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Home My WebLink About01-7172 FX ~~ -~ _I - ' ,1.",,,-, &"".j:~1flt;,i , . FEDERMAN AND PHELAN, LLP By: FRANK FEDERMAN, ESQUIRE IDENTIFICATION NO. 12248 ONE PENN CENTER AT SUBURBAN STATION 1617 JOHN F, KENNEDY BOULEVARD SUITE 1400 PHILADELPHIA, PA 19103-1814 (215) 563-7000 GMAC MORTGAGE CORPORATION 401 MILE OF CARS WAY NATIONAL CITY, CA 91950 ATTORNEY FOR PLAINTIFF COURT OF COMMON PLEAS CIVIL DIVISION TERM Plaintiff v, NO, D[ - 7/7:2 ~ CUMBERLAND COUNTY BRADLEY A. MILLS CATHY J. MILLS 73 SOUTH HIGH STREET NEWVILLE, PA 17241 Defendant(s) CIVIL ACTION - LAW COMPLAINT IN MORTGAGE FORECLOSURE NOTICE **THIS FIRM IS A DEBT COLLECTOR ATTEMPTING TO COLLECT A DEBT AND ANY INFORMATION OBTAINED WILL BE USED FOR THAT PURPOSE. IF YOU HA YE PREVIOUSLY RECEIVED A DISCHARGE IN BANKRUPTCY AND THIS DEBT WAS NOT REAFFIRMED, THIS CORRESPONDENCE IS NOT AND SHOULD NOT BE CONSTRUED TO BE AN ATTEMPT TO COLLECT A DEBT, BUT ONLY ENFORCEMENT OF A LIEN AGAINST PROPERTY. ** You have been sued in Court. If you wish to defend against the claims set forth in the following pages, you must take action within twenty (20) days after this Complaint and Notice are served, by entering a written appearance personally or by attorney and filing in writing with the court your defenses or objections to the claims set forth against you. You are warned that if you fail to do so the case may proceed without you and a judgment may be entered against you by the court without further notice for any money claimed in the Complaint or for any other claim or relief requested by the Plaintiff. You may lose money or properly or other rights important to you, YOU SHOULD TAKE THIS PAPER TO YOUR LAWYER AT ONCE, IF YOU DO NOT HAVE A LAWYER OR CANNOT AFFORD ONE, GO TO OR TELEPHONE THE OFFICE SET FORTH BELOW TO FIND OUT WHERE YOU CAN GET LEGAL HELP, CUMBERLAND COUNTY CUMBERLAND COUNTY BAR ASSOCIATION 2 LIBERTY AVENUE CARLISLE, PA 17013 (717) 249-3166 Loan #: 306083904 - '. _.~- , . "I..; I, ;" ""~ "^'" ~~.~i'\i'iilii;n" , IF THIS IS THE FIRST NOTICE THAT YOU HAVE RECEIVED FROM THIS OFFICE, BE ADVISED THAT: PURSUANT TO THE FAIR DEBT COLLECTION PRACTICES ACT, 15 U,S.C. ~ 1692 et seq. (1977), DEFENDANT(S) MAY DISPUTE THE VALIDITY OF THE DEBT OR ANY PORTION THEREOF. IF DEFENDANT(S) DO SO IN WRITING WITHIN THIRTY (30) DAYS OF RECEIPT OF THIS PLEADING, COUNSEL FOR PLAINTIFF WILL OBTAIN AND PROVIDE DEFENDANT(S) WITH WRITTEN VERIFICATION THEREOF; OTHERWISE, THE DEBT WILL BE ASSUMED TO BE VALID. LIKEWISE, IF REQUESTED WITHIN THIRTY (30) DAYS OF RECEIPT OF THIS PLEADING, COUNSEL FOR PLAINTIFF WILL SEND DEFENDANT(S) THE NAME AND ADDRESS OF THE ORIGINAL CREDITOR, IF DIFFERENT FROM ABOVE. THE LAW DOES NOT REQUIRE US TO WAIT UNTIL THE END OF THE THIRTY (30) DAY PERIOD FOLLOWING FIRST CONTACT WITH YOU BEFORE SUING YOU TO COLLECT THIS DEBT. EVEN THOUGH THE LAW PROVIDES THAT YOUR ANSWER TO THIS COMPLAINT IS TO BE FILED IN THIS ACTION WITHIN TWENTY (20) DAYS, YOU MAY OBTAIN AN EXTENSION OF THAT TIME. FURTHERMORE, NO REQUEST WILL BE MADE TO THE COURT FOR A JUDGMENT UNTIL THE EXPIRATION OF THIRTY (30) DAYS AFTER YOU HAVE RECEIVED THIS COMPLAINT. HOWEVER, IF YOU REQUEST PROOF OF THE DEBT OR THE NAME AND ADDRESS OF THE ORIGINAL CREDITOR WITHIN THE THIRTY (30) DAY PERIOD THAT BEGINS UPON YOUR RECEIPT OF THIS COMPLAINT, THE LAW REQUIRES US TO CEASE OUR EFFORTS (THROUGH LITIGATION OR OTHERWISE) TO COLLECT THE DEBT UNTIL WE MAIL THE REQUESTED INFORMATION TO YOU. YOU SHOULD CONSULT AN ATTORNEY FOR ADVICE CONCERNING YOUR RIGHTS AND OBLIGATIONS IN THIS SUIT. ~ L " ,~ " _riel , .~-",-",~J,~d',<i: ~ 1. Plaintiff is GMAC MORTGAGE CORPORATION 401 MILE OF CARS WAY NATIONAL CITY, CA 91950 2, The name(s) and last known addressees) of the Defendant(s) are: BRADLEY A. MILLS CATHY J. MILLS 73 SOUTH HIGH STREET NEWVILLE, PA 17241 who is/are the mortgagor(s) and real owner(s) of the property hereinafter described, 3. On 7/28/98 mortgagor( s) made, executed and delivered a mortgage upon the premises hereinafter described to ACCUBANC MORTGAGE CORPORATION which mortgage is recorded in the Office of the Recorder of CUMBERLAND County, in Mortgage Book No. 1472, Page II. By Assignment of Mortgage recorded 5/26/99 the mortgage was assigned to PLAINTIFF which Assignment is recorded in Assignment of Mortgage Book No. 614, Page 37, 4. The premises subject to said mortgage is described as attached. 5, The mortgage is in default because monthly payments of principal and interest upon said mortgage due II/liDO and each month thereafter are due and unpaid, and by the terms of said mortgage, upon failure of mortgagor to make such payments after a date specified by written notice sent to Mortgagor, the entire principal balance and all interest due thereon are collectible forthwith, ..w.: " ~J --,- , Jlli~:~,",," 6. The following amounts are due on the mortgage: Principal Balance Interest 10/1/00 through 12/1/01 (Per Diem $16.20) Attorney's Fees Cumulative Late Charges 7/28/98 to 12/1/01 Cost of Suit and Title Search Subtotal $81,573.38 6,917,40 4,000,00 160,80 750,00 $93,401.58 Escrow Credit Deficit Subtotal 0,00 1.147.85 $1.147,85 TOTAL $94,549,43 7, The attorney's fees set forth above are in conformity with the Mortgage documents and Pennsylvania Law, and will be collected in the event of a third party purchaser at Sheriffs Sale. If the Mortgage is reinstated prior to the Sale, reasonable attorney's fees will be charged. 8, This action does not come under Act 6 of 1974 because the original mortgage amount exceeds $50,000.00, 9. The Combined Notice has been sent to the Defendant(s) by regular and certified mail as required by 35 P.S. ~1680,403c. 10, The Temporary Stay as provided by the Homeowner's Emergency Mortgage Assistance Program, Act 91 of 1983, has terminated because either: (i.) Defendant(s) have failed to meet with the Plaintiff or an authorized Credit Counseling Agency in accordance with Plaintiffs written Notice to Defendants; or (ii,) Defendant(s) application for assistance has been rejected by the Pennsylvania Housing Finance Agency. WHEREFORE, PLAINTIFF demands an in rem Judgment against the Defendant(s) in the sum of $94,549,43, together with interest from 12/1/01 at the rate of $16.20 per diem to the date of Judgment, and other costs and charges collectible under the mortgage and for the foreclosure and sale of the mortgaged property. ,}~:r~ /s/ Frank Federman FRANK FEDERMAN, ESQUIRE Attorney for Plaintiff 1iN - ~" '" L . _ ~. ~ L...~ ~ ht~id -~ ~I~j~~;; ALL TBA~ CERTAIN lot or parcel of land sit~ated in the Borough of Newville; Cumberland county, Pennsylvania, known and numbered as No. 73 South High street, together with the improvements erected thereon as is more particularly bounded and described as follows: BEGINNING at an iron pin set in westerly line of twenty (20) foot wide alley which pin is North thirteen (13) degrees forty-seven (47) minutes fifty-eight (58) seconds West fifty (50.00) feet from an existing post which said existing post is a common corner of lands now or formerly of Kenneth Graham, lands now or formerly of Ronald H. Stouffer and lands now or formerly of H. Wa~en Welch; thence along line of Lot No. 3 of land subdivision for a. Warren Welch Estate, South seventy-three (73) degrees four (04) minutes sixteen (16) seconds West one hundred seventy-seven and fifty-five hundredths (177.55) feet through an iron pin set eight and three hundredths (8.03) feet from property corner to a point at easterly curbline of South. High Street; thence along said curbline North sixteen (16) degrees nineteen (19) minutes twelve (12) seconds West fifty (50.00) feet to a point at corner of Lot No.1; thence along line of Lot No.1, North seventy-three (73) degrees five (05) minutes thirty-eight (38) seconds East one hundred seventy-nine and seventy-five hundredths (179.75) feet through an iron pin set eight and thirty hundredths (8.30) feet from property corner and through a f~ame garage situated partially on Lot No. 2 and partiallY on Lot No. 1 to an iron pin set in the westerly edge of a twenty (20) foot wide alley; thence along the westerly edge of said alley, South fourteen (14) degrees forty-seven (47) minutes fifty-eight (58) seconds East fifty (50.00) faet to an iron pin, the point and place of BEGINNING. BEING the same premises which Lar~{ A. Bgge by his deed dated July ~Jr , 1998 and about to be recorded herewith in the office of the Recorder of Deeds of Cumberland County pennsylvania, granted and conveyed unto Bradley A. Mills and Cathy J. Mills, h/w, mortgagor herein. PREMISES: 13 SOUTH HIGH STREET NEWVILLE, PA 17241 ~ -'^ ", 1",-1 "",.~i- . . . VERIFICATION KRISTINE WILSON hereby states that she is FORECLOSURE SPECIALIST of GMAC MORTGAGE CORPORATION mortgage servicing agent for Plaintiff in this matter, that she is authorized to take this Verification, and that the statements made in the foregoing Civil Action in Mortgage Foreclosure are true and correct to the best of her knowledge, information and belief. The undersigned understands that this statement is made subject to the penalties of 18 Pa. C.S. Sec. 4904 relating to unsworn falsification to authorities. cx.,...