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FEDERMAN AND PHELAN
By: FRANK FEDERMAN, ESQUIRE
IDENTIFICATION NO. 12248
TWO PENN CENTER PLAZA, SUITE 900
PHILADELPHIA, PA 19102
(215) 563.7000
PNC BANK, N.A.
539 SOUTH FOURTH AVENUE
LOUISVILLE, KY 40202
V.
Plaintiff
BRETT S. GORSLINE
51 OLIVER ROAD
ENOLA, PA 17025
Dcfcndant(s)
ATTORNEY FOR PLAINTIFF
COURT OF COMMON PLEAS
CIVIL DIVISION
TERM
NO. 94- 1. 30/ &,;a! 7-e.
CUMBERLAND COUNTY
CIVIL ACTION - LAW
MORTGAGE FORECLOSURF.
ON TICS
PLEASE IIR ADVISED THAT THIS FIRM IS A DEIIT COLLECTOR ATTEMPTING TO COLLECT A DEBT. ANY
INFORMATION RECEIVED WILL IIE USED FOR THAT PURI'OSF_ IF YOU HAVE PREVIOUSIA' RECEIVED A
DISCIIARGK IN BANKRUPTCY AND TI IIS DEIIT WAS NO'r REAFFIRAIF.D. Tn IS CORRESPONDENCE IS NOT AND
SHOULD NOT IIE CONSTRUED TO IIK AN ATTEhmr TO COLLECT A DEIIT BUT ONLY KNFORCF.MEN'r OF A
WEN AGAINST 1'ROPKBTY.
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 arc wamcd 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
I. Plaintiff is
PNC BANK, N.A.
539 SOUTH FOURTH AVENUE
LOUISVILLE, KY 40202
2. The name(s) and last known address(es) of the Defendant(s) arc:
BRETT S. GORSLINE
51 OLIVER ROAD
ENOLA, PA 17025
who is/are the mortgagor(s) and real owner(s) of the property hereinafter described.
3. On 11/15/93 mortgagor(s) made, executed and delivered a mortgage upon the premises
hereinafter described to FLEET REAL ESTATE FUNDING CORP. which mortgage is
recorded in the Office of the Recorder of CUMBERLAND County, in Mortgage Book
No. 1178, Page 25. By Assignment of Mortgage dated 8/11/97 the mortgage was
assigned to PLAINTIFF which Assignment is recorded in Assignment of Mortgage Book
No. 555, Page 701.
4. The premises subject to said mortgage is described as attached.
5. The mortgage is in default because monthly payments of principal and interest upon said
mortgage due 1/1/99 and each month thereafter are due and unpaid, and by the terms of
said mortgage, upon failure of mortgagor to make such payments after a date specified by
written notice sent to Mortgagor, the entire principal balance and all interest due thereon
arc collectible forthwith. A copy of such notice is attached as Exhibit "A."
6. The following amounts arc due on the mortgage:
Principal Balance $58,959.19
Interest 3,438.24
12/1/98 through 10/1/99
(Per Dicm $11.31)
Attorney's Fees 2,947.00
Cumulative Late Charges 209.60
11/15/93 to 10/1/99
Cost of Suit and Title Search 0 00
Subtotal 66,104.03
Escrow
Credit 0.00
Deficit 91.92
Subtotal 2.m
TOTAL $66,195,95
7. The attorney's fees set forth above arc 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. The Combined Notice has been sent to the Defendant(s) by regular and certified mail as
required by 35 P.S. § 1680.403c on the date(s) set forth in the true and correct copy of
such notice(s)attached hereto as Exhibit "A."
9. The Temporary Stay as provided by the Homeowner's Emergency Mortgage Assistance
Program, Act 91 of 1983, has terminated because Defendant(s) have failed to meet with
the Plaintiff or an authorized Credit Counseling Agency in accordance with Plaintiffs
written Notice to Defendants, a true and correct copy of which is attached hereto as
Exhibit "A."
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 j0 fSII] Judgment against the Defendant(s) in the sum of sY
$66,195.95, together with interest from 10/1/99 at the rate of S 11.31 per diem to the date of '-
Judgment, and other costs and charges collectible under the mortgage and for the foreclosure and
sale of the mortgaged property.
s/ Frank Federman
FRANK FEDERMAN, ESQUIRE
Attorney for Plaintiff
• PVC Mortgage Corp. of America
599 South Fmtrth Awnur
------ 4,.uki le.KY40202
1 800 736 9090
October 01, 1999
Brett S Gorsline
51 Oliver Rd
Enola PA 17025 0000
PNCM®]EBT GAGE
RE: PNC No. 0000789537
Dear Mortgagor:
Please be advised that PNC Mortgage has initiated foreclosure
proceedings on your loan. The case has been referred
to the following law firm to commence foreclosure:
Federman & Phelan
Suite 900
Two Penn Center Plaza
Philadelphia PA, 19102
In order to avoid foreclosure, there are several options:
1. If your situation changes, and you are able to reinstate or pay
off your loan, then contact the law firm referenced above at
(215)563-7000.
2. If you are unable to reinstate or pay off your loan, PNC Mortgage
may be able to help you save your home and protect your credit
rating. We have enclosed an information package that better
describes possible options. In order for PNC Mortgage to help
you, please review the attached, complete the financial information
and return with all the required documentation to the Loss Mitiga-
tion Department at 75 N. Fairway Drive, Vernon Hills, IL 60061.
NOTE: We are required to continue all foreclosure activity during the
review of any possible alternatives.
Sincerely,
Default Administration
1-800-736-9090
Foreclosure Department
FEDERAL LAW REQUIRES US TO INFORM YOU THAT ANY INFORMATION YOU PROVIDE
US CAN BE USED IN THE COLLECTION OF YOUR MORTGAGE DEBT.
Investor Name: Fnma 126690002 Corp A/a /Conventional
XF993/L
50\511 P
APPENDIX A
ACT 91 NOTICE
TAKE ACTION TO SAVE
YOUR HOME FROM
FORECLOSURE
This is an official notice that the mortgage on your home is in default and the lender intends to foreclose
Specific'information about the nature of the default is provided in the attached pages
The HOMEOWNER'S MORTGAGE ASSISTANCE PROGRAM (HEMAP) may be able to help to save
your home. This Notice explains how the program works.
To see if HEMAP can help, you must 4NIEET WITH A CONSUMER CREDIT COUNSELING AGENCY
WITHIN 30 DAYS OF THE DATE OF THIS NOTICE. Take this Notice with you when you meet with
the Counseling Agency.
