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Home My WebLink About01-3312FIRST UNION NATIONAL BANK AS TRUSTEE IN THE COURT OF COMMON PLEAS FOR PENNSYLVANIA HOUSING FINANCE OF CUMBERLAND COUNTY AGENCY Plaintiff CIVIL ACTION - LAW vs. ACTION OF MORTGAGE FORECLOSURE SHAWN M. BOWERS AND ~ CJI- ..3.:4/~. LISA M. GRANT Defendants THIS ~IRM IS A DEBT COLLECTOR AND WE ARE ATTEMPTINGTO COLLECT A DEBT OWED TO OUR CLIENT. ANY INFORMATION OBTAINED FROM YOU WILL BE USED FOR THE PURPOSE OF COLLECTING THE DEBT. NOTICE You have been sued in court. If you wish to defend against the claims set forth in the following pages, you nmst take action within twenty (20) days after the Complaint and notice are served, by entering a writ~n appearance personally or by atXomey and filing in writing with the court your defenses or objections to the claims set forth against you. You are warned ~hat 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 claim in the Complaint of 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 POPER TO YOUR LAWYER AT ONCE. IF YOU DO NOT HAVE A LAWYER OR CANNOT AFFORD ONE, GO TO OR TELEPHONE THE OFFICE SET FORTH BELOW TO FIND OUT WHERE YOU CAN GET LEGAL HELP. CUMBERLAND COUNTY LAWYER REFERRAL SERVICE CUMBERLAND COUNTY BAR ASSOCIATION 2 LIBERTY AVENUE CARLISLE, PA 17013 717-249-3166 AVISO LE HAN DEMANDADO A USTED EN LA CORTE. SI DESEA DEFENDERSE CONTRA LAS QUEJAS PERESENTADAS, ES ABSOLUTAMENTE NECESSARIO QUE USTED RESPONDA DENTRO DE 20 DIAS DESPUES DE SER SERVIDO CON ESTA DEMANDA Y AVISO. PARA DEFENDERSE ES NECESSARIO QUE USTED, O SU ABOGADO, REGISTRE CON LA CORTE EN FORMA ESCRITA, EL PUNTO DE VISTA DE USTED Y CUALQUIER OBJECCION CONTRA LAS QUE,IAS EN ESTA DEMANDA. RECUERDE: SI USTED NO REPONDE A ESTA DEMANDA, SE PUEDE PROSEGUIR CON EL PROCESO SIN SU PARTICIPACION. ENTONCES, LA COUTE PUEDE, SIN NOTIFICARIO, DECIDIR A FAVOR DEL DEMANDANTE Y REQUERIRA QUE USTED CUMPLA CON TODAS LAS PROVISION'ES DE ESTA DEMANDA. POR RAZON DE ESA DECISION, ES POSSIBLE QUE USTED PUEDA PERDER DINERO, PROPIEDAD U OTROS DERECHOS IMPORTANTES. LLEVE ESTA DEMANDA A UN ABOGADO IMMEDIATEAMENTE. SI NO CONOCE A UN ABOGADO, LLAME AL "LAWYER REFERENCE SERVICE" (SERVICIO DE REFERENCIA DE ABOGADOS), (215) 238-6300. CUMBERLAND COUNTY LAWYER REFERRAL SERVICE CUMBERLAND COUNTY BAR ASSOCIATION 2 LIBERTY AVENUE CARLISLE, PA 17013 717-249-3166 FIRST UNION NATIONAL BANK AS TRUSTEE : IN THE COURT OF COMMON PLEAS FOR PENNSYLVANIA HOUSING FINANCE : CUMBERLAND COUNTY, PENNSYLVANIA AGENCY, : Plaintiff : : CIVIL ACTION LAW vs. : ACTION OF MORTGAGE FORECLOSURE : SHAWN M. BOWERS AND : LISA M. GRANT, : Defendants : THE FOLLOWING NOTICE IS BEING PROVIDED PURSUANT TO THE FAIR DEBT COLLECTION PRACTICES ACT, 15 U.S.C. 1601 The undersigned attorney is attempting to collect a debt owed to the Plaintiff, and any information obtained will be used for that purpose. The amount of the debt is stated in this Complaint. Plaintiff is the creditor to whom the debt is owed. Unless the Debtor, within thirty (30) days after your receipt of this notice disputes the validity of the aforesaid debt or any portion thereofowing to the Plaintiff, the undersigned attorney will assume that said debt is valid. If the Debtor notifies the undersigned attorney in writing with the said thirty (30) day period that the aforesaid debt, or any portion thereof, is disputed, the undersigned attorney shall obtain written verification of the said debt from the Plaintiffand mail same to Debtor. Upon written request by Debtor to the undersigned attorney within said thirty (30) day period, the undersigned attorney will provide debtor with the name and address of the original creditor if different from the current creditor. PURCELL, KRUG & HALLER 1719 North Front Street Harrisburg, PA 17102 (717) 234-4178 Attorney I.D.# 15700 Attorney for Plaintiff FIRST UNION NATIONAL BANK AS TRUSTEE IN THE COURT OF COMMON PLEAS FOR PENNSYLVANIA HOUSING FINANCE CUMBERLAND COUNTY, PENNSYLVANIA AGENCY, Plaintiff : CIVIL ACTION - LAW : vs. : ACTION OF MORTGAGE FORECLOSURE : ~..01-33~.Z ~ 'T'".t~.-- SHAWN M. BOWERS AND : LISA M. GRANT, : Defendants : COMPLAINT IN MORTGAGE FORECLOSURE 1. Plaintiff, FIRST UNION NATIONAL BANK AS TRUSTEE FOR PENNSYLVANIA HOUSING FINANCE AGENCY, pursuant to a Trust indenture dated as of April 1, 1982 ("Trust"), is a National Association with a servicing agent of Pennsylvania Housing Finance Agency, with an address of 2101 North Front Street, Harrisburg, Pennsylvania 17105. 2. Defendant, SHAWN M. BOWERS, is an adult individual, whose last known address is 1122 FERNWOOD AVENUE, CAMP HILL, PENNSYLVANIA 17011. Defendant, LISA M. GRANT, is an adult individual, whose last known address is 1122 FERNWOOD AVENUE, CAMP HILL, PENNSYLVANIA 17011. 3. On or about, December 30, 1998, the said Defendant executed and delivered a Promissory Note ("Note") in favor of BROADVIEW MORTGAGE COMPANY ("Original Mortgagee") in the principal mount of $79,859.00, the proceeds of which were used to purchase a residential property located at 1122 FERNWOOD AVENUE, CAMP HILL, PENNSYLVANIA 17011. A copy of the said Note is attached hereto and marked Exhibit "A". 4. Contemporaneously with and at the time of the execution of the aforesaid Mortgage Note, in order to secure payment of the same, Defendant made, executed, and delivered to original Mortgagee, a certain real estate Mortgage which is recorded in the Recorder of Deeds Office of the within County and Commonwealth in Mortgage Book 1511, Page 362 conveying to original Mortgagee the subject premises. The Mortgage was subsequently assigned to PENNSYLVANIA HOUSING FINANCE AGENCY and was recorded in the aforesaid County in Book 599, Page 640. The Mortgage subsequently assigned to FIRST UNION NATIONAL BANK AS TRUSTEE FOR PENNSYLVANIA HOUSING FINANCE AGENCY and will be sent for recording. 5. The land subject to the Mortgage is: 1122 FERNWOOD AVENUE, CAMP HILL, PENNSYLVANIA 17011 and is more particularly described in Exhibit "B" attached hereto. 6. The said Defendant is the real owner of the property. 7. The Mortgage is in default due to the fact that Mortgagor has failed to pay the installment due on December 01, 2000 and all subsequent installments thereon, and the following amounts are due on the Mortgage: UNPAID PRINCIPAL BALANCE $77,563.24 Interest at $10.77 per day $2,283.24 From 11/01/2000 To 06/01/2001 ( based on contract rate of 5.000%) Accumulated Late Charges $117.90 Late Charges $17.15 $120.04 From 12/01/2000 to 06/01/2001 Escrow Deficit $88.45 Attorney's Fee at 5% of Principal Balance $3,878.16 TOTAL $84,051.03 **Together with interest at the per diem rate noted above after June 01, 2001 and other charges and costs to date of Sheriff's Sale. The attorney's fees set forth above are in conformity with the Mortgage documents and Pennsylvania law, and will be collected in the event of a third party purchaser at Sheriff's Sale. If the Mortgage is reinstated prior to the sale, reasonable attorney's fees will be charged that are actually incurred by Plaintiff. 