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HomeMy WebLinkAbout99-07373 %'? ;;;:-.i. FEDERMAN AND 1111L•LAN By: FRANK FEDERMAN, ESQUIRE IDENTIFICATION NO. 12248 Two PENN CENTER PLAZA, SUITE 900 PHILADELPHIA, PA 19102 (21511 563-7000 GMAC MORTGAGE CORPORATION 3451 HAMMOND AVENUE P.O.BOX 780 WATERLOO, IA 50704-0780 Plaintiff V. BETII A. WOGAN 26 McBRIDE AVENUE CARLISLE, PA 17013 Defendant(s) ATTORNEY FOR PLAINTIFF COURT OF COMMON PLEAS CIVIL DIVISION TERM NO. q?-73/3 CUMBERLAND COUNTY CIVIL ACTION - LAW MORTGAGE FORECLOSURE NOTICE PLEASE BE ADVISED THAT THIS FIRM ISA DEBT COLLECTORATTENPTING TO COLLECT A DEBT. ANY A INFORMATION RECEIVED %VILL BE USED FOR TIIAT PURPOSE. IF YOU HAVE PREVIIONDENCE OUSLY RE IS NTT OF A U SBOULD NOT BE CO, STBUF.D TO BEAN ATTEd1I'T TO COLLECT A DEBT UT ONLY E FORCEAIEN ll LIEN AGAINST PROPERTY. You have been sued in Court. If you wish to defend against the claims set forth in the following pages, you must take action within twenty, (20) days after this Complaint and Notice are served, by entering a written appearance personally or by attorney and filing in writing with the court your defenses or objections to the claims set forth against you. You are warned that if you fail to do so the case may proceed without you and a judgment may be entered against you by the court without further notice for any money claimed in the Complaint or for any other claim or relief requested by the Plaintiff. You may lose money or property or other rights important to you. YOU SHOULD TAKE THIS PAPER TO YOUR LAWYER AT ONCE. IF YOU DO NOT HAVE A LAWYER OR CANNOT AFFORD ONE, GO TO OR TELEPHONE THE OFFICE SET FORTH BELOW TO FIND OUT WHERE YOU CAN GET LEGAL HELP. CUMBERLAND COUNTY CUMBERLAND COUNTY BAR ASSOCIATION 2 LIBERTY AVENUE CARLISLE, PA 17013 (717) 249-3166 Loan it: 450688791 Plaintiff is GMAC MORTGAGE CORPORATION 3451 1IAMMOND AVENUE P.O.BOX 780 WATERLOO, IA 50704-0780 2. The name(s) and last known address (cs) of the Defendant(s) are: BETII A. WOGAN 26 McBRIDE AVENUE CARLISLE, PA 17013 who is/are the mortgagor(s) and real owner(s) of the property hereinafter described. On 4/10/97 mortgagor(s) made, executed and delivered a mortgage upon the premises hereinafter described to PLAINTIFF which mortgage is recorded in the Office of the Recorder of CUMBERLAND County, in Mortgage Book No. 1374, Page 941. 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 8/1/99 and each month thereafter are due and unpaid, and by the terms of said mortgage, upon failure of mortgagor to make such payments after a date specified by written notice sent to Mortgagor, the entire principal balance and all interest due thereon are collectible forthwith. A copy of such notice is attached as Exhibit "A." 6. The following amounts are due on the mortgage: Principal Balance $63,504.49 Interest 1,685.10 7/1/99 through 11/1/99 (Per Diem $13.70) Attorney's Fees 3,175.00 Cumulative Late Charges 120.75 4/10/97 to I1/I/99 00 550 Cost of Suit and Title Search . Subtotal 69,035.34 Escrow Credit 0.00 Deficit 97.97 Subtotal 97.97 TOTAL $69,133.31 7. The attorney's fees set forth above are in conformity with the Mortgage documents and Pennsylvania Law, and will be collected in the event of a third party purchaser at Sheriffs Salc. If the Mortgage is reinstated prior to the Sale, reasonable attomey's fees will be charged. 8. This action does not come under Act 6 of 1974 because the original mortgage amount exceeds $50,000.00. 9. The Combined Notice has been sent to the Defendant(s) by regular and certified mail as required by 35 P.S. § 1680.403c on the date(s) set forth in the true and correct copy of such notice(s) attached hereto as Exhibit "A." 10. This action does not come under Act 91 of 1983 because the mortgaged premises is not the principal residence of the defendant(s). 11. Pursuant to the Fair Debt Collection Practices Act, 15 U.S.C. § 1692 et seq. (1977), Defendant(s) may dispute the validity of the debt or any portion thereof. If Defendant(s) do so in writing within thirty (30) days of receipt of this pleading, Counsel for Plaintiff will obtain and provide Defendant(s) with written verification thereof; otherwise, the debt will be assumed to be valid. Likewise, if requested within thirty (30) days of receipt of this pleading, Counsel for Plaintiff will send Defendant(s) the name and address of the original creditor if different from above. WHEREFORE, PLAINTIFF demands an in rem Judgment against the Defendant(s) in the sum of $69,133.31, together with interest from 1 I/I99 at the rate of $13.70 per diem to the date of Judgment, and other costs and charges collectible under the mortgage and for the foreclosure and sale of the mortgaged property. s/ Frank FCdcr????? FRANK FEDERMAN, ESQUIRE Attorney for Plaintiff CA 92186.5071 3451 Hammond Ave P.O. Box 780 Waterloo, 1A 50704.0780 GAIAC Mortgage Date: October 13, 1999 ACT 91 NOTICE TAKE ACTION TO SAVE YOUR HOME FROM FORECLOSURE This is an official notice that the mortgage on your home is in default, and the lender intends to foreclose. Specific information about the nature of the default is provided in the attached pages. The HOMEOWNER'S MORTGAGE ASSISTANCE PROGRAM (HEMAP) may be able to help to save Your home. This Notice explains how the proeram works. 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 SUiNA IAIPORTANCIA, PUES AFECTA SU DERECHO A CONTINUAR VIVIENDO EN SU CASA. SI NO COMPRENDE EL CONTENIDO DE ESTA NOTIFICACION OBTENGA UNA TRADUCCION IMMEDIATAMENTE LLA,IIANDO ESTA AGENCIA (PENNSYLVANIA HOUSING FINANCE AGENCY) SIN CARGOS AL NAMERO MENCIONADO ARRIBA. PUEDES SER ELEGIBLE PARR UN PRESTAJIO POR EL PROGRAbIA LLAJIADO "HOMEOWNER'S EMERGENCY MORTGAGE ASSISTANCE PROGRAM" EL CUAL PUEDE SALVAR SU CASA DE LA PERDIDA DEL DERECHO A REDINHR SU HIPOTECA HOMEOWNER'S NAME(S): PROPERTY ADDRESS: LOAN ACCT. NO.: ORIGINAL LENDER: CURRENT LENDER/SERVICER: BETH A. WOGAN 9 W BUTLER STREET MT HOLLY SPRINGS, PA 17065 450688791 N/A GMAC Mortgage EXHIBITA HOMEOWNER'S EMERGENCY MORTGAGE ASSISTANCE PROGRAM IF YOU COMPLY AITH 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 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 FORF.CI.OSURE -- 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. Diving that time you mist arrange and attend a "face-to•face" meeting with oneoftheconszunercredit counseling agenciesT^`d^Tthnn vor RsrnoaFUrt+H- CONSU11fER 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 (30) days after the date ofthis meeting.The names addresus and telephone numbers of designated consumer credit counseling agencies for . . __t -- c- ,,,, eau forth ar the end of this Nonce. It is only necessary to schedule one APPLICATION FOR MORTGAGE ASSISTA4N'CE -- Ymvmortgage is in default for the reasons set forth later in this Notice (see following pages for specific information about the native 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 Program Application with one of the designated consumer credit counseling agencies listed at the end of this Notice. Only consumer credit counseling agencies have applications for the meeting Finance Agency. or postmarked within thirty (30) days of you face Pennsylvania Youa pplication MUST be assist you 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 RILL BE DENIED. imited They AGENCY ACTION •- Available finds for emergency mortgage assistance are very l. will be disbursed has by the Agency urndcr the eligibility criteria established by the Ala. The Pennsylvania Hoursing Finance Agency rgs sixty (60) days to make a decision after it re ceives your application. IhOut that time, no foreclos if procecd y by you if you have met the time re quvements set forth above. You will be notfied direct I vvi .11 he pursued to the Pennsylvania Housing Finance Agency of its decision on yow application. EX,1IBI-; k 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 flr ed bankruptcy you can still apply for Emergency Mortgage Assistance.) HOW TO CURE, YOUR MORTGAGE DEFAULT (Bring it an to date). NATURE OF THE DEFAULT ..The MORTGAGE debt held by the above lender is on yourproperty located at: 9 W