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HomeMy WebLinkAbout03-3963FEDERMAN AND PHELAN, LLP By: FRANK FEDERMAN, ESQ., Id. No. 12248 LAWRENCE T. PHELAN, ESQ., Id. No. 32227 FRANCIS S. HALLINAN, ESQ., Id. No. 62695 ONE PENN CENTER PLAZA, SUITE 1400 PHILADELPHIA, PA 19103 (215) 563-7000 ATTORNEY FOR PLAINTIFF COURT OF COMMON PLEAS CIVIL DIVISION GMAC MORTGAGE CORPORATION 500 ENTERPRISE ROAD SUITE 150 HORSHAM, PA 19044-0969 Plaintiff ROBERT C. PETERS, JR. 733 MOUNTAIN ROCK ROAD CARLISLE, PA 17013-942 COURT OF COMMON PLEAS CiVIL DIVISION TERM CUMBERLAND COUNTY DIANA L. PETERS 733 MOUNTAIN ROCK ROAD CARLISLE, PA 17013-942 Defendant(s) CIVIL ACTION - LAW COMPLAINT/3/MORTGAGE FORECLOSURE NOTICE **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 CORRESPONDENCE IS NOT AND SHOULD NOT BE CONSTRUED TO BE AN ATTEMPT TO COLLECT A DEBT, BUT ONLY ENFORCEMENT OF A 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. 1F 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 File #: 64457 FEDERMAN AND PHELAN, LLP By: FRANK FEDERMAN, ESQ., Id. No. 12248 LAWRENCE T. PHELAN, ESQ., Id. No. 32227 FRANCIS S. HALLINAN, ESQ., Id. No. 62695 ONE PENN CENTER PLAZA, SUITE 1400 PHILADELPHIA, PA 19103 (215) 563-7000 ATTORNEY FOR PLAINT1]?F COURT OF COMMON PLEAS CIVIL DIVISION GMAC MORTGAGE CORPORATION 500 ENTERPRISE ROAD SUITE 150 HORSHAM, PA 19044-0969 Plaintiff ROBERT C. PETERS, IR. 733 MOUNTAIN ROCK ROAD CARLISLE, PA 17013-942 COURT OF COMMON PLEAS CIVIL DIVISION TERM NO. ox CUMBERLAND COUNTY DIANA L. PETERS 733 MOUNTAIN ROCK ROAD CARLISLE, PA 17013-942 Defendant(s) CIVIL ACTION - LAW COMPLAINT IN MORTGAGE FORECLOSURE NOTICE **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 CORRESPONDENCE IS NOT AND SHOULD NOT BE CONSTRUED TO BE AN ATTEMPT TO COLLECT A DEBT, BUT ONLY ENFORCEMENT OF ALIEN 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 iiling 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. 117 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 File #: 64457 IF THIS IS THE FIRST NOTICE THAT YOU HAVE RECEIVED FROM THIS OFFICE, BE ADVISED THAT: 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. THE LAW DOES NOT REQUIRE US TO WAIT UNTIL THE END OF THE THIRTY (30) DAY PERIOD FOLLOWING FIRST CONTACT WITH YOU BEFORE SUING YOU TO COLLECT THIS DEBT. EVEN THOUGH THE LAW PROVIDES THAT YOUR ANSWER TO THIS COMPLAINT IS TO BE FILED IN THIS ACTION WITHIN TWENTY (20) DAYS, YOU MAY OBTAIN AN EXTENSION OF THAT TIME. FURTHERMORE, NO REQUEST WILL BE MADE TO THE COURT FOR A JUDGMENT UNTIL THE EXPIRATION OF THIRTY (30) DAYS AFTER YOU HAVE RECEIVED THIS COMPLAINT. HOWEVER, IF YOU REQUEST PROOF OF THE DEBT OR THE NAME AND ADDRESS OF THE ORIGINAL CREDITOR WITHIN THE THIRTY (30) DAY PERIOD THAT BEGINS UPON YOUR RECEIPT OF THIS COMPLAINT, THE LAW REQUIRES US TO CEASE OUR EFFORTS (THROUGH LITIGATION OR OTHERWISE) TO COLLECT THE DEBT UNTIL WE MAIL THE REQUESTED INFORMATION TO YOU. YOU SHOULD CONSULT AN ATTORNEY FOR ADVICE CONCERNING YOUR RIGHTS AND OBLIGATIONS IN THIS SUIT. File #: 64457 Plaintiff is GMAC MORTGAGE CORPORATION 500 ENTERPRISE ROAD SUITE 150 HORSHAM, PA 19044-0969 The name(s) and last known address(es) of the Defendant(s) are: ROBERT C. PETERS, JR. 733 MOUNTAIN ROCK ROAD CARLISLE, PA 17013-942 DIANA L. PETERS 733 MOUNTAIN ROCK ROAD CARLISLE, PA 17013-942 who is/are the mortgagor(s) and real owner(s) of the property hereinafter described. On 8/24/98 mortgagor(s) made, executed and delivered a mortgage upon the premises hereinafter described to PLAINTIFF which mortgage is recorded in the Office of thc Recorder of CUMBERLAND County, in Mortgage BookNo. 1478, Page 1020. The premises subject to said mortgage is described as attached. The mortgage is in default because monthly payments of principal and interest upon said mortgage due 03/01/2003 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. File#: 64457 The following amounts are due on the mortgage: Principal Balance Interest 02/01/2003 through 08/11/2003 (Per Diem $18.77) Attorney's Fees Cumulative Late Charges 08/24/1998 to 08/11/2003 Cost of Suit and Title Search Subtotal $105,385.69 3,603.84 1,250.00 263.73 $ 550.00 $111,053.26 Escrow Credit 0.00 Deficit 1,406.35 Subtotal $ 1,406.35 TOTAL $112,459.61 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 SheriWs Sale. If the Mortgage is reinstated pr/or to the Sale, reasonable attorney's fees will be charged. Notice of