HomeMy WebLinkAbout01-1303 CHARLOTTE K. HUMMEL, ESQUIRE Attorney for Plaintiff
MARTHA E. VON ROSENSTIEL, P.C.
16 SOUTH LANSDOWNE AVENUE
PO BOX 457
LANSDOWNE, PA 19050
Attorney ID # 63657
GMAC Mortgage Corporation : COURT OF COMMON PLEAS
500 Enterprise Road : Cumberland COUNTY
Horsham, PA 19044-0963 :
Plaintiff, :
Suzanne M. Thomas aka :
Suzanne Thomas :
97 Richneck Road, :
Newport News, VA 23608, :
Defendant :
CIVIL ACTION - MORTGAGE FORECLOSURE
THIS IS AN ATTEMPT TO COLLECT A DEBT ANY INFORMATION OBTAINED
WILL BE USED FOR THAT PURPOSE
NOTICE ADVISO
You have been sued in cota't. If you wish to defend against the te han demandado a usted un la corte. Si usted quiere defenderse
claims set forth in the following pages, you must take action de estas demandas expuestas en las paginas siguientes, usted
within twenty (20) days after this complaint and notice are tiene veinte (20) dias de plazo al partir de la fecha de la demanda
served, by entering a written appearance personally or by y la notificacion. Hace falta a sentar una comparencia escrita o
attorney and filing in writing with the com't your defenses or en persona o con un abogado y entregar a la corte en forma
objections to the claims set forth against you by the court escrita sus defensas o sus objeciones a las demandas en contra de
without further notice for any money claimed in the complaint su persona. Sea a visado que si usted no se defiende, la torte
or for any other claim or relief requested by the plaintiff. You toma ra medidas y puede continuar la demanda en contra suya sin
may lose money or property or other rights important to you. previo aviso o notificacion. Ademas, la corte puede decidir a
favor del demandante y requiere que usted cumpla con todas las
provisiones de esta demanda. Usted puede perder dinero o sus
propiedades o otros de rechos importantes para usted.
YOU SHOULD TAKE THIS PAPER TO YOUR LAWYER LLEVE ESTA DEMANDA A UN ABOGADO
AT ONCE. IF YOU DO NOT HAVE A LAWYER OR INMEDIATAMENTE. SI NO TIENE ABOGADO O SI NO
CANNOT AFFORD ONE. GO TO OR TELEPHONE THE TIENE EL DINERO SUFICIENTE DE PAGAR TAL
OFFICE SET FORTH BELOW TO FIND OUT WHERE SERVICIO. VAYA EN PERSONA O LLAME POR
YOU CAN GET LEGAL HELP. TELEFONO A LA OFICINA CUYA DIRECCION SE
ENCUENTRA ESCRITA ABA JO PARA AVERIGUAR
DONDE SE PUEDE CONSEGUIR ASISTENCIA LEGAL.
CUMBERLAND COUNTY BAR ASSOCIATION
2 LIBERTY AVENUE, CARLISLE, PA 17013
717-249-3166
800-990-9 108
CHARLOTTE K. HUMMEL, ESQUIRE Attorney for Plaintiff
MARTHA E. VON ROSENSTIEL, P.C.
16 SOUTH LANSDOWNE AVENUE
PO BOX 457
LANSDOWNE, PA 19050
Attorney ID# 63657
GMAC Mortgage Corporation : COURT OF COMMON PLEAS
500 Enterprise Road : Cumberland COUNTY
Horsham, PA 19044-0963 :
Plaintiff, :
vs. : Case No:
Suzanne M. Thomas aka :
Suzanne Thomas :
97 Richneck Road :
Newport News, VA 23608, :
Defendant :
CIVIL ACTION - MORTGAGE FORECLOSURE
THIS IS AN ATTEMPT TO COLLECT A DEBT ANY INFORMATION OBTAINED
WILL BE USED FOR THAT PURPOSE
1. Plaintiff is GMAC Mortgage Corporation, a corporation
organized and existing under state law, with offices for the
conduct of business at 500 Enterprise Road, Horsham, PA 19044-
0963.
2. Defendant, Suzanne M. Thomas aka Suzanne Thomas is the
mortgagor and real owner of premises 217 South Sixteenth Street,
Camp Hill, PA 17011, hereinafter described, whose last known
address is the same as in the caption above.
3. Plaintiff brings this action in mortgage foreclosure
against defendant, mortgagor and real owner, to foreclose a
certain indenture of mortgage made, executed and delivered by
the above named defendant, mortgagor and real owner to GMAC
Mortgage Corporation on November 13, 1998, which mortgage is
recorded in the Office of the Recorder of Deeds of Cumberland
County in Mortgage Record Book 1499, page 216 secured on
premises 217 South Sixteenth Street, Camp Hill, PA 17011 a true
and correct description of which is attached hereto as Exhibit
I.
4. Plaintiff alleges each and every term, condition and
covenant in the aforesaid mortgage, and hereby incorporates them
herein by reference thereto.
5. The aforesaid mortgage is in default in that monthly
installments of principal and interest have not been made
conformity with the terms of the mortgage, for the month of
October 1, 2000 and each month thereafter, up to and including
the present time.
6. Under the terms of the aforesaid mortgage, upon default
of payments set forth in the mortgage documents, the entire
principal balance and all interest due thereon are collectible
forthwith.
7. The following is an itemized statement of the amount
due plaintiff under the terms of the aforesaid mortgage:
Principal Balance $104,339.30
Interest from 9/1/00 to 3/6/01
At $19.30 per diem $ 3,609.10
Late charges for 2/01
At $34.51 per month $ 34.51
Accrued Escrow deficit to 1/24/01 $ 182.70
Monthly escrow deposits for 2/1/01
To 3/1/01 at $210.45 per month $ 420.90
Corporate Advances $ 7.25
Monthly Inspections from 10/01/00
To 3/01/01 at $15.00 per month $ 90.00
Attorney's Fee $5,200.00
Title Information Certificate $ 350.00
Photostats and Postage $ 45.00
Notarizations $ 10.00
TOTAL $114,288.76
9. Plaintiff sent to defendants, mortgagors and real
owners a combined Notice and Warning of Intention to Foreclose
and Notices of Homeowners' Emergency Mortgage Assistance Act of
1983 advising of rights available under the statutes. To date
payments have not been received and Act 91 assistance has not
been granted although the applicable time periods provided by
statute have expired (Exhibit II).
W/{~R~FORE, plaintiff demands judgment for $114,288.76, plus
per diem interest at $19.30 from 3/9/01 to the date of judgment
plus monthly late charges of $34.51 from 3/15/01 to the date of
judgment plus monthly escrow deposits of $210.45 from 4/1//01 to
the date of judgment plus monthly inspection costs of $15.00
from 4/1/01 to the date of judgment and foreclosure and sale of
the mortgaged premises plu~ costs ~ereon----
Charlotte K. Hummel
Attorney for the Plaintiff
VERIFICATION
I verify that the statements made in the foregoing Complaint
in Mortgage Foreclosure are true and correct.
I understand that false statements herein are made subject
to penalties of 18 Pa C.S. Section 4904 relating to unsworn
falsification to authorities.
C~nest~ga Title Insurance Company
EXHIBIT
GMAC Mortgage Corporation Servicing
P.O. Box 8§07f
San Diego, CA, 92186-5071
3451 Hammond Ave !
Bo ? o
Waterloo, IA 50704-0780
NOTICE OF INTENTION TO FORECLOSE AND ACCELERATE LOAN BALANCE
DATE: December 18, 2000
CERTIFIED MAIL No. ,v, ,Ly y""o-"-a-e
TO: 8UZANNE M. THOMAS
97 RICHNECK RD
NEWPORT NEWS, VA 23608
RE: MORTGAGE LOAN NUMBER: 164381204
MORTGAGED PREMISES: 217 S SIXTEENT~ STREET
CAMP HILL, PA 17011-5535
This company is the holder of the FIRST MORTGAGE (AND NOTE) on the above
premises, or is the mortgage service agent for such holder. (Hereinafter
referred to as we, us or ours).
As of the date of this notice, THE MORTGAGE IS IN SERIOUS DEFAULT because
you have not made the October l, 2000 and subsequent monthly payments as
listed, and/or for other reasons as indicated below:*
2 payments ~ $900.56 $1,801.12
1 payments ~ $921.05 $921.05
Accrued late charges ............................... $69.02
NSF Check Fees ...................................... $0.00
All other fees accrued to date ..................... $12.00
* Less available suspense credits .................. $188.66
The total amount now required to cure this default, or in
other words, get caught up in your payments as of the date
of this letter is .................................... $2,614.53
You may cure this default within THIRTY (30) DAYS of the date of this
letter, by paying to us the above amount, plus any additional monthly
payments and late charges which may fall due during this period. Such
payment must be made either by cash, cashier's check, certified check or
money order, and made at, or sent to: 3451 Hammond Avenue, P.O. Box 780,
Waterloo, IA 50704-0780.
If you do not cure the default within THIRTY (30) DAYS, we intend to
exercise our right to accelerate the mortgage payments. This means that
whatever is owing on the original amount borrowed will be considered due
immediately and you may lose the chance to pay off the original mortgage
in monthly installments. If full payment of the amount of default is not
made within THIRTY (30) DAYS, we also intend to instruct our attorneys to
start a lawsuit to foreclose your mortgaged property. If the mortgage is
foreclosed your mortgaged property will be sold by the Sheriff to pay
DMS5-BRCHPAC (Page 1 of 2)
Decen%ber 18, 2000
Page 2
164381204
off the debt. If we refer your case to our attorneys, but you cure the
default before they begin legal proceedings against you, you will still
have to pay the reasonable attorney's fees, actually incurred, up to
$50.00.
However, if legal proceedings are started against you, you will have to
pay the reasonable attorney's fees even if they are over $50.00. Any
attorney's fees will be added to whatever you owe us, which may also
include our reasonable costs. If you cure the default within the thirty
day period, you will not be rec~uired to pay attorney's fees.
Remember you are also responsible for keeping all real estate taxes
current.
We may also sue you personally for the unpaid balance and all other sums
due under the mortgage. If you have not cured the default within the
thirty day period and foreclosure proceedings have begun, you still have
the right to cure the default and prevent the sale at any time up to one
hour before the Sheriff's foreclosure sale. You may do so by paying the
total amount of the unpaid monthly payments plus any late or other
charges then due, as well as the reasonable attorney's fees and costs
connected with the foreclosure sale (and perform any other requirements
under the mortgage). It is estimated that the earliest date that such a
Sheriff's sale could be held would be approximately onebhundred and fifty
(150) days from the date of this letter. A notice of the date of the
Sheriff's sale will be sent to you before the sale. Of course, the
amount needed to cure the default will increase the longer you wait. You
may find out at any time exactly what the required payment will be by
calling us at the following number: 1-800-850-4622. The payment must be
in cash, cashier's check, certified check or money order and made payable
to us at the address previously stated.
You should realize that a Sheriff's sale will end your ownership of the
mortgaged property and your right to remain in it. If you continue to
live in the property after the Sheriff's sale, a lawsuit could be started
to evict you.
NOTICE - This is an attempt to collect a debt and any information
obtained will be used for that purpose.
You have additional rights to help protect your interest in the property.
YOU HAVE THE RIGHT TO SELL THE PROPERTY TO OBTAIN MONEY TO PAY OFF THE
MORTGAGE DEBT, OR TO BORROW MONEY FROM ANOTHER LENDING INSTITUTION TO PAY
OFF THIS DEBT. YOU MAY HAVE THE RIGHT TO SELL OR TRANSFER THE PROPERTY
SUBJECT TO THE MORTGAGE TO A BUYER OR ~ANSFEREE W/~O WILL ASSUME THE
MORTGAGE DEBT~ PROVIDED T~AT ALL OUTSTANDING PAYMENTS, CHARGES AND
ATTORNEY'S FEES AND COSTS ARE PAID PRIOR TO OR AT THE SALE, (AND THAT THE
OTHER REQUIREMENTS UNDER THE MORTGAGE ARE SATISFIED). CONTACT US TO
DETERMINE UNDER W~AT CIRCUMSTANCES THE RIGHT MAY EXIST. YOU HAVE THE
RIGHT TO HAVE THIS DEFAULT CURED BY ANY THIRD PARTY ACTING ON YOUR
BEHALF.
If you cure the default, the mortgage will be restored to the same
position as if no default had occurred. However, you are not entitled to
this right to cure your default more than three times in any calendar
year.
DMS5-BRCHPAC (Page 2 of 2)
GMAC Mortgage Corporation Servicing
P.O. BOX 85071
San Diego, CA 92186-5071
3451 Hammond Ave
P.O. Box 780
Waterloo, IA 50704-0780
NOTICE OF INTENTION TO FORECLOSE AND ACCELERATE LOAN BALANCE
DATE: December 18, 2000 G~C
CERTI F ED NO. z ,v,u,
TO: SUZANNE M, THOMAS
217 S SIXTEENTH STREET
CAMP HILL, PA 17011-5535
RE: MORTGAGE LOAN NUMBER: 164381204
MORTGAGED PREMISES: 217 S SIXTEENTH STREET
CAMP HILL, PA 17011-5535
This company is the holder of the FIRST MORTGAGE (AND NOTE) on the above
premises, or is the mortgage service agent for such holder. (Hereinafter
referred to as we, us or ours).