The name, address and phone number of Consumer Credit Counseling Agencies serving your County are
listed at the end of this Notice. If you have any questions, you may call the Pennsylvania Housing Finance
Agency toll free at 1-800.342.2397.(Persons.with impaired hearing can call (717) 780-1869).
This Notice contains important legal information. If you have any questions, representatives at the
Consumer Credit Counseling Agency may be able to help explain it. You may also want to contact an
attorney in your area. The local bar association may be able to help you find a lawyer.
LA NOTIFICACION EN ADJUNTO ES DE SOMA IMPORTANCIA, PUES AFECTA SU DERECHO
A CONTINUAR VIVIENDO EN SU CASA. SI NO COMPRENDE EL CONTENIDO DE ESTA
NOTIFICACION OBTENGA UNA TRADUCCION INMEDITAMENTE LLAIMANDO ESTA
AGENCIA (PENNSYLVANIA HOUSING FINANCE AGENCY) SIN CARGOS AL NUMERO
MENCIONADO ARRIBA. PUEDES SER ELEGIBLE PARA UN PRESTAMO POR EL PROGRAMA
LLAMADO "HOMEOWNER'S EMERGENCY MORTGAGE ASSISTANCE PROGRAM" EL CUAL
PUEDE SALVAR SU CASA DE LA PERDIDA DEL DERECHO A REDIMIR SU HIPOTECA.
HOMEOWNER'S EMERGENCY MORTGAGE ASSISTANCE PROGRAM
YOU MAY BE ELIGIBLE FOR FINANCIAL ASSISTANCE WHICH CAN SAVE YOUR HOME
FROM FORECLOSURE AND HELP YOU MAKE, FUTURE MORTGAGE PAYMENTS
IF YOU COMPLY WITH THE PROVISIONS OF THE HOMEOWNER'S EMERGENCY MORTGAGE ASSISTANCE
ACT OF 1983 (THE "ACT"), YOU MAY BE ELIGIBLE FOR EMERGENCY MORTGAGE ASSISTANCE:
IF YOUR DEFAULT HAS BEEN CAUSED BY CIRCUMSTANCES BEYOND YOUR CONTROL,
IF YOU HAVE A REASONABLE PROSPECT OF BEING ABLE TO PAY YOUR MORTGAGE
PAYMENTS, AND
IF YOU MEET OTHER ELIGIBILITY REQUIREMENTS ESTABLISHED BY THE
PENNSYLVANIA HOUSING FINANCE AGENCY.
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Pennsylvania Housing Finance Agency
Homeowner's Emergency Mortgage Assistance Program
Consumer Credit Counseling Agencies
(Rev. 5199)
Lycomin .r CLDVTO-_- ;COLVIT
Commission For Ccmmt a!
2138 Lincoln Street ry Action ISfEP) CCCS of Norbeaatern P.4.
1631 S Atherton St
P 0. Box 1328 Suite 100
W(Illamspor PA 17703 State College, PA 16a01
(370) 326-0sa7 (814) 2384668
FAY (570) 322.2197 FAX (814) 238.3669
CCCS of Nor4eastern PA
201 Basin Street
=Pom PA 17703
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FAX (570) 323.8626
COLUNMIA COUNTY
CCCS of Northeastern Pennsylvania
31 W. h?arkat Sreec 000 Abington Executive Park
14
POB 11_7 a
PA 1870.
Wilkes-Barre `
Clarks Summit- P.A. 18411
.
(570) 821-0837 or (800) 922.9537
' (570) Sa7•9163 or (800) 921•9537
FAX (570) 587.913 0135
C (570) 821.1785
FA.
CommLssion an Econamio Opportunity of L=eme County
163 Amber Lane
Wilkea•Barre, PA 18702
(570) 826-0510 or (800) 822-0339
FAX (570) 829.1665-CALL BEFORE FAMG
(570) 4554994 HAZELTON
F.4.'C (570) 455.5631--CAL(. BEFORE F.J=XG
(570) 8364090 TUNKHANNOCK
Booker T. Washington Center
1720 Holland Sc-eec
Erie, PA 16503
(814) 453.5744
FAX (814) 453.5749
John F. Kennedy Center, Inc.
2021 East 20th Street
Erie, PA 16510
(814) 898-0400
FAX (814) 898.1243
CCCS of Western Pennsylvania, Inc.
2000 Linglestown Road
HarrisburgPA 17102
(717)341.1757
Urban League of Metropolitan Harrisburg
N. 6th Street
Harrisburg, PA 17101
(717) 234-5925
FAX (717) 234.9459
CRAWFORD COUNTY
Greater Erie Community Ac=on Committee
18 West 9th Street
Ere, PA 16501
(814) 4594581
FAX (814) 456-0161
Shenango Valley Urban League, Inc
601 )ndiaaa Avenue
Farrell. PA 16121
(412)981.5310
CUMER.L ,IM COUNW
Financial Counseling Services of Franklin
31 West Std Street
Waynesboro, PA 17268
(717) 762.7295
YWCA of Carlisle
301 G Street
Carlisle, PA 17013
(717)243.3818
FAX (717) 731.9sa9
Community Action Comm of the Capital Region
1514 Derry Street
Harrishurj, PA 17104
(717) 232.9757
FAX (717)234.2227
Adams County Housing Auchorir/
139-143 Carlisle St
Gettysburg, PA 17325
(717) 334.1518
FAX (717) 334.8326
PENNSYLVANIA BUUXM, VOL 29, NO. 27, JUNE S, 1999
All THAT CERTAIN piece or parcel of land situate. in East Pannaboro
Township, Cumberland County, Pennsylvania, morn particularly bounded*
and described in accordance with a survey by Michael C. DOAngelo,
Registered Surveyor, dated March 26, 1975, as follows, to wit:
BEGINNING at a stake along the westerly line of Oliver Road, which
stake is one hundred fifty-eight and ninety-six hundredths (158.96
foot southeast of the southeast corner of the intersection of Louis
Lana and Oliver Road; thence South forty-six (46) degrees zero (00)
minutes East, a distance of sixty-four (64.0) feat to a.¦take at the.
dividing line between the herein described Lot and Lot No. 52 on the
hereinafter mentioned Plan of Lots; thence South forty-four (44)
degrees zero (00) minutes West, a distance of one hundred ten
(110.0) feet along the dividingg line between the herein described
Lot and Lot No. 52, as aforesaid, to a stake; thence along the
dividing line between the heroin described Lot and Lot No. 45 on the
hereinafter mentioned Plan of Lots, North forty-six (46) degrees
zero (00) minutes West, a distance of sixty-four (64.0) feet. to a
stake; thence along the dividing line between the herein described
Lot and Lot No. 50 on the. hereinafter mentioned Plan of Lots, North
forty-four (44) degreas zero (00) minutes East, adistance of one
hundred tan (110.0) feet to a stake, the place of BEGINNING.
