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HomeMy WebLinkAbout99-00907 COUNTRYWIDE HOME LOANS, INC. D/B/A AMERICA'S WHOLESALE LENDER Plaintiff IN THE COURT OF COMMON PLEAS CUMBERLAND COUNTY, PENNSYLVANIA vs. NO. 99-907 e'ur'{ c kl2..rJ CIVIL ACTION - LAW _ IN MORTGAGE FORECLOSURE DAVID B. PEPPERMAN AND CHRISTINE A. PEPPERMAN Defendants THIS LAW FIRM IS A DEBT COLLECTOR AND WE ARE ATTEMPTING TO COLLECT A DEBT OWED TO OUR CLIENT. ANY INFORMATION OBTAINED FROM YOU WILL BE USED FOR THE PURPOSE OF COLLECTING THE DEBT. NOT ICE 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 the Complaint and notice are served, by entering a written appearance personally or by attorney and filing in writing with the court your defenses or objections to the claims set forth against you. You are warned that if you fail to do so the case may proceed without you and a jUdgment may be entered against you by the Court without further notice for any money claimed in the Complaint or for any other claim or relief requested by the Plaintiff. You may lose money or property or other rights important to you. YOU SHOULD TAKE THIS PAPER TO YOUR LAWYER AT ONCE. IF YOU DO NOT HAVE A LAWYER OR CANNOT AFFORD ONE, GO TO OR TELEPHONE THE OFFICE SET FORTH BELOW TO FIND OUT WHERE YOU CAN GET LEGAL HELP. Cumberland County Bar Association 2 Liberty Ave., Carlisle, PA 17013 717-249-3166 Legal Services, Inc. a Irvine Row, Carli.sle, PA 17013 717-243-9400 AVISO LE MAN DEMANDADO A USTED EN LA CORTE. SI DESEA DEFENDERSE CONTRA LAS QUEJAS PERESENTADAS, ES ABSOLUTAMENTE NECESSARIO QUE USTED RESPONDA DENTRO DE 20 DIAS DESPUES DE SER SERVIDO CON ESTA DEMANDA Y AVISO. PARA DEFENDERSE ES NECESSARIO QUE USTED, 0 SU ABOGADO, REGISTRE CON LA CORTE EN FORMA ESCRITA, EL PUNTO DE VISTA DE USTED Y CUALQUIER OBJECCION CONTRA LAS QUEJAS EN ESTA DEMANDA. RECUERDE: SI USTED NO REPONDE A ESTA DEMANDA, SE PUEDE PROSEGUIR CON EL PROCESO SIN SU PARTICIPACION. ENTONCES, LA COUTE PUEDE, SIN NOTIFICARIO. DECIDIR A FAVOR DEL DEMANDANTE Y REQUERIRA QUE USTED CUMPLA CON TODAS LAS PROVISIONES DE ESTA DEMANDA. POR RAZON DE ESA DECISION, ES POSSIBLE QUE USTED PUEDA PERDER DINERO, PROPIEDAD U OTROS DERECHOS IMPORTANTES. LLEVE ESTA DEMANDA A UN ABOGADO IMMEDIATAMENTE. SI NO CONOCE A UN ABOGADO, LLAME AL "LAWYER REFERENCE SERVICE" (SERVICIO DE REFERENCIA DE ABOGADOS), 215-238-6300. Cumberland County Bar Association 2 Liberty Ave., CarliSle, PA 17013 717-249-3166 Legal Services, Inc. a Irvine Row, Carlisle, "PA 17013 717-243-9400 COUNTRYWIDE HOME LOANS, INC. D/B/A AMERICA'S WHOLESALE LENDER Plaintiff IN THE COURT OF COMMON PLEAS CUMBERLAND COUNTY, PENNSYLVANIA vs. NO. qq. <70'1 CUoJ-&., DAVID B. PEPPERMAN AND CHRISTINE A. PEPPERMAN Defendants CIVIL ACTION - LAW _ IN MORTGAGE FORECLOSURE COM P L A I N T 1. Plaintiff, COUNTRYWIDE HOME LOANS, INC. D/B/A AMERICA'S WHOLESALE LENDER, is a corporation, with an address of 6400 Legacy Drive, PIano, Texas, 75024-3632. 2. Defendant, DAVID B. PEPPERMAN, is an adult individual whose last known address is 430 ORRS BRIDGE ROAD, CAMP HILL, PENNSYLVANIA 17011. Defendant, CHRISTINE A. PEPPERMAN, is an adult individual whose last known address is 430 ORRS BRIDGE ROAD, CAMP HILL, PENNSYLVANIA 17011. 