HomeMy WebLinkAbout99-01854
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AVIBO
Le han demandado a usted en la corte. Si usted quiere defenderse
de estas demandas expuestas en las paginas siguientes, usted tiene
veinte (20) dias de plazo al partir de la fecha de la demanda y la
notificacion. Hace falta ar.centar una comparencia escrita 0 en
persona 0 con un abogado y entregar a la corte en forma escrita 9US
defensas 0 sus objecioncs alas demandas en contra de su persona.
Sea avisado que si Usted no se dafiende, la corte tomara medidas y
puede continuar la demanda en contra suya sin previo aviso 0
notificacion. Ademas, la corte puede decidir a favor del
demandante y requiere que usted cumpla con todas las provisiones de
esta demanda. Usted puede perder dinero 0 sus propiedades u otros
derechos importantes para usted.
LLEVE ESTA DEMANDA A UN ABOGADO IMMEDIATAMENTE, SI NO TIENE ABOGADO
o SI NO TIENE EL DINERO SOPICIENTE DE PAGAR TAL SERVICIO, VAYA EN
PERSONA 0 LLAME POR TELEPONO A LA OPICINA CUYA DIRECCION SE
ENCOENTRA ESCRITA ABAJO PARA AVERIGOAR DONOE SE PUEDE CONSEGOIR
ASISTENCIA LEGAL.
Court Administrator
Cumberland County Courthouse
1 Courthouse Square
Carlisle, PA 17013-3387
717-240-6200
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l.
caption
is such
Plaintiff is the Corporation designated as such
on a preceding page. If Plaintiff is an assignee
by virtue of the following recorded assignments:
in the
then it
AssignQr: Ameriquest Mortgage Company
'Assignments of Record to: Lehman Capi tal, A Division of Lehman
Brotfiers Holdings, Inc.
Recording Date: LODGED FOR RECORDING Book: Page:
2. Defendant(s) is the individual designated as such on the
caption on a preceding page, whose last known address is as set
forth in the .caps~on, and unless designated otherw~~e, is the real
owner(s) and mortgagor(s) of the premises being foreclosed.
3. On or about the date appearing on the Mortgage
hereinafter described, at the instance and request of Defendant(s),
Plaintiff (or its predecessor, hereinafter called Plaintiff) loaned
to the Defendant (s) the sum appearing on said Mortgage, which
Mortgage was executed and delivered to Plaintiff as security for
the indebtedness. Said Mortgage is incorporated herein by
reference in accordance with Pa.R.C.P. 1019 (g).
The information regarding the Mortgage being foreclosed is as
follows:
MORTGAGED PREMISES: 3 Sunset Drive
MUNICIPALITY/TOWNSHIP/BOROUGH: Township of Silver Spring
COUNTY: Cumberland
DATE EXECUTED: 6/8/98
DATE RECORDED: 6/15/98 BOOK: 1460 PAGE: 673
Th'e :llegal de'scHiptd:cm of the mortgaged premises' is' attached hereto
and made part hereof.
4. Said Mortgage is in default because the required payments
have not been made as set forth below, and by its terms, upon
breach and failure to cure said breach after notice, all sums
secured by said Mortgage, together with other charges authorized. by
said Mortgage itemized below, shall be immediately due.
S. After demand, the Defendant (s) continues to fail or
refuses to comply with the terms of the Note as follows:
(a) by failing or refusing to pay the installments of
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principal and interest when due in the amounts indicated
below;
(b) by failing or refusing to pay other charges, if any,
indicated below.
6. The fOllowing amounts are due on thp said Mortgage. as of
3/9/99:
Principal of debt due and unpaid
Interest at 9.5%*
from 9/1/98
to 3/9/99
(the per diem interest accruing on
this debt is $30.58 and that sum
should be added each day after
3/9/99)
Title Report
Court Costs (anticipated, excluding
Sheriff's Sale costs)
Escrow Overdraft/(Balance)
(The monthly escrow on this account
is $150.08 and that sum should
be added on the first of each
month after 3/9/99)
Late Charges
(monthly late charge of $58.52
should be added on the f1fteenth of
each month after 3/9/99)
Fees Billed
Quote Fee
Satisfaction Fee
Attorneys Fees (anticipated and actual
to 5% of principal)
$115,885.41
5,779.79
250.00
280.00
(50.25)
292.60
26.85
10.00
45.00
5.794.27
TOTAL $128,313.67
*Thisin:i:'life's't' rate is subject. to adjustment: as more fully set
forth in the Note and Mortgage
7. The attorney's fee 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
Sale. If the mortgage is reinstaLed prior to the sale, reas0nable
attorney's fees will be charged in accordance with the reduction
provisions of Act 6, if applicable.
8. Notice of Intention to Foreclose under Act 6 of 1974 of
the Commonwealth of Pennsylvania is not required as the original
principal amount exceeds the sum of $50,000.00. The notice
specified by the Pennsylvania Homeowner's Emergency Mortgage
ARsistance Program, Act 91 of 1983, has b~en sent as required on
the date appearing on the copy attached hereto as Exhibit. "A", and
Defendant(sl have failed to proceed within the time limits, or have
been determined ineligible, or Plaintiff has not been notified in
a timely manner of Defendant(s) eligibility.
WHEREFORE, the Plaintiff demands judgment, in rem, against
the Defendant(sl herein in the sum of $128,313.67, plus interest,
costs and attorneys fees as more fully set orth in the Complaint,
and for foreclosure and sale of the Mor g ged premises.
Udren, ESQUIRE
MARK J. UDREN & ASSOCIATES
Attorney for Plaintiff
Attorney I.D. No. 04302
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VIA Fint Clu. Mail
VIA Certified Mail (,ellnl ,..eip! 'equested)
ROBERTMANNlNG ,SHARON MANNING
3 SUNSET DR
MECHANICSBURG, PA 170SS
Re: Loon Number: 37t 7S68
Property Address: 3 SUNSET DR, MECHANICSBURG MECHANICSBU, PA 170SS
FROM: OcwenFedef31BankFSB
Yau or. her.by ootified that this teller is an attempt to colle.. a debt. All information obcainod will be \lied ror that purpcI'.
You 01'" b. .1J;Ib1e ror naaaclall.lllshlaco th.t wID prev.at roreclosure o. 10ur mortpp If 10U complr wltbth.
provlsloas 01 lb. Hom......n' Em.r;..C)' MortPI' Asslmo.c. Act 0' 1983 (th. "Act"). You 01'" b. .lJ;Ibt. ror .m.....C)'
t.mponry o.uIslaac. If 10ur d.r.ult has b... ..wad br .In:uJDSta.c.. b'"ODd )'Our co.troI, 10U hov. . ".....bl. prospectol
ruumluC 10ar mortpc. p.,.,...", ..d If 10U m.et oth.r .IJ;IbW", nqulrem..ts eshlhlbh.d br the P'IlDI1In... HOWl
F1uOllC. Ac"C)'. PI.... re.d .0 0' thls Nollc.. It CODlaIas OIl uplDD.lIo. 0' 10ur rlchls.
Under lhe Act, you or. entitled to a temporary Illy or Coreclosur. .. 'fOOl mor1g.g. ror thirty (30) days from lhe date or this
Nolio.. During that time you must """'8' and .;tend a "face-to-r.c." meeting with a repr..entativ. or this lender, or with .designat.d
c.....,er credit c""",eling agency. The purpcle of this meetmg is to attempt to work out a repayment plan, or to otberwis. settleyour
de1icqueocy, Thio meeting mUlt occur in lhe next thirty (30) days.
IC you attend a face.to-face meeting with this lender, or with a consumer credit counseling agency idectified in this notice, no
fUrther proceeding in mor1g.ge roreclosure may lake plac. Cor thirty (30) days after the date or this meeting. The 1lIIIle, addrwond
lelephale IllIIIlher or our repr..entativ. is:
Toay VanNess
Foreclosur. Coordinator
OcwenFedetal Bank FSB
P. O. Box 24737, Suite SA
W..tPalm Beach, F1orida'33416-4737
Toll Free T.lepborle N\JII\ber: 1-800-74 OCWEN
The 1lIIIl.. and addr..s.. or designated CC<lSUll1er aedit c""",elinB agOllci.. are shown..lhe attached sheet It is ooly
1lOCWI%)' to schedule ODe r.c.-to-f.c. m..ting. You should .elvis.this lender imm.diately oCyour intentioos.
EXHIBIT A
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"O"C"W"it'N"
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ACT 91 NOTICE
TAKE ACTION TO SAVE
YOUR HOME FROM
FORECLOSURE
The Commonwealth of Pennsylvania's
Homeowner's Emergency Mortgage Assistance
Program
may be able to help you.
Read the attached notice to find out how the
program works.
If you need more information, call the Pennsylvania
Housing Finance Agency at 1(800) 342-2397.
LA NOTIFICACION ADJUNTO ES DE SUMA IMPORTANCIA, PUES AFECTA SU DERECHO A
CONTINUAR VIVIENDO EN SU CASA SI NO COMPRENDE EL CONfENIDO DE ESTA
NOTIFICACION OBTENGA UNA TRADUCCION INMEDIATAMENTE LLAMANDO A ESTA
AGENCIA (pENNSYLVANIA HOUSING FINANCE AGENCY) SIN CARGOS AL NUMERO
MENCIONADO ARRIBA PUEDES SER ELEOffiLE PARA UN PRESTAMO POREL PROGRAMA
LLAMADO "HOMEOWNER'S EMERGENCY MORTGAGE ASSISTANCE PROGRAM" EL CUAL
PUEDE SAL V AR SU CASA DE LA PERDIDA DEL DERECHO A REDIMIR SU HIPOTECA
ACT 91 NOTICE
IMPORTANT: NOTICE OF HO:MEOWNERS'
EMERGENCY MORTGAGE ASSISTANCE PROGRAM
PLEASE READ THIS NOTICE.
YOU MAY BE ELIGlliLE FOR FINANCIAL ASSISTANCE
WHICH CAN SAVE YOUR HO:ME FROM FORECLOSURE AND
HELP YOU MAKE FUTURE MORTGAGE PAYMENTS
P 968 534 900
V F. R I FIe A T ION
Mark J. Udren, Esquire, hereby states that he is the attorney
for the Plaintiff, a corporation unless designated otherwise; th3t
he is authoiized to take this Verification and does so because or
the exigencies regarding this matter, and because Plaintiff must
verify much of the information through agents, and because he has
personal knowledge of some of the facts averred in the foregoing
pleading; and that the statements made in the foregoing pleading
are true and correct to the best of his knowledge, information and
belief and the source of his information is public records and
reports of Plaintiff's agents. The undersigned understands that
this statement herein is made subject to the penalties of 18
Pa.C.S. Section 4904 relating to unsworn falsification to
authorities.
Udren, ESQUIRE
UDREN & ASSOCIATES
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SHERIFF'S RETURN - REGULAR
CASE NO: 1999-01854 P
COMMONWEALTH OF PENNSYLVANIA:
COUNTY OF CUMBERLAND
LEHMAN CAPITAL ET AL
VS.
MANNING ROBERT B ET AL
SHANNON SUNDAY , Sheriff or Deputy Sheriff of
CUMBERLAND County, Pennsylvania, who being duly sworn according
to law, says, the within NOTICE AND COMPLAINT IN was served
upon MANNING SHARON C the
defendant, at 10:56 HOURS, on the 31st day of March
1999 at 3 SUNSET DRIVE
MECHANICSBURG, PA 17055 ,CUMBERLAND
County, Pennsylvania, by handing to ROBERT MANNING (HUSBAND)
a true and attested copy of the NOTICE AND COMPLAINT IN
together with MORTGAGE FORECLOSURE
and at the same time directing His attention to the contents thereof.
