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Home My WebLink About01-1813. FEDERMAN AND PHELAN, LLP · By: FRANK FEDERMAN, ESQUIRE IDENTIFICATION NO. 12248 ONE PENN CENTER AT SUBURBAN STATION ATTORNEY FOR PLAINTIFF SUITE 1400 PHILADELPHIA, PA 19103-1814 ~000 COURT OF COMMON PLEAS CIVIL DIVISION CENDANT MORTGAGE CORPORATION, F/K/A PHH MORTGAGE SERVICES CORPORATION 6000 ATRIUM WAY MOUNT LAUREL, NJ 08054 Plaintiff TERM V. JOSEPH T. JORDAN CUMBERLAND COUNTY OLIVIA K. JORDAN 120 PALM CLUB CIRCLE BRUNSWICK, GA 31525 Defendant(s) ~CI~.I.L_ ~A_CTION. LAW N~OTICE **THIS FIRM IS A DEBT COLLECTOR ATTEMPTING TO COLLECT A DEBT AND ANY INFORMATION OBTAINED WILL BE USED FOR THAT PURPOSE. IF YOU HAVE PREVIOUSLY RECEIVED A DISCHARGE IN BANKRUPTCY AND THIS DEBT WAS NOT REAFFIRMED, THIS CORRESPONDENCE IS NOT AND SHOULD NOT BE CONSTRUED TO BE AN ATTEMPT TO COLLECT A DEBT, BUT ONLY ENFORCEMENT OF A LIEN AGAINST PROPERTY. ** You have been sued in Court. If you wish to defend against the claims set forth in the following pages, you must take action within twenty (20) days after this Complaint and Notice are served, by entering a written appearance personally or by attorney and filing in writing with the court your defenses or objections to the claims set forth against you. You are warned that if you fail to do so the case may proceed without you and a judgment may be entered against you by the court without further notice for any money claimed in the Complaint or for any other claim or relief requested by the Plaintiff. You may lose money or property or other rights important to you. YOU SHOULD TAKE THIS PAPER TO YOUR LAWYER AT ONCE. IF YOU DO NOT HA VE A LA WYER OR CANNOT AFFORD ONE, GO TO OR TELEPHONE THE OFFICE SET FORTH BELOW TO FIND OUT WHERE YOU CAN GET LEGAL HELP. CUMBERLAND COUNTY CUMBERLAND COUNTY BAR ASSOCIATION 2 LIBERTY AVENUE CARLISLE, PA 17013 (717) 249-3166 Loan #: 0008445934 1. Plaintiff is CENDANT MORTGAGE CORPORATION, F/K/A PHH MORTGAGE SERVICES CORPORATION 6000 ATRIUM WA Y MOUNT LAUREL, NJ 08054 2. The name(s) and last known address(es) of the Defendant(s) are: JOSEPH T. JORDAN OLIVIA K. JORDAN 120 PALM CLUB CIRCLE BRUNSWICK, GA 31525 who is/are the mortgagor(s) and real owner(s) of the property hereinafter described. 3. On 4/19/96 mortgagor(s) made, executed and delivered a mortgage upon the premises hereinafter described to MEMBERS FIRST FEDERAL CREDIT UNION which mortgage is recorded in the Office of the Recorder of CUMBERLAND County, in Mortgage Book No. 1315, Page 411. By Assignment of Mortgage recorded 4/24/96 the mortgage was assigned to PLAINTIFF which Assignment is recorded in Assignment of Mortgage Book No. 518, Page 597. 4. The premises subject to said mortgage is described as attached. 5. The mortgage is in default because monthly payments of principal and interest upon said mortgage due 8/1/00 and each month thereafter are due and unpaid, and by the terms of said mortgage, upon failure of mortgagor to make such payments after a date specified by written notice sent to Mortgagor, the entire principal balance and all interest due thereon are collectible forthwith. A copy of such notice is attached as Exhibit "A." 6. The following amounts are due on the mortgage: Principal Balance Interest $81,884.65 7/1/00 through 3/1/01 4,104.08 (Per Diem $16.82) Attorney's Fees Cumulative Late Charges 4,000.00 4/19/96 to 3/1/01 388.96 Cost of Suit and Title Search Subtotal 550.00 $90,927.69 Escrow Credit Deficit 66.82 Subtotal 0.0~0 TOTAL $90,860.87 7. The attorney's fees set forth above are in conformity with the Mortgage documents and Pennsylvania Law, and will be collected in the event of a third party purchaser at Sheriffs Sale. If the Mortgage is reinstated prior to the Sale, reasonable attorney's fees will be charged. 8. This action does not come under Act 6 of 1974 because the original mortgage amount exceeds $50,000.00. 9. This action does not come under Act 91 of 1983 because the mortgaged premises is not the principal residence of the defendant(s). WHEREFORE, PLAINTIFF demands an $90,860.87, together with interest from 3/in re_~m Judgment against the Defendant(s) in the sum of i~-0] at the rate of $16.82 per diem to the date of Judgment, and other costs and charges collectible under the mortgage and for the foreclosure and sale of the mortgaged property. '/s/Frank Federman FRANK FEDERMAN, ESQUIRE Attorney for Plaintiff 03/15/01 THU 16'35 FAX 215'* 4508 FEDERMANAPHEtAN 1~1002 ,,.. FEDERMAN AND PHELAN, L.L.P. One Penn Center at-Suburban Station 1617 $ohn F. Kennedy Boulevard Suite 1400 Philadelp~a, PA 19103-1814 215-563-7000 Fax: 215-$63-$$34 · Represeutins Lenders in P~Ivania and New Jersey February 12, 2001 Joseph T. Jordan Olivia K. Jordan 120 Palm Club Circle 120 Palm Club Circle Brunswick, GA 31525 Brunswick, G'A 31525 Re: Premises: 11 Paradise Dr£ve-Ca~ltsle, PA 17013 Loan No.: 0008445934 NOTICE OP INTENTION TO FOI~_NCLOS~ We represen~ Cendan~ Mortgage' Corporation, ~he holder o~ ~he Mortgage on the above-referenced premises, who hereby advlses ~ha~ i~ will accelerate your Mortgage (demand paymen~ in full) and pursue the foreclosure remedies permitted by the mortgage unless your loan delinquencies are cured as provided below. THIS FIRM IS A DEBT COLI,ECTOR ATTEMPTING TO COLLECT A DEBT. THIS NOTICE IS SENT TO YOU IN AN ATTEMPT TO COLLECT THE INDEBTEDNESS REFERRED TO HEREIN AND ANY INFORMATION OBTAINED FROM YOU WILL BE USED FOR THAT PURPOSE. IF YOU HAVE PREVIOUSLY RECEIVED A DISCHARGE IN BANKRUPTCY, THIS CORRESPONDENCE IS NOT AND SHOULD NOT BE CONSTRUED TO BE AN ATTEMPT TO COLLECT A DEBT, BUT ONLY ENFORCEMENT OF A LIEN AGAINST PROPERTY. " You. may' dispute the validity of the debt or any portion thereof. I~ you do so in writing wi thin thirty (30) days of receipt of this letter, this firm will obtain and provide you with wri==en verification thereof; otherwise, the debt will be assumed to be valid. Likewise, you may request =he name and address of the original creditor if different from above. The total delinquency, including late and other charges is $5,628.59 for the months o~ 8/1/00 through 2/1/01. Your failure pay the delinquent amount, plus any additional monthly payment late and other charges (including any accrued interest} -t~hat may come due within the nex~ ~hirt¥ (30) days, will result in the acceleration of all sums due under your Mot=gage. After acceleration occurs, a foreclosure action or any other remedy permitted by your mortgage may be ins=ituted. EXHIBJTA 03/15/01 TI~T 15'35 FAX 215' 4500 FEO£~&piiEIA~ ~0~ · To avoid the acceleration of your mort~ag~ and subsequent foreclosure action, =he delinquency men=ioned above and any accrual ~here=o taus= be pa~d by CF2~TIFIED CHECK OH MONey O~DEa and received in our offices a~ CENDANT MOrTgAgE CORPORATION, 6000 Atrium Way, Moun~ Laurel, NJ 08054, A~en~ton~ Collections Department, in or before =birmy (~0) days from ~he da=e of ~his le~er. Please (S00) ~57-0%$0 for ~he exa¢~ amoun= required. You have the righ~ ~o reins~aue your mortgage acceleration by fulfilling ~he conditions s~a~ed in your pertaining to such reins~a=emen=. You may call our office discuss ~hese condi=ions. Any future negotiations a~emp~ing to reinstate your loan or acceptance o~ any paymen~ less ~han ~he full amoun= due shall no= constitute a waiver by ~he mortgage holder of the acceleration unless agreed to in wri~in~ by the mor=~a~e holder. You have the righ~ to assert' in the foreclosure 9roceedin~s ~he non-existence o~ a defaul~ or any o~her defense ~o accelera=ion and foreclosure. Very =rul¥ yours, Frank Federman FF:ll cc. Cendan~ Mortgage Corpora=ion Attn:Collections Depar'tmen~ Loan No.- 0005¢45934 EXHIBITA .......... ALL TtIOSE CERTAIN lo~s ' Mid~'~scx Town ' of Eround wi~h thc i · '' 'wi'~h' ' sh~p, Cure.Hand ~un p . mprovcmcnts thcrcon ~ect ' · . a ~t Plan ~ ~, enns lvam ~ sl~ate ~n .. .. . or B~ Roush re Y a. ~und~ ~d d ' · copy or which is at ~ p~ed by L~ B. Nei~' _~cn~d m accord~cc ,-, ~ .... ~ched hereto, a~ follows: roger,. ~ofesszon~ L~d S~eyor, a : ~EGINNING at an kon pin in ~e nonh~ Hght-of-way Hne of 50 feet w/dc P~a~se ~oad at comer:of Lot ~o. 149 as shown on ~ Dale Fe~ow Revised Plan of ~~ r~corded in cinaft~r mentioned R~o~cr's Office in Plan B~k No. 3, Page 103; thence by seal Sdulh 85 de,ecs I~ ~nutes ~st a distance of 172.85 feet to an kon pin; ~cnce South de~ees 43 minutes West a ~st~ce o~ 1~ fee~ to ~ ~sfing ~on pin a~ com~ of Lot ~o. I46 as shown on ~e a~ve mentioned Dale ~c~ow Revised PI~ of ~ts; fl~cnce by s~d ~ ~o. 145 No~h ~ de~ees 15 ~nutes West a distance of 172.85 f~et ~o' an iron pin in ~e not, em ~ght- of-way linc of 30 feet wide P~~ise Road; thence by said no, hem H~ht-oLway line o~ P~dise Road North 3 de.ecs 43 minutes Hasla ~stance of 100 feet to an iron pin at the place of BEGINNING. ~AVI~G ~her~on erected a single family dwell/nE house with mailin~ address o~ 11 Paradise Road, C~lisle, Pennsylvani~ 9EING M~s No. 147 and 141 on the ~or~men~on~d Dale Fe~ow Revised PI~ which Plan is record~ in ~he h6rein~ter m~nfioned Recorder's Of Hce in Plan Book Mo. 3, Pa~e 103. · . ~EIN~ the same premises which Hdi~h ~. Myers, ExecutNx under the Las~ Will and Tes ' t~ent of Tressie A. ~~n by De~ dat~ September 16, 1983 ~d Reeord~ ~eptember 16, 19~3 in the Office of the ,~fiorder of Deeds in and for Cumberl Pennsylvania in Deed Book J , Volume 30 ~_ ~~ .... and County, at Carlisle, , Pa~ ~~, ~ant~ ana conveyed to ~ry and Linde C. Roush, husband and wife, ~e ~an~o~ here~. L. Roush ~EING also as to ~t 147, ~c same premises which ~h~ E. Clepper ~d C~aline Clcppcr, his wife, by Deed dated ~uly 3, 1948, and record~ ~uly 3, 1948 in thc thc a~vc- mentioned Recordcr's Offic~ in Dccd B~k "V" Volume 13, Page 414, ~an~ and conveyed Luther L. Clcppcr, and M~ ~u Clep~r, his wi~c. I~ being aho ~ which lhe Tax Cl~m Bur~u of ~m~rland County by Decd datedt° ~t 147, thc same Premises 55. ~n~cd ~d conveyed as the property oF Lu~cr Clcppcr, M~h 6, 1964, and rccord~ March 9, 1964 in ~hc a~ve-menfioncd Rccordcr's Of Hce in Dccd Book "D" Volume 21, Page ~~k~. d_a~d ~ifc. ~e said Luther L. Clcppcr, by Quit-to Vernon M. Sh~k ~d Trcssic A. omea ~ay 14, 1991 in tlae a~oresaid Recorder's Office in Claim Deed daeed May 9, 1991 633, conveyed any interest which he may ha~e had in the above-descried property by ~tle of any i~egul~fies in the s~d sale and conveyance Deed Book "C", Volume 35, Page Linde C. Rough, the Grantors he~in. 