3. On or about April 4, 1996, the said Defendants executed and delivered a Mortgage Note in the sum of $123,400.00 payable to AMERICA'S WHOLESALE LENDER. The said Note is not accessible to Plaintiff and is believed to have been lost. In further answer thereto, a copy is believed to be in the possession of Defendants. Plaintiff also avers that the within Mortgage foreclosure complaint is based upon the Mortgage and that the attachment of a copy of the Note is unnecessary pursuant to Rules 1019(h) and 1141(a) of the Pennsylvania Rules of Civil Procedure. 4. Contemporaneously with and at the time of the execution of the aforesaid Mortgage Note, in order to secure payment of the same, Defendants made, executed, and delivered to original Mortgagee, a certain real estate Mortgage which is recorded in I'. ,I the Recorder of Deeds Office of the within County and Commonwealth in Mortgage Book 1314, Page 32 conveying to original Mortgagee the subject premises. Countrywide Home Loans is doing business as America's Wholesale Lender. Said Mortgage is incorporated herein by reference. 5. The land subject to the Mortgage is: 1680 HIGH STREET, CAMP HILL, PENNSYLVANIA 17011 and is more particularly described in Exhibit "A" attached hereto. 6. The said Defendants are the real owners of the land subject to the Mortgage. 7. The Mortgage is in default due to the fact that Mortgagors have failed to pay the installment due on April 1, 1998 and all subsequent installments thereon, and the following amounts are due on the Mortgage: (a) Unpaid principal balance $ 121,399.24 (b) Interest at $27.44 per day from 3/1/98 to 3/1/98 (based on contract rate of 8.250%) (f) 5% Attorney's Commission I 10,015.60 , \ 417.15 556.20 I I ! 1,178.35 6,069.96 $ 139,636.50 (c) Accumulated Late Charges (d) Late charges at $46.35 per month for 12 months (e) Escrow Deficit *Together with interest at the per diem rate noted in (b) above after March 1, 1999 and other charges and costs to date of Sheriff's Sale. The attorney's fees set forth above are in conformity with the Mortgage documents and pennsylvania law, and will be collected in the event of a third party purchaser at Sheriff's WHEREFORE, Plaintiff demands judgment in Mortgage foreclosure "IN REM" for the aforementioned total amount due together with interest at the rate of 8.250% ($27.44 per diem), together with other charges and costs including escrow advances incidental thereto to the date of Sheriff's Sale and for foreclosure and sale of the property within described. ALLER By Leo P. Halle Attorney for Plaintiff I.D. #15700 1719 N. Front Street Harrisburg, Pa. 17102 (717) 234-4178 '. " , . --.. , ,. . ..~\ \ Legal Deocriptloll ^'..L thot curtain tract or lot of land situate in till!! Borough of Camp 11111. Cumberland. County, PennsylvDnin. more pal.'l:lcularly lJoumled amI deacribec.l aD 1:0.1.10\010. to Witl , " , , DEOINNINO at a point in the northern 11110 of 1I1gh Street. onld poiut of Deginning being at: the interBection of the' .r.orthern line of High Gtreet: with the eastern line of . n twenty feel: wide nlley. known ao Rover ^lley I thence along l:he lIorthern line of lIigh street, North 60 degrees BAst. a diotance of 01 feet to a point: thence along the line'.... of lands noW" or f01:merly of ^nurew W. Mueller. el: UK of .which, tlll.s is a part, North 22 ". deg1:ceo Weot. a distance of 150.20 feet to a point in th.! Doul:IH~rri line of l'\ 15 feet' wir.le alley; thence along the southern line oC snit! alley, South GO degrees West, a diDtnnce of 07 feet to a point: in the eastern linear l\ 20 Ceel: ,wiele alley known a9 Rover J\lley, aforementioned; thence along the e8D\:er.n line of said Rover T\lley, South ,,7. elegrees East, a~ distance of 150.20 reel:. to a poilll: in the northern line of High Street, aforementioned, the Place of Br::OINt'aNG. lI^VINlJ thereon erected a single family brick, ranch type dwelling hOUDe, known alld numbered ad lGOO High Street, Camp 11111, ~^. t="'ihiblt \\/{ >- Ln n; .