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HomeMy WebLinkAbout03-6412FEDERMAN 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 SUNTRUST MORTGAGE, INC., F/K/A CRESTAR MORTGAGE CORPORATION 1001 SEMMES AVENUE P.O. BOX 26149, VA 23261 RICHMOND, VA 23224-2243 Plaintiff KAREN L. SAPORITO 507 NORTH PITT STREET CARLISLE, PA 17013 ATTORNEY FOR PLAINTIFF COURT OF COMMON PLEAS CIVIL DIVISION TERM NO. 03 CUMBERLAND COUNTY 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 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 #: 84386 IF THIS IS THE FIRST NOTICE THAT YOU HAVE RECEIVED FROM THIS OFFICE, BE ADVISED THAT: PURSUANT TO THE FAIR DEBT COLLECTION PRACTICES ACT, 15 U.S.C. § 1692 et seq. (1977), DEFENDANT(S) MAY DISPUTE THE VALIDITY OF THE DEBT OR ANY PORTION THEREOF. IF DEFENDANT(S) DO SO IN WR/TING WITHIN THIRTY (30) DAYS OF RECEIPT OF THIS PLEADING, COUNSEL FOR PLAINTIFF WILL OBTAIN AND PROVIDE DEFENDANT(S) WITH VCRITTEN 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, 1F 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 #: 84386 Plaintiff is SUNTRUST MORTGAGE, INC., F/K/A CRESTAR MORTGAGE CORPORATION 1001 SEMMES AVENUE P.O. BOX 26149, VA 23261 RiCHMOND, VA 23224-2243 The name(s) and last known address(es) of the Defendant(s) are: KAREN L. SAPORITO 507 NORTH PITT STREET CARLISLE, PA 17013 who is/are the mortgagor(s) and real owner(s) of the property hereinafter described. On 02/23/1999 mortgagor(s) made, executed and delivered a mortgage upon the premises hereinafter described to COMMERCE BANK/HARRISBURG, N.A. which mortgage is recorded in the Office of the Recorder of CUMBERLAND County, in Mortgage Book No. 1523, Page 27l. By Assignment of Mortgage recorded 3/1/99 the mortgage was assigned to PLAINTIFF which Assignment is recorded in Assignment of Mortgage Book No. 605, Page 259. 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 07/01/2003 and each month thereafter are due and tmpaid, 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 #: 84386 The following amounts are due on the mortgage: Principal Balance Interest 06/01/2003 through 12/10/2003 (Per Diem $10.07) Attorney's Fees Cumulative Late Charges 02/23/1999 to 12/10/2003 Cost of Suit and Title Search Subtotal $53,451.40 1,943.51 1,225.00 117.06 $ 550.00 $ 57,286.97 Escrow Credit 0.00 Deficit 262.75 Subtotal $ 262.75 TOTAL $ 57,549.72 The attorney's fees set forth above are in conformity with the mortgage documents and Pennsylvania law, and will be collected in the event ora third party purchaser at Sheriffs Sale. If the Mortgage is reinstated prior to the Sale, reasonable attorney's fees will be charged. Notice of Intention to Foreclose as set forth in Act 6 of 1974, Notice of Homeowner's Emergency Assistance Program pursuant to Act 91 of 1983, as amended in 1998, and/or Notice of Default as required by the mortgage document, as applicable, have been sent to the Defendant(s) on the date(s) set forth thereon, and the temporary stay as provided by said notice has terminated because Defendant(s) has/have failed to meet with the Plaintiff or an authorized consumer credit counseling agency, or has/have been denied assistance by the Pennsylvania Housing Finance Agency. This action does not come under Act 6 of 1974 because the original mortgage amount exceeds $50,000. WHEREFORE, PLAINTIFF demands an in rem Judgment against the Defendant(s) in the sum of $ 57,549.72, together with interest from 12/10/2003 at the rate of $10.07 per diem to the date of Judgment, and other costs and charges collectible under the mortgage and for the foreclosure and sale of the mortgaged property. FEDERMAN_AND PHELAN, LLP ,~ ~ By: /sfFr'afi~g STHa-llinan