~ (Ah'",hy() DATE: /cJ-JJ-ol 1.-_, "'_^., A ty';,:.,'.J;j~' ."",~';,"i.M"",-:"-",k'ili."f,...,':;-~-mi"'!W2t,!fr.';!;"""-d\61'1-",:,.'j~,,,,-"'jM_"",,!!\lW'" . ."'"~~ m1i!!JIII!lK'~" ~ 11',~c",Ri\!I~J.l ,,!J~I ,UIIIIIII1l.l!llll",!J. . . .. """,,,,,,,.,,..,,,,[I!!II,,IWIJln! J.U.!\JU,..",,,~.. :;;>e:, ~~ ::-b ...... r- ~ 't-' - "'-. ~ ~. -.J ci ~ 0" "'-" VJ 0-' ~ k, Il,~iJjI"J~~L_,"," U . ""...'."""i....."...!!L .. -~1 ~)-r . ~ o c: <:" -053 rTl IT, z-,.-._, 0~; ,,",, ~e ;;:;: ..::0 .'0 )>~ z: =< ~-- Cl a r", ('"') ."V CT. :.8f:3 ~~ om ~ -< , @ o -'-1 :Ll -,.'-".?7. ~ ,_,,,,,,,,,.._,,";'.,'l'1fW~''',,'<<!'<;<.,~ , ....." ., """.,"u".... '''..."....."LM,t1 -0 :J<: ry :"''1 +:- - <, ." I~- "~ - 1_ 1"1 . IW/~-'.-lib~ 1:<iiMiw>"". .<< I. SHERIFF'S RETURN - REGULAR CASE NO: 2001-07172 P COMMONWEALTH OF PENNSYLVANIA: COUNTY OF CUMBERLAND GMAC MORTGAGE CORP VS MILLS BRADLEY A ET AL CPL. TIMOTHY REITZ , Sheriff or Deputy Sheriff of Cumberland County,pennsylvania, who being duly sworn according to law, says, the within COMPLAINT - MORT FORE was served upon MILLS BRADLEY A the DEFENDANT , at 1305:00 HOURS, on the 7th day of January ,2002 at 73 SOUTH HIGH STREET NEWVILLE, PA 17241 by handing to CATHY J MILLS a true and attested copy of COMPLAINT - MORT FORE together with and at the same time directing Her attention to the contents thereof. Sheriff's Costs: Docketing Service Affidavit surcharge So Answers: 18.00 7.80 .00 10.00 .00 35.80 r~~ R. Thomas Kline Sworn and Subscribed to before me this J/ ~ day of 4AWDli ,)JM.2-J A.D. Q -- ~H ~a.ru,If.t.u',~ B othonotary 01/08/2002 FEDERMAN & PHELAN ~ -~ ....,--. - .--: ~ -7 By: ,;v...-1 /. . D puty ~f ~ .1 .I,uo I ,~ " . ,,,1 1. 'id I,k.'d .' . SHERIFF'S RETURN - REGULAR . CA~E NO: 2001-07172 P COMMONWEALTH OF PENNSYLVANIA: COUNTY OF CUMBERLAND GMAC MORTGAGE CORP VS MILLS BRADLEY A ET AL CPL. TIMOTHY REITZ , Sheriff or Deputy Sheriff of Cumberland County,pennsylvania, who being duly sworn according to law, says, the within COMPLAINT - MORT FORE was served upon MILLS CATHY J the DEFENDANT , at 1305:00 HOURS, on the 7th day of January ,2002 at 73 SOUTH HIGH STREET NEWVILLE, PA 17241 by handing to CATHY J. MILLS a true and attested copy of COMPLAINT - MORT FORE together with and at the same time directing Her attention to the contents thereof. Sheriff's Costs: Docketing Service Affidavit Surcharge So Answers: 6.00 .00 .00 10.00 .00 16.00 ~~~<~ R. Thomas Kline 01/08/2002 FEDERMAN & PHELAN Sworn and Subscribed to before IP me this JI - day of c;~ c2U#;LJ A.D. ~~()~~ P othonotary' By: ~ 1/-. if- ._), . Dep y Sheri ". ~" 1.-, ....,;I~_ ~.r .. ~ ~ 'c,.'" __I L",,_, . ~...DE~AN AND PHELAN By: FRJ<NK FEDERMAN IdentificRtion No. 12248 Attorney for PIRintiff ONE PENN CENTER AT SUBURBAN STATION 1617 JOHN F. KENNEDY BLVD., SUITE 1400 PIDLADELPIDA, PA 19103-1814 (215\ 563-7000 GMAC MORTGAGE CORPORATION 401 MILE OF CARS WAY NATIONAL CITY, CA 91950 CUMBERLAND COUNTY COURT OF COMMON PLEAS Plaintiff, CIVIL DIVISION v. NO. 01-7172 CIVIL BRADLEY A. MILLS CATHY J. MILLS DefendRnt(s). PRAECIPE FOR JUDGMENT FOR FAILURE TO ANSWER AND ASSESSMENT OF DAMAGES TO THE PROTHONOTARY: Kindly enter judgment in favor of the Plaintiff and against BRADLEY A. MILLS and CATHY J. MILLS, Defendant( s) for failure to file an Answer to Plaintiff's Complaint within 20 days from service thereof and for Foreclosure and Sale of the mortgaged premises, and assess Plaintiff's damages as follows: As set forth in Complaint Interest from 12/1/01 to 2/20/02 TOTAL $94,549.43 $1,328.40 $95,877.83 I hereby certify that (1) the addresses of the Plaintiff and Defendant( s) are as shown above, and (2) that notice has been given in accordance with Rule 237.1, copy attached. .~~?-~ FRANK FEDERMAN, ESQUIRE Attorney for Plaintiff DAMAGES ARE HEREBY ASSESSED AS INDICATED. ~ DATE: ~eb . :2~ 206",- ~+/l ) k . PRO PROTHY , 1,-" ,~" , -< ~.L.,1k( . ' :~,'L -# (Rule of Civil Procedure No. 236) - Revised IN THE COURT OF COMMON PLEAS OF CUMBERLAND COUNTY, PENNSYLVANIA CIVIL ACTION - LAW GMAC MORTGAGE CORPORATION 401 MILE OF CARS WAY CUMBERLAND COUNTY COURT OF COMMON PLEAS Plaintiff, CIVIL DIVISION v. NO. 01-7172 CIVIL BRADLEY A. MILLS CATHY J. MILLS Defendant(s). Notice is given that a Judgment in the above-captioned matter has been entered against you on ):;L~::JP 20~. DEPUTY If you have any questions concerning this matter, please contact: FRANK FEDERMAN. ESOUIRE Attorney for Plaintiff ONE PENN CENTER AT SUBURBAN STATION 1617 JOHN F. KENNEDY BL YD., SUITE 1400 PHILADELPHIA, PA 19103-1814 (215) 563-7000 **THIS FIRM IS A DEBT COLLECTOR ATTEMPTING TO COLLECT A DEBT AND ANY INFORMATION OBTAINED WILL BE USED FOR THAT PURPOSE. IF YOU HAVE PREVIOUSLY RECEIVED A DISCHARGE IN BANKRUPTCY AND THIS DEBT WAS NOT REAFFIRMED, THIS CORRESPONDENCENDENCE IS NOT AND SHOULD NOT BE CONSTRUED TO BE AN ATTEMPT TO COLLECT A DEBT, BUT ONLY ENFORCEMENT OF A LIEN AGAINST PROPERTY. ** ,"" ~A , '_or.' -~- "^ ,,,", "'", '>......'"~ :'; .,. FEDERMAN AND PHELAN, L.L.P. Frank Federman, Esquire Identification No. 12248 One Penn Center Plaza at Suburban Station, Suite 1400 Philadelphia, PA 19103-1799 (215) 563-7000 ATTORNEY FOR PLAINTIFF COURT OF COMMON PLEAS GAMC MORTGAGE CORPORATION CIVIL DIVISION Plaintiff CUMBERLAND COUNTY vs. NO. 01-7172 CIVIL BRADLEY A. MILLS CATHY J. MILLS Defendant(s) TO: BRADLEY A. MILLS 73 SOUTH HIGH STREET NEWVILLE,PA 17241 FILE C p~i DATE OF NOTICE: JANUARY 29.2002 THIS FIRM IS A DEBT COLLECTOR ATTEMPTING TO COLLECT A DEBT. THIS NOTICE IS SENT TO YOU IN AN ATTEMPT TO COLLECT THE INDEBTEDNESS REFERRED TO HEREIN, AND ANY INFORMATION OBTAINED FROM YOU WILL BE USED FOR THAT PURPOSE. IF YOU HAVE PREVIOUSLY RECEIVED A DISCHARGE IN BANKRUPTCY, THIS CORRESPONDENCE IS NOT AND SHOULD NOT BE CONSTRUED TO BE AN ATTEMPT TO COLLECT A DEBT, BUT ONLY AS ENFORCEMENT OF LIEN AGAINST PROPERTY. IMPORTANT NOTICE You are in default because you have failed enter a written appearance personally or by attorney and file in writing with the court your defenses or objections to the claims set forth against you. Unless you act within ten (10) days from the date of this notice, a Judgment may be entered against you without a hearing and you may lose your property or other important rights. You should take this notice to a lawyer at once. If you do not have a lawyer or cannot afford one, go to or telephone the following office to find out where you can get legal help: CUMBERLAND COUNTY CUMBERLAND COUNTY BAR ASSOCIATION 2 LIBERTY AVENUE CARLISLE, P A 17013 (717)249-3166 ~A.k~~ Frank Federman, Esquire Attorney for Plaintiff .'-' .~, I "., <_ -, "" . ,,'-"'<< ~,- >'" - '!. ,:; '" l _', ~ FEDERMAN AND PHELAN Frank Federman, Esquire Identification No. 12248 One Penn Center Plaza at Suburban Station, Suite 1400 Philadelphia, PA 19103-1799 (215) 563-7000 ATTORNEY FOR PLAINTIFF COURT OF COMMON PLEAS GAMC MORTGAGE CORPORATION CIVIL DIVISION plaintiff vs. CUMBERLAND COUNTY BRADLEY A. MILLS CATHY J. MILLS NO.01-7172 CIVIL Defendant TO: CATHY J. MILLS 73 SOUTH HIGH STREET NEWVILLE,PA 17241 fIt E CL,l! DATE OF NOTICE: JANUARY 29.2002 THIS FIRM IS A DEBT COLLECTOR ATTEMPTING TO COLLECT A DEBT. THIS NOTICE IS SENT TO YOU IN AN ATTEMPT TO COLLECT THE INDEBTEDNESS REFERRED TO HEREIN, AND ANY INFORMATION OBTAINED FROM YOU WILL BE USED FOR THAT PURPOSE. IF YOU HAVE PREVIOUSLY RECEIVED A DISCHARGE IN BANKRUPTCY, THIS CORRESPONDENCE IS NOT AND SHOULD NOT BE CONSTRUED TO BE AN ATTEMPT TO COLLECT A DEBT, BUT ONLY AS ENFORCEMENT OF LIEN AGAINST PROPERTY. IMPORTANT NOTICE You are in default because you have failed enter a written appearance personally or by attorney and file in writing with the court your defenses or objections to the claims set forth against you. Unless you act within ten (10) days from the date of this notice, a Judgment may be entered against you without a hearing and you may lose your property or other important rights. You should take this notice to a lawyer at once. If you do not have a lawyer or cannot afford one, go to or telephone the following office to find out where you can get legal help: CUMBERLAND COUNTY CUMBERLAND COUNTY BAR ASSOCIATION 2 LIBERTY AVENUE CARLISLE,PA 17013 (717) 249-3166 7c.