HomeMy WebLinkAbout99-07240
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GOLDBECK McCAFFERTY & MCKEEVER
BY: Joseph A. Goldbeck, Jr.
Attorney I.D.#16132
Suite 500 - The Bourse Bldg.
111 S. Independence Mall East
Philadelphia, PA 19106
215-627-1322
Attorney for Plaintiff
NATIONAL CITY MORTGAGE CO
P.O. Box 1820
Dayton, OH 45401-1820
Plaintiff
VS.
DOROTHY G.A. KOLTRIDER
(Mortgagor(s) and Real Owner(s))
429 Third Street
West Fairview, PA 17025
Defendant(s)
IN THE COURT OF COMMON PLEAS
OF CUMBERLAND COUNTY
CIVIL ACTION - LAW
:ACTION OF MORTGAGE FORECLOSURE
Term
No.
CIVIL ACTION: MORTGAGE
FORECLOSURE
THIS LAW FIRM IS A DEBT COLLECTOR AND WE ARE ATTEMPTING
TO COLLECT A DEBT OWED TO OUR CLIENT. ANY INFORMATION
OBTAINED FROM YOU WILL BE USED FOR THE PURPOSE OF
COLLECTING THE DEBT.
N O T I C E
You have been sued in court. If you wish to detend against the claims set forth in the following pages,
you must take action within twenty (20) days after the Complaint and notice are served, by entering a written
appearance personally or by attorney and fll Ing in writing with the court your defenses or objections to the
claims set forth against you. You are warned that if you fail to do so the case may proceed without you and a
judgment may be entered against you by the Court without further notice for any money claimed in the Complaint
or for any other claim or relief requested by the Plaintiff. You may lose money or property or other rights
important to you.
YOU SHOULD TAKE THIS PAPER TO YOUR LAWYER AT ONCE. IF YOU DO NOT HAVE A LAWYER OR CANNOT AFFORD ONE,
GO TO OR TELEPHONE THE OFFICE SET FORTH BELOW TO FIND OUT WHERE YOU CAN GET LEGAL HELP.
Cumberland County Bar Association
2 Liberty Avenue, Carlisle, PA
(000) 990-9108
Legal Services Inc.
0 Irvine Row, Carlisle, PA 17013
(717) 243-9400
A V I S O
LE IAN DEMANDADO A USTED EN LA CORTE. SI DESEA DEFFNDERSE CONTRA LAS QUEJAS PERESENTADAS, ES
ABSOLUTAMENTE NECESSARIO DUE LISTED RESPONDA DEMIRO DE 20 DIAS DESPUES DE SER SERVIDO CON ESTA DEMANDA Y AVISO.
PARA DEFENDERSE ES NECESSARIO DUE USTED, 0 SU ABOGADO, REGISTRE CON LA CORTE EN FORMA ESCRITA, EL PUNTO DE VISTA
DE LISTED Y CUALOUIER OBJECCION CONTRA LAS OUEJAS EN ESTA DEMANDA.
RECUERDF.: SI USTED NO REPONDE A ESTA DEMANDA. SE PUEDE PROSEGUIR CON EL PROCESO SIN SU PARTICIPACION.
ENTONCES, LA MUTE PUEDE, SIN NOTIFICARIO, DECIDIR A FAVOR DEL DEMANDANTE Y REQUERIRA DUE USTED CUMPLA CON TODAS
LAS PROVISIONES DE ESTA DEMANDA. FOR RAZON DE ESA DECISION, ES POSSIBLE QUE USTED PUEDA PERDER DINERO, PROPIEDAD
U GIRDS DERECHOS IMPORTAII'ES.
LLEVE ESTA DEMANDA A ON ABOGADO IM.MEDIATAMENTE.
SI NO CONOCE A IN ABOGADO, LLAME AL "LAWYER REFERENCE SERVICE" (SERVICIO DE REFERENCIA DE ABOGADOS),
215.238-8300.
Cumberland County Oar Association
2 Liberty Avenue, Carlisle, PA
(800) 990-9100
Legal Services Inc.
0 Irvine Row, Carlisle, P,. 17013
(717) 243-9400
COMPLAINT IN MORTGAGE FORECLOSURE
1. Plaintiff is NATIONAL CITY MORTGAGE CO., P.O. Box 1820,
Dayton, OH 45401-1820.
2. The name(s) and address(es) of the Defendant(s) is/are
DOROTHY G.A. KOLTRIDER, 424 Third Street, Enola, PA 17025, who
is/are the mortgagor (s) and real owner (s) of the mortgaged property
hereinafter described.
3. On June 13, 1986, mortgagor(s) made, executed and
delivered a mortgage upon the premises hereinafter described to
SEARS MORTGAGE CORP., which mortgage is recorded in the office of
the Recorder of Deeds of Cumberland County in Mortgage Book 819,
Page 326. By Assignment of Mortgage recorded January 29, 1996, the
mortgage was assigned to Plaintiff, which Assignment is recorded in
Assignment of Mortgage Book No. 512, Page 784. These documents are
matters of public record and are incorporated herein by reference
in accordance with Pennsylvania Rule of Civil Procedure 1019(g).
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 June 1, 1999, and
each month thereafter are due and unpaid, and by the terms of said
mortgage, upon default in such payments for a period of one month,
the entire principal balance and all interest due thereon are
collectible forthwith.
The following amounts are due on the mortgage:
Principal Balance $ 25,682.37
Interest from 5/ 1/99
through 11/30/99 at 9.875% 1,480.35
Per diem interest rate at $6.9 5
Attorney's Fee at 5%
of Principal Balance 1,284.12
Late Charges 6/ 1/99-11/30/99 81.30
Monthly late charge amount at $13.55
Costs of suit and Title Search 560.00
$ 29,088.14
Escrow Balance Deficit 198.00
Monthly Escrow amount $78.21
$ 29,286.14
7. The Attorney's Fees set forth above are in conformity
with the Mortgage documents and Pennsylvania law, and, will be
collected in the event of a third party purchaser at Sheriff's
Sale. If the Mortgage is reinstated prior to the Sale reasonable
Attorney's Fees will be charged based on work actually performed.
8. Notice of Intention to Foreclose and a Notice of
Homeowners' Emergency Mortgage Assistance has been sent to
Defendant (s) by Certified and regular mail, as required by Act 160
of 1998 of the Commonwealth of Pennsylvania, on the date(s) set
forth in the true and correct copy of such notice(s) attached
hereto as Exhibit "A". The Defendant(s) has/have not had the
required face to face meeting within the required time and
Plaintiff has no knowledge of any such meeting being requested by
the Defendant(s) through the Plaintiff, the Pennsylvania Housing
Finance Agency, or any appropriate Consumer Credit Counseling
Agency.
WHEREFORE, Plaintiff demands judgment in mortgage foreclosure
the sum of $29,286.14, together with interest at the rate of $6.95,
per day and other expenses incurred by the Plaintiff which are
properly chargeable in accordance with the terms of the mortgage,
and for the foreclosure and sale of the mortgapp premises.
By:
BY: Joseph A. Goldbeck\ Jr., Esq.
Attorney for Plaintiff)
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1ERIFICATIQX
I Anita Holbrook , as the representative of the
Plaintiff corporation within named do hereby verify that I am
authorized to and do make this verification on behalf of the
Plaintiff corporation and the facts set forth in the foregoing
Complaint are true and correct to the best of my knowredge,
information and belief. I understand that false statements therein
are made subject to the penalties of 18 Pa. C.S. 4904 relating to
unsworn falsification to authorities.
