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HomeMy WebLinkAbout03-6255FEDERMAN AND PHELAN, LLP By: FRANK FEDERMAN, ESQ., Id. No. 12248 LAWRENCE T. PHELAN, ESQ., Id. No. 32227 FRANCIS S. HALL1NAN, ESQ., Id. No. 62695 ONE PENN CENTER PLAZA, SUITE 1400 PHILADELPHIA, PA 19103 (215) 563-7000 ATTORNEY FOR PLAINT~F SFJV-2002-1, LLC 7495 NEW HORIZON WAY FREDERICK, MD 21703-8388 COURT OF COMMON PLEAS CIVIL DIVISION Plaintiff ERIC A. BISHOP 113 NORTH BALTIMORE AVENUE MOUNT HOLLY SPRINGS, PA 17065 TERM CUMBERLAND COUNTY AMY M. BISHOP 113 NORTH BALTIMORE AVENUE MOUNT HOLLY SPRINGS, PA 17065 Defendant(s) CIVIL ACTION - LAW 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 ELIG1BLE PERSONS AT A REDUCED FEE OR NO FEE. CUMBERLAND COUNTY CUMBERLAND COUNTY BAR ASSOCIATION 2 LIBERTY AVENUE CARLISLE, PA 17013 (717) 249-3166 File #: 83248 IF THIS IS THE FIRST NOTICE THAT YOU HAVE RECEIVED FROM THIS OFIqCE, BE ADVISED THAT: PURSUANT TO THE FAIR DEBT COLLECTION PRACTICES ACT, 15 U.S.C. § 1692 et seq. (1977), DEFENDANT(S) MAY DISPUTE THE VALIDITY OF THE DEBT OR ANY PORTION THEREOF. IF DEFENDANT(S) DO SO IN WRITING WITHIN THIRTY (30) DAYS OF RECEIPT OF THIS PLEADING, COUNSEL FOR PLAINTIFF WILL OBTAIN AND PROVIDE DEFENDANT(S) WITH WRITTEN VERIFICATION THEREOF; OTHERWISE, THE DEBT WILL BE ASSUMED TO BE VALID. LIKEWISE, IF REQUESTED WITHIN THIRTY (30) DAYS OF RECEIPT OF THIS PLEADING, COUNSEL FOR PLAINTIFF WILL SEND DEFENDANT(S) THE NAME AND ADDRESS OF THE ORIGINAL CREDITOR, IF DIFFERENT FROM ABOVE. THE LAW DOES NOT REQUIRE US TO WAIT UNTIL THE END OF THE THIRTY (30) DAY PERIOD FOLLOWING FIRST CONTACT WITH YOU BEFORE SUING YOU TO COLLECT THIS DEBT. EVEN THOUGH THE LAW PROVIDES THAT YOUR ANSWER TO THIS COMPLAINT IS TO BE FILED IN THIS ACTION WITHIN TWENTY (20) DAYS, YOU MAY OBTAIN AN EXTENSION OF THAT TIME. FURTHERMORE, NO REQUEST WILL BE MADE TO THE COURT FOR A JUDGMENT UNTIL THE EXPIRATION OF THIRTY (30) DAYS AFTER YOU HAVE RECEIVED THIS COMPLAINT. HOWEVER, IF YOU REQUEST PROOF OF THE DEBT OR THE NAME AND ADDRESS OF THE ORIGINAL CREDITOR WITHIN THE THIRTY (30) DAY PERIOD THAT BEGINS UPON YOUR RECEIPT OF THIS COMPLAINT, THE LAW REQUIRES US TO CEASE OUR EFFORTS (THROUGH LITIGATION OR OTHERWISE) TO COLLECT THE DEBT UNTIL WE MAIL THE REQUESTED INFORMATION TO YOU. YOU SHOULD CONSULT AN ATTORNEY FOR ADVICE CONCERNING YOUR RIGHTS AND OBLIGATIONS IN THIS SUIT. IF YOU HAVE FILED BANKRUPTCY AND RECEIVED A DISCHARGE, THIS IS NOT AN ATTEMPT TO COLLECT A DEBT. IT IS AN ACTION TO ENFORECE A LIEN ON REAL ESTATE. File #: 83248 Plaintiff is SFJV-2002-1, LLC 7495 NEW HORIZON WAY FREDERICK, MD 21703-8388 The name(s) and last known address(es) of the Defendant(s) are: ERIC A. BISHOP 113 NORTH BALTIMORE AVENUE MOUNT HOLLY SPRINGS, PA 17065 AMY M. BISHOP 113 NORTH BALTIMORE AVENUE MOUNT HOLLY SPRINGS, PA 17065 who is/are the mortgagor(s) and real owner(s) of the property hereinafter described. On 07/29/1999 mortgagor(s) made, executed and delivered a mortgage upon the premises hereinafter described to PHIl MORTGAGE SERVICE CORPORATION which mortgage is recorded in the Office of the Recorder of CUMBERLAND County, in Mortgage Book No. 1561, Page 115. PLAINTIEF is now the legal owner of the mortgage and is in the process of formalizing an assignment of same. The premises subject to said mortgage is described as attached. The mortgage is in default because monthly payments of principal and interest upon said mortgage due 03/01/2003 and each month thereafter are due and unpaid, and by the terms of said mortgage, upon failure of mortgagor to make such payments after a date specified by written notice sent to Mortgagor, the entire principal balance and all interest due thereon are collectible forthwith. File #: 83248 The following amounts are due on the mortgage: Principal Balance Interest 02/01/2003 through 12/01/2003 (Per Diem $15.80) Attorney's Fees Cumulative Late Charges 07/29/1999 to 12/01/2003 Cost of Suit and Title Search Subtotal $72,216.32 4,803.20 1,250.00 173.28 $ 550.00 $ 78,992.80 Escrow Credit 0.00 Deficit 925.54 Subtotal $ 925.54 TOTAL $ 79,918.34 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. The mortgage premises are vacant and abandoned. WHEREFORE, PLAINTIFF demands an in rem Judgment against the Defendant(s) in the sum of $ 79,918.34, together with interest from 12/01/2003 at the rate of $15.80 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. By: FEDERMAN AND PHELAN, LLP FRANK FEDERMAN, ESQUIRE LAWRENCE T. PHELAN, ESQUIRE FRANCIS S. HALLINAN, ESQUIRE Attorneys for Plaintiff F/leg: 83248 ALL THAT C~IITAIN lot of ~'ound with t~o improvements ~o~on crected si~u~t~ in ~* Borough ofl,~nt Holly ~l~ings, Cumb~aud County, P~mS!dwni~, botmdcd md clc~,~b~d ~ fallows: BRING thn same propen~ which b.y D~rr~: s. wntding Rcld Estat= d,tted 24,1976 and recorded in l~e Office ol'tl~s R~.ot, der of Deeds in nnd [or cuml~rlsnd Count/in D=ed Book T.2~;, Pngc 401, ~vard~ to A,~ns I. Kiln= ;nd June Mr..M~rrny. grantOr~ ber~n. P~SES BEING: 113 NORTR BALTIMORE AVENUE 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 are based upon information supplied by Plaintiff and are true and correct to the best of its knowledge, information and belief. Furthermore, it is counsel's intention to substitute a verification from Plaintiff as soon as it is received by counsel. The undersigned understands that this statement is made subject to the penalties of 18 Pa. C. S. Sec. 4904 relating to unswom falsifications to authorities. Francis S. Hallinan, Esquire Attorney