Sheriff's Costs:
Docketing
Service
Affidavit
Surcharge
So ?~~t
K. lhomas Kl~ne, bher~Lf
6.00
.00
.00
8.00
$1.'.. UU
MARK J. UDREN
04/01/1999
by
~lt ",;cmL 271, fiAL-rtrUf
uepu y b en.
Sworn and subscribed to before me
this i day of ~AJ'.P
"q~ A~
If op) J ~o!)fY
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MARX J. UDRIH . ASSOCIATES
BY, Mark J. Udren, E.quire
ATTY I.D. XO. 04302
1040 X. EIXGS BIGHWAY, SUITE 500
CHERRY BILL, XJ 08034
609-482-6900
Lehman Capital. A Division of
Lehman Brothers Holdings, Inc.
P.O. Box 24737
West Palm Beach. FL 33416-4737
Plaintiff
ATTORNEY WOR PLAIKTIPW
: COURT OF COMMON PLEAS
: CIVIL DIVISION
: Cumberland County
: MORTGAGE FORECLOSURE
v.
Robert B. Manning
Sharon C. Manning
3 Sunset Drive
Mechanicsburg, PA 17055
Defendant (s)
: NO. 99-1854 civil
PRAECIPB POR JUDGMENT POR PAILURE TO
ANSWER A!lD ASSBSSKBNT 01' DAMAGBS
TO THE PROTHONOTARY:
Kindly enter judgment in favor of the Plaintiff and against the
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 per Complaint
From 3/10/99 to 5/27/99
Late charges per Complaint
From 3/15/99 to 5/27/99 @$58.52
Escrow payment per Complaint
From 4/1/99 to 5/27/99 @$150.08
$128,313.67
2,416.61
175.56
300.1.6
TOTAL
$131.206..00
I hereby certify that (1) the addresses of the Plaintiff and
Defendant are as shown above, and (2) that notice has been given in
accordance with Rule 237.1. a copy of which is attached hereto.
MARK J. UDREN & ASSOCIATES
~
Mark J. Udren, ESQUIRE
Attorney for Plaintiff
DAMAGES ARE HEREBY ASSESSED AS IND!
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HARK J. UDREN & ASSOCIATES
BY: Mark J. Udren, Esquire
ATTY I.D. NO. 04302
1040 N. KINGS BIGBWAY, SUITE 500
CHERRY HILL NJ 08034
ATTORNEY FOR PLAINTIFF
Lehman Capital, A Division of Lehman
Brothers Holdings, Inc.
P.O. Box 24737
West Pal~ 8aachL FL 33416-4737
daintiff
COURT OF COMMON PLEAS
CIVIL DIVISION
Cumberland County
v.
Robert B. Manning
Sharon C. Manning
3 Sunset Drive
Mechanicsburg, PA 17055
Defendant(s)
NO. 99-1854 civil
DATED: April 23, 1999
TO: Robert B. Manning
3 Sunset Drive
Mechanicsburg, PA 17055
IMPORTANT NOTICE
YOU ARE IN DEFAULT BECAUSE YOU HAVE FAILED TO ENTER A WRITTEN
APPEARANCE PERSONALLY OR BY ATTORNEY AND FILE IN WRITING WITH THE
COURT YOUR DEFENSES OR OBJECTIONS TO THE CLAIMS SET FORTH AGAINST
YOU. UNLESS YOU ACT WITHIN TEN DAYS FROM THE DATE OF THIS NOTICE
A JUDGMENT MAY BE ENTERED AGAINST YOU WITHOUT A HEARING AND YOU MAY
LOSE YOUR PROPERTY OR OTHER IMPORTANT RIGHTS. YOU SHOULD TAKE THIS
NOTICE TO A LAWYER AT ONCE. IF YOU DO NOT HAVE A LAWYER OR CANNOT
AFFORD ONE.! GO TO OR TELEPHONE THE FOLLOWING OFFICE TO FIND OUT
WHERE YOU ~AN GET LEGAL HELP.
LAWYER REFERRAL SERVICE
Court Administrator
Cumberland County Courthouse
1 Courthouse Square
Carlisle-l PA 170n-3387
71/-240-6200
NOTIFlCACION IMPORTANTE
USTED SE ENCUENTRA EN ESTADO DE RE8ELDIA POR NO HA8ER TOMADO LA
ACCION REQUIRIDA DE SU PARTE EN ESTE CASO. AL NO TOMAR LA ACCION
E~B~R~Bg~~lR~o~~A~N lMMJ~8E~fDRfn)E (~~kp~~1j,,1<&1:IfSJ:T~RTl~I~~~.f~N6
ESCUCHAR PREUBA ALGUNA, DICTAR SENTENCIA EN SU CONTRA, USTED PUEDE
&5~PHdb\EJlNE). 6N (~Jl6~~DgEr~~~8i'ATA1ttt<f~T~~T8~TED ~5B~I~tJf~~~d~56~
o SI NO TIENE DINERO SUFICIENTE PARA TAL SERVICIO, VAYA EN PERSONA
o LLAME POR TELEFONO A LA OFICINA, CUYA DIRECCION SE ENCUENTRA
ESCRITA ABAJO PARA AVERIGUAR DONDE SE PUEDE CONSEGUIR ASSISTENCIA
LEGAL.
SERVICIO DE REFERENCIA LEGAL
LAWYER REFERRAL SERVICE
Court Administrator
Cumberland County Courthouse
1 Courthouse Square
Carlisle-l PA 170n-3387
71/-240-6200
NOTICE: PURSUANT TO THE FAIR DEBT COLLECTION PRACTICES ACT, THIS
LAW FIRM IS DEEMED TO BE A DEBT COLLECTOR AND THIS IS AN ATTEMPT TO
COLLECT A DEBT. ANY INFORMATION OBTAINED WILL BE USED FOR THAT
PURPOSE.
HARK J. UDREN , ASSOCIATES
BY: Hark J. Udren, Esquire
ATTY 1.0. NO. 04302
1040 N. KINGS HIGHWAY, SUITE 500
CHERRY HILL NJ 09034
ATTORNEy FOR PLAINTIFF
Lehman Capital, A Division of Lehman
Brothers Holdings, Inc.
P.O. Box 24737
West Palm Beach( FL 33416-4737
'l.Jintiff
COURT OF COMMON PLEAS
CIVIL DIVISION
Cumberland County
v.
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I NO.
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99-1854 civil
Robert B. Manning
Sharon C. Manning
3 Sunset Drive
Mechanicsburg, PA 17055
Defendant (s)
DATED: April 23, 1999
TO: Sharon C. M~nning
3 Suns'i't Dr~ve
Mechan~csburg, PA 17055
IMPORTANT NOTICE
YOU ARE IN DEFAULT BECAUSE YOU HAVE FAILED TO ENTER A WRITTEN
APPEARANCE PERSONALLY OR BY ATTORNEY AND FILE IN WRITING WITH THE
COURT YOUR DEFENSES OR OBJECTIONS TO THE CLAIMS SET FORTH AGAINST
YOU. UNLESS YOU ACT WITHIN TEN DAYS FROM THE DATE OF THIS NOTICE
A JUDGMENT MAY BE ENTERED AGAINST YOU WITHOUT A HEARING AND YOU MAY
LOSE YOUR PROPERTY OR OTHER IMPORTANT RIGHTS. YOU SHOULD TAKE THIS
NOTICE TO A LAWYER AT ONCE. IF YOU DO NOT HAVE A LAWYER OR CANNOT
AFFORD ONE~ GO TO OR TELEPHONE THE FOLLOWING OFFICE TO FIND OUT
WHERE YOU cAN GET LEGAL HELP.
LAWYER REFERRAL SERVICE
Court Administrator
Cumberland County Courthouse
1 ~ourthouse Square
Carl~sle..} PA 17013 -3387
71/-240-6200
NOTIFICACION IMPORTANTE
USTED SE ENCUENTRA EN ESTADO DE RE8ELDIA POR NO HABER TOMADO LA
ACCION REOUIRIDA DE SU PARTE EN ESTE CCSO. AL NO TOMAR LA ACCION
DEBIDA DENTRO DE UN TERMINO DE DIEZ (10 DIAS DE ESTA NOTIFICACION6
EL TRIBUNAL PODRA SIN NECESIDAD DE CO PARARECER USTED EN CORTE
ESCUCHAR PREUBA ALGUNA, DICTAR SENTENCIA EN SU CONTRA, USTED PUEDE
~~~~HCA~IIE6l-Jri 0N 9Jfo'b~DgEf~~MgrATJI~~qrF~T~~TED g~B~IJ'rtl~G~6AA' ".
o SI NO TIENE DINERO SUFICIENTE PARA TAL SERVICI04 VAYA EN PERSON
o LLAME POR TELEFONO A LA OFICINA CUYA DIRECC10N SE ENCUENTRA
ESCRITA ABAJO PARA AVERIGUAR DONDE SE PUEDE CONSEGUIR ASSISTENCIA
LEGAL.
SERVICIO DE REFERENCIA LEGAL
LAWYER REFERRAL SERVICE
Court Administrator
Cumberland County Courthouse
1 ~ourthouse Square
Carl~sle..} PA 17013-3387
71/-240-6200
NOTICE: PURSUANT TO THE FAIR DEBT COLLECTION PRACTICES J\CT, THIS
LAW FIRM IS DEEMED TO BE A DEBT COLLECTOR AND THIS 'IS 'AN ATTEl.1PT TO
COLLECT A DEBT. ANY INFORMATION OBTAINED WILL BE USED FOR THAT
PURPOSE.
MAJUt J. UDIUl:N , ASSOCIATES ATTORNEY FOR PLAIKTII'P
BY: Mark J. Udren, Esquire
ATTY I.D. NO. 04302
1040 N. ~INGS HIGHWAY, SUITE 500
CHERRY HILL, NJ 08034
609-482-6900 .
Lehman Capital, ,", DiVision~ COURT Of COMMON Pl.;.iS
Lehman Brother~ Holdlngs, 'i~~. I CIVIL DIVISION
P.O. Box 24737 Cumberland County
West Palm Beach, FL 33416-4737
Plaintiff MORTGAGE FORECLOSURE
f
,
v.
Robert B. Manning
Sharon C. Manning
3 Sunset Dri ve
Mechanicsburg, PA 17055
. Defendant(s)
i
: NO. 99-1854 civil
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AFFIDAVIT OF NON-MILITARY SERVICE
,
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t
STATE OF
COUNTY OF
THE UNDERSIGNED being duly sworn, deposes and says that the
averments herein are based upon invest~gations made and records
maintained by us either as Plaintiff or as servicing agent of the
Plaintiff herein and that the above Defendant(s) are not in the
Military or Naval Service of the United States of America OT its
Allies as defined in the Soldiers and Sailors civil Relief Act of
1940, as amended, and that the age and last known residence and
employment of each Defendant are as follows:
Defendant: Robert B. Manning
Age: Over 18
Residence: As captioned above
Employment: Unknown
Defendant: Sharon C. Manning
Age: Over 18
Residence: As captioned abC"..e
F.mployment: Unknown
SS
Sworn to and subscribed
before me this day
of ,199 .
NO?M\~J.C fY\ fiY'/ aM
Name:
Title:
Company:
or!} ~uJO(.y;.,
J.lTTORNEY IN FACT
!.thfY'{)f\ Capt-ll b-l, 0- D I '//516() 01-
UhmtU1 Bros. /-I6ldl{)'r' -:r:rc,
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w,.~)'i "Vea".. '^'OtvM;----~..
