheriff, who being duly sworn according to law, states that on April 8;'2002 at 10:10 o'clock AM, EDST, he served a true copy of the within Real Estate Writ, Notice and Description, in the above entitled action, upon the within /' _.-- nariled defendant, to wit: Joan Appleton-Costanza, by making known unto Joan Appleton,Costanza personally, at 102 Franklin Square, Mechanicsburg, Cumberland County, Pennsylvania, its contents and at the same time handing to him personally the said true and correct copy of the same. David McKinney, Deputy Sheriff, who being duly sworn according to law, states that on April 8, 2002 at 10:34 0 'clock A.M., EDST, he posted a true copy of the within Real Estate Writ, Notice, Poster and Description, in the above entitled action, upon the property of Joan Appleton-Costanza located at 53 Honeysuckle Drive, Mechanicsburg, Pennsylvania, according to law. R. Thomas Kline, Sheriff, who being duly sworn according to law says he served the above Real Estate Writ, Notice, Poster and Description in the following manner: The Sheriff mailed a notice of the pendency of the action to one of the within named defendants to wit: Joan Appleton-Costanza, by regular mail to her last known address of 102 Franklin Square, Mechanicsburg, P A 17055. This letter was mailed under the date of April 15, 2002 and never returned to the Sheriffs Office. R. Thomas Kline, Sheriff, who being duly sworn according to law, says that after due and legal notice had been given according to law, exposed the within described premises at public venue or outcry at the Court House, Carlisle, Cumberland County, Pennsylvania, on June 5' 2002 at 10:00 o'clock A.M. He sold the same for the sum of $132,500.00 to Alan Ball and Kevin Craig. It being the highest bid and best price received for the same, Alan Ball and Kevin Craig of 6101 Westover Drive, Mechanicsburg, P A 17055, being the buyer in this execution paid SheriffR. Thomas Kline, the sum of$138,895.50. Sheriff s Costs: Docketing Poundage Posting Bills Advertising Acknowledging Deed Auctioneer Law Library Prothonotary Service $30.00 2650.00 15.00 15.00 30.00 10.00 .50 1.00 12.42 ;,~1fi?"q;'i"""""~. ,:,t I', ~ - ~ . "~ -.- -~ .-r-c- , , , 'f".' ~"~, ~ ~., r "' fl"fi1-<-c;.'~r:"'P'~~""~'''''''i "..; ~";~" ~'''' '" - ,~~ Certified Mail Levy Surcharge Legal Search Law Journal Patriot News Share of Bills Distribution of Proceeds Sheriff s Deed " 1.86 15,00 20.00 200.00 381.65 270.55 25.20 25.00 29.50 $3732.68 Sworn and subscribed to before me So Answers: ThisoLiJ""::'dayof~ .r-~~~ ~ ' R. Thomas Kline, Shenff 2002,A.D, ~ () ~~ rothonotary ( BNOd..t.{ '-)~ Real Estate Deputy "):i."~~h''''''",,,,,''''-'~_'''i.l:f~,J4l.1fI~; r"~",-, ,,".~~ 1 ,', ~ , ,". ?~ ?JO'lJU f1) \. c./o-31L{Pf fu,v. /'l.I'I,.l'J... "".,.,,.. -- "' I~.""'~~,,~ ~- 'TfT liT]!' WRIT OF EXECUTION andlor ATTACHMENT COMMONWEALTH OF PENNSYL VANIA) COUNTY OF CUMBERLAND) NO 01-7070 Civil CIVIL ACTION - LAW TO THE SHERIFF OF CUMBERLAND COUNTY: To satisfy the debt, interest and costs dne GMAC MORTGAGE CORPORATION, Plaintiff (s) From JOAN APPLETON,COST ANZA, 53 HONEYSUCKLE DRIVE, MECHANICSBURG, P A 17055 (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 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 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 lrim/her that he/she has been added as a garnishee and is enjoined as above stated, Amount Due $160,976,52 L.L. $.50 Interest FROM 3/12/02 TO SALE DATE AT $26.24 PER DIEM Atty's Comm % Atty Paid $105,85 Plaintiff Paid Date: MARCH 12, 2002 Due Prothy $1.00 Other Costs CURTIS R. LONG Prothonotary, Civil Division <.Bv: L2~# -Q ryOl/l~~(brE- REQUESTING PARTY: Name MARTHA E, VON ROSENSTIEL, ESQUIRE Address: 16 SOUTH LANSDOWNE AVENUE P,O,BOX 457 LANSDOWNE, PA 19050 Attorney for: PLAINTIFF Telephone: 610-623-2660 Supreme Court ill No, 52634 \~Y,;-N';:;~0"'w.~9l!R~, ,:_~ _, '"'"~ , .1-~' - " ~-, ~~F"~ ,~ ,-.-."".", ~~" ~ , ~ c'-,-- "I ~ '."~ ~_N,' e,. ,.