Loading...
HomeMy WebLinkAbout02-0859GOLD$ECK McCAFFERTY & McKEEVER BY: JOSEPH A. GOLDBECK, JR. ATTORNEY I.D.#16132 SUITE 500 - THE BOURSE BLDG. 111 S. INDEPENDENCE MALL EAST PHILADELPHIA, PA 19106 (215) 627-1322 ATTORNEY FOR PLAINTIFF COLUMBIA NATIONAL INC. 7142 Columbia Gateway Drive Columbia, MD 21046 Plaintiff vs. ROBERT A. DECKER DIANNE L. DECKER Mortgagor(s) and Real Owner(s) 106-108 Gilbert Road Shippensburg,PA 17257 Defendant(s) IN THE COURT OF COMMON PLEAS OF Cumberland COUNTY CIVIL ACTION - LAW ACTION OF MORTGAGE FORECLOSURE Term n No.= -.r9 1. CIVIL ACTION: MORTGAGE IC4FORECLOSURE THIS FIRM 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 must take action within twenty (20) days after the 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 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 BAR ASSOCIATION 2 Liberty Avenue Carlisle, PA 17013 LEGAL SERVICES INC 8 Irvine Row Carlisle, PA 17013 717-243-9400 AVISO LE HAN DEMANDADO A USTED EN LA CORTE. SI DESEA DEFENDERSE CONTRA LAS QUFJAS 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 OBIECCION CONTRA LAS QUEJAS 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 PROVISIONES 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 BAR ASSOCIATION 2 Liberty Avenue Carlisle, PA 17013 LEGAL SERVICES INC 8 Irvine Row Carlisle, PA 17013 717-243-9400 COMPLAINT IN MORTGAGE FORECLOSURE 1. Plaintiff is COLUMBIA NATIONAL INC., 7142 Columbia Gateway Drive, Columbia, MD 21046. 2. The name(s) and address(es) of the Defendant(s) is/are ROBERT A. DECKER, 106-108 Gilbert Road, Shippensburg, PA 17257 and DIANNE L. DECKER, 106-108 Gilbert Road, Shippensburg, PA 17257, who is/are the mortgagor(s) and real owner(s) of the mortgaged premises hereinafter described. On April 01, 1997 mortgagor(s) made, executed and delivered a mortgage upon the premises hereinafter described to COLUMBIA NATIONAL INC., which mortgage is recorded in the Office of the Recorder of Deeds of Cumberland County as Book 1373 Page 949. The mortgage has not been assigned unless said assignment to the Plaintiff is hereafter mentioned. These documents are matters of public record and are incorporated herein by reference in accordance with Pennsylvania Rule of Civil Procedure 1019(g). 4. The premises subject to said mortgage is described as attached. 5. The mortgage is in default because monthly payment of principal and interest upon said mortgage due May 01, 2001, and each month thereafter are due and unpaid, and by the terms of said mortgage, upon default in such payments for a period of one month, the entire principal balance and all interest due thereon are collectible forthwith. 6. The following amounts are due on the mortgage: Principal Balance Interest from 04/01/2001 through 01/31/2002 at 8.5000% Per Diem interest rate at $22.22 Attorney's Fee at 5.0% of Principal Balance Late Charges from 05/01/2001 to 01/31/2002 Monthly late charge amount at $36.47 Costs of suit and Title Search Escrow Monthly Escrow amount $151.72 $95,440.23 $6,799.31 $4,772.01 $328.22 $750.00 $108,089.77 $0.00 $108,089.77 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 based on work actually performed. Notice of Intention to Foreclose and a Notice of Homeowners' Emergency Mortgage Assistance has been sent to Defendant(s) by Certified and regular mail, as required by Act 160 of 1998 of the Commonwealth of Pennsylvania, on the date(s) set forth in the true and correct copy of such notice(s) attached hereto as Exhibit "A". The Defendant(s) has/have not had the required face-to-face meeting within the required time and Plaintiff has no knowledge of any such meeting being requested by the Defendant(s) through the Plaintiff, the Pennsylvania Housing Finance Agency, or any appropriate Consumer Credit Counseling Agency. WHEREFORE, Plaintiff demands judgment in mortgage foreclosure in the sum of $108,089.77, together with interest at the rate of $22.22, per day and other expenses incurred by the Plaintiff which are properly chargeable in accordance with the terms of the mortgage, and for the foreclosure and sale of the mortgaged premises. By: GOLDB M AFFERTY & McKEEVER BY: Jos PH A. G LDBECK, JR., ESQUIRE ATTORNEY FOR PLAINTIFF VERIFICATION I, Vernetta M. Watson as the representative of the Plaintiff corporation within named do hereby verify that I am authorized to and do make this verification on behalf of the Plaintiff corporation and the facts set firth in the foregoing Complaint are true and correct to the best of my knowledge, information and belief. I understand that false statements therein are made subject to the penalties of 18 Pa. C.S. 4904 relating 10 ttnswom falsification to authorities. Date: /-629-oZ ?cU - Veretta M. Watson, Asst. Treasurer Columbia National Inc. 01/16/2002 11:23 717-295-7155 LANC TITLE INFO JOUR PAGE 02 i VIV 2002 05:34 591-1784 SEARCH ONE PAGE 03 Yd'!/89 w • To; MnN tr.+.ra: -111mfs-01a-owe And »-+s.eiffiograe "ADS this / day of / 7,??/ "97, BETWi:><N PATRSCX R. OTT and TRnex 9. oTT, husband and wire, of l06 Gilbert Boil, Shippwnabarg, PX 17257 "GRANTORS", 11 N p ' Ron== A. DEC=M and DIANM2 L. DECl-gIt, hueAend And wit*, of 10095-2 Tower Road, Shippsnaburg, PA 17257 "caANT?;es" . W2TNE88>9TU, that in consideration Or the sum of NINETY-SIX TRWRAND AND 09/100 ($96,o0o.00) Dollars, in hand paid, the raosipt whereof is hereby a*knowledgod? the said GR71MRs do hereby great and convoy 4n rest simple to said axanTwo, ALL that rollowiny dow 111bod real estate, together with the improvaments ersoted thereon. lyitmp and being 'aituato in Southampton Townabip, Cumberland Comity, rannsylvania, were particularly described as lollewst mbacm g ti aMWING at'h railroad spite in Lagisiazive Route 21008 at the southeastarn aaxfter oiv Lot No. 1 an the herein .ftsu X*ntlonsd platy of lotst thenaa along the easterd edge of Lot No. }, North moventesn (17) degreat pins (9) Minatae six (a) asoonds test, a distanos of ninety-thsas (92) tact to an Lrox pin, thence along the nartAel" edge of Let No. 1, South eighty-nine (60) w 4agriaes distance (or )ens unixtes hundwed tin ?.aven and fortty- two hUndredths (127.42) root to an iron pint thenos along the same, North eighty (00) degrees zero (00) minutas ttgey-five (55) seconds West, a dxatanoe of ninety (90) toot to aft iron pint thence along lands now ear formerly of Wan H, Delancey, North five (0) degrees tw*Mty-might (28) Minutes twenty-maven (27) seconds $ant, a distance '01/16/2002 11:23 717-295-7155 LANC TITLE INFO JOUR PAGE 03 01/10/2002 05..34_._..591-17e4 SEARCH ONE PAGE 04 l+ssias 0 or two hundred nine ight Ana ninety,four hundredths (298.947 feat to an rent in, thence along the southern Daft! Of Lot NO. B, South eighty-lour a4) degrees, thirty_ (31) Minot" thirty-.three (33) second* maxt, a distance of lour hundred eightewn and Seventy-eight hundredths (41x,78) fast to an iron pin: thence along the eonthweatern portion of Lot No. S, South three (3) asgdistance Live (nree S hundred twelve ! a ('12) ad e nin tyc-two hundredthhe (205.92) feet to a ]Cal;road spiks in Legislative Route 210061 thence slonq hisgislative gouts 21006, Ncftth seventy-throe (73) degree= fifteen (15) minutes fifty-five (55) ascends hest, a distance OR seventy-seven and tvanty-saven hundredths ('77a27) toot to a railroad splkat thence &I" the same, Booth aevantT.- t Seconds West, a wo (72) &nmeas fifty (50) mirmtas fifty-tour (54) ninety-eight hundredths distanas of one ninet ne)feetn to hen plan a and 9r.GXNNSNO, CONNING 3.1114 roues, and being Lot On. 4 on a plan of lots retarded in Plan Back 43, pays 21. auwncT To restrictions recorded in Cumbarland County Plnn book 49, page 21. cT x s* 0 ALL "a following deaaribed ,real estate, together with the iNWOVaments *r4afted thereon, lying and being. Situate in Southampton Township, Cumberland County, Pannsylvani.%, more particularly described as follows DWINNZWO at a railroad spike in the centarline air Legislative gouts 21006, corner yr lands now or formerly of John 0. Martin; nuance by Martin lands, Korth seventeen (17) degrees nine (9) minutes six (6) seconds Neat, ninety-three (93) Coot to an iron pint thence'by ether lands now or formerly a! ,john C. Martin, North eighty-nine (89) degx¦o ¦ixtAwn (a,e) minutes twnty-three (29) seconds W6st, a distaRae of one handrail twenty-.even and forty-two hundredths (127.42) feet td min iron pin; tyh(eoj agrees mar by (no) minutes ro John i ive ps) Martin# 39amt, a distance of ninety (90) feat to an iron pin at line of lands now or formerly of Lynn N. Dolancyt thence by said Delany Lands, south give (a) dagreas twanty.-eight (28) minutes twenty-Seven (27) seconds weal, a distance of one hundred eighty-two and eighty hundredths (183,00) goat to a railroad spike in the centerline of Legislative Route ,10061 thence by the Centerline of Lagl,aiative gouts 2104061 North seventy-three (73) degream thirteen (13) minutes thirtoork (13) '01/16/2002 11:23 717-295-7155 LANC TITLE INFO JOUR PAGE 04 01/10/2002 _05:34 591-1764 SEARCH ONE PAGE 05 . _._... $84/QS sec nds seat a distancejof two hundred seven and sixty-sour hVndredths 0107.64) rest to a railroad npikef thence by the degreesllfifty (n) wino ai ? lty?-ra= (4)j booond tSeat, a distance er sixty-rive (63) feet 'to a railroad spSka, the point and place of RNGINNIMG. CONTAINING 0.72x5 acres, less 0.1335 acres resew" for improvements of right-or-May of Leg1MXftt1Ve Route 11006. AMXMC9 Lot No. I on subdivision plan for John C. Martin dateA November 14, 1960• prepared by Carl a. Dart, R.s. 9 xNG the wafts p? as conveyed by PATMOX s. OTT and PATRIMA y. O'rr, now t1 no an PA'?'R='= a. V2sDtL ¦s tenants irl th Recoorrd" a tots of cuwbarlarnd ounty oaVnnn0rlveLni a in Deea Hook "Gad, Volume 32, page 75 antd g]?TRXCX E. OTT, the grantor herein. AM, the Said ORAXTORS ha eby w4krrant spaaialiy thae property herein conveyed. 2K• wITKP.$8 wMMOr, the said QPAMTOa9 do harebV eat their hands and scabs the day and year first above written. witne :: ?? ?, (SEAL) PA CX E• CO?Oez BAX&M of PINN!1YLVANIA p ss. COUNTY OF CUM133MAIM On this th ? dsy ar •,?7'ri?? , 14!?7, b?etdrb na, the underm -' o xloer, psrafna1ly appeared PATRICK s. OTP and TRACY S. OTT, husband and wire, known to ae (or antlefaatorily coven) to be the ersopa whose na1bas %Ys Subscribed to the within Instrument, and a?owlsdgad tae rore"$-ng dead to be their act and dead and desired the same to be recorded aw such. WZTAG ss sy hand and official sea tho da end first above written. ._ a+a ??AL L _ Ot-l Publ o ` i Mr??°d ? 9 n?: ? :. -01/16/2002 11:23 717-295-7155 __01/0[2002 05:34 591-1784 S do hereby an peat office address , 1997 precise residence and couplet* Ia GRAKP is: ¦I fl s M G Gu!ot IMN Or. • .-? comoitInR7?l'/pH or FmQr3YLv11NI11 COMM OF CUMBlRLUD Pug. ,?:iq/?ier?y,;jresi^•?t•• RE=RDED on this -1."y at l ..•• ?:?' 1?=D; 199 , in ?tthe? Recorderts O.Mce of said County, in Doted Boole vol.( `, page Given under my hand and (real of tht• safari osfioe; °ttie' date above written. At ' RdooXdsY 14 -W ?? 1F a O: yr '., r•• a?FIA + E0?