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HomeMy WebLinkAbout03-5361 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 GE MORTGAGE SERVICES, LLC, F/KIA GE CAPITAL MORTGAGE SERVICES, INe. 3476 STATEVIEW BOULEVARD FORT MILL, SC 29715 ATTORNEY FOR PLAINTIFF COURT OF COMMON PLEAS CIVIL DIVISION TERM v. NO. 03 - 5'.31..1 (liolt-~ Plaintiff CUMBERLAND COUNTY GLENN E. BURDGE JANA G. BURDGE AJKJA JANE G. BURDGE 204 HICKORY LANE SHIPPENSBURG, P A 17257 Defendant(s) CIVIL ACTION - LA \Y COMPLAINT IN MORTGAGE FORECLOSURE 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 are served, by entering a written appearance personally or by attorney and filing in writing with the court your defenses or objections to the claims set forth against you. You are warned that if you fail to do so the case may proceed without you and a judgment may be entered against you by the court without further notice for any money claimed in the complaint or for any other claim or relief requested by the plaintiff. You may lose money or property or other rights important to you, YOU SHOULD TAKE THIS PAPER TO YOUR LAWYER AT ONCE. IF YOU DO NOT HAVE A LAWYER, 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 File #: 80748 File #; 80748 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 seC[. (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 Rl~QUEST WILL BE MADE TO THE COURT FOR A JUDGMENT UNTIL THE EXPIRATION OF THIRTY (30) DAYS AFfER 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 RlGHTS AND OBLIGATIONS IN THIS SUIT. 1. Plaintiff is GE MORTGAGE SERVICES, LLC, FIKIA GE CAPITAL MORTGAGE SERVICES, INC. 3476 STATEVIEW BOULEVARD FORT MILL, SC 29715 2. The name(s) and last known address(es) ofthe Defendant(s) are: GLENN E. BURDGE JANA G. BURDGE NKJ A JANE G. BURDGE 204 HICKORY LANE SHIPPENSBURG, P A 17257 who is/are the mortgagor(s) and real owner(s) of the property hereinafter described. 3. On 10/01/1992 mortgagor(s) made, executed and delivered a mortgage upon the premises hereinafter described to BANK UNITED OF TEXAS which mortgage is recorded in the Office of the Recorder of CUMBERLAND County, in Mortgage Book No. 1092, Page 667. By Assignment of Mortgage recorded 09/30/93 the mortgage was assigned to PLAINTIFF which Assignment is recorded in Assignment of Mortgage Book No. 455, Page 178. 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 12/01/2002 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 #: 80748 6. The following amounts are due on the mortgage: Principal Balance Interest 11/01/2002 through 10/08/2003 (Per Diem $17.24) Attorney's Fees Cumulative Late Charges 10/01/1992 to 10/08/2003 Cost of Suit and Title Search Subtotal $78,792.68 5,896.08 1,250.00 327.20 $ 550.00 $ 86,815.96 Escrow Credit Deficit Subtotal 0.00 1,823.13 $ \,823.13 TOTAL $ 88,639.09 7. The attorney's fees set forth above are in conformity with the mortgage documents and Pennsylvania law, and will be collected in the event of a third party purchaser at Sheriff's Sale. If the Mortgage is reinstated prior to the Sale, reasonable attorney's fees will be charged. 8. 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. 9. 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 $ 88,639.09, together with interest from 10/08/2003 at the rate of $17.24 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, I,LPj / , ~~,)j ~ By: !s!Ff{lR;is S. Hallinan FRANK FEDERMAN, ESQUIRE LAWRENCE T. PHELAN, ESQUIRE FRANCIS S. HALLINAN, ESQUIRE Attorneys for Plaintiff File #: 80748 r . ALL that certain tract ot: gound situate in Shippensbucg TownsbIp, Cumberland Count}!'1 "-'...... ...... i...~.... wi.......... llom;'" dwol.... _ .... _ __...... . an" described as tbllows: . . ." BHGINNlN'.3 at a point On the eastern edge of" Hickal)' Lane at common comer orLoI i No~ J. Section "N". and Lot No.2, Section "N", as shown on Subdivision PlltIt ror G &. C ' Associates daled Allgust :W. 1991; thence along Lot No.1 South 35 degrees 51 minutes S3 seconds East 150.011 feet to a point; thence along otber lands now or fonneely of Galen S. Asper North .54 degrees 011 minutes 07 seconds East 111.80 feet to a point; tJ1CDc:e along a proposed pubUc'street North :JS degrees 51 minutes 53 scc:onds West 115.00 ket to a point; thcncebya curve to (be 10ft ha"lng a radius of 35.00 feet, a chord bearing of North 80 degrees 51 minutCl$1 seconds East. an ar.: distance of 54.98 reet to a point on the eastern edge ofHlckory Lane; lhcnlIe ' along the _em edge of Hickory Lane South 54 <lagrees 08 minutes 07 seconds West 76.80 r... to It point. the poim lUld pla~ of BEGINNING. BEING all (,fLot No.2. Section "N", on SUbdivision Plan for G &. C Associates dated August 20. 1991 and recorded in Cumberland COUnty Plan Book 64. Page 60. CONTAINING 0.3790 acres, more or less. PROPERTY ADDRESS: 204 HICKORY LANE " VERIFICATION NADINE BONSICK hereby states that she is VICE PRESIDENT LOAN DOCUMENTATION of WELLS FARGO HOME MORTGAGE, INC. mortgage servicing agent for Plaintiff in this matter, that she is authorized to take this Verification, and that the statements made in the foregoing Civil Action in Mortgage Foreclosure are true and correct to the best of her knowledge, information and belief. The undersigned understands that this statement is made subject to the penalties of 18 Pa. C.S. Sec. 4904 rel,ting " ~;wom '";lfi,,,lon '",uUMltire. I U . LA1 LILA tJUai.- Nadine Bonsick, DATE: (D~~c5'J Vice President Loan Documentation N a ;0. # ~ .~ '- Ul 0 C" c-' tS w -~ (;) c C,O! .':" -~ 0 0 -ort. 0 , ~ ~ fT11 J' :-~) z:-; .-. ~ 2~ ; , ((1' '0 -...c..: vt -~:. ' ..... ~l::: .'1-' }::i'-- 1- ~~(~ -- I. ::? ',-) /~ ._-~ ...., ,. .-1 5:) -<, .(:" -< --- CASE NO: 2003-05361 P SHERIFF'S RETURN - REGULAR COMMONWEALTH OF PENNSYLVANIA: COUNTY OF CUMBERLAND GE MORTGAGE SERVICES LLC VS BURDGE GLENN E ET AL VALERIE WEARY , Sheriff or Deputy Sheriff of Cumberland County, Pennsylvania, who being duly sworn according to law, says, the within COMPLAINT - MORT FORE was served upon BURDGE GLENN E the DEFENDANT , at 1542:00 HOURS, on the lOth day of October 2003 at 204 HICKORY LANE SHIPPENSBURG, PA 17257 by handing to GLENN E BURDGE 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 18.00 13 .11 .00 10,00 ,00 41.11 So Answers: //7 ,,;;/ 0/- r"%;H'U<'<' .,:~.J' R, Thomas Kline 10/13/2003 FEDERMAN & PHELAN Sworn and Subscribed to before By: {"-- ~~---- Deputy She~ff me this /{,~ day of (Dd<..L .,lo{}..3 A,D. r) '-1. '- C2 ~ .- ~rothonotary ,~ SHERIFF'S RETURN - REGULAR CASE NO: 2003-05361 P COMMONWEALTH OF PENNSYLVANIA: COUNTY OF CUMBERLAND GE MORTGAGE SERVICES LLC VS BURDGE GLENN E ET AL VALERIE WEARY , Sheriff or Deputy Sheriff of Cumberland County, Pennsylvania, who being duly sworn according to law, says, the within COMPLAINT - MORT FORE was served upon BURDGE JANA G AKA JANE G BURDGE the DEFENDANT , at 1542:00 HOURS, on the 10th day of October ,2003 at 204 HICKORY LANE SHIPPENSBURG, PA 17257 by handing to GLENN E BURDGE, HUSBAND 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 So Answers: 6.00 .00 .00 10.00 .00 16.00 :r{;~>,<.