-~-<>- """""'-l1'ii%r.'fi;JIfiilkt'ifj~rTr:1 r:(1f~D'j{:f':;~';j~;g;: Real Estate Sale #55 On March 15, 2002 the sherifflevied upon the defendant's interest in the real property situated in Silver Spring Township, Cumberland County, P A known and numbered as 53 Honeysuckle Drive, Mechanicsburg and more fully described on Exhibit "A" filed with this writ and by this reference incorporated herein. Date: March 15,2002 By: Real Estate Deputy ~ t::;ri1 c::;r;l ~ GV ~ " .\ (,1,\ 'io\ ::1''-' -0 \ ",,,:'" \,\'0; /, "', ,,", 'Ii 1\"" " , "' , ~\\ \ \ L \. 1\ \;I \ \\ 1~, \,;,:, ,"\',] .. c, ';~~~"\~jO J.1~i\\:,::, ~c) j,l\ "J\ll;\'" ~i~~~~~~"~If'l;';:r;N#.f!),'~Wf!i~'Y!:"j~'~'\!.~Jffiifi'~~'iW:ll'-%;m~m!'l".w~*"",,',,""''''Fc',,,~~,,,,/,,,~,~,,, - '.--.. --'-""-",,,;,:""'/.";,"', '~'" :"-~~'!"~'-~''''''i'tWtP;~l.ii!~!jmi!~~~JW\; ~!:l~'j'i(-_Jlf :[1': _ - ..', ,-, ., SCHEDULE OF DISTRIBUTION SALE NO. 55 Date Filed: July 5, 2002 Writ No. 2001,7070 Civil Term GMAC Mortgage Corporation VS Joan Appleton-Costanza 53 Honeysuckle Drive Mechanicsburg, P A 17055 Sale Date: Buyer: Bid Price: June 5, 2002 Alan Ball and Kevin Craig $132,500.00 Real Debt: Interest: Attorney Costs: $160,976.52 2,230.40 105.85 Total: $163,312,77 DISTRIBUTION Receipts: Cash on account (3/15/02): Cash on account (6/05/02): Cash on account (6/07/02): $ 1,000.00 13,250.00 125.645.50 Total Receipts: $139,895.50 ~~""l&o.", ". ,~. '_',"_" ~, _'1'. ' - '7~" . ~ - - ,,- , .. , " , ~'" ~..=.- r-:" " fW"' ,~ " " Disbursements: To Sheriff's Costs $3,532.68 To Legal Search 200,00 To State Realty Transfer Tax 1,772.75 To Local Realty Transfer Tax 1,772.75 To Silver Spring Township Authority (Writ No. 2001-4643 Civil) 1,325.39 To GMAC Mortgage Corporation 130,291.93 To Attorney Martha Yon Rosenstiel 1,000.00 Total Disbursement: Balance for Distribution So Answers: r~~--r R. Thomas Kline Sheriff C',7iiiW'''ii;J1''.'''*'~,ll!IilI,~_..,~, " ;--,,,"-1' , , ($139.895.50) $ 0.00 - ~"" U" ~" r-- ;ik" '-"'''('''''''-'1'' -'-"'~-," "111""'''''''-' ,'" -~-" .~ , TITLE REPORT THE PREMISES ENDORSED HEREON ARE SUBJECT TO THE FOLLOWING ITEMS, WmCH WILL BE EXCEPTED IN THE POLICY UNLESS SATISFACTORY EVIDENCE PERMITTING THEIR REMOVAL IS PRODUCED. SHERIFF SALE NO. 55 Held Wednesday, June 5, 2002 Date: June 5, 2002 TAXES: Receipts for all taxes for the years 1999 to 2001 inclusive. Taxes for the current year 2002, WATER RENT: SEWER RENT Company assumes no liability for private supply of water or sewer. Receipts to be produced if services are lienable. MECHANICS' AND Possible unfiled Mechanics Liens and Municipal Claims. MUNICIPAL CLAIMS MORTGAGES: Listed Under Other Exceptions Below. JUDGMENTS: Listed Under Other Exceptions Below. INSTRUMENTS TO BE PRODUCED: Deed from Cumberland County Sheriff to dated , 2002, and recorded , 2002, in Cumberland County Deed Book , Page RECITAL: BEING the same premises which Frank J. Costanza, married person, by deed dated August 21, 1995 and recorded August 25,1995 in the Office of the Recorder of Deeds in and for Cumberland County at Carlisle, Pennsylvania, ill Deed Book 127, Page 164, granted and conveyed to Joan Appleton Costanza, married person. OTHER EXCEPTIONS: I, The identity and legal competency of parties at the closing of this title should be established to the satisfaction of the closing attorney acting for this Company. 2. Rights or claims of parties in possession, if any, other than the owner. 3, Unrecorded easements, discrepancies or conflicts in boundary lines, shortage in area and encroachments which an accurate and complete survey would disclose. 4, Payment of State and local Real Estate Transfer Taxes, if required. 5, Public and private rights in the roadbed of Honeysuckle Drive. 6. Conditions, easements and restrictions shown on or set forth on the Final Subdivision Plan for Mulberry Crossing, Section Three, Wynnewood West Development Company, recorded in Plan Book 49, Page 11 L 7. Building and use conditions and restrictions set forth in the Declaration of Wynnewood West Deveopment Company recorded in Miscellaneous Record Book 308, Page 260. ~""ii"F-~'\%;' -- ~ ,,< ., ^ ~I'-o', " ,',~,~, -'<-- ,.,," " l~ "''''''''':-''l'f'T~TI^ - _'1. ~., -, '" ~'. " " ,', 8. Rights granted to West Shore TV Cable by instrument recorded in Miscellaneous Record Book 271, Page 741. 