As of the date of this notice, T~E MORTGAGE IS IN SERIOUS DEFAULT because
you have not made the October l, 2000 and subsequent monthly payments as
listed, and/or for other reasons as indicated below:*
2 payments ~ $900.56 $1,801.12
1 payments ~ $921.05 $921.05
Accrued late charges ............................... $69.02
NSF Check Fees ...................................... $0.00
All other fees accrued to date ..................... $12.00
* Less available suspense credits .................. $188.66
The total amount now required to cure this default, or in
other words, get caught up in your payments as of the date
of this letter is .................................... $2,614.53
You may cure this default within THIRTY (30) DAYS of the date of this
letter, by paying to us the above amount, plus any additional monthly
payments and late charges which may fall due during this period. Such
payment must be made either by cash, cashier's check, certified check or
money order, and made at, or sent to: 3451 Hammond Avenue, P.O. Box 780,
Waterloo, IA 50704-0780.
If you do not cure the default within THIRTY (30} DAYS, we intend to
exercise our right to accelerate the mortgage payments, This means that
whatever is owing on the original amount borrowed will be considered due
immediately and you may lose the chance to pay off the original mortgage
in monthly installments. If full payment of the amount of default is not
made within THIRTY (30) DAYS, we also intend to instruct our attorneys to
start a lawsuit to foreclose your mortgaged property. If the mortgage is
foreclosed your mortgaged property will be sold by the Sheriff to pay
DMS5-BRCHPAC (Page 1 of 2)
· . ~ December 18, 2000
Page 2
164381204
off the debt. If we refer your case to our attorneys, but you cure the
default before they begin legal proceedings against you, you will still
have to pay the reasonable attorney's fees, actually incurred, up to
$50,00.
However, if legal proceedings are started against you, you will have to
pay the reasonable attorney's fees even if they are over $50.00. Any
attorney's fees will be added to whatever you owe us, which may also
include our reasonable costs. If you cure the default within the thirty
day period, you will not be required to pay attorney's fees.
Remember you are also responsible for keeping all real estate taxes
current.
We may also sue you personally for the unpaid balance and all other sums
due under the mortgage. If you have not cured the default within the
thirty day period and foreclosure proceedings have begun, you still have
the right to cure the default and prevent the sale at any time up to one
hour before the Sheriff's foreclosure sale. You may do so by paying the
total amount of the unpaid monthly pa~nents plus any late or other
charqes then due, as well as the reasonable attorney's fees and costs
connected with the foreclosure sale (and perform any other requirements
under the mortgage). It is estimated that the earliest date that such a
Sheriff's sale could be held would be approximately one-hundred and fifty
(150) days from the date of this letter. A notice of the date of the
Sheriff's sale will be sent to you before the sale. Of course, the
amount needed to cure the default will increase the longer you wait. You
may find out at any time exactly what the required payment will be by
calling us at the following number: 1-800-850-4622. The payment must be
in cash, cashier's check, certified check or money order and made payable
to us at the address previously stated.
You should realize that a Sheriff's sale will end your ownership of the
mortgaged property and your right to remain in it. If you continue to
live in the property after the Sheriff's sale, a lawsuit could be started
to evict you.
NOTICE - This is an attempt to collect a debt and any information
obtained will be used for that purpose.
You have additional rights to help protect your interest in the property.
YOU HAVE T~E RIGHT TO SELL THE PROPERTY TO OBTAIN MONEY TO PAY OFF THE
MORTGAGE DEBT, OR TO BORROW MONEY FROM ANOTHER LENDING INSTITUTION TO PAY
OFF THIS DEBT. YOU MAY HAVE THE RIGHT TO SELL OR TRANSFER THE PROPERTY
SUBJECT TO THE MORTGAGE TO A BUYER OR TRANSFEREE W~O WILL ASSUME THE
MORTGAGE DEBT, PROVIDED THAT ALL OUTSTANDING PAYMENTS, CHARGES AND
ATTORNEY'S FEES AND COSTS ARE PAID PRIOR TO OR AT THE SALE, (AND THAT THE
OTHER REQUIREMENTS UNDER THE MORTGAGE ARE SATISFIED). CONTACT US TO
DETERMINE UNDER WHAT CIRCUMSTANCES THE RIGHT MAY EXIST. YOU HAVE THE
RIGHT TO HAVE THIS DEFAULT CURED BY ANY THIRD PARTY ACTING ON YOUR
BEHALF.
If you cure the default, the mortgage will be restored to the same
position as if no default had occurred. However, you are not entitled to
this right to cure your default more than three times in any calendar
year.
DMS5~BRCHPAC (Page 2 of 2)
SHERIFF'S RETURN - REGULAR
CASE NO: 2001-01303 P
COMMONWEALTH OF PENNSYLVANIA:
COUNTY OF CUMBERLAND
GMAC MORTGAGE CORPORATION
VS
THOMAS SUZANNE M ET AL
DEP WILLIAM DIEHL , Sheriff or Deputy Sheriff of
Cumberland County, Pennsylvania, who being duly sworn according to law,
says, the within COMPLAINT - MORT FORE was served upon
TERRE TENANTS the
DEFENDANT at 1536:00 HOURS, on the 8th day of March 2001
at 217 SOUTH 16TH STREET
CAMP HILL, PA 17011 by handing to
MARNA HARTZELL CURRENT TENNANT
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 18 00
Service 8 68 ~~~//~
Affidavit 00
Surcharge 10 00 R. Thomas Kline
00
36 68 03/i2/200i
MARTHA E VON ROSENSTEIL
Sworn and Subscribed to before ~~
me this J~ ~ day of
-2h~_~3%~ ~, ~2~/ A.D.
f /Prothonotary~
CHARLOTTE K. HUMMEL, ESQUIRE Attorney for Plaintiff
MARTHA E. VON ROSENSTIEL, P.C.
16 SOUTH LANSDOWNE AVENUE
PO BOX 457
LANSDOWNE, PA 19050
Attorney ID # 63657
GMAC Mortgage Corporation : COURT OF COMMON PLEAS
500 Enterprise Road Cumberland COUNTY
Horsham, PA 19044-0963
Plaintiff,
Suzanne M. Thomas aka :
Suzanne Thomas
97 Richneck Road,
Newport News, VA 23608,
Defendant
CIVIL ACTION - MORTGAGE FORECLOSURE
TI{IS IS AN ATTEMPT TO COLLECT A DEBT ANY INFORMATION OBTAINED
WILL BE USED FOR THAT PURPOSE
NOTICE ADVI$O
You have been sued in court. If you wish to defend against the Le han demandado a usted en la corte. Si usted quiere defenderse
claims set forth in the following pages, you must take action de estas demandas expuestas en las paginas siguientes, usted
within twenty (20) days after this complaint and notice are tiene veinte (20) dias de plazo al partir de la fecha de la demanda
served, by entering a written appearance personally or by y la notificacion. Hace falta a sentar una compamncia escrita o
attorney and filing in writing with the court your defenses or en persona o con un abogado y en~regar a la corte en forma
objections to the claims set forth against you by the court escrita sus defensas o sus objeciones a las demandas en contra de
without further notice for any money claimed in the complaint su persona. Sea a visado que si usted no se defiende, la corte
or for any other claim or relief requested by the plaintiff. You toma ra medidas y puede continuar la demanda en contra suya sin
may lose money or property or other rights important to you. previo aviso o notificacion. Ademas, la corte puede decidir a
favor del demandante y requiere que usted cumpla con todas las
provisiones de esta demanda. Usted puede perder dinero o sus
propiedades o otros de mchos importantes para usted.
YOU SHOULD TAKE THIS PAPER TO YOUR LAWYER LLEVE ESTA DEMANDA A UN ABOGADO
AT ONCE. IF YOU DO NOT HAVE A LAWYER OR INMEDIATAMENTE. SI NO TIENE ABOGADO O SI NO
CANNOT AFFORD ONE. GO TO OR TELEPHONE THE TIENE EL DINERO SUFICIENTE DE PAGAR TAL
OFFICE SET FORTH BELOW TO FIND OUT WHERE SERVICIO. VAYA EN PERSONA O LLAME POR
YOU CAN GET LEGAL HELP. TELEFONO A LA OFICINA CUYA DIRECCION SE
ENCUENTRA ESCRITA ABA JO PARA AVERIGUAR
DONDE SE PUEDE CONSEGUIR ASISTENCIA LEGAL.
CUMBERLAND COUNTY BAR ASSOCIATION
2 LIBERTY AVENUE, CARLISLE, PA 17013
717-249-3166
CHARLOTTE K. HUMMEL, ESQUIRE Attorney for Plaintiff
MARTHA E. VON ROSENSTIEL, P.C.
16 SOUTH LANSDOWNE AVENUE
PO BOX 457
LANSDOWNE, PA 19050
Attorney ID# 63657
GMAC Mortgage Corporation : COURT OF COMMON PLEAS
500 Enterprise Road : Cumberland COUNTY
Horsham, PA 19044-0963 :
Plaintiff, :
vs. Case No:
Suzanne M. Thomas aka
Suzanne Thomas
97 Richneck Road :
Newport News, VA 23608, :
Defendant :
CIVIL ACTION - MORTGAGE FORECLOSURE
THIS IS AN ATTEMPT TO COLLECT A DEBT ANY INFORMATION OBTAINED
WILL BE USED FOR THAT PURPOSE
1. Plaintiff is GMAC Mortgage Corporation, a corporation
organized and existing under state law, with offices for the
conduct of business at 500 Enterprise Road, Horsham, PA 19044-
0963.
2. Defendant, Suzanne M. Thomas aka Suzanne Thomas is the
mortgagor and real owner of premises 217 South Sixteenth Street,
Camp Hill, PA 17011, hereinafter described, whose last known
address is the same as in the caption above.
3. Plaintiff brings this action in mortgage foreclosure
against defendant, mortgagor and real owner, to foreclose a
certain indenture of mortgage made, executed and delivered by
the above named defendant, mortgagor and real owner to GMAC
Mortgage Corporation on November 13, 1998, which mortgage is
recorded in the Office of the Recorder of Deeds of Cumberland
County in Mortgage Record Book 1499, page 216 secured on
premises 217 South Sixteenth Street, Camp Hill, PA 17011 a true
and correct description of which is attached hereto as Exhibit
I.
4. Plaintiff alleges each and every term, condition and
covenant in the aforesaid mortgage, and hereby incorporates them
herein by reference thereto.
5. The aforesaid mortgage is in default in that monthly
installments of principal and interest have not been made
conformity with the terms of the mortgage, for the month of
October 1, 2000 and each month thereafter, up to and including
the present time.
6. Under the terms of the aforesaid mortgage, upon default
of payments set forth in the mortgage documents, the entire
principal balance and all interest due thereon are collectible
forthwith.
7. The following is an itemized statement of the amount
due plaintiff under the terms of the aforesaid mortgage:
Principal Balance $104,339.30
Interest from 9/1/00 to 3/6/01
At $19.30 per diem $ 3,609.10
Late charges for 2/01
At $34.51 per month $ 34.51
Accrued Escrow deficit to 1/24/01 $ 182.70
Monthly escrow deposits for 2/1/01
To 3/1/01 at $210.45 per month $ 420.90
Corporate Advances $ 7.25
Monthly Inspections from 10/01/00
To 3/01/01 at $15.00 per month $ 90.00
Attorney's Fee $5,200.00
Title Information Certificate $ 350.00
Photostats and Postage $ 45.00
Notarizations $ 10.00
TOTAL $114,288.76
9. Plaintiff sent to defendants, mortgagors and real
owners a combined Notice and Warning of Intention to Foreclose
and Notices of Homeowners' Emergency Mortgage Assistance Act of
1983 advising of rights available under the statutes. To date
payments have not been received and Act 91 assistance has not
been granted although the applicable time periods provided by
statute have expired (Exhibit II).
WI~EREFORE, plaintiff demands judgment for $1t4,288.76, plus
per diem interest at $19.30 from 3/9/01 to the date of judgment
plus monthly late charges of $34.51 from 3/15/01 to the date of
judgment plus monthly escrow deposits of $210.45 from 4/1//01 to
the date of judgment plus monthly inspection costs of $15.00
from 4/1/01 to the date of judgment and foreclosure and sale of
the mortgaged premises plus costs thereon,,
Charlotte K. Hummel
Attorney for the Plaintiff
VERIFICATION
I verify that the statements made in the foregoing Complaint
in Mortgage Foreclosure are true and correct.
I understand that false statements herein are made subject
to penalties of 18 Pa C.S. Section 4904 relating to unsworn
falsification to authorities.
Dated:
SCHEDULE C :. :'
PROPERTY DESCRIPTION
BEGINNING ~t a point two hundred fore/(240} fee: South of the Southeast comer of Second and Six'~eenbh
(fcrmech/Jackson) Streets; thence Eas~,vardly along the South Ithe Of Lot No. 61, one hundred fifty (150) fee~ to
a poinl in a [',vent,/(20) feet wide alley; thence Southwardly aIcng Ihe West side of s~id alley Forty (40) feet ~o a
BEGINNING.
BEING the same premises which Paul R, Eicbetber~er and Lerde Bicheiberger, his wife by their deed dated
November 954, and about to be recorded in the Recorder of Deeds Office Jn and for Cumberland County.
GMAC Mortgage Corporation Servicing
P.O. Box 85071
San Diego, CA 92186-5071
3451 Hammond Ave
P.O. Box 780 ~ L.~ I
Waterloo, IA 50704-0780
NOTICE OF INTENTION TO FORECLOSE AND ACCELERATE LOAN BALANCE
DATE: December 18, 2000
CERTIFIE MA L No.,v,
TO: SUZANNE M. THOMAS
97 RICHNECK RD
NEWPORT NEWS, VA 23608
RE: MORTGAGE LOAN NUMBER: 164381204
MORTGAGED PREMISES: 217 S SIXTEENTH STREET
CAMP HILL, PA 17011-5535
This company is the holder of the FIRST MORTGAGE (AND NOTE) on the above
premises, or is the mortgage service agent for such holder. (Hereinafter
referred to as we, us or ours).
