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HomeMy WebLinkAbout04-2196FEDERMAN AND PHELAN, LLP By: FRANK FEDERMAN, ESQ., Id. No. 12248 LAWRENCE T. PHELAN, ESQ., Id. No. 32227 FRANCIS S. HALLINAN, ESQ., Id. No. 62695 ONE PENN CENTER PLAZA, SUITE 1400 PHILADELPHIA, PA 19103 (215) 563-7000 FEDERAL NATIONAL MORTGAGE ASSOCIATION 3415 VISION DRIVE COLUMBUS, OH 43219 Plaintiff V. RICHARD J. GORDON 836 MEADOW LANE CAMP HILL, PA 17011 PATRICIA A. GORDON 836 MEADOW LANE CAMP HILL, PA 17011 ATTORNEY FOR PLAINTIFF COURT OF COMMON PLEAS CIVIL DIVISION TERM NO. OW -a14L et- uL??_- l CUMBERLAND COUNTY Defendant(s) CIVIL ACTION - LAW COMPLAINT IN MORTGAGE FORECLOSURE NOTICE You have been sued in court. If you wish to defend against the claims set forth in the following pages, you must take action within twenty (20) days after this complaint and notice are served, by entering a written appearance personally or by attorney and filing in writing with the court your defenses or objections to the claims set forth against you. You are warned that if you fail to do so the case may proceed without you and a judgment may be entered against you by the court without further notice for any money claimed in the complaint or for any other claim or relief requested by the plaintiff. You may lose money or property or other rights important to you. YOU SHOULD TAKE THIS PAPER TO YOUR LAWYER AT ONCE. IF YOU DO NOT HAVE A LAWYER, GO TO OR TELEPHONE THE OFFICE SET FORTH BELOW. THIS OFFICE CAN PROVIDE YOU WITH INFORMATION ABOUT HIRING A LAWYER. IF YOU CANNOT AFFORD TO HIRE A LAWYER, THIS OFFICE MAY BE ABLE TO PROVIDE YOU WITH INFORMATION ABOUT AGENCIES THAT MAY OFFER LEGAL SERVICES TO ELIGIBLE PERSONS AT A REDUCED FEE OR NO FEE. Lawyer Referral Service Cumberland County Bar Association 32 South Bedford Street Carlisle, PA 17013 (800)990-9108 File #: 88634 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. IF YOU HAVE FILED BANKRUPTCY AND RECEIVED A DISCHARGE, THIS IS NOT AN ATTEMPT TO COLLECT A DEBT. IT IS AN ACTION TO ENFORCE A LIEN ON REAL ESTATE. File k 88634 Plaintiff is FEDERAL NATIONAL MORTGAGE ASSOCIATION 3415 VISION DRIVE COLUMBUS, OH 43219 The name(s) and last known address(es) of the Defendant(s) are: RICHARD J. GORDON 836 MEADOW LANE CAMP HILL, PA 17011 PATRICIA A. GORDON 836 MEADOW LANE CAMP HILL, PA 17011 who is/are the mortgagor(s) and real owner(s) of the property hereinafter described. On 12/22/2000 mortgagor(s) made, executed and delivered a mortgage upon the premises hereinafter described to FLAGSTAR BANK, FSB which mortgage is recorded in the Office of the Recorder of CUMBERLAND County, in Mortgage Book No. 1676, Page 1144. By Assignment of Mortgage recorded 4/22/2002 the mortgage was assigned to PLAINTIFF which Assignment is recorded in Assignment of Mortgage Book No. 686, Page 2830. 4. The premises subject to said mortgage is described as attached. 5. The mortgage is in default because monthly payments of principal and interest upon said mortgage due 12/01/2003 and each month thereafter are due and unpaid, and by the terms of said mortgage, upon failure of mortgagor to make such payments after a date specified by written notice sent to Mortgagor, the entire principal balance and all interest due thereon are collectible forthwith. File #: 88634 The following amounts are due on the mortgage: Principal Balance $132,092.30 Interest 5,482.12 11/01/2003 through 05/14/2004 (Per Diem $27.97) Attorney's Fees 1,250.00 Cumulative Late Charges 92.12 12/22/2000 to 05/14/2004 Cost of Suit and Title Search $ 550.00 Subtotal $ 139,466.54 Escrow Credit 0.00 Deficit 359.50 Subtotal $ 359.50 TOTAL $ 139,826.04 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 Sheriff s Sale. If the Mortgage is reinstated prior to the Sale, reasonable attorney's fees will be charged. Notice of Intention to Foreclose as set forth in Act 6 of 1974, Notice of Homeowner's Emergency Assistance Program pursuant to Act 91 of 1983, as amended in 1998, and/or Notice of Default as required by the mortgage document, as applicable, have been sent to the Defendant(s) on the date(s) set forth thereon, and the temporary stay as provided by said notice has terminated because Defendant(s) has/have failed to meet with the Plaintiff or an authorized consumer credit counseling agency, or has/have been denied assistance by the Pennsylvania Housing Finance Agency. This action does not come under Act 6 of 1974 because the original mortgage amount exceeds $50,000. WHEREFORE, PLAINTIFF demands an in rem Judgment against the Defendant(s) in the sum of $ 139,826.04, together with interest from 05/14/2004 at the rate of $27.97 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. FEDERMA AND PPHELAN By: /s/4 cis ' Hallinan FRANK FEDERMAN, ESQUIRE LAWRENCE T. PHELAN, ESQUIRE FRANCIS S. HALLINAN, ESQUIRE Attorneys for Plaintiff File #: 88634 LEGAL DESCRIPTION ALL THAT CERTAIN tract of land situate in Hampden Township shown as 95.08 feet to Lot No. 38 and 16.75 feet to Lot No. 40 on Plan of Brentwater, East Pennsboro and Hampden Township, Cumberland County, Pennsylvania, recorded in the Office of the Recorder of Deeds, Carlisle, Pennsylvania, in Plan Book No. 4, Page 93, bounded and described as follows, to wit: BEGINNING at a point on the center line of Meadow Lane at the intersection of the Western line of a five (5) foot wide path now or late of Harold A. Monaco, et ux; thence along the Western line of said path, South 12 degrees 13 minutes East, two hundred forty-three and eighty-one hundredths (243.80) feet, more or less, to the fence and property line of land now or late of Lawrence H. Walker, et ux; thence along said fence and property line, South 77 degrees 47 minutes West, one hundred eleven and eighty-three one hundredths (111.83) feet, more or less, to a point; thence North 12 degrees 13 minutes West, two hundred forty-three and eighty one hundredths (243.80) feet, more or less, to a point on the center line of Meadow Lane; thence North 77 degrees 47 minutes East, one hundred eleven and eighty-three one hundredths (111.83) feet, more or less, along said center line to the point of BEGINNING. CONSISTING of 95.08 feet of Lot #38 and eastern 16.75 feet of Lot #40. HAVING thereon erected a single brick and aluminum dwelling known and numbered as 836 Meadow Lane. BEING the same premises which William R. Green, single man, by deed dated October 16, 1975 and recorded in the Cumberland County Recorder's Office in Deed Book'Q, Volume 26, Page 17, granted and conveyed unto Shirley J. Green, Grantor herein. SUBJECT to restrictions as contained in prior deeds. File #: 88634 VERIFICATION Beth Mortis hereby states that he/she is AsWiANT SECRETARY of CHASE MANHATTAN MORTGAGE CORPORATION mortgage servicing agent for Plaintiff in this matter, that she is authorized to take this Verification, and that the statements made in the foregoing Civil Action are true and correct to the best of her knowledge, information and belief. The undersigned understands that this statement is made subject to the penalties of 18 Pa. C.S. Sec. 4904 relating to unswom falsification to authorities. DATE: 511-3101 Beth Morris 4&%S1 ANT SECRETARY Lei ? d ((JJ7 .J cr. C7 SHERIFF'S RETURN - REGULAR CASE NO: 2004-02196 P COMMONWEALTH OF PENNSYLVANIA: COUNTY OF CUMBERLAND FEDERAL NATIONAL MORTGAGE VS GORDON RICHARD J 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 GORDON RICHARD J the DEFENDANT , at 1938:00 HOURS, on the 20th day of May 2004 at 836 MEADOW LANE CAMP HILL, PA 17011 by handing to PATRICIA A GORDON, SPOUSE 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 10.35 .00 10.00 R. Thomas Kline .00 38.35 05/21/2004 FEDERMAN & PHELAN Sworn and Subscribed to before By: me this 24`% day of Z00(( A.D. Prothonor otas?y v?- l?