for Plaintiff '_2' SHERIFFIS RETURN - CASE NO: 2003-062S5 P COMMONWEALTH OF PENNSYLVANIA: COUNTY OF CUMBERLAND SFJV-2002-1 LLC VS BISHOP ERIC A ET AL REGULAR HAROLD WEARY Sheriff or Deputy Sheriff of Cumberland County, Pennsylvania, who being duly sworn according to says, the within COMPLAINT - MORT FORE was served upon BISHOP AMY M DEFENDANT , at 1859:00 HOURS, at 109 EAST MAIN STREET PLAINFIELD, PA 17081 MARLYS EDWARDS, MOTHER a true and attested copy of COMPLAINT the on the 26th day of December by handing to - MORT FORE together with 2003 and at the same time directing Her attention to the Additional Comments 113 N BALTIMORE AVE MT HOLLY SPRINGS IS VACANT. contents thereof. Sheriff's Costs: Docketing 6.00 Service 4.14 Affidavit .00 Surcharge 10.00 .00 20.14 Sworn and Subscribed to before me this gE day of [ ,~;.,, ~ ,,:J~.~ A.D. Y/P~othonotary ' ' So Answers: R. Thomas Kline 12/29/2003 FEDERMAN & PHELAN By: Deputy She~tif f SHERIFF'S RETURN CASE NO: 2003-06255 P COMMONWEALTH OF PENNSYLVANIA: COUNTY OF CUMBERLAND SFJV-2002-1 LLC VS BISHOP ERIC A ET AL - REGULAR GERALD WORTHINGTON , Sheriff or Deputy Sheriff of Cumberland County,Pennsylvania, who being duly sworn according to law, says, the within COMPLAINT BISHOP ERIC A DEFENDANT , at 1735:00 at 18 MARILYN DRIVE CARLISLE, PA 17013 ERIC BISHOP a true and attested copy of COMPLAINT - - MORT FORE was served upon the HOURS, on the 19th day of December , 2003 by handing to MORT FORE together with and at the same time directing His attention to the contents thereof. Sheriff's Costs: Docketing 18 Service 4 Affidavit Surcharge 10 32 00 14 00 00 00 14 Sworn and Subscribed to before me this Y~ day of thonotary ' So Answers: R. Thomas Kline 12/29/2003 FEDERMAN & PHELAN Deputy Sh~if f · FEDERMAN A.ND PHELAN, LLP By: FRANK FEDERMAN Identification No. 12248 Attorney for Plaintiff ONE PENN CENTER AT SUBURBAN STATION 1617 JOHN F. KENNEDY BLVD., SUITE 1400 PHILADELPHIA, PA 19103-1814 (215} 563-7000 SFJV-2002-1, LLC 7495 NEW HORIZON WAY FREDERICK, MD 21703-8388 Plaintiff, ERIC A. BISHOP AMY M. BISHOP CUMBERLAND COUNTY COURT OF COMMON PLEAS CIVIL DIVISION NO. 03-6255 CIVIL TERM Defendant(s). : 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 ERIC A. BISHOP and AMY M. BISHOP, Defendant(s) for failure to file an Answer to Plaintiffs Complaint within 20 days from service thereof and for Foreclosure and Sale of the mortgaged premises, and assess Plaintiffs damages as follows: As set forth in Complaint Interest from 12/2/03 to 2/9/04 TOTAL $79,918.34 $1,106.00 $81,024.34 I hereby certify that (1) the addresses of the Plaintiff and Defendant(s) are as shown above, and (2) that notice has been given in accordance with Rule 237.1, copy attached. FRANK FEDERMAN, ESQUIRE Attorney for Plaintiff DAMAGES ARE HEREBY ASSESSED AS INDICATED. PRO PROTHY · FEDERMAN AND PHELAN, LLP FRANK FEDERMAN, ESQ., Id. No. 12248 LAWRENCE T. PHELAN, ESQ., Id. No. 32227 FRANCIS S. HALLINAN, ESQ., Id. No, 62695 ONE PENN CENTER PLAZA, SUITE 1400 PHILADELPHIA, PA 19103 (~ s) 56~-7000 SFJV-2002-1, LLC Plaintiff VS. ERIC A. BISHOP AMY M. BISHOP Defendants ATTORNEY FOR PLAINTIFF : COURT OF COMMON PLEAS : CIVIL DMSION : CUMBERLAND COUNTY : NO. 03-6255 CML TERM TO: ERIC A. BISHOP 18 MARILYN DRIVE CARLISLE, PA 17013 DATE OF NOTICE: JANUARY 16. 2004 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 1N DEFAULT BECAUSE YOU HAVE FAILED TO ENTER A WRITTEN APPEARANCE PERSONALLY OR BY ATTORNEY AND FILE 1N WRITING WITH THE COURT YOUR DEFENSES OR OBJECTIONS TO THE CLAIMS SET FORTH AGAINST YOU. UNLESS YOU ACT WITHIN TEN DAYS FROM THE DATE OF THIS NOTICE, A JUDGMENT MAY BE ENTERED AGAINST YOU WITHOUT A HEARING AND YOU MAY LOSE YOUR PROPERTY OR OTHER IMPORTANT RIGHTS. YOU SHOULD TAKE THIS PAPER TO YOUR LAWYER AT ONCE. IF YOU DO NOT HAVE A LAWYER, GO TO OR TELEPHONE THE OFFICE SET FORTH BELOW. THIS OFFICE CAN PROVIDE YOU WITH INFORMATION ABOUT HIRING A LAWYER. IF YOU CANNOT AFFORD TO HIRE A LAWYER, THIS OFFICE MAY BE ABLE TO PROVIDE YOU WITH INFORMATION ABOUT AGENCIES THAT MAY OFFER LEGAL SERVICES TO ELIGIBLE PERSONS AT A REDUCED FEE OR NO FEE. CUMBERLAND COUNTY CUMBERLAND COUNTY BAR ASSOCIATION 2 LIBERTY AVENUE CARLISLE, PA 17013 (717) 249-3166 FRANK FEDERMAN, ESQUIRE LAWRENCE T. PHELAN, ESQUIRE FRANCIS S. HALLINAN, ESQUIRE Attorneys for Plaintiff FEDERMAN AND PHELAN, LLP FRANK FEDERMAN, ESQ., Id. No. 12248 LAWRENCE T. PHELAN, ESQ., Id. No. 32227 FRANCIS S. HALLINAN, ESQ., Id. No. 62695 ONE PENN CENTER PLAZA, SUITE 1400 PHILADELPHIA, PA 19103 (715) 56'~-7000 SFJV-2002-1, LLC Plaintiff ERIC A. BISHOP AMY M. BISHOP Defendants ATTORNEY FOR PLAINTIFF : COURT OF COMMON PLEAS : CIVIL DMSION : CUMBERLAND COUNTY : NO. 03-6255 CML TERM TO: AMY M. BISHOP 109 EAST MAIN STREET PLAINFIELD, PA 17081 DATE OF NOTICE: JANUARY 16. 2004 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. IF YOU DO NOT HAVE A LAWYER, GO TO OR TELEPHONE THE OFFICE SET FORTH BELOW. THIS OFFICE CAN PROVIDE YOU WITH INFORMATION ABOUT HIRING A LAWYER. IF YOU CANNOT AFFORD TO HIRE A LAWYER, THIS OFFICE MAY BE ABLE TO PROVIDE YOU WITH INFORMATION ABOUT AGENCIES THAT MAY OFFER LEGAL SERVICES TO ELIGIBLE PERSONS AT A REDUCED FEE OR NO FEE. CUMBERLAND COUNTY CUMBERLAND COUNTY BAR ASSOCIATION 2 LIBERTY AVENUE CARLISLE, PA 17013 (717) 249-3166 FRANK FEDERMAN, ESQUIRE LAWRENCE T. PHELAN, ESQUIRE FRANCIS S. HALLINAN, ESQUIRE Attorneys for Plaintiff SHERIFF'S rETURN - CASE NO: 2003-06255 P COMMONWEALTH OF PENNSYLVANIA: COUNTY OF CUMBERLAND SFJV-2002-1 LLC VS BISHOP ERIC A ET AL REGULAR HAROLD 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 BISHOP AMY M the DEFENDANT , at 1859:00 HOURS, on the 26th day of December 2003 at 109 EAST MAIN STREET PLAINFIELD, PA 17081 by handing to MARLYS EDWARDS, MOTHER a true and attested copy of COMPLAINT - MORT FORE together with and at the same time directing Her attention Additional Comments to the contents thereof. 