~ ~u}~ -:: ~~(. -. r/l H"'. A.' - J (~r.-:' .--: 2:., r- U-ll... - -, er": en - :J... L,'j 1-- lI- u- CT o o~ 'j-. ---,.. --;.. + c:::j: c:j '-.J I~ ~~ I (2. 0 G'- , ; ,,' 1"\ 0 r'S ;';..; ~]2 K ~ ,;;;e \) Zi) ~ ~ '~ d ~ ;j tJ ci ~i ~ ~ ..; I C\ ~ I .l'J ~; j ~ ~II~ P< I N II ~ . ..:d :;; ~ . N . . 0 . -- ~~~~ I ~~p ~ ~ ... ~ II I 7. ~ In :> - . d.~2 il < " ~ 0 --3- -j- 0- r-- a- 0- ~ --- ()o If) ':J1 "=tj .'.) .J '1k .J .~ c) ~; ~ -?o cD -- -.2 -- -, 6.-; (~";' (j 05 '.- :-5 <;: \... cr;. Q e '_3 ~~: -<Y u.~~' . a- d -t () ','. .-..\ . cc.. ....1 ifJ }~,:: \ ::. .,.-,.... '- <;) \~'; 1.0 .:~-~! ~5 '0 3 C'.- f. lU . \1.._ !.\.I!....'..J -~~ l' . :5 ~f.1[l_ ~ ll- -.:~_ -") > \... ,- en ::;) l..!.. <.) 0 ",. ~ ..:J' f;,~ ~:'? ('"". @ \.:-:; c.,: l'.l~) ; ) .. ()~ - ..1 :~ :.; p:~ tl- . , .'. F'~, () (~, , '. -:j , ~- C'; ~n " uJ ,.. j ~~~ ._1 u: '~ ~ __j' " :~:: ~ ' "I t.lJ " .. ::.::~ ~n (1. ,1 lJ. C' ... 0 .;;) G" U S- O l'- -:r l'- Q: :r ()o '=ll ~ "'l1 i '@ = = :; -= 1b 1L ::. : ~ 0 = -.] 0 I) 6 tD l{) rf) 0 0 'I'} 0 tn lJ) l{) @ cf -:::t r<) (Q rI1 -. ~ ~ 0 rV <V ? ? '\) -:. --0 . -! ,') = U .J .9 0 8 0J :l g; .'tj A SCHEDULE OF DISTRIBUTION, being a list of the persons and/or governmental or corporate entities or agencies being entitled to receive part of the proceeds of the sale received and to be disbursed by the Sheriff (for example, to banks that hold mortgages and municipalities that are owed taxes) will be filed by the Sheriff of this County thirty (30) days after the sale and distribution of the proceeds of sale in accordance with this schedule will, in fact, be made unless someone objects by filing exceptions to it within ten (10) days of the date it is filed. Information about the Schedule of Distribution may be obtained from the Sheriff of the Court of Common Pleas of the within County at the Courthouse address specified herein. THIS PAPER IS A NOTICE OF THE TIME AND PLACE OF THE SALE OF YOUR PROPERTY. IT HAS BEEN ISSUED BECAUSE THERE IS A JUDGMENT AGAINST YOU. IT MAY CAUSE YOUR PROPERTY TO BE HELD, TO BE SOLD OR TAKEN TO PAY THE JUDGMENT. You may have legal rights to prevent your property from being taken away. A lawyer can advise you more specifically of these rights. If you wish to exercise your rights, YOU MUST ACT PROMPTLY. YOU SHOULD TAKE THIS PAPER TO YOUR LAWYER AT ONCE. GO TO OR TELEPHONE THE OFFICE SET FORTH BELOW TO FIND OUT WHERE YOU CAN GET FREE LEGAL ADVICE: Cumberland County Bar Association 2 Liberty Avenue Carlisle, Pennsylvania 17013 Phone (717) 249-3166 THE LEGAL RIGHTS YOU MAY HAVE ARE: 1. You may file a petition with the Court of Common Pleas of the within County to open the judgment if you have a meritorious defense against the person or company that has entered judgment against you. You may also file an petition with the same Court if you are aware of a legal defect in the obligation or the procedure used against you. 