Date:_ _l '1 n
Anita Holbrook
Foreclosure Supervisor
P
s
NOV. 11. 1999 14:21AM NATIONAL CITY N0. 2615 P. 3/3
Mtbf Id ® /°32National City 32I Ion9 afk Dfiva - Mia o Co.misburg
dd ,as o-'Qo, Ohio 45342
Mor`gage EX,age 9 ppeIT ® Telophona
August 09, 1999 P.O. Box 1820
Dayton. Ohio 45401-1820
Dorothy Koltrider
429 Third St
West. Fairview PA 17025
Loan No. 839902-3
Current Servicer: National City Mortgage
HOW TO CURE YOUR MORTGAGE DEFAULT (Bring it up to date).
NATURE OF THE DEFAULT-- The MORTGAGE debt held by the above lender on
your property located at:
429 Third St
West Fairview PA 17025
IS SERIOUSLY IN DEFAULT because:
YOU HAVE NOT MADE MONTHLY MORTGAGE PAYMENTS for the following month(s)
611199 through 8/1/99
and the following amount (s) are now past due:
Monthly Payments 1,061.16
Late Charges 20.64
Other Fees 7.25
Less Suspense Balance .00-
Total Due 1,089.25
YOU HAVE FAILED TO TAKE THE FOLLOWING ACTION
(Do not use if not applicable) :
HOW TO CURE THE DEFAULT - You may cure the default within thirty (30) days
HOW TO CURE THE DEFAULT
of the date of this notice BY PAYING THE TOTAL AMOUNT PAST DUE TO THE
X,MM8R, WHICH IS $ 1,089.25, PLUS ANY MORTGAGE PAYMENTS AND LATE CHARGES
WHICH BECOME DUE DURING THE THIRTY (30) DAY PERIOD,
Payments must be made either by cash. cashiarI. n1e 1 _ _r__,
National city mortgage
Attn: Collection Cashier
3232 Newmark Dr.
Miamisburg, OH 45342
You can cure any other default by taking the following action within
THIRTY (30) DAYS of the date of this letter: (Do not use if not applicable)
DR672 FT8 . Page' 1
NOV, it. 1999 4:55PM NATIONAL CITY NO. 2640 P, 2
ACT 91 NOTICE
TAKE ACTION TO SAVE
YOUR HOME FROM
FORECL' OSIJRE
.. . .
This Notice contains important legal information. If you have any
questions, representatives, at the Consumer Credit Counseling.Agency,
may be able to help explain i .,.YOU may also Want tocontact,-- a tto rney in
your area. The local -bar association may be able to help you find a lawyer.
LA NOTIFICACION,EN ADJUNTO ES DE,SUMA IMPORTANCIA, PUES
AFECTA SU DERECHO A CONTJNUAR VIVIENDO EN SO CASH. 1 NO
COMP.RrNDE EL• CONTENIDQDE.ESTA.NOTIFICACION OBTENGA•UNA
TRADUCCION INMEDITAMENTE LLAMANDO ESTA AGENCIA:' ' , ... .
(PENNSYLVANIA HOUSI!46p1 ANCE AGENCY), SIN Ci4RGOS.AL •,
NUMERO MENCIONADO•ARRIBA. PUEDES,SER ELEGIBLE,EARA UN
PRESTAMO. POR EL^ PROGRAMA LL?AMADO T HOflIIEOlIYP1ER'$,;,,
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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.
SALVAR SU CASA DE LA PERDIDA DEL DERECHO A REDIMIR SU
HIPOTECA4 i'."e t.... ' l• ?rl.r, .'• ., rt: ;_ti 'r ...'tt,r.r':.ll T 15k? _:
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NOV. 11. 1999 4:56PM NATIONAL CITY NO.2640 P. 3
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.
TEMPORARY STAY 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 of
this Notice. THIS MEETING MUST OCCUR WITHIN THE NEXT (30) DAYS. IF
CONSUMER CREDIT COUNSELING AGENCIES - 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 (3) days after the date of this
meeting;: g riahim: addresses and telephone numbers of desiqnated
located ere set forth at the end of this Notice. It is only necessary to schedule
one face-to-face meeting. Advise your lender immediately of your intentions.
APPLICATION FOR MORTGAGE 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 fill out, sign and file a completed Homeowner's Emergency
Assistance-Frftram A{iplication rvith'one bf•the designated consumer credit
counseling agencies listed at the end of this Notice. Only consumer credit
counseling agencies have 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-faoe meeting.
YOU MUST FILE YOUR APPLICATION PROMPTLY. 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.-
AGENCY ACTION - Available funds for emergency mortgage assistance are very
limited. They will be disbursed by the Agency under the eligibility criteria
NOV. 11. 1999 4:56PI-I NATIONAL CITY NO, 2640 P. 4 .
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.)
IF YOU Do NOT CURE THE DEFAULT(see page 11- If you do not cure the
default within THIRTY (30) DAYS of the date of this Notice, the lender Intends to
Sgercise its rights to accelerate the mortgage debt This means that the entire
outstanding balance of this debt will be 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 not made within THIRTY (30) DAYS, the lender, also
intends to instiuat its attomeys to start legal action to foreclose upon your
mortgage property. .^..
IF THE MORTGAGE IS FORECLOSED UPON -The mortgaged property will be
sold by the Sherdf.to pay off the mortgage debt. If the lender refers your case to its
attomeys, but you wire the de(inquendy 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 attomeys' fees actually incurred by the
lender even if they exceed $50:00. Any attorney's fees Will be added to the amount
you owe the lender, which may also include other reasonable costs. If irod cure
attorney's fees.
OTHER LENDER REMEDIES=•Tfie lender may also sue you Personally for the
61
unpaid principal balance and all other sums due under the iortgage.
RIGHT TO CURE THE DEFAULT PRIOR TO SHERIFF'S SALE - If.you*have not
cured the default within the THIRTY (30) DAY period abdi foreclosure. proceedings
have beoun..vou still have.the dahtto:cure the default atid`'716 ent•the sales ntnnv
penorming any other reauirements'under'the mortgage;-Curing your••defaultln
the manner set forth in this notice will restore your mortgage to the same
position as if you had never defaulted.
EARLIEST POSSIBLE SHERIFF'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 FOUR(4) 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
NOV. 11. 1999a 4:57PbineexNAT?ONAL CITY N0.269D g. 5
wired payment or action Will be by w„wLtin utc
lender.
' HOW TO CONTACT THE LENDER: Name of Lender: National City Mortgage
Address: 3232 Newmark Dr. Miamisburg OH 45342
Phone Number:1-800.523-6654 Fax Number: (937) 910.4057
Contact Person: COLLECTIONS DEPT.
EFFECT OF SHERIFF'S SALE -You should realize that a Sheriffs Sate will end
-- yourownership of the mortgaged property and your right to occupy iL If you
continue to live In the property after the Sheriffs Sale, a lawsuit to remove you and
your furnishing and other belongings could be started by the lender at any time.
ASSUMPTION OF MORTGAGE -You may or may not be able to sell or transfer
•-• your home to a buyer or transferee -who will assume the mortgage debt, provided
that all the outstanding payments, charges and attorney's fees and costs are paid
prior to or at ttie sale and that )he, other requirements of the mortgage are satisfied.
For additional infonmatibn please contact the Collection Dept.
