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HomeMy WebLinkAbout05-2507 PHELAN IIALLINAN & SCHMIEG. LLP LAWRENCE T. PHELAN, ESO., Id. No. 32227 FRANCIS S. HALLINAN, ESO., [d. No 62695 ONE PENN CENTER PLAZA SUITE 1400 PHILADELPHIA. P A 19103 (215) 563-7000 PHil MORTGAGE CORPORATION, F/K/A CENDANT MORTGAGE CORPORATION, F/K/A PHH MORTGAGE SERVICES CORPORATION 6000 ATRIUM WAY MT. LAUREL, NJ 08054 ATTORNEY FOR PLAINTIFF Plaintiff COURT OF COMMON PLEAS CIVIL DIVISION TERM NO. d()(/; - '2507 e.c; I v. CUMBERLAND COUNTY DOUGLAS E. WILHELM, JR. LISA H. WILHELM NKI A L WILHELM NKIA WILHELM LISA HANLON NKI A LISA M HANLON NK/A LISA HANLON WILHELM 4704 COURTLAND STREET CAMP HILL, PA 17011 Defendants CIVIL ACTION - LAW COMPLAINT IN MORTGAGE FORECLOSURE NOTICE You have been sued in court. If you wish to defend against the claims set forth in the following pages, you must take action within twenty (20) days after this complaint and notice are served, by entering a written appearance personally or by attorney and filing in writing with the court your defenses or objections to the claims set forth against you. You are warned that if you fail to do so the case may proceed without you and a judgment may be entered against you by the court without further notice for any money claimed in the complaint or for any other claim or reliefrequested by the plaintiff You may lose money or property or other rights important to you. YOU SHOULD TAKE THIS PAPER TO YOUR LAWYER AT ONCE. IF YOU DO NOT HAVE A LAWYER, GO TO OR TELEPHONE THE OFFICE SET FORTH BELOW. THIS OFFICE CAN PROVIDE YOU WITH INFORMATION ABOUT HIRING A LA WYER IF YOU CANNOT AFFORD TO HIRE A LAWYER, THIS OFFICE MAY BE ABLE TO PROVIDE YOU WITH INFORMA nON ABOUT AGENCIES THAT MAY OFFER LEGAL SERVICES TO ELIGIBLE PERSONS AT A REDUCED FEE OR NO FEE. Lawyer Referral Service Cumberland County Bar Association 32 South Bedford Street Carlisle, P A 17013 (800)990-9108 Filc#: 116424 File #: 116424 IF THIS IS THE FIRST NOTICE THAT VOl! HAVE RECEIVED FROM THIS OFFICE, BE ADVISED THAT: PURSUANT TO THE FAIR DEBT COLLECTION PRACTICES ACT, IS U.S.c. ~ 1692 et seq. (1977), DEFENDANT(S) MAY DISPUTE THE VALIDITY OF THE DEBT OR ANY PORTION THEREOF. IF DEFENDANT(S) DO SO IN WRITING WITHIN THIRTY (30) DAYS OF RECEIPT OF THIS PLEADING, COUNSEL FOR PLAINTIFF WILL OBTAIN AND PROVIDE DEFENDANT(S) WITH WRITTEN VERIFICATION THEREOF; OTHERWISE, THE DEBT WILL BE ASSUMED TO BE VALID. LIKEWISE, IF REQUESTED WITHIN THIRTY (30) DA YS OF RECEIPT OF THIS PLEADING, COUNSEL FOR PLAINTIFF WILL SEND DEFENDANT(S) THE NAME AND ADDRESS OF THE ORIGINAL CREDITOR, IF DIFFERENT FROM ABOVE. THE LAW DOES NOT REQUIRE US TO WAIT UNTIL THE END OF THE THIRTY (30) DAY PERIOD FOLLOWING FIRST CONTACT WITH YOU BEFORE SUING YOU TO COLLECT THIS DEBT. EVEN THOUGH THE LAW PROVIDES THAT YOUR ANSWER TO THIS COMPLAINT IS TO BE FILED IN THIS ACTION WITHIN TWENTY (20) DAYS, YOU MAY OBTAIN AN EXTENSION OF THAT TIME. FURTHERMORE, NO REQUEST WILL BE MADE TO THE COURT FOR A JUDGMENT UNTIL THE EXPIRATION OF THIRTY (30) DAYS AFTER YOU HAVE RECEIVED THIS COMPLAINT. HOWEVER, IF YOU REQUEST PROOF OF THE DEBT OR THE NAME AND ADDRESS OF THE ORIGINAL CREDITOR WITHIN THE THIRTY (30) DAY PERIOD THAT BEGINS UPON YOUR RECEIPT OF THIS COMPLAINT, THE LAW REQUIRES US TO CEASE OUR EFFORTS (THROUGH LITIGATION OR OTHERWISE) TO COLLECT THE DEBT UNTIL WE MAIL THE REQUESTED INFORMATION TO YOU. YOU SHOULD CONSULT AN ATTORNEY FOR ADVICE CONCERNING YOUR RIGHTS AND OBLIGATIONS IN THIS SUIT. IF YOU HAVE FILED BANKRUPTCY AND RECEIVED A DISCHARGE, THIS IS NOT AN ATTEMPT TO COLLECT A DEBT. IT IS AN ACTION TO ENFORCE A LIEN ON REAL ESTATE. - 1. Plaintiff is PHil MORTGAGE CORPORATION. F/KJA CENDANT MORTGAGE CORPORATION, F/KJA PHil MORTGAGE SERVICES CORPORATION 6000 ATRIUM WAY MT. LAUREL. NJ 08054 2. The name(s) and last known address(es) of the Defendant(s) are: DOUGLAS E. WILHELM, JR. LISA H, WILHELM A/K/A L WILHELM AIKJ A WILHELM LISA HANLON NK/A LISA M HANLON NK/A LISA HANLON WILIIELM 4704 COURTLAND STREET CAMPHILL,PA 1701] who is/are the mortgagor(s) and real owner(s) of the property hereinafter described. 3. On 12/30/I997 mortgagor(s) made, executed and delivered a mortgage upon the premises hereinafter described to PLAINTIFF which mortgage is recorded in the Office of the Recorder of CUMBERLAND County, in Mortgage Book: 1424. Page: 917. 4. The premises subject to said mortgage is described as attached. 5. The mortgage is in default because monthly payments of principal and interest upon said mortgage due 01101/2005 and each month thereafter are due and unpaid, and by the terms of said mortgage, upon failure of mortgagor to make such payments after a date specified by written notice sent to Mortgagor. the entire principal balance and all interest due thereon arc collectible forthwith. File# 116424 6. Thc following amounts arc duc on the mortgage: Principal Balance Interest 12/0 I /2004 through 05/1 3/2005 (Per Diem $20.20) Attorncy's Fees Cumulative Late Charges 12/30/1997 to 05/13/2005 Cost of Suit and Title Search Subtotal $103,868. I 4 3,312.80 1,250.00 121.08 $ 550.00 $ 109,102.02 Escrow Credit Deficit Subtotal 0.00 36.07 $ 36.07 TOTAL $ 109.138.09 7. 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 Sheriffs Sale. If the Mortgage is reinstated prior to the Sale, reasonable attorney's fees will be charged. 8. The mortgage premises are vacant and abandoned. WHEREFORE, PLAINTIFF demands an in rem Judgment against the Defendant(s) in the sum of $ 109,138.09. together with interest from 05/13/2005 at the rate of $20.20 per dicm to thc date of Judgment. and other costs and charges collectible under the mortgage and for the foreclosure and sale of the mortgaged property. PHELAN HALLINAN & SCHMIEG. LIJ # 17 2~ ('}S~. By: /s/Fr1nc~inan LAWRENCE T PHELAN. ESQUIRE FRANCIS S. HALLINAN, ESQUIRE Attorneys for Plaintiff Filc#: 116424 LEGAL DESCRIPTION ALL that certain tract in the Township of Hampden, County of Cumberland, Commonwealth of Pennsylvania, more particularly bounded and described as follows. to wit: BEGINNING at a point on the East side of Courtland Street. which point is 212 feet Westwardly and Southwardly trom the Southwesterly comer of Courtland Street and Hampdcn A venue, said point being also at the division lines of Lots Nos. 160 and 161; thence South 73 degrees 12 minutes East along said division line eighty five and thirty-four hundredths (85.34) feet to a point at the division lines of Lots Nos. 158 and 161; thence South 20 de6'fceS 0 I minute East along said division lines sixty-four and twelve hundredths (64.12) feet to a point at the division lines of Lots Nos 161 and 162; thence South 69 degrees 55 minutes West along said division line eighty-eight and nine hundredths (88.09) fcet to a point on the Eastern side of Courtland Street; thence North 20 degrees 39 minutes West along the aforementioned Courtland Street fifty-one and thirty-eight hundredths (51.38) feet to a point; thence continuing along Courtland Street in a arc to the right with a radius of one hundred five and seventy-eighty hundredths (105.78) feet the arc distance of sixty-seven and thirty-nine hundredths (67.39) feet to a point the PLACE OF BEGINNING. IT BEING Lot No. 161 on General Plan of Section 2 and 3 Clearview Farms, which plan is recorded in Plan Book 9, Page 6. Cumberland County. HAVING thereon erected a split-level brick and frame dwelling house know as 4704 Courtland Street. BEING part of the same tract of ground which Nelson Improvement and Development Corporation by Deed dated the 15th day of August 1960, and recorded in and for the County of Cumberland in Deed Book 2, Volume 19. Page 40, 6'fanted and conveyed unto Robert H. Snyder and Patricia J. Snyder, his wife of Hampden Township, who are both now deceased. AND the Grantors will warrant specially the property hereby conveyed. PREMISES: 4704 COURTLAND STREET filc#: 1]6424 VERIFICATION FRANCIS S. HALLINAN, ESQUIRE hereby states that he is attorney for Plaintiff in this matter, that Plaintiff is outside the jurisdiction of the court and or the verification could not be obtained within the time allowed for the filing of the pleading, that he is authorized to make this verification pursuant to Pa. R. C. P. 1024 ( c ), and that the statements made in the foregoing Civil Action in Mortgage Foreclosure are based upon information supplied by Plaintiff and are true and correct to the best of its knowledge, information and belief. Furthermore, it is counsel's intention to substitute a verification from Plaintiff as soon as it is received by counsel. The undersigned understands that this statement is made subject to the penalties of 18 Pa. C. S. Sec. 4904 relating to unsworn falsifications to authorities. ~}kL Francis S. Hallinan, Esquire Attorney for Plaintiff DATE:~ ~ -- r.