2. After the Sheriff's Sale you may file a petition with the Court of Common Pleas of the within County to set aside the sale for a grossly inadequate price or for other proper cause. This petition MUST BE FILED BEFORE THE SHERIFF'S DEED IS DELIVERED. ,..4'" COUNTRYWIDE HOME LOANS, INC. D/B/A AMERICA'S WHOLESALE LENDER Plaintiff vs. DAVID B. PEPPERMAN AND CHRISTINE A. PEPPERMAN Defendants IN THE COURT OF COMMON PLEAS CUMBERLAND COUNTY, PENNSYLVANIA NO. 99 - 907 DATE OF THIS NOTICE: May 25, 1999 TO: DAVID B. PEPPERMAN 2102 FOXFIRE DRIVE CAMP HILL, PENNSYLVANIA 17011 CHRISTINE A. PEPPERMAN 2102 FOXFIRE DRIVE CAMP HILL, PENNSYLVANIA 17011 CIVIL ACTION - LAW IN MORTGAGE FORECLOSURE THIS LAW FIRM IS A DEBT COLLECTOR AND WE ARE ATTEMPTING TO COLLECT A DEBT OWED TO OUR CLIENT. ANY INFORMATION OBTAINED FROM YOU WILL BE USED FOR THE PURPOSE OF COLLECTING THE DEBT. IMPORT~ NOTICE YOU ARE IN DEFAULT BECAUSE YOU HAVE FAILED TO ENTER A WRITTEN APPEARANcE PERSONALLY OR BY ATTORNEY AND FILE IN WRITING WITH THE COURT YOUR DEFENSES OR OBJECTIONS TO THE CLAIMS SET FORTH AGAINST YOU. UNLESS YOU ACT WITHIN TEN (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: Lawyer Referral Service Court Administrator Cumberland County Courthouse Carlisle, PA 17013 717-240-6200 PURCELL, KRUG & HALLER I I I BY~ Leon P. Halh:-r- Attorney for Plaintiff I.D. #15700 1719 N. Front Street Harrisburg, Pa. 17102 (717) 234-4178 '- -:J' >- [i- <': t:'; ....;1 ~.=:- c-'; ... i I.U~_~ , 1 .., S-J < . ~ .' . ,. (.1 : :..J~ :C 6... . I,!. ! :, C.) , '. '. , ( :n (. ! 0 .. U.. .' j:.. , -,0 , :'j !U [i:. ;;; ) ::1- r::: " U_ (n :5 0 (;') U " , .' ~ .... LEGAL DESCRIPTION ALL that certain tract or lot of land situate in the Borough of Camp Hill, Cumberland County, Pennsylvania, more particularly bounded and described as follows, to wit: BEGINNING at a point in the northern line of High Street, said point of Beginning being at the intersection of the northern line of High Street with the eastern line of a twenty feet wide alley, known as Rover Alley; thence along the northern line of High Street, North 68 degrees East, a distance of 87 feet to a point; thence along the line of lands now or formerly of Andrew W. Mueller, et ux of which this is a.part, Nor.th 22!degrees West, a distance of 150.20 feet to a point. in the.southern.line of a 15 feet wide alley; thence along the southern line of said alley, South 68 degrees West, a distance of 87 feet to a point in the eastern line of a 20 feet wide alley known as Rover Alley, aforementioned; thence along the eastern line of said Rover Alley, South 22 degrees East, a distance of 150.20 feet to a point i.n the northern line of High Street.. aforementioned, the Place of BEGINNING. HAVING THEREON ERECTED A DWELLING KNOWN AS 1680 High Street, Camp Hill, Pennsylvania BEING THE SAME PREMISES which Ferne Smith Hetrick and Reda Smith Long by their Deed dated April 4, 1996 and recorded in Cumberland County Deed Book 137, Page 749, granted and conveyed unto David B. Pepperman and Christine A. Pepperman. TO BE SOLD AS THE PROPERTY OF DAVID B. PEPPERMAN AND CHRISTINE A. PEPPERMAN UNDER JUDGMENT NO. 1999-907 CIVIL TERM PARCEL NO. 01-21-0269-142 >- l.