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COLUMBIA NATIONAL,
INCORPORATED
Plaintiff
VS.
SUSAN LYNN MCCAFFERTY
Defendant
: IN THE COURT OF COMMON PLEAS
: CUMBERLAND COUNTY, PENNSYLVANIA
NO. 79 ?ISS? ?(Uc C !E/Ll*1
CIVIL ACTION - LAW -
IN MORTGAGE FORECLOSURE
THIS LAW FIRM IS A DEBT COLLECTOR AND WE ARE ATTEMPTING
TO COLLECT A DEBT OWED TO OUR CLIENT. ANY INFORMATION
OBTAINED FROM YOU WILL BE USED FOR THE PURPOSE OF
COLLECTING THE DEBT.
N O T I C E
You have been sued in court. If you wish to defend against the claims set
forth in the following pages, you must take action within twenty (20) days after the
complaint and notice are served, by entering a written appearance personally or by
attorney and filing in writing with the court your defenses or objections to the
claims set forth against you. You are warned that if you fail to do so the case may
proceed without you and a judgment may be entered against you by the Court without
further notice for any money claimed in the Complaint or for any other claim or
relief requested by the Plaintiff. You may lose money or property or other rights
important to you.
YOU SHOULD TAKE THIS PAPER TO YOUR LAWYER AT ONCE. IF YOU DO NOT HAVE A LAWYER
OR CANNOT AFFORD ONE, GO TO OR TELEPHONE THE OFFICE SET FORTH BELOW TO FIND OUT
WHERE YOU CAN GET LEGAL HELP.
Cumberland County Bar Association
2 Liberty Ave., Carlisle, PA 17013
717-249-3166
Legal Services, Inc.
8 Irvine Row, Carlisle, PA 17013
717-243-9400
A V I S 0
LE HAN DEMANDADO A USTED EN LA CORTE. SI DESEA DEFENDERSE CONTRA LAS QUEJAS
PERESENTADAS, ES ABSOLUTAMENTE NECESSARIO QUE USTED RESPONDA DENTRO DE 20 DIAS
DESPUES DE SER SERVIDO CON ESTA DEMANDA Y AVISO. PARA DEFENDERSE ES NECESSARIO QUE
USTED, 0 SU ABOGADO, REGISTRE CON LA CORTE EN FORMA ESCRITA, EL PUNTO DE VISTA DE
USTED Y CUALQUIER OBJECCION CONTRA LAS QUEJAS EN ESTA DEMANDA.
RECUERDE: SI USTED NO REPONDE A ESTA DEMANDA, SE PUEDE PROSEGUIR CON EL
PROCESO SIN SU PARTICIPACION. ENTONCES, LA COUTE PUEDE, SIN NOTIFICARIO, DECIDIR A
FAVOR DEL DEMANDANTE Y REQUERIRA QUE USTED CUMPLA CON TODAS LAS PROVISIONES DE ESTA
DEMANDA. POR RAZON DE ESA DECISION, ES POSSIBLE QUE USTED PUEDA PERDER DINERO,
PROPIEDAD U OTROS DERECHOS IMPORTANTES.
LLEVE ESTA DEMANDA A UN ABOGADO IMMEDIATAMENTE.
SI NO CONOCE A UN ABOGADO, LLAME AL "LAWYER REFERENCE SERVICE" (SERVICIO DE
REFERENCIA DE ABOGADOS), 215-238-6300.
Cumberland County Bar Association
2 Liberty Ave., Carlisle, PA 17013
717-249-3166
Legal Services, Inc.
8 Irvine Row, Carlisle, PA 17013
717-243-9400
COLUMBIA NATIONAL,
INCORPORATED
Plaintiff
Vs.
SUSAN LYNN MCCAFFERTY
Defendant
: IN THE COURT OF COMMON PLEAS
: CUMBERLAND COUNTY, PENNSYLVANIA
NO.
: CIVIL ACTION - LAW -
: IN MORTGAGE FORECLOSURE
THE FOLLOWING NOTICE IS BEING PROVIDED PURSUANT TO THE
FAIR DEBT COLLECTION PRACTICES ACT, 15 U.S.C. §1601:
The undersigned attorney is attempting to collect a
debt owed to the Plaintiff, and any information
obtained will be used for that purpose. The amount
of the debt is stated in this Complaint. Plaintiff
is the creditor to whom the debt is owed. Unless
the Debtor, within thirty (30) days after your
receipt of this notice disputes the validity of the
aforesaid debt or any portion thereof owing to the
Plaintiff, the undersigned attorney will assume
that said debt is valid. If the Debtor notifies
the undersigned attorney in writing within the said
thirty (30) day period that the aforesaid debt, or
any portion thereof, is disputed, the undersigned
attorney shall obtain written verification of the
said debt from the Plaintiff and mail same to
Debtor. Upon written request by Debtor to the
undersigned attorney within said thirty (30) day
period, the undersigned attorney will provide
debtor with the name and address of the original
creditor if different from the current creditor.
PURCELL, KRUG & HALLER
Leon P. Haller, Esquire
1719 North Front Street
Harrisburg, PA 17102-2392
(717)234-4178
Attorney ID #15700
Attorney for Plaintiff
COLUMBIA NATIONAL,
INCORPORATED : IN THE COURT OF COMMON PLEAS
Plaintiff CUMBERLAND COUNTY, PENNSYLVANIA
VS.
NO.
SUSAN LYNN MCCAFFERTY
Defendant : CIVIL ACTION - LAW _
: IN MORTGAGE FORECLOSURE
C 0 M-- L A I N T
I. Plaintiff, COLUMBIA NATIONAL, INCORPORATED, is a
{ Maryland Corporation, with an address of 7142 Columbia Gateway
Drive, Columbia, Maryland 21046-2132.
2. Defendant, SUSAN LYNN MCCAFFERTY, is an adult individual
whose last known address is 1915 PRINCETON AVENUE, 12AMP HILL,
PENNSYLVANIA 17011.
3. On or about January 4, 1994, the said Defendant executed
and delivered a Mortgage Note in the sum of $86,450.00 payable to
COLUMBIA NATIONAL, INCORPORATED, which Note is attached hereto
and marked Exhibit "A°.
4. Contemporaneously with and at the time of the execution
of the aforesaid Mortgage Note, in order to secure payment of the
same, Defendant made, executed, and delivered to original
Mortgagee, a certain real estate Mortgage which is recorded in
the Recorder of Deeds Office of the within County and
Commonwealth in Mortgage Book 1190, Page 770 conveying to
original Mortgagee the subject premises. Said Mortgage is
incorporated herein by reference.
5. The land subject to the Mortgage is: 1915 PRINCETON
AVENUE, CAMP HILL, PENNSYLVANIA 17011 and is more particularly
described in Exhibit "B° attached hereto.
6. The said Defendant is the real owner of the land subject
to the Mortgage.
7. The Mortgage is in default due to the fact that
Mortgagor has failed to pay the installment due on January 1,
1999 and all subsequent installments thereon, and the following
amounts are due on the Mortgage:
(a) Unpaid principal balance
$ 81,302.19
(b) Interest at $15.42 per day
from 12/1/98 to 811199
(based on contract rate of 7.370%) 3,747.06
(c) Accumulated Late Charges 140.20
(d) Late charges at $19.63
per month for 8 months 157.04
(e) Escrow 0.00
(f) S, Attorney's Commission 4,065.11
$ 99,411.60
*Together with interest at the per diem rate noted in (b) above
after August 1, 1999 and other charges and costs to date of
Sheriff's Sale.
The attorney's fees set forth above are in conformity with
the Mortgage documents and Pennsylvania law, and will be
collected in the event of a third party purchaser at Sheriff's
Sale. If the Mortgage is reinstated prior to the sale,
reasonable attorney's fees will be charged that are actually
incurred by Plaintiff.
8. No judgment has been entered upon said Mortgage in any
jurisdiction.
9. Notice of intention to foreclose and accelerate the
loan balance pursuant to Pennsylvania Act No. 6 of 1974 is not
required in that the original principal balance exceeds
$50,000.00.
10. Defendant is not a member of the Armed Forces of the
United States of America, nor engaged in any way which would
bring her within the Soldiers and Sailors Relief Act of 1940, as
amended.
11. The within Mortgage is insured by the Federal Housing
Administration under Title II of the National Housing Act and, as
such, is not subject to the provisions of Pennsylvania Act No. 91
of 1983.
WHEREFORE, Plaintiff demands judgment in Mortgage
foreclosure "IN REM" for the aforementioned total amount due
together with interest at the rate of 7.370% ($15.42 per diem),
together with other charges and costs including escrow advances
incidental thereto to the date of Sheriff's Sale and for
foreclosure and sale of the property within described.
PURCELL CRU & ?R
By
Le P. Haller
Attorney for Plaintiff
I.D. #15700
1719 N. Front Street
Harrisburg, Pa. 17102
(717) 234-4178
Multistate FHA Case No.
ADJUSTABLE RATE NOTE 441-4794189-729
JANUARY 4TH , 1994
[Date]
1915 PRINCETON AVE. CAMP HILL, PENNSYLVANIA 17011
1. PARTIES ]Property Address]
"Borrower" means each person signing at the time of this Note, and the person's successors and assigns. "Lender"
means
COLUMBIA NATIONAL, INCORPORATED, A MARYLAND CORPORATION
and its successors and assigns.
2. BORROWER'S PROMISE TO PAY; INTEREST
In return for a loan received from Lender, Borrower promises to pay the principal sum of
EIGHTY SIX THOUSAND FOUR HUNDRED FIFTY AND 00/100
Dollars(U.S.$******86,450.00), plus interest, to the order of Lender. Interest will be charged on unpaid
principal, from the dateofdisbursementoftheloan proceeds by Lender, ata rate Of FIVE AND ONE-HALF
percent (* * * * * * * * *5 .500 %) per year. The interest rate may change in accordance with Paragmph 5(C) of this Note.
3. PROMISE TO PAY SECURED
Borrower's promise to pay is secured by a mortgage, deed of trust or similar security instrument that is dated the
same date as this Note and called the "Security Instrument." That Security Instrument protects the Lender from losses
which might result if Borrower defaults under this Note.
4. MANNER OF PAYMENT
(A) Time
Borrower shall make a payment of principal and interest to Lender on the first day of each month beginning on
MARCH 01 1994 Any principal and interest remaining on the first day of FEBRUARY 01
2024 will be due on that date, which is called the "Maturity Date."
(B) Place
Payment shall be made at COLUMBIA NATIONAL, INCORPORATED , P,O. BOX 905,
COLUMBIA, MARYLAND 21044-0905 or at such other place as Lender may designate in
writing by notice to Borrower.
(C) Amount
Initially, each monthly payment of principal and interest will be in the amount of $ .... ***"*490.86.
This amount will be part of a larger monthly payment required by the Security Instrument that shall be applied to
principal, interest and other items in the order described in the Security Instrument. This amount may change in
accordance with Paragraph 5(E)ofthis Note.
S. INTEREST RATE AND MONTHLY PAYMENT CHANGES
(A) Change Date
The interest rate may change on the first day of APRIL 01 1995 and on that day of each
succeeding year. "Change Date" means each date on which the interest rats could change.
(B) The Index
Beginning with the first Change Date, the interest rate will be based on an Index. "Index" means the weekly
FHA Multistate Adjustable Rate Note - 2/91
Pao* 1 of 3 % .
Ck-590 (9103) VMP MORTGAGE FORMS 'J313)2938100 (8001521-7291
Inlllalr. ,
FAN1 01/03/94 3:45 PM 02001765
average yield on United States Treasury Securities adjus
Federal Reserve B ted to a constant maturity ol'one year, as made available by the
Board. "Current Index" means the most recent Index figure available 30 days before; the Change Date,
If the Index (as defined above) is no longer available, Lender will use as a new Index any index prescribed by the
Secretary (as defined in Paragraph 7(B)). Lender will give Borrower notice of the new Index.
(C) Calculation of Interest Rate Changes
Before each Change Date, Lender will calculate anew interest rate by adding a margin of TWO
percentage point(s) ( •••......2 .000 %) to the Current Index and rounding
the sum to the nearest onc•cighlh of one percentage point (0.125%). Subject to the limits stated in Paragraph 5(D) of this
Note, this rounded amount will be the new interest rate until the next Change Date.
(D) Limits on Interest Rate Changes
The interest rate will never increase or decrease by more than one percentage point (1.0%) on any single Change
Date. The interest rate will never be more than five percentage points (5.0%) higher or lower than the initial interest rate
stated in Paragraph 2 of this Note.
(E) Calculation of Payment Change
If the interest rate changes on a Change Date, Lender will calculate the amount of monthly payment of principal
and interest which would be necessary to repay the unpaid principal balance in full at the Maturity Date at the new
interest rate through substantially equal payments. In making such calculation, Lender will use the unpaid principal
balance which would be owed on the Change Date if there had been no default in payment on the Note, reduced by the
amount of any prepayments to principal. The result of this calculation will be the amount of the new monthly payment of
principal and interest.
(F) Notice of Changes
Lender will give notice to Borrower of any change in the interest rate and monthly payment amount. The notice
must be given at least 25 days before the new monthly payment amount is due, and must set forth (i) the date of the
notice, (ii) the Change Date, (iii) the old interest rate, (iv) the new interest rate, (v) the new monthly payment amount,
(vi) the Current Index and the date it was published, (vii) the method of calculating the change in monthly payment
amount, and (viii) any other information which may be required by law from time to time.
