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FEDERMAN AND PHELAN
By: FRANK FEDERMAN
Identification No. 12248
Two Penn Center Plaza - Suite 900
Philadelphia, PA 19102
(215) 563-7000
CENDANT MORTGAGE CORPORATION,
F/K/A PHH US MORTGAGE CORPORATION
6000 ATRIUM WAY
MT. LAUREL, NJ 08054
Va.
DONALD E. BAKER
321 CHESTNUT STREET
MT. HOLLY, PA 17065
LISA K. BAKER
144 FAIRVIEW DRIVE
CARLISLE, PA 17013
Attorney for Plaintiff
CUMBERLAND COUNTY
COURT OF COMMON PLEAS
. CIVIL DIVISION
. NO. 99-4737 CIVIL
PRAECIPE FOR JUDGMENT FOR FAILURE TO
ANSWER AND ASSESSMENT OF DAMAGES
TO THE PROTHONOTARY:
Kindly enter judgment in favor of the Plaintiff and against
DONALD E. BAKER AND LISA K. BAKER, Defendant (s) for failure to file
an Answer to Plaintiff's Complaint within 20 days from service
thereof and for Foreclosure and Sale of the mortgaged premises, and
assess Plaintiff's damages as follows:
As set forth in Complaint
Interest - 8/1/99 TO 10/4/99
TOTAL
$61,884.53
$ 497.25
$62,381.78
I hereby certify that (1) the addresses of the Plaintiff and
Defendant (s) are as shown above, and (2) that notice has been given
in accordance with Rule 237.1, copy attached.
DAMAGES ARE HEREBY ASSESSED AS I
DATE: IO- 8-- - "
bt
F K FEDE MAN, ESQUIRE
Attorney for Plaintiff
FEDERMAN AND PHELAN
BY: FRANK FEDERMAN, ESQUIRE
Identification No. 12248
Suite 900, Two Penn Center Plaza
Philadelphia, PA 19102
(215) 563-7000
CENDANT MORTGAGE CORPORATION,
F/K/A PHH US MORTGAGE CORPORATION
Plaintiff(s)
vs.
DONALD E. BAKER
LISA K. BAKER
Defendant(s)
TO: DONALD E. BAKER
321 CHESTNUT STREET
MT. HOLLY, PA 17065
DATE OF NOTICE: 9/10199
ATTORNEY FOR PLAINTIFF
COURT OF COMMON PLEAS
CIVIL DIVISION
CUMBERLAND COUNTY
NO. 99-04737
THIS FIRM IS A DEBT COLLECTOR ATTEMPTING TO COLLECT A DEBT. ANY
INFORMATION WE OBTAIN WILL BE USED FOR THAT PURPOSE. IF YOU HAVE
PREVIOUSLY RECEIVED A DISCHARGE IN BANKRUPTCY, THIS CORRESPONDENCE
SHOULD NOT BE CONSTRUED TO BE AN ATTEMPT TO COLLECT A DEBT BUT ONLY
ENFORCEMENT OF A LIEN AGAINST PROPERTY.
IMPORTANT NOTICE
You are in default because you have failed enter a written appearance personally or by attorney and file
in writing with the court your defenses or objections to the claims set forth against you. Unless you act within ten
(10) days from the date of this notice, a Judgment may be entered against you without a hearing and you may lose
your property or other important rights. You should take this notice to a lawyer at once. If you do not have a
lawyer or cannot afford one, go to or telephone the following office to find out where you can get legal help:
CUMBERLAND COUNTY
CUMBERLAND COUNTY BAR ASSOCIATION
2 LIBERTY AVENUE
CARLISLE, PA 17013
(717) 249-3166
DATE: Au¢ust 30. 1999
FRANK FEDERMAN, ESQUIRE
Attorney for Plaintiff
e
1'EDERMAN AND PHELAN
BY: FRANK FEDERMAN, ESQUIRE
Identification No. 12248
Suite 900, Two Penn Center Plaza
Philadelphia, PA 19102
(215) 563-7000
CENDANT MORTGAGE CORPORATION,
F/IVA PHH US MORTGAGE CORPORATION
Plaintiff(s)
Vs.
DONALD E. BAKER
LISA K. BAKER
Defendant(s)
TO: LISA K. BAKER
144 FAIRVIEW DRIVE
CARLISLE, PA 17013
DATE OF NOTICE: 9/10199
ATTORNEY FOR PLAINTIFF
COURT OF COMMON PLEAS
CIVIL DIVISION
CUMBERLAND COUNTY
NO. 99-04737
THIS FIRM IS A DEBT COLLECTOR ATTEMPTING TO COLLECT A DEBT. ANY
INFORMATION WE OBTAIN WILL BE USED FOR THAT PURPOSE. IF YOU HAVE
PREVIOUSLY RECEIVED A DISCHARGE IN BANKRUPTCY, THIS CORRESPONDENCE
SHOULD NOT BE CONSTRUED TO BE AN ATTEMPT TO COLLECT A DEBT BUT ONLY
ENFORCEMENT OF A LIEN AGAINST PROPERTY.
IMPORTANT NOTICE
You are in default because you have failed enter a written appearance personally or by attorney and file
in writing with the court your defenses or objections to the claims set forth against you. Unless you act within ten
(10) days from the date of this notice, a Judgment may be entered against you without a hearing and you may lose
your property or other important rights. You should take this notice to a lawyer at once. If you do not have a
lawyer or cannot afford one, go to or telephone the following office to find out where you can get legal help:
CUMBERLAND COUNTY
CUMBERLAND COUNTY BAR ASSOCIATION
2 LIBERTY AVENUE
CARLISLE, PA 17013
(717) 249-3166
DATE: Aueust 30. 1999
FRANK FEDERMAN, ESQUIRE
Attorney for Plaintiff
FEDERMAN and PHELAN
By: FRANK FEDERMAN
Identification No. 12248
Suite 900
Two Penn Center Plaza
Philadelphia, PA 19102
(215) 563-7000
ATTORNEY FOR PLAINTIFF
CENDANT MORTGAGE CORPORATION,
F/K/A PHH US MORTGAGE CORPORATION CUMBERLAND COUNTY
COURT OF COMMON PLEAS
. CIVIL DIVISION
VS.
DONALD E. BAKER
LISA K. BAKER NO. 99-4737 CIVIL
VERIFICATION OF NON-MILITARY SERVICE
FRANK FEDERMAN, ESQUIRE, hereby verifies that he is
attorney for the Plaintiff in the above-captioned matter, and that
on information and belief, he has knowledge of the following facts,
to wit:
(a) that the defendant (s) is/are not in the Military or
Naval Service of the United States or its Allies, or otherwise
within the provisions of the Soldiers' and Sailors' Civil Relief
Act of Congress of 1940, as amended.
(b) that defendant DONALD E. BAKER is over 18 years of
age and resides at 321 CHESTNUT STREET, MT. HOLLY, PA 17065.
(c) that defendant LISA K. BAKER is over 18 years of
age, and resides at 144 FAIRVIEW DRIVE, CARLISLE, PA 17013.
This statement is made subject to the penalties of 18 Pa.
C.S. Section 4904 relating to unsworn falsification to authorities.
F NK FEDER , ESQUIRE
Attorney for Plaintiff
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PRAECIPE FOR WRIT OF EXECUTION - (MORTGAGE FORECLOSURE)
P.R.C.P.3180-3183
CENDANT MORTGAGE CORPORATION,
F/K/A PHH US MORTGAGE
CORPORATION
Plaintiff
Vs.
DONALD E. BAKER
LISA K. BAKER
COURT OF COMMON PLEAS
CUMBERLAND COUNTY, PA
NO. 99-4737 CIVIL
PRAECIPE FOR WRIT OF EXECUTION
(MORTGAGE FORECLOSURE?