Butler street Mt Holly Springs, PA 17065 IS SERIOUSLY IN DEFAULT because: YOU HAVE NOT MADE MONTHLY MORTGAGE PAYMENTS for the following months and the following amounts are now past due: August 1, 1999 through October 1, 1999. See attached Exhibit for payment breakdown. Monthly Payments 1,824.69 - Late Charges 96.60 NSF 10.00 Inspections 14.50 Other Suspense 0.00 TOTAL AINIOUNT PAST DUE: 1,945.79 B. YOU HAVE FAILED TO TAKE THE FOLLOWING ACTION (Do not use if not applicable): HOW TO CURE THE DEFAULT -- You may clue the default within THIRTY (30) DAYS of the date of this notice BY PAYING THE TOTAL AMOUNT PAST DUE TO THE LENDER, WHICH IS $ 1,945.79 PLUS ANY MORTGAGE PAYMENTS AND LATE CHARGES WHICH BECOME DUE DURING THE THIRTY (30) DAY PERIOD. Payments must be made either by cash cashier's check certified check or money order made Payable and sent to• GMAC Mortgage Corporation ATTN: Payment Processing P.O. Box 780 Waterloo, IA 50704-0780 You can cure any other default by taking the following action within THIRTY (30) DAYS of the date of this letter: (Donotuseifnotanolicable.) Not Applicable Ir Ytru Uu NUT CURE THE. DEFAULT -- If you do not aue the default within THIRTY (30) DAYS of the date of this Nonce, the lender intends to exercise its ri hts to accelerate the mortgage debt. This means that the entire outstanding balance ofthis debt will be considered due immediately and you may lose the chance to pay the mortgage in monthly installments. If fidl payment of the total amount past due is not made within THIRTY (30) DAYS, the lender also intends to instruct its attorneys to start legal action to foreclose upon your mortgaged Proverty IF THE MORTGAGE, IS FORECLOSED UPON --The mortgaged property will be sold by the Sheriff to pay off the mortgage debt. If the lender re fers your case to its attomeys, but you acre the delinquency before the lender begins legal proceedings against your, you will still be required to pay the reasonable attorney's fees that were actually innurred, up to 550.00. However, if legal proceedings an started against against you, ynt will have to pay all re asonable att orney's fees acually incurred by the lendereven if they exceed 550.00. Any attomeys fees will be added to the amotmt your owe the lender, which may also include other reasonable costs. ?k tf ^ n OTHER LENDER REMEDIES -The lender may also sue you personally for the unpaid principal balance and all other sums due under the mortgage. -- If you have not erred the default within restore your mortgage to the same position as manner set 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 six (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 CONTACT THE LENDER: GMAC Mortgage Corporation 401 West 24th Street National City, CA 91950 (800) 850-4622 (619) 470-5579 Collection Department EFFECT OF SHERIFF'S SALE -- You should realize that a Sheriff s Sale will end your ownership of the mortgaged property and your right to occupy it. If you continue to be 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 may or may not 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 the sale and that the other requirements of the mortgage are satisfied. 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. (HOR'EVER, YOU DO NOT HAVE THIS RIGHT TO CURE YOUR DEFAULT MORE THAN THREE TIMES IN ANY CALENDAR YEAR) TO ASSERT THE NONEXISTENCE 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 CREDIT COUNSELING, AGENCIES SERVING YOUR COUNTY IS ENCLOSED ?aa 1 FYHI13lT X Pennsylvania Housing Finance Agency Homeowner's Emergency Mortgage Assistance Program Consumer Credit Counseling Agencies (Rev. 5/99) Lycoming-Cliaron Counties CuVT0=-1. Commission For Communicy ActiOa (STEP) 2138 Lincoln Stre CCCS of Norheastera PA et P. 0. Box 1328 1631 S Atherton St W(llintaspo - PA 17703 (510) 326-05,37 Suite 100 State College, P-A I68ol FAX (570) 322.2197 (814) 238.3668 CCCS of Yor4east FAX (814) 238.3669 em pA 201 Basin SL-eet vrill, 'acuPort, P.A 17703 (570 (570)323.6627 FAX (570)323-66626 COLUMBIA COL-INTY CCCS ofNortheastera Pennsvlvania pig 31 W. Market Street FOB U27 1400 Abin a E.cmitive Park Wilkes-Barre. PA 18702 Suite 1 Clarks Summit. PA 18411 (570) 821-0837 or(800)92^_•9537 FAX{ (570) 821 1785 (670) 537.9163 or(800)922.9537 . FAX (570) 587-9134/9135 Commission on Economics Opportunity of Luzern County j` 163 Amber Lane I( Wilkes-Bare, PA 18702 (570) 826-0510 or (800) 822-0359 "j FAX (570) 829.1665--CALL BEFORE F-AX24G 1 .(570) 455-4994 HAZELTON FAY (570) 455.56631-CALL BEFORE FAXLYG (570) 836-4090 TGti IC-L a,`(YOCK CR.AWFORD COUNTY Booker T. Washington. Center Greater Erie Community Action Committee 1720 Holland Street Erie PA 16503 18 West 9th Street , (814) 453-5744 Erie, PA 16501 (814) 459-4581 .. ".? FAR (814) 453.5749 FAX (814) 456-0161 -? " John R Kennedy Center, Inc. Shenango Valley Urban League, Inc 2021 East 20th Street Erie PA 16510 601 Indiana Avenue , (814) 898-0400 Farrell, PA 16121 (412) 981.5310 r j !: FAX (814) 898-1243 .I CUMMERLLr-D COUNTY CCCS of Western Pennsylvania, Inc. 2000 Ling!estowa Road Financial Counseling Services of Franklin Har.:3burg, PA 17102 31 West 3rd Street Waynesboro, PA 17268 i (717) 541.1757 (717) 762.3285 / Urban League of Sletropolitaa Harrisburg YWCA of Carlisle N. 6th Street Harrisburg, P.A. 17101 301 G Street Carlisle, PA 17013 (717)234.59^_5 FAX (717) 234.9459 (717) 243-3818 FA.Y (717) 731-9549 Community Ac:ion Comm of the Capital Region Adams County Housing Authority 1514 Derrv Street Harrsbur3 PA 17104 139-143 Carlisle St G -' , (717) 232.9757 et:jsburg, P.A. 17325 (717) 334.1518 F.AX (717) 234.2297 F.AX (717) 334-8325 PENNSYLVANIA BULLETIN, VOL 29, NO. 23. JUNE 5, 5499 ?w????mmmr++ ? Iwrsaola?mmtr?rtrnmrrm???= - - r` ALL THAT CERTAIN tract of land with the improvements thereon erected, situate in the Borough of Mount Holly Springs, Cumberland County, Pennsylvania, bounded and described as follows: BEGINNING at a point on Butler Street; thence by a public alley, South 5 degrees East 160 feet to a point at an alley; thence along the same, South 85 degrees West 80 feet to a point; thence North 5 degrees West 160 feet to Butler Street, thence along said Street, North 85 degrees east 8o feet to the place ofBEGLNWINTG. BEING improved with a two and one-half story- frame dwelling house known as No. 9 Butler Street. BEING the same premises which john W. Guffey, Jr, and Paula Gurley, his wife, by Dusan Bratic, esquire, as Attorney-In-Pact for John W. Gulley, Jr, and Paula Gulley, and James E. Gray, a4da James D. Gray, and Carol J. Scholl Gray, his wife, formerly Carol J. Scholl, by Deed dated January 16, 1986 and recorded January 17, 1986 in the Office of the Recorder of Deeds in and for Cumberland County, Pennsylvania, in Deed Book R-31, Page 756, granted and conveyed unto John C. Hornock and Stanley Miller. B00K11 3'7'4 PACE 947 i VERIFICATION SHIRLEY J. EADS hereby states that she is FORECLOSURE SPECIALIST of GMAC MORTGAGE CORPORATION mortgage servicing agent for Plaintiff in this matter, that she is authorized to take this Verification, and that the statements made in the foregoing Civil Action in Mortgage Foreclosure are true and correct to the best of her knowledge, information and belief. The undersigned understands that this statement is made subject to the penalties of 18 Pa. C.S. Sec. 4904 relating to unswom falsification to authorities. ?24c.?c Cc ? ?i DATE: 1 :4 FEDERMAN AND PHELAN By: FRANK FEDERMAN identification No. 12248 Two Penn Center Plaza - Suite 900 Philadelphia, PA 19102 (215) 563-7000 GMAC Mortgage Corporation 3451 Hammond Avenue P.O. Box 780 Waterloo, IA 50704 Plaintiff VS. Beth A. Wogan 96 Cold Spring Road Carlisle, PA 17013 Defendant(s) Attorney for Plaintiff Cumberland COUNTY COURTOF COMMON PLEAS CIVIL DIVISION NO. 99-7373 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 Beth A. Wogan , Defendant(s), for failure to file an Answer to Plaintiffs Complaint within 20 days from service thereof and for foreclosure and sale of the mortgaged premises, and assess Plaintiffs damages as follows: As set forth in Complaint $69,133.31 Interest 11/1/99 to 1/26/00 $1,191.90 TOTAL $70,325.21 1 hereby certify that (1) the addresses of the Plaintiff and Defendant(s) are as shown above, and (2) notice has been given in accordance with Rule 237. 