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Home My WebLink About99-03698V V Q :" ..4d 'C i FEDERMAN AND PHELAN BY: Lisa D. Blankenburg, Esq. Atty. I.D. 478020 Ste. 900/Two Penn Center Plaza Philadelphia, PA 19102 (215) 563-7000 CONTI MORTGAGE CORPORATION VS. THERESA J. DETWILER, A/K/A THERESA J. GRIMES ATTORNEY FOR PLAINTIFF COURT OF COMMON PLEAS CIVIL DIVISION CUMBERLAND COUNTY No. 99-3698-CIVIL ORDER /I AND NOW, this day of 1999, upon consideration of Plaintiff's Motion and the Affidavit of Good Faith Investigation attached thereto, it is hereby ORDERED that Plaintiff may obtain service of the complaint on the above captioned Defendant(s), THERESA J. DETWILER, A/K/A THERESA J. GRIMES , by mailing a true and correct copy of the complaint by certified mail and regular mail to the defendant's last known address and to the mortgaged premises at 159 SOUTH BEDFORD STREET, CARLISLE, PA 17013. Service of the aforementioned mailings is effective upon the date of mailing and is to be done by Plaintiff's attorney, who will file with the Prothonotary's Office an Affidavit as to--the mailing. BY THE COURT: ALFD-OMCE OF T-, 'n .01'OTAAy 99 OCT 26 API 8: 19 coum PEN4\SYLVANLA FEDERMAN AND PHELAN ATTORNEY FOR PLAINTIFF BY: Lisa D. Blankenburg, Esq. Atty. I.D. #78020 Ste. 900/Two Penn Center Plaza Philadelphia, PA 19102 1215) 563-7000 CONTI MORTGAGE CORPORATION COURT OF COMMON PLEAS CIVIL DIVISION CUMBERLAND COUNTY VS. No. 99-3698-CIVIL THERESA J. DETWILER, A/K/A THERESA J. GRIMES MOTION FOR SERVICE PURSUANT TO SPECIAL ORDER OF COURT Plaintiff, by its counsel, Lisa D. Blankenburg, Esquire, moves this Honorable Court for an Order directing service of the Complaint upon the above-captioned Defendant(s) by Certified mail and regular mail to the defendant's last known address and mortgaged premises, 159 SOUTH BEDFORD STREET, CARLISLE, PA 17013 and in support thereof avers the following: 1. Attempts to serve Defendant(s) with Complaint have been unsuccessful, as indicated by the Sheriff's Return of Service by the Sheriff's Office attached hereto as Exhibit "A". 2. Pursuant to Pennsylvania Rule of Civil Procedure 430, Plaintiff has made a good faith effort to locate the Defendant(s). An Affidavit of Good Faith Investigation setting forth the specific inquiries made and the results therefrom is attached hereto as exhibit "B". WHEREFORE, Plaintiff respectfully requests this Honorable Court enter an Order pursuant to Pennsylvania Rule of Civil Procedure 430 directing service of the Complaint by certified mail and regular mail. Lisa D. Bla ]enburg, Esquire ATTORNEY FO PLAINTIFF FEDERMAN AND PHELAN ATTORNEY FOR PLAINTIFF BY: Lisa D. Blankenburg, Esq. Atty. I.D. 478020 Ste. 900/Two Penn Center Plaza Philadelphia, PA 19102 (215) 563-7000 CONTI MORTGAGE CORPORATION COURT OF COMMON PLEAS CIVIL DIVISION CUMBERLAND COUNTY VS. No. 99-3698-CIVIL THERESA J. DETWILER, A/K/A THERESA J. GRIMES MEMORANDUM OF LAW Pennsylvania Rule of Civil Procedure 430(a) specifically provides: (a) If service cannot be made under the applicable rule, the plaintiff may move the Court for a special order directing the method of service. The Motion shall be accompanied by an Affidavit stating the nature and extent of the investigation which has been made to determine the whereabouts of the Defendant(s) and the reasons why service cannot be made. Note: A Sheriff's return of "Not Found" or the fact that a Defendant has moved without leaving a new forwarding address is insufficient evidence of concealment. Gonzales vs. Polis, 238 Pa. Super. 362, 357 A.2d 580 (1976). "Notice of intended adoption mailed to last known address requires a good faith effort to discover the correct address." Adoption of Walker, 468 Pa. 165, 360 A.2d 603 (1976). An illustration of good faith effort to locate the defendant includes (1) inquires of postal authorities including inquiries pursuant to the Freedom of Information Act, 39 C.F.R. Part 265, (2) inquiries of relatives neighbors, friends and employers of the Defendant and (3) examinations of local telephone directories, voter registration records, , local tax records, and motor vehicle records. As indicated by the attached Sheriff's Return of Service, marked hereto as Exhibit "A", the Sheriff has been unable to serve the Complaint. A good Faith effort to discover the whereabouts of the Defendant(s) has been made as evidenced by the attached Affidavit of Good Faith Investigation, marked Exhibit "B". WHEREFORE, Plaintiff respectfully requests service of the Complaint by certified mail and regular mail to the defendant's last known address. T psubmitted: Lisa D. Blank nburg, Esquire Attorney for Plaintiff SHERIFF'S RETURN - NOT FOUND CASE NO: 1999-03698 P COMMONWEALTH OF PENNSYLVANIA: COUNTY OF CUMBERLAND CONTIMORTGAGE CORPORATION VS. DETWILER THERESA J R. Thomas Kline , Sheriff, who being duly sworn according to law, says, that he made a diligent search and inquiry for the within named defendant, to wit: DETWILER THERESA J A/K/A THERESA J GRIMES but was unable to locate Her in his bailiwick. He therefore returns the NOTICE AND COMPLAINT IN MORTGAGE FORECLOSURE NOT FOUND , as to the within named defendant DETWILER THERESA J A/K/A THERESA J GRIMES DEFT. COULD NOT BE SERVED PRIOR TO EXPIRATION DATE, IS ALSO BELEIVED TO BE LIVING IN SHIPPENSBG Sheriff's Costs: So answe s: Docketing 18.00 Service .20 Not Found Return 5.00 Surcharge 8.00 A `Thomas 1ne, Snerlf $37ZQ 0FEDER 7M & 1999 PHELAN 7/20 Sworn and subscribed to before me this day of 19 A.D. ono ary - AFFIDAVIT OF GOOD FAITH INVESTIGATION Loan Number: File Number: Attorney Firm: Federman & Phelan Subject: Theresa J. Grimes Last Known Address: 159 South Bedford Street Carlisle, PA 17013 Current Address: 159 South Bedford Street Carlisle, PA 17013 Mailing Address: 159 South Bedford Street Carlisle, PA 17013 Last Known Number: 717-249-3478 George H. Lewis, III, being duly sworn according to law, deposes and says: I. I am employed in the capacity of President of EKL DATA, INC. 2. On October 13, 1999, I conducted an investigation into the whereabouts of the above named defendant(s). The results of my investigation are as follows: I. Credit Information A. Social Security Number `41yl?7p/ 1. Theresa J. Grimes: 180-26-6068 ?e B. Employment Search: Could not locate any employment for the above named subject. C. Inquiry of Creditors: The creditors indicated that Theresa J. Grimes resides at 159 South Bedford Street, Carlisle, PA 17013. AFFIDAVIT OF GOOD FAITH INVESTIGATION II. Inquiry of Telephone Company A. Directory Assistance Search: The Telephone Company has Theresa J. Grimes listed with an address of 159 South Bedford Street, Carlisle, PA 17013. The phone number is 717-249-3478. III. Inquiry of Neighbors Contacted Mr. Vaughn of 157 South Bedford Street, Carlisle, PA 17013 and verified that Theresa J. Grimes does Indeed reside at 159 South Bedford Street. IV. Inquiry of Post Office A. National Address Update: As of October 13,1999 the National Change of Address has Theresa J. Grimes listed at 159 South Bedford Street, Carlisle, PA 17013. V. Inquiry of DMV The Pennsylvania Department of Motor Vehicles has Theresa J. Grimes listed at 159 South Bedford Street, Carlisle, PA 17013. VI. Other Inquiries A. Death Records: As of October 13, 1999 the Social Security Death Index has no death record on file for Theresa J. Grimes under her social security number. B. Public Licenses None found C. County Voter Registration: The county does not have Theresa J. Grimes listed as a registered voter with an address of 159 South Bedford Street, Carlisle, PA 17013. D. A.K.A.: None E. D.O.B.: Theresa J. Grimes: 1933 AFFIDAVIT OF GOOD FAITH INVESTIGATION F. Miscellaneous Information None 4rge H Lewis 111 Subscribed and sworn before me. ll 31 99 ' Otary Public . - / v ?yzelrs ? ?. i e;??rV PuhGc IF T V E R I F I C A T I O N Lisa D. Blankenburg, Esquire, hereby states that she is the Attorney for the Plaintiff in this action, that she is authorized to take this Affidavit, and that the statements made in the foregoing MOTION FOR SERVICE OF THE COMPLAINT PURSUANT TO SPECIAL ORDER OF COURT are true and correct to the best of her knowledge, information and belief. The undersigned understands that this statement herein is made subject to the penalties of 18 Pa. C.S. Sec. 4904 relating to unsworn falsification to authorities. October 18, 1999 IL12- - Lisa D. Blan enburg, Esquire Attorney for Plaintiff i V 11 ?? 1. I 1 1. 1 1 l? l _' V ? ? '`Y33 v WMI LIL WMIN w01 W)(/[W A'I Tu1F.i?1?1 X111• YY 1'??xx?u..(IY fY110 IYIIII IIYI'i IIY• 1 (Rule of Civil Procedure No. 236 - Revised) CONTINIORTGAGE CORPORATION Plaintiff VS. TIIERI.SA.I. DETWILER AJK/A TIIERESA ,1. GRINIES : CUMBERLAND COUNTY Court of Common Pleas : CIVIL DIVISION : NO. 99-3698-CIVIL Defendant(s) Notice is given that a Judgment in the above captioned matter has been entered against you on DECEMBER 3 ft.