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Home My WebLink About99-01940 1. Plaintiff iu CON'rIMORTGAGE CORPORATION ONE CONT I PARK 1 318 ROUTH WARMINSTER ROAD IIATBORO, Ph 19040 2. The name(s) and last known address(es) of the Defendant(s) are DENNIS E. MEYER TAMARA S. MEYER 116 WEST SPRINGVILLE ROAD BOILING SPRINGS, PA 17007-9740 who is/are the mortgagor(s) and real owner(s) of the property hereinafter described. 3. Mortgagor(s) made, executed and delivered a mortgage upon the premises hereinafter described, which mortgage is recorded in the Office of the Recorder of CUMBERLAND County, as follows: !;1.W Oriqinal Mortqaqee Book no. Paqe 10/13/97 KEYSTONE STATE 1411 138 MORTGAGE CORPORATION The Mortgage referred to herein was assigned as follows: Recorded Aseiqned To Book No. Paqe 3/2/98 PLAINTIFF 569 1116 4. The premises subject to said mortgage is described as attached. 5. The mortgage is in default because monthly payments of principal and interest upon said mortgage due 4/1/98 and each month thereafter are due and unpaid, and by the terms of said mortgage, upon failure of mortgagor to make such payments after a date specified by written notice sent to Mortgagor, the entire principal balance and all interest due thereon are collectible forthwith. A copy of such notice is attached as Exhibit "A." . FEDERMAN AND PHELAN Suite 900 Two Penn Center Plaza Philadelphia, PA 19102,1799 215-241-1711 Fax: 215-568-7617 Representill8 Lenders in Pennsylvania and New Jersey February 26. 1999 Dennis E, Myers 116 W. SprinsviUe Road Boilill8Springs, PA 17007.9740 Tamara S. Myers 116 W, SpringviUe Road Boiling Springs, PA 17007.9740 Re: Premises: I Pine Hill Avenue, Merd1anJcsblll'g, PA 17055 Lilan No,: 0005185880 NOTICE OF INTENTION TO FORECLOSE We represent ContIMortp&e Corporation, the holder of the Mortgage on the above-referenced premises, who hereby advises that it win accelerate your Mortgage (demand payment In fun) and pursue the foreclosure remedies permitted by the mortgage unless your loan delinquencies are cured as provided below, TIllS FIRM IS A DEBT COLLECTOR ATIEMPTlNG TO COLLECT A DEBT. TIllS NOTICE IS SENT TO YOU IN AN A TIEMPT TO COLLECT TIlE INDEBTEDNESS REFERRED TO HEREIN AND ANY lNFORMA nON OBTAINED FROM YOU WILL BE USED FOR 1HA T PURPOSE, IF YOU HAVE PREVIOUSLY RECEIVED A DISCHARGE IN BANKRUPTCY, TIllS CORRESPONDENCE IS NOT AND SHOULD NOT BE CONSTRUED TO BE AN ATIEMPT TO COLLECT A DEBT, BUT ONLY ENFORCEMENT OF A LIEN AGAINST PROPERTY. You may dispute the validity of the debt or any portion thereof, If you do so in writill8 within thirty (30) days of receipt of this letter, this firm will obtain and provide you with written verification thereof; otherwise, the debt will be assumed to be valid. Likewise, you may request the name and address of the original creditor if dill'erent from above. . The total delinquency, including late and other charges is $14,188.51 for the months of 4/1198 through 2/1/99 . Your failure to pay the delinquent amoun~ plus any additional monthly payment and late and other charges (including any accrued interest) that may come due within the next thirty (30) days, wiU result in the acceleration of aD sums due under your Mortgage. After acceleration occurs, a foreclosure action or any other remedy pennitted by your mortgage may be Instintted. To avoid the acceleration of your mortgage and subsequent foreclosure action, the delinquency mentioned above and any accrual thereto must be paid by CERTIFIED CHECK OR MONEY ORDER and received in our oflices at Suite 900, Two Penn Center Plaza, Philadelphia, PA 19102, in or before thirty (30) days from the date of this letter, Please caD (215)241-1711 for the exact amount required. You have the right to reinstate your mortgage after acceleration by fulfilling the conditions stated in your mortgage pertaining to such reinstatement. You may caD our office to discuss these conditions. Any future negotiations attempting to reinstate your loan or acceptance of any payment less than the fun amount due shaD not constitute a waiver by the mortgage holder of the acceleration unless agreed to in writing by the mortgage holder, You have the right to assert in the foreclosure proceedings the non.existence of a default or any other defense to acceleration and foreclosure. EXHIBIT A ..... ..- LAWUMCI T. PHILUt MA&CI.D N. IAPU.H- u:a.a L I'UID". I'IAHCIII. IW.lJtCAH- ...... 0. IODGKI -......... -...- -....- -'.W DIAICJNDI' IADGL_ IJIIA .. ............... _L_ .....,.&,~JU.,. -ADMJ'DDmrAANDH/ .."." JDUf IitAIUOINQ rMaNl. .....omaa FEDERMAN AND PHELAN ..... ... twO ,.,.. QHTII. Pl.AZA PIIIADILI'MIA.'''' 1'la.l7ft ClIJ)J4I.nll 'AI am ..mol 1"II.XCPUIa'(1lnJO.UM IANDIIPT't"t 1D.IICDP1U (1lJ) ""Mil ..... """" ... NCII1II-.... MIDIA.'A IIOU OIJlBI4J404 --"""" JUnlJIlS aNTI.Y OI'PICI PlAZA 11' HADDCIf AYDftlI WU11On', NIW .JIUIY .1. 'I'IUCD'IU , CD) UUC 11aI J<<ma 1I1Df'1' 1'0 YOU If AM AT1Da'I' TO CCIJ.ICT 11m DCDllftDHUlIIPIIUD 10 MIllIN NfDAJfY ~11QHo.rADIIDnc:aI YOU WILL U UIID POI. 11CAT P\IUOSI.. ...........- DOtW.D L IlClDOOIAH February 16, 1999 Dennis E. Myers 1 pine Hill Avenue Merchanicsburg, PA 17055 839 Bower Road Snermans Pale, PA 17090 Tamara S. Myers 1 pine Hill Avenue Merchanicsburg, PA 17055 839 Bower Road Shermans Pale, PA 17090 Re: Premises: 1 pine Hill Avenue, Merchanicsburg, PA 17055 Loan No.: 0005185880 NOTICE OF INTENTION TO FORECI.DSE We represent contillOrtgage Corporation, the holder of the Mortgage on the above-referenced premises, who hereby advises that it will accelerate your Mortgage (demand payment in full) and pursue the foreclosure remedies permitted by the mortgage unless your loan delinquencies are cured as provided below. THIS FIm~ IS A DEBT COLLECTOR ATT~rING TO COLLECT A DEBT. THIS NOTICE IS SENT TO YOU IN AN ATTEMPT TO COLLECT THE INDEBTEDNESS REFERRED TO HEREIN AND ANY INFORMATION OBTAINED FROM YOU WILL BE USED FOR THAT PURPOSE. IF YOU HAVE PREVIOUSLY RECEIVED A DISCHARGE IN BANKRUPTCY, THIS CORRESPONDENCE IS NOT AND SHOULD NOT BE CONSTRUED TO BE AN ATTEMPT TO COLLECT A DEBT, BUT ONLY ENFORCEMENT OF A LIEN AGAINST PROPERTY. You may dispute the validity of the debt or any portion thereof. If you do so in writing within thirty (30) days of receipt of this letter, this firm will obtain and provide you with written verification thereof; otherwise, the debt will be assumed to be valid. Likewise, you may request the name and address of the original creditor if different from above. The total delinquency, including late and other charges is $14,188.51 for the months of 4/1/98 through 2/1/99. Your failure ExH/BIT A VERIFICATION DANIEL W. PRATT hereby states that he is FORECLOSURE COORDINATOR ot CONTI MORTGAGE CORPORATION mortgage servicing agent tor Plaintiff in this matter, that he/she is authorized to take this Verification, and that the statements made in the toregoing civil Action in Mortgage Foreclosure are true and correct to the best ot his/her knowledge, intormation and belief. The undersigned understands that this statement is made subject to the penalties ot 18 Pa. C.S. Sec. 4904 relating to unsworn falsification to authorities. !JCI~ rJ. ?J' DATE: '31~cJ 'h I # . . ' ". . .' . . ~ ,.. rr o<i: '"" ~~q p.:~'~ ~i.::.: ,'; I' L4 r":: -. c.;;g u.. ,0 \l) u: 8 E .' :-)~ (J" .-. ( ,... .