../..-r.,j't,~':"::'" mISS:CN I .,"
.__.~!~"."", Bonae EXPIRES: Ju LC 6!,672S ,!
-~----._. ~ !hI1JNofifry;1t 17, ~{I(), .,1
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JC6RX J. UDRIH . ASSOCIATES
BY, Mark J. Udren, B.quire
ATTY I.D. NO. 04302
1040 X. EINGS BIGHWAY, SUITB 500
CBBRRY BILL, NJ 08034
609-482-6900
ATTORNEY FOR PLAINTIFF
Lehman Capital, A Division of
Lehman Brothers Holdings, Inc.
P.O. Box 24737
West Palm Beach, FL 33416-4737
. COURT OF COMMON PLEAS
: CIVIL DIVISION
: Cumberland County
.
: MORTGAGE FORECLOSURE
Plaintiff
v.
Robert B. Manning
Sharon c. Manning
3 Sunset Drive
Mechanicsburg, PA 17055
: NO. 99-1854 civil
Defendant(s)
TO: ROBERT B. MANNING
3 Sunset Drive
Mechanicsburg, PA 17055
NOTICE
Pursuant to Rule 236 of the Supreme Court of Pennsylvania, you are hereby
notified that a Judgment has been entered against you in the above
proceeding as indicated below.
Prothonotary
X Judgment by Default
Money Judgment
Judgment in Replevin
Judgment for Possession
Judgment on Award of Arbitration
Judgment on Verdict
Judgment on Court Findings
IF YOU HAVE ANY QUESTIONS CONCERNING THIS NOTICE PLEASE CALL:
ATTORNEY __....-_._.... _.._._Mark_.J....Udren.._Esquire ._.
At this telephone number:
.. _.609'"-482=.69.00__.__..~._..
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ATTORKBY rOR PLAIXTIrr
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MARX J. UDRIH . ASSOCIATES
BY, Kart J. Udren, E_quire
ATTT I.D. XO. 04302
10.0 X. EIHOS BIGHWAY, SUITE 500
~.Y BILL, XJ 08034
5Og-U2-SlIOO
Lehman Capital, A Division of
Lehman Brothers Holdings, Inc.
P.O. Box 24737
West Palm Beach, PL 33416-4737
Plaintiff
. COURT OP COMMON PLEAS
: CIVIL DIVISION
: Cumberland County
: MORTGAGE FORECLOSURE
v.
Robert B. Manning
Sharon C. Manning
3 Sunset Drive
Mechanicsburg, PA 17055
Defendant (s)
: NO. 99-1854 civil
AFFIDAVIT PURSUANT TO RULE 3129.1
Lehman Capital, A Division of Lehman Brothers Holdings, Inc., Plaintiff
in the above action, by its attorney, Mark J. Udren, ESQ., sets forth as
of the date the Praecipe for the Writ of Execution was filed the
following information concerning the real property located at: 3 Sunset
Drive, Mechanicsburg, PA 17055
1. Name and address of Owner(s) or reputed Owner(s) :
Name Address
ROBERT B. MANNING
3 SUNSET DRIVE, MECHANICSBURG, PA 17055
I .
;
I
,
SHARON C. MANNING
3 SUNSET DRIVE, MECHANICSBURG, PA 17055
2. Name and address of Defendant(s) in the judgment:
Name Address
SAME AS #1 ABOVE
3. Name and address of every judgment creditor whose judgment is a record
lien on the real property to be sold:
Name Address
NONE
4. Name and address of the last recorded holder of every mortgage of
record:
Name Address
Plaintiff herein.
See Caption above.
PNC BANK, NATIONAL ASSOC
AMERICAN GENERAL FINANCE,
2370 LIVERTY AVE., PITTSBURGH,
INC. 125 GATEWAY DRIVE, SUITE 109,
MECHANICSBURG, PA 17055
PA 15222
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MARX J. UDRIN . U.OCIATa8
BY, lCa:rk J. Od.ru, .squir.
ATTY I.D. XO. 04302
1040 X. EIXGS BIGBWAY, 8UITE 500
~ay BILL, XJ 01034
609-482-5900
Lehman Capital. A Division of
Lehman Brothers Holdings, Inc.
P.O. Box 24737
West Palm Beach. PL 33416-4737
Plaintiff
v.
Robert B. Manning
Sharon C. Manning
3 Sunset Drive
Mechanicsburg, PA 17055
Defendant(s)
ATTORKBY FOR PLAXXTIpW
. COURT OF COMMON PLEAS
: CIVIL DIVISION
: Cumberland County
.
: MORTGAGE FORECLOSURE
: NO. 99-1854 civil
BOllCR OJ!' BBBRIJ!'J!"B BAt.R OJ!' RIl!U. PII.ORBRn
TO: ROBERT B. MANNING
3 Sunset Drive
Mechanicsburg, PA 17055
SHARON C. MANNING
3 Sunset Drive
Mechanicsburg. PA 17055
Your house (real estate) at 3 Sunset Drive, Mechanicsburg, PA 17055 is
scheduled to be sold at the Sheriff's Sale on SEPTEMBER 01, 1999. at
10:00 A.M. in the COMMISSIONERS HEARING ROOM, 2ND FLOOR, COURTHOUSE,
CARLISLE, PA., to enforce the court judgment of $131,206.00, obtained by
Plaintiff above (the mortgagee) against you. If the sale is postponed,
the property will be relisted for the Next Available Sale.
HOTYl!R OF Olf}l'RR' R R:IGlITS
yon Mll.Y RR n.JUJR TO PRRVRN"T' TR'T~ ~HRRTF'P I g ~n.T,R
To prevent this Sheriff's Sale, you must take immIll.diAt.A lle~iODt
1. The sale will be cancelled if you pay to the mortgagee the back payment, late
charges, costs and reasonable attorney's fees. TO find 'out how much you must pay,
you may call: (~nql 4A~_~qnn
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.)
,
tOu MAt_BULL BB ABLE TO. SAW tOl1Jl. PROPDTY A!lD YOU OW, OTBDIlIGBT.
JrVD II'TJII. Bun!'!'! S SALB DOBS TUB PLACK.
1. If the Sheriff'. Sale i. not atopped, your property will be .old to the
high..t bidder. You may find out the price bid by calling 609-482-6900.
2. You may be able to petition the Court to aet aaide the aale if the bid price
wa. gro..ly inadequate compared to the value of your property.
3. The .ale will go through only if the buyer paye the Sheriff tha full amount
due in the aale. To find out if thia haa happened, you may call 609-482-6900.
4. It the amount due from the Buyer ia not paid to the Sheritt, you will remain
the owner of the property aa if the aa1e never happened.
5. You have the right to remain in the property until the full amount due i.
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 entitlecl to a share of the money which was paid for your houae.
A achedule of distribution of the money bid for your house will be filed by the Sheriff
within 30 days after the sale. This schedule will state who will be receiving that
money. The money will be paid out in accordance with this schedule unless exceptiona
(reasona why the proposed distribution is wrong) are filed with the Sheriff within ten
(10) days after Schedule of 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.
rOll SIIOllLll TUB THIS PAPBll TO rOllll LAWYllll AT OHCB. IP rOll DO HOT IlAVIl A LAlf!BIl 011
CAlllfOT UPOIID Ollll, GO TO OR TllLI!PlIOIlll TBB OPPICII LISTBD BIlLOW TO PIIID OllT llIIIlIlB rOll CAJr
allT LBGAL IIllLP.
LAlfYIIll llBPIlllllAL SBllVICB
Court Administrator
Cumberland County Courthouse
1 Courthouse Square
Carlisle, PA ~7013-3387
717-240-6200
ASSOCIATION DE LICENCIDADOS DE FILADELFIA
Court Administrator
Cumberland County Courthouse
1 Courthouse Square
CarliSle, PA 17013-3387
717-240-6200
. ALL THAT CERTAIN TRACT OF LAND SITUATE IN THE TOWNSHIP OF SILVER
SPRING, COUNTY OF CUMBERLAND AND STATE OF PENNSYLVANIA, BOUNDED AND
DESCRIBED AS FOLLOWS TO WIT:
BEGINNING AT A POINT ON THE SOUTHWEST SIDE OF A PUBLIC ROAD KNOWN
AS T-597, AT THE CORNER OF LAND NOW OR LATE OF BARBARA HERSH;
THENCE ALONG THE SOUTHWEST SIDE OF SAID PUBLIC ROAD, SOUTH 41
DEGREES 46 MINUTES EAST, ONE HUNDRED NINETY-FOUR AND ONE-TENTH
(194 .1) FEET TO A POINT; THENCE ALONG THE SAME AND ALONG THE
SOUTHWEST SIDE OF PUBLIC ROAD KNOWN AS T-596, SOUTH 29 DEGREES 5
MINUTES 30 SECONDS EAST, EIGHTY-ONE AND FORTY-FOUR HUNDREDTHS
(81.44) FEET TO A POINT; THENCE ON A CURVE TO THE RIGHT, HAVING A
RADIUS OF FIFTY (50) FEET, AN ARC,DISTANCE OF SEVENTY-TWO AND THREE
HUNDRED SIXTY-NINE THOUSANDTHS (72.369) FEET TO A POINT; THENCE
ALONG LAND OF GEORGE W. WALKER 'AND MARY ALICE WALKER, HIS WIFE
SOUTH 53 DEGREES 50 MINUTES 15 SECONDS WEST, EIGHTY-ONE AND TWENTY-
ONE AND TWENTY-NINE HUNDREDTHS ( 81 . 29) FEET TO A POINT; THENCE
ALONG LAND OF SAME, ON A CURVE TO THE RIGHT, HAVING A RADIUS OF ONE
HUNDRED SEVENTY-NINE AND EIGHTEEN HUNDREDTHS (179.18) FEET, AN ARC
DISTANCE OF TWO HUNDRED FORTY-EIGHT AND EIGHTY-SEVEN HUNDREDTHS
(248.87) FEET TO A POINT; THENCE ALONG LAND NOW OR LATE OF MAX L.
MILLER AND JOYCE R. MILLER, HIS WIFE, NORTH 63 DEGREES 27 MINUTES
EAST, ONE HUNDRED SIXTY-EIGHT AND NINE HUNDREDTHS (168.09) FEET TO
A POINT; THENCE ALONG LAND OF SAME, NORTH 22 DEGREES 13 MINUTES
WEST, TWO HUNDRED FIFTY-EIGHT AND ONE TENTH (258.1) FEET TO A
POINT; THENCE ALONG LAND NOW OR LATE OF BARBARA HERSH, FIRST
MENTIONED ABOVE, DUE EAST, EIGHTY-SEVEN AND FOUR HUNDREDTHS (87.04)
FEET TO A POINT ON THE SOUTHWEST SIDE OF PUBLIC ROAD KNOWN AS T-
597, THE PLACE OF BEGINNING.
BEING LOT NO. 32, AS SHOWN IN THE SUB-DIVISION PLAN OF WHITE BIRCH
FARMS DEVELOPMENT, INDICATED AS TRACT NO.1, LOT NO. 32, AS
RECORDED IN THE RECORDER'S OFFICE IN AND FOR CUMBERLAND COUNTY,
PENNSYLVANIA, IN PLAN BOOK 24, PAGE 114.
HAVING THEREON ERECTED A SINGLE, BRICK RANCH TYPE DWELLING WITH TWO
CAR GARAGE.
TAX PARCEL 38-14-0847-057
TITLE TO SAID PREMISES IS VESTED IN ROBERT B. MANNING AND SHARON C.