BEING Lot No. 51 an Plan of Louie Park, recorded in Plan Book 5,
Page 50.
VERIFICATION
ADAM STYERS hereby states that lie is ASSISTANT VICE-PRESIDENT of PNC
MORTGAGE CORP. OF AMERICA mortgage servicing agent for Plaintiff in this matter, that he
is authorized to take this Verification, and that die statements made in the foregoing Civil Action
in Mortgage Foreclosure are true mid correct to the best of his knowledge, information and belief.
The undersigned understands that this statement is made subject to die penalties of 18 Pa. C.S.
Sec. 4904 relating to unsworn falsification to authorities.
DATE: 1b 1 LJof q
ADAM STYERS
ASST: VICE PRESIDENT
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SHERIFF'S RETURN - REGULAR
CASE NO: 1999-06301 P
COMMONWEALTH OF PENNSYLVANIA:
COUNTY OF CUMBERLAND
PNC BANK N A
VS.
GORSLINE BRETT S
CPL. TIMOTHY REITZ Sheriff or Deputy Sheriff of
CUMBERLAND County, Pennsylvania, who being duly sworn according
to law, says, the within COMPLAINT - MORT FORE was served
upon GORSLINE BRETT S the
defendant, at 20:05 HOURS, on the 21st day of October ,
1999 at 51 OLIVER ROAD
ENOLA, PA 17025 ,CUMBERLAND
County, Pennsylvania, by handing to BRETT S. GORSLINE ,
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 answe s
Docketing 18.00 `./
Service 9.30 ?A ?
Affidavit .00
Surcharge 8.00 Kline,
Tnomas S-.35.3II-10%22 1999 P//HELAN
by d~ .lsr?i G
Sworn and subscribed to before me
this .?.? A-W day of
191l A.D. Q ?(
IIr , e ?'d Sa a ?7-r
FEDERMAN AND PHELAN
By: FRANK FEDERMAN
Identification No. 12248
Two Penn Center Plaza - Suite 900
Philadelphia, PA 19102
(215) 563-7000
PNC Bank, N.A.
539 South Fourth Avenue
Louisville, KY 40202
Plaintiff
VS.
Brett S. Gorsline
51 Oliver Road
Enola, PA 17025
Defendant(s)
Attorney for Plaintiff
Cumberland COUNTY
:COURT OF COMMON PLEAS
CIVIL DIVISION
NO. 99-6301 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 Brett S. Gorsline, Defendant(s),
for failure to file an Answer to Plaintiffs Complaint within 20 days from service thereof and for
foreclosure and sale of the mortgaged premises, and assess Plaintiffs damages as follows:
As set forth in Complaint $66,195.95
Interest 10/1/99 to 11/23/99 610.74
TOTAL $66,806.69
I hereby certify that (1) the addresses of the Plaintiff and Defendant(s) are as shown above,
and (2) notice has been given in accordance with Rule 237. 1, copy attached.
FRANK FEDERMAN, ESQUIRE
Attorney for Plaintiff
DAMAGES ARE HEREBY ASSESSED AS INDICATED.
DATE: 74tLt,u&, ?Y /949
PROP THY
"THIS FIRM IS A DEBT COLLECTOR ATTEMPTING TO COLLECT A DEBT AND ANY INFORMATION OBTAINED WILL BE
USED FOR TIIAT PURPOSE.. IF YOU HAVE PREVIOUSLY RECEIVED A DISCHARGE IN DANKRVrTCV AND THIS DEBT WAS
NOT REAFFIRM ED, TIIIS CORRESPONDENCE IS NOT AND SHCRILD NOT BE CONSTRUED TO BE AN ATTE%IrT TO COLLECT
A DEBT, RIrr ONIN ENFORCEMENT OF A LIEN AGAINST PROPERTY."
FEDERMAN AND PHELAN
Frank Federman, Esquire
Identification No. 12248
Two Penn Center Plaza
Suite 900
Philadelphia, PA 19102-1799
(215) 563-7000
ATTORNE': FOR PLAINTIFF
PNC BANK, N.A. COURT OF CCMMON PLEAS
Plaintiff CIVIL DIVISION
Vs.
BRETT S. GORSLINE
Defendant(s)
TO: BRETT S. GORSLINE
51 OLIVER ROAD
ENOLA, PA 17025
DATE OF NOTICE: NOVEMBER 12, 1999
CUMBERLAND COUNTY
. NO. 99-6301-CIVIL TERM
THIS FIRM IS A DEBT COLLECTOR ATTEMPTING TO COLLECT A DEBT.
ANY INFORMATION WE OBTAIN WILL BE USED FOR THAT PURPOSE. IF
YOU HAVE PREVIOUSLY RECEIVED A DISCHARGE IN BANKRUPTCY, THIS
CORRESPONDENCE IS NOT AND SHOULD NOT BE CONSTRUED TO BE AN
ATTEMPT TO COLLECT A DEBT, BUT ONLY ENFORCEMENT OF A LIEN
AGAINST PROPERTY.
IMPORTANT NOTICE
You are in default because you have failed to enter a written
appearance personally or by attorney and file in writing with the
court your defenses or objections to the claims --et forth against
you. Unless you act within ten (10) days from =he date of this
notice, a Judgment may be entered against you wit::)ut a hearing and
you may lose your property or other important r_ Its. You should
take this notice to a lawyer at once. If you do :.ot have a lawyer
or cannot afford one, go to or telephone the fc-'lowing office to
find out where you can get legal help:
CUMBERLAND COUNTY
2 LIBERTY AVENUE
CARLISLE, PA 17013
(717) 249-3166
BAR ASSOCI.%TION
Frank Federms;:, Esquire
Attorney for _laintiff
FEDERMAN and PHELAN
By: FRANK FEDERMAN
Identification No. 12248
Suite 900
Two Penn Center Plaza
Philadelphia. PA 19102
(215) 563-7000
Attorney for Plaintiff
PNC Bank, N.A.
Plaintiff
VS.