Intention to Foreclose as set forth in Act 6 of 1974, Notice of Homeowner's Emergency Assistance Program pursuant to Act 91 of 1983, as amended in 1998, and/or Notice of Default as required by the mortgage document, as applicable, have been sent to the Defendant(s) on the date(s) set forth thereon, and the temporary stay as provided by said notice has terminated because Defendant(s) has/have failed to meet with the Plaintiff or an authorized consumer credit counseling agency, or has/have been denied assistance by the Pennsylvania Housing Finance Agency. This action does not come under Act 6 of 1974 because the original mortgage amount exceeds $50,000. WHEREFORE, PLAINTIFF demands an in rem Judgment against the Defendant(s) in the sum of $112,459.61, together with interest from 08/11/2003 at the rate of $18.77 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. FEDERMAN AND PHELAN, LLP / FRANK FEDERMAN, ESQUIRE LAWRENCE T. PHELAN, ESQUIRE FRANCIS S. HALL[NAN, ESQUIRE Attorneys for Plaintiff File #: 64457 Bucher; tLhenoe alon~ lande now or formerly o£ Robert C. plan Nor':h 7" 53' 29" W~et 419.20 feet to an i~on pin set in ~E~INNIN3. CONTAINING ~.721 acres. PREMISES O1~: 733 MOUNTAIN ROCK ROAD VERIFICATION Robert Lelli 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 tree 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. OAt : SHERIFF'S RETURN - REGULAR CASE NO: 2003-03963 P COMMON-WEALTH OF PENNSYLVANIA: COUNTY OF CUMBERLAND GMAC MORTGAGE CORPORATION VS PETERS ROBERT C JR ET AL GERALD WORTHINGTON , Cumberland County,Pennsylvania, says, the within COMPLAINT - MORT FORE was served upon PETERS DIANA L DEFENDANT , at 1759:00 HOURS, on the 20th day of August at 733 MOUNT ROCK ROAD CARLISLE, PA 17013 by handing to DIANA PETERS a true and attested copy of COMPLAINT - MORT FORE NOTICE Sheriff or Deputy Sheriff of who being duly sworn according to law, the , 2003 together with and at the same time directing Her attention to the contents thereof. Sheriff's Costs: Docketing 6.00 Service .00 Affidavit .00 Surcharge 10.00 .00 16.00 Sworn and Subscribed to before me this ~ day of honorary So Answers: R. Thomas Kline 08/21/2003 FEDERMAN AND PHELAN Deputy Sheriff SHERIFF'S RETURN - CASE NO: 2003-03963 P COMMONWEALTH OF PENNSYLVANIA: COUNTY OF CUMBERLAND GMAC MORTGAGE CORPOP~ATION VS PETERS ROBERT C JR ET AL REGULAR GEP~ALD WORTHINGTON , Cumberland County, Pennsylvania, says, the within COMPLAINT - MORT FORE PETERS ROBERT C JR DEFENDANT , at 1759:00 HOURS, at 733 MOUNT ROCK ROAD CARLISLE, PA 17013 by handing to DIANA PETERS, WIFE OF DEFENDANT a true and attested copy of COMPLAINT - MORT FORE NOTICE Sheriff or Deputy Sheriff of who being duly sworn according to law, was served upon on the 20th day of August the , 2003 together with and at the same time directing Her attention to the contents thereof. Sheriff's Costs: Docketing 18.00 Service 5.52 Affidavit .00 Surcharge 10.00 .00 33.52 Sworn and Subscribed to before me this 27~ day of P~othonotary · , 3 So Answers: R. Thomas Kline 08/21/2003 FEDERMAN AND PHELAN FEDERMAN AND PHELAN, LLP By: FRANK FEDERMAN Identification No. 12248 Attorney for Plaintiff ONE PENN CENTER AT SUBURBAN STATION 1617 JOHN F. KENNEDY BLVD., SUITE 1400 PHILADELPHIA, PA 19103-1814 (215) 563-7000 GMAC MORTGAGE CORPORATION 500 ENTERPRISE ROAD, SUITE 500 HORSHAM, PA 19044-0969 Plaintiff, ROBERT C. PETERS, JR. DIANA L. PETERS Defendant(s). CUMBERLAND COUNTY COURT OF COMMON PLEAS CIVIL DIVISION NO. 03-3963 CIVIL TERM PRAECIPE FOR IN REM JUDGMENT FOR FAILURE TO ANSWER AND ASSESSMENT OF DAMAGES TO THE PROTHONOTARY: Kindly enter an in rem judgment in favor of the Plaintiff and against ROBERT C. PETERS, JR. and DIANA L. PETERS, Defendant(s) for failure to file an Answer to Plaintiffs Complaint within 20 days fron~service thereof and for Foreclosure and Sale of the mortgaged premises, and assess Plaintiffs damages as follows: As set forth in Complaint Interest from 8/12/03 to 9/24/03 TOTAL $112,459.61 $825.88 $113,285.49 I hereby certify that (1) the addresses of the Plaintiff and Defendant(s) are as shown above, and (2) that notice has been given in accordance with Rule 237.1, copy attached. FRANK FEDERMAN, ESQUIRE Attorney for Plaintiff DAMAGES ARE HEREBY ASSESSED AS INDICATED. PRO PROTHY FEDERMAN AND PHELAN, LLP - FRANK FEDERMAN, ESQ., Id. No. 12248 LAWRENCE T. PHELAN, ESQ., Id. No. 32227 FRANCIS S. HALLINAN, ESQ., Id. No. 