HomeMy WebLinkAbout99-07621
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IN THE COURT OF COMMON PLEAS OF CUMBERLAND COUNTY, PENNSYLVANIA
PROPERTY ASSET MANAGEMENT, CIVIL DIVISION
INC., without recourse, Assignee of /}
I EST MORTGAGE NO. 99 - L, t V
COMPANY, ?+¢ !+
Plaintiff,
VS.
GUY W. BURFORD, unmarried,
Defendants.
COMPLAINT IN MORTGAGE
FORECLOSURE
Code
MORTGAGE FORECLOSURE
Filed on behalf of
Plaintiff
Counsel of record for this
party.
Louis P. Vitti, Esquire
PA I.D. #3810
Supreme Court #01072
Louis P. Vitti & Assoc., P.C.
916 Fifth Avenue
Pittsburgh, PA 15219
(412) 281-1725
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COMPLAINTIN-RORTGAGE_EORECLOSURE
NONOTICE
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
THE ATTORNEY AND FILING IN WRITING WITH THE COURT YOUR DEFENSES
AND 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
SHOULD 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 17013
(717) 249-3166
COMUA1NTiN-NiORTGAGE EORECLOS.URE
AND NOW, comes the Plaintiff by its attorneys, Louis P. Vitti and Associates, P.C. and Louis P.
Vitti, Esquire, and pursuant to the Pennsylvania Rules of Civil Procedure Numbers 1141 through 1150, for
its Complaint in Mortgage Foreclosure, sets forth the following:
1. The Plaintiff is a corporation duly authorized to conduct business within the laws of the
Commonwealth of Pennsylvania, having a principal place of business located at C/O 505 South Main Street,
Suite 6000, Orange, CA.
2. The Defendant(s) is/are individuals with a last known mailing address of 409-411 N.
Baltimore Ave, Mt. Holly Springs, PA 17065. The property address is 409411 N. Baltimore Ave, Mt.
Holly Springs, PA 17065 and is the subject of this action.
3. On the 21 st day of August, 1998, in consideration of a loan of Ninety NineThousand Two
Hundred ($99,200.00) Dollars made by Ameriquest Mortgage Co., a DE corporation, to Defendant(s), the
said Defendant(s) executed and delivered to Ameriquest Mortgage Co., aDE corporation, a "Note" secured
by a Mortgage with the Defendant(s) as mortgagor(s) and Ameriquest, as mortgagee, which mortgage was
recorded on the 28th day of August, 1998, in the Office of the Recorder of Deeds of Cumberland County,
in Mortgage Book Volume 1478, page 1084. The said mortgage is incorporated herein by reference thereto
as though the same were set forth fully at length.
4. The premises secured by the mortgage are:
SEE EXHIBIT "A" ATTACHED HERETO.
5. Subsquent thereto, Ameriquest Mortgage Co., aDE corporation, assigned to the Plaintiff,
Property Asset Management, Inc., the said mortgage, that assignment being recorded in the Office of the
Recorder of Deeds of Cumberland County and the said assignment is incorporated herein by reference.
6. Said mortgage provides, inter alia:
"that when as soon as the principal debt secured shall become due and payable, or in
case default shall be made in the payment of any installment of principal and interest, or any
monthly payment, keeping and performance by the mortgagor of any of the terms, conditions
or covenants of the mortgage or note, it shall be lawful for mortgagee to bring an Action of
Mortgage Foreclosure, or other proceedings upon the mortgage, of principal debt, interest
and all other recoverable sums, together with attorney's fees."
7. Since July 1, 1999, the mortgage has been in default by reason, inter alia, of the failure
of the mortgagor(s) to make payments provided for in the said mortgage (including principal and interest)
and, under the terms of the mortgage, the entire principal sum is due and payable.
8. In accordance with the appropriate Pennsylvania Acts of Assembly and the Pennsylvania
Rules of Civil Procedure, the mortgagor(s) has been advised in writing of the mortgagees intention to
foreclose. The appropriate time period has elapsed since the Notice of Intention to Foreclose has been
served upon the mortgagor(s).
9. The amount due on said mortgage is itemized on the attached schedule.
10. Plaintiff does hereby release the personal representative, heir and/or devisee of the
mortgagor(s) from liability for the debt secured by the mortgage.
WHEREFORE, pursuant to Pennsylvania Rule of Civil Procedure Number 1147(6), Plaintiff
demands judgment for the amount due of One Hundred Thirteen Thousand Seven Hundred Seventy Eight
and 39/100 Dollars ($113,778.39) with interest and costs.
Respectfully submitted,
LOUIS P. ITT OC., P.C.
BY t _ '
Louis P. Vitti, Esquire
Attorney for Plaintiff
BURFORD
SCHEDULE OF AMOUNTS DUE UNDER MORTGAGE
Unpaid Principal Balance
Interest @ 9.9900% from 06/01/99 through 12/31/99
(Plus $27.0389 per day after 12/31/99 )
Late charges through 12/31/99
0 months @ 52.19 0.00
Accumulated beforehand 313.14
(Plus $52.19 on the 17th day of each month after 12/31/99 )
Attorney's fee
Escrow deficit
(This figure includes projected additional charges that may be incurred by the
Plaintiff and transmitted to the sheriff as charges on the writ prior to the date of the
sheriff's sale)
BALANCE DUE
98,790.63
5,759.28
313.14
4,939.53
3,.975_.$1
13.77 9
PALS 3
aY Y. P,cfard
409-411 R. 9altia At..
'bunt Sm11Y agriog., PA Voif
RA-rded 1dp.a ancm xW.0th.r. L1.0.,tinn.d
All that e.rtain pzvperty is cb4 7armbou of Mawr SOl3X /primp., coom Of C,.d. jamd. ,OA
LTE Of Pa®aYlra0u, Patvel 1. O. 177-37-7110.Oil. Dei0t meta f011Y d....tb d 9a
Ned dated 09/10/37, n=zded 09/10/97, and appeazIM wA"j the lame r.torda of LA. Ca cr
904 state ..t EOrth Aber., la Sock 139, page 199.
w6 NE.a E3YCEnMTHtS
TO BE A TRUE "COMECT
COPY K
8Y• _
AEA TSORiGAGEC0WM
f?
MIFICATION
AND NOW Louis P. Vitti verifies that the statements made in this Complaint are true
and correct to the best of his knowledge, information and belief. I understand that false statements
herein are made subject to the penalties of 18 Pa.C.S. 4904, relating to unsworn falsification to
authorities.
By virtue of the fact that the Plaintiff is outside the jurisdiction of the court and the
verification cannot be obtained within the time allowed for the filing of this pleading, the pleading
is submitted by counsel having sufficient knowledge, information and belief based upon the
information provided him by the Plaintiff.
ou' P. itti
Dated: December 16, 1999
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SHERIFF'S RETURN - REGULAR
CASE NO: 1999-07621 P
COMMONWEALTH OF PENNSYLVANIA:
COUNTY OF CUMBERLAND
PROPERTY ASSET MANAGEMENT INC
VS
BURFORD GUY W
CHRISTOPHER EVANS Sheriff or Deputy Sheriff of
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Cumberland County, Pensylvania, who being duly sworn according to law,
says, the within COMPLAINT - MORT FORE was served upon
GUY W. BURFORD the
DEFENDANT at 0009:30 HOURS, on the 13th day of January 2000
at 424 N. HANOVER ST
APT 1
CARLISLE, PA 17013 by handing to
GUY BURFORD
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 3.10
Affidavit .00
Surcharge 8.00
.00
29.10
Sworn and Subscribed to before
me this 71 y day of
v?J A. D.
., , 7Ywc¢w'
Prothonotary
So Answers:
R. Thomas Kline
01/14/2000
LOUIS VITTTII ?& ASSOC.
By:
Deputy Sheriff
IN THE COURT OF COMMON PLEAS OF CUMBERLAND COUNTY, PENNSYLVANIA
PROPERTY ASSET MANAGEMENT, CIVIL DIVISION
INC. without recourse, Assignee of
AMERIQUEST MORTGAGE COMPANY, N0.99-7621 Civil Term
Plaintiff, PRAECIPE FOR DEFAULT
JUDGMENT, CERTIFICATION OF
MAILING AND AFFIDAVIT OF NON-
Vs MILITARY SERVICE
GUY W.BURFORD
Code MORTGAGE FORECLOSURE
Defendants. Filed on behalf of
Plaintiff
Counsel of record for this
party:
Louis P. Vitti, Esquire
PA I.D. #3810
Supreme Court #01072
Louis P. Vitti & Assoc., P.C.