Brett S. Gorsline
Defendant(s)
: Cumberland COUNTY
: Court of Common Pleas
: CIVIL DIVISION
: NO. 99-6301 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 Brett S. Gorsline is over 18 years of age and resides at 51 Oliver
Road, Enola, PA 17025.
This statement is made subject to the penalties of 18 Pa. C.S. Section 4904 relating
to unswom falsification to authorities.
1"Y' +.- .
RANK FEDERMAN
Attorney for Plaintiff
(Rule of Civil Procedure No. 236- Revised)
PNC Bank, N.A. : Cumberland COUNTY
Plaintiff : Court of Common Pleas
VS. : CIVIL DIVISION
Brett S. Gorsline : NO. 99-6301 Civil
Defendant(s)
Notice is given that a Judgment in the above captioned matter has been entered against you on
November .1999.
By DEPUTY
If you have any questions concerning this matter, please contact:
FRANK FEDERMAN. E
Attorney for Filing Party
SUITE 900
TWO PENN CENTER PLAZA
PHILADELPHIA. PA 19102
(215) 563-7000
"THIS FIRM 1S A DEBT COLLECTOR ATTEMPTING TO COLLECT A DEBT AND ANY
INFORMATION OBTAINED WILL BE USED FOR THAT PURPOSE. IF YOU HAVE PREVIOUSLY
RECEIVED A DISCHARGE IN BANKRUPTCY AND THIS DEBT WAS NOT REAFFIRMED, THIS IS NOT
AND SHOULD NOT BE CONSTRUED TO BE AN ATTEMPT TO COLLECT A DEBT, BUT ONLY
ENFORCEMENT OF A LIEN AGAINST PROPERTY. ""
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IN THE COURT OF COMMON PLEAS OF CUMBERLAND COUNTY, PENNSYLVANIA
PNC BANK, N.A.
Plaintiff
VS.
BRETT S. GORSLINE
Defendants
CIVIL DIVISION
No. 99-6301 CIVIL
AFFIDAVIT OF SERVICE PURSUANT TO RULE 3129
COMMONWEALTH OF PENNSYLVANIA
CUMBERLAND COUNTY
SS:
I, FRANK FEDERMAN, ESQ., attorney for PNC BANK. N.A. hereby verify
that on DECEMBER 10. 1999, true and correct copies of the Notice of Sheriffs Sale
were served by certificate of mailing to the recorded Ilenholder(s), and any known
interested party, see Exhibit "A" attached hereto, and the Notice of Sale was sent to
defendant(s) on DECEMBER 10. 1999 by first class mall and certified mail return
receipt requested, see Exhibit "B" attached hereto.
r?
FRANK FEDRMAN, ESQUIRE
Attorney for, laintiff
Date: January 29, 2000
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IN THE COURT OF COMMON PLEAS OF CUMBERLAND COUNTY, PENNSYLVANIA
PNC BANK, N.A.
Plaintiff
VS.
BRETT S. GORSLINE
Defendants
FEDEnfvllkia i%l:'.' F}4r'-?.i?
CIVIL DIVISION
No. 99-6301 CIVIL
AFFIDAVIT OF SERVICE PURSUANT TO RULE 3129
COMMONWEALTH OF PENNSYLVANIA
CUMBERLAND COUNTY
SS:
FEDERMAN AND PHELAU
ATTORNEY Fll.r C'1PY
0"
PiLl.-.I.F,c.
I, FRANK FEDERMAN, ESQ., attorney for PNC BANK. N.A. hereby verify
that on DECEMBER 10. 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 DECEMBER 10. 1999 by first class mail and certified mail return
receipt r qALWN"4Egr?pxhibit "B" attached hereto.
FEDERMAN
A p?Ej?EEtrrtEl COPY
FRANK FEDERMAN, ESQUIRE
/ Attorney for Plaintiff
Date: January 29. 2000
FEDERMAN AND PHELAN
ATTORNEY FILE COPY
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PRAECIPE FOR WRIT OF EXECUTION - (MORTGAGE FORECLOSURE)
P.R.C.P. 31M3183
PNC BANK, N.A. s COURT OF COMMON PLEAS
: CUMBERLAND COUNTY, PA
s
Plaintiff s NO. 99-6301 CIVIL
s
va. s
s
BRETT S. OORSLINE i PRABCIPE FOR WRfr OF EXECUTION
i (MORTCACE FORECLOSURE)
i
Defendant(s) _
TO THE DIRECTOR OF THE OFFICE OF THE PROTHONOTARY:
Issue writ of execution in the above matter:
Amount Due $66.806.69
Interest from 11/24/99 TO $ 1.065.06 and Costs
3/1/00
(PER DIEM - $10.98)
$67.871.75 Total
X
FRAI?lC FEDERMAN/ ESQUIRE
TWO PENN CENT R PLAZA
SUITE 900
PHILADELPHIA, PA 19102
Attorney for Plaintiff
Note: Please attach description of property.
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DESCRIPTION
ALL THAT CERTAIN piece or parcel of land situate in East Pennsboro Township. Cumberland
County, Pennsylvania, more particularly bounded and described in accordance with a survey by
Michael C. D'Angelo, Registered Surveyor, dated March 26, 1975, as follows, to wit:
BEGINNING at a stake along the Westerly line of Oliver Road, which stake is one hundred fifty-
eight and ninety-six hundredths (158.96) feet Southeast of the Southeast corner of the intersection of
Louis Lane and Oliver Road; thence South forty-six (46) degrees zero (00) minutes East, a distance
of sixty-four (64.0) feet to a stake at the dividing line between the herein described Lot and Lot No.
52 on the hereinafter mentioned Plan of Lots; thence South forty-four (44) degrees zero (00) minutes
West, a distance of one hundred ten (110.0) feet along the dividing line between the herein
described Lot and Lot No. 52, as aforesaid, to a stake; thence along the dividing line between the
herein described Lot and Lot No. 45 on the hereinafter mentioned Plan of Lots. North forty-six (46)
degrees zero (00) minutes West, a distance of sixty-four (64.0) feet to a stake; thence along the
dividing line between the herein described Lot and Lot No. 50 on the hereinafter mentioned Plan of
Lots. North forty-four (44) degrees zero (00) minutes East, a distance of one hundred ten (110.0)
feet to a stake, the place of BEGINNING.
BEING Lot No. 81 on Plan of Louis Park, recorded in Plan Book 5, page 50.
HAVING THEREON ERECTED a one story frame dwelling house known as 51 Oliver Road.
