HomeMy WebLinkAbout11-3529In the Court of Common Pleas of Cumberland County, Pennsylvania
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COURTYARDS OF CARLISLE ,
UNIT OWNERS ASSOCIATION, INC., .
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Plaintiff, -)a
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VS. tV
ANNA MARIE SALADIGO
and Foreclosure
DONALD L. GOSSARD
Defendants,
NOTICE
YOU HAVE BEEN SUED IN COURT. If you wish to defend against the
claims set forth in the following pages, you must take action within twenty (20)
days after this complaint and notice are served, by entering a written appearance
personally or by attorney and filing in writing with the court your defenses or
objections to the claims set forth against you. You are warned that if you fail to
do so the case may proceed without you and a judgment may be entered against
you by the court without further notice for any money claimed in the complaint or
for any other claim or relief requested by the plaintiff. YOU MAY LOSE MONEY
OR PROPERTY OR OTHER RIGHTS IMPORTANT TO YOU.
YOU SHOULD TAKE THIS PAPER TO YOUR LAWYER AT ONCE. IF
YOU DO NOT HAVE A LAWYER, GO TO OR TELEPHONE THE OFFICE SET
FORTH BELOW. THIS OFFICE CAN PROVIDE YOU WITH INFORMATIN
ABOUT HIRING A LAWYER.
IF YOU CANNOT AFFORD TO HIRE A LAWYER, THIS OFFICE MAY BE
ABLE TO PROVIDE YOU WITH INFORMAITON ABOUT AGENCIES THAT
MAY OFFER LEGAL SERVICES TO ELIGIBLE PERSONS AT A REDUCED
FEE OR NO FEE.
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AVISO PARA DEFENDER
Conforme a PA R.C.P. Num. 1018.1
Usted ha sido demandado/a en la corte. Si usted desea defenderse de
las demandas que se presentan mas adelante en las siguientes paginas, debe
tomar accion dentro de los proximos veinte (20) dias despu6s de la notificacibn
de esta Demanda y Aviso radicando personalmente o por medio de un abogado
una comparecencia escrita y radicando en la Corte por escrito sus defenses de,
y objecciones a, las demandas presentadas aqui en contra suya. Se le advierte
de que si usted falla de tomar accion como se describe anteriormente, el caso
puede proceder sin usted y un fallo por cualquier suma de dinero reclamada en
la demanda o cualquier otra reclamacion o remedio solicitado por el demandante
puede ser dictado en contra suya por la Corte sin mas aviso adicional.
USTED DEBE LLEVAR ESTE DOCUMENTO A SU ABOGADO
INMEDIATAMENTE. SI USTED NO TIENE UN ABOGADO, LLAME 0 VAYA A
LA SIGUIENTE OFICINA. ESTA OFICINA PUEDE PROVEERLE
INFORMACION A CERCA DE COMO CONSEGUIR UN ABOGADO.
SI USTED NO PUEDE PAGAR POR LOS SERVICIOS LEGALES SIN
CARGO 0 BAJO COSTO A PERSONAS QUE CUALIFICAN.
IF YOU DO NOT HAVE A LAWYER CONTACT:
CUMBERLAND COUNTY BAR ASSOCIATION
32 SOUTH BEDFORD STREET
CARLISLE, PA 17013
1-800-990-9108
717-249-3166
In the Court of Common Pleas of Cumberland County, Pennsylvania
COURTYARDS OF CARLISLE
UNIT OWNERS ASSOCIATION, INC.,
Plaintiff,
VS.
ANNA MARIE SALADIGO
and.
DONALD L. GOSSARD
Defendants,
COMPLAINT
No.
Foreclosure
AND NOW, comes the Plaintiff, COURTYARDS OF CARLISLE UNIT
OWNERS ASSOCIATION, INC., (hereinafter "Courtyards of Carlisle"), by and
through its attorneys, Saidis, Sullivan & Rogers and respectfully represents as
follows:
1. Plaintiff Courtyards of Carlisle, A Condominium Community, maintains
its principal office at 337 Lincoln Street, Carlisle, Pennsylvania, 17013.
2. Defendant, Anna Marie Saladigo, is an adult individual with a last
known residence of 93 Courtyard Drive, Carlisle, Pennsylvania, 17013.
3. Defendant, Donald L. Gossard, is an adult individual with a last known
residence of 711 North Hanover Street, Apt. F-104, Carlisle,
Pennsylvania 17013.
4. On or about July 7, 2005, the Defendants purchased a condominium
from COC Associates, as tenants in common. See Deed dated July 7,
2005, attached hereto and incorporated herein as Exhibit 1 ".
5. The Deed noted that the property is subject to a Declaration of
Condominium of The Courtyards of Carlisle, A Condominium
Community, (hereinafter "Declaration") which had been filed and
recorded at the Recorder of Deeds for Cumberland County on April 22,
1999 at Miscellaneous Book 610 Page 678.
6. The Declaration notes that the Plaintiff has the authority to set
assessments on each condominium. See relevant portions of
Declarations attached hereto and incorporated herein as Exhibit "2".
7. The payment of assessments represents each condominium owners'
contribution to maintain the various common areas, to maintain liability
insurance and to maintain other services provided by the Plaintiff to the
condominium owners.
8. Plaintiff has established monthly assessment fees for each
condominium based upon size and location of each individual
condominium.
9. The premises subject to the assessments and owned by the
Defendants is described in the Deed attached as Exhibit I ".
10. The monthly assessment for Defendants' condominium is one-hundred
twenty-one dollars ($121.00); although this monthly assessment is
subject to re-evaluation and potential increases at any time.
11. Plaintiff has been issuing a three dollar ($3.00) credit to Defendants
towards their monthly assessment since a common-area light is
connected to Defendants' electricity.
12. The Declaration also permits the collection of interest for any unpaid
assessments at the rate of 15 % per annum and the collection of
reasonable attorneys' fees for the collection of any assessment. See
Section X B of the Declarations attached hereto as Exhibit 2.
13. The Declaration also permits the assessment of late charges of up to
$150.00 per occurrence. Id.
14. Defendants are in default in that they have failed to pay monthly
assessments.
15. A condominium association may foreclose as a result of a unit owner's
failure to pay monthly association assessment dues. See 68
Pa.C.S.A. § 3315.
16. As of March 4, 2011, Defendants had an outstanding balance due of
six-thousand two-hundred forty-five dollars and seven cents
($6,245.07) which included past due assessments, last fees and partial
attorney's fees. This amount reflects fees due from March 2008
through March 2011. See Statement of Fees attached hereto and
incorporated herein as Exhibit "3."
17. Defendants' condominium unit continues to incur monthly assessment
fees.
18. To date Plaintiff has incurred six-thousand three-hundred forty-three
dollars and nine cents ($6,343.09) in attorney's fees and costs of suit.
19. Plaintiff continues to incur additional attorney's fees as costs as this
case continues.
20. Plaintiff sent notice to Defendant of its intention to file this foreclosure
complaint. See Notice of Intent to Foreclose and receipt of mailings
attached hereto as Exhibit 4.
WHEREFORE, Plaintiff demands an in rem judgment against Defendants
in the sum of $12,588.16 for unpaid assessments, costs, interest and
attorney's fees in addition to other costs and charges collectible for the
foreclosure and sale of the property subject to the Condominium
Declarations.
Respectfully submitted,
By.
Date
SAIDIS, SULWAN & ROGERS
0`e n E. osa
Attorney I. D. 80440
Attorney for Plaintiff
2109 Market Street
Camp Hill, PA 17011
Phone (717) 737-3405
Fax (717) 737-3407
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2005 JUL 18 HN 9 11.
DEED
MADE THE 7th day of July, in the year of our Lord Two Thousand Five (2005)
BETWEEN COC ASSOCIATES, A Pennsylvania Limited Partnership, hereinafter
(Grantor)
and ANNA MARIE SALADIGO AND DONALD L. GOSSARD, single persons,,
of Cumberland County, Pennsylvania, hereinafter
(Grantees)
WITNESSETH, that in consideration of One Hundred Fifty-five Thousand, Five
Hundred Fifty Dollars and 00/100 ($155,550.00) in hand paid, the receipt whereof
is hereby acknowledged, the said grantor does hereby grant and convey to the
said grantees, as tenants in common
ALL THAT CERTAIN Unit in the property known, named and identified in the
Declaration referred to below as "The Courtyards of Carlisle, A Condominium
Community", located in the Borough of Carlisle, County of Cumberland and
Commonwealth of Pennsylvania which has heretofore been submitted to the
provisions of the Pennsylvania Uniform Condominium Act, 68 Pa.C.S.A. Section
3101, et seq., by the recording in the Office of the Recorder of Deeds in and for
Cumberland County, Pennsylvania, of a Declaration dated February 26, 1999,
and recorded April 22, 1999, in Miscellaneous Book 610, Page 678, together with
all amendments and supplements thereto recorded on or before the date hereof
and designated as Unit No. 141 as more fully described in such Declaration,
together with the proportionate undivided interest in the Common Elements as
defined in such Declaration.
UNDER AND SUBJECT to any and all covenants, conditions, restrictions, rights of
way, easements and agreements of record including, but not limited to, those
contained in the Declaration and Declaration Plan.
BEING part of the some premises which James S. Hall, by Deed dated April 8,
1998 which Deed is recorded in the Office of the Recorder of Deeds in and for
Cumberland County in Deed Book 175, Page 88, granted and conveyer to C
Associates, a Pennsylvania Limited Partnership, Grantor herein.
900K 269 PAa47j.9
AND the said Grantor hereby covenants and agrees that it wil! warrant
specially the property hereby conveyed.
IN WITNESS WHEREOF, said grantor has hereunto set its hand and seal the
day and year above written.
SIGNED, SEALED AND DELIVERED
IN THE PRESENCE OFD
Eddie P
: COC ASSOCIATES,
: A PENNSYLVANI LIMI PARTNERSHIP
By: COC, IN , its s e g era] partner
By.
Eddie P. Droga esident
COMMONW LTH PENNSYLVANIA: _Qft COUNTY OF CUMVERLAND
SS
On this, the P% day of , 2005, before me a Notary Public,
the undersigned officer, personally a ar d Eddie P. Orogaris who acknowledged
himself to be the President of COC, Inc., the sole general partner of COC Associates, A
Pennsylvania Limited Partnership, and that he as such general partner being authorized
to do so, executed the foregoing instrument for the purposes therein contained by,,..
signing the name of the said Corporation by himself as such President.
