Loading...
HomeMy WebLinkAbout01-6460FEDERMAN AND PHELAN, LLP By: FRANK FEDERMAN, ESQUIRE IDENTIFICATION NO. 12248 ONE PENN CENTER AT SUBURBAN STATION 1617 JOHN F. KENNEDY BOULEVARD SUITE 1400 PHILADELPHIA, PA 19103-1814 COUNTRYWIDE HOME LOANS, INC. 7105 CORPORATE DRIVE PLANO, TX 75024-3632 Plaintiff V. TIMOTHY S. CLIPPINGER TRACIE A. CLIPPINGER 338 C STREET CARLISLE, PA 17013 Defendant(s) ATTORNEY FOR PLAINTIFF COURT OF COMMON PLEAS CWIL DIVISION TERM CUMBERLAND COUNTY CML ACTION - T.AW COMPI,AINT TN MORTGAGE FORECT,O,RI~RE NOTICE **THIS FIRM IS A DEBT COLLECTOR ATTEMPTING TO COLLECT A DEBT AND ANY INFORMATION OBTAINED WILL BE USED FOR THAT PURPOSE. IF YOU HAVE PREVIOUSLY RECEIVED A DISCHARGE IN BANKRUPTCY AND THIS DEBT WAS NOT REAFFIRMED, THIS CORRESPONDENCE IS NOT AND SHOULD NOT BE CONSTRUED TO BE AN ATTEMPT TO COLLECT A DEBT, BUT ONLY ENFORCEMENT OF A LIEN AGAINST PROPERTY. ** You have been sued in Court. If you wish to defend against the claims set forth in the following pages, you must take action within twenty (20) days after this Complaint and Notice are served, by entering a written appearance personally or by attorney and filing in writing with the court your defenses or objections to the claims set forth against you. You are warned that if you fail to do so the case may proceed without you and a judgment 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 OR CANNOT AFFORD ONE, GO TO OR TELEPHONE THE OFFICE SET FORTH BELOW TO FIND OUT WHERE YOU CAN GET LEGAL HELP. CUMBERLAND COUNTY CUMBERLAND COUNTY BAR ASSOCIATION 2 LIBERTY AVENUE CARLISLE, PA 17013 (717) 249-3166 Loan It: 5909984 IF THIS IS THE FIRST NOTICE THAT YOU HAVE RECEIVED FROM THIS OFFICE, BE ADVISED THAT: PURSUANT TO THE FAIR DEBT COLLECTION PRACTICES ACT, 15 U.S.C. § 1692 et seq. (1977), DEFENDANT(S) MAY DISPUTE THE VALIDITY OF THE DEBT OR ANY PORTION THEREOF. IF DEFENDANT(S) DO SO IN WRITING WITHIN THIRTY (30) DAYS OF RECEIPT OF THIS PLEADING, COUNSEL FOR PLAINTIFF WILL OBTAIN AND PROVIDE DEFENDANT(S) WITH WRITTEN VERIFICATION THEREOF; OTHERWISE, THE DEBT WILL BE ASSUMED TO BE VALID. LIKEWISE, IF REQUESTED WITHIN THIRTY (30) DAYS OF RECEIPT OF THIS PLEADING, COUNSEL FOR PLAINTIFF WILL SEND DEFENDANT(S) THE NAME AND ADDRESS OF THE ORIGINAL CREDITOR, IF DIFFERENT FROM ABOVE. THE LAW DOES NOT REQUIRE US TO WAIT UNTIL THE END OF THE THIRTY (30) DAY PERIOD FOLLOWING FIRST CONTACT WITH YOU BEFORE SUING YOU TO COLLECT THIS DEBT. EVEN THOUGH THE LAW PROVIDES THAT YOUR ANSWER TO THIS COMPLAINT IS TO BE FILED IN THIS ACTION WITHIN TWENTY (20) DAYS, YOU MAY OBTAIN AN EXTENSION OF THAT TIME. FURTHERMORE, NO REQUEST WILL BE MADE TO THE COURT FOR A JUDGMENT UNTIL THE EXPIRATION OF THIRTY (30) DAYS AFTER YOU HAVE RECEIVED THIS COMPLAINT. HOWEVER, IF YOU REQUEST PROOF OF THE DEBT OR THE NAME AND ADDRESS OF THE ORIGINAL CREDITOR WITHIN THE THIRTY (30) DAY PERIOD THAT BEGINS UPON YOUR RECEIPT OF THIS COMPLAINT, THE LAW REQUIRES US TO CEASE OUR EFFORTS (THROUGH LITIGATION OR OTHERWISE) TO COLLECT THE DEBT UNTIL WE MAIL THE REQUESTED INFORMATION TO YOU. YOU SHOULD CONSULT AN ATTORNEY FOR ADVICE CONCERNING YOUR RIGHTS AND OBLIGATIONS IN THIS SUIT. Plaintiff is COUNTRYWIDE HOME LOANS, INC. 7105 CORPORATE DRIVE PLANO, TX 75024-3632 The name(s) and last known address(es) of the Defendant(s) are: TIMOTHY S. CLIPPINGER TRACIE A. CLIPPINGER 338 C STREET CARLISLE, PA 17013 who is/are the mortgagor(s) and real owner(s) of the property hereinafter described. On 10/29/96 mortgagor(s) made, executed and delivered a mortgage upon the premises hereinafter described to PROVIDENT MORTGAGE CORP. T/A CONSOLIDATED MORTGAGE CORP. which mortgage is recorded in the Office of the Recorder of CUMBERLAND County, in Mortgage Book No. 1348, Page 818. By Assignment of Mortgage recorded 10/29/96 the mortgage was assigned to PROVIDENT BANK OF MARYLAND which Assignment is recorded in Assignment of Mortgage Book No. 533, Page 702. By Assignment of Mortgage recorded 2/14/97 the mortgage was assigned to PLAINTIFF which Assignment is recorded in Assignment of Mortgage Book No. 540, Page 809. The premises subject to said mortgage is described as attached. The mortgage is in default because monthly payments of principal and interest upon said mortgage due 3/1/01 and each month thereafter are due and unpaid, and by the terms of said mortgage, upon default in such payments for a period of one month, the entire principal balance and all interest due thereon are collectible forthwith. The following amounts are due on the mortgage: Principal Balance Interest 2/1/01 through 11/1/01 (Per Diem $14.89) Attorney's Fees Cumulative Late Charges 10/29/96 to 11/1/01 Cost of Suit and Title Search Subtotal $67,009.45 4,079.86 3,350.00 211.84 550 00 $75,201.15 Escrow Credit 0.00 Deficit 1.535 27 Subtotal $.15..35..22 TOTAL $76,736.42 7. The attorney's fees set forth above are in conformity with the Mortgage documents and Pennsylvania Law, and will be collected in the event of a third party purchaser at Sherifgs Sale. If the Mortgage is reinstated prior to the Sale, reasonable attorney's fees will be charged. 8. This action does not come under Act 6 of 1974 because the original mortgage amount exceeds $50,000.00. WHEREFORE, PLAINTIFF demands an in rem Judgment against the Defendant(s) in the sum of $76,736.42, together with interest from 11/1/01 at the rate of $14.89 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. FRANK FEDERMAN, ESQUIRE Attorney for Plaintiff Cari~si~, Cumbcri.:mc. Ca~n-'7' ?~,m'.