1, copy attached. Imo. F ANK FEDERMAN, ESQUIRE Attorney for Plaintiff DAMAGES ARE HEREBY ASSESSED AS INDICATED. DATE:/,,,? / W. ®R*4?y iYmi Yq i r ?- t; ` i "THIS FIRM IS A DEBT COI.LECTOR ATrE%IPTIN(:TO C01.1.ECr A DEBT AND ANY INFORMATION OBTAINED WILL BE USED FOIL TIIAT Puiu,osE. IF YOU HAVE I-BEVIOUSLY RECEIVED A DISCHARGE IN BANKRUPTCY AND THIS DEBT WAS NOT RF.AF'Flit.Nl F.1). TIIIS CORRFSI'ONDF.NCE IS NOT AND SHOULD NOT BE CONSTRUED TO DEAN AMMITTO COLLECT A DEBT. BIT ONLY F.N FORCENIENT OF A LIEN AGAINST PROPERTY. " > FEDERMAN AND PHELAN s Frank Federman, Esquire Identification No. 12246 Two Penn Center Plaza Suite 900 Philadelphia, PA 19102-1799 (215) 563-7000 GMAC MORTGAGE CORPORATION Plaintiff Vs. BETH A. WOGAN Defendant TO: BETH A. WOGAN 96 COLD SPRING ROAD CARLISLE, PA 17013 DATE OF NOTICE: JANUARY 13, 2000 ATTORNEY FOR PLAINTIFF COURT OF COMMON PLEAS CIVIL DIVISION CUMBERLAND COUNTY . N0. 99-7373 FILE COPY THIS FIRM IS A DEBT COLLECTOR ATTEMPTING TO COLLECT A DEBT. THIS NOTICE IS SENT TO YOU IN AN ATTEMPT TO COLLECT THE INDEBTEDNESS REFERRED TO HEREIN, AND ANY INFORMATION OBTAINED FROM YOU WILL BE USED FOR THAT PURPOSE.IF YOU HAVE PREVIOUSLY RECEIVED A DISCHARGE IN BANKRUPTCY, THIS CORRESPONDENCE IS NOT AND SHOULD NOT BE CONSTRUED TO BE AN ATTEMPT TO COLLECT A DEBT, BUT ONLY AS ENFORCEMENT OF LIEN AGAINST PROEPRTY. IMPORTANT NOTICE You are in default because you have failed enter a written appearance personally or by attorney and file in writing with the court your defenses or objections to the claims set forth against you. Unless you act within ten (10) days from the date of this notice, a Judgment may be entered against you without a hearing and you may lose your property or other important rights. You should take this notice to a lawyer at once. If he not have a lawyer or cannot afford one, go t o telephone following office to find out where you can get legal help: CUMBERLAND COUNTY CUMBERLAND COUNTY BAR ASSOCIATION 2 LIBERTY AVENUE CARLISLE, PA 17013 (717) 249-3166 11 1 Frank Federman, Esquir Attorney for Plaintiff iI 1- 1 i FEDERMAN and PHELAN By: FRANK FEDERMAN Identification No. 12248 Suite 900 Two Penn Center Plaza Philadelphia, PA 19102 (215) 563-7000 Attorney for Plaintiff GMAC Mortgage Corporation : Cumberland COUNTY Plaintiff : Court of Common Pleas VS. : CIVIL DIVISION Beth A. Wogan :NO. 99-7373 Civil Defendant(s) VERIFICATION OF NON-MILITARY SERVICE FRANK FEDERMAN, ESQUIRE, hereby verifies that he is attorney for the Plaintiff in the above-captioned matter, and that on information and belief, he has knowledge of the following facts, to wit: (a) that the defendant(s) is/are not in the Military or Naval Service of the United States or its Allies, or otherwise within the provisions of the Soldiers' and Sailors' Civil Relief Act of Congress of 1940, as amended (b) that defendant Beth A. Wogan is over 18 years of age and resides at 96 Cold Spring Road, Carlisle, PA 17013. This statement is made subject to the penalties of 18 Pa. C.S. Section 4904 relating to unswom falsification to authorities. Q,4J k? FRANK FEDERMAN Attorney for Plaintiff L~-14 (Rule of Civil Procedure No. 236 - Revised) GMAC Mortgage Corporation : Cumberland COUNTY Plaintiff : Court of Common Pleas Vs. Beth A. Wogan CIVIL DIVISION :NO. 99-7373 Civil Defendant(s) Notice is given that a Judgment in the above captioned matter has been entered against you on January 2000. By DEPUTY If you have any questions concerning this matter, please contact: FRANK FEDERMAN. ESOUIRE Attorney for Filing Party SUITE 900 TWO PENN CENTER PLAZA PHILADELPHIA, PA 19102 (215)563-7000 **THIS FIRM IS A DEBT COLLECTOR ATTEMPTING TO COLLECT A DEBT AND ANY INFORMATION OBTAINED WILL BE USED FOR THAT PURPOSE. IF YOU HAVE PREVIOUSLY RECEIVED A DISCHARGE IN BANKRUPTCY AND THIS DEBT WAS NOT REAFFIRMED, THIS IS NOT AND SHOULD NOT BE CONSTRUED TO BE AN ATTEMPT TO COLLECT A DEBT, BUT ONLY ENFORCEMENT OF A LIEN AGAINST PROPERTY. ** Y \ I 1 ? i' CSI } cl: LIJ J- 77 PRAECIPE FOR WRIT OF EXECUTION - (MORTGAGE FORECLOSURE) Cumberland County GMAC Mortgage Corporation ' Plaintiff, V. No. 99-7373 Civil Beth A. Wagon Defendant(s). TO THE DIRECTOR OF THE OFFICE OF THE PROTHONOTARY: Issue writ of execution in the above matter: Amount Due Interest from 1/26/00 - 6/7/00 (per diem - $11.56) $70325.21_ i/ $1,537.48 and Costs $71.862.69 TOTAL J K EDE AN ESQUIRE PENN CENTE PLAZA SUITE 900 PHILADELPHIA, PA 19102 Attorney for Plaintiff Note: Please attach description of property.No. i Q d rn a% F wQ Oz Q> a(n az zz O ?a O F U z 00 U as Od U? Ww x„ F? za 0 R L O i U nn 0 U C7 C 3 Q r Cq z O F a [U[]] 7 V /W y W o O? F ? O t Gzi o a? U W C! O M y C bD ? 'D n c ti ? c ': Q E 3?a p u v d o ? .o U i tt 0.1aU.c y 3 N 4 v Q ?L r ? I t? DESCRIPTION ALL THAT CERTAIN tract of land with the improvements thereto erected, situate in the Borough of Mount Holly Springs, Cumberland County, Pennsylvania, bounded and described as follows: BEGINNING at a point on Butler Street; thence by a public alley, South 5 degrees East 160 feet to a point at an alley; thence along the same, South 85 degrees West 80 feet to a point; thence North 5 degrees West 160 feet to Butler Street; thence along said street, North 85 degrees East 80 feet to the Place of BEGINNING. BEING improved with a two and one-half story frame dwelling house known as 9 Butler Street. Tax Parcel #23-32-2336-149 TITLE TO SAID PREMISES IS VESTED IN Beth A. Wogan by Deed fro John G. Hornock, singleman and Stanley Miller and Pok Sun Miller, his wife dated 4110/97 recorded 4/14/97 in Deed Book 155 Page 865. L r> =j CZ9 0 V vim. v I` t? r GMAC Mortgage Corporation Plaintiff, V. Beth A. Wogan Defendant(s). CUMBERLAND COUNTY COURT OF COMMON PLEAS CIVIL DIVISION NO. 99-7373 Civil AFFIDAVIT PURSUANT TO RULE 3129 (Affidavit No. 1) GMAC Mort t=aPe Corporation, Plaintiff in the above action, by its attorney, FRANK FEDERMAN, 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 9 W Butler Street Mt Hollv SnrinQs. PA 17065. Name and address of Owner(s) or reputed Owner(s): NAME 2. LAST KNOWN ADDRESS (If address cannot be reasonably ascertained, please so indicate.) Beth A. Wogan 96 Cold Spring Road Carlisle, PA 17013 Name and address of Defendant(s) in the judgment: NAME LAST KNOWN ADDRESS (If address cannot be reasonably ascertained, please so indicate.) Same as above 3. Name and address of every judgment creditor whose judgment is a record lien on the real property to be sold: NAME LAST KNOWN ADDRESS (If address cannot be reasonably ascertained, please so indicate.) None 4. Name and address of the last recorded holder of every mortgage of record: NAME LAST KNOWN ADDRESS (If address cannot be reasonably ascertained, please so indicate.) Federal Home Loan 2001 Jefferson Davis Highway Mortgage Corporation Suite 901 Arlington, VA 22202 5. Name and address of every other person who has any record lien on the property: NAME LAST KNOWN ADDRESS (If address cannot be reasonably ascertained, please so indicate.) None 6. Name and address of every other person who has any record interest in the property and whose interest may be affected by the sale: NAME LAST KNOWN ADDRESS (If address cannot be reasonably ascertained, please so indicate.) None 7. Name and address of every other person whom the plaintiff has knowledge who has any interest in the property which may be affected by the sale: NAME LAST KNOWN ADDRESS (If address cannot be reasonably ascertained, please so indicate.) Tenant/Occupant 9 W. Butler Street Mt. Holly Springs, PA 17065 Domestic Relations of 13 North Hanover Street Cumberland County Carlisle, PA 17013 I verify that tite 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. Februarv 18, 2000 S2c? DATE F NK FEr ER AN, ESQUIRE A torney fo Plaintiff 1 GMAC Mortgage Corporation Plaintiff, V. Beth A. Wogan Defendant(s). TO: Beth A. Wogan 96 Cold Spring Road Carlisle, PA 17013 26 McBride Avenue Carlisle, PA 17013 "THIS FIRM IS A DEBT COLLECTOR ATTEMPTING TO COLLECT A DEBT AND ANY INFORMATION OBTAINED WILL BE USED FOR THAT PURPOSE. IF YOU HAVE PREVIOUSLY RECEIVED A DISCHARGE IN BANKRUPTCY AND THIS DEBT WAS NOT REAFFIRMED, THIS IS NOT AND SHOULD NOT BE CONSTRUED TO BE AN ATTEMPT TO COLLECT A DEBT, BUT ONLY ENFORCEMENT OF A LIEN AGAINST PROPERTY." Your house (real estate) at 9 W. Butler Street, Mt. Holly Springs, PA 17065, is scheduled to be sold at the Sheriffs Sale on June 7, 2000 at 10:00 a.m. in the Cumberland County Courhtouse, South Hanover Street, Carlisle, PA 17013, to enforce the court judgment obtained by GMAC Mortgage Corporation (the mortgagee) against you. If the Sheriff's sale is postponed, the property will be relisted for the Sheriffs Sale. CUMBERLAND COUNTY No. 99-7373 Civil February 18, 2000 9 West Butler Street Mount Holly Springs, PA 17065 NOTICE OF OWNER'S RIGHTS YOU MAY BE ABLE TO PREVENT THIS SHERIFF'S SALE To prevent this Sheriffs Sale, you must take immediate action: The sale will be cancelled if you pay to the mortgagee the back payments, late charges, costs and reasonable attorney's fees due. To find out how much you must pay, you may call: (215) 563-7000. 