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HomeMy WebLinkAbout05-3220IN THE COURT OF COMMON PLEAS OF CUMBERLAND COUNTY, PENNSYLVANIA CIVIL DIVISION CAPITAL ONE BANK Plaintiff VS. DEBBIE M SEELING AKA DEBBIE M THIPAVONG Defendant No: bS - COMPLAINT IN CIVIL ACTION FILED ON BEHALF OF Plaintiff COUNSEL OF RECORD OF THIS PARTY: James C. Warmbrodt,42524 WELTMAN, WEINBERG & REIS CO., L.P.A. 436 Seventh Avenue, Suite 2718 Pittsburgh, PA 15219 (412) 434-7955 FAX: 412-338-7130 04219827 C A Pit KMJ IN THE COURT OF COMMON PLEAS OF CUMBERLAND COUNTY, PENNSYLVANIA CIVIL DIVISION CAPITAL ONE BANK Plaintiff VS. Civil Action No DEBBIE M SEELING Defendant COMPLAINT AND NOTICE TO DEFEND 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 an attorney and filing in writing with the court your defenses or objections to the claims set forth against you. You are warned that if you fail to do so the case may proceed without you and a judgment may be entered against you by the court without further notice for any money claimed in the complaint or for any other claim or relief requested by the plaintiff. You may lose money or property or other rights important to you. YOU SHOULD TAKE THIS PAPER TO YOUR LAWYER AT ONCE. IF YOU DO NOT HAVE A LAWYER OR CANNOT AFFORD ONE, GO TO OR TELEPHONE THE OFFICE SET FORTH BELOW TO FIND OUT WHERE YOU CAN GET LEGAL HELP. 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. LAWYER REFERRAL SERVICE CUMBERLAND COUNTY BAR ASSOCIATION 32 SOUTH BEDFORD STREET CARLISLE, PA 17013 (717) 249-3166 COMPLAINT 1. Plaintiff, CAPITAL ONE BANK is a corporation with offices at 6851 JERICHO TURNPIKE #190 SYOSSET , NY 11791 . 2. Defendant is an adult individual(s) residing at the address listed below: DEBBIE M SEELING 415 FAIRWAY DR MECHANICSBURG, PA 17055 3. Defendant applied for and received a credit card bearing the account number 4121741612346879 4. Defendant made use of said credit card and has a current balance due of $1924.94 , as of June 01, 2005 . 5. Defendant is in default by failing to make monthly payments when due. As such, the entire balance is immediately due and payable to Plaintiff. 6. Plaintiff is entitled to the addition of interest at the rate of 6.000% per annum on the unpaid balance from June 01, 2005 7. Although repeatedly requested to do so by Plaintiff, Defendant has willfully failed and/or refused to pay the balance due to Plaintiff. Wherefore, the Plaintiff prays for judgment in its favor and against Defendant , DEBBIE M SEELING , individually , in the amount of $1924.94 with continuing interest thereon at the rate of 6.00000 per annum from June 01, 2005 plus costs. v - x /Z V 1Z Jame C. W rmbrodt,42 4 WEL WEINBERG & REIS CO., L.P.A. 43 eventh Avenue, Suite 2718 P't burgh, PA 15219 434-7955 412-338-7130 4219827 C A Pit KMJ This law firm is a debt collector attempting to collect this debt for our client and any information obtained will be used for that purpose. VERIFICATION The undersigned does hereby verify subject to the penalties of 18 Pa. C.S. §4904 relating to unsworn falsification to authorities, that he is an attorney for the Plaintiff herein and makes this Verification based upon the facts as supplied to his by the Plaintiff because the Plaintiff is outside the jurisdiction of the court and the Plaintiffs Verification cannot be obtained within the time allowed for the filing of this pleading; and that the facts and circumstances set forth in this