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Home My WebLink About04-1063 IN THE COURT OF COMMON PLEAS OF CUMBERLAND COUNTY, PENNSYLVANIA JAMES B. NUTTER & COMPANY CIVIL DIVISION NO. 04 - JDW c;,,\t'y~ Plaintiff, COMPLAINT IN MORTGAGE FORECLOSURE vs. JEHAD A. EWIDEH and NIVERTITI EWIDEH Code - MORTGAGE FORECLOSURE Filed on behalf of Plaintiff Defendants. Counsel of record for this party: Louis P. Vitti, Esquire PA J.D. #3810 Supreme Court #01072 Louis P. Vitti & Assoc., P.C. 916 Fifth Avenue Pittsburgh, PA 15219 (412) 281-1725 IN THE COURT OF COMMON PLEAS OF CUMBERLAND COUNTY, PENNSYLV ANlA CIVIL DIVISION Ys. ) ) ) ) ) ) JAMES B. NUTTER & COMPANY Plaintiff, NO: 04 - Cw iL't-E/2.n-- I JEHAD A. EWIDEH and NlVERTITI EWIDEH Defendant( s) COMPLAINT lN MORTGAGE FORECLOSURE NOTICE YOU HAVE BEEN SUED IN COURT. IF YOU WISH TO DEFEND AGAINST THE CLAIMS SET FORTH IN THE FOLLOWING PAGES, YOU MUST TAKE ACTION WITillN TWENTY (20) DAYS AFTER TillS COMPLAINT AND NOTICE ARE SERVED, BY ENTERING A WRITTEN APPEARANCE PERSONALLY OR BY THE ATTORNEY AND FILING IN WRITING WITH THE COURT YOUR DEFENSES AND 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 TillS PAPER TO YOUR LAWYER AT ONCE. IF YOU SHOULD 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. IF YOU CANNOT AFFORD TO HIRE A LAWYER, TillS OFFICE MAY BE ABLE TO PROVIDE YOU WITH INFORMATION ON AGENCIES THAT MAY OFFER LEGAL SERVICES TO ELIGIBLE PERSONS AT A REDUCED FEE OR NO FEE. CUMBERLAND COUNTY BAR ASSOCIATION 2 LIBERTY AVENUE CARLISLE, P A 17013 (717) 249-3166 COMPLAINT IN MORTGAGE FORECLOSURE AND NOW, comes the Plaintiff by its attorneys, Louis P. Vitti and Associates, P.C. and Louis P. Vitti, Esquire, and pursuant to the Pennsylvania Rules of Civil Procedure Numbers 1141 through 1150, for its Complaint in Mortgage Foreclosure, sets forth the following: 1. The Plaintiff is a corporation duly authorized to conduct business within the laws of the Commonwealth of Pennsylvania, having a principal place of business located at WestportJPlaza Office, 4153 Broadway, P.O. Box 10346, Kansas City, MO 64171. 2. The Defendant(s) is/are individuals with a last known mailing address of 149 Chester Street, Carlisle PA 17013. The property address is 149 Chester St, Carlisle, PA 17013 and is the subject of this action. 3. On the 14th day of May, 2001, in consideration ofa loan of One Hundred Four Thousand Four Hundred Forty Nine and 00/100 ($104,449.00) Dollars made by James B. Nutter & Company, a MO corporation, to Defendant(s), the said Defendant(s) executed and delivered to James B. Nutter & Company, a MO corporation, a "Note" secured by a Mortgage with the Defendant(s) as mortgagor(s) and James B. Nutter & Company, as mortgagee, which mortgage was recorded on the 26th day of June, 2001, in the Office of the Recorder of Deeds of Cumberland County, in Mortgage Book Volume 1724, page 538. The said mortgage is incorporated herein by reference thereto as though the same were set forth fully at length. 4. The premises secured by the mortgage are: SEE EXHffiIT "A" ATTACHED HERETO. 5. Said mortgage provides, inter alia: "that when as soon as the principal debt secured shall become due and payable, or in case default shall be made in the payment of any installment of principal and interest, or any monthly payment, keeping and performance by the mortgagor of any of the terms, conditions or covenants of the mortgage or note, it shall be lawful for mortgagee to bring an Action of Mortgage Foreclosure, or other proceedings upon the mortgage, of principal debt, interest and all other recoverable sums, together with attomey's fees. " 6. Since July 1, 2003, the mortgage has been in default by reason, inter alia, of the failure of the mortgagor(s) to make payments provided for in the said mortgage (including principal and interest) and, under the terms of the mortgage, the entire principal sum is due and payable. 7. In accordance with the appropriate Pennsylvania Acts of Assembly and the Pennsylvania Rules of Civil Procedure, the mortgagor(s) has been advised in writing of the mortgagees intention to foreclose. The appropriate time period has elapsed since the Notice of Intention to Foreclose has been served upon the mortgagor(s). 8. The amount due on said mortgage is itemized on the attached schedule. 9. Plaintiff does hereby release the personal representative, heir and/or devisee of the mortgagor(s) from liability for the debt secured by the mortgage. WHEREFORE, pursuant to Pennsylvania Rule of Civil Procedure Number 114 7( 6), Plaintiff demands judgment for the amount due of One Hundred Twelve Eight Hundred Four and 50/100 Dollars ($112,804.50) with interest and costs. Respectfully submitted, LOUIS P. VITTI & ASSOC., P.C. BY , . ! r;tp)(~ / Louis P. Vitti, Esquire . Attorney for Plaintiff EWIDEH SCHEDULE OF AMOUNTS DUE UNDER MORTGAGE Unpaid Principal Balance Interest @ 7.5000% from 06/01/03 through (plus $20.0467 per day after 3/31/2004 ) 3/31/2004 Late charges through 3/9/2004 o months @ 40.20 Accumulated beforehand (Plus $40.20 on the 17th day of each month after 3/9/2004 ) Attorney's fee Escrow deficit (This figure includes projected additional charges that may be incurred by the Plaintiff and transmitted to the sheriff as charges on the writ prior to the date of the sheriff's sale) BALANCE DUE 97,560.51 6,094.19 320.56 4,878.03 3.951.21 112,804.50 .:- : ,,'.' "..., Schedule A ALL THAT CERTAIN tract ofland with the improvements thereon erected situate in North Middleton Township, County of Cumberland and Commonwealth of Pennsylvania, bounded and described as follows: BEING Lot No.7, on Plan No.7 of Noll Manor as recorded in the Office of the Recorder of Deeds for Cumberland County, in Plan Book 23, Page 119, containing 90 feet along Chester Street, having a /' depth along the West along Lot No.8 of 133.65 feet, having a width in the rear along the North of /' 102,89 feet and having a depth along the East along Lot NO.6 of 125.49 feet KNOWN AND NUMBERED AS 149 Chester Street, Carlisle, Pennsylvania BEING Tax Parcel No. 29-16-1096-020 .....".A -~.. '. r ':"";,1f'}, irk' ;'~iffl;:li;0'.:'j;TI'i:r0!:IT'];~f:',f0~'rn:DW~f'~1~;~Bl"1\~'~;'f;~:~~;.i'{K'i;W;~1;'0~W~/:i:i![,':~Jt\,f~:~~;~,..~~\\;~~I~~!i:~\!~,.iII~r~~[:\8m~\~~f'f\~:;?]\0:~~~;:~)j:;:i"i ,_.. .:.:;, ._ ..,. .>.c-'.:' '. ..- ," VERJFICATION AND NOW Louis P. Vitti verifies that the statements made in this Complaint are true and correct to the best of his knowledge, information and belief. I understand that false statements herein are made subject to the penalties of 18 Pa.C.S. 4904, relating to unsworn falsification to authorities. By virtue of the fact that the Plaintiff is outside the jurisdiction of the court and the verification cannot be obtained within the time allowed for the filing of this pleading, the pleading is submitted by counsel having sufficient knowledge, information and belief based upon the information provided him by the Plaintiff. iv)v itti i / \-...-/ Dated: March 9, 2004 7V (J ;0. ~ 't 0 ~ ~ C> ~ ~ -) ..c:: 0{) ~ -.J VJ ~ (j ~~ c-:~ .,.L- C) t -" ___I CI) 00-' I,:<T} ;>q , '<:~J , C) -,-, -'"I -,-J w C) SHERIFF'S RETURN - NOT SERVED CASE NO: 2004-01063 P COMMONWEALTH OF PENNSYLVANIA COUNTY OF CUMBERLAND JAMES B NUTTER & COMPANY VS EWIDEH JEHAD A ET AL R. Thomas Kline , Sheriff , who being duly sworn according to law, says, that he made a diligent search and inquiry for the within named DEFENDANT , to wit: EWIDEH NIVERTITI but was unable to locate Her in his bailiwick. He therefore returns the COMPLAINT - MORT FORE NOT SERVED , as to the within named DEFENDANT , EWIDEH NIVERTITI 149 CHESTER STREET CARLISLE, PA 17013 IT APPEARS AS THOUGH SOMEONE IS LIVING THERE ALTHOUGH NO ONE WOULD ANSWER THE DOOR. Sheriff's Costs: Docketing Service Affidavit Surcharge 6.00 3.45 .00 10.00 .00 19.45 So answers: , -" .. .--- /.." ..-""':::..,:::::::::.=-> ~~~?~...._.... Sheriff of Cumberland County LOUIS VITTI 04/01/2004 Sworn and subscribed to before me this /;;L~ day of ~ ~*. (). nuu,-,- 114 Prothonotary SHERIFF'S RETURN - REGULAR CASE NO: 2004-01063 P COMMONWEALTH OF PENNSYLVANIA: COUNTY OF CUMBERLAND JAMES B NUTTER & COMPANY VS EWIDEH JEHAD A ET AL ROBERT BITNER , Sheriff or Deputy Sheriff of Cumberland County, Pennsylvania, who being duly sworn according to law, says, the within COMPLAINT - MORT FORE was served upon EWIDEH JEHAD A the DEFENDANT , at 2140:00 HOURS, on the 31st day of March , 2004 at CUMBERLAND COUNTY PRISON 1101 CLAREMONT ROAD CARLISLE, PA 17013 by handing to JEHAD A EWIDEH a true and attested copy of COMPLAINT - MORT FORE together with and at the same time directing His attention to the contents thereof. Sheriff's Costs: Docketing Service Affidavit Surcharge So Answers: 18.00 6.90 .00 10.00 .00 34.90 ;r'~~/~ R. Thomas Kline ' 04/01/2004 LOUIS VITTI day of By~~~~~:lM.vc. ' T~puty Sheriff Sworn and Subscribed to before , a. me this /.1- qQA..) ;).Dv 'f . A. D. C i"t-<-- r;: ~ ~ ~ r -jt;rothonotary I -/ I IN THE COURT OF COMMON PLEAS OF CUMBERLAND COUNTY, PENNSYLVANIA JAMES B. NUTTER & COMPANY, CNIL DIVISION Plaintiff, NO. 04-1063 CNIL TERM vs. MOTION FOR SPECIAL SERVICE JEHAD A. EWIDEH and NNERTITI EWIDEH, Defendants. Code - MORTGAGE FORECLOSURE Filed on behalf of Plaintiff Counsel of record for this party: Louis P. Vitti, Esquire PA J.D. #3810 Supreme Court #01072 Louis P. Vitti & Assoc., P.e. 916 Fifth Avenue Pittsburgh, PA 15219 412-281-1725 IN THE COURT OF COMMON PLEAS OF CUMBERLAND COUNTY, PENNSYLVANIA CIVIL DIVISION NOTICE TO: Nivertiti Ewideh 149 Chester Street Carlisle, P A 17013 Take notice that the within Motion for Special Service pursuant to Rule 430 of the Pennsylvania Rules of Civil Procedure will be presented before the Motions Judge, Cumberland County, Pennsylvania, as unopposed unless a responsive pleading is filed. LOUIS P. VITTI & ASSOC., P.e. BY: v~ CERTIFICATION I hereby certify that a true and correct copy of the within Motion was mailed to the Defendant at the above address on the 23rd day of April, 2004. BY: (;;v ou . Vitti, Esquire orney for Plaintiff IN THE COURT OF COMMON PLEAS OF CUMBERLAND COUNTY, PENNSYLVANIA CIVIL DIVISION JAMES B. NUTTER & COMPANY Plaintiff, Defendants. ) ) No. 04-1063 CIVIL TERM ) ) ) ) ) vs. JEHAD EWIDEH and NIVERTITI EWIDEH MOTION FOR SPECIAL SERVICE PURSUANT TO RULE 430 AND THE PENNSYL VANIA RULES OF CIVIL PROCEDURE 400, ET SEQ. NOW comes the Plaintiff by and through their attorneys, Louis P. Vitti & Associates, P.C. and Louis P. Vitti, Esquire, and files this motion requesting this Honorable Court permit service pursuant to Pennsylvania Rules of Civil Procedure 400, et seq., Imd particularly Rule 430 whereof the following is a statement: I. Plaintiff did file a Complaint at the above-captioned number in mortgage foreclosure. 