2. You may be able to stop the sale by filing a petition asking the Court to strike or open the judgment, if the judgment was improperly entered. You may also ask the Courtto postpone the sale for good cause. 3. You may also be able to stop the sale through other legal proceedings. 7 r"< Y 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.) I' T 1. If the Sheriffs Sale is not stopped, your property will be sold to the highest bidder. You may find out the price bid by calling (215) 563-7000. 2. You may be able to petition the Court to set aside the sale if the bid price was grossly inadequate compared to the value of your property. 3. The sale will go through nl (717) buyer pays the Sheriff the full amount due in the sale. To find out if this has happened, you may call (717) 240-6390. 4. If the amount due from the Buyer is not paid to the Sheriff, you will remain the owner of the property as if the sale never happened. 5. You have the right to remain in the property until the full amount due is paid to the Sheriff and the Sheriff gives a deed to the buyer. At that time, the buyer may bring legal proceedings to evict you. 6. You may be entitled to a share of the money which was paid for your house. A schedule of distribution of the money bid for your house will be filed by the Sheriff within 30 days of 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 the 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 FIND OUT WHERE YOU CAN GET O LEGAL HELP. THE OFFICE LISTED BELOW TO CUMBERLAND COUNTY ATTORNEY REFERRAL CUMBERLAND COUNTY BAR ASSOCIATION 2 LIBERTY AVENUE CUMBERLAND COUNTY COURTHOUSE CARLISLE, PA 17013 (717) 249-3166 (800) 990-9108 t -Aa DESCRIPTION ALL THAT CERTAIN tract of land with the improvements thereto erected, situate in the Borough of Mount Holly Springs, Cumberland County, Pennsylvania, bounded and described as follows: BEGINNING at a point on Butler Street; thence by a point at an alley; thence along the same, South 85 degrees West 160 feet to Butler Street; thence along Place of BEGINNING. a public alley, South 5 degrees East 160 feet to degrees West 80 feet to a point; thence North 5 said street, North 35 degrees East 80 feet to the BEING improved with a two and one-half story frame dwelling house known as 9 Butler Street. Tax Parcel #23-32-2316-149 TITLE TO SAID PREMISES IS VESTED IN Beth A. Wogan by Deed fro John G. Homock, sineleman and Stanley Miller and Pok Sun Miller, his wife dated 4/10/97 recorded 4/14/97 in Deed Book 155 Page 865. FEDERMAN and PHELAN By: FRANK FEDERMAN Identification No. 12248 Suite 900 Two Penn Center Plaza Philadelphia, PA 19102 (215) 563-7000 GMAC Mortgage Corporation V. Beth A. Wogan ATTORNEY FOR PLAINTIFF Plaintiff, Defendant(s). CUMBERLAND COUNTY COURT OF COMMON PLEAS CIVIL DIVISION NO. 99-7373 Civil CERTIFICATION FRANK FEDERMAN, ESQUIRE, hereby verifies that he is attorney for the Plaintiff in the above-captioned matter, and that the premises are not subject to the provisions of Act 91 because it is: () an FHA mortgage () non-owner occupied () vacant (X) Act 91 procedures have been fulfilled This certification is made subject to the penalties of 18 Pa. C.S. Section 4904 relating to unswom falsification to authorities. FRANI FEDERMAN,ES IRE Attorney for Plaintiff GMAC Mortgage Corporation -vs- Beth A. Wogan R. Thomas Kline, Sheriff, who being duly sworn according to law, says this writ is returned STAYED. Sheriff's Costs: Docketing Poundage Law Library County Levy Postpone Sale Surcharge Sworn and subscribed to before me 30.00 1.73 .50 1.00 15.00 20.00 20.00 $ 88.23 Pd By atty 3-15-00 This -2? day of 1999,A.D. C. o Prothonotary In the Court ofConunon Pleas of Cumberland County, Pennsylvania No. 99-7373 Civil So answers: R. Thomas Kline, Sheriff BY, Real Estate Deputy 1.S'V Ch a-7 r-I -?' f&- 43o 3 y ,<. GMAC Mortgage Corporation Plaintiff, V. Beth A. Wogan Defendant(s). CUMBERLAND COUNTY COURT OF COMMON PLEAS CIVIL DIVISION NO. 99-7373 Civil AFFIDAVIT PURSUANT TO RULE 3129 (Affidavit No. l) GMAC Mortgage Corporation, Plaintiff in the above action, by its attorney, FRANK FEDERMAN, ESQUIRE, set:, forth as of the date the Praecipe for the Writ of Execution was filed the following information concerning the real property located at 9 W Butler Street Mt Holly Springs, PA 17065. Name and address of Owner(s) or reputed Owner(s): NAME LAST KNOWN ADDRESS (If address cannot be reasonably ascertained, please so indicate.) Beth A. Wogan 96 Cold Spring Road Carlisle, PA 17013 2. Name and address of Defendant(s) in the judgment: NAME LAST KNOWN ADDRESS (If address cannot be reasonably ascertained, please so indicate.) Same as above Name and address of every judgment creditor whosejudgment is a record lien on the real property to be sold: NAME LAST KNOWN ADDRESS (If address cannot be reasonably ascertained, please so indicate.) None . ?f 4. Name and address of the last recorded holder of every mortgage of record: NAME LAST KNOWN ADDRESS (If address cannot be reasonably ascertained, please so indicate.) Federal Home Loan 2001 Jefferson Davis Ilighway Mortgage Corporation Suite 901 Arlington, VA 22202 5. 6. Name and address of every other person who has any record lien on the property: NAME LAST KNOWN ADDRESS (If address cannot be reasonably ascertained, please so indicate.) None Name and address of every other person who has any record interest in the property and whose interest may be affected by the sale: NAME LAST KNOWN ADDRESS (if address cannot be reasonably ascertained, please so indicate.) None 7. Name and address of every other person wlwnn the plaintiff has knowledge who has any interest in the property which may be alTected by the sale: NAME LAST KNOWN ADDRESS (If address cannot be reasonably ascertained, please so indicate.) Tenant/Occupant 9 11'. (Sutler Street Mt. (lolly Springs, PA 17065 Domestic Relations of 13 North I lanover Street Cumberland County Carlisle, PA 17013 I verify that the statements made in this aliidavit are true and correct to the best of my personal knowledge or information mud belief. I understand that false statements herein are made subject to the penalties of 18 Pa. C.S, Sec. 4901 relating to unsworn falsification to authorities. February 18, 2000 ? DATE PRANK EIL?IAN, ESQUIRE Attorney for Plaintiff GMAC Mortgage Corporation Plaintiff, V. Beth A. Wogan Defendant(s). TO: Beth A. Wogan 96 Cold Spring Road Carlisle, PA 17013 26 McBride Avenue Carlisle, PA 17013 "THIS FIRM IS A DEBT COLLECTOR ATTEMPTING TO COLLECT A DEBT AND ANY INFORMATION OBTAINED WILL BE USED FOR THAT PURPOSE. IF YOU HAVE PREVIOUSLY RECEIVED A DISCHARGE IN BANKRUPTCY AND THIS DEBT WAS NOT REAFFIRMED, THIS IS NOT AND SHOULD NOT BE CONSTRUED TO BE AN ATTEMPT TO COLLECT A DEBT, BUT ONLY ENFORCEMENT OF A LIEN AGAINST PROPERTY." Your house (real estate) at 9 W. Butler Street. Mt. Holly Springs, PA 17065, is scheduled to be sold at the Sheriffs Sale on June 7.2000 at 10:00 a.m. in the Cumberland County Courhtouse , South Hanover Street, Carlisle, PA 17013, to enforce the court judgment obtained by GMAC Mortgage Corporation (the mortgagee) against you. If the Sheriffs sale is postponed, the property will be relisted for the Sheriff s Sale. CUMBERLAND COUNTY No. 99-7373 Civil February 18, 2000 9 West Butler Street Mount Holly Springs, PA 17065 NOTICE OF OWNER'S RIGHTS YOU MAY BE ABLE TO PREVENT THIS SHERIFF'S SALE To prevent this Sheriffs Sale, you must take immediate action: The sale will be cancelled if you pay to the mortgagee the back payments, late charges, costs and reasonable attorney's fees due. To find out how much you must pay, you may call: (215) 563-7000. 