9. Rights granted to Sammons Communications by instrument recorded in Miscellaneous Record Book 314, Page 268. 10, Rights granted to Pennsylvania Power & Light Company and the Tell Telephone Company of Pennsylvania by instrument recorded in Miscellaneous Record Book 317, Page 124, 11. Mortgage in the amount of $132,000 given by Joan Appleton-Costanza to PHH US Mortgage Corp, dated August 21, 1995 recorded August 25, 1995 in the Office of the Recorder of Deeds in Mortgage Book 1278 Page 673. Said mortgage was assigned to Cap stead Inc. by assignment recorded January 2, 1997 in Miscellaneous Record Book 543, Page 624. Then assigned to GMAC Mortgage Corp. by assignment recorded February 16, 1999 in Miscellaneous Record Book 616, Page 1061. Complaint in mortgage foreclosure filed by GMAC Mortgage Corp. as Plaintiff against Joan Appleton-Costanza as Defendant on December 17,2001 in the office of the Prothonotary of Cumberland County to File No.O 1,7070, Default judgment entered March 12,2002 in the amount of $160,976.52. Chapter 13 Bankruptcy File # 01,01564 RJW. 12. Mortgage in the amount of $25,775 given by Joan Appleton-Costanza to Premier Bank dated December 28, 1995 recorded January 11, 1996 in Mortgage Book 1298, Page 1186. Said Mortgage was assigned to Eastern Mortgage Service, Inc. by assignement recorded December 28, 1995 in Miscellaneous Record Book 511, Page 986. Then assigned to Monogram Home Equity Corp. by assignment recorded March 27, 1996 in Miscellaneous Record Book 522, Page 126. Then assigned to Ford Consumer Finance Co., Inc. by assignment recorded October 23, 1996 in Miscellaneous Record Book 545, Page 253. 13, Mortgage in the amount of $11,618.08 given by Joan Appleton Costanza and Frank Costanza to Ford Consumer Finance Company, Inc. dated April 12, 1997 recorded April 16, 1997 in the Office of the Recorder of Deeds in Mortgage Book 1375, Page 585. 14. Mortgage in the amount of $25,000 given by Joan Appleton Costanza and Frank J. Costanza to Commerce Bank/Harrisburg N.A., dated October 9, 1998 and recorded October 22, 1998 in the Office of the Recorder of Deeds in Mortgage Book 1491, Page 102. Complaint in mortgage foreclosure filed by Commerce Bank/Harrisburg N.A. as Plaintiff against Frank J. Costanza and Joan Appleton Costanza as Defendants on March 2, 200 I in the office of the Prothonotary of Cumberland County to File No. 01-1209, No judgment entered. 15. Certified copy of lien in the amount of $108.14 entered by the Pennsylvania Bureau of Compliance as Plaintiff against Joan A. Costanza. address 53 Honeysuckle Drive. as Defendant on January 3, 2001 in the Office of the Prothonotary of Cumberland County to file No 01-56. "~~',"';'"",. ".' -"' '1,','" ~" . '~d r ~I"'l'~'" cnr Ii J HI :'4~~~'t~<<;,"" .' 16. Municipal lien in the amount of $1,325.39 entered by Silver Springs Township Authority as Plaintiff against Joan Appleton Costanza as Defendant on August 2, 2001 in the office of the Prothonotary of Cumberland County to File No. 01-4643. 17. Satisfactory evidence to be produced that proper notice was given to holders of all liens and encumbrances intended to be divested by subject Sheriff Sale. 18. Satisfactory evidence to be produced that the advertisement of the property for sale is satisfactory in spite of the absence of any reference to the improvements on the subject property. 19. Satisfactory evidence to be produced that Jean Ann Costanza, Joan Appleton Costanza, Joan Appleton Constanza, Joan Appleton-Costanza and Joan Appleton Jones are one in the same person or that Frank 1. Costanza and Jean Ann Costanza were divorced prior to August 21, 1995 and that Frank 1. Costanza subsequent to August 21, 1995 married Joan Appleton Costanza and which marriage has not been terminated. 