() , -- r;; C":- ~-".:: ., (-j ('') U_I..:;.,. o~c- jj: ~. do_. :-.1 ';l,. r~ ; , (1)(-' In C1~ ! ',! c u.;.,.;. - -' I ; i !J ti: ! ~: -.", :.!.? {-'- r.: -) .;,;: ,-'- en :;) 0 m 0 . - '-. .... I. ,. A SCHEDULE OF DISTRIBUTION, being a list of the persons and/or governmental or corporate entities or agencies being entitled to receive part of the proceeds of the sale received and to be disbursed by the Sheriff (for example, to banks that hold mortgages and municipalities that are owed taxes) will be filed by the Sheriff of this County thirty (30) days after the sale and distribution of the proceeds of sale in accordance with this schedule will, in fact, be made unless someone objects by filing exceptions to it within ten (10) days of the date it is filed. Information about the Schedule of Distribution may be obtained from the Sheriff of the Court of Common Pleas of the within County at the Courthouse address specified herein. THIS PAPER IS A NOTICE OF THE TIME AND PLACE OF THE SALE OF YOUR PROPERTY. IT HAS BEEN ISSUED BECAUSE THERE IS A JUDGMENT AGAINST YOU. IT MAY CAUSE YOUR PROPERTY TO BE HELD. TO BE SOLD OR TAKEN TO PAY THE JUDGMENT. You may have legal rights to prevent your property from being taken away. A lawyer can advise you more specifically of these rights. If you wish to exercise your rights, YOU MUST ACT PROMPTLY. YOU SHOULD TAKE THIS PAPER TO YOUR LAWYER AT ONCE. GO TO OR TELEPHONE THE OFFICE SET FORTH BELOW TO FIND OUT WHERE YOU CAN GET FREE LEGAL ADVICE: Cumberland County Bar Association 2 Liberty Avenue Carlisle, Pennsylvania 17013 Phone (717) 249-3166 THE LEGAL RIGHTS YOU MAY HAVE ARE: 1. You may file a petition with the Court of Common Pleas of the within County to open the judgment if you have a meritorious defense against the person or company that has entered judgment against you. You may also file an petition with the same Court if you are aware of a legal defect in the obligation or the procedure used against you. 2. After the Sheriff's Sale you may file a petition with the Court of Common Pleas of the within County to set aside the sale for a grossly inadequate price or for other proper cause. This petition MUST BE FILED BEFORE THE SHERIFF'S DEED IS DELIVERED. >;-: If' r.': c.., C': .+/ ;':~: .,) ~.:: " I f ~-, (': , .., c)", .' ."' - ~ ,,-. ~. 'I ;~'_l C) C -7: t:) , '_f"> >. : , ", ,. , ,'. : .' ','-:1 L : -~ - ~-::.) ,- t). C1' ::s () 0'"\ () -,+,--~.'~ '. _..+_.,_.----~.- '. ..,,) -- If) '>~ t~; c.: [;:: ~:': . : 1l.J f~: ~~ .- . .) , , C) ~.- , , . , !~C I ...:.. ~~l ! r~? ! .- ,-, r.-,) i ., Ct . -;1 :;:; I LV ,. -I" ". , ;'iiiJ t:..:"::: ...., ~i:i(L I r. =) .,"- I ll. m ::l , 0 Goo, U , Countrywidc Homc Loans, Inc. -vs- David B. Pcppcrman and Christinc A. Peppcrman In thc Court of Common Picas of Cumbcrland County, Pcnnsylvania No. 99-907 Civil Robert L. Fink, Jr. Dcputy Shcriffwho being duly sworn according to law, says on July 7, 1999 at 4;30 o'clock P.M. EDST, he posted a true copy of Real Estate Writ Notice Postcr and Dcscription in thc above entitled action upon the propcrty of David B. Pcpperman and Christinc A. Pcppermanlocatcd at 1680 High Street, Camp Hill, Cumberland County, Pennsylvania, according to law. Michael E. Barrick, Deputy Sheriff, who being duly sworn according to law, says on July 29,1999 at 3:16 o'clock P.M. EDST, he served a true copy of Real Estate Writ Notice Poster and Description in the above entitled action upon one of the within named defendants to wit: David B. Pepperman, by making known unto David Pepperman at 1901 State Street. Camp