HomeMy WebLinkAbout99-03031FEDERMAN
B
FRAANKNFEDERMANr ESQUIRE
By: ATTORNEY FOR PLAINTIFF
IDENTIFICATION NO. 1224 900
TWO PENN CENTE , PAPL19102 SUITE COURT OF COMMON PLEAS
PHILADELPHIA,
215 563-7000 CIVIL DIVISION
GE CAPITAL MORTGAGE SERVICES, INC.
4680 HALLMARK PARKWAY
SAN BERNARDINO, CA 92407 TERM
Plaintiff NO q v ? I
V.
CUMBERLAND COUNTY
GARY DAVIS, DAVIS
A/K/A GARY B.
53B NORTH BA T 17013T
CARLISLE,
Defendant(s)
CIVIL ACTION - LAW
MORTGAGE FORECLOSURE
NOTICE
THIS IS AN ATTEMPT TO COLLECT A DEBT AND ANY
USED FOR THAT PURPOSE
INFORMATION OBTAINED WILL BE .
ou wish to defend against the
action
you have been sued in court. If Y
es, youaint and must take Notice are
claims set forth in the
served, by entering afterwthispaCompfersonally or by
within twenty (20) day written appearance p our defenses or
attorney and filing in writing with a the inst court you. yYou are warned
? objections to the claims set forth ag her
so the case may proceed without you and a
that if you fail to do ainst you by the court without furt
other
judgment may be entered a9 the Complaint or for any
claimed in You may lose money
notice for any money nested by the Plaintiff.
claim or relief the
ty or other APER rights TO important to you. E IF YO
CANNOT AF HONE THE OFFICE
YOU SHOULD TAKE THIS P YOURYOUWCAN GET LEGAL HELP U DO NO
FORD WHERE ONE, GO TO OR TEL EP
or HAVE A properLADYER OR
SET FORTH BELOW TO FIND OUT
CUMBERLAND COUNTY
CUMBERLAND COUNTY BAR ASSOCIATION
2 LIBERTY AVENUE
CARLISLE, PA 17013
(717) 249-3166
1. Plaintiff is
GE CAPITAL MORTGAGE SERVICES, INC.
4680 HALLMARK PARKWAY
SAN BERNARDINO, CA 92407
2. The name(s) and last known address(es) of the Defendant(s)
are
GARY DAVIS,
A/K/A GARY B. DAVIS
538 NORTH PITT STREET
CARLISLE, PA 17013
who is/are the mortgagor(s) and real owner(s) of the
property hereinafter described.
3. On 5/19/98 mortgagor(s) made, executed and delivered a
mortgage upon the premises.hereinafter described to CRUSADER
BANK, FSB which mortgage is recorded in the office of the
Recorder of CUMBERLAND County, in Mortgage Book No. 1458,
Page 466. PLAINTIFF is now the legal owner of the mortgage
and is in the process of formalizing an assignment of same.
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 1/1/99 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 $78,472.28
Interest 2,559.60
12/19/98 through 5/1/99
(Per Diem $18.96)
Attorney's Fees 3,923.00
Cumulative Late Charges 61.70
5/19/98 to 5/1/99
Cost of Suit and Title Search 550.00
Subtotal 85,566.58
Escrow
Credit 0.00
Deficit 0.00
Subtotal
TOTAL
0.00
$85,566.58
7. The attorney's fees set forth above are in conformity with
the Mortgage documents and Pennsylvania Law, and will be
collected in the event of a third party purchaser at
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. The Temporary Stay as provided by the Homeowner's
Emergency Mortgage Assistance Program, Act 91 of 1983,
has terminated because either:
(i) Defendant(s) have failed to meet with the Plaintiff or
an authorized Credit Counseling Agency in accordance
with Plaintiff's written Notice to Defendants, a true
and correct copy of which is attached hereto as Exhibit
"Bn. or
(ii) Defendant(s) application for assistance has been
rejected by the Pennsylvania Housing Finance Agency.
10. Pursuant to the Fair Debt Collection Practices Act, 15
U.S.C. § 1692 et seq. (1977), Defendant(s) may dispute
the validity of the debt or any portion thereof. If
Defendant(s) do so in writing within thirty (30) days
of receipt of this pleading, Counsel for Plaintiff will
obtain and provide Defendant(s) with written
verification thereof; otherwise, the debt will be
assumed to be valid. Likewise, if requested within
thirty (30) days of receipt of this pleading, Counsel
for Plaintiff will send Defendant(s) the name and
address of the original creditor if different from
above.
WHEREFORE, PLAINTIFF demands an in rem Judgment against the
Defendant(s) in the sum of $85,566.58, together with interest
from 5/1/99 at the rate of $18.96 per diem to the date of
Judgment, and other costs and charges collectible under the
mortgage and for the foreclosure and sale of the mortgaged
property.
/s/ Frank Federman
FRANK FEDERMAN, ESQUIRE
Attorney for Plaintiff
DDDDEMQPA6_N000102
March. 24,• 1999
GE Capital
GE Capital Mortgage Services, Inc.
A UnitNQ CEEIPFic ZKEN71?Q)J CSQ7rRORECLOSE
16801P:7IDR,'EAA1rEayLEtAEFna?:vHi?'T•Appb0p03 OF PA
ACT NO. 6 OF 1974. (READ BOTH
PAGES OF THIS NOTICE CAREFULLY.)
GARY DAVIS
538 N PITT STREET
CARLISLE, 17013
RE: GE LOAN # 0022082440
PROPERTY 538 N PITT STREET CARLISLE, PA 17013
MORTGAGEE: G.E. CAPITAL MORTGAGE SERVICES
We represent GE Capital Mortgage Services, Inc. ("GECMSI" the holder of a
mortgage on your property located at: 538 N PITT STREET, CARLISLE, PA which
mortgage is in serious default because you have not made the monthly
payments of $617.11 for 1 months and/or because N/A. Late
charges (and other charges) have also accrued of $30.85. The total
amount now required to cure this default, or in other words, get caught up
in your payments as of the date of this letter, is $1,882.18
You may cure this default within THIRTY (30) days of this letter by paying
the above amount of $1,882.18, plus any additional monthly payments and
late charges (and other charges) which may fall due during this period.
Such payment must be made in the form of a cashier's check, certified
check, or money order, and sent to 2000 West Loop South, Suite 1300,
Houston, TX 77027.
If you do not cure the default within THIRTY (30) days, we intend to
exercise our right to accelerate the mortgage payments. This means that
whatever is owing on the original mortgage amount borrowed will be
considered due immediately, and you may lose the chance to pay off the
original mortgage in monthly installments. If full payment of the amount
of default is not made within THIRTY (30) days, we also intend to instruct
our attorneys to start a lawsuit to foreclose your mortgage property.
If the mortgage is foreclosed, your mortgage property will be sold by the
Sheriff to pay off the mortgage debt. If you cure the default before we
begin legal proceedings against you, you will still have to pay the
reasonable attorney's fees actually incurred up to $50.00. However, if
legal proceedings are started against you, you will have to pay the
reasonable attorney's fees even if they are over $50.00. Any attorney's
fees will be added to whatever you owe us, which may also include our
reasonable costs. If you cure the default within the THIRTY(30) day
period, you will not be required to pay attorney's fees. YOU HAVE THE
RIGHT TO REINSTATE AFTER ACCELERATION AND THE RIGHT TO ASSERT IN THE
FORECLOSURE PROCEEDINGS THE NONEXISTENCE OF A DEFAULT OR ANY OTHER DEFENSE
YOU MAY HAVE TO ACCELERATION AND FORECLOSURE.
F-AnlB TA
DDDDEMQPA6__N000102 '
Marc?.24, 1999
GE Capital
GECapg a d8Bri1upNION TO FORECLOSE
AUn,t9=.GA+0'tr.4UQERVGPGF@i WtARr3 OF PA
4680 f801%1=rkw.fv. SWaa?F. l*j, CA OJ= BOTH
PAGES OF THIS NOTICE CAREFULLY.)
GARY DAVIS
BOX 1006
CARLISLE, PA 17013
RE: GE LOAN # 0022082440
PROPERTY 538 N PITT STREET CARLISLE, PA 17013
MORTGAGEE: G.E. CAPITAL MORTGAGE. SERVICES
We represent GE Capital Mortgage Services, Inc. ("GECMSI" the holder of a
mortgage on your property located at: 538 N PITT STREET, CARLISLE, PA which
mortgage is in serious default because you have not made the monthly
payments of $617.11 for 3 months and/or because N/A. Late
charges (and other charges) have also accrued of $30.85. The total
amount now required to cure this default, or in other words, get caught up
in your payments as of the date of this letter, is $1,882.18
You may cure this default within THIRTY (30) days of this letter by apay nding
the above amount of $1,802.18, plus any additional monthly payments
late charges (and other charges) which may fall due during this period.