8. No judgement has been entered upon said Mortgage in any jurisdiction. 9. Notice of intention to foreclose and accelerate the loan balance pursuant to Pennsylvania Act No. 6 of 1974 is not required in that the principal balance exceeds $50,000.00. 10. Defendant is not a member of the Armed Forces of the United States of America, nor engaged in any way which would bring him within the Soldiers and Sailors Relief Act of 1940, as amended. 1 I. The within Mortgage is insured by the Federal Housing Administration unde~ Title II of the National Housing Act and, as such, is not subject to the provisions of Pennsylvania Act No. 91 of 1983. WHEREFORE, Plaintiff demands judgment in mortgage foreclosure "IN REM" tbr the aforementioned total amount due together with interest at the rate of 5.000% ($10.77 p),~tiem), together with other charges and costs including escrow advances incidental thereto to the date of Sheriffs Sale and for foreclosure and sale of Leon P. Haller, E~uire Attorney for Plaintiff I.D. # 15700 1719 N. Front Street Harrisburg, PA 17102 (717-234-4178) FR-441-5857746.703 DECh'tBER 30, 1998 1122 FERR;',~("~D AVENUE CAMP HILL, PA 17011 1. "t3urmowcr" Illttil~l,': ~Ich person s going al l];c end of thb: Note, and ~e person s ~uccesso,s mc:ms BROADVIEW MORTgaGE COMPANY, q5 E. WILSON BRIDGE ROAD, WORtHINgTON, Oil 430BB 2. BORROWEi~'S I'ROMISE TO PAY; INTEREST lu return for a ]tmn r~cived from Lendec, Bom~wer promises Io pay ~e principal sum of SEVENTY-NINE THOUSAND EIaH'r HUNDRED FIFTY-NINE AND NO/lO0 (u.s. S 79,859. O0 ), Nuz bmn~, m ~lm order of ~md~r. pfiucip~, l'rom ~o dm~ o~ ~sb:r~mem of fl~e ~,au pmcc~ds by Leud~, ~ ~ ~m: o~ ****************************** p~cent ( S. 000 %) pez ~' ar u:~dl file full ~on]',t of p~cip~ h~ been paid. 3. PROMISE TO PAY SECURED Borrow~'s promise lo pay is s~ by a mortgage, d~ of ~st or sim~ s~ity ins~ment date as ~is No~ and culled the "S~urity Instlt ~,~c.nt. ~c S~ity Ins~umcnt proem ~c ~nd~ from losses which mighl result d Bo~w~ defaulm und~ ~is Note. 4. MA~ER OF PA~ENT (A) T~e Bo~ower sh~l m~e a paymem of p~ncip~ ~d inler~t to ~nd~ on ~e ~ffst ~y of each monfl~ bgginning on FEBRUARY 1, 1999 . Anypfincip~andim~stremainingon~cf~st~yof 0ANUARY 1, 2029 will be due on ~at dam, which is c~ ~e "Mat~ity Date." (B) Place . Payment sh~ be made at BROADVIEN ~0RSGAGE COMPANY, 95 E. gILS0~ BRIDGE ROAD, ~0RTHINBTON, OH 43085 or at such o~ place ~ ~d~ may d~igna~ ~ ~g by nofi~ ~ Bonow~. (C) Amount ~ch mon~ly paym~t of p~cip~ and inter~t w~ b~ in ~e ~ount of U.S. $ 428. This ~ount will b~ p~t of a linger mon~ly payment r~u~ by ~ Sec~ Ins~ment, ~at sh~ be appH~ W p~cipfl, iu~t~t ~d o~ items m me oracr dcsc~b~ in ~e S~ty Ins~um~t MULTISTAT~ FHA FIXED RATE NOTE 6/96 GREA~LAND I1 ITEM 6432L I (g606) O¢~cld 0000000763 (Page ] ors ~ge.t) To Order Call: 1-800.530-9393rI ,=ax 6t6-191-1131 ACCT# 935442 Illin Note. (Ch~'k a]q'fli~abJ~ ho .; ~] edger [spe~il~] S. BORROT%'ER'S RTG] J'J' TO l'i~ I&PAY Borrower hits die light lo pay fl~t: debt evidenced by Ibis Note, in whole or iu pilil, wiflIOnt ch~gc or l)clndly, u~; t:~=: day ul' rely monfli. Lender shall accqu prqmymeut o,~ mher days provided flint Borrower pays inleresl on the aqmn;~, ]':repaid Io~ file remainder of fl~ monfll to 0~,: extgul requi~ed by ~ntl~ nu~ permitteA by re, gulafio~a of ~e Sec~'ts~r)'. Il !'~{..'~owc~ makes iL p~fial prtqniynlgnt, the. re w,'; hr'. no chat]t~c~ in ~e dllC date or Jn file IUUOUl)t O~ lilt' ['noufllly payment Ul~!.~;e: I entice : t~re~ in writing to ~ose BORROWER'S FAILIJR'., TO PAY (A) Late Charge for Overdue Paymenls If Lender has not r<eiv~ th~ full monthly p:~ymont requR~ by die S~urity Insffumeut, as di:scrib~ iL' P~agraI;h 4(C) of fids Note, by fl'L~ end of fifk:cu ci,leL~dar days slier file payment is due, ~nder may collt'ct a la~ ch~ge in the zunount of Default {]ift~o~ower dufaulB by l' iling I J pay io fi i y mt { hly payment ~¢n l~nder may, except ~ limiiml by r~glRadons IbC Se<rely in IJR~ eigsu et i,:{ymgnt defaulls, retl~ke im~n~lint¢ puyment in fidl of ~ principM b~ance rema~uing d;,c. and all uco'uml in~x~t. ~nd~r may choose, noi to extu'ci:~c Ods option wilhoot w~ving ils righls in ~g gvm~t of any Sl{b?'qUUlR. default. In m~y clreumsi:mc~ regt~laaons lssum, by th. Suclg~ will limit I~nde~'s fighl~ Io r~uire imm~iq~c I':;~y~',,unt full in Ole c~e of payment dgfaulls. This Note dm:s uot auHiorl7.¢ accel~afion whe. n not pcrmitl~ by HL]D regq{afi:~,m. As us,' } in ~is Nme, "S<~" m~ns file S~remr)' of Housing and Urb~ Development or his or ll~ designee. (C) Payment of Costs and Expenses If ~nder has r~uired immmliuto payment in fnll, as de~rib~ above, Lend~ may r~u~e Bo~wur lo pay cos~ ~d expenses including ~onablo arid custom~y attorneys' f~ for enforcing ~is Note to ~e extent not prohibit~ by applicable law. Such f~s m~d cos~ sh~l b~ interest frmn d~ datg of disb~sument at ~e s~u ram ~s Hie pfincipM of ~is 7. WAIVERS Bo~ow~ ~d ~y o~er person who has obligations under ~is Nora w~ve ~e righu of pr~en~unt a~d oofice of dishonor. "~sgn~unt" mm~s ~e right to require Lend~ to dem~d payment of ~oun~ du~. "Nodce of dishonor" me~s ~e right to r~u~e ~nder ~ give nofi~ to o~ persons ~at ~ounB due have not b~n p~d. 8. GI~G O~ NO~CRS Unless applicabl~ law ~u~es a diff~unt mg~od, ~y nofic~ ~at must bg given m Bo~w~ und~ ~ Nora w~ given by delivering it or by m~ling it by f~st cl~s m~l m Bo~wgr at ~ prosy ad.ss above or at a ~f~nt ad.ess B~ow~ h~ given ~nd~ a nofi~ of Bo~w~'s diff~ont ad~s. Any notice ~at must be given m ~nd~ under ~is Nog will bu giv~ by f~st cl~s m~ ~ ~nd~ at ~ address in P~agmph 4(B) or at a different ad~s if Bo~ow~r is giv~ a notice of ~at ~ff~t ad~s. OBLIGATIONS O~ PERSONS ~DER ~S NOTE If more ~ one p~n signs ~is Nog, ~ch person is Mlly ~d pmon~y ob~gatM m k~p ~ of ~e pmmis~ rome in &is No~, include ~u promise m pay ~e rub ~ount ow~. Any p~son who B a gumn~, aery ~ endorser of ~is Nog is ~so obEga~ m do ~usu ~ings. Any person who ~ over ~ obHgafitns, M~u~ ~e obligations of a gu~, s~e~ ~ en~r~ of ~is No~, ~ ~so obfiga~ m k~p ~ of ~ pmm~ made in ~is No~. ~nd~ may enfome i~ figh~ und~ ~is Nog ag~nst each p~rson in~vidu~y or ag~nst ~ ~gnatofi~ mg~. Any one preen signing ~is Note may be r~u~ed m pay ~1 of ~e ~ounm ow~ und~ ~is Note. " . ,~ TG .'n~ URI)E:K ~,. PENNSYLVANIA HOUSING FINANCE AGENCY' ~o..'.i,v:~,....,~,.~?,~. ...... Z'_L "~ ~--.~ ~. / ........... ~~~ .. Rosema~ Howard V~c~ President ACCT# 9354-12 and tha lin.~'~ ~ adjoi~l:.,' 13e~ween lot~ nu~.~a-'.'":d 106 and 107 a~'~ the ment~cne~, plan of lonz~ b~in9 130.00 feet in a ~cuth~rly di=~=t!on by th~ 106, 16~.7~' l%.zt ~o =Is.': poin[ and place of ALTA Sc:h~u(. m C .' ~'~-.