~''i''~'''n''~ ~ouaCe~ ~",d .las¢:-:b~c, ~ Comp~ on :h~ Scu:~: ~'..' prep=? aow ~: form~d~ of E~'ar~ Bra~na~]', ~nd ~ E. BELNG :he .,-am, e .'2r,~."~..' which .'LA'..~dONqD C. BOBB. ,5.I..1 ~nd DSBOKA.:'{ A_ BCBB, November 3, i9~ :~nd r~..,o, rded in the O~c= of th," Reorder of Deeds for Camberiznd Count~, ?:nnsylvania, in D~e Bock: :4, Page 505. PKEMISES ON: 338 C STREET VERIFICATION FRANK FEDERMAN, ESQUIRE hereby states that he is attorney for Plaintiff in this matter, that Plaintiff is outside the jurisdiction of the court and/or the verification could not be obtained within the time allowed for the filing of the pleading, that he is authorized to make this verification pursuant to Pa. R. C. P. 1024 ( c ), and that the statements made in the foregoing Civil Action in Mortgage Foreclosure is based upon information supplied by Plaintiff and is true and correct to the best of its knowledge, information and belief. Furthermore, it is counsel's intention to substitute a verification from Plaintiff as soon as it is received by counsel. The undersigned understands that this statement is made subject to the penalties of 18 Pa. C. S. Sec. 4904 relating to unsworn falsification to authorities. Frank Federman, Esquire Attorney for Plaintiff DATE: ///o0/6)/ SHERIFF'S RETURN CASE NO: 2001-06460 P COMMONWEALTH OF PENNSYLVANIA: COUNTY OF CUMBERLAND COUNTRYWIDE HOME LOANS INC VS CLIPPINGER TIMOTHY S ET AL - REGULAR RICHARD SMITH , Sheriff or Deputy Sheriff of Cumberland County,Pennsylvania, who being duly sworn according to says, the within COMPLAINT - MORT FORE was served upon CLIPPINGER TIMOTHY S the DEFENDANT at 338 C STREET , at 2105:00 HOURS, on the 16th day of November , 2001 CARLISLE, PA 17013 TIMOTHY CLIPPINGER by handing to 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 18.00 Service 3.25 Affidavit .00 Surcharge 10.00 .00 31.25 Sworn and Subscribed to before me this 2~~e~ day of ~ ~l~{ A.D. / Prothonotary So Answers: ii/19/2001 FEDERMAN & PHELAN By: riff SHERIFF'S RETURN - REGULAR CASE NO: 2001-06460 P COMMONWEALTH OF PENNSYLVANIA: COUNTY OF CUMBERLAND COUNTRYWIDE HOME LOANS INC VS CLIPPINGER TIMOTHY S ET AL RICHARD SMITH , Sheriff or Deputy Sheriff of Cumberland County,Pennsylvania, who being duly sworn according to law, says, the within COMPLAINT - MORT FORE was served upon CLIPPINGER THACIE A the DEFENDANT , at 2105:00 HOURS, at 338 C STREET CARLISLE, PA 17013 TIMOTHY CLIPPINGER, HUSBAND on the 16th day of November 2001 by handing to 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 6.00 Service .00 Affidavit .00 Surcharge 10o00 .00 16.00 Sworn and Subscribed to before me this 2L~ day of ~ ~/ A.D. thonotary' ' ' So Answers: R. Thomas Kline 11/19/2001 FEDERMAN & PHELAN By: e~p~t~y Sheriff FEDERMAN AND PHELAN By: FRANK FEDERMAN Identification No. 12248 Attorney for Plaintiff ONE PENN CENTER AT SUBURBAN STATION 1617 JOHN F. KENNEDY BLVD., SUITE 1400 PHILADELPHIA, PA 19103-1814 (215) 563-7000 COUNTRYWIDE HOME LOANS, INC. 7105 CORPORATE DRIVE PLANO, TX 75024-3632 Plaintiff, V. TIMOTHY S. CLIPPINGER TRACIE A. CLIPPINGER Defendant(s). CUMBERLAND COUNTY COURT OF COMMON PLEAS CIVIL DIVISION NO. 01-6460 PRAECIPE FOR JUDGMENT FOR FAILURE TO ANSWER AND ASSESSMENT OF DAMAGES TO THE PROTHONOTARY: Kindly enter judgment in favor of the Plaintiff and against TIMOTHY S. CLIPPINGER and TRACIE A. CLIPPI~NGER, 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 Plaintifl~s damages as!follows: As set forth in Complaint Interest from 11/1/01 to 12/20/01 TOTAL $76,736.42 $744.5O $77,480.92 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. FRAN~ FEDEt~VIAN, ESQ~ Attorney for Plaintiff DAMAGES ARE HEREBY ASSESSED AS INDICATED. PRO PROTHY FEDERMAN AND PHELAN, L.L.P. Frank Federman, Esquire Identification No. 12248 One Penn Center Plaza at Suburban Station, Suite 1400 Philadelphia, PA 19103-1799 (215) 563-7000 ATTORNEY FOR PLAINTIFF COUNTRYWIDE HOME LOANS, INC. Plaintiff VS. TIMOTHY S. CLIPPINGER TRACIE A. CLIPPINGER : COURT OF COMMON PLEAS : CIVIL DIVISION : CUMBERLAND COUNTY : NO. 01-6460 CIVIL Defendant(s) TO: TIMOTHY S. CLIPPINGER 338 C STREET CARLISLE,PA 17013 DATE OF NOTICE: DECEMBER 7,2001 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. IMPORTARTNOTICE You are in default because you have failed enter a written appearance personally or by attorney and file in writing with the court your defenses or objections to the claims set forth against you. Unless you act within ten (10) days from the date of this notice, a Judgment may be entered against you without a hearing and you may lose your property or other important rights. You should take this notice to a lawyer at once. If you do not_have a lawyer or cannot afford one, go to or telephone the following office to find out where you can get legal help: CUMBERLAND COUNTY CUMBERLAND COUNTY BAR ASSOCIATION 2 LIBERTY AVENUE CARLISLE, PA 17013 (717) 249-3 166 Frank Federman, Esquire Attorney for Plaintiff FEDERMAN AND PHELA~ Frank Federman, Esquire Identification No. 12248 One Penn Center Plaza at Suburban Station, Suite 1400 Philadelphia, PA 19103-1799 (215) 563-7000 ATTORNEY FOR PLAINTIFF COUNTRYWIDE HOME LOANS, INC. Plaintiff VS. : COURT OF COMMON PLEAS : CIVIL DIVISION : CUMBERLAND COUNTY TIMOTHY S. CLIPPINGER TRACIE A. CLIPPINGER Defendant TO: TRACIE A. CLIPPINGER 338 C STREET CARLISLE,PA 17013 : NO.01-6460 CIVIL DATE OF NOTICE: DECEMBER 7,2001 THIS FIRM IS A DEBT COLLECTOR ATTEMPTING TO COLLECT A DEBT. THIS NOTICE IS SENT TO YOU IN AN ATTEMPT TO COLLECT THE INDEBTEDNESS REFERRED TO HEREIN, AND ANY