}? 0> .,.;...J :.:ru; .J .. rt:'" I{JZ :.)~ ~ ::.) U ,,- ~ In I Cc: Co. .." en en rlOlLO . '.:tu ,OOllO-Ul906r u. I rvuu.,VUJGWI 81'~IIVOIW.UZ<<lEl , 1000"""0'1 ~313J.V1S"1V .,\ ... , V} ~ ;l ,:) -" d ~ " , ...,' ". ., ~ .. ~ i ~ cr;}">"); \S\'{) ..' ' ,,~';;\\~O'.~\l~\\\\~ ,-,,"J\' '1l1l<)c1ol~l. ~",'" " l~\Il~'J ( ".rS ........\0 Q(jji.h',l' ,,,~:iJ.3; ~'f\3\-\c1 Q~N \~'l'" t!'..; ..;j I. : v' >- V". 0 '" a: '" UJ"i:< ~./-:o ~I-' :~~ i~"5 ~!t! .~ iE :'WO r1,' I- : ex :z ,It\, ...., -= ,./: : <! J: : '..J ~ . >n:~ l'i1 ~ N ',' ~'8 ...... '- I 0J"- =-- ... "< ~ '., " ~J . FEDERMAN AND PHE~~ Frank Federman, Esquire Ide:-:tificacion Nc, 122-13 Two Penn Center Plazd Sui te 900 Philadelphia, PA 19102-1799 (215) 563-7000 ATTORNE'l FOR PLAINTH'? CONTIMORTGAGE CORPORATION COURT OF COMMON PLEAS Plaintiff CIVIL DIVISION vs. CUMBERLAND COUNTY DENNIS E. MEYER TAMARA S. MEYER NO. 99-1940 Defendant(s) "'. tiLt C~Py TO: TAMARA S. MEYER 7073 CARLISLE PIKE, LOT 132 CARLISLE, PA 17013 DATE OF NOTICE, JUNE 8, 1999 THIS FIRM IS A DEBT COLLECTOR ATTEMPTING TO COLLECT A DEBT. ANY INFORMATION WE OBTAIN WILL BE USED FOR THAT PURPOSE. IF YOU HAVE PREVIOUSLY RECEIVED A DISCHARGE IN BANKRUPTCY, THIS CORRESPONDENCE IS NOT AND SHOULD NOT BE CONSTRUED TO BE AN ATTEMPT TO COLLECT A DEBT, BUT ONLY ENFORCEMENT OF A LIEN AGAINST PROPERTY. 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 (10) days from the date of this notice, a Judgment may be entered against you without a hearing and you may lose your property or other important rights. You should take this notice to a lawyer at once. If you do not have a lawyer or cannot afford one, go to or telephone the following office to find out where you can get legal help: CUMBERLAND COUNTY CUMBERLAND COUNTY BAR ASSOCIATION 2 LIBERTY AVENUE CARLISLE, PA 17013 (717) 249-3166 Frank Federman, Esquire Attorney for Plaintiff (J' .Sf.. ll; ..0 ~ ~ - .,.. ~ w ::-14: i (}O u.J0 I:):.;.!) (')~ ; (..)~i . " ;:;: ,~ t1J l..I_' ')~ c) II. 1; . ~,.., ~ if) 00 ~ 0' (',J :J:;:: -a ~ Ci5 11"-' '-Z lD -:-1(" $;: :JUj "t. 11.-. ;clu.. ~:. ~ ,- D ~ .....j. > ~ ". C'l ::J 1 oJ 0 CT> 0 0 '- rr 11 ~ 3 -1 cL- iff () ... rl 0 t"- M ~ . , I'iI ~ ~ . till>: 'tl ,1'iI 1-1 QJ Q ~~ ~ e . ;~ Z .0: 0 QJ ~ui III CO .... ... '" ~ ~ ... , QJ '" '.... N .Q rl ...:1>= l.i~ u '-' ... 1-1 r-l'Oj' ~ rl m ~rn ~ i~ :>< ... ..... ~ z~ r-l ,. III Eo< '" .-i 0 <V Or-l 0 ~ Q p., ..:l III E-< ~': p., 0] '" ~ '" QJ ~ 0 Q~ ... ... 0. ci ~ 0> t.I . .0:1..: iil~ ~""""'. U1 u~ III 1-1 ll. E-< I'iI :- .......... :::~ >. 110 ffl 1..:.0: ~~ QJ QJ ..:l ~o ..... , ~ I'iI '" 1-1 Ou <~ 01:: '" ..:l QJ :> ~~ tl ,1'iI ~ Q 0. tIl ~ H ~~ ~~ '-' 1-1 (J 0 (~,! :I: III 0 8gj 1-1 :>< .... III ... ~ fEJui u oo QJ '" ~ 'tl '" .... r-lr-l 0 <V 'tl I ~~ t.I i~ ..-i ~ '" ..... '" ~~ ~ t"- oo ~ Ol Ol Q <V '" '0 '0 .0: '. , . PEDERMAN and PHELAN By. PRANK PEDERMAN Identification No. 12248 Suite 900 Two Penn Center Plaza Philadelphia, PA 19102 (215) 563-7000 ATTORNEY POR PLAINTIFF CONTI MORTGAGE CORPORATION CUMBERLAND COUNTY COURT OP COMMON PLEAS CIVIL DIVISION VB. DENNIS E. MEYER, A/K/A DENNIS E. MEYER, SR. TAMARA S. MEYER, A/K/A TAMERA S. MEYER NO. 99-1940 CIVIL TERM VERIFICATION OF NON-MILITARY SERVICE FRANK FEDERMAN, ESQUIRE, hereby verifies that he is attorney for the Plaintiff in the above-captioned matter, and that on information and belief, he has knowledge of the following facts, to wit: (a) that the defendant(s) is/are not in the Military or Naval Service of the United States or its Allies, or otherwise within the provisions of the Soldiers' and Sailors' Civil Relief Act of Congress of 1940, as amended. (b) MEYER, SR. is PIKE, LOT 132, that defendant DENNIS E. MEYER, over 18 years of age and resides CARLISLE, PA 17013. A/K/A DENNIS E. at 7073 CARLISLE (c) that defendant TAMARA S. MEYER, A/K/A TAMERA S. MEYER is over 18 years of age, and resides at 7073 CARLISLE PIKE, LOT 132, CARLISLE, PA 17013, This statement is made subject to the penalties of 18 Pa. C. S. Section 4904 relating to unsworn falsification to authorities. 1NlAk :1~A~~ FRANK FEDER ,ESQUIRE Attorney for Plaintiff ,... I..U t t<: ,"- .::J \.. co ..... llJC, ::>..,. c,)<, C) ::-:~ ~~ . :.i -.)~ ,,1. r ,'.-::J <.,.)"-- c.:~: 'n ;~ \...l.j!+ N .:12 ~I, (.':J 'jdj ,.....-. =.') r' "" ~_!u.. " ,,:- ,. 0' :::> '-' (1'\ U ~ Ul r;: 1r, ~ ):~ Ch 5,.,; l!.l~' r_J;;...... <",).:'-" ::c :-'~ _'-I . \.1_0, oe: _'"1~ ~'!c,r. , >:r .". '.." ']'" C~L N '_Z u.:l. ,:cz _It. <.!l ..j.JLU iL :~. :=l 0) u.. l-' o<X -..;, ,,- en ::s 0 en (J . FEDERMAN AND PHELAN By: FRANK FEDERMAN, ESQUIRE IDENTIFICATION NO. 12248 TWO PENN CENTER PLAZA, SUITE 900 PHILADELPHIA, PA 19102 (215\ 563-7000 ATTORNEY FOR PLAINTIFF COURT OF COMMON PLEAS CIVIL DIVISION CONTIMORTGAGE CORPORATION ONE CONTI PARK, 338 SOUTH WARMINSTER ROAD HATBORO, PA 19040 Plaintiff TERM NO. 99. /l),/O e.:v,.rr;~- CUMBERLAND COUNTY v. DENNIS E. MEYER TAMARA S. MEYER 116 WEST SPRINGVILLE ROAD BOILING SPRINGS, PA 17007-9740 Defendant(s) CIVIL ACTION - LAW MORTGAGE FORECLOSURE NOTICE THIS IS AN ATTEMPT TO COLLECT A DEBT AND ANY INFORMATION OBTAINED WILL BE USED FOR THAT PURPOSE. You have been sued in Court. If you wish to defend against the claims set forth in the following pages, you must take action within twenty (20) days after this Complaint and Notice are served, by entering a written appearance personally or by attorney and filing in writing with the court your defenses or objections to the claims set forth against you, You are warned that if you fail to do so the case may proceed without you and a jUdgment may be entered against you by the court without further notice for any money claimed in the complaint or for any other claim or relief requested by the Plaintiff. You may lose money or 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. T CUMBERLAND COUNTY RUE COpy FROM RECORD CUMBERLAND COUNTY BAR In Testlroony wheroot, I ~lro UnlQ sit my Mna LIBERTY AVENUE Md Ihll ppal of said Court at Carlisle Pa CARLISLE, PA 17013 r~!J) ~y OI~ I~ (717) 249-3166 .- (~.,; () 'I ~ .I. /. Prothonotary ASSOCIATION We hereby certify the within to be a true and c::rrecl copy of tho ., f)~:1Inal filed of record " , '":'\11/.\'" "li~O PHELAN , 1, Plaintiff is CONTIMORTGAGE CORPORATION ONE CONTI PARK , 338 SOUTH WARMINSTER ROAD HATBORO, PA 19040 2. The name(s) and last known address (es) of the Defendant(s) are DENNIS E. MEYER TAMARA S. MEYER 116 WEST SPRINGVILLE ROAD BOILING SPRINGS, PA 17007-9740 who is/are the mortgagor(s) and real owner(s) of the property hereinafter described. 3. Mortgagor(s) made, executed and delivered a mortgage upon the premises hereinafter described, which mortgage is recorded in the Office of the Recorder of CUMBERLAND County, as follows: ~ OriQ'inal Mortqaqee Book No. PaQ'e 10/13/97 KEYSTONE STATE 1411 138 MORTGAGE CORPORATION The Mortgage referred to herein was assigned as follows: Recorded Assiqned To Book No. PaQ'e 3/2/98 PLAINTIFF 569 1116 4. The premises subject to said mortgage is described as attached. 5. The mortgage is in default because monthly payments of principal and interest upon said mortgage due 4/1/98 and each month thereafter are due and unpaid, and by the terms of said mortgage, upon failure of mortgagor to make such payments after a date specified by written notice sent to Mortgagor, the entire principal balance and all interest due thereon are collectible forthwith. A copy of such notice is attached as Exhibit "A." . 