HomeMy WebLinkAbout02-0091THOMAS I. PULEO
InENTIFICATION NO. 27615
620 Sentry Parkway, Suite 100
BLUE BELL, PENNSYLVANIA 19422
610) 941-3600
ATTORNEY FOR
ATLANTIC MORTGAGE & INVESTMENT
CORPORATION, a division of
ABN AMRO Mortgage Group, Inc
7159 Corklan Drive
Jacksonville, Florida 32258
V.
SHANE D. BURGER and
SHELLEY LEE LAWRENCE
403 Deerfield Road
Camp Hill, PA 17011
PLAINTIFF
UM ?Y
By%AnnON9M .
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DI VISION
TERM,
No Q,,2 - 41 (!w
CIVIL ACTION - MORTGAGE FORECLOSURE
COMPLAINT
"NOTICE
'You have been sued in court. If you wish to defend against the
claims set forth in the following pages, you must take action within twenty
(20) days after this complaint and notice are served, by entering a written
appearance personally or by attorney and filing in writing with the court
your defenses or objections to the claims set forth against you. You are
warned that if you fail to do so the case may proceed without you and a
judgment may be entered against you by the court without further notice for
any money claimed in the complaint or for any other claim or relief
requested by the plaintiff. You may lose money or property or other rights
important to you.
'YOU SHOULD TAKE THIS PAPER TO YOUR LAWYER AT ONCE.
IF YOU DO NOT HAVE A LAWYER OR CANNOT AFFORD ONE, GO TO
OR TELEPHONE THE OFFICE SET FORTH BELOW TO FIND OUT
WHERE YOU CAN GET LEGAL HELP.
Court Administrator
4th Floor, Cumberland County Courthouse
Carlisle, PA 17013
(717) 240-6200
"AVISO
'Le han demandado a usted an to torte. Si usted quiere defenderse
de estas demandas expuestas en las paginas siguientes, usted tiene veinte
(20) dies, de plazo at partir de to fecha de to demanda y to nolificatian.
Hace falta asentar una comparencia escrita o an persona o con un
abogado y entregar a la carte an forma escrita sus defenses o sus
objeciones a las demandas on contra de su persona. Sea avisado qua si
usted no se defiende, la torte tomar9 medidas y puede continuer la
demanda an contra suya sin previo aviso o nolificacion. Ademas, Is coarte
puede decidir a favor del demandante y requiere qua usted cumpla con
lodas las provisioner de esta demanda. Listed puede perder dinero o sus
propiedades u otros derechos importantes pars usted.
'LLEVE ESTA DEMANDA A UN ABOGADO INMEDIATAMENTE. SI
NO TIENE ABOGADO O SI NO TIENE EL DINERO SUFICIENTE DE
PAGAR TAL SERVICIO, VAYA EN PERSONA O LLAME FOR TELEFONO
A LA OFICINA CUYA DIRECC16N SE ENCUENTRA ESCRITA ABAJO
PARA AVERIGUAR DONDE SE PUEDE CONSEGUIR ASISTENCIA
LEGAL.
Court Administrator
4th Floor, Ct.uflberland County Courthouse
Carlisle, PA 17013
(717) 240-6200
LAW OFFICE OF
THOMAS I. PULEO
620 SENTRY PARKWAY, SUITE 100
BLUE BELL, PENNSYLVANIA 19422 ATTORNEY FOR
(610) 941-3600
BY:
IDENTIFICATION NO.
ATLANTIC MORTGAGE & INVESTMENT
CORPORATION, a division of
ABN AMRO Mortgage Group, Inc
7159 Corklan Drive
Jacksonville, Florida 32258
PLAINTIFF
CUMBERLAND COUNTY
COURT OF COMMON PLEAS
DIVISION
TERM,
V. _
SHANE D. BURGER and No. Q.2 , 91 1 u
SHELLEY LEE LAWRENCE
403 Deerfield Road
Camp Hill, PA 17011
CIVIL ACTION - MORTGAGE FORECLOSURE
COMPLAINT
1. Plaintiff, ATLANTIC MORTGAGE & INVESTMENT CORPORATION, a division of
ABN AMRO Mortgage Group, Inc., is a corporation organized and existing under laws of the State of
Delaware with offices at 7159 Corklan Drive, Jacksonville, Florida.
2. Defendants, SHANE D. BURGER and SHELLEY LEE LAWRENCE, are the mortgagors
and real owners of premises Lot #7 Section 9, 403 Deerfield Road, Township of Lower Allen,
Cumberland County, Pennsylvania, hereinafter described, whose last known address is as stated above.
-1-
3. On the 27`s day of May, 1997, the above named mortgagors made, executed and delivered a
mortgage upon premises hereinafter described to First United Mortgage Services, Inc., which mortgage
is recorded in the Office of the Recorder of Deeds for Cumberland County in Mortgage Book 1385 page
118 and re-recorded in Mortgage Book 1402 page 867.
4. The premises subject to the said mortgage is described in Exhibit "A" attached hereto and
made a part hereof.
5. The mortgage secures defendants' certain Note dated the same as the mortgage in the amount
of $114,622.00 payable in monthly installments with interest at an adjustable rate with an initial rate of
6.5% per annum. A copy of the said Note is attached hereto, made a part hereof and marked Exhibit
«B„
6. The said mortgage was last assigned to ATLANTIC MORTGAGE & INVESTMENT
CORPORATION, a division of ABN AMRO Mortgage Group, Inc., the plaintiff herein, by written
assignment which is being recorded forthwith in the Office of the Recorder of Deeds for Cumberland
County.
7. The mortgage is in default because the defendants have failed to make the payment of the
monthly installment of principal and interest in accordance with the terms of the mortgage for the month
of August 2001, and each month thereafter, up to and including the present time.
8. The following amounts are due on the mortgage:
Principal
Interest at 9.25% per annum from 7/1/01 thru
11/30/01 ($27.79 per diem)
Late charges accrued thru 11/30/01 ($46.03/month)
Escrow deficit (taxes and insurance) ($426.38/month)
Attorney's fee (5%)
Title information certificate
Total
$109,647.21
4,251.87
134.53
1,705.52
5,482.36
325.00
$121,546.49
-2-
9. The said mortgage is not a residential mortgage as defined by Pennsylvania Act No. 6 of
1974, and hence, no notice of intention to foreclose is required by the said Act.
10. The aforesaid mortgage is insured under Title II of the National Housing Act, and therefore,
is not subject to the provisions of Pennsylvania Act No. 91 of 1983.
WHEREFORE, plaintiff demands judgment in the sum of $121,546.49 plus interest, late
charges, escrow advances and costs to the date of judgment and foreclosure of the said mortgage.
-3-
Attorney for Plaintiff
DESCRIPTION
ALL THAT CERTAIN tract or parcel of land and premises, situate, lying and being in the Township
of Lower Allen in the County of Cumberland and Commonwealth of Pennsylvania, more particularly
described as follows:
BEGINNING at a point on the:northeasterly line of Deerfield Road, a 50 foot wide right-of-way, which
said point of beginning is located at-the intersection of the northeasterly line of Deerfield Road and the
dividing line between Lots Nos. 7 and 8 on the Resubdivision Plan of Allendale, Section 9, recorded
in Cumberland County Plan Book "25", Page 133; thence, from said point of beginning along the north
easterly line of Deerfield Road, north 24 degrees 58 minutes 10 seconds west, a distance of 100.00 feet
to a point on the dividing line between Lots Nos. 6 and 7; thence from said point along the dividing line
between Lots Nos. 6 and 7' north 65 degrees, 1 minute 50 seconds east, a distance of 170.03 feet to a
point; thence from said point, south 24 degrees 58 minutes 10 seconds east, a distance of 100.00 feet
to a point on the,dividing line between Lots Nos. 7 and 8; thence from said point along the dividing line
between Lots Nos. 7 and 8, south 65 degrees 1 minute 50 seconds west, a distance of 170.03 feet to
a point, the point and place of beginning.
BEING Lot No. 7 on the Resubdivision Plan of Allendale, Section 9, recorded in the Office of the
Recorder of Deeds of Cumberland County, Pennsylvania, in Plan Book "25", Page 133.
HAVING thereon erected a dwelling house being known and numbered as premises 403 Deerfield Road,
Camp Hill, Pennsylvania.
Map #24-0809 Parcel 010
n
EXHIBIT A
t,Llliif ILL, M) L
1•IIA toe Na.
S1.1" "I `A AND CORRECT COPY
;441-541-0044 i
ry?
AD4, r J r L'
L
MAY 29 .19 97
403 DEERFIELD ROAD, CAMP HILL, PA. 17011
(Propcni, Addrr+nl
1. PARTIES
"Borrower" mans each person signing at the time of this Note, and the person); successors and assigns. `Lender"
means FIRST UNITED MORTGAGE SERVICES, INC.
Q1
and its successors and assigns. O
.2. BORROWER'S I'RONIISE TO PAY; INTEREST
Ir return far a loan received from Lender. Borrower promises to pay the principal sum of
ONE HUNDRED FOURTEEN THOUSAND SIX HUNDRED TWENTY TWO AND 00/100 ?s
Dollars (U.S. f 114,622.00 ), plus interest, to the order of Lender. Interest will be charged on
unpaid principal, from ilia date or disbursement of the loan proceeds by Lender, at a rate of
SIX AND ONE HALF s?
parccnt l 6.50 %) per year. The interest rate may change in accordance with Paragraph 5(C) of this Note.
3. PRUAIISE TO PAY SECURED
Borrower's promise to pay is secured by a mongage, decd or trust or similar security instrument that is dated the same
date as this Note and called the "Security Instrument." That Security Instrument protects the Lender from losses which
might result if Borrower defaults under this Note.
4, NIANNER OF PAYNILN'1'
(A) Thne
Borrower shall make a payment of principal and interest to Lender on the first day of each month beginning on
JULY 1997 . Any principal and interest remaining on the first day of JUNE
'
2027 , will be due on that date, which is called the maturity dale.
(B) Place
Payment shall be made at FIRST UNITED MORTGAGE SERVICES, INC.
4931 CARLISLE PIKE, MECHANICSBURG, PA. 17055
,,
or at such other place. - Lender may designate in writing by notice to Borrower.
(C) Amount
Initially, each monthly paymcn'. -r principal and interest will be in the amount of $ 724.49
This amount will be part of a larlit! monthly payment required by the Security Instrument that shall be applied to principal,
interest and other items in the order described in the Security Instrument. This amount may change in accordance with
Paragraph 5(E) of this Note.
5. INTEREST RATE AND NIONTIILY PAYMENT CHANGES
(A) Change Unit
The interest rate may change on the first day of OCTOBER 1998 , and on that Jay of each succeeding
ycv. "Change Dete" means each date on which the interest rate could change.
(8) The Index
Beginninf with ilia first Change Date, the interest rate will be based on an Index. "Index" means the weekly average
yield on United Staxs Treasury Securities adjusted to a constant maturity of one year, as made-available by the Federal
Reserve Board. "Cunene Index" means the most recent Index figure available 30 days before the Change Date. If the Index
(as dcrined above) is no stinger available, Lender will use as a new Index any index presc:lbed by the Secretary (as defined
in Paragraph 7(13)). Lender will give Burrower notice of the new Index.
(C) Calculation of Interest Rate Changes
Before each Change Date. Lender wi!I calculate a new interest rate by adding a margin of THREE
percentage points ( 3.00 %) to the Current Indcs and rounding the sum to the nearest one-eighth of one percentage
point (0.125%). Subject to ilia limits stated in Paragraph 5(D) of this Note, this rounded amount will be ilia new interest
rate until the next Change Date.
(D) Limits an Interest Rate Changes
The interest rate will never increase or decrease by more than one percentage point (1.0%) on any single Change Date.
71 interest rate will never be more than rive percentage points (5.0'x) higher or lower than the initial interest rate stated in
Paragraph 2 of this Note.
(E) Calculation of Payment Change
it ilia interest rate changes on a Change Date. Lender will calculate the amount of monthly payment or principal and
interest which would be necessary to repay :he unpaid principal balance In full at the maturity dale at the new interest rate
through substantially equal payments. In making such calculation, Lender will use the unpaid principal balance which
would be owed on ilia Chan Date if there had been no default in payment on die Note, reduced by the amount of any
prepayments to principal. The result of this calculation will be the amount of the new monthly payment of principal and
interest.
l? 1
film W WOO
EXHIBIT B sass D sex 816.111.1131
t
?t.
it.) NnUCeul Clwoges
Lender will give notice to Borrowoo'f any change in the t,.,eresi rate and monml; •mcnt The notice must
be given at least 25 days before the new monthly payment amount Is due, and must set orth (1) the date of :he notice, (it)
the Change Date, (iii) the old interest rate, (iv) the new interest rate, (v) the new monthly payment amount, (A) the Current
Index and the date it was published, (vii) the method of calculating the change in monthly payment amount, and (viii) any
other information which may be required by law from time to time.
(G) Errective Dote of Changes
A new interest rate calculated in accordance with Paragraphs S(C) and S(D) of this Note will become effective on the
Change Date: Borrower shall make a payment in the new monthly amount beginning on the first payment date which
occurs at least 25 days after Lender has given Borrower the notice of changes required by Paragraph S(F) of this Note.
Burrower shall have no obligation to pay any increase in the monthly payment amount calculated in accordanse with
Paragraph 5(E) of this Note for any payment date occurring less than 25 days after Lender has given the required notice. If
the monthly payment amount calculated in accordance with Paragraph 5(E) of this Note decreased, but Lender failed to give
tamely notice of the decrease and Borrower made any monthly payment amounts exceeding the payment amount which
should have been stated in a timely notice, then Borrower has the optioi to either (i) demand the return to Borrower of any
excess payment, with interest thereon at the Note rate (a rate equal to the interest rate which should have been stated in a
timely notice), or (ii) request that any excess payment, with interest thereon at the Note rate, be applied as payment of
prince ja! Lender's obligation to return any excess payment with interest on demand is not assignable even if this Note is
othn a.;se assigned before the demand for return is made.
6. BORROWER'S RIGHT TO PREPAY
Borrower has the right to'pay the debt eviuenced by this Note, in whole or in part, without charge or penalty, on the
first day of any month.
7. BORROWER'S FAILURE TO PAY
(A) Late Charge for Overdue Payments
If Lender has not received the full monthly payment •(uired by the Security Instrument, as described in Paragraph
4lC) of this Note, by the end of fifteen calendar days tt 'he r..yment is due. Lender may collect a late charge in the
amount of FOUR
percent( 4.00 %) of the overdue amount of each payment.
(B) Derault
If Porruwer defaults by failing to pay in full any monthly payment, then Lender may, except as limited by regulations
of the Secretary in the case of payment defaults, requite immediate payment in full of the principal balance remaining due
and all accrued interest. Lender may choose not to exercise this option without waiving its rights in the event of any
subsequent default. This Note does not authorize acceleradon when net permitted by HUD regulations. As used in this
Note, "Secretary" means the Secretary of Housing and Urban Development or his or her designee.