>< j.55 PACE 564 A 1 ro ?. „ LANC TITLE INFO JOUR PAGE 05 SEARCH ONE PAGE 05 _ p99/95 4 01/11/02 16:44 FAX 4108722596 COLUMBIA NATIONAL January 10, 2002 Robert Decker Dianne Decker 106-10B Gilbert Rd. Shippensbur, PA 17257 Re: Columbia National No. 3197084 106-106 Gilbert Rd. C Shippensbur, PA 17257 N Dear Borrower: A P P E N D I X A A C T 91 N O T I C S T A R E A C T I O N T O Y O U R H 0 M E F R O M F O R E C L O S U R E 0 002 COLUMBIA NATIONAL Incorporated' EXHIBIT S A V E t This is an official notice that the mortgage on your home is in default, and the lender intends to foreclose. Specific information about the nature of the default is provided in the attached pages. The HOMEOWNER'S MORTGAGE ASSISTANCE PROGRAM (SEMM) may be able to help to save your home. This Notice explains how the programs works. To see if HENAP can help, you must MEET WITH A CONSUMER CREDIT COUNSELING AGENCY WITHIN 30 DAYS OF THE DATE OF THIS NOTICE. Take this Notice with you when you meet with the Counseling Agency. This name, address and phone number of Consumer Credit Counseling Agencies serving your County are listed at the end of this Notice_ if you have any questions, you may call the Pennsylvania Housing Agency toll free at 1-800-342-2397. (Persons with impaired hearing call (717) 780-1869). This Notice contains important legal information. If you have any questions, representatives at the consumer Credit Counseling Agency may be able to help explain it. You may also want to contact an attorney in your area. The local bar association may be able to help you find a lawyer. LA NOTIFICACION EN ADJUNTO ES DE SUMA IMPORTANCIA, PUBS AFECTA SII DERrkczo A CONT=UAR VzV=BNDO EN SU CASA-01 NO COMPRENDE EL CONTENIDO DE ESTA NOTIFICACION OBTENGA UNA TRADUCCION INMEDITAMENTE LLa*MANDO ESTA AGENCIA (PENNSYLVANIA HOUSING FINANCE AGENCY) SIN CARGOS AL NUMBRO MENCIONADO ARRIBA. PUEDES SER ALEGIHLE PARA UN PRESTAMO POR EL PROGRAM LLAMADO "HOMEOWNERS'S EMERGENCY MORTGAGE ASSISTANCE PROGRAM' EL CUAL PUEDE SALVAR SII CASA DE LA PERDIDA DEL DERECFtO A REDIMIR SU HTPOTECA_ 7142 COLIRA"IP GATEYIAY DRIVE P.O. Ban 3050 Cot uMeu, MD 21046 www. Col umbianational, com f2r W.s 01/11/2002 FRI 15:36 (TX/RX NO 55381 01002 01/11/02 16:44 FAX 4108722596 January 10, 2002 Robert Decker Dianne Decker 125 Airport Rd. Shippensburg, PA 17257 Re: Columbia National No_ 3197084 106-108 Gilbert Rd. N Shippensbur, PA 17257 Dear Borrower: A P P E N D I X A COLUMBIA NATIONAL Incorporated* A C T 91 N O T I C E T A K E A C T I O N T O S A V E Y O U R H O M E F R O M F O R E C L O S U R E* This is an official notice that the mortgage on your home is in default, and the lender intends to foreclose. Specific information about the nature of the default is provided in the attached pages. The HOMEOWNER'S MORTGAGE ASSISTANCE PROGRAM (HEMAP) may be able to help to save your home. This Notice explains how the programs works. To see if XZKXP can kelp, you must MEET WITH A CONSUMER CREDIT COUNSELING AGENCY WITHIN 30 DAYS OF THE DATE OF THIS NOTICE. Take this Notice with you when you meet with the Counseling Agency. This name, address and phone number of Consumer Credit Counseling Agencies serving your County are listed at the end of this Notice. If you have any questions, you may call the Pennsylvania Housing Agency toll free at 1-800-342-2397. (Persons with impaired hearing call (717) 780-1869). This Notice contains important legal information. If you have any questions, representatives at the Consumer Credit Counseling Agency may be able to help explain it. You may also want to contact an attorney in your area. The local bar association may be able to help you find a lawyer. LA NOTIFICACION EN ADJUNTO SS DS SUMA IMPORTANCTA, PUSS AFECTA SU DERECHO A CONTINUAR VIVIENDO EN SU CASA.SI NO COMPRENDE EL CONTENIDO DE ESTA NOTTFICACION ORTENGA VISTA TRADUCCION IIMDITAMENTE LLAMANDO ROTA AGENCIA (PENNSYLVANIA HOUSING FINANCE AGENCY) SIN CARGOS AL NUMBRO MENCIONADO ARRIBA. PUEDES SER ELEGIBLB PARA UN PRESTANO POR EL PROGRAM LIJUOMO `HOMEOWNERS d S EMERGENCY MORTGAGS ASSISTANCE PROGRAM' EL COAL PUEDE SALVAR SU CASA DS LA PERDIDA DEL DERECHO A REDIMIR SU HIPOTECA. 7142 CoLumem GATewmr Dwvc P.O. SM 3050 COLUMA, MD 21046 WWW.ColumbianaTional.com 7^^ r L 01/11/2002 FRI 15:36 (Tx/R% NO 55381 IR1009 COLUMBIA NATIONAL 1@009 01/11/02 16:44 FAX 4108722596 COLUMBIA NATIONAL (a 003 NON90WHERIS EMERGENCY MORTGAGE ASSISTANCE PROGRAM you MAY BE ELIGIBLE FOR FINANCIAL. ASSISTANCE WHICH CAN SAVE YOUR ROME FROM FORECLOSURE AND HELP YOB MAKE FUTURE MORTGAGE PAYMENTS IF YOU COMPLY WITH THE PROVISIONS OF THE HOMEOWNERS EKS11GENCY MORTGAGE ASSISTANCE ACT OF 1983 (THE "ACT"), YOU BE ELIGIBLE FOR EMERGENCY MORTGAGE ASSISTANCE: IF YOUR DEFAULT HAS BEEN CABBED BY CIRCUMSTANCES BEYOND YOUR CONTROL, IF YOU HAVE A REASONABLE PROSPECT OF BEING ABLE TO PAY YOUR MORTGAGE PAYMENTSf AND IF YOB MEET OTHER ELIGIBILITY REQBIRgMBNTS ESTABLISHED 9Y THE PENNSYLVANIA HOUSING FINANCE AGENCY. TEMPORARY STAY OF FORECLOSURE -- Under the Act, you are entitled to a temporary stay of foreclosure on your mortgage for thirty (30) days from the date of this Notice. During that time you must arrange and attend a "face-to-face" meeting with one of the consumer credit counseling agencies listed at the end of this Notice. THIS MEETING MUST OCCUR WITHIN TBS NEXT (30) DAYS. IF YOU DO NOT APPLY FOR EMERGENCY MORTGAGE ASSISTANCE, YOU MUST BRING YOUR MORTGAGE UP TO DATE. THE PART OF THIS NOTICE CALLED "HOW TO CURE YOUR MORTGAGE DEFAULT", EXPLAINS BOW TO BRING YOUR MORTGAGE BP TO DATE. CONSUMER CREDIT COUNSELING AGENCIES -- If you meet with one of the consumer credit counseling agency listed at the end of this notice, the leader may NOT take action against you for thirty (30) days after the date of this meeting. The names, addresses and telephone numbers of designated consumer credit counseling agencies for the county in which the property is located are set forth at the end of this Notice. It is only necessary to schedule one face-to-face meeting. Advise your lender immediately of your intentions. APPLICATION FOR MORTGAGE ASISTANCE -- Your mortgage is in default for the reasons set forth later in this Notice (see following pages for specific information about the nature of your default). If you have tried and are unable to resolve this problem with the lender, you have the right to apply for financial assistance from the Homeowner's Emergency Mortgage Assistance Program. To do so, you must fill out, sign and file a completed Homeowner's Emergency Assistance Program Application with one of the designated consumer credit counseling agenciea listed at the and of this Notice. Only consumer credit couneling agencies have applications to the Pennsylvania Housing Finance Agency. Your application MUST be filed or postmarked within thirty (30) days of your face-to-face meeting. 01/11/2002 FRI 15:56 ITx/R% NO 55381 R003 01/11/02 16:44 FAX 4108722596 COLUMBIA NATIONAL YOU MUST FILE YOUR APPLICATION PROMPTLY. IF YOU FAIL TO DO 90 OR IF YOU DO NOT FOLLOW THE OTHER TIME PERIODS SET FORTH IN THIS LETTER, FORECLOSURE MAY PROCEED AGAINST YOUR HOME IMMEDIATELY AND YOUR APPLICATION FOR MORTGAGE ASSISTANCE WILL BE DENIED. AGENCY ACTION Available funds for emergency mortgage assistance are very limited. They will be disbursed by the Agency under the eligibility criteria established by the Act. The Pennsylvania Housing Finance Agency has sixty (60) days to make a decision after it recieves your application. During that time, no foreclosure proceedings will be pursued against you if you have met the time requirements set forth above. You will be notified directly by the Pennsylvania Housing Finance Agency of its decision on your application. NOTE: IF YOU ARE CURENTLY PROTECTED BY THE FILING OF A PETITION IN BA MUPTCY, THE FOLLOWING PART OF THIS NOTICE IS FOR INFORMATION PURPOSE ONLY AND SHOULD NOT BE CONSIDERED AS AN ATTEMPT TO COLLECT THE DEBT. (if you have filed bankruptcy you can still apply for Emergency Mortgage Assistance). NOW TO CURB YOU MORTGAGE DEFAULT (Bring it up tp Date). NATURE OF THE DEFAULT -- The MORTGAGE debt held by the above lender on your property located at: 106-108 Gilbert Rd. Shippensbur, PA 17257 IS SERIOUSLY IN DEFAULT because: YOUR HAVE NOT MADE MONTHLY MORTGAGE PAYMENTS for the following months and the following amounts are now past due. PAYMENTS NSF FENS LATHS OTHER FEES LESS FUNDS ON-RAM TOTAL $9,103.87 $.00 $298.91 $8.00 $.00 $9,410.78 lih 004 01/11/2002 FRI 15:56 ITx/R% NO 55981 X1004 01/11/02 16:44 FAX 4108722596 COLUMBIA NATIONAL B. YOU HAVE FAILED TO TAKE THE FOLLOWING ACTION (Do not use if not applicable): HOW TO CURE TUT DEFAULT -- You may cure the default within THIRTY (30) DAYS of the date of this notice BY PAYING THE TOTAL AMOUNT PAST DUE TO THx LENDER, WHICH 15 $9,410.78 PLUS ANY MORTGAGE PAYMENTS AND LATE CHARGES WHICH SECOMS DUE DURING THE THIRTY (30) DAY PERIOD. Payments must be made either by cash, cashier's check, certified check or mosey order made payable and seat to: Columbia National, Incorporated 7142 Columbia Gateway Drive Columbia, Maryland 21046 IF YOU DO NOT CORE THE DEFAULT -- If you do not cure the default within THIRTY (30) DAYS of the date of this Notice, the lender intends to exercise its rights to accelerate the mortgage debt. This means that the entire outstanding balance of this debt will be considered due immediately and you may lose the chance to pay the mortgage in monthly installments. If full payment of the total amount past due is not made within THIRTY (30) DAYS, the lender also intends to instruct its attorneys to start legal action to foreclose upon your mortgaged property. IF THE MORTGAGE IS FORECLOSED UPON -- The mortgaged property will be sold by the Sheriff to pay off the mortgage debt. If the lender refers your case to its attorneys, but you cure the delinquency before the lender begins legal proceedings against you, you will still be required to pay the reasonable attorney's fees that were actually incurred, up to $50.00. However, if legal proceedings are started against you, you will have to pay all reasonable attorney's fees actually incurred by the lender even if they exceed $50.00_ Any attorney's fees will be added to the amount you owe the lender, which may also include other reasonable costs. If you cure the default within the THIRTY (30) DAY period, you will not be required to pay attorney's fees. OTHER LENDER REMEDIES -- The lender may also sue you personally for the unpaid principal balance and all other sums due under the mortgage. RIGHT TO CbRE THE DEFAULT PRIOR TO SHERIFF'S SALE -- If you have not cured the default within the THIRTY (30) DAY period and foreclose proceedings have begun, you still have the right to cure the default lih 005 01/11/2002 FRI 15:36 (Tx/Rx NO 55381 1A005 01/11/02 16:44 FAX 4108722596 COLUMBIA NATIONAL and prevent the sale at any time up to one hour before the sheriff's sale- You may do so by paying the total amount then past due, plus any late or other charges then due, reasonable attorney's fees and costs connected with the Sheriff's Sale as specified in writing by the lender and by performing any other requirements under the mortgage. Curing your default in the manner set forth in this Notice will restore your mortgage to the same position as if you had never defaulted. EARLIEST POSSIBLE SHERIFF'S SALE DATE -- It is estimated that the earliest date that such a Sheriff's Sale of the mortgage property could be held would be approximately Six (6) months from the date of this Notice. A notice of the actual date of the Sheriff's Sale will be sent to you before the sale. Of course, the amount needed to cure the default will increase the longer you wait. You may find out at any time exactly what the required payment or action will be by contacting the lender. HOW TO CONTACT THE LENDER: Columbia National, Incorporated 7142 Columbia Gateway Drive Columbia, Maryland 21046 EFFECT OF SHERIFF'S SALE -- You should realize that a Sheriff's Sale will end your ownership of the mortgaged property and your right to occupy it_ If you continue to live in the property after the Sheriff's Sale, a lawsuit to remove you and your furnishings and other belongings could be started by the lender at any time- ASSUMPTION OF MORTGAGE -- You _ may or _ may not (CHECK ONE) sell or transfer your home to a buyer or transferee who will assume the mortgage debt, provided that all the outstanding payments, charges and attorney's fees and costs are paid prior to or at the sale and that the other requirements of the mortgage are satisfied. YOU MAY ALSO RAVE THE RIGHT: TO SELL THE PROPERTY TO OBTAIN MONEY TO PAY OFF THE MORTGAGE DEBT OR TO BORROW MONEY FROM ANOTHER LENDING INSTITUTION TO PAY OFF THIS DEBT. TO HAVE THIS DEFAULT CURED BY ANY THIRD PARTY ACTING ON YOUR BEHALF. TO HAVE THE MORTGAGE RESTORED TO THE SAME POSITION AS IF NO DEFAULT HAD OCCURED, IF YOU CURE THE DEFAULT- (HOWEVER, YOU DO NOT HAVE X1006 01/11/2002 FRI 15:96 rT%/R% NO 55381 R006 01/11/02 16:44 FAX 4108722596 COLUMBIA NATIONAL THIS RIGHT TO CURE YOUR DEFAULT MORE THAN THREE TIMES nT ANY CALENDAR YEAR-) TO ASSERT THE NONEXISTENCE OF A DEFAULT IN ANY FORECLOSURE PROCEEDING OR ANY OTHER LAWSUIT INSTITUTED UNDER THE MORTGAGE DOCUMENTS, TO ASSERT ANY OTHER DEFENSE YOU BELIEVE YOU MAY HAVE TO SUCH ACTION BY THE LENDER. TO SEER PROTECTION UNDER THE FEDERAL, BANKRUPTCY LAW. CONSUMER CREDIT COUNSELING AGENCIES SERVING YOUR COUNTY Q 007 01/11/2002 FRI 15:36 rT%/R% NO 55381 P007 r c cc ry Cr 'T7 C? rni } r_ A J ?l .r ii ?? ton SHERIFF'S RETURN - REGULAR CASE NO: 2002-00859 P COMMONWEALTH OF PENNSYLVANIA: COUNTY OF CUMBERLAND COLUMBIA NATIONAL INC VS DECKER ROBERT A 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 DECKER DIANNE L the DEFENDANT , at 1436:00 HOURS, on the 25th day of February , 2002 at 125 AIRPORT ROAD SHIPPENSBURG, PA 17257 by handing to ROBERT A DECKER a true and attested copy of COMPLAINT - MORT FORE together with and at the same time directing His attention to the contents thereof. GILBERT ROAD ADDRESS APPEARS TO BE VACANT. Sheriff's Costs: Docketing 6.00 Service .00 Affidavit .00 Surcharge 10.00 .00 16.00 Sworn and Subscribed to before me this 13 iz- day of A. D. -? 