BEING Tax Parcel # 09-13-3993-046.
TITLE TO SAID PREMISES IS VESTED IN Brett S. Gorsline, married man by Deed from
Donald T. Custer and Nancy L. Custer, husband and wife dated 11/15/93, recorded 11/16/93, in
Deed Book Q36, page 442.
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PNC BANK, N.A. : CUMBERLAND COUNTY
s COURT OF COMMON PLEAS
s CIVIL DIVISION
vs.
BRETT S. GORSLINE
: NO. 99-6301 CIVIL
AFFIDAVIT PURSUANT TO RULE 3129
(Affidavit No. 1)
PNC BANK, N.A., 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 51 OLIVER ROAD,
ENOLA, PA 17025.
1. Name and address of Owner(s) or reputed Owner(s):
NAME LAST KNOWN ADDRESS (if address
cannot be reasonably ascertained,
please so indicate)
BRETT S. GORSLINE 51 OLIVER ROAD
ENOLA, PA 17025
2. Name and address of Defendant(s) in the judgment:
NAME LAST KNOWN ADDRESS (if address
cannot be reasonably ascertained,
please so indicate)
SAME AS ABOVE
3. Name and address of every judgment creditor whose judgment is
a record lien on the real property to be sold:
NAME LAST KNOWN ADDRESS (if address
cannot be reasonably ascertained,
please so indicate)
NONE
4. Name and address of the last recorded holder of every mortgage
of record:
NAME LAST KNOWN ADDRESS (if address
cannot be reasonably ascertained,
please so indicate)
DAUPHIN DEPOSIT HANK P.O. BOX 4800
AND TRUST COMPANY HARRISBURG. PA 17111
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5. Name and address of every other person who has any record lien
on the property:
NAME LAST KNOWN ADDRESS (if address
cannot be reasonably ascertained,
please so indicate)
NONE
6. Name and address of every other person who has any record
interest in the property and whose interest may be affected by
the sale:
NAME LAST KNOWN ADDRESS (if address
cannot be reasonably ascertained,
please so indicate)
NONE
7. Name and address of every other person whom the plaintiff has
knowledge who has any interest in the property which may be
affected by the sale:
NAME LAST KNOWN ADDRESS (if address
cannot be reasonably ascertained,
please so indicate)
NICOLE J. OORSLINE 10 WEST HEALE AVENUE
APT, D
ENOLA, PA 17025
TENANT/OCCUPANT
DOMESTIC RELATIONS OF
CUMBERLAND COUNTY
51 OLIVER ROAD
ENOLA. PA 17025
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.
December 2, 1999
DATE F K FEDERMA , 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
PNC BANK, N.A.
vs.
BRETT S. GORSLINE
ATTORNEY FOR PLAINTIFF
s CUMBERLAND COUNTY
s COURT OF COMMON PLEAS
s CIVIL DIVISION
s
s NO. 99-6301 CIVIL
CERTIFICATION
FRANK FEDERMAN, ESQUIRE, hereby verifies that he is
attorney for the Plaintiff in the above-captioned matter, and that
the premises are not subject to the provisions of Act 91
because it is:
( ) an FHA mortgage
( ) non-owner occupied
( ) vacant
(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.
Mc ?-
F K FEDER , ESQUIRE
Attorney for Plaintiff
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PNC BANK, N.A. : CUMBERLAND COUNTY
s COURT OF COMMON PLEAS
va. s CIVIL DIVISION
BRETT S. GORSLINE
NO. 99-6301 CIVIL
NOTICE OF SHERIFF'S SALE OF REAL PROPERTY
December 2, 1999
TOs BRETT S. GORSLINE
51 OLIVER ROAD
ENOLA, PA 17025
"*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 51 OLIVER ROAD, ENOLA, PA 17025,
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
$66,806.69 obtained by PNC BANK, N.A. (the mortgagee) against you.
If the sale is postponed, the property will be relisted for the
JUNE 7. 1999 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.)
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 THAT CERTAIN piece or parcel of land situate in East Pennsboro Township, Cumberland
County, Pennsylvania. more particularly bounded and described in accordance with a survey by
Michael C. D'Angelo, Registered Surveyor, dated March 26, 1975, as follows. to wit:
BEGINNING at a stake along the Westerly line of Oliver Road, which stake is one hundred ffty-
ehyht and ninety-six hundredths (153.96) feet Southeast of the Southeast corner of the intersection of
Louis Lane and Oliver Road; thence South forty-six (46) degrees zero (00) minutes East, a distance
of sixty-four (64.0) feet to a stake at the dividing line between the herein described Lot and Lot No.
52 on the hereinafter mentioned Plan of Lots; thence South forty-four (44) degrees zero (00) minutes
West, a distance of one hundred ten (110.0) feet along the dividing line between the herein
described Lot and Lot No. 53, as aforesaid, to a stake; thence along the dividing line between the
herein described Lot and Lot No. 45 on the hereinafter mentioned Plan of Lots. North f n-v-six (46)
degrees zero (00) minutes West, a distance of sixty-four (64.0) feet to a stake; thence along the
dividing line between the herein described Lot and Lot No. 50 on the hereinafter mentioned Plan of
Lots, North forty-four (44) degrees zero (00) minutes East, a distance of one hundred ten ( 110.0)
feet to a stake, the place of BEGINNING.
BEING Lot No. 81 on Plan of Louis Park, recorded in Plan Book 5, page 50.
HAVING THEREON ERECTED a one storv frame dwellin, house known as 51 Oliver Road.
BEING Tax Parcel R 09-12-3992.046.
TITLE TO SAID PREMISES IS VESTED IN Brett S. Gorsline, married man by Deed from
Donald T. Custer and Nancy L. Custer, husband and wife dated 11/15/93, recorded 11/16193, in
Deed Book Q36, page 442.
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DESCRIPTION
ALL THAT CERTAIN piece or parcel of land situate in East Pennsboro Township, Cumberland
County, Pennsylvania, more particularly bounded and described in accordance with a survey by
Michael C. D'Angelo, Registered Surveyor, dated March 26, 1975, as follows, to wit:
BEGINNING at a stake along the Westerly line of Oliver Road, which stake is one hundred fifty-
eight and ninety-six hundredths (158.96) feet Southeast of the Southeast corner of the intersection of
Louis Lane and Oliver Road; thence South forty-six (46) degrees zero (00) minutes East, a distance
of sixty-four (64.0) feet to a stake at the dividing line between the herein described Lot and Lot No.