~ ':},,/;~ Frank Federman,Esquire Attorney for plaintiff _~_. ~ ,~, h"" -"~ ,~ 1 ~ I " I, " 1-. i-._ - '~ <"J1;'~~,"'-''';~ FEDkRMANandPHELAN ." -' By: . FRANK FEDERMAN Identification No. 12248 ONE PENN CENTER AT SUBURBAN STATION 1617 JOHN F. KENNEDY BL YD., SIDTE 1400 PHILADELPIDA, PA 19103-1814 (215) 563-7000 ATTORNEY FOR PLAINTIFF GMAC MORTGAGE CORPORATION 401 MILE OF CARS WAY CUMBERLAND COUNTY COURT OF COMMON PLEAS Plaintiff, CIVIL DIVISION v. NO. 01-7172 CIVIL BRADLEY A. MILLS CATHY J. MILLS Defendant(s). VERIFICATION OF NON-MILITARY SERVICE FRANK FEDERMAN, ESQUIRE, hereby verifies that he is attorney for the Plaintiff in the above- captioned matter, and that on information and belief, he has knowledge ofthe following facts, to wit: (a) that the defendant(s) is/are not in the Military or Naval Service ofthe United States or its Allies, or otherwise within the provisions of the Soldiers' and Sailors' Civil Relief Act of Congress of 1940, as amended. (b) that defendant BRADLEY A. MILLS is over 18 years of age and resides at , 73 SOUTH HIGH STREET, NEWVILLE, P A 17241 . (c) that defendant CATHY J. MILLS is over 18 years of age, and resides at, 73 SOUTH HIGH STREET, NEWVILLE, PA 17241. This statement is made subject to the penalties of 18 Pa. C.S. Section 4904 relating to unsworn falsification to authorities. ~,~~ F FEDE AN, ESQUIRE Attorney for Plaintiff ~1;'ful:~~~~~ig"..l!lt""'i~t"';I1~'>1~i~,jb'l;).'~llffilh;;H$;ibl>'"'b;",""j;,.",",,';' /, .0'''''.';''-'" ,'''''''-n,G._t'"i:i,i<,,",MMi~,,!liii.~1i~~:':'~.iI1i'l~i"_J_I' ""-II;/lft'ft".""~~' '~~"r ~1lO l' -<:t . ... .' (") C <" -" t (J ~ -0 [i'~ 1'1 ;U [PC" ,~i'J :-0 .t..-.)! -t 'l ZC-' r",) Ii:. C CljL: 0:.' ~< 1.-- r-r~' ! ~.:.: - ...... () <'-' ::,.;:--> I; ~:-I r ...... ~o ".;;;C:' J.J ~-v ---0 \J:l ":.,"" I'll )>c c_~ N _.."J. Z W p' ~ -~ ::0 t t~ -< w -< - . --.0 ) R c--, il~ . . -- "~~.~.~ ,. '"~-, ~~~ .~",. ~"" ,.^,~~. .~.."~ ~.".~ .~ ~ . ...'~ L~_-_..~ _ -_ ,~,.. -, ,_;~L ;;l:~il AFFIDAVIT OF SERVICE 1C-17I'\ . PLAINTIFF GMAC MORTGAGE CORPORATION CUMBERLAND COUNTY KMD No.OI-7172-CIVIL DEFENDANT(S) BRADLEY A. MILLS CATHY J. MILLS ACCT. #306083904 SERVE BRADLEY A. MILLS AT 73 SOUTH mGH STREET NEWVILLE,PA 17241 Type of Action - Notice of Sheriff's Sale Sale Date: 9/4/02 SERVED Served and made known to ~Yl,~J \~i U;\\S at~, o'clock -f.m., at 7 5 ~. Hi,,!.. ~t I of Pennsylvania, in the manner described below: , Defendant, on the lJ~w\l~\k /5' Ii. daYOf~; \ ,2002., , Commonwealth X Defendant personally served. Adult family member with whom Defendant(s) reside(s). Relationship is Adult in charge of Defendant(s)'s residence who refused to give ,name or relationship. Manager/Clerk of place oflodging in which Defendant(s) residers). Agent or person in charge ofDefendant(s)'s office or usual place of business. an officer of said Defendant(s)'s company. Other: , II I"". . \ V~"'f $l......~ Age $$" Height.u WeightLfJ.$ Race 1.11 SexR Other ~ ~u , ~ """',~ I, ~..,...'- \." C~~ -::Jot- , a competent adult, being duly sWOJ;n according to law, de ose and state that I personally handed a true and correct copy of the Notice of Sheriffs Sale in the manue . ...5).. 'M~ e caphone case on tte date and at the aGdress indicated above. Ei '-M. JOHANSSON. Ncfa1yPublo . GnIene '\\\'p., Franklin County Sworn to and subsqiped " MyCommlsalon ExpIr8s Deo.19,_ be~~trs~aY ~ot :~~~BY: m ~ PL;AQ A~TEMPT S~VICE AT LEAS~gilt ATE Description: S OF SERVICE ATTEMPTED. NOT SERVED On the day of ,200_, at o'clock _.m., Defendant NOT FOUND because: Moved Unknown No Answer Vacant 1 sl Attempt: I I Time: 2nd Attempt: I I Time: 3rd Attempt: I I Time: S worn to and subscribed before me this _ day of , 200 _' Notary: By: Attornev for Plaintiff Frank Federman, Esquire - I.D. No. 12248 .~ .>~~,,,:L, ,"_' ~\,,-,~.," ~",'-, ,J;'_,_-;;.,'iMl!m!ii~i1iI;r;lJlm.liir~"i\i'!;0iV"",'BIIl<_\>,""'/;,"CkJ,tl$~"",,"jjmi:!M~~""'\JjHM\:~.t."ii~WllW:il__J.l'i<i.<liJjj____ o ~ L:lC' , gJ~: 2:.r"-- ,-,",1. - ::;- ~8 Z --1 -<. II!!.th~~_J!_,.._.lIi'I! I ..~! IIW!lI.!lt,-!,."~.,,,..... ....,'...~..-"......,._...~...>r~"..........._.._.....,.......,.... '....._~.._,...., .. ....%..."........ ..,_,...~.... ~~", CJ ,-....., ,,- :r:;.. -'0 ';:;'0 ;"0 ~..c -'D --,..... GO ~ _ .~~"~. ~,~_~'._hX _"" ., ~~~L ~"~ ~ ,. J""1it*:J" AFFIDAVIT OF SERVICE PLAINTIFF GMAC MORTGAGE CORPORATION CUMBERLAND COUNTY KMD No.OI-7172-CIVIL DEFENDANT(S) BRADLEY A. MILLS CATHY J. MILLS ACCT. #306083904 SERVE CATHY J. MILLS AT 73 SOUTH mGH STREET NEWVILLE, PA 17241 Type of Action - Notice of Sheriff's Sale Sale Date: 9/4/02 SERVED Served and made known to CaJc"'1 J; M;\\r at 1. ;to,O'clock~.m.,at 7.3 S. l-(i'jL.. of Pennsylvania, in the manner described below: ~h , Defendant, on the /J'i!~\I;\\ ~ /5;...... day of A~:\ ,200~ . , Commonwealth x . Defendant personally served. Adult family member with whom Defendant(s) reside(s). Relationship is _IA V, b~.. ~ Adult in charge ofDefendant(s)'s residence who refused to give name or relationship. Manager/Clerk of place oflodging in which Defendant(s) reside(s). Agent or person in charge of Defendant(s)'s office or usual place of business. an officer of said DefendantCs)'s company. . ~R:.H~1 ~,~;\\$ Other: It . , ,. ,Ql:'I' W.A ~S' V~v 51..0<<'* Description: Age.;J..5:. HeightS-LL Weight~ Race~SexLL Other' 1 /,^.U. I, Ck.."'e~ \,., e~<<. ~ ' -:r-". , a competent adult, being duly sworn according to law, depose and state that I personally handed a true and correct copy of Notice of Sheriffs Sale in the manner as set forth herein, issued in the captioned case on tho date and at the address indicated above. NOTARIALSEAI. alZABETH M. JOHANSSoN, NoIaIyNlc Gl8enel\vp~!~~ on CllpIIllI Dec.19, 2005 Sworn to and SU~'f'~ed be:&~e(hiS (q day ~ of \ ,200f:... . J N ta c;\JckP1 ~ ~BY: 7' PL;A~ ATTEMPT SERVICE AT LEAST 3 TIMES. INDICATE D > & TIMES OF SERVICE ATTEMPTED. NOT SERVED On the day of ,200_, at o'clock _.m., Defendant NOT FOUND because: Moved Unknown No Answer Vacant 1 st Attempt: / / Time: 2nd Attempt: / / Time: 3rd Attempt: / / Time: Sworn to and subscribed before me this _ day of , 200 _' Notary: By: Attornev for Plaintiff Frank Federman, Esquire - J.D. No. 12248 In ~..",~,~.. ~,~~~-< ,,~ , ,k',l~:-; ,_>"_""t_'lf~"U,Ai'h:t*~..~m~.Ml101>",i",*"";j~M.~~.tf!~rlW,,jiiMti.,-ii,.., ,_"~..,~.",~ __,_,., '_RO" -~. ~-" , _..= _",.y, _~,~ h . .,~ ~~_".~.,.,",""_ W o c ':i? ~....., ,-,' '-.,.' '---'~' rY1f'r-, ~;~~:- ~ r::: ::::~ ""~-;:C. 5~~~i. 7: :< tq.s rjj CJ f"..) r" '-' _or, ~~ :Co ;c,? N <.0 ," - :,,;-n ~~\ ;~6 ,::Jrn ~ :.:0 .< - :..."", L.) .~. ,,~~ ^~ ; I,' ~,' ~,,; ~- , -J.-,_:._, "J.."-.."",,.~,~J">h;o'''"''k..:::. , IN THE COURT OF COMMON PLEAS OF CUMBERLAND COUNTY, PENNSYLVANIA RE: GMAC MORTGAGE CORPORATION ) ) CIVIL ACTION vs. BRADLEY A. MILLS CATHY J. MILLS ) ) CIVIL DIVISION NO. 01-7172 CIVIL AFFIDAVIT OF SERVICE PURSUANT TO RULE 3129 COMMONWEALTH OF PENNSYLVANIA COUNTY OF CUMBERLAND ) ) SS: I, FRANK FEDERMAN, ESQUIRE attorney for GMAC MORTGAGE CORPORATION hereby verify that on 4/9/02 true and correct copies of the Notice of Sheriff's sale were served by certificate of mailing to the recorded lienholders, and any known interested party see Exhibit "A" attached hereto. Notice of Sale was sent to the Defendant(s) on 4/9/02 by certified mail return receipt requested see Exhibit "B" attached hereto. DATE: Auqust 14. 2002 5-~ 5-~ FRANK FEDERMAN, ESQUIRE Attorney for Plaintiff ----. -~ " -':,/~ . ~.~' -~-, '- "':'>'JV'\ -" \. ,\. .. .. ~\ ->::;. -- .,., ~ < ~ ! E g ::l "<t~ ~:::l " . 5~ a... S CI'J .5 ~'..o ,,-;; ...J.s"E~ --CI) ro.. ~ t: [;~ ..J2"'5- UJSooo ;:r:.<:>Pl' Q... ::1 :>.8 Q~13""" Zroc~ <~i:i< z"~"-' <l3~ i ~2.E~ ,.,-, Q) 0 ~ _p...-''''O Clvr-ro UJc......:-= ,,"0~E: "I::l ... '" '" " ~ [I'.I-c " " '" 5 ... 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Wj.~ ~ ;:;; ... >( .... :l1 ~ !'!"s 6 5 ; g ~~ia~o "" 3 t'~ 8 .~.g B z '0 &z g ~ ~ ~.:2 i;; 0..9 .~ '0 0..::-1!i ~ ~8'~.E ~gg~~ 'o..:~]<.8 .~ ~ '0 g s.! 1'~~.~~ ~ i;; '" 5 ~ = :5 B !!;;:; ..:~t~~ il) ...",.,00 ~.E~~~ 1!' ., H ~ (; ~ " ~ o .. ~~ . 0 . ~ ~i o = ~"' ~ ~ <2 >< ~ ....l ~ Cl . . .~E ~o ~ - o . _ 0 o~ ~- = . 5~ Z 0 , ",'il _ 0 ~~ '" - '" - - o ~ ij ~ ~~ .~ "E~ i~ !l t: ~J: v; - 1 " L ~ijlrL ~ , 7160 3901 9844 7042 6694 PS Form 3800 June 2000 RETURN Postage RECEIPT Certified Fee SERVICE . Return Receipt Fee Restricted Delive Total Postage & Fees o-aN~~ ::- . '. 4 us Postal Service POST. ~DATE""""<" ~(~"'=>~. :;:?' A.~;,,,- ~. TO: CATHY J. MILLS, 73 SOUTH HIGH STREET, NEWVILLE, PA 17241 . SENDER: K..'\1D REFERENCE: SALES Receipt for Certified Mail No Insurance Coverage Provided Do Not Use for International Mail 7160 3901 9844 7042 6700 TO: BRADLEY A. MILLS, 73 SOUTH HIGH STREET, NEWVILLE, PA 17241 PS F='onn 3800 June 2000 RETURN Postage RECEIPT Certified Fee SERVICE Return Receipt Fee Restricted Delivery Total p~~ge &. Fees ? I'J I... -:-94 us Postal Service POS: IW.RK.ilfl DATE .).~ I-I "\;,', '" , ""~ :D '7;.\~~ ....!);" . -:)"" . "Id S\. SENDER: KMD REFERENCE: SALES Receipt for Certified Mail No Insurance COllerage Provided 00 Not Use: for International Mail .34 1.90 1.50 3. 0 "".-..-_._.~,- ...-.,.~--_........-...., Ji:;rr~~",:"'",":Ng"dL;lkH'\;~~~~_Wi.lt;;.'i!liCft,~:%~;;,Y-,*dii;;;P,",&:i,<~'d"5~'''_'_,ij, "" . ,'-~i.i,. j~ __",,"; <_,,,;::,;,;.- :i.H~","::i"':~ilil;,~iJ!.r.i:-i;~!fi~~lt~;i!;i'f-iilli:-_-!li-"'-'-'i,.~~,)oi'i.Jiii~r~' ._- ;1;1,J8Ll]!L.~,,,=,, [,~''''''''''''m~. ~,=!1<~_-__,"'>.""'''''. d'~""',^, .'" ,""~""''''_-''_ __.,. __ ~,. "'",_".",~,,,,_'""'''''_'''_,",,.,"<~ ~_ _,:~~,.. ';<,_ ,'"..'o~.,_~ '"=.