'And ~ing°f the Tax Cl~m B~eau, to B~ L. Roush and ~nher as to ~t 147, the same premises which by Order of Coua recorded August 25, 1991 in Deed Book "H", Volume 35, Page 5 Pe~anently enjoined and res~ained fl~e said M~ ~u Clepper, her he~s and assi~s, ~om asserting any clem or interest in or to the said real pro~~y adverse to that of B~ L. Roush and Linde C. Roush, the Grantors herein. SUBJECT tlO WEVER, to fl~c resections as fl~ey appe~ on ~c DEe Fe~ow ReUsed Plan o~ ~rs recorded as aforesaid. VERIFICATION MARK HIINKLE hereby states that he is V.P. of CENDANT MORTGAGE SERVICES mortgage servicing agent for Plaintiff in this matter, that he is authorized to take this Verification. and that the statements made in the foregoing Civil Action in Mortgage Foreclosure are true and correct to the best of his knowledge, information and belief. The undersigned understands that this statement is made subject to the penalties of 18 Pa. C.S. Sec. 4904 relating to unswom falsification to authorities. , SHERIFF'S RETURN - NOT FOUND CASE NO- 2001-01813 P COMMONWEALTH OF PENNSYLVANIA COUNTY OF CUMBERLAND CENDANT MORTGAGE CORP VS JORDAN JOSEPH T ET AL R. Thomas Kline ,Sheriff or Deputy Sheriff, who being duly sworn according to law, says, that he made a diligent search and inquiry for the within named defendant, DEFENDANT JORDAN JOSEPH T but was unable to locate Him in his bailiwick. He therefore returns the COMPLAINT - MORT FORE FORECLOSURE , NOT FOUND , as to the within named DEFENDANT , JORDAN JOSEPH T DEFENDANT NO LONGER RESIDES AT ADDRESS STATED, LEF FORWARDING, RETURN NOT FOUND AS PER JASON RICCO 4/.9/01 Sheriff.s Costs- So answ~rs~/ ~~~ Docketing 18.00 Service 3.10 . Not Found Return 5.00 R. Thomas Kline Surcharge 10.00 Sheriff of Cumberland County .00 36.10 FEDERMAN & PHEIJtN 0 /0 /200 Sworn and subscribed to before me this P.~! ~ day of~ ~~ A.D. Prot~0~otary -'; · , SHERIFF' S RETURN - NOT FOUND CASE NO' 2001-01813 P COMMONWEALTH OF PENNSYLVANIA COUNTY OF CUMBERLAND CENDANT MORTGAGE CORP VS JORDAN JOSEPH T ET AL R. Thomas Kline ,Sheriff or Deputy Sheriff, who being duly sworn according to law, says, that he made a diligent search and inquiry for the within named defendant, DEFENDANT JORDAN OLIVIA K but was unable to locate Her in his bailiwick. He therefore returns the COMPLAINT - MORT FORE , NOTICE , NOT FOUND , as to the within named DEFENDANT , JORDAN OLIVIA K DEFT. NO LONGER RESIDES AT ADDRESS STATED, LEFT NO RETURN NOT FOUND AS PER JASON RICCO, 4/9/01 . Sheriff's Costs- So answersp? ~-- Docketing 6.00 ~ Not Found Return 5.00 _ Affidavit .00 R./'Thomas Kline Surcharge 10.00 Sheriff of Cumberland County .00 21.00 FEDERMAN & PHELAN 04/09/2001 Sworn and subscribed to before me this ~ ~-~' day of ~ ~ ~ A.D. ProthOnotary -- 03/1'5/01 THU 10'35 FAT 21.5" 4,508 FFDERMAN&PHELAN 1~1002 FEDERMAN AND PHELAN, L.L.P. One Penn Center at'Suburban Station 1617 John F. Kennedy Boulevard S uitre 1400 Philadelphia, PA 19103-1814 215-563-7000 Fax: 215-563-5534 · Repmsentin~l Lenders i~ Pcnnsylv~ and New Jersey February 12, 2001 Joseph T. Jot 'dan Olivia K. Jordan 120 Palm Club Circle 120 Palm Club Circle Brunswick, GA 31525 Brunswick, GA 31525 Re: Premises: 11 Paradise Driv~-C&rltsle, PA 17013 Loan No.: 0008445934 NOTICE OP INTENTION TO FO~__NCLOS~. We represen~ Cend~~ Mortgage Corporation, the holder o~ the Mortgage on the above-referenced premises, who hereby advises tha~ ig will accelerato your Mortgage (demand payment; in full) and pursu~ the foreclosurm remedies permitted by the mortgage unless your loan delinquencies are cured as provided below. THIS FIRM IS A DEBT COLI,ECTOR ATTEMPTING TO COLLECT A DEBT. THIS NOTICE IS SENT TO YOU IN AN ATTEMPT TO COLLECT THE INDEBTEDNESS REFERRED TO HEREIN AND ANY INFORMATION OBTAINED FROM YOU WILL BE USED FOR THAT PURPOSE. IF YOU HAVE PREVIOUSLY RECEIVED A DISCHARGE IN BANKRUPTCY, THIS CORRESPONDENCE IS NOT A,ND SHOULD NOT BE CONSTRUED TO BE AN ATTEMPT TO COLLECT A DEBT, BUT ONLY ENFORCEMENT OF A LIEN AGAINST PROPERTY. You may dispute ~he validity of ~he deb~ or any portion thereof. If you do so in writing within ~hirty (30) days of receipt of this letter, this firm will obtain and provide you wi~h written verification thereof; otherwise, ~he deb~ will be assumed to be valid. Likewise, you may request ~he name and address of the original credit:or if different: from above. The total delinquency, including lace and other charges Ss $5,628.59 for the months o~ 8/1/00 through 2/1/01. Your failure ~o pay the de!inquen*, amount, plus any additional monthly ~aym.~.'t an~ late and other charges (including any accrued £nteres~) r~hat .may come due within ~he nex~ ~hirty (30) day~ will ' ' '~ , resu~ ~ £n he acceleration of all sums due under your Mortgage. After acceleration occurs, a foreclosure action or any or:her remedy permitted by your mortgage may be instituted. EXHIBITA · a~, :~'35 ¥.4X 215' 450~ I:'E~E~&PHELA~ . To avoi~ ~he acceleration of your mo foreclosure action, ~here=o delin · r~gage a · must be ~ nc m · nd s · n ou ~ ~ald by C~TI Y ~n=loned ~ov _ ~se~ent _ r offaces ~ ..... FI~ ~~ ~ .... e and ' &~7-0~60 for -=- ~,,, une date of =~;- . ~~ar~en~, in .... ~~c re~ired r. ~zease call You have the rich= =o reinsba=e your ~ort~a~e a~cer acceleration by fulfilling =he conditions stated in your Detraining to such reinstatemen= You may call our office discuss these conditions.· Any future ne oti ' constitute a -- ~ ~a~ent less than *~ ~u_~e~nstate your un~___ waiver by .~- _ . ~u tull am~ ..... - _ loan or ~==~ agreed to ~- .... ~ .~'~= .mortgage hol~ _ ~ju ~ue shall n --- wzz~n~ Dy the ~..__~e~ of ~ne acc=~-~-~ .=_ You have the r~-~ ~ "'~~a~e ~older. ~ue non-existence o~'~"]~~ ~sert' in the fOreclos - and foreclo ute ~ uerense to acce!erauion s . - -~==~u or any o~he- =-~ ute proceedings Ve~ ~ruly yours, F~: 11 Frank Federman cc- Cendant Mortgage CorDora=ion Attn: ColleCtions Department Loan No.- 0008445934 EXHIBITA ......... ~/-.L TI:IO$~. ¢£1~T,4IN lots o[' ground wi~h ~c improvcmcn~h ~hCrcon ~ec[~ situate in ~ddl~sex Township, Cure.fiend ~un~, Pennsylvania. ~und~ ~d descried in accord~cc '~'~ 'a ~ Plan for B~ Roush prepped by L~ B. ~ei~inger, ~ofession~ L~d S~eyor, a d&py o~ Which is a~ched hercxo, as follows: '-" ~~I~V~IN~ at an ~on pin in ~c nonh~ fight-of-way ~ne of 50 feet wide P~a~se Road at comer.'of Lot Ho. 149 as shown on ~ Dal~ Fc~ow Revised Plan of ~ts recorded in h~einaft~r mentioned R~o~er's Office in Plan B~k No. 3, Page 103; thence by seal ~t No. 149 Sguth fig de,ecs 13 ~nutes ~st a distance of 172.83 fcct to an kon pin; ~cnce South de~ees 45 minutes West a ~st~ce of 1~ feet to ~ ~sfing ~on pin at com~ of Lot No. I45 as shown on ~e a~ve men~oned Dale ~c~ow R~viscd PI~ of ~s; fl~cnce by s~d ~t No. 145 Noah ~g de~ees 1~ ~nutes West a distance of 172.83 feet to' an iron pin in ~ nor~m fight- of-way linc og 30 feet wide P~~ise Road; thence by said no, hem fight-of-way line o~ P~dise Road North 3 de,ecs 45 minutcs Hast a ~stanc~ of 100 feet to an iron pin at thc place of B E G INNING. ·IAVING thereon erected a single family dwcllin~ house with mailing address oF 11 Paradise Road, C~lisle, Pcnnsylvani~ ~EIN~ ~ts No. 147 and 148 on the ~orcmenfioned Dale Fe~ow Revised PI~ of ~ts, which Plan is record~ in the h6rein~tcr m~n~oned ~ecorder's Office in Plan Book No. 3 Page 103. , . ~E/N~ thc same premises which Hdith 5. Myers, Exccut~x under the Last Will and Test~ent o~ Trcssie A. ~~n by Dc~ dat~ September 1~, 1983 and Rccord~ September 1 1983 in the Of~ce of thc Recorder of Dc~ds in and for Cumberland County, at Carlisle, Pennsylvania in Deed Book "J", Volumc 30, Page 455, ~ant~ and conveyed to B~ry L. Roush and Linde C. Roush, husband and wife, ~ ~anto~ her~. BEI.~G also as to ~t 147, ~c same premises which ~h~ E. Cleppcr ~d C~aline Clcpper, his wi~e, by Deed dated ~uly 3, 1948, and record~ ~uly 3, 1948 in thc the a~ve- ~~ti°ge~ecordcr's Officc in Deed B~k "V", Volume '~ ~--- ~ · ~, ~a~= ~t,, ~ant~ ann conveyed ~o ~utner ~. ~lcppcr, and M~ ~u Clep~r, his wife. I~ b~in also ~ which the Tax Cl~m Bur~u of ~m~rla n ~ ....... ,.. ~_ .... tp~t. 1~7, thc same premises n~ ~,,,,~ oy ~cca aatea ~~h 6, 1964, and r~corded ~arch 9, 1964 in the a~ve-men~oned Recordcr's O~ce in cd ~d conv~ycd as the property o~ Lurer Cie er, Deed Book "D". olume 59. ~n~ _~ . V ........ , ' ~u to V¢mon M. S hkk ~d Trcssie A. ~~k~ h~~d.ap~ ~jfc. ~e said Luther L Clcpper, by -- it Claim Deed da:ed May 9, 1991 ~d ·c~oraea ~ay 14, 1991 in tl~e a~oresa~d Rccorder's Of~c~ In De~d Book "C". Volume ~3 conveyed any interest which he may ha~c had in the above-descried property by ~ue o~ any i~egt:l~fies in the s~d sale and conveyance o~ thc Tax Cl~m B~eau, to B~ L. Roush and Linde C. Roush, thc Grantors he~in. 