2. The property address is 149 Chester Street, Carlisle, PA 17013, and is the subject of this action. 3. The Sheriff did attempt to make service, but has been unable to serve the Defendant Nivertiti Ewideh. See Exhibit "A". 4. A postal verification was ordered and the postal authority indicated that the Defendant receives mail at 149 Chester Street, Carlisle PA 17013. See Exhibit "B". 5. Efforts to effectuate service by the Sheriff have met without success and service has been frustrated requiring presentation of this Motion. WHEREFORE, Plaintiff prays this Honorable Court enter an Order permitting service by ordinary mail to Defendant's last known address and also by pOosting the property by the Sheriff. Respectfully submitted, BY: LOUIS P. VITTI & ASSOC., P.C. "iV~P; omey D)r Plaintiff PA ill 01072 916 Fifth Avenue Pittsburgh, PA 15219 (412) 281-1725 ----- IN THE COURT OF COMMON PLEAS OF CUMBERLAND COUNTY, PENNSYLVANIA CIVIL DIVISION JAMES B. NUTTER & COMPANY Plaintiff, Defendants. ) ) No. 04-1063 CIVIL TERM ) ) ) ) ) vs. JEHAD A. EWIDEH and NlVERTITI EWIDEH INVESTIGATION AFFIDAVIT PURSllANI.. TO PA.R.C.P. NO. 430 Louis P. Vitti & Associates, P.C. sets forth the following: 1. Affiant and/or its agents have conducted an investigation to determine the whereabouts of the Defendant, NIVERTITI EWIDEH, by making inquiries of or examining the following: a. Local telephone directory assistance in the Cumberland County area has a non-published telephone number per customer's request for Nivertiti Ewideh at 149 Chester Street, Carlisle, PA; b. No information was available for Voter's Registration; c. No information was able to be ascertained from the Department of Transportation; d. Local tax records show mailing address for Defendant is accurate; and 2. Notwithstanding the investigation as set forth in this Affidavit, Affiant and/or its agents have not been able to locate the whereabouts of said Defendant as shown above and by the attached exhibits. We verify that the statements made in this Affidavit are tme and correct to the best of our knowledge, information and belief. We understand that false statements are made subject to the penalties of 18 Pa.C.S.A. Section 4904, relating to unswom falsification to authorities. ICIATES, P.C. Kathleen arr Legal As stant to Louis P. Vitti 916 Fift Avenue Pittsburgh, PA 15219 '#lh BY: Commonwealth of Pennsylvania SS. County of Allegheny On this the cE)!'d. day o~ ' 2004, before me the undersigned officer, personally appeared the Affiant, kri to me (or satisfactorily proven) to be the person whose name is subscribed to the within instrument and acknowledged that he executed the same for the purposes therein contained. In Witness Whereof, I hereunto set my hand and official seal. C~~~JU~L NOTARIAL SEAL P\dlIII AntIIA. (;oIIZIItI.~~ ClIlYalt.="~AuO.17.2004 My Ca/l.m CASE NO:' 2004-01063 COMMONWEALTH OF PENNSYLVANIA COUNTY OF CUMBERLAND SHERIFF'S RETURN - NOT SERVED JAMES B NUTTER & COMPANY VB EWIDEH JEHAD A ET AL R. Thomas Kline , Sheriff , who being duly sworn according to law, says, that he made a diligent search and inquiry for the within named DEFENDANT , to wit: EWIDEH NIVERTITI unable to locate ~ in his bailiwick. He therefore returns the but was COMPLAINT - MORT FORE : NOT SERVED , as to the within named DEFENDANT , EWIDEH NIVERTITI 149 CHESTER STREET CARLISLE, PA 17013 IT APPEARS AS THOUGH SOMEONE IS LIVING THERE ALTHOUGH NO ONE WOULD ANSWER THE DOOR. Sheriff's Costs: Docketing Service Affidavit SurCharge 6.00 3.45 .00 10.00 .00 19.45 So answers: / ____ :=-9W:=:=-;:'--~::.::'-'--'=-,~,:,::---":o.;> ( R. Thomas Kl~e Sheriff of Cumberland County LOUIS VITTI 04/01/2004 Sworn and subscribed to before me this day of A.D. EXHIBIV II.A-. Prothonotary : -4 LOUIS P. VITTI & ASSOCIATE~i'",C. 916 Fifth Avenue Pittsburgh, PA 15219 PHONE: (412) 281-1725 FAX: (412) 281-3810 DATE: MONDAY. APRIL 12, 2004 POSTMASTER OF CARLISLE PA 17013 Request for Change of Address or Bo)[holder Information Needed for Service of Legal Process Please furnish the new address or the name and street address (if a boxholder) for the following: Name: Address: NIVERTITI EWIDEH 149 CHESTER STREET. CARLISLE. PA 17013 NOTE: The name and last known address are required for change of address information. The name, if known. and post office box address are required for boxholder information. The following information is provided in accordance with 39 CFR 265.6(d)(6)(ii). There is no fee for providing boxholder information. The fee for grovidina cha!1oe of address infcrmation is waived in accordance with 39 CFR 265.6IdI/1\ and 12\ and corresDonclina Administrative SUDDort Manual 352.44a and b. 1. Capacity of requester (e.g.. process server, attorney. party representing himself): Attornev 2. Statute or reguiation that empowers me to serve process (not required when requester is an attorney or a party acting pro sa. except a corporation acting pro se must cite statute): t!I8 3. The names of all known parties to the litigation: JAMES B. NUTTER ~~ COMPANY 4. The court in which the case has been or will be heard: CUMBERLAND COUNTY. PA 5. The docket or other identifying number if one has been issued: t!.Q; 04-1063 CIVIL TERM 6. The capacity in which this Individual is to be served (e.g. defendant or witness): Defendant WARNING THE SUBMISSION OF FALSE INFORMATION TO OBTAIN AND USE CHANGE OF ADDRESS INFORMATION OR BOXHOLDER INFORMATION FOR ANY PURPOSE OTHER THAN THE SERVICE OF LEGAL PROCESS IN CONNECTION WITH ACTUAL OR PROSPECTIVE LITIGATION COULD RESULT IN CRIMINAL PENALTIES INCLUDING A FINE OF UP TO $10,000 OR IMPRISONMENT OR (2) TO AVOID PAYMENT OF THE FEE FOR CHANGE OF ADDRESS INFORMATION OF NOT MORE THAN 5 YEARS, OR BOTH (TITLE 18 U.S.C. SECTION 1001). I certify that the above information is true and that the address information is needed and will be used soiely for service of legal process in connection with actual or prospective litigation. Louis FOR POST OFFICE USE ONLY ADDRESS or BOXHOLDER'S POSTMARK _ No change of address order on file. NEW _ Not known at address given. No such address. ~ Good as Addressed EXHIBIT II ~ NAME AND STREET ADDRESS ,.<~,.qp ."" r- . \ (0 I, \~~~ ~\")C!V':) ~ , Q.. 'f' _ Moved, left no forwarding address. " .. VERIFICATION AND NOW Louis P. Vitti verifies that the statements made in this Motion are true and correct to the best of his knowledge, information and belief. I understand that false statements herein are made subject to the penalties of 18 Pa.C.S. 4904, relating to unswom falsification to authorities. By virtue of the fact that the Plaintiff is outside the jurisdiction of the Court and the verification cannot be obtained within the time allowed for the filing of this pleading, the pleading is submitted by counsel having sufficient knowledge, infomlation and belief based upon the information provided him by the Plaintiff. J~ Dated: April 23, 2004 '. (') ...... c: = ~ <'"' c;> -0''- ..c- p_.gJ :1>0 :r _J" , --0 ~'n ;-.^'::. ::0 m~ ci)~ N ~ ~..:. (1\ ,<0 J:; C) --0 ~~ ~'(j ::!: :t."'C: ~ ~ ~ 0 ., ~ , APR 2 8 lO041\) ,,,. IN THE COURT OF COMMON PLEAS OF CUMBERLAND COUNTY, PENNSYLVANIA CIVIL DIVISION vs. ) ) NO. 04-1063 CIVIL TERM ) ) ) ) ) ) J. QRDER OF COURT NOW, this L day of Plaintiff, JAMES B. NUTTER & COMPANY JEHAD A. EWIDEH and NIVERTITI EWIDEH Defendants. that the Sheriffhas been frustrated in service of cess, it is Ordered, Adjudged and Decreed that , 2004, it appearing to the Court service of the Complaint and all subsequent documents upon all Defendants be accomplished by ordinary mail to Defendant'slast known address and by posting the property by the Sheriff in order to effect compliance with Rule 400, et seq. and Rule 3129.1, et seq. BY THE COURT: J. >- ~ wQ O.L~- u:& ~~ ~LU O:jE OJ.. o ~...P Kl ~i, t\; ~ r & 1. --t ~ co o ~ ::;J.<t: 02; r..J~ ,.,>. ~::;!:J ~;'(0 L::~~= I"U!'J :..:JJcL """. :5 o .. ...::r ::IC 0- M I >- -< ::IC -"'" = = c-.. IN THE COURT OF COMMON PLEAS OF CUMBERLAND COUNTY, PENNSYLVANIA JAMES B. NUTTER & COMPANY, CIVIL DIVISION Plaintiff, NO. 04-1063 CIVIL TERM vs. MOTION FOR SPECIAL SERVICE JEHAD A. EWIDEH and NIVERTITI EWIDEH, Defendants. Code - MORTGAGE FORECLOSURE Filed on behalf of Plaintiff Counsel of record for this party: Louis P. Vitti, Esquire PA J.D. #3810 Supreme Court #01072 Louis P. Vitti & Assoc., P.e. 916 Fifth Avenue Pittsburgh, PA 15219 412-281-1725 IN THE COURT OF COMMON PLEAS OF CUMBERLAND COUNTY, PENNSYLVANIA CIVIL DIVISION NOTICE TO: Nivertiti Ewideh 149 Chester Street Carlisle, PA 17013 Take notice that the within Motion for Special Service pursuant to Rule 430 of the Pennsylvania Rules of Civil Procedure will be presented before the Motions Judge, Cumberland County, Pennsylvania, as unopposed unless a responsive pleading is filed. LOUIS P. VITTI & ASSOC., P.C'. BY: CERTIFICATION I hereby certif'y that a true and correct copy of the within Motion was mailed to the Defendant at the above address on the 23rd day of April, 2004. BY: tv. ou . Vitti, Esquire orney for Plaintiff IN THE COURT OF COMMON PLEAS OF CUMBERLAND COUNTY, PENNSYLVANIA CNIL DNISION JAMES B. NUTTER & COMPANY Plaintiff, Defendants. ) ) No. 04-1063 CNIL TERM ) ) ) ) ) vs. JEHAD EWIDEH and NNERTITI EWIDEH MOTION FOR SPECIAL SERVICE PURSUANT TO RULE 430 AND THE PENNSYL VANIA RULES OF CIVIL PROCEDURE 400, ET SEQ. NOW comes the Plaintiff by and through their attorneys, Louis P. Vitti & Associates, P.C. and Louis P. Vitti, Esquire, and files this motion requesting this Honorable Court permit service pursuant to Pennsylvania Rules of Civil Procedure 400, et seq., and particularly Rule 430 whereof the following is a statement: I. Plaintiff did file a Complaint at the above-captioned number in mortgage foreclosure. 