6. The following amounts are due on the mortgage: Principal Balance Intersst 3/1/98 through 3/1/99 (Per Diem $38.99) Attorney's Feos Cumulative Late Charges 10/13/97 to 3/1/99 Cost of suit and Title Subtotal $131,794.12 14,231.35 Search 6,589.00 1,038.87 550.00 154,203.34 Escrow Credit Deficit 0.00 125.00 Subtotal TOTAL 125.00 $154,328.34 7. The attorney's fees set forth above are in conformity with the Mortgage documents and Pennsylvania La~, and will be collected in the event of a third party purchaser at Sheriff's Sale. If the Mortgage is reinstated prior to the Sale, reasonable attorney's fees will be charged. 8. This action does not come under Act 6 of 1974 because the original mortgage amount exceeds $50,000.00. 9. This action does not come under Act 91 of 1983 because the mortgaged premises is not the principal residence of the Oefendant(s). . . FEDERMAN AND PHELAN Suite 900 Two Penn Center Plaza Philadelphia, PA 19102-1799 215-241,1711 Fax: 215.568-7617 Representina Lenden in PeMlylvuli~ iIld New Jersey Febnwy 2&, 1999 Dennis E. Myen 116 W, SpringviUe Ro~d BoIUna Springs, PA 17007.9740 TilDW'a S, Myen 116 W. SpringviUe Road Boilina Springs, PA t7007.9740 Re: Premises: I Pine Hill Avenue, MerthanlcsbWl, PA 17055 Loan No.: 0005185880 NOTICE OF INTENTION TO FORECLOSE We represent ContlMortp&e Corporation, the holder of the Mortgage on the above-referenced premises, who bereby advises that it will accelerate your Mortpge (demand payment in full) and pursue the foreclosure remedies permitted by the mortpge unless your loan delinquencies are cured as provided below. TInS FIRM IS A DEBT COLLECTOR A TIEMPTING TO COLLECT A DEBT. TInS NOTICE IS SENT TO YOU IN AN A TIEMPT TO COLLECT TIlE INDEBTEDNESS REFERRED TO HEREIN AND ANY INFORMA nON OBTAINED FROM YOU Wll.L BE USED FOR lHA T PURPOSE. IF YOU HAVE PREVIOUSLY RECEIVED A DI50IARGE IN BANKRUPTCY, TInS CORRESPONDENCE IS Nor AND SHOULD NOT BE CONSTRUED TO BE AN ATIEMPT TO COLLECT A DEBT, BUT ONLY ENFORCEMENT OF A LIEN AGAINST PROPERTY. You may dispute the validity of the debt or any portion thereof. lfyou do so in writing within thirty (30) days of receipt of this letter, this firm will obtain and provide you with written verification thereof; otherwise, the debt will be assumed to be valid Lilcewise, you may request the name and address of the original creditor if diJl'erem from above, ' The total delinquency, includina late and other charges is S14,188,51 for the montlu of4/J/98tbrough 1.11199 . Your failure to pay the delinquent amoun~ plus any additional monthly payment and late and other charges (includina any accrued interest) that may come due within the next thirty (30) clays. will result in the acceleration ofall sums due under your Mortgage. After acceleration occurs, a foreclosure action or any other remedy pennitled by your mortgage may be instituted To avoid the acceleration of your mortgage and subsequent fureclosure action, the delinquency mentioned above and any accrual thereto must be paid by CERTIFIED CHECK OR MONEY ORDER and received in our ollices at Sulte!lOO, Two Penn Center Plaza, Philadelphia, PA 19102, in or before thirty (30) days from the date oflhis letter, Please caU (215) 241-1711 for the exact amount required, You have the right to reinstate your mortgage after acceleration by fulfilling the conditions stated in your mortgage pertaining to such reinstatement. You may caU our office to discuss these conditions, Any future negotiations attempting to reinstate your loan or acceptance of any payment Jess than the full amount due shall not constitute a waiver by the mortgage holder of the acceleration unless agreed to in writing by the mortgage holder, You have the right to assen in the foreclosure proceedings the non.existence of a default or any other defense to acceleration and foreclosure. EXHIB\T A , .... .......... lAW'UNCI T. PKII1..AH IIAaCI.D N. IAI'I.AH- La.III. PUlDA. .......~ ~ rwa-.. 0, ICaeD -.. ..... DCII&AI "'~N.I'''' -....- -.......... CitltlI ,...... ~ LIlA A. 1IJ JrCIIeUmI' -..- ..."....,.,."..IMII- -ADMnIDDlrAANDIU -""/aur~'MaMII .....""""" FEDERMAN AND PHELAN ....... TWO "* CDnD ftJ.JA ~'4 l'ICD-I'" (21n14I.1711 'AI C:lln >>J"" ftUCaItD, all) .",.. INtDUP'I'C'Y 1'II.ICDPID (1l1l ""?l1t ...... 0PPIa 6<J '-"'....... llCMA.'" I_ CZlJ)8147" ... ...., OPPJCI JUmI"" IIHnY arna PI.AZ4 'If MADOON AVIHUI 'WUnOn'. ... ..., 11I1. ~'ID)1SMC na:lNOnCIlI SDft' '10 YOU IN AM 4TrIWT TO 01l.XT,. ....I---a IIPIIUD TO KDIIN NCDNffMlCltiCAtDlc.rADIIDP'IOW 'IOU W1IJ. II UIID POI. THAT PUIPDII. -- -.wi L CllXDWf February 16, 1999 DeMis E. Myers 1 Pine Hill Avenue Merchanicsburg, PA 17055 839 Bower Road Shermans Pale, PA 17090 Tamara S. Myers 1 Pine Hill Avenue Merchanicsburg, PA 17055 839 Bower Road Shermans Pale, PA 17090 Re: Premises: I.oan No.: 1 Pine Hill Avenue, Merchanicsburg, PA 17055 0005185880 NOTICE OF INTENTION TO FORF'.M'DSE We represent Contilllortgage Corporation, the holder of the Mortgage on the above-referenced premises, who hereby advises that it will accelerate your Mortgage (demand payment in fUll) and pursue the foreclosure remedies permitted by the mortgage unless your loan delinquencies are cured as provided below. THIS FIRM IS A DEBT COLLECTOR ATTEMPTING TO COLLECT A DEBT. THIS NOTICE IS SENT TO YOU IN AN ATTEMPT TO COLLECT THE INDEBTEDNESS REFERRED TO HEREIN AND ANY INFORMATION OBTAINED FROM YOU WILL BE USED FOR THAT PURPOSE. IF YOU HAVE PREVIOUSLY RECEIVED A DISCHARGE IN BANKRUPTCY, THIS CORRESPONDENCE IS NOT AND SHOULD NOT BE CONSTRUED TO BE AN ATTEMPT TO COLLECT A DEBT, BUT ONLY ENFORCEMENT OF A LIEN AGAINST PROPERTY. You may dispute the validity of the debt or any portion thereof. If you do so in writing within thirty (30) days of receipt of this letter, this firm will obtain and provide you with written verification thereof; otherwise, the debt will be assumed to be valid. Likewise, you may request the name and address of the original creditor if different from above. The total delinquency, including late and other charges is $14,188.51 for the months of 4/1/98 through 2/1/99. Your failure . FEDERMAN AND PHELAN By: FRANK FEDERMAN, ESQUIRE IDENTIFICATION NO, 12248 TWO PENN CENTER PLAZA, SUITE 900 PHILADELPHIA, PA 19102 (2151 563-7000 ATTORNEY FOR PlAINTIFF CONTIMORTGAGE CORPORATION ONE CONTIPARK, 338 SOUTH WARMINSTER ROAD HATBORO, PA 19040 COURT OF COMMON PLEAS CIVIL DIVISION Plaintiff TERM NO. 91,/9'10 ~ I..u- v. DENNIS E. MEYER TAMARA S. MEYER 116 WEST SPRINGVILLE ROAD BOILING SPRINGS, PA 17007-9740 CUMBERLAND COUNTY Defendant(s) CIVIL ACTION - LAW MORTGAGE PORECLOSURE NOTICE THIS IS AN ATTEMPT TO COLLECT A DEBT AND ANY INFORMATION OBTAINED WILL BE USED FOR THAT PURPOSE. You have been sued in Court. If you wish to defend against the claims set forth in the following pages, you must take action within twenty (20) days after this Complaint and Notice are served, by entering a written appearance personally or by attorney and filing in writing with the court your defenses or objections to the claims set forth against you. You are warned that if you fail to do so the case may proceed without you and a judgment may be entered against you by the court without further notice for any money claimed in the Complaint or for any other claim or relief requested by the Plaintiff. You may lose money or 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 TRUE COPY FROM RECORD CUMBERLAND COUNTY 2 LIBERTY AVENUE In TIlIItlmt'l1yWll8reof, I here unto set my hanltARLISLE, PA 17013 c1Ild the 98al 0/ sald Cour,t.,1t Carllsle. PI. (717) 249-3166 This, 5~) ;y ~ st~ l~ ?