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Home My WebLink About04-4888 Attorney for Plaintiff Martha E. Van Rosenstiel, P. C. Martha E. Von Rosenstiel 16 South Lansdowne Avenue P.O. Box 457 Lansdowne, PA 19050 610 623-2660 Attorney LD.# 52634 GREEN TREE CONSUMER DISCOUNT COMPANY 7360 SOUTH KYRENE ROAD, MSD TEMPE AZ 85282 PLAINTIFF COURT OF COMMON PLEAS CUMBERLAND COUNTY CASE NO: 64 - 4fR~ Cl o,'(T E./J...1Y1 VS. GORDON E. LUCE OR OCCUPANTS 91 SANDBANK ROAD SHIPPENSBURG PA 17257 DEFENDANT CIVIL ACTION - EJECTMENT NOTICE ADVISO 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 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 ELEGIBLE PERSONS AT A REDUCED FEE OR NO FEE. Le han demandado a usted en la corte. Si usted quiere defenderse de estas demandas expuestas en [as paginas siguientes, usted tiene veinte (20) dias de plaza al partir de la fecha de la demanda y la notificacion. Hace falta a sentar una comparencia escrita 0 en persona 0 con un abogado y entregar a la corte en forma escrita sus defensas 0 sus objeciones alas demandas en contra de su persona. Sea a visado que si usted no se defiende, la corte toma ra medidas y puede continuar la demanda en contra suya sin previa aviso 0 notificacion. Ademas, 1a corte puede decidir a favor del demandante y requiere que usted cumpla con todas las provisiones de esta demanda. U sted puede perder dinero 0 sus propiedades 0 otros de rechos importantes para usted. LLEVE ESTA DEMANDA A UN ABOGADO INMEDIATAMENTE. SINOTIENEABOGADO VAYA EN PERSONA 0 TELEFONA A LA OFICINA ESCRITA ABAJO . ESTA OFICINA LE PUEDE PROVEER INFORMACION SOBRE COMO CONTRATARA UN ABOGADO. SI USTED NO TIENE EL DINERO SUFICIENTE PARA CONTRATARA UN ABOGADO, LE PODEMOS DAR INFORMACION SOBRE AGENCIAS QUE PROVEEN SERVlCIO LEGAL A PERSONAS ELEGIBLE PARA SERVlCIOS A COSTO REDUCIDO 0 GRATUlTO. DAUPHIN COUNTY LAWYER REFERRAL SERVICES 213 NORTH FRONT STREET, HARRISBURG, PA 17101 (717) 232-7536 Martha E. Yon Rosenstiel, P.C. Martha E. Yon Rosenstiel 16 South Lansdowne A venue P.O. Box 457 Lansdowne, PA 19050 610 623-2660 Attorney I.D.# 52634 Attorney for Plaintiff GREEN TREE CONSUMER DISCOUNT COMPANY 7360 SOUTH KYRENE ROAD, MSD TEMPE AZ 85282 PLAINTIFF COURT OF COMMON PLEAS CUMBERLAND COUNTY CASE NO: 04 - 41'J'cP CILJi...t-rftL~ YS. GORDON E. LUCE OR OCCUPANTS 91 SANDBANK ROAD SHIPPENSBURG PA 17257 DEFENDANT CIVIL ACTION - EJECTMENT 1. Plaintiff, Green Tree Consumer Discount Company, is the owner of premises known as 91 Sandbank Road Shippensburg PA 17257, more fully described in the legal description attached hereto as Exhibit I. 2. Plaintiff claims title to the aforesaid property by virtue of a Sheriff's sale held on September 8th, 2004 in the execution of a judgment in mortgage foreclosure obtained in the Court of Common Pleas of Cumberland County, Docket No. 02-1458 Civil Term where plaintiff was the successful bidder, and became the owner of the said property. 3. Plaintiff, by virtue of the aforesaid title, is the owner in fee of the said premises, and is entitled to possession thereof. The defendants Gordon E. Luce or Occupants are occupying the said premises without right, and so far as the plaintiff is informed, without claim of title. WHEREFORE, plaintiff brings this suit and seeks 0 recover possession of said premises. Ill. / Martha E. Yon Rosenstiel Attorney for Plaintiff I VERIFICATION I verify that the statements made in the foregoing document(s) are true and correct. I understand that false statements herein are made subject to penalties of 18 Pa C.S. Section 4904 relating to unsworn falsification to authorities. By: ,/L- ~rtha E. Von Rosenstiel, Esq. /_ttorney for Plaintiff UESCRU"rION ...,L THOSE TWO CERTAIN tracr~i of lanel wirh improvements rhe:eon erected, siNale 1)} SouthamptOn fO>\l1Ship, Cumberland County, PelIDsylvania, bounded Md described as follows; \ TRACT NO.1: BEGINNING at a srone in the middle of public road, Township Route 317, being also known as tbe road leading from Helm Saw Mill to Big Pond Furnace; thence along said road. East seven (7) rods w a post; thence South along lands formerly of Christopher Helm, of which rhis was a part, tl'n (10) rods to a post; thence along the same lands. 'Vest eight (8) rods to a post; thenct. North along lands forme-IIY of Highlands Heirs to the place of Beginning. CONTAINING about seventy and one,half (70 1/2) perches, more or less. Having erected thereon 9. frame and log two-story dwelling house and outbuilding. TRACT NO.2: ALL THAT'CERTAIN lot of sprout land situare in Southampton Township, Cumberland County, Pennsylvania. along public road, Township Route 317, being also k.nown as the road le;:\ding from Huckleberry Land to Big Pond, bounded and described as follows: ON the Easr by Lands now or formerly of George Eckenrode; on the South by lands now 0]: formed'! of John Russell; on the West by lands now or formerly of P.F. Taylor; and on the Norrh by the. aforesaid public road. CONTAINING one hundred fifty (150) rods, more or less. EXCEPTING, HOWEVER, a parcel of rhe above tract of land containing 22,895 square feet, wpjeh was conveyed by Elwood F. Reck and Janet P. Reck, his wife, by their deed dared September 6, 1973, and recorded in the Office of the Recorder of Deeds ar Cnmberland County, Pennsylvania, in De~d Book "1", Volume 25, Page 691, to Richard L. Davidson and Deboral1 A. Davidson. his wife Tax Parcel # 13-0106-079 AND BEING the same premises which were sold to Green Tree Consumer Discount Company by the Sheriff of Cumberland County on September 8th, 2004 in execution of a judgment in mortgage foreclosure entered in the Court of Common Pleas of Cumberland COlIDty in the matter of Green Tree Consumer Discount Company v. Gordon E. Luce, Docket No.02-1458 Civil Term ~ ~ .-.> 0 ~ (") C.-:J -n AJ ~ C'J .>C- ..... t u') .,: -r, ,'" rf'l"('; ~ "T\ :qJt;i l'J (),(") C) ;-f', "- W ',.- '-~", <q ~ ,'--.., ...:., r- , i\ ..c:: .- J:^ ~ 6' ~ 0 .' U:.' '\;,. ---L SHERIFF'S RETURN - REGULAR CASE NO: 2004-04888 P COMMONWEALTH OF PENNSYINANIA: COUNTY OF CUMBERLAND GREEN TREE CONSUMER DISCOUNT vs LUCE GORDON E ET AL CPL. MICHAEL BARRICK , Sheriff or Deputy Sheriff of Cumberland County,Pennsylvania, who being duly sworn according to law, says, the within COMPLAINT - EJECTMENT was served upon LUCE GORDON E the DEFENDANT , at 1740:00 HOURS, on the 30th day of September, 2004 at 91 SANDBANK ROAD SHIPPENSBURG, PA 17257 GORDON E. LUCE by handing to a true and attested copy of COMPLAINT - EJECTMENT together with and at the same time directing His attention to the contents thereof. Sheriff's Costs: Docketing Service Affidavit Surcharge 18.00 12.58 .00 10.00 .00 40.58 Sworn and Subscribed to before nysJthis b 4 day of L8 ~1 AD / . P~O'ho~7J (~CJ So Answers: .r~~ R. Thomas Kline 10(01(2004 MARTHA VON ROSENSTIEL By: A~~--1/ ~;:;-ty She Martha E. Von Rosenstiel P.C. Martha E.Rosenstiel 16 South Lansdowne Avenue P.O. Box 457 Lansdowne Pa. 19050 610 623.2660 Attorney 1.0. # 52634 OCT 1 9 2004~ Green Tree Consumer Discount Company 73760 South Kyrene Road ,MSD Temepe ,AZ. 85282 PLAINTIFF Court of Common Pleas Cumberland County VS. GORDON LUCE Or OCCUPANTS 91 SAND BANK ROAD SHIPPENSBURG,PA.17257 DEFENDENT CASE #: 0-41- 4888 CIVIL TERM Docket # 11)2-1458 CIVIL ACTION - EJECTMENT ANSWERING A BRIEF, TO PLAINTIFF'S MOTION FOR EJECTIONMENT ..PLEASE, NOTIFY US THE DATE CAlSE TRIAL WILL BE ? GORDON E. LUCE OR OCCUPANTS ,Pro Se 91 SAND BANK ROAD SHIPPENSBURG, PA. 17257 ON THE BRIEF Answers : GORDON LUCE, Pro Se; 1] False Statements Made Subject to Title 18 Pa.S.C. Section 4904 2] Elder Abuse Financial Law & Related to Housing ,MORTGAGE FRAUD. 3] so Far withOut Mediation or Arbitration offered 4] Refusal, of all offers to settle by CERTIFIEID MAIL RETURNS LEFT UNANSWERED AS , ...'" Monetary Offers """" Please Allow a Notification By Certified Mail, of Court Date setting TO ME :::: Gordon Luce S I.: lJ d. M'o::R c:e.. 1:e ' , q'trY'dtffi, ~tJ.LL zt OcCl{~ q( ~~ I9()Nt g~ ~hlwe~~ b~va I (JQ /7J,o'l-f64~ Cj arcLnt .~~ Dd-,,1er- (~J ~o~4- .- lO (<J "".,,," Cl.- C> <....J -- 'c...:) c:> - u.w c~'"} () ~~ " " Martha E. Von Rosenstiel P.C. Martha E.Rosenstiel 16 South Lansdowne Avenue P.O. Box 457 Lansdowne Pa. 19050 610 623-2660 Attorney I.D. # 52634 OCT 1 9 2004 r Green Tree Consumer Discount Company 73760 South Kyrene Road ,MSD Temepe ,AZ 85282 PLAINTIFF Court of Common Pleas Cumberland County VS. GORDON LUCE Or OCCUPANTS 91 SAND BANK ROAD SHIPPENSBURG,PA. 17257 DEFENDENT CASE #: 04.. 4888 CIVIL TERM Docket # (]i2-1458 CIVIL ACTION - EJECTMENT ANSWERING A BRIEF, TO PLAINTIFF'S M01rlON FOR EJECTIONMENT ..PLEASE, NOTIFY US THE DATE CAS,E TRIAL WILL BE ? GORDON E. LUCE OR OCCUPANTS , Pro Se 91 SAND BANK ROAD SHIPPENSBURG, PA. 17257 ON THE BRIEF Answers : GORDON LUCE, Pro Se; 1] False Statements Made Subject to Title 18 Pll.S.C. Section 4904 2] Elder Abuse Financial Law & Related to HOUlsing ,MORTGAGE FRAUD. 3] so Far withOut Mediation or Arbitration offered 4] Refusal, of all offers to settle by CERTIFIE[1 MAIL RETURNS LEFT UNANSWERED AS , """ Monetary Offers """" Please Allow a Notification By Certified Mail, of Court Date setting TO ME :::: Gordon Luce S'E'I>lJ- toloi.C-4... -k ' ~()y"bY\. L..IA~ d C)CCl.{pa~ "t{ <a~ BONI': glhJd~ SJ'1\~~t4t;. ~411 ~- /1},,5 7- ~(j,4,'3> 1~ ilUML C3a-+o(h1' .t91 ;9004-- 'j'; /, ...1 Martha E. Von Rosenstiel P.C. Martha E.Rosenstiel 16 South Lansdowne Avenue P.O. Box 457 Lansdowne Pa. 19050 610 623.2660 Attorney 1.0. # 52634 oel 1 9 2004 ~ Green Tree Consumer Discount Company 73760 South Kyrene Road ,MSD Temepe ,AZ 85282 PLAINTIFF Court of Common Pleas Cumberland County VS. GORDON LUCE Or OCCUPANTS 91 SAND BANK ROAD SHIPPENSBURG,PA. 17257 DEFENDENT CASE #: 04. 