MANNING, HIS WIFE, AS TENANTS BY THE ENTIRETIES, BY DEED FROM GENO
A. FRANCAVILLA AND DOLLY M. FRANCAVILLA, HIS WIFE DATED 5/9/1996
AND RECORDED 5/9/1996 IN DEED BOOK 138 PAGE 1133.
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Lehman Capital, A Division of
Lehman Brothers Holdings, Inc.
-vs-
Robert D. Manning Sharon C. Manning
In the Court of Common Pleas of
Cumberland County, Pennsylvania
No. 99-1854 Civil Term
R. Thomas Kline, Sheriff who being duly sworn according to law,
says this writ is returned STAYED.
Sheriff's Costs:
Docketing
Law Library
County
Surcharge
Postpone Sale
Levy
Poundage
Share of Bills
30.00
.50
1. 00
24.00
20.00
15.00
to 81
21. 88
5114.19
Advance costs
Sheriff's Costs
1000.00
E4.19
$ 885-~; refund to atty
. 7-29-99
So answers: ~ ~
r-" ~~-r~~
R. Thomas Kline, Sheriff
Bygi;h4LM~
Real Estate Deputy
Sworn and Subscribed To Before Me
This IJ'/i!::- Day of rJ'r
1999, A.D. ~'t" 12 ~,~
pr t onotary
,. ..{C>
CiL :l ,L/'I?
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.
. '
"
MARX J. UDRBN . ABSOCIATBS
BY' _ark J. Udren, ..quire
ATTT I.D. XO. 04302
1040 X. EXHOS BIQBWAY, SUITB 500
rnnJIRY BILL, JrJ 08034
609-482-6900
Lehman Capital, A Division of
Lehman Brothers HOldings, Inc.
P.O. Box 24737
West Palm Beach, FL 33416-4737
Plaintiff
. COURT OF COMMON PLEAS
: CIVIL DIVISION
: CUmberland County
: MORTGAGE FORECLOSURE
ATTOIUfBY FOR l'LAIKTUW
v.
Robert B. Manning
Sharon C. Manning
3 Sunset Drive
Mechanicsburg, PA 17055
Defendant(s)
:NO. 99-1854 civil
AFFIDAVIT PURSUANT TO RULE 3129.1
Lehman Capital, A Division of Lehman Brothers Holdings, Inc., Plaintiff
in the above action, by its attorney, Mark J. Udren, ESQ., sets forth as
of the date the Praecipe for the Writ of Execution was filed the
following information concerning the real property located at: 3 Sunset
Drive, Mechanicsburg, PA 17055
1. Name and address of Owner(s) or reputed Owner(s) :
Name Address
ROBERT B. MANNING
3 SUNSET DRIVE, MECHANICSBURG, PA 17055
SHARON C. MANNING
3 SUNSET DRIVE, MECHANICSBURG, PA 17055
2. Name and address of Defendant(s) in the judgment:
Name Address
SAME AS #1 ABOVE
3. Name and address of every judgment creditor whose judgment is a record
lien on the real property to be sold:
Name Address
NONE
4. Name and address of the last recorded holder of every mortgage of
record:
Name Address
Plaintiff herein.
See Caption above.
PNC BANK, NATIONAL ASSOC
AMERICAN GENERAL FINANCE,
2370 LIVERTY AVE., PITTSBURGH, PA l5222
INC. 125 GATEWAY DRIVE, SUITE 109,
MECHANICSBURG, PA 17055
. .
r
JIAIlJt J. UDIlBlf . ASSOCIATES
BY' Ikrk J. Udren, Esquire
ATTY I.D. RO. 04302
1040 R. EI_GS BIGBKAY, SUITE 500
CBBRRY BILL, _J 08034
609-482-6900
Lehman Capital, A Division of
Lehman Brothers Holdings, Inc.
P.O. Box 24737
West Palm Beach, FL 33416-4737
ATTORlfBY FOR PLADlTIn
. COURT OF COMMON PLEAS
: CIVIL DIVISION
: CUmberland County
: MORTGAGE FORECLOSURE
Plaintiff
v.
Robert B. Manning
Sharon C. Manning
3 Sunset Drive
Mechanicsburg, PA 17055
:NO. 99-1854 civil
Defendant (a)
HOTleR OP SBBRIpp'g SALK OP R~~T. PROP~
TO: ROBERT B. MANNING
3 Sunset Drive
Mechanicsburg, PA 17055
SHARON C. MANNING
3 Sunset Drive
Mechanicsburg, PA 17055
Your house (real estate) at 3 Sunset Drive, Mechanicsburg, PA 17055 is
scheduled to be sold at the Sheriff's Sale on SEPTEMBER 01, 1999, at
10: 00 A.M. in the COMMISSIONERS HEARING ROOM, 2ND FLOOR, COURTHOUSE,
CARLISLE, PA., to enforce the court judgment of $131,206.00, obtained by
Plaintiff above (the mortgagee) against you. If the sale is postponed,
the property will be relisted for the Next Available Sale.
XnTYCR OP O~RIS RyaRTS
yon Mnv 'R.R ~'RTJR TO 'PRRV'RNT THTS SJ..tF.RTFFI9 ~nT.E
To prevent this Sheriff's Sale, you must take ~MM.diA~A A~~ionl
1. The sale will be cancelled if you pay to the mortgagee the back payment, late
charges, costs and reasonable attorney's fees. To find'out how much you must pay,
you may call: (~nql 4R2_~qnn
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 Baoner you contact one, the
more chance you will have of stopping the sale. (See notice on page two on how
to obtain an attorney.)
,
..
XQtLJIA]CB.TILL 81 AJlLJrTO. SAVBrOUR, PJlOPIRTY AIm .YOU.-IlAVI.OTBID IIQBTS
BYBlLI"'-DLSBlRIJ'J"S SAlol DOIB..TAQ.PLACZ.
1. It the Sheritt'. Sale i. not .topped, your property will be lold to the
highest bidder. You may tind out the price bid by calling 609-482-6900.
2. You may be able to petition the Court to set ..ide the sale it the bid price
was grossly inadequate compared to the value ot your property.
3. The sale will go through only 1t ths buyer pays the Sheritt the tull amount
duo in the .ale. To find out if this has happened, you may call 609-482-6900.
4. It the amount due from the Buyer is not paid to the SheriU, you will remain
the owner of the property as it the sale never happened.
5. You have the right to remain in the property until the tull amoWlt due i.
paid to the SheriU and the SheriU 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 ot the money which was paid for your house.
A schedule of distribution of the money bid for your house will be tiled by the Sheriff
within 30 days after 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 Schedule ot 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 SIIOtILD TUB TIIIS PAPn TO YOn LAlrYBR AT OHCB. II' YOU DO HOT IlAVB A LAIIIllR OR
CAHlI'OT APFORD Ollll. GO TO OR T!lLBPIIOIlll TIIB OPPICB LISTED BilLOW TO PI1ID OUT WIIBIlB YOU CAlf
QBT LGAL III!LP.
LAwrn RBPIlRRAL SnVICB
Court Administrator
Cumberland County Courthouse
1 Courthouse Square
Carlisle, PA 17013-3387
717-240-6200
ASSOCIATION DE LICENCIDADOS DE FILADELFIA
Court Administrator
Cumberland County Courthouse
1 Courthouse square
Carlisle, PA 170~3-3387
717-240-6200
;
t
.. ALL THAT CERTAIN TRACT OF LAND SITUATE IN THE TOWNSHIP OF SILVER
SPRING, COUNTY OF CUMBERLAND AND STA'I'E OF PENNSYLVANIA, BOUNDED AND
DESCRIBED AS FOLLOWS TO WIT:
BEGINNING AT A POINT ON THE SOUTHWEST SIDE OF A PUBLIC ROAD KNOWN
AS T-597, AT THE CORNER OF LAND NOW OR LATE OF BARBARA HERSH;
THENCE ALONG THE SOUTHWEST SIDE OF SAID PUBLIC ROAD, SOUTH 41
DEGREES 46 MINUTES EAST, ONE HUNDRED NINETY-FOUR AND ONE-TENTH
(194 .1) FEET TO A POINT; THENCE ALONG THE SAME AND ALONG THE
SOUTHWEST SIDE OF PUBLIC ROAD KNOWN AS T-596, SOUTH 29 DEGREES 5
MINUTES 30 SECONDS EAST, EIGHTY-ONE AND FORTY-FOUR HUNDREDTHS
(81.44) FEET TO A POINT; THENCE ON A CURVE TO THE RIGHT, HAVING A
RADIUS OF FIFTY (50) FEET, AN ARC DISTANCE OF SEVENTY-TWO AND THREE
HUNDRED SIXTY-NINE THOUSANDTHS (72.369) FEET TO A POINT; THENCE
ALONG LAND OF GEORGE W. WALKER 'AND MARY ALICE WALKER, HIS WIFE
SOUTH 53 DEGREES 50 MINUTES 15 SECONDS WEST, EIGHTY-ONE AND TWENTY-
ONE AND TWENTY-NINE HUNDREDTHS (81.29) FEET TO A POINT; THENCE
ALONG LAND OF SAME, ON A CURVE TO THE RIGHT, HAVING A RADIUS OF ONE
HUNDRED SEVENTY-NINE AND EIGHTEEN HUNDREDTHS (179.18) FEET, AN ARC
DISTANCE OF TWO HUNDRED FORTY-EIGHT AND EIGHTY-SEVEN HUNDREDTHS
(248.87) FEET TO A POINT; THENCE ALONG LAND NOW OR LATE OF MAX L.
MILLER AND JOYCE R. MILLER, HIS WIFE, NORTH 63 DEGREES 27 MINUTES
EAST, ONE HUNDRED SIXTY-EIGHT AND NINE HUNDREDTHS (168.09) FEET TO
A POINT; THENCE ALONG LAND OF SAME, NORTH 22 DEGREES 13 MINUTES
WEST, TWO HUNDRED FIFTY-EIGHT AND ONE TENTH (258.1) FEET TO A
POINT; THENCE ALONG LAND NOW OR LATE OF BARBARA HERSH, FIRST
MENTIONED ABOVE, DUE EAST, EIGHTY-SEVEN AND FOUR HUNDREDTHS (87.04)
FEET TO A POINT ON THE SOUTHWEST SIDE OF PUBLIC ROAD KNOWN AS T-
597, THE PLACE OF BEGINNING.
I
,
,
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,.
BEING LOT NO. 32, AS SHOWN IN THE SUB-DIVISION PLAN OF WHITE BIRCH
FARMS DEVELOPMENT, INDICATED AS TRACT NO.1, LOT NO. 32, AS
RECORDED IN THE RECORDER'S OFFICE IN AND FOR CUMBERLAND COUNTY,
PENNSYLVANIA, IN PLAN BOOK 24, PAGE 114.
HAVING THEREON ERECTED A SINGLE, BRICK RANCH TYPE DWELLING WITH TWO
CAR GARAGE.
TAX PARCEL 38-14-0847-057
TITLE TO SAID PREMISES IS VESTED IN ROBERT B. MANNING AND SHARON C.
MANNING, HIS WIFE, AS TENANTS BY THE ENTIRETIES, BY DEED FROM GENO
A. FRANCAVILLA AND DOLLY M. FRANCAVILLA, HIS WIFE DATED 5/9/1996
AND RECORDED 5/9/1996 IN DEED BOOK 138 PAGE 1133.
. .
Rt~l ES1~lE S~lE No ~5'
Q~~ t J 999 the sharif! levied upon the defendant~
Inlol'est in the real property siiu8ted in
~
Cumberland County, Pa., kn("'ill and n:J',;berod as: -51.~_'_.J'1.L2'._< .