(C) Payment or costs and Expenses
If Lender has required immediate payment in full, as described above, Lender may require Borrower to pay costs and
expenses including reasonable and customary attorneys' fees for enforcing this Note. Such fees and costs shall bear interest
from the date of disbursement at the same rate as the principal of this Note.
S. WAIVERS
Borrower rand any other person who has obligations under this Note waive the rights of presentment and notice of
dishonor. "Presentment" means the right to require Lender to demand payment of amounts due. "Notice of dishonor"
means the right to require Lender to give notice to other persons that amounts due have not been paid.
9. GIVING OF NOTICES
Unless applicable law requires a different method, any notice that must be given to Borrower under this Note will be
given by delivering it or by mailing it by rust class mail to Borrower at the property address above or at a different address
if Borrower has given Lender a notice of Borrower's different address.
Any notice that must be given to Lender under this Note will be given by first class mail to Lender at the address
stated in Paragraph 4(B) or at a different address if Borrower is given a notice of that different address.
10. OBLIGATIONS OF PERSONS UNDER THIS NOTE
If more than one person signs this Note, each person Is fully and personally obligated to keep all of the promises made
in this Note, Including the promise to pay the full amount owed. Any Persia i ??Bgu uuyyCe2r endorser or this
Note Is also obligated to do these things. Any person who takes over these 'ob i(Hon=EA%9fkL?ygja ender or a
guarantor, surct; or endorser of this Note, Is alst obligated to keep all of the promise Is Note. Lender may
enfor,e its rights under this Note against each person individually or against all sign together. Any one person
signing this Note may be required to pay all of the amounts owed under dais Note.
BY SIGNING BELOW, Borrower accepts and agrees
Note.
terms and covenants contained in pages 1 and 2 of this
(Seal)
aHAN DAVID BURGER -- Borrower
rY ? L e t 1 i (Seal)
SHELLEY LSE LAliRENCE Borrows
_ (Seal)
Bonower
_ (Seal)
Borrower
(pose 2 of t pages)
PAY TO THE ORDER OF STANDARD FEDERAL BANK itITHOUT RECOURSE
f)Y,,? IRST UNITED MORTGAGE SERVICES, INC.
ROBERT E. MOSS 'PRESIDENT
VERIFICATION
qtr. Edward M. Johns hereby states that he is Assist, Vice President of Atlantic Mortgage &
Investment Corporation mortgage servicing agent in this matter, that he is authorized to take this
Verification, and that the statement made in the foregoing Civil Action Mortgage Foreclosure
Complaint are true and correct to the best of his knowledge, information and belief. The
undersigned understands that this statement is made to the penalties of 18 Pa C. S.A. Sec. 4904
relating to unsworn falsification to authorities.
Edward M. Johns
Vice President
Date: _ 1 2-- p ? 61
Q K
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SHERIFF'S RETURN - NOT FOUND
CASE NO: 2002-00091 P
COMMONWEALTH OF PENNSYLVANIA
COUNTY OF CUMBERLAND
ATLANTIC MORTGAGE & INVESTMENT
VS
BURGER SHANE D 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
LAWRENCE SHELLEY LEE
unable to locate Her in his bailiwick
COMPLAINT - MORT FORE
but was
He therefore returns the
NOT FOUND , as to
the within named DEFENDANT , LAWRENCE SHELLEY LEE
FORWARDING ORDER EXPIRED. BELIEVED TO BE
LIVING IN NEW CUMBERLAND AREA.
Sheriff's Costs:
Docketing 6.00
Service 9.10
Affidavit .00
Surcharge 10.00
nn
L J . 1 V
So answ rs:
OThomas Kline
Sheriff of Cumberland County
THOMAS PULEO
01/10/2002
Sworn and subscribed to before me
this N'rl day o
,1"2. A.D.
Pr thonotary
SHERIFF'S RETURN - REGULAR
CASE NO: 2002-00091 P
COMMONWEALTH OF PENNSYLVANIA:
COUNTY OF CUMBERLAND
ATLANTIC MORTGAGE & INVESTMENT
VS
BURGER SHANE D ET AL
GERALD WORTHINGTON
Cumberland County,Pennsylvania, who being duly sworn according to law,
says, the within COMPLAINT - MORT FORE
BURGER SHANE D
was served upon
the
DEFENDANT , at 1022:00 HOURS, on the 8th day of January , 2002
at 403 DEERFIELD ROAD
CAMP HILL, PA 17011
SHANE D. BURGER
by handing to
a true and attested copy of COMPLAINT - MORT FORE
together with
and at the same time directing His attention to the contents thereof.
Sheriff's Costs:
Docketing 18.00
Service 9.10
Affidavit .00
Surcharge 10.00
.00
37.10
Sworn and Subscribed to before
me this rL{!!?- day of
Zoo A. D.
,Prothonotary
, Sheriff or Deputy Sheriff of
So ?Anys/wers :
R. Thomas Kline
7
01/10/2002
THOMAS PULEO
By
Deputy eriff
THOMAS I. PULED, ESQUIRE
Identification No. 27615
620 Sentry Parkway, , Suite 100
O?
Blue Bell, PA 19422
(610) 941-3600 Attorney for Plaintiff
IN THE COURT OF COMMON PLEAS OF CUMBERLAND COUNTY, PENNSYLVANIA
CIVIL ACTION - LAW
ATLANTIC MORTGAGE & INVESTMENT
CORPORATION
No. 02-91 Civil Term
V.
SHANE D. BURGER and
SHELLEY LEE LAWRENCE
PRAECIPE TO REINSTATE COMPLAINT
TO THE PROTHONOTARY:
Kindly reinstate the Complaint in the above captioned matter for service upon defendants.
Attorney for Plaintiff
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THOMAS I. PULEO
IDENTIFICATION NO. 27615
620 Sentry Parkway, Suite 100
BLUE BELL. PENNSYLVANIA 19422 ATTORNEY FOR
610) 941-3600 PLAINTIFF
ATLANTIC MORTGAGE & INVESTMENT COURTHCZJAfMOWLEAS
DIVISION
CORPORATION, a division of
ABN AMRO Mortgage Group, Inc
7159 Corklan Drive TEKhI.
Jacksonville, Florida 32258
V. n
SHANE D. BURGER and No. Q dI - 9l l? j Uy l T
SHELLEY LEE LAWRENCE
403 Deerfield Road
Camp Hill, PA 17011
CIVIL ACTION - MORTGAGE FORECLOSURE
COMPLAINT
"NOTICE
'You have been sued in court. II you wish to defend aga'.nst the
claims sot forth in the fogowing pages, you must take action within twenty
(2o) days after this complaint and notice are served. by entering a written
appoarante pa. sonally or by attorney and Ning in wiling with the court
your defenses or objections to the claims set forth against you. You are
womad that it you fol to do so the case may proceed without yrou and a
judgment may be entered against you by the court without fu Mar notice for
any money claimed in the complaint or for any other claim or relioI
requested by the plaintiff. You may lose money or proPerty or or righa
important to you.
'YOU SHOULD TAKE THIS PAPER TO YOUR LAWYER AT ONCE.
IF YOU DO NOT HAVE A LAWYER OR CANNOT AFFORD ON . GO TO
OR TELEPHONE THE OFFICE SET FORTH BELOW TO FIND OUT
WHERE YOU CAN GET LEGAL HELP.
Court Administrator
4th Floor, Cumberland County Courthouse
Carlisle, PA 17013
(717) 240-6200
"AVISO
'Lo hon demandado a usted an Is torte. Si usled quiere defenders
do esas demandas expuesas on [as pAginas siguientes, us!ad Gone vt'n!z
(20) dias. de pazo al parer de to fecha do la demands y is no6ticat:6n.
Hate rata asenar una comparencia escria o an persona o con un
abogado y entregar a la torte an forma escria sus defenses o sus
objecionos a las demandas on contra de su persona. Sea avisado qve si
usted no se defienda. Is tor-.o lornarA medidas y puede con;nuar Is
demanda an contra suys sin previo oviso o notification. AdemAs. Is Marte
puede docidir a favor dol demandante y requiare qua usted cumpla con
sodas las provisionos do asa demands. Usted puede perder dinoro o sus
propfedades u otros derechos importances Para usted.
'LLEVE ESTA DEMANOA A UN ABOGADO INMEDIATMAENTE. S!
NO TIENE ABOGADO O St NO TIENE EL OINERO SUFICIENTE DE
PAGAR TAL SERVICIO. VAYA EN PERSONA O LUVAE FOR TELAFONO
PARA AVERIGUAK UOINUE Se f`UEUc LQN$EUUht ASS i e;.?u.
LEGAL.
Court Administrator
4th Floor, Ctimiberlarld County Courthouse
Carlisle, PA 17013
(717) 240-6200
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SHERIFF'S RETURN - REGULAR
CASE NO: 2002-00091 P
COMMONWEALTH OF PENNSYLVANIA:
COUNTY OF CUMBERLAND
ATLANTIC MORTGAGE & INVESTMENT
VS
BURGER SHANE D ET AL
RICHARD SMITH , Sheriff or Deputy Sheriff of
Cumberland County,Pennsylvania, who being duly sworn according to law,
says, the within COMPLAINT - MORT FORE was served upon
LAWRENCE SHELLEY LEE the
DEFENDANT , at 1740:00 HOURS, on the 8th day of February , 2002
at 142 15TH STREET UNIT R
NEW CUMBERLAND, PA 17070
SHELLEY LAWRENCE
by handing to
a true and attested copy of COMPLAINT - MORT FORE together with
and at the same time directing Her attention to the contents thereof.
Sheriff's Costs:
Docketing 18.00
Service 11.73
Affidavit .00
Surcharge 10.00
.00
39.73
Sworn and Subscribed to before
me this JJ6- day of
ZDb,L A.D.
ro notary
So Answers:
R. Thomas Kline
02/12/2002
THOMAS PULEO
By:
4eu tySheriff
LAW OFFICE OF PULEO & D'EMILIO, LLC
By: Thomas I. Puleo, Esquire -
Identification No. 27615
660 Sentry Parkway, Suite 210
Blue Bell, PA 19422
(610) 941-3600 Attorney for Plaintiff
IN THE COURT OF COMMON PLEAS OF CUMBERLAND COUNTY, PENNSYLVANIA
CIVIL ACTION - LAW
ATLANTIC MORTGAGE & INVESTMENT
CORPORATION
V.
SHANE D. BURGER and
SHELLEY LEE LAWRENCE
No. 2002-91 Civil Term
PRAECIPE FOR JUDGMENT
Enter judgment in favor of the Plaintiff and against the Defendant(s) for want of an answer and
assess damages as follows:
Principal Debt
Interest from 7/1/01 through 3/15/02 $109,647.21
Late charges accrued through 3/15/02 7,169.82
Escrow deficit 272.62
Attorney fees 3,411.04
Title information certificate 5,482.36
325.00
Total $126,308.05
I CERTIFY THAT THE FOREGOING ASSESSMENT OF DAMAGES IS FOR SPECIFIED
AMOUNTS ALLEGED TO BE DUE IN THE COMPLAINT AND IS CALCULABLE AS A SUM
CERTAIN FROM THE COMPLAINT.
1 certify that written notice of the intention to file this Praecipe was mailed or delivered to the
party against whom judgment is to be entered and to his attorney of record, if any, after the default
occurred and at least ten days prior to the date of the filing is praecipe. A cop f the notice is
attached. Pa.R.C.P.237.1
9HOMAS I. PU O, ESQUIRE
Attorney for Plaintiff
AND NOW 2002, Judgment is entered in favor of plaintiff and against
defendants and damages assessed as per the above certification.
Prothonotary
LAW OFFICE OF PULEO & D'EMILIO, LLC
By: Thomas I. Puleo, Esquire
Identification No. 27615
660 Sentry Parkway, Suite 210
Blue Bell, PA 19422
(610) 941-3600 Attorney for Plaintiff
IN THE COURT OF COMMON PLEAS OF CUMBERLAND COUNTY, PENNSYLVANIA
CIVIL ACTION - LAW
ATLANTIC MORTGAGE & INVESTMENT
CORPORATION
V.
SHANE D. BURGER and
SHELLEY LEE LAWRENCE
To: Ms. Shelley Lee Lawrence
142 151h Street
New Cumberland, PA 17070
Date of Notice: March 2, 2002
No. 2002-91 Civil Term
NOTICE OF INTENTION TO FILE PRAECIPE
FOR ENTRY OF
DEFAULT JUDGMENT UNDER Pa.R.C.P.237.1
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 AND 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:
COURT ADMINISTRATOR
4th Floor, Cumberland County Courthouse
Carlisle, PA 17013
(717) 240-6200
r
THOMAS I. PULE
Attorney for Plaintiff
LAW OFFICE OF PULEO & D'EMILIO, LLC
By: Thomas I. Puleo, Esquire
Identification No. 27615
660 Sentry Parkway, Suite 210
Blue Bell, PA 19422
(610) 941-3600 Attorney for Plaintiff
IN THE COURT OF COMMON PLEAS OF CUMBERLAND COUNTY, PENNSYLVANIA
CIVIL ACTION - LAW
ATLANTIC MORTGAGE & INVESTMENT
CORPORATION
V.
SHANE D. BURGER and
SHELLEY LEE LAWRENCE
To: Mr. Shane D. Burger
403 Deerfield Road
Camphill, PA 17011
Date of Notice: March 2, 2002
: No. 2002-91 Civil Term
NOTICE OF INTENTION TO FILE PRAECIPE
FOR ENTRY OF
DEFAULT JUDGMENT UNDER Pa.R.C.P.237.1
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 AND 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:
COURT ADMINISTRATOR
4th Floor, Cumberland County Courthouse
Carlisle, PA 17013
(717) 240-6200
T OMAS I. P EO
Attorney for Plaintiff
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LAW OFFICE OF PULEO & D'EMILIO, LLC
By: Thomas I. Puleo, Esquire
Identification No. 27615
660 Sentry Parkway, Suite 210
Blue Bell, PA 19422
(610) 941-3600 Attorney for Plaintiff
IN THE COURT OF COMMON PLEAS OF CUMBERLAND COUNTY, PENNSYLVANIA
CIVIL ACTION - LAW
ATLANTIC MORTGAGE & INVESTMENT
CORPORATION
No. 2002-91 Civil Term
V.
SHANE D. BURGER and
SHELLEY LEE LAWRENCE
AFFIDAVIT OF NON-MILITARY SERVICE
COMMONWEALTH OF PENNSYLVANIA
COUNTY OF MONTGOMERY SS.
THOMAS I. PULEO, being duly sworn according to law deposes and says that the defendant(s)
is/are not in the Military or Naval Service of the United States or its Allies, or otherwise within the
provisions of the Soldiers' and Sailors' Civil Relief Act of Congress of 1940, as amended;
That Shane D. Burger is over 21 years of age, resides at 403 Deerfield Road, Camphill,
Pennsylvania, and is employed by/as unknown.