/? Deputy Sheriff SHERIFF'S RETURN - REGULAR CASE NO: 2004-02196 P COMMONWEALTH OF PENNSYLVANIA: COUNTY OF CUMBERLAND FEDERAL NATIONAL MORTGAGE VS GORDON RICHARD J 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 GORDON PATRICIA A the DEFENDANT , at 1938:00 HOURS, on the 20th day of May 2004 at 836 MEADOW LANE CAMP HILL, PA 17011 by handing to PATRICIA A GORDON 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 Affidavit Surcharge So Answers: 6.00 .00 .00 ( 'T 10.00 R. Thomas Kline .00 16.00 06/21/2004 FEDERMAN & PHELAN Sworn and Subscribed to before By: me this a y ? day of c2 a 0-o Y A.D. 4 .lam n -)?0, / ! ProthonoMy4?a; Deputy Sherff FEDERMAN AND PHELAN, LLP By: FRANK FEDERMAN Identification No. 12248 Attorney for Plaintiff ONE PENN CENTER AT SUBURBAN STATION 1617 JOHN F. KENNEDY BLVD., SUITE 1400 PHILADELPHIA, PA 19103-1814 (215) 563-7000 FEDERAL NATIONAL MORTGAGE ASSOCIATION 3415 VISION DRIVE COLUMBUS, OH 43219 Plaintiff, V. CUMBERLAND COUNTY COURT OF COMMON PLEAS CIVIL DIVISION NO. 04-2196 CIVIL RICHARD J. GORDON PATRICIA A. GORDON Defendant(s). PRAECIPE FOR IN REM JUDGMENT FOR FAILURE TO ANSWER AND ASSESSMENT OF DAMAGES TO THE PROTHONOTARY: Kindly enter an in rem judgment in favor of the Plaintiff and against RICHARD J. GORDON and PATRICIA A. GORDON, Defendant(s) for failure to file an Answer to Plaintiffs Complaint within 20 days from service thereof and for Foreclosure and Sale of the mortgaged premises, and assess Plaintiffs damages as follows: As set forth in Complaint Interest from 5/15/04 to 6/29/04 TOTAL $139,826.04 1,286.62 $141,112.66 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. '41-0 q UA ? ffi-o rk? FRANK FEDERMAN, ESQUIRE Attorney for Plaintiff DAMAGES ARE HEREBY ASSESSED AS INDICATED. L n DATEs, I,L, y 1 10Gy 0-1t _,4? 1 PRO PROTHY "/FEDERMAN AND PHELAN, LLP FRANK FEDERMAN, ESQ., Id. No. 12248 LAWRENCE T. PHELAN, ESQ., Id. No. 32227 FRANCIS S. HALLINAN, ESQ., Id. No. 62695 ONE PENN CENTER PLAZA, SUITE 1400 PHILADELPHIA, PA 19103 (215) 561-7000 FEDERAL NATIONAL MORTGAGE ASSOCIATION Plaintiff Vs. RICHARD J. GORDON PATRICIA A. GORDON Defendants TO: RICHARD J. GORDON 836 MEADOW LANE CAMP HILL, PA 17011 DATE OF NOTICE:,HiNF. 10, 2004 ATTORNEY FOR PLAINTIFF : COURT OF COMMON PLEAS CIVIL DIVISION CUMBERLAND COUNTY NO. 04-2196 CIVEL TERM 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 OF LIEN AGAINST PROPERTY. IMPORTANT NOTICE YOU ARE IN DEFAULT BECAUSE YOU HAVE FAILED TO ENTER A WRITTEN APPEARANCE PERSONALLY OR BY ATTORNEY AND FILE IN WRITING WITH THE COURT YOUR DEFENSES OR OBJECTIONS TO THE CLAIMS SET FORTH AGAINST YOU. UNLESS YOU ACT WITHIN TEN DAYS FROM THE DATE OF THIS NOTICE, A JUDGMENT MAY BE ENTERED AGAINST YOU WITHOUT A HEARING AND YOU MAY LOSE YOUR PROPERTY OR OTHER IMPORTANT RIGHTS. YOU SHOULD TAKE THIS PAPER TO YOUR LAWYER AT ONCE. IF YOU DO NOT HAVE A LAWYER, GO TO OR TELEPHONE THE OFFICE SET FORTH BELOW. THIS OFFICE CAN PROVIDE YOU WITH INFORMATION ABOUT HIRING A LAWYER. IF YOU CANNOT AFFORD TO HIRE A LAWYER, THIS OFFICE MAY BE ABLE TO PROVIDE YOU WITH INFORMATION ABOUT AGENCIES THAT MAY OFFER LEGAL SERVICES TO ELIGIBLE PERSONS AT A REDUCED FEE OR NO FEE. CUMBERLAND COUNTY LAWYER REFERRAL SERVICE CUMBERLAND COUNTY BAR ASSOCIATION 32 SOUTH BEDFORD STREET CARLISLE, PA 17013 w Q (800)990-9108 O `1 \V- V NK FEDERMAN, ESQUIRE LAWRENCE T. PHELAN, ESQUIRE FRANCIS S. HALLINAN, ESQUIRE Attorneys for Plaintiff FEDERMAN AND PHELAN, LLP FRANK FEDERMAN, ESQ., Id. No. 12248 LAWRENCE T. PHELAN, ESQ., Id. No. 32227 FRANCIS S. HALLINAN, ESQ., Id. No. 62695 ONE PENN CENTER PLAZA, SUITE 1400 PHILADELPHIA, PA 19103 (215) 563-7000 FEDERAL NATIONAL MORTGAGE ASSOCIATION Plaintiff Vs. RICHARD J. GORDON PATRICIA A. GORDON Defendants TO: PATRICIA A. GORDON 836 MEADOW LANE CAMP HILL, PA 17011 DATE OF NOTICE: JUNF,10, 2004 ATTORNEY FOR PLAINTIFF COURT OF COMMON PLEAS. : CIVIL DIVISION CUMBERLAND COUNTY NO. 04-2196 CIVEL TERM THIS FIRM IS A DEBT COLLECTOR ATTEMPTING TO COLLECT A DEBT. THIS NOTICE IS SENT TO YOU IN AN ATTEMPT TO COLLECT THE INDEBTEDNESS REFERRED TO HEREIN, AND ANY INFORMATION OBTAINED FROM YOU WILL BE USED FOR THAT PURPOSE.IF YOU HAVE PREVIOUSLY RECEIVED A DISCHARGE IN BANKRUPTCY, THIS CORRESPONDENCE IS NOT AND SHOULD NOT BE CONSTRUED TO BE AN ATTEMPT TO COLLECT A DEBT, BUT ONLY AS ENFORCEMENT OF LIEN AGAINST PROPERTY. IMPORTANT NOTICE YOU ARE IN DEFAULT BECAUSE YOU HAVE FAILED TO ENTER A WRITTEN APPEARANCE PERSONALLY OR BY ATTORNEY AND FILE IN WRITING WITH THE COURT YOUR DEFENSES OR OBJECTIONS TO THE CLAIMS SET FORTH AGAINST YOU. UNLESS YOU ACT WITHIN TEN DAYS FROM THE DATE OF THIS NOTICE, A JUDGMENT MAY BE ENTERED AGAINST YOU WITHOUT A HEARING AND YOU MAY LOSE YOUR PROPERTY OR OTHER IMPORTANT RIGHTS. YOU SHOULD TAKE THIS PAPER TO YOUR LAWYER AT ONCE. IF YOU DO NOT HAVE A LAWYER, GO TO OR TELEPHONE THE OFFICE SET FORTH BELOW. THIS OFFICE CAN PROVIDE YOU WITH INFORMATION ABOUT HIRING A LAWYER. IF YOU CANNOT AFFORD TO HIRE A LAWYER, THIS OFFICE MAY BE ABLE TO PROVIDE YOU WITH INFORMATION ABOUT AGENCIES THAT MAY OFFER LEGAL SERVICES TO ELIGIBLE PERSONS AT A REDUCED FEE OR NO FEE. CUMBERLAND COUNTY LAWYER REFERRAL SERVICE CUMBERLAND COUNTY BAR ASSOCIATION 32 SOUTH BEDFORD STREET CARLISLE, PA 17013 (800)990-9108 PRANK FEDERMAN, ESQUIRE LAWRENCE T. PHELAN, ESQUIRE FRANCIS S. HALLINAN, ESQUIRE Attorneys for Plaintiff SHERTFF'S RETURN - REGULAR CASE NO: 2004-02196 P COMMONWEALTH OF PENNSYLVANIA: COUNTY OF CUMBERLAND FEDERAL NATIONAL MORTGAGE VS GORDON RICHARD J 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 GORDON RICHARD J the DEFENDANT , at 1938:00 HOURS, on the 20th day of May 2004 at 836 MEADOW LANE CAMP HILL, PA 17011 by handing to PATRICIA A GORDON, SPOUSE 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 10.35 Affidavit .00 Surcharge 10.00 .00 38.35 Sworn and Subscribed to before me this day of A. D. So Answers: R. Thomas Kline 05/21/2004 FEDERMAN & PHELANN By. ?/ //_ / e/ - Deputy Deputy Sheriff Prothonotary SHER_T,FF'S RETURN - REGULAR CASE NO: 2004-02196 P COMMONWEALTH OF PENNSYLVANIA: COUNTY OF CUMBERLAND FEDERAL NATIONAL MORTGAGE VS GORDON RICHARD J 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 GORDON PATRICIA A the DEFENDANT , at 1938:00 HOURS, on the 20th day of May 2004 at 836 MEADOW LANE CAMP HILL, PA 17011 by handing to PATRICIA A GORDON 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: So Answers: Docketing 6.00 Service 00 Affidavit .00 Surcharge 10.00 R. Thomas Kline .00 16.00 06/21/2004 FEDERMAN & PHELAN Sworn and Subscribed to before By: 4? me this day of Deputy Sher?ff A. D. Prothonotary ? ? ? r? ? C ,.,, ? ? <, ? W -? W ?, ? t ?- ?, ee ?. ?1?._ ` ?f- i?.= ?-?o ?? ?, - ?,:; _ . FEDERMAN and PHELAN, LLP By: FRANK FEDERMAN Identification No. 12248 ONE PENN CENTER AT SUBURBAN STATION 1617 JOHN F. KENNEDY BLVD., SUITE 1400 PHILADELPHIA, PA 19103-1814 (215) 563-7000 FEDERAL NATIONAL MORTGAGE ASSOCIATION 3415 VISION DRIVE Plaintiff, V. RICHARD J. GORDON PATRICIA A. GORDON Defendant(s). ATTORNEY FOR PLAINTIFF CUMBERLAND COUNTY COURT OF COMMON PLEAS CIVIL DIVISION NO. 04-2196 CIVIL VERIFICATION OF NON-MILITARY SERVICE FRANK FEDERMAN, ESQUIRE, hereby verifies that he is attorney for the Plaintiff in the above-captioned matter, and that on information and belief, he has 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 RICHARD J. GORDON is over 18 years of age and resides at, 836 MEADOW LANE, CAMP HILL, PA 17011. (c) that defendant PATRICIA A. GORDON is over 18 years of age, and resides at, 836 MEADOW LANE, CAMP HILL, PA 17011. This statement is made subject to the penalties of 18 Pa. C.S. Section 4904 relating to unsworn falsification to authorities. FRANK FEDERMAN, ESQUIRE Attorney for Plaintiff ? =.J ': 7 _- --1 f i'_ ?? _: C ?... ?-:C ?.:; _- Gp FEDERMAN and PHELAN, LLP By: FRANK FEDERMAN Identification No. 12248 ONE PENN CENTER AT SUBURBAN STATION 1617 JOHN F. KENNEDY BLVD., SUITE 1400 PHILADELPHIA, PA 19103-1814 (215) 563-7000 FEDERAL NATIONAL MORTGAGE ASSOCIATION Plaintiff, v. RICHARD J. GORDON PATRICIA A. GORDON Defendant(s). ATTORNEY FOR PLAINTIFF CUMBERLAND COUNTY COURT OF COMMON PLEAS CIVIL DIVISION NO. 04-2196 CIVIL CERTIFICATION FRANK FEDERMAN, ESQUIRE, hereby verifies that he is attorney for the Plaintiff in the above-captioned matter, and that the premises are not subject to the provisions of Act 91 because it is: ( ) an FHA mortgage ( ) non-owner occupied ( ) vacant (X) Act 91 procedures have been fulfilled This certification is made subject to the penalties of 18 Pa. C.S. Section 4904 relating to unsworn falsification to authorities. 1) n K_?Q r1o'Am0lx FRANK FEDERMAN, ESQUIRE Attorney for Plaintiff ?, ' c; s -- -r; ??, -.. ,,. >`: ?_ ??: 3 ' ? . PRAECIPE FOR WRIT OF EXECUTION - (MORTGAGE FORECLOSURE) P.R.C.P.3180-3183 FEDERAL NATIONAL MORTGAGE ASSOCIATION Plaintiff, V. No. 04-2196 CIVIL RICHARD J. GORDON PATRICIA A. GORDON Defendant(s). TO THE DIRECTOR OF THE OFFICE OF THE PROTHONOTARY: Issue writ of execution in the above matter: Amount Due Interest from 6/30/04 to DECEMBER 8, 2004 (per diem -$23.20) TOTAL $141,112.66 $1,624.00 and Costs $142,736.66 ,k?) n k ?p 60 -1 K-4,-o T?, FRANK FEDERMAN, ESQUIRE One Penn Center at Suburban Station 1617 John F. Kennedy Boulevard, Suite 1400 Philadelphia, PA 19103-1814 Attorney for Plaintiff Note: Please attach description of property.No. IMPORTANT NOTICE: This property is sold at the direction of the plaintiff. It may not be sold in the absence of a representative of the plaintiff at the Sheriff's Sale. The sale must be postponed or stayed in the event that a representative of the plaintiff is not present at the sale. oz z o ? Z U zz a o° w= a '?o oQ? o ?a tid ki?? OMU ?? 