/ff~Ib~f2~ and more iuli';' jr,~cr:l:;Gd on Ext:ibit """ iilea w;lf1
:g::;;~;;' IOC"~~~
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MARX J. ODRBN ~ ASSOCIATSS
BY' Mark J. Udren, S8quire
ATTY I.D. NO. 04302
1040 N. KXNGS HIGHWAY, SUITB 500
CHSRRY HILL, NJ 08034
609-482-6900
Lehman Capital, A Division of
Lehman Brothers Holdings, Inc.
P.O. Box 24737
West Palm Beach, FL 33416-4737
ATTORNEY POR PLAINTIPP
. COURT OF COMMON PLEAS
: CIVIL DIVISION
: Cumberland County
: MORTGAGE FORECLOSURE
Plaintiff
v.
Robert B. Manning
Sharon C. Manning
3 Sunset Drive
Mechanicsburg, PA 17055
: NO. 99-1854 civil
Defendant(s)
AFFIDAVIT PURSUANT TO RULE 3129.1
Lehman Capital, A Division of Lehman Brothers Holdings, Inc., Plaintiff
in the above action, by its attorney, Mark J. Udren, ESQ., sets forth as
of the date the praecipe for the ~lrit of Execution was filed the
following information concerning the real property located at: 3 Sunset
Drive, Mechanicsburg, PA 17055
1. Name and address of Owner(s) or reputed Owner(s) :
Name Address
ROBERT B. MANNING
3 SUNSET DRIVE, MECHANICSBURG, PA 17055
SHARON C. MANNING
3 SUNSET DRIVE, MECHANICSBURG, PA 17055
2. Name and address of Defendant(s) in the judgment:
Name Address
SAME AS # 1 ABOVE
3. Name and address of every judgment creditor whose judgment is a record
lien on the real property to be sold:
Name Address
NONE
4. Name and address of the last recorded holder of every mortgage of
record:
Name Address
Plaintiff herein.
See Caption above.
PNC BANK, NATIONAL ASSOC.
2370 LIBERTY AVENUE, PITTSBURGH, PA 15222
..
AMERICAN GENERAL FINANCE INC 1~5 GATEWAY DR, STE 109, MECHANICSBURO, PA
17055
PNC BANK, NA 21ST FL, 620 LIBERTY AVE., PITTSBURGH, PA
ATTN: LEGAL DEPT. 15222
5. Name and address of every other person who has any record lien on the
property:
Name Address
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 Address
REAL ESTATE TAX DEPT.
1 COURTOUSE SQUARE, CARLISLE, PA 17013
Domestic Relations Section
13 N. HANOVER ST., CARLISLE, PA 17013
Commonwealth of PA,
Department of Revenue
Bureau of Compliance, Dept. 280946
Harrisburg, PA 17128-0946
7. Name and address of every
knowledge who has any interest
the sale:
Name
other person of whom the plaintiff has
in the property which may be affected by
Address
Tenants(Occupants
3 Sunset Drive, Mechanicsburg, PA 17055
I verify that the statements made in this affidavit are true and correct
to the best of my personal knowledge or information and belief. I
understand that false statements herein are made subject to the penalties
of 18 Pa.C.S. sec. 4904 relating to unsworn falsification to authorities.
MARK J. UDREN & ASSOCIATES
DATED: February 15, 2000
Mar J. Udren, ESQ.
At rney for Plaintiff
,~
,.
YOU HAY STILL 8B ABLE TO SAVE YOUR PROPBRTY AND YOU HAVB OTHER RIGHTS
BVBN IP TBB SHERIPI"S SALB DOBS TAKB PLACB.
1. If the Sheri tt' s Sale is not etopped, your property will be sold to the
highest bidder. You may find out the price bid by calling 609-482-6900.
2. You may be able to petition the Court to Det aside the .ale if the bid price
was groDoly inadequate compared to the value of your property.
3. The Dale will go through only if the buyer pay. the Sheriff the full amount
due in the sale. To find out if this has happened, you may call 609-482-6900.
4. If the amount due from the Buyer io not paid to the Sheriff, you will remain
the owner of the property as if the Dale never happened.
5. You have the right to remain in the property until the full amount due is
paid to the Sheriff and the Sheriff gives a deed to the buyer. At that time. the buyer
may bring legal proceedings to evict you.
6. You may be entitled to a share of the money which was paid for your house.
A schedule of distribution of the money bid for your house will be filed by the Sheriff
within 30 days after 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 withir ten
(~O) days after Schedule of 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 SBOtl'LD TAXB THIS PAPBR TO YOtlR LAWYER AT ORCB. II' YOU DO NOT HAW A LAWYBR OR
CANNOT AJ'PORD ONS, GO TO OR TBLBPHONS THB OPPICB LISTED BBLOW TO rIND OOT WIIIlRll YOU CAN
GBT LEGAL BBLP.
LAWYBR RBrBRllAL SBRVICB
cumberland County Bar Association
2 Liberty Avenue
Carlisle. PA 170~3-33B7
7~7-249-3~66 or ~-BOO.990.910B
ASSOCIATION DE LICENCIDADOS DE FILADELFIA
Cumberland County Bar Association
2 Liberty Avenue
Carlisle. PA 170~3.33B7
7~7.249-3~66 or ~-BOO-990-9~08
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ALL TIlAT CERTAIN TRACT OF LAND SITUATE IN THE TOWNSHIP OF SILVER
SPRING, COUNTY OF CUMBERLAND AND STATE OF PENNSYLVANIA, BOUNDED AND
DESCRIBED AS FOLLOWS TO WIT:
BEGINNING AT A POINT ON THE SOUTHWEST SIDE OF A PUBLIC ROAD KNOWN
AS T-S97, AT THE CORNER OF LAND NOW OR LATE OF BARBARA HERSH;
THENCE ALONG THE SOUTHWEST SIDE OF SAID PUBLIC ROAD, SOUTH 41
DEGREES 46 MINUTES EAST, qNE HUNDRED NINETY-FOUR AND ONE-TENTH
(194.1) FEET TO A POINT; THENCE ALONG THE SAME AND ALONG TIlE
SOUTHWEST SIDE OF PUBLIC ROAD KNOWN AS T-596, SOUTH 29 DEGREES 5
MINUTES 30 SECONDS EAST, EIGHTY:,ONE AND FORTY - FOUR HUNDREDTHS
(81.44) FEET TO A POINT; THENCE ON A CURVE TO THE RIGHT, HAVING A
RADIOS OF FIFTY (50) FEET, AN ARC DISTANCE OF SEVENTY-TWO AND THREE
HUNDRED SIXTY-NINE THOOSANDTHS (72.369) FEET TO A POINT; THENCE
ALONG LAND OF GEORGE W. WALKER I AND MARY ALICE WALKER, HIS WIFE
SOUTH 53 DEGREES 50 MINUTES 15 SECONDS WEST. EIGHTY-ONE AND TWENTY-
ONE AND TWENTY-NINE HUNDREDTHS (81.29) FEET TO A POINT; THENCE
ALONG LAND OF SAME, ON A CURVE TO THE RIGHT, HAVING A RADIUS OF ONE
HUNDRED SEVENTY-NINE AND EIGHTEEN HUNDREDTHS (179.18) FEET, AN ARC
,DISTANCE OP TWO HUNDRED FORTY-EIGHT AND EIGHTY-SEVEN HUNDREDTHS
(248.87) FEET TO A POINT; THENCE ALONG LAND NOW OR LATE OF MAX L.
MILLER AND JOYCE R. MILLER, HIS WIFE, NORTH 63 DEGREES 27 MINUTES
EAST, ONE HUNDRED SIXTY-EIGHT AND NINE HUNDREDTHS (168.09) FEET TO
A POINT; THENCE ALONG LAND OF SAME, NORTH 22 DEGREES 13 MINUTES
WEST, TWO HUNDRED FIFTY-EIGHT AND ONE TENTH (258.1) FEET TO A
POINT; THENCE ALONG LAND NOW OR LATE OF BARBARA HERSH, FIRST
MENTIONED ABOVE, DUE EAST, EIGHTY-SEVEN AND FOUR HUNDREDTHS (87.04)
FEET TO A POINT ON THE SOUTHWEST SIDE OF PUBLIC ROAD KNOWN AS T-
597, THE PLACE OF BEGINNING.
,
BEING LOT NO. 32, AS SHOWN IN THE SUB-DIVISION PLAN OF WHITE BIRCH
FARMS DEVELOPMENT, INDICATED AS TRACT NO.1, LOT NO. 32, AS
RECORDED IN THE RECORDER'S OFFICE IN AND FOR CUMBE~ COUNTY,
PENNSYLVANIA, IN PLAN BOOK 24, PAGE 114.
HAVING THEREON ERECTED A SINGLE, BRICK RANCH TYPE DWELLING WITH TWO
CAR GARAGE.
TAX PARCEL 38-14-0847-057
TITLE TO SAID PREMISES IS VESTED IN ROBERT B. MANNING AND SHARON C.
MANNING, HIS WIFE, AS TENANTS BX THE ENTIRETIES, BY DEED FROM GENO
A. FRANCAVILLA AND DOLLY M. FRANCAVILLA, HIS WIFE DATED 5/9/1996
AND RECORDED 5/9/1996 IN DEED BOOK 138 PAGE 1133.
.
,
MARx J. ODRBN & ASSOCIATBS
BY, Mark J. Udren, Bequire
ATTY I.D. NO. 04302
1040 N. KINGS HIGHWAY, SUITE 500
CHERRY HILL, NJ 08034
609-482-6900
Lehman Capital, A Division of
Lehman Brothers HOldings, Inc.
P.O. Box 24737
West Palm Beach, FL 33416-4737
ATTORNEY POR PLAINTIPP
Plaintiff
. COURT OF COMMON PLEAS
: CIVIL DIVISION
: Cumberland County
: MORTGAGE FORECLOSURE
v.
Robert B. Manning
Sharon C. Manning
3 Sunset Drive
Mechanicsburg, PA 17055
Defendant(s)
: NO. 99-1854 civil
NOTICB-O~SHERIPF~S_SALB-O~RBAL-PRoeERTY
TO: ROBERT B. MANNING
3 Sunset Drive
Mechanicsburg, PA 17055
SHARON C. MANNING
3 Sunset Drive
Mechanicsburg, PA 17055
Your house (real estate) at 3 Sunset Drive, Mechanicsburg, PA 17055 is
scheduled to be sold at the Sheriff's Sale on June 7, 2000, at 10:00 A.M.
in the COMMISSIONERS HEARING ROOM, 2ND FLOOR, COURTHOUSE, CARLISLE, PA,
to enforce the court jUdgment of $131,206.00, obtained by Plaintiff above
(the mortgagee) against you. If the sale is postponed, the property will
be relisted for the Next Available Sale. ~
NQTI.CB-O.L.OWNER!.S-RIGHTS
YOU MAY-BE-ABLE Tn P'~E.'lENL.:IHIS SHF.PIFF'S !iALE
To prevent this Sheriff's Sale. you must take i:mnedi&t.lLAc:.tion,.
1. The sale will be cancelled if you pay to the mortgagee the back payment. late
charges, costs and reasonable attorney's fees. 'fo find out how much you must pay,
you may call: (6001 4a~~~
2. You may be able to stop the sale by tiling a petition asking the COurt to strike,
or open the jUdgment, if the judgme~t 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.)
..
.
YOU .HAY STILL BK ABLB TO SAVE YOUR PROPKllTY AND YOU HAVP: OTHKRRIGHTS
BVRNIY THB SHBRIFP'S SALE DOES TAKE.PLACK.