916 Fifth Avenue
Pittsburgh, PA 15219
(412) 281-1725
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IN THE COURT OF COMMON PLEAS OF CUMBERLAND COUNTY, PENNSYLVANIA
CIVIL DIVISION
PROPERTY ASSET MANAGEMENT, INC.
without recourse, Assignee of AMERIQUEST
MORTGAGE COMPANY,
VS.
Plaintiff,
NO.99-7621 Civil Term
GUY W. BURFORD,
Defendant.
PRAECIPE FOR DEFAULT TUDGMENT
AND ASSESSMENT OF DAMAGES
TO: PROTHONOTARY OF CUMBERLAND
Enter judgment in Default of an Answer in the amount of $116,130.78, in favor of
the Property Asset Management et al., Plaintiff in the above-captioned action, against the
Defendants, Guy W. Burford and assess Plaintiffs damages as follows and/or as calculated in the
Complaint:
Unpaid Principal Balance $98,790.63
Interest from 06/01/99-03/27/00 8,111.67
(Plus $27.0389 per day after 03/27/00)
Late charges (Plus $52.19 per
14
313
month from 12/31/00-09/06/00 $417.52) .
Attorney's fee 4,939.53
Escrow Deficit 3,975.81
(Plus any additional charges that may be
incurred by the Plaintiff and transmitted
to the sheriff as charges on the writ prior
to the date of the sheriffs sale)
Total Amount Due $116 130.78
The real estate, which is the subject matter of the Complaint, is situate in Boro of
Mount Holly Springs, Cty of Cumberland, Cmwlth of PA, HET a dwg. k/a 411 N. Baltimore
Avenue, Mount Holly Springs, PA 17065. being Parcel No. 233 23?3/6?062.
/ `?/!112336
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P.1\V ,Esquire
icy for the Plaintiff
,
IN THE COURT OF COMMON PLEAS OF CUMBERLAND COUNTY, PENNSYLVANIA
CIVIL DIVISION
PROPERTY ASSET MANAGEMENT, INC.
without recourse, Assignee of AMERIQUEST
MORTGAGE COMPANY,
VS.
Plaintiff,
NO. 99-7621 Civil Temi
GUY W. BURFORD,
Defendant.
CERTIFICATION OF MAILING
I, Louis P. Vitti, do hereby certify that a Notice of Intention to Take Judgment was mailed
to the Defendant(s), in the above-captioned case on March 9, 2000, giving ten (10) day notice that
judgment would be entered should no action be taken.
BY:
SWORN to and subscribed
before me this 28th day
of March, 2000.
Notary Public
LOUIS P. VITTI & ASSOCIATES, P.C.
P. Viii, Esquire
ey for Plaintiff
NoWW Soo,
Pfd t.Kirch. n!nretx.:.,u,liN
rrggr,, Alregron,.
Commfsa ', C\rPIMA
ertber, Penresy?,a,?y'k"'+?!'?;?r,: ; :r fJ?tnrAts
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SIN THE COURT OF COMMON PLEAS OF CUMBERLAND COUNTY, PENNSYLVANIA
CIVIL DIVISION
PROPERTY ASSET MANAGEMENT, INC.
without recourse, Assignee of AMERIQUEST
MORTGAGE COMPANY,
VS.
Plaintiff
NO. 99-7621 Civil Term
GUY W. BURFORD, unmarried,
Y.
Defendant.
IMPORTANT NOTICE
TO: Guy W. Burford
424 N. Hanover Street
Carlisle, PA 17013
Date of Notice: March 9, 2000
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 YOUR LAWYER AT ONCE. IF YOU DO NOT
HAVE A LAWYER OR CANNOT AFFORD ONE, GO TO OR TELEPHONE THE FOLLOWING'
OFFICE SET FORTH BELOW TO FIND OUT WHERE YOU CAN GET LEGAL HELP:
CUMBERLAND COUNTY BAR ASSOCIATION
2 LIBERTY AVENUE
CARLISLE, PA 17013
(717) 249-3166 ?? I
LOUIS P.AITTI & ASSOCIATH ,
BY:
Louis-P' Vitti, Esquire
Attorney for Plaintiff
916 Fifth Avenue
Pittsburgh, PA 15219
** THE DEBT COLLECTOR IS ATTEMPTING TO COLLECT A DEBT AND ANY
INFORMATION OBTAINED WILL BE USED FOR THAT PURPOSE.**
IN THE COURT OF COMMON PLEAS OP CUMBERLAND COUNTY, PENNSYLVANIA
CIVIL DIVISION
COMMONWEALTH OF PENNSYLVANIA, SS:
COUNTY OF ALLEGHENY
BEFORE me, the undersigned authority, personally appeared Louis P. Vitti, Esquire, who,
being duly sworn according to law, deposes and says that he is advised and believes that
DEFENDANT(S) is/are not presently in the active military service of the United States of America
and not members of the Army of the United States, United States Navy, the Marine Corps, or the
Coast Guard, and not officers of the Public Health Service detailed by proper authority for duty with
the Army or Navy; nor engaged in any active military service or duty with any military or naval units
covered by the Soldiers and Sailors Civil Relief Act of 1940 and designated therein as military
service, and to the best of this afftant's knowledge is/are not enlisted in military service covered by
said act, and that the averments herein set forth, insofar as they are within his knowledge, are correct,
and true; and insofar as they are based on information received from others, are true and correct as
he verily believes.
This Affidavit is made under the provisions of the Soldiers and Sailors Civil Relief Act of
1940.
uis P. ,Esquire
SWORN to and subscribed
before me this 27th day
of March, 2000.
l ";'Pp Ad
Notary Public
Notarial Soei
Rebecca L. Kirch, Notary Public
Pittsburggh, Allegheny County i
M Commission Ex Iree Nov. 10, 2Gp3
Mor ber,penrayNanlaAssodationoll NCtanoS
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IN THE COURT OF COMMON PLEAS OF CUMBERLAND COUNTY, PENNSYLVANIA
CIVIL DIVISION
PROPERTY ASSET MANAGEMENT, INC.
without recourse, Assignee of AMERIQUEST
MORTGAGE COMPANY,
Plaintiff,
VS. NO. 99-7621 Civil Term
GUY W. BURFORD,
Defendant.
PRAECIPE FOR WRIT OF
EXECUTION IN MORTGAGE FORECLOSURE
TO: PROTHONOTARY OF CUMBERLAND COUNTY
Issue a Writ of Execution in favor of the Plaintiff and against the Defendant(s) in the
above-captioned matter as follows: /
Amount Due $116,130.78 V/
Interest 03/28/00-09/06/00
Total
4,407.34
$120.538.12
The real estate, which is the subject matter of the Praecipe for Writ of Execution is situate
in: Boro of Mount Holly Springs, Cty of Cumberland, Cmwlth of PA, HET a dwg. k/a 411 N. Baltimore
Avenue, Mount Holly Springs, PA 17065. being Parcel No. 23-32-2336-062.
L,kouis P. itti, Esquire
Attorney for Plaintiff
IN THE COURT OF Cor2•rJrl PLEAS OP CUMBERUu41) COUtTY, PaINSYLVMITA
CIVIL DIVISION
PPASCIPE FOR WRIT OF ECECUTICPl
Caption:
( ) Confessed Judgment
( ) Other
PROPERTY ASSET MANAGEMENT INC.
ET AL.
Vs.
GUY W. BURFORD
TO THE PROTHONOTARY OF THE SAID COURT:
-ile No. 99-7621 CIVIL TERM
Amount Oue $116,130.78
Interest 4,407.34
Atty's Comm
. Costs
The undersigned hereby certifies that the below does not arise out of a retail
installment sale, contract, or account based on a confession of judgment, but if it does,
it is based on the appropriate original proceeding filed pursuant to Act 7 of 1966 as
amended; and for real property pursuant to Act 6 of 1974 as arrended.
Issue writ of execution in the above natter to the Sheriff of CUMBERLAND
County, for debt, interest and costs upon the following described property of the
defendant(s) GUY W. BURFORD
PRAECIPE FOR EKJLZTPION
Issue writ of attachment to the Sheriff of CUMBERLAND County, for debt,
interest and costs, as above, directing attachment against the above-named garnishee(s) for
the following property (if real estate, supply six copies of the description; supply four
copies of lengthy personalty list)
S
and all other property of the defendant(s) in the possession, custody or control of the
said garnishee(s).
(Indicate) Index this writ against the garnishee(s) as a lis pendens against
real estate of the defendant(s) described in the attached exhibit.
