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MARK J. UDREN & ASSOCIATES
BY: Mark J. Udren, Esquire
ATTY I.D. NO. 04302
1040 N. KINGS HIGHWAY, SUITE 500
CHERRY HILL, NJ 08034
609-482-6900
ATTORNEY FOR PLAINTIFF
United Companies Lending :COURT OF COMMON PLEAS
Corporation CIVIL DIVISION
P.O. Box 1591 ;Cumberland County
Baton Rouge, LA 70821-1591
Plaintiff
V.
David M. Kyler
a/k/a David Merle Kyler
Lisa A. Kyler
118 Hogestown Road
Mechanicsburg, PA 17055
Defendant(s)
• NO.
wry-- ?3??
ai?L
COMPLAINT IN MORTGAGE FORECLOSURE
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.
LAWYERS REFERRAL SERVICE
Cumberland County Bar Association
2 Library Avenue
Carlisle, PA 17013-3387
(717) 249-3166 or (800) 990-9108
AVISO
Le han demandado a usted en la corte. Si usted quiere defenderse
de estas demandas expuestas en las paginas siguientes, usted tiene
veinte (20) dias de plazo al partir de la fecha de la demanda y la
notificacion. Hace falta ascentar una comparencia escrita o en
persona o con un abogado y entregar a la corte en forma escrita sus
defensas o sus objeciones a las demandas en contra de su persona.
Sea avisado que si usted no se dafiende, la corte tomara medidas y
puede continuar la demanda en contra suya sin previo aviso 0
notificacion. Ademas, la corte puede decidir a favor del
demandante y requiere que usted cumpla con todas las provisiones de
esta demanda. Usted puede perder dinero o sus propiedades u otros
_. -derechos importantes para usted.
LLEVE ESTA DEMANDA A UN ABOGADO IbMEDIATAMENTE, SI NO TIENE ABOGADO
0 SI NO TIENE EL DINERO SUFICIENTE DE PAGAR TAL SERVICIO, VAYA EN
PERSONA 0 LLAME POR TELEFONO A LA OFICINA CUYA DIRECCION SE
ENCUENTRA ESCRITA ABAJO PARA AVERIGUAR DONDE SE PUEDE CONSEGUIR
ASISTENCIA LEGAL.
Cumberland County Bar Association
2 Library Avenue
Carlisle, PA 17013-3387
(717) 249-3166 or (800) 990-9108
NOTICE
The amount of your debt is as stated in the attached document. The name of the creditor
to whom the debt is owed is as named in the attached document. Unless you notify us within
30 days after receipt of this Notice and the attached document that the validity of the stated
debt, or any portion of it, is disputed, we will assume that the debt is valid. If you do notify us
in writing of a dispute within the 30 day period, we will obtain verification of the debt or a
copy of a judgment against you, and mail it to you. If you do not dispute the debt, It is not an
admission of liability on your part. Also, upon your written request within the 30 day period,
we will provide you with the name and address of the original creditor if different from the
current creditor.
If you notify us in writing within the 30 day period as stated above, we will cease collection
of your debt, or any disputed portion of it, until we obtain the information that is required
and mail it to you. Once we have mailed to you the required information, we will then
continue the collection of your debt.
This law firm is deemed to be a debt collector and this Notice and the attached document is
an attempt to collect a debt, and any information obtained will be used for that purpose.
LAW OFFICES OF MARK J. UDREN
/s/ Mark J. Udren, Esquire
1040 N. Kings Highway, Suite 500
Cherry Hill, NJ 08034
(609) 482-6900
1. Plaintiff is the Corporation designated as such in the
caption on a preceding page. If Plaintiff is an assignee then it
is such by virtue of the following recorded assignments:
Assignor: United Companies Lending Corporation
Assignee: Bankers Trust Companies of California, N.A.
Recording Date: 1/26/98 Book: 567 Page: 278
Assignor: Bankers Trust Companies of California, N.A.
Assignee: United Companies Lending Corporation
Recording Date: Lodged for Recording:
- -_2. Defendant(s) is the individual designated as such on the
caption on a preceding page, whose last known address is as set
'forth in the caption, and unless designated otherwise, is the real
owner(s) and mortgagor(s) of the premises being foreclosed.
3. On or about the date appearing on the Mortgage
hereinafter described, at the instance and request of Defendant(s),
Plaintiff (or its predecessor, hereinafter called Plaintiff) loaned
to the Defendant(s) the sum appearing on said Mortgage, which
Mortgage was executed and delivered to Plaintiff as security for
the indebtedness. Said Mortgage is incorporated herein by
reference in accordance with Pa.R.C.P. 1019 (g).
The information regarding the Mortgage being foreclosed is as
follows:
MORTGAGED PREMISES: 118 Hogestown Road
MUNICIPALITY/TOWNSHIP/BOROUGH: City of Mechanicsburg
COUNTY: Cumberland
DATE EXECUTED: 12/12/96
DATE RECORDED: 12/20/96 BOOK: 1357 PAGE: 242
The legal description of the mortgaged premises is attached hereto
and made part hereof.
4. Said Mortgage is in default because the required payments
have not been made as set forth below, and by its terms, upon
breach and failure to cure said breach after notice, all sums
secured by said Mortgage, together with other charges authorized by
said Mortgage itemized below, shall be immediately due.
5. After demand, the Defendant(s) continues to fail or
refuses to comply with the terms of the Note as follows:
(a) by failing or refusing to pay the installments of
principal and interest when due in the amounts indicated
.. _..... ._ ._ _.below; ._ ..
(b) by failing or refusing to pay other charges, if any,
indicated below.
6. The following amounts are due on the said Mortgage as of
10/8/99:
Principal of debt due and unpaid $40,467.62
Interest at 13.50V
from 8/1/98
to 10/8/99
(the per diem interest accruing on
this debt is $14.97 and that sum
should be added each day after
10/8/99) 6,493.39
Title Report 250.00
Court Costs (anticipated, excluding
Sheriff's Sale costs) 280.00
Escrow Overdraft/(Balance)
(The monthly escrow on this account
is $0.00 and that sum should
be added on the first of each
month after 10/8/99) 0.00
Late Charges
(monthly late charge of $0.00
should be added on the fifteenth of
each month after 10/8/99) 0.00
Other Fees 95.96
Attorneys Fees (anticipated and actual
to SV of principal) 2,023.38
TOTAL $49,610.35
7. The attorney's fee set forth above are in conformity
with the mortgage documents and Pennsylvania law, and will be
collected in the event of a third party purchaser at Sheriff's
Sale. If the mortgage is reinstated prior to the sale, reasonable
attorney's fees will be charged in accordance with the reduction
provisions of Act 6, if applicable.
8. The combined notice specified by the Pennsylvania
Homeowner's Emergency Mortgage Assistance Program, Act 91 of_1983
and Notice of Intention to Foreclose under Act 6 of 1974 has been
sent to each defendant, via certified and regular mail, accordance
with the requirements of those acts, and the date appearing on the
copy attached hereto as exhibit A, and made part hereof, and
defendants have failed to proceed within the time limits, or has
been determined ineligible, or Plaintiff has not been notified in
a timely manner of Defendant(s) eligibility.
WHEREFORE, the Plaintiff demands judgment, in rem, against
the Defendant(s) herein in the sum of $49,610.35, plus interest,
costs and attorneys fees as more fully set forth in the Complaint,
and for foreclosure and sale of the Mortgaged premises.
Mark J. Udren, ESQUIRE
MARK J. UDREN & ASSOCIATES
Attorney for Plaintiff
Attorney I.D. No. 04302
SCHEDULE C
PROPERTY DESCRIPTION
The la:::l referred to in this Commitment is described as follows:
ALL that certain piece or parcel of land situate in the Township of
Silver Spring, ;County of Cumberland land State of Pennsylvania,
bounded and described as follows, to wit:
BEGINNING at a point in the center of the Hogestown Road; thence by
land now or formerly of Lloyd Doner, North 35 degrees 45 minutes
East, ..060'.95 feet to a pin on line of land now or formerly of
Wilbur II. Ward; thence along lands now or formerly of said Ward,
South 55 degrees (erroneously set forth in prior deed as 65
degrees) East, 102.65 feet to a pin in corner of lot now or
formerly of William B. Kaley and Elsie 1. Kaley, his wife; thence
along said land of William B. Y,aley and Elise I. Kaley, his wife,
South 35 degrees 45 minutes West, 1060.95 feet to a point in the
center of the Hogestown Road; thence along the center of said,
North 55 degrees West, 102.65 feet to a point in the center of said
Road, the place of BEGINNING. CONTAINING 2.5 acres and having
thereon erected a mobile home known and numbered as 118 Hogestown
Road, Mechanicsburg, Pennsylvania.
Being the same premises which became vested in David Merld Kyler
and Lisa A. Kyler.by deed from Sandy K. Rhoades dated December
18,1993 and recorded December 20,1993 in Record Book S 36, Page 108.
I
September 2, 1999
DATE:
ACT 91 NOTICE
TAKE ACTION TO SAVE
YOUR HOME FROM
FORECLOSURE
This Is-an-official. notice_that_the.mortgage_on.your.home is.in.defoult?andtbe_lender
intends_toloreclose._Speciric_information_aboutthe.nature .otthe_defaulLi&proAdedJsLthe
attached-pages.
