HomeMy WebLinkAbout07-5431PHELAN HALLINAN & SCHMIEG, LLP
LAWRENCE T. PHELAN, ESQ., Id. No. 32227
FRANCIS S. HALLINAN, ESQ., Id. No. 62695
DANIEL G. SCHMIEG, ESQ., Id. No. 62205
ONE PENN CENTER PLAZA, SUITE 1400
PHILADELPHIA, PA 19103
X215) 563-7000 160768
GMAC MORTGAGE, LLC
1100 VIRGINIA DRIVE
P.O. BOX 8300
FORT WASHINGTON, PA 19034
v.
Plaintiff
GEORGE A. WELSH
A/K/A GEORGE A. WELSH, JR.
2 BRIGHTON LANE
CAMP HILL, PA 17011
Defendant
ATTORNEY FOR PLAINTIFF
COURT OF COMMON PLEAS
CIVIL DIVISION
TERM
NO. D'~ - 5/31 1/~v11 Tcx~
CUMBERLAND COUNTY
CIVIL ACTION -LAW
COMPLAINT IN MORTGAGE FORECLOSURE
File #: 160768
NOTICE
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 aze
served, by entering a written appeazance personally or by attorney and filing in writing with the
court your defenses or objections to the claims set forth against you. You aze warned that if you
fail to do so the case may proceed without you and a judgment may be entered against you by the
court without further notice for any money claimed in the complaint or for any other claim or
relief requested by the plaintiff. You may lose money or property or other rights important to
you.
YOU SHOULD TAKE THIS PAPER TO YOUR LAWYER AT ONCE. IF YOU DO
NOT HAVE A LAWYER, 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.
Lawyer Referral Service
Cumberland County Bar Association
32 South Bedford Street
Cazlisle, PA 17013
(800)990-9108
File #: 160768
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
File q: 160768
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.
IF YOU HAVE FILED BANKRUPTCY AND RECEIVED A
DISCHARGE, THIS IS NOT AN ATTEMPT TO COLLECT
A DEBT. IT IS AN ACTION TO ENFORCE A LIEN ON
REAL ESTATE.
File #: 160768
1. Plaintiff is
GMAC MORTGAGE, LLC
1100 VIRGINIA DRIVE
P.O. BOX 8300
FORT WASHINGTON, PA 19034
2. The name(s) and last known address(es) of the Defendant(s) aze:
GEORGE A. WELSH
A/K/A GEORGE A. WELSH, JR.
2 BRIGHTON LANE
CAMP HILL, PA 17011
who is/aze the mortgagor(s) and/or real owner(s) of the property hereinafter described.
3. On 06/15/2006 mortgagor(s) made, executed, and delivered a mortgage upon the
premises hereinafter described to MORTGAGE ELECTRONIC REGISTRATION
SYSTEMS, INC. AS A NOMINEE FOR QUICKEN LOAN, INC. which mortgage is
recorded in the Office of the Recorder of CUMBERLAND County, in Book: 1955, Page:
72. PLAINTIFF is now the legal owner of the mortgage and is in the process of
formalizing an assignment of same. The mortgage and assignment(s), if any, aze matters
of public record and are incorporated herein by reference in accordance with Pa.R.C.P.
1019(g); which Rule relieves the Plaintiff from its obligations to attach documents to
pleadings if those documents aze of public record.
4. The premises subject to said mortgage is described as attached.
5. The mortgage is in default because monthly payments of principal and interest upon said
mortgage due 05/01/2007 and each month thereafter aze 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 #: 160768
6.
The following amounts aze due on the mortgage:
Principal Balance $199,000.00
Interest $5,252.92
04/01/2007 through 09/11/2007
(Per Diem $32.03)
Attorney's Fees $1,250.00
Cumulative Late Chazges $194.84
06/15/2006 to 09/11/2007
Cost of Suit and Title Seazch 550.00
Subtotal $206,247.76
Escrow
Credit $0.00
Deficit $357.56
Subtotal 357.56
TOTAL $206,605.32
7
8
If the mortgage is reinstated prior to a Sheriffs Sale, the attorney's fee set forth above may
be less than the amount demanded based on work actually performed. The attorney's fees
requested aze in conformity with the mortgage and Pennsylvania law. Plaintiff reserves its
right to collect attorney's fees up to 5% of the remaining principal balance in the event the
property is sold to a third party purchaser at Sheriffs Sale, or if the complexity of the
action requires additional fees in excess of the amount demanded in the Action.
Plaintiff is not seeking a judgment of personal liability (or an in personam judgment)
against the Defendant(s) in the Action; however, Plaintiff reserves its right to bring a
sepazate Action to establish that right, if such right exists. If Defendant(s) has/have
received a dischazge of personal liability in a bankruptcy proceeding, this Action of
Mortgage Foreclosure is in no way an attempt to reestablish such personal liability
discharged in bankruptcy, but only to foreclose the mortgage and sell the mortgaged
premises pursuant to Pennsylvania Law.
File #: 160768
9. 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.
10. 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 $206,605.32, together with interest from 09/11!2007 at the rate of $32.03 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.
PHELA HALLINAN & SCI~MIEG, LLP
By: /s/Francis S. Hallinan
LAWRENCE T. PHELAN, ESQUIRE
DANIEL G. SCHMIEG, ESQUIRE
FRANCIS S. HALLINAN, ESQUIRE
Attorneys for Plaintiff
File #: 160768
LEGAL DESCRIPTION
ALL that certain lot or tract of land situate in East Pennsboro Township, Cumberland County,
Commonwealth of Pennsylvania, more particularly bounded and described as follows, to wit:
BEGINNING at a point on the northern right of way line of Windsor Way a fifty (50) foot wide
road, said point also being the southwest corner of Lot #2 as shown on the final subdivision plan
of Victoria Glen II; thence continuing along the northern right of way line of Windsor Way the
following two courses, along a curve to the right having a radius of four hundred fifteen and no
hundredths (415.00) feet, an arc length of forty three and sixty seven hundredths (43.67) feet,
said arc being subtended by a chord and bearing seventy four (74) degrees seventeen (17)
minutes twenty eight (28) seconds West a distance of forty three and sixty five hundredths
(43.65) feet to a point; thence continuing South seventy seven (77) degrees eighteen (18) minutes
twenty (20) seconds West a distance of thirty eight and seventy eight hundredths (38.78) feet to a
point, said point being the end of the radius at the northeast corner of the intersection of said
Windsor Way with Brighton Lane a fifty (50) foot wide road; thence continuing along the right
of way radius and along the eastern right of way of Brighton Lane the following two courses,
along a curve to the right, having a radius of fifteen and no hundredths (15.00) feet, an arc length
of twenty and ninety hundredths (20.90) feet, said arc being subtended by a chord and bearing of
North sixty two (62) degrees forty six (46) minutes thirty five (35) seconds West, a distance of
nineteen and twenty five hundredths (19.25) feet to a point; thence continuing North twenty two
(22) degrees fifty one (51) minutes thirty (30) seconds West a distance of one hundred eleven
and forty seven hundredths (111.47) feet to a point, said point being the southwest corner of Lot
#38 as shown on the final subdivision plan of Victoria Glen (Phase 1); thence continuing along
File #: 160768
the southern line of said Lot #38, and along a portion of the southern line of Lot #39 respectively
North seventy-two (72) degrees twenty eight (28) minutes twenty (20) seconds East, a distance
of one hundred three and sixty hundredths (103.60) feet to a point, said point being northwest
corner of the aforementioned Lot #2; thence continuing along the western line of Lot #2, South
eighteen (18) degrees forty-three (43) minutes twenty three (23) seconds East a distance of one
hundred twenty nine and twenty two hundredths (129.22) feet to a point, said point being the
point and place of BEGINNING.
Being Lot #1 as shown on a Final Subdivision Plan of Victoria Glen II recorded in Plan Book 55,
Page 57.
PROPERTY BEING: 2 BRIGHTON LANE
File #: 160768
VERIFICATION
FRANCIS S. HALLINAN, ESQUIRE hereby states that he is attorney for
Plaintiff in this matter, that Plaintiff is outside the jurisdiction of the court and/or the
verification could not be obtained within the time allowed for the filing of the pleading,
that he is authorized to make this verification pursuant to Pa.R.C.P. 1024 (c), and that
the statements made in the foregoing Civil Action in Mortgage Foreclosure aze based
upon information supplied by Plaintiff and are true and correct to the best of its
knowledge, information and belief. Furthermore, counsel intends to substitute a
verification from Plaintiff upon receipt.