20. Real estate taxes accruing on and after July 1,2002 not yet due and payable. It is to be noted that no search of Domestic Relations Records has been made to determine support arrearages regarding Honse Bill 1412, Act 58 of 1997, nor has any search been made for environmental liens in Federal District Court. A. 7-0 Robert G. Frey, Agent Note: This Title Report shall not be valid or binding until countersigned by an authorized signatory. 0_, ~, . .'. "~ __=,'~,. _ ,_ ,',,".,~ _ , "~ "1'~ ';f'&>":i1j{O:",;' "'~"> "-',,". '. ,,,,',,, - -"".",.." / , 6 'S0- ~........~--- - REAL,ESTATE SALE NO. 55 f Writ No. 2001-7070 Civil GMAC Mortgage Corporation vs, 11 Joan ~ppietOl{Constanza I lJ Atty."Martha E, Van ,~osenstiel DESCRIPTION', .. AIL TIfAT CERTAIN piece orpar- eel of land situate In SUver Spring Township. Cumberland County, (er- roneously referred to in pIior .deed as Dauphin County) Pennsylvania. as set forth on a Final Subdivision Plan for Mulberry Crossing, Section 47 hnlnJ --':-~..~' ---''':'._,"_..,.,..."--~''';,;~, <';B).'FO-"".,'<$~ U..",="'~."~ .,.. ---"",,""'",~", ."" ~ :, i : , ZJJ- CUMBERLAND LAW JOURNAL Three. Wynnewood West Develop- ment CompanY1 as prepared by Ganett Fleming ClvU Engineers. Inc.. and recorded in the Recorder of Deeds Office of Cumberland Coun- ty, Pennsylvania. in Plan Book 49. Page Ill. and more particularly bounded and described as follows. to wit: BEGINNING at a point on the ", rlght'of-way line of Honeysuckle Drive at the dividing line between Lots Nos, 167 and 168 as shown on the aforementioned Subdivision Plan; thence along said right-of-way line of Honeysuckle Olive by a curve to the left having a radius of 175,00 feet. an arc distance of 59.50 feet with a chord beating North 52 de- grees 18 minutes 24 seconds East. a distance of 159,11 feet to a point at the dividing line between Lots Nos, 168 and 169; thence along same South 47 degrees 39 minutes 2 seconds East 151.40 feet to a point; thence South 25 degrees 16 minutes 2 seconds West a distclnce of 63.36 feet to a point at the divid, Ing !lne be_en Lots Nos, 168 and 154; thence along same South 79 degrees 20 minutes 46 seconds West, a distance of 60.77 feet to a point at the dividing line between Lots Nos, 168. 154 and 167; thence along the dividing !lne between Lots Nos, 168 and 167 North 28 degrees 10 minutes 12 seconds West, a dis- " tance of 152.17 feet to a point, the place 'of beglnnlng. BEING Lot No, 168 on the afore- mentioned Final Subdivision Plan for Mulberry Crossing. Section Three. Wynnewood West Develop- ment Company. CONTA1N1NG 14.159 square feet. more or less. UNDER AND SUBJECT to set- back lines. easements and condt~ " ~&, ()V\~1uV\Zt^-- ,.,~ "-", . tions as shown on the aforemen- tioned Final Subdivision Plan and restrictions and conditions as set forth in the Declaration of Wynne- wood West Development Company that is recorded in Cumberland County Miscellaneous Book 308. Page 260, , ' Tax Parcel #38-22-0144-118. t o t: 48 I ~ ~, ""'" -";!-"'-',": ~-""=:,~'Jr~--~' ,,~- <,,,-- , . & ~0- Martha E. Von Rosenstiel, P.C. Martha E. Von Rosenstiel 16 South Lansdowne Avenue P.O. Box 457 Lansdowne, PA 19050 610623-2660 Attorney LD.# 52634 Attorney for Plaintiff GMAC Mortgage Corporation 500 Enterprise Road Horsham P A 19044-0963 COURT OF COMMON PLEAS CUMBERLAND COUNTY Plaintiff vs. Joan Appleton-Costanza 53 Honeysuckle Drive Mechanicsburg, P A 17055 Defendants No: 01,7070-Civil Term AFFIDAVIT OF NOTICE PURSUANT TO RULE 3129,1 COMMONWEALTH OF PENNSYLVANIA: SS COUNTY OF DELAWARE MARTHA E. VON ROSENSTIEL, attorney for the plaintiff in the above action, sets forth as of the date the praecipe for the Writ of Execution was filed the following information concerning the real property located at 53 Honeysuckle Drive, Mechanicsburg, P A 17055. I, Name and address of owners(s) or reputed owner(s) Joan Appleton-Costanza 53 Honeysuckle Drive Mechanicsburg, P A 17055 2. Name and address of defendant(s) in the judgment: Joan Appleton-Costanza 53 Honeysuckle Drive Mechanicsburg, P A 17055 3. Name and address of every judgment creditor whose judgment is a record lien on the real property to be sold: NONE 4. Name and address of the last recorded holder of every mortgage of record: ';"<<""'-'l,"('-'~,.