DATE: 3/ 2 8/ 0 0 Signature:
Print Name: TOUTS P VTTTT
address: 916 FIFTH AVENUE
PITTSBURGH PA 15219
,':r001:!Y for: PTATNTTPP
412-281-1725
r: yi,• t',,u: ;h v1.: 01072..-
IN THE COURT OF COMMON PLEAS OF CUMBERLAND COUNTY, PENNSYLVANIA
CIVIL DIVISION
PROPERTY ASSET MANAGEMENT, INC.
without recourse, Assignee of AMERIQUEST
MORTGAGE COMPANY,
GUY W. BURFORD,
Plaintiff,
VS.
Defendant.
AFFIDAVIT
NO. 99-7621 Civil Terni
I, Louis P. Vitti, do hereby swear that, to the best of my knowledge, information and
belief, the Defendant(s), is/are the owners of the real property on which the Plaintiff seeks to
execute . That the Defendants' last known address is 424 N. Hanover Street, Carlisle, PA 17013.
V?
Ais Esquire
SWORN TO and subscribed
before me this 27th day of
March, 2000.
Notarial Seal
. ,?) •') Rayecca L. arch, Notary Publlc
pntsbur?gh, Alleggheny County
, jl ?•G UL liG(v: M Commission Explree Nov. 10, 2003
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Na As:/?"'z"nnMNMrrIB6
Notary Public M&nper,Penn Ylva
IN THE COURT OF COMMON PLEAS OF CUMBERLAND COUNTY, PENNSYLVANIA
PROPERTY ASSET MANAGEMENT, CIVIL DIVISION
INC, without recourse, Assignee of
AMERIQUEST MORTGAGE COMPANY NO. 99-7621 Civil term
Plaintiff, PRAECIPF, FOR WRIT OF
EXECUTION AND AFFIDAVIT OF
LAST KNOWN ADDRESS
VS.
GUY W. BURFORD, unmarried,
Defendants.
Code MORTGAGE FORECLOSURE
Filed on behalf of
Plaintiff
Counsel of record for this
party:
Louis P. Vitti, Esquire
PA I.D. #3810
Supreme Court #01072
Louis P. Vitti & Assoc., P.C.
916 Fifth Avenue
Pittsburgh, PA 15219
(412)281-1725
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AND COUNTY, PENNSYLVANIA
IN THE COURT OF COMMON PLEAS
VIL DIVISION
PROPERTY ASSET MANAGEMENT, INC.
without recourse, Assignee of AMERIQUEST
MORTGAGE COMPANY,
VS.
Plaintiff,
NO, 99-7621 Civil Term
GUY W.BURFORD,
Defendant.
AFFIDAVIT PURSUANT TO RULE 3129.1
Property Asset Management, Inc., et al, plaintiff in the above action, sets forth as of the date the
Praecipe for the Writ of Execution was filed the following information concerning the real property
located at 411 N. Baltimore Avenue, Mount Holly Springs, PA 17065.
1. Name and address of Owner(s) or Reputed Owner(s):
Name: Address (Please indicate if this
cannot be reasonably ascertained)
Guy W. Burford 424 N. Hanover Street
Carlisle, PA 19013
2. Name and address of Defendant(s) in the judgment:
Name: Address (Please indicate if this
cannot be reasonably ascertained)
Same as No. 1 above.
3. Name and last known address of every judgment creditor whose judgment is a record lien
on the real property to be sold:
Name:
Bureau of Compliance
Address (Please indicate if this
cannot be reasonably ascertained)
Dept. 208946
Harrisburg, PA 17128-0946
Cumberland County Adult Probation 1 Courthouse Square
Carlisle, PA 17013-3387
4. Name and address of the last recorded holder of every mortgage of record:
Name
Personal Mortgage Corporation
Address (Please indicate if this
cannot be reasonably ascertained)
100 Business Center Drive
Highway 22
Brewster, NY 10509
Beneficial Mortgage Corp
100 Business Center Drive
Brewster, NY 10509
Ameriquest Mortgage Company 1100 Town and County Rd
Suite 200
Orange, CA 92868
5. Name and address of every other person who has any record lien on the property:
Name
Address (Please indicate if this
cannot be reasonably ascertained)
None
6. Name and address of every other person who has any record interest in or record lien on
the property and whose interest-may be affected by the sale:
Name Address (Please indicate if this
cannot be reasonably ascertained)
None
7. Name and address of every other person of whom the Plaintiff has knowledge who has
any interest in the property which may be affected by the sale:
Name
Tax Collector of Boro. of Mt. Holly Springs
Borough of Mounty Holly Springs
Address (Please indicate if this
cannot be reasonably ascertained)
3 Trine Avenue
Mount Holly Springs, PA 17065
200 Hamilton Street
Mount Holly Springs, PA 17065
Commonwealth of PA -DPW
Court of Common Pleas of
Cumberland County
Domestic Relations Division
Bureau of Compliance
Tenant/Occupant
P.O. Box 8016
Harrisburg, PA 17105
One Courthouse Square
Carlisle, PA 17013
Clearance Support Section
Dept. #281230
Harrisburg, PA 17128-1230
Attn: Susan Blough
411 HN. Baltimore Avenue
Mount Holly Springs, PA 17065
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. Section 4904 relating to unworn falsification to authorities.
March 27, 2000
Date
SWORN TO and subscribed
before me this 27th day
of March, 2000.
Notary Public
V
Lo is P. V ` i Esquire
ttomey for Plaintiff
NotaMl Sea,
ji L Kl 0 ^ktax'ubtic
gh. PeNyhen6• ru nty
Mon -.:.cues Nov. 10.2003
Mwber,Penm-panaassoaatlonot Notaries
_ ___ ._ ,r.:,
NOTICE OF SHERIFF'S SALE OF
REAL ESTATE PURSUANT TO
PENNSYLVANIA RULE OF CIVIL
PROCEDURE 3129.1
TO: Guy W. Burford
424 N. Hanover Street
Carlisle, PA 17013
AND: ALL LIEN HOLDERS
TAKE NOTICE that by virtue of the above Writ of Execution issued out of the Court of
Common Pleas of Cumberland County, Pennsylvania and to the Sheriff of Cumberland County,
directed, there will be exposed to Public Sale in Cumberland County Courthouse on September 6,
2000 at 10:00 A.M., the following described real estate, of which Guy W. Burford are owners or
reputed owners:
Boro of Mount Holly Springs, Cty of Cumberland, Cmwlth of PA, HET a dwg. k/a 411 N. Baltimore
Avenue, Mount Holly Springs, PA 17065. being Parcel No. 23-32-2336-062.
The said Writ of Execution has issued on a judgment in the mortgage foreclosure action of
Property Asset Management Inc. et al. vs. Guy W. Burford at NO. 99-7621 Civil Term in the
amount of $120,538.12.
Claims against property must be filed at the Office of the Sheriff before above sale date.
Claims to proceeds must be made with the Office of the Sheriff before the sale date.
Schedule of Distribution will be filed with the Office of the Sheriff no later than thirty (30)
days from sale date.
Exceptions to Distribution or a Petition to Set Aside the Sale must be filed with the Office
of the Sheriff no later than ten (10) days from the date when Schedule of Distribution is filed in the
Office of the Sheriff.
Attached hereto is a copy of the Writ of Execution. It has been issued because there is a
judgment against you. It may cause your property to be held or taken to pay the judgment. You may
have legal rights to prevent your property from being taken. A lawyer can advise you more
specifically of these rights. If you wish to exercise your rights you must act promptly.
ii
YOU SHOULD TAKE THIS NOTICE AND THE WRIT OF EXECUTION 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 ADVICE.
CUMBERLAND COUNTY BAR ASSOCIATION
2 LIBERTY AVENUE
CARLISLE, PA 17013
(717)249-3166
You may have legal rights to prevent the Sheriffs Sale and the loss ofyour property. In order
to exercise those rights, prompt action on your part is necessary. A lawyer may be able to help you.
You may have the right to prevent or delay the Sheriffs Sale by filing, before the sale occurs,
a petition to open or strike the judgment or a petition to stay the execution.
If the judgment was entered because you did not file with the Court any defense or objection
you might have within twenty (20) days after service of the Complaint for Mortgage Foreclosure and
Notice to Defend, you may have the right to have the judgment opened in you promptly file a petition
with the Court alleging a valid defense and a reasonable excuse for failing to file the defense on time.
If the judgment is opened, the Sheriffs Sale would ordinarily be delayed pending a trial of the issue
of whether the Plaintiff has a valid claim to foreclose the Mortgage.
You may also have the right to have the judgment stricken if the Sheriff has not made a valid
return of service of the Complaint and Notice to Defend or if the judgment was entered before twenty
(20) days after service or in certain other events. To exercise this right, you would have to file a
petition to strike thejudgment.