Such payment must be made in the form of a cashier's check, certified
j check, or money order, and sent to 2000 West Loop South, Suite 1300,
j Houston, TX 77027•
If you do not cure the default within THIRTY (30) days, we intend to
exercise our right to accelerate the mortgage payments. This means that
whatever is owing on the original n rtgage amount chance borrowed willo a the may lose the considered due immediately, and yo payment opay f the amount
original mortgage in monthly installments. If full also intend to instruct
of default is not made within THIRTY (30) days,
our attorneys to start a lawsuit to foreclose your mortgage property.
If the mortgage is foreclosed, your mortgage property will be sold by the
fore we
ff to ay off the mortgage debt. If you cure the default bee
proceedings Sheri p You will still have pay
against
begin legal
you, reasonable attorney's fees actually incurred pwill$have to pay wever, if
the
legal proceedings are started against you, you
reasonable attorney'se fees even if they are over $50.00. Any attorney's
fees will be added to whatever you owe us, which may also include our
reasonable costs. If you cure the default within the THIRTYOU ) dayTHE
period, you will not be required to pay attorney's fees. HAVE
RIGHT TO REINSTATE AFTER ACCELERATION AND THE RIGHT TO ASSERT IN THE
FORECLOSURE PROCEEDINGS THE NONEXISTENCE OF A DEFAULT OR ANY OTHER DEFENSE
YOU MAY HAVE TO ACCELERATION AND FORECLOSURE.
EXHIBIT A
We may also sue you personally for the unpaid principal balance, and all
0 so sums due under the Mortgage. If you have not cured the default
the thirty day period and foreclosure proceedings have begun you
have the right to cure the default and prevent the sale at any time
up to one hour before the Sheriff's foreclosure sale. You may AFG801
paying the tetal due, as well as the L-easenable atter-neys I fees a d costs
incurred in connection with the foreciagprypyH6higoS Rerform any other
requirements under the mortgage). A Unit of General Electric Capital Mortgage Corporation
.4680 Hallmark Parkway, San Bernardino. CA 92407
It is estimated that the earliest date that such a Sheriff's Sale could be
held would be approximately six months from the date of this letter. A
notice of the date of the Sheriff's sale will be sent to you before the
sale. of course, the amount needed to cure the default will increase the
longer you wait. You may find out at any time exactly what the required
payment will be by calling us at he following number: 1 (800) 962-8399. This
payment must be in the form of cashier's check , certified check, or money
order and made payable to us at the address stated above. You should
realize that a sheriff's sale will end your ownership of the mortgaged
property and your right to remain in it. If you continue to live in the
property after the sheriff's sale, a lawsuit could be started to evict
you.
You have additional rights to help protect your interest in the property.
You have the right to sell the property to obtain. money to pay off the
mortgage debt, or borrow money from another lending institution to pay off
this debt (you may have the right to sell or transfer the property subject
to the mortgage to a buyer or transferee who will assume the mortgage
debt, provided that all the outstanding payments, charges, attorney's fees
and costs are paid prior to, or at the sale and that other requirements
under the Mortgage are satisfied). Contact us to determine under what
circumstances might exist. You have the right to have this default cured
by any third party acting on your behalf.
If you cure the default, the mortgage will be restored to the same
position as if no default had occurred. However, you are entitled to this
right to cure your default no more than three (3) times in a calendar year.
Very Truly Yours,
Felissa Carter, Loan Counselor 1 (800) 962-8399
22082440
EXHIBITA
GE Capital
BE Capital Mortgage Services, Inc.
A Unit of General Electric Capital Mortgage Corporation
DDDDEMOPA91 NOR0106 4680 Hallmark Parkway, San Bernardino, CA 92407
ACT 91 NOTICE
TAKE ACTION TO SAVE YOUR HOME FROM FORECLOSURE
The Commonwealth of Pennsylvania's Homeowners' Emergency Mortgage
Assistance Program may be able to help you. Read the following 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 Notification en adjunto es de suma importancia, pues afecta su
derecho a continuar viviendo en su case. Si no comprende el contenido de
esta notification obtenga una traduccion immediatamente llamando esta
agencia (Pennsylvania Housing Finance Agency) sin cargos al numero
mencionado arriba. Puedes ser elegible pare. un prestamo por el programs
llamado "Homeowners' Emergency Mortgage Assistance Program" al cual puede
salvar su casa de la perdida del derecho a redimir su hipoteca.
ACT 91 NOTICE
IMPORTANT: NOTICE OF HOMEOWNERS'
EMERGENCY MORTGAGE ASSISTANCE PROGRAM
PLEASE READ THIS NOTICE.
YOU MAY BE ELIGIBLE FOR FINANCIAL
ASSISTANCE WHICH CAN SAVE YOUR HOME FROM
FORECLOSURE AND HELP YOU MAKE FUTURE MORTGAGE PAYMENTS
March 24,. 1999
RE: G.E. CAPITAL MORTGAGE SERVICES, INC.
Property Address: 538 N PITT STREET, CARLISLE PA 17013
Loan # 22082440
TO: GARY B DAVIS
538 N PITT STREET
CARLISLE, PA 17013
FROM: G.E. Capital Mortgage Services
You may be eligible for financial assistance that will prevent foreclosure
on your mortgage if you comply with the provisions of the Homeowners'
Emergency Mortgage Assistance Act of 1983 (the "ACT"). You may be eligible
for emergency temporary assistance if you default has been caused by
circumstances beyond your control, you have a reasonable prospect of
resuming your mortgage payments, and if you meet other eligibility
requirements established by the Pennsylvania Housing Finance Agency.
Please read all of this Notice. It contains an explanation of your rights.
EXHIBIT B
DDDDEMQPA917NOR0106
ACT 91 NOTICE
GE Capital
The Commonwealth of Pennsylvani.?Lq?PltalMartgageServfces,lna
Assistance Program may be able to he ?Pa?'p??C4pAlptgage
find out how the program works. 1894/otg:urkl$adtf.5016e4alacart 97 notice to
If you need more information, call the Pennsylvania Housing Finance
Agency at 1-800-342-2397.
La Notification en adjunto es de suma importancia, pues afecta su
derecho a continuar viviendo en su casa. Si no comprende el contenido de
esta notificacion obtenga una traduccion immediatamente llamando esta
agencia (Pennsylvania Housing Finance Agency) sin cargos al numero
mencionado arriba. Puedes ser elegible para un prestamo por el programs
llamado "Homeowners' Emergency Mortgage Assistance Program" al cual puede
salvar su casa de la perdida del derecho a redimir su hipoteca.
ACT 91 NOTICE
IMPORTANT: NOTICE OF HOMEOWNERS'
EMERGENCY MORTGAGE ASSISTANCE PROGRAM
PLEASE READ THIS NOTICE.
YOU MAY BE ELIGIBLE FOR FINANCIAL
ASSISTANCE WHICH CAN SAVE YOUR HOME FROM
FORECLOSURE AND HELP YOU MAKE FUTURE MORTGAGE PAYMENTS
March 24, 1999
RE: G.E. CAPITAL MORTGAGE SERVICES, INC.
Property Address: 538 N PITT STREET, CARLISLE PA 17013
Loan # 22082440
?? p 6 ?y9°•
TO: GARY BDAVIS
BOX 1006
CARLISLE, PA 17013
FROM: G.E. Capital Mortgage Services
You may be eligible for financial assistance that will prevent foreclosure
on your mortgage if you comply with the provisions of the Homeowners'
Emergency Mortgage Assistance Act of 1983 (the "ACT"). You may be eligible
for emergency temporary assistance if you default has been caused by
circumstances beyond your control, you have a reasonable prospect of
resuming your mortgage payments, and if you meet other eligibility
requirements established by the Pennsylvania Housing Finance Agency.
Please read all of this Notice. It contains an explanation of your rights.
60
C
EXHIBIT B
the Act, You are entitled to a temporary stay of foreclosure on
mortgage for thirty (30) days from the date of this Notice, ??r Your
u Di1 Wq1§t?
representative of this lender, or with dP1i9?liiQQ%qcounseling agency. The purpose of t c?cNumer credit
f repayment plan, or to otherwise settles g?eC?Ca4Ua$pQ$hvork out a
occur in the next thirty (30) days. J*?S?1no'?j09?eeting must
If you attend a face-to-face meeting with this lender, or with a consumer
credit counseling agency identified in this notice, no further proceeding
in mortgage foreclosure may take place for thirty (30) days after the date
of this meeting. The name, address, and telephone number of our
representative is:
G.E. Capital Mortgage Services
2000 West Loop South, Suite 1300
Houston, Texas 77027
The names and addresses of designated consumer(credit6counseling agencies
are shown on the attached sheet. It is only necessary to schedule one
face-to-face meeting. You should advise this lender immediately of your
intentions.