- , 1999. By u- a• )ha DEPUTY II you have any questions concerning this matter, please contact: FRANK FEDERMAN. ESQUIRE Attorney for Filing Party SUITE 900 TWO PENN CENTER PLAZA 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 AND THIS DEBT WAS NOT REAFFIRMED, THIS IS NOT AND SHOULD NOT BE CONSTRUED TO BE AN ATTEMPT TO COLLECT A DEBT, BUT ONLY ENFORCEMENT OF A LIEN AGAINST PROPERTY. «. FEDERMAN AND PHELAN By: FRANK FEDERMAN Identification No. 12248 Two Penn Center Plaza - Suite 900 Philadelphia, PA 19102 (215) 563-7000 CONTIMORTGAGE CORPORATION 338 S. WARMINSTER ROAD HATBORO, PA 19040 Plaintiff Attome}' for Plaintiff CUMBERLAND COUNTY : COURT OF COMMON PLEAS : CIVIL DIVISION Vs. NO. 99-3698-CIVIL THERESA.I. DETWILER A/K/A THERESA J. GRIMES 159 S. BEDFORD STREET CARLISLE, PA 17013 Defendant(s) PRAECIPE FOR JUDGMENT FOR FAILURE TO ANSWER AND ASSESSMENT OF DAMAGES TO THE PROTHONOTARY: Kindly enter judgment in favor of the Plaintiff and against THERESA J. DETWILER A/K/A THERESA J. GRIMES, Defendant(s), for failure to file an Answer to Plaintiffs Complaint within 20 days from service thereof and for foreclosure and sale of the mortgaged premises. and assess Plaintiffs damages as follows: As set forth in Complaint S59,965.51 Interest 4/1/99 to 12/29/99 54.742.01 TOTAL 564,70752 I hereby certify that (1) the addresses of the Plaintiff and Defendant(s) are as shown above. and (2) notice has been given in accordance with Rule 237. 1. copy attached. JFRANK FEDERtMAN. ESQUIRE Attorney for Plaintiff DAMAGES ARE HEREBY ASSESSED AS INDICATED. DATE: PRO PROTHY '•'I'IIIS FIRM IS A DEBT COI.I.I.CrOll AITEMI'I INN TO C0L1.F.('1'.\ DEBT AND AN) INFORMATION OBTAINED 11'11.1. BE I SEO FOR )11.11. V(.RPOSE. IF M ILM- I'14F:1'lot SI.1 I(E('El\ EU:1 U6(11.1RGF: i.\ B.1N F:RII'ff T:1ND"1'1113 ur.fil vs N'OT RE.\FFIRIIED, I IIIS('ORRF.M'ONDENCE IS NOI".\NI)Sllol I.D N0T BE CONS I'la ED 10 ]-1 EMIT I'o COI.LF.CF A DEIST. BI'T ONIA F.NFORCENIEN.I' OF A LIEN AGAINS I' PROVERT1'. •. FEDERMAN AND PHELAN Frank Federman, Esquire Identification No. 12248 Two Penn Center Plaza Suite 900 Philadelphia, PA 19102-1799 (215) 563-7000 ATTORNEY FOR PLAINTIFF CONTIMORTGAGE CORPORATION COURT OF COMMON PLEAS Plaintiff VS. THERESA J. DETWILER, A/K/A THERESA J. GRIMES CIVIL DIVISION : CUMBERLAND COUNTY . NO. 99-3698-CIVIL Defendant(s) TO: THERESA J. DETWILER, A/K/A THERESA J. GRIMES 159 SOUTH BEDFORD STREET CARLISLE, PA 17013 DATE OF NOTICE: DECEMBER 15, 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 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 FEDERMAN and PHELAN By: FRANK FEDERMMAN Identification No. 12248 Suite 900 Two Penn Center Plaza Philadelphia, PA 19102 (215)56=-,7000 CONTIMORTGAGE CORPORATION Plaintiff Vs. Attorney for Plaintiff :CUMBERLANDCOUNTY : Court of Common Pleas : CIVIL DIVISION THERESA.I. DETWILER : NO. 99-3698-CIVIL A/K/A THERESA J. GRINIES Defendant(s) VERIFICATION OF NON-MILITARY SERVICE FRANK FEDERMAN, ESQUIRE, herebv verities that he is attorney for the Plaintiff in the above-captioned matter, and that on information and belief, he has knowledee 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 THERESA J. DETWILER A/K/A THERESA J. GRIMES is over 18 years of age and resides at 159 S. BEDFORD STREET, CARLISLE, PA 17013. This statenment is made subject to the penalties of 18 Pa. C.S. Section 4904 relating to unswom falsification to authorities. FRANK FEDERMAN Attorney for Plaintiff FEDERMAN AND PHELAN By: FRANK FEDERMAN Identification No. 12248 Two Penn Center Plaza - Suite 900 Philadelphia, PA 19102 (215) 563-7000 Attorney for Plaintiff CONTIMORTGAGE CORPORATION 338 S. WARMINSTER ROAD HATBORO, PA 19040 Plaintiff VS. THERESA J. DETWILER A/K/A THERESA J. GRIMES 159 S. BEDFORD STREET CARLISLE, PA 17013 Defendant(s) : CUMBERLAND COUNTY COURT OF COMMON PLEAS : CIVIL DIVISION : NO. 99-3698-CIVIL PRAECIPE FOR JUDGMENT FOR FAILURE TO ANSWER AND ASSESSMENT OF DAMAGES TO THE PROTHONOTARY: Kindly enterjudgment in favor of the Plaintiff and against THERESA J. DETWILER A/K/A THERESA J. GRIMES, Defendant(s), for failure to file an Answer to Plaintiffs Complaint within 20 days from service thereof and for foreclosure and sale of the mortgaged premises, and assess Plaintiffs damages as follows: As set forth in Complaint Interest 4/1/99 to 12/29/99 TOTAL 559,965.51 54.742.01 $64,707.52 I hereby certify that (1) the addresses of the Plaintiff and Defendant(s) are as shown above, and (2) 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: AJ??_x.l,? . u i119ri ( i. ,. J... 4 ? ?= PROP OiXHY "TIIIS FIRM IS A DEBT COLLECTOR Al'I'41.111''I'IN(;'10 COLLECI' A DFB I AND AM' INFOIt\IA'170\ 011'1',%INED \\'ILI. BE 1'SED FOR I IIAl' M'RI'lriE. IF )01 II,\1'I: PRIA [OI SL% RI:(7(IN LI),\ DIS('I IAIWE IN RANKRI'P I'C) AND TI [IS I)EB1' %VAS NO I' REAFFIRMED, 111 IS('( IRRESPONDF.N('E IS NOT ANDSI lot LD NOI' BF( ONS I HIED 'TO RE AN,\'I'Tt:,1tF'1"I'OCOLLECI' ,\ DER I" BI' l' ONLV ENFOW E\IEN'I OF A LIEN AGAINS1' PROPER IY. " " y. F,EDERMAN AND PHELAN Frank Federman, Esquire Identification No. 12248 Two Penn Center Plaza Suite 900 Philadelphia, PA 19102-1799 (215) 563-7000 ATTORNEY FOR PLAINTIFF CONTIMORTGAGE CORPORATION COURT OF COMMON PLEAS Plaintiff Vs. THERESA J. DETWILER, A/K/A THERESA J. GRIMES . CIVIL DIVISION : CUMBERLAND COUNTY . NO. 99-3698-CIVIL Defendant(s) TO: THERESA J. DETWILER, A/K/A THERESA J. GRIMES 159 SOUTH BEDFORD STREET CARLISLE, PA 17013 DATE OF NOTICE: DECEMBER 15, 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 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 q1445?- Frank Federman, Esquire Attorney for Plaintiff FEDERMAN and PHELAN By: FRANK FEDERMAN Identification No. 12248 Suite 900 Two Penn Center Plaza Philadelphia, PA 19102 (215) 563-7000 CONTIMORTGAGE CORPORATION Plaintiff VS. Attorney for Plaintiff CUMBERLAND COUNTY Court of Common Pleas : CIVIL DIVISION THERESA J. DETWILER : NO. 99-3698-CIVIL A/K/A THERESA J. GRIMES Defendant(s) VERIFICATION OF NON-MILITARY SERVICE FRANK FEDERMAN, ESQUIRE, hereby verifies that he is attorney for the Plaintiff in the above-captioned matter, and that on information and belief, he has knowledge 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 THERESA J. DETWILER A/K/A THERESA J. GRIMES is over 18 years of age and resides at 159 S. BEDFORD 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. 214in? FRANK FEDERMAN Attorney for Plaintiff (Rule of Civil Procedure No. 236 - Revised) CONTIMORTGAGE CORPORATION Plaintiff VS. THERESA J. DETWILER AIK/A THERESA J. GRIMES : CUMBERLAND COUNTY : Court of Common Pleas : CIVIL DIVISION : NO. 99-3698-CIVIL Defendant(s) Notice is given that a Judgment in the above captioned matter has been entered against you on DECEMBER 30 = . 1999. By?? .,•._ t:. ) ,4L. , DEPUTY If you have any questions concerning this matter, please contact: FRANK FEDERMAN, ESQUIRE Attorney for Filing Party SUITE 900 TWO PENN CENTER PLAZA 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 AND THIS DEBT WAS NOT REAFFIRMED, THIS IS NOT AND SHOULD NOT BE CONSTRUED TO BE AN ATTEMPT TO COLLECT A DEBT, BUT ONLY ENFORCEMENT OF A LIEN AGAINST PROPERTY. ** 1 j G G P P nl d ^I J 94 J V q` CASE NO: 1999-03698 P SHERIFF'S RETURN - NOT FOUND COMMONWEALTH OF PENNSYLVANIA: COUNTY OF CUMBERLAND CONTIMORTGAGE CORPORATION VS. DETWILER THERESA J R. Thomas Kline , Sheriff, who being duly sworn according to law, says, that he made a diligent search and inquiry for the within named defendant, to wit: DETWILER THERESA J A/K/A THERESA J GRIMES but was unable to locate Her in his bailiwick. He therefore returns the NOTICE AND COMPLAINT IN MORTGAGE FORECLOSURE NOT FOUND , as to the within named defendant DETWILER THERESA J A/K/A THERESA J GRIMES DEFT. COULD NOT BE SERVED PRIOR TO EXPIRATION DATE, IS ALSO BELEIVED TO BE LIVING IN SHIPPENSBG Sheriff's Costs: So answe s: Docketing 18.00 Service 6 20 / . Not Found Return 5.00e?? ?..- Surcharge 8.00 mas e, eri & PHELAN $-3 FEDERMAN 9 9 07/20/19 Sworn and subscribed to before me this u 136 day of 199') A.D. ?J, 0. ? , ??rornonotary FEDERMAN AND PHELAN By: FRANK FEDERMAN, ESQUIRE IDENTIFICATION NO. 12248 TWO PENN CENTER PLAZA, SUITE 900 PHILADELPHIA, PA 19102 12151 563-7000 CONTIMORTGAGE CORPORATION 338 SOUTH WARMINSTER ROAD HATBORO, PA 19040 V. Plaintiff THERESA J. DETWILER, A/K/A THERESA J. GRIMES 159 SOUTH BEDFORD STREET CARLISLE, PA 17013 Defendant(s) ATTORNEY FOR PLAINTIFF COURT OF COMMON PLEAS CIVIL DIVISION TERM No. 9? •3G 9s' CUMBERLAND COUNTY CIVIL ACTION - LAW 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. We hereby certify the within to De a true and correct copy of the original filed of record FEDERMAN AND PHELAN CUMBERLAND COUNTY CUMBERLAND COUNTY 2 LIBERTY AVENUE CARLISLE, PA 17 013 (717) 249-3166 BAR ASSOCIATION TRUE COPY FROM RECORD in AedZaot hereof. I ha a Mosel my bmw anCo Aisle, Pa. This P thonota 1. Plaintiff is CONTIMORTGAGE CORPORATION 338 SOUTH WARMINSTER ROAD HATBORO, PA 19040 2. The name(s) and last known address(es) of the Defendant(s) are THERESA J. DETWILER, A/K/A THERESA J. GRIMES 159 SOUTH BEDFORD STREET CARLISLE, PA 17013 who is/are the mortgagor(s) and real owner(s) of the property hereinafter described. 