Defendant(s)
TO THE DIRECTOR OF THE OFFICE OF THE PROTHONOTARY:
Issue writ of execution in the above matter: i
Amount Due $62,381.78 V/
Interest from 10/4/99 TO $ 1.527.25 and Costs
3/1/00
(PER DIEM - $10.25)
$63,909.03 Total
F K FEDER , ESQUIRE
TW PENN CEN ER PLAZA
SUITE 900
PHILADELPHIA, PA 19102
Attorney for Plaintiff
Note: Please attach description of property.
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DESCRIPTION
ALL those lots of ground situate in Middlesex Township, Cumberland County, Pennsylvania,
bounded and described as follows:
Lots Nos. 16 and 17, Block "C". in the Plan of Lots of Jacob S. Shenk, known as Cloverleaf Acres,
said Plan of Lots being recorded in the Recorder's Office of Cumberland County, Pennsylvania in
Plan Book No. 8, page 7. Each of said Lots Nos. 16 and 17 having a frontage of Fairview Avenue
of 75 feet and extending in depth at an even width a distance of 140 feet. Said Fairview Avenue
being a 60 foot street from inside curb line to inside curb line.
TAX PARCEL //21-18-1363-030.
TITLE TO SAID PREMISES IS VESTED IN Donald Baker and Lisa Baker, their heirs and
assigns by Deed from Harold H. Brenner, dated 9/27/89, recorded 9/29/89 in Deed Book "E"
Volume 34 page 828.
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CENDANT MORTGAGE CORPORATION,
F/K/A PHH US MORTGAGE CORPORATION CUMBERLAND COUNTY
COURT OF COMMON PLEAS
VS. CIVIL DIVISION
DONALD E. BAKER
LISA K. BAKER NO. 99-4737 CIVIL
NOTICE OF SHERIFF'S SALE OF REAL PROPERTY
October 4, 1999
TO: DONALD E. BAKER LISA K. BAKER
321 CHESTNUT STREET 144 FAIRVIEW DRIVE
MT. HOLLY, PA 17065 CARLISLE, PA 17013
**THIS FIRM IS A DEBT COLLECTOR ATTEMPTING TO COLLECT A
DEBT AND ANY INFORMATION OBTAINED WILL BE USED FOR
THAT PURPOSE. IF YOU HAVE PREVIOUSLY RECEIVED A
DISCHARGE IN BANKRUPTCY, THIS IS NOT AND SHOULD NOT BE
CONSTRUED TO BE AN ATTEMPT TO COLLECT A DEBT, BUT
ONLY ENFORCEMENT OF A LIEN AGAINST PROPERTY.**
Your house (real estate) at 144 FAIRVIEW DRIVE. CARLISLE PA
17013, is scheduled to be sold at the Sheriff's Sale on MARCH 1.
2000 at 10:00 a.m. in the Cumberland County Courthouse, South
Hanover Street, Carlisle, PA 17013, to enforce the court judgment
of $62,381.78 obtained by CENDANT MORTGAGE CORPORATION F/K/A PHH
US MORTGAGE CORPORATION (the mortgagee) against you. If the sale
is postponed, the property will be relisted for the
Sheriff's Sale.
NOTICE OF OWNER'S RIGHTS
YOU MAY BE ABLE TO PREVENT THIS SHERIFF'S SALE
To prevent this Sheriff's Sale, you must take immediate
action:
1. The sale will be cancelled if you pay to the mortgagee
the back payments, late charges, costs and reasonable
attorney's fees due. To find out how much you must pay,
you may call: (215) 563-7000.
2. You may be able to stop the sale by filing a petition
asking the Court to strike or open the judgment, if the
judgment was improperly entered. You may also ask the
Court to postpone the sale for good cause.
3. You may also be able to stop the sale through other legal
proceedings.
You may need an attorney to assert your rights. The sooner
you contact one, the more chance you will have of stopping the
sale. (See notice on page two on how to obtain an attorney.)
YOU MAY STILL BE ABLE TO SAVE YOUR PROPERTY AND YOU HAVE OTHER
RIGHTS EVEN IF THE SHERIFF'S SALE DOES TAKE PLACE.
1. If the Sheriff's Sale is not stopped, your property will
be sold to the highest bidder. You may find out the price bid by
calling (215) 563-7000.
2. You may be able to petition the Court to set aside the
sale if the bid price was grossly inadequate compared to the value
of your property.
3. The sale will go through only if the buyer pays the
sheriff the full amount due in the sale. To find out if this has
happened, you may call (717) 240-6390.
4. If the amount due from the Buyer is not paid to the
Sheriff, you will remain the owner of the property as if the sale
never happened.
5. You have the right to remain in the property until the
full amount due is paid to the Sheriff and the Sheriff gives a deed
to the buyer. At that time, the buyer may bring legal proceedings
to evict you.
6. You may be entitled to a share of the money which was paid
for your house. A proposed schedule of distribution of the money
bid for your house will be prepared by the Sheriff not later than
thirty (30) days after the sale. The schedule shall be kept on
file with the SHeriff and will be made available for inspection in
his office. The schedule will state who will be receiving that
money. The money will be paid out in accordance with this schedule
unless exceptions (reasons why the proposed distribution is wrong)
are filed with the sheriff within ten (10) days after the filing of
the proposed schedule.
7. You may also have other rights and defenses, or ways of
getting your home back, if you act immediately after the sale.
YOU SHOULD TAKE THIS PAPER TO YOUR LAWYER AT ONCE. IF YOU DO NOT
HAVE A LAWYER OR CANNOT AFFORD ONE, GO TO OR TELEPHONE THE OFFICE
LISTED BELOW TO FIND OUT WHERE YOU CAN GET LEGAL HELP.
CUMBERLAND COUNTY ATORNEY REFERRAL
CUMBERLAND COUNTY BAR ASOCIATION
2 LIBERTY AVENUE
CUMBERLAND COUNTY COURTHOUSE
CARLISLE, PA 17013
(717) 249-3166
(800) 990-9108
DESCRIPTION
ALL those lots of ground situate in Middlesex Township, Cumberland County, Pennsylvania,
bounded and described as follows:
Lots Nos. 16 and 17, Block "C", in the Plan of Lots of Jacob S. Shenk, known as Cloverleaf Acres,
said Plan of Lots being recorded in the Recorder's Office of Cumberland County, Pennsylvania in
Plan Book No. 8, page 7. Each of said Lots Nos. 16 and 17 having a frontage of Fairview Avenue
of 75 feet and extending in depth at an even width a distance of 140 feet. Said Fairview Avenue
being a 60 foot street from inside curb line to inside curb line.
TAX PARCEL #21-18-1363-030.
TITLE TO SAID PREMISES IS VESTED IN Donald Baker and Lisa Baker, their heirs and
assigns by Deed from Harold H. Brenner, dated 9/27/89, recorded 9/29/89 in Deed Book "E"
Volume 34 page 828.
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NT MORTG.%GE CORPORATION,
1 PHH US MORTGAGE CORPORATION
VS.