Your mortgage is in default because you have failed to pay promptly
installments of principal and interest, as required for at least sixty (60)
days. The total amount of the delinquency is $1,882.18. That sum includes
the following: payments due 01/19/99 through the date of this letter and
late charges.
Your mortgage is also in default for the following reason:
ILLNESS OF PRINCIPAL MORTGAGOR.
If you have tried and are unable to resolve this problem at or after our
face-to-face meeting, you have the right to apply for financial assistance
from the Homeowners' Emergency Mortgage Assistance Fund. In order to do
this, you must fill out, sign and file a completed Homeowners' Emergency
Assistance Application with one of the designated consumer credit
counseling agencies listed on the attachment. An application for
assistance may only be obtained from a consumer credit counseling agency.
The consumer credit counseling agency will assist you in filling out your
application and will submit your completed application to the Pennsylvania
Housing Finance Agency. Your application must be filed or postmarked,
within thirty (30) days of your face-to-face meeting.
It is extremely important that you file your application promptly. If you
do not do so, or if you do not follow other time periods set forth in this
letter, foreclosure may proceed against your home immediately.
EXHIBIT B
Available funds for emergency mortgage assistance are very limited. They
be disbursed by the Agency under the eligibility criteria established.
e ACT.
j
It is extremely important that your application is accurate and%Wllge in
60) days
to make a decision after it receives
G
additional time, no foreclosure Procem?i?.a?anere6dettrAivi.TkewWtrbAprA a oWCgSgaAUSt that y
ib?,P ou if
you have met the time requirements seWofooghF8kW,6anXvurdw4tA93t67notified
directly by the Agency of its decision on your application.
The Pennsylvania Housing Finance Agency is located at 2101 North Front
Street, Post Office Box 8029, Harrisburg, Pennsylvania 17105. Telephone
No. (717) 780-3800 or 1-B00-342-2397 (toll free number). Persons with
impaired hearing can call 1-800-342-2397.
In addition, you may receive another notice from this lender under Act 6 of
1974. That notice is called a "Notice of Intention to Foreclose." You must
read both notices, since they both explain rights that you now have under
Pennsylvania law. However, if you choose to exercise your rights described
in this notice, you cannot foreclosed upon while you are receiving that
assistance.
Sincerely, 22082440
Felissa Carter, 1 (800) 962-8399, Collection Department
The following disclosure is required by applicable federal and state law
for certain loans that we service: This communication is from a debt
collector and is an attempt to collect a debt; any information obtained
will be used for that purpose.
EXHIBIT B
GE Capital
BE Capital Mortgage Services, Inc.
A Unit of General Electric Capital Mortgage Corporation
4680 Hallmark Parkway, San Bernardino, CA 97407
HUD APPROVED COUNSELING AGENCIES
PENNSYLVANIA
DELAWARE COUNTY H.O.P.E. BAYFRONT NATO, INC,
PHILADELPHIA. COUNCIL FOR COMMUNITY 312 CHESTNUT STREET
ADVANCEMENT ERIE, PA 16507
511 WELSH STREET (814) 459-2761
CHESTER, PA 19013
(215) 872 3500
COMMUNITY RESOURCES FOR INDEP
2222 FILMORE AVENUE
ERIE, PA 16506
(814) 838-7222
HARRISBURG FAIR HOUSING COUNCIL
1228 BAILEY STREET
HARRISBURG, PA 17103
(717) 238-9540
INDIANA COUNTY COMMUNITY
ACTION PROGRAM INC.
827 WATER STREET
PO BOX 187
INDIANA, PA 15701
(412) 465-2657
NORTHERN TIER COMMUNITY
ACTION CORPORATION
135 WEST 4TH STREET
EMPORIA, PA 15834
(814) 486-1161
GREATER ERIE COMMUNITY
ACTION AGENCY
18 WEST 9TH STREET.
ERIE, PA 16501
(814) 459-4581
ELK COUNTY HOUSING AUTHORITY
424 WATER STREET EXT.
PO BOX 100
JOHNSONBURGH, PA 15845
(814) 965-2532
ASSOCIATED FAMILY SERVICES
213 CENTER STREET
MEADVILLE, PA 16335
(814) 337-8457
NEW KENSINGTON C.D.C.
2513-15.FRANKFORD AVENUE
PHILADELPHIA, PA 19125
(215) 427-0350
TABOR COMMUNITY SERVICES
439 EAST KING STREET
LANCASTER, PA 17602
(717) 397-5182
BOOKER T. WASHINGTON CENTER
1720 HOLLAND STREET
ERIE, PA 16503
(814) 453-5744
URBAN LEAGUE OF
METROPOLITAN HARRISBURG
25 NORTH FRONT STREET
HARRISBURG, PA 17101
(717) 234-3253
HOUSING OPPORTUNITIES, INC
133 SEVENTH AVENUE
PO BOX 9
MCKEESPORT, PA 15132
(412) 664-1590
LAWRENCE COUNTY SOCIAL SERVICES,INC
33-39 SOUTH JEFFERSON STREET
NEW CASTLE, PA 16103.
(412) 658-7258
PHILADELPHIA COUNCIL FOR
COMMUNITY ADVANCEMENT
100 NORTH 17TH STREET - SUITE 600
PHILADELPHIA, PA 19103
(215) 567-7803
EXHIBIT B
GE Capital
i
iI
J
i
i
GE Capital Mortgaga Sarvlcaa, Inc.
A Unit of General EICCtnC Capital Mortgage Corporation
4680 Hallmark Parkway. San Bernardino, CA 97407
HUD APPROVED COUNSELING AGENCIES
PENNSYLVANIA(COnt)
TENANTS' ACTION GROUP CENTER FOR INDEPENDENT LIVING SW PA
OF PHILADELPHIA 7110 PENN AVENUE
21 SOUTH 12TH STREET - 12TH FLOOR PITTSBURGH, PA 15208
PHILDELPHIA,.PA 19107 (412) 371-7700
(215) 575-0700
TREHAD CENTER OF NE PENNSYLVANIA
7 LAKE AVENUE
MONTROSE, PA 18801
(717) 278-3338
HOUSING ASSOCIATION INFORMATION PROGRAM
1314 CHESTNUT STREET - SUITE 900
PHILADELPHIA, PA 19107
(215) 545-6010
MORTGAGORS COUNSELED AT
658-60 NORTH WATTS STREET,
PHILADELPHIA, PA 19123
NORTHWEST COUNSELING SERVICE
5001 NORTH BROAD STREET
PHILADELPHIA, PA 19141
(215) 549-2344
URBAN LEAGUE OF PHILADELPHIA
4601 MARKET STREET
PHILADELPHIA, PA 19139
(215) 476-4040
ELDER-ADO, INC
320 BROWNSVILLE ROAD.
PITTSBURGH, PA 15210
(412) 381-6900
ECONOMIC OPPORTUNITY CABINET
118 EAST NORWEGIAN STREET
POTTSVILLE, PA 17901-2921
(717) 622-1995
TABLELAND SERVICES, INC.
131 NORTH CENTER AVENUE
PO BOX 756
SOMERSET, PA 15501
(814)445-9628 OR (814) 445-0148
PHILADELPHIA HOUSING
DEVELOPMENT CORPORTATION
1234 MARKET STREET - 10TH FLOOR
PHILADELPHIA, PA 19107
(215) 448-3137 OR (215) 448-3132
CONSUMER CREDIT COUNSELING
OF WESTERN PENNSYLVANIA
309 SMITHFIELD STREET -.SUITE 2000
PITTSBURGH, PA 15222
(412) 471-7584
HILL COMMUNITY DEVELOPMENT CORPORTATION
2015-2017 CENTRE AVENUE
PITTSBURGH, PA 15219
(412) 765-1320
MERCER COUNTY
COMMUNITY ACTION AGENCY
309 OHIO STREET
SHARON, PA 16146
(412) 342-6222
WARREN FOREST COUNTY E.O.C.
1209 PENNSYLVAIA AVENUE WEST
PO BOX 547
WARREN, PA 16365
(814) 726-2400
EXHIBIT B
GE Capital
CE Capital Mortgage Services, Inc.