pleading, are true and correct to the best of his knowledge, information and belief. V 14 crz -KJ ?j cn hJ W T n.? T -1 T -? m ?. C: i it SHERIFF'S RETURN - REGULAR CASE NO: 2005-03220 P COMMONWEALTH OF PENNSYLVANIA: COUNTY OF CUMBERLAND CAPITAL ONE BANK VS SEELING DEBBIE M AKA DEBBIE M BRYAN WARD Sheriff or Deputy Sheriff of Cumberland County,Pennsylvania, who being duly sworn according to law, says, the within COMPLAINT & NOTICE was served upon SEELING DEBBIE M AKA DEBBIE M THIPAVONG the DEFENDANT , at 1815:00 HOURS, on the 28th day of June 2005 at 415 FAIRWAY DR MECHANICSBURG, PA 17055 by handing to CASSANDRA THIPAVONG, DAUGHTER a true and attested copy of COMPLAINT & NOTICE together with and at the same time directing Her attention to the contents thereof. Sheriff's Costs: Docketing 18.00 Service 6.66 Affidavit .00 Surcharge 10.00 .00 34.66 Sworn and Subscribed to before me this day of A. D. rothonotary So Answers: R. Thomas Kline 06/29/2005 WELTMAN WEINBERG REIS l By: K n, lll Depu Sheriff IN THE COURT OF COMMON PLEAS CUMBERLAND COUNTY, PENNSYLVANIA CIVIL DIVISION CAPITAL ONE BANK, Plaintiff VS. DEBBIE M. SEELING Defendant TO THE PROTHONOTARY: Civil Action No. 2005-3220 PRAECIPE FOR DEFAULT JUDGMENT Kindly enter Judgment against the Defendant, DEBBIE M. SEELING above named, in the default of an Answer, in the amount of $1938.91 computed as follows: Amount claimed in Complaint $1924.94 Interest from June 1, 2005 at the legal interest rate of 6% per annum $13.97 TOTAL $1938.91 I hereby certify that appropriate Notices of Default, as attached have been mailed in accordance with PA R.C.P. 237.1 on the dates indicated on the Notices. W EL: PMAN, W EIN BERG & REIS CO., By: James PA 1. W EL 271$/ Esquire YMA , WEINBERG & REIS CO op ers Building e nth Avenue ?Mtgh, PA 15219 434-7955 #04219827 L.P.A. Plaintiff's address is: c/o Weltman, Weinberg & Reis Co., L.P.A., 2718 Koppers Building, 436 71h Avenue, Pittsburgh, PA 15219 And that the last known address of the Defendant is: 415 FAIRWAY DR MECHANICSBURG,PA 17055 V IN THE COURT OF COMMON PLEAS CUMBERLAND COUNTY, PENNSYLVANIA CIVIL DIVISION CAPITAL ONE BANK, Plaintiff DEBBIE M. SEELING Defendant 2005-3220 IMPORTANT NOTICE TO: DEBBIE M SEELING 415 FAIRWAY DR MECHANICSBURG,PA 17055 Date of Notice: July 25, 2005 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 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. LAWYER REFERRAL SERVICE CUMBERLAND COUNTY BAR ASSOCIATION 32 SOUTH BEDFORD STREET CARLISLE, PA 17013 (717) 249-3166 WELTMAN, WEINBERG & REIS CO., L.P.A By: ?i William Molczan, Eouire // PA I. D. #76014 (/ WELTMAN, WEINBERG & REIS CO., L.P.A. 2718 Koppers Building 436 Seventh Avenue Pittsburgh, PA 15219 (412) 434-7955 WWR #04219827 Request for Military Status Page 1 of I Department of Defense Manpower Data Center AUG-18-2005 06:01:21 Military Status Report Pursuant to the Service Members' Civil Relief Act -47 Last Name First/Middle Begin Date Active Duty Status Service/Agency SEELING Based on the information you have furnished, the DMDC does not possess any information indicating that the individual is currently on active duty Upon searching the information data banks of the Department of Defense Manpower Data Center, the above is the current status of the individual, per the Information provided, as to all branches of the Military. Robert J. Brandewie, Director Department of Defense - Manpower Data Center 1600 Wilson Blvd., Suite 400 