~ ... (L:..L- '. ....I.~.4.. Prothonotary . BAR ASSOCIATION ,,'nl tna b eel\h, ... lJ'Je nete I} ttUe af\u . tobea "- vJi\n\n pI} 0\ tne d "- --cet eO \ tecot .., CO" ned 0 ~E.v.\... oliglnal \ l'l/>.NO P FE.OE.f\~r>: . 1. Plaintiff is CONTIMORTGAGE CORPORATION ONE CONTI PARK , 338 SOUTH WARMINSTER ROAD HATBORO, PA 19040 2. The name(s) and last known address (es) of the Defendant(s) are DENNIS E. MEYER TAMARA S. MEYER 116 WEST SPRINGVILLE ROAD BOILING SPRINGS, PA 17007-9740 who is/are the mortgagor(s) and real owner(s) of the property hereinafter described. 3. Mortgagor(s) made, executed and delivered a mortgage upon the premises hereinafter described, which mortgage is recorded in the Office of the Recorder of CUMBERLAND County, as follows: Date Oricina1 Mortqaqee Book No. Paqe 10/13/97 KEYSTONE STATE 1411 138 MORTGAGE CORPORATION The Mortgage referred to herein was assigned as follows: Recorded Assiqned To Book No. Pace 3/2/98 PLAINTIFF 569 1116 4. The premises subject to said mortgage is described as attached. 5. The mortgage is in default because monthly payments of principal and interest upon said mortgage due 4/1/98 and each month thereafter are due and unpaid, and by the terms of said mortgage, upon failure of mortgagor to make such payments after a date specified by written notice sent to Mortgagor, the entire prinCipal balance and all interest due thereon are collectible forthwith. A copy of such notice is attached as Exhibit "A." , ~ FEDERMAN AND PHELAN Suite 900 Two Penn Center Plaza Philadelphia, PA 19102.1799 215.241-1711 Fax: 215-568-7617 Representing Lenders in PeruuylvanJa and New Jersey February 26, 1999 Dennis E, Myers 116 W, SpringviUe Road Boiling Springs, PA 17007.9740 Tamara S. Myers 116 W, Springville Road Boiling Springs. PA 17007.9740 Re: Premises: 1 Pille Hill Avenue, Meld1anIabWW, PA 17055 Loan No,: 0005185880 NOTICE OF INTENTION TO FORECLOSE We repleseDt ContIMo1tpge Corporation, the holder of the Mortgage on the above-tl!fen!nced premises, who bereby advises that it will accelerate your Mortgage (demand payment in full) and pursue the foreclosure remedies permitted by the mortgage unless your loan delinquencies are cured a.l provided below. 1HIS FlRM IS A DEBT COLLECTOR ATTEMPTING TO COllECT A DEBT. 1HIS NOTICE IS SENT TO YOU IN AN ATTEMPT TO COLLECT TIlE INDEBTEDNESS REFERRED TO HEREIN AND ANY INFORMA TlON OBTAINED FROM YOU WILL BE USED FOR 1HA T PURPOSE, IF YOU HAVE PREVIOUSLY RECENED A DISCHARGE IN BANKRUPTCY, 1HIS CORRESPONDENCE IS Nor AND SHOULD NOT BE CONSTRUED TO BE AN ATTEMPT TO COLLECT A DEBT, BUT ONLY ENFORCEMENT OF A LIEN AGAINST PROPERTY, You may dispute the validity of the debt or any portion thereof, !fyou do so in writing within thilty (30) days of receipt of this letter, this firm will obtain and provide you with written verification thetl!of; otherwise, the debt will be assumed to be valid Likewise, you may request the name and address of the original creditor if different from above, , The tola! delinquency, including late and other charges is $14,188.51 for the months of4/1/98 through 2/1/99. Your failure to pay the delinquent amount, plus any additional monthly payment and late and other clwges (including any accrued interest) that may come due within the next thirty (30) days, will result in the acceleration ofall sums due under your Mortgage. After acceleration occurs, a foreclosure action or any other remedy pennitted by your mortgage may be instituted To avoid the acceleration of your mortgage and subsequent foreclosure action, the delinquency mentioned above and any accrual thereto must be paid by CERTlFffiD CHECK OR MONEY ORDER and received in our offices at Suite 900, Two Penn Center Plaza, Philadelphia, PA 19102, in or befotl! thirty (30) days from the date of this letter, Plea.le call (215) 241.1711 for the exact amount required, You have the right to reinstate your mOrl8age after acceleration by fu1/iUing the conditions stated in your mOrl8age pertainin& to such reinstatement. You may call our office to discuss these conditions, Any future negotiations attempting to reinstate your loan or acceptance of any payment less than the full amount due shall not constitute a waiver by the mortgage holder of the acceleration unless agreed to in writing by the mortgage holder. You have the right to assert in the foreclosure proceedings the non-existence of a default or any other defense to acceleration and foreclosure. EXHIBIT A --- ""....... LAWIDICI T. PImLUf IIAaCLD N. lItAJlt.AH- ....... PUIIM,' ........ L ........... ~O.JCJIIGIQ -......... -...- ......... DUliPQaD -".W DIAICICD" ..... .. ....... LllAA.~ _LUDaDDN ,..,-.. ..../MtP .AMn'1IlII1I'AANIJ NI -"." Jaur IIAIUtJlN(J 'AIlI'H.. -.uTCO -........ -.u< l.\."""", FEDERMAN AND PHELAN ..... lOt 'I'WOPIJOIc:::IH1'DPIAA 1'IIlADIUWIA.',\ ItlCIJ.I'" '1111111.1111 'AX am JG.U,. TII.aCDPIII , (21J) M).'''' 1AHD11J'n:Y'TUIICXI'III(21J)J6I.1'I1' ...... ama '" ...", IIIIUICN MIDIA..4 IIOU e2l.nltl...,... NlWlDDTama """'... SI!:H1'Ily ames PlAZA 111 N4DDQI AVDUI W'!.!'1'MOHT, Hn' JIUIY GlIOI TIUCXJPID '(a) ~ nus HOnCIlS SDn'1'O YOU IN AM AnDCPT 10 <XIUJIC.T1'1II DmD'I'IDfrCUS III'DUD TO IIDIDf AHDAN'IDlPCUCA1JCIrIo.rAINID PIQIlf TOU WILL" usm POa 1HAT I'UUOII. February 16, 1999 Dennis E. Myers 1 Pine Hill Avenue Merchanicsburg, PA 17055 839 Bower Road Sh~~~ns Pale, PA 17090 Tamara S. Myers 1 pine Hill Avenue Merchanicsburg, PA 17055 839 Bower Road Shermans Pale, PA 17090 Re: Premises: Loan No.: 1 pine Hill Avenue, Merchanicsburg, PA 17055 0005185880 HOTICE OF IHTEIlTION TO FORECLOSE We represent Contillortgage Corporation, the holder of the Mortgage on the above-referenced premises, who hereby advises that it will accelerate your Mortgage (demand payment in fUll) and pursue the foreclosure remedies permitted by the mortgage unless your loan delinquencies are cured as provided below. THIS FIRM IS A DEBT COLLECTOR ATTEMPTING TO COLLECT A DEBT. THIS NOTICE IS SENT TO YOU IN AN ATTEMPT TO COLLECT THE INDEBTEDNESS REFERRED TO HEREIN AND ANY INFORMATION OBTAINED FROM YOU WILL BE USED FOR'l'HAT PURPOSE. IF YOU HAVE PREVIOUSLY RECEIVED A DISCHARGE IN BANKRUPTCY, THIS CORRESPONDENCE IS NOT AND SHOULD NOT BE CONSTRUED TO BE AN ATTEMPT TO COLLECT A DEBT, BUT ONLY ENFORCEMENT OF A LIEN AGAINST PROPERTY. You may dispute the validity of the debt or any portion thereof. If you do so in writing wi thin thirty (30) days of receipt of this letter, this firm will obtain and provide you with written verification thereof; otherwise, the debt will be assumed to be valid. Likewise, you may request the name and address of the original creditor if different from above. The total delinquency, inclUding late and other charges is $14,188.51 for the months of 4/1/98 through 2/1/99. Your failure VERIFICATION DANIEL w. PRATT hereby states that he is FORECLOSURE COORDINATOR of CONTI MORTGAGE CORPORATION mortgage servicing agent for Plaintiff in this matter, that he/she is authorized to take this Verifioation, and that the statements made in the foregoing civil Action in Mortgage Foreclosure are true and correct to the best of his/her knowledge, information and beliet. The undersigned understands that this statement is made subject to the penalties of 18 Pa. C.S. Sec. 4904 relating to unsworn falsification to authorities. /Jt\~ {J. (W, DATE: ~I~"J~~ I ' "- cr, >- cr; -:J [, " -, ,-- fi! " ,~ I).J_'"';. -} ():- . ~f ~-L .... , C... (")1__ T' ;:'.J I/} 0:. Il..'r. 1 li!t: :. ~ij ..cc j:. :.:.: JU_ l., "" '::3 c' CJ) u . 