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Home My WebLink About05-4000 McCABE, WEISBEREh\NB €ONWAY, P.C. BY: TERRENCE J. McCABE, ESQUIRE Identification Number 16496 123 South Broad Street, Suite 2080 Philadelphia, Pennsylvania 19109 215 790-1010 Centex Home Equity Corporation n/dlb/a Centex Home Equity Company, LLC 350 Highland Drive Lewisville, TX 75067 v, Terry E. Hill 59 Glendale Drive Mechanicsburg, PAl 7050 and Bobbie J. Hill 59 Glendale Drive Mechanicsburg, P A 17050 u Attorney for Plaintiff Cumberland County Court of Common Pleas Number os- - J.j OPD ~~ CIVIL ACTlONIMORTGAGE FORECLOSURE NOTICE You have been sued in court. If you wish to defend against the claims set forth in the following pages, you. rtn..lSt take action within twenty (20) days after this complaint and notice are served, by entering a written appearance personally or by attorney and filing in writing with the court your defenses or objections to the claims set forth against you. You are warned that if you fail to do so the case may proceed without you and a judgment may be entered against you by the court without further notice for any money Claimed in the complaint or for any other claim or relief requested by the plaintiff. You way lose rroney or property or other rights important to you. YOU SHOULD TAKE THIS PAPER TO YOUR LAWYER AT ONCE. IF YOU DO NOT HAVE A LAWYER, GO TO OR TELEPHONE THE OFFICE SET FORTH BELOW, THIS OFFICE CAN PROVIDE YOU WITH INFORMATION ABOUT HIRING A LAWYER. IF YOU CANNOT AFFORD TO HIRE A LA WYER, THIS OFFICE MAY BE ABLE TO PROVIDE YOU WITH INFORMATION ABOUT AGENCIES THA TMA Y OFFER LEGAL SERVICES TO ELIGIBLE PERSONS AT A REDUCED FEE OR NO FEE. Cumberland County Bar Association 2 Liberty Avenue Carlisle, PA, 17013 800-990-9108 AVISO Le han demandado a listed en la corte. 81 usted quiere defenderse de estas demandas ex-puestas en las paginas siguientes, usted tiene veinte (20) dias de plazo al partir de la fecha de la demanda y la notificacion. Hace falta asentar una ccmparencia escrita 0 en persona 0 con un abogado y entregar a la corte en fonna escrita sus defensas 0 sus obj eciones alas demandas en contra de su persona. Sea avisado que si usted no se defiende, la corte tomara. medidas y puede continuar la demanda en contra suya sin previa aviso 0 notificacion. Ademas, la corte puede decidir a favor del demandante y reguiere que usted cumpla con todas las provisiones de esta demanda. Usted puede perder dinero 0 sus propiedades U otros derechos importantes para listed. USTED LE DEBE TOMAR ESTE PAPEL A SU ABOGADO INMEDIA T AMENTE. SI USTED NO TIENE A UN ABOGADO. V A A 0 TELEFONEA LA OFICINA EXPUSO ABAJO, ESTA OFICINA LO PUEDE PROPORCIONAR CON INFORMATION ACERCA DE EMPLEAR A UN ABOGADO, SI USTED NO PUEDE PROPORCIONAR PARA EMPLEAR UN ABOGADO, EST A OFICINA PUEDE SER CAPAZ DE PROPORCIONARLO CON INFORMACION ACERCA DE LAS AGENCIAS QUE PUEDEN OFRECER LOS SERVICIOS LEGALES A PERSONAS ELEGIBLES EN UN HONORARIO REDUClDO NI NINGUN HONORARIO, Cumberland County Bar Association 2 Liberty Avenue carlisle, PA, 17013 800-990-9108 -1"- -~ ~ McCABE, WEISBERG AND CONWAY, P.c. BY: TERRENCE J. McCABE, ESQUIRE Identification Number 