2. You may be able to stop the sale by filing a petition asking the Court to strike or open the judgment, if the judgment was improperly entered. You may also ask the Court to postpone the sale for good cause. 3. You may also be able to stop the sale through other legal proceedings. You may need an attorney to assert your rights. The sooner you contact one, the more chance you will have of stopping the sale. (See notice on page two on how to obtain an attorney.) YOU MAY STILL BE ABLE TO SAVE YOUR PROPERTY AND YOU HAVE OTHER RIGHTS EVEN IF THE SHERIFF'S SALE DOES TAKE PLACE. 1. If the Sheriffs Sale is not stopped, your property will be sold to the highest bidder. You may find out the price bid by calling (215) 563-7000. 2. You may be able to petition the Court to set aside the sale if the bid price was grossly inadequate compared to the value of your property. 3. The sale will go through only if the buyer pays the Sheriff the full amount due in the sale. To find out if this has happened, you may call (717) 240-6390. 4. If the amount due from the Buyer is not paid to the Sheriff, you will remain the owner of the property as if the sale never happened. 5. You have the right to remain in the property until the full amount due is paid to the Sheriff and the Sheriff gives a deed to the buyer. At that time, the buyer may bring legal proceedings to evict you. 6. You may be entitled to a share of the money which was paid for your house. A schedule of distribution of the money bid for your house will be filed by the Sheriff within 30 days of 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 the 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. CUMBERLAND COUNTY ATTORNEY REFERRAL CUMBERLAND COUNTY BAR ASSOCIATION 2 LIBERTY AVENUE CUMBERLAND COUNTY COURTHOUSE CARLISLE, PA 17013 (717) 249-3166 (800) 990-9108 4vuei? f DESCRIPTION ALL THAT CERTAIN tract of land with the improvements thereto erected, situate in the Borough of Mount Holly Springs, Cumberland County, Pennsylvania, bounded and described as follows: BEGINNING at a point on Butler Street; thence by a public alley, South 5 degrees East 160 feet to a point at an alley; thence along the same, South 85 degrees West 80 feet to a point; thence North 5 degrees West 160 feet to Butler Street; thence along said street, North 85 degrees East 80 feet to the Place of BEGINNING. BEING improved with a two and one-half story frame dwelling house known as 9 Butler Street. Tax Parcel 23-32-2336-119 TITLE TO SAID PREMISES IS VESTED IN Beth A. Wogan by Deed fro John G. Homock, sineleman and Stanley Miller and Pok Sun Miller, his wife dated 4/10/97 recorded 4/14/97 in Deed Book 155 Page 865. WRIT OF EXECUTION and/or ATTACHMENT COMMONWEALTH OF PENNSYLVANIA) NO. 99-7373 CIVIL 19 COUNTY OF CUMBERLAND) CIVIL ACTION - LAW TO THE SHERIFF OF Cumberland COUNTY: To satisfy the debt, interest and costs due GMAC Mortgage Corporation from Beth A. Wogan, 96 Cold Spring Road, Carlisle, PA 17013 DEFENDANT(S) (1) You are directed to levy upon the property of the defendant(s) and to sell See Legal Description (2) You are also directed to attach the property of the defendant(s) not levied upon in the possession of GARNISHEE(S) as follows: and to notify the garnishee(s) that: (a) an attachment has been issued; (b) the garnishee(s) is/are enjoined from paying any debt to or for the account of the defendant(s) and from delivering any property of the defendant(s) or otherwise disposing thereof; (3) If property of the defendant(s) not levied upon an subject to attachment is found in the possession of anyone other than a named garnishee, you are directed to notify hinvhe r that he/she has been added as a garnishee and is enjoined as above stated. Amount Due $70,325.21 L.L. $.50 from - per hem $11.56 Interest $1 ,537 48 and costs Due Prothy S1 _00 Atty's Comm Atty Paid $102.96 Plaintiff Paid Other Costs Date: February 24, 2000 REQUESTING PARTY: Name Frank Federman, Esq. Address: Two Penn Center Plaza, Suite 900 Attorney for; Telephone: Philadelphia, PA 19102 Plaintiff 215-563-7000 Curtis R. Long Prothonotary, Civil Division -1J WP Deputy Supreme Court ID No. 12248 RE L H A T E SALE Not ?? On F-5:?a"? the sheriff levied upon the defendants Interest in the real property situated in / Y64 Cumberland County, Pa., known and numbered as; 2esc tea- wand more fully described on Exhibit "A" filed with this writ and by this reference incorporated herein. Date:{. B ° 0 SHERIFF'S RETURN - REGULAR ,E NO: 1999-07373 P COMMONWEALTH OF PENNSYLVANIA: COUNTY OF CUMBERLAND GMAC MORTGAGE CORP VS WOGAN BETH A SHANNON SUNDAY , Sheriff or Deputy Sheriff of Cumberland County, Pensylvania, who being duly sworn according to law, says, the within COMPLAINT - MORT FORE was served upon WOGAN BETH A the DEFENDANT at 0014:37 HOURS, on the 23rd day of December , 1999 at 96 COLD SPRING ROAD CARLISLE, PA 17013 DAVE WOGAN (HUSBAND) by handing to a true and attested copy of COMPLAINT - MORT FORE together with NOTICE and at the same time directing His attention to the contents thereof. Sheriff's Costs: Docketing 18.00 Service 4.96 Affidavit .00 Surcharge 8.00 .00 30.96 Sworn and Subscribed to before a, me this /Z " day of .?P „je? -,?e17) A.D. ,'P othonotary So Answers: R. Thomas Kline 12/27/1999 FEDERMAN & PHELAN By: l rll N m,n nyf ' / ' • ?Y?-COtL?l,?.?-I Deputy Sheriff k FAA i 7 PRAECIPE FOR WRIT OF EXECUTION - (MORTGAGE FORECLOSURE) P.R.C.P.3180-3183 GMAC Mortgage Corporation Cumberland County Plaintiff, V. No. 99-7373 Civil Beth A. Wagon Defendant(s). TO THE DIRECTOR OF THE OFFICE OF THE PROTHONOTARY: Issue writ of execution in the above matter: Amount Due Interest from 1/26/00 -12/6/00 (per diem - $11.56) $70,325.21 $1.537.48 and Costs $73.966.61 TOTAL F NK F DE AN, ESQUIRE T 0 PENN NTER PLAZA SUITE 900 PHILADELPHIA, PA 19102 Attorney for Plaintiff f:._ _- Note: Please attach description of property.No. r? i i i I :t Q a rn F w? oz? as a? zz ?a OF Vz OD ac Oa F Oa ?U V C O 0 U bL 14 F1 0 V d' G?7 C 3 a r d ra z 0 F U ? V Wy w g 0"5 F L 0t w? W a w 9 v w v R d N o rx4) R p .ri ? o '? a s Q o a BUT. Ca ooN U H V v Q DESCRIPTION ALL THAT CERTAIN tract of land with the improvements thereto erected, situate in the Borough of Mount Holly Springs, Cumberland County, Pennsylvania, bounded and described as follows: BEGINNING at a point on Butler Street; thence by a public alley, South 5 degrees East 160 feet to a point at an alley; thence along the same, South 85 degrees West 80 feet to a point; thence North 5 degrees West 160 feet to Butler Street; thence along said street, North 85 degrees East 80 feet to the Place of BEGINNING. BEING improved with a two and one-half story frame dwelling house known as 9 Butler Street. Tax Parcel n23-32-2336-149 TITLE TO SAID PREMISES IS VESTED IN Beth A. Wogan by Deed fro John G. Hornock, singleman and Stanley Miller and Pok Sun Miller, his wife dated 4110/97 recorded =4/14/97 in Deed Book 155 Page 865. P n 0 1.1 rJ _ r GMAC Mortgage Corporation Plaintiff, v. Beth A. Wogan Defendant(s). CUMBERLAND COUNTY COURT OF COMMON PLEAS CIVIL DIVISION NO. 99-7373 Civil AFFIDAVIT PURSUANT TO RULE 3129 (Affidavit No. l) GMAC Mortgage Corporation, Plaintiff in the above action, by its attomey, FRANK FEDERMAN, 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 9 W. Butler Street Mt. Holly Springs, PA 17065. 1. Name and address of Owner(s) or reputed Owner(s): NAME LAST KNOWN ADDRESS (If address cannot be reasonably ascertained, please so indicate.) Beth A. Wogan 96 Cold Spring Road Carlisle, PA 17013 2. Name and address of Defendant(s) in the judgment: NAME LAST KNOWN ADDRESS (If address cannot be reasonably ascertained, please so indicate.) Same as above 3. Name and address of everyjudgment creditor whose judgment is a record lien on the real property to be sold: NAME LAST KNOWN ADDRESS (If address cannot be reasonably ascertained, please so indicate.) None 4. Name and address of the last recorded holder of every mortgage of record: NAME LAST KNOWN ADDRESS (If address cannot be reasonably ascertained, please so indicate.) Federal Home Loan 1155 151h Street Mortgage Corporation NW #606 Washington, DC 20005-2706 5. Name and address of every other person who has any record lien on the property: NAME LAST KNOWN ADDRESS (If address cannot be reasonably ascertained, please so indicate.) None 6. Name and address of every other person who has any record interest in the property and whose interest may be affected by the sale: NAME LAST KNOWN ADDRESS (If address cannot be reasonably ascertained, please so indicate.) None Name and address of every other person whom the plaintiff has knowledge who has any interest in the property which may be affected by the sale: NAME LAST KNOWN ADDRESS (If address cannot be reasonably ascertained, please so indicate.) Tenant/Occupant 9 W. Butler Street Mt. Holly Springs, PA 17065 Domestic Relations of 13 North Hanover Street Cumberland County Carlisle, PA 17013 I verify that the statements made in this affidavit are true and correct to the best of my personal knowledge or information and belief. I understand that false statements herein are made subject to the penalties of 18 Pa. C.S. Sec. 4904 relating to unswom falsification to authorities. September 040 DATE F WK FE ER AN, ESQUIRE Attorney for Plaintiff y C1 «- L: 'iL 7i ?'? ?? ! ? '._. ii L. -_ --• (.J GMAC Mortgage Corporation Plaintiff, V. Beth A. Wogan Defendant(s). TO: Beth A. Wogan 96 Cold Spring Road Carlisle, PA 17013 CUMBERLAND COUNTY No. 99-7373 Civil September 6, 2000 9 West Butler Street Mount Holly Springs, PA 17065 26 McBride Avenue Carlisle, PA 17013 "THIS FIRM IS A DEBT COLLECTOR ATTEMPTING TO COLLECT A DEBT AND ANY INFORMATION OBTAINED WILL BE USED FOR THAT PURPOSE. IF YOU HAVE PREVIOUSLY RECEIVED A DISCHARGE IN BANKRUPTCY AND THIS DEBT WAS NOT REAFFIRMED, THIS IS NOT AND SHOULD NOT BE CONSTRUED TO BE AN ATTEMPT TO COLLECT A DEBT, BUT ONLY ENFORCEMENT OF A LIEN AGAINST PROPERTY." Your house (real estate) at 9 W. Butler Street. Mt. Holly Springs PA 17065, is scheduled to be sold at the Sheriffs Sale on December 6.2000 at 10:00 a.m. in the Cumberland County Courhtouse , South Hanover Street, Carlisle, PA 17013, to enforce the court judgment obtained by GMAC Mortgage Corporation (the mortgagee) against you. If the Sheriff's sale is postponed, the property will be relisted for the March 7, 2001 Sheriff's Sale. NOTICE OF OWNER'S RIGHTS YOU MAY BE ABLE TO PREVENT THIS SHERIFF'S SALE To prevent this Sheriffs Sale, you must take immediate action: 1. The sale will be cancelled if you pay to the mortgagee the back payments, late charges, costs and reasonable attorney's fees due. To find out how much you must pay, you may call: (215) 563-7000. 2. You may be able to stop the sale by filing a petition asking the Court to strike or open the judgment, if the judgment was improperly entered. You may also ask the Court to postpone the sale for good cause. 3. You may also be able to stop the sale through other legal proceedings. You may need an attorney to assert your rights. The sooner you contact one, the more chance you will have of stopping the sale. (See notice on page two on how to obtain an attorney.) 1. If the Sheriffs Sale is not stopped, your property will be sold to the highest bidder. You may find out the price bid by calling (215) 563-7000. 2. You may be able to petition the Court to set aside the sale if the bid price was grossly inadequate compared to the value of your property. 3. The sale will go through only if the buyer pays the Sheriff the full amount due in the sale. To find out if this has happened, you may call (717) 240-6390. 4. If the amount due from the Buyer is not paid to the Sheriff, you will remain the owner of the property as if the sale never happened. 5. You have the right to remain in the property until the full amount due is paid to the Sheriff and the Sheriff gives a deed to the buyer. At that time, the buyer may bring legal proceedings to evict you. 6. You may be entitled to a share of the money which was paid for your house. A schedule of distribution of the money bid for your house will be filed by the Sheriff within 30 days of 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 the 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. CUMBERLAND COUNTY ATTORNEY REFERRAL CUMBERLAND COUNTY BAR ASSOCIATION 2 LIBERTY AVENUE CUMBERLAND COUNTY COURTHOUSE CARLISLE, PA 17013 (717) 249-3166 (800) 990-9108 DESCRIPTION ALL THAT CERTAIN tract of land with the improvements thereto erected, situate in the Borough of ivlount Holly Springs, Cumberland County, Pennsylvania, bounded and described as follows: BEGINNING at a point on Butler Street; thence by a public alley, South 5 degrees East 160 feet to a point at an alley; thence along the same, South 85 degrees West 80 feet to a point; thence North 5 degrees West 160 feet to Butler Street; thence along said street, North 85 degrees East 80 feet to the Place of BEGINNING. BEING improved with a two and one-half story frame dwelling house known as 9 Butler Street. Tar Parcel #23-32-2336-149 TITLE TO SAID PREMISES IS VESTED IN Beth A. Wogan by Deed fro John G. Homoclc, sineleman and Stanley Miller and Pok Sun Miller, his wife dated 4110/97 recorded 4/14/97 in Deed Book 155 Page 865. FEDERMAN and PHELAN By: FRANK FEDERMAN Identification No. 12248 Suite 900 Two Penn Center Plaza Philadelphia, PA 19102 (215) 563-7000 GMAC Mortgage Corporation Plaintiff, V. Beth A. Wogan Defendant(s). ATTORNEY FOR PLAINTIFF CUMBERLANDCOUNTY COURT OF COMMON PLEAS CIVIL DIVISION NO. 99-7373 Civil CERTIFICATION FRANK FEDERMAN, ESQUIRE, hereby verifies that he is attorney for the Plaintiff in the above-captioned matter, and that the premises are not subject to the provisions of Act 91 because it is: O an FHA 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. Section 4904 relating to unswom falsification to authorities. FRAp K FED RW , ESQUIRE Att mey for Plaintiff -: AFFIDAVIT OF SERVICE PLAINTIFF GMAC Mortgage Corporation Cumberland County No.99-7373 Civil DEFENDANT(S) Beth A. Wogan Type of Action SERVE AT 96 Cold Spring Road Notice of Sherifrs sale Carlisle, PA 17013 Sale Date: December 6, 2000 2 ?I Q 'A f SERVED Served and made known to - LJCV !T /t?/?5? 3 N p, /Defendant, on the / day of d , 200x, at JP', o'clock a.m., at "7etci N5 d\C3 ('a- K ( 1 1 S l °L , Commonwealth of Pennsylvania, in the manner described below: Defendant personally served. 1 Adult family member with whom Defendant(s) reside(s). Relationship is tJ 0aVid AI lNcsa N Adult in charge of Defendant(s)'s residence who refused to give name or relationship. Manager/Clerk of place of lodging in which Defendant(s) reside(s). Agent or person in charge of Defendant(s)'s office or usual place of business. an officer of said Defendant(s)'s company. Other: Description: Age I, C.-1o+"NcP_ ht L51 a true and correct copy of th the address indicated above. I/ // I 5 N,.) ?a; K o Height ?? 6 Weight Race W? sex 1=' Other 16 duI stvom according to law, depose and state that I personally handed tner as forth herein, issued in the captioned case on the date and at Public County 2, 2003 Sworn to and subscyiiDed Mel before m this J? day of C 20 / Notary: /c- On the day of Moved _ Unknown Other: Sworn to and subscribed before me this day of 200 Notary: By: Attorney for Plaintiff Frank Federman, Esquire - I.D. No. 12248 Two Penn Center Plaza, Suite 900 Philadelphia, PA 19102 (215) 563-7000 ?::r:>yr+un:a Association of NNootta?n?ess By: C?7? *9 NOTSERVED 200, at o'clock _.m., Defendant NOT FOUND because: No Answer - Vacant /' ova ^.? r? :, f ?1 "I X..l, J ., ?:J i. ? C?. 1-... ?.