'Prothonotary So Answers: 17 R. Thomas Kline 02/26/2002 GOLDBECK MCCAFFERTY MCKEEVER By: Deputy S riff SHERIFF'S RETURN - REGULAR rCASE NO: 2002-00859 P COMMONWEALTH OF PENNSYLVANIA: COUNTY OF CUMBERLAND COLUMBIA NATIONAL INC VS DECKER ROBERT A 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 DECKER ROBERT A the DEFENDANT , at 1436:00 HOURS, on the 25th day of February , 2002 at 125 AIRPORT ROAD SHIPPENSBURG, PA 17257 ------ w I'll"" by handing to a true and attested copy of COMPLAINT - MORT FORE together with and at the same time directing His attention to the contents thereof. GILBERT ROAD ADDRESS APPEARS TO BE VACANT. Sheriff's Costs: Docketing 18.00 Service 13.80 Affidavit .00 Surcharge 10.00 .00 41.80 Sworn and Subscribed to before me this /3 a- day of ,2.vO.L A. D. 'Prothonotary So Answers: R. Thomas Kline 02/26/2002 GOLDBECK MCCAFFERTY MCKEEVER By: Deputy Sh riff IN THE COURT OF COMMON PLEAS OF Cumberland COUNTY COLUMBIA NATIONAL INC. 7142 Columbia Gateway Drive Columbia, MD 21046 Vs. ROBERT A. DECKER DIANNE L. DECKER (Mortgagors and Record Owners) 106-108 Gilbert Road Shippensburg, PA 17257 Plaintiff Defendants PRAECIPE FOR JUDGMENT AND ASSESSMENT OF DAMAGES No. 00859-2002 THIS LAW FIRM IS A DEBT COLLECTOR AND WE ARE ATTEMPTING TO COLLECT A DEBT OWED TO OUR CLIENT. ANY INFORMATION OBTAINED FROM YOU WILL BE USED FOR THE PURPOSE OF COLLECTING THE DEBT. Kindly enter judgment in favor of the Plaintiff and against ROBERT A. DECKER and DIANNE L. DECKER, Defendants for failure to file an Answer to Plaintiff's Complaint within 20 days (or 60 days if defendant is the United States of America) from the date of service of the complain and for foreclosure and sale of the mortgaged premises, and assess Plaintiff's damages as follows: As set forth in Complaint $108,089.77 Interest - 2/1/02 - 4/15/02 $ 1,644.28 Late Charges $ 109.41 Escrow Debit $ 455.16 TOTAL $110,298.62 I hereby certify that (1) the addresses of the Plaintiff and Defendants are as shown above, and (2) that notice has been given in accordance with Rule 237.1, copy attached. O o Q? r ? Jos A. Gol eck, Jr. Att ney for aintiff I. #16132 DAMAGES ARE HEREBY ASSESSED AS INDICATED. DATE: 7,- ?Z,71/--- ? ? , PRO PROTHY n I 7D AND NOW Judgment is entered in favor f COLUMBIA NATIONAL INC. and against ROB TR R and DIANNE L. DECKER by default for want of an Answer and damages assessed in the sum of $110,298.62 as per the above certification. Prothonotary THIS LAW FIRM IS A DEBT COLLECTOR AND WE ARE ATTEMPTING TO COLLECT A DEBT OWED TO OUR CLIENT. ANY INFORMATION OBTAINED FROM YOU WILL BE USED FOR THE PURPOSE OF COLLECTING THE DEBT. DATE OF THIS NOTICE: March 18, 2002 TO: DIANNE L. DECKER 125 Airport Road Shippensburg PA 17257 COLUMBIA NATIONAL INC. 7142 Columbia Gateway Drive Columbia, MD 21046 vs. ROBERT A. DECKER DIANNE L. DECKER (Mortgagor(s) and Record Owner(s)) 106-108 Gilbert Road Shippensburg, PA 17257 Plaintiff Defendant(s) TO: DIANNE L. DECKER 125 Airport Road Shippensburg PA 17257 IN THE COURT OF COMMON PLEAS of Cumberland County CIVIL ACTION - LAW ACTION OF MORTGAGE FORECLOSURE Term D 0 e5 q No. O?L 0 OOA- IMPORTANT NOTICE YOU ARE IN DEFAULT BECAUSE YOU HAVE FAILED TO ENTER A WRITTEN APPEARANCE PERSONALLY OR BY ATTORNEY AND FILE IN WRITING WITH THE COURT YOUR DEFENSES OR OBJECTIONS TO THE CLAIMS SET FORTH AGAINST YOU. UNLESS YOU ACT WITHIN TEN (10) DAYS FROM THE DATE OF THIS NOTICE, A JUDGMENT MAY BE ENTERED AGAINST YOU WITHOUT A HEARING AND YOU MAY LOSE YOUR PROPERTY OR OTHER IMPORTANT RIGHTS. YOU SHOULD TAKE THIS NOTICE TO A LAWYER AT ONCE. IF YOU DO NOT HAVE A LAWYER OR CANNOT AFFORD ONE, GO TO OR TELEPHONE THE FOLLOWING OFFICE TO FIND OUT WHERE YOU CAN GET LEGAL HELP: C?,V1 E NO COUNTY BAR ASSOCIATION Caris5e. ???11J GAL 9qE,RVICES INC f?A J, F013 G 19 C IcCAFFER EVER B seph A. Goldbeck, Jr., Esq. Attorney for Plaintiff Suite 500 - The Bourse Bldg. 111 S. Independence Mall East Philadelphia, PA 19106 215-627-132 THIS LAW FIRM IS A DEBT COLLECTOR AND WE ARE ATTEMPTING TO COLLECT A DEBT OWED TO OUR CLIENT. ANY INFORMATION OBTAINED FROM YOU WILL BE USED FOR THE PURPOSE OF COLLECTING THE DEBT. DATE OF THIS NOTICE: March 18, 2002 TO: ROBERT A. DECKER 125 Airport Road Shippensburg, PA 17257 COLUMBIA NATIONAL INC. 7142 Columbia Gateway Drive Columbia, MD 21046 vs. ROBERT A. DECKER DIANNE L. DECKER (Mortgagor(s) and Record Owner(s)) 106-108 Gilbert Road Shippensburg, PA 17257 Plaintiff Defendant(s) TO: ROBERT A. DECKER 125 Airport Road Shippensburg,PA 17257 IN THE COURT OF COMMON PLEAS of Cumberland County CIVIL ACTION - LAW ACTION OF MORTGAGE FORECLOSURE Term 00 $5 9 No. )-Opp IMPORTANT NOTICE YOU ARE IN DEFAULT BECAUSE YOU HAVE FAILED TO ENTER A WRITTEN APPEARANCE PERSONALLY OR BY ATTORNEY AND FILE IN WRITING WITH THE COURT YOUR DEFENSES OR OBJECTIONS TO THE CLAIMS SET FORTH AGAINST YOU. UNLESS YOU ACT WITHIN TEN (10) DAYS FROM THE DATE OF THIS NOTICE, A JUDGMENT MAY BE ENTERED AGAINST YOU WITHOUT A HEARING AND YOU MAY LOSE YOUR PROPERTY OR OTHER IMPORTANT RIGHTS. YOU SHOULD TAKE THIS NOTICE TO A LAWYER AT ONCE. IF YOU DO NOT HAVE A LAWYER OR CANNOT AFFORD ONE, GO TO OR TELEPHONE THE FOLLOWING OFFICE TO FIND OUT WHERE YOU CAN GET LEGAL HELP: ('? BER AND COUNTY BAR ASSOCIATION C?illl %%saas3 b] 1351NC l? ie IN/??4ef- 4 GO t6fi C ICCAFFER Z EVER B seph A. Goldbeck, 7r., Esq. Attorney for Plaintiff Suite 500 - The Bourse Bldg. 111 S. Independence Mall East Philadelphia, PA 19106 215-627-132 THIS LAW FIRM IS A DEBT COLLECTOR AND WE ARE ATTEMPTING TO COLLECT A DEBT OWED TO OUR CLIENT. ANY INFORMATION OBTAINED FROM YOU WILL BE USED FOR THE PURPOSE OF COLLECTING THE DEBT. DATE OF THIS NOTICE: March 18, 2002 TO: DIANNE L. DECKER 106-108 Gilbert Road Shippensburg PA 17257 COLUMBIA NATIONAL INC. 7142 Columbia Gateway Drive Columbia, MD 21046 vs. ROBERT A. DECKER DIANNE L. DECKER (Mortgagor(s) and Record Owner(s)) 106-108 Gilbert Road Shippensburg, PA 17257 TO: DIANNE L. DECKER 106-108 Gilbert Road Shippensburg, PA 17257 Plaintiff Defendant(s) In the Court of Common Pleas of Cumberland County CIVIL ACTION - LAW ACTION OF MORTGAGE FORECLOSURE Term 00 $5 No. ).-ppa. IMPORTANT NOTICE YOU ARE IN DEFAULT BECAUSE YOU HAVE FAILED TO ENTER A WRITTEN APPEARANCE PERSONALLY OR BY ATTORNEY AND FILE IN WRITING WITH THE COURT YOUR DEFENSES OR OBJECTIONS TO THE CLAIMS SET FORTH AGAINST YOU. UNLESS YOU ACT WITHIN TEN (10) DAYS FROM THE DATE OF THIS NOTICE, A JUDGMENT MAY BE ENTERED AGAINST YOU WITHOUT A HEARING AND YOU MAY LOSE YOUR PROPERTY OR OTHER IMPORTANT RIGHTS. YOU SHOULD TAKE THIS NOTICE TO A LAWYER AT ONCE. IF YOU DO NOT HAVE A LAWYER OR CANNOT AFFORD ONE, GO TO OR TELEPHONE THE FOLLOWING OFFICE TO FIND OUT WHERE YOU CAN GET LEGAL HELP: {; lJ(,BE ND COUNTY BAR ASSOCIA]'[ON ("'I" ScPd v} 813 V4GAI,SERVICES INC qN i'S''ifi- a1lh?oli GO .C IIcCAFFEl2' EEVF.R B seph A. Goldbeck, Jr., Esq. Attorney for Plaintiff Suite 500 - The Bourse Bldg. I I 1 S. Independence Mall East Philadelphia, PA 19106 215-627-1322 THIS LAW FIRM IS A DEBT COLLECTOR AND WE ARE ATTEMPTING TO COLLECT A DEBT OWED TO OUR CLIENT. ANY INFORMATION OBTAINED FROM YOU WILL BE USED FOR THE PURPOSE OF COLLECTING THE DEBT. DATE OF THIS NOTICE: March 18, 2002 TO: ROBERT A. DECKER 106-108 Gilbert Road Shippensburg, PA 17257 COLUMBIA NATIONAL INC. 7142 Columbia Gateway Drive Columbia, MD 21046 vs. ROBERT A. DECKER DIANNE L. DECKER (Mortgagor(s) and Record Owner(s)) 106-108 Gilbert Road Shippensburg, PA 17257 TO: ROBERT A. DECKER 106-108 Gilbcrt Road Shippensburg, PA 17257 Plaintiff Defendant(s) In the Court of Common Pleas of Cumberland County CIVIL ACTION - LAW ACTION OF MORTGAGE FORECLOSURE Term 00 $ 5 9 No. a, 00 ON-- IMPORTANT NOTICE YOU ARE IN DEFAULT BECAUSE YOU HAVE FAILED TO ENTER A WRITTEN APPEARANCE PERSONALLY OR BY ATTORNEY AND FILE IN WRITING WITH THE COURT YOUR DEFENSES OR OBJECTIONS TO THE CLAIMS SET FORTH AGAINST YOU. UNLESS YOU ACT WITHIN TEN (10) DAYS FROM THE DATE OF THIS NOTICE, A JUDGMENT MAY BE ENTERED AGAINST YOU WITHOUT A HEARING AND YOU MAY LOSE YOUR PROPERTY OR OTHER IMPORTANT RIGHTS. YOU SHOULD TAKE THIS NOTICE TO A LAWYER AT ONCE. IF YOU DO NOT HAVE A LAWYER OR CANNOT AFFORD ONE, GO TO OR TELEPHONE THE FOLLOWING OFFICE TO FIND OUT WHERE YOU CAN GET LEGAL HELP: ''AND COUNTY BAR ASSOCIATION Cmlis o1°i}?f3 VGA qEwRVICPSINC GO C IeCAFFER EVER B seph A. Goldbeck, Jr., Esq. Attorney for Plaintiff Suite 500 -The Bourse Bldg. I I I S. Independence Mall Past Philadelphia, PA 19106 215-627-1322 VERIFICATION OF NON-MILITARY SERVICE The undersigned, as the representative for the Plaintiff corporation within named do hereby verify that I am authorized to make this verification on behalf of the Plaintiff corporation and that the facts set forth in the foregoing verification of Non-Military Service are true and correct to the best of my knowledge, information and belief. I understand that false statements therein are made subject to penalties of 18 Pa. C.S. 4904 relating to unsworn falsification to authorities. 1. That the above named Defendant, ROBERT A. DECKER, is about unknown years of age, that Defendant's last known residence is 125 Airport Road Shippensburg, PA 17257 and is engaged in the unknown business located at unknown address. 2. That the above named Defendant, DIANNE L. DECKER, is about unknown years of age, that Defendant's last known residence is 125 Airport Road Shippensburg, PA 17257 and is engaged in the unknown business located at unknown address. 3. That Defendant is 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 Action of Congress of 1940 and its Amendments. Date: April 15, 2002 A. Go] eck, Jr. V for aintiff 11 JG ? ?Q I c? c_ T7 S7? Z ; G j 0 n. T7 0 n 1.? 3T) 11., C? r f Y ?I PRAECIPE FOR WRIT OF EXECUTION - (MORTGAGE FORECLOSURE) P.R.C.P. 3180-3183 COLUMBIA NATIONAL INC. Plaintiff Vs. ROBERT A. DECKER DIANNE L. DECKER Defendants TO THE OFFICE OF THE PROTHONOTARY: : COURT OF COMMON PLEAS : CUMBERLAND COUNTY, PA : NO: 00859-2002 PRAECIPE FOR WRIT OF EXECUTION (MORTGAGE FORECLOSURE) Issue writ of execution in the above matter: Amount Due Interest from 4/15/02 to sale date at $18.13 per diem Total $110,298.62 Plus Costs Jos h A. G eck, Jr. Sui 500- Bourse Bldg. 111 . Ind ndence Mall East Philadelphia, PA 19106 Attorney for Plaintiff Note: Please attach description of property. J A 0 0 0 N N 0 0 N o, N 0 0 Q n Ln N o? z 0 H va v :;P 44 Id z 4 w a All z H as m a ?' 41 a z G G ° U a q >, .1 GI P4 D a H 0 P4 O 9 9 (?f C4 E4 1 4) A H am oro v ?w a 1 a 8 WWA N a °u Ham„ b v P° z b a w } w j?- Lll P4 4 :L .? .. ID i u Sz r. Ll- ? N :2 ' a 0 CD C-) cx° ?x Tract No. 2: All the following described real estate, together with the improvements erected thereon, lying and being situate in Southampton Township, Cumberland County, Pennsylvania, more particularly described as follows: Beginning at a railroad spike in the centerline of Legislative Route 21006, corner of lands now or formerly of John C. Martin; thence by Martin lands, North seventeen (17) degrees nine (9) minutes six (6) seconds West, ninety-three (93) feet to an iron pin; thence by other lands now or formerly of John C. Martin, North eighty-nine (89) degrees sixteen (16) minutes twenty-three (23) seconds West, a distance of one hundred twenty-seven and forty-two hundredths (127.42) feet to an iron pin; thence continuing by other lands of John C. Martin, North eighty (80) degrees zero (00) minutes fifty-five (55) seconds East, a distance of ninety (90) feet to an iron pin at line of lands now or formerly of Lynn H. Delancy; thence by said minutes twenty-seven (27) seconds West, a distance of one hundred eighty-two and eighty hundredths (182.80) feet to a railroad spike in the centerline of Legislative Route 21006; thence by the centerline of Legislative Route 21006, North seventy-three (73) degrees thirteen (13) minutes thirteen (13) seconds East a distance of two hundred seven and sixty-four hundredths (207.64) feet to a railroad spike; thence by the centerline of Legislative Route 21006 North seventy-two (72) degrees fifty (50) minutes fifty-four (54) seconds East, a distance of sixty- five (65) feet to a railroad spike, the point and place of beginning. Containing 0.7216 acres, less 0.1535 acres reserved for improvements of right-of-way of Legislative Route 21006. Being Lot No. 1 on the subdivision plan for John C. Martin dated November 14, 1980, prepared by Carl D. Bert, R.B. Tax Parcel #39130104049C & 39130104949D 4 Being known as 106 - 108 Gilbert Road, Shippensburg, PA 17257. WRIT OF EXECUTION and/or ATTACHMENT COMMONWEALTH OF PENNSYLVANIA) NO 02-859 Civil COUNTY OF CUMBERLAND) CIVIL ACTION - LAW TO THE SHERIFF OF CUMBERLAND COUNTY: To satisfy the debt, interest and costs due COLUMBIA NATIONAL INC PLANTIFF(S) From ROBERT A. DECKER DIANNE L. DECKER (1) You are directed to levy upon the property of the defendant(s) and to sell SEE LEGAL DESCRIPTION OF PROPERTY (2) You are also directed to attach the property of the defendant(s) not levied upon in the possession of GARNISHEE(S) as follows: and to notify the garnishee(s) that: (a) an attachment has been issued; (b) the garnishee(s) is enjoined from paying any debt to or for the account of the defendant (s) and from delivering any property of the defendant (s) or otherwise disposing thereof; (3) If property of the defendant(s) not levied upon an subject to attachment is found in the possession of anyone other than a named garnishee, you are directed to notify him/her that he/she has been added as a garnishee and is enjoined as above stated. Amount Due $110,298.62 L.L.