INFORMATION OBTAINED FROM YOU WILL BE USED FOR THAT PURPOSE. IF YOU HAVE PREVIOUSLY RECEIVED A DISCHARGE IN BANKRUPTCY, THIS CORRESPONDENCE IS NOT AND SHOULD NOT BE CONSTRUED TO BE AN ATTEMPT TO COLLECT A DEBT, BUT ONLY AS ENFORCEMENT OF LIEN AGAINST PROPERTY. IMPORTANT NOTICE You are in default because you have failed enter a written appearance personally or by attorney and file in writing with the court your defenses or objections to the claims set forth against you. Unless you act within ten (10) days from the date of this notice, a Judgment may be entered against you without a hearing and you may lose your property or other important rights. You should take this notice to a lawyer at once. If you do not have a lawyer or cannot afford one, go to or telephone the fol!owi~g office to find out where you can get legal help: CUMBERLAND COUNTY CUMBERLAND COUNTY BAR ASSOCIATION 2 LIBERTY AVENUE CARLISLE, PA 17013 (717) 249-3166 Frank Federman, Esquire Attorney for Plaintiff FEDERMAN and PHELAN By: FRANK FEDERMAN Identification No. 12248 ONE PENN CENTER AT SUBURBAN STATION 1617 JOHN F. KENNEDY BLVD., SUITE 1400 PHILADELPHIA, PA 19103-1814 (215) 563-7000 COUNTRYWIDE HOME LOANS, INC. 7105 CORPORATE DRIVE Plaintiff, V. TIMOTHY S. CLIPP[NGER TRACIE A. CLIPPINGER Defendant(s). ATTORNEY FOR PLAINTIFF CUMBERLAND COUNTY COURT OF COMMON PLEAS CIVIL DIVISION NO. 01-6460 VERIFICATION OF NON-MILITARY SERVICE FRANK FEDERMAN, ESQUIRE, hereby verifies that he is attorney for the Plaintiff in the above-captioned matter, and that on information and belief, he has knowledge of the following facts, to wit: (a) that the defendant(s) is/are not in the Military or Naval Service of the United States or its Allies, or otherwise within the provisions of the Soldiers' and Sailors' Civil Relief Act of Congress of 1940, as amended. (b) that defendant TIMOTHY S. CLIPPINGER is over 18 years of age and resides at, 338 C STREET, CARLISLE, PA 17013. (c) that defendant TRACIE A. CLIPPINGER is over 18 years of age, and resides at, 338 C STREET, CARLISLE, PA 17013. This statement is made subject to the penalties of 18 Pa. C.S. Section 4904 relating to unsworn falsification to authorities. FRANK FEDERMAN, I~SQ~IR~ Attorney for Plaintiff (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 ~'laintiff, V. TIMOTHY S. CLIPP!NGER TRACIE A. CLIPPINGER Ddfendant(s). CUMBERLAND COUNTY COURT OF COMMON PLEAS CIVIL DIVISION NO. 01-6460 Notice is given that a Judgment in the above-captioned matter has been entered against you on /o~- ~ J, 2001. (~DEPUTY ,/ If you have ~y questions concerning this matter, please contact: FRANK FEDERMAN, ESQUIRE Attorney for Plaintiff ONE PENN CENTER AT SUBURBAN STATION 1617 JOHN F. KENNEDY BLVD., SUITE 1400 PHILADELPHIA, PA 19103-1814 (215) 563-7000 **THIS FIRM IS ADEBT 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 ~FHIS DEBT WAS NOT REAFFIRMED, THIS CORRESPONDENCENDENCE IS NOT AND SHOULD NOT BE CONSTRUED TO BE AN ATTEMPT TO COLLECT A DEBT, BUT ONLY ENFORCEMENT OF A LIEN AGAINST PROPERTY.** P~CIPE FOR W~T OF E~CUTION - (MORTGAGE FO~CLOSU~) P.~C.P. 3180-3183 COUNTR~E HOME LOANS, Plaintiff, TIMOT~ S. CLIPPiNGER T~CIE A. CLIPP~GER D~fendant(s). No. 01-6460 TO THE DIRECTOR[ OF THE OFFICE OF THE PROTHONOTARY: Issue writ of execution in the above matter: Amount Due $77,480.92 / Interest from 12/2( (per diem - 13.14) TOTAL Note: ~/01 to 6/5/02 $2,486.63 and Costs $79,967.55 FRANK FEDERMAN, ESQUIRE One Penn Center at Suburban Station 1617 John F. Kennedy Boulevard, Suite 1400 Philadelphia, PA 19103-1814 Attorney for Plaintiff Please attach description of property. No. LEGAL Dr:,scILgPTION ~e improvements thereon situate in the Borough of Carlisle. id deSCribed as foI).ows: · ~st Company: on the South -----or~,, f Carhs).e T .L_ ~y,,~ by pro~ert? --,~,, now or tm,,,~--~_° -awelt; a~d on m: .... t . _ . . : East by p~vw..~. ~ o.*b~cca E. brow. the Sou:h ward BrownaWett anu ~-,- "C" Street of 45.g5 feet and on said lot having a frontage on 37 and 38, Breck I feet and b~ing made up o~ !~art~ of LotS Nos. Castis[e, ?enns~van[a. :ompany, and being .known a~ 3313 "C" Street, ' dated gaymond C. Bo0~ v~- ~d Deborah -\. Bobb. his wife, by their Deed COUNTRYWIDE HOME LOANS, INC. Plaintiff, V. TIMOTHY S. CLIPPiNGER TRACIE A. CLIPPINGER Defendant(s). CUMBERLAND COUNTY COURT OF COMMON PLEAS CIVIL DIVISION NO. 01-6460 COUNTRYWIDE FEDERMAN, ESQU following informatior 1. Name and address Name TIMOTHY S. CLIPP TRACIE A. CLIPPIN 2. Name and address TIMOTHY S. CLIPP TRACIE A. CLIPPIN 3. Name and last kno property to be sold: Sanl¢ None. AFFIDAVIT PURSUANT TO RULE 3129 (Affidavit No. 1) OME LOANS~ INC., Plaintiff in the above action, by its attomey, FRANK RE, sets forth as of the date the Praecipe for the Writ of Execution was filed the concerning the real property located at ~338 C STREET~ CARLISLE~ PA 17013 of Owner(s) or reputed Owner(s): Last Known Address (if address cannot be reasonably ascertained, please indicate) NGER 338 C STREET CARLISLE, PA 17013 GER 338 C STREET CARLISLE, PA 17013 of Defendant(s) in the judgment: 2qGER 338 C STREET CARLISLE, PA 17013 GER 338 C STREET CARLISLE, PA 17013 0vn address of every judgment creditor whose judgment is a record lien on the real Last Known Address (if address cannot be reasonably ascertained, please indicate) 4. Name and address of last recorded holder of every mortgage of record: Nanle UNION BANK AND TRUST COMPANY 5. Name and address Name None. 6. Name and address interest may be affect, Name None. 7. Name and