(G) Effective Date of Changes
A new interest rate calculated in accordance with Paragraphs 5(C) and 5(D) of this Note will become effective
on the Change Date. Borrower shall make a payment in the new monthly amount begitming on the first payment date
which occurs at least 25 days after Lender has given Borrower the notice of changes required by Paragraph 5(F) of this
Note. Borrower shall have no obligation to pay any increase in the monthly payment amount calculated in accordance
with Paragraph 5(E) of this Note for any payment date occurring less than 25 days after Lender has given the required
notice. If the monthly payment amount calculated in accordance with Paragraph 5(E) of this Note decreased, but Lender
failed to give timely notice of the decrease and Borrower made any monthly payment amounts exceeding the payment
amount which should have been stated in a timely notice, then Borrower has the option to either (i) demand the return to
Borrower of any excess payment, with interest thereon at the Note rate (a rate equal to the interest rate which should
have been stated in a timely notice), or (ii) request that any excess payment, with interest thereon at the Note rate, be
applied as payment of principal. Lender's obligation to return any excess payment with interest on demand is not
assignable even if this Note is otherwise assigned before the demand for return is made.
6. BORROWER'S RIGHT TO PREPAY
Borrower has the right to pay the debt evidenced by this Note, in whole or in part, without charge or penalty, on the
first day of any month.
7. BORROWER'S FAILURE TO PAY
(A) Late Charge for Overdue Payments
If Lender has not received the full monthly payment required by the Security Instrument, as described in
Paragraph 4(C) of this Note, by the end of fifteen calendar days after the payment is due, Lender may collect a late
charge in the amount of FOUR percent( • • • • • •.......4 , 00%) of the
overdue amount of each payment.
(B) Default
If Borrower defaults by failing to pay in full any monthly payment, then Lender may, except as limited by
regulations of the Secretary in the case of payment defaults, require immediate payment in full of the principal balance
remaining due and all accrued interest. Lender may choose not to exercise this option without waiving its rights in the
1590 I9I03I
FAN1
01/03/94
P... 203
3:45 PM
02001765
event of any subsequent default. 'T'his Note does not authorize acceleration when not permitted by HUD regulations. As
used in this Note, "Secretary" means the Secretary of Housing and Urban Development or his or her designee.
(C) Payment of Costs and Expenses
If Lender has required immediate payment in full, as described above, Lender may require Borrower to pay costs
and expenses including reasonable and customary attorneys' fees for enforcing this Note. Such fees and costs shall bear
interest from the date of disbursementat the same rate as the principal of this Note.
8. WAIVERS
Borrower and any other person who has obligations under this Note waive the rights of presentment and notice of
dishonor. "Presentment" means the right to require Lender to demand payment of amounts due. "Notice of dishonor"
means the right to require Lender to gi ve notice to other persons that amounts due have not been paid.
9. GIVINGOFNOTICES
Unless applicable law requires a different method, any notice that must be given to Borrower under this Note will be
given by delivering it or by mailing it by first class mail to Borrower at the property address above or at a different address
if Borrower has given Lender a notice of Borrower's different address.
Any notice that must be given to Lender under this Note will be given by first class mail to Lender at the address
stated in Paragraph 4(B) or at adifferent address if Borrower is given a noliceof that different address.
10. OBLIGATIONS OF PERSONS UNDER THIS NOTE
If more than orie person signs this Note, each person is fully and personally obligated to keep all of the promises
made in this Note, including the promise to pay the full amount owed. Any person who is a guarantor, surety or endorser
of this Note is also obligated to do these things. Any person who takes over these obligations, including the obligations of
a guarantor, surety or endorser of this Note, is also obligated to keep all of the promises made in this Note. Lender may
enforce its rights under this Note against each person individually or against all signatories together. Any one person
signing this Note may be required to pay all of the amounts owed under this Note.
BY SIGNING BELOW, Borrower accepts and agrees to the terms and covenants contained in this Note.
(Seal)
1,4 SUSAN LYNN MCCAFFERTV -Borrower
-Borrower
-(Seal)
-Borrower
(Seal)
-Borrower .-
(o®590 (91031
P., 3.1 3
FANS 01/03/94 3:45 PM 02001765
ALL THAT CERTAIN lot or tract of land situate in the Borough
of Camp Hill, Cumberland County, Pennsylvania, in accordance with
a survey by Gerrit J. Betz, Registered Surveyor, dated August 31,
1972, and being more particularly bounded and described as follows,
to wit:
BEGINNING at a hub on the southern line of Princeton Avenue,
said point being 452.46 feet from the southwest corner of Princeton
Avenue and 19th Street measured in a westerly direction; thence
South 30 degrees 17 minutes East 120 feet along the dividing line
between Lots 7 and 8 on the hereinafter mentioned Plan of Lots to
a point; thence extending South 59 degrees 43 minutes West 60 feet
to a hub; thence extending North 30 degrees 17 minutes West 120
feet along the dividing line between Lots 8 and 9 on the
hereinafter mentioned Plan of Lots to a hub on the southern line of
Princeton Avenue; thence by said line North 59 degrees 43 minutes
East 60 feet to a point, the place of BEGINNING.
HAVING THEREON erected a two story brick dwelling known and
numbered as 1915 Princeton Avenue, Camp Hill, PA.
4?. .?.. •• :twY
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+r•, the recordingofveula
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IN-? q- I t+ul - Page ..L_Lv s
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.,.this day o 19-
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rpail.l.Jll F+GE 7if;
COMPANY NAME : allMUA NMO AL, DMRTTMM
VERIFICATrON
I verity that the statements made in the foregoing Complaint
are true and correct.
I understand that false statements herein are made subject
to the penalties of is Pa. C.S. Section 4904 relating to unsworn
falsification to authorities.
Dated: JulY 22, 1999
Sharon Phillips-Cary
Title Assistant Treasurer
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SHERIFF'S RETURN - NOT FOUND
CASE NO: 1999-04558 P
COMMONWEALTH OF PENNSYLVANIA:
COUNTY OF CUMBERLAND
COLUMBIA NATIONAL INCORPORATED
VS.
MCCAFFERTY SUSAN LYNN
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: MCCAFFERTY SUSAN LYNN
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
MCCAFFERTY SUSAN LYNN
DEFT. NO LONGER RESIDES AT ADDRESS STATED, LEFT
NO FORWARDING WITH THE P.O., HOUSE IS EMPTY. Return not found as per
Atty 8/3/99.
Sheriff's Costs: So answ s:
Docketing 18.00
Service 9.30
Not Found Return 5.00 ff99y?f
Surcharge 8.00 II?? omas ine, eri
$?D 08/04%139 9UG & HALLER
Sworn and subscribed to before me
this y -q-- day of
1999 A.D.
ro ono ar
COLUMBIA NATIONAL,
INCORPORATED
Plaintiff
VS.
SUSAN LYNN MCCAFFERTY
Defendant
THIS LAW FIRM IS A DEBT
TO COLLECT A DEBT OWED
OBTAINED FROM YOU WILL
COLLECTING THE DEBT.
: IN THE COURT OF COMMON PLEAS
: CUMBERLAND COUNTY, PENNSYLVANIA
NO. 9?f lJJ? l !Ul °<.21?
: CIVIL ACTION - LAW -
: IN MORTGAGE FORECLOSURE
COLLECTOR AND WE ARE ATTEMPTING
TO OUR CLIENT. ANY INFORMATION
BE USED FOR THE PURPOSE OF
N O T I C E
You have been sued in court. If you wish to defend against the claims set
forth in the following pages, you must take action within twenty (20) days after the
Complaint and notice are served, by entering a written appearance personally or by
attorney and filing in writing with the court your defenses or objections to the
claims set forth against you. You are warned that if you fail to do so the case may
proceed without you and a judgment may be entered against you by the court without
further notice for any money claimed in the Complaint or for any other claim or
relief requested by the Plaintiff. You may lose money or property or other rights
important to you.
YOU SHOULD TAKE THIS PAPER TO YOUR LAWYER AT ONCE. IF YOU DO NOT HAVE A LAWYER
OR CANNOT AFFORD ONE, GO TO OR TELEPHONE THE OFFICE SET FORTH BELOW TO FIND OUT
WHERE YOU CAN GET LEGAL HELP.
Cumberland County Bar Association
2 Liberty Ave., Carlisle, PA 17013
717-249-3166
Legal Services, Inc.
8 Irvine Row, Carlisle, PA 17013
717-243-9400
A V I S 0
LEHAN DEMANDADO A USTED EN LA CORTE. SI DESEA DEFENDERSE CONTRA LAS QUEJAS
PERESENTADAS, ES ABSOLUTAMENTE NECESSARIO QUE USTED RESPONDA DENTRO DE 20 DIAS
DESPUES DE SER SERVIDO CON ESTA DEMANDA Y AVISO. PARA DEFENDERSE ES NECESSARIO QUE
USTED, 0 SU ABOGADO, REGISTRE CON LA CORTE EN FORMA ESCRITA, EL PUNTO DE VISTA DE
USTED Y CUALQUIER OBJECCION CONTRA LAS QUEJAS EN ESTA DEMANDA.
RECUERDE: SI USTED NO REPONDE A ESTA UEMANDA, SE PUEDE PROSEGUIR CON EL
PROCESO SIN SU PARTICIPACION. ENTONCES, LA COUTE PUEDE, SIN NOTIFICARIO, DECIDIR A
FAVOR DEL DEMANDANTE Y REQUERIRA QUE USTED CUMPLA CON TODAS LAS PROVISIONES DE ESTA
DEMANDA. POR RAZON DE ESA DECISION, ES POSSIBLE QUE USTED PUEDA PERDER DINERO,
PROPIEDAD U OTROS DERECHOS IMPORTANTES.
LLEVE ESTA DEMANDA A UN ABOGADO IMMEDIATAMENTE.
SI NO CONOCE A UN ABOGADO, LLAME AL "LAWYER REFERENCE SERVICE" (SERVICIO DE
REFERENCIA DE ABOGADOS), 215-238-6300.
Cumberland County Bar Association
2 Liberty Ave., Carlisle, PA 17013
717-249-3166
Legal Services, Inc.
8 Irvine Row, Carlisle, PA 17013
717-243-9400
TRUE COPY FROM RECORD
In Testimony whereof, I here unto set my hand
and tha seal of said Cot at Carlisle, Pa.
Thi572 ay of 19
2?
rn4thonotary
COLUMBIA NATIONAL,
INCORPORATED
Plaintiff
Vs.
SUSAN LYNN MCCAFFERTY
Defendant
: IN THE COURT OF COMMON PLEAS
: CUMBERLAND COUNTY, PENNSYLVANIA
: NO.
: CIVIL ACTION - LAW -
: IN MORTGAGE FORECLOSURE
THE FOLLOWING NOTICE IS BEING PROVIDED PURSUANT TO THE
FAIR DEBT COLLECTION PRACTICES ACT, 15 U.S.C. §1601:
The undersigned attorney is attempting to collect a
debt owed to the Plaintiff, and any information
obtained will be used for that purpose. The amount
of the debt is stated in this Complaint. Plaintiff
is the creditor to whom the debt is owed. Unless
the Debtor, within thirty (30) days after your
receipt of this notice disputes the validity of the
aforesaid debt or any portion thereof owing to the
Plaintiff, the undersigned attorney will assume
that said debt is valid. If the Debtor notifies
the undersigned attorney in writing within the said
thirty (30) day period that the aforesaid debt, or
any portion thereof, is disputed, the undersigned
attorney shall obtain written verification of the
said debt from the Plaintiff and mail same to
Debtor. Upon written request by Debtor to the
undersigned attorney within said thirty (30) day
period, the undersigned attorney will provide
debtor with the name and address of the original
creditor if different from the current creditor.
PURCELL, KRUG & HALLER
Leon P. Haller, Esquire
1719 North Front Street
Harrisburg, PA 17102-2392
(717)234-4178
Attorney ID #15700
Attorney for Plaintiff
COLUMBIA NATIONAL, : IN THE COURT OF COMMON PLEAS
INCORPORATED : CUMBERLAND COUNTY, PENNSYLVANIA
Plaintiff
VS. NO.
SUSAN LYNN MCCAFFERTY CIVIL ACTION - LAW -
Defendant IN MORTGAGE FORECLOSURE
C O M P L A I N T
1. Plaintiff, COLUMBIA NATIONAL, INCORPORATED, is a
Maryland Corporation, with an address of 7142 Columbia Gateway
Drive, Columbia, Maryland 21046-2132.
2. Defendant, SUSAN LYNN MCCAFFERTY, is an adult individual
whose last known address is 1915 PRINCETON AVENUE, CAMP HILL,
PENNSYLVANIA 17011.
3. On or about January 4, 1994, the said Defendant executed
and delivered a Mortgage Note in the sum of $66,450.00 payable to
COLUMBIA NATIONAL, INCORPORATED, which Note is attached hereto
and marked Exhibit "A"
4. Contemporaneously with and at the time of the execution
of the aforesaid Mortgage Note, in order to secure payment of the
same, Defendant made, executed, and delivered to original
Mortgagee, a certain real estate Mortgage which is recorded in
the Recorder of Deeds Office of the within County and
Commonwealth in Mortgage Book 1190, Page 770 conveying to
original Mortgagee the subject premises. Said Mortgage is
incorporated herein by reference.
5. The land subject to the Mortgage is: 1915 PRINCETON
AVENUE, CAMP HILL, PENNSYLVANIA 17011 and is more particularly
described in Exhibit "B" attached hereto.
6. The said Defendant is the real owner of the land subject
to the Mortgage.