Y
OMAS I. P ED
Attorney for Plaintiff
SWORN TO AND SUBSCRIBED
BEFORE ME THIS 13th DAY
OF
'ARY PUB IC LISA A O !IAL SEAL
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COMMONWEALTH OF PENNSYLVANIA
COUNTY OF CUMBERLAND
ATLANTIC MORTGAGE & INVESTMENT COURT OF COMMON PLEAS
CORPORATION,
Plaintiff,
NO. 2002-91 Civil Term
V.
SHANE D. BURGER and
SHELLEY LEE LAWRENCE,
Defendant(s).
PRAECIPE FOR WRIT OF EXECUTION
TO THE PROTHONOTARY:
Issue Writ of Execution in the above matter:
AMOUNT DUE
INTEREST FROM
March 15, 2002
$126,308.05
$ 4,807.67
COSTS TO BE ADDED
March 13, 2002
TH AS I. PUL O, ESQUIRE
Attorney for Plaintiff
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" DESCRIPTION
ALL THAT CERTAIN tract or parcel of land and premises, situate, lying and being in the Township
of Lower Allen in the County of Cumberland and Commonwealth of Pennsylvania, more particularly
described as follows:
BEGINNING at a point on the northeasterly line of Deerfield Road, a 50 foot wide right-of-way, which
said point of beginning is located at the intersection of the northeasterly line of Deerfield Road and the
dividing line between Lots Nos. 7 and 8 on the Resubdivision Plan of Allendale, Section 9, recorded
in Cumberland County Plan Book "25", Page 133; thence, from said
easterly line of Deerfield Road, north 24 degrees 58 minutes 10 secondpoint of s w st,l a d?ce of pp pp fee
to a point on the dividing line between Lots Nos. 6 and 7; thence from said point along the dividing line
between Lots Nos. 6 and 7 north 65 degrees, 1 minute 50 seconds east, a distance of 170.03 feet to a
point; thence from said point, south 24 degrees 58 minutes 10 seconds east, a distance of 100.00 feet
to a point on the dividing line between Lots Nos. 7 and 8; thence from said point along the dividing line
between Lots Nos. 7 and 8, south 65 degrees 1 minute 50 seconds west, a distance of 170.03 feet to
a point, the point and place of beginning.
BEING Lot No. 7 on the Resubdivision Plan of Allendale, Section 9, recorded in the Office of the
Recorder of Deeds of Cumberland County, Pennsylvania, in Plan Book "25", Page 133.
HAVING thereon erected a dwelling house being known and numbered as premises 403 Deerfield Road,
Camp Hill, Pennsylvania.
Map #24-0809 Parcel 010
LAW OFFICES OF PULEO & D'EMILIO
660 Sentry Parkway, Suite 210
Blue Bell, PA 19422
(610) 941-3600
By: Thomas I. Puleo, Esquire
Identification No. 27615 Attorney for PLAINTIFF
IN THE COURT OF COMMON PLEAS OF CUMBERLAND COUNTY, PENNSYLVANIA
CIVIL ACTION - LAW
ATLANTIC MORTGAGE & INVESTMENT
CORPORATION,
Plaintiff
NO. 2002-91 Civil Term
V.
SHANE D. BURGER and
SHELLEY LEE LAWRENCE,
Defendant
AFFIDAVIT UNDER PA. RCP RULE 3129
THOMAS I. PULEO, attorney for Plaintiff in the above captioned mortgage foreclosure
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 403 Deerfield Road, Camp Hill, Cumberland
County, Pennsylvania, was true and correct to the best of its knowledge, information and belief.
Name and address of each Owner and/or Reputed Owner:
Shane D. Burger Shelley Lee Lawrence
403 Deerfield Road 142 15' Street
Camp Hill, PA 17011 New Cumberland, PA 17070
2. Name and address of each Defendant named in the judgment:
Shane D. Burger Shelley Lee Lawrence
403 Deerfield Road 142 15`h Street
Camp Hill, PA 17011 New Cumberland, PA 17070
3. Name and last known address of every judgment creditor whose judgment is a record lien
on the real property to be sold:
None
4. Name and address of the last recorded holder of every mortgage of record:
Atlantic Mortgage & Investment Corporation, Plaintiff
7159 Corklan Drive
Jacksonville, FL 32258
Barry A. Richmond Beneficial CDC d/b/a
237 Gravel Hill Road Beneficial Mtg. Co. of PA
Palmyra, PA 17036 P. O. Box 4499
Harrisburg, PA 17111
5. Name and address of every other person or entity which has any record lien on the
property:
None
6. Name and address of every other person or entity which has any record interest in the
property and whose interest may be affected by the sale:
Cumberland County Domestic Relations Commonwealth of PA
13 N. Hanover Street Department of Public Welfare
Carlisle, PA 17013 P. O. Box 2675
Harrisburg, PA 17105
7. Name and address of every other person of whom the Plaintiff has knowledge who may
have an interest in the property which may be affected by the sale:
None
I verify that the statements made in this Affidavit are true and correct to the best of my
personal knowledge, information and belief. I understand that false statements herein are made
subject to the penalties of 18 Pa.C.S. Section 4904 relating to unworn falsification to authorities.
Date: March 13, 2002
S I. PUPO, ESQUIRE
for Plaintiff
LAW OFFICES OF PULEO & D'EMILIO
660 Sentry Parkway, Suite 210
Blue Bell, PA 19422
(610) 941-3600
By: Thomas I. Puleo, Esquire
Identification No. 27615 Attorney for PLAINTIFF
IN THE COURT OF COMMON PLEAS OF CUMBERLAND COUNTY, PENNSYLVANIA
CIVIL ACTION - LAW
ATLANTIC MORTGAGE & INVESTMENT
CORPORATION,
Plaintiff
V.
NO. 2002-91 Civil Term
SHANE D. BURGER and
SHELLEY LEE LAWRENCE,
Defendant
NOTICE OF SHERIFF'S SALE OF REAL PROPERTY
TO: Shane D. Burger
403 Deerfield Road
Camp Hill, PA 17011
Shelley Lee Lawrence
142 159i Street
New Cumberland, PA 17070
Your house at 403 Deerfield Road, City of Camp Hill, Cumberland County, is scheduled
to be sold by the Cumberland County Sheriffs Department to enforce the Court judgment of
$126,308.05 obtained by Plaintiff Atlantic Mortgage & Investment Corporation against you.
The Sheriffs Sale will be conducted on Wednesday, September 4, 2002, at 10:00 A.M.,
Cumberland County Courthouse, 2nd Floor, Commissioner's Hearing Room, Carlisle,
Pennsylvania.
NOTICE OF OWNERS' RIGHTS
YOU MAY BE ABLE TO PREVENT THIS SHERIFF'S SALE
To prevent this Sheriffs Sale, you must take immediate action:
This sale will be canceled if you pay to Atlantic Mortgage & Investment
Corporation the back payments, late charges, costs and reasonable attorneys' fees
due. To find out how much you must pay, you may call (610) 941-3600.
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 below 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
If the Sheriff s Sale is not stopped, your property will be sold to the highest bidder.
You may find out the price bid by calling the Cumberland County Sheriffs
Department at (717) 240-6390.
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.
The sale will go through only if the buyer pays the Sheriff the full amount bid in
the sale. To find out if this has happened, you may call the Cumberland County
Sheriffs Department at (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 had never happened.
5. You have the right to remain in the property until the full amount due is paid to
the Sheriff and the Sheriff gives a deed to the buyer. At that time, the buyer may
bring legal proceedings to evict you.
6. You may be entitled to a share of the money which was paid for your house. A
schedule of distribution of the money bid for your house will be filed by the
Cumberland County Sheriff on or about thirty (30) days from the date of Sheriffs
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 sheet 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
BELOW TO FIND OUT WHERE YOU CAN GET LEGAL HELP.
Court Administrator
4th Floor, Cumberland County Courthouse
Carlisle, PA 17013
(717) 240-6200
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LAW OFFICES OF PULED & D'EMILIO
660 Sentry Parkway, Suite 210
Blue Bell, PA 19422
(610) 941-3600
By: Thomas I. Puleo, Esquire
Identification No. 27615
Attorney for PLAINTIFF
IN THE COURT OF COMMON PLEAS OF CUMBERLAND COUNTY, PENNSYLVANIA
CIVIL ACTION - LAW
ATLANTIC MORTGAGE & INVESTMENT
CORPORATION,
Plaintiff
NO. 2002-91 Civil Term
V.
SHANE D. BURGER and
SHELLEY LEE LAWRENCE,
Defendant
NOTICE OF SHERIFF'S SALE OF REAL PROPERTY
TO: Shane D. Burger Shelley Lee Lawrence
403 Deerfield Road 142 151" Street
Camp Hill, PA 17011 New Cumberland, PA 17070
Your house at 403 Deerfield Road, City of Camp Hill, Cumberland County, is scheduled
to be sold by the Cumberland County Sheriffs Department to enforce the Court judgment of
$126,308.05 obtained by Plaintiff Atlantic Mortgage & Investment Corporation against you.
The Sheriffs Sale will be conducted on Wednesday, September 4, 2002, at 10:00 A.M.,
Cumberland County Courthouse, 2nd Floor, Commissioner's Hearing Room, Carlisle,
Pennsylvania.
NOTICE OF OWNERS' RIGHTS
YOU MAY BE ABLE TO PREVENT THIS SHERIFF'S SALE
To prevent this Sheriffs Sale, you must take immediate action:
1. This sale will be canceled if you pay to Atlantic Mortgage & Investment
Corporation the back payments, late charges, costs and reasonable attorneys' fees
due. To find out how much you must pay, you may call (610) 941-3600.
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.
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 below on how to obtain an attorney).
)LOU MAY STILL BE ABLE TO SAVE YOUR PROPERTY AND
YOU HAVE OTHER RIGHTS EVEN IF THE SHERIFF'S SALE DOES TAKE PLACE.
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 the Cumberland County Sheriffs
Department at (717) 240-6390.
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 bid in
the sale. To find out if this has happened, you may call the Cumberland County
Sheriffs Department at (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 had never happened.
5. You have the right to remain in the property until the full amount due is paid to
the Sheriff and the Sheriff gives a deed to the buyer. At that time, the buyer may
bring legal proceedings to evict you.
6. You may be entitled to a share of the money which was paid for your house. A
schedule of distribution of the money bid for your house will be filed by the
Cumberland County Sheriff on or about thirty (30) days from the date of Sheriffs
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 sheet 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
BELOW TO FIND OUT WHERE YOU CAN GET LEGAL HELP.
Court Administrator
4th Floor, Cumberland County Courthouse
Carlisle, PA 17013
(717) 240-6200
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Law Offices
PULEO & D'EMILIO, LLC
660 SENTRY PARKWAY, SUITE 210
BLUE BELL, PENNSYLVANIA 19422
(610) 941-3600
FAX (610) 941-5487
Thomas 1. Puleo
Paul F. D'Ermho
April 2, 2002
Ms. Pat Shatto
Real Estate Deputy
Office of the Sheriff
Cumberland County
Carlisle, PA 17013
Re: Atlantic Mortgage & Investment Corporation v. Shane D. Burger and Shelley Lee
Lawrence
No. 2002-q1 Civil Term
Dear Ms. Shatto:
Kindly stay the sheriff's sale in the above matter which is scheduled for September 4,
2002, as the mortgagor, Shane D. Burger, has filed a Chapter 13 Petition with the United States
Bankruptcy Court on January 29, 2002, being No. 02-00443RJW. A copy of the bankruptcy
notice is enclosed herewith. Please refund any deposit moneys on hand.
Thank you for your prompt attention to this matter.
Veryy yours,
t ?F !
THOMAS I' PULED
TIP:dm
FAX and First Class Mail
FC)RM R4!• fC;hnntar 1.q C aRP.1(9/A71
Al I C:
Case Number 02-00443RJW-1
UNITEI} STATES BANKRUPTCY COURT
MIDDLE DISTRICTOI PENNSYLVANIA
Notice of Chapter '3 Bankruptcy Case, Meeting of Creditors, & Deadlines
The debtor(s) listed below filed a chapter 13 bankruptcy case on January 29, 2002_
You may be a creditor of the debtor. This notice lists important deadlines. You may want to consult an attorney to protect your
rights. All documents filed in the case may be inspected at the bankruptcy clerk's office at the address listed below. NOTE: The
staff of the bankruptcy clerk's office cannot give legal advice.
See Reverse Side For Important Explanations.
Debtor(s) (name(s) and address):
BURGER, SHANE D
403 I)EhRFIELD DRIVE
CAMP HILL, PA 17011
Case Number: Social Security/Taxpayer ID Nos.:
02 -00443RJW- I 193-56-1099
Attorney for Debtor(s) (name and address): Bankruptcy Trustee (name and address):
kl-:NNETH A. WISE CHARLES J. DEHART, III
126 LOCUST ST., P.O. BOX 11489 P.O. BOX 410
HARRISBURG. PA 17108 HUNTMELSTOWN, PA 17036
Telephone number: (717) 238-3838 Telephone number: (717) 566-6097
Meeting o Creditors:
Effective February 1, 2002, all individual debtors must provide picture identification and proof of social security number to
the trustee at the meeting of creditors.
Date: April 18, 2002 Time: 12:00 P.M.
Location: Federal Bldg, Trustee Hearing Km, Rm 1160, 11th F1,228 Walnut St, Harrisburg,PA
Deadlines:
Papers must he received by the bankruptcy clerk's office by the following deadlines:
Deadline to File a Proof of Claim:
PROOF OF CLAIM FORM IS INCLUDED
All creditors who file proof of claim MUST serve a true copy of said claim
upon the Chapter 13 Trustee CHARLES .1. DEHART, III at the above address
For all creditors (except a governmental unit): July 17, 2002 For a governmental unit: July 29, 2002
Deadline to Object to Exemptions:
Thirty (30) days after the conclusion of the meeting of creditors
Filing of Plan, Hearing on Confirmation of Plan
OBJECTIONS TO THE PLAN. Objections to the plan must be filed within fifteen (15) days after the §341 (a) meeting has been
held. A copy of the proposed plan (or summary) is included. Any objections filed to the plan that are not settled will be set for
hearing. If no objections are filed , the court may enter an order confirming plan.
Creditors May Not T'ake' Certain Actions.
The filing of the bankruptcy case automatically stays certain collection and other actions against the debtor, debtor's property, and
certain codebtors. If you attempt to collect a debt or take other action in violation of the Bankruptcy Code, you may be penalized.
