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HomeMy WebLinkAbout01-07075 ii" IN THE COURT OF COMMON PLEAS OF CUMBERLAND COUNTY, PENNSYLVANIA NATIONAL CITY MORTGAGE CO., CIVIL DIVISION ( ~ NO. 01- 7tY1S C~utl 1fUJ...~ Plaintiff, COMPLAINT IN MORTGAGE FORECLOSURE vs, MICHELE L. GRAFF and KIMBERLY L. HILEMAN, both unmarried, Code MORTGAGE FORECLOSURE Defendants. Filed on behalf of Plaintiff Counsel of record for this party : Louis P. Vitti, Esquire PA LD. #3810 Supreme Court #01072 Louis P. Vitti & Assoc., P.C. 916 Fifth Avenue Pittsburgh, PA I5219 (412) 281-1725 '~":"; ::":'":? ,'//d;;', ,"', -L,;, !;,;';.:-:< c__-,,:.<;,:::>:,:.:;.)):g::~<'t!-:';~--'7,>~ /j:" ,j;;;;' ,I" " ,d, 'd",,'/;~~,;'d,L:, ~ -- '-' -,- -i.C'::' '~"""":-><:'-'," - d, I: " -',;';"', ,-- :' . ' COMPLAINT IN MORTGAGE FORECLOSURE NOTICE 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 THE ATTORNEY AND FILING IN WRITING WITH THE COURT YOUR DEFENSES AND OBJECTIONS TO THE CLAIMS SET FORTH AGAINST YOU. YOU ARE WARNED THAT IF YOU FAIL TO DO SO THE CASE MAY PROCEED WITHOUT YOU AND A JUDGMENT MAY BE ENTERED AGAINST YOU BY THE COURT WITHOUT FURTHER NOTICE FOR ANY MONEY CLAIMED IN THE COMPLAINT OR FOR ANY OTHER CLAIM OR RELIEF REQUESTED BY THE PLAINTIFF. YOU MAY LOSE MONEY OR PROPERTY OR OTHER RIGHTS IMPORTANT TO YOU. YOU SHOULD TAKE THIS PAPER TO YOUR LAWYER AT ONCE. IF YOU SHOULD 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 BAR ASSOCIATION 2 LIBERTY AVENUE CARLISLE, PA 17013 (717) 249-3166 z;,>j;~~:__n ~ - ";,''::;,.,:_ '. -:(~";',~':~:4,:)i"~;:,:i;~~~,t~~jl;-:;\:~-:~L:~,::~: ,,';~;;;i,j!/_t,'''';'F ""I", . '.... "".,' ".z..,!.;',C ""';"';"; ,.,.c",;tC;,.:;.,.'.".,.".' ,"-~ - :'I:~:~- , r= 1 . COMPLAINT TN MORTGAGE FORECLOS1JRE AND NOW, comes the Plaintiff by its attorneys, Louis P. Vitti and Associates, P.C. and Louis P. Vitti, Esquire, and pursuant to the Pennsylvania Rules of Civil Procedure Numbers 1141 through 1150, for its Complaint in Mortgage Foreclosure, sets forth the following: 1. The Plaintiff is a corporation duly authorized to conduct business within the laws of the Commonwealth of Pennsylvania, having a principal place of business located at 3232 Newmark Drive, Miamisburg, OH 45342. 2. The Defendant(s) is/are individuals with a last known mailing address of 924 Alexander Spring Road, Carlisle, PA 17013. The property address is 924 Alexander Spring Road, Carlisle, PA 17013 and is the subject of this action. 3, On the 29th day of February, 2000, in consideration of a loan of One Hundred Nineteen Thousand, Nine Hundred Thirty-Nine and No/100 ($119,939.00) Dollars made by National City Mortgage Co., an OH corporation, to Defendant(s), the said Defendant(s) executed and delivered to National City Mortgage Co., an OH corporation, a "Note" secured by a Mortgage with the Defendant(s) as mortgagor(s) and National City Mortgage, as mortgagee, which mortgage was recorded on the 2nd day of March, 2000, in the Office of the Recorder of Deeds of Cumberland County, in Mortgage Book Volume 1598, page 809 and re-recorded on the 24th day of October, 2000 in the Office of the Recorder of Deeds of Cumberland County, in Mortgage Book Volume 1647, page 97. The said mortgage is incorporated herein by reference thereto as though the same were set forth fully at length. 4. The premises secured by the mortgage are: See Schedule "A" attached hereto. "'-~~~~~--, ! '-,,",'"-,"', -- g '-.-',-- ';-,,.-- ; ;-,,_,')i; ,,~,_".c., ',_";~<:,^, " -;::;-';,>;)-,';':-:-> " r "::'---,<--: " '-j-,- ." ,~ 1 :Ji ,~ 'w 5. Said mortgage provides, inter alia: "that when as soon as the principal debt secured shall become due and payable, or in case default shall be made in the payment of any installment of principal and interest, or any monthly payment, keeping and performance by the mortgagor of any of the terms, conditions or covenants of the mortgage or note, it shall be lawful for mortgagee to bring an Action of Mortgage Foreclosure, or other proceedings upon the mortgage, of principal debt, interest and all other recoverable sums, together with attorney's fees." 6. Since July 1, 2001, the mortgage has been in default by reason, inter alia, ofthe failure of the mortgagor(s) to make payments provided for in the said mortgage (including principal and interest) and, under the terms of the mortgage, the entire principal sum is due and payable. 7. In accordance with the appropriate Pennsylvania Acts of Assembly and the Pennsylvania Rules of Civil Procedure, the mortgagor(s) has been advised in writing of the mortgagees intention to foreclose. The appropriate time period has elapsed since the Notice ofIntention to Foreclose has been served upon the mortgagor(s). 8. The amount due on said mortgage is itemized on the attached schedule. 9. Plaintiff does hereby release the personal representative, heir and/or devisee of the mortgagor(s) from liability for the debt secured by the mortgage. WHEREFORE, pursuant to Pennsylvania Rule of Civil Procedure Number 114 7( 6), Plaintiff demands judgment for the amount due of One Hundred Thirty-Five Thousand, One Hundred Forty-Six and 29/100 Dollars ($135,146.29) with interest and costs. Respectfully submitted, LOUIS P. VITTI & ASSOC., P.C. BY ~~ Louis P. Vitti, Esquire Attorney for Plaintiff :'~f:<"','!lit'l -,-" ,'-- ""-,-,-- <:,",~~;.'~',~ ::~:~;'1"!<<-- '::J!F, ,~ - , , "7,-. ,---"";",;-:,-:,.;::,, 'I" :-':"";-';:'-",-: ~- :-",:'~ .:' ,- : --~-" - -,,-c',_, ,., -"<,',1".-:;?.;",,:--,,' :'_i:,_~:;;;,,>:--:i< _~ ". ,'"10.,';," - , "J: . , , ' MICHELE C. GRAFF SCHEDULE OF AMOUNTS DUE UNDER MORTGAGE Unpaid Principal Balance 118,445.74 Interest@ 7.2500% from 06/01/01 through 12/3112001 (Plus $23.5269 per day after 12/31/2001 ) 5,011.23 Late charges through 12/13/2001 o months @ 40.23 Accumulated beforehand (Plus $40.23 on the 17th day of each month after 394.87 12/13/2001 ) Attorney's fee 5,922.29 Escrow deficit 5.372.16 (This figure includes projected additional charges that may be incurred by the Plaintiff and transmitted to the sheriff as charges on the writ prior to the date of the sheriff's sale) BALANCE DUE 135,146.29 "'C'~"",!"'__f,__," "-,"" ~::;;:;-',,\;,:: "Y.\,,,,coj-\\';'if-""" co>, ~:};;';;~'r}~-J~: ..1 ' -''-:;:L'-:;--~, .>i~;?;<:)'<; ;::;':.'rDi;'-<<;:,:,,);,_'__-: -. I.:, ',- . . , , e e e EXHIBIT "/1.:' . Legal Description 924 Alexander Spring Road Carllale PA 17013 Au.. THAT CERTAIN tract of land situate in Dickinson Township, Cumberland County, Pennsylvania, more particularly bounded and described In accordance with a survey by Stephen C. FIsher, R,$" dated November 4, 1976 (revised), as follows: , BEGINNING at an Iron pine on the northern dedicated right-of-way line of the Alexander Sprlng Roael IT 467), a 33-foct right.Qf-way, llaid iron pin being also at the southeast comer of Lot No.6 oHhe hereinafter mentioned Plan of Lota; thence along the dividing line of Lots No.5 and 6, North 36 degrees 56 minutes 26 seconds West 302.85 feet to an iron pin; thence along the northern line of Los No.6, North 31 degrees 21 minutes 40 seconds East M.63 feet to an Iron pin at the comer of Lots No... 6 and 7; thence along the dlvldlng line of Lots Nos. 6 and 7, South 58 degrees 38 minutes 20 seconds Easl295 feel to an Iron pin on the northern dedicated rlghl-of-way line of Alexander Spring Road (T -467); lhtlica along said right-of-way line, South 31 degrees 21 minutes 40 seconds West a distance of 120.82 feel to an iron pin; thence continuing along sarna rlghl-of-way line in an arc with a radius of 290.0 feet a distance of a9.18 feet (ertoneously described as 82.35 feet In prior deed) to an iron pin, the point and place of BEGINNiNG. ~ BEING Lot No. 13 of the Plan of Lots of Dickinson Farms recorded in the Cumberland County Reoorder of Deeds Office in Plan Book 29, Page 41. BElNG the same premises which Jo~n M. Shearer and Rebecca $, Shearer, his wife, and J'J,y a Gallcway and Patricia 0, Galloway (formerly Patricia D. Kuhn), his wife, by deed dated January 28, 1983 and recorded February 1, 1983 In the Office Of the Recorder of Deeds in and for Cumberland County, Pennsylvania, in Deed Book "8" Volume 30, Page 3, granted and conveyed unto G. Frankrtn Eichelberger and Linde Marie Eichelberger. AND BE;ING the same premises which G. Franklin Eichelberger and Linda Marie Eichelberger, by deed dated and recorded even date herewith In the Office ofthe Recorder of Deeds in and for Cumberland County. Pennsylvania, granted and conveyed unto Kimberly L Hileman and Michele L. Graff, Mortgagors herein. aouK:!.5S8 rAGE J317 . , II \=\\'\ e. 'X. \--..\ '0' \ \: " .. . VERIFICATION AND NOW Louis P. Vitti verifies that the statements made in this Complaint are true and correct to the best of his knowledge, information and belief. I understand that false statements herein are made subject to the penalties of 18 Pa.C.S. 4904, relating to unsworn falsification to authorities. By virtue of the fact that the Plaintiff is outside the jurisdiction of the court and the verification cannot be obtained within the time allowed for the filing of this pleading, the pleading is submitted by counsel having sufficient knowledge, information and belief based upon the information provided him by the Plaintiff. Dated: December 12, 2001 Y!~~ - -"<." ,,' "'I'.".",."'., ~ -' :-" ,,- ,', , ,- ".. ," ~ ~- -', -' 'v _' ," '-, '" -"'-C-,-'_;';" ,:,:;:-f3__'.-:;~: ;;""',,<'- L -~ "'." '-- ,. ""i"~d"' " ' "--''';"--'. " .,-;-,,', -V,""_-,_-,;,- , ,. ~",", c;-,:) 'i,::~"';~'__i,icZ_-c-",,~,__;:,;,,;; ,- "_c _<~."~_ ~-, .~ _"~'~v ~"-,, <'",,--,_' _, --'-~~-- ," ~~ ~ ,- ~-" _""vo"""^" r2 c:> ~-) (.J \~-: '" ~ "9- '''"J rr ~ : 'l ~ 'c) ~ ~ ~,-.; 8 6\l d . ~ () " ......... ..... (3, ~ () () :.,_."l ' ,I ~ W j I '.}'l ~kJ co .,." -C, i- ~ '-.t.. i I I i~~,?,,",:,,_,_._ --",,-i'~~' ",,, """""'";"F"';2;;1!1)')W,I'1,,'m"":C"'e';";1, ,,;:;1;';N";'W::\::"";f"!l:;e'l!II!J;::;::D~;';"";r:::!:.t~~r';' ''''1; ";,';'B~~~lI!!~~II!lII!I~~h;j."",,, [~~~:tl~: t'-'= -~ SHERIFF'S RETURN- REGULAR i CASE NO: 2001-07075 P COMMONWEALTH OF PENNSYLVANIA: COUNTY OF CUMBERLAND NATIONAL CITY MORTGAGE CO VS GRAFF MICHELE L ET AL RICHARD SMITH , Sheriff or Deputy Sheriff of Cumberland County,Pennsylvania, who being duly sworn according to law, says, the within COMPLAINT - MORT FORE was served upon GRAFF MICHELE L the DEFENDANT , at 1955:00 HOURS, on the 28th day of December, 2001 at 924 ALEXANDER SPRING ROAD CARLISLE, PA 17013 by handing to MICHELE GRAFF 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 18.00 3.90 .00 10.00 .00 31. 90 So Answers: r~ ~t:~~ R. Thomas Kline 01/02/2002 LOUIS VITTI Sworn and Subscribed to before By: me this r"t: day of ~ J-.1rOd...> A. D. ~ Q tVIAI,., AIfS' rothonotary . .C.,,,","',,",,", ~. -~ I' o , . n~ __~ ~~. i'O""~'~ ~''f "' ',-- - ~ .,'''' - . w ~ ~ -. SHERIFF'S RETURN - REGULAR 1 ~ASE_NO: 2001-07075 P COMMONWEALTH OF PENNSYLVANIA: COUNTY OF CUMBERLAND NATIONAL CITY MORTGAGE CO VS GRAFF MICHELE L ET AL STEVE WHISTLER , Sheriff or Deputy Sheriff of Cumberland County, Pennsylvania, who being duly sworn according to law, was served upon says, the within COMPLAINT - MORT FORE HILEMAN KIMBERLY L the DEFENDANT , at 1535:00 HOURS, on the 19th day of December, 2001 at CUMBERLAND CO SHERIFF'S OFFICE ONE COURTHOUSE SQ CARLISLE, PA 17013 KIMBERLY L HILEMAN 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 6.00 .00 .00 10.00 .00 16.00 Sworn and Subscribed to before me this f~ day of ~ J.-IJ1J).... A.D. ~Q tn.iL\ ~r. rothonotary , v """""-:;Rl'4)~_ I" -., -, So Answers: r~~~ R. Thomas Kline 01/02/2002 LOUIS VITTI & ASSOC. BY'J,~h~ , ? ,~~~ ~ ~.......~, 'I~ ?~"n"l?"