16496 123 South Broad Street, Suite 2080 Philadelphia, Pennsylvania 19109 215 790-1010 Attorney for Plaintiff Centex Home Equity Corporation nld/b/a Centex Home Equity Company, LLC 350 Highland Drive Lewisville, TX 75067 Cumberland County Court of Common Pleas v, Terry E, Hill 59 Glendale Drive Mechanicsburg, P A 17050 and Bobbie 1. Hill S9 Glendale Drive Mechanicsburg, PAl 7050 Number CIVIL ACTIONfMORTGAGE FORECLOSURE I. Plaintiffis Centex Home Equity Corporation nldIb/a Centex Home Equity Company, LLC, a corporation duly organized and doing business at the above captioned address. 2, The Defendant is Terry E. Hill, who is one of the mortgagors and real owners of the mortgaged property hereinafter described, and his last-known address is 59 Glendale Drive, Mechanicsburg, P A 17050, 3. The Defendant is Bobbie 1. Hill, who is one of the mortgagors and real owners ofthe mortgaged property hereinafter described, and her last-known address is 59 Glendale Drive, Mechanicsburg, P A 17050, 4. On 09/05/200l, mortgagors 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 1733, Page 1 85 l, 5, The premises subject to said mortgage is described in the legal description attached as Exhibit "A" and is known as 59 Glendale Drive, Mechanicsburg, PA 17050, 6. The mortgage is in default because monthly payments of principal and interest upon said mortgage due 04/15/2005 and each month thereafter are due and unpaid, and by the terms of said mortgage, upon default in such payments for a period of one month, the entire principal balance and all interest due thereon are collectible forthwith, 7. The following amounts are due on the mortgage: Principal Balance $ 122,402,27 Interest 03115/2005 through 07/27/2005 $ 4,979,93 (Plus $ 36,89 per diem thereafter) Attorney's Fee $ 6,120,11 Late Charges $ 556.59 Corporate Advances $ 20,00 Cost of Suit $ 225,00 Appraisal Fee $ 125,00 Title Search $ 200,00 GRAND TOTAL $ 134,628,90 8, 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 based on work actually performed, 9, Notice of Intention to Foreclose as required by Act 6 of 1974 (4l P,S, 9403) and notice required by the Emergency Mortgage Assistance Act of 1983 as amended under l2 P A Code Chapter 13, et seq" commonly known as the Combined Notice of Delinquency has been sent to Defendants by regular mail with a certificate of mailing and by certified mail, return receipt requested, WHEREFORE, Plaintiff demands Judgment against the Defendants in the sum of $134,628,90, together with interest at the rate of $36,89 per diem and other costs and charges collectible under the mortgage and for the foreclosure and sale of the mortgaged property. ~. ...... 0 ./ ' . J-..-:;,/ ~/ // h// ' ////.-'-. /;/;;% TERRENCE J. McCABE, ESQUIRE Attorney for Plaintiff VEIUFICATlON The undersigned, Terrence J. McCabe, Esquire, hereby certifies that he is the Attorney for the Plaintiff in the within action, and that he is authorized to make this verification and that the foregoing facts are true and correct to the best of his knowledge, information and belief and further states that false statements herein are made subject to the penalties of 1 8 P A.CS, 94904 relating to unsworn falsification to authorities, /" . / 2:;:~:/</ . _ ~. .