IN WITNESS WHEREOF, I hereunto set my hand and official seal.
NpTARIAL SEAL
MELODY J. MARTIN, NOTARY PUBLr- _ .. ?,
WEST EARL 1WP., COUNTY OF LANCASTER ?
a ,
W COMMSSIOI EMRES AUGUST 27, 20
I do here y certify that the precis rdence and com,plete post office.. address of the within named grantee is ?V . r Cam' 7 ?- i PA 1 013 `
DATED:
Att ney for Grantee
COMMONWEALTH OF PENNSYLVANIA:
County of :ss
RECORDED on this day of _
A.D. 2005, in the Recorder's office of the
said County, in Deed Book Vol. ,
Page
Given under my hand and the seal of the said
office, the date above wditen.
Recorder.
BOOK 269 PACE4720
EXHIBIT "A"
ALL THAT CERTAIN Unit in the property known, named and identified in the
Declaration referred to below as "The Courtyards of Carlisle, A Condominium
Community", located in the Borough of Carlisle, County of Cumberland and
Commonwealth of Pennsylvania which has heretofore been submitted to the
provisions of the Pennsylvania Uniform Condominium Act, 68 Pa.C.S.A. Section
3101, et seq., by the recording in the Office of the Recorder of Deeds in and for
Cumberland County, Pennsylvania, of a Declaration dated February 26, 1999,
and recorded April 22, 1999, in Miscellaneous Book 610, Page 678, together with
all amendments and supplements thereto recorded on or before the date
hereof and designated as Unit No. 141 as more fully described in such
Declaration, together with the proportionate undivided interest in the Common
Elements as defined in such Declaration.
UNDER AND SUBJECT to any and all covenants, conditions, restrictions, rights of
way, easements and agreements of record including, but not limited to, those
contained in the Declaration and Declaration Plan.
1 Certify this to be recorded
In Cumberland County PA
Recorder of Deeds
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G:\UsersWis\CVit\courtyards.certificate. wpd:12/30/04
THE COURTYARDS OF CARLISLE, A CONDOMIMUM COMMUNITY
CERTIFICATE OF SUBSTANTIAL COMPLETION
I, Gary E. Weaver, of Tippetts, Weaver and Others Architects, Inc., certify as follows:
1. I am a Registered Architect, License No. X 11624, in the Commonwealth of
Pennsylvania.
2. This Certificate is given pursuant to Sections 3414(c) and (d) of the Pennsylvania
Uniform Condominium Act, Act of July 2, 1980, P.L. 286, No. 82, as amended, and pertains to The
Courtyards of Carlisle, A Condominium Community, located in the Borough of Carlisle,
Cumberland County, Pennsylvania. The Declarant is COC Associates, a Pennsylvania limited
partnership.
3. All structural components and common element mechanical systems of the structure
which contains Unit No. 141 of The Courtyards of Carlisle, A Condominium Community, are
substantially completed to the extent required of the Declarant so as to permit the use of such unit
and any limited common elements appurtenant thereto for their intended use and such unit is
substantially completed in accordance with the description set forth in the Declaration and Public
Offering Statement.
S WHEREOF,, this Certificate of Substantial
n e-y
is executed this ?e14
On this, the 7?!gday of , 20,L?,before me, a Notary Public, the
undersigned officer, personally appear d E. Weaver, known to me (or satisfactorily proven)
to be the person whose name is subscribe o the foregoing instrument and acknowledged that he
executed the same for the purposes therein contained.
`4, .IN WITNESS WHEREOF, I have hereunto set my hand and official seal.
•1! •i?y. .. •?4 y?y
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1
NOTARIAL SEAL
MELODY J. MARTIN, NOTARY PUBLIC
WEST EARL TWP„ COUNTY OF LANCASTER
MY COMMISSION EXPIRES AUGUST 27,2W5 /,/;x 76?
Notary P c
Rok 269 W*Lc '72
I
DECLARATION OF CONDOMINIUM OF
THE COURTY,k.DS OF CARLISLE. A CONDOMINIUM COIf1viUNTI? ?'
G. Limited Expense Assessments, as described in Article VI B. shall be levied.
assessed and collected in accordance with the provisions of this article.
XI
MORTGAGES ON UNITS
A. Requirements. Any mortgage or other lien on a Unit, and the obligations
secured thereby, shall be deemed to provide, generally, that the mortgage or other lien instrument
and that the rights and obligations of the parties thereto shall be subject to the terms and conditions
of the Act and this Declaration, including specifically Article XJX G hereof, and shall be deemed
to provide specifically, but without limitation, that the mortgagee or lien holder shall have no right:
1. To participate in the adjustment of losses with insurers or in the
decision as to whether or not or how to repair or restore damage to or destruction of the Property;
or
2. To receive or apply the proceeds of insurance to the reduction of the
mortgage debt or otherwise, except in the event and to the extent either of a distribution of such
proceeds to Unit Owners pursuant to Section 3312(8) of the Act or of insurance proceeds in excess
of the cost of repair or restoration being received by the owner of the Unit encumbered by such
mortgage; or
3'. To accelerate the mortgage debt or to have any other remedies by
virtue of waste or alleged waste or other conditions occurring anywhere on the Property other than
within the affected Unit, and the obligations secured shall be prepayable, without penalty, upon the
happening of any termination of the Condominium or determination not to restore or replace the
affected Unit.
Nothing contained in Article XI A, or elsewhere in this Declaration, shall give
a Unit Owner or any other party priority over any rights of the mortgagee of a Unit pursuant to its
mortgage in case ofa distribution to such Unit Owner ofinsurance proceeds or condemnation awards
for loss to or a taking of one or more Units and/or Common Elements.
B. Notice of Mortgages, No Unit Owner orprospectivepurchaser of a'Jnit shall
deliver any mortgage, or other lien insttvment secured by a Unit, unless it has first notified the Board
of the name and address of the proposed mortgagee, and the forms thereof and proposed mortgage
have been then or theretofore submitted to and approved by the Board as complying with the
provisions of this Article, which approval shall be promptly given or denied and shall not be
unreasonably withheld. Any such approved mortgage shall be deemed an "Eligible Mortgage".
When an Eligible Mortgage is delivered, the Unit Owner shall simultaneously provide executed or
16
COURTYARDS of CARLISLE UOA
c/o Sterling Property Management, Inc.
337 Lincoln Street
Carlisle, PA 17013
(717) 258-5800
To:
Anna Marie Saladigo
Donald L. Gossard
93 Courtyard Drive
Carlisle, PA 17013
Statement
Date
3/4/2011
Amount Due Amount Enc.
$6,245.07
Date Transaction Amount Balance
03/31/2006 Balance forward
04/01/2006
INV #2852. Due 04/01/2006. Monthly Association Fee - Outer Unit
108
28 -0.02
04/01/2006
CREDMEM #2859. Street Light .
-5
05 108.26
04/17/2006
INV #2931. Due 04/17/2006. 4/15/06 Finance Charge .
1
29 103.21
05/01/2006
INV #3065. Due 05/01/2006. Monthly Association Fee - Outer Unit .
108
28 104.50
05/01/2006
CREDMEM #3077. Street Light .
-5
05 212.78
05/09/2006
PMT #3109. SALADIGO .
-104
50 207.73
05/15/2006
INV #3144. Due 05/15/2006. Finance Charge .
1
29 103.23
06/01/2006
INV #3283. Due 06/01/2006. Monthly Association Fee - Outer Unit .
108
28 104.52
06/01/2006
CREDMEM #3297. Street Light . 212.80
06/09/2006
PMT #3120. Saladigo -5.05 207.75
06/20/2006
INV #3355. Due 06/20/2006. Finance Charge -104.52 103.23
07/01/2006
INV #3492. Due 07/01/2006. Monthly Association Fee - Outer Unit 1.29
108
28 104.52
07/01/2006
CREDMEM #3506. Street Light . 212.80
07/17/2006
INV #3583. Due 07/17/2006. 7/15/06 Finance Charge -5.05 207.75
08/01/2006
INV 43723. Due 08/01/2006. Monthly Association Fee - Outer Unit 2.60
108
28 210.35
08/01/2006
CREDMEM #3737. Street Light . 318.63
08/15/2006
PMT #3143. Saladigo -5.05 313.58
09/01/2006
INV #3928. Due 09/01/2006. Monthly Association Fee - Outer Unit -104.52
108
28 209.06
09/01/2006
CREDMEM #3942. Street Light . 317.34
09/15/2006
INV #4226. Due 09/15/2006. Finance Charge -5.05 312.29
10/01/2006
INV #4143. Due 10/01/2006. Monthly Association Fee - Outer Unit 3.90
108
28 316.19
10/01/2006
CREDMEM #4158. Street Light . 424.47
10/16/2006
INV #4236. Due 10/16/2006. October Finance Charge -5.05 419.42
11/01/2006
INV #4397. Due 11/01/2006. Monthly Association Fee - Outer Unit 5.24
108
28 424.66
11/01/2006
CREDMEM #4416. Street Light . 532.94
11/16/2006
INV #4468. Due 11/16/2006. November Finance Charge -5.05 527.89
12/01/2006
INV #4623. Due 12/01/2006. Monthly Association Fee - Outer Unit 6.60 534.49
12/01/2006
CREDMEM #4642. Street Light 108.28 642.77
12/18/2006
INV #4699. Due 12/18/2006. Finance Charge -5.05 637.72
01/01/2007
INV #4846. Due 01/01/2007. Monthly Association Fee - Outer Unit 7.97 645.69
01/01/2007
CREDMEM #4865. Street Light 118.40 764.09
01/18/2007
INV #4917. Due 01/18/2007. Late Fee -5.05 759.04
02/01/2007
INV #5066. Due 02/01/2007. Monthly Association Fee - Outer Unit 15.00 774.04
118.40 892.44
CURRENT 1-30 DAYS PAST 31-60 DAYS PAST 61-90 DAYS PAST OVER 90 DAYS
DUE DUE DUE PAST DUE Amount Due
0.00 15.00 0.00 15.00 6,215.07 $6,245.07
COURTYARDS of CARLISLE UOA
c/o Sterling Property Management, Inc.
337 Lincoln Street
Carlisle, PA 17013
(717) 258-5800
To:
Anna Marie Saladigo
Donald L. Gossard
93 Courtyard Drive
Carlisle, PA 17013
Statement
Date
3/4/2011
I Amount Due I Amount Enc.