Address of the Bankruptcy Clerk's Office: For the Court'
228 WALNUT STREET Clerk of the Bankruptcy Court:
P.O. BOX 908 Arlene Byers
HARRISBURG, PA 17108-0908
Hours Open: Date:
8:00 a.m. - 5:00 p.m. - March 12, 2002
006234
VCWM AYE) (()frial Fnrm 1044101)
UNITED STATES BANKRUPTCY COURT PROOF CAF CLAIM
MIDIXY DISTRICT OF PFNNSYI.VANIA
Name of Debtor Case Number
BURGER, SHANE D 02-00443RJW-1
NOTE: This forth should tzar be w is ke aM&hn for an admsaiArative exok axis after,
the commencement of the eaiiie. A "requ"t" fnr `payment of a n administrative expense may be filed
pursuant to 11 u.S.C. §503' II
'
II II
ll
III II ?I VIII I I ?I ( I
I
Name of Clcdttor (The person or other entity to whom the debtor ? Check box if you are aware that I
'
':
'
owes money or property): anyone else has filed a proof of 02-0043RIW-1
THOy1AS 1 PULF'o ESQ claim relating to your claim. Attach
Name and Address where notices should be sent: copy of statement giving particulars. 'II,'I I I?I'
I III I,I
I
? Check box if you have never I
':
y
THOMAS I PULEO ESQ received any notices from. the
620 SENTRY PARKWAY SUITE 100 bankruptcy court in this case.
B1,t I: BELL, PA 19322 ? Check box if the address differs THIS SPACE: ,S FOR CoLRT USE ONILY
from the address on the envelope
sent to you by the court.
Telephone Number:
Account or other number by which creditor identifies debtor:
t Check here if replaces
this claim ? amends a previously filed claim, dated
1. Basis for Claim ? Retiree benefits as defined in 11 U.S.C. § i 114(a)
? Goods sold ? Wages, salaries, and compensation (fill out below)
? Services performed Your SS #: _
? Money loaned Unpaid compensation for services performed
? Personal injury/wrongful death from to _
? Taxes (date) (date)
? Other
2. Date debt was incurred: 3. If court judgment, date obtained:
4. Total Amount of Claim at Time Case Filed: $
If all or part of your claim is secured or entitled to priority, also complete Item 5 or 6 below.
? Check this box if claim includes interest or other charges in addition to the principal amount of the claim. Attach itemized statement of all
interest or additional charges.
5, Secured Claim. 6. Unsecured Priority Claim.
? Check this box if your claim is secured by collateral ? Check this box if you have an unsecured priority claim
(including a right of setoff). Amount entitled to priority $
Brief Description of Collateral: Specify the priority of the claim:
? Real Estate ? Motor Vehicle ? Wages, salaries, or commissions (up to $4,650),* earned within 90 days
? Other before filing of the bankruptcy petition or cessation of the debtor's
business, whichever is earlier - 11 U.S.C. § 507(x)(3).
Value of Collateral: $ ? Contributions to an employee benefit plan - I I U.S.C. §507(a)(4).
? Up to S 2,100* o!-deposits toward purchase, lease, or rental of property or
services for personal, family, or household use - I I U.S.C. § 507(a)(6).
? Alimony, maintenance, or support owed to a spouse, former spouse, or
child - l I U.S.C. § 507(x)(7).
Amount of an-earage and other charges at time case filed ? Taxes or penalties owed to governmental units - I 1 U.S.C. § 507(a)(8).
included in secured claim, if any: S ? Other - Specify applicable paragraph of I 1 U.S.C. § 507(a)(_).
*Amoutus are subject to adjustment on 411104 and even, 3 years thereafter
with respect to cases commenced on or after the date of adjustment.
17. Credits: The amount of all payments on this claim has been credited and deducted for the purpose of 'IMS SPACE IS FOR COURT USE UNL?
making this proof of claim.
8. Supporting Documents: Attach copies of supporting documents, such as promissory notes, purchase
orders, invoices, itemized statements of running accounts, contracts, court judgments, mortgages, security
agreements, and evidence of perfection of lien. DO NOT SEND ORIGINAL. DOCUMENTS. If the
documents are not available, explain. If the documents are voluminous, attach a summary.
9. Date-Stamped Copy: To receive an acknowledgment of the filing of your claim, enclose a stamped, self-
addressed envelope and copy of this proof of claim.
Date Sign and print the name and title, if any, of the creditor or other person authorized to file
this claim (attach copy of power of attorney, if any):
Penalty for presenting fraudulent claim: Fine of up to $500,000 or imprisonment for up to 5 years, or both. 18 U.S.C. §§ 152 and 3571.
00623-1
1-02-00443
IN THE UNITED STATES BANKRUPTCY COURT
FOR THE MIDDLE DISTRICT OF PENNSYLVANIA -
In Re: SHANE BURGER Case No. 1-02-00443
Debtor
Chapter 13 1
CHAPTER 13 PLAN
PLAN SUMMARY:
CLASS 1: Administrative claims, priority claims and taxes - 100% in Plan
CLASS 2: Claims Secured by Personal Residence - (Atlantic Mortgage and
Beneficial) Avoid all judicial liens interfering with exemptions -
Mortgage arrearages only to be paid in Plan. Mortgage liens to be
retained, regular post-petition payments to be made outside Plan
until the obligations are paid in full.
CLASS 3: All Other Secured Claims -
a) AffFirst - Toyota to be sold and lien secured by Toyota to be
paid off in full.
b)Peavey - Stock to be secured and sold at retail in reopened
business. Secured portion to be paid in plan. Where Debtor has
"crammed down" secured creditor's claim and has paid off the
secured portion of the claim in this Plan, the Debtor will receive
the title to the property free and clear of the creditor's lien,
notwithstanding that the Debtor has not completed the payment of
unsecured claims under the Plan. If stock, which was with Mr.
Marnickes, is not available, Peavey will be treated as unsecured.
CLASS 4: Allowed Unsecured Claims - Zero percentage of claims paid
through Plan
CLASS 5: Post-Petition claims allowed under Section 1305 -- Paid through
Plan
Amount & Duration: $350.00 for 48 months, beginning May 1, 2002, or up to 60
months if necessary to pay allowed claims.
Total of S 16,800.00, depending on allowed proofs of claim filed. No interest is to _
be provided to any creditor on any claim in any class unless specifically provided herein
and supported by an allowed proof of claim. Claims not filed by bar date are barred
and will not be included for distribution in this plan. Creditors holding security
other than consensual mortgage liens who fail to file a timely proof of claim shall
release and cancel said lien of record upon discharge of the debtor(s).
- U
006234
WRIT OF EXECUTION and/or ATTACHMENT
COMMONWEALTH OF PENNSYLVANIA)
COUNTY OF CUMBERLAND)
NO 02-91 Civil
CIVIL ACTION - LAW
TO THE SHERIFF OF CUMBERLAND COUNTY:
To satisfy the debt, interest and costs due ATLANTIC MORTGAGE & INVESTMENT
CORPORATION, Plaintiff (s)
From SHANE D. BURGER, 403 DEERFIELD ROAD, CAMP HILL, PA 17011 AND SHELLEY
LEE LAWRENCE, 142 15TH STREET, NEW CUMBERLAND, PA 17070
(1) You are directed to levy upon the property of the defendant (s)and to sell SEE LEGAL
DESCRIPTION.
(2) You are also directed to attach the property of the defendant(s) not levied upon in the possession
of
GARNISHEE(S) as follows:
and to notify the garnishee(s) that: (a) an attachment has been issued; (b) the garnishee(s) is enjoined from
paying any debt to or for the account of the defendant (s) and from delivering any property of the defendant
(s) or otherwise disposing thereof;
(3) If property of the defendant(s) not levied upon an subject to attachment is found in the possession
of anyone other than a named garnishee, you are directed to notify him/her that he/she has been added as a
garnishee and is enjoined as above stated.
Amount Due $126,308.05
Interest FROM MARCH 15, 2002 - $4,807.67
Atty's Comm %
Atty Paid $173.93
Plaintiff Paid
Date: MARCH 18, 2002
REQUESTING PARTY:
L.L. $.50
Due Prothy $1.00
Other Costs
CURTIS R. LONG
Prothonotary, Civil Division
Name THOMAS I. PULEO, ESQUIRE
Address: 660 SENTRY PARKWAY, SUITE 210
BLUE BELL, PA 19422
Attorney for: PLAINTIFF
Telephone: 610-941-3600
Supreme Court ID No. 27615
LAW OFFICES OF
PULEO 8Z D'EMILIO, LLC
620 SENTRY PARKWAY
Suite 100
Blue Bell, PA 19422
(610) 941-3600
FAX (610) 941-5487
TO: Sheriff of Cumberland County
FROM: Thomas I. Puleo, Esquire
DATE: March 13, 2002
RE: ATLANTIC MORTGAGE & INVESTMENT CORPORATION v.
SHANE D. BURGER and SHELLEY LEE LAWRENCE
Cumberland County Court of Common Pleas No. 2002-91 Civil Term
MEMORANDUM
Kindly effect personal service of the Notice of Sheriffs Sale and Writ of Execution upon the
Defendant(s), SHANE D. BURGER, personally, or in the event you are unable to effect personal
service, then upon the person in charge of his residence, situated at
403 Deerfield Road
Camp Hill
Cumberland County, PA 17011
LAW OFFICES OF PULEO & D'EMILIO
660 Sentry Parkway, Suite 210
Blue Bell, PA 19422
(610) 941-3600
By: Thomas I. Puleo, Esquire
Identification No. 27615
IN THE COURT OF COMMON PLEAS OF
Attorney for PLAINTIFF
CUMBERLAND COUNTY, PENNSYLVANIA
CIVIL ACTION - LAW
ATLANTIC MORTGAGE & INVESTMENT
CORPORATION,
Plaintiff
V.
SHANE D. BURGER and
SHELLEY LEE LAWRENCE,
Defendant
NO. 2002-91 Civil Term
AFFIDAVIT UNDER PA. RCP RULE 3129
THOMAS I. PULED, attorney for Plaintiff in the above captioned mortgage foreclosure
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 403 Deerfield Road, Camp Hill, Cumberland
County, Pennsylvania, was true and correct to the best of its knowledge, information and belief
Name and address of each Owner and/or Reputed Owner:
Shane D. Burger Shelley Lee Lawrence
403 Deerfield Road 142 15' Street
Camp Hill, PA 17011 New Cumberland, PA 17070
2. Name and address of each Defendant named in the judgment:
Shane D. Burger Shelley Lee Lawrence
403 Deerfield Road 142 15`h Street
Camp Hill, PA 17011 New Cumberland, PA 17070
3. Name and last known address of every judgment creditor whose judgment is a record lien
on the real property to be sold:
None
,
F
Name and address of the last recorded holder of every mortgage of record:
4
Atlantic Mortgage & Investment Corporation, Plaintiff
7159 Corklan Drive
Jacksonville, FL 32258
Barry A. Richmond
237 Gravel Hill Road
Palmyra, PA 17036
Beneficial CDC d/b/a
Beneficial Mtg. Co. of PA
P. O. Box 4499
Harrisburg, PA 17111
Name and address of every other person or entity which has any record lien on the
property:
5
None
Name and address of every other person or entity which has any record interest in the
property and whose interest may be affected by the sale:
6.
Cumberland County Domestic Relations Commonwealth of PA
13 N. Hanover Street Department of Public Welfare
Carlisle, PA 17013 P. O. Box 2675
Harrisburg, PA 1.7105
Name and address of every other person of whom the Plaintiff has knowledge who may
have an interest in the property which may be affected by the sale:
7.
None
I verify that the statements made in this Affidavit are true and correct to the best of my
personal knowledge, 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.
Date: March 13, 2002
'?MMAS I. PU:?/EO, ESQUIRE
ttorney for Plaintiff
4'
LAW OFFICES OF PULEO & D'EMILIO
660 Sentry Parkway, Suite 210
Blue Bell, PA 19422
(610) 941-3600
By: Thomas I. Puleo, Esquire
Identification No. 27615
Attorney for PLAINTIFF
IN THE COURT OF COMMON PLEAS OF CUMBERLAND COUNTY, PENNSYLVANIA
CIVIL ACTION - LAW
ATLANTIC MORTGAGE & INVESTMENT
CORPORATION,
Plaintiff
NO. 2002-91 Civil Term
V.
SHANE D. BURGER and
SHELLEY LEE LAWRENCE,
Defendant
NOTICE OF SHERIFF'S SALE OF REAL PROPERTY
TO: Shane D. Burger Shelley Lee Lawrence
403 Deerfield Road 142 15'b Street
Camp Hill, PA 17011 New Cumberland, PA 17070
Your house at 403 Deerfield Road, City of Camp Hill, Cumberland County, is scheduled
to be sold by the Cumberland County Sheriff s Department to enforce the Court judgment of
$126,308.05 obtained by Plaintiff Atlantic Mortgage & Investment Corporation against you.
The Sheriffs Sale will be conducted on Wednesday, September 4, 2002, at 10:00 A.M.,
Cumberland County Courthouse, 2nd Floor, Commissioner's Hearing Room, Carlisle,
Pennsylvania.
NOTICE OF OWNERS' RIGHTS
YOU MAY BE ABLE TO PREVENT THIS SHERIFF'S SALE
To prevent this Sheriffs Sale, you must take immediate action:
This sale will be canceled if you pay to Atlantic Mortgage & Investment
Corporation the back payments, late charges, costs and reasonable attorneys' fees
due. To find out how much you must pay, you may call (610) 941-3600.
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 sto 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 below 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 the Cumberland County Sheriffs
Department at (717) 240-6390.
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 bid in
the sale. To find out if this has happened, you may call the Cumberland County
Sheriffs Department at (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 had never happened.
5. You have the right to remain in the property until the full amount due is paid to
the Sheriff and the Sheriff gives a deed to the buyer. At that time, the buyer may
bring legal proceedings to evict you.
6. You may be entitled to a share of the money which was paid for your house. A
schedule of distribution of the money bid for your house will be filed by the
Cumberland County Sheriff on or about thirty (30) days from the date of Sheriffs
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 sheet 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
BELOW TO FIND OUT WHERE YOU CAN GET LEGAL HELP.
Court Administrator
4th Floor, Cumberland County Courthouse
Carlisle, PA 17013
(717) 240-6200
ALL THAT CERTAIN tract or parcel of land and premises, situate, lying and being in the Township
of Lower Allen in the County of Cumberland and Commonwealth of Pennsylvania, more particularly
described as follows:
BEGINNING at a point on the northeasterly line of Deerfield Road, a 50 foot wide right-of-way, which
said point of beginning is located at the intersection of the northeasterly line of Deerfield Road and the
dividing line between Lots Nos. 7 and 8 on the Resubdivision Plan of Allendale, Section 9, recorded
in Cumberland County Plan Book "25", Page 133; thence, from said point of beginning along the north
easterly line of Deerfield Road, north 24 degrees 58 minutes 10 seconds west, a distance of 100.00 feet
to a point on the dividing line between Lots Nos. 6 and 7; thence from said point along the dividing line
between Lots Nos. 6 and 7 north 65 degrees, 1 minute 50 seconds east, a distance of 170.03 feet to a
point; thence from said point, south 24 degrees 58 minutes 10 seconds east, a distance of 100.00 feet
to a point on the dividing line between Lots Nos. 7 and 8; thence from said point along the dividing line
between Lots Nos. 7 and 8, south 65 degrees 1 minute 50 seconds west, a distance of 170.03 feet to
a point, the point and place of beginning.