- -+:. c c;; ~ v,... ~ ",,\e ~ '" -z:- ------.", r:, ~ ~ "'-~ ~ -" ~~ ~ ':-:::, (;S> ':;.-; C) -, -n ;;:_,1 ::::} fl"" ~ Cr'\ \'.,,) C.-' :.0 .-<. cr. SHERIFF'S RETURN - NOT FOUND CASE NO: 2005-02507 P COMMONTWEALTH OF PENNSYLVANIA COUNTY OF CUMBERLAND PHH MORTGAGE CORPORATION VS WILHELM DOUGLAS E JR ET AL R. Thomas Kline ,Sheriff or Deputy Sheriff, who being duly sworn according to law, says, that he made a diligent search and inquiry for the within named DEFENDANT WILHELM DOUGLAS E JR but was unable to locate Him in his bailiwick. He therefore returns the COMPLAINT - MORT FORE , NOT FOUND , as to the within named DEFENDANT , WILHELM DOUGLAS E JR 4704 COURTLAND STREET CAMP HILL, PA 17011 4704 COURTLAND STREET IS VACANT. Sheriff's Costs: Docketing Service Not Found Surcharge 18.00 11.10 5.00 10.00 .00 44.10 So answe~. /__--~ .--;;;;~ "</_. .',". ,,/,:,-:,_::-::::~~,_...~ __~;;--~~__?V'-: .4 , R. Th~rr;as -Kline Sheriff of Cumberland County PHELAN HALLINAN SCHMIEG 06/13/2005 Sworn and subscribed to before me /} this ,Nul-. day of ( L" ) olutJ/-;' A . D . Cb Q ~d#", ~. Prdt onotary ) SHERIFF'S RETURN - NOT FOUND CASE NO: 2005-02507 P COMMONTWEALTH OF PENNSYLVANIA COUNTY OF CUMBERLAND PHH MORTGAGE CORPORATION VS WILHELM DOUGLAS E JR ET AL R. Thomas Kline ,Sheriff or Deputy Sheriff, who being duly sworn according to law, says, that he made a diligent search and inquiry for the within named DEFENDANT WILHELM LISA H AKA L WILHELM AKA WILHELM LISA HANLON AKA but was unable to locate Her in his bailiwick. He therefore returns the COMPLAINT - MORT FORE , NOT FOUND , as to the within named DEFENDANT , WILHELM LISA H AKA L WILHELM AKA WILHELM LISA HANLON AKA 4704 COURTLAND STREET CAMP HILL, PA 17011 4704 COURTLAND STREET IS VACANT. Sheriff's Costs: Docketing Service Not Found Surcharge 6.00 .00 5.00 10.00 .00 21.00 So ans\'J,:E92-~ .~__-_.--------- ~ .::;;;-,.::.----~.;...~-- / R. Thomas Kline Sheriff of Cumberland County PHELAN HALLINAN SCHMIEG 06/13/2005 Sworn and subscribed to before me this .<3.MA. day of ql,.' :2tJ1J~ A.D. (),,,,- 0 pro'tJt~notary n,A;f,<./:~ SHERIFF'S RETURN - REGULAR CASE NO: 2005-02507 P COMMONWEALTH OF PENNSYLVANIA: COUNTY OF CUMBERLAND PHH MORTGAGE CORPORATION VS WILHELM DOUGLAS E JR ET AL 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 WILHELM DOUGLAS E JR the DEFENDANT , at 1811:00 HOURS, on the lOth day of June , 2005 at 4709 BRIAN ROAD MECHANICSBURG, PA 17055 by handing to DOUGLAS WILHELM JR a true and attested copy of COMPLAINT - MORT FORE together with and at the same time directing His attention to the contents thereof. sheriff's Costs: Docketing Service Affidavit Surcharge So Answers: 6.00 8.88 .00 10.00 .00 24.88 r~-e'<~ R. Thomas Kline Sworn and Subscribed to before 06/13/2005 PHELAN HALLINAN SCHMIEG By~~4e Deputy Sherl me this :2 3 A-d day of ().:,~, r2MJ) A.D. C 1 ';fc J . () Ivu f€t'~ 414< I~ I P othonotary J "f"F SHERIFF'S RETURN - REGULAR CASE NO: 2005-02507 P COMMONWEALTH OF PENNSYLVANIA: COUNTY OF CUMBERLAND PHH MORTGAGE CORPORATION VS WILHELM DOUGLAS E JR ET AL RONALD HOOVER Sheriff or Deputy Sheriff of Cumberland County,Pennsylvania, who being duly sworn according to law, says, the within COMPLAINT - MORT FORE was served upon WILHELM LISA H AKA L WILHELM AKA WILHELM LISA HANLON AKA the DEFENDANT , at 2032:00 HOURS, on the 1st day of June , 2005 at l02 E KELLER STREET MECHANICSBURG, PA l7055 by handing to LISA WILHELM a true and attested copy of COMPLAINT - MORT FORE together with and at the same time directing Her attention to the contents thereof. Sheriff's Costs: Docketing Service Affidavit Surcharge So Answers: r. ~~ r~~~1'~~ 6.00 7.40 .00 lO.OO .00 23.40 R. Thomas Kline 06/13/2005 PHELAN HALLINAN SCHMIEG Sworn and Subscribed to before By: ~c-~ Deputy Sheriff me this ~3~~ day of (} 4" d..vv,..( A. D . ( I'-Y;L () {wJ}LI +11 rothonotary , PHELAN HALLINAN & SCHMIEG, L.L.P. .. By: DANIEL G. SCHMIEG Identification No. 62205 Attorney for Plaintiff ONE PENN CENTER AT SUBURBAN STATION 1617 JOHN F. KENNEDY BLVD., SUITE 1400 PHILADELPHIA, PA 19103-1814 (215) 563-7000 PHH MORTGAGE CORPORATION F/KJA CENDANT MORTGAGE CORPORATION, F/KJA PHH MORTGAGE SERVICES CORPORATION 6000 ATRIUM WAY MT. LAUREL, NJ 08054 CUMBERLAND COUNTY COURT OF COMMON PLEAS CIVIL DIVISION Plaintiff, NO. 05-2507 v. DOUGLAS E. WILHELM, JR. LISA H. WILHELM A/KJ A L. WILHELM A/KJA WILHELM LISA HANLON AlKJA LISA M. HANLON AlKJ A LISA HANLON WILHELM Defendant(s). PRAECIPE FOR IN REM JUDGMENT FOR FAILURE TO ANSWER AND ASSESSMENT OF DAMAGES TO THE PROTHONOTARY: Kindly enter an in remjudgrnent in favor of the Plaintiff and against DOUGLAS E. WILHELM. JR. and LISA H. WILHELM AlK/ A L. WILHELM AlK/ A WILHELM LISA HANLON AlK/A LISA M. HANLON AlK/A LISA HANLON WILHELM, Defendant(s) for failure to file an Answer to Plaintiffs Complaint within 20 days from service thereof and for Foreclosure and Sale of the mortgaged premises, and assess Plaintiffs damages as follows: As set forth in Complaint Interest from 5/14/05 to 9/2/05 TOTAL $109,138.09 $2,262.40 $111,400.49 I hereby certify that (1) the addresses of the Plaintiff and Defendant(s) are as shown above, and (2) that notice has been given in accordance with Rule 237.1, copy attached. (-- '" . ~ 6 \ . l0 ,,,,,,Qk ~ ~(l\Y\A\-e ( ..J --BANiEL G. SCH lEG, ESQUIRE Attorney for Plaintiff DAMAGES ARE HEREBY ASSESSED AS INDlCAT~ ',' ~.. DATE: S'~.;y-.J..! :lC6S ~ ' ~ ( PR PRO THY ... (Rule of Civil Procedure No. 236) - Revised IN THE COURT OF COMMON PLEAS OF CUMBERLAND COUNTY, PENNSYL VANIA CIVIL ACTION - LAW PHH MORTGAGE CORPORATION F/K/A CENDANT MORTGAGE CORPORATION, F/K/A PHH MORTGAGE SERVICES CORPORATION 6000 ATRIUM WAY Plaintiff, v. DOUGLAS E. WILHELM, JR. LISA H. WILHELM AJKJA L. WILHELM AlK/A WILHELM LISA HANLON AlK/ A LISA M. HANLON AJKJA LISA HANLON WILHELM Defendant(s). CUMBERLAND COUNTY COURT OF COMMON PLEAS CIVIL DIVISION NO. 05-2507 Notice is given that a Judgment in the above-captioned matter has been entered against you on Slp-+ '-= 200~ If you have any questions concerning this matter, please contact: ~c& Q. <1:Ylf\\Aftu!.;- DANIEL G. SCHMIEG, ESQU~ Attorney for Plaintiff ONE PENN CENTER AT SUBURBAN STATION 1617 JOHN F. KENNEDY BLVD., SUITE 1400 PHILADELPHIA, PA 19103-1814 (215) 563-7000 **THIS FIRM IS A DEBT COLLECTOR ATTEMPTING TO COLLECT A DEBT AND ANY INFORMATION OBTAINED WILL BE USED FOR THAT PURPOSE. IF YOU HAVE PREVIOUSLY RECEIVED A DISCHARGE IN BANKRUPTCY AND THIS DEBT WAS NOT REAFFIRMED, THIS CORRESPONDENCE IS NOT AND SHOULD NOT BE CONSTRUED TO BE AN ATTEMPT TO COLLECT A DEBT, BUT ONLY ENFORCEMENT OF A LIEN AGAINST PROPERTY.