Hill Cumberland County, Pennsylvania, its contents and at the same time handing to him personally the said true and attested copies of the same. Michael E. Barrick, Deputy Sheriff who being duly sworn according to law, says on July 29,1999 at 3:25 o'clock P.M. EDST, he served a true copy of Real Estate Writ Notice Poster and Description, in the above entitled action upon one of the wihtin named defendants to wit: Christine Pepperman, by making known unto Paul Duggan, Father at 2803 Columbia Avenue, Camp Hill, Cumberland County, Pennsylvania, its contents and at the same time handing to her personally the said true and attested copies of the same. R. Thomas Kline, Sheriff, who being duly sworn according to law, says he served the above Real Estate Writ Notice Poster and Description in the following manner: The Sheriff mailed a notice of the pendency of the action to one of tile within named defendants to wit; David Peppenman by regular mail to his last known address 2102 Foxfire Drive, Camp Hill, Pennsylvania. This letter was mailed under the date of July 29, 1999 and returned to the Sheriff's Office on August 4, 1999 with reason checked No Such Number. R. Thomas Kline, Sheriff, who being duly sworn according to law, says he served the above Real Estate Writ Notice Poster and Description in the following manner: The Sheriff mailed a notice of the pendency of the action to one of the within named defendants to wit: Christine Pepperman by regular mail to her last known address 2803 Columbia Avenue, Camp Hill, Pennsylvania. This letter was mailed under the date of July 30, 1999 and never returned to the Sheriff's Office. R. Thomas Kline, Sheriff, who being duly sworn according to law, says after due and legal notice had been given according to law, exposed the within described premises at public venue or outcry at Court House, Carlisle, Cumberland County, Pennsylvania, on September 1,1999 at 10:00 o'clock A.M. EDST, and sold the same for the sum of $110,000.00 to Attorney Jill Wineka for Federal National Mortgage Association. It being the highest bid and best price received for the same Federal National Mortgage Association of 1900 Market Street, Suite 800, Philadclphia, Pennsylvania being the buyer in this Execution paid to R. Thomas Kline Sheriff, the sum 01'$ 3,241.59 it being costs. .,' .. _.. 0'.. 'i. , TITLE REPORT THE PREMISES ENDORSED HEREON ARE SUBJECT TO THE FOLLOWING ITEMS, WHICH WILL BE EXCEPTED IN THE POLICY UNLESS SATISFACTORY EVIDENCE PERMITTING THEIR REMOV AL IS PRODUCED. SHERIFF SALE NO. 21 Held Wednesday, September 1, 1999 Date: September 1, 1999 TAXES: Receipts for all taxes for the years 1996 to 1998 inclusive. Taxes for the current year 1999. WATER RENT: SEWER RENT Company assumes no liability for private supply of watcr or sewer. Receipts to be produced if serviccs are lienable. MECHANICS' AND Possible unfilcd Mechanics Liens and Municipal Claims. MUNICIPAL CLAIMS MORTGAGES: Listed Under Other Exceptions Below. JUDGMENTS: Listed Under Other Exceptions Below. INSTRUMENTS TO BE PRODUCED: Deed from Cumberland County Sheriff to dated , 1999, and recorded ,1999, in Cumberland County Deed Book ,Page RECIT AL: Being the same premises which Feme Smith Hetrick and Reda Smith Long, Executrices of the Estate of Bernice G. Smith by Deed dated April 4, 1996 and recorded April 16, 1996 in the Office of The Recorder of Deeds in and for Cumberland County at Carlisle, Pennsylvania in Decd Book 137, Page 749 granted and conveyed to David B. Pepperman and Christine A. Pepperman, his wife. OTHER EXCEPTIONS: I . The identity and legal competency of partics at thc closing of this title should be established to the satisfaction of the closing attorney acting for this Company, 2. Rights or claims of parties in possession, if any, other than the owner. 