~''''~~'' ~ ., IN THE COURT OF COMMON PLEAS OF CUMBERLAND COUNTY, PENNSYLVANIA NATIONAL CITY MORTGAGE CO., CIVIL DIVISION NO. 01-7075 CIVIL TERM Plaintiff, PRAECIPE FOR DEFAULT JUDGMENT, CERTIFICATION OF MAILING AND AFFIDAVIT OF NON- MILITARY SERVICE vs. MICHELE 1. GRAFF and KIMBERLY 1. HILEMAN, both unmarried, Code MORTGAGE FORECLOSURE Defendants. Filed on behalf of Plaintiff Counsel of record for this party: Louis P. Vitti, Esquire PALD. #3810 Supreme Court #01072 Louis P. Vitti & Assoc., P.C. 916 Fifth Avenue Pittsburgh, PA 15219 (412) 281-1725 -'~.J,)" -_",./J", _.',,-,'."',,,,"';>""-",",_.,_..'''".,,<'.'',. c,.., "'-.."~'It''''.~'''-_ ,~':""'~, ~".".-,__..Y" ,~_.~._ '"'",,'''~''M,.,___ '.,_~_.'__,"'. _-"_",.~,_".,,,.,, '''",,",~,~,~,< ",',"'",_..' ,,~~._, _~. h _ - -I. i~-t'~'.,<.>-_ :'_;1" ,.~ 1JlrJjjjjj . r ",><"'"'" '~,~ '-.- -^,,~ IN THE COURT OF COMMON PLEAS OF CUMBERLAND COUNTY, PENNSYL VANIA CIVIL DIVISION NATIONAL CITY MORTGAGE CO., NO. 01-7075 CIVIL TERM Plaintiff, vs. MICHELE 1. GRAFF and KlMBERL Y 1. HILEMAN, both unmarried, Defendants. PRAECIPE FOR DEFAULT JUDGMENT AND ASSESSMENT OF DAMAGES TO: PROTHONOTARY OF CUMBERLAND COUNTY Enter judgment in Default of an Answer in the amount of $135,899.15, in favor of the National City Mortgage Co., Plaintiff in the above-captioned action, against the Defendants, Michele L. Graff and Kimberly L. Hileman and assess Plaintiff's damages as follows and/or as calculated in the Complaint: Unpaid Principal Balance Interest from 06/01/01-02/01/02 (Plus $23.5269 per day after 02/01/02) $118,445.74 5,764.09 Late charges (Plus $40.23 per month from 12/13/01-06/05/02 $241.38) 394.87 Attorney's fee 5,922.29 Escrow Deficit (Plus any additional charges that may be incurred by the Plaintiff and transmitted to the sheriff as charges on the writ prior to the date of the sheriff's sale) 5.372.16 Total Amount Due $135,899.1:; The real estate, which is the subject matter of the Complaint, is situate in Twp of Dickinson, Cumberland Cty & Cmwlth ofP A. HET a dwg k/a 924 Alexander Spring Road, Carlisle, PA 17013. Parcel No. 08-09-0523-043. Z?~~ LoUIS P. Vitti, Esquire Attorney for the Plaintiff :',~1!;\1'!~ ~",,-"" "^ ,.'-q--~,,,,-, rI_',',c,:'"_,:,~",_-,, _ ".1 .,._ e,,,.,, ~~, -,,"'" .-". "'"c-",' ," <",' ". ".r.,,_-,-_ "~l't"-lmr' IN THE COURT OF COMMON PLEAS OF CUMBERLAND COUNTY, PENNSYLVANIA CIVIL DIVISION NATIONAL CITY MORTGAGE CO., NO. 01-7075 CIVIL TERM Plaintiff, vs. MICHELE 1. GRAFF and KlMBERL Y 1. HILEMAN, both unmarried, Defendants. CERTIFICATION OF MAILING I, Louis P. Vitti, do hereby certify that a Notice ofIntention to Take Judgment was mailed to the Defendant(s), in the above-captioned case on January 18, 2002, giving ten (10) day notice that judgment would be entered should no action be taken. LOUIS P. VITTI & ASSOCIATES, P.C. BY: p~- LOUIS P. Vitti, Esquire Attorney for Plaintiff SWORN to and subscribed Notarial Seal C~=J B.Edler, No\ary Public Pi , County My Commie ~~e 10, 2002 Member, Pennsylvania Ass<lclatlon of Nolaries before me this 1 st day of February, 2002. a '-"-$~",1 '~"',>', ._,_,,__,'~, -*~',_"'^1";'~"~"..o_,~_J,,,. ,_,.'_ Y_' . """""_ .' ^.__,_d~_~"~__ ",~,_ _",'~, " ".'< ____^,,_~_ ~_=~,='_. ,~____ c'\' ,'.,0_,',_ -,-I c" rr'~__ -" ~ "-~ - -~ -- , IN THE COURT OF COMMON PLEAS OF CUMBERLAND COUNTY, PENNSYLVANIA CIVIL DIVISION NATIONAL CITY MORTGAGE CO., ) ) Plaintiff, ) vs, ) ) MICHELE 1. GRAFF and KIMBERLY 1. ) HILEMAN, both unmarried, ) ) Defendants, ) No. 01-7075 CIVIL TERM IMPORTANT NOTICE TO: Michele 1. Graff Kimberly L. Hileman 924 Alexander Spring Road Carlisle, PA 17013 Date of Notice: January 18, 2002 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 (10) DAYS FROM THE DATE OF THIS NOTICE, A JUDGMENT MAYBE ENTERED AGAINST YOU WITHOUT A HEARING AND YOU MAY LOSE YOUR PROPERTY OR OTHER IMPORTANT RIGHTS. YOU SHOULD TAKE THIS NOTICE TO YOUR LAWYER AT ONCE. IF YOU DO NOT HAVE A LAWYER OR CANNOT AFFORD ONE, GO TO OR TELEPHONE THE FOLLOWING OFFICE SET FORTH BELOW TO FIND OUT WHERE YOU CAN GET LEGAL HELP: CUMBERLAND COUNTY BAR ASSOCIATION 2 LmERTY AVENUE CARLISLE, PA 17013 (717) 249-3166 LOUIS p, VITTI & ASSOCIATES, P.C. /~ ~" /---.... . \" ~~~ ./ ./ . --; ,( ! ~ ",. ;' '1/ I,}'\-. ,! , / !)....'I/Z.'l..,:''^----'~ , I . . I I - U C<.-C1 BY: Louis P. Vitti, Esquire Attorney for Plaintiff 916 Fifth Avenue Pittsburgh, PA 15219 ** THE DEBT COLLECTOR IS ATTEMPTING TO COLLECT A DEBT AND ANY INFORMATION OBTAINED WILL BE USED FOR THAT PURPOSE. ** L-'>_"'-"!'7-Wjti~ili!II,-.f!\!)_ ,..,} _UWl I - - - - -.- ~~~ ""'r.,.N' ~a-trr-" '-' ~,- c~,_ ~".. , , . IN THE COURT OF COMMON PLEAS OF CUMBERLAND COUNTY, PENNSYL VANIA CIVIL DIVISION COMMONWEALTH OF PENNSYLVANIA, SS: COUNTY OF ALLEGHENY BEFORE me, the undersigned authority, personally appeared Louis P. Vitti, Esquire, who, being du1y sworn according to law, deposes and says that he is advised and believes that DEFENDANT(S) is/are not presently in the active military service of the United States of America and not members of the Army of the United States, United States Navy, the Marine Corps, or the Coast Guard, and not officers of the Public Health. Service detailed by proper authority for duty with the Army or Navy; nor engaged in any active military service or duty with any military or naval units covered by the Soldiers and Sailors Civil Relief Act of 1940 and designated therein as military service, and to the best of this affiant's knowledge is/are not enlisted in military service covered by said act, and that the averments herein set forth, insofar as they are within his knowledge, are correct, and true; and insofar as they are based on information received from others, are true and correct as he verily believes. This Affidavit is made under the provisions of the Soldiers and Sailors Civil Relief Act of 1940. ~-~----- Louis P. Vitti, Esquire SWORN to and subscribed Notarial Seal ~ B. Edler, Notary Public . rgh, AIIeQhenY County My Commlssoon Expires June 10, 2002 Member, Pennsylvania AsS<lClation 01 Notari.. before me this 1 st day of February, 2002. .,,~ Iffij J, ~ ,_",' ""_;,'-.'''.G',,"~.-_'''f'>'--''''' :~_,~__,_:"_: ,~~,,'> .-_o,'~ ,~~ "l ," ,- .",,~- - ---;-b~o_,.,~_ .,"_ , " ,,",,'_ "',, _ __"__ __ ,_, .y,", " ,NIr.__.__ ." , I '~" _._"~ d"__~C._<~" __'_'.,,-_,,"" _-<r>_._~"" ,_.~J_e"" '''''''~-'-V',~---' O,-''''''"'''T,_, <,," --~-' - .",,~, '-~'-^"'>'I~"""-"-'''' ~~ ''''"'--'''''",',.~''-.''- ,-;-;---,",,,,,,,;{~,,,~m~~-.~M"---""'''''ii">=~'- -"~l""~~"U:G- "::f' .~'-,-~ -, t fJ (.) "<l. :.0 It- i 0 F ..... ~ (} C) Cd JJ C~_ f'<:' -U ..""~ - < -,., tN ~ S2ff .....1 3 L r CLJ -.0 :c:':: r , pi . "'() 5!J ;.~ C/' ~ ~ r:c-': :;;::~ r :7;c: );..~' .. :;1 c:- -----.. ~ (J\ :0 - ~ ""1,',, . ":'L,~,:,,";l~~~.,..,.~!,!~!!g~~~~~~ "'~-r <h",~ ", .~ . IN THE COURT OF COMMON PLEAS OF CUMBERLAND COUNTY, PENNSYLVANIA NATIONAL CITY MORTGAGE CO., CIVIL DIVISION NO. OI-7075 CIVIL TERM Plaintiff, PRAECIPE FOR WRIT OF EXECUTION AND AFFIDAVIT OF LAST KNOWN ADDRESS vs. MICHELE 1. GRAFF and KIMBERLY 1. IDLEMAN, both urnnarried, Code MORTGAGE FORECLOSURE Filed on behalf of Plaintiff Defendants. Counsel ofrecord for this party : Louis P. Vitti, Esquire PA LD. #3810 Supreme Court #0 I 072 Louis P. Vitti & Assoc., P.C. 916 Fifth Avenue Pittsburgh, PA 15219 (412) 281-1725 .;:'-~~!i!!l!!!-.f , ">.: ",-."""""~-,Z\'~"_"."''"_'"'\~"",,.>__,'' 0_"'''" "_,_,,_..~,-,,I' ." "_~'.",_"_~,L"~,,~," ~ . ."~-~ ~, ~, _ _"'--_'..~. "'". c, ,,_ -,,,". _c__. _ '_'. ~,,>,,'__'''' _,". . _ c" '_e' 'H , "" _ ~ f ~ ,~ "1':r'" " Un ."", '" IN THE COURT OF COMMON PLEAS OF CUMBERLAND COUNTY, PENNSYLVANIA CIVIL DIVISION NATIONAL CITY MORTGAGE CO., NO. 01-7075 CIVIL TERM Plaintiff, vs. MICHELE 1. GRAFF and KlMBERL Y L. HILEMAN, both unmarried, Defendants. PRAECIPE FOR WRIT OF EXECUTION IN MORTGAGE "FORECLOSURE TO: PROTHONOTARY OF CUMBERLAND"COUNTY Issue a Writ of Execution in favor of the Plaintiff and against the Defendant(s) in the above-captioned matter as follows: Amount Due $135,899.15 Interest 02/02/02-06/05/02 2.917.34 Total $138,816.49 The real estate, which is the subject matter of the Praecipe for Writ of Execution is situate m: Twp of Dickinson, Cumberland Cty & Cmwlth ofPA. HET a dwg k/a 924 Alexander Spring Road, Carlisle, PA 17013. Parcel No. 08-09-0523-043. ~~ti3PJi Louis P. Vitti, Esquire Attorney for Plaintiff 1,'--~r ~!", " '_h'"-'~""'"_",,,~,_ ,'f'_,<-->,.~",c"",:_,,_ _ '_~""'~",>__'h' -,' F IP_.,<,'__O" ---p.. " .--".'- ,'--', ~,-_. " ,,~ _ -e ~ _ - _ -_ _~"__o"_, -",q -_:' ~_. , ,~ -~, , '"I",'''i,'I',-'-:'I';-~I';-,"'\lli>---.k<'Y2?'':N'i~~"J;--\:~~ - - ""'. - """"'~""";.-I-.;>~,c,;"';.;,-;'W'+'''Ji:",,_--'F",~~'l"jff,f.<r-ttfft"w:"_"q(j""'''=' I,,_~ '.-"'_" w',',.~" '.;.,.C,...... ........_. ~ ...... ~ ~ " ~ .tQ. CO ;~~. (-j 'i ~ ~ ~ "- tv ~ c" - ~~ .... ..() " - ~ ~R -'1 Vol ,() ~ , 8 . "I . C & .0 & D ..~, - cl c C' c 0 () I 0 U~'_' (j~ ~ { I , --< :r_c,_ J !,,-' (~-. - ~ , ~G ~: _;..1 (,.J I ~ ~C .c l ~{f r ,.~, -::.~~ -l'I .....-:. (-J ~ ~ ~ ... ........:. ~6 ~ ;:: ~ ... , :;J - .~ " 0"\ -< . , , .... ~ ~ ~ .... "_~",,,ee' " _,'"'e,"," ",,",,",'''_'e,"'''Y m ",,'_. ---~- - c Jt,_,_".._,_,.,~~w~~"",__"""",._,..;,J., ,,;~ " ' ,;,k, -'~'~.~~:,~u-ill;m~@l!1~:~~~~~~~IN,,<_~J,:!,:~, ~~'l1(''fl<l;^f":L ~'T _no' -"( '"., , ~-- , IN THE COURT OF COMl'ON PLEAS OF CUMBERlAL'lD COUNTY, PENNSYLVANIA CIVIL DIVISION PRAECIPE FOR WRIT OF EXECUTION Caption: National City Mortgage Co., Confessed Judgment Other vs. F 1 No 01-7075 Civil Term i e . Arroun t DUe $135,899.15 Interest 2,917.34 Atty's Comn Costs Michele L. Graff and Kimberly L. Hileman, ro THE: PllO'IHONOl'ARY OF THE SAID COURT: '!'he undersigned hereby certifies that the below does not arise out of a retail insta1.lJrent sale, a:mtract, or account based on a confession of judgment, but if it does, it is based on the appropriate orj.ginal proceeding filed pursuant to Act 7 of 1966 as arre!1ded: and for real property pursuant to Act 6 of 1974 as arrended. Issue writ of execution in the above matter to the Sheriff of Cumberland County, for debt, interest and costs :.!pon the following described property of the defendant(s) See attached Legal Description. PRAECIPE FOR A~ EXEDmON Issue writ of attachIrent to the Sheriff of Cumberland County, for debt, interest and costs, as above, directing attachrrent against the above-named garnishee(s) for the following property (if real estate, supply six copies of the description; supply four' copies of lengthy personalty list) and all other property of the defendant ( s) in the possession, custody or control of the said garnishee ( s). DATE: ( Indicate) Index this writ agains t the garnishee{ s) as a lis pendens against real estate of the defendant(s) described in the attached exhibit. ~ . ..<:? "- Signature: ~W~ P:::int Narre: uis P. Vitti February 1, 2002 .~d.ress : 916 Fifth Aveneu Pittsburgh, PA 15219 At tOr71ey for: Plaintiff (412) 281-1725 :ele::hor.e: ""'-f""XBi\""H~_l ~11 '., ~_, "_._,_. , -p -, I " -~ ,. - ~ .,..~~ .~ . ~c~~.,," ~ ~__. fR'i.