7. The Mortgage is in default due to the fact that
Mortgagor has failed to pay the installment due on January 1,
1999 and all subsequent installments thereon, and the following
amounts are due on the Mortgage:
(a) Unpaid principal balance $ 81,302.19
(b) Interest at $15.42 per day
from 12/1/98 to 8/1/99
(based on contract rate of 7.3701) 3,747.06
(c) Accumulated Late Charges 140.20
(d) Late charges at $19.63
per month for 8 months 157.04
(e) Escrow 0.00
(f) 5% Attorney's Commission 4,065.11
$ 99,411.60
*Together with interest at the per diem rate noted in (b) above
after August 1, 1999 and other charges and costs to date of
Sheriff's Sale.
The attorney's fees set forth above are in conformity with
the Mortgage documents and Pennsylvania law, and will be
collected in the event of a third party purchaser at Sheriff's
Sale. If the Mortgage is reinstated prior to the sale,
reasonable attorney's fees will be charged that are actually
incurred by Plaintiff.
8. No judgment has been entered upon said Mortgage in any
jurisdiction.
9. Notice of intention to foreclose and accelerate the
loan balance pursuant to Pennsylvania Act No. 6 of 1974 is not
required in that the original principal balance exceeds
$50,000.00.
10. Defendant is not a member of the Armed Forces of the
United States of America, nor engaged in any way which would
bring her within the Soldiers and Sailors Relief Act of 1940, as
amended.
11. The within Mortgage is insured by the Federal Housing
Administration under Title II of the National Housing Act and, as
such, is not subject to the provisions of Pennsylvania Act No. 91
of 1983.
WHEREFORE, Plaintiff demands judgment in Mortgage
foreclosure "IN REM" for the aforementioned total amount due
together with interest at the rate of 7.370% ($15.42 per diem),
together with other charges and costs including escrow advances
incidental thereto to the date of Sheriff's Sale and for
foreclosure and sale of the property within described.
PURCELL-,ARUW & ,yfAIA-ER
By / i
Le P. Haller
Attorney for Plaintiff
I.D. #15700
1719 N. Front Street
Harrisburg, Pa. 17102
(717) 234-4178
Multistate FHA Case No.
ADJUSTABLE RATE NOTE [441-4794189-7729
JANUARY 4TH , 1994
[Date]
1915 PRINCETON AVE. CAMP HILL, PENNSYLVANIA 17011
1. PARTIES [Property Address]
"Borrower" means each person signing at the time of this Note, and the person's successors and assigns. "Lender"
means
COLUMBIA NATIONAL, INCORPORATED, A MARYLAND CORPORATION
and its successors and assigns.
2. BORROWER'S PROMISE TO PAY- INTEREST
In return for a loan received from Lender, Borrower promises to pay the principal sum of
EIGHTY SIX THOUSAND FOUR HUNDRED FIFTY AND 00/100
Dollars (U.S.$•*`*86,450.00), plus interest, to the order of Lender. Interest will be charged on unpaid
principal, from the date of disbursement of the loan proceeds by Lender, at a rate of FIVE AND ONE-HALF
Percent (•» • «- - * *.5 , 500 %) per year. The interest rate may change in accordance with Paragraph S(C) of this Note.
3. PROMISE TO PAY SECURED
Borrower's promise to pay is secured by a mortgage, deed of trust or similar security instrument that is dated the
same date as this Note and called the "Security Instrument." That Security Instrument protects the Lender from losses
which might result if Borrower defaults under this Note.
4. MANNER OFPAYMENT
(A) Time
Borrower shall make a payment of principal and interest to Lender on the first day of each month beginning on
MARCH 01 1994 Any principal and interest remaining on the first day of FEBRUARY 01
2024 will be due on that date, which is called the "Maturity Date."
(B) Place
Payment shall be made at COLUMBIA NATIONAL, INCORPORATED , P,0. BOX 905,
COLUMBIA, MARYLAND 21044-0905 or at such other place as Lender may designate in
writing by notice to Borrower.
(C) Amount
Initially, each monthly payment of principal and interest will be in the amount Of $ **********490 86
This amount will be part of a larger monthly payment required by the Security Instrument thatshall bplieedd to
principal, interest and other items in the order described in the Security Instrument. This amount may change in
accordance with Paragraph 5(E) of this Note.
5. INTEREST RATE AND MONTHLY PAYMENT CHANGES
(A) Change Date
The interest rate may change on the first day of APRIL 01 199 succeeding year. "Change Date" means each date on which the interest rate could change. and on that day of each
(B) The Index
Beginning with the first Change Date, the interest rate will be based on an Index. "Index" means the weekly
690 191031
FAN1
Pp. 1013
VMP MORTGAGE FORMS' 13 1 312 9 3-9 100'(800)521-7291
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01/03/94
3:45 PM
tate Note - 2191
mna.: : [
02001765
average yield on United States Treasury Securities adjusted to a constant maturity of one year, as made available by the
Federal Reserve Board. "Current Index" means the most recent Index figure available 30 days before the Change Date.
If the Index (as defined above) is no longer available, Lender will use as a new Index any index prescribed by the
Secretary (as defined in Paragraph 7(B)). Lender will give Borrower notice of the new Index.
(C) Calculation of Interest Rate Changes
Before each Change Date, Lender will calculate anew interest rate by adding a margin of TWO
percentage point(s) ( ' • •''"''2 , 000 %) to the Current Index and rounding
the sum to the nearest one-eighth of one percentage point (0.125%). Subject to the limits stated in Paragraph 5(D) of this
Note, this rounded amount will be the new interest rate until the next Change Date.
(D) Limits on Interest Rate Changes
The interest rate will never increase or decrease by mote than one percentage point (1.0%) on any single Change
Date. The interest rate will never be more than five percentage points (5.0%) higher or lower than the initial interest rate
stated in Paragraph 2 of this Note.
(E) Calculation of Payment Change
If the interest rate changes on a Change Date, Lender will calculate the amount of monthly payment of principal
and interest which would be necessary to repay the unpaid principal balance in full at the Maturity Date at the new
interest rate through substantially equal payments. In making such calculation, Lender will use the unpaid principal
balance which would be owed on the Change Date if there had been no default in payment on the Note, reduced by the
amount of any prepayments to principal. The result of this calculation will be the amount of the new monthly payment of
principal and interest.
(F) Notice of Changes
Lender will give notice to Borrower of any change in the interest rate and monthly payment amount. The notice
must be given at least 25 days before the new monthly payment amount is due, and must set forth ;i) the date of the
notice, (ii) the Change Date, (iii) the old interest rate, (iv) the new interest rate, (v) the new monthly payment amount,
(vi) the Current Index and the date it was published, (vii) the method of calculating the change in monthly payment
amount, and (viii) any other information which may be required by law from time to time.
(G) Effective Date of Changes
A new interest rate calculated in accordance with Paragraphs 5(C) and 5(D) of this Note will become effective
on the Change Date. Borrower shall make a payment in the new monthly amount beginning on the first payment date
which occurs at least 25 days after Lender has given Borrower the notice of changes required by Paragraph 5(F) of this
Note. Borrower shall have no obligation to pay any increase in the monthly payment amount calculated in accordance
with Paragraph 5(E) of this Note for any payment date occurring less than 25 days after Lender has given the required
notice. If the monthly payment amount calculated in accordance with Paragraph 5(E) of this Note decreased, but Lender
failed to give timely notice of the decrease and Borrower made any monthly payment amounts exceeding the payment
amount which should have been stated in a timely notice, then Borrower has the option to either (i) demand the return to
Borrower of any excess payment, with interest thereon at the Note rate (a rate equal to the interest rate which should
have been stated in a timely notice), or (ii) request that any excess payment, with interest thereon at the Note rate, be
applied as payment of principal. Lender's obligation to return any excess payment with interest on demand is not
assignable even if this Note is otherwise assigned before the demand for return is made.
6. BORROWER'S RIGHT TO PREPAY
Borrower has the right to pay the debt evidenced by this Note, in whole or in part, without charge or penalty, on the
first day of any month.
7. BORROWER'S FAILURE TO PAY
(A) Late Charge for Overdue Payments
If Lender has not received the full monthly payment required by the Security Instrument, as described in
Paragraph 4(C) of this Note, by the end of fifteen calendar days after the payment is due, Lender may collect a late
charge in the amount of FOUR percent( """"'**'*4.00%) of the
overdue amount of each payment.
(B) Default
If Borrower defaults by failing to pay in full any monthly payment, then Lender may, except as limited by
regulations of the Secretary in the case of payment defaults, require immediate payment in full of the principal balance
remaining due and all accrued interest. Lender may choose not to exercise this option without waiving its rights in the
890 IGtWI Ngs 2 oft Inltialc r "I
FAN1 01/03/94 3;45 PM 02001765
event of any subsequent default. This Note does not authorize acceleration when not permitted by HUD regulations. As
used in this Note, "Secretary" means the Secretary of Housing and Urban Development or his or her designee.
(C) Payment of Costs and Expenses
If Lender has required immediate payment in full, as described above, Lender may require Borrower to pay costs
and expenses including reasonable and customary attorneys' fees for enforcing this Note. Such fees and costs shall bear
interest from the date of disbursement at the same rate as the principal of this Note.
8. WAIVERS
Borrower and any other person who has obligations under this Note waive the rights of presentment and notice of
dishonor. "Presentment" means the right to require Lender to demand payment of amounts due. "Notice of dishonor"
means the right to require Lender to give notice to other persons that amounts due have not been paid.
9. GIVINGOFNOTICES
Unless applicable law requires a different method, any notice that must be given to Borrower under this Note will be
given by delivering it or by mailing it by first class mail to Borrower at the property address above or at a different address
if Borrower has given Lender a notice of Borrower's different address.
Any notice that must be given to Lender under this Note will be given by first class mail to Lender at the address
stated in Paragraph 4(B) or at a different address if Borrower is given a notice of that different address.
10. OBLIGATIONSOFPERSONSUNDER TEISNOTE
If more than one person signs this Note, each person is fully and personally obligated to keep all of the promises
made in this Note, including the promise to pay the full amount owed. Any person who is a guarantor, surety or endorser
of ttds Note is also obligated to do these things. Any person who takes over these obligations, including the obligations of
a guarantor, surety or endorser of this Note, is also obligated to keep all of the promises made in this Note. Lender may
enforce its rights under this Note against each person individually or against all signatories together. Any one person
signing this Note may be required to pay all of the amounts owed under this Note.
BY SIGNING BELOW, Borrower accepts and agrees to the terms and covenants contained in this Note.
_7 (Seal)
SUSAN LYNN MCCAFFERTY ?-Borrower
(Seal)
-Borrower
-Borrower
-Borrower
Mi590 121031
P.2. 3.13
FAN3 01/03/94 3;45 PM 02001765
ALL THAT CERTAIN lot or tract of land situate in the Borough
of Camp Hill, Cumberland County, Pennsylvania, in accordance with
a survey by Gerrit J. Betz, Registered Surveyor, dated August 31,
1972, and being more particularly bounded and described as follows,
to wit:
BEGINNING at a hub on the southern line of Princeton Avenue,
said point being 452.46 feet from the southwest corner of Princeton
Avenue and 19th Street measured in a westerly direction; thence
South 30 degrees 17 minutes East 120 feet along the dividing line
between Lots 7 and 8 on the hereinafter mentioned Plan of Lots to
a point; thence extending South 59 degrees 43 minutes West 60 feet
to a hub; thence extending North 30 degrees 17 minutes West 120
feet along the dividing line between Lots 8 and 9 on the
hereinafter mentioned Plan of Lots to a hub on the southern line of
Princeton Avenue; thence by said line North 59 degrees 43 minutes
East 60 feet to a point, the place of BEGINNING.
HAVING THEREON erected a two story brick dwelling known and
numbered as 1915 Princeton Avenue, Camp Hill, PA.
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COMPANY NAME : O2[P3IA L.
VERIFICATION
I verify that the statements made in the foregoing Complaint
are true and correct.
I understand that false statements herein are made subject
to the penalties of is Pa. C.S. Section 4904 relating to unsworn
falsification to authorities.
Dated: July 22, 1999
sy_?f11 111 J?e?? C?
s`baron vaPhillips-Carv
Title Assistant Treasurer
r
OFFICE OF THE SHERIFF
CUP" ... , i ,14TY o
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JuL 18 1 ii PM 199
?, PENNSYLVANIA
COLUMBIA NATIONAL
INCORPORATED
Plaintiff
vs.
SUSAN LYNN MCCAFFERTY
Defendant
IN THE COURT OF COMMON PLEAS
CUMBERLAND COUNTY, PENNSYLVANIA
CIVIL ACTION - LAW -
No. 99 4558 CIVIL TERM
IN MORTGAGE FORECLOSURE
PRAECIPE TO REINSTATE COMPLAINT
TO THE PROTHONOTARY:
Kindly reinstate the complaint on the above captioned matter.
DATE: January 26, 2000
PURCELL, KRUG & HALLER
BY LeP. ler, Esquire
1719 rth Front Street
Harrisburg, PA. 17102
Attorney for Plaintiff
Attorney ID# 15700
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ONp 00 Awns W031 nVAS'TY
SHERIFF'S RETURN - REGULAR
CASE NO: 1999-04558 P
COMMONWEALTH OF PENNSYLVANIA:
COUNTY OF CUMBERLAND
COLUMBIA NATIONAL INCORPORATED
VS
MCCAFFERTY SUSAN LYNN
SHAWN HARRISON Sheriff or Deputy Sheriff of
Cumberland County, Pensylvania, who being duly sworn according to law,
says, the within COMPLAINT/MORT-FORECLOSUR was served upon
MCCAFFERTY SUSAN LYNN the
DEFENDANT , at 0015:19 HOURS, on the 31st day of January 2000
at 1915 PRINCETON AVENUE
CAMP HILL, PA 17011 by handing to
POSTED PROPERTY AT ABOVE ADDRESS
a true and attested copy of COMPLAINT/MORT-FORECLOSUR together with
REINSTATED W/NOTICE
and at the same time directing Her attention to the contents thereof.