DONALD E. BAKER
LISA K. BAKER
CUMBERLAND COUNTY
COURT OF COMMON PLEAS
CIVIL DTVISION
NO. 99-4737 CIVIL
AFFIDAVIT PURSUANT TO RULE 3129
(Affidavit No 1)
CORPORATION , Plaintiff in the above action, by its attorney, FRANK
FEDERMAN, ESQ., sets forth as of the date the Praecipe for the Writ
of Execution was filed the following information concerning the
real property located at 144 FAIRVIEW DRIVE. CARLISLE, PA 17013
1. Name and address of Owner (s) or reputed Owner(s):
NAME LAST KNOWN ADDRESS (if address
cannot be reasonably ascertained,
please so indicate)
DONALD E. BAKER 321 CHESTNUT STREET
MT. HOLLY. PA 17065
LISA K. BAKER 144 FAIRVIEW DRIVE
CARLISLE, PA 17103
2. Name and address of Defendant (s) in the judgment:
NAME LAST KNOWN ADDRESS (if address
cannot be reasonably ascertained,
please so indicate)
SAME AS ABOVE
3. Name and address of every judgment creditor whose judgment is
a record lien on the real property to be sold:
NAME LAST KNOWN ADDRESS (if address
cannot be reasonably ascertained,
please so indicate)
MEMBERS 1ST FEDERAL 5275 EAST TRINDLE ROAD
CREDIT UNION MECHANICSBURG. PA 17055
4. Name and address of the last recorded holder of every mortgage
of record:
NAME LAST KNOWN ADDRESS (if address
cannot be reasonably ascertained,
please so indicate)
PENNSYLVANIA HOUSING 2101 N. FRONT STREET
FINANCE AGENCY HARRISBURG. PA 17101
Name and address
on the property:
NAME
NONE
6
NONE
7
of every other person who has any record lien
LAST KNOWN ADDRESS (if address
cannot be reasonably ascertained,
please so indicate)
Name and address of every other person who has any record
interest in the property and whose interest may be affected by
the sale:
NAME LAST KNOWN ADDRESS (if address
cannot be reasonably ascertained,
please so indicate)
Name and address of every other person whom the plaintiff has
knowledge who has any interest in the property which may be
affected by the sale:
NAME
TENANT/OCCUPANT
DOMESTIC RELATIONS OF
CUMBERLAND COUNTY
LAST KNOWN ADDRESS (if address
cannot be reasonably ascertained,
please so indicate)
144 FAIRVIEW DRIVE
CARLISLE, PA 17013
13 NORTH HANOVER STREET
CARLISLE, PA 17013
I verify that the statements made in this affidavit are
true and correct to the best of my personal knowledge or
information and belief. I understand that false statements herein
are made subject to the penalties of 18 Pa. C.S. Sec. 4904 relating
to unsworn falsification to authorities.
October 4, 1999
DATE F K FEDER'9AN, ESQUIRE
At orney for Plaintiff
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FEDERMAN and PHELAN
By: FRANK FEDERMAN
Identification No. 12248
Suite 900
Two Penn Center Plaza
Philadelphia, PA 19102
(215) 563-7000
CENDANT MORTGAGE CORPORATION,
F/K/A PHH US MORTGAGE CORPORATION
Va.
DONALD E. BAKER
LISA K. BAKER
CERTIFICATION
ATTORNEY FOR PLAINTIFF
CUMBERLAND COUNTY
COURT OF COMMON PLEAS
CIVIL DIVISION
. NO. 99-4737 CIVIL
FRANK FEDERMAN, ESQUIRE, hereby verifies that he is
attorney for the Plaintiff in the above-captioned matter, and that
the premises are not subject to the provisions of Act 91
because it is:
( ) an FHA mortgage
( ) non-owner occupied
( ) vacant
(XX) Act 91 procedures have been fulfilled
This certification is made subject to the penalties of
18 Pa. C.S. Section 4904 relating to unsworn falsification to
authorities.
taO t
F K FEDER , ESQUIRE
Attorney for Plaintiff
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FEDERMAN AND PHELAN
By: FRANK FEDERMAN, ESQUIRE
IDENTIFICATION NO. 12248
TWO PENN CENTER PLAZA, SUITE 900
PHILADELPHIA, PA 19102
21( 5) 5 3-7000
CENDANT MORTGAGE CORPORATION,
F/K/A PHH US MORTGAGE CORPORATION
6000 ATRIUM WAY
MT. LAUREL, NJ 08054
ATTORNEY FOR PLAINTIFF
COURT OF COMMON PLEAS
CIVIL DIVISION
TERM
Plaintiff
V. NO. -,737 (CGc?x
CUMBERLAND COUNTY
DONALD E. BAKER
LISA K. BAKER
144 FAIRVIEW DRIVE
CARLISLE, PA 17013
Defendant(s)
CIVIL ACTION - LAW
MORTGAGE FORECLOSURE
NOTICE
THIS FIRM IS A DEBT COLLECTOR ATTEMPTING TO COLLECT A DEBT. ANY INFORMATION WE
OBTAIN WILL BE USED FOR THAT PURPOSE. IF YOU HAVE PREVIOUSLY RECEIVED A
DISCHARGE IN BANKRUPTCY, THIS CORRESPONDENCE SHOULD NOT BE CONSTRUED TO BE AN
ATTEMPT TO COLLECT A DEBT BUT ONLY ENFORCEMENT OF A LIEN AGAINST PROPERTY.
You have been sued in Court. If you wish to defend against the claims set forth in the following
pages, you must take action within twenty (20) days after this Complaint and Notice are served,
by entering a written appearance personally or by attorney and filing in writing with the court
your defenses or objections to the claims set forth against you. You are warned that if you fail to
do so the case may proceed without you and a judgment may be entered against you by the court
without further notice for any money claimed in the Complaint or for any other claim or relief
requested by the Plaintiff. You may lose money or property or other rights important to you.
YOU SHOULD TAKE THIS PAPER TO YOUR LAWYER AT ONCE. IF YOU DO NOT
HAVE A LAWYER OR CANNOT AFFORD ONE, GO TO OR TELEPHONE THE OFFICE
SET FORTH BELOW TO FIND OUT WHERE YOU CAN GET LEGAL HELP.
CUMBERLAND COUNTY
CUMBERLAND COUNTY BAR ASSOCIATION
2 LIBERTY AVENUE
CARLISLE, PA 17013
(717) 249-3166
1. Plaintiff is
CENDANT MORTGAGE CORPORATION,
F/K/A PHH US MORTGAGE CORPORATION
6000 ATRIUM WAY
MT. LAUREL, NJ 08054
2. The name(s) and last known address(es) of the Defendant(s) are:
DONALD E. BAKER
LISA K. BAKER
144 FAIRVIEW DRIVE
CARLISLE, PA 17013
who is/are the mortgagor(s) and real owner(s) of the property hereinafter described.
3. On 2/21/92 mortgagor(s) made, executed and delivered a mortgage upon the premises
hereinafter described to PLAINTIFF which mortgage is recorded in the Office of the
Recorder of CUMBERLAND County, in Mortgage Book No. 1050, Page 260.
4. The premises subject to said mortgage is described as attached.
5. The mortgage is in default because monthly payments of principal and interest upon said
mortgage due 4/1/99 and each month thereafter are due and unpaid, and by the terns of
said mortgage, upon failure of mortgagor to make such payments after a date specified by
written notice sent to Mortgagor, the entire principal balance and all interest due thereon
are collectible forthwith. A copy of such notice is attached as Exhibit "A."
6. The following amounts are due on the mortgage:
Principal Balance $55,859.20
Interest 1,170.45
3/1/99 through 8/1/99
(Per Diem $7.65)
Attorney's Fees 2,792.00
Cumulative Late Charges 307.18
2/21/92 to 8/1/99
Cost of Suit and Title Search 550.00
Subtotal 60,678.83
Escrow
Credit 0.00
Deficit 1.205.70
Subtotal 1.205.70
TOTAL $61,884.53
7. The attorney's fees set forth above are in conformity with the Mortgage documents and
Pennsylvania Law, and will be collected in the event of a third party purchaser at
Sheriffs Sale. If the Mortgage is reinstated prior to the Sale, reasonable attorney's fees
will be charged.
8. This action does not come under Act 6 of 1974 because the original mortgage amount
exceeds $50,000.00.
9. The Temporary Stay as provided by the Homeowner's Emergency Mortgage Assistance
Program, Act 91 of 1983, has terminated because either:
(i.) Defendant(s) have failed to meet with the Plaintiff or an authorized Credit
Counseling Agency in accordance with Plaintiff's written Notice to Defendants,
a true and correct copy of which is attached hereto as Exhibit "B"; or
(ii.) Defendant(s) application for assistance has been rejected by the Pennsylvania
Housing Finance Agency.
10. Pursuant to the Fair Debt Collection Practices Act, 15 U.S.C. § 1692 et seq.
(1977), Defendant(s) may dispute the validity of the debt or any portion thereof.