< 1II_-~"""~-'*"""-".1" J,,",_>, c.,.",., ~"""""~M~ . ~.. _~_ '" IN THE COURT OF COMMON PLEAS OF CUMBERLAND COUNTY, PENNSYLVANIA CIVIL DIVISION NATIONAL CITY MORTGAGE CO., NO, 01-7075 CIVIL TERM Plaintiff, vs. MICHELE 1. GRAFF and KlMBERL Y 1. HILEMAN, both unmarried, Defendants. LEGAL DESCRIPTION ALL THAT CERTAIN tract ofland situate in Dickinson Township, Cumberland County, Pennsylvania, more particularly bounded and described in accordance with a survey by Stephen C, Fisher, R.S., dated November 4, 1976 (revised), as follows: BEGINNING at an iron pin on the Northern dedicated right-of-way line of the Alexander Spring Road (T- 467), a 33 foot right-of-way, said iron pin being also at the Southeast comer of Lot No.6 of the hereinafter mentioned Plan of Lots; thence along the dividing line of Lots Nos. 5 and 6, North 36 degrees 56 minutes 26 seconds West 302.85 feet to an iron pin; thence along the Northern line of Lot No.6, North 31 degrees 21 minutes 40 seconds East 96.63 feet to an iron pin at the corner of Lots Nos. 6 and 7; thence along the dividing line of Lots Nos. 6 and 7, South 58 degrees 38 minutes 20 seconds East 295 feet to an iron pin on the Northern dedicated right-of-way line of Alexander Spring Road (T-467); thence along said right-of- way line, South 31 degrees 21 minutes 40 seconds West a distance of 120.82 feet to an iron pin; thence continuing along same right-of-way line in an arc with a radius of 290.0 feet a distance of 89.18 feet (erroneously described as 8235 feet in prior deed) to an iron pin, the point and place of beginning. BEING Lot No.6 of the Plan of Lots of Dickinson Farms recorded in the Cumberland County Recorder of Deeds Office in Plan Book 29, page 41. HAVING erected thereon a dwelling known as 924 Alexander Spring Road, Carlisle, PA 17013. PARCEL NO. 08-09-0523-043. BEING the same premises which G. Franklin Eichelberger and Linda Marie Eichelberger by deed dated 02/29/2000 and recorded on 03/02/2000 in the Cumberland County, Pennsylvania, Recorder of Deeds Office in Deed Book Volume 217, page 19, granted and conveyed unto Michele 1. Graff, unmarried and Kimberly 1. Hileman, unmarried. _-_""",_';.#l:jW;; "! , _ _~_ ",__, t;~ ~ -. ,~ ,1"--:-- .. ,." '-,' ~ -~ ~ ,~~ " ~ -.,""['" .""r~""':T'__'rn'-" ^ '. .' IN THE COURT OF COMMON PLEAS OF CUMBERLAND COUNTY, PENNSYLVANIA CIVIL DIVISION NATIONAL CITY MORTGAGE CO., NO. 01-7075 CIVIL TERM Plaintiff, vs. MICHELE 1. GRAFF and KlMBERL Y 1. HILEMAN, both unmarried, Defendants. AFFIDAVIT I, Louis P. Vitti, do hereby swear that, to the best of my knowledge, information and belief, the Defendant(s), is/are the owners of the real property on which the Plaintiff seeks to execute. That the Defendants' last known address is 924 Alexander Spring Road, Carlisle, P A 17013. ~W4/i- L . P V' 'E . OUlS . Ittl, sqUire SWORN TO and subscribed before me this 1 st day of Notarial Seal ~ryl B. Edler, Nolery Public PIl\sbuIllh, Allegheny -County My CommlssTon Elcplres June 10, 2002 Member, Pennsylvanla _Iallon 01 NOla'ie. February, 2002. f;M:.~;.", _._ . _~" ,.. ~~"-' _~~_,,, ,,~. ,~,_ ,_ .~".= '~"_ w, _ ,_ _ _1__ ,~~ __. ".=""_.", ... --- "."'-' - ~-- . __n." ..,,,,.,,.,",,,;c., .''_ _ ',< -' _,)~,~" __.'" ,C".',,,::..,, """,,'"', -' '1- -,- ""' -, '"'''''''' '-L'ilb""';;,~' -o"i---'P!l%'"-:-'-'ir;~rf'>~l'~"{!frr>'ffiiIn[n"'>1 ~-rx"~mrnr"'~-'1-1f"'~~Te::'I-:~".0 C) 0'i~; ~:...... -, fif;'~~ ~~lJ }-;;. >.."..c> ~(-I Pc:' 2: -'I -, ,. '<"'l'\-:, _C\'''''--:o~. . __?,~,"-_,"U-.:.'__',;.,,_ ,.,__~'",_,," "V"_~ _ .' -, S:l r.- (1; , ." c} ( '",~ !~3 , c.., :e;:t~ ...,~ v.,~. t~ <~~ ~,_, ;;>eJ1JP,_.~__KJ~~,-,_!I_[,.,fi\~~l'fr~fR(R!fm-~g,fflf,i\?l"~~"h.:1!~~; t."r~, <"""';""'f~' ",^' 'r IN THE COURT OF COMMON PLEAS OF CUMBERLAND COUNTY, PENNSYL VANIA CIVIL DIVISION NATIONAL CITY MORTGAGE CO., NO. 01-7075 CIVIL TERM Plaintiff, vs. MICHELE 1. GRAFF and KlMBERL Y 1. HILEMAN, both urnnarried, Defendants. AFFIDAVIT I, Louis P. Vitti, hereby certify that as representative of National City Mortgage Co. am familiar with the above-captioned case and various servicing activities related thereto and that the provisions of the laws of the Commonwealth of Pennsylvania and specifically, Act 91 of 1983, have been complied with in the above-captioned case. 2:J~4 ' Louis P. Vitti, Esquire Attorney for Plaintiff SWORN to and subscribed before me this 1 st day NotarlalS$al C!Jeryt B. Edler, Notary Public P,l\9burflh, AUeilheny County My CommissIOn Expfres June 10, 2002 Member, Pennsylvani'i ASS<1Cletlon of Notaries of February, 2002, ~ - '.\'-~ - ". .'~"'O' ___."-Cr"""-, "_s,,"__,",..,-',"";<""'_"'~ '_' ~'d'",'_A'''''__'n_' _0-'"'"" =.,,' ,- _,,,~ Or'"..7" ,n - , ", _'~ '" I~ ,,- r V)-::::t 10m ",~" ..,~'...., ,',..,..,'",..",'..,.. ..' . ",.~__.' ~_,d_!_. ','_,-e.,r .7'" ~. -~ ". . ,-" ..'.- '" ".h-;,o.-~"r','-' -. '-"'f"-""";V"i-~'''~'c2 ":rl-'ft"'~"1 '1 ~'~ 1-1[:" ITT r"'" _%,':d"1:;;:~~~~t;:F~r-;!': '_':_"'_~~~~_~ '1'~,' ".>~<; ,,!'JlIi,~,lP~~I,~~~~;,:,"":;'F~~"#Td'iilJ'<!!'~' o ~~. -alT' fTi~-{' z:r: l~; z :.:i C;:J \.'-.} "'1 ~-T'i '-::.rJ L~i ~.v' -- ~) r (T"- .1!i\t\,_~_~~~~~,~Ji![~~~ '~:Utl-'rf'-'" ~"--' ,~,,,-,,- IN THE COURT OF COMMON PLEAS OF CUMBERLAND COUNTY, PENNSYLVANIA CIVIL DIVISION NATIONAL CITY MORTGAGE CO., NO. 01-7075 CIVIL TERM Plaintiff, vs. MICHELE 1. GRAFF and KlMBERL Y 1. HILEMAN, both unmarried, Defendants. AFFIDAVIT PURSUANT TO RULE 3129.1 National City Mortgage Co, 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 924 Alexander Spring Road, Carlisle, PA 17013. 1. Name and address ofOwner(s) or Reputed Owner(s): Name: Address (Please indicate if this cannot be reasonably ascertained) Michele 1. Graff Kimberly 1. Hileman 924 Alexander Spring Road Carlisle, P A 17013 2. Name and address ofDefendant(s) in the judgment: Name: Address (Please indicate if this cannot be reasonably ascertained) Same as No.1 above. 3. Name and last known address of every judgment creditor whose judgment is a record lien on the real property to be sold: Name: Address (Please indicate if this cannot be reasonably ascertained) None "''''~A~_ _'0 ,-" ~'~~'""'.'o __"~"_ _ ~__= -.. ~_I_ ,_ _~~_~"~, _ H." "'" , - ='-", ,-~'~ ," v -..'."~" ~"" "-""<"". '-"-"'<-"""'-'<'"''- -." I ' ~~ :.-~ ~r '0:": '--'TI r- -' -~ ,"- 4. Name and address of the last recorded holder of every mortgage of record: Name Address (Please indicate if this cannot be reasonably ascertained) None 5. Name and address of every other person who has any record lien on the property: Name Address (Please indicate if this cannot be reasonably ascertained) None 6. Name and address of every other person who has any record interest in or record lien on the property and whose interest may be affected by the sale: Name Address (Please indicate if this cannot be reasonably ascertained) 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 Address (please indicate if this cannot be reasonably ascertained) Tax Collector of Dickinson Township 1044 Pine Road Carlisle, P A 17013 Commonwealth ofPA -DPW P.O. Box 8016 Harrisburg, PA 17105 Clerk of Courts Criminal/Civil Division One Courthouse Square Carlisle, PA 17013 Court of Common Pleas of Cumberland County Domestic Relations Division P.O. Box 320 Carlisle, PA 17013 '~\!-r-""",,",," ~_ ,,,~,,.,,,=...,,.--> _,,, r, _.~ ""'_""".>, _<"" ~. -'. . --,,'^-^-- ~ ,_^" " ',"0,__' -"--0 ,,"-. :.~.~'-~~' ", <-, ~~..,^" Bureau of Compliance Clearance Support Section Dept. #281230 Harrisburg, PA 17128-1230 Attn: Susan Blough Tenant/Occupant 924 Alexander Spring Road Carlisle, PA 17013 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, February 1. 2002 Date ~' , (ilJ( L 'p V' . E . OUlS . Ittl, sqUire Attorney for Plaintiff SWORN TO and subscribed before me this 1 st day Notarial Seal Cheryl B. Edler, Notary Public Plltsbuf'Oh, ~eny County My Commission Exptres June 10. 2002 Member, Pennsytmnia Assoclatton 01 Notaries of February, 2002. ::--;lTJw.~,c -:;,_ -~, .W,"~_,._ :.,~.^_=",",~, _~~ ~__" ^' . - '" ~- ;, ,~,--,-,~"" r.-__~ ' ~, ~,,' , . '" " ~"""'- ~-, ". H ._. ,,_~V - .~ -~~ ,'''''~''' - '''"'''' """"ili(~~ILl JIIllf1 fflirrij1'IliUI'u'11'iIV',F;' ,j'o _._ -T~" ",<J_,_ Jl. ~Q~. _~, -'_~ rn !J...UJ'ffi~)~-~~~~~~-"U P ? -oij'- n":\""',-' ~..-"-:- .k-_ ~.- ~7! ~~~0 r':;l_:'" :::'i:; ," Z:j, )> l~~ 2~ r -, C.:J t'.,; 41 rq C:-:J I cJ: ~~ --'-40 (> -, 'F; c>' ~;: ...-r-, ',;;;'.7\ ,",0 '_.-' -', ~ ~ -- r::- ._1 ![!. __,.~J J:f -__:]1'-'11\" -, ._ [n_ . .""~ . NOTICE OF SHERIFF'S SALE OF REAL ESTATE PURSUANT TO PENNSYL VANIA RULE OF CIVIL PROCEDURE 3129.1 TO: Michele L. Graff Kimberly 1. Hileman 924 Alexander Spring Road Carlisle, PA 17013 AND: ALL LIEN HOLDERS TAKE NOTICE that by virtue of the above Writ of Execution issued out of the Court of Common Pleas of Cumberland County, Pennsylvania and to the Sheriff of Cumberland County, directed, there will be exposed to Public Sale in Cumberland County Courthouse on June 5 , 2002 at 10:00 A.M., the following described real estate, of which Michele L. Graff and Kimberly L. Hileman are owners or reputed owners: Twp of Dickinson, Cumberland Cty & Cmwlth ofPA. HET a dwg k/a 924 Alexander Spring Road, Carlisle, PA 17013. Parcel No. 08-09-0523-043. The said Writ of Execution has issued on a judgment in the mortgage foreclosure action of National City Mortgage Co. vs. Michele 1. Graff and Kimberly 1. Hileman at No. 01-7075 Civil Term in the amount of$135,899.15. Claims against property must be filed at the Office of the Sheriff before above sale date. Claims to proceeds must be made with the Office ofthe Sheriff before the sale date. Schedule of Distribution will be filed with the Office of the Sheriff no later than thirty (30) days from sale date. Exceptions to Distribution or a Petition to Set Aside the Sale must be filed with the Office of the Sheriff no later than ten (10) days from the date when Schedule of Distribution is filed in the Office of the Sheriff. Attached hereto is a copy of the Writ of Execution. It has been issued because there is ajudgment against you. It may cause your property to be held or taken to pay the judgment. You may have legal rights to prevent your property from being taken. A lawyer can advise you more specifically of these rights. rfyou wish to exercise your rights you must act promptly. -!';(;Lli.l5lll!'_lt~." _, '>',"__'"< ^'~"~'""'''''~'=_0."''''7=,_^_..~," '~M_~_,~_I_,<___..-_"__, _, _,'...'_.;< <,_~~_._~,. w_~ ,", ".,. ",_ ,u. . YOU SHOULD TAKE TmS NOTICE AND THE WRIT OF EXECUTION 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 ADVICE. CUMBERLAND COUNTY BAR ASSOCIATION 2 LIBERTY AVENUE CARLISLE,PA 17013 (717) 249-3166 You may have legal rights to prevent the Sheriffs Sale and the loss of your property. In order to exercise those rights, prompt action on your part is necessary. A lawyer may be able to help you. You may have the right to prevent or delay the Sheriffs Sale by filing, before the sale occurs, a petition to open or strike the judgment or a petition to stay the execution. If the judgment was entered because you did not file with the Court any defense or objection you might have within twenty (20) days after service of the Complaint for Mortgage Foreclosure and Notice to Defend, you may have the right to have the judgment opened in you promptly file a petition with the Court alleging a valid defense and a reasonable excuse for failing to file the defense on time. If the judgment is opened, the Sheriff's Sale would ordinarily be delayed pending a trial ofthe issue of whether the Plaintiff has a valid claim to foreclose the Mortgage. You may also have the right to have the judgment stricken if the Sheriff has not made a valid return of service of the Complaint and Notice to Defend or if the judgment was entered before twenty (20) days after service or in certain other events. To exercise this right, you would have to file a petition to strike the judgment. You may also have the right to petition the Court to stay or delay the execution and the Sheriffs Sale if you can show a defect in the Writ of Execution or service or demonstrate any other legal or equitable right. You may also have the right to have the Sheriff's Sale set aside if the property is sold for a grossly inadequate price or if there are defects in the Sheriff's Sale. To exercise this right, you should file a petition with the Court after the sale and before the Sheriffhas delivered his Deed to the property. The Sheriff will deliver the Deed ifno petition to set aside the sale is filed within ten (10) days from the date when the Schedule of Distribution is filed in the Office of the Sheriff. ~~- Lo s P. Vitti, Esquire Attorney for Plaintiff 916 Fifth Avenue Pittsburgh, PA 15219 (412) 281-1725 **THE DEBT COLLECTOR IS ATTEMPTING TO COLLECT A DEBT AND ANY INFORMATION OBTAINED WILL BE USED FOR THAT PURPOSE.