3. On 5/9/97 mortgagor(s) made, executed and delivered a mortgage upon the premises hereinafter described to KEYSTONE STATE MORTGAGE CORPORATION which mortgage is recorded in the Office of the Recorder of CUMBERLAND County, in Mortgage Book No. 1383, Page 1089. By Assignment of Mortgage recorded 11/17/97 the mortgage was assigned to PLAINTIFF which Assignment is recorded in Miscellaneous Book No. 562, Page 215. 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 9/14/98 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 $52,551.48 Interest 4,012.47 8/14/98 through 4/1/99 (Per Diem $17.37) Attorney's Fees 2,627.00 Cumulative Late Charges 215.06 5/9/97 to 4/1/99 Cost of Suit and Title Search 550.00 Subtotal 59,956.01 Escrow Credit 0.00 Deficit 9.50 Subtotal 9.50 TOTAL $59,965.51 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 "B"• 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.O. S 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 ii em Judgment against the Defendant(s) in the sum of $59,965.51, together with interest from 4/1/99 at the rate of $17.37 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 FEDERMAN AND PHELAN Suite 900 Two Penn Center Plaza Philadelphia, PA 19102-1799 215-241-1711 Fax: 215-568-7617 Representing Lenders in Pennsylvania and New Jersey May 12, 1999 Theresa J. Detwiler, a/k/a Theresa J. Grimes 159 S. Bedford Street Carlisle, PA 17013 Re: Premises: 159 South Bedford Street, Carlisle, PA 17013 Loan No.: 0004411203 NOTICE OF INTENTION TO FORECLOSE We represent ContiMortgage Corp., 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 $4,578.95 for the months of 9/14/98 through 4/14/99. Your failure to pay the delinquent amount, plus any additional monthly payment and late and other charges (including any accrued interest) that may come due within the next thirty (30) days, will result in the acceleration of all sums due under your Mortgage. After acceleration occurs, a foreclosure action or any other remedy permitted by your mortgage may be instituted. To avoid the acceleration of your mortgage and subsequent foreclosure action, the delinquency mentioned above and any accrual EXHIBIT A thereto must be paid by CERTIFIED CHECK OR MONEY ORDER and received in our offices at Suite 900, Two Penn Center Plaza, Philadelphia, PA 19102, in or before thirty (30) days from the date of this letter. Please call (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 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. Very truly yours, FEDERMAN AND PHELAN Frank Federman FF:ll CC: ContiMortgage Corp. (Hatboro, PA) Attn:Kymberlee Lescas Loan No.: 0004411203 EXHIBIT A ACT 91 NOTICE TAKE ACTION TO SAVE YOUR HOME FROM FORECLOSURE 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. The Commonwealth of Pennsylvania's Homeowner's 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 notificacion en adjunto es de suma importancia, pues afecta su derecho a continuar viviendo en su Casa. Si no comprende e1 contenido de esta notificacion obtenga una traduccion immediatamente llamanda esta agencia (Pennsylvania Housing Finance Agency) sin cargos a1 numero mencionado arriba. Puedes ser elegible Para un prestamo par el programa llamado "Homeowner's Emergency Mortgage Assistance Program" el cual puede salvar su Casa de la perdida del derecho a redimir su hipoteca. ACT 91 NOTICE IPIPORTANT: 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 Date May 12, 1999 RE: Account No. 0004411203 Premises:159 South Bedford Street, Carlisle, PA 17013 TO: Theresa J. Detwiler, a/k/a Theresa J. Grimes 159 S. Bedford Street Carlisle, PA 17013 FROM: Federman and Phelan, attorney for ContiMortgage Corp. 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 bo eligible for emergency temporary assistance if your 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 g Under the Act, you are entitled to a temporary stay of foreclosure on your mortgage for thirty (30) days from the date of this Notice. During that time you must arrange and attend a "face-to-face" meeting with a representative of this lender, or with a designated consumer credit counseling agency. The purpose of this meeting is to attempt to work out a repayment plan, or to otherwise settle your delinquency. This meeting must occur in the next (30) days. 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. As representative of the mortgage holder, our name and address is: SEDEMOW AND PHELAN, SUITE 900, TWO PENN CENTER PLAZA, PHILADELPHIA, PA 19102; Telephone Number: (215) 563-7000. The names and address of designated consumer credit counseling 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 failed to pay promptly installments of principal and interest, as required, for a period of at least sixty (60) days. The total amount of the delinquency is $4,578.95. That sum includes the following: Total of Principal plus interest including all accrued late charges, if any: $4,554.95 Property Inspections and NSF check Charges, if any: 0.00 Other charges accrued, if any 24.00 LESS: Suspense (unapplied funds) 0.00 TOTAL DUE: $4,578.95 Your mortgage is also in default for the following reasons: N/A . If you have tried and are unable to resolve this problem at or after your 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 the other time periods set forth in this letter, foreclosure may proceed against your home immediately. Available funds for emergency mortgage assistance are very limited. They will be disbursed by the Agency under the eligibility criteria established by the Act. It is extremely important that your application is accurate and complete in every respect. The Pennsylvania Housing Finance Agency has sixty (60) days to make a decision after it receives your application. During that additional time, no foreclosure proceedings will be pursued against you if you have met the time EXHIBIT 9 requirements set forth above. You will be notified directly by that 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 1-800-342-2397 (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 "Notice of Intention to Foreclose". You must read both notices, since they both explain law. However, rights that you now have under Pennsylvania , if you choose to exercise your rights described in this notice, you cannot be foreclosed upon while you are receiving that assistance. Very truly yours, CDE AN PHELAN Y Frank Federman FF/11 cc: ContiMortage Corp. (Hatboro, PA) Attn:Kymberlee Lescas Loan No.:0004411203 Sent by Regular Mail, Certificate of Mailing (PS Form 3877) EXHI61T e :aw PLY SYLVANU HOCSriG MA.-NCE AGENCY HOstiIEOwr-ER'S E-vIERGE CY.NIORTGAGE .4,SSLST;.NCE PROGRAM CO(rSU ER CREDIT COCNSELL G AGENCIES CRAY FORD Q2LN7Y Booker T. Washington Ceam: 1720 icilacd Street E^.e. PA 16:v'3 (814) 453-5-144 FAX • (814) 453.5749 Greater Eie Cotomunicy Acdan C=c:im-e 18 West Ninth Street E:e, PA 16501 (814) 459=581 FAX 0 (8!4) = 6.0161 Jahn F. Kennedy Center, Inc. 2021 Fast 20th Street E::. PA 16510 (814) 898-0400 FAX s (814) 898-1243 Sberanga Valley Urban}: League. Inc. 601 Indiana Avenue 'ea,:-.?:• ?A 16M (412) 981-5310 CLNIBERLA_\'D COLN-rY Contr.: C._:it Counseling Service of Wese = ?ens !:aa a Inc. 2000 Liaglestown Road Elattshu:3, PA 17102 (717 541•I75i ' FA.X # (912) 131.9589 Fes: al Counseling Services of F-='-;- 31 West 3rd Stet Wa:-esbcro. i =68 (717 i6=•3.85 , Cuban League of Me_opaiitaa :a.sbu 2!07 Nor -6h 4th Street Ra.:3bu:3, PA 17101 ("17 _-59:. FA-X a (717 _3:4459 YWCA of C:isle 301 G. Street Car!s:e, P.4, 170" (717 243-38:8 FAX 3 (717 71.9589 Cc_•aiy Acden Coe=s3iea of the Caoical Res_ioa 15.- Dew • Seen. Ra--sbu.-a. ?A 1-1C- FAX ? (717)_3=.2 i 7 he Pr=svl- aaia Reusing F=c: Agency esr- be reached TOLL FREE at l(800) 342-2-35r EXHIBITS lying and ALL TMT CERTAN or being in thetSecond parcel d of the1Borough of Carlisle, intthe County of Cumberland, and Commonwealth of Pennsylvania, more particularly described in accordance with a survey and plan thereof made by Ernest J. Walker, Professional Engineer, dated 2 June 1964, as follows: BEGIP41% at a point on the eastern side of South Bedford Street, which point is 40.50 feet north of South Street; thence extending along Bedford Street, North 24 degrees East 36.50 feet to a point at the middle of the partition wall between the double frame house; thence extending through the center of said partition wall, South 66 degrees East 60 feet to the line of property now or formerly of John Gibson; thence along said land, South 24 degrees West 36.50 feet to an iron pin at a corner of property now or formerly of Dorothy M. Taylor; thence along the same, North 66 degrees West 60 feet to the point and place of BEGINNING. HAVING THEREON ERECTED the southern one-half of a double frame dwelling house known as No. 159 South Bedford Street. BEING the same premises which David A. KrUac, by his deed dated 20 Outober 1987 and recorded in the Office of the Recorder of Deeds in and for Cumberland County, Pennsylvania, in Deed Book 2, Volume 32. Page 757, granted and conveyed into John W. Harley and Mary E. Hurley, his wife. The said John W. Hurley died or. 19 January 1990 whereby title vested in fee in Mary E. Hurley, the surviving tenant by the entireties, Grantor herein. VERIFICATION Daniel Pratt hereby states that he/she is f ytc tl, jS,,fLf ( OWE of Conti Mortgage Corporation 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. DATE: b' 0q J; 'O -? W "? p ti [. `? 