A Unit of General Electric Capital Mortgage Corporation
,I 4680 Hallmark Parkivav. San Bernardino, CA 92407
1 HUD APPROVED COUNSELING AGENCIES
I
PENNSYLVANIA(Cont)
j,. GARFIELD JUBLIEE ASSOCIATION, INC. URBAN LEAGUE OF PITTSBURGH
5138 PENN AVENUE ONE SMITHFIELD STREET
PITTSBURGH, PA 15224
- PITTSBURGH, PA 15222
. .I. (412) 665-5200
I (412) 261-1130
1
BERKS COMMUNITY ACTION AGENCY
SHENANGO VALLEY URBAN LEAGUE
BUDGET COUNSELING CENTER 39 CHESTNUT STREET
247 NORTH FIFTH STREET SHARON, PA 16146
READING, PA 19601 (412) 981-5310
(215) 375-7866
.? FAYETTE COUNTY TRI-COUNTY PARTNERSHIP FOR
COMMUNITY ACTION AGENCY INDEPENDENT LIVING
137 NORTH BEESON AVENUE 69 EAST BEAU STREET
UNIONTOWN, PA 15401 WASHINGTON, PA 15301
(412) 437-6050 (412) 223-5115
WASHINGTON-GREENE CONSUMER CREDIT COUNSELING
COMMUNITY ACTION CORPORATION SERVICE OF LEHIGH VALLEY
315 EAST HALLAM AVENUE 3671 CRESCENT COURT EAST
J WASHINGTON, PA 15301 WHITEHALL, PA 18052
i
(412) 225-9550 (215) 821-4011
.i HOUSING COUNCIL OF YORK WASHINGTON-GREENE
j 116 NORTH GEORGE STREET COMMUNITY ACTON CORPORATION
YORK, PA 17401 22 WEST HIGH STREET
(717). 854-1541 WAYNESBURG, PA 15370
(412) 852-2893
COMMISSION OF ECONOMIC
j OPPORTUNITY OF LUZERNE COUNTY
1 122-213 SOUTH MAIN STREET
WILKES-BARRE, PA 18701
.; (717) 826-0510
{
EXHIBIT B
ALL THAT CERTAIN messuage and lot of ground situate in the Borough of
Carlisle, County of Cumberland and Commonwealth of Pennsylvania, bounded
and described as follows, to wit:
BOUNDEq on the East by Pitt Street; on the Soug?h by-1o7:now':or°lahe-•of
Albert X. Myers; on the West by an alley; and bn-the•1goriht„by;,,);H;7,.Str at.
HAVING a frontage of 15-1/2 feet on Pitt Street'. a nd'extending'--in: depth to
the alley aforesaid, a distance of 110 feet.
BEING improved with a brick dwelling house and known as No. 538 North Pitt
Street.
BEING THE SAME PREMISES that Fred E. Jumper and Theos E. Verow by deed
dated November 6, 1987, and recorded November 6, 1987, in the Office of the
Recorder of Deeds in and for Cumberland County, Pennsylvania, in Record
Book A-33, Page 635, granted and conveyed unto Dale M. Carey, Jr., his
heirs and assigns.
TAX MAP NUMBER is 06-20-1798-095.
VERIF_ ICATION
SCOTT PATTERSON hereby states that he is ASSISTANT VICE-PRESIDENT
of GE CAPITAL MORTGAGE SERVICES, INC. mortgage servicing agent for
Plaintiff in this matter, that he/she is authorized to take this
Verification, and that the statements made in the foregoing Civil
Action in Mortgage Foreclosure are true and correct to the best of
his/her knowledge, information and belief. The undersigned
understands that this statement is made subject to the penalties of
18 Pa. C.S. Sec. 4904 relating to unsworn falsification to
authorities.
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FEDERMAN and PHELAN
By: FRANK FEDERMAN
Identification No. 12248
suite 900
Two Penn Center Plaza
Philadelphia, PA 19102
(215) 563-7000
GE CAPITAL MORTGAGE SERVICES, INC.
ATTORNEY FOR PLAINTIFF
. CUMBERLAND COUNTY
. COURT OF COMMON PLEAS
. CIVIL DIVISION
VS.
GARY DAVIS, A/K/A GARY B. DAVIS
. NO. 99-3031 CIVIL
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) that defendant GARY DAVIS, A/K/A GARY B. DAVIS is
over 18 years of age and resides at 538 NORTH PITT STREET,
CARLISLE, PA 17013.
This statement is made subject to the penalties of 18 Pa.
C.S. Section 4904 relating to unsworn falsification to authorities.
FRANK FEDERMAN, ESQUIRE
Attorney for Plaintiff
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(Rule of Civil Procedure No. 236) - Revised
IN THE COURT OF COMMON PLEAS OF CUMBERLAND COUNTY, PENNSYLVANIA
CIVIL ACTION - LAW
GE CAPITAL MORTGAGE SERVICES, INC.
Plaintiff
VS.
GARY DAVIS, A/K/A GARY B. DAVIS
Defendants
NO. 99-3031 CIVIL
Notice is given that a Judgment in the above-captioned
matter has been entered against you on JULY , 1999.
By: DEPUTY
If you have any questions concerning this matter, please
contact:
FR K?FEDEPM N ES UIRE\
Attorney for Party Filing
Two Penn Center Plaza, Suite 900
Philadelphia, PA 19102
(215) 563-7000
**THIS FIRM IS A DEBT COLLECTOR ATTEMPTING TO COLLECT A
DEBT AND ANY INFORMATION OBTAINED WILL BE USED FOR
THAT PURPOSE. IF YOU HAVE PREVIOUSLY RECEIVED A
DISCHARGE IN BANKRUPTCY, THIS IS NOT AND SHOULD NOT BE.
CONSTRUED TO BE AN ATTEMPT TO COLLECT A DEBT, BUT
ONLY ENFORCEMENT OF A LIEN AGAINST PROPERTY.**
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PRAF,CII'E FOR WRIT OF EXECUTION - (MORTGAGE FORECLOSURE)
P.R.C.P. 3180-3183
GE CAPITAL MORTGAGE SERVICES,
INC.
Plaintiff
Vs.
GARY DAVIS, A/K/A GARY B. DAVIS
COURT OF COMMON PLEAS
CUMBERLAND COUNTY, PA
NO. 99-3031 CIVIL
PRAECIPE FOR WRIT OF E)GXUTION
(MORTCM'W FY)RFXI OSURF)
Defendant(s)
TO THE DIRECTOR OF THE OFFICE OF THE PROTHONOTARY:
Issue writ of execution in the above matter:
Amount Due X6,988.58
Interest from 7/14/99 TO $ 2,116.40 and Costs
3.2/8/99
(PER-DIEM - $14.30)
$89.104.98 TOTAL
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FRANC FEDERMA , ESQUIRE
TWO.PENN CENTER PLAZA
SUITE 900
PHILADELPHIA, PA 19102
Attorney for Plaintiff
Note: Please attach description of property.
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DESCRIPTION
ALL THAT CERTAIN messuage and lot of ground situate in the Borough of Carlisle, County of
Cumberland and Commonwealth of Pennsylvania, bounded and described as follows, to wit:
BOUNDED on the East by Pitt Street; on the South by lot, now or late of Albert K. Mvers; on the
West by an alley; and on the North by "B" Street.
HAVING a frontage of I5-1/2 feet on Pitt Street and extending in depth to the alley aforesaid, a
distance of 110 feet. -
BEING improved with a brick dwelling house and known as No. 533 North 1106-20-1798-095.
TAX NIAP NUMBER is 06-20-1798-095.
TITLE TO SAID PREMISES IS VESTED IN Gary B. Davis by Deed 1M. Carey, Jr,
dated 5/19'98 recorded 6/d/93 in Deed from Dale Book 173 Page 673.
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GE CAPITAL MORTGAGE SERVICES, INC.
VS.
GARY DAVIS, A/K/A GARY B. DAVIS
. CUMBERLAND COUNTY
. COURT OF COMMON PLEAS
CIVIL DIVISION
NO. 99-3031 CIVIL
AFFIDAVIT PURSUANT TO RULE 3129
(Affidavit No. 1)
GE CAPITAL MORTGAGE SERVICES. INC. , 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 538 NORTH PITT
STREET, CARLISLE, PA 17013.
1. Name and address of Owner(s) or reputed Owner(s):
NAME LAST KNOWN ADDRESS (if address
cannot be reasonably ascertained,
please so indicate)
GARY DAVIS, A/K/A 536 NORTH PITT STREET
GARY B. DAVIS CARLISLE. PA 17013
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)
NONE
11
5
Name and address of every other person who has any record lien
on the property:
NAME LAST KNOWN ADDRESS (if address
cannot be reasonably ascertained,
please so indicate)
NONE
6
NONE
7
Name and address of every other person who has any record
interest in the property and whose interest may be affected by
the sale:
NAME LAST KNOWN ADDRESS (if address
cannot be reasonably ascertained,
please so indicate)
Name and address of every other person whom the plaintiff has
knowledge who has any interest in the property which may be.
affected by the sale:
NAME LAST KNOWN ADDRESS (if address
cannot be reasonably ascertained,
please so indicate)
DOMESTIC RELATIONS OF 13 NORTH HANOVER STREET
CUMBERLAND COUNTY CARLISLE. PA 17013
I verify that the statements made in this affidavit are
true and correct to the best of my personal knowledge or
information and belief. I understand that false statements herein
are made subject to the penalties of 18 Pa. C.S. Sec. 4904 relating
to unsworn falsification to authorities.