address the property which ml Name Tenant/Occupant Domestic Relations Commonwealth of Pe: Department of Welfar I verify that the knowledge or informa penalties of 18 Pa. C.S December 20, 2001 DATE Last Known Address (if address cannot be reasonably ascertained, please indicate) 500 WASHINGTON STREET COLUMBUS, INDIANA 47201 of every other person who has any record lien on the property: Last Known Address (if address cannot be reasonably ascertained, please indicate) of every other person who has any record interest in the property and whose ~'d by the sale. Last Known Address (if address cannot be reasonably ascertained, please indicate) ~f every other person of whom the plaintiff has knowledge who has any interest in .y be affected by the sale: Last Known Address (if address cannot be reasonably ascertained, please indicate) 338 C STREET CARLISLE, PA 17013 'Cumberland County 13 North Hanover Street Carlisle, PA 17013 msylvania PO Box 2675 Harrisburg, PA 17105 tatements made in this affidavit are true and correct to the best of my personal tion and belief. I understand that false statements herein are made subject to the Sec. 4904 relating to unswom falsification to authorities. FRANK FEDERMAN, ESQUIRE Attorney for Plaintiff ~'EDERMAN and PHELAN By: FRANK FEDERMAN Identification No. 12248 ONE PENN CENTER AT SUBURBAN STATION 1617 JOHN F. KENNEDY BLVD., SUITE 1400 PHILADELPHIA, PA 19103-1814 (215) 563-7000 COUNTRYWIDE HOME LOANS, INC. Plaintiff, V. TIMOTHY S. CLIPPI TRACIE A. CLIPPIN nt FRAlx[ the above-captioned n because it is: (x) () () 0 NGER ~ER endant(s). ATTORNEY FOR PLAINTIFF This certification falsification to authori CUMBERLAND COUNTY COURT OF COMMON PLEAS CIVIL DIVISION NO. 01-6460 CERTIFICATION ( FEDERMAN, ESQUIRE, hereby verifies that he is attorney for the Plaintiff in tatter, and that the premises are not subject to the provisions of Act 91 FHA mortgage a-owner occupied Vl [cant Ac 91 procedures have been fulfilled s made subject to the penalties of 18 Pa. C.S. Section 4904 relating to unswom ties. FRANK FEDERMAN, ESQUIRE Attorney for Plaintiff COUNTRYWIDE HOME LOANS, INC. Plaintiff, V. TIMOTHY S. CLIPPINGER TRACIE A. CLIPPINGER Defendant(s). CUMBERLAND COUNTY No. 01-6460 December 20, 2001 TO: TIMOTHY S. 338 C STREE CARLISLE, l CLIPPINGER 17013 TRACIE A. CLIPPINGER 338 C STREET CARLISLE, PA 17013 **THIS FIPUVI IS OBTAINED WILL BE US[ BANKRUPTCY AND TH[2 AN ATTEMPT TO COLLE Your house (re the Sheriff's Sale on J Street, Carlisle, PA 17 HOME LOANS, IN( be relisted for the SEF YOU MAY BE ABLI To prevent thi,, The sal costs al call: (2 You ml judgme postpol 3. You m~ You may need you will have of stopp 4 DEBT COLLECTOR ATTEMPTING TO COLLECTA DEBTAND ANY INFORMATION D FOR THAT PURPOSE. IF YOU HA VE PRE VIOUSL Y RECEIVED A DISCHARGE IN DEBT WAS NOT REAFFIRMED, THIS IS NOT AND SHOULD NOT BE CONSTRUED TO BE CT A DEBT, BUT ONLY ENFORCEMENT OF A LIEN AGAINST PROPERTY. ** al estate) at, 338 C STREET~ CARLISLE, PA 17013, is scheduled to be sold at JNE $, 2002 at 10:00 a.m. in the Cumberland County Courthouse, South Hanover D 13, to enforce the court judgment of 777480.92 obtained by COUNTRYWIDE ',. (the mortgagee) against you. If the Sheriffs sale is postponed, the property will TEMBER 4, 2002 Sheriffs Sale. NOTICE OF OWNER'S RIGHTS , TO PREVENT THIS SHERIFF'S SALE Sheriffs Sale, you must take immediate action: will be cancelled if you pay to the mortgagee the back payments, late charges, td reasonable attorney's fees due. To find out how much you must pay, you may 5) 563-7000. Ly be able to stop the sale by filing a petition asking the Court to strike or open the nt, if the judgment was improperly entered. You may also ask the Court to ~e the sale for good cause. also be able to stop the sale through other legal proceedings. aa attorney to assert your rights. The sooner you contact one, the more chance ing 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 inadequate compared t 3. The sale wi] find out if this has hap 4. If the amora property as if the sale able to petition the Court to set aside the sale if the bid price was grossly the value of your property. go through only if the buyer pays the Sheriffthe full amount due in the sale. To ~ened, you may call (717) 240-6390. ~t due from the Buyer is not paid to the Sheriff, you will remain the owner of the tever happened. 5. You have tl e right to remain in the property until the full amount due is paid to the Sheriff and the Sheriff gives aldeed to the buyer. At that time, the buyer may bring legal proceedings to evict you. 6. You may b~ entitled to a share of the money which was paid for your house. A schedule of distribution of the mo~ey bid for your house will be filed by the Sheriff within 30 days of the sale. This schedule will state wh, > will be receiving that money. The money will be paid out in accordance with this schedule unless e~ ceptions (reasons why the proposed distribution is wrong) are filed with the Sheriff within ten (10) :lays after the distribution is filed. 7. You may al ;o have other rights and defenses, or ways of getting your home back, if you act immediately after the .ale. YOU SHOULD TAI E THIS PAPER TO YOUR LAWYER AT ONCE. IF YOU DO NOT HAVE A LAWYER OR CA NNOT AFFORD ONE, GO TO OR TELEPHONE THE OFFICE LISTED BELOW TO FIND 12 ,UT WHERE YOU CAN GET LEGAL HELP. CUMBERLAND COUNTY ATTORNEY REFERRAL CUMBERLAND COUNTY BAR ASSOCIATION 2 LIBERTY AVENUE CUMBERLAND COUNTY COURTHOUSE CARLISLE, PA 17013 (717) 249-3166 (800) 990-9108 ALL ~,at ce.".ma tract of land wi~. ' On ~ Noah ~ "C" S:r~t; on ~ w or formcrtv of S. L. Di~n. ~o ..... .