YOU MAY ALSO HAVE THE RIGHT:
TO SELL THE PROPERTY TO OBTAIN MONEY TO PAY OFF THE MORTGAGE
DEBT OR TO BORROW MONEY FROM ANOTHER LENDING INSTITUTION TO
PAY OFF THIS DEBT.
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
TIMES IN ANY CALENDAR YEAR.)
TO ASSERT THE NONEXISTENCE OF 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.
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SHERIFF'S RETURN - REGULAR
CASE NO: 1999-07240 P
COMMONWEALTH OF PENNSYLVANIA:
COUNTY OF CUMBERLAND
NATIONAL CITY MORTGAGE CO
VS.
KOLTRIDER DOROTHY G A
KENNETH GOSSERT , Sheriff or Deputy Sheriff of
CUMBERLAND County, Pennsylvania, who being duly sworn according
to law, says, the within COMPLAINT - MORT FORE was served
upon KOLTRIDER DOROTHY G A the
defendant, at 17:45 HOURS, on the 13th day of December
1999 at 424 THIRD STREET
WEST FAIRVIEW, PA 17025 CUMBERLAND
County, Pennsylvania, by handing to DOROTHY KOLTRIDER
a true and attested copy of the COMPLAINT - MORT FORE
together with NOTICE
and at the same time directing Her attention to the contents thereof.
Sheriff's Costs: So answers:
Docketing 18.00
Service 9.92
Affidavit .00
Surcharge 8.00 I. I omah s fC?ne; 5 eri
$3b.?)2 102/D4/199
by
Sworn and subscribed to before me
this /<1= day of
7P_62alyri A.D.
Q„? n 7?,da, ??,
?-Pro ono a y
IN THE COURT OF COMMON PLEAS OF CUMBERLAND COUNTY
NATIONAL CITY MORTGAGE CO.
P.O. Box 1820
Dayton, OH 45401-1820
Plaintiff
VS.
DOROTHY G.A. KOLTRIDER
(Mortgagor(s) and Record
owner(s))
429 Third Street Term
No. 99-Term Civil
West Fairview, PA 17025
Defendant(s)
PRAECIPE FOR JUDGMENT
THIS LAW FIRM IS A DEBT COLLECTOR AND WE ARE ATTEMPTING TO COLLECT A
DEBT OWED TO OUR CLIENT. ANY INFORMATION OBTAINED FROM YOU WILL BE USED FOR
THE PURPOSE OF COLLECTING THE DEBT.
Enter Judgment in favor of Plaintiff and against DOROTHY G.A.
KOLTRIDER by default for want of an Answer.
(X) Assess damages as follows:
Debt $ 30.089.62
Interest 5/ 1/99 to 2/14/00
Total $
(Assessment of Damages attached) FOREG
AMO ALLEGEDFTOTBETDUEEIN THEOCOMPLAINTSAND ISOFCALCULABLEDAMAGES SUMCCERTAIN FROMS
THE COMPLAINT.
I certify that written notice of the intention to file this praecipe was
mailed or delivered to the party against whom judgment is to be entered and
to his attorney of record, if any, after the default occurred and at least
ten days prior to the date of the filing of this praecipe. A copy of he
notice is attached. R.C.P. 237.1 n / n N nfi A /6
Jos A.`Gold eck, Jr-
y for Plaintiff
50s
I.D. #16132
AND NOW ZJudgment is
entered in favor of NATIONAL CITY MORTGAGE CO., and against DOROTHY G.A.
per
CENTS ($30,089.62), as h um
of THIRTY THOUSAND IEIGHTY wNINE DOLLARS AND 62 and
the above certification.
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GOLDBECK McCAFFERTY & McKEEVER
BY: Joseph A. Goldbeck, Jr.
Attorney I.D.#16132
Suite 500 - The Bourse Bldg.
111 S. Independence Mall East
Philadelphia, PA 19106
215-627-1322
Attorney for Plaintiff
NATIONAL CITY MORTGAGE CO
P.O. Box 1820
Dayton, OH 45401-1820
Plaintiff
VS.
IN THE COURT OF COMMON PLEAS
OF CUMBERLAND COUNTY
CIVIL ACTION - LAW
:ACTION OF MORTGAGE FORECLOSURE
DOROTHY G.A. KOLTRIDER
(Mortgagor(s) and Record
Owner(s))
429 Third Street
West Fairview, PA 17025
Defendant(s)
Term
No. 99-7240 Civil
ORDER FOR JUDGMENT
Please enter Judgment in favor of NATIONAL CITY MORTGAGE
CO., and against DOROTHY G.A. KOLTRIDER for failure to file an
Answer in the above action within (20) days (or sixty (60) days
if defendant is the United States of America) from the date of
service of the Complaint, in the sum of THIRTY THOUSAND EIGHTY
NINE DOLLARS AND 62 CENTS ($30,089.4Aneoy Goldb ck, Jrfor Plaintiff
I hereby certify that the above names are correct and that
the precise residence address of the judgment creditor is P.O.
Box 1820, Dayton, OH 45401-1820 and that the name(s) and last
known address(es) of the Defendant(s) is/are DOROTHY G.A.
KOLTRIDER, 424 Third Street, Enola 9GD st Fai iew 70 ;
CK McC FERTY & M EVER
oseph A. Godbeck, orney for Plaintiff
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ASSESSMENT OF DAMAGES
TO THE PROTHONOTARY:
Kindly assess the damages in this case to be as follows:
$ 25,682.37
Principal balance
Interest from 5/ 1/99 through 2/14/00 2,008.55
Attorney's Fee at 5% of principal balance 1,284.12
Late Charges 121.95
560.00
Costs of Suit and Title Search
$ 29,656.99
432.63
Escrow Balance Deficit
$ 30,089.62
GOLD C McCAFFE & McKEEVE
BY: seph A. Go P eck, Jr.
Attorney for Plaintiff
AND NOW, this /-) day of damages are assessed as above.
2000
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TO: DOROTHY G.A. KOLTRIDER
424 Third Street
West Fairview, PA 17025
NATIONAL CITY MORTGAGE CO.
P.O. Box 1820
Dayton, OH 45401-1820
Plaintiff
Vs.
DOROTHY G.A. KOLTRIDER (Mortgagor(s))
(Record Owner(s))
429 Third Street
West Fairview, PA 17025
Defendant(s)
IN THE COURT OF COMMON PLEAS
OF CUMBERLAND COUNTY
CIVIL ACTION - LAW
ACTION OF MORTGAGE FORECLOSURE
Term
No. 99-7240 CIVIL
THIS LAW FIRM IS A DEBT COLLECTOR AND WE ARE ATTEMPTING TO COLLECT A
DEBT OWED TO OUR CLIENT. ANY INFORMATION OBTAINED FROM YOU WILL BE USED
FOR THE PURPOSE OF COLLECTING THE DEBT.
TO: DOROTHY G.A. KOLTRIDER
424 Third Street
West Fairview, PA 17025
DATE OF THIS NOTICE: January 4, 2000
IMPORTANT NOTICE
YOU ARE IN DEFAULT BECAUSE YOU HAVE FAILED TO ENTER A WRITTEN
APPEARANCE PERSONALLY OR BY ATTORNEY AND FILE IN WRITING WITH THE COURT
YOUR DEFENSES OR OBJECTIONS TO THE CLAIMS SET FORTH AGAINST YOU. UNLESS
YOU ACT WITHIN TEN (10) DAYS FROM THE DATE OF THIS NOTICE, A JUDGMENT
MAY BE ENTERED AGAINST YOU WITHOUT A HEARING AND YOU MAY LOSE YOUR
PROPERTY OR OTHER IMPORTANT RIGHTS. YOU SHOULD TAKE THIS NOTICE TO A
LAWYER AT ONCE. IF YOU DO NOT HAVE A LAWYER OR CANNOT AFFORD ONE, GO TO
OR TELEPHONE THE FOLLOWING OFFICE TO FIND OUT WHERE YOU CAN GET LEGAL
HELP:
Cumberland County Bar Association
2 Liberty Avenue, Carlisle, PA
(800) 990-9108
/s/ A03e04 _.i. coldlech. Jr.