2. The property address is 149 Chester Street, Carlisle, PA 17013, and is the subject of this action. 3. The Sheriff did attempt to make service, but has been unable to serve the Defendant Nivertiti Ewideh. See Exhibit "A". 4. A postal verification was ordered and the postal authority indicated that the Defendant receives mail at 149 Chester Street, Carlisle PA 17013. See Exhibit "B". 5. Efforts to effectuate service by the Sheriff have met without success and service has been frustrated requiring presentation ofthis Motion. WHEREFORE, Plaintiff prays this Honorable Court enter an Order permitting service by ordinary mail to Defendant's last known address and also by posting the property by the Sheriff. Respectfully submitted, LOUIS P. VITTI & ASSOC., P.C. BY: oui . Vi ti, Esquire orney for Plaintiff PA ill 01072 916 Fifth Avenue Pittsburgh, PA 15219 (412) 281-1725 IN THE COURT OF COMMON PLEAS OF CUMBERLAND COUNTY, PENNSYLVANIA CIVIL DIVISION JAMES B. NUTTER & COMPANY Plaintiff, Defendants. ) ) No. 04-1063 CIVIL TERM ) ) ) ) ) vs. JEHAD A. EWIDEH and NNERTITI EWIDEH INVESTIGATION AFFIDAVIT PURSUANT TO PA.R.C.P. NO. 430 Louis P. Vitti & Associates, P.C. sets forth the following: 1. Affiant and/or its agents have conducted an investigation to determine the whereabouts of the Defendant, NIVERTITI EWIDEH, by making inquiries of or examining the following: a. Local telephone directory assistance in the Cumberland County area has a non-published telephone number per customer's request for Nivertiti Ewideh at 149 Chester Street, Carlisle, PA; b. No information was available for Voter's Registration; c. No information was able to be ascertained from the Department of Transportation; d. Local tax records show mailing address for Defendant is accurate; and 2. Notwithstanding the investigation as set forth in this Affidavit, Affiant and/or its agents have not been able to locate the whereabouts of said Defendant as shown above and by the attached exhibits. We verify that the statements made in this Affidavit are true and correct to the best of our knowledge, information and belief. We understand that false statements are made subject to the penalties of 18 Pa.C.S.A. Section 4904, relating to unswom falsification to authorities. LOUIS P. VITTI & AS BY: Kathleen arr Legal As stant to Louis P. Vitti 916 Fift Avenue Pittsburgh, P A 15219 Commonwealth of Pennsylvania SS. County of Allegheny On this the d:)rct. day o~ ' 2004, before me the undersigned officer, personally appeared the Affiant, kri to me (or satisfactorily proven) to be the person whose name is subscribed to the within instrument and acknowledged that he executed the same for the purposes therein contained. In Witness Whereof, I hereunto set my hand and official seal. ~"_._., V:' /I~ OT~Ufl:c NOTARIAL SeAL PuIlllO Ann M. 6OI\ZIIII.~ AI\8QhIIIf , :=-~AuD.17.2004 CASE NO:' 2004-01063 COMMONWEALTH OF PENNSYLVANIA COUNTY OF CUMBERLAND SHERIFF'S RETURN - NOT SERVED JAMES B NUTTER & COMPANY VS EWIDEH JEHAD A ET AL R. Thomas Kline , Sheriff , who being duly sworn the within named DEFENDANT according to law, says, that he made a diligent search and inquiry for EWIDEH NIVERTITI , to wit: unable to locate ~ in his bailiwick. He therefore returns the but was COMPLAINT - MORT FORE = the within named DEFENDANT NOT SERVED , as to , EWIDEH NIVERTITI 149 CHESTER STREET CARLISLE, PA 17013 IT APPEARS AS THOUGH SOMEONE IS LIVING THERE ALTHOUGH NO ONE WOULD ANSWER THE DOOR. Sheriff's Costs: Docketing Service Affidavit SurCharge 6.00 3.45 .00 10.00 .00 19.45 So answers: . .. __.__ ;...~.r::~~:::-:-::-::::"":::_..._....,:.> ( R. Thomas KI~e Sheriff of Cumberland County LOUIS VITTI 04/01/2004 Sworn and subscribed to before me this day of A.D. EXHIBIT"..4- .. Prothonotary ./ ~ LOUIS P. VITTI & ASSOCIATE~;'",C. 916 Fifth Avenue Pittsburgh, PA 15219 PHONE: (4U) 281-1725 FAX: (4U) 281-3810 DATE; MONDAY, APRIL 12,2004 POSTMASTER OF CARLISLE PA 17013 Request for Change of Address or Boxholder Information Needed for Service of Legal Process Please furnish the new address or the name and street address (if a boxholder) for the following: Name: Address; NIVERTITI EWIDEH 149 CHESTER STREET. CARLISLE. PA 17013 NOTE: The name and last known address are required for change of address information. The name, if known, and post office box address are required for boxholder information. The following information is provided in accordance with 39 CFR 265.6(d)(6)(ii). There is no fee for providing boxholder information. The fee for wovi ina cha!'loe of address infcrmiiti_n is waived in accordance with 39 CFR 265.61d1l11 and 121 and corresDondina Administrative SUDDort Manual 352.44a and b. 1. Capacity of requester (e.g., process server, attorney. party representing himself): Attornev 2. Statute or reguiation that empowers me to serve process (not required when requester is an attorney or a party acting pro se - except a corporation acting pro se must cite statute): N/A 3. The names of all known parties to the litigation: JAMES B. NUTTER & COMPANY 4. The court in which the case has been or will be heard: CUMBERLAND COUNTY. PA 5. The docket or other identifying number if one has been issued: NO: 04-1063 CIVIL TERM 6. The capacity in which this individual is to be served (e.g. defendant or witness): Defendant WARNING THE SUBMISSION OF FALSE INFORMATION TO OBTAIN AND USE CHANGE OF ADDRESS INFORMATION OR BOXHOLDER INFORMATION FOR ANY PURPOSE OTHER THAN THE SERVICE OF LEGAL PROCESS IN CONNECTION WITH ACTUAL OR PROSPECTIVE LITIGATION COULD RESULT IN CRIMINAL PENAL TIES INCLUDING A FINE OF UP TO $10,000 OR IMPRISONMENT OR (2) TO AVOID PAYMENT OF THE FEE FOR CHANGE OF ADDRESS INFORMATION OF NOT MORE THAN 5 YEARS, OR BOTH (TITLE 18 U.S.C. SECTION 1001). I certify that the above information is true and that the address information is needed and will be used solely for service of legal process in connection with actual or prospective litigation. Louis . Vi' squire 916 Fi venue Pittsburgh. PA 15219 FOR POST OFFICE USE ONLY ADDRESS or BOXHOLDER'S POSTMARK _ No change of address order on file. NEW _ Not known at address given. NAME AND STREET ADDRESS /~,~~ ~ /'",,:-'/ ....."\ fa , f_ 0- - 'n _ Moved, left no forwarding address. _ No such address. ~ Good as Addressed EXHIBIT W YERIFICA nON AND NOW Louis P. Vitti verifies that the statements made in this Motion are true and correct to the best of his knowledge, information and belief I understand that false statements herein are made subject to the penalties of 18 Pa.C.S. 4904, relating to unswom falsification to authorities. By virtue of the fact that the Plaintiff is outside the jurisdiction of the Court and the verification cannot be obtained within the time allowed for the filing ofthis pleading, the pleading is submitted by counsel having sufficient knowledge, information and belief based upon the information provided him by the Plaintiff. Dated: April 23, 2004 ..... ~ () = c "'" ...- ~ <'" >- -JfD "'\:) lTTfl; :::Q ~i~;1 N ~~ "....,. (I; ;?,: en ~6 -u 15 J;: (") 3: z~ ~~.() 0 :P'c <:! -'-I '7 ~ ~ a ~ ;jJj IN THE COURT OF COMMON PLEAS OF CUMBERLAND COUNTY, PENNSYL VANIA JAMES B. NUTTER & COMPANY CNIL DNISION NO. 04-1063 CNIL TERM Plaintiff, PRAECIPE TO REINSTATE COMPLAINT IN MORTGAGE FORECI,OSURE Ys. JEHAD A. EWIDEH and NNERTITI EWIDEH Code - Mortgage Foreclosure Filed on behalf of Plaintiff Defendants. Counsel of record for this party: Louis P. Vitti, Esquire PA I.D. #3810 Supreme Court #01072 Louis P. Vitti & Assoc., P.C. 916 Fifth Avenue Pittsburgh, PA 15219 (412) 281-1725 IN THE COURT OF COMMON PLEAS OF CUMBERLAND COUNTY, PENNSYLVANIA CNIL DNISION JAMES B. NUTTER & COMPANY ) Plaintiff, ) vs. ) ) JEHAD A. EWIDEH and NNERTITI EWIDEH ) ) Defendants. ) PRAECIPE TO REI~TATE COMPLAINT TO THE PROTHONOTARY OF CUMBERLAND COUNTY: Please reinstate the complaint in the above-captioned caSf'. Respectfully submitted, LOUIS P. VITTI SO BY: DATE: May 10, 2004 . (') ......, c-- = 0 = .r- -n --I :.>'" I:!J -< rn-~ ,. -om -.J :JJO Oc (" ::::)'~ ::;:1-) c-=s;d , -'- -~.. l. ) c. 9 (jr-n ~ :=r;~ -<: en ~.o CD ..< SHERIFF'S RETURN - REGULAR CASE NO: 2004-01063 P COMMONWEALTH OF PENNSYLVANIA: COUNTY OF CUMBERLAND JAMES B NUTTER & COMPANY VS EWIDEH JEHAD A ET AL VALERIE WEARY , Sheriff or Deputy Sheriff of Cumberland County,Pennsylvania, who being duly sworn according to law, says, the within COMPLAINT - MORT FORE was served upon EWIDEH NIVERTITI the DEFENDANT , at 2023:00 HOURS, on the 17th day of May , 2004 at 149 CHESTER STREET CARLISLE, PA 17013 by handing to POSTED PROPERTY AT 149 CHESTER ST CARLISLE a true and attested copy of COMPLAINT - MORT FORE together with and at the same time directing Her attention to the contents thereof. Sheriff's Costs: Docketing Service Posting Surcharge So Answers: 18.00 3.45 6.00 10.00 .00 37.45 r~~ R. Thomas Kline 05/18/2004 LOUIS VITTI Sworn and Subscribed to before By: ~:PU~ -- me this jqh;:.. day of ~ J /}{;uLf A.D. CI . I _ /J !nJt7,.... ~ j.;J;' " P~onotary j ~~ IN THE COURT OF COMMON PLEAS OF CUMBERLAND COUNTY, PENNSYLVANIA JAMES B. NUTTER & COMPANY, CIVIL DIVISION NO. 04-1063 CIVIL TERM Plaintiff, vs. CERTIFICATION OF MAILING JEHAD A. EWIDEH and NIVERTITI EWIDEH Code - MOItgage Foreclosure Defendants. Filed on behalf of Plaintiff Counsel of record for this party: Louis P. Vitti, Esquire PA J.D. #3810 Supreme Court #01072 Louis P. Vitti & Assoc., P.C. 916 Fifth Avenue Pittsburgh, PA 15219 (412) 281-1725 IN THE COURT OF COMMON PLEAS OF CUMBERLAND COUNTY, PENNSYLVANIA CNIL DNISION JAMES B. NUTTER & COMPANY Plaintiff, Defendants. ) ) No. 04-1063 CNIL TERM ) ) ) ) ) vs. JEHAD A. EWIDEH and NNERTITI EWIDEH .