~'~ deoth of LOt.~O C~!~sle ~nu ..... Novem~S 3, t99~ ~ CounW ~n D~ ~k tt~, Pa~e LEGAL D F..SC!LIEPTION t'~e improvements thereon situate in the Bcrough of Carlisle. Cumberland. de~bed as fotlowS: , ~ Ulh ~: Lc T~st Company'. o~. - ---ay now or formertY of C~J~.,. ~cd on thc West oy pruy-.-,. ~t oy pru~ f, .4 ~eb~Ca E. BroWn~ ..... feet and on :he Soum . ~ Off . o~an~, and beinB ~o~n ~ ,~ ~- Deed ; Camber~a~6 ~ymond C. ~bh 'v. ~=6 DebO~ A. ~bb. ~is wife. by 4 in ~e O~fice of ~e R~oree5 of D~s Novem~ 4, ~9 '--:;,,~-unto lo~a A. ~b, ~ng[e m~ u, ..... i63, gmnt~ an¢ con*~ . PLAINTIFF DEFENDANT(S) AFFIDAVIT OF SERVICE COUNTRYWIDE HOME LOANS, INC. TIMOTHY S. CLIPPINGER TRACIE A. CLIPPINGER CUMBERLAND COUNTY No. 01-6460 ACCT. #5909984 SERVE TRACIE A. CLIPPINGER AT 338 C STREET CARLISLE, PA 17013 Type of Action - Notice of Sheriff's Sale Sale Date: JUNE 5, 2002 SERVED Served and made known to '7~/''e'- )4 t C};ff;M~ff"-,Defendant, onth¢ of Pennsylvania, in the manner described below: ~'-I0~ dayof ~cZ_ , 2ooL, , Commonwealth Defendant personally served. ~ Adult family member with whom Defendant(s)reside(s). Relationship is ~q4d~3~-~. . ~ Adult in c~ge of Defendant(s)'s residence who reused to give ~me or relatio~hip. ~ Manager/Clerk of place of lodg~g in w~ch Defendant(s) reside(s). Agent or person ~ c~ge of Defen~nt(s)'s office or us~l place of business. an officer of said Defen~nt(s)'s company. O~er: Description: Age 5~ Height ~ Weight/~ff Race ~ Sex f Other ~[ I, ~e~c~ ~, ~.) ,~g, a co~etent ad.t, berg duly sworn according to law, depose and~state ~at I personally handed a ~e and co~ect copy of~e ~%&~ cf ~Lc~: ~:~ ~e *~- ~--~' as set fo~ here~, issued ~ ~e captioned case on the ~te and at · e ad.ess indicated above. [ ~ ~ ~ / ~ mK.~,N~ /.~~F~n~ I Sworn to ~d subsc~bed [ MY~~2,~ I - / ot , ood. //]/ PLEASE ATTEMPT SERVICE ~T LE~T 3 T~ES. I~ICATE DATES &~MES OF SER~CE ATTEMPED. NOT SERVED On the day of ,200__, at __ o'clock __.m., Defendant NOT FOUND because: Moved Unknown No Answer Other: Sworn to and subscribed before me this __ day of ,200 _. Notary: By: Attorney for Plaintiff Frank Federman, Esquire - I.D. No. 12248 One Penn Center at Suburban Station 1617 John F. Kennedy Boulevard, Suite 1400 Philadelphia, PA 19103-1814 (215) $63-7000 PLAINTIFF DEFENDANT(S) AFFIDAVIT OF SERVICE COUNTRYWIDE HOME LOANS, INC. TIMOTHY S. CL[PPINGER TRACIE A. CLIPPINGER SERVE TIMOTHY S. CLIPPINGER AT 338 C STREET CARLISLE, PA 17013 CUMBERLAND COUNTY No. 01-6460 ACCT. #5909984 Type of Action - Notice of Sheriff's Sale Sale Date: JUNE 5, 2002 SERVED Served and made known to "-f~1~'4'~~ S, C(i(~9,/~K.,Defendant, onthe a~''/~ dayof~C ,2001, , Co~onweal~ of Pe~sylva~a, in the ~er descdbed below: Defendant perso~lly se~ed. ~Adult fa~ly me~er with whom Defendant(s)reside(s). Relations~p is ~eK [~ ~. Adult in charge of Defendant(s)'s residence who reused to give name or relationsMp. Manager/Clerk of place of lodging in which Defendant(s) reside(s). Agent or person in ch~ge of Defendant(s)'s o~ce or usual place of bus,ess. ~ Other: an officer of said Defendant(s)'s company. D ' ' ~ ~ // escnpt, on: Age,~ ffeightff~ Weight~-Race~ SexE O~er 5~e~- g y m accordM to I w ~nd co~c~~u't' ~mg ~ly s~m~ ~ ~ . a , ~epose ~d. smte ~at I personally handed me aa~ess Maicam,~~~~Z~,~, .n hereto, ~ssued m ~e eaptmned case on the date and at swo= I bef~e me this. 3 t ' [~~~a ~ PLEASE ATTEMPT SERVICE AT LEAST 3 TI~E~ ...... 7-- - ~ ~ ' o. ~n~LAI~ DA~S & T~ES OF ATTEMPED. NOT SER~D On the day of. _, 200~, at ~ o'clock ~.m., Defendant NOT FOUND because: Moved _ U~o~ _ No Answer ~ Vacant Other: Sworn to and subscribed before me this. day of ,200 _. Notary: By: Attorne for Plaintiff Frank Federman, Esquire - I.D. No. 12248 One Penn Center at Suburban Station 1617 John F. Kennedy Boulevard, Suite 1400 Philadelphia, PA 19103-1814 (215) 563-7000 IN THE COURT OF COMMON PLEAS OF CUMBERLAND COUNTY, PENNSYLVANIA RE: COUNTRYWIDE HOME LOANS, INC. ) ) CIVIL ACTION VS. TIMOTHY S. CLIPPINGER TRACIE a. CLIPPINGER CIVIL DIVISION NO. 01-6460 AFFIDAVIT OF SERVICE PURSUANT TO RULE 3129 COMMONWEALTH OF PENNSYLVANIA ) COUNTY OF CUMBERLAND ) SS: I, FRANK FEDERMAN, ESQUIRE attorney for COUNTRYWIDE HOME LOANS, INC. hereby verify that on 12/21101 true and correct copies of the Notice of Sheriff's sale were served by certificate of mailing to the recorded lienholders, and any known interested party see Exhibit "A" attached hereto. Notice of Sale was sent to the Defendant(s) on 12121101 by certified mail return receipt requested see Exhibit "B" attached hereto. DATE: April 29, 2002 FRANK FEDERMAN, ESQUIRE Attorney for Plaintiff 71603901 9844 6532 0600 TO: TIMOTHY S. CLIPPINGER 338 C STREET CARLISLE, PA ~7013 SENDER: JPG REFERENCE: SALES(CLIPPINGER) PS Form 3800, June 2000 RETURN [Postage .34 i 71E0 3901 9844 6532 0662 RECEIPT [ Certified Fee 1.90 SERVICE / Return Receipt Fee 1.50 [ Restricted Delivery . 3.~0 I TO: TRACIE A. CLIPPINGER / Tctel Po~Qe &Fees ~"~ ~4 i 338 C STREET CARLISLE, PA '17013 .ece,., or Certified Mail No Insurance Coverage provided jp~j Do Not Use for International Mail ............................................................................................... f REFERENCE: SALES(CLIPP1NGER) i PS Form 3800~ June 2000 iRETUR.I Po~g~ RECEIPT ~- ...... I SERVICE [ ~enmecl I-ee I 19{1 ! ~ netu~ n~ipt Fee i / Restricted Delivery / -- i Receipt for ! Certified Mail NO h3surarlce Coverage Provided ~ Do Not Use for International Mail ............................................... STATE OF PENNSYLVANIA, COUNTY OF CUMBERLAND ss. Robert: p Ziegler ...................................... Recorder of Deeds {n and for said County and State do'hereby certify that the SherlfPs Deed in which Countrywide Home Loans In¢ ................ ·- ...................................... /s the grantee the Same having been sold to said grantee un the Sth Sune 02 .................. day of ........................................ A. D., ~ ..... , under an/1 ~yc virtue of a writ .............. EXecution issued on thc day of December ........................... A.D., O1 Civil ..... ~ out of the Cou~ of ConUnan Pie. az of said County~ of ' 6460 ....................................... Term, ' O1 Number ..... , at the suit of Countrywide Home Loans Inc i//j/_-_-_-.- .... .................................................... ............. Timothy S Clippin~er & - - ............... against ......... o Tracze A duly recorded in Sheriff's Deed Boo 252 .......................... is kNo ............. , Page ......... _1=6.1. 8 IN TESTIMoNy WHEREOF, I have hereunto set m/y/land and seal of said office this t _~_C__ _.' ._--~_ ___ __ day ..... Countrywide Home Loans, Inc. VS Timothy S. Clippinger and Tracie A. Clippinger In The Court of Common Pleas of Cumberland County, Pennsylvania Writ No. 2001-6460 Civil Term Michael Barrick, Deputy Sheriff, who being duly sworn according to law, states that on February 25, 2002 at 9:13 o'clock am, EST, he served a true copy of the within Real Estate Writ, Notice and Description, in the above entitled action, upon the within named defendant, to wit: Timothy S. Clippinger, by making known unto Jacqueline Skeel, mother-in-law of defendant, at 338 C Street, Carlisle, Cumberland County, Pennsylvania, its contents and at the same time handing to her personally the said tree and correct copy of the same. Michael Barrick, Deputy Sheriff, who being duly sworn according to law, states that on February 25, 2002 at 9:13 o'clock am, EST, he served a tree copy of the within Real Estate Writ, Notice and Description, in the above entitled action, upon the within named defendant, to wit: Tracie A. Clippinger, by making known unto Jacqueline Skeel, mother of defendant, at 338 C Street, Carlisle, Cumberland County, Pennsylvania, its contents and at the same time handing to her personally the said true and correct copy of the same. Gerald Worthington, Deputy Sheriff,who being duly sworn according to law, states that on April 5, 2002 at 2:57 o'clock p M., E.S.T., he posted a true copy of the within Real Estate Writ, Notice, Poster and Description, in the above entitled action, upon the property of Timothy S. Clippinger and Tracie A. Clippinger located at 338 C Street, Carlisle, Pennsylvania, according to law. R. Thomas Kline, Sheriff, who being duly sworn according to law says 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 one of the within named defendants to wit: Timothy S. Clippinger, by regular mail to his last known address of 338 C. Street, Carlisle, PA 17013. This letter was mailed under the date of April 04, 2002 and never returned to the SherifFs Office. R. Thomas Kline, Sheriff, who being duly sworn according to law says 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 one of the within named defendants to wit: Tracie A. Clippinger, by regular mail to her last known address of 338 C. Street, Carlisle, PA 17013. This letter was mailed under the date of April 04, 2002 and never returned to the SherifFs Office. R. Thomas Kline, Sheriff, who being duly sworn according to law, says that after due aTn. d legal notice had been given according to law, exposed the within described premises at public venue or outcry at the Court House, Carlisle, Cumberland County, Pennsylvania, on June 5, 2002 at I0:00 o'clock A.M.. He sold the same for the sum of $1.00 to Attorney Frank Federman for Countywide Home Loans, Inc.. It being the highest bid and best price received for the same, Countrywide Home Loans, Inc. of 7105 Corporate Drive, PTX-B35, Plano, TX 72024, being the buyer in this execution, paid Sheriff R. Thomas Kline the sum of $654.17, it being costs. Sheriff's Costs: Docketing $30.00 Poundage 12.83 Posting Bills 15.00 Advertising 15.00 Acknowledging Deed 30.00 Auctioneer 10.00 Law Library .50 Prothonotary 1.00 Mileage 6.90 Certified Mail .84 Levy 15.00 Surcharge 30.00 Law Journal 232.85 Patriot News 174.55 Share of Bills 25.20 Distribution of Proceeds Sheriff's Deed 25.00 29.5Q $654.17 paid by attorney 06/19/2002 Sworn and subscribed to before me This _!~t ~ day of~t.d~ 1 2002, A.D. · Prothonotary SoAn~r:. R. Thomas Kline, Sheriff Real Esta/c~Deputy - COUNTRYWIDE HOME LOANS, INC. Plaintiff, TIMOTHY S. CLIPPINGER TRACIE A. CLIPPINGER Defendant(s). CUMBERLAND COUNTY COURT OF COMMON PLEAS CIVIL DIVISION NO. 01-6460 AFFIDAVIT PURSUANT TO RULE 3129 (Affidavit No. 1) COUNTRYWIDE HOME LOANS~ INC., Plaintiff in the above action, by its attorney, FRANK FEDERMAN, ESQUIRE, sets forth as of the date the Praecipe for the Writ of Execution was filed the following information concerning the real property located at ~338 C STREET~ CARLISLE~ PA 17013 1. Name and address of Owner(s) or reputed Owner(s): Name Last Known Address (if address cannot be reasonably ascertained, please indicate) TIMOTHY S. CL1PPINGER 338 C STREET CARLISLE, PA 17013 TRACIE A. CLIPPINGER 338 C STREET CARLISLE, PA 17013 2. Name and address of Defendant(s) in the judgment: TIMOTHY