4888 CIVIL TERM Docket# 02-1458 CIVIL ACTION. EJECTMENT ANSWERING A BRIEF, TO PLAINTIFF'S MOTION FOR EJECTION ME NT ..PLEASE, NOTIFY US THE DATE CASE TRIAL WILL BE ? GORDON E. LUCE OR OCCUPANTS ,PI~O Se 91 SAND BANK ROAD SHIPPENSBURG, PA. 17257 ON THE BRIEF Answers : GORDON LUCE, Pro Sej 1] False Statements Made Subject to Title 18 PSI.S.C. Section 4904 2] Elder Abuse Financial Law & Related to Hou:sing ,MORTGAGE FRAUD. 3] so Far withOut Mediation or Arbitratil)n offered 4] Refusal, of all offers to settle by CERTIFIED MAIL RETURNS LEFT UNANSWERED AS , ...... Monetary Offers ",,,,,, Please Allow a Notification By Certified Mail, of Court Date setting TO ME :::: Gordon Luce 5e:,..d twhtL -/-0 ~ ca o'{C1tm k $f 6CLUpo ~ '11 $,~J ~(mt. I<.d cshqJpplIsbr./,1 / p~~ 11J.57J"(P4~ Lf~ cYctU- od-{)be.f' it; ~o4 Martha E. Von Rosenstiel P.C. Martha E.Rosenstiel 16 South Lansdowne Avenue P.O. Box 457 Lansdowne Pa. 19050 610 623-2660 Attorney 1.0. # 52634 OCT 16 of~ I Green Tree Consumer Discount Company 73760 South Kyrene Road ,MSD Temepe ,AZ. 85282 PLAINTIFF Court of Common Pleas Cumberland County VS. GORDON LUCE Or OCCUPANTS 91 SAND BANK ROAD SHIPPENSBURG,PA. 17257 DEFENDENT CASE #: 04.. 4888 CIVIL TERM Docket # 02-1458 CIVIL ACTION - EJECTMENT ANSWERING A BRIEF, TO PLAINTIFF'S MOTION FOR EJECTIONMENT ..PLEASE, NOTIFY US THE DATE CAS I: TRIAL WILL BE ? GORDON E. LUCE OR OCCUPANTS , Pro Se 91 SAND BANK ROAD SHIPPENSBURG, PA. 17257 ON THE BRIEF Answers : GORDON LUCE, Pro Se; 1] False Statements Made Subject to Title 18 Pa.S.C. Section 4904 2] Elder Abuse Financial Law & Related to Hou!.ing ,MORTGAGE FRAUD. 3] so Far withOut Mediation or Arbitration offered 4] Refusal, of all offers to settle by CERTIFIED MAIL RETURNS LEFT UNANSWERED AS , """ Monetary Offers """" Please Allow a Notification By Certified Mail, of Clourt Date setting TO ME :::: Gordon Luce ~ €Kd w41ea.. :f-o', 1~('~ cVU#- 8$ OCCt.lr~- q ( all fJeI. eo Nt:. f2,()71d.~ 'ah\~~ey.l'5btt~1 Pa- /7J..&7-fID43 q~~ 6cAocbei-; 1<;, fj;tJoit '. "~ GREEN TREE CONSUMER DISCOUNT COMPANY COURT OF COMMON PLEAS CUMBERLAND COUNTY Plaintiff vs. Case No: 04-4888 GORDON E. LUCE or Occupants Defendants MOTION FOR SUMMARY JUDGMENT Plaintiff, by its undersigned counsel, respectfully moves this Honorable Court, pursuant to Pa,R.C,P. No, 1035.1, for the entry of summary judgment in favor of the plaintiff and against the defendants for possession of 91 Sandbank Road, Shippensburg, P A 17257, the relief requested in plaintiff's complaint, on the grounds that: 1. The pleadings are closed and time exists within which to dispose of this motion without delaying trial. 2. This Action in Ejectment was commenced by the filing of a Complaint on September 28, 2004. 3. The Sheriff's Sale through which plaintiff claims title occurred on September 8, 2004. 4. The Sheriff's Deed Poll vesting legal title in the plaintiff was executed on September 28, 2004, is recorded in the Office of the Recorder of Deeds of VERIFICATION I verify that the Statements made in the foregoing document are true and correct. I understand that false statements herein are made subject to penalties of 18 Pa C.S. Section 4904 relating to unsworn falsification to authorities. By: ~ ~CsNJCfY'..- Date: \ \- \\.0- 0&.\ - q;}, 09{ . G 4... Tax Parcel No. 39-13-0106-079 bOBCRT ',) ZIEGLER" (to L.. \ .. "-:r,OROEH Of DEeDS 1\ t. 'J ~ I i rl ~ : ) 1..- 'J _ ~) :'\ " 1 ! :.1 q r: 01 I ~- '\ C C \ " ' , ,. -' ~ J \.. : .1..' .....f\ ....k Know aU Men by these Presents lU6~ GCT 19 Prl 1 20 That I, R Thomas Kline, Sheriff of the County of Cumberland, In the State of Pennsylvania, for and in consideration of the sum of$40.0oo.oo. (Fortv Thousand Dollars), to me in hand paid, do hereby grant and convey to Green Tree Consumer Discount COUloanv REAL ESTATE SALE No. 34 Wrtt No. 2002-1458 CIvIl Term ConMCO ConIUmII' I*count Com..ny C/o CoMeco Finance CoqIoratIon Va Gordon E. Luoe and Gertrude Luee 8/'Va G. lucille Luce Atty: D8vId Comroe DESCRIPTION ALL TIiOSE TWO CERTAIN tracts of land with improvements thereon erected, situate in SoutbaTpm T~ OJnileItniOuty,~ bcuDdtnidrscrbd lIiI follows: TRACT NO. \: BEGINNING at a stone in the middle of public road, Township Route 317, being also known as the road leading from Helm Saw Mill to Big Pond Furnace; thence along said road, East seven (7) rods to a post; thence South along lands formerly of Christopher Helm, of which this was a part. ten (10) rods to a post; thence along the same lands. West eight (8) rods to a post; thence North along lands formerly of Highlands Heirs to the place of BEGINNING. CONTAINING about seventy and one-half (70 Y.) perches, more or less. Having erected thereon a frame and log two-story dwelling house and outbuilding. TRACT NO, 2: ALL THAT CERTAIN lot of sprout land situate in Southampton Township, Cumberland COlDlty. Pennsylvania, along public road, Township Route 3 I 7, being also kown as the road leading from Huckleberry Land to Big Pend, bounded and described as follows: ON the East by Lands now or formerly of George Eckenrode; on the South by lands now or fonnerly of John Russell; on the West by lands now or formerly ofP.F. Taylor, and on the North by the aforesaid public road. CONTAINING one hundred fifty (150) rods. more or less. EXCEPTING, however, a parcel of the above tract of land containing 22,895 square feet, which was conveyed by Elwood F. Keck and Janet P. Keck, his wife, by their deed dated September 6, 1973, and recorded in the Office of the Recorder of Deeds at Cumberland County. Pennsylvania, in Deed Book "I", Volume 25, Page 691, to Richard L. Davidson and Deborah A. Davidson, his wife. TAX PARCEL #13-0106-079. 800~ 265 Pl,~:~08 -........... . The same having been sold by me to the said grantee on the 8th day ofSeutember Anno Domini Two Thousand and.f!!!!l (2004) after due advertisement according to law, under and by Virtue of a Writ of Execution issued on the ll!J!.day of Mav Anno Domini ~ out of the Court of Common Pleas of Cumberland County, Pennsylvania, as of Civil TenD., Two Thousand and Two (2002) Number 1458 at the suit ofConseco Consumer Discount Comuany c/o Conseco Finance Coroor.tlon against Gordon E. Luce and Gertrude Luce aIkIa G. Lucille Luce. aOOK 265 PAcc40Ci9 . . In Witness Whereof, I have hereunto affixed my signature this 1 2thfay ofOctober Anno Domini Two Thousand and Four (2004) ~~ ~-;:7 ~-/~ R Thomas Kline, Sheri€' --=- Commonwealth of Pennsylvania, ss. County of Cumberland Before the undersigned, Curtis R Long, Prothonotary of the Court of Common Pleas of Cumberland County, Pennsylvania, personally appeared R Thomas Kline, Sheriff of Cumberland County aforesaid, and in due fonn of law declared that the facts Set forth in the foregoing Deed are true, and that he acknowledged the same in order that Said deed might be recorded. Witness my hand and seal of said Court, this 12tl'\iay of Oct.Anno Domini Two Thousand and Four (2004) I hereby certify that the residence And Post Office address of the Within Grantee is 7360 S. KVfene Road TeDlDe. AZ 85282 ~~~ j CC.t-il:[Y' 'l"l11" , -, t...., t-''-''''\l'(le~d . -'.. ... ... '.. ~.' ...... \.r ,-''-,u.... ; " ,""., .,,1.. ':-' I' ,,{'"1 -, ..' t PA 1~1 '--,L.lhv....r ..... ....;, 'vGlULY . ." '~ 4 -=2.. .'" ;;' /"{j" ~ Recorder of Deeds ~OOK 265 PAGE43iO REALTY TRANS FIR TAX .... N-w ":)1 r COMMONWeALTH Of PENN$VWANIA STATIMENT OF VALUE (;t ", 'OE'ARTMENT 0. REVENUE 'ap ........ ' U ~ <::'i IUHAU 0. INDCVIDUAI. TAXIS '1 \~ ~ HARRJ$::J-. ~21-O603 S.. R.ve.....!or Instructions b_ a-.w 10 ~~,.O'# Complele each section and file In dupUcate with Recorder of DMCh when (1) the fuU voluelconsicl<<atlon Is not..t forth in the deed, (2) when the deed is wilhout consideration, or by gift, or (3) a 'ax el(~ption is dolm-d, A Stat_nt of Volue I. not required if the trallsfer is wftolly exempt from tall: based on: (1) family r.lationihlp or (2) pvbnc utility eaQlMftt. If more space is needed, attach additional s,,",{sl. . A CORRESPONDENT.. All inquiries may be directed to the followina person: Nam. T.a.,hoM HUIIIb.r: IDavid B. Com roe ESQuire 1 AnoCod.1215-568-0400 s".., Addro.. City Slate 11608 Walnut St Ste 300 IPhiladelohia I [fKJ B TRANSFER DATA 0.. ef Au.pt.",. e(DocuM...t Grontor(,I/L.uMlsl Gnw.e(.ln.-{.J ISheriff of Cumberland County I IGreen Tree Consumer Discount Comoanv Sir.., Addr... . SIfMI Add,... lOne Courthouse Sq 117360 S. Kyrene Rd City Slate ZIp Cade Oty ICarlisle liPs I 117013 IITemoe C PROPERTY LOCATION SIr... Adeh" 191 Sandbank Rd. COUnty ICumberland D VALUATION DATA 1. Actual CCldl CanslderCltlOft 1$40,000.00 4. CDllftty AI"" Va.... 1$55.150.00 E eXEMPTION DATA 1 a. A.nouAt 01 b.n.pllCIIl CIalNCl r 100% .' 1lfV.113 EX (/>0961 . RECORDER'S USE ONLY $!aI. l'''';- Paid .- z;p Cod. 119103 I~ Zip Code 185282 I CIty, T ownshlp, Iorcwgh I /Shippensburg I School Di#rid I yax Parcel Numll... I I ~h'P(l(n')bu<j ~;tr13-0106-079 I I 2. OIlMr CotuIcIerotIan J + 10.00 5. ~o_ I.#teI lotio 'acor I X 11.11 3. TOIal eolllicMration I = 1$40.000.00 6. Fair Marbt Value 1 =1$61,216,50 l' b. P.,ceAtap t! 1ft,__ eo.-yed I 1100% J/ 2. Check Appropriate lox "low for Exemption Clolm.d D Will or inteltale sueceuion I o Tranlfer to Industrial Oevelopment Agency. o Tronsf... to a trult. (Attach compl.te copy of trust agrMlUllt identi~ln9 011 beneReiori...) o Tro""... between principal end agent. (Attoch complete copy of ClgOl'lcy/straw party agreement.) o Tran.. to the Commonwealth, the United Stat.. and Instrv...ntaliries by gift, dedication, condomnallon or in lieu of cend...natlon. (If condemnation or In lieu of condemnation, attach copy of resolution. I . r;a T ransf... from mortgagor to 0 holder of a mortgage in default. Mortgage Boole Number 11602 J, Page Number 1352 o Correcti"e or c0n6nn<1tory d..d. (Attach compl..e copy of the prior deed being corr~ed or conlirmecf.l o Statutory corporate consolidation, merger or division. (Attoch ~opy of articles.) o Other (Pleo.e exploln exemption claimed, if other than listed C1bo"..) . not taxable, grantee 1 st mortgagee IN-.