HomeMy WebLinkAbout01-6453FEDERMAN AND PHELAN, LLP
By: FRANK FEDERMAN, ESQUIRE
IDENTIFICATION NO. 12248
ONE PENN CENTER PLAZA, SUITE 1400
PHILADELPHIA, PA 19103
(2is) s~~-ono
GE CAPITAL MORTGAGE SERVICES, INC.
5024 PARKWAY PLAZA BOULEVARD
BUILDING 7/F/C
CHARLOTTE, NC 28217-2407
Plaintiff
v.
ATTORNEY FOR PLAINTIFF
COURT OF COMMON PLEAS
CNIL DNISION
TERM
NO. aI - L~~
l~ LU~C, [ElL.Y~.,
SARA JANE CREELMAN
12 SHIRLEY LANE
BOILING SPRINGS, PA 17007
Defendant(s)
CUMBERLAND COUNTY
**THIS FIRM IS A DEBT COLLECTOR ATTEMPTING TO COLLECT A DEBT AND ANY
INFORMATION OBTAINED WILL BE USED FOR THAT PURPOSE. IF YOU HAVE PREVIOUSLY
RECEIVED A DISCHARGE IN BANKRUPTCY AND THIS DEBT WAS NOT REAFFIRMED, THIS
CORRESPONDENCE IS NOT AND SHOULD NOT BE CONSTRUED TO BE AN ATTEMPT TO COLLECT
A DEBT, BUT ONLY ENFORCEMENT OF A LIEN AGAINST PROPERTY. **
You have been sued in Court. If you wish to defend against the claims set forth in the following
pages, you must take action within twenty (20) days after this Complaint and Notice are served,
by entering a written appearance personally or by attorney and filing in writing with the court
your defenses or objections to the claims set forth against you. You are warned that if you fail to
do so the case may proceed without you and a judgment maybe 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 OR CANNOT AFFORD ONE, GO TO OR TELEPHONE THE OFFICE
SET FORTH BELOW TO FIND OUT WHERE YOU CAN GET LEGAL HELP.
CUMBERLAND COUNTY
CUMBERLAND COUNTY BAR ASSOCIATION
2 LIBERTY AVENUE
CARLISLE, PA 17013
(717) 249-3166
Loan #: 0022099485/KXM
IF THIS IS THE FIRST NOTICE THAT YOU
HAVE RECEIVED FROM THIS OFFICE, BE
ADVISED THAT:
PURSUANT TO THE FAIR DEBT COLLECTION
PRACTICES ACT, 15 U.S.C. § 1692 et seq. (1977),
DEFENDANT(S) MAY DISPUTE THE VALIDITY OF
THE DEBT OR ANY PORTION THEREOF. IF
DEFENDANT(S) DO SO IN WRITING WITHIN
THIRTY (30) DAYS OF RECEIPT OF THIS
PLEADING, COUNSEL FOR PLAINTIFF WILL
OBTAIN AND PROVIDE DEFENDANT(S) WITH
WRITTEN VERIFICATION THEREOF;
OTHERWISE, THE DEBT WILL BE ASSUMED TO
BE VALID. LIKEWISE, IF REQUESTED WITHIN
THIRTY (30) DAYS OF RECEIPT OF THIS
PLEADING, COUNSEL FOR PLAINTIFF WILL
SEND DEFENDANT(S) THE NAME AND ADDRESS
OF THE ORIGINAL CREDITOR, IF DIFFERENT
FROM ABOVE.
THE LAW DOES NOT REQUIRE US TO WAIT
UNTIL THE END OF THE THIRTY (30) DAY
PERIOD FOLLOWING FIRST CONTACT WITH
YOU BEFORE SUING YOU TO COLLECT THIS
DEBT. EVEN THOUGH THE LAW PROVIDES
THAT YOUR ANSWER TO THIS COMPLAINT IS
TO BE FILED IN THIS ACTION WITHIN TWENTY
(20) DAYS, YOU MAY OBTAIN AN EXTENSION OF
THAT TIME. FURTHERMORE, NO REQUEST
WILL BE MADE TO THE COURT FOR A
JUDGMENT UNTIL THE EXPIRATION OF THIRTY
(30) DAYS AFTER YOU HAVE RECEIVED THIS
COMPLAINT. HOWEVER, IF YOU REQUEST
PROOF OF THE DEBT OR THE NAME AND
ADDRESS OF THE ORIGINAL CREDITOR WITHIN
THE THIRTY (30) DAY PERIOD THAT BEGINS
UPON YOUR RECEIPT OF THIS COMPLAINT,
THE LAW REQUIRES US TO CEASE OUR
EFFORTS (THROUGH LITIGATION OR
OTHERWISE) TO COLLECT THE DEBT UNTIL
WE MAIL THE REQUESTED INFORMATION TO
YOU. YOU SHOULD CONSULT AN ATTORNEY
FOR ADVICE CONCERNING YOUR RIGHTS AND
OBLIGATIONS IN THIS SUIT.
Plaintiff is
GE CAPTI'AL MORTGAGE SERVICES, INC.
5024 PARKWAY PLAZA BOULEVARD
BUILDING 7/F/C
CHARLOTTE, NC 28217-2407
The name(s) and last known address(es) of the Defendant(s) are:
SARA JANE CREELMAN
12 SHIRLEY LANE
BOILING SPRINGS, PA 17007
who is the mortgagor and real owner of the property hereinafter described.
3. On 06/30/98, mortgagor, SARA JANE CREELMAN, made, executed and delivered a
mortgage upon the premises hereinafter described to HOMEGOLD, INC. which
mortgage is recorded in the Office of the Recorder of CUMBERLAND County, in
Mortgage Book No. 1465, Page 388. By Assignment of Mortgage recorded 05/19/99, the
mortgage was assigned to PLAINTIFF which Assignment is recorded in Assignment of
Mortgage Book No. 613, Page 350.
4. The premises subject to said mortgage is described as attached.
5. The mortgage is in default because monthly payments of principal and interest upon said
mortgage due 07/06/01 and each month thereafter are due and unpaid, and by the terms
of said mortgage, upon default in such payments for a period of one month, the entire
principal balance and all interest due thereon are collectible forthwith.
6. The following amounts are due on the mortgage:
Principal Balance $51,099.06
Interest 1,656.81
06/06/01 through 10/06/01
(Per Diem $13.47)
Attorney's Fees 1,000.00
Cumulative Late Charges 89.04
06/30/98 to 10/06/01
Cost of Suit and Title Search 554.Q4
Subtotal $54,394.91
Escrow
Credit 0.00
Deficit 4,200.20
Subtotal $4,204.252
TOTAL $58,595.11
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
Sheriffs Sale. If the Mortgage is reinstated prior to the Sale, reasonable attorney's fees
will be charged.
8. This action does not come under Act 6 of 1974 because the original mortgage amount
exceeds $50,000.00.
The Temporary Stay as provided by the Homeowner's Emergency Mortgage Assistance
Program, Act 91 of 1983, has terminated because Defendant(s) have failed to meet with
the Plaintiff or an authorized Credit Counseling Agency in accordance with Plaintiff's
written Notice to Defendants, a true and correct copy of which is attached hereto as
Exhibit "A".
10. By virtue of the death of ARTHUR N. CREELMAN on 03/25/93, SARA JANE
CREELMAN became the sole owner of the mortgaged premises as surviving tenant by
the entireties.
WHEREFORE, PLAINTIFF demands an in rem Judgment against the Defendant(s) in the sum of
$58,595.11, together with interest from 10/06/01 at the rate of $13.47 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.
/s/ Frank Federman
FRANK FEDERMAN, ESQUIItE
Attorney for Plaintiff
I'.O. Box 1225
Charlotte, NC 28201-1225
September 10, 200]
Sara _)ane Creelman
12 Shirley Ln.
Boiling SprinKs PA 17007
003]099A 85/001035/936Am91
RE: Wells Fargo Home Mortgage, Inc. Loan Number 0022099485
Mortgagor(s): Sara Jane Creelman
h4ortgaged Premises: 12 Shirley Ln.
Boiling Spr, P.4 17007
ACT 91 NOTICE
TAKE ACTION TO SAVE
YOUR HOME FROM
FORECLOSURE
This is an official notice that the mortt;a~e on your home is in default, and the lender intends to
foreclose Specific information about the nature of the default is provided in the attached paces.
MORTGAGE
MEET
of
{717) 780-1869).
be able to help to
This Notice contains important legal information. If you have any questions, representatives
at the Consumer Credit Counseling Agency may be able to help explain it. You may also want to
contatt an attorney in your area. The local bar association may be able to help you find a lawyer.
LA NOTIFICACION EN ADJUNTO ES DE SUMA IMPORTANCIA, PUES AFECTA SU DERECHO
A CONTINUAR VIVIENDO EN SU CASA. SI NO COMPRENDE EL CONTENDO DE ESTA
NOTIFICACION OBTENGA UNA TRADUCCION INMEDTI'AMENTE LLAMANDO ESTA
AGENCiA (PENNSYLVANTA HOUSING FINANCE AGENCY) SIN CARGOS AL NUMERO
MENCIONADO ARRIBA. PUEDES SER ELEGIBLE PARA UN PRESTAMO POR EL PROGRAMA
LLAMADO "HOMEOWNER'S EMERGENCY MORTGAGE ASSISTANCE PROGRAM" EL CURL
PUEDE SALVAR SU CASA DE LA PERDIDA DEL DERECHO A RED1Mlli SU Hll'OTECA.
~~HI~IT A
HOMEOWNER'S NAME(S):
PKOPEKTY' AllDKESS:
LOAN ACCT. NO.:
ORIGINAL LENDER:
CURRENT LENDER/SERVICER:
72 Shirle~T n.
Boiling Spr, PA 17007
0022099485
WELLS FARGO HOME MORTGAGE, INC.
HOMEOWNER'S EMERGENCY MORTGAGE ASSISTANCE PROGRAM
MAY BE
ff YOU COMPLY WITH THE PROVISIONS OF THE HOMEOWNER'S EMERGENCY
MORTGAGE ASSTSTANCE ACT OF 1983 (THE "ACT" ), YOU MAY BE ELIGTBLE FOR EMERGENCY
MORTGAGE ASSISTANCE:
• IF YOUR DEFAULT HAS BEEN CAUSED BY CIRCUMSTANCES BEYOND YOUR CONTROL.
• R' YOU HAVE A REASONABLE PROSPECT OF BEING ABLE TO PAY YOUR MORTGAGE
PAYMENTS, AND
• IF YOU MEET OTHER ELIGIBILITY REQUIREMENTS ESTABLISHED BY THE PENNSYLVANIA
HOUSING FINANCE AGENCY.
-- Under the Act, you are entitled to a temporary stay
0 orec osure on your mortgage or t irty (30) days from the date of this Notice. During that time
you must arrange and attend a 'face-to-face" meeting with one of the consumer credit counseling
agencies listed at the end of this Notice. THIS MEETING MUST OCCIIR WITHIN THE NEXT
CONSUME CREDIT COUNSELING AGENCIES - If you meet with one of the consumer credit
counse ing aggencies isle at t e end n t is n7i- once, the lender may NOT take action against you
fo_r thirty (30) days after the date of this meeting. The names, addresseses aT d telephone numbers
meeting. Advise your
,~ is only necessary to scneaute one
your intenttons.
APPLTCATTON FOR MORTGAGE ASSTSTANCE -- Your mortgage is in default for the reasons
set ort later in this Notice (see o owing pages for specific information about the nature of your
default.) If you have tried and are unable to resolve this problem with the lender, you have the
right to appply for financial assistance from the Homeowner's Emergency Mortgage Assistance
Program. To do so, yyou must fill out, sign and file a completed Homeowner's Emergency
Assistance Program Ap lication with one of the designated consumer credit counseling agencies
listed at the end of this Notice. Only consumer credit counseling agencies have applications for
the program and they will assist you to submitting a complete application to the Pennsylvania
Housing Finance Agency: Your application MUST be filed or postmarked within thirty (30) days
of your face-to-face meeting.
YOU MI IST FILE YOUR APPLICATION PROMPTLY. IF YOU FAIL TO DO SO OR IF YOU
DO NOT FOLLOW THE OTHER TIME PERIODS SET FORTH IN THIS LETTER, FORECLOSURE
MAY PROCEED AGAINST YOUR HOME IMMEDIATELY AND YOUR APPLICATION FOR
MORTGAGE ASSISTANCE WILL BE DENIED.
E~H~!~ITA
001036/936
A 1 Y A TI , l~ -- Available funds for emergency, mortgage assistance are very limited. They will
e is urse y t e Agency under the eligibility criteria established by the Act. The Penns}'lvania
Housing Finance Agency has sixty (60) days to make a decision after it receives your application.
During that time, no foreclosure proceedings will be pursued against you if you have met the time
requirements set forth ahove. You will he notified directly by the 1'ennsylvama Housing Finance
Agency of its decision on your application.
NOTE: IF YOU ARE CURRENTLY PROTECTED BY THE FILING OF A PETITION
IN BANKRUPTCY THE FOLLOWING PART OF THIS NOTICE IS FOR INFORMATION
PURPOSES O1~ILY AND SHOULD NOT BE CONSIDERED AS AN ATTEMPT
TO COLLECT THE DEBT.
(If you have filed bankruptcy you can still apply for Emergency Mortgage Assistance.)
HOW TO CURE YOUR MORTGAGE DEFAULT (Brim it up to date).
NATiIRE OF THE DEFAULT - -The MORTGAGF, debt held by the above lender on your property
located at: 12 Shirley Ln
IS SERIOUSLY I D AULT because:
A. YOU HAVE NOT 1~IADE MONTHLY MORTGAGE PAYi\4ENT5 for the following months and
the following amounts are now past due:
~v ~f101 ~y:ptemher ~f101 ~3 (156 RS
Other char es (explain itemize): Lace Char es $0.00
~rher Feec (jf annlicahle) ~ ~~
TOTAL AMOUNT PAST DUE: $2 463.34
B. YOU HAVE FAILED TO TAKE THE FOLLOWING ACTION
HOW R E - -You may cure the default within THIRTY (30} DAYS of the
Gate o t is notice BY PAYIN E TOTAL AMOUNT PAST DUE TO THE LENDER WHICH
IS $ 2,463.34 PLUS ANY MORTGAGE PAYMENTS AND LATE CHARGES WHICH BECOME
DUE DURING THE THIRTY (30) DAY PERIOD. Pa ments must be made either b cash cashier's
check certified check or money order made payable an sent to:
WELLS FARGO HOME MORTGAGE, INC.
1 HOME CAMPUS
X2501-O1H
DES MOINES, IOWA 50328
You can cure any other default by taking the following action within THIRTY (30) DAYS of the date
of this letter:
IF Y U OT_ CURE THEE DE_F,gU~ - - I you do not cure the de ault within THIRTY /30) DAYS
o~ t e ate o this Nonce, t e en er m n to xer 'se its rieh s to acceler g the m rt a e b . Thi
means that the entire outstan3ing a ante o t is e t wi ~e consiaere ue immeacate y an you may
lose the chance to pay the mortga e m monthly installments. If full payment of the total amount past
due is not made within THIRTY ~30) DAYS, the lender also intends to instruct its attorneys to start
legal action to foreclose uaon vour mortgaged vronerty.
IF THE A R~~FQB~ - -The mortgaged property will be sold by the Sheriff
to pay o f t e mortgage a t. teen er re ers your case to its attorneys, but you cure the delinquency
before the lender begins legal proceedings against ou, you will still be required to pay the reasonable
attorney's fees that were actually incurred, up to 50.00. However, if legal proceedings are started
against you, nu will have to pay all reasonable attorney's fees actually incurred by the lender even if
they exceed 50.00. Any attornev's fees will be added to the amount you owe the lender, which may
also include other reasonable costs. If you cure the default within the THIRTY (301 DAY veriod, you
- -The lender may also sue you personally for the unpaid principal
a ante an a of er sums ue under the mortgage.
EXHIBIT A
001035/936
If you have not cured the default
ave beeun, you still have the right
mortaa~e.y Curing your a au t in t e manner set ort in t is notice will restore your mortgage to
same p ios tion as if you had never defaulted.
FARtTFST POSSTRI F. SHF.RTFF'S SAT.F. DATE -- It is estimated that the earliest date that such a
Sheriff's Sale of the mortgaged property could be held would be approximately six (6) months from
the date of this Notice. A notice of the actual date of the Sheriff's Sale will be sent to you before the
sale. Of course, the amount needed to cure the default will increase the longer you wait. You may find
out at any time exactly what the required payment or action will he by contacting the lender.
Name of Lender:
Address:
Phone Number:
Fax Number:
Contact Person:
Wells Farggo Home, Mortgage, Inc.
.5024 1'arkwap Plaza Blvd.
Charlotte, NC 28217
1-800-766-0987
704-423-4016
Tanisha Robinson
EFFECT OF SHFRTFF'S SALE -You should realize that a Sheriff's Sale will end your ownership of
the mortgaged property and your right to occupy it. If you contirn~e to live in the property after the
Sheriff's Sale, a lawswt to remove you and your furnishings and other belongings could be started by
the lender at any time.
ASSUMPTION OF MORTGAGE -- You may or may not sell or transfer your home to
a uyer or trans eree w o wi assume the mortgage debt, provided that all the outstanding payments,
charges and attorney's fees and costs are paid prior to or at the sale and that the other requirements
of the mortgage are satisfied.
YOU MAY ALSO HAVE THE RIGHT:
• TO SELL THE PROPERTY TO OBTAIN MONEY TO PAY OFF THE MORTGAGE DEBT
OR TO BORROW MONEY FROM ANOTHER LENDING INSTITUTION TO PAY OFF
THIS DEBT.
• TO HAVE THIS DEFAULT CURED BY ANY THIRD PARTY ACTING ON YOUR BEHALF.
• TO HAVE THE MORTGAGE RESTORED TO THE SAME POSITION AS IF NO DEFAULT
HAD OCCURRED: IF YOU CURE THE DEFAULT. (HOWEVER, YOU DO NOT HAVE
THIS RIGHT TO CURE YOUR llEFAULT MORE THAN THREh TIMES IN ANY
CALENDAR YEAR.)
• TO ASSERT THE NONEXISTENCE OF A DEFAULT IN ANY FORECLOSURE
PROCEEDING OR ANY OTHER LAWSUIT INSTITUTED UNDER THE MORTGAGE
DOCUMENTS.
• TO ASSERT ANY OTHER DEFF.NSF. YOLJ BF.I.IF.VF. YOL1 MAY HAVF. TO SUCH
ACTION BY THE LENDER.
• TO SEEK PROTECTION UNDER THE FEDERAL BANKRUPTCY LAW.
EKu~~."T A
pEvNSYLV,•1NIa HOUSLYG FINANCE AGE`1CY'
HOMEOWNER'S El4ERGENCY ,~SSISTaNCE PROGR>.~[
CONSUMER CREDIT COUNSELING AGENCIES
(REV. 8100)
PERRY COCNTY
CCCS of'Neste:n Penns}Ivania, Ina Firanral Caursa!irs Scr.:c:s cr Fr'r!!n
3000 Lingiatown Road i l W:st S" Seee:
Harzisburg, P.> ! ;103 Waynesboro. PA f ".63
(; l7) S~tI-1737 F.>.'((; I") 511-t6;0 (; l' 761-i'_33
Urban Lesgue of ~tecopolitan Harrisbur;
? (07 Varth 6° Street
Harrisburg, P.> I7101
(7I7) 13i-:9:i FAX ("!') ~;.t-oa.9
nvea ofcarr,5le
30 [ "G^ S[rca
Carlisle. PA l ; O l3
(717) 113x8!3 F.>.`C ("I"} 11,-3913
PHiL>DELPHL> COC`il'l'
Acom Housing Corparaucn
316 forth Broad Srrr_:
Phdadelphta. P.> 19130
(16)763-1111
CCCS of De!awart Valle}
lily MarketStzrt. SutmU13
Philadeiphta, PA 19107
(3li) 563-5663 FA.7C(1li) 36•t--:660
H.>C~
I6; West.-Vlt,heny Ac:-ue.'_°' Fi.
Phtladetphia. P.> l9l-l0
(1!511.5-50.5 F.X.:..,1_"•-al--
Media Fellowship Reuse
3C1 Suuu't Jackson Sure:
ivledia. PA 1906:
(6:0~ 565-0815 F.>a ~,6!0~ 505-850"
PCC.>
l00 ~crh :"° Suee:
Suitt 500
Philadelphia. P.> 19103
tZtS)56;-'303 F.>.'C~115'~9ti3•d91!
3»: Caa::s Sc:::
13:13' :;:-e"li
>tnerican Credit Counse!ins Insritute
I : =sst 7ek9b tike
F.-~.a i6I0)_65~311
Watulterizasion O~c:
9l; ~liftlin Sort
Huntingdon. P.> 16fi6?=
Can:munih .>c:icn Cornr.ssicn ct
The Gpital .2._ien
l5 t» Cec' S;:...
Harrishur, P.> ! 710- _
N~rh«es: C.;unsti:ns Ser•:.es
5001 vorh Broad Sc:e:
CCCS of ~rr.~a::'~ lire'.
CneCher,,: Hill. Su:[:':i
Chc.•ry Hiil. V! OSCO=
(1151 563.56ti5
Reusing Asscciaacn of 3e:awzr: 'rail='•
1300 walnut Srr:et Sutra 50!
P':uadelph:a. ?.> !910-
Hcus;rs.vscc:aecs ai ~.iz«a::'~-
653 ~cr_':'•cars S~:e:
Grcuo litr.:s:'+
16:0 urscar.. Scr.:
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PE~~SYL~~.~`~L> BCLLETLY, YOL.29. NO.'_3..JL~E =• lgaq
EXHIBIT A
~[~ that certain piece or parcel of land situate in South Middleton
Cumberland County, Pennsylvania. bounded anuste13r11970~nascfollows:
Township, b Thomas, A. Neff, R. S. dated Auq
ante with a survey Y Lana on the
BEGINNING at a point on the Northern side of Shirley
,dividing line between Lots Nos.589~24dfee~ Wes teofethenWesternerighteofgwaY
of Lots, said poan.. also being
int at the dividing
line of L. 49 minutes 50ESecondsnWestel00rfeetntolaepof Shi1as~ said lane '
68 degrees into THENCE by
line between Lots Nos. 18 and l9 on said plan: THENCE along
North 21 degrees 10 minutes~l0'seconds West 120 feet to z ~
the alviding line between Lots Nos. 19 and 31 on said plan North 68 degrees
49 minutes 50,seconds Fast 100 feet to a point; THENCE by the dividing-line
between Lots Nos. 19 and 20 aforesaid South 21 degrees 10 minutes 10 seconds
East 120 feet to a point, the place of BEGINNING.,
i
BEING Lot No. 19 on the Plan of Lots known as Clifton Heights as
recorded in Plan Book 17, Page 59..
HAVING erected thereon a masonry and aluminum siding ranch house.
BEING part of the same premises which. Roy D. Gotshall and Pearl W.
Gotshall, his wife by Deed dated May 22, 1964 and recorded in 'Cumberland
County, in Deed Book F, Vol. 21, Page 336•conveyed unto Clifford L.•Heishman an
and Ethel S. Heishman,his wife. AND being the undivided one-half interest in
and to the same premises .which Clifford L. Heishman and Ethel E., his wife by,
Deed dated November 1, 1967 and recorded in Cumberland County is Deed Book 0,
Volume 22, Page 279 conveyed unto William S. Wert and Lois A. Wert, his wife. ,
PRElIISES: 12 SHIRLEY LANE
VERIFICATION
TAMMY JOHNSON hereby states that she is ASSISTANT VICE PRESIDENT of
WELLS FARGO HOME MORTGAGE, INC. mortgage servicing agent for Plaintiff in this matter,
that she is authorized to take this Verification, and that the statements made in the foregoing Civil Action in
Mortgage Foreclosure are true and correc[ to the best of her knowledge, information and belief. The
undersigned understands that this statement is made subject to the penalties of 18 Pa. C.S. Sec. 4904
relating to unsworn falsification to authorities.
~~~
DATE: ~ ~ BSI ~
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FEDERMAN AND PHELAN
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
(2151 563-7000
GE CAPITAL MORTGAGE SERVICES, INC.
5024 PARKWAY PLAZA BOULEVARD
BUILDING 7/F/C
CHARLOTTE, NC 28217-2407
Plaintiff,
v.
CUMBERLAND COUNTY
COURT OF COMMON PLEAS
CIVIL DIVISION
NO. 01-6453 CIVIL
SARA JANE CREELMAN
Defendant(s).
PRAECIPE FOR JUDGMENT FOR FAILURE TO
ANSWER AND ASSESSMENT OF DAMAGES
TO THE PROTHONOTARY:
Kindly enter judgment in favor of the Plaintiff and against SARA JANE CREELMAN and ,
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 01/16/02 to 06/05/02
TOTAL
$58,595.11
$1373.94
$59,969.05
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.
~lY ~ ~ ,
FRANK FEDERMAN, ESQUIRE
Attorney for Plaintiff
DAMAGES ARE HEREBY ASSESSED AS INDICATE
DATE: ~ ~ / 7 2po d~
PROPROTHY
(Rule of Civil Procedure No. 236) -Revised
IN THE COURT OF COMMON PLEAS OF CUMBERLAND COUNTY, PENNSYLVANIA
CIVIL ACTION -LAW
GE CAPITAL MORTGAGE SERVICES, INC.
5024 PARKWAY PLAZA BOULEVARD
BUILDING 7/F/C
CUMBERLAND COUNTY
COURT OF COMMON PLEAS
Plaintiff,
v.
SARA JANE CREELMAN
Defendant(s).
CIVIL DIVISION
NO. 01-6453 CIVIL
Notice is given that a Judgment in the above-captioned matter has been entered against you on
200
BY~(J.. o ~ ~C
DEPUTY
If you have any questions concerning this matter, please contact:
FRANK FEDERMAN, ESQUIRE
Attorney for Plaintiff
ONE PENN CENTER AT SUBURBAN STATION
1617 JOHN F. KENNEDY BLVD., SUITE 1400
PHII,ADELPHIA, PA 19103-1814
(215)563-7000
**THIS FIRM IS A DEBT COLLECTOR ATTEMPTING TO COLLECT A DEBT AND ANY INFORMATION
OBTAINED WILL BE USED FOR THAT PURPOSE. IF YOU HAVE PREVIOUSLY RECEIVED A DISCHARGE IN
BANKRUPTCY AND THIS DEBT WAS NOT REAFFIRMED, THIS CORRESPONDENCENDENCE IS NOT AND
SHOULD NOT BE CONSTRUED TO BEAN ATTEMPT TO COLLECT A DEBT, BUT ONLY ENFORCEMENT OF A
LIEN AGAINST PROPERTY.**
FEDERMAN AND PHELAN, L.L.P.
Frank Federman, Esquire
Identification No. 12248
One Penn Center Plaza at
Suburban Station, Suite 1400
Philadelphia, PA 19103-1799
(215) 563-7000
GE CAPITAL MORTGAGE SERVICES,
INC.
Plaintiff
vs.
SARA JANE CREELMAN
Defendant(s)
TO: SARA JANE CREELMAN
12 SAIRLEY LANE
SOILING SPRINGS,PA 17007
DATE OF NOTICE: DECEMBER 18. 2001
ATTORNEY FOR PLAINTIFF
COURT OF COMMON PLEAS
CIVIL DIVISION
CUMBERLAND COUNTY
NO. 01-6453 CIVIL
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 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 (10) 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 notice to a lawyer at once. If you do not have a
lawyer or cannot afford one, go to or telephone the following
office to find out where you can get legal help:
CUMBERLAND COUNTY
CUMBERLAND COUNTY BAR ASSOCIATION
2 LIBERTY AVENUE
CARLISLE, PA 17013
(717)249-3166
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Frank Fed rman', quire
Attorney for Plaintiff
FEDERMAN and PHELAN
By: FRANK FEDERMAN
Identification No. 12248
ONE PENN CENTER AT SUBURBAN STATION
1617 JOHN F. KENNEDY BLVD., SUITE 1400
PHILADELPHIA, PA 19103-1814
[2151563-7000
GE CAPITAL MORTGAGE SERVICES, INC.
5024 PARKWAY PLAZA BOULEVARD
BUILDING 7/F/C
ATTORNEY FOR PLAINTIFF
CUMBERLAND COUNTY
COURT OF COMMON PLEAS
Plaintiff,
v.
SARA JANE CREELMAN
Defendant(s).
CIVIL DIVISION
NO.O1-6453 CIVIL
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 lrnowledge 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 SARA JANE CREELMAN is over 18 years of age and resides at ,
12 SHIRLEY LANE, BOILING SPRINGS, PA 17007 .
(c) that defendant is over 18 years of age, and resides at , , .
This statement is made subject to the penalties of 18 Pa. C.S. Section 4904 relating to
unsworn falsification to authorities.
FRANK FE ERMAN, ESQUII2E
Attorney for Plaintiff
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PRAECIPE FOR WRIT OF EXECUTION - (MORTGAGE FORECLOSURE)
P.RC.P.3180-3183
GE CAPITAL MORTGAGE SERVICES, INC. .
Plaintiff, ,
v.
No. 01-6453 CIVIL
SARA JANE CREELMAN
Defendant(s).
TO THE DIRECTOR OF THE OFFICE OF THE PROTHONOTARY:
Issue writ of execution in the above matter:
Amount Due
Interest from 01/15/02 to 06/05/02
(per diem -9.86)
TOTAL
$59,969.05
$1,390.26 and Costs
$61,359.31
~~V
FRANK FEDERMAN, E IRE
One Penn Center at Suburban Station
1617 John F. Kennedy Boulevard, Suite 1400
Philadelphia, PA 19103-1814
Attorney for Plaintiff
Note: Please attach description of property.No.
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~I~ that certain piece or parcel of land situate in South Middleton
Township, Cumberland County, Pennsylvania, bounded and described in zccord-
anee with a survey by Thosas A. Neff, R. 5, dated August 13, 1970, as follows:
BEGINNING at a point on the Northern side o~ Shirley Lane on the
~dividinq line between Lots Nos. 19 and 20 on the hereinafter mentioned Flan
of Lots, said point also being 589.24 feet west of the western right of way
line of L. R, 421008; THENCE along the Northern side of Shirley Lane Sout4
68 dogrees 49 minutes SO seconds West 100 feet to a, point at the dividing
line between Lots Nos. 18 and 19 on said plan: THENCE along last said line
North 21 degrees 10 minutes 10'seeonds West 120 feet to a point; THENCE by
the a:viding Line between Lots Nos, 19 and 31 on said plan North 68 degrees
49 minutes 50,seconds Fast 100 feet to a point; THENCE b
between Lots Nos, I9 and 20 aforesaid So
East 120 feet to a Y the dividing line
point, the place of BEGINNINGegrees 10 minutes 10 seconds
HEING Lot No. 19 on the Plan of Lots known as Clifton Heights as
recorded in Plan Hook 17, Page 59.
HAVING erected thereon a masonry and aluminum siding ranch house.
Gotshall +
HEINh_$awifefb~e same premises which Roy D, Gotshall and Pearl W,
County, in Deed 8ookyF~Volda22d p Ye 23361964 and recorded in Cumberland
and Ethel E. Heishman,his wife, ANDgbein conveyed unto Clifford L.'Heishatari an
and to the same premises .which Clifford L,t'he nndavzded one-half
Deed dated November 1, 1967 and Heishman and Ethel E, iriteresG in
Volume 22, page 279 conve ed recorded in Cumberland Co his wi.e by
Y unto William S, Wert and Lois AY Wert,ehisowife,
PRaffSES: 12 SHIRLEy LAS
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' - GE CAPITAL MORTGAGE SERVICES, INC.
v.
Plaintiff,
SARA JANE CREELMAN
Defendant(s).
CUMBERLAND COUNTY
COURT OF COMMON PLEAS
CIVIL DIVISION
NO.O1-6453 CIVIL
AFFIDAVIT PURSUANT TO RULE 3129
(Affidavit No. l)
GE CAPITAL MORTGAGE SERVICES, INC., 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 ,12 SHIRLEY LANE,
BOILING SPRINGS, PA 17007 .
1. Name and address of Owner(s) or reputed Owner(s):
Name
SARA JANE CREELMAN
Last Known Address (if address cannot be
reasonably ascertained, please indicate)
12 SHIRLEY LANE
BOILING SPRINGS, PA 17007
2. Name and address of Defendant(s) in the judgment:
SARA JANE CREELMAN
12 SHIRLEY LANE
BOILING SPRINGS, PA 17007
Name and last known address of every judgment creditor whose judgment is a record lien on the real
property to be sold:
Name
Last Known Address (if address cannot be
reasonably ascertained, please indicate)
None.
4. Name and address of last recorded holder of every mortgage of record:
PNC BANK NATIONAL ASSOCIATION 2730 LIBERTY AVENUE
PITTSBURG, PA 15222
None.
5. Name and address of every other person who has any record lien on the property:
None.
Last Known Address (if address cannot be
reasonably ascertained, please indicate)
6. Name and address of every other person who has any record interest in the property and whose
interest maybe affected by the sale.
Name
Last Known Address (if address cannot be
reasonably ascertained, please indicate)
None.
7. Name and address of every other person of whom the plaintiff has knowledge who has any interest in
the property which maybe affected by the sale:
Name
Last Known Address (if address cannot be
reasonably ascertained, please indicate)
Tenant/Occupant
Domestic Relations of Cumberland County
Commonwealth of Pennsylvania
Department of Welfare
12 SHIRLEY LANE
BOILING SPRINGS, PA 17007
13 North Hanover Street
Cazlisle, PA 17013
PO Box 2675
Harrisburg, PA 17105
I verify that the statements made in this affidavit aze 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.
January 15. 2002 l
DATE FRANK FEDERM SQUIRE
Attorney for Plaintiff
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FEDERMAN and PHELAN
By: FRANK FEDERMAN
Identif-cation No. 12248
ONE PENN CENTER AT SUBURBAN STATION
1617 JOHN F. KENNEDY BLVD., SUITE 1400
PHILADELPHIA, PA 19103-1814
(215) 563-7000
GE CAPITAL MORTGAGE SERVICES, INC.
Plaintiff,
v.
SARA JANE CREELMAN
Defendant(s).
ATTORNEY FOR PLAINTIFF
CUMBERLAND COUNTY
COURT OF COMMON PLEAS
CIVIL DIVISION
NO. 01-6453 CIVIL
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:
Q an FHA mortgage
() non-owner occupied
() vacant
(X) Act 91 procedures have been fulfilled
This certification is made subject to the penalties of 18 Pa. C.S. Section 4904 relating to unsworn
falsification to authorities.
FRANK FEDERMAN, ESQUII2E
Attorney for Plaintiff
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GE CAPITAL MORTGAGE SERVICES, INC.
Plaintiff,
v.
SARA JANE CREELMAN
Defendant(s).
CUMBERLAND COUNTY
No. 01-6453 CIVIL
January 15, 2002
TO: SARA JANE CREELMAN
12 SHIRLEY LANE
BOILING SPRINGS, PA 17007
* *TH/S FIRM /S A DEBT COLLECTOR ATTEMPT/NG TO COLLECT A DEBT AND ANY /NFORYfAT70N
OBTAINED WILL BE USED FOR THAT PURPOSE. !F YOU HAVE PREY/OUSLY RECEIVED A DISCHARGE /N
BANKRUPTCYAND TH/S DEBT WAS NOT REAFFIRMED, THIS /S NOT AND SHOULD NOT BE CONSTRUED TO BE
AN ATTEMPT TO COLLECT A DEBT, BUT ONLY ENFORCEMENT OF A L/EN AGAINST PROPERTY *
Your house (real estate) at , 12 SHIRLEY LANE, BOILING SPRINGS, PA 17007 is
scheduled to be sold at the Sheriffs Sale on JUNE 5, 2002 at 10:00 a.m. in the Cumberland County
Courthouse, South Hanover Street, Carlisle, PA 17013, to enforce the court judgment of 59,969.05
obtained by GE CAPITAL MORTGAGE SERVICES. INC. (the mortgagee) against you. If the
Sheriff's sale is postponed, the property will be relisted for the Sheriff's Sale.
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 chazges,
costs and reasonable attorney's fees due. To find out how much you must pay, you may
call: (2151563-7000.
2. You maybe 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 onc, th:: more chane~
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 (2151563-7000.
2. You maybe able to petition the Court to set aside the sale if the bid price was grossly
inadequate compared to the value of your property.
3. The sale will go through only if the buyer pays the Sheriff the full amount due in the sale. To
find out if this has happened, you may call (717) 240-6390.
4. If the amount due from the Buyer is not paid to the Sheriff, you will remain the owner of the
property as if the sale never happened.
5. You have the right to remain in the property until the full amount due is paid to the Sheriff
and the Sheriff gives a deed to the buyer. At that time, the buyer may bring legal proceedings to evict
you.
6. You maybe 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
~I1 that certain piece or parcel of la:.d situate South Midd_etcn
Township, Cu.~herland County, Pennsylvania, bounded and described is acccrd-
anca with a survey by Thocas A. Neff, R. S. dated Acgust 13, 197, as fcllcws:
DEGI27NING at a point on the Northern side of Shirley Lane or. t:e
dividing line between Lots Nos. 19 and 20 on the hereinafter mentioned Flan
o: Lots, said point also being SS9.2q feet West o: the Western right o: way
line of L. R. (21008; TH~aC2 along the Northern side of Shirley Lane Scuth
68 dogrees q9 minutes 50 seconds West 100 feet to a point at the dividing
line between Lots Nos. I8 and 19 on said plan: THENCE aicng last said line
North 2i degrees 10 minutes 20'seeonds West 120 feet to z Feint; T3E::C~ by
the aividing Line between Lots Nos. I9 and 31 on said plan North 63 degrees
b¢tweentLotsONoscol9sands201aforesaidoSouth;2l~deHL•N~cE by t:e dividing Iine
East 120 feat to a point, the place of BEGI:NI:iG.g~e_s IO minutes 10 seconds
BEING Lot No. 19 on the Plan o: Lots kiown as Clifton Heights as
recorded in Plan Book 17, Page 59.
HaVTNG erected thereon a masonry and alumizua siding ran eh house.
BEING part of the same premises which Hoy D. Wtshail and Peari 'A.
Wtshail, his wife by Deed dated ~1ay 22, 1964 and recorded i Cuatberland
County, in Deed Book F, Vol. 2I, Page 336 conveyed onto Clifford L.'Beis'.zman ,V:
and Ethel S. lieishaan,his wife. AND being t:e undivided one-half interest in
and to t'~e sane premises.whieh Clifford L. Heishman and Ethel c^., his wife by
Deed dated November 1, 1967 and recorded in Cumberland County is peed Bock 0,
Volume 22, Page 279 conveyed unto William S. Wert and Lois A. Wert, his wife.
PRII'IISES: 12 SHIRLEY ~E
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AFFIDAVIT OF SERVICE
PLAINTIFF GE CAPITAL MORTGAGE SERVICES,
INC.
DEFENDANT(S) SARA JANE CREELMAN
SERVE SARA JANE CREELMAN AT
12 SHIRLEY LANE
BOILING SPRINGS, PA 17007
Served and made known to _
at ~_ ~~ ,o'clock g.m.,
of Pennsylvania, in the manner described below:
Defendant personally served.
Adult family member with whom Defendant(s) reside(s). Relationship is
Adult in charge of Defendant(s)'s residence who refused to give name or relationship.
Manager/Clerk of place of lodging in which Defendant(s) reside(s).
Agent or person in charge of Defendant(s)'s office or usual place of business.
an officer of said Defendant(s)'s company.
Commonwealth
Other:
_ ~ .' I~' ~a85cS
Description: Age ~ O Height 3G Weight ~~ Race w~ Sex ~ Other
I G ~ 2FeN t ~ ~, , C9 R-~ ~ ' ~a competent adult, being duly sworn according to law, depose and state that I personally handed
a true 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 subscri ed ~TM M. JOFIAF'13
before me this aZB day ~~~'' jpps
of `.faNvac , 200 a„
PLE ATTEMPT SERVICE AT LEAST 3 TIMES. INDICATE TES & TIMES OF SERVICE ATTEMPED.
NOT SERVED
On the day of , 200_, at o'clock - m., Defendant NOT FOUND because
Moved _ Urtlmown _ No Answer Vacant
Other:
Sworn to and subscribed
before me this day
of , 200 _.
Notary: By:
Attorney for Plaintiff
Frank Federman, Esquire - I.D. No. 12248
One Penn Center at Suburban Station
1617 John F. Kennedy Boulevard, Suite 1400
Philadelphia, PA 19103-1814
(21~ 563-7000
CUMBERLAND COUNTY
No. 01-6453 CIVIL
ACCT. #0022099485
Sale Date: JUNE 5, 2002
Type of Action
-Notice of Sheriff s Sale
SERVE , r
So''IftZ TaNe C~~e' ~3N ~`~` ~a~
Defendant, on the ~_ day of , 200 ~
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GE CAPITAL MORTGAGE SERVICES, INC.
Plaintiff,
v.
SARA JANE CREELMAN
Defendant(s).
CUMBERLAND COUNTY
COURT OF COMMON PLEAS
CIVIL DIVISION
NO.Ol-6453 CIVIL
AMENDED AFFIDAVIT PURSUANT TO RULE 3129
(Affidavit No. 1)
GE CAPITAL MORTGAGE SERVICES, INC., 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 ,12 SHIRLEY LANE,
BOILING SPRINGS. PA 17007.
1. Name and address of Owner(s) or reputed Owner(s):
Name
SARA JANE CREELMAN
Last Known Address (if address cannot be
reasonably ascertained, please indicate)
12 SHIRLEY LANE
BOILING SPRINGS, PA 17007
2. Name and address of Defendant(s) in the judgment:
SARA JANE CREELMAN
12 SHIRLEY LANE
BOII,ING SPRINGS, PA 17007
3. Name and last known address of every judgment creditor whose judgment is a record lien on the real
property to be sold:
Name
Last Known Address (if address cannot be
reasonably ascertained, please indicate)
None.
4. Name and address of last recorded holder of every mortgage of record:
PNC BANK NATIONAL ASSOCIATION
2730 LIBERTY AVENUE
PITTSBURGH, PA 15222
CITIFINANCIAL INC.
5520 CARLISLE PIKE, SUITE 155
MECHANICSBURG, PA 17055
5. Name and address of every other person who has any record lien on the property:
None.
Last Known Address (if address cannot be
reasonably ascertained, please indicate)
6. Name and address of every other person who has any record interest in the property and whose
interest maybe affected by the sale.
Name
Last Known Address (if address cannot be
reasonably ascertained, please indicate)
COMMONWEALTH OF PENNSYLVANIA
BUREAU OF INDNIDUAL TAX
INHERITANCE TAX DNISION
ATTENTION: JOHN MURPHY
INTERNAL REVENUE SERVICE
FEDERATED INVESTORS
TOWER
6r" FLOOR, STRAWBERRY SQUARE
DEPT. 280601
HARRISBURG, PA 17128
13T" FLOOR, SUITE 1300
1001 LIBERTY AVENUE
PITTSBURGH, PA 15222
DEPARTMENT OF PUBLIC WELFARE TPL P.O. BOX 8486
CASUALTY UNIT ESTATE RECOVERY WILLOW OAK BUILDING
PROGRAM
HARRISBURG, PA 17105-8486
7. Name and address of every other person of whom the plaintiff has lrnowledge who has any interest in
the property which maybe affected by the sale:
Name
Last Known Address (if address cannot be
reasonably ascertained, please indicate)
Tenant/Occupant
Domestic Relations of Cumberland County
Commonwealth of Pennsylvania
Department of Welfare
12 SHII2LEY LANE
BOILING SPRINGS, PA 17007
13 North Hanover Street
Carlisle, PA 17013
PO Bos 2675
Harrisburg, PA 17105
" I verify that the statements made in this affidavit aze true and correct to the best of my personal
knowledge or information and belief. I understand that false statements herein are made subject to the
penalties of 18 Pa. C.S. Sec. 4904 relating to unsworn falsification to authorities.
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April 19. 2002 /
DATE FRANK FEDERMAN, ESQUII2E
Attorney for Plaintiff
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IN THE COURT OF COMMON PLEAS OF CUMBERLAND COUNTY,
PENNSYLVANIA
RE: GE CAPITAL MORTGAGE SERVICES, INC. )CIVIL ACTION
vs.
SARA JANE CREELMAN) CIVIL DIVISION
NO. 01-6453 CIVIL
AFFIDAVIT OF SERVICE PURSUANT TO RULE 3129
COMMONWEALTH OF PENNSYLVANIA )
COUNTY OF CUMBERLAND ) SS:
I, FRANK FEDERMAN, ESQUIRE attorney for GE CAPITAL
MORTGAGE SERVICES, INC. hereby verify that on 1116102 8~ 4/19102 true and
correct copies of the Notice of Sheriffs sale were served by certificate of mailing
to the recorded lienholders, and any known interested party see Exhibit "A"
attached hereto. Notice of Sale was sent to the Defendant(s) on 4/19/02 by
certified mail return receipt requested see Exhibit "B" attached hereto.
~...~ P
DATE: May 2. 2002 FR INK FEDERMAN, ESQUIRE
Attorney for Plaintiff
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I
TO: SARA JANE GREELMAN
i 12 SHIRLEY LANE
I BOILING SPRINGS, PA 17007
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SENDER: TEAM 5
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REFERENCE: CREELMAN, SARA JANE
~ RETURN
I Postage
1 RECEIPT ~~~ Fee
SERVICE
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Relum Receipt Fee
j Restricted t~livery 3.20
I Total Postage & Fees
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GE Capital Mortgage Services, Inc.
VS
Sara Jane Creelman
In The Court of Common Pleas of
Cumberland County, Pennsylvania
Writ No. 2001-6453 Civil Term
R. Thomas Kline, Sheriff, who being duly sworn according to law, states this writ
is returned STAYED pursuant to instructions from Attorney Frank Federman.
Sheriff s Costs:
Docketing 30.00
Surcharge 20.00
Law Library .50
Prothonotary 1.00
Mileage 6.90
Levy 15.00
Advertising 15.00
Posting Handbills 15.00
Share of Bills 25.20
Poundage 14.64
Law Journal 330.50
Patriot News 251.35
Certified Mail 1,72
Postpone Sale 20.00
$746.81 paid by attorney
09/03/02
Sworn and subscribed to before me So Answer
This ~i~ dayof,k~ ~%!~~,x.,p''
~~ R. Thomas Kline, Sheriff
2002, A.D. , p,~
Prothonotary Real Estate Deputy
1,
~ .~ ~Od ~
~, /~9~/~
GE CAPITAL MORTGAGE SERVICES, INC:
v.
Plaintiff,
SARA JANE CREELMAN
Defendant(s).
CUMBERLAND COUNTY
COURT OF COMMON PLEAS
CIVIL DIVISION
NO.Ol-6453 CIVIL
AFFIDAVIT PURSUANT TO RULE 3129
(Affidavit No. 1)
GE CAPITAL MORTGAGE SERVICES, INC., Plaintiff in the above action, by its attorney,
FRANK FEDERMAN, ESQUIItE, sets forth as of the date the Praecipe for the Writ of Execution was
filed the following information concerning the real property located at ,12 SHIRLEY LANE,
BOILING SPRINGS. PA 17007 .
1. Name and address of Owner(s) or reputed Owner(s):
Name
SARA JANE CREELMAN
Last Known Address (if address cannot be
reasonably ascertained, please indicate)
12 SHIRLEY LANE
BOILING SPRINGS, PA 17007
2. Name and address of Defendant(s) in the judgment:
SARA JANE CREELMAN
12 SHIRLEY LANE
BOILING SPRINGS, PA 17007
3. Name and last known address of every judgment creditor whose judgment is a record lien on the real
property to be sold:
Name
Last Known Address (if address cannot be
reasonably ascertained, please indicate)
None.
4. Name and address of last recorded holder of every mortgage of record:
PNC BANK NATIONAL ASSOCIATION 2730 LIBERTY AVENUE
PITTSBURG, PA 15222
None.
5. Name and address of every other person who has any record lien on the property:
None.
Last Known Address (if address cannot be
reasonably ascertained, please indicate)
6. Name and address of every other person who has any record interest in the property and whose
interest maybe affected by the sale.
Name Last Known Address (if address cannot be
reasonably ascertained, please indicate)
None.
7. Name and address of every other person of whom the plaintiff has knowledge who has any interest in
the property which maybe affected by the sale:
Name
Last Known Address (if address cannot be
reasonably ascertained, please indicate)
Tenant/Occupant
Domestic Relations of Cumberland County
Commonwealth of Pennsylvania
Department of Welfare
12 SHIRLEY LANE
BOILING SPRINGS, PA 17007
13 North Hanover Street
Carlisle, PA 17013
PO Box 2675
Hamsburg, 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.
January 15, 2002 ~ i
DATE FRANK FEDERM SQUIRE
Attorney for Plaintiff
GE CAPITAL MORTGAGE SER~CES, I1t1C.
plaintiff,
v.
SAR4 JANE CREELMAN
Defendant(s).
TO: SARA JANE CREELMAN
12 SHIRL,EY LANE
GS PA 17007
CUMBERLAND COUNTY
No. 01-6453 CIVIL
January 15, 2002
BOILING SPRIN '
IS A DEBT COLLECTOR AETEMPTING TO COLLECT DEBT AND ANY INFORMATI
IF YOU HAVE PREVIOUSLY RECEIVED A DISCHARGE IN
HOULD NOT BE CONSTRUED TO BE
**THIS FIRM
OBTAINED WILL BE USED FOR TNAT PURPO
MPT TO COLLECT A DEBT, BUT ONLY ENFORCEMENT OF A LIEN AG.4I,NST PROPERT .
BANKRUPTCY AND THIS DEBT WAS NOT REAFFIRMED. THIS IS NOT A ING SPRINGS PA 17007 is
bun ,
ANATTE Ey LANE FOIL
5 2002 at 10:00 a.m. in the Cumberland
Your house (real estate) at 12 SHIRL ud ent of 59 9_~ 6
pA 17013, to enforce the court j ~ ainst you. If the
scheduled to be sold at the Sheriff s Sale on JUNy NC (the mortgagee) ag
Courthouse, GE CAPITAL MORTGAGE SER
obtained by the property will be relisted for the Sheriff s Sale.
Sheriff s sale is postponed, GHTS
NOTICE OF OWNER'S RI
To prevent this Sheriffs Sale, you must take immediate action:
to the mortgagee the back payments, late charges,
's fees due. To find out how much you must pay> you mad
1 The sale will be cancelled if you Pay
costs and reasonable attorney
call: (2151~0~ etition asking the Court to strike or open
be able to stop the sale by filing a p also ask the Court to
2 You may ent was improperly entered. You may.
judgment, if the jud~ood cause.
postpone the sale for g
3 You may also be able to stop the sale through other legal proceedings
to assert your rights. The sooner you contact ou4, ~~~< <n" ~ `''y~
You may need an attorney a e two on how to obtain an attorney)
you will have of stopping the sale. (See notice on p g
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 maybe able to petition the Court to set aside the sale if the bid price was grossly
inadequate compared to the value of your property.
3. The sale will go through only if the buyer pays the Sheriff the full amount due in the sale. To
find out if this has happened, you may call (717) 240-6390.
4. If the amount due from the Buyer is not paid to the Sheriff, you will remain the owner of the
property as if the sale never happened.
5. You have the right to remain in the property until the full amount due is paid to the Sheriff
and the Sheriff gives a deed to the buyer. At that time, the buyer may bring legal proceedings to evict
you.
6. You maybe 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) aze 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
~1( that certain piece or parcel o_° Ia:.d ituatz South ni^..:eton
Tovnahip, Cu.~`~eriand Cou:.ty, Pennsylva:.ia, bou:.ded and desc_ihed is zcce_c-
aace with a survey by Thocas A. lie.`t, R. 5, dated Auc,,st 13, 197J, as fcilcw3:
~l~ that certain piece or parcel o: la:.d ituata Sout:1 nidd:eton
Township, Cu.~~erlaad Cou:.ty, Pennsy'_vania, bounded and descrifed is acccrd-
anCe with a surrey by Tho.;as A. lief:, R. S, dated August i3, l9'/J, as foilcw3:
BEGiY;JiYG at a point On the NCrtle r: .,~de O~ J: _ 1~?V :.3 2 GP. a'
.dividing line between Lots nos. 19 ar.d 20 on the here'_nafter mentioned r'laa
o: Lots, said paint also beirq 539.24 feet West o: t:^.e i:esta-i r'_q~t of w~;,j
line of L. R. 321008; TY~:1C2 along t::e Norther:: side of Shirle ~ Lane Soot..`:
68 dogrees 47 minutes 50 seccnds West i00 feet to a,point at the dividing
line bet•.reen Lots Nos. 18 and 19 on said plan: THE:7CE along last said line
North 2I degrees 10 minutes 10'seccnds hest 1:0 test to a ^cint; THEI:Cr by
the alviding line between Lots Nos. 19 and 31 on said plan Norty 63 degrees
d9 minutes 50,seconds Fast 100 feet to a Foist; THcNCE by t::e dividing line
between Lots Nos, 19 and 20 aforesaid South 2i degrees IO :nilutes 1J seconds
East I20 feet to a point, t`t~ place of 3EGZ.WING,
3ET:7G Lot No. 19 on the Plan of Lots known as Clifton F?eights as
recorded in Plan Book 17, Page 59.
HAVTNG erected tyereon a masonry and alw:.ilua siding ranch ho us a.
Wtshall,Vhisawifetby~Deedmdated,~ys22h1i96goanQ~recordedl+andC~e~baerland
County, in Deed gook F, Vol. 2i, Page 336 conveyed wzto Clifford L.'Heishman .v:
and Ethel S, Fieishaan,his wife. A.`1D beiny t.:e u^.divided one-half interest in
and to the sate prim+ses which C1ifFord L. Heishman aid Et:~el E., his wife by
Deed dated November 1, 1967 and recorded in Cu.:,berland County is peed Bobk 0,
Volume 22, page 279 conveyed unto William S, Wert and Lois ~. Wert, his wife.
PBII'IISES: 12 SBIRLEY LAKE
WRIT OF EXECUTION and/or ATTACHMENT
COMMONWEALTH OF PENNSYLVANIA)
COUNTY OF CUMBERLAND)
NO 01-6453 Civil
CIVIL ACTION -LAW
TO THE SHERIFF OF Cumberland COUNTY:
To satisfy the debt, interest and costs due GE CAPITAL MORTGAGE SERVICES, INC.
PLANTIFF(S)
From SARA JANE CREELMAN, 12 SHIRLEY LANE, BOILING SPRINGS, PA 17007
(1) You are directed to levy upon the property of the defendant(s) and [o sell SEE LEGAL
DESCRIPTION
(2) You are also directed [o 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 aze duetted to notify him/her that he/she has been added as a
garnishee and is enjoined as above stated.
Amount Due $59,969.05 L.L. $.50
Interest FROM 1/15/02 TO 6/5/02 (PER DIEM - 9.86) $1,390.26 AND COSTS
Atty's Comm % Due Prothy $L00
Atty Paid $103.25 Other Costs
Plaintiff Paid
Date: JANUARY 17, 2002 CURTIS R. LONG
Prothonotary, Civil Division
By' ~/l2r'y ~ / ' / ~~L ~~
REQUESTING PARTY:
Name FRANK FEDERMAN, ESQUIRE
Address: ONE PENN CENTER AT SUBURBAN STATION
1617 JOHN F. KENNEDY BOULEVA RD, SUITE 1400
PHILADELPHIA, PA 19103-1814
Attorney for: PLAINTIFF
Telephone: 215-5 63-7000
Supreme Court ID No. 12248
TRUE DOPY FROM RECORD
M Tu.~ti,I~o~I ~ab~I:,a„~af~,e I h~r~tcalg¢alsst mpyhand
~''~"pp a°~ ?~0 t'~ ~riC~.~"rI 411~.;i' i a.{4 L~ti~ fY.
rn~°r~-~ ~A9 ~- Sr ~;,
On February 6, 2002, the sheriff levied upon the
defendant's interest in the real property situated in
South Middleton Township, Cumberland County, PA,
known and numbered as 12 Shirley Lane, Boiling Springs,
and more fully described on Exhibit "A" filed
with this writ and by this reference incorporated herein.
Date: February 6, 2002
BY~ ~OU-L-(
Real Estate Deputy
,,,!'lyn~~Sthld~d
10~ ,, , no ~i hZ N°C
n (10
A1H~ : : ~tj.~9
jjiN~~i` irtl 1v ~
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.
Roger M. Morgenthal, 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 26, MAY 3, 10, 2002
Affiant further deposes that he is authorized to verify this statement by the Cumberland
Law Journal, a legal periodical of general circulation, and that he is not interested in the subject
matter of the aforesaid notice or advertisement, and that all allegations in the foregoing
statements as to time, place and character of publication are true.
Ro er M. Morgenthal, Editor
SWORN TO AND SUBSCRIBED before me this
10 day of MAY, 2002_
LOiS ~°. 4Y[DeR, Notary PubgC
Ca~a:~ flora, Cumberlarb Cou~1l
mAy C;¢;:srdssfar Expires Ater~h 5, ~6
REAL ESTATE SALE NO. 8
Writ No. 2001-6453 Civil
GE Capital Mortgage
Services, Inc.
vs.
Sara Jane Creelman
Atty.: Frank Federman
ALL that certain piece or parcel
of land situate in South Middleton
Township, Cumberland County.
Pennsylvania, bounded and de-
scribed 1n accordance with a stu'-
vey by Thomas A. Neff. R. S. dated
August 13. 1970, as follows:
BEGINNING at a point on the
Northern side of Shirley Lane on the
dividing line between Lots Nos. 19
and'20 on the hereinafter mentioned
Plan of Lots, sold point also being
559.24 feet West of the Western
right of way line of L. R. N2100S:
THENCE along the Northern side of
Shirley Lane South 6S degrees 49
minutes 50 seconds West 100 feet
to a point at the dividing line be-
tween Lots Nos. 18 and 19 on said
plan; THENCE along last said line
North 21 degrees 10 minutes 10
seconds West 120 feet to a point:
THENCE by the dividing line be-
tween Lots Nos. 19 and 31 on said
plan North 6S degrees 49 minutes
50 seconds East 100 feet to a point;
THENCE by the dividing line be-
tween Lots Nos. 19 and 20 afore-
said Sou[h 21 degrees 10 minutes
10 seconds East 120 feet to a point,
the place of BEGINNING.
BEING Lot No. 19 on the Plan of
Lots known as Clifton Heights as
recorded in Plan Book 17, Page 59.
HAVING erected thereon a ma-
sonry and aluminum siding ranch
house.
BEING part of the same premises
which Roy D. Gotshall and Peazl W.
Gotshall, his witeby Deed dated
May 22. 1964 and recorded in
Cumberland County. in Deed Book
F. Vol. 21. Page 336 conveyed unto
Clifford L. Heishman and Ethel E.
Heishman, his wife. AND being the
undivided one-half interest in and
to [he same premises which Clifford
L. Heishman and Ethel E., his wife
by Deed dated November 1. 1967
and recorded in Cumberland County
in Deed Book O. Volume 22, Page
279 conveyed unto William S. Wert
and Lois A. Wert, his wife.
PREMISES: 12 SHIRLEY LANE.
~-
THE PATRIOT NEWS
THE SUNDAY PATRIOT NEWS
Proof of Publication
Under Ad No. 587, Approved May 16,1929
Commonwealth of Pennsylvania, County of Dauphin) ss
Frank J. Epley 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 Patrict-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 23rd and 30th day(s) of April 2002 and the
7th day(s) of May 2002. That neither he nor said Company is interested in the subject matter of said printed notice
or advertising, and that all of the allegations of this statement as to the time, place and character of publication are
true; and
That he has personal knowledge of the facts aforesaid and is duly authorized and empowered to verify this
statement on behalf of The Patriot-News Co. aforesaid by virtue and pursuant to a resolution unanimously passed and
adopted severally by the stockholders and board of directors of the said Company and subsequently duly recorded in
the office for the Recording of Deeds in and for said County of Dauphin in Miscellaneous Book "M",
Volume 14, Page 317.
-
PUBLICATION C'
. ~~...~,, :..............................
~ ................
COPY ...
Sworn 17th o y 200 D.
SALE #8 NotaAal Seal Z~
Terry L. Ruscpll, Notary Pubsc
tieniseurg, DauphNr County TARY PUBLIC
My canmissionE~iresJunes, mission expires June 6, 2002
Member, Pennsylvania Association of Notaries
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 $ 249.60
Probating same Notary Fee(s) $ 1.75
Total $ 251.35
Publisher's Receipt for Advertising Cost
The Patriot News Co., publisher of The Patriot-News and The Sundav Patriot-N ws, newspapers of general
circulation, hereby acknowledge receipt of the aforesaid notice and publication costs and certifies that the same have
been duly paid.
By ....................................................................
~=
r
(800) 990-9108
PRAECIPE FOR WRIT OF EXECUTION - (MORTGAGE FORECLOSURE)
P.R.C.P. 3180-3183
GE CAPITAL MORTGAGE SERVICES, INC.
Plaintiff,
v.
SARA JANE CREELMAN
Defendant(s).
No. 01-6453 CIVIL
TO THE DIRECTOR OF THE OFFICE OF THE PROTHONOTARY:
Issue writ of execution in the above matter:
Amount Due
Add'1 cost
Interest from to DECEMBER 6, 2006
(per diem -$9.86)
$59,969.05
$3,677.00
$01 / 15/02 TO 12/6/06 and Costs
TOTAL
$17,609.96
DANIEL G. SCHMIEG, ESQUIRL~
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.
IMPORTANT NOTICE: This property is sold at the direction of the
plaintiff. It may not be sold in the absence of a representative of
the plaintiff at the Sheriff's Sale. The sale must be postponed or
stayed in the event that a representative of the plaintiff is not
present at the sale.
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ALL THAT CERTAIN piece or parcel of land situate in South Middleton Township, Cumberland
County, Pennsylvania, bounded and described in accordance with a survey by Thomas A. Neff, R. S.
dated August 13, 1970, as follows:
BEGINNING at a point on the Northern side of Shirley Lane on the dividing line between Lots Nos.
19 and 20 on the hereinafter mentioned Plan of Lots, said point also being 589.24 feet West of the
Western right of way line of L. R. #21008; thence along the Northern side of Shirley Lane South 68
degrees 49 minutes 50 seconds West 100 feet to a point at the dividing line between Lots N,os. 18 and
19 on said Plan; thence along last said line North 21 degrees 10 minutes 10 seconds West 120 feet to
a point; thence by the dividing line between Lots Nos. 19 and 31 on said Plan North 68 degrees 49
minutes 50 seconds East 100 feet to a point; thence by the dividing line between Lots Nos. 19 and 20
aforesaid South 21 degrees 10 minutes 10 seconds East 120 feet to a point, the place of beginning.
BEING Lot No. 19 on the Plan of Lots known as Clifton Heights as recorded in Plan Book 17, Page
59.
HAVING, erected thereon a masonry and aluminum siding ranch house.
TITLE TO SAID PREMISES IS VESTED IN Sara Jane Creelman by reason of the following:
BEING THE SAME premises which Clifford L. Heishman and Ethel E. Heishman, his wife and
William S. Wert and Lois A. Wert, his wife by Deed dated 8/31/1970 and recorded 9/15/1970 in
the County of Cumberland in Deed Book Volume 23, Page 385 conveyed unto Arthur N. Creelman
and Sara Jane Creelman, his wife.
AND THE SAID Arthur N. Creelman died on 3/25193 whereby title to said premises became vested
in Sara Jane Creelman by right of survivorship.
Tax Map #27-1921, Parcel 2
Premises: 12 SHIRLEY LANE, TOWNSHIP OF SOUTH MIDDLETON
CUMBERLAND COUNTY
PENNSYLVANIA
r. - .
GE CAPITAL MORTGAGE SERVICES, INC.
Plaintiff,
v.
SARA JANE CREELMAN
Defendant(s).
CUMBERLAND COUNTY
COURT OF COMMON PLEAS
CIVIL DIVISION
NO.Ol-6453 CIVIL
AFFIDAVIT PURSUANT TO RULE 3129
(Affidavit No. l)
GE CAPITAL MORTGAGE SERVICES~INC., Plaintiff in the above action, by its attorney,
DANIEL G. SCHMIEG, ESQUIRE, sets forth as of the date the Praecipe for the Writ of Execution was
filed the following information concerning the real property located at ,12 SHIRLEY LANE,
BOILING SPRINGS. PA 17007 .
1. Name and address of Owner(s) or reputed Owner(s):
Name
SARA JANE CREELMAN
Last Known Address (if address cannot be
reasonably ascertained, please indicate)
12 SHIRLEY LANE
BOILING SPRINGS, PA 17007
2. Name and address of Defendant(s) in the judgment:
Same as above
3. Name and last known address of every judgment creditor whose judgment is a record lien on the real
property to be sold:
Name
Last Known Address (if address cannot be
reasonably ascertained, please indicate)
None
~ ~~
f
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)
2730 LIBERTY AVENUE
PNC BANK NATIONAL ASSOCIATION PITTSBURGH, PA 15222
CITIFINANCIAL INC. 5520 CARLISLE PIKE STE 155
MECHANICSBURG, PA 17055
5. Name and address of every other person who has any record lien on the property:
Name Last Known Address (if address cannot be
reasonably ascertained, please indicate)
None
6. Name and address of every other person who has any record interest in the property and whose
interest may be affected by the sale.
Name Last Known Address (if address cannot be
reasonably ascertained, please indicate)
None
7. Name and address of every other person of whom the plaintiff has knowledge who has any interest in
the property which may be affected by the sale:
,. . ~ame
,..
Tenant/Occupant
Domestic Relations of Cumberland County
Commonwealth of Pennsylvania
Department of Welfare
Commonwealth of Pennsylvania
Bureau of individual Tax
Inheritance Tax Division
Attention: John Murphy
Internal Revenue Service
Federated Investors Tower
Department of Public Welfare
TPL Casualty Unit
Estate Recovery Program
Last Known Address (if address cannot be
reasonably ascertained, please indicate)
12 SHIRLEY LANE
BOILING SPRINGS, PA 17007
13 North Hanover Street
Carlisle, PA 17013
PO Box 2675
Harrisburg, PA 17105
6th Floor, Strawberry Square
Dept. 280601
Harrisburg, PA 17128
13"' Floor, Suite 1300
1001 Liberty Avenue
Pittsburgh, PA 15222
P.O. Box 8486
Willow Oak Building
Harrisburg, PA 17105-8486
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.
August 25, 200.6 ~
DATE DANIEL G. SCHMIEG, ESQUIRE
Attorney for Plaintiff
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PHELAN HALLINAN AND SCHMIEG, L.L.P.
By: DANIEL G. SCHMIEG
Identification No. 62205
ONE PENN CENTER AT SUBURBAN STATION
1617 JOHN F. KENNEDY BLVD., SUITE 1400
PHILADELPHIA, PA 19103-1814
(215) 563-7000
GE CAPITAL MORTGAGE SERVICES, INC.
Plaintiff,
v.
SARA JANE CREELMAN
Defendant(s).
ATTORNEY FOR PLAINTIFF
CUMBERLAND COUNTY
COURT OF COMMON PLEAS
CIVIL DIVISION
NO. 01-6453 CIVIL
CERTIFICATION
DANIEL G. SCHMIEG, ESQUIRE, hereby verifies that he is attorney for the Plaintiff in
the above-captioned matter, and that the premises are not subject to the provisions of Act 91
because it is:
n an FHA mortgage
() non-owner occupied
() vacant
(X) Act 91 procedures have been fulfilled
This certification is made subject to the penalties of 18 Pa. C.S. Section 4904 relating to unsworn
falsification to authorities.
~~ ~'
DANIEL G. SCHMIEG, ESQUIRE
Attorney for Plaintiff
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GE CAPITAL MORTGAGE SERVICES, INC.
Plaintiff,
v.
SARA JANE CREELMAN
Defendant(s).
CUMBERLAND COUNTY
No. 01-6453 CIVIL
August 25, 2006
TO: SARA JANE CREELMAN
12 SHIRLEY LANE
BOII.ING SPRINGS, PA 17007
**THIS FIRMIS A DEBT COLLECTOR ATTEMPTING TO COLLECT A DEBT AND ANYINFORMATION
OBTAINED WILL BE USED FOR THAT PURPOSE. IF YOU HAVE PREYIOUSLYRECEIiJED ADISCHARGE IN
BANKRUPTCYAND THIS DEBT WAS NOT REAFFIRMED, THIS IS NOT AND SHOULD NOT BE CONSTRUED TO BE
ANATTEMPT TO COLLECT A DEBT, BUT ONLYENFORCEMENT OFA LIENAGAINST PROPERTY. **
Your house (real estate) at ,12 SHIRLEY LANE, BOILING SPRINGS, PA 17007, is
scheduled to be sold at the Sheriffs Sale on DECEMBER 6, 2006 at 10:00 a.m. in the Cumberland
County Courthouse, South Hanover Street, Cazlisle, PA 17013, to enforce the court judgment of
$59,969.05 obtained by GE CAPITAL MORTGAGE SERVICES, INC. (the mortgagee) against you.
In the event the sale is continued, an announcement will be made at said sale in compliance with
Pa.R.C.P., Rule 3129.3.
NOTICE OF OWNER'S RIGHTS
YOU MAY BE ABLE TO PREVENT THIS SHERIFF'S SALE
To prevent this Sheriffs Sale, you must take immediate action:
1. The sale will be cancelled if you pay to the mortgagee the back payments, Late chazges,
costs and reasonable attorney's fees due. To find out how much you must pay, you may
call: (215) 563-7000.
2. You may be able to stop the sale by f ling a petition asking the Court to strike or open the
judgment, if the judgment was improperly entered. You may also ask the Court to
postpone the sale for good cause.
3. You may also be able to stop the sale through other legal proceedings.
I
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
fmd out the price bid by calling j215) Sb3-7000.
2. You may be able to petition the Court to set aside the sale if the bid price was grossly
inadequate compared to the value of your property.
3. The sale will go through only if the buyer pays the Sheriff the full amount due in the sale. To
find out if this has happened, you may call (717) 240-6390.
4. If the amount due from the Buyer is not paid to the Sheriff, you will remain the owner of the
property as if the sale never happened.
5. You have the right to remain in the property until the full amount due is paid to the Sheriff
and the Sheriff gives a deed to the buyer. At that time, the buyer may bring legal proceedings to evict
you.
6. You may be entitled to a share of the money which was paid for your house. A schedule of
distribution of the money bid for your house will be filed by the Sheriff within 30 days of the sale. This
schedule will state who will be receiving that money. The money will be paid out in accordance with
this schedule unless exceptions (reasons why the proposed distribution is wrong) are filed with the
Sheriff within ten (10) days after the distribution is filed.
7. You may also have other rights and defenses, or ways of getting your home back, if you act
immediately after the sale.
YOU SHOULD TAKE THIS PAPER TO YOUR LAWYER AT ONCE. IF YOU DO NOT HAVE
A LAWYER OR CANNOT AFFORD ONE, GO TO OR TELEPHONE THE OFFICE LISTED
BELOW TO FIND OUT WHERE YOU CAN GET LEGAL HELP.
IMPORTANT NOTICE: This property is so{d at the direction of the plaintiff. !t may not be sold
in the absence of a representative of the plaintiff at the Sheriffs Sale. The sale must be
postponed or stayed in the event that a representative of the plaintiff is not present at the sale.
CUMBERLAND COUNTY ATTORNEY REFERRAL
CUMBERLAND COUNTY BAR ASSOCIATION
2 LIBERTY AVENUE
CUMBERLAND COUNTY COURTHOUSE
CARLISLE, PA 17413
(717) 249-3166
;ALL THAT CERTAIN piece or parcel of land situate in South Middleton Township, Cumberland
County, Pennsylvania, bounded and described in accordance wiW a survey by Thomas A. Neff, R. S.
dated August 13, 1970, as follows:
BfiGIN1~iING at a point on the Northern side of Shirley Lane on the dividing line between Lots Nos.
19 and 20 on the hereinafter mentioned Plan of Lots, said point also being 589.24 feet West of the
western right of way line of L. R. #21008; thence along the Northern side of Shirley Lane South 68
degrees 49 nunutes 50 seconds West 100 feet to a point at the dividing line between Lots Nos. 18 and
19 on said Plan; thence along last said line North 21 degrees 10 minutes 10 seconds West i20 feet to
a point; thence by the dividing line between Lots Nos. 19 and 31 on said Plan North 68 degrees 49
minutes 50 seconds East 100 feet to a point; thence by the dividing line between Lots Nos. 19 and 20
aforesaid South 21 degrees IO minutes 10 seconds East 120 feet to a point, the place of beginning.
BEING Lot No. 19 on the Plan of Lots known as Clifton Heights as recorded in Plan Book 17, Page
59.
HAVING. erected thereon a masonry and aluminum siding ranch house.
TITLE TO SAID PREMISES IS VESTED IN Sara Jane Creelman by reason of the following:
BEING THE SAME premises which Clifford L. Heishman and Ethel E. Heishman, his wife and
William S. Wert and Lois A. Wert, his wife by Deed dated 8/31/1970 and recorded 9!15/1970 in
the County of Cumberland in Deed Book Volume 23, Page 385 conveyed unto Arthur N. Creelman
and Sara Jane Creelman, his wife.
AND THE SAID Arthur N. Creelman died on 3/25/93 whereby title to said premises became vested
in Sara Jane Creehnan by right of survivorship.
Tax Map #27-1921, Parcel 2
Premises: 12 SHIRLEY LANE, TOWNSHIP OF SOUTH MIDDLETON
CUMBERLAND COUNTY
PENNSYLVANIA _ _ ~ _
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WRIT OF EXECUTION and/or ATTACHMENT
COMMONWEALTH OF PENNSYLVANIA)
COUNTY OF CUMBERLAND)
NO 01-6453 Civil
CIVIL ACTION -LAW
TO THE SHERIFF OF CUMBERLAND COUNTY:
To satisfy the debt, interest and costs due GE CAPITAL MORTGAGE SERVICES, INC.,
Plaintiff (s)
From SARA JANE CREELMAN
(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 $59,969.05
L.L.
Interest FROM 1/5/02 TO 12/6/06 (PER DIEM - $9.86) - $3,677.00 AND COSTS
Atty's Comm % Due Prothy $1.00
Atty Paid $862.56
Plaintiff Paid
Date: AUGUST 28, 2006
(Seal)
REQUESTING PARTY:
Name DANIEL G. SCHMIEG, ESQUIRE
Address: ONE PENN CENTER AT SUBURBAN STATION
1617 JOHN F. KENNEDY BOULEVARD, SUITE 1400
PHILADELPHIA, PA 19103-1814
Attorney for: PLAINTIFF
Telephone: 215-563-7000
Other Costs
URT .LONG
Prothonotary
By:
Deputy
Supreme Court ID No. 62205•
AFFIDAVIT OF SERVICE
PLAINTIFF ~ GE CAPITAL MORTGAGE SERVICES,
• INC.
DEFENDANT(S) SARA JANE CREELMAN
SERVE SARA JANE CREELMAN AT
12 SHIRLEY LANE
BOILING SPRINGS, PA 17007
CUMBERLAND COUNTY
CQS
No. 01-6453 CIVIL
ACCT. #0022099485 P~~~ 5a~
Type of Action
-Notice of Sheriffls Sale
Sale Date: DECEMBER 6, 2006
SERVED
Served and made known to S~ ~ 4 ~~ ~ e L~P PC ~,~¢ ri ,Defendant, on the S * day of Se P FPM b''~' , 20010,
at ~~, o'clock ~m., at { ~ S h i r 1 eY 1 ~ n ~ ,Commonwealth
of Pennsylvania, in the manner described below:
V Defendant personally served.
Adult family member with whom Defendant(s) reside(s). Name and Relationship is _
Adult in charge of Defendant(s)'s residence who refused to give name or relationship.
Manager/Clerk of place of lodging in which Defendant(s) reside(s).
Agent or person in charge of Defendant(s)'s office or usual place of business.
an officer of said Defendant(s)'s company.
Other:
Description: Age ~d Height ~t5 ~ ~ Weight Zd Race 1~ Sex ~. Other
I, ~ Qc t ti ~ I~6 ~Q N-S , a competent adult, being duly sworn according to law, depose and state that I personally handed
a true 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.
and
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200.
~f-~L`'~AS~ A'1"1'EM~ SERVICE AT
Moved Unknown _ _ No Answer
1St Attempt: / / Time:.
3rd Attempt: J I Time:
Sworn to and subscribed
before me this day
of ,200 _.
Notary: By:
Attorney for Plaintiff
Daniel G. Schmieg, Esquire - I.D. No. 62205
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Commission Expires Jure 16, 2004
On the day of
LEAST 3 TIMES. INDICATE DATES & TIMES OF SERVICE ATTEMPTED.
NOT SERVED
200_, at o'clock _.m., Defendant NOT FOUND because:
Vacant
2°d Attempt: / / Time:
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PHELAN HALLINAN &SCHMIEG, LLP
By: DANIEL G. SCHMIEG, ESQUIRE
Atty. LD. No. 62205
ATTORNEY FOR PLAINTIFF
One Penn Center Plaza, Suite 1400
Philadelphia, PA 19103
(215) 563-7000
GE Capital Mortgage Services, Inc.
5024 parkway Plaza Boulevard
Building 7/F/C
Charlotte, NC 28217-2407
COURT OF COMMON PLEAS
CNII. DIVISION
v.
Sara Jane Creelman
12 Shirley Lane
Boiling Springs, PA 17007
NO. 01-6453 Civil
Cumberland County
PRAECIPE TO MARK JUDGMENT TO USE OF PLAINTIFF
TO THE PROTHONOTARY:
Please mark judgment in the above-captioned matter to the use of:
Wells Fargo Bank, N.A.
1 Home Campus
Des Moines, IA 50328
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DANIEL G. SCHMIEG, ESQ
ATTORNEY FOR PLAINTIFF
DATED: Friday, November 03 2006
•64.
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SALE DATE: DECEMBER 6, 2006
IN THE COURT OF COMMON PLEAS OF CUMBERLAND COUNTY, PENNSYLVANIA
CNIL ACTION -LAW
WELLS FARGO BANK, N.A.
No.: BOILING SPRINGS, PA 17007
vs.
SARA JANE CREELMAN
AFFIDAVIT PURSUANT TO RULE 3129.1
AND RETURN OF SERVICE PURSUANT TO
Pa. R.C.P. 405 OF NOTICE OF SALE
Plaintiff in the above action sets forth as of the date the Praecipe for the Writ of
Execution was filed the following information concerning the real property located at:
12 SHIRLEY LANE.
`TFi~,~
As required by Pa. R.C.P. 3129.2(a) Notice of Sale has been given in the manner
required by Pa. R.C.P. 3129.2(c) on each of the persons or parties named, at that address set forth
on the attached Affidavit No. 2 (previously filed) and Amended Affidavit No. 2 on the date
indicated, and a copy of the notice is attached as an Exhibit. A copy of the Certificate of Mailing
(Form 3817) and/or Certified Mail Return Receipt stamped by the U.S. Postal Service is attached
for each notice.
DANIEL SCHMIEG, ESQUIlZE
Attorney for Plaintiff
November 3, 2006
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GE Capital Mortgage Services, Inc.
VS
Sara Jane Creelman
In the Court of Common Pleas of
Cumberland County, Pennsylvania
Writ No. 2001-6453 Civil Term
Kenneth Gossert, Deputy Sheriff, who being duly sworn according to law, states that on
September 22, 2006 at 1837 hours, he served a true copy of the within Real Estate Writ, Notice and
Description, in the above entitled action, upon the within named defendant, to wit: Sara Jane
Creelman, by making known unto Sara Jane Creelman personally, at 12 Shirley Lane, Boiling
Springs, Cumberland County, Pennsylvania its contents and at the same time handing to her
personally the said true and correct copy of the same.
Valerie Weary, Deputy Sheriff, who being duly sworn according to law, states that on
October 16, 2006 at 1817 hours, she posted a true copy of the within Real Estate Writ, Notice,
Poster and Description, in the above entitled action, upon the property of Sara Jane Creelman
located at 12 Shirley Lane, Boiling Springs, Cumberland County, Pennsylvania according to law.
R. Thomas Kline, Sheriff, who being duly sworn according to law, states he served the
above Real Estate Writ, Notice, Poster and Description in the following manner: The Sheriff
mailed a notice of the pendency of the action to the within named defendant, to wit: Sara Jane
Creelman, by regular mail to her last known addresses of 12 Shirley Lane, Boiling Springs, PA
17007. This letter was mailed under the date of October 10, 2006 and never returned to the Sheriffs
Office.
R. Thomas Kline, Sheriff, who being duly sworn according to law, states this writ is
returned STAYED per letter of instruction from Attorney Daniel Schmieg.
Sheriff s Costs:
Docketing 30.00
Poundage 18.00
Posting bills 15.00
Advertising 15.00
Law Library
Prothonotary 1.00
Mileage 10.56
Certified Mail 7.25
Levy 15.00
Surcharge 20.00
Law Journal 413.00
Patriot News 336.98
Share of Bills 15.94
Postpone Sale 20.00
$917.73
So Answers:
R. Thomas Kline, Sheriff
B 't
Rea Esta ergeant
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GE CAPITAL MORTGAGE SERVICES, INC. -
~y CUMBERLAND COUNTY
Plaintiff,
v. COURT OF COMMON PLEAS
SARA JANE CREELMAN CIVIL DIVISION
Defendant(s). NO.Ol-6453 CIVIL
AFFIDAVIT PURSUANT TO RULE 3129
(Affidavit No. i)
GE CAPITAL. MORTGAGE SERVICES INC. Plaintiff in the above action, by its attorney,
DANIEL G. SCHIvIIEG, 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 ,12 SHIRLEY LANE,
BOILING SPRINGS. PA 17007 .
1. Name and address of Owner(s) or reputed Owner(s):
Name
SARA JANE CREELMAN
Last Known Address (if address cannot be
reasonably ascertained, please indicate)
12 SHIRLEY LANE
BOILING SPRINGS, PA 17007
2. Name and address of Defendant(s) in the judgment:
Same as above
3. Name and last known address of every judgment creditor whose judgment is a record lien on the real
property to be sold:
Name
Last Known Address (if address cannot be
reasonably ascerkained, please indicate)
None
,.
} ,
4. Name and address of last recorded holder of every mortgage of record:
Name
PNC BANK NATIONAL ASSOCIATION
Last Known Address (if address cannot be
reasonably ascertained, please indicate)
2730 LIBERTY AVENUE
PITTSBURGH, PA 15222
CITIFINANCIAL INC.
5520 CARLISLE PIKE STE 155
MECHANICSBURG, PA 17055
5. Name and address of every other person who has any record lien on the property:
Name Last Known Address (if address cannot be
reasonably ascertained, please indicate)
None
6. Name and address of every other person who has any record interest in the property and whose
interest may be affected by the sale.
Name Last Known Address (if address cannot be
reasonably ascertained, please indicate)
None
7. Name and address of every other person of whom the plaintiff has knowledge who has any interest in
the property which may be affected by the sale:
' ' Name
Tenant/Occupant
Domestic Relations of Cumberland County
Commonwealth of Pennsylvania
Department of Welfare
Commonwealth of Pennsylvania
Bureau of Individual Tax
Inheritance Tax Division
Attention: John Murphy
Internal Revenue Service
Federated Investors Tower
Department of Public Welfare
TPL Casualty Unit
Estate Recovery Program
Last Known Address (if address cannot be
reasonably ascertained, please indicate)
12 SHIRLEY LANE
BOILING SPRINGS, PA 17007
13 North Hanover Street
Carlisle, PA 17013
PO Box 2675
Harrisburg, PA 17105
6th Floor, Strawberry Square
Dept. 280601
Harrisburg, PA 17128
13~' Floor, Suite 1300
1001 Liberty Avenue
Pittsburgh, PA 15222
P.O. Box 8486
Willow Oak Building
Harrisburg, PA 17105-8486
I verify that the statements made in this affidavit aze true and correct to the best of my personal
knowledge or information and belief. I understand that false statements herein aze made subject to the
penalties of 18 Pa. C.S. Sec. 4904 relating to unsworn falsification to authorities.
August 25, 2006 ~ ~
DATE DANIEL G. SCHMIEG, ESQUIRE
Attorney for Plaintiff
h ~ ~~ d 8 Z 9fi~ 901
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GE CAPITAL MORTGAGE SERVICES, INC.
Plaintiff,
v.
SARA JANE CREELMAN
Defendant(s).
CUMBERLAND COUNTY
. No. 01-6453 CIVIL
August 25, 2006
TO: SARA JANE CREELMAN
12 SHIRLEY LANE
BOILING SPRINGS, PA 17007
* *THIS FIRM IS A DEBT COLLECTOR ATTEMPTING TO COLLECT A DEBT AND ANYWFORMATION
OBTAINED WILL BE USED FOR THAT PURPOSE. IF YOUHAVE PREVIOUSLYRECEIVED ADISCHARGE IN
BANKRUPTCYAND THIS DEBT WAS NOT REAFFIRMED, THIS IS NOT AND SHOULD NOT BE CONSTRUED TO BE
ANATTEMPT TO COLLECT A DEBT, BUT ONLYENFORCEMENT OFA LIENAGAINST PROPERTY. **
Your house (real estate) at ,12 SHIRLEY LANE, BOILING SPRINGS, PA 17007, is
scheduled to be sold at the Sheriffs Sale on DECEMBER 6, 2006 at 10:00 a.m. in the Cumberland
County Courthouse, South Hanover Street, Carlisle, PA 17013, to enforce the court judgment of
59 969.05 obtained by GE CAPITAL MORTGAGE SERVICES, INC. (the mortgagee) against you.
In the event the sale is continued, an announcement will be made at said sale in compliance with
Pa.R.C.P., Rule 3129.3.
NOTICE OF OWNER'S RIGHTS
YOU MAY BE ABLE TO PREVENT THIS SHERIFF'S SALE
To prevent this Sheriffs Sale, you must take immediate action:
1. The sale will be cancelled if you pay to the mortgagee the back payments, late charges,
costs and reasonable attorney's fees due. To find out how much you must pay, you may
call: (215) 563-7000.
2. You may be able to stop the sale by filing a petition asking the Court to strike or open the
judgment, if the judgment was improperly entered. You may also ask the Court to
postpone the sale for good cause.
3. You may also be able to stop the sale through other legal proceedings.
1r >
You may need an attorney to assert your rights. The sooner you contact one, the more chance
you will have of stopping the sale. (See notice on page two on how to obtain an attorney.)
YOU MAY STILL BE ABLE TO SAVE YOUR PROPERTY AND YOU HAVE OTHER
RIGHTS EVEN IF THE SHERIFF'S SALE DOES TAKE PLACE.
1. If the Sheriffs Sale is not stopped, your property will be sold to the highest bidder. You may
find out the price bid by calling (215) 563-7000.
2. You may be able to petition the Court to set aside the sale if the bid price was grossly
inadequate compared to the value of your property.
3. The sale will go through only if the buyer pays the Sheriff the full amount due in the sale. To
find out if this has happened, you may call (717) 240-6390.
4. If the amount due from the Buyer is not paid to the Sheriff, you will remain the owner of the
property as if the sale never happened.
5. You have the right to remain in the property until the full amount due is paid to the Sheriff
and the Sheriff gives a deed to the buyer. At that time, the buyer may bring legal proceedings to evict
you.
6. You may be entitled to a 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 (l0) days after the distribution is filed.
7. You may also have other rights and defenses, or ways of getting your home back, if you act
immediately after the sale.
..~ ...., ..........YOU SHOULD TAKE THIS PAPER TO YOUR LAWYER AT ONCE. IF YOU DO NOT HAVE
A LAWYER OR CANNOT AFFORD ONE, GO TO OR TELEPHONE THE OFFICE LISTED
BELOW TO FIND OUT WHERE YOU CAN GET LEGAL HELP.
IMPORTANT NOTICE: This property is sold at the direction of the plaintiff. It may not be sold
in the absence of a representative of the plaintiff at the Sheriffs Sale. The sale must be
postponed or stayed in the event that a representative of the plaintiff is not present at the sale.
CUMBERLAND COUNTY ATTORNEY REFERRAL
CUMBERLAND COUNTY BAR ASSOCIATION
2 LIBERTY AVENUE
CUMBERLAND COUNTY COURTHOUSE
CARLISLE, PA 17013
(717) 249-3166
' ~' .
ALL THAT CERTAIN piece or parcel of land situate in South Middleton Township, Cumberland
County, Pennsylvania, bounded and described in accordance with a survey by Thomas A. Neff, R. S.
dated August 13, 1970, as follows:
BEGINNING at a point on the Northern side of Shirley Lane on the dividing line between Lots Nos.
19 and 20 on the hereinafter mentioned Plan of Lots, said point also being 589.24 feet West of the
Western right of way line of L. R. #21008; thence along the Northern side of Shirley Lane South 68
degrees 49 minutes 50 seconds 'West 100 feet to a point at the dividing line between Lots Nos. 18 and
19 on said Plan; thence along last said line North 21 degrees 10 minutes 10 seconds West 12A feet to
a point; thence by the dividing line between Lots Nos. 19 and 31 on said Plan North 68 degrees 49
minutes 50 seconds East 100 feet to a point; thence by the dividing line between Lots Nos. 19 and 20
aforesaid South 21 degrees 10 minutes 10 seconds East 120 feet to a point, .the place of beginning.
BEING Lot No. 19 on the Plan of Lots known as Clifton Heights as recorded in Plan Book 17, Page
59.
HAVING. erected thereon a masonry and aluminum siding ranch house.
TITLE TO SAID PREMISES IS VESTED IN. Sara Jane Creelman by reason of the following:
BEING THE SAME premises which Clifford L. Heishman and Ethel E. Heishman, his wife and
William S. Wert and Lois A. Wert, his wife by Deed dated 8/31/1970 and recorded 9/15/1970 in
the County of Cumberland in Deed Book Volume 23, Page 385 conveyed unto Arthur N. Creelman
and Sara Jane Creehnan, his wife.
AND THE SAID Arthur N. Creehnan died on 3/25/93 whereby title to said premises became vested
in Sara Jane Creelrnan by right of survivorship.
Tax Map #27-1921, Parcel 2
Premises: 12 SHIRLEY LANE, TOWNSHIP OF SOUTH MIDDLETON
CUMBERLAND COUNTY _
PENNSYLVANIA ~~
WRIT OF EXECUTION and/or ATTACHMENT
COMMONWEALTH OF PENNSYLVANIA)
COUNTY OF CUMBERLAND)
NO 01-6453 Civil
CIVIL ACTION -LAW
TO THE SHERIFF OF CUMBERLAND COUNTY:
To satisfy the debt, interest and costs due GE CAPITAL MORTGAGE SERVICES, INC.,
Plaintiff (s)
From SARA JANE CREELMAN
(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 $59,969.05
L.L.
Interest FROM 1/5/02 TO 12/6/06 (PER DIEM - $9.86) -- $3,677.00 AND COSTS
Atty's Comm % Due Prothy $1.00
Atty Paid $862.56
Plaintiff Paid
Date: AUGUST 28, 2006
(Seal)
REQUESTING PARTY:
Name DANIEL G. SCHMIEG, ESQUIRE
Other Costs
URTIS R. LONG
Prothonotary
By:
Deputy
Address: ONE PENN CENTER AT SUBURBAN STATION
1617 JOHN F. KENNEDY BOULEVARD, SUITE 1400
PHILADELPHIA, PA 19103-1814
Attorney for: PLAINTIFF
Telephone: 215-563-7000
Supreme Court ID No. 62205
Real Estate Sale # 44
On August 29, 2006 the Sheriff levied upon the
defendant's interest in the real property situated in
South Middleton Township, Cumberland County, PA
Known and numbered as 12 Shirley Lane,
Boiling Springs, more fully described on Exhibit "A"
filed with this writ and by this reference incorporated herein.
Date: August 29, 2006 By:
Real Estate Sergeant
hZ ~~ d 8Z 9f)d 9001
;~ - ~ ,,
THE PATRIOT NEWS
THE SUNDAY PATRIOT NEWS
Proof of Publication
Under Act No. 587, Approved May 16, 1929
Commonwealth of Pennsylvania, County of Dauphin} ss
Joseph A. Dennison, being duly sworn according to law, deposes and says:
That he is the Assistant Controller of The Patriot News Co., a corporation organized and existing under the
laws of the Commonwealth of Pennsylvania, with its principal office and place of business at 812 to 818 Market
Street, in the City of Harrisburg, County of Dauphin, State of Pennsylvania, owner and publisher of The Patriot-
News and The Sunday Patriot-News newspapers of general circulation, printed and published at 812 to 818 Market
Street, in the City, County and State aforesaid; that The Patriot-News and The Sunday Patriot-News were
established March 4th, 1854, and September 18th, 1949, respectively, and all have been continuously published ever
since;
That the printed notice or publication which is securely attached hereto is exactly as printed and published
in their regular daily and/or Sunday/ Metro editions which appeared in the 25th day(s) of October and the 1st and
8th day(s) of November 2006. That neither he nor said Company is interested in the subject matter of said printed
notice or advertising, and that all of the allegations of this statement as to the time, place and character of
publication are true; and
That he has personal knowledge of the facts aforesaid and is duly authorized and empowered to verify this
statement on behalf of The Patriot-News Co, aforesaid by virtue and pursuant to a resolution unanimously passed
and adopted severally by the stockholders and board of directors of the said Company and subsequently duly
recorded in the office for the Recording of Deeds in and for said County of Dauphin in Miscellaneous Book "M",
Volume 14, Page 317.
~7l `~
PUBLICATION ......... .. . ~ .. ... .............................................
COPY Sworn to subs ed before me this 15th day of November 2006 ~e,~D
SALE #44 COMMONWEALTH OF PENNSYLVANIA
Notarial Seal
i'erry i.. Russell, Notary Public
City Of rrisburg, Dauphin County
My Co fission E s June 6, 2010
ember, nns v i? ssn~iation of Notaries
!!!///
NOTAR PUBLIC
~1
CUMBERLAND COUNTY SHERIFF'S OFFICE
CUMBERLAND COUNTY COURTHOUSE
CARLISLE, PA. 17013
PROOF OF PUBLICATION OF NOTICE
IN CUMBERLAND LAW JOURNAL
(Under Act No. 587, approved May 16, 1929), P. L.1784
COMMONWEALTH 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 regulazly
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:
October 20, October 27 and November 3, 2006
Affiant further deposes that he is authorized to verify this statement by the Cumberland
Law Journal, a legal periodical of general circulation, and that he is not interested in the subject
matter of the aforesaid notice or advertisement, and that all allegations in the foregoing
statements as to time, place and character of publication are true.
sa arie Coyne, E for
SWORN TO AND SUBSCRIBED before me this
3 day of November, 2006
NOTARIAL SEAL
LOTS E. SNYDER, Notary Public
CarNsle Boro, Cumberland County
My Commission Expires March 5, 2009
REAL ESTATE '3~AI.E NO. 44
Writ No. 2001-6453 Civil
GE Capital Mortgage
Services, Inc.
vs.
Sara Jane Creelman
Atty.: Daniel Schmieg
ALL THAT CERTAIN piece or
parcel of land situate in South
Middleton Township, Cumberland
County, Pennsylvania, bounded and
described in accordance with a sur-
vey by Thomas A. Neff, R. S. dated
August 13, 1970, as follows:
BEGINNING at a point on the
Northem side of Shirley Lane on the
dividing line between Lots Nos. 19
and 20 on the hereinafter mentioned
Plan of Lots, said point also being
589.24 feet West of the Western
right of way line of L. R. #21008;
thence along the Northern side of
Shirley Lane South 68 degrees 49
minutes 50 seconds West 100 feet
to a point at the dividing line be-
tween Lots Nos. 18 and 19 on said
Plan; thence along last said line North
21 degrees 10 minutes 10 seconds
West 120 feet to a point; thence by
the dividing line between Lots Nos.
19 and 31 on said Plan North 68
degrees 49 minutes 50 seconds
East 100 feet to a point; thence by
the dividing line between Lots Nos.
19 and 20 aforesaid South 21 de-
grees 10 minutes 10 seconds East
120 feet to a point, the place of be-
ginning.
BEING Lot No. 19 on the Plan of
Lots known as Clifton .Heights as
recorded in Plan Book 17, Page 59.
HAVING erected thereon a ma-
sonry and aluminum siding ranch
house.
TITLE TO SAID PREMISES IS
VESTED IN Sara Jane Creelman by
reason of the following:
BEING THE SAME premises
which Clifford L. Heishman and
Ethel E. Heishman, his wife and
William S. Wert and Lois A. Wert,
his wife by Deed dated 8/31/1970
and recorded 9/15/1970 in the
County of Cumberland in Deed Book
Volume 23, Page 385 conveyed unto
Arthur N. Creelman and Sara Jane
Creelman, his wife.
AND THE SAID Arthur N.
Creelman died on 3/25/93 whereby
title to said premises became vested
in Sara Jane Creelman by right of
survivorship.
Tax Map #27-1921, Parcel 2.
Premises: 12 SHIRLEY LANE,
TOWNSHIP OF SOUTH MIDDLE-
TON, CUMBERLAND COUNTY,
PENNSYLVANIA..