GOLDBECK MCCAFFERTY & MCKEEVER
BY: Joseph A. Goldbeck, Jr., Esq.
Attorney for Plaintiff
Suite 500 - The Bourse Bldg.
111 S. Independence Mall East
Philadelphia, PA 19106
215-627-1322
TO: DOROTHY G.A. KOLTRIDER
429 Third Street
West Fairview, PA 17025
NATIONAL CITY MORTGAGE CO.
P.O. Box 1820
Dayton, OH 45401-1820
Plaintiff
VS.
DOROTHY G.A. KOLTRIDER (Mortgagor(s))
(Record Owner(s))
429 Third Street
West Fairview, PA 17025
Defendant(s)
IN THE COURT OF COMMON PLEAS
OF CUMBERLAND COUNTY
CIVIL ACTION - LAW
ACTION OF MORTGAGE FORECLOSURE
Term
No. 99-7240 CIVIL
THIS LAW FIRM IS A DEBT COLLECTOR AND WE ARE ATTEMPTING TO COLLECT A
DEBT OWED TO OUR CLIENT. ANY INFORMATION OBTAINED FROM YOU WILL BE USED
FOR THE PURPOSE OF COLLECTING THE DEBT.
TO: DOROTHY G.A. KOLTRIDER
429 Third Street
West Fairview, PA 17025
DATE OF THIS NOTICE: January 4, 2000
IMPORTANT NOTICE
YOU ARE IN DEFAULT BECAUSE YOU HAVE FAILED TO ENTER A WRITTEN
APPEARANCE PERSONALLY OR BY ATTORNEY AND FILE IN WRITING WITH THE COURT
YOUR DEFENSES OR OBJECTIONS TO THE CLAIMS SET FORTH AGAINST YOU. UNLESS
YOU ACT WITHIN TEN (10) DAYS FROM THE DATE OF THIS NOTICE, A JUDGMENT
MAY BE ENTERED AGAINST YOU WITHOUT A HEARING AND YOU MAY LOSE YOUR
PROPERTY OR OTHER IMPORTANT RIGHTS. YOU SHOULD TAKE THIS NOTICE TO A
LAWYER AT ONCE. IF YOU DO NOT HAVE A LAWYER OR CANNOT AFFORD ONE, GO TO
OR TELEPHONE THE FOLLOWING OFFICE TO FIND OUT WHERE YOU CAN GET LEGAL
HELP:
Cumberland County Bar Association
2 Liberty Avenue, Carlisle, PA
(800) 990-9108
/s/ 466ep4 Coldbech. Jr.
GOLDBECK MCCAFFERTY & MCKEEVER
BY: Joseph A. Goldbeck, Jr., Esq.
Attorney for Plaintiff
Suite 500 - The Bourse Bldg.
111 S. Independence Mall East
Philadelphia, PA 19106
215-627-1322
TO: DOROTHY G.A. KOLTRIDER
424 Third Street
Enola, PA 17025
NATIONAL CITY MORTGAGE CO.
P.O. Box 1820
Dayton, OH 45401-1820
Plaintiff
Vs.
DOROTHY G.A. KOLTRIDER (Mortgagor(s))
(Record Owner(s))
429 Third Street
West Fairview, PA 17025
Defendant(s)
IN THE COURT OF COMMON PLEAS
OF CUMBERLAND COUNTY
CIVIL ACTION - LAW
ACTION OF MORTGAGE FORECLOSURE
Term
No. 99-7240 CIVIL
THIS LAW FIRM IS A DEBT COLLECTOR AND WE ARE ATTEMPTING TO COLLECT A
DEBT OWED TO OUR CLIENT. ANY INFORMATION OBTAINED FROM YOU WILL BE USED
FOR THE PURPOSE OF COLLECTING THE DEBT.
TO: DOROTHY G.A. KOLTRIDER
424 Third Street
Enola, PA 17025
DATE OF THIS NOTICE: January 4, 2000
IMPORTANT NOTICE
YOU ARE IN DEFAULT BECAUSE YOU HAVE FAILED TO ENTER A WRITTEN
APPEARANCE PERSONALLY OR BY ATTORNEY AND FILE IN WRITING WITH THE COURT
YOUR DEFENSES OR OBJECTIONS TO THE CLAIMS SET FORTH AGAINST YOU. UNLESS
YOU ACT WITHIN TEN (10) DAYS FROM THE DATE OF THIS NOTICE, A JUDGMENT
MAY BE ENTERED AGAINST YOU WITHOUT A HEARING AND YOU MAY LOSE YOUR
PROPERTY OR OTHER IMPORTANT RIGHTS. YOU SHOULD TAKE THIS NOTICE TO A
LAWYER AT ONCE. IF YOU DO NOT HAVE A LAWYER OR CANNOT AFFORD ONE, GO TO
OR TELEPHONE THE FOLLOWING OFFICE TO FIND OUT WHERE YOU CAN GET LEGAL
HELP:
Cumberland County Bar Association
2 Liberty Avenue, Carlisle, PA
(800) 990-9108
/s/ if w4 j Caoldbech, Jr.
GOLDBECK MCCAFFERTY & MCKEEVER
BY: Joseph A. Goldbeck, Jr., Esq.
Attorney for Plaintiff
Suite 500 - The Bourse Bldg.
111 S. Independence Mall East
Philadelphia, PA 19106
215-627-1322
VERIFICATION OF NON-MILITARY SERVICE
The undersigned, as the representative for the Plaintiff
corporation within named do hereby verify that I am authorized to
make this verification on behalf of the Plaintiff corporation and
that the facts set forth in the foregoing verification of Non-
Military Service are true and correct to the best of my knowledge,
information and belief. I understand that false statements therein
are made subject to penalties of 18 Pa. C.S. 4904 relating to
unsworn falsification to authorities.
1. That the above named Defendant, DOROTHY G.A. KOLTRIDER,
is about unknown years of age, that Defendant's last known
residence is 424 Third Street, Enola (West Fairview), PA 17025 and
is engaged in the unknown business located at unknown address.
2. That Defendant is 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 Action of Congress of
1940 and its Amendments.
1
Date:
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839902-3 - KOLTRIDER, DOROTHY G.A.
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PRAECIPE FOR WRIT OF EXECUTION - (MORTGAGE FORECLOSURE)
P.R.C.P 3180-3183
Joseph A. Goldbeck, Jr.
Attorney I.D.#16132
Suite 500 - The Bourse Bldg.
111 S. Independence Mall East
Philadelphia, PA 19106
215-627-1322
Attorney for Plaintiff
NATIONAL CITY MORTGAGE CO
'P.O. Box 1820
Dayton, OH 45401-1820
Plaintiff
VS.