As of the date of this notice, THE MORTGAGE IS IN SERIOUS DEFAULT because
you have not made the October 1, 2000 and subsequent monthly payments as
listed, and/or for other reasons as indicated below:*
2 payments ~ $900.56 $1,801.12
1 payments ~ $921.05 $921.05
Accrued late charges ............................... $69.02
NSF Check Fees ...................................... $0.00
All other fees accrued to date ..................... $12.00
* Less available suspense credits .................. $188.66
The total amount now required to cure this default, or in
other words, get caught up in your payments as of the date
of this letter is .................................... $2,614.53
You may cure this default within THIRTY (30) DAYS of the date of this
letter, by paying to us the above amount, plus any additional monthly
payments and late charges which may fall due during this period. Such
payment must be made either by cash, cashier's check, certified check or
money order, and made at, or sent to: 3451 Hammond Avenue, P.O. Box 780,
Waterloo, IA 50704-0780.
If you do not cure the default within THIRTY (30) DAYS, we intend to
exercise our right to accelerate the mortgage payments. This means that
whatever is owing on the original amount borrowed will be considered due
immediately and you may lose the chance to pay off the original mortgage
in monthly installments. If full payment of the amount of default is not
made within THIRTY (30) DAYS, we also intend to instruct our attorneys to
start a lawsuit to foreclose your mortgaged property. If the mortgage is
foreclosed your mortgaged property will be sold by the Sheriff to pay
DMS5-BRCHPAC (Page 1 of 2)
December 18, 2000
PaGe 2
164381204
off the debt. If we refer your case to our attorneys, but you cure the
default before they begin legal proceedings against you, you will still
have to pay the reasonable attorney's fees, actually incurred, up to
$50.00.
However, if legal proceedings are started against you, you will have to
pay the reasonable attorney's fees even if they are over $50.00. Any
attorney's fees will be added to whatever you owe us, which may also
include our reasonable costs. If you cure the default within the thirty
day period, you will not be required to pay attorney's fees.
Remember you are also responsible for keepinq all real estate taxes
current.
We may also sue you personally for the unpaid balance and all other sums
due under the mortqage. If you have not cured the default within the
thirty day period and foreclosure proceedings have begun, you still have
the right to cure the default and prevent the sale at any time up to one
hour before the Sheriff's foreclosure sale. You may do so by paying the
total amount of the unpaid monthly payments plus any late or other
charges then due, as well as the reasonable attorney's fees and costs
connected with the foreclosure sale (and perform any other requirements
under the mortgage). It is estimated that the earliest date that such a
Sheriff's sale could be held would be approximately one-hundred and fifty
(150) days from the date of this letter. A notice of the date of the
Sheriff's sale will be sent to you before the sale. Of course, the
amount needed to cure the default will increase the longer you wait. You
may find out at any time exactly what the required payment will be by
calling us at the following number: 1-800-850-4622. The payment must be
in cash, cashier's check, certified check or money order and made payable
to us at the address previously stated.
You should realize that a Sheriff's sale will end your ownership of the
mortgaged property and your right to remain in it. If you continue to
live in the property after the Sheriff's sale, a lawsuit could be started
to evict you.
NOTICE - This is an attempt to collect a debt and any information
obtained will be used for that purpose.
You have additional rights to help protect your interest in the property.
YOU HAVE THE RIGHT TO SELL THE PROPERTY TO OBTAIN MONEY TO PAY OFF THE
MORTGAGE DEBT, OR TO BORROW MONEY FROM ANOTHER LENDING INSTITUTION TO PAY
OFF THIS DEBT. YOU MAY HAVE THE RIGHT TO SELL OR TRANSFER THE PROPERTY
SUBJECT TO THE MORTOAGE q~D A BUYER OR TRANSFEREE WHO WILL ASSUME THE
MORTGAGE DEBT, PROVIDED THAT ALL OUTSTANDING PAYMENTS, CHARGES AND
ATTORNEY'S FEES AND COSTS ARE PAID PRIOR TO OR AT THE SALE, (AND THAT THE
OTHER REQUIREMENTS UNDER THE MORTGAGE ARE SATISFIED). CONTACT US TO
DETERMINE UNDER WHAT CIRCUMSTANCES THE RIGHT MAy EXIST. YOU HAVE THE
RIGHT TO HAVE THIS DEFAULT CURED BY ANY THIRD PARTY ACTING ON YOUR
BEHALF.
If you cure the default, the mortgage will be restored to the same
position as if no default had occurred. However, you are not entitled to
this right to cure your default more than three times in any calendar
year.
DMS5-BRCHPAC (PaGe 2 of 2}
GMAC Mortgage Corporation Servicing
P.O. Box 85071
San Diego, CA 92186-5071
3451 Hammond Ave
P.O. Box 780
Waterloo, IA 50704-0780
NOTICE OF INTENTION TO FORECLOSE AND ACCELERATE LOAN BALANCE
DATE: December 18, 2000
OE TIFIED MAIL NO. Z 'V' nAo'*"a"e
TO: SUZANNE M. THOMAS
217 S SIXTEENTH STREET
CAMP HILL, PA 17011-5535
RE: MORTGAGE LOAN NUMBER: 164381204
MORTGAGED PREMISES: 217 S SIXTEENTH STREET
CAMP HILL, PA 17011-5535
This company is the holder of the FIRST MORTGAGE (AND NOTE) on the above
premises, or is the mortgage service agent for such holder. (Hereinafter
referred to as we, us or ours).
As of the date of this notice, THE MORTGAGE IS IN SERIOUS DEFAULT because
you have not made the October 1, 2000 and subsequent monthly payments as
listed, and/or for other reasons as indicated below:* ·
2 payments ~ $900.56 $1,801.12
1 payments ~ $921.05 $921.05
Accrued late charges ............................... $69.02
NSF Check Fees ...................................... $0.00
All other fees accrued to date ..................... $12.00
* Less available suspense credits .................. $188.66
The total amount now required to cure this default, or in
other words, get caught up in your payments as of the date
of this letter is .................................... $2,614.53
You may cure this default within THIRTY (30) DAYS of the date of this
letter, by paying to us the above amount, plus any additional monthly
payments and late charges which may fall due during this period. Such
payment must be made either by cash, cashier,s check, certified check or
money order, and made at, or sent to: 3451 Hammond Avenue, P.O. Box 780,
Waterloo, IA 50704-0780.
If you do not cure the default within THIRTY (30) DAYS, we intend to
exercise our right to accelerate the mortgage payments. This means that
whatever is owing on the original amount borrowed will be considered due
immediately and you may lose the chance to pay off the original mortgage
in monthly installments. If full payment of the amount of default is not
made within THIRTY (30) DAYS, we also intend to instruct our attorneys to
start a lawsuit to foreclose your mortgaged property. If the mortgage is
foreclosed your mortgaged property will be sold by the Sheriff to pay
DMS5-BRCNPAC (Page 1 of 2)
December 18, 2000
Page 2
164381204
off the debt. If we refer your case to our attorneys, but you cure the
default before they begin legal proceedings against you, you will still
have to pay the reasonable attorney's fees, actually incurred, up to
$50.00.
However, if legal proceedings are started against you, you will have to
pay the reasonable attorney's fees even if they are over $50.00. Any
attorney's fees will be added to whatever you owe us, which may also
include our reasonable costs. If you cure the default within the thirty
day period, you will not be required to pay attorney's fees.
Remember you are also responsible for keeping all real estate taxes
current.
We may also sue you personally for the unpaid balance and all other sums
due under the mortgage. If you have not cured the default within the
thirty day period and foreclosure proceedings have begun, you still have
the right to cure the default and prevent the sale at any time up to one
hour before the Sheriff's foreclosure sale. You may do so by paying the
total amount of the unpaid monthly payments plus any late or other
charges then due, as well as the reasonable attorney's fees and costs
connected with the foreclosure sale (and perform any other requirements
under the mortgage). It is estimated that the earliest date that such a
Sheriff's sale could be held would be approximately one-hundred and fifty
(150) days from the date of this letter. A notice of the date of the
Sheriff's sale will be sent to you before the sale. Of course, the
amount needed to cure the default will increase the longer you wait. You
may find out at any time exactly what the required payment will be by
calling us at the following number: 1~800~850~4622. The payment must be
in cash, cashier's check, certified check or money order and made payable
to us at the address previously stated.
You should realize that a Sheriff's sale will end your ownership of the
mortgaged property and your right to remain in it. If you continue to
live in the property after the Sheriff's sale, a lawsuit could be started
to evict you.
NOTICE - This is an attempt to collect a debt and any information
obtained will be used for that purpose.
You have additional rights to help protect your interest in the property.
YOU HAVE THE RIGHT TO SELL THE PROPERTY TO OBTAIN MONEY TO PAY OFF THE
MORTGAGE DEBT, OR TO BORROW MONEY FROM ANOTHER LENDING INSTITUTION TO PAY
OFF THIS DEBT. YOU MAY HAVE THE RIGHT TO SELL OR TRANSFER THE PROPERTY
SUBJECT TO THE MORTGAGE TO A BUYER OR TRANSFEREE W~O WILL ASSUME THE
MORTGAGE DEBT, PROVIDED THAT ALL OUTSTANDING PAYMENTS, CHARGES AND
ATTORNEY'S FEES AND COSTS ARE PAID PRIOR TO OR AT THE SALE, (AND THAT THE
OTHER REQUIREMENTS UNDER THE MORTGAGE ARE SATISFIED). CONTACT US TO
DETERMINE UNDER WHAT CIRCUMSTANCES THE RIGHT MAY EXIST. YOU HAVE THE
RIGHT TO HAVE THIS DEFAULT CURED BY ANY THIRD PARTY ACTING ON YOUR
BEHALF.
If you cure the default, the mortgage will be restored to the same
position as if no default had occurred. However, you are not entitled to
this right to cure your default more than three times in any calendar
year.
DMS5-BRCHPAC (Page 2 of 2)
Martha E. Von Rosenstiel, P.C. Attorney for Plaintiff
Charlotte K. Hummel
16 South Lansdowne Avenue
P.O. Box 457
Lansdowne, PA 19050
610 623-2660
Attorney I.D.# 63657
GMAC Mortgage Corporation : COURT OF COMMON PLEAS
500 Enterprise Road : Cumberland COUNTY
Horsham, PA 19044-0963 :
Plaintiff :
vs. :
Suzanne M. Thomas aka : Case No: 01-1303 Civil Term
Suzanne Thomas :
97 Richneck Road :
Newport News, VA 23608 :
Defendant :
CERTIFICATION OF SERVICE
CHARLOTTE K. HUMMEL, Esquire, hereby certifies that she is
the attorney for the plaintiff here, and that service of the Civil
Action in Mortgage Foreclosure in the above matter on the
defendants pursuant to Pa R.C.P. Section 403 and Pa. R.C.P.
Section 404 by certified mail April 21, 2001.
This verification is made subject to the penalties of 18 Pa.
C.S. Section 4904 relating to unsworn falsification to
authorities.
Dated: April 25, 2001 Charlotte K. Hummel
Attorney for Plaintiff
· Complete items 1, 2, and 3. Also complete B. Date of Dellve,'y
item 4 if Restricted Delivery is desired. ,~ i/t ~'. o~'
· Print your name and address on the reverse
so that we can return the card to you. [3 Agent
· Attach this card to the back of the mailpiace, X
or on the front if space permits. [~ Addressee
PO ]3OX 22411
[q~:WPO~.~' ~:~g$~ VA. 23609
3. ice Type
2
dA
Martha E. Von Rosenstiel, P.C. Attorney for Plaintiff
Martha E. Von Rosenstiel
16 South Lansdowne Avenue
P.O. Box 457
Lansdowne, PA 19050
610 623-2660
Attorney I.D.# 52634
GMAC Mortgage Corporation COURT OF COMMON PLEAS
500 Enterprise Road CUMBERLAND COUNTY
Horsham PA 19044-0963
Plaintiff
vs. No: 01-1303 Civil Term
Suzanne M. Thomas aka Suzanne Thomas
217 South Sixteenth Street
Camp Hill, PA 17011
Defendants
PRAECIPE
TO THE PROTHONOTARY:
Enter judgment in the sum of $116,921,44 in favor of the above named plaintiff and against
the above named defendants for failure to file an answer in the above action in Mortgage
Foreclosure within twenty (20) days from date of service of the Civil Action, and assess damages.
I hereby certify that the correct addresses of plaintiff and defendants are as follows:
Plaintiff: 500 Enterprise Road
Horsham, PA 19044-0963
Defendants: P.O. Box 22411
Newport News, VA 23609 .f /~
/
M~a E. Vorc-R'6~enstiel
Attorney for Plaintiff
Martha E. Von Rosenstiel, P.C. Attorney for Plaintiff
Martha E. Von Rosenstiel
16 South Lansdowne Avenue
P.O. Box 457
Lansdowne, PA 19050
610 623-2660
Attorney I.D.# 52634
GMAC Mortgage Corporation : COURT OF COMMON PLEAS
500 Enterprise Road : CUMBERLAND COUNTY
Horsham, PA 19044-0963 :
Plaintiff :
vs. : No: 01-1303 Civil Term
Suzanne M. Thomas aka Suzanne Thomas :
217 South Sixteenth Street :
Camp Hill, PA 17011 :
Defendants :
ASSESSMENT OF DAMAGES
TO THE PROTHONOTARY:
Kindly assess damages against the above named defendants as per Civil Action in Mortgage
Foreclosure, as follows:
Total per complaint $114,288.76
Additional interest on unpaid balances
from 03/09/01 to 06/13/01 at $19.30 per diem $ 1,852.80
Additional late charges from 03/15/01
to 05/15/01 at $34.51 per month $ 103.53
Additional escrow deposit 04/10/01 to
06/01/01 at $210.45 per month $ 631.35
Additional monthly inspections from
04/01/01 to 06/01/01 at $15.00 per month $ 45.00
Total assessment /~ _ $116,9~
J Marttra-ETVon Rosenstiel
/~ Attorney for Plaintiff
AND NOW, to wit, this ! ~ day of ~-'~/ , 2001, damages are assessed as above.