You may also have the right to petition the Court to stay or delay the execution and the
Sheriffs Sale if you can show a defect in the Writ of Execution or service or demonstrate any other
legal or equitable right.
You may also have the right to have the Sheriffs Sale set aside if the property is sold for a
grossly inadequate price or if there are defects in the Sheriffs Sale. To exercise this right, you should
file a petition with the Court after the sale and before the Sheriff has delivered his Deed to the
property. The Sheriff will deliver the Deed if no petition to set aside the sale is filed within ten (10)
days from the date when the Schedule of Distribution is filed in the Office of the [Sheriff.
V v
Louis P. i, Esquire
Attorney for Plaintiff
916 Fifth Avenue
Pittsburgh, PA 15219
(412) 281-1725
"THE DEBT COLLECTOR IS ATTEMPTING TO COLLECT A DEBT AND ANY
INFORMATION OBTAINED WILL BE USED FOR THAT PURPOSE."
11.E
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IN THE COURT OF COMMON PLEA SOIL CUMBERLAND COUNTY, PENNSYLVANIA DIVISION
PROPERTY ASSET MANAGEMENT, INC.
without recourse, Assignee of AMERIQUEST
MORTGAGE COMPANY,
Plaintiff,
VS. NO. 99-7621 Civil Term
GUY W. BURFORD, Defendant.
LEGAL DESCRIPTION
TRACT 1:
of land with the improvements thereon erected situate in t Borou
tract ALL that certain
Mount Holly Springs, Cumberland County, Pennsylvania, bounded and described asefollows h of
ON the East by the Carlisle-Hanover Tumpike Road, known as?Baltimore
20 feet wide and thetheSouth
North
land now or formerly of Daniel March; on the West by a public Y
by land formerly of J. Lynn Elliot and Mane G. Elliot, his wife, and conveyed to Dixie Lee Piper,
Grantor herein.
Having a frontage of 25 feet, more or less, on Baltimore Avenue and extending 180 feet in depth,
and being improved with a dwelling house known as 409 North Baltimore Avenue.
The Northern line of the tract above describe shall pass through the center of the partition wall
dividing the house on said tract and the house on the tract formerly of J. Lynn Elliott and Marie C.
Elliot, his wife conveyed to Dixie Lee Piper, Grantor Herein.
TOGETHER with the right privilege in the Grantor, her heirs and assigns, to secure water from the
water main entering the basement of the premises formerly of J. Lynn Elliot and Mane G. Elliot, his
wife.
BEING the same property conveyed to Dixie Lee Piper, by R. Elizabeth Elliot, by deed dated
October 27, 1987 and recorded in the Office of the Recorder of Deeds for Cumberland County in
Deed Book Vol. A33, Page 343.
EXCEPTING AND RESERVING, however to R. Elizabeth Elliott, single woman, without liability
for waste, for the term of her natural life, so long as she desires to use such premises an pay all cost
of maintenance thereof, including taxes, assessments, insurance and ordinary repairs, a life estate in
the above described property. Said Grantor herein, Dixie Lee Piper, has a Power of Attorney for R.
Elizabeth Elliot, to conveyed premises located 409 North Baltimore Avenue, due to this life tenancy
held by the abovementioned R. Elizabeth Elliot.
r
TRACT 2:
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:
On the east by the Carlisle-Hanover Turnpike Road, known as Baltimore Avenue; on the North by
land now or formerly of Theodore Shover; on the West by a public alley of 20 feet wide; and on
the south by land now or formerly of R. Elizabeth Elliott.
HAVING a frontage of 25 feet, more or less, or Baltimore Avenue and extending 180 feet in depth;
and being improved with a dwelling house known as 411 North Baltimore Avenue.
THE Southern line of the tract above described shall pass through the center of the partition wall
dividing the house on said tract and the house on the tract now or formerly of R. Elizabeth Elliott.
SUBJECT, however, to the rights and privileges of R. Elizabeth Elliott, her heirs and assigns, to
secure water from the water main entering the basement of the premises above described.
BEING the same property which was conveyed in Dixie Lee Piper, Grantor of herein, by deed dated
November 10, 1987, and recorded in the Office of Recorder of Deeds For Cumberland County in
Deed Book Vol. A 33, page 820. Said property was conveyed as part of the Estate Proceeding for
J. Lynn Elliott who died on September 24, 1987 and by his last will and Testament duly probated
in the Office of the Register of Wills for Cumberland county in Will Book 104, page 955, appointed
Dixie Lee Piper Executrix of his estate, to whom letters testamentary were duly issued.
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IN THE COURT OF COMMON PLEAS OF CUMBERLAND COUNTY, PENNSYLVANIA
CIVIL DIVISION
PROPERTY ASSET MANAGEMENT, INC.
without recourse, Assignee of AMERIQUEST
MORTGAGE COMPANY,
Plaintiff,
VS.
NO. 99-7621 Civil Term
GUY W. BURFORD,
Defendant.
AMENDED AFFIDAVIT PURSUANT TO RULE 3129.1
Property Asset Management, Inc., et al, plaintiff in the above action, sets forth as of the date the
Praecipe for the Writ of Execution was filed the following information concerning the real property
located at 411 N. Baltimore Avenue, Mount Holly Springs, PA 17065.
1. Name and address of Owner(s) or Reputed Owner(s):
Name: Address (Please indicate if this
cannot be reasonably ascertained)
Guy W. Burford 424 N. Hanover Street
Carlisle, PA 19013
2. Name and address of Defendant(s) in the judgment:
Name: Address (Please indicate if this
cannot be reasonably ascertained)
Same as No. 1 above.
3. Name and last known address of everyjudgment creditor whose judgment is a record lien
on the real property to be sold:
Name: Address (Please indicate if this
cannot be reasonably ascertained)
Bureau of Compliance Dept. 208946
Harrisburg, PA 17128-0946
Cumberland County Adult Probation
Property, Asset,Management Inc:;
Providian National Bank
I Courthouse Square
Carlisle, PA 17013-3387
c% 505'South 141aidStreet
Siiite600Q
OrangeGA`i926.13
29514Main Street
Tilton;°NI-I03276
4. Name and address of the last recorded holder of every mortgage of record:
Name
Personal Mortgage Corporation
Address (Please indicate if this
cannot be reasonably ascertained)
100 Business Center Drive
Highway 22
Brewster, NY 10509
Beneficial Mortgage Corp
Ameriquest Mortgage Company
Property Asset Managment Inc.
100 Business Center Drive
Brewster, NY 10509
1100 Town and County Rd
Suite 200
Orange, CA 92868
c/o 505 South Main Street
Suite 6000
Orange, CA 92613
5. Name and address of every other person who has any record lien on the property:
Name Address (Please indicate if this
cannot be reasonably ascertained)
None
6. Name and address of every other person who has any record interest in or record lien on
the property and whose interest may be affected by the sale:
Name Address (Please indicate if this
cannot be reasonably ascertained)
None
7. Name and address of every other person of whom the Plaintiff has knowledge who has
any interest in the property which may be affected by the sale:
Name
Tax Collector of Boro. of Mt. Holly Springs
Borough of Mounty Holly Springs
Commonwealth of PA -DPW
Court of Common Pleas of
Cumberland County
Domestic Relations Division
Address (Please indicate if this
cannot be reasonably ascertained)
3 Trine Avenue
Mount Holly Springs, PA 17065
200 Hamilton Street
Mount Holly Springs, PA 1706.5
P.O. Box 8016
Harrisburg, PA 17105
One Courthouse Square
Carlisle, PA 17013
Bureau of Compliance
Tenant/Occupant
Clearance Support Section
Dept. #281230
Harrisburg, PA 17128-1230
Attn: Susan Blough
411 HN. Baltimore Avenue
Mount Holly Springs, PA 17065
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. Section 4904 relating to unswom falsification to authorities.
April 11. 2000
Date
SWORN TO and subscribed
before me this 1 Ith day
of April, 2000.
?' ? 9Crt? L2
Notary Public
(;buis P. Esquire
Attorney for Plaintiff
4MOM'-ryrypnIl n5£tr.,ynlNn fd MMn Ilyp
4. -
.. J J
..t
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 ----------------
First Natl BK Of Chicago Tr of STructured Asset Securties Corp Mtg
----- Pass_nmough----------------------------------------------------------------
the same having been sold to said grantee on the ------6th
-------------------------------------- day of
December 2000
--- --------- --------- --------- A. D., 1'-------- under and by virtue of a writ--------------
Execution 4th
------------------------------------------------issued on the -----
-------------------------------
April 2000
day of _________________ A. D., 199______, out of the Court of Common Pleas of said County as of
Civil
--- --- il ------------------••----------------------------------
--------------- Term, 19_ -9--i!6& X
-
7621 Property Asset Management Inc assienee of Ameriguest
Number--------------- atthe suit of---------------------------,141:e- -------- - ------
Guy {9 Buford
against----------------------------- ---------- is
duly recorded in Sheriff's Deed Book No. __ 237______, Page _____ 11
IN TESTIMONY WHEREOF, I have hereunto
set my hand and seal of said office this _. %day
of / ?? - --/------- A.