$.50 Interest FROM 4/15/02 TO SALE DATE AT $18.13 PER DIEM Atty's Comm % Due Prothy $1.00 Arty Paid $129.80 Other Costs Plaintiff Paid Date: APRIL 18, 2002 REQUESTING PARTY: CURTIS R. LONG Prothonotary, Civil Division D By: Name JOSEPH A. GOLDBECK, JR. Address: SUITE 500-THE BOURSE BLDG. 111 S. INDEPENDENCE MALL EAST PHILADELPHIA, PA 19106 Attorney for: Plaintiff Telephone: 215-627-1322 Supreme Court ID No. #16132 Rule of Civil Procedure No. 236 - Revised IN THE COURT OF COMMON PLEAS OF Cumberland COUNTY, PENNSYLVANIA CIVIL ACTION - LAW COLUMBIA NATIONAL INC. 7142 Columbia Gateway Drive Columbia, MD 21046 VS. Plaintiff No. 00859-2002 ROBERT A. DECKER DIANNE L. DECKER (Mortgagors and Record Owners) 106-108 Gilbert Road Shippensburg, PA 17257 Defendants THIS LAW FIRM IS A DEBT COLLECTOR AND WE ARE ATTEMPTING TO COLLECT A DEBT OWED TO OUR CLIENT. ANY INFORMATION OBTAINED FROM YOU WILL BE USED FOR THE PURPOSE OF COLLECTING THE DEBT. NOTICE Notice is given that a judgment in the above-captioned matter has been entered against you. Prothonotary By: If you have any questions concerning the above, please contact: Joseph A. Goldbeck, Jr. Goldbeck McCafferty & McKeever Suite 500 - The Bourse Bldg. 111 S. Independence Mall East Philadelphia, PA 19106 215-627-1322 GOLDBECK McCAFFERTY & McKEEVER BY: Joseph A. Goldbeck, Jr. Attorney I.D.#16132 Suite 500 - The Bourse Bldg. 111 S. Independence Mall East Philadelphia, PA 19106 215-627-1322 Attorney for Plaintiff COLUMBIA NATIONAL INC. 7142 Columbia Gateway Drive Columbia, MD 21046 Plaintiff Vs. IN THE COURT OF COMMON PLEAS of Cumberland County CIVIL ACTION - LAW ROBERT A. DECKER DIANNE L. DECKER (Mortgagors and Record Owners) 106-108 Gilbert Road Shippensburg, PA 17257 Defendants ACTION OF MORTGAGE FORECLOSURE Term No. 00859-2002 AFFIDAVIT PURSUANT TO RULE 3129 COLUMBIA NATIONAL INC., Plaintiff in the above action, by its attorney, Joseph A. Goldbeck, Jr., Esquire, sets forth as of the date the praecipe for the writ of execution was filed the following information concerning the real property located at: 106-108 Gilbert Road, Shippensburg, PA 17257 1.Name and address of Owner(s) or Reputed Owner(s): ROBERT A. DECKER 125 Airport Road, Shippensburg, PA 17257 DIANNE L.. DECKER 125 Airport Road, Shippensburg, PA 17257 2. Name and address of Defendant(s) in the judgment: ROBERT A. DECKER 125 Airport Road, Shippensburg, PA 17257 DIANNE L. DECKER 125 Airport Road, Shippensburg, PA 17257 3. Name and last known address of every judgment creditor whose judgment is a record lien on the property to be sold: PA DEPARTMENT OF PUBLIC WELFARE - Bureau of Child Support Enforcement Health and Welfare Bldg. - Room 432 P.O. Box 2675 Harrisburg, PA 17105-2675 DOMESTIC RELATIONS OF CUMBERLAND COUNTY PO Box 320, Carlisle, PA 17013 4. Name and address of the last recorded holder of every mortgage of record: GMAC Mortgage Corp. 8360 Old York Road Elkins Park, PA 19027 5. Name and address of every other person who has any record interest in or record lien on the property and whose interest may be affected by the sale: 6. Name and address of every other person of whom the plaintiff has knowledge who has any record interest in the property which 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. (attach separate sheet if more space is needed) I verify that the statements made in this affidavit are true and correct to the best of my personal knowledge or information and belief. I understand that false statements herein are made subject to the penalties of 18 Pa. C.S. Section 4904 relating to unsworn falsification to authorities. DATED: April 15, 2002 ?- ? ?' \ GOLDS K McCAFF TY & McKEEVER BY: J eph A. G ldbeck, Jr., Esq. Atto v for P1 intiff C7 Q ? { - U' 'L3 - - ?7l ? 11 Lt ? G> >-_ 07 1 Z ..F: tJ r C7 -4 tD ? Joseph A. Goldbeck, Jr. Attorney I.D. #16132 Suite 500 - The Bourse Bldg. 111 S. Independence Mall East Philadelphia, PA 19106 215-627-1322 Attorney for Plaintiff COLUMBIA NATIONAL INC. 7142 Columbia Gateway Drive Columbia, MD 21046 Plaintiff Vs. ROBERT A. DECKER DIANNE L. DECKER (Mortgagors and Record Owners) 106-108 Gilbert Road Shippensburg, PA 17257 Defendants IN THE COURT OF COMMON PLEAS of Cumberland County CIVIL ACTION - LAW ACTION OF MORTGAGE FORECLOSURE TERM NO. 00859-2002 CERTIFICATION AS TO THE SALE OF REAL PROPERTY I, Joseph A. Goldbeck, Jr., Esquire hereby certify that I am the attorney of record for the Plaintiff in this action, and I further certify that this property is subject to Act 91 of 1983 and the Plaintiff has complied with all the provisions of the Act. o N n ?' 7T .._i z -r:T M Urn ? -C CA G GOLDBECK McCAFFERTY & McKEEVER BY: Joseph A. Goldbeck, Jr. Attomey I.D.#16132 Suite 500 - The Bourse Bldg. 111 S. Independence Mall East Philadelphia, PA 19106 215-627-1322 Attorney for Plaintiff' COLUMBIA NATIONAL INC. 7142 Columbia Gateway Drive Columbia, MD 21046 Plaintiff Vs. ROBERT A. DECKER DIANNE L. DECKER (Mortgagors and Record Owners) 106-108 Gilbert Road Shippensburg,PA 17257 Defendants IN THE COURT OF COMMON PLEAS of Cumberland County CIVIL ACTION - LAW ACTION OF MORTGAGE FORECLOSURE Term No. 00859-2002 THIS LAW FIRM IS A DEBT COLLECTOR AND WE ARE ATTEMPTING TO COLLECT A DEBT. THIS NOTICE IS SENT TO YOU IN AN ATTEMPT TO COLLECT A DEBT. ANY INFORMATION OBTAINED FROM YOU WILL BE USED FOR THAT PURPOSE. NOTICE OF SHERIFF'S SALE OF REAL PROPERTY TO: DECKER, ROBERT A. ROBERT A. DECKER 125 Airport Road Shippensburg, PA 17257 Your house at 106-108 Gilbert Road, Shippensburg, PA 17257 is scheduled to be sold at Sheriffs Sale on Wednesday, September 04, 2002, at 10:00 AM, in Commissioners Hearing Rm 2nd FL Courthouse to enforce the court judgment of $110,298.62 obtained by COLUMBIA NATIONAL INC. against you. NOTICE OF OWNER'S RIGHTS YOU MAY BE ABLE TO PREVENT THIS SHERIFF'S SALE To prevent this Sheriffs Sale you must take immediate action: 1. The sale will be cancelled if you pay to Columbia National, Inc. the back payments, late charges, costs and reasonable attorney's fees due. To find out how much you must pay call: 215-627-1322 2. You may be able to stop the sale by filing a petition asking the Court to strike or open judgment, if the judgment was improperly entered. You may also ask the Court to postpone the sale for good cause. 3. You may also be able to stop the sale through other legal proceedings. You may need an attorney to assert your rights. The sooner you contact one, the more chance you will have of stopping the sale. (See notice below on how to obtain an attorney). YOU MAY STILL BE ABLE TO SAVE YOUR PROPERTY AND YOU HAVE OTHER RIGHTS EVEN IF THE SHERIFF'S SALE DOES NOT TAKE PLACE. 1. If the Sheriffs Sale is not stopped, your property will be sold to the highest bidder. You may find out the price bid price by calling the Sheriff of 717-240-6390. 2. You may be able to petition the Court to set aside the sale if the bid price was grossly inadequate compared to the value of your property. 3. The sale will go through only if the buyer pays the Sheriff the full amount due in the sale. To find out if this has happened, you may call the Sheriff of 717-240-6390. 4. If the amount due from the Buyer is not paid to the Sheriff, you will remain the owner of the property as if the sale never happened. 5. You have a right to remain in the property until the full amount due is paid to the Sheriff and the Sheriff gives a deed to the buyer. At that time, the buyer may bring legal proceedings to evict you. 6. You may be entitled to a share of the money which was paid for your house. A schedule of distribution of the money bid for your house will be filed by the Sheriff thirty (30) days from the date of the Sheriffs Sale. This schedule will state who will be receiving that money. The money will be paid out in accordance with this schedule unless exceptions (reasons why the proposed distribution is wrong) are filed with the Sheriff within ten (10) days after the schedule of distribution is filed. 7. You may also have other rights and defenses, or ways of getting your house back, if you act immediately after the sale. YOU SHOULD TAKE THIS PAPER TO YOUR LAWYER AT ONCE. IF YOU DO NOT HAVE A LAWYER OR CANNOT AFFORD ONE, GO TO OR TELEPHONE THE OFFICE LISTED BELOW TO FIND OUT WHERE YOU CAN GET LEGAL HELP. CUMBERLAND COUNTY BAR ASSOCIATION 2 Liberty Avenue Carlisle, PA 17013 LEGAL SERVICES INC 8 Irvine Row Carlisle, PA 17013 0 o O C Ss V1:: co C ) =i ?7 . DG ?O ??m N 3T QD ? GOLDBECK McCAFFERTY & McKEEVER BY: Joseph A. Goldbeck, Jr. Attorney I.D.#16132 Suite 500 - The Bourse Bldg. 11 I S. Independence Mall East Philadelphia, PA 19106 215-627-1322 Attorney for Plaintiff COLUMBIA NATIONAL INC. 7142 Columbia Gateway Drive Columbia, MD 21046 Plaintiff Vs. IN THE COURT OF COMMON PLEAS of Cumberland County CIVIL ACTION - LAW ROBERT A. DECKER DIANNE L. DECKER (Mortgagors and Record Owners) 106-108 Gilbert Road Shippensburg,PA 17257 Defendants ACTION OF MORTGAGE FORECLOSURE Term No. 00859-2002 THIS LAW FIRM IS A DEBT COLLECTOR AND WE ARE ATTEMPTING TO COLLECT A DEBT. THIS NOTICE IS SENT TO YOU IN AN ATTEMPT TO COLLECT A DEBT. ANY INFORMATION OBTAINED FROM YOU WILL BE USED FOR THAT PURPOSE. NOTICE OF SHERIFF'S SALE OF REAL PROPERTY TO: DECKER, DIANNE L. DIANNE L. DECKER 125 Airport Road Shippensburg,PA 17257 Your house at 106-108 Gilbert Road, Shippensburg, PA 17257 is scheduled to be sold at Sheriffs Sale on Wednesday, September 04, 2002, at 10:00 AM, in Commissioners Hearing Rm 2nd FL Courthouse to enforce the court judgment of $110,298.62 obtained by COLUMBIA NATIONAL INC. against you. NOTICE OF OWNER'S RIGHTS YOU MAY BE ABLE TO PREVENT THIS SHERIFF'S SALE To prevent this Sheriffs Sale you must take immediate action: 1. The sale will be cancelled if you pay to Columbia National, Inc. the back payments, late charges, costs and reasonable attorney's fees due. To find out how much you must pay call: 215-627-1322 2. You may be able to stop the sale by filing a petition asking the Court to strike or open judgment, if the judgment was improperly entered. You may also ask the Court to postpone the sale for good cause. 3. You may also be able to stop the sale through other legal proceedings. You may need an attorney to assert your rights. The sooner you contact one, the more chance you will have of stopping the sale. (See notice below on how to obtain an attorney). YOU MAY STILL BE ABLE TO SAVE YOUR PROPERTY AND YOU HAVE OTHER RIGHTS EVEN IF THE SHERIFF'S SALE DOES NOT TAKE PLACE. 1. If the Sheriffs Sale is not stopped, your property will be sold to the highest bidder. You may find out the price bid price by calling the Sheriff of 717-240-6390. 2. You may be able to petition the Court to set aside the sale if the bid price was grossly inadequate compared to the value of your property. 3. The sale will go through only if the buyer pays the Sheriff the full amount due in the sale. To find out if this has happened, you may call the Sheriff of 717-240-6390. 4. If the amount due from the Buyer is not paid to the Sheriff, you will remain the owner of the property as if the sale never happened. 5. You have a right to remain in the property until the full amount due is paid to the Sheriff and the Sheriff gives a deed to the buyer. At that time, the buyer may bring legal proceedings to evict you. 6. You may be entitled to a share of the money which was paid for your house. A schedule of distribution of the money bid for your house will be filed by the Sheriff thirty (30) days from the date of the Sheriffs Sale. This schedule will state who will be receiving that money. The money will be paid out in accordance with this schedule unless exceptions (reasons why the proposed distribution is wrong) are filed with the Sheriff within ten (10) days after the schedule of distribution is filed. 