Arlington, VA 22209-2593 The Defense Manpower Data Center (DMDC) is an organization of the Department of Defense that maintains the Defense Enrollment and Eligibility Reporting System (DEERS) database which is the official source of data on eligibility for military medical care and other eligibility systems. The Department of Defense strongly supports the enforcement of the Service Members Civil Relief Act [50 USCS Appx. §§ 501 et seq] (SCRA) (formerly the Soldiers' and Sailors' Civil Relief Act of 1940). DMDC has issued hundreds of thousands of "does not possess any information indicating that the individual is currently on active duty" responses, and has experienced a small error rate. In the event the individual referenced above, or any family member, friend, or representative asserts in any manner that the individual is on active duty, or is otherwise entitled to the protections of the SCRA, you are most strongly encouraged to contact us by Fax at (703-696-4156) or by phone at (703-696-6762). We will then conduct further research. Your failure to re-contact DMDC may cause provisions of the SCRA to be invoked against you. This response reflects current active duty status only. For historical information, please contact the military services SCRA point of contact. See: In //www.defenselink.mil/faq is PC09SLDR.htm1. Report ID. BKNOYTVRLBZ https://www.dmdc.osd-mil/scra/owa/scra.prc_Select 8/18/2005 IN THE COMMON PLEAS COURT OF CUMBERLAND COUNTY, PENNSYLVANIA CIVIL DIVISION CAPITAL ONE BANK Plaintiff vs. DEBBIE M. SEELING Defendant Case no: 2005-3220 NON-MILITARY AFFIDAVIT The undersigned, who first being duly sworn, according to law, deposes and states as follows: That he/she is the duly authorized agent of the Plaintiff in the within matter. Affiant further states that the within Affidavit is made pursuant to and in accordance with the Servicemembers' Civil Relief Act (SCRA), 50 U.S.C. App. § 521. Affiant further states that based upon investigation it is the affiant's belief that the Defendant, DEBBIE M. SEELING is not in the military service. Affiant further states that this belief is supported by the attached certificate from the Defense Manpower Data Center (DMDC), which states that the Defendant, DEBBIE M. SEELING is not in the military service. Further Affiant sayeth naught. A"FIA / SWOR l ND B CRS ED jl my presence thi&day of ?t n( J// This law firm is a debt collector attempting to collect this debt for our client and any information obtained will be used for that purpose. Rf ? n V c n C n? i- T (? 5 n? lJ --I T ? fill. U rTl a IN THE COURT OF COMMON PLEAS CUMBERLAND COUNTY, PENNSYLVANIA CIVIL DIVISION CAPITAL ONE BANK, Plaintiff vs. Civil Action No. 2005-3220 DEBBIE M. SEELING Defendant NOTICE OF JUDGMENT OR ORDER TO: ( ) Plaintiff (xx) Defendant ( ) Garnishee You are hereby notified that the following Order X Judgment was enteredLagainst you (xx) Assumpsit Judgment in the amount of$1938.91 plus costs. ( ) Trespass Judgment in the amount of$____ plus costs. ( ) If not satisfied within sixty (60) days, your motor vehicle operator's license and/or registration will be suspended by the Department of Transportation, Bureau of Traffic Safety, Harrisburg, PA. (xx) Entry of Judgment of ( ) Court Order ( ) Non-Pros ( ) Confession (xx) Default ( ) Verdict ( ) Arbitration Award Prothonotary By: PROT OTARY(OR DEBBIE M SEELING 415 FAIRWAY DR MECHANICSBURG,PA 17055 Plaintiffs address is: C/O Weltman, Weinberg & Reis Co., L.P.A., 2718 Koppers Building, 436 7`" Avenue, Pittsburgh, PA 15219 1-888-434-0085 First Nationwide Mortgage Corp. VS James Hoover and Linda Hoover The Court of Common Pleas of Cumberland County, Pennsylvania Writ No. 2001-3220 Civil Term Sharon Lantz, Deputy Sheriff, who being duly sworn according to law, states that on June 22, 2005 at 5:46 o'clock PM, she 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 defendants, to wit: James C. Hoover and Linda L. Hoover, by making known unto Linda Hoover, personally and wife of James C. Hoover, at 329 15th Street, New Cumberland, Cumberland County, Pennsylvania, its contents and at the same time handing to her personally the said true and correct copy of the same. Gerald Worthington, Deputy Sheriff, who being duly sworn according to law, states that on July 07, 2005 at 4:54 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 James C. Hoover and Linda L. Hoover, located at 329 15th Street, New Cumberland, 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 defendants, to wit: James C. Hoover and Linda L. Hoover, by regular mail to their last known address of 329 15th Street, New Cumberland, PA 17070. These letters were mailed under the date of July 05, 2005 and never returned to the Sheriffs Office. R. Thomas Kline, Sheriff, who being duly sworn according to law, states this writ is returned STAYED per instructions from Attorney Joseph Goldbeck. Sheriffs Costs: Docketing 30.00 Poundage 435.30 Advertising 15.00 Posting Handbills 15.00 Mileage 27.20 Certified Mail 1.75 Levy 15.00 Surcharge 30.00 Postpone Sale 20.00 Prothonotary 1.00 00 CkA 57ND Law Journal 263.00 Patriot News 248.39 Share of Bills 18.20 $1119.84 Sworn and subscribed to before me This _10 11 day of ?0?CA'( 2005, A.D. Prothonotary So s s ?? R. Thomas Kline, Sheriff BY Ja ? Real Estate rgeant ).ov?/8l? Goldbeck McCafferty & McKeever BY: Joseph A. Goldbeck, Jr. Attorney I.D. #16132 Suite 5000 - Mellon Independence Center 701 Market Street Philadelphia, PA 19106-1532 215-627-1322 Attorney for Plaintiff FIRST NATIONWIDE MORTGAGE CORPORATION PO Box 9481 Mail Code: 22-528-1011 Gaithersburg, MD 20898-9481 vs. JAMES HOOVER LINDA HOOVER (Mortgagor(s) and Record Owner(s)) 329 15th Street New Cumberland, PA 17070 IN THE COURT OF COMMON PLEAS Plaintiff of Cumberland County CIVIL ACTION - LAW ACTION OF MORTGAGE FORECLOSURE Defendant(s) No. 0l -3220-CIVIL AFFIDAVIT PURSUANT TO RULE 3129 FIRST NATIONWIDE MORTGAGE CORPORATION, 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 329 15th Street New Cumberland, PA 17070 1.Name and address of Owner(s) or Reputed Owner(s): JAMES HOOVER 329 15th Street New Cumberland, PA 17070 LINDA HOOVER 329 15th Street New Cumberland, PA 17070 ^. Name and address of Defendant(s) in the judgment: JAMES HOOVER 329 15th Street New Cumberland, PA 17070 LINDA HOOVER 329 15th Street New Cumberland, PA 17070 3. Name and last known address of every judgment creditor whose judgment is a record lien on the property to be sold: DOMESTIC RELATIONS OF CUMBERLAND COUNTY PO Box 320 01-3220-CIVIL GOLDBECK McCAFFERTY & McKEEVER BY: Joseph A. Goldbeck, Jr. Attomey I.D.