~ I, Louis P. Vitti, Esquire, do hereby certify that service ofthe Complaint was accomplished by ordinary mail on the Defendant(s) NNERTITI EWIDEH, on May 20,2004, as per the Order of Court dated May 3, 2004. A copy of said certificate of mailing is attached hereto as Exhibit "A". Swom to and subscribed before me, this 21 st ub ic NOTAR EAL Ann M. Gonzales. Notary MIlO City of PIttsburgh, CoImIy of AI1eghsny My Commission expires Aug. 17. 2004 U.S. POSTAL SERVICE CERT FI F MA UN ~ff~~~:rh:~es~~:~a~~~ MAY BE USED FOR DOMESTIC AND, J~~c,,:': "-~>ib.lilllt. Inquire of PROVIOE FOR INSURANCE-POSTMA FG h iJ . '".''' '~;'''''~"'!'' '-~Ol...,f, 'm ounent :..:-: (r \'T::~',r".,~,l~,~ fee. i:: Received From: n ....-I'20n" 'I.....-..."'..'.".;~:'? I,' ,".. ./.... ....... r,,.. ~..~ _,. ,":__", .',_ .,_. .: ~. . : '" Louis P. Vitti Associ~~~s";~1 '":: 916 Fifth Avenue,PI\/ . ",..','te:':U:S"'" ':;: riLLoLu,.L'::!l.L, PA 1:;213 [!:>D:-: "','j ': One piece of Ordinary mail addressed to: Nivertiti Ewideh 149 Chester St. Car1ia1e, FA 17e1J ~-~ ~....... PS Form 3817. Mar. 1989 kc #53111 [Xhi fJd \' A (( IN THE COURT OF COMMON PLEAS OF CUMBERLAND COlJNTY, PENNSYLVANIA JAMES B. NUTTER & COMPANY CIVIL DNISION Plaintiff, NO. 04-1063 CIVIL TERM vs. PRAECIPE FOR DEFAULT JUDGMENT, CERTIFICATION OF MAILING AND AFFIDAVIT OF NON- MILITARY SERVICE JEHAD A EWIDEH NIRERTlTl EWIDEH Defendants. Code MORTGAGE FORECLOSURE Filed on behalf of Plaintiff Counsel of record for this party: Louis P. Vitti, Esquire PA 1.0. #3810 Supreme Court #01072 Louis P. Vitti & Assoc., P.e. 916 Fifth Avenue Pittsburgh, PA 15219 (412) 281-1725 IN THE COURT OF COMMON PLEAS OF CUMBERLAND COUNTY, PENNSYLVANIA CNIL DNISION JAMES B. NUTTER & COMPANY, Plainitff, ) ) vs. ) JEHAD A EWIDEH and NIVERTITI EWIDEH, ) Defendants ) NO. 04-1063 CNIL TERM PRAECIPE FO.RDEFAULT JUDGMENT AND ASSESSMENT OF DAMAGES TO PROTHONOTARY OF CUMBERLAND COUNTY Enter judgment in Default of an Answer in the amount of$114,468.37 ,in favor of the James B. Nutter & Company, Plaintiff in the above-captioned action, against the Defendants, Jehad A. Ewideh and Nivertiti Ewideh and assess Plaintiffs damages as follows and/or as calculated in the Complaint: Unpaid Principal Balance Interest from 06/01/03-6/22/04 (Plus $20.0467 per day after 06/22/04) $97,560.51 7,758.06 Late charges (Plus $40.20 per month from 3/9/04-12/8/04 $361.80) 320.56 Attorney's fee 4,878.03 Escrow Deficit (Plus any additional charges that may be incurred by the Plaintiff and transmitted to the sheriff as charges on the writ prior to the date of the sheriffs sale) 3.951.21 Total Amount Due $114,468.37 The real estate, which is the subject matter of the Complaint, is situate in North Middletown Twp, CtyofCumberland, CmwlthofPA HET 149 Chester Street, Carlisle, PA 17013, Parcel# 29-16-1096-020, ~uWQ Vdh L P. Vitti, Esquire torney for the Plaintiff IN THE COURT OF COMMON PLEAS OF CUMBERLAND COUNTY, PENNSYLVANIA CIVIL DIVISION JAMES B. NUTTER & COMPANY, Plainitff, ) ) vs. ) JEHAD A. EWIDEH and NIVERTITI EWIDEH, ) Defendants, ) NO. 04-1063 CIVIL TERM CERTIFICATION OF MAILJNG I, Louis P. Vitti, do hereby certify that a Notice ofIntention to Take Judgment was mailed to the Defendant(s), in the above-captioned case on June 10,2004, giving ten (10) day notice that judgment would be entered should no action be taken. LOUlS P. VITTI & ASSOCIATES, PC u ~ '. At ey for Plaintiff SWORN to and subscribed before me this 22nd day of June, 2004, ~~cYa(tJLJ _ Nnhry. .lic l 'lota',i;i Seal I I ~ Sli8rry!::, House, Notary Public r-l8asan~ h!ilS 8.?ro, Allegheny County My CO~:~~'__::{pir~s January 28,2007 Member, Pen":,y-inni3 A';~:,,:,-.::i:)t;cr' ,;[ Not3ries IN THE COURT OF COMMON PLEAS OF CUMBERLAND COUNTY, PENNSYLVANIA CIVIL DIVISION JAMES B. NUTTER & COMPANY, ) Plaintiff, ) vs. ) illHAD A. EWIDEH and NIVERTITI EWIDEH, ) Defendants, ) NO 01-1063 CIVIL TERM IMPORTANT NOTICE TO: Nivertiti Ewideh 149 Chester Street Carlisle, PA I7013 Iehad Ewideh Cumberland County Prison 1101 Claremont Rd Carlisle, PA 17013 Date of Notice: June 10, 2004 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 ACI' WITHIN TEN (10) DAYS FROM THE DATE OF THIS NOTICE, A JUDGMENT MAYBE ENTERED AGAINST YOU WITHOUT A HEARING AND YOU MAY LOSE YOUR PROPERTY OR OTHER IMPORTANT RIGHTS. YOU SHOULD TAKE THIS NOTICE TO YOUR LAWYER AT ONCE. IF YOU DO NOT HAVE A LAWYER OR CANNOT AFFORD ONE, GO TO OR TELEPHONE THE FOLLOWING . OFFICE SET FORTH BELOW TO FIND OUT WHERE YOU CAN GET LEGAL HELP: IF YOU CANNOT AFFORD TO HIRE A LAWYER, THIS OFFICE MAYBE ABLE TO PROVIDE YOU WITH INFORMATION ON AGENCIES THAT MAY OFFER LEGAL SERVICES TO ELIGIBLE PERSONS AT A REDUCED FEE OR NO FEE. CUMBERLAND COUNTY BAR ASSOCIA nON 2 LIBERTY AVE CARLISLE, PA 17013 717-249-3166 ~o IIT~CltJ~c:. (J.)M'i..~ s . Vitti, Esquire Attorney for Plaintiff 916 Fifth Avenue Pittsburgh, PA 15219 ** THE DEBT COLLECTOR IS A TI'EMPTING TO COLLECT A DEBT AND ANY INFORMATION OBTAINED WILL BE USED FOR THAT PURPOSE.** BY: IN THE COURT OF COMMON PLEAS OF CUMBERLAND COUNTY, PENNSYLVANIA CIVIL DIVISION COMMONWEALTH OF PENNSYLVANIA, SS: COUNTY OF ALLEGHENY BEFORE me, the undersigned authority, personally appeared Louis P. Vitti, Esquire, who, being duly sworn according to law, deposes and says that he is advised and believes that DEFENDANT(S)'is/are not presently in the active military service of the United States of America and not members of the Anny of the United States, United States Navy, the Marine Corps, or the Coast Guard, and not officers of the Public Health Service detailed by proper authority for duty with the Anny or Navy; nor engaged in any active military service or duty with any military or naval units covered by the Soldiers and Sailors Civil Relief Act of 1940 and designated therein as military service, and to the best of this affiant's knowledge is/are not enlisted in military service covered by said act, and that the averments herein set forth, insofar as they are within his knowledge, are correct, and true; and insofar as they are based on information received from others, are true and correct as he verily believes. This Affidavit is made under the provisions of the Soldiers and Sailors Civil Relief Act of 1940, SWORN to and subscribed j_db - before me this 22nd day of June, 2004, =(J-~~~ " . r<(,ld~",:/ '>'\:11 Jh()Cr/ l. dCI';c:. j\!niary F'ue.::': , ;-"I~,:'iSanl j,'iiis ~1'-'''',''\liL-'Qhenv Co~!nt'l Vly Corr:tY1:'<'~, ':":)!i;::'~i ,JanU81Y 28.~!n(ri -~-,.--:----.+--~,- y..:':r'r":c....::. '. "',::.:..-,~Y:;'i,~,.. '-'! ",'cob,'''''''" c ^=> (:J ..lQ. ~1t-~ 6 ~ ~ ~ D ~ ~ ~ ~ 6"- ~ r- ~~ (> 1- , :--1 ,;1. '- IN THE COURT OF COMMON PLEAS OF CUMBERLAND COUNTY, PENNSYLVANIA JAMES B. NUTTER & COMPANY CIVIL DNISION Plaintiff, NO. 04-1063 CNIL TERM vs, PRAECIPE FOR WRIT OF EXECUTION AND AFFIDAVIT OF LAST KNOWN ADDRESS JEHAD A EWIDEH NIRERTITI EWIDEH Code MORTGAGE FORECLOSURE Defendants. Filed on behalf of Plaintiff Counsel of record for this party: Louis P. Vitti, Esquire PA I.D. #3810 Supreme Court #0 I 072 Louis p, Vitti & Assoc., P.e. 916 Fifth Avenue Pittsburgh, P A 15219 (412) 281-1725 IN THE COURT OF COMMON PLEAS OF CUMBERLAND COUNTY, PENNSYLVANIA CIVIL DIVISION JAMES B. NUTTER & COMPANY, Plainitff, ) ) ) JEHAD A. EWIDEH and NIVERTITI EWIDEH, ) Defendants. ) NO. 04-1063 CIVIL TERM vs. PRAECIPE FOR WRIT OF EXECUTION IN MORTGAGE FORECLOSURE TO PROTHONOTARY OF CUMBERLAND COUNTY Issue a Writ of Execution in favor of the Plaintiff and against the Defendant(s) in the above-captioned matter as follows: Amount Due $114,468.37 Interest 6/23/04-12/8/04 3.387.89 Total $117.856.26 The real estate, which is the subject matter of the Praecipe for Writ of Execution is situate Ill: North Middletown Twp, Cty of Cumberland, Cmwlth ofP A. HET 149 Chester Street, Carlisle, P A 17013, Parcel# 29-16-1096-020, / :f is P. Vitti, Esquire .Jttorney for Plaintiff IN 'ffiE COURT Of COI<M)N PLEAS Of CUMBERlAND COUNI'Y, PENNSYLVANIA .---- CIVIL DIVISION PRAECIPE ~R WRIT Of EXECUTION :aptian: Jo.m e5 6. \\.l u{kr c....(') Plc.intit'+ Confessed Judgment Other vs. File No. DIJ -IOfrl3 Mount Due .$llG\] L/&'X.37 Interest (.If}*" - )d/~/t1q I ~3;557. $9' Atty's Ccmn Costs J.e no.d t LU i c\~ Y\ <\ ~1'\j<,\~I'ti ["\.ulk\1 10 THE ProIHOroTARY OF TIlE SAID COURT: The undersigned hereby certifies that the below does not a.ri.se out of a retail. installlrent sale, OJntract, or account based on a confession of judgment, but if it does, it is based on the appropriate or:i.ginal proceeding filed pursuant to Act 7 of 1966 as arreoded; and for real property pursuant to Act 6 of 1974 as amended. Issue writ of execution in the above il'dtter to the Sheriff of C,urf\o:>rlan ~ County, for debt, interest and costs 'upon the following described property of the defendant(s) 5ee.. a.tlr1che.d \Q~\ ~\ \~Or't PRAECIPE FOR A'I'l'ACa1ENl' EX:EnJTICN Issue '<>Irit of attachrrent to the Sheriff of (\)(\\1:10(' lam County, for debt, interest and costs, as above, directing attacl'.rrent against the 'abc;ve-narred garnishee(s) for the following property (if real estate, supply six copies of the description; supply four' copies of lengthy personalty list) <.p,e..... R-rt At h ~ A \ ~ (' ~ . I..Y tl - and all other property of the defendant( s) in the possession, custody or control of the said garnishee ( s) . ( Indicate) Index this wri t agains t the garnishee( s) as a lis ~ens against real estate of the defendant(s) described in the attache ~biy-) .. DATE: [p IO~/oCf Signat: uA_YI Jk=; ?=int i'S P 01!-i /&J -5 I}L< f) lJ e ~. PI! J..