~ I I .,. 11-. fie ......... Under ponaltI.. ., Jaw. I cIecIo,. thot I have exallllned th. Stat....nt, Incluchat GCcomp..yfng ffthsnnatlon. and to....bat of my b_lecI,e ancllMl1ef, It. true, corNet and c.mp..... -- AO-t i 1- .. C'::'::l ,. -.... .... &QnI( 2G6 PACE -.. - I Dot. I IMeg O'E\fie-Y' 7' ~ I 19/8/04 I Martha E. Von Rosenstiel 16 South Lansdowne Avenue P.O. Box 457 Lansdowne, P A 19050 (610) 626-2660 Attorney J.D. #52634 Attorney fOf Plaintiff/Movant GREEN TREE CONSUMER DISCOUNT COMPANY COURT OF COMMON PLEAS CUMBERLAND COUNTY Plaintiff vs. Case No: 04-4888 GORDON E. LUCE or Occupants Defendants CERTIFICATION OF SERVICE MARTHA E.VON ROSENSTIEL, ESQUIRE hereby certifies that she is the attorney for the plaintiff herein, and that sefvice of the Plaintiff's Motion for Summary Judgment for Possession of91 Sandbank Road, Shippensburg, PA 17257 in the above matter was made upon Gordon Luce, 91 Sand Bank Road, Shippensburg, PA 17252, by regular first class mail, postage prepaid, deposited in the United States Postal Service Mail Collection Box in the lobby of the United States Post Office, Lansdowne, P A 19050 on November 24, 2004. / This verification is made subject to the penalties of 18 Pa.C.S. ~490;;elating to unsworn falsification to authorities. ( /~ ~ Martha E. Yon Rosenstiel Attorney for Plaintiff 16 South Lansdowne Avenue Lansdowne, PA 19050 (610) 623-2660 Ext. 10 Attorney I.D, #52634 MARTHA E. YON ROSENSTIEL, P.C. ATTORNEY AT LAW 16 SOUTH LANSDOWNE AVENUE P.O. BOX 457 LANSDOWNE, PA 19050 PHONE( 610)623-2660 FAX(610)623-2745 November 24, 2004 Prothonotary Court House 1 Courthouse Square Carlisle, PA 17013 RE: Green Tree Consumer Discount Company v. Gordon E. Luce or Occupants No. 04-4888 Dear Sir/Madam: Enclosed herewith Motion for Summary Judgment, which I would like to have filed with the Court. Kindly time stamp the extra copy and return it to me in the enclosed envelope. Thank you. Sincerely yours, ,~ Martha E. Von Rosenstiel Encl~ \ . Cc: }~ ~ MARTHA Eo YON ROSENSTIEL, PoCo ATTORNEY AT LAW 16 SOUTH LANSDOWNE AVENUE P.O. BOX 457 LANSDOWNE, PA 19050 PHONE( 610)623-2660 FAX(61O)623-2745 November 24, 2004 Prothonotary Court House 1 Courthouse Square Carlisle, P A 17013 RE: Green Tree Consumer Discount Company v. Gordon E. Luce or Occupants No. 04-4888 Dear Sir/Madam: Enclosed herewith Motion for Summary Judgment, which I would like to have filed with the Court. Kindly time stamp the extra copy and return it to me in the enclosed envelope. Thank you. Sincerely yours, ,~ I ~I Martha E. Von Rosenstiel ; ,/ Encl.(' I . Cc: (f; ~ \fi..U-- l MARTHA E. YON ROSENSTIEL, P.C. ATTORNEY AT LAW 16 SOUTH LANSDOWNE AVENUE P.O. BOX 457 LANSDOWNE, PA 19050 PHONE(61O)623-2660 FAX(610)623-2745 November 24, 2004 Prothonotary Court House 1 Courthouse Square Carlisle, P A 17013 RE: Green Tree Consumer Discount Company v. Gordon E. Luce or Occupants No. 04-4888 Dear Sir/Madam: Enclosed herewith Motion for Summary Judgment, which I would like to have filed with the Court. Kindly time stamp the extra copy and return it to me in the enclosed envelope. Thank you. Sincerely yours, ..~ / I ~ Martha E. Von Rosenstiel EncL Cc: G~ ~ i ,/ v' 0 ~ 0 c::::> c: = -11 "'-'Ill"' ..c- -r! ~:t % :t.::n (l' I C) '. , .ow.::: rn r"- -orn ) f',' :i:.l? . \.0 Sc) [,;:- , " :-f.::n J:; -0 '. -,- ~;~ ~') 5~. 2"~:, ...... (.,., ?") j n :-1 ~ "C- r.." ~n CO -< 1 Office Of the Prothonotalry Cumberland County To Curtis Long Or otherwise Cumberland County Prothonotary or Cumberland County Administrator This request was made ,By the order, of the Honorable Judge Mary D. France Federal Bankruptcy Court Judge orders: Per hearing Held Feb. 2 2005 GREEN TREE CONSUMER DISCOUNT Kimberly A. DeWitt, Esq. VS GORDON E. LUCE OR OCCUPANTS Pro se No. 04-4888 Civil Term Plaintiff's Motion for Summary Judgment for possession elf 91 Sandbank Road, Shippensburg, PA 17257 Listed December 20, 2004, by Kimberly A. DeWitt, Esq. IT was Requested for a RE-submissiion ,of the documents ,. sent to both, the Federal Tnlstee ,The FEDERAL Judge, and the Court reviewed.... They also were requested , to be RE-Sent ,to the COUNTY Pronothonotary"s office, to be RE- submitted, due to ''''''Reasons'''''''' that they are, or were Fl'auded and Illegal FALSIFIED Documents, according to the Court review, of the ILLEGAL FORMAT Practice to, Foreclose a Mortgage ILlegally... AS, required, byLaw, to be, at least,in a form used as REQUIRED BY LAW TO USE AS 7.4 Pennsylvania Statute Code FORM ONLY ... This was Not, done ,or nor found, done ever... it is not in accordance ,BY LAW ,TO BE reasons, that were also not found, & or nor done, By Law, to process Foreclosure thiis way.... The 2 Attorney's office, that worked the, Mortgllge Foreclosure process Case .... AS The Case No. 04-4888, done at 91 Sand Bank Road , Shippensburg ,Pa.17257 ,Never was found or nor done either ... Along with several other C4t)des, & Court rules also In Violation , that do not comply ei'ther . I am only requesting, With what was Found, and directed, me to do so by, The Honorable .Judge Mary D. France Federal .Judge at The FEDERAL Bankruptcy Court Feb.2 , 2005 Hearing .. The Documents ,were "'"'''Falsified &Fraud ,and there-fore, were sent, to the Bankruptcy Court for Bankrupting The debt out because of ilt .. It was required, By The Federal Bankrupcy Judge to re -enter or re-submit the same paper Complaint argument, documents ,To the County Prothonotary, to be, accepted, or else, We would have to cOITect the case, by taking the case, to a higher Court of La"" , to be processed ....The Case Involves, Violation OF 7.4 Ftennsylvania Statute Code, proving to having been, Violated By The Attorney, that was Handling the Case, at lthe Time The Foreclosure was In, process and was flully unknown by me ,or was not disclosed to me at all ,Until Late in The year 2004 or just recently.... This Entire Court Case # 04-4888, Hals been reviewed, By The Honorable Judge Mary D.France ,Bankruptcy .Judge ,I am Not, Doing any Non_ instructed ,'''"' Actions'""' , By Doing so, But, I am Strictly, following the rules, and according to What is, In accordance, to Bankruptcy Laws, as relating, to the hearing held Feb 2, 2005, at the Federal Bankruptcy Court... The Documents have been filed already, for attempts to prove A Complaint and , argument case, that the Law, was not in any legal Process of being done, according to rule Code 7.4 of the Pennsylvania '""I FORECLOSURE"" Law ,There fore ,I am Trying to establish, a Solution, If a Correc:tion ,will be Allowed or ,Made or not? If not, it will reqluire ,this case # 04-4888 to be taken, to a Higher Court, or what ever...? 3 It is , In accordance, to what, has been decided, by orders , given me, by the Federal Court, to Follow, and to attempt, to obtain a Correction ,to, or, at least be! within ,the Law, the way, they were written,or to report back to her, to attempt, to get this case, Corrected prop4l!rly, or to be entered , into a higher court, for the cc.rrection to be made properly ? It has not been my decisions, to there fore, Do and not try to do, any other types, or suggested form, of filings types, or o'ther enacted ,types of Complaint, or argument resolutions.... ,llease Recommend ,what would be a reason, other-wise ,for doing other non -suggested forms, or ways to solve an argument case ... Its Facts, are that of , there forct ways, other than, what I have already been,directed to do... This was, by the order of the Federal Court, I Would N,ot be in compliance using, Any, other, documents... There are Copies, of the sam~, approved ones ,spe1cifiaccllyproving Fraud "Proving Falsified Documents ,Wer41! done, they are made available, that"s already been , obs4!rved by, and fully recommended , by a Federal .Judge, and or, are sent to , Whom ,1 was ordered, to do so, By that IFederal .Judge, as orders, to, process, on them, as they w,ere sent, to please, act on Them Now, as the ones re-submitted ,according , to a Federal .Judges, request I Gordon Luce Feb.5 ,2005 ~."bt clit?L t J1. vi'" ~ <('" ~ "1dJ. l \) jooS- . <' ""-,. '-"(\ ......, ::;-! '~', -:...., c .t ""C"I '" PRAECIPE FOR LISTING CASE FOR ARGUMENT (Must be typewritten and sul:mi.tted in duplicate) TO THE PROTHONOTARY OF CUMBERLAND COUNTY: Please list the within matter far the next Argunent Court. --------------------------------------------------------------------------------------- CAPTION OF CASE (entire caption must be stated in full) GREEN TREE CONSUMER DISCOUNT COMPANY ( Plaintiff) vs, GORDON E. LUCE or Occupants (I:efendant) No. 4888 Civil xk"lc 7004 1. State matter to be argued (Le" plaintiff's rrotion for new trial. defendant's demurrer to canplaint, etc.): Plaintiff's Motion for Summary Judgment for possession of 91 Sandbank Road, Shippensburg, PA 17257 2, Identify =unsel ..tlo will argue case: (a) far plaintiff: Kimberly A. DeWitt, Esquire Address: P.O. Box 650 Hershey, PA 17033 (b) for defendant: Pro Address: se 3. I will notify all parties in writing within boo days that this case has been listed for argunent. 