# 16132 Suite 5000- Mellon Independence Center 701 Market Street Philadelphia, PA 19106 215-627-1322 Attorney for Plaintiff FIRST NATIONWIDE MORTGAGE CORPORATION PO Box 9481 Mail Code: 22-528-1011 Gaithersburg, MD 20898-9481 Plaintiff Vs. JAMES HOOVER LINDA HOOVER Mortgagor(s) and Record Owner(s) 329 15th Street New Cumberland, PA 17070 of Cumberland County CIVIL ACTION - LAW ACTION OF MORTGAGE FORECLOSURE Term No. 01-3220-CIVIL THIS LAW FIRM IS A DEBT COLLECTOR AND NYE 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: HOOVER, JAMES JAMES HOOVER 329 15th Street New Cumberland, PA 17070 Your house at 329 15th Street, New Cumberland, PA 17070 is scheduled to be sold at Sheriffs Sale on Wednesday, September 07, 2005, at 10:00 AM, in Commissioners Hearing Rai 2nd FL Courthouse to enforce the court judgment of $21,056.51 obtained by FIRST NATIONWIDE MORTGAGE CORPORATION 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: IN THE COURT OF COMMON PLEAS 1. The sale will be cancelled if you pay to FIRST NATIONWIDE MORTGAGE CORPORATION, the back payments, late charges, costs and reasonable attorney's fees due. To find out how much you must pay call: 215-627-1322 01-3220-CIVIL 2. You maybe 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 within thirty (30) days from the date of the Sheriffs Sate. 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. LEGAL SERVICES INC 8 Irvine Row Carlisle, PA 17013 CUMBERLAND COUNTY BAR ASSOCIATION 2 Liberty Avenue Carlisle, PA 17013 01-3220-CIVIL GOLDBECK McCAFFERTY & Mcl EVER BY: Joseph A. Goldbeck, Jr. Attorney I.D.#16132 Suite 5000- Mellon Independence Center 701 Market Street Philadelphia, PA 19106 2L5-627-1322 Attorney for Plaintiff FIRST NATIONWIDE MORTGAGE CORPORATION PO Box 9481 Mail Code: 22-528-1011 Gaithersburg, MD 20898-9481 IN THE COURT OF COMMON PLEAS of Cumberland County Plaintiff Vs. JAMES HOOVER LINDA HOOVER Mortgagor(s) and Record Owner(s) 329 15th Street New Cumberland, PA 17070 CIVIL ACTION - LAW ACTION OF MORTGAGE FORECLOSURE Term No. 01-3220-CIVIL 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: HOOVER, LINDA LINDA HOOVER 329 15th Street New Cumberland, PA 17070 Your house at 329 15th Street, New Cumberland, PA 17070 is scheduled to be sold at Sheriffs Sale on Wednesday, September 07, 2005, at 10:00 AM, in Commissioners Hearing Rm 2nd FL Courthouse to enforce the court judgment of $21,056.51 obtained by FIRST NATIONWIDE MORTGAGE CORPORATION 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: I. The sale will be cancelled if you pay to FIRST NATIONWIDE MORTGAGE CORPORATION, the back payments, late charges, costs and reasonable attorney's fees due. To find out how much you must pay call: 215-627-1322 01-3220-CIVIL, 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 sate 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 within 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. LEGAL SERVICES INC 8 Irvine Row Carlisle, PA 17013 CUMBERLAND COUNTY BAR ASSOCIATION 2 Liberty Avenue Carlisle, PA 17013 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 First Nationwide Mortgage Corp. P.O. Box 9481, Mail Code: 22-528-1011 Gaithersburg, MD 20898-9481 Vs. John O. Osgood (Mortgagor only) Susan C. Osgood (Mortgagor only) 52 Catoctin Court Silver Springs, MD 20906 James Hoover (Real Owner only) Linda Hoover (Real owner only) 329 15th Street New Cumberland, PA 17070 ATTORNEY FOR PLAINTIFF CUMBERLAND COUNTY COURT OF COMMON PLEAS CIVIL DIVISION NO 01-3220-Civil ALL THAT CERTAIN lot or tract of land situate in the Borough of New Cumberland, County of Cumberland and State of Pennsylvania, more particularly bounded and described as follows according to a survey of D.P. Raffensperger (49-29) dated