3 Co 00 F,O ?U a,p o p4A z? U Ow o U ?C U x W A WW w uu \ F r r?Q ^ ` C., t v?Q t4 t 1 1 1 1 \ a L' 0 o tq 0 0 `9 Q Z L9 rq Q Vj M Ll r7 g J?~ 0 d a a a x w U W z a O A M b d a? a N 1 M ? J ALL THAT CERTAIN tract or land situate in Hampden Township shown as 95.08 feet to l.e( No. 38 and 16.75 feet to 1.41 No, 40 on Plan of Brcutwater. Ernst Penwboro and Hampdca Township, Cumbetlaod County, Pennsylvania, recorded in the Office of the Recorder of Deeds, Carlisle, Pennsylvania, in Plan Book No. 4, Page 93, bounded and described as follows, to wit: BEGINNING at a point on the center line of Meadow Lane at the intersection of the Western line of a five (5) fort wile path now or late of Harold A. Monaco, et ax; thence along the Western line of said path, South 12 degrees 13 mires= East, two hundred forty-three and eighty one hundredths (243.80) feet, more or less, to the fence and property line of land now or late of Lawreace H. Walker, et ux; theme along said fence and property line, South 77 degrees 47 minutes West, one hundred eleven and eighty-three one hundredths (111,83) feet, more or leas, to a point; thence North 12 degrees 13 minutes West, two hundred fumy-three and eighty one hundredths (243.80) feet, more or leas, to a point on the center line of Meadow Lana; thence North 77 degrees 47 minutes Cast, one hundred eleven and eighty- three one hundredths (111.83) feet, more or less, along said tenter lime to the point of beginning. CONSISTING of 95.08 fed of Lot #38 and Eastern 16.75 feet of Lot #40. HAVING thereon erected a single brick and aluminum dwtlting known and numbered as 836 Meadow Lane, Tax Parcel #10-18.1312.009 TITLE TO SAID PREMISES IS VB$TED IN Richard J. Gordon and Patricia A. Gordon, his wife by Deed from Shirley J. Green dated 101711976 and recorded 10/8!1976, in Deed Book V26, Page 526. WRIT OF EXECUTION and/or ATTACHMENT COMMONWEALTH OF PENNSYLVANIA) COUNTY OF CUMBERLAND) NO 04-2196 Civil CIVIL ACTION - LAW TO THE SHERIFF OF CUMBERLAND COUNTY: To satisfy the debt, interest and costs due FEDERAL NATIONAL MORTGAGE ASSOCIATION, Plaintiff (s) From RICHARD J. GORDON AND PATRICIA A. GORDON (1) You are directed to levy upon the property of the defendant (s)and to sell SEE LEGAL DESCRIPTION (2) You are also directed to attach the property of the defendant(s) not levied upon in the possession of GARNISHEE(S) as follows: and to notify the garnishee(s) that: (a) an attachment has been issued; (b) the garnishee(s) is enjoined from paying any debt to or for the account of the defendant (s) and from delivering any property of the defendant (s) or otherwise disposing thereof; (3) If property of the defendant(s) not levied upon an subject to attachment is found in the possession of anyone other than a named garnishee, you are directed to notify him/her that he/she has been added as a garnishee and is enjoined as above stated. Amount Due $141,112.66 L.L. $.50 Interest FROM 6/30/04 TO 12/8/04 (PER DIEM - $23.20) - $1,624.00 AND COSTS Atty's Comm % Arty Paid $136.35 Plaintiff Paid Date: JULY 14, 2004 (Seal) Due Prothy $1.00 Other Costs CURTIS R. LONG ProthonooJtary (' ?iy? `ByyX/ '0'xr , T , t' e-7/AJ'3Z' - REQUESTING PARTY: Name FRANK FEDERMAN, ESQUIRE Address: ONE PENN CENTER AT SUBURBAN STATION 1617 JOHN F. KENNEDY BOULEVARD, SUITE 1400 PHILADELPHIA, PA 19103-1814 Attorney for: PLAINTIFF Deputy Telephone: 215-563-7000 Supreme Court ID No, 12248 FEDERAL NATIONAL MORTGAGE ASSOCIATION Plaintiff, V. RICHARD J. GORDON PATRICIA A. GORDON Defendant(s). CUMBERLAND COUNTY COURT OF COMMON PLEAS CIVIL, DIVISION NO. 04-2196 CIVIL AFFIDAVIT PURSUANT TO RULE 3129 (Affidavit No. 1) FEDERAL NATIONAL MORTGAGE ASSOCIATION, 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, 836 MEADOW LANE, CAMP HILL, PA 17011. 1. Name and address of Owner(s) or reputed Owner(s): Name RICHARD J. GORDON PATRICIA A. GORDON Last Known Address (if address cannot be reasonably ascertained, please indicate) 836 MEADOW LANE CAMP HILL, PA 17011 836 MEADOW LANE CAMP HILL, PA 17011 2. Name and address of Defendant(s) in the judgment: Same as above 3. Name and last known address of every judgment creditor whose judgment is a record lien on the real property to be sold: Name Last Known Address (if address cannot be reasonably ascertained, please indicate) None 4. Name and address of last recorded holder of every mortgage of record: Name Last Known Address (if address cannot be reasonably ascertained, please indicate) HARRIS SAVINGS BANK 2ND AND PINE STREET HARRISBURG, PA 17101 5. Name and address of every other person who has any record lien on the property: Name Last Known Address (if address cannot be reasonably ascertained, please indicate) None 6. Name and address of every other person who has any record interest in the property and whose interest may be affected by the sale. Name Last Known Address (if address cannot be reasonably ascertained, please indicate) None 7. Name and address of every other person of whom the plaintiff has knowledge who has any interest in the property which may be affected by the sale: Name Last Known Address (if address cannot be reasonably ascertained, please indicate) Tenant/Occupant Domestic Relations of Cumberland County Commonwealth of Pennsylvania Department of Welfare 836 MEADOW LANE CAMP HILL, PA 17011 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 unworn falsification to authorities. July 12, 2004 ,A CIA k k k.LJtJ1 1 n Pk, DATE FRANK FEDERMAN, ESQUIRE Attorney for Plaintiff FEDERAL NATIONAL MORTGAGE ASSOCIATION Plaintiff, V. RICHARD J. GORDON PATRICIA A. GORDON Defendant(s). CUMBERLAND COUNTY No. 04-2196 CIVIL July 12, 2004 TO: RICHARD J. GORDON 836 MEADOW LANE CAMP HILL, PA 17011 PATRICIA A. GORDON 836 MEADOW LANE CAMP HILL, PA 17011 "THIS FIRM IS A DEBT COLLECTOR ATTEMPTING TO COLLECT A DEBT AND ANY INFORMATION OBTAINED WILL BE USED FOR THAT PURPOSE. IF YOUHAVE PREVIOUSLYRECEIVED A DISCHARGE IN BANKRUPTCYAND THIS DEBT WAS NOT REAFFIRMED, THIS IS NOT AND SHOULD NOT BE CONSTRUED TO BE ANA TTEMPT TO COLLECT A DEBT, BUT ONLY ENFORCEMENT OF A LIENAGAINST PROPERTY. * * Your house (real estate) at, 836 MEADOW LANE, CAMP HILL, PA 17011, is scheduled to be sold at the Sheriffs Sale on DECEMBER 8, 2004 at 10:00 a.m. in the Cumberland County Courthouse, South Hanover Street, Carlisle, PA 17013, to enforce the court judgment of $141,112.66 obtained by FEDERAL NATIONAL MORTGAGE ASSOCIATION (the mortgagee) against you. In the event the sale is continued, an announcement will be made at said sale in compliance with Pa.R.C.P., Rule 3129.3. NOTICE OF OWNER'S RIGHTS YOU MAY BE ABLE TO PREVENT THIS SHERIFF'S SALE To prevent this Sheriffs Sale, you must take immediate action: The sale will be cancelled if you pay to the mortgagee the back payments, late charges, costs and reasonable attorney's fees due. To find out how much you must pay, you may call: (215) 563-7000. 2. You may be able to stop the sale by filing a petition asking the Court to strike or open the judgment, if the judgment was improperly entered. You may also ask the Court to postpone the sale for good cause. 3. You may also be able to stop the sale through other legal proceedings. You may need an attorney to assert your rights, The sooner you contact one, the more chance you will have of stopping the sale. (See notice on page two on how to obtain an attorney.) YOU MAY STILL BE ABLE TO SAVE YOUR PROPERTY AND YOU HAVE OTHER RIGHTS EVEN IF THE SHERIFF'S SALE DOES TAKE PLACE. 1. If the Sheriffs Sale is not stopped, your property will be sold to the highest bidder. You may find out the price bid by calling (215) 563-7000. 2. You may be able to petition the Court to set aside the sale if the bid price was grossly inadequate compared to the value of your property. 3. The sale will go through only if the buyer pays the Sheriff the full amount due in the sale. To find out if this has happened, you may call (717) 240-6390. 4. If the amount due from the Buyer is not paid to the Sheriff, you will remain the owner of the property as if the sale never happened. 