('~tiPt~°P~thY[~C% ~
Martha E. Von Rosenstiel, P.C. Attorney for Plaintiff
Martha E. Von Rosenstiel
16 South Lansdowne Avenue
P.O. Box 457
Lansdowne, PA 19050
610 623-2660
Attorney I.D.//52634
GMAC Mortgage Corporation : COURT OF COMMON PLEAS
500 Enterprise Road : CUMBERLAND COUNTY
Horsham, PA 19044-0963 :
Plaintiff :
vs. : No: 01-1303 Civil Term
Suzanne M. Thomas aka Suzanne Thomas :
217 South Sixteenth Street :
Camp Hill, PA 17011 :
Defendant :
AFFIDAVIT OF NON-MILITARY SERVICE
COMMONWEALTH OF PENNSYLVANIA:
SS
COUNTY OF DELAWARE
MARTHA E. VON ROSENSTIEL, being duly sworn according to law deposes and says
that the defendants 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;
That Suzanne M. Thomas aka Suzanne Thomas is over 21 years of age and mailing address
is P.O. Box 22411, Newport News, VA 23609.
Sworn to and Subscribed
Before me this June 11, 2001.
[ ~0~ '0~ ~n? se~!dx3 uo!ss!mmoo ~
/qunoo e~e~eleO "o~oB eu~opsue9
o!lqnd/delON 'll~Bq 3~
9¥3S 9¥1BV/ON
Martha E. Von Rosenstiel, P.C. Attorney for Plaintiff
Martha E. Von Rosenstiel
16 South Lansdowne Avenue
P.O. Box 457
Lansdowne, PA 19050
610 623-2660
Attorney I.D.# 52634
GMAC Mortgage Corporation COURT OF COMMON PLEAS
500 Enterprise Road CUMBERLAND COUNTY
Horsham PA 19044-0963
Plaintiff
vs. No: 01-1303 Civil Term
Suzanne M. Thomas aka Suzanne Thomas
97 Richneck Road
Newport News, VA 23608
Defendants
CERTIFICATION OF SERVICE
MARTHA E. VON ROSENSTIEL, ESQUIRE, hereby certifies that she is the attorney
for the plaintiff herein, and that service of the Notice under Rule 237.5 in the above matter was
made on the defendants on May 15, 2001, as evidenced by the attached postal receipts.
This verification is made subject to the penalties of 18 Pa. C.S. Section 4904 relating to
unswom falsification to authorities.
Esquire
Attorney for Plaintiff
DATED: June 12,2001 ,
Martha E. Von Rosenstiel, ?.C. Attorney for Plaintiff
Charlotte K. Hummel, Esq.
16 South Lansdowne Avenue
P.O. Box 457
Lansdowne, PA 19050
610 623-2660
Attorney I.D.# 52634
GMAC Mortgage Corporation : COURT OF COMMON PLEAS
500 Enterprise Road : Cumberland COUNTY
Horsham, PA 19044-0963 :
Plaintiff :
VS. :
Suzanne M. Thomas : Case No: 01-1303 Civil Term
aka Suzanne Thomas :
97 Richneck Road :
Newport News, VA 23608 :
Defendant :
TO: Suzanne M. Thomas aka Suzanne Thomas
217 S. Sixteenth Street
Camp Hill, PA 17011-553
Date of Notice: May 15, 2001
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
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
U.S* POSTAL SERVICE CERTIFICATE OF MAILING A ' r~ ~n s~amps
so ,.d ;SOCIATION
MAy SE USED FOR DOMESTIC AND INTEBNATIONAL MALL, DOES NOT uite ot
PROVIDE FOR ~NSORANCE--~OST~4ASTER
MARTHA £. YON ROSENSTI£1., P.O.
16 $- I_A~$DOWNF AVl'.
[ R O. BOX 457 "~
--j LANSDOWNE, PA 19050 .
SUZ
ANNE M. THOMAS AKA SUZANNE-~TIq~I~fAS~.~
217 SOUTH SIXTEENTH STREET ~ ~'~ Ii!: '-
CAMP HILL, PA. 17011
PS Form 3817, Mar. 1989
Martha E. Yon Rosenstiel, P.C. Attorney for Plaintiff
Charlotte K. Hummel, Esq.
16 South Lansdowne Avenue
P.O. Box 457
Lansdowne, PA 19050
610 623-2660
Attorney I.D.# 52634
GMAC Mortgage Corporation : COURT OF COMMON PLEAS
500 Enterprise Road : Cumberland COUNTY
Horsham, PA 19044-0963 :
Plaintiff :
VS. :
Suzanne M. Thomas : Case No: 01-1303 Civil Term
aka Suzanne Thomas :
97 R£chneck Road :
Newport News, VA 23608 :
Defendant :
TO: Suzanne M. Thomas aka Suzanne Thomas
P.O. Box 22411
Newport News, VA 23609
Date of Notice: May 15, 2001
IMPORTANT NOTICE
YOU ARE IN DEFAULT BECAUSE YOU HAVE FAILED TO ENTER A WRITTEN
APP~I~RJ~CE PERSON~.~LY OR BY ATTO~IEY ~ FILE IN }~RITING W~TH THE
COURT YOUR DEFENSES OR OBJECTIONS TO TEE CLAIMS SET FORTH AGAINST
YOU. UI~ESS YOU ACT WITHIN TEN DAYS ~ROM THE DATE OF THIS NOTICE,
A JUDGMENT MAY BE ENTERED AGAINST YOU WITHOUT A HEARING AND YOU MAY
LOSE YOUR PROPERTY OR OTHER IMPORTJ~.NT RIGHTS. YOU SHOULD TJ~r~l THIS
NOTICE TO A LAWYER AT ONCE. IF YOU DO NOT HAVE A LAWYER OR CA/~NOT
........... ~^'~ '"~ ~T.?.~WTNG OFFICE TO FIND OUT
U.S. POSTAL SERVICE CERTIFICATE OF MAILING Affi~l~'~re in ~Affi re in stemps
MAY BE USED FOR DOMESTIC AND rNTERNATIONAL MAIL, DOES NOT · and
.ROV,DE EOR IW/14~F~F~q~N~Ir~ENSTEL, p,p,, ~ uire of
,(,i~,d ~,or,:LAN~DUWNI:,16 S.p. LANSDOWNE AVE.0. BOXFA451190.50 . --~'~"-. . g cTM ;OCIATION
One piece of ordinary mall addressed to:
NEWPOI~T NEWS, VA. 23609 m ~ It!!
PS Form 3817, Mar. 1989
PRAECIPE FOR WRIT OF EXECUTION
COMMONWEALTH OF PENNSYLVANIA
COUNTY OF CUMBERLAND
GMAC Mortgage Corporation
v. NO. 01-1303 Civil Term
Suzanne M. Thomas aka Suzanne Thomas
Praecipe for Writ of Execution
TO THE PROTHONOTARY:
Issue Writ of Execution in thc above matter:
AMOUNT DUE $116,921.44
INTEREST from 06/13/01 to SALE DATE
At $19.30 per diem $
(Costs to be added) $ ~
Rosenstiel
A~omey for Plaintiff
DESCRIPTION
ALL THAT CERTAIN tract of land, situate in the Borough of Camp Hill, County of Cumberland,
and Commonwealth of Pennsylvania, more particularly bounded and described as follows, to wit:
BEGINNING at a point two hundred forty (240) feet South of the Southeast corner of Second and
Sixteenth (formerly Jackson) Streets; thence Eastwardly along the South side line of Lot No. 61, one
hundred fifty (150) feet to a point in a twenty (20) feet wide alley; thence Southwardly along the
West side of said alley forty (40) feet to a point; thence Westwardly along the Northern line of Lot
No. 63 one hundred fifty (150) feet to a point in Sixteenth Street; thence Northwardly along the East
side of said Sixteenth Street forty (40) feet to a place of beginning.
It being Lot No. 62 on the Plan of Lots known as Greater Harrisburg, Estate of Jackson Free,
recorded in the Recorder's Office at Carlisle, Pennsylvania, in Plan Book 1, Page 20.
Tax Parcel #01-22-0826-062
WRIT OF EXECUTION - (MORTGAGE FORECLOSURE)
P.R.C.P. 3180 to 3183 and Rule 3257
GMAC Mortgage Corporation
IN THE COURT OF COMMON PLEAS OF
CUMBERLAND COUNTY, PENNSYLVANIA
vs. No. 01-1303 Term, 20 E.D.
No. Term, 20- A.D.
Suzanne M. Thomas, aka Susanne Thomas
WRIT OF EXECUTION
(MORTGAGE FORECLOSURE)
Commonwealth of Pennsylvania:
County of :
TO THE SHERIFF OF CUMBERLAND COUNTY, PENNSYLVANIA:
To satisfy the judgment, interest and costs in the above matter you are directed to levy upon and
sell the following described property (specifically describe property below):
PREMISES: 217 S. Sixteenth Street
Camp Hill, PA 17011
Amount Due $116,288.76
Interest from 06/14/01 to
SALE DATE ~ $19.30 per diem $
Attorney's fees $
Costs $
Total $
as endorsed.
Prothonotary, Common Pleas Court of
Dated Cumberland County, Penna.
(SEAL)
By:
Deputy
Martha E. Von Rosenstiel, P.C. Attorney for Plaintiff
Martha E. Von Rosenstiel
16 South Lansdowne Avenue
P.O. Box 457
Lansdowne, PA 19050
610 623-2660
Attorney I.D.# 52634
GMAC Mortgage Corporation : COURT OF COMMON PLEAS
500 Enterprise Road : CUMBERLAND COUNTY
Horsham PA 19044-0963 :
Plaintiff :
vs. : No: 01-1303 Civil Term
Suzanne M. Thomas aka Suzanne Thomas :
217 South Sixteenth Street :
Camp Hill, PA 17011 :
Defendants :
CERTIFICATION
I hereby certify that I am the attorney of record for the plaintiffin this action against real
property, and further certify that the property is:
( ) FHA Tenant Occupied or Vacant
( ) Commercial
( ) As a result of a Complaint in Assumpsit
(X) That the plaintiff has complied in all respects with
Section 403 of the Mortgage Assistance Action
Including but not limited to:
(a) Service of the notice on defendants
(b) Expiration of 30 days since service of the Notice
(c) Defendants failure to request or appear at the meeting with
the mortgagee or Consumer Counseling Agency
(d) Defendants failure to file application with the
Homeowners Emergency Assistance Program.
I further agree to indemnify and hold harmless the Sheriff for any false~ein.
· Vo . .
Dated: June 11, 2001
Martha E. Von Rosenstiel, P.C. Attorney for Plaintiff
Martha E. Von Rosenstiel
16 South Lansdowne Avenue
P.O. Box 457
Lansdowne, PA 19050
610 623-2660
Attorney I.D.# 52634
GMAC Mortgage Corporation COURT OF COMMON PLEAS
500 Enterprise Road CUMBERLAND COUNTY
Horsham PA 19044-0963
Plaintiff
vs. No: 01-1303 Civil Term
Suzanne M. Thomas aka Suzanne Thomas
217 South Sixteenth Street
Camp Hill, PA 17011
Defendants
AFFIDAVIT OF NOTICE PURSUANT TO RULE 3129.1
COMMONWEALTH OF PENNSYLVANIA:
SS
COUNTY OF DELAWARE
MARTHA E. VON ROSENSTIEL, attorney for the plaintiff in the above action, sets forth
as of the date the praecipe for the Writ of Execution was filed the following information
concerning the real property located at 217 South Sixteenth Street, Camp Hill, PA 17011.
1. Name and address of owners(s) or reputed owner(s)
Suzarme M. Thomas aka Suzanne Thomas
P.O. Box 22411
Newport News, VA 23609
2. Name and address of defendant(s) in the judgment:
Suzarme M. Thomas aka Suzanne Thomas
P.O. Box 22411
Newport News, VA 23609
3. Name and address of every judgment creditor whose judgment is a record lien on the real
property to be sold:
Westgate Garden Assoc.
1149 Columbus Ave.
Lemoyne, PA 17043
4. Name and address of the last recorded holder of every mortgage of record:
NONE
5. Name and address of every other person who has any record lien on the property:
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:
NONE
7. Name and address of every other person of whom plaintiff has knowledge who has any
interest in the property which may be affected by the sale:
Family Court/Domestic Relations Office
One Courthouse Square
Carlisle, PA 17013
Dept. of Public Welfare
Box 2675
Harrisburg, PA 17105
Inheritance Tax Bureau
Harrisburg, PA 17105
U.S. Inheritance Tax Bureau
Washington, DC 20530
Commonwealth Dept. of Revenue
Inheritance Tax Division
1400 Spring Garden Street
Philadelphia, PA 19130
Internal Revenue Service
Federal Estate Tax, Chief
Examiner's Div. Grp. 18120
P.O. Box 2040
Philadelphia, PA 19105
Register of Wills of Cumberland
One Courthouse Square
Carlisle, PA 17013
MARTHA E. YON ROSENSTIEL, P.C.