//. Terrence J, McCa6~ -----., ---,,~ ALL THA. T CERT A.lN tract of land with improvements thereon situate in the Township of Silver Spring, County of Cwnberland, State of Pennsylvania, as follows: BEGINNING at a point at the southeast corner of the property of George W. Weigel, et we, and at the northeast comer of the property herein described, which point is marked with an angle iron; thence SOllth 02 degrees 59 minutes West and along the center line of a fann lane, a distance of296 feet to a stake, tllence North 86 degrees 55 minutes West and along the northern property line ofland of Helen M. Vogelsong, a distance of 400.80 feet to a point at an iron pin; thence North 02 degrees 00 minutes West, and along other lands of Helen M. Vogelsong, a distance of 265 feet to a point at the southern line of property of George W, Weigel, et llJ(.; thence North 88 degrees 45 minutes East and along the southern line ofproperty of George W, Weigel, et we, a distance of 425 feet to a jloint, the point and place ofBEGlNNlNG. CONT AlNlNG 2.654 acres ofland, E. b'b' ~ ,]. ~ l.~'i...' A ~. ~ - ~ l"':;; r:- J~- - -- SHERIFF'S RETURN - REGULAR CASE NO: 2005-04000 P COMMONWEALTH OF PENNSYLVANIA: COUNTY OF CUMBERLAND CENT EX HOME EQUITY CORP VS HILL TERRY E ET AL CPL. TIMOTHY REITZ , Sheriff or Deputy Sheriff of Cumberland County, Pennsylvania, who being duly sworn according to law, says, the within COMPLAINT - MORT FORE was served upon HILL BOBBIE J the DEFENDANT , at 2053:00 HOURS, on the 30th day of August 2005 at 93 CHERRY LANE CARLISLE, PA 17013 by handing to BOBIE HILL 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 6.00 12.00 .00 10.00 .00 28.00 So Answers: ~;...,..ct~' f" ,'c;::',."'" " A>"~9! "~.'...C~;:,'-"-<I-~-'; . R. Thomas Kline A.D. 09/01/2005 MCCABE WEISBERG CONWAY ~:tt- By: -' - . ..-4 . / ~ Dep t Sher" Sworn and Subscribed to before me this ell day of SHERIFF'S RETURN - REGULAR CASE NO: 2005-04000 P COMMONWEALTH OF PENNSYLVANIA: COUNTY OF CUMBERLAND CENTEX HOME EQUITY CORP VS HILL TERRY E ET AL SHARON LANTZ Sheriff or Deputy Sheriff of Cumberland County,Pennsylvania, who being duly sworn according to law, says, the within COMPLAINT - MORT FORE was served upon HILL TERRY E the DEFENDANT , at 1741:00 HOURS, on the 31st day of August , 2005 at 125 OAK FLAT ROAD NEWVILLE, PA 17241 by handing to TERRY HILL a true and attested copy of COMPLAINT - MORT FORE together with and at the same time directing His attention to the contents thereof. Additional Comments 59 GLENDALE DRIVE MECHICSBURG IS VACANT. Sheriff's Costs: Docketing Service Affidavit Surcharge 18.00 8.80 .00 10.00 .00 36.80 So Answers: ,-p~"'-C;~~~~"."""" ../~ ' ..,.. ....~~....:-C' ?