$6,245.07
Date I Transaction
02/01/2007 CREDMEM #5085. Street Light
02/15/2007 INV #5139. Due 02/15/2007. Violation Fine
02/15/2007 INV #5140. Due 02/15/2007. Certified Mailing
02/19/2007 INV #5144. Due 02/19/2007. Late Fee
02/23/2007 INV #5159. Due 02/23/2007. Certified Letter
03/01/2007 INV #5296. Due 03/01/2007. Monthly Association Fee - Outer Unit
03/01/2007 CREDMEM #5315. Street Light
03/02/2007 INV #5364. Due 03/02/2007. 28th Late Fee
03/19/2007 INV #5377. Due 03/19/2007. Late Fee
04/01/2007 INV #5526. Due 04/01/2007. Monthly Association Fee - Outer Unit
04/01/2007 CREDMEM #5546. Street Light
04/25/2007 INV #5636. Due 04/25/2007. late fee
05/01/2007 INV #5776. Due 05/01/2007. Monthly Association Fee - Outer Unit
05/01/2007 CREDMEM #5824. Street Light
05/16/2007 INV #5881. Due 05/16/2007. late fee
05/30/2007 INV #6122. Due 05/30/2007. 30th late fee
06/01/2007 INV #6021. Due 06/01/2007. Monthly Association Fee - Outer Unit
06/01/2007 CREDMEM #6070. Street Light
06/15/2007 INV #6132. Due 06/15/2007. late fee
06/30/2007 INV #6374. Due 06/30/2007. late fee
07/01/2007 INV #6272. Due 07/01/2007. Monthly Association Fee - Outer Unit
07/01/2007 CREDMEM #6321. Street Light
07/16/2007 INV #6388. Due 07/16/2007. late fee
07/30/2007 INV #6633. Due 07/30/2007. 30th late fee
08/01/2007 INV #6530. Due 08/01/2007. Monthly Association Fee - Outer Unit
08/01/2007 CREDMEM #6579. Street Light
08/15/2007 INV #6646. Due 08/15/2007. late fee
08/30/2007 INV #6652. Due 08/30/2007. 30th late fee
09/01/2007 INV #6790. Due 09/01/2007. Monthly Association Fee - Outer Unit
09/01/2007 CREDMEM #6839. Street Light
09/17/2007 INV #6897. Due 09/17/2007. 15th late fee
10/01/2007 INV #7034. Due 10/01/2007. Monthly Association Fee - Outer Unit
10/01/2007 CREDMEM #7083. Street Light
10/01/2007 INV #7135. Due 10/01/2007. 30th late fee
Amount
-5.05
150.00
4.64
15.00
4.64
118.40
-5.05
15.00
15.00
118.40
-5.05
15.00
118.40
-5.05
15.00
15.00
118.40
-5.05
15.00
15.00
118.40
-5.05
15.00
15.00
118.40
-5.05
15.00
15.00
118.40
-5.05
15.00
118.40
-5.05
15.00
Balance
887.39
1,037.39
1,042.03
1,057.03
1,061.67
1,180.07
1,175.02
1,190.02
1,205.02
1,323.42
1,318.37
1,333.37
1,451.77
1,446.72
1,461.72
1,476.72
1,595.12
1,590.07
1,605.07
1,620.07
1,738.47
1,733.42
1,748.42
1,763.42
1,881.82
1,876.77
1,891.77
1,906.77
2,025.17
2,020.12
2,035.12
2,153.52
2,148.47
2,163.47
CURRENT 1-30 DAYS PAST 31-60 DAYS PAST 61-90 DAYS PAST OVER 90 DAYS
DUE DUE DUE PAST DUE Amount Due
0.00 15.00 0.00 15.00 6,215.07 $6,245.07
Page 2
COURTYARDS of CARLISLE UOA
c/o Sterling Property Management, Inc.
337 Lincoln Street
Carlisle, PA 17013
(717) 258-5800
To:
Anna Marie Saladigo
Donald L. Gossard
93 Courtyard Drive
Carlisle, PA 17013
Statement.
Date
3/4/2011
Amount Due Amount Enc.
$6,245.07
Date Transaction Amount Balance
10/15/2007 INV #7147. Due 10/15/2007. late fee 15.00 2,178.47
10/30/2007 INV #7386. Due 11/15/2006. 30th late fee 15.00 2,193.47
11/01/2007 INV #7286. Due 11/01/2007. Monthly Association Fee - Outer Unit 118.40 2,311.87
11/01/2007 CREDMEM #7335. Street Light -5.05 2,306.82
11/15/2007 INV #7641. Due 12/17/2007. late fee 15.00 2,321.82
11/30/2007 INV #7643. Due 11/30/2007. late fee 15.00 2
336.82
12/01/2007 INV #7531. Due 12/01/2007. Monthly Association Fee - Outer Unit 118.40 ,
2
455.22
12/01/2007 CREDMEM #7580. Street Light -5.05 ,
2
450.17
12/17/2007 INV #7644. Due 12/17/2007. late fee 15.00 ,
2
465.17
01/01/2008 INV #7788. Due 01/01/2008. Monthly Association Fee - Outer Unit 121.00 ,
2
586.17
01/01/2008 CREDMEM #7837. Street Light -5.05 ,
2
581.12
01/02/2008 INV #7646. Due 01/02/2008. 12/31 Late Fee 15.00 ,
2
596.12
01/15/2008 INV #7886. Due 01/15/2008. 15.00 ,
2
611.12
01/30/2008 INV #7892. Due 01/30/2008. 15.00 ,
2
626.12
02/01/2008 INV #8032. Due 02/01/2008. Monthly Association Fee - Outer Unit 121.00 ,
2
747.12
02/01/2008 CREDMEM #8080. Street Light -5.05 ,
2
742.07
02/15/2008 INV #8134. Due 02/15/2008. 15th Late Fee 15.00 ,
2
757
07
02/28/2008 INV #8149. Due 02/28/2008. DJ Judgment-CV-406-07 101.50 ,
.
2
858
57
03/01/2008 INV #8300. Due 03/01/2008. Monthly Association Fee - Outer Unit 121.00 ,
.
2
979
57
03/01/2008 CREDMEM #8348. Street Light -5.05 ,
.
2
974
52
03/17/2008 INV #8401. Due 03/17/2008. 15th Late Fee 15.00 ,
.
2
989
52
03/31/2008 INV #8413. Due 03/31/2008. 30th Late Fee 15
00 ,
.
04/01/2008
INV #8559. Due 04/01/2008. Monthly Association Fee - Outer Unit .
121
00 3,004.52
04/01/2008
CREDMEM #8607. Street Light .
-5
05 3,125.52
04/15/2008
INV #8661. Due 04/15/2008. Late Fee .
15
00 3,120.47
04/30/2008
INV #8681. Due 04/30/2008. 30th Late Fee .
15
00 3,135.47
05/01/2008
INV #8828. Due 05/01/2008. Monthly Association Fee - Outer Unit .
121
00 3,150.47
05/01/2008
CREDMEM #8876. Street Light .
-5
05 31271.47
05/15/2008 I
NV #8927. Due 05/15/2008. 15th Late Fee .
15
00 3,266.42
05/30/2008 I
NV #8940. Due 05/30/2008. 30th Fee .
15
00 3,281.42
06/01/2008 I
NV #9084. Due 06/01/2008. Monthly Association Fee - Outer Unit .
121
00 3,296.42
06/01/2008
CREDMEM #9132. Street Light .
-5
05 3,417.42
06/16/2008 I
NV #9181. Due 06/16/2008. 15th Late Fee .
15
00 3,412.37
07/01/2008 I
NV #9333. Due 07/01/2008. Monthly Association Fee - Outer Unit .
121
00 3,427.37
. 3,548.37
CURRENT 1-30 DAYS PAST 31-60 DAYS PAST 61-90 DAYS PAST OVER 90 DAYS
DUE DUE DUE PAST DUE Amount Due
0.00 15.00 0.00 15.00 6,215.07 $6,245.07
Page 3
COURTYARDS of CARLISLE UOA
c/o Sterling Property Management, Inc.
337 Lincoln Street
Carlisle, PA 17013
(717) 258-5800
To:
Anna Marie Saladigo
Donald L. Gossard
93 Courtyard Drive
Carlisle, PA 17013
Statement
Date
3/4/2011
Amount Due I Amount Enc.
$6,245.07
Date Transaction
07/01/2008 CREDMEM #9381. Street Light
07/01/2008 INV #9440. Due 07/01/2008. late fee
07/15/2008 INV #9441. Due 07/15/2008. 15th Late Fee
07/31/2008 INV #9703. Due 07/31/2008. late fee
08/01/2008 INV #9595. Due 08/01/2008. Monthly Association Fee - Outer Unit
08/01/2008 CREDMEM #9643. Street Light
08/15/2008 INV #9724. Due 08/15/2008. August 15th Late Fee
09/01/2008 INV #9871. Due 09/01/2008. Monthly Association Fee - Outer Unit
09/01/2008 CREDMEM #9919. Street Light
09/02/2008 INV #9975. Due 09/02/2008. August Late Fee
09/04/2008 INV #9968. Due 09/04/2008. Aug 30th Late Fees
09/30/2008 INV #9992. Due 09/30/2008. Late Fee for September 30th
10/01/2008 INV #10137. Due 10/01/2008. Monthly Association Fee - Outer Unit
10/01/2008 CREDMEM #10185. Street Light
10/15/2008 INV #10251. Due 10/15/2008. Late Fees - Oct 15th
10/31/2008 INV #10257. Due 10/31/2008. Late Fee - Oct 30th
11/01/2008 INV # 10402. Due 11/01/2008. Monthly Association Fee - Outer Unit
11/01/2008 CREDMEM # 10449. Street Light
11/17/2008 INV #10498. Due 11/17/2008. Late Fee
12/01/2008 INV # 10646. Due 12/01/2008. Monthly Association Fee - Outer Unit
12/01/2008 CREDMEM # 10693. Street Light
12/01/2008 INV #10742. Due 12/01/2008. Late Fees
12/02/2008 INV # 14356. Due 12/02/2008. DJ Filing CV-256-08
12/15/2008 INV #10752. Due 12/15/2008. Late Fee
12/30/2008 INV 411046. Due 12/30/2008. Late Fees
01/01/2009 INV # 11190. Due 01/01/2009. Monthly Association Fee - Outer Unit
01/01/2009 CREDMEM # 11237. Street Light
01/15/2009 INV 4 11287. Due 01/15/2009. Late Fee
01/30/2009 INV #11300. Due 01/30/2009. Late Fee
02/01/2009 INV # 11444. Due 02/01/2009. Monthly Association Fee - Outer Unit
02/01/2009 CREDMEM # 11491. Street Light
02/16/2009 INV #11541. Due 02/16/2009. Late Fees
02/28/2009 INV 412291. Due 02/28/2009. Late Fee
03/01/2009 INV # 11694. Due 03/01/2009. Monthly Association Fee - Outer Unit
Amount
-5.05
15.00
15.00
15.00
121.00
-5.05
15.00
121.00
-5.05
15.00
15.00
15.00
121.00
-5.05
15.00
15.00
121.00
-5.05
15.00
121.00
-5.05
15.00
89.00
15.00
15.00
121.00
-3.00
15.00
15.00
121.00
-3.00
15.00
15.00
121.00
Balance
3,543.32
3,558.32
3,573.32
3,588.32
3,709.32
3,704.27
3,719.27
3,840.27
3,835.22
3,850.22
3,865.22
3,880.22
4,001.22
3,996.17
4,011.17
4,026.17
4,147.17
4,142.12
4,157.12
4,278.12
4,273.07
4,288.07
4,377.07
4,3 92.07
4,407.07
4,528.07
4,525.07
4,540.07
4,555.07
4,676.07
4,673.07
4,688.07
4,703.07
4,824.07
CURRENT 1-30 DAYS PAST 31-60 DAYS PAST 61-90 DAYS PAST OVER 90 DAYS
DUE DUE DUE PAST DUE Amount Due
0.00 15.00 0.00 15.00 6,215.07 $6,245.07
Page 4
COURTYARDS of CARLISLE UOA
c/o Sterling Property Management, Inc.