S. CLIPPINGER 338 C STREET CARLISLE, PA 17013 TRACIE A. CLIPPINGER 338 C STREET CARLISLE, PA 17013 3. Name and last known address of every judgment creditor whose judgment is a record lien on the real property to be sold: Narfle Last Known Address (if address cannot be reasonably ascertained, please indicate) None. 4 '.4ame and address of tast recorded holder of every mortgage of record: Name Last Known Address (if address cannot be reasonably ascertained, please indicate) IRWIN L~'q'ION BANK AND TRUST COMPANY 500 WASHINGTON STREET COLUMBUS, INDIANA 47201 5. Name and address of every other person who has any record lien on the property: Name Last Known Address (if address cannot be reasonably ascertained, please indicate) None. 6. Name and address of every other person who has any record interest in the property and whose interest may be affected by the sale. Name None. Last Known Address (if address cannot be reasonably ascertained, please indicate) 7. Name and address of every other person of whom the plaintiff has knowledge who has any interest in the property ~vhich may be affected by the sale: Name Tenant/Occupant Domestic Relations of Cumberland County Commonwealth of Pennsylvania Department of Welfare Last Known Address (if address cannot be reasonably ascertained, please indicate) 338 C STREET CARLISLE, PA 17013 13 North Hanover Street Carlisle, PA 17013 PO Box 2675 Harrisburg, PA 17105 I verify that the statements made in this affidavit are true and correct to the best of my personal knowledge or information and belief. I understand that false statements herein are made subject to the penalties of 18 Pa. C.S. Sec. 4904 relating to unsworn falsification to authorities. December 20, 2001 ~-~/ DATE FRANK FEDERMAN, ESQUIRE Attorney for Plaintiff COUNTRYWIDE HOME LOANS, INC. Plaintiff, TIMOTHY S. CLIPPINGER TRACIE A. CLIPPINGER Defendant(s). TO: TIMOTHY S. CLIPPINGER 338 C STREET CARLISLE, PA 17013 CUMBERLAND COUNTY No. 01-6460 December 20, 2001 TRACIE A. CLIPPINGER 338 C STREET CARLISLE, PA 17013 **THIS FIRM IS A DEBT COLLECTOR ATTEMPTING TO COLLECT A DEBT AND ANY INFOR~ATION OBTAINED WILL BE USED FOR THAT PURPOSE. IF YOU HA VE PREVIOUSLY RECEIVED ,4 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 PROPERTE ** Your house (real estate) at, 338 C STREET~ CARLISLE~ PA 17013, is scheduled to be sold at the Sheriff's Sale on JUNE 5~ 2002 at 10:00 a.m. in the Cumberland County Courthouse, South Hanover Street, Carlisle, PA 170 l 3, to enforce the court.judgment of 7Z480.92 obtained by COUNTRYWIDE HOME LOANS I__~.[~NC. (the mortgagee) against you. If the Sheriff's sale is postponed, the property will be relisted for the SEPTEMBER 4, 2002 Sheriff's Sale. NOTICE OF OWNER'S RIGHTS YOU MAY BE ABLE TO PREVENT THIS SHERIFF'S SALE To prevent this Sheriff's 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 ho~v much you must pay, you may call: (215) 563-7000. You may be able to stop the sale by filing a petition asking the Court to strike or open the judgment, if the judgment was improperly entered. You may also ask the Court to postpone the sale for good cause. You may also be able to stop the sale through other legal proceedings. You may need an attorney to assert your rights. The sooner you contact one, the more chance you will have of stopping the sale. (See notice on page two on how to obtain an attorney.) YOU MAY STILL BE ABLE TO SAVE YOUR PROPERTY AND YOU HAVE OIHER RIGHTS EVEN IF 'IHE 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 Sheriffgives a deed to the buyer. At that time, the buyer may bring legal proceedings to evict you. 6. You may be entitled to a share of the money which was paid for your house. A schedule of distribution of the money bid for your house will be filed by the Sheriffwithin 30 days of the sale. This schedule will state who will be receiving that money. The money will be paid out in accordance with this schedule unless exceptions (reasons why the proposed distribution is wrong) are filed with the Sheriffwithin ten (10) days after the distribution is filed. 7. You may also have other rights and defenses, or ways of getting your home back, if you act immediately after the sale. YOU SHOULD TAKE THIS PAPER TO YOUR LAWYER AT ONCE. IF YOU DO NOT HAVE A LAWYER OR CANNOT AFFORD ONE, GO TO OR TELEPHONE THE OFFICE LISTED BELOW TO FIND OUT WHERE YOU CAN GET LEGAL HELP. CUMBERLAND COUNTY ATTORNEY REFERRAL CUMBERLAND COUNTY BAR ASSOCIATION 2 LIBERTY AVENUE CUMBERLAND COUNTY COURTHOUSE CARLISLE, PA 17013 (717) 249-3166 (800) 990-9108 LEGAL D E,5 c1LD~IO N - ~, Ol ,-- . Cumbedr-,:c ALL ~2,a~ :,er.an tract of t~n~ w~ ~e ~mprav¢ n Count7, p-nn'"" ama bound~ and de%db~ ~s follows: welt ~d [ebeccx E. Browna~C[1. ~nd on rb~ ~es, ay ~stbyprope~yn°w°r ormer.7~' , _ ' ". · On ~c No~h b~ "C" S:r~t; on ~c by pro~¢7 aow or [c~eriy of ~w~d Browna "C" Stree[ of 48.~5 feet and on now or former v o~ S. L. Dwen. smd lot having a fron~ge on Nos, 37 and 38 B ccx ..... ~t C~tist¢, z9.95 feet. ~nd a depth of [0t.40 f~t and being made up of ~ of Lots [mprevement Compan*, and being '~nown a~ 338 C St, C~[is[e ~nd and ' BEING ~e ~me premiss which ~ymond C. ~bh '1[ and Debor~ .k. ~bb. his wire, by ,,he,r Deed Novem~r 3, t994 ~d r~or~ November 4, 1994 in ~c Office of fe R~or~er of D~ds of Camber~anc A. ~bb. hng[e man, Grantor Coun~ in D~ ~k [14, Page 563, gmat~ and con~ef~ unto Joha WRIT OF EXECUTION and/or ATTACHMENT COMMONWEALTH OF PENNSYLVANIA) COUNTY OF CUMBERLAND) TO THE SHERIFF OF -- - OUMBE RIBAND- _ COUNTY: To salisfy the debl. inlerest and cosls due Countrya~.id_e~ ~o~ _Loans Inc. NO 01-6460 CIVIL 19 CIVIL ACTION _ LAW trom Timothy S. and Tract A. Clippinger, -PLAINTIFF(S) 338 C. St Carlisle PA 17013. -DEFENDANT(S) (t) You are directed to levy upon the properly of the defendant(s) and to sell Real es ta~:e '],oeated at 338 C St.