~~~c~ "" ~.Oel(151.1. PAGE, 369 VERIFICATION Donald J. Plunkett hereby states that he is the Assistant Executive Director for Single Family Programs of the Pennsylvania Housing Finance Agency, mortgage servicing agent for Plaintiff in this matter, that he is authorized to take this Verification, and that the statements made in the foregoing Civil ACtion in Mortgage Foreclosure are true and correct to the best of his knowledge, information and belief. The undersigned understands that this statement is made subject to the penalties of 18 Pa. C.S. Sec. 4904 relating to unswom falsification to authorities. Assistant Executive Director for Single Family Programs Dale: r~ 29, mol SHERIFF'S RETURN - NOT FOUND ~SE NO: 2001-03312 P ~MMONWEALTH OF PENNSYLV;~NIA oOUNTY OF CUMBERLAND FIRST UNION NATIONAL BANK VS BOWERS SHAWN M 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 GRANT LISA M but was unable to locate Her in his bailiwick. He therefore returns the COMPLAINT - MORT FORE , , NOT FOUND , as to the within named DEFENDA/qT , GRANT LISA M NO LONGER LIVES IN AREA Sheriff's Costs: ~~ Docketing 6.00 Service .00 Affidavit .00 R~ ~homas Kline Surcharge 10.00 Sheriff of Cumberland County NOT FOUND 5.00 21.00 PURCELL KRUG & HALLER 06/07/2001 Sworn and subscribed to before me this 2 £~R day of ~! A.D. P~o~honot ary SHERIFF'S RETURN - REGULAR ~SE NO: 2001-03312 P ~OMMONWEALTH OF PENNSYLVANIA: COUNTY OF CUMBERLAND FIRST UNION NATIONAL BANK VS BOWERS SHAWN M ET AL CPL MICHAEL BARRICK , Sheriff or Deputy Sheriff of Cumberland County,Pennsylvania, who being duly sworn according to law, says, the within COMPLAINT - MORT FORE was served upon BOWERS SHAWN M the DEFENDANT , at 1400:00 HOURS, on the 5th day of June , 2001 at 1122 FERNWOOD AVENUE CAMP HILL, PA 17011 by handing to STEPHANIE HOLLEN, GIRLFRIEND a true and attested copy of COMPLAINT - MORT FORE together with and at the same time directing Her attention to the contents thereof. Sheriff's Costs: So Answers Docketing 18.00 · .~'~~ ~.~ ~' Service 8.68 Affidavit .00 Surcharge 10.00 R. Thomas Kline .00 36.68 06/07/2001 PURCELL KRUG Sworn and Subscribed to before By: ~/D~pu~~ me this A.D. Prot~n6not ary FIRST UNION NATIONAL BANK, AS : IN THE COURT OF COMMON PLEAS TRUSTEE FOR PENNSYLVANIA : CUMBERLAND COUNTy, PENNSYLVANIA HOUSING FINANCE AGENCY, : PLAINTIFF : CIVIL ACTION - LAW VS. : SHAWN M. BOWERS, : NO. 2001 3312 DEFENDANT : IN MORTGAGE FORECLOSURE P RAE C I P E TO THE PROTHONOTARY OF THE WITHIN COUNTY: Please enter JUDGMENT "in rem,, in favor of the Plaintiff and against Defendant SHAWN M. BOWERS, for failure to plead to the above action within twenty (20) days from date of service of the Complaint, and assess Plaintiff's damages as follows: Unpaid principal balance $77,563.24 Interest $ 2,283.24 (Per diem of $10.77 from 11/1/00 to 6/1/01) Accumulated late charges $ 117.90 Late charges $ 120.04 ($17.15 per month to 6/01) Escrow Deficit $ 88.45 5% Attorney's Commission $ 3,878.16 TOTAL $84,051.03** ** Together with additional interest at the per diem rate indicated above from the date herein, based on the contract rate, and other charges and costs to the date of Sheriff's Sale. ~,eon P. Hailer PA I.D. ~:1S700 171S North Front Street Harrisburg, PA 17102 (717) 234-4178 FIRST UNION NATIONAL BANK, AS : IN THE COURT OF COMMON PLEAS TRUSTEE FOR PENNSYLVANIA : CUMBERLAND COUNTY, PENNSYLVANIA HOUSING FINANCE AGENCY, : PLAINTIFF : CIVIL ACTION - LAW VS. : SHAWN M. BOWERS, : NO. 2001 3312 DEFENDANT : IN MORTGAGE FORECLOSURE CERTIFICATE OF SERVICE PURSUANT TO PA. R.C.P. 237.1 I hereby certify that on AUGUST 21, 2001 I served the Ten Day Notice required by Pa. R.C.P. 237.1 on the Defendant(s) in this matter by regular first class mail, postage prepaid, as indicated on the attached Notice. Leon P. #15700 Attorney for Plaintiff Purcell, Krug &Haller 1719 North Front St. Harrisburg, PA 17102 FIRST UN/ON NATIONAL BANK AS TRUSTEE FOR PENNSYLVANiA : IN THE COURT OF COMMON PLEAs HOUSING FINANCE AGENCY CUMBERLAND COUNTy, PENNSYLVANiA Plaintiff VS. : NO. 01~3312 CIVIL TERM SHAWN M. BOWERs AND LISA M. GRANT : : CIVIL ACTION LAW Defendants : IN MORTGAGE FORECLOSURE DATE OF THIS NOTICE: AUGUST 21, TO: SHAW~ M. BOWERS 11~ ~OOD AVE~E CAMp HILL, PA 17011 ~_ms_ r~w ~ ~s A orBT co , ' '" ~*dVlA TION OBTAINED V~ILL BE USED FOR THE PURPOSE OF COLLECT/NG THE DEBT. PERSONALLy OR BY ATTORNEy AND F~HE COURT y YOU ARE IN DEFAULT BECAUSE YOU HAVE FAILED TO ENTER A WRITTEN APPEARANCE OBJECTIONS TO THE CLAIMs SET FORTH AGAINST YOU ~ ..... OUR DEFENs=o DAyS FROM THE DATE OF THIS NOTICE, A JUDGMENT MAy BE ENUT~RE"'Dwll~-lIN TEN (I0) WITHOUT A HEARING AND YOU MAy LOSE YOUR PROPERTY OR OTHER AGAINST YOU YOU SHOULD TAKE THIS NOTICE TO A LAWYER AT ONCE. IF YOU DO NOT HAVE A LAWYER IMPORTANT RIGHTs. OR CANNOT AFFORD ONE, GO TO OR TELEPHONE THE FOLLowiNG OFFICE TO FIND OUT WHER~ YOU CAN GET LEGAL HELP: LAWYER REFERRAL SERVICE CUMBERLAND COUNTy BAR ASSOCIATION 2 LIBERTy AVENUE CARLISLE, PA 17013 717-249-3166 OR 800-990.9108 By I.D. 15700 ff 1719 N. Front St., Harrisburg, PA (717) 234-4178 17102 FIRST UNION NATIONAL BANK, AS : IN THE COURT OF COMMON PLEAS TRUSTEE FOR PENNSYLVANIA : CUMBERLAND COUNTY, PENNSYLVANIA HOUSING FINANCE AGENCY, : PLAINTIFF : CIVIL ACTION - LAW VS. : SHAWN M. BOWERS, : NO. 2001 3312 DEFENDANT : IN MORTGAGE FORECLOSURE NOTICE OF ENTRY OF JUDGMENT TO THE ABOVE-NAMED DEFENDANTS: You are hereby notified that on 13, ~,6~D] the following judgment has been entered agains~ 'you in the above- 'captioned matter: $84,051.03 and for the sale and foreclosure of your property located at: 1122 Fernwood Avenue, Camp Hill, PA 17011 Dated: ~/'~-/6~ ~,¢~3~ ~.~_ PROTHONOTANYf' Attorney for Plaintiff: Leon P. Haller 1719 North Front Street Harrisburg, PA 17102 Phone: (717) 234-4178 I hereby certify that the following person(s) and their respective addresses are the proper individuals to receive this Notice pursuant to PA R.C.P. No. 236: Shawn M. Bowers 1122 Fernwood Avenue Camp Hill, Pa 17011 FIRST UNION NATIONAL BANK, AS : IN THE COURT OF COMMON PLEAS TRUSTEE FOR PENNSYLVANIA : CUMBERLAND COUNTY, PENNSYLVANIA HOUSING FINANCE AGENCY, : PLAINTIFF : CIVIL ACTION - LAW VS. : SHAWN M. BOWERS, : NO. 2001 3312 DEFENDANT : IN MORTGAGE FORECLOSURE P RAE C I P E TO THE PROTHONOTARY OF THE WITHIN COUNTY: Please enter ~JDGMENT "~n rem', in favor of the Plaintiff and · against Defendant SHAWN M. BOWERS, for failure to plead to the above action within twenty (20) days from date of service of the Complaint, and assess Plaintiff's damages as follows: Unpaid principal balance $77,563.24 Interest $ 2,283.24 (Per diem of $10.77 from 11/1/00 to 6/1/01) Accumulated late charges $ 117.90 Late charges $ 120.04 ($17.15 per month to 6/01) Escrow