** PHELAN, HALLINAN AND SCHMIEG . By: Francis S. Hallinan, Esq., Id. No. 62695 ATTORNEY FOR PLAINTIFF One Penn Center Plaza, Suite 1400 Philadelphia, P A 19103 () I 'i) 'i61-7000 PHH MORTGAGE CORPORATION, FiKlA CENDANT : COURT OF COMMON PLEAS MORTGAGE CORPORATION, FiKlA PHH MORTGAGE SERVICES CORPORATION : CIVIL DIVISION Plaintiff : CUMBERLAND COUNTY Vs. : NO. 05-2507 DOUGLAS E. WILHELM, JR. LISA H. WILHELM A/KJA L WILHELM A/KJA WILHELM LISA HANLON AfKJA LISA M. HANLON A!KI A LISA HANLON WILHELM Defendants FILE COpy TO: LISA H. WILHELM AlK/A L WILHELM AlK/A WILHELM LISA HANLON AlKJA LISA M. HANLON A/KJ A LISA HANLON WILHELM 102 E. KELLER STREET MECHANICSBURG, P A 17055 DATE OF NOTICE: .nrr,y 1, 2005 THIS FIRM IS A DEBT COLLECTOR ATTEMPTING TO COLLECT A DEBT. THIS NOTICE IS SENT TO YOU IN AN ATTEMPT TO COLLECT THE INDEBTEDNESS REFERRED TO HEREIN, AND ANY INFORMATION OBTAINED FROM YOU WILL BE USED FOR THAT PURPOSE.IF YOU HAVE PREVIOUSLY RECEIVED A DISCHARGE IN BANKRUPTCY, THIS CORRESPONDENCE IS NOT AND SHOULD NOT BE CONSTRUED TO BE AN ATTEMPT TO COLLECT A DEBT, BUT ONLY AS ENFORCEMENT OF LIEN AGAINST PROPERTY. IMPORTANT NOTICE YOU ARE IN DEFAULT BECAUSE YOU HAVE FAILED TO ENTER A WRITTEN APPEARANCE PERSONALLY OR BY ATTORNEY AND FILE IN WRITING WITH THE COURT YOUR DEFENSES OR OBJECTIONS TO THE CLAIMS SET FORTH AGAINST YOU. UNLESS YOU ACT WITHIN TEN DAYS FROM THE DATE OF THIS NOTICE, A JUDGMENT MAY BE ENTERED AGAINST YOU WITHOUT A HEARING AND YOU MAY LOSE YOUR PROPERTY OR OTHER IMPORTANT RIGHTS. YOU SHOULD TAKE THIS PAPER TO YOUR LAWYER AT ONCE. IF YOU DO NOT HAVE A LAWYER, GO TO OR TELEPHONE THE OFFICE SET FORTH BELOW. THIS OFFICE CAN PROVIDE YOU WITH INFORMATION ABOUT HIRING A LAWYER. IF YOU CANNOT AFFORD TO HIRE A LAWYER, THIS OFFICE MAY BE ABLE TO PROVIDE YOU WITH INFORMATION ABOUT AGENCIES THAT MAY OFFER LEGAL SERVICES TO ELIGIBLE PERSONS AT A REDUCED FEE OR NO FEE. CUMBERLAND COUNTY LA WYER REFERRAL SERVICE CUMBERLAND COUNTY BAR ASSOCIA nON 32 SOUTH BEDFORD STREET CARLISLE, P A 17013 (800)990-9108 FRANCIS S. HALLINAN, ESQUIRE Attorneys for Plaintiff PHELAN, HALLINAN AND SCHMIEG By: Francis S. Hallinan, Esq., [d. No. 62695 ATTORNEY FOR PLAINTIFF One Penn Center Plaza, Suite 1400 Philadelphia, P A 19103 (21 '5) '561-7000 PHH MORTGAGE CORPORATION, F/KJ A CENDANT : COURT OF COMMON PLEAS MORTGAGE CORPORATION, F/KJA PHH MORTGAGE SERVICES CORPORATION : CIVIL DIVISION Plaintiff : CUMBERLAND COUNTY Vs. : NO. 05-2507 DOUGLAS E. WILHELM, JR. LISA H. WILHELM A/KJ A L WILHELM A/KJ A WILHELM LISA HANLON A/KJ A LISA M. HANLON A/KJ A LISA HANLON WILHELM Defendants F'~ pi (1'>0. "PV j~t ~U TO: DOUGLAS E. WILHELM, JR. 4709 BRIAN ROAD MECHANICSBURG, P A 17055 DATE OF NOTICE: nlIY 1, 2005 THIS FIRM IS A DEBT COLLECTOR ATTEMPTING TO COLLECT A DEBT. THIS NOTICE IS SENT TO YOU IN AN ATTEMPT TO COLLECT THE INDEBTEDNESS REFERRED TO HEREIN, AND ANY INFORMATION OBTAINED FROM YOU WILL BE USED FOR THAT PURPOSE.IF YOU HAVE PREVIOUSLY RECEIVED A DISCHARGE IN BANKRUPTCY, THIS CORRESPONDENCE IS NOT AND SHOULD NOT BE CONSTRUED TO BE AN ATTEMPT TO COLLECT A DEBT, BUT ONLY AS ENFORCEMENT OF LIEN AGAINST PROPERTY. IMPORT ANT NOTICE YOU ARE IN DEF AUL T BECAUSE YOU HAVE FAILED TO ENTER A WRITTEN APPEARANCE PERSONALLY OR BY ATTORNEY AND FILE IN WRITING WITH THE COURT YOUR DEFENSES OR OBJECTIONS TO THE CLAIMS SET FORTH AGAINST YOU. UNLESS YOU ACT WITHIN TEN DAYS FROM THE DATE OF THIS NOTICE, A JUDGMENT MAYBE ENTERED AGAINST YOU WITHOUT A HEARING AND YOU MA Y LOSE YOUR PROPERTY OR OTHER IMPORTANT RIGHTS. YOU SHOULD TAKE THIS PAPER TO YOUR LA WYER AT ONCE. IF YOU DO NOT HAVE A LAWYER, GO TO OR TELEPHONE THE OFFICE SET FORTH BELOW. THIS OFFICE CAN PROVIDE YOU WITH INFORMATION ABOUT HIRING A LAWYER. IF YOU CANNOT AFFORD TO HIRE A LAWYER, THIS OFFICE MAYBE ABLE TO PROVIDE YOU WITH INFORMATION ABOUT AGENCIES THAT MAY OFFER LEGAL SERVICES TO ELIGIBLE PERSONS AT A REDUCED FEE OR NO FEE. CUMBERLAND COUNTY LAWYER REFERRAL SERVICE CUMBERLAND COUNTY BAR ASSOCIA nON 32 SOUTH BEDFORD STREET CARLISLE, P A 17013 (800)990-9108 FRANCIS S. HALLINAN, ESQUIRE Attorneys for Plaintiff PHELAN HALLINAN & SCHMIEG, L.L.P. - By: DANIEL G. SCHMIEG Identification No. 62205 ATTORNEY FOR PLAINTIFF ONE PENN CENTER AT SUBURBAN STATION 1617 JOHN F. KENNEDY BLVD., SUITE 1400 PIDLADELPHIA, PA 19103-1814 (215) 563-7000 PHH MORTGAGE CORPORATION F/KJA CENDANT MORTGAGE CORPORATION, F/KJA CUMBERLAND COUNTY PHH MORTGAGE SERVICES CORPORATION COURT OF COMMON PLEAS 6000 ATRIUM WAY CIVIL DIVISION Plaintiff, NO. 05-2507 v. DOUGLAS E. WILHELM, JR. LISA H. WILHELM A/KJA L. WILHELM A/KJ A WILHELM LISA HANLON AIKI A LISA M. HANLON AJKJA LISA HANLON WILHELM Defendant(s). VERIFICATION OF NON-MILITARY SERVICE DANIEL G. SCHMIEG, ESQUIRE, hereby verifies that he is attorney for the Plaintiff in the above-captioned matter, and that on information and belief, he has knowledge ofthe following facts, to wit: (a) that the defendant(s) is/are not in the Military or Naval Service of the United States or its Allies, or otherwise within the provisions of the Soldiers' and Sailors' Civil Relief Act of Congress of 1940, as amended. (b) that defendant DOUGLAS E. WILHELM, JR. is over 18 years of age and resides at, 4709 BRIAN ROAD, MECHANICSBURG, PA 17055. (c) that defendant LISA H. WILHELM A/KJA L. WILHELM A/KJA WILHELM LISA HANLON A/KJA LISA M. HANLON A/KJA LISA HANLON WILHELM is over 18 years of age, and resides at, 102 E. KELLER STREET, MECHANICSBURG, PA 17055. This statement is made subject to the penalties of 18 Pa. C.S. Section 4904 relating to unsworn falsification to authorities. . . . Q , \ J \ ,-_.\c~~\;'V~cb( ~ .~\ )\\~e_,Q6~ DANIEL G. SCHMIEG, ESQUIRE Attorney for Plaintiff ).... l::J t> ~ it ~ ~ ) ~ ~ ~ ~ r---.. ~ ~ D o ~ ~ ~ U') -J ~ P- f f ~ ." . Cl ...._l C - ~:::; 'J C,.T' ~l i<~ ::;j --::J I (}, ~ , 'oJ .:--) '. -+n .7 --:'.::.. o CUMBERLAND COUNTY BAR ASSOCIATION 2 LIBERTY AVENUE CUMBERLAND COUNTY COURTHOUSE CARLISLE, PA 17013 (717) 249-3166 (800) 990-9108 PRAECIPE FOR WRIT OF EXECUTION - (MORTGAGE FORECLOSURE) P.R.C.P. 3180-3183 PHH MORTGAGE CORPORATION F/K/A CENDANT MORTGAGE CORPORATION, F/K/A PHH MORTGAGE SERVICES CORPORA nON Plaintiff, v. DOUGLAS E. WILHELM, JR. LISA H. WILHELM A/K/A L. WILHELM A/K/A WILHELM LISA HANLON A/K/A LISA M. HANLON A/K/A LISA HANLON WILHELM No. 05-2507 Defendant(s). TO THE DIRECTOR OF THE OFFICE OF THE PROTHONOTARY: Issue writ of execution in the above matter: Amount Due $111,400.49 ./ Interest from 9/2/05 to DECEMBER 7, 2005 (per diem -$18.31) $1,757.76 and Costs TOTAL $113,158.25 -----.----- \ " r:n \.AJ DANIEL G. SCHM , ESQUIRE One Penn Center at Suburban Station 1617 John F. Kennedy Boulevard, Suite 1400 Philadelphia, P A 19103-1814 Attorney for Plaintiff /---- Note: Please attach description of property. No. IMPORTANT NOTICE: This property is sold at the direction of the plaintiff. It may not be sold in the absence of a representative of the plaintiff at the Sheriff's Sale. The sale must be postponed or stayed in the event that a representative of the plaintiff is not present at the sale. ~~ O~ ~>: ~~ ~~ ~z ~~ ~ " O~ uz ~5 Ou ~~ 5~ u; ~~ ~~ ~~ u ")0- r:l ~~--'~'~",' ,.' :.-:.... _~'"' ~"'-r'" q,:~:~. '-.D / ~:,~:-: : - ,'.;-.,':: r', -J' '," ;-;-; . ; ,"~:: (-;; .... ' ;",' .-'.E . L-...... W"::> (13'--': c::::::) ":'.>, F-~ C1 <'1. ~OC/) ~~~ ~~u z~~ SO~ ~~~z o8t5S ~~<~ OCC~ u<~O t5~i% <o=u c~= ~~~ o~< ~~~ =z~ ~~ < ~ ~ < ~ "< ~ ~ ~ = ~ < C/) ~ < ~ "< ~ ~~ ~" ~ ~ ~~~ ~C/)~ =~..... ~~~ ~~~ ~~~ ~~~ G~~ ;J<= o~ ~"< 3 ~ ~ ~ '0c ~ r < f'() ~ "-0; \S~ --= ~ ~ ~ < ~ ~ ~ j;l> 2 t', ~ :il ~ <5-, ~ .11> . .:-::r':" ":) rC' \j ~ ~~:5-<""\~rb N- - ...