BEING Lot No. 7 on the Resubdivision Plan of Allendale, Section 9, recorded in the Office of the
Recorder of Deeds of Cumberland County, Pennsylvania, in Plan Book "25", Page 133.
HAVING thereon erected a dwelling house being known and numbered as premises 403 Deerfield Road,
Camp Hill, Pennsylvania.
Map #24-0809 Parcel 010
LAW OFFICES OF PULEO & D'EMILIO, LLC
By: Thomas I. Puleo, Esquire
Identification No. 27615
660 Sentry Parkway, Suite 210
Blue Bell, PA 19422
(610) 941-3600 Attorney for Plaintiff
IN THE COURT OF COMMON PLEAS OF CUMBERLAND COUNTY, PENNSYLVANIA
CIVIL ACTION - LAW
ATLANTIC MORTGAGE & INVESTMENT
CORPORATION, a division of ABN AMRO
Mortgage Group, Inc. No. 02-91 Civil Term
V.
SHANE D. BURGER and
SHELLEY LEE LAWRENCE
PRAECIPE TO VACATE JUDGMENT
Plaintiff, Atlantic Mortgage & Investment Corporation, a division of ABN ANRO Mortgage
Group, Inc., obtained a judgment in mortgage foreclosure against the above named defendants in this
proceeding on March 18, 2002. Prior thereto and without notice to the plaintiff or the Prothonotary, the
defendant, Shane D. Burger, had filed a Chapter 13 Petition under the United States Bankruptcy Code
with the United States Bankruptcy Court for the Middle District of Pennsylvania, Bankruptcy No.
1-02-00443-JJT, on January 29, 2002, thereby staying the within action and thereby rendering the
judgment obtained by plaintiff void. To effectuate the purposes of Section 362 of the United States
Bankruptcy Code, plaintiff directs the Prothonotary to vacate the judgment described above without
prejudice to the continuing validity and lien priority of the mortgage and without prejudice to plaintiff
continuing these proceedings after termination of the
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LAW OFFICES OF PULEO & D'EMILIO, LLC
By: Thomas I. Puleo, Esquire
Identification No. 27615
660 Sentry Parkway, Suite 210
Blue Bell, PA 19422
(610) 941-3600 Attorney for Plaintiff
IN THE COURT OF COMMON PLEAS OF CUMBERLAND COUNTY, PENNSYLVANIA
CIVIL ACTION - LAW
ATLANTIC MORTGAGE & INVESTMENT
CORPORATION, a division of ABN AMRO
Mortgage Group, Inc. : No. 02-91 Civil Term
V.
SHANE D. BURGER and
SHELLEY LEE LAWRENCE
PRAECIPE TO REINSTATE COMPLAINT
TO THE PROTHONOTARY:
Kindly reinstate the Complaint in the above captioned matter for service upon defendant.
HOMAS le ULEO
'Attorney for Plaintiff
THOMAS I. PULEO
IDENTIFICATION NO. 27615
620 Sentry Parkway, Suite 100
BLUE BELL. PENNSYLVANIA 19422
610) 941-3600
ATTORNEY FOR
TRUE COPY FROM RECORD
In Testftny whereof, I here unto set my hand
the sea of said Court atprlisle, Pa.
PLAINTIFF
MORTGAGE & INVESTMENT C? RM0Y% K9PE IATSY
ATLANTIC MO DIVISION
CORPORATION, a division of
ABN AMRO Mortgage Group, Inc
7159 Corklan Drive TERM,
Jacksonville, Florida 32258
V.
6Q
No. b 7 ?
Iv
SHANE D. BURGER and
SHELLEY LEE LAWRENCE n c-n
403 Deerfield Road C:
Camp Hill, PA 17011 o
CIVIL ACTION - MORTGAGE FORECLOSURE ::_, -,;• ,
COMPLAINT
o
tU `h'7
"NOTICE
'You have been sued in court. If you wish to defend against the
claims set forth in the following pages, you must take action within twenty
(20) days after this complaint and notice are served, by entering a written
appearance personally or by attorney and filing in writing with the court
your defenses or objections to the claims set forth against you. You are
warmed 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.
Court Administrator
4th Floor, CuAnberland County Courthouse
Carlisle, PA 17013
I - , .,, ? n n .mil/1A
"AVISO
'Le ban demandado a usted en la corte. Si usted quiere defenderse
de estas demandas expuestas en las p3ginas siguientes, usted liene veinte
(20) dias, de plazo aI partir de la fecha de Ia demanda y la notificati6n.
Hace fatta asentar una comparencia escrita o en persona o con un
abogado y entregar a la corte en forma escrila sus defensas o sus
objeciones a las demandas en contra de su persona. Sea avisado quo si
usted no se defiende, la corte tomar9 medidas y puede continuar la
demanda en contra suya sin previo aviso o notificacion. Adem$s, la coade
puede decidir a favor del demandante y requiere quo usted cumpla con
todas las provisiones de esta demanda. Usted puede perder dinero o sus
propiedades u otros derechos importantes pare usled.
'LLEVE ESTA DEMANDA A UN ABOGADO INMEDIATAMENTE. SI
NO TIENE ABOGADO O SI NO TIENE EL DINERO SUFICIENTE DE
PAGAR TAL SERVICIO, VAYA EN PERSONA O LLAME POR TELEFONO
A LA OFICINA CUYA DIRECC16N SE ENCUENTRA ESCRITA ABAJO
PARA AVERIGUAR DONDE SE PUEDE CONSEGUIR ASISTENCIA
LEGAL.
Court Administrator
4th Floor, C'uunberland County Courthouse
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SHERIFF'S RETURN - REGULAR
CASE NO: 2002-00091 P
COMMONWEALTH OF PENNSYLVANIA:
COUNTY OF CUMBERLAND
ATLANTIC MORTGAGE & INVESTMENT
VS
BURGER SHANE D ET AL
ROBERT BITNER
Sheriff or Deputy Sheriff of
Cumberland County,Pennsylvania, who being duly sworn according to law,
says, the within COMPLAINT - MnRT Fnpw
the
LAWRENCE SHELLEY LEE
was served upon
DEFENDANT
at 1839:00 HOURS, on the 28th day of April , 2003
at 142R 15TH STREET
NEW CUMBERLAND, PA 17070
SHELLEY LEE LAWRENCE
by handing to
a true and attested copy of COMPLAINT - MORT FORE
together with
and at the same time directing Her attention to the contents thereof.
Sheriff's Costs:
Docketing 18.00
Service 11.73
Affidavit .00
Surcharge 10.00
.00
39.73
Sworn and Subscribed to before
me this day of
o2131?3 A.D.
Prothonotary
So Answers:
R. Thomas Kline
04/29/2003
PULEO & D'EMILIO
By-
,NL
Deputy Sheriff
R. Thomas Kline, Sheriff, who being duly sworn according to law, states this
Writ is returned ABANDONED, no action taken in six months.
Sheriff's Costs:
Advance Costs: 150.00
Sheriff's Costs- 83 08
Docketing 18.00 66
92
Poundage .
1.63
Advertising
Law Library
-Prothonotary-- - 20.00-------- Refunded to-Attyor--4f24/03 -- -----
Mileage 3.45
Misc.
Surcharge 20.00
Levy 20.00 .
Post Pone Sale
Garnishee
TOTAL 83.08-
t ' Sworn and Subscribed to before me
" this 4, day of
2003 A .D
Cp
- pro onotary
So Answers;
r
R. Thomas-Kluie, Sheriff
By Claudia A. Brewbaker
i.C
WRIT OF EXECUTION - (MONEY JUDGMENTS)
RULES P.R.C.P. 3101 TO 3149 7U. vo7- `? Ps'/
HURON INSURANCE CO., ETAL. ) IN THE COURT OF COMMON PLEAS OF
PERRY COUNTY, PENNSYLVANIA
WRIT No: 02-108
VS. No: CV-CV-2001-00798
AMOUNT DUE: $11,441.00
INTEREST: $
MICHAEL GOSHORN ) ATTY'S Comm: $
RD#1,BOX 145 A ATTY DUE: $
ICKESBURG,PA.17037 ) PLTFF. PAID FROTHY. $39.50
THIS WRIT PAID - $20.00 - -
SHERIFF'S COSTS $300.00
SATISFACTION $5.00
COMMONWEALTH OF PENNSYLVANIA, COUNTY OF PERRY.
TO THE SHERIFF OF CU14BERLAND COUNTY
To satisfy the judgment, interest and costs against MICHAEL GOSHORN , Defendant(s).
(1) You are directed to levy upon the property of the defendant(s) and to sell his, her(or their) interest therein:
(Exemption Laws waived and Condemnation agreed to).
(2) You are also directed to attach the property to the defendant not levied upon in the possession of as Garnishee(s).
(Specifically described property)
LEVY ALL PERSONAL PROPERTY
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
fromdelivering any property to the defendant(s) or otherwise disposing thereof.
(3) If property of the defendant not levied upon and subject to attachment is found in the possession of anyone other
than the named garnishee(s), on are directed to notify him that he has been added as a garnishee and is enjoined as above
stated.
BRENDA J
Dated: 09/10/2002 J. ALBRIGHT
Prothonotary, Court of Common Pleas
e County, Pennsylvania
(2 _ . -L-
By:
-
Deputy
[SEAL]
z ? u
SHERIFF'S RETURN - OUT OF COUNTY
CASE NO: 2002-05426 P
COMMONWEALTH OF PENNSYLVANIA:
COUNTY OF CUMBERLAND
EAGLE FREIGHT LINES INC
VS
STAR INSURANCE COMPANY
R. Thomas Kline
Sheriff or Deputy Sheriff who being
duly sworn according to law, says, that he made a diligent search and
and inquiry for the within named DEFENDANT
STAR INSURANCE COMPANY
to wit:
but was unable to locate Them in his bailiwick. He therefore
deputized the sheriff of ALLEGHENY
serve the within COMPLAINT & NOTICE
County, Pennsylvania, to
On April 22nd , 2003 , this office was in receipt of t
attached return from ALLEGHENY
Sheriff's Costs:
Docketing 18.00
Out of County 9.00
Surcharge 10.00
Dep Allegheny Co 50.00
Notary 3.00
7v . vu
04/22/2003
WILLIAM T SMITH
Sworn and subscribed to before me
this G ` day of
d?zl.3 A. D.
Prothonotai `y
So answer
R" Thomas Kli e
Sheriff of Cumberland County
In The Court of Common Pleas of C'umb'erland County, Pennsylvania
j Gir-p Eagle Freight Lines, Inc C/)
VS.
Star Insurance Company et al
SERVE: Tri-Star Trailer 02-5426 civil
Leas' Inc. No.
3?1?0 ONE
ow, April 4, 2003 , I, SHERIFF OF CUMBERLAND COUNTY, PA, do
hereby deputize- the Sheriff of Allegheny County to execute this Writ, this
deputation being made at the request and risk of the Plaintiff.
Sheriff of Cumberland County, PA
Affidavit of Service
Now, 20 63 , at I? 3 o'clock 4__ M. served the
within
upon / JI ) - S
at
by handing to
7Xr,
MA4)Citi-AV
a - 71? V e copy of the original 1 t
and made known to the contents thereof.
So answers,
Sher' f County, PA
COST'S
Sworn an s bscribed h ore SERVICE _ ,? g c
me this day of _Zy ,
Notarial SWMEAUE
Sheila O'Brien, Al TX5??p}l? `? r
City of Pittsburgh, i e t 1
Commission Expires June 19, 2004
Member, Pennsylvania Association of Notaries
$ ?) 3, 00
SHERIFF'S RETURN - GARNISHEE
CASE NO: 2002-06069 P
COMMONWEALTH OF PENNSLYVANIA
COUNTY OF CUMBERLAND
HOUSEHOLD REALTY CORPORATION
VS
ROLLINGS RICHARD W
And now ROBERT BITNER
,Sheriff or Deputy Sheriff of
Cumberland County of Pennsylvania, who being duly sworn according
to law, at 0014:48 Hours, on the 28th day of April , 2003, attached
as herein commanded all goods, chattels, rights, debts, credits, and
moneys of the within named DEFENDANT
ROLLINGS RICHARD W
hands, possession, or control of the within named Garnishee
MID PENN BANK 4622 CARLISLE PIKE
, in the
MECHANICSBURG, PA 17055
Cumberland County, Pennsylvania, by handing to
DENEISE SHALAN (OFFICE MANAGER)
personally three copies of interogatories together with 3 true
and attested copies of the within WRIT OF EXECUTION and made
the contents there of known to Her .
Sheriff's Costs:
Docketing .00
Service .00
Affidavit .00
Surcharge .00
.Uu
So a
!.'
R. Thomas Kline
Sheriff of Cumberland County
00/00/0000
Sworn and subscribed to before me
this L` day of
3 ) A/.?D.
Pr t onotary '
By
Deputy Sheriff
LAW OFFICES OF PULEO & D'EMILIO, LLC
By: Thomas I. Puleo, Esquire
Identification No. 27615
660 Sentry Parkway, Suite 210
Blue Bell, PA 19422
(610) 941-3600 Attorney for Plaintiff
IN THE COURT OF COMMON PLEAS OF CUMBERLAND COUNTY, PENNSYLVANIA
CIVIL ACTION - LAW
ATLANTIC MORTGAGE & INVESTMENT
CORPORATION, a division of ABN AMRO
Mortgage Group, Inc. No. 02-91 Civil Term
V.
SHANE D. BURGER and
SHELLEY LEE LAWRENCE
PRAECIPE FOR JUDGMENT
Enter judgment in favor of the Plaintiff and against the Defendant(s) for want of an answer and
assess damages as follows:
Principal
Interest from 7/1/01 to 6/4/03
Late charges accrued thru 6/4/03
Escrow deficit (taxes and insurance)
Attorney's fee (5%)
Title information certificate
$109,647.21
19,564.16
963.07
9,806.74
5,482.36
325.00
Total $145,788.54
I CERTIFY THAT THE FOREGOING ASSESSMENT OF DAMAGES IS FOR SPECIFIED
AMOUNTS ALLEGED TO BE DUE IN THE COMPLAINT AND IS CALCULABLE AS A SUM
CERTAIN FROM THE COMPLAINT.
I certify that written notice of the intention to file this Praecipe was mailed or delivered to the party
against whom judgment is to be entered and to his attorney of record, if any, after the default occurred and
at least ten days prior to the date of the filing of this praecip A copy of the notice is attached. Pa.R.C.P.