Deficit $ 88.45 5% Attorney's Commission $ 3,878.16 TOTAL $84,051.03** · * Together with additional interest at the per diem rate indicated above from the date herein, based on the contract rate, and other charges and costs to the date of Sheriff's Sale. PURCELL, KRUG &~~~~'~ Leon P. Haller PA I.D. #15700 1719 North Front Street Harrisburg, PA 17102 (717) 234-4178 IN THE COURT OF COMMON PLEAS OF CUMBERL;~N-D COUNTY, PENNSYLV~/gIA CIVIL DIVISION - LAW AT NO. 2001 3312 TOTAL AMOUNT FIRST UNION NATIONAL BANK AS OF JUDGMENT $84,051.03 ~ TRUSTEE FOR PENNSYLVANIA HOUSING Interest at $10.77 per diem FINANCE AGENCY, to sale date $ 2,024.76 PLAINTIFF Late charges at $17.15 per month to sale date $ 85.75 VS. Escrow Deficit $ 2,000.00 TOTAL $88,161.54, SHAWN M. BOWERS, DEFENDANT(S) *SALE DATE= WEDS.,DEC. 5, 2001 (PROTHONOTARY'S USE) Plaintiff Attorney Sheriff This Writ Pi~AECIPE FOR ~TRIT OF EXECUTION MORTgAgE FORECLOSURE - P.R.C.P. 3180-318a TO THE PROTHONOTARY/CLERK OF SAID COURT: Issue Writ of Execution in the above captioned case. Date: September 12, 2001 ~ Attorney for Plaintiff 1719 North Front Street Leon P. Harrisburg, PA 17102 PA I.D. #15700 (717) 234-4178 WRIT OF EXECUTION - MORTgAgE FOHECLOSURZ COMMONWEALTH OF PENNSYLVANIA : SS COUNTY OF CUMBERLAND : TO THE SHERIFF OF CUMBERLAND COUNTY: To satisfy the judgment, interest and costs in the above captioned case, you are directed to levy upon and sell the property described in the attached description known as 1122 FEP/~WOOD A~um, CAMP HILL, PA 17011. Date: PROTHONOTARY/CLERK CIVIL DIVISION BY DEPUTY K:!MKFtD~S'~UMBERLA~BOWERS W ALL THAT CERTAIN tract or parcel of land situate in the Township of Lower Allen, Cumberland County, Pennsylvania, bounded and described as follows: BEGINNING at the point of intersection of the western line'of Fernwood Avenue and the line of adjoiner between lots numbered 106 and 107 aon the hereinafter mentioned plan of lots, being 130.00 feet in a southerly direction by the western line of Fernwood Avenue from ~lenwood Avenue; thence South 30 degrees East by the western line of Fernwood Avenue, 65.00 feet to Lot No. 108; thence South 60 degrees West by the northern line of Lot No. 108, 166.76 feet to Lot No. 86; thence North 30 degrees West by the eastern line of 'No. 86, 66.00 feet to Lot No. 106; thence North 60 degrees East, by the southern line of Lot No. 106, 166.76 feet to the point and place of BEGINNING. BEING Lot No. 107 on the Plan of Rana Villa Springs TerraCe as recorded in the Cumberland County Recorder~s Office in Plan Book 2, Page 42. HAVING THEREON ERECTED A RESIDENTIAL DWELLING KNOWN AS 1122 FERNWOOD AVENUE, CAMP HILL, PA. 17011 BEING THE SAME PREMISES WHICH Shawn M. Bowers and Lisa M. Grant by deed dated 11/3/00 and recorded 12/26/00 in Deed Book 236, page 719 granted and conveyed unto Shawn M. Bowers. TO BE SOLD AS THE PROPERTY OF SHAWN M. BOWERS ON J~JDGMENT NO. 2001 3312. ASSESSMENT: 13-24-0799-251 FIRST UNION NATIONAL BANK, AS : IN THE COURT OF COMMON PLEAS TRUSTEE FOR PENNSYLVANIA : CUMBERLAND COUNTY, PENNSYLVANIA HOUSING FINANCE AGENCY, : PLAINTIFF : CIVIL ACTION - LAW VS. SHAWN M. BOWERS, : NO. 2001 3312 DEFENDANT : IN MORTGAGE FORECLOSURE AFFIDAVIT P~'~SUANT TO P.R.C.P. 3129.1 The Plaintiff in the above action, by its attorneys, Purcell, Krug &Haller, sets forth as of the date the praecipe for the writ of execution was filed, the following information concerning the real property located at 1122 FERNWOOD AVENUE, CAMP HILL, PA: 1. Name and address of the Owner(s) or Reputed Owner(s): Shawn M. Bowers 1122 Fernwood Avenue Camp Hill, PA 17011 2. Name and address of Defendant(s) in the Judgment, if different from that listed in (1) above: SAHE 3. Name and address of every Judcjment creditor whose judgment appears of record on the real property to be sold: 4. Name and address of last recorded holder of every mortg&ge of record: PLAINTIFF HEREIN (AND ANy OTHERS AS NOTED BELOW): Household Realty Corporation 25 Gateway Drive Gateway Square - Suite 107 Mechanicsburg, PA 17055 5. Name and address of every other person who has any record lien on the property: UN'KNOWN 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: 7. Name and address of every other person of whom the Plaintiff has knowledge who has any interest in the property which may be affected by the sale: TENANTS IF ANY ... Stephanie Hollen 1122 Fernwood Avenue Camp Hill, PA 17011 Domestic Relations Office Cumberland County Courthouse Hanover & High Streets Carlisle, PA 17013 (In the precedin9 information, where addresses could not be reasonably ascertained, the same is indicated.) 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 ~%~e subject to the penalties of 18 PA C.S. Section 4904 relati o unsworn falsification to authorities. ~o Leon P. Halle~ PA I.D. #15700 Purcell, Krug& Haller 1719 North Front Street Harrisburg, PA 17102 (717) 234-4178 DATE: September 12, 2001 FIRST UNION NATIONAL BANK, AS : IN THE COURT OF COMMON PLEAS TRUSTEE FOR PENNSYLVANIA : CUMBERLAND COUNTY, PENNSYLVANIA HOUSING FINANCE AGENCY, : PLAINTIFF : CIVIL ACTION - LAW VS. : SHAWN M. BOWERS, : NO. 2001 3312 DEFENDANT : IN MORTGAGE FORECLOSURE NOTICE OF SHERIFF'S SALE OF REAL ESTATE PURSUANT TO PENNSYLVANIA RIILE OF CIVIL PROCEDURE 3129 TAKE NOTICE: That the Sheriff's Sale of Real Property (real estate) will be held: DATE: WEDNESDAY, DECemBER 5, 2001 TIME: 10:00 O'clock A.M. LOCATION: Commissioner's Hearing Room 2nd Floor Cumberland County Courthouse Carlisle, Pennsylvania 17013 THE PROPERTY TO BE SOLD is delineated in detail in a legal description mainly consisting of a statement of the measured boundaries of the property, together with a brief mention of the buildings and any other major improvements erected on the land. (SEE DESCRIPTION ATTACHED) THE LOCATION of your property to be sold is: 1122 FERNWOOD AVENUE CAMP HILL CUMBERLAND COUNTY PENNSYLVANIA THE JUDONENT under or pursuant to which your property is being sold is docketed in the within Commonwealth and County to: NO. 2001 3312 THE NAME(S) OF THE OWNER(S) OR REPUTED OWNERS of this property is: SHANNM. BOWERS A SCHEDULE OF DISTHIBUTION, being a list of the persons and/or governmental or corporate entities or agencies being entitled to receive part of the proceeds of the sale received and to be disbursed by the Sheriff (for example, to hanks that hold mortgages and municipalities that are owed taxes) will be filed by the Sheriff of this County thirty (30) days after the sale and distribution of the proceeds of sale in accordance with this schedule will, in fact, be made unless someone objects by filing exceptions to it within ten (10) days of the date it is filed. Information about the Schedule of Distribution may be obtained from the Sheriff of the Court of Common Pleas of the within County at the