Sheriff's Costs:
Docketing 18.00
Service 9.30
Posting 6.00
Surcharge 10.00
.00
43.30
Sworn and Subscribed to before
me this 1 ; day of
?aP?- ?cv1 A. D.
rothonotary
So Answer
?eRfMC +a?'
R. Thomas Kline
02/09/2000
PURCELL, KRUG HALLER
By: `
Deputy hex'ff
SHERIFF'S RETURN - U.S. CERTIFIED MAIL
CASE NO: 1999-04558 P
COMMONWEALTH OF PENNSYLVANIA
COUNTY OF CUMBERLAND
COLUMBIA NATIONAL INCORPORATED
VS.
MCCAFFERTY SUSAN LYNN
R. Thomas Kline , Sheriff of Cumberland
County, Pennsylvania, who being duly sworn according to law served the
within named DEFENDANT MCCAFFERTY SUSAN LYNN
by United States Certified Mail postage
prepaid, on the 31st day of January 2000 at 000800 HOURS, at
174 PENNSYLVANIA AVE # 3
WESTMINSTER, MD 21157 a true
and attested copy of the attached COMPLAINT/ MORT-FORECLOSUR. Together
with REINSTATED W/NOTICE
The returned
receipt card was signed by ILLEGIBLE SIGNATURE on
02/03/2000 .
Additional Comments:
Sheriff's Costs:
Docketing 6.00
Cert Mail 3.54
Affidavit .00
Surcharge 10.00
.00
19.54
Paid by PURCELL, KRUG & HALLER
Sworn and subscribed to before me
this 25 ° day ofd
.2Lv- A.D. T
I Prothonotary
So ans s
Thomas Kline
Sheriff of Cumberland Coun
on 02/09/2000 .
ty
SHERIFF'S RETURN - U.S. MAIL
CASE NO: 1999-04558 P
COMMONWEALTH OF PENNSYLVANIA
COUNTY OF CUMBERLAND
COLUMBIA NATIONAL INCORPORATED
VS
MCCAFFERTy SUSAN LYNN
R. Thomas Kline Sheriff
of Cumberland
County, Pennsylvania, who being duly sworn according to law served the
within named DEFENDANT MCCAFFERTY SUSAN LYNN
, by United States Mail postage prepaid,
on the 31st day of January 2000 , at 0008:00 Hours, at
174 PENNSYLVANIA AVE
2
a true and attested copy of the attached COMPLAINT/MORT-FORECLOSUR.
Sheriff's Costs:
Docketing
Postage
Affidavit
Surcharge
So answers:
6.00 -
.92
.00
10.00 R. Thomas Kline
.00 Sheriff of Cumberland County
16.92 PURCELL, KRUG & HALLER
02/09/2000
Sworn and subscribed to before me
this 75 z day of
<Gti?s y
a7 ova A. D.
1?c
Pro otary % '
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_.?_?. w_.. _.. .__. _ -.tom.. ^Vi•. _:!J
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ompe
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tems 1 and
or z for addiuonat services.
Complete nema 3,4a. and 4b. ing services (for an extra fee):
f 0 Pool your namB and address on the inverse of This loon so that we can rewan this
card to you.
? Attach this form to the bout of the nuolpiace. or an tore book it spew does not 1. ? Addressee's Address
(m perms.
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Relum Racolp
Requested
on the madpiew below the article number.
O The Return Receipt will show to whom the article was delivered and me date
O delivered.
3. Article Addressed to: 4a. ARicie Number
M 3 3 acs
Susan Lynn McCafferty
17 4D. service Type
Registered eRtfied
4 Pennsylvania Ave
f, 4 ? Express Mail ? Insured
Westminster, MD 2115-
We ? Return Receipt for Merchandise ? COD
7. Date of Delivery
. 5. Received By: (Print Name) 0. Addressee's ddre s (Only rerequesled and
lee is paid)
c 6. Sgnature (Addressee or Agent)
N
Ps Farm 3811, December 1994 102595-99 e-0223 Domestic Return Recelpl
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COLUMBIA NATIONAL INCORPORATED,
PLAINTIFF
VS.
SUSAN LYNN MCCAFFERTY,
DEFENDANT
IN THE COURT OF COMMON PLEAS
CUMBERLAND COUNTY, PENNSYLVANIA
CIVIL ACTION - LAW
NO. 1999 04558
IN MORTGAGE FORECLOSURE
P R A E C I P E
TO THE PROTHONOTARY OF THE WITHIN COUNTY:
Please enter JUDGMENT "in remit in favor of the Plaintiff and
against Defendant SUSAN LYNN McCAFFERTY for failure to plead to the
above action within twenty (20) days from date of service of the
Complaint, and assess Plaintiff's damages as follows:
Unpaid principal balance $81,302.19
Interest $ 3,747.06
(Per diem of $15.42
from 12/1/98 to 8/1/99)
Accumulated late charges $ 140.20
Late charges $ 156.04
($19.63 per month to 8/99)
Escrow Deficit $
5% Attorney's Commission $ 4,065.11
TOTAL $99,411.60**
** Together with additional interest at the per diem rate indicated
above from the date herein, based on the contract rate, and other
charges and costs to the date of Sheriff's Sale.
PURCELL, KRUG &
By
Leon P. Haller PA I.D. #15700
1719 North Front Street
Harrisburg, PA 17102
(717) 234-4178
I .HOMEM1IKFIDOCSICUMERLAIMCCAFFER P
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COLUMBIA NATIONAL INCORPORATED,
PLAINTIFF
VS.
SUSAN LYNN McCAFFERTY,
DEFENDANT
IN THE COURT OF COMMON PLEAS
CUMBERLAND COUNTY, PENNSYLVANIA
CIVIL ACTION - LAW
NO. 1999 04558
IN MORTGAGE FORECLOSURE
CERTIFICATE OF SERVICE
PURSUANT TO PA. R.C.P. 237.1
I hereby certify that on MAY 24, 2000 I served the Ten Day
Notice required by Pa. R.C.P. 237.1 on the Defendant(s) in this
matter by regular first class mail, postage prepaid, as indicated
on the attached Notice.
By
Leon P. Haller PA 1.57-7 -415700
Attorney for Plaintiff
Purcell, Krug & Haller
1719 North Front St.
Harrisburg, PA 17102
COLUMBIA NATIONAL,
INCORPORATED
Plaintiff
Vs.
SUSAN LYNN MCCAFFERTY
Defendant
IN THE COURT OF COMMON PLEAS
CUMBERLAND COUNTY, PENNSYLVANIA
: NO. 99-S-4558
CIVIL ACTION - LAW
IN MORTGAGE FORECLOSURE
DATE OF THIS NOTICE: May 24, 2000
TO: SUSAN LYNN MCCAFFERTY
174 PENNSYLVANIA AVENUE, 43
WESTMINISTER, MD 21157
SUSAN LYNN MCCAFFERTY
1915 PRINCETON AVENUE
CAMP HILL, PA 17011
THIS LAW FIRM IS A DEBT COLLECTOR AND WE ARE ATTEMPTING
TO COLLECT A DEBT OWED TO OUR CLIENT. ANY INFORMATION
OBTAINED FROM YOU WILL BE USED FOR THE PURPOSE OF
COLLECTING THE DEBT.
IMPORTANT NOTICE
YOU ARE IN DEFAULT BECAUSE YOU HAVE FAILED TO ENTER A WRITTEN
APPEARANCE PERSONALLY OR BY ATTORNEY AND FILE IN WRITING WITH THE
COURT YOUR DEFENSES OR OBJECTIONS TO THE CLAIMS SET FORTH AGAINST
YOU. UNLESS YOU ACT WITHIN TEN (10) DAYS FROM THE DATE OF THIS
NOTICE, A JUDGMENT MAY BE ENTERED AGAINST YOU WITHOUT A HEARING
AND YOU MAY LOSE YOUR PROPERTY OR OTHER IMPORTANT RIGHTS. YOU
SHOULD TAKE THIS NOTICE TO A LAWYER AT ONCE. IF YOU DO NOT HAVE A
LAWYER OR CANNOT AFFORD ONE, GO TO OR TELEPHONE THE FOLLOWING
OFFICE TO FIND OUT WHERE YOU CAN GET LEGAL HELP:
Lawyer Referral Service
Court Administrator
Cumberland County Courthouse
Carlisle, PA 17013
717-249-3166
PURCELL, KRUG & LLER
By
Leon P. Haller
Attorney for Plaintiff
I.D. #15700
1719 N. Front Street
Harrisburg, Pa. 17102
717-234-4178
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COLUMBIA NATIONAL INCORPORATED, IN THE COURT OF COMMON PLEAS
PLAINTIFF CUMBERLAND COUNTY, PENNSYLVANIA
VS. CIVIL ACTION - LAW
NO. 1999 04558
SUSAN LYNN McCAFFERTY,
DEFENDANT IN MORTGAGE FORECLOSURE
NOTICE OF ENTRY OF MMGMENT
TO THE ABOVE-NAMED DEFENDANTS:
You are hereby notified that on 'a /3 _;2 pro the
following judgment has been entered against you 'in the above-
captioned matter:
$99,411.60 and for the sale and foreclosure of your property
located at: 1915 Princeton Avenue, Camp Hill, PA 17011
Dated ??OVv
et,?' n..,
PROTHONOTARY
Attorney for Plaintiff:
Leon P. Haller
1719 North Front Street
Harrisburg, PA 17102
Phone: (717) 234-4178
I hereby certify that the following person(s) and their respective
addresses are the proper individuals to receive this Notice
pursuant to PA R.C.P. No. 236:
Susan Lynn McCafferty
174 Pennsylvania Avenue #3
Westminster, MD 21157
Susan Lynn McCafferty
1915 Princeton Avenue
Camp Hill, PA 17011
COLUMBIA NATIONAL INCORPORATED, : IN THE COURT OF COMMON PLEAS
PLAINTIFF CUMBERLAND COUNTY, PENNSYLVANIA
VS. CIVIL ACTION - LAW
NO. 1999 04558
SUSAN LYNN McCAFFERTY,
DEFENDANT IN MORTGAGE FORECLOSURE
NON-MILITARY AFFIDAVIT
COMMONWEALTH OF PENNSYLVANIA
SS
COUNTY OF DAUPHIN
Personally- appeared before me, a Notary Public in and for said
Commonwealth and County, LEON P. HALLER, ESQUIRE who being duly
sworn according to law deposes and states that the Defendant(s)
above named are not in the Military or Naval Service nor are they
engaged in any way which would bring them within the Soldiers and
Sailors Relief Act of 1940, as amended.
Sworn to and subscribed :
befo e this day :
of ?% 20 v-r?
otl ry Pu I c?
LEON P. HALLER, ESQUIRE
NOTARIAL SEAL
MARYLAND K. FERRET1 Notary Public
LOWER PAYTONN/P., DAUPHIN County
My Commission ExplresAL'GUST 8, 2002
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IN THE COURT OF COMMON PLEAS OF CUMBERLAND COUNTY, PENNSYLVANIA
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CIVIL DIVISION
PRAECIPE FOR WRIT OF EXECUTION
Caption:
COIUMBIA NATIONAL INCORPORATED,
Plaintiff
( ) Confessed Judgment
(xx) Other In Mortgage Foreclosure
File No. 1999 04558
VS.
SUSAN LYNN McCAFFERTY,
DEFENDANT
Amount Due per Judgment: $ 99,411.60
Interest franc8/1/99 $ 6,168.00 ($15.42)
Late charges $ 255.19 (19.63)
Escrow deficit $ 2,893.12
TO THE PROTHONOTARY OF THE SAID COURT: WRIT $108,727.91
The undersigned hereby certifies that the below does not arise out of a retail installment sale, contract, or
account based on a confession of judgment, but if it does, it is based on the appropriate original proceeding filed
pursuant to Act 7 of 1966 as amended; and for real property pursuant to Act 6 of 1974 as amended.
Issue writ of execution in the above matter to the Sheriff of Cumberland County,
for debt, interest and costs, upon the following described property of the defendant(s)
Real Estate: 1915 Princeton Avenue. Camo Hill PA
Sale date: 9/6/00
PRAECIPE FOR ATTACHMENT EXECUTION
Issue writ of attachment to the Sheriff of Ctmbprland County, for debt, interest and
costs, as above, directing attachment against the above-named garnishee(s) for the following property (if real
estate, supply six copies of the description; supply four copies of lengthy personalty list)
Real Estate: as indicated above
Real Owner: Susan Lynn McCafferty
and all other property of the defendant(s) in the possession, custody or control of the said garnishee(s).
Q (Indicate) Index this writ against the garnish e(s) as a lis pendens against real e e `f the
defendant(s) described in the attached exhibit.