(") \::1r WRIT OF EXECUTION and/or ATTACHMENT COMMONWEALTH OF PENNSYLVANIA) COUNTY OF CUMBERLAND) NO 05-2507 Civil CIVIL ACTION - LAW TO THE SHERIFF OF CUMBERLAND COUNTY: To satisfy the debt, interest and costs due PHH MORTGAGE CORP. F/K/A CENDANT MORTGAGE CORP., D/B/A PHH MORTGAGE SERVICES CORP. PJaintiff(s) From DOUGLAS E. WILHELM, JR., 4709 BRIAN ROAD, MECHANICSBURG P A 17055 and LISA H. WILHELM AJK/A L. WILHELM AJK/A WILHELM LISA HANLON AJK/A LISA M. HANLON AJK/A LISA HANLON WILHELM, 102 E. KELLER ST., MECHAlCSBURG PA 17055 (1) You are directed to levy upon the property of the defendant (s)and to sell REAL EST A TE LOCATED AT 4704 COURTLAND ST., CAMP HILL PA 17011. (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) Ifproperty 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 $111,400.49 L.L. $.50 Interest FROM 9/2/05 TO 12/7/05 @ $18.31 PER DIEM = $1,757.76 Atty's Comm % Due Prothy $1.00 Atty Paid $195.38 Plaintiff Paid Other Costs (Seal) (~~J7Ji:J? d!J l!uRTI~~ Prothonotary By: Date: SEPTEMBER 6, 2005 Deputy REQUESTING PARTY: Name DANIEL G. SCHMIEG, ESQ. Address: ONE PENN CENTER @ SUBURBAN STATION 1617 JFKBLVD., STE 1400 PHILADELPHIA PA 19103-1814 Attorney for: PLAINTIFF Telephone: (215) 563-7000 Supreme Court ID No. 62205 ~ PHH MORTGAGE CORPORATION F/K/A CENDANT MORTGAGE CORPORATION, F/K/A PHH MORTGAGE SERVICES CORPORATION CUMBERLAND COUNTY COURT OF COMMON PLEAS Plaintiff, CIVIL DIVISION v. DOUGLAS E. WILHELM, JR. LISA H. WILHELM AIK/ A L. WILHELM A/K/ A WILHELM LISA HANLON AIK/ A LISA M. HANLON A/K/A LISA HANLON WILHELM Defendant(s). NO. 05-2507 AFFIDAVIT PURSUANT TO RULE 3129 (Affidavit No. I) PHH MORTGAGE CORPORATION F/KJA CENDANT MORTGAGE CORPORATION, F/KJA PHH MORTGAGE SERVICES CORPORATION, Plaintiff in the above action, by its attorney, DANIEL G. SCHMIEG, ESQUIRE, sets forth as ofthe date the Praecipe for the Writ of Execution was filed the following information concerning the real property located at ,4704 COURTLAND STREET, CAMP HILL, P A 17011 . 1. Name and address ofOwner(s) or reputed Owner(s): Name Last Known Address (if address cannot be reasonably ascertained, please indicate) DOUGLAS E. WILHELM, JR. 4709 BRIAN ROAD MECHANICSBURG, P A 17055 LISA H. WILHELM A/K/ A L. WILHELM A/KJA WILHELM LISA HANLON A/KJA LISA M. HANLON A/K/ A LISA HANLON WILHELM 102 E. KELLER STREET MECHANICSBURG, P A 17055 2. Name and address of Defendant(s) in the judgment: Same as above 3. Name and last known address of every judgment creditor whose judgment is a record lien on the real property to be sold: Name Last Known Address (if address cannot be reasonably ascertained, please indicate) None .. .. 4. Name and address oflast recorded holder of every mortgage of record: Name Last Known Address (if address cannot be reasonably ascertained, please indicate) MERS P.O. BOX 2026 FLINT, MI 48501-2026 MERS 3200 PARK CENTER DRIVE, STE 150 COSTA MESA, CA 92626 5. Name and address of every other person who has any record lien on the property: Name Last Known Address (if address cannot be reasonably ascertained, please indicate) None 6. Name and address of every other person who has any record interest in the property and whose interest may be affected by the sale. Name Last Known Address (if address cannot be reasonably ascertained, please indicate) None 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: Name Last Known Address (if address cannot be reasonably ascertained, please indicate) Tenant/Occupant 4704 COURTLAND STREET CAMP HILL, P A 17011 Domestic Relations of Cumberland County 13 North Hanover Street Carlisle, P A 17013 Commonwealth of Pennsylvania Department of Welfare PO Box 2675 Harrisburg, P A 17105 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 ofl8 Pa. C.S. Sec. 4904 relating to unsworn falsification to authorities. C~==~~~~~~1~ro~u September 2, 2005 DATE -~-----. ----------- ---------------------------.--. '""', ~~....? c:-:, c:.f1 (,1) ~~ --' \ C'" -0 -- ."0 PHELAN HALLINAN & SCHMIEG, L.L.P. By: DANIEL G. SCHMIEG Identification No. 62205 ONE PENN CENTER AT SUBURBAN STATION 1617 JOHN F. KENNEDY BLVD., SUITE 1400 PIDLADELPIDA, PA 19103-1814 (215) 563-7000 A TTORNEY FOR PLAINTIFF PHH MORTGAGE CORPORATION FIK/A CENDANT MORTGAGE CORPORATION, F/KlA PHH MORTGAGE SERVICES CORPORATION CUMBERLAND COUNTY COURT OF COMMON PLEAS Plaintiff, CIVIL DIVISION v. NO. 05-2507 DOUGLAS E. WILHELM, JR. LISA H. WILHELM AlKJ A L. WILHELM AlKI A WILHELM LISA HANLON AfKJA LISA M. HANLON AlKlA LISA HANLON WILHELM Defendant(s). CERTIFICATION DANIEL G. SCHMIEG, ESQUIRE, hereby verifies that he is attorney for the Plaintiff in the above-captioned matter, and that the premises are not subject to the provisions of Act 91 because it is: (X) an FHA mortgage () non-owner occupied () vacant o Act 91 procedures have been fulfilled This certification is made subject to the penalties of 18 Pa. C.S. Section 4904 relating to unsworn falsification to authorities. " _l \')\\.~\ QUIRE C t""-::> {--..., s=?,. '~1 c:::rl - t';: - - ; PHH MORTGAGE CORPORATION F/K/A CENDANT MORTGAGE CORPORATION, F/K/A PHH MORTGAGE SERVICES CORPORATION Plaintiff, CUMBERLAND COUNTY No. 05-2507 v. DOUGLAS E. WILHELM, JR. LISA H. WILHELM A/K/ A L. WILHELM A/K/ A WILHELM LISA HANLON A/K/A LISA M. HANLON A/K/ A LISA HANLON WILHELM Defendant(s). September 2, 2005 TO: DOUGLAS E. WILHELM, JR. 4709 BRIAN ROAD MECHANICSBURG, PA 17055 LISA H. WILHELM A/KIA L. WILHELM A/KlA WILHELM LISA HANLON A/K/A LISA M. HANLON A/KlA LISA HANLON WILHELM 102 E. KELLER STREET MECHANICSBURG, PA 17055 * * THIS FIRM IS A DEBT COLLECTOR A TTEMPTING TO COLLECT A DEBT AND ANY INFORM A TION OBTAINED WILL BE USED FOR THA T PURPOSE. IF YOU HA VE PREVIOUSLY RECEIVED A DISCHARGE IN BANKRUPTCY AND THIS DEBT WAS NOT REAFFIRMED, THIS IS NOT AND SHOULD NOT BE CONSTRUED TO Bl AN ATTEMPT TO COLLECT A DEBT, BUT ONLY ENFORCEMENT OF A LIEN AGAINST PROPERTY. ** Your house (real estate) at. 4704 COURTLAND STREET. CAMP HILL, PA 17011. is scheduled to be sold at the Sheriffs Sale on DECEMBER 7, 2005 at 10:00 a.m. in the Cumberland County Courthouse, South Hanover Street, Carlisle, P A 17013, to enforce the court judgment of $111.400.49 obtained byPHH MORTGAGE CORPORATION F/K/A CENDANT MORTGAGE CORPORATION, F/K/A PHH MORTGAGE SERVICES CORPORATION (the mortgagee) against you. In the event the sale is continued, an announcement will be made at said sale in complian with Pa.R.C.P., Rule 3129.3. 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 the mortgagee the back payments, late charges, costs and reasonable attorney's fees due. To find out how much you must pay, you ma) call: (215) 563-7000. , 2. You may be able to stop the sale by filing a petition asking the Court to strike or open the judgment, if the judgment was improperly entered. You may also ask the Court to postpone the sale for good cause. 3. You may also be able to 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 on page two on how to obtain an attorney.) YOU MAY STILL BE ABLE TO SAVE YOUR PROPERTY AND YOU HAVE OTHER RIGHTS EVEN IF THE SHERIFF'S SALE DOES TAKE PLACE. I. If the Sheriffs Sale is not stopped, your property will be sold to the highest bidder. You may find out the price bid by calling (215) 563-7000. 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 (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 the right to remain in the property until the full amount due is paid to the Sheriff and the Sheriff gives a deed to the buyer. At that time, the buyer may bring legal proceedings to evict you. 6. You may be entitled to a share of the money which was paid for your house. A schedule of distribution of the money bid for your house will be filed by the Sheriff within 30 days of the 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 (to) days after the distribution is filed. 