113 N BALTIMORE AVE MT HOLLY SPRINGS IS VACANT. Sheriff's Costs: Docketing 6.00 Service 4.14 Affidavit .00 Surcharge 10.00 .00 20.14 So Answers: 12/29/2003 FEDERMAN & PHELAN Sworn and Subscribed 5o ....... 7 ~' /~-~ ~t~/ 7///~ / [~ . . before By- · me Ehis day of Deputy S'~iff A.D. Prothonotary SHERIFF'S CASE NO: 2003-06255 P COMMONWEALTH OF PENNSYLVANIA: COUNTY OF CUMBERLAND SFJV-2002~i LLC VS BISHOP ERIC A ET AL RETURN - REGULAR GERALD WORTHINGTON Cumberland County, Pennsylvania, says, the within COMPLAINT - MORT FORE BISHOP ERIC A DEFENDANT at 1735:00 HOURS, at 18 MARILYN DRIVE CARLISLE, PA 17013 ERIC BISHOP a true and attested copy of COMPLAINT - Sheriff or Deputy Sheriff of who being duly sworn according to law, was served upon the on the 19th day of December , __ by handing to together with MORT FORE 2O03 and at the same time directing His attention to the contents thereof. Sheriff's Costs: Docketing 18.00 Service 4.14 Affidavit .00 Surcharge 10.00 .00 32.14 Sworn and Subscribed to before me this day of A.D. Prothonotary So Answers: R. Thomas Kline 12/29/2003 FEDERMAN & PHELAN F ny Sheriff FEDERMAN and PHELAN, LLP By: FRANK FEDERMAN Identification No. 12248 ONE PENN CENTER AT SUBURBAN STATION 1617 JOHN F. KENNEDY BLVD., SUITE 1400 PHILADELPHIA, PA 19103-1814 (215~ 563-7000 SFJV-2002-1, LLC 7495 NEW HORIZON WAY FREDERICK, MD 21703-8388 Plaintiff, ERIC A. BISHOP AMY M. BISHOP Defendant(s). ATTORNEY FOR PLAINTIFF CUMBERLAND COUNTY COURT OF COMMON PLEAS CIVIL DMSION NO. 03-6255 CIVIL TERM VERIFICATION OF NON-MILITARY SERVICE FRANK FEDERMAN, ESQUIRE, hereby verifies that he is attorney for the Plaintiff in the above-captioned matter, and that on information and belief, he has knowledge of the following facts, to wit: (a) that the defendant(s) is/are not in the Military or Naval Service of the United States or its Allies, or otherwise within the provisions of the Soldiers' and Sailors' Civil Relief Act of Congress of 1940, as amended. (b) that defendant ERIC A. BISHOP is over 18 years of age and resides at, 18 MARILYN DRIVE, CARLISLE, PA 17013 · (c) that defendant AMY M. BISHOP is over 18 years of age, and resides at, 109 EAST MAIN STREET, PLAINFIELD, PA 17081. This statement is made subject to the penalties of 18 Pa. C.S. Section 4904 relating to unswom falsification to authorities. FRANK FEDERMAN, ESQUIRE Attorney for Plaintiff Request for Military Status Page 1 of 1 Department of Defense Manpower Data Center FEB-06-2004 08:59:34 Military Status Report Pursuant to the Soldiers' and Sailors' Civil Relief Act of 1940 E~ii~a~topName ]~t [Middle [BeginDate [ Active Duty Status I service/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 Manpower Data Center, the above is the current status of the Defendant(s), per the Information provided, as to all branches of the Military. Kenneth C. Scheflen, Director Department of Defense - Manpower Data Center 1600 Wilson Blvd., Suite 400 Arlington, VA The Defense Manpower Data Center (DMDC) is an organization of the Department of Defense that maintains the Defense Enrollment and Eligibility Reporting System (DEERS) database which is the official soume of data on eligibility for military medical care and other eligibility systems. If you have information that makes you feel that the DMDC response is not correct, please send an e-mail to sscra.heipdesk~osd.pentagon.mil. For personal privaey reasons, SSNs are not available on this printed results page. Requesters submitting a SSN only receive verification that the SSN they submitted is a match or non-match. https://www.dmdc.osd.mil/udpdri/owaJsscra.prc_Select 2/6/2004 Request for Military Status Page 1 of 1 Department of Defense Manpower Data Center FEB-06-2004 09:00:02 Soldiers' and Sailors' Civil Relief Act of 1940 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 Manpower Data Center, the above is the current status of the Defendant(s), per the Information provided, as to all branches of the Military. Kenneth C. Scheflen, Director Department of Defense - Manpower Data Center 1600 Wilson Blvd., Suite 400 Arlington, VA The Defense Manpower Data Center (DMDC) is an organization of the Department of Defense that maintains the Defense Enrollment and Eligibility Reporting System (DEERS) database which is the official source of data on eligibility for military medical care and other eligibility systems. If you have information that makes you feel that the DMDC response is not correct, please send an e-mail to sscra.helpdesk~osd_.pentagon.mil. For personal privacy reasons, SSNs are not available on this printed results page. Requesters submitting a SSN only receive verification that the SSN they submitted is a match or non-match. https://www.dmdc.osd.mil/udpdri/owaYsscra.prc_Select 2/6/2004 FEDERMAN and PHELAN, LLP By: FRANK FEDERMAN Identification No. 12248 ONE PENN CENTER AT SUBURBAN STATION 1617 JOHN F. KENNEDY BLVD., SUITE 1400 PHILADELPHIA, PA 19103-1814 (215) 563-7000 SFJV-2002-1, LLC Plaintiff, ERIC A. BISHOP AMY M. BISHOP Defendant(s). ATTORNEY FOR PLAINTIFF CUMBERLAND COUNTY COURT OF COMMON PLEAS CIVIL DIVISION NO. 03-6255 CIVIL TERM CERTIFICATION FRANK