FRANK FEDERMAN, ESQUIRE LAWRENCE T. PHELAN, ESQUIRE FRANCIS S. HALL[NAN, ESQUIRE Attorneys for Plaintiff File#: 84386 RECORDATION REQUESTED BY: WHEN RECORDED MAll. TO: MORTGAGE ,o~1523~ ~271 02-23-1999 FNMA/FHLM~ MORTGAGE · ~ Page 2 of Loa~ No ,','.'71082 (CollfJnued} 02-23-1999 FNMA/FHLM¢ ~MO¥~TGA~, :~; Page Lo~n No YY~'~"J082 (Continued) o2.23-1;; FNMA/FHLMC MORTGAGE Page 4 of ,~ Lean ~No /~'/~1082 (Continued) CERTIFICATE OF RESIDENCE INDIVIDUAL ACKNOWLEDGMENT !,. feousylvnull, more puflleularly bounded and d~icflbed' ts rollowl, to BEGINNING et · 't~lot os' North Pitt Stat, ~mfr of I~d iow or f~efly of Arthu{ HA¥INQ tiltri01 ,r~e~d tiaa oorthero o.,bflr ti/2) or e rrm, dt~lliml boule ka0w8 es 507 AToflh Pitt R~.~ Cathie; PA. BEING the same premise· conveyed to Karen L. Saporito, ·ingle individual, by deed dated June 30, [989, and recorded in Cumberland County Deed Book 34-Q-714 PREMISES BEING: 507 N6RTH PITT STREET. VERIFICATION FRANCIS S. HALLINAN, ESQUIRE hereby states that he is attorney for Plaintiff in this matter, that Plaintiffis 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 Plaintiffand arc true and correct to the best of its knowledge, information and belief. Furthermore, it is counsel's intention to substitute a verification from Plaintiffas 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 unsworn falsifications to authorities. Francis S. Hallinan, Esquire Attorney for Plaintiff SHERIFF'S RETURN - REGULAR CASE NO: 2003-06412 P COMMONWEALTH OF PENNSYLVANIA: COUNTY OF CUMBERLAND SUNTRUST MORTGAGE INC VS SAPORITO KAREN L 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 SAPORITO KAREN L DEFENDANT at 1422 BP~ADLEY DRIVE CARLISLE, PA 17013 KAREN L SAPORITO a true at 1641:00 HOURS, C-114 and attested copy of COMPLAINT - the on the 26th day of December , 2003 by handing to MORT FORE together with and at the same time directing Her attention to the contents thereof. Sheriff's Costs: Docketing 18.00 Service 3.45 Affidavit .00 Surcharge 10.00 .00 31.45 Sworn and Subscribed to before me this ~-~ day of ~ ~ ~Z~ ~/ A.D. So Answers: R. Thomas Kline 12/29/2003 FEDERMAN & PHELAN By: Deputy Sher~ f f · FEDERMAN AND PHELAN, LLP By: FRANK FEDERMAN Identification No. 12248 Attorney for Plaintiff ONE PENN CENTER AT SUBURBAN STATION 1617 JOHN F. KENNEDY BLVD., SUITE 1400 PHILADELPHIA, PA 19103-1814 1'215} 563-7000 SUNTRUST MORTGAGE, INC., F/K/A CRESTAR MORTGAGE CORPORATION 1001 SEMMES AVENUE RICHMOND, VA 23224-2243 Plaintiff, KAREN L. SAPORITO Defendant(s). CUMBERLAND COUNTY COURT OF COMMON PLEAS CIVIL DIVISION NO. 03-6412 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 KAREN L. SAPORITO, Defendant(s) for failure to file an Answer to Plaintiff's Complaint within 20 days from service thereof and for Foreclosure and Sale of the mortgaged premises, and assess Plaintiff's damages as follows: As set forth in Complaint Interest from 12/11/03 to 2/9/04 TOTAL $57,549.72 $614.27 $58,163.99 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. FEDERMAN AND PHELAN, LLP 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 SUNTRUST MORTGAGE, INC., F/K/A CRESTAR MORTGAGE CORPORATION Plaintiff Vs. KAREN L. SAPORITO Defendants ATTORNEY FOR PLAINTIFF : COURT OF COMMON PLEAS : CIVIL DIVISION : CUMBERLAND COUNTY : NO. 03-6412 CIVIL TERM TO: KAREN L. SAPORITO 1422 BRADLEY DRIVE, C~114 CARLISLE, PA 17013 DATE OF NOTICE: .IANUARY 16, 2004 THIS FIRM IS A DEBT COLLECTOR ATTEMPTING TO COLLECT A DEBT. THIS NOTICE IS SENT TO YOU 1N 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, BIfF 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. FILE COPY 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 Plahntiff SHERIFF'S