The undersigned understands that this statement is made subject to the penalties
of 18 Pa.C.S. Sec. 4904 relating to unsworn falsifications to authorities.
Francis S. Hallinan, Esquire
Attorney for Plaintiff
DATE: G (( ~
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SHERIFF'S RETURN - REGULAR
CASE N0: 2007-05431 P
COMMONWEALTH OF PENNSYLVANIA:
COUNTY OF CUMBERLAND
GMAC MORTGAGE LLC
VS
WELSH GEORGE ET AL
MICHAEL BARRICK
Sheriff or Deputy Sheriff of
Cumberland County,Pennsylvania, who being duly sworn according to law,
says, the within COMPLAINT - MORT FORE was served upon
WELSH GEORGE A
the
DEFENDANT at 2048:00 HOURS, on the 20th day of September, 2007
at 2 BRIGHTON LANE
CAMP HILL, PA 17011 by handing to
GEORGE A WELSH A/K/A GEORGE A WELSH JR
a true and attested copy of COMPLAINT - MORT FORE together with
and at the same time directing His attention to the contents thereof.
Sheriff's Costs:
Docketing
Service
Affidavit
Surcharge a Ion
9! ~,~
Sworn and Subscibed to
before me this
So Answers:
18.00
14.40
.00 •
10.00 R. Thomas Kline
.oo
42.40 09/21/2007 --
PHELAN HALLINAN SCHMIEG
By: ~ ~
day D putt' Sheriff
of A.D.
'PHELAN HALLINAN &SCHMIEG, L.L.P.
By: DANIEL G. SCHMIEG
Identification No. 62205
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, LLC
1100 VIRGINIA DRIVE P.O. BOX 8300
FORT WASHINGTON, PA 19034
CUMBERLAND COUNTY
COURT OF COMMON PLEAS
Plaintiff,
v.
GEORGE A. WELSH A/K/A GEORGE WELSH,
JR.
2 BRIGHTON LANE
CAMP HILL, PA 17011
Defendant(s).
CIVIL DIVISION
NO. 07-5431-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 GEORGE A. WELSH
A/K/A GEORGE WELSH, JR. ,Defendant(s) for failure to file an Answer to Plaintiff s Complaint
within 20 days from service thereof and for Foreclosure and Sale of the mortgaged premises, and assess
Plaintiffs damages as follows:
As set forth in Complaint $206,605.32
Interest from 09/12/07 to 10/25/07 $ 1,409.32
TOTAL $ 208,014.64
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.
ANIEL G. SCHMIEG, ESQU
Attorney for Plaintiff
DAMAGES ARE HEREBY ASSESSED AS INDICATED. n
DATE: ~a/~ S ~ JC
O PROTHY n~3
160768
• PHELAN HALLINAN & SCHMIEG, LLP
By: Lawrence T. Phelan, Esq., Id. No. 32227 ATTORNEY FOR PLAINTIFF
Francis S. Hallman, Esq., Id. No. 62695
Daniel G. Schmieg, Esq., Id. No. 62205
Philadelphia, PA 19103
(215) 563-7000
GMAC MORTGAGE, LLC :COURT OF COMMON PLEAS
Plaintiff
CIVIL DIVISION
Vs.
CUMBERLAND COUNTY
GEORGE A. WELSH A/K/A GEORGE A. WELSH, JR.
Defendants : NO. 07-5431-CIVIL TERM
TO: GEORGE A. WELSH A/K/A GEORGE A. WELSH, JR.
2 BRIGHTON LANE
CAMP HILL, PA 17011
DATE OF NOTICE: OCTOBER 11.2007
THIS FIRM IS A DEBT COLLECTOR ATTEMPTING TO COLLECT A DEBT. THIS NOTICE IS SENT TO
YOU IN AN ATTEMPT TO COLLECT THE INDEBTEDNESS REFERRED TO HEREIN, AND ANY
INFORMATION OBTAINED FROM YOU WILL BE USED FOR THAT PURPOSE.IF YOU HAVE
PREVIOUSLY RECEIVED A DISCHARGE IN BANKRUPTCY, THIS CORRESPONDENCE IS NOT AND
SHOULD NOT BE CONSTRUED TO BE AN ATTEMPT TO COLLECT A DEBT, BUT ONLY AS
ENFORCEMENT OF LIEN AGAINST 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. lF 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, THI5 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
LAWYER REFERRAL SERVICE
CUMBERLAND COUNTY BAR ASSOCIATION
32 SOUTH BEDFORD STREET
CARLISLE, PA 17013
(800)990-9108
F NCIS S. HALL A ,ESQUIRE
Attorneys for Plaintiff
'PHELAN HALLINAN &SCHMIEG, L.L.P.
By: DANIEL G. SCHMIEG
Identification No. 62205
ONE PENN CENTER AT SUBURBAN STATION
1617 JOHN F. KENNEDY BLVD., SUITE 1400
PHILADELPHIA, PA 19103-1814
(215) 563-7000
GMAC MORTGAGE, LLC
1100 VIRGINIA DRIVE P.O. BOX 8300
Plaintiff,
v.
GEORGE A. WELSH A/K/A GEORGE WELSH,
JR.
Defendant(s).
ATTORNEY FOR PLAINTIFF
CUMBERLAND COUNTY
COURT OF COMMON PLEAS
CIVIL DIVISION
N0.07-5431-CIVIL TERM
VERIFICATION OF NON-MILITARY SERVICE
DANIEL G. SCHMIEG, ESQUIRE, hereby verifies that he is attorney for the Plaintiff in
the above-captioned matter, and that on information and belief, he has knowledge of the following facts,
to wit:
(a) that the defendant(s) is/are not in the Military or Naval Service of the United States
or its Allies, or otherwise within the provisions of the Soldiers' and Sailors' Civil Relief Act of Congress
of 194Q, as amended.
(b) that defendant GEORGE A. WELSH A/K/A GEORGE WELSH, JR. is over 18
years of age and resides at , 2 BRIGHTON LANE, CAMP HILL, PA 17011 .
This statement is made subject to the penalties of 18 Pa. C.S. Section 4904 relating to
unsworn falsification to authorities.
Attorney for Plaintiff
` ~ ~HELAN HALLINAN &SCHMIEG, L.L.P.
By: DANIEL G. SCHMIEG
Identification No. 62205
ONE PENN CENTER AT SUBURBAN STATION
1617 JOHN F. KENNEDY BLVD., SUITE 1400
PHILADELPHIA, PA 19103-1814
(215 563-7000
GMAC MORTGAGE, LLC .
Plaintiff,
v. .
GEORGE A. WELSH A/K/A GEORGE WELSH,
JR. .
Defendant(s).
ATTORNEY FOR PLAINTIFF
CUMBERLAND COUNTY
COURT OF COMMON PLEAS
CIVIL DIVISION
NO. 07-5431-CIVIL TERM
CERTIFICATION
DANIEL G. SCHMIEG, 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:
Q 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 unsworn
falsification to authorities.
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A L G. SC I G, ESQU
Attorney for Plaintiff
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(Rule of Civil Procedure No. 236) -Revised
IN THE COURT OF COMMON PLEAS OF CUMBERLAND COUNTY, PENNSYLVANIA
CIVIL ACTION -LAW
GMAC MORTGAGE, LLC
1100 VIRGINIA DRIVE P.O. BOX 8300
CUMBERLAND COUNTY
COURT OF COMMON PLEAS
Plaintiff,
v.
GEORGE A. WELSH A/K/A GEORGE WELSH,
JR.
CIVIL DIVISION
NO. 07-5431-CIVIL TERM
Defendant(s).
Notice is given that a Judgment in the above-captioned matter has been entered against you on
(fit-. 30~` Zoos .