<,.: ,(/-17 ,,':',,_':'.~:',.,'d:" ~.....~ R. Thomas Kline 10/13/2003 FEDERMAN & PHELAN Sworn and Subscribed to before By: /L:~ Deputy She~ me this /~ E::. day of m~~ 2ti).3 A.D. (\. W~ -- ~onotary ,~, . . , AFFIDAVIT OF SERVICE CUMBERLAND COUNTY PLAINTIFF GE MORTGAGE SERVICES, LLC, FIKIA GE CAPITAL MORTGAGE SERVICES, INC. PIT No. 2003-05361 ACCT. #0010457042 DEFENDANT(S) GLENN E. BURDGE JANA G. BURDGE A!KIA JANE G. BURDGE Type of Action - Notice of Sheriff's Sale SERVE JANA G. BURDGE A!KIA JANE G. BURDGE AT 204 mCKORY LANE SHIPPENSBURG, P A 17257 Sale Date: JUNE 8, 2005 SERVED Served and made known to Ja IV a G'. 1'3 V j'--c\, 5 e..., Defendant, on the ,ZOO~at,1: 1po,0'c!Ock!-.m.,at 5Zc:J/f ffiCKd'f-j!.tJ I , I ~ ..Jt'day of ,A1,7('.-.cA/ \ 'SA I ffe)..J3tJUf:-S Sworn to and subscnoed before me this llif1 day , of 11)(. "''''"ZOO-.?-- ~'- Notary' '-.' ~1 ) I ,-r- By' ~ . Z; '" c,:J.. L0 j"-,u.A., '-".. " . (/ "'2 PLEASE ATTEMPT SERVI& AT LE T 3 S. INnI ATTEMPTED. ) Commonwealth of Pennsylvania, in the manner described below: X Defendant personally served, Adult family member with whom Defendant( s) reside( s), Name and Relationship is Adult in charge ofDefendant(s)'s residence who refused to give name or relationship. Manager/Clerk of place oflodging in which Defendant(s) reside(s). Agent or person in charge of Defendant(s)'s office or usnal place of business. an officer of said Defendant(s)'s company. Other: , IV /,J'- Des:1tion: AgeM HeightS 7 Weight /70 Race~SexL Other I, C101'LttJ C ~ h, (!~'(L+7 ,.J!ml>etent adult, being duly sworn according to law, depose and state that I personally handed a true and corree copy of the Notice of Sheriffs S . as et forth herein issued in the captioned case on the date and at the address indicated above. NOTARIAL SEAl. ~~==~ My Comrnfsalon ExpIr8s ,0. 200t -, NOT SERVED On the day of .200_, at o'clock~.m" Defendant NOT FOUND because: Moved Unknown No Answer Vacant 1 'I Attempt: I I Time: 2nd Attempt: I I Time: 3rd Attempt: I I Time: Sworn to and subscribed before me this _ day of , ZOO _' Notary: By: . AFFIDAVIT OF SERVICE PLAINTIFF GE MORTGAGE SERVICES, LLC, FIKIA GE CAPITAL MORTGAGE SERVICES, INC. CUMBERLAND COUNTY PJT No. 2003-05361 ACCT. #0010457042 DEFENDANT{S) GLENN E. BURDGE JANA G. BURDGE A/K/A JANE G. BURDGE Type of Action - Notice of Sheriff's Sale SERVE GLENN E. BURDGE AT 204 mCKORY LANE SIDPPENSBURG, PA 17257 Sale Date: JUNE 8, 2005 Sd;VED II G Ie:" IV tJ e. ' tt<'\ ~ Served and made known to r, t3 U I't' ,Defendant, OIythe / 3 day of )4il-f:.cl. ,200-" at f).ftJO ,O'cloCk-fm.,at !J()f ;l1~lott:-'I J)IJ I / "3l..1i ~rt'j.J 5' Gv /C.J ,Commonwealth of Pennsylvania, in the manner described below: Defendant personally served. )( Adult family member with whom Defendant(s) reside{s), Name and Relationship is Adult in charge ofDefendant(s)'s residence who refused to give name or relationship, Manager/Clerk of place oflodging in which Defendant( s) reside(s). Agent or person in charge ofDefendant(s)'s office or usual place of business, an officer of said Defendant( s) 's company, Wife '-:}3tv'J. vi I 130 I\. cLJ e Other: Description: Age 5"0 I II , , . Height 67 WeigJJt1l0 Race 1.UL. SexL Other ']Aompetent adult, being duly sworn according to law, depose and state that I personally handed . ce of Sheriff s Sale in the manner as set forth herein, issued in the captioned case on the date and at I, ~eiJc I a true and correct copy of the N the address indicated above. NOTARIAl SEAL LUCIUE H. CARTY, NolIry PubIc before me this d'l'/1\ay Lellerlr8n 1i , Frin County of'7l 10'-d...200,l:-., ~ ~i My _ .10.200t Notary: 'y..., i Wl li.t.c/vl.., By: /' 'J}h~~ f"" :5 .V ~'Q PLEASE ATTEMPT SERVICE AT LEAST 3 TIMES. INDICl Sworn to and subscribed OF SERVICE ATTEMi'TED. NOT SERVED On the day of .200~at o'clock _,ro., Defendant NOT FOUND because: Moved Unknown No Answer Vacant 1" Attempt: / / Time: 2nd Attempt: / / Time: 3rd Attempt: / / Time: Sworn to and subscribed before me this _ day of . 200 _' Notary: By: Attornev for Plaintiff Daniel G. Sehmieg, Esquire - I.D. No. 62205 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 GE MORTGAGE SERVICES, LLC, FIKfA GE CAPITAL MORTGAGE SERVICES, INC. 3476 STATEVIEW BOULEVARD FORT MILL, SC 29715 CUMBERLA D COUNTY COURT OF C MMON PLEAS Plaintiff, v. NO, 2003-053 1 GLENN E. BURDGE JANA G. BURDGE AlKfA JANE G. BURDGE Defendant(s). PRAECIPE FOR IN REM JUDGMENT FOR FAIL RE TO ANSWER AND ASSESSMENT OF DAMAG S TO THE PROTHONOTARY: Kindly enter an in rem judgment in favor of the Plaintiff and against LENN E. BURDGE and JANA G. BURDGE AlKJA JANE G. BURDGE, Defendant(s) for failure t file an Answer to Plaintiffs Complaint within 20 days from service thereof and for Foreclosur and Sale of the mortgaged premises, and assess Plaintiffs damages as follows: As set forth in Complaint Interest from 10/8/03-3/1/05 to 3/2/05 TOTAL $88,639.0 $8,809.6 $97,448.7 I hereby certify that (I) the addresses of the Plaintiff and Defendant(s) re as shown above, and (2) that notice has been given in accordance with Rule 237.1, copy attached. DANIEL G. SCHMIEG. DIRE Attorney for Plaintiff DAMAGES ARE HEREBY ASSESSED AS INDICAT DATE: fY2'-:J t2r t. '3 d-.OO-S- I PRO PROTHY PHELAN HALLINAN & SCHMIEG, LLP , By: Lawrence T. Phelan, Esq., Id, No, 32227 Francis S, Hallinan, Esq" Id, No, 62695 Daniel G. Schmieg, Esq., Id. No. 62205 Philadelphia, P A 19103 (7 I 'Ii '61-7000 ATTORNEY FOR PLA IFF FILE COpy GE MORTGAGE SERVICES, LLC, FIK/A GE : COURT OF COMMON PLE S CAPITAL MORTGAGE SERVICES, INe. Plaintiff : CIVIL DIVISION Vs, : CUMBERLAND COUNTY JANA G. BVRDGEA/K/AJANEG. BURDGE GLENN E. BURDGE Defendants : NO, 2003-05361 TO: JANA G. BURDGE AJK! A JANE G. BURDGE 204 HICKORY LANE SffiPPENSBURG, P A 17257 DATE OF NOTICE: FF,BRlJARY 11, 200~ TIllS FIRM IS A DEBT COLLECTOR ATTEMPTING TO COLLECT A DEB . TIllS NOTICE IS SENT TO YOU IN AN ATTEMPT TO COLLECT THE INDEBTEDNESS REFE D TO HEREIN, AND ANY INFORMATION OBTAINED FROM YOU WILL BE USED FOR TIfA PURPOSEJF YOU HAVE PREVIOUSLY RECEIVED A DISCHARGE IN BANKRUPTCY, THIS CO SPONDENCE IS NOT AND SHOULD NOT BE CONSTRUED TO BE AN ATTEMPT TO COLLE A DEBT, BUT ONLY AS ENFORCEMENT OF LIEN AGAINST PROPERTY. IMPORTANT NOTICE YOU ARE IN DEFAULT BECAUSE YOU HAVE FAILED TO ENTER A WRIT EN APPEARANCE PERSONALLY OR BY ATTORNEY AND FILE IN WRITING WITH THE COURT YOU DEFENSES OR OBJECTIONS TO THE CLAIMS SET FORTH AGAINST YOU. UNLESS YOU ACT WI HIN TEN DAYS FROM THE DATE OF THIS NOTICE, A JUDGMENT MAYBE ENTERED AGAINST YOU WITHO T A HEARING AND YOU MAY LOSE YOUR PROPERTY OR OTHER IMPORTANT RIGHTS, YOU SHOULD TAKE THIS PAPER TO YOUR LAWYER AT ONCE. IF YOU 0 NOT HAVE A LAWYER. GO TO OR TELEPHONE THE OFFICE SET FORTH BELOW, THIS OFFICE CAN PRO IDE YOU WITH INFORMATION ABOUT HIRING A LAWYER. IF YOU CANNOT AFFORD TO HIRE ALA WYER, THIS OFFICE MA Y BE AB E TO PROVIDE YOU WITH INFORMA nON ABOUT AGENCIES THAT MAY OFFER LEGAL SERVICES TO ELIG LE 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 FRANCIS S, ALL/NAN, ESQUIRE Attorneys for laintiff PHELAN HALLINAN & SCHMIEG, LLP By: Lawrence T. Phelan, Esq., Id. No. 32227 ATTORNEY FOR PLA TIFF Francis S. Hallinan, Esq., Id. No. 62695 Daniel G. Schmieg, Esq., Id. No. 62205 Philadelphia, P A 19103 (? 