=,.'=~ ~*,~, ",',", ,~, ,_, ----.. C) J;; ~8? ~i!' 0.>"", ;:s <.~ 5r'-1 ~B ~ ~ r..., "---~. . ~ h c::; ,., r..., ~ -- ':;-:1 Ni;JJ ""~l~ "o"} ().? ':;:!'i? Q:;;J 6f.;'; 'i;! ~ ;;g r..., -. J3 BI-I ~ ~o~~=.._ "~~"= ,_~~_'"'~",~,' .~. - -""" ."",,, ,. ~~ ~~*,,,,,, WRIT OF EXECUTION and/or ATTACHMENT COMMONWEALTH OF PENNSYL VANIA) COUNTY OF CUMBERLAND) NO 01-7172 Civil CIVIL ACTION - LAW TO THE SHERIFF OF CUMBERLAND COUNTY: To satisfy the debt, interest and costs due GMAC MORTGAGE CORPORATION, Plaintiff (s) From BRADLEY A. MILLS AND CATHY J. MILLS, 73 SOUTH ffiGH STREET, NEWVILLE, PA 17241 (1) You are directed to levy upon the property of the defendant (s)and to sell SEE LEGAL DESCRIPTION. (2) You are also directed to attach the property of the defendant(s) not levied upon in the possession of GARNISHEE(S) as follows: and to notify the gamishee(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 him/her that he/she has been added as a garnishee and is enjoined as above stated. Amount Due $95,877.83 L.L. $.50 Interest FROM 2/21/01 TO 9/4/02 (PER DIEM - 15.76) $3,088.96 AND COSTS Atty's Co= % Due Prothy $1.00 Atty Paid $123.80 Other Costs Plaintiff Paid Date: APRIL 12, 2002 CURTIS R. LONG Prothonotary, Civil Division ~y: a~. e.~ftAt.F:U~ REQUESTING PARTY: Name FRANK FEDERMAN, ESQUIRE Address: ONE PENN CENTER AT SUBURBAN STATION 1617 JOHN F. KENNEDY BOULEVARD, SmTE 1400 P:lIILADELPHIA, PA 19103-1814 Attorney for: PLAINTIFF Telephone: 215-563-7000 Supreme Court ill No. 12248 "; 1.-;"'-,.,-'- ' ~"", oj ..~_ :;., ~~ '~lli' '" . PRAECIPE FOR WRIT OF EXECUTION - (MORTGAGE FORECLOSURE) P.R.C.P.3180-3183 GMAC MORTGAGE CORPORATION Plaintiff, v. No.Ol-7172-CIVIL BRADLEY A. MILLS CATHY J. MILLS Defendant(s). TO THE DIRECTOR OF THE OFFICE OF THE PROTHONOTARY: Issue writ of execution in the above matter: Amount Due $95,877.83 Interest from 2/21/02 to 9/4/02 (per diem -15.76) $3,088.96 and Costs TOTAL $98,966.79 ... ~~~1<~~~- One Penn Center at Suburban Station 1617 John F. Kennedy Boulevard, Suite 1400 Philadelphia, PA 19103-1814 Attorney for Plaintiff Note: Please attach description of property.No. 'i!! ! 6",'j)J)!!f&~"'l:""",m.bl~Jl!~~1J1i.'~"i:iii'V.,j,:#;,,,,,,,;\:;;'~'!(;'""L'f..",~" .0"_,.0,>",.",,,' '~.;';v'.","'h""""':\''''~lH!8>IW-l'~~~lI~~i;liii,k~AA!~)l$$~~!ili;ilt''.~. ~ llii__ 1M"''''''''''' .. ..... ..... ..,...,. NN r-r- ..... ..... << ~~ rJ'rJ' ..l..l ..l..l ..... ..... >> ~;::; ~.~ OZ Z ~~ 1J:J< Z 0 ZZ <> 0 ..... ~~ E-< ~..l ..... i:;;J ~~ ..l;;" ~ U ~~ .,::J ~1J:J ~'E' Q) ZZ 1J:J E-<E-< ~ OZ 0 ..l1J:J ~ = 1J:J1J:J Q) ~t: ~ ..l..l '" == en .......l ~ 0 Q) ~ . 0 ~~ O<l "" ,.0 O~ U E-< ~ ..... ..... ~ < . == UZ ~ .; ;;..'"' ca.i: == s " ;. ~i:;;J ~;;.. ~~ E-<E-< en < '" 00 ..l= i:;;J;;l Q) E-<U " ~E-< ~~ 00 g. ~ ~~ 0.... p. ~~ ~ S 1J:J1J:J Q) ;;lZ ,., ,., '" 0 ;:Q ~~ r-r- Q) 0< ~ U~ ~ ~'-' ..... OJ ~~ U U en =;:Q < ~ .;j ~ E-<~ ~ ~ 2 " .~ < Z;;l ~ ~ .....U ~" ~~>,' o~~"" ~.~~~~. _ '" =~~"_~"_" "~,'_..~,~,~~ ~,~,~_, ,_ M'=',,"'.' ~_"."~ ,"_~_ ~^M,<_ ","""",""'v.. . .'" _,."._., =~~ .~= - -'~~.~=".~~-'"~'"', ^ ,~ .. " ALL THAT CERTAIN lot or parcel of land situated in the Borough of Newville, Cumberland County, Pennsylvania, known and numbered as No. 73 South High Street, together with the improvements erected thereon as is more particularly bounded and described as follows: BEGINNING at an iron pin set in Westerly line of twenty (20) foot wide alley which plan is North thirteen (13) degrees forty-seven (47) minutes fifty-eight (58) seconds West fifty (50.00) feet from an existing post which said existing post is a common comer of lands now or formerly of Kenneth Graham, lands now or formerly of Ronald M. Stouffer and lands now or formerly of H. Warren Welch; thence along line of Lot NO.3 of land subdivision for H. Warren Welch Estate, South seventy-three (73) degrees four (04) minutes sixteen (16) seconds West one hundred s.eventy-seven and fifty-five hundredths (177.55) feet from property carrier to a point at Easterly curb line of South High Street; thence along said curbline North sixteen (16) degrees nineteen (19) minutes twelve (12) seconds West fifty (50.00) feet to a point at comer of Lot No.1; thence along line of Lot No.1, North seventy-three (73) degrees five (05) minutes thirty-eight (38) seconds East one hyndred seventy-nine and seventy-five hundredths (179.75) feet through an iron pin set eight and thirty hundredths (8.30) feet from property corner and through a frame garage situated 'partially on Lot No.2 and partially on Lot No.1 to an iron pin set in the Westerly edge of a twenty (20) foot wide alley; thence along the Westerly edge of said alley, South fourteen (14) degrees forty-seven (47) minutes fifty-eight (58) seconds East fifty (50.00) feet to an iron pin, the point and place of BEGINNING. UNDER AND SUBJECT to the right of public in and to the right-of-way for South High Street as shown on said Plan. ALSO UNDER AND SUBJECT to the rights granted unto purchasers of Lot No.3 in and to a right-of- way and easement five (5) feet in width and extending ,seventy (70) feet Eastwardly from the curbline ' of South High Street as showiJ. (In 'said Plan. T(lgether with the right, in common with the Grantees of. Lot No.3, their heirs and aSsigns:, to 'utilize the aforesaid right-of-way for sewer purposes, provided however that any such utilization by Grantees, their heirs or assigns, shall be at the cost and expense of the party exercising same. Provided, however, Grantees shall have the right to erect a boundary line fence. TOGE'TfIER with, in common nevertheless with the Grantor, his' successors and assigns, the right of ingress, egress and regress over and along and to a twenty (20) foot wide iUley leading from Liberty A venue in a Southerly direction to line ofIands now or formerly of Ronald M. Stouffer as shown on said Subdivision Plan. The obligation to maintain said alley shall be shared on a pro-rata basis with other purchasers from the Estate of H. Warren Welch unless or until the said alley shall be accepted by the Borough of Newville. BEING Lot No.2 as shown on plan entitled "Land Subdivision for H. Warren WeIch Estate" dated January 25, 1979, which said Plan is approved by the Council of the Borough of Newville and recorded in Cumberland County Plan Book No. 35, Page 29. BEING No. 73 South High Street. PARCEL NUMBER: 007 A TAX MAP NUMBER: 20-1756 Premises: 73 SOUTH HIGH STREET, BOROUGH OF NEWVILLE CUMBERLAND COUNTY PENNSYLVANIA . M'll d Cathy J. Mills, husband and TITLE TO SAID PREMISES IS VESJr~; I~ ~:r~;~w\gg~ sh:band and wife dated 7/2811998 wife by Deed from Larry A. Egge an u Ie . ,,' '. . ' - and recorded 7/31/1998 in Record Book 182 Page 470. . 'b"illi']~:;'1).\\'r,':1,;iH~tl~; iii~,:""",'t::,,~, _;.~ H.lii>i"'16;ijk"','..:"t....,,'c"~;"i.'t !:he;,;__,,' .- u_: c.l,', ,,-" ,IJJj~L.~ ~.._JI 1~ "- Iv ~ D ....... ~ :J -..) IN C::,~ IA ~/ .-..- ....... .... ,.._"_""'-,,.~''''')MI,W~~~:-Ul'J,,:(ej~"'#il!ll'''_'''''~_'~~_~__''''''''"__- .. ~.fQ. ~ :-- \) 8 r-~ .lQ. .... ?v Iv ~-o~-Cv~ ~i..,b~r-')~ .. ~ cd8~g j I I ~~:~p:! ;~. ,,~~ ~~ , ~ - , - . '" .... ".,~".~" ,_ O_'A~"""'<1~",,,,~~,,_ . .""'... ~_,~._-.""'_"""'''''''^~' ~~ "'"~. __~,,_ _=..~, _~. o c ~.~ L'- C0:~ ~~~ -- zc;. bO -c Z :;:J , C) P'..'} ::t"~~. .0 7:::; ;":~I p.....:, :r:-.,., "c; -""- <- ,', -;:;:-c: o_r~ _..J )> :0 -< ~ CJ1 - ~~._"~~ .~,- .~. <.",",...' " ~ .1 'J.,,"..... .,.J "'" ~ t" '. w---H: FEDERMAN AND PHELAN, LLP By: FRANK FEDERMAN Identification No. 12248 Suite 1400 One Penn Center at Suburban Station Philadelphia, PA 19103 (215) 563-7000 ATTORNEY FOR PLAINTIFF GMAC MORTGAGE CORPORATION Plaintiff, CUMBERLAND COUNTY COURT OF COMMON PLEAS v. CIVIL DIVISION BRADLEY A. MILLS CATHY J. MILLS NO. Ol-7172-CIVIL Defendant(s). CERTIFICATION FRANK FEDERMAN, ESQUIRE, hereby verifies that he is attorney for the Plaintiff in the above-captioned matter, and that the premises are not subject to the provisions of Act 91 because it is: o an FHA mortgage () non-owner occupied () vacant (X) Act 91 procedures have been fulfilled This certification is made subject to the penalties of 18 Pa. C.S. Section 4904 relating to unsworn falsification to authorities. 111. o../I.~~Q^^MOI\^ RANK FE ERMAN, ESQUIRE Attorney for Plaintiff 1;;~:*..llOCcii'<"..illt'i',!,i'I~~f&"j~ili\BI,h""*"!t,,,,:i;""i,,';~fg",H,,l:,"d','"~),,",",;:,:;i,..,, "i,(,""';i- ~-~,!".,:;i;;';j);",;~~I;.t",i@!~;$t~flWMtallUi,",~----- 0 C,' .-- c:; P',-) - I ~-;:: J:';!'> -OC..) -~:) rf'1rT" :':'J- -""," ""-..--' &'~:~ - f-,:' " -< r:::t~:' '-' >~, ?Z C:,) "-"I Zl, F;, "",0 '!? ,,~~~ iTl .P,- 8 Z -'~1 ~ (Jl 1) -< ES /fS ,lh9,~,Jl1i!lill!lJ!OI! , I, !II! rnIIUlJjll,~'M."IUllJl!'l'ilI!.!LM!\lrnll!ll_JJL.I..l}nl,J1,J1L'~"M_"_ "".__",,_ .co", '" ., __,_,~_,__,_____,,_,~__, '" ~ "~"I"""""._"" .._N~. .'''