62695 ONE PENN CENTER PLAZA, SUITE 1400 PHILADELPHIA, PA 19103 (?15) 563-7000 GMAC MORTGAGE CORPORATION Plaintiff VS. ROBERT C. PETERS, JR. DIANA L. PETERS Defendants ATTORNEY FOR PLAINTIFF : COURT OF COMMON PLEAS : CML DMSION : CUMBERLAND COUNTY : NO. 03-3963 CML TERM TO: ROBERT C. PETERS, JR. 733 MOUNTAIN ROCK ROAD CARLISLE, PA 17013 FILE COPY DATE OF NOTICE: SEPTEMBER 10, 200.3 THiS FIRM IS A DEBT COLLECTOR AI-tI~MPTING TO COLLECT A DEBT. THIS NOTICE IS SENT TO YOU IN AN A'I-I'EMPT 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 ATI~MPT TO COLLECT A DEBT, BUT ONLY AS ENFORCEMENT OF LIEN AGAINST PROPERTY. IMPORTANT NOTICE YOU ARE IN DEFAULT BECAUSE YOU HAVE FAILED TO ENTER A WRITTEN APPEARANCE PERSONALLY OR BY ATTORNEY AND FILE IN WRITING WITH THE COURT YOUR DEFENSES OR OBJECTIONS TO THE CLAIMS SET FORTH AGAINST YOU. UNLESS YOU ACT WITHIN TEN DAYS FROM THE DATE OF THIS NOTICE, A JUDGMENT MAY BE ENTERED AGAINST YOU WITHOUT A HEARING AND YOU MAY LOSE YOUR PROPERTY OR OTHER IMPORTANT RIGHTS. YOU SHOULD TAKE THIS PAPER TO YOUR LAWYER AT ONCE. IF YOU DO NOT HAVE A LAWYER, GO TO OR TELEPHONE THE OFFICE SET FORTH BELOW. THIS OFFICE CAN PROVIDE YOU WITH INFORMATION ABOUT HIRING A LAWYER. IF YOU CANNOT AFFORD TO HIRE A LAWYER, THIS OFFICE MAY BE ABLE TO PROVIDE YOU WITH INFORMATION ABOUT AGENCIES THAT MAY OFFER LEGAL SERVICES TO ELIGIBLE PERSONS AT A REDUCED FEE OR NO FEE. CUMBERLAND COUNTY CUMBERLAND COUNTY BAR ASSOCIATION 2 LIBERTY AVENUE CARLISLE, PA 17013 (717) 249-3166 FRANK FEDERMAN, ESQUIRE LAWRENCE T. PHELAN, ESQUIRE FRANCIS S. HALLINAN, ESQUIRE Attorneys for Plaintiff FEDERMAN AND PHELAN, LLP FRANK FEDERMAN, ESQ., Id. No. 12248 LAWRENCE T. PHELAN, ESQ., Id. No. 32227 FRANCIS S. HALLINAN, ESQ., Id. No. 62695 ONE PENN CENTER PLAZA, SUITE 1400 PHILADELPHIA, PA 19103 (5'15) 56~-70fl0 GMAC MORTGAGE CORPORATION Plwmtiff VS. ROBERT C. PETERS, JR. DIANA L. PETERS Defendants ATTORNEY FOR PLAINTIFF COURT OF COMMON PLEAS CIVIL DMSION CUMBERLAND COUNTY NO. 03-3963 CIVIL TERM TO: DIANA L. PETERS 733 MOUNTAIN ROCK ROAD CARLISLE, PA 17013 DATE OF NOTICE: SEPTE. MBER 10, 2003 THIS FIRM IS A DEBT COLLECTOR AI-D~MPTING TO COLLECT A DEBT. THIS NOTICE IS SENT TO YOU IN AN ATI'I~MPT TO COLLECT THE INDEBTEDNESS REFERRED TO HEREIN, AND ANY INFORMATION OBTAINED FROM YOU WILL BE USED FOR THAT PURPOSE.Il: YOU HAVE PREVIOUSLY RECEIVED A DISCHARGE IN BANKR~CY, THIS CORRESPONDENCE IS NOT AND SHOULD NOT BE CONSTRUED TO BE AN AFI't~MPT TO COLLECT A DEBT, BUT ONLY AS ENFORCEMENT OF LIEN AGAINST PROPERTY. IMPORTANT NOTICE YOU ARE IN DEFAULT BECAUSE YOU HAVE FAILED TO ENTER A WRITTEN APPEARANCE PERSONALLY OR BY ATTORNEY AND FILE IN WRITING WITH THE COURT YOUR DEFENSES OR OBJECTIONS TO THE CLAIMS SET FORTH AGAINST YOU. UNLESS YOU ACT WITHIN TEN DAYS FROM THE DATE OF THIS NOTICE, A JUDGMENT MAY BE ENTERED AGAINST YOU WITHOUT A HEARING AND YOU MAY LOSE YOUR PROPERTY OR OTHER IMPORTANT RIGHTS. YOU SHOULD TAKE THIS PAPER TO YOUR LAWYER AT ONCE. IF YOU DO NOT HAVE A LAWYER, GO TO OR TELEPHONE THE OFFICE SET FORTH BELOW. THIS OFFICE CAN PROVIDE YOU WITH INFORMATION ABOUT HIRING A LAWYER. IF YOU CANNOT AFFORD TO HIRE A LAWYER, THIS OFFICE MAY BE ABLE TO PROVIDE YOU WITH INFORMATION ABOUT AGENCIES THAT MAY OFFER LEGAL SERVICES TO ELIGIBLE PERSONS AT A REDUCED FEE OR NO FEE. CUMBERLAND COUNTY CUMBERLAND COUNTY BAR ASSOCIATION 2 LIBERTY AVENUE CARLISLE, PA 17013 (717) 249-3166 FRANK FEDERMAN, ESQUIRE LAWRENCE T. PHELAN, ESQUIRE FRANCIS S. HALLINAN, ESQUIRE Attorneys for Plaintiff SHERIFF'S RETURN - CASE NO: 2003-03963 P COMMONWEALTH OF PENNSYLVANIA: COUNTY OF CUMBERLAND GMAC MORTGAGE CORPOP~ATION VS PETERS ROBERT C JR ET AL REGULAR GERALD WORTHINGTON , Cumberland County, Pennsylvania, says, the within COMPLAINT - MORT FORE PETERS ROBERT C JR DEFENDANT , at 1759:00 HOURS, at 733 MOUNT ROCK ROAD CARLISLE, PA 17013 DIANA PETERS, WIFE OF DEFENDANT a true and attested copy of COMPLAINT - MORT FORE NOTICE Sheriff or Deputy Sheriff of who being duly sworn according to law, was served upon on the 20th day of August by handing to the , 2003 together with and at the same time directing Her attention to the contents thereof. Sheriff's'Costs: Docketing 18.00 Service '5.52 Affidavit .00 Surcharge 10.00 .00 33.52 Sworn and Subscribed to before me this day of A.D. So Answers: R~ Thomas Kline 08/21/2003 FEDERMANAND PHELAN Deputy Sheriff Prothonotary SHERIFF'S RETURN - REGULAR C.