1. It the Sheritf's Sale is not stopped. YOllr property will be sold to the
highest bidder. You may find out the price bid by calling 609-482-6900.
2. You may be able to petition the Court to set uide the 84le it 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 609-482-6900.
4. It the amount due from the Buyer is not paid to the Sheritf. you will remain
the owner of the property as if the sale never happened.
S. You have the right to remain in the property until the full amount due is
paid to the Sherift and the Sheritf 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 after 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 atter Schedule of 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 SllOtlLJ) TAXIl TlIIS PAPIlR TO YOllR LAWYIlR AT ONCIl. IP YOU DO NOT llAVll A LAWYIlR OR
CANNOT APPORD Olll!. GO TO OR TIlLIlPllOIll! TIlE OPFICE LISTED BIlLOW TO FIND OllT IillllRI! YOU CAN
GIlT LIlGAL llIlLP.
LAWYIlR RllPIlRRAL SIlRVICB
Cumberland County Bar ASSOCiation
2 Liberty Avenue
CarliSle. PA 17013-3387
717-249-3166 or 1-800-990-9108
ASSOCIATION DE LICENCIDADOS DE FILADELFIA
Cumberland County Bar Association
2 Liberty Avenue
Carlisle. PA 17013-3387 ..
717-249-3166 or 1-800-990-9108
.:
AL~ THAT CERTAIN TRACT OF LAND SITUATE IN THE TOWNSHIP OF SILVER
SPRING, COUNTY OF CCMBER.I.AND AND STATE OF PENNSYl.VANIA, BOUNDED AND
DESCRIBED AS FOLLOWS TO WIT:
BEGINNING AT A POINT ON THE SOUTHWEST SIDE OF A PUBLIC ROAD KNOWN
AS T-597, AT THE CORNER OF LAND NOW OR LATE OF BARBARA HERSH;
THENCE ALONG THE SOUTHWEST SIDE OF SAID PUBLIC ROAD, SOOTH 41
DEGREES 46 MINUTES EAST, qNE HUNDRED NINETY-FOUR AND ONE-TENTH
(194.1) FEET TO A POINT; THENCE ALONG THE SAME AND ALONG THE
SOUTHWEST SIDE OF PUBLIC ROAD KNOWN AS T-596, SOUTH 29 DEGREES 5
MINUTES 30 SECONDS EAST, EIGHTY:;,ONE AND FORTY-FOUR IroNDREDTHS
(81.44) FEET TO A POINT; THENCE ON A CURVE TO THE RIGHT, HAVING A
RADIUS OF FIFTY (50) FEET, AN ARC DISTANCE OF SEVENTY-TWO AND THREE
HUNDRED SIXTY-NINE THOUSANDTHSln.369) FEET TO A POINT; THENCE
ALONG LAND OF GEORGE W. WALKER lAND MARY ALICE WALKER, HIS WIFE
SOOTH 53 DEGREES 50 MINUTES 15 SECONDS WEST, EIGHTY-ONE AND TWENTY-
ONE AND TWENTY-NINE HUNDREDTHS (81. 29) FEET TO A POINT; THENCE
ALONG LAND OF SAME, ON A CURVE TO THE RIGHT, HAVING A RADIUS OF ONE
HUNDRED SEVENTY-NINE AND EIGHTEEN HUNDREDTHS (179.18) FEET, AN ARC
,DISTANCE 01' TWO HUNDRED FORTY-EIGHT AND EIGHTY-SEVEN IroNDREDTHS
(248.87) FEET TO A POINT; THENCE ALONG LAND NOW OR LATE OF MAX L.
MILLER AND JOYCE R. MILLER, HIS WIFE, NORTH 63 DEGREES 27 MINUTES
EAST, ONE HUNDRED SIXTY-EIGHT AND NINE HUNDREDTHS (168.09) FEET TO
A POINT; THENCE ALONG LAND OF SAME, NORTH 22 DEGREES 13 MINUTES
WEST, TWO HUNDRED FIFTY-EIGHT AND ONE TENTH (258.1) FEET TO A
POINT; THENCE ALONG LAND NOW OR LATE OF BARBARA HERSH, FIRST
MENTIONED ABOVE, DUE EAST, EIGHTY-SEVEN AND FOUR HUNDREDTHS (87.04)
FEET TO A POINT ON THE SOUTHWEST SIDE OF PUBLIC ROAD KNOWN AS T-
597, THE PLACE OF BEGINNING.
BEING LOT NO. 32: AS SHOWN IN THE SUB-DIVISION PLAN OF WHITE BIRCH
FARMS DEVELOPMENT, INDICATED AS TRACT NO.1, LOT NO. 32, AS
RECORDED IN THE RECORDER'S OFFICE IN AND FOR CUMBERLAND COUNTY,
. '"
PENNSYLVANIA, IN PLAN BOOK 24, PAGE 114.
HAVING THEREON ERECTED A SINGLE, BRICK RANCH TYPE DWELLING WITH TWO
CAR GARAGE.
TAX PARCEL 38-14-0847-057
TITLE TO SAID PREMISES IS VESTED IN ROBERT B. MANNING AND SHARON C.
MANNING, HIS WIFE, AS TENANTS B~ THE ENTIRETIES, BY DEED FROM GENO
A. FRANCAVILLA AND DOLLY M. FRANCAVILLA, HIS WIFE DATED 5(9/1996
AND RECORDED 5/9/1996 IN DEED BOOK 138 PAGE 1133.
WRIT OF EXECUTION and/or AlTACHMENT
COMMONWEALTH OF PENNSYLVANIA)
COUNTY OF CUMBERLAND)
NO, 99-1854 CIVIL to' Term
CIVIL ACTION. LAW -
TO THE SHERIFF OF
Cwnber1and
COUNTY:
To satisfy the debt. Inlerest andcosls due _ LehrMn Capital, A Division of LehrMn 80rthers
Holding, Inc. PLAINTIFF(S)
trom Robert B. M,,1nning and Sharon C. Manning, 3 Sunnct Drive, Mechanicsburg, PA 17055
DEFENDANT(S)
(1) You are direcled to levy upon Ihe propeny oflhe defendant(s) and to sell See Leqal Description
(2) You are also direcled 10 allach the property oflhe defendant(s) not levied upon in the possession of _
GARNISHEE(S) as follows:
and to nolny the garnishee(s) Ihal: (a) an allachmenl has been issued: (b) the garnishee(s) Is/are enjoined from paying any
debt to or for the account of Ihe defendant(s) and Irom delivering any property of the defendanl(s) or otherwise disposing
thereof;
(3) If property of the defendant(s) not levied upon an subjecl to allachment is found in the possession of anyone other
than a named garnishee, you are directedlo notify him/herthal he/she has been added as agarnisheeand is enjoined as above
stated,
Amount Due $' " ,?n~ nn
from 5/28/99 to 6/7/00 per
Interest diem @)Q.SS ~1l.S2S 66
AIlY'S Comm %
Ally Paid S~44. 89
Plaintiff Paid
L.L.
Due Prolhy
Other Costs
$' nn
Date:
February 23. 2000
Curtis R. Lonq
Prothonotary, Civil Division
~n..y. I . P ~ 7?m"1",v-
r
Deputy
~
REQUESTING PARTY:
Name Mark J. Udren, Esq.
Address: 1040 N. Kinqs Hiqhwav, Suite 500
Cherry Hill. NJ 08034
Morney for: Plaintiff
Telephone: 609-482-6900
Supreme Court 10 No, 04302
IN '!IS UN I ;,,1} STATES BI\NK"lJPTCY
COUR'I' 1.'(1 ,1m MIlJDLE DrSTRIC'/ 'I . PENNSYLVANIA
IN Rll: !~oberl. u. Manning
SharlJ/I ':. Manning
'CHA,"EI{ 13
i CASE NO. 99-03!'01
!
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_.J 11 U..';,c. SEC. 362
Lehman (dpita], a division of
Lehman Hcothers HOldings, Inc,
Movant
FlLrcil) - H!nltb'JIC, P.\ I
r~,:: ;;'~r' i
c,""~;;-:- '~"c",,: I
P... '." "'-'~~'2,.~'f.<:':E~'
vs.
Robert B. Manning
Sharon c, Manni.ll<j
Debtor(r;)
and
Charles J. DeHart III, Esquire
Trustee
RESPO)IDENTS
DEFAULT ORDER MODIFYING SECTION 362 Al1'1'OMATIC STAY
AND NOW, this ~d day of D,j1-<U'~, 19<17 , at
, upon Motion For Relief and Certification of No Answer of
Movant above, it is
ORDERED AND DECREED THAT:' The Automatic Stay of all
proceedings, as provided under Section 362 of the Bankruptcy Reform
Act of 1979, as amended (The Code), 11 U.S.C. 362, is modified with
respect to premises:
3 Sunset Drive, Mechanicsburg, PA 17055
as to allow the Movant to foreclose,on its mortgage and allow the
purchaser of said premises at Sheriff I s Sale (or purchaser's
assignee) to take any legal action for enforcement of its right to
possession of said premises. '
III Robtlll 1. Wnadaia.
.', ..
Bankruptcy Judge
cc. Stuart Winneg, Esq.
MARK J. UDREN & ASSOCIATES
1040 North Kings Highway, Suite 500
Cherry Hill, New Jersey 08034
Charles J. DeHart III, Trustee
P.O. Box 410
Hummelstown, PA 17036
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e'f.-~
Matthew J. EShaAm&h, Esq.
2108 Market Street
Camp Hill, PA 17011.
Robert B. Manning
Sharon C. Manning
3 Sunset Drive
Mechanicsburg, PA 17055
.
MARX J. ODREN & ASSOCIATBS
BY. Mark J. Udren, Esquire
ATTY 1.0. NO. 04302
1040 N. XINGS HIGHWAY, SUITB 500
CHERRY HILL, NJ 08034
856-482-6900
ATTORNEY FOR P7.AINTIPP
Lehman Capital, A Division of
Lehman Brothers Holdings, Inc.
P.O. Box 24737
West Palm Beach, FL 33416-4737
. COURT OF COMMON PLEAS
: CIVIL DIVISION
: Cumberland County
: MORTGAGE FORECLOSURE
Plaintiff
v.
Robert B. Manning
Sharon C. Manning
3 Sunset Drive
Mechanicsburg, PA 17055
: NO. 99-1854 civil
Defendant(s)
I HEREBY CERTIFY THAT:
CERTIFICATE TO THE SHERIFF
I. The judgment entered in the above matter is based on an Action:
_.~__A. In Assumpsit (Contract)
...._.__B. In Trespass (Accident)
__X-C. In Mortgage Foreclosure
______.0. On a Note accompanying a purchase money mortgage and the property
being exposed to sale is the mortgaged property.
II. The Defendant(s) own the property being exposed to sale as:
_no_A.
_X_B.
_C.
.___0.
.... __E.
__..F.
An individual
Tenants by Entireties
Joint 7enants with right of survivorship
A partnership
Tenants in Common
A corporation
III. The Defendant(s) is (are):
....X..A.
..._B.
___.c.
Resident in the Commonwealth of Pennsylvania
Not resident in the Commonwealth of Pennsylvania
If more than one Defendant and either A or B above is not applicable,
state which Defendant is resident of the Commonwealth of
Pennsylvania.
Resident:
(Jvv
Mark j' Udren. ESQUIRE
Addre,s & I.D. # as above
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MARX J. ODRBN , ASSOCIATBS
BY' Mark J. Udren, Eequire
ATTY I.D. NO. 04302
1040 N. XINGS HIGHWAY, SUITB 500
CHERRY HILL, NJ 08034
856..482 -6900
Lehman Capital, A Division of
Lehman Brothers Holdings, Inc.