'And ~ing further as to ~t 147, the same premises which by Order of Cou~ recorded August 25, 1991 in Deed Book "H", Volume 35, Page 5 pe~ancntly enjoined and res~aincd ~ said M~ ~u Clcpper, her he~s and assi~s, ~om asserting any clem or interest in or to the said real pro~~y adverse to that of B~ L. Roush and Linde Roush, ~hc Grantors herein. ~U~ECT ~IO}VE~E~. ~o ~c res~c~ons as O~cy appe~ oa ~c DEe ~~ow 'R~scd Plan oF ~s recorded as aforesaid. VERIFICATION MARK HIINKLE hereby states that he is V.P. of CENDANT MORTGAGE SERVICES mortgage servicing agent for Plaintiff in this matter, that he is authorized to take this Verification. and that the statements made in the foregoing Civil Action in Mortgage Foreclosure are true and correct to the best of his knowledge, information and belief. The undersigned understands that this statement is made subject to the penalties of 18 Pa. C.S. Sec. 4904 relating to unsworn falsification to authorities. FEDERMAN AND PHELAN, LLP By: FRANK FEDERMAN, ESQUIRE IDENTIFICATION NO. 12248 ATTORNEY FOR PLAINTIFF ONE PENN CENTER AT SUBURBAN STATION SUITE i 400 PHILADELPHIA, PA 19103-1814 COURT OF COMMON PLEAS (215) 563-7000 CIVIL DIVISION CENDANT MORTGAGE CORPO~TION, F/K/A PHH MORTGAGE SERVICES CORPORATION 6000 ATRIUM WAY MOUNT LAUREL, NJ 08054 TERM Plaintiff v. CUMBERLAND COUNTY JOSEPH T. JORDAN OLIVIA K. JORDAN 120 PALM CLUB CIRCLE BRUNSWICK, GA 31525 Defendant(s) CIVIL ACTION - LAW COMPLAINT IN MORTGAGE FORECLOSURE NOTICE **THIS FIRM IS A DEBT COLLECTOR ATTEMPTING TO COLLECT A DEBT AND ANY INFORMATION OBTAINED WILL BE USED FOR THAT PURPOSE. IF YOU HAVE PREVIOUSLY RECEIVED A DISCHARGE IN BANKRUPTCY AND THIS DEBT WAS NOT REAFFIRMED, THIS CORRESPONDENCE IS NOT AND SHOULD NOT BE CONSTRUED TO BE AN ATTEMPT TO COLLECT A DEBT, BUT ONLY ENFORCEMENT OF A LIEN AGAINST PROPERTY. ** You have been sued in Court. If you wish to defend against the claims set forth in the following pages, you must take action within twenty (20) days after this Complaint and Notice are served. by entering a written appearance personally or by attorney and filing in writing with the court your defenses or objections to the claims set forth against you. You are warned that if you fail to do so the case may proceed without you and a judgment may be entered against you by the court without further notice for any money claimed in the Complaint or for any other claim or relief requested by the Plaintiff. You may lose money or property or other rights important to you. YOU SHOULD TAKE THIS PAPER TO YOUR LAWYER AT ONCE. IF YOU DO NOT HAVE A LAWYER OR CANNOT AFFORD ONE, GO TO OR TELEPHONE THE OFFICE SET FORTH BELOW TO FIND OUT WHERE YOU CAN GET LEGAL HELP. CUMBERLAND COUNTY CUMBERLAND COUNTY BAR ASSOCIATION We hereby certify the 2 LIBERTY AVENUE within to be a true and CARLISLE. PA 17013 correct copy of the (717) 249-3166 original filed of record FEDERI~N AND PHEI.~N Loan = 001)8445934 1. Plaintiff is CENDANT MORTGAGE CORPORATION, F/K/A PHH MORTGAGE SERVICES CORPORATION 6000 ATRIUM WAY MOUNT LAUREL, NJ 08054 2. The name(s) and last known address(es) of the Defendant(s) are: JOSEPH T. JORDAN OLIVIA K. JORDAN 120 PALM CLUB CIRCLE BRUNSWICK, GA 31525 who is/are the mortgagor(s) and real owner(s) of the property hereinafter described. 3. On 4/19/96 mortgagor(s) made, executed and delivered a mortgage upon the premises hereinafter described to MEMBERS FIRST FEDERAL CREDIT UNION which mortgage is recorded in the Office of the Recorder of CUMBERLAND County, in Mortgage Book No. 1315, Page 411. By Assignment of Mortgage recorded 4/24/96 the mortgage was assigned to PLAINTIFF which Assignment is recorded in Assignment of Mortgage Book No. 518~ Page 597. 4. The premises subject to said mortgage is described as attached. 5. The mortgage is in default because monthly payments of principal and interest upon said mortgage due 8/1/00 and each month thereafter are due and unpaid, and by the terms of said mortgage, upon failure of mortgagor to make such payments after a date specified by written notice sent to Mortgagor, the entire principal balance and all interest due thereon are collectible forthwith. A copy of such notice is attached as Exhibit "A." 6. The following amounts are due on the mortgage:' Principal Balance $81,884.65 Interest 4,104.08 7/1/00 through 3/1/01 (Per Diem $16.82) 4~000.00 Attorney' s Fees ~ Cumulative Late Charges ~88.96 4/19/96 to 3/1/01 Cost of Suit and Title Search 550.00 Subtotal $90,927.69 Escrow 66.82 Credit 0.0_____Q0 Deficit (~ 66.82) Subtotal TOTAL $90,860.87 7. The attorney's fees set forth above are in conformity with the Mortgage documents and Pennsylvania Law, and will be collected in the event of a third party purchaser at Sheriffs Sale. If the Mortgage is reinstated prior to the Sale, reasonable attorney's fees will be charged. 8. This action does not come under Act 6 of 1974 because the original mortgage amount exceeds $50,000.00. 9. . This action does not come under Act 91 of 1983 because the mortgaged premises is not the principal residence of the defendant(s). WHEREFORE, PLAINTIFF demands an in re~___3n Judgment against the Defendant(s) in the sum of $90,860.87, together with interest from 3/1/01 at the rate of $16.82 per diem to the date of Judgment, and other costs and charges collectible under the mortgage and for the foreclosure and sale of the mortgaged property. /s/Frank Federman FRANK FEDERMAN. ESQUIRE Attorney for Plaintiff ~.'- TRU'~ C""?"~' F?~ In Testimony x;...I,,---rc:;o'l:, I J',-r'c~ u.'.nto set my hand · "'-' Pa and the seal of sa~d Court at ~.a,~isle, · This .... ~ ..... day of. --, ......... , ......... - ro OhO ary · o 03/~$/01 TBU 16'35 FAX 215' 4508 FFD~&P~~ 1~1002 . FEDERMAN AND PHELAN, L.L.P. One P~nn Center ar Suburb~u Station 1617 John F. Kmm~dy Beulcva~d $ ui~'~ 1400 Phihd~lphh, PA. 19103-1514 215-563-7000 Fax: 215.563-5534 P,,ep~esentin8 Lenders in. · Pemnsylvania and New Jersey February 12, 2001 Joseph T. Jot 'dan Olivia K. Jordan 120 Palm Club Circle 120 Palm Club Circle Brunswick, GA 31525 Brunswick, GA 31525 Re: Premises: 11 Paradise Drivm-C&rlisle, PA 17013 Loan No.: 0008445934 NOTICE_ OP INTENTION TO _FORECLOSE we represen~ Cendan~ MorUgagm' Corporation, ghe holder o~ ~he Mortgage on the above-referenced premises, who hereby advises it will accelerate your Mortgage (demand payment in full) and pursue the foreclosure remedies permi~ued by the mortgage unless your loan delinquencies are cured as provided below. THIS FIRM IS A DEBT COLI,ECTOR ATTEMPTING TO COLLECT A DEBT. THIS NOTICE I$ SENT TO YOU IN AN ATTEMPT TO COLLECT THE INDEBTEDNESS REFERRED TO HEREIN AND ANY INFORMATION OBTAINED FROM YOU WILL B~ USED FOR THAT PURPOSE. IF YOU HAVE PREVIOUSLY RECEIVED A DISCHARGE IN BANKRUPTCY, THIS CORRESPONDENCE IS NOT ~ND SHOULD NOT BE CONSTRUED TO BE AN ATTEMPT TO COLLECT A DEBT, BUT ONLY ENFORCEMENT OF A LIEN AGAINST PROPERTY. You may dispute the validity of the debt or any portion thereof. If. you do so in writing within thirty (30) days of receipt of this letter, this firm will obtain and provide you wi~h wri=~en verification thereof; otherwise, the debt will be assumed to be valid. Likewise, you may request =he name and address of the original creditor if different from above. The to=al delinquency, including late and other charges is $5,628.59 for the months o~ 8/1/00 through 2/1/01. Your failure to pay the delinquent amount, plus any additional monthly Daym~.'t and late and other charges (including any accrued £aterest) r~hat .may come due wi thin the nex~ ~hirty (30) days, w~21! res":~ in acceleration of all sums due under your Mot:gage · After acceleration occurs, a foreclosure action or any other remedy permitted by your mortgage may be insSituted. EXHIBITA ' 03/1'$/01 '1'gl! 15'35 F.~T~ 215' 4508 FEOER)IAY&PI~LAN 1~003 To avoid ~he acceleration of your mortgage and subsequenb foreclosure ac=ion, ~he delinquency mentioned above and any accrual ~here~o mus~ be paid by CERTIFIED CH~CK O~ MONN~ ORDE~ and received in our offices a~ CENDANT MOKT~A~E CORPORATION, 6000 Atri~ Way, M~un~ L~urel, NJ 08054, A~=en~ion: Colle¢=ione Depar~men=, in or before ~hir=y (~0) days from ~he da~e of =his le~er. Please call (800) 257-0460 for ~he exac~ amoun~ required. You have ~he righ~ ~o reinstate your mortgage a~er acceleration by fulfilling ~he conditions stated in your mortgage pertaining to such reinstatement. You may call our office to discuss these conditions. Any future negotiations attempting to reinstate your loan or acceptance of any payment less than the full amoun= due shall no= constitute a waiver by =he mortgage holder of the acceleration unless agreed to in writin~ by the mortgage holder. You have the right to assert' in the foreclosure proceedings the non-existence of a defaul~ or any other defense to acceleration and forecl osurs. Very truly yours, By: Frank Federman FF:ll cc- Cendant Mot=gage Corporation Attn:Collections Department Loan No.- 0008445934 · EXHIBITA ......... .ALL TtIOSE CERTAIN lo~s o[' ground with the improvcmem~ ~hcr¢on erec£ed situate in ~ddlSsex Township, Cure.Hand ~un~, Pennsylvania, ~und~ ~d d~cd~d in accord~~ '~kh a ~t Plan for B~ Roush prepped by L~ B. Nei~inger, ~ofession~ L~d S~eyor, a d&py 9~ Which is ~mched hereto, ~s follows: - ~ · '" BEGINNING ~ an ~on pin in ~c no~h~ Hght-o~-w~y ~ne of 50 feet wide P~~se Road at comer:of Lo~ ~o. 149 as shown on ~c Dal~ Fc~ow Rcviscd Plan o~ ~ts recorded in ~ h~cinaf~r mentioned R~o~cr's Office in Plan B~k No. 3, Page 103; thence by s~d ~t No. ]49 Sou~h 8~ dc~ecs 15 ~nutcs ~st a distance of 172.85 feet to an ~on pin; ~cncc Sou~h 3 de,ecs 45 minutes Wc~ a ~smncc o~ 1~ feet to ~ c~sfing ~on pin a~ com~ o~ Lot No. I4~ as shown on ~c a~ve mentioned Dale Fc~ow Revised PI~ of ~s; fl~cncc by s~d ~ No. 1~ ~o~h 8~ dc~ccs 15 ~nu~cs West a distance of 172.85 fcc~ ~o' ~n iron pin in ~c not, em ~gh~- or-way linc o~ 50 rec~ wide P~~isc Road; ~hcnce by said no, hem ~gh~-or-way linc or P~dise Road North 3 de.ecs 45 minutes Eas~ a ~stancc o~ 100 feet ~o ~ iron pin nt thc place of BEGINNING. ·IAVING thereon erected a ~ingle family dwelling house with mailing address of 1 1 Paradise Road, C~lisle, Pennsylvani~ ~EING ~ts No. 147 and 148 on the ~orcmenfioned Dale Fe~ow Revised PI~ of ~ts, which Plan is record~ in the herein~tcr men~oned Kecorder's Office in Plan ~ook ~o. 3 Page 103. · . ~EING the same premises which Edith J. Myers, Executrix under the Last Will and Te~tment of Tressie A. Co~n by De~ dat~ September 16, 1983 ~d Record~ September 16, 1983 in the Office of the Recorder of Deeds in and for Cumberland County, at Carlisle, Penn~ylvania in Deed Book "J", Volume 30, Page 465, ~ant~ and conveyed to B~ry L. Roush and Linde C. Roush, husband and wife, ~e ~antom here~. BEING also as to ~t 147, ~e same premises which ~h~ E. Clepper ~d C~aline Clepper, his wi~e, by Deed dated July 3, 1948, ~nd record~ July 3, 1948 in the the a~ve- mentioned Recorder's Office in Deed B~k "V", Volume 13, Page 414, ~ant~ and conveyed ~o Luther L. Clepper, and M~ ~u Clep~r, his wife. It being also ~ to ~t 147, the same premises which the Tax Cl~m Bur~u of ~m~rland County by Deed dated M~h 6, 1964, and record~ arch 9, 1964 in the a~ve-men~oned Recorder's Of~ce in Deed Book "D", Volume 21, Peg, . ~nted ~d conveyed as the prope~y o~ Lurer Clepper, to Vernon N'I. Shkk ~d Tressie A. Shirk, l~u~b~d and wife. ~e said Luther L. Clepper, by Quit-Claim Deed dated May 9, 1991 mud recorded N{ay 14, 1991 in tl~e aforesaid Recorder's Office in Deed Book "C", Volume 35, Page 633, conveyed any interest which he may haGe had in the above-descried property by ~ue of any i~egul~fies in the ~d sale and conveyance oF the Tax Cl~m B~eau, to B~ L. Rouxh and Linde C. Rough, the Grantors heroin. 