~/q ~~~o~ey for: P/ciin-/-! Pi' ~de;:,.,or.e: Lj}~-dZ)' /Jas IV ~ f (t- S 7=>. +- ~ ~ 70 f') t-~ n ~ Ii'- ~ .t:::. ,.; t)-O "'CQ. ;<q,....... '"1 ~ (; () r-[;J I r ~ -iQ. ....:) ~ w - w..... (,., ~':-O!'t~:O~~ "Q ~ c c., ~ ~...oo () '-' CO Crt cr,O() I I I I I . :tJ , ~~ , "'.:::::: ::: +- ~ ~ .:. ~ ::. .:. .:.q.r- f-'"~ ".; " IN THE COURT OF COMMON PLEAS OF CUMBERLAND COUNTY, PENNSYLVANIA CIVIL DIVISION JAMES B. NUTTER & COMPANY, Plainitff, ) ) vs. ) JEHAD A. EWIDEH and NIVERTlTl EWlDEH, ) Defendants. ) NO. 04-1063 CIVIL TERM LEGAL DESCRIPTION All that certain tract ofland with the improvement thereon erected situate in North MIddleton Twonship, County of Cumberland and Commonwealth of Pennsylvania, bounded and descnbed as follows: Being Lot No. 7, on Plan No.7 of Noll Manor as recorded in the Office of the Recorder of Deeds Office for Cumberland County, in Plan Book 23, page 119, containing 90 feet along Chester Street, having a depth along the West along Lot No.8 of 133.65 feet, having a width in the rear along the North of 102.89 feet and having a depth along East along Lot No.6 of 125.49 feet. Having erected thereon a dwelling known as 149 Chester Street, Carlisle, P A 17013 Tax Parcel # 29-16-1096-020 Being the same premises which G. Travis Paules and Rickie L. Paules by their deed dated 11/28/2000 and recorded on 12/04/2000 in the Recorder of Deeds Office of Cumberland County, Pennsylvania, in Deed Book Volume 2335, page 543, granted and conveyed unto Jehad A. Ewideh WRIT OF EXECUTION and/or ATTACHMENT COMMONWEALTH OF PENNSYL VANIA) COUNTY OF CUMBERLAND) NO 04-1063 Civil CIVIL ACTION ~LAW TO THE SHERIFF OF CUMBERLAND COUNTY: To satisfy the debt, interest and costs due JAMES B. NUTTER & COMPANY, Plaintiff (s) From JEHAD A. EWIDEH AND NIVERTITI EWIDEH (1) You are direc!ed 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 deb! to or for the account of the defendant (s) and from delivering any property of the defendant (s) or otherwise disposing thereof; (3) Ifproperty of the defendant(s) not levied upon an subject to attachment is found in the possession of anyone other than a named garnishee, you are directed to notify himlher that he/she has been added as a garnishee and is enjoined as above stated. Amount Due $114,468.37 Interes! 6/23/04 - 12/8/04 - $3,387.89 Atty's Comrn % Atty Paid $173.80 Plaintiff Paid Date: JUNE 28, 2004 L.L. $.50 Due Prothy $1.00 Other Costs (Seal) CURTIS R. LONG Prothono!a!Y ~ ~y: ~IJ~'J.. 2. F 'c~0)~ Deputy REQUESTING PARTY: Name LOUIS P. VITTI, ESQUIRE Address: 916 FIFTH AVENUE PITTSBURGH, PA 15219 Attorney for: PLAINTIFF Telephone: 412-281-1725 Supreme Court ID No. 01072 IN THE COURT OF COMMON PLEAS OF CUMBERLAND COUNTY, PENNSYLVANIA CIVIL DIVISION JAMES B. NUTTER & COMPANY, ) Plainitff, ) w, ) JEHAD A. EWIDEH and NlVERTITI EWIDEH, ) Defendants. ) NO. 04-1063 CIVIL TERM AFFIDAVIT I, Louis P. Vitti, do hereby swear that, to the best of my knowledge, information and belief, the Defendant(s), is/are the owners of the real property on which the Plaintiff seeks to execute, That the Defendants' last known address for Nivertiti Ewideh149 Chester Street, Carlisle, PA 17013, last known address for Jehad A. Ewideh is Cumberland County Prison, 110 1 Claremont Rd, Carlisle, P A 17013. SWORN TO and subscribed before me this 22nd day of June, 2004 ~~~P%J~_ ) NC'tar-ird Scar ;j' i_Sherry L 1'10UGO, Notary Public I UI -'0', ;.';. , ., . '....P....CJD..rt H...$ G,'JrO, Allegheny co. unty L. ,I"l)' CC'1'TrJ!S$/(} F mires January 28, 2007 r~(.:,:,'.-.~~!','f~;;I:;;:;;f1~~~~~~~otaries IN THE COURT OF COMMON PLEAS OF CUMBERLAND COUNTY, PENNSYLVANIA CIVIL DIVISION JAMES B. NUTTER & COMPANY, ) Plainitff, ) ft. ) JEHAD A EWIDBH and NIVBRTITI BWIDBH, ) Defendants. ) NO. 04-1063 CIVIL TBRM AFFIDAVIT I, Louis P. Vitti, hereby certifY that as representative of James B. Nutter & Company am familiar with the above-captioned case and various servicing activities related thereto and that the provisions of the laws of the Connnonwealth of Pennsylvania and specifically, Act 91 of 1983, have been complied with in the above-captioned case. jJ . liARJlt/ dh ! Lo's P Vitti, Esquire Jt mey for Plaintiff SWORN to and subscribed before me this 22nd day of June, 2004. r/:(:~~~l__ ~ fltA.t!. , "' NOj;,>i;~;':'-;~:',:,~'--'---'--'-----; Shany L HOL!SIC' t./.,,>\;o;-"i! D, .b'l" I' F'i- r~ ,. .., . ",..-.. .". ! ~. ,1,_ .08..::>dnt hIlls Bom. AU '-''''''''''''1 {" ty i ~'jh C' '. "- , "~1 .,,' , ,_.Gun I _.~..'2:'~~SIO~_~XfJIres ,January ~8. 2007 t/0;1 !Ix"r c-enn~;~III.:;;;;;'::..::_~,.;;;~:,~,-:-~;.;.~~;:;;;J IN THE COURT OF COMMON PLEAS OF CUMBERLAND COUNTY, PENNSYLVANIA CIVIL DIVISION JAMES B. NUTTER & COMPANY, Plainitff, ) ) vs. ) JEHAD A. EWIDEH and NIVERTITI EWIDEH, ) Defendants. ) NO. 04-1063 CIVIL TERM AFFIDAVIT PURSUANT TO RULE 3129.1 James B. Nutter & Company, Plaintiff in the above action, sets forth as of the date the Praecipe for the Writ of Execution was filed the following infonnation conceming the real property located at 149 Chester Street, Carlisle, PA 17013, 1. Name and address ofOwner(s) or Reputed Owner(s): Name: Address (Please indicate if this cannot be reasonably ascertained) Nivertiti Ewideh 149 Chester Street Carlisle, PA 17013 Jehad Ewideh Cumberland County Prison Carlisle, PA 17013 2, Name and address ofDefendant(s) in the judgment: Name: Address (Please indicate if this cannot be reasonably ascertained) Same as No. I 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: Address (Please indicate if this cannot be reasonably ascertained) None 4. Name and address of the last recorded holder of every mortgage ofrecord: Name Address (Please indicate if this cannot be reasonably ascertained) None 5, Name and address of every other person who has any record lien on the property: Name Address (Please indicate ifthis cannot be reasonably ascertained) None 6, Name and address of every other person who has any record interest in or record lien on the property and whose interest may be affected by the sale: Name Address (Please indicate if this cannot be reasonably ascertained) 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 Address (Please indicate if this cannot be reasonably ascertained) Tax Collector of North Middleton Twp c/o Robin Soloenberger 5 Hill Drive Carlisle, PA 17013 North Middleton Sewer Authority 240 Clearwater Dr Carlisle, PA 17013 Commonwealth ofPA -DPW P.O. Box 8016 Harrisburg, PA 17105 Clerk of Courts CriminallCivil Division One Courthouse Square Carlisle, P A 17013 Tax Claim Bureau of Cumberland County Cumberland County Courthouse One Courthouse Square Carlisle, P A 17013 Court of Common Pleas of Cumberland County Domestic Relations Division PO. Box 320 Carlisle, PA 17013 Bureau of Compliance Clearance Support Section Dept. #281230 Harrisburg, PA 17128-1230 Attn: Susan Blough T enantlOccupant 149 Chester Street Carlisle, P A 17013 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. Section 4904 relating to unsworn falsification to authorities, June 22, 2004 Date ~;wQrJJv P. Vitti, Esquire mey for Plaintiff SWORN TO and subscribed before me this 22nd day of June, 2004. ~raY~~j -------;-',-z-~;.---.- J I r\,clu.n8.1~)8C:U ] SI"eny L. House, Nowry F'UbiiC \ 81'.",<"'aI11 Hills B010...AUegneny COUIl,tv007 , . "e, 28 ' i ~,1v Commission Expires J~--=~.:.:=_ , L~. _.:..--:-. "0""'" 'I,.,.",i'~ fS-:-1datlon 0\ NotaneS 1-"-'''-''-''''', r':.""C'" V<->. " ( r--) L., , -, , r. (-') NOTICE OF SHERIFF'S SALE OF REAL ESTATE PURSUANT TO PENNSYLVANIA RULE OF CIVIL PROCEDURE 3129.1 TO Nivertiti Ewideh 149 Chester St Carlisle, PA 17013 Jehad A. Ewideh Cumberland County Prison 1101 Claremont Rd Carlisle, PA 17013 AND: ALL LIEN HOLDERS TAKE NOTICE that by virtue of the above Writ of Execution issued out of the Court of Connnon Pleas of Cumberland County, Pennsylvania and to the Sheriff of Cumberland County, directed, there will be exposed to Public Sale in Cumberland County Courthouse on December 8, 2004 at 10:00 A.M., the following described real estate, of which Jehad A. Ewideh and Nivertiti Ewideh are owners or reputed owners: North Middletown Twp, Cty of Cumberland, Cmwlth ofPA. HET 149 Chester Street, Carlisle, PA 17013, Parcel# 29-16-1096-020. The said Writ of Execution has issued on a judgment in the mortgage foreclosure action of James B. Nutter & Company vS.JehadA. Ewideh and Nivertiti No. 04-1063 in the amount of$144,468.37 Claims against property must be filed at the Office of the Sheriff before above sale date. Claims to proceeds must be made with the Office of the Sheriff before the sale date. Schedule of Distribution will be filed with the Office of the Sheriff no later than thirty (30) days from sale date. Exceptions to Distribution or a Petition to Set Aside the Sale must be filed with the Office ofthe Sheriff no later than ten (10) days from the date when Schedule of Distribution is filed in the Office of the Sheriff. Attached hereto is a copy of the Writ of Execution. It has been issued because there is a judgment against you. It may cause your property to be held or taken to pay the judgment. You may have legal rights to prevent your property from being taken. A lawyer can advise you more specifically of these rights If you wish to exercise your rights you must act promptly. YOU SHOULD TAKE TIDS NOTICE AND THE WRIT OF EXECUTION TO YOUR LAWYER AT ONCE. IF YOU DO NOT HAVE A LAWYER OR CANNOT AFFORD ONE, GO TO OR TELEPHONE TIIE OFFICE SET FORTH BELOW TO FlND OUT WHERE YOU CAN GET LEGAL ADVICE. CUMBERLAND COUNTY BAR ASSOCIATION 2 LmERTY AVENUE CARLISLE, PA 17013 (717) 249-3166 Yau may have legal rights to prevent the Sheriff's Sale and the loss of your propeny. In order to exercise those rights, prompt action on your part is necessary. A lawyer may be able to help you. You may have the right to prevent or delay the Sheriff's Sale by filing, before the sale occurs, a petition to open or strike the judgment or a petition to stay the execution. If the judgment was entered because you did not file with the Court any defense or objection you might have within twenty (20) days after service of the Complaint for Mortgage Foreclosure and Notice to Defend, you may have the right to have the judgment opened in you promptly file a petition with the Court alleging a valid defense and a reasonable excuse for failing to file the defense on time. If the judgment is opened, the Sheriff's Sale would ordinarily be delayed pending a trial of the issue of whether the Plaintiff has a valid claim to foreclose the Mortgage. You may also have the right to have the judgment stricken if the Sheriff has not made a valid return of service of the Complaint and Notice to Defend or if the judgment was entered before twenty (20) days after service or in certain other events. To exercise this right, you would have to file a petition to strike the judgment. . You may also have the right to petition the Court to stay or delay the execution and the Sheriff's Sale if you can show a defect in the Writ of Execution or service or demonstrate any other legal or equitable right. You may also have the right to have the Sheriff's Sale set aside if the property is sold for a grossly inadequate price or if there are defects in the Sheriff's Sale. To exercise this right, you should file a petition with the Court after the sale and before the Sheriffhas delivered his Deed to the property. The Sheriff will deliver the Deed if no petition to set aside the sale is filed within ten (10) days from the date when the Schedule of Distribution is filed in the Office of the Sheriff. , J i/t- P. Vitti, Esquire torney for Plaintiff 916 Fifth Avenue Pittsburgh, PA 15219 (412) 281-1725 **THE DEBT COLLECTOR IS ATTEMPTING TO COLLECT A DEBT AND ANY INFORMATION OBTAINED WILL BE USED FOR THAT PURPOSE.