By:
x a~
If you have any questions concerning this matter, please contact:
1
PSANIEL G. SCHMIEG, ES
Attorney for Plaintiff
ONE PENN CENTER AT SUB AN STATION
1617 JOHN F. KENNEDY BLVD., SUITE 1400
PHILADELPHIA, PA 19103-1814
(215) 563-7000
**THIS FIRM IS A DEBT COLLECTOR ATTEMPTING TO COLLECT A DEBT AND ANY INFORMATION
OBTAINED WILL BE USED FOR THAT PURPOSE. IF YOU HAVE PREVIOUSLY RECEIVED A DISCHARGE IN
BANKRUPTCY AND THIS DEBT WAS NOT REAFFIRMED, THIS CORRESPONDENCE IS NOT AND SHOULD
NOT BE CONSTRUED TO BE AN ATTEMPT TO COLLECT A DEBT, BUT ONLY ENFORCEMENT OF A LIEN
AGAINST PROPERTY.**
r
PRAECIPE FOR WRIT OF EXECUTION - (MORTGAGE FORECLOSURE)
P.R.C.P.3180-3183
GMAC MORTGAGE, LLC
Plaintiff,
v.
No. 07-5431-CIVIL TERM
GEORGE A. WELSH A/K/A GEORGE WELSH,
JR.
Defendant(s).
TO THE DIRECTOR OF THE OFFICE OF THE PROTHONOTARY:
Issue writ of execution in the above matter:
Amount Due
$ 208,014.64
Interest from 10/26/07 - 03/05/08 $ 4,513.08 and Costs
(per diem -$34.1.9)
Add'1 Costs $ 1,978.50
TOTAL $214,506.22 1
n
~.KNIEL G. SCH1bIIEG, ESQUIRE
ne Penn Center at Suburban Station
1617 John F. Kennedy Boulevard, Suite 1
Philadelphia, PA 19103-1814
Attorney for Plaintiff
Note: Please attach description of property.No.
IMPORTANT NOTICE: This property is sold at the direction of the
plaintiff. It may not be sold in the absence of a representative of
the plaintiff at the Sheriff's Sale. The sale must be postponed or
stayed in the event that a representative of the plaintiff is not
present at the sale.
160768
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DESCRIPTION
ALL that certain piece or parcel of land situated in the Township of
Fairview, County of Luzerne and Commonwealth of Pennsylvania, bounded and
described as follows:
BEGINNING at a point in the northerly side line of the fifty (50) foot
wide Diane Court, said point being in the dividing line between Lots 43
and 39 of the Park Terrace Subdivision Plot of Lots;
THENCE along: said road side line, North 83 degrees 45 minutes 00 second
West, 38.55 feet to a point in the cul-de-sac located at the westerly end
of said road;
THENCE along said cul-de-sac side line by the two (2) following described
lines:
1. By a curve to the right for an arc distance of 17.45 feet to a point,
said curve having a radius of 20.00 feet and a chord course and distance
of North 58 degrees 45 minutes 09 seconds West, 16.90 feet;
2. By a curve to the left for an arc distance of 75.16 feet to a point in
the dividing line between Lots 43 and 42 of said plot, said curve having a
radius of 50.00 feet and a chord course and distance of North 76 degrees
49 minutes 06 seconds West, 68.28 feet;
THENCE along the dividing line between said Lots 43 and 42, North 29
degrees 52 minutes 54 seconds West, 135 feet, more or less, to a point in
the centerline of a stormwater swale (known as 'Spring Run'), the same
being the dividing line between Lots 43 and 47 of said plot;
THENCE alonq~said dividing line and continuing along Lots 46 and 45 of
said plot in`a southerly and easterly direction or upstream direction, 203
feet, more or less, to a point in the dividing line between Lots 43 and 44
of said plot;
THENCE along said dividing line and continuing along the aforesaid Lot 39,
South 6 degrees 15 minutes 00 second West, 140 feet, more or less, to a
point, the place of beginning.
BEING the same premises conveyed to the Grantors herein by Deed from
Robert M. Bjornsti and Patricia H. Bjornsti, his wife, dated October 16,
1999 and recorded November 3, 1999 in Luzerne County Deed Book 2699, page
1001. ALL that certain piece or parcel of land situated in the Township of
Fairview, County of Luzerne and Commonwealth of Pennsylvania, bounded and
described as follows:
BEGINNING at a point in the northerly side line of the fifty (50) foot
wide Diane Court, said point being in the dividing line between Lots 43
and 39 of the Park Terrace Subdivision Plot of Lots;
THENCE alonq.;said road side line, North 83 degrees 45 minutes 00 second
West, 38.55 feet to a point in the cul-de-sac located at the westerly end
of said road;
THENCE along;said cul-de-sac side line by the two (2) following described
lines:
1. By a curve to the right for an arc distance of 17.45 feet to a point,
said curve having a radius of 20.00 feet and a chord course and distance
of North 58 degrees 45 minutes 09 seconds West, 16.90 feet;
2. By a curve to the left for an arc distance of 75.16 feet to a point in
the dividing line between Lots 43 and 42 of said plot, said curve having a
ATTACHED TO AND FORMING A PART OF RECORD OWNER AND LIEN CERTIFICATE
.- ~ ~` Order Number:LTS62954
Client:
Client Number: 160768
radius of 50.00 feet and a chord course and distance of North 76 degrees
49 minutes 06 seconds West, 68.28 feet;
THENCE along the dividing line between said Lots 43 and 42, North 29
degrees 52 minutes 54 seconds West, 135 feet, more or less, to a point in
the centerline of a stormwater swale (known as 'Spring Run'), the same
being the dividing line between Lots 43 and 47 of said plot;
THENCE along said dividing line and continuing along Lots 46 and 45 of
said plot in a southerly and easterly direction or upstream direction, 203
feet, more or less, to a point in the dividing line between Lots 43 and 44
of said plot;
THENCE along said dividing line and continuing along the aforesaid Lot 39,
South 6 degrees 15 minutes 00 second West, 140 feet, more or less, to a
point, the place of beginning.
BEING the same premises conveyed to the Grantors herein by Deed from
Robert M. Bjornsti and Patricia H. Bjornsti, his wife, dated October 16,
1999 and recorded November 3, 1999 in Luzerne County Deed Book 2699, page
1001.
PARCEL IDENTIFICATION NO: 09-18-1304-173, CONTROL #:09005193
Premises: 2 Brighton Lane, Pennsboro Township, PA 17011
East Pennsboro Township
Cumberland County
Pennsylvania
TITLE TO SAID PREMISES IS VESTED IN George A. Welsh, adult individual, by Deed from
Russell A. Dzielak and Angela K. Dzielak, his wife, dated 0611412006, recorded 06/16/2006, in Deed
Book 275, page 838.
GMAC MORTGAGE, LLC .
Plaintiff, ;
v. .
GEORGE A. WELSH A/KiA GEORGE WELSH,
JR. .
Defendant(s).
CUMBERLAND COUNTY
COURT OF COMMON PLEAS
CIVIL DIVISION
N0.07-5431-CIVIL TERM
AFFIDAVIT PURSUANT TO RULE 3129
(Affidavit No. l)
GMAC MORTGAGE. LLC , Plaintiff in the above action, by its attorney, DANIEL G. SCHMIEG,
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 ,2 BRIGHTON LANE, CAMP HILL, PA 17011
17011 .
1. Name and address of Owner(s) or reputed Owner(s):
Name
Last Known Address (if address cannot be
reasonably ascertained, please indicate)
GEORGE A. WELSH A/K/A GEORGE
WELSH, JR.
2 BRIGHTON LANE
CAMP HILL, PA 17011
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
properly to be sold:
Name
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:
Name
Last Known Address (if address cannot be
reasonably ascertained, please indicate)
MERS AS A NOMINEE FOR
QUICKEN LOAN, INC.
MERS AS A NOMINEE FOR
QUICKEN LOAN, INC.
P.O. BOX 2026
FLINT, MI 48501-2026
20555 VICTOR PARKWAY
LIVONIA, MI 48152
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.
Name
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:
Name
Last Known Address (if address cannot be
reasonably ascertained, please indicate)
TenantlOccupant
Domestic Relations of Cumberland County
Commonwealth of Pennsylvania
Department of Welfare
2 BRIGHTON LANE
CAMP HILL, PA 17011 17011
13 North Hanover Street
Carlisle, PA 17013
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.
October 25.2007 ~ L
DATE ANIEL G. S IEG, ESQ
Attorney for Plaintiff
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GMAC MORTGAGE, LLC
Plaintiff,
v.
GEORGE A. WELSH A/K/A GEORGE WELSH,
JR.
Defendant(s).