Record'er of Deeds
Recorder of Deeds, Cumberland County, Carlisle, PA
My Commission Expires the first Monday of An. 2002
Property Asset Management, Inc. In the Court of Common Pleas of
Without recourse, Assignee of Ameriquest Cumberland County, Pennsylvania
Mortgage Company No. 1999-7621 Civil
-vs-
Guy W. Burford
Dawn L. Kell, Deputy Sheriff, who being duly sworn according to law, says on April
13, 2000 at 10:40 o'clock A.M. EDST, she served a true copy of Real Estate Writ Notice
Poster and Description in the above entitled action upon the defendant to wit: Guy W.
Burford by handing to Guy W. Burford at 424 North Hanover Street, Carlisle,
Cumberland County, Pennsylvania, its contents and at the same time handing to him
personally the said true and attested copies of the same.
Richard E. Smith, Deputy Sheriff, who being duly sworn according to law, says on
July 11, 2000 at 7:12 o'clock P.M. EDST, he posted a copy of real Estate Writ Notice
Poster and Description on the property of Guy W. Burford located at 41 1 North
Baltimore Avenue, Mt Holly Springs, Cumberland County, Pennsylvania according to
law.
R. Thomas Kline, Sheriff, who being duly swom according to law, says he served the
above Real Estate Writ Notice Poster and Description in the following manner: 'I'lie
Sheriff mailed a notice of the pendency of the action to the defendant Guy W. Burford by
regular mail to 424 North Hanover Street, Carlisle, Pennsylvania. This letter was mailed
under the date of July 12, 2000 and never returned to the Sheriff's Office.
Richard E. Smith Deputy Sheriff, who being duly sworn according to law, says on
September 21, 2000 at 10:08 o'clock A.M. EDST he served a copy of Notice of Sheri 11's
Sale on the defendant Guy Burford by handing to Guy Burford at 424 North I Innover
Street, Carlisle, Cumberland County, Pennsylvania and at the same time handing to hint
personally the said true and attested copies of the same.
Richard Smith Deputy Sheriff, who being duly sworn according to Inv, says oat
September 21, 2000 at 10:41 o'clock A.M. EDST, he posted a copy of Notice of Real
Estate Sale on the properties of Guy Burford located at 409 and 411 North Iltaltintore
Avenue, Mt Holly Springs, Cumberland County, Pennsylvania according to law.
R. Thomas Kline, Sheriff, who being duly sworn according to late, 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 Courtly, Pennsylvania oat
December 6, 2000 at 10:00 o'clock A.M. EST and sold the sane to Kathy Hirsch litr'I'he
First National Bank of Chicago for the sum of $ 1.00. It being the highest bid and hest
price received for the same The First National Bank of Chicago ol'505 South Main
Street, Orange Street, CA. Being the buyer in this execution paid to Sheri IT R, 'llutnuas
Kline the sum of $ 1,489.90 it being costs.
Sheriff's Costs
Docketing
Poundage 30 QO
30
Posting Bills 01
Advertising 30.00
Acknowledging Deed 30 00
30.00
Auctioneer 10.00
Law Library .50
County 1.00
Certified Mail 3.29
Mileage 6.82
Levy 30.00
Postpone sale 20.00
Surcharge 30.00
Law Journal 660.65
Patriot News 503.40
Share of Bills 23.53
Distribution of Proceeds 25.00
Sheriff's Deed ?fi,5-Q
$ 1,489.90 Pd By Atty
12/12/00
Sworn and Subscribed To Before Me j
So answers sre f`?4'
This C/ R- Day ofc,)
R. Thomas Kline, Sheriff
2001.. A.D.
r thonotary By
Real Estate Deputy
J?
nab. &
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IN THE COURT OF COMMON PLEAS OF CUMBERLAND COUNTY, PENNSYLVANIA
CIVIL DIVISION
PROPERTY ASSET MANAGEMENT, INC.
without recourse, Assignee of AMERIQUEST
MORTGAGE COMPANY,
Plaintiff,
VS. NO. 99-7621 Civil Term
GUY W. BURFORD,
Defendant.
AFFIDAVIT PURSUANT TO RULE 3129.1
Property Asset Management, Inc., et al, plaintiff in the above action, sets forth as of the date the
Praecipe for the Writ of Execution was filed the following information concerning the real property
located at 411 N. Baltimore Avenue, Mount Holly Springs, PA 17065.
1. Name and address of Owner(s) or Reputed Owner(s):
Name: Address (Please indicate if this
cannot be reasonably ascertained)
Guy W. Burford 424 N. Hanover Street
Carlisle, PA 19013
2. Name and address of Defendant(s) in the judgment:
Name: Address (Please indicate if this
cannot be reasonably ascertained)
Same as No. I above.
3. Name and last known address of every judgment creditor whose judgment is a record lien
on the real property to be sold:
Name: Address (Please indicate if this
cannot be reasonably ascertained)
Bureau of Compliance Dept. 208946
Harrisburg, PA 17128-0946
1 .
Cumberland County Adult Probation
1 Courthouse Square
Carlisle, PA 17013-3387
4. Name and address of the last recorded holder of every mortgage of record:
Name
Personal Mortgage Corporation
Beneficial Mortgage Corp
Ameriquest Mortgage Company
Address (Please indicate if this
cannot be reasonably ascertained)
100 Business Center Drive
Highway 22
Brewster, NY 10509
100 Business Center Drive
Brewster, NY 10509
1100 Town and County Rd
Suite 200
Orange, CA 92868
5. Name and address of every other person who has any record lien on the property:
Name Address (Please indicate if this
cannot be reasonably ascertained)
None
6. Name and address of every other person who has any record interest in or record lien on
the property and whose interest may be affected by the sale:
Name Address (Please indicate if this
cannot be reasonably ascertained)
None
7. Name and address of every other person of whom the Plaintiff has knowledge who has
any interest in the property which may be affected by the sale:
Name
Tax Collector of Boro. of Mt. Holly Springs
Borough of Mounty Holly Springs
Address (Please indicate if this
cannot be reasonably ascertained)
3 Trine Avenue
Mount Holly Springs, PA 17065
200 Hamilton Street
Mount Holly Springs, PA 17065
Commonwealth of PA -DPW
Court of Common Pleas of
Cumberland County
Domestic Relations Division
Bureau of Compliance
Tenant/Occupant
P.O. Box 8016
Harrisburg, PA 17105
One Courthouse Square
Carlisle, PA 17013
Clearance Support Section
Dept. #281230
Harrisburg, PA 17128-1230
Attn: Susan Blough
411 HN. Baltimore Avenue
Mount Holly Springs, PA 17065
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. Section 4904 relating to unswom falsification to authorities.
March 27.2000
Date
SWORN TO and subscribed
before me this 27th day
of March, 2000.
4.Loi;s Vi Vi., Esquire
ttc mey for Plaintiff
1_7) B tJOtarircti ?a,' Seanca.
abette L. Klry ???nric
Wltsburgh. Au,Iyhen nnnty
_ M Canmisslon i.%Firas u?. 10.20031
Notary Public MwW PennsyIvani3AS,-ff=onof Notaries
/
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NOTICE OF SHERIFF'S SALE OF
REAL ESTATE PURSUANT TO
PENNSYLVANIA RULE OF CIVIL
PROCEDURE 3129.1
TO: Guy W. Burford
424 N. Hanover Street
Carlisle, PA 17013
AND: ALL LIEN HOLDERS
TAKE NOTICE that by virtue of the above Writ of Execution issued out of the Court of
Common Pleas of Cumberland County, Pennsylvania and to the Sheriff of Cumberland County,
directed, there will be exposed to Public Sale in Cumberland County Courthouse on September 6,
2000 at 10:00 A.M., the following described real estate, of which Guy W. Burford are owners or
reputed owners:
Boro of Mount Holly Springs, Cty of Cumberland, Cmwlth of PA, HET a dwg. k/a 411 N. Baltimore
Avenue, Mount Holly Springs, PA 17065. being Parcel No. 23-332-2336-062.
The said Writ of Execution has issued on a judgment in the mortgage foreclosure action of
Property Asset Management Inc. et al. vs. Guy W. Burford at NO. 99-7621 Civil Term in the
amount of $120,538.12.
Claims against property must be filed at the Office of the Sheriff before above sale date.