If Defendant(s) do so in writing within thirty (30) days of receipt of this pleading,
Counsel for Plaintiff will obtain and provide Defendant(s) with written
verification thereof, otherwise, the debt will be assumed to be valid. Likewise, if
requested within thirty (30) days of receipt of this pleading, Counsel for Plaintiff
will send Defendant(s) the name and address of the original creditor if different
from above.
WHEREFORE, PLAINTIFF demands an in rem Judgment against the Defendant(s) in the sum of
$61,884.53, together with interest from 8/1/99 at the rate of $7.65 per diem to the date of
Judgment, and other costs and charges collectible under the mortgage and for the foreclosure and
sale of the mortgaged property.
2sFank Federman
FRANK FEDERMAN, ESQUIRE
Attorney for Plaintiff
PHH 31onp8e Tel 800 449 8767
6000 .Vnnum Way Fax 609 642 8300
6000
ML LAMI, V1 08074
PHH.
June 04, 1999
Donald Z Baker
Lisa H Baker
144 Fairview Drive
Carlisle, PA 17013
RE: Loan Number 2920064
144 Fairview Drive
Carlisle PA 17013
Dear Member(s):
NOTICE Of INTENTION TO FORECLOSE MORTGAGE
The mortgage held by PHH Mortgage Services (hereinafter
we us or ours) on your property located at 144 Fairview Drive
Carlisle pA 17013 is in serious default because you
have not made the monthly payment of $ 548.75 for last 3
months. Late charges (and other charges) have also accrued to
this date in the amount of $ 265.54.
You may cure this default within thirty (30) days of the date
of this letter by paying to us the amount of $ 1,927.09 plus
any additional monthly payments and late charges which may
fall due during this period. Such payment must be made either
by cash, cashier's check, certified check or money order, and
sent to 6000 Atrium Way, Mount Laurel, NJ 08054.
If you do not cure the default within thirty (30) days, we
intend to exercise our right to accelerate the mortgage
payments. This means that whatever is outstanding on the original
amount borrowed will be considered due immediately and you
may lose the chance to pay off the original mortgage in
monthly installments. If full payment of the amount of
default is not made within thirty (30) days, we also intend
to instruct our attorneys to start a lawsuit to foreclose
your mortgaged property.
If the mortgage is foreclosed, your mortgaged property will
be sold by the sheriff to pay off the mortgage debt. If we
refer your case to our attorneys and you cure the default
before they begin legal proceedings against you, you will
still have to pay the reasonable attorney's fees incurred up
to $50.00. However, if legal proceedings are started against
you, you will have to pay the reasonable attorney's fees even
if they are over $50.00.
EXHlBR A
9999 9999999 XC200 2920064
Attorney's tees will be -ided to whatever you owe us, wh!
may also include our ca. cable costs. If you cure the c ault
within the thirty day period, you will not be required to pay
attorney's fees.
We may also sus You personally for the unpaid principal balance
and all other sums under the mortgage If you have not cured the
default within the thirty day period and foreclosure proceedings
have begun, you still have the right to cure the default and
prevent the sale at any time up to one hour before the sheriff's
foreclosure sale. You may do so by paying the Total Amount
of the unpaid monthly payments plus any late or other charges
then due, as well as the reasonable attorney's fees and costs
connected with the foreclosure sale (and perform any other
requirements under the mortgage). It is estimated that the
earliest date that such a sheriff's sale could be held would
be approximately six months from date of this letter. A
notice of the date of the sheriff's sale will be sent to
you before the sale. of course, the amount needed to cure
the default will increase the longer you wait. You may
find out at any time exactly what the required payment will
be by calling us at the following number 1-800-257-0460.
This payment must be in cash, cashier's check, certified
check or money order and made payable to us at the address
stated above.
You should realize that a sheriff's sale will end your
ownership of the mortgaged property and your right to remain
in it. If you continue to live in the property. alter the
sheriff's sale, a lawsuit could be started to evict you.
You have additional rights to help protect your interest in
the property. You have the right to sell the property to
obtain money to pay off the mortgage debt, or to borrow
money from another lending institution to pay off this debt.
You may have the right to sell or transfer the property
subject to the mortgage to a buyer or transferee who will
assume the mortgage debt, provided that all the outstanding
payments, charges and attorney's fees and costs are paid prior
to or at the sale, (and that the other requirements under the
mortgage are satisfied). Contact us to determine under what
circumstances this right might exist. You have the right to
have this default cured by any third p:,rty acting on your behalf.
If you cure the default, the mortgage will be restored to the
same position as if no default had occurred. However, you are
not entitled to this right to cure your default more than
three times in any calendar year. If you have any questions
regarding your account, please call us at 800-257-0460 Ext. 3901.
Sincerely,
The Collection Department
=200/Attachment CXH113N A
PHH Nongife
Bemicee
6000 ALnum Way
Sn Lavel. V1 08064
Tel 800 449 8767
Fan 609 642 8300
ACT 91 NOTICE
TAKE ACTION TO SAVE YOUR HOME FROM FORECLOSURE
IMPORTANT: NOTICE OF HOMEOWNERS EMERGENCY MORTGAGE ASSISTANCE PROGRAM
PLEASE READ THIS NOTICE] YOU MAY BE ELIGIBLE FOR FINANCIAL ASSISTANCE
WHICH CAN SAVE YOUR HOME FROM FORECLOSURE AND HELP YOU TO MAKE FUTURE
MORTGAGE PAYMENTS.
June 04, 1999
Donald E Baker
Lisa K Baker
144 Fairview Drive
Carlisle, PA 17013
RE: Mortgage Loan Number 2920064
144 Fairview Drive
Carlisle PA 17013
The Commonwealth of Pennsylvania's " Homeowners Emergency Mortgage
Assistance Program " may be able to help you. Read the following
notice to find out how the program works. If you need more information,
call the Pennsylvania Housing Finance Agency at (800)-342-2397.
LA NOTIFICACION EN ADJUNTO ES DE SUMA IMPORTANCIA, DUES AFECTA SO
DERECHO A CONTINUAR VIVIENDO EN SU CASA. 31 NO CONPAENDE EL COMPAENDE
EL CONTENIDO DE ESTA NOTIFICACION OBTENGA UNA TRADUCCION IMMEDIATAMENTE
LLAMANDO ESTA AGENCIA (PENNSYLVANIA HOUSING FINANCE AGENCY) SIN CARGOS
AL NUMBZRO 14ENCIONAW ARRIBA. PUEDES SER ELIGIBLE PARR UN PRESTAMO POR
EL PAOGRAMA LLAMADO " HOMEOWNERS EMERGENCY MORTGAGE ASSISTANCE PROGRAM "
AL CUAL PUEDE SALVAR SO CASA DE LA PERDIDA DEL DERECHO A REDIMAR SO
HIPOTECA.
You may be eligible for financial assistance that will prevent your
home from being foreclosed upon if you comply with the provisions of
the " Homeowners Emergency Assistance Act of 1983 ". Temporary assistance
may be offered if your default has been caused by circumstances beyond
your control, you have a reasonable prospect of resuming your mortgage
payments, and you meet other eligibility requirements established by the
Pennsylvania Housing Finance Agency. Please read the enclosed notice as
it contains an explanation of your rights.
Under the Act of 1983, you are entitled to a temporary stay of fore-
closure for thirty (30) days from the date of this notice. During that
time you have the right to arrange a "Face to race" meeting with a
representative of this lender, or with a designated Consumer Credit
Counseling Agency. The purpose of that meeting is to work out a repayment
plan or to otherwise settle your delinquency. That mating must occur in
the next thirty (30) days.
I PHH
999! 9999999 XC201 2920064
If you attend a face-to- on meeting with this lender, or +ith a represen
tative of the Consumer Credit Counseling Agency, no further foreclosure
proceeding may take place for thirty (30) days after the date of that
meeting. You may contact us at 1-800-257-0660 Ext. 3901 for the name of
our representative.