237.1
THOMAS I. ULEO, ESQUIRE
Attorney for Plaintiff
AND NOW , 2003, Judgment is entered in favor of plaintiff and against
defendants and damag g assessed as per the above certification.
cat t t'
Prothonotary
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IN THE UNITED STATES BANKRUPTCY COURT
FOR THE MIDDLE DISTRICT OF PENNSYLVANIA
In re: : Chapter 13
SHANE D. BURGER
Bankruptcy No. 1-02-00443-JJT
Debtor
`/ ORDER
AND NOW, this 7 day of 2003, upon consideration of the Motion of
Atlantic Mortgage & Investment Corporation for relief from stay pursuant to 11 U.S.C. Section
362, and no answer having been filed thereto, it is ORDERED that the automatic stay is
terminated as to Movant which may proceed to enforce its mortgage by foreclosure and sheriff's
sale of the premises 403 Deerfield Road, Camp Hill, Cumberland County, Pennsylvania, and
exercise any other rights and remedies it has under the mortgage.
By the Court:
/sl John J. Thomas j
cc: Mr. Shane D. Burger
403 Deerfield Drive
Camp Hill, PA 17011
Honorable John J. Thomas
United States Bankruptcy Judge
Kenneth A. Wise, Esquire
126 Locust Street
P.O. Box 11489 PA
Harrisburg, PA 17108 h3. _ F
Charles J. DeHart, III, Esquire I ?
P.O. Box 410 1
Hummelstown, PA 17036 1 r3 ia° : coin
Thomas I. Puleo, Esquire
660 Sentry Parkway, Suite 210
Blue Bell, PA 19422
LAW OFFICES OF PULEO & D'EMILIO, LLC
By: Thomas I. Puleo, Esquire
Identification No. 27615
660 Sentry Parkway, Suite 210
Blue Bell, PA 19422
(610) 941-3600 Attorney for Plaintiff
IN THE COURT OF COMMON PLEAS OF CUMBERLAND COUNTY, PENNSYLVANIA
CIVIL ACTION - LAW_
ATLANTIC MORTGAGE & INVESTMENT
CORPORATION, a division of ABN AMRO
Mortgage Group, Inc.
No. 02-91 Civil Term
V.
SHANE D. BURGER and
SHELLEY LEE LAWRENCE
To: Mr. Shane D. Burger
403 Deerfield Road
Camp Hill, PA 17011
Date of Notice: May 20, 2003
NOTICE OF INTENTION TO FILE PRAECIPE FOR
ENTRY OF DEFAULT JUDGMENT UNDER Pa.R.C.P.237.1
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 AND 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 Bar Association
2 Liberty Avenue
Carlisle, PA 17013
(717) 249-3166
(800) 990-9108
HOMAS I. P LEO
Attorney for Plaintiff
LAW OFFICES OF PULEO & D-EMILIO, LLC
By: Thomas I. Puleo, Esquire
Identification No. 27615
660 Sentry Parkway, Suite 210
Blue Bell, PA 19422
(610) 941-3600 Attorney for Plaintiff
IN THE COURT OF COMMON PLEAS OF CUMBERLAND COUNTY, PENNSYLVANIA
CIVIL ACTION - LAW
ATLANTIC MORTGAGE & INVESTMENT
CORPORATION, a division of ABN AMRO
Mortgage Group, Inc.
v
SHANE D. BURGER and
SHELLEY LEE LAWRENCE
To: Ms. Shelley Lee Lawrence
142 15`n Street, Unit R
New Cumberland, PA 17070
Date of Notice: May 20, 2003
No. 02-91 Civil Term
NOTICE OF INTENTION TO FILE PRAECIPE FOR
ENTRY OF DEFAULT JUDGMENT UNDER Pa.R.C.P.237.1
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 AND 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 Count
2 Liberty Avenue
Carlisle, PA 17013
(717) 249-3166
(800) 990-9108
y Bar Association
TfIOMAS I. P LEO
Attorney for Plaintiff
V
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COMMONWEALTH OF PENNSYLVANIA
COUNTY OF CUMBERLAND
ATLANTIC MORTGAGE & INVESTMENT COURT OF COMMON PLEAS
CORPORATION, a division of ABN AMRO
Mortgage Group, Inc.
Plaintiff, NO. 02-91 Civil Term
V.
SHANE D. BURGER and
SHELLEY LEE LAWRENCE,
Defendant(s).
PRAECIPE FOR WRIT OF EXECi?T'IDN
4
TO THE PROTHONOTARY:
Issue Writ of Execution in the above matter:
AMOUNT DUE
INTEREST FROM
6/5/03 @ $27.79 per diem
$145,788.54 ?, /
COSTS TO BE ADDED
June 3, 2003
4-10-03 f er ?eG?p{, A11-
arytU rf-V n a
c? fills
$ 2&7.6 IE
H MMA41ULEO, ZESOU'IRE
Attorney for Plaintiff
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WRIT OF EXECUTION and/or ATTACHMENT
COMMONWEALTH OF PENNSYLVANIA)
COUNTY OF CUMBERLAND)
NO 02-91 Civil
CIVIL ACTION - LAW
TO THE SHERIFF OF CUMBERLAND COUNTY:
To satisfy the debt, interest and costs due ATLANTIC MORTGAGE & INVESTMENT
CORPORATION, a division of ABN AMRO Mortgage Group, Inc. Plaintiff (s)
From SHANE D. BURGER, 403 DEERFIELD ROAD, CAMP HILL PA 17011 AND
SHELLEY LEE LAWRENCE, 142 15TH STREET, UNIT R, NEW CUMBERLAND PA 17070
(1) You are directed to levy upon the property of the defendant (s)and to sell REAL ESTATE
LOCATED AT 403 DEERFIELD ROAD, 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 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 $145,788.54
Interest FROM 6/5/03 @ $27.79 PER DIEM
Arty's Comm %
Arty Paid
$240.16
Plaintiff Paid
Date: JUNE 9, 2003
(Seal)
REQUESTING PARTY:
L.L.
Due Prothy 1.00
Other Costs
CURTIS R. LONG
Protho tary
By: (I {. t G
Depu
Name THOMAS I. PULED, ESQUIRE
Address: 660 SENTRY PARKWAY, STE. 210
BLUE BELL PA 19422
Attorney for: PLAINTIFF
Telephone: (610) 941-3600
Supreme Court ID No. 27615
LAW OFFICES OF PULEO & D'EMILIO, LLC
By: Thomas I. Puleo, Esquire
Identification No. 27615
660 Sentry Parkway, Suite 210
Blue Bell, PA 19422
(610) 941-3600 Attorney for Plaintiff
IN THE COURT OF COMMON PLEAS OF CUMBERLAND COUNTY, PENNSYLVANIA
CIVIL ACTION - LAW
ATLANTIC MORTGAGE & INVESTMENT
CORPORATION, a division of ABN AMRO
Mortgage Group, Inc. : No. 02-91 Civil Term
V.
SHANE D. BURGER and
SHELLEY LEE LAWRENCE
AFFIDAVIT OF NON-MILITARY SERVICE
COMMONWEALTH OF PENNSYLVANIA
COUNTY OF MONTGOMERY
SS.
THOMAS I. PULED, being duly sworn according to law deposes and says that the defendant(s)
is/are not in the Military or Naval Service of the United States or its Allies, or otherwise within the
provisions of the Soldiers' and Sailors' Civil Relief Act of Congress of 1940, as amended;
That Shane D. Burger is over 21 years of age, resides at 403 Deerfield Road, Camp Hill,
Pennsylvania, and is employed by/as unknown.
That Shelley Lee Lawrence is over 21 years of age, resides at 142 15'n Street, Unit R, New
Cumberland, Pennsylvania, and is employed by/as unknown.
PULEO
Plaintiff
SWORN TO AND SUBSCRIBED
BEFORE ME THIS 20" DAY
OF Mav. 2003.
Y PU IC NOTARIAL SEAL
LISA A. KANE, Notary Public
Whitpain TwP., Montgomery County
My Commission Expires August 1, 2005
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LAW OFFICES OF PULEO & D'EMILIO
660 Sentry Parkway, Suite 210
Blue Bell, PA 19422
(610) 941-3600
By: Thomas I. Puleo, Esquire
Identification No. 27615 Attorney for PLAINTIFF
IN THE COURT OF COMMON PLEAS OF CUMBERLAND COUNTY, PENNSYLVANIA
CIVIL ACTION - LAW
ATLANTIC MORTGAGE & INVESTMENT
CORPORATION, a division of ABN AMRO
Mortgage Group, Inc NO. 02-91 Civil Term
Plaintiff
V.
SHANE D. BURGER and
SHELLEY LEE LAWRENCE,
Defendant
AFFIDAVIT UNDER PA. RCP RULE 3129
THOMAS I. PULED, attorney for Plaintiff in the above captioned mortgage foreclosure
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 403 Deerfield Road, Camp Hill, Cumberland
County, Pennsylvania, was true and correct to the best of its knowledge, information and belief.
Name and address of each Owner and/or Reputed Owner:
Shane D. Burger Shelley Lee Lawrence
403 Deerfield Road 142 15" Street, Unit R
Camp Hill, PA 17011 New Cumberland, PA 17070
2. Name and address of each Defendant named in the judgment:
Shane D. Burger Shelley Lee Lawrence
403 Deerfield Road 142 15`h Street, Unit R
Camp Hill, PA 17011 New Cumberland, PA 17070
3.
4.
Name and last known address of every judgment creditor whose judgment is a record lien
on the real property to be sold:
None
Name and address of the last recorded holder of every mortgage of record:
Atlantic Mortgage & Investment Corporation, Plaintiff
7159 Corklan Drive
Jacksonville, FL 32258
Barry A. Richmond
237 Gravel Hill Road
Palmyra, PA 17036
Beneficial CDC d/b/a
Beneficial Mtg. Co. of PA
P. O. Box 4499
Harrisburg, PA 17111
Name and address of every other person or entity which has any record lien on the
property:
None
6. Name and address of every other person or entity which has any record interest in the
property and whose interest may be affected by the sale:
Cumberland County Domestic Relations Commonwealth of PA
13 N. Hanover Street Department of Public Welfare
Carlisle, PA 17013 P. O. Box 2675
Harrisburg, PA 17105
7. Name and address of every other person of whom the Plaintiff has knowledge who may
have an interest in the property which may be affected by the sale:
None
I verify that the statements made in this Affidavit are true and correct to the best of my
personal knowledge, 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.
Date: June 3, 2003
AHOMAAS L P,FJLEO, ESQUIRE
Attorney for Plaintiff
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LAW OFFICES OF PULEO & D'EMILIO
660 Sentry Parkway, Suite 210
Blue Bell, PA 19422
(610) 941-3600
By: Thomas I. Puleo, Esquire
Identification No. 27615
Attorney for PLAINTIFF
IN THE COURT OF COMMON PLEAS OF CUMBERLAND COUNTY, PENNSYLVANIA
CIVIL ACTION - LAW
ATLANTIC MORTGAGE & INVESTMENT
CORPORATION, a division of ABN AMRO
Mortgage Group, Inc
Plaintiff
V.
SHANE D. BURGER and
SHELLEY LEE LAWRENCE,
Defendant
NO. 02-91 Civil Term
NOTICE OF SHERIFF'S SALE OF REAL PROPERTY
TO: Shane D. Burger
403 Deerfield Road
Camp Hill, PA 17011
Shelley Lee Lawrence
142 15`n Street, Unit R
New Cumberland, PA 17070
Your house at 403 Deerfield Road, City of Camp Hill, Cumberland County, is scheduled
to be sold by the Cumberland County Sheriffs Department to enforce the Court judgment of
$145,788.54 obtained by Plaintiff Atlantic Mortgage & Investment Corporation, a division of
ABN AMRO Mortgage Group, Inc against you. The Sheriffs Sale will be conducted on
Wednesday, September 3, 2003, at 10:00 A.M., Cumberland County Courthouse, 2nd Floor,
Commissioner's Hearing Room, Carlisle, Pennsylvania.
NOTICE OF OWNERS' RIGHTS
YOU MAY BE ABLE TO PREVENT THIS SHERIFF'S SALE
To prevent this Sheriffs Sale, you must take immediate action:
This sale will be canceled if you pay to Atlantic Mortgage & Investment
Corporation the back payments, late charges, costs and reasonable attorneys' fees
due. To find out how much you must pay, you may call (610) 941-3600.
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 sto 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 below 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 Sheriffs Sale is not stopped, your property will be sold to the highest bidder.
You may find out the price bid by calling the Cumberland County Sheriffs
Department at (717) 240-6390.
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 bid in
the sale. To find out if this has happened, you may call the Cumberland County
Sheriffs Department at (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 had never happened.
5. You have the right to remain in the property until the full amount due is paid to
the Sheriff and the Sheriff gives a deed to the buyer. At that time, the buyer may
bring legal proceedings to evict you.
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
Cumberland County Sheriff on or about thirty (30) days from the date of Sheriffs
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 sheet is posted.
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
BELOW TO FIND OUT WHERE YOU CAN GET LEGAL HELP.
Court Administrator
4th Floor, Cumberland County Courthouse
Carlisle, PA 17013
(717) 240-6200
LAW OFFICES OF PULED & D'EMILIO
660 Sentry Parkway, Suite 210
Blue Bell, PA 19422
(610) 941-3600
By: Thomas I. Puleo, Esquire
Identification No. 27615 Attorney for PLAINTIFF
IN THE COURT OF COMMON PLEAS OF CUMBERLAND COUNTY, PENNSYLVANIA
CIVIL ACTION - LAW
ATLANTIC MORTGAGE & INVESTMENT::
CORPORATION, a division of ABN AMRO
Mortgage Group, Inc
Plaintiff
V.
SHANE D. BURGER and
SHELLEY LEE LAWRENCE,
Defendant
NO. 02-91 Civil Term
AFFIDAVIT OF SERVICE
I, Thomas I. Puleo, Jr., Legal Assistant to Thomas I. Puleo, Esquire, attorney for plaintiff,
being duly sworn according to law, deposes and says that he mailed by ordinary mail a Notice of
Sale pursuant to Pa.R.C.P 3129.2 upon the persons listed below on the 24`" day of July, 2003 as
evidenced by the U.S. Postal Service Certificate of Mailing (Form 3877), which is attached
hereto as Exhibit "A":
Cumberland County Domestic Relations
13 N. Hanover Street
Carlisle, PA 17013
Barry A. Richmond
237 Gravel Hill Road
Palmyra, PA 17036
SWORN TO AND SUBSCRIBED
BEFORE ME THIS 14"' DAY
OF Ua , 2003.