The_HOMEOIVNER'S MORTGAGE ASSISTANCE_PROGRAIL(HEMAP).may_he.able
to_help..to_save.your.home. This Notice-explains-how-the. program works.
TD-see if H .NIAP an.help,you must.NIEET_NV1TH-A-rONSUIIERCREDiT
COUNSELING.AGErICY}Y1THIiY3A?A]CS_OFTHE_ DATROETHISNOTICE. Take
this Notice-with-you when you meet_with.the Counseling Agency.
The-tame,-address-and-phone. number. of_Consumer Credit_CounselingAgencies serving
ur-County_are.listed.at the end ofthis.Notice.._Ifyou.have_any_questions,.you.may_callthe
nnsylvania.Housing- FInance_Agency_toll.free- at_1-800-342-239.7..(Persons-with impaired
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 SUMA INIPORTANCIA, PUES AFECTA SU
DERECHO A CONTINUAR VIVIENDO EN SU CASA. SI NO COMPRENDE EL
CONTENDO DE ESTA NOTIFICACION OBTENGA UNA TRADUCCIOiy
INNIEDITAINIENTE LLAMANDO 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.
Page of6 FXHInITA
HOMEOWNER'S NA.SIE(S): AV1D31-KYLER.
_-LISAA. KYLER _
PROPERTY ADDRESS: ___ _ 118IIOGESTOWiY RD.___. _-__.._
_. ..... 1ECILVNICSBURG,PA12055_ _
LOAN ACCT. NO.: .-34401051859-
ORIGINAL LENDER: -
-UNITED-COMPANIES-LENDING-CORP.-CURRENT LENDER: . __UNITED.COAIPANIESLENDIMG_CORP-
HOMEOWNER'S EMERGENCY MORTGAGE ASSISTANCE PROGRAM
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.
TEMPORARYSTAY OF FORECLOSURE - Under the Act, you are entitled to a temporary stay
of foreclosure on your mortgage for thirty (30) days from the date of this Notice. During that time
you must arrange and attend a "face-to-face" meeting with one of the consumer credit counseling
agencies listed at the end df this Notice. THIS_MEETINGIlIUSZOCCUR- IY THIN1'HE
CONSUMER_CREDIT_CO.UNSELINGAGENCIES - If you meet with one of the consumer
credit counseling agencies listed at the end of this notice, the lender may NOT take action against
you for thirty (30) days after the date of this meeting. The.names, addresses and telephone numbers
of designated consumer credit counseling agencies for the county in_which.the property_is.located
are-set-forth-at-the-end-of this_Notice. It is only necessary to schedule one face-to-face Ineeting.
Advise your lender immediately of your intentions.
APPLICATION_FORIVIORTGAGE_ASSISTANCE - Your mortgage is in default for the
reasons set forth later in this Notice (see following pages for specific information about the nature
of your default.) If you have tried and are unable to resolve this problem with the lender, you have
the right to apply for financial assistance from the Homeowner's Emergency Mortgage Assistance
Program. To do so, you must till out , sign and tile a completed Homeowner's Emergency
Assistance Program Application with one of the designated consumer credit counseling agencies
listed at the end of this Notice. Only consumer credit counseling agencies ha% c applications for the
program and they will assist you in submitting a complete application to the Pennsylvania Housing
Finance Agency. Your application MUST be filed or postmarked within thirty (30) days of your
face-to-face meeting.
YOU MUST FILE YOUR APPLICATION PROMPTLN. IF YOU FAIL TO DO SO OR IF YOU
DO NOT FOLLOW THE OTHER TIME PERIODS SET FORTH IN THIS LETTER,
FORECLOSURE MAY PROCEED AGAINST YOUR HOME IMMEDIATELY AND YOUR
APPLICATION FOR MORTGAGE ASSISTANCE WILL BE DENIED.
Page 2 of 6
AGENCYACTION - Available funds for emergency mortgage assistance are very limited. They will
be disbursed by the Agency under the eligibility criteria established by the Act. 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 be pursued against you if you have met the time requirements set forth
above. You will be notified directly by the Pennsylvania Housing Finance Agency of its decision on your
application.
NOTE: IF YOU ARE CURRENTLY PROTECTED BY THE FILING OF A PETITION IN
BANKRUPTCY, THE FOLLOWING PART OF THIS NOTICE IS FOR INFORMATION
PURPOSES ONLY AND SHOULD NOT BE CONSIDERED AS AN ATTEMPT TO
COLLECT THE DEBT.
(If you have filed bankruptcy you can still apply for Emergency Mortgage Assistance.)
ILO-W-MO_CME-YOURAORTGAGE DEFAULT_(Bring-it.up to date).
NATURE-OF-UIE-DEFAULT - The MORTGAGE debt hel by the above lender on your property located
at: .118 Hogestown Road-------------_ -
Mechaniesburg,PA.17055
IS SERIOUSLY IN DEFAULT because:
A. YOU HAVE NOT MADE MONTHLY MORTGAGE PAYMENTS for the following months and the
following amounts are now past due:
-Monthly Payments ot$545.29 for_September,.1998 through September,1999 = 57,088.77_
Other charges (explain/itemize):.__-_N!A
TOTAL AiIOUNT PAST DUE: _.._57,088.77_.
B. YOU HAVE FAILED TO TAKE THE FOLLOWING ACTION (Do.not_usc.i£nnt.appikable):
HOW TO-CURE-THE DEFAULT - You may cure the default within THIRTY (30) DAYS of the date of
this notice BY PAYING THE TOTAL A.NOUI T PAST DUE TO THE LENDER. WHICH IS 57.088.77. PLUS
ANY MORTGAGE PAYMENTS AND LATE CHARGES WHICH BECOME DUE DURING THE THIRTY (30)
DAY PERIOD. Payments musrbe madaeither_by cash.casWer:s.chcck..cenified checkormoney_order made.payable
aad.seat to.
_-_.-Mark J..Udren &.Associates--..__ . _
1090.N..Kings Hlghway,Suite.500
Cherry_HiII,NJ_08033 _.._-
You can cum any other default by taking the following action within THIRTY (30) DAYS of the date of
this letter. (Do not.use if not.applicable.)
N/A.
IF YOU DO NOT CURE THE DEFAULT •- If you do not cure the default within THIRTY (30) DAYS
of the date of this Notice, theleader intends to exercise- its.dghts to accelerate-the mortgage-debt. This
means that the entire outstanding balance of this debt will he considered due immediately and you may lose
the chance to pay the mortgage in monthly installments. If full payment of the total amount past due is no)
made within THIRTY (30) DAYS, the lender also intends to instruct its attomeys to start legal action to
foreclose upon your mortgaged property.
Page 3 of 6
IF-THE.MORTGAGE.IS.EO.RECLOSED_UPON - The mortgaged property will be sold by the Sheriff
to pay off the mortgage debt. If the lender refers your case to its attorneys, but you cure the delinquency
before the lender begins legal proceedings against you, you will still be required to pay the reasonable
attorney's fees that were actually incurred, up to $50.00. However, if legal proceedings are started against
you, you will have to pay all reasonable attorney's fees actually incurred by the lender even if they exceed
S50.00. Any attorney's fees will be added to the amount you owe the lender, which may also include other
reasonable costs. ILyou_cure.the defsult.within.the THHtTY (30) DAY. perio& yotuvID_notbe required
to_pay.attorney's-fees.
OTIIERLENDERREMEDIES - The lender may also sue you personally for die unpaid principal balance
and all other sums due under the mortgage. If your debt has been discharged in bankruptcy without your
having reaffirmed it, then lender cannot pursue this remedy.
RIGHT-TO-CURE-THE DEFAULT PRIOR TO SHERIFF'S SALE - If you have not cured the default
within the THIRTY (30) DAY period and foreclosure proceedings have begun, you-still have the-right-to-cure
paying.the.total-amount.then past-due.plus any late orothercharges then due,reasonable anomey'ifees and
costs connected with tkforeclosure sale and any other costs connected with the.5herin-Sale- asspecified
in_writing by-the.lenderand.by_perlormiogany_othcrrequuementsunderthe mortgage. Curing your default
in the manner set forth in this notice will restore your mortgage to the same position as if you had
never defaulted.
EARLIESZPOSSEBLE_SHERIFE'S.SALE.DATE - It is estimated that the earliest date that such a
Sheriffs Sale of the mortgaged property could be held would be approximately-6_ months from
the date,of this Notice. A notice of the actual date of the Sheriffs 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 or action will be by contacting the lender.
HOW-TO CONTACZTHE LENDER:
Name.oflrender/Servicer: _United Compaaies.Lending Corp._
Address:- 8549-United Plaza Blvd.
_____ __-_- -Baton Rouge.LA_7.0809___
Phone Number: __225-9822719_
Fax Number:- __ -2259824228 ____-__ ----.-
ContactPerson:--_. __ Debbie blayeux_-__
EFFECT.OF SHERIFF'S SALE -You should realize that a Sheriffs Sale will end your ownership of the
mortgaged.property and your right to occupy it. If you continue to live in the property after the Sheriffs
Sale, a lawsuit to remove you and your furnishings and other belongings could be started by the lender at
any time.