0.' ?' <U T n. n - b n• b ?? <? 5 ? __? ?T ?'?'] - T::. `: 7°' ?_? C ?? n cu ?: iii N =? C '-? ,...?, • ... yy. . ? r ? r `??r?l FEDERMAN AND PHELAN BY: Lisa D. Blankenburg, Esq. Atty. I.D. #78020 Ste. 900/Two Penn Center Plaza Philadelphia, PA 19102 (215) 563-7000 CONTI MORTGAGE CORPORATION ATTORNEY FOR PLAINTIFF COURT OF COMMON PLEAS CIVIL DIVISION CUMBERLAND County Vs. No. 99-3698-CIVIL THERESA J. DETWILER, A/K/A THERESA J. GRIMES I, LISA D. BLANKENBURG, ESQUIRE, hereby certify that a copy of the Motion for Alternate Service has been sent to the individual(s) as indicated below by first class mail, postage prepaid, on the date listed below. THERESA J. DETWILER, A/K/A THERESA J. GRIMES 159 SOUTH BEDFORD STREET CARLISLE, PA 17013 The undersigned understands that this statement is made subject to the penalties of 18 PA C.S. 4904 relating to unsworn falsification to authorities. iQL? Lisa D. Blankenburg, Esquire Federman and Phelan Date: October 18, 1999 ?fl f 1 : . ` f l? of L_ 4 r v Lti • :` tiL; f` , f G1 I `J LYA]LLL WGflI W OI?A2RUW Ai lppl?.IJW? an. Atl w W. v tYILO 1M3131Vis ' l iv FEDERMAN AND PHELAN BY: FRANK FEDERMAN, ESQUIRE Identification No. 12248 Suite 900 Two Penn Center Plaza Philadelphia, PA 19102 (215)563-7000 CONTIMORTGAGE CORPORATION Attorney for Plaintiff . COURT OF COMMON PLEAS Plaintiff V8. CIVIL DIVISION THERESA J. DETWILER, A/K/A THERSA J. GRIMES Defendants Cumberland County No. 99-3698-CIVIL PRAECIPE TO REINSTATE CIVIL ACTION/MORTGAGE FORECLOSURE TO THE PROTHONOTARY: Kindly reinstate the Civil Action in Mortgage Foreclosure with reference to the above captioned matter. FRANK FEDERMAN, ESQUIRE Attorney for Plaintiff Date: November 3, 1999 c. L_-. L:J' - C PRAECIPE FOR WRIT OF EXECUTION - (MORTGAGE FORECLOSURE) P.R.C.P. 3180-3183 Contimortgage Corporation Plaintiff, V. Dauphin County Theresa J. Detwiler, a/k/a Theresa J. Grimes Defendant(s). No. 99.3698 Civil TO THE DIRECTOR OF THE OFFICE OF THE PROTHONOTARY: Issue writ of execution in the above matter: Amount Due 64 707.52 Interest from 12/29/99 - 6/7/00 (per diem -$10.64) $1,702.40 and Costs 66 409.92 TOTAL FRATj K FEDERMAQ, ESQUIRE T PENN CENT R PLAZA SUITE 900 PHILADELPHIA, PA 19102 Attorney for Plaintiff Note: Please attach description of property.No. A Q rn H W4 O z h O 0 e zz ° ti A z o y z OW W L ?. v L W y '? a °y s w o O F Uz U `° ; 0 `?' "7 ° W° 00 u = y w .? o A 8 ? r f? o a c A W W U x C W L Cdr Z U F=„ v a. N d e c? d ? o A v ? = e d ? N ' ;; d a u a y 3 l y v Q DESCRIPTION ALL THAT CERTAIN tract or parcel of land and premises, situate, lying and being in the Second Ward of the Borough of Carlisle, in the County of Cumberland, and Commonwealth of Pennsylvania, more particularly described in accordance with a survey and plan thereof made by Ernest 1. Walker, Professional Engineer, dated 2 June 1964, as follows: BEGINNING at a point on the Eastern side of South Bedford Street, which point is 40.50 feet North of South Street; thence extending along Bedford Street, North 24 degrees East 36.50 feet to a point at the middle of the partition wall between the double frame house; thence extending through the center of said partition wall, South 66 degrees East 60 feet to the line of property now or formerly of John Gibson; thence along said land, South 24 degrees West 36.50 feet to an iron pin at a corner of property now or formerly of Dorothy M. Taylor; thence along the same, North 66 degrees West 60 feet to the point and place of BEGINNING. HAVING THEREON ERECTED the Southern one-half of a double frame dwelling house known as No. 159 South Bedford Street. TITLE TO SAID PREMISES IS VESTED IN Theresa J. Grimes, married woman by Deed from Mary E. Hurley, widow dated 2/20/90 recorded 2/23/90 in Deed Book K, Volume 34 Page 745. 10 0 0v G .e o? `Y D ? a c? FEDERMAN AND PHELAN By: FRANK FEDERMAN, ESQUIRE IDENTIFICATION NO. 12248 TWO PENN CENTER PLAZA, SUITE 900 PHILADELPHIA, PA 19102 (2151 563-7000 CONTIMORTGAGE CORPORATION 338 SOUTH WARMINSTER ROAD HATBORO, PA 19040 V. Plaintiff ATTORNEY FOR PLAINTIFF COURT OF COMMON PLEAS CIVIL DIVISION TERM NO. 99-369T Civ'IL CUMBERLAND COUNTY THERESA J. DETWILER, A/K/A THERESA J. GRIMES 159 SOUTH BEDFORD STREET CARLISLE, PA 17013 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. CUMBERLAND COUNTY CUMBERLAND COUNTY BAR ASSOCIATION 2 LIBERTY AVENUE CARLISLE, PA 17013 (717) 249-3166 Plaintiff is CONTIMORTGAGE CORPORATION 338 SOUTH WARMINSTER ROAD HATBORO, PA 19040 The name(s) and last known address(es) of the Defendant(s) are THERESA J. DETWILER, A/K/A THERESA J. GRIMES 159 SOUTH BEDFORD STREET CARLISLE, PA 17013 who is/are the mortgagor(s) and real owner(s) of the property hereinafter described. 3. On 5/9/97 mortgagor(s) made, executed and delivered a mortgage upon the premises hereinafter described to KEYSTONE STATE. MORTGAGE CORPORATION which mortgage is recorded in the Office of the Recorder of CUMBERLAND County, in Mortgage Book No. 1383, Page 1089. By Assignment of Mortgage recorded 11/17/97 the mortgage was assigned to PLAINTIFF which Assignment is recorded in Miscellaneous Book No. 562, Page 215. 4. The premises subject to said mortgage is described as attached. The mortgage is in default because monthly payments of principal and interest upon said mortgage due 9/14/98 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 $52,551.48 Interest 4,012.47 8/14/98 through 4/1/99 (Per Diem $17.37) Attorney's Fees 2,627.00 Cumulative Late Charges 215.06 5/9/97 to 4/1/99 Cost of suit and Title Search 550.00 Subtotal 59,956.01 Escrow Credit 0.00 Deficit 9.50 Subtotal 9.50 TOTAL $59,965.51 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 "B"• 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 $59,965.51, together with interest from 4/1/99 at the rate of $17.37 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 FEDERMAN AND PHELAN Suite 900 Two Penn Center Plaza Philadelphia, PA 19102-1799 215-241-1711 Fax: 215-568-7617 Representing Lenders in Pennsylvania and New Jersey May 12, 1999 Theresa J. Detwiler, a/k/a Theresa J. Grimes 159 S. Bedford Street Carlisle, PA 17013 Re: Premises: 159 South Bedford Street, Carlisle, PA 17013 Loan No.: 0004411203 NOTICE OF INTENTION TO FORECLOSE We represent ContiMortgage Corp., 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 $4,578.95 for the months of 9/14/98 through 4/14/99. Your failure to pay the delinquent amount, plus any additional monthly payment and late and other charges (including any accrued interest) that may come due within the next thirty (30) days, will result in the acceleration of all sums due under your Mortgage. After acceleration occurs, a foreclosure action or any other remedy permitted by your mortgage may be instituted. To avoid the acceleration of your mortgage and subsequent foreclosure action, the delinquency mentioned above and any accrual EXHIBIT A thereto must be paid by CERTIFIED CHECK OR MONEY ORDER and received in our offices at Suite 900, Two Penn Center Plaza, Philadelphia, PA 19102, in or before thirty (30) days from the date of this letter. Please call (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 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. Very truly yours, FEDERMAN AND PHELAN B? y Frank Federman FF:11 CC: ContiMortgage Corp. (Hatboro, PA) Attn:Kymberlee Lescas Loan No.: 0004411203 EXV41BIT R ACT 91 NOTICE TAKE ACTION TO SAVE YOUR HOME FROM FORECLOSURE 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. The Commonwealth of Pennsylvania's Homeowner's 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 continua- viviendo an su casa. Si no comprende el contenido de esta notification obtenga una traduccion immediatamente llamanda esta agencia (Pennsylvania Housing Finance Agency) sin cargos al numero mencionado arriba. Puedes ser elegible Para un prestamo por el programa llamado "Homeowner's Emergency Mortgage Assistance Program" el cual puede salvar su casa de 1a perdida del derecho a red_mir 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 Date May 12, 1999 RE: Account No. 0004411203 Premises:159 South Bedford Street, Carlisle, PA 17013 TO: Theresa J. Detwiler, a/k/a Theresa J. Grimes 159 S. Bedford Street Carlisle, PA 17013 FROM: Federman and Phelan, attorney for ContiMortgage Corp. 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 your 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. EXH/S17 B Under the Act, you are entitled to a temporary stay of foreclosure on your mortgage for thirty (30) days from the date of this Notice. During that time you must arrange and attend a "face-to-face" meeting with a representative of this lender, or with a designated consumer credit counseling agency. The purpose of this meeting is to attempt to work out a repayment plan, or to otherwise settle your delinquency. This meeting must occur in the next (30) days. 