~SE NO: 2003-03963 P COMMONWEALTH OF PENNSYLVANIA: COUNTY OF CUMBERLAND GMAC MORTGAGE CORPOP~ATION VS PETERS ROBERT C JR ET AL GERALD WORTHINGTON Cumberland County, Pennsylvania, says, the within COMPLAINT - MORT FORE was served upon PETERS DIANA L DEFENDANT , at 1759:00 HOURS, on the 20th day of August at 733 MOUNT ROCK ROAD CARLISLE, PA 17013 by handing to DIANA PETERS a true and attested copy of COMPLAINT - MORT FORE NOTICE Sheriff or Deputy Sheriff of who being duly sworn according to law, the , 2003 together with and at the same time directing Her attention to the contents thereof. Sheriff's Costs: Docketing 6.00 Service .00 Affidavit .00 Surcharge 10.00 .00 16.00 Sworn and Subscribed to before me this day of A.D. Prothonotary So Answers: R. Thomas Kline 08/21/2003 FEDERMANAND PHELAN Deputy sheriff PRAECIPE FOR WRIT OF EXECUTION - (MORTGAGE FORECLOSURE) P.R.C.P. 3180-3183 GMAC MORTGAGE CORPORATION Plaintiff, ROBERT C. PETERS, JR. DIANA L. PETERS Defendant(s). No. 03-3963 CIVIL TERM TO THE DIRECTOR OF THE OFFICE OF THE PROTHONOTARY: Issue writ of execution in the above matter: Amount Due Interest fi:om 9/2403 to MARCH 3, 2004 (per diem -$18.62) TOTAL $113,285.49 $2,997.82and Costs FRANK FEDERMAN, ESQUIRE One Penn Center at Suburban Station 1617 John F. Kennedy Boulevard, Suite 1400 Philadelphia, PA 19103 - 1814 Attorney for Plaintiff Note: Please attach description of property. No. ALL THAT CERTAIN parcel of ]and zit*,~te in Dickinson Township~ Curnhcrland County, Pennsylvania, bounded a~l ¢~escrihcd as BEGINNING at an iron pin at corner of property of Roborc C, Peters, Jr. and in linc of land now or formerly of Prancis C. Bucber; thence along innd~ flow Or foIl'oeriy o~ P~obe~ C. Peters, Jr. Sol,th 75° 00' O0' West 581.50 feet to an ~ pin to be set in concrete; th~agc along thc dividing line I~twee~ Lo~ No, 2 and Lot No. 3 on thc h~&mfu:r m~Z~ncd subdivi~'ion plan N0rlh 7" 53' 39~ West 419.20 f~t to an iron pm s~ in concrete; thence along o~her lands now or formerly of Ray K. Jumpvr Noxtl~ 63° 52' 49' East 482.10 feet to an iron pin; thance along lands now or formerly of Pnmgis C. Bather South 32° 17' 49" East 523,~ East lo an iron pin, the point and place of {Tg~tnni~lg. TITLE TO SAID PREMISES IS; VF:~TED IN Rohctt C. Peters, Jr. nnd Dian~ L. Peters, his wife by Deed from Ruy K. Jumper datect 5/2fl995 ami recorded $/3/1995, in Record Book 121 Page 763. TAX PARCEL ~t31-09-0521-003 WRIT OF EXECUTION and/or ATTACHMENT COMMONWEALTH OF PENNSYLVANIA) NO 03-3963 Civil COUNTY OF CUMBERLAND) CIVIL ACTION - LAW TO THE SHERIFF OF CUMBERLAND COUNTY: To satisfy the debt, interest and costs due GMAC MORTGAGE CORPORATION, Plaintiff (s) From ROBERT C. PETERS, JR. AND DIANA L. PETERS (1) You are directed to lew upon the property of the defendant (s)and to sell SEE LEGAL DESCRIPTION. (2) You are also directed m 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 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 him/her that he/she has been added as a garnishee and is enjoined as above stated. Amount Due $113,285.49 L.L. $.50 Imerest FROM 9/24/03 TO 3/3/04 (PER DIEM - $18.62) - $2,997.82 AND COSTS Atty's Comm % Due Prothy $1.00 AttyPaid $131.52 Other Costs Plaintiff Paid Date: SEPTEMBER 29, 2003 (Seal) CURTIS R. LONG Prothonotary Deputy REQUESTING PARTY: Name FRANK FEDERMAN, ESQUIRE Address: ONE PENN CENTER AT SUBURBAN STATION 1617 JOHN F. KENNEDY BOULEVARD, SUITE 1400 PHILADELPHIA, PA 19103-1814 Attorney for: PLAINTIFF Telephone: 215-563-7000 Supreme Court ID No. 12248 FEDERMAN and PHELAN, LLP By: FRANK FEDERMAN Identification No. 12248 ONE PENN CENTER AT SUBURBAN STATION 1617 JOHiN F. KENNEDY BLVD., SUITE 1400 pII:IILADELPHIA, PA 19103-1814 (215) 563-7000 GMAC MORTGAGE CORPORATION 500 ENTERPRISE ROAD, SUITE 500 Plaintiff, ROBERT C. PETERS, JR. DIANA L. PETERS Defendant(s). ATTORNEY FOR PLAINTIFF CUMBERLAND COUNTY COURT OF COMMON PLEAS CIVIL DIVISION NO. 03-3963 CIVIL TERM VERIFICATION OF NON-MILITARY SERVICE FRANK FEDERMAN, ESQUIRE, hereby verifies that he is attomey 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 ROBERT C. PETERS, JR. is over 18 years of age and resides at 733 MOUNTAIN ROCK ROAD, CARLISLE, PA 17013-942. (c) that defendant DIANA L. PETERS is over 18 years of age, and resides at 733 MOUNTAIN ROCK ROAD, CARLISLE, PA '170'13-942. This statement is made subject to the penalties of 18 Pa. C.S. Section 