'And ~ing fumher as to ~t 147, the same premises which by Order of Cou~ recorded August 26, 1991 in Deed Book "H , "Volume 35, Page 5 pe~anen:i>, enjoined and res~ained ~e said M~ ~u Clepper, her he~s and assi~s, from asserting any cl~m or interest in or to the zaid real pro~~y adverse to that of B,~~ L. Roush and Linde ~. Roush, thc Grantor~ herein. SUBJECT IIO~EVER. to fl~c resections as ~ey appe~ on ¢.e D~e Fe~ow 'ReUsed Plan of ~ts recorded as aforesaid. VERIFICATION MARK HIINKLE hereby states that he is V.P. of CENDANT MORTGAGE SERVICES mortgage servicing agent for Plaintiff in this matter, that he is authorized to take this Verification. and that the statements made in the foregoing Civil Action in Mortgage Foreclosure are true and correct to the best of his knowledge, information and belief. The undersigned understands that this statement is made subject to the penalties of 18 Pa. C.S. Sec. 4904 relating to unsworn falsification to authorities. AFFIDAVIT OF SERVICE - CUMBERLAND (FHLMC) PLAINT/FF CENDANT MORTGAGE CORPORATION, F/K/A p}{~ MORTGAGE SERVICES CORPO~TION ~~~ ~os~, ~. ~o~~ ~o. 0~-~3-c~v~ o~v~a ~. ~o~~ ~~ o~ ~c~o~ SERVE AT- ~n ~''l .... ~ Mortgage Foreclosure BR~SWICK, ~ 3152 5 SERV~__n Served and made ~-- ----F". --. - ' --- ~., at ~ , D~~_ ' , City in the mann ~ ..... ~~u persona~tY i-n th~manner de~~ aiY served. ~crlDed be . Adult family member with whom Defendant(s) reside(s). ~Adult in charge of Defendant,s residence' name/relationship, who refused to give Manager/Clerk of place of lodging in which Defendant(s) reside(s) ~Agent or person in charge of Defendant,s office or USual place of business. company, and officer of said defendant Other. I, ..... , a competent adult, being duly SWorn according to law, depose and state that I personally handed to ~ a /rue and correc[ Copy of ~he · SSued in the captioned case on the ated above. Sworn to and subscribed Before me this Of · day ~o~~' ~0~ By' On the M n .... day of NOT SERVED ~. ., u~zen~ant NOT FO ~ , 2001 Moved UND because. ' , at O'clock Other~~ ~gnknown No Answer Vacant Sworn to and subsc ' . Before me th robed uz ~ ~ ~ ~_ _. day Not~~, ?00~. ~ .... , .. ~..., ~.. ....... <' '~"-"'~"~ "' ... ~" F~NK FEDERMAN, ESQUIRE _ I. D Suite ~400 · ~12248 One Pe~ Center Plaza at Suburb~ Station Philadelphia, PA ~ 9 ~ 03- ~ 799 (215) 563-7000 AFFIDAVIT OF SERVICE - CUMBERLAND (FHLMC) PLAINTIFF CENDANT MORTGAGE CORPORATION, F/K/A PHH MORTGAGE SERVICES CORPORATION NO. 01-1813-CIVIL DEFENDANT JOSEPH T. JORDAN OLIVIA K. JORDAN TYPE OF ACTION ~ Mortgage Foreclosure SERVE AT- 120 PALM CLUB CIRCLE ~ Civil Action BRUNSWICK, GA 31525 SERVED a ' ~o_'m o c k- o~ ~,,~ -LTL_ d ~o ~-----~~~' - ~ .Il '/m_. "~., at ..~~ . '~ _. , ~001. ~ ~ ~- . --, ~~?"~c personally served, ow: ~ Adult family member wi w om D audit in charge of ~e name/re ation hip s . ' who refused to give Manager/Clerk of place of lodging in which Defendant(s) reside(s) ...... Agent or person in charge of Defendant,s office or usual place of business. company, and officer of said defendant Other- I, , ~ a competent adult~ being duly sworn according to law, dep~and s ate that I persona ly handed to ~ a true and correct copy of the issued in the captioned case on the above. ~ated Sworn to and subscribed Before me thisday B ~ , ~0~ Not~ ~.M., ~ .... day of ~ . . , 2001, at o'clock ueren~ant NOT FOUND because Moved Unknown Other. ~ No Answer Vacant Sworn to and subscr' . B = bed e~ore me the I0~ Of~ ~, D ~ day No ~_~.~ ~,', 2001. · .'.,~;,,,....~,+..~... ATTORNEY OF PLAINTIFF ........ ,.,...~.. ~'~.'"~""~"-"'~.'<" F~NK FEDERMAN ESQUIRE I D ~12248 ...... Suite 1400 ' · One Penn Center Plaza at Suburban Station Philadelphia, PA 19103-1799 (2~5) 563-?000 P FEDERMAN AND PHELAN .-4 By: FRANK FEDERMAN Identification No. 12248 One Penn Center at Suburban Station Suite 1400 Philadelphia, PA 19103-1814 ooo Attorney for Plaintiff CENDANT MORTGAGE CORPORATION, F/~A PI~ MORTGAGE SERVICES ' CUMBERLAND COUNTY CORPORATION . 6000 ATRUIM WAY ' COURT OF COMMON PLEAS ""~- MOUNT LAUREL, NJ 08054 ' Plaintiff ' CIVIL DIVISION ,. · ,, vs. 'NO. 01-1813 JOSEPH T. JORDAN · OLIVIA K. JORDAN · 5800 ALTAMA AVENUE, #102 ' "'~' -~, BRUNSW/CK, GA 31525 ' Defendant(s) ~.., PRAECIPE FOR JUDGMENT FOR FAILURE TO TO THE PROTHONOTARY: Kindly enter judgment, in rem in fi " an..d OLIVIA K. JORDAN, Defena-~-:' ., .avor of the Plaintiff and against oJ?..S__.E~? ~T. JORDAN ~ua/s), for fa/lure to file an Answer to Plaintiffs Complaint ..,,. w~thin 20 days from service thereof and for foreclosure and sale of the mortgaged premises, and assess Plaintiff's damages as follows. . .... ., As set forth in Complaint Interest 3/1/01 TO 5/18/01 $90,860.87 TOTAL $_J,328.7~8 $92,189.65 I hereby certify that (1) the addresses of the Plaintiff and Defendant(s) are as shown above, and (2) notice has been given in accordance with Rule 237.1, copy attached. .~,.. Attorney for Plaintiff '"'~' DAMAGES ARE HEREBY ASSESSED AS INDICATED. DATE: I "' .... O' **THIS FIRM IS A DEBT COLLECTOR ATTEMPTING TO COLLECT A DEBT AND ANY INFORMATION OBTAINED WILL BE .'.' USED FOR THAT PURPOSE. IF YOU HAVE PREVIOUSLY RECE/VED A DISCHARGE IN BANKRUPTCY AND THIS DEBT WAS NOT REAFFIRMED, TH/S CORRESPONDENCE IS NOT AND SHOULD NOT BE CONSTRUED TO BE AN ATTEMPT TO COLLECT A DEBT, BUT ONLY ENFORCEMENT OF A LIEN AGAINST PROPERTY. ** FEDERMAN AND PHELAN, L.L.P. Frank Federman, Esquire Identification No. 12248 One Penn Center Plaza at ATTORNEY FOR PLAINTIFF Suburban Station, Suite 1400 Philadelphia, PA 19103-1799 (215) 563-7000 CENDANT MORTGAGE CORPORATION, · COURT OF COMMON PLEAS F/K/A PHH MORTGAGE SERVICES CORPORATION · CIVIL DIVISION vs. ' CUMBERLAND COUNTY JOSEPH T. JORDAN OLIVIA K. JORDAN · NO. 01-1813_CiViL De f endant ( s ) 5800 ALTAMA AVENUE, #102 BRUNSWICK, GA 31525 DATE OF NOTICE: ~MAY 7, 2001 THIS FIRM IS A DEBT COLLECTOR ATTEMPTING TO COLLECT A DEBT. THIS NOTICE IS SENT TO YOU IN AN ATTEMPT TO COLLECT THE INDEBTEDNESS REFERRED TO HEREIN, AND ANY INFORMATION OBTAINED FROM YOU WILL BE USED FOR THAT PURPOSE. IF YOU HAVE PREVIOUSLY RECEIVED A DISCHARGE IN BANKRUPTCY, THIS CORRESPONDENCE IS NOT AND SHOULD NOT BE CONSTRUED TO BE AN ATTEMPT TO COLLECT A DEBT BUT ONLY AS ENFORCEMENT OF LIEN AGAINST PROPERTY. ' IMPORTANT NOTICE You are in default because you have failed enter a written appearance personally or by attorney and file in writing with the court your defenses or objections to the claims set forth against you. Unless you act within ten (10) days from the date of this notice, a Judgment may be entered against you without a hearing and you may lose your property or other important rights. You should take this notice to a lawyer at once. If you do not have a lawyer or cannot afford one, go to or telephone the following office to find out where you can get legal help. CUMBERLAND COUNTY CUMBERLAND COUNTY BAR ASSOCIATION 2 LIBERTY AVENUE CARLISLE, PA 17013 (717) 249-3166 Frank Federman, Esquire Attorney for Plaintiff FEDERMAN AND PHELAN, L.L.P. Frank Federman, Esquire Identification No. 12248 One Penn Center Plaza at ATTORNEY FOR PLAINTIFF Suburban Station, Suite 1400 Philadelphia, PA 19103-1799 (215) 563-7000 CENDANT MORTGAGE CORPORATION, · COURT OF COMMON PLEAS F / K/A PHH MORTGAGE SERVICES CORPORATION ·CIVIL DIVISION vs. ' CUMBERLAND COUNTY JOSEPH T. JORDAN OLIVIA K. JORDAN · NO. 01-1813_CiViL Defendant(s) FiLE TO: OLIVIA K. JORDAN 5800 ALTAMA AVENUE, #102 BRUNSWICK, GA 31525 DATE OF NOTICE: _MAY 7, 200] THIS FIRM IS A DEBT COLLECTOR ATTEMPTING TO COLLECT A DEBT. THIS NOTICE IS SENT TO YOU IN AN ATTEMPT TO COLLECT THE INDEBTEDNESS REFERRED TO HEREIN, AND ANY INFORMATION OBTAINED FROM YOU WILL BE USED FOR THAT PURPOSE. IF YOU HAVE PREVIOUSLY RECEIVED A DISCHARGE IN BANKRUPTCY, THIS CORRESPONDENCE IS NOT AND SHOULD NOT BE CONSTRUED TO BE AN ATTEMPT TO COLLECT A DEBT BUT ONLY AS ENFORCEMENT OF LIEN AGAINST PROPERTY. ' IMPORTANT NOTICE You are in default because you h . appearance personall~z ~ ~ ..... = ave_ failed enter a wr4t~=~ court your defense.~ i~~~_~.~°rney and file in writ'~ ,~,~i~~_ _y_o~u: Unless you act within ten (10 _c=la~ms. ~set~forth against nOulce, a Judgment may be entered -j .~=YS ~rom une ~ate of this and ou ma agalnsu you without a Y y lose your property or other im ...... hearing puruanu rights. You should take this notice to a lawyer at once. If you do not have a lawyer or cannot afford one, go to or telephone the following office to find out where you can get legal help- CUMBERL~ COUNTY CUMBE~~ COUNTY BAR ASSOCIATION 2 LIBERTY AVENUE CARLISLE, PA 17013 (7~ 7) 249-3 ~66 Frank Federman, Esquire Attorney for Plaintiff FEDERMAN and PHELAN ~ By: FRANK FEDERMAN Identification No. 12248 One Penn Center at Suburban Station Suite 1400 Philadelphia, PA 19103-1814 " ~7000 Attorney for Plaintiff "'~1~ CENDANT MORTGAGE CORPO~TION, F/K/A PHH ' CUMBERLAND COUNTY .,,,,~ ' MORTGAGE SERVICES .,~. CORPORATION · Court of Common Pleas · CIVIL DIVISION Plaintiff . vs. · NO. 01-1813 -~' JOSEPH T. JORDAN ' OLIVIA K. JORDAN ' Defendant(s) ,.. FRANK FEDERMAN, ESQUIRE, hereby verifies that he is attorney for the · Plaintiff in the above-captioned matter, and that on information and belief, he has knowledge of the ...