7. You may also have other rights and defenses, or ways of getting your house back, if you act immediately after the sale. YOU SHOULD TAKE THIS PAPER TO YOUR LAWYER AT ONCE. IF YOU DO NOT HAVE A LAWYER OR CANNOT AFFORD ONE, GO TO OR TELEPHONE THE OFFICE LISTED BELOW TO FIND OUT WHERE YOU CAN GET LEGAL HELP. CUMBERLAND COUNTY BAR ASSOCIATION 2 Liberty Avenue Carlisle, PA 17013 LEGAL SERVICES INC 8 Irvine Row Carlisle, PA 17013 n co O 7 N 1 M MI ? t7 T . T i 71 r 1 CP m j C s. G -ICJ ?y l0 ?iTl +v GOLDBECK McCAFFERTY & McKEEVER BY: Joseph A. Goldbeck, Jr. Attorney I.D.#16132 Suite 500 - The Bourse Bldg. 111 S. Independence Mall East Philadelphia, PA 19106 215-627-1322 for Plaintiff COLUMBIA NATIONAL INC. 7142 Columbia Gateway Drive Columbia, MD 21046 Vs. Plaintiff ROBERT A. DECKER DIANNE L. DECKER Mortgagors and Record Owners 106-108 Gilbert Road Shippensburg,PA 17257 Defendants IN THE COURT OF COMMON PLEAS of Cumberland County CIVIL ACTION - LAW ACTION OF MORTGAGE FORECLOSURE No. 00859-2002 CERTIFICATE OF SERVICE PURSUANT TO Pa.R.C.P. 3129.2 (c) (2) Joseph A. Goldbeck, Jr., Esquire, Attorney for Plaintiff, hereby certifies that service on the Defendants of the Notice of Sheriff Sale was made by: Personal Service by the Sheriffs Office/o&w4e69x6ed**(copy of return attached). Certified mail by Joseph A. Goldbeck, Jr. (original green Postal return receipt attached). ( ) Certified mail by Sheriffs Office. ( ) Ordinary mail by Joseph A. Goldbeck, Jr., Esquire to Attorney for Defendant(s) of record (proof of mailing attached). ( ) Acknowledgment of Sheriffs Sale by Attorney for Defendant(s) (proof of acknowledgment attached). ( ) Ordinary mail by Sheriffs Office to Attorney for Defendant(s) of record. IF SERVICE WAS ACCOMPLISHED BY COURT ORDER ( ) Premises was posted by Sheriffs Office/competent adult (copy of return attached). ( ) Certified Mail & ordinary mail by Sheriffs Office (copy of return attached). ( ) Certified Mail & ordinary mail by Joseph A. Goldbeck, Jr. (original receipt(s) for Certified Mail attached). Pursuant to the Affidavit under Rule 3129 (copy attached), service on all lienholders (if any) has been made by ordinary mail by Joseph A. Goldbeck, Jr., Esquire (copies of proofs of mailing attached). The undersigned understands that the statements herein are subject to the penalties provided by 18 P.S. Section 4904. submitted, x // - CI ph IA. Goldbeck, Jr. for Plaintiff T O 3 W co to w ,-?yG^` Up _ V 1- 0 "O 1. • 7 2v O to • 0 r o f)7 A W N -? O W co V W (n A W N s G D Z ?c (03 9. s s C $Z 3 T 2 3 . 1 A b z3g°?r, jJ251 ! a mi _ 55ppap5p5({({ o a?wM?•?T S SF ? • A?$3 $ R Emil s,. at 11 I wil a¢ N iE 5 1. g F,?,m 10 ?° Von -?Cm 10 cm & x 8 oz J ? N 1 l' nJL 1 ? cK %0 ** 00 A N 4 %0 %0 w N N ?? a O N>I?I C ? 'O 0 ? N ? • N ? O\ J .a .p O O ++ . O? N W _T 0>z s N 3 Z ?? v ? N z b 3 ? ? a ? Ro Q% N $° 1100 M 0 O A n: n e s? o e 3 °- 0 v o O A m g Y b aa O A br n ° • ti m n <3 s a's4 O?o a ?z v o : m D rr ? v. S?c.SQ N oa . • ? m N = C ?JU CL 3 r Columbia National Inc. In the Court of Common Pleas of VS Cumberland County, Pennsylvania Robert A. Decker and Writ No. 2002-859 Civil Term Dianne L. Decker Brian Barrick, Deputy Sheriff, who being duly sworn according to law, states that on May 9, 2002 at 7:26 o'clock PM, he served a true copy of the within Real Estate Writ, Notice and Description, in the above entitled action, upon the within named defendant, to wit: Robert A. Decker, by making known unto Robert Decker personally, at 125 Airport Road, Shippensburg, Cumberland County, Pennsylvania, its contents and at the same time handing to him personally the said true and correct copy of the same. Brian Barrick, Deputy Sheriff, who being duly sworn according to law, states that on May 9, 2002 at 7:26 o'clock PM, he served a true copy of the within Real Estate Writ, Notice and Description, in the above entitled action, upon the within named defendant, to wit: Dianne L. Decker, by making known unto Robert Decker, husband of defendant, at 125 Airport Road, Shippensburg, Cumberland County, Pennsylvania, its contents and at the same time handing to him personally the said true and correct copy of the same. Jason Vioral, Deputy Sheriff, who being duly sworn according to law, states that on July 10, 2002 at 12:29 o'clock P.M., he posted a true copy of the within Real Estate Writ, Notice, Poster and Description, in the above entitled action, upon the property of Robert A. Decker and Dianne L. Decker located at 106-108 Gilbert Road, Shippensburg, 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 Sheriff mailed a notice of the pendency of the action to one of the within named defendants to wit: Robert A. Decker, by regular mail to his last known address of 125 Airport Road, Shippensburg, PA 17257. This letter was mailed under the date of July 12, 2002 and never returned to the Sheriff's Office. 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 Sheriff mailed a notice of the pendency of the action to one of the within named defendants to wit: Dianne L. Decker, by regular mail to her last known address of 125 Airport Road, Shippensburg, PA 17257. This letter was mailed under the date of July 12, 2002 and never returned to the Sheriff's Office. Sworn and subscribed to before me s s: R. Thomas Kline heriff BYVO , s? Real Estat eputy This day of 2002, Prothonotary GOLDBECK McCAFFERTY & McKEEVER BY: Joseph A. Goldbeck, Jr. Attorney I.D.#16132 Suite 500 - The Bourse Bldg. 111 S. Independence Mall East Philadelphia, PA 19106 215-627-1322 Attorney for Plaintiff COLUMBIA NATIONAL INC. 7142 Columbia Gateway Drive Columbia, MD 21046 Plaintiff vs. ROBERT A. DECKER DIANNE L. DECKER Mortgagors and Record Owners 106-108 Gilbert Road Shippensburg, PA 17257 Defendants IN THE COURT OF COMMON PLEAS of Cumberland County CIVIL ACTION - LAW ACTION OF MORTGAGE FORECLOSURE Term No. 00859-2002 AFFIDAVIT PURSUANT TO RULE 3129 COLUMBIA NATIONAL INC., Plaintiff in the above action, by its attorney, Joseph A. Goldbeck, Jr., Esquire, sets forth as of the date the praecipe for the writ of execution was filed the following information concerning the real property located at: 106-108 Gilbert Road, Shippensburg, PA 17257 1.Name and address of Owners or Reputed Owners: ROBERT A. DECKER 125 Airport Road Shippensburg, PA 17257 DIANNE L. DECKER 125 Airport Road Shippensburg, PA 17257 2. Name and address of Defendants in the judgment: ROBERT A. DECKER 125 Airport Road Shippensburg, PA 17257 DIANNE L. DECKER 125 Airport Road Shippensburg, PA 17257 3. Name and last known address of every judgment creditor whose judgment is a record lien on the property to be sold: PA DEPARTMENT OF PUBLIC WELFARE- Bureau of Child Support Enforcement Health and Welfare Bldg. - Room 432 P.O. Box 2675 Harrisburg, PA 17105-2675 DOMESTIC RELATIONS OF CUMBERLAND COUNTY PO Box 320 Carlisle, PA 17013 4. Name and address of the last recorded holder of every mortgage of record: GMAC Mortgage Corp. 8360 Old York Road Elkins Park, PA 19027 5. Name and address of every other person who has any record interest in or record lien on the property and whose interest may be affected by the sale: 6. Name and address of every other person of whom the plaintiff has knowledge who has any record interest in the property which 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. (attach separate sheet if more space is needed) I verify that the statements made in this affidavit are true and correct to the best of my personal knowledge or information and belief. I understand that false statements herein are made subject to the penalties of 18 Pa. C.S. Section 4904 relating to unsworn falsification to authorities. DATED: August 19, 2002 VJoBB-EE VAAGGolddbeck, CCAFFERTY & McKEEVER 91::z? ep Jr., Esq. Attorney for Plaintiff -r, 'C? ET A .-1 (l`i u'1 i?T PN1J fb 7160 3901 9644 7671 0797 TO: DECKER, ROBERT A. ROBERT A. DECKER 125 Airport Road Shippensburg, PA 17257 SENDER: GOLDBECK MCCAFFERTY & MCKEEVER April 15, 2002 REFERENCE: DECKER, ROBERT A./ PW-0648 09/04/02 - Cumberland RETURN RECEIPT SERVICE Return Receipt Fee Restricted Delivery Total Postage S Fees, US Postal Service ?Q7MARI qp I Receipt for Certified Mail No Insurance Coverage Provided Do Not Use for International Mail AFFIX POSTAGE TO MAIL PIECE TO COVER FIRST CLASS POSTAGE, CERTIFIED FEE, RETURN RECEIPT FEE AND' CHARGES FOR ANY SELECTED OPTIONAL SERVICES. 1. Detach the form 3811, Domestic return receipt by tear- ing left to right across pert. Attach to mailpiece by peeling back the adhesive strips and affixing to front of mailpiece if space permits. Otherwise affix to back of mailpiece. 2. If you do not want the receipt postmarked, stick the article # label to the right of the return address, date receipt and retain the receipt. 3. If you want this receipt postmarked, slip the 3800 receipt between the return receipt, and the mailpiece, and slide the edge of the receipt to the gummed edge of adhesive. This will hold the receipt in place to present to your mailcenter, or post office service window. (SEE ILLUSTRATION) W.lib•iJ I r<us N1 NS 1FY A O.Yw 1 < pY, npmp6? YnrY,ln^ Y<nnHr ll9pu, pC plp}OfMI,] I,n 1?0 rw M1tn kWlM MMoD mil nr.r taw m..lMtsllM.umm I Davie 0. 002 LSNI Ssament Msrkallna Manaaar Walz Poets, Solution., Inc. 1588 South MINIOn XE. SuIN 110 Fallhraok, CA .2024-4112 4. Enter fees for the services requested in the appropriate spaces on the front of this receipt. 1i 5. Save this receipt and present it if you make an inquiry. 7160 3W1 g844 7671 0803 -ro: DECKER, DIANNE L. DIpNNE L. DECKER 125 Airport Road Shippertsburg, PA 17257 SENDER: GOLDBECK MCCAFFERTY & MCKEEVF Al)ril 15, 2002 REFERENCE: DECKER, ORZBER A. land 0648 RETURN rwwy- RECEIPT Certified Fee SERVICE Return Receipt Fee Total Postage ?` Fees 1 10 POSTMARK OR US Postal Service Receipt for Certified Mail nsurance DolNot Use for?nternational1Mai1 -? AFFIX POSTAGE TO MAIL PIECE TO COVER FIRST CLASS POSTAGE, CERTIFIED FEE, RETURN RECEIPT FEE AND CHARGES FOR ANY SELECTED OPTIONAL SERVICES. 1. Detach the form 3811, Domestic return receipt by tear- Ing left to right across perf. Attach to mailpiece by peeling back the adhesive strips and affixing to front of mailpiece if s 2, YOU do not want the pace permits. Otherwise affix to back of mailpiece. article l# abet to the right of theeretarn address, date receipt and retain the receipt. 3• If You want this receipt postmarked, slip the 3800 receipt between the return receipt, and the mailpiece, and slide the edge of the receipt to the hold the receipt in gummed edge of adhesive. This will place to present to Your mailcenter, or post office service window. (SEE ILLUSTRATION) - ? p • 2e1 N2 lY2 ley Mpmrnl YerYelly Wntptr ISlp BeuMY rbn 4tl Bt g110roeY, Cp {p0fe111]ull I Y0W R111gnM "?: 441gM4 la 44441 BbeM.-IM CSY. Sl41p lyy I?r =? oevle D. obe ent agoall IP0u141 Mark. ' 1118 8ou1M1 Mleklon q0. I 1 ellbtao4, CA 02028-4112Sulla 110 r t f 4• Enter fees for the services requested r spaces on the front of this receipt, in the appropriate f 5• Save this receipt and present it if you make an inouirv COMMONWEALTH OF PENNSYLVANIA COUNTY OF CUMBERLAND } SS: I, Robert P. Ziegler, Recorder of Deeds in and for said County and State do hereby certify that the Sheriff's Deed in which Secretary of Veterans Affairs is the grantee the same having been sold to said grantee on the 4th day of Sept A.D., 2002, under and by virtue of a writ Execution issued on the 18th day of April, A.D., 2002, out of the Court of Common Pleas of said County as of Civil Term, 2002 Number 859, at the suit of Columbia Natl Inc against Robert A Decker & Dianne L is duly recorded in Sheriffs Deed Book No. 254, Page 838. IN TESTIMONY WHEREOF, I have hereunto set my hand and seal of said office this day of A.D. 2002 of Deeds ASCO(dw of Deeds, Cunbe"WW ?CBW^ PA My Cattt"Ion EVWN the Fft dim WN Columbia National Inc. In the Court of Common Pleas of VS Cumberland County, Pennsylvania Robert A. Decker and Writ No. 2002-859 Civil Term Dianne L. Decker Brian Barrick, Deputy Sheriff, who being duly sworn according to law, states that on May 9, 2002 at 7:26 o'clock PM, he served a true copy of the within Real Estate Writ, Notice and Description, in the above entitled action, upon the within named defendant, to wit: Robert A. Decker, by making known unto Robert Decker personally, at 125 Airport Road, Shippensburg, Cumberland County, Pennsylvania, its contents and at the same time handing to him personally the said true and correct copy of the same. Brian Barrick, Deputy Sheriff, who being duly sworn according to law, states that on May 9, 2002 at 7:26 o'clock PM, he served a true copy of the within Real Estate Writ, Notice and Description, in the above entitled action, upon the within named defendant, to wit: Dianne L. Decker, by making known unto Robert Decker, husband of defendant, at 125 Airport Road, Shippensburg, Cumberland County, Pennsylvania, its contents and at the same time handing to him personally the said true and correct copy of the same. Jason Vioral, Deputy Sheriff, who being duly sworn according to law, states that on July 10, 2002 at 12:29 o'clock P.M., he posted a true copy of the within Real Estate Writ, Notice, Poster and Description, in the above entitled action, upon the property of Robert A. Decker and Dianne L. Decker located at 106-108 Gilbert Road, Shippensburg, 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 Sheriff mailed a notice of the pendency of the action to one of the within named defendants to wit: Robert A. Decker, by regular mail to his last known address of 125 Airport Road, Shippensburg, PA 17257. This letter was mailed under the date of July 12, 2002 and never returned to the Sheriff's Office. 