337 Lincoln Street
Carlisle, PA 17013
(717) 258-5800
To:
Anna Marie Saladigo
Donald L. Gossard
93 Courtyard Drive
Carlisle, PA 17013
Statement
Date
3/4/2011
Amount Due Amount Enc.
$6,245.07
Date Transaction Amount Balance
03/01/2009 CREDMEM # 11741. Street Light -3.00 4,821.07
03/02/2009 INV #11553. Due 03/02/2009. late fees 15.00 4,836.07
03/16/2009 INV #11790. Due 03/16/2009. Late Fee 15.00 4,851.07
04/01/2009 INV #11942. Due 04/01/2009. Monthly Association Fee - Outer Unit 121.00 4,972.07
04/01/2009 CREDMEM #11989. Street Light -3.00 4,969.07
04/15/2009 INV # 12038. Due 04/15/2009. Late Fee 15.00 4,984.07
04/30/2009 INV # 12290. Due 04/30/2009. Late Fee 15.00 4,999.07
05/01/2009 INV # 12187. Due 05/01/2009. Monthly Association Fee - Outer Unit 121.00 5,120.07
05/01/2009 CREDMEM # 12234. Street Light -3.00 5,117.07
05/15/2009 INV # 12285. Due 05/15/2009. Late Fee 15.00 5,132.07
06/01/2009 INV #12303. Due 06/01/2009. Late Fee 15.00 51147.07
06/01/2009 INV #12444. Due 06/01/2009. Monthly Association Fee - Outer Unit 121.00 5
268.07
06/01/2009 CREDMEM #12491. Street Light -3.00 ,
5,265.07
06/15/2009 INV #12541. Due 06/15/2009. Late Fees 15.00 5
280.07
06/30/2009 INV # 13262. Due 06/30/2009. 15.00 1
5
295.07
07/01/2009 INV # 12641. Due 07/01/2009. Monthly Association Fee - Outer Unit 121.00 1
5
416.07
07/01/2009 CREDMEM #12732. Street Light -3.00 ,
5
413.07
07/15/2009 INV #13263. Due 07/15/2009. 15.00 ,
5
428.07
07/30/2009 INV #13264. Due 07/30/2009. 15.00 1
5
443.07
08/01/2009 INV # 12880. Due 08/01/2009. Monthly Association Fee - Outer Unit 121.00 ,
5
564
07
08/01/2009 CREDMEM # 12971. Street Light -3.00 ,
.
5
561
07
08/17/2009 INV #13265. Due 08/17/2009. 15.00 ,
.
5
576
07
08/31/2009 INV #13266. Due 08/31/2009. 15.00 ,
.
5
591
07
09/01/2009 INV # 13164. Due 09/01/2009. Monthly Association Fee - Outer Unit 121.00 ,
.
5
712
07
09/01/2009 CREDMEM # 13211. Street Light -3.00 ,
.
5
709
07
09/15/2009 INV #13267. Due 09/15/2009. 15.00 ,
.
5
724
07
09/16/2009 INV # 13261. Due 09/16/2009. owner search 46.00 ,
.
5
770
07
10/01/2009 INV #13466. Due 10/01/2009. Monthly Association Fee - Outer Unit 121.00 ,
.
5
891
07
10/01/2009 CREDMEM # 13513. Street Light -3
00 ,
.
10/01/2009
INV #13562. Due 10/01/2009. .
15
00 5,888.07
10/16/2009
INV #13574. Due 10/16/2009. .
15
00 5,903.07
11/01/2009
INV # 13727. Due 11/01/2009. Monthly Association Fee - Outer Unit .
121.00 5,918.07
6
039
07
11/01/2009 CREDMEM # 13774. Street Light -3
00 ,
.
11/01/2009
INV #13823. Due 11/01/2009. .
15
00 6,036.07
. 6,051.07
CURRENT 1-30 DAYS PAST 31-60 DAYS PAST 61-90 DAYS PAST OVER 90 DAYS
DUE DUE DUE PAST DUE Amount Due
0.00 15.00 0.00 15.00 6,215.07 $6,245.07
Page 5
COURTYARDS of CARLISLE UOA
c/o Sterling Property Management, Inc.
337 Lincoln Street
Carlisle, PA 17013
(717) 258-5800
To:
Anna Marie Saladigo
Donald L. Gossard
93 Courtyard Drive
Carlisle, PA 17013
Statement
Date
3/4/2011
Amount Due Amount Enc.
$6,245.07
Date Transaction Amount Balance
11/16/2009 INV #13839. Due 11/16/2009. 15.00 6
066
07
11/30/2009 INV #14087. Due 11/30/2009. ,
.
15.00 6
081
07
12/01/2009 INV #13991. Due 12/01/2009. Monthly Association Fee - Outer Unit ,
.
121.00 6
202
07
12/01/2009 CREDMEM # 1403 8. Street Light ,
.
-3.00 6
199
07
12/15/2009 INV #14102. Due 12/15/2009. 30th Late fee ,
.
15.00 6
214
07
12/30/2009 INV # 14110. Due 12/30/2009. 30th late fee ,
.
15.00 6
229
07
01/01/2010 INV #14260. Due 01/01/2010. Monthly Association Fee - Outer Unit ,
.
121
00
01/01/2010
CREDMEM # 14307. Street Light .
6,350.07
-3
00
01/16/2010
INV #14357. Due 01/16/2010. 15th late fee .
6,347.07
15
00
01/30/2010
INV #14605. Due 01/30/2010. 30th late fee .
6,362.07
15
00
02/01/2010
INV #14508. Due 02/01/2010. Monthly Association Fee - Outer Unit .
6,377.07
121
00
02/01/2010
CREDMEM # 14555. Street Light .
6,498.07
-3
00
02/16/2010
INV #14622. Due 02/16/2010. 15th late fee .
6,495.07
15
00
02/28/2010
INV #14868. Due 02/28/2010. 30th late fee .
6,510.07
15
00
03/01/2010
INV # 14772. Due 03/01/2010. Monthly Association Fee - Outer Unit .
6,525.07
121
00
03/01/2010
CREDMEM #14819. Street Light .
6,646.07
-3
00
03/15/2010
INV #14879. Due 03/15/2010. 15th late fee .
6,643.07
15
00
03/31/2010
INV # 15134. Due 03/31/2010. 3/30/10 Late Fee .
6,658.07
15
00
04/01/2010
CREDMEM # 14944. Street Light .
6,673.07
04/01/2010
INV # 15129. Due 04/01/2010. Monthly Association Fee - Outer Unit -3.00 6,670.07
121
00
04/15/2010
INV #15150. Due 04/15/2010. Attorney fees & costs .
6,791.07
04/16/2010
INV #15139. Due 04/16/2010
Late Fee 710.00 7,501.07
04/30/2010 .
INV #15395. Due 04/30/2010
Late Fee 15.00 7,516.07
04/30/2010 .
INV #15408. Due 04/30/2010
30th Late fee 15.00 7,531.07
04/30/2010 .
INV #15409. Due 04/30/2010
30th Late fee 15.00 7,546.07
05/01/2010 .
CREDMEM # 15197. Street Light 15.00 7,561.07
05/01/2010
INV #15338. Due 05/01/2010. Monthly Association Fee - Outer Unit -3.00 7,558.07
121
00
05/17/2010
INV # 15399. Due 05/17/2010
15th Late Fee .
7,679.07
06/01/2010 .
INV #15546. Due 06/01/2010. Monthly Association Fee - Outer Unit 15.00 7,694.07
121
00
06/01/2010
CREDMEM # 15593. Street Light .
7,815.07
06/01/2010
INV #15642. Due 06/01/2010
30th Late Fee -3.00 7,812.07
06/15/2010 .
INV #15651. Due 06/15/2010
15th Late Fee 15.00 7,827.07
06/30/2010 .
INV #15659. Due 06/30/2010
30th Late Fee 15.00 7,842.07
07/01/2010 .
INV #15800. Due 07/01/2010. Monthly Association Fee -Outer Unit 15.00 7,857.07
121
00
.
7,978.07
1-30 DAYS PAST
CURRENT 31-60 DAYS PAST 61-90 DAYS PAST OVER 90 DAYS
DUE DUE DUE PAST DUE Amount Due
0.00 15.00 0.00 15.00 6,215.07 $6,245.07
Page 6
COURTYARDS of CARLISLE UOA
c/o Sterling Property Management, Inc.
337 Lincoln Street
Carlisle, PA 17013
(717) 258-5800
To:
Anna Marie Saladigo
Donald L. Gossard
93 Courtyard Drive
Carlisle, PA 17013
Statement
Date
3/4/2011
Amount Due Amount Enc.