3. Unrecorded easements, discrepancies or conl1icts in boundary lines, shortage in area and encroachments which an accurate and complete survey would disclose. 4. Payment of State and local Real Estate T ransfcr Taxes, if required. 5. Public and private rights in the roadbed of High Street and 20 feet wide Rovcr Alley. 6. Mortgagc in the amount of $123,400.00 givcn by David B. Pepperman and Christine A. Peppcrman, husband and wife, to Amcrica's Wholesalc Lcndcr datcd April 4, 1996 and rccorded April 16, 1996 in Mortgagc Book 1314, Page 32. Complaint in.Mortg,~gc Foreclosur~ f\lcd on Fcbruary 17, 1999 by <;~llll1trywide H.ome Loan Inc., dOlllg buslllcss as Amcnca s Wholcsale Lcnder as PlallltIlf agalllst DaVid B. I . A SCHEDULE OF DISTRIBUTION, being a list of the persons and/or governmental or corporate entities or agencies being entitled to recei ve part of the proceeds of the sale received and to be disbursed by the Sheriff (for example, to banks that hold mortgages and municipalities that are owed taxes) will be filed by the Sheriff of this County thirty (30) days after the sale and distribution of the proceeds 0f sale in accordance with this schedule ~ill, in fact, be made unless someone objects by filing exceptions to it within ten (10) days of the date it is filed. Information about the Schedule of Distribution may be obtained from the Sheriff of the Court of Common Pleas of the within County at the Courthouse address specified herein. THIS PAPER IS A NOTICE OF THE TIME AND PLACE OF THE SALE OF YOUR PROPERTY. IT HAS BEEN ISSUED BECAUSE THERE IS A JUDGMENT AGAINST YOU. IT MAY CAUSE YOUR PROPERTY TO BE HELD. TO BE SOLD OR TAKEN TO PAY THE JUDGMENT. You may have legal rights to prevent your property from being taken away. A lawyer can advise you more specifically of these rights. If you wish to exercise your rights, YOU MUST ACT PROMPTLY. YOU SHOULD TAKE THIS PAPER TO YOUR LAWYER AT ONCE. GO TO OR TELEPHONE THE OFFICE SET FORTH BELOW TO FIND OUT WHERE YOU CAN GET FREE LEGAL ADVICE: Cumberland County Bar Association 2 Liberty Avenue Carlisle, Pennsylvania 17013 Phone (717) 249-3166 THE LEGAL RIGHTS YOU MAY HAVE ARE: 1. You may file a petition with the Court of Common Pleas of the within County to open the judgment if you have a meritorious defense against the person or company that has entered judgment against you. You may also file an petition with the same Court if you are aware of a legal defect in the obligation or the procedure used against you. 2. After the Sheriff's Sale you may file a petition with the Court of Common Pleas of the within County to set aside the sale for a grossly inadequate price or for other proper cause. This petition MUST BE FILED BEFORE THE SHERIFF'S DEED IS DELIVERED. , . THE PATRIOT NEWS THE SUNDAY PATRIOT NEWS Proof of Publication Under Act No. 587. Aooroued MaU 16. 