4904 relating to unswom falsification to authorities. FRANK FEDERMAN, ESQUIRE Attorney for Plaintiff FEDERMAN and PHELAN, LLP By: FRANK FEDERMAN Identification No. 12248 ONE PENN CENTER AT SUBURBAN STATION 1617 JOHN F. KENNEDY BLVD., SUITE 1400 PHILADELPI~A, PA 19103-1814 (21 ) -7ooo GMAC MORTGAGE CORPORATION Plaintiff, V. ROBERT C. PETERS, JR. DIANA L. PETERS Defendant(s). ATTORNEY FOR PLAINTIFF CUMBERLAND COUNTY COURT OF COMMON PLEAS CIVIL DIVISION NO. 03-3963 CIVIL TERM 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. FRANK FEDERMAN, ESQUIRE Attorney for Plaintiff GMAC MORTGAGE CORPORATION Plaintiff, ROBERT C. PETERS, JR. DIANA L. PETERS Defendant(s). CUMBERLAND COUNTY COURT OF COMMON PLEAS CIVIL DMSION NO. 03-3963 CIVIL TERM 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,733 MOUNTAIN ROCK ROAD, CARLISLE, PA 17013-942. 1. Name and address of Owner(s) or reputed Owner(s): Name Last Known Address (if address cannot be reasonably ascertained, please indicate) ROBERT C. PETERS, JR. 733 MOUNTAIN ROCK ROAD CARLISLE, PA 17013-942 DIANA L. PETERS 733 MOUNTAIN ROCK ROAD CARLISLE, PA 17013 2. Name and address of Defendant(s) in the judgment: Same as above 3. Name and last known address of every judgment creditor whose judgment is a record lien on the real property to be sold: maine None Last Known Address (if address cannot be reasonably ascertained, please indicate) 4. Name and address of last recorded holder of every mortgage of record: Name Last Known Address (if address cannot be reasonably ascertained, please indicate) None 5. Name and address of every other person who has any record lien on the property: marne Last Known Address (if address cannot be reasonably ascertained, please 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. Nalne Last Known Address (if address cannot be reasonably ascertained, please indicate) 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: manic Last Known Address (if address cannot be reasonably ascertained, please indicate) Tenant/Occupant 733 MOUNTAIN ROCK ROAD CARLISLE, PA 17013-942 Domestic Relations of Cumberland County 13 North Hanover Street Carlisle, PA 17013 Commonwealth of Pennsylvania Department of Welfare PO Box 2675 Harrisburg, PA 17105 I verify that the statements made in this affidavit are true and correct to the best of my personal knowledge or information and belief. I understand that false statements herein are made subject to the penalties of 18 Pa. C.S. Sec. 4904 relating to unsworn falsification to authorities. September 25, 2003 DATE FRANK FEDERMAN, ESQUIRE Attorney for Plaintiff GMAC MORTGAGE CORPORATION Plaintiff, ROBERT C. PETERS, JR. DIANA L PETERS Defendant(s). TO: ROBERT C. PETERS, JR. 733 MOUNTAIN ROCK ROAD CARLISLE, PA 17013-942 CUMBERLAND COUNTY No. 03-3963 CIVIL TERM September 25, 2003 DIANA L. PETERS 733 MOUNTAIN ROCK ROAD CARLISLE, PA 17013-942 **THIS FIRM IS A DEBT COLLECTOR ATTEMPTING TO COLLECT A DEBTAND ANY INFORMATION OBTAINED WILL BE USED FOR THAT PURPOSE. IF YOU HA VE PREVIOUSLY RECEIVED A DISCHARGE IN BANKRUPTCYAND THIS DEBT WAS NOTREAFFIRMED, THIS IS NOT,4ND SHOULD NOT BE CONSTRUED TO BE ANATTEMPT TO COLLECTA DEBT, BUT ONLYENFORCEMENT OF A LIENAGAINST PROPERTY ** Your house (real estate) at, 733 MOUNTAIN ROCK ROAD, CARLISLE, PA 17013-942, is scheduled to be sold at the Sheriffs Sale on MARCH 3, 2004 at 10:00 a.m. in the Cumberland County Courthouse, South Hanover Street, Carlisle, PA 17013, to enforce the court judgment of $113,285,49 obtained by GMAC MORTGAGE CORPORATION (the mortgagee) against you. In the event the sale is continued, an announcement will be made at said sale in compliance with Pa.R.C.P., Rule 3129.3. 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: t 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. 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 fights. 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 Sherifl} you will remain the owner of the property as if the sale never happened. 