5. You have the right to remain in the property until the full amount due is paid to the Sheriff and the Sheriff gives a deed to the buyer. At that time, the buyer may bring legal proceedings to evict you. 6. You may be entitled to a share of the money which was paid for your house. A schedule of distribution of the money bid for your house will be filed by the Sheriff within 30 days of the sale. This schedule will state who will be receiving that money. The money will be paid out in accordance with this schedule unless exceptions (reasons why the proposed distribution is wrong) are filed with the Sheriff within ten (10) days after the distribution is filed. 7. You may also have other rights and defenses, or ways of getting your home back, if you act immediately after the sale. YOU SHOULD TAKE THIS PAPER TO YOUR LAWYER AT ONCE. IF YOU DO NOT HAVE A LAWYER OR CANNOT AFFORD ONE, GO TO OR TELEPHONE THE OFFICE LISTED BELOW TO FIND OUT WHERE YOU CAN GET LEGAL HELP. IMPORTANT NOTICE: This property is sold at the direction of the plaintiff. It may not be sold in the absence of a representative of the plaintiff at the Sheriffs Sale. The sale must be postponed or stayed in the event that a representative of the plaintiff is not present at the sale. CUMBERLAND COUNTY ATTORNEY REFERRAL CUMBERLAND COUNTY BAR ASSOCIATION 2 LIBERTY AVENUE CUMBERLAND COUNTY COURTHOUSE CARLISLE, PA 17013 (717) 249-3166 (800) 990-9108 ALL THAT CERTAIN tract of land situate in Hampden Township shown as 95.08 feet to IA( No. 38 and 16.75 feet to lot No, 40 on Plan of Brentwater, East Pennsboro and llampdcn Township, Cumberland County, Pennsylvania, recorded in the Office of the Recorder of Deeds, Carlisle, Pennsylvania, in Plan Book No. 4, Page 93, bounded and described as follows, to wit: BEGINNING at a pnint on the center line of Meadow Lane at file intetxectiun of the Wesem line of a five (5) foot wide path now or late of Ilarold A. Monaco, ei ux; thence along the Western line of said path. South 12 dogrecs 13 minnes Fast, two hundred forty-three and eighty one hundredths (243.80) feet, more or less, to the fence and property line of land now or late of Lawrence H. Walker, et ux; thence along said fence and property line, South 77 degrees 47 minutes West, one hundred eleven and eighty-throe one hundredths (i 11,83) feet, more or lest, to a point; thence North 12 degrees 13 minutes West, two hundred forty-three and eighty one hundredths (243.80) feet, more or less, to a point on the center line of Meadow lam; thence North 77 degrees 47 minutes East, one hundred eleven and eighty- three one hundredths (111.83) fed, more or less, along said oenter lice to the point of beginning. CONSISTING of 95.08 feet of Lot #38 and Eastern 16.75 feet of tut #40. HAVING thereon erected a single brick and aluminum dwelling known and numbered as $36 Meadow Lane. Tax parcel #10-18.1312-009 TITi.E TO SAID PREMISES IS VESTED IN Richard J. Gordon and Patricia A. Gordon, his wife by Deer) from Shirley J. Green dated 10/7/1976 and recorded 1018/1976, in Decd Book V26, Page 5245. -? N _] _' `1 1 (_. '_? ? I'l"1 _ ?\-? ... ? ...? l?a _• f l Y. it 2"-•\ _ Gr IN THE COURT OF COMMON PLEAS OF CUMBERLAND COUNTY, PENNSYLVANIA FEDERAL NATIONAL MORTGAGE ASSOCIATION Plaintiff VS. RICHARD J. GORDON PATRICIA A. GORDON Defendant(s) CIVIL ACTION NO. 04-2196 CIVIL TYPE OF PLEADING: Motion for Special Service. } Code and Classification 140 Civil Action Filed on behalf of Plaintiff PREMISES: 836 MEADOW LANE CAMP HILL, PA 17011 Counsel of Record for this Party: FRANK FEDERMAN, ESQ. -?A I.D. #12248 FEDERMAN & PHELAN One Penn Center at Suburban Station, Suite 1400 Philadelphia, PA, 19103-1814 FEDERMAN PHELAN By: FRANK FEDERMAN, ESQUIRE IDENTIFICATION NO. 12248 ONE PENN CENTER PLAZA, SUITE 1400 PHILADELPHIA, PA 19103 (215) 563-7000 ATTORNEY FOR PLAINTIFF COURT OF COMMON PLEAS CIVIL DIVISION FEDERAL NATIONAL MORTGAGE ASSOCIATION vs. RICHARD J. GORDON PATRICIA A. GORDON CUMBERLAND COUNTY No.: 04-2196 CIVIL MOTION FOR SERVICE PURSUANT TO SPECIAL ORDER OF COURT Plaintiff, by its counsel, Frank Federman, Esquire, move:, this Honorable Court for an Order directing service of the Notice of Sale upon the above captioned Defendant(s) by certified mail and regular mail to Defendant's last known address. 1. Attempts to serve Defendant with Notice of Sale have been unsuccessful, as indicated by the Affidavit of Service attached hereto as Exhibit "A." 2. Pursuant to Pennsylvania Rule of Civil Procedure 430, Plaintiff has made a good faith effort to locate the Defendant. An Affidavit of Good Faith Investigation setting forth the specific inquiries made and the result there from is attached hereto as Exhibit "B." WHEREFORE, Plaintiff respectfully requests this Honorable Court enter an Order pursuant to Pennsylvania Rule of Civil Procedure 430 directing service of the Notice of Sale by certified mail and regular mail to Defendant's last known address. 1 FRANK FEDERMAN, ESQUIRE ATTORNEY FOR PLAINTIFF FEDERMAN PHELAN By: FRANK FEDERMAN, ESQUIRE IDENTIFICATION NO. 12248 ONE PENN CENTER PLAZA, SUITE 1400 PHILADELPHIA, PA 19103 (215) 563-7000 FEDERAL NATIONAL MORTGAGE ASSOCIATION ATTORNEY FOR PLAINTIFF COURT OF COMMON PLEAS CIVIL DIVISION CUMBERLAND COUNTY , No.: 04-2196 CIVIL vs. RICHARD J. GORDON PATRICIA A. GORDON MEMORANDUM OF LAW Pennsylvania Rule of Civil Procedure 430(a) specifically provides: (a) If service cannot be made under the applicable rule, the plaintiff may move the Court for a special order directing the method of service. The Motion shall be accompanied by an Affidavit stating the nature and extent of the investigation which has been made to determine the whereabouts of the Defendant and the reasons why service cannot be made. Note: A Sheriffs return of "Not Found" or the fact that a Defendant has moved without leaving a new forwarding address is insufficient evidence of concealment. Gonzales vs. Polis, 238 Pa. Super. 362, 357 A.2d 580 (1976). "Notice of intended adoption mailed to last known address requires a good faith effort to discover the correct address." Adoption of Walker, 468 Pa. 165, 360 A.2d 603 (1976). An illustration of good faith effort to locate the defendant includes (1) inquires of postal authorities including inquiries pursuant to the Freedom of Inforination Act, 39 C.F.R. Part 265, (2) inquiries of relatives neighbors, friends and employers of the Defendant and (3) examinations of local telephone directories, voter registration records, local tax records, and motor vehicle records. As indicated by the attached Affidavit of Service, marked hereto as Exhibit "A", the Sheriff has been unable to serve the Notice of Sale. A good faith effort to discover the whereabouts of the Defendant has been made as evidenced by the attached Affidavit of Good Faith Investigation, marked Exhibit "B." WHEREFORE, Plaintiff respectfully requests service of the Notice of Sale by certified mail and regular mail to Defendant's last known address. Respectfully submitted: qjuonf. ,d ywaA- FRANK FEDERMAN, ESQUIRE ATTORNEY FOR PLAINTIFF AFFIDAVIT OF SERVICE PLAINTIFF FEDERAL NATIONAL MORTGAGE ASSOCIATION DEFENDANT(S) RICHARD J. GORDON PATRICIA A. GORDON SERVE PATRICIA A. GORDON AT 836 MEADOW LANE CAMP HILL, PA 17011 SERVED Served and made known to , 200_, at , o'clock _.m., at , Commonwealth of Pennsylvania, in the manner described below: ,--XLIIBIT A Defendant, on the day of Defendant personally served. Adult family member with whom Defendant(s) reside(s). Name and Relationship is _ Adult in charge of Defendant(s)'s residence who refused to give name or relationship. Manager/Clerk of place of lodging in which Defendant(s) reside(s). Agent or person in charge of Defendant(s)'s office or usual place of business. an officer of said Defendant(s)'s company. Other: Description: Age Height Weight Race; Sex Other I, a competent adult, being duly sworn according to law, depose and state that I personally handed a true and correct copy of the Notice of Sheriff's Sale in the manner as set forth herein, issued in the captioned case on the date and at the address indicated above. Sworn to and subscribed before me this day of , 200-. Notary: By: PLEASE ATTEMPT SERVICE AT LEAST 3 TIMES. INDICATE DATES & TIMES OF SERVICE ATTEMPTED. NOT SERVED On the 2 4 day of July , 200A, at 3 : 0 0 o'clock __.m, Defendant NOT FOUND because: Moved Unknown No Answer X Vacant: 1St Attempt: 07/ 23 2 0 0 4 Time: 5: 00 2nd Attempt: o7 /24 /200 4Time: 3.0 0 pm 3rd Attempt: Tim.e:_..