The names and addresses of designated Consumer Credit Counceling Agencies
are shown on the attached sheet. It is only necessary to schedule one
face-to-face meeting. You should advise this lender immediately of your
intention.
Your mortgage is in default because you have failed to pay prompt
installments of principal and interest, as required, for a period of
at least sixty (60) days, The total amount of the delinquency is
$ 1,927,09.
If you have tried and are unable to resolve this problem at/or after
your face-to-face meeting, you have the right to apply for financial
assistance under the Homeowners Emergency Assistance Act of 1983 with
one of the designated Consumer Credit Counseling Agencies listed on
the attachment. An application for assistance may only be obtained from
a Consumer Credit Counseling Agency, That Agency will will assist you in
filling out your application and will submit the completed application
to the Pennsylvania Housing Finance Agency. Your application must be
filed or postmarked within thirty (30) days of your face-to-face meeting.
It in very important that your application is accurate and complete.
The Pennsylvania Housing Finance Agency has sixty (60) days to make a
decision after it receives your application. During that time, no
foreclosure proceedings will take place providing that you have met the
time requirements not forth above. You will be notified directly by the
agency of its decision. Available funds will be dispursed by the agency
under the eligibility criteria established by the Act.
You may receive another notice from this lender under ACT 6 of 1974.
That notice is called a " NOTICE OF INTENTION TO FORECLOSE ". You must
read both notices as they explain your rights under Pennsylvania Law.
The Pennsylvania Housing Finance Agency is located at:
2101 North Front Street, PO Box 8029
Harrisburg, pA 17105
Phone: (717)-780-3800 or (800)-342-2397
Sincerely,
The Collection Department
XC201/Attachment
EXHIDT °B".
Pennsylvania Housing Finance Agency
Homeowner's Emergency Mortgage Assistance Program
Consumer Credit Counseling Agencies
(Rev. 5/99)
Lyeoming-C!iateo Counties
Commission For Community Action (STEP)
2138 Lincoln Street
P. 0. Box 1328
(WOll)oun"P d7P? 17703
FAX (570) 322.2197
CCCS Of Yomheastern PA
201 Basin Street
((WiU'3' 2,7 cM PA 17703
FAX (5+,0)323-6526
CLL`ITO OL-=11,
CCCS of Northeaster= Pk
1631 S !Atherton St
Suite 100
State College, PA 16a01
(814) 238-0668
F•1X (814) 238-0669
C0LL-178LL COU; QTY
CCCS of Northeastern Pennsylvania
31 W. Market Suet
POB 1127 1400 Abington E.teardve Park
Wilkes-Barre, PA 18702 Suite 1
Clarks Summits. PA 18411
(570) 821-0837 or(800)922.9537
FAX (570) 821-1785 (570)587.9163 or (600) 922-9537
FAX (570) 587-913.0135
Commission on Economics Opportunity of Luzern County
163 Amber Lane
Wilkes-Barre, PA 18702
(570) 826-0510 or (800) 822-0359
FAX (570) 829-1665-CALL BEFORE F.•=qG
(570) 455-4994 HAZELTON
FAX (570) 455.5631--CALL 13EF ORE FAlZNG
(570) 836-4090 TUNKIi44; OCK
CRAWFOR.D COMM
Booker T. Washington Center
1720 Holland Street Greater Erie Community Action Committee
Erie, PA 16503 18 West 9th Street
Ere, PA 16501
(814) 453.5744 (814) 459-4581
F.A.}C (814) 453-5749 FAX (814) 456.0161
John F. Kennedy Center, Inc. Shenango Valley Urban League
Inc
2021 East 20th Street ,
601 Indiana Avenue
Erie, PA 16510 Farrell. PA 16121
(814) 898-0400 (412) 981.5310
FAX (814) 898.1243 ,
CUMER.LIND COL'NTY
CCCS of Western Pennsvlvania. Inc.
2000 Ling!esmwn Road Finanda! Counseling Serrices of Franklin
3
W
Harrisburg, P.4 17102 1
est 3rd Street
Waynesboro, P4 17268
(711) 541.1757 (717)762.3295
Urban League of Metropolitan Harrisburg YWCA of Carlisle
N. 6th Street 301 G Street
Harrisburg, PA. 17101 Carlisle, PA 17013
(717) 234-5925 (717) 243-3818
FXC (717) 234.9459 FAX (717) 731.9589
Community Acton Comm of the Capital Region Adams County Housing Aut4orit7
1514 Derry Street 139-143 Carlisle St
Harrisburg, PA 17104 Gettysburg, PA 1735
(717) 232.9757 (717)334.1518
FAX (717) 23+2227 FA.( (717) 334.8326
EXHIBIT 1113"
PENNSYLVANIA BULLETIN, VOL 29, NO. 4 JUNE S. 1999
"" ue- ALL those late of
ground .LzuatB Middlesex
4f ? Z 7 c Township, Cumberland County, Pennsylvania, bounded
and described as follows,
Lots Now. 16 and 17, Block •'C", In the Plan of
Lots of Jricob S. Shenk, knoem no Cloverleaf Acres,
avid Plan of Lots being recorded in the Recorder's
Office of Cumberland County, Pennsylvania in Plan
Book No. e, page 7. Each of aaid Lots Noe. 16 and 17
l having a frontage on Pairview Avenue of 75 feet and
extending In depth at an even width a distance of 140
feet. Said Fairview Avanua being a 60 foot street
from inside curb line to Inside i.urb line.
r, 'Che above described lots are subject to the
ti building restrictions and covenants attached to and
1; W applicable to said Plana.
w Being the same promises which Jacob S. Shenk and
I Edna N. Shenk, his wife, by their dead dated July 24,
1956, and recorded in the office aforesaid in Deed
l Book "I", Volume 17, Page 488, granted and conveyed
unto Clyde Brenner and Pearl Brenner, his wife. The
Bald Pearl Brenner, having died August 17, 1976,
title was veotcd in Clyde Brenner as surviving tenant
by the entirety. The said Clydo E. Brenner died
July 7, 1977, and Letters Testamentary were issued on
his estate by the Register of Hills of Cumberland
County to Joseph D. Brenner as Executor. Upon
application by said Executor, the Orphans' Court
Division of the Court of Common Pleas of Cumberland
County, Pennsylvania, by a Decree Awarding Real
Estate dated June 7, 1970, did award, decree and
- --- confirm the aforesaid lots unto Harold N. Brenner
,
Grantor herein, said Decree A:w,=ding Real Estate
having boon recorded in the Office of the Recorder of
Deedo in and for Cumberland County in Deed Book "V"
,
Volumes 27, Page 498..
PREMISES: 144 FAIRVIEW DRIVE
VERIFICATION
MARC HINKLE hereby states that he is VICE-PRESIDENT of CENDANT
MORTGAGE SERVICES mortgage servicing agent for Plaintiff in this
matter, that he is authorized to take this Verification, and that
the statements made in the foregoing civil Action in Mortgage
Foreclosure are true and correct to the best of his knowledge,
information and belief. The undersigned understands that this
statement is made subject to the penalties of 18 Pa. C.S. Sec. 4904
relating to unsworn falsification to authorities.
DATE: a- 3 -99
-% SHERIFF'S RETURN - REGULAR
CASE NO: 1999-04737 P
COMMONWEALTH OF PENNSYLVANIA:
COUNTY OF CUMBERLAND
CENDANT MORTGAGE CORP
VS.
BAKER DONALD E ET AL
_DAWN KELL Sheriff or Deputy Sheriff of
CUMBERLAND County, Pennsylvania, who being duly sworn according
to law, says, the within COMPLAINT - MORT FORE
was served
upon BAKER DONALD E
the
defendant, at _ 18:10 HOURS, on the 19th day of August
1999 at 321 CHESTNUT STREET
MT HOLLY, PA 17065 CUMBERLAND
County, Pennsylvania, by handing to DONALD BAKER
a true and attested copy of the COMPLAINT - MORT FORE
together with NOTICE
and at the same time directing His attention to the contents thereof.