5. You have the fight to remain in the property until the full amount due is paid to the Sher/ff 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 fights 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 ALL THAT CERTAIN [~rc¢! of land situate in DickinsOn Tnwnsl~ip, Cumbcflaod County, Pcnnsy~vania~ bounded and describcd as follows: EIEGINNING at an i[on pin at comer of property of Robert C. Peters, Jr. and in fine of land now or form~ly of Fcanc~ C. Bucher; rlrenc¢ along hinds now or formedy of Robert C. Peters, Jr. $ouff, 75° 00' 00' West 581.50 feet to an iron pin to be set in concr~e; ~thencc along tl~c dividing li~ between Lot No. 2 and Lot No. 3 on the hereinafter n~mlinned subdivision plan Nollh 7~ 53' 39" Wes~ 419.20 f~et to an iron pin set in cancmm: tlteacc along o~et lands now or formerly of Ray K. Jumper Nor~ 63e 52~ 49' East 482.10 feet to an iron pin; thence along lancln now or x~ormerly of Francis C. Bocher South 32~ 17' 49' East 523.66 East Io an iron pin, the point and place of begianing. TITi, E TO SAID PREMISES 1S VESTED IN Robert C. Peterm, Jr. aud Diana L. Peters, his wife by Deed from Ray K. Jumper dated 5/2/1995 and recorded 51311995, in Record I~k 12! Page 763. TAX PARCEL PL~AINTIFF DEFENDANT(S) AFFIDAVIT OF SERVICE GMAC MORTGAGE CORPORATION ROBERT C. PETERS, JR. DIANA L PETERS CUMBERLAND COUNTY No. 03-3963 CIVIL TERM ACCT. ~1.98284801 PJT SERVE DIANA L. PETERS AT 733 MOUNT~OCK ROAD CARLISLE, PA 17013-942 Type of Action - Notice of Sheriff's Sale Sale Date: MARCH 3, 2004 Served and made known to SERVED c~day of ~--~k~ , Comrtmnwealth of Pennsylvania, in the manner described below: ~ Defendant personally served. __ Adult family member with whom Defendant(s) reside(s). Relationship is __ 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/~ Height~2'r', Weight/33- Race~~x Sex /r~ Other I, Q ['3'6-~1'~¢~ k, ~h~'-~'/,~,a competent adult, being duly sworn according to law, depose and state that I personally handed a tree and c6rrect copy of the Notice of Shariff's Sale in the,r ...... on the date and at the address ind~ ! ~ gl~ ~n'u ~~,l~il~t I~ll~ captioned case Sworn to and subserved befor~ rile this _~_ day of ':2oo 7 A/C) t PLEASE ATTEMPT SERVICE AT LE~ST-3 TIMES. INDICATE I~,F~& TIMES OF SERVICE ATTEMPTED. NOT SERVED On the day of ,200__, at __ o'clock __.m, Defendant NOT FOUND because: Moved Unknown No Answer Vacant 1st Attempt: / / Time: : 2nd Attempt: / / Time: 3rd Attempt:. / / Time: : Sworn to and subscribed before me this __ day of ,200 _. Notary: By: Attorney for Plaintiff Frank Federman, Esquire - I.D. No. 12248 PLA/NT1FF DEFENDANT(S) AFFIDAVIT OF SERVICE GMAC MORTGAGE CORPORATION ROBERT C. PETERS, JR. DIANA L. PETERS CUMBERLAND COUNTY PJT No. 03-3963 CIVIL TERM ACCT. #498284801 SERVE ROBERT C. PETERS, JR. AT 733 MOUNT~II~ROCK ROAD CARLISLE, PA 17013-942 Type of Action - Notice of Sheriff's Sale Sale Date: MARCH 3, 2004 SERVED at 711~ ,o'clockg. m.,atT.~_~ /~0~3~'- ~¢ ~X~t/j of Pennsylvania, in the manner described below: day of (~ ~'0 ~Oe u' , 200_3 , Commonwealth __ Defendant personally served. ~ Adult family member with whom Defnndant(s) reside(s). Relationship is ~x):~ .0~o~._ ~., ~,~%- Adult in charge of Defendant(s)'s residence who refused to give name or relations]ti~. ~ Manager/Clerk of place of lodging in which Defendant(s) reside(s). Agent or person in charge of Defendnnt(s)'s office or usual place of business. an officer of said Defendant(s)'s company. Other: Description:. Age/7~ Height ~/~." Weight /.~- Race ~0~Sex ~ Other 16~o*,~[~ ~0;~ i,C {~f'¢e [x: E ~, C*g. ~ ~,va competent adult, being duly sworn according to law, depose and state that I personally handed a true and correct copy of the Notice of Sherifffs Sale in the manner as set forth hereby, i ~sued in the cantinned case on the dato ~nd at the address indicated above. Sworn to and subscribed I before 's day ~'9., ~ G01g~ Notary. ~ ')~. By~ . EASE ATTEMPT SERVICE AT LEAST 3 TIMES. II~)IC~¥E D~ ~' TIMES OF SERVICE ATTEMPTED. NOT SERVED On the day of ., 200__, at __ __ Moved __ Unknown__ No Answer 1st Attempt: / / Time: : o'clock _.m, Defendant NOT FOUND because: Vacant 2~a Attempt:. / / Time: 3rd Attempt:. / / Time: : Sworn to and subscribed before me this day of ,200 _. Notary: By: Attorney for Plaintiff Frank Federman, Esquire - I.D. No. 12248 IN THE COURT OF COMMON PLEAS OF CUMBERLAND COUNTY, PENNSYLVANIA GMAC MORTGAGE CORPORATION VS. ROBERT C. PETERS, JR. DIANA L. PETERS CIVIL ACTION CIVIL DIVISION NO. 03-3963 CIVIL TERM AFFIDAVIT OF SERVICE PURSUANT TO RULE 3129 COMMONWEALTH OF PENNSYLVANIA ) COUNTY OF CUMBERLAND ) SS: I, FRANK FEDERMAN, ESQUIRE attorney for GMAC MORTGAGE CORPORATION hereby verify that on January 2L 2004 tree and correct copies of the Notice of Sheriff's sale were served by certificate of