1 ,) ,61-7000 GE MORTGAGE SERVICES, LLC, FfKJA GE : COURT OF COMMON PLE S CAPITAL MORTGAGE SERVICES, INC. Plaintiff : CIVIL DIVISION Vs. : CUMBERLAND COUNTY JANA G. BURDGE NKlA JANE G. BURDGE GLENN E. BURDGE Defendanls : NO. 2003-05361 TO: GLENN E. BURDGE 204 IDCKORY LANE SIDPPENSBURG, PA 17257 DATE OF NOTICE: FF.RRUARV 11, 2005 TIllS FIRM IS A DEBT COLLECfOR ATTEMPTING TO COLLECf A DEB. TillS NOTICE IS SENT TO YOU IN AN ATTEMPT TO COLLECf THE INDEBTEDNESS REFE D TO HEREIN, AND ANY INFORMATION OBTAINED FROM YOU WILL BE USED FOR THA PURPOSE. IF YOU HAVE PREVIOUSLY RECENED A DISCHARGE IN BANKRUPTCY, THIS CO SPONDENCE IS NOT AND SHOULD NOT BE CONSTRUED TO BE AN ATTEMPT TO COLLE A DEBT, BUT ONLY AS ENFORCEMENT OF LIEN AGAINST PROPERTY IMPORTANT NOTICE YOU ARE IN DEFAULT BECAUSE YOU HAVE FAILED TO ENTER A WRI EN APPEARANCE PERSONALLY OR BY ATTORNEY AND FILE IN WRITING WITH THE COURT YOU DEFENSES OR OBJECTIONS TO THE CLAIMS SET FORTH AGAINST YOU. UNLESS YOU ACT WI HIN TEN DA YS FROM THE DATE OF THIS NOTICE, A JUDGMENT MAYBE ENTERED AGAINST YOU WITHO T A HEARING AND YOU MAY LOSE YOUR PROPERTY OR OTHER IMPORTANT RIGHTS. YOU SHOULD TAKE THIS PAPER TO YOUR LAWYER AT ONCE. IF YOU 0 NOT HAVE A LAWYER, GO TO OR TELEPHONE THE OFFICE SET FORTH BELOW. THIS OFFICE CAN PRO IDE YOU WITH INFORMATION ABOUT HIRING A LAWYER. IF YOU CANNOT AFFORD TO HIRE A LAWYER, THIS OFFICE MAYBE AB E TO PROVIDE YOU WITH INFORMATION ABOUT AGENCIES THAT MAY OFFER LEGAL SERVICES TO EUGI LE 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 FRANCIS S. ALLIN AN, ESQUlRE Attorneys for laintiff SHERIFF'S RETURN - REGULAR CASE NO: 2003-05361 P COMMONWEALTH OF HENNSYLVAN1A: COUNTY OF CUMBERLAND \o\~'\G ) I GE MORTGAGE SERVICES LLC VS BURDGE GLENN E ET AL VALERIE WEARY , Sheriff or Deputy Sh according to law, Cumberland County, Pennsylvania, who being duly says, the within COMPLAINT - MORT FORE was serve upon BURDGE GLENN E the DEFENDANT , at 1542:00 HOURS, on the 10th day of October 2003 at 204 HICKORY LANE SHIPPENSBURG, PA 17257 by handing t GLENN E BURDGE a true and attested copy of COMPLAINT - MORT FORE together with and at the same time directing His attention to the c ntents thereof. Sheriff's Costs: Docketing Service Affidavit Surcharge So Answers: 18.00 13 .11 .00 10.00 .00 41.11 ./ . ,r_/-j~.:.,;:r ... _" ,/ "-'~ t..'!",....,. _~ _~...t...+_.~ ..,. _.", ~.n._- ._ ." ,.,..'~...""'" ~ , R. Thomas Kline 10/13/2003 FEDERMAN & PHELAN me this day of ff Sworn and Subscribed to before By: A.D. Prothonotary 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 PIDLADELPIDA, PA 19103-1814 (215) 563-7000 ATTORNEY FO PLAINTIFF GE MORTGAGE SERVICES, LLC, F/KIA GE CAPITAL MORTGAGE SERVICES, INC. 3476 STATEVIEW BOULEVARD CUMBERL D COUNTY COURT OF C Plaintiff, v. NO. 2003-0536 GLENN E. BURDGE JANA G. BURDGE AfK/A JANE G. BURDGE Defendant(s). VERIFICATION OF NON-MILITARY SERV CE DANIEL G. SCHMIEG, ESQUIRE, hereby verifies that he i attorney for the Plaintiff in the above-captioned matter, and that on information and belief, he has kno ledge of the following facts, to wit: (a) that the defendant(s) is/are not in the Military or Naval S rvice of the United States or its Allies, or otherwise within the provisions of the Soldiers' and Sailors'ivil Relief Act of Congress of 1940, as amended. (b) that defendant GLENN E. BURDGE is over 18 years 0 age and resides at , 204 HICKORY LANE, SHIPPENSBURG, PA 17257. (c) that defendant JANA G. BURDGE AlKJ A JANE G. B RDGE is over 18 years of age, and resides at, 204 HICKORY LANE, SHIPPENSBU G, PA 17257. This statement is made subject to the penalties of 18 Pa. e.S. ection 4904 relating to unsworn falsification to authorities. G DANIEL G. SCHMIEG, E QUIRE Attorney for Plaintiff LEGAL DESCRIPTION ALL THAT CERTAIN [(aCI M ground sitoalJ: in Sbippellsolng Towmhip, Cumbe land COUllty, Penns)'Ivania, beillg improved with a single lamlly dwelling house, anLl more llarticulllrl bourukd!\llLl d=rihcd as folkiw,;: BEGINNING at a point on the E~8tem edge of HJckory UlW at commol\ comer of Lot o. t, Section "N' , aod Lot Nll. 2, Sectioll "N', as sbown on Suhdivi.iml p,~" lot G & C Associates dated Atl811St 20, 1991; t1lcncealong Lot No.1 Sooth 35 degrees 51 minutc5 53 'cco~ FASt 150.00 f, to l poilu; [hence along other land. now or fOJmerly Ilf Galen S. Asper North 54 degrec.j 00 minu 07 Il<:C()ruls E<cit IU.Bel feet \l) a fX'int; ,hcllce ~100g it proposed pllblic Strcct North 35 degrees _1 minutes 53 ~econds West1l5.00 feet co a poilJt; theoce by a curie to the left having a ladiu~ of 35. (eet, . chord bearing of Norlll SO dllgrces j I minutes 53 sewnds EaIJt, an arc distance (){ 54.98 feel to point on the Eastern edge of Hickory Lane; tIIeR~C along the Ellslertl edge of Hickory Lane South ~ degree~ 0& mit1U1e> 01 8~onds We~1 76.80 fl:ct to II potnt, lhe point and place IJf Bcginniug. BEING all of Lot No. Z, SecrjOll "N", on Subdillisi(ln !'lall for G & C Associates dat Aug~t 20, 199J Illld [I:wrd::d in Cumberland County PhlIl Book 64, Page 60. TITLE TO SAID PREMISES IS VESTED eN Glenn E. Burdge and Jane G. Burdge, 11 wife by Deed from Galen S. A.pel and JeatlIlel:te A. Asper, his wife, by tl1eir attorJtey-in-fao, J bn McCrea Ill, aod Martin Humt wtd Mabel M. Hu[~l. hU8b~nd :md wife dated 101111992 and reea ded 10/~{I992 ill Deed Boole: Xl5 Page 612_ PROPERTY ADDRESS: 204 HICKORY LANE, SHIPPENSBURG, PA 17257 TAX PARCEL: # 36-35-2385-116 , (Rule of Civil Procedure No. 236) - Revis d IN THE COURT OF COMMON PLEAS OF CUMBERLAND CO NTY, PENNSYL VANIA CIVIL ACTION - LAW GE MORTGAGE SERVICES, LLC, F/KlA GE CAPITAL MORTGAGE SERVICES, INC. 3476 STATEVIEW BOULEVARD Plaintiff, v. GLENN E. BURDGE JANA G. BURDGE A/KlA JANE G. BURDGE Defendant(s). CUMBERLA D COUNTY COURT OF C MMON PLEAS CIVIL DIVISI NO. 2003-053 1 Notice is given that a Judgment in the above-captioned matter has been ent red against you on fYI ':VLc( ~-=l 200$. B If you have any questions concerning this matter, please contact: ~~ DANIEL G. SCHMIE Attorney for Plaintiff ONE PENN CENTER A 1617 JOHNF. KENNED BLVD., SUITE 1400 PHILADELPHIA, PA 1 103-1814 (215) 563-7000 **THIS F1RM lS A DEBT COLLECTOR ATTEMPTING TO COLLECT A DEBT OBT AlNED W1LL BE USED FOR THAT PURPOSE. IF YOU HAVE PREV10USL Y ECEIVED A D1SCHARGE IN BANKRUPTCY AND TH1S DEBT WAS NOT REAFF1RMED, THIS CORRESPOND NCE IS NOT AND SHOULD NOT BE CONSTRUED TO BE AN ATTEMPT TO COLLECT A DEBT, BUT ONLY NFORCEMENT OF A LIEN AGAINST PROPERTY. ** t fJ 0 ~ Tt ~ Ft:- C) (-) t-.,) t.., \) , ....:) ".,-1 ~ - J; ~ ....... \) :.