** !o.,,#~ , JlU,Y,~'~ ""--~""..,'''V'':=<'''::C'3'l'?''9,~'=,e."., ,'1'~"AN,7""~"~':'f" d.~I~.,]'~, ',"','" -,~:o,~.""" ",~ . .-c~ .'<-" ,~~,,'^, ~," ",,-".. ,~ ._~ ., _, _ ~__ ,__".". ',.c .. ,~ ~ " "., - "." . . IN THE COURT OF COMMON PLEAS OF CUMBERLAND COUNTY, PENNSYL VANIA CIVIL DIVISION NATIONAL CITY MORTGAGE CO., NO. 01-7075 CIVIL TERM Plaintiff, vs. MICHELE 1. GRAFF and KlMBERL Y 1. HILEMAN, both unmarried, Defendants. LEGAL DESCRIPTION ALL THAT CERTAIN tract ofland situate in Dickinson Township, Cumberland County, Pennsylvania, more particularly bounded and described in accordance with a survey by Stephen C. Fisher, R.S., dated November 4, 1976 (revised), as follows: BEGINNING at an iron pin on the Northern dedicated right-of-way line of the Alexander Spring Road (T- 467), a 33 foot right-of-way, said iron pin being also at the Southeast comer of Lot No, 6 of the hereinafter mentioned Plan of Lots; thence along the dividing line of Lots Nos. 5 and 6, North 36 degrees 56 minutes 26 seconds West 302.85 feet to an iron pin; thence along the Northern line of Lot No. 6, North 31 degrees 21 minutes 40 seconds East 96.63 feet to an iron pin at the comer of Lots Nos, 6 and 7; thence along the dividing line of Lots Nos. 6 and 7, South 58 degrees 38 minutes 20 seconds East 295 feet to an iron pin on the Northern dedicated right-of-way line of Alexander Spring Road (T-467); thence along said right-of- way line, South 31 degrees 21 minutes 40 seconds West a distance of 120.82 feet to an iron pin; thence continuing along same right-of-way line in an arc with a radius of 290.0 feet a distance of 89.18 feet (erroneously described as 82.35 feet in prior deed) to an iron pin, the point and place of beginning. BEING Lot No.6 of the Plan of Lots of Dickinson Farms recorded in the Cumberland County Recorder of Deeds Office in Plan Book 29, page 41. HAVING erected thereon a dwelling known as 924 Alexander Spring Road, Carlisle, PA 17013. PARCEL NO. 08-09-0523-043. BEING the same premises which G. Franklin Eichelberger and Linda Marie Eichelberger by deed dated 02/29/2000 and recorded on 03/02/2000 in the Cumberland County, Pennsylvania, Recorder of Deeds Office in Deed Book Volume 217, page 19, granted and conveyed unto Michele L. Graff, unmarried and Kimberly 1. Hileman, unmarried. '-<'~;~~" _ ~.~~'~,.'r 1'" , ~1'\Ilr - EI . ~~_. ~ ~~-.. -.~ --~- '>'''.'' ,_ >4'- .,- , -,'.C, ," - ,.N 'C-'~ ;._.~ , - ~""';i;"V;;"W'~ '''''-":.r,>_._~"-,,,~,,,. .~"",'_'","', ,_Y',,"' " .m' -- ~-~"-k'''''~-,o'>l''''''J;.-!>-'[i '-'oil . . --~.. 0 0 C'; C \-....) -'1'1 > -.., -0 r-; , r-q rn r- '::~~'; --;;r ...:._; 'if-- I en ::.,. () -<. ",,::::, ~t~ :~ :JL---: C... -7 ~ iJ =< ...! -< D~ i--:i<~j l:r"_,,~, '_00\''''''''',,",_ ,_ ",1~~~'~\!flflr~:lr.I"-,'(,!"",,";;Y-'-':f:,"-,Y.;1"'-~f'~1C:~'c' '-'.<",-' ,-- .,,=, National City Mortgage Co. VS Michele 1. Graff and Kimberly L Hileman In The Court of Common Pleas of Cumberland County, Pennsylvania Writ No. 2001-7075 Civil Term R. Thomas Kline, Sheriff, who being duly sworn according to law, states this writ is returned STAYED pursuant to instructions from Attorney Louis P. Vitti. 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 3.45 15.00 1.60 $ 81.55 paid by attorney 3~13-02 Sworn and subscribed to before me So Answers: This~dayofl1uu.d./ r~ -t: ~ fl R. Thomas Kline, ~e;;;- 2002,A.D. rt~Q ThAt/;~;~OZf BYJo~ ~ Prothonotary Real Estate Deputy \, :sD Q3SQI'i ~ r);;' 'is'( """"""~f;;:~_:;,,_~,,,,_, ,,~ ~ < I"-~ '" '-to. . . ~_.""'-""'""..'"'',.,..".~~''' " IN THE COURT OF COMMON PLEAS OF CUMBERLAND COUNTY, PENNSYLVANIA CIVIL DIVISION NATIONAL CITY MORTGAGE CO., NO. 01-7075 CIVIL TERM Plaintiff, vs. MICHELE 1. GRAFF and KIMBERLY 1. HILEMAN, both unmarried, Defendants. AFFIDAVIT PURSUANT TO RULE 3129.1 National City Mortgage Co, Plaintiff in the above action, sets forth as ofthe date the Praecipe for the Writ of Execution was filed the following information concerning the real property located at 924 Alexander Spring Road, Carlisle, PA 17013, 1. Name and address of Owner(s) or Reputed Owner(s): Name: Address (Please indicate if this cannot be reasonably ascertained) Michele 1. Graff Kimberly 1. Hileman 924 Alexander Spring Road Carlisle, PA 17013 2. Name and address ofDefendant(s) in the judgment: Name: Address (Please indicate if this cannot be reasonably ascertained) Same as No, 1 above. 3. Name and last known address of every judgment creditor whose judgment is a record lien on the real property to be sold: Name: Address (Please indicate if this cannot be reasonably ascertained) None ^~!;i"'~<t;1_q '"'~ ,""'~. , " c, _'"~ , ~,~ 'T'" c' ~ -, - - -,.. ~.~ ~- ~,~ "!_'J''!<:I'!~'~'; ", 4. Name and address of the last recorded holder of every mortgage of record: Name Address (Please indicate if this, cannot be reasonably ascertained) None 5. Name and address of every other person who has any record lien on the property: Name Address (Please indicate if this cannot be reasonably ascertained) None 6, Name and address of every other person who has any record interest in or record lien on the property and whose interest may be affected by the sale: Name Address (Please indicate if this cannot be reasonably ascertained) 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 Address (Please indicate if this cannot be reasonably ascertained) Tax Collector of Dickinson Township 1044 Pine Road Carlisle, P A 17013 Commonwealth ofPA -DPW P.O. Box 8016 Harrisburg, PA 17105 Clerk of Courts Criminal/Civil Division One Courthouse Square Carlisle, PA 17013 Court of Common Pleas of Cumberland County Domestic Relations Division P.O. Box 320 Carlisle, PA 17013 'f'.Wf!Jll1~,",,, " ,. .,., . ,., .~_.. - -r' '. '-"- , <,;T, ,...-"" Bureau of Compliance Clearance Support Section Dept. #281230 Harrisburg, PAl 7128-123 0 Attn: Susan Blough Tenant/Occupant 924 Alexander Spring Road Carlisle, PA 17013 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. February 1. 2002 Date ~I , fPI' L 'p V' . E . oms . lttl, sqmre Attorney for Plaintiff SWORN TO and subscribed before me this 1 st day Notarial Seal Che=. Edler, Notary Public PI , en County My Comm on ~res t;e 10,2002 Member, PennsYMmii\ As~atlon of NOlaries of February, 2002. '-'ii'~1i;~ If ,._"," ~;, ~ ,._ _ ,,.., ,",,""'-r '-"'I ~ > ~ ,~ ,-- NOTICE OF SHERIFF'S SALE OF REAL ESTATE PURSUANT TO PENNSYL VANIA RULE OF CIVIL PROCEDURE 3129.1 TO: Michele 1. Graff Kimberly 1. Hileman 924 Alexander Spring Road Carlisle, PA 17013 AND: ALL LIEN HOLDERS TAKE NOTICE that by virtue of the above Writ of Execution issued out of the Court of Common Pleas of Cumberland County, Pennsylvania and to the Sheriff of Cumberland County, directed, there will be exposed to Public Sale in Cumberland County Courthouse on June 5 , 2002 at 10:00 A.M., the following described real estate, of which Michele 1. Graff and Kimberly 1. Hileman are owners or reputed owners: Twp of Dickinson, Cumberland Cty & CmwIth ofPA. HET a dwg kla924 Alexander Spring Road, Carlisle, PA 17013. Parcel No. 08-09-0523-043. The said Writ of Execution has issued on a judgment in the mortgage foreclosure action of National City Mortgage Co. vs. Michele 1. Graff and Kimberly 1. Hileman at No. 01-7075 Civil Term in the amount of$135,899.15. Claims against property must be filed at the Office of the Sheriff before above sale date. Claims to proceeds must be made with the Office ofthe Sheriff before the sale date. Schedule of Distribution will be filed with the Office ofthe Sheriff no later than thirty (30) days from sale date. Exceptions to Distribution or a Petition to Set Aside the Sale must be filed with the Office of the Sheriff no later than ten (10) days from the date when Schedule of Distribution is filed in the Office of the Sheriff. Attached hereto is a copy of the Writ of Execution. It has been issued because there is ajudgment against you. It may cause your property to be held or taken to pay the judgment. You may have legal rights to prevent your property from being taken. A lawyer can advise you more specifically of these rights. If you wish to exercise your rights YQu must act promptly. '~"*t_,\"iUJI, ,_ ~__~_" "~'~' , I-f,. ' , .~ - lFT ~.,~_ ~, - 0' YOU SHOULD TAKE THIS NOTICE AND THE WRIT OF EXECUTION 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 ADVICE. CUMBERLAND COUNTY BAR ASSOCIATION 2 LIBERTY AVENUE CARLISLE,PA 17013 (717) 249-3166 You may have legal rights to prevent the Sheriffs Sale and the loss of your property, In order to exercise those rights, prompt action on your part is necessary. A lawyer may be able to help you. You may have the right to prevent or delay the Sheriffs Sale by filing, before the sale occurs, a petition to open or strike the judgment or a petition to stay the execution. If the judgment was entered because you did not file with the Court any defense or objection you might have within twenty (20) days after service of the Complaint for Mortgage Foreclosure and Notice to Defend, you may have the right to have the judgment opened in you promptly file a petition with the Court alleging a valid defense and a reasonable excuse for failing to file the defense on time. If the judgment is opened, the Sheriffs Sale would ordinarily be delayed pending a trial of the issue of whether the Plaintiff has a valid claim to foreclose the Mortgage. You may also have the right to have the judgment stricken if the Sheriff has not made a valid return of service of the Complaint and Notice to Defend or if the judgment was entered before twenty (20) days after service or in certain other events. To exercise this right, you would have to file a petition to strike' the judgment. You may also have the right to petition the Court to stay or delay the execution and the Sheriffs Sale if you can show a defect in the Writ of Execution or service or demonstrate any other legal or equitable right. Yau may also have the right to have the Sheriffs Sale set aside if the property is sold for a grossly inadequate price or if there are defects in the Sheriffs Sale. To exercise this right, you should file a petition with the Court after the sale and before the Sheriff has delivered his Deed to the property. The Sherirfwill deliver the Deed if no petition to set aside the sale is filed within ten (10) days from the date when the Schedule of Distribution is filed in the Office of the Sheriff. t?1=@ti- Attorney for Plaintiff 916 Fifth Avenue Pittsburgh, PA 15219 (412) 281-1725 **TllE DEBT COLLECTOR IS ATTEMPTING TO COLLECT A DEBT AND ANY INFORMATION OBTAINED WILL BE USED FOR THAT PURPOSE.** '>:i.