ASSUMPTION OF MORTGAGE - You _ mayor X . may not (CHECK ONE) sell or transfer your
home to a buyer or transferee whu 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 -quiren:crts
of the mcrtgage are satisfied.
Page 4 of 6
NOTICE
The amount of your debt is as stated in the attached document. The name of the creditor
to whom the debt is owed is as named in the attached document. Unless you notify us within
30 days after receipt of this Notice and the attached document that the validity of the stated
debt, or any portion of it, is disputed, we will assume that the debt is valid. If you do notify us
in writing of a dispute within the 30 day period, we will obtain verification of the debt or a
copy of a judgment against you, and mail it to you. If you do not dispute the debt, it is not an
admission of liability'on your part. Also, upon your written request within the 30 day period,
we will provide you with the name and address of the original creditor If different from the
current creditor.
If you notify us in writing within the 30 day period as stated above, we will cease collection
of your debt, or'any disputed portion of It, until we obtain the Information that is required
and matt it to you. Oncd we have mailed to you the required information, we will then
continue the collection of your debt.
This law firm Is deemed to be a debt collector and this Notice and the attached document Is
an attempt to collect a debt, and any information obtained will be used for that purpose.
LAW OFFICES OF MARK J. UDREN
/s/ Mark J. Udren, Esquire
1040 N. Mugs Highway, Suite 500
Cherry Hill, NJ 08034
(609) 482-6900
v s,v.
Page 5 of 6
YOU11AYALSO_HAVE TILE 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.
• TO HAVE THIS DEFAULT CURED BY ANY THIRD PARTY ACTING ON YOUR BEHALF.
• TO HAVE THE MORTGAGE RESTORED TO THE SAME POSITION AS IF NO DEFAULT
HAD OCCURRED, IF YOU CURE THE DEFAULT. (HOWEVER YOU DO NOT HAVE THIS
RIGHT TO CURE YOUR DEFAULT MORE THAN THREE TIDIES IN ANY CALENDAR
YEAR.)
• TO ASSERT THE NONE?GSTENCE OF A DEFAULT IN ANY FORECLOSURE PROCEEDING
OR ANY OTHER LAWSUIT INSTITUTED UNDER THE MORTGAGE DOCUMENTS,
• TO ASSERT ANY OTHER DEFENSE YOU BELIEVE YOU MAY HAVE TO SUCH ACTION
BY THE LENDER.
• TO SEEK PROTECTION UNDER THE FEDERAL BANKRUPTCY LAW.
CONSUMER C ftEDIT-COUNSELING AGENCIES.SERVIING YOUR-CO.UNTY
(EALin_a.list of_all_Caunseling.Agencies.listed_in Append&-C, FOR THE.000NT.Yinwhich the
, property is located,. using additional pages.ifneeessaty)
CUMBERLAND_COUNIY
CCCS of Western Pennsylvania, Inc.
2000 Linglestown Road
Harrisburg, PA 17102
(717) 541-1757
FAX (717) 5414670
Financial Counseling Services of Franklin
31 West 3rd Street
Waynesboro, PA 17268
(717) 762-3285
Community Action Comm of the Capital Region
1514 Deny Street
Harrisburg, PA 17104
(717) 232-9757
FAX (717) 234-2227
Urban League of Metropolitan Harrisburg
N. 6th Street
Harrisburg, PA 17101
(717) 234-5925
FAX (717) 234.9459
YWCA of Carlisle
301 G Street
Carlisle, PA 17013
(717) 243-3818
FAX (717) 731-9589
Adams County Housing Authority
139-143 Carlisle St.
Gettysburg, PA 17325
(717) 334-1518
FAX (717) 334.8326
Page 6 of 6
V E R I F I C A T I O N
Mark J. Udren, Esquire, hereby states that he is the attorney
for the Plaintiff, a corporation unless designated otherwise; that
he is authorized to take this Verification and does so because of
the exigencies regarding this matter, and because Plaintiff must
verify much of the information through agents, and because he has
------personal knowledge of some of the facts averred in theforegoing
-- - ------
pleading; and that the statements made in the foregoing pleading
are true and correct to the best of his knowledge, information and
belief and the source of his information is public records and
reports of Plaintiff's agents. The undersigned understands that
this statement herein is made subject to the penalties of 18
Pa.C.S. Section 4904 relating to unsworn falsification to
authorities.
Mark J. Udren, ESQUIRE
MARK J. UDREN & ASSOCIATES
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MARK J. UDREN 4 ASSOCIATES ATTORNEY FOR PLAINTIFF
HY: Mark J. Udren, Esquire
ATTY I.D. NO. 04302
1040 N. KINGS HIGHWAY, SUITE 500
CHERRY HILL, NJ 08034
609-482-6900
United Companies Lending :COURT OF COMMON PLEAS
Corporation :CIVIL DIVISION
P.O. Box 1591 :Cumberland County
Baton Rouge, LA 70821-1591
Plaintiff MORTGAGE FORECLOSURE
V.
David M. Kyler
a/k/a David Merle Kyler
Lisa A. Kyler
118 Hogestown Road
Mechanicsburg, PA 17055
Defendant(s)
:NO. 99-6369 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 the
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 $49,610.35
Interest per Complaint 943.11
From 10/9/99 to 12/10/99
Late charges per Complaint 0.00
From N/A to N/A
Escrow payment per Complaint 0.00
From N/A to N/A
TOTAL $50,553.46
I hereby certify that (1) the addresses of the Plaintiff and
Defendant are as shown above, and (2) that notice has been given in
accordance with Rule 237.1, a copy of which is attached hereto.
7MV & ASSOCIATES
Ma k J. Udren, ESQUIRE
At orney for Plaintiff
DAMAGES ARE HEREBY ASSESSED AS INDICATED
9
DATE:.. "24 --' --
PRO PROTHY
1
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MARK J. UDREN & ASSOCIATES
BY: Mark J. Udren, Esquire
ATTY I.D. NO. 04302
1040 N. KINGS HIGHWAY, SUITE 500
CHERRY HILL, NJ 08034
609-482-6900
ATTORNEY FOR PLAINTIFF
United Companies Lending 'COURT OF COMMON PLEAS
Corporation :CIVIL DIVISION
P.O. Box 1591 :Cumberland County
Baton Rouge, LA 70821-1591
-MORTGAGE FORECLOSURE
Plaintiff
V.
David M. Kyler
a/k/a David Merle Kyler :NO. 99-6369 civil
Lisa A. Eyler
118 Hogestown Road
Mechanicsburg, PA 17055
Defendant(s)
PRAECIPE FOR WRIT OF EXECUTION
TO THE SHERIFF:
Issue Writ of Execution in the above matter:
118 HOGESTOWN ROAD
MECHANICSBURG, PA 17055
Amount due $50,553.46
Interest From December--11, 1999 1,227.54
to Date of Sale March 1, 2000
Per diem 0$14.97
(Costs to be added) $
MARK J. UDREN & ASSOCIATES
N //
Mark Udren, ESQUIRE
ATTO EY FOR PLAINTIFF
fti r..
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ON
v
ALL that certain piece or parcel of land situate in the Township of
Silver Spring, County of Cumberland and•State of Pennsylvania,
bounded and described as follows, to wit:
BEGINNING at a point in the center of the Hogestown Road; thence by
land now or formerly of Lloyd Doner, North 35 degrees 45 minutes
East, 1060.95 feet to a pin on line of land now or formerly of
Wilber Ii. Ward; thence along lands now or formerly of said Ward,
South 55 degrees (erroneously set forth in prior deed as 65
degrees) East, 102.65 feet to a pin in corner of lot now or
formerly of William B. Kaley and Elsie I. Kanel, his wife; thence
along said land of William B. Kaley and Elise I. Kaley, his wife,
South 35 degrees 45 minutes West, 1060.95 feet to a point in the
center of the Hogestown Road; thence along the center of said,
North 55 degrees West, 102.65 feet to a point in the center of said
Road, the place of BEGINNING. --' -" - "-'"- -
BEING KNOWN AS 118 HOGESTOWN ROAD
PROPERTY TAX PARCEL NO. 38-21-0289-017
TITLE TO SAID PREMISES IS VESTED IN DAVID MERLE KYLER AND LISA A.
KYLER, HIS WIFE, AS TENANTS BY THE ENTIRETIES BY DEED FROM SANDY K.
RHOADES, DATED 12/8/1993 AND RECORDED 12/20/1993 IN DEED BOOK 36-S
PAGE 108
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MARK J. UDREN & ASSOCIATES
BY: Mark J. Udren, Esquire
ATTY I.D. NO. 04302
1040 N. KINGS HIGHWAY, SUITE 500
CHERRY HILL. NJ 08034
United Companies Lending Corporation
P.O. Box 1591
Baton Rouge, LA 70821-1591
Plaintiff
V.