RETURN - CASE NO: 2003-06412 P COMMONWEALTH OF PENNSYLVANIA: COUNTY OF CUMBERLAND SUNTRUST MORTGAGE INC VS SAPORITO KAREN L 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 SAPORITO KAREN L DEFENDANT , at 1641:00 HOURS, at 1422 BRADLEY DRIVE C-114 CARLISLE, PA 17013 KAREN L SAPORITO a true and attested copy of COMPLAINT the on the 26th day of December , 2003 by handing to - MORT FORE together with and at the same time directing Her attention to the contents thereof. Sheriff's Costs: Docketing 18.00 Service 3.45 Affidavit .00 Surcharge 10.00 .00 31.45 Sworn and Subscribed to before day of me this , Prothonotary So Answers: R. Thomas Kline 12/29/2003 FEDERMAN & PHELAN Dephty Shemif f.i 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 SUNTRUST MORTGAGE, 1NC., F/K/A CRESTAR MORTGAGE CORPORATION 1001 SEMMES AVENUE Plaintiff, KAREN L. SAPORITO Defendant(s). ATTORNEY FOR PLAINTIFF CUMBERLAND COUNTY COURT OF COMMON PLEAS CIVIL DIVISION NO. 03o6412 VERIFICATION OF NON-MILITARY SERVICE FRANK FEDERMAN, ESQUIRE, hereby verifies that he is attorney for the Plaintiffin 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 KAREN L. SAPORITO is over 18 years of age and resides at, 1422 BRADLEY DRIVE, C-114, CARLISLE, PA 17013. 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 07:43:08 Military Status Report Soldiers' and Sailors' Civil Relief Act of 1940 SAPORITO [Not on Active Duty ! 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 sscro, h_~l~desk~osd.pentagon.mii. 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/owedsscra.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 SUNTRUST MORTGAGE, INC., F/K/A CRESTAR MORTGAGE CORPORATION Plaintiff, KAREN L. SAPORITO Defendant(s). ATTORNEY FOR PLAINTIFF CUMBERLAND COUNTY COURT OF COMMON PLEAS CIVIL DIVISION NO. 03-6412 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, ESQU1RE Attorney for Plaintiff PRAECIPE FOR WRIT OF EXECUTION - (MORTGAGE FORECLOSURE) P.R.C.P. 3180-3183 SUNTRUST MORTGAGE, INC., F/K/A CRESTAR MORTGAGE CORPORATION Plaintiff, ¥. KAREN L. SAPORITO Defendant(s). No. 03-6412 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 -$9.56) TOTAL $58,163.99 $1,156.76 and Costs $59,320.75 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. ~o Oo ~ 0 ALL THAT CERTAIN tract of land situate in the Borough of Carlisle, Cumberland County, Pennsylvania, more particularly bounded and described as follows, to wit: BEGINNING at a point on North Pitt Street, corner of land now or formerly of Arthur Keck and land herein conveyed; thence along North Pitt Street, a distance of 17 feet 6 inches, more or less to a point at corner of land now or formerly of Robert McKeon; thence along property now or formerly of Robert McKcon, a distance of 100 feet, more or less, to an alley; thence North along said alley, a distance of 16 feet 6 inches, more or less to a point at corner of said land now or formerly of Arthur Keck; thence West along said land now or formerly Arthur Keck, a distance of 100 feet, more or less to a point in North Pitt Street, the place of beginning. HAVING thereon erected the Northern one-half (1/2) of a frame dwelling house known as 507 North Pitt Street, Carlisle, PA. TITLE TO SAID PREMISES 'IS VESTED IN Karen L. Saparito, Single Individual by Deed from Michael D. Hurley and Patti J. Hurley, His Wife, dated 6/30/1989 and recorded 6/30/1989 in Deed Book Q34 Page 714. Tax Parcel #06-20-1798-059 WRIT OF EXECUTION and/or ATTACHMENT COMMONWEALTH OF PENNSYLVANIA) NO 03-6412 Civil COUNTY OF CUMBERLAND) CIVIL ACTION - LAW TO THE SHERIFF OF CUMBERLAND COUNTY: To satisfy the debt, imerest and costs due SUNTRUST MORTGAGE, INC., F/K/A CRESTAR MORTGAGE