FEDERMAN, ESQUIRE, hereby verifies that he is attorney for the Plaintiff in the above-captioned matter, and that the premises are not subject to the provisions of Act 91 because it is: 0 an FHA mortgage ( ) non-owner occupied ( ) vacant (X) Act 91 procedures have been fulfilled This certification is made subject to the penalties of 18 Pa. C.S. Section 4904 relating to unswom falsification to authorities. FRANK FEDERMAN, ESQUIRE Attorney for Plaintiff PRAECIPE FOR WRIT OF EXECUTION - (MORTGAGE FORECLOSURE) P.R.C.P. 3180-3183 SFJV-2002-1, LLC : Plaintiff, : ERIC A. BISHOP : AMY M. BISHOP : Defendant(s). : No. 03-6255 CIV1L TERM TO THE DIRECTOR OF THE OFFICE OF THE PROTHONOTARY: Issue writ of execution in the above matter: Amount Due Interest from 2/10/04 to JUNE 9, 2004 (per diem -$13.32) TOTAL $81,024.34 $ 1,611.72 $82,636.06 and Costs FRANK FEDERMAN, ESQUIRE One Penn Center at Suburban Station 1617 John F. Kennedy Boulevard, Suite 1400 Philadelphia, PA 19103-1814 Attorney for Plaintiff Note: Please attach description of property. No. ALL THAT CERTAIN lot of ground with the improvements thereon erected situate in the Borough of Mount Holly Springs, Cumberland County, Pennsylvania, bounded and described as follows: ON the North by Church Street; on the East by Baltimore Avenue; on the South by land formerly of Ellen J. Skolly, now or formerly of Emma Rice; and on the West by an alley; having a frontage of 30 feet on Baltimore Avenue and extending in depth a distance of 180 feet to the alley on the West, and being improved with a 2 1/2 story frame dwelling house known as No. 113 North Baltimore Avenue. TITLE TO SAID PREMISES IS VESTED iN Eric A. Bishop and Amy M. Bishop, husband and wife by Deed from Anna L. Kline and June M. McMurray, single persons dated 7/29/1999 and recorded 8/2/1999 in Deed Book 204 Page 1074. //~ WRIT OF EXECUTION and/or ATTACHMENT COMMONWEALTH OF PENNSYLVANIA) NO 03~6255 Civil COUNTY OF CUMBERLAND) CIVIL ACTION - LAW TO THE SHERIFF OF CUMBERLAND COUNTY: To satisfy the debt, interest and costs due SFJV-2002-1, LLC, Plaintiff (s) From ERIC A. BISHOP AND AMY M. BISHOP (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 at, ach the property of the defendant(s) not Ievied 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. AmountDue $81,024.34 L.L. $.50 Interest FROM 2/10/04 TO 6/9/04 (PER DIEM - $13.32) - $1,611.72 AND COSTS Atty's Corem% Due Prothy $1.00 AttyPaid $134.28 Other Costs PlaintiffPaid Date: FEBRUARY 10, 2004 (Seal) CURTIS R. LONG Prothono~ D~uty REQUESTING PARTY: Name FRANK FEDERMAN, ESQUIRE Address: ONE PENN CENTER AT SUBURBAN STATION 1617 JOHN F. KENNEDY BOULEVARD, SUITE 1400 PHILADELPHIA, PA 19103-1814 Attorney for: PLAINTIFF Telephone: 215-563-7000 Supreme Court ID No. 12248 SFJV-2002-1, LLC Vo ERIC A. BISHOP AMY M. BISHOP Plaintiff, Defendant(s). CUMBERLAND COUNTY COURT OF COMMON PLEAS CIVIL DIVISION NO. 03-6255 CIVIL TERM AFFIDAVIT PURSUANT TO RULE 3129 (Affidavit No. 1) SFJV-2002-1, LLC, Plaintiff in the above action, by its attorney, FRANK FEDERMAN, ESQUIRE, sets forth as of the date the Praecipe for the Writ of Execution was filed the following information concerning the real property located at ,113 NORTH BALTIMORE AVENUE, MOUNT HOLLY SPRINGS, PA 17065. 1. Name and address of Owner(s) or reputed Owner(s): Name Last Known Address (if address cannot be reasonably ascertained, please indicate) ERIC A. BISHOP 18 MARILYN DRIVE CARLISLE, PA 17013 AMY M. BISHOP 109 EAST MAIN STREET PLAINFIELD, PA 17081 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 None Last Known Address (if address cannot be reasonably ascertained, please indicate) 4. Name and address of last recorded holder of every mortgage of record: Name Last Known Address (if address cannot be reasonably ascertained, please indicate) JP MORGAN CHASE BANK 2138 NORTH ONTARIO, SUITE 400 BURBANK, CA 5. Name and address of every other person who has any record lien on the property: Nan'le 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 plaintiffhas knowledge who has any interest in the property which may be affected by the sale: Nalne Last Known Address (if address cannot be reasonably ascertained, please indicate) Tenant/Occupant 113 NORTH BALTIMORE AVENUE MOUNT HOLLY SPRINGS, PA 17065 Domestic Relations of Cumberland County 13 North Hanover Street Carlisle, PA 17013 Commonwealth of Pennsylvania Department of Welfare PO Box 2675 Harrisburg, PA 17105 I verify that the statements made in this affidavit are true and correct to the best of my personal knowledge or information and belief. I understand that false statements herein are made subject to the penalties of 18 Pa. C.S. Sec. 4904 relating to unswom falsification to authorities. February 9, 2004 DATE FRANK FEDERMAN, ESQUIRE Attorney for Plaintiff SFJV-2002-1, LLC : Plaintiff, : ERIC A. BISHOP : AMY M. BISHOP : Defendant(s). : TO: ERIC A. BISHOP 18 MARILYN DRIVE CARLISLE, PA 17013 CUMBERLAND COUNTY No. 03-6255 CIVIL TERM February 9, 2004 AMY M. BISHOP 109 EAST MAIN STREET PLAINFIELD, PA 17081 **THIS FIRM IS A DEBT COLLECTOR ATTEMPTING TO COLLECT A DEBT AND ANY INFORMATION OBTAINED WILL BE USED FOR THAT PURPOSE. IF YOU HAVE PREVIOUSL Y RECEIVED A DISCHARGE IN BANKRUPTCY AND THIS DEBT WAS NOT REAFFIRMED, THIS IS NOT AND SHOULD NOT BE CONSTRUED TO BE AN ATTEMPT TO COLLECT A DEBT, BUT ONLY ENFORCEMENT OF A LIEN AGAINST PROPERTY. ** Your house (real estate) at, 113 NORTH BALTIMORE AVENUE, MOUNT HOLLY SPRINGS, PA 17065, is scheduled to be sold at the Sheriffs Sale on JUNE 9, 2004 