Claims to proceeds must be made with the Office of the Sheriff before the sale date.
Schedule of Distribution will be filed with the Office of the Sheriff no later than thirty (30)
days from sale date.
Exceptions to Distribution or a Petition to Set Aside the Sale must be filed with the Office
of the Sheriff no later than ten (10) days from the date when Schedule of Distribution is filed in the
Office of the Sheriff.
Attached hereto is a copy of the Writ of Execution. It has been issued because there is a
judgment against you. It may cause your property to be held or taken to pay the judgment. You may
have legal rights to prevent your property from being taken. A lawyer can advise you more
specifically of these rights. If you wish to exercise your rights you must act promptly.
YOU SHOULD TAKE THIS NOTICE AND THE WRIT OF EXECUTION 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 ADVICE.
CUMBERLAND COUNTY BAR ASSOCIATION
2 LIBERTY AVENUE
CARLISLE, PA 17013
(717)249-3166
You may have legal rights to prevent the Sheriffs Sale and the loss of your property. In order
to exercise those rights, prompt action on your part is necessary. A lawyer may be able to help you.
You may have the right to prevent or delay the Sheriffs Sale by filing, before the sale occurs,
a petition to open or strike the judgment or a petition to stay the execution.
If the judgment was entered because you did not file with the Court any defense or objection
you might have within twenty (20) days after service of the Complaint for Mortgage Foreclosure and
Notice to Defend, you may have the right to have the judgment opened in you promptly file a petition
with the Court alleging a valid defense and a reasonable excuse for failing to file the defense on time.
If the judgment is opened, the Sheriffs Sale would ordinarily be delayed pending a trial of the issue
of whether the Plaintiff has a valid claim to foreclose the Mortgage.
You may also have the right to have the judgment stricken if the Sheriff has not made a valid
retum of service of the Complaint and Notice to Defend or if the judgment was entered before twenty
(20) days after service or in certain other events. To exercise this right, you would have to file a
petition to strike the judgment.
You may also have the right to petition the Court to stay or delay the execution and the
Sheriffs Sale if you can show a defect in the Writ of Execution or service or demonstrate any other
legal or equitable right.
You may also have the right to have the Sheriffs Sale set aside if the property is sold for a
grossly inadequate price or if there are defects in the Sheriff s Sale. To exercise this right, you should
file a petition with the Court after the sale and before the Sheriff has delivered his Deed to the
property. The Sheriff will deliver the Deed if no petition to set aside the sale is filed within ten (10)
days from the date when the Schedule of Distribution is filed in the Office of the Sheriff.
V v
Louis P. i, Esquire
Attorney for Plaintiff
916 Fifth Avenue
Pittsburgh, PA 15219
(412) 281-1725
"THE DEBT COLLECTOR IS ATTEMPTING TO COLLECT A DEBT AND ANY
INFORMATION OBTAINED WILL BE USED FOR THAT PURPOSE."
. IN THE COURT OF COMMON PLEAS OF CUMBERLAND COUNTY, PENNSYLVANIA
CIVIL DIVISION
PROPERTY ASSET MANAGEMENT, INC.
without recourse, Assignee of AMERIQUEST
MORTGAGE COMPANY,
Plaintiff,
VS.
GUY W. BURFORD,
TRACT 1:
NO. 99-7621 Civil Term
Defendant.
LEGAL DESCRIPTION
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:
ON the East by the Carlisle-Hanover Tumpike Road, known as Baltimore Avenue on the South by
land now or formerly of Daniel March; on the West by a public alley 20 feet wide and on the North
by land formerly of J. Lynn Elliot and Marie G. Elliot, his wife, and conveyed to Dixie Lee Piper,
Grantor herein.
Having a frontage of 25 feet, more or less, on Baltimore Avenue and extending 180 feet in depth,
and being improved with a dwelling house known as 409 North Baltimore Avenue.
The Northern line of the tract above describe shall pass through the center of the partition wall
dividing the house on said tract and the house on the tract formerly of J. Lynn Elliott and Marie C.
Elliot, his wife conveyed to Dixie Lee Piper, Grantor Herein.
TOGETHER with the right privilege in the Grantor, her heirs and assigns, to secure water from the
water main entering the basement of the premises formerly of J. Lynn Elliot and Marie G. Elliot, his
wife.
BEING the same property conveyed to Dixie Lee Piper, by R. Elizabeth Elliot, by deed dated
October 27, 1987 and recorded in the Office of the Recorder of Deeds for Cumberland County in
Deed Book Vol. A33, Page 343.
EXCEPTING AND RESERVING, however to R. Elizabeth Elliott, single woman, without liability
for waste, for the term of her natural life, so long as she desires to use such premises an pay all cost
of maintenance thereof, including taxes, assessments, insurance and ordinary repairs, a life estate in
the above described property. Said Grantor herein, Dixie Lee Piper, has a Power of Attorney for R.
Elizabeth Elliot, to conveyed premises located 409 North Baltimore Avenue, due to this life tenancy
held by the abovementioned R. Elizabeth Elliot.
JA
,TRACT2:
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:
On the east by the Carlisle-Hanover Turnpike Road, known as Baltimore Avenue; on the North by
land now or formerly of Theodore Shover; on the West by a public alley of 20 feet wide; and on
the south by land now or formerly of R. Elizabeth Elliott.
HAVING a frontage of 25 feet, more or less, or Baltimore Avenue and extending 180 feet in depth;
and being improved with a dwelling house known as 411 North Baltimore Avenue.
THE Southern line of the tract above described shall pass through the center of the partition wall
dividing the house on said tract and the house on the tract now or formerly of R. Elizabeth Elliott.
SUBJECT, however, to the rights and privileges of R. Elizabeth Elliott, her heirs and assigns, to
secure water from the water main entering the basement of the premises above described.
BEING the same property which was conveyed in Dixie Lee Piper, Grantor of herein, by deed dated
November 10, 1987, and recorded in the Office of Recorder of Deeds For Cumberland County in
Deed Book Vol. A 33, page 820. Said property was conveyed as part of the Estate Proceeding for
J. Lynn Elliott who died on September 24, 1987 and by his last will and Testament duly probated
in the Office of the Register of Wills for Cumberland county in Will Book 104, page 955, appointed
Dixie Lee Piper Executrix of his estate, to whom letters testamentary were duly issued.
?R-j1
WRIT OF EXECUTION and/or ATTACHMENT
COMMONWEALTH OF PENNSYLVANIA) NO. 99-7621 CIVIL W_
COUNTY OF CUMBERLAND) CIVIL ACTION - LAW
TO THE SHERIFF OF Cumberland COUNTY:
To satisfy the debt, interest and costs due Property Asset Management, Inc. without recourse
Assignee of Attteriquest Mortgage Company
PLAINTIFF(S)
from Guy W. Burford
DEFENDANT(S)
(1) You are directed to levy upon the property of the defendant(s) and to sell- Boro of Mount Holly
Springs, Cty of Cumberland, Cmwlth of PA. HET a dwq.k/a 411 N. Baltimore Avenue Mount
Holly Springs, PA 17065. being Parcel No. 23-32-2336-062.
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 hirn/herthat he/she has been added as a garnishee and is enjoined as above
stated.
Amount Due S116.130.78
Interest 03128/00-09/06/00 $4,407.34
Ally's Comm,
Ally Paid $101.10
Plaintiff Paid
Date: April 4, 2000
Due Prothy $1.00
Other Costs
Curtis R.
Prothonotary, Civil Division
REQUESTING PARTY:
Name ro ,;a a V; ti Esq
Address: 916 Fifth Ave-
Attorney for:- pl aint; ff
Telephone: (419) 781-1775
v Deputy
Supreme Court ID No. 01072
_.. r' .!.
REAL ESTATE SALE No,.
'1i 1;" '' a 2""' the sheriff levied upon the defendants
interest in the real property situated I n44 ., •, . 'moo
,
Cumberland County, Pa., known, and numbered as: i-v//
amore fully described on Exhibit "A" filed with
this writ and by this reference incorporated herein.
gate:-?- By:
003 !!7 E` 71 1 earl
i
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S
THE PATRIOT NEWS
THE SUNDAY PATRIOT NEWS
Proof of Publication
Under Rct No. 567. Rooroued Mau 16. 1929
Commonwealth of Pennsylvania, County of Dauphin) as
James L. Clark being duly sworn according to law, deposes and says:
That he is the Accounts Receivables 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 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 1st, 8th and 15th day(s) of
August 2000. That neither he nor said Company is interested in the subject matter of said printed notice or
advertising, and that all of the allegations of this statement as to the time, place and character of publication are
true; and
That he has personal knowledge of the facts aforesaid and is duly authorized and empowered to verify this
statement on behalf of The Patriot-News Co. aforesaid by virtue and pursuant to a resolution unanimously passed and
adopted severally by the stockholders and board of directors of the said Company and subsequently duly recorded in
the office for the Recording of Deeds in and for said County of Dauphin in Miscellaneous Book "M",
Volume 14, Page 317. (t//
PUBLICATION ---------------------
COPY
Sworn to and subscribed before a this 30th day of /Cugupt?2000 A.D.