Sheriff's Costs: So answers:
Docketing 18.00 ,/-
Service 4.34
Affidavit .00 ?
Surcharge 8.00 omas ine, eri
XFEDERMAN & PHELAN
08/20/1999
by Q
L)epucy eri
sworn and subscribed to before me
this x -&- day of
199 A.D.
%'-'fro n??ono?ta?r
I I
SHERIFF'S RETURN - REGULAR
CASE NO: 1999-04737 P
COMMONWEALTH OF PENNSYLVANIA:
COUNTY OF CUMBERLAND
CENDANT MORTGAGE CORP
VS.
BAKER DONALD E ET AL
BRIAN BARRICK Sheriff or Deputy Sheriff of
CUMBERLAND County, Pennsylvania, who being duly sworn according
to law, says, the within COMPLAINT - MORT FORE was served
upon BAKER LISA K the
defendant, at 13:29 HOURS, on the 20th day of August
1999 at 144 FAIRVIEW DRIVE
CARLISLE, PA 17013 CUMBERLAND
County, Pennsylvania, by handing to LISA K. BAKER
a true and attested copy of the COMPLAINT - MORT FORE
together with NOTICE
and at the same time directing Her attention to the contents thereof.
Sheriff's Costs: So answers:
Docketing 6.00
Service 3.10
Affidavit .00 ioG !4? P
Surcharge 8.00 A. omas ine, 5 eri
-08%20 1999 PHELA?N
by
_ epu y 1
Sworn and subscribed to before me
this „LU 19, day of
19q0j A. D.
ro ono ary-
FEDERMAN AND PHELAN
BY: FRANK FEDERMAN
ATTORNEY I.D. NO. 12248
SUITE 900
TWO PENN CENTER PLAZA
PHILADELPHIA, PA 19102
(215) 563-7000
CENDANT MORTGAGE CORPORATION F/K/A
PHH US MORTGAGE CORPORATION
VS.
DONALD E. BAKER
LISA K. BAKER
ATTORNEY FOR PLAINTIFF
Court of Common Pleas
Civil Division
CUMBERLAND COUNTY
NO. 99-4737 CIVIL
AFFIDAVIT OF SERVICE OF NOTICE OF SHERIFF'S SALE
PURSUANT TO P.R C P 404(2)/403
FRANK FEDERMAN, ESQUIRE, Attorney for Plaintiff, hereby certifies
that service of the Notice of Sheriff's Sale was made by sending
a true and correct copy by certified mail to Defendant(s) LISA
K. BAKER at 144 FAIRVIEW DRIVE CARLISLE, PA 17013 which notice of
Sheriff's Sale was received by Defendant(s) LISA K. BAKER on
NOVEMBER 17, 1999 as evidenced by the attached return receipt.
The undersigned understands that this statement is mad subject to
the penalties of 18 PA C.S. s 4? relati unsworn
falsification to authorities. / //
FRANK
DATE: NOVEMBER 24. 1999
FEDERMAN AND PHELAN
BY: FRANK FEDERMAN
ATTORNEY I.D. NO. 12248
SUITE 900
TWO PENN CENTER PLAZA
PHILADELPHIA, PA 19102
(215) 563-7000
ATTORNEY FOR PLAINTIFF
Court of Common Pleas
Civil Division
CENDANT MORTGAGE CORPORATION F/K/A CUMBERLAND COUNTY
PFF US MORTGAGE CORPORATION
VS.
DONALD E. BAKER NO. 99-4737 CIVIL
LISA K. BAKER
AFFIDAVIT OF SERVICE OF NOTICE OF SHERIFF'S SALE
PURSUANT TO P.R.C P 404(2)/403
FRANK FEDERMAN, ESQUIRE, Attorney for Plaintiff, hereby certifies
that service of the Notice of Sheriff's Sale was made by sending
a true and correct copy by certified mail to Defendant (s) DONALD
E. BAKER at 321 CHESTNUT STREET MT.HOLLY,PA 17065 which notice of
Sheriff's Sale was received by Defendant(s) DONALD E. BAKER on
NOVEMBER 17, 1999 as evidenced by the attached return receipt.
The undersigned understands that this s
the penalties of 18 PA C.S. s 4
falsification to authorities. /
is made subject to
sting tt6 \ unsworn
FRANK
DATE: NOVEMBER 24. 1999
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IN THE COURT OF COMMON PLEAS OF CUMBERLAND COUNTY, PENNSYLVANIA
CENDANT MORTGAGE CORPORATION,
F/K/A PHH US MORTGAGE CORPORATION
Plaintiff CIVIL DIVISION
vs.
DONALD E. BAKER
LISA K. BAKER
Defendants
No. 99-4737 CIVIL
AFFIDAVIT OF SERVICE PURSUANT TO RULE 3129
COMMONWEALTH OF PENNSYLVANIA
CUMBERLAND COUNTY
SS:
I, FRANK FEDERMAN, ESQ., attorney for CENDANT MORTGAGE
CORPORATION. F/K/A PHH US MORTGAGE CORPORATION, hereby verify that on
NOVEMBER 5. 1999, true and correct copies of the Notice of Sheriffs Sale were served
by certificate of mailing to the recorded lienholder(s), and any known interested party,
see Exhibit "A" attached hereto, and the Notice of Sale was sent to defendant(s) on
NOVEMBER 15. 1999 by first class mail and certified mail return receipt requested, see
Exhibit "B" attached hereto.
FRANK FEDER AN, ESQUIRE
Attorney for PI ' tiff
Date: January 28. 2000
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IN THE COURT OF COMMON PLEAS OF CUMBERLAND COUNTY, PENNSYLVANIA
CENDANT MORTGAGE CORPORATION,
F/WA PHH US MORTGAGE CORPORATION
Plaintiff
vs.
DONALD E. BAKER
LISA K. BAKER
Defendants
CIVIL DIVISION
No. 99-4737 CIVIL
AFFIDAVIT OF SERVICE PURSUANT TO RULE 3129
COMMONWEALTH OF PENNSYLVANIA
FEDEFii,•R ,•'1!- i :_ .I SS:
CUMBERLAND COUNTY
I, FRANK FEDERMAN, ESQ., attorney for CENDANT MORTGAGE
CORPORATION. F/K/A PHH US MORTGAGE CORPORATION, hereby verify that on
NOVEMBER 5. 1999, true and correct copies of the Notice of Sheriffs Sale were served
by certificate of mailing to the recorded lienholder(s), and any known interested party,
see Exhibit "A" attached hereto, and the Notice of Sale was sent to defendant(s) on
NOVEMBER 15. 1999 by first class mail and certified mail return receipt requested, see
Exhibit "B" attached hereto.
FEDERMAW •.,D riif i,ii
ATTORNrY ?;7 '7 r_ rs; Y
PLEASE M-
FEDERMAN AND PHFI-?',,f
ATTORNEY r=i L'ri; y
PLEiiSr r..r'i; i?
FRANK FEDER AN, ESQUIRE
Attorney for Plai tiff
Date: January 28. 2000
N }
t:] J
R
FEDERMAN AND PHELAN
By: FRANK FEDERMAN
IDENTIFICATION NO. 12248
TWO PENN CENTER PLAZA, SUITE 900
PHILADELPHIA, PA 19102
X215) 563-7000
Cendant Mortgage Corporation,
f/k/a PHH US Mortgage
Corporation
Plaintiff
Vs.
Donald E. Baker
Lisa K. Baker
Defendant(s)
ATTORNEY FOR PLAINTIFF
Cumberland County
Court of Common Pleas
CIVIL DIVISION
NO. 99-4737-CIVIL
PRAECIPE TO SATISFY JUDGMENT
AND MARK CASE DISCONTINUED AND ENDED
WITHOUT PREJUDICE
TO THE PROTHONOTARY:
Kindly satisfy the Judgment which was entered on
October 8, 1999 against Donald E. Baker and Lisa K. Baker,
Defendant(s), in the amount of $62,381.78 relative to the instant
matter and mark this case discontinued and ended, without
prejudice, upon payment of your costs only.