-"~"""",,,,,,, ":' ~ " ["'~ ~ ,~ . ,~- - .~ '!!- eo , ....~~~..., "f"''''-.--'~~ ;,~'\:^~-'r"'~.:.-': ""~' ,..-/:~"'. - .,.,~,~"," ,-'- '. ", Ford Consumer Finance Co" lnc, 11311 Cornell Park Dr., Ste. 300 Cincinnati, OH 45242 Ford Consumer Finance Co., lnc. 3220 Tillman Dr., Ste. 101 Bensalem, P A 19020 Commerce Bank NA 100 Senate Ave. P.O, Box 8599 Camp Hill, PA 17011 5, Name and address of every other person who has any record lien on the property: 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: NONE 7. Name and address of every other person of whom plaintiff has knowledge who has any interest in the property which may be affected by the sale: Family CourtlDomestic Relations Office One Courthouse Square Carlisle, PA 17013 Dept. of Public Welfare Box 2675 Harrisburg, P A 17l 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. Section 4904 relating to unsworn falsification to authorities. / Martha E. Yon Rosenstiel Attorney for Plaintiff / -"~,-",.,",,,,~,'--"~--" ,.,:,", _ J_l,~,_~, > I" , . . _ r ._~ _. m, { I~' '1 .~"'" '.oK" "Cir--"!""ill!"j ""'~~~,," "-~,',,', ,~--,''''~- Martha E. Von Rosenstiel, P.C, Martha E. Von Rosenstiel 16 South Lansdowne Avenue P,O. Box 457 Lansdowne, PA 19050 610 623-2660 Attorney LD,# 52634 Attorney for Plaintiff GMAC Mortgage Corporation 500 Enterprise Road Horsham, PA 19044-0963 COURT OF COMMON PLEAS CUMBERLAND COUNTY Plaintiff vs. Joan Appleton-Costanza 53 Honeysuckle Drive Mechanicsburg, P A 17055 Defendant No: 01-7070-Civil Tenn THIS IS AN ATTEMPT TO COLLECT A DEBT ANY INFORMATION OBTAINED WILL BE USED FOR THAT PURPOSE NOTICE OF SHERIFF'S SALE OF REAL PROPERTY TO: Joan Appleton-Costanza 53 Honeysuckle Drive Mechanicsburg, P A 17055 Your house and/or real estate at 53 Honeysuckle Drive, Mechanicsburg, P A 17055 is scheduled to be sold at Sheriffs Sale on June 5, 2002 at 10:00 a.m. to enforce the court judgment of$160,976.52 obtained by GMAC Mortgage Corporation against you. NOTICE OF OWNERS 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 GMAC Mortgage Corporation the back payments, late charges, costs and reasonable attorney's fees due. To find out how much you must pay, you may call 610 623,2660. 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. -':~(},t"'"'--';<:''~''''':''''' ,"~~, J ~, F, ,"," ~ ,-, " 'I, "",~ "1"'""""~ '-"A""Jtht'l~~r" .~~",^~~~. - ~,. , You may contact 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) YOU MAY STILL BE ABLE TO SAVE YOUR PROPERTY AND YOU HAVE OTHER RIGHTS EVEN IF THE SHERIFF'S SALE DOES TAKE PLACE. 1. Ifthe Sheriff's Sale is not stopped, your property will be sold to the highest bidder. You may fmd out the bid price by calling 610 623-2660. 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 the 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 610 623-2660. 4. Ifthe 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 a 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 on a date to be announced by the Sheriff. 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 Schedule of Distribution is posted. 7. You may also have other rights and defenses, or ways of getting your house back, if you act immediately after the sale. YOU SHOULD TAKE THIS PAPER TO YOUR LAWYER AT ONCE. IF YOU DO NOT HAVE ALA WYER OR CANNOT AFFORD ONE, GO TO OR TELEPHONE THE OFFICE LISTED BELOW TO FIND OUT WHERE YOU CAN GET LEGAL HELP. ' COURT ADMINISTRATOR 4TH FLOOR CUMBERLAND COUNTY COURT HOUSE CARLISLE, PA 17013 Telephone: 717 240-6200 "'r-",,~",,~j'<;f-<',""O;~", "-',~ "', ,'" --"':,,, ,'"c ~ . 'I" _"'1,',- , "",,,,,- ,~"""",,"'i(;';;U ~~r"~'" - /E ~",-:"'1'" . -'~"- '. CLAIM FOR EXEMPTION To the Sheriff: I, the above named defendant, claim exemption of property from levy or attachment: (1) From my real property in my possession which has been levied upon, (a) I desire that my $300.00 statutory exemption be set-aside in kind (specify real property to be set-aside in kind): I request a prompt court hearing to determine the exemption. Notice of the hearing should be given to me at (Address) (Telephone Number) I verify that the statements made in this Claim for Exemption are true and correct. I understand that false statements herein are made subject to the penalties of 18 Pa. C.S, Section 4904 relating to unsworn falsification to authorities. Date: Signature THIS CLAIM TO BE FILED WITH THE OFFICE OF THE SHERIFF CUMBERLAND COUNTY COURTHOUSE CARLISLE, PA 17013 717 240-6391 %"""wr""i7"';"''',~_,,~, _ ",--,.. .. ~~- .