___ _ N ,,auia'. Seal Sworn to and subscribed ,uly M. Livingston, Notary Public -,u,:jurhanna Twp.. Dauphin Cc=ur jy - - before me this day:: G?..tinission Expires Oct. 24, 2 . c•. of , 200 .... _ _., v _. ` Not By: Att ev for Plain Frank Federman, Esquire - I.D. No. 12248 CUMBERLAND COUNTY No. 04-2196 CIVIL ACCT. #1963562911 Type of Action - Notice of Sheriff's Sale PJT Sale Date: DECEMBER 8, 2004 AFFIDAVIT OF SERVICE CUMBERLAND COUNTY PLAINTIFF FEDERAL NATIONAL MORTGAGE PJT ASSOCIATION No. 04-2196 CIVIL DEFENDANT(S) RICHARD J. GORDON ACCT. #1963562911 PATRICIA A. GORDON Type of Action SERVE RICHARD J. GORDON AT - Notice of Sheriffs Sale 836 MEADOW LANE CAMP HILL, PA 17011 Sale Date: DECEMBER 8, 2004 SERVED v !T 01 Served and made known to , Defendant, on the day of , 200, at , o'clock _.m., at , Commonwealth of Pennsylvania, in the manner described below: Defendant personally served. Adult family member with whom Defendant(s) reside(s). Name and Relationship is Adult in charge of Defendant(s)'s residence who refused to give name or relationship. Manager/Clerk of place of lodging in which Defendant(s) reside(s). Agent or person in charge of Defendant(s)'s office or usual place of business. an officer of said Defendant(s)'s company. Other: Description: Age Height Weight Race _ Sex Other I, , a competent adult, being duly sworn according to law, depose and state that I personally handed a true and correct copy of the Notice of Sheriff's Sale in the manner as set forth herein, issued in the captioned case on the date and at the address indicated above. Sworn to and subscribed before me this day of 200. Notary: By: PLEASE ATTEMPT SERVICE AT LEAST 3 TIMES. INDICATE DATES & TIMES OF SERVICE ATTEMPTED. NOT SERVED On the ? t r day of July , 200 4, at 3 : 0 0 o'clock p.m., Defendant NOT FOUND because: Moved Unknown No Answer X Vacant 1 St Attempt: 0 7/ 2 3 /2 0 0 4Time: 5 : 0 0 2"d Attempt: 07 /24 2004 Time: 3: 00 p.m. 3rd Attempt: Notarial Seal Sworn to and subscrib Wendy M. Livingston, Notary Public rusquehanna Twp., Dauphin County before me this t- C t ,mission Expires Oct. 24, 2005 of 200 -_ -- - p Nota Attorn or Plainti Frank Federman, Esquire - I.D. No. 12248 y ? A SKN Data Research Inc. AFFIDAVIT OF GOOD FAITH INVESTIGATION File Number: 4-14123PA wutg1'j' e Attorney Firm: Federman & Phelan f?1 Subject: Richard J. Gordon & Patricia A. Gordon Current Address: 836 Meadow Ln. Camp Hill, PA 17011 Property Address: 836 Meadow Ln. Camp Hill, PA 17011 Mailing Address: 836 Meadow Ln. Camp Hill, PA 17011 I Scott Nulty, being duly sworn according to law, do hereby depose and state as follows, I have conducted an investigation into the whereabouts of the above-noted individual(s) and have discovered the following: 1. CREDIT INFORMATION A. SOCIAL SECURITY NUMBER Our search verified the following to be true and correct Richard J. Gordon -164-38-5856 Patricia A. Gordon -169-42-5615 B. EMPLOYMENT SEARCH A review of the credit reporting agencies provided no employment information. Richard J. Gordon - not available Patricia A. Gordon - not available C. INQUIRY OF CREDITORS Our inquiry of creditors indicated that Richard J. Gordon & Patricia A. Gordon reside(s) at: 836 Meadow Ln. Camp Hill, PA 17011 II. INQUIRY OF TELEPHONE COMPANY A. DIRECTORY ASSISTANCE SEARCH On 10/15/04 our office contacted directory assistance, which indicated that Richard J. Gordon & Patricia A. Gordon reside(s) at: 836 Meadow Ln. Camp Hill, PA 17011. Our office made a telephone call to the mortgagors phone number and received the following information: 717-761-0852 10/14 12:06p,10/15 9:33a. III. INQUIRY OF NEIGHBORS Our office attempted to contact E. Ruediger 834 Meadow Ln. 10/15 9:34a spoke with female who confirmed house is empty, they were not able to verify that Richard J. Gordon & Patricia A. Gordon reside(s) at: 836 Meadow Ln. Camp Hill, PA 17011 IV. ADDRESS INQUIRY A. NATIONAL ADDRESS UPDATE On 10/15/04 we reviewed the National Address database and found the following information, Richard J. Gordon & Patricia A. Gordon - 836 Meadow Ln. Camp Hill, PA 17011 B. ADDITIONAL ACTIVE MAILING ADDRESSES Per our inquiry of creditors , the following is a possible mailing address: no addresses on file V. DRIVERS LICENSE INFORMATION A. MOTOR VEHICLE & DMV OFFICE Per the PA Department of Motor Vehicles, we were unable to obtain address information on Richard J. Gordon & Patricia A. Gordon. VI. OTHER INQUIRIES DEATH RECORDS A. As of 10/15/04 Vital Records and all public databases have no death record on file for Richard J. Gordon & Patricia A. Gordon. HtBIN 6 B. COUNTY VOTER REGISTRATION The Cumberland County Voter registration was unable to confirm a registration for Richard J. Gordon & Patricia A. Gordon residing at: last registered address. VII. ADDITIONAL INFORMATION OF SUBJECT A. DATE OF BIRTH Richard J. Gordon -YOB 1947 Patricia A. Gordon -YOB 1951 B. A.K.A. none *All accessible public databases have been checked and cross-referenced for the above named individual(s). * Please be advised all database information indicates the subjects reside at the current address. The undersigned understands that this statement herein is made subject to the penalties of 18 Pa. C.S. Sec. 4904 relating to unsworn falsification to authorities. I hereby verify that the statements made herein are true and correct to the best of my knowledge, information and belief and that this affidavit of investigation is made subject to the penalties of 18 Pa. C.S. Sec. 4904 relating to unsworn falsification to authorities. AFFIANT Scott ulty SKN Data Research Inc. President Sworn to and subscribed before me this 1lp 0 day of lfie, Vc4t, 2004 T NOTARY . UBLIC Notarial Seat Margaret E. Nulhr, Notary Public East Goshen Twp., Chester County My Commission Expires Dec. 19, 2005 Member, Pennsylvania Association Of Notaries The above information is obtained from available public records and we are only liable for the cost of the affidavit VERIFICATION FRANK FEDERMAN, ESQUIRE, hereby states that lie is the Attorney for the Plaintiff in this action, that he is authorized to take this Affidavit, and that the statements made in the foregoing MOTION FOR SERVICE OF THE NOTICE OF SALE PURSUANT TO SPECIAL ORDER OF COURT are true and correct to the best of his knowledge, information and belief. The undersigned understands that this statement herein is made subject to the penalties of 18 Pa. C.S. Sec. 4904 relating to unworn falsification to authorities. A ! FRANK FEDERMAN, ESQUIRE ATTORNEY FOR PLAINTIFF FEDERMAN PHELAN By: FRANK FEDERMAN, ESQUIRE IDENTIFICATION NO. 12248 ONE PENN CENTER PLAZA, SUITE 1400 PHILADELPHIA, PA 19103 (215) 563-7000 FEDERAL NATIONAL MORTGAGE ASSOCIATION VS. RICHARD J. GORDON PATRICIA A. GORDON ATTORNEY FOR PLAINTIFF COURT OF COMMON PLEAS CIVIL DIVISION CUMBERLAND COUNTY No.: 04-2196 CIVIL CERTIFICATION OF SERVICE I, FRANK FEDERMAN, ESQUIRE, hereby certify that a copy of the Motion for Service Pursuant to Special Order of Court has been sent to the individuals indicated below on November 8, 2004. RICHARD J. GORDON PATRICIA A. GORDON 836 MEADOW LANE CAMP HILL, PA 17011 FRANK FEDERMAN, ESQUIRE Attorney for Plaintiff Date: November 8, 2004 ?? ?? ?? C? ?' a::'.? ..C:' ??? ....,{ „ ? . ? _! s Kw f .t r -r7 ` r7 ?i? ... 1 W - j CA7 C; ? i ?? ;`n ?? ?,'? C,i"! :.7 .i: IN THE COURT OF COMMON PLEAS OF CUMBERLAND COUNTY, PENNSYLVANIA FEDERAL NATIONAL MORTGAGE ASSOCIATION CIVIL ACTION vs. RICHARD J. GORDON PATRICIA A. GORDON CIVIL DIVISION NO. 04-2196 CIVIL AFFIDAVIT OF SERVICE PURSUANT 'TO RULE 3129 COMMONWEALTH OF PENNSYLVANIA ) COUNTY OF CUMBERLAND 1 SS: I, FRANK FEDERMAN, ESQUIRE attorney for FEDERAL NATIONAL MORTGAGE ASSOCIATION hereby verify that on 7/16/04 & 10/26/04 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. DATE: November 22, 2004 IA"k*m FRANK FEDERMAN, ESQUIRE Attorney for Plaintiff FEDERAL NATIONAL MORTGAGE ASSOCIATION Plaintiff, V. RICHARD J. GORDON PATRICIA A. GORDON Defendant(s). C04BERLAND COUNTY COURT OF COMMON PLEAS CIVIL DIVISION NCO. 04-2196 CIVIL AMENDED AFFIDAVIT PURSUANT TO RULE 3129 (Affidavit No. 1) FEDERAL NATIONAL MORTGAGE ASSOCIATION, 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, 836 MEADOW LANE, CAMP HILL, PA 17011. 