ATTORNEY AT LAW
16 SOUTH LANSDOWNE AVENUE
P.O. BOX 457
LANSDOWNE, PA 19050
PHONE(610)623 -2660 FAX(610)623 -2745
June 11,2001
TO: Westgate Garden Assoc.
1149 Columbus Ave.
Lemoyne, PA 17043
RE: NOTICE OF SALE OF REAL PROPERTY:
217 South Sixteenth Street Camp Hill, PA 17011
Amount of Judgment: $116,921.44
Date of Judgment: June 13, 2001
Court Term and Number: Court of Common Pleas of
Cumberland County, Doeke~ 01-1303 Civil Term
Plaintiff: GMAC Mortgage Corporation
Defendants: Suzanne M. Thomas aka Suzanne Thomas
Dear Sir/Madam:
Please be advised that the property and residential dwelling, located at and known as 217
South Sixteenth Street Camp Hill, PA 17011 will be sold by the Sheriff of Cumberland County on
September 5,2001 at 10:00 a.m. in the Cumberland County Court House, One Court House
Square, Carlisle, PA 17013.
This notice is being sent to you because my records indicate that you hold a lien on the
property secondary to the first mortgage, which is being foreclosed.
This property and improvements are being sold pursuant to a judgment entered as indicated
above in favor of the above named plaintiff, and against the above named defendants.
The name of the owners, real owners, and reputed owners of the aforementioned property are
Suzanne M. Thomas aka St~xtme Thomas.
A schedule of distribution will be filed by the Sheriff on a date specified by the Sheriff no
later than 30 days after said sale, and distribution will be made in accordance with the schedule
unless exceptions are filed thereto within ten (10) days after the date of the filing of said schedule.
You should check with the Sheriff's Office by calling 717 240-6391 to determine the actual date of
the filing of the schedule.
Sincerely yours,
MARTHA E. VON ROSENSTIEL, P.C.
ATTORNEY AT LAW
16 SOUTH LANSDOWNE AVENUE
P.O. BOX 457
LANSDOWNE, PA 19050
PHONE(610)623-2660 FAX(610)623-2745
June 11, 2001
TO: Family Court/Domestic Relations Office
One Courthouse Square
Carlisle, PA 17013
RE: NOTICE OF SALE OF REAL PROPERTY:
217 South Sixteenth Street Camp Hill, PA 17011
Amount of Judgment: $116,921.44
Date of Judgment: June 13, 2001
Court Term and Number: Court of Common Pleas of
Cumberland County, Doeke~ 01-1303 Civil Term
Plaintiff.' GMAC Mortgage Corporation
Defendants: Suzanne M. Thomas aka Suzanne Thomas
Dear Sir/Madam:
Please be advised that the property and residential dwelling, located at and known as 217
South Sixteenth Street Camp Hill, PA 17011 will be sold by the Sheriff of Cumberland County on
September 5, 2001 at 10:00 a.m. in the Cumberland County Court House, One Court House
Square, Carlisle, PA 17013.
This notice is being sent to you because my records indicate that you hold a lien on the
property secondary to the first mortgage, which is being foreclosed.
This property and improvements are being sold pursuant to a judgment entered as indicated
above in favor of the above named plaintiff, and against the above named defendants.
The name of the owners, real owners, and reputed owners of the aforementioned property are
Suzanne M. Thomas aka Suzanne Thomas.
A schedule of distribution will be filed by the Sheriff on a date specified by the Sheriff no
later than 30 days after said sale, and distribution will be made in accordance with the schedule
unless exceptions are filed thereto within ten (10) days after the date of the filing of said schedule.
You should check with the Sheriff's Office by calling 717 240-6391 to determine the actual date of
the filing of the schedule.
Sincerely yours,
Ro~-nsticl -t~
MARTHA E. VON ROSENSTIEL, P.C.
ATTORNEY AT LAW
16 SOUTH LANSDOWNE AVENUE
P.O. BOX 457
LANSDOWNE, PA 19050
PHONE(610)623 -2660 FAX(610)623 -2745
June 1 I, 2001
TO: Dept. of Public Welfare
Box 2675
Harrisburg, PA 17105
RE: NOTICE OF SALE OF REAL PROPERTY:
217 South Sixteenth Street Camp Hill, PA 17011
Amount of Judgment: $116,921.44
Date of Judgment: June 13, 2001
Court Term and Number: Court of Common Pleas of
Cumberland County, Doeket~ 01-1303 Civil Term
Plaintiff.' GMAC Mortgage Corporation
Defendants: Suzanne M. Thomas aka Suzanne Thomas
Dear Sir/Madam:
Please be advised that the property and residential dwelling, located at and known as 217
South Sixteenth Street Camp Hill, PA 17011 will be sold by the Sheriff of Cumberland County on
September 5, 2001 at 10:00 a.m. in the Cumberland County Court House, One Court House
Square, Carlisle, PA 17013.
This notice is being sent to you because my records indicate that you hold a lien on the
property secondary to the first mortgage, which is being foreclosed.
This property and improvements are being sold pursuant to a judgment entered as indicated
above in favor of the above named plaintiff, and against the above named defendants.
The name of the owners, real owners, and reputed owners of the aforementioned property are
Suzanne M. Thomas aka Suzanne Thomas.
A schedule of distribution will be filed by the Sheriff on a date specified by the Sheriff no
later than 30 days after said sale, and distribution will be made in accordance with the schedule
unless exceptions are filed thereto within ten (10) days after the date of the filing of said schedule.
You should check with the Sheriff's Office by calling 717 240-6391 to determine the actual date of
the filing of the schedule.
Sincerely yours,
M~. Von Ro~n~tiel ~
MARTHA E. VON ROSENSTIEL, P.C.
ATTORNEY AT LAW
16 SOUTH LANSDOWNE AVENUE
P.O. BOX 457
LANSDOWNE, PA 19050
PHONE(610)623 -2660 FAX(610)623 -2745
June 11, 2001
TO: Inheritance Tax Bureau
Harrisburg, PA 17105
RE: NOTICE OF SALE OF REAL PROPERTY:
217 South Sixteenth Street Camp Hill, PA 17011
Amount of Judgment: $116,921.44
Date of Judgment: June 13, 2001
Court Term and Number: Court of Common Pleas of
Cumberland County, Docke~ 01-1303 Civil Term
Plaintiff.' GMAC Mortgage Corporation
Defendants: Suzanne M. Thomas aka Suzanne Thomas
Dear Sir/Madam:
Please be advised that the property and residential dwelling, located at and known as 217
South Sixteenth Street Camp Hill, PA 17011 will be sold by the Sheriff of Cumberland County on
September 5, 2001 at 10:00 a.m. in the Cumberland County Court House, One Court House
Square, Carlisle, PA 17013.
This notice is being sent to you because my records indicate that you hold a lien on the
property secondary to the first mortgage, which is being foreclosed.
This property and improvements are being sold pursuant to a judgment entered as indicated
above in favor of the above named plaintiff, and against the above named defendants.
The name of the owners, real owners, and reputed owners of the aforementioned property are
Suzarme M. Thomas aka Suzarme Thomas.
A schedule of distribution will be filed by the Sheriff on a date specified by the Sheriff no
later than 30 days after said sale, and distribution will be made in accordance with the schedule
unless exceptions are filed thereto within ten (10) days after the date of the filing of said schedule.
You should check with the Sheriff's Office by calling 717 240-6391 to determine the actual date of
the filing of the schedule.
Sincerely yours,
MARTHA E. VON ROSENSTIEL, P.C.
ATTORNEY AT LAW
16 SOUTH LANSDOWNE AVENUE
P.O. BOX 457
LANSDOWNE, PA 19050
PHONE(610)623-2660 FAX(610)623-2745
June 11, 2001
TO: U.S. Inheritance Tax Bureau
Washington, DC 20530
RE: NOTICE OF SALE OF REAL PROPERTY:
217 South Sixteenth Street Camp Hill, PA 17011
Amount of Judgment: $116,921.44
Date of Judgment: June 13, 2001
Court Term and Number: Court of Common Pleas of
Cumberland County, Dockeff4 01-1303 Civil Term
Plaintiff: GMAC Mortgage Corporation
Defendants: Suzanne M. Thomas aka Suzanne Thomas
Dear Sir/Madam:
Please be advised that the property and residential dwelling, located at and known as 217
South Sixteenth Street Camp Hill, PA 17011 will be sold by the Sheriff of Cumberland County on
September 5, 2001 at 10:00 a.m. in the Cumberland County Court House, One Court House
Square, Carlisle, PA 17013.
This notice is being sent to you because my records indicate that you hold a lien on the
property secondary to the first mortgage, wh/ch is being foreclosed.
This property and improvements are being sold pursuant to a judgment entered as indicated
above in favor of the above named plaintiff, and against the above named defendants.
The name of the owners, real owners, and reputed owners of the aforementioned property are
Suzanne M. Thomas aka Suzanne Thomas.
A schedule of distribution will be filed by the Sheriff on a date specified by the Sheriff no
later than 30 days after said sale, and distribution will be made in accordance with the schedule
unless exceptions are filed thereto within ten (10) days after the date of the filing of said schedule.
You should check with the Sheriff's Office by calling 717 240-6391 to determine the actual date of
the filing of the schedule.
Sincerely yours,
Mar~hadon Ros¢llsti¢l ~
MARTItA E, VON ROSENSTIEL, P.C.
ATTORNEY AT LAW
16 SOUTH LANSDOWNE AVENUE
P.O. BOX 457
LANSDOWNE, PA 19050
PHONE(610)623 -2660 FAX(610)623 -2745
June 11, 2001
TO: Commonwealth Dept. of Revenue
Inheritance Tax Division
1400 Spring Garden Street
Philadelphia, PA 19130
RE: NOTICE OF SALE OF REAL PROPERTY:
217 South Sixteenth Street Camp Hill, PA 17011
Amount of Judgment: $116,921.44
Date of Judgment: June 13, 2001
Court Term and Number: Court of Common Pleas of
Cumberland County, Dockeff4 01-1303 Civil Term
Plaintiff.' GMAC Mortgage Corporation
Defendants: Suzanne M. Thomas aka Suzanne Thomas
Dear Sir/Madam:
Please be advised that the property and residential dwelling, located at and known as 217
South Sixteenth Street Camp Hill, PA 17011 will be sold by the Sheriffof Cumberland County on
September 5, 2001 at 10:00 a.m. in the Cumberland County Court House, One Court House
Square, Carlisle, PA 17013.
This notice is being sent to you because my records indicate that you hold a lien on the
property secondary to the first mortgage, which is being foreclosed.
This property and improvements are being sold pursuant to a judgment entered as indicated
above in favor of the above named plaintiff, and against the above named defendants.
The name of the owners, real owners, and reputed owners of the aforementioned property are
Suzanne M, Thomas aka Suzanne Thomas.
A schedule of distribution will be filed by the Sheriff on a date specified by the Sheriff no
later than 30 days after said sale, and distribution will be made in accordance with the schedule
unless exceptions are filed thereto within ten (10) days after the date of the filing of said schedule.
You should check with the Sheriffs Office by calling 717 240-6391 to determine the actual date of
the filing of the schedule.
Sincerely yours,
~ , 'hrtha~/'/' Von Roocnatm~~'~
MARTHA E. VON ROSENSTIEL, P.C.
ATTORNEY AT LAW
16 SOUTH LANSDOWNE AVENUE
P.O. BOX 457
LANSDOWNE, PA 19050
PHONE(610)623-2660 FAX(610)623 -2745
June I 1,2001
TO: Imernal Revenue Service
Federal Estate Tax, Chief
Examiner's Div. Grp. 18120
P.O. Box 2040
Philadelphia, PA 19105
RE: NOTICE OF SALE OF REAL PROPERTY:
217 South Sixteenth Street Camp Hill, PA 17011
Amount of Judgment: $116,921.44
Date of Judgment: June 13, 2001
Court Term and Number: Court of Common Pleas of
Cumberland County, Dockeff4 01-1303 Civil Term
Plaintiff: GMAC Mortgage Corporation
Defendants: Suzanne M. Thomas aka Suzanne Thomas
Dear Sir/Madam:
Please be advised that the property and residential dwelling, located at and known as 217
South Sixteenth Street Camp Hill, PA 17011 will be sold by the Sheriff of Cumberland County on
September 5, 2001 at 10:00 a.m. in the Cumberland County Court House, One Court House
Square, Carlisle, PA 17013.
This notice is being sent to you because my records indicate that you hold a lien on the
property secondary to the first mortgage, which is being foreclosed.
This property and improvements are being sold pursuant to a judgment entered as indicated
above in favor of the above named plaintiff, and against the above named defendants.
The name of the owners, real owners, and reputed owners of the aforementioned property are
Suzanne M. Thomas aka Suzanne Thomas.
A schedule of distribution will be filed by the Sheriff on a date specified by the Sheriff no
later than 30 days after said sale, and distribution will be made in accordance with the schedule
unless exceptions are filed thereto within ten (I0) days after the date of the filing of said schedule.
You should check with the Sheriff's Office by calling 717 240-6391 to determine the actual date of
the filing of the schedule.
Sincerely yours,
~. Von~Rosensti~~-
MARTHA E. VON ROSENSTIEL, P.C.