CUMBERLAND COUNTY
No. 07-5431-CIVIL TERM
October 25, 2007
TO: GEORGE A. WELSH A/K/A
GEORGE WELSH, JR.
2 BRIGHTON LANE
CAMP HILL, PA 17011
* *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
BANKRUPTCYAND THIS DEBT WAS NOT REAFFIRMED, THIS IS NOT AND SHDULD NOT BE CONSTRUED TO BE
AN ATTEMPT TO COLLECT A DEBT, BUT ONLY ENFORCEMENT OF A LIEN AGAINST PROPERTY.
Your house (real estate) at i2 BRIGHTON LANE, CAMP HILL, PA 17011 17011, is
scheduled to be sold at the Sheriffs Sale on MARCH 5.2008 at 10:00 a.m. in the Cumberland County
Courthouse, South Hanover Street, Carlisle, PA 17013, to enforce the court judgment of $ 208.014.64
obtained by GMAC MORTGAGE. LLC (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 MAYBE ABLE TO PREVENT THIS SHERIFF'S SALE
To prevent this Sheriff s Sale, you must take immediate action:
1. The sale will be cancelled if you pay to the mortgagee the back payments, late charges,
costs and reasonable attorney's fees due. To find out how much you must pay, you may
call: (215) 563-7000.
2. You may be able to stop the sale by filing a petition asking the Court to strike or open the
judgment, if the judgment was improperly entered. You may also ask the Court to
postpone the sale for good cause.
3. You may also be able to stop the sale through other legal proceedings.
You may need an attorney to assert your rights. The sooner you contact one, the more chance
you will have of stopping the sale. (See notice on page two on how to obtain an attorney.)
_YOU MAY STILL BE ABLE TO SAVE YOUR PROPERTY AND YOU HAVE OTHER
RIGHTS EVEN IF THE SHERIFF'S SALE DOES TAKE PLACE.
1. If the Sheriff s Sale is not stopped, your property will be sold to the highest bidder. You may
find out the price bid by calling (215) 563-7000.
2. You may be able to petition the Court to set aside the sale if the bid price was grossly
inadequate compared to the value of your property.
3. The sale will go through only if the buyer pays the Sheriff the full amount due in the sale. To
find out if this has happened, you may call (717) 240-6390.
4. If the amount due from the Buyer is not paid to the Sheriff, you will remain the owner of the
property as if the sale never happened.
5. You have the right to remain in the property until the full amount due is paid to the Sheriff
and the Sheriff gives a deed to the buyer. At that time, the buyer may bring legal proceedings to evict
you.
6. You may be entitled to a share of the money which was paid for your house. A schedule of
distribution of the money bid for your house will be filed by the Sheriff within 30 days of the sale. This
schedule will state who will be receiving that money. The money will be paid out in accordance with
this schedule unless exceptions (reasons why the proposed distribution is wrong} are filed with the
Sheriff within ten (10) days after the distribution is filed.
7. You may also have other rights and defenses, or ways of getting your home back, if you act
immediately after the sale.
YOU SHOULD TAKE THIS PAPER TO YOUR LAWYER AT ONCE. IF YOU DO NOT HAVE
A LAWYER OR CANNOT AFFORD ONE, GO TO OR TELEPHONE THE OFFICE LISTED
BELOW TO FIND OUT WHERE YOU CAN GET LEGAL HELP.
IMPORTANT NOTICE: This property is sold at the direction of the plaintiff. It may not be so{d
in the absence of a representative of the plaintiff at the Sheriff s Sale. The sale must be
postponed or stayed in the event that a representative of the plaintiff is not present at the safe.
CUMBERLAND COUNTY ATTORNEY REFERRAL
CUMBERLAND COUNTY BAR ASSOCIATION
2 LIBERTY AVENUE
CUMBERLAND COUNTY COURTHOUSE
CARLISLE, PA 17013
(?17) 249-3166
(800) 990-9108
DESCRIPTION
ALL that certain piece or parcel of land situated in the Township of
Fairview, County of Luzerne and Commonwealth of Pennsylvania, bounded and
described as follows:
BEGINNING at a point in the northerly side line of the fifty (50) foot
wide Diane Court, said point being in the dividing line between Lots 43
and 39 of the Park Terrace Subdivision Plot of Lots;
THENCE along; said road side line, North 83 degrees 45 minutes 00 second
West, 38.55 feet to a point in the cul-de-sac located at the westerly end
of said road;
THENCE along said cul-de-sac side line by the two (2) following described
lines:
1. By a curve to the right for an arc distance of 17.45 feet to a point,
said curve having a radius of 20.00 feet and a chord course and distance
of North 58 degrees 45 minutes 09 seconds West, 16.90 feet;
2. By a curve to the left for an arc distance of 75.16 feet to a point in
the dividing line between Lots 43 and 42 of said plot, said curve having a
radius of 50.00 feet and a chord course and distance of North 76 degrees
49 minutes 06 seconds West, 68.28 feet;
THENCE along the dividing line between said Lots 43 and 42, North 29
degrees 52 minutes 54 seconds West, 135 feet, more or less, to a point in
the centerline of a stormwater swale (known as 'Spring Run'), the same
being the dividing line between Lots 43 and 47 of said plot;
THENCE along?said dividing line and continuing along Lots 46 and 45 of
said plot in2a southerly and easterly direction or upstream direction, 203
feet, more or less, to a point in the dividing line between Lots 43 and 44
of said plot;
THENCE along said dividing line and continuing along the aforesaid Lot 39,
South 6 degrees 15 minutes 00 second West, 140 feet, more or less, to a
point, the place of beginning.
BEING the same premises conveyed to the Grantors herein by Deed from
Robert M. Bjornsti and Patricia H. Bjornsti, his wife, dated October 16,
1999 and recorded November 3, 1999 in Luzerne County Deed Book 2699, page
1001. ALL that certain piece or parcel of land situated in the Township of
Fairview, County of Luzerne and Commonwealth of Pennsylvania, bounded and
described as follows:
BEGINNING at a point in the northerly side line of the fifty (50) foot
wide Diane Court, said point being in the dividing line between Lots 43
and 39 of the Park Terrace Subdivision Plot of Lots;
THENCE along .,said road side line, North 83 degrees 45 minutes 00 second
West, 38.55 feet to a point in the cul-de-sac located at the westerly end
of said road;.
THENCE along ;said cul-de-sac side line by the two (2) following described
lines:
1. By a curve to the right for an arc distance of 17.45 feet to a point,
said curve having a radius of 20.00 feet and a chard course and distance
of North 58 degrees 45 minutes 09 seconds West, 16.90 feet;
2. By a curve to the left for an arc distance of 75.16 feet to a point in
the dividing line between Lots 43 and 42 of said plot, said curve having a
` ATTACHED TO AND FORMING A PART OF RECORD OWNER AND LIEN CERTIFICATE
Order Number:LTS62454
Client:
Client Number: 160768
radius of 50.00 feet and a chord course and distance of North 76 degrees
49 minutes 06 seconds West, 68.28 feet;
THENCE along the dividing line between said Lots 43 and 42, North 29
degrees 52 minutes 54 seconds West, 135 feet, more or less, to a point in
the centerline of a stormwater swale (known as 'Spring Run'), the same
being the dividing line between Lots 43 and 47 of said plot;
THENCE along said dividing line and continuing along Lots 46 and 45 of
said plot in a southerly and easterly direction or upstream direction, 203
feet, more or less, to a point in the dividing line between Lots 43 and 44
of said plot;
THENCE along, said dividing line and continuing along the aforesaid Lot 39,
South 6 degrees 15 minutes 00 second West, 140 feet, more or less, to a
point, the place of beginning.
BEING the same premises conveyed to the Grantors herein by Deed from
Robert M. Bjornsti and Patricia H. Bjornsti, his wife, dated October 16,
1999 and recorded November 3, 1999 in Luzerne County Deed Book 2699, page
1001.
PARCEL IDENTIFICATION NO: 09-18-1304-173, CONTROL #: 09005193
Premises: 2 Brighton Lane, Pennsboro Township, PA 17011
East Pennsboro Township
Cumberland County
Pennsylvania
TITLE TO SAII) PREMISES IS VESTED IN George A. Welsh, adult individual, by Deed from
Russell A. Dzielak and Angela K. Dzielak, his wife, dated 06/1412006, recorded Ob/1612006, in Deed
Book 275, page 838.