- - ~v' --"" ,~ , """""'~ .!ll,'~~ c."~"';'; .'1>:' , , : ~ '''J WRIT OF EXECUTION _ (MORTGAGE FORECLOSURE) P,R.C.P, 3180 to 3183 and Rule 3257 GMAC Mortgage Corporation IN THE COURT OF COMMON PLEAS OF CUMBERLAND COUNTY, PENNSYL VANIA VS, No. OI-7070,Civil Term No, Term, 20_ _ _ ,E.D. Term, 20-_ _ ,A.D. Joan Appleton-Coztanza WRIT OF EXECUTION (MORTGAGE FORECLOSURE) Commonwealth of Pennsylvania: County of TO THE SHERIFF OF CUMBERLAND COUNTY, PENNSYLVANIA: To satisfy the judgment, interest and costs in the above matter you are directed to levy upon and sell the following described property (specifically describe property below): PREMISES: 53 Honeysuckle Drive Mechanicsburg, P A 17055 Amount Due $ 160,976,52 Interest from 03/13/02 to Sale Date @ $26.24 per diem Attorney's fees Total $ $ $ $ Costs as endorsed, Dater! Prothonotary, Common Pleas Court of Cumberland County, Penna, (SEAL) By: Deputy "'j;'"0'~'''':F''''J_,~ ,,", , 1" , ~ ,-"'- "",111 ~~~ i-~~~,''l'_':' '! ':--:'["~": , , DESCRIPTION ALL THAT CERTAIN piece or parcel of land situate in Silver Spring Township, Cumberland County, (erroneously referred to in prior deed as Dauphin County) Pennsylvania, as set forth on a Final Subdivision Plan for Mulberry Crossing, Section Three, Wynnewood West Development Company, as prepared by Ganett Fleming Civil Engineers, Inc., and recorded in the Recorder of Deeds Office of Cumberland County, Pennsylvania, in Plan Book 49, Page III, and more particularly bounded and described as follows, to wit: BEGINNING at a point on the right-of-way line of Honeysuckle Drive at the dividing line between Lots Nos. 167 and 168 as shown on the aforementioned Subdivision Plan; thence along said right- of-way line of Honeysuckle Drive by a curve to the left having a radius of 175.00 feet, an arc distance of 59,50 feet with a chord bearing North 52 degrees 18 minutes 24 seconds East, a distance of 159.11 feet to a point at the dividing line between Lots Nos. 168 and 169; thence along same South 47 degrees 39 minutes 2 seconds East 151.40 feet to a point; thence South 25 degrees 16 minutes 2seconds West a distance of 63.36 feet to a point at the dividing line between Lots Nos. 168 and 154; thence along same South 79 degrees 20 minutes 46 seconds West, a distance of 60.77 feet to a point at the dividing line between Lots Nos. 168, 154 and 167; thence along the dividing line between Lots Nos. 168 and 167 North 28 degrees 10 minutes 12 seconds West, a distance of 152.17 feet to a point, the place of beginning. BEING Lot No, 168 on the aforementioned Final Subdivision Plan for Mulberry Crossing, Section Three, Wynnewood West Development Company. CONTAINING 14,159 square feet, more or less, UNDER AND SUBJECT to setback lines, easements and conditions as shown on the aforementioned Final Subdivision Plan and restrictions and conditions as set forth in the Declaration of Wynnewood West Development Company that is recorded in Cumberland County Miscellaneous Book 308, Page 260, Tax Parcel # 38,22-0144-118 ".:"',R~~,,,,,,,,,,,,,,,,",,, .~'" T , ,,' "'.""" , ~ r'"'''''" '~r~~~' ,l!!Il .... .REAtESTATESALE No. 55 _. co, WrttNo,2001,7070 ~ ~r -~: ",.... -'}-:;-~:<,'Clvilferm -' ,'., GMAC Mortgage Corp. :::: - ".. "'5 "., ~~A~,~~;~~~nz. ,_ ~RoaenstJel ~,ut.:)wufl[ON . ~ CER1'AJNP'i~cc,otParceloflandsitu3te . 'er Spring Town5hfp,~Ctiniberland County_ refeifcd to ~)1rior deed as Dauphin enn~ylvania, tJ,' set forth on a Final Plan ror~MOJiferi:y -Crossing, Section =' ~~ ynn,ewoooWestl)_evelopmenfCom~any,as ~lip~d by aannelt F1ciiling Civil Engineers, Inc., ~r@tde)i in the Recorder of DeeIh Office of ~CU~rJand County, Pennsylvanijl, in Plan Book 49, -~ .Page li, and' rno~_ particularly bounded and aescribed asJoUows, Ii.l wit: 1lEGIRNING' at a point on the right-or.way line of .Honeysuckle Driye l!