~,wr:J~""_,_,, ",_1 __-~_c___"i. " ~; "',, ~ , I~ ' ,_r - ~" .. " ~ " "'~ IN THE COURT OF COMMON PLEAS OF CUMBERLAND COUNTY, PENNSYLVANIA CIVIL DIVISION NATIONAL CITY MORTGAGE CO., NO. 01-7075 CIVIL TERM Plaintiff, vs. MICHELE L. GRAFF and KlMBERL Y L. HILEMAN, both unmarried, Defendants. LEGAL DESCRIPTION ALL THAT CERTAIN tract ofland situate in Dickinson Township, Cumberland County, Pennsylvania, more particularly bounded and described in accordance with a survey by Stephen C. Fisher, R.S., dated November 4, 1976 (revised), as follows: BEGINNING at an iron pin on the Northem dedicated right-of-way line of the Alexander Spring Road (T- 467), a 33 foot right-of-way, said iron pin being also at the Southeast corner of Lot No.6 of the hereinafter mentioned Plan of Lots; thence along the dividing line of Lots Nos. 5 and 6, North 36 degrees 56 minutes 26 seconds West 302.85 feet to an iron pin; thence along the Northern line of Lot No.6, North 31 degrees 21 minutes 40 seconds East 96.63 feet to an iron pin at the corner of Lots Nos. 6 and 7; thence along the dividing line of Lots Nos. 6 and 7, South 58 degrees 38 minutes 20 seconds East 295 feet to an iron pin on the Northern dedicated right-of-way line of Alexander Spring Road (T-467); thence along said right-of- way line, South 31 degrees 21 minutes 40 seconds West a distance of 120.82 feet to an iron pin; thence continuing along same right-of-way line in an arc with a radius of 290.0 feet a distance of 89.18 feet (erroneously described as 8235 feet in prior deed) to an iron pin, the point and place of beginning. BEING Lot No.6 of the Plan of Lots of Dickinson Farms recorded in the Cumberland County Recorder of Deeds Office in Plan Book 29, page 41. HAVING erected thereon a dwelling known as 924 Alexander Spring Road, Carlisle, PA 17013. PARCEL NO. 08-09-0523-043. BEING the same premises which G. Franklin Eichelberger and Linda Marie Eichelberger by deed dated 02/29/2000 and recorded on 03/02/2000 in the Cumberland County, Pennsylvania, Recorder of Deeds Office in Deed Book Volume 217, page 19, granted and conveyed unto Michele L. Graff, unmarried and Kimberly L. Hileman, unmarried, <'\;;W~~:']~t:tl .l ., . ~ " ' T" ". 'i'-'~- " IIJl'1 WRIT OF EXECUTION and/or ATTACHMENT COMMONWEALTH OF PENNSYLVANIA) COUNTY OF CUMBERLAND) TO THE SHERIFF OF CUMBERLAND COUNTY: To satisfy the debt, interest and costs due NATIONAL CITY MORTGAGE CO.,PLANTIFF(S) From MICHELE L, GRAFF AND KIMBERLY L. HILEMAN, 924 ALEXANDER SPRING ROAD, CARLISLE, P A 17013 NO 01-7075 Civil CIVIL ACTION - LAW (I) You are directed to levy upon the property of the defendant( s) and to sell SEE LEGAL DESCRIPTION (2) You are also directed to attach the property of the defendant(s) not levied upon in the possession of GARNISHEE(S) as follows: and to notify the garnishee(s) that: (a) an attachment has been issued; (b) the garnishee(s) is enjoined from paying any debt to Or for the account of the defendant (s) and from delivering any property of the defendant (s) or otherwise disposing thereof; (3) If property of the defendant(s) not levied upon an subject to attachment is found in the possession of anyone other than a named garnishee, you are directed to notify 1rim/her that he/she has been added as a garnishee and is enjoined as above stated. Amount Due $135,899,15 Interest FROM 2/2/02-6/5/02 - $2,917.34 Atty's Conun % Atty Paid $119.90 Plaintiff Paid Date: FEBRUARY 5, 2002 L.L. $.50 Due Protpy,' $1.00 Other Costs CURTIS R. LONG Prothonotary, Civil Division REQUESTING PARTY: Name LOUIS P. VITTI, ESQUIRE Address: 916 FIFTII AVENUE PITTSBURGH, PA 15219 Attorney for: PLAINTIFF Telephone: 412-281-1725 Supreme Court ID No, 01072 ~t)~p p 7rtJ(/1~,r:Dp&- "'''"!'~~!~!liPJ ',~ ~,,","~ ~ ,." , I "~ . , [!f;' ='" -,-~,~~~,"~,- ~""""*%~"'-l"'1f'l'W REAL ESTATE SALE No \ ~ On February 7,2002, the sheriffIevied upon the defendant's interest in the real property situated in Dickinson Township, Cumberland C9unty, P A, !mown and numbered as 924 Alexander Spring Road, Carlisle and more fully described on Exhibit "A" filed .~ Date: February 7,2002 By: .JcL-t C2S~ Real Estate Deputy ~ ~ ~ ~ with this writ and by this reference incorporated herein. ,', ,\ \,,\ ':\ (\ I""" ~~\\, r\~.?"~,: .., \\~ ~'i\ t, (\}\ " ~jl \j ) \ ,~i\",\, ,....l-I..-.1'r\,; :) '. ~:l\'tIr ,r'O 'c;\"(\"(} ';\"j:l\~:1 y,-, " i.".iW}ji~K,~~~~'Il1~I~i@jjilmi!f~"i'if-~"1'~~"'1i'",,.~'!?t"'~'l~"'1",,;;~r~10"'1'~]lijR~~~.ljMW!j1r~";V;':'j;;-;~-;.- "n--"~;'_'_'-""" ~,,---'''' -' ", -- "-->l-\-,,,,,,,--"";';i,'-~,, E~h', j "'~'Tif'T~:;;i' .',>".:+ ;,!,'g'~t;~Wq-)'i)!!f;"~'W!'~:'f%\" 0, f":-" .'~'. .' "' IN THE COURT OF COMMON PLEAS OF CUMBERLAND COUNTY, PENNSYLVANIA NATIONAL CITY MORTGAGE CO., CIVIL DIVISION NO. 01-7075 CIVIL TERM Plaintiff, PRAECIPE TO REISSUE WRIT OF EXECUTION AND AFFIDAVIT OF LAST KNOWN ADDRESS vs. MICHELE 1. GRAFF and KIMBERLY 1. HILEMAN, both unmarried, Code MORTGAGE FORECLOSURE Filed on behalf of Plaintiff Defendants. Counsel of record for this party: Louis P. Vitti, Esquire PA LD, #3810 Supreme Court #01072 Louis P. Vitti & Assoc., P.C. 916 Fifth Avenue Pittsburgh, PA 15219 (412) 281-1725 i'}~'%": ."" ~;~~:;~", -7"''''~. '_ ~.-C-'".~'_-'_ , -,,- " .~- '-''''-,,''''I'~',r-'C',:'!'" ~"-_::"~",, :<^>,_ ,~ -- """". -'-'''-'':'T~''t'''~Y'''''.f.,.", _,~"'--'--_~.,"G"'" ", -c.',~4"'"'''- .,-, '. - IN THE COURT OF COMMON PLEAS OF CUMBERLAND COUNTY, PENNSYLVANIA CIVIL DIVISION NATIONAL CITY MORTGAGE CO., NO. 01-7075 CIVIL TERM Plaintiff, vs. MICHELE 1. GRAFF and KIMBERLY 1. HILEMAN, both unmarried, Defendants, PRAECIPE TO REISSUE WRIT OF EXECUTION IN MORTGAGE FORECLOSURE TO: PROTHONOTARY OF CUMBERLAND COUNTY Kindly Reissue a Writ of Execution in favor of the Plaintiff and against the Defendant(s) in the above-captioned matter as follows: Amount Due $135,899.15 Interest 02/02/02-09/03/03 13.622.07 Total iJ.49.521.22 The real estate, which is the subject matter ofthe Praecipe for Writ of Execution is situate in: Twp of Dickinson, Cumberland Cty & Cmwlth ofP A. HET a dwg k/a 924 Alexander Spring Road, Carlisle, PA 17013. Parcel No. 08-09-0523-043. ~(~~ ~itti' Esquire Attorney for Plaintiff i"~':",__,~_.~ ~ "~."~_~{,~'___,:_/~_,"'~., ",_""!".,,R:, _ _'" ",_.1',< .,c, - ""'__ ",._:_",__]~_.(_,"_, - . .T' '~'J,- ,'~, ., , 1 J J lf - IN THE COURT OF COMM:lN PLEAS OF CUMBERLAND COUNI'Y, PENNSYLVANIA CIVIL DIVIS,IPN PRAECIPE FOR IVRIT OF E{88JTION Caption; Confessed Judgment Other ,4 National City Mortgage Co., vs. F 1 No 01-7075 Civil Term i e . Amount Due $135,899.15 Interest 13,622.07 Atty's Comn Costs \! Michele L. Graff & Kimberly L. Hileman, , ;:-1 ~' c , l" r i' .I ro THE PROIHONJTARY OF THE SAID COURT: I The undersigned hereby certifies that the below does not arise out of a retail . insta.l.J.Irent sale, a:>ntract, or account based on a confession of judgment, but if it does, rt ~, it is based on the appropriate or5.ginal proceeding filed pursuant to Act 7 of 1966 as '~ crrended; and for real property pursuant to Act 6 of 1974 as arrended. f". ?f1 Issue writ of execution in the above rratter to the Sheriff of Cumberland County, for debt, interest and costs upon the following described property of the defendant ( s ) See attached legal description. 1: -'" , ~, :, .', U PRAECIPE FOR A'ITl\OMENl' EXEnmOO ':1, "'I Issue writ of attachrrent to the Sheriff of Cumberland County, for debt, interest and costs, as above, directing attachrrent against the above-nared gaz:nishee{s) for the following property (if real estate, supply six copies of the description; supply four' copies of lengthy personalty list) ":1 ',.', and all other property of the defendant! s) in the possession, custody or Control of the said garnishee(s). ( Indicate) Index this writ agains t the garnishee( s) as a lis pendens against real estate of the defendant ( s) described in the attached exhibit. ~~@~ DATE: April 22, 2003 Signa ture: Print Name: Louis P. Vitti Mdress: 916 Fifth Avenue Pittsburgh, PA 15219 AtCo~ey for: Plaintiff :ele~~one: (412) 281-1725 ,;;fli';Y'l'i_~ i. ~ ~". -", "' ~"""t, _ '-"1- ,~, - ,. ~~<~ ., .---l~ '~'r""- !!l 7CJ ~ ,- fP ~ (Yl s (s. :+ W k 71 () 'll ~ ;q ;--.. g .- . . .~: '-' ~ -_--.~ ~ -, I""="-i__'-'_V~"_F'- """_"$..-_" 'fj ]ilID""~-^-_-"""-;~' :-' 11 n:- 'm:f'-li1.K,Ir?~~"..tcC~;~;I#);{?:-;-; ~ 9.J W.o~~~~ :.oOO~frtO fl)CCC "'0 j I I - .. ~ " "" 'rq ~~ ..0 0 o 0 , ~r ~~~ "' 't7< - (;:J 'i1 ~ [J ..... CI1 ~ CY ~ () C-.:> q c: (,) <-'"'" !J>o ~ ""tJ.--,.-1 V rn f7;~ ;:0 :0 ;;:::::D r-v f,1 zc ~n\_) (/)",0.., 'D <.:;(S .J' < C':c: > ;:l~:B :?r--' :::t z{-_:,:\ '<);0 6 ;:::~m J>c ~< .. ~ 2: ()1 =<! -.J -< " .. , , . .. , , '"' , , , .. I;' I i 1, ,,~~ ," _ -; ~~~,' _~__ __ _~ ".. ,_","I-~,"~~),,_-~._ ,--_,_,,~__, ,., ::~- ,eo, ------!$,'i4?~~::R!JJL~ ,'!IE"" '"",;,:__~~__)~~;i1,~~~~~_>iji<""""'~''''-''t''~f~''';f:;1;;r~'''t?!J)'-:C~W"'Wfl!;t..",!~,j!L'lll;'-~.lMH!~~!j!#!j!g:);"_~",,...___~_0;'-: ",;.*;~";';l~""}~:;;'i",~, '-ji-} " '""f' '<0 .~ IN THE COURT OF COMMON PLEAS OF CUMBERLAND COUNTY, PENNSYLVANIA CIVIL DIVISION NATIONAL CITY MORTGAGE CO., NO. 01-7075 CIVIL TERM Plaintiff, vs. MICHELE 1. GRAFF and KIMBERLY 1. HILEMAN, both unmarried, Defendants. LEGAL DESCRIPTION ALL THAT CERTAIN tract of land situate in Dickinson Township, Cumberland County, Pennsylvania, more particularly bounded and described in accordance with a survey by Stephen C. Fisher, R.S., dated November 4, 1976 (revised), as follows: BEGINNING at an iron pin on the Northern dedicated right-of-way line of the Alexander Spring Road (T-467), a 33 foot right-of-way, said iron pin being also at the Southeast comer of Lot No.6 of the hereinafter mentioned Plan of Lots; thence along the dividing line of Lots Nos. 5 and 6, North 36 degrees 56 minutes 26 seconds West 302.85 feet to an iron pin; thence along the Northern line of Lot No.6, North 31 degrees 21 minutes 40 seconds East 96.63 feet to an iron pin at the comer of Lots Nos. 6 and 7; thence along the dividing line of Lots Nos. 6 and 7, South 58 degrees 38 minutes 20 seconds East 295 feet to an iron pin on the Northern dedicated right-of-way line of Alexander Spring Road (T-467); thence along said right-of-way line, South 3\ degrees 2\ minutes 40 seconds West a distance of 120.82 feet to an iron pin; thence continuing along same right-of-way line in an arc with a radius of290.0 feet a distance of89.l8 feet (erroneously described as 82.35 feet in prior deed) to an iron pin, the point and place of beginning. BEING Lot No.6 of the Plan of Lots of Dickinson Farms recorded in the Cumberland County Recorder of Deeds Office in Plan Book 29, page 41. HAVING erected thereon a dwelling known as 924 Alexander Spring Road, Carlisle, PA 17013. PARCEL NO. 08-09-0523-043. BEING the same premises which G. Franklin Eichelberger and Linda Marie Eichelberger by deed dated 02/29/2000 and recorded on 03/02/2000 in the Cumberland County, Pennsylvania, Recorder of Deeds Office in Deed Book Volume 217, page 19, granted and conveyed unto Michele 1. Graff, unmarried and Kimberly 1. Hileman, unmarried. ;nl!!tm"'ll't ~, ' ,~ " ',' ~, " "'1 ' -~~'r' , - -~ , _ ~n_ '. " ~ -. ~ ',~ ., " 1" --~- ':~"""'" i*",tf"(~'~""lii(\t""ht :~ ""c, -' '-'-"1~ "j ''"- ,-, IN THE COURT OF COMMON PLEAS OF CUMBERLAND COUNTY, PENNSYLVANIA CIVIL DIVISION NATIONAL CITY MORTGAGE CO., NO. 01-7075 CIVIL TERM Plaintiff, vs. ~i ji ~ MICHELE 1. GRAFF and KIMBERLY 1. HILEMAN, both unmarried, Defendants. AFFIDAVIT I, Louis P. Vitti, do hereby swear that, to the best of my knowledge, information and belief, the Defendant(s), is/are the owners of the real property on which the Plaintiff seeks to execute. That the Defendants' last known address is 924 Alexander Spring Road, Carlisle, PA 17013, LC;~~. OUlS . Ittl, sqUIre SWORN TO and subscribed before me this 22nd day of April,2003. NOTARIAL SEAL ._ t.l!VANGl!1I8TA. NarAlf'f pUBIJC ...... ................... "'''HENY COUNTY CIlYOF.."........-............ MYCOMf,ISSION EXPIRES OC1QBER 17. 2005 -"-\~r_" '-<-;?o' :-::?",,~"'_!;'c:>-<'_-:'-'," ~--,_ -"I' , , '-, ~ ~ ;jjJ ""'>'" "",' " ,',,",' ,,,,,"'W',d''''"'''"','"'',,,,,,,e,,C,''',''''""e,ec1'''''''''''' ...! ',J"'iv,' , , ',i.;' )~i ~- - "" ~. ~ ,.~ . ..' "'-,-w' -'-""-'0"~'i*~'''' - - -~_~'-~-r~l'ilrr'"-rr ':l~'t" '~''"~J:~:'T_~,,~,*;li (") c s: *1:'CG mf~l Z:.:n ~j~: ~B :'] -. -" 5=' I.....) o '7" :::::1 ,~;\ ---;""] "F "',-'}rr; ','7Ci , : ,~~ ,-' )::....: -'~ -< "~~._~'~ J.;:~JJ~~t;v.;'~""'"'''''''''''''''''\''''' '" ''::'':' .At'Ji,i"':~',"II?l,' ,A" il(l, 'I ,L,(" ' '~~ q~ If~\ i,,'t:1"'(1~q *~fl \'i'~'f."" . , ' -'.;- I.;, '_''1'' , ~ ~ bo "::J ,'v 1'" VJ 5: :~~ ;'.11 .,-' , A_ i.~ '~'i'__c;>~"*:.