at 10:00 a.m. in the Cumberland County Courthouse, South Hanover Street, Carlisle, PA 17013, to enforce the court judgment of $81,024.34 obtained by SFJV-2002-1, 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: The sale will be cancelled if you pay to the mortgagee the back payments, late charges, costs and reasonable attorney's fees due. To find out how much you must pay, you may call: (215) 563-7000. You may be able to stop the sale by filing a petition asking the Court to strike or open the judgment, if the judgment was improperly entered. You may also ask the Court to postpone the sale for good cause. You may also be able to stop the sale through other legal proceedings. You may need an attorney to assert your 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 Sheriffthe full amount due in the sale. To find out if this has happened, you may call (717) 240-6390. 4. If the amount due from the Buyer is not paid to the Sheriff, you will remain the owner of the property as if the sale never happened. 5. You have the right to remain in the property until the full amount due is paid to the Sheriff and the Sheriff gives a deed to the buyer. At that time, the buyer may bring legal proceedings to evict you. 6. You may be entitled to a share of the money which was paid for your house. A schedule of distribution of the money bid for your house will be filed by the Sheriff within 30 days of the sale. This schedule will state who will be receiving that money. The money will be paid out in accordance with this schedule unless exceptions (reasons why the proposed distribution is wrong) are filed with the Sheriff within ten (10) days after the distribution is filed. 7. You may also have other rights and defenses, or ways of getting your home back, if you act immediately after the sale. YOU SHOULD TAKE THIS PAPER TO YOUR LAWYER AT ONCE. IF YOU DO NOT HAVE A LAWYER OR CANNOT AFFORD ONE, GO TO OR TELEPHONE THE OFFICE LISTED BELOW TO FIND OUT WHERE YOU CAN GET LEGAL HELP. CUMBERLAND COUNTY ATTORNEY REFERRAL CUMBERLAND COUNTY BAR ASSOCIATION 2 LIBERTY AVENUE CUMBERLAND COUNTY COURTHOUSE CARLISLE, PA 17013 (717) 249-3166 (800) 990-9108 ALL THAT CERTAIN lot of ground with the improvements thereon erected situate in the Borough of Mount Holly Springs, Cumberland County, Pennsylvania, bounded and described as follows: ON the North by Church Street; on the East by Baltimore Avenue; on the South by land formerly of Ellen I. Skolly, now or formerly of Emma Rice; and on the West by an alley; having a frontage of 30 feet on Baltimore Avenue and extending in depth a distance of 180 feet to the alley on the West, and being improved with a 2 1/2 story frame dwelling house known as No. 113 North Baltimore Avenue. TITLE TO SAID PREMISES IS VESTED iN Eric A. Bishop and Amy M. Bishop, husband and wife by Deed from Anna L. Kline and June M. McMurray, single persons dated 7/29/1999 and recorded 8/2/1999 in Deed Book 204 Page 1074. PLAINTIFF DEFENDANT(S) SFJV-2002-1, LLC ERIC A. BISHOP AFFIDAVIT OF SERVICE CUMBERLAND COUNTY PJT No.. 03-6255 CML TERM AC:CT. #.1171000242 SERVE ERIC A. BISHOP AT 18 MARILYN DRIVE CARLISLE, PA 17013 Type of Action - Notice of Sheriff's Sale Salte Date: JUNE 9, 2004 SERVED I¢ Served and made lmown to ~"V'~,C ~, I'~'t-~'~'~¥~ , Defendant, on the '~[ day of ~/~y ,200~ ~ at. 1~ ~ ,o'clock~-m. at / ~ ~X/2~ ~/b~ ~.~ ~. ~.~ ,Co~nwealth of Pennsylvania, in the manner described below: ~efendant personally served. -- Adult family member with whom Defendant(s) reside(s). Relationship is y' Adult in charge of Defendant(s)'s residence who refused to give name or relationship. -- Manager/Clerk of place of lodging in which Defendant(s) reside(s)· -- Agent or person in charge of Defendant(s)'s office or usual place of business. an officer of satd Defendant(s) s comp y. Other: Description: Age /~2 Height '-'q' ~'~ // Weight / ~O Race /IJ Sex /l~ Other yl, '-~fs ,fi'/~?~ , a competent adult, being duly sworn according to law, depose and state that I personally handed a tree and correct copy of the Notice of Sheriff's Sale in the manner as set forth herein, issued in the captioned case on the date and at the address indicated above. Sworn to and subscribed .ri before me~ day ~ /] ~ /.~ . (... PL~A~ ATT~M~ ~E~OI~ AT LEaf3 T~S. II OlCATE DATES & T~ES OF SER~CE ATTEMP~O. yOn the day of ,200~ at y.__ Moved Unknown No Answer ~,t' lSt Attempt: / / Time: : ~ 3rd Attempt: / / Time: : NOT SERVED o'clock__.m-, Defendant NOT FOUND because: Vacant 2na Attempt:_ / / Time: Sworn to and subscribed before me this day of ,200 _. Notary: By: Attorney for Plaintiff Frank Federman, Esquire - I.D. No. 12248 PLAINTIFF DEFENDANT(S) AFFIDAVIT OF SERVICE SFJV-2002-1, LLC AMY M. BISHOP CUMBERLAND COUNTY No. 03-6255 CIVIL TERM AC;CT. #1171000242 PJT SERVE AMY M. BISHOP AT 109 EAST MAIN STREET PLAINFIELD, PA 17081 Type of Action - Notice of SherifPs Sale Sale Date: JUNE 9, 2004 SERVED Commonwealth of Pennsylvaina, in the manner described below: day of ~-~ru~-/ Defendant personally served. ~ Adult family member with whom Defendant(s) reside(s). Relationship is .