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 conta<:t one, the more chance you will have of stopping the sale. (See notice on page two on how to obtain an attorney.) YOU MAY STILL BE ABLE TO SAVE YOUR PROPERTY AND YOU HAVE OTHER RIQHTS EVEN IF THE SHERIFF'S SALE DOES TAKE PLACE. 1. be sold calling If the Sheriff's Sale to the highest bidder. (215) 563-7000. is not stopped, your property will You may find out the price bid by 2. sale if of your You may be able to petition the Court to set aside the the bid price was grossly inadequate compared to the value property, 3. The sale will go through only Sheriff the full amount due in the sale. happened, you may call (717) 240-6390. if the buyer pays the To find out if this has 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 proposed schedule of distribution of the money bid for your house will be prepared by the Sheriff not lat~r than thirty (30) days after the sale. The schedule shall be kept on file with the SHeriff and will be made available for inspection in his office. The schedule will state who will be receiving that money. The money will be paid out in accordance with this schedule unless exceptions (reasons why the proposed distribution is wrong) are filed with the Sheriff within ten (10) days after the filing of the proposed schedule. 7. You may also have other rights and defenses, or ways of getting your home back, if you act immediately after the sale. YOU SHOULD TAKE THIS PAPER TO YOUR LAWYER AT ONCE. IF YOU DO NOT HAVE A LAWYER OR CANNOT AFFORD ONE, GO TO OR TELEPHONE THE OFFICE LISTED BELOW TO FIND OUT WHERE YOU CAN GET LEGAL HELP. CUMBERLAND COUNTY ATORNEY REFERRAL CUMBERLAND COUNTY BAR ASOCIATION 2 LIBERTY AVENUE CUMBERLAND COUNTY COURTHOUSE CARLISLE, PA 17013 (717) 249-3166 (800) 990-9108 '- \l. (;; !I: ~ /- ,.. co --:><1; C LJJ. " ,_);';- ( ) ~-. -~ :.J ~,<: ~"- \ I..... "" ''''1-::' ~~.'f: 'n ..::"/j f:~' .':-, '.z rr" N I ... :% ,.,..11 L'; .JtJj l~ ::;. ..ld~ ,- .a ~ ".. en U 0' U ~ ,... \ll b. ~'( ~ ,- " CiJ ~~l <f' 1110 f.)::) ~.'! C", .~ \.-1 ;~~ \ l~ .'. .:.: '\.- !~ C'J'., " 'n ~:!n ~, N J% 111 ','1m .,....!t <-" ". ;::: . :~ u.. 0<< " O' :5 0 <:1' U \, J ". IN THE COURT OF COMMON PLEAS OF CUMBERLAND COUNTY, PENNSYLVANIA CONTI MORTGAGE CORPORATION PlaintIff CIVIL DIVISION vs. No. 99-1940 CIVIL TERM DENNIS E. MEYER, A/K/A DENN!S E. MEYER, SR. ':,W.J,RA S. r4EYER, AI K/ A TAMERA S, MEYER Defendants AFFIDAVIT OF SERVICE PURSUANT TO RULE 3129 COMMONWEALTH OF PENNSYLVANIA CUMBERLAND COUNTY SS: I, FRANK FEDERMAN, ESQ., attorney for CONTI MORTGAGE CORPORATION, hereby verify that on SEPTEMBER 2. 1999, true and correct copies of the Notice of Sheriff's Sale were served by certificate of mailing to the recorded lienholder(s), and any known interested party, see Exhibit "A" attached hereto, and the Notice of Sale was sent to defendant(s} on SEPTEMBER 2. 1999 by first class mail and certified mail return receipt requested, see Exhibit "B" attached hereto. 1~D~~ Attorney for Plaintiff Date: December 1, 1999 ~ . I I - , ie~\H z . " ';:.1 I ~j - ''',' t (. " n.i~. I ..i.:, . .'1 HiiH ~' . M I " , " 1.\. - , . f . '. , , , tli~H ,- J;.f J I II oz hlfi~fi JA b "''" a! SI 1!~iH ~ .n a ~~ '" i i! H f 1m ~ ~i~il ~n ~= !,Illil ~ II fi !J j I !if1i ! i j r ." R. I~ ~6ii~h r j I ~~ ihii~f ; :II )2" .. 1': S J~~ n !~di:i ;f ~ d~ji~l .. 0 r : .- .5 J U & j .: S j 'i JA;g ~!' I, t ! 'll CD i:" I~ ~ .. .a !i j ~ ~ r i !lJh~ . i a. E i - ~ 3 0 1; u -~j " 1l E ~ -;; ~ ~ Ii; :E - := .. ~ .: ~ 8 " . "- ;; i ~ ~@ @ H '" 3 E ~~ ;; 'J ~~ 0 .. '= ciif,r< 0"; '" ~ ~h -en << ~~ "'::C ~~ , 0._ gj~ ~ ~~ . Jl!<( ( CQ,. ~ ~ en . :> . :>r< '" . ::> <: 0 ~B ; O.!9 '5 3 ~ co ~~ :tiE '0 "'a '" ,.., ~ -0 ~ ~ ~ .... ,.., "-- ." 'OC_ ,.., gOj . 00 ;c>&f m '" -"- '(l) ~ Z H 2'" H ~~ .Il. '''' ~= en '" '" g'il : ci3 Fo If '" ~~ 0 ~ Z,> 3 0'> Z ~~ .... ~ .... M {!.a; r- .... .... .... or '" co '" ~ ~ ~ ~ '" ~ ~ " 2 !;1" d ~ .0 " ",::J "- ..... lli! 0:. ~ -. ~!l .Il.ll co "".... CO) c..-8 E ~ E "ec '" hell ~!l 0 " " "' I!) "- co Ol 0 C\J M .. "' a.!a "- ~ C\J M ~ ;!C'O c ~ ~ ~ ~ ~ ~ ...~ '" ::J a. , ; ", .0 lI'" Q. POSTMARK 011 DATE ....- -- .. --_. -_. _'4 _~ _ :7 '" :7 ""1.1/', } h ......,. :,:,.'./ : 1,(, I '" ,..'.. " "," 'I"',,, 1 ',. '. " ", ;~.m1're".,1Il' :; N 0 OoLI'(')II.....'.I4.I'O""l~',..:. ) , , e g f "' l!;, ~' tc a: "' ~ ~ ~ ~ li -'-- - - - -.- -- - -- - - - - - - - - - - - -- -.-' I '0 '" VI t;c..\.. :.... .1.:,,'& :;.,\, .1/ "'''''' -- -- - - - - - -.- -- --- - -- - --- -_. VI VI :r co '" VI VI .1l lI'" Q. ,,-:0.....,...,;, _, :u:.t..\, .h'. iJ/J ~,~:~~~ !.~~. ~vr lJ4 (,..L..... ~ ~:...:. I .'", ..;.,...) PS FORM 3800 US Postal Service Receipt for Certified Mail r.[!u". ,.0 >NSO ,114 ~ VI NOT fOIl.r':T~~~"T10.NAL YAll ,',\,,- POSTMARK OR DATE .~":'>", ,:';'~;';,:::'y "/,/ ~L'~~'LW / Ij!:.CEP! 5[r.\1([ , , L"- Olrr, :., 1_: ~,,''', ~(< ~ =. Ie;'"".. ,.- _~.~,~< ....,'~ ~<'.!" :;ENT TO L'.:.. l.\.....\ :). .'i~'. 't :.~.:. .~J ...,..\ 'J. A. .r.;'~..\ ..). i".J!."""'t:.J ,-:r. ~ ':'.'. i..., J J '.;.\~~.. I ;,_.;. ..' ..:..... ...'.~~' i..... ..n..:....__....., l'.~ ~.. ;..~ f))1-t PS FORM 3300 US Postal Service Receipt for Certified Mail "' Z ~ 0: o ~ ~ . Conti mortgage Corporation .vs- Dennis E. Meyer, nlkla Dennis E. Meyer Sr and Tamara S. Meyer Nkla Tamera S. Meyer I n the Court of Common Pleas of Cumberland County, Pennsylvania No. 99.1940 Civil Term Dawn L. Kell, Deputy Sheriff, who being duly sworn according to law, suys on September 30, 1999 ul 2: 18 0 'clock P.M. EDST, she postcd II copy of Reul Estate Writ Notice Poster and Description, in the above entitled action upon the property of Dennis E. Meyer Sr. and Tamara S. Meyer located at I Pine Hill Road, Mechanicsburg, Cumberland County, Pennsylvania according to law. Brian M Barrick, Deputy Sheriff, who being duly sworn IIccording to law, says on August 30, 1999 at 8:55 o'clock A.M. EDST, he served true copy of real cstate Writ Notice and Description, in the above entitled action upon one of the within named defendants to wit: Dennis E. Meyer Sr, by makin gknown unto Dennis Meyer at 7073 Carlisle Pike, Lot 132, Carlisle, Cumberland County, Pennsylvania, its contents and at the same time handing to him personally the said true and aUested copies of the same. Brian M. Barrick, Deputy Sheriff, who being duly sworn according to law, says on August 30, 1999 at 8:55 o'clock 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: Tamara S. Meyer, by making known unto Dennis Meyer ut 7073 Carlisle Pike, Lot 132, Carlisle, Cumberland County, Pennsylvania, its contents and at the same time handing to him personally the said true and aUested copies of the same. Dawn L.Kell, Deputy