CORPORATION, Plaintiff (s) From KAREN L. SAPORITO (1) You are directed to levy upon the property of the defendant (s)and to sell SEE LEGAL DESCRIPTION. (2) You are also directed to attach the property of the defendant(s) not levied upon in the possession of GARNISHEE(S) as follows: and to notify the garnishee(s) that: (a) an attachment has been issued; (b) the garnishee(s) is enjoined from paying any debt to or for the account of the defendant (s) and from delivering any property of the defendant (s) or otherwise disposing thereof; (3) If property of the defendant(s) not levied upon an subject to attachment is found in the possession of anyone other than a named garnishee, you are directed to notify him/her that he/she has been added as a garnishee and is enjoined as above stated. Amount Due $58,163.99 L.L. $.50 Imerest FROM 2/10/04 TO 6/9/04 ~ (PER DIEM - $9.56) - $1,156.76 AND COSTS At~y's Corem % Due Prothy $1.00 Ally Paid $113.45 Other Costs Plaintiff Paid Date: FEBRUARY 10, 2004 (Seal) CURTIS R. LONG Prothonotary Deputy REQUESTING PARTY: Name FRANK FEDERMAN, ESQUIRE Address: ONE PENN CENTER AT SUBURBAN STATION 1617 JOHN F. KENNEDY BOULEVARD, SUITE 1400 PHILADELPHIA, PA 19103q814 A~omey for: PLAINTIFF Telephone: 215-563-7000 Supreme Court ID No. 12248 SUNTRUST MORTGAGE, INC., F/K/A CRESTAR MORTGAGE CORPORATION Plaintiff, KAREN L. SAPORITO Defendant(s). CUMBERLAND COUNTY COURT OF COMMON PLEAS CIVIL DIVISION NO. 03-6412 AFFIDAVIT PURSUANT TO RULE 3129 (Affidavit No. 1) SUNTRUST MORTGAGE, INC., F/K/A CREST.aR MORTGAGE CORPORATION, Plaintiff in the above action, by its attorney, FRANK FEDERMAN, ESQUIRE, sets forth as of the date the Praecipe for the Writ of Execution was filed the following information concerning the real property located at ,507 NORTH PITT STREET, CARLISLE, PA 17013. 1. Name and address of Owner(s) or reputed Owner(s): Name Last Known Address (if address cannot be reasonably ascertained, please indicate) KAREN L. SAPOR/TO 1422 BRADLEY DRIVE, C-114 CARLISLE, PA 17013 2. Name and address of Defendant(s) in the judgment: Same as above 3. Name and last known address of every judgment creditor whose judgment is a record lien on the real property to be sold: Sallie 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) CONSECO FINANCE CONSUMER 332 MINNESOTA STREET, SUITE 610 DISCOUNT COMPANY ST. PAUL, MN 55101 5. Name and address of every other person who has any record lien on the property: NalTle 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: Nalne Last Known Address (if address cannot be reasonably ascertained, please indicate) Tenant/Occupant 507 NORTH PITT STREET CARLISLE, PA 17013 Domestic Relations of Cumberland County 13 North Hanover Street Carlisle, PA 17013 Commonwealth of Pennsylvania Department of Welfare PO Box 2675 Harrisburg, PA 17105 I verify that the statements made in this affidavit are tree and correct to the best of my personal knowledge or information and belief. I tmderstand that false statements herein are made subject to the penalties off8 Pa. C.S. Sec. 4904 relating to unswom falsification to authorities. February 9, 2004 DATE FRANK FEDERMAN, ESQUIRE Attorney for Plaintiff SUNTRUST MORTGAGE, INC., F/K/A CRESTAR MORTGAGE CORPORATION Plaintiff, KAREN L. SAPORITO Defendant(s). TO: KAREN L. SAPORITO 1422 BRADLEY DR/VE, C-114 CARLISLE, PA 17013 CUMBERLAND COUNTY No. 03-6412 February 9, 2004 **THIS FIRM IS A DEBT COLLECTOR ATTEMPTING TO COLLECT A DEBT AND ANY INFORal4ATION OBTAINED WILL BE USED FOR THAT PURPOSE. IF YOU HA VE PRE VIOUSL Y RECEIVED A DISCHARGE IN BANKR UPTCY AND THIS DEBT WAS NOT REAFFIRMED, THIS IS NOT AND SHOULD NOT BE CONSTRUED TO BE AN A TTEMPT TO COLLECT A DEBT, BUT