March 4, 1974, to wit: BEGINNING at a point on the Northern side of 15th Street said point being 870.6 feet west of Bridge Street; thence extending along 15th Street South 62 degrees West 50 feet to a corner of lot number 30 on the hereinafter mentioned plan of lots; thence along lot number 30 north 28 degrees West 195 feet to a point a corner; thence North 62 degrees East 50 feet to a point a corner; thence extending through lot number 31 on said plan South 28 degrees East 195 feet to the point and place of BEGINNING. Being a part of lot number 31 Section E plan of Hillside as recorded in the Cumberland County Recorder's Office in Plan Book 1, page 75. Having thereon erected a two story frame dwelling and detached frame garage known as 329 15th Street. Tax Parcel #26-23-0541-133 WRIT OF EXECUTION and/or ATTACHMENT COMMONWEALTH OF PENNSYLVANIA) NO 01-3220 Civil COUNTY OF CUMBERLAND) CIVIL ACTION - LAW TO THE SHERIFF OF CUMBERLAND COUNTY: To satisfy the debt, interest and costs due FIRST NATIONWIDE MORTGAGE CORPORATION, Plaintiff (s) From JAMES HOOVER AND LINDA HOOVER (1) You are directed to levy upon the property of the defendant (s)and to sell SEE LEGAL DESCRIPTION (2) You are also directed to attach the property of the defendant(s) not levied upon in the possession of GARNISHEE(S) as follows: and to notify the gamishee(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 $21,056.51 L.L. Interest FROM 9112/01 AT 0.0100% Any's Comm % Due Prothy $1.00 Arty Paid $1486.40 Other Costs Plaintiff Paid Date: JUNE 8, 2005 CURTIS R. LONG Prothonotary (Seal) By: , - P Deputy REQUESTING PARTY: Name JOSEPH A. GOLDBECK, JR., ESQUIRE Address: SUITE 5000 - MELLON INDEPENDEN CE CENTER 701 MARKET STREET PHILADELPHIA, PA 19106-1532 Attorney for: PLAINTIFF Telephone: 215-627-1322 Supreme Court ID No. 16132 ,ClndaQ Isg Iuo2I SooZ `£I aunf .al>?Q •ula.zaq palezodaout aaua.ta3az sty Kq pue Ilion sigl glim palg «V„ ITgrgxg uo paquasap Xlln3 aaouz `pu>?ltaquznD maN Q `IaazlS T9I 6Z£ sz pa.taquznu pur umoux CR c"M dd `SIunoD put?laaquzn3 `q$notog puslaagwnD maN ?J 02 ut pal7anIls Cltadojd I>;at aql ut Isatalut s,luspu23ap aql uodn patn31 33?.IagS aql SooZ `£I aunf uo 8 E -b V 6 - Na go, 99# alts alelsg Iia?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 on the 19th and 26th day(s) of July and the 2nd day(s) of August 2005. That neither he nor said Company is interested in the subject [natter 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 Miscellaneou ook "M", Volume 14, Page 317. PUBLICATION \il6iJT?iX??°?? o1 COPY Sworn to and subsc be before mts th day of Au???ssst 20 A.`Pd 9Ga o SALE #66 // L ey??? ?'oy ®, NOTARY PUBLIC °°02- ,y My commission expires June 6, 2006 CUMBERLAND COUNTY SHERIFFS OFFICE CUMBERLAND COUNTY COURTHOUSE CARLISLE, PA. 17013 Statement of Advertising Costs To THE PATRIOT-NEWS CO. For publishing the notice or publication attached hereto on the above stated dates 248.39 REAL ESTATE SALE No. 66 Writ No. 20D1-3220 Civil Term First Nationwide Mortgage Corp. Vs James Hoover and Linde Hoover Atty: Joseph Goldbeck DESCRIPTION ALL THAT CERTAIN lot or tract of laud situate in the Borough of New Cumberland, County of Cumberland and State of Peno-sylvaum same particularly, bounded and described as follows accorc[mg to a survey of DP. Ratfenspergm (49- 29)datedMarch 4,1974,mwa BEGINNING at a point ou the Northern side of 15th Street said poim.beiog 8708 fed West of Bridge Suit; thence