Sheriff, who being duly sworn according to law, says on September 28, 1999 at I :38 o'clock P.M. EDST, she served II copy ofRcal Estate Poster, in the above entitled action upon one of the within named defendants to wit: Dennis E. Meyer Sr, by making known unto Dennis Meyer Jr at 7073 Cllrlisle Pike, Lot 132, Carlisle, Cumberland County, Pennsylvania, its contents and ntthe same time handing to him personally the said true and attested copies of the same. Dawn L. Kell, Deputy Sheriff, who being duly sworn according to law, says on September 28, 1999 at I :48 o'clock P.M. EDST, she served n copy of Real Estate Poster, in the above entitled action upon one of the within named defendants to wit: Tamara Meyer, by m akin gknown unto Dennis Meyer, Jr, at 7073 Cnrlisle Pike, Lot 132, Carlisle, Cumberland County, Pennsylvania, its contents and ntthe same time handing to him personally the said true and attested copies of the same. R, Thomas Kline, Sheriff, who b 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 pendcncy of the action to one of the within named defendants to wit: Dennis E. Meyer aka Dennis E, Meyer, Sr by first class mail to his last known address 7073 Carlisle Pike Lot 132, Carlisle, Pennsylvnnia, This letter was mailed under the date of October I, 1999 and never returned to the Sheriffs Office. R. Thoma<, Kline, Sheriff, who being duly sworn according to Inw, says he served the above Real Estate Writ Notice Poster and Description in the following manner: The Sh~riff mailed a notice of the pendency of the action to onc of the wihtin named defendants to wit: Tamara S. Meyer aka Tamers S. Meyer by first class mail to her last TITLE REPORT THE PREMISES ENDORSED HEREON ARE SUBJECT TO THE FOLLOWING ITEMS, WHICH WILL BE EXCEPTED IN THE POLICY UNLESS SATISFACTORY EVIDENCE PERMITIING THEIR REMOVAL IS PRODUCED. SHERIFF SALE NO. 36 Held Wednesday, December 8, 1999 Date: December 22, 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 water or sewer. Receipts to be produced if services are lienable. MECHANICS' AND Possible un filed 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 . 2000. and recorded . 2000. in Cumberland County Deed Book . Page RECITAL: BEING THE SAME PREMISES which George W. Walker. also known as George W. Walker. Sr.. and Marion Smith Walker. his wife. by Deed dated October 19. 1995 and recorded October 31. 1995 in the Office of the Recorder of Deeds in and for Cumberland County at Carlisle, Pennsylvania in Deed Book 130, Page 456 granted and conveyed to Dennis E. Meyer. Sr.. and Tamera S. Meyer, his wife, OTHER EXCEPTIONS: I. The identity and legal competency of parties at the closing of this title should be established to the satisfaction of the closing attorney acting for this Company. 2. Rights or claims of parties in possession, if any, other than the owner. 3. Unrecorded easements, discrepancies or conflicts in boundary lines. shortage in area and encroachments which an accurate and complete survey would disclose, 4, Payment of State and local Real Estate Transfer Taxes, if required, 5. Public and private rights in the roadbed of 50 feet wide Pine Hill Avenue and in the roadbed of 50 feet wide White Birch Circle as shown on the Final Subdivision Plan for Shirley L. Walker recorded in Cumberland County Plan Book 45, Page 98. 6. Conditions, easements and restrictions as shown on or set forth on the Final Subdivision Plan for Shirley L. Walker recorded in Cumberland County Plan Book 45, Page 98, including, a 50 foot setback line from the southern dedicated right-of-way line of Pine Hill A venue and White Birch Circle, 35 foot setback line from the rear property line and a 20 foot wide utility and drainage easement along the southern property line.. 7. Condilions. eusements ,md reslriclions us shown on or us set forth on the PI un of While Birch Furms recorded in Cumberlund County PI un Book 33, Puge 127. 8. Mortguge in the umount of $72, 100.00 given by Dennis E. Meyer, Sr. und Tumera S. Meyer 10 Northwest Consumer Discount Company, doing business us Preis Consumer Discount Company dated OClober 30, 1995 und recorded October 31 1995 in Cumberlund County Mortgage Book 1288, Page 1069. 9. Mortguge in the umount of $132,000.00 given by Dennis E. Meyer. Sr., and Tumera S. Meyer, his wife to Keystone Slule Mortguge Corporalion dated October 13, 1997 und recorded October 20, 1997 in Mortguge Book 1411. P,lge 138. Suid Mortgage wus ussigned 10 ContiMortgage Corporution duted Oclober 13. 1997 und recorded OClober 20, 1997 in Miscelluneous Record Book 569, Puge 1116, Compluint in Mortguge Foreclosure filed by Conti Mortgage Corporation as Pluintiff against Dennis E. Meyer and Tamera S. Meyer on April 5, 1999 in the Office of the Prolhonotary of Cumberland County to File No. 99-1940. Default judgment enlered August 25,1999 in the amounl 01'$161,073,61. 10. Mechanics lien filed April 16, 1996 by George Bazquez, First Class Building und Remodeling, as Plaintiff uguinst Dennis E. Meyer, Sr., Tammie Meyer, and Tumera S. Meyer as Defendunts in the Oftice of the Prolhonolury of Cumberlund Counly 10 File No, 96-2076 in the amount 01'$15, 626.98. II. Delinquent real eSlate laxes turned over to the Cumberllllld County Tax Claim Bureau, the amounl being due as of the dule of this report $1,163.89. 12. Subject to Developer's Agreemenl between George W. Walker lllId Mary A. Walker, his wife and the Township of Silver Spring dated September I, 1983 and recorded November 2, 1983 in Miscellaneous Record Book 290, Page 663. 13. Rights granled 10 Bell Telephone Company by Agreement recorded in Miscellaneous Record Book 164, Page 249. 14, Righls granted 10 Pennsylvania Power and Lighl Company by Instrument recorded in Miscellaneous Record Book 179, Page 933. 15. Salisfaclory evidence to be produced that proper nOlice was given to the holders of all liens and encumbrunces inlended 10 be dives led by subject Sheriff Sale. 16. Real estate taxes accruing on und after January 1,2000 not yet due and payable. It is to be noted that no search of Domestic Relations Records has been made to determine support arrearages regarding House Bill 1412, Act 58 of 1997, nor has any sellrch been made for environmental liens in Federal District Court. LS'A. Robert G. Frey, Agenl NOlC: This Title Report shall not be valid or in ng until countersigned by an authorized signatory. REAL ESTATE SALE NO. 38 Witt No, 99-1940 Civil ConUmortgage CorpornUon v.. Dennl' E, Meyer, AliI! A DennIs E. Meyer. Sr.. TamlU'o S. Meyer. A/KIA Tnmern S, Meyer Atty.: Frank Federman DESCRIPTION ALL 'mAT CERTAIN tract o( land situate In the Township of SUver Spring, Cumberland County. Penn- sylvania, more particularly bounded and described as (oUowa, to wit: BEGINNING ot n point on the South side o( Pine Hili Road. at the comcr of Lot No. 84A as shown in the hereinafter menUoned plan of lols; Ulcoce along the South side of Pine Hili Road In an ea.terly dlrecUon on a curve to the right having a radius of two hundred and fiIty.Cour hun- dredths 1200.54) feet. an arc distance o( elghty.seven and (orly.elght hun- dredths (87.48) feet to a point; thence conUnufng along the South side of Pine Hill Road. due East thirty-nine and sixteen hundredths (39.161 feet to a point: thence due South two hundred seventy and twenty-six hundredths (270.261 feet to a point: thence along land now or fonnerly of John Neibert, South 84 degrees 50 minutes West one hundred thirty and eighty-seven hundredths (130,87) (eel to a point at the corner oCLotNo. 