Date 6/12/00 Signature: `
Print Name: Leon P. Haller, Esquire
Purcell, Krug & Haller
Address: 1719 North Fr=f- Street
Harrisburg, PA 17102
Attorney for: Plaintiff
Telephone: 717 234 4178
Supreme Court ID No.: PA #15700
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LEGAL DESCRIPTION
ALL THAT CERTAIN lot or tract of land situate in the Borough
of Camp Hill, Cumberland County, Pennsylvania, in accordance with
a survey by Gerrit J. Betz, Registered Surveyor, dated August 31,
1972, and being more particularly bounded and described as follows,
to wit:
BEGINNING at a hub on the southern line of Princeton Avenue,
said point being 452.46 feet from the southwest corner of Princeton
Avenue and 19th Street measured in a westerly direction; thence
South 30 degrees 17 minutes East 120 feet along the dividing line
between Lots 7 and 8 on the hereinafter mentioned Plan of Lots to
a point; thence extending South 59 degrees 43 minutes West 60 feet
to a hub; thence extending North 30 degrees 17 minutes West 120
feet along the dividing line between Lots 8 and 9 on the
hereinafter mentiuned Plan of Lot to a hub on the southern line of
Princeton Avenue; thence by said line North 59 degrees 43 minutes
East 60 feet to a point, the place'of BEGINNING.
HAVING ERECTED THEREONf a two story brick dwelling house known as
1915 Princeton Avenue, Camp Hill, PA.
BEING THE SAME PREMISES WHICH Thomas J. D'Annunzio, III and Susan
W. D'Annunzio by deed dated 1/4/94 and recorded in Cumberland
County Deed Book S-26 Page 1176 granted and conveyed unto Susan
Lynn McCafferty.
TO BE SOLD AS THE PROPERTY OF SUSAN LYNN MCCAFFERTY ON JUDGMENT NO.
1999 04558.
TAX PARCEL: 01-22-0536-328
e,,
COLUMBIA NATIONAL INCORPORATED, IN THE COURT OF COMMON PLEAS
PLAINTIFF CUMBERLAND COUNTY, PENNSYLVANIA
vs. CIVIL ACTION - LAW
NO. 1999 04558
SUSAN LYNN McCAFFERTY,
DEFENDANT IN MORTGAGE FORECLOSURE
AFFIDAVIT PURSUANT TO P.R.C.P. 3129.1
The Plaintiff in the above action, by its attorneys, Purcell,
Krug & Haller, sets forth as of the date the praecipe for the writ
of execution was filed, the following information concerning the
real property located at 1915 Princeton Avenue, Camp Hill, PA
17011:
1. Name and address of the Owner(s) or Reputed Owner(s):
Susan Lynn McCafferty
174 Pennsylvania Avenue #3
Westminster, MD 21157
Susan Lynn McCafferty
1915 Princeton Avenue
Camp Hill, PA 17011
2. Name and address of Defendant(s) in the Judgment, if
different from that listed in (1) above:
SAME
3. Name and address of every judgment creditor whose judgment
appears of record on the real property to be sold:
4. Name and address of last recorded holder of every mortgage
of record:
PLAINTIFF HEREIN
(AND ANY OTHERS AS NOTED BELOW):
U.S. Department of
Housing & Urban Development of Washington, D.C.
451 7th Street - Southwest
Washington, D.C. 20410
U. S. Department of
Housing & Urban Development
Albany Office, Region II
52 Corporate Circle
Albany, New York 12203-5121
5. Name and address of every other person who has any record
lien on the property:
UNKNOWN
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:
UNKNOWN
7. Name and address of every other person of whom the
Plaintiff has knowledge who has any interest in the property which
may be affected by the sale:
TENANTS IF ANY ...
DOMESTIC RELATIONS OFFICE
CUMBERLAND COUNTY COURTHOUSE
HIGH AND HANOVER STREETS
CARLISLE PA 17013
(In the preceding information, where addresses could not be
reasonably ascertained, the same is indicated.)
I verify that the statements made in this Affidavit are true
and correct to the best of my personal knowledge, information and
belief. I understand that false statements herein are made subject
to the penalties of 18 PA C.S. Section 4904 relati to unsworn
falsification to authorities.
Leon P. Haller PA I.D. #15700
Purcell, Krug & Haller
1719 North Front Street
Harrisburg, PA 17102
(717) 234-4178
DATE: June 12, 2000
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COLUMBIA NATIONAL INCORPORATED, IN THE COURT OF COMMON PLEAS
PLAINTIFF CUMBERLAND COUNTY, PENNSYLVANIA
VS. CIVIL ACTION - LAW
NO. 1999 04558
SUSAN LYNN McCAFFERTY,
DEFENDANT IN MORTGAGE FORECLOSURE
NOTICE OF SHERIFF'S SALE OF REAL ESTATE
PURSUANT TO
PENNSYLVANIA RULE OF CIVIL PROCEDURE 3129
TAKE NOTICE:
held: the Sheriff's Sale of Real Property (real estate) will be
DATE: WEDNESDAY, September 6, 2000
TIME: 10:00 O'clock A.M.
LOCATION: Commissioner's Hearing Room
2nd Floor
Cumberland County Courthouse
Carlisle, Pennsylvania 17013
THE PROPERTY TO BE SOLD is delineated in detail in a legal
description mainly consisting of a statement of the measured
boundaries of the property, together with a brief mention of the
buildings and any other major improvements erected on the land.
(SEE DESCRIPTION ATTACHED)
THE LOCATION of your property to be sold is:
1915 Princeton Avenue
Camp Hill
CUMBERLAND COUNTY
PENNSYLVANIA
THE JUDGMENT under or pursuant to which your property is being
sold is docketed in the within Commonwealth and County to:
No. 1999 04558
THE NAME(S) OF THE OWNER(S) OR REPUTED OWNERS of this property
is:
SUSAN LYNN McCAFFERTY
V
A SCHEDULE OF DISTRIBUTION, being a list of the persons and/or
governmental or corporate entities or agencies being entitled to
receive part of the proceeds of the sale received and to be
disbursed by the Sheriff (for example, to banks that hold mortgagee
and municipalities that are owed taxes) will be filed by the
Sheriff of this County thirty (30) days after the sale and
distribution of the proceeds of sale in accordance with this
schedule will, in fact, be made unless someone objects by filing
exceptions to it within ten (10) days of the date it is filed.
Information about the Schedule of Distribution may be obtained
from the Sheriff of the Court of Common Pleas of the within County
at the Courthouse address specified herein.
THIS PAPER IS A NOTICE OF THE TIME AND PLACE OF THE SALE OF
YOUR PROPERTY.
IT HAS BEEN ISSUED BECAUSE THERE IS A JUDGMENT AGAINST YOV
IT MAY CAUSE YOUR PROPERTY TO BE HELD TO BE SOLD OR TAKEN TO
PAY THE JUDGMENT.
You may have legal rights to prevent your property from being
taken away. A lawyer can advise you more specifically of these
rights. If you wish to exercise your rights, YOU MUST ACT
PROMPTLY.
YOU SHOULD TAKE THIS PAPER TO YOUR LAWYER AT ONCE. GO TO OR
TELEPHONE THE OFFICE SET FORTH BELOW TO FIND OUT WHERE YOU CAN GET
FREE LEGAL ADVICE:
Cumberland County Bar Association
2 Liberty Avenue
Carlisle, Pennsylvania 17013
717-249-3166
Legal Services, Inc.
8 Irvine Row
Carlisle, PA 17013
717-243-9400
THE LEGAL RIGHTS YOU MAY HAVE ARE:
1. You may file a petition with the Court of Common Pleas of
the within County to open the judgment if you have a meritorious
defense against the person or company that has entered judgment
against you. You may also file an petition with the same Court if
you are aware of a legal defect in the obligation or the procedure
used against you.
2. After the Sheriff's Sale you may file a petition with the
Court of Common Pleas of the within County to set aside the sale
for a grossly inadequate price or for other proper cause. This
W
petition MUST BE FILED BEFORE THE SHERIFF'S DEED IS DELIVERED.
3. A petition or petitions raising the legal issues or rights
mentioned in the preceding paragraphs must be presented to the
Court of Common Pleas of the within County. The petition must be
served on the attorney for the creditor or on the creditor before
presentation to the court and a proposed order or rule must be
attached to the petition.
If a specific return date is desired, such date must be
obtained from the Court Administrator's Office - Civil Division, of
the within County Courthouse, before a presentation of the petition
to the Court.
A copy of the writ of Execution is attached hereto.
PURCELL, KRUG & HALLER
Attorneys for Plaintiff
1719 North Front Street
Harrisburg, PA 17102
(717) 234-4178
r
LEGAL DESCRIPTION
ALL THAT CERTAIN lot or tract of land situate in the Borough
of Camp Hill, Cumberland County, Pennsylvania, in accordance with
a survey by Gerrit J. Betz, Registered, Surveyor, dated August 31,
1972, and being more particularly bounded and described as follows,
to wit:
BEGINNING at a hub on the southern line of Princeton Avenue,
said point being 452.46 feet from the southwest corner of Princeton
Avenue and 19th Street measured Ln a westerly direction; thence
South 30 degrees 17 minutes East 120 feet along the dividing line
between Lots 7 and 8 on the hereinafter mentioned Plan of Lots to
a point; thence extending South 59 degrees 43 minutes West 60 feet
to a hub; thence extending North 30 degrees 17 minutes West 120
feet along the dividing line between Lots 8 and 9 on the
heretnaf*er mentioned Plan of Lots?to a hub on the southern line of
Princeton Avenue; thence by said line North 59 degrees 43 minutes
East 60 feet to a point, the place'of BEGINNING.
HAVING ERECTED THEREONf a two story brick dwelling house known as
1915 Princeton Avenue, Camp Hill, PA.
BEING THE SAME PREMISES WHICH Thomas J. D'Annunzio, III and Susan
W. D'Annunzio by deed dated 1/4/94 and recorded in Cumberland
County Deed Book 5-26 Page 1176 granted and conveyed unto Susan
Lynn McCafferty.
TO BE SOLD AS THE PROPERTY OF SUSAN LYNN MCCAFFERTY ON JUDGMENT NO.
1999 04558.
TAX PARCEL: 01-22-0536-328
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COLUMBIA NATIONAL INCORPORATED, IN THE COURT OF COMMON PLEAS
PLAINTIFF CUMBERLAND COUNTY, PENNSYLVANIA
vs. CIVIL ACTION - LAW
SUSAN LYNN MCCAFFERTY, NO. 1999 04558
DEFENDANT IN MORTGAGE FORECLOSURE
RETURN OF SERVICE
I hereby certify that I hav, d sited in the U.S. Mails at
Harrisburg, Pennsylvania on a true and correct
copy of the Notice of Sale of Real Estate pursuant to PA R.C.P.
3129.1 to the Defendants herein and all lienholders of record by
regular first class mail (Certificate of Mailing form in compliance
with U.S. Postal Form 3817 is attached hereto as evidence), and
also to the Defendants by Certified Mail, which mailing receipts
are attached. Service addresses are as follows:
Susan Lynn McCafferty
174 Pennsylvania Avenue #3
Westminster, MD 21157
Susan Lynn McCafferty
1915 Princeton Avenue
Camp Hill, PA 17011
U.S. Department of
Housing & Urban Development
451 7th Street - Southwest
Washington, D.C. 20410
of Washington, D.C.
U. S. Department of
Housing & Urban Development
Albany Office, Region II
52 Corporate Circle
Albany, New York 12203-5121
Domestic Relations Office
Cumberland County Courthouse
Hanover & High Streets
Carlisle, PA 17013
By
PURCELL, KRUG & HALLER
Attorneys for Plaintiff
1719 North Front Street
Harrisburg, PA 17102
(717) 234-4178
LAW OFFICES
PURCELL, KRUG AND HALLER
1719 NORTH FRONT STREET
HARRISBURG, PENNSYLVANIA 17102-2392
JOHN W. K)RC1:L1. TELEPHONE (717) 2344178
HOWARD H. KRUO FORECLOSURE DEPT. FAX (717) 234.1206
LEON 1'. IIALI.Ht
JOHN W. 11IIt('ELI..IR.
13RIAN J. 'I 'Y1-FR
111.1. M. WINRKA
(21]15330838
NOTICE TO:
Susan Lynn McCafferty
174 Pennsylvania Avenue H3
Westminster, MD 21157
Susan Lynn McCafferty
1915 Princeton Avenue
Camp Hill, PA 17011
U.S. Department of
Housing & Urban Development of Washington, D.C.
451 7th Street - Southwest
Washington, D.C. 20410
U. S. Department of
Housing & Urban Development
Albany Office, Region II
52 Corporate Circle
Albany, New York 12203-5121
Domestic Relations Office
Cumberland County Courthouse
Hanover & High Streets
Carlisle, PA 17013
JOSEPH NISSLEY 119104982)
ANTHONY DISANTO
OF COUNSEL
HERSHEY
1099 GOVERNOR ROAD
NOTICE IS HEREBY GIVEN to the Defendants in the within action and
those parties who hold one or more mortgages, judgments or tax liens
against the real estate which is the subject of the Notice of Sale
pursuant to Pennsylvania Rule of Civil Procedure 3129.1 attached
hereto.
YOU ARE HEREBY NOTIFIED that by virtue of a Writ of Execution
issued out of the Court of Common Pleas of the within county on the
judgment of the Plaintiff named herein the said real estate will be
exposed to public sale as set forth on the attached Notice of Sale.
YOU ARE FURTHER NOTIFIED that the lien you hold against the said
real estate will be divested by the sale and at you have an
opportunity to protect your interest, if ,? being notified of
said Sheriff's Sale.
By:
Leon P. Haller PA I.D.15700
Attorney for Plaintiff
COLUMBIA NATIONAL INCORPORATED, c IN THE COURT OF COMMON PLEAS
PLAINTIFF CUMBERLAND COUNTY, PENNSYLVANIA
VS. CIVIL ACTION - LAW
NO. 1999 04558
SUSAN LYNN McCAFFERTY,
DEFENDANT IN MORTGAGE FORECLOSURE
NOTICE OF SHERIFF'S SALE OF REAL ESTATE
PURSUANT TO
PENNSYLVANIA RULE OF CIVIL PROCEDURE 3129
TAKE NOTICE:
That the Sheriff's Sale of Real Property (real estate) will be
held:
DATE: WEDNESDAY, September 6, 2000
TIME: 10:00 O'clock A.M.