1. Name and address of Owner(s) or reputed Owner(s): Name RICHARD J. GORDON PATRICIA A. GORDON Last Known Address (if address cannot be reasonably ascertained, please indicate) 836 MEADOW LANE CAMP HILL, PA 17011 836 MEADOW LANE CAMP BILL, PA 17011 2. Name and address of Defendant(s) in the judgment: Same as above 3. Name and last known address of every judgment creditor whose judgment is a record lien on the real property to be sold: Name Last Known Address (if address cannot be reasonably ascertained, please indicate) WAYPOINT BANK 235 NORTH 2ND STREET HARRISBURG, PA 17105-1711 4. Name and address of last recorded holder of every mortgage of record: Name Last Known Address (if address cannot be reasonably ascertained, please indicate) HARRIS SAVINGS BANK 2ND AND PINE STREET HARRISBURG, PA 17101 5. Name and address of every other person who has any record :lien on the property: Name Last Known Address (if address cannot be reasonably ascertained, please indicate) None 6. Name and address of every other person who has any record interest in the property and whose interest may be affected by the sale. Name Last Known Address (if address cannot be reasonably ascertained, please indicate) None 7. Name and address of every other person of whom the plaintiff has knowledge who has any interest in the property which may be affected by the sale: Name Last Known Address (if address cannot be reasonably ascertained, please indicate) Tenant/Occupant Domestic Relations of Cumberland County Commonwealth of Pennsylvania Department of Welfare 836 MEADOW LANE CAMP HILL, PA 17011 13 North Hanover Street Carlisle, PA 1.7013 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. November 22, 2004 q4zld V? DATE FRANK FEDERMAN, ESQUIRE Attorney for Plaintiff by O E z W N p ?O oo J O? c.n A W N ,-, r ?. r ci CD z c v ' eo ?03 0 0 o C 0 z 3 Z pFg z G 033 y ? O 6 Oro ? Y O C) ? tTj C1 z rr ° ? z o N o ? c z C7 7 y ?? b x ?El..o O p, p pp ? e O D = J \IILLL??lrrrlll O f.+ ?-+ O O O O N ~ ?.OO b O °, n r N NR o e cn H $r?? o C7 a S51 0. ?. Fg ^ ? i6 t? ? 0 s ?? A ? Fe J d Lf 6„ 5' ? o ^ ¦ 02 1„ ZO 0004300377 USA MAILED FROM, o?z "= y a ?0?3 C?r1 ? co d Ito lD > x R O? ? M o C1. 'r7. r'' LI C/? '.j b A ? O PITNEY 130YyE5 $ 01.200 JUL16 2004 DPCODE 19103 0 p1 CD ? N 00 W y ?3 aN cr o ?o xN? w w o' ? y o b O C/1 H z cD t t° H J (9 ro 0 r'b fD e' oc la-. Posr4Q r ? a N£ ES Q ~ • 90 04 4 26 00,311 v CODE 19ti 03 043 ` 30 Fgom z1 0 '*am ? y A7 "S a 0. ro e s c w G A H? O 0 C7? ? ?"? ? ? o c ,.? <?.? r -?, .T, ` M1 y ?,,,• ?... +? ("il ?' ' ` y to {?? `??" Lw? ? ?twl v ? .. ;,? ..+? ?? ti COMMONWEALTH OF PENNSYLVANIA COUNTY OF CUMBERLAND I SS: I, Robert P. Ziegler, Recorder of Deeds in and for said County and State do hereby certif the Sheriff's Deed in which Fannie Mae is the grantee the same having been sold to said grantee Pn the 8th day of December A.D., 2004, under and by virtue of a writ Execution issued on the 14th daypf July, A.D., 2004, out of the Court of Common Pleas of said County as of Civil Term, 2004 Number 2 96, at the suit of Federal Natl Mtg Assoc against Richard J Gordon & Patricia A is duly recorded in Deed Book No. 267, Page 611 IN TESTIMONY WHEREOF, I have hereunto s t my hand and seal of said office this ? day of u , .D. 200->-' of Deeds National Mortgage Association In The Court of Common Pleas of VS Cumberland County, Pennsylvania Richard J. Gordon and Patricia A. Writ No. 2004-2196 Civil Term Gordon R. Thomas Kline, Sheriff, who being duly sworn according to law, states that he made a diligent search and inquiry for the within named defendant, to wit: Richard J. Gordon, but was unable to locate him in his bailiwick. He therefore deputized the Sher of Dauphin County, Pennsylvania, to serve the within Real Estate Writ, Notice of Sale and Description according to law. Dauphin County Return: And Now: October 27, 2004 at 12:43 pm served the within Real Estate Writ, Notice of Sale upon Richard J. Gordon by personally handing defendant one true attested copy of the original Real Estate Writ, Notice of Sale and making know to him the contents thereof at Dauphin County Sheriffs Office, Harrisbut PA 17101. So answers: JR Lotwick, Sheriff of Dauphin County, PA. Cpl. Timothy Reitz, Deputy Sheriff, who being duly sworn according to law, states that on October 27, 2004 at 7:57 o'clock PM, he served a true copy of the within Real Estate Writ, Notice of Sheriffs Sale and Description, in the above entitled action, upon the within named defendant, to wit: Patricia Gordon, by making known unto Patricia Gordon, personally, at 744 Allenview Drive, Mechanicsburg, Cumberland County, Pennsylvania, its contents and at the same time handing to her personally the said true and correct copy of the same. Ron Hoover, Deputy Sheriff, who being duly sworn according to law, states tha on October 07, 2004 at 1:30 o'clock P.M., he posted a true copy of the within Real Est< Writ, Notice, Poster and Description, in the above entitled action, upon the property of Richard J. Gordon and Patricia A. Gordon located at 836 Meadow Lane, Camp Hill, 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 defendant, to wit: Richard J. Gordon, by regular mail to his last known address of 297 N. Second St., Harrisburg, PA 17110. This letter was mailed under the date of Nove 04, 2004 and never returned to the Sheriffs Office. 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 defendant, to wit: Patricia A. Gordon, by regular mail to her last known address of 74 Allenview Drive, Mechanicsburg, PA 17055. This letter was mailed under the date o October 28, 2004 and never returned to the Sheriffs Office. R. Thomas Kline, Sheriff, who being duly sworn according to law, states that after due and legal notice had been given according to law, he exposed the within described premises at public venue or outcry at the Courthouse, Carlisle, Cumberlan County, Pennsylvania on December 08, 2004 at 10:00 o'clock A.M. He sold the sam the sum of $ 1.00 to Attorney Daniel Schmieg for Fannie Mae. It being the highest bi and best price received for the same, Fannie Mae of 1900 Market Street, Suite 800, for Philadelphia, PA 19103, being the buyer in this execution, paid to Sheriff R. Thomas Kline the sum of $931.44, it being costs. Sheriffs Costs Docketing $30.00 Poundage 18.26 Posting Bills 15.00 Advertising 15.00 Acknowledging Deed 30.00 Auctioneer 10.00 Law Library .50 Prothonotary 1.00 Mileage 11.10 Out of County 9.00 Dauphin County 30.00 Levy 15.00 Surcharge 30.00 Law Journal 302.60 Patriot News 319.06 Share of Bills 30.42 Distribution of Proceeds 25.00 Sheriffs Deed 39.50 $ 931.44 Sworn and subscribed to before me So ? e?s??y rte. ? This !-J a" day of R. Thomas Kline, Sheriff 2005, A.D. /? rot onotary BY 6 do !? Real Estate eputy C 31? 1 5U ? ? i, y S ?s 5y FEDERAL NATIONAL MORTGAGE ASSOCIATION Plaintiff, v. RICHARD J. GORDON PATRICIA A. GORDON Defendant(s). CUMBERLAND COUNTY COURT OF COMMON PLEAS CIVIL DIVISION NO. 04-2196 CIVIL AFFIDAVIT PURSUANT TO RULE 3129 (Affidavit No. 1) FEDERAL NATIONAL MORTGAGE ASSOCIATION, 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, 836 MEA LANE, CAMP HILL, PA 17011. 1. Name and address of Owner(s) or reputed Owner(s): Name Last Known Address (if address cannot be reasonably ascertained, please indicate) RICHARD J. GORDON PATRICIA A. GORDON 836 MEADOW LANE CAMP HILL, PA 17011 836 MEADOW LANE CAMP HILL, PA 17011 2. Name and address of Defendant(s) in the judgment: Same as above 3. Name and last known address of every judgment creditor whose judgment is a record lien or? the real property to be sold: I Name Last Known Address (if address cannot be reasonably ascertained, please indicate) None 4. Name and address of last recorded holder of every mortgage of record: Name Last Known Address (if address cannot be reasonably ascertained, please indicate) HARRIS SAVINGS BANK 2"D AND PINE STREET HARRISBURG, PA 17101 5. Name and address of every other person who has any record lien on the property: Name Last Known Address (if address cannot be reasonably ascertained, please indicate) None 6. Name and address of every other person who has any record interest in the property and whose interest may be affected by the sale. Name Last Known Address (if address cannot be reasonably ascertained, please indicate) None 7. Name and address of every other person of whom the plaintiff has knowledge who has any inter t in the property which may be affected by the sale: Nance Last Known Address (if address cannot be reasonably ascertained, please indicate) Tenant/Occupant Domestic Relations of Cumberland County Commonwealth of Pennsylvania Department of Welfare 836 MEADOW LANE CAMP HILL, PA 17011 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 pers al knowledge or information and belief. I understand that false statements herein are made subject t the penalties of 18 Pa. C.S. Sec. 4904 relating to unsworn falsification to authorities. July 12, 2004 1 (? n f } l (`( f J`? DATE FRANK FEDERMAN, ESQUIRE Attorney for Plaintiff FEDERAL. NATIONAL MORTGAGE ASSOCIATION Plaintiff, V. RICHARD J. GORDON PATRICIA A. GORDON Defendant(s). CUMBERLAND COUNTY No. 04-2196 CIVIL July 12, 2004 TO: RICHARD J. GORDON 836 MEADOW LANE CAMP HILL, PA 17011 PATRICIA A. GORDON 836 MEADOW LANE CAMP HILL, PA 17011 "THIS FIRM IS A DEBT COLLECTOR ATTEMPTING TO COLLECT A DEBT AND ANYINFORMA11 N OBTAINED WILL BE USED FOR THAT PURPOSE. IF YOUHAVE PREVIOUSLY RECEIVED A DISCHARGE BANKRUPTCYAND THIS DEBT WAS NOT REAFFIRMED, THIS IS NOT AND SHOULD NOT BE CONSTRUE TO BE ANA TTEMPT TO COLLECT A DEBT, BUT ONLYENFORCEMENT OFA LIENAGAMST PROPERTY. ** Your house (real estate) at, 836 MEADOW LANE , CAMP HILL, PA 17011, is sche be sold at the Sheriffs Sale on DECEMBER 8, 2004 at 10:00 a.m. in the Cumberland County Courthouse, South Hanover Street, Carlisle, PA 17013, to enforce the court judgment of $141,] obtained by FEDERAL NATIONAL MORTGAGE ASSOCIATION (the mortgagee) again the event the sale is continued, an announcement will be made at said sale in compliance with 1 Rule 3129.3. NOTICE OF OWNER'S RIGHTS YOU MAY BE ABLE TO PREVENT THIS SHERIFF'S SALE To prevent this Sheriffs Sale, you must take immediate action: The sale will be cancelled if you pay to the mortgagee the back payments, late costs and reasonable attorney's fees due. To find out how much you must pay, call: (215) 563-7000. 