ATTORNEY AT LAW
16 SOUTH LANSDOWNE AVENUE
P.O. BOX 457
LANSDOWNE, PA 19050
PHONE(610)623-2660 FAX(610)623 -2745
June 11,2001
TO: Register of Wills of Cumberland
One Courthouse Square
Carlisle, PA 17013
RE: NOTICE OF SALE OF REAL PROPERTY:
217 South Sixteenth Street Camp Hill, PA 17011
Amount of Judgment: $116,921.44
Date of Judgment: June 13, 2001
Court Term and Number: Court of Common Pleas of
Cumberland County, Docketg 01-1303 Civil Term
Plaintiff: GMAC Mortgage Corporation
Defendants: Suzanne M. Thomas aka Suzanne Thomas
Dear Sir/Madmn:
Please be advised that the property and residential dwelling, located at and known as 217
South Sixteenth S~reet Camp Hill, PA 17011 will be sold by the Sheriff of Cumberland County on
September 5,2001 at 10:00 a.m. in the Cumberland County Court House, One Court House
Square, Carlisle, PA 17013.
This notice is being sent to you because my records indicate that you hold a lien on the
property secondary to the first mortgage, which is being foreclosed.
This property and improvements are being sold pursuant to a judgment entered as indicated
above in favor of the above named plaintiff, and against the above named defendants.
The name of the owners, real owners, and reputed owners of the aforementioned property are
Suzanne M. Thomas aka Suzanne Thomas.
A schedule of distribution will be filed by the Sheriff on a date specified by the Sheriffno
later than 30 days after said sale, and distribution will be made in accordance with the schedule
unless exceptions are filed thereto within ten (10) days after the date of the filing of said schedule.
You should check with the Sheriff's Office by calling 717 240-6391 to determine the actual date of
the filing of the schedule.
Sincerely yours,
/
Martha E. Von Rosenstiel, P.C. Attorney for Plaintiff
Martha E. Von Rosenstiel
16 South Lansdowne Avenue
P.O. Box 457
Lansdowne, PA 19050
610 623-2660
Attorney I.D.# 52634
GMAC Mortgage Corporation : COURT OF COMMON PLEAS
500 Enterprise Road : CUMBERLAND COUNTY
Horsham, PA 19044-0963 :
Plaintiff :
vs. : No: 01-1303 CiviiTerm
Suzarme M. Thomas aka Suzarme Thomas :
217 South Sixteenth Street :
Camp Hill, PA 17011 :
Defendant :
THIS IS AN ATTEMPT TO COLLECT A DEBT ANY INFORMATION OBTAINED
WILL
BE USED FOR THAT PURPOSE
NOTICE OF SHERIFF'S SALE OF REAL PROPERTY
TO: Suzanne M. Thomas aka Suzanne Thomas
97 Richneck Road
Newport News, VA 23608
Your house and/or real estate at 217 South Sixteenth Street, Camp Hill, PA 17011 is
scheduled to be sold at Sheriffs Sale on September 5, 2001 at 10:00 a.m. to enfome the court
judgment of $116,921.44 obtained by GMAC Mortgage Corporation against you.
NOTICE OF OWNERS RIGHTS
YOU MAY BE ABLE TO PREVENT THIS SHERIFF'S SALE
To prevent this Sheriff's Sale you must take IMMEDIATE action:
1. The sale will be cancelled if you pay to GMAC Mortgage Corporation the back
payments, late charges, costs and reasonable attorney's fees due. To find out how much you must
pay, you may call 610 623-2660.
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 contact an attorney to assert your rights. The sooner you contact one, the more
chance you will have of stopping the sale. (See notice on page two on how to obtain an attorney)
YOU MAY STILL BE ABLE TO SAVE YOUR PROPERTY AND YOU HAVE OTHER
RIGHTS EVEN IF THE SHERIFF'S SALE DOES TAKE PLACE.
1. If the Sheriff's Sale is not stopped, your property will be sold to the highest bidder. You
may find out the bid price by calling 610 623-2660.
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 the 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 610 623-2660.
4. If the mount 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 a 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 on a date to be
announced by the Sheriff. This schedule will state who will be receiving that money. The money
will be paid out in accordance with this schedule unless exceptions (masons why the proposed
distribution is wrong) are filed with the Sheriff within ten (10) days after the Schedule of
Distribution is posted.
7. You may also have other rights and defenses, or ways of getting your house 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.
COURT ADMINISTRATOR
4TM FLOOR CUMBERLAND COUNTY COURT HOUSE
CARLISLE, PA 17013
Telephone: 717 240-6200
CLAIM FOR EXEMPTION
To the Sheriff:
I, the above named defendant, claim exemption of property from levy or attachment:
(t) From my real property in my possession which has been levied upon,
(a) I desire that my $300.00 statutory exemption be set-aside in kind (specify
real property to be set-aside in kind):
I request a prompt court hearing to determine the exemption. Notice of the hearing should
be given to me at
(Address) (Telephone Number)
I verify that the statements made in this Claim for Exemption are true and correct. I
understand that false statements herein are made subject to the penalties of 18 Pa. C.S. Section
4904 relating to unsworn falsification to authorities.
Date:
Signature
THIS CLAIM TO BE FILED WITH THE OFFICE OF THE SHERIFF
CUMBERLAND COUNTY COURTHOUSE CARLISLE, PA 17013
717 240-6391
WRIT OF EXECUTION - (MORTGAGE FORECLOSURE)
P.R.C.P. 3180 to 3183 and Rule 3257
GMAC Mortgage Corporation
IN THE COURT OF COMMON PLEAS OF
CUMBERLAND COUNTY, PENNSYLVANIA
vs. , No. 0I-I303 Term, 20 E.D.
No. Term, 20- A.D.
Suzanne M. Thomas, aka Susanne Thomas
WRIT OF EXECUTION
(MORTGAGE FORECLOSURE)
Commonwealth of Pennsylvania:
County of :
TO THE SHERIFF OF CUMBERLAND COUNTY, PENNSYLVANIA:
To satisfy the judgment, interest and costs in the above matter you are directed to levy upon and
sell the following described property (specifically describe property below):
PRE1MISES: 217 S. Sixteenth Street
Camp Hill, PA 17011
Amount Due $116,288.76
Interest from 06/14/01 to
SALE DATE ~ $19.30 per diem $
Attorney's fees $
Costs $
Total $
as endorsed.
Prothonotary, Corarnon Pleas Court of
Dated Cumberland County, Penna.
(SEAL)
By:
Deputy
DESCRIPTION
ALL THAT CERTAIN tract of land, situate in the Borough of Camp Hill, County of Cumberland,
and Commonwealth of Pennsylvania, more particularly bounded and described as follows, to wit:
BEGINNING at a point two hundred forty (240) feet South of the Southeast corner of Second and
Sixteenth (formerly Jackson) Streets; thence Eastwardly along the South side line of Lot No. 61, one
hundred fift~y (150) feet to a point in a twenty (20) feet wide alley; thence Southwardly along the
West side of said alley forty (40) feet to a point; thence Westwardly along the Northern line of Lot
No. 63 one hundred fifty (150) feet to a point in Sixteenth Street; thence Northwardly along the East
side of said Sixteenth Street forty (40) feet to a place of beg~nnin$.
It being Lot No. 62 on the Plan of Lots known as Greater Harrisburg, Estate of Jackson Free,
recorded in the Recorder's Office at Carlisle, Pennsylvania, in Plan Book 1, Page 20.
Tax Parcel #01-22-0826-062
Martha E. Von Rosenstiel, P.C. Attomey for Plaintiff
Martha E. Von Rosenstiel
16 South Lansdowne Avenue
P.O. Box 457
Lansdowne, PA 19050
610 623-2660
Attorney I.D.# 52634
GMAC Mortgage Corporation COURT OF COMMON PLEAS
500 Enterprise Road Cumberland COUNTY
Horsham PA 19044-0963
Plaintiff
vs. No: 01-1303 Civil Term
Suzanne M. Thomas aka Suzanne Thomas
97 Richneck Road
Newport News, VA 23608
Defendants
PRAECIPE TO SUBSTITUTE ATTORNEY
TO THE PROTHONOTARY:
Kindly withdraw my appearance as attorney for the plaintiff in the above captioned action.
Charlotte K. Hummel, Esq.
TO THE PROTHONOTARY:
Kindly enter my appearance as attorney flr/0~pl)intiff in/ ~ the aboveffcap/~°ned action.
' Martha E. Von Rosenstiel
Dated: June 11, 2001
#8202
Martha E. Von Rosenstiel, P.C. Attorney for Plaintiff
Martha E. Von Rosenstiel
16 South Lansdowne Avenue
P.O. Box 457
Lansdowne, PA 19050
610 623-2660
Attorney I.D.# 52634
GMAC Mortgage Corporation : COURT OF COMMON PLEAS
500 Enterprise Road : CUMBERLAND COUNTY
Horsham PA 19044-0963 :
:
Plaintiff :
vs. : No: 01-1303 Civil Term
Suzanne M. Thomas aka Suzanne Thomas :
217 South Sixteenth Street :
Camp Hill, PA 17011 :
Defendants :
AFFIDAVIT OF SERVICE OF NOTICES PURSUANT TO RULE 3129.1
COMMONWEALTH OF PENNSYLVANIA:
SS
COUNTY OF DELAWARE
MARTHA E. VON ROSENSTIEL, attorney for the plaintiff in the above action, hereby
certifies that service of the Notice ttnder Rule 3129.1, in the above matter was made on the
defendants via certified mail, return receipt requested and on all interested parties, set forth below,
by regular first class mail, postage prepaid, as evidenced by the attached certificates of mailing:
1. Name and address of every judgment creditor whose judgment is a record lien on the
real property to be sold:
Westgate Garden Assoc.
1149 Columbus Ave.
Lemoyne, PA 17043
2. Name and address of the last recorded holder of every mortgage of record:
NONE
3. Name and address of every other person who has any record lien on the property:
NONE
4. Name and address of every other person who has any record interest in the property and
whose interest may be affected by the sale:
Family Court/Domestic Relations Office
One Courthouse Square
Carlisle, PA 17013
Dept. of Public Welfare
Box 2675
Harrisburg, PA 17105
Inheritance Tax Bureau
Harrisburg, PA 17105
U.S. Inheritance Tax Bureau
Washington, DC 20530
Commonwealth Dept. of Revenue
Inheritance Tax Division
1400 Spring Garden Street
Philadelphia, PA 19130
Internal Revenue Service
Federal Estate Tax, Chief
Examiner's Div. Grp. 18120
P.O. Box 2040
Philadelphia, PA 19105
Register of Wills of Cumberland
One Courthouse Square
Carlisle, PA 17013
I verify that the statements made in this affidavit are true and correct to the best of my
personal knowledge or information and belief. I understand that false statements herein are made
subject to the penalties of 18 Pa. C.S. Section 4904 relating to unsworn falsification to authorities.
~e~ ~oVr°l~a~n°~stiel
For Accountable Mall
~
~ ~ = ~
· Complete items 1, 2, and 3. Also.i~ A. R~v~by~P~ntCl~) . Date~f ~ve~
it~ 4 if Restrict~ Delivew is desired.
a Aff~ch this c~ to the back of the mailpiece, ~d~
~ ~ the ~nt E space ~its. D, is d~~t ~m ~ 17 -~ Yes
SUZANNE M, THO~S aka
Sg'ZANNE THO~S
651 SOUTH ANN STREET
3. ~:e Ty~
LANCASTER, PA. 17602 c~ ~,~t ~ ~pm~ Mail
4. Res~ ~l}v~ ~ F~) ~ Yes
PS Fo~ 381 1, Ju~y 1999 Dom~fic Retu~
GMAC Mortgage Corporation In The Court of Common Pleas of
VS Cumberland County, Pennsylvania
Suzanne M. Thomas aJk/a Writ No. 2001-1303 Civil Term
Suzanne Thomas
R. Thomas Kline, Sheriff, who being duly sworn according to law, states this writ
is returned STAYED pursuant to instructions from Attorney Martha E, Von Rosensteil.
Sheriff's Costs:
Docketing 30.00
Surcharge 20.00
Posting Handbills 15.00
Law Library .50
Prothonotary 1.00
Share of Bills 25.66
Mileage 19.50
Levy 15.00
Advertising 15.00
Certified Mail 9.58
Potmdage 12.41
Postpone Sale 20.00
Law Journal 223.55
Patriot News 225.60
$632.80 paid by attorney
Sworn and subscribed to before me So Answers:
This ? ~-~ day of ,4.ff~,,.,~ i ~~. ~~
R. Thomas Kline, Sheriff
2001, A.D.~ D ~/~
Prothonot~ Rgal Est~e Deputy
~41 ~S~ff
Martha E. Von Rosenstiel, P.C. Attorney for Plaintiff
Martha E. Von Rosenstiel
16 South Lansdowne Avenue
P.O. Box 457
Lansdowne, PA 19050
610 623-2660
Attorney I.D.//52634
GMAC Mortgage Corporation COURT OF COMMON PLEAS
500 Enterprise Road CUMBERLAND COUNTY
Horsham PA 19044-0963
Plaintiff
vs. No: 01-1303 Civil Term
Suzanne M. Thomas aka Suzanne Thomas
217 South Sixteenth Street
Camp Hill, PA 17011
Defendants
AFFIDAVIT OF NOTICE PURSUANT TO RULE 3129.1
COMMONWEALTH OF PENNSYLVANIA:
SS
COUNTY OF DELAWARE
MARTHA E. VON ROSENSTIEL, attorney for the plaintiff in the above action, sets forth
as of the date the praecipe for the Writ of Execution was filed the following information
concerning the real property located at 217 South Sixteenth Street, Camp Hill, PA 17011.
1. Name and address of owners(s) or reputed owner(s)
Suzarme M. Thomas aka Suzanne Thomas
P.O. Box 22411
Newport News, VA 23609
2. Name and address of defendant(s) in the judgment:
Suzanne M. Thomas aka Suzarme Thomas
P.O. Box 22411
Newport News, VA 23609
3. Name and address of every judgment creditor whose judgment is a record lien on the real
property to be sold:
Westgate Garden Assoc.