mailing to the recorded lienholders, and any known interested party see Exhibit "A" attached hereto. DATE: February 5, 2004 FRANK FEDERMAN, ESQUIRE Attorney for Plaintiff FEDERMAN AND PHELAN, L.L.P. One Penn Center at Suburban Station 1617 John F. Kennedy Boulevard Suite 1400 Philadelphia, PA 19103-1814 215-563-7000 Main Fax 215-563-5534 February 5, 2004 Office of the Prothonotary CUMBERLAND County Courthouse GMAC MORTGAGE CORPORATION v. ROBERT C. PETERS, JR. DIANA L. PETERS CUMBERLAND County, No. 03-3963 CIVIL TERM Dear Sir, Please file thc enclosed AMENDED affidavit(s) in reference to the above captioned matter(s). Kindly return the attorney copy(s) in the self addressed stamped envelope that has been provided for your convenience. Thank you for your cooperation. Yours truly, Rach~el~. Allmond for Federman and Phelan CC: Sheriff's Office of CUMBERLAND County GMAC MORTGAGE CORPORATION Plaintiff, Vo ROBERT C. PETERS, JR. DIANA L. PETERS Defendant(s). CUMBERLAND COUNTY COURT OF COMMON PLEAS CIVIL DIVISION NO. 02-5392 AMENDED 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 Praeeipe for the Writ of Execution was filed the following information concerning the real property located at ~733 MOUNT ROCK ROAD~ CARLISLE~ PA 17013 . 1. Name and address of Owner(s) or reputed Owner(s): Name Last Known Address (if address cannot be reasonably ascertained, please indicate) ROBERT C. PETERS, JR. 733 MOUNT ROCK ROAD CARLISLE, PA 17013 DIANA L. PETERS 733 MOUNT ROCK ROAD CARLISLE, PA 17013 2. Name and address of Defendant(s) in the judgment: Same as above 3. Name and last known address of every judgment creditor whose judgment is a record lien on the real property to be sold: Nanle Last Known Address (if address cannot be reasonably ascertained, please indicate) None 4. Name and address of last recorded holder of every mortgage of record: Last Known Address (if address cannot be reasonably ascertained, please indicate) None 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 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. NaiTle Last Known Address (if address cannot be reasonably ascertained, please indicate) 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: NR1Tie Last Known Address (if address cannot be reasonably ascertained, please indicate) Tenant/Occupant 733 MOUNT ROCK ROAD CARLISLE, PA 17013 Domestic Relations of Cumberland County 13 North Hanover Street Carlisle, PA 17013 Commonwealth of Pennsylvania Department of Welfare PO Box 2675 Harrisburg, PA 17105 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. February 5, 2004 DATE FRANK FEDERMAN, ESQUIRE Attorney for Plaintiff GMAC Mortgage Corporation VS Robert C. Peters, Jr. and Diana L. Peters In The Court of Common Pleas of Cumberland County, Pennsylvania Writ No. 2003-3963 Civil Term R. Thomas Kline, Sheriff, who being duly sworn according to law, states this writ is returned STAYED pursuant to instructions from Attorney Frank Federman. Sheriff's Costs: Docketing 30.00 Poundage 2443.58 Advertising 15.00 Posting Handbills 15.00 Levy 15.00 Surcharge 30.00 Service 14.49 Law Journal 200.30 Patriot News 155.59 Law Library .50 Prothonotary 1.00 Share of Bills 29.32 $2949.78 paid by attorney 02/24/04 This ,~J~ day of ~  Thomas Kline, Sheriff 2004, A.D. ~ ~ '~ BY Prothonotary Real E~fate Deputy THE PATRIOT NEWS THE SUNDAY PATRIOT NEWS Proof of Publication UnderAct No. 587, Approved May 16, 1929 Commonwealth of Pennsylvania, County of Dauphin} ss Michael Morrow, being duly sworn according to law, deposes and says: That he is the Controller of The Patriot News Co., a corporation organized and existing under the laws of the Commonwealth of Pennsylvania, with its principal office and place of business at 812 to 818 Market Street, in the City of Harrisburg, County of Dauphin, State of Pennsylvania, owner and publisher of The Patriot-News and The Sunday Patriot-News newspapers of general circulation, printed and published at 812 to 818 Market Street, in the City, County and State aforesaid; that The Patriot-News and The Sunday Patriot-News were established March 4th, 1854, and September 18th, 1949, respectively, and all have been continuously published ever since; That the printed notice or publication which is securely attached hereto is exactly as printed and published in their regular daily and/or Sunday/ Metro editions which appeared on the 20th and 27th day(s) of