~y.r;,<rL"I'!~~JJJ~'~;!-'~~~~~~f!f'~-~r l~1T&q~:I!ff,~~!:t~l01~_t<_"' ~~~JI~!l;1.~~.;:~;~~1 WRIT OF EXECUTION and/or ATTACHMENT COMMONWEALTH OF PENNSYL VANIA) COUNTY OF CUMBERLAND) NO 01-7075 Civil CML ACTION - LAW TO THE SHERIFF OF CUMBERLAND COUNTY: To satisfy the debt, interest and costs due NATIONAL CITY MORTGAGE CO., Plaintiff (s) From MICHELE L. GRAFF AND KIMBERLY L. IDLEMAN, 924 ALEXANDER SPRING ROAD, CARLISLE, P A 17013 (i) You are directed to levy upon the property of the defendant (s)and to sell SEE LEGAL DESCRIPTION . (2) You are also directed to attach the property of the defendant(s) not levied upon in the possession of GARNISHEE(S) as follows: and to notify the garnishee(s) that: (a) an attachment has been issued; (b) the garnishee(s) is enjoined from paying any debt to or for the account of the defendant (s) and from delivering any property of the defendant (s) or otherwise disposing thereof; (3) Ifproperty of the defendant(s) not levied upon an subject to attachment is found in the possession of anyone other than a named garnishee, you are directed to notify hirn/her that he/she has been added as a garnishee and is enjoined as above stated. Amount Due $135,899.15 Interest $13,622.07 Arty's Connn % L.L, Arty Paid $213.95 Plaintiff Paid Date: APRIL 29, 2003 Due prothy $1.00 Other Costs (Seal) CURTIS R. LONG prothon~ ~ 1Yt.~ - f?. 7fcYl.A....,. r Deputy REQUESTING PARTY; Name LOUIS P. VITTI, ESQUIRE Address: 916 FIFTH AVENUE PITTSBURGH, PA 15219 Attorney for; PLAINTIFF Telephone: 412-281-1725 Supreme Court ID No. '~'~:"'~\"~)1,Si~l!l~,~,"~,""~",,",~,_ ;, _~4 - "~r~ ,_ c~ .1 ~-~~, - ""7P"""~'~' -~ "'~~ -i'i!"W{1:~;\{~"^_'(,,~~~O- '<-'.'-- -- 'ft-. ",,' - ~ IN THE COURT OF COMMON PLEAS OF CUMBERLAND COUNTY, PENNSYLVANIA CML DIVISION NATIONAL CITY MORTGAGE CO., NO. 01-7075 CIVIL TERM Plaintiff, vs. " :I !i !i .;1 j MICHELE 1. GRAFF and KIMBERLY 1. HILEMAN, both unmarried, Defendants. 'i :i -f! , "I :i! LEGAL DESCRIPTION ., -~ -,f ALL THAT CERTAIN tract of land situate in Dickinson Township, Cumberland County, Pennsylvania, more particularly bounded and described in accordance with a survey by Stephen C. Fisher, R.S., dated November 4, 1976 (revised), as follows: j , 'I ,:!. 0' ;i: "i ;, 1i I " I BEGINNING at an iron pin on the Northern dedicated right-of-way line of the Alexander Spring Road (T-467), a 33 foot right-of-way, said iron pin being also at the Southeast corner of Lot No.6 ofthe hereinafter mentioned Plan of Lots; thence along the dividing line of Lots Nos. 5 and 6, North 36 degrees 56 minutes 26 seconds West 302.85 feet to an iron pin; thence along the Northern line of Lot No.6, North 31 degrees 21 minutes 40 seconds East 96.63 feet to an iron pin at the corner of Lots Nos. 6 and 7; thence along the dividing line of Lots Nos. 6 and 7, South 58 degrees 38 minutes 20 seconds East 295 feet to an iron pin on the Northern dedicated right-of-way line of Alexander Spring Road (T -467); thence along said right-of-way line, South 31 degrees 21 minutes 40 seconds West a distance of 120.82 feet to an iron pin; thence continuing along same right-of-way line in an arc with a radius of290.0 feet a distance of89.18 feet (erroneously described as 82.35 feet in prior deed) to an iron pin, the point and place of beginning. -,~! \1- ii 'd :) BEING Lot No.6 of the Plan of Lots of Dickinson Farms recorded in the Cumberland County Recorder of Deeds Office in Plan Book 29, page 41. HAVING erected thereon a dwelling known as 924 Alexander Spring Road, Carlisle, PA 17013. , , PARCEL NO, 08-09-0523-043. BEING the same premises which G. Franklin Eichelberger and Linda Marie Eichelberger by deed dated 02/29/2000 and recorded on 03/02/2000 in the Cumberland County, Pennsylvania, Recorder of Deeds Office in Deed Book Volume 21 7, page 19, granted and conveyed unto Michele 1. Graff, unmarried and Kimberly 1. Hileman, unmarried. {~i.~_!'. "'., "--t;~'" "-',~7,>-'r-"'..' __ ",n_,."'''' ''G:_I,''"~' ',,_ c" c-'"--- . ~""~ .~, .~< ~~jt;><r ',"'-'i' "r" '~d"" IN THE COURT OF COMMON PLEAS OF CUMBERLAND COUNTY, PENNSYLVANIA CIVIL DIVISION NATIONAL CITY MORTGAGE CO., NO. 01-7075 CIVIL TERM Plaintiff, vs. MICHELE 1. GRAFF and KIMBERLY 1. HILEMAN, both urnnarried, Defendants. AFFIDAVIT I, Louis P. Vitti, hereby certify that as representative of National City Mortgage Co. am familiar with the above-captioned case and various servicing activities related thereto and that the provisions of the laws of the Commonwealth of Pennsylvania and specifically, Act 91 of 1983, have been complied with in the above-captioned case. ~_. L PY"E" /t66b- OUlS . Ittl, sqUIre Attorney for Plaintiff SWORN to and subscribed before me this 22nd day of April, 2003. ~~4J Notary Public -; NOTARIAL SEAL LOIS ,.. EVANGEUSTA, NOTARY PUBlIC CITY OF PIT1SBURGH, ALLEGHENY COUNTY MYCOMMISSION EXFIRES OClOllER 17, 2005 ";~~ -_.'~_ O"7.'}_ - ~,,~ - -" 't'".,.--' -'--,..,._"-(,,. '~-". ~ " ,- " , - -f- ~ ^ ~- c"_""" 'M_'~_'"," 'C>o ""-h;;H~",~,;,__"_v"';;Qih' :,-:r~' '"-'~l'~~\t~ '-' - "",;:1-')':'<':'~" ::"s~:;n5:~}:iif't~~~0i o c ~ -on:: fllr"..-: Z:r '7r~' (f.)J.';o -..(;,: ~c p(-, z'"' )>~~ =I ,"<, -, '; 0 'l~'" -,~~"-~::'~t] k,' ,,: a w ,.,. 'u :00 ,"'J '1:) o -n '--1 --1'" ;~-i~'1 -"'~~it5 "3~~~ ~;~ ~-~ i:jrn ~;;} ::J:l -< ~ :.:!: (5 :.n -...J ~-~'~kV" '~""_;',_'~'~"'':'"'",(__, "J". ~.- _-;,.- >"0'_ X';",\";"!:,':'!'~,:,,\~,,A:::"r_-'-, ,_~, _,__"\!,,,,,r'~t~) ,~..;c - "J '~!:"%:'-'_~;"k-Y;!'''';::'l!!f~~~,~~~~<6!ft~ll1*~',;if,':m;~~~,~~~~IK~~!lJC~J!~ilW.~L_~~j"O~ "~;''''''@''f'I"<i'''' ""j~" -'-i>.'.' --, "',] "." ... IN THE COURT OF COMMON PLEAS OF CUMBERLAND COUNTY, PENNSYLVANIA CIVIL DIVISION NATIONAL CITY MORTGAGE CO., NO. 01-7075 CIVIL TERM Plaintiff, vs. MICHELE 1. GRAFF and KIMBERLY 1. HILEMAN, both unmarried, Defendants. AFFIDAVIT PURSUANT TO RULE 3129.1 National City Mortgage Co, Plaintiff in the above action, sets forth as ofthe date the Praecipe for the Writ of Execution was filed the following information concerning the real property located at 924 Alexander Spring Road, Carlisle, P A 17013. L Name and address ofOwner(s) or Reputed Owner(s): Name: Address (Please indicate ifthis cannot be reasonably ascertained) Michele 1. Graff Kimberly 1. Hileman 924 Alexander Spring Road Carlisle, PA 17013 2. Name and address ofDefendant(s) in the judgment: Name: Address (please indicate ifthis cannot be reasonably ascertained) Same as No.1 above. 3. Name and last known address of every judgment creditor whose judgment is a record lien on the real property to be sold: Name: Address (Please indicate if this cannot be reasonably ascertained) None "'~~, "~'_',-_i_"}'~,,,,:J,__,__ ,'1',,- ,,--,'_"'~", ;-;,,,p,/~cr~-,_,~"I ,_"i.I-, '0_-.. '17-~'--?,7~~'"",' - - -, 'c, ",_~,""'?_;>_",",,: -,"'" '.,~y_ . f- 'f:1"'f!r!"" ~>, -',"'1 ':~,;_L r I~ r ," _'"b~ ,,,,'''"'- < 4. Name and address of the last recorded holder of every mortgage of record: Name Address (Please indicate ifthis cannot be reasonably ascertained) None ,I ! 5. Name and address of every other person who has any record lien on the property: Name Address (Please indicate if this cannot be reasonably ascertained) "Ii I i ;'; None + j 6. Name and address of every other person who has any record interest in or record lien on the property and whose interest may be affected by the sale: -'!i , II Name Address (please indicate if this cannot be reasonably ascertained) j; I , None ii , <:' 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: 'J' , ii Name Address (Please indicate if this cannot be reasonably ascertained) jl 'I' Tax Collector of Dickinson Township 1044 Pine Road Carlisle, PAl 7013 'Ii I; 'ii :;, Commonwealth ofPA -DPW P.O, Box 8016 Harrisburg, P A 17105 " IL Clerk of Courts Criminal/Civil Division One Courthouse Square Carlisle, PA 17013 , " :i Court of Common Pleas of Cumberland County Domestic Relations Division P.O. Box 320 Carlisle, P A 17013 Tax Claim Bureau of Cumberland County Cumberland County Courthouse One Courthouse Square Carlisle, P A 17013 '-~~J~~~r;;,~",,_ _'"n~,;, '_:""',"_'__ ~ < "":1 " ',' - '-,---,-~_, -_,0' (,".'fr&'{f "j-'<:'< ,,- f' '_~: N" ~'"-. Bureau of Compliance Clearance Support Section Dept. #281230 Harrisburg, PA 17128-1230 Attn: Susan Blough Tenant/Occupant 924 Alexander Spring Road Carlisle, PA 17013 ,) ~! 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. -.'! ~~: ';i ':" April 22. 2003 Date ~- L . P yo 'E" ~ oms . lttl, sqmre Attorney for Plaintiff f SWORN TO and subscribed before me this 22nd day of April, 2003. '" ~ 'j'; NOTARIAL SEAL LOIS It. I!VANGEUSTA, NOTARY I'UBI..IC ClTYOFPl1TS8lJRllH. AI.l.EGHENYCOUNTY MYOOMMlllSIONEllPIRES OClllBER 17, 2005 ,I;.. !~~ ~--,\'l!l:'.,1\'t:. M,. .' ^<", __ ~,"';''''''<'5 - ',' .'.n-- , ,'-. '__',"I':'.~ ".- hIc"'_" .--; '';0'"'' .~""'~"-- --.,. - . , V", _, ~ .~ <:l !!!l!l '..'%,.. '",e........' =-,- '...,'..'..?....'....,'....,..',"<....",,,......,..."',,,,....', :/, '-1 , ~H- ;-, ~j -'~;. '':"';'''', f'yj ,A~' ,:;) ."'!; :'l . '. ~\, __ i'i -" -""":lli'1iliMClll1JJfIl.:CJ '," 0" Jlffu"1iji~u :-~\".-r~~c'iJ'.f:t";~'i>;;:'f};;},gi3' o c ~ t.JlJ., Q)[fi ~~~~: -<.-.- ~c:: ~~ -'.. -( !J..IIiIg,.."..~,.."",,,,,,-~.., , . '. >t'>,,,,1~''\_~'''''~~{fS''''':';', __."rl,~,,,,,, /"_ -, _ <:::> <,~t :t='" -'0 ;;:> o -0 ~~~;.~ ]~;9 '-~:;C) ~~~ "t':.-"': ::9 -- i" \.D ~ 3: '2 ..J1 (XI i; <,C: _i....I.. ,i.';;;;:;'~il~;i2!:i-"$"~,,\,,,,~_,~:-;:'-_ ':'It l': .' ,~,'" '~": >~ ""'~ NOTICE OF SHERIFF'S SALE OF REAL ESTATE PURSUANT TO PENNSYL VANIA RULE OF CIVIL PROCEDURE 3129.1 OJ i, .i TO: Michele 1. Graff Kimberly 1. Hileman 924 Alexander Spring Road Carlisle, P A 17013 '_'i ~ \ :J :~--:! AND: ALL LIEN HOLDERS "Cl II TAKE NOTICE that by virtue of the above Writ of Execution issued out of the Court of Common Pleas of Cumberland County, Pennsylvania and to the Sheriff of Cumberland County, directed, there will be exposed to Public Sale in Cumberland County Courthouse on September 3, 2003 at 10:00 A.M., the following described real estate, of which Michele 1. Graff and Kimberly L. Hileman are owners or reputed owners: :'~ <; .~~ iti \j, ')1 ""1 ::;; ;,~:: , Twp of Dickinson, Cumberland Cty & Cmwlth ofP A. HET a dwg k/a 924 Alexander Spring Road, Carlisle, PA 17013. Parcel No. 08-09-0523-043. ~~:: ,::: -i;i The said Writ of Execution has issued on a judgment in the mortgage foreclosure action of National City Mortgage Co~ vs. Michele 1. Graff and Kimberly 1. Hileman at No. 01-7075 Civil Term in the amount of$135,899.15. Claims against property must be filed at the Office ofthe Sheriff before above sale date. Claims to proceeds must be made with the Office of the Sheriff before the sale date. Schedule of Distribution will be filed with the Office of the Sheriff no later than thirty (30) days from sale date. Exceptions to Distribution or a Petition to Set Aside the Sale must be filed with the Office ofthe Sheriff no later than ten (10) days from the date when Schedule of Distribution is filed in the Office of the Sheriff. Attached hereto is a copy of the Writ of Execution. It has been issued because there is a judgment against you. It may cause your property to be held or taken to pay the judgment. You may have legal rights to prevent your property from being taken. A lawyer can advise you more specifically of these rights, If you wish to exercise your rights you must act promptly. ~\~, ."',~~,',,,' '.>-;!i'-"'__~%;<, ","">"~~- ,,--.,"'~"';'I': "" 'c'o'C -->~,~-'"- ,'~ ," - ", ,~,. . 'r, ", . ,""T':'"""" f',~-" ""f-r~nJ ': '!i.'1i --( '-]t'~ .