-, ,I, , ~" = --, " ~ ' '-;liiit'i . GMAC MORTGAGE CORPORATION CUMBERLAND COUNTY Plaintiff, v. COURT OF COMMON PLEAS BRADLEY A. MILLS CATHY J. MILLS CIVIL DIVISION NO.OI-7172-CIVIL Defendant(s). AFFIDAVIT PURSUANT TO RULE 3129 (Affidavit No. I) GMAC MORTGAGE CORPORATION, Plaintiff in the above action, by its attorney, FRANK FEDERMAN, ESQUIRE, sets forth as ofthe date the Praecipe for the Writ of Execution was filed the following information concerning the real property located at ,73 SOUTH HIGH STREET, NEWVILLE, PA 17241. 1. Name and address of Owner(s) or reputed Owner(s): Name Last Known Address (if address cannot be reasonably ascertained, please indicate) BRADLEY A. MILLS 73 SOUTH HIGH STREET NEWVILLE, PA 17241 CATHY J. MILLS 73 SOUTH HIGH STREET NEWVILLE, PA 17241 2. Name and address ofDefendant(s) in the judgment: Same as above 3. Name and last known address of every judgment creditor whose judgment is a record lien on the real property to be sold: Name Last Known Address (if address cannot be reasonably ascertained, please indicate) None 4. Name and address of last recorded holder of every mortgage of record: Name Last Known Address (if address cannot be reasonably ascertained, please indicate) AMERICAN GENERAL CDC 6 SOUTH HANOVER STREET CARLISLE, PA 17013 '1!( ~ ~ I "- '-",< -, -;..,,,,, b_~~i~.LU', ,,"" J- 5. Name and address of every other person who has any record lien on the property: Name Last Known Address (if address cannot be reasonably ascertained, please indicate) None 6. Name and address of every other person who has any record interest in the property and whose interest may be affected by the sale. Name Last Known Address (if address cannot be reasonably ascertained, please indicate) None 7. Name and address of every other person of whom the plaintiff has knowledge who has any interest in the property which may be affected by the sale: Name Last Known Address (if address cannot be reasonably ascertained, please indicate) COMMONWEALTH OF PENNSYL VANIA DEPARTMENT OF WELFARE PO BOX 2675 HARRISBURG, PA 17105 DOMESTIC RELATIONS OF CUMBERLAND COUNTY 13 NORTH HANOVER STREET CARLISLE, PA 17013 TENANT/OCCUPANT 73 SOUTH HIGH STREET NEWVILLE, PA 17241 I verify that the statements made in this affidavit are true and correct to the best of my personal knowledge or information and belief. I understand that false statements herein are made subject to the penalties of18 Pa. C.S. Sec. 4904 relating to unsworn falsification to authorities. April 9, 2002 DATE ~ ~~ ~.Q,A AM[), "'^ FRANK F DERMAN, ESQUiRE Attorney for Plaintiff . <:~~~$<b.;l!iAM,~i'&--.l6.icih.~~..\ffilI1t~~~,.W~~.J&J~~d,,;L&'i~-<-:':":'!d~~".~,b.,'_".~" .,,",~~_- u"H_i;c;!;1,,,:~~j,.~.~~ihilllr.Mli'l1~flijh>>~l:Iiim~imli!~.I'~--W!j- '. ~ ..... 0 <:::;!- ~'-' - c: "'...) -'n <~ ",. ~~t -U AJ L~ r<' (f),;:: 2'c :<:c. :t':<P' fH) )> -. ~ z": ., --c \D (5 )>c _.~"! Z ~ =< '11 ~5 f<S ,i:MJULY\jJI.l~,. . _..._J!lf~",'_""m~ij".".,~", _ _,"~""~,", < "_ ,",''''~l<, """~. '_',' "",.. ". "'_~'=~""'~ ~ ,., '.=__""'..,~,,, ,y., .-. . --~ ,,,"".'~,<'. "" - "-, I '-' , ,,' , ," ,- ~ _I"" " '1'-' .-'j 'oj: " GMAC MORTGAGE CORPORATION Plaintiff, CUMBERLAND COUNTY v. No.Ol-7172-CIVIL BRADLEY A. MILLS CATHY J.MILLS Defendant(s). April 9, 2002 TO: BRADLEY A. MILLS 73 SOUTH HIGH STREET NEWVILLE, PA 17241 CATHY J. MILLS 73 SOUTH HIGH STREET NEWVILLE, PA 17241 **THIS FIRM IS A DEBT COLLECTOR A TTEMPTING TO COLLECT A DEBT AND ANY INFORMA TION OBTAINED WILL BE USED FOR THAT PURPOSE. IF YOU HA VE PREVIOUSLY RECEIVED A DISCHARGE IN BANKRUPTCY AND THIS DEBT WAS NOT REAFFIRMED. THIS IS NOT AND SHOULD NOT BE CONSTRUED TO BE AN ATTEMPT TO COLLECT A DEBT, BUT ONLY ENFORCEMENT OF A LIEN AGAINST PROPERTY. ** Your house (real estate) at, 73 SOUTH HIGH STREET. NEWVILLE. PA 17241. is scheduled to be sold at the Sheriff's Sale on 9/4/02 at 10:00 a.m. in the Cumberland County Courthouse, South Hanover Street, Carlisle, P A 17013, to enforce the court judgment of $95.877.83 obtained by GMAC MORTGAGE CORPORATION (the mortgagee) against you. In the event the sale is continued, an announcement will be made at said sale in compliance with Pa.R.C.P., Rule 3129.3. NOTICE OF OWNER'S RIGHTS YOU MAY BE ABLE TO PREVENT THIS SHERIFF'S SALE To prevent this Sheriff's Sale, you must take immediate action: I. The sale will be cancelled if you pay to the mortgagee the back payments, late charges, costs and reasonable attorney's fees due. To find out how much you must pay, you may call: (215) 563-7000. 2. You may be able to stop the sale by filing a petition asking the Court to strike or open the judgment, if the judgment was improperly entered. You may also ask the Court to postpone the sale for good cause. 3. You may also be able to stop the sale through other legal proceedings. You may need an attorney to assert your rights. The sooner you contact one, the more chance you will have of stopping the sale. (See notice on page two on how to obtain an attorney.) - .-., ..d _., 'H' . ,- -" ~~, J' " , ,,' >.'<\, ,1,," 1l~':\l';'_ YOU MAY STILL BE ABLE TO SAVE YOUR PROPERTY AND YOU HAVE OTHER RIGHTS EVEN IF THE SHERIFF'S SALE DOES TAKE PLACE. 1. If the Sheriff's Sale is not stopped, your property will be sold to the highest bidder. You may find out the price bid by calling (215) 563-7000. 2. You may be able to petition the Court to set aside the sale if the bid price was grossly inadequate compared to the value of your property. 3. The sale will go through only if the buyer pays the Sheriff the full amount due in the sale. To find out ifthis has happened, you may call (717) 240-6390. 4. If the amount due from the Buyer is not paid to the Sheriff, you will remain the owner of the property as if the sale never happened. 5. You haw the right to remain in the property until the full amount due is paid to the Sheriff and the Sheriff gives a deed to the buyer. At that time, the buyer may bring legal proceedings to evict you. 6. You may be entitled to a share of the money which was paid for your house. A schedule of distribution of the money bid for your house will be filed by the Sheriff within 30 days of the sale. This schedule will state who will be receiving that money. The money will be paid out in accordance with this schedule unless exceptions (reasons why the proposed distribution is wrong) are filed with the Sheriff within ten (10) days after the distribution is filed. 7. You may also have other rights and defenses, or ways of getting your home back, if you act immediately after the sale. YOU SHOULD TAKE THIS PAPER TO YOUR LAWYER AT ONCE. IF YOU DO NOT HAVE A LAWYER OR CANNOT AFFORD ONE, GO TO OR TELEPHONE THE OFFICE LISTED BELOW TO FIND OUT WHERE YOU CAN GET LEGAL HELP. CUMBERLAND COUNTY ATTORNEY REFERRAL CUMBERLAND COUNTY BAR ASSOCIATION 2 LIBERTY AVENUE CUMBERLAND COUNTY COURTHOUSE CARLISLE, PA 17013 (717) 249-3166 (800) 990-9108 i\ij . '. 'A.LL THAT CERTAIN lot or parcel of land situated in the Borough of Newville, Cumberland County, . . 'Pennsylvania, known and numbered as No. 73 South High Street, together with the improvements erected thereon as is more particularly bounded and described as follows: BEGINNING at an iron pin set in Westerly line of twenty (20) foot wide alley which plan is North thirteen (13) degrees forty-seven (47) minutes fifty-eight (58) seconds West fifty (56.00) feet from an existing post which said existing post is a cornman corner of lands now or formerly of Kenneth Graham, lands now or formerly of Ronald M. Stouffer and lands now or formerly of H. Warren Welch; thence along .line of Lot NO.3 of land subdivision for H. Warren Welch Estate, South seventy-three (73) degrees four (04) minutes sixteen (16) seconds West one hundred seventy-seven and fifty-five hundredths (177.55) feet from property corner to a point at Easterly curbline of South High Street; thence along said curbline North sixteen (16) degrees nineteen (19) minutes twelve (12) seconds West fifty (50.00) feet to a point at corner of Lot No.1; thence along line of Lot No.1, North seventy-three (73) degrees five (05) minutes thirty-eight (38) seconds East one hvndred seventy-nine and seventy-five hundredths (179.75) feet through an iron pin set eight and thirty hundredths (8.30) feet from property corner and through a frame garage situated partially on Lot NO.2 and partially on Lot No.1 to an iron pin set in the Westerly edge of.a twenty (20) foot wide alley; thence along the Westerly edge of said alley, South fourteen (14) degrees forty-seven (47) minutes fifty-eight (58) seconds East fifty (50.00) feet to an iron pin, the point and place of BEGINNING. UNDER AND SUBJECT to the right of public in and to the right-of-way for South High Street as shown on said Plan. ALSO UNDER AND SUBJECT to the rights granted unto purchasers of Lot No.3 in and to a right-of- way and easement five (5) feet in width and extending seventy (70) feet Eastwardly from the curbline of South High Street as shown on said Plan. Together with the right, in common with the Grantees of Lot No.3, their heirs and assigns, to utilize the aforesaid right-of-way for sewer purposes, provided however that any such utilization