LOCATION: Commissioner's Hearing Room
2nd Floor
Cumberland County Courthouse
Carlisle, Pennsylvania 17013
THE PROPERTY TO HE SOLD is delineated in detail in a legal
description mainly consisting of a statement of the measured
boundaries of the property, together with a brief mention of the
buildings and any other major improvements erected on the land.
(SEE DESCRIPTION ATTACHED)
THE LOCATION of your property to be sold is:
1915 Princeton Avenue
Camp Hill
CUMBERLAND COUNTY
PENNSYLVANIA
THE JUDGMENT under or pursuant to which your property is being
sold is docketed in the within Commonwealth and County to:
No. 1999 04558
THE NAME (S) OF THE OWNER (S) OR REPUTED OWNERS of this property
is:
SUSAN LYNN McCAFFERTY
A SCHEDULE OF DISTRIBUTION, being a list of the persons and/or
governmental or corporate entities or agencies being entitled to
receive part of the proceeds of the sale received and to be
disbursed by the Sheriff (for example, to banks that hold mortgages
and municipalities that are owed taxes) will be filed by the
Sheriff of this County thirty (30) days after the sale and
distribution of the proceeds of sale in accordance with this
schedule will, in fact, be made unless someone objects by filing
exceptions to it within ten (10) days of the date it is filed.
Information about the Schedule of Distribution may be obtained
from the Sheriff of the Court of Common Pleas of the within County
at the Courthouse address specified herein.
THIS PAPER IS A NOTICE OF THE TIME AND PLACE OF THE SALE OF
YOUR PROPERTY.
IT HAS BEEN ISSUED BECAUSE THERE IS A JUDGMENT AGAINST YOU.
IT MAY CAUSE YOUR PROPERTY TO BE HELD TO BE SOLD OR TAKEN TO
PAY THE JUDGMENT.
You may have legal rights to prevent your property from being
taken away. A lawyer can advise you more specifically of these
rights. If you wish to exercise your rights, YOU MUST ACT
PROMPTLY.
YOU SHOULD TAKE THIS PAPER TO YOUR LAWYER AT ONCE. GO TO OR
TELEPHONE THE OFFICE SET FORTH BELOW TO FIND OUT WHERE YOU CAN GET
FREE LEGAL ADVICE:
Cumberland County Bar Association
2 Liberty Avenue
Carlisle, Pennsylvania 17013
71.7-249-3166
Legal Services, Inc.
9 Irvine Row
Carlisle, PA 17013
717-243-9400
THE LEGAL RIGHTS YOU MAY HAVE ARE:
1. You may file a petition with the Court of Common Pleas of
the within County to open the judgment if you have a meritorious
defense against the person or company that has entered judgment
against you. You may also file an petition with the same Court if
you are aware of a legal defect in the obligation or the procedure
used against you.
2. After the Sheriff's Sale you may file a petition with the
Court of Common Pleas of the within County to set aside the sale
for a grossly inadequate price or for other proper cause. This
petition MUST BE FILED BEFORE THE SHERIFF'S DEED IS DELIVERED.
3. A petition or petitions raising the legal issues or rights
mentioned in the preceding paragraphs must be presented to the
Court of Common Pleas of the within County. The petition must be
served on the attorney for the creditor or on the creditor before
presentation to the court and a proposed order or rule must be
attached to the petition.
If a specific return date is desired, such date must be
obtained from the Court Administrator's Office - Civil Division, of
the within County Courthouse, before a presentation of the petition
to the Court.
A copy of the Writ of Execution is attached hereto.
PURCELL, KRUG & HALLER
Attorneys for Plaintiff
1719 North Front Street
Harrisburg, PA 17102
(717) 234-4176
LEGAL DESCRIPTION
ALL THAT CERTAIN lot or tract of land situate in the Borough
of Camp Hill, Cumberland County, Pennsylvania, in accordance with
a survey by Gerrit J. Betz, Registered Surveyor, dated August 31,
1972, and being more particularly bounded and described as follows,
to wit:
BEGINNING at a hub on the southern line of Princeton Avenue,
said point being 452.46 feet from the southwest corner of Princeton
Avenue and 19th Street measured in a westerly direction; thence
South 30 degrees 17 minutes East 120 feet along the dividing line
between Lots 7 and 8 on the hereinafter mentioned Plan of Lots to
a point; thence extending South 59 degrees 43 minutes West 60 feet
to a hub; thence extending North 30 degrees 17 minutes West 120
feet along the dividing line between Lots B and 9 on the
hereinafter mentioned Plan of Lot to a hub on the southern line of
Princeton Avenue; thence by said line North 59 degrees 43 minutes
East 60 feet to a point, the place'of BEGINNING.
HAVING ERECTED THEREONf a two story brick dwelling house known as
1915 Princeton Avenue, Camp Hill, PA.
BEING THE SAME PREMISES WHICH Thomas J. D'Annunzio, III and Susan
W. D'Annunzio by deed dated 1/4/94 and recorded in Cumberland
County Deed Book 5-26 Page 1176 granted and conveyed unto Susan
Lynn McCafferty.
TO BE SOLD AS THE PROPERTY OF SUSAN LYNN MCCAFFERTY ON JUDGMENT NO
1999 04558.
TAX PARCEL: 01-22-0536-326
COURT OF COMMON PLEAS OF CUMBERLAND COUNTY
9TH JUDICIAL DISTRICT
COMMONWEALTH OF PENNSYLVANIA
AFFIDAVIT OF SERVICE OF PROCESS
COLUMBIA NATIONAL INCORPORATED NO. 1999.04558
Plaintiff
CIVIL ACTION - LAW
venue IN MORTGAGE FORECLOSURE
SUSAN LYNN MCCAFFERTY
Ddendant
Know all persons by these presents that I, J-,oh?I III I , was assigned to duly
execute this service upon the following defendant: SUSAN LYNN M CAFFERTY at 174
PENNSYLVANIA AVENUE #3 WESTMINSTER MD 21157. 1 hereby depose and say:
1) That I am of the necessary age and sound mind to execute said service.
2) That I am not a party to the action or have any interest in it.
3) That I am an agent of Eric J. Kerchner, a Monroe County, Pennsylvania licensed private
investigator.
1 hereby certify that on a Z6 Z???at approximately S Z ?a.m. ?!p.m. a true and correct
copy of the NOTICE OF S EH RIFFS SALE were served on the above-named party or witness in
the following manner:
M I personally delivered them into the hands of the person to be served.
? By leaving a copy at his/her usual place of abode with whose
relationship to the defendant is and who is of suitable age and discretion
and also residing therein.
? By leaving a copy with the manager/clerk of place of lodging in which
defendant resides.
? By leaving a copy with the agent in charge of defendant's office or
usual place of business. Job title or position of agent is
? After due and diligent efforts, described below, I was unable to serve the process
Description of Recipient: ? NO
11 ?
Sex: W Race: I- Approximate Height: _ Approximate Weight: _ Approximate Age; '30
FURTHER AFFIDAVIT SAYTH NOT.
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Signature=of rocess Serve
Subscrib d and sworn to before me this
ay 7
d ?G a 2000.
Noflxi?Public
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SUSAN LYNN MCCAFFERTY
° 1915 PRINCETON AVENUE
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SUSAN LYNN MCCAFFFRTY
° 174 PENNSYLVANIA AVENUE #3 '.........
`ry 5 WESTMINSTER MD 21157 .
JAN 0 4 2000
COLUMBIA NATIONAL INCORPORATED, IN THE COURT OF COMMON PLEAS
Plaintiff CUMBERLAND COUNTY,PENNSYLVANIA
VS. CIVIL ACTION - LAW
NO. 99 4558 CIVIL TERM
SUSAN LYNN MCCAFFERTY,
Defendant IN MORTGAGE FORECLOSURE
ORDER FOR SERVICE
AND NOW, to wit, this 16+h day of ,? O, upon
consideration of the within Motion, it a pearing that a good faith
investigation and effort to locate the Defendant, Susan Lynn
McCafferty, has been made by Plaintiff, it is hereby
ORDERED that service of the Complaint be made by posting a copy
of the original Complaint on the most public part of the property
located at 1915 Princeton Avenue, Camp Hill, PA 17011, and by
forwarding a copy of the Complaint by certified mail and ordinary
mail (service to be completed upon mailing) to Defendant, Susan Lynn
McCafferty, at her last known address located at 174 Pennsylvania
Avenue, #3, Westminster, MD 21157, and by publication pursuant to
Rule 430(b); AND FURTHER, that in the event this case should be
reduced to judgment and execution shall be issued, service upon the
Defendant pursuant to Rule 3129.2(c) (1) (C) shall be effected by
mailing copies of the required notices to the Defendant at her last
known address by certified mail and ordinary mail (service to be
completed upon mailing) and by posting a copy of the Notice of Sale
or Sheriff's handbill on the most public part of the premises and by
publication by Sheriff pursuant to Pennsylvania Rule of Civil
Procedure 3129.2(d).
BY THE COURT
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wt;tnn;'•,!icr: a;tyhard
acd the sya! of sdiu Court yf?Carli le, Pa.
ihi 4A112 f )U ?a
Pry' n+h?.?_/
Re: Columbia Nat'l vs. McCafferty
Cumberland County Sale 9/6/00
Received from:
Purcell, Krug & Haller Postage:
1719 North Front Street
Harrisburg, PA 17102
One piece of ordinary mail addressed to: Postmark:
Susan Lynn McCafferty
174 Pennsylvania Avenue #3
Westminster, MD 21157
U. S. POSTAL SERVICE
CERTIFICATE OF MAILING
(In compliance with Postal Service Form 3877)
Received from:
Purcell, Krug & Haller Postage:
1719 North Front Street
Harrisburg, PA 17102
One piece of ordinary mail addressed to: Postmark:
Susan Lynn McCafferty
1915 Princeton Avenue
Camp Hill, PA 17011
U. S. POSTAL SERVICE
CERTIFICATE OF MAILING
(In compliance with Postal Service Form 3877)
Received from:
Purcell, Krug & Haller Postage:
1719 North Front Street
Harrisburg, PA 17102
One piece of ordinary mail addressed to: Postm
H \"
U.S. Department of
Housing & Urban Development of Washington, D.C. /
451 7th Street - Southwest $
Washington, D.C. 20410 r
is
Received from:
Purcell, Krug & Haller Postage:
1719 North Front Street
Harrisburg, PA 17102
One piece of ordinary mail addressed to: Postmark:
U. S. Department of
Housing & Urban Development
Albany Office, Region II
52 Corporate Circle
Albany, New York 12203-5121
Received from:
Purcell, Krug & Haller Postage:
1719 North Front Street
Harrisburg, PA 17102
One piece of ordinary mail addressed to: Postmark:
Domestic Relations Office
Cumberland County Courthouse
Hanover & High Streets
Carlisle, PA 17013
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COLUMBIA NATIONAL, IN THE COURT OF COMMON PLEAS
INCORPORATED CUMBERLAND COUNTY, PENNSYLVANIA
Plaintiff
Vs. CIVIL ACTION - LAW -
No. 99 4558
SUSAN LYNN MCCAFFERTY
Defendant IN MORTGAGE FORECLOSURE
PROOF OF PUBLICATION
PURCELL, KRUG & HALLER
,Leon P. -Fuller, Esquire
1719 North Front Street
Harrisburg, PA. 17102
(717) 234-4178
Attorney ID # 15700
Attorney for Plaintiff
PROOF OF OU13LICATION
State of Pennsylvania,
County of Cumberland.
Sherry Clifford, Classified Advertising Manager
of THE SENTINEL,
of the County and State aforesaid, being duly sworn, deposes and says that T
HE SENTINEL, a newspaper of
general circulation in the Borough of Carlisle, County and State aforesaid, was established December 13th,
1881, since which date THE SENTINEL has been regularly Issued in said County, and that the printed notice
or publication attached hereto is exactly the same as was printed and published in the regular editions and
Issues of THE SENTINEL on the following dates, viz
January 29, 2000
further deposes that he is not interested in
Iject matter of the aforesaid notice or
sement, and that all allegations in the
ng statement as to time, place and character
!cation are true.
Febr 1, 2000
FICESEEr""'n to and subscribed before me this 1st
.AN GET: f February ,2000
Notary Public
y
717,2U-4178
: %)mmission expires:
NOTARIAI. SEAL
SHIRLEY 0. DURNIFI. ry P;,p,lic
Carlisle Bnro., Cum!mn^-;i Coun'y
MY Ccr:. r,iss:nn Erc!?? nut D. 2(r)3
01: P%Mulc ?i-N
of
\Nei., ev+spoper o\
ennsylvania,
?t ?urnberiand' otTNeENt\NE?Qe ember tali e
ogee and sale Was as bush 0e printed and
pdvetl n(J Mana9er dap stores,, regular
lion SO 1% M9 duly sworn, to
uad M said county' in 08 a edi
t nd state
NOrd rasa\d, pub\iaha
Metal a n%ad and
GC1?