P.O. Box 24737
West Palm Beach, FL 33416-4737
ATTORNEY FOR PLAINTIFP
Plaintiff
. COURT OF COMMON PLEAS
: CIVIL DIVISION
: Cumberland County
: MORTGAGE FORECLOSURE
v.
Robert B. Manning
Sharon C. Manning
3 Sunset Drive
Mechanicsburg, PA 17055
: NO. 99-1854 civil
Defendant(s)
AFFIDAVIT PURSUANT TO RULE 3129.1
Lehman Capital, A Division of Lehman Brothers Holdings, Inc., Plaintiff
in the above action, by its attorney, Mark J. Udren, ESQ., sets forth as
of the date the Praecipe for the Writ of Execution was filed the
following information concerning the real property located at: 3 Sunset
Drive, Mechanicsburg, PA 17055
1. Name and address of Owner(s) or reputed Owner(s) :
Name Address
ROBERT B. MANNING
3 SUNSET DRIVE, MECHANICSBURG, PA 17055
SHARON C. MANNING
3 SUNSET DRIVE, MECHANICSBURG, PA 17055
2. Name and address of Defendant(s) in the judgment:
Name Address
SAME AS # 1 ABOVE
3. Name and address of every judgment creditor whose judgment is a record
lien on the real property to be sold:
Name Address
FARMERS TRUST COMPANY
1 W HIGH ST., PO BOX 220,CARLISLE, PA 17013
LISA KLINGER
61 HALF-MILE DR., GARDNERS, PA 17324
4. Name and address of the last recorded holder of every mortgage of
record:
Name Address
Plaintiff herein.
See Caption above.
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YOU MAY STILL BE ABLE TO SAVE YOUR PROPBRTY AND YOU HAVE OTHER RIGHTS
BVBN IP THB SHERIPP'S SALE DOES TAKE PLACE.
1. It the Sheriff's Sale is not stopped, your prope'ty will be sold to the
highest bidder. You may find out the price bid by calling 856-482-6900.
2. You may be able to petition the Court to set aside the sale if the bid price
was groosly 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 Dale. To find out if this has happened, YOII may call 856-482-6900.
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 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 after 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 Schedule of 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 TAKB THIS PAPBR TO YOUR LAWYBR AT ONCE. IP YOU DO NOT HAVE A LAWYER OR
CANNOT AFPORD ONE. GO TO OR TELEPHONE THE OPPICE LISTED BELOW TO PIND OOT WHERE YOU CAN
GET LEGAL HELP.
LAWYER REPERRAL SERVICE
Cumberland County Bar Association
2 Liberty Avenue
Carlisle, PA ~7013-3387
717-249-3~66 or ~-800-990-9~08
ASSOCIATION DE LICENCIDADOS DE FILADELFIA
Cumberland County Bar Association
2 Liberty Avenue
Carlisle, PA 17013-3387
717-249-3~66 or ~-800-990-9~08
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ALL THAT CERTAIN TRACT OF LAND SITUATF. IN THE TOWNSHIP OF SILVER
SPRING, COUNTY OF CUMBERLAND AND STATE OF PENNSYLVANIA, BOUNDED AND
DESCRIBED AS FOLLOWS TO WIT:
BEGINNING AT A POINT ON THE SOUTHWEST SIDE OF A PUBLIC ROAD KNOWN
AS T-597, AT THE CORNER OF LAND NOW OR LATE OF BARBARA HERSH;
THENCE ALONG THE SOUTHWEST SIDE OF SAID PUBLIC ROAD, SOUTH 41
DEGREES 46 MINUTES EAST, ONE HUNDRED NINETY-FOUR AND ONE-TENTH
(194.1) FEET TO A POINT; THENCE ALONG THE SAME AND ALONG THE
SOUTHWEST SIDE OF PUBLIC ROAD KNOWN AS T-596, SOUTH 29 DEGREES 5
MINUTES 30 SECONDS EAST, EIGHTY-ONE AND FORTY-FOUR HUNDREDTHS
(81.44) FEET TO A POINT; THENCE ON A CURVE TO THE RIGHT, HAVING A
RADIUS OF FIFTY (50) FEET, AN ARC DISTANCE OF SEVENTY-TWO AND THREE
HUNDRED SIXTY-NINE THOUSANDTHS (72.369) FEET TO A POINT; THENCE
ALONG LAND OF GEORGE W. WALKER AND MARY ALICE WALKER, HIS WIFE
SOUTH 53 DEGREES 50 MINUTES 15 SECONDS WEST, EIGHTY-ONE AND TWENTY-
ONE AND TWENTY-NINE HUNDREDTHS (81.29) FEET TO A POINT; THENCE
ALONG LAND OF SAME, ON A CURVE TO THE RIGHT, HAVING A RADIUS OF ONE
HUNDRED SEVENTY-NINE AND EIGHTEEN HUNDREDTHS (179.18) FEET, AN ARC
DISTANCE OF TWO HUNDRED FORTY-EIGHT AND EIGHTY-SEVEN HUNDREDTHS
(248.87) FEET TO A POINT; THENCE ALONG LAND NOW OR LATE OF MAX L.
MILLER AND JOYCE R. MILLER, HIS WIFE, NORTH 63 DEGREES 27 MINUTES
EAST, ONE HUNDRED SIXTY-EIGHT AND NINE HUNDREDTHS (168.09) FEET TO
A POINT; THENCE ALONG LAND OF SAME, NORTH 22 DEGREES 13 MINUTES
WEST, TWO HUNDRED FIFTY-EIGHT AND ONE TENTH (258.1) FEET TO A
POINT; THENCE ALONG LAND NOW OR LATE OF BARBARA HERSH, FIRST
MENTIONED ABOVE, DUE EAST, EIGHTY-SEVEN AND FOUR HUNDREDTHS (87.04)
FEET TO A POINT ON THE SOUTHWEST SIDE OF PUBLIC ROAD KNOWN AS T-
597, THE PLACE OF BEGINNING.
BEING LOT NO. 32, AS SHOWN IN THE SUB-DIVISION PLAN OF WHITE BIRCH
FARMS DEVELOPMENT, INDICATED AS TRACT NO.1, LOT NO. 32, AS
RECORDED IN THE RECORDER'S OFFICE IN AND FOR CUMBERLAND COUNTY,
PENNSYLVANIA, IN PLAN BOOK 24, PAGE 114.
HAVING THEREON ERECTED A SINGLE, BRICK RANCH TYPE DWELLING WITH TWO
CAR GARAGE.
TAX PARCEL 38-14-0847-057
TITLE TO SAID PREMISES IS VESTED IN ROBERT B. MANNING AND SHARON C.
MANNING, HIS WIFE, AS TENANTS BY THE ENTIRETIES, BY DEED FROM GENO
A. FRANCAVILLA AND DOLLY M. FRANCAVILLA, HIS WIFE DATED 5/9/1996
AND RECORDED 5/9/1996 IN DEED BOOK 138 PAGE 1133.
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MAJut J. UDRBN . ASSOCIATBS
BY, Hark J. Oc1ren
ATTY I.D. NO. 04302
1040 N. KINGS HIGHWAY, SOITB 500
CHBRRY HILL, NJ 08034
856-482-6900
Lehman Capital, A Division of
Lehman Brothers Holdings, Inc.
P.O. Box 24737
West Palm Beach, FL 33416-4737
Plaintiff
ATTORNEY FOR PLAINTIFF
. COURT OF COMMON PLEAS
: CIVIL DIVISION
: Cumberland County
v.
Robert B. Manning
Sharon C. Manning
3 Sunset Drive
Mechanicsburg, PA 17055
Defendant(s)
: NO. 99-1854 civil
APPIDAVIT OP SERVICB PURSUANT TO Pa.R.c.p.ROLE 3129.1
Plaintiff, by its/his/her Attorney, Mark J. Udren, Esquire, hereby verifies
that:
1. A copy of the Notice of Sheriff's Sale, a true and correct copy of which
is attached hereto as Exhibit "A", was sent to every recorded lienholder and
every other interested party known as of the date of the filing of the
Praecipe for the Writ of Execution, on the date(s) appearing on the attached
Certificates of Mailing.
2. A Notice of Sheriff's Sale was sent to Defendant(s) by regular mail and
certified mail on the date appearing on the attached Return Receipt, which
was signed for by Defendant (s) on the date specified on the said Return
Receipt. Copies of the said Notice and Return Receipt are attached hereto as
Exhibit "B".
3. If a Return Receipt is not attached hereto, then service was by personal
service on the date specified on the attached Return of Service, attached
hereto as Exhibit "B".
4. If service was by Order of Court, then proof of compliance with said
Order is attached hereto as Exhibit "B".
All Notices were served wi thin the time limits set forth by Pa Rule C. P.
3129.
This Affidavit is made subject to the penalties of 18 Pa.C.S. Section 4904
relating to unsworn falsification to authorities.
Dated: August 4, 2000
BY:
MARK J. UDREN & ASSOCIATES
L~
Mark J. Udren, Esquire
Attorney for Plaintiff
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MAR1t J. ODREN , ASSOCIATES.
BY: Hark J. Udren, Esquire
ATTY 1.0. NO. 04302
1040 N. KINGS HIGHWAY, SUITE 500
CHERRY HILL, NJ 08034
856-482-6900
ATTORNEY FOR PLAINTIFF
Resource Bancshares Mortgage
Group, Inc.
P.O. Box 24737
West Palm Beach, FL 33416-4737
Plaintiff
i COURT OF COMMON PLEAS
! CIVIL DIVISION
i Bucks County
v.
Louis Weinkopff
47 Border Rock Road
Levittown, P~ 19057
Defendant(s)
INO
00001156-22-1
,
llERIEI.CATION ..0LSER.'l.I.CE...BY_CERTI.EIED_.MAIL....ANIL
REGULAR.. MAI L-EJJRS.UAN:r._T.O_CQUR'LORDER
The undersigned hereby verifies that he is counsel for Plaintiff in
the above case and that pursuant to the Court order issued in this
matter he mailed a true and correct copy of the Notice of Sale to
Defendant(s), by certified mail and regular first class mail, to
the last known address of Defendant(s) as follows:
DATE MAILED: June 02, 2000
Louis Weinkopff
47 Border Rock Road
Levittown, PA 19057
..
.
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I verify that the statements made herein are true and correct ::and .;:.:Z:~_.
I understand that false statements made herein are subject to 1=he '::,=."
penalties of 18 Pa.C.S. Section 4904 relating to unsworn
falsification to authorities.
2:
-
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MARK J. UOREN & ASSOCIATES
o
Dated:
\""rv~
Mark J. Udren. Esquire
EXHIBIT 8
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Lchman Capilal, A Division of
Lchman Brolhcrs Holdings, Inc.
-vs-
Robert B. Manning and Sharon C.
Manning
In thc Coart of Common Pleas of
Cumberland County, Pennsylvania
No. 1999.1854 Civil
Robert L. Fink, Deputy SherilTwho being duly sworn according to luw, suys on July
13, 2000 01 II :05 o' clock A.M. EDS'r, he served a true copy of Real Estale Writ Notice
Poster and Description in thc above entitled action upon one of the within named
defendants to wit: Robert B. Manning by making known unto Robert Manning at 3
Sunset Drive, Mechanicsburg, Cumberland County, Pennsylvania, its contents and at the
same time handing to him personally the said true and allested copies of the same.