-":' r- \ ~ - - C~) !.N ~ , ~ :b .,' -'~ \lJ' 0 ~ ~ ~ , - ','1 (J" <.. ,. ~ PRAECIPE FOR WRIT OF EXECUTION - (MORTGAGE ORECLOSURE) P.R.C.P.3180-3183 GE MORTGAGE SERVICES, LLC, F/K/A GE CAPITAL MORTGAGE SERVICES, INC. Plaintiff, v. No. 2003-05361 GLENN E. BURDGE JANA G. BURDGE A/K/A JANE G. BURDGE Defendant(s). TO THE DIRECTOR OF THE OFFICE OF THE PROTHONOTARY: Issue writ of execution in the above matter: Amount Due $97,44873 Interest from 3/2/05 to JUNE 8, 2005 (per diem -$16.02) $1,585 98 and Costs TOTAL $99,034.71 G DANIEL G. SCHMIEG, E Q IRE One Penn Center at Suburban tation 1617 John F. Kennedy Boulev rd, Suite 1400 Philadelphia, PA 19103-1814 Attorney for Plaintiff Note: Please attach description of property.No. IMPORTANT NOTICE: This property is sold at the di plaintiff. It may not be sold in the absence of a the plaintiff at the Sheriff's Sale. The sale mus stayed in the event that a representative of the p present at the sale. ection of the representative of be postponed or aintiff is not ~ ~... O~ ~? ~~ ~(/) 7< ~z ..,.~ ~;; 8~ ~~ Ou ~~ ~~ ~~ pt ~G Jj ~.... -- -o~ "':,z_ ""...... ~;::. ~ '".1''::<:' ',';_2('~,' 'c;f'L~ ".") (~,l.~ '--\0--- '-:)tl.' .1 -.c:. "-p p- O ,"" \ ~:i :~ ~6 (.;::;) ,-' ~ . (/) '.l~ ~.... U~ ~~ ~~ U....~ C' ~....u IO<~~ (/)0 ~'t <~ ~~ i:t<~ ~y IO<~ C J, ... ~ ~ i rj ~IO< ~~ ~~ .'.l IO<~ ~~ ~~ CQ ~ rj ~ ~ ,.., z S .... G ~'E IO<~ ~% o .., ~:. ~~ ~~ ~6 ~ u ~ ~ --Jin - :;; ':. -:: dr-1 - \ &. - :::. :::. - \J (\- p c:J \ \ I \ () :\:):)0 () (SVlOU:>. In ...:. ~ \-Ii ci- Ii _:-c- - W) ~ r-ti) ~... r-r- ........ ~~ ~~ ~~ Q~ ~(/) ~~ ~~ ~~ $~ (/)(/) ~~ \::: ~~ ~ ,..;l,..;l ,..~ ~O ~~ ur;::. $~ ~~ ...... ::: -;;; .- ~ '"' '<B -, :>-> e ~ < .;j <l) "" I"-< ~ <l) b if> <l) P '~ S if, if> <l) ~ ~ if> 'i) ~ p. <l) 'i) p ~ 1 Vl 11 --r -d r , '- - - -1 ..J) 0 0- rO - ~--i Q - -'J ;::) ~ "8 a 0) 1)-& - t>-i- -- ~ Q- 'v:r '" - .. LEGAL DESCRIPTION " ALL THAT CERTAIN crac! (If ground situatt in Sbippenshurg 70....Ollhi[l. CUluhcr Penns}'lvania, being improved with a single ra1llily dwelling house, llIId more particularly described as fllllowo; BEGINNING at a point on the Eastern ooge of HiCKOry Larn: at common corner of Lot N . t, Section "N', and Lor No.2, Section "N', as shown on Subdivi.it'll Plan for G & C Associates August ZO, 1991; IIconce alOng Lot No.1 South 35 degrees 511Jlinutc:i 53 sccond~ Ea~ 150.110 fo III ~ point; [hence along other lands now or formerly of Galen S. Asper Not1h 54 degrees 08 minI!: rJ78COOnds &o;t lll. 80 reet III a fXlin(; dlCllCC a1ool! a proposed public street North 35 degrees 5 J minute~ .53 ~eeonds We'l 115.00 feet Co a poilll.; thcllCC by a CUflie \(1 the left I11\vinj; a radiu~ or 3j.00 Eel, a chord bearing of Norlh SO deg.-ees 51 minure~ 53 seconds E;.u;t, an arc distance of 54.98 feel to n [JOint on the East.c:m edge of Hickory ullle; theJl~'" along the Easlt'rn edge of 11 ickory Lane South:; degreeg 0& miJ]UIcs 07 scconds West 76.80 feel to a point, 11lc point and place uf IkgiUl\iug. BEING all of Lot No. ~, Seclion "NO', on Subdi"i.iQn rlal\ for G & C ASSoclates dated August 20, 199] IllId reconkd in Cumberland County Plan Book 64, Page 60. TITLE TO SAID PREMISES IS VESTED IN Glenn E. Burdge and Jane G. Burdge, 11' wife b:; \)eed from Galen S. Asper and Jeanllelle k Asper, his wife, by their allorney-in-fact. J bn McCrea Ill, aoo Martin [{urnt arul Mabel M. H,,[~1. h,,~baw.l and wife dated IOilJ1991: and recol 10/.5/1992 ill Deed Book X35 Page 612. PROPERTY ADDRESSl 204 HICKORY LANE, SHIPPENSBURG, P A 17257 TAX PARCEL: # 36-35-238S-116 WRIT OF EXECUTION and/or ATTACHMENT COMMONWEALTH OF PENNSYL VANIA) COUNTY OF CUMBERLAND) NO 03-5361 ivil CIVIL CTION - LAW TO THE SHERIFF OF CUMBERLAND COUNTY: To satisfy the debt, interest and costs due GE MORTGAGE SERVICES, LLC, F/K/A GE CAPITAL MORTGAGE SERVICES, INC., Plaintiff(s) From GLENN E. BURDGE, JANA G. BURDGE, A/K/A JANE G. BURDGE (1) You are directed to levy upon the property of the defendant (s)and to sell SEE EGAL DESCRIPTION (2) You are also directed to attach the property of the defendam(s) not levied upon in he 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 prop rty of the defendant (s) or otherwise disposing thereof; (3) If property of the defendant(s) not levied upon an subject to attachment is found i the possession of anyone other than a named garnishee, you are directed to notify him/her that he/she s been added as a garnishee and is enjoined as above stated. Amount Due $97,448.73 L.L. $.50 Interest FROM 3/2/05 TO 6/8/05 (PER DIEM - $16.02) - $1,585.98 AND COSTS Atty's Comm % Due Prothy $1.00 Atty Paid $139.11 Other Costs Plaintiff Paid Date: MARCH 3, 2005 CURTIS R. LONG (Seal) By: Deputy REQUESTING PARTY: Name DANIEL G. SCHMIEG, 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. 62205 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 ATTORNEY FOR PLAINTIFF GE MORTGAGE SERVICES, LLC, FIK/A GE CAPITAL MORTGAGE SERVICES, INC. CUMBERLAN COUNTY COURT OF C MON PLEAS Plaintiff, v. CIVIL DIVISI GLENN E. BURDGE JANA G. BURDGE A/KIA JANE G. BURDGE NO. 2003-053 1 Defendant(s). CERTIFICATION DANIEL G. SCHMIEG, ESQUIRE, hereby verifies that he i attorney for the Plaintiff in the above-captioned matter, and that the premises are not subject to the pro isions 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 unsworn falsification to authorities. .....-.) ") c> _.,.', I C..:' ,(I C:) Request for Military Status Department of Defense Manpower Data Center Military Status Report Pursuant to the Servicemen's Civil Relief Act of 2003 -<Last Name First Middle Begin Date Active Duty Status GLENN Not on Active Duty BURDGE Page I of I MAR-01-200S 12:22:52 Servicel Agency Upon searching the information data banks of the Department of Defense M power Data Center, the above is the current status of the Defendant(s), per the Information provided, s to all branches of the Military. ~~U-~ Robert 1. Brandewie, Director Department of Defense - Manpower Data Center 1600 Wilson Blvd., Suite 400 Arlington, VA 22209-2593 The Defense Manpower Data Center (DMDC) is an organization of the Dep ment of Defense that maintains the Defense Emollment and Eligibility Reporting System (DEERS) atabase which is the official source of data on eligibility for military medical care and other eligibil ty systems. If you have information that makes you feel that the DMDC response is n t correct, please fax your response to 703-696-4156 or call 703-696-6762 and further research ill be done. For personal privacy reasons, SSNs