July 14. 1999
DATE FRANK FEDERMAN, ESQUIRE
Attorney for Plaintiff
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FEDERMAN AND PHELAN
By: FRANK FEDERMAN
Identification No. 12248
TWO Penn Center Plaza suite goo
Philadelphia, PA 19102
(215) 563-7000
GE CAPITAL MORTGAGE SERVICES, INC
4680 HALLMARK PARKWAY
SAN BERNARDINO, CA 92407
VS.
GARY DAVIS, A/K/A GARY B. DAVIS
538 NORTH PITT STREET
CARLISLE, PA 17013
Attorney for Plaintiff
CUMBERLAND COUNTY
COURT OF COMMON PLEAS
CIVIL DIVISION
NO. 99-3031 CIVIL
PRAECIPE FOR JUDGMENT FOR FAILURE TO
ANSWER AND ASSESSMENT OF DAMAGES
TO THE PROTHONOTARY:
Kindly enter judgment in favor of the Plaintiff and against
GARY DAVIS. A/K/A GARY B. DAVIS, 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 - 5/1/99 TO 7/14/99
TOTAL
$85,566.58
,^+11.422. 00
$86,988.58
I hereby certify that (1) the addresses of the Plaintiff and
Defendant (s) are as shown above, and (2) that notice has been given
in accordance with Rule 237.1, copy attached.
FRANK FEDERMAN, ESQUIRE
Attorney for Plaintiff
DAMAGES ARE HEREBY ASSESSED AS INDICATED.
DATE: /(. l 39ry
PRO PROTHY?
FEDERMAN AND PHELAN
Frank Federman, Esquire
Identification No. 12248
Two Penn Center Plaza
Suite 900.
Philadelphia, PA 19102-1799
(215) 563-7000
GE CAPITAL MORTGAGE SERVICES,
INC.
Plaintiff
VS.
GARY DAVIS,
A/K/A GARY B. DAVIS
Defendant(s)
ATTORNEY FOR PLAINTIFF
COURT OF COMMON PLEAS
CIVIL DIVISION
CUMBERLAND COUNTY
NO. 99-3031 CIVIL
TO: GARY DAVIS
A/K/A GARY B. DAVIS
538 NORTH PITT STREET
CARLISLE, PA 17013
DATE OF NOTICE: JUNE 18, 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 BAR ASSOCIATION
2 LIBERTY AVENUE
CARLISLE, PA 17013
(717) 249-3166
Frank Federman, Esquire
Attorney for Plaintiff
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GE CAPITAL MORTGAGE SERVICES, INC. CUMBERLAND COUNTY
COURT OF COMMON PLEAS
Vs. CIVIL DIVISION
GARY DAVIS, A/K/A GARY B. DAVIS
NO. 99-3031 CIVIL
NOTICE OF SHERIFF'S SALE OF REAL PROPERTY
July 14, 1999
TO: GARY DAVIS, A/K/A GARY B. DAVIS
538 NORTH PITT STREET
I) CARLISLE, PA 17013
**THIS FIRM IS A DEBT COLLECTOR ATTEMPTING TO COLLECT A
DEBT AND ANY INFORMATION OBTAINED WILL BE USED FOR
THAT PURPOSE. IF YOU HAVE PREVIOUSLY RECEIVED A
{ DISCHARGE IN BANKRUPTCY, THIS IS NOT AND SHOULD NOT BE
CONSTRUED TO BE AN ATTEMPT TO COLLECT A DEBT, BUT
ONLY ENFORCEMENT OF A LIEN AGAINST PROPERTY.**
Your house (real estate) at 538 NORTH PITT STREET, CARLISLE,
PA 17013, is scheduled to be sold at the Sheriff's Sale on DECEMBER
8. 1999 at 10:00 a.m. in the Cumberland County Courthouse, South
' Hanover Street, Carlisle, PA 17013, to enforce the court judgment
of $86,988.58 obtained by GE CAPITAL MORTGAGE SERVICES, Y C. (the
mortgagee) against you. If the sale is postponed, the property
1 will be relisted for the MARCH 1. 2000 Sheriff's Sale.
NOTICE OF OWNER'S RIGHTS
YOU MAY BE ABLE TO PREVENT THIS SHERIFF'S SALE
?nmmediate
To prevent this Sheriff's Sale, you must take
action:
1. The sale will be cancelled if you pay to the mortgagee
the back payments, late charges, costs and reasonable
attorney's fees due. To find out how much you must pay,
you may call: (215) 563-7000.
2. You may be able to stop the sale by filing a., petition
asking the Court to strike or open the judgment, if the
judgment was improperly entered. You may also ask the
Court to postpone the sale for good cause.
3. You may also be able to stop the sale through other legal'
proceedings.
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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.
1. If the Sheriff's Sale is not stopped, your property will
be sold to the highest bidder. You may find out the price bid by
calling (215) 563-7000.
2. You may be able to petition the Court to set aside the
sale if the bid price was grossly inadequate compared to the value
of your property.
3. The sale will go through only if the buyer pays the
Sheriff the full amount due in the sale. To find out if this has
happened, you may call (717) 240-6390.
4. If the amount due from the Buyer is not paid to the
Sheriff, you will remain the owner of the property as if the sale
never happened.
5. You have the right to remain in the property until the
full amount due is paid to the Sheriff and the Sheriff gives a deed
to the buyer. At that time, the buyer may bring legal proceedings
to evict you.
6. You may be entitled to a share 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 dofenses, 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
DESCRIPTION
ALL THAT CERTAIN messuage and lot of ground situate in the Borough of Carlisle, County of
Cumberland and Commonwealth of Pennsylvania, bounded and described as follows, to wit:
BOUNDED on the East by Pitt Street; on the South by lot, now or late of Albert K. Myers; on the
West by an allev; and on the North by "B" Street.
HAVING a frontage of I5-1`3 feet on Pitt Street and extending in depth to the alley aforesaid, a
distance of 110 feet.
BEING improved with a brick dwelling house and known as No. 538 North 11106-20-1798-095.
TAY MAP NUMBER is 06-20-1798-095.
TITLE TO SAID PREMISES IS VESTED IN Gary B. Davis by Deed from Dale LIVI. Carey, Jr
dated 6/19/98 recorded 6/4:'98 in Deed Book 178 Page 678.
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IN THE COURT OF COMMON PLEAS OF CUMBERLAND COUNTY, PENNSYLVANIA
GE CAPITAL MORTGAGE SERVICES, INC.
Plaintiff CIVIL DIVISION
Vs. No. 99-3031 CIVIL
GARY DAVIS, A/K/A GARY B. DAVIS
Defendants
AFFIDAVIT OF SERVICE PURSUANT TO RULE 3129
COMMONWEALTH OF PENNSYLVANIA
SS:
CUMBERLAND COUNTY
I, FRANK FEDERMAN, ESQ., attorney for GE CAPITAL
MORTGAGE SERVICES. INC. , hereby verify that on JULY 15, 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 JULY 15. 1999
by first class mail and certified mail return receipt requested,
see Exhibit "B" attached hereto.
n
FRANK F •DERMAN, ESQUIRE
Attorn y for Plaintiff
Date: November 8. 1999
LLS. POSTAL SERVICE CERTIFICATE OF MAILING I
MAY BE USED FOR DOMESTIC AND INTERNATIONAL MAIL. DOES NOT j
PROVIDE FOR INSURANCE-POSTMASTER
Received From:
DHR FEDERMAN AND PHELAN'
--REz DAVIS, 6. --WW-900
Two Penn Center Plaza
Philadelphia, PA 19102
One piece of ardinary mail addressed to:
Domestic Relations Cumberland County
13 North over Street
Carlisle, Pa 17013
PS Form 3817. Mar. 1989
Affix fee here in stamps
o• metal 09911'19 er•d
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RETURN POSTAGE POSTMARK DA RATE
S RECEIPT RESTRICTED DELIVERY
SERVICE CERNPEO FEE • RETURN RECEPT --
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PS FORM 3800 US Postal Service Receipt for
Certified Mail
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RETURN ROSrAGE i Y?-_;PA _ AN OA DATE
RECEIPT RESTRICTED DEUVERV
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.0 TOTAL POSTAGE AND FEES
SENT T IN I" " -
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SHERIFF'S RETURN - REGULAR
CASE NO: 1999-03031 P
COMMONWEALTH OF PENNSYLVANIA:
COUNTY OF CUMBERLAND
GE CAPITAL MORTGAGE SERVICES
VS.