Robert L. Fink, Deputy Sheri IT, who being duly sworn according to law, says on July
13,2000 at 11:050 'c1ock A.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: Sharon C. Manning by making known unto Robert Manning, Husband
at 3 Sunset Drive, Mechanicsburg, Cumberland County, Pennsylvania, its contents and at
the same time handing to him personally the said true and allested copies of the same.
Robert L. Fink, Deputy SheirlT, who being duly sworn according to law, says on July
13,2000 Atl 1:05 o'clock A.M. EDST, he posted a copy of Real Estate Writ Notice
Poster and Description on the property of Robert Manning and Sharon Manning located a
3 Sanset Drive, Mechanicsburg, Cumberland County, Pennsylvania according to law.
R. Thomas Kline Sheriff who being duly sworn according to law, says he served the
above Real Estate Writ Notice Poster and Description in the following manner: The
Sheriff mailed a notice of the pendency of the action to one of the within named
defendants to wit: Robert B. Manning to 3 Sunset Drive, Mechanicsburg, Pennsylvania.
This letter was mailed under the date of July 14,2000 and never retumed to the Sheriffs
Office.
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: Sharon C. Manning by regular mail to 3 Sunset Drive, Mechanicsburg,
Pennsylvania. This leller was mailed under the date of July 14, 2000 and never returned
to the Sheriffs Office.
R. Thomas Kline, Sheriff, who being duly swom according to law, says that after
due and legal notice had been given according to law, exposed the within described
premises at public venue or outcry at the Court House, Carlisle, Cumberland County,
Pennsylvania, on September 6,2000 at 10:00 o'clock A.M., E.D.S.T. and sold the same
for the sum of $1.00 to Attomey Dale Shughart for The Chase Manhattan Bank, as
Trustee. It being the highest bid and the best price received for the same The Chase
Manhattan Bank, as Trustee, of 1675 Palm Beach Lakes Boulevard West Palm Beach,
FL, being the buyer in this execution paid SheriffR.Thomas Kline, the sum of$I,042.03,
it being costs,
.
. ~
MARK J. UDRF.N .. ASSOCIATES
BY: Mark~. Udren. Esquire
ATTY 1.0. );(1, 04302
1040 N. KINGS HIGHWAY, SUITE 500
CHERRY HILL, NJ 08034
856-482-6900
ATTORNEY FOR PJ.l\INTIPP'
Lehman Capital, A I.li vinion of
Lehman Brothers Holdings, Inc.
P.O. Box 21'13'1
West Pal", lJ,"ach, FL 33416-473'/
. COURT OF' COMMON PLEAS
: C; VIL DIVISION
: (', ""berland County
: r~ORTGAGE FORE,:LOSURI':
Plaintir I
v,
Robert B. Hanning
Sharon C. Manning
3 Sunset Drive
Mechanicsburg, PA 1705 S
: NO. 99-1854 (' 'vil
Defondant (s)
NOTICE..OF SHERIFF'S. SALE OF._REAL PROPERTY
SHARON C. MANNING
3 Sunset Drive
: Mechanicsburg, PA 17055
\
Your house (real estate) at 3 Sunset Drive, Mechanicsburg, PA 17055 is
scheduled to be sold at the Sheriff's Sale on September 6, 2000, at 10:00
A.M. in the COMMISSIONERS HEARING ROOM, 2ND FLOOR, COURTHOUSE, CARLISLE,
PA to enforce the court judgment of $131,206.00, obtained by Plaintiff
above (the mortgagee) against you. If the sale is postponed, the
property will be relisted for the Next Available Sale.
TO:
ROBERT B. MANNING
3 Sunset Drive
Mechanicsburg, PA
17055
NOTICE-OF OWNER~S_RIGHTS
YOU. .MAY._BE....ABLE TO_EREVENT THIS_SHERIFF_~s.....9ALE
To prevent this Sheriff I s Sale, you must take imma.diate__ac.ti.QIl:
1. The sale will be cancelled if you pay to the
charges, costs and reasonable attorney's fees.
you may call: .La56L..48.:t=.69.0.a..
mortgagee the back payment, late
To find out how much you must pay.
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.
more chance you will have of stopping the sale.
to obtain an attorney. )
The sooner you contact one, the
{See notice on page two on how
ALL THAT CERTAIN TRACT OF LAND SITUATE IN THE TOWNSHIP OF !aLVER
SPRING, COUNTY OF CUMBERLANll MIll STAn; ew PENNSYLVANT,\, BOUNllI-:rl AND
DESCI'TI\":, I AS [:iILLOWS TO WTT:
BEcrr';!I1NG AT A POINT ON Till: ~;OUTHWEST SI!>!.: OF " 1'::i',[,IC ROAD KNOI'IN
AS '1'-597, AT THE ('(,RNER ew LAND NOW 011 LATE 0[0' BARBARA llER~:iI;
THENCE ALONG TilE SOUTHWEST sroE OF ~:A(lJ PUBLIC ROAD, SOIJTII on
DEGREES 46 MJ NI ITES EAST, ONE !lUND!' Io:li NINETY - FOUR r,ND 01 I,: TENTH
(194.]) FEET TO A POINT; TH"ICE ALONG THE SAME ,fI[) ALONG THE
SOUTmlEST SIDE OF PUBLIC [WAf' KNOWN AS '1'- 596, SOIITII 29 DEGREES 5
MIIIlI'I'ES 3 0 SECOND~: EAST, E rGHTY -ONE At'll FOR'I"{. FOUR HUNDREDT""
(8] .44) FEET TO A I'UnlT; THENCE ON A CUW'''; TO THE RIGHT, HAVING ^
RADIUS OF FIFTY (50) FEET, AN 1,RC DISTM1Cr.: OF SEVENTY-TWO AND THREE
HUNDRED SIXTY. NINE THOUSANDTH, (72. ",(,9) FEET TO A POINT; THENCE
ALONG LAND OF GEORGE W. Wd,; I;R AND MARY ALICE WAr 1\ER, HIS WIFE
SOUTH 53 DEGREES 50 MINUTES 1" SECONDS WEST, EIGIlTI' ONE AND TWENTY-
ONT.: MID TWENTY - NINI.: HUNH':-:IJTHS (81. 29) "EET TU A POINT; THEt:CE
ALONG LAND OF SAME, ON A CURVE TO THE RIGHT, HAVING A RADIUS OF UNE
HUNDRED SEVENTY-NINE AND EIGHTEEN HUNDREDTHS (179.18) FEET, AN ARC
DISTANCE OF TWO HUNDRED FORTY-EIGHT AND EIGHTY-SEVEN HUNDREDTHS
(248.87) FEET TO A POINT; THENCE ALON9 LAND NOW OR LATE OF MAX L.
MILLER AND JOYCE R. MILLER, HIS WIFE, NORTH 63 DEGREES 27 MINUTES
EAST, ONE HUNDRED SIXTY-EIGHT AND NINE HUNDREDTHS (168.09) FEET TO
A POINT; THENCE ALONG LAND OF SAME, 'NORTH 22 DEGREES 13 MINUTES
WEST, TWO HUNDRED FIFTY-EIGHT AND ONE TENTH (258.1) FEET TO A
POINT; THENCE ALONG LAND NOW OR LATE OF BARBARA HERSH, FIRST
MENTIONED ABOVE, DUE EAST, EIGHTY-SEVEN AND FOUR HUNDREDTHS (87.04)
FEET TO A POINT ON THE SOUTHWEST SIDE OF PUBLIC ROAD KNOWN AS T-
597, THE PLACE OF BEGINNING.
BEING LOT NO. 32, AS SHOWN IN THE SUB-DIVISION PLAN OF WHITE BIRCH
FARMS DEVELOPMENT, INDICATED AS TRACT NO.1, LOT NO. 32, AS
RECORDED IN THE RECORDER'S OFFICE IN AND FOR CUMBERLAND COUNTY,
PENNSYLVANIA, IN PLAN BOOK 24, PAGE ~14.
;,
HAVING THEREON ERECTED A SINGLE, BRICK RANCH TYPE DWELLING WITH TWO
CAR GARAGE.
TAX PARCEL 38-14-0847-057
TITLE TO SAID PREMISES IS VESTED IN ROBERT B. MANNING AND SHARON C.
MANNING, HIS WIFE, AS TENANTS BY THE ENTIRETIES, BY DEED FROM GENO
A. FRANCAVILLA AND DOLLY M. FRANCAVILLA, HIS WIFE DATED 5/9/1996
AND RECORDED 5/9/1996 IN DEED BOOK 138 PAGE 1133.
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UndorRcl NO. 587, Roomuod Mau 16. 1912
CommOnwaalth 01 Pannly/vanla, COunly of DauphIn) II
Jama. L. Cllrk being duty Sworn according to low, deposes and says:
That ha Is tho Accountl Rocolvablos Mnnager 01 THE PATRIOT.NEWS CO., a cOrporallon organized and exlsllng under
Iha law, of the Commonweellh of POnnsylvanla, wllh lis prlnclpel office and place of business el 812 to 818 Market
Slraal. in tha Clly 01 Harrisburg, County of Dauphin, Slate of Pennsylvania. owner and PUbllshar of THE PATRIOT.
NEWS and THE SUNDAY PATRIOT.NEWS newspapers of genaral circulation, printed and published at 812 10 818
Market Strael, In tha Clly, County and Slala eforasald; that THE PATRIOT-NEWS and THE SUNDAY PATR/OT.NEWS
were ostabllshed March 4th. 1854, and SOPlembar 18th, 1949, respectively, and all have been continuously
publish ad ever slnca;
That Ihe prlnlod nollco or PUbllceflon whIch Is securaly alia chad hereto Is exaclly as printed and published In
their ragular dally and/or Sundey and Moira odlllonsllssues which appeared on Iha lsl, 8th and 15th day(s) of
August 2000. That nalthar he nor said Company Is Intareslad In the subject mailer of said printed nollce or
advertising, and that all of the alia gallons of this sfatemanl as to the time. place and character of PUblica lion are
Irue; and
That he has porsona' knowladga of Iha facts aforosald and is duly authorized and empOwered to verify this
slatement on behalf 01 Tho PatrlOI.Nows Co, arorosald by vIrtue and pursuant to a resolullon unanimOUSly passed and
adopled severally by Iha stOCkhOlders and board of directors 01 the said Company and Subsequenlly dUly recorded In
the office for Iha Recording of Deads In and for saId County of Dauphin In M/SCllla ous 800k 'M',
VOlume 14, Page 317,
PUBLICATION ____________________ c.L._ ______________________
COpy Sw s 30lh day Aug 000 A.D.
NOlart.1ISoal
S ALE 1/42 Tony L Ru",", Notary Public
HarriSburg, DaUPhIn Count
My CommiSSion Ell'oires June t. ?002 NOT RY PUBLIC
Mamber, POnnsyN'",a ASSOCIation <Mj<>1~iM1mlsslon expires June 6, 2002
THE PATRIOT NEWS
THE SUNDAY PATRIOT NEWS
Proof of Publication
, .
CUM8ERlAND COUNTY SHERIFFS OFFICE
CUM8ERlAND COUNTY COUATHoUSE
CARLISLE, PA. 17013
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 acknowladge receipt of Ihe aforesaid nollce and pUbticatlon cosls and certifies that the same have
bean duly paid, THE PATRIOT-NEWS CO.
By...............,....,...............................................
Statement of Advertisina Costs
To THE PATRIOT-NEWS CO., Dr.
For Publishing Ihe notice or PUblication allached
herelo on the above stated dates $
Probating same Notary Fae(s) $
Total $
367,46
1.505368,96