are not available on this printed results p ge. Requesters submitting a SSN only receive verification that the SSN they submitted is match or non- match. https:llwww.dmdc.osd.mil/udpdri/owaJsscra.prc_Select 3/l/200S Request for Military Status Department of Defense Manpower Data Center Military Status Report Pursuant to the Servicemen's Civil Relief Act of 2003 <Last Name BURDGE First Middle Begin Date Active Duty Status JANE Page I ofl MAR-01-200512:23:44 Servicel Agency Currently not on Active Military Duty, based on the Social Security Number and last name provided. Upon searching the information data banks of the Department of Defense Ma power Data Center, the above is the current status of the Defendant(s), per the Information provided, s to all branches ofthe Military. ~WJ~O-~ Robert J. Brandewie, Director Department of Defense - Manpower Data Center 1600 Wilson Blvd., Suite 400 Arlington, V A 22209-2593 The Defense Manpower Data Center (DMDC) is an organization of the Depart ent of Defense that maintains the Defense Enrollment and Eligibility Reporting System (DEERS) atabase which is the official source of data on eligibility for military medical care and other eligibili systems. If you have information that makes you feel that the DMDC response is no correct, please fax your response to 703-696-4156 or call 703-696-6762 and further research w'll be done. For personal privacy reasons, SSNs are not available on this printed results pa e. Requesters submitting a SSN only receive verification that the SSN they submitted is a match or non- match. https:llwww.dmdc.osd.milludpdri/owalsscra.prc_Seiect 3/112005 GE MORTGAGE SERVICES, LLC, F/K/A GE , ~ CAPITAL MORTGAGE SERVICES, INC. Plaintiff, CUMBERLANO COUNTY COURT OF COMMON PLEAS CIVIL DIVISION NO. 2003-05361 v. GLENN E. BURDGE JANA G. BURDGE A/K1A JANE G. BURDGE Defendant(s). AFFIDAVIT PURSUANT TO RULE 3129 (Affidavit No. I) GE MORTGAGE SERVICES LLC F/K/A GE CAPITAL MORTGA E SERVICES INC., Plaintiff in the above action, by its attorney, DANIEL G. SCHMIEG, ESQ IRE, sets forth as of the date the Praecipe for the Writ of Execution was filed the following information oncerning the real property located at 204 HICKORY LANE, SHIPPENSBURG, P A 17257 . 1. Name and address of Owner(s) or reputed Owner(s): Name Last Known Address (if ad ress cannot be reasonably ascertained, pIe se indicate) GLENN E. BURDGE 204 HICKORY LANE SHIPPENSBURG, P A 17257 JANA G. BURDGE A1K/A JANE G. BURDGE 204 HICKORY LANE SHIPPENSBURG, P A 7257 2. Name and address of Defendant(s) in the judgment: Same as above 3. Name and last known address of every judgment creditor whose judgm t is a record lien on the real property to be sold: Name Last Known Address (if ddress cannot be reasonably ascertained, p ease indicate) None 4. Name and address of last recorded holder of every mortgage of record: I i Name Last Known Address (iflddress cannot be reasonably ascertained, [lease indicate) ! ALL FIRST BANK SOUTH CHARLES S REET BALTIMORE, MD 2 201 5. Name and address of every other person who has any record lien on t e property: Name Last Known Address C f address cannot be reasonably ascertained please indicate) None 6. Name and address of every other person who has any record interest 'n the property and whose interest may be affected by the sale. Name Last Known Address (if address cannot be reasonably ascertain ,please indicate) None 7. Name and address of every other person of whom the plaintiff has nowledge who has any interest in the property which may be affected by the sale: Name Last Known Addre (if address cannot be reasonablyascertai ed, please indicate) Tenant/Occupant 204 HICKORY L SHIPPENSBUR Domestic Relations of Cumberland County 13 North Hanove Street Carlisle, PA 1701 Commonwealth of Pennsylvania Department of Welfare PO Box 2675 Harrisburg, P A 71 05 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 state ents herein are made subject to the penalties ofl8 Pa. C.S. Sec. 4904 relating to unsworn falsification authorities. March 1. 2005 DATE SQUIRE (-', r--.) -'~ _:,- <"A'. r'-, en " ~ GE MORTGAGE SERVICES, LLC, F/K/A GE CAPITAL MORTGAGE SERVICES, INC. Plaintiff, CUMBERL No. 2003-QS36 v. GLENN E. BURDGE JANA G. BURDGE A/K/A JANE G. BURDGE Defendant(s). March 1,2005 TO: GLENN E. BURDGE 204 HICKORY LANE SHIPPENSBURG, PA 17257 JANA G. BURDGE KIA JANE G. BURDGE 204 HICKORY LAN SHIPPENSBURG, P 17257 "THIS FIRM IS A DEBT COLLECTOR ATTEMPTING TO COLLECT A DEBT ND ANY INFORM A T/ON OBTAINED WILL BE USED FOR THAT PURPOSE IF YOU HAVE PREVIOUSLY REC lVED A DISCHARGE iN BANKRUPTCY AND THIS DEBT WAS NOT REAFFiRMED, THIS IS NOT AND SHOUL NOT BE CONSTRUED TO BE AN ATTEMPT TO COLLECT A DEBT, BUT ONLY ENFORCEMENT OF A LIEN AGAi T PROPERTY. *. Your house (real estate) at 204 HICKORY LANE SHIPPENSB RG PA 17257 is scheduled to be sold at the Sheriff's Sale on JUNE 8,2005 at 10:00 a.m. in he Cumberland County Courthouse, South Hanover Street, Carlisle, PA 17013, to enforce the court 'udgment of $97,448.73 obtained by GE MORTGAGE SERVICES LLC FIKlA GE CAPITAL MORTGAGE SERVICES INC. (the mortgagee) against you. In the event the sale is continued, an an ouncement will be made at said sale in compliance with Pa.R.CP., Rule 3129.3. NOTICE OF OWNER'S RIGHTS YOU MAY BE ABLE TO PREVENT THIS SHERIFF'S SALE To prevent this Sheriff's Sale, you must take immediate action: L The sale will be cancelled if you pay to the mortgagee the ba k payments, late charges, costs and reasonable attorney's fees due. To find out how m ch you must pay, you may call: (215) 563-7000. 2. You may be able to stop the sale by filing a petition asking th 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 pro eedings. -. 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 Y U HAVE OTHER RIGHTS EVEN IF THE SHERIFF'S SALE DOES TAKE PLACE. 1. Ifthe Sheriffs Sale is not stopped, your property will be sold to t e 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 id price was grossly inadequate compared to the value of your property. 3. The sale will go through only ifthe buyer pays the Sheriff the ful 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 ill 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 our house. A schedule of distribution ofthe money bid for your house will be filed by the Sheriff wit in 30 days of the sale. This schedule will state who will be receiving that money. The money will be p . d out in accordance with this schedule unless exceptions (reasons why the proposed distribution is wr ng) 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 our 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 pi intiff. 