DAVIS GARY
RICHARD SMITH
Sheriff or Deputy Sheriff of
CUMBERLAND County, Pennsylvania, who being duly sworn according
to law, says, the within NOTICE AND COMPLAINT IN
upon DAVIS GARY A K/A DAVIS GARY B was served
defendant, at 14:23 HOURS, on the 28th day of May the
1999 at 538 NORTH PITT ST
County, Pennsylvania, by handing to JOE CARMINATI (CO-PARTNER) LAND
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.
Sheriffis Costs:
Docketing
Service
Affidavit
surcharge
18.00 So answe ?
3.0
.000
8.00 omas eri
$27711TFEDE & PHELAN
06/01 1999
by ,
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Sworn ndsubscribed to before me
this 4-/' day of d
STA'T'E OF PENNSYLVANIA,
COUNTY OF CUMBERLAND ss'
I----------Robert_P Ziegler---------------------
--------------------------- Recorder of
Deeds in and for said County and State do hereby certify that the Sheriff's Deed in which ----------------
GE CApital Mtg Serv Inc
---------- -- -- --------------------------------
------------------------------- is tile grantee
the same having been sold to said grantee on the ------ 8th------------------------------------- day of
_____________ __ December --------------- A. D., 19_99 under and by virtue of a writ______________
- Execution -------------------- issued on the_____________16th
day of __________ July----------- A. D., 19____99 out of the Court of Comman Pleas of said County as of
-- - Civil
---------- - -- ------- - ------ - ----------------------- Term, 19-- 99--
Number--------- 3031 at the suit of.... GE CApital Mtg Serv -Inc
----------------------
Gary Davis aka gary B
----------------------------------- against
duty recorded in Sheriff's Deed Book No. ____-__220 Page 628 -
----
IN TESTIMONY WHEREOF, I ha2hemunto
set my hand and seal of said office this .J --------- day
of ---- - - ---------- - A. ab9 --- -
rder of
R?orduAbMatOaMtbdOw? M
wo?..u?m.fur.w4'?e
GE Capital Mortgage Services Inc.
-vs-
Gary Davis, A/K/A Gary B. Davis'
In the Court of Common Pleas of
Cumberland County, Pennsylvania
No. 99-3031 Civil Term
Richard E. Smith, Deputy Sheriff, who being duly sworn according to law, says on
September 30, 1999 at 8:36 o'clock A.M. EDST, he posted a copy of Real estate Writ
Notice Poster and Description on the property of Gary B. Davis located at 538 North Pitt
Street, Carlisle, Cumberland County, Pennsylvania, according to law.
Brian M. Barrick, Deputy Sheriff, who being duly sworn according to law, says on
August 13, 1999 at 3:54 o'clock P.M. EDST, he served a true copy of Real Estate Writ
Notice and Description in the above entitled action upon the within named defendant to
wit: Gary Davis, by making known unto Gary Davis at 1548 Spring Road, Carlisle,
Cumberland County, Pennsylvania, its contents and at the same time handing to him
personally the said true and attested copies of the same.
Richard E. Smith Deputy Sheirff, who being duly sworn according to law, says on
September 30, 1999 at 9:15 o'clock A.M. EDST, he served a copy of Real Poster, in the
above entitled action upon the within named defendant to wit: Gary B. Davis by making
known unto Gary B. Davis at 172 Faith Circle, Carlisle, Cumberland County,
Pennsylvania, its contents and at the same time handing to him personally the said true
copy of the same.
R. Thomas Kline, Sheirff, 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 Gary B. Davis the within named
defendant by First Class Mail to his last 172 Faith Circle, Carlisle, Pennsylvania. This
Letter was mailed under the date of October 1, 19999 and never returned to the Sheriff's
Office.
R. Thomas Kline, Sheriff, who being duly sworn according to law, says that after due
and legal notice had been given according to law, exposed the above described premises
at public venue or outcry at Court House, Carlisle Cumberland County Pennsylvania on
December 8,1999 and sold the same for the sum of $ 1.00 to Attorney Dale Shughart for
GE Capital Mortgage Services, Inc. It being the highest bid and best price quoted for the
GE Capital Mortga.-c Services, Inc. of 4680 Hallmark Parkway, San Bernardino, CA
being the buyer in this execution paid to Sheriff R. Thomas Kline the sum of $ 596.90 it
being Sheriffs Costs.
Sheriffs Costs:
Docketing 30.00
Poundage 11.70
Posting Bills 15.00
Advertising 15.00
Acknowledging Deed 30.00
Auctioneer 10.00
Law I.ibrary .50
County 1.00
Mileage 6.20
Certified Mail
Levy
Surcharge
Law Journal
Patriot News
Share of Bills
Distribution of Proceeds
Sheriff's Deed
Sworn and Subscribed To Before Me
.74
15.00
16.00
170.00
200.63
23.63
25.00
26.50
$596.90 Pd By Atty
4-26-00
So answers:
R. Thomas Kline, Sheriff
This 13,u1DDaay of 2kilr,..
2000, A.D. 6' /Protho
? / Prothonotary
By Real Estate Deputy
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GE CAPITAL MORTGAGE SERVICES, INC.
Vs.
GARY DAVIS, A/K/A GARY S. DAVIS
CUMBERLAND COUNTY
COURT OF COMMON PLEAS
CIVIL DIVISION
NO. 99-3031 CIVIL
AFFIDAVIT PURSUANT TO RULE 3129
(Affidavit No 1)
GE CAPITAL MORTGAGE SERVICES INC. , Plaintiff in the above
action, by its attorney, FRANK FEDE MMAN, 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 538 NORTH PITT
STREET, CARLISLE PA 17013
1. Name and address of Owner(s) or reputed owner(s):
NAME LAST KNOWN ADDRESS (if address
cannot be reasonably ascertained,
please so indicate)
GARY DAVIS, A K/A 538 NORTH PITT STREET
GARY 8. DAVIS CARLISLE, PA 17013
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:
At E LAST KNOWN ADDRESS (if address
cannot be reasonably ascertained,
please so indicate)
NONE
1.
5.
NONE
6
NONE
7.
Name and address of every other person who has any record lien
on the property:
NAME LAST KNOWN ADDRESS (if address
cannot be reasonably ascertained,
please so indicate)
Name and address of every other person who has any record
interest in the property and whose interest may be affected by
the sale:
NAME LAST KNOWN ADDRESS (if address
cannot be reasonably ascertained,
please so indicate)
Name and address of every other person whom the plaintiff has
knowledge who has any interest in the property which may be
affected by the sale:
NAME LAST KNOWN ADDRESS (if address
cannot be reasonably ascertained,
please so indicate)
DOMESTIC RELATIONS OF 13 NORTH HANOVER STREET
CUMBERLAND COUNTY CARLISLE, PA 17013
I verify that the statements made in this affidavit are
true and correct to the best of my personal knowledge or
information and belief. I understand that false statements herein
are made subject to the penalties of 18 Pa. C.S.; Sec. 4904 relating
to unsworn falsification to authorities.
July 14, 1999 ??/1A?1 (C a
DATE FLANK FEDERM?N, ESQUIRE
Attorney for Plaintiff
GE CAPITAL MORTGAGE SERVICES, INC. CUMBERLAND COUNTY
COURT OF COMMON PLEAS
Vs CIVIL DIVISION
GARY DAVIS, A/K/A GARY B. DAVIS
NO. 99-3031 CIVIL
NOTICE OF SHERIFF'S SALE OF REAL PROPERTY
July 14, 1999
TO: GARY DAVIS, A/K/A GARY B. DAVIS
538 NORTH PITT STREET
CARLISLE, PA 17013
**THIS FIRM IS A DEBT COLLECTOR ATTEMPTING TO COLLECT A
DEBT AND ANY INFORMATION OBTAINED WILL BE USED FOR
THAT PURPOSE. IF YOU HAVE PREVIOUSLY RECEIVED A
DISCHARGE IN BANKRUPTCY, THIS IS NOT AND SHOULD NOT BE
CONSTRUED TO BE AN ATTEMPT TO COLLECT A DEBT, BUT
ONLY ENFORCEMENT OF A LIEN AGAINST PROPERTY.**
Your house (real estate) at 538 NORTH PITT STREET, CARLISLE,-
PA 17013, is scheduled to be sold at the Sheriff's Sale on DECEMBER
8. 1999 at 10:00 a.m. in the Cumberland County Courthouse, South
Hanover Street, Carlisle, PA 17013, to enforce the court judgment
of $86,988.58 obtained by GE CAPITAL MORTGAGE SERVICES, INC. (the
mortgagee) against you. If the sale is postponed, the property
will be relisted for the MARCH 1, 2000 Sheriff's Sale.