-'<I-... ~'f ~ , , R. Thomas Kline A.D. 09/01/2005 MCCABE WEISBERG CONWAY BY'~ ~~. ./' epCaY~<SheriI Sworn and Subscribed to before J.1 day of me this , McCABE, WEISBERG AND CONWAY, P.C. . BY: TERRENCE J. McCABE, ESQUIRE Identification Number 16496 123 South Broad Street, Suite 2080 Philadelphia, PA 19109 (215) 790-1010 Attorney for Plaintiff Centex Home Equity Corporation nld/b/a Centex Home Equity Company, LLC Cumberland County Court of Common Pleas vs. Number 05-4000 Terry E. Hill Bobbie J. Hill ASSESSMENT OF DAMAGES AND ENTRY OF JUDGMENT TO THE PROTHONOTARY: Kindly enfer judgment by default in favor of Plaintiff and against Defendant in the above- captioned matter for failure to answer Complaint as required by Pennsylvania Rules of Civil Procedure and assess damages as follows: Principal Interest from 7/28/05 - 10/5/05 TOTAL $l34,628,90 $ 2.582.30 $137,2l1.20 ~ / ~ / ---1.'_-"'1"'t--L..--1..--1 eGo /l /71c &.-?-.... "-'(" TERRENCE J. McCABE, ESQUIRE AND NOW, this 7~ay of Del. , 2005, Judgment is entered in favor of Plaintiff, Centex Home Equity Corporation nld/b/a Centex Home Equity Company, LLC and against Defendant(s) Terry E. Hill and Bobbie J. Hill and damages are assessed in the amount of $137,2l 1.20, plus interest and costs. BY THE PROTHONOTARY: f}~- . 7 , McCABE, WEISBERG AND CONWAY, P.c. . BY: TERRENCE J. McCABE, ESQUIRE Identification Number 16496 123 South Broad Street, Suite 2080 Philadelphia, PA 19109 (215) 790-1010 Attorney for Plaintiff Centex Home Equity Corporation nld/b/a Centex Home Equity Company, LLC Cumberland County Court of Common Pleas vs. Number 05-4000 Terry E. Hill Bobbie J. Hill AFFIDAVIT OF NON-MILITARY SERVICE COMMONWEALTH OF PENNSYLVANIA: SS. COUNTY OF CuMBERLAND: The undersigned, being duly sworn according to law, deposes and says that the Defendant is not in the Military or Naval Service of the United States or its Allies, or otherwise within the provisions of the Soldiers' and Sailors' Civil Relief Act of Congress of 1940 as amended; and that the Defendant(s), Terry E. Hill and Bobbie J. Hill, is over eighteen (l8) years of age, and resides at 59 Glendale Drive, Mechanicsburg, P A 17050, -r-A'I/L.-(/~1 <:.&- ;), /11/''!".e~ TERRENCE J. McCABE, ESQUIRE Attorney for Plaintiff SWORN TO AND SUBSCRIBED BEFORE ME THIS 5th DAY OF Oct. , 2005, OTARYPUBLIC r""---"". -""''';'''-'-','''-'-.''___ (:.W1"'," . McCABE, WEISBERG AND CONWAY, P.e. . BY: TERRENCE J. McCABE, ESQUIRE Identification Nnmber 16496 123 South Broad Street, Suite 2080 Philadelphia, PA 19109 (215) 790-1010 Attorney for Plaintiff Centex Home Equity Corporation n/dIb/a Centex Home Equity Company, LLC Cumberland County Court of Common Pleas vs. Number 05-4000 Terry E. Hill Bobbie J. Hill CERTIFICATION I certify that the foregoing assessment of damages is for specified amounts alleged to be due in the Complaint and is calculable as a sum certain from the Complaint. I certify that written notice of the intention to file this Praecipe was mailed or delivered to the party against whom judgment is to be entered and to the attorney of record, if any, after the default occurred and at least ten (10) days prior to the date ofthe filing of the Praecipe. A true and correct copy of the notice pursuant to Pennsylvania Rule of Civil Procedure No. 237.1 is attached hereto and marked Exhibit "A". ~ J-c.<-~LL-9.,/j1/ ~./-<..... TERRENCE J. McCABE, ESQUIRE Attorney for Plaintiff SWORN TO AND SUBSCRIBED BEFORE ME THIS 5th DAY OF Oct. ,2005. ~.tru. tJJ 0 .~rcJ&t N TARYPUBLIC r-..... f c,.,:'Y~' c.TiTlSGir---, . 1'.",.,'jt';lPU::i:c f !,:j\';"'~7 ! ..-..:...,-.