~. following facts, to wit: '~' (a) that the defendant(s) is/are not in the Military or States or its Allies, ,Naval Servic, e of the United or otherwise within the provisions of the Soldiers and Sailors Civil Relief Act of Congress of 1940, as amended -.~ (b) that defendant JOSEPH T. JORDAN is over 18 years of age and resides at 5800 ALTAMA AVENUE, #102, BRUNSWICK, GA 31525. ~.,. (c) that defendant OLIVIA K. JORDAN is over 18 years of age, and resides at 5800 ALTAMA AVENUE, #102, BRUNSWICK, GA 31525. ..~,,. ~.~, This statement is made subject to the penalties of 18 Pa. C.S. Section 4904 relating to unswom falsification to authorities. FRANK FEDERMAN Attorney for Plaintiff .,,~. -,.,~. (Rule of Civil Procedure No. 236 - Revised) CENDANT MORTGAGE ' CUMBERLAND COUNTY CORPORATION, F/K/A PHH MORTGAGE SERVICES ' CORPORATION · Court of Common Pleas · CIVIL DIVISION Plaintiff . · NO. 01-1813 VS. JOSEPH T. JORDAN i OLIVIA K. JO~~ . ' Defendant(s) ~,'. Notice is given that a Judgment in the above captioned matter has been entered against you on ~,. ,.. P'UTY ~ll~. If you have any questions concerning this matter, please contact: FRANK FEDERMAN ES UIRE Attorney for Filing Party One Penn Center at Suburban Station Suite 1400 Philadelphia, PA 19103-1814 (215) 563-7000 ~" · *THIS FIRM IS A DEBT COLLECTOR ATTEMPTING TO COLLECT A DEBT AND ANY INFORMATION OBTAINED WILL BE USED FOR THAT PURPOSE. IF YOU HAVE PREVIOUSLY RECEIVED A DISCHARGE IN BANKRUPTCY AND THIS DEBT WAS NOT REAFFIRMED, THIS IS NOT 71 AND SHOULD NOT BE CONSTRUED TO BE AN ATTEMPT TO COLLECT A DEBT, BUT ONLY "' ENFORCEMENT OF A LIEN AGAINST PROPERTY. ** ,. .. PRAECIPE FOR WRIT OF EXECUTION - (MORTGAGE FORECLOSURE) P.R.C.P. 3180-3183 CENDANT MORTGAGE CORPORATION, F/K/A PHH : CUMBERLAND COUNTY MORTGAGE SERVICES CORPORATION . Plaintiff, : No. 01-1813 V, JOSEPH T. JORDAN OLIVIA K. JORDAN : Defendant(s). : TO THE DIRECTOR OF THE OFFICE OF THE PROTHONOTARY: Issue writ o£ execution in the above matter: Amount Due $92,189.65 Interest from 5/18/01 to 9/5/01 $1,666.99and Costs (per diem - $15.15) TOTAL $93,856.64 I~'RANK FEDERMAN, ESQUIRE ONE PENN CENTER at SUBLTRBAN STATION SUITE 1400 PHILADELPHIA, PA 19103 Attorney for Plaintiff Note: Please attach description of property. No. ..'"'...ALL T2~fOSE C~RTAIN lo~x of ground wilh thc improvcmcnr~ thereon crcc£e~ situate in .~ddI~cx Township, Cure.fiend ~un~, Penn~ylvania, ~und~ ~d dczcS~d in accord~cc '~ih a ~r Plan for B~ Roush pr:p~cd by L~ B. Nci~ingcr, ~o~cssion~ L~d S~eyor, a copy 9f which is a~mched hcrc~o, as follows: "" ~EGIJV~VI,~G ~t an kon pin in ~c no~h~ Hght-of-w~y ~n: of 50 fc~ wide P~a~se Road at comdr.'of Lo~ No. 149 as shown on ~: Dal~ Fc~ow R~viscd Plan of ~s r~cord~d in h~cinaft~r m~n[~on~d R~o~:r's Of Hc: in Plan B~k ~o. 3, Page 103; thence by s~d ~t No. ~49 Sou~h Sd d~acs 15 ~nut~s ~s~ a distance of 172.85 f~gt to an ~on pin; ~gnc~ South da~es 45 minutes ~st I ~stznc= of 1~ fcct to ~ c~s~ng ~on pin mt com~ of Lot No. I46 as shown on ~c a~v~ mentioned Dale Fc~o~ R~vised PI~ of ~s; ~cncc by s~d ~ No. I~ ~o~1 S6 de~c~s 15 ~nutes ~esr a distance of 172.85 f~[ ~o' an iron pin in ~c nor~m ~gh~- of-way lin~ of 50 fact wide P~~s~ Road; thence by said nomh~m ~ght-of-way line of P~disa Road North 3 d~mcs 45 minut:s ~as~ a ~stancc of 100 f~ct to an iron pin a[ th~ place of BEGINNING. ;IA VIxVO ~hcrgon cr:c~ed a singIc family d~:Iling house with mailing address of 11 Paradise Road, C~lislc, Pennsylvania ~EI~VO ~s No. l d7 and 148 on th~ ~orgmandoncd Dale Fz~ow Revised PI~ of which Plan is rgcord~ in the hcrein~tcr mentioned R~cordcr's Offic~ in Plan Book No. 103. B EI~VO th~ same pr~miscs ~hich Edith 3. ~y~rs, Execut~x under th~ Last ~1I and Tcs:~~nt of Trcssi~ A. Co~n by Dc~ da~cd. Sep~zmb~r 1'6, 1983 and R~cord~ 19S3 in the Officz of thc Recorder of D::ds in and for Cumberland County, at Carlisl~, P~nnsylvnnia in Dasd Book "J", Volume 30, Page 465, ~ant~ and conveyed to B~~ L. Roush and Linde C. ~oush, husband and wife, ~: ~an[o~ herc~. BELVO also as to ~[ 147, ~e sam~ pr~misgs which ~h~ E. Cleppar ~d C~aI~n~ Clapp~r, h~s wife, by Dead datgd July 3, 1948, and regord~ /uly 3, 1948 in thc mentioned Rmcordcr's Offic: in D~cd B~k "V", Volu~e 13, Peg: 4I 4, ~ant~d and conveyed Luther L. Clcpp~r, and M~ ~u Clep~r, his wife. It b:ing a~o ~ to ~t 147, th: sam~ which ~h~ Tax Cl~m Bur~u of Cure,fiend County by Deed da:ed M~h 6, 1964, and recorded ~arch 9, 1964 in fha a~ve-~:n~oned R~cord~r's Or--ce in Dccd Book "D", Volum~ 21, 55. ~n~cd ~d convcyzd as ~h~ propc~y of Lurer Clgpp~r, [o V~on N'f. Sh~k ~d Tr:ss{~ Shirk, hushed and wife. ~e said Luthgr L. C]cpp~r, by Qui[-Claim Deed dated ~fay 9, lPgl recorded Nfay 14. 1991 in Iht aforesaid Rccord:r's Offic~ in Deed Book "C", Volume 35 , Pag~ 633, conveyed any intcr~sl which hc may ha~c had in [he above-descried property by ~u= of any i~agt:I~~es in Ibc ~d sale and conveyance of thc Tax CI~m B~au, to B~/L. Roush and Linde C. Roush, thc Grantors he~in. 'And ~ing ~mhcr as to ~t 147, the sang premises ~h~ch by Order of Cou~ recorded August 26, I991 ia Dead Book "H", Volum~ 35, Png~ 5 ~njoin~d and r~s=ain~d d~ said ~~ ~u C]cpp~r, her he~s a.~d assl~s, ~om ass~rring mmv c!~m or in:eros[ in or [o thc said r~al pro~~y advcrsz to ~hat of Bm~ L. Roush and Linde , . SUBJECT ;IO~VEVER. ~o d~c ras~c~ons as D%cy appa~ oa ~.~ D~ F=~ow 'R=-~scd Plan .. Tax P~cel ~21-22-0119-089 TITLE TO SAID PREMISES IS VESTED IN :Iosehp T. Jordan and Olivia K. 3ordan, his wife by Deed from Barry L. Roush and Linda C. Roush, his wife dated 8/30/91, recorded 9/4/91, in Record Book A-35, Page 408. CENDANT MORTGAGE CORPORATION, F/K/A PHH : MORTGAGE SERVICES CORPORATION · CUMBERLAND COUNTY : Plaintiff, · COURT OF COMMON PLEAS ¥o : CIVIL DIVISION JOSEPH T. JORDAN : OLIVIA K. JORDAN : NO. 01-1813 Defendant(s). : AFFIDAVIT PURSUANT TO RULE 3129 (Affidavit No. 1) CENDANT MORTGAGE CORPORATION F/K/A PHH MORTGAGE SERVICES CORPORATION, Plaintiff in the above action, by its attorney, FRANK FEDERMAN, ESQUIRE, sets ~'orth as of the date the Praecipe for the Writ of Execution was filed the following information concerning the real property located at 11 PARADISE DRIVECARLISLE~ PA 17013 1. Name and address of Owner(s) or reputed Owner(s): NAME LAST KNOWN ADDRESS (If address cannot be reasonably ascertained, please so indicate.) JOSEPH T. JORDAN 5800 ALTAMA AVENUE, #102 BRUNSWICK, GA 31525 OLIVIA K. JORDAN 5800 ALTAMA AVENUE, #102 BRUNSWICK, GA 31525 2. Name and address of Defendant(s) in the judgment: NAME LAST KNOWN ADDRESS (If address cannot be reasonably ascertained, please so indicate.) Same as above 3. Name and address of every judgment creditor whose judgment is a record lien on the real property to be sold: NAME LAST KNOWN ADDRESS (If address cannot be reasonably ascertained, please so indicate.) None 4. Name and address of the last recorded holder of every mortgage of record: NAME LAST KNOWN ADDRESS (If address cannot be reasonably ascertained, please so indicate.) MASTER FINANCIAL PO BOX 1109 INC. ORANGE, CA 92668 5. Name and address of every other person who has any record lien on the property: NAME LAST KNOWN ADDRESS (If address cannot be reasonably ascertained, please so indicate.) None 6. Name and address of every other person who has any record interest in the property and whose interest may be affected by the sale: NAME LAST KNOWN ADDRESS (If address cannot be reasonably ascertained, please so indicate.) None 7. Name and address of every other person whom the plaintiff has knowledge who has any interest in the property, which may be affected by the sale' NAME LAST KNOWN ADDRESS (If address cannot be reasonably ascertained, please so indicate.) Tenant/Occupant 11 PARADISE DRIVE CARLISLE, PA 17013 Domestic Relations of Cumberland 13 North Hanover Street County Carlisle, PA 17013 Commonwealth of Pennsylvania PO Box 2675 Department of Welfare Harrisburg, PA 17105 I verify that the statements made in this affidavit are tree and correct to the best of my personal knowledge or information and belief. I understand that false statements herein are made subject to the penalties of 18 Pa. C.S. Sec. 4904 relating to unswom falsification to authorities. May 25, 2001 DATE FRANK FEDERMAN, ESQUIRE Attorney for Plaintiff FEDERMAN and PHELAN By: FRANK FEDERMAN Identification No. 12248 Suite 1400 ATTORNEY FOR PLAINTIFF One Penn Center at Suburban Station Philadelphia, PA 19103 (~ S) SaZ-7000 CENDANT MORTGAGE CORPORATION, F/K/A PHH : MORTGAGE SERVICES CORPORATION ' CUMBERLAND COUNTY Plaintiff, ' COURT OF COMMON PLEAS V. .' : CIVIL DIVISION JOSEPH T. JORDAN : OLIVIA K. JORDAN : NO. 01-1 $13 Defendant(s). : CERTIFICATION FRANK FEDERMAN, ESQUIRE, hereby verifies that he is attorney for the Plaintiff in the above-captioned matter, and that the premises are not subject to the provisions of Act 91 because it is: ( ) an FHA mortgage ( ) non-owner occupied ( ) vacant (X) Act 91 procedures have been fulfilled This certification is made subject to the penalties of 18 Pa. C.S. Section 4904 relating to unswom falsification to authorities. FRANK FEDERMAN, ESQUIRE ~'-" Attorney for Plaintiff CENDANT MORTGAGE CORPORATION, F/K/A PHH · CUMBERLAND COUNTY MORTGAGE SERVICES CORPORATION . Plaintiff, .: · No. 01-1813 V. JOSEPH T. JORDAN : OLIVIA K. JORDAN . Defendant(s). May 25, 2001 TO: JOSEPH T. JORDAN OLIVIA K. JORDAN 5800 ALTAMA AVENUE, #102 BRUNSWICK, GA 31525 **THIS FIRM IS A DEBT COLLECTOR ATTEMPTING TO COLLECT A DEBT AND ANY INFORMATION OBTAINED WILL BE USED FOR THAT PURPOSE. IF YOU HAVE PREVIOUSLY RECEIVED A DISCHARGE IN BANKRUPTCY AND THIS DEBT WAS NOT REAFFIKMED, THIS IS NOT AND SHOULD NOT BE CONSTRUED TO BE AN ATTEMPT TO COLLECT A DEBT, BUT ONLY ENFORCEMENT OF A LIEN AGAINST PROPERTY.