4. Argunent Court Date: March 23, 2005 Martha D'>ted: I' Attorney far Plaine.Hf Case No: 04-4888 Martha E. Van Rosenstiel Attorney for Plaintiff/Movant 649 South Avenue, Unit #7 P,O. Box 307 Secane, PA 19018 (610) 328-2887 Attorney l.D. #52634 GREEN TREE CONSUMER DISCOUNT COMPANY COURT OF COMMON PLEAS CUMBERLAND COUNTY Plaintiff vs. GORDON E. LUCE OR OCCUPANTS Defendants CERTIFICATION OF SERVICE MARTHA E.VON ROSENSTIEL, ESQUIRE hereby certifies that she is the attorney for the plaintiff herein, and that service of the Praecipe for Listing Case for Argument in the above matter was made upon Gordon E, Luce, pro se defendant, at 91 Sandbank Road, Shippensburg, P A 17257, by regular first class mail, postage prepaid, deposited with the United States Postal Service on February Uf,2005. i This verification is made subject to the penalties of 18 pa,c.sjS490 relating to unsworn falsification to authorities, artha E, Von Rosenstiel Attorney for Plaintiff Dated: February 11, 2005 PRAECIPE FOR LISTING CASE FOR ARGUMENT (Must be typewritten and subnitted in duplicate) TO THE PROTHONOTARY OF CUMBERLAND COUNTY: please list the within matter for the next Argunent Court. --------------------------------------------------------------------------------------- CAPTION OF CASE (entire caption must be stated in full) GREEN TREE CONSUMER DISCOUNT COMPANY (Plaintiff) vs. GORDON E. LUCE or Occupants 7 't'Y/J.RJ, t6u N. k Ra.tA ~)~Y\ ~~ ( 't-f:b ,~aJ ,J.,ocf5 ~H rpei-t-Sbltt'ff Fh { 17/157 1. state matter to be argued (Le., plaintiff's rrotion for new trial. defendant's dam=er to canplaint. etc.): Plaintiff's Motion for Summary Judgment for possession of 91 Sandbank Road, Shippensburg, PA 17257 ( Defendant) No. 4888 Civil xl& ;W[)L, 2. Identify counsel who will argue case: (a) for plaintiff: Kimberly A. DeWitt, Esquire l\iIdress : P.O. Box 650 Hershey, PA 17033 (b) for defendant: Pro Address: se 3. I will notify all parties in writing within t'NO days that this case has been liste:l for argunent. / 4. ArgI.Jrent Court Date: March 23, 2005 Martha E. VonRosens iel IHted: / ! Attorney f= Plaine:f,ff r:; y ---------- ~ ...... ("<", l1" e i:Y" ~ - = Jr:- Martha E. Von Rosenstiel Attorney for PlaintiID'Movant 649 South Avenue, Unit #7 P.O. Box 307 Secane, PA 19018 (610) 328-2887 Attorney l.D. #52634 GREEN TREE CONSUMER DISCOUNT COMPANY COURT OF COMMON PLEAS CUMBERLAND COUNTY Plaintiff vs. Case No: 04-4888 GORDON E. LUCE OR OCCUPANTS Defendants CERTIFICATION OF SERVICE MARTHA E.VON ROSENSTIEL, ESQUIRE hereby certifies that she is the attorney for the plaintiff herein, and that service of the Praecipe for Listing Case for Argument in the above matter was made upon Gordon E. Luce, pro se defendant, at 91 Sandbank Road, Shippensburg, PA 17257, by regular first class mail, postage prepaid, deposited with the United States Postal Service on February" 2005. Dated: February 11,2005 r elating to unsworn This verification is made subject to the penalties of 18 Pa.C.S. ~4 falsification to authorities. artha E. Von Rosenstiel Attorney for Plaintiff V\ :P 3 5" ~ -n -$ r-' - ~ <5 ..s::- Form BI8 (Official Form 18)(12/03) United States Bankruptcy Court Middle District of Pennsylvania Case No. 1:04 hk-4l7JlS-MDF Chapter 7 ) 'i - LJ <iSX2 In re: Debtor(s) (name(s) used by the debtor(s) in the last 6 years, including married,' maiden, t de, and address): Gordon Eugene Luce Gertrude Lucille Luce dba Luce Foundation Trustee dba Luce Foundation Tru~tee 91 Sand Bank Road 91 Sand Bank Road Shippensburg, PA 17257 Shippensburg, PA 17257 Social Security No.: xxx-xx-7659 xxx-xx-9605 Employer's Tax LD. No.: DISCHARGE OF DEBTOR It appearing that the debtor is entitled to a discharge, IT IS ORDERED: 'The debtor is granted a discharge under section 727 of title II, United States Code, (~he Ban BY THE COURT Dated: ~I2I /05 7f~ tJ!)d/ i I United States Bankruptcy\Judge I , , " ....., , ,~ 0 ,.... ~:':Jo ., I <:.-(1 ,-:;! .,,;, f'ilf[l :;.~ -- m c...' \fJ --j , (~) "'" " ::;:-; /~ -.-'" c; ~~) , -;, W ~-:'l U1 .~~ <-..... :":< SEE THE BACK OF THIS ORDER FOR IMPORTANT INFORMA Tl N. 070974 FORM 818 continued (7/97) EXPLANA nON OF BANKRUPTCY DISCHARGE IN A CHAPfER 7 CASE This court order grants a discharge 10 the person named as Ihe deblor. II is not a dismissal of die case and it does not determine how much money, if any, the trustee wiu pay to creditors. ColI~on of Di~harDed Dehts: Prohihittil 1be discharge prohibits any attempt to collect from the debtor a debt that has been discharged. For example, a creditor is not permitted to contact. a debtor by mail, phone, or otherwise, to file or continue a lawsuit, to attach wages or other property, or to take any other action to collect a discharged debt from the debtor. {in a case involving community property: I [1bere are also special rules that protect certain community property owned by die debtor's spouse, even if that spouse did not file a bankntptcy case.] A creditor who violates this order can be required to pay damages and attorney's fees to the debtor. However, a creditor may have die right to enforce a valid lien, such as a mortgage or security interest, against the debtor's property after die bankruptcy, if that lien was not avoided or eliminated in the bankntptcy case. Also, a debtor may voluntarily pay any debt that has been discharged. Dehb That are DischsroM 1be chapter 7 discharge order eliminates a debtor's legal obligation to pay a debt that is discharged. Most, but not all, types of debts are discharged if the debt existed on the date the bankruptcy case was filed. (If this case was begun under a different chapter of the Bankntptcy Code and converted to chapter 7, the discharge applies to debts owed when the bankruptcy case was converted.) Dehb thAt a~ Not Di~hamed. Some of the common types of debts which are Dll1 discharged in a chapter 7 bankruptcy case are: a. Debts for most taxes; b. Debts that are in the nature of alimony, maintenance, or support; c. Debts for most student loans; d. Debts for most [mes, penalties, forfeitures, or criminal restitution obligations; e. Debts for personal injuries or death caused by die debtor's operation of a motor vehicle while intoxicated; f. Some debts which were not properly listed by the debtor; g. Debts chat !he bankruptcy court specifically has decided or will decide in this bankntptcy case are nOl discharged; h. Debts for which !he debtor has given up the discharge protections by signing a reaffirmation agreement in compliance with the Bankntplcy Code requirements for reaffinnation of debts. This infonnation is only a general summary of the bankruptcy discharge. There are exceptions to these general rules. Because the law is complicated, you may want to consult an attorney to detennine the exact effect of the discharge in this case. 07WN 18108071116015 Case Number. 04-07315 Form: B 18 Notice Date: 03-23.12005 Page I TO TIlE DEBTORlDEBTOR'S ATfORNEY: A copy of Ibis notice could nol be mailed to eacb creditor lisled below bec:anse the conrt does not ve both a city and stale for the creditor or, if being mailed 10 a foreign country, bolb a city a!l<l COIInIlY. tmme4iately cont t the cout\ in writing if you believe it failed to properly add to its database aU of the addn:sses you provid"41 in your i1ing matrix. Please be advised that a creditor's failure to receive some notice of your case could mean the debt lowed 10 t creditor may pot be discharged (debtor should contact their anomey wilb questioos). IMPORTANT NOTE: YOU MUST SEND A COPY OF TIllS NOTICE TO THE CREDj10RS LIS TilE COURT WILL NOT MAIL THIS NOTICE AGAIN. I For future notices, 10 correct a creditor's address lisled below you must: I (I) Cross OUt all incorrect information on this page and clearly insert aU updated infonnation; (2) ~te and si n in tlte space provided on the bonom of lhis form; AND (3) Immedialely return this page 10 Ibe Cour(. l. . . IMPORTANT NarE: YOU MUST ALWAYS INCLUDE ANY ALPHABETIC OR NU~RlC CO E LOCATED TO TilE LEFT OF TIlE CREDITOR'S NAME WlIEN CONTACfING THE COURT TO COfRECT A REDlTOR'S ADDRESS! IMPORTANT NOTE: WHILE YOU MAY CORRECf A CREDITOR'S ADDRES~ USING E ABOVE INSTRUCOONS, IT IS IMPORTANT TO NOTE THAT, IF YOU WISH TO AMEND YOUR~HEDU TO ADD A PREVIOUSLY UNLISTED CREDITOR, YOU MUST CONTACT THE COURT FOR INSTRUC IONS. LI TlNG SUCH A CREDITOR ON TInS PAGE IS INSUFFiCIENT, AND WILL NOT RESULT IN THE CREDI . R BEING DDED. lbe list of each recipient who was not mailed a copy of lhis notice, including lhe portionl of the a III the COllrt'S database for lhe creditor, is as follows: cr Green Tree Consumer Discount Co Date Deblor/Debtor's All mey 017736 , V6Ut'C6lll1"H'YNsmi!' The Luco Foundation To Better Living . Sbippensburg,Po, 17257-9643 Phone I Fax: Your phone number Your web site address and / or e..mail Ontomert#. Jmloice 0. Date 68865 28-Ma....2005 In o;ce Sold To Ship.... To ~ Green Tree Conswner Discount Company ~ P,O.. Bo~ &172 ~ Rapid City, SD :.57709-&172 Purcbase Order It Sales Name Pa eot Terms Tn% Date Sbi d 30 days 28-Mar-2005 Qty Unit Price Extended ed. Tax Total Payable Price 4 $300,000,00 $1,200 000,00 $1,200,000,00 ~~-~ ,-- leases The Luco Foundation For Better living Product ID Product Description 91 Sand Bank Rd Pr e Owned B 1tle above listed Foundation ';.t.7";"~'--'~'-"''''' ,. -'- - "'-J''''- -r'_~,..-r .:,-~,...-... ---:-.-.,.,... .-.....,." if this is not aid or settled it wiN be a Forectosure o.cessed a ainst the ou urchased ut setmn Leases now Account Number $1,200,000.00 $1,200,000.00 Total be ore Tax $1,200,00000 T 8Xell T...es Amount Due Amount Paid bi in & andlin 5' $1,200000.00 a,OD Total Pa able $1,200000.00 Customer A rov I Commen s Totals SaIelJ He, 8ilmrtUre IX SlgnatUft X Insert Fine Print Here There is Personal Health excessive damages problems to the already complicated issues done anyway involved as Damages to health via Property negligence actions to fix the problems that were already there which means already was provoked since 1980 had a Million Dollar Price tag for just me alone as an ongoing problem induced By this issue to begin with anyway ! Right Now is hampering severely The Displaced persons parts of obtaining other or New and replaced Housing ! Gordon luce .