?iassiiied h 0 ri\s\e, sotoljo 11. hag been
e a
r+tY'a ont+% to Ne seV, acw the a" , via
d?a?d ?ret° to to\iowing dates,
th
Yi p?.. :4L- 1
?-w. , ?anuarY ? '
not interested in
deposes that Tesaid notice or
q? p{fianUblect Matte, d t„at a0 aiiegat+ace and character
173
' ' the s isement, an erlt as to time: p
for 9°in` t area a true
Ot pubii
9 ?. 2000
? ? ?' ?YA?. ? Febr Y `
R P ethis 1s/
_ ------'' beforem
to and subscribed 2000
SWOrn Februa - ?? public
Notary
,? day of
expires'
MY c'00'ssion
N!"ll 'PtAt.Stp? y?utK
SN\P1EY ?t??i i? ed,w 13
CaTV EY, EY1F:
MY
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NM DGI[DA7 GGI[DID CGI(DlD'[G?[D
pI PNOf OO ?IJJM b03131Y16'tly
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IN THE COURT OF COMMON PLEAS
CUMBERLAND COUNTY, PENNSYLVANIA
CIVIL ACTION - LAW -
No. 99 4558
IN MORTGAGE FORECLOSURE
PROOF OF PUBLICATION
PURCELL, KRUG & HALLER
Leon P. Haller, Esquire
1719 North Front Street
Harrisburg, PA. 17102
(717) 234-4178
Attorney ID # 15700
Attorney for Plaintiff
COLUMBIA NATIONAL,
INCORPORATED
Plaintiff
VS.
SUSAN LYNN MCCAFFERTY
Defendant
PROOF OF PUBLICATION OF NOTICE
IN CUMBERLAND LAW JOURNAL
(Under Act No. 587, approved May 16, 1929), P. L.I784
STATE OF PENNSYLVANIA :
COUNTY OF CUMBERLAND :
Ss.
Roger M. Morgenthal, Esquire, Editor of the Cumberland Law Journal, of the County
and State aforesaid, being duly 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,
FEBRUARY 4, 2000
Affiant further deposes that he is authorized to verify this statement by the Cumberland
Law Journal, a legal periodical of general circulation, and that he is not interested in the subject
matter of the aforesaid notice or advertisement, and that all allegations in the foregoing
statements as to time, place and character of publication are
Roger M. Morgenthal, Editor
SWORN TO AND SUBSCRIBED before me this
4 day of FEBRUARY, 2000
NOTARIAL SEAL
L045 E. SNYDER, Notary Publk
CadW, (ICro, Cumberlond County, PA
My Comnw;w "Expire Moah S, 2001
.44e
NOTICE OF ACTION IN
MORTGAGE FORECLOSURE
In the Court of Common Pleas of
Cumberland County, PA
Civil Acton-Law
No. 99 4558 Civil Term
COLUMBIA NATIONAL.
INCORPORATED
PLAINTIFF
v5.
SUSAN LYNN McCAFFERTY
DEFENDANT
MORTGAGE FORECLOSURE
TO: SUSAN LYNN McCAFFERTY:
You are hereby notified that on
July 27, 1999, Plaintiff. COLUMBIA
NATIONAL. INCORPORATED, filed a
Mortgage Foreclosure Complaint en.
dorsed with a Notice to Defend
against you in the Court of Common
Pleas of Cumberland County, Penn-
sylvania, docketed to No. 99 4558
CIVIL TERM wherein Plaintiff seeks
to foreclose its mortgage securing
your property located at 1915
PRINCETON AVENUE, CAMP HILL.
PA 17011 whereupon your property
would be sold by the Sheriff of Cum-
berland County.
You are hereby notified to plead to
the above referenced Complaint on or
before 20 DAYS from the date of this
publication or a Judgment will be
entered against you.
NOTICE
You have been sued in Court. If
you wish to defend, you must enter a
written appearance personally or by
attorney, and file your defenses or
objections In writing with the Court.
You are warned that if you fall to do
so, the case may proceed without you
and a Judgment may be entered
against you without further notice for
the relief requested by the Plaintiff.
You may lose money or property or
other rights important to you.
YOU SHOULD TAKE THIS NO-
TICE TO YOUR LAWYER AT ONCE.
IFYOU DO NOT HAVEA IAWYEROR
CANNOT AFFORD ONE, GO TO OR
TELEPHONE THE OFFICE SET
FORTH BELOW TO FIND OUT
WHERE YOU CAN GET LEGAL HELP.
Lawyer Referral Service
Court Administrator
Cumberland County Courthouse
Fourth Floor
Carlisle. PA 17013
(7171240-6200
LEON P. HALLER. ESQUIRE
1719 North Front Street
Harrisburg. PA 17102
(717) 234-4178
Feb. 4
Cumbertaud Notices
8 w
a
s
MM'KIN•ApGGILG•?G CGIL9.1B iG1t5
ON 3610) 0'j AlNl15 M1G31 ]LV15'l1V
STATE OF PENNSYLVANIA,
COUNTY OF CUMBERLAND Ss.
llobert P Ziegler
f------------------------------------------------------------------------------- Recorder of
Deeds in and for said County and State do hereby certify that the Sheriffs Deed in which ----------------
Secretary of Housing & Urban DEvelopme.nt of Washington
---------------------------•-------------------------------------------------------- is the grantee
the same having been sold to said grantee on the __ 6th ----------------------------------------- day of
September 2000
______________________________ A. D., under and by virtue of a writ______________
Execution 13th
----------- issued on the
June xx2000
day of __________________________ A. D., out of the Court of Common Pleas of said County as of
---------------------- civil-., -------------------------------------------------- Term, 19 --- 99
4558 Columbia. Na.tl Inc
Number --------------- atthe suit of ---------------------------------------------------------------
-°-------------------------------- against--- Susan ------------ Lynn McCafferty
-------------------------------------
duly recorded in Sheriffs Deed Book No. 235 -- Page 1103 ------
IN TESTIMONY WHEREOF, I have hereunto
set my hand and seal) of said office this day
of -L " ----------- A.
Recorder of Deeds
Recorder N nook &ffk"bWC?a?, hRk IM
IlpCome" tomw1:1Maalt/ilhalllf
Columbia National Incorporated
-vs-
Susan Lynn McCafferty
In the Court of Common Pleas of
Cumberland County, Pennsylvania
No. 1999-4558 Civil
Shannon M. Sunday, Deputy Sheriff, who being duly sworn according to law, says on
July 11, 2000 at 1:45 o'clock P.M. EDST, she posted a copy of Real Estate Writ Notice
Poster and Description on the property of Susan Lynn McCafferty located at 1915
Princeton Avenue, Camp Hill, Cumberland County, Pennsylvania according to law,
R. Thomas Kline, Sheriff, who being duly sworn according to law, says he served the
above Real Estate Writ Notice Poster and Description in the following manner: The
Sheriff mailed a notice of the pendency of the action to Susan Lynn McCafferty by
Certified Mail Return Receipt Requested, Restricted Delivery, Deliver To Addressee
Only to 174 Pennsylvania Avenue, Westminster, Maryland. This letter was mailed under
the date of July 27, 2000 and received by Susan L. McCafferty on August 9, 2000 the
return receipt card signed by Susan McCafferty.
R. Thomas Kline, Sheriff, who being duly sworn according to law, says he served the
above Real Estate Writ Notice Poster and Description in the following manner: The
Sheriff mailed a notice of the pendency of the action to the defendant to wit: Susan Lynn
McCafferty to 1915 Princeton Avenue, Camp Hill, Pennsylvania. This letter was mailed
under the date of August 7, 2000 and never returned to the Sheriffs Office.
r. Thomas Kline, Sheriff, who being duly sworn according to law, says that after due
and legal notice hand been given according to law, exposed the above described premises
at public venue or outcry at Court House, Carlisle, Cumberland County, Pennsylvanian
on September 6, 2000 at 10:00 o'clock A.M.EDST, and sold the same for the sum of $
1.00 to Attorney Leon P. Haller for The Secretary of Housing and Urban Development of
Washington D.C., his successors and/or assigns. It being the highest bid and best price
quoted for the same The Secretary of Housing and Urban Development, of Washington
D.C., his successors and/or assigns of One Sentry Place. 475 Sentry Parkway, suite 5000,
Blue Bell, Pa being the buyer in this execution paid to Sheriff R. Thomas Kline the sum
of $ 825.19 it being costs.
Sheriffs Costs:
Docketing 30.00
Poundage 16.16
Posting Bills 15.00
Advertising 15.00
Acknowledging Deed 30.00
Auctioneer 10.00
Law Library .50
County 1.00
Mileage 18,60
Certified Mail 9.24
Levy 15.00
Surcharge 20.00
Law Journal 307.25
Patriot News
Share of Bills
Distribution of Proceeds
Sheriff s Deed
Sworn and Subscribed To Before Me
This /9 ? Day of 2000, A.D,Q. 7x?ll?? nPa
Pro otary
261.41
23.53
25.00
27.50
$825.19 Pd By Atty
9/22/00
So Answe s.,
r
R. Thomas Kline, Sheriff
By AL:,, g,&-
Real Estate Deputy
COY
93
)0'
THE PATRIOT NEWS
THE SUNDAY PATRIOT NEWS
Proof of Publication
JnderBct No. 587. Rnorod Mau 16, 1929
Commonwealth of Pennsylvania, County of Dauphin) as
James L. Clark being duly sworn according to law, deposes and says:
That he is the Accounts Receivables Manager 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 1st, 8th and 15th day(s) of
August 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 and pursuant to a resolution unanimously passed and
adopted severally by the stockholders and board of directors of the said Company and subsequently duly recorded in
the office for the Recording of Deeds in and for said County of Dauphin in Misc)I aneous Book "M",
Volume 14, Page 317.
PUBLICATION ------------------ ----1-------------------------
COPY Sworn to and subscribed before m is 30th ofAug t 2000 A.D.
S A L E 848 Notamal Seal
17L Russell, Notary P lid
Hardabury, Dauphin County NOTARY PUBLIC
My Commission Eaplree June S. 2002
A1E Aft ission expires June 6, 2002
1 Manlber, PennsywarNa association o Notarles
y¢owmWewkw' j CUMBERLAND COUNTY SHERIFFS OFFICE
x nl-''l? CUMBERLAND COUNTY COURTHOUSE
IS
EBCRI
k CARLISLE, PA. 17013
r
.
O
AT.L•TN¢T?CERTAIN lot 6r iract of land
Statement of Advertising Costs
siiuaid '?bo
Borough Of Camp Hilo
Cumber W- County, IAms}hania,`.in
To THE PATRIOT-NEWS CO., Dr.
aunjda I h itsuny by Gemt J Betz,
Regis
tere
d
;
or
doted
e
Apgust For publishing the notice or publication attached
and
.in
ore paN
acula
bounded bounded and
and
be
m
g?:
dy
hereto on the above stated dates $ 259.91
,
descdbicinfollons,loxib.. .- Probating same Notary Fee(s) $ 1.50
`,BEGINNING at'a kub'on the smiithem
%mi, of PrimeiooA%vnue;'safd.'polot :being Total $ 261.41
15216 feet'" the soulWest comer of
PrIkilonAinueand19th51reeimekutidin
i wesierly'cRection, thonce;South 30 degrees isher's Receipt for Advertising cost
17 minotesEast I20feefatgngthedhidingline :her of THE PATRIOT-NEWS and THE SUNDAY PATRIOT-NEWS, newspapers of general
>ttN hAots-land eron the hereinafter
nesdoined.. Plan of Lob fo a point thence receipt of the aforesaid notice and publication costs and certifies that the same have
rstending South 59 degrees 43 minutes %Vol THE PATRIOT-NEWS CO.
e feei,to a'hub; thence extending North 30
kgyees 17 minutes 4Vesf 110. feet along-the
'
?
By
llne
h%
en Lois B and 9 on. the
lividing
...........................................••.......................
Mrelufter mentioned flan of Lots to a hub on
HAVL ERECTED thereon a two stop
! brick dxelli house known as 1915 Princeton
Aronug Cam Hill; PA.
BEING.. E SAME premises xhich
Thomas J: Annunzio, Ill and Susan' 1V.
D'Anounzio by deed dated 1/4194, and
PROOF OF PUBLICATION OF NOTICE
IN CUMBERLAND LAW JOURNAL
(Under Act No. 587, approved May 16, 1929), P. L.1784
STATE OF PENNSYLVANIA :
COUNTY OF CUMBERLAND SS.
Roger M. Morgenthal, Esquire, Editor of the Cumberland Law Journal, of the County
and State aforesaid, being duly sworn, according to law, deposes and says that the Cumberland
Law Journal, a legal periodical published in the Borough of Carlisle in the County and State
aforesaid, was established January 2, 1952, and designated by the local courts as the official legal
periodical for the publication of all legal notices, and has, since January 2, 1952, been regularly
issued weekly in the said County, and that the printed notice or publication attached hereto is
exactly the same as was printed in the regular editions and issues of the said Cumberland Law
Journal on the following dates.
Affbant 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 EB?ATE BALE No. 48
No. 1999.4558 Civil
Columbia National Incorporated
VS.
Susan Lynn McCafferty
Atty.: Leon P. Haller
LEGAL DESCRIPTION
ALL THAT CERTAIN lot or tract of
land situate in the Borough of Camp
Hill, Cumberland County. Pennsyl-
vania. in accordance with a survey by
Gerrit J. Betz, Registered Surveyor,
dated Augusl3l. 1972. and being more
particularly bounded and described
as follows, to wit:
BEGINNING at a hub on the south-
em line of Princeton Avenue, said
point being 452.46 feet from the
southwest corner of Princeton Ave-
nue and 19th Street measured in a
westerly direction; thence South 30
degrees 17 minutes East 120 feet
along the dividing line between Lots
7 and 8 on the hereinafter mentioned
Plan Of Lots to a point; thence extend
Ing South 59 degrees 43 minutes
West 60 feet to a hub: thence "tend-
ing North 30 degrees 17 rmnutes
West 120 feet along the dividing line
between Lots 8 and 9 on the Iterem-
after mentioned Plan of Lots. to a hub
on the southern line of Princeton Am
nue; thence by said line North 59
degrees 43 minutes East 60 feet to a
point, the place of BEGINNING.