7 . You may also have other rights and defenses, or ways of getting your home 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. IMPORTANT NOTICE: This property is sold at the direction of the plaintiff. It may not be sold in the absence of a representative ofthe plaintiff at the Sheriff's Sale. The sale must be postponed or stayed in the event that a representative of the plaintiff is not present at the sale. CUMBERLAND COUNTY ATTORNEY REFERRAL DESCRIPTION ALL that certain tract in the Township of Hampden, County of Cumberland, Commonwealth of Pennsylvania, more particularly bounded and described as follows, to wit: BEGINNING at a point on the East side of Courtland Street, which point is 212 feet Westwardly and Southwardly from the Southwesterly comer of Courtland Street and Hampden Avenue, said point being also at the division lines of Lots Nos. 160 and 161; thence South 73 degrees 12 minutes East along said division line eighty five and thirty- four hundredths (85.34) feet to a point at the division lines of Lots Nos. 158 and 161; thence South 20 degrees 01 minute East along said division lines sixty-four and twelve hundredths (64.12) feet to a point at the division lines of Lots No.s 161 and 162; thence South 69 degrees 55 minutes West along said division line eighty-eight and nine hundredths (88.09) feet to a point on the Eastern side of Courtland Street; thence North 20 degrees 39 minutes West along the aforementioned Courtland Street fifty-one and thirty-eight hundredths (51.38) feet to a point; thence continuing along Courtland Street in a arc to the right with a radius of one hundred five and seventy-eighty hundredths (105.78) feet the arc distance of sixty-seven and thirty-nine hundredths (67.39) feet to a point the PLACE OF BEGINNING. IT BEING Lot No. 161 on General Plan of Section 2 and 3 Clearview Farms, which plan is recorded in Plan Book 9, Page 6, Cumberland County. HAVING thereon erected a split-level brick and frame dwelling house know as 4704 Courtland Street. BEING part of the same tract of ground which Nelson Improvement and Development Corporation by Deed dated the 15th day of August 1960, and recorded in and for the County of Cumberland in Deed Book 2, Volume 19, Page 40, granted and conveyed unto Robert H. Snyder and Patricia J. Snyder, his wife of Hampden Township, who are both now deceased. AND the Grantors will warrant specially the property hereby conveyed. Being Parcel # 10-21-0279-144 RECORD OWNER TITLE TO SAID PREMISES IS VESTED IN Douglas E. Wilhelm, Junior, and Lisa H. Wilhelm, husband and wife, by Deed from Robert H. Snyder and Kristy L. Kessler, Executors of the Estate of Patricia J. Snyder, dated 12-30-97, recorded 1-2-98 in Deed Book 170, page 265. Premises: 4704 Courtland Street, Camp Hill, PA 17011 .--- ~~-:1 ~"'..... ,....) c-:2} 25~ (/J r.' -v c.... !,.) - AFFIDAVIT OF SERVICE PLAINTIFF. PHH MORTGAGE CORPORATION F/KlA CENDANT MORTGAGE CORPORATION. FtKlA PHH MORTGAGE SERVICES CORPORATION CUMBERLAND COUNTY KIO No. 05-2507 DEFENDANT(S) DOUGLAS E. WILHELM, JR. ACCT. #0006456842 LISA H. WILHELM AlKlA L- WILHELM AlKlA WILHEUf LISA HANLON AlKlA LISA M. HANLON AIKIA LISA HANLON WILHELM SERVE LISA H. WILHELM AlKlA L- WILHEI,M AlKlA WILHELM LISA HANLON AlKlA LISA M. HANLON AlK/A LISA HANLON WILHELM AT 102 E. KELLER STREET MECHANICSBURG. P A 17055 Type of Action - Notice of Sheriff's Sale Served and made known to J.., i ~ a Sale Date: DECEMBER 7, 2005 ". Wolf ~e.VED rJt 1- H iAe . Defendant, on the / 1 day of Se r . f', ,Kellut Sf.) )t1e.cka.Nic.;IoVf(:; ,200';':1 C,'J (), o'clock~.m., al I (i.;{ ,Commonwea]lh of Pennsylvania, in the manner described below: Defendant personally served. I _ r _ .J Adult family member with whom Defendant(s) reside(s). Name and Relationship is _V\ VS I:?~ to Q Adult in charge of Defendant(s)'s residence who refused to give name or relationship. (J \ ,..- Manager/Clerk of place oflodging in which Defendant(s) reside(s). 00,) .6 ~ j:., Agent or person in charge ofDefendanl(s)'s office or usual place of business. an officer of said Defendant(s)'s company. Other: , .' sCo.~ cd...~ "'- \......: l<.. Description: Age!fQ Height.i:.l..o Weight '(,,0 Race W~SexA Other No ":l\~...,.. ~ I, n~~....e... L. C~\71 ~acompetent adult, being duly sworn according to law, depose and state that I personally handed a true and correct copy of the Notice of Sheriffs Sale in the manner as set forth herein, issued in the captioned case on the date and at the address indicated above. Y.. W;\~elw:r\-. 1 Sworn to and subscribed before me this 1!I.tit. day of -yn+- ,200~ ~ Notary:~ By: PLEASE ATTE~CE AT LE 3 TIMES. INDI ATTEMPTED. NOTNIW.SE'N. L.UCW H. r.wv.:NlIc My '.m NOT SERVED On the day of ,200_, at o'clock _.m.. Defendant NOT FOUND because: Moved Unknown No Answer Vacant 1" Attempt: / / Time: 2"" Attempt: / / Time: 3rd Attempt: / Time: Sworn 10 and subscribed before me this _ day of , 200 _' Notary: By: Attornev for Plaintiff Daniel G. Schmieg, Esquire I.D. No. 62205 C--' c-.;) c;:? <.Y' o co -, \ ...l () ~'n .... ~r:.-n r-ne ':.0~ ,.:. (} ~-;, ...-' - c? ".. -_\;~~ ~~=?t' ::;S ::.::. - u.... - AFFIDAVIT OF SERVICE CUMBERLAND COUNTY PLAINTIFF PHH MORTGAGE CORPORATION FIKIA CENDANT MORTGAGE CORPORATION, F/KfA PHH MORTGAGE SERVICES CORPORATION KIO No. 05-2507 DEFENDANT(S) DOUGLAS E. WILHELM, JR. LISA H. WILHELM A/KfA L. WILHELM A/KfA WILHELM LISA HANLON A/KfA LISA M. HANLON A/KfA LISA HANLON WILHELM ACCT. #0006456842 SERVE DOUGLAS E. WILHELM, JR. AT 4709 BRIAN ROAD MECHANICSBURG. PA 17055 Type of Action - Notice of Sheriff's Sale Sale Date: DECEMBER 7, 2005 \, SE\tVED Jt.- Served and made known to -Do,"" \"'~ f, \..1.), "'~ \ W'\ ,Defendant, on the I q If day of S'E',&. ,200-r,-at c.:}O .o'clock?-m.,at IC~ 'E, ,("~f1ell '5~. I t<<~c.~Q.,",; l1.'> k:.OlC.") , Commonwealth of Pennsylvania, in the manner described below: '-{ Defendant personally served. Adult family member with whom Defendant(s) reside(s). Name and Relationship is Adult in charge of Defendant(s)'s residence who refused to give name or relationship. Manager/Clerk of place oflodging in which Defendant(s) reside(s). Agent or person in charge of Defendant(s)'s office or usual place of business. an officer of said Defendant(s)'s company. . ~(~ d_ lc , Ir ..\ Description: Age..!fQ.. Height ~ /0 Weight 1,"0 Race ~ Sex Lather tJo ':l \..,.,::>e '> I, (\ i}v . \lJC~ L. ~~" ~, a competent adult, being duly sworn according to law, depose and state that I personally handed a true and bOh-ect copy of the Notice of Sheriffs Sale in the manner as set forth herein, issued in the captioned case on the date and at the address indicated above. \",.\ It. Other: Sworn to and subscribed before me this IfI'Ib day of ~m-,bu , 200S. Ndtary~ Ci;d; vJ;... By: PLEASE ATT~~;~ ~VICE A NOTARIAL SEAl. WCUEH.CARTY.~ ~ . Nov.1~ ~ NOT SERVED day of ,200_, at o'clock _.m., Defendant NOT FOUND because: On the Moved Unknown No Answer Vacant 2nd Attempt: / / Time: 1" Attempt: / / Time: 3rd Attempt: / / Time: Sworn to and subscribed before me this _ day of , 200 _' Notary: By: /~, Attornev for Plaintiff Daniel G. Schmieg, Esquire - I.D. No. 62205 ...., c=' = c:...rl co <"? -, ~ s:'" inr: -'7fT} ~ 'J C;::,1 .