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 i not present at the sale. CUMBERLAND COUNTY ATTORNEY REFE L CUMBERLAND COUNTY BAR ASSOCIATI N 2 LIBERTY AVENUE CUMBERLAND COUNTY COURTHOUSE CARLISLE, PA 17013 (717) 249-3166 (800) 990-9108 .. LEGAL DESCRIPTION " .' ALL THAT CERTAIN [raCI of ground situan: in Sbippensburg lowIlllhip, Cumber Pe~yl'lllI\i3, being improved with a single rarolly dwelling house, llJId more partkuJllrly described as follow,;; BEGINNING at a pom! on the Eastern odge of HiCKory Lane at <;ommon corner of Lot N . 1, Secuorl "N', aoo un N[). 2, Sec.tirJII "N', as shown on Subdivisiol} Plan lOr G & C Associates August 20, 1991; tllcnce along Lot No.1 Sooth 35 degree~ 51nllnutc:5 53 sccondl; BiN 150.00 fI ill a poim; thence along other land& now or formerly of Galen S. Asper NOI1h 54 degrees 08 minu 07 se<<>rnls Ea'it 1l1.80 reet 10 a fOmt; melICe 1l1()l]l! a proposed public Blreet North 35 degrees 51 mirnttes 53 ~eeoncts WeSI 115.00 feet to a poil1t; thence by a curve \0 the left ha"ins a Jadiu~ of 35.00 , a dmrd bearing of North 80 degrees 51 minutes ~3 seconds &t, an arc distance of 54.98 feel to n point on die Ealitcm ooge or Hkkory Lane; thence' along the Eastertl edge of lHckQry Lane South 5 degrees 08 minules 07 seconds West 76.80 feel to a point, the point and pla~t "f Bcgilll1illg. BEING all of Lot No. ~, Section "N". on Subdivi~iQn P\;ll\ foc G & C AssocJates dated August 2iJ, J 99J !llld rewrucd in Cumber] and COlJJ1ty PllIu Book 64, Page 60. TITLE TO SAID PREMISES IS VESTED IN Glenn E. Burdge and Jane G. Burdge,l1 wife b:; Deed from GaI..ll S. Asper and J~lt)nette Ac Asper, his wife, by their attorney-ilI.fact, J MCCrea Ill, aocl Martin Hurst arul Mabel M. Hunt, hu~b~nd lIllI1 wife dated 101111992 and recor 101511'}92 In Deed Book X35 Page 612. PROPERTY ADDRESS: 204 HICKORY LANE, SHIPPENSBURG, PA 17257 TAX PARCEL: # 36-35-2385-116 ,-.., . '~':) .::,;:) e..... >,--; , (...) ,'t) (.:."\ Cl ~n :.,; i-';" ~T": "'i-'.,: ~I-! \.1, , . <. '. iII FEDERMAN PHELAN IS NOW PHELAN HALLINAN & SCHMIEG By: DANIEL G. SCHMIEG, ESQUIRE IDENTIFICA nON NO. 62205 ATTORNEY FOR PLAINTIFF ONE PENN CENTER AT SUBURBAN STATION 1617 JOHN F. KENNEDY BOULEVARD, SUITE 1400 PHILADELPHIA, PA 19103-1814 (215) 563-7000 GE MORTGA:GE SERVICES, LLC, F/K/A GE CAPITAL MORTGAGE SERVICES,INC. 3476 STATE VIEW BOULEVARD FORT MILL, SC 29715 v. CUMBERLAND COUNTY COURT OF COMMON PLEAS CIVIL DIVISION NO.: 2003-05361 GLENN E. BURDGE JANA G. BURDGE AlK/A JANE G. BURDGE 204 HICKORY LANE SHIPPENSBURG, PA 17257 PRAECIPE TO MARK JUDGMENT TO USE PLAINTIFF TO THE PROTHONOTARY: Please mark the judgment in the above captioned matter to the use of WELLS FARGO BANK. N.A., 1 HOME CAMPUS. DES MOINES. IA 50328. Co_ DANIEL G. SCHMIEG, E Attorney for Plaintiff Date: May 10, 2005 ENTRY OF APPEARANCE TO THE PROTHONOTARY: Kindly enter my appearance on behalf of WELLS FARGO BANK. N.A., USE PLAINTIFF. ~J~~ DANIEL G. SCHMIEG" - Attorney for Plaintiff Date: May 10, 2005 ::D (:) ~ It ~ (~ 0 -'I'; '-_.-, "'- --L () - ~ w .IU -u -.0 (i"- F -- t '-..t::: C") ,;1' E ~ f- ~ , IN THE COURT OF COMMON PLEAS OF CUMBERLAND COUNTY, PENNSYLVANIA GE MORTGAGE SERVICES, LLC, F/KIA GE CAPITAL MORTGAGE SERVICES, me. ) CIVIL ACTION ) vs. ) CIVIL DIVISION ) NO. 2003-05361 GLENN E. BURDGE JANA G. BURDGE NK/ A JANE G. BURDGE AFFIDAVIT OF SERVICE PURSUANT TO RULE 3129 COMMONWEALTH OF PENNSYLVANIA COUNTY OF CUMBERLAND ) ) SS: I, DANIEL SCHMIEG, ESQUIRE attorney for GE MORTGAGE SERVICES, LLc, FIKlA GE CAPITAL MORTGAGE SERVICES, INC. hereby verify that on March 9, 2005 true and correct copies of the Notice of Sheriffs sale were served by certificate of mailing to the recorded lienholders, and any known interested party see Exhibit "A" attached hereto. ~~(y D NIEL G. SCHMIE@,-ES( IRE Attorney for Plaintiff ~ DATE: Mav 10, 2005 GE MORTGAGE SERVICES, LLC, F/KJA GE CAPITAL MORTGAGE SERVICES, INC. CUMBERLAND COUNTY Plaintiff, COURT OF COMMON PLEAS v. CIVIL DIVISION GLENN E. BURDGE JANA G. BURDGE A!KIA JANE G. BURDGE NO. 2003-05361 Defendant(s). AFFIDAVIT PURSUANT TO RULE 3129 (Affidavit No. I) GE MORTGAGE SERVICES. LLC. FIKIA GE CAPITAL MORTGAGE SERVICES. INC., Plaintiff in the above action, by its attorney, DANIEL G. SCHMIEG, ESQUIRE, sets forth as ofthe date the Praecipe for the Writ of Execution was filed the following information concerning the real property located at 204 HICKORY LANE. SHlPPENSBURG. PA 17257. 1. Name and address of Owner(s) or reputed Owner(s): Name Last Known Address (if address cannot be reasonably ascertained, please indicate) GLENN E. BURDGE 204 HICKORY LANE SHIPPENSBURG, PA 17257 JANA G. BURDGE AlKfA JANE G. BURDGE 204 HICKORY LANE SHIPPENSBURG, PA 17257 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) ALL FIRST BANK SOUTH CHARLES STREET BALTIMORE, MD 21201 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 204 HICKORY LANE SHIPPENSBURG, PA 17257 ; 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 ofl8 Pa. C.S. Sec. 4904 relating to unsworn falsification to authorities. March I, 2005 DATE ~ G ~r~1 DANIEL G. SCHMIEG, SQUIRE Attorney for Plaintiff ",-< 0 g-~ - - - - - - r< ..., " - v. ... '" 00 g' . Z '" N - 0 -.l ~ V. ... '" N - rJJ H g ~" ".. "," ~ ~8, ~ 'fI ~ n CO Z c: :1 cr .. ... ,,-' 0 '"<:l- B,€. ';;j ~ -l () Cl z =,,'" ~ ~ ~ . _. - < z 9 .,-.l ~3 ~ " '" ~ '" ft''O -~ ~ t" 1:- "," ('1 ~ >B"-g g' ~ ~ _8, . ~cn 0'" ~ g n . g.; ~' to ~ a t" ~ ~ '"<:l';": ~ ~ ;J> "' ;~ ~ ~ ~ ~ ~ ~ r N . o~ v. ~ ~ rf> .. 'fo:l 2 tv '" rf> ~ -0 0 ~ 0 0 00", @ ... .--.~ trt'" \'5 '" ~ ""'< .ijg l ~ rf> % ,. ",e; o~ ~ ~ ~p ~ . " g" ~ . .. r/) ~r ~ E- ~ -< ~ ~ ...,,; Z tn r< .. - ~ ~ '" ~ i ~ Q, ~ Cl 0 " rf> m () .., ~ ~ \ ~ @ " ~ to '" ~ ~ ~ rf> ~ - i'I~f.-~i( '" 8~70'a ~ 0 Z 1n~s:l(\'€ 9 '" 0 ::9. 6 ~ c;: :oS 8 ....~llOg~ '" '" .... \1. e ;J> f\ ::> )I.~' '" "'s' 2. g.~ - '" ~ ~a~6g' N -l ~ N ;[~g? - v. N -.l "~o~. 0 ~ g -"g~ ~ - '" s~ g. (i;- 0 g.-g ~ ~'d to ?:l ~~ g (i'~ 0 ~ ~~~g~ ~ x o .'g ~ 0 N < ~ 0 :') ~~~::l~ t'JO.~ -!!n" Y' :-J <8if~o ~ ('] "a'~ -l % a ~.mR t>1 ~.%i ~ ~ ,,3 ~ rf> tn s.-" a' to ~ a:$..S N a" ~il ~ .,3 ~o, '" -;~. g ~ ;J> 0" \- '" - />~~ ...~ it -.l ~.~ ...~. >- 0 SoA"f!(; - - l ~gg3 -l '" g. mg p, - ~H~ 0 v. a" ~ ~r ~ . --I c'. Ha" . .' ~ '" a "" .....-.. <, . . ~ ~ ~, ~a&~ _ .\..v~'~-"'-""< <II g ....E . {;!~ II '"ddZ~1 ~g.:"a \l-~ :z I~ .....- ~ ~ 0" . -;\ .-:=-'~ ~ .0' > \ ~''8g PUNEY BOWE~ 0';;' :::. . : g5o~~oom t01.200 ~~ 8~ ~~"g ~ e-to''; ~ \ ; MAlLED FROM ZIP C~;E9 1 ~ ~ ~; ::> ;::;.tl> \ \ ~ ~ ~ \ \ \ \ \ \ \ \ II , ;J>Z ".... ~~ ~ ~ ".. 2~ " tl1 '"<:lr< g~ n::I: ~p ... r< ~Z ~~ Ei ~ ~~ jq';I; ~~ grn 9 r< r :-0 ('-) -" ....-,.~ ",.~ -- ...'" ,.... c....) ,._......._.