David M. Kyler
a/k/a David Merle Kyler
Lisa A. Kyyler
118 Hoyestown Road
Mechan csburg, PA 17055
Defendant(s)
ATTORNEY FOR PLAINTIFF
COURT OF COMMON PLEAS
CIVIL DIVISION
Cumberland County
NO. 94.63(- 9 &;? Tim
DATED: November 29 1999
TO: David M. Kyier a/k/a
David Merle Kyler
118 Hogestown Road
Mechanicsburg, PA 17055
IMPORTANT NOTICE
YOU ARE IN DEFAULT BECAUSE YOU HAVE FAILED TO ENTER A WRITTEN
APPEARANCE PERSONALLY OR BY ATTORNEY AND FILE IN WRITING WITH THE
COURT YOUR DEFENSES OR OBJECTIONS TO THE CLAIMS SET FORTH AGAINST
YOU. UNLESS YOU ACT WITHIN TEN DAYS FROM THE DATE OF THIS NOTICE,
A JUDGMENT MAY BE ENTERED AGAINST YOU WITHOUT A HEARING AND YOU MAY
LOSE YOUR PROPERTY OR OTHER IMPORTANT RIGHTS. YOU SHOULD TAKE THIS
NOTICE TO A LAWYER AT ONCE. IF YOU DO NOT HAVE A LAWYER OR CANNOT
AFFORD ONE, GO TO OR TELEPHONE THE FOLLOWING OFFICE TO FIND OUT
WHERE YOU CAN GET LEGAL HELP.
LAWYER REFERRAL SERVICE
Cumberland County Bar Association
2 Library Avenue
Carlisle, PA 17013-3387
(717) 249-3166 or (800) 990-9108
NOTIFICACION IMPORTANTE
USTED SE ENCUENTRA EN ESTADO DE REBELDIA POR NO HABER TOMADO LA
ACCION REQUIRIDA DE SU PARTE EN ESTE CASO. AL NO TOMAR LA ACCION
DEBIDA DENTRO DE UN TERMING DE DIEZ (10) DIAS DE ESTA NOTIFICACION,
EL TRIBUNAL PODRA, SIN NECESIDAD DE COMPARARECER USTED EN CORTE 0
ESCUCHAR PREUBA ALGUNA, DICTAR SENTENCIA EN SU CONTRA, USTED PUEDE
PERDER BIENES Y OTROS DERECHOS, IMPORTANTES. DEBE LLEVAR ESTA
NOTIFICACION A UN ABOGADO IMMEDIATAMENTE SI USTED NO TIENE ABOGADO,
O SI NO TIENE DINERO SUFICIENTE PARA TAL SERVICIO, VAYA EN PERSONA
O LLAME POR TELEFONO A LA OFICINA, CUYA DIRECCION SE ENCUENTRA
ESCRITA ABAJO PARA AVERIGUAR DONDE SE PUEDE CONSEGUIR ASSISTENCIA
LEGAL.
SERVICIO DE REFERENCIA LEGAL
LAWYER REFERRAL SERVICE
Cumberland County Bar Association
2 Library Avenue
Carlisle, PA 17013-3387
(717) 249-3166 or (800) 990-9108
NOTICE: PURSUANT TO THE FAIR DEBT COLLECTION PRACTICES ACT, THIS
LAW FIRM IS DEEMED TO BE A DEBT COLLECTOR AND THIS IS AN ATTEMPT TO
COLLECT A DEBT. ANY INFORMATION OBTAINED WILL BE USED FOR THAT
PURPOSE.
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HARK J. UDREN Q ASSOCIATES
BY: Hark J. Udren Enquire
ATTY I.D. NO. 04301
1.040 N. KINGS HIGHWAY, SUITS 500
CHERRY HILL. NJ 08034
United Companies Lending Corporation
P.O. Box 1591
Baton Rouge, LA 70821-1591
Plaintiff
v.
David M. Kyler
a/k/a David Merle Kyler
Lisa A. Kyler
118 Hogestown Road
Mechanicsburg, PA 17055
Defendant(s)
DATED: November 29, 1999
TO: Lisa A. Kyler
118 Hogestown Road
Mechanicsburg, PA 17055
ATTORNEY FOR PLAINTIFF
COURT OF COMMON PLEAS
CIVIL DIVISION
Cumberland County
NO. 9q•63lq&aT1
IMPORTANT NOTICE
YOU ARE IN DEFAULT BECAUSE YOU HAVE FAILED TO ENTER A WRITTEN
APPEARANCE PERSONALLY OR BY ATTORNEY AND FILE IN WRITING WITH THE
COURT YOUR DEFENSES OR OBJECTIONS TO THE CLAIMS SET FORTH AGAINST
YOU. UNLESS YOU ACT WITHIN TEN DAYS FROM THE DATE OF THIS NOTICE,
A JUDGMENT MAY BE ENTERED AGAINST YOU WITHOUT A HEARING AND YOU MAY
LASE 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 'ELP.
LAWYER REFERRAL SERVICE
Cumberland County Bar Association
2 Library Avenue
Carlisle, PA 17013-3387
(717) 249-3166 or (800) 990-9108
NOTIFICACION IMPORTANTE
USTED SE ENCUENTRA EN ESTADO DE REBELDIA POR NO HABER TOMADO LA
ACCION REQUIRIDA DE SU PARTE EN ESTE CASO. AL NO TOMAR LA ACCION
DEBIDA DENTRO DE UN TERMINO DE DIEZ (10) DIAS DE ESTA NOTIFICACION,
EL TRIBUNAL PODRA, SIN NECESIDAD DE COMPARARECER USTED EN CORTE O
ESCUCHAR PREUBA ALGUNA, DICTAR SENTENCIA EN SU CONTRA, USTED PUEDE
PERDER BIENES Y OTROS DERECHOS, IMPORTANTES. DEBE LLEVAR ESTA
NOTIFICACION A UN ABOGADO IMMEDIATAMENTE SI USTED NO TIENE ABOGADO,
O SI NO TIENE DINERO SUFICIENTE PARA TAL SERVICIO, VAYA EN PERSONA
O LLAME POR TELEFONO A LA OFICINA, CUYA DIRECCION SE ENCUENTRA
ESCRITA ABAJO PARA AVERIGUAR DONDE SE PUEDE CONSEGUIR ASSISTENCIA
LEGAL.
SERVICIO DE REFERENCIA LEGAL
LAWYER REFERRAL SERVICE
Cumberland County Bar Association
2 Library Avenue
Carlisle, PA 17013-3387
(717) 249-3166 or (800) 990-9108
NOTICEt PURSUANT TO THE FAIR DEBT COLLECTION PRACTICES ACT, THIS
LAW FIRM IS DEEMED TO BE A DEBT COLLECTOR AND THIS IS AN ATTEMPT TO
COLLECT A DEBT, ANY INFORMATION OBTAINED WILL BE USED FOR THAT
PURPOSE.
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MARK J. UDREN 4 ASSOCIATES
BY: Mark J. Udron, Koquire
ATTY I.D. NO. 04302
1040 N. KINGS HIGHWAY, SUITS 500
CHERRY HILL, NJ 08034
609-484-6900
United Companies Lending
Corporation
P.O. BOX 1591
Baton Rouge, LA 70821-1591
Plaintiff
V.
David M. Kyler
a/k/a David Marla Kylor
Lisa A. Kyler
-_:-118-H entawn Road __ ___---
Mechanicsburg, PA 17055
Defandant(s)
ATTORNEY FOR PLAINTIFF
COURT OF COMMON PLEAS
CIVIL DIVISION
Cumberland County
MORTGAGE FORECLOSURE
NO. q q • (. 3(.q OAAjj T,..-
AFFIDAVIT OF NON-MILITARY SERVICE
STATE OF ILW6 n -
CGMMT-OF V_ LI c,,F "i3(Xhu W 11OW Pokro I.,
SS
THE UNDERSIGNED beings duly Sworn, deposes and says that the
averments heroin are based upon. investigations made and records
maintained by us either as Plaintiff or as servicing agent of the
Plaintiff herein and that the above Defendant(s) are not in the
Military or Naval Service of the•United States of America or its
Allies as defined in the Soldiers and Sailors Civil Relief Act of
1940, as amended, and that the age and last known residence and
employment of each Defendant are as follows:
Defandant:
Age:
Residences
Employment:
Defendant:
Age:
Residence:
Employment:
David M. Kyler
A/K/A David,Merle Kj+ler
.. i
Over 18
As,captioned above
Unknown
Lisa A. Kyler
Over 18
As captioned
Unknown
Sworn to and subscribed
before me this ) I- Cday
of 199'
Notary Public
e
Name : ( : tax ?}C(CT
Company: v
dcai
t)eborah S. Aydeil, duly commissioned In
and for the Parish of Livingston, qualified
to act in and for tho parish of East Baton
Dalon Rouge, slate of Louisiana.
My commision is for Life.
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MARK J. UVREN Q ASSOCIATES
BY: Mark J. Udren, Enquire
ATTY I.D. NO. 04302
1040 N. KINGS HIGHWAY, SUITE 500
CHERRY HILL, NJ 08034
609-482-6900
United Companies Lending
Corporation
P.O. Box 1591
Baton Rouge, LA 70821-1591
ATTORNEY FOR PLAINTIFF
:COURT OF COMMON PLEAS
:CIVIL DIVISION
:Cumberland County
MORTGAGE FORECLOSURE
Plaintiff
V.