WRIT OF EXECUTION and/or ATTACHMENT
COMMONWEALTH OF PENNSYLVANIA) NO 07-5431 Civil
COUNTY OF CUMBERLAND) CIVIL ACTION -LAW
TO THE SHERIFF OF CUMBERLAND COUNTY:
To satisfy the debt, interest and costs due GMAC MORTGAGE, LLC, Plaintiff (s)
From GEORGE A. WELSH a/k/a GEORGE WELSH, JR.
(1) You are directed to levy upon the property of the defendant (s)and to sell SEE LEGAL
DESCRIPTION.
(2) You are also directed to attach the property of the defendant(s) not levied upon in the possession
of
GARNISHEE(S) as follows:
and to notify the garnishee(s) that: (a) an attachment has been issued; (b) the garnishee(s) is 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 $208,014.64 L.L.$.50
Interest from 10/26/07 to 3/05/08 (per diem - $34.19) - $4,513.08 and Costs
Atty's Comm % Due Prothy $2.00
Atty Paid $161.40 Other Costs $1,978.50
Plaintiff Paid
Date: 10/30/07
C is R. Long, Prothonota
(Seal) By; K,
Deputy
REQUESTING PARTY:
Name DANIEL G. SCHMIEG, ESQUIRE
Address: PHELAN HALLINAN &SCHMIEG, LLP
ONE PENN CENTER AT SUBURBAN STATION
1617 JOHN F KENNEDY BLVD, SUITE 1400
PHILADELPHIA, PA 19103-1814
Attorney for: PLAINTIFF
Telephone: 215-563-7000
Supreme Court ID No. 62205
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PHELAN HALLINAN & SCHMIEG, LLP
BY: DANIEL G. SCHMIEG, ESQUIRE
ATTORNEY LD. NO. 62205
ONE PENN CENTER AT SUBURBAN
STATION, SUITE 1400
PHILADELPHIA, PA 19103-1814
(215) 563-7000
GMAC MORTGAGE, LLC
v.
GEORGE A. WELSH
ATTORNEY FOR PLAINTIFF
COURT OF COMMON PLEAS
CIVIL DNISION
NO: 07-5431-CIVIL TERM
CUMBERLAND COUNTY
Praecipe to Substitute Legal Description
Attached to Writ of Execution
NUNC PRO TUNC
TO THE PROTHONOTARY:
Kindly substitute the attached legal description for the legal description originally
filed with the writ of execution in the instant matter.
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p~ANIEL G: SCHMIEG, ESQU
Attorney for Plaintiff
DATE:November 8, 2007
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DESCRIPTION
ALL THAT CERTAIN lot or tract of land situate in East Pennsboro
Township, Cumberland County, Pennsylvania, more particularly bounded
and described as follows, to wit:
BEGINNING at a point on the northern right of way line of Windsor Way,
a fifty (50) foot wide road, said point also being he southwest corner
of Lot #2 as shown on the final subdivision plan of Victoria Glen II;
thence continuing along the northern right of way line of Windsor Way
the following two courses, along a curve to the right having a radius
of four hundred fifteen and no hundredths (415.00) feet, an arc length
of forty three and sixty seven hundredths (43.67) feet, said arc being
subtended by a chord and bearing seventy four (74) degrees seventeen
(17) minutes twenty eight (28) seconds West a distance of forty three
and sixty five hundredths (43.65) feet to a point; thence continuing
South seventy seven degrees eighteen (18) minutes twenty (20) seconds
West a distance of thirty eight and seventy eight hundredths (38.78)
feet to a point, said point being the end of the radius at the
northeast corner of the intersection of said Windsor Way with Brighton
Lane a fifty (50) foot wide road; thence continuing along the right of
way radius and along the eastern right of way of Brighton Lane the
following two courses, along a curve to the right, having a radius of
fifteen and no hundredths (15.00) feet, an arc length of twenty and
ninety hundredths (20.90) feet, said arc being subtended by a chord and
bearing of North sixty two (62) degrees forty six (46) minutes thirty-
five (35) seconds West, a distance of nineteen and twenty-five
hundredths (19.25) feet to a point; thence continuing North twenty two
(22) degrees fifty one (51) minutes thirty (30) seconds West a distance
of one hundred eleven and forty seven hundredths (111.47) feet to a
point, said point being the southwest corner of Lot #38 as shown on the
final subdivision plan of Victoria Glen (Phase 1); thence continuing
along the southern line of said Lot #38, and along a portion of the
southern line of Lot #39 respectively North seventy-two (72) degrees
twenty eight (28) minutes twenty (20) seconds East, a distance of one
hundred three and sixty hundredths (103.60) feet to a point, said point
being northwest corner of the aforementioned Lot #2; thence continuing
along the western line of Lot #2, South eighteen (18) degrees forty-
three (43) minutes twenty three (23) seconds East a distance of one
hundred twenty nine and twenty two hundredths (129.22) feet to a point,
said point being the point and place of BEGINNING.
BEING Lot #1 as shown on a Final Subdivision Plan of Victoria Glen II
recorded in Plan Book 55, Page 57.
SAID lot containing twelve thousand five hundred fifty five and forty-
two hundredths (12,555.42) square feet or 0.28823 acres.
BEING the same premises which Edward V. Moyle an Sandra A. Moyle, his
wife, by deed dated July 18, 2001 and recorded in the Cumberland County
Recorder of Deeds Office in Book 24, Page 3439, granted and conveyed
unto Russell A. Dzielak and Angela K. Dzielak, his wife, Granters
herein.
TITLE TO SAID PREMISES IS VESTED IN: George A. Welsh, adult individual, by Deed from
Russell A. Dzielak and Angela K. Dzielak, his wife, dated 06/14/2006, recorded 06/16/2006, in
Deed Book 275, page 838.
PARCEL IDENTIFICATION NO: 09-18-1304-173, CONTROL #: 09005193
Premises: 2 Brighton Lane, Pennsboro Township, PA 17011
East Pennsboro Township, Cumberland County
Pennsylvania
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PHELAN HALLINAN &SCHMIEG
One Penn Center at Suburban Station
1617 John F. Kennedy Boulevard
Suite 1400
Philadelphia, PA 19103-1814
215-563-7000
Main Fax 215-563-3826
January 28, 2008
Office of the Sheriff
Cumberland County Courthouse
RE: GMAC MORTGAGE, LLC
V. GEORGE A. WELSH A/K/A GEORGE WELSH, JR.
CUMBERLAND COUNTY, NO. 07-5431-CIVIL TERM
RE: AFFIDAVIT OF SERVICE PURSUANT TO RULE 3129
Dear Sir/madam:
Enclosed please find the following:
XX Affidavit of service pursuant to rule 3129 with attachments.
Please find attached a copy of the original Affidavit of service pursuant to rule 3129,
which has been sent for filing with the CUMBERLAND COUNTY Prothonotary's Office as of
the date of this letter.
***Please be advised that in the event the Plaintiff is not represented at the sale the sale is
to be stayed or postponed.* *
Yours truly,
SQC
CHRISTINE SCHOFFLER
for PHELAN HALLIANAN &SCHMIEG
* * *PROPERTY IS LISTED FOR THE MARCH 5, 2008 SHERIFF'S SALE.*
SALE DATE: MARCH 5, 2008
IN THE COURT OF COMMON PLEAS OF CUMBERLAND COUNTY, PENNSYLVANIA
CIVIL ACTION -LAW
GMAC MORTGAGE, LLC
No.: 07-5431-CIVIL TERM
vs.
GEORGE A. WELSH A/K/A GEORGE
WELSH, JR.
AFFIDAVIT PURSUANT TO RULE 3129.1
AND RETURN OF SERVICE PURSUANT TO
Pa. R.C.P. 405 OF NOTICE OF SALE
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:
2 BRIGHTON LANE, CAMP HILL, PA 17011.
As required by Pa. R.C.P. 3129.2(a) Notice of Sale has been given in the manner
required by Pa. R.C.P. 3129.2(c) on each of the persons or parties named, at that address set forth
on the attached Affidavit No. 2 (previously filed) and Amended Affidavit No. 2 on the date
indicated, and a copy of the notice is attached as an Exhibit. A copy of the Certificate of Mailing
(Form 3817) andlor Certified Mail Return Receipt stamped by the U.S. Postal Service is attached
for each notice.