FRANK FEDERMAN, ESQUIRE
Attorney for Plaintiff
Dated: March 27, 2000
[fit cv
CK,
Ci'-
u.r._ -
F - 1
Lk
? Ci
Cendant Mortgage Corporation
F/k/a PHH US Mortgage Corporation
-vs-
Donald E. Baker and Lisa K. Baker
In the Court of Common Pleas of
Cumberland County, Pennsylvania
No. 99-4737 Civil
R. Thomas Kline, Sheriff, who being duly sworn according to law, says this writ
is returned STAYED.
Sheriff's Costs:
Docketing
Poundage
Posting Bills
Advertising
County
Law Library
Mileage
Certified Mail
Levy
Postpone Sale
Surcharge
Share of Bills
Law Journal
Patriot News
Auctioneer
Sworn and subscribed to before me
30.00
1,315.04
15.00
15.00
1.00
.50
10.54
1.95
15.00
20.00
24.00
25.08
214.25
198.68
10.00
1,896.04 By Atty
04/12/00
This -L7:-`day of
2000, A.D. I t
I o onotary
'
So answers:,
R. Thomas Kline, Sheriff
BY
Real Estate Deputy
(,j17
Ck'2 Sw3
d&, 9 dr.9L
PROOF OF PUBLICATION OF NOTICE
IN CUMBERLAND LAW JOURNAL
(Under Act No. 587, approved May 16, 1929), P. L.1784
STATE OF PENNSYLVANIA :
COUNTY OF CUMBERLAND :
ss.
Roger M. Morgenthal, Esquire, Editor of the Cumberland Law Journal, of the County
and State aforesaid, being duly sworn, according to law, deposes and says that the Cumberland
Law Journal, a legal periodical published in the Borough of Carlisle in the County and State
aforesaid, was established January 2, 1952, and designated by the local courts as the official legal
periodical for the publication of all legal notices, and has, since January 2, 1952, been regularly
issued weekly in the said County, and that the printed notice or publication attached hereto is
exactly the same as was printed in the regular editions and issues of the said Cumberland Law
Journal on the following dates,
viz:
JANUARY 21, 28, 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 true.
REAL ESTATE 8011E NO. 6
Writ No. 99-4737 Civil
Cendant Mortgage Corporation
f/k/a PHH US Mortgage
Corporation
VS.
Donald E. Baker, Lisa K. Baker
Atty.: Frank Federman
DESCRIPTION
ALL those lots of ground situate
In Middlesex Township. Cumberland
County, Pennsylvania, bounded and
described as follows:
LOTS NOS. 16 and 17. Block "C",
In the Plan of Lots of Jacob S. Shenk,
known as Cloverleaf Acres, said Plan
of Lots being recorded in the Re-
corder's Office of Cumberland
County, Pennsylvania in Plan Book
Roger M. Morgenthal, Editor
SWORN TO AND SUBSCRIBED before me this
4 day of FEBRUARY- 2000
Alntnn,
NOTARIAL SEAL
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THE PATRIOT NEWS
THE SUNDAY PATRIOT NEWS
Proof of Publication
Under 8CtNo.587.8nnro Rnnmued Mail 16, 1929
Commonwealth of Pennsylvania, County of Dauphin) as
Frank J. Epler being duly sworn according to law, deposes and says:
That he is the Controller of THE PATRIOT-NEWS CO., a corporation organized and existing under the laws of the
Commonwealth of Pennsylvania, with Its principal office and place of business at 812 to 818 Market Street, In the
City of Harrisburg, County of Dauphin, State of Pennsylvania, owner and publisher of THE PATRIOT-NEWS and THE
SUNDAY PATRIOT-NEWS newspapers of general circulation, printed and published at 812 to 818 Market Street, in
the City, County and State aforesaid; that THE PATRIOT-NEWS and THE SUNDAY PATRIOT-NEWS were established
March 4th, 1854, and September 18th, 1949, respectively, and all have been continuously published ever since;
That the printed notice or publication which is securely attached hereto is exactly as printed and published In
their regular dally and/or Sunday and Metro editionalissues which appeared on the 25th day of January and the let
and 8th day(s) of February 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 Miscellaneous Book •M',
Volume 14, Page 317.
PUBLICATION
a anal sore m this 25th y f Febr t? 0 A.D.
otarial Seel
Na
Terry L. Fussell, Notary Public
Hanisburg, Dauphin County
a? 9mv NOT AMY PUBLIC
Member.Pennsylvania ASSONatbnulNOlyricommission expires June 8, 2002
CUMBERLAND COUNTY SHERIFFS OFFICE
COURTHOUSE
CARLISLE, PA. 17013
Statement of Advertising Costs
To THE PATRIOT-NEWS CO., Dr.
For publishing the notice or publication attached
hereto on the above stated dates $ 197.18
Probating same Notary Fee(s) $ 1.50
Total $ 198.88
Publisher's Receipt for Advertising Cost
THE PATRIOT-NEWS CO., publisher of THE PATRIOT-NEWS and THE SUNDAY PATRIOT-NEWS, newspapers of general
circulation, hereby acknowledge receipt of the aforesaid notice and publication costs and certifies that the same have
been duly paid. THE PATRIOT-NEWS CO.
By ........................
COPY
SALE#5
GENDANT MORTGAGE CORPORATION,
F/K/A PHH US MORTGAGE CORPORATION
Vs.
DONALD E. BAKER
LISA K. BAKER
CUMBERLAND COUNTY
COURT OF COMMON PLEAS
. CIVIL DIVISION
. NO. 99-4737 CIVIL
AFFIDAVIT PURSUANT TO RULE 3129
(Affidavit No 1)
cURYURATION , Plaintiff in the above action, by its attorney, FRANK
FEDERMAN, ESQ., sets forth as of the date the Praecipe for the Writ
of Execution was filed the following information concerning the
real property located at 144 FAIRVIEW DRIVE CARLISLE PA 17013.
1. Name and address of Owner (s) or reputed Owner(s):
NAME LAST KNOWN ADDRESS (if address
cannot be reasonably ascertained,
please so indicate)
DONALD E. BAKER 321 CHESTNUT STREET
MT. HOLLY, PA 17065
LISA K. BAKER 144 FAIRVIEW DRIVE
CARLISLE, PA 17103
2. Name and address of Defendant (s) in the judgment:
NAME LAST KNOWN ADDRESS (if address
cannot be reasonably ascertained,
please so indicate)
SAME AS ABOVE
3. Name and address of every judgment creditor whose judgment is
a record lien on the real property to be sold:
NAME LAST KNOWN ADDRESS (if address
cannot be reasonably ascertained,
please so indicate)
MEMBERS 1ST FEDERAL 5275 EAST TRINDLE ROAD
CREDIT UNION MECHANICSBURG, PA 17055
4. Name and address of the last recorded holder of every mortgage
of record:
NAME LAST KNOWN ADDRESS (if address
cannot be reasonably ascertained,
please so indicate)
PENNSYLVANIA HOUSING 2101 N. FRONT STREET
FINANCE AGENCY HARRISBURG. PA 17101
5
NONE
6
NONE
7
Name and address of every other person who has any record lien
on the property:
NAME LAST KNOWN ADDRESS (if address
cannot be reasonably ascertained,
please so indicate)
Name and address of every other person who has any record
interest in the property and whose interest may be affected by
the sale:
NAME LAST KNOWN ADDRESS (if address
cannot be reasonably ascertained,
please so indicate)
Name and address of every other person whom the plaintiff has
knowledge who has any interest in the property which may be
affected by the sale:
NAME
TENANT/OCCUPANT
DOMESTIC RELATIONS OF
CUMBERLAND COUNTY
LAST KNOWN ADDRESS (if address
cannot be reasonably ascertained,
please so indicate)
144 FAIRVIEW DRIVE
CARLISLE, PA 3.7013
13 NORTH HANOVER STREET
CARLISLE, PA 17013
I verify that the statements made in this affidavit are
true and correct to the best of my personal knowledge or
information and belief. I understand that false statements herein
are made subject to the penalties of 18 Pa. C.S. Sec. 4904 relating
to unsworn falsification to authorities.