-t the dividmg line betweenwts JSQs.J67 and 168 as shown on the aforementioned =Suuaf~isiOti Plan;{hence aloi1g said right-or-way line ""'"of Honeysuckle Drive by a curve to the left having a "radius__oJ 175.00 feet, an arc distance of 59.50 feet -,VilliiClioro bearirtg North 51 degrees 18 minutes 24 :$g:sJn.dsEas~ a distance of 159.11 fretta a point at __,tliLdlviilfugliiie--bctweenD:ifSNos-, 168 and 169; ~t1lepQu!long, same Spath ,~7 degrees 39 minutes 2 ~tds East 151.40 feet to a (}Omt thence South 25 naegree(16 minutes 2 ~econds West a distance of 63.16Jeettoa point at the dividing 1ine between Lots _ ~os.,)68 and 154; thence along same South 79 ~cie~~2~ miqut~s 4.6u~o!1ilS Wes~ a distance of -00;77 fret to ii pOrnrafthe diVidrrig1indi~tween Lots _ 'I'(os.16&,154and167;thencealonglhedividingline ~1:Xitween Lots, Nos. 168 and 167 North 28 degrees 10 IDirijI[es12 secondsWesl,::" distance of 152.17 feet to ,;, .~pm--=m;-the place ofBEGIKNING. ~BElNG Lot No. 168 on the aforementioned Final ~isililfPlan,forMy1bt:rryCrossing,Section "'Three., Wynnewood \Vest Development Company. ~tQlITA.JNINGli-,159 square feet, more ot less. ~~~AJi(D .SliBJECT to_-setback lines; eaSements ~and,cQnditi9l1S.asshownontheaforemenTIOlfedFinal d,uhdi\(j,siQjtet~\lll.andrestrictionsimd-conditionsas ~~otlhJn .the Declaration of Wynnewood \V~ ~ DeVelopment Company that is'" recorded in i:- ~rl1l!ldp:ninty'MisceUaneous Book 308, Page 1"'"2.llL_" . ~,TAX PARCElJ,!o,,38,22,Ol44-118, -~ ~ lJ , ,~ THE PATRIOT NEWS THE SUNDAY PATRIOT NEWS Proof of Publication Under Act No. 587, Approved May 16,1929 Commonwealth of Pennsylvania, County of Dauphin} ss Frank J, Epler being duly sworn according to law, deposes and says: That he is the Controller of The Patriot News Co., a corporation organized and existing under the laws of the Commonwealth of Pennsylvania, with its principal office and place of business at 812 to 818 Market Street, in the City of Harrisburg, County of Dauphin, State of Pennsylvania, owner and publisher of The Patriot, News and~ Sunday Patriot,News newspapers of general circulation, printed and published at 812 to 818 Market Street, in the City, County and State aforesaid; that The Patriot,News and The Sunday Patriot'News were established March 4th, 1854, and September 18th, 1949, respectively, and all have been continuously published ever since; That the printed notice or publication which is securely attached hereto is exactly as printed and published in their regular daily and!or Sunday! Metro editions which appeared on the 23rd and 30th day(s) of April 2002 and the 7th day(s) of May 2002, That neither he nor said Company is interested in the subject matter of said printed notice or advertising, and that all of the allegations of this statement as to the time, place and character of publication are true; and That he has personal knowledge of the facts aforesaid and is duly authorized and empowered to verify this statement on behalf of The Patriot,News Co. aforesaid by virtue and pursuant to a resolution unanimously passed and adopted severally by the stockholders and board of directors of the said Company and subsequently duly recorded in the office for the Recording of Deeds in and for said County of Dauphin in Miscellaneous Book "M", Volume 14, Page 317, PUBLICATION COpy SALE #55 A.D. Notarial Seal Teny L. Auss~lI, Nolall' Public Harrisburg, Oauphin County Y PUBLIC My C,ommlsslon E~pires June 6. 