DANIEL SCHMIEG, ESQUI~
Attorney for Plaintiff
January 28, 2008
GMAC MORTGAGE, LLC
Plaintiff,
v.
GEORGE A. WELSH A/K/A GEORGE WELSH,
JR.
Defendant(s).
CUMBERLAND COUNTY
COURT OF COMMON PLEAS
CIVIL DIVISION
N0.07-5431-CIVIL TERM
Amended
AFFIDAVIT PURSUANT TO RULE 3129
(Affidavit No. l)
GMAC MORTGAGE, LLC ,Plaintiff in the above action, by its attorney, DANIEL G. SCHMIEG,
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 ,2 BRIGHTON LANE, CAMP HILL, PA 17011
17011 .
1. Name and address of Owner(s) or reputed Owner(s):
Name
Last Known Address (if address cannot be
reasonably ascertained, please indicate)
GEORGE A. WELSH A/K/A GEORGE
WELSH, JR.
2 BRIGHTON LANE
CAMP HILL, PA 17011
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:
Name
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:
Name
Last Known Address (if address cannot be
reasonably ascertained, please indicate)
MERS AS A NOMINEE FOR
QUICKEN LOAN, INC.
MERS AS A NOMINEE FOR
QUICKEN LOAN, INC.
P.O. BOX 2026
FLINT, MI 48501-2026
20555 VICTOR PARKWAY
LIVONIA, MI 48152
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.
Name
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:
Name
Last Known Address (if address cannot be
reasonably ascertained, please indicate)
Tenant/Occupant
Domestic Relations of Cumberland County
Commonwealth of Pennsylvania
Department of Welfare
MS. ROBBI LEMIRE
WILSHIRE CREDIT CORPORATION/
MERRILL LYNCH,
2 BRIGHTON LANE
CAMP HILL, PA 17011 17011
13 North Hanover Street
Carlisle, PA 17013
PO Box 2675
Harrisburg, PA 17105
14523 SW MILLIKAN WAY, SUITE 200,
BEAVERTON, OR 97005
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.
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January 28, 2008 ~ ~
DATE DANIEL G. CHMIEG, ESQUIRE
Attorney for Plaintiff
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GMAC Mortgage, LLC In the Court of Common Pleas of
VS Cumberland County, Pennsylvania
George A. Welsh a/k/a George Welsh, Jr. Writ No. 2007-5431 Civil Term
Kenneth Gossert, Deputy Sheriff, who being duly sworn according to law, states that on
December 06, 2007 at 1904 hours, he served a true copy of the within Real Estate Writ, Notice and
Description, in the above entitled action, upon the within named defendant, to wit: George A. Welsh
a/k/a George Welsh, Jr., by making known unto George Welsh, personally, at 2 Brighton Lane,
Camp Hill, Cumberland County, Pennsylvania its contents and at the same time handing to him
personally the said true and correct copy of the same.
Cpl. Timothy Reitz, Deputy Sheriff, who being duly sworn according to law, states that on
January 11, 2008 at 1018 hours, he posted a true copy of the within Real Estate Writ, Notice, Poster
and Description, in the above entitled action, upon the property of George W. Welsh a/k/a George
Welsh, Jr. located at 2 Brighton Lane, Camp Hill, Cumberland County, Pennsylvania according to
law.
R. Thomas Kline, Sheriff, who being duly sworn according to law, states he served the
above Real Estate Writ, Notice, Poster and Description in the following manner: The Sheriff A
mailed a notice of the pendency of the action to the within named defendant, to wit: George A.
Welsh a/k/a George Welsh, Jr. by regular mail to his last known address of 2 Brighton Lane, Camp
Hill, PA 17011. This letter was mailed under the date of January 8, 2008 and never returned to the
Sheriffs Office.
R. Thomas Kline, Sheriff, who being duly sworn according to law, states this writ is
returned STAYED per letter of request from Attorney Daniel Schmieg.
Sheriff s Costs:
Docketing 30.00
Poundage 25.00
Advertising 15.00
Posting Bills 15.00
Law Library .50
Prothonotary 2.00
Mileage 28.80
Levy 15.00
Surcharge 20.00
Postpone Sale 20.00
Law Journal 593.00
Patriot News 514.67
Share of Bills 16.17
$1295.14 / ~„,. ~'~/ ~ ~0 8'
So Answers:
R. Thomas Kline, Sheriff
BY o CQ.~. ~~ G_
Real Estate ergeant
l~""
Q~
a ~'~' ~ cue. L Yo a Y
r'
~,
~GMAC MORTGAGE, LLC
Plaintiff, .
v.
GEORGE A. WELSH A/K/A GEORGE WELSH,
JR.
Defendant(s). ,
CUMBERLAND COUNTY
COURT OF COMMON PLEAS
CIVIL DIVISION
N0.07-5431-CIVIL TERM
AFFIDAVIT PURSUANT TO RULE 3129
(Affidavit No. l)
GMAC MORTGAGE LLC Plaintiff in the above action, by its attorney, DANIEL G. SCHMIEG,
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 ,2 BRIGHTON LANE, CAMP HILL, PA 17011
17011 .
1. Name and address of Owner(s) or reputed Owner(s):
Name
GEORGE A. WELSH A/K/A GEORGE
WELSH, JR.
Last Known Address (if address cannot be
reasonably ascertained, please indicate)
2 BRIGHTON LANE
CAMP HILL, PA 17011
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:
Name 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:
Name
Last Known Address (if address cannot be
reasonably ascertained, please indicate}
MERS AS A NOMINEE FOR
QUICKEN LOAN, INC.
MERS AS A NOMINEE FOR
QUICKEN LOAN, INC.
P.O. BOX 2026
FLINT, MI 48501-2026
20555 VICTOR PARKWAY
LIVONIA, MI 48152
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.
Name
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 maybe affected by the sale:
Name
Last Known Address (if address cannot be
reasonably ascertained, please indicate)
Tenant/Occupant
Domestic Relations of Cumberland County
Commonwealth of Pennsylvania
Department of Welfare
2 BRIGHTON LANE
CAMP HILL, PA 1701 117011
13 North Hanover Street
Carlisle, PA 17013
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. 1
October 25, 2007
DATE ANIEL G. S EG, ESQ
Attorney for Plaintiff
1
. t
GMAC MORTGAGE, LLC
Plaintiff,
v.
GEORGE A. WELSH A/K/A GEORGE WELSH,
JR.
Defendant(s).
CUMBERLAND COUNTY
No. 07-5431-CIVIL TERM
October 25, 2007
TO: GEORGE A. WELSH A/K/A
GEORGE WELSH, JR.
2 BRIGHTON LANE
CAMP HILL, PA 17011
* *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
BANKRUPTCYAND THIS DEBT WAS NOT REAFFIRMED, THIS IS NOT AND SHOULD NOT BE CONSTRUED TO BE
ANATTEMPT TO COLLECT A DEBT, BUT ONLY ENFORCEMENT OF A LIEN AGAINST PROPERTY. **
Your house (real estate) at , 2 BRIGHTON LANE, CAMP HILL, PA 17011 17011, is
scheduled to be sold at the Sheriffs Sale on MARCH S, 2008 at 10:00 a.m. in the Cumberland County
Courthouse, South Hanover Street, Cazlisle, PA 17013, to enforce the court judgment of $ 208.014.64
obtained by GMAC MORTGAGE, LLC (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:
1. The`sale will be cancelled if you pay to the mortgagee the back payments, late charges,
costs and reasonable attorney's fees due. To find out how much you must pay, you may
call: (2151563-7000.
2. You may be able to stop the sale by filing a petition asking the Court to strike or open the
judgment, if the judgment was improperly entered. You may also ask the Court to
postpone the sale for good cause.
3. You may also be able to stop the sale through other legal proceedings.
•r
. r
You may need an attorney to assert your rights. The sooner you contact one, the more chance
you will have of stopping the sale. (See notice on page two on how to obtain an attorney.)
YOU MAY STILL BE ABLE TO SAVE YOUR PROPERTY AND YOU HAVE OTHER
RIGHTS EVEN IF THE SHERIFF'S SALE DOES TAKE PLACE.
1. If the Sheriffs Sale is not stopped, your property will be sold to the highest bidder. You may
find out the price bid by calling (215) 563-7000.