** Your house (real estate) at 11 PARADISE DRIVECARLISLE, PA 17013is scheduled to be sold at the Sheriff's Sale on SEPTEMBER 5, 2001 at 10:00 a.m. in the Cumberland County Courthouse, South Hanover Street, Carlisle, PA 17013, to enforce the court judgment obtained by CENDANT MORTGAGE CORPORATION F/K/A PHH MORTGAGE SERVICES CORPORATION (the mortgagee) against you. If the Sheri~'f's sale is postponed, the property will be relisted for the - Sheriff's Sale. NOTICE OF OWNER'S RIGHTS Y___OU 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 the mortgagee the back payments, late charges, costs and reasonable attorney's fees due.' To find out how much you must pay, you may call- (215) 563-7000. 2. You may be able to stop the sale by filing a petition asking the Court to strike or open the judgment, if the judgment was improperly entered. You may also ask the Court to postpone the sale for good cause. 3. You may also be able to stop the sale through other legal proceedings. You may need an attorney to assert your fights. 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.) 1. If the Sheriffs Sale is not stopped, your property will be sold to the highest bidder. You may find out the price bid by calling (_215) 563-7000. 2. You may be able to petition the Court to set aside the sale if the bid price was grossly inadequate compared to the value of your property. 3. The sale will go through only if the buyer pays the Sheriff the full amount due in the sale. To find out if this has happened, you may call (717) 240-6390. 4. If the amount due. from the Buyer is not paid to the Sheriff, you will remain the owner of the property as if the sale never happened. 5. You have the fight 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 f(led by the Sheriff within 30 days of the sale. This schedule will state who will be receiving that money. The money will be paid out in accordance with this schedule unless exceptions (reasons why the proposed distribution is wrong) are filed with the Sheriff within ten (10) days after the distribution is filed. 7. You may also have other fights and defenses, or ways of getting your home back, if you act immediately after the sale. YOU SHOULD TAKE THIS PAPER TO YOUR LAWYER AT ONCE. IF YOU DO NOT HAVE A LAWYER OR CANNOT AFFORD ONE, GO TO OR TELEPHONE THE OFFICE LISTED BELOW TO FIND OUT WHERE YOU CAN GET LEGAL HELP. CUMBERLAND COUNTY ATTORNEY REFERRAL CUMBERLAND COUNTY BAR ASSOCIATION 2 LIBERTY AVENUE CUMBERLAND COUNTY COURTHOUSE CARLISLE, PA 17013 (717) 249-3166 (800) 990-9108 .. .A..LL Ti:I'OSE CERTAIN Io~s o~ ground w£~h thc improv~mcnEs thereon crecy:cd si~a~c in . ~ "" ~EGL~V~NG a: an ~on pin in ~c no~h~ ~gh~-of-way ~nc of 50 fcic w/dc P~a~se Road ac coeur'of Loc ~o. 1~9 as shown on ~: DaI~ Fc~ow Revised Plan of ~:s recorded in h~'cinaf~r m~n~foa~d R~o~cr's Of~c: in Plan B~k ~. 3, Pag~ 103; th~nc~ by s~d ~ ~o. da~=s 45 ~nuccs ~z~: a ~s~ancc of 1~ f~c~ ~o ~ c~s~n~ ~on pin a~ co~~ of Lo~ ~o. sho~n on ~c a~vc ~cndoncd DaI: Fc~ow R~vis~d PI~ of ~s; dj:nc: by s~d ~ ~o. N%~ S6 d~e~s 15 ~2nu~s ~sr a dis:anco of ~ 72.85 fcc: ~o an iron pin in ~c nor~:~ ~h~- oLway linc of 50 fcc: wide P~~ise Road; :hence by said no~hc~ ~gh:-of-way line of Road Nor:h 3 d~~cs 45 minu~:s ~as~ a ~s~ancc of ]00 fc~t ro an iron p~a a~ thc p)ace of B E G INN IN G. , ;f~ Vf~VG thereon erected a single family d~clling house w~th mailing address of 11 Paradise Road. C~Iisle, Pennsylvanim BEING ~ts No. I47 and 148 on the ~eoremen~oned Dale Fe=ow R:viscd PI~ of ~~, which Plan is record~ in ~he hcrein~rer mentioned Recorder's Office ia Plan Book No. 3, Page I03. BEING the same r-mi - · ' ' ' Tc , - · P ~ sc~ wn~ch ._i~enr or Trcss~e A Co~-- ~- ~ ,- Edith I. Myers, ExeCutes under =he L 1983 in ~h* ~ca_, ~ _ ,~,, uy ~c~ dared SeDre~b ~ ,no~ ~ _ _ _ asr %'ili nd P=nnsyIvania in Deed Book "3", Volume 30, Pa~c 465, ~an~ and conveyed :o Ban7 L. Roush -~- ~u~ocrtan= ~oun~y, a~ Carlisle, and Linde C. Roush, husband and wife ~c ~anro~ he, am. ~EI;VO also as To ~ 147, ~c sam: premises which ~h~ ~. C!eppar ~nd C~a!inc ClapD~r, his wife, by Dead da[cd July 3, 1948, and record~ Iuly 3, 1948 in th= th= ~cnrioned Rzcordcr's Office in Deed B~k "V" V - 4I~, ~anred a-d conv-~-~ · ax ..... , ~u~u oc ~-um~rlan~ ~ounry by D ~?rch 9, {964 in the a~vc-mcndoncd Rcco · ~ ~~n 6, 1964, and recorded Sh~rk hush..a ..... ~cOs the propc~y of gu~*- ~.~- Deed Boo "~" .. recorded May I4, 1991 in ~I~c aforesaid Rccorder's Office in Deed Book "C", Volume 35 , Page 633,. COnveyed any inrere=: which he may haGe had in [he above-descried property by ~u= of any ~cgt:l~d~ez in [he s~d sale and conveyance of thc Tax C/~m B~cau, to B~/L. Roush and L/nde C. Rou=h t,he Grantors he=i%.I i~ Dead Book "~", Volume 35, Page 5 'And ~in ~nhcr by Order of Co~ recorded August-6, 199 g as ro ~t 147, ~he same premises ~h~ch enjeined and res~ained dec said ~~W ~u Clcpper, her he~s and assi~s, ~om asserting c!~m or in:eres~ in or ro thc said real pro.ay adverse co that of R,%W L. Roush and Linde Roush, the Grat~rors herein. · , SE/EJECT ;IO~VEVER. to d~c res~c~ons a~ d~cy appe~ on ~.e D~* F:~ow 'Rc'~scd Plan Tax P~cel ~21-22-0119-089 losehp T. lordan and Olivia K. lordan, kis wife by Deed from Barry L. Roush and Linda C. Roush, his wife dated 8/30/91, recorded 9/4/91, in Record Book A-35, Page 408. , AFFIDAVIT OF SERVICE PLAINTIFF , CENDANT MORTGAGE CORPORATION, CUMBE~AND COUNTY F/K/A PHH MORTGAGE SERVICES No.01-1513 CORPORATION DEFENDANT(S) JOSEPH T. JORDAN Type of Action OLIVIA K. JORDAN - Notice of Sheriff's Sale SERVE JOSEPH T. JORDAN AT Sale Date: SEPTEMBER 5, 2001 5800 ALTAMA AVENUE, #102 BRUNSWICK, GA 31525 SERVED Served and made known to ~ ~::~x,.l~ ~ Defen ..... / t., · ~ -____, aant, on me I ~ ~ day of ~-- , 200~, of ~v~yl~fia, in the ~~er described below: ~~ ., Co~onwealth Defendant personally served. ~Adult family member with whom Defendant(s) reside(s). Relationship is ~Adult in charge of Defendant(s) 's residence who reused to give name or relationship. ~_Manager/Clerk of place of lodging in which Defendant(s) reside(s). ~Agent or person h charge of Defendant(s)'s office or usual place of bus,ess. an officer of said Defendant(s)'s company. ~ Other: Description: Age ~ Height Weight ~ Race ~ Sex ~ Other I ~ _, a competent adul ~sg rding to law, depose and state that I personally handed a tree and co~ect copy of the Notic~ the address ind.~ca~d above. ~/~~herein, issued i~ the captioned case on the date and at Sworn t~ and subscribed befo~e n~e this ~ day of ~~_~, 2~1. .~ ~~on ~ir.s ~av ~. ~0~. NOT SER~D On the day of _, 200~, at~ o'clock ~.m., Defendant NOT FOUND because: ~ Moved ~ U~o~~ No Answer ~ Vacam Other: Sworn to and subschbed before me this~ day of _, 200 Notary: By: Attorney t~r Plaintiff Frank Federman, Esquire- I.D. No. 12248 One Penn Center Suburban Station, Suite 1400 Philadelphia, PA 19103 (215) Sa~-7000 · .. · · .,. AFFIDAVIT OF SERVICE PLAINTIFF ' CENDANT MORTGAGE CORPORATION, CUMBERLAND COUNTY , F/K/A PHH MORTGAGE SERVICES No.01-1813 CORPORATION DEFENDANT(S) JosEpH T. JORDAN Type of Action OLIVIA K. JORDAN - Notice of Sheriff's Sale SERVE OLIVIA K. JORDAN AT Sale Date: SEPTEMBER 5, 2001 5800 ALTAMA AVENUE, #102 BRUNSWICK, GA 31525 SERVED Served and made known to , Defendant, on the day of_~J~.,~ _, 200J_, ., Commonwealth of Pennsylvania, in the manner described below: ,De£endant personally served. .__t~Adult family member with whom Defendant(s)reside(s). Relationship is ~t~_,y~ -~~ _~~_,~ Adult in charge of Defendant(s)'s residence who refused to give name or relationship. - -~_._Manager/Clerk of place of lodging in which Defendant(s) reside(s). ~~_.Agent or person in charge of Defendant(s)'s office or usual place of business. - an officer of said Defendant(s)'s company. ~ Other: Description: Age If=, Heig~ Wei Race ~ffL__ Sex /~Other I, _ _ ~t~ ~'~'-'~, a competent adult, bein to law, depose and state that I personally handed a true and correct copy of the Notic, in the herein, issued in the captioned case on the date and at the address indicated above. Sworn to and subscribed before me this ~ day o f__~. ~, 200A. Nota~-: By: It~ C, ot~ion ~ite, s te, a~'9. ~'~0~ NOT SERVED On the day of _, 200__, at~ o'clock ~.m., Defendant NOT FOUND because: Moved _ Unknown...____ No Answer ______ Vacant Other: Sworn to and subscribed before me this_ _ day of _, 200 · Notary: -- By: Attorney for Plaintiff Frank Federman, E~uire- I.D. No. 12248 One Penn Center at Suburban Station 1617 John F. Kennedy Boulevard, Suite 1400 Philadelphia, PA 19103-1814 (215) 563--7000 SALE DATE: SEPTEMBER $, 2001 · IN THE COURT OF COMMON PLEAS OF CUM~El~AND COUNTY, PENNSYLV~IA CIVIL ACTION- LAW CENDANT MORTGAGE COP~OI~TION, F/K/A PI-IH MORTGAGE CORPORATION No.' 0 l- 1 ~ 1 ~ VS, OSEPH T. $ORD~ OLIVIA K. $ORDAN AFFIDAVIT PURSUANT TO RULE 3129.1 AND RETU~ OF SERVICE PURSUIT TO 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: As required by Pa. R.C.P. 3129.2(a) Notice of Sale has been given in the manner required by Pa. R.C.P. 3129.2(c) on each of the persons or parties named, at that address set forth on the attached Affidavit No. 2 (previously filed) and Supplemental Affidavit No. 2 on the date indicated, and a copy of the notice is attached as an Exhibit. A copy of the Certificate of Mailing (Form 3817) and/or Certified Mail Return Receipt stamped by the U.S. Postal Service is attached for each notice. August 14, 2001 CENDAaNT MORTGAGE CORPORATION, F/K/A PHH · MORTGAGE SERVICES CORPOI~TION ' CUMBERLAND COL~TY Plaintiff, ' COURT OF COMMON PLEAS V. · CIVIL DIVISION JOSEPH T. JORDAN . OLIVIA K. JORDAN · NO. 01-1813 Defendant(s). . AFFIDAVIT PURSUANT TO RULE 3129 (Affidavit No. 1) CEND~ANT MORTGAGE CORPORATION. F/K/A PHH MORTGAGE SERVICES CORPORATION_, Plaintiff in the above action, by its attorney, FRANK FEDERMAN, ESQUIRE, sets forth as of the date the Prae¢ipe for the Writ of Execution was filed the following information concerning the real property located at 11 PAR.,kDISE DRIVECARLISLE PA 17013 1. Name and address of Owner(s) or reputed Owner(s): NAME LAST KNOWN ADDRESS (If address cannot be '- reasonably ascertained, please so indicate.) JOSEPH T. JORDAN 5800 ALTAMA AVENUE, #102 BRUNSWICK, GA 31525 OLIVIA K. JORDAN 5800 ALTAMA AVENUE, #102 BRUNSWICK, GA 31525 2. Name and address of Defendant(s) in the judgment: NAME LAST KaN0~ ADDRESS (If address cannot