DOROTHY G.A. KOLTRIDER
(Mortgagor(s) and Record
Owner(s))
429 Third Street
West Fairview, PA 17025
Defendant(s)
IN THE COURT OF COMMON PLEAS
OF CUMBERLAND COUNTY
CIVIL ACTION - LAW
:ACTION OF MORTGAGE FORECLOSURE
Term
No. 99-7240 Civil
PRAECIPE FOR WRIT OF EXECUTION
TO THE PROTHONOTARY:
Issue Writ of Execution in the above matter:
Amount Due
Interest from 5/ 1/99 to
2/14/00 at 9.875%
$ 30.089.62
(Costs to be added) $
J42 o eck, Jr.
A o ey for Plaintiff
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ALL THAT CERTAIN lot or tract of land situate in the Borough of West
Fairview, Cumberland County, Pennsylvania, more particularly
bounded and described as follows according to survey of Ernest J.
Walker, Professional Engineer, dated October 15, 1968, to wit:
BEGINNING at a point on the eastern line of Third Street being 180
feet in a southerly direction by same from Locust Street; thence North
53 degrees 46 minutes East 128 feet to an alley; thence South 36
degrees 49 minutes East by the western line of said alley 29.94 feet
to a point at an iron pin at the corner of Lot No. 10; thence by the
northern line of Lot No. 10 South 53 degrees 46 minutes West 130 feet
to the eastern line of Third Street; thence North 33 degrees West by
the Eastern line of Third Street, 30 feet to a point, the place of
BEGINNING.
BEING Lot No. 11, Section B of H.R. May's Addition to the town of
West Fairview, recorded in the Cumberland County Recorder's Office
in Plan Book 1, Page 23.
HAVING THEREON ERECTED a two and one-half story, frame
dwelling house known and numbered as 429 Third Street.
IMPROVEMENTS consist of a residential dwelling.
BEING PREMISES: 429 Third Street, West Fairview, PA 17025
SOLD as the property of DOROTHY G.A. KOLTRIDER
TAX PARCEL #45-17-1044-038
GOLDBECK McCAFFERTY & McKEEVER
BY: Joseph A. Goldbeck, Jr.
Attorney I.D.#16132
Suite 500 - The Bourse Bldg.
111 S. Independence Mall East
Philadelphia, PA 19106
215-627-1322
Attorney for Plaintiff
NATIONAL CITY MORTGAGE CO.
P.O. Box 1820
Dayton, OH 45401-1820
Plaintiff
VS.
DOROTHY G.A. KOLTRIDER
(Mortgagor(s) and Record
Owner(s))
429 Third Street
West Fairview, PA 17025
Defendant(s)
IN THE COURT OF COMMON PLEAS
OF CUMBERLAND COUNTY
CIVIL ACTION - LAW
:ACTION OF MORTGAGE FORECLOSURE
Term
No. 99-7240 Civil
AFFIDAVIT PURSUANT TO RULE 3129
NATIONAL CITY MORTGAGE CO., Plaintiff in the above action,
by its attorney, Joseph A. Goldbeck, Jr., Esquire, sets forth as
of the date the praecipe for the writ of execution was filed the
following information concerning the real property located at:
429 Third Street, West Fairview, PA 17025
1. Name and address of owner (s) or Reputed Owner(s):
DOROTHY G.A. KOLTRIDER
424 Third Street
Enola (West Fairview), PA 17025
2. Name and address of Defendant(s) in the judgment:
DOROTHY G.A. KOLTRIDER
424 Third Street
Enola (West Fairview), PA 17025
3. Name and last known address of every judgment creditor whose
judgment is a record lien on the property to be sold:
EAST PENNSBORO TOWNSHIP
98 5. Enola Drive
Enola, PA 17025
4. Name and address of the last recorded holder of every mortgage ?
K
of record:
SECURITY SAVINGS MORTGAGE CORP. y
p.0. Box 8469
Canton, OH 44711
5. Name and address of every other person who has any record
interest in or the record lien on the property and whose interest may
be affected by sale:
6. Name and address of everecothe person in thompthe plaintiff
has knowledge who has a sale.
may be affected by
7. Name and address of every other
has knowledge who has any interest
affected by the sale.
person of whom the plaintiff
in the property which may be
(attach separate sheet if more space is needed)
I verify that the statements made in
nothis affidavit are true
and correct to the best of my personal and belief. I understand ofa18fPaSeC.statements S. herei4904nrelatingare
subject to the penalties
unsworn falsification to authorities.
4FETY :DATED: February 11, 2000 GO B K R& MIKE ,ER
BY: Joseph A. Goldbeck, Jr., s4•
Attorney for Plaintiff
a
GOLDBECK McCAFFERTY & McKEEVER
BY: Joseph A. Goldbeck, Jr.
Attorney I.D.#16132
Suite 500 - The Bourse Bldg.
111 S. Independence Mall East
Philadelphia, PA 19106
215-627-1322
Attorney for Plaintiff
NATIONAL CITY MORTGAGE CO.
P.O. Box 1820.
Dayton, OH 45401-1820
Plaintiff
VS.
DOROTHY G.A. KOLTRIDER
(Mortgagor (s) and Record
owner(s))
429 Third Street
West Fairview, PA 17025
Defendant(s)
TO:
IN THE COURT OF COMMON PLEAS
OF CUMBERLAND COUNTY
CIVIL ACTION - LAW
:ACTION OF MORTGAGE FORECLOSURE
Term
No. 99-7240 Civil
THIS LAW FIRM IS A DEBT COLLECTOR AND WE ARE ATTEMPTING
TO COLLECT A DEBT. THIS NOTICE IS SENT TO YOU IN AN
ATTEMPT TO COLLECT A DEBT. ANY INFORMATION OBTAINED
FROM YOU WILL BE USED FOR THAT PURPOSE.
NOTICE OF SHERIFF'S SALE OF REAL PROPERTY
DOROTHY G.A. KOLTRIDER
424 Third Street
Enola (West Fairview), PA 17025
Your house at 429 Third Street, West
scheduled to be sold at Sheriff's Sale on
a.m., in Cumberland County, Commissioners
Floor, Courthouse, Carlisle, PA 17013 to
judgment of $30,089.62 obtained by NATION
against you.
Fairview, PA 17025 is
June 7, 2000, at 10:00
Hearing Room, 2nd
enforce the court
%L CITY MORTGAGE CO.
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 NATIONAL CITY
MORTGAGE CO., the back payments, late charges, costs and
reasonable attorney's fees due. To find out how much you must pay
call: 215-627-1322
2. You may be able to stop the sale by filing a petition asking
the Court to strike or open judgment, if the judgment was
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GOLDBECK McCAFFERTY & McKEEVER
Joseph A. Goldbeck, Jr.
Attorney I.D.#16132
Suite 500 - The Bourse Bldg.
111 S. Independence Mall East
Philadelphia, PA 19106
215-627-1322
Attorney for Plaintiff
NATIONAL CITY MORTGAGE CO
P.O. Box 1820
Dayton, OH 45401-1820
Plaintiff
VS.
DOROTHY G.A. KOLTRIDER
(Mortgagor(s) and Record
Owner(s))
429 Third Street
West Fairview, PA 17025
Defendant(s)
IN THE COURT OF COMMON PLEAS
OF CUMBERLAND COUNTY
CIVIL ACTION - LAW
:ACTION OF MORTGAGE FORECLOSURE
Term
No. 99-7240 Civil
CERTIFICATION AS TO THE SALE OF REAL PROPERTY
I, Joseph A. Goldbeck, Jr., Esquire hereby certify that I am
the attorney of record for the Plaintiff in this action, and I
further certify that this property is subject to Act 91 of 1983
and the Plaintiff has complied with all the provisions of the
Act.
d ? A'
Jo h . Gol dbeck, Jr.