** ,. e> r~ , I: I..':", Q <;:, -':;,. -rJ\:J.'J (0f"I; f:;;-:.~' ~i ..,r... ; ><:: ?~ :<i - " ..., = => -"'" ::ll: :1>" -c 1') ~ ~ ~ mfQ ."en ::09 '15:) 0 -r, --n -?o ?,-fl1 2 ':'f::l; ~, -0 :3: '8 Cl IN THE COURT OF COMMON PLEAS OF CUMBERLAND COUNTY, PENNSYLVANIA ALTEGRA CREDIT COMPANY, CIVIL DIVISION Plaintiff, NO. 2004-1063 CIVIL TERM AFFIDAVIT OF SERVICE vs. JEHAD A. EWIDEH and NIVERTITI EWIDEH, Defendants. Filed on behalf of Plaintiff Counsel of record for this party: Louis P. Vitti, Esquire PA J.D. #3810 Supreme Court #01072 Louis P. Vitti & Assoc., P.C. 916 Fifth Avenue Pittsburgh,PP. 15219 (412) 281-1725 IN THE COURT OF COMMON PLEAS OF CUMBERLAND COUNTY, PENNSYLVANIA CIVIL DIVISION JAMES B. NUTTER & COMPANY, Plaintiff, ) ) vs. ) JEHAD A. EWIDEH and NIRERTITI EWIDEH, ) Defendants. ) NO,. 04-1063 AFFIDAVIT OF SERVICE I, Helen Boyce, do hereby certify that a Notice of Sale has been served upon the Defendants on September 02, 2004 by the Sheriff of Cumberland County and all Lien Holders, by Certificate of Mailing, for service in the above-captioned case on June 30, 2004, advising them of the Sheriff's sale of the property at 149 Chester Street, Carlisle, P A 17013 on December 8, 2004. LOUIS P. VITTI & ASSOCIATES, P.c. BY~ ~L Helen Boyce SWORN to and subscribed before me this 1st day of November, 2004.. $~~~~~ I :.~ ~ '," .. <. ',:~ ),~:: ;1 : :' ..' ~ ," . ) D');;';,,,,$,,/ ; ", ., I '::,':;' '2,"",;", ~ L . " US. POSTAL SERVICE 1t",.:"~,,,<j(,,~~U"'. --,:. ". ~-.........'..~.., ...............--, 1;"" I: I !;.Ul ~ :, j .~ ,>Oft, t :~ ~ .-'. :: .~ , .... { I r ~ ~.-' ~ t..... l ./ -' , ~ ."', A ~ ~ C';--.. ; .l~' I /, -...'..11...."'~; "'f RecoNed From I ~/:,--.... cf'.~'~' . ;' ; Louis P. Vitti & Associates P .C. i ':"'..... i .cl ~()ll.' .. . . I r. ! 916 Fifth Avenue. Pittsburgh. PA 152191 ol;;z:', Go? '.;:: ~';. .' , i 0... _,:,? t,"'" ~- ~ ., f' .' ..." '.,p..\, ,I.,~, ..,. . :-#';.~;;\-;" '\,: ~ , . " . , ' CERTIFICATE OF MAILING MAY BE USED FOR DOMESTIC AND INTERNATIONAL MAil. DOES NOT PROVIDE FOR INSURANCE-POSTMASTER One piece of ordinary maD lIddr8S5ed to Tenant/Occupant 149 Chester Street Carlisle, PA 17013 PS Form 3817, January 2001 ..: M:; '(~', ..../' U.S POSTAL SERVICE CERTIFICATE OF MAILING MAY BE USED FOR DOMESTIC AND INTERNATIONAL MAIL. DOES NOT PROVIDE FOR INSURANCE-POSTMASTER Received From- :' ' One piece of ordinary mail addressed to: Louis P. Vitti & Associates. P.C. ._~ 916 Fifth Avenue. Pittsburgh. PA 15219 ,it 5 fA'" .' --..... '1 ~ 1"1'':( .,d};' \,~.. ,.:::., c';?-. \ fl 10 ~~.%:..;::'>j \ v.. :;?.;. ,l / Co. , 4Jw ,'- .,,/ \' "...1:' '....,_,,.,~../..'c '. ).Ir-..J f'o.- ":"-' , . . ~ PS Form 3817, January 2001 ~ "--~ ~ "l~ f'<. ; :,.:~~..,_._.\ ' " .ri~;}1,,)~] It:; I .'11 .n . \ '-, ,!'" I -n i '. ..' ! ~~: C~l i . .". 1 ~" i co.: ~ '..j, " ~ ' ! ; ~; ; ,.",' ! ~,,~~. ,;, l ....... J Bureau of Compliance Clearance Support Section Dept. #281230 Harrisburg, PA 17128-1230 Attn: Susan Blough U,S. POSTAl SERVICE CERTIFICATE OF MAIUNG .j,-,,~... ~f.<1I4r-l<~1I.l<. i~ ~.r-~~7"!."'~~ , ~ ~ ~ 'II ! "'~ ;. l~i~~,:Y~~':;k (:r: i~~~ t l?,/ 4,....., ;' \ -.-> ;~. . I:../i ,:;;;;, ~ :.., 1 ':"j i, 10 \ ?E:,(;f'"c:--.l., ! ',......;....:::... ~ : !.."If/' -~.~/~~. .. '." f..!r: .J I'~~';"~ ........c . /. --,-..... ~' ,. . '..... MAY BE USED FOR DOMESTIC AND INTERNATIONAL MAil. DOES NOT PROVIDE FOR INSURANCE-POSTMASTER ReceIVed From: Louis P. Vitti & Associates. P.C. 916 Fifth Avenue. Pittsburgh. PA 15219 One piece of ordinary maD addre8llied to- Court of Common Pleas of Cumberland County Domestic Relations Division P.O. Box 320 Carlisle, P A 17013 PS Form 3817, Janua 2001 ... i, l..-.~ ....' ~' ~ :.' ' , , r I // Louis p, Vitti & Associates. P .C. 916 Fifth Avenue. Plttsburah. PA 15219 CERTIFICATE OF MAIUNG .' -:;--- ')i~- " , ~.,... -.. 0"'. flo.:\ \ ~ '~!2.>/ o.:s:. ~'<~. .,., ,.:::J~. '1f';:1 ~,. ,O.~"_ ;~) ,. \v.-- ',.... . _...-:,~ .\" .,- ~ rJ ;... ;~(\' :.::; I" U.S POSTAl SERVICE MAY BE USED FOR DOMESTIC AND INTERNATIONAL MAil. DOES NOT PROVIDE FOR INSURANCE-POSTMASTER Rt!lCeiVed From: One plecl!!l of ordinary man ad~essed to: , ~ , \ ;,' t'; i., ---,_,~_.-,-,. .",:; ~~~&%~,;:\:~ 1 :.-. I ' " ". ,I f ~,~ , ,_. ~'r.~ 1 ~~ ! :~~ ?'i ;~:~ ) '::-:~ 1 ~ Tax Claim Bureau of Cumberland County Cumberland County Courthouse One Courthouse Square Carlisle, P A 17013 ~.Uu;dW. \J.3.0l..(.~~02a./,/~~ U.S, POSTAl SERVICE CERTIFICATE OF MAIUNG .. ,~.~,." ....~~~.\~'.~ " f,'~ .:_:~h ..~ ;;~ ~ ~ 1 '. ~< t i' . 71., ~'!'" f ,':_~ : MAY BE USED FOR DOMESTIC AND INTERNATIONAL MAIL. DOES NOT PROVIDE FOR INSURANCE.pOSfMASTER Received From. ,..., ~ '- (,": ,/ /,\. )(A';, :' ( ~~".-...'l ~. . Louis P. Vitti & Associates. P.C. !.~ './ ~>",.. ", 916 Fifth Avenue. Pittsburgh. PA 1521:;,? I '" 1; \~~, ~.. ,,' 10. ~.;;:}:>. .,' '...,Go,., ,-- , .' - ........,~' , J>--.~ "~')I .,.. ,,-... ... }.Ire _H\''"C~'' l. "~,..,:~~.........."" . _. I ~ et , One piece of ordinary mall addressed to: Clerk of Courts Criminal/Civil Division One Courthouse Square Carlisle, P A 17013 i' ,/ ':'~ ./,,(.:1.' ./' PS Fenn 3817, January 2001 .~' i i -,~, " '., ~ CERTIFICATE OF MAIUNG _. '.-, ~-' . , ~ ~." ,.>- -, ~ MAY B USED FOR DOMESTIC AND INTERNATIONAl. MAlL, DOES NOT /' ~ ~ . ;-', '. . I PROVIDE FOR INSURANCE.pOSTMASTER ,~. ~ ", ,,- ., ' :.J ..~;:, ~~'-:'_":""--' 0," ~ RllC<lIvodFrom' II..:; ~ -.r""ell ..'........' ,/"1 " C. ;' ~"-' ,-, "~'",: ." ie, Loul:, P. Vitti & Associates. P.C. j1J 4:"~' ~,;~:~~;~:.~;\~.:;~~ 916 Fifth Avenue. Pittsburgh. PA 15219 \0;6-') Go-ll;"';"!Y\''\'", ',,, \~ ~ ~ ...;) ~.~ ff~~~:':1{:?:";: t\ .:~ '-.('. "re.tf~~/ '~:;!' in t~J '..r.v'V ','" 1 i."; .~~~ ... '-- . ~ ~1,,,, . ~.....! I', .": ~ r.S 1 ! l:f': ~ .~:.~) 1 ~ '~ t U.S. POSTAl SERVICE One piece of adinary mail addrMSed to: Commonwealth ofPA -DPW P.O. Box 8016 Harrisburg, PA 17105 , .~:~. , PS Fenn 3817, January 2001 ... (:.),.~!.~:.>:~.~~.~~I~ ~ :~, i.~. I . U,S POSTAl SERVICE CERTIFICATE OF MAIUNG .' :~:~l , . : :;: ; One piece of ordinary mail addressed to: ,,: . .-;---......., j'. ~ '), ~ /",.t ;)" ~I.' ' .,;. ~~ :0--_'.. ,1'>., " . ~. . :/ r.~""U~";' ,.' ".':....n .:.7:".~ f ,,,.'n .".~. .;. ;. ,.", >.r.' ./:J .2" , ','" .' i" " : ~",'" .,/~")~ 'r~{ ~ ~ 1 ' ,." . vel , > ' ,,~ " , \~~"- dtJ' '.,' \:{,,}.I~ ~\~~/\~ ' --....,~",. ~,,' ~ :: ~ : --:-'" MAYBE USED FOR DOMESTIC AND INTERNATIONAL MAIL. DOES NOT PROVIDE FOR INSURANCE-POSTMASTER Received From. Louis P. Vitti & Associates P .C. 916 Fifth Avenue. Pittsburgh. PA 15219 North Middleton Sewer Authority 240 Clearwater Dr Carlisle, P A 17013 I ' ,'~ , :-:I. PS Fonn 3817, January 2001 . ~ ~. \. / :Jl "~~ ;<, " ,,,. lJ..' / , / .,.,.' US POSTAl SERVICE CERTIFICATE OF MAILING MAYBE USED FOR DOMESTIC AND INTERNA TIONAi. MAIL. DOES NOT PROVIDE FOR INSURANCE-POS"TMASTER Louis P. Vitti & Associates. P .C. 916 Fifth Avenue. Pittsburgh. PA 15219 ~~=,)!.~~;~. . Pi}>: i I 1/;]1 ~~\ ,~) :; .:"::1 I;:J ~'" I. l:.t _ :'~.:.' ~; I \"" p" ,. h"'?!!S \. -;.. ,,:: ,) , ,.. J ~ i'C;:] >.i'):;~\;':~".;" " Received From: One piece of ordinary mail addressed to: Tax: Collector of North Middleton Twp c/o Robin Soloenberger 5 Hill Drive Carlisle, P A 17013 .;.. ~. '.' : ~i;~ ~ , ',' . ,.,. ~ '.:1 ,~ ; .J~ ; ~-") ,. r.' ,/ i ,:: "~\l~. .~..... ..'. -.. ... U.S. POSTAL SERVICE CERTIFICATE OF MAILING .~~ ;$ ... ~ 'Jj ~" " t ~ i~ , ", '--~"~ '. . MAY BE USED FOR DOMESTIC AND INTERNATIONAL MAIL, DOES NOT ) i , '- , PROVIDE FOR INSURANCE-POSTMASTER , l.' . J' !., '.... ~..... . . "". . V ' \\,h)Ut.i.',E Cir~1l.. S .... '.' 916 FIFTH AVENUE/~~/:-:--":'; 'N'; " ." i ~~, I'll 1::::~~~:;~5~B ~riT!:f:~:;J \~. ~4 "!:/!~'~.;; '(~~~;j.~;~:;, '.~l';..Jt\o":;"~ ;; '~di~~,,:' , '-"'~: ~..._: ~ ~--_... ~ :~" " .' ..--:-~ '<'J ; :-t ,- One piece of ordinary mail addressed to: Je.ho. ~ (UJ ~ cl.Q. h C,,\)M t\.Qr \ Q.t^ ~ (1110 (\ \ '-\ \~l C\t!.(€-f\.\.O()4 U 1.5~. PA al PS Form 3817, January 2001 Q\'\~c.'\. , .., t, " .. ., !.. ,;.. '.' :."i ,I ~', . ,- / , ."..~ U.S. POSTAL SERVICE CERTIFICATE OF MAILING /"'Di" JI / l '; \ I ~ . \,! 'c.; I MAY BE USED FOR DOMESTIC AND INTERNATIONAL MAIL, DOES NOT PROVIDE FOR INSURANCE-POSTMASTER , . -', I . ~ '-, -- .", 4' " \ ' \if'\ _t (>.. ',(<'t,.. a J,'n .~" ':I , ~* j I~., i' ;~ , c. ~ ~' f'~f l' I \IE' r -\. i -\-; €\.u ~ d.{l_ V\ \qq L~<;.kr s+ Co.r\is\e. PA \10\3 .;, . ~;~~~ ; ;.~ ; ~. " y, " PS Form 3817, January 2001 ~-~ ....".._~. -',' 'HH ,. 'f~ """\" '.' ,. <.~ c . I ( ,(; I'. ~~ .' "f I~ ~ , ' """ .' f,'~~ (') c <' -cl i'~ . f'\ 1 .+ ~5 ~!~ ~.~L .r c "~.:i {:~ - C" Z ~ ,. f''' ~..,. CJ ..r- :z: <:.:.' ...