be reasonably ascertained, please so indicate.) Same as above 3. Name and address of every judgment creditor whose judgment is a record lien on the real property to be sold: NAME LAST K~NO~ ADDRESS (If address cannot be reasonably ascertained, please so indicate.) None 4. Name and address of the last recorded holder of every mortgage of record: NAME LAST KNOWN ADDRESS (If address cannot be reasonably ascertained, please so indicate.) MASTER FINANCIAL PO BOX 1109 INC. ORANGE, CA 92668 5. Name and address of every other person who has any record lien on the property: NAME LAST KNOWN ADDRESS (If address cannot be reasonably ascertained, please so indicate.) None 6. Name and address of every other person who has any record interest in the property and whose interest may be affected by the sale- NAME LAST KNOWN ADDRESS (If address cannot be reasonably ascertained, please so indicate.) None 7. Name and address of every other person whom the plaintiffhas knowledge who has anv interest in the property, which may be affected by the sale' NAME LAST KNOWN ADDRESS (If address cannot be reasonably ascertained, please so indicate.) Tenant/Occupant 11 PARADISE DRIVE CARLISLE, PA 17013 Domestic Relations of Cumberland 13 North Hanover Street County Carlisle, PA 17013 Commonwealth of Pennsylvania PO Box 2675 Department of Welfare Harrisburg, PA 17105 I verify that the statements made in this affidavit are true and correct to the best of my personal knowledge or information and belief. I understand that false statements herein are made subject to the penalties of 18 Pa. C.S. Sec. 4904 relating to unswom falsification to authorities. DATE FEDERLV~AN, ESQUIRE Attorney for Plaintiff DATE- May 25, 2001 TO- ALL PARTIES IN INTEREST AND CLAIMANTS NOTICE OF SHERIFF'S SALE . OF REAL PROPERTY OWNER(S) JOSEPH T. JORDAN OLIVIA K. JORDAN PROPERTY: 11 PARADISE DRIVE CARLISLE, PA 17013 Improvements. Residential Property CUMBERLAND COUNTY The above-captioned property is scheduled to be sold at the Sheriffs Sale on SEPTEMBER 5, 2001 at !0:00 a.m. in CCarlisle~ PA_. Our records indicate that you may hold a mortgage or judgment on the property, which may be extinguished by the sale. You may wish to attend the sale to protect your interests. A schedule of Distribution will be filed by the Sheriff On a date specified by the Sheriff not later than 30 days after sale. Distribution will be made in accordance with the schedule unless exceptions are filed thereto within 10 days after the filing of the schedule. LH STATE OF PENNSYLVANIA, COUNTY OF CUMBERLAND ss. Robert: P Zieg].er I, .............................................................................. Recorder Deeds in and for said County and State do'hercby certify that the Sheriff's Deed in which ................ · Federal Home Loan Mtg Corp is the grantee the same having been sold to said grantee on the ...... ~_h_ ..................................... day of 01 S ep t ember A.D., ~ ..... , under and by virtue of a writ .............. 8ch Execution issued on the ~ .... ~. ,., ~ ,., .. ,., ~,, ,., .,. ,., .., ,., .. ~,., -, -, ,., ,.~ .., ~ ~ ~ ........................................................... · da), o~ June A.D.,01 ............................... ~ out of thc (]ourt of Comman Picas of said County as of 01 Civil Term, ' Number 1813 at thcsuitof Cendant Mtg Corp fka PHH Mtg Serv Corp Joseph T Jordan & Olivia K ................................... against .................................................... 248 2576 duly recorded in Shcri~£s Deed Book No ............. , Page ............. IN TESTIMONY WHEREOF, I have hereunto set my hand and seal of said office this _ __~~______ day o,____ ,,. Recorder of Dcc~ Cendant Mortgage Corporation, f/k/a In The Court of Common Pleas of PHH Mortgage Services Corporation Cumberland County, Pennsylvania VS Writ No. 2001-1813 Civil Term Joseph T. Jordan and Olivia K. Jordan R. Thomas Kline, Sheriff, who being duly sworn according to law, states he served the above Real Estate Writ, Notice, Poster and Description in the following manner: The Sheriff mailed a notice of the pendency of the action to one of the within named defendant to wit: Joseph T. Jordan, by Certified Mail Return Receipt Requested, Restricted Delivery, Deliver to Addressee Only, to his last known address of 5800 Altama Avenue, #102, Brunswick, GA 31525. This letter was mailed under the date of June 29, 2001. On July 23, 2001, the unopened letter was returned to the Sheriff's Office with reason checked "unclaimed." R. Thomas Kline, Sheriff, who being duly sworn according to law, states he served the above Real Estate Writ, Notice, Poster and Description in the following manner: The Sheriff mailed a notice of the pendency of the action to one of the within named defendant to wit: Olivia K. Jordan, by Certified Mail Return Receipt Requested, Restricted Delivery, Deliver to Addressee Only, to her last known address of 5800 Altama Avenue, #102, Brunswick, GA 31525. This letter was mailed under the date of June 29, 2001. On July 23,2001, the unopened letter was returned to the Sheriff's Office with reason checked "unclaimed." Dawn L. Kell, Deputy Sheriff, who being duly sworn according to law, states on July 2, 2001 at 8:50 o'clock A.M., EDST, she posted a tree copy of the above Real Estate Writ, Notice, Poster and Description on the property of Joseph T. Jordan and Olivia K. Jordan, located at 11 Paradise Drive, Carlisle, PA 17013, according to law. R. Thomas Kline, Sheriff, who being duly sworn according to law, states that he served the above Real Estate Writ, Notice, Poster and Description in the following manner: The Sheriff mailed a pendency of the action to one of the within named defendants, to wit: Joseph T. Jordan, by regular mail to his last known address of 5800 Altama Ave., # 102, Brunswick, GA 31525. This letter was mailed under the date of July 24, 2001 and never returned to the Sheriff's Office. R. Thomas Kline, Sheriff, who being duly sworn according to law, states that he served the above Real Estate Writ, Notice, Poster and Description in the following manner: The Sheriff mailed a pendency of the action to one of the within named defendants, to wit: Olivia K. Jordan, by regular mail to her last known address of 5800 Altama Ave., # 102, Brunswick, GA 31525. This letter was mailed under the date of July 24, 2001 and never returned to the Sheriff's Office. R. Thomas Kline, Sheriff, who being duly sworn according to law, says that after due and legal notice had been given according to law, exposed the within described premises at public venue or outcry at the Court House, Carlisle, Cumberland County, Pennsylvania, on September 5,2001 at 10:00 A.M., E.D.S.T., and sold the same for the sum of $1.00 to Attorney Frank Federman for Federal Home Loan Mortgage Corporation. It being highest bid and best price received for the same, Federal Home Loan Mortgage Corporation of Foreclosure Unit, Mail Stop 61, P.O. Box 5000, Vienna, VA 22183-5000, being the buyer in this execution paid Sheriff R. Thomas Kline the sum of $1,283.67, it being costs. Sheriff' s Costs: Docketing 30.00 Poundage 25.17 Posting Handbills 15.00 Advertising 15.00 Acknowledging Deed 30.00 Auctioneer 10.00 Law Library .50 Prothonotary 1.00 Mileage 3.25 Certified Mail 14.30 15.00 Levy 30.00 Surcharge Law Journal 586.25 Patriot News 431.04 Share of Bills 25.66 Distribution of Proceeds25.00 Sheriff' s Deed ~ $1283.67 So Aa.sw~: ~~: Sworn and subscribed to before me [.,r__.~',~.,~~ This ~ day of L~~-g,~ R. Thomas Kline, Sheriff thonotary -~eal Estate Deputy CENDANT MORTGAGE CORPORATION, FflUA PHH : MORTGAGE SERVICES CORPORATION : CUMBERLAND COUNTY Plaintiff, : COURT OF COMMON PLEAS V. ; : CIVIL DIVISION JOSEPH T. JORDAN : OLIVIA K. JORDAN : NO. 01-1813 Defendant(s). : AFFIDAVIT PURSUANT TO RULE 3129 (Affidavit No. 1) CENDANT MORTGAGE CORPORATION~ F/K/A PI, IH MORTGAGE SERVICES CORPORATION, Plaintiff in the above action, by its attorneY, FRANK FEDERMAN, ESQUIRE, sets forth as of the date the Praecipe for the Writ of Execution was filed the following information concerning the real property located at 11 PARADISE DRIVECARLISLE~ PA 17013 1. Name and address of Owner(s) or reputed Owner(s): ,,, NAME LAST KNOWN ADDRESS (If address cannot be reasonably ascertained, please so indicate.) JOSEPH T. JORDAN 5800 ALTAMA AVENUE, #102 BRUNSWICK, GA 31525 OLIVIA K. JORDAN 5800 ALTAMA AVENUE, #102 BRUNSWICK, GA 31525 2. Name and address of Defendant(s) in the judgment: NAME LAST KNOWN ADDRESS (If address cannot be reasonably ascertained, please so indicate.) Same as above 3. Name and address of every judgment creditor whose judgment is a record lien on the real property to be sold' NAME LAST KNOWN ADDRESS (If address cannot be reasonably ascertained, please so indicate.) None CENDANT MORTGAGE CORPORATION, F/K/A PHH · CUMBERLAND COUNTY MORTGAGE SERVICES CORPORATION · Plaintiff, · No. 01-1813 . JOSEPH T. JORDAN : OLIVIA K. JORDAN . Defendant(s). May 25,2001 TO: JOSEPH T. JORDAN OLIVIA K. JORDAN 5800 ALTAMA AVENUE, # 102 BRUNSWICK, GA 31525 **THIS FIRM IS A DEBT COLLECTOR ATTEMPTING TO COLLECT A DEBT AND ANY INFORMATION OBTAINED WILL BE USED FOR THAT PURPOSE. IF YOU HAVE PREVIOUSLY RECEIVED A DISCHARGE IN BANKRUPTCY AND THIS DEBT WAS NOT REAFFIRMED, THIS IS NOT AND SHOULD NOT BE CONSTRUED TO BE AN ATTEMPT TO COLLECT A DEBT, BUT ONLY ENFORCEMENT OF A LIEN AGAINST PROPF. RTY.** Your house (real estate) at 11 PARADISE DRIVECARLISLE, PA 17013is scheduled to be sold at the Sheriffs Sale on SEPTEMBER 5, 2001 at 10:00 a.m. in the Cumberland County Courthouse, South Hanover Street, Carlisle, PA 17013, to enforce the court judgment obtained by CENDANT MORTGAGE CORPORATION F/K/A PHH MORTGAGE SERVICES CORPORATION (the mortgagee) against you. If the Sheriff's sale is postponed, the property will be relisted for the Sheriffs Sale. NOTICE OF OWNER'S RIGHTS YOU MAY BE ABLE TO PREVENT THIS SHERIFF'S SALF, To prevent this Sheriffs Sale, you must take immediate action' 1. The sale will be cancelled if you pay to the mortgagee the back payments, late charges, costs and reasonable attorney's fees due.' To find out how much you must pay, you may call' (215) 563-7000. 