Att rney for Plaintiff
_. __. __ L
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____ _ ?/?r :?
ALL THAT CERTAIN lot or tract of land situate in the Borough of West
Fairview, Cumberland County, Pennsylvania, more particularly
bounded and described as follows according to survey of Ernest J.
Walker, Professional Engineer, dated October 15, 1968, to wit:
BEGINNING at a point on the eastern line of Third Street being 180
feet in a southerly direction by same from Locust Street; thence North
53 degrees 46 minutes East 128 feet to an alley; thence South 36
degrees 49 minutes East by the western line of said alley 29.94 feet
to a point at an iron pin at the corner of Lot No. 10; thence by the
northern line of Lot No. 10 South 53 degrees 46 minutes West 130 feet
to the eastern line of Third Street; thence North 33 degrees West by
the Eastern line of Third Street, 30 feet to a point, the place of
BEGINNING.
BEING Lot No. 11, Section B of H.R. May's Addition to the town of
West Fairview, recorded in the Cumberland County Recorder's Office
in Plan Book 1, Page 23.
HAVING THEREON ERECTED a two and one-half story frame
dwelling house known and numbered as 429 Third Street.
TAX PARCEL #45-17-1044-038.
r,OLDBECK McCAFFERTY & McKEEVER
BY: Joseph A. Goldbeck, Jr.
Attorney I.D.416132
Suite 500 - The Bourse Bldg.
111 S. Independence Mall East
Philadelphia, PA 19106
215-627-1322
Attorney for Plaintiff
NATIONAL CITY MORTGAGE CO.
P.O. Box 1820
Dayton, OH 45401-1820
Plaintiff
Vs.
IN THE COURT OF COMMON PLEAS
OF CUMBERLAND COUNTY
DOROTHY G.A. KOLTRIDER (Mortgagor(s) CIVIL ACTION - LAW
and Record Owner(s))
(Record Owner(s)) ACTION OF MORTGAGE FORECLOSURE
429 Third Street Term
West Fairview, PA 17025 No. 99-7240 Civil
Defendant(s)
CERTIFICATE OF SERVICE
PURSUANT TO Pa.R.C.P. 3129.2(c)(2)
Joseph A. Goldbeck, Jr., Esquire, Attorney for Plaintiff, hereby
certifies that service on the Defendants of the Notice of Sheriff Sale was
mad by:
( ) Personal Service by the Sheriff's Office%ew@e-- ==` (copy of
` return attached).
( ) Certified mail by Joseph A. Goldbeck, Jr. (original green Postal
return receipt attached).
( ) Certified mail by Sheriff's Office.
( ) Ordinary mail by Joseph A. Goldbeck, Jr., Esquire to Attorney for
Defendant(s) of record (proof of mailing attached).
( ) Acknowledgment of Sheriff's Sale by Attorney for Defendant(s) (proof
of acknowledgment attached).
( ) Ordinary mail by Sheriff's Office to Attorney for Defendant(s) of
record.
IF SERVICE WAS ACCOMPLISHED BY COURT ORDER.
( ) Premises was posted by Sheriff's office/competent adult (copy of
return attached).
( ) Certified Mail & ordinary mail by Sheriff's Office (copy of return
attached).
( ) Certified Mail & ordinary mail by Joseph A. Goldbeck, Jr. (original
receipt (s) for Certified mail attached).
Pursuant to the Affidavit under Rule 3129 (copy attached), service on all
lienholders (if any) has been made by ordinary mail by Joseph A. Goldbeck,
Jr., Esquire (copies of proofs of mailing attached).
The undersigned understands that the statements
penalties provided by 18 P.S. Section 4904.
Rsectu y
GO K McC?
BY Joseph Ai
Attorney for
herein are subject to the
m - d,
FFERTY & Mc E ER
Goldbeck, Jr.)
Plaintiff
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TO: l
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( 424 Third Street
Enola (West Fairview), PA 17025
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SENDER: GOLDBECN MCCAFFERtt 000
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National City Mortgage Co
-vs-
Dorothy G.A. Koltrider
In the Court of Common Pleas of
Cumberland County, Pennsylvania
No. 99-7240 Civil
Kathy J. Clarke, Deputy Sheriff who being duly sworn according to law, says on
February 24, 2000 at 5:53 o'clock P.M.EST, site served a true copy of Real Estate Writ
Notice and Description in the above entitled action upon the within named defendant to
wit: Dorothy Koltrider, by making known unto Dorothy Koltrider at 424 Third Street,
West Fairview, Cumberland County, Pennsylvania, its contents and at the same time
handing to her personally the said true and attested copies of the same.
Harold J Weary Deputy Sheriff, who being duly sworn according to law, says on
March 29, 2000 at 5:44 o'clock P.M. EST, he posted a copy of Real Estate Writ Notice
Poster and Description in the above entitled action upon the property of Dorothy
Koltrider located at 429 Third Street, West Fairview, Cumberland County, Pennsylvania
according to law.
R. Thomas Kline, Sheriff who being duly sworn according to law, says he served the
above Real Estate Writ Notice Poster and Description in the following manner: The
Sheriff mailed a notice of the pendency of the action to Dorothy Koltrider by First Class
to her last known the date of March Third Street, West Fairview,
Mail
2000 and never reurnedlt
was mailed under to the Sheriff s Office.
So acts
R. Thomas Kline, Sheriff
B
Real Estate Deputy
GOLDBECK McCAFFERTY & MCKEEVER
BY: Joseph A. Goldbeck, Jr.
Attorney I.D.#16132
Suite 500 - The Bourse Bldg.
111 S. Independence Mall East
Philadelphia, PA 19106
215-627-1322
Attorney for Plaintiff
NATIONAL CITY MORTGAGE CO.
P.O. Box 1820
Dayton, OH 45401-1820
Plaintiff
VS.
DOROTHY G.A. KOLTRIDER
(Mortgagor(s) and Record
Owner(s))
429 Third Street
West Fairview, PA 17025
Defendant(s)
IN THE COURT OF COMMON PLEAS
OF CUMBERLAND COUNTY
CIVIL ACTION - LAW
:ACTION OF MORTGAGE FORECLOSURE
Term
No. 99-7240 Civil
AFFIDAVIT PURSUANT TO RULE 3129
NATIONAL CITY MORTGAGE CO., Plaintiff in the above action,
by its attorney, Joseph A. Goldbeck, Jr., Esquire, sets forth as
of the date the praecipe for the writ of execution was filed the
following information concerning the real property located at:
429 Third Street, West Fairview, PA 17025
1. Name and address of Owner(s) or Reputed Owner(s) :
DOROTHY G.A. KOLTRIDER
424 Third Street
Enola (West Fairview), PA 17025
2. Name and address of Defendant(s) in the judgment:
DOROTHY G.A. KOLTRIDER
424 Third Street
Enola (West Fairview), PA 17025
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STATE OF PENNSYLVANIA,
COUNTY OF CUMBERLAND SS.