__~f ~(~ ~ 6 Adult in charge of Defendant(s)'s residence who refused to give name or relationship. __Manager/Clerk of place of lodging in which Defendant(s) reside(s). Agent or person in charge of Defendant(s)'s office or nsnal place ofbnsiness. an officer of said Defendant(s)'s company. __Other: /k~ --' Description: Age ¢ ~- Height ~ ~'~ t! Weight /~:,~0 Race [0k Sex ~ Other I,~'lb,r ~:~o c t ,~. ~'~ ~ ~'/'3'~r,, a competent adult, being duly sworn according to law, ~dep. os.e and s?te t? I.. personally handed a tree and c6rrect copy of the Notice of SheriWs Sale in the manner as set torm tterem, ~ssuect m me captioned case on the date and at the address indicated above. Sworn to and subscribed before me this _la'day ~ ~ ~ ~ of 200 . ///// PLEASE ATTEMPT SERVICE AT LEAST 3 TIMES. INDICATE DAT~,S & ATTEMPTED. rIMES OF SERVICE NOT SERVED On the day of ,200__, at o'clock __.hz, Defendant NOT FOUND became: Moved Unknown __ No Answer 1st Attempt: / / Time: : Vacant 2~a Attempt: / / Time: 3rd Attempt: / / Time: : Sworn to and subscribed before me this day of ,200 _. Notary: By: Attorney for Plaintiff Frank Federman, Esquire - I.D. No. 12248 IN THE COURT OF COMMON PLEAS OF CUMBERLAND COUNTY, PENNSYLVANIA SFJV-2002, LLC VS. ERIC A. BISHOP AMY M. BISHOP CIVIL ACTION CIVIL DIVISION NO. 03-6255 CIVIL TERM AFFIDAVIT OF SERVICE PURSUANT TO RULE 3129 COMMONWEALTH OF PENNSYLVANIA ) COUNTY OF CUMBERLAND ) SS: I, FRANK FEDERMAN, ESQUIRE attorney for SFJV-2002~ LLC hereby verify that on February 1 IT 2004 true and correct copies of the Notice of Sheriff's sale were served by certificate of mailing to the recorded lienholders, .and any known interested party see Exhibit "A" attached hereto. DATE: April 26, 2004 FRANK FEDERMAN, ESQUIRE Attorney for Plaintiff COMMONWEALTH OF PENNSYLVANIA COUNTY OF CUMBERLAND ~ SS: I, Robert P. Zieeler, Recorder of Deeds in and for said County and State do hereby certify that the Sheriff's Deed in which SFJV 2002-LLC is the grantee the same having been sold to said grantee on the 7th day of July A.D., 2004, under and by virtue of a writ Execution issued on the 10th day of Feb, A.D., 2004, out of the Court of Common Pleas of said County as of Civil Term, 2003 Number 6255, at the suit of SFJV-2002-1 LLC against Eric A Bishop & Amy M is duly recorded in Sheriff' s Deed Book No. 264, Page 3014. IN TESTIMONY WHEREOF, I have hereunto set my hand and seal of said office this q __.day of & ~ , A.D2004 ,~m,~' -3 Reco<her of Deeds SFJV-2002- I, LLC VS Eric A. Bishop and Amy M. Bishop In The Court of Common Pleas of Cumberland County, Pennsylvania Writ No. 2003-6255 Civil Term Cpl. Timothy Reitz, Deputy Sheriff, who being duly sworn according to law, states that on March 01, 2004 at 2:54 o'clock PM, 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: Eric A. Bishop, by making known unto Erica LeBlanc, adult in charge for defendant, at 18 Marilyn Drive, Carlisle, Cumberland County, Pennsylvania, its contents and at the same time handing to her 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 March 02, 2004 at 2:00 o'clock PM, 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: Amy M. Bishop, by making known unto Marlise Edwards, mother of defendant, at 109 East Main Street, Plainfield, Cumberland County, Pennsylvania, its contents and at the same time handing to her personally the said true and correct copy of the same. David McKinney, Deputy Sheriff, who being duly sworn according to law, states that on April 07, 2004 at 9:52 o'clock A.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 Eric A. Bishop and Amy M. Bishop located at 113 North Baltimore Ave., Mt. Holly Springs, 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 nmned defendant, to wit: Eric A. Bishop, by regular mail to his last known address of 18 Marilyn Drive, Carlisle, PA 17013. This letter was mailed under the date of April (}6, 2004 and never returned to the Sheriff's Office. 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 Sheriffmailed a notice of the pendency of the action to the within named defendant, to wit: Amy M. Bishop, by regular mail to her last known address of 109 East Main Street, Plainfield, PA 17081. This letter was mailed under the date of April 06, 2004 and never returned to the Sheriff's Office. R. Thomas Kline, Sheriff, who being duly sworn according to law, states that after due and legal notice had been given according to law, he exposed the within described premises at public venue or outcry at the Courthouse, Carlisle, Cumberland County, Pennsylvania on July 7, 2004 at 10:00 o'clock A.M. He sold the same for the sum of $1.00 to Attorney Frank Federman for SFJV-2002-1, LLC. It being the highest bid and best price received for the same, SFJV-2002-1, LLC of 7495 New Horizon Way, Frederick, MD 21703-8388, being the buyers in this execution, paid to SheriffR. Thomas Kline the sum of $675.57. Sheriffs Costs: Docketing $30.00 Poundage 13.25 Posting Bills 15.00 Advertising 15.00 Acknowledging Deed 30.00 Auctioneer 10.00 Law Library .50 Prothonotary 1.00 Mileage 11.73 Levy 15.00 Surcharge 30.00 Postpone Sale 20.00 Law Journal 177.05 Patriot News 213.28 Share of Bills 29.26 Distribution of Proceeds 25.00 Sheriff's Deed 39.50 $ 675.57 Sworn and subscribed to before me This I0 day of (_g,,q/.,.~ ~Prothonotary R. Thomas Kline, Shed'iff Real Estat~qDeputy 30 ,o SFJV-2002-1, LLC : Plaintiff, : ERIC A. BISHOP : AMY M. BISHOP : : Defendant(s). : CUMBERLAND COUNTY COURT OF COMMON PLEAS CIVIL DIVISION NO. 03-6255 CML TERNI AFFIDAVIT PURSUANT TO RULE 3129 (Affidavit No. 1) SFJV-2002-1, LLC, Plaintiffin the above action, by its attorney, FRANK FEDERMAN, ESQUIRE, sets forth as of the date the Praecipe for the Writ of Execution was filed the following information concerning the real property located at ,I 13 NORTH BALTIMORE AVENUE, MOUNT HOLLY SPRINGS, PA 17065. 