OTA PUBLIC
Commonwealth of PA
Department of Public Welfare
P. O. Box 2675
Harrisburg, PA 17105
Beneficial CDC d/b/a
Beneficial Mtg rCa
P. O. Box 4 99
as L Puleo, Jr., Legal Assistant to
Ttiomas I. Puleo
NOTARIAL SEAL
LUZ N FUENTES, Notary Public
n T wp., Montgomery C[:Whitpa'
Commission Expires January 13, 2007
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LAW OFFICES OF PULEO & D'EMILIO
660 Sentry Parkway, Suite 210
Blue Bell, PA 19422
(610) 941-3600
By: Thomas L Puleo, Esquire
Identification No. 27615 Attorney for PLAINTIFF
IN THE COURT OF COMMON PLEAS OF CUMBERLAND COUNTY, PENNSYLVANIA
CIVIL ACTION - LAW
ATLANTIC MORTGAGE &
INVESTMENT
CORPORATION, a division of ABN AMRO NO. 02-91 Civil Term
Mortgage Group, Inc
Plaintiff
V.
SHANE D. BURGER and
SHELLEY LEE LAWRENCE,
Defendant
AFFIDAVIT OF SERVICE
I, Thomas I. Puleo, Jr., Legal Assistant to Thomas I. Puleo, Esquire, attorney for plaintiff,
being duly sworn according to law, deposes and says that he mailed by ordinary mail a Notice of
Sale pursuant to Pa.R.C.P 3129.2 upon the persons listed below on thelth day of July, 2003 as
evidenced by the U.S. Postal Service Certificate of Mailing (Form 3877), which is attached
hereto as :Exhibit "A":
Lower Allen Township Lower Allen Township
1993 Hummel Avenue 120 Limekiln Road
Camp Hill, PA 17012 New Cumberland, PA 17070
Tl? mas I. Puleo, Jr., Legal Assistant to
Thomas I. Puleo
LUZ N. FUENTES, Notary Public
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NOTA PUBLI Whitpain Twp Montgomery County
My Commission Expires January 13, 2007
SWORN TO AND SUBSCRIBED
BEF ME THIS ) ?-" DAY
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LAW OFFICES OF PULEO & D'EMILIO
660 Sentry Parkway, Suite 210
Blue Bell, PA 19422
(610) 941-3600
By: Thomas 1. Puleo, Esquire
Identification No. 27615 Attorney for PLAINTIFF
IN THE COURT OF COMMON PLEAS OF CUMBERLAND COUNTY, PENNSYLVANIA
CIVIL ACTION - LAW
ATLANTIC MORTGAGE &
INVESTMENT
CORPORATION, a division of ABN AMRO
Mortgage Group, Inc
Plaintiff
NO. 02-91 Civil Term
V.
SHANE D. BURGER and
SHELLEY LEE LAWRENCE,
Defendant
AFFIDAVIT UNDER PA. RCP RULE 3129
THOMAS I. PULED, attorney for Plaintiff in the above captioned mortgage foreclosure
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 403 Deerfield Road, Camp Hill, Cumberland
County, Pennsylvania, was true and correct to the best of its knowledge, information and belief.
Name and address of each Owner and/or Reputed Owner:
Shane D. Burger Shelley Lee Lawrence
403 Deerfield Road 142 15`h Street, Unit R
Camp Hill, PA 17011 New Cumberland, PA 17070
2. Name and address of each Defendant named in the judgment:
Shane D. Burger Shelley Lee Lawrence
403 Deerfield Road 142 15`h Street, Unit R
Camp Hill, PA 17011 New Cumberland, PA 17070
a
3
4
5
6
Name and last known address of every judgment creditor whose judgment is a record lien
on the real property to be sold:
Lower Allen Township
1993 Hummel Avenue
Camp Hill, PA 17012
Lower Allen Township
120 Limekiln Road
New Cumberland, PA 17070
Name and address of the last recorded holder of every mortgage of record:
Atlantic Mortgage & Investment Corporation, Plaintiff
7159 Corklan Drive
Jacksonville, FL 32258
Barry A. Richmond
237 Gravel Hill Road
Palmyra, PA 17036
Beneficial CDC d/b/a
Beneficial Mtg. Co. of PA
P. O. Box 4499
Harrisburg, PA 17111
Name and address of every other person or entity which has any record lien on the
property:
None
Name and address of every other person or entity which has any record interest in the
property and whose interest may be affected by the sale:
Cumberland County Domestic Relations Commonwealth of PA
13 N. Hanover Street Department of Public Welfare
Carlisle, PA 17013 P. O. Box 2675
Harrisburg, PA 17105
7. Name and address of every other person of whom the Plaintiff has knowledge who may
have an interest in the property which may be affected by the sale:
None
I verify that the statements made in this Affidavit are true and correct to the best of my
personal knowledge, 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.
Date: July 25, 2003
Ie ?i ?9 I
THOMAS I. LEO, ESQUIRE
Attorney for Plaintiff
COMMONWEALTH OF PENNSYLVANIA
COUNTY OF CUMBERLAND } SS:
I, Robert P. Ziegler, Recorder of Deeds in and for said County and State do hereby certify that
the Sheriff s Deed in which ABN AMRO Mtg Group Inc fka Atlantic Mtg & Inv Corp is the grantee the
same having been sold to said grantee on the 3rd day of Sept A.D., 2003, under and by virtue of a writ
Execution issued on the 9th day of June, A.D., 2003, out of the Court of Common Pleas of said County
as of Civil Term, 2002 Number 91, at the suit of Atlantic Mtg & Inv Corp division of AMRO Mtg
Group Inc against Shane D Burger & Shelley Lee Lawrence is duly recorded in Sheriff s Deed Book
No. 259, Page 3021.
IN TESTIMONY WHEREOF, I have hereunto set my hand
and seal of said office this /pat day of
OCTr , A.D. 2003
My C °°r FMUr ?Y MG
Atlantic Mortgage & Investment hi The Court of Common Pleas of
Corporation, a division of ABN Cumberland County, Pennsylvania
Amro Mortgage Group, Inc. Writ No. 2002-91 Civil Term
VS
Shane D. Burger and Shelley Lee Lawrence
R. Thomas Kline, Sheriff, who being duly sworn according to law, states that he
made a diligent search and inquiry for the within named defendants, to wit: Shane D.
Burger, but was unable to locate him in his bailiwick. He therefore deputized the Sheriff
of Dauphin County, Pennsylvania, to serve the within Real Estate Writ, Notice and
Description according to law.
DAUPHIN COUNTY RETURN: And Now: July 9, 2003 at 8:40 AM served the
within Notice of Sale upon Shane D. Burger by personally handing to Deandra Burger
(wife), one true attested copy of the original Notice of Sale and making known to him the
contents thereof at 509 Winand Drive, Harrisburg, PA 17109. So answers: J.R. Lotwick,
Sheriff of Dauphin County, PA.
Valerie Weary, Deputy Sheriff, who being duly sworn according to law, states
that on July 1, 2003 at 8:03 o'clock PM, she served a true copy of the within Real Estate
Writ, Notice and Description, in the above entitled action, upon the within named
defendant, to wit: Shelley Lee Lawrence, by making known unto Shelley L. Lawrence
personally, at 403 Deerfield Road, Camp Hill, Cumberland County, Pennsylvania, its
contents and at the same time handing to her personally the said true and correct copy of
the same.
Jason Vioral, Deputy Sheriff, who being duly sworn. according to law, states that
on July 9, 2003 at 1:45 o'clock P.M., he posted a true copy of the within Real Estate
Writ, Notice, Poster and Description, in the above entitled action, upon the property of
Shane D. Burger and Shelley Lee Lawrence located at 403 Deerfield Road, Camp Hill,
Pennsylvania, according to law.
R. Thomas Kline, Sheriff, who being duly sworn according to law, states he
served the above Real Estate Writ, Notice, Poster and Description in the following
manner: The Sheriff mailed a notice of the pendency of the action to one of the within
named defendants, to wit: Shane D. Burger, by regular mail to his last known address of
509 Winand Dr., Harrisburg, PA 17109. This letter was mailed under the date of July 14,
2003 and never returned to the Sheriffs Office.
R. Thomas Kline, Sheriff, who being duly sworn according to law, states he
served the above Real Estate Writ, Notice, Poster and Description in the following
manner: The Sheriff mailed a notice of the pendency of the action to one of the within
named defendants, to wit: Shelley Lee Lawrence, by regular mail to her last known
address of 142 15th Street, Unit R, New Cumberland, PA 17070. This letter was mailed
under the date of July 007, 2003 and never returned to the Sheriffs Office.
R. Thomas Kline, Sheriff, who being duly sworn according to law, states that
after due and legal notice had been given according to law, he exposed the within
described premises at public venue or outcry at the Courthouse, Carlisle, Cumberland
County, Pennsylvania on September 3, 2003 at 10:00 o'clock A.M. He sold the same for
the sum of $1.00 to Attorney Thomas Puleo for ABN AMRO Mortgage Group, Inc., f/k/a
Atlantic Mortgage & Investment Corporation, its successors and assigns. It being the
highest bid and best price received for the same, ABN AMRO Mortgage Group, Inc. f/k/a
Atlantic Mortgage & Investment Corporation, its successors and assigns of 7159 Corklan
Drive, Jacksonville, FL 32258, being the buyer in this execution, paid to Sheriff R.
Thomas Kline the sum of $914.07.
Sheriffs Costs
Docketing $30.00
Poundage 17.92
Posting Bills 15.00
Advertising 15.00
Acknowledging Deed 30.00
Auctioneer 10.00
Law Library
Prothonotary 1.00
Mileage 23.46
Out of County 9.00
Dauphin County 30.50
Levy 15.00
Surcharge 30.00
Law Journal 311.90
Patriot News 281.89
Share of Bills 28.90
Distribution of Proceeds 25.00
Sheriffs Deed 39.50
$ 914.07
Sworn and subscribed to before me So Answ
This k"' day of Oa--L.
, `
1 R. Thomas Kline, Sheriff
2003, A.D.?
Prothonotary BY CAL
Real Estate eputy
aAk? 00A
?b Ili
?' Ue yd 3,31
PG"1431? 7
LAW OFFICES OF PULEO & D'EMILIO
660 Sentry Parkway, Suite 210
Blue Bell, PA 19422
(610) 941-3600
By: Thomas I. Puleo, Esquire
Identification No. 27615 Attorney for PLAINTIFF
IN THE COURT OF COMMON PLEAS OF CUMBERLAND COUNTY, PENNSYLVANIA
CIVIL ACTION - LAW
ATLANTIC MORTGAGE & INVESTMENT
CORPORATION, a division of ABN AMRO
Mortgage Group, Inc
Plaintiff
NO. 02-91 Civil Term
V.
SHANE D. BURGER and
SHELLEY LEE LAWRENCE,
Defendant
AFFIDAVIT UNDER PA. RCP RULE 3129
THOMAS I. PULED, attorney for Plaintiff in the above: captioned mortgage foreclosure
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 403 Deerfield Road, Camp Hill, Cumberland
County, Pennsylvania, was true and correct to the best of its knowledge, information and belief.
Name and address of each Owner and/or Reputed Owner:
Shane D. Burger Shelley Lee Lawrence
403 Deerfield Road 142 15' Street, Unit R
Camp Hill, PA 17011 New Cumberland, PA 17070
2. Name and address of each Defendant named in the judgment:
Shane D. Burger Shelley Lee Lawrence
403 Deerfield Road 142 15`h Street, Unit R
Camp Hill, PA 17011 New Cumberland, PA 17070
3
4.
5.
6.
Name and last known address of every judgment creditor whose judgment is a record lien
on the real property to be sold:
None
Name and address of the last recorded holder of every mortgage of record:
Atlantic Mortgage & Investment Corporation, Plaintiff
7159 Corklan Drive
Jacksonville, FL 32258
Barry A. Richmond
237 Gravel Hill Road
Palmyra, PA 17036
Beneficial CDC d/b/a
Beneficial Mtg. Co. of PA
P. O. Box 4499
Harrisburg, PA 17111
Name and address of every other person or entity which has any record lien on the
property:
None
Name and address of every other person or entity which has any record interest in the
property and whose interest may be affected by the sale:
Cumberland County Domestic Relations Commonwealth of PA
13 N. Hanover Street Department of Public Welfare
Carlisle, PA 17013 P. O. Box 2675
Harrisburg., PA 17105
7. Name and address of every other person of whom the Plaintiff has knowledge who may
have an interest in the property which may be affected by the sale:
None
I verify that the statements made in this Affidavit are true and correct to the best of my
personal knowledge, 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.
Date: June 3, 2003
YMW i
HOMAS I. WLEO, ESQUIRE
Attorney for Plaintiff
LAW OFFICES OF PULEO & D'EMILIO
660 Sentry Parkway, Suite 210
Blue Bell, PA 19422
(610) 941-3600
By: Thomas I. Puleo, Esquire
Identification No. 27615 Attorney for PLAINTIFF
IN THE COURT OF COMMON PLEAS OF CUMBERLAND COUNTY, PENNSYLVANIA
CIVIL ACTION - LAW
ATLANTIC MORTGAGE & INVESTMENT
CORPORATION, a division of ABN AMRO
Mortgage Group, Inc
Plaintiff
V.
SHANE D. BURGER and
SHELLEY LEE LAWRENCE,
Defendant
NO. 02-9.1 Civil Term
NOTICE OF SHERIFF'S SALE OF REAL PROPERTY
TO: Shane D. Burger Shelley Lee Lawrence
403 Deerfield Road 142 15'h Street, Unit R
Camp Hill, PA 17011 New Cumberland, PA 17070
Your house at 403 Deerfield Road, City of Camp Hill, Cumberland County, is scheduled
to be sold by the Cumberland County Sheriffs Department to enforce the Court judgment of
$145,788.54 obtained by Plaintiff Atlantic Mortgage & Investment Corporation, a division of
ABN AMRO Mortgage Group, Inc against you. The Sheriffs Sale will be conducted on
Wednesday, September 3, 2003, at 10:00 A.M., Cumberland County Courthouse, 2nd Floor,
Commissioner's Hearing Room, Carlisle, Pennsylvania.
NOTICE OF OWNERS' RIGHTS
YOU MAY BE ABLE TO PREVENT THIS SHERIFF'S SALE
To prevent this Sheriffs Sale, you must take immediate action:
This sale will be canceled if you pay to Atlantic Mortgage & Investment
Corporation the back payments, late charges, costs and reasonable attorneys' fees
due. To find out how much you must pay, you may call (610) 941-3600.
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 so 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 below 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.
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 the Cumberland County Sheriffs
Department at (717) 240-6390.
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 bid in
the sale. To find out if this has happened, you may call the Cumberland County
Sheriffs Department at (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 had never happened.
5. You have the right to remain in the property until the full amount due is paid to
the Sheriff and the Sheriff gives a deed to the buyer. At that time, the buyer may
bring legal proceedings to evict you.
6. You may be entitled to a share of the money which was paid for your house. A
schedule of distribution of the money bid for your house will be filed by the
Cumberland County Sheriff on or about thirty (30) days from the date of Sheriffs
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 sheet is posted.