84A aforesald: thence along Une of saJd Lot No. 84A due North one hundred seventeen and sixty.four hundredths (117.641 feet to an lron plo: thence conUnulog along sald Lot No. B4A North 2 degrees 31 minutes 14 sec. onds East one hundred focty.nve and seventy-six hundredUls (145.76) feet to a polot on Ule South side of Pine Hill Road. the place of BEGINNING. HAYING thereon erected a mobile home wtth attached building and containing .ao acres. BEING Lot No. 84 In the final subdlvtslon plan oCShlrley A, Walker. dated January 26, 1984 and re. corded in the Recorder's Office In and for Cumberland County, Pennsylva- nia In Plan Book 45. page 98. TAX PARCEL #38-14,0847.065, TITLE TO SAID PREMiSES is VESTED IN Dennis E. Meyer. Sr. and Tarnera S. Meyer. his wife, by Deed from George W. Walker. also known as George W. Walker. Sr.. and Marion Smith Walker, his wife. dated 10/19/95. recorded 10/31/95, In Deed Book 130. Page 456. THE PATRIOT NEWS THE SUNDAY PATRIOT NEWS Proof of Publication UnderAct No. 58J. Aoomued MaV 16, 191'1 Commonw'llIh 01 Plnnlylvlnll, County 01 Dluphln} II Michael Morrow being duly sworn occording to law, deposes and soys: That he Is the Assistant Controller of THE PATRIOT.NEWS CO.. a corporation organized and existing under the laws of the Commonwealth 01 Pennsylvania. with i1s principal office and place 01 business at 812 to SlS Market Street. In the City 01 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 SIS Market Street, In the City, County end State eforesald; that THE PATRIOT.NEWS and THE SUNDAY PATRIOT. NEWS were established March 4th. 1854. and September 181h. 1949, respectively, end ail have been conllnuously published ever since; That the printed notice or publication which Is securely attached hereto Is exacliy as printed and published In their regular dally and/or Sunday and Melro editionsflssues which appeared on the 26th day of October and the 2nd and 9th day(s) 01 November 1999. That neither he nor said Company Is Interested in the subject mailer of said printed notice or advertising. and that all of the allegations of this statement as to the time. place and character of publication are true; and That he has personal knowledge of the lacts aforesaid and Is duly authorized and empowered 10 verify Ihls statement on behalf of The Patriot. News Co, aforesaid by virt e and pursuant to a resolulion unanimously passed and adopted severally by the stockholders and board of directors 01 the said Company and subsequenliy duly recorded In the office for the Recording of Oeeds In and for said County f auphi(1ln Miscellaneous Book 'M'. Volume 14. Page 317. '-',.\",1: RW I!8TATI! SALE No. 38 '.:'."~No."1~ .,.', '"' .ClvII~,^" . ',. ..rwp-.,-_--.. ..: " ....^':.:' \"" ...... "l I~ >" ):,i';~1 ,&~ .o!ll -'AIKIN 'I"""" 'E"". , ',.,.., ',' ',""Ueq , nla, '1~:,' \'.'.:'.Tam8I'8S.' , ,AJrrJA . .-,. "',1M\InI S; r , , .'~"A!lY: Frank Federman , '", 1'.DESCRIPTlON ' Au.',:tHAr. CERTAIN tract.oIland 1IIuatlI' ""1I1e ',TOWllIhIp of "SlIv8r Spring. '''-....._......~Ia, mote CUtnIle'...N~,and __ as par1fculalfywll:" ,', ,"',., foIlow8.to/ '<:.'..'.;, .'~";; .," BEGINNING at:. polnt on II1e ,South aide 01 PIne Hili Road, at II1e comer of Lot , Nci.'84A'u'.-ln:'Ihe,h8relnafter meriUOlled pIaIj:of fo1s:_ along the . . . south 'sldlirol;jpjne',HIU.Roadm en Ler' a ReCe1pt for Advert1B1ng Coat ' reOuot\. 'cu 1O'lherlght , =-t"~ hU::red and,fifty. )f THE PATRIOT.NEWS and THE SUNDAY PATRIOT,NEWS. newspapers of general clOU~'; , :'01 ~i!~~)~~~;'i Ipt of the aforesaid notice and publication costs and certilles that the same have ',=:-IdlhI, (87m;;' tOa:,POln~ thence THE PATRiOT. NEWS CO, ' '~"alOlIlI"dfaSou1h8lde,of PIna , ~RoilCl"due~~Eut 'thlrty.nlne ancl : .," "ii11111;;;{rIdlIii;l39.18).feoItoapolnt: 'lIiiiI1Cit'''''''\80lllh'two' hundred _nly 'llrid,~..I",'hu.ldredlhs(270,28) Iget to B polnij. thence along .land now or formerly of ,John, Neibert, South 84 degrees SO ,minutes West one hundred thirty "ancl"','elghty.seven hundredths (lSO.87)leeno a;'90lnt at the corner of Lot No.'!l4A'8!orerald; thence elong line of'"..k1 Lot,"No. 84A due North one hundr.d':;':".~nle9n, and slxty.fou~ 'hUnd<O\l1!il'(117.ll41 feet to en Iron C, thence' =.ln9 elong said Lot No, A North 2~ 31 minutes 14 seconds Ess1 clMl1iin3r~d fortY.flve end seventy. 81x h"......... (145 76) feel to e point on theQ~~;~e of' Pine Hili Rond, the pIeCe of egGINNING. ' bite ",'HAVlN, G thereon, erectbUedlldalngmOand home..,'Wlth el1ached qonlaln~ ,80 acrea. 54 In tile flnat ,BEING; loti No.ol Shlrl~ A. Walker. SU......."'n pan .'ij' rded In '~-t~''l'_- ery 2" 1984 ar. reco uo - _.u .t Offl In end lor Ih8 'Reoorde~s , ce sylvania In Plan Cumberland County, Pann Book 45, pege g~. -085 , TAX PARTCOIEL SA 4.orFiEMIS'ES IS ! T'TLE Sand VESTED IN Dennis E Meyer, r.. . hi '.e by Deed from Tamara S. Meyer" S WII' . 8S G~e George W. Walker, also kn~lth Walker. W, Walker. Sr" and Merlon -"rdiid 10131/ his wife, dstea 10/19/95, r"458 95, In Deed Book 130, Page , PUBLICATION COPY SALE 1#36 Sw .D. NolJ.ial scal~ Terry l. flllsscll, Nol~ Plltl Hillw,burg, Diluptllfl Co. y My Co:nll,nslon t~,JirC3 JtJno G, 2002 Memcer, PennSYlvar:l<l AssQ{l"lIon cMyJ~oommlssion expires June G, 2002 CUMBERLAND COUNTY SHERIFFS OFFICE COURTKlUSE CARLISLE, PA. 17013 Statement of Advertisina Costs To THE PATRIOT.NEWS CO,. 0" For publishing the notice or publication attached hereto on the above stated dates Probating same Notary Feels) Total $ $ $ 365.06 1.50 366,56 8y,............,............,........,................................ .... -....""leq .. ... - uo awwnuow . oa --~-- NllIl .. -IH> __ t loe.oop .:~ 1101 U_oq -...... I:lUOIn '1101 n '81 PUI oc: 'lION U(~p fHU 'v eUJn oa"SI__ ~ OOUIrtt,p cu. uw · "'- u"'.... -11"810__ ~noo~:E PATRIOT NEWS 01 .... (linn) ~~.UNDAY PATRIOT NEWS 1UfI::: Proof of Publication ~ . 01 IIHtj Under Act No.587. AODroued May 16. 1929 =: nWlalth 01 Penneylvanla, Counly 01 Dauphin) II llOUOtA ' sworn according to low, deposes and says: jO "'!d THE PATRIOT.NEWS CO., a corporation organized and existing undar tha laws 1lUlI:--C: a, with its principal ollice and place 01 business al 812 to 818 Market Slreet, In .. _1 uphln. State of Pennsylvania, owner and publisher of THE PATRIOT.NEWS and AlM-JO,1IlGlJ Ipapars of general circulation. printed and published at 812 to 818 Market Street, .1UIWnUOW 1; that THE PATRIOT.NEWS and THE SUNDAY PATRIOT.NEWS were established 'NNID38 th, 1949. respectively, and ait have been continuously published ever since; , 1lUlI:'::: bllcation which Is securely attached hereto Is exaclly as printed and published In 'OlocIsuutd I Met,o edillons/lssues which appeared on the 28th day of October and the 2nd P9181ll/8 JlU8/ That neilher he nor said Company is Interested in the subject matter 01 said 30 .I.VHJ. i1V It all 01 the allegations 01 this statement as to the time. place and character of edge of the facts aforesaid and Is duly authorized and empowered to verify this ews Co. aforesaid by virt e and pursuant to a resolution unanimously passed and 's and board of directors of the said Company and subsequentiy duly recorded in 3 in and for said County f auphi(1 in Miscellaneous Book "M". Sw ~ 's 18t~ Novem~.D' z;?;; 4~ v.u!