ONLY ENFORCEMENT OF A LIEN AGAINST PROPERTE ** Your house (real estate) at, 507 NORTH PITT STREET, CARLISLE, PA 17013, is scheduled to be sold at the Sherif£s 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 $58~163.99 obtained by SUNTRUST MORTGAGE, INC., F/K/A CRESTAR MORTGAGE CORPORATION (the mortgagee) against you. In the event the sale is continued, an announcement will be made at said sale in compliance with Pa.R.C.P., Rule 3129.3, NOTICE OF OWNER'S RIGHTS YOU MAY BE ABLE TO PREVENT THIS SHERIFF'S SALE To prevent this Sheriffs Sale, you must take immediate action: 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, ifthejudgment 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 fights. The sooner you contact one, the more chance you will have of stopping the sale. (See notice on page two on how to obtain an attorney.) YOU MAY STILL BE ABLE TO SAVE YOUR PROPERTY AND YOU HAVE OTHER RIGHTS EVEN IF THE SHERIFF'S SALE DOES TAKE PLACE. 1. If the Sheriff's Sale is not stopped, your property will be sold to the highest bidder. You may find out the price bid by calling (215) 563-7000. 2. You may be able to petition the Court to set aside the sale if the bid price was grossly inadequate compared to the value of your property, 3. The sale will go through only if the buyer pays the Sheriff the full amount due in the sale. To find out if this has happened, you may call (717) 240-6390. 4. If the amount due fi.om 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 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 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 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 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 tract of land situate ia the Borough of Carlisle, Cumberland County, Pennsylvania, more particularly bounded and described as follows, to wit: BEGINNING at a point on North Pitt Street, corner of land now or formerly of Arthur Keck and land herein conveyed; thence along North Pitt Street, a distance of 17 feet 6 inches, more or less to a point at corner of land now or formerly of Robert McKeon; thence along property now or formerly of Robert McKeon, a distance of 100 feet, more or less, to an alley; thence North along said alley, a distance of 16 feet 6 inches, more or less to a point at corner of said land now or formerly of Arthur Keck; thence West along said land now or formerly Arthur Keck, a distance of 100 feet, more or less to a point in North Pitt Street, the place of beginning. HAVING thereon erected the Northern one-half (1/2) of a frame dwelling house known as 507 North Pitt Street, Carlisle, PA. TITLE TO SAID PREMISES 'IS VESTED IN Karen L. Saparito, Single Individual by Deed from Michael D. Hurley and Patti J. Hurley, His Wife, dated 6/30/1989 and recorded 6/30/1989 in Deed Book Q34 Page 714. Tax Parcel #06-20-1798-059 IN THE COURT OF COMMON PLEAS OF CUMBERLAND COUNTY, PENNSYLVANIA SUNTRUST MORTGAGE, INC., F/FdA CRESTAR MORTGAGE CORPORATION VS. KAREN L. SAPORITO ) CIVIL ACTION ) ) CIVIL DIVISION ) NO. 03-6412 AFFIDAVIT OF SERVICE PURSUANT TO RULE 3129 COMMONWEALTH OF PENNSYLVANIA ) COUNTY OF CUMBERLAND ) SS: I, FRANK FEDERMAN, ESQUIRE attorney for SUNTRUST MORTGAGE~ INC. F/FdA CRESTAR MORTGAGE CORPORATION hereby verify that on February 1L 2004 tree and correct copies of the Notice of Sheriff's sale were served by certificate of mailing to the recorded lienholders, and any kntown interested party see Exhibit "A" attached hereto. DATE: April 26, 2004 FRANK FEDERMAN, ESQUIRE Attorney for Plaintiff COMMONWEALTH OF PENNSYLVANIA COUNTY OF CUMBERLAND t SS: I, Robert P. Ziegler, Recorder of Deeds in and for said County and State do