1149 Columbus Ave.
Lemoyne, PA 17043
4. Name and address of the last recorded holder of every mortgage of record:
NONE
5. Name and address of every other person who has any record lien on the property:
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:
NONE
7. Name and address of every other person of whom plaintiff has knowledge who has any
interest in the property which may be affected by the sale:
Family Court/Domestic Relations Office
One Courthouse Square
Carlisle, PA 17013
Dept. of Public Welfare
Box 2675
Harrisburg, PA 17105
Inheritance Tax Bureau
Harrisburg, PA 17105
U.S. Inheritance Tax Bureau
Washington, DC 20530
Commonwealth Dept. of Revenue
Inheritance Tax Division
1400 Spring Garden Street
Philadelphia, PA 19130
Internal Revenue Service
Federal Estate Tax, Chief
Examiner's Div. Grp. 18120
P.O. Box 2040
Philadelphia, PA 19105
Register of Wills of Cumberland
One Courthouse Square
Carlisle, PA 17013
MARTHA E. VON ROSENSTIEL, P.C.
ATTORNEY AT LAW
16 SOUTH LANSDOWNE AVENUE
P.O. BOX 457
LANSDOWNE, PA 19050
PHONE(610)623-2660. FAX(610)623-2745
June 11, 2001
TO: Westgate Garden Assoc.
1149 Columbus Ave.
Lemoyne, PA 17043
RE: NOTICE OF SALE OF REAL PROPERTY:
217 South Sixteenth Street Camp Hill~ PA 17011
Amount of Judgment: $116,921.44
Date of Judgment: June 13, 2001
Court Term and Number: Court of Common Pleas of
Cumberland County, Docket~ 01-1303 Civil Term
Plaintiff.' GMAC Mortgage Corporation
Defendants: Suzanne M. Thomas aka Suzanne Thomas
Dear Sir/Madam:
Please be advised that the property and residential dwelling, located at and known as 217
South Sixteenth Street Camp Hill, PA 17011 will be sold by the Sheriff of Cumberland County on
September 5, 2001 at 10:00 a.m. in the Cumberland County Court House, One Court House
Square, Carlisle, PA 17013.
This notice is being sent to you because my records indicate that you hold a lien on the
property secondary to the first mortgage, which is being foreclosed.
This property and improvements are being sold pursuant to a judgment entered as indicated
above in favor of the above named plaintiff, and against the above named defendants.
The name of the owners, real owners, and reputed owners of the aforementioned property are
Suzarme M. Thomas aka Suzanne Thomas.
A schedule of distribution will be filed by the Sheriff on a date specified by the Sheriff no
later than 30 days after said sale, and distribution wilt be made in accordance with the schedule
unless exceptions are filed thereto within ten (10) days after the date of the filing of said schedule.
You should check with the Sheriff's Office by calling 717 240-6391 to determine the actual date of
the filing of the schedule.
Sincerely yours,
Vo~ ~scnoti~I ~
MARTHA E. VON ROSENSTIEL, P.C.
ATTORNEY AT LAW
I6 SOUTH LANSDOWNE AVENUE
P.O. BOX 457
LANSDOWWE, PA 19050
PHONE(610)623-2660 FAX(610)623-2745
June 11, 2001
TO: Family Court/Domestic Relations Office
One Courthouse Square
Carlisle, PA 17013
RE: NOTICE OF SALE OF REAL PROPERTY:
217 South Sixteenth Street Camp Hill, PA 17011
Amount of Judgment: $116,921.44
Date of Judgment: June 13, 2001
Court Term and Number: Court of Common Pleas of
Cumberland County, Docket~ 01-1303 Civil Term
Plaintiff: GMAC Mortgage Corporation
Defendants: Suzanne M. Thomas aka Suzanne Thomas
Dear Sir/Madam:
Please be advised that the property and residential dwelling, located at and known as 217
South Sixteenth Street Camp Hill, PA 17011 will be sold by the Sheriffof Cumberland County on
September 5, 2001 at 10:00 a.m. in the Cumberland County Court House, One Court House
Square, Carlisle, PA 17013.
This notice is being sent to you because my records indicate that you hold a lien on the
property secondary to the first mortgage, which is being foreclosed.
This property and improvements are being sold pursuant to a judgment entered as indicated
above in favor of the above named plaintiff, and against the above named defendants.
The name of the owners, real owners, and reputed owners of the aforementioned property are
Suzanne M. Thomas aka Suzanne Thomas.
A schedule of distribution will be filed by the Sheriff on a date specified by the Sheriff no
later than 30 days after said sale, and distribution will be made in accordance with the schedule
unless exceptions are filed thereto within ten (10) days after the date of the filing of said schedule.
You should check with the Sheriff's Office by calling 717 240-6391 to determine the actual date of
the filing of the schedule.
Sincerely yours,
Ra~nsticl ~~
MARTHA E. VON ROSENSTIEL, P.C.
ATTORNEY AT LAW
16 SOUTH LANSDOWNE AVENUE
P.O. BOX 457
LANSDO~.NE, PA 19050
PHONE(610)623-2660 FAX(610)623-2745
June I 1, 2001
TO: Dept. of Public Welfare
Box 2675
Harrisburg, PA 17105
RE: NOTICE OF SALE OF REAL PROPERTY:
217 South Sixteenth Street Camp Hill, PA 17011
Amount of Judgment: $116,921.44
Date of Judgment: June 13, 2001
Court Term and Number: Court of Common Pleas of
Cumberland County, Docket~ 01-1303 Civil Term
Plaintiff: GMAC Mortgage Corporation
Defendants: Suzanne M. Thomas aka Suzanne Thomas
Dear Sir/Madam:
Please be advised that the property and residential dwelling, located at and known as 217
South Sixteenth Street Camp Hill, PA 17011 will be sold by the Sheriff of Cumberland County on
September 5, 2001 at I0:00 a.m. in the Cumberland County Court House, One Court House
Square, Carlisle, PA 17013.
This notice is being sent to you because my records indicate that you hold a lien on the
property secondary to the first mortgage, which is being foreclosed.
This property and improvements are being sold pursuant to a judgment entered as indicated
above in favor of the above named plaintiff, and against the above named defendants.
The name of the owners, real owners, and reputed owners of the aforementioned property are
Suzarme M. Thomas aka Suzarme Thomas.
A schedule of distribution will be filed by the Sheriff on a date specified by the Sheriff no
later than 30 days after said sale, and distribution will be made in accordance with the schedule
unless exceptions are filed thereto within ten (10) days after the date of the filing of said schedule.
You should check with the Sheriff's Office by calling 717 240-6391 to determine the actual date of
the filing of the schedule.
Sincerely yours,
M~ Roscnsdel
/
MARTHA E. VON ROSENSTIEL, P.C.
ATTORNEY AT LAW
16 SOUTH LANSDOWi~E AVENUE
P.O. BOX 457
LANSDOWNE, PA 19050
PHONE(610)623-2660 FAX(610)623-2745
June 11,2001
TO: Inheritance Tax Bureau
Harrisburg, PA 17105
RE: NOTICE OF SALE OF REAL PROPERTY:
217 South Sixteenth Street Camp Hill, PA 17011
Amount of Judgment: $116,921.44
Date of Judgment: June 13, 2001
Court Term and Number: Court of Common Pleas of
Cumberland County, Docket~ 01-1303 Civil Term
Plaintiff.' GMAC Mortgage Corporation
Defendants: Suzanne M. Thomas aka Suzanne Thomas
Dear Sir/Madam:
Please be advised that the property and residential dwelling, located at and known as 217
South Sixteenth Street Camp Hill, PA 17011 will be sold by the Sheriff of Cumberland County on
September 5, 2001 at 10:00 a.m. in the Cumberland County Court House, One Court House
Square, Carlisle, PA 17013.
This notice is being sent to you because my records indicate that you hold a.lien on the
property secondary to the first mortgage, which is being foreclosed:
This property and improvements are being sold pursuant to a judgment entered as indicated
above in favor of the above named plaintiff, and against the above named defendants.
The name of the owners, real owners, and reputed owners of the aforementioned property are
Suzanne M. Thomas aka Suzanne Thomas.
A schedule of distribution will be filed by the Sheriff on a date specified by the Sheriff no
later than 30 days after said sale, and distribution will be made in accordance with the schedule
unless exceptions are filed thereto within ten (10) days after the date of the filing of said schedule.
You should check with the Sheriff' s Office by calling 717 240-6391 to determine the actual date of
the filing of the schedule.
Sincerely yours,
MARTHA E. VON ROSENSTIEL, P.C.
ATTORNEY AT LAW
16 SOUTH LANSDOWNE AVENUE
P.O. BOX 457
LANSDOX,X, ~'NE, PA 19050
PHONE(610)623-2660 FAX(610)623-2745
June 11, 2001
TO: U.S. Inheritance Tax Bureau
Washington, DC 20530
RE: NOTICE OF SALE OF REAL PROPERTY:
217 South Sixteenth Street Camp Hill, PA 17011
Amount of Judgment: $116,921.44
Date of Judgment: June 13, 2001
Court Term and Number: Court of Common Pleas of
Cumberland County, Docket~ 01-1303 Civil Term
Plaintiff.' GMAC Mortgage Corporation
Defendants: Suzanne M. Thomas aka Suzanne Thomas
Dear Sir/Madam:
Please be advised that the property and residential dwelling, located at and known as 217
South Sixteenth Street Camp Hill, PA 170I 1 will be sold by the Sheriffof Cumberland County on
September 5,200I at 10:00 a.m. in the Cumberland County Court House, One Court House
Square, Carlisle, PA 17013.
This notice is being sent to you because my records indicate that you hold a lien on the
property secondary to the first mortgage, wkich is being foreclosed.
This property and improvements are being sold pursuant to a judgment entered as indicated
above in favor of the above named plaintiff, and against the above named defendants.
The name of the owners, real owners, and reputed owners of the aforementioned property are
Suzanne M. Thomas aka Suzanne Thomas.
A schedule of distribution will be filed by the Sheriff on a date specified by the Sheriff no
later than 30 days after said sale, and distribution will be made in accordance with the schedule
unless exceptions are filed thereto within ten (10) days after the date of the filing of said schedule.
You should check with the Sheriff's Office by calling 717 240-6391 to determine the actual date of
the filing of the schedule.
Sincerely yours,
Mariha n
/
MARTHA E. VON ROSENSTIEL, P.C.
ATTORNEY AT LAW
16 SOUTH LANSDOWNE AVENUE
P.O. BOX 457
LANSDOWNE, PA 19050
PHONE(610)623-2660 I~AX(610)623-2745
June 11, 2001
TO: Commonwealth Dept. of Revenue
Inheritance Tax Division
1400 Spring Garden Street
Philadelphia, PA 19130
RE: NOTICE OF SALE OF REAL PROPERTY:
217 South Sixteenth Street Camp Hill, PA 17011
Amount of Judgment: $116,921.44
Date of Judgment: June 13, 2001
Court Term and Number: Court of Common Pleas of
Cumberland County, Doeke~ 01-1303 Civil Term
Plaintiff.' GMAC Mortgage Corporation
Defendants: Suzanne M. Thomas aka Suzanne Thomas
Dear Sir/Madam:
Please be advised that the property and residential dwelling, located at and known as 217
South Sixteenth Street Camp Hill, PA 17011 will be sold by the Sheriff of Cumberland County on
September 5, 2001 at I0:00 a.m. in the Cumberland County Court House, One Court House
Square, Carlisle, PA 17013.
This notice is being sent to you because my records indicate that you hold a lien on the
property secondary to the first mortgage, which is being foreclosed.
This property and improvements are being sold pursuant to a judgment entered as indicated
above in favor of the above named plaintiff, and against the above named defendants.
The name of the owners, real owners, and reputed owners of the aforementioned property are
Suzanne M. Thomas aka Suzanne Thomas.
A schedule of distribution will be filed by the Sheriff on a date specified by the Sheriff no
later than 30 days after said sale, and distribution will be made in accordance with the schedule
unless exceptions are filed thereto within ten (10) days after the date of the filing of said schedule.
You should check with the Sheriff's Office by calling 717 240-6391 to determine the actual date of
the filing of the schedule.
Sincerely yours,
MARTHA E. VON ROSENSTIEL, P.C.
ATTORNEY AT LAW
16 SOUTH LANSDOWNE AVENUE
P.O. BOX 457
LANSDO~t'NE, PA 19050
PHONE(610)623-2660 FAX(610)623-2745
June 11, 2001
TO: Register of Wills of Cumberland
One Courthouse Square
Carlisle, PA 17013
RE: NOTICE OF SALE OF REAL PROPERTY:
217 South Sixteenth Street Camp Hill, PA 17011
Amount of Judgment: $116,921.44
Date of Judgment: June 13, 2001
Court Term and Number: Court of Common Pleas of
Cumberland County, Docket-/t 01-1303 Civil Term
Plaintiff.' GMAC Mortgage Corporation
Defendants: Suzanne M. Thomas aka Snzanne Thomas
Dear Sir/Madam:
Please be advised that the property and residential dwelling, located at and known as 217
South Sixteenth Street Camp Hill, PA 17011 will be sold by the Sheriff of Cumberland County on
September 5, 2001 at 10:00 a.m. in the Cumberland County Court House, One Court House
Square, Carlisle, PA 17013.
This notice is being sent to you because my records indicate that you hold a lien on the
property secondary to the first mortgage, which is being foreclosed.