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 Sheriff mailed a notice of the pendency of the action to one of the within named defendants to wit: Dianne L. Decker, by regular mail to her last known address of 125 Airport Road, Shippensburg, PA 17257. This letter was mailed under the date of July 12, 2002 and never returned to the Sheriff s Office. R. Thomas Kline, Sheriff, who being duly sworn according to law, states that after due and legal notice had been given according to law, he exposed the within described premises at public venue or outcry at the Court House, Carlisle, Cumberland County, Pennsylvania, on September 4, 2002 at 10:00 AM. He sold the same for the sum of $70,000.00 to Attorney Joseph Goldbeck for Secretary of Veterans Affairs. It being the highest bid and best price received for the same, Secretary of Veterans Affairs of 5000 Wissahickon Ave., Philadelphia, PA 19144, being the buyer in this execution, paid Sheriff R. Thomas Kline the sum of $8,500.00. Sheriffs Costs: Docketing $ 30.00 Poundage 1400.00 Posting Bills 30.00 Advertising 30.00 Acknowledging Deed 30.00 Auctioneer 20.00 Law Library .50 Prothonotary 1.00 Mileage 26.91 Certified Mail 6.97 Levy 30.00 Surcharge 40.00 Legal Search 400.00 Law Journal 656.00 Patriot News 472.15 Share of Bills 25.20 Distribution of Proceeds 25.00 Sheriff s Deed 29.50 $3,253.23 Sworn and subscribed to before me This Su' day of ( ,p... R. Thomas Kline, Sheriff r? 2002, A.D. B? ??c) Prothonotary Real Estate Deputy CO 3a Cdr 3 ?' L s"? Real Estate Sale #01 On May 8, 2002 the sheriff levied upon the defendant's interest in the real property situated in Southampton Township, Cumberland County, PA known and numbered as 106-108 Gilbert Road, Shippensburg, and more fully described on Exhibit "A" filed with this writ and by this reference incorporated herein. -r," Date: May 8, 2002 By: Jootq J. &tL: Real Estate Deputy A ?\ A SCHEDULE OF DISTRIBUTION SALE NO. 01 Date Filed: October 4, 2002 Writ No. 2002-859 Civil Term Columbia National Inc. VS Robert A. Decker and Dianne L. Decker 106-108 Gilbert Road Shippensburg, PA 17257 Sale Date: September 4, 2002 Buyer: Secretary of Veterans Affairs Bid Price: $70,000.00 Real Debt $110,298.62 Interest 2,574.46 Attorney Writ Costs 129.80 Total: $113,002.88 DISTRIBUTION Receipts: Cash on account (05/8/02) $1,000.00 Cash on account (8/28/02) 500.00 Cash on account (9/04/02) 7,000.00 Credit Writ 61,500.00 Total Receipts: $70,000.00 Disbursements: To Sheriffs Costs To Legal Search To Attorney Joseph Goldbeck Credit Writ Total Disbursement: Balance for Distribution: So Answers: $2,853.23 400.00 5,246.77 61.500.00 ($70,000.00) 0.00 R. Thomas Kline Sheriff TITLE REPORT THE PREMISES ENDORSED HEREON ARE SUBJECT TO THE FOLLOWING ITEMS, WHICH WILL BE EXCEPTED IN THE POLICY UNLESS SATISFACTORY EVIDENCE PERMITTING THEIR REMOVAL IS PRODUCED. SHERIFF SALE NO.1 Held Wednesday, September 4, 2002 Date: September 4, 2002 TAXES: Receipts for all taxes for the years 1999 to 2001 inclusive. Taxes for the current year 2002. WATER RENT: Company assumes no liability for private supply of water or sewer. SEWER RENT Receipts to be produced if services are lienable. MECHANICS' AND Possible unfiled Mechanics Liens and Municipal Claims. MUNICIPAL CLAIMS MORTGAGES: Listed Under Other Exceptions Below. JUDGMENTS: Listed Under Other Exceptions Below. INSTRUMENTS TO BE PRODUCED: Deed from Cumberland County Sheriff to dated 2002, and recorded , 2002, in Cumberland County Deed Book , Page RECITAL: BEING the same premises which Patrick E. Ott and Tracy S. Ott his wife, by deed dated April 1, 1997 and recorded April 7, 1997 in the Office of the Recorder of Deeds in and for Cumberland County, at Carlisle, Pennsylvania in Deed Book 155, Page 561 granted and conveyed to Robert A. Decker and Dianne L. Decker, his wife. OTHER EXCEPTIONS: 1. The identity and legal competency of parties at the closing of this title should be established to the satisfaction of the closing attorney acting for this Company. 2. Rights or claims of parties in possession, if any, other than the owner. 3. Unrecorded easements, discrepancies or conflicts in boundary lines, shortage in area and encroachments which an accurate and complete survey would disclose. Payment of State and local Real Estate Transfer Taxes, if required. 5. Public and private rights in the road bed of L. R. 21006 dedicated 25 feet from the center line. 6. Conditions, easements and restrictions shown on or set forth on the Plan of Land Subdivision for John C. Martin recorded in Cumberland County Plan Book 43, Page 21 and on the Plan of Land Subdivision for John C. Martin recorded in Cumberland County Plan Book 44, Page 21. Mortgage in the amount of $3,000.00 given by Mervin E. Negley and Betty Negley, his wife, to People's National Bank of Shippensburg dated April 9, 1949 recorded April 18, 1949 in Mortgage Book 226, Page 462. 8. Mortgage in the amount of $67,500.00 given by Patrick E. Ott to United Federal Savings Bank,a dated September 24, 1993 and recorded September 30, 1993 in Mortgage Book 1167 Page 439. 9. Mortgage in the amount of $98,850.00 given by Robert A. Decker and Dianne L. Decker to Columbia National. Inc. dated April 1, 1997 and recorded April 7, 1997 in Mortgage Book 1373, Page 949. Complaint in mortgage foreclosure filed by Columbia National Inc. as Plaintiff against Robert A. Decker and Dianne L. Decker as Defendant in the office of the Prothonotary of Cumberland County on February 19, 2002 to File No. 2002-859. Judgment in the amount of $110,298.62 entered April 18, 2002. 10. Mortgage in the amount of $85,000.00 given by Robert A. Decker and Dianne L. Decker to GMAC Mortgage Corporation dated February 10, 2000 recorded March 8, 2000 in Mortgage Book 1599, Page 626. 11. Subject to rights of John C. Martin and Edna M. Martin, their heirs, successors and assigns, in a 20 foot wide easement for use and repair of a water line as set forth in deed recorded March 4, 1983 in Deed Book "B," Volume 30, Page 915. 12. Rights granted to Adams Electric Cooperative, Inc. by instrument recorded August 19, 1983 in Miscellaneous Record Book 288, Page 785. 13. Rights granted to United Telephone Company of Pennsylvania by instrument recorded January 31, 1975 in Miscellaneous Record Book 213, Page 422. 14. Rights granted to United Telephone Company of Pennsylvania by instrument recorded August 5, 1953 in Miscellaneous Record Book 103, Page 402. 15. Rights granted to United Telephone Company of Pennsylvania by instrument recorded August 8 1953 in Miscellaneous Record Book 103, Page 400. 16 Satisfactory evidence to be produced that proper notice was given to the holders of all liens and encumbrances intended to be divested by subject Sheriff Sale. It is to be noted that no notice was given to United Federal Savings Bank or to People's National Bank of Shippensburg, holders of open and unsatisfied mortgages. 17. Real estate taxes accruing on and after January 1, 2003 not yet due and payable. It is to be noted that no search of Domestic Relations Records has been made to determine support arrearages regarding House Bill 1412, Act 58 of 1997, nor has any search been made for environmental liens in Federal District Court. Robert G. Frey, Agent Note: This Title Report shall not be valid or t until countersigned by an authorized signatory. t SHERIFFS SALE a distance of ninety-three 93 Wednesday to an iron ( ) feet . September 4, 2002 northern Pin: thence along the - edge of Lot No. 1, South BY virtue of certain Writs of Ex- eighty-nine (89) degrees s' ecution, issued out of minutes twent• - sixteen. (16) Common Pleas of Cumber and urt of West, Y three (23) seconds a distance of one-hundred C Pennsylvania and to Coun_ twenty-seven and for ty tY, -two will expose at me directed , dredths (127.42) feet to iron ll exue or outblic sale by pub- thence alon an uOn pin; vend Court House in ?'' at the new g thc. same, North eighty the County Co (80) degrees zero (00) minutes fifty- oner's Conference Room, nmiis- five (55) seconds West, in the Borough 2nd Floor, of ninety (90) feet to a distance in vania th at 10:00 O'clock A.M. le' Pennsyl- thence aloe an iron g lands now North f pin; gTime on Prevail- of Lynn H. Delaney, NOS fi formerly f es the above date, the here- degrees twenty-eight (28) ve minutes rafter mentioned real estate. 27) All parties in interest and Claim- twenty-seven ( (27) seconds East, a ants are es in distance of two hundred hereby ninety-eght notified that a and ninety-four hundredths (298194) schedule of Distribution will be by the Sheriff October 4 filed feet to an iron pin; thence along the that distribution will r 2002' and southern edge of Lot No. cordance with said will be'made in ac- eighty-four (84) degrees thi ri, South exceptions are filed schedule unless (31) minutes thirty-three (33) sec- ten (10) days thereto within onds East, a distance of four (hun- thereinafter. dred el --?' hundredths(418 and e feet tota-an ESTATE SALE NO 1 Pin: thence orlon an iron Portion of Lot No the southwestern Writ No. degrees f _ 5' South three (3) 2002-859 Civil (12) seconds W five est( a l mu cutes e welve Columbia National Inc. c• hundred five stance of three vs. .92) feet to and ninety-two (305- Robert A. Decker and islative Route 2 ] OOEa spike in Dianne L. Decker thence along Legislative Route 21006, South Atty.: Joseph Goldbeck, Jr. seven All the followin (15) tythree (73) degrees fifteen estate, to ether g described real minutes fifty-five (55) seconds meats ere red thereon; e improve- West, a distance of seventy-seven being situate in SoutharrIp lying and feet to a railroad seven hundredths (77 27) ship. Cumberland Coun topes 1 the sameut spike; thence along vania, y _ South seventy-two (72) more particularly described degrees fif as follows: (54) seconds W ? t a minu di ten fifty-four Tract No. 1: hundred eleven and stance ninety-e one Begininning at a railroad spike in hundredths (111.98) feet to the place Be Legislative Route a 21006 rail at the South- of beginnin ? Place eastern co acres, g' Containing a 3.1114 plan rner of Lot No. 1 on and being Lot No. 4 on a hereinafter mentioned the of lots recorded in Plain Book 43, then ce orlon plan of lots; Page 21. g the c North seveneastern teen age of Lot Subject to restrictions recorded nme (9) minutes six (1) degrees in Cumberland County (6) seconds West, 43, Page 21. Plan Book 11 GOLDBECK MCCAFFERTY & MCKEEVER BY: Joseph A. Goldbeck, Jr. Attorney I.D.#16132 Suite 500 - The Bourse Bldg. 111 S. Independence Mall East Philadelphia, PA 19106 215-627-1322 Attorney for Plaintiff COLUMBIA NATIONAL INC. 7142 Columbia Gateway Drive Columbia, MD 21046 Plaintiff Vs. ROBERT A. DECKER DIANNE L. DECKER (Mortgagors and Record Owners) 106-108 Gilbert Road Shippensburg, PA 17257 Defendants IN THE COURT OF COMMON PLEAS of Cumberland County CIVIL ACTION - LAW ACTION OF MORTGAGE FORECLOSURE Term No. 00859-2002 AFFIDAVIT PURSUANT TO RULE 3129 COLUMBIA NATIONAL INC., Plaintiff in the above action, by its attorney, Joseph A. Goldbeck, Jr., Esquire, sets forth as of the date the praecipe for the writ of execution was filed the following information concerning the real property located at: 106-108 Gilbert Road, Shippensburg, PA 17257 1.Name and address of Owner(s) or Reputed Owner(s): ROBERT A. DECKER 125 Airport Road, Shippensburg, PA 17257 DIANNE L. DECKER 125 Airport Road, Shippensburg, PA 17257 2. Name and address of Defendant(s) in the judgment: ROBERT A. DECKER 125 Airport Road, Shippensburg, PA 17257 DIANNE L. DECKER 125 Airport Road, Shippensburg, PA 17257 3. Name and last known address of every judgment creditor whose judgment is a record lien on the property to be sold: PA DEPARTMENT OF PUBLIC WELFARE - Bureau of Child Support Enforcement Health and Welfare Bldg. - Room 432 P.O. Box 2675 Harrisburg, PA 17105-2675 DOMESTIC RELATIONS OF CUMBERLAND COUNTY PO Box 320, Carlisle, PA 17013 4. Name and address of the last recorded holder of every mortgage of record: GMAC Mortgage Corp. 8360 Old York Road Elkins Park, PA 19027 5. Name and address of every other person who has any record interest in or record lien on the property and whose interest may be affected by the sale: 6. Name and address of every other person of whom the plaintiff has knowledge who has any record interest in the property which 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. (attach separate sheet if more space is needed) I verify that the statements made in this affidavit are true and correct to the best of my personal knowledge or information and belief. I understand that false statements herein are made subject to the penalties of 18 Pa. C.S. Section 4904 relating to unsworn falsification to authorities. DATED: April 15, 2002 uvLL7TJ x MCCAFF TY & MCKEEVER By. ephM A. ldbeck, Jr., Esq. Atto y for P1 intiff GOLDBECK MCCAFFERTY BY: Joseph A. Goldbeck, Jr. Attorney I.D.