David M. Kyler
a/k/a David Merle Kyler
Lisa A. Kyler
118 Hogestown Road
Mechanicsburg, PA 17055
Defendant(s)
: NO.' 99-6369 civil
TO: DAVID M. KYLER a/k/a DAVID MERLE KYLER
118 Hogestown Road
Mechanicsburg, PA 17055
NOTICE
Pursuant to Rule 236 of the Supreme Court of Pennsylvania, you are hereby
notified that a Judgment has been entered against you in the above
proceeding as indicated below.
Prothonotary
-X_ Judgment by Default
Money Judgment
Judgment in ReOevin
Judgment for Possession
Judgment on Award of Arbitration
- Judgment on Verdict
Judgment on Court Findings
IF YOU HAVE ANY QUESTIONS CONCERNING THIS NOTICE PLEASE CALL:
ATTORNEY _._ Mark J. Udren, Esquire
At this telephone number: 609-482-6900
A
MARK J. UDREN Q ASSOCIATES
BY: Mark J. Udren, Esquire
ATTY I.D. NO. 04302
1040 N. KINGS HIGHWAY, SUITE 500
CHERRY HILL, NJ 08034
609-482-6900
United Companies Lending
Corporation
P.O. Box 1591
Baton Rouge, LA 70821-1591
Plaintiff
V.
David M. Kyler
a/k/a David Merle Kyler
Lisa A. Kyler
118 Hogestown Road
Mechanicsburg, PA 17055
Defendant(s)
ATTORNEY FOR PLAINTIFF
:COURT OF COMMON PLEAS
:CIVIL DIVISION
:Cumberland County
MORTGAGE FORECLOSURE
NO. 99-6369 civil
PRAECIPE FOR JUDGMENT FOR FAILURE TO
ANSWER_ANIZASSESSNMiT_OF DAMAGES
TO THE PROTHONOTARY:
Kindly enter judgment in favor of the Plaintiff and against the
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 $49,610.35
Interest per Complaint 943.11
From 10/9/99 to 12/10/99
Late charges per complaint 0.00
From N/A to N/A
Escrow payment per Complaint _0_._00
From N/A to N/A
TOTAL : $501553.36
I hereby certify that (1) the addresses of the Plaintiff and
Defendant are as shown above, and (2) that notice has been given in
accordance with Rule 237.1, a copy of which is attached hereto.
= & ASSOCIATES
Ma #k J. Udren, ESQUIRE
Attorney for Plaintiff
DAMAGES ARE HEREBY ASSESSED AS INDICATED
DATE: t-f e,,,..(-e l1 /9 l; . /CI. ekj T
PRO PROTHY
V F.._R-F 1_C_A T t o N
The undersigned, an officer of the Corporation which is the
Plaintiff in the foregoing Complaint or an officer of the
Corporation which is the servicing agent of Plaintiff, and being
authorized to make this verification on behalf of the Plaintiff,
hereby verifies that the facts set forth in the foregoing Complaint
undersigned who maintain the business records of the mortgage held
by Plaintiff in the ordinary course of business and that those
facts are true and correct. to the best of the knowledge,
information and belief of the undersigned.
The undersigned understands that this statement is made
subject to the penalties of 18 Pa. C.S. Section 4904 relating to
unsworn falsification to authorities.
Date : hi kloq qj-
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Title: UI9?p{1c" Z , c,Aq -
Company: .VPZcd Con.p-In
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MARK J. WHEN Q ASSOCIATES
HYt Mark J. Udren, Esquire
ATTY I.D. NO. 04302
1040 N. KINGS HIQHWAY, SUITE 500
CHERRY HILL, NJ 06034
609-482-6900
ATTORNEY FOR PLAINTIFF
United Companies Lending 'COURT OF COMMON PLEAS
Corporation :CIVIL DIVISION
P.O. Box 1591 :Cumberland County
Baton Rouge, LA 70821-1591
Plaintiff
MORTGAGE FORECLOSURE
V.
David M. Kyler
a/k/a David Merle Kyler 99-6369 civil
Lisa A. Kyler
118 Hogestown Road
Mechanicsburg, PA 17055
Defendant(s)
C E R T I F I C A T E
Mark J. Udren, Esquire, hereby states that he is the 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 insured mortgage
( ) Non-owner occupied
( ) Vacant
( X ) Act 91 procedures have been fulfilled.
This certification is made subject to the penalties of 18 Pa. C.S.
Sec. 4904 relating to unsworn falsification to authorities.
MARK /M/PRENA ASSOCIATES
dren, ESQUIRE
FOR PLAINTIFF
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MARK J. UDREN 4 ASSOCIATES
BYs Mark J. Udren, Esquire
ATTY I.D. NO. 04302
1040 N. KINGS HIGHWAY, SUITE 500
CHERRY HILL, NJ 08034
609-462-6900
ATTORNEY FOR PLAINTIFF
United Companies Lending COURT OF COMMON PLEAS
Corporation :CIVIL DIVISION
P.O. Box 1591 :Cumberland County
Baton Rouge, LA 70821-1591
MORTGAGE FORECLOSURE
Plaintiff
V.
David M. Kyler
a/k/a David Merle Kyler
Lisa A. Kyler
118 Hogestown Road
Mechanicsburg, PA 17055
Defendant(s)
NO. 99-6369 civil
AFFIDAVIT PURSUANT TO RULE 3129.1
United Companies Lending Corporation, Plaintiff in the above action, by
its attorney, Mark J. Udren, 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: 118 Hogestown Road, Mechanicsburg, PA
17055
1. Name and address of Owner(s) or reputed Owner(s):
Name Address
DAVID MERLE KYLER 118 HOGESTOWN RD., MECHANICSBURG, PA 17055
a/k/a DAVID MERLE KYLER
LISA A. KYLER 118 HOGESTOWN RD., MECHANICSBURG, PA 17055
2. Name and address of Defendant(s) in the judgment:
Name Address
SAME AS ##1 ABOVE
3. Name and address of every judgment creditor whose judgment is a record
lien on the real property to be sold:
Name Address
YELLOW BOOK MID-ATLANTIC & 1300 MORRIS DR., STE 200, WAYNE, PA 19087
REUBEN F. DONNELLEY
AMERICAN GENERAL FINANCE INC 125 GATEWAY DR., STE 109, MECHANICSBURG, PA
17055
4. Name and address of the last recorded holder of every mortgage of
record:
Name
Plaintiff herein.
COUNTRYWIDE HOME LOANS
Address
See Caption above.
6400 LEGACY DR., PLANO, TX 75024
DAUPHIN DEPOSIT BANK & TRUST PO BOX 4800, HARRISBURG, PA
AMERICA'S WHOLESALE LENDER 155 N. LAKE AVE., PASADENA, CA 91109
5. Name and address of every other person who has any record lien on the
property:
Name Address
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 Address
REAL ESTATE TAX DEPT.
Domestic Relations Section
Commonwealth of PA,
Department of Revenue
1 COURTHOUSE SQ., CARLISLE, PA 17013
13 N. HANOVER ST., CARLISLE, PA 17013
Bureau of Compliance, Dept. 280946
Harrisburg, PA 17128-0946
7. Name and address of every other person of whom the plaintiff has
knowledge who has any interest in the property which may be affected by
the sale:
Name Address
Tenants/Occupants 118 Hogestown Road, Mechanicsburg, PA 17055
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.
DATED: December 10, 1999
MARK J. UDREN & ASSOCIATES
Mar . Udren, ESQ.
Att rney for Plaintiff
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NARK J. UDREN Q ASSOCIATES ATTORNEY FOR PLAINTIFF
BYe Nark J. Udren, Esquire
ATTY I.D. NO. 04302
1040 N. KINGS HIGHWAY, SUITE 500
CHERRY HILL, NJ 08034
609-482-6900
United Companies Lending 'COURT OF COMMON PLEAS
Corporation :CIVIL DIVISION
P.O. Box 1591 ;Cumberland County
Baton Rouge, LA 70821-1591
MORTGAGE FORECLOSURE
Plaintiff
V.
David M. Kyler
a/k/a David Merle Kyler
Lisa A. Kyler
118 Hogestown Road
Mechanicsburg, PA 17055
Defendant(s)
99-6369 Civil
NOTICE OF SHERIFF'S SALE OF REAL PROPERTY
TO: DAVID M. KYLER LISA A. KYLER
a/k/a DAVID MERLE KYLER 118 Hogestown Road
118 Hogestown Road Mechanicsburg, PA 17055
Mechanicsburg, PA 17055
Your house (real estate) at 118 Hogestown Road, Mechanicsburg, PA 17055
is scheduled to be sold at the Sheriff's Sale on March 1, 2000, at 10:00
AM in the CUMBERLAND COUNTY COURTHOUSE, 1 COURTHOUSE SQUARE, CARLISLE,
PA, to enforce the court judgment of $50,553.46, obtained by Plaintiff
above (the mortgagee) against you. If the sale is postponed, the
property will be relisted for the Next Available 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 payment, late
charges, costa and reasonable attorney's flea. To find out how much you must pay,
you may call: (609) 482-6900.