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. As representative of the mortgage holder, our name and address is: FEDERMAN AND PHELAN, SUITE 900, TWO PENN CENTER PLAZA, PHILADELPHIA, PA 19102; Telephone Number: (215) 563-7000. The names and address of designated consumer credit counseling 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 failed to pay promptly installments of principal and interest, as required, for a period of at least sixty (60) days. The total amount of the delinquency is $4,578.95. That sum includes the following: Total of Principal plus interest including all accrued late charges, if any: $4,554.95 Property Inspections and NSF check Charges, if any: 0.00 Other charges accrued, if any 24.00 LESS: Suspense (unapplied funds) 0.00 TOTAL DUE: $4,578.95 Your mortgage is also in default for the following reasons: N/A . If you have tried and are unable to resolve this problem at or after your 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 the other time periods set forth in this letter, foreclosure may proceed against your home immediately. Available funds for emergency mortgage assistance are very limited. They will be disbursed by the Agency under the eligibility criteria established by the Act. It is extremely important that your application is accurate and complete in every respect. The Pennsylvania Housing Finance Agency has sixty (60) days to make a decision after it receives your application. During that additional time, no foreclosure proceedings will be pursued against you if you have met the time EXHIBIT 9 requirements set forth above. You will be notified directly by that 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 1-800-342-2397 (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 "Notice of Intention to Foreclose". You must read both notices, since they both explain rights that you now have under Pennsylce ivania law. However, if you choose to exercise your rights described in thisnot, you cannot be foreclosed upon while you are receiving that assistance. very truly yours, ?DCD AMA? AN PHELAN ? Frank Federman FF/11 cc: ContiMortage Corp. (Hatboro, PA) Attn:Kymberlee Lescas Loan No. :0004411203 Sent by Regular Mail, Certificate of Mailing (PS Form 3877) EXHIBIT B a PLNNL SYLV A-rZA HOCSriG MA-`CE AGENCY HO:YfEOWNER'S EtiIERGF- CY MORTGAGE .ASSIST.L CE PROGRAM COirSLZMER CREDIT COU SELLNG AGENCIES CR WFORD CQU?7i' Broker T. Washington Center 1720 Hoiland Ssr_: E-.e. P.i L6503 (8144) 453-5-144 F.AX't (814) 453.5749 John F. Kennedy Center. Inc. 1011 E.U: 20th Street F-m PA 16510 (814) 898-0400 FAX N (814) 898-1143 Greater F-ie Community Action Commitm-- l8 West `Ninth Stte•_t F-i e, PA 16501 (8114) 4$9=581 FAX a (814) 456-0161 Shemaa8e Valley Urbanlt Lague. Inc. 601 Indiana Avenue (412) 981-5310 CUNMERL -ND COL-:NTY Consumer Crit CourseUng Se:'Ace of Western Inc. 2000 Linglestown Road Hatr!sburg, PA L7101 (717) 541-1751 ' FAA sp (911) %c i-9589 Fecal Counseling Services of Fmrkii Cz==1:y A.--cm Cow issioe of the Caoiml Re_sion 31 West 3rd SL-et 151= Der.: Sc:;:, R'avm-sncro. P.i 17108 Ira:-.sbu'Z. 9.A. 1710-1 (711' ifi1.3_8. (71-) FA.X = (717)'--34-_-1 Urban Lague of Mecopo!i= ia=hu 2107 North 6th Street Harsbur;, PA 171011 (7!7) 3.L59_- FA.Y = (, l-,) _34-9459 YWCA of Ca.-lisle 301 G. Street Cat!Sle, ?A 1700 (-17 143-3818 FAX i (711) 731.9589 The ?:cz!r lvania Housing Finance Agency can be reached TOLL FR r. at 1(800) 341-23r, EXHIBIT B ALL THAT CERTAIN tract or parcel of land and premises, situate, lying and being in the Second Ward of the-Borough of Carlisle, in the County of Cumberland, and Commonwealth of Pennsylvania, more particularly described in no, rdance with a survey and plan thereof made by Ernest J. Walker, Professional Engineer, dated 2 June 1964, as follows: BEGINNING at a point on the eastern side of South Bedford Street, which point is 40.50 feet north of South Street; thence extending along Bedford Street, North 24 degrees Fast 36.50 feet to a point at the middle of the partition wall between the double frame house; thence extending through the center of said partition wall, South 66 degrees East 60 feet to the line of property now or formerly of John Gibson; thence along said land, South 24 degrees West 36.50 feet to an iron pin at a corner of property now or formerly of Dorothy M. Taylor; thence along the same, North 66 degrees West 60 feet to the point and place of BEGINNING. HAVING THMEON EREC M the southern one-half of a double frame dwelling house known as No. 159 South Bedford Street. BEING the same premises which David A. Krulac, by his deed dated 20 Ck:tober 1987 and recorded in the Office of the Recorder of Deeds in and for Cumberland County, Pennsylvania, in Deed Book Z, volume 32, Page 757, granted and conveyed unto John W. Finley and Mary E. Hurley, his wife. The said John W. Hurley died on 19 January 1990 whereby title vested in fee in Mary E. Hurley, the surviving tenant by the entireties, Grantor herein. VERIFICATION Daniel Pratt hereby states that he/she is FIVIcC/--JS,A t f t)W, of Conti Mortgage corporation 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. DATE: o 0q 0 CT" L . rr ` Y J\ C-6 E CJ U Wit: Ul t? !Y IN THE COURT OF COMMON PLEAS OF CUMBERLAND COUNTY, PENNSYLVANIA CONTIMORTGAGE CORPORATION Plaintiff CIVIL DIVISION vs. No. 99-3698 CIVIL THERESA J. DETWILER, A/K/A THERESA J. GRIMES Defendants AFFIDAVIT OF SERVICE PURSUANT TO RULE 3129 COMMONWEALTH OF PENNSYLVANIA CUMBERLAND COUNTY SS: I, FRANK FEDERMAN, ESQ., attorney for CONTIMORTGAGE CORPORATION, hereby verify that on FEBRUARY 18. 2000, true and correct copies of the Notice of Sheriffs 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 FEBRUARY 18. 2000 by first class mail and certified mail return receipt requested, see Exhibit "B" attached hereto. FRANK FED RMAN, ESQUIRE Attorney for laintiff Date: Mav 18.2000 O b Z to a N a C6 °` . aUs E a ?abw O e. ?Fa P, Iq H 'o C d m ?p b e Z < o x y - i v y? J5V ,N 3d a• o C A ? 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If 13 ?, 4. ••? ? ?. 0 PS FORM 3800 US Postal Service L ?t . L C c ? 101 Receipt for Certified Mail t c7-;' N ?c LL 4: c? C . FEDERMAN AND PHELAN By: Frank Federman, Esquire Attorney I.D. No.: 12248 Two Penn Center Plaza, Suite 900 Philadelphia, PA 19102 (215) 563-7000 Attorney for Plaintiff Contimortgage Corporation Plaintiff, V. Theresa J. Detwiler a/k/a Theresa J. Grimes Cumberland COUNTY COURT OF COMMON PLEAS CIVIL DIVISION NO. 99-3698 CIVIL Defendant(s). AFFIDAVIT OF SERVICE OF NOTICE OF SHERIFF'S SALE PURSUANT TO P.R.C.P., 404(2)/403 FRANK FEDERMAN, ESQUIRE, Attorney for Plaintiff, hereby certifies that service of the Notice of Sheriffs Sale was made by sending a true and correct copy by certified mail and regular mail to Defendant(s) Theresa J. Detwiler a/k/a Theresa J. Grimes at 159 South Bedford Street Carlisle, Pa 17013 on February 18. 2000 in accordance with the Order dated October 25. 1999 . The undersigned understands that this statement is made subject to the penalties of 18 Pa.C.S. 4904 relating to the unsworn falsification to authorities. ZN =EAENE;SQRr? B: y Dated: March 15, 2000 ? - z r- aN & o ~ ^ Q aco 2 =d N ? 5> z , ¢z ww r- a z LU a o= Z n. z J w LLJ CL° a Q J ?a ? V C-. ? 1 J 7 4. ?ty3 d U F °G w Z C o." 0 C ;.I w ddavi h y N -?? p ?? 1 0 1 t? :i .FEDERMAN AND PHELAN BY: Lisa D. Blankenburg, Esq. Atty. I.D. #78020 Ste. 900/Two Penn Center Plaza Philadelphia, PA 19102 (215) 563-7000 - CONTI MORTGAGE CORPORATION VS. THERESA J. DETWILER, A/K/A THERESA J. GRIMES OCT 2 2 ugcj, ATTORNEY FOR PLAINTIFF Y COURT OF COMMON PLEAS CIVIL DIVISION CUMBERLAND COUNTY No. 99-3698-CIVIL ORDER AND NOW, this o2S day of 1999, upon consideration of Plaintiff's Motion and the Affidavit of Good Faith Investigation attached thereto, it is hereby ORDERED that Plaintiff may obtain service of the Complaint on the above captioned Defendant(s), THERESA J. DETWILER, A/K/A-THERESA J. GRIMES , by mailing a true and correct copy of the Complaint by certified mail and regular mail to the defendant's last known address and to the mortgaged premises at 159 SOUTH BEDFORD STREET, CARLISLE, PA 17013. Service of the aforementioned mailings is effective upon the date of mailing and is to be done by Plaintiff's attorney, who will file with the Prothonotary's Office an Affidavit as to the mailing. BY THE COURT: CCGt Gam.- J v u _ N .ate Z : L L ? cs 7 C:) cs FEDERMAN AND PHELAN BY: FRANK FEDERMAN, ESQUIRE Identification No. 12248 Suite 900 Two Penn Center Plaza Philadelphia, PA 19102 (215) 563-7000 CONTIMORTGAGE CORPORATION Attorney for Plaintiff . COURT OF COMMON PLEAS Plaintiff Vs. THERESA J. DETWILER, A/K/A THERESA J. GRIMES . CIVIL DIVISION : CUMBERLAND COUNTY NO. 99-3698-CIVIL Defendant(s) VERIFICATION I hereby certify that a true and correct copy of the Civil Action Complaint in Mortgage Foreclosure in the above captioned matter was sent by regular and certified mail, return receipt requested, to the following persons, to THERESA J. DETWILER, A/K/A THERESA J. GRIMES at 159 SOUTH BEDFORD STREET, CARLISLE, PA 17013 , on NOVEMBER 24, 1999, in accordance with the Order of Court dated OCTOBER 25, 1999. 