extending along 15th Street South 62 degrees West 50 feet to a rouser of lot number 30 on the hereinafter m momared plan of Iots; thence thing lot number 30 North 28 degrees Wes f95 fain a pass a new, d•ooc *A 62 deem Eut 50 fast to a poet a corm, ire esariog thtayY In r®1 31 on rout Mfr Saoh 21 dgmr EW 195 feet to the poht ad placeofBIDGINNING. BBPIG a pat of lot number 31 Seetion B plr of Hillside as recorded in the Cumberland County Recorder's Office in Ran Book 1, page 75. HAVING mereoo erected a two story frame dwelling and demchdl frame garage known as 329 15th Sneer. Tax Parcel #2623-054-133. PROOF OF PUBLICATION OF NOTICE IN CUMBERLAND LAW JOURNAL (Under Act No. 587, approved May 16, 1929), P. L.1784 COMMONWEALTH OF PENNSYLVANIA COUNTY OF CUMBERLAND ss. 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, July 15, 22, 29, 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. before me this LOIS E. SNYDER, Notary Public Carlisle Boro, Cumberland County My Commission Expires March 5,2W9 29 clay of July. 2005 REAL ESTATE SALE NO. 88 Writ No. 2001-3220 Civil First Nationwide Mortgage Corp. vs. James Hoover and Linda Hoover Atty.: Joseph Goldbeck ALL THAT CERTAIN lot or tract of land situate in the Borough of New Cumberland, County of Cumberland and State of Pennsyl- vania, more particularly bounded and described as follows according to a survey of D.P. Raffensperger (49-29) dated March 4, 1974, to wit: BEGINNING at a point on the Northern side of 15th Street said point being 870.8 feet west of Bridge Street; thence extending along 15th Street South 62 degrees West 50 feet to a corner of lot num- ber 30 on the hereinafter mentioned plan of lots; thence along lot num- ber 30 north 28 degrees West 195 feet to a point a corner; thence North 62 degrees East 50 feet to a point a corner; thence extending through lot number 31 on said plan South 28 degrees East 195 feet to the point and place of BEGINNING. Being a part of lot number 31 Section E plan of Hillside as re- corded in the Cumberland County Recorder's Office in Plan Book 1, page 75. Having thereon erected a two story frame dwelling and detached frame garage known as 329 15th Street. Tax Parcel #26-23-0541-133. IN THE COURT OF COMMON PLEAS OF CUMBERLAND COUNTY, PENNSYLVANIA CIVIL DIVISION CAPITAL ONE BANK Plaintiff VS. DEBBIE M SEELING - AKA DEBBIE SEELING Defendant No. 05-3220 PRAECIPE FOR SATISFACTION OF JUDGMENT FILED ON BEHALF OF Plaintiff COUNSEL OF RECORD OF THIS PARTY: PATRICK THOMAS WOODMAN, Esquire PA. I.D.#42524 WELTMAN, WEINBERG & REIS CO., L.P.A. 2718 Koppers Building 436 Seventh Avenue Pittsburgh, PA 15219 (412) 434-7955 WWR#04219827 A' IN THE COURT OF COMMON PLEAS CUMBERLAND COUNTY, PENNSYLVANIA CIVIL DIVISION CAPITAL ONE BANK Plaintiff vs. DEBBIE M SEELING - AKA DEBBIE SEELING Defendant Civil Action No. 05-3220 PRAECIPE FOR SATISFACTION OF JUDGMENT At the request of the undersigned attorneys for the Plaintiff, you are directed to satisfy the above-captioned Judgment. Sworn to and subibed before me this day of Ju , 07 NO ARY PU IC WELTMAN, WEINBERG & REIS CO., L.P.A. By: ?Q.- owta•t G ?rr4,e?-_ PATRICK THOMAS WOODMAN, Esquire PA. I.D.#42524 WELTMAN, WEINBERG & REIS CO., L.P.A. 2718 Koppers Building 436 Seventh Avenue Pittsburgh, PA 15219 (412) 434-7955 WWR #04219827 00NIM0NW@ T P Is NNSY VANIA Notarial seal Wayne A Jones, Notary public -¢ Pittsburgh. Alleghany Cc° nmitssion E)ires June M Pennsylvania Association o. es