$6,245.07
Date Transaction Amount Balance
07/01/2010 CREDMEM # 15847. Street Light -3
00
07/15/2010
INV #15898. Due 07/15/2010. 15th Late Fee .
15
00 7,975.07
07/30/2010
INV # 15906. Due 07/30/2010. 30th Late Fee .
15
00 7,990.07
08/01/2010
INV # 16046. Due 08/01/2010. Monthly Association Fee - Outer Unit .
121
00 8,005.07
08/01/2010
CREDMEM # 16093. Street Light .
-3
00 8,126.07
08/16/2010
INV # 16377. Due 08/16/2010. Aug. Late Fee .
15
00 8,123.07
08/31/2010
INV # 16401. Due 08/31/2010. 8/30/10 Late Fee .
15
00 8,138.07
09/01/2010
INV #16278. Due 09/01/2010. Monthly Association Fee - Outer Unit .
121
00 8,153.07
09/01/2010
CREDMEM # 16325. Street Light .
-3
00 8,274.07
09/20/2010
INV #16403. Due 09/20/2010. 9/15/10 Late Fee .
15
00 8,271.07
10/01/2010
INV # 16545. Due 10/01/2010. Monthly Association Fee - Outer Unit .
121
00 8,286.07
10/01/2010
CREDMEM # 16592. Street Light .
-3
00 8,407.07
10/04/2010
INV #16648. Due 10/04/2010. Late Fees Sept. 2010 .
15
00 8,404.07
10/18/2010
INV #16651. Due 10/18/2010. Late Fee Oct. 2010 .
15
00 8,419.07
11/01/2010
INV # 16794. Due 11/01/2010. Monthly Association Fee - Outer Unit .
121
00 8,434.07
11/01/2010
CREDMEM # 16841. Street Light . 8,555.07
11/05/2010
INV #16896. Due 11/05/2010
10/31/10 Late Fee -3.00 8,552.07
11/15/2010 .
INV #16901. Due 11/15/2010. 11/15/2010 Late Fee 15.00
15
00 8,567.07
11/30/2010
INV # 16905. Due 11/30/2010. November 30 2010 Late Fees . 8,582.07
12/01/2010
INV # 17047. Due 12/01/2010. Monthly Association Fee - Outer Unit 15.00
121
00 8,597.07
12/01/2010
CREDMEM # 17094. Street Light . 8,718.07
12/15/2010
INV #17150. Due 12/15/2010. Late Fees Dec
15th 2010 -3.00 8,715.07
01/01/2011 .
INV #17289. Due 01/01/2011. Monthly Association Fee - Outer Unit 15.00
121
00 8,730.07
01/01/2011
CREDMEM #17336. Street Light . 8,851.07
01/03/2011
INV #17387. Due 01/03/2011. Dec. 30th 2010 Late Fee -3.00 8,848.07
01/18/2011
INV #17393. Due 01/18/2011. Jan
15th Late Fee 15.00 8,863.07
02/01/2011 .
INV # 17531. Due 02/01/2011. Monthly Association Fee - Outer Unit 15.00
121
00 8,878.07
02/01/2011
CREDMEM # 17578. Street Light . 8,999.07
02/02/2011
INV 4 17627. Due 02/02/2011. Jan 30th Late Fee -3.00 8,996.07
02/04/2011
INV # 17631. Due 02/04/2011. Exterior Violations - Clutter, Lattice, etc. 15.00
50
00 9,011.07
02/15/2011
INV # 17632. Due 02/15/2011. Feb. 15th 2011 Late Fee .
15
00 9,061.07
03/01/2011
INV #17773. Due 03/01/2011. Monthly Association Fee - Outer Unit .
121
00 9,076.07
03/01/2011
CREDMEM # 17820. Street Light . 9,197.07
03/01/2011
INV #17874. Due 03/01/2011. Feb. 28th 2011 Late Fee -3.00 9,194.07
15.00 9,209.07
CURRENT 1-30 DAYS PAST 31-60 DAYS PAST 61-90 DAYS PAST OVER 90 DAYS
DUE DUE DUE PAST DUE Amount Due
0.00 15.00 0.00 15.00 6,215.07 $6,245, 07
Page 7
COURTYARDS of CARLISLE UOA
c/o Sterling Property Management, Inc.
337 Lincoln Street
Carlisle, PA 17013
(717) 258-5800
To:
Anna Marie Saladigo
Donald L. Gossard
93 Courtyard Drive
Carlisle, PA 17013
Statement
Date
3/4/2011
Amount Due Amount Enc.
$6,245.07
Date Transaction Amount Balance
03/03/2011 PMT #5660. Saladigo -148.00 9,061.07
03/03/2011 PMT #5663. Saladigo -50.00 9,011.07
03/03/2011 PMT#5661. Saladigo -148.00 8,863.07
03/03/2011 PMT #5662. Saladigo -118.00 8,745.07
03/03/2011 PMT #5664. Saladigo -2,500.00 6,245.07
CURRENT 1-30 DAYS PAST 31-60 DAYS PAST 61-90 DAYS PAST OVER 90 DAYS
DUE DUE DUE PAST DUE Amount Due
0.00 15.00 0.00 15.00 6,215.07 $6,245.07
Page 8
Notice of Intention to Foreclose pursuant to 68 Pa C S A § 3315
TO
Re
Anna Marie Saladigo
93 Courtyard Drive
Carlisle, PA 17013
Donald Gossard
17 N. Hanover St., Apt. F-104
Carlisle, PA 17013
Foreclosure due to failure to pay condominium assessment fees pursuant to 68
Pa.C.S.A. § 3315
Premises: 93 Courtyard Drive, Carlisle PA 17013
Notice of Intention to Foreclose:
The deed by which you took title the property noted that it was subject to a
Declaration of Condominium of Courtyards of Carlisle, A Condominium Community,
filed and recorded on April 22, 1999. These Declarations provide the Board of Directors
with the authority to fix monthly assessments on each condominium unit. You are in
default and therefore subject to foreclosure for the following reason:
1. Failure to pay your monthly assessment from April 6, 2006 through the
present - a statement of the outstanding assessments is attached to this notice for your
convenience.
The total amount now required to cure this default or, in other words, to get
caught up in your payments to this date is $8,863.07.
You may cure this default within thirty (30) days of the date of this letter, by
paying to us the above amount of $8,863.07, plus any additional monthly payments and
late charges which may fall due during this period. Such payment must be made in the
form of certified check, cashier's check or money order, and made at 26 W. High Street,
Carlisle, PA 17013.
If you do not cure the default within thirty (30) days, the Courtyard of Carlisle
intends to exercise its right to foreclose on the property pursuant to 68 Pa.C.S.A. §
3315. If full payment of the amount of default is not made within thirty (30) days, the
Courtyard of Carlisle intends to instruct its attorneys to start a lawsuit to foreclose your
property. If your property is foreclosed, your mortgaged property may be sold by the
Sheriff to pay off the debt. If we refer your case to our attorneys, but you cure the
default before they begin legal proceedings against you, you will still have to pay the
reasonable attorney's fees. Any attorney's fees will be added to whatever you owe us,
which may also include our reasonable costs.
We may also sue you personally for the unpaid principal balance and all other
sums due under the agreement. If you have not cured the default within the thirt J-
period and foreclosure proceedings have begun,
default and prevent the sale at any time up to one
y y
you still have the right to cure the
hour before the Sheriff's foreclosurp
sale. You may do so by paying the total amount of the unpaid monthly assessments
plus any late or other charges then due, as well as the reasonable attorney's fees and
costs connected with the foreclosure sale. It is estimated that the earliest date that such
a Sheriff's sale could be held would be approximately June 11, 2011. A notice of the
date of the Sheriff sale will be sent to you before the sale. Of course, the amount
needed to cure the default will increase the longer you wait. You may find out at any
time exactly what the required payment will be by calling us at the following telephone
number: (717) 243-6222.
This payment must be in cash, cashier's check, certified check or money order and
made payable to Courtyards of Carlisle at the address stated above.
You should realize that a Sheriff's sale will end your ownership of the property and your
right to remain in it. If you continue to live in the property after the Sheriff's sale, a
lawsuit could be started to evict you.
You have additional rights to help protect your interest in the property. YOU HAVE THE
RIGHT TO SELL THE PROPERTY TO OBTAIN MONEY TO PAY OFF THE DEBT, OR
TO BORROW MONEY FROM ANOTHER LENDING INSTITUTION TO PAY OFF THIS
DEBT. YOU MAY HAVE THE RIGHT TO SELL OR TRANSFER THE PROPERTY
SUBJECT TO THE DEBT TO A BUYER OR TRANSFEREE WHO WILL ASSUME THE
DEBT, PROVIDED THAT ALL THE OUTSTANDING PAYMENTS, CHARGES AND
ATTORNEY'S FEES AND COSTS ARE PAID PRIOR TO OR AT THE SALE, AND
THAT THE OTHER REQUIREMENTS UNDER THE AGREEMENT ARE SATISFIED.
CONTACT US TO DETERMINE UNDER WHAT CIRCUMSTANCES THIS RIGHT
MIGHT EXIST. YOU HAVE THE RIGHT TO HAVE THIS DEFAULT CURED BY ANY
THIRD PARTY ACTING ON YOUR BEHALF.
If you cure the default, assessments will continue to accrue as if no default had
occurred.
Date: 4-? 3j ;-Z)//
Courtyards of Carlisle Unit Owners
Donald H. Cutlip, President
Association, In
2
VERIFICATION
I, Donald H. Cutlip, hereby verify I am authorized to make this verification
on behalf of Courtyards of Carlisle Unit Owners Association, Inc., and that the
statements made in the foregoing document are true and correct to the best of
my information, knowledge 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.
Courtyards of Carlisle Unit Owners Association, Inc.
F? 7
By
Donald H. Cutlip
Date:Ad- _,2 - 2011
IN THE COURT OF COMMON PLEAS OF
CUMBERLAND COUNTY, PENNSYLVANIA
COURTYARDS OF CARLISLE UNIT
OWNERS ASSOCIATION, INC.,
Plaintiff
v.
ANNA MARIE SALADIGO and
DONALD L. GOSSARD,
Defendants
NO. 11-3529 CIVIL TERM
FORECLOSURE
NOTICE OF JUDGMENT BY DEFAULT AGAINST DEFENDANT
ANNA MARIE SALADIGO
Pursuant to Pa. R.C.P. 236, you are hereby notified that a JUDGMENT BY DEFAULT
has been entered against Defendant, Anna Marie Saladigo in the above proceeding.