52 on the hereinafter mentioned Plan of Lots; thence South forty-four (44) degrees zero (00) minutes
West, a distance of one hundred ten (110.0) feet along the dividing line between the herein
described Lot and Lot No. 52, as aforesaid, to a stake; thence along the dividing line between the
herein described Lot and Lot No. 45 on the hereinafter mentioned Plan of Lots. North ferry-six (46)
degrees zero (00) minutes West, a distance of sixty-four (64.0) feet to a stake; thence along the
dividing line between the herein described Lot and Lot No. 50 on the hereinafter mentioned Plan of
Lots, North forty-four (44) degrees zero (00) minutes East, a distance of one hundred ten ( 110.0)
feet to a stake, the place of BEGINNING.
BEING Lot No. 81 on Plan of Louis Park, recorded in Plan Book 5, pa:;e 50.
HAVING THEREON ERECTED a one story frame dwelling house known as 51 Oliver Road.
BEING Tax Parcel h 09-12-2992-046.
TITLE TO SAID PREMISES IS VESTED IN Brett S. Gorsline, married man by Deed from
Donald T. Custer and Nancy L. Custer, husband and wife dated 11/15/93, recorded 11/16/93, in
Deed Book Q36, page 442.
STATE OF PENNSYLVANIA,
COUNTY OF CUMBERLAND ?'
Robert P Ziegler
I? ---------------------------- ------ ------- --------------------------
Deeds in and for said County and State do hereby certify that the Sheriffs Deed in which _____
Federal National Mortgn?e Aseociation_
Recorder of
_ 6 the grantee
the same having been sold to said grantee on the --------- lot ___________________ day of
-----March ---------------------------- A. D.,>t-2000_, under and by virtue of a writ______________
-----Execution -------------------------------------- issued onthe----- th_
day of _ D€ SAUr_______________ A. D., 1999___, out of the Court of Comman Pleas of said County as of
Civil
Number__b3RL-------- atthe suit of____PNC Bank N A
Term, 19-i2---
----------------------------------- against ---Brgtt_ S_Cortaling----------------------------- is
duly recorded in Sheriffs Deed Book No. _-L ------- Page 1049-------
IN TESTII110NY WHEREOF, I have hereunto
set my hand and seal of said office this day
of ____-!/ c --------- A. 100,19-125t.C e
of Deeds
beseJwslflsM,daMMlpa ffttM PA
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PNC Bank N.A.
.vs.
Brett S. Gorsline
In the Court of Common Pleas of
Cumberland County, Pennsylvania
No. 99-6301 Civil
Shawn Harrison Deputy Sheirff, who being duly swom according to law, says on
January 4, 2000 at 6:16 o'clock P.M. EDST, he posted a copy of Real Estate Writ Notice
Poster and Description on the property of Brett S.Gorslinc located at 51 Oliver Road,
Enola, Cumberland County, Pennsylvania according to law.
Shaw Harrison Deputy Sheirff, who being duly sworn according to law, says on
January 4, 2000 at 6:16 o'clock P.M. EDST, he served a true copy of Real Estate Writ
Notice Poster and Description in the above entitled action upon the within named
defendant to wit: Brett S. Gorsline, by handing to Brett Gorsline at 51 Oliver Road,
Enola, Cumberland County, Pennsylvania, its contents and at the same time handing to
him personally the said true and attested copies of the same.
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 within named defendant to
wit: Brett S.Gorsline by regular mail to his last known address 51 Oliver Road, Enolo,
Pennsylvania. This letter was mailed under the date of January 5, 2000 and never
returned to the Sheriffs Office.
R. Thomas Kline, Sheirff, who being duly sworn according to law, says that after due
and legal notice had been given according to law exposed the above described premise at
public venue or outcry at Courthouse Carlisle, Cumberland County, Pennsylvania on
March I, 2000 at 10:00 o'clock A.M. EST and sold the same to Dale Shughart, Jr. for
Federal National Mortgage Association. It being the highest bid and best price quoted for
the same Federal National Mortgage Association of 1900 Market Street, Suite 800,
Philadelphia, PA paid to Sheriff R. Thomas Kline the sum of S 879.13 it being costs.
Sheri ffs Costs:
Docketing 30.00
Poundage 17.24
Advertising 15.00
Posting Bills 15.00
Acknowledging Deed 30.00
Auctioneer 10.00
Law Library .50
County 1.00
Mileage 9.92
Certified Mail .84
Levy 15.00
Surcharge 16.00
Law Journal 353.75
Patriot News 288.30
Share of Bills 25.08
Distribution of Proceeds 25.00
Sheriff's Deed
26 .50
$ 879.13 Pd by Atty
03/17/00
Sworn and Subscribed To Before Me Son This AU _ Day of T
R. Thomas Kline, Sheriff
2000, A.D. `
ro onotary By.
Real Estate Deputy
Off' o
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. g3hy1
PNC BANK, N.A.
: CUMBERLAND COUNTY
: COURT OF COMMON PLEAS
: CIVIL DIVISION
vs.
BRETT S. GORSLINE
: NO. 99-6301 CIVIL
AFFIDAVIT PURSUANT TO RULE 3129
(Affidavit No. 1)
PNC BANK, N.A., 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 51 OLIVER ROAD,
ENOLA, PA 17025.
1. Name and address of Owner(s) or reputed Owner(s):
NAME LAST KNOWN ADDRESS (if address
cannot be reasonably ascertained,
please so indicate)
BRETT S. GORSLINE 51 OLIVER ROAD
ENOLA, PA 17025
2. Name and address of Defendant(s) in the judgment:
NAME LAST KNOWN ADDRESS (if address
cannot be reasonably ascertained,
please so indicate)
SAME AS ABOVE
3. Name and address of every judgment creditor whose judgment is
a record lien on the real property to be sold:
NAME LAST KNOWN ADDRESS (if address
cannot be reasonably ascertained,
please so indicate)
NONE
4. Name and address of the last recorded holder of every mortgage
of record:
NAME LAST KNOWN ADDRESS (if address
cannot be reasonably ascertained,
please so indicate)
DAUPHIN DEPOSIT BANK P.O. BOX 4800
AND TRUST COMPANY HARRISBURG. PA 17.111
J
S. Name and address of every other person who has any record lien
on the property:
NAME LAST KNOWN ADDRESS (if address
cannot be reasonably ascertained,
please so indicate)
NONE
6. Name and address of every other person who has any record
interest in the property and whose interest may be affected by
the sale:
NAME LAST KNOWN ADDRESS (if address
cannot be reasonably ascertained,
please so indicate)
NONE
7. Name and address of every other person whom the plaintiff has
knowledge who has any interest in the property which may be
affected by the sale:
NAME LAST KNOWN ADDRESS (if address
cannot be reasonably ascertained,
please so indicate)
NICOLE J. GORSLINE 10 WEST BEALE AVENUE
APT. D
ENOLA, PA 17025
TENANT/OCCUPANT
DOMESTIC RELATIONS OF
CUMBERLAND COUNTY
51 OLIVER ROAD
ENOLA. PA 17025
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.