SALE f15 _ ??
Noladal Seal /
Terry L. Russell, Notary Publl
Harrisburg, Dauphin County NOTA Y PUBLIC
My COmmissW Expires June 6. mission expires June 6, 2002
Member, PennsyNeNa Association el Nolarios
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 $ 501.90
Probating same Notary Fee(s) $ 1.50
Total $ 503.40
IS Receipt for Advertising Coat
E PATRIOT-NEWS and THE SUNDAY PATRIOT-NEWS, newspapers of general
f the aforesaid notice and publication costs and certifies that the same have
THE PATRIOT-NEWS CO.
By ....................................................................
been duly paid.
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, Editorof 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 theliorough 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:
JULY 28, AUGUST 4, 11, 2000
Afftant 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. 8
Writ No. 99-7621 Civil
Property Asset Management. Inc.
without recourse. Assignee of
Ameriquest Mortgage Company
VS.
Guy W. Buford
Atty.: Louis P. Vittl
LEGAL DESCRIPTION
TRACT 1:
ALL that certain tract of land with
the improvements thereon erected
situate in the Borough of Mount Holly
Springs. Cumberland County. Penn-
sylvania, bounded and described as
follows:
ON Ute East by the Carlisle-Hano-
ver Turnpike Road. known as Bahl-
more Avenue on the South by land
now or formerly of Daniel March: on
the West by a public alley 20 feet wide
mid on the Nnrth by land fornterlY of
Roger M. Morgenthal, Editor
SWORN TO AND SUBSCRIBED before me this
__L l day of AUGUST. 2000
1016 E. SNYDER,Nolory Pubic
CorN a Eom. Cumberland County, PA
My Ce rnjq is Exoms Minch S, 4001
'ff-wim
IN THE COURT OF COMMON PLEAS OF CUMBERLAND COUNTY, PENNSYLVANIA
PROPERTY ASSET MANAGEMENT
INC. without recourse, Assignee of
AMERIQUEST MORTGAGE
COMPANY,
Plaintiff,
Vs.
GUY W. BURFORD,
Defendants.
CIVIL DIVISION
No.99-7621 CIVIL TERM
AFFIDAVIT OF SERVICE
Code MORTGAGE FORECLOSURE
Filed on behalf of
Plaintiff
Counsel of record for this
party:
Louis P. Vitti, Esquire
PA I.D. #3810
Supreme Court #01072
Louis P. Vitti & Assoc., P.C.
916 Fifth Avenue
Pittsburgh, PA 15219
(412) 281-1725
.._ ? 5`yrs
IN THE COURT OF COMMON PLEAS OF CUMBERLAND COUNTY, PENNSYLVANIA
CIVIL DIVISION
PROPERTY ASSET MANAGEMENT, INC.,
without recourse, Assignee of AMERIQUEST
MORTGAGE COMPANY,
Plaintiff,
VS.
GUY W. BURFORD,
Defendant.
NO. 99-7621-CIVIL TERM
AFFIDAVIT OF SERVICE
I, Rebecca L. Kirch, do hereby certify that a Notice of Sale was mailed and served
upon the defendants by certified mail on September 11, 2000 and all lien holders by Certificate
of Mailing for service in the above-captioned case on September 8, 2000, advising them of the
Sheriff's sale of the property at 409 & 411 N. Balitmore Avenue, Mount Holly Springs, PA
17065, on December 6, 2000.
LOUIS P. VITTI & ASSOCIATES, P.C.
BY 1 U
Rebecca L. Kirch
SWORN to and subscribed
before me this 25th day
of October, 2000.
Notanal Seal
Kathleen Carr Notary Pu
? ` Pittsburgh, Allegheny County
Notary ublic Me tWgr PG yt n aA== May 1,
yNBrba/?`..SOCAat10rIW NObltc1a,
aneS
U.S. POSTAL SERVICE CERTIFICATE OF MAILING
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197 F686`
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PiTTS5L1Ar•.-1. PA 15219
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COURT OF COMMON PLEAS OF CUMBERLAND C
DOEMSTIC REALTIONS DIVISION
ONE COURTHOUSE SQUARE
CARLISLE, PA 17013
PS Form 3817, Mar. 1989
7/5
Affix fee hero In stamps
or motor postage and
post mark. Inquiet of
Postmaster for current
Received From:
LOUIS P, VITTI
68654135
?A 1529?8RG" PA 1 5 2 1
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BURFORD/RLK
PA 17128
12/6
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TENATN/OCCUPANT
411 N. BALITMORE AVENUE
MOUNT HOLLY SPRINGS, PA 17065 BURFORD/RLK
PS Form 3817, Mar. 1989
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post mark. Inquire of
Postmaster for current
4135
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TAX rr)l T FirTnR !)V RnRrt nR VT NnT T V ¢a
3 TRINE AVENUE
MOUNT HOLLY SPRINGS, PA 17065
PS Form 3817, Mar. 1989
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12/5
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BOROUGH OF MT. HOLLY STPINGS
200 HAMILOTN STREET
MOUNT HOLLY SPRINGS, PA 17065 1
PS Form 3817. Mar. 188`.1
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or meter postage and
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12/6
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COMMONWEALTH OF PA-DPW
P.O. BOX 8016
HARRISBURG, PA 17105 BURFORD/RLK
12/6
PS Form 3817, Mar. 1989
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MAY BE USED FOR DOMESTIC AND INTERNATIONAL MAIL, DOES NOT
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PROVIDIAN NATIONAL BANK 1 :.
I
295 MAIN STREET
TILT ON, NH 03276
BURFORDJRIK
12/5
PS Form 3817, Mar. 1989
U.S. POSTAL SERVICE CERTIFICATE OF MAILING
MAY BE USED FOR DOMESTIC AND INTERNATIONAL MAIL, DOES NOT
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(412) 281-1725
One piece of ordinary mail addressed lo:
PERSONAL MORTGAGE CORPORATION
100 BUSINESS CENTER DRIVE
HIGHWAY 22
BREWSTER, NY 10509
PS Form 3817, Mar. 1989
Affix lee here in stamps
or mater postage and
post mark. Inquire of
Postmaster for current
X135
;219
?J
BURFORD/RLK
12/5
U.S. POSTAL SERVICE CERTIFICATE OF MAILING
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Race'v 'R O * c ? ??-
???19 P. VITTI LASSO - _?4
P1386
PITTSB 1IW ?PA f?3idRGNPA
(412) 281-1725
One piece of ordinary mail addressed to:
AMERIQUEST MORTGAGE COMPANY
1100 TOWN & COUNTRY DRIVE
SUITE 200
ORANGE, CA 92686 l
Affix too hero in stamps
or meter Postage and
post mark. Inquire of
Postmaster for current
54135
15219
iURFORD/RLK
ra roan jai y, mar. ISt19
12/6
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UU r,no PO 36541 35
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(412) "81-17
One piec. al ordinary mail addressed ro: -
CUMBERLAND COUNTY ADULT PROBATION COURTHOUSE SQUARE
CARLISLE, PA 17013
PS Form 3817, Mar. 1989
5 2 1 9
BURFROD/RLK
12/5
/.S. POSTAL SERVICE CERTIFICATE OF MAILING Affix 1l) here In stamps
LAY BE USED FOR DOMESTIC AND INTERNATIONAqL AIL, DOES NOT or mater postage end
ROVIDE FOR INSURANCE-POSTMASTER ipliS dJS. past mark. Inquire of
Postmaster for current
Reeeive LOUIS P. VI?316& AS W? ??t
TTI6& x• f 8.8 6 5 4 73 5
Ni 1 I `EIRC`H •ttiAlIffttPA 1 5 2 y9? ?
(412) 281-1725 ' -" ,
One piece of ordinary mail eddmssetl to: ' /' UL'.