JRT VOY? June --J30 2011
If you have any questions concerning this Notice, please contact Attorney Dean E.
Reynosa, with the law firm of Saidis Sullivan Law, Attorney for Plaintiff, (717) 243-6222.
IN THE COURT OF COMMON PLEAS OF
CUMBERLAND COUNTY, PENNSYLVANIA
COURTYARDS OF CARLISLE UNIT
OWNERS ASSOCIATION, INC., ,
Plaintiff
V.
ANNA MARIE SALADIGO and
DONALD L. GOSSARD,
Defendants
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NO. 11-3529 CIVIL TER1S%Q
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FORECLOSURE
PRAECIPE FOR ENTRY OF JUDGMENT OF DEFAULT
TO THE PROTHONOTARY:
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Kindly enter an in rem judgment in favor of Plaintiff and against Defendant, Anna
Marie Saladigo, for failure to file an Answer to Plaintiffs Complaint within twenty (20)
days from service thereof and for foreclose pursuant to 68 Pa. C.S.A. §3315.
Please assess damages as follows: An in rem judgment is entered in favor of
Plaintiff and against Defendant, Anna Marie Saladigo, in the amount of $12,588.16 plus
interest.
Attached as Exhibit A is a copy of Plaintiff's written notice in accordance with
Rule 237.1, which I certify was mailed by regular mail to Defendant Anna Marie
Saladigo at her last known address 93 Courtyard Drive, Carlisle, PA 17013 which is at least
ten (10) days prior to the filing of this Praecipe.
Damages as assessed above:
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Prothonotary
Respectfully submitted,
SAIDIS, SULLIVAN &
By:
n s and nosa, Esquire
PA Sup. Ct. #80440
26 West High Street
Carlisle, PA 17013
(717) 243-6222
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In the Court of Common Pleas of Cumberland County, Pennsylvania
COURTYARDS OF CARLISLE UNIT
OWNERS ASSOCIATION, INC.,
Plaintiff
V. NO. 11-3529 CIVIL TERM
ANNA MARIE SALADIGO and
DONALD L. GOSSARD,
Defendants CIVIL ACTION - LAW
TO: Anna Marie Saladigo
93 Courtyard Drive
Carlisle, PA 17013
DATE OF NOTICE: May 27, 2011
IMPORTANT TEN DAY 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 (10) DAYS FROM THE DATE OF THIS NOTICE, A JUDGMENT MAY BE
ENTERED AGAINST YOU WITHOUT A HEARING, AND YOU MAY LOSE YOUR PROPERTY OR
OTHER IMPORTANT RIGHTS.
YOU SHOULD TAKE THIS PAPER TO YOUR LAWYER AT ONCE. IF YOU DO NOT HAVE
A LAWYER, GO TO OR TELEPHONE THE OFFICE SET FORTH BELOW. THIS OFFICE CAN
PROVIDE YOU WITH INFORMATION ABOUT HIRING A LAWYER.
IF YOU CANNOT AFFORD TO HIRE A LAWYER, THIS OFFICE MAY BE ABLE TO
PROVIDE YOU WITH INFORMATION ABOUT AGENCIES THAT MAY OFFER LEGAL SERVICES
TO ELIGIBLE PERSONS AT A REDUCED FEE OR NO FEE.
CUMBERLAND COUNTY LAWYER REFERRAL SERVICE
32 SOUTH BEDFORD STREET
CARLISLE, PA 17013
1-800-990-9108
Respectfully submitted,
SAIDIS, SULLIVAN & ROGERS
By:
Carlisle, PA 17013
Phone: (717) 243-6222
Fax: (717)24')-6486
Attorney for Plaintiff
CERTIFICATE OF SERVICE
I hereby certify that on this day of June, 2011, a true and correct copy of the
foregoing document was served upon the party listed below, via First Class Mail, postage
prepaid, addressed as follows:
Anna Marie Saladigo
93 Courtyard Drive
Carlisle, PA 17013
Donald L. Gossard
17 North Hanover Street, Apt. F-104
Carlisle, PA 17013
SAIDIS, S)ILLIVAN & ROGERS
DePn Esquire
Attorney Id. 8044
26 West High Street
Carlisle, PA 17013
717-243-6222
IN THE COURT OF COMMON PLEAS OF
CUMBERLAND COUNTY, PENNSYLVANIA
COURTYARDS OF CARLISLE UNIT
OWNERS ASSOCIATION, INC.,
Plaintiff
V.
ANNA MARIE SALADIGO and
DONALD L. GOSSARD,
Defendants
NO. 11-3529 CIVIL TERM
FORECLOSURE
NOTICE OF JUDGMENT BY DEFAULT AGAINST DEFENDANT
DONALD L. GOSSARD
Pursuant to Pa. R.C.P. 236, you are hereby notified that a JUDGMENT BY DEFAULT
has been entered against Defendant, Donald L. Gossard in the above proceeding.
IA6 June t3t'_, 2011
JOTHONOTARY
If you have any questions concerning this Notice, please contact Attorney Dean E.
Reynosa, with the law firm of Saidis Sullivan Law, Attorney for Plaintiff, (717) 243-6222.
IN THE COURT OF COMMON PLEAS OF
CUMBERLAND COUNTY, PENNSYLVANIA
COURTYARDS OF CARLISLE UNIT :
OWNERS ASSOCIATION, INC.,
Plaintiff
V.
ANNA MARIE SALADIGO and
DONALD L. GOSSARD,
Defendants
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NO. 11-3529 CIVIL TERArp-°
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FORECLOSURE
PRAECIPE FOR ENTRY OF JUDGMENT OF DEFAULT
TO THE PROTHONOTARY:
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Kindly enter an in rem judgment in favor of Plaintiff and against Defendant,
Donald Gossard, for failure to file an Answer to Plaintiff's Complaint within twenty (20)
days from service thereof and for foreclose pursuant to 68 Pa. C.S.A. §3315.
Please assess damages as follows: An in rem judgment is entered in favor of
Plaintiff and against Defendant, Donald Gossard, in the amount of $12,588.16 plus
interest.
Attached as Exhibit A is a copy of Plaintiff's written notice in accordance with
Rule 237.1, which I certify was mailed by regular mail to Defendant Donald Gossard at
his last known address 17 North Hanover Street, Apt. F-104, Carlisle, PA 17013 which is at
least ten (10) days prior to the filing of this Praecipe.
Damages as assessed above:
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Jtot
WOO-
Respectfully submitted,
SAIDIS, AN & ROGERS
By:
Dean E. Reynosit, Esquire
PA Sup. Ct. #80440
26 West High Street
Carlisle, PA 17013
(717) 243-6222
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In the Court of Common Pleas of Cumberland County, Pennsylvania
COURTYARDS OF CARLISLE UNIT
OWNERS ASSOCIATION, INC.,
Plaintiff
v.
ANNA MARIE SALADIGO and
DONALD L. GOSSARD,
Defendants
TO: Donald L. Gossard
17 North Hanover Street, Apt. F-104
Carlisle, PA 17013
DATE OF NOTICE: May 19, 2011
NO. 11-3529 CIVIL TERM
CIVIL ACTION - LAW
IMPORTANT TEN DAY 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 (10) DAYS FROM THE DATE OF THIS NOTICE, A JUDGMENT MAY BE
ENTERED AGAINST YOU WITHOUT A HEARING, AND YOU MAY LOSE YOUR PROPERTY OR
OTHER IMPORTANT RIGHTS.
YOU SHOULD TAKE THIS PAPER TO YOUR LAWYER AT ONCE. IF YOU DO NOT HAVE
A LAWYER, GO TO OR TELEPHONE THE OFFICE SET FORTH BELOW. THIS OFFICE CAN
PROVIDE YOU WITH INFORMATION ABOUT HIRING A LAWYER.
IF YOU CANNOT AFFORD TO HIRE A LAWYER, THIS OFFICE MAY BE ABLE TO
PROVIDE YOU WITH INFORMATION ABOUT AGENCIES THAT MAY OFFER LEGAL SERVICES
TO ELIGIBLE PERSONS AT A REDUCED FEE OR NO FEE.
CUMBERLAND COUNTY LAWYER REFERRAL SERVICE
32 SOUTH BEDFORD STREET
CARLISLE, PA 17013
1-800-990-9108
Respectfully submitted,
SAIDIS, SULLIVAN & ROGERS
By:
Dean E. Reynosa
Attorney I.D. 80440
26 West High Street
Carlisle, PA 17013
Phone: (717) 243-6222
Fax: (717) 243-6486
Attorney for Plaintiff
CERTIFICATE OF SERVICE
I hereby certify that on this /3 6 day of June, 2011, a true and correct copy of the
foregoing document was served upon the party listed below, via First Class Mail, postage
prepaid, addressed as follows:
Anna Marie Saladigo
93 Courtyard Drive
Carlisle, PA 17013
Donald L. Gossard
17 North Hanover Street, Apt. F-104
Carlisle, PA 17013
SAIDIS, SULLIVAN & ROGERS
Datin E.-Re-yno Esquire
Attorney Id. 8044
26 West High Street
Carlisle, PA 17013
717-243-6222
WRIT OF EXECUTION and/or ATTACHMENT
COMMONWEALTH OF PENNSYLVANIA)
COUNTY OF CUMBERLAND)
NOII-3529 Civil
CIVIL ACTION - LAW
TO THE SHERIFF OF CUMBERLAND COUNTY:
To satisfy the debt, interest and costs due COURTYARDS OF CARLISLE UNIT OWNERS
ASSOCIATION, INC. Plaintiff (s)
From ANNA MARIE SALADIGO AND DONALD L GOSSARD
(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: $12,588.16
Interest $275.31
Arty's Comm: %
Atty Paid: $214.94
Plaintiff Paid:
I]ate 12/1/2011
L.L.: $.50
Due Prothy: $2.00
Other Costs:
- JJ
avid D. Buell, (Seal)
By:
Deputy
REQUESTING PARTY:
Name: DEAN E. REYNOSA, ESQUIRE
Address: 2109 MARKET STREET
CAMP HILL, PA 17011
Attorney for: PLAINTIFF
Telephone: 717-737-3405
Supreme Court ID No. 80440
In the Court of Common Pleas of Cumberland County, Pennsylvania
COURTYARDS OF CARLISLE UNIT
OWNERS ASSOCIATION, INC.,
Plaintiff
V. NO. 11-3529 CIVIL TERM
ANNA MARIE SALADIGO and
DONALD L. GOSSARD,
Defendants FORECLOSURE rnCo a,----
rn
PRAECIPE FOR A WRIT OF EXECUTION
QJ
(MORTGAGE FORECLOSURE)
To the Prothonotary:
Please issue a writ of execution against both Defendants in the above matter (a
description of the property is attached hereto as Exhibit A):
Amount Due:
Interest:
Costs to be added:
GJ"
1o8??Y CBF
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$12,588.16
$ 275.31
$ 1,524.00
SAIDIS SULLIVAN &ROGERS
f
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De l=. Reynosa, Esquire
26 West High Street
Carlisle, PA 17013
(717) 243-6222
Attorney for Plaintiff
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In the Court of Common Pleas of Cumberland County, Pennsylvania
COURTYARDS OF CARLISLE UNIT
OWNERS ASSOCIATION, INC.,
Plaintiff
V.