hereby certify that the Sheriff's Deed in which Federal HOme Ln Mtg Corp is the grantee the same having been sold to said grantee on the 9th day of June 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 6412, at the suit of Suntrust Mtg Inc fka Crestar Mtg Coro against Karen L Saporito is duly recorded in Sheriff's Deed Book No. 263, Page 3558. IN TESTIMONY WHEREOF, I have hereunto set my hand and seal of said office this , A.D2004 day of ~-0') R~eeds Suntrust Mortgage, Inc. f/k/a Crestar Mortgage Corporation VS Karen L. Saporito In The Court of Common Pleas of Cumberland County, Pennsylvania Writ No. 2003-6412 Civil Term Jody Smith, Deputy Sheriff, who being duly sworn according to law, states that on March 04, 2004 at 12:35 o'clock PM, she 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: Karen L. Saporito, by making known unto Karen L. Saporito, personally, at The Cumberland County Sheriffs Office, One Courthouse Square, Carlisle, Cumberland County, Pennsylvania, its contents and at the same time handing to her personally the said true and correct copy of the same. Ronald Hoover, Deputy Sheriff, who being duly sworn according to law, states that on April 07, 2004 at 12:51 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 ofKaren L. Saporito located at 507 North Pitt Street, Carlisle, 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 defendant, to wit: Karen L. Saporito, by regular mail to her last known address of 1422 Bradley Drive, C-114, Carlisle, PA 17013. This letter was mailed under the date of April 06, 2004 and never returned to the Sheriffs 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 June 9, 2004 at 10:00 o'clock A.M. He sold the same for the sum of $1.00 to Attorney Frank Federman for Federal Home Loan Mortgage Corporation. It being the highest bid and best price received for the same, Federal Home Loan Mortgage Corporation of Foreclosure Unit, Mail Stop 61, P.O. Box 5000, Vienna, VA 22183-5000 being the buyers in this execution, paid to SheriffR. Thomas Kline the sum of $716.91. Sheriffs Costs: Docketing $30,00 Poundage 14.06 Posting Bills 15.00 Advertising 15.00 Acknowledging Deed 30.00 Auctioneer 10.00 Law Library .50 Prothonotary 1.00 Mileage 6.90 Levy 15.00 Surcharge 20.00 Law Journal 223.55 Patriot News 242.14 Share of Bills 29.26 Distribution of Proceeds 25.00 Sheriffs Deed 39.50 $ 716.91 Sworn and subscribed to before me So Answers: Real EstateODeputy &UNTRUST MORTGAGE, INC., F/K/A CRESTAR MORTGAGE CORPORATION Plaintiff, KAREN L. SAPORITO Defendant(s). CUMBERLAND COUNTY COURT OF COMMON PLEAS CIVIL DIVISION NO. 03-6412 AFFIDAVIT PURSUANT TO RULE 3129 (Affidavit No. 1) SUNTRUST MORTGAGEr INC., F/K/A CRESTAR MORTGAGE CORPORATION, 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 ~507 NORTH PITT STREET, CARLISLE, PA 17013. 1. Name and address of Owner(s) or reputed Owner(s): Name Last Known Address (if address cannot be reasonably ascertained, please indicate) KAREN L. SAPORITO 1422 BRADLEY DRIVE, C-114 CARLISLE, PA 17013 2. Name and address of Defendant(s) in the judgment: Same as above 3. Name and last known address of every judgment creditor whose judgment is a record lien on the real property to be sold: Nalrle 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) ,CONSECO FINANCE CONSUMER 332 MINNESOTA STREET, SUITE 610 DISCOUNT COMPANY ST. PAUL, MN 5510! 