This property and improvements are being sold pursuant to a judgment entered as indicated
above in favor of the above named plaintiff, and against the above named defendants.
The name of the owners, real owners, and reputed owners of the aforementioned property are
Suzanne M. Thomas aka Suzanne Thomas.
A schedule of distribution will be filed by the Sheriff on a date specified by the Sheriff no
later than 30 days after said sale, and distribution will be made in accordance with the schedule
unless exceptions are filed thereto within ten (10) days after the date of the filing of said schedule.
You should check with the Sheriff's Office by calling 717 240-6391 to determine the actual date of
the filing of the schedule.
Sincerely yours,
Martha E. Von Rosenstiel, P.C. Attorney for Plaintiff
Martha E. Von RosenstieI
16 South Lansdowne Avenue
P.O. Box 457
Lansdowne, PA 19050
610 623-2660
Attorney I.D.# 52634
GMAC Mortgage Corporation COURT OF COMMON PLEAS
500 Enterprise Road CUMBERLAND COUNTY
Horsham, PA 19044-0963
Plaintiff
vs. No: 01~1303 Civil Term
Suzanne M. Thomas aka Suzanne Thomas
217 South Sixteenth Street
Camp Hill, PA 17011
Defendant
THIS IS AN ATTEMPT TO COLLECT A DEBT ANY INFORMATION OBTAINED
WILL
BE USED FOR THAT PURPOSE
NOTICE OF SHERIFF'S SALE OF REAL PROPERTY
TO: Suzanne M. Thomas aka Suzanne Thomas
97 Richneek Road
Newport News, VA 23608
Your house and/or real estate at 217 South Sixteenth Street, Camp Hill, PA 17011 is
scheduled to be sold at Sheriff's Sale on September 5, 2001 at 10:00 a.m. to enforce the court
judgment orS116,921.44 obtained by GMAC Mortgage Corporation against you.
NOTICE OF OWNERS RIGHTS
YOU MAY BE ABLE TO PREVENT THIS SHERIFF'S SALE
To prevent this Sheriff's Sale you must take IMMEDIATE action:
1. The sale will be cancelled if you pay to GMAC Mortgage Corporation the back
payments, late charges, costs and reasonable attorney's fees due. To find out how much you must
pay, you may call 610 623-2660.
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 contact an attorney to asser~ 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.
I. If the Sheriff's Sale is not stopped, your property will be sold to the highest bidder. You
may find out the bid price by calling 610 623-2660.
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 the property.
3. The sale will go through only if the buyer pays the Sheriffthe full amount due in the sale.
To find out if this has happened you may call 610 623-2660.
4. Jif 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 a right to rema/n 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 on a date to be
announced by the Sheriff. 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 Schedule of
Distribution is posted.
7. You may also have other rights and defenses, or ways of getting your house 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.
COURT ADMINISTRATOR
4TM FLOOR CUMBERLAND COUNTY COURT HOUSE
CARLISLE, PA 17013
Telephone: 717 240-6200
CLAIM FOR EXEMPTION
To the Sheriff:
I, the above named defendant, claim exemption of property from levy or attachment:
(1) From my real property in my possession which has been levied upon,
(a) I desire that my $300.00 statutory exemption be set-aside in kind (specify
real property to be set-aside in kind):
I request a prompt court hearing to determine the exemption. Notice of the hearing should
be given to me at
(Address) (Telephone Number)
I verify that the statements made in this Claim for Exemption are true and correct. I
understand that false statements herein are made subject to the penalties of 18 Pa. C.S. Section
4904 relating to unsworn falsification to authorities.
Date:
Signature
THIS CLAIM TO BE FILED WITH THE OFFICE OF THE SHERIFF
CUMBERLAND COUNTY COURTHOUSE CARLISLE, PA 17013
717 240-6391
WRIT OF EXECUTION - (MORTGAGE FORECLOSURE)
P.R.C.P. 3180 to 3183 and Rule 3257
GMAC Mortgage Corporation
IN THE COURT OF COMMON PLEAS OF
CLrMBERLAND COUNTY, PENNSYLVANIA
vs. No. 01-1303 Term, 20 E.D.
No. Term, 20- A.D.
Suzanne M. Thomas, aka Susanne Thomas
WRIT OF EXECUTION
(MORTGAGE FORECLOSURE)
Commonwealth of Pennsylvania:
County of :
TO TI-IE SHERIFF OF CUMBERLAND COUNTY, PENNSYLVANIA:
To satisfy the judgment, interest and costs in the above matter you are directed to levy upon and
sell the following described property (specifically describe property, below):
Plq. EMISES: 217 S. Sixteenth Street
Camp Hill, PA 17011
Amount Due $_[16,288.76
Interest from 06/14/01 to
SALE DATE ~ $19.30 per diem $
Attorney's fees $
Costs $
Total $
as endorsed.
Prothonotary, Common Pleas Court of
Dated Cumberland County, Penna.
(SEAL)
By:
Deputy
DESCRIPTION
ALL THAT CERTAIN tract of land, situate in the Borough of Camp Hill, County of Cumberland,
and Commonwealth of Pennsylvania, more pamicularly bounded and described as follows, to wit:
BEGINNING at a point two hundred forty (240) feet South of the Southeast corner of Second and
Sixteenth (formerly Jackson) Streets; thence Eastwardly along the South side line of Lot No. 61, one
hundred fifty (150) feet to a point in a twenty (20) feet wide alley; thence Southwardly along the
West side of said alley forty (40) feet to a point; thence Westwazdly along the Northern line of Lot
No. 63 one hundred fifty (150) feet to a point in Sixteenth Street; thence Northwardly along the East
side of said Sixteenth Street forty (40) feet to a place of beginning.
It being Lot No. 62 on the Plan of Lots known as Greater Harrisburg, Estate of Jackson Free,
recorded in the Recorder's Office at Carlisle, Pennsylvania, in Plan Book 1, Page 20.
Tax Parcel #01-22-0826-062
WRIT OF EXECUTION and/or ATTACHMENT
COMMONWEALTH OF PENNSYLVANIA) NO. 01-1303 CIVIL 19__
COUNTY OF CUMBERLAND) CIVIL ACTION - LAW
TO THE SHERIFF OF CUP~'~R!~LND COUNTY:
To satisfy the debt, interest and costs due GF,.AC Mortgage Corporation
PLAINTIFF(S)
from Suzanne M. Thomas aka Suzanne Thomas, 217 South 16th St., Camp Hill
PA 17011.
DEFENDANT(S)
(1) You are directed to levy upon the properly of the defendant(s) and to sell Real estate located
at 217 South 16th St., Camp HIll PA 17011. (See attached 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/are 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 nolify him/her that he/she has been added as a garnishee and is enjoined as above
stated.
$.50
Amount Due $116,921.44 L.L.
Interest 6/13/01 - 9/5/01 @ $19.30/d±em Due Prothy $1,00
Alty's Comm % Other Costs
Atty Paid $108.68
Plaintiff Paid
Date: .. 13, 2001 Curtis R. Long
~'~.~p..~L- ~?tho~not ary, Civil ,Division
Name Martha E. Von Rosenstiel, Esq.
Address: 16 S. Lansdowne Avenue
Lansdowne PA 19050
Attorney for: Plaintiff
Telephone: (610) 623-2660
Supreme Court ID No. 52634
REAL ESTATE SALE No. ~q
,,~.~'~- IC~ 20ol thesnentllevieouBontrlea6len(~::
illterest i~ the real proDerty situated in ~oF~g o ~ ~ M~
Oumberta~d County~ Pa. k r~o~. -md numbered as ~[~ ........... -,
(~~ and more tu,, ~escribed on ~t "~" ti~ With
t~is writ and by t~is reference incorporated ~r~n,
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 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 thc same as was printed in the regular editions and issues of the said Cumberland Law
Journal on the following dates,
viz:
JULY 20, 27, AUGUST 3, 2001
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.
Roger M. Morgenthal, Editor
Writ No. 2001 1303 Civil
GM~C Mortg~e Corporation SWO~ TO ~ S~SC~ED before me this
vs. 3 dayof AUGUST, 2001
~L ~T CERT~N ~act of l~d,
CounW of Cm~rl~d, ~d Corn
monwe~th of Pennsylv~ia, more
dred for~ [240) f~t South of the
~n~e E~tw~d~ ~ong ~e
THE PATRIOT NEWS
THE SUNDAY PATRIOT NEWS
Proof of Publication
UnderAct No. 587, Approved May 16, 1929
Commonwealth of Pennsylvania, County of Dauphin} ss
James L. Clark being duly sworn according to law, deposes and says:
That he is the Acounts Receivable Manager 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 24th and 31st day(s) of July and the 7th
day(s) of August 2001. 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 Misce, Jlaneous Book "M',
Volume 14, Page 317. ,/~/
s A · B #S? ! _
/ MyCom~ssl~E~ne6,~ I ~TARY PUBLIC
: · Member, P~ns~a~a A~t~ ~ ~a~ commission expires June 6, 2002
CUMBER~ND COU~ SHERI~S ~FICE
CUMBERED COU~ C~OUSE
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 $ 224.10
Probating same Nota~ Fee(s) $ 1.50
Total $ 225.60
~:;~:,~[,~__~.r ~ 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 ce~ifies that the same have
been duly paid.
B~GINNING al a poh#wo hundred fofly
(240) ftml Soolh d' tim S~iJiIi~4 CQmcr of.
Str~. and Sixz~endt (fomlcrly Jackson)
,,.~. 'u, one hundred fi~ty
¢'/'50 k, et ~ a I~im.in.n twenty ¢~) Tt~.t
West skit of- sa~ ailty t.,.~ .u?,~ no~ tM
.~. ; .._ v,m~dlyala~tbeEas~
~.~ ~ sa~ ,Sixreemb ~ ~ (40;. f~
Ja~k~ Fn~, ns~otd~l in h'~
~ at Cm'lide, PenAsy/vania, in Plan
noo .
Tu ~rcel d0l
REAL ESTATE SALE No. S4 ,d,m.~ L,,~ No. h. ~,mh I)4 dcl~i~..~
Walt NO. 20Ql-1311 nlirl.t¢~ ~'.t *.(~¢nnd~ I~. Ih~' dl.larlCe O1'
RObMt M. MumIM~ II [Izc k..ft w.h,¢h curve i~..~h(¢nd,..d h? u cl~)nt
AI1oultylY~ h,L~ a [k:anng S(mlh ~) d~tty~. 41 minute%
Omltlnl F. qol~Mtt CO., klc. ~;I.~T fc,.~ un arc .i.lancc , 4('1~.24 Ik~t
fl/IL/8 ~ Eciullx11MIt .s ~')lnl: thcT~¢ al~q~ '~tl~:. ;ik'41~ Irk' arc (,(
.TR.A~'T NO. IA: ALJ. THAT ~'~t~rA.IN arc dl,tanc,' .1' .lhit.h0 fL~.~ I' a pilnl;
ir, x'l Or ~ai'cel (11' land ~,ilUal¢ in UI~AIlelt COnlinuip8 akin8 L,M Nu, e,..~.)nh 66
~J~Z~.~?, 12 ralnuKs .17 ~4.Y. oitd~, l.~.,4,
Pt'nm,¥1vani:k haand~J ~d dcK'rihcd dt~aalK~ M' 513.24 fm to a pmnl: thaec~
acc~'dmg to a ~;ur'..,y plan made I~. Adan~,, com!lpjie8 aloe8 L~ Ko. 6. North hO
land, li.'nl~dy of Reading Compmly now ds>lunge of (t~.l: IL, el to a point al lu~:
~mc ul~ ~don,e 1undo. (d Lupin3L.ci.
o( Rcadhtg Conipml now C~n~olidated Rail
Corporatkm (C('mrai,L Norlh .10 d,:gn:e, 46 ·
~id track~ I~y a curie lC) Ihc K'ft having a .~1,1)7 I'~x't IO a poilit :it line of land, now
v~e, tedy ~,ide o( Penn',yl'*,ania ROule I I.fand in thc t~'d o( M(..C'on~tcl, Read: thence
laE(~INNING,
CON'FA NING ~.~ 2 ~uare foci a, a point: ti~.ql~: continuing along sam
TRACT NO. 2: ALL THAT CERTAIN T~;~4. the die.ncc of 5t)~.7.5 feel t~ a Tx~im:
Pt'nn~ylvaflia. i~.fl,l'~d a.~ L(,t No. I on a
Suhdr.,i~,i~m Plan r(.'c~l in Cumberland
Courtly Plan B(Jo~ 7q. PaSc 7.1. which lands now ~ Ionn~'dy of Philip
pn.'mr~, an.. boundud and de, cribed ~ ;hcnt~ aJong Mtm~. North lb ~..o~'c. 06
Ea',t L],,ham R(md [S.R. 0114) at line of' along ~al~.', SO(ILh I~11 i~..gn,'u~ ~g
af'~.-,aid ~bdivi~i(m plan: fhcece alon8 allim.,ot'ian~,noworfornk.'dyul'DiPk-'lfo~
along i,(l( N,. h. Soulh I0 ~.crctN .~ alh~l'e~a~d ihct)ce a]on~ ~,aJ11('. N~qh 0!
dk, right ~,hi~h cur~: i~ ~uhlcnded I~v a pla.-~oI'I~EOINNIIqCL
chonJ i~in8 IO thc v,e~t Ihcl~.'ol' a,ld wl~ich CONTAIN[NO 11~.~.14 a~Te~oi'|and,
ch~d h~,. a 'lxxanDg Se~th I.~ (k'gtCt'~, 0q
minutk% .~h :*,ecrm(I,, [.:d'd and a chord