December 2, 1999
DATE F NK FEDER , ESQUIRE
At,0rney for Plaintiff
i
PNC BANK, N.A.
V8.
BRETT S. GORSLINE
CUMBERLAND COUNTY
COURT OF COMMON PLEAS
CIVIL DIVISION
NO. 99-6301 CIVIL
NOTICE OF SHERIFF'S SALE OF REAL PROPERTY
December 2, 1999
TO: BRETT S. GORSLINE
51 OLIVER ROAD
ENOLA, PA 17025
*"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 51 OLIVER ROAD, ENOLA, PA 17025,
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
$66,806.69 obtained by PNC BANK. N.A. (the mortgagee) against you.
If the sale is postponed, the property will be relisted for the
JUNE 7. 1999 Sheriff's Sale.
NOTICE OF OWNER'S RIGHTS
YOU MAY BE ABLE TO PREVENT THIS SHERIFF'S SALE
To prevent this Sheriff's Sale, you must take immediate
action:
1. The sale will be cancelled if you pay to the mortgagee
the back payments, late charges, costs and reasonable
attorney's fees due. To find out how much you must pay,
you may call: (215) 563-7000.
2. You may be able to stop the sale by filing a petition
asking the Court to strike or open the judgment, if the
judgment was improperly entered. You may also ask the
Court to postpone the sale for good cause.
3. You may also be able to stop the sale through other legal
proceedings.
i
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
i
DESCRIPTION
ALL THAT CERTAIN piece or parcel of land situate in East Permsboro Township, Cumberland
County, Pennsylvania, more particularly bounded and described in accordance with a survey by
Michael C. D'Angelo, Registered Surveyor, dated March 36, 1975, as follows, to wit:
BEGINNING at a stake along the Westerly line of Oliver Road, which stake is one hundred fifty-
eight and ninety-six hundredths (158.96) feet Southeast of the Southeast corner of the intersection of
Louis Lane and Oliver Road; thence South forty-six (46) degrees zero (00) minutes East. a distance
of sixty-four (64.0) feet to a stake at the dividing line between the herein described Lot and Lot No.
52 on the hereinafter mentioned Plan of Lots; thence South forty-four (44) degrees zero (00) minutes
West, a distance of one hundred ten (110.0) feet along the dividing line between the herein
described Lot and Lot No. 52, as aforesaid, to a stake; thence alone the dividine line between the
herein described Lot and Lot No. 45 on the hereinafter mentioned Plan of Lots. North Nr:v-si:t (46)
degrees zero (00) minutes West, a distance of sixty-four (64.0) feet to a stake; thence alone, the
dividing line between the herein described Lot and Lot No. 50 on the hereinafter mentioned Plan of
Lots, North forty-four (44) degrees zero (00) minutes East, a distance of one hundred ten (110.0)
feet to a stake, the place of BEGINNING.
BEING Lot No. 81 on Plan of Louis Park. recorded in Plan Book 5. pate 50.
HAVING THEREON ERECTED a one storv frame dwellin; house known as 51 Oliver Road.
BEING Tax Parcel ., 09-12-2992-046.
TITLE TO SAID PREMISES IS VESTED IN Brett S. Gorsline, married man by Deed from
Donald T. Custer and Nancy L. Custer, husband and wife dated 11115/93, recorded 11/16/93, In
Deed Book Q36, page 413.
1
WRIT OF EXECUTION and/or ATTACHMENT
COMMONWEALTH OF PENNSYLVANIA) NO. 99-6301 CIVIL iP?'erm
COUNTY OF CUMBERLAND) CIVIL ACTION . LAW
TO THE SHERIFF OF Cumberland COUNTY:
To satisfy the debt, interest and costs due -PW Dank N A
PLAINTIFF(S)
from nratt S Corsline, 51 rnivnr Rnnrl, Fnnln, PA 17n25
DEFENDANT(S)
(1) You are directed to levy upon the property of the defendant(s) and to sell- See legal description
(2) You are also directed to allach the property of the defendant(s) not levied upon In the possession of
GARNISHEE(S) as follows:
and to notify the gamishee(s) that: (a) in 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 defendani(s) not levied upon an subject to attachment is found in the possession of anyone other
than a named garnishee, you are directed to notify hinvherthat he/she has been added as agarnishee and Is enjoined as above
slated.
Amount Due $66,806.69 from 11/24/99 to 3/1/00
Interest -$1rOG§r06 Due Prothy,
Ally's Comm °/Y Other Costs
Ally Paid S107.3Q
Plaintiff Paid
Date: Decertbgr 7, 1999 Curtis R. Long
Prothonotary, Civil Division
Deputy
REQUESTING PARTY:
Name Frank Federman Esq.
7W0 Penn Center Plaza
Address: 8irte yag
Philadelphia, PA 19102
Attorneyfor: Plaintiff
Telephone: 215-563-7000
Supreme Court ID No. 12248
REAL ESTATE SALE Nfli
1199 the sheriii 10 led cpca the dEi "?
Oil 1Y
interest in the real property situated in ?°
Cumberland County, Pa., known and numborcd as: sLsP
--- and more fully doacrip;:d on Ullbit "A" flied VJ-li"
tills writ and by this reieronce incorporated herein.