-. • __. _. L il.a !: _ '_? lJ } IN THE COURT OF COMMON PLEAS OF CUMBERLAND COUNTY, PENNSYLVANIA GMAC MORTGAGE CORPORATION. Plaintiff VS. BETH A. WOGAN Defendant CIVIL DIVISION No. 99-7373 CIVIL AFFIDAVIT OF SERVICE PURSUANT TO RULE 3129 COMMONWEALTH OF PENNSYLVANIA SS: CUMBERLAND COUNTY I, FRANK FEDERMAN, ESQ., attorney for GMAC MORTGAGE CORPORATION, hereby verify that on SEPTEMBER 7. 2000, true and correct copies of the Notice of Sheriffs Sale were served by certificate of mailing to the recorded lienholder(s), and any known interested party, see Exhibit "A" attached hereto, and the Notice of Sale was sent to defendant(s) on SEPTEMBER 7. 2000 by first class mail and certified mail return receipt requested, see Exhibit "B" attached hereto. FRANK FEDERM N, ESQUIRE Attorney for Plaintiff Date: November 2. 2000 W. e Y 6 N W N xa._ G w `a6 Y C G vim] 3 r is. F G. W ? 7 Y ? z<o •. 09L9909 d a\ tre a i m f0? ' s l ?? ? yco.i-aa x \ asvisoa•s*n Y m s PEN Cc^ ti w ? t r Q h N $! ° 6' 1 o N a 3til O o C h e C a L Y 3 a to U 0 0 3 z ?, Q Y e h yj m (E x C > ? O. T C Z C F O vim. Z C x T O C y 8 U in m 19 6 t ? = ? ? 0. m a Z m l J C ? O w ? ? E 6 , Y R c 6 0 ` E o ? ? u C ? o g a ZE z ci F D 3 ?? .x E Z b 9 V_ C y °a x u N rt Q vt tD h °o a\ O ? N t'1 7 h Z F P 968 740 941 TO: BETH A. WOGAN 9 WEST BUTLER STREET MOUNT HOLLY SPRINGS, PA 17065 SENDER: DMK REFERENCE: SALES cwmm F.o RETURN RECEIPT SERVICE US Postal Service Receipt for Certified Mail No Insurance Coverage Providec Do not use for Intemational Mail POSTMARK OR DATE TO: P 969 055 352 ,. BETH A. WOGAN 96 COLD SPRING ROAD CARLISLE, PA 17013 SENDER: DMK REFERENCE: SALES . RETURN Creea F" @:f)0- RECEIPT r4nnn 14tH FN E SERVICE - i a«rm.e o.+ ' Tw ftr a w r... US Postal Service POSTMA QR alflf/. p Receipt for Q SEP Certified Mail 7 O~ ?? No Insurance Coverage Provided D J' ti? o not use for International Mail - -- - - - - - - - - - - - - - - - - - - -- - SOd - - - - - - - - - -- To: P 968'740942 BETH A. WOGAN 26 MCBRIDE AVENUE CARLISLE, PA 17013 SENDER: DMK REFERENCE: SALES c.mn.a r« RETURN e.n.n R?rw RECEIPT SERVICE ITdY M?v? aM FMf US Postal Service Receipt for Certified Mail No Insurance Coverage Providec Do not use for International Mail ....................... ........................... :l =t o U ._ P.,- STATE OF PENNSYLVANIA, SS. COUNTY OF CUMBERLAND 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 ----- 6th --------------------------------------- day of Dec 2000 ____________________________ A. D., ------ under and by virtue ofa writ______________ Execution 12th -------------------------issued on the ------------------------------------- day of ________ Sept ------------ A D 2000 - , out of the Court of Comman Pleas of said County as of Civil 99 ------------------------------------------------------------------- Term, ---- 7373 CMAC MTG Corp Number --------------- atthesuit of_________________--- Beth A Wogan ----------------------------------- against---------------------------------------------------- IS 237 588 duly recorded in Sheriffs Deed Book No -------------- Page ------------- IN TESTIMONY WHEREOF, I have hereunto set my hand and seal of said office this _ZL_??- _ day of -------- -2" ---r A. D., f z ecorddDeeds Recorder of Deeds, Cumberland County, Carlisle, PA My Commission Expires the First Monday of Jan. 2002 GMAC Mortgage Corporation In the Court of Conunon Pleas of -vs- Cumberland County, Pennsylvania Both A. Wogan No. 1999-7373 Civil Trevor Kent, Deputy Sheriff, who being duly sworn according to law, says on October 10, 2000 at 6:40 o'clock P.M. EDST, he served a true copy of real Estate Writ Notice Poster and Description in the above entitled action upon the within named defendant to wit: Both A. Wogan by making known unto Beth Wogan at 96 Cold Spring Road, Carlisle, Cumberland County, Pennsylvania, its contents and at the same time handing to her personally the said true and attested copies of the same. Trevor Kent, Deputy Sheriff, who being duly sworn according to law, says on October 10, 2000 at 6:09 o'clock P.M. EDST, he posted a copy of real Estate Writ Notice Poster and Description on the property of Beth A. Wogan located at 9 West Butler Street, Mt Holly Springs, 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 the defendant Beth A. Wogan by regular mail to her last known address 96 Cold Spring Road, Carlisle, PA. This letter was mailed under the date of October 11, 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 December 6, 2000 at 10:00 o'clock A.M. and sold the same for the sum of S 1.00 to attorney Dale Shughart for Federal National Mortgage Association. It being the highest bid and best price quoted for the same Federal National Mortgage Association of 1900 Market Street, Suite 800, Philadelphia, PA being the buyer in this execution paid to Sheriff R. Thomas Kline the sum of S 572.91 it being costs. Sheriff's Costs: Docketing 30.00 Poundage 11.43 Posting Bills 15.00 Advertising 15.00 Acknowledging Deed 30.00 Auctioneer 10.00 County 1.00 Mileage 8.68 Certified Mail 1.60 Levy 15.00 Surcharge 20.00 Law Journal 195.65 Patriot News 144.90 Share of Bills 23.15 Distribution of Proceeds 25.00 Sheriff's Deed 26.50 S 572.91 pd by atty 01/05/01 Sp aff??.e? Sworn and Subscribed To Before Mc Thisa ja--day ofl R. Thomas Kline, Sheriff 2001 A.D.. % ' a.K -- fay )? Prothonotary Real 4sitc Dcputy 3b•`N / vu (Jt 3 /09 7 /P1, t' A GMAC Mortgage Corporation Plaintiff, V. Beth A. Wogan Defendant(s). CUMBERLAND COUNTY COURT OF COMMON PLEAS CIVIL DIVISION NO. 99-7373 Civil AFFIDAVIT PURSUANT TO RULE 3129 (Affidavit No. 1) GMAC Mortgage Corporation, Plaintiff in the above action, by its attorney, FRANK FEDERMAN, 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 9 W. Butler Street. Mt. Holly Springs PA 17065. 1. Name and address of Owner(s) or reputed Owner(s): 2. 3. NAME LAST KNOWN ADDRESS (If address cannot be reasonably ascertained, please so indicate.) Beth A. Wogan 96 Cold Spring Road Carlisle, PA 17013 Name and address of Defendant(s) in the judgment: NAME LAST KNOWN ADDRESS (If address cannot be reasonably ascertained, please so indicate.) Same as above Name and address of everyjudgment creditor whose judgment is a record lien on the real property to be sold: NAME LAST KNOWN ADDRESS (If address cannot be reasonably ascertained, please so indicate.) None a 5 i .1 1 4. Name and address of the last recorded holder of every mortgage of record: NAME LAST KNOWN ADDRESS (If address cannot be reasonably ascertained, please so indicate.) Federal Home Loan 1155 15'h Street Mortgage Corporation NW #606 Washington, DC 20005-2706 5. Name and address of every other person who has any record lien on the property: NAME LAST KNOWN ADDRESS (If address cannot be reasonably ascertained, please so indicate.) None 6. Name and address of every other person who has any record interest in the property and whose interest may be affected by the sale: NAME LAST KNOWN ADDRESS (If address cannot be reasonably ascertained, please so indicate.) None Name and address of every other person whom the plaintiff has knowledge who has any interest in the property which may be affected by the sale: NAME LAST KNOWN ADDRESS (If address cannot be reasonably ascertained, please so indicate.) Tenant/Occupant 9 W. Butler Street Nit. Holly Springs, PA 17065 Domestic Relations of 13 North Hanover Street Cumberland County Carlisle, PA 17013 I verify that the statements made in this affidavit are true and correct to the best of my personal knowledge or information and belief. I understand that false statements herein are made subject to the penalties of 18 Pa. C.S. Sec. 4904 relating to unswom falsification to authorities. September 6, 2000 DATE F NK FE E AN, ESQUIRE Attorney for Plaintiff r i=. 