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
BELOW TO FIND OUT WHERE YOU CAN GET LEGAL HELP.
Court Administrator
4th Floor, Cumberland County Courthouse
Carlisle, PA 17013
(717) 240-6200
LAW OFFICES OF PULEO & D'EMILIO
660 Sentry Parlmay, Suite 210
Blue Bell, PA 19422
(610)941-3600 leo Esquire
By. Thomas I. 27615
Identification No. _-
-? OF
Attorney for PLAINTIFF
------ COUNTY, PENNSYLVANIA:
CUMBERLAND
F COMMON PLEA
O CIVIL ACTION - LAW
IN THE COURT
ATLANTIC MORTGAGE & INVESTMENT
CORPORATION, a division of ABN AMRO NO 02 91 Civil Term
Mortgage Group, Inc
Plaintiff
V.
SHANE D. BURGER and
CE,
SHELLEY LEE LAWRENCE'
Defendant
NOTICE OF SHERIFF'S SALE OF REAL PROPERTY
TO: 4Shane D. Burger
03 Deerfield Road
Camp Hill, PA 17011
Shelley Lee Lawrence
Unit R
142 15`' Street,
New Cumberland, PA 17070
Your house at 403 Deerfield Road, City of Camp Hill, Cumberland County, is
to be sold by the Cumberland County Sheriff s Department to enforce the Court Judgm
Plaintiff Atlantic Mortgage & Investment Corporation, a divi cond $1 N AI\.54 obtained Group, Inc against you. The Sheriffs Sale Cwill ourthou et, 2nd
ABN AMRO Mortgage Cumberland County
Wednesday, September 3, 2003, at 10:00 A.M., lvania.
Commissioner's Hearing Room, Carlisle, Pennsy
NOTICE OF OWNERS' RIGHTS
To prevent this Sheriff s Sale, you must take immedi
1 This sale will be canceled if you pay to Atlantic Mortgage & Investme
call reasonable 10) 941-36
corporation the back payments, late charges, costs and
due. To find out how much you must pay, you may
of
1 of
You may be able to stop the sale by filing a petition asking the Court to strike or
open the Judgment, if the judgment was improperly entered. You may also ask
the Court to postpone the sale for good cause.
You may also be able to stop the sale through other legal proceedings.
You may need an attorney to assert your rights. The sooner you contact one, the more
chance you will have of stopping the sale. (See notice below 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.
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 the Cumberland County Sheriffs
Department at (717) 240-6390.
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 bid in
the sale. To find out if this has happened, you may call the Cumberland County
Sheriffs Department at (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 had never happened.
You have the right to remain in the property until the full amount due is paid to
the Sheriff and the Sheriff gives a deed to the buyer. At that time, the buyer may
bring legal proceedings to evict you.
6. You may be entitled to a share of the money which was paid for your house. A
schedule of distribution of the money bid for your house will be filed by the
Cumberland County Sheriff on or about thirty (30) days from the date of Sheriffs
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 sheet is posted.
I ,
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
BELOW TO FIND OUT WHERE YOU CAN GET LEGAL HELP.
Court Administrator
4th Floor, Cumberland County Courthouse
Carlisle, PA 17013
(717) 240-6200
g
DESCRIPTION
ALL THAT CERTAIN tract or parcel of land and premises, situate, lying and being in the Township
of Lower Allen in the County of Cumberland and Commonwealth of Pennsylvania, more particularly
described as follows:
BEGINNING at a point on the northeasterly line of Deerfield Road, a 50 foot wide right-of-way, Iwhich
said point of beginning is located at the intersection of the northeasterly line of Deerfield Road and the
dividing line between Lots Nos. 7 and 8 on the Resubdivision Plan of Allendale, Section 9, recorded
in Cumberland County Plan Book "25", Page 133; thence, from said point of beginning along the north
easterly line of Deerfield Road, north 24 degrees 58 minutes 10 seconds west, a distance of 100. feet
to a point on the dividing line between Lots Nos. 6 and 7; thence from said point along the divid' g line
between Lots Nos. 6 and 7 north 65 degrees, 1 minute 50 seconds east, a distance of 170.03 feet to a
point; thence from said point, south 24 degrees 58 minutes 11) seconds east, a distance of 100. feet
to a point on the dividing line between Lots Nos. 7 and 8; thence from said point along the dividing line
between Lots Nos. 7 and 8, south 65 degrees 1 minute 50 seconds west, a distance of 170.03 feet to
a point, the point and place of beginning.
BEING Lot No. 7 on the Resubdivision Plan of Allendale, ;iection 9, recorded in the Office ?f the
Recorder of Deeds of Cumberland County, Pennsylvania, in Mn Book "25", Page 133.
HAVING thereon erected a dwelling house being (mown and numbered as premises 403 Deerfield Road,
Camp Hill, Pennsylvania.
Map #24-0809 Parcel 010
WRIT OF EXECUTION and/or ATTACHMENT
COMMONWEALTH OF PENNSYLVANIA)
COUNTY OF CUMBERLAND)
NO 02-91 Civil
CIVIL ACTION - LAW
TO THE SHERIFF OF CUMBERLAND COUNTY:
To satisfy the debt, interest and costs due ATLANTIC MORTGAGE & INVESTMENT
CORPORATION, a division of ABN AMRO Mortgage Group, Inc. Plaintiff (s)
From SHANE D. BURGER, 403 DEERFIELD ROAD, CAMP HILL PA 17011 AND
SHELLEY LEE LAWRENCE, 142 15TH STREET, UNIT R, NEW CUMBERLAND PA 17070
(1) You are directed to levy upon the property of the defendant (s'land to sell REAL ESTATE
LOCATED AT 403 DEERFIELD ROAD, CAMP HELL 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 gamishee(s) is enjoined from
paying any debt to or for the account of the defendant (s) and from delivering any property of the defendant
(s) or otherwise disposing thereof;
(3) If property of the defendant(s) not levied upon an subject to attachment is found in the possession
of anyone other than a named garnishee, you are directed to notify him/her that he/she has been added as a
garnishee and is enjoined as above stated.
Amount Due $145,788.54 L.L.
Interest FROM 6/5/03 @ $27.79 PER DIEM
Atty's Comm % Due Prothy 1.00
Atty Paid
$240.16 Other Costs
Plaintiff Paid
Date: JUNE 9, 2003
CURTIS R. LONG
Protlm
(Seal) By:
U Deputy
REQUESTING PARTY:
Name THOMAS I. PULED, ESQUIRE
Address: 660 SENTRY PARKWAY, STE. 210
BLUE BELL PA 19422
Attorney for: PLAINTIFF
Telephone: (610) 941-3600
Supreme Court ID No. 27615
Real Estate Sale # 58
On June 16, 2003 the sheriff levied upon the
defendant's interest in the real property situated in
Lower Allen Township, Cumberland County, PA
known and numbered as 403 Deerfield Road,
Camp Hill, more fully described on Exhibit "A"
filed with this writ and by this reference incorporated herein.
Date: June 16, 2003 By:,,_, I C (Lq S«?
Real Estate Deputy
c A
THE PATRIOT NEWS
THE SUNDAY PATRIOT NEWS
Proof of Publication
Under Act No. 587, Approved May 16, 1929
Commonwealth of Pennsylvania, County of Dauphin) ss
Joseph A. Dennison, being duly sworn according to law, deposes and says:
That he is the Asst. Controller of The Patriot News Co., a corporation organized and existing under the laws
of the Commonwealth of Pennsylvania, with its principal office and place of business at 812 to 818 Market Street, in
the City of Harrisburg, County of Dauphin, State of Pennsylvania, owner and publisher of The Patriot-News and The
Sunday Patriot-News newspapers of general circulation, printed and published at 812 to 818 Market Street, in the
City, County and State aforesaid; that The Patriot-News and The Sunday Patriot-News were established March 4th,
1854, and September 18th, 1949, respectively, and all have been continuously published ever since;
That the printed notice or publication which is securely attached hereto is exactly as printed and published in
their regular daily and/or Sunday/ Metro editions which appeared on the 22nd and 29th day(s) of July and the 5th
day(s) of August 2003. That neither he nor said Company is interested in the subject matter of said printed notice
or advertising, and that all of the allegations of this statement as to the time, place and character of publication are
true; and
That he has personal knowledge of the facts aforesaid and is duly authorized and empowered to verify this
statement on behalf of The Patriot-News Co. aforesaid by virtue and pursuant to a resolution unanimously passed and
adopted severally by the stockholders and board of directors of the said Company and subsequently duly recorded in
the office for the Recording of Deeds in and for said County of Dauphin in Miscellaneous Book "M",
Volume 14, Page 317.
PUBLICATION
Nop
....../.... ....... Z;OL
COPY Sworn t an subscribed before me his 13th day of August 26d3 A.D.
S A L E #58 Notarial Seal t.
T ID J
/ + '
REAL ESTATE SALE No. 58
W
i
N -1y . ussell, NotaryPubhc
City Of Hamsburg
Dauphin County
r
t
o. 2002-91
Civil Term ,
My Commission Expires June 6, 2006 NOTARY PUBLIC
Atlantic Mortgage &
Investment Corporation, Member, Pennsvlvanin Association Of Notaries My commission expires June 6, 2006
a division of
ABN Amro Mortgage Group, Inc„ CUMBERLAND COUNTY SHERIFFS OFFICE
Shane D. Burger and CUMBERLAND COUNTY COURTHOUSE
Shelley Lee Lawrence CARLISLE, PA. 17013
Atty : Thomas Puleo
DESCRIPTION
ALL THAT CERTAIN tract or parcel of lard Statement of Advertising Costs
and premises, situate, lying and being in the
Township of Lower Allen in the County of To THE PATRIOT-NEWS CO., Dr.
Cumberland and Commonwealth of
Pennsylvania, more particularly described as
For publishing the notice or publication attached
follows: hereto on the above stated dates $ 280.14
BEGINNING at a point on the northeasterly lire
of Deerfield Road, a 50-foot-wide right-of-way,
Probating same Notary Fee(s) $ 1.75
which said point of beginning is located at the Total $ 281.89
intersection of the northeasterly line of Deerfield
Road and the dividing line between Lots Nos. 7
and 8 on the iPlan of Allendale,
Section 9, recorded ded in Cumberland County Plan 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 acknowledg e receipt of the aforesaid notice and publication costs and certifies that the same have
been duly paid. ,
By ....................................................................
Book .ner_ , a sa.u p„in: ,
beginning along the northeasterly line ,ti
Deerfield Road, north 24 degrees 58 minutes 10
seconds west, a distance of 100.00 feet to a point
on the dividing line between Lots Nos. 6 and 7,
thence from said point along the dividing line
between Lots Nos. 6 and 7 north 65 degrees,
minutes 50 seconds east, a distance of 170.03 fee:
to a point thence from said point, south 2-!:
degrees 58 minutes 10 seconds east, a distance of
100.00 feet to a point on the dividing line between
Lots Nos. 7 and 8; thence from said point along
the dividing line between Lots Nos. 7 and 8, south
65 degrees 1 minute 50 seconds west, a distance
of 170.03 feet to a point, the point and place of
BEGINNING.
BEING Lot No. '7 on the Resubdivision Plan .,;
Allendale, Section 9, recorded in the Office of the
Recorder of Deeds of Cumberland County
Pennsylvania, Plan Book "25", Page 133.
HAVING thereon erected a dwelling house beint
known and numbered as premises 403 Deerfield
Road, Camp Hill, Pennsylvania.
MAP #24.0809; PARCEL 0 10.
PROOF OF PUBLICATION OF NOTICE
IN CUMBERLAND LAW JOURNAL
(Under Act No. 587, approved May 16, 1929), P. L.1784
STATE OF PENNSYLVANIA :
COUNTY OF CUMBERLAND :
ss.
Lisa Marie Coyne, Esquire, Editor of the Cumberland Law Journal, of the County and
State aforesaid, being duly sworn, according to law, deposes and says that the Cumberland Law
Journal, a legal periodical published in the Borough of Carlisle in the County and State aforesaid,
was established January 2, 1952, and designated by the local courts as the official legal
periodical for the publication of all legal notices, and has, since January 2, 1952, been regularly
issued weekly in the said County, and that the printed notice or publication attached hereto is
exactly the same as was printed in the regular editions and issues of the said Cumberland Law
Journal on the following dates,
viz:
JULY 18, 25, 2003 AUGUST 1, 2003
Affiant further deposes that he is authorized to verify this statement by the Cumberland
Law Journal, a legal periodical of general circulation, and that he is not interested in the subject
matter of the aforesaid notice or advertisement, and that all allegations in the foregoing
statements as to time, place and character of publication are true.
REAL ESTATE BALE NO. 58
Writ No. 2002-91 Civil
Atlantic Mortgage & Investment
Corporation, a division of ABN
AMRO Mortgage Group, Inc.
VS.
Shane D. Burger and
Shelley Lee Lawrence
Atty.: Thomas Puleo
DESCRIPTION
ALL THAT CERTAIN tract or par-
cel of land and premises, situate,
lying and being in the Township of
Lower Allen in the County of
Cumberland and Commonwealth of
Pennsylvania, more particularly de-
scribed as follows:
BEGINNING at a point on the
northeasterly line of Deerfield Road,
a 50 foot wide right-of-way, which
said point of beginning is located at
Editor
SWO1,N?TO AND SUBSCRIBED before me this
1 day of AUGUST, 2003
Ltd ?,? .. Irr
14
the intersection of the northeasterly
line of Deerfield Road and the di
viding line between Lots Nos. 7 and
8 on the Resubdivision plan ofAllen
dale, Section 9, recorded in Cumber
land County Plan Book "25. Page
133: thence. from said point of he
ginning along the north easterly line
of Deerfield Road, north 24 degrees
58 minutes 19 seconds west. 'a dis
tance of 100.00 feet to a point on
the dividing Iine between hots Nos
6 and 7: thence from said Point
along the dividing line betwecn hots
Nos. 6 and 7 north 65 degrees. I
minute 50 seconds east, a distawec
of 170.03 feet to a point: then(,(,
from said point, south 24 degrees
58 minutes 10 seconds east, a dis
lance of 10t).UO feet to P,i111, "11
the dividing line between Lots Nos.
7 and 8; thence from said point
along the dividing line between Lots
Nos. 7 and 8, south 65 degrees 1
minute 50 seconds west. a distance
of 170.03 feet to a point. the point
and place of beginning.
BEING Lot No. 7 on the Resin)
division Plan of Allendale.. Section,
9, recorded in the Office of (11(, Re
corder of Deeds of (,Ulrlberiand
County, Pennsylvamia, ill Plan Hook
"25", Page 13i
HAVING thereon erected ::z dwe11
ing house being known and num
tiered as premises 403 Deerfield
Road, Camp Hill, Pennsylvania.
Map #24-0809. Parcel 010.
1/517