- ---";'" YOU SHOULD TAKE THIS NOTICE AND THE WRIT OF EXECUTION TO YOUR LA WYERAT 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 ADVICE. CUMBERLAND COUNTY BAR ASSOCIATION 2 LIBERTY AVENUE CARLISLE, P A 17013 (717) 249-3166 :j I ,;i I " You may have legal rights to prevent the Sheriffs Sale and the loss of your property. In order to exercise those rights, prompt action on your part is necessary. A lawyer may be able to help you. -ii ;;~I 'I 1'1 :1 31 '11 ,i :1 lj, :1' .'", ,- ~I' ,I " '''1) I :1 'ii ";: , "~~i , , You may have the right to prevent or delay the Sheriffs Sale by filing, before the sale occurs, a petition to open or strike the judgment or a petition to stay the execution. If the judgment was entered because you did not file with the Court any defense or objection you might have within twenty (20) days after service ofthe Complaint for Mortgage Foreclosure and Notice to Defend, you may have the right to have the judgment opened in you promptly file a petition with the Court alleging a valid defense and a reasonable excuse for failing to file the defense on time. If the judgment is opened, the Sheriffs Sale would ordinarily be delayed pending a trial of the issue of whether the Plaintiff has a valid claim to foreclose the Mortgage. You may also have the right to have the judgment stricken if the Sheriff has not made a valid return of service of the Complaint and Notice to Defend or if the judgment was entered before twenty (20) days after service or in certain other events. To exercise this right, you would have to file a petition to strike the judgment. , -~i ! :.:i <I i i You may also have the right to petition the Court to stay or delay the execution and the Sheriffs Sale if you can show a defect in the Writ of Execution or service or demonstrate any other legal or equitable right. ,i I ! You may also have the right to have the Sheriffs Sale set aside if the property is sold for a grossly inadequate price or if there are defects in the Sheriffs Sale, To exercise this right, you should file a petition with the Court after the sale and before the Sheriff has delivered his Deed to the property. The Sheriff will deliver the Deed if no petition to set aside the sale is filed within ten (IO) days from the date when the Schedule of Distribution is filed in the Office of the Sheriff. ,;., j ;~i :\j , 5j I ::'1 -j ~ I LV)'- . L~~PV"E' ~ OUlS . IttI, sqUIre Attorney for Plaintiff 916 Fifth Avenue Pittsburgh, PA 15219 (412) 281-1725 **THE DEBT COLLECTOR IS ATTEMPTING TO COLLECT A DEBT AND ANY INFORMATION OBTAINED WILL BE USED FOR THAT PURPOSE.** '-I g~1pt.~, ", -,- ., -~-' "r' -f-- " ~,- -- " ,... ',- ,- - , -, "I:y~ .' J _~_"__ ,,~ . " -,-'-- ,_v "'1' -" ",,~., , r,' 'itf""_' "<It,- u_.- ~-...". ," IN THE COURT OF COMMON PLEAS OF CUMBERLAND COUNTY, PENNSYLVANIA CIVIL DIVISION NATIONAL CITY MORTGAGE CO., NO. 01-7075 CIVIL TERM Plaintiff, vs. MICHELE L. GRAFF and KlMBERL Y L. HILEMAN, both unmarried, Defendants. LEGAL DESCRIPTION ALL THAT CERTAIN tract of land situate in Dickinson Township, Cumberland County, Pennsylvania, more particularly bounded and described in accordance with a survey by Stephen C. Fisher, R.S., dated November 4, 1976 (revised), as follows: BEGINNING at an iron pin on the Northern dedicated right-of-way line of the Alexander Spring Road (T-467), a 33 foot right-of-way, said iron pin being also at the Southeast corner of Lot No.6 of the hereinafter mentioned Plan of Lots; thence along the dividing line of Lots Nos. 5 and 6, North 36 degrees 56 minutes 26 seconds West 302.85 feet to an iron pin; thence along the Northern line of Lot No.6, North 31 degrees 21 minutes 40 seconds East 96.63 feet to an iron pin at the corner of Lots Nos. 6 and 7; thence along the dividing line of Lots Nos. 6 and 7, South 58 degrees 38 minutes 20 seconds East 295 feet to an iron pin on the Northern dedicated right-of-way line of Alexander Spring Road (T-467); thence along said right-of-way line, South 31 degrees 21 minutes 40 seconds West a distance of 120.82 feet to an iron pin; thence continuing along same right-of-way line in an arc with a radius of290.0 feet a distance of89.18 feet (erroneously described as 82.35 feet in prior deed) to an iron pin, the point and place of beginning. BEING Lot No.6 of the Plan of Lots of Dickinson Farms recorded in the Cumberland County Recorder of Deeds Office in Plan Book 29, page 41. HA VING erected thereon a dwelling known as 924 Alexander Spring Road, Carlisle, PA 17013. PARCEL NO, 08-09-0523-043. BEING the same premises which G. Franklin Eichelberger and Linda Marie Eichelberger by deed dated 02/29/2000 and recorded on 03/02/2000 in the Cumberland County, Pennsylvania, Recorder of Deeds Office in Deed Book Volume 217, page 19, granted and conveyed unto Michele L. Graft~ unmarried and Kimberly L. Hileman, unmarried. -'1!~llO)!lf, ~1 .,. "I. ".~ - I' '-'Y I' ~ ill ~ "~, "" ""e", ''" ~",'" " tr'~' tr'[~"r'nln Ie '1ffwW"~ , 0 0 0 c v~, -n .?".:;:: :~ ....J uCG "1J "T' nlrT :::0 flip Z:I~ Z I~ ~.) '"I''''f71 (f.> (.1.) :~j? -< ...:-:: ;'-;c) ~c: :7;~,. ,-Ii J>r'" ::t1.: .:,~2) Zi'(, )> .-' 15 ~~m c '....; --I Z U1 55 =2 0;' -< %6 ~~~l!!I1lr___ ll1ii,;m,U'...T _.~~_~:m~.~,~~~"'!llSIrM:j.,""itlOOi):,._~~""~W"'~~~~1E?~Hi_':<"'" iil,(:,'_"":"~ \{-""'''4,,,,,''1''-;;;ST~iW-"i?'\i~;f$_~[<JZ;;C(~~_\;f~jl''2$\_1;;fJ;~;~.';ffi__~~~,'" ~~~~'j,,"'l"<"" ":"'" .'--C I'~'''~'_~ IN THE COURT OF COMMON PLEAS OF CUMBERLAND COUNTY, PENNSYLVANIA NATIONAL CITY MORTGAGE CO., CIVIL DIVISION NO. 01-7075 CIVIL TERM Plaintiff, AMENDED AFFIDAVIT PURSUANT TO RULE 3129.1 vs. Code MORTGAGE FORECLOSURE MICHELE 1. GRAFF and KIMBERLY 1. HILEMAN, both unmarried, Filed on behalf of Plaintiff Defendants. Counsel of record for this party: Louis P. Vitti, Esquire PA LD. #3810 Supreme Court #01072 Louis P. Vitti & Assoc., P.C. 916 Fifth Avenue Pittsburgh, PA 15219 (412) 281-1725 "'i'i:"~~~_",,,,,~ 'W -'. ,-"~_"'~~''''_ _ ,"{e,,"',!",':'-''''':''''_ ',:C,,' "'Co-__, ,"" '''_'1,,-'_'''':-~1 _,,-'f- _',0_ d ',,' ',''''''-' r_' " -?'" - ~".".. *lWW*J!o;"-'''f'b',::;~;;i;',,~,+ NO," -: - '1 '1 . 'J .' - - '-",,$'-W>.: ~,~ ,\~ ",^~,_~ IN THE COURT OF COMMON PLEAS OF CUMBERLAND COUNTY, PENNSYL VANIA CIVIL DIVISION NATIONAL CITY MORTGAGE CO., NO. 01-7075 CIVIL TERM Plaintiff, vs. MICHELE 1. GRAFF and KIMBERLY 1. HILEMAN, both unmarried, Defendants. AMENDED AFFIDAVIT PURSUANT TO RULE 3] 29.] National City Mortgage Co, Plaintiff in the above action, sets forth as ofthe date the Praecipe for the Writ of Execution was filed the following information concerning the real property located at 924 Alexander Spring Road, Carlisle, PA 17013. 1. Name and address ofOwner(s) or Reputed Owner(s): Name: Address (Please indicate if this cannot be reasonably ascertained) Michele 1. Graff Kimberly 1. Hileman 924 Alexander Spring Road Carlisle, PA 17013 2. Name and address ofDefendant(s) in the judgment: Name: Address (Please indicate if this cannot be reasonably ascertained) Same as No.1 above. 3. Name and last known address of every judgment creditor whose judgment is a record lien on the real property to be sold: Name: Address (please indicate if this cannot be reasonably ascertained) Cumberland County Adult Probation 1 Courthouse Square Carlisle, P A 17013 .,' ~, ;- - f "". ~ . -',' ..' ""v;;,<<;~", ~;",~"_~H:">e_,,,,;,.-:' ~ ': {f ." '[(~:ii!''''<~\~~-"' ~I" 4. Name and address of the last recorded holder of every mortgage of record: Name Address (Please indicate if this cannot be reasonably ascertained) _oJ None 5. Name and address of every other person who has any record lien on the property: Name Address (Please indicate if this cannot be reasonably ascertained) "'j None 6. Name and address of every other person who has any record interest in or record lien on the property and whose interest may be affected by the sale: Name Address (Please indicate if this cannot be reasonably ascertained) 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 Address (Please indicate if this cannot be reasonably ascertained) Tax Collector of Dickinson Township 1044 Pine Road Carlisle, PA 17013 Commonwealth ofPA -DPW P.O. Box 8016 Harrisburg, PA 17105 Clerk of Courts Criminal/Civil Division One Courthouse Square Carlisle, P A 17013 Court of Common Pleas of Cumberland County Domestic Relations Division P.O, Box 320 Carlisle, PA 17013 Tax Claim Bureau of Cumberland County Cumberland County Courthouse One Courthouse Square Carlisle, P A 17013 "O_-'-l;~.," _~ co ,"-" ~~" '~~o_~_1_~_' .:r-."__'I:'" - ',- Fj~''#'<~ti;_~~r}~'i;~''-~",: \. "'Ui' cp' '~:',~r'""\'''>~ ':' '~'f ,- ... '. ~^' Bureau of Compliance Clearance Support Section Dept. #281230 Harrisburg, PA 17128-1230 Attn: Susan Blough Tenant/Occupant 924 Alexander Spring Road Carlisle, P A 17013 , " 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. May 8. 2003 Date ~~. Louis P. Vitti, Esquire Attorney for Plaintiff SWORN TO and subscribed before me this 8th day of May, 2003. ...... SIAL ..Ill rw "" NOrMY PU8UC ..In ._.....~M1EGHENY COUNTY M'fOllMllSSlONElCPIAESOClOBER 17, 2(105 _'f--WI'~~ - '--'='. ,,~. -''', c_ ,'. _"_,I,' -~--'" .n'._'....., . ~< - ."." , . ! . l! _.-~^ > ,^",,-, ~-._.,~ -v----""w~-_~;~'-Q V'1f"_o ~-.~._-.._-"',"'" ,UWl J.I\IM1mI 'X ,n '~"f1Al~ Jrillll~.. ,\(, rnHJ!llUII ,H!J!IU611T1'I'I'lOm .{1 ;'~'~n '\ :ji~~X:! ~Oj1?'~J':Mt~vt~ ~~~ ~~~, L.,~. .~_?_, -"(':1""[9)(';- Fa" ,~i:;kk:Wi:4:if_~~{:f~~~F!-;_1~%;_4\:;X;) -oc;~.' rnj' -:.-- ._,- .::.". ~.~ :r:; <~ > () C ;-:;,. .".." .,'",',"-'. (:;::' c...,':;' c; "1'1 __'!h ';"~l" c- :r-, ""-c} - :~ li~ri , r.- j::.; c...::' ~< i'.. ,-_,~ ," ?'-'-, ,_~L", ,.~ - L- '~-':f-- . , '-~-'~--'-~J!__:_:~~:,;,~;,~:;-,~~,:,_~_~,_,~~~"~~!f?J'Jll"~*'lf~!ji!~m~~llr~~ili:~_tJ!J_~~lJIltl1!~mn~~NL v'~~:: -'n_ - ')Jr "'JMj "', ",'--,-0" -~- '''''J:-F':'?f,~'l\1!lllJ\1lr: _ National City Mortgage Co, VS Michele 1. Graff and Kimberly 1. Hileman In The Court of Common Pleas of Cumberland County, Pennsylvania Writ No. 2001-7075 Civil Term R. Thomas Kline, Sheriff, who being duly sworn according to law, states this writ is returned STAYED pursuant to instructions from Attorney Louis P. Vitti. Sheriffs Costs: Docketing Poundage Surcharge Prothonotary Mileage Levy 30.00 1.59 30.00 1.00 3.45 15.00 $ 81.04 paid by attorney 5/16/03 This )./7!!:' day of ~ 2003, AD.0r-" () So Answers: ?'~~~~ R. Thomas Kline, Sheriff f11,I", " +1 ~~ ~+h BY 1 t SW-.D Real Estate Deputy Sworn and subscribed to before me Prothonotary '\.00 , ,,,,t!, _ ~'_ w '. , , , ,", -I'~' - '"' . ,<~ r'" - , 4 0'1 s'~ e.;.,- ~J3f:J.51 " --~ .1 ij , IN THE COURT OF COMMON PLEAS OF CUMBERLAND COUNTY, PENNSYLVANIA CIVIL DIVISION NATIONAL CITY MORTGAGE CO., NO. 01-7075 CIVIL TERM Plaintiff, vs. MICHELE 1. GRAFF and KIMBERLY 1. HILEMAN, both unmarried, Defendants. AFFIDAVIT PURSUANT TO RULE 3129.1 National City Mortgage Co, 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 924 Alexander Spring Road, Carlisle, PA 17013. 1. Name and address ofOwner(s) or Reputed Owner(s): Name: Address (Please indicate if this cannot be reasonably ascertained) Michele L. Graff Kimberly L. Hileman 924 Alexander Spring Road Carlisle, PA 17013 2. Name and address ofDefendant(s) in the judgment: Name: Address (Please indicate if this cannot be reasonably ascertained) Same as No, 1 above. 3. Name and last known address of every judgment creditor whose judgment is a record lien on the real property to be sold: Name: Address (Please indicate if this cannot be reasonably ascertained) None -'lJl'')o,,~~ ~ ,~- . ~ ,=" - , ",-,- - , ,-" ~,,-r-~I_~_ " ~ il- -;.