2. You may be able to petition the Court to set aside the sale if the bid price was grossly
inadequate compared to the value of your property.
3. The sale will go through only if the buyer pays the Sheriff the full amount due in the sale. To
find out if this has happened, you may call (717) 240-6390.
4. If the amount due from the Buyer is not paid to the Sheriff, you will remain the owner of the
property as if the sale never happened.
5. You have the right to remain in the property until the full amount due is paid to the Sheriff
and the Sheriff gives a deed to the buyer. At that time, the buyer may bring legal proceedings to evict
you.
6. You may be entitled to a shaze of the money which was paid for your house. A schedule of
distribution of the money bid for your house will be filed by the Sheriff within 30 days of the sale. This
schedule will state who will be receiving that money. The money will be paid out in accordance with
this schedule unless exceptions (reasons why the proposed distribution is wrong) are filed with the
Sheriff within ten (10) days after the distribution is filed.
7. You may also have other rights and defenses, or ways of getting your home back, if you act
immediately after the sale.
YOU SHOULD TAKE THIS PAPER TO YOUR LAWYER AT ONCE. IF YOU DO NOT HAVE
A LAWYER OR CANNOT AFFORD ONE, GO TO OR TELEPHONE THE OFFICE LISTED
BELOW TO FIND OUT WHERE YOU CAN GET LEGAL HELP.
IMPORTANT NOTICE: This property is sold at the direction of the plaintiff. It may not be sold
in the absence of a representative of the plaintiff at the Sheriff's Sale. The sale must be
postponed or stayed in the event that a representative of the plaintiff is not present at the sale.
CUMBERLAND COUNTY ATTORNEY REFERRAL
CUMBERLAND COUNTY BAR ASSOCIATION
2 LIBERTY AVENUE
CUMBERLAND COUNTY COURTHOUSE
CARLISLE, PA 17013
(717) 249-3166
(800) 990-9108
I~I.~VVL/VVL
ALL that certain lot or tract of land situate in East Pennsboro
Township, Cumberland County, Commonwealth of Pennsylvania, more
particularly bounded and desoribed as follows, to wit:
BEGINNING at a point on the northern right of way line of Windsor Way a
fifty (50) foot wide road,. said point also being the southwest corner
of Lot #2 as shown on the final subdivision plan of Victoria Glen II;
thence continuing along the northern right of way line of Windsor Way
the following two courses, along a curve to the right having 3 radius
of four hundred fifteen .and no hundredths (415.00) feet, an arc length
of forty three and sixty seven hundredths {93.67) feet, said arc being
subtended by a chord and bearing seventy four (79) degrees seventeen
(17) minutes twenty eight (28) seconds West a distance of forty three
and sixty five hundredths (93.65) feet to a point; thence continuing
South seventy seven (7?) degrees eighteen (18) minutes twenty (20)
seconds West a distance of thirty eight and seventy eight hundredths
(38.78) feet to a point, said point being the end of the radius at the
northeast *corner of the intersection of said Windsor Way with Brighton
Lane a fifty (50) foot wide road; thence continuing along the right of
way radius and along the eastern right of way of Brighton Lane the
following two Courses, along a curve to the right, having a radius of
fifteen and no hundredths (15.00) feet, an arc length of twenty and
ninety hundredths (20.90) feet, said arc being subtended by a chord and
bear~,ng of ~]orth sixty two {62) degrees forty six (46) minutes thirty
five (35) seconds West, a distance of nineteen and twenty five
hundredths (19.25) feet to a point; thence continuing North twenty two
(22) degrees fifty one (51) minutes thirty (30) seconds West a distance
of one hundred eleven and forty seven hundredths (111.97) feet to a
point, said point being the southwest corner of Lot #38 as shown on the
final subdivision plan of VlCCOrla Glen (Phase 1); thence continuing
along the southern line of said Lot #98, and along a portion of the
southern line of Lot #39 respectively North seventy-two (72) degrees
twenty eight (28) minutes twenty (20) seconds East, a distance of one
hundred three and sixty hundredths (103.60) feet to a point, said point
being northwest corner of the aforementioned Lot #2; thence continuing
along the westErn line of Lot #2, South eighteen (1B) degrees forty-
three (93) minutes twenty three (23) seconds Easti a distance of one
hundred twenty nine and twenty two hundredths (129.22) feet to a point,
said point being the point and place of BEGINNING.
Being Lot #1 as shown on a Final Subdivision Flan of victoria Glen II
recorded in Plan Book 55, Page 57.
?ITL.E TO SAID p1tEMISES IS VESTED 1N George A. Welsh, adult individual, by Deed from
Russell A. Dzielak and Angela K. Dzielak, his wife, dated 06/14/2006, recorded 06/16/2006, in
Deed Book 275, page 838.
PARCEL IDENTIFICATION NO: 09-1&1304173
Premises: 2 BRIGIdTON LANE, CAMP HILL, PA 17011
WRIT OF EXECUTION and/or ATTACHMENT
COMMONWEALTH OF PENNSYLVANIA)
COUNTY OF CUMBERLAND)
NO 07-5431 Civil
CIVIL ACTION -LAW
TO THE SHERIFF OF CUMBERLAND COUNTY:
To satisfy the debt, interest and costs due GMAC MORTGAGE, LLC, Plaintiff (s)
From GEORGE A. WELSH a/k/a GEORGE WELSH, JR.
(1) You are directed to levy upon the property of the defendant (s)and to sell SEE LEGAL
DESCRIPTION.
(2) You are also directed to attach the property of the defendant(s) not levied upon in the possession
of
GARNISHEE(S) as follows:
and to notify the garnishee(s) that: (a) an attachment has been issued; (b) the garnishee(s) is 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 $208,014.64
L.L.$.50
Interest from 10/26/07 to 3/05/08 (per diem - $34.19) - $4,513.08 and Costs
Atty's Comm
Atty Paid $161.40
Plaintiff Paid
Date: 10!30!07
(Seal)
REQUESTING PARTY:
Due Prothy $2.00
Other Costs $1,978.50
acs ~
is R. Long, Prothonota
By: ~. 9
Deputy
Name DANIEL G. SCHMIEG, ESQUIRE
Address: PHEI,AN HALLINAN &SCHMIEG, LLP
ONE PENN CENTER AT SUBURBAN STATION
1617 JOHN F KENNEDY BLVD, SUITE 1400
PHILADELPHIA, PA 19103-1814
Attorney for: PLAINTIFF
Telephone: 215-563-7000
Supreme Court ID No. 62205
f
t~i~
k
Real Estate Sale # 41
On November 8, 2007 the Sheriff levied upon the
defendant's interest in the real property situated in
East Pennsboro Township, Cumberland County, PA
Known and numbered as 2 Brighton Lane,
Camp Hill, more fully described on Exhibit "A"
filed with this writ and by this reference
incorporated herein.
Date: November 8, 2007 By' ~/b br ~~~v
Real Estate Sergeant
:_..;
PROOF OF PUBLICATION OF NOTICE
IN CUMBERLAND LAW JOURNAL
(Under Act No. 587, approved May 16, 1929), P. L.1784
COMMONWEALTH OF PENNSYLVANIA
ss.
COUNTY OF CUMBERLAND
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 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:
January 25, February 1 and February 8, 2008
Affiant further deposes that he is authorized to verify this statement by the Cumberland
Law Journal, a legal periodical of general circulation, and that he is not interested in the subject
matter of the aforesaid notice or advertisement, and that all allegations in the foregoing
statements as to time, place and character of publication are true.
~'
Lis arie Coyne, itor
SWORN TO AND SUBSCRIBED before me this
8 day of February, 2008
Notary '
NOTARIAL SEAL
DEBORAH A COLLINS
Notary Public
CARLISLE BORO, CUMBERLAND COUNTY
My Commission Expires Apr 28, 2010
>RiAL ~TAT>d BALD ^O. 41
Writ No. 2007-5431 Civil
GMAC Mortgage, LLC
vs.
George A. Welsh a/k/a
George Welsh, Jr.