BUREAU OF COMPLIANCE i'
DEPT. 208946
-HARRISBURG RA 17128 0946 BURFORD%RLK
12/6
PS Form 3817, Mar. 1989
U.S. POSTAL SERVICE CERTIFICATE OF MAILING
MAY BE USEO FOR DOMESTIC AND INTERNATIONAL Tt GOES NOT
PROVIDE FOR INSURANCE-POSTMASTER .ptF 3,'ti
it r * Yr
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P. VITTI?A ASSOG]Arr $
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PITTSBURIAW 9PA 159S91GH PA
(412) 281-1725
One piece olordinary mail addressed to:
--PROPERTY ASSET MANAGEMENT IN
C/O 505 SOUTH MAIN STREET
SUITE 600
ORANGE, CA 92613
rD rorm Jd l /, mar. I ut1B
Affix fee here in stamps
or meter postage and
post mark. Inquire of
Postmaster for current
54135
15219
I Le
BURFORD/RLK
12/5
lire
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.S. POSTAL SERVICE CERTIFICATE OF AILING or motor postage and
mark. Inquire of
AV USED FOR DOMESTIC AND INTERNATIONAL ?MSI L. DOES DOES SNOT post Postmaster for current
IOVID VIDE FOR INSURANCE-POSTMASTER t>
Received From: * * * y
LOUIS PVI 38654135
916 I AVEW&GH PA 1 5 2-1;9i
,11/!? ,
One piece of ordinary mail addressed to: I j
BENEFICAL MORTGAGE CORP. ``,•.?? `:
10 BUSINESS CENTER DRIVE ?dU
BREWSTER, NY 10509 BURFORD/RLK
12/5
PS Form 3817, Mar. 1989
Affix fee herein stamps
CERTIFICATE OF MAILING or meter postage and
U.S. POSTAL SERVICE
MAV BE USED FOR DOMESTIC AND INTERNATIONAL MAIL. DOES NOT
.E5 r
-XT post mark. Inquire of
postmaster for current
PROVIDEfOR INSURANCE-POSTMASTER
ITtIrr D: VITTI VAMCIAT P886 4 135
PITTSBUR(?ztQ-61`'w11TSeURGHPA 5219
,
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One piece of ordinary mail addressed to:
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TENANT OCCUPANT J
409 N. BALITMORE AVENUE
MOUNT HOLLY SPRINGS PA 17065 BURF66/RK
12/5
PS Form 3817, Mar. 1989
001% 00"S
DCIVUtR:.
I ?.GwrE ha. al 61t, H M W. aoatriclad oelhorY. - I also wish to receive the :S
7.'ti Rlet )aur teen aM mNeaa an it* m of thin form w Net wa ran mturn tw canf following services (for an titre fee}.:
lJtoa, IOft farm ro tm hmt of the riioilpbce; ar an ate back n apace mn'not pantlt ? Re&Idcled Delivery
ojlrRanun tieCW wleMM to whM the mode wee aelnered erd ft date deWWO& t 1) -"i.1
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a,w a reseed to - - ,
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P 974 408 380
( "iCIJY N.. SURFORD _.
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IN THE COURT OF COMMON PLEAS OF CUMBERLAND COUNTY, PENNSYLVANIA
PROPERTY ASSET MANAGEMENT CIVIL DIVISION
INC., without recourse, Assignee of
AMERIQUEST MORTGAGE COMPANY No.99-7621 Civil term
Plaintiff,
VS.
AFFIDAVIT OF SERVICE
Code MORTGAGE FORECLOSURE
Filed on behalf of
Plaintiff
GUY W. BURFORD
Defendants. Counsel of record for this
party:
Louis P. Vitti, Esquire
PA I.D. #3810
Supreme Court #01072
Louis P. Vitti & Assoc., P.C.
916 Fifth Avenue
Pittsburgh, PA 15219
(412) 281-1725
IN THE COURT OF COMMON PLEAS OF CUMBERLAND COUNTY, PENNSYLVANIA
CIVIL DIVISION
PROPERTY ASSET MANAGEMENT, INC.,
without recourse, Assignee of AMERIQUEST
MORTGAGE COMPANY,
Plaintiff,
vs.
NO. 99-7621 Civil Term
GUY W. BURFORD,
Defendant.
I, Rebecca L. Kirch, do hereby certify that a Notice of Sale was mailed and served
upon the defendants by certified mail on April 13, 2000 and all lien holders by Certificate of
Mailing for service in the above-captioned case on March 31, 2000, advising them of the
Sheriff's sale of the property at 411 N. Balitmore Avenue, Mount Holly Springs, PA 17065,
an September 6, 2000.
LOUIS P. VITTI & ASSOCIATES, P.C.
Rebecca L. Kirch '
SWORN to and subscribed
before me this 8th day FEdlor. Notary!
111, Ad h
I rr 09 any(
Of ?-- -. Ion Expiras it I,-,
August, 2000.
. ?.IVa047 AS50CIaiuL„ Notary Public
'!
an
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Postmaster for current
4135
1 00
/RLK
U. POSTAL SERVICE CERTIFICATE OF MAILING
MAIL. DOES NOT
MAY BE USED FOR DOMESTIC AND INTERNATI0,W,,33TT
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PERSONAL MORTGAGE CORP.
_4
100 BUSINESS CENTER DRIVE ?(
HIGHWAY 22
BREWSTER, NY 10509
PS Form 3817, Mar. 1989
Affix fee here in stamps
or meter postage and
post mark. Inquire of
Postmaster for currant
135
100
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or molar postage and
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I.
U.S. POSTAL SERVICE CERTIFICATE OF MAILING
MAY BE USED FOR DOMESTIC AND INTERNATIONAL MAIL, DOES NOT
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P. ReeelyedFiora: v I
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One piece of ordinary mail addressed to:
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BENEFICIAL MORTGAGE CORP.
100 BUSINESS CENER DRIVE
BREWSTERS, NY 10509
PS Form 3817, Mar. 1989
4135
1 00
S
9
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3UiF. M/RLK
PS Form 3817, Mar. 1989
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POat mark,
C1 In Of
a0elTaat01 for current
PS F,11 71-38
BURFORI).DTv
Affix lee here in stamps
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post mark. Inquire of
Postmaster for current
BURFORD/RLK
U POSTAL SERVICE CERTIFICATE OF MAILING
MAY gE USED FOR DOMESTIC A
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BOROUGH
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200 HAMILTON STREET
MOUNTY HOLLY SPRIONGS, PA 17065 U
B
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PS Form 3817, Mer. 1989
U.S. POSTAL SERVICE CERTIFICATE OF MAILING
MAY BE USED FOR DOMESTIC AND INTERNAj19y6, MAIL, DOES NOT
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ONIA(INNFALTH - 12 `
.O. BOX 8016
RRISBURG, PA 17105
P5 Form 3817, Mar. 1989
VFTI"&
9161M17p
One piece of ordinary mail addressed to:
DOMESTIC RELATIONS DIVISION
ONE COURTHOUSE SQUARE
CARLISLE, PA 17013
PS Form 3817, Mar. 1989
U.S. POSTAL SERVICE CERTIFICATE OF MAILING
MAY BE USED FOR DOMESTIC AND INTERNATIONAL MAIL, DOES NOT
PROVIDE FOR INSURANCE-POSTMASTER - PoS,.
Received From:
LOUIS 88
65
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BURFORD/RLK
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4135
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71
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U.S. POSTAL SERVICE CERTIFICATE OF MAILING
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0 Pf-A-R 6 3
PITTS8 IDAP c-4 PA 1
(412) 281 -11 e0
One place of ordinary mail addressed to:
Of
RITREATT OF rOMPT TA rF,
CLEARANCE SUPOPORT SECTION d
DEPT. 281230
HARRISBURG, PA 17128-1230
1`5 f•orm 3817. Mar. 1989
Received 0FJlv7 P. VITA
Affix roe hero in stomps
of molar postage and
post mark. Inquire of
Postmaster for currant
J?YY?
5135
1 DO
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3URFORD/RLK
Affix foe here in stamps
or meter postage and
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Postmaster for Current
B8614135
-AR 1 00
PA
One place of ordinary all addressed to:
IT ` ti Iy1
BUREAU OF COMPLIANCE 2
DEPT. 208946 JvAF?RD/gLK
HARRSBURG, PA 17128-0946
:Affix fee here in stamps
U s POSTAL SERVICE CERTIFICATE OF MAILING or mater postage and
post mark. Inquire of
MAY BE USED FOP DOMESTIC AND INTERNATIONAL MAIL. DOES NOT
e._encTAIASTER ..nV`?S; Postmaster for current
Received From: * * *?
PBSfi54135
`rL,L tnrT.I •'
91G=i1.1r8t1-?".I PITISBURGHPA 152S0?GH,PACg4yr
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One Piece of ordinary mall addressed to: r 9 r
PROVIDIAN NATIOANL DP.NX
295 MAIN STREET
TILTON, NJ 03276 BURFORD/RLK
AMENDED3129
PS Form 3817, Mar. 1989
1
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