- "., '(1 . ~ .'r "' 4. Name and address of the last recorded holder of every mortgage of record: Name Address (Please indicate if this cannot be reasonably ascertained) None S. Name and address of every other person who has any record lien on the property: Name Address (Please indicate if this cannot be reasonably ascertained) None 6. Name and address of every other person who has any record interest in or record lien on the property and whose interest may be affected by the sale: Name Address (Please indicate if this cannot be reasonably ascertained) 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 Address (Please indicate if this cannot be reasonably ascertained) Tax Collector of Dickinson Township 1044 Pine Road Carlisle, P A 17013 Commonwealth ofPA -DPW P.O. Box 8016 Harrisburg, P A 17105 Clerk of Courts Criminal/Civil Division One Courthouse Square Carlisle, PA 17013 Court of Conunon Pleas of Cumberland County Domestic Relations Division P.O. Box 320 Carlisle, P A 17013 Tax Claim Bureau of Cumberland County Cumberland County Courthouse One Courthouse Square Carlisle, P A 17013 '",W""'-f-"L,,,,,,~..,,,",, ~ ~- - -. >"" " ,~ -'- A~ - ~ ", ,~- T'" , T'-. . ~. - -,~ "." Bureau of Compliance Clearance Support Section Dept. #281230 Harrisburg, PA 17128-1230 Attn: Susan Blough Tenant/Occupant 924 Alexander Spring Road Carlisle, P A 17013 ," 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 unswom falsification to authorities. April 22. 2003 Date ~9~ Louis P. Vitti, Esquire Attorney for Plaintiff SWORN TO and subscribed before me this 22nd day of April, 2003. NOTARIAL SEAL LOIS A. EVANGEUSTA, NOTARY PUBLIC CITY OF PITTSBURGH, AllEGHENY COUNTY MY COMMISSION EXPIRES OCTOBER 17, 2005 ;;w~ .~~. -. " ., -'-' '"!C- .~ ,,"'\'- "' '"' ~-~TI"'L~n l_,l-~'f apf, ~"_I-' "- K_ :""'- '--".J~ ~ '!" NOTICE OF SHERIFF'S SALE OF REAL ESTATE PURSUANT TO PENNSYLVANIA RULE OF CIVIL PROCEDURE 3129.1 TO: Michele 1. Graff Kimberly 1. Hileman 924 Alexander Spring Road Carlisle, P A 17013 AND: ALL LIEN HOLDERS TAKE NOTICE that by virtue of the above Writ of Execution issued out of the Court of Common Pleas of Cumberland County, Pennsylvania and to the Sheriff of Cumberland County, directed, there will be exposed to Public Sale in Cumberland County Courthouse on September 3, 2003 at 10:00 A.M., the following described real estate, of which Michele 1. Graff and Kimberly 1. Hileman are owners or reputed owners: Twp of Dickinson, Cumberland Cty & Cmwlth ofPA. HET a dwg k/a 924 Alexander Spring Road, Carlisle, PA 17013. Parcel No. 08-09-0523-043. The said Writ of Execution has issued on a judgment in the mortgage foreclosure action of National City Mortgage Co. vs, Michele 1. Graff and Kimberly 1. Hileman at No. 01-7075 Civil Tenn in the amount of$135,899.15, Claims against property must be filed at the Office of the Sheriff before above sale date. Claims to proceeds must be made with the Office of the Sheriff before the sale date. Schedule of Distribution will be filed with the Office of the Sheriffno later than thirty (30) days from sale date. Exceptions to Distribution or a Petition to Set Aside the Sale must be filed with the Office of the Sheriff no later than ten (10) days from the date when Schedule of Distribution is filed in the Office of the Sheriff. Attached hereto is a copy of the Writ of Execution. It has been issued because there is a judgment against you. It may cause your property to be held or taken to pay the judgment. You may have legal rights to prevent your property from being taken. A lawyer can advise you more specifically of these rights. If you wish to exercise your rights you must act promptly. ..,,~,~ ," -0.<.- ^, '_ .,. 'I~- _. ,_ , - = ,~ ~~- _l'!! - .., ur-- , . YOU SHOULD TAKE THIS NOTICE AND THE WRIT OF EXECUTION 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 ADVICE. CUMBERLAND COUNTY BAR ASSOCIATION 2 LIBERTY A VENUE CARLISLE, PA 17013 (717) 249-3166 You may have legal rights to prevent the Sheriffs Sale and the loss of your property, In order to exercise those rights, prompt action on your part is necessary. A lawyer may be able to help you. You may have the right to prevent or delay the Sheriffs Sale by filing, before the sale occurs, a petition to open or strike the judgment or a petition to stay the execution. If the judgment was entered because you did not file with the Court any defense or objection you might have within twenty (20) days after service of the Complaint for Mortgage Foreclosure and Notice to Defend, you may have the right to have the judgment opened in you promptly file a petition with the Court alleging a valid defense and a reasonable excuse for failing to file the defense on time. If the judgment is opened, the Sheriffs Sale would ordinarily be delayed pending a trial of the issue of whether the Plaintiff has a valid claim to foreclose the Mortgage. You may also have the right to have the judgment stricken if the Sheriff has not made a valid return of service of the Complaint and Notice to Defend or if the judgment was entered before twenty (20) days after service or in certain other events. To exercise this right, you would have to file a petition to strike the judgment. You may also have the right to petition the Court to stay or delay the execution and the Sheriffs Sale if you can show a defect in the Writ of Execution or service or demonstrate any other legal or equitable right. You may also have the right to have the Sheriffs Sale set aside if the property is sold for a grossly inadequate price or if there are defects in the Sheriffs Sale. To exercise this right, you should file a petition with the Court after the sale and before the Sheriff has delivered his Deed to the property. The Sheriff will deliver the Deed ifno petition to set aside the sale is filed within ten (10) days from the date when the Schedule of Distribution is filed in the Office of the Sheriff. q~~' Louis P. Vitti, Esquire Attorney for Plaintiff 916 Fifth Avenue Pittsburgh, PA 15219 (412) 281-1725 **THE DEBT COLLECTOR IS ATTEMPTING TO COLLECT A DEBT AND ANY INFORMATION OBTAINED WILL BE USED FOR THAT PURPOSE.** ~df.1~~""_~,~ ~ - ".,~ "_~,,_,,,_,_",_o _ ~7 h ,_7_ ?~"' _, . . "". ~ ~_ " ~ ~'-~'~ ,~ ,"-'i";-- "-", ' . '-<)"~'{r f::' ':--' ,'" IN THE COURT OF COMMON PLEAS OF CUMBERLAND COUNTY, PENNSYLVANIA CIVIL DIVISION NATIONAL CITY MORTGAGE CO., NO. 01-7075 CIVIL TERM Plaintiff, vs. MICHELE L. GRAFF and KIMBERLY L. HILEMAN, both unmarried, Defendants. LEGAL DESCRIPTION ALL THAT CERTAIN tract of land situate in Dickinson Township, Cumberland County, Pennsylvania, more particularly bounded and described in accordance with a survey by Stephen C. Fisher, R.S., dated November 4, 1976 (revised), as follows: BEGINNING at an iron pin on the Northern dedicated right-of-way line of the Alexander Spring Road (T-467), a 33 foot right-of-way, said iron pin being also at the Southeast corner of Lot No.6 of the hereinafter mentioned Plan of Lots; thence along the dividing line of Lots Nos. 5 and 6, North 36 degrees 56 minutes 26 seconds West 302.85 feet to an iron pin; thence along the Northern line of Lot No.6, North 31 degrees 21 minutes 40 seconds East 96.63 feet to an iron pin at the corner of Lots Nos. 6 and 7; thence along the dividing line of Lots Nos. 6 and 7, South 58 degrees 38 minutes 20 seconds East 295 feet to an iron pin on the Northern dedicated right-of-way line of Alexander Spring Road (T-467); thence along said right-of-way line, South 31 degrees 21 minutes 40 seconds West a distance of 120.82 feet to an iron pin; thence continuing along same right-of-way line in an arc with a radius of290.0 feet a distance of89.18 feet (erroneously described as 82.35 feet in prior deed) to an iron pin, the point and place of beginning. BEING Lot No.6 of the Plan of Lots of Dickinson Fanus recorded in the Cumberland County Recorder of Deeds Office in Plan Book 29, page 41. HA VING erected thereon a dwelling known as 924 Alexander Spring Road, Carlisle, PA 17013. PARCEL NO. 08-09-0523-043. BEING the same premises which G, Franklin Eichelberger and Linda Marie Eichelberger by deed dated 02/29/2000 and recorded on 03/02/2000 in the Cumberland County, Pennsylvania, Recorder of Deeds Offiee in Deed Book Volume 217, page 19, granted and conveyed unto Michele L. GralT. unmarried and Kimberly L, Hileman, unmarried. ",,",IjI~w- .. ~ ~,,~ , . ".- '>e , ,.~- ~ WRIT OF EXECUTION and/or ATTACHMENT COMMONWEALTH OF PENNSYL V ANlf\) . COUNTY OF CUMBERLAND) TO THE SHERlFF OF CUMBERLAND COUNTY: To satisfy the debt, interest and costs dne NATIONAL CITY MORTGAGE CO., Plaintiff (s) NO 01-7075 Civil CIVIL ACTION - LAW From MICHELE L. GRAFF AND KIMBERLY L. IDLEMAN, 924 ALEXANDER SPRING ROAD, CARLISLE, P A 17013 (I) You are directed to levy upon the property of the defendant {s)and to sell SEE LEGAL DESCRIPTION . (2) You are also directed to attach the property of the defendant(s) not levied upon in the possession of GARNISHEE(S) as follows: and to notify the garnishee(s) that: (a) an attachment has been issued; (b) the garnishee(s) is enjoined from paying any debt to or for the account of the defendant (s) and from delivering any property of the defendant (s) or otherwise disposing thereof; (3) If property of the defendant(s) not levied upon an subject to attachment is found in the possession of anyone other than a named garnishee, you are directed to notify him/her that he/she has been added as a garnishee and is enjoined as above stated. AmountDue $135,899.15 Interest $13,622.07 Atty's Comm % Atty Paid $213.95 Plaintiff Paid Date: APRIL 29, 2003 L.L. Dne Prothy $1.00 Other Costs CURTIS R. LONG (8eal) ProthOna ~ :afh-t< _P .7?Ol/2<V Deputy REQUESTING PARTY: Name LOmS P. VITTI, ESQUIRE Address: 916 FIFTH AVENUE PITTSBURGH, PA 15219 Attorney for: PLAINTIFF Telephone: 412-281-1725 Supreme Court ill No, '_""""r;;"J~_;~:;[~,,-~ ~~ " . . 'r~ " - ~ =, .. N,",,~_ '. .1 .._'.~ '~'!1'." ".;. ~ -." M =~~.""<",""'~.~_'o nl" m'-rr:'~-_'l'",-,~'" '-~_'~j1e:"'tl'YF:\'1frf:-:~~\'f~t;c;~!;;:b';':!'f:;(:I;j;'}l;-i~ Real Estate Sale # 16 On May 5, 2003 the sheriff levied upon the defendant's interest in the real property situated in Dickinson Township, Cumberland County, PA known and numbered as 924 Alexander Spring Road, Carlisle, more fully described on Exhibit "A" filed with this writ and by this reference incorporated herein. Date: May 5, 2003 By: Jcck{~ Real Estate Deputy ~ ~ ~ev ~ ""-I , r,.,' ~ "".," . ,,,------ / ,,_.~ -'"r','., +fJ';;;",,"~~JIJ'<1~1j~;I",'~W*"t!'J,\Willf:""'~!Jllii!!~_i1!iiiIUi _~~llli,_\;jl:il1~,.W1l!~~'fl-r.;..c'lBf';<<*,,90'i"'if1.'Hrj~1\'R!!,i~~\~\!!ii'm!l~~i;",n-j~,}'f:,;,'-'~':_,_.''-''_''_'_~'_-''_ -~_J'<"-,_;'''.-,,,_ -':c, ~~IIiWOMj;!IJiffi,,_ ,_M,~~Yii;1f1. ,,"" '." .' _ ,,_ __ __ , ~3'''r ':,i~ -'"jj'iiIC' t'J6,;;Lc' .'!:-':2i~J" ." -: ir IN THE COURT OF COMMON PLEAS OF CUMBERLAND COUNTY, PENNSYLVANIA NATIONAL CITY MORTGAGE CO., CIVIL DIVISION NO. 01-7075 CIVIL TERM Plaintiff, PRAECIPE TO SETTLE AND DISCONTINUE vs, Filed on behalf of Plaintiff MICHELE 1. GRAFF and KIMBERLY 1. HILEMAN, both unmarried, Counsel of record for this party: Defendant. Louis P. Vitti, Esquire PA J.D. #3810 Supreme Court #01072 Louis P. Vitti & Assoc., P.C. 916 Fifth Avenue Pittsburgh, PA 15219 (412) 281-1725 '~:f.'j;"'J;3:W""',"_, " '"", ,,~" .~. >". '1-', _,_~_<,__"",,!_'__, ._, '.I,._"""n_-~-, -.," , -"," ""'-"",' ., "~'~',~'~ . .~ '-,' '" '~--'"I"~" '.- ,\,!~"_"::T- :;:,:>~-,:::~/~ =" r '.-""...,. ,~ -~ IN THE COURT OF COMMON PLEAS OF CUMBERLAND COUNTY, PENNSYLVANIA CIVIL DIVISION NATIONAL CITY MORTGAGE CO., NO. 01-7075 CIVIL TERM Plaintiff, vs. MICHELE L GRAFF and KlMBERL Y L HILEMAN, both unmarried, Defendants. PRAECIPE TO SETTLE AND DISCONTINUE TO: PROTHONOTARY OFCUMBERLAND COUNTY KINDLY settle, discontinue - Verdicts, Judgments, Executions, Awards, Decrees, Equity, Liens, Counterclaims or Cross-claims and Plaintiff's case as to Defendant(s). ~~V"E' .' OutS . Ittl, squtre Attorney for Plaintiff I hereby certify that the foregoing is a true and correct statement ofthe above case. 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