-.c: I W (i '1'1 :Y. - rnp -nm :tl CJ ~:~ (T.'I :',:2~ ;:,) rT\ ~ -a - -... .r.::- o c.." IN THE COURT OF COMMON PLEAS OF CUMBERLANDA COUNTY, PENNSYLVANIA JAMES B. NUTTER & COMPANY, CIVIL DIVISION Plaintiff, No. 2004-.1063 CIVIL TERM vs. PRAECIPE TO SETTLE/DISCONTINUE AND SATISFY JUDGMENT JEHAD A. EWIDEH and NIRERTITI EWIDEH, Defendants. - MORTGAGE FORECLOSURE - Filed on behalf of Plaintiff Counsel of record for this party: Louis P. Vitti, Esquire PA I.D. #3810 Supreme Court #01072 Louis P. Vitti & Assoc., P.C. 916 Fifth Avenue Pittsburgh, PA 15219 (412) 281-1725 IN THE COURT OF COMMON PLEAS OF CUMBERLAND COUNTY, PENNSYLVANIA CIVIL DNISION JAMES B. NUTTER & COMPANY, ) ) Plaintiff, ) ) vs. ) ) JEHAD A. EWIDEH and NEIERTITI EWIDEH, ) ) Derendants. ) NO. 2004-1063 CNIL TERM PRAECIPE TO SETTLE/DISCONTINUE AND SATISFY JUDGMENT TO: THE PROTHONOTARY KINDLY settle, discontinue and satisfY judgment of Plaintiffs case in the above-captioned matter. LOUIS P. VITTI & ASSOCIATES, P.C. BY: , , .\J~- uis P. Vitti, EsqUllre omey for Plaintiff SWORN TO and subscribed before me this 1.J..!{ day :J:;;;;):~A Notary Publi COMMONWEALTH OF PENNSYLVANIA Notarial Seal ~ Ci Theresa Siwik, Notary Public ty Of P~rgh, Allegheny County Me My CommISSIOn Expires Oct. ;9, 2007 mber, Pennsylvania Association Of Notaries (' ';I ( - I I '~--:I ", - I i I C:-.l ~. ,) , C I i .' ( ,.~ I l..)) ,. James B. Nutter & Company VS Jehad A. Ewideh and Nivertiti Ewideh In The Court of Common Pleas of Cumberland County, Pennsylvania Writ No. 2004-]063 Civil Term Michael Barrick, Deputy Sheriff, who being duly sworn according to law, sta es that on September 02, 2004 at 10:21 o'clock AM, he served a true copy of the within Real Estate Writ, Notice of Sheriffs Sale and Description, in the above entitled actio , upon the within named defendants, to wit: Jehad A. Ewideh and Nivertiti Ewideh, by posting the premises located at 149 Chester Street, Carlisle, Cumberland County, Pennsylvania, with a true copy of the Real Estate Writ, Notice ofSa1e and Descriptio, pursuant to order of court, according to law. Richard Smith, Deputy Sheriff, who being duly sworn according to law, state that on October 08, 2004 at 12:35 o'clock P.M., he posted a true copy of the within R al Estate Writ, Notice, Poster and Description, in the above entitled action, upon the property of Jehad A. Ewideh and Nivertiti Ewideh located at 149 Chester Street, Carl sle, 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 name defendants, to wit: Jehad A. Ewideh and Nivertiti Ewideh, by regular mail to their las known address of 149 Chester Street, Carlisle, P A 17013. These letters were mailed under the date of October 06,2004 and retumed to the Sheriff's Office on October 12, 2004 marked "Not Deliverable as Addressed, Unable to Forward." R. Thomas Kline, Sheriff, who being duly sworn according to law, states this rit is returned STAYED per instructions from Attorney Louis P. Vitti. Sheriffs Costs: Docketing Poundage Advertising Posting Handbills Law Library Prothonotary Levy 30.00 2,252.60 15.00 15.00 .50 1.00 15.00 . 1,t>'O c.r~ 41921 tL-. /6''ilJ). <; " James B. Nutter & Company VS Jehad A. Ewideh and Nivertiti Ewideh In The Court of Common Pleas of Cumberland County, Pennsylvania Writ No. 2004-1063 Civil Term Michael Barrick, Deputy Sheriff, who being duly sworn according to law, sta s that on September 02, 2004 at 10:21 o'clock AM, he served a true copy ofthe within Real Estate Writ, Notice of Sheriff's Sale and Description, in the above entitled actio upon the within named defendants, to wit: Jehad A. Ewideh and Nivertiti Ewideh, by posting the premises located at 149 Chester Street, Carlisle, Cumberland County, Pennsylvania, with a true copy of the Real Estate Writ, Notice of Sale and Descriptio , pursuant to order of court, according to law. Richard Smith, Deputy Sheriff, who being duly sworn according to law, states that on October 08,2004 at 12:35 o'clock P.M., he posted a true copy of the within R al Estate Writ, Notice, Poster and Description, in the above entitled action, upon the property of Jehad A. Ewideh and Nivertiti Ewideh located at 149 Chester Street, Carli Ie, Pelillsylvania, 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 ofthe pendency ofthe action to the within name defendants, to wit: Jehad A. Ewideh and Nivertiti Ewideh, by regular mail to their last known address of 149 Chester Street, Carlisle, P A 17013. These letters were mailed under the date of October 06, 2004 and returned to the Sheriff's Office on October 12, 2004 marked "Not Deliverable as Addressed, Unable to Forward." R. Thomas Kline, Sheriff, who being duly swom according to law, states this t is returned STAYED per instructions from Attomey Louis P. Vitti. Sheriffs Costs: Docketing Poundage Advertising Posting Handbills Law Library Prothonotary Levy 30.00 2,252.60 15.00 15.00 .50 1.00 15.00 t 1>1) . 41'1.1.) ~ cr/)}..lf . 10 IN THE COURT OF COMMON PLEAS OF CUMBERLAND COUNTY, PENNSYL ANIA CIVIL DIVISION JAMES B. NUTTER & COMPANY, Plainitff, ) ) vs ) JEHAD A EWIDEH and NIVERTITI EWIDEH, ) Defendants. ) NO. 04-1063 CIVIL TERM AFFIDAVIT PURSUANT TO RULE 3129.1 James B. Nutter & Company, Plaintiff in the above action, sets forth as of the date the Praeci e for the Writ of Execution was filed the following infonnation conceming the real property located at 14 Chester Street, Carlisle, PA 17013. I. Name and address ofOwner(s) or Reputed Owner(s): Name: Address (Please indicate if this cannot be reasonably ascertained) Nivertiti Ewideh 149 Chester Street Carlisle, P A 17013 Jehad Ewideh Cumberland County Prison Carlisle, P A 17013 2. Name and address ofDefendant(s) in the judgment: Name: Address (Please indicate if this cannot be reasonably ascertained) Same as No, I above. 3, Name and last known address of every judgment creditor whose judgment is a record ( en on the real property to be sold: Name: Address (Please indicate if this cannot be reasonably ascertained) None 4. Name and address of the last recorded holder of every mortgage of record: Name Address (Please indicate if this cannot be reasonably ascertained) None 5, Name and address of every other person who has any record lien on the property: Name Address (Please indicate if this cannot be reasonably ascertained) None 6, Name and address of every other person who has any record interest in or record Ii n on the property and whose interest may be affected by the sale: Name Address (Please indicate ifthis cannot be reasonably ascertained) 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 Address (Please indicate if this cannot be reasonably ascertained) Tax Collector of North Middleton Twp c/o Robin Soloenberger 5 Hill Drive Carlisle, PA 17013 North Middleton Sewer Authority 240 Clearwater Dr Carlisle, PA 17013 Commonwealth ofPA -DPW P.O. Box 8016 Harrisburg, PA 17105 Clerk of Courts Criminal/Civil Division One Courthouse Square Carlisle, PA 17013 Tax Claim Bureau of Cumberland County Cumberland County Courthouse One Courthouse Square Carlisle, P A 17013 NOTICE OF SHERIFF'S SALE OF REAL ESTATE PURSUANT TO PENNSYLVANIA RULE OF CIVIL PROCEDURE 3129.1 TO Jehad A. Ewideh Nivertiti Ewideh 149 Chester St Carlisle, P A 17013 AND ALL LIEN HOLDERS TAKE NOTICE that by virtue of the above Writ of Execution issued out of the Court fCommon Pleas of Cumberland County, Pennsylvania and to the Sheriff of Cumberland County, directe there will be exposed to Public Sale in Cumberland County Courthouse on December 8, 2004 at 10:0 A.M., the following described real estate, of which Jehad A Ewideh and Nivertiti Ewideh are owners r reputed owners: North Middletown Twp, Cty of Cumberland, Cmwlth ofPA. HET 149 Chester Street, Carlisle, A 17013 Parcel# 29-16-1096-020, The said Writ of Execution has issued on a judgment in the mortgage foreclosure action f James B. Nutter & Company vsJehad A. Ewideh and Nivertiti No. 04-1063 in the amount of$144, 68,37, Claims against property must be filed at the Office of the Sheriff before above sale date Claims to proceeds must be made with the Office of the Sheriff before the sale date, Schedule of Distribution will be filed with the Office of the Sheriff no later than thirty ( 0) days from sale date Exceptions to Distribution or a Petition to Set Aside the Sale must be filed with the Offi e of the Sheriff no later than ten (10) days from the date when Schedule of Distribution is filed in the Offi of the Sheriff Attached hereto is a copy of the Writ of Execution. It has been issued because there is a ju gment against you, It may cause your property to be held or taken to pay the judgment. You may ha e legal rights to prevent your property from being taken. A lawyer can advise you more specifically f these rights, If you wish to exercise your rights you must act promptly YOU SHOULD TAKE TIDS NOTICE AND THE WRIT OF EXECUTIO LAWYER AT ONCE. IF YOU DO NOT HAVE A LAWYER OR CANNOT AFFO TO OR TELEPHONE THE OFFICE SET FORTH BELOW TO FIND OUT WHE GET LEGAL ADVICE. TO YOUR ONE, GO YOU CAN CUMBERLAND COUNTY BAR ASSOCIATION 2 LIBERTY AVENUE CARLISLE, PA 17013 (717) 249-3166 You may have legal rights to prevent the Sheriff's Sale and the loss of your property In order to exercise those rights, prompt action on your part is necessary. A lawy~r may be able to hel you You may have the right to prevent or delay the Sheriff's Sale by filing, before the sa e occurs, a petition to open or strike the judgment or a petition to stay the execution, If the judgment was entered because you did not file with the Court any defense or ob ection you might have within twenty (20) days after service of the Complaint for Mortgage Foreclosure d Notice to Defend, you may have the right to have the judgment opened in you promptly file a petiti n with the Court alleging a valid defense and a reasonable excuse for failing to file the defense on ti e, If the judgment is opened, the Sheriff's Sale would ordinarily be delayed pending a trial of the issue f whether the Plamtiffhas a valid claim to foreclose the Mortgage. You may also have the right to have the judgment stricken if the Sheriff has not made a v id return of service ofthe Complaint and Notice to Defend or if the judgment was entered before twenty 20) days after service or in certain other events, To