~~ S"'~C) ;::(")01 ~~ ~ I ---' :s:: ~._~ -' ~:? fJ1 IN THE COURT OF COMMON PLEAS OF CUMBERLAND COUNTY, PENNSYLVANIA PHH MORTGAGE CORPORATION, F/KJA CENDANT MORTGAGE CORPORATION, F/K/A PHH MORTGAGE SERVICES CORPORATION ) CIVIL ACTION ) vs. ) CIVIL DIVISION ) NO. 05-2507 DOUGLAS E. WILHEMLM, JR. and LISA H. WILHEM A/K/ A L. WILHELM A/K/ A WILHELM LISA HANLON A/K/A LISA M. HANLON A/K/A LISA HANLON WILHELM AFFIDAVIT OF SERVICE PURSUANT TO RULE 3129 COMMONWEALTH OF PENNSYLVANIA COUNTY OF CUMBERLAND ) ) ss: 1, DANIEL G. SCHMIEG, ESQUIRE attorney for PHH MORTGAGE CORPORATION, F/K/ A CENDANT MORTGAGECORPORA TION, F/KJA PHH MORTGAGE SERVICES CORPORATION hereby verify that on 9/6/05 true and correct copies of the Notice of Sheriffs sale were served by certificate of mailing to the recorded lienholders, and any known interested party see Exhibit "A" attached hereto. DATE: November 3. 2005 ANIEL G. SCHMIEG, ES Attorney for Plaintiff PHH MORTGAGE CORPORATION FfI(/A CENDANT MORTGAGE CORPORATION, F/KIA PHH MORTGAGE SERVICES CORPORATION CUMBERLAND COUNTY COURT OF COMMON PLEAS Plaintiff, v. CIVIL DIVISION DOUGLAS E. WILHELM, JR. LISA H. WILHELM AfKJA L. WILHELM AfKJA WILHELM LISA HANLON AfKJA LISA M. HANLON AfKJA LISA HANLON WILHELM Defendant(s). NO. 05-2507 AFFIDAVIT PURSUANT TO RULE 3129 (Affidavit No. I) PHH MORTGAGE CORPORATION FIKlA CENDANT MORTGAGE CORPORATION. FIKlA PHH MORTGAGE SERVICES CORPORATION, Plaintiff in the above action, by its attorney, DANIEL G. SCHMIEG, 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 ,4704 COURTLAND STREET. CAMP HILL. P A 17011 . 1. Name and address ofOwner(s) or reputed Owner(s): Name Last Known Address (if address cannot be reasonably ascertained, please indicate) DOUGLAS E. WILHELM, JR. 4709 BRIAN ROAD MECHANICSBURG, PA 17055 LISA H. WILHELM AlKlA L. WILHELM AlKlA WILHELM LISA HANLON AlKlA LISA M. HANLON AlKlA LISA HANLON WILHELM 102 E. KELLER STREET MECHANICSBURG, PA 17055 2. Name and address of Defendant(s) in the judgment: Same as above 3. Name and last known address of every judgment creditor whose judgment is a record lien on the real property to be sold: Name Last Known Address (if address cannot be reasonably ascertained, please indicate) None 4. Name and address of last recorded holder of every mortgage of record: Name Last Known Address (if address cannot be reasonably ascertained, please indicate) MERS P.O. BOX 2026 FLINT, MI 48501-2026 MERS 3200 PARK CENTER DRIVE, STE 150 COSTA MESA, CA 92626 5. Name and address of every other person who has any record lien on the property: Name Last Known Address (if address cannot be reasonably ascertained, please indicate) None 6. Name and address of every other person who has any record interest in the property and whose interest may be affected by the sale. Name Last Known Address (if address cannot be reasonably ascertained, please indicate) None 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: Name Last Known Address (if address cannot be reasonably ascertained, please indicate) Tenant/Occnpant 4704 COURTLAND STREET CAMP HILL, P A 17011 Domestic Relations of Cumberland County 13 North Hanover Street Carlisle, P A 17013 Commonwealth of Pennsylvania Department of Welfare PO Box 2675 Harrisburg, PA 17105 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 ofl8 Pa. C.S. Sec. 4904 relating to unsworn falsification to authorities. <:~-- September 2. 2005 DATE o",',L. l;:'. ,...,Q." 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" :? 0' ~ 1 () "C - ~ ~ ~ '-" % -z I!t 0 (jQ ~~~\fil ;..-\ ~ ~ % j5,'H,<: ';l> ~. tn;;)"'O- ~ () ;I: ~ ~.6p ~ ~ po .....~ ~ t;;' .-l i \~~gl (/) ~ ~ ~~~;g ?' ? 0 ... ,V>"'" 0 () ~ ~ 5 0'~g5'2 ';>' ,... :',"' H r' If1 '0' ~,~~og ~' ~ ~ \"\llt;, tg .-0 '"<l ~ tg ';>' ~ po s'\:~~\ ..... ~ ~. ----l co g ':,;\ ~ g 0 0 ~ ~ ~ ~ e., ..... .-0 ~iil~g: ..... 0 ~ o:aH cO t\ ;;;- 0 M ~~~e ~ .., ~ <'> ~,- a tio ~ ,,~~ S' N "" %.H~ ~ >- po a ~ ~ , :!' - 0 p'g\ -' 0 .... g'" ~- - po ...~ 'a '-" t;e. ~_ ~~tl;9.. ., €;:ii''itW; V> .gg%%. ~ \:;;~% \V~ ' PUiN ((; ~~POsI-~ \\~\\ ~1 "h' i"~'- ~ f~:;...~- -~ - 'li" ~.~ \d/-..~~ . -;:) ......... f'llf'l('/ 6()VI!'ES \1%-~\ \"' <o<8/.' 021A $ 01.500 ~~." ~ ~' V 0004300311 ~\~,z "~ SEP 06 2005 -s. 8~ . MAILED FllOM ZIP coDE 19103 ~ 1'%- '''_ 'l,si-o ,*;J,'''g.?> \ ..w i:l III 0' \j. ~, ~ C> t'-.;) C~,::I 0 t. C:.J WI -n :1"'" ---< (:',) :1: .....,; rn::::!) , Gl 0 CJ l:~) -., .:{.; ::.t (:':> r:::- ,.", (1'1 ~:'l p,,) ~,> :~i.J N .< PHH Mortgage Corporation f/k/a Cendant Mortgage Corporation f/k/a PHH Mortgage Services Corporation VS Douglas E. Wilhelm & Lisa H. Wilhelm a/k/a 1. Wilhelm aIkIa Wilhelm Lisa HenIon a/k/a Lisa M. Wilhelm aIkIa Lisa Hanlon Wilhelm The Court of Common Pleas of Cumberland County, Pennsylvania Writ No. 2005-2507 Civil Term Richard E. Smith, Deputy Sheriff, who being duly sworn according to law, states that on Sept. 28, 2005 at 6:46 o'clock PM, he served a true copy of the within Real Estate Writ, Notice of Sheriffs Sale and Description, in the above entitled action, upon the within named defendant, to wit: Douglas E. Wilhelm, by making known unto Douglas E. Wilhelm, personally, at 4709 Brian Road, Mechanicsburg, Cumberland County, Pennsylvania, its contents and at the same time handing to him personally the said true and correct copy of the same. Richard E. Smith, Deputy Sheriff, who being duly sworn according to law, states that on Sept. 28, 2005 at 6:56 o'clock PM, he served a true copy of the within Real Estate Writ, Notice of Sheriffs Sale and Description, in the above entitled action, upon the within named defendant, to wit: Lisa H. Wilhelm aIkIa 1. Wilhelm a/k/a Wilhelm Lisa Hanlon a/k/a Lisa M. Hanlon a/k/a Lisa Hanlon Wilhelm, by making known unto Betty Miller, Mother of Lisa Wilhelm, at 102 E. Keller Street, Mechanicsburg, Cumberland County, Pennsylvania, its contents and at the same time handing to her personally the said true and correct copy of the same. Ron Hoover, Deputy Sheriff, who being duly sworn according to law, states that on October 12,2005 at 6:01 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 Douglas E. Wilhelm, Jr. and Lisa H. Wilhelm aIkIa 1. Wilhelm a/k/a Wilhelm Lisa HenIon a/k/a Lisa M. Hanlon a/k/a Lisa Hanlon Wilhelm located at 4704 Courtland Street, Camp Hill, Pennsylvania, according to law. R. Thomas Kline, Sheriff, who being duly sworn according to law, states he served the above Real Estate Writ, Notice, Poster and Description in the following manner: The Sheriff mailed a notice of the pendency of the action to the within named defendant, to wit: Douglas E. Wilhelm, Jr., by regular mail to his last known address of 4709 Brian Road, Mechanicsburg, P A 17055. This letter was mailed under the date of October 06, 2005 and never returned to the Sheriffs Office. ''t L. , PHH MORTGAGE CORPORATION FIK/A CENDANT MORTGAGE CORPORATION, FIKfA PHH MORTGAGE SERVICES CORPORATION CUMBERLAND COUNTY COURT OF COMMON PLEAS Plaintiff, v. CIVIL DIVISION DOUGLAS E. WILHELM, JR. LISA H. WILHELM AlKfA L. WILHELM AlKlA WILHELM LISA HANLON AfK/A LISA M. HANLON AlKlA LISA HANLON WILHELM Defendant(s). NO. 05-2507 AFFIDAVIT PURSUANT TO RULE 3129 (Affidavit No. I) PHH MORTGAGE CORPORATION F/K1A CENDANT MORTGAGE CORPORATION, F/K1A PHH MORTGAGE SERVICES CORPORATION, Plaintiff in the above action, by its attorney, DANIEL G. SCHMIEG, 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 ,4704 COURTLAND STREET. CAMP HILL. P A 17011 . 