1. Name and address of Owner(s) or reputed Owner(s): Name Last Known Address (if address cannot be reasonably ascertained, please indicate) ERIC A. BISHOP 18 MARILYN DRIVE CARLISLE, PA 17013 AMY M. BISHOP 109 EAST MAIN STREET PLAINFIELD, PA 17081 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 KnownAddress (ifaddress cannot be reasonably ascerlained, pleaseindicate) None 4. Name and address of last recorded holder of every mortgage of record: NalTle Last Known Address (if address ca,mot be reasonably ascertained, please indicate) JP MORGAN CHASE BANK 2138 NORTH ONTARIO, SUITE 400 BURBANK, CA 5. Name and address of every other person who has any record lien on the property: Nan'le 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. maine Last Known Address (if address cannot be reasonably ascertained, please indicate) None 7. Name and address of every other person of whom the plaintiffhas knowledge who has any interest in the property which may be affected by the sale: Nallle Last Known Address (if address cannot be reasonably ascertained, please indicate) Tenant/Occupant 113 NORTH BALTIMORE AVENUE MOUNT HOLLY SPRINGS, PA 17065 Domestic Relations of Cumberland County 13 North Hanover Street Carlisle, PA 17013 Commonwealth of Pennsylvania Department of Welfare PO Box 2675 Harrisburg, PA 17105 I verify that the statements made in this affidavit are true and correct to the best of my personal knowledge or information and belief. I understand that false statements herein are, made subject to the penalties of 18 Pa. C.S. Sec. 4904 relating to unsworn falsification to authorities. February 9, 2004 DATE FRANK FEDERMAN, ESQUIRE Attorney for Plaintiff SFJV-2002-1, LLC : Plaintiff, : ERIC A. BISHOP : AMY M. BISHOP : Defendant(s). : TO: ERIC A. BISHOP 18 MARILYN DRIVE CARLISLE, PA 17013 CUMBERLAND COUN~I~ No. 03-6255 CIVIL TERM February 9, 2004 AMY M. BISHOP 109 EAST MAIN STREET PLAINFIELD, PA 17081 **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 BANKRUPTCYAND THIS DEBT WAS NOTREAFFIRMED, THIS IS NOTAND SHOULD NOTBE CONSTRUED TO BE AN ATTEMPT TO COLLECT A DEBT, B UT ONLY ENFOR CEMENT OF A LIEN AGAINST PROPFR TI( * * Your house (real estate) at, 113 NORTH BALTIMORE AVENUE, MOUNT HOLLY SPRINGS, PA 17065, is scheduled to be sold at the Sheriffs Sale on JUNE 9, 2004 at 10:00 a.m. in the Cumberland County Courthouse, South Hanover Street, Carlisle, PA 17013, to enforce the court judgment of $SL024.34 obtained by SFJV-2002~L LLC (the mortgagee) against you. In the event thc 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: The sale will be cancelled if you pay to the mortgagee the back payments, late charges, costs and reasonable attorney's fees due. To find out how much you must pay, you may call: (215) 563-7000. You may be able to stop the sale by filing a petition asking the Courl 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, ~e 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 Sheriffthe full mount 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 mount due is paid to the Sheriff and the Sheriffgives 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 Sheriffwithin 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 Sheriffwithin 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 yon act immediately after the sale. YOU SHOULD TAKE THIS PAPER TO YOUR LAWYER AT ONCE. IF YOU DO NOT HAVE A LAWYER OR CANNOT AFFORD ONE, GO TO OR TELEPHONE THE OFFICE LISTED BELOW TO FIND OUT WHERE YOU CAN GET LEGAL HELP. CUMBERLAND COUNTY ATTORNEY REFERRAL CUMBERLAND COUNTY BAR ASSOCIATION 2 LIBERTY AVENUE CUMBERLAND COUNTY COURTHOUSE CARLISLE, PA 17013 (717) 249-3166 (800) 990-9108 ALL THAT CERTAIN lot of ground with the improvements thereon erected situate in the Borough of Mount Holly Springs, Cumberland County, Pemtsylvania, bounded and descril:~l as follows: ON the North by Church Street; on the East by Baltimore Avenue; on the South by land formerly of Ellen J. Skolly, now or formerly of Emma Rice; and on the West by an alley; having a frontage of 30 feet on Baltimore Avenue and extending in depth a distance of 180 feet to the alley on the West, and being improved with a 2 1/2 story frame dwelling house known as No. 113 North Baltimore Avenue. TITLE TO SAID PREMISES IS VESTED iN Eric A. Bishop and Amy M. Bishop, husbaud and wife by Deed from Anna L. Kline and June M. McMurray, single persons dated 7/29/1999 and reeorded 8/2/1999 in Deed Book 204 Page 1074. j ALL THAT CERTAIN lot of ground with the improvements thereon erected situate in the Borough of Mount Holly Springs, Cumberland County, Pennsylvania, bounded and described as follows: ON the North by Church Street; on tile East by Baltimore Avenue; on the South by land formerly of Ellen J. Skolly, now or formerly of Emma Rice; and on thc West by an alley; having a frontage of 30 feet on Baltimore Avenue cud exteudiug in depth a distance of 180 feet to the alley on the West, and being 'unproved with a 2 1/2 story frame dwelling house known as No. 113 North Baltimore Avenue. TITLE TO SAID PREMISES IS VESTED iN Eric A. Bishop and Amy M. Bishop, husband and wife by Deed from Anna L. [(line and June M. McMurray, single persons dated 7/29/1999 and recorded 8/2/1999 in Deed Book 204 Page 1074. //..