exercise this right, you would I!ave to file a petitio to strike the judgment. You may also have the right to petition the Court to stay or delay the execution and th Sheriffs Sale if you can show a defect in the Writ of Execution or service or demonstrate any othe legal or equitable right. You may also have the right to have the Sheriffs Sale set aside if the property is sold for grossly inadequate price or if there are defects in the Sheriffs Sale. To exercise this right, you sho Id file a petition with the Court after the sale and before the Sheriff has delivered his Deed to the prope y. The Sheriff will deliver the Deed ifno petition to set aside the sale is filed within ten (10) days from he date when the Schedule of Distribution is filed in the Office of the Sheriff. -.... L s P Vitti Esquire tomey for Plaintiff 916 Fifth Avenue Pittsburgh, PA 15219 (412) 281-]725 **THE DEBT COLLECTOR IS ATTEMPTING TO COLLECT A DEBT AND ANY INFORMATION OBTAINED WILL BE USED FOR THAT PURPOSE. ** IN THE COURT OF COMMON PLEAS OF CUMBERLAND COUNTY, PENNSY VANIA CNIL DIVISION JAMES B. NUTTER & COMPANY, Plainitff, ) ) vs, ) JEHAD A EWIDEH and NIVERTITI EWIDEH, ) Defendants, ) NO. 04-1063 CIVIL TERM LEGAL DESCRIPTION All that certain tract ofland with the improvement thereon erected situate in North MIddleton Twonship, County of Cumberland and Commonwealth of Pennsylvania, bounded and described as foUo s Being Lot No, 7, on Plan No.7 of Noll Manor as recorded in the Office ofthe Recorder ofD eds Office for Cumberland County, in Plan Book 23, page I 19, containing 90 feet along Chester Stree , having a depth along the West along Lot No 8 of 133.65 feet, having a width in the rear along the North of ]02.89 feet and having a depth along East along Lot No, 6 of 125.49 feet. Having erected thereon a dwelling known as 149 Chester Street, Carlisle, PA 17013 Tax Parcel # 29-16-1096-020 Being the same premises which G. Travis Paules and Rickie L. Paules by their deed dated 11/28 000 and recorded on 12/04/2000 in the Recorder of Deeds Office of Cumberland County, Pennsylvani in Deed Book Volume 2335, page 543, granted and conveyed unto Jehad A Ewideh WRIT OF EXECUTION andlor ATTACHMENT COMMONWEALTH OF PENNSYL V A'lIA) COUNTY OF CUMBERLAND) . NO 04-1063 Civil CIVIL ACTION - LA TO THE SHERIFF OF CUMBERLAND COUNTY: To satIsfy the debt, interest and costs due JAMES B. NUTTER & COMPANY, Plaintiff (s) From JEHAD A, EWlDEH AND NIVERTITI EWlDEH (1) You are direc(ed (0 levy upon (he property of the defendant (s)and to sell SEE LEGAL DESCRIPTION (2) You are also directed to attach the property of the defendan((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 fr paying any deb( to or for (he account of the defendant (s) and from delivering any property of the defend nt (s) or otherwise disposing thereof: (3) Ifproperty ofthe defendant(s) not levied upon an subject to attachment is found in the possession of anyone other than a named garnishee, you are directed to notify himlher that helshe has been added as garnishee and is enjoined as above stated. Amount Due $114,468.37 In(erest 6/23/04 - 1218/04 - $3,387.89 L.L. $.50 Atty's Comm % Arty Paid $173.80 Plaintiff Paid Date: JUNE 28, 2004 Due Pro(hy $1.00 Other Costs CURTIS R. LONG (Seal) Deputy REQUESTING PARTY: Name LOUIS P. VITTI, ESQUIRE Address: 916 FIFTH AVENUE PITTSBURGH, PA 15219 Attorney for: PLAINTIFF Telephone: 412-281-1725 Supreme Court lD No. 01072 Real Estate Sale #20 On August 27, 2004 the Sheriff levied upon the defendant's interest in the real property situated in North Middleton Township, Cumberland County, PA Known and numbered as 149 Chester Street, Carlisle, more fully described on Exhibit "A" filed with this writ and by this reference incorporated herein. Date: August 27, 2004 By: JxL..; JfWJ.4 Real Estate Deputy t/I \';< '1' C"lIu"i I 'j I ,',j;' /\ ^,.i) flfl-;;;}G '~'\r\-'l^ ;.'}i ,) Ie '.' 9( r GZ Iwr .w, ,jillllilH, ' t-j F "J,' :ct.:t_,L~J @2> c:::;:nl c:::;:nl c:::::::l G?J (iVU {- ' . 0 ~ ~ ~ 6 " .~ g '" z U ~;:: c<1 0 ~ <D U ;::-15 0 06 ~~ .... ~\ , '" . ~ tu .j' 0 ~~ p 0 N ;l J,:P i :z: '" ci "" . ",:> :z: (0 " z ...... CI) ~ ~ ~ ~ ~ ~ 'Sill !ttl!i!:!1 j1 glI1.~11a z~~~gg ~~~"g13~St&~~ ~.eg~%~~< _0,,""0".0 "",;,.~_<dl<>""o '" 0> ""..JNtlU ."'''' ~ _ ~ \:l t-< ~ .. ~ E Cl .....'.$ . tl " 0 '" 0> tl So'" ""......~ '- " ;?; " :~~~%~~~o~~~~~l~%"i~~~~ ~l~~~it~ ",,-,~"":a,,>"" 0""-00> "" '" +:> 'm "'........."'''' t: ,~,5"<%."".".."~.~"~~"~.]~Oa~' 30t5'~%;~'"2~!~!~~.~:~;~'~"i~~~ ~~~~t8'~S.~,au~~~~*'~~'~116~~~i <. 1\ ,z~~' ~.58.;~o.; '"3~! .f ~.""~ ,., ""~,~.~~.~.~~~~..~..~,~..{.8~~ ~~sai"'(Oi""~8~~~:~g=~~t-<~~SB~i8"i .pgu~~ :z:~~(O~-15~.p~," Eu d~~B~(O~~ PROOF OF PUBLICATION OF NOTICE IN CUMBERLAND LAW JOURNAL (Under Act No. 587, approved May 16, 1929), P. L.1784 STATEOFPENNSYLVANIA : ss. COUNTY OF CUMBERLAND : Lisa Marie Coyne, Esquire, Editor ofthe Cumberland Law Journal, of the Co State aforesaid, being duly sworn, according to law, deposes and says that the Cumberl Journal, a legal periodical published in the Borough of Carlisle in the County and State a 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 re issued weekly in the said County, and that the printed notice or publication attached here exactly the same as was printed in the regular editions and issues of the said Cumberland Joumal on the following dates, VIZ: OCTOBER 8,15,22,2004 Affiant further deposes that he is authorized to verify this statement by the Cumbe land Law Journal, a legal periodical of general circulation, and that he is not interested in the s bject matter of the aforesaid notice or advertisement, and that all allegations in the foregoing statements as to time, place and character of publication are true. REAL ESTATE SALE NO. 20 ORN TO AND SUBSCRIBED before me t IS 22 day of OCTOBER 2004 Writ No. 2004-1063 Civil James B. Nutter & Company VS. Jehad A. Ewideh and Nivertiti Ewideh Atty.: Louis P. Vitti LEGAL DESCRIPTION All that certain tract of land with the improvement thereon erected sit- uate in North Middleton Township, County of Cumberland and Common- wealth of Pennsylvania, bounded and described as follows: Being Lot No.7. on Plan NO.7 of Non Manor as recorded in the Of- fice of the Recorder of Deeds Of- fice for Cumberland County, in Plan Book 23, page 119, containing 90 feet along Chester Street, having a depth along the West along Lot No. S of 133.65 feet, having a width in ~ AL SEAL LOIS E, SNYDER, Notary Public Carlisle Boro, Cumberland County My Commission Expires March 5. 2005 . 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 Michael Morrow, being duly sworn according to law, deposes and says: That he is (he Controller of The Patriot News Co., a corporation organized and existing under th laws of the Commonwealth of Pennsylvania, with its principal office and place of business at 812 to 818 Market eet, in the City of Harrisburg, County of Dauphin, State of Pennsylvania, owner and publisher of The Patriot-Ne s and The Sunday Patriot-News newspapers of general circulation, printed and published at 812 to 818 Market Stree , in (he City, County and State aforesaid: that The Patriot-News and The Sunday Patriot-News were established rch 4th, 1854. and September 18th, 1949, respectively, and all have been continuously published ever since; Tha( the printed notice or publication which is securely attached hereto is exactly as printed and ublished in their regular daily and/or Sunday! Metro editions which appeared on the 19th and 26th day(s) ofOctob and the 2nd day(s) of November 2004. That neither he nor said Company is interested in the subject matter of sai printed notice or advertising, and that all of the allegations of this statement as to the time, place and character of ublication are true; and That he has personal knowledge of the facts aforesaid and is duly authorized and empowered to v rify this statement on behalf of The Patriot-News Co. aforesaid by virtue and pursuant to a resolution unanimously assed and adopted severally by the stockholders and board of directors of the said Company and subsequently d Iy recorded in the office for the Recording of Deeds in and for said County of Dauphin in Miscellaneous Bo "M", Volume 14, Page 317. { I PUBLICATION ...............LAJ, COpy Sworn to and subscribed b~ S ALE #20 REAL ESTATE SALE No. 20 Writ No. 2004-1063 Civil Term Ja_ B. NutI8r . Company Vs Jehad A. Ewldah and NhIartIll Ewlclah Ally: louis P. Vitti DESCRIPTION NOTARIAL SEAl. Terry l. Russell, Notary Oly of Harrisburg. Dauphin My Commission Expires Jun Memb.r, P.nnlylvanlaAa.oclatlo ~4' OT PUBLIC 'ssion expires June 6, 2006 CUMBERLAND COUNTY SHERIFFS OFFICE CUMBERLAND COUNTY COURTHOUSE CARLISLE, PA. 17013 AlL 1HAT CEKrAIN tract of land with the improvement lbereon erected situate in North MiddI_ T....mp. County of Cumberland and CommonweaItb. of Pennsylvania, bounded and described as follows: BEING Lot No.7, on Plan No.1 of Noll Manor as recorded in the Office of ~ Recorder of Deeds OIIice for CumbedJlIld County, in Plan Book 13, page t19. OOIltaining 90 feet dong Chester Sttee\ baving a depth along the West a100g Lot No.8 of 133.65 feet, ba<ing a width in the rear aIong the North of 102.89 feet and ba,jng a depIh aIoog East dong Lot No.6 of 125.49 feet, llI\VlNG erected _ a dwelling inown " 149 Chester S_ Carlisle, PA 17013. TAX PARCFU29-16-10lJ6.ill0. BErNG the same premiseswbich G. Travis Paules and RU:kie L Pao1es by their deed dated 11128l2OOO and recorded on 121041'2OOJinthe _ of Deeds Ofti<:e of CumbedJlIld County. Peomyl...... in Deed Book Volume 2335. page 543. granted and conveyed unto JehadA. Ewideb. Statement of Advertising Costs To THE PATRIOT-NEWS CO. For publishing the notice or publication attached hereto on the above staled dates 213.28 Publisher's Receipt for Advertising Cost isher of The Patrio(-News and The Sunday Patriot-News, newspapers of genera edge receip( of the aforesaid notice and publication costs and certifies that the s me have By.................................................... ...............