/ J' , OTA PU L1C NolJri:JlSCill Terry L Russell, Not.:! PlitT Halw,lJurg. Dauphin Co y My Co:nrr,I:iSlon E~pirf::; Juno 6, 7002 Member, PennsYIVdi1!;l fl!;50(1.)!lon <My>'commission expires June 6, 2002 CUMBERLAND COUN1Y SHERIFFS OFRCE OOUFmOUSE CARLISLE, PA. 17013 Statement of Adverlisinll 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 $ 365.06 1.50 366.56 Publisher's Receipt for Advertising Cost THE PATRIOT.NEWS CO" publisher 01 THE PATRIOT.NEWS and THE SUNDAY PATRiOT-NEWS, newspapers 01 general circulation. hereby acknowiedge receipt of the aforesaid notice and publication costs and ce,tilles that the same have been duly paid, THE PATRIOT-NEWS CO. By........,....................................."....."..,.."...... j " , "I Illl' I, 'C IIlllc uluugh uf Carltslc in the County and State aforesaid, was established January 2, 1952. and designated by the local courts as the official legal periodical for the publication of alllcgal notices, and has, since January 2, 1952, been regularly issued weekly in the said County, and that the printed notice or publication attached hereto is exactly the same as was printed in the regular editions and issues of the said Cumberland Law Journal on the following dates, viz: OCTOBER 22. 29, NOVEMBER 5,1999 Affiant further deposes that he is authorized to verify this statement by the Cumberland Law Journal, a legal periodical of general circulation, and thaI he is not interested in the subject matter of the aforesaid notice or advertisement, and that all allegations in the foregoing statements as to time, place and character of publication arc true, REAL ESTATE lIAI.I!: NO. 36 ~/l Rog r M. Morgenthal, Editor Wrtl No. 90. HHO ('110'11 Contlmonl{age Corporallon vs, SWORN TO AND SUBSCRIBED before me this ~day of NOVEMBER. 1999 OennJs E. Meyer. A/KIA DennJs E. Meyer. Sr.. Tamara S. Meyer. A/K/A Tamera S, Meyer Atty.: Frank Federman DESCRIPTION ALL 'mAT CERTAIN tract of land sUuate In the Township of SUio'er Spnng. Cumberland COunty, Penn- , sylvanJa. more partIcularly boUnded f and descrtbed as [cHows. to Wit: I BEGINNING at a point on the I South side of Pine HtlI Road. at 111e corner oCLot No. 84A as shown In 111e hereinafter menUoned plan of lots: thence along the South side of Pine HUl Road In an easterJy d/recUon on a curve to the light havJng a radius of two hundred and nny-four hun- dredths (200,54) feel. an arc dtslance of eIghty-seven and (orty-eJght hun- dredths (87,48) feet toa potnt: thence conUnuJng along the South side of Pine HJIJ Road, due East thlrty-nJne and sixteen hundredths (39.16) feet to a point: thence due South two hundred seventy and twentY-Six hundredths (270,26) feet to a poInt: thence along land now or formerly of John Netbert. South 84 degrees 50 mJnutes West one hundred thirty and etghIY'sc:ven hundredths (130,87) feel to a poInt at the cOrner of Lot No. 84A aforeSaid: thence along line of silld Lot No. 84A due North one hundred seventeen and sixty-four hundredths (117.64) feet to an Jron pIn: thence conUnuJng along said Lot No. 84A North 2 degrees 31 rnJnutes 14 sec- onds East one hundred forty-five and seventy-six hundredths (145.76) feel to a potnt on the South side of Pine HtII Road, the place of 8EGlNNING. , 1 HAVINC thereon erected, a mobtJe ;, home wtth attached buildIng and contafnJng .80 acres. BEING LoI No, 84 In the final subdJvfslon plan of ShIrley A. Walker. dated January 26, 1984 and re- corded in the Recorder's Office In and for Cumberland County, Pennsylva- nIa tn Plan Book 45, page 98. TAX PARCEL #38-14,0847,065, TITLE TO SAID PREMISES IS VESfED IN Dennis E, Meyer. Sr. and Tamern S. Meyer. his Wife, by Deed from George W. Walker. also known as George W. Walker. Sr., and Marlon Smith Walker, his Wife. daled 10/19/95. recorded 10/31/95, tn Deed Book 130, Page 456, rARI lSEAl lOt~ E, SNYDER. Notary PubUe Carliole ~~. Cumborland Caunty, PA My Commflllon e.p',e. Mo~h 5, 200' \ , I 1-.. , . ' CONTIMORTGAGE CORPORATION CUMBERLAND COUNTY COURT OF COMMON PLEAS CIVIL DIVISION VB. DENNIS E. MEYER, A/K/A DENNIS E, MEYER, SR. TAMARA S. MEYER, A/K/A TAMERA S. MEYER NO. 99-1940 CIVIL TERM AFFIDAVIT PURSUANT TO RULE 3129 (Affidavit No.1) CONTIMORTGAGE CORPORATION, Plaintiff in the above action, by its attorney, FRANK FEDERMAN, 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 1 PINE HILL AVENUE. MECHANICSBURG. PA 17055, 1. Name and address of Owner(s) or reputed Owner(s) : ~ LAST KNOWN ADDRESS (if address cannot be reasonably ascertained, please so indicate) DENNIS E. MEYER. A/K/A DENNIS E. MEYER. SR. 7073 CARLISLE PIKE. LOT 132 CARLISLE. PA 17013 7073 CARLISLE PIKE. LOT 132 CARLISLE. PA 17013 TAMARA S. MEYER. A/K/A TAMERA S. MEYER 2. Name and address of Defendant(s) in the judgment: NAME LAST KNOWN ADDRESS (if address cannot be reasonably ascertained, please so indicate) SAME AS ABOVE 3. Name and address of every judgment creditor whose judgment is a record lien on the real property to be sold: NAME LAST KNOWN ADDRESS (if address cannot be reasonably ascertained, please so indicate) NONE 4. Name and address of the last recorded holder of every mortgage of record: NAME LAST KNOWN ADDRESS (if address cannot be reasonably ascertained, please so indicate) NORTHWEST CONSUMER DISCOUNT COMPANY D/B/A PREIS 32 WEST MAIN STREET MECHANICSBURG, PA 17055 ,. ~ 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 MAY STILL BE ABLE TO SAVE YOUR PROPERTY AND YOU HAVE OTHER RIGHTS EVEN IF THE SHERIFF'S SALE DOES TAKE PLACE. l. be sold calling If the Sheriff's Sale to the highest bidder. (215) 563-7000. is not stopped, your property will You may find out the price bid by 2. You may be able to petition the Court to set aside the sale if the bid price was grossly inadequate compared to the value of your property. 3. The sale will go through only Sheriff the full amount due in the sale. happened, you may call (717) 240-6390. if the buyer pays the To find out if this has 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 tj'e Sheriff gives a deed to the buyer. At that time, the buyer may bLing legal proceedings to evict you. 6. You may be entitled to a share of the money which was paid for your house. A proposed schedule of distribution of the money bid for your house will be prepared by the Sheriff not later than thirty (30) days after the sale. The schedule shall be kept on file with the SHeriff and will be made available for inspection in his office. The schedule will state who will be receiving that money. The money will be paid out in accordance with this schedule unless exceptions (reasons why the proposed distribution is wrong) are filed with the Sheriff within ten (10) days after the filing of the proposed schedule. 7. You may also have other rights and defenses, or ways of getting your home back, if you act immediately after the sale. YOU SHOULD TAKE THIS PAPER TO YOUR LAWYER AT ONCE. IF YOU DO NOT HAVE A LAWYER OR CANNOT AFFORD OnE, GO TO OR TELEPHONE THE OFFICE LISTED BELOW TO FIND OUT WHERE YOU CAN GET LEGAL HELP. CUMBERLAND COUNTY ATORNEY REFERRAL CUMBERLAND COUNTY BAR ASOCIATION 2 LIBERTY AVENUE CUMBERLAND COUNTY COURTHOUSE CARLISLE, PA 17013 (717) 249-3166 (800) 990-9108