1. Name and address ofOwner(s) or reputed Owner(s): Name Last Known Address (if address cannot be reasonably ascertained, please indicate) DOUGLAS E. WILHELM, JR. 4709 BRIAN ROAD MECHANICSBURG, PA 17055 LISA H. WILHELM A/K1A L. WILHELM A/K1A WILHELM LISA HANLON A/K1A LISA M. HANLON A/K1A LISA HANLON WILHELM 102 E. KELLER STREET MECHANICSBURG, PA 17055 2. Name and address of Defendant(s) in the judgment: Same as above 3. Name and last known address of every judgment creditor whose judgment is a record lien on the real property to be sold: Name Last Known Address (if address cannot be reasonably ascertained, please indicate) None 4. Name and address of last recorded holder of every mortgage of record: Name Last Known Address (if address cannot be reasonably ascertained, please indicate) MERS P.O. BOX 2026 FLINT, MI 48501-2026 MERS 3200 PARK CENTER DRIVE, STE 150 COSTA MESA, CA 92626 5. Name and address of every other person who has any record lien on the property: Name Last Known Address (if address cannot be reasonably ascertained, please indicate) None 6. Name and address of every other person who has any record interest in the property and whose interest may be affected by the sale. Name Last Known Address (if address cannot be reasonably ascertained, please indicate) None 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: Name Last Known Address (if address cannot be reasonably ascertained, please indicate) Tenant/Occnpant 4704 COURTLAND STREET CAMP HILL, P A 17011 Domestic Relations of Cumberland County 13 North Hanover Street Carlisle, PA 17013 Commonwealth of Pennsylvania Department of Welfare PO Box 2675 Harrisburg, PA 17105 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 ofl8 Pa. C.S. Sec. 4904 relating to unsworn falsification to authorities. September 2. 2005 DATE .. .. " ,. PHH MORTGAGE CORPORATION F/KJA CENDANTMORTGAGE CORPORATION, F/KJA PHH MORTGAGE SERVICES CORPORATION Plaintiff, CUMBERLAND COUNTY No. 05-2507 v. DOUGLAS E. WILHELM, JR. LISA H. WILHELM AlKJA L. WILHELM AlKJA WILHELM LISA HANLON AlKJA LISA M. HANLON AlKJA LISA HANLON WILHELM Defendant(s). September 2, 2005 TO: DOUGLAS E. WILHELM, JR. 4709 BRIAN ROAD MECHANICSBURG, P A 17055 LISA H. WILHELM A/KiA L. WILHELM AlKiA WILHELM LISA HANLON AlKiA LISA M. HANLON AlKiA LISA HANLON WILHELM 102 E. KELLER STREET MECHANICSBURG, PA 17055 **THIS FIRM IS A DEBT COLLECTOR A TTEMPTfNG TO COLLECT A DEBT AND ANY INFORMATION OBTAINED WILL BE USED FOR THAT PURPOSE IF YOU HAVE PREVIOUSLY RECEIVED A DISCHARGE IN BANKRUPTCY AND THIS DEBT WAS NOT REAFFIRJrfED, THIS IS NOT AND SHOULD NOT BE CONSTRUED TO BE AN ATTEMPT TO COLLECT A DEBT, BUT ONLY ENFORCEMENT OF A LIEN AGAINST PROPERTY ** Your house (real estate) at, 4704 COURTLAND STREET, CAMP HILL, PA 17011, is scheduled to be sold at the Sheriffs Sale on DECEMBER 7. 2005 at 10:00 a.m. in the Cumberland County Courthouse, South Hanover Street, Carlisle, PA 17013, to enforce the court judgment of $111,400.49 obtained by PHH MORTGAGE CORPORATION F/K/A CENDANT MORTGAGE CORPORATION, F/K/A PHH MORTGAGE SERVICES CORPORATION (the mortgagee) against you. In the event the sale is continued, an announcement will be made at said sale in compliance with Pa.R.C.P., Rule 3129.3. 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 the mortgagee the back payments, late charges, costs and reasonable attorney's fees due. To find out how much you must pay, you may call: (215) 563-7000. ":t' .. 2. You may be able to stop the sale by filing a petition asking the Court to strike or open the judgment, if the judgment was improperly entered. You may also ask the Court to postpone the sale for good cause. 3. You may also be able to 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 on page two on how to obtain an attorney.) YOU MAY STILL BE ABLE TO SAVE YOUR PROPERTY AND YOU HAVE OTHER RIGHTS EVEN IF THE SHERIFF'S SALE DOES TAKE PLACE. I. If the Sheriffs Sale is not stopped, your property will be sold to the highest bidder. You may find out the price bid by calling (215) 563-7000. 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 (717) 240-6390. 4. If the amount due from the Buyer is not paid to the Sheriff, you will remain the owner ofthe property as if the sale never happened. 5. You have the right to remain in the property until the full amount due is paid to the Sheriff and the Sheriff gives a deed to the buyer. At that time, the buyer may bring legal proceedings to evict you. 6. You may be entitled to a share of the money which was paid for your house. A schedule of distribution of the money bid for your house will be filed by the Sheriff within 30 days of the sale. This schedule will state who will be receiving that money. The money will be paid out in accordance with this schedule unless exceptions (reasons why the proposed distribution is wrong) are filed with the Sheriff within ten (10) days after the distribution is filed. 7. You may also have other rights and defenses, or ways of getting your home 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. IMPORT ANT NOTICE: This property is sold at the direction of the plaintiff. It mav not be sold in the absence of a representative of the plaintiff at the Sheriffs Sale. The sale must be postponed or stayed in the event that a representative ofthe plaintiff is not present at the sale. CUMBERLAND COUNTY ATTORNEY REFERRAL . . DESCRIPTION ALL that certain tract in the Township of Hampden, County of Cumberland, Commonwealth of Pennsylvania, more particularly bounded and described as follows, to wit: BEGINNING at a point on the East side of Courtland Street, which point is 212 feet Westwardly and Southwardly from the Southwesterly corner of Courtland Street and Hampden Avenue, said point being also at the division lines of Lots Nos. 160 and 16 I; thence South 73 degrees 12 minutes East along said division Jine eighty five and thirty- four hundredths (85.34) feet to a point at the division lines of Lots Nos. 158 and 16 I; thence South 20 degrees 01 minute East along said division lines sixty-four and twelve hundredths (64.12) feet to a point at the division Jines of Lots No.s 161 and 162; thence South 69 degrees 55 minutes West along said division line eighty-eight and nine hundredths (88.09) feet to a point on the Eastern side of Courtland Street; thence North 20 degrees 39 minutes West along the aforementioned Courtland Street fifty-one and thirty-eight hundredths (51.38) feet to a point; thence continuing along Courtland Street in a arc to the right with a radius of one hundred five and seventy-eighty hundredths (105.78) feet the arc distance of sixty-seven and thirty-nine hundredths (67.39) feet to a point the PLACE OF BEGINNING. IT BEING Lot No. 161 on General Plan of Section 2 and 3 Clearview Farms, which plan is recorded in Plan Book 9, Page 6, Cumberland County. HAVING thereon erected a split-level brick and frame dwelling house know as 4704 Courtland Street. BEING part of the same tract of ground which Nelson Improvement and Development Corporation by Deed dated the 15th day of August J 960, and recorded in and for the County of Cumberland in Deed Book 2, Volume 19, Page 40, granted and conveyed unto Robert H. Snyder and Patricia J. Snyder, his wife of Hampden Township, who are both now deceased. AND the Grantors will warrant specially the property hereby conveyed. Being Parcel # 10-2 I -0279-144 RECORD OWNER TITLE TO SAID PREMISES IS VESTED IN Douglas E. Wilhelm, Junior, and Lisa H. Wilhelm, husband and wife, by Deed from Robert H. Snyder and Kristy L Kessler, Executors of the Estate of Patricia J. Snyder, dated 12.30-97, recorded 1-2-98 in Deed Book 170, page 265. Premises: 4704 Courtland Street, Camp Hill, P A 170 II . . WRIT OF EXECUTION and/or ATTACHMENT COMMONWEALTH OF PENNSYLVANIA) COUNTY OF CUMBERLAND) NO 05-2507 Civil CIVIL ACTION ~ LAW TO THE SHERIFF OF CUMBERLAND COUNTY: To satisfy the debt, interest and costs due PHH MORTGAGE CORP. F/K/A CENDANT MORTGAGE CORP., D/B/A PHH MORTGAGE SERVICES CORP. Plaintiff(s) From DOUGLAS E. WILHELM, JR., 4709 BRIAN ROAD, MECHANICSBURG P A 17055 and LISA H. WILHELM A/K/ A L. WILHELM A/K/ A WILHELM LISA HANLON A/K/ A LISA M. HANLON A/K/A LISA HANLON WILHELM, 102 E. KELLER ST., MECHAICSBURG PA 17055 (1) You are directed to levy upon the property of the defendant (s)and to sell REAL ESTATE LOCATED AT 