Courthouse address specified herein. THIS PAPER IS A NOTICE OF THE TIME AND PLACE OF THE SALE OF YOUR PROPERTY. IT HAS BEEN ISS~m BECAUSE THERE IS A JUDGMENT AGAINST YOU. IT MAY CAUSE YOUR PHOPEHTY TO BE ~L~, TO BE SOLD OH Ta~mN TO PAY THE JUDGMENT. You may have legal rights to prevent your property from being taken away. A lawyer can advise you more specifically of these rights. If you wish to exercise your rights, YOU MUST ACT PROMPTLY. YOU SHOULD TAKE THIS PAPER TO YOUR LAWYEH AT ONCE. GO TO OH TELEPHONE THE OFFICE SET FORTH BELOW TO FIND OUT WHERE YOU CAN GET FREE LEGAL ADVICE: Cumberland County Bar Association 2 Liberty Avenue Carlisle, Pennsylvania 17013 717-249-3166 Legal Services, Inc. 8 Irvine Row Carlisle, PA 17013 717-243-9400 THE LEGAL RIGHTS YOU MAY HAVE ARE: 1. You may file a petition with the Court of Common Pleas of the within County to open the judgment if you have a meritorious defense against the person or company that has entered judgment against you. You may also file an petition with the same Court if you are aware of a legal defect in the obligation or the procedure used against you. 2. After the Sheriff's Sale you may file a petition with the Court of Common Pleas of the within County to set aside the sale for a grossly inadequate price or for other proper cause. This petition MUST BE FILED BEFORE THE SHERIFF'S DEED IS DELIVERED. 3. A petition or petitions raising the legal issues or rights mentioned in the preceding paragraphs must be presented to the Court of Common Pleas of the within County. The petition must be served on the attorney for the creditor or on the creditor before presentation to the court and a proposed order or rule must be attached to the petition. If a specific return date is desired, such date must be obtained from the Court Administrator's Office - Civil Division, of the within County Courthouse, before a presentation of the petition to the Court. A copy of the Writ of Execution is attached hereto. PURCELL, KRUG & HALLER Attorneys for Plaintiff 1719 North Front Street Harrisburg, PA 17102 (717) 234-4178 ALL TF~AT CERTAIN tract or parcel of land situate in the Township of Lower Allen, Cund~erland County, Pennsylvania, bounded and described as follows: BEGINNING at the point of intersection of the western linc'of Fernwood Avenue and the line of adjoiner between lots numbered 106 and 107 aon the hereinafter mentioned plan of lots, being 130.00 feet in a southerly direction by the "western line of Fernwood Avenue from Olenwood Avenue; thence South 30 degrees East by the western line of Fernwood Avenue, 65.00 feet to Lot No. 10B; thence South 60 degrees West by the northern line of Lot No. 108, 166.75 feet to Lot No. 86; thence North 30 degrees West by the eastern line of No. 86, 65.00 feet to Lot No. 106; thence North 60 degrees East, by the southern line of Lot No. 106, 166.76 feet to the point and place of BEOINNING. BEING Lot No. 107 on the Plan of Rana Villa Springs TerraCe as recorded in the Cumberland County Recorder's Office in Plan Book 2, Page 42. HAVING THEREON ERECTED A RESIDENTIAL DWELLING KI~OWN AS 1122 FERNWOOD AVENUE, CAMP HILL, PA. 17011 BEING THE SAME PREMISES WHICH Shawn M. Bowers and Lisa M. Grant by deed dated 11/3/00 and recorded 12/26/00 in Deed Book 236, page 719 granted and conveyed unto Shawn M. Bowers. TO BE SOLD AS THE PROPERTY OF SHAWN M. BOWERS ON JUDGMENT NO. 2001 3312. ASSESSMENT: 13~24-0799_251 FIRST UNION NATIONAL BANK, AS : IN THE COURT OF COMMON PLEAS TRUSTEE FOR PENNSYLVANIA : CUMBERLAND COUNTY, PENNSYLVANIA HOUSING FINANCE AGENCY, : PLAINTIFF : CIVIL ACTION - LAW VS. : SHAWN M. BOWERS, : NO. 2001 3312 DEFENDANT : IN MORTGAGE FORECLOSURE RE'i'UI~OF SERV~C~ I hereby certify that I have deposited in the U.S. Mails at Harrisburg, Pennsylvania on ~-//--~/ , a true and correct copy of the Notice of Sale of Real Estate pursuant to PA R.C.P. 3129.1 to the Defendants herein and all lienholders of record by regular first class mail (Certificate of Mailing form in compliance with U.S. Postal Form 3817 is attached hereto as evidence), and also to the Defendants by Certified Mail. Service addresses are as follows: Shawn M. Bowers 1122 Fernwood Avenue Camp Hill, PA 17011 Household Realty Corporation 25 Gateway Drive Gateway Square - Suite 107 Mechanicsburg, PA 17055 Stephanie Hollen 1122 Fernwood Avenue Camp Hill, PA 17011 Domestic Relations Office Cumberland County Courthouse /~ Hanover & High Streets Carlisle, PA 17013 By PURCELL, Plaintiff Attorneys for 1719 North Front Street Harrisburg, PA 17102 (717) 234-4178 LAW OFFICES PURCELL KRUG AND H 4LLER 1719 NORTH FRONT STREET HARRISBURG, PENNSYLVANIA 17102-2392 JOHN W. PI IRCELL TELEPHONE (717) 234-4178 JOSEPH NISSLEY {1910-'1~) IR)WARD B KRUG FORECLOSURE DEPT. FAX (717) 234-1206 ANTHONY DiSANTO [.EON P. HAI.LER OF COUNSEL J(')HN W. PURCEI.L JR. I{I,[[AN J. TYLER HERSHEY .11[ L M. WINEKA 1099 GOVERNOR ROAD NOTICE TO: Shawn M. Bowers 1122 Fernwood Avenue C~ Hill, PA 17011 Household Realty Corporation 25 Gateway Drive Gateway Square - Suite 107 N~chan£osburg, PA 17055 Stephanie Hollen 1122 Fernwood Avenue Camp Hill, PA 17011 Domestic Relations Office C~-herland County Courthouse Hanover & High Streets Carlisle, PA 17013 NOTICE IS HEREBY GIVEN tO the Defendants in the within action and those parties who hold one or more mortgages, judgments or tax liens against the real estate which is the subject of the Notice of Sale pursuant to Pennsylvania Rule of Civil Procedure 3129.1 attached hereto. YOU ARE HEREBY NOTIFIED that by virtue of a Writ of Execution issued out of the Court of Common Pleas of the within county on the judgment of the Plaintiff named herein the said real estate will be exposed to public sale as set forth on the attached Notice of Sale. YOU ARE FURTHER NOTIFIED that the lien you hold against the said real estate will be divested by the sale and that yo~ve an opportunity to protect your interest, if any, b~,~zf~otified of said Sheriff's Sale. By: ~ Y~ Leon P. Haller PA I/D.15700 Attorney for Plaintiff FIRST UNION NATIONAL BANK, AS : IN THE COURT OF COMMON PLEAS TRUSTEE FOR PENNSYLVANIA : CUMBERLAND COUNTY, PENNSYLVANIA HOUSING FINANCE AGENCY, : PLAINTIFF : CIVIL ACTION - LAW VS. : SHAWN M. BOWERS, : NO. 2001 3312 DEFENDANT : IN MORTGAGE FORECLOSURE NOTICE OF SHERIFF'S SALE OF REAL ESTATE PURSUANT TO PENNSYLVANIA RULE OF CIVIL PROCEDURE 3129 TAKE NOTICE: That the Sheriff's Sale of Real Property (real estate) will be held: DATE: WEDNESDAY, DECEMBER 5, 2001 TIME: 10:00 O'clock A.M. LOCATION: Commissioner's Hearing Room 2nd Floor Cumberland County Courthouse Carlisle, Pennsylvania 17013 THE PROPERTY TO BE SOLD is delineated in detail in a legal description mainly consisting of a statement of the measured boundaries of the property, together with a brief mention of the