~-"' WRIT OF EXECUTION and/or ATTACHMENT COMMONWEALTH OF PENNSYLVANIA) NO 03-6255 Civil COUNTY OF CUMBERLAND) CIVIL ACTION - LAW TO THE SHERIFF OF CUMBERLAND COUNTY: To satisfy the debt, interest and costs due SFJV-2002-1, LLC, Plaintiff (s) From ERIC A. BISHOP AND AMY M. BISHOP (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 £ollows: and to notify the garnishee(s) that: (a) an attachmem 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. AmountDue $81,024.34 L.L. $.50 Interest FROM 2/10/04 TO 6/9/04 (PER DIEM - $13.32) ~ $1,611.72 AND COSTS Atty's Comm % Due Prothy $1.00 AttyPaid $134.28 Other Costs Plaintiff Paid Date: FEBRUARY I0, 2004 (Seal) CURTIS R. LONG Prothonot,~,r~ REQUESTING PARTY: Name FRANK FEDERMAN, ESQUIRE Address: ONE PENN CENTER AT SUBURBAN STATION 1617 JOHN F. KENNEDY BOULEVARD, SUITE 1400 PHILADELPHIA, PA 19103-1814 Attorney for: PLAINTIFF Telephone: 215-563-7000 Supreme Court ID No. 12248 Deputy Real Estate Sale #27 On March 01, 2004 the sherifflevied upon the defendant's interest in the real property situated in Mt. Holly Springs Borough, Cumberland County, PA Known and numbered as 113 North Baltimore Ave., Mt. Holly Springs, more fully described on Exhibit "A" filed with this writ and by this reference incorporated herein. Date: March 01, 2004 By: 'JC([~;,~md/t~-'~ ~ ) Real Estale Deputy PROOF OF PUBLICATION OF NOTICE IN CUMBERLAND LAW JOURNAL (Under Act No. 587, approved May 16, 1929), P. L. 1784 STATE OF PENNSYLVANIA : : COUNTY OF CUMBERLAND : SS. 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: APRIL 16, 23, 30, 2004 Affiant further deposes that he is authorized to verify this statement by the Ctm~befland Law Journal, a legal periodical of general circulation, and that he is not interested in the subject matter of the aforesaid notice or advertisement, and that all allegations in the foregoing statements as to time, place and character of publication are true. REAL ESTATE ~ALE NO. 27 Writ No. 2003~6255 Civil SFdV-2002-1, LLC Eric A. Bishop and Amy M.Blshop Atty.: Frank Federman ALL THAT CERTAIN lot offlround with the improvements thereon erected situate In the Borough of Mount Holly Springs, Cumberland County, Pe~ansylvanla. bounded and described as follows: ON the North by Church Street; on the East by Baltimore Avenue: on the South by land formerly of Ellen J. Skolly, now or formerly of Emma Rice; and on the West by an alley; hmrlng a frontage of 30 feet on Baltlmore Avenue and extending in depth a distance of 180 feet to the alley on the West, and being improved with a 2 1/2 story flame dwelling house known as No. 113 ~isa~M .~e C',~yn~EE~itor ' SWORN TO AND SUBSCRIBED before rrle this 30 day of APRIL 2004 LOIS E. SNYDER, Nolary Public Carlisle Bom, Cumberland County My Commission Expires March 5, 2005 Writ No. 2003-6255 Civil SFJV-2002-1, LLC VS. Eric A, Bishop and Amy M,Bishop Atty.: Frank Federman ALL THAT C ERTPJN lot of ~round with the improvements thereon erected situate in the Borough of Mount Holly Springs, Cumberland County, Permsylvan/a, bounded and described as fallows: ON the North by Church Street; on the East by Baltimore Avenue; on the South by land formerly of Ellen J. Skolly, now or formerly of Emma Rice; and on the West by an alley; having a frontage of 30 feet on Baltimore Avenue and extending in depth a distance of 180 feet to the alley on the West, and being improved with a 2 1/2 story frame dwelling house known as No. 113 North Baltimore Avenue. TITLE TO SAID PREMISES IS VESTED IN Eric A. Bishop and Amy M. Bishop, husband and wife by Deed from Anna L. Kline and June M. McMurray, single persons dated 7/29/1999 and recorded 8/2/ 1999 in Deed Book 204 Page 1074. Tax Parcel #23-32-2536-214. /Jma Maqie Coyn~Edit SWORN TO AND SUBSCRIB[ 30 day of_ APRIL 2 LOIS E. SNY~EFI, Notary Pul: Carlisle Bom, Cumbedand Co~ My Commission lSq~ims March 5 THE PATRIOT NEWS THESUNDAY PATRIOT NEWS Proof of Publication Under Ac~ No. 587, Approved May 16, 1929 Commonwealth of Pennsylvania, County of Dauphin} ss Michael Morrow, being duly sworn according to law, deposes and says: That he is the Controller of The Patriot News Co., a corporation organized and existing under the laws of the Commonwealth of Pennsylvania, with its principal office and place of business at 812 to 818 Market Street, in the City of Harrisburg, County of Dauphin, State of Pennsylvania, owner and publisher of The Patriot-News and The Sunday Patriot-News newspapers of general circulation, printed and published at 812 to 818 Market Street, in the City, County and State aforesaid; that The Patriot-News and The Sunday Patriot-News were established March 4th, 1854, and September 18th, 1949, respectively, and all have been continuously published ever since; That the printed notice or publication which is securely attached hereto is exactly as printed and published in their regular daily and/or Sunday/ Metro editions which appeared on the 27th day(s) of April and the 4th and 11th day(s) of May 2004. That neither he nor said Company is interested in the subject matter of said printed notice or advertising, and that all of the allegations of this statement as to the time, place and character of publication are true; and That he has personal know~edge 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 (~o~ty ;)auphin in. Miscellaneous Book "M', PUBLICATION ...... s,,,,, ,,,, ,,,o., Terry L Russe n ' ' I City of Harr'isburg, D~uphinCounty I ~,~C~T~V =~ N~y Commission F. xplres June 6, 2006~ ~' i ...... ~" Member, PennsylvanlaAsso¢lalionofNol~r~ commission expires June 6, 2006 CUMBERLAND COUNTY SHERIFFS OFFICE CUMBERLAND COUNTY COURTHOUSE CARLISLE, PA. 17013 Statement of Advertising Costs To THE PATRIOT-NEWS CO., Dr. For publishing the notice or publication attached hereto on the above stated dates Total $ 213.28 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.