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. FRANK FEDERMAN, ESQUIRE DATE: November 24, 1999 r Z . y T fi 1 . lll F- p L O a U Contimortgage Corporation Plaintiff, V. CUMBERLAND COUNTY COURT OF COMMON PLEAS Theresa J. Detwiler, CIVIL DIVISION a/k/a Theresa J. Grimes Defendant(s). NO. 99-3698 Civil AFFIDAVIT PURSUANT TO RULE 3129 (Affidavit No. l) Contimortt=_age Corporation, Plaintiff in the above action, by its attorney, FRANK FEDERMAN, ESQUIRE, sets forth as of the date the Praecipe for the Writ of Execution was filed the following information concerning the real property located at 159 South Bedford Street Carlisle PA 17013. Name and address of Owner(s) or reputed Owner(s): NAME LAST KNOWN ADDRESS (If address cannot be reasonably ascertained, please so indicate.) Theresa J. Detwiler, a/k/a 159 South Bedford Street Theresa J. Grimes Carlisle, PA 17013 Present Whereabouts Unknown 2. 4. 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 Name and address of everyjudgment 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 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.) Eastern Savings Executive Plaza 11, Suite 200 Bank, FSB 11350 McCormick Road Hunt Valley, MD 21031 Pennsylvania Housing 2101 N. Front Street Finance Agency Harrisburg, PA 18101 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. 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.) None 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.) David A. Detwiler 159 South Bedford Street Carlisle, PA 17013 Tenant/Occupant 159 South Bedford Street Carlisle, PA 17013 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 unswom falsification to authorities. February 16. 2000 DATE FRAN { FEDE AN, ESQUIRE Attor ey for Plaintiff _, - •J FEDERMAN and PHELAN By: FRANK FEDERMAN Identification No. 12248 Suite 900 Two Penn Center Plaza Philadelphia, PA 19102 (215) 563-7000 Contimortgage Corporation ATTORNEY FOR PLAINTIFF CUMBERLAND COUNTY Plaintiff, COURT OF COMMON PLEAS V. CIVIL DIVISION Theresa J. Detwiler, a/k/a Theresa J. Grimes NO. 99-3698 Civil Defendant(s). CERTIFICATION FRANK FEDERMAN, ESQUIRE, hereby verifies that he is attorney for the Plaintiff in the above-captioned matter, and that the premises are not subject to the provisions of Act 91 because it is: () an FHA mortgage () non-owner occupied () vacant (X) Act 91 procedures have been fulfilled This certification is made subject to the penalties of 18 Pa. C.S. Section 4904 relating to unswom falsification to authorities. FRAN 7FEDER AN,E QUIRE Atto r Plaintif - ?.. _.. Contimortgage Corporation CUMBERLAND COUNTY Plaintiff, V. No. 99-3698 Civil Theresa J. Detwiler, a/Wa Theresa J. Grimes Defendant(s). February 16, 2000 TO: Theresa J. Detwiler, a/k/a Theresa J. Grimes 159 South Bedford 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 AND THIS DEBT WAS NOT REAFFIRMED, THIS IS NOT AND SHOULD NOT BE CONSTRUED TO BE AN ATTEMPT TO COLLECT A DEBT, BUT ONLY ENFORCEMENT OF A LIEN AGAINST PROPERTY." Your house (real estate) at 159 South Bedford Street . Carlisle, PA 17013, is scheduled to be sold at the Sheriffs Sale on June 7, 2000 at 10:00 a.m. in the Cumberland County Courthouse , South Hanover Street, Carlisle, PA 17013, to enforce the courtjudgment obtained by Contimortilatte Corporation (the mortgagee) against you. If the Sheriffs sale is postponed, the property will be relisted for the Sheriffs Sale. NOTICE OF OWNER'S RIGHTS YOU MAY BE ABLE TO PREVENT THIS SHERIFF'S SALE To prevent this Sheriffs Sale, you must take immediate action: 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. You may be able to stop the sale by filing a petition asking the Court to strike or open the judgment, if the judgment was improperly entered. You may also ask the Court to postpone the sale for good cause. 3. You may also be able to stop the sale through other legal proceedings. You may need an attorney to assert your rights. The sooner you contact one, the more chance you will have of stopping the sale. (See notice on page two on how to obtain an attorney.) 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 Sheriffs 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 schedule of distribution of the money bid for your house will be filed by the Sheriff within 30 days of the sale. This schedule will state who will be receiving that money. The money will be paid out in accordance with this schedule unless exceptions (reasons why the proposed distribution 's wrong) are filed with the Sheriff within ten (10) days after the distribution is filed. 7. You may also have other rights and defenses, or ways of getting your home back, if you act immediately after the sale. YOU SHOULD TAKE THIS PAPER TO YOUR LAWYER AT ONCE. IF YOU DO NOT HAVE A LAWYER OR CANNOT AFFORD ONE, GO TO OR TELEPHONE THE OFFICE LISTED BELOW TO FIND OUT WHERE YOU CAN GET LEGAL HELP. CUMBERLAND COUNTY ATTORNEY REFERRAL CUMBERLAND COUNTY BAR ASSOCIATION 2 LIBERTY AVENUE CUMBERLAND COUNTY COURTHOUSE CARLISLE, PA 17013 (717) 249-3166 (800) 990-9108 DESCRIPTION ALL THAT CERTAIN tract or parcel of land and premises, situate, lying and being in the Second Ward of the Borough of Carlisle, in the County of Cumberland, and Commonwealth of Pennsylvania, more particularly described in accordance with a survey and plan thereof made by Ernest J. Walker, Professional Engineer, dated 2 June 1964, as follows: BEGINNING at a point on the Eastern side of South Bedford Street, which point is 40.50 feet North of South Street; thence extending along Bedford Street, North 24 degrees East 36.50 feet to a point at the middle of the partition wall between the double frame house; thence extending through the center of said partition wall, South 66 degrees East 60 feet to the line of property now or formerly of John Gibson; thence along said land, South 24 degrees West 36.50 feet to an iron pin at a corner of property now or formerly of Dorothy M. Taylor; thence along the same, North 66 degrees West 60 feet to the point and place of BEGINNING. HAVING THEREON ERECTED the Southern one-half of a double frame dwelling house known as No. 159 South Bedford Street. TITLE TO SAID PREMISES IS VESTED IN Theresa J. Grimes, married woman by Deed from Mary E. Hurley, widow dated 2/20/90 recorded 2/23/90 in Deed Book K, Volume 34 Page 745. _? . . ?:: -, ;. ?,; ` - ?;_ ?. _ _ - s FEDERMAN AND PHELAN By: FRANK FEDERMAN, ESQUIRE Atty. I.D. No. 12248 Two Penn Center Plaza, Suite 900 Philadelphia, PA 19102-1799 (215) 563-7000 CONTIMORTGAGE CORPORATION V. THERESA J. DETWILER A/K/A THERESA J. GRIMES ATTORNEY FOR PLAINTIFF COURT OF COMMON PLEAS CIVIL DIVISION CUMBERLAND COUNTY NO: 99-3698 Kindly attach the appended Affidavit of Release to the captioned Complaint in Mortgage Foreclosure. Respectfully submitted, FEDERMANN & PHELA??NQQ??Dated: March 1, 2000 Frank Federman, Esquire Attorney for Plaintiff FEDERMAN AND PHELAN By: FRANK FEDERMAN, ESQUIRE Atty. I.D. No. 12248 Two Penn Center Plaza, Suite 900 Philadelphia, PA 19102.1799 (215) 563-7000 ATTORNEY FOR PLAINTIFF COURT OF COMMON PLEAS CIVIL DIVISION CONTIMORTGAGE CORPORATION V. THERESA J. DETWILER A/K/A THERESA J. GRIMES CUMBERLAND COUNTY NO: 99-3698 David Detwiler, mortgagor, is hereby released from liability for the debt secured by the mortgage as referenced at paragraph three (3) in the conformity to Pa.R.C.P., Rule 1144(b). FEDERMAN AND PHELAN Date: March 1, 2000 By: Frank Federman, Esquire STATE OF PENNSYLVANIA COUNTY OF PHILADELPHIA ss On " ` -ck / 2000, before me, 7?z o- r , Notary Public in and for said County and State, personally appeared Frank Federman, personally/known to me (or proved to me on the basis of satisfactory evidence) to be the person(s) whose name(s) are subscribed to the within instrument and acknowledge to me that he/she/they executed the same in his/her/their authorized capacity(ies), and that by his/her/their signature(s) on the instrument the person(s), or the entity upon behalf of which the person(s) acted, executed the instrument. WITNESS my hand and official seal. otary Public NOTARIAL SEAL NOTARY SEAL Tara L. Leahy, Notary Public M C tars i I. Expires Se t. 25, County N L H Q ? N .J O CJ N 7C a J l C; c re ui .. ?y c V Z g u. v O o 0 V ; STATE OF PENNSYLVANIA, COUNTY OF CUMBERLAND ss. Robert P Ziegler 11 -- Deeds in and for said County and State do hereby certify that the Sheriff's Deed m which Contimort:gage Corp -------•-------------------------------------------------------- is the grantee the same having been sold to said grantee on the __------ ______ t-h ------------------------------ day of June xx2000 ---------------------------------------- A. D.,19--------- under and by virtue of a writ______________ Execution ------------------------------------------------issued on the -- 2 2nd ------------------------ February day of __________________________ A. D., I xtt 90.0 out of the Court of Comman Pleas of said County as of Civil -------------------------- ------------------------------- Term,'tW59---- Number 3698 _, at the suit of----- Contim --- -- -- Corp -- - ---- against___Theresa J Detweiler aka-Theresa J r ---------------------------------- - - - - ----------- --- yrimes dulyrecordedinSheriff'sDeed Book No.