-.____.J VERIFICATION The undersigned, TERRENCE J. McCABE, ESQUIRE, hereby certifies that he is the attorney for the Plaintiff in the within action and that he is authorized to make this verification and that the foregoing facts are true and correct to the best of his knowledge, information and belief and further states that false statements herein are made subject to the penalties of 18 P A.C.S. Section 4909 relating to unsworn falsification to authorities. .----;:, /,-/~""1 L_<--' (2. /h. ~,J-<-. TERRENCE J. McCABE, ESQUIRE ~- OFFICE OF THE PROTHONOTARY COURT OF COMMON PLEAS Cumberland County Courthouse, Carlisle, P A 17013 Curt Long Prothonotary September 21,2005 To: Bobbie J. Hill 93 Cherry Lane, Carlisle" P A 17013 Centex Home Equity Corporation n/dIb/a Centex Home Equity Company, LLC vs. Terry E. Hill and Bobbie J. Hill Cumberland County Court of Common Pleas Number 05-4000 NOTICE, RULE 237.5 NOTICE OF PRAECIPE TO ENTER JUDGMENT BY DEFAULT IMPORTANT NOTICE You ARE IN DEFAULT BECAUSE YOU HAVE FAilED TO ENTER A WRITTEN APPEARANCE PERSONALLY OR BY AITORNEY AND FILE IN WRITING WITH THE COURT YOUR DEFENSES OR OBJECTIONS 'fa THE CLAIMS SET FORTH AGAINST YOU. UNLESS YOU ACT WITHIN TEN (10) DAYS FROM THE DATE OF THIS NOTICE, A JUDGMENT MAYBE ENTERED AGAiNST YOUWITHQUT A HEARING AND YOU MA V WSE VOUR 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 BBWW. THIS OFFICE CAN PROVIDE YOU WITH lNFORMATION ABOUT HIRING A LAWYER. IF VOU CANNOT AFFORD TOHIREA LAWYER, THIS OFFICE MAY BE ABLE TO PROVIDE YOU WITH INFORMATION ABOUT AGENCIES THATMA Y OFFER LEGAL SERVICES TO EUGIBLE PERSONS AT A REDUCED FEE OR NO FEE. Cumberland County Bar Association 2 Liberty A venue Carlisle,PA,17013 800-990-9108 TJM/rda NOTlFICACION IMPORTANTE USTED SE ENCUENTRA EN ESTADO DE REBELDIA POR NO HABER PRESENTADO UNA COMPARECENCIA ESCRlTA, VA SEA PERSONALMENTE 0 POR ABOGADO Y POR NO HABER RADICADO POR ESCRITO CON ESTE TRIBUNAL SUS DEFENSAS V OBJECIONES A LOS RECLAMQS FORMULADOS EN CONTRA SUYO. AL NO TOMAR LA ACCION DEBlDA DENTRO DE DIEZ (10) DIAS DE LA FECHA DE ESTA NOTlFlCACION, EL TRIBUNAL PODRA, SIN NECESIDAD DE COMPARECER VSTED EN CORTE U OIR PREUBA ALGUNA, DICTAR SENTENCIA EN SU CONTRA Y USTED PODRIA PERnER BIENES U OTROS DERECHOS IMPORT ANTES. USTED LE DEBE TOMAR ESTE PAPEL A SU ABOGADO JNMEDIATAMENTE. SI USTED NO TIENE A UN ABOGADO, VA A 0 TELEFONEA LA OFICINA EXl'USO ABAJO. ESTA OFICINA LO PUEDE PROPORCIONAR CON INFORMACI6N ACERCA DE EMPLEAR A UN ABOGADO. SI USTED NO PUEDE l'ROPORCIONAR PARA EMl'LEAR UN ABOGADO, EST A OFICINA PUEDE SER CAP AZ DE PROPORCIONARLO CON INFORMACI6N ACERCADE LAS AGENCIAS QUE PUEDEN OFRECER LOS SERVICIOS LEGALES A PERSONAS ELEGIBLES EN UN HONORARIO REDUClDO NI NINGUN HONORARIO. Cumberland County Bar Association . + 2 Liberty Avenue D \ Carlisle, P A, 17013 (v \'\ \ _j 800-990-91 08 ~ "; \ f\ \ Terrence J. McCabe, Esquire Attorney for Plaintiff McCABE, WEISBERG & CONWAY, P.C. 123 South Broad Street, Suite 2080 Philadelphia, Pennsylvania 19109 ~.... , OFFICE OF THE PROTHONOTARY COURT OF COMMON PLEAS Cumberland County Courthouse, Carlisle, PA 17013 Curt Long Prothonotary September 21,2005 To: Terry E. Hill 125 Oak Flat