October 4, 1999
DATE F K FEDER4AN, ESQUIRE
At orney f Plaintiff
CENDANT MORTGAGE CORPORATION,
• F/K/A PHH US MORTGAGE CORPORATION
vs.
DONALD E. BAKER
LISA K. BAKER
NO. 99-4737 CIVIL
NOTICE OF SHERIFF'S SALE OF REAL PROPERTY
October 4, 1999
TO: DONALD E. BAKER LISA K. BAKER
321 CHESTNUT STREET 144 FAIRVIEW DRIVE
MT. HOLLY, PA 17065 CARLISLE, PA 17013
"THIS FIRM IS A DEBT COLLECTOR ATTEMPTING TO COLLECT A
DEBT AND ANY INFORMATION OBTAINED WILL BE USED FOR
THAT PURPOSE. IF YOU HAVE PREVIOUSLY RECEIVED A
DISCHARGE IN BANKRUPTCY, THIS IS NOT AND SHOULD NOT BE
CONSTRUED TO BE AN ATTEMPT TO COLLECT A DEBT, BUT
ONLY ENFORCEMENT OF A LIEN AGAINST PROPERTY."
Your house (real estate) at 144 FAIRVIEW DRIVE, CARLISLE PA
17013, is scheduled to be sold at the Sheriff's Sale on MARCH 1.
2000 at 10:00 a.m. in the Cumberland County Courthouse, South
Hanover Street, Carlisle, PA 17013, to enforce the court judgment
of $62,381.78 obtained by CENDANT MORTGAGE CORPORATION, F/K/A PHH
US MORTGAGE CORPORATION (the mortgagee) against you. If the sale
is postponed, the property will be relisted for the
Sheriff's Sale.
NOTICE OF OWNER'S RIGHTS
YOU MAY BE ABLE TO PREVENT THIS SHERIFF'S SALE
To prevent this Sheriff's Sale, you must take immediate
action:
1. The sale will be cancelled if you pay to the mortgagee
the back payments, late charges, costs and reasonable
attorney's fees due. To find out how much you must pay,
you may call: (215) 563-7000.
2. You may be able to stop the sale by filing a petition
asking the Court to strike or open the judgment, if the
judgment was improperly entered. You may also ask the
Court to postpone the sale for good cause.
CUMBERLAND COUNTY
COURT OF COMMON PLEAS
CIVIL DIVISION
3. You may also be able to stop the sale through other legal
proceedings.
j You may need an attorney to assert your rights. The sooner
you contact one, the more chance you will have of stopping the
sale. (See notice on page two on how to obtain an attorney.)
YOU MAY STILL BE ABLE TO SAVE YOUR PROPERTY AND YOU HAVE OTHER
RIGHTS EVEN IF THE SHERIFF'S SALE DOES TAKE PLACE.
1. If the Sheriff's Sale is not stopped, your property will
be sold to the highest bidder. You may find out the price bid by
calling (215) 563-7000.
2. You may be able to petition the Court to set aside the
sale if the bid price was grossly inadequate compared to the value
of your property.
3. The sale will go through only if the buyer pays the
Sheriff the full amount due in the sale. To find out if this has
happened, you may call (717) 240-6390.
4. If the amount due from the Buyer is not paid to the
Sheriff, you will remain the owner of the property as if the sale
never happened.
5. You have the right to remain in the property until the
full amount due is paid to the Sheriff and the Sheriff gives a deed
to the buyer. At that time, the buyer may bring legal proceedings
to evict you.
6. You may be entitled to a share of the money which was paid
for your house. A proposed schedule of distribution of the money
bid for your house will be prepared by the Sheriff not later than
thirty (30) days after the sale. The schedule shall be kept on
file with the SHeriff and will be made available for inspection in
his office. The schedule will state who will be receiving that
money. The money will be paid out in accordance with this schedule
unless exceptions (reasons why the proposed distribution is wrong)
are filed with the Sheriff within ten (10) days after the filing of
the proposed schedule.
7. You may also have other rights and defenses, or ways of
getting your home back, if you act immediately after the sale.
YOU SHOULD TAKE THIS PAPER TO YOUR LAWYER AT ONCE. IF YOU DO NOT
HAVE A LAWYER OR CANNOT AFFORD ONE, GO TO OR TELEPHONE THE OFFICE
LISTED BELOW TO FIND OUT WHERE YOU CAN GET LEGAL HELP.
CUMBERLAND COUNTY ATORNEY REFERRAL
CUMBERLAND COUNTY BAR ASOCIATION
2 LIBERTY AVENUE
CUMBERLAND COUNTY COURTHOUSE
CARLISLE, PA 17013
(717) 249-3166
(800) 990-9108
ALL those lots of ground situate in Middlesex Township, Cumberland County, Pennsylvania,
bounded and described as follows:
Lots Nos. 16 and 17, Block "C", in the Plan of Lots of Jacob S. Shenk, known as Cloverleaf Acres,
said Plan of Lots being recorded in the Recorder's Office of Cumberland County, Pennsylvania in
Plan Book No. 8, page 7. Each of said Lots Nos. 16 and 17 having a frontage of Fairview Avenue
of 75 feet and extending in depth at an even width a distance of 140 feet. Said Fairview Avenue
being a 60 foot street from inside curb line to inside curb line.
TAX PARCEL k21-18-1363-030.
TITLE TO SAID PREMISES IS VESTED IN Donald Baker and Lisa Baker, their heirs and
assigns by Deed from Harold H. Brenner, dated 9/27/89, recorded 9/29/89 in Deed Book "E"
Volume 34 page 828.
WRIT OF EXECUTION and/or ATTACHMENT
COMMONWEALTH OF PENNSYLVANIA) NO. 99-4737 _CIVIL 19_
COUNTY OF CUMBERLAND) CIVIL ACTION - LAW
TO THE SHERIFF OF CUMBERLAND COUNTY:
To satisfy the debt, interest and costs due Cendarrt Mortgage Corporation, f/k/a PHH
US Mortgage Corporation
PLAINTIFF(S)
from Donald E. Baker, 321 Chestnut St., Mt. Holly. Springs PA '.17065 and
Lisa K. Baker, 144 Fairview Dr., Carlisle PA 17013.
DEFENDANT(S)
(1) You are directed to levy upon the property of the defendant(s) and to sell Real estate located
at 144 Fairview Dr., Carlisle PA 17013. (See attached lega escrip ion.)
(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 property of 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 hirtvher that he/she has been added as a garnishee and is enjoined as above
stated.
Amount Due $62,381.78
Interest R6409per34,14mO0 $1,527.25
Ally's Comm
Ally Paid _
Plaintiff Paid
Date:
October 8, 1999
REQUESTING PARTY
Name Frank Federman, Esquire
Address: Two Perin Center Sq Ste
$119.44
Philadelphia PA 19102
Attorney for: Plaint/
Telephone: (215)
Supreme Court ID No.
637000
12248
L.L.
$.50
Due Prothy.
_
Other Costs
1.00
CURTIS R. LONG
Protho ot=CivilDivision
by:
Depuly
REAL ESTATE SALE No.-5-
0 n 19 4 S the Sheri i Ind upon tie dcianda:,ts
interest in the real property situa a;+ in 4-&
Curr:berla.nd C0ui=,ty, Pa., kn,iv.i,I,,:Iri ui:;11, red as: _/??- - 1L.?
.? u;i;ibit „A„ filed l,r„1
this vlrit ald.t by tlljJ 11:;'rcnCH II1l,QIporatGtl herein.
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