2. You may be able to stop the sale by filing a petition asking the Court to strike judgment, if the judgment was improperly entered. You may also ask the Cot postpone the sale for good cause. to you. In may open the to 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 ch nice you will have of stopping the sale. (See notice on page two on how to obtain an attorney.) YOU MAY STILL BE ABLE TO SAVE YOUR PROPERTY AND YOU HAVE OTHER RIGHTS EVEN IF THE SHERIFF'S SALE DOES TAKE PLACE. 1. If the Sheriffs Sale is not stopped, your property will be sold to the highest bidder. Y )u 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 ale. 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 own 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 eriff and the Sheriff gives a deed to the buyer. At that time, the buyer may bring legal proceedings t evict you. 6. You may be entitled to a share of the money which was paid for your house. A sche ule of distribution of the money bid for your house will be filed by the Sheriff within 30 days of the s le. This schedule will state who will be receiving that money. The money will be paid out in accordan e with this schedule unless exceptions (reasons why the proposed distribution is wrong) are filed with the Sheriff within ten (10) days after the distribution is filed. 7. You may also have other rights and defenses, or ways of getting your home back, if?ou act immediately after the sale. YOU SHOULD TAKE THIS PAPER TO YOUR LAWYER AT ONCE. IF YOU DO NQT HAVE A LAWYER OR CANNOT AFFORD ONE, GO TO OR TELEPHONE THE OFFICE iJIISTED BELOW TO FIND OUT WHERE YOU CAN GET LEGAL HELP. IMPORTANT NOTICE: This property is sold at the direction of the plaintiff. It may n be sold in the absence of a representative of the plaintiff at the Sheriffs Sale. The sale must e postponed or stayed in the event that a representative of the plaintiff is not present at the sale. CUMBERLAND COUNTY ATTORNEY REFERRAL CUMBERLAND COUNTY BAR ASSOCIATION 2 LIBERTY AVENUE CUMBERLAND COUNTY COURTHOUSE CARLISLE, PA 17013 (717) 249-3166 (800) 990-9108 ALL THAT CERTAIN tract of land situate in Hampdca Township shown as 95.08 feet to I.at No. 38 and 16.75 fed to Lot No, 40 on Plan of Bmatwater, East Pennsbom and Hampden Towns", Cumberland County, Pennsylvania, recorded in the Office of the Recorder of Deeds, Carlisle, Pennsylvania, in Plan Rook No. 4, Page 93, bounded and described as follows, to wit. BEGINNING a[ a print on the center tine of Meadow Lane at the interscc It of the Western tin" of a five (5) font wide path now or late of Harold A. Monaco, et ax; thence along the Western line of said path, South 12 degrees 13 minutes Past, two hundred forty-three and eighty om hundredths (243.80) feet, more or less, to the fence and property line of land now or late of Lawrence H. Walker, er ux; theme along said fence and property line, South 77 degrees 47 minutes West, one handred eleven and eighty-throe one hundredths (111.83) feet, more or less, to apoint; theme North 12 degrees )3 minutes West, two hundred (orty-three and eighty one hundredths (243.80) feet, more or less, to a point on the center lime of Meadow Lane; theme North 77 degrees 47 minutes East, one hundred eleven and eighty- thtee one hundredths (111.83) feet, more or less, along said center lice to the point of beginning. CONSISTING of 95.08 feet of Lot ,f38 and Eastern 16.75 feet of Lot 840. HAVING thereon erected a single brick and aluminum dwelling known and numbered as 836 Meadow Lane. Tax Parcel ,010-1&1312.009 TjjjB ju SAID PREMISES 1S VFsrEI) IN Rlrhatd 3, Gordon and. Patricia A. Gordon, his wife by Deed from Shirley I. Green dated 10/711976 and recorded 10/8!1976, in Deed Book V26, Pag 526. WRIT OF EXECUTION and/or ATTACHMENT COMMONWEALTH OF PENNSYLVANIA) COUNTY OF CUMBERLAND) NO 04-2196 Civil CIVIL ACTION - LAW TO THE SHERIFF OF CUMBERLAND COUNTY: To satisfy the debt, interest and costs due FEDERAL NATIONAL MORTGAGE ASSOCIATION, Plaintiff (s) From RICHARD J. GORDON AND PATRICIA A. GORDON (1) You are directed to levy upon the property of the defendant (s)and to sell SEE LEGAL DESCRIPTION (2) You are also directed to attach the property of the defendant(s) not levied upon in the possession of GARNISHEE(S) as follows: and to notify the garnishee(s) that: (a) an attachment has been issued; (b) the garnishee(s) is enjoined frc paying any debt to or for the account of the defendant (s) and from delivering any property of the defend (s) or otherwise disposing thereof; (3) If property of the defendant(s) not levied upon an subject to attachment is found in the possession of anyone other than a named garnishee, you are directed to notify him/her that he/she has been added as garnishee and is enjoined as above stated. Amount Due $141,112.66 L.L. $.50 Interest FROM 6/30/04 TO 12/8/04 (PER DIEM - $23.20) - $1,624.00 AND COSTS Atty's Comm % Arty Paid $136.35 Plaintiff Paid Date: JULY 14, 2004 Due Prothy $1.00 Other Costs CURTIS R. LONG (Seal) REQUESTING PARTY: Name FRANK FEDERMAN, ESQUIRE Address: ONE PENN CENTER AT SUBURBAN STATION 1617 JOHN F. KENNEDY BOULEVARD, SUITE 1400 PHILADELPHIA, PA 19103-1814 Attorney for: PLAINTIFF Telephone: 215-563-7000 Deputy Supreme Court ID No. 12248 Real Estate Sale #10 On August 20, 2004 the Sheriff levied upon the defendant's interest in the real property situated in Hampden Township, Cumberland County, PA Known and numbered as 836 Meadow Lane, Camp Hill, more fully described on Exhibit "A" filed with this writ and by this reference incorporated herein. D Date: August 20, 2004 By: Real Estate Deputy ! s['lN3d ,u r. REAL. ESTATE SALE No. 1o Writ No. 2004-2196 CIv11 Term Federal National Mortgage VAssociation Richard J. Gordon and Patricia A. Gordon Atly: Frank Federman DESCRIPTION ALL THAT CEKEAIN tract of land situate m Hampden Townsbip shown as 95.08 fed to Lot No. 38 and 16.75 fed to Lot No. 40 on Plan of Brentwater, East Penmsboro and Hampden Tcwnsbip, Cumberland t oft Peaosylvania; recorded in the Office of the Recorder of Deeds, Carlisle, Penosylvaaia, in Plan Book N6.4, Page 93, bounded and described as follows, to wit BEaNNiNG at a point on du renter line of Meadow Lane at the intersection of the Westero line of a five (5) foot wide path now or late of Harold A. Monaco, et ux; thence along the fence and property tine of lava now or Sate of Lawrence H WaUa%,:et ax thence along said face and;moaerty lim Soath 77 degrees 47 nunmed - Tom-taleeJ run ! elm '- one- more or less, along said center line to the point of BEGINNING: CONSISTING of 9508 feet of Lot #38 and Eastem 16.75 fed of Lot #40 !, MVING tenon erecteda single brick and aluminum dwelling kmwn and numbered as 836 MeadowLane. TAX PARCEL #10-1&1311009. THU TO SAID PREMISES is vested m Richard 7. Gordon and Patricia A. Gordon, his wife, by Deed from Shirley J. Green dared 10/1/ 1976 aadrecolded 10/&1976, in Deed Book V26, Page 526. d 6 REAL ESTATE SALE NO, 10 Writ No. 2004-2196 Civil Federal National Mortgage Association VS. Richard J. Gordon and Patricia A. Gordon Atty.: Frank Federman ALL THAT CERTAIN tract of land situate in Hampden Township shown as 95.08 feet to Lot No. 38 and 16.75 feet to Lot No, 40 on Plan of Brent- water, East Pennsboro and Hamp- den Township, Cumberland County, Pennsylvania, recorded in the Of- fice of the Recorder of Deeds, Carlisle, Pennsylvania, in Plan Book No. 4, Page 93, bounded and de- scribed as follows, to wit: BEGINNING at a point on the center