by Grantees, their heirs or assigns, shall be at the cost and expense of the party exercising same. Provided, however, Grantees shall have the right to erect a boundary line fence. TOGETHER with, in common nevertheless with the Grantor, his' successors aud assigns, the right of ingress, egress and regress over and along and to a twenty (20) foot wide alley leading from Liberty Avenue in a Southerly direction to line of lands now or formerly of Ronald M. Stouffer as shown on said Subdivision Plan. The obligation to maintain said alley shall be shared on a pro-rata basis with other purchasers from the Estate of H. Warren Welch unless or until the said alley shall be accepted by the Borough of Newville. BEING Lot No.2 as shown on plan entitled "Land Subdivision for H. Warren Welch Estate" dated January 25, 1979, which said Plan is approved by the Council of the Borough of Newville and recorded in Cumberland County Plan Book No. 35, Page 29. "'. ' BEING No. 73 South High Street. PARCEL NUMBER: 007 A TAX MAP NUMBER: 20-1756 Premises: 73 SOUTH HIGH STREET, BOROUGH OF NEWVILLE CUMBERLAND COUNTY PENNSYLV ANIA , M'lI and Cathy J. Mills, husband and TITLE TO SAID PREMISES IS VESTED. IN ~ad~ey \: 1 shusband and wife dated 7/2811998 wife by Deed from Larry A. Egge and JulIe R. ar row- gge, and recorded 7/31/1998 in Record Book 182 Page 470. :4r!i;~[$ii:~~~i9m'i;.i!!&,jj!t1!:--wI'li;",">l1"Q~4~iJ~,.!i,iM"_'iI:""';P"':-"\L;'=0>:;''~'r - . -' -' ~,-},..' ,,,,c,.,-~,;;,;,/ <,f~].-""'-W.,,\#**~~-Hii->>~_~~);;~,,,0~~_~jjlrn!1t><;~1l1 ,1,\,,~,~~JL!UJlIl!!'!JiL~ __'_"'"'_~~><".".mC'" ',"," ." ,'''' ," ~- ~>~ "-",~~',"-'~'~-,,,<~,,~~ o ~.; rR-g~ --7"j ""--" -'" ,,-:-:C ~:~ ~C: ~C) =0 >c :z: :< ~M.=__","~ "=_ ~ ~~~--- ',~ r,,) ;;~ ----0 :.TI -p,} /::::.s R.,:S . ~, 5;:: : ~~ .-<. l'"' "-" ~ :0 -<. _0 (.I'l -=""'...~. .~ ~.~~~, I-~ . ~ , GMAC Mortgage Corporation VS Bradley A. Mills and Cathy J. Mills In The Court of Common Pleas of Cumberland County, Pennsylvania Writ No. 2001-7172 Civil Term -,- ~,i'$#kD- R. Thomas Kline, Sheriff, who being duly sworn according to law, states this writ is retumed STAYED pursuant to instructions from Attorney Frank Federman. Sheriff s Costs: Docketing Surcharge Law Library Prothonotary Mileage Levy Advertising Posting Handbills Share of Bills Poundage Law Joumal Patriot News Certified Mail 30.00 30.00 .50 1.00 16.56 15.00 15.00 15.00 25.20 23.74 595.55 433.75 9.59 $1210.89 paid by attorney 09/05/02 Sworn and subscribed to before me So An~~ This q~ day of th~'. , ~ ...,t:.,.?~ O .. R. Thomas Kline, Sheriff 2002, A.D. _..-t., 0 Ih.~i&(.", Il~ . l (' ..-LJ I ' T~ BYVfJ~~ Prothonotary Real Estate Deputy L~ll Ue. 3 fO:5'1 ~ /,Jv13).;L ~ " ~I "' ,- ~- i'l ~' ^' ~ . Lu id4r&i'; WRIT OF EXECUTION and/or ATTACHMENT COMMONWEALTII OF PENNSYLVANIA) COUNTY OF CUMBERLAND) NO 01-7172 Civil CIVIL ACTION - LAW TO THE SHERIFF OF CUMBERLAND COUNTY: To satisfy the debt, interest and costs due GMAC MORTGAGE CORPORATION, Plaintiff (s) From BRADLEY A. MILLS AND CATHY J. MILLS, 73 SOUTH IDGH STREET, NEWVILLE, PA 17241 (I) You are directed to levyupou 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 ofthe defendant (s) and from delivering any property of the defendant (s) or otherwise disposing thereof; (3) Ifproperty of the defendant(s) not levied upon an subject to attachment is found in the possession of anyone other than a named garnishee, you are directed to notify himlher that he/she has been added as a garnishee and is enjoined as above stated. Amount Due $95,877.83 L.L. $.50 Interest FROM 2/21/01 TO 9/4/02 (pER DIEM - 15.76) $3,088.96 AND COSTS Atty's Comm % Due Prothy $1.00 Atty Paid $123.80 Other Costs Plaintiff Paid Date: APRIL 12, 2002 CURTIS R. LONG Prothonotary, Civil Division ~: ~f>t D f? 7l;~A'''-.4J~ REQUESTING PARTY: Name FRANK FEDERMAN, ESQillRE Address: ONE PENN CENTER AT SUBURBAN STATION 1617 JOHN F. KENNEDY BOULEVARD, SillTE 1400 PHILADELPIDA, PA 19103-1814 Attorney for: PLAINTIFF Telephone: 215-563-7000 Supreme Court ill No. 12248 "" k ,"'ct'~CJi'''''o_~'1-i<:'i'''?~ "'<"","~,H;',,~' p, ,,,"ie,' ,i'd,'.__'.'- .b'iL'-;," ',_-i \" , " '" ",-, , >","'0 .,,' ., ",,",' ',,,:,L,"'-,~,K"""t.,..,. .,<'k,-"t -M",-j'i,rth_",'h',jL;d;,;;;"""""",~":;."c',.,,,,:!W:,~,,,,,4t!;.l]~;\>l~"",,,,-,~;~;;<I_'>-~IHilillB,Ii.~'i'1"~_ Real Estate Sale # 16 On May 9, 2002 the sherifflevied upon the defendant's interest in the real property situated in Borough of Newville, Cumberland County, PA Known .md numbered as 73 South High Street, Newville, and more fully described on Exhibit "A" filed with this writ and by this reference incorporated herein. Date: May 9, 2002 By: (1 Cluclla......q. ~bk/ ~-[p:\ 'n --', .' ! :,'- !3d ,Cc;.....5) =jyil """'UlJ ~-, ,(s~ ,r " ,I'.' C[ PI ZI Hd~ , , AjLli~II~:!~ , .:Bl/li!ii?:1!I'.:- '''''':');j J,:';;;.JtJ:fJ !ll,ll~lQllmo!L'!1I1IL......."..._,..... .............. "..,'.....",....,_ ..."ce"... ....".....-.... <.0.., , , -,~~~, . ~. 9 ,c,J'U ~--~ -'.f1l >:::-:-~ .= ~ -~- . , -, I = L. , I, ^~-__ ~ ,..J,.;.,"--_:''''<~:: GMAC MORTGAGE CORPORATION CUMBERLAND COUNTY Plaintiff, v. COURT OF COMMON PLEAS BRADLEY A. MILLS CATHY J. MILLS CIVIL DIVISION : NO.OI-7172-CIVIL S Defendant(s). : 5 HER IFF ~ ,-- AFFIDAVIT PURSUANT TO RULE 3129 COpy (Affidavit No.1) GMAC MORTGAGE CORPORATION. Plainfiffin the above action, by its attorney, FRANK FEDERMAN, ESQUlRE, sets forth as of the date the Praecipe for the Writ of Execution was filed the following information concerning the real property located at .73 SOUTH HIGH STREET. NEWVILLE. PA 17241. 1. Name and address ofOwner(s) or reputed Owner(s): Name Last Known Address (if address cannot be reasonably ascertained, please indicate) BRADLEY A. MILLS 73 SOUTH HIGH STREET NEWVILLE, PA 17241 CATHY J. MILLS 73 SOUTH HIGH STREET NEWVILLE, P A 17241 2. Name and address ofDefendant(s) in the judgment: Same as above 3. Name and last known address of every judgment creditor whose judgment is a record lien on the real property to be sold: Name Last Known Address (if address cannot be reasonably ascertained, please indicate) None 4. Name and address oflast recorded holder of every mortgage of record: Name Last Known Address (if address cannot be reasonably ascertained, please indicate) AMERICAN GENERAL CDC 6 SOUTH HANOVER STREET CARLISLE, P A 17013 ~'1 '-I ., ~-~,,' . '."- 1-'-H'iIn~ , 5. Name and address of every other person who has any record lien on the property: Name Last Known Address (if address cannot be reasonably ascertained, please indicate) None 6. Name and address of every other person who has any record interest in the property and whose interest may be affected by the sale. Name Last Known Address (if address cannot be reasonably ascertained, please indicate) None 7. Name and address of every other person of whom the plaintiff has knowledge who has any interest in the property which may be affected by the sale: Name Last Known Address (if address cannot be reasonably ascertained, please indicate) COMMONWEALTH OF PENNSYLVANIA DEPARTMENT OF WELFARE PO BOX 2675 HARRISBURG, PA 17105 DOMESTIC RELATIONS OF CUMBERLAND COUNTY 13 NORTH HANOVER STREET CARLISLE, PA 17013 TENANT/OCCUPANT 73 SOUTH HIGH STREET NEWVILLE, PA 17241 I verify that the statements made in this affidavit are true and correct to the best of my personal knowledge or information and belief. I understand that false statements herein are made subject to the penalties ofl8 Pa. C.S. Sec. 4904 relating to unsworn falsification to authorities. Aori19.2002 DATE ~~~~A^M[)^~ FRANK F DERMAN, ESQ Attorney for Plaintiff ~" _~ ~ .,.' ., ~ , L...,",-~_."~" _ " ~~>~~ , ~-- I ~~'~f)'! , , ; GMAC MORTGAGE CORPORATION Plaintiff, CUMBERLAND COUNTY '1'. No.OI-7172-CIVIL BRADLEY A. MILLS CATHY J. MILLS Defendant(s). April 9, 2002 TO: BRADLEY A. MILLS 73 SOUTH HIGH STREET NEWVILLE, PA 17241 CATHY J. MILLS 73 SOUTH HIGH STREET NEWVILLE, PA 17241 "THIS FIRM IS A DEBT COLLECTOR ATTEMPTING TO COLLECT A DEBT AND ANY INFORMATION OBTAINED WILL BE USED FOR THAT PURPOSE. IF YOU HA VE PREVIOUSLY RECEIVED A DISCHARGE IN BANKRUPTCY AND THIS DEBT WAS NOT REAFFIRMED.. THIS IS NOT AND SHOULD NOT BE CONSTRUED TO BE AN ATTEMPT TO COLLECT A DEBT, BUT ONLY ENFORCEMENT OF A LIEN AGAINST PROPERTY." Your house (real estate) at. 73 SOUTH HIGH STREET. NEWVILLE. PA 17241. is scheduled to be sold at the Sheriff's Sale on 9/4/02 at 10:00 a.m. in the Cumberland County Courthouse, South Hanover Street, Carlisle, P A 17013, to enforce the court judgment of $95,877.83 obtained by GMAC MORTGAGE CORPORATION (the mortgagee) against you. In the event the sale is continued, an announcement will be made at said sale in compliance with Pa.R.C.P., Rule 3129.3. NOTICE OF OWNER'S RIGHTS YOU MAY BE ABLE TO PREVENT THIS SHERIFF'S SALE To prevent this Sheriff's Sale, you must take immediate action: l. The sale will be cancelled if you pay to the mortgagee the back payments, late charges, costs and reasonable attorney's fees due. To find out how much you must pay, you may call: (215) 563-7000. 