HAVING ERECTED THEREON a
two story brick dwelling house known
as 1915 Princeton Avenue. Croup Hill.
PA.
BEING THE SAME PREMISES
WHICH Thomas J. D'Annunzlo, III
and Susan W. D'Annumlo by deed
dated 1/4/94 and recorded in Cum-
berland County Deed Book S-26
Rog 6r M. Morgenthal, Editor
SWORN TO AND SUBSCRIBED before me this
II dayof_ AUGUST. 2000
LOIS E. SNYDElt, Notary Pubk
Corli* Iloro. Cumharland County, PA
My commiwon Eapirtts Morch 3. 2WI
PROOF OF PUBLICATION OF NOTICE
IN CUMBERLAND LAW JOURNAL
(Under Act No. 587, approved May 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.
Affiant further deposes that he is authorized to verify this statement by the Cumberland
Law Journal, a legal periodical of general circulation, and that he is not interested in the subject
matter of the aforesaid notice or advertisement, and that all allegations in the foregoing
statements as to time, place and character of publication are true.
REAL ESTATE BALE NO. 48
No. 1999-4558 Civil
Columbia National Incorporated
VS.
Susan Lynn McCafferty
Atty.: Leon P. Haller
LEGAL DESCRIPTION
ALL THAT CERTAIN lot or tract of
land situate in the Borough of Camp
Hill. Cumberland County, Pennsyl-
vania. In accordance with a survey by
Gerrit J. Betz, Registered Surveyor.
dated August 31. 1972, and being more
particularly bounded and described
as follows, to wit:
BEGINNING at a hub on the south-
ern line of Princeton Avenue, said
point being 452.46 feet from the
southwest corner of Princeton Ave-
nue and 19th Street measured in a
westerly direction; thence South 30
degrees 17 minutes East 120 feet
along the dividing line between Lots
7 and 8 on the hereinafter mentioned
Plan of Lots to a point: thence extend -
Ing South 59 degrees 43 minutes
West 60 feet to a hub: thence extend-
ing North 30 degrees 17 minutes
West 120 feet along the dividing line
between Lots 8 and 9 on the herein-
after mentioned Plan of Lots, to a hub
on the southern line of Princeton Ave-
nue; thence by said line North 59
degrees 43 minutes East 60 feel to a
point, the place of BEGINNING.
HAVING ERECTED THEREON a
two story brick dwelling house known
as 1915 Princeton Avenue, Cmnp Hill,
PA.
BEING THE SAME PREMISES
WHICH Thomas J. D'Annunzio, III
and Susan W. D'Annunzio by decd
dated 1/4/94 and recorded In Cum-
berland County Deed Book S-26
Page 1176 granted and conveyed
unto Susan Lynn McCafferty.
TO BE SOLD AS THE PROPERTY
OF SUSAN LYNN McCAFFERTY ON
JUDGMENT NO. 1999-04558.
Roger PM Morgenthal, Editor
SWORN TO AND SUBSCRIBED before me this
11 day of AUGUST. 2000
NOT aL
LOIS E. SNYDEd, Notary Public
Ca"am, Cumbortand County, PA
My CommiWon Expir /arch 3, 2101
TAX PARCEL: 01.22.0536328.
COLUMBIA NATIONAL INCORPORATED, IN THE COURT OF COMMON PLEAS
PLAINTIFF CUMBERLAND COUNTY, PENNSYLVANIA
vs. CIVIL ACTION - LAW
NO. 1999 04558
SUSAN LYNN McCAFFERTY,
DEFENDANT IN MORTGAGE FORECLOSURE
AFFIDAVIT PURSUANT TO%P.R.C.P. 3129.1
The Plaintiff in the above action, by its attorneys, Purcell,
Krug & Haller, sets forth as of the date the praecipe for the writ
of execution was filed, the following information concerning the
real property located at 1915 Princeton Avenue, Camp Hill, PA
17011:
1. Name and address of the owner (s) or Reputed Owner(s):
Susan Lynn McCafferty
174 Pennsylvania Avenue #3
Westminster, MD 21157
Susan Lynn McCafferty
1915 Princeton Avenue
Camp Hill, PA 17011
2. Name and address of Defendant(s) in the Judgment, if
different from that listed in (1) above:
SAME
3. Name and address of every judgment creditor whose judgment
appears of record on the real property to be sold:
4. Name and address of last recorded holder of every mortgage
of record:
PLAINTIFF HEREIN
(AND ANY OTHERS AS NOTED BELOW):
U.S. Department of
Housing & Urban Development of Washington, D.C.
451 7th Street - Southwest
Washington, D.C. 20410
U. S. Department of
Housing & Urban Development
Albany Office, Region II
52 Corporate Circle
Albany, New York 12203-5121
5. Name and address of every other person who has any record
lien on the property:
UNKNOWN
6. Name and address of every ether person who has any record
interest in the property and whose interest may be affected by the
sale:
UNKNOWN
7. Name and address of every other person of whom the
Plaintiff has knowledge who has any interest in the property which
may be affected by the sale:
TENANTS IF ANY ...
DOMESTIC RELATIONS OFFICE
CUMBERLAND COUNTY COURTHOUSE
HIGH AND HANOVER STREETS
CARLISLE PA 17013
(In the preceding information, where addresses could not be
reasonably ascertained, the same is indicated.)
I verify that the statements made in this Affidavit are true
and correct to the best of my personal knowledge, information and
belief. I understand that false statements herein are made subject
to the penalties of. 18 PA C.S. Section 4904 relati to unsworn
falsification to authorities.
Leon P. Haller PA I.D. #15700
Purcell, Krug & Haller
1719 North Front Street
Harrisburg, PA 17102
(717) 234-4178 rs
DATE: June 12, 2000
-14
COLUMBIA NATIONAL INCORPORATED, IN THE COURT OF COMMON PLEAS
PLAINTIFF CUMBERLAND COUNTY, PENNSYLVANIA
VS. CIVIL ACTION - LAW
NO. 1999 04558
SUSAN LYNN McCAFFERTY,
DEFENDANT IN MORTGAGE FORECLOSURE
NOTICE OF SHERIFF'S SALE OF REAL ESTATE
PURSUANT TO
PENNSYLVANIA RULE OF CIVIL PROCEDURE 3129
TAKE NOTICE:
held: the Sheriff's Sale of Real Property (real estate) will be
DATE: WEDNESDAY, September 6, 2000
TIME: 10:00 O'clock A.M.
LOCATION: Commissioner's Hearing Room
2nd Floor
Cumberland County Courthouse
Carlisle, Pennsylvania 17013
THE PROPERTY TO BE SOLD is delineated in detail in a legal
description mainly consisting of a statement of the measured
boundaries of the property, together with a brief mention of the
buildings and any other major improvements erected on the land.
(SEE DESCRIPTION ATTACHED)
THE LOCATION of your property to be sold is:
1915 Princeton Avenue
Camp Hill
CUMBERLAND COUNTY
PENNSYLVANIA
THE JUDGMENT under or pursuant to which your property is being
sold is docketed in the within Commonwealth and County to:
No. 1999 04558
THE NAME(S) OF THE OWNER(S) OR REPUTED OWNERS of this property
is:
SUSAN LYNN McCAFFERTY
A SCHEDULE OF DISTRIBUTION, being a list of the persons and/or
governmental or corporate entities or agencies being entitled to
receive part of the proceeds of the sale received and to be
disbursed by the Sheriff (for example, to banks that hold mortgagee
and municipalities that are owed taxes) will be filed by the
Sheriff of this County thirty (30) days after the sale and
distribution of the proceeds of sale in accordance with this
schedule will, in fact, be made unless someone objects by filing
exceptions to it within ten (10) days of the date it is filed.
Information about the Schedule of Distribution may be obtained
from the Sheriff of the Court of Common Pleas of the within County
at the Courthouse address specified herein.
THIS PAPER IS A NOTICE OF THE TIME AND PLACE OF THE SALE OF
YOUR PROPERTY.
IT HAS BEEN ISSUED BECAUSE THERE IS A JUDGMENT AGAINST YOU
IT MAY CAUSE YOUR PROPERTY TO BE HELD TO BE SOLD OR TAKEN TO
PAY THE JUDGMENT.
You may have legal rights to prevent your property from being
taken away. A lawyer can advise you more specifically of these
rights. If you wish to exercise your rights, YOU MUST ACT
PROMPTLY.
YOU SHOULD TAKE THIS PAPER TO YOUR LAWYER AT ONCE. GO TO OR
TELEPHONE THE OFFICE SET FORTH BELOW TO FIND OUT WHERE YOU CAN GET
FREE LEGAL ADVICE:
Cumberland County Bar Association
2 Liberty Avenue
Carlisle, Pennsylvania 17013
717-249-3166
Legal Services, Inc.
8 Irvine Row
Carlisle, PA 17013
717-243-9400
THE LEGAL RIGHTS YOU MAY HAVE ARE:
1. You may file a petition with the Court of Common Pleas of
the within County to open the judgment if you have a meritorious
defense against the person or company that has entered judgment
against you. You may also file an petition with the same Court if
you are aware of a legal defect in the obligation or the procedure
used against you.
2. After the Sheriff's Sale you may file a petition with the
Court of Common Pleas of the within County to set aside the sale
for a grossly inadequate price or for other proper cause. This
Petition MUST BE FILED BEFORE THE SHERIFF'S DEED IS DELIVERED.
3. A petition or petitions raising the legal issues or rights
mentioned in the preceding paragraphs must be presented to the
Court of Common Pleas of the within County. The petition must be
served on the attorney for the creditor or on the creditor before
presentation to the court and a proposed order or rule must be
attached to the petition.
If a specific return date is, desired, such date must be
obtained from the Court Administrator's Office - Civil Division, of
the within County Courthouse, before a presentation of the petition
to the Court.
A copy of the Writ of Execution is attached hereto.
PURCELL, KRUG & HALLER
Attorneys for Plaintiff
1719 North Front Street
Harrisburg, PA 17102
(717) 234-4178
LEGAL DESCRIPTION
ALL THAT CERTAIN lot or tract of land situate in the Borough
of Camp Hill, Cumberland County, Pennsylvania, in accordance with
a survey by Gerrit J. Betz, Registered?Surveyor, dated August 31,
1972, and being more particularly bounded and described as follows,
to wit:
BEGINNING at a hub on the southern line of Princeton Avenue,
said point being 452.46 feet from the southwest corner of Princeton
Avenue and 19th Street measured in a westerly direction; thence
South 30 degrees 17 minutes East 120 feet along the dividing line
between Lots 7 and B on the hereinafter mentioned Plan of Lots to
a point; thence extending South 59 degrees 43 minutes West 60 feet
to a hub; thence extending North 30 degrees 17 minutes West 120
feat along the dividing line between Lots 8 and 9 on the
hereinafter mentiuned Plan of Lcts?to a hub on the southern line of
Princeton Avenue; thence by said line North 59 degrees 43 minutes
East 60 feet to a point, the place'of BEGINNING.
HAVING ERECTED THEREONf a two story brick dwelling house known as
1915 Princeton Avenue, Camp Hill, PA.
BEING THE SAME PREMISES WHICH Thomas J. D'Annunzio, III and Susan
W. D'Annunzio by deed dated 1/4/94 and recorded in Cumberland
County Deed Book S-26 Page 1176 granted and conveyed unto Susan
Lynn McCafferty.
TO BE SOLD AS THE PROPERTY OF SUSAN LYNN MCCAFFERTY ON JUDGMENT NO.
1999 04558.
TAX PARCEL: 01-22-0536-328
WRIT OF EXECUTION and/or ATTACHMENT
COMMONWEALTH OF PENNSYLVANIA) NO. _99-4558 CIVILxJ9TF,
COUNTY OF CUMBERLAND) CIVIL ACTION - LAW
TO THE SHERIFF OF ljm t and COUNTY:
To satisfy the debt, interest and costs due Columbia National Incorporated
from Susan Lynn McCafferty 1915 Princeton Avenue. Carno Hill. Pa. 17011
DEFENDANT(S)
(1) You are directed to levy upon the property of the defendant(s) and to sell
Real Estate: 1915 Princeton Avenue, Camp Hill, Pa.
(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) If properlyof the defendant(s) not levied upon an subject to attachment isfound in the possession of 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 $ 99.411.60 L.L. $0.50
ANSI, /01/99 6 168 no r$ts.a71 Due Prothy Loo
Atty's Comm % Other Costs
Atty Paid 19g _n6 Late Charges 255.19 (19.63)
Plaintiff Paid Escrow Deficit 2,893.12
Date: June 13. 2000
Curtis R. Long
Prothonotary, Civil Division
by:
Deputy
REQUESTING PARTY:
Purcell, Krug & Haller
Name Leon P. Haller Escuire
Address: 1719 North Front Street
Attorney tor: PiAini- iff _
Telephone: 17171234-4178
Supreme Court ID No. PA 415700
REAL ESTATE SALE N0.4
in QG,,,, the sheriff levied upon the detendancs
interest in the real property situated in
Cumberland County, Pa., known and numbered as: /?/-r
aand more tuily described on Exhibit "A" filed with ?
this writ and by this reference incorporated herein. G?
nate:?? /S ?- BY :- .
-? Y