ANNA MARIE SALADIGO and
DONALD L. GOSSARD,
Defendants
;'TJ
r
NO. 11-3529 CIVIL TERM fi
,
FORECLOSURE
AFFIDAVIT PURSUANT TO RULE 3129.1
Courtyards of Carlisle Unit Owners Association, Inc., Plaintiff in the above action,
sets forth that as of the date the Praecipe for the Writ of Execution was filed the
following information concerning the real property located at 93 Courtyard
Drive,Carlisle, PA 17013:.
Description of Property: The most recent Deed found at Book 269, Page 4719
in the Recorder of Deeds Office is attached hereto as Exhibit A.
1) Name and addresses of owners or reputed owners:
Anna Marie Saladigo and Donald L. Gossard
93 Courtyard Drive 711 N. Hanover Street, Apt. F-104
Carlisle, PA 17013 Carlisle, PA 17013
2) Name and addresses of Defendants in the judgment:
Same as above.
3) Name and address of every judgment creditor whose judgment is a
record lien on the real property to be sold
Plaintiff herein.
w
4) Name and address of the last recorded holder of every mortgage of
record:
Primary Residential Mortgage Inc.
4750 West Wiley Post Way #200
Salt Lake City, UT 84116
5) Name and address of every other person who has any record lien on the
property:
None known other than as stated above.
6) Name and address of every other person who has any record interest in
the property and whose interest may be affected by the sale:
None known other than those identified above.
7) Name and address of every other person of whom plaintiff has
knowledge who has any interest in the property which may be affected
by the sale:
None known other than those identified above.
1, Sharon Zupko, hereby verify I am authorized to make this verification on behalf
of Courtyards of Carlisle Unit Owners Association, Inc., and that the statements made in
the foregoing document are true and correct to the best of my information, knowledge
and belief. I understand that false statements herein are made subject to the penalties
of 18 Pa. C.S. Section 4004, relating to unsworn falsification to authorities.
Courtyards of Carlisle Unit Owners Association, Inc.
By
haron Zupko
IN THE COURT OF COMMON PLEAS OF
CUMBERLAND COUNTY, PENNSYLVANIA
COURTYARDS OF CARLISLE
UNIT OWNERS ASSOCIATION, INC.,
Plaintiff,
V.
ANNA MARIE SALADIGO
and
DONALD L. GOSSARD
Defendants,
No. 11-3529 CIVIL TERM
CA/
Foreclosure = .
NOTICE of SHERIFF'S SALE PURSUANT TO
PENNYSLVANIA RULE OF CIVIL PROCEDURE RULE 3129.3
TAKE NOTICE:
That a Sheriff's Sale of Real Property (Real Estate) and all improvements thereon or affixed
thereto will be held in the Cumberland County Sheriff's Office, One Courthouse Square, Carlisle,
Pennsylvania 17013 on March 7, 2012 at 10:00 AM, prevailing time.
THE REAL ESTATE TO BE SOLD is delineated in detail in a legal description mainly consisting
of a statement of the measured boundaries of the property.
(SEE METES AND BOUNDS DESCRIPTION
ATTACHED HERETO AT EXHIBIT "A").
THE LOCATION of the property to be sold is: 93 Courtyard Drive, Carlisle, PA 17013.
Parcel Number: 06-18-1371-002.-U141
THE JUDGEMENT under or pursuant to which the property is being sold is docketed to No. 11-
3529 Civil Term.
A notice is directed to all parties in interest and claimants that a schedule of distribution will be
filed by the sheriff on a date specified by the sheriff not later than thirty (30) days after the sale and that
distribution will be made in accordance with the schedule unless exceptions are filed therein within ten
(10) days after the filing of the schedule.
Name and addresses of owners or reputed owners:
Anna Marie Saladigo
93 Courtyard Drive
Carlisle, PA 17013
Donald L. Gossard
711 North Hanover Street, Apt. F-104
Carlisle, PA 17013
Name and address of last recorded holder of every mortgage of record:
Primary Residential Mortgage, Inc.
4750 West Wiley Post Way #200
Salt Lake City, UT 84116
? J'+ ,\
Respectfully submitted,
SAIDIS, SULLIVM & ROGERS
By:
Dedn E. Reynosa
Attorney I.D. 80440
Attorney for Plaintiff
2109 Market Street
Camp Hill, PA 17011
Phone (717) 737-3405
Fax (717) 737-3407
dreynosaa-ssr-attorneys. com
Date
EXHIBIT "A"
ALL THAT CERTAIN Unit in the property known, named and identified in the
Declaration referred to below as "The Courtyards of Carlisle, A Condominium
Community", located in the Borough of Carlisle, County of Cumberland and
Commonwealth of Pennsylvania which has heretofore been submitted to the
provisions of the Pennsylvania Uniform Condominium Act, 68 Pa.C.S.A. Section
3101, et seq., by the recording in the Office of the Recorder of Deeds in and for
Cumberland County, Pennsylvania, of a Declaration dated February 26, 1999,
and recorded April 22, 1999, in Miscellaneous Book 610, Page 678, together with
all amendments and supplements thereto recorded on or before the date
hereof and designated as Unit No. 141 as more fully described in such
Declaration, together with the proportionate undivided interest in the Common
Elements as defined in such Declaration.
UNDER AND SUBJECT to any and all covenants, conditions, restrictions, rights of
way, easements and agreements of record including, but not limited to, those
contained in the Declaration and Declaration Plan.
I Certify this to be recorded
Jri Cumbwrland County PA
Recorder of Deeds
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SHERIFF'S OFFICE OF CUMBERLAND COUNTY
Ronny RAnderson r
Sheriff r'i
Jody S Smith juu 1
Chief Deputy 11J 4 =?
Richard W Stewart
[(,; CG7t;C?-
Solicitor P? NNS YLVA I A
Courtyards of Carlisle Unit Owners Association, Inc.
vs. Case Number
Donald L Gossard (et al.) 2011-3529
- i
SHERIFF'S RETURN OF SERVICE
12/29/2011 07:50 PM - Deputy Shawn Gutshall, being duly sworn according to law, states service was performed y
posting a true copy of the requested Real Estate Writ, Notice and Description, in the above titled action
upon the property located at 93 Courtyard Drive, Carlisle, Cumberland County, PA 17013.
12/29/2011 09:01 PM - Deputy Shawn Gutshall, being duly sworn according to law, served the requested Real Estate
Writ, Notice and Description, in the above titled action, by making known its contents and at the same imE
personally handing a true copy to a person representing themselves to be the Defendant, to wit: Dona d L
Gossard at 711 N Hanover St, Apt. F-104, Carlisle Borough, Carlisle, Cumberland County, PA 17013.
02/06/2012 Ronny R Anderson, Sheriff, being duly sworn according to law, states that he made a diligent search a?d
inquiry for the within named Defendant, to wit: Anna Marie Saladigo, but was unable to locate the
Defendant in his bailiwick. He therefore returns the within Real Estate Writ, Notice and Description, in t1ke
above titled action, as "Not Found" at 93 Courtyard Drive, Carlisle Borough, Carlisle, PA 17013.
03/02/2012 Ronny R Anderson, Sheriff, being duly sworn according to law, states that this writ is returned "stayed"?
per letter of instruction from Attorney.
03/02/2012 Bankruptcy filed in Sheriffs Office
03/05/2012 Property sale removed from 3/7/2012 sale.
03/07/2012 As directed by Dean E. Reynosa, Attorney for the Plaintiff, Sheriffs Sale Continued to 6/6/2012
06/05/2012 As directed by Dean E. Reynosa, Attorney for the Plaintiff, Sheriffs Sale Continued to 7/11/2012
07/10/2012 Ronny R Anderson, Sheriff, being duly sworn according to law, states that this writ is returned "stayed",!
per letter of instruction from Attorney.
SHERIFF COST: $799.87
July 10, 2012
SO ANSWERS,
RON R ANDERSON, SHERIFF
In the Court of Common Pleas of Cumberland County, Pennsylvania
COURT YARDS OF CARLISLE UNIT
OWNERS ASSOCIATION, INC..
Plaintiff
V.
ANNA MARIE SALADIGO and
DONALD L. GOSSARD,
Defendants
NO. 11-3529 CIVIL TERM
FORECLOSURE
AFFIDAVIT PURSUANT TO RULE 3129.1
Courtyards of Carlisle Unit Owners Association, Inc., Plaintiff in the above action,
sets forth that as of the date the Praecipe for the Writ of Execution was filed the
following information concerning the real property located at 93 Courtyard
Drive. Carlisle, PA 17013:
Description of Property: The most recent Deed found at Book 269, Page 4719
in the Recorder of Deeds Office is attached hereto as Exhibit A.
1) Name and addresses of owners or reputed owners:
Anna Marie Saladigo and Donald L. Gossard
93 Courtyard Drive 711 N. Hanover Street, Apt. F-104
Carlisle, PA 17013 Carlisle, PA 17013
2) Name and addresses of Defendants in the judgment:
Same as above.
3) Name and address of every judgment creditor whose judgment is a
record lien on the real property to be sold
Plaintiff herein.
IN THE COURT OF COMMON PLEAS OF
CUMBERLAND COUNTY, PENNSYLVANIA
COURTYARDS OF CARLISLE
UNIT OWNERS ASSOCIATION, INC., No. 11-3529 CIVIL TERM
Plaintiff,
V.