line of Meadow Lane at the intersection of the Western line of a five (5) foot wide path now or late of Harold A. Monaco, et ux; thence along the Western line of said path. South 12 degrees 13 minutes East, two hundred forty-three and eighty one hundredths (243.80) feet, more or less, to the fence and property line of land now or late of Lawrence H. Walker, et ux; thence along said fence and property line, South 77 degrees 47 minutes West, one hun- dred eleven and eighty-three one hundredths (111.83) feet, more or less, to a point; thence North 12 degrees 13 minutes West, two hun- dred forty-three and eighty one hun- dredths (243.80) feet, more or less, to a point on the center line of Meadow Lane; thence North 77 de- grees 47 minutes East, one hun- dred eleven and eighty-three one hundredths (111.83) feet, more or less, along said center line to the point of beginning. CONSISTING of 95.08 feet of Lot #38 and Eastern 16.75 feet of Lot #40. HAVING thereon erected a single brick and aluminum dwelling known and numbered as 836 Meadow Lane. Tax Parcel #10-18-1312-009. TITLE TO SAID PREMISES IS VESTED IN Richard J. Gordon and Patricia A. Gordon, his wife by Deed from Shirley J. Green dated 10/7/ 1976 and recorded 10/8/1976, in Deed Book V26, Page 526. PROOF OF PUBLICATION OF NOTICE IN CUMBERLAND LAW JOURNAL (Under Act No. 587, approved May 16, 1929), P. L.1784 STATE OF PENNSYLVANIA : COUNTY OF CUMBERLAND : ss. Lisa Marie Coyne, Esquire, Editor of the Cumberland Law Journal, of the County and State aforesaid, being duly sworn, according to law, deposes and says that the Cumberland Law Journal, a legal periodical published in the Borough of Carlisle in the County and State aforesaid, was established January 2, 1952, and designated by the local courts as the official legal periodical for the publication of all legal notices, and has, since January 2, 1952, been regularly issued weekly in the said County, and that the printed notice or publication attached hereto is exactly the same as was printed in the regular editions and issues of the said Cumberland Law Journal on the following dates, viz: OCTOBER 8, 15, 22, 2004 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. r sa Marie CovnA Editor )RN TO AND SUBSCRIBED before me this 22 day of OCTOBER 2004 NOTARIAL SEAL LOIS E. SNYDER, Notary Public Carlisle Boro, Cumberland County My Commission Expires March 5, 2005 REAL. NOTATE AAL.E NO. 10 Wrlt No. 2004-2196 Civil Federal National Mortgage Association vs. Richard J. Gordon and Patricia A. Gordon Atty.: Frank Federman ALL THAT CERTAIN tract of land situate in Hampden Township shown as 95.08 feet to Lot No. 38 and 16.75 feet to Lot No, 40 on Plan of Brent- water, East Pennsboro and Hamp- den Township, Cumberland County, Pennsylvania, recorded in the Of- fice of the Recorder of Deeds, Carlisle, Pennsylvania, in Plan Book No. 4, Page 93, bounded and de- scribed as follows, to wit: BEGINNING at a point on the center line of Meadow Lane at the intersection of the Western line of a five (5) foot wide path now or late of Harold A. Monaco, et ux; thence along the Western line of said path, South 12 degrees 13 minutes East, two hundred forty-three and eighty one hundredths (243.80) feet, more or less, to the fence and property line of land now or late of Lawrence H. Walker, et ux; thence along said fence and property line, South 77 degrees 47 minutes West, one hun- dred eleven and eighty-three one hundredths (111.83) feet, more or less, to a point; thence North 12 degrees 13 minutes West, two hun- dred forty-three and eighty one hun- dredths (243.80) feet, more or less, to a point on the center line of Meadow Lane; thence North 77 de- grees 47 minutes East, one hun- dred eleven and eighty-three one hundredths (111.83) feet, more or less, along said center line to the point of beginning. CONSISTING of 95.08 feet of Lot #38 and Eastern 16.75 feet of Lot #40. HAVING thereon erected a single brick and aluminum dwelling known and numbered as 836 Meadow Lane. Tax Parcel #10-18-1312-009. TITLE TO SAID PREMISES IS VESTED IN Richard J. Gordon and Patricia A. Gordon, his wife by Deed from Shirley J. Green dated 10/7/ 1976 and recorded 10/8/1976, in Deed Book V26, Page 526. 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 the Controller of The Patriot News Co., a corporation organized and existing under the laws of the Commonwealth of Pennsylvania, with its principal office and place of business at 812 to 818 Market Street, in the City of Harrisburg, County of :Dauphin, State of Pennsylvania, owner and publisher of The Patriot-News and The Sunday Patriot-News newspapers of general circulation, printed and published at 812 to 818 Market Street, in the City, County and State aforesaid; that The Patriot-News and The Sunday Patriot-News were established March 4th, 1854, and September 18th, 1949, respectively, and all have been continuously published ever since; That the printed notice or publication which is securely attached hereto is exactly as printed and published in their regular daily and/or Sunday/ Metro editions which appeared on the 19th and 26th day(s) of October and the 2nd day(s) of November 2004. That neither he nor said Company is interested in the subject matter of said printed notice or advertising, and that all of the allegations of this statement as to the time, place and character of publication are true; and That he has personal knowledge of the facts aforesaid and is duly authorized and empowered to verify this statement on behalf of The Patriot-News Co. aforesaid by virtue and pursuant to a resolution unanimously passed and adopted severally by the stockholders and board of directors of the said Company and subsequently duly recorded in the office for the Recording of Deeds in and for said County of Dauphin in Miscellaneous Book "M", Volume 14, Page 317. PUBLICATION ......................... .. ........ -? ....................................... COPY Swo i to and subscribed be th day of N/ember 2Q04 A.D. NOTARIAL SEAL SALE #] 0 Terry L. Russell, Notaryl Ic I , City of Harrisburg, Daup C My Commission Expires June 6, AR PUBLIC Member, Pennsylvania Aseocla I coAMion expires June 6, 2006 J CUMBERLAND COUNTY SHERIFFS OFFICE CUMBERLAND COUNTY COURTHOUSE CARLISLE, PA. 17013 Statement of Advertising Costs To THE PATRIOT-NEWS CO. For publishing the notice or publication attached hereto on the above stated dates 319.06 Publisher's Receipt for Advertising Cost The Patriot News Co., publisher of The Patriot-News and The Sunday Patriot-News, newspapers of general circulation, hereby acknowledge receipt of the aforesaid notice and publication costs and certifies that the same have been duly paid. By .................................................................... DEAL ESTATE SALE No. 10 Writ No. 20042196 Civil Term Federal National Mortgage Association Vs Richard J. Gordon and Patricia A. Gordon Atty: Frank Federman DESCRIPTION ALL THAT CERTAIN tract of land situate in Hampden Township shown as 95.08 feet to Lot No. 38 and 16.75 feet to Lot No. 40 on Plan of Brentwater, East Pennsbo o and Hampden Township, Cumberland L:ui ty, Pennsylvania, recorded in the Office of the Recorder of Deeds, Carlisle, Pennsylvania, in Plan Book No. 4, Page 93, bounded and described as follows, to wit: BEGINNING at a point on the center line of Meadow lane at the intersection of the Western line of a five (5) foot wide path now or late of Harold A. Monaco, et ux; thence along the Western line of said path, South 12 degrees 13 minutes East, two hundred forty-three and eighty one-hundredths (243.80) feet, more or less, to the fence and property line of land now or late of Lawrence H. Walker, et ux; thence along said fence and property line, South 77 degrees 47 minutes West, one hundred eleven and eighty- three hundredths (111.83) feet, more or less, to a point; thence North 12 degrees 13 minutes West, two hundred forty-three and eighty one- hundredths (243.80) feet more or less, to a point on the center line of Meadow Lane; thence North 77 degrees 47 minutes East, one hundred eleven and eighty-three one hundredths (111.83) feet, more or less, along said center he to the point of BEGINNING. CONSISTING of 95.08 feet of Lot #38 and Eastern 16.75 f-et of Lot #40 HAVING thereon erected a single brick and aluminum dwehing known and numbered as 836 Meadow Lane. TAX PARCEL #10-18-1312-009. TITLE TO SAID PREMISES is vested in Richard J. Gordon and Patricia A. Gordon, his wife, by Deed from Shirley J. Green dated 10n1 1976 and recorded 10/811976, in Deed Book V26, Page 526.