Atty.: Daniel Schmieg
DESCRIPTION
ALL that certain lot or tract of land
situate in East Pennsboro Township,
Cumberland County, Commonwealth
of Pennsylvania, more particularly
bounded and described as follows,
to wit:
BEGINNING at a point on the
northern right of way line of Wind-
sor Way a fifty (50) foot wide road,
said point also being the southwest
corner of Lot #2 as shown on the final
subdivision plan of Victoria Glen II;
thence continuing along the northern
right of way line of Windsor Way the
following two courses, along a curve
to the right having a radius of four
hundred fifteen and no hundredths
(415.00) feet, an arc length of forty
three and sixty seven hundredths
(43.67) feet, said arc being subtended
by a chord and bearing seventy four
(74) degrees seventeen (17J minutes
twenty eight (28) seconds West a
distance of forty three and sixty five
hundredths (43.65) feet to a point;
thence continuing South seventy
seven (77) degrees eighteen (18)
minutes twenty (20) seconds West a
distance of thirty eight and seventy
eight hundredths {38.78) feet to a
point, said point being the end of
the radius at the northeast corner of
the intersection of said Windsor Way
with Brighton Lane a fifty (50) foot
wide road; thence continuing along
the right of way radius and along
----.-._...,r .............,.... ~._.,.-. .,~,.__.,....
the eastern right of way of 13ngritoi,
Lane the following two courses,
along a curve to the right, having a
radius of fifteen and no hundredths
(15.00) feet, an arc length of twenty
and ninety hundredths (20.90) feet,
said arc being subtended by a chord
and bearing of North sixty two (62)
degrees forty six (46) minutes thirty
five (35) seconds West, a distance of
nineteen and twenty five hundredths
(19.25) feet to a point; thence con-
tinuing North twenty two (22) degrees
fifty one (51) minutes thirty (30} sec-
onds West a distance of one hundred
eleven and forty seven hundredths
(111.47) feet to a point, said point
being the southwest corner of Lot
#38 as shown on the final subdivi-
sion plan of Victoria Glen (Phase 1);
thence continuing along the southern
line of said Lot #38, and along a por-
tion of the southern line of Lot #39
respectively North seventy-two (72)
degrees twenty eight (28) minutes
twenty (20) seconds East, a distance
of one hundred three and sixty
hundredths (103.60) feet to a point,
said point being northwest corner of
the aforementioned Lot #2; thence
continuing along the western line of
Lot #2, South eighteen (18) degrees
forty-three (43) minutes twenty three
(23) seconds East a distance of one
hundred twenty nine and twenty two
hundredths (129.22) feet to a point,
said point being the point and place
of BEGINNING.
Being Lot # 1 as shown on a Final
Subdivision Plan of Victoria Glen II
recorded in Plan Book 55, page 57.
TITLE TO SAID PREMISES IS
VESTED IN George A. Welsh, adult
individual, by Deed from Russell A.
Dzielak and Angela K. Dzielak, his
wife, dated 06/14/2006, recorded
06/ 16/2006, in Deed Book 275,
page 838.
PARCEL IDENTIFICATION NO:
09-18-1304-173.
Premises: 2 Brighton Lane, Camp
Hill, PA 17011.
The Patriot-News Co.
812 Market St.
Harrisburg, PA 17101
Inquiries - 717-255-8292
CUMBERLAND COUNTY SHERIFFS OF
CUMBERLAND COUNTY COURT HOUSE
~e~latriot News
Now you know
CARLISLE PA 17013
THE PATRIOT NEWS
THE SUNDAY PATRIOT NEWS
Proof of Publication
Under Act No. 587, Approved May 16, 1929
Commonwealth of Pennsylvania, County of Dauphin} ss
Joseph A. Dennison, being duly sworn according to law, deposes and says:
That he is the Assistant Controller of The Patriot News Co., a corporation organized and existing under the laws of the
Commonwealth of Pennsylvania, with its principal office and place of business at 812 to 818 Market Street, in the City of
Harrisburg, County of Dauphin, State of Pennsylvania, owner and publisher of The Patriot-News and The Sunday Patriot-News
newspapers of general circulation, printed and published at 812 to 818 Market Street, in the City, County and State aforesaid; that
The Patriot-News and The Sunday Patriot-News were established March 4th, 1854, and September 18th, 1949, respectively, and
all have been continuously published ever since;
That the printed notice or publication which is securely attached hereto is exactly as printed and published in their regular
daily and/or Sunday/ Metro editions which appeared on the date(s) indicated below. 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 COPY
This ad ran on the date(s) shown below:
01I30I08
02/06/08
02/13/08
~~
Sworn to an~scribed before yne th~5~y o~ February, 2008 A. D.
Notary Public
COMMONWEALTH OF QEI~P#SYLVAfVl.A
Notarial S<y~iSry~! -~
Shortie L_ Kis~!er, aa:,G;~ry Public
CilyOfHertistx~rt~ ~?a~rt5i,inCounty
My Ci0n7n11B~Or? ~.~ ,~IYfi ~iQV. 26, 2011
Member, Pennaytvania Association of Notaries
iNFJ1t. i18'~tTE BiAt~ NQ 41
MMt Nor. ~OP~*i 4;a~
GNNC. ; i1C
~otrgs ~ 1:+tArht ~iew'ye
tAlie~rfi, Jt.
~, AtNtms7IE'Ni S
DESCRIP'T10N
ALL that certain lot or trail of land situate in
East Petutsbono Township, Cumberland County,
Commonwealth of Peansylvaoia, more
particularly bounder( and described as follows,
to wit:
BEGiI~INING at a point on the northern right of
way line of Windsor Way a fd3y (50) foot wide
road, said point rho trig the southwest corner
of Lot #2 as shown oa the final subdivision plan
of VictoriaGka II; thence oot~minaB ~8
nortltem right of way line of Windsor Way the
following two causes. along a clove to the right
having a radius of four hundred fifteen and no
hundredths (415.00) feet, an arc lengdt of forty
three a~ starry seven hnodt~odths (43.57) fcei
said arc being sitl~dad bya'chord and bed
seventy four (74) degrees seventxn (1~)
minutes twenty eight (28) semnds West a
distance of forty three sail sixty five hundredths
. y,(43:145) ~ a pct thence cnntiiauing Sow
5' seven ('T7) degrees eighteen (18)
r'~es twenty (~) secrouds West a distance af'
thiny tight toil seventy cigMhrmdnedlhs (38:78}
fed m e poise, said poiast bong the end of the
mdim at tfic northeast ctx'ner of the intersection
of said 9s~mdsor Way with Brighton Lane a fifty
(50) foot wide road; thence onrttitwing along the
riglu of way radius and along the eastern tight of
way of Lane rho foUovving two
ceases, atos~ a carve to the right, havirsg a
radios of fiftseto aqd s~ hnndtetidts (15.00) fret.
an arc rsi' twenty astd artery handiethhs
(20.90) fed, still azc tieing subtended by a cltotd
?~1 beming of 1Vorth sixty two (62) ds~roes
,.forty six (46} ~igtrces thirty five (35} sacaeds
Wert, s distatroe of nineteen aisd twenty five
1~ut~s (19.13) feel to a point; tbessoe
North twenty two (22} degrees 9fYy
orsc {fit) minutes thirty (3Q) seconds West a
distaatx of os>c ) eleven and forty. sever
6 (ii1.47} fed to a point,. said pant
being tlrt soufiswest crxna of Lot #38 as slirrwn
on the final subdivision plsw of Victoria Glen
(Phase 1} thse continuing along the soudtetn
line of said Lot #38; asul along a portion of tie
southern line of Lot #39 respectively 14rx~
seventy-two (72} degrees ta1tAty eight (28)
minutes twpNy:(2(1) secao~ Fast, a drdi~ct of
one 6u>odrod t)xee and sixty hundredths {b0)
feet to a point, said paint tieing northcvxatta
of the afore~tionrd Lot tt2; thence rt
along the western lime of Lot N2, So~P
(18} de~esftiry-time (43) minutes tvvcaty
three (23) seconds East a distalooe ~f .one
humfred twenty Qis>E and tweedy rno h
(124.22) feet m a point, said point b~hlt
point a~ pkce of BEti3NAffi~1G.
Being Lot #1 as shave on a Finat 3t~tiuisioo
Plan of Ytctoria Glen II recorded in Pism Boat:
55, page 57.
Title to Budd pr±tuases is vcsapd irP ~,
Wash, arbdt individual, by t7sxd,
A: Dzielak and Arige~ R '~; wee.
iTaid
~'~~ _
Parori ~No:09-18-1304.173
Premises: 2 titighton Lane, ( ti>B. ~
17011: