HomeMy WebLinkAbout08-2415PHELAN HALLINAN & SCHMIEG, LLP
LAWRENCE T. PHELAN, ESQ., Id. No. 32227
FRANCIS S. HALLINAN, ESQ., Id. No. 62695
DANIEL G. SCHMIEG, ESQ., Id. No. 62205
MICHELE M. BRADFORD, ESQ., Id. No. 69849
JUDITH T. ROMANO, ESQ., Id. No. 58745
SHEETAL SHAH-JANI, ESQ., Id. No. 81760
JENINE R. DAVEY, ESQ., Id. No. 87077
MICHAEL E. CARLETON, ESQ., Id. No. 203009
VIVEK SRIVASTAVA, ESQ., Id. No. 202331
JAY B. JONES, ESQ., Id. No. 86657
PETER MULCAHY, ESQ., Id. No. 61791
ANDREW SPIVACK, ESQ., Id. No. 84439
ONE PENN CENTER PLAZA, SUITE 1400
PHILADELPHIA, PA 19103
(215) 563-7000 174120
COUNTRYWIDE HOME LOANS, INC.
7105 CORPORATE DRIVE
PLANO, TX 75024
Plaintiff
V.
CONSTANCE M. VAN METER
MELVIN V. VAN METER, JR
122 YATES STREET
MOUNT HOLLY SPRINGS, PA 17065-1018
Defendants
ATTORNEY FOR PLAINTIFF
COURT OF COMMON PLEAS
CIVIL DIVISION
TERM
NO. OS- 0jyj5 Nit Terrh
CUMBERLAND COUNTY
CIVIL ACTION - LAW
COMPLAINT IN MORTGAGE FORECLOSURE
File #: 174120
NOTICE
You have been sued in Court. If you wish to defend against the claims set forth in the
following pages, you must take action within twenty (20) days after this Complaint and Notice
are served by entering a written appearance personally or by attorney and filing in writing with
the Court your defenses or objections to the claims set forth against you. You are warned that if
you fail to do so, the case may proceed without you, and a judgment may be entered against you
by the Court without further notice for any money claimed in the Complaint or for any other
claim or relief requested by the plaintiff. You may lose money or property or other rights
important to you.
YOU SHOULD TAKE THIS PAPER TO YOUR LAWYER AT ONCE. IF YOU DO
NOT HAVE A LAWYER, GO TO OR TELEPHONE THE OFFICE SET FORTH BELOW.
THIS OFFICE CAN PROVIDE YOU WITH INFORMATION ABOUT HIRING A LAWYER.
IF YOU CANNOT AFFORD TO HIRE A LAWYER, THIS OFFICE MAY BE ABLE
TO PROVIDE YOU WITH INFORMATION ABOUT AGENCIES THAT MAY OFFER
LEGAL SERVICES TO ELIGIBLE PERSONS AT A REDUCED FEE OR NO FEE.
Lawyer Referral Service
Cumberland County Bar Association
32 South Bedford Street
Carlisle, PA 17013
(800)990-9108
File #: 174120
IF THIS IS THE FIRST NOTICE THAT YOU HAVE
RECEIVED FROM THIS OFFICE, BE ADVISED THAT:
PURSUANT TO THE FAIR DEBT COLLECTION
PRACTICES ACT, 15 U.S.C. § 1692 et seq. (1977),
DEFENDANT(S) MAY DISPUTE THE VALIDITY OF THE
DEBT OR ANY PORTION THEREOF. IF DEFENDANT(S)
DO SO IN WRITING WITHIN THIRTY (30) DAYS OF
RECEIPT OF THIS PLEADING, COUNSEL FOR
PLAINTIFF WILL OBTAIN AND PROVIDE
DEFENDANT(S) WITH WRITTEN VERIFICATION
THEREOF; OTHERWISE, THE DEBT WILL BE ASSUMED
TO BE VALID. LIKEWISE, IF REQUESTED WITHIN
THIRTY (30) DAYS OF RECEIPT OF THIS PLEADING,
COUNSEL FOR PLAINTIFF WILL SEND DEFENDANT(S)
THE NAME AND ADDRESS OF THE ORIGINAL
CREDITOR, IF DIFFERENT FROM ABOVE.
THE LAW DOES NOT REQUIRE US TO WAIT UNTIL
THE END OF THE THIRTY (30) DAY PERIOD
FOLLOWING FIRST CONTACT WITH YOU BEFORE
SUING YOU TO COLLECT THIS DEBT. EVEN THOUGH
THE LAW PROVIDES THAT YOUR ANSWER TO THIS
File #: 174120
COMPLAINT IS TO BE FILED IN THIS ACTION WITHIN
TWENTY (20) DAYS, YOU MAY OBTAIN AN EXTENSION
OF THAT TIME. FURTHERMORE, NO REQUEST WILL
BE MADE TO THE COURT FOR A JUDGMENT UNTIL
THE EXPIRATION OF THIRTY (30) DAYS AFTER YOU
HAVE RECEIVED THIS COMPLAINT. HOWEVER, IF
YOU REQUEST PROOF OF THE DEBT OR THE NAME
AND ADDRESS OF THE ORIGINAL CREDITOR WITHIN
THE THIRTY (30) DAY PERIOD THAT BEGINS UPON
YOUR RECEIPT OF THIS COMPLAINT, THE LAW
REQUIRES US TO CEASE OUR EFFORTS (THROUGH
LITIGATION OR OTHERWISE) TO COLLECT THE DEBT
UNTIL WE MAIL THE REQUESTED INFORMATION TO
YOU. YOU SHOULD CONSULT AN ATTORNEY FOR
ADVICE CONCERNING YOUR RIGHTS AND
OBLIGATIONS IN THIS SUIT.
IF YOU HAVE FILED BANKRUPTCY AND RECEIVED A
DISCHARGE, THIS IS NOT AN ATTEMPT TO COLLECT
A DEBT. IT IS AN ACTION TO ENFORCE A LIEN ON
REAL ESTATE.
File #: 174120
I . Plaintiff is
COUNTRYWIDE HOME LOANS, INC.
7105 CORPORATE DRIVE
PLANO, TX 75024
2. The name(s) and last known address(es) of the Defendant(s) are:
CONSTANCE M. VAN METER
MELVIN V. VAN METER, JR
122 YATES STREET
MOUNT HOLLY SPRINGS, PA 17065-1018
who is/are the mortgagor(s) and/or real owner(s) of the property hereinafter described.
On 05/18/2006 mortgagor(s) made, executed and delivered a mortgage upon the premises
hereinafter described to MORTGAGE ELECTRONIC REGISTRATION SYSTEMS,
INC AS A NOMINEE FOR COUNTRYWIDE HOME LOANS, INCORPORATED
which mortgage is recorded in the Office of the Recorder of CUMBERLAND County, in
Mortgage Book No. 1951, Page 4709. The PLAINTIFF is now the legal owner of the
mortgage and is in the process of formalizing an assignment of same. The mortgage and
assignment(s), if any, are matters of public record and are incorporated herein by
reference in accordance with Pa.R.C.P. 1019(g); which Rule relieves the Plaintiff from its
obligations to attach documents to pleadings if those documents are of public record.
4. The premises subject to said mortgage is described as attached.
5. The mortgage is in default because monthly payments of principal and interest upon said
mortgage due 11/0 1/2007 and each month thereafter are due and unpaid, and by the terms
of said mortgage, upon failure of mortgagor to make such payments after a date specified
by written notice sent to Mortgagor, the entire principal balance and all interest due
thereon are collectible forthwith.
File #: 174120
6.
The following amounts are due on the mortgage:
Principal Balance $105,896.15
Interest $3,348.18
10/01/2007 through 04/15/2008
(Per Diem $16.91)
Attorney's Fees $1,250.00
Cumulative Late Charges $186.84
05/18/2006 to 04/15/2008
Cost of Suit and Title Search 550.00
Subtotal $111,231.17
Escrow
Credit $0.00
Deficit $103
30
Subtotal .
$103
30
TOTAL .
$111,334.47
7.
If the mortgage is reinstated prior to a Sheriffs Sale, the attorney's fee set forth above
may be less than the amount demanded based on work actually performed. The
attorney's fees requested are in conformity with the mortgage and Pennsylvania law.
Plaintiff reserves its right to collect attorney's fees up to 5% of the remaining principal
balance in the event the property is sold to a third party purchaser at Sheriffs Sale, or if
the complexity of the action requires additional fees in excess of the amount demanded in
the Action.
Plaintiff is not seeking a judgment of personal liability (or an in personam judgment)
against the Defendant(s) in the Action; however, Plaintiff reserves its right to bring a
separate Action to establish that right, if such right exists. If Defendant(s) has/have
received a discharge of personal liability in a bankruptcy proceeding, this Action of
Mortgage Foreclosure is in no way an attempt to reestablish such personal liability
discharged in bankruptcy, but only to foreclose the mortgage and sell the mortgaged
premises pursuant to Pennsylvania Law.
File #: 174120
9. Notice of Intention to Foreclose as set forth in Act 6 of 1974, Notice of Homeowner's
Emergency Assistance Program pursuant to Act 91 of 1983, as amended in 1998, and/or
Notice of Default as required by the mortgage document, as applicable, have been sent to
the Defendant(s) on the date(s) set forth thereon, and the temporary stay as provided by
said notice has terminated because Defendant(s) has/have failed to meet with the Plaintiff
or an authorized consumer credit counseling agency, or has/have been denied assistance
by the Pennsylvania Housing Finance Agency.
10. This action does not come under Act 6 of 1974 because the original mortgage amount
exceeds $50,000.
WHEREFORE, PLAINTIFF demands an in rem Judgment against the Defendant(s) in
the sum of $111,334.47, together with interest from 04/15/2008 at the rate of $16.91 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.
PHELAN HALLINAN & SCHMIEG, LLP
4By: ,J (Q a cps S?
LAWRENCE T. PHELAN, ESQUIRE
FRANCIS S. HALLINAN, ESQUIRE
DANIEL G. SCHMIEG, ESQUIRE
MICHELE M. BRADFORD, ESQUIRE
JUDITH T. ROMANO, ESQUIRE
SHEETAL R. SHAH-JANI, ESQUIRE
JENINE R. DAVEY, ESQUIRE
MICHAEL E. CARLETON, ESQUIRE
VIVEK SRIVASTAVA, ESQUIRE
JAY B. JONES, ESQUIRE
PETER MULCAHY, ESQUIRE
ANDREW SPIVACK, ESQUIRE
Attorneys for Plaintiff
File #: 174120
LEGAL DESCRIPTION
All that certain tract or parcel of land and premises, situate, lying and being in the Borough of
Mount Holly Springs in the County of Cumberland and Commonwealth of Pennsylvania, more
particularly as follows:
BEGINNING at a point, the intersection of the Carlisle - Gettysburg Highway, also known as
Pennsylvania Highway Route No. 34, and the Southern line of Lot No. 64 on the hereinafter
mentioned Plan of Lots; thence extending at or nearly at right angles to said Highway, in a
Westerly direction to the 50 foot right-of-way of the P & R Railway; thence along said right-of-
way in a Southerly direction, 100 feet to a point on the Northern line of Lot No. 62 on said Plan
of Lots; thence in an Easterly direction along the Northern line of said Lot No. 62 to
Pennsylvania Highway Route No. 34 aforesaid; thence in a Northerly direction along said
Highway, 100 feet to the Place of BEGINNING.
BEING Lot No. 63 on the Plan of Lots of Mount Holly Gap Lake Resort, as recorded in the
Office of the Recorder of Deeds for Cumberland County in Plan Book 2, Page 95.
BEING improved with a dwelling house known as No. 122 Yates Street.
BEING the same property which was conveyed to Lenore L. Steinberger by Edgar J. Steinberger
and Lenore L. Steinberger, his wife, by deed dated August 24, 1979, and recorded in the Office
of the Recorder of Deeds in Deed Book'P', Vol. 28, Page 677.
PARCEL NO: 23-35-2316-048
PROPERTY ADDRESS: 122 YATES STREET
File #: 174120
VERIFICATION
I hereby state that I am the attorney for Plaintiff in this matter, that. Plaintiff is
outside the jurisdiction of the Court and/or the verification could not be obtained
the time allowed for the filing of the pleading, that I am authorized to make this
verification pursuant to Pa.R.C.P. 1024 (c), and that the statements made in the foregoing
Civil Action in Mortgage Foreclosure are based upon information supplied b P
and are true and correct to the best of my knowledge, information by Plaintiff
and belief.
Furthermore, counsel intends to substitute a verification from Plaintiff upon receipt.
The undersigned understands that this statement is made subject to the penalties
of 18 Pa.C.S. Sec. 4904 relating to unsworn falsifications to authorities.
1 ` 1
??'l•9vv -
Attorney for Plaintiff
DATE: ? - I S =D
'j, 7
N T
u
. SHERIFF'S RETURN - REGULAR
CASE NO: 2008-02415 P
COMMONWEALTH OF PENNSYLVANIA:
COUNTY OF CUMBERLAND
COUNTRYWIDE HOME LOANS INC
VS
VAN METER CONSTANCE M ET AL
MICHAEL BARRICK Sheriff or Deputy Sheriff of
Cumberland County,Pennsylvania, who being duly sworn according to law,
was served upon
says, the within COMPLAINT - MORT FORE
the
VAN METER CONSTANCE M
2008
DEFENDANT , at 1728:00 HOURS, on the 13th day of May
at 100 MOTTER LANE
by handing to
BOILING SPRINGS, PA 17007
CONSTANCE M VAN METER
a true and attested copy of COMPLAINT - MORT FORE together with
and at the same time directing Her attention to the contents thereof.
Additional Comments
122 YATES STREET MT HOLLY SPRINGS IS VACANT.
Sheriff's Costs: So Answers:
Docketing 18.00
Service 12.00`,2
Affidavit .00
Surcharge 10.00 R. Thomas Kline
00
p 40.00 PHE1LA2HALLINAN SCHMIEG
Sworn and Subscibed to By:
Deputy heriff
before me this day
of A. D.
SHERIFF'S RETURN - REGULAR
CASE NO: 2008-02415 P
COMMONWEALTH OF PENNSYLVANIA:
COUNTY OF CUMBERLAND
COUNTRYWIDE HOME LOANS INC
VS
VAN METER CONSTANCE M ET AL
Sheriff or Deputy Sheriff of
MICHAEL BARRICK
Cumberland County,Pennsylvania, who being duly sworn according to law,
was served upon
says, the within COMPLAINT - MORT FORE
the
VAN METER MELVIN V JR
2008
DEFENDANT , at 1728:00 HOURS, on the 13th day of May
at 100 MOTTER LANE
by handing to
BOILING SPRINGS, PA 17007
CONSTANCE M BAN METER
a true and attested copy of COMPLAINT - MORT FORE together with
and at the same time directing Her attention to the contents thereof.
Additional Comments
122 YATES STREET MT HOLLY SPRINGS IS VACANT.
Sheriff's Costs: So Answers:
6,00 _
Docketing
Service .00 Affidavit .00
Surcharge 10.00 R. Thomas Kline
.00
3#aler C?- 16.00 05/16/2008
PHELAN HALLINAN SCHMIEG
--
Sworn and Subscibed to By:
Deputy Sheri f
before me this day
A.D.
PHELAN HALLiNAN & SCHMIEG, LLP
FRANCIS S. HALLINAN, ESQ., Id. No. 62695
ONE PENN CENTER PLAZA, SUITE 1400
PHILADELPHIA, PA 19103
(215) 563-7000
COUNTRYWIDE HOME LOANS, INC.
Plaintiff
VS.
ATTORNEY FOR PLAINTIFF
COURT OF COMMON PLEAS
CIVIL DIVISION
NO. 08-2415 CIVIL TERM
CONSTANCE M. VAN METER CUMBERLAND COUNTY
MELVIN V. VAN METER, JR
Defendant(s)
PRAECIPE TO SUBSTITUTE VERIFICATION
TO CIVIL ACTION COMPLAINT
IN MORTGAGE FORECLOSURE
TO THE PROTHONOTARY:
Kindly substitute the attached verification for the verification originally filed with the
complaint in the instant matter.
Date: Y-a 1-41
Phelan Hallinan & Schmieg, LLP
Attorney for Plaintiff
Z?7
By:
Francis S. Hallinan, Esquire
PHS #: 174120
PHELAN HALLINAN & SCHMIEG, LLP
LAWRENCE T. PHELAN, ESQ., Id. No. 32227
FRANCIS S. HALLINAN, ESQ., Id. No. 62695
ONE PENN CENTER PLAZA, SUITE 1400
PHILADELPHIA, PA 19103
(215) 563-7000
COUNTRYWIDE HOME LOANS, INC.
Plaintiff
VS.
CONSTANCE M. VAN METER
MELVIN V. VAN METER, JR
Defendant(s)
CUMBERLAND COUNTY
CERTIFICATE OF SERVICE
I hereby certify that a strue and correct copy of Plaintiff's Praecipe to attach Verification
of Complaint was sent via first class mail to the following on the date listed below:
CONSTANCE M. VAN METER
MELVIN V. VAN METER, JR
122 YATES STREET
MOUNT HOLLY SPRINGS, PA 17065-1018
Phelan Hallinan & Schmieg, LLP
Attorney for Plaintiff ?
By:
Franc's . Hallinan, Es quire
ATTORNEY FOR PLAINTIFF
COURT OF COMMON PLEAS
CIVIL DIVISION
NO. 08-2415 CIVIL TERM
Date: 5/27/08
VERIFICATION
KERtSELMAN hereby states that he/she is
AWMTMEPREIT of COUNTRYWIDE HOME LOANS, INC., servicing agent for Plaintiff in this matter,
that he/she is authorized to take this Verification, and that the statements made in the foregoing Civil
Action in Mortgage Foreclosure are true and correct to the best of his/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.
F
Name: KERI SELMAN, ASSISTANT VICE PRESIDENT
DATE:
Title:
Company: COUNTRYWIDE HOME LOANS,
INC.
File #: 174120
.
y Z7-
PHELAN HALLINAN & SCHMIEG, L.L.P.
Vi.By: DANIEL G. SCHMIEG
Identification No. 62205
Attorney for Plaintiff
ONE PENN CENTER AT SUBURBAN STATION
1617 JOHN F. KENNEDY BLVD., SUITE 1400
PHILADELPHIA, PA 19103-1814
(215) 563-7000
COUNTRYWIDE HOME LOANS, INC.
7105 CORPORATE DRIVE
PLANO, TX 75024
CUMBERLAND COUNTY
COURT OF COMMON PLEAS
Plaintiff,
V.
CONSTANCE M. VAN METER
100 MOTTER LANE
BOLING SPRING, PA 17007
MELVIN V. VAN METER, JR.
100 MOTTER LANE
BOLING SPRINGS, PA 17007
CIVIL DIVISION
NO. 08-2415 CIVIL TERM
Defendant(s).
PRAECIPE FOR IN REM JUDGMENT FOR FAILURE TO
ANSWER AND ASSESSMENT OF DAMAGES
TO THE PROTHONOTARY:
Kindly enter an in rem judgment in favor of the Plaintiff and against CONSTANCE M. VAN
METER and MELVIN V. VAN METER. JR., Defendant(s) for failure to file an Answer to Plaintiff s
Complaint within 20 days from service thereof and for Foreclosure and Sale of the mortgaged premises,
and assess Plaintiffs damages as follows:
As set forth in Complaint $111,334.47
Interest from 04/16/2008 to 08/06/2008 $1,910.83
TOTAL $113,245.30
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.
DANIEL G. SCHMIEG,
Attorney for Plaintiff
DAMAGES ARE HEREBY ASSESSED AS INDICATED.
DATE: $ D p
s
k all,4.k
O PROTHY
174120
PHELAN HALLINAN & SCHMIEG, LLP
By: Lawrence T. Phelan, Esq., Id. No. 32227 ATTORNEY FOR PLAINTIFF
Francis S. Hallinan, Esq., Id. No. 62695
Daniel G. Schmieg, Esq., Id. No. 62205
Philadelphia, PA 19103
(215) 563_7000
COUNTRYWIDE HOME LOANS, INC. : COURT OF COMMON PLEAS
Plaintiff
Vs.
CIVIL DIVISION
CUMBERLAND COUNTY
CONSTANCE M. VAN METER
MELVIN V. VAN METER, JR. :NO. 2008-2415 CIVIL TERM
Defendants
TO: CONSTANCE M. VAN METER
100 MOTTER LANE
BOLING SPRINGS, PA 17007
DATE OF NOTICE: JRTLY R. 2008
THIS FIRM IS A DEBT COLLECTOR ATTEMPTING TO COLLECT A DEBT. THIS NOTICE IS SENT TO
YOU IN AN ATTEMPT TO COLLECT THE INDEBTEDNESS REFERRED TO HEREIN, AND ANY
INFORMATION OBTAINED FROM YOU WILL BE USED FOR THAT PURPOSE.IF YOU HAVE
PREVIOUSLY RECEIVED A DISCHARGE IN BANKRUPTCY, THIS CORRESPONDENCE IS NOT AND
SHOULD NOT BE CONSTRUED TO BE AN ATTEMPT TO COLLECT A DEBT, BUT ONLY AS
ENFORCEMENT OF LIEN AGAINST PROPERTY.
IMPORTANT NOTICE
YOU ARE IN DEFAULT BECAUSE YOU HAVE FAILED TO ENTER A WRITTEN APPEARANCE
PERSONALLY OR BY ATTORNEY AND FILE IN WRITING WITH THE COURT YOUR DEFENSES OR
OBJECTIONS TO THE CLAIMS SET FORTH AGAINST YOU. UNLESS YOU ACT WITHIN TEN DAYS FROM THE
DATE OF THIS NOTICE, A JUDGMENT MAY BE ENTERED AGAINST YOU WITHOUT A HEARING AND YOU
MAY LOSE YOUR PROPERTY OR OTHER IMPORTANT RIGHTS.
YOU SHOULD TAKE THIS PAPER TO YOUR LAWYER AT ONCE. IF YOU DO NOT HAVE A LAWYER,
GO TO OR TELEPHONE THE OFFICE SET FORTH BELOW. THIS OFFICE CAN PROVIDE YOU WITH
INFORMATION ABOUT HIRING A LAWYER.
IF YOU CANNOT AFFORD TO HIRE A LAWYER, THIS OFFICE MAY BE ABLE TO PROVIDE YOU WITH
INFORMATION ABOUT AGENCIES THAT MAY OFFER LEGAL SERVICES TO ELIGIBLE PERSONS AT A
REDUCED FEE OR NO FEE.
CUMBERLAND COUNTY
0 J j A LAWYER REFERRAL SERVICE
CUMBERLAND COUNTY BAR ASSOCIATION
32 SOUTH BEDFORD STREET
CARLISLE, PA 17013
(800)990-910$1.
Hainey, Legal Assistant
PHELAN HALLINAN & SCHMIEG, LLP
• ' Ny: Lawrence T. Phelan, Esq., Id. No. 32227 ATTORNEY FOR PLAINTIFF
Francis S. Hallinan, Esq., Id. No. 62695
Daniel G. Schmieg, Esq., Id. No. 62205
Philadelphia, PA 19103
(715) 561-7000
COUNTRYWIDE HOME LOANS, INC. : COURT OF COMMON PLEAS
Plaintiff
CIVIL DIVISION
Vs.
CUMBERLAND COUNTY
CONSTANCE M. VAN METER
MELVIN V. VAN METER, JR. :NO. 2008-2415 CIVIL TERM
Defendants
TO: MELVIN V. VAN METER, JR.
100 MOTTER LANE
BOILING SPRINGS, PA 17007
DATE OF NOTICE: J TTY 8, 2008
THIS FIRM IS A DEBT COLLECTOR ATTEMPTING TO COLLECT A DEBT. THIS NOTICE IS SENT TO
YOU IN AN ATTEMPT TO COLLECT THE INDEBTEDNESS REFERRED TO HEREIN, AND ANY
INFORMATION OBTAINED FROM YOU WILL BE USED FOR THAT PURPOSE.IF YOU HAVE
PREVIOUSLY RECEIVED A DISCHARGE IN BANKRUPTCY, THIS CORRESPONDENCE IS NOT AND
SHOULD NOT BE CONSTRUED TO BE AN ATTEMPT TO COLLECT A DEBT, BUT ONLY AS
ENFORCEMENT OF LIEN AGAINST PROPERTY.
IMPORTANT NOTICE
YOU ARE IN DEFAULT BECAUSE YOU HAVE FAILED TO ENTER A WRITTEN APPEARANCE
PERSONALLY OR BY ATTORNEY AND FILE IN WRITING WITH THE COURT YOUR DEFENSES OR
OBJECTIONS TO THE CLAIMS SET FORTH AGAINST YOU. UNLESS YOU ACT WITHIN TEN DAYS FROM THE
DATE OF THIS NOTICE, A JUDGMENT MAY BE ENTERED AGAINST YOU WITHOUT A HEARING AND YOU
MAY LOSE YOUR PROPERTY OR OTHER IMPORTANT RIGHTS.
YOU SHOULD TAKE THIS PAPER TO YOUR LAWYER AT ONCE. IF YOU DO NOT HAVE A LAWYER,
GO TO OR TELEPHONE THE OFFICE SET FORTH BELOW. THIS OFFICE CAN PROVIDE YOU WITH
INFORMATION ABOUT HIRING A LAWYER.
IF YOU CANNOT AFFORD TO HIRE A LAWYER, THIS OFFICE MAY BE ABLE TO PROVIDE YOU WITH
INFORMATION ABOUT AGENCIES-4NA MAY OFFER LEGAL SERVICES TO ELIGIBLE ?RSONS AT A
REDUCED FEE OR NO FEE.
CUMBERLAND COUNTY
LAWYER REFERRAL SERVICE
CUMBERLAND COUNTY BAR ASSOChy1bN
32 SOUTH BEDFORD STREET
CARLISLE, PA 17013
(800)990-9108 , rLilyey, Legal Assistant
PHELAN HALLINAN & SCHMIEG, L.L.P.
Ny: 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
COUNTRYWIDE HOME LOANS, INC.
7105 CORPORATE DRIVE
Plaintiff,
V.
CONSTANCE M. VAN METER
MELVIN V. VAN METER, JR.
Defendant(s).
ATTORNEY FOR PLAINTIFF
CUMBERLAND COUNTY
COURT OF COMMON PLEAS
CIVIL DIVISION
NO. 08-2415 CIVIL TERM
VERIFICATION OF NON-MILITARY SERVICE
DANIEL G. SCHMIEG, ESQUIRE, hereby verifies that he is attorney for the Plaintiff in
the above-captioned matter, and that on information and belief, he has knowledge of the following facts,
to wit:
(a) that the defendant(s) is/are not in the Military or Naval Service of the United States
or its Allies, or otherwise within the provisions of the Soldiers' and Sailors' Civil Relief Act of Congress
of 1940, as amended.
(b) that defendant CONSTANCE M. VAN METER is over 18 years of age and resides
at, 100 MOTTER LANE, BOLING SPRING, PA 17007.
(c) that defendant MELVIN V. VAN METER, JR. is over 18 years of age, and resides
at, 100 MOTTER LANE, BOLING SPRINGS, PA 17007.
This statement is made subject to the penalties of 18 Pa. C.S. Section 4904 relating to
unsworn falsification to authorities.
• C i N
DANIEL G. SCHMIEG, ESQUIRE
Attorney for Plaintiff
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cn ,•- t` 73
-v
A' (Rule of Civil Procedure No. 236) - Revised
IN THE COURT OF COMMON PLEAS OF CUMBERLAND COUNTY, PENNSYLVANIA
CIVIL ACTION - LAW
COUNTRYWIDE HOME LOANS, INC.
7105 CORPORATE DRIVE CUMBERLAND COUNTY
COURT OF COMMON PLEAS
Plaintiff, CIVIL DIVISION
V.
NO. 08-2415 CIVIL TERM
CONSTANCE M. VAN METER
MELVIN V. VAN METER, JR.
Defendant(s).
Notice is given that a Judgment in the above-captioned matter has been entered against you on
2009.
By: s J.?a ?• a
If you have any questions concerning this matter, please contact:
DANIEL G. SCHMIEG, ESQUI]
Attorney for Plaintiff
ONE PENN CENTER AT SUBURI
1617 JOHN F. KENNEDY BLVD.,
PHILADELPHIA, PA 19103-1814
(215) 563-7000
1400
"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."
(800) 990-9108
PRAECIPE FOR WRIT OF EXECUTION - (MORTGAGE FORECLOSURE)
P.R.C.P.3180-3183
COUNTRYWIDE HOME LOANS, INC.
Plaintiff,
V.
No. 08-2415 CIVIL TERM
CONSTANCE M. VAN METER
MELVIN V. VAN METER, JR.
Defendant(s).
TO THE DIRECTOR OF THE OFFICE OF THE PROTHONOTARY:
Issue writ of execution in the above matter:
Amount Due
Interest from 08/07/2008-12/10/2008
(per diem -$18.62)
TOTAL
$113,245.30
$2,346.12 and Costs
$115,591.42
Y
&?? L;?A __' -
DANIEL G. SCHMIEG, ES 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.
IMPORTANT NOTICE: This property is sold at the-direction of the
plaintiff. It may not be sold in the absence of.'s<:representative of
the plaintiff at the Sheriff's Sale.. The isale'ntust be postponed or
.
SLdyed in L-he event that a representative of.thb plaintiff is not
present at the sale.
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WRIT OF EXECUTION and/or ATTACHMENT
COMMONWEALTH OF PENNSYLVANIA)
COUNTY OF CUMBERLAND)
NO 08-2415 Civil
CIVIL ACTION - LAW
TO THE SHERIFF OF CUMBERLAND COUNTY:
To satisfy the debt, interest and costs due COUNTRYWIDE HOME LOANS, INC., Plaintiff (s)
From CONSTANCE M. VAN METRE & MELVIN V. VAN METER, JR.
(1) You are directed to levy upon the property of the defendant (s)and to sell SEE LEGAL
DESCRIPTION.
(2) You are also directed to attach the property of the defendant(s) not levied upon in the possession
of
GARNISHEE(S) as follows:
and to notify the garnishee(s) that: (a) an attachment has been issued; (b) the garnishee(s) is enjoined from
paying any debt to or for the account of the defendant (s) and from delivering any property of the defendant
(s) or otherwise disposing thereof;
(3) If property of the defendant(s) not levied upon an subject to attachment is found in the possession
of anyone other than a named garnishee, you are directed to notify him/her that he/she has been added as a
garnishee and is enjoined as above stated.
Amount Due $113,245.30
L.L. $.50
Interest FROM 8/7/08 -12/10/08 (PER DIEM - $18.62) -- $2,346.12 AND COSTS
Atty's Comm %
Atty Paid $175.00
Plaintiff Paid
Date: AUGUST 26, 2008
(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
Due Prothy $2.00
Other Costs
C is R. Long, Pr
By:
Deputy
Supreme Court ID No. 62205
LEGAL DESCRIPTION
All that certain tract or parcel of land and premises, situate, lying and being in the Borough of
Mount Holly Springs in the County of Cumberland and Commonwealth of Pennsylvania, more
particularly as follows:
BEGINNING at a point, the intersection of the Carlisle - Gettysburg Highway, also known as
Pennsylvania Highway Route No. 34, and the Southern line of Lot No. 64 on the hereinafter
mentioned Plan of Lots; thence extending at or nearly at right angles to said Highway, in a
Westerly direction to the 50 foot right-of-way of the P & R Railway; thence along said right-of-
way in a Southerly direction, 100 feet to a point on the Northern line of Lot No. 62 on said Plan
of Lots; thence in an Easterly direction along the Northern line of said Lot No. 62 to
Pennsylvania Highway Route No. 34 aforesaid; thence in a Northerly direction along said
Highway, 100 feet to the Place of BEGINNING.
BEING Lot No. 63 on the Plan of Lots of Mount Holly Gap Lake Resort, as recorded in the
Office of the Recorder of Deeds for Cumberland County in Plan Book 2, Page 95.
BEING improved with a dwelling house known as No. 122 Yates Street.
BEING the same property which was conveyed to Lenore L. Steinberger by Edgar J.
Steinberger and Lenore L. Steinberger, his wife, by deed dated August 24, 1979, and recorded
in the Office of the Recorder of Deeds in Deed Book'P', Vol. 28, Page 677.
TITLE TO SAID PREMISES IS VESTED IN Melvin V. Van Meter, Jr. and Constance M.
Van Meter, by Deed from Lenore L. Steinberger, dated 10/16/1989, recorded 10/17/1989, in
Deed Book F-34, page 617.
PREMISES BEING: 122 YATES STREET, MOUNT HOLLY SPRINGS, PA 17065-1018
PARCEL NO. 23-35-2316-048
PHELAN HALLINAN & SCHMIEG, L.L.P.
By: DANIEL G. SCHMIEG
Identification No. 62205
ONE PENN CENTER AT SUBURBAN STATION
1617 JOHN F. KENNEDY BLVD., SUITE 1400
PHILADELPHIA, PA 19103-1814
(215) 563-7000
COUNTRYWIDE HOME LOANS, INC.
Plaintiff,
V.
CONSTANCE M. VAN METER
MELVIN V. VAN METER, JR.
Defendant(s).
ATTORNEY FOR PLAINTIFF
CUMBERLAND COUNTY
COURT OF COMMON PLEAS
CIVIL DIVISION
NO. 08-2415 CIVIL TERM
CERTIFICATION
DANIEL G. SCHMIEG, ESQUIRE, hereby verifies that he is attorney for the Plaintiff in
the above-captioned matter, and that the premises are not subject to the provisions of Act 91
because it is:
() 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.
- /1? t , LUV
DANIEL G. SCHMI G, ESQUIRE
Attorney for Plaintiff
ws
Yr* °C m
AV - V&
Defendant(s).
CUMBERLAND COUNTY
COURT OF COMMON PLEAS
CIVIL DIVISION
NO. 08-2415 CIVIL TERM
AFFIDAVIT PURSUANT TO RULE 3129
(Affidavit No. l)
COUNTRYWIDE HOME LOANS, INC.
V.
Plaintiff,
CONSTANCE M. VAN METER
MELVIN V. VAN METER, JR.
COUNTRYWIDE HOME LOANS. 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 322 YATES STREET. MOUNT
HOLLY SPRINGS. PA 17065-1018.
1. Name and address of Owner(s) or reputed Owner(s):
Name
CONSTANCE M. VAN METER
MELVIN V. VAN METER, JR.
Last Known Address (if address cannot be
reasonably ascertained, please indicate)
100 MOTTER LANE
BOLING SPRING, PA 17007
100 MOTTER LANE
BOLING 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)
BEREAU OF COMPLIANCE DEPT. 280946
HARRISBURG, PA 17128-0946
4. Name and address of last recorded holder of every mortgage of record:
Name
BELCO COMMUNITY CREDIT UNION
Last Known Address (if address cannot be
reasonably ascertained, please indicate)
403 NORTH 2ND STREET
PO BOX 82
HARRISBURG, PA 17108
i --t. 5. Name and address of every other person who has any record lien on the property:
Name Last Known Address (if address cannot be
reasonably ascertained, please indicate)
None
6. Name and address of every other person who has any record interest in the property and whose
interest may be affected by the sale.
Name Last Known Address (if address cannot be
reasonably ascertained, please indicate)
None
7. Name and address of every other person of whom the plaintiff has knowledge who has any interest in
the property which may be affected by the sale:
Name
Last Known Address (if address cannot be
reasonably ascertained, please indicate)
Tenant/Occupant
Domestic Relations of Cumberland County
Commonwealth of Pennsylvania
Department of Welfare
Commonwealth of Pennsylvania
Bureau of Individual Tax
Inheritance Tax Division
Internal Revenue Service
Federated Investors Tower
Department of Public Welfare
TPL Casualty Unit
Estate Recovery Program
122 YATES STREET
MOUNT HOLLY SPRINGS, PA 17065-1018
13 North Hanover Street
Carlisle, PA 17013
PO Box 2675
Harrisburg, PA 17105
6th Floor, Strawberry Sq., Dept. 28061
Harrisburg, PA 17128
13th Floor, Suite 1300
1001 Liberty Avenue
Pittsburgh, PA 15222
P.O. Box 8486
Willow Oak Building
Harrisburg, PA 17105
I verify that the statements made in this affidavit are true and correct to the best of my personal
knowledge or information and belief. I understand that false statements herein are made subject to the
penalties of 18 Pa. C.S. Sec. 4904 relating to unworn falsification to authorities.
August 25, 2008 4;?f a h Ck4z
DATE DANIEL G. SCHMIEG, ESQUIRE
Attorney for Plaintiff
,.
c
o
COUNTRYWIDE HOME LOANS, INC.
Plaintiff,
V.
CONSTANCE M. VAN METER
MELVIN V. VAN METER, JR.
Defendant(s).
CUMBERLAND COUNTY
No. 08-2415 CIVIL TERM
August 25, 2008
TO: CONSTANCE M. VAN METER
100 MOTTER LANE
BOLING SPRING, PA 17007
MELVIN V. VAN METER, JR.
100 MOTTER LANE
BOLING SPRINGS, PA 17007
"THIS FIRM IS A DEBT COLLECTOR ATTEMPTING TO COLLECT A DEBT AND ANY INFORMATION
OBTAINED WILL BE USED FOR THAT PURPOSE. IF YOU HAVE PREVIOUSLYRECEIVED A DISCHARGE IN
BANKRUPTCY AND THIS DEBT WAS NOT REAFFIRMED, THIS IS NOT AND SHOULD NOT BE CONSTRUED TO BE
AN ATTEMPT TO COLLECT A DEBT, BUT ONLY ENFORCEMENT OF A LIEN AGAINST PROPERTY"
Your house (real estate) at, 122 YATES STREET, MOUNT HOLLY SPRINGS, PA 17065-
1018, is scheduled to be sold at the Sheriffs Sale on DECEMBER 10, 2008 at 10:00 a.m. in the
Cumberland County Courthouse, South Hanover Street, Carlisle, PA 17013, to enforce the court
judgment of 5111245.30 obtained by COUNTRYWIDE HOME LOANS, 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.
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
find out the price bid by calling (215) 563-7000.
2. You may be able to petition the Court to set aside the sale if the bid price was grossly
inadequate compared to the value of your property.
3. The sale will go through only if the buyer pays the Sheriff the full amount due in the sale. To
find out if this has happened, you may call (717) 240-6390.
4. If the amount due from the Buyer is not paid to the Sheriff, you will remain the owner of the
property as if the sale never happened.
5. You have the right to remain in the property until the full amount due is paid to the Sheriff
and the Sheriff gives a deed to the buyer. At that time, the buyer may bring legal proceedings to evict
you.
6. You may be entitled to a share of the money which was paid for your house. A schedule of
distribution of the money bid for your house will be filed by the Sheriff within 30 days of the sale. This
schedule will state who will be receiving that money. The money will be paid out in accordance with
this schedule unless exceptions (reasons why the proposed distribution is wrong) are filed with the
Sheriff within ten (10) days after the distribution is filed.
7. You may also have other rights and defenses, or ways of getting your home back, if you act
immediately after the sale.
YOU SHOULD TAKE THIS PAPER TO YOUR LAWYER AT ONCE. IF YOU DO NOT HAVE
A LAWYER OR CANNOT AFFORD ONE, GO TO OR TELEPHONE THE OFFICE LISTED
BELOW TO FIND OUT WHERE YOU CAN GET LEGAL HELP.
IMPORTANT NOTICE: This property is sold at the direction of the plaintiff. It may not be sold
in the absence of a representative of the plaintiff at the 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
l
rt
LEGAL DESCRIPTION
All that certain tract or parcel of land and premises, situate, lying and being in the Borough of
Mount Holly Springs in the County of Cumberland and Commonwealth of Pennsylvania, more
particularly as follows:
BEGINNING at a point, the intersection of the Carlisle - Gettysburg Highway, also known as
Pennsylvania Highway Route No. 34, and the Southern line of Lot No. 64 on the hereinafter
mentioned Plan of Lots; thence extending at or nearly at right angles to said Highway, in a
Westerly direction to the 50 foot right-of-way of the P & R Railway; thence along said right-of-
way in a Southerly direction, 100 feet to a point on the Northern line of Lot No. 62 on said Plan
of Lots; thence in an Easterly direction along the Northern line of said Lot No. 62 to
Pennsylvania Highway Route No. 34 aforesaid; thence in a Northerly direction along said
Highway, 100 feet to the Place of BEGINNING.
BEING Lot No. 63 on the Plan of Lots of Mount Holly Gap Lake Resort, as recorded in the
Office of the Recorder of Deeds for Cumberland County in Plan Book 2, Page 95.
BEING improved with a dwelling house known as No. 122 Yates Street.
BEING the same property which was conveyed to Lenore L. Steinberger by Edgar J.
Steinberger and Lenore L. Steinberger, his wife, by deed dated August 24, 1979, and recorded
in the Office of the Recorder of Deeds in Deed Book'P', Vol. 28, Page 677.
TITLE TO SAID PREMISES IS VESTED IN Melvin V. Van Meter, Jr. and Constance M.
Van Meter, by Deed from Lenore L. Steinberger, dated 10/16/1989, recorded 10/17/1989, in
Deed Book F-34, page 617.
PREMISES BEING: 122 YATES STREET, MOUNT HOLLY SPRINGS, PA 17065-1018
PARCEL NO. 23-35-2316-048
-TI
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AFFIDAVIT OF SERVICE
PLAINTIFF COUN I'RYWEDE HOME LOANS, INC.
DEFENDANT(S) CONSTANCE M. VAN METER
MELVIN V. VAN METER, JR.
SERVE CONSTANCE M. VAN METER AT:
100 MOTTER LANE
BOLING SPRING, PA 17007
SERVED
CUMBERLAND COUNTY
No. 08-2415 CIVIL TERM
ACCT. #174120
Type of Action
- Notice of Sheriff's Sale
Sale Date: DECEMBER 10, 2008
Served and made known to ()Q N " WCE M - VAN Defendant, on the 13 day of- Cr/r?* 200E
at 9 f N o'clock &_.m., at 100 A(4Tj1AQ CAF N£,1301 L I A6, 5 r 4&5 , Commonwealth
of Pennsylvania, in the manner described below:
Defendant personally served.
%/ Adult family member with whom Defendant(s) reside(s). Name and Relationship is 4U S 8"D
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
A ,6 Height J -( ` WeightAC6 Race W Sex M Other
I, K() )V41= b / Vld L(-- , a competent adult, being duly sworn according to law, depose and state that 1 personally handed
a true and correct copy of the Notice of Sheriffs Sale in the manner as set forth herein, issued in the captioned case on the date and at
the address indicated above.
to and
200 C??? "A
_? _
By: -at44-
T SERVICE AT LEAST 3 TIMES. INDICATE DATES & TIMES OF SERVICE ATTEMPTED.
Notary Publla
Strom of NeM, Jersey NOT SERVED
CPATibCIA E. HARRIS
84,m"108106 PI^!lli4YlAr 16, M2
, 200_, at o'clock _.m., Defendant NOT FOUND because:
Moved Unknown No Answer Vacant
1sr Attempt: Time: 2"d Attempt: Time:
3rd Attempt: Time:
Sworn to and subscribed Attorney for Plaintiff
before me this day DANIEL G. SCHMIEG, Esquire - I.D. No. 62205
of , 200. One Penn Center at Suburban Station, Suite 1400
Notary: By: 1617 John F. Kennedy Boulevard
Philadelphia, PA 19103-1814
(215) 563-7000
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PLAINTIFF COUNTRYWIDE HOME LOANS, INC.
DEANT(S) CONSTANCE M. VAN METER
MELVIN V. VAN METER, JR.
SERVE MELVIN V. VAN METER, JR. AT:
100 MOTTER LANE
BOLING SPRINGS, PA 17007
CUMBERLAND COUNTY
No. 08-2415 CIVIL TERM
ACCT. #174120
Type of Action
- Notice of Sheriffs Sale
Sale Date: DECEMBER 10, 2008
SERVED Q
Served and made known to M F-1. VI N V. VAN MF-Tf .Defendant, on the 13 ?' day of J[-?130J,
, 200.6 at 93S, . o'clock 4-.m., at t OO M O TTr=9 L4NE f %1 LI N& SpaI NGS
, Commonwealth of Pennsylvania, in the manner described below:
? Defendant personally served.
Adult family member with whom Defendant(s) reside(s). Name and Relationship is _
Adult in charge 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 =50- Height-5A' Weight 90d Race W Sex /1,0?'1 Other
1,i _n I?(_ , 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.
By: rp.
C LEAST 3 TIMES. INDICATE DATES & TIMES OF SERVICE
ATTEMPTED.
NNotoy Public NOT SERVED
ftft of Now Jm"
PATRICIA
200. at o'clock _.in., Defendant NOT FOUND because:
Moved Unknown No Answer Vacant
lg` Attempt: Time: 2°d Attempt: Time:
3rd Attempt: Time:
Sworn to and subscribed Attorney for Plaintiff
before me this day DANIEL G. SCHMIEG, Esquire - I.D. No. 62205
of , 200_. One Penn Center at Suburban Station, Suite 1400
Notary: By: 1617 John F. Kennedy Boulevard
Philadelphia, PA 19103-1814
(215) 563-7000
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IN THE COURT OF COMMON PLEAS
OF CUMBERLAND COUNTY, PENNSYLVANIA
COUNTRYWIDE HOME LOANS, INC. CUMBERLAND COUNTY
Plaintiff COURT OF COMMON PLEAS
V.
CIVIL DIVISION
CONSTANCE M. VAN METER
MELVIN V. VAN METER, JR. NO. 08-2415 CIVIL TERM
Defendant(s)
AFFIDAVIT OF SERVICE PURSUANT TO RULE 3129
COMMONWEALTH OF PENNSYLVANIA )
COUNTY OF CUMBERLAND COUNTY ) SS:
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 YATES STREET, MOTTT`T'i'
HOLLY SPRINGS, PA 12065-1019.
As required by Pa. R.C.P. 3129.2(a) Notice of Sale has been given to Lienholders 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
Affidavit No. 2 (previously filed) and/or Amended Affidavit No. 2 on the date indicated. 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 G. SCHMIEG, ESQU
Attorney for Plaintiff
Date: November 10, 2008
IMPORTANT NOTICE: This property is sold at the direction of the plaintiff. It may not he cold in h
ahsence of a r precentativ of the nlaintiff at the Sheriff c Sale. The sale must be postponed or stayed in the
event that a representative of the plaintiff is not present at the sale.
174120
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COMMONWEALTH OF PENNSYLVANIA
COUNTY OF CUMBERLAND
SS:
I, Robert P. Ziegler, Recorder of Deeds in and for said County and State do hereby certify that
the Sheriff s Deed in which Fannie Mae is the grantee the same having been sold to said grantee on the 4
day of February A.D., 2009, under and by virtue of a writ Execution issued on the 26 day of Au ust,
A.D., 2008, out of the Court of Common Pleas of said County as of Civil Term, 2008 Number 2415, at
the suit of Countrywide Home Loans Inc against Constance M & Melvin V VanMeter Jr is duly
aotol o 5633
recorded as Instrument Number 12-ani a-A4Afa C#?
IN TESTIMONY WHEREOF, I have hereunto set my hand
and seal of said office this oZ
`?'lG?ftt4 , A.D.P---e)Oq
day of
amowdy of Ga' s, cumbert2nd county, caftle, P ecorder of Deeds
My Conaalsslon Expaes the Fkst Monday of Jan. 2010
Countrywide Home Loans, Inc.
VS
Constance M. Van Meter
and Melvin V. Van Meter, Jr.
In The Court of Common Pleas of
Cumberland County, Pennsylvania
Writ No. 2008-2415
Stephen Bender, Deputy Sheriff, who being duly sworn according to law, states that on
September 11, 2008 at 1750 hours, he served a true copy of the within Real Estate Writ, Notice and
Description, in the above entitled action, upon the within named defendants, to wit: Constance M.
Van Meter and Melvin V. Van Meter, by making known unto Constance M. Van Meter and Melvin
V. Van Meter, Jr., personally, at 100 Motter Lane, Boiling Springs, Cumberland County,
Pennsylvania its contents and at the same time handing to them personally the said true and correct
copy of the same.
Kenneth Gossert, Deputy Sheriff, who being duly sworn according to law, states that on
October 11, 2008 at 1051 hours, he posted a true copy of the within Real Estate Writ, Notice, Poster
and Description, in the above entitled action, upon the property of Constance M. Van Meter and
Mely)i V. Van Meter, Jr., located at 122 Yates Street, Mt. Holly 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 defendants, to wit: Constance M.
Van Meter and Melvin V. Van Meter, Jr., by regular mail to their last known address of 100 Molter
Lane, Boiling Springs, PA 17007. These letters were mailed under the date of October 7, 2008 and
never returned to the Sheriffs Office.
R. Thomas Kline, Sheriff, who being duly sworn according to law, states that after due and
legal notice had been given according to law, he exposed the within described premises at public
venue or outcry at the Courthouse, Carlisle, Cumberland County, Pennsylvania on February 4, 2009
at 10:00 o'clock A.M., He sold the same for the sum of $1.00 to Attorney Daniel G. Schmieg, on
behalf of Fannie Mae. It being the highest bid and best price received for the same, Fannie Mae of
P.O. Box 650043, Dallas TX 75265-0043, being the buyer in this execution, paid to Sheriff R.
Thomas Kline the sum of $ 1,068.10
Sheriffs Costs:
Docketing $30.00
Poundage 20.94
Posting Bills 15.00
Advertising 15.00
Acknowledging Deed 48.00
Auctioneer 10.00
Law Library .50
Prothonotary 2.00
Mileage 13.00
Levy 15.00
Surcharge 30.00
Post Pone Sale 40.00
Law Journal 371.00
Patriot News 368.24
Share of Bills 14.92
i?=° }
a r ? r^
A?ti.?s -? ?..
Distribution of Proceeds 25.00
Sheriffs Deed 49.50
$1,068.10
So Answers:
R. Thomas Kline, Sheriff
BY
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Real Estate Coordinator
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. nUNTRYWIDE HOME LOANS, INC.
Plaintiff,
V.
•
CONSTANCE M. VAN METER
MELVIN V. VAN METER, JR.
Defendant(s).
CUMBERLAND COUNTY
COURT OF COMMON PLEAS
CIVIL DIVISION
NO. 08-2415 CIVIL TERM
AFFIDAVIT PURSUANT TO RULE 3129
(Affidavit No. l)
COUNTRYWIDE HOME LOANS, 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 ,122 YATES STREET, MOUNT
HOLLY SPRINGS, PA 17065-1018.
1. Name and address of Owner(s) or reputed Owner(s):
Name
Last Known Address (if address cannot be
reasonably ascertained, please indicate)
CONSTANCE M. VAN METER
MELVIN V. VAN METER, JR.
100 MOTTER LANE
BOLING SPRING, PA 17007
100 MOTTER LANE
BOLING 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)
BEREAU OF COMPLIANCE DEPT. 280946
HARRISBURG, PA 17128-0946
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)
BELCO COMMUNITY CREDIT UNION
403 NORTH 2ND STREET
PO BOX 82
HARRISBURG, PA 17108
5. Name and address of every other person who has any record lien on the property:
Name
Last Known Address (if address cannot be
reasonably ascertained, please indicate)
None
6. Name and address of every other person who has any record interest in the property and whose
interest may be affected by the sale.
Name
Last Known Address (if address cannot be
reasonably ascertained, please indicate)
None
7. Name and address of every other person of whom the plaintiff has knowledge who has any interest in
the property which may be affected by the sale:
Name
Last Known Address (if address cannot be
reasonably ascertained, please indicate)
Tenant/Occupant
Domestic Relations of Cumberland County
Commonwealth of Pennsylvania
Department of Welfare
Commonwealth of Pennsylvania
Bureau of Individual Tax
Inheritance Tax Division
Internal Revenue Service
Federated Investors Tower
Department of Public Welfare
TPL Casualty Unit
Estate Recovery Program
122 YATES STREET
MOUNT HOLLY SPRINGS, PA 17065-1018
13 North Hanover Street
Carlisle, PA 17013
PO Box 2675
Harrisburg, PA 17105
6th Floor, Strawberry Sq., Dept. 28061
Harrisburg, PA 17128
13th Floor, Suite 1300
1001 Liberty Avenue
Pittsburgh, PA 15222
P.O. Box 8486
Willow Oak Building
Harrisburg, PA 17105
I verify that the statements made in this affidavit are true and correct to the best of my personal
knowledge or information and belief. I understand that false statements herein are made subject to the
penalties of 18 Pa. C.S. Sec. 4904 relating to unsworn falsification to authorities.
August 25, 2008 414'a t h- ?w
DATE DANIEL G. SCHMIEG, ESQUIRE
Attorney for Plaintiff
COUNTRYWIDE HOME LOANS, INC.
Plaintiff,
V.
CONSTANCE M. VAN METER
MELVIN V. VAN METER, JR.
Defendant(s).
CUMBERLAND COUNTY
No. 08-2415 CIVIL TERM
August 25, 2008
TO: CONSTANCE M. VAN METER
100 MOTTER LANE
BOLING SPRING, PA 17007
MELVIN V. VAN METER, JR.
100 MOTTER LANE
BOLING SPRINGS, PA 17007
* *THIS FIRM IS A DEBT COLLECTOR ATTEMPTING TO COLLECT A DEBT AND ANY INFORMATION
OBTAINED WILL BE USED FOR THAT PURPOSE. IF YOU HAVE PREVIOUSLYRECEIVED A DISCHARGE IN
BANKRUPTCY AND THIS DEBT WAS NOT REAFFIRMED, THIS IS NOT AND SHOULD NOT BE CONSTRUED TO BE
ANA TTEMPT TO COLLECT A DEBT, BUT ONLY ENFORCEMENT OFALIEN AGAINST PROPERTY."
Your house (real estate) at, 122 YATES STREET, MOUNT HOLLY SPRINGS, PA 17065-
1018, is scheduled to be sold at the Sheriffs Sale on DECEMBER 10, 2008 at 10:00 a.m. in the
Cumberland County Courthouse, South Hanover Street, Carlisle, PA 17013, to enforce the court
judgment of $113,245.30 obtained by COUNTRYWIDE HOME LOANS, 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:
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.
You may also be able to stop the sale through other legal proceedings.
You may need an attorney to assert your rights. The sooner you contact one, the more chance
you will have of stopping the sale. (See notice on page two on how to obtain an attorney.)
YOU MAY STILL BE ABLE TO SAVE YOUR PROPERTY AND YOU HAVE OTHER
RIGHTS EVEN IF THE SHERIFF'S SALE DOES TAKE PLACE.
1. If the Sheriff s Sale is not stopped, your property will be sold to the highest bidder. You may
find out the price bid by calling (215) 563-7000.
2. You may be able to petition the Court to set aside the sale if the bid price was grossly
inadequate compared to the value of your property.
3. The sale will go through only if the buyer pays the Sheriff the full amount due in the sale. To
find out if this has happened, you may call (717) 240-6390.
4. If the amount due from the Buyer is not paid to the Sheriff, you will remain the owner of the
property as if the sale never happened.
5. You have the right to remain in the property until the full amount due is paid to the Sheriff
and the Sheriff gives a deed to the buyer. At that time, the buyer may bring legal proceedings to evict
you.
6. You may be entitled to a share of the money which was paid for your house. A schedule of
distribution of the money bid for your house will be filed by the Sheriff within 30 days of the sale. This
schedule will state who will be receiving that money. The money will be paid out in accordance with
this schedule unless exceptions (reasons why the proposed distribution is wrong) are filed with the
Sheriff within ten (10) days after the distribution is filed.
7. You may also have other rights and defenses, or ways of getting your home back, if you act
immediately after the sale.
YOU SHOULD TAKE THIS PAPER TO YOUR LAWYER AT ONCE. IF YOU DO NOT HAVE
A LAWYER OR CANNOT AFFORD ONE, GO TO OR TELEPHONE THE OFFICE LISTED
BELOW TO FIND OUT WHERE YOU CAN GET LEGAL HELP.
IMPORTANT NOTICE: This property is sold at the direction of the plaintiff. It may not be 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
LEGAL DESCRIPTION
All that certain tract or parcel of land and premises, situate, lying and being in the Borough of
Mount Holly Springs in the County of Cumberland and Commonwealth of Pennsylvania, more
particularly as follows:
BEGINNING at a point, the intersection of the Carlisle - Gettysburg Highway, also known as
Pennsylvania Highway Route No. 34, and the Southern line of Lot No. 64 on the hereinafter
mentioned Plan of Lots; thence extending at or nearly at right angles to said Highway, in a
Westerly direction to the 50 foot right-of-way of the P & R Railway; thence along said right-of-
way in a Southerly direction, 100 feet to a point on the Northern line of Lot No. 62 on said Plan
of Lots; thence in an Easterly direction along the Northern line of said Lot No. 62 to
Pennsylvania Highway Route No. 34 aforesaid; thence in a Northerly direction along said
Highway, 100 feet to the Place of BEGINNING.
BEING Lot No. 63 on the Plan of Lots of Mount Holly Gap Lake Resort, as recorded in the
Office of the Recorder of Deeds for Cumberland County in Plan Book 2, Page 95.
BEING improved with a dwelling house known as No. 122 Yates Street.
BEING the same property which was conveyed to Lenore L. Steinberger by Edgar J.
Steinberger and Lenore L. Steinberger, his wife, by deed dated August 24, 1979, and recorded
in the Office of the Recorder of Deeds in Deed Book 'P', Vol. 28, Page 677.
TITLE TO SAID PREMISES IS VESTED IN Melvin V. Van Meter, Jr. and Constance M.
Van Meter, by Deed from Lenore L. Steinberger, dated 10/16/1989, recorded 10/17/1989, in
Deed Book F-34, page 617.
PREMISES BEING: 122 YATES STREET, MOUNT HOLLY SPRINGS, PA 17065-1018
PARCEL NO. 23-35-2316-048
WRIT OF EXECUTION and/or ATTACHMENT
COMMONWEALTH OF PENNSYLVANIA)
COUNTY OF CUMBERLAND)
NO 08-2415 Civil
CIVIL ACTION - LAW
If TO THE SHERIFF OF CUMBERLAND COUNTY:
To satisfy the debt, interest and costs due COUNTRYWIDE HOME LOANS, INC., Plaintiff (s)
From CONSTANCE M. VAN METRE & MELVIN V. VAN METER, JR.
(1) You are directed to levy upon the property of the defendant (s)and to sell SEE LEGAL
DESCRIPTION.
(2) You are also directed to attach the property of the defendant(s) not levied upon in the possession
of
GARNISHEE(S) as follows:
and to notify the garnishee(s) that: (a) an attachment has been issued; (b) the garnishee(s) is enjoined from
paying any debt to or for the account of the defendant (s) and from delivering any property of the defendant
(s) or otherwise disposing thereof;
(3) If property of the defendant(s) not levied upon an subject to attachment is found in the possession
of anyone other than a named garnishee, you are directed to notify him/her that he/she has been added as a
garnishee and is enjoined as above stated.
Amount Due $113,245.30
L.L. $.50
Interest FROM 8/7/08 -12/10/08 (PER DIEM - $18.62) -- $2,346.12 AND COSTS
Atty's Comm %
Atty Paid $175.00
Plaintiff Paid
Due Prothy $2.00
Other Costs
Date: AUGUST 26, 2008
(Seal)
REQUESTING PARTY:
/ ??/61 - 4. -t ? - ?-- -
C R. Long, Proth
By:
Deputy
Name DANIEL G. SCHMIEG, ESQUIRE
Address: ONE PENN CENTER AT SUBURBAN STATION
1617 JOHN F. KENNEDY BOULEVARD, SUITE 1400
PHILADELPHIA, PA 19103-1814
Attorney for: PLAINTIFF
Telephone: 215-563-7000
Supreme Court ID No. 62205
Real Estate Sale #60
On September 5, 2008 the Sheriff levied upon the
defendant's interest in the real property situated in
Mt. Holly Springs Borough, Cumberland County, PA
Known and numbered as 122 Yates Street, Mt. Holly Springs
more fully described on Exhibit "A"
filed with this writ and by this reference
incorporated herein.
Date: September 5, 2008 By:
Real Esta Sergeant
,(lee
PROOF OF PUBLICATION OF NOTICE
IN CUMBERLAND LAW JOURNAL
(Under Act No. 587, approved May 16, 1929), P. L.1784
COMMONWEALTH OF PENNSYLVANIA
ss.
COUNTY OF CUMBERLAND :
Lisa Marie Coyne, Esquire, Editor of the Cumberland Law Journal, of the County and
State aforesaid, being duly sworn, according to law, deposes and says that the Cumberland Law
Journal, a legal periodical published in the Borough of Carlisle in the County and State aforesaid,
was established January 2, 1952, and designated by the local courts as the official legal
periodical for the publication of all legal notices, and has, since January 2, 1952, been regularly
issued weekly in the said County, and that the printed notice or publication attached hereto is
exactly the same as was printed in the regular editions and issues of the said Cumberland Law
Journal on the following dates,
viz:
October 31, November 7 and November 14, 2008
Affiant further deposes that he is authorized to verify this statement by the Cumberland
Law Journal, a legal periodical of general circulation, and that he is not interested in the subject
matter of the aforesaid notice or advertisement, and that all allegations in the foregoing
statements as to time, place and character of publication are true.
SWORW,TO AND SUBSCRIBED before me this
4 day of November, 200
Notary
NOTARIAL SEAL
DEBORAH A COLLINS
Notary Public
CARLISLE BORO, CUMBERLAND COUNTY
MY Commission Expires Apr 28, 2010
REAL EBTATE BALE NO. 60
Writ No. 2008-2415 Civil
Countrywide Home Loans, Inc.
VS.
Constance M. Van Meter and
Melvin V. Van Meter, Jr.
Atty.: Daniel Schmieg
LEGAL DESCRIPTION
All that certain tract or parcel of
land and premises, situate, lying and
being in the Borough of Mount Holly
Springs in the County of Cumberland
and Commonwealth of Pennsylvania,
more particularly as follows:
BEGINNING at a point, the inter-
section of the Carlisle-Gettysburg
Highway, also known as Pennsylva-
nia Highway Route No. 34, and the
Southern line of Lot No. 64 on the
hereinafter mentioned Plan of Lots;
? a
wo*s to said Highway, in a Westerly
direction to the 50 foot right-of-way of
the P & R Railway; thence along said
right-of-way in a Southerly direction,
100 feet to a point on the Northern
line of Lot No. 62 on said Plan of Lots;
thence in an Easterly direction along
the Northern line of said Lot No. 62
to Pennsylvania Highway Route No.
34 aforesaid; thence in a Northerly
direction along said Highway, 100
feet to the Place of BEGINNING.
BEING Lot No. 63 on the Plan of
Lots of Mount Holly Gap Lake Re-
sort, as recorded in the Office of the
Recorder of Deeds for Cumberland
County in Plan Book 2, Page 95.
BEING improved with a dwell-
ing house known as No. 122 Yates
Street.
BEING the same property which
was conveyed to Lenore L. Stein-
berger by Edgar J. Steinberger and
Lenore L. Steinberger, his wife, by
deed dated August 24, 1979, and
recorded in the Office of the Recorder
of Deeds in Deed Book `P', Vol. 28,
Page 677.
TITLE TO SAID PREMISES IS
VESTED IN Melvin V. Van Meter,
Jr. and Constance M. Van Meter,
by Deed from Lenore L. Steinberger,
dated 10/ 16/ 1989, recorded 10/ 17/
1989, in Deed Book F-34, page 617.
PREMISES BEING: 122 YATES
STREET, MOUNT HOLLY SPRINGS,
PA 17065-1018.
PARCEL NO. 23-35-2316-048.
1"The Patriot-News Co.
812 Market St.
Harrisburg, PA 17101
inquiries - 717-255-8213
CUMBERLAND COUNTY SHERIFFS OF
CUMBERLAND COUNTY COURT HOUSE
CARLISLE
PA 17013
ZheAPatriot-News
Now you know
THE PATRIOT NEWS
THE SUNDAY PATRIOT NEWS
Proof of Publication
Under Act No. 587, Approved May 16, 1929
Commonwealth of Pennsylvania, County of Dauphin} ss
Joseph A. Dennison, being duly sworn according to law, deposes and says:
That he is the Assistant Controller of The Patriot News Co., a corporation organized and existing under the laws of the
Commonwealth of Pennsylvania, with its principal office and place of business at 812 to 818 Market Street, in the City of
Harrisburg, County of Dauphin, State of Pennsylvania, owner and publisher of The Patriot-News and The Sunday Patriot-News
newspapers of general circulation, printed and published at 812 to 818 Market Street, in the City, County and State aforesaid; that
The Patriot-News and The Sunday Patriot-News were established March 4th, 1854, and September 18th, 1949, respectively, and
all have been continuously published ever since;
That the printed notice or publication which is securely attached hereto is exactly as printed and published in their regular
daily and/or Sunday/ Metro editions which appeared on the date(s) indicated below. That neither he nor said Company is
interested in the subject matter of said printed notice or advertising, and that all of the allegations of this statement as to the time,
place and character of publication are true; and
That he has personal knowledge of the facts aforesaid and is duly authorized and empowered to verify this statement on
behalf of The Patriot-News Co. aforesaid by virtue and pursuant to a resolution unanimously passed and adopted severally by the
stockholders and board of directors of the said Company and subsequently duly recorded in the office for the Recording of Deeds
in and for said County of Dauphin in Miscellaneous Book "M", Volume 14, Page 317.
PUBLICATION COPY This ad ran on the date(s) shown below:
10/29/08
11/05/08
11/12/08
Sworn to an, subsdribed befor me tt i? ?5 day of November, 2008 A.D.
Notary Public
COMMONWEA1 TH C7= PENNSYLVANIA
Notarial Seal
Shen* ,_ finer, Notary Public
City Of Harrisburg, Dauphin County
MY Commission E-Vires Nov. 26, 2011 I
Member Pennsyiva,oia Association of Notaries
Real Ewa Sate No. 60
Writ No. 2OW2415 CM Tom
Countrywide Home Loans, Inc.
VS
Constance M. Van Meter and
Melvin V. Van Meter, Jr.
Attorney Daniel Schmieg
LEGAL DESCRIPTION
All that certain tract or parcel of ]and and
premises, situate, lying and being in the
Borough of Mount Holly Springs in the County
of Cumberland and Commonwealth of
Pennsylvania, more particularly as follows:
BEGINNING at a point, the intersection of the
Carlisle - Gettysburg Highway, also known as
Pennsylvania Highway Route No. 34, and the
Southern fine of Lot No. 64 on the hereinafter
mentioned Plan of Lots; thence extending at or
nearly at right angles to said Highway, in a
Westerly direction to the 50 foot right-of-way of
the P & R Railway;, thence along said right-of-
way in a Southerly direction, 100 feet to a point
on the Northern line of Lot No. 62 on said Plan
of Lots; thence in an Easterly direction along the
Northern line of said Lot No. 62 to Pennsylvania
Highway Route No. `34 aforesaid; thence in a
Northerly direction along said Highway, 100
feet to the Place of BEGINNING.
BEING Lot Na 63 on the Plan of Lots of Mount
Holly Gap Lake Resort, as recorded in the
Office of the Recorder of Deeds for Cumberland
County in Plan Book 2, Page 95.
BEING improved with a dwelling house known
as No. 122 Yates Street.
BEING'tbe same property which was conveyed
to Lenore L Steldbagat by Edgar J. Steinberger
and Lenore. L. Stchkiger, his wife, by deed
dated August 24, 1979, and recorded in the
Office of the Rem of Deeds in Deed Book
`P', Vol. 28, Page 677.
TITLE TO SAID PREMISES IS VESTED IN
Melvin V Van Meter, k and Constance M. Van
Meter, by Deed from Lenore L. Stemberger.
dated 10/16!1989, recorded 1011711989, in Deed
Book R•34, page 617.
PREMISES BEING: 122 YATES STREET,
MOUNT HOLLY SPRINGS, PA 17065-1018
PARCEL NO. 23-35-2316-048
?the patriot-Mu is
Now you know
P. O. BOX 2265
HARRISBURG, PA 17105
(717) 255-6237
BILL TO: Cumberland County Sheriffs Office
Cumberland County Court House
Carlisle, PA 17013
ACCT. #
2260
DUPLICATE BILL
10/29/08
11/05/08
11/12/08
Of Ad
Sheriff Sale 60 8.31 $14.57 $ 121.08
Sheriff Sale 60 8.31 $14.57 $ 121.08
Sheriff Sale 60 8.31 $14.57 $ 121.08
Notary Fee I I I I I 1 1 $5.00
TOTAL DUE FOR THIS SALE:
$ 368.24
JLC