Road Newville" P A 17241 Centex Home Equity Corporation n/dIb/a Centex Home Equity Company, LLC vs. Terry E. Hill and Bobbie J. Hill Cumberland County Court of Common Pleas Number 05-4000 NOTICE, RULE 237.5 NOTICE OF PRAECIPE TO ENTER JUDGMENT BY DEF AUL T IMPORTANT NOTICE You ARE IN DEFAULT BECAUSE YOU HAVE FAILED TO ENTER A WRITTEN APPEARANCE PERSONALLY OR BY ATTORNEY AND FILE IN WRITING WITH THE COURT YOUR DEFENSES OR OBJECTIONS TO THE CLAIMS SET FORTH AGAINST YOU. UNLESS YOU ACT WITHIN TEN (10) DAYS FROM THE DA IE OF THIS NOTICE, A JUDGMENT MAYBE ENTERED AGAINSTYOUWITHQUT AHEARING AND YOU MAY LOSE YOUR PROPERTY OR onlER IMPORT ANT RIGHTS. YOU SHOULDT AKE THIS PAPER TO YOUR LA WYER AT ONCE. IF YOU DO NOT HAVE A LAWVER, 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 AGENCIESTHATMA Y OFFER LEGAL SERVICES TO EUGIBLE PERSONS AT A REDUCED FEE OR NO FEE. Cumberland County Bar Association 2 Liberty Avenue Carlisle, PA, 17013 800-990-9108 TJM/rda NOTlFlCACION IMPORTANTE USTED SE ENCUENTRA EN ESTAOO DE REBELDIA POR NO HABER PRESENTADO UNA COMPARECENCIA ESCRITA, YA SEA PERSONAlMENTE 0 POR ABOGADQ Y paR NO HABER RADICADO POR ESCRITO CON ESTE TRIBUNAL SUS DEFENSAS U OBJECIONES A LOS RECLAMOS FORMULADQS EN CONTRA SUVO. AL NO TOMAR LA ACCION DEBIDA DENTRO DE DIEZ (10) DIAS DE LA FECHA DE ESTA NOTIFICACION, EL TRIBUNAL PODRA, SIN NECESIDAD DE COMPARECER USTED EN CORTE U OIR PREUBA ALGUNA, DfCTAR SENTENCIA EN SU CONTRA Y USTED PODRIA PERnER BIENES U OTROS DERECHOS IMPORT ANTES. USTED LE DEBE TOMAR ESTE PAPEL A SU ABOGAOO INMEDIATAMENTE. SI USTED NO IlENE A UN ABOGADO, VA A 0 TELEFONEA LA OFICINA EXPUSO ABAJO. EST A OFICINA LO PUEDE PROPORCfONAR CON INFORMACION ACERCA DE EMPLEAR A UN ABOGADQ. Sr usrED NO PUEDE PROPORCIONAR PARA EMPLEAR UN ABOGADO, EST A OFICINA PUEDE SER CAP AZ DE PROPORCIONARLO CON INFORMACl6N ACERCADE LAS AGENCfAS QUE PUEDEN OFRECER LOS SERVICIOS LEGALES A PERSONAS ELEGIBLES EN UN HONORARIO REDUCIDO NJ NINGiJN HONORARIO. Cumberland County Bar Association 2 Liberty Avenue Carlisle, PA, 17013 800-990-9108 Terrence J. McCabe, Esquire Attorney for Plaintiff McCABE, WEISBERG & CONWAY, P.C. 123 South Broad Street, Suite 2080 Philadelphia, Pennsylvania 19109 G 0. -!a.. ~ ?':; ~ ~ Jl:. 0 0 "', - L C> c::~ 0 8 -- r- e':) G'" L" -n ~ "c.' c:> ::::! -0 -u C) --!-11 ~ -. rl1r-'-=' ~ - ~ I i--n (j-- -J C) G1 ;,"-) - ~ =~~ ;~;:t ~ -" ',:.;(') ':'? :;,)f'";i ?E c..) I" -< OFFICE OF THE PROTHONOTARY COURT OF COMMON PLEAS CUMBERLAND COUNTY COURTHOUSE, CARLISLE, PA 17013 Curtis R. Long Prothonotary To: Terry E. Hill 125 Oak Flat Road Newville, PA 17241 Centex Home Equity Corporation n/dIb/a Centex Home Equity Company, LLC Cumberland County Court of Common Pleas vs. Number 05-4000 Terry E. Hill Bobbie J. Hill NOTICE Pursuant to Rule 236, you are hereby notified that a JUDGMENT has been entered in the above proceeding as indicated below. I Judgment by Default ID/7/0S Money Judgment Judgment in Replevin Judgment for Possession If you have any questions concerning this Judgment, please call Terrence J. McCabe. Esquire at (215) 790-1010. OFFICE OF THE PROTHONOTARY COURT OF COMMON PLEAS CUMBERLAND COUNTY COURTHOUSE, CARLISLE, PA 