2. You may be able to stop the sale by filing a petition asking the Court to strike or open the judgment, if the judgment was improperly entered. You may also ask the Court to postpone the sale for good cause. 3. You may also be able to stop the sale through other legal proceedings. You may need an attorney to assert your rights. The sooner you contact one, the more chance you will have of stopping the sale. (See notice on page two on how to obtain an attorney.) ;f:~~i "'~- , ~ ,Ie-__ ,". ~ ' '_'i~~1';ri,: . . ., YOU MAY STILL BE ABLE TO SAVE YOUR PROPERTY AND YOU HAVE OTHER RIGHTS EVEN IF THE SHERIFF'S SALE DOES TAKE PLACE. 1. If the Sheriff's Sale is not stopped, your property will be sold to the highest bidder. You may find out the price bid by calling (215) 563-7000. 2. You may be able to petition the Court to set aside the sale if the bid price was grossly inadequate compared to the value of your property. 3. The sale will go through only if the buyer pays the Sheriff the full amount due in the sale. To find out if this has happened, you may call (717) 240-6390. 4. If the amount due from the Buyer is not paid to the Sheriff, you will remain the owner of the property as if the sale never happened. 5. You have the right to remain in the property until the full amount due is paid to the Sheriff and the Sheriff gives a deed to the buyer. At that time, the buyer may bring legal proceedings to evict you. 6. You may be entitled to a share ofthe money which was paid for your house. A schedule of distribution of the money bid for your house will be filed by the Sheriff within 30 days of the sale. This schedule will state who will be receiving that money. The money will be paid out in accordance with this schedule unless exceptions (reasons why the proposed distribution is wrong) are filed with the Sheriff within ten (10) days after the distribution is filed. 7. You may also have other rights and defenses, or ways of getting your home back, if you act immediately after the sale. YOU SHOULD TAKE THIS PAPER TO YOUR LAWYER AT ONCE. IF YOU DO NOT HAVE ALA WYER OR CANNOT AFFORD ONE, GO TO OR TELEPHONE THE OFFICE LISTED BELOW TO FIND OUT WHERE YOU CAN GET LEGAL HELP. CUMBERLAND COUNTY ATTORNEY REFERRAL CUMBERLAND COUNTY BAR ASSOCIATION 2 LIBERTY AVENUE CUMBERLAND COUNTY COURTHOUSE CARLISLE, P A 17013 (717) 249-3166 (800) 990-9108 _. AllLTHAT CERTAIN lot or parcel of land situated in the Borough of Newville, Cumberland County, Pehnsylvania, known and numbered as No. 73 South High Street, together with me improvements e,<)",ted thereon. as is more particularly bounded and described as follows: .. BEGINNING at an iron pin set in Westerly line of twenty (20) foot wide alley which plan is North thirteen (13) degrees forty-seven (47) minutes fifty-eight (58) seconds West fifty (50.00) feet from an existing post which said existing post is a common corner of lands now or formerly ofRenneth Graham, lands now or formerly of Ronald M. Stouffer and lands now or formerly of H. Warren Welch; thence along .line of Lot NO.3 of land subdivision for. H. Warren Welch Estate, South seventy-three (73) degrees four (04) minutes sixteen (16) seconds West one hundred seventy-seven and fifty-five hundredths (177.55) feet from property corner to a point at Easterly curbline of South High Street; thence along said curbline North sixteen (16) degrees nineteen (19) minutes twelve (12) seconds West fifty {50.00) feet to a P9int at comer of Lot No.1; thence along line of Lot No.1, North seventy-three (73) degrees five (05) minutes thirty-eight (38) seconds East one h\lndred seventy-nine and seventy-five hundredths (179.75) feet through an iron pin set eight and thirty hundredths (8.30) feet from property corner and through a frame garage situated partially on Lot NO.2 and partially on Lot No. 1 to an iron pin se1 in the Westerly edge ofa twenty (20) foot wide alley; thence along the Westerly edge of said alley, South fourteen (14) degrees forty-seven (47) minutes fifty-eight (58)seconds East fifty (50.00) feet to an iron pin, the point and place of BEGINNING. UNDER AND SUBJECT to the right of public in and to the right-of-way for South High Street as shown on said Plan. ALSO UNDER AND SUBJECT to the rights granted unto purchasers of Lot No.3 in and to a right-of- way and easement five (5) feet in width and extendiug seventy (70) feet Eastwardly from the curb line of South High Street as shown on said Plan. Together with the right, in cornman with the Grantees of Lot No.3, their heirs and assigns, to utilize the aforesaid right-of-way for sewer purposes, provided however that any such utilization by Grantees, their heirs or assigns, shall be at the cost and expense of the party exercising same. Provided, however, Grantees shall have the right to erect a boundary line fence. TOGETItER with, in common uevertheless with the Grantor, his' successors and assigns, the right of ingiess, egress and regress over and along and to a twenty (20) foot wide !illey leading from Liberty Avenue in a Southerly direction to line of lands now or formerly of Ronald M. Stouffer as shown on said Subdivision Plan. The obligation to maintain said alley shall be shared on a pro-rata basis with other purchasers from the Estate of H. Warren Welch unless or until the said alley shall be acc~pted by the Borough of Newville. . l' BEING Lot No.2 as shown on plan entitled "Land Subdivision for H. Warren Welch Estate" dated January 25, 1979, which said Plan is approved. by the Council of the Borough of Newville and recorded in Cumberland County Plan Book No. 35, Page 29. . ,_.., BEING No. 13 South High Street. ,,>,- . ,'., PARCEL NUMBER: 007 A TAX MAP NUMBER: 20-1756 Premises: 73 SOUTH HIGH STREET, BOROUGH OF NEWVILLE CUMBERLAND COUNTY PENNSYLVANIA A M'll and Cathy J Mills husband and TITLE TO SAID PREMISES IS VESTED. I~ ~~DradbIe:Y -E ~ shusband and ~ife d;ted 7/28/1998 wife by Deed from Larry A. Egge and JulIe '. ar roW gg, and recorded 7/31/1998 in Record Book 182 Pal1;e 470. ", ~'I ., " ',,-'" . '" <- -~ PROOF OF PUBLICATION OF NOTICE IN CUMBERLAND LAW JOURNAL (Under Act No. 587, approved May 16,1929), P. L.1784 STATE OF PENNSYLVANIA : ss. COUNTY OF CUMBERLAND : Roger M. Morgenthal, Esquire, Editor of the Cumberland Law Journal, of the County and State aforesaid, being duly sworn, according to law, deposes and says that the Cumberland Law Journal, a legal periodical published in the Borough of Carlisle in the County and State aforesaid, was established January 2, 1952, and designated by the local courts as the official legal periodical for the publication of all legal notices, and has, since January 2, 1952, been regularly issued weekly in the said County, and that the printed notice or publication attached hereto is exactly the same as was printed in the regular editions and issues of the said Cumberland Law Journal on the following dates, VIZ: JULY 26, AUGUST 2, 9, 2002 Affiant further deposes that he is authorized to verify this statement by the Cumberland Law Journal, a legal periodical of general circulation, and that he is not interested in the subject matter of the aforesaid notice or advertisement, and that all allegations in the foregoing statements as to time, place and character of publication are true. ~ditor . SWORN TO AND SUBSCRIBED before me this 9 day of AUGUST. 2002 NOt LOIS E. SNYDER.~ NIIlc.. .. CerIl8Ie Boro, CuI. Ccu1lY.. ... My CuMnliulon ElcplIII M81d15. 2005 REAL E$'l'ATE SALE NO. 16 Writ No. 2001-7172 Civil GMAC Mortgage Corporation VB. ,Bradley A Mills and Cathy J. )\1ills Atty.: Frank Federman ALLTIlAT CERTAIN lot or par- cel of land situated in the. Borough of Newville, Cumberland County. Pennsylvania. known and numbered as No. 73 South High Street. togeth- er with the improvements erected thereon as is more particularly bounded and described as follows: BEGINNING at an iron pin set in Westerly line of twenty (20} foot wide alley which plan is North thirteen (13) degrees forty-seven (47) min- utes fifty-eight (58) seconds West fifty (50.00) feet ft~jfi an exlsting post which said existing post is a corn- man comer of lands now or formerly of Kenneth Graham. lands now or formerly of Ronald M. Stouffer and illndsnoworfurmerlyofH.Wwrren Welch: thence along line of Lot No. 3 of land subdivision for H. Warren Welch Estate. South seventy-three (73) degrees four (04) minutes sIx- teen (IB) seconds West one hnndred seventy-seven and fifty-five hun- dredths (177.55) feet from property corner te:' a point at Easterly curbline of South High Street: thence along said curbline North sixteen (16) de- grees :nineteen (I9) minutes twelve (12) seconds West fifty (50.00) feet to a point at corner of Lot No.1; thence along line of Lot No. 1. North seventy-three (73) degrees five (05) minutes thirty-eight (38) seconds___ East one 'hundred seventy-nine and seventy-five hundredths (179.75) feet through an iron pin set eight and thtrty hundredths (8.30) feet from property comer and through a frame garage situated partially on Lot No. 2 and partially on Lot No. I to an iron pin set in the Westerly edge of a twenty (20) foot wide al- ley: thence along the Westerly edge of said alley, South fourteen (14) degrees forty-seven (47) minutes fifty-eight (58) seconds East fifty (50.00) feet to an iron pin, the point and place of BEGINNING. UNDER AND SUBJECT to the right of public in and to tbe right- of-way for South High Street as shown on said Plan. ALSO UNDER AND SUBJECT to the rights granted unto purchasers of Lot No.3 in and to a right-of-way and easement five {5) feet in width and extending seventy (70) feet East- wardy Ibm the curbline of South HI!!h Street as shown on said Plan. Together with the right. in common ,. T, "~ ""_ 'l .j.l,.,~~... >.