& G.lucille luce Two OF 4 (four) Trustees OWNER SINCE 1998 LUCE FOUNDATION FOR BETTER LIVING @ 91 Sand Bank Road ' Shippensburg, Pa.17257-9643 Friday, January 21, 2005 Trustees inv Ived: Gordon luce ph: 717-37 -7580 G.Lucille Luce PhI 717- 37 .7580 Ronald Luce Ph: 717-81 .7785 And lor 717.37 .3159 Stephen Horto., 717-53 -6147 lUTRE' P"rotllonotary Court of Common Pleas Cumberland County , One Court House Square Carlfsre, P"a. 17013. CURT LONG Kindly Appreciated, to have all fired o-ocuments, please prease and very Kindly a thank-yo,:!. for it I I I , I recorde1 as enel sed I Relating to: GREEN TREE CONSUMER DISCOUNT Kimberly A. DeWitt, Esq. VS GORDON E. LUCE OR OCCUPANTS Pro se No. 04-4888 Civil Term Plaintiff's Motion for Summary Judgment for possession of 91 Sandba k Road, Shippensburg, PA 17257 Listed December 20, 2004, by Kimberly A. DeWitt, Esq. RE: Real Occupants Sand Bank Road 199& mr I I and Real Ownership, of this property located at 9. ,Shippensburg ,Pa. 17257 in this case si~ce Jan 1 , Code # 151.1 There is Personal Health excessive damages prohlems to the already complicated issues done anyway involved as Damages to health via Property negligence actions to fix the problems that were already there which means already was provoked since 1980 had a Million Dollar Price tag for just me alone as an ongoing problem induced By this issue to begin with anyway ! Right Now is hampering severely The Displaced persons parts of obtaining other or New and replaced Housing ! Its due to Lease Options being In place before there was any Sale or any at all Foreclosure process done Indeed much less done as one of legal reasons at all ? GREEN TREE CONSUMER DISCOUNT COMPANY, Plaintiff vs, GORDON D. LUCE OR OCCUPANTS, Defendants IN THE COURT OF COMMON PLEAS OF CUMBERLAND COUNTY, PENNSYLVANIA CIVIL ACTION - LAW NO, 04-4888 CIVIL IN RE: MOTION OF PLAINTIFF FOR SUMMARY JUDGMENT BEFORE HESS AND OLER, J.J. ORDER AND NOW, this ;u>- day of April, 2005, the court being satisfied that this particular case will be more appropriately resolved after the opportunity for hearing, the motion of the plaintiff for summary judgment is DENIED. ..-Kimberly A. DeWitt, Esquire For the Plaintiff ~rdon E. Luce 91 Sand Bank Road Shippensburg, P A 17257 :rlm BY THE COURT, -;/(~ A4- 7 A.Hess,J. ~~ (~ ()~ . ZI -() 5 " .,'" "1'1" (/::i :Ul 'i;:~J \ " \' "j or,,17 (-, ,:..:(j\ 'JliIJIJ ",0 GREEN TREE CONSUMER DISCOUNT COMPANY, Plaintiff IN THE COURT OF COMMO CUMBERLAND COUNTY, Pl /) I <,/1 v',. t4. <<,0'] f ,/ .. vs. , .j , ;' -'! CIVIL ACTION - LA W , ..~ ~ I NO. 04-4888 CIVIL 'I' j ; GORDON D. LUCE OR OCCUPANTS, Defendants IN RE: MOTION OF DEFENDANT ORDER 2 -::f' AND NOW, this day of April, 2005, the attached motion of the defend IS DISMISSED as being unintelligible. BY THE COURT, Amberly A. De Witt, Esquire F or the Plaintiff //4- :rlm ~ . ')) '\....... F~~.k~' , L,/'\ VW=) ~ !J / 1,Li " \~} '\ t" C vGordon E. Luce 91 Sand Bank Road Shippensburg, PA 17257 1 The Luce Foundation for Better Living 91 Sand Bank Road Shlppen.burg, Pa.17257-9643 Since January 1, 1998 The Luce Foundation for Better Living : would recommend A Motion BE MADE That would By the way represent the Laws that are Pennsylvan Statute Law CODES number 151 1] As Housing Replacement for Displaced persons: Relating that since the property was transferred into The Ownership of GREEN TREE CONSUMER DISCOUNT COMPANY as its listed Case number 04-4888 CIVIL Matters to correct, that verifies a Foreclosure action or actions taken to primarily claim this property as Their property without reasons to signify being fully paid for purchase ! 2] The Law relating as Pennsylvania Code Number 302: was, and has, been Law since 1977... ITS about Upgrading DEVASTATED Property , that's been devastated, The devastation if i Natural disaster or man made ,. Is still DEVASTATED IN THIS CASE Y TWO HURRICANE JUSTIFYING ISSUES, ONE OF WHICH WAS IN LA T 1996 AS HURRICANE ''''''FRANCIS '''", and as again, also Late AUGUST 2004.... Names """" IVAN & JEANNE"'''' ... PRESIDENTIAL DECLARATIONS, INVOLVING DEVASTATION DISASTERS ::: Its very hard to decide that CONSECO FINANCE DID NOT KNOW , this case, was a case they were financing as a Claimed to be Mortgage property Finance ? When it originally, was created, as a Mortgage Document, y their, so-called Claimed, Reasons, was to gain asset Value of very Much Intended illegal reasons ? At that time, seems to prove, at least have a Hypothetic patterned theory of it now...lt NOW APPEARS, That NO INSPECTION, OR ELSE PURPOSELY AVOIDED REASONS A FINANCED REASONS AVOIDED PROPER REPORTS OF THIS PROPERTY CONDITION , NOTIFICATION WAS LEGALLY, PURPOSELY NOT REPORTED TO THE INSURANCE COMPANY, KNOWN AS DYMOND INSURANCE (see The INSURANCE CLAIM FORM ) ... No it has been indicated as completely Discharged By Bankruptcy ... It leaves ,this matter, a Case relating resolution to be one not Found in any ordinary property negotiated terms at all ..... ITS, BECAUSE OF THE UGLY UNFINISHED CONSTRUCTION, ATTEMPTS DONE, TO 2 ATTEMPT TO FIX, WHAT OTHER-WISE, WAS NEVER DONE, and lor LEFT IN THE DAMAGED , CONDITION OF DEVASTATED FLOOD DAMAGED PROPERTY ... FOR WHAT IS USUALLY TERMED AS "'''''' RIP-OFF '''''' PURPOSES TO MAKE MONEY ON FLOOD DEV AST A TIO PROPERTIES! IT APPEARS THEN THEY DID NOT REPORT ANY OF THIS TO THE INSURANCE COMPANY AT ALL? IF FRAUDULENT PURPOSELY DONE OR WHAT IT UNKNOWN? 3 ] AS Its being Shown here, there are or was 4 leases, of al the =same worded types" as the one enclosed, that's made out being recipient Leases, from The primarily formerly owned prope of the Luce Foundation for better living (since 1998 ) IT APPEARS that there , was attempts to do this for the benefit, by Law for its 4 trustees, In WHICH A FOUNDATION HAS RIGHTS TO DO THIS FOR IT TRUSTEES .They originally were determined To BUILD OR REPLACE BY LAW , $300,000.00 plus all costs, to justify a good cause purpo e attempt to do so , ITS being known that building Replacement housing was the original idea here, and that its now been a Non Justified cause of purpose relating to illegally, Leaving Unpaid for lease as Financial Instruments never paid for or settled upon Initiating The Sheriff's Sale of the property Sept. 8, 2004 4] Now leaving, unsettled Lease, situations, involved, as never pai for, Usually Transacted when any Sale, Has ever Been initiated?.... IT includes these actions taken, By Green Tree Consumer Discount and Conseco Finance Corp. AS NOT ACCEPTED AT ALL BY US IN ANY TERMS DEALING WITH REAL ESTATE.... 5 ] At this time the Home owners Insurance policy, has been cancelled and that the Insurance commissioner, is notified apparently of falsified or fraud ,policy documentation also? It is carried by Diamond Insurance Company AGENCY of Chambersburg, Pa. 17202 It is inevitably, one of too many, "II No end ...... conditions, they see to, have sponsored. Lied to, and not disclosed properly, Schemes, tric s ! and By Law Reasons to Violate so many ways, and things already emphasized, of J what they did not do Right ... This COMPANY KNOWN AS CONSECO FINANCE & GREEN TREE CONSUMER DISCOUNT COMPANY, HAS FAILED TO REPORT.... ALTERNATIVELY, THEY HAVE TRIED TO COVER -UP THE NEGLIGENCE, THE UL TIMAT FRAUD WAYS, RELATING TO, VERY UNUSUAL, DEALINGS WITH HANDLING REAL ESTATE... 3 SHOWN HERE AS BEING PROPERTY THEY FINANCED, and did not intend to abide, by the Laws properly ,Including Insurance fraud an possibly attempting to use, falsifying documentation on Insurance too The personal Insurance, coverage, was originally, Thought to be supposedly applied, for, Use as personal Home Furnishing coverage, because: Mr. Luce and family, living in that house at 91 Sand Bank Road, Shippensburg, Pa. 17257 , had personal possessions, to be covered & needed that coverage ,of Home possessions ... 6) It I., now found, TO BE, MORE IMPORTANTLY, IMPORTANT, UNKNOWN, WHY DID THEY (GREEN TREE CONSUMER DISCOUNT, NOT CANCEL THE INSURANCE?) NEXTI~SFOUND THAT WENEVER HAD ANY KNOWLEDGE THAT CON8ECO FINA WAS LOCATED AT P.O. BOX 6075 , RAPID CITY SOUTH DAKOTA, and more .0 yet (NO ONE AT THIS ADDRESS LOCATION EVER f Never took out Bfty Insu..nee J as He OWNERS INSURANCE , through, no .uch an addre.., location, a. that either? Something that I. extremely false Is going on or not shown properly here, for sure, that needs adjusting or fixing? WHAT IS UNKNOWN? Intentionally, they make continued, Attempts to do thl.... The correction has been, made .s a notified result of the.. conditions, existing, to the agency at Chambers burg .... 7] Its been Noted, however, that they committed Fraud and Falsified Documents, and failed, many other ways... In this term 0 be intentionally illegal.... It is now including, the Insurance Company 0 these same, problems... Until Now, its been apparently NON-reported as a neglect ,and Improvised methods, called Money scamming, RIP-OFF, situations to having attempted to, NOT justify ,these claims, (Normally considered as RIP-OFF either doing so also No to this Foundation, or else, was done, for unknown I private reasons, anyway, Left, Unexplained why ? THE Original Mortgage make -up, and ultimate, Foreclosure on these CIVIL CASE VIOLA TIO S as actual problems, ARE INDICATED AS PURPOSELY BROKEN LAWS RULES and That FRAUD and FALSIFYING DOCUMENTS MAYBE ,ARE I IS A WAY THEY OPERATE? 4 IT was the making purposes, perpetrated, purposely, behind al these causes, make up our, Very much Non-accepted terms .... There- fore, it is believed these determinations, are determined, by. Including, these documents, for exhibit proof, now, showing up, that these conditions exist, in the ways, that proves, they fully Intended to present, to supposedly benefit, them selves criminally ,only , now, called or known as ''''RIP-OFF Intentions, because it was maybe Flo devastation reasons? ...That, determination, being, determined, By FACTS, THAT WERE MADE, AND USED By the FEDERAL Bankruptcy Judge ,to Have Good Reasons to Discharge, the entir Estate, as all, or everything OWED, Because of the Fraud and Falsified documents, associated in this case anyway? It has been determined that, there has, to be something, done about the case, as it stands now, is increasing, in illegal Unwanted , forms, with out regards for anyone or anything else at all ? ., e..v.s~ 4 -flu- ~M.