17013 Curtis R. Long Prothonotary To: Bobbie J. Hill 93 Cherry Lane Carlisle, P A 17013 Centex Home Equity Corporation n/dIb/a Centex Home Equity Company, LLC Cumberland County Court of Common Pleas vs. Number 05-4000 Terry E. Hill Bobbie J. Hill NOTICE Pursuant to Rule 236, you are hereby notified that a JUDGMENT has been entered in the above proceeding as indicated below. ~ Judgment by Default ID/7/DS Money Judgment Judgment in Replevin Judgment for Possession If you have any questions concerning this Judgment, please call Terrence J. McCabe. Esquire at (215) 790-1010. IN THE COURT OF COMMON PLEAS OF CUMBERLAND COUNTY. PENNSYLVANIA CIVIL DIVISION FILE NO.: 05-4000 Civil Term Centex Home Equity Corporation n/dIb/a Centex Home Equity Company, LLC v. AMOUNT DUE: $137,211.20 Terry E. Hill Bobbie J. Hill INTEREST: from 10/6/05 - 3/8/06 $3.541.92 at $22.56 Per Diem ATTY'S COMM.: COSTS: TO THE PROTHONOTARY OF SAID COURT: The undersigned hereby certifies that the below does not arise out of a retail installment sale, contract, or account based on a confession of judgment, but if it does, it is based on the appropriate original proceeding filed pursuant to Act 7 of 1966 as amended; and for real property pursuant to Act 6 of 1974 as amended. PRAECIPE FOR EXECUTION Issue writ or execution in the above matter to the Sheriff of Cumberland County, for debt, interest and costs upon the following described property of the defendant(s) 59 Glendale Drive. Mechanicsbur~. PA 17050 (More fully described as attached) PRAECIPE FOR ATTACHMENT EXECUTION Issue writ of attachment to the Sheriff of CUMBERLAND County, for debt, interest and costs, as above, directing attachment against the above-named gamishee(s) for the following property (if real estate, supply six copies of the description; supply four copies of lengthy personalty list) and all other property of the defendant( s) in the possession, custody or control of the said gamishee( s). (Indicate) Index this writ against the gamishee( s) as a lis pendens against real estate of the defendant(s) described in the attached exhibit. DATE: /0/5175 { ( Signature: -;:---'" /H_<>M u_, f1 /1; r /i<.~':~ Print Name: TERRENCE J. McCABE, ESQUIRE Address: 123 S. Broad Street. Suite 2080 Philadelphia. PA 19109 Attorney for: Plaintiff Telephone: (215) 7901010 Supreme Court ill No. 16496 ~ 0 :f-1-~ ~ _ 90 \) \.fl C'\'\..a "'\> ~0 ~ ~ ~ 0 ':/- ~. L. ~ ~ r-- ~-k,. - , ~ \) \) \/ f& ^""" -\A.. _ (~9.J W - ..r: ~...c'0~v-~ ~ '~ ~ B 'g ~ % , ,\ '- '- ~ ~ ~~ '::'~ ~ ': ~ ~~; (:J C;;:,l -r1 >.',.X'''' o CC'. -, \ ....J -::; --;' '-.:: (....) \"') .------ WRIT OF EXECUTION and/or ATTACHMENT COMMONWEALTH OF PENNSYLVANIA) COUNTY OF CUMBERLAND) NO 05-4800 Civil CIVIL ACTION - LAW TO THE SHERIFF OF CUMBERLAND COUNTY: To satisfy the debt, interest and costs due CENTEX HOME EQillTY CORPORATION NlDfB/A CENTEX HOME EQUITY COMPANY, LLC., Plaintiff (s) From TERRY E. HILL AND BOBBI J. HILL (I) 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 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 himlher that he/she has been added as a garnishee and is enjoined as above stated. Amount Due $137,211.20 L.L. $.50 Interest