- . '~ ....,j I, ""~;J' ~". " "-i-:'~I , Withlfie-U-rantees-tiCLO'r'N1b. <;), U~ heirs and assigns, to utilize the afore- said right-of-way for sewer pur- poses, provided however that any such utilization by Grcmtees, their heirs or assigns, shan be at the cost and expense of the parly exerCising same. Provided, however, Grantees shall have the right to erect a bound- ary line fence. TOGETHER with. in common neverthbless with the Grantor, his successors and assigns, the right of ingress, egress and regress over and alo\1g and to a twenty (20) foot wide alley leaning from Uberty Av- enue in a Southerly direction to line of lands now or formerly of Ronald M. Stouffer as shown on said Sub- division Plan. The obligation to main- tain said alley shall be shared on a pro-rata basis with other purchas- ers from the Estate of H. Warren Welch unless or lUltil the said alley shall be accepted by the Borough of Newville. BEING Lot No. 2 as shown on pla.'tJ. e.."1titled "La."1d Subdivision: fOT H. Warren Welch Estate" dated Jan- uary 25, 1979. whtch said Plan is approved by the Council of the Bor- ough of Newville and recorded in Cumberland Cormty Plan Book No. 35. Page 29. BEING No. 73 South High Street. PARCEL NUMBER: 007A. TAX MAP NUMBER: 2D-1756. Premises: 73 SOUTH HIGH STREET. BOROUGH OF NEW- VILLE. CUMBERLAND COUNTY. PENNS".'LVANlA TITLE TO SAID PREMISES IS VESTED IN Bradley A. MIlls and Cathy J.. Mills, husband and wife by Deed from Larry A. Egge and Julie R. Darbrow-Egge, husband and wlfe dated 7/28 /l998 and recorded 7/31/l998 in Record Book 182 Page 470. ~.... - ~...,~ '~>'~ -. ~~ I_."~ ~" "~"""'''"""",,,,- ~-'~. ~~ '-~..~~1it" ,..~ THE PATRIOT NEWS THE SUNDAY PATRIOT NEWS Proof of Publication UnderAct No. 58?, Approved May 16, 1929 Commonwealth of Pennsylvania, County of Dauphin} ss Frank J. Epler being duly sworn according to law, deposes and says: That he is the Controller of The Patriot News Co., a corporation organized and existing under the laws of the Commonwealth of Pennsylvania, with its principal office and place of business at 812 to 818 Market Street, in the City of Harrisburg, County of Dauphin, State of Pennsylvania, owner and publisher of The Patriot-News and The Sundav Patriot-News newspapers of general circulation, printed and published at 812 to 818 Market Street, in the City, County and State aforesaid; that The Patriot-News and The Sunday Patriot-News were established March 4th, 1854, and September 18th, 1949, respectively, and all have been continuously published ever since; That the printed notice or publication which is securely attached hereto is exactly as printed and published in their regular daily andlor Sundayl Metro editions which appeared on the 23rd and 30th day(s) of July and the 6th day(s) of August 2002. That neither he nor said Company is interested in the subject matter of said printed notice or advertising, and that all of the allegations of this statement as to the time, place and character of publication are true; and That he has personal knowledge of the facts aforesaid and is duly authorized and empowered to verify this statement on behalf of The Patriot-News Co. aforesaid by virtue and pursuant to a resolution unanimously passed and adopted severally by the stockholders and board of directors of the said Company and subsequently duly recorded in the office for the Recording of Deeds in and for said County of Dauphin in Miscellaneous Book "M", Volume 14, Page 317. PUBLICATION COpy S ALE #16 a~....~...................................................... Sworn to and subscribed before Notanal Seal I T eny L. Russell, Notary Public City Of Harrisburg, Dauphin County My Commission Expires June 6, 2006 Member, Pennsylvania Association Of Notaries NOTARY PUBLIC Y commission expires June 6, 2006 . CUMBERlAND COUN1Y SHERIFFS OFFICE CUMBERlAND COUN1Y COURTHOUSE CARLISLE, PA. 17013 , Statement of Advertising Costs To THE PATRIOT-NEWS CO., Dr. For publishing the notice or publication attached hereto on the above stated dates $ Probating same Notary Fee(s) $ Total $ 432.00 1.75 433.75 Publisher's Receipt for Advertising Cost The Patriot News Co., publisher of The Patriot-News and The Sundav Patriot-News, newspapers of general circulation, hereby acknowledge receipt of the aforesaid notice and publication costs and certi.fies that the same have been duly paid. By.................................................................... ~ -;-:~€AL_ J:sTATe~sAIEJio.~16 - -. - u--Wrlt No. 2001-7172 - -.- -_C'vIlTerm :: GMAC Mortgage ""-, COrporation -. vs ~~aaleYA: Mills and --,. Cathy J. Mills - -. --}\lty: Frank Federman DESCRll'TrON .. -~AU. : WAT _CERTAIN lot or parcel of land _~tuBt~jn the Borou~ Newville, Cumbt'rland f-Ci5lfiItr,'" Pennsylvania, . J1O\Vn and numbered as .Yo: 73 South High :::treet, together willi the ~1JI1provemenl'S: erected thereon as is' more ~8{!ic.u]l!1'1J: .1:.0. u!24e.c. _ ~~scdbed ~ fo!IO\y~:. . ~ BEGINNING a(~tnroq pm set in ",:csterly line of :-twenty (20) foot wide alley which plan is Nonh thirt~en (13) degrees forty-seven (47) minutes tifty-elght (58) seconds West VII}' (50.GO) feet from an existing post Whicb said existing paSl is a ....J:.Q!llD1pn ,gJ[!1er of lands now or formerlv of Jcewetb - GJ<ihem-;-:-illMS qDW or formerly -of - Remald}dwStauffecandJands now or formerly of dL Warren Welch; thence along line of Lot No.3 f l.md isiqn for H. Warren Welch Estate, t1i . e:-P3jdesrees' four (04) In 6J,s~cDJ1os West one olII1dred n. fiftY.lh'e'hllrldntdths (17755) Jt()ItlPrope~roa Point'at easterly ~1TIt~of ~pu1,h Rig). Street; t1)ence along said ~!jne N(]itIj-s1xte_en~16) degrees nineteen (19) ~teL~tv~,.ILZ) seconds west fifty (50,00) ~ fe'eflo"ap61n1 at comer"orr6fNO:T; thence along iiine .allot No, I, North stventy-thcee 73) degrel<S five (05) minutes lhirty-eight (38) secoods East . 9JIe hun:)re(j seventy.nine aod seventy-five hundrerltli.s...O,19.17S) feet lbrough an konpin set --.Wght and thitty hundredlh~ (8.30) feet from ~jbperty -co'm-er-and through' a frame garage- ~tua!tG" partiillly OJ) Lot No. and partially on Lot , lSro.Tto.ilJlJron pin set in the Westexly edge of - iWentY--(2D) foot wide alley; thence long the ","-}Vestel'Jyed~.orsair:iAlIey, South fourteen (14) ~~Joct)!;seven..(47) minutes_Hft}'-eigbl (58) -~li:ds East fifty (50,00) feet an iran pin, tin: p..21~t ~lace ofBEGlNNlNG. .JlWttA"RD~'O:l3:J'eCT1D1{'-e-ngnt of public in . ,iIDd to_the nghl.of-way for South High Street as .. JOi.QWn_tis said Plan, ~~b llNQER,'ANP:SUBJEGT io the rigbl~ ~tQ,pu-rchasefs oCtot No.3 in and 10 II ~gbt:of-way and ,easement five (5) feel in width ~cLextentT{n.g seventy.(70) feel eastwardly from .,the curbline ofSoutb High Slreet as shown as said ~JogetheI' with the rigfli, in common with the ~I~~~:Lo~ {,aCNo.. .&,~;ir q~irs ~d assigns. 10 ~{lm.(z<<<--lhe..~.ai'!reSald~,nlJi.t-of.\Yay or sewer ~ provided. l~e"er tfuJl any such ~ !.I.~it.atiQlJ...bx~ranle.es,. tJJeitbcks or assigns, haH bULthe.cost and expense of t1Je party exercising .~ Ji3:mc...Plrwjded, mwever, Grantee,s sha,Illave the ~r:1oerecta bOundaryJilie fence, . ~ :--WGEl'HER. with.. in commD]) ne\'l~rtheless with Ul<I...iRl.D-ID1.Jjis".suCCe8.5ors.8ildasSignS"thenghi ~ngress, egress and'regress.uvcr and along and ~~1W~ptr(2O) foPt. w[d~ aILey leading from ~Qeny Avcfij!e in, a $ollth~[y.dir~lion to Jioe of hnd-iJJQW or formerly ofR6naJd M, Stouffer as ~1~~~~~~J-i'CP1ilitrse~~~~~f~ - :ljiim-:.WIQioili~r purchasers [roOm Ute E~tate of H. Warren Welch Jmle~Lat.untilthe..said aUcy shall E~accepiea/)j'llieBaffiiignofNewvil1e. , ;13EINGT.at.No,2 as shoWD-SlI1. plan entitled "Land' iiS.OOJfVisToo_ fot..K. Warrr!LWelch Estue" dated January 25, 1979~ wHich ;jd Plan is appro."ed .by' - - :lhe Council of the Borough of Newville and. ~uicdj{LCumberl.alld_Cgullty Pla.n_B.oQt No. sgt~~jOuUl"High.Si~.ieL ~_~~~~56.. . ~:.73fu>uthJ:li&h S"",. Jlo~&h of &"WvJl1e. Cumberland County, Pennsylva!ll:l. j. .:rn:.tEro &rUD PREMISES is vested in BradJey _~ll$,-and.CaJhY J. rVIill~, husband and wife, by ::UeedJrom.Larry A. Egge and Julie R. Darbraw_ .egg~husQ8ijd.. and wife. dated 7/28/1998 and_ ~m0JmL(998 in Record .~Q9kJ~2 P.<tge 470~__