2002 commission expires June 6, 2002 Member, Pennsylvania Assooialion 0' Notaries CUMBERLAND COUNlY SHERIFFS OFFICE CUMBERLAND COUNlY COURTHOUSE CARLISLE, PA. 17013 Statement of Advertising Costs To THE PATRIOT-NEWS CO., Dr. For publishing the notice or publication attached hereto on the above stated dates $ Probating same Notary Fee(s) $ Total $ 268,80 1.75 270.55 Publisher's Receipt for Advertising Cost , ,The Patriot News Co" publi~her of The Patriot, News and The Sundav Patriot-News, newspapers of general Circulation, hereby acknowledge receipt of the aforesaid notice and publication costs and certifies that the same have been duly paid. By.,.""".,.,.,.,.".,.,..........,.,.,.,.,......................... @'iltf''''I'''c'''''''"'-''~'''''''i,'~~ . ~_,_ "~ _ '!:'" r' ,~ '11~"! ,,., t,. REAL ESTATE SALE NO. 55 Writ No. 2001-7070 Civil GMAC Mortgage Corporation VS, Joan Appleton-Constanza Atty.: Martha E. Von Rosenstiel DESCRIPTION ALL THAT CERTAIN piece or par- cel of land situate in SUver Spring Township, Cumberland County, (er- roneously referred to in prior deed as Dauphin County) Pennsylvania, as set forth on a Final Subdivision Plan for Mulbeny Crossing, Section Three. Wynnewood West Develop- ment Company, as prepared by Gallet! Fleming Civil Engineers. Inc" and recorded in the Recorder of Deeds Office of Cumberland Coun- ty. Pennsylvania, in Plan Book 49. Page III. and more particularly bounded and described as follows. to wit: BEGINNING at a point on the right-of-way line of Honeysuckle Drive at the dividing line between Lots Nos, 167 and 168 as shown on the aforementioned Subdivision Plan; thence along said right-of-way line of Honeysuckle Drive by a curve to the left having a radius of 175.00 feet. an arc distance of 59.50 feet with a chord bearing North 52 de- grees 18 minutes 24 seconds East, a distance of 159.11 feet to a point at the dividing line between Lots Nos. 168 and 169; thence along same South 47 degrees 39 minutes 2 seconds East 151.40 feet to a point; thence South 25 degrees 16 minutes 2 seconds West a distance of 63.36 feet to a point at the divid- ing line between Lots Nos. 168 and 154: thence along same South 79 degrees 20 minutes 46 seconds West. a distance of 60.77 feet to a point at the dividing line between Lots Nos. 168, 154 and 167; thence along the dividing line between Lots Nos. 168 and 167 North 28 degrees 10 minutes 12 seconds West. a dis- tance of 152.17 feet to a point, the place of beginning. BEING Lot No, 168 on the afore- mentioned Final Subdivision Plan for Mulberry Crossing, Section Three, Wynnewood West Develop- ment Company. CONTAIN1NG 14.159 square feel. more or less. UNDER AND SUBJECT to set- back lines, easements and condi- tions as shown on the aforemen- tioned Final Subdivision Plan and restrictions and conditions as set forth in the Declaration of Wynne- wood West Development Company that is recorded in Cumberland County Miscellaneous Book 308. Page 260, Tax Parcel #38-22-0144-118. i)~ ',0 _';"'" ' "'~ ,,~~\; ;,,;;~,",~r~~.G ,",~.~ - ",",,~ . 'o'?].:~,~- -'- ~ ' ,-.?-."<~>:;::~~ ". ~ :;,. -.~...., ,-- , 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. Morgenthal, Esquire, Editor of the Cumberland Law Journal, ofthe County and State aforesaid, being duly sworn, according to law, deposes and says that the Cumberland Law Journal, a legal periodical published in the Borough of Carlisle in the County and State aforesaid, was established January 2, 1952, and designated by the local courts as the official legal periodical for the publication of all legal notices, and has, since January 2, 1952, been regularly issued weekly in the said County, and that the printed notice or publication attached hereto is exactly the same as was printed in the regnlar editions and issues of the said Cumberland Law Journal on the following dates, V1Z: APRIL 26, MAY 3,10,2002 Affiant further deposes that he is authorized to verify this statement by the Cumberland Law Journal, a legal periodical of general circulation, and that he is not interested in the subject matter ofthe aforesaid notice or advertisement, and that all allegations in the foregoing statements as to time, place and character of publication are true. r-- /~ Rogdr M. Morgenthal, Editor SWORN TO AND SUBSCRlBED before me this 10 day of MAY. 2002 NOT~ LOIS E. SNY!:lER, No!lIIy PublIc CIIrIlsIe Boro. ~ County My CommIsaion Expires March 5, 2005 ":~U ""~'''' ,___",_,,__, ., "-1"' :- ,,"~"'1 ~ - ~, ~- - .,~ ~~,~~~~~'"', ~'I"='r.~.-- _ '."1""~~"''='_