NOTICE OF OWNER'S RIGHTS
YOU MAY BE ABLE TO PREVENT THIS SHERIFF'S SALE
To prevent this Sheriff's Sale, you must take immediate
action:
1. The sale will be cancelled if you pay to the mortgagee
the back payments, late charges, costs and reasonable
attorney's fees due. To find out how much you must, pay,
you may call: 215 563-7000.
2. You may be able to stop the sale by filing a petition
asking the Court to strike or open the judgment, if the
judgment was improperly entered. You may also ask the
Court to postpone the sale for good cause.
3. You may also be able to stop the sale through other legal'
proceedings.
i
f
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 SHERIFFS SALE DOES TAKE PLACE
1. If the Sheriff's Sale is not stopped, your property will
be sold to the highest bidder. You may find out the price bid by
calling (215) 563-7000.
2. You may be able to petition the Court to set aside the
sale if the bid price was grossly inadequate compared to the value
of your property.
3. The sale will go through only if the buyer pays the
Sheriff the full amount due in the sale. To find out if this has
happened, you may call (717) 240-6390.
4. If the amount due from the Buyer is not paid to the
Sheriff, you will remain the owner of the property as if the sale
never happened.
5. You have the right to remain in the property until the
full amount due is paid to the Sheriff and the Sheriff gives a deed
to the buyer. At that time, the buyer may bring legal proceedings
to evict you.
6. You may be entitled to a share 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
(71.7) 249-3166
(800) 990-9108
DESCRIPTION
ALL THAT CERTAIN messuage and lot of ground situate in the Borough of Carlisle, County of
Cumberland and Commonwealth of Pennsylvania, bounded and described as follows, to wit:
BOUNDED on the East by Pitt Street; on the South by lot, now or late of Albert K. Nlyers; on the
West by an alley; and on the North by "B" Street.
HAVING a frontage of 15-1/2 feet on Pitt Street and extending in depth to the alley aforesaid. a
distance of 110 feet.
BEING improved with a brick dwelling house and known as No. 533 North 1406-20-1793-095.
TAX MAP NUNIBER is 06-20-1798-095.
TITLE TO SAID PREMISES IS VESTED IN Gary B. Davis by Deed from Dale M. Carey, Jr.
dated 5119/98 recorded 614/93 in Deed Book 173 Page 673.
WRIT OF EXECUTION and/or ATTACHMENT
COMMONWEALTH OF PENNSYLVANIA) NO. 99-3031 CIVIL W Term
COUNTY OF CUMBERLAND) CIVIL ACTION - LAW
TOTHESHERIFFOF omberlana COUNTY:
To satisfy the debt, interest and costs due GE Capital Mortgage Services. Inc.
PLAINTIFF(S)
from Gary Davis A/K/A Gary B Davis 8 North P' r rl;al Pa 1701
DEFENDANT(S)
(1) You are directed to levy upon the property of the defendant(s) and to sell
538 North Pitt Street Carlisle Pa 17013
(2) You are also directed to attach the property of the defendant(s) not levied upon in the possession of
as follows:
and to notify the garnishee(s) that: (a) an attachment has been issued; (b) the garnishee(s) is/are enjoined from paying any
debt to or for the account of the defendant(s) and from delivering any property of the defendant(s) or otherwise disposing
thereof;
(3) Ifpropertyofthedefendant(s)notlevieduponansubjecttoattachment isfoundinthepossession ofanyoneother
than a named garnishee, you are directed to notify him/her that he/she has been added as a garnishee and is enjoined as above
stated.
Amount Due S 86 988 58 L.L.
Int. Fran 7/14/99 to 12/08/99(Per Diem $14.30D
Interest 2 116 40 ue Prothy
Ally's Comm -%
Other Costs
Ally Paid 101 10
Plaintiff Paid
Date: July 16. 1999
Curtis R. Lon
nProthonotary, Civil Division
by: _ .,.? C2 -ALpQ.. i
Deputy
REQUESTING PARTY:
Name Frank. Federnian, Esq.
Address.TwQ Penn Center. Plaza. Suite 900
Philadelpbia. Pa. 1910
Attorney for: p1 a; nri ff
Telephone: _?2?Sai-77900
Supreme Court ID No. 12248
A-1 [A L L
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THE PATRIOT NEWS
THE SUNDAY PATRIOT NEWS
Proof of Publication
Under Rct No 587. Booroued May 16. 1929
Commonwealth of Pennsylvania, County of Dauphin) as
Michael Morrow being duly sworn according to law, deposes and says:
That he is the Assistant Controller of THE PATRIOT-NEWS CO., a corporation organized and existing under the laws
of the Commonwealth of Pennsylvania, with its principal office and place of business at 812 to 818 Market Street, in
the City of Harrisburg, County of Dauphin, State of Pennsylvania, owner and publisher of THE PATRIOT-NEWS and
THE SUNDAY PATRIOT-NEWS newspapers of general circulation, printed and published at 812 to 818 Market Street,
in the City, County and State aforesaid; that THE PATRIOT-NEWS and THE SUNDAY PATRIOT-NEWS were established
March 4th, 1854, and September 18th, 1949, respectively, and all have been continuously published ever since;
That the printed notice or publication which is securely attached hereto is exactly as printed and published in
their regular daily and/or Sunday and Metro editions/issues which appeared on the 26th day of October and the 2nd
and 9th day(s) of November 1999. That neither he nor said Company is interested in the subject matter of said
printed notice or advertising, and that all of the allegations of this statement as to the time, place and character of
publication are true; and
That he has personal knowledge of the facts aforesaid and is duly authorized and empowered to verify this
statement on behalf of The Patriot-News Co, aforesaid by virtue and pursuant to a resolution unanimously passed and
adopted severally by the stockholders and board of directors of the said Company and subsequently duly recorded in
the office for the Recording of Deeds in and for said Coµt tN of Dauphin in Miscellaneous Book "M",
Volume 14, Page 317. I I ?` J'`
PUBLICATION `
-
COPY e ore a ih 18th da?gf Novemb r 19 A.D.
Swo
S A L E #18 nn
ry ublic lj
tr NOTA PUBLIC
June 6.2002
Member, Pennsymnnia FssociatiunMy commission expires June 6, 2002
CUMBERLAND COUNTY SHERIFFSOFRCE
COURTHOUSE
CARLISLE, PA. 17013
Statement of Advertising Costs
To THE PATRIOT-NEWS CO., Dr.
For publishing the notice or publication attached
' hereto on the above stated dates $ 199.13
Probating same Notary Fee(s) $ 1.50
Total $ 200.63
Publisher's Receipt for Advertising Cost
THE PATRIOT-NEWS CO., publisher of THE PATRIOT-NEWS and THE SUNDAY PATRIOT-NEWS, newspapers of general
circulation, hereby acknowledge receipt of the aforesaid notice and publication costs and certifies that the same have
been duly paid. THE PATRIOT-NEWS CO.
By ...............................................................:....
I
I
PROOF OF PUIILICATION OF NOTICE
IN CUMBERLAND LAW JOURNAL
(Under Act No. 587, approved May 16, 1929), P. L.1784
STATE OF PENNSYLVANIA :
COUNTY OF CUMBERLAND :
ss.
Roger M. Morgenthal, Esquire, Editor of the Cumberland Law Journal, of the County
and State aforesaid, being duly sworn, according to law, deposes and says that the Cumberland
Law Journal, a legal periodical published in the Borough of Carlisle in the County and State
aforesaid, was established January 2, 1952, and designated by the local courts as the official legal
periodical for the publication of all legal notices, and has, since January 2, 1952, been regularly
issued weekly in the said County, and that the printed notice or publication attached hereto is
exactly the salve as was printed in the regular editions and issues of the said Cumberland Law
Journal on the following dates,
viz:
OCTOBER 22, 29, NOVEMBERS, 1999
Affiant further deposes that he is authorized to verify this statement by the Cumberland
Law Journal, a legal periodical of general circulation, and that he is not interested in the subject
matter of the aforesaid notice or advertisement, and that all allegations in the foregoing
statements as to time, place and character of publication are true.
REAL ESTATE RAZE NO. IS
Wilt No. 99-3031 Civil
GE Capital Mortgage Services. Inc.
VS.