___226Page__----- IN TESTIMONY WHEREOF, I have hereunto set my hand and seal of said office this day of -------- -------------- A D., I3 ?s K--- er of Deeds "ftE tft jl ?? Contimortgage Corporation In the Court of Common Pleas of -vs- Cumberland County, Pennsylvania Theresa J. Detwiler, a/k/a No. 99-3698 Civil Theresa J. Grimes Dawn L.Kell Deputy Sheriff who being duly s worn according to law, says on March 30, 2000 at 9:17 o'clock A.M. EST she posted a copy of Real Estate Writ Notice Poster and Description in the above entitled action on the property of Theresa J. Detwiler aka Theresa J. Grimes located at 159 South Bedford Street, Carlisle, Cumberland County, Pennsylvania according to law. R. Thomas Kline, Sheriff, who being duly sworn according to law, says that after due %-J-- and legal notice had been given according to law, exposed the within described premises 4/17Mat public venue or outcry at the Court House, Carlisle, Cumberland County, Pennsylvania and sold the same for the sum of $ 25,000.00 to Attorney Dale Shughart for Contimortgage Corporation. It being the highest bid and best price quoted for the same Contimortgage Corporation of 338 South Warminister Road, Hatboro, Pennsylvania being the buyer in this execution paid to Sheriff R. Thomas Kline the sum of $ 980.95 it being costs. Sheriff's Costs Docketing 30.00 Poundage 50.00 Posting Bills 15.00 Advertising 15.00 Acknowledging Deed 30.00 Auctioneer 10.00 Law journal .50 County 1.00 Mileage 3.10 Certified Mail 1.17 Levy 15.00 Surcharge 20.00 Legal Search 200.00 Law Journal 279.35 Patriot News 234.53 Share of Bills 24.80 Distribution of Proceeds 25.00 Sheriffs Deed 26.50 $ 980.95 Pd By Atty 6/21/00 Sworn and Subscribed To Before Me This ,) 'Y" Day of 2000, A.D. u, hu¢lc AQ?aG Prot on tary So answers: R. Thomas li , Sheriff Ole, By /ri Real Estate Deputy ? v G clU"'" ? v l.? uz? A, 195Ly SCHEDULE OF DISTRIBUTION SALE # 20 Date filed Writ No 1999-3698 Civil Term Contimortgage Corporation -vs- Theresa J. Detwiler aka Theresa Grimes 159 South Bedford Street Carlisle, PA 17013 Sale Date June 7, 2000 Buyer Dale Shughart for Contimortgage Corporation Bid Price $ 25,000.00 Real Debt Interest fir 12/29/99-6/7/00 Atty's Writ Costs DISTRIBUTION Amount collected Sheriff's Costs Legal Search Refund to arty $ 64,707.52 1,702.40 109.20 $ 66,519.12 $ 1,000.00 780.95 200.00 19.05 0,000.00 So anlv"rs wy .,e? R. Thomas Kline, Sheriff By a Real Estate Deputy TITLE REPORT THE. PREMISES ENDORSED HEREON ARE SUBJECT TO THE FOLLOWING ITEMS, WHICH WILL BE EXCEPTED IN THE POLICY UNLESS SATISFACTORY EVIDENCE PERMITTING THEIR REMOVAL IS PRODUCED. SHERIFF SALE NO. #20 Held Wednesday, June 7, 2000 Date: June 7, 2000 TAXES: Receipts for all taxes for the years 1997 to 1999 inclusive. Taxes for the current year 1999. WATER RENT: Company assumes no liability for private supply of water or sewer. SEWER RENT Receipts to he produced if services are lienable. MECHANICS' AND Possible unfiled Mechanics Liens and Municipal Claims. MUNICIPAL CLAIMS MORTGAGES: Listed Cinder Other Exceptions Below. JUDGMENTS: Listed Under Other Exceptions Below. INSTRUMENTS TO BE PRODUCED: Deed from Cumberland County Sheriff to dated . 2000, and recorded ,2(K)0. in Cumberland County Deed Book Page RECITAL: Being the same premises which Mary E. Hurley, widow by deed dated February 20, 1990 and recorded February 23, 1990 in the Office of the Recorder of Deeds in and for Cumberland Count, at Carlisle, Pennsylvania in Deed Book 'K", Volume 34, Page 745 granted and conveyed to Theresa K. Grimes, married woman. 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 F,siate Transfer Taxes, if required. 5. Public and private rights in the roadhed of 60 feet wide South Bedford Street. (i. Mortgage given by Theresa J. Grimes to Eastern Savings Bank. FSB dated September 24. 1992 and recorded September 24, 1992 in Mortgage Book 1091, Page 301. Mortgage in the annnutt of $52.800.00 given by David Dehviller and Theresa J. Detwiller, also known as Theresa J. Cirimes to Keystone State Mortgage Corporation dated May 9. 1997 and recorded May 27. 1997 in Mortgage Book 1383, Page 1089. Said mortgage was assigned n, C'ontinuntgagc C 0rporati0n by instrument dated May 9, 1997 and recorded November 17, 1997 in Miscellaneous Record Book 562, Page 215. Complaint in Mortgage Foreclosure filed by Contimortgage Corporation as plaintiff against Theresa J. Detwiller and Theresa J. Grimes on June 18, 1999 in the Office of the Prothonotary of Cumberland County to file number 99-3698. Default judgment in the amount of $64,707.52 entered on December 30, 1999. 8. Mortgage in the amount of $5,000.00 given by Theresa J. Grimes, also known as Theresa J. Detwiller, and David A. Detwiller to Pennsylvania Housing Finance Agency dated August 4, 1998 and recorded August 7, 1998 in Mortgage Book 1474, Page 40. 9. Delinquent real estate taxes turned over to the Cumberland County Tax Claim Bureau in the amount of $1,332.93. 10. Satisfactory evidence to be produced that proper notice was given to the holders of all liens and encumbrances intended to be divested by subject Sheriff Sale. 1 I . Real estate taxes accruing on and after July 1, 2000 not yet due and payable. 12. Subject to rights of a spouse, if any, in the subject premises pursuant to any divorce action filed. 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 search been made for environmental liens in Federal District Court. Note: This Title Report shall not be valid or b until countersigned by an authorized signatory. REAL ESTATE SALE NO. 20 Writ No. 99-3698 Civil Contimortgage Corporation V9. Theresa J.. Detwiler, a/k/a Theresa J. Grimes Atty.: Frank Federman DESCRIPTION ALL THAT CERtAIN tract or par- cel of land and premises. situate, lying and being in the Second Ward of the Borough of Carlisle, in the County of Cumberland, and Commonwealth of Pennsylvania, more particularly de- scribed in accordance with a survey and plan thereof made by Ernest J. Walker, Professional Engineer, dated 2 June 1964, as follows: BEGINNING at a point on the Eastern side of South Bedford Street, which point is 40.50 feet North of South Street; thence extending along Bedford Street, North 24 degrees East 36.50 feet to a point at the middle of the partition wall between the double frame house; thence ex- tending through the center of said partition wall. South 66 degrees East 60 feet to the line of property now or formerly of John Gibson; thence along said land. South 24 degrees West 36.50 feet to an iron pin at a comer of property now or formerly of Dorothy M. Taylor, thence along the same, North 66 degrees West 60 feet to the point and place of BEGINNING. HAVING THEREON ERECTED the Southern one-half of a double frame dwelling house known as No. 159 South Bedford Street. TITLE TO SAID PREMISES IS VESTED IN Theresa J. Grimes, mar- ried woman by Deed from Mary E. Hurley, widow dated 2/20/90 re- corded 2/23/90 in Deed Book K. Vol. ume 34 Page 745. Contimortgage Corporation Plaintiff, V. CUMBERLAND COUNTY COURT OF COMMON PLEAS Theresa J. Detwiler, CIVIL DIVISION a/Wa Theresa J. Grimes Defendant(s). NO. 99-3698 Civil AFFIDAVIT PURSUANT TO RULE 3129 (Affidavit No. I) Contimortease Corporation. Plaintiff in the above action, by its attorney, FRANK FEDERMAN, ESQUIRE, sets forth as of the date the Praecipe for the Writ of Execution was filed the following information concerning the real property located at 159 South Bedford Street. Carlisle PA 17013 2. 3. 4. Name and address of Owner(s) or reputed Owner(s): NAME LAST KNOWN ADDRESS (If address cannot be reasonably ascertained, please so indicate.) Theresa J. Detwiler, aWa 159 South Bedford Street Theresa J. Grimes Carlisle, PA 17013 Present Whereabouts Unknown 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 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 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.) Eastern Savings Executive Plaza II, Suite 200 Bank, FSB 11350 McCormick Road Hunt Valley, MD 21031 Pennsylvania Housing 2101 N. Front Street Finance Agency Harrisburg, PA 18101 5. Name and address of every other person who has any record lien on the property: / NAME LAST KNOWN ADDRESS (If address cannot be I None reasonably ascertained, please so indicate.) 6. Name and address of every other person who has any record interest in the property and whose interest may be affected by the sale: NAME LAST KNOWN ADDRESS (If address cannot be None reasonably ascertained, please so indicate.) 7. 