#16132 Suite 500 - The Bourse Bldg. 111 S. Independence Mall East Philadelphia, PA 19106 215-627-1322 Attorney for Plaintiff COLUMBIA NATIONAL INC. 7142 Columbia Gateway Drive Columbia, MD 21046 Vs. Plaintiff ROBERT A. DECKER DIANNE L. DECKER (Mortgagors and Record Owners) 106-108 Gilbert Road Shippensburg,PA 17257 Defendants NOTICE OF SHERIFF'S SALE OF REAL PROPERTY TO: DECKER, ROBERT A. ROBERT A. DECKER 125 Airport Road Shippensburg,PA 17257 Your house at 106-108 Gilbert Road, Shippensburg, PA 17257 is scheduled to be sold at Sheriffs Sale on Wednesday, September 04, 2002, at 10:00 AM, in Commissioners Hearing Rm 2nd FL Courthouse to enforce the courtjudgment of $110,298.62 obtained by COLUMBIA NATIONAL INC. against you. NOTICE OF OWNER'S RIGHTS YOU MAY BE ABLE TO PREVENT THIS SHERIFF'S SALE & MCKEEVER IN THE COURT OF COMMON PLEAS of Cumberland County CIVIL ACTION - LAW ACTION OF MORTGAGE FORECLOSURE Term No. 00859-2002 THIS LAW FIRM IS A DEBT COLLECTOR AND WE ARE ATTEMPTING TO COLLECT A DEBT. THIS NOTICE IS SENT TO YOU IN AN ATTEMPT TO COLLECT A DEBT. ANY INFORMATION OBTAINED FROM YOU WILL BE USED FOR THAT PURPOSE. To prevent this Sheriffs Sale you must take immediate action: 1. The sale will be cancelled if you pay to Columbia National, Inc. the back payments, late charges, costs and reasonable attorney's fees due. To find out how much you must pay call: 215-627-1322 2. You may be able to stop the sale by filing a petition asking the Court to strike or open judgment, if the judgment was improperly entered. You may also ask the Court to postpone the sale for good cause. 3. You may also be able to stop the sale through other legal proceedings. You may need an attorney to assert your rights. The sooner you contact one, the more chance you will have of stopping the sale. (See notice below on how to obtain an attorney). YOU MAY STILL BE ABLE TO SAVE YOUR PROPERTY AND YOU HAVE OTHER RIGHTS EVEN IF THE SHERIFF'S SALE DOES NOT TAKE PLACE 1. If the Sheriffs Sale is not stopped, your property will be sold to the highest bidder. You may find out the price bid price by calling the Sheriff of 717-240-6390. 2. You may be able to petition the Court to set aside the sale if the bid price was grossly inadequate compared to the value of your property. 3. The sale will go through only if the buyer pays the Sheriff the full amount due in the sale. To find out if this has happened, you may call the Sheriff of 717-240-6390. 4. If the amount due from the Buyer is not paid to the Sheriff, you will remain the owner of the property as if the sale never happened. 5. You have a right to remain in the property until the full amount due is paid to the Sheriff and the Sheriff gives a deed to the buyer. At that time, the buyer may bring legal proceedings to evict you. 6. You may be entitled to a share of the money which was paid for your house. A schedule of distribution of the money bid for your house will be filed by the Sheriff thirty (30) days from the date of the Sheriffs Sale. This schedule will state who will be receiving that money. The money will be paid out in accordance with this schedule unless exceptions (reasons why the proposed distribution is wrong) are filed with the Sheriff within ten (10) days after the schedule of distribution is filed. 7. You may also have other rights and defenses, or ways of getting your house back, if you act immediately after the sale. YOU SHOULD TAKE THIS PAPER TO YOUR LAWYER AT ONCE. IF YOU DO NOT HAVE A LAWYER OR CANNOT AFFORD ONE, GO TO OR TELEPHONE THE OFFICE LISTED BELOW TO FIND OUT WHERE YOU CAN GET LEGAL HELP. CUMBERLAND COUNTY BAR ASSOCIATION 2 Liberty Avenue Carlisle, PA 17013 LEGAL SERVICES INC 8 Irvine Row Carlisle, PA 17013 GOLDBECK McCAFFERTY & McKEEVER BY: Joseph A. Goldbeck, Jr. Attomey I.D.# 16132 Suite 500 - The Bourse Bldg. 111 S. Independence Mall East Philadelphia, PA 19106 215-627-1322 Attorney for Plaintiff COLUMBIA NATIONAL INC. 7142 Columbia Gateway Drive Columbia, MD 21046 Plaintiff Vs. ROBERT A. DECKER DIANNE L. DECKER (Mortgagors and Record Owners) 106-108 Gilbert Road Shippensburg, PA 17257 Defendants IN THE COURT OF COMMON PLEAS of Cumberland County CIVIL ACTION - LAW ACTION OF MORTGAGE FORECLOSURE Term No. 00859-2002 THIS LAW FIRM IS A DEBT COLLECTOR AND WE ARE ATTEMPTING TO COLLECT A DEBT. THIS NOTICE IS SENT TO YOU IN AN ATTEMPT TO COLLECT A DEBT. ANY INFORMATION OBTAINED FROM YOU WILL BE USED FOR THAT PURPOSE. NOTICE OF SHERIFF'S SALE OF REAL PROPERTY TO: DECKER, DIANNE L. DIANNE L. DECKER 125 Airport Road Shippensburg, PA 17257 Your house at 106-108 Gilbert Road, Shippensburg, PA 17257 is scheduled to be sold at Sheriffs Sale on Wednesday, September 04, 2002, at 10:00 AM, in Commissioners Hearing Rm 2nd FL Courthouse to enforce the courtjudgment of $110,298.62 obtained by COLUMBIA NATIONAL INC. against you. NOTICE OF OWNER'S RIGHTS YOU MAY BE ABLE TO PREVENT THIS SHERIFF'S SALE To prevent this Sheriffs Sale you must take immediate action: 1. The sale will be cancelled if you pay to Columbia National, Inc. the back payments, late charges, costs and reasonable attorney's fees due. To find out how much you must pay call: 215-627-1322 2. You may be able to stop the sale by filing a petition asking the Court to strike or open judgment, if the judgment was improperly entered. You may also ask the Court to postpone the sale for good cause. 3. You may also be able to stop the sale through other legal proceedings. You may need an attorney to assert your rights. The sooner you contact one, the more chance you will have of stopping the sale. (See notice below on how to obtain an attorney). YOU MAY STILL BE ABLE TO SAVE YOUR PROPERTY AND YOU HAVE OTHER RIGHTS EVEN IF THE SHERIFF'S SALE DOES NOT TAKE PLACE 1. If the Sheriffs Sale is not stopped, your property will be sold to the highest bidder. You may find out the price bid price by calling the Sheriff of 717-240-6390. 2. You may be able to petition the Court to set aside the sale if the bid price was grossly inadequate compared to the value of your property. 3. The sale will go through only if the buyer pays the Sheriff the full amount due in the sale. To find out if this has happened, you may call the Sheriff of 717-240-6390. 4. If the amount due from the Buyer is not paid to the Sheriff, you will remain the owner of the property as if the sale never happened. 5. You have a right to remain in the property until the full amount due is paid to the Sheriff and the Sheriff gives a deed to the buyer. At that time, the buyer may bring legal proceedings to evict you. 6. You may be entitled to a share of the money which was paid for your house. A schedule of distribution of the money bid for your house will be filed by the Sheriff thirty (30) days from the date of the Sheriffs Sale. This schedule will state who will be receiving that money. The money will be paid out in accordance with this schedule unless exceptions (reasons why the proposed distribution is wrong) are filed with the Sheriff within ten (10) days after the schedule of distribution is filed. 7. You may also have other rights and defenses, or ways of getting your house back, if you act immediately after the sale. YOU SHOULD TAKE THIS PAPER TO YOUR LAWYER AT ONCE. IF YOU DO NOT HAVE A LAWYER OR CANNOT AFFORD ONE, GO TO OR TELEPHONE THE OFFICE LISTED BELOW TO FIND OUT WHERE YOU CAN GET LEGAL HELP. CUMBERLAND COUNTY BAR ASSOCIATION 2 Liberty Avenue Carlisle, PA 17013 LEGAL SERVICES INC 8 Irvine Row Carlisle, PA 17013 All the following described real estate, together with the improvements erected thereon, lying and being situate in Southampton Township, Cumberland County, Pennsylvania, more particularly described as follows: Tract No. 1: Beginning at a railroad spike in Legislative Route 21006 at the Southeastern corner of Lot No. 1 on the hereinafter mentioned plan of lots; thence along the eastern edge of Lot No. 1, North seventeen (17) degrees nine (9) minutes six (6) seconds West, a distance of ninety-three (93) feet to an iron pin; thence along the northern edge of Lot No. 1, South eighty-nine (89) degrees sixteen (16) minutes twenty-three (23) seconds West, a distance of one-hundred twenty-seven and forty-two hundredths (127.42) feet to an iron pin; thence along the same, North eighty (80) degrees zero (00) minutes fifty-five (55) seconds West, a distance of ninety (90) feet to an iron pin; thence along lands now or formerly of Lynn H. Delancy, North five (5) degrees twenty-eight (28) minutes twenty-seven (27) seconds East, a distance of two hundred ninety-eight and ninety- four hundredths (298.94) feet to an iron pin; thence along the southern edge of Lot No. 5, South eighty-four (84) degrees thirty-one (31) minutes thirty-three (33) seconds East, a distance of four hundred eighteen and seventy-eight hundredths (418.78) feet to an iron pin; thence along the southwestern portion of Lot No. 5, South three (3) degrees fifty-five (55) minutes twelve (12) seconds West, a distance of three hundred five and ninety-two (305.92) feet to a railroad spike in Legislative Route 21006; thence along Legislative Route 21006, South seventy-three (73) degrees fifteen (15) minutes fifty-five (55) seconds West, a distance of seventy-seven and twenty-seven hundredths (77.27) feet to a railroad spike; thence along the same, South seventy-two (72) degrees fifty (50) minutes fifty- four (54) seconds West, a distance of one hundred eleven and ninety-eight hundredths (111.98) feet to the place of beginning. Containing 3.1114 acres, and being Lot No. 4 on a plan of lots recorded in Plan Book 43, Page 21. Subject to restrictions recorded in Cumberland County Plan Book 43, Page 21. Tract No. 2: All the following described real estate, together with the improvements erected thereon, lying and being situate in Southampton Township, Cumberland County, Pennsylvania, more particularly described as follows: Beginning at a railroad spike in the centerline of Legislative Route 21006, corner of lands now or formerly of John C. Martin; thence by Martin lands, North seventeen (17) degrees nine (9) minutes six (6) seconds West, ninety-three (93) feet to an iron pin; thence by other lands now or formerly of John C. Martin, North eighty-nine (89) degrees sixteen (16) minutes twenty-three (23) seconds West, a distance of one hundred twenty-seven and forty-two hundredths (127.42) feet to an iron pin; thence continuing by other lands of John C. Martin, North eighty (80) degrees zero (00) minutes fifty-five (55) seconds East, a distance of ninety (90) feet to an iron pin at line of lands now or formerly of Lynn H. Delancy; thence by said minutes twenty-seven (27) seconds West, a distance of one hundred eighty-two and eighty hundredths (182.80) feet to a railroad spike in the centerline of Legislative Route 21006; thence by the centerline of Legislative Route 21006, North seventy-three (73) degrees thirteen (13) minutes thirteen (13) seconds East a distance of two hundred seven and sixty-four hundredths (207.64) feet to a railroad spike; thence by the centerline of Legislative Route 21006 North seventy-two (72) degrees fifty (50) minutes fifty-four (54) seconds East, a distance of sixty- five (65) feet to a railroad spike, the point and place of beginning. Containing 0.7216 acres, less 0.1535 acres reserved for improvements of right-of-way of Legislative Route 21006. Being Lot No. 1 on the subdivision plan for John C. Martin dated November 14, 1980, prepared by Carl D. Bert, R.B. Tax Parcel #391301040490 & 39130104949D Being known as 106 - 108 Gilbert Road, Shippensburg, PA 17257. PROOF OF PUBLICATION OF NOTICE IN CUMBERLAND LAW JOURNAL (Under Act No. 587, approved May 16, 1929), P. L.1784 R ger M. Morgenthal, Editor SWORN TO AND SUBSCRIBED before me this 9 day of AUGUST. 2002 6V1X LOIS a SNYDE Y Pd& My CMaJaMon EOM Momh 5, STATE OF PENNSYLVANIA : COUNTY OF CUMBERLAND : ss. Roger M. Morgenthal, Esquire, Editor of the Cumberland Law Journal, of the County and State aforesaid, being duly sworn, according to law, deposes and says that the Cumberland Law Journal, a legal periodical published in the Borough of Carlisle in the County and State aforesaid, was established January 2, 1952, and designated by the local courts as the official legal periodical for the publication of all legal notices, and has, since January 2, 1952, been regularly issued weekly in the said County, and that the printed notice or publication attached hereto is exactly the same as was printed in the regular editions and issues of the said Cumberland Law Journal on the following dates, viz: JULY 26, AUGUST 2, 9, 2002 Affiant further deposes that he is authorized to verify this statement by the Cumberland Law Journal, a legal periodical of general circulation, and that he is not interested in the subject matter of the aforesaid notice or advertisement, and that all allegations in the foregoing statements as to time, place and character of publication are true. REAL ESTATE SALE NO. 1 Writ No. 2002-859 Civil Columbia National Inc. VS. Robert A. Decker and Dianne L. Decker Atty.: Joseph Goldbeck, Jr. All the following described real estate, together with the improve- ments erected thereon; lying and being situate in Southampton Town- ship. Cumberland County. Pennsyl- vania, more particularly described as follows: 'Butt No. 1: Beginning at a railroad spike in Legislative Route 21006 at the South- eastern corner of Lot No. 1 on the hereinafter mentioned plan of lots; thence along the eastern edge of Lot No. 1, North seventeen (17) degrees nine (9) minutes six (6) seconds West. a distance of ninety-three (93) feet to an iron pin; thence along the northern edge of Lot No. 1, South eighty-nine (89) degrees sixteen (16) minutes twenty-three (23) seconds West, a distance of one-hundred twenty-seven and forty-two hun- dredths (127.42) feet to an iron pin; thence along the same, North eighty (80) degrees zero (00) minutes fifty- five (55) seconds West, a distance of ninety (90) feet to an iron pin; thence along lands now or formerly of Lynn H. Delancy, North five (5) degrees twenty-eight (28) minutes twenty-seven (27) seconds East, a distance of two hundred ninety-eight and ninety-four hundredths (298.94) feet to an iron pin; thence along the southern edge of Lot No. 5, South eighty-four (84) degrees thirty-one (31) minutes thirty-three (33) sec- onds East, a distance of four hun- dred eighteen and seventy-eight hundredths (418.78) feet to an iron pin; thence along the southwestern portion of Lot No. 5, South three (3) degrees fifty-five (55) minutes twelve (12) seconds West, a distance of three hundred five and ninety-two (305- .92) feet to a railroad spike in Leg- islative Route 21006; thence along Legislative Route 21006, South seventy-three (73) degrees fifteen (15) minutes fifty-five (55) seconds West, a distance of seventy-seven and twenty-seven hundredths (77.27) feet to a railroad spike; thence along the same, South seventy-two (72) degrees fifty (50) minutes fifty-four (54) seconds West, a distance of one hundred eleven and ninety-eight hundredths (111.98) feet to the place of beginning. Containing 3.1114 acres, and being Lot No. 4 on a plan of lots recorded in Plan Book 43, Page 21. Subject to restrictions recorded in Cumberland County Plan Book 43, Page 21. Tract No. 2: All the following described real estate, together with the improve- ments erected thereon, lying and being situate in Southampton Town- ship, Cumberland County, Pennsyl- vania, more particularly described as follows: Beginning at a railroad spike in the centerline of Legislative Route 21006, corner of lands now or for- merly of John C. Martin; thence by Martin lands, North seventeen (17) degrees nine (9) minutes six (6) sec- onds West, ninety-three (93) feet to an iron pin; thence by other lands now or formerly of John C. Martin, North eighty-nine (89) degrees six- teen (16) minutes twenty-three (23) seconds West, a distance of one hundred twenty-seven and forty-two hundredths (127.42) feet to an iron pin; thence continuing by other lands of John C. Martin, North eighty (80) degrees zero (00) minutes fifty-five (55) seconds East, a dis- tance of ninety (90) feet to an iron pin at line of lands now or formerly of Lynn H. Delancy; thence by said minutes twenty-seven (27) seconds West, a distance of one hundred eighty-two and eighty hundredths (182.80) feet to a railroad spike in the centerline of Legislative Route 21006; thence by the centerline of Legislative Route 21006, North seventy-three (73) degrees thirteen (13) minutes thirteen (13) seconds East a distance of two hundred seven and sixty-four hundredths (207.64) feet to a railroad spike; thence by the centerline of Legisla- tive Route 21006 North seventy-two (72) degrees fifty (50) minutes fifty-four (54) seconds East, a dis- tance of sixty-five (65) feet to a rail- road spike, the point and place of beginning. Containing 0.7216 acres, less 0.1535 acres reserved for im- provements of right-of-way of Leg- islative Route 21006. Being Lot No. 1 on the subdivi- sion plan for John C. Martin dated November 14, 1980, prepared by Carl D. Bert, R.B. Tax Parcel #39130104049C & 39130104949D. Being known as 106-108 Gilbert Road, Shippensburg, PA 17257. THE PATRIOT NEWS THE SUNDAY PATRIOT NEWS Proof of Publication Under Act No. 587, Approved May 16, 1929 Commonwealth of Pennsylvania, County of Dauphin) ss Frank J. Epler being duly sworn according to law, deposes and says: That he is the Controller of The Patriot News Co., a corporation organized and existing under the laws of the Commonwealth of Pennsylvania, with its principal office and place of business at 812 to 818 Market Street, in the City of Harrisburg, County of Dauphin, State of Pennsylvania, owner and publisher of The Patriot-News and The Sunday Patriot-News newspapers of general circulation, printed and published at 812 to 818 Market Street, in the City, County and State aforesaid; that The Patriot-News and The Sunday Patriot-News were established March 4th, 1854, and September 18th, 1949, respectively, and all have been continuously published ever since; That the printed notice or publication which is securely attached hereto is exactly as printed and published in their regular daily and/or Sunday/ Metro editions which appeared on the 23rd and 30th day(s) of July and the 6th day(s) of August 2002. That neither he nor said Company is interested in the subject matter of said printed notice or advertising, and that all of the allegations of this statement as to the time, place and character of publication are true; and That he has personal knowledge of the facts aforesaid and is duly authorized and empowered to verify this statement on behalf of The Patriot-News Co. aforesaid by virtue and pursuant to a resolution unanimously passed and adopted severally by the stockholders and board of directors of the said Company and subsequently duly recorded in the office for the Recording of Deeds in and for said County of Dauphin in Miscellaneous Book "M", Volume 14, Page 317. PUBLICATION t' -:........?L !. >< - ................................................................ COPY Sworn to and subscribed before me this 14th day o Augttst?2002 A.D. SALE # 1 REAL ESTATE SALE No. 1 Notarial Seal ? Writ No. 2002-859 Terry L. Russell, Notary Public Civil Term City of Harrisburg, Dauphin County C Columbia National Inc. My Commission Expires June 6, 2006 NOT RY PUBLIC vs Robert A. Decker and Member, Pennsylvania Association Of Notari y commission expires June 6, 2006 Dianne L. Decker Atty: Joseph Goldbeck, Jr. CUMBERLAND COUNTY SHERIFFS OFFICE DESCRIPTION CUMBERLAND COUNTY COURTHOUSE ALL THE following described real estate, together with the improve nents erected thereon, CARLISLE, PA. 17013 lying and being situate in Southampton Township, Cumberland County, Pennsylvania, more particularly described as follows: Statement of Advertising Costs Tract No. 1: Beginning at a railroad spike in TO THE PATRIOT-NEWS Route 21006 at the Southeastern CO., Dr. comer of Lot No. I on the hereinafter mentioned For publishing the notice or plan of lots; thence along the eastern edge of Lot publication attached No. 1, North seventeen (17) degrees nine (9) hereto on the above stated dates minutes six (6) seconds West, a distance of Probating same $ 470.40 ninety-three (93) feet to an iron pin, thence along Total Notary Fee (s) $ 1 1 5 the northern edge of Lot No. 1, South eighty-nine (89) degrees sixteen (16) minutes twenty-three $ 472.1 5 (23) seconds West, a distance of one-hundred twenty-seven and forty-two hundredths (127.42) Publisher's Receipt for Advertising Cost The Patriot News Co., publisher of The Patriot-News and The Sunday Patriot-News, newspapers of general circulation, hereby acknowledge receipt of the aforesaid notice and publication costs and certifies that the same have been duly paid. By feet to an iron pin; thence along the same, North eighty (80) degrees zero (00) minutes fifty-five (55) seconds West, a distance of ninety (90) feet to an iron pin; thence along lands now or formerly of Lynn H. Delancy, North five (5) degrees twenty-eight (28) minutes twenty-seven (27) seconds East, a distance of two hundred ninety-eight and ninety-four hundredths (298.94) feet to an iron pin; thence along the southern edge of Lot No. 5, South eighty-four (84) degrees thirty-one (31) minutes thirty-three (33) seconds East, a distance of fwar hundred eighteen and seventy-eight hundredths (418.78) feet to an iron pin; thence along the southwestern portion of Lot No. 5, South three (3)'drgrees fifty-five (55) minutes twelve (12) seconds West, a distance of three hundred five and ninety-two (305.92) feet to a railroad spike in Legislative Route 25006; thence along Legislative Route 21006, seventy-three (73) degrees fifteen (15) minutes fifty-five (55) seconds West, a distance of seventy-seven and twenty-seven hundredths (77.27) feet to a railroad spike; thence along the same, South seventy-two (72) degrees fifth (50) minutes fifty-four (54) seconds West, a distance of one hundred eleven and ninety-eight hundredths (111-98) feet to the place of beginning. Containing 3.1114 acres, and being Lot No. 4 on a plan of lots recorded in Plan Book 43, Page 21. Subject to restrictions recorded in Cumberland County Plan Book 43 v Page 21. Tract No. 2: All the following described real estate, together with the improvements erected thereon, lying and being r -uate in Southampton Township, Cumberland unty, Pennsylvapia, more particularly descri s follows: Beginning at a ratiroad stC in the centerline of Legislative Route 21005, comer of lands now or formerly of John C. Martin; thence by Martin lands, North seventeen (17) degrees nine (9) minutes six (6) seconds West, ninety-three (93) feet to an iron pin; thence by other lands now or formerly of John C. Martin, North eighty-nine (89) degrees sixteen (16) minutes twenty-three (23) seconds West, a distance of one hundred twenty-seven and forty-two hundredths (127.42) feet to an iron pin; thence continuing by other lands of John C. Martin, North eighty (80) degrees zero (00) minutes fifty-five (55) seconds East, a distance of ninety (90) feet to an iron pin at line of lands now or formerly of Lynn H. Delancy; thence by said minutes twenty-seven (27) seconds West, a distance of one hundred eighty-two and eighty hundredths (182.80) feet to a railroad spike in the centerline of Legislative Route 21006; thence by the centerline of Legislative Route 21006, North seventy-three (73) degrees thirteen (13) minutes thirteen (13) seconds East a distance of two hundred seven and sixty-four hundredths (207.64) feet to a railroad spike; thence by the centerline of Legislative Route 21006 North seventy-two (72) degrees fifty (50) minutes fifty-four (54) seconds East, a distance of sixty-five (65) feet to a railroad spike, the point and place of beginning. Containing 0.7216 acres, less 0.1535 acres reserved for improvements of right-of-way of Legislative Route 21006. Being Lot No. 1 on the subdivision plan for John C. Martin dated November 14, 1980, prepared by Carl D. Bert, R.B. Tax Parcel #39130104049C & 39130104949D. Being known as 106-108 Gilbert Road, Shippensburg,PA 17257.