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THE PATRIOT NEWS
THE SUNDAY PATRIOT NEWS
Proof of Publication
Under Rel No. S27. Rnproued Mau 16.1929
Commonwealth of Pennsylvania, County of Dauphin} as
Frank J. Epler being duly sworn according to low, 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 41h, 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 editioneAssues 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 Patdot•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
COPY
SALE018
aFJ?i.tLaTA7al?ue as le
Will NtA 10 I7t11
„-. ?.<, PIIO Mn14 Ma. ,
tiMt 8.0oralkn
Airy Funk FetArmrt
DUCKII' +
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Notadal Seal
Tony L. nussell. Notary Public
Hamsburg. DaupNn County
My Comrtnwon Espues June 6.2M
this 25th
PUBLIC
Member. Pennsytvania Assoclatanof NotMr commission expires June 6, 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 $ 286.80
Probating same Notary Fee(s) $ 1.50
Total $ 288.30
heras Receipt for Advertising Cost
• of THE PATRIOT-NEWS and THE SUNDAY PATRIOT-NEWS, newspapers of general
elpt of the aforesaid notice and publication costs and certifies that the same have
THE PATRIOT-NEWS CO.
of
on
to a
10111110
Puad,
to a SUM
kNern the
, so
the
LoL, on Nadt
nioutes Fisk
1U) led to a
1 Louis Park,
) a one stay
as kt Olncr
i IS TESTED M
nnryby Detd fromqq
197 recordedtll
By ....................................................................
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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
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.
RZAL RSTAT6 SALE NO. 10
Writ No. 09.6301 Civil
PNC Bank, N.A.
VS.
Brett S. Gorshne
Ally.: Frank Federman
DESCRUMON
ALL THAT CERTAIN piece or par-
cot of land situate in East Pennsboro
Township, Cumberland County. Ponn-
syh^rma, more particularly bounded
and described in accordance with a
survey by Michael C. D'Angelo, Reg-
MUM Surveyor, dated March 26,
1075, as follows, to wit:
BEGINNING at a stake along the
westerly line of Oliver Road, which
stake is one hundred allyetghl and
ninelyslx hundred(hs (156.96) feet
Southeast of theSoulticast corner of
the Intersection of Louis Lnne and
Oliver Road: thence South fonysu
(46) degrees zero (00) minutes East,
a distance of sixty-four (64.0) feet to
a stake at the dividing line between
the herein described Lot and Lot No.
52 on the hereinafter mentioned Plan
of Lots; thence South forty-four (44)
degrees zero (00) minutes West, a
distance or one hundred ten (110.0)
feel along lilt dh9dhnn, Into between
the herein described Lot and Lot No.
52, as aforesaid, to a stake: thence
along ate dividing line between the
herein described Lot and tat No. 45
on llle hereinafter mentioned Plan of
Lots. Norlh forty-six (46) degrees zero
(00) minutes West, a distance of
sixty-four (64.0) feet to n stake;
thence along the dividing lute between
the herein described Lot and Lot No.
50 on the hereinafter mentioned Plan
of Lots. North forty-four (44) degrees
zero (00) minutes East, a distance of
one hundred ten (110.0) feet 10 n
stake, the place of IEGINNING.
Roger M. Morgenthal, Editor
SWORN TO AND SUBSCRIBED before me this
_L _day of FEBRUARY. 2000
WiS E, SNtbER, Nomory Ibbric
Cariid• Scio, Cumbwtond County, PA
My Comm.,uon E.p?e, Monk 5 :Oat
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,
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 arc true.
IRRAL nTATZ ¦MZ No. IS
Wtil No. 00.6301 Civil
PNC Bank, N.A.
Vs.
Brett S. Goniline
Atty.: Frank Federman
DESCRIPTION
ALL THAT CERTAIN piece or par.
cel of land situate in East Pennsbwro
Township, Cumberland County. Penn.
syhanla. more particularly bounded
and described In accordance with a
survey by Michael C. D'Angelo, Reg-
Istered Surveyor, dated March 26,
1975, as follows, to wit:
BEGINNING at a stake along the
Westerly line of Oliver Road, which
stake to one hundred fifty-eight and
ninety-six hundredths (158.96) feet
Southeast of the Southeast corner of
the Intersection of Louis Lane and
Oliver Road: thence South forty-six
(46) degrees zero (00) minutes East.
a distance of sixty-four (84.0) feet to
a stake at the dividing line between
the herein described Lot and Lot No.
52 on the heremaller mentioned Plan
of Lots; thence South forty-four (44)
degrees zero (00) minutes West, a
distance of one hundred ten (110.0)
feel along the dividing, line between
the herein described Lot and Lot No.
52, as aforesaid, to a stake; thence
along the dividing line between the
herein described lot and Lot No. 45
on the hereinafter mentioned Plan of
Lots. North forty-six (46) degrees zero
(00) minutes West, a distance of
sixty-four (64.0) feel to a stake;
thence along the dividing line between
the herein described Lot and Lot No.
50 on the hereinafter mentioned Plan
of Lots, North forty-four (44) degrees
zem (00) minutes East, a distance of
one hundred ten (110.0) feel to a
stake, the place of BEGINNING.
BEING Lot No. 81 on Plan of Louis
Park, recorded in Man Book 5, page
50,
HAVING TnEREON ERECTED a
one story frame dwelling (rouse
known as 51 Oliver Road.
BEING Tax Parcel N00.12.2992-
046.
;r TITLE TO SAID PREMISES IS
VESTED IN Brell S. Gorsline, mar-
tied man by Deed from Donald T.
Custer amt Nancy L. Custer, husWuml
and wife dated 11/15/63. recorded
11/16/93, lit Deed [look 936, page
442.
Roger M. Morgenthal, Editor
SWORN TO AND SUBSCRIBED before me this
-4-day of FEBRUARY. 2000
IONS E. SNYDER. Nolory Public
Carlisle 60ro, Cumberlond County, PA
My Commirwon Efpir01 March 5, 2001
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RE 14-L ESTATE S. U - E NO 18
51,000.00 Ad,.ance Cos'sPaid 12/13/99 qr Frank Federman
Assessed Valuation S 4960.00
WRJTN099-6301 Civil
PNC Bank, N.A.
VS
Brett S. Goraline
51 Oliver Road
Enola, PA
REAL DEBT
NrHPEST 11/24/99-3/1/00
ATT'S FEES
IMT COSTS ?.TTY
ESCROW
LATE C1L;RGE _
SHELTH'S COSTS
Docke:ine
Poundase
Posing Bills
Adse:,isine
Acknowled¢inst Deed
Auctiereer
Law Library
Count:
Milea:e
Cea %fail
Le%ti•
Posrgone Sale
Surcharge
Le:zal Search
Lwx Journal
Patrol
Share of Bills
Distribution of Proce:as
She:afi's Deeds
STAMPS
Pa. Transfer Tae
Tup or Boro Transfer Tax
TA YES
$ 66,806.69
1,06.5.06
107.30
30.00
17.24
15.00
15.00
30.00
10.00
.50
1.00
9.92
.84
15.00
16.00
353.75
288.30
25.08
25.00
26.50
1