1 i" 1 IMR: GMAC Mortgage Corporation Plaintiff, V. Beth A. Wogan Defendant(s). September 6, 2000 TO: Beth A. Wogan 96 Cold Spring Road Carlisle, PA 17013 26 McBride Avenue Carlisle, PA 17013 "THIS FIRM IS A DEBT COLLECTOR ATTEMPTING TO COLLECT A DEBT AND ANY INFORMATION OBTAINED WILL BE USED FOR THAT PURPOSE. IF YOU HAVE PREVIOUSLY RECEIVED A DISCHARGE IN BANKRUPTCY AND THIS DEBT WAS NOT REAFFIRMED, THIS IS NOT AND SHOULD NOT BE CONSTRUED TO BE AN ATTEMPT TO COLLECT A DEBT, BUT ONLY ENFORCEMENT OF A LIEN AGAINST PROPERTY." Your house (real estate) at 9 W. Butler Street, Mt. Holly Springs, PA 17065, is scheduled to be sold at the Sheriffs Sale on December 6, 2000 at 10:00 a.m. in the Cumberland County Courhtouse , South Hanover Street, Carlisle, PA 17013, to enforce the court judgment obtained by GMAC Mortgage Corporation (the mortgagee) against you. If the Sheriff's sale is postponed, the property will be relisted for the March 7, 2001 Sheriff's Sale. CUMBERLAND COUNTY No. 99-7373 Civil 9 West Butler Street Mount Holly Springs, PA 17065 NOTICE OF OWNER'S RIGHTS YOU MAY BE ABLE TO PREVENT THIS SHERIFF'S SALE To prevent this Sheriffs Sale, you must take immediate action: The sale will be cancelled if you pay to the mortgagee the back payments, late charges, costs and reasonable attorney's fees due. To find out how much you must pay, you may call: (215) 563-7000. 2. You may be able to stop the sale by filing a petition asking the Court to strike or open the judgment, if the judgment was improperly entered. You may also ask the Court to postpone the sale for good cause. You may also be able to stop the sale through other legal proceedings. You may need an attorney to assert your rights. The sooner you contact one, the more chance you will have of stopping the sale. (See notice on page two on how to obtain an attorney.) 1. If the Sheriffs Sale is not stopped, your property will be sold to the highest bidder. You may find out the price bid by calling (215) 563-7000. 2. You may be able to petition the Court to set aside the sale if the bid price was grossly inadequate compared to the value of your property. 3. The sale will go through only if the buyer pays the Sheriff the full amount due in the sale. To find out if this has happened, you may call (717) 240-6390. 4. If the amount due from the Buyer is not paid to the Sheriff, you will remain the owner of the property as if the sale never happened. 5. You have the right to remain in the property until the full amount due is paid to the Sheriff and the Sheriff gives a deed to the buyer. At that time, the buyer may bring legal proceedings to evict you. 6. You may be entitled to a share of the money which was paid for your house. A schedule of distribution of the money bid for your house will be filed by the Sheriff within 30 days of 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 the 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. CUMBERLAND COUNTY ATTORNEY REFERRAL CUMBERLAND COUNTY BAR ASSOCIATION 2 LIBERTY AVENUE CUMBERLAND COUNTY COURTHOUSE CARLISLE, PA 17013 (717) 249-3166 (800) 990-9108 I DESCRIPTION ALL THAT CERTAIN tract of land with the improvements thereto erected, situate in the Borough of Mount Holly Sprints, Cumberland County, Pennsylvania, bounded and described as follows: BEGINNING at a point on Butler Street, thence by a public alley, South 5 degrees East 160 feet to a point at an alley; thence along the same, South 85 degrees West 80 feet to a point; thence North 5 degrees West 160 feet to Butler Street; thence along said street, North 85 degrees East 80 feet to the Place of BEGINNING. BEING improved with a two and one-half storv frame dwelling house known as 9 Butler Street. Tax Parcel #^_3-32-2336-149 TITLE TO SAID PREMISES IS VESTED IN Beth A. Wogan by Deed fro John G. Homock, si. nvleman and Stanley Miller and Pok Sun Miller, his wife dated 4/10197 recorded 4/14/97 in Deed Book 155 Page 865. WRIT OF EXECUTION and/or ATTACHMENT COMMONWEALTH OF PENNSYLVANIA) NO. 99-7373 CIVILXB TEFd4 COUNTY OF CUMBERLAND) CIVIL ACTION - LAW TO THE SHERIFF OF Cumberland COUNTY: To satisfy the debt, interest and costs due GMAC Mortgage Corporation from Beth A. Wogan 96 Cold Serino Road Carlisle Pa 17013 DEFENDANT(S) (t) You are directed to levy upon the property of the defendant(s) and to sell_ See attached 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) Ilpropertyof the defenclant(s) not levied upon an subject to attachment is found in thepossession of anyoneother than a named garnishee, you are directed to notify hinuhe r that he/she has been added as a garnishee and is enjolned as above stated. Amount Due ? in 2 Interest an - -6-00 per rem Interest 1,537.48 Atty's Comm _% Atly Paid 203.69 Plaintiff Paid Date: September 12, 2000 REQUESTING PARTY: Name Frank Federman Esg Address: Two Penn Center Plaza Suite 900 Philadelphia Pa 19102 Attorney for: Plaintiff Telephone: (215) 563-7000 Supreme Court ID No. 12248 L.L. $11.5 Due Prothy $1.00 Other Costs Curtis R. Long /Prothonotary, Civil Division by: L./a?r2y l t' <asi Deputy REAL ES TA rE SALE No. y? -lamd? /9. a•" the sheriff levied upon the defendants interest in the real property situated in Cumberland County, pa , %ntw..:,d numbered as:9w g -? no more h;, uocribea on Exhibit "A" filed with this writ and by this reference incorporated herein. 'late By h? (RD C;M C:U@ C7 &D tl?_L'i). THE PATRIOT NEWS THE SUNDAY PATRIOT NEWS Proof of Publication Under Ad No. 587, Approved May 16,1929 Commonwealth of Pennsylvania, County of Dauphin) ss James L. Clark being duly sworn according to law, deposes and says: That he Is the Acounts Receivable Manager of The Patriot News Co., a corporation organized and existing under the laws of the Commonwealth of Pennsylvania, with its principal office and place of business at 812 to 818 Market Street, in the City of Harrisburg, County of Dauphin, State of Pennsylvania, owner and publisher of The Patriot-News and The Sunday Patriot-News newspapers of general circulation, printed and published at 812 to 818 Market Street, in the City, County and State aforesaid; that The Patriot-News and The Sunday Patriot-News were established March 4th, 1854, and September 181h, 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/ Metro editions which appeared on the 31st day of October and the 7th and 14th and matter of said printed day(s) of November 2000. That neither he nor said Company is interested in the subject notice or advertising, and that all of the allegations of this statement as to the time, place 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 is7llaneous Book "M", Volume 14, Page 317. (/ PUBLICATION ••• ..... COPY Sworn to and subscribed before me 1st day of ece er 2000 A.D. Notarial Seat D , Teny L. Russell, Notary Publio HaMsburg, DaupNn County My commisslon Expires June 6, 2002 NOTARY PUBLIC ______T Member, Pennsylvania Assocfatbn of Notaries My 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 Probaling same Total Notary Fee(s) 143.40 1.50 144.90 Publisher's Receipt for Advertising Cost The Patriot News Co., publisher of The Patriot-News and The S'fndav Pairio • ews, newspapers of general circulation, hereby acknowledge receipt of the aforesaid notice and publication costs and certifies that the same have been duly paid. By .................................................................... SALE #46: 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 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'-), 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: OCTOBER 27, NOVEMBER 3, 10, 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 SALE NO. 46 Writ No. 1999-7373 Civil GMAC Mortgage Corporation VS. Beth A. Wogan Ally: Frank Federman DESCRIPTION ALL THAT CERTAIN tract of land with the improvements thereto erected. situate in the Borough of Mount Holly Springs. Cumberland County, Pennsylvania, bounded and described as follows: BEGINNING at a point on Butler Street: thence by a public alley. South 5 degrees East 160 feet to a point at an alley: thence along the .. .. _..... ar. .r...._... vr.,., on Roger M. Morgenthal, Editor SWORN TO AND SUBSCRIBED before me this 10 day of NOVEMBER 2000 NbY1,'x1),i SEAL I/ L04S E. SNYDER, Notary Pvbi,c Carlialo 800, Cumberland Counry, PA My Commisuon E-010s Momh S, 2001