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 None Last Known Address (if address cannot be reasonably ascertained, please indicate) 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: Name Ten ant/Occupant Domestic Relations of Cumberland County Commonwealth of Pennsylvania Department of Welfare Last Known Address (if address cannot be reasonably ascertained, please indicate) 507 NORTH PITT STREET CARLISLE, PA 17013 13 North Hanover Street Carlisle, PA 17013 PO Box 2675 Harrisburg, PA 17105 I verify that the statements made in this affidavit are true and correct to the best of my personal knowledge or information and belief. I understand that false statements herein are made subject to the penalties of 18 Pa. C.S. Sec. 4904 relating to unsworn falsification to authorities. February 9. 2004 DATE FRANK FEDERMAN, ESQLrlRE Attorney for Plaintiff SUNTRUST MORTGAGE, INC., : F/K/A CRESTAR MORTGAGE CORPORATION : Plaintiff, : KAREN L. SAPORITO Defendant(s). TO: KAREN L. SAPORITO 1422 BRADLEY DRIVE, C-114 CARLISLE, PA 17013 CUMBERLAND COUNTY No. 03-6412 February 9, 2004 **THIS FIRM IS A DEBT COLLECTOR ATTEMPTING TO COLLECTA DEBTAND 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 ANATTEMPT TO COLLECTA DEBT, BUT ONL YENFORCEMENT OF,4 LIENA GAINSTPROPERTE * * Your house (real estate) at, 507 NORTH PITT STREET, CARLISLE, PA 17013, 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 $58~163.99 obtained by SUNTRUST MORTGAGE, INC., F/K/A CRESTAR MORTGAGE CORPORATION (the mortgagee) against you. In the event the sale is continued, an announcement will be made at said sale in compliance with Pa.R.C.P., Rule 3129.3. NOTICE OF OWNER'S RIGHTS YOU MAY BE ABLE TO PREVENT THIS SHERIFF'S SALE To prevent this Sheriffs Sale, you must take immediate action: The sale will be cancelled if you pay to the mortgagee thc back payments, late charges, costs and reasonable attorney's fees due. To find out how much you must pay, you may calk (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 Sheriff's Sale is not stopped, your property will be sold to the highest bidder. You may find out the price bid by calling (215~ 563-7000. 2. You may be able to petition the Court to set aside the sale if the bid price was grossly inadequate compared to the value of your property. 3, The sale will go through only if the buyer pays the 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 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 thc 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 &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 flied 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 tract of land situate in the BorOugh of Carlisle, Cumberland County, Pennsylvania, more particularly bounded and described as follows, to wit: BEGINNING at a point on North Pitt Street, corner of land now or formerly of Arthur Keck and land herein conveyed; thence along North Pitt Street, a distance of 17 feet 6 inches, more or less to a point at corner of land now or formerly of Robert McKeon; thence along property now or formerly of Robert McKeon, a distance of 100 feet, more or less, to an alley; tlrence North along said alley, a distance of 16 feet 6 inches, more or less to a point at comer of said land now or formerly of Arthur Keck; thence West along said land now or formerly Arthur Keck, a distance of 100 feet, more or less to a point in North Pitt Street, the place of beginning. HAVING thereon erected the Northern one-half (1/2) of a frame dwelling house known as 507 North Pitt Street, Carlisle, PA. ~ ...... TITLE TO SAID PREMISES.IS VESTED IN Karen L. Saparito, Single Individual by Deed from Michael D. Hurley and Patti I. Hurley, His Wife, dated 6/30/1989 and recorded 6/30/1989 in Deed Book Q34 Page 714. Tax Parcel//06-20-1798-059 VfRIT OF EXECUTION and/or ATTACHMENT COMMONWEALTH OF PENNSYLVANIA) NO 03-6412 Civil COUNTY OF CUMBERLAND) CIVIL ACTION - LAW TO THE SHERIFF OF CUMBERLAND COUNTY: To satisfy the debt, interest and costs due SUNTRUST MORTGAGE, INC., F/K/A CRESTAR MORTGAGE CORPORATION~ Plaintiff (s) From KAREN L. SAPORITO (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 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. Amount Due $58,163.99 L.L. $.