4704 COURTLAND ST., CAMP HILL PA 17011. (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 $111,400.49 LL $.50 Interest FROM 9/2/05 TO 12/7/05 @ $18.31 PER DIEM = $1,757.76 Atty's Comm % Due Prothy $1.00 Atty Paid $195.38 Plaintiff Paid Date: SEPTEMBER 6, 2005 Other Costs (:. CURTIS R. LONG Prothonotary (Seal) By: Deputy REQUESTING PARTY: Name DANIEL G. SCHMIEG, ESQ. Address: ONE PENN CENTER @ SUBURBAN STATION 1617 JFKBLVD., STE 1400 PHILADELPHIA PA 19103-1814 Attorney for: PLAINTIFF Telephone: (215) 563-7000 Supreme Court ID No. 62205 ~ ~ GV'l Real Estate Sale #54 On September 12,2005 the Sheriff levied upon the defendant's interest in the real property situated in Hampden Township, Cumberland County, P A Known and numbered as 4704 Courtland Street, Camp Hill, more fully described on Exhibit "A" CD -::filed with this writ and by this reference incorporated herein. ~ate: September 12,2005 By:,JocL-x \~ Real Estat<el Sergeant I THE PATRIOT NEWS THE SUNDAY PATRIOT NEWS Proof of Publication Under Act No. 587, Approved May 16, 1929 Commonwealth of Pennsylvania, County of Dauphin) ss Joseph A. Dennison, being duly sworn according to law, deposes and says: That he is the Assistant 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 in the 25th day(s) of October and the 1st and 8th day(s) of November 2005. 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 COpy re me this 23rd day of November 200S A.D. NOIARIAL SEAl Terry L Russell~ Notary Public Oly of H~rnsbur . Dauphin Counly My CommlsSlo pires Ju 6, 2006 ."r-j Membsf,PennsyJ VZ/e/?7 NOTARY PUBLIC My commission expires June 6, 2006 Sworn to and s CUMBERLAND COUNTY SHERlFFS OFFICE CUMBERLAND COUNTY COURTHOUSE CARLISLE, PA. 17013 '"REAL ESTATE IM.E No. 54 WrtlNo.-.07 Civil Term PHH ........ CoIp., IIkIa Cenclant IIOrIgage Corp., ,_ PHH IIOrIgage Services CoIp. VB Dougl_ E. Wilhelm, Jr. & Usa H. Wilhelm aIkIlI LWllh8lm 81 k1a Wilhelm Usa Henlon aIkIa Usa M. Hmllon aIkIa Usa 1Ian"'" Wilhelm Ally: Danlal Schmieg DESCRIPTION Jtt.L THAT CElUAIN tJact in the Township of Hampden, County of Cumberland, Commonweallb. of PellllSylvania, more particularly bounded and described asfo1Iows,to wit: BEGINNING at a point on the East side of Courtland Street, which point is 212 feet Westwardly and Southwardly from the Southwesterly comer of Courtland Street and Hampden AVenue. said point being also at the division lines of Lots Nos. 160 and 161; thence South 13 degrees 12. minutes East along said dimion line eigbIy 6" and 1hirty foorlumdredlhs (8534) feet to a point at the division lines of lots Noo. 158 and 161; "',nce Soulh 1J) degrees 01 minute East along said division 1ines sixty four and lWelve h_ (64.12) feet to . point at the division lines of Lots NoS. 161 and 162; lhence South (f} degrees 55 minutes West along said division line eighty eight and nine hundredths (88.09) feet to a point on the Eastern side of Courtland Street; thence Nerth 2D degrees 39 _Westaloogth,~onedCourtland S_fifty one and thiny eightlumdredlhs (5138) feet "'. point; thonce iootinuing along Courtland Street in an arc to tile right with a radius of one hundred five and seventy eight hundredths (105.78) feet the at< disIance of sixty seven and thiny nine Iumdredlhs (6739) feet'" . point the PLACE OFBE-GINNING. IT BEING Lot No. 161 on Geoeral Plan of Section 2 and 3 C1earview Fauns, which pian is n=ded m Plan Book 9, Page 6. Cumberland County. HAVING thereon erected a split-level brick. and frame dwelling house known .. 4704 Cowtland S_. BEING port of the '''''' _ of groond which Nelson Improvement and Development GoliPatioo by Deed dated the 15th day 01 August 1960, and recorded in and for the County of Cumberland in Dced Book 2, Volume 19, Page 40. granted and conveyed unto Robert H. Snyder and PatriclaJ Snyder. his Wife.ofllatnpden Thwnship. woo are both now deceased. AND the ~ will)"""'" specially the property heJeby conv'yol. '. Bcing Pmrel #10-21-0279-144. 1TIlE TO SAID PREMISES is vested in Douglaa E. Wilhelm. Junior. and Lisa H. Wdhelm. h",band and _. by Deedfroin Roher! H. snYder and kristy L. Kessler, F..xec1Illmi of the F.uate of Patricia J. Snyder. dated 12130197,Ie<:1lIded 1/2/98 in Deed Book 170, page 265. Premises: 4704 Cowtland S_, Camp Ilill. PA l7Oll. PROOF OF PUBLICATION OF NOTICE IN CUMBERLAND LAW JOURNAL (Under Act No. 587, approved May 16, 1929), P. L.1784 COMMONWEALTH OF PENNSYLVANIA ss. COUNTY OF CUMBERLAND Lisa Marie Coyne, Esquire, Editor of the Cumberland Law Journal, of the County and State aforesaid, being duly sworn, according to law, deposes and says that the Cumberland 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, V1Z: October 14, 21, 28, 2005 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. SWORN TO AND SUBSCRIBED before me this 28 day of October. 2005 ~~td'";~r~ I NOT ARI;\,. )C,'e. I , l GIS E. S~NDr:8, Notary P'~l,~ilc I C 'li!:')(' Bi)fC (;~!rnheriand C'J\I:I\\:; . ;",';:~,::;,i~;~;{n l~.};'...-:: :\:'!w(:h Ci, ~:(}\I:l I "'. ~~......",,-~~-~...... . ,..... REAL ESTATE SALE NO. 54 Writ No. 2005-2507 Civil PHH Mortgage Corporation F /K/ A Cendant Mortgage Corporation, F /K/ A PHH Mortgage Services Corporation VS. Douglas E. Wilhelm, Jr. & Lisa H. Wilhelm A/K/ A L. Wilhelm A/K/ A Wilhelm Usa Henlon A/K/ A Lisa M. Hanlon A/K/ A Lisa Hanlon Wllmelm Atty.: Daniel Schmieg DESCRIPTION ALL that certain tract in the Town- ship of Hampden, County of Cum- berland. Commonwealth of Penn- sylvania. more particularly bounded and described as follows. to wit: BEGINNING at a point on the East side of Courtland Street, which point Is 212 feet Westwardly and Southwardly from the Southwesterly corner of Courtland Street and Hampden Avenue, said point being also at the division lines of Lots Nos. 160 and 161; thence South 73 de- grees 12 minutes East along said division line eighty five and thtrty- four hundredths (85.34) feet to a point at the division lines of Lots Nos. 158 and 161: thence South 20 degrees 01 minute East along said division lines sixty-four and twelve hundredths {64.12} feet to a point at the division lines of Lots Nos. 161 and 162; thence South 69 degrees 55 minutes West along said division line eighty-eight and nine hun- dredths (88.09) feet to a point on the Eastern side of Courtland Street: thence North 20 degrees 39 min- utes West along the aforementioned Courtland Street fifty-one and thlrty- eight hundredths (51.38) feet to a pOl-nt; thence continuing al~ng Courtland Street in a arc to the nght with a radius of one hundred five and seventy-eighty hundredths 005.78) feet the arc distance of sixty-seven and thirty-nine hun- dredths (67.39) feet to a point the PLACE OF BEGINNING. IT BEING Lot No. 161 on Gen- eral Plan of Section 2 and 3 Clear- view Farms, which plan is recorded in Plan Book 9. Page 6, Cumberland County. HAVING thereon erected a split- level brick and frame dwelling house know as 4704 Courtland Street. BEING part of the same tract of ground which Nelson Improvement and Development Corporation by Deed dated the 15th day of August 1960, and recorded in and for the County of Cumberland in Deed Book 2, Volume 19, Page 40, granted and conveyed unto Robert H. Snyder and Patricia J, Snyder, his wife of Hampden Township, who are both now deceased. AND the Grantors will warrant specially the property hereby con- veyed. Being Parcel # 10-21-0279-144. RECORD OWNER TITLE TO SAID PREMISES IS VESTED IN Douglas E. Wllhelm, Junior, and Lisa H. Wilhelm, hus- band and wife, by Deed from Rob- ert H. Snvder and Knstv L. Kessler, Executors of the Estate of Patricia J. Snyder, dated 12-30-97, re- corded 1-2-98 in Deed Book 170, page 265. Premises: 4704 Courtland Street, Camp Hill, PA 17011.