buildings and any other major improvements erected on the land. (SEE DESCRIPTION ATTACHED) THE LOCATION of your property to be sold is: 1122 FERNWOOD AVE~um CAMP HILL CUMBERLAND COUNTY PENNSYLVANIA THE JUD~MENTunder or pursuant to which your property is being sold is docketed in the within Commonwealth and County to: NO. 2001 3312 THE NAME(S) OF THE OWNER(S) OR REPUTED OWNERS of this property is: SHAWN M. BOWERS A SCHEDULE OF DISTRIBUTION, being a list of the persons and/or governmental or corporate entities or agencies being entitled to receive part of the proceeds of the sale received and to be disbursed by the Sheriff (for example, to banks that hol~mortgagas an~ municipalities that are owe~ taxes) will be filed by the Sheriff of this County thirty (30) days after the sale and distribution of the proceeds of sale in accordance with this schedule will, in fact, be made unless someone objects by filing exceptions to it within ten (10) days of the date it is filed. Information about the Schedule of Distribution may be obtained from the Sheriff of the Court of Common Pleas of the within County at the Courthouse address specified herein. THIS PAPER IS A NOTICE OF THE TIME AND PLACE OF THE SALE OF YOUR PROPERTY. IT HAS ~ ISSUED BECAUSE THERE IS A ~u'DG~ENT AGAINST YOU. IT MAY CAUSE YOUR PROPerTY TO BE ~LDr TO BE SOLD OR TAKEN TO PAY THE JUDGMENT. You may have legal rights to prevent your property from being taken away. A lawyer can advise you more specifically of these rights. If you wish to exercise your rights, YOU MUST ACT PROMPTLY. YOU SHOULD TAKE THIS PAPER TO YOUR LAWYER AT ONCE. GO TO OH TELEPHONE THE OFFICE SET FORTH BELOW TO FIND OUT WHEHE YOU CAN GET FREE LEGAL ADVICE: Cumberland County Bar Association 2 Liberty Avenue Carlisle, Pennsylvania 17013 717-249-3166 Legal Services, Inc. 8 Irvine Row Carlisle, PA 17013 717-243-9400 THE LEGAL RIGHTS YOU MAY HAVE AREs 1. You may file a petition with the Court of Common Pleas of the within County to open the judgment if you have a meritorious defense against the person or company that has entered judgment against you. You may also file an petition with the same Court if you are aware of a legal defect in the obligation or the procedure used against you. 2. After the Sheriff's Sale you may file a petition with the Court of Common Pleas of the within County to set aside the sale for a grossly inadequate price or for other proper cause. This petition MUST BE FILED BEFORE THE SHERIFF'S DEED IS DELIVERED. 3. A petition or petitions raising the legal issues or rights mentioned in the preceding paragraphs must be presented to the Court of Common Pleas of the within County. The petition must be served on the attorney for the creditor or on the creditor before presentation to the court and a proposed order or rule must be attached to the petition. If a specific return date is desired, such date must be obtained from the Court Administrator's Office - Civil Division, of the within County Courthouse, before a presentation of the petition to the Court. A copy of the Writ of Execution is attached hereto. PURCELL, KRUG & HALLER Attorneys for Plaintiff 1719 North Front Street Harrisburg, PA 17102 (717) 234-4178 ALL THAT CERTAIN tract or parcel of land situate in the Township of Lower Allen, Cumberland County, Pennsylvania, bounded and described as follows: BEGINNIN~ at the point of intersection of the western line'of Fernwood Avenue and the line of adjoiner between lots numbered 106 and 107 aon the hereinafter mentioned plan of lots, being 130.00 feet in a southerly direction by the 'western line of Fernwood Avenue from Glenwood Avenue; thence South 30 degrees East by the western line of Fernwood Avenue, 65.00 feet to Lot NO. 108; thence South 60 degrees West by the northern line of Lot No. 108, 166.75 feet to Lot No. 86; thence North 30 degrees West by the eastern line of No. 86, 65.00 feet to Lot No. 106; thence North 60 degrees East, by the southern line of Lot No. 106, 166.76 feet to the point and place of BEGINNING. BEING Lot No. 107 on the Plan of Rana Villa Springs Terra6e as recorded in the Cumberland County Recorder'a Office in Plan Book 2, Page 42. HAVING THEREON ERECTED A RESIDENTIAL DWELLING KNOWN AS 1122 FERNWOOD AVENUE, CAMP HILL, PA. 17011 BEING THE SAME PREMISES WHICH Shawn M. Bowers and Lisa M. Grant by deed dated 11/3/00 and recorded 12/26/00 in Deed Book 236, page 719 granted and conveyed unto Shawn M. Bowers. TO BE SOLD AS THE PROPERTY OF SHAWN M. BOWERS ON JUDGMENT NO. 2001 3312. ASSESSMENT: 13-24-0799-251 Re: PHFA v. Bowers Cumberland Sales 12/5/01 U. S. POSTAL SERVICE CERTIFICATE OF NAILIN~ (In co~l~anee with Postal Service Form 3877) Received from: Purcell, Krug &Haller Postage: 1719 North Front Street Harrisburg, PA 17102 One piece of ordinary mail addressed to: Postmark: Shawn M. Bowers 1122 Pernwood Avenue Camp Hill, PA 17011 U. S. POSTAL SERVICE CERTIFICATE OF MAILING (In C~.liance with Postal Service Form 3877) Received from: Purcell, Krug &Haller Postage: 1719 North Front Street Harrisburg, PA 17102 One piece of ordinary mail addressed to: Postmark: Household Realty Corporation 25 Gateway Drive Gateway Square - Suite 107 Mechanicsburg, PA 17055 U. S. POSTAL SERVICE CERTIFICATE OF MAILING (In comDliance with Postal Service Form 3877) Received from: /~/-~ Purcell, Krug &Haller Postage: 1719 North Front Street Harrisburg, PA 17102 One plece of ordinary mail addressed ~..... Stephanie Hollen 1122 Fernwood Avenue .... Camp Hill, PA 17011 U. S. POSTAL SERVICE CERTIFICATE OF MAILING (In compliance with Postal Service Form 3877) Received from: Purcell, Krug &Haller Postage: 1719 North Front Street Harrisburg, PA 17102 One piece of ordinary mail addressed to: Postmark: Domestic Relations Office Cumberland County Courthouse Hanover & High Streets Carlisle, PA 17013 FIRST UNION NATIONAL BANK, AS : IN THE COURT OF COMMON PLEAS TRUSTEE FOR PENNSYLVANIA : CUMBERLAND COUNTY, PENNSYLVANIA HOUSING FINANCE AGENCY, : PLAINTIFF : CIVIL ACTION - LAW VS. : SHAWN M. BOWERS AND : NO. 2001 3312 LISA M. GRANT, : DEFENDANTS : IN MORTGAGE FORECLOSURE PRAECIPE TO REMOVE DEFENDANT AND RELEASE FROM LIABILITY TO THE PROTHONOTARY; The above named defendant, LISA M. ~RANT, has been released fro~ liability and should be removed as a Defendant in the above action. BY:~~/~~ #15700 PURCELL, KRUG & HALLER Attorneys for Plaintiff 1719 North Front Street Harrisburg, PA 17102 (717) 234-4178 Dated: September 12, 2001 STATE OF PENNSYLVANIA, } COUNTY OF CUMBERLAND ss. Robert P Ziegler .................................................................... Recorder o! Deeds in and for mid County ~nd State do'herchy ceflify that thc Sheriff's Deed in which ................ SEcretary O£ HOusin8 & Urbaz~ Der o£ l~ashin§ton D C ..................................................................................... is th~, grantee thc stone having been sold to sald gruntee oa thc .............................. d~y of Dec ........................................ A. D., ..' ..... , under and bH v/rtoc o( u wxlt Execut ion 12 th ................................................ hued on thc ..................................... September day ~f ........ ~ ................ A.D., 01 ..... .s out of thc Court of Comman Pleas of said County'~s Civil O1 .................................................................................. Term, i ...... Number. 3312 _. . . First union Na~'l Bk t-r £or Penna Housing Fin Agency ............. s it ~ Suit of ............................................................... Shawn I~ Borers ................................... against .................................................... is duly nmoeded in Shetlfrs Deed Book No. .... .2_~= 9= .... ,~.l~lag6c ............. IN TESTIMONY WHF.,REOF, I have hcmmto _Z_/. , set m~_ and ,d..seal of 'd office thh ......... da), of_. --~ ....... Ilecofder d Ikeds, ~umberbnd {bunty, My Commi~ion Expires the Firit I&mday First Union National Bank, as Trustee In The Court of Common Pleas of For Pennsylvania Housing Finance Agency Cumberland County, Pennsylvania VS Writ No. 2001-3312 Civil Term Shawn M. Bowers Kenneth E. Gossert, Deputy Sheriff, who being duly sworn according to law, states that on Sept. 28, 2001 at 7:45 o'clock P.M., E.D.S.T., he served a true copy ofthe within Real Estate Writ, Notice, Poster and Description, in the above entitled action, upon the within named defendant, to wit: Shawn Bowers, by making known unto Shawn Bowers personally at The Cumberland County Prison, 1101 Claremont Road, Carlisle, Pennsylvania, its contents and at the same time handing to him personally the said true attested copy of the same. Kenneth E. Gossert, Deputy Sheriff, who being duly sworn according to law, states that on Sept. 28, 2001 at 5:05 P.M., E.D.S.T., he posted a true copy of the within Real Estate Writ, Notice, Poster and Description, in the above entitled action, upon the property of Shawn M. Bowers, located at 1122 Ferowood Ave., Camp Hill, Pennsylvania, according to law. R. Thomas Kline, Sheriff, who being duly sworn according to law says he served the above Real Estate Writ, Notice, Poster and Description in the following manner: The Sheriffmailed a notice of the pendency of the action to one of the within named defendants to wit: Shawn M. Bowers, by regular mail to his last known address of The Cumberland County Prison, 1101 Claromont Road, Carlisle, PA 17013. This letter was mailed under the date of October 2, 2001 and never returned to the Sheriff's Office. R. Thomas Kline, Sheriff, who being duly sworn according to law, says that after due and legal notice had been given according to laxv, exposed the within described premises at public venue or outcry at the Court House, Carlisle, Cumberland County, Pennsylvania on December 5, 2001 at 10:00 o'clock A.M., EST. He sold the same for the sum orS1.00 to Attorney Leon P. Hailer for The Secretary of Housing and Urban Development of Washington, D.C., his successors and/or assigns. It being the highest bid and best price received for the same, The Secretary of Housing and Urban Development of Washington, D.C., his successors and/or assigns of c/o Golden Feather Realty at 1600 Sacramento Inn Way, Suite 220, Sacramento, CA 95815, being the buyer in this execution paid SheriffR. Thomas Kline the sum of$843.18, it being costs. Sheriff's Costs: Docketing $30.00 Poundage 16.53 Posting Bills 15.00 Advertising 15.00 Acknowledging Deed 30.00 Auctioneer I 0.00 Law Library .50 Prothonotary 1.00 Mileage 13.00 Certified Mail 1.74 Levy 15.00 Surcharge 20.00 Law Journal 297.95 Patriot News 300.30 Share of Bills 25.66 Distribution of Proceeds 25.00 Sheriff's Deed 26.50 $843.18 pd by atty. This 19~ day o~__ R. Thomas Kline, Sheriff 2oo , /P~othonotary k~ BY~ R~al Estate Deputy FIRST UNION NATIONAL BANK, AS : IN THE cOURT OF COMMON PLEAS TRUSTEE FOR PENNSYLVANIA : CUMBERLAND COUNTY, PENNSYLVANIA HOUSING FINANCE AGENCY, : PLAINTIFF : CIVIL ACTION - LAW VS. : SHAWN M. BOWERS, : NO. 2001 3312 DEFENDANT : IN MORTGAGE FORECLOSURE AFFIDAVIT FURgUANT TO P.R.C.P. 3129.1 The Plaintiff in the above action, by its attorneys, Purcell, Krug &Haller, sets forth as of the date the praecipe for the writ of execution was filed, the following information concerning the · real property located at 1122 FERNWOOD A%~ENUE, CA~P HILL, PA~ 1. Name and address of the Owner(s) or Reputed Owner(s): Shawn M. Bowers 1122 Fernwood Avenue Camp Hill, PA 17011 2. Name and address of Defendant(s) in the Judgment, if different from that listed in (1) above: SAME 3. Name and address of every Judgn~snt creditor whose judgment appears of record on the real property to be sold: 4. Name and address of last recorded holder of every mortgage of record: PLAINTIFF HEREIN (AND ANY OTHERS AS NOTED BELOW): Household Realty Corporation 25 Gateway Drive Gateway Square - Suite 107 Mechanicsburg, PA 17055 5. Name and address of every other person who has any record lien on the property: 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: UNKNOWN FIRST UNION NATIONAL BANK, AS : IN THE COURT OF COMMON PLEAS TRUSTEE FOR PENNSYLVANIA : CUMBERLAND COUNTY, PENNSYLVANIA HOUSING FINANCE AGENCY, : PLAINTIFF : CIVIL ACTION - LAW VS. : SHAWN M. BOWERS, : NO. 2001 3312 DEFENDANT : IN MORTGAGE FORECLOSURE NOTICE OF SHERIFF'S SALE OF REAL ESTATE PURSUANT TO PENNSYLVANIA R~ILE OF CIVIL PROCEDURE 3129 TAKE NOTICE: That the Sheriff's Sale of Real Property (real estate) will be held: DATE: WEDNESDAY, DECEMBER 5, 2001 TIME: 10:00 O'clock A.M. LOCATION: Commissioner's Hearing Room 2nd Floor Cumberland County Courthouse Carlisle, Pennsylvania 17013 THE PROPERTY TO BE SOLD is delineated in detail in a legal description mainly consisting of a statement of the measured boundaries of the property, together with a brief mention of the buildings and any other major improvements erected on the land. (SEE DESCRIPTION ATTACHED) THE LOCATION of your property to be sold is: 1122 FEP. NWOOD AVENUE CAMP HILL CUMBERLAND COUNTY PENNSYLVANIA THE JUDGMENT under or pursuant to which your property is being sold is docketed in the within Commonwealth and County to: NO. 2001 3312 THE NAME(S) OF THE OWNER(S) OR REPUTED OWNERS of this property is: SHAWN M. BONERS A SCHEDULE OF DISTRIBUTION, being a list of the persons and/or governmental or corporate entities or agencies being entitled to receive part of the proceeds of the sale received and to be disbursed by the Sheriff (~or exmn~le, to banks that hold mortgages and municipalities that are owed taxes) will be filed by the Sheriff of this County thirty (30) days after the sale and distribution of the proceeds of sale in accordance with this schedule will, in fact, be made unless someone objects by filing exceptions to it within ten (10) days of the date it is filed. Information about the Schedule of Distribution may be obtained from the Sheriff of the Court of Common Pleas of the within County at the Courthouse address specified herein. THIS PAPER IS A NOTICE OF THE TIME AND PLACE OF THE SALE OF YOUR PROPERTY. IT HAS B~N ISSUED BECAUSE T__U~_~ IS A JUDgMeNT AGAINST YOU. IT MAY CAUSE YOUR PROPERTYTO BE ~mT.