1929 Commonwealth of Pennsylvania, County of Dauphin} ss ~ichae/~orrow being duly sworn according to law, deposes and says: ThaI he is the Assistant 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 Markel Street, in the City of Harrisburg, County of Dauphin. State of Pennsylvania, owner and publisher of THE PATRIOT.NEWS and THE SUNDAY PATRIOT.NEWS newspapers of general circulation, printed and published at 812 to 818 Market Street, In the City, County and State aforesaid: that THE PATRIOT.NEWS and THE SUNDAY PATRIOT.NEWS were established March 4th, 1854, and September 18th, 1 949, respectively, and all have been continuously published ever since: That the printed notice or publication which is securely attached hereto is exactly as printed and published in their regular daily and/or Sunday and Metro editions/issues which appeared on the 27th day(s) of July and the 3rd and 10th day(s) of August 1 999. 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 personai 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 au hin 'n Miscellaneous Book "M", Volume 14, Page 317. , PUBLICATION COPY S ALE #21 Sw rn 1999 A.D. CUMBERlAND COUNlY SHERIFFS OFRCE COURTHOUSE CARLISLE, PA. 17013 Statement of Advertisina 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 $ 320.82 1.50 322.32 , Publisher's Receipt for Advertising Cost THE PATRIOT-NEWS CO., publisher of THE PATRIOT.NEWS and THE SUNDAY PATRIOT.NEWS, newspapers of general circulation, hereby acknowledge receipt of the aforesaid notice and publication costs and certifies that tho same have been duly paid. THE PATRiOT.NEWS CO. By.................................................................... REAL ESTATE SALE NO. 21 Wrtt No. 99-907 Civil COlllltlywtdc Home Loans, fnc.. d/b/a America's WholcSlllc 1~lldcr VS. David B. Pepperman Il!lel Cllrtstlnc A. Pepperman Ally.: Leon P. Haller LEGAL DESCRIPTION ALL that certain lmet or lot ofland sUuate In the Borough of Camp HUI. Cumberland County. Pennsylvania. morc particularly bounded and dc- sertbed as follows. to wit: BEGINNING at a point In the northern line of High Street. said point of Beginning being al the Inter- section of the nor,\hcrn line of Hlp;h Street with the eastern line ora twen. ty feet wJdc alley, known as Rover Alley; thence along the northern line of High Street. North 68 degrees East. a distance of 87 feet to a point; thence along the I1nc of lands now or formerly of Andrew W. Mueller, cl ux of which 011s 1s a part, North 22 dc. grces West, a distance of 150,20 feet to a point In Ule souUlern lIne ofa 15 feet wide alley; thence along the .5l.ili:.hcrn line of !j~!d <lll/;'y. S0111h RA degrees West. a distance of 87 feet to a point In U1C eastern line of a 20 feet wiele alley known as Rover Alley, nforementJoned: thence along the eastcrn I1ne of said Rover Alley. South 22 degrees East. a distance of 150,20 fect to a point In the northcrn line of High Street. aforcmcntloned, the Place of BEGINNING. HAVING THEllEON ERECTED A DWELLING KNOWN AS 1680 Htgh S~reet. Camp HIli, Pennsylvania. BEING THE SAME PREMISES which Ferne SmJlh Hellick and Recla Smith Long by their Deed daled April 4, 1996 and recorded In Cumberland County Deed Book 137. Page 749. granted and conveyed unto David B. Pepperman and ChrtsUne A. Pepper- man. TO BE SOLD AS THE PROPUnY 01' DAVID B. PEPrC;RMAN AND CHRISTINE A. I'U'PERMAN UNDER JUDGMENT NO. 1999-907 CIVIL TERM. PARCEL NO. 01-21-0269-142. " .- .-, .1 (' .\ "