2. You may be able to stop the sale by filing a petition asking the Court to strike or open the judgment, if the judgment was improperly entered. You may also ask the Court to postpone the sale for good cause. 3. You may also be able to stop the sale through other legal proceedings. You may need an attorney to assert your rights. The sooner you contact one, the more chance you will have of stopping the sale. (See notice on page two on how to obtain an attorney.) YOU MAY STILL BE ABLE TO SAVE YOUR PROPERTY AND YOU HAVE OTHER RIGHTS EVEN IF THE SHERIFF'S SALE DOES TAKE PLACE. 1. If the Sheriffs Sale is not stopped, your property will be sold to the highest bidder. You may find out the price bid by calling (215) 563-7000. 2. You may be able to petition the Court to set aside the sale if the bid price was grossly inadequate compared to the value of your property. 3. The sale will go through only if the buyer pays the Sheriff the full amount due in the sale. To find out if this has happened, you may call (717) 240-6390. 4. If the amount due from the Buyer is not paid to the Sheriff, you will remain the owner of the property as if the sale never happened. 5. You have the fight to remain in the property until the full amount due is paid to the Sheriff and the Sheriff gives a deed to the buyer. At that time, the buyer may bring legal proceedings to evict you. 6. You may be entitled to a share of the money which was paid for your house. A schedule of distribution of the money bid for your house will be filed by the Sheriff within 30 days of the sale. This schedule will state who will be receiving that money. The money will be paid out in accordance with this schedule unless exceptions (reasons why the proposed distribution is wrong) are filed with the Sheriff within ten (10) days after the distribution is filed. 7. You may also have other fights and defenses, or ways of getting your home back, if you act immediately after the sale. YOU SHOULD TA~ THIS PAPER TO YOUR LAWYER AT ONCE. IF YOU DO NOT HAVE A LAWYER OR CANNOT AFFORD ONE, GO TO OR TELEPHONE THE OFFICE LISTED BELOW TO FIND OUT WHERE YOU CAN GET LEGAL HELP. CUMBERLAND COUNTY ATTORNEY REFERRAL CUMBERLAND COUNTY BAR ASSOCIATION 2 LIBERTY AVENUE CUMBERLAND COUNTY COURTHOUSE CARLISLE, PA 17013 (717) 249-3166 (800) 990-9108 . . . · .'.~.A£L T2c. I'~$E CERTAIN lo:s of ground with thc irnprovcmenrk thereon erec£cd .,'tiddI~'.~¢x To n_ship, Cumberland Count, Pennsylvania, bounded and · 'u,4hh a L6¢ Plan for B~ Roush prepared b L · . d.e~cm d6py of'which bcd in accordance -- . ~$ a~chad her'al:o, as foIIow:~. Y. arty B. 1N'=~ln~er' l:¥ofc$$~on-,9.l La.nd Surveyor, a · ~ "" 27EGL%%VI,,,VG a~ an iron pin in thc northern right-of-way lin: of' 50 fc=c xuid¢ Paradise Road a: corner'of Lot No. 149 as sho~n on the Da/= Fc=ow Revised Plan of Lo~$ recorded in ha."einafr&r menrfoned Racorder's Office in Plan Book No. 3, Page 103; :hence by sa/d Lot No. degrees 45 .."".inures VYc~: a d~s:anc= of 100 fcc: to an ¢;ds~iag iron pin at corner of' Lot No. I46 as shown on thc above mentioned Dale Fctrou,, Revised PIa. n of Lots; d~¢nc¢ by $,'%/.d Lot: No. N'o~: Sc~ degrees 15 rr~nut~s %x/~sr a distance of ! 72.85 feet ~o an iron pin in r2,,¢ norr. hern right= of-way l/ne of 50 feec wide Paradise Road; thence by said northern ~ght-o£-v,,ay linc of' Paradise Road North 3 de=~rees 45 minutes East a d.i_~tanc¢ of 100 feet !:o an iron pin at the piece of' B E G INN'IN G. · lira VLVG thereon tree:ed a sing!e family dwelling house wfth mailing address of 11 Paradise Road. Carlisle, ~ennsylvanin. · . . BEI;v'G r_ora N'o. 147 and 148 on the a_roremen~oned Dale Fen'ow Revised Plan of Lots, which Plan is recorded in the hereinafter mentioned Recorder s Office ia Plat,. lgook No. 3, Page I03. , . · 2~EING the same premises which Edith J. Nlver.s, E×eeurhx under the Last ~x/i!I and Te~n. rr..¢nr or' Tressie A. Co~n by D¢-_d dared $¢prerC, ber 16, 1983 and Recorded. I983 in the Office of' the Recorder of' Deeds in and for Cumberland County, ~.t Carlisle Pennsylvania in Deed Book "' ~ , ¥o~t:rr,..¢ 30, Page 465, grar,.red and conveyed to Ba.--:-y L. Rous~ and Linde C. Roush, husband and wife, the grantors herein. BEING also as to Lot 147, ~c same premises which A. rthu.r E. C!epper a.nd Carma!ine Clepper. his wife, by' Deed dated July 25, 1948, and recorded July 3, 1948 in the the abeve- mcnrione~ Recordcr's Office in Deed Book "V", Volume 13 Pa Luther L. Clcpoer, and M~ Lo ,· · N!arch 9, 196fin the above u_Clept:~r, h~s w~£¢ I, b¢~,-- -"-- ge 414, granted and ¢onvey.¢_.~ which the Tax Claim Bureau of Cumberland Coun~, gv ir,'--~~° as_to Lot 1,47, thc same premises 55 nrc-* ' ., . ,-,~cra anted March 6, 1964, and recorded .._: gra ,.. and conva,.,,-~ ... mentioned R¢corder's O£fic¢ in D ,, ,, · --.~,., ,,,~ the ro - ccd Book: ID .~htrk, husba.nd and wife. 'l~hc .... P. l::...rty of' Luther Cleon¢,- ,,- ~r ..... , Volu,,-nc 21, Pac,- sal~ Lul:kcr L r"? .... ,_ -...,- -, kw vernon ~'i ..Shirk :,-~ .-r. ..... recorded May 14 1991 in rile aforesaid Rccorder's Office in Deed Book "C", Volume 35 , Page · --, ~=~u =area tVlay 9, 1991 and 623, convc.,.,cd any interest which he may haG¢ had in the above-described propcr:7 by ~-rtue 05 ar...,, ir:'-cgula..qfies in thc said sale and conveyance of thc Tax Cla/m Bureau, to B,u-r,/L. Roush and r-inda C. P-,ou.sh, the Grantors herein. 'And being farther as to Lot 147, the same prem£sez which by Order of' Court recorded August 26, 1991 ir:, Deed Book "H", Volume 35, Page 5 '-njeined and rcs~aincd tl,.e said M.a.:-y Lou C/cpp¢:-, her heh's and assigns, from asserting ar., '!a. im or in:crest in or to the said rea/ prope,wy adverse co [her of B,%~ L Roush and Linde C'. ~.oush, thc Grate:ors herc,;n.. , Tax Parcel #21-22-0119-089 PREi~SES IS VESTED IN ~oseh . eed from Barry L. Roush and Linda ~ u~. ~ ~. p .T,. Jordan and Olivia K. Jordan, his wife by Book A-35, Page 408. ~... ~.~u~u, nas wire dated 8/30/91, recorded 9/4/91, in Record WRIT OF EXECUTION and/or ATTACHMENT · .. : . . COMMONWEALTH OF PENNSYLVANIA) " NO. 0'1- ].8'i3 COUNTY OF CUMBERLAND) CIVIL 3~ TERM CIVIL ACTION - LAW TO THE SHERIFF OF Oznberland COUNTY: To satisfy the debt. interest and costs due Cendant Nortgage CorDoration, F/K/A PHH Hort a~ Services Corporation PLAINTIFF(S) from Joseph T. Joz~lan and Olivia K. Jo~lan, 5800 Altama Avenue, #102, B~'unswick, GA' 31525 DEFENDANT(S) (1) You are directed to levy upon the prope~y of the defendant(s) and to sell See ~egal Desc~iptio~ (2) You are also directed to a.ttach 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 notify him/her that he/she has been added as a garnishee and is enjoined as above stated. Amount Due $92,189.65 L.L. $. 50 frcm 5/18/01 to 9/5/01 Interest p~r di_~..-$!5~ 15 - $!~666.99 and Cc_,stsDue Prothy $1.00 Atty's Comm % Other Costs Arty Paid $129.10 Plaintiff Paid Date: _ June 8, 2001 Curtis R. Long Prothonotary. Civil Division REQUESTING PARTY- Deputy Name Frank Federman, Esq. Address: One Penn Center at Suburban Station, Suite 1400 Philadelphia, PA 19103 A~orney for: Plaintiff Telephone: 215-563-7000 Supreme Court ID No. 12248 REAL ESTATE SALE No. ~~ .,... / ~ ~ 3, ~c, o l the ~neritt levied upon the ~etenoa~',t~ ~..:~.,moerlano Coun[~ ~-";~.. ~n~,.,~ .~..d number~ as // ~~- ~~ _ and more fuii):, rjescribed on ~hibit "A" filed with this writ and by this reference incoroorated PROOF OF PUBLICATION OF NOTICE IN CUMBERLAND LAW JOURNAL (Under Act No. 587, approved May 16, 1929), P. L. 1784 STATE OF PENNSYLVANIA · · $$o 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 the 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. REAL F~?&TE ~E NO. 26 Writ No. 2001-1813 Civil Cendant Mortgage Corporation, F/K/A PHH Mortgage SWORN TO AND SUBSCRIBED before me this Servtces Corporation 3 day of AUGUST, 2001 Olivia K. Jordan d _ Atty.: Frank Federman Notary ALL THOSE CERTAIN lots of -' ground with the improvements there- on erected situate in Middlesex Town- t ' ' ' "-'--~ ' "'""' vania, bounded and described in '~. accordance with a Lot Plan for Barry Roush prepared by Larry B. Nejd- linger, Professional Land Surveyor, a copy of which is attached hereto, as follows: THE PATRIOT NEWS THESUNDAY PATRIOT NEWS Proof of Publication Under Act 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 P___atriot-News and~ 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 Mis Volume 14, Page 317. ~ c/~a/..t neous Book "M", PUBLICATION .... , ....... .,..,...,...,.,.,......,,. ,.o.....,..,,.,,,,,.,.,,.,,,.,.,.o,...,.,.,,.,..,...,,,,,,,, CO PY Sworn to and subscribed before2~~ S A L E #26 s 21st da.,y~i Augu~i~001 A.D. ,'. ..c~.T~~ ... I ~,~~, o~~C,o.r~ _ ' "- ? ' .--~.~ ' ~ My c~,mao, F.x~# ,~,e L ax~ L ~nt ' · .., ' Menfoe~, Petmsy~vania ASSOCiat~ Ot N~mMl~commission expires June 6, 2002 .. ,-. . . . .. , . ...,. cou sH R, :s .......'. ,' .':.. ".; cu B R cou, cou, ous "'.. ,...' ' - C^RL,SL , P^. " ' Statement of Advertising ,"~w~,x~s. ~i~, '" wie..: ~' C O S t S Ex''~ ?o,v,Shi,,'"'"'~..~ '~.~.ua~.' .,,.lWiddb.', TO THE PATRIOT-NEWS CO., Dr. ~nnsvlvan:~ " T ' _',,umoerla~d .. ' .Co · .. ,, ,i~, '-IXXl-a,~ .'. :,_, -- ulft. v' ...... ~ · ' -' For publishing the notice or publication attached . accordance .'with ° ,'... ,,. · ~, 'descnl~. 'in · ~.mr~ ~y ba~j a',,~'~ ......~' R~h.' hereto on the above stated dates .' .... w,~ o~,~. , ''" Probating same Notary Fee(s) $ · _he,to, as.fo/lows:.. . . . .... ,s auac~ $ 429.54 a.:.,EOI..N. INO at. an ,m. p?.i,'~ ~' ngi,, Total 1.5 0 - ,-,u. ~,f~ aS'S/tOW ' .'P_~w,~.i.d.p~.......'..,.o,~.~e ~-hlisher's Receipt for Advertising Cost .................. -'"-:~ma~L~_U~. -- The Patriot News Co., publisher of T__he Patriot-News~and The Sunda Patrio-New , newspapers of general circulation, hereby acknowledge receipt of the aforesaid notice and publication costs and certifies that the same have been duly paid.