~ ~.-,k Lua ~~ Jc., ~~fLllh~ C(jLW~. '4~ /J:)J Joo5 GREEN TREE CONSUMER DISCOUNT COMPANY, Plaintiff IN THE COURT OF COMMON PLEAS OF CUMBERLAND COUNTY, PEN'"NSYL VANIA vs. CIVIL ACTION - LAW NO. 04-4888 CIVIL GORDON D. LUCE OR OCCUPANTS, Defendants IN RE: MOTION OF PLAINTIFF FOR SUMMARY JUDGMENT BEFORE HESS AND OLER. J.1. ORDER AND NnW, this 2.-C- day of Amil, 2005. th.e conrt beimr ~:atisfied tb.8t this .,.J:.. ....... particular case will be more appropriately resolved after the opportunity for hearing, the mot on of the plaintiff for summary judgment is DENIED. BY THE COURT, Kimberly A. De Witt, Esquire F or the Plaintiff //iL Gordon E. Luce 91 Sand Bank Road Shippensburg, FA 17257 :rlm 1110 N j4 ~ ~ uu. ~ j1IJJcL ~ a~- ~(J dOc6" ~d~ r ""~I)~ll~/) l'h.. c~ 1'.. . . ~-..{" is diSch ctrge(jll.$tru st", of the DIlt. Ilho"e e(j: 3/24/05 lJll11le(j deb torrS) ll1JcJ thech Ilpter 7 caSe Of th e c'tho"e 8~~~h lJ~dd ?C~ o. Ohb ebtolfs:) . u~~ IS cl ~~& . '- lJlJi.te(j States lJ. ~ 'Ptcy JII,_-6 uge AlIIl1ciaJ, It Slobotiio ." (1',.~) NOTICE OF CANCELLATION OR REFUSAL TO RE EW THIS CANCELLATION OR NON-RENEWAL NOTICE IS ISSUED BY o WESTFIELD NATIONAL INS RANCE CO. [8J WESTFIELD INSURANCE CO. Westfield Center, Ohio o OHIO FARMERS INSURANCE CO. o AMERICAN SELECT INSURANCE CO. THIS NOTICE MAILED TO: PENNSYL ANIA LAW REQUIRE THAT YOU BE GIVEN COPY OF THIS NOTI E. READ IT CAREFU L Y. GORDON LUCE G LUCILLE LUCE INSURED 91 SAND BANK RD SHIPPENSBURG PA 17257 ISSUING OFFICE DATE ISSUED CANCELLATION OR NON-RENEWA WILL TAKE EFFECT Fold - WESTFIELD CENTER OH 44251 APRIL 18, 2005 With Respeclto Insured, Additional Insured or Lien Holder. With Respeclto Mortgagee: -Fold POLICY OR BOND NO. TYPE OF CONTRACT POLICY OR BOND EFF. DATE AGENCY DYMONDINSURANCEA ENCY HOP 8843159 HOMEOWNERS MARCH 26. 2005 CHAMBERSBURG PA 37 4109 NOTICE IS HEREBY GIVEN THAT THE POLICY OR BOND DESIGNATED HEREIN IS BEING CANCELED) ('1JlWNOO<~) IN ACCORDANCE WITH ITS TERMS, SUCH CAN ELLATION TO BE EFFECTIVE ON THE DATE SET FORTH HEREIN, AT THE HOUR ON WHICH SUC POLICY OR BOND BECAME EFFECTIVE, OR AT SUCH OTHER HOUR, IF ANY, SPECIFI 0 IN THE CANCELLATION PROVISIONS OF SUCH POLICY OR BOND. YOU HAVE, THEREFORE, AT LEAST 30 DAYS TO GET NEW COVERAGE IF YOU WANT TO DO SO. THE REASON FOR THIS (cancellation)~X~}(]) IS: SEE ATTACHED IF REASON FOR CANCELLATION IS NON-PAYMENT OF PREMIUM: AMOUNT DUE DATE DUE YOU MAY REQUEST IN WRITING, WITHIN 10 DAYS OF THE RECEIPT OF THIS NOTICE OF CANCELLATION OR N NRENEWAL, THAT THE INSURANCE COMMISSIONER REVIEW THIS ACTION BY THE COMPANY. TO DO THIS, SIGN AND SEN A COPY OF THIS FORM WITHIN 10 DAYS TO THE PENNSYLVANIA INSURANCE DEPARTMENT AT ONE OF THESE OFFICES: - Fold Pa, Insurance Commissioner-Reviews Room 1701 State Office Building 1400 Broad and Spring Garden Streets Philadelphia. PII. 19130 Tel.: (215) 238-7240 Pa, Insurance Commissioner-Reviews Room 304 State Office Building 300 Liberty Avenue Pittsburgh. PA 15222 Tel.: (412) 565-5020 Fold. Pa. Insurance Commissioner-Reviews P,O, Box 6142 505 Commerce Building 916 12th and State Streets Erie, PA 16512 TeL: (814) 454-2818 I request the Pennsylvania Insurance Commissioner review the (canceilation) (non-renewal) of this insurance policy. Pa, Insurance Commissioner-Reviews 1321 Strawberry Square Harrisburg. PA 17120 TeL: (717) 787-2317 (Signature of Insured) IF YOU HAVE TROUBLE GETTING NEW INSURANCE, YOU SHOULD CONTACT YOUR AGENT OR BROKER, OR ANY AGEN ABOUT YOUR POSSIBLE ELIGIBILITY FOR COVERAGE THROUGH THE: Insurance Placement Facility of Pennsylvania Constitution Place 325 Chestnut Street, Suite 600 Philadelphia, PA 19106 OR BROKER By MORTGAGEE, . 'EN HOLDER, OR ADDITIONAL INSURED CONSECO FIN CONSUMER DISC CO PO BOX 6075 RAPID CITY SO 57709 AC 290 Pennsylvania (12-97) MAIL THIS COPY TO INSURED ; -J:f1\:~~:;'~:! . ;. ",1'-;:':1'-1.::'; A0~;:;,',:~t~J~:Jlf.':~t7_:::';' OPTION TO LEASE PURCHASE REAL ESTATE When Recorded Mail to: _Gordon-luce' TRUS''fEE-or-any'one-ofthe-TRUS-TEES-, for-The- luce' Foundation-for-Bette Living including Ron Luce or Stephen Hortion @ ~ IIII 111l11I11I I MIIIMU II ,..L...... A - NOTICE OF CANCELLATION OR REFUSAL TO REN W THIS CANCELLATION OR NON-RENEWAL NOTICE IS ISSUED BY: lZl WESTFIELD INSURANCE CO. 0 WESTFIELD NATIONAL INSU NCE CO, Westfield Center, Ohio THIS NOTICE MAILED TO: PENNSYLVA IA LAW REQUIRES HAT YOU BE GIVEN A OPY OF THIS NOTIC ,READ IT CAREFUL Y. o OHIO FARMERS INSURANCE CO. o AMERICAN SELECT INSURANCE CO. GORDON LUCE G LUCILLE LUCE INSURED 91 SAND BANK RD SHIPPENSBURG PA 17257 ISSUING OFFICE DATE ISSUED CANCELLATION OR NON-RENEWAL ILL TAKE EFFECT WESTFIELD CENTER OH 44251 APRIL 18, 2005 With Respect to Insured, Additional Insured or Lien Holder. With Respect to Mortgagee: MAY 23 2005 MAY 23 2005 Fold - - Fold POLICY OR BOND NO, TYPE OF CONTRACT POLICY OR BOND EFF. DATE AGENCY DYMONDINSURANCEAG NCY HOP 8843159 HOMEOWNERS MARCH 26, 2005 CHAMBERSBURG PA 370 109 NOTICE IS HEREBY GIVEN THAT THE POLICY OR BOND DESIGNATED HEREIN (I BEING CANCELED) (WlWNOO<~) IN ACCORDANCE WITH ITS TERMS, SUCH CANC LLATION TO BE EFFECTIVE ON THE DATE SET FORTH HEREIN, AT THE HOUR ON WHICH SUC POLICY OR BOND BECAME EFFECTIVE, OR AT SUCH OTHER HOUR, IF ANY, SPECIFIE IN THE CANCELLATION PROVISIONS OF SUCH POLICY OR BOND. YOU HAVE, THEREFORE, AT LEAST 30 DAYS TO GET NEW COVERAGE IF YOU WANT TO DO SO. THE REASON FOR THIS (cance\lation)~X~}(l) IS: SEE ATTACHED IF REASON FOR CANCELLATION IS NON-PAYMENT OF PREMIUM: AMOUNT DUE DATE DUE YOU MAY REQUEST IN WRITING, WITHIN 10 DAYS OF THE RECEIPT OF THIS NOTICE OF CANCELLATION OR NO RENEWAL, THAT THE INSURANCE COMMISSIONER REVIEW THIS ACTION BY THE COMPANY. TO DO THIS, SIGN AND SEN A COpy OF THIS FORM WITHIN 10 DAYS TO THE PENNSYLVANIA INSURANCE DEPARTMENT AT ONE OF THESE OFFICES: Pa, Insurance Commissioner-Reviews 1321 Strawberry Square Harrisburg, PA 17120 Tel.: (717) 787-2317 Pa, Insurance Commissioner-Reviews Room 304 State Office Building 300 Liberty Avenue pittsburgh, PA 15222 Tel., (412) 565-5020 Pa, Insurance Commissioner-Reviews PO, Box 6142 505 Commerce Building 916 12th and State Streets Erie, PA 16512 Tel.: (814)454-2818 I request the Pennsylvania Insurance Commissioner review the (canceilation) (non-renewal) of this insurance policy. Fold - - Fold Pa, Insurance Commissioner-Reviews Room 1701 State Office Building 1400 Broad and Spring Garden Streets Philadelphia. PiI, 19130 Tel.: (215) 238-7240 (Signature of Insured) IF YOU HAVE TROUBLE GETTING NEW INSURANCE, YOU SHOULD CONTACT YOUR AGENT OR BROKER, OR ANY AGE ABOUT YOUR POSSIBLE ELIGIBILITY FOR COVERAGE THROUGH THE: Insurance Placement Facility of Pennsylvania Constitution Place 325 Chestnut Street, Suite 600 Philadelphia, PA 19106 By OR BROKER MORTGAGEE, . 'EN HOLDER, OR ADDITIONAL INSURED CONSECO FIN CONSUMER DISC CO PO BOX 6075 RAPID CITY SD 57709 MAIL THIS COpy TO INSURED ~, ;(~l~~;'Y~ ,.... ...., 0 ,.. '''",-,', ;..,\, ..,..,;,.,.."..1..'..::;."..,.,[..:'....,,.,':'......'.,,;>, ';;l~ ,< -~',,~'l-"" ""~~ '_~tfE,j:L'; FNLDEC UNITED STATES BANKRUPTCY COURT MIDDLE DISTRICT OF PENNSYLVANIA Case No. 1:04_bk-0731S-MDF Chapter 7 In re: Debtor(s) (name(s) used by the debtor(s) in the last 6 years, including married, maiden, trade, and a Gordon Eugene Luce dba Luce Foundation Trustee 91 Sand Bank Road Shippensburg. P A 17257 Social Security No.: xxx-xx-7659 Employer's Tax J.D. No.: GertrUde Lucille Luce dba Luce Foundation 91 Sand Bank Road Shippensburg. P A 17257 xxx-xx-9605 FINAL DECREE The estate of the above named debtor(s) has been fully administered. IT IS ORDERED THAT: MarkiaD R Slobodian (Trustee) is discharged as trUstee of the above named debtor(s) and the chapter 7 case of the above named debto s) is closed. Dated: 3/24105 BY THE COURT 77~ JOa.-u- United States Bankroptcy Judge OPTION TO LEASE PURCHASE REAL ESTATE When Recorded Mail to: _Gordon--luce' TRUS-TEE--'or-any'one'ofthe'TRU5-TEES-, for-The' Luce Foundation'for-Bette Living including Ron Luceor Stephen Hortion @ _91 Sand Bank Road _5hippensburg Pa_ !7257 -9643 _January 1 1998 Cumberland County ,pennsylvania effective Date: OWNER: ( Name & address& zip) COUNTY & STATE The- Luce-Foundation' For-Setter- Living' ,91' Sand'Bank'Road , Sippensburg, Pa~ 1725'7..9643- OPT10NEE ('name-&- ilddll:ltlt &- zip) GORDON Luce,91 Sand Bani< Road ,SI!!Ppensburg ,Pa, 17257-9643 Agrees to Options Of a Lease Purchase ,FOR OBTAINING A BETTER HOUSE TO LIVE IN OR A itltsW111 ,tiltiUl1ti a i:ui'itf1itt' , --m lIltUw mti, --m n-a:v~ 1I gu--ra)1t~t!tt nuUft ur numi! -m IMi m ami' i Yt!~ ,unless ,there is other-wise ",,,,,, disrupting'''''' LIFE conditions, to add more costs, or expense costs, t th~ CQmilJ'~t fiulfjJlm~J)L to,{l!J m!~.a!fy js ~ t9!l~ wjto jJ) .a tirn~ fnlln~ 91 {J) S~Y~J! yeilfS t9 CJ9S~ toe Option,with..." It is-,Inc~sive, of. this-one , Located,at- 91, Sand,Bank- Road. ,Shippensburg Pa. 1-12S1, if it may be needs to purchase, more 'land to replace this land, at 91 Sand Bank Road ,pennsylvania . 1i257 9643 Due, l' 0 -FftltffJ Of other -Ceftspiraey pr6bleffl!l,-teIatiftg-to~yiflg deetJffleftts,Of ifltervefltieft3 ~ Tampering' with, Health'and-or causes of devastating-problems to- deal; with'other-wise-usuaHy-unknow to be like at all ..".? That's intendeed to expand upon or make grow into a florishing Charity Organizatio of special help Benef"tts to those who will be recipients to it ! As this program is. meant. to allow Bidded contacts to fulfill The problems associated of Bette Ijyjng.. for. aU, u, ANY purchases, mada for aHouse(s)&- building.. supplies..Jor housing..,jnthis. agreement., in this case, to provide, for the terms related, herein as found in the FOUNDATION TERMS ALLOT!iD ,-OR MADE and RcqYirQd c:h2R9QSl to .smca Uom 1Ha for 1 rCIISlonSl. to bQnQfit.ua, ~ ,WeU as others, by- Building' BetteI'Finan1:ed-ac1:ess Homes fOl'its T-rustees, In'this ease, due,to'Joss Damages concurred here AS """Presidentially ,..", , Created, Devastating damage OF DISASTER FORMS OF REL F dOne-. or Caused Via 11urTtCane damages ftOm. 2 '01' Mote 1'tun1Canes and never fixed 1', OJ)6a1y ..