Robert P Ziegler
I------------------------------------------------------------------------------- Recorder of
Deeds in and for said County and State do hereby certify that the Sheriff's Deed in which ----------------
Federal Natl Mtg Assoc
---------------------------•----------------------------------------------°-------- is the grantee
the same having been sold to said grantee on the ---- 5th--------------------------------------- day of
-------------JulY-------- x2000 _ under and by virtue of a writ ---------_____
Execution 17th
----- --- ---------- ------------------------issued on the -------------------------------------
day of ____-_ Feb --------------- A D xfg000__, out of the Court of Comman Pleas of said County as of
------------- Civil ----------- Term, 19 99 ----
------------------------------------------------------
Number------7240 ---, at the suit of ---- National-Slaty-kttg_S.u.----------------------------------
------------------------------------ against -------- Iyorothx_G A Koltrider------------------ is
------
duly recorded in Sheriff's Deed Book No. 226 ________, Page 479________.
IN TESTIMONY WHEREOF, I have hereunto
set my hand and seal of said office this day
of ---------?- ---------- A. D.,#1- 47-- ?--
--- ?
--------------- - -?= ---------
<, Recrorder of Deeds
RataNtr M ONO aaobdtal Ctutb. Cttisq, f#
ly fxmi? LaWeM tM fltttl tlm4l td laa 290t
National City Mortgage Co In the Court of Common Pleas of
-vs- Cumberland County, Pennsylvania
Dorothy G.A. Koltrider No. 99-7240 Civil
Kathy J. Clarke, Deputy Sheriff who being duly sworn according to law, says on
February 24, 2000 at 5:53 o'clock P.M.EST, she served a true copy of Real Estate Writ
Notice and Description in the above entitled action upon the within named defendant to
wit: Dorothy Koltrider, by making known unto Dorothy Koltrider at 424 Third Street,
West Fairview, Cumberland County, Pennsylvania, its contents and at the same time
handing to her personally the said true and attested copies of the same.
Harold J Weary Deputy Sheriff, who being duly sworn according to law, says on
March 29, 2000 at 5:44 o'clock P.M. EST, he posted a copy of Real Estate Writ Notice
Poster and Description in the above entitled action upon the property of Dorothy
Koltrider located at 429 Third Street, West Fairview, Cumberland County, Pennsylvania
according to law.
R. Thomas Kline, Sheriff who being duly sworn according to law, says he served the
above Real Estate Writ Notice Poster and Description in the following manner: The
Sheriff mailed a notice of the pendency of the action to Dorothy Koltrider by First Class
Mail to her last known address 424 Third Street, West Fairview, Pennsylvania. This letter
was mailed under the date of March 30, 2000 and never returned to the Sheriff's Office.
R. Thomas Kline, Sheriff, who being duly sworn according to law, says that after due
and legal notice had been given according to law, exposed the above described premises
at public venue or outcry at Court House, Carlisle, Cumberland County, Pennsylvania on
July 5, 2000 at 10:00 o'clock A.M. and sold the same for the sum of $ 1.00 to Attorney
Leon P. Haller for Federal National Mortgage Association. It being the highest bid and
best price quoted for the same Federal National Mortgage Association being the buyer in
this execution paid to Sheriff R. Thomas Kline the sum of $ 740.72 it being costs.
Sheriffs Costs:
Docketing 30.00
Poundage 14.52
Posting Bills 15.00
Advertising 15.00
Acknowledging Deed 30.00
Auctioneer 10.00
Law Library .50
County 1.00
Mileage 19.84
Certified Mail .86
Levy 15.00
Surcharge 20.00
Postpone sale 20.00
Law Journal 256.10
Patriot News 216.60
Share of Bills 24.80
Distribution of Proceeds 25.00
Sheriffs Deed 26.50
$ 740.72 pd by atty
7/31/00
Swom and Subscribed To Before Me
This ,7 Day of C...r So?Q
2000, A.D. s 4&.1-
R. Thomas Kline,Sheriff
Proth notary By f
Real Estate Deputy
J
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TIE PATRIOT NEVUS
THE SUNDAY PATRIOT NEVUS
Proof of Publication
Underficl No. 587. Bbbmued May 16. 1929
Commonwealth of Pennsylvania, County of Dauphin) ss
Michael Morrow being duly sworn according to law, deposes and says:
That he is the Assistant Controller of THE PATRIOT-NEWS CO., a corporation organized and existing under the laws
of the Commonwealth of Pennsylvania, with Its principal office and place of business at 812 to 818 Market Street, in
the City of Harrisburg, County of Dauphin, State of Pennsylvania, owner and publisher of THE PATRIOT-NEWS and
THE SUNDAY PATRIOT-NEWS newspapers of general circulation, printed and published at 812 to 818 Market Street,
in the City, County and State aforesaid; that THE PATRIOT-NEWS and THE SUNDAY PATRIOT-NEWS were established
March 4th, 1854, and September 18th, 1949, respectively, and all have been continuously published ever since;
That the printed notice or publication which is securely attached hereto is exactly as printed and published In
their regular daily and/or Sunday and Metro editions/issues which appeared on the 2nd, 9th and 16th day(s) of May
2000. That neither he nor said Company is interested in the subject matter of said printed notice or advertising, and
that all of the allegations of this statement as to the time, place and character of publication are true; and
That he has personal knowledge of the facts aforesaid and is duly authorized and empowered to verify this
statement on behalf of The Patriot-News Co. aforesaid by virtue 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 Coun y Dauphin in Miscellaneous Book "M",
Volume 14, Page 317. I () 'v-,i
PUBLICATION _ FLU ___
COPY Sworn to and subscribed before m Is nd day7JunP 0 A.D.
Seel
Terry L. Russell, Nelary Public
No""'
/IsuisDurq, o.UGNn COumy
L W COmrraslon Expires June 6.2002 N ARY PUBLIC
Member, Pennsylvania Association 01 Nel Ys commission expires June 6, 2002
CUMBERLAND COUNTY SHERIFFS OFFICE
CUMBERLAND COUNTY 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 $ 215.10
Probating same Notary Fee(s) $ 1.50
Total $ 216.60
Publisher's Receipt for Advertising Cost
THE PATRIOT-NEWS CO., publisher of THE PATRIOT-NEWS and THE SUNDAY PATRIOT-NEWS, newspapers of general
circulation, hereby acknowledge receipt of the aforesaid notice and publication costs and certifies that the same have
been duly paid. THE PATRIOT-NEWS CO.
By ....................................................................
SALE#14
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:
APRIL 28, MAY 5, 12, 2000
Affiant further deposes that he is authorized to verify this statement by the Cumberland
Law Journal, a legal periodical of general circulation, and that he is not interested in the subject
matter of the aforesaid notice or advertisement, and that all allegations in the foregoing
statements as to time, place and character of publication are true.
REAL ESTATE BALE NO. 14
writ No. 99.7240 Civil _
National City Mortgage Co. Roger M. Morgenthal, Editor
VS.
Dorothy G.A. Koltnder
Atty.: Flank Federman
ALL THAT CERTAIN lot or tract of
land situate In the Township of East
Pennsboro (formerly the Borough of
West Fairview), Cumberland County.
Pennsylvania, more particularly
bounded and described as follows
according to survey of Ernest J.
Walker, Proressional Engineer. dated
October 15, 1968, to wit:
BEGINNING at a point on the
eastern line of Third Street being 180
feet In a southerly direction by same
from Locust Street: thence North 53
degrees 46 minutes East 128 feet to
SWORN TO AND SUBSCRIBED before me this
12 day of MAY. 2000
hotA;y,sy$W'
LLOIS E. SNYDEP., Wohory Pubac
a taro, CurnborirrJ County, PA
mmirwon Er;pina Morch 5, 2001
i. r
GOLDBECK McCAFFERTY & McKEEVER
BY: Joseph A. Goldbeck, Jr.