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 atop 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 609-482-6900.
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 609-482-6900.
4. If the amount due from the Buyer is not paid to the Sheriff, you will remain
the owner of the property as if the sale never happened.
5. You have the right to remain in the property until the full amount due is
paid to the Sheriff and the Sheriff gives a deed to the buyer. At that time, the buyer
may bring legal proceedings to evict you.
6. You may be entitled to a share of the money which was paid for your house.
A schedule of distribution of the money bid for your house will be filed by the Sheriff
within 30 days after the sale. This schedule will state who will be receiving that
money. The money will be paid out in accordance with this schedule unless exceptions
(reasons why the proposed distribution is wrong) are filed with the Sheriff within ten
(10) days after Schedule of Distribution is filed.
7. You may also have other rights and defenses, or ways of getting your home
back, if you act immediately after the sale.
YOU SHOULD TAKE THIS PAPER TO YOUR LAWYER AT ONCE. IF YOU DO NOT HAVE A LAWYER OR
CANNOT AFFORD ONE, 00 TO OR TELEPHONE THE OFFICE LISTED BELOW TO FIND OUT WHERE YOU CAN
GET LEGAL HELP.
LAWYER REFERRAL SERVICE
Cumberland County Bar Association
2 Library Avenue
Carlisle, PA 17013-3387
(717) 249-3166 or (800) 990-9108
ASSOCIATION DE LICENCIDADOS DE FILADELFIA
Cumberland County Bar Association
2 Library Avenue
Carlisle, PA 17013-3387
(717) 249-3166 or (800) 990-9108
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MARK J. UDREN & ASSOCIATES ATTORNEY FOR PLAINTIFF
BY: Kark J. Udren, Esquire
ATTY I.D. NO. 04301
1040 N. KINGS HIGHWAY, SUITE 500
CHERRY HILL, Na 08034
609-481-6900
United Companies Lending 'COURT OF COMMON PLEAS
Corporation :CIVIL DIVISION
Plaintiff :Cumberland County
V.
David M. Kyler :NO. 99-6369 civil
a/k/a David Merle Kyler
Lisa A. Kyler
Defendant(s)
PRAHCIPE TO SUBSTITUTE VERIFICATION
TO THE PROTHONOTARY:
Kindly substitute the attached Verification for the
Verification attached to the Complaint in Mortgage Foreclosure with
regard to the captioned matter.
MARK J. UDREN & ASSOCIATES
DATED: December 10, 1999
BY:
rk J. Udren, Esquire
torney for Plaintiff
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w. . SHERIFF'S RETURN - REGULAR
CASE NO: 1999-06369 P
COMMONWEALTH OF PENNSYLVANIA:
COUNTY OF CUMBERLAND
UNITED COMPANIES LENDING
VS.
KYLER DAVID M 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 KYLER DAVID M A/K/A KYLER DAVID MERLE the
defendant, at 17:50 HOURS, on the 2nd day of November
1999 at 118 HOGESTOWN ROAD
MECHANICSBURG PA 17055 CUMBERLAND
County, Pennsylvania, by handing to DAVID KYLER
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. I
Sheriff's Costs: So answers
Docketing 18.00
Service 6.20
Affidavit
Surcharge 8.00
5
SJ;! - d II -M1 K J. UDREN
103/1999
by
Sworn and subscribed to before me
this 9 ?1" day of -liQcu,? _
1989 A.D./
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YP
CASE NO: 1999-06369 P
SHERIFF'S RETURN - REGULAR
COMMONWEALTH OF PENNSYLVANIA:
COUNTY OF CUMBERLAND
UNITED COMPANIES LENDING
VS.
KYLER DAVID M 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 KYLER LISA A the
defendant, at 17:50 HOURS, on the 2nd day of November ,
1999 at 118 HOGESTOWN ROAD
MECHANICSBURG, PA 17055 ,CUMBERLAND
County, Pennsylvania, by handing to DAVID KYLER (HUSBAND)
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 Costa: So an:%?
Docketing 6.00 ?
Service .00
Surcharge 8.00 ,
11/03/1999REN
by
go-ao) #I
Deputy SnerIEL
Sworn and subscribed to before me
this ?9r= day of ka".f l
19Q_ A.D.
??h??
MARK J. UDREN & ASSOCIATES ATTORNEY FOR PLAINTIFF
BY: Mark J. Udren
ATTY I.D. NO. 04302
1040 N. KINGS HIGHWAY, SUITE 500
CHERRY HILL, NJ 08034
856-482-6900
United Companies Lending :COURT OF COMMON PLEAS
Corporation :CIVIL DIVISION
P.O. Box 1591 :Cumberland County
Baton Rouge, LA 70821-1591
Plaintiff
V.
David M. Kyler
a/k/a David Merle Kyler
Lisa A. Kyler
118 Hogestown Road
Mechanicsburg, PA 17055
Defendant(s)
:NO. 99-6369 civil
AFFIDAVIT OF SERVICE PURSUANT TO Pa.R.C.P.RULE 3129.1
Plaintiff, by its/his/her Attorney, Mark J. Udren, Esquire, hereby verifies
that:
1. A COPY of the Notice of Sheriff's Sale, a true and correct copy of which
is attached hereto as Exhibit "A", was sent to every recorded lienholder and
every other interested party known as of the date of the filing of the
Praecipe for the Writ of Execution, on the date(s) appearing on the attached
Certificates of Mailing.
2. A Notice of Sheriff's Sale was sent to Defendant(s) by regular mail and
certified mail on the date appearing on the attached Return Receipt, which
was signed for by Defendant(s) on the date specified on the said Return
Receipt. Copies of the said Notice and Return Receipt are attached hereto as
Exhibit "B".
3. If a Return Receipt is not attached hereto, then service was by personal
service on the date specified on the attached Return of Service, attached
hereto as Exhibit "B".
4. If service was by Order of Court, then proof of compliance with said
order is attached hereto as Exhibit "B".
.
All Notices were served within the time limits set forth by Pa Rule C.P.
3129.
This Affidavit is made subject to the penalties of 18 Pa.C.S. Section 4904
relating to unsworn falsification to authorities.
Dated: January 27, 2000 K?• UDREN & ASSOCIATES
BY: N -
ark J. Udren, Esquire
ttorney for Plaintiff
MARK J. UDREN & ASSOCIATES
BY: Mark J. Udren, Esquire
ATTY I.D. NO. 04302
1040 N. KINGS HIGHWAY, SUITE 500
CHERRY HILL, NJ 08034
609-482-6900
United Companies Lending
Corporation
P.O. Box 1591
Baton Rouge, LA 70821-1591
Plaintiff
V.
David M. Kyler
a/k/a David Merle Kyler
Lisa A. Kyler
118 Hogestown Road
Mechanicsburg, PA 17055
Defendant(s)
ATTORNEY FOR PLAINTIFF
'COURT OF COMMON PLEAS
:CIVIL DIVISION
:Cumberland County
MORTGAGE FORECLOSURE
.NO. 99-6369 civil
AMENDED AFFIDAVIT PURSUANT TO RULE 3129.1
United Companies Lending Corporation, Plaintiff in the above action, by
its attorney, Mark J. Udren, 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: 118 Hogestown Road, Mechanicsburg, PA
17055
1. Name and address of Owner(s) or reputed Owner(s):
Name Address
DAVID MERLE KYLER 118 HOGESTOWN RD., MECHANICSBURG, PA 17055
a/k/a DAVID MERLE KYLER
LISA A. KYLER 118 HOGESTOWN RD., MECHANICSBURG, PA 17055
2. Name and address of Defen dant(s) in the judgment:
Name Address
SAME AS #1 ABOVE
3. Name and address of every judgment creditor whose judgment is a record
lien on the real property to be sold:
Name Address
YELLOW BOOK MID-ATLANTIC & 1300 MORRIS DR., STE 200, WAYNE, PA 19087
REUBEN F. DONNELLEY
AMERICAN GENERAL FINANCE INC 125 GATEWAY DR., STE 109, MECHANICSBURG, PA
17055
FARR FAMILY TIRE 3201 TRINDLE RD., CAMP HILL, PA 17011
4. Name and address of the last recorded holder of every mortgage of
record:
Name Address
Plaintiff herein. See Caption above.
COUNTRYWIDE HOME LOANS 6400 LEGACY DR., PLANO, TX 75024
DAUPHIN DEPOSIT BANK & TRUST PO BOX 4800, HARRISBURG, PA
AMERICA'S WHOLESALE LENDER 155 N. LAKE AVE., PASADENA, CA 91109
5. Name and address of every other person who has any record lien on the
property:
Name Address
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 Address
REAL ESTATE TAX DEPT
Domestic Relations Section
Commonwealth of PA,
Department of Revenue
1 COURTHOUSE SQ., CARLISLE, PA 17013
13 N. HANOVER ST., CARLISLE, PA 17013
Bureau of Compliance, Dept. 280946
Harrisburg, PA 17128-0946
7. Name and address of every other person of whom the plaintiff has
knowledge who has any interest in the property which may be affected by
the sale:
Name Address
Tenants/Occupants 118 Hogestown Road, Mechanicsburg, PA 17055
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.
MARK J. UDREN & ASSOCIATES
DATED: JANUARY 27, 2000
Ma k J. Udren, ESQ.
Attorney for Plaintiff
MARK J. UDREN & ASSOCIATES
BY: Mark J. Udren, Esquire
ATTY I.D. NO. 04302
1040 N. KINGS HIGHWAY, SUITE 500
CHERRY HILL, NJ 08034
609-482-6900
United Companies Lending
Corporation
P.O. Box 1591
Baton Rouge, LA 70821-1591
Plaintiff
V.
David M. Kyler
a/k/a David Merle Kyler
*Lisa .A. Kyler'
318 Hogestown Road
Mechanicsburg, PA 17055
. Defendant(s)
DATE: December 20, 1999
NO. 99-6369 civil
ATTORNEY FOR PLAINTIFF
COURT OF COMMON PLEAS
CIVIL DIVISION
Cumberland County
TO: ALL PARTIES IN INTEREST AND CLAIMANTS
NOTICE OF'SHERIFF'S SALE
OA RF. L ROPSRTY.
OWNER(S): DAVID M KYLER a/k/a DAVID MERLE KYLER & LISA A KYLER
PROPERTY: 118 Hogestown Road Mechanicsburg, PA 17055
Improvements: RESIDENTIAL DWELLING
The above captioned property is scheduled to be sold at the
Cumb_eri.and county sheriff's Sale on Mar_Ch_1._20-Q0, at 10:00 AM, at
the CUMBERLAND COUNTY COURTHOUSE 1 COURTHOUSE SQUARE CARLISLE PA.
Our records indicate that you may hold a mortgage or judgment on
the property which will be extinguished by the sale. You may wish
to attend the sale to protect your interests.
A Schedule of Distribution will be filed by the Sheriff on a date
specified by the Sheriff not later that 30 days after sale.
Distribution will be made in accordance with the schedule unless
exceptions are filed thereto within 10 days after the filing of the
schedule.
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United Companies Lending Corporation In the Court of Common Pleas of
.vs. Cumberland County, Pennsylvania
David M. Kyler aka David Merle Kyler No.1999.6369 Civil
Lisa A. Kyler
R. Thomas Kline, Sheriff, who being duly sworn according to law, says this writ
is returned STAYED.
Sheriffs Costs:
Docketing
Poundage
Advertising
Posting Bills
Law Library
County
Mileage
Certified Mail
Levy
Postpone Sale
Surcharge
Law Journal
Partiot News
Share of Bills
Sworn and subscribed to before me
30.00
13.09
15.00
15.00
.50
1.00
5.58
1.21
15.00
40.00
24.00
274.70
207.64
25.08
$667.80 Pd by Atty
5/24/00
This &"!?:dayof_
2000, A.D. 12 A Am,'
r thonotary
So answers:
R. Thomas Kline, Sheriff
BY
Real Estate Deputy
121 ..96y"
MARK J. UDREN & ASSOCIATES
BY: Mark J. Udren, Esquire
ATTY I.D. NO. 04302
1040 N. KINGS HIGHWAY, SUITE 500
CHERRY HILL, NJ 08034
609-482-6900
United Companies Lending
Corporation
P.O. Box 1591
Baton Rouge, LA 70821-1591
Plaintiff
ATTORNEY FOR PLAINTIFF
:COURT OF COMMON PLEAS
: CIVIL DIVISION
:Cumberland County
MORTGAGE FORECLOSURE
v.
David M. Kyler
a/k/a David Merle Kyler
Lisa A. Kyler
118 Hogestown Road
Mechanicsburg, PA 17055
Defendant(s)
NO.i99-6369 civil
AFFIDAVIT PURSUANT TO RULE 3129.1
United Companies Lending Corporation, Plaintiff in the above action, by
its attorney, Mark J. Udren, 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: 118 Hoge§tovln Road, Mechanicsburg, PA
17055
1. Name and address of Owner(s) or.reputed Owner(s):
Name Address
DAVID MERLE KYLER 118 HOGESTOWN RD., MECHANICSBURG, PA 17055
a/k/a DAVID MERLE KYLER
LISA A. KYLER 118 HOGESTOWN RD., MECHANICSBURG, PA 17055
2. Name and address of Defendant(j in'the judgment:
Name Address
SAME AS #1 ABOVE
3. Name and address of every judgment creditor whose judgment is a record
lien on the real property to be sold:
Name Address
YELLOW BOOK MID-ATLANTIC & 1300 MORRIS DR., STE 200, WAYNE, PA 19087
REUBEN F. DONNELLEY
AMERICAN GENERAL FINANCE INC 125 GATEWAY DR., STE 109, MECHANICSBURG, PA
17055
4. Name and address of the last recorded holder of every mortgage of
record:
Name
Plaintiff herein.
COUNTRYWIDE HOME LOANS
DAUPHIN DEPOSIT BANK & TRUST
AMERICA'S WHOLESALE LENDER
Address
See Caption above.
6400 LEGACY DR., PLANO, TX 75024
PO BOX 4800, HARRISBURG, PA
155 N. LAKE AVE., PASADENA, CA 91109
5. Name and address of every other person who has any record lien on the
property:
Name Address
NONE
6. Name and address of eve
the property and whose interest may be affected byn heesale:interest in
Name Address
REAL ESTATE TAX DEPT.
Domestic Relations Section
Commonwealth of PA,
Department of Revenue
,-1 COURTHOUSE SQ., CARLISLE, PA 17013
13 N. HANOVER ST., CARLISLE, PA 17013
Bureau of Compliance, Dept._ 280946
Harrisburg, PA 17128-0946
7. Name and address of every other person of whom the plaintiff has
knowledge who has any interest in the property which may be affected by
the sale:
Name Address
Tenants/Occupants 118 Hogestown Road, Mechanicsburg, PA 17055
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 toiunswprn falsification to authorities.
DATED: December 10, 1999
MARK J. UDREN & ASSOCIATES
Z
Mar MUdren, ESQ.
Att rney for Plaintiff
MARK J. UDREN & ASSOCIATES
BYs Mark J. Udren, Esquire
ATTY I.D. NO. 04302
1040 N. KINGS HIGHWAY, SUITE 500
CHERRY HILL, NJ 08034
609-482-6900
ATTORNEY FOR PLAINTIFF.
United Companies Lending
Corporation
P.O. Box 1591
Baton Rouge, LA 70821-1591
Plaintiff
V.
David M. Kyler
a/k/a David Merle Kyler
Lisa A. Kyler
118 Hogestown Road
Mechanicsburg, PA 17055
Defendant(s)
'COURT OF COMMON PLEAS
CIVIL DIVISION
:Cumberland County
MORTGAGE FORECLOSURE
.140.- 99-6369 civil
NOTICE_OF_SHERIFF!S_SALE_OF REAL_PROPERTY
TO: DAVID M. KYLER LISA A. KYLER
a/k/a DAVID MERLE KYLER 118 Hogestown Road
118 Hogestown Road Mechanicsburg, PA 17055
Mechanicsburg, PA 17055 11
Your house (real estate) at 118 Hogestown Road, Mechanicsburg, PA 17055
is scheduled to be sold at the Sheriff's Sale on March 1, 2000, at 10:00
AM in the CUMBERLAND COUNTY COURTHOUSE, 1 COURTHOUSE SQUARE, CARLISLE,
PA, to enforce the court judgment of $50,553.46, obtained by Plaintiff
above (the mortgagee) against you. If the sale is postponed, the
property will be relisted for the Next Available Sale.
NOTICE_OP QWNER!S_RIGHTS
To prevent this Sheriff's Sale, you must take immadiate_actiont
1. The sale will be cancelled if you pay to the mortgagee the back payment, late
charges, costs and reasonable attorney's fees. To find out how much you must pay,
you may call: (609)_482-6900..
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 TARE 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 609-482-6900.
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 609-482-6900.
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 Co a share of the money which was paid for your house.
A schedule of distribution of the money bid for your house will be filed by the Sheriff
within 30 days after the sale. This schedule will state who will be receiving that
money. The money will be paid out in accordance with this schedule unless exceptions
(reasons why the proposed distribution is wrong) are filed with the Sheriff within ten
(10) days after Schedule of Distribution is filed.
7. You may also have other rights and defenses, or ways of getting your home
back, if you act immediately after the sale.
YOU SHOULD TAKE THIS PAPER TO YOUR LAWYER AT ONCE. IF YOU DO NOT HAVE A LAWYER OR
CANNOT AFFORD ONE, GO TO OR TELEPHONE THE OFFICE LISTED BELOW TO FIND OUT WHERE YOU CAN
GET LEGAL HELP.