Gary Davis, a/k/a Gary D. Davis
Atty.: Frank Federman
DESCRIIMON
ALLTIIAT CERTAIN niessuage and
lot of ground situate in the Borough
of Carlisle, County of Cumberland
and Conunonwealth of Pennsylvania.
bounded and described as follows. to
wit:
BOUNDED on tile East by Pitt
Strree on the South by lot, now or
late of Allxit K. Myers; on the West
by an alley; and on the North by "B"
Street.
Roger M.Morgentlial, Editor
SWORN TO AND SUBSCRIBED before me this
5 day of NOVEMBER. 1999
1016 E. SNMER, Notary Pvblk
Corals 6oro, Cumbsriond County, PA
My Commission Exp:rrs March 3, 2001
Previous Image
Refilmed to Correct
Possible Error
PROOF OF PUBLICATION OF NOTICE
IN CUMBERLAND LAW JOURNAL
(Under Act No. 587, approved May 16, 1929), P. L.1784
STATE OF PENNSYLVANIA :
COUNTY OF CUMBERLAND :
ss.
Roger M. Morgenthal, Esquire, Editor of the Cumberland Law Journal, of the County
and State aforesaid, being duly sworn, according to law, deposes and says that the Cumberland
Law Journal, a legal periodical published in the Borough of Carlisle in the County and State
aforesaid, was established January 2, 1952, and designated by the local courts as the official legal
periodical for the publication of all legal notices, and has, since January 2, 1952, been regularly
issued weekly in the said County, and that the printed notice or publication attached hereto is
exactly the same as was printed in the regular editions and issues of the said Cumberland Law
Journal on the following dates,
viz:
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 that he is not interested in the subject
matter of the aforesaid notice or advertisement, and that all allegations in the foregoing
statements as to time, place and character of publication are true.
REAL ESTATE SATE. NO. 18
Writ No. 99-3031 Civil
GE Capital Mortgage Services. Inc.
V5.
Gary Davis, a/k/a Gary B. Davis
Atty.: Frank Federman
DESCRIPTION
ALL THAT CERTAIN messuage and
lot of ground situate In the Borough
of Carlisle. County of Cumberland
and Commonwealth of Pennsylvania,
bounded and described as follows, to
wit:
BOUNDED on the East by nit
Surel: on the South 13), lot, now or
late of Albert K. Myers: on the West
by an alley; and on the North by "B"
Street.
1 IIAViNG a fnmtage of 15-1 /2 feel
oil Pat Street and esaending in depth
to the alley aforesaid, a distance of
110 feet.
BEING unproved with a brick
dwelling house and luaown as No.
538 North 1400-20.1798-095.
TAX MAP NUMBER Is 00-20.
1798-OJ5.
TITLE TO SAID PREMISES IS
VESTED IN Gary il. Davis by Dred
from Dale M. Cairy.Jr. dated 5/19/98
recorded 6/4/98 111 Decd Bank 178
Page 678.
Roger M. Morgenthal, Editor
SWORN TO AND SUBSCRIBED before me this
5 day of NOVEMBER, 1999
L016 E. SNYDElt, Notary Public
CodiJe Soro, Cumbodand County, PA
Mr CommitGiwt Expires Morch 3, 2001
RE AL ESTATE SALE NO 18
S1,000.00Ad•.anceCosts Paid 7/23/99 Am. Frank Federman
Assessed Valuation S 2560.00
WRIT NO. 99-3031 Civil
GE Capital Mortgage Services Inc.
VS
Gary. Davis, A/K/A Gary B., Davis
538 North Pitt Street
Carlisle, PA 17013 "
REAL DEBT $ 86,988.58
INTEREST fr 7/14/99 to 12/8/99 @ 14.30 per diem
ATT SFEES 2,116.40
ZNT UT COSTS -1.T Y 101.10
ESCROW
LATE CHA.RGE
SHERIFFS COSTS
Docketing 30.00
Poundage 11.70
Postine Bills 15.00
Advenisine 15.00
Ackno<<ledo_in_s Dee_ 30.00
Auctioree: 10.00
Law Libras' .50
Counn- 1.00
Vlilta^e 6.20
Cea `fail .74
Levy. 15.00
Postpone Sale
Surcharge 16.00
Le•ral Starch
=.Dt'ERTISTNGi
Lrc Journal 170.00
Patriot 200.63
Share of Bills 23.63
Distribution of Process 25.00
Sh?af.`s Deeds 26.50
STA NIPS
Pa. T:anafe: Tax
T«T or Boro Trans,`tr Tas
TAXES
w
1 -
f
rrrrre i
OFFICE OF THE PROTHONOTARY
CUI4BERLAND COUNTY COURTHOUSE me y
SOUTH HANOVER STmtLT
CARLISLE, PA 170137`;;;
tav
GARY B. DA DAVIS,A/K/A
GARY B. DAMS
538 NORTH PITT STREET
CARLISLE, PA 17013
AT01'?-1'i 4? 09 ?n????ni???nnn??????i ni?????n???.??n ??n????n?n??u?
?i
?
ti
I
(Rule of Civil Procedure No. 236) - Revised
IN THE COURT OF COMMON PLEAS OF CUMBERLAND COUNTY, PENNSYLVANIA
CIVIL ACTION - LAW
GE CAPITAL MORTGAGE SERVICES, INC.
Plaintiff
VS.
GARY DAVIS, A/K/A GARY B. DAVIS
Defendants
NO. 99-3031 CIVIL
Notice is given that a Judgment in the above-captioned
matter has been entered against you on JULY
1999.
By: DEPUTY
contact: If you have any questions concerning this matter, please
??'
FRANM gDERMAN ES- pUZ.
Attorney for Party Filing
Two Penn Center Plaza, Suite 900
Philadelphia, PA 19102
(215) 563-7000
**THIS FIRM IS A DEBT COLLECTOR ATTEMPTING TO COLLECT A
DEBT AND ANY INFORMATION OBTAINED WILL BE USED FOR
THAT PURPOSE. IF YOU HAVE PREVIOUSLY RECEIVED A
DISCHARGE IN BANKRUPTCY, THIS IS NOT AND SHOULD NOT BE
CONSTRUED TO BE AN ATTEMPT TO COLLECT A DEBT, BUT
ONLY ENFORCEMENT OF A LIEN AGAINST PROPERTY.**
FEDERMAN AND PHELAN
By: FRANK FEDERMAN
Identification No. 12248
TWO Penn Center Plaza - Suite 900
Philadelphia, PA 19102
(2151 563-7000
Attorney for Plaintiff
GE CAPITAL MORTGAGE SERVICES, INC. CUMBERLAND COUNTY
4680 HALLMARK PARKWAY COURT OF COMMON PLEAS
SAN BERNARDINO, CA 92407
VS, CIVIL DIVISION
GARY DAVIS, A/K/A GARY B. DAVIS
538 NORTH PITT STREET
CARLISLE, PA 17013 NO. 99-3031 CIVIL
PRAECIPE FOR JUDGMENT FOR FAILURE TO
ANSWER AND ASSESSMENT OF DAMAGES
TO THE PROTHONOTARY:
Kindly enter judgment in favor of the Plaintiff and against
GARY DAVIS, A/K/A GARY B DAVIS, 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 - 5/1/99 TO 7/14/99
TOTAL
$85,566.58
$ 1,422.00
$86,988.58
I hereby certify that (1) the addresses of the Plaintiff and
Defendant(s) are as shown above, and (2) that notice has been given
in accordance with Rule 237.1, copy attached.
'?XaAL
FRANK FEDERKAN, ESQUIRE
Attorney for Plaintiff
DAMAGES ARE HEREBY ASSESSED AS INDICATED.
DATE: t' 1491 / ,..rte U 7k //
;
PRO PROTHY " 7 7
FEDERMAN AND PHELAN
Frank Federman, Esquire
Identification No. 12248
Two Penn Center Plaza
Suite 900
Philadelphia, PA 19102-1799
(215) 563-7000
GE CAPITAL MORTGAGE SERVICES,
INC.
Plaintiff
VS.
GARY DAVIS,
A/K/A GARY B. DAVIS
Defendant(s)
T0: GARY DAVIS
A/K/A GARY B. DAVIS
538 NORTH PITT STREET
CARLISLE, PA 17013
DATE OF NOTICE: JUNE 18, 1999
ATTORNEY FOR PLAINTIFF
. COURT OF COMMON PLEAS
. CIVIL DIVISION
CUMBERLAND COUNTY
NO. 99-3031 CIVIL
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 BAR ASSOCIATION
2 LIBERTY AVENUE
CARLISLE, PA 17013
(717) 249-3166
Frank Federman., Esquire
Attorney for Plaintiff