January and the 3rd day(s) of February 2004. That neither he nor said Company is interested in the subject matter of said printed notice or advertising, and that all of the allegations of this statement as to the time, place and character of publication are true; and That he has personal knowledge of the facts aforesaid and is duly authorized and empowered to verify this statement on behalf of The Patriot-News Co. aforesaid by virtue and pursuant to a resolution unanimously passed and adopted severally by the stockholders and board of directors of the said Company and subsequently duly recorded in the office for the Recording of Deeds in and for said County of Dauphin~in Miscellaneous Book 'M", Volume 14, Page 317. ~~~'~' PUBLICATION ........................................... C O P Y Sworn to ~ ~lle,...tl~is 23rd day o,J/~ebru, afy 2004 A.D. REAL ESTA't'E 8AI'E f~' ~ ~ I~"~ 6XP~re~ J~e ~'' ~x'l~ ~ NO'~ARY PUBLIC My com ssion ~R~ C, ~ d~. ~ CUMBERED COU~ SHERIFFS O~ICE ~ ~ CUMBERED C~ ~U~SE A~.~ 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 Total $ 155.59 Publisher's Receipt for Advertising Cost publisher of The Patriot-News and The Sunday Patriot-News. newspapers of general receipt of the aforesaid notice and publication costs and certifies that the same have PROOF OF PUBLICATION OF NOTICE IN CUMBERLAND LAW JOURNAL (Under Act No. 587, approved May 16, 1929), P. L1784 STATE OF PENNSYLVANIA : COUNTY OF CUMBERLAND : SS. Lisa Marie Coyne, Esquire, Editor of the Cumberland Law Journal, of the County and State aforesaid, being duly sworn, according to law, deposes and says that the Cumberland Law Journal, a legal periodical published in the Borough of Carlisle in the County and State aforesaid, was established January 2, 1952, and designated by the local courts as the official legal periodical for the publication of ail legal notices, and has, since January 2, 1952, been regularly issued weekly in the said County, and that the printed notice or publication attached hereto is exactly the same as was printed in the regular editions and issues of the said Cumberland Law Journal on the following dates, viz: JANUARY 16, 23, 30, 2004 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 ail allegations in the foregoing statements as to time, place and character of publication are true. REAL ESTATE $ALE NO. 75 Writ No. 2003-3963 Civil GMAC Mortgage Corporation VS. Robert C. Peters Jr. and Diana L. Peters Atty: Frank Federman ALL THAT CERTAIN parcel of land situate in D~ckinson Township. Cum- berland County, Pennsylvania, bounded and described as follows: BEGINNING at an iron pin at comer of property of Robert C. Pe- ters, dr. and in line of land now or formerly of Francis C. Bucher: thence along lands now or formerly of Rob- ert C. Peters. dn South 75° 00' 00" West 581.50 feet to an a'on pin to be set in concrete: thence along the dividing line between Lot No. 2 and Lot No. 3 on the hereinafter men tioned subdivision plan North 7* 53' 39" West 419.20 feet to an iron pin set in concrete; thence along other lands now or formerly of Ray K. Jumper North 63* 52' 49" East 482.10 feet to an iron pin; thence along lands now or formerly of Francis C. Bucher South 32° 17' 49" East 52.3.66 East to an iron pin, the point and place of beginning. TITLE TO SAID PREMISES IS ~D IN Robert C. Peters. Jn and Diana L. Peters. his wife by Deed from Ray Ft. Jumper dated 5/2/1995 and recorded 5/3/1995, In Record Book 121 Page 763. TAX PARCEL #31 09 0521-003. f/isa Marie Coy~e, Editor SWORN TO AND SUBSCRIBED before me this 30 day of JANUARY 2004_ LOIS E. SNYDEFI, Notary Public C~lsle Bom, Cumbedand County My Commission Expires Mmh 5, 2005 err C. Peters, dr. South law uu u~ West 581.50 feet to an iron pin to be set in concrete; thence along the dividing lirie between Lot No. 2 and Lot No. 3 on the hereinafter men- tioned subdivision plan North 7° 53' 39" West 419.20 feet to an iron pin set in concrete; thence along other lands now or formerly of Ray K. Jumper North 63° 52' 49" East 482.10 feet to an Iron pin; thence along lands now or formerly of Francis C. I3ucher South 32° 17' 49" East 523.66 East to an iron pin, the point and place of begimxing. TITLE TO SAID PREMISES IS VESTED IN Robert C. Peters. Jr. and Diana L. Peters. his wife by Deed from Ray PL Jumper dated 5/2/1995 and recorded 5/3/1995, in Record Book 121 Page 763. TAX pARCEL #31-09-0521 003.