Attorney I.D.416132
Suite 500 - The Bourse Bldg.
111 S. Independence Mall East
Philadelphia, PA 19106
215-627-1322
Attorney for Plaintiff
NATIONAL CITY MORTGAGE CO
P.O. Box 1820
Dayton, OH 45401-1820
Plaintiff
VS.
DOROTHY G.A. KOLTRIDER
(Mortgagor(s) and Record
Owner(s))
429 Third Street
West Fairview, PA 17025
Defendant(s)
IN THE COURT OF COMMON PLEAS
OF CUMBERLAND COUNTY
CIVIL ACTION - LAW
:ACTION OF MORTGAGE FORECLOSURE
Term
No. 99-7240 Civil
AFFIDAVIT PURSUANT TO RULE 3129
NATIONAL CITY MORTGAGE CO., Plaintiff in the above action,
by its attorney, Joseph A. Goldbeck, Jr., Esquire, sets forth as
of the date the praecipe for the writ of execution was filed the
following information concerning the real property located at:
429 Third Street, West Fairview, PA 17025
1. Name and address of Owner(s) or Reputed Owner(s) :
DOROTHY G.A. KOLTRIDER
424 Third Street
Enola (West Fairview), PA 17025
2. Name and address of Defendant(s) in the judgment:
DOROTHY G.A. KOLTRIDER
424 Third Street
Enola (West Fairview), PA 17025
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GOLDBECK McCAFFERTY & MCKEEVER
BY: Joseph A. Goldbeck, Jr.
Attorney I.D.1116132
Suite 500 - The Bourse Bldg.
111 S. Independence Mall East
Philadelphia, PA 19106
215-627-1322
Attorney for Plaintiff
NATIONAL CITY MORTGAGE CO.
P.O. Box 1820
Dayton, OH 45401-1820
Plaintiff
VS.
DOROTHY G.A. KOLTRIDER
(Mortgagor(s) and Record
owner(s))
429 Third Street
West Fairview, PA 17025
Defendant(s)
IN THE COURT OF COMMON PLEAS
OF CUMBERLAND COUNTY
CIVIL ACTION - LAW
:ACTION OF MORTGAGE FORECLOSURE
Term
No. 99-7240 Civil
THIS LAW FIRM IS A DEBT COLLECTOR AND WE ARE ATTEMPTING
TO COLLECT A DEBT. THIS NOTICE IS SENT TO YOU IN AN
ATTEMPT TO COLLECT A DEBT. ANY INFORMATION OBTAINED
FROM YOU WILL BE USED FOR THAT PURPOSE.
NOTICE OF SHERIFF'S SALE OF REAL PROPERTY
TO:
DOROTHY G.A. KOLTRIDER
424 Third Street
Enola (West Fairview), PA 17025
Your house at 429 Third Street, West Fairview, PA 17025 is
scheduled to be sold at Sheriff's Sale on June 7, 2000, at 10:00
a.m., in Cumberland County, Commissioners Hearing Room, 2nd
Floor, Courthouse, Carlisle, PA 17013 to enforce the court
judgment of $30,089.62 obtained by NATIONAL CITY MORTGAGE CO.
against you.
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 NATIONAL CITY
MORTGAGE CO., the back payments, late charges, costs and
reasonable attorney's fees due. To find out how much you must pay
call: 215-627-1322
2. You may be able to stop the sale by filing a petition asking
the Court to strike or open 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 below 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 NOT 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 price
by calling the Sheriff of Cumberland County at (717) 240-6390.
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 the Sheriff of Cumberland County at (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 a 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 thirty (30) days from the
date of the Sheriff's Sale. This schedule will state who will be
receiving that money. The money will be paid out in accordance
with this schedule unless exceptions (reasons why the proposed
distribution is wrong) are filed with the Sheriff within ten (10)
days after the schedule of distribution is filed.
7. You may also have other rights and defenses, or ways of
getting your house 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 Bar Association
2 Liberty Avenue, Carlisle, PA
(800) 990-9108
Legal Services Inc.
8 Irvine Row, Carlisle, PA 17013
(717) 241-9400
P. 2/2
FE9 22 '00 10:49AM
ALL THAT CERTAIN lot or tract of land situate in the Township of East
Pennsboro (formerly the Borough of West Fairview), Cumberland
County, Pennsylvania, more particularly bounded and described as
follows according to survey of Ernest J. Walker, Professional Engineer,
dated October 15, 1968, to wit:
BEGINNING at a point on the eastern line of Third Street being 180
feet in a southerly direction by same from Locust Street; thence North
53 degrees 46 minutes East 128 feet to an alley; thence South 36
degrees 49 minutes East by the western line of said alley 29.94 feet
to a point at an iron pin at the corner of Lot No. 10; thence by the
northern line of Lot No. 10 South 53 degrees 46 minutes West 130 feet
to the eastern line of Third Street; thence North 33 degrees West by
the Eastern line of Third Street, 30 feet to a point, the place of
BEGINNING.
BEING Lot No. 11, Section B of H.R. May's Addition to the town of
West Fairview, recorded in the Cumberland County Recorder's Office
in Plan Book 1, Page 23.
HAVING THEREON ERECTED a two and one-half story frame
dwelling house known and numbered as 429 Third Street.
TAX PARCEL #45-17-1044-038.
PRGE.02
FES 22 2000 1052
WRIT OF EXECUTION and/or ATTACHMENT
COMMONWEALTH OF PENNSYLVANIA)
COUNTY OF CUMBERLAND)
NO. 99-7240 CIVIL tT
CIVIL ACTION - LAW
TO THE SHERIFF OF Cumberland COUNTY:
To satisfy the debt, interest and costs due National City Mortgage Co. P.O. Box 1820
Dayton, OH 45401-1820 PLAINTIFF(S)
from Dorothy G.A. Koltrider
429 Third Street
West Fairview, PA 17025 DEFENDANT(S)
(1) You are directed to levy upon the property of the defendant(s) and to
see legal description
(2) You are also directed to attach the property of the defendant(s) not levied upon in the possession of
GARNISHEE(S) as follows:
and to notify the garnishee(s) that: (a) an attachment has been issued; (b) the garnishee(s) is/are enjoined from paying any
debt to or for the account of the defendant(s) and from delivering any property of the defendant(s) or otherwise disposing
thereof:
(3) Ifpropertyofthedefendant(s)notlevieduponansubjecttoattachment isfoundinthepossession ofanyoneother
than a named garnishee, you are directed to notify him/he rthat he/she has been added as a garnishee and is enjoined as above
stated.
Amount Due $30.089.62 L.L. $.50
Interest from 5/1/99 to 2/14/00 at 9.875$ Due Prothy $1.00
Atty's Comm
Afty Paid $107.92
Plaintiff Paid
Date: February 17, 2000
Other Costs
Curtis R.
Prothonotary, Civil Division
REQUESTING PARTY:
Name Joseph A. Goldbeck, Jr.
Address: Suite 500 - The Bourse Bldg.
111 S. Independence Mall East
Attorney for: Philadelphia, PA 19106
ain i
Telephone: 215-627-1192
Supreme Court ID No. 16132
by:
All Deputy
REAL ESTATE SALE loo.' 1`
On FzA,,,,,,r a2. ae-wv the sheriff levied upon the defendants
Interest in the real property situated in Curnberiand County, pa., known and nun, Weed an):
vtjl ucti mire tni!y uescriberl on --vNbit "A" filed with
this writ and by t"i" re;sre nc2 incorporated her,ln.
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