-WO be the Affected program. causes. and about. other ways. to Better financing. known as MAJOR . MORTGAGING. THAT'S PROVEN TO BE FRAUDULENT AND FALSIFYING DOCUMENTATION. Of SERIES PRQ8LEM5-..... TO. other- wise..aIlow. UlL.to..livaat.a1L....., TO. UV-E-....- In. Tbis.re'Spec:t . ,as. , L.easa.Opti s... to Purchase Agreement forms to lead to A much safer, and more secured way ,to Finance home, pwrdlaae5m ~ ~ ~ all amcwRt -of minumwm mcnetary -bi4a., .~ -No -upper ~, -over the of $3&0;6*00' for- each-unit, to- be- established', for-atotal; amount to-cover-any; or-altcosts-over-a d' above all costs ,made accordingly... A MINIMUM amount, to repay, upon closing" this Option of puTC1Tase, to own, -sy a Lease purc1Tasl!, 'in tMS case ts lJSfng a th1S I;ontract fora starter of Just 4Un1tS' only, If perhaps, there fore it's a program that's not upset I At this time it appears to be Stalled, down problems infracting, other, impairing complications ,since January 1.2004 ".... . Collateral Contra~' Agr~ements , to use this Option Form was Started & was Dated: Jan 1 , 20 They, ate' Entitled- lease-Option-Contaret(s)-. for Purchase-to-own' ,to- self', tease-out; or otherwise'; RENT !O OWN "',~r sell for TOTAL CASH , A Contract. usable, the same. as any Any Mortgage du,"umo:.1t ,woatd be , using 1.t1e security, -of II Lease hTchase Option. to create ft. and make it perfonn. more s~ely. as much more Securely. and of course more fa.r more ffibility than any other mortaging knownuas Financing would give? It Gives anyone the better chance at owning a Home, an so. far, its_ prAYen._ to. be.any. otheu: related.. way. 01. w;qs.. going.. AfT,ER_ EXPERJENCJNG. A_ failed Mortgage devastation . case, so far" has done ,Not as much as Noting' that abiding;' reasons to be thos ,of .any Jaw or Jaws t that's t suppoed to have tor do hay. Needs for pr.opel' bousiIlg? . ,', Between oWner & OPTIONEE Ronald luce, at _91 Sand Bank Road, ShippenSburg ,Pa. 17257 Also to 'ncIUde PU'cha... of olhe, lots . land.. O,"dded on .pace 0"0001 ." EXPANSION TYpe HOUsing. to flni.h lhls PO,"On to. satlsty. w...... laws. the... fo", found. to be laws. w_n a ....anl.. to, """ng. by The Penn'''avania C..... .. We/l.. Othe, Constltut'onal law.. "'qUi"'d fo Haal'" and Safety and San..", & Welfa", PU",o.e. . of each Ind'v'dual pe"'on 0' pe"'on. 0' , "'.'d.... and OCCUpants. lhe", to", to. live 'n. 0' u.e. Wh'Ch neve,. can . di"/low having. to Put up, w/lh un-Fl.... P"'perty · Wh'ch has P"''''n. to be "'al He.... P"",!em.. done Only. a. a cau.ed acCOnlingl.y majo, ''''blem to "'coup ... IL.....,. Una""",. 0' ....ny othe, P,o."m. "u_. and ur........y ....on. · SIn.. Sept. Of ,....... .In lhi. ...., to at least allow fo, lhe la... of Pann.ylvanla hou"ng.. its gUide lines Automatic Termination Date for this CONTRACT ,. 5 to 'Yea",. which -in.... . In se"'n ye"",. _'d be Janua", '. 2011 Con.,da"";on to"hls OPllon. no Money a. ca'h. to pay down. 0' until the Hou.e ,. BUIlt .... OTHes, '....n. to ..."'... lhe C.n..ct, a. a Mongage paya... In , Yea", nnt 16 0' 3ll Yea" OptIonally con"da"", as M<>nlhly 0, Yea.y. A total 'um. at the -'nation time of 'Yea..... Janua", 1. 2011.. It OW/l...., huge money · 0......, any othe, known way..... The Flnanc'ng, to a/low , Os pU",ose. to funetton to, P'OaUCing Iiou"ng. to any 0,"/1 Mem_"" Tm_. , ana 10,"nyona el.e, OW'h'eg to jO'n and get help. with Hou"ng FInance ReLIeF that. can not be founa in many Ofhe, type. P,ovided by othe, financIng nend.. to anyone ChoOS'ng to seek Bette, mo", .1Ivable. and .u'table O"atid.fY'ng hOUSing this Way: ) ReceIPT Is P,oVldad bVlhe Owne, , The Lu.. FoUndat'on fo, Bette, Living U.'ng Thi. fo"" and Optlon....e to PU/Chase ,Detai"d opt'on. of, It may, be fat 010", detailed Ie"". a", av....b.. and I "'''n be ,n"ud... . AS THIS FORM IS ONL Y THE SHORrPOR'" ...... Real Property Add..... 0' LOCATlOIII ": Fo, now I. ., Sand Bank ROOd ,Sh''''''bu"" Pa. 1729' Until .- .........ng placea can be .bfa'_, Built On 0' "sa .stabll..... he... tc allow bU'ld'ngf.) or Construction to begin ? I leg., desc.ption , AS.o be · House . 1 0, 2 S'o/)' R"'dence, single faml/y types . _ 3 BedrOom and 2 Baths at least .... Payable bYo.Ioa... FinanCOd. COIlditfons . on,y in Ieen. of paYmen'.mounts. eff/..,... pe, month 0'. lolal sUm ca.h .moUnt, Of in Closing the option. .. of 'he Yea, Jan. 1 2011. for the first of 4 Units .... B.'.nce FInanced · in the leen., Shown .bo.. ,as ""1/ .. Below " '0 INCLUDE ANY EXTRA CHARGES OR COSTS INVOLVED ! Othe, Ch...... .nd e.pen... of .ny Sale to be paid 0' Prol'aled .. Fol/ows , 1 ) Exelelso Of Option to Option... and may exeleiso this Option by Sending w_n notice · by cel1ifled mal/ to the Owne, .. Add..... ShOWn On 0' befo... the Automatic Termination date ..... Upon 'uch Exeleiso of this Option The P.rtie. .ha" Execute E.crow 'n......Cllon. In the Sland.1d Foen of thel, cho_ ESCROW COMPANY and 'h." INCORPoRATE thIs OPI/on by reference . 2) T'me I. e_nce . Time is Of the es.ence of this OptIon 3 J Non .SS'Dnable. This option, ,. not .'.Ign.bIe by the OPT'ONEE -out Wl'iften notice by,or of the owners, consent, 4 ) Modification : This Option. maYbe Modin.. .only by . Wrflten. & .'gned , consent by Both Parties .. S ) Successo.. of Rights , The Te_ ofthis Option .h." be binding upon .nd Intu... of The SUCC__.. Inte_. .nd as .ss/g__ of the P."i.. belOln to InVOlved I 6 J Any or all Additional PrOVIsions : ---..'-.-----.., '''-', -'''''. .'--.'..-.-----,... ---.-...---....-------..''''..., - '" , 2 3 Signature of Owner : _The Luce Foundation For Better Living _ Signature of Owner:' ~t::-'t-~ ~L-CJ2... Subscibed and Sworn before me this date rn l.{( d ~,-:J 1 ,~,lJ?TC) / ) I STATEOF: _ft1/;ne-- COMMONWEALTH OF PENNSYLVANIA 1 "!'"'\~~"'I.'l ~!:'l I . ;~-J,t'\~:'-..~.'~_J"._ ., 1 : P,1.h1E~'~. ,\. 2\r-.t)'.~...<./, . ::.~~":1 :~":~~1?~ \ C:;:"N"' "~","m" . ,',,-~.;-..~ "~.,~,-.; 1 ,-,ul,.-;...;eI1o.,l\.ol~'", 1 '~vp.. ......,..~T.J_:;~ ...~.I"" '..........;..,1 ;-.." ~ >I, Ccmm',,-'m'l '-",~;'_A ;:"" A I'""r.o ! l JVlY -. - .,I....~j~,. C.'~~uc~ . 'v..... ~, "'~uO - NOTARY \ I ;/ / ' ; /\ ;----;{' () ''v -/- ' PUBLIC -Ll~tJ iy Iii GL ~J~dJLLl) L' ( seal) J COUN'TYOF: ~i)n')/Yr /0 na Subscibed and Sworn Before me this date STATEOF : COUNTY OF : NOTARY PUBLIC ( seal ) ',3 :-~ ;. n c :;: "'OCt mrrr z:-;-; Zt- ~i? <<.. :> C' " Z -' :lC: >~ 7- ::<. Ul ROBERT J. WILSON, ESQUIRE, does hereby certify that he did make service of CD Plaintiff s Praecipe for Listing Case for Trial upon the following individuals on this 16th day of May, 2005 by first class mail, postage pre-paid as follows: MARTHA E. VON ROSENSTIEL, P.C. BY: Robert J. Wilson, Esquire Identification No. 42434 649 South Avenue, Unit 7 Secane, PA 19018 (610) 328-2887 Attorney for Plaintiff GREEN TREE CONSUMER DISCOUNT COMPANY Plaintiff, vs. GORDON D. LUCE OR OCCUPANTS Defendant(s) COURT OF COMMON PLEAS CUMBERLAND COUNTY No: 4888, 2004 Term CERTIFICATION OF SERVICE Gordon E Luce 91 Sandbank Road Shippensburg., PA 17257 Occupant 91 Sandbank Road Shippensburg., PA 17257 ~ 0 = -n c.n ~ ~=n :::= -om a. :09 ~~~ o~ Zr o ~ -< ~ >-0- ~Q .-5 ......:c ~.L. -i- 00 To: 630- dltJ U-.iE i'5 r- a.. ~ C"> ~ :';;;'sS '."-'\? -' ......,~ ~ >- rD -./ - :5 ......, ..... = = c--J ~:,;',~t .'....,;; 5 () PRAECIPE FOR LISTING CASE FOR TRIAL (Must be typewritten and submitted in duplicate) TO THE PROTHONOTARY OF CUMBERLAND COUNTY Please list the following case: o for JURY trial at the next term of civil court. [19 for trial without a jury. ---------.-----.-----------------..-----------..-----..-----------------..---------~._-------------------------------..-- CAPTION OF CASE (entire caption must be stated in full) GREEN TREE CONSUMER DISCOUNT COMPANY ( check one) [EI Civil Action - Law o Appeal from arbitration o (other) (Plaintiff) GORDON ~; LUCE OR OCCUPANTS The trial list will be called on and Trials commence on (Defendant) Pretrials will be held on (Briefs are due 5 days before pretrials vs. No.4888 , ?nn4 Term Indicate the attorney who will try case for the party who files this praecipe: Robert J. Wilson, Esquire Indicate trial counsel for other parties if known: Unknown Si~~ Prio<N=" . ROb,re J. WE 'on. E'oui" This case is ready for trial. Date: May 16, 2005 Attorney for: Plaintiff C'l ~ ~ c; ~ ~ ~ ~:P t~~~~ ~~ 2i ~a ~~ - ~ ~ ~ ~ - GREEN TREE CONSUMER DISCOUNT COMPANY, PLAINTIFF IN THE COURT OF COMMON PLEAS OF CUMBERLAND COUNTY, PENNSYLVANIA V. GORDON D, LUCE OR OCCUPANTS, DEFENDANTS : 04-4888 CIVIL TERM ORDER OF COURt AND NOW, this ~ day of July, .2005, a bench trial shall be conducted in Courtroom Number 2, Cumberland County Courthouse, Carlisle, Pennsylvania at 2:30 p.m., Thursday, July 21, 2005. By ~e'6urt, ~ Robert J. Wilson, Esquire For Plaintiff .Gordon Luce, Pro se 91 Sandbank Road Shippensburg, PA 17257 ~ ~ 7-11-05 Q-- Court Administrator :sal >: ~ '0 ~~2. CJr5 ! h"_ Qa. \..wO.. ::.JtU O::F is l""- N N :z: a.. CJ:) I --' :::> ....., U"> = ~ >- ~; ~5,~ ':"~3~~ ", ~~) ~ ~~0 -7 -~~ ':::;. t{rt :s o _",' k, " ",~', .(.-', .. -- " . ,;:',:~ r CURTIS R LONG Prothonotary Cumberland County One Courthouse Square Carlisle, PA 17013 04-4PJ>? flU:!.)"".)! f' I\~;':" OF THr P"(',.TI..ll'i' ,,,T/.\P'V t. h'~." ."......1, ':'.) I '" 2:Q~H!L 18 PI1 2: 20 ~"-., l_,,-_,_, I ,::,', Robert J, Wilson, Esquire 26 S. Lansdown'" 1I.