LAWYER REFERRAL SERVICE
Cumberland County Bar Association
2 Library Avenue.
Carlisle „PA 17013-3387
(717) 249-3166 or (800) 990;9108
ASSOCIATION DE LICENCIDADOS DE?,FILADELFIA
Cumberland County Bar Association
2 Library Avenue
Carlisle, PA 17013-3387
(717) 249-3166 or (800) 990-9108
r
ALL that certain piece or parcel of land situate in the Township of
Silver Spring, County of Cumberland and•State of Pennsylvania,
bounded and described as follows, to wit: '
BEGINNING at a point in thb center of the Hogestown Road; thence by
land now or formerly of Lloyd Doner, North 35 degrees 45 minutes
East, 1060.95 feet to a pin on line of land now or formerly of
Wilber H. Ward; thence along lands now or formerly of said Ward,
South 55 degrees (erroneously' set forth in prior deed as 65
degrees) East, 102.65 feet to a pin in corner of lot now or
formerly of William B. Kaley and Elsie I. Kanel, his wife; thence
along said land of William B. Kaley and Elise I. Kaley, his wife,
South 35 degrees 45 minutes West, 1060.95' feet to a point in the
center of the Hogestown Road;, thence along the center of said,
North 55 degrees West, 102.65 feet to a point in the center of said
Road, the place of BEGINNING.
BEING KNOWN
•,1
PROPERTY TAX
M
AS 118 HOGESTOWN ROAD
PARCEL NO. 38-21-0289-017
TITLE TO SAID PREMISES IS VESTED IN DAVID MERLE KYLER AND LISA A.
KYLER, HIS WIFE, AS TENANTS BY THE ENTIRETIES BY DEED FROM SANDY K. V,
RHOADES, DATED 12/8/1993 AND RECORDED 12/20/1993 IN DEED BOOK 36-5 a
PAGE 108
WRIT OF EXECUTION and/or ATTACHMENT
COMMONWEALTH OF PENNSYLVANIA) NO, 99-6369 CIVIL99,TEIM
COUNTY OF CUMBERLAND) CIVIL ACTION - LAW
TO THE SHERIFF OF Cumberland COUNTY:
To satisfy the debt, Interest and costs due United Companies Lending Corporation
PLAINTIFF(S)
from David M. Kyler a/k/a/ David Merle Kyler Lisa A. Kyler
118 Hogestown Road Mechanicsburg, PA 17055
DEFENDANT(S)
(1) You are directed to levy upon the property of the defendant(s) and to sell
118 Hogestown Road Mechanicsburg, PA 17055
(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) riot levied upon an subject to attachment Is found inthe possossionof anyoneother
than a named garnishee, you are directed to notify hinvherthat he/she has been added as a garnishee and is enjoined as above
stated.
Amount Due ?$t 50,553.46 L.L. $0.50 _
ost m IMYUIP?ti9@tv 1490 Dare of sale $ 1,00
Intern
81.227.54 Due Prothy
Atty's Comm % Other Costs
Any Paid $118.20
Plaintiff Paid
Date: nw-arnb.r is- 1999 Curtis R. Long
n Prothonotary, Civil Division
by: G,.,.ti_ ?. ?Zt @Cr?
-l Deputy
REQUESTING PARTY:
Name Mark J. tklren, ESQ _
Address, 24 North Merion Avenue Suite - 240
Bryn Mawr PA 19010
Attomeyfor: Plff
Telephone: 215-568-9500
Supreme Court ID No. 4302
REAL L6TATE SALE No. Y v
u...
Ott rg95' tit s ^ ` 1 !.?d t ren i il', dr,., .0 "'16
;':
i nt nt in tiro roof proporty sitcn,'c;i is?,
.Q,
Cu??bari,n;l County, Pa., knc':r, n..r?t?%:rd as: o.* _p
O
and fil rG Gn Exhibit 'AIliad v,itil
QQQ O
QQQ Cuz7
this wrt and by tttis retctenco incorporated heroin.
Dales 1?s a
Vltt?;. •• . ,
G6, Jed t.t of ill 331
b.l. 10 ;1"110
daltl:m..
PROOF OF PUBLICATION OF NOTICE
IN CUMBERLAND LAW JOURNAL
(Under Act No. 587, approved May 16, 1929), P. L.1784
STATE OF PENNSYLVANIA :
ss.
COUNTY OF CUMBERLAND :
Roger M, Morgenthal, Esquire, Editor of the Cumberland Law Journal, of the County
and State aforesaid, being duly swom, according to law, deposes and says that the Cumberland
Law Journal, a legal periodical published in the Borough of Carlisle in the County and State
aforesaid, was established January 2, 1952, and designated by the local courts as the official legal
periodical for the publication of all legal notices, and has, since January 2, 1952, been regularly
issued weekly in the said County, and that the printed notice or publication attached hereto is
exactly the same as was printed in the regular editions and issues of the said Cumberland Law
Journal on the following dates,
Affiant further deposes that he is authorized to verify this statement by the Cumberland
Law Journal, a legal periodical of general circulation, and that he is not interested in the subject
matter of the aforesaid notice or advertisement, and that all allegations in the foregoing
statements as to time, place and character of publication arc true.
RrrAL ESTATE SALE; NO. 42
Will NO. 09.6369 Civil
United Companies
Lending Corporation
vs.
David M. KYler, a/k/a
David Merle Kyler, Usa A. Kyler
Ally.: Mark J. Udren
ALL that certain piece or parcel of
land situate In the Township of Silver
State imCau,mberland and
bounded and
described as follows, to wit:
BEGINNING at a point In the cen.
ter of the liogestown Road; thence by
land now or formerly of Uoyd Doner,
North 35 degrees 45 minutes Fast.
1060.95 fat to a pin on line of land
now or formerly of Welber If. Ward;
thence along lands now or formerly
of said Ward. South 55 degrees (erro.
neously set forth In prior deed as o5
degrees) East. 102.05 feel to a pin in
corner of lot now or formerly of Wa-
s liam B. Kaley and Elsie 1, Kanel, his
wife; thence along said land of wo-
Ilam B. Kaley and Elise 1. Kaley, Ills
wife, South 35 degrees 45 minutes
West, IOGM95 feet to a point In the
center of the Ilogeslown (toad:
thence along the center of said, Road
thence
degrees West. 102,65 feet North 10 a
point in the center or said Road, the
place of BEGINNING.
BEING KNOWN AS 118 1IOGES•
TOWN ROAD.
PROPERTY TAX PARCEL NO. 38.
21.0289017.
TITLE TO SAID PREMISES IS
VESTED IN DAVID MERLE KYLER
AND USA A. KYI.FR. I IIS WIFE:, AS
TENANTS BY 711F ENI1REnE.S DY
DEED FROM SANDY K. R1IOADFS,
DATED 12/8/1093 AND RECOIt)•
ED 12/20/1093 IN DEED IIOOK 311.5
PAGE 108.
Ro er M. N orgenthal, Editor
SWORN TO AND SUBSCRIBED before me this
_ 4 day of FEBRUARY 2000
IOIS E. SNYDER, Notary Pubk
Cur6d• 8010, Cumbitdond County, PA
My Cwnmia0n Expires Monh 3, 2001
? i
1.
1,
THE PATRIOT NEWS
THE SUNDAY PATRIOT NEWS
Proof of Publication
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 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 editione/Issues 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 /G
COPY Sworn to and subscrl ed before me this 251h day/o F r ery
S A L E /42 Notarial Seal ?/
Terry L. Pusses. Notary PLM NO ARY UBLIC
Hamstwrp, OaupNn Courrty
p?L E$T?Ti! SALE No. 42 lay Comasston Erpnes June e.
.mc ?bfe9 Jorrimisslon expires June 6, 2002
Civil Member, PennsyNnnia,lssodahon of Notaries
Lending C j*1,L CUMBERLAND Ct7l1N1Y SHERIFFS OFFICE
District M vs a/we COURTHOUSE
D 111 !. ly Kyler CARLISLE, PA. 17013
,'p o- - Statement of Advertising Costs
that C' , ?p To THE PATRIOT-NEWS CO., Dr. "tall ugh In talrite or parcel of For publishing the notice or publication attached
ship of Silver
hereto on the above stated dates $ 206.14
County of Cumberland and rid
clisi:
eda?"i(o atda, bounded and Probating same Notary Fee(s) $ 1.50
.INNING at to oolnt In r6,. Total S 207.64
?u wrier, Neer 35 dearer; ?d lieherr, a Receipt for Advertising Cost
nlnutrs East, 1060.95 feet to a in on
no of land noworformerly ofIvllber Asher of THE PATRIOT-NEWS and THE SUNDAY PATRIOT-NEWS, newspapers of general
!mvarl% thence id Mrd. South ss )e receipt of the aforesaid notice and publication costs and certifies that the same have
epnets f ,tronruu+ly gel forth In
rinr JVV as 65 de THE PATRIOT-NEWS CO.
0 lu a m 6 grees) East 102.65 in of rmerly of{1'illiam are i lot nnl or
By ....................................................................
Karin, his wife Iheneesalond salt
rid of Ntlllam B, Kalov and I
defy his wife, Soulh 25 degrees 45
Inulrs n d
Ncyl, 10605 f
inl
the center of the',, eelogtocetmcnar ;
in
rote along the «ntcr of said, North
cv s {VeyL 102.45 feel to a point
,he ivtii T;I sold Rwd, he place
IiI,NG K'M1q'y,N a4 I la I logrsluw n
d.
1289.017. Ax PARCEL NO. It,.
"if" As of
TLE In said
hl M pir'mlw•x I. coed in
Merle Kyfer and Liw A. Klee