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.) David A. Detwiler 159 South Bedford Street Carlisle, PA 17013 Tenant/Occupant 159 South Bedford Street Carlisle, PA 17013 Domestic Relations of 13 North Hanover Street Cumberland County Carlisle, PA 17013 1 verify that the statements made in this affidavit are true and correct to the best of my knowledge or information and belief I understand that false statements herein are made ub ect to the penalties of 18 Pa. C.S. Sec. 4904 relating to nswom falsification to authorities. February 16 2000 n1 S, n DATE FRANK FEDE1tMAN, ESQUIRE Attorney for Plaintiff Contimortgage Corporation Plaintiff, V. CUMBERLAND COUNTY No. 99-3698 Civil Theresa J. Detwiler, a/Wa Theresa J. Grimes Defendant(s). r February 16, 2000 TO: Theresa J. Detwiler, a/k/a Theresa J. Grimes 159 South Bedford 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 AND THIS DEBT WAS NOT REAFFIRMED, THIS IS NOT AND SHOULD NOT BE CONSTRUED TO BE AN ATTEMPT TO COLLECT A DEBT, BUT ONLY ENFORCEMENT OF A LIEN AGAINST PROPERTY." Your house (real estate) at 159 South Bedford Street, Carlisle PA 17013, is scheduled to be sold at the Sheriffs Sale on June 7.2000 at 10:00 a.m. in the Cumberland County Courthouse, South Hanover Street, Carlisle, PA 17013, to enforce the court judgment obtained by C2n1im11U= Corporation (the mortgagee) against you. If the Sheriff's sale is postponed, the property will be relisted for the Sheriff's Sale. NOTICE OF OWNER'S RIGHTS YOU MAY BE ABLE TO PREVENT THIS SHERIFF'S SALE To prevent this Sheriffs 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 Courtto postpone the sale for good cause. 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.) 1. If the Sheriffs 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 schedule of distribution of the money bid for your house will be filed by the Sheriff within 30 days of the sale. This schedule will state who will be receiving that money. The money will be paid out in accordance with this schedule unless exceptions (reasons why the proposed distribution is wrong) are filed with the Sheriff within ten (10) days after the distribution is filed. 7. You may also have other rights and defenses, or ways of getting your home back, if you act immediately after the sale. YOU SHOULD TAKE THIS PAPER TO YOUR LAWYER AT ONCE. IF YOU DO NOT HAVE A LAWYER OR CANNOT AFFORD ONE, GO TO OR TELEPHONE THE OFFICE LISTED BELOW TO FIND OUT WHERE YOU CAN GET LEGAL HELP. CUMBERLAND COUNTY ATTORNEY REFERRAL CUMBERLAND COUNTY BAR ASSOCIATION 2 LIBERTY AVENUE CUMBERLAND COUNTY COURTHOUSE CARLISLE, PA 17013 (717) 249-3166 (800) 990-9108 DESC?0 ALL THAT CERTAIN tract or parcel of land and premises, situate, lying and being in the Second Ward of the Borough of Carlisle, in the County of Cumberland, and Commonwealth of Pennsylvania, more particularly described in accordance with a survey and plan thereof made by Ernest J. Walker, Professional Engineer, dated 2 June 1964, as follows: BEGINNING at a point on the Eastern side of South Bedford Street, which point is 40.50 feet North of South Street; thence extending along Bedford Street, North 24 degrees East 36.50 feet to a point at the middle of the partition wall between the double frame house; thence extending through the center of said partition wall, South 66 degrees East 60 feet to the line of property now or formerly of John Gibson; thence along said land, South 24 degrees West 36.50 feet to an iron pin at a corner of property now or formerly of Dorothy M. Taylor; thence along the same, North 66 degrees West 60 feet to the point and place of BEGINNING. ` HAVING THEREON ERECTED the Southern one-half of a double frame dwelling house known as No. 159 South Bedford Street. TITLE TO SAID PREMISES IS VESTED IN Theresa J. Grimes, married woman by Deed from Mary E. Hurley, widow dated 2/20/90 recorded 2/23/90 in Deed Book K, Volume 34 Page 745. WRIT OF EXECUTION and/or ATTACHMENT COMMONWEALTH OF PENNSYLVANIA) NO. 99-3698 COUNTY OF CUMBERLAND) CIVIL t Term CIVIL ACTION • LAW TO THE SHERIFF OF c ,m Land COUNTY: from To satisfy the debt, Interest and costs due Contimortgage Corporation PA 17013 Theresa J. Grimes, 159 South Bedford Street, Carlisle, DEFENDANT(S) (1) You are directed to levy upon the property of the defendant(s) and to sell See Legal Description (2) You are also directed to attach the property of the defendant(s) not levied upon in the possession of GARNISHEE(S) as follows; and to notify the 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) IlloroPerty, of the clefenclant(s) not levied upon an subject to attachment Isfound in the P0880681onof anyoneother than a named garnishee, you are directed to notify him/herthat he/she has been added as a garnishee and is enjoined as above stated. Amount Due 07.52 Interest from 12 /29/99 - 6 X702 40 Afty's Comm Arty Paid$ Al na 20 Plaintiff Paid Date: __ PPhrnarv 22 2000 REQUESTING PARTY: Name Frank Federman, Esq. Address: Two Penn Center Plaza Suite 900 Philadelphia PA 19102 Attorney for: Plaintiff Telephone:_ 215-961-7000 Supreme Court ID No. 1 2248- L.L. 50 Due Prolhy_ $1.00 Other Costs Curtis R. Long Prothonotary, Civil Division ?? Daputy (tLiA'L ? 3 i 1, i u ?, CM Cale: 0 c?$?a?rn??._-2?;1aOz - `;m GL?' rl rj r` !I rZ u? l THE PATRIOT NEWS THE SUNDAY PATRIOT NEWS Proof of Publication Commonwealth of Pennsylvania, County of Dauphin) ss 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 2nd, 9th and 16th day(s) of May 2000. 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 a pd pursuant to a resolution unanimously passed and adopted severally by the stockholders and board of directors of t?e d Company and subsequently duly recorded in the office for the Recording of Deeds in and for said County of D u n .n Mi cellaneous Book "M", Volume 14, Page 317. PUBLICATION -------------- UV COPY Sworn to and subscribed befa S A L E #20 Notarial Seal Terry L. Russell, Notary Public Harrisburg, Dauphin County My Commission Expires June 6, 2002 Member, Pennsylvania ASSOClatlon of Nob day OyJune,21f00 A.D. commission expires June 6, 2002 CUMBERLAND COUNTY SHERIFFS OFFICE CUMBERLAND COUNTY COURTHOUSE CARLISLE, PA. 17013 Statement of Advertisina Costs To THE PATRIOT-NEWS CO., Dr. For publishing the notice or publication attached hereto on the above stated dates $ 233.03 Probating same Notary Fee(s) $ 1.50 Total $ 234.53 Publisherrs 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 .................................................................... PROOF OF PUBLICATION OF NOTICE IN CUMBERLAND LAW JOURNAL (Under Act No. 587, approved Mary 16, 1929), P. L.1784 STATE OF PENNSYLVANIA : ss. COUNTY OF CUMBERLAND : Roger M. Morgenthal, Esquire, Editor of the Cumberland Law Journal, of the County and State aforesaid, being duly swom, 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, Afffant 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 EBTAT(t BALE NO. 20 Wnl No. 003609 Civil Contlmortgage Cogwratlon vs. Theresa J. Detwiler. a/k/a Theresa J. Gr nics Ally.: Frank Federman DESCRIPTION ALL THAT CERTAIN tract or par- cel of land and premises, slumio. lying and being in the Second Ward oft] e Borough of Carlisle, fit the County of Cumberland, and Conuuouwc lth of Pennsylvania, more particularly dr- senbed in accordance with it survey and plan thereof made by Ernest .1. Walker. Professional f:ni ua•rr. d.nrd 2 June 1964. as follow+: BEGINNING at a point oil lhr Eastern side of South Bedford Street, 'which IAmlt is 40.501irt North of South street; I hence extending along Bedford Street, North 24 degrees East 36.50 feet to if point at life middle of the partition wall hetwrril i the double frame house; Ihenve ex- lending through Ihr renter of sold partition wall, South w(lrgrccs IC:Int 1 60 feel to the laic of piola•rty unw or formerly of John Glbsan; throve along sad land. South 24 degives West 311.50 feel to an uou plu :u if corner of pi mpct ly unw or lot mcrly of Dorothy M. Taylor; thence along the same, North (16 degrees West 60 feel ionic point and place of 1EGINNING. HAVING TBERKON ERECTED Bin Southern one-half of it dnuhle (mute dwelling house known as No. 150 South Bedford Streel. TITLE TO SAID PRE-Mlst,s Is VESTED IN Therrea,). Gnnirs, mar reed woman by nerd from M.ov r Hurley, widow dulrd Y/xups, it Carried 2/23/t10 1n Drv•d (look K. Vol ume 34 Page 74 5. Roger . Morgenthal, Editor SWORN TO AND SUBSCRIBED before me this 12 day of_ MAY. 2000 to,!, E 'rnLr? vine r,;rr H,f?ti. Cato' e.„o. arib?iia itl Donee, PA My Co ';pi„..1 span lNuck i. 200I i., i Real Estate No 20 $ 1000.00 advance costs paid 2/28/00 Atty Frank Federman Assessed valuation $ 3,050 Writ No. 1999-3698 Civil Term Contimortgage Corporation -vs- Theresa J. Detwiler aka Theresa Grimes 159 South Bedford Street Carlisle, PA Real Debt $ 64,707.52 Interest fir 12/29/99-6/7/00 1,702.40 Atty's Fees Atty `s Writ Costs 109.20 Escrow Late Charges Sheriffs Costs Docketing 30.00 Poundage 50.00 Posting Bills 15.00 Advertising 15.00 Acknowledging Deed 30.00 Auctioneer 10.00 Law Library .50 County 1.00 Mileage 3.10 Certified Mail 1.17 Levy 15.00 Surcharge 20.00 Postpone sale Out of County Legal Search 200.00 Law Journal 279.35 Patriot News 234.53 Share of Bills 24.80 Distribution of Proceeds 25.00 Sheriffs Deed 26.50 Taxes