\I",n, '''' Lansdowne, P iSGSQ+2.i02-2e Not Deliverable as addressed. Unable to forward , GREEN TREE CONSUMER DISCOUNT COMPANY, PLAINTIFF : IN THE COURT OF COMMON PLEAS OF : CUMBERLAND COUNTY, PENNSYLVANIA V. GORDON D. LUCE OR OCCUPANTS, DEFENDANTS 04-4888 CIVIL TERM ORDER OF COURT AND NOW, this -;;;? ~ day of July, 2005, the bench trial currently scheduled for July 21,2005, is cancelled and shall now be conducted in Courtroom Number 2, Cumberland County Courthouse, Carlisle, P'annsylvania at 1 :30 p,m" Thursday, August 4, 2005. ~ ------ By th). C6urt, Edgar B. Bayley, J. ~~ert J. Wilson, Esquire For Plaintiff ftrdon Luce, Pro se 91 Sandbank Road Shippensburg, PA 17257 d-7 ~ ~.'} o Court Administrator :sal , " ,',' "~';..., FLED.Ci-=F1CE OF THE F8C>HU:)TNW 20D5 JUL 22 ?,H II: 13 ^ IN THE COURT OF COMMON PLEAS OF CUMBERLAND COUNTY, PENNSYLVANIA GREEN TREE CONSUMER DISCOUNT COMPANY, PLAINTIFF V. GORDON D. LUCE OR OCCUPANTS, DEFENDANTS : 04-4888 CIVIL TERM IN RE: EJECTMENT GENERAL FINDINGS AND JUDl3MENT (1) Plaintiff, Green Tree Consumer Discount Company, is the owner of a parcel in Southampton Township, Cumberland County, known as 91 Sandbank Road, Shippensburg, PA 17257, as more fully described in a deed to plaintiff from the Sheriff of Cumberland County recorded in the Office of the Record of Deeds on October 19, 2004, at Deed Book 265, Page 4008, (2) The deed to plaintiff resulted from a sale of the property at foreclosure against Gordon E. Luce and Gertrude LUGe alkla G, Luc;iIIe Luce. (3) Defendants allege defenses to the action in mortgage foreclosure. No appeal was taken from the judgment in foreclosure, whilch is final. (4) Defendants, citing 37 Pa. Code 151.1-151,12, allege that plaintiff is required to provide assistance for their relocation. These administrative regulations are applicable to acquisitions by eminent domain, not mortgage foreclosure. (5) Gordon E. LUGe and Gertrude Luce alkla G. Lucille Luce continue unlawfully to reside in the property without legal right. (6) Plaintiff is entitled to judgment ejectment. cOy-l-(~n JUDGMENT AND NOW, this ~ day of August, 2005, Gordon E. Luce and Gertrude Luce a/kla G. Lucille Luce ARE EJECTED from 91 Sandbank Road, Shippensburg, PA 17257. ~bert J. Wilson, Esquire 16 South Lansdowne Avenue P.O. Box 457 Lansdowne,PA 19050 F or Plaintiff By the ,C{){Jrt, . / / f / Court Administrator ~rdon Luce, Pro se 91 Sandbank Road Shippensburg, PA 17257 :sal -'- - - 'n '\ t./"'Cl ~~:::) ;;;';'':1 ,~ Martha E. Von Rosenstiel, P.C. Martha E. Von Rosenstiel 649 South Avenue, Unit 7 Secane, PA 19018 610 328-2887 Attorney I.D,# 52634 GREEN TREE CONSUMER DISCOUNT COMPANY 7360 SOUTH KYRENE ROAD, MSD TEMPE AZ 85282 PLAINTIFF VS. GORDON E. LUCE OR OCCUPANTS 91 SANDBANK ROAD SHIPPENSBURG PA 17257 DEFENDANT Attorney for Plaintiff COURT OF COMMON PLEAS CUMBERLAND COUNTY CASE NO: 04-4888 PRAECIPE TO ENTER JUDGMENT TO THE PROTHONOTARY: Enter judgment in the above captioned Ejectment pursuant to the attached court order dated August 5th, 2005. /l_______ / I / / /; Martha E. Von Rosenstiel Attorney for Plaintiff GREEN TREE CONSUMER DISCOUNT COMPANY, PLAINTIFF IN THE COURT OF COMMON PLEAS OF CUMBERLAND COUNTY, PENNSYLVANIA V, GORDON D, LUCE OR OCCUPANTS, DEFENDANTS : 04-4888 CIVIL TERM IN RE: EJECTMENT GENERAL FINDINGS AND JUDGMENT (1) Plaintiff, Green Tree Consumer Discount Company, is the owner of a parcel in Southampton Township, Cumberland County, known as 91 Sandbank Road, Shippensburg, PA 17257, as more fully described in a deed to plaintiff from the Sheriff of Cumberland County recorded in the Office of the Record of Deeds on October 19, 2004, at Deed Book 265, Page 4008, (2) The deed to plaintiff resulted from a sale of the property at foreclosure against Gordon E. Luce and Gertrude Luce a/k/a G. Lucille Luce. (3) Defendants allege defenses to the action in mortgage foreclosure, No appeal was taken from the jUdgment in foreclosure, which is final. (4) Defendants, citing 37 Pa, Code 151,1-151,12, allege that plaintiff is required to provide assistance for their relocation, These administrative regulations are applicable to acquisitions by eminent domain, not mortgage foreclosure, (5) Gordon E. Luce and Gertrude Luce a/k/a G. Lucille Luce continue unlawfully to reside in the property without legal right. (6) Plaintiff is entitled to jUdgment ejectment. JUDGMENT AND NOW, this ~ day of August, 2005, Gordon E, Luce and Gertrude Luce a/k/a G. Lucille Luce ARE EJECTED from 91 Sandbank Road, Shippensburg, PA 17257. Robert J. Wilson, Esquire 16 South Lansdowne Avenue P.O, Box 457 Lansdowne, PA 19050 For Plaintiff / Gordon Luce, Pro se 91 Sandbank Road Shippensburg, PA 17257 Court Administrator :sal Martha E. Von Rosenstiel, P,C. Martha E. Von Rosenstiel 649 South Avenue, Unit 7 Secane, PA 19018 610 328-2887 Attorney I.D.# 52634 Attorney for Plaintiff GREEN TREE CONSUMER DISCOUNT COMPANY 7360 SOUTH KYRENE ROAD, MSD TEMPE AZ 85282 PLAINTIFF COURT OF COMMON PLEAS CUMBERLAND COUNTY VS. GORDON E. LUCE OR OCCUPANTS 91 SANDBANK ROAD SHIPPENSBURG P A 17257 DEFENDANT CASE NO: 04-4888 AFFIDAVIT OF NON MILITARY SERVICE COMMONWEALTH OF PENNSYLVANIA: : SS COUNTY OF DELA WARE MARTHA E. VON ROSENSTIEL, being duly sworn according to law deposes and says that she is the attorney for the plaintiff herein; that she is duly authorized to take this affidavit in behalf of the plaintiff, and that the defendants are not in the Military or Naval Service of the United States or its Allies, or otherwise within the provisions of the Soldiers' and Sailors' Civil Relief Act of Congress of 1940, as amended; I That Gordon E. Luce or Occupants is/are over 21 years Id and reside(s) at 91 Sandbank Road Shippensburg P A 17257. Sworn to and Subscribed Before me this 8/26/2005 ~~~ Notary Pu ic co P M N_ISeaI Joshua PhlfHps, Nolaty Public Ridley l'wp" Delaware County My Commission Expi.... May 16. 2006 Member, Pennsytvania Association of Notartee C 7V D ~ ~ it- l[ \) ~'J "-> .::;,J' 0 cC";) -n cJ' F ........ D :P'~ -< U( c:..::: :r:...." 6- G~j rl1f.:;;d ~ --- f! c.) :r~"J...'"! 3 U( 0 -J'..,..I '~,~~ ~f\ -!2 lA ~ QJ - --,.-.' - ',_:j:-n t: J r-,) ,< .-:~ jJ 0 -< Martha E. Von Rosenstiel, P.C. Martha E. Von Rosenstiel 649 South Avenue, Unit 7 Secane, PA 19018 610 328-2887 Attorney I.D.# 52634 Attorney for Plaintiff GREEN TREE CONSUMER DISCOUNT COMPANY 7360 SOUTH KYRENE ROAD, MSD TEMPE AZ 85282 PLAINTIFF COURT OF COMMON PLEAS CUMBERLAND COUNTY VS, GORDON E. LUCE OR OCCUPANTS 91 SANDBANK ROAD SHIPPENSBURG PA 17257 DEFENDANT CASE NO: 04-4888 PRAECIPE FOR THE WRIT OF POSSESSION TO THE PROTHONOTARY: Kindly issue Writ of Possession in the abov~ Ejectment matter. 91 Sandbank Road Shippensburg, PA 17257 ....---1 /1 K1artha E. Von Rosenstiel Attorney for Plaintiff t: t=' - . f t DL.. 10 ~ ~) ~ OV ~ ~ ~ ..... cr ~ &-r 1 ff>> -b9. -- -<: ~ ~ -- ~ \) -0 0 vt ~ 0 () V) () ...., vr () () = 0 Q \).. C c.:: G=:> -n l 0 \); c:.r, \) \ , ~ :::"," :r-n I c:: lnp: I ~ c.":' -rJI-I} ~ C,) ~'3 ~1; "' "' Cl ff , "' "' rq. -'1.;.'" "' ,,;~i~~ ~ - , cvt: "' "' >:::;, Ii ..... N ~':1 ~ Y-E d::~ Cl .< Form CP 109 Ejectment Quiet Title Commonwealth of Pennsylvania COURT OF COMMON PLEAS Green Tree Consumer Discount Company VS, GORDON E, LUCE OR OCCUPANTS 91 SANDBANK ROAD SHIPPENSBURG P A 17257 NO 04-4888 ATTY'S COSTS $120.08 WRIT OF POSSESSION PROTHY $ 1.00 TO THE SHERIFF OF CUMBERLAND COUNTY: (1) To satisfy the judgment for possession in the above matter You are directed to deliver possession of the following described property to: Green Tree Consumer Discount Company (2) To satisfy the costs against 91 Sandbank Road, Shippensburg, P A 17257 directed to levy upon any property of Gordon Luce you are 1," 1,'2~ ~,e.,. and sell interest therein. By Clerk Date 3oikthtJ.-{ ~ "" .. ~ = o e e o u ..... o -- ... = o U 00 00 00 l' ..,. o a :<; >> g ~ c U - c i5 <..> ~ is ,. ~ ~ S c ~ c c U " " ~ c " " ~ (:J VJ I-< ~ "" B r-- U .,., o '" ~OS: 0<< ~~"" 3~~ '< ~ ~~VJ ~~~ ~~e; 0_::<: (:J",VJ z o .... [/J [/J ~ [/J [/J o p. ~ o f-< ~ ..,. o? '" N ll"J 'It q i'! 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LUCE OR OCCUPANTS 91 SANDBANK ROAD SHIPPENSBURG PA 17257 NO 04-4888 A'ITY'S COSTS $120.08 WRIT OF POSSESSION pm $ 1.00 TO THE SHERIFF OF CUMBERLAND COUNTY: (1) To satisfy the judgment for possession in the above matter You are directed to deliver possession of the following described property to: Green Tree Consumer Discount Company (2) To satisfy the costs against 91 Sandbank Road, Shippensburg, PA 17257 directed to levy upon any property of Gordon Luce you are and sell i2~. ~_A ,~~ interest therein. . r: By Clerk Date 30 4q~().5 ~ ... ... - ~ = <:> e e <:> U .... <:> -- .... = <:> U 00 00 00 l' ;g c :<; >> ia 0- S o u E " 8 ~ is ~ ~ M " s " ~ o o U " " M E- o " " M o '" E- Z < c. ::> ~ r;; o N ~~S:: 0<< "-l~c. g~~ ..lz::> , < '" "-l",,,, 5~~ ~~e; 0_0:: 0",,,, z o ~ en en >LI en en o p. "- o E-< ~ .... '" CD N I!l o;t o ~ . 'S ~ g Q) a..we ~~ Q) Q;Q)> ~~<( c: c: Q) ~~~ T"" 000 C::C::" <l:o CC(I)!'-Q..<D oocLt';) _<0 >>~'Q"~~ u.iu.i:s~~~ mm5CCl"O_ ..c..c'n . rn 0 t::t::wQc.....- ttI co (0 . ro to :2:~......a..-.J_ >> Q) c: OM 1!l.8 g;;: Form CP 109 Ejectment QuietTme Commonwealth of Pennsylvania COURT OF COMMON PLEAS Green Tree Consumer Discount Company VS. NO 04-4888 GORDON E. LUCE OR OCCUPANTS 91 SANDBANK ROAD SHIPPENSBURG PA 17257 WRIT OF POSSESSION pm $120.08 $ 1.00 ATI'Y 'S COSTS TO THE SHERIFF OF CUMBERLAND COUNTY: (I) To satisfy the judgment for possession in the above matter You are directed to deliver possession of the following described property to: Green Tree Consumer Discount Company (2) To satisfy the costs against 91 Sandbank Road, Shippensburg, PA 17257 directed to levy upon any property of Gordon Luce you are and sell interest therein, {~ By Clerk Date :3oiluht5 ~~~nuO'J A8 / J J 1,':Il)qS ,~:.. ?~' . ~ I ~'flt'"''1..j.rad - If'd S(){)C ~0 fO 1...'(1 ;;,3/ >:'f).. 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