$0 Interest FROM 2/10/04 TO 6/9/04 - {PER DIEM - $9.56) - $1,156.76 AND COSTS Atty's Conun % Due Prothy $1.00 Atty Paid $113.45 Other Costs Plaintiff Paid Date: FEBRUARY 10, 2004 (Seal) CURTIS R. LONG Prothonotary REQUESTING PARTY: Name FRANK FEDERMAN, ESQUIRE Address: ONE PENN CENTER AT SUBURBAN STATION 1617 JOHN F. KENNEDY BOUI. EVARD, SUITE 1400 PHILADELPHIA, PA 19103-1814 Attorney for: PLAINTIFF Telephone: 215-563-7000 Supreme Court ID No, 12248 Deputy Real Estate Sale # 06 On February 12, 2004 the sherifflevied upon the defendant's interest in the real property situated in The Carlisle Borough, Cumberland County, PA Known and numbered as 507 North Pitt Street, Carlisle, more fully described on Exhibit "A" filed with this writ and by this reference incorporated herein. Date: February 12, 2004 Real Estat~ Deputy THE PATRIOT NEWS THESUNDAY PATRIOT NEWS Proof of Publication UnderAct No. 587, Approved May16, 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 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 D~M~Book "M", Volume 14, Page 317. PUBLICATION C O P Y Sworn to and subscribed befor~ m~s 28th day o~,~May 2.~4 A.D. CllyofHondsbtxg, DauphlnCounly k,~..~K~m,,~, ,~.," - ~ ~ ' My Commissio~ Expires June6.2006 ..,.~.~n, r-u~u,... [ Member, penneylvanlaAl~o01&tlonolNotmlo~Y 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 $ 242.14 Publisher's Receipt for Advertising Cost .~o., publisher of The Patriot-News and The Sunday Patriot-News, newspapers of general dge receipt of the aforesaid notice and publication costs and certifies that the same have PROOF OF PUBLICATION OF NOTICE IN CUMBERLAND LAW JOURNAL (Under Act No. 587, approved May 16, 1929), P. 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 Sournal on the following dates, viz: APRIL 16, 23, 30, 2004 Affiant ftu'ther deposes that he is authorized to verify this statement by the Cumberland Law Journal, a legal periodical of general circulation, and that he is not interested in the subject matter of the aforesaid notice or advertisement, and that all allegations in the foregoing statements as to time, place and character of publication are true. REAL ESTATE 8ALE NO. 6 Writ No. 2003-6412 Civil Suntrust Mortgage, Inc., f/k/a Crestar Mortgage Corporaaon vs. Karen L. Saparito Atty.: Frank Federman ALL THAT CERTAIN tract of land situate in the Borough of Carlisle. Cumberland CountT, Pennsylvania, more partJculaxly bounded and de- scribed as follows, to wit: BEGINNING at a point on North Pitt Street, corner of land now or formerly of Arthur Keck and land herein conveyed; thence tdong North Pitt Street, a distance of 17 feet 6 inches, more or less to a point at comer of land now or formerly of Rober~ McKeon; thence along prop- erty now or formerly of Robert McKeon, a distance of 100 feet, more ~L~sa Marie Co~X~e~ Editor SWORN TO AND SUBSCRIBED before me this 30 .day of APRIL 2004 LOIS E. SNYDER, Notary Public Carlisle Bom, Cumberland Counly My Commission Expires March 5, 2005 situate in the Borough of Carlisle, Cumberland County, Pennsylvania, scribed as follows, to wit: along said alley, a distance of 16 Street, the place of beginrring, Northern one-half (1/2) of a frame dwelling house known as 507 North TITLE TO SAID PREMISES IS VESTED IN Karcn L. Saparito, Single Individual by Deed from Michael D. dated 6/30/1989 and recorded 6/ 30/1989 in Deed Book Q34 Page LOIB E. SNYDER, Not Carlislo Boro, Cumbed~ My Commission Expires