~, TO BE SOLD OR TAKEN TO PAY THE J~'D~MENT. You may have legal rights to prevent your property from being taken away. A lawyer can advise you more specifically of these rights. If you wish to exercise your rights, YOU MUST ACT PROMPTLY. YOU SHOULD TAKE THIS PAPER TO YOUR LAWYER AT ONCE. GO TO OR TELEPHONE THE OFFICE SET FORTH BELOW TO FIND OUT WHERE YOU CAN GET FREE LEGAL ADVICE: Cumberland County Bar Association 2 Liberty Avenue Carlisle, Pennsylvania 17013 717-249-3166 Legal Services, Inc. 8 Irvine Row Carlisle, PA 17013 717-243-9400 THE LEGAL RIGHTS YOU MAY HAVE ARE: 1. You may file a petition with the Court of Common Pleas of the within County to open the judgment if you have a meritorious defense against the person or company that has entered judgment against you. You may also file an petition with the same Court if you are aware of a legal defect in the obligation or the procedure used against you. 2. After the Sheriff's Sale you may file a petition with the Court of Common Pleas of the within County to set aside the sale for a grossly inadequate price or for other proper cause. This WRIT OF EXECUTION and/or ATI'ACHMENT COMMONWEALTH OF PENNSYLVANIA) NO. 01-3312 CIVIL ~ TEt~I COUNTY OF CUMSERLAND) CIVIL ACTION - LAW TO THE SHERIFF OF ~berland COUNTY: To satisfy the debt, interest and costs due First Union National Bank as Turstee for Pennsylvania Housing Finance Agency PLAINTIFF(S) I~m Shawn M. Bowers, 1122 Fernwocd Avenue, C~,~ Hill, PA 17011 DEFENDANT(S) (1) You are directed to levy upon the property of the defendant(s) and to sell See Lecjal Description (2) You are also directed to attach the property of Ihe defendant(s) not levied upon in the possession of __ GARNISHEE(S) as follows: and to notify the garnishee(s) that: (a) an attachment has been issued; (b) the garnishee(s) is/are enjoined from paying any debt to or for the account of the defendant(s) and from delivering any propady of the delendant(s) or otherwise disposing thereof; (3) If proparty bt the defendant(s) not levied upon an subject lo attachment is Iound in the passession of anyone bther than a named garnishee, you are directed to notify him/her that he/she has been added as a garnishee and is enjolnod as above stated. Aniount Due $84,051.03 L.L. $.50 at $10.77 per diem to sale date $1.00 Interest ,.~ n.~ .~ Due Prothy Atty'$~omm % OlherCosts Late Charges at $17.15 per month to ~.~ Sale Date $85.75 -- Escrow Deficit $2000. Plaintiff Paid Date: Septenber 12, 2001 Curtis R. Long Prothonotary, Civil Division C. Deputy REQUESTING PARTY; Name Leon P. Haller, F_.,sq. Address: 1719 North F~u~'c Street Harrisburg, PA 17102 Attorney for: Telephone: 717-~34-4178 Supreme Court iD No. 15700 REAL ESTATE SALE No. On September 18, 2001, the sheriff levied upon the defendant's interest in the real property situated in Lower Allen Township, Cumberland County, PA, known and numbered as 1122 Femwood Ave., Camp Hill, and more fully described on Exhibit "A" filed with this writ and by this reference incorporated herein. Date: September 18, 2001 By: Real Estate Deputy THE PATRIOT NEWS THESUNDAY PATRIOT NEWS Proof of Publication UnderAct No, 587, Approved May16, 1929 Commonwealth of Pennsylvania, CourW of Dauphin} ss James L. Clerk being duly swom according to law, deposes and says: That he is the Acounts Receivable Manager of The Patriot News Co., a corporation organized and existing under the laws of the Commonwealth of Pennsylvania, with its principal office and place of business at 812 to 818 Market Street, in the City of Harrisburg, County of Dauphin, State of Pennsylvania, owner and publisher of The ~ 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 cecurely attached hereto is exactly as pdnted and published in their regular dally and/or Sunday/ Metro editions which appeared on the 23rd and 30th day(s) of October and the 6th day(s) of November 2001. That neither he nor said Company is interested in the subject matter of said printed notice or advertising, and that all of the allegations of this statement as to the time, place and character of publication ara true; and That he has personal knowledge of the facts aforesaid end 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 ' '~'~' ~in Miscellaneous Book "M", the office for the Recording of Deeds in and for said County of Daup Volume 14, Page 317. PUBLICATION ........................... { ............................................................. COPY e.,~,,, ,u u,,u suos.%lb?u outu, u ~,..btJ~l~ 19th day o~Nov..~er 2001 A.D. Te~y L. ~, NOla~y Pubic 8 A I. E #47 ,.~,~;. I ~I, AI~A~ m layC.,e~,i~Ex~.~JuneS, ax,,, r NOT~'RY PUBLIC ~ '¢Ml~na My commission expires June 6, 2002 ~ ~Rmm~ ~ CUMBERLAND COUNTY SHERIFFS OFFICE ~/1O~Q~ ~,~ ~ m==l ~' l=~ CARLISLE, PA. 17018 19~....c~,,r~,,~,,~ Statement of Advertising Costs F~e~O~ ~1~,~"=~'~ ti= d TO THE PATRIOT'NEWS CO., Dr. ! ~ ~ I., re.lind 1~ .,a I~'/~ For publishing the notice or publication attached hereto on the above stated dates $ 298.80 !l~0]~'ka'a~Y;Ima~i~l~'b/II~e~ Notary Fee(s) $ 1.50 i~ ~ ~ ~,,mt ~ ~ Probating same : eta~tt~ sa~ 30 ~ Total $ 300.30 ,~,,~=,~t~,~,,~,m~mn Publlaher'a Racelpt for AdverUalng Coat The Patriot News Co., pubtisher of ~and Th '- , newspapers of general circulation, hereby acknowledge receipt of the aforesaid notice and publication costs and certifies that the same have been duly paid. PROOF OF PUBLICATION OF NOTICE IN CUMBERLAND LAW JOURNAL (Under Act No. 587, approved May 16, 1929), P. L. 1784 STATE OF PENNSYLVANIA : : SS. COUNTY OF CUMBERLAND : Roger M. Morgenthal, Esquire, Editor of the Cumberland Law Journal, ofthe 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 Sanuary 2, 1952, and designated by the local courts as the official legal periodical for the publication of all legal notices, and has, since .lanuary 2, 1952, been regularly issued weekly in the said County, and that the printed notice or publication attached hereto is exactly the same as was printed in the regular editions and issues of the said Cumberland Law Journal on the following dates, viz: October 12, 19, 26, 2001 Affiant further deposes that he is authorized to veril~y 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 t~ue. .................... ,.. Ror M~Mor nthal, Editor SWORN TO AND SUBSCRIBED before me this 26 day of~