ANNA MARIE SALADIGO
and Foreclosure
DONALD L.GOSSARD
Defendants,
NOTICE of SHERIFF'S SALE PURSUANT TO
PENNYSLVANIA RULE OF CIVIL PROCEDURE RULE 3129.3
TAKE NOTICE:
That a Sheriff's Sale of Real Property (Real Estate) and all improvements thereon or a fixed
thereto will be held in the Cumberland County Sheriff's Office, One Courthouse Square, Ca lisle,
Pennsylvania 17013 on March 7, 2012 at 10:00 AM, prevailing time.
THE REAL ESTATE TO BE SOLD is delineated in detail in a legal description mainly consisting
of a statement of the measured boundaries of the property.
(SEE METES AND BOUNDS DESCRIPTION
ATTACHED HERETO AT EXHIBIT "A").
THE LOCATION of the property to be sold is: 93 Courtyard Drive, Carlisle, PA 17013.
Parcel Number: 06-18-1371-002.-0141
THE JUDGEMENT under or pursuant to which the property is being sold is docketed to Nq. 11-
3529 Civil Term.
A notice is directed to all parties in interest and claimants that a schedule of distribution Will be
filed by the sheriff on a date specified by the sheriff not later than thirty (30) days after the sale an that
distribution will be made in accordance with the schedule unless exceptions are filed therein within ten
(10) days after the filing of the schedule.
Name and addresses of owners or reputed owners:
Anna Marie Saladigo
93 Courtyard Drive
Carlisle, PA 17013
Donald L. Gossard
711 North Hanover Street, Apt. F-104
Carlisle, PA 17013
Name and address of last recorded holder of every mortgage of record:
Primary Residential Mortgage, Inc.
4750 West Wiley Post Way #200
Salt Lake City, UT 84116
Date
Respectfully submitted,
SAIDIS, SULLIV
By:
ROGERS
D n E. Reynosa
Attorney I.G. 80440
Attorney for Plaintiff
2109 Market Street
Camp Hill, PA 17011
Phone (717) 737-3405
Fax (717) 737-3407
dreynosa(assr-attorneys.com
EXHIBIT "A"
ALL THAT CERTAIN Unit in the property known, named and identified in the
Declaration referred to below as "The Courtyards of Carlisle, A Condominium
Community", located in the Borough of Carlisle, County of Cumberland and
Commonwealth or Pennsylvania which has heretofore beer, submitted to the
provisions of the Pennsylvania Uniform Condominium Act, 68 Pa.C.S.A. Section
3101, et seq., by the recording in the Office of the Recorder of Deeds in and for
Cumberland County, Pennsylvania, of a Declaration dated ebruary 26, 1999,
and recorded April 22, 1999, in Miscellaneous Book 610, Page 678, together with
all amendments and supplements thereto recorded on or before the date
hereof and designated as Unit No. 141 as more fully described in such
Declaration, together with the proportionate undivided interest in the Common
Elements as defined in such Declaration.
UNDER AND SUBJECT to any and all covenants, conditions, restrictions, rights of
way, easements and agreements of record including, but not limited to, those
contained in the Declaration and Declaration Plan.
C, c r tI'i1S t0 recorded ?!A
corder of Dc,,
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WRIT OF EXECUTION and/or ATTACHMEN r
COMMONWEALTH OF PENNSYLVANIA)
COUNTY OF CUMBERLAND)
NO11-3529 Civil
CIVIL ACTION - LAW
TO THE SHERIFF OF CUMBERLAND COUNTY:
To satisfy the debt, interest and costs due COURTYARDS OF CARLISLE UNIT OWNERS
ASSOCIATION, INC. Plaintiff (s)
From ANNA MARIE SALADIGO AND DONALD L GOSSARD
(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: $12,588.16
Interest $275.31
Atty's Comm: %
Atty Paid: $214.94
Plaintiff Paid:
Date: 12/1/2011
(Seal)
REQUESTING PARTY:
Name: DEAN E. REYNOSA, ESQUIRE
Address: 2109 MARKET STREET
CAMP HILL, PA 17011
Attorney for: PLAINTIFF
Telephone: 717-737-3405
Supreme Court ID No. 80440
L.L.: $.50
Due Prothy: $2.00
Other Costs:
David D. Bue , rothonot
By: -
Deputy
TRUE COPY FROP0 RECORD In Testimony whereof, I here unto set my hand
and the seal of said Co rt at Carlisle, Pa.
This day of _ ;, 20
n Prothonotary
c.t
On December 19, 201 1 the Sheriff` levied upon the
defendant's interest in the real property situated in
Carlisle Borough, Cumberland County, PA,
Known and numbered as, 93 Courtyard Drive,
Carlisle, more fully described on Exhibit "A" filed
with this writ and by this reference incorporated herein.
Date December 19, 2011
By:
Real Estate Coor in for
c C -4 t
L 1
CUMBERLAND LAW JOURNAL
Writ No. 2011-3529 Civil Term
Courtyards of Carlisle Unit
Owners Association, Inc.
VS.
Donald L. Gossard and
Anna Marie Saladigo
Atty.: Dean Reynosa
ALL THAT CERTAIN Unit in the
property known, named and identi-
fied in the Declaration referred to be-
low as "The Courtyards of Carlisle, A
Condominium Community," located
in the Borough of Carlisle, County of
Cumberland and Commonwealth of
Pennsylvania which has heretofore
been submitted to the provisions of
the Pennsylvania Uniform Condo-
minium Act, 68 Pa. C.S.A. Section
3101, et seq., by the recording in
the Office of the Recorder of Deeds
in and for Cumberland County,
Pennsylvania, of a Declaration dated
February 26, 1999, and recorded
April 22, 1999, in Miscellaneous
Book 610, Page 678, together with
all amendments and supplements
thereto recorded on or before the
date hereof and designated as Unit
No. 141 as more fully described in
such Declaration, together with the
proportionate undivided interest in
the Common Elements as defined in
such Declaration.
UNDER AND SUBJECT to any
and all covenants, conditions, restric-
tions, rights of way, easements and
agreements of record including, but
not limited to, those contained in the
Declaration and Declaration Plan.
BEING part of the same premises
which James S. Hall, by Deed dated
April 8, 1998 which Deed is recorded
in the Office of the Recorder of Deeds
in and for Cumberland County in
Deed Book 175, Page 88, granted
and conveyed to COC Associates, a
Pennsylvania Limited Partnership,
Grantor herein.
40
PROOF OF PUBLICATION OF NOTICE
IN CUMBERLAND LAW JOURNAL
(Under Act No. 587, approved May 16, 1929), P. L.1784
COMMONWEALTH OF PENNSYLVANIA
ss.
COUNTY OF CUMBERLAND :
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 La
Journal, a legal periodical published in the Borough of Carlisle in the County and State afores
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,
27. February 3, and February 10, 2012
Affiant further deposes that he is authorized to verify this statement by the Cumberla
Law Journal, a legal periodical of general circulation, and that he is not interested in the subj
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.
Edi
SWORN TO AND SUBSCRIBED before me this
10 day of February, 2012 4
d. ( -
Notary
NOTARIAL SEAL
DEBORAH A COLLINS
Notary Public
CARLISLE BOROUGH, CUMBERLAND COUNTY
My Commission Expires Apr 28, 2014
The Patriot-News Co.
2020 Technobgy Pkwy
Suite 300
Mechanicsburg, PA 17050
Inquiries - 717-255-8213
CUMBERLAND CO. SHERIFFS OFFICE
CUMBERLAND COUNTY COURT HOUSE
CARLISLE PA 17013
this,24 f February, 2012 A. D.
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
Holly Blain, being duly sworn according to law, deposes and says:
That she is a Staff Accountant of The Patriot News Co., a corporation organized and existing under the laws
Commonwealth of Pennsylvania, with its principal office and place of business at 2020 Technology Pkwy, Suite 300,
Township of Hampden, County of Cumberland, State of Pennsylvania, owner and publisher of The Patriot-News and
Patriot-News newspapers of general circulation, printed and published at 1900 Patriot Drive, in the City, County and
aforesaid; that The Patriot-News and The Sunday Patriot-News were established March 4th, 1854, and September 11
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
daily and/or Sunday/ Community Weekly editions which appeared on the date(s) indicated below. That neither she nc
Company is interested in the subject matter of said printed notice or advertising, and that all of the allegations of this
to the time, place and character of publication are true; and
That she has personal knowledge of the facts aforesaid and is duly authorized and empowered to verify this
behalf of The Patriot-News Co. aforesaid by virtue and pursuant to a resolution unanimously passed and adopted sev
stockholders and board of directors of the said Company and subsequently duly recorded in the office for the Recordi
in and for said County of Dauphin in Miscellaneous Book "M", Volume 14, Page 317.
PUBLICATION COPY
This ad ran on the date(s) shown
Sworn to and
the patr1*0t?XeWs
Now yolu know
Notarial sea- j -
Owens, nary Public
Lower Commi?n wp., Dauphin County
26, 2015
3f the
n the
The Sunday
tate
;th, 1949,
heir regular
it said
tatement as
tatement on
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ig of Deeds
N:
01/27/12
02/03/12
02/10/12
2011-3529 Chili Tom
Courtyards of Carlisle UnR
Owners Assoclatlon, inc.
VS
Donald L. Gossard and Anna
Marie Saladlgo
Atty. Dean Reynosa
ALL THAT CERTAIN Unit in the
property known, named and identified in
the Declaration referred to below as "The
Courtyards of Carlisle, A Condominium
Community," located in the Borough
of Carlisle, County of Cumberland and
Commonwealth of Pennsylvania which
has heretofore been submitted to the
provisions of the Pennsylvania Uniform
Condominium Act, 68 Pa. C.S.A. Section
3101, et seq., by the recording in the
Office of the Recorder of Deeds in and for
Cumberland County, Pennsylvania, of a
Declaration dated February 26, 1999, and
recorded April 22,1999, in Miscellaneous
Book 610, Page 678, together with all
amendments and supplements thereto
r( corded on or before the date hereof and
th ugnated as Unit No. 141 as more fully
cribed in such Declaration, together
the proportionate undivided interest in
the Common Elements as defined in such
neclaration.
BIDER AND SUBJECT to any and
,d covenants, conditions, restrictions,
rights of way, easements and agreements
of record including, but not limited to,
those contained in the Declaration and
Declaration Plan.
BEING part of the same premises which
James S. Hall, by Deed dated April 8,1998
which Deed is recorded in the Office of the
Recorder of Deeds in and for Cumberland
County in Deed Book 175, Page 88, granted
and conveyed to COC Associates, a
Pennsylvania Limited Partnership, Grantor
herein.