~rlisle PA 17013. (See attached l~tion.) (2) You are also directed lo attach the property of the defendant(s) riel 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/are enjoined from paying any debt to or for lhe account of the defendant(s) and from delivering any property of the defendant(s) or Othen~vise disposing thereof; (3) It property of the defendant(s) not levied upon an subject to altachment is found in lhe POssession o~' anyone other ts~;.nec~.named garnishee, you are directed to notify him/herthat he/she has been added as a garnishee and is enjoined as above Amount Due .$77,480.92 LL $.50 Inlerest 12/20/01 - 6/5/02 $2,486.63 Atty's Corem · per ~-em Due Prothy $1.00 % Atly Paid $119.25 ~_ Other Costs Plaintiff Paid Date: December 31, 2001 by REQUESTING PARTY: Name Frank Federman, Esq. Address: 1617 JFK Blvd., Ste 1400 Philadelphia PA 19103 1814 Ailorney tot: Plaintiff Telephone:__~_215) 563 7000 Supreme Court ID No. 12248 CURTIS R. LQNG Prothonotary, Civil Division k.J ~/ Deputy I~EAL ESTATE SALE No, ~- On February 6, 2002, the sheriff levied upon the defendant's interest in the real property situated in Borough of Carlisle, Cumberland County, PA, known and numbered as 338 C Street, Carlisle, and more fully described on Exhibit "A" filed with this writ and by this reference incorporated herein. Date: February 6, 2002 By: Real Estate Deputy PROOF OF PUBLICATION OF NOTICE IN CUMBERLAND LAW JOURNAL (Under Act No. 587, approved May 16, 1929), P. L.1784 STATE OF PENNSYLVANIA : ; SS. COUNTY OF CUMBERLAND : Roger M. Morgenthal, Esquire, Editor of thc Cumberland Law Journal, of the County and State aforesaid, being duly sworn, according to law, deposes and says that the Cumberland Law Journal, a legal periodical published in the Borough of Carlisle in the County and State aforesaid, was established January 2, 1952, and designated by the local courts as the official legal periodical for the publication of all legal notices, and has, since January 2, 1952, been regularly issued weekly in the said County, and that the printed notice or publication attached hereto is exactly the same as was printed in the regular editions and issues of the said Cumberland Law Journal on the following dates, viz: APRIL 26, MAY 3, 10, 2002 Affiant further deposes that he is authorized to verify this statement by the Cumberland Law Journal, a legal periodical of general circulation, and that he is not interested in the subject matter of the aforesaid notice or advertisement, and that all allegations in the foregoing statements as to time, place and character of publication are true. REAL ESTATE SALE NO. 12 Writ No. 2001 6460 Civil Countrywide Home LoaI~s, Inc. VS. Timothy S. Clipplnger and Tracie A. Clipplnger Atty.: Frank Federman LEGAL DESCRIPTION ALL that certain tract of larval with the improvements thereon situate in the Borough of Carlisle, cumber- land County, PermsylvaI~ia, bound- ed and described os follows: On the North by 'C' Street; on the East by property now or for- merly of Carlisle Trust Company; on the South by property now or for- merly of Edward Brownawell and Rebecca E. Brownawell; and on the West by property now or formerly of S. L. Diven, Said lot having a frontage on 'C' Street of 48.85 feet ~genthal, Edit SWORN TO AND SUBSCRIBED before me this 10 .day of MAY, 2002 THE PATRIOT NEWS THE SUNDAY PATRIOT NEWS Proof of Publication UnderAct No. 587, Approved May16, 1929 Commonwealth of Pennsylvania, County of Dauphin} ss Frank J. Epler being duly sworn according to law, deposes and says: That he is the Controller of The Patriot News Co., a corporation organized and existing under the laws of the Commonwealth of Pennsylvania, with its principal office and place of business at 812 to 818 Market Street, in the City of Harrisburg, County of Dauphin, State of Pennsylvania, owner and publisher of The Patriot-News and The ~0pdav 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 23rd and 30th day(s) of April 2002 and the 7th day(s) of May 2002. That neither he nor said Company is interested in the subject matter of said printed notice or advertising, and that all of the allegations of this statement as to the time, place and character of publication are true; and That he has personal knowledge of the facts aforesaid and is duly authorized and empowered to verify this statement on behalf of The Patriot-News Co. aforesaid by virtue and pursuant to a resolution unanimously passed and adopted severally by the stockholders and board of directors of the said Company and subsequently duly recorded in the office for the Recording of Deeds in and for said County of Dauphin in Miscellaneous Book "M", Volume 14, Page 317. PUBLICATION COPY SALE #12 CUMBERLAND COUNTY SHERIFFS OFFICE CUMBERLAND COUNTY COURTHOUSE CARLISLE, PA. 17013 Statement of Advertising Costs To THE PATRIOT-NEWS CO., Dr. For publishing the notice or publication attached hereto on the above stated dates Probating same Notary Fee(s) Total $ 172.80 $ 1.75 $ 174.55 Publisher's Receipt for Advertising Cost , publisher of The Patriot-News and The Sunday Patriot-News, newspapers of general e receipt of the aforesaid notice and publication costs and certifies that the same have