---~ - GE Mortgage Services, LLC flkJa GE Capital Mortgage Services, Inc. VS Glenn E. Burdge and Jana G. Burdge alk!a Jane G. Burdge In The Court of Common Pleas of Cwnberland County, Pennsylvania Writ No. 2003-5361 Civil Term Ron Hoover, Deputy Sheriff, who being duly sworn according to law, states that on March 10,2005 at 10:50 o'clock PM, he served a true copy of the within Real Estate Writ, Notice of Sheriffs Sale and Description, in the above entitled action, upon the within named defendants, to wit: Glenn E. Burdge and Jana G. Burdge alk!a Jane G. Burdge, by making known unto Allison Burdge, adult daughter of Glenn E. Burdge and Jana G. Burdge, at 204 Hickory Lane, Shippensburg, Cwnberland County, Pennsylvania, its contents and at the same time handing to her personally the said true and correct copy ofthe same. cpt Michael Barrick, Deputy Sheriff, who being duly sworn according to law, states that on April 14, 2005 at 6:27 o'clock P.M., he posted a true copy of the within Real Estate Writ, Notice, Poster and Description, in the above entitled action, upon the property of Glenn E. Burdge and Jana G. Burdge alk!a Jane G. Burdge located at 204 Hickory Lane, Shippensburg, 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 mailed a notice of the pendency of the action to the within named defendants, to wit: Glenn E. Burdge and Jana G. Burdge alk!a Jane G. Burdge, by regular mail to their last known address of204 Hickory Lane, Shippensburg, PA 17257. These letters were mailed under the date of April 18, 2005 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 instructions from Attorney Daniel Schmieg. Sheriffs Costs: Docketing Poundage Posting Bills Advertising Law Library Prothonotary Mileage Certified Mail Levy 30.00 15.78 15.00 15.00 .50 1.00 29.60 7.03 15.00 , I)>"'V Ck {'tJo;7 r-J .. _..... L~.- Surcharge Postage Law Journal Patriot News Share of Bills 30.00 .74 321.20 307.27 16.47 $804.59 sworn:d sUbscribe~ to before me S~~,. "'It ~'" This i!L..- day of, !v.~ R: Thomas 'tiine, She!ff"-" ~ 2005, A.D. . [J rn-llfh' , ~'BY 0" Pr th notary Real Es . GE MORTGAGE SERVICES, LLC, F/KIA GE CAPITAL MORTGAGE SERVICES, INC. CUMBERLAND COUNTY Plaintiff, COURT OF COMMON PLEAS v. CIVIL DIVISION GLENN E. BURDGE JANA G. BURDGE A/KJA JANE G. BURDGE NO. 2003-05361 Defendant(s). AFFIDAVIT PURSUANT TO RULE 3129 (Affidavit No. I) GE MORTGAGE SERVICES. LLC, FIKJA GE CAPITAL MORTGAGE SERVICES. INC., 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 204 HICKORY LANE. SHIPPENSBURG. P A 17257 . 1. Name and address ofOwner(s) or reputed Owner(s): Name Last Known Address (if address cannot be reasonably ascertained, please indicate) GLENN E. BURDGE 204 HICKORY LANE SHIPPENSBURG, P A 17257 JANA G. BURDGE A/KJA JANE G. BURDGE 204 HICKORY LANE SHIPPENSBURG, P A 17257 2. Name and address ofDefendant(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 oflast recorded holder of every mortgage ofrecord: Name Last Known Address (if address cannot be reasonably ascertained, please indicate) ALL FIRST BANK SOUTH CHARLES STREET BALTIMORE, MD 21201 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 204 HICKORY LANE SHIPPENSBURG, P A 17257 Domestic Relations of Cumberland County 13 North Hanover Street Carlisle, P A 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 ofl8 Pa. C.S. Sec. 4904 relating to unsworn falsification to authorities. March 1. 2005 DATE ~ G ~r~ DANIEL G. SCHMIEG, SQUIRE Attorney for Plaintiff , . GE MORTGAGE SERVICES, LLC, FfKJA GE CAPITAL MORTGAGE SERVICES, INC. Plaintiff, CUMBERLAND COUNTY No. 2003-05361 v. GLENN E. BURDGE JANA G. BURDGE AfKfA JANE G. BURDGE Defendant(s). March I, 2005 TO: GLENN E. BURDGE 204 HICKORY LANE SHIPPENSBURG, P A 17257 JANA G. BURDGE AiKlA JANE G. BURDGE 204 HICKORY LANE SHIPPENSBURG, PA 17257 **THIS FIRM IS A DEBT COLLECTOR ATTEMPTING TO COLLECT A DEBT AND ANY INFORMATION OBTAINED WILL BE USED FOR THAT PURPOSE. IF YOU HA VE PREVIOUSLY RECEIVED A DISCHARGE IN BANKRUPTCY AND THIS DEBT WAS NOT REAFFIRMED, THIS IS NOT AND SHOULD NOT BE CONSTRUED TO BE AN A TTEMPT TO COLLECT A DEBT, BUT ONL Y ENFORCEMENT OF A LIEN AGAINST PROPERTY. .. Your house (real estate) at. 204 HICKORY LANE. SHIPPENSBURG. PA 17257, is scheduled to be sold at the Sheriffs Sale on JUNE 8, 2005 at 10:00 a.m. in the Cumberland County Courthouse, South Hanover Street, Carlisle, PA 17013, to enforce the court judgment of $97,448.73 obtained by GE MORTGAGE SERVICES. LLC, FIKlA GE CAPITAL MORTGAGE SERVICES. INC. (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 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. lfthe Sheriffs Sale is not stopped, your property will be sold to the highest bidder. You may find out the price bid by calling (215) 563-7000. 2. You may be able to petition the Court to set aside the sale if the bid price was grossly inadequate compared to the value of your property. 3. The sale will go through only if the buyer pays the Sheriff the full amount due in the sale. To find out if this has happened, you may call (717) 240-6390. 4. If the amount due from the Buyer is not paid to the Sheriff, you will remain the owner of the property as if the sale never happened. 5. You have the right to remain in the property until the full amount due is paid to the Sheriff and the Sheriff gives a deed to the buyer. At that time, the buyer may bring legal proceedings to evict you. 6. You may be entitled to a share of the money which was paid for your house. A schedule of distribution of the money bid for your house will be filed by the Sheriff within 30 days of the sale. This schedule will state who will be receiving that money. The money will be paid out in accordance with this schedule unless exceptions (reasons why the proposed distribution is wrong) are filed with the Sheriff within ten (10) days after the distribution is filed. 7. You may also have other rights and defenses, or ways of getting your home back, if you act immediately after the sale. YOU SHOULD TAKE THIS PAPER TO YOUR LAWYER AT ONCE. IF YOU DO NOT HAVE A LAWYER OR CANNOT AFFORD ONE, GO TO OR TELEPHONE THE OFFICE LISTED BELOW TO FIND OUT WHERE YOU CAN GET LEGAL HELP. 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 ASSOCIA TlON 2 LIBERTY A VENUE CUMBERLAND COUNTY COURTHOUSE CARLISLE, P A 17013 (717) 249-3166 (800) 990-9108 . , LEGAL DESCRIPTION ALL THAT CERTAIN tract of JJoumf mtualI: in Sbip~nsburg lowmhip. Cllmbcrlarld ('.oU:nty, PenDliyll/ania, beillg improvcm with a Gingle ramlly dwding house, lIIId more particularly ooumfed l\lld described a5 folkiw.s; BEGINNJNG at a point on ll1e Eastern odge of HiGkory LaIl1' Ilt common corner of Lot No.1, Scc6.on "1'1'. and Lot No.2. Section "N' , as sJrown on SllbdMsiflll Pbll fot G & C Associates dartd )\uJ!lld 20, 1991; thence alOng Lot No.1 South ~S degrees 51 minute:; 53 seconds 6a:;t 1.50.00 feet \l) a point; tIlencc along other land$ MW or fOlmerly of Galen S. Asper North 54 degreo$ 08 m.in\l.1!:S 07 scwnm &:>t 1l1.80 feet to a p.liot; dlcJlCe aloog a proposed public slf~t North 3S c1egrees 51 mirmte~ 53 ~econds West 115.00 feel to II poibl.: thcm:c by 1I curve 10 the left baving a radiu~ Df35.00 feet, a chord bearing of Norll1 80 degrees j 1 minutes.53 seconds &t, an Ilrc distance of 54.98 l'ee11o II point on the Eastern edge or Hickory Lane; lllenee along the Elstem edge of II ickoIY Lane South 54 degree~ 08 millule; 07 seconds West 76.80 feet 10 a point, the point and place: of BcgiDJ1iug. BEING all of Lot No.2, See/Jon "N", on Sulxlivision P!:lll for G & C Associates dared August 20, 199J WJd r~wrucd in (.'umberJand Coonty Phlll Buok 64, Page 60. JITlL TO SAID PREMISES IS 'v'ESlED IN Glenn f" Burdge and Jane G. Burdge, bi:! wife by Dero from Galen S. Asper and Je:armel1e A. Asper, his wife, by tbeir aJ[orncy.in.fact, John McCrea Ill, .00 MartiD Humt rmd Mabel M. RlInt. hu~b~m1llDd wife dated IOll/lm alld recorded 101~11991 in Deed Book X35 Page 612. PROPERTY ADDRESS: 204 HICKORY LANE, SHIPPENSBURG, PA 17257 TAX PARCEL: # 36-35.2385-116 WRIT OF EXECUTION andlor ATTACHMENT COMMONWEALTH OF PENNSYL VANIA) COUNTY OF CUMBERLAND) NO 03-5361 Civil CIVIL ACTION - LAW TO THE SHERIFF OF CUMBERLAND COUNTY: To satisfy the debt, interest and costs due GE MORTGAGE SERVICES, LLC, F/KJA GE CAPITAL MORTGAGE SERVICES, INC., Plaintiff (s) From GLENN E. BURDGE, JANA G. BURDGE, AlK/A JANE G. BURDGE (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 ofthe 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 himlher that helshe has been added as a garnishee and is enjoined as above stated. Amount Due $97,448.73 L.L. $.50 Interest FROM 3/2/05 TO 6/8/05 (PER DIEM - $16.02) - $1,585.98 AND COSTS Atty's Corom % Due Prothy $1.00 Atty Paid $139.11 Other Costs Plaintiff Paid Date: MARCH 3, 2005 CURTIS R. LONG , (Seal) Prothonotary em '-.]3y: 0rv..g _9 / {r'/VV1.; Deputy REQUESTING PARTY: Name DANIEL G. SCHMIEG, 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 lD No. 62205 <t "-0- U-_ ->. 0:::..... w. :r:~: U1C: Wt ::CC'" 1-- w_ "'::" 0- LJ..1c.::': U~.-. ~,\ ~~i '--' Real Estate Sale #31 On March 09, 2005 the Sherifflevied upon the defendant's interest in the real property situated in Shippensburg Township, Cumberland County, P A Known and numbered as 204 Hickory Lane, Shippensburg, more fully described on Exhibit "A" filed with this writ and by this reference incorporated herein. Date: March 09, 2005 co =r- M ByJO cL.{ Jwih Real Estate Deputy 6;> ~ c:::;:j G!) &tilO Q 00 I ex: <<: :E Ln = = ~ . > 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 pnblisher 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 andlor Sunday! Metro editions which appeared on the 26th day(s) of April and the 3rd and lOth day(s) of May 2005. 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 Mis ellaneous Book "M", Volume 14, Page 317. COpy S ALE #31 Sworn to an PUBLICATION CUMBERLAND COUNTY SHERIFFS OFFICE CUMBERLAND COUNTY COURTHOUSE CARLISLE, PA 17013 . Statement of Advertising Costs . To THE PATRIOT-NEWS CO. For publishing the notice or publication attached hereto on the above stated dates 307.27 Publisher's Receipt for Advertising Cost The Patriot News Co., publisher of The Patriot-News and The Sunday Patriot-News, newspapers of general circulation, hereby acknowledge receipt of the aforesaid notice and publication costs and certifies that the same have been duly paid. By.................................................................... , - REAL.:"~~~l ae:=-=u.c .,. .. . .. , . ,-IT , Inc. V. GIIlnn E. 8unIOt lInd -G.!IUJ!llIlI llIIrIa"'6. .... Au,:~rll L~. 1I1111AIPTJON in..~~b.~c:;, Famsy!-il.btioIf'-"'" widt a.. family dweIIiIc bouse. .. _ pmtieuIarIy bouaded 8IIlIdeiaiIIed.~.. BEGINNING.. a poiat..1bo Ea=n ed8e ofllicQoy Laoe.. __ of Lot 110.1. Scctioo"ll"._ Lot 1Io.~. Scctioo "N".. _.. ~ 1'1III bG &: CAaociafes -AIlIlUII 711. 199\; lIleii:e oIoog Lot 110. 1 . Soodl 3S ....... 51 ....... 53 _ East 15000 r... to a.,'jIoiDI; lbeoce oIoog__ -"'ftJJood!'orQlll=S.. _ 54 ....OIl~!!_llastl11JlOr...tO apoiat;lbeoce_apqlOllOClpol!lii:_ _35 .... 5l1llim!la 53 ....... ""'" l15oor...",.poiI;_bya_1l1bo1eft having'llIlIin! "'. 35. OOr...,a _ belaiDg. of North IKldegnios51.....53IOC!1ll1sEast... lIlCdiJlaoceof54.9tr...llapoilll..lbo_ edge of'lIi<tcrY'-lboDI:e a!ol!Jlbo_ edge of IIicIay Laoe Soodl 54 degn!os.1I8 _~_"""'76J10r...",.pOim.1bo point and pia<< oflQ!(llNNlNG.. BEING aD ......110. 2. Scctioo"ll"... sul>divisiolll'llllb\G-&:CAssociaIes_ August 20. 199=.1' '""" r in Cumbedand C-YPlall_ 60.' TI1Ul TO . . ~ vesIod in Glonn E. BunIge and lI!MI O.IluoIF. bis wile. by Deed Iiom 0aIeII S. ^"" and_ A. Asper. bis wiIe.bylboiJ~;lciIml<<lum. and _ HooiI.,.l)/abd 1(........ bushand 8IIlIwiIe._...OII)J!IIl..........w.I..10151 1992 iDDee4:&eci." _,,~ IIOI'IItVi JIlIlld<cry Lane. ,....TAX7J.\ _.~5-116... 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, V1Z: April 15,22,29,2005 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 charact~r of publication are true. ditor TO AND SUBSCRIBED before me this day of April NOT I SEAL LOIS E. SNvoeR. Notary Public ClIIlisla 8010. Cumberland County My Commission Expires March 5, 2009 REAL ESTATE SALE NO. 31 Wrtt No. 2003-5361 CMl GE Mortgage Services, LLC, f/k/a GE Capital Mortgage Services, Inc. VB. Glenn E. Burdge and Jana G. Burdge aJk/a Jane G. Burdge Atty.: Daniel Schmieg LEGAL DESCRIPTION ALL THAT CERTAIN tract of ground situate in Shippensburg Township. Cumberland County, Pennsylvania. being improved with a single family dwelling house, and more particularly bounded and de- scribed as follows: BEGINNING at a point on the Eastern edge of Hickory Lane at common comer of Lot No. 1, Sec- tion "N" and Lot No.2, Section "N", as shown on Subdivision Plan for G & C Associates dated August 20, 1991; thence along Lot. No.1 South 35 degrees 51 minutes 53 seconds East 150.00 feet to a point; thence along other lands now or formerly of Galen S. Asper North 54 degrees 08 minutes 07 seconds East 111.80 feet to a point: thence along a pro. posed public street North 35 de- grees 51 minutes 53 seconds West 115.00 feet to a point: thence by a cutve to the left. having a radius of 35.00 feet. a chord hearing of North 80 degrees 51 minutes, 53 seconds East. an arc distance of 54.98 feet to a point on the Eastern edge of Hickory Lane; thence along the Eastern edge of Hickory Lane South 54 degrees 08 minutes 07 seconds West 76.80 feet to a point. the point and place of Beginning. BEING all of Lot No.2. Section "N". on Subdivision Plan for G & C Associates dated August 20. 1991 and recorded in Cumberland County Plan Book 64. Page 60. TITLE TO SAID PREMISES IS VESTED IN Glenn E. Burdge and Jane G. Burdge. his wife by Deed from Galen S. Asper and Jeannette A. Asper, his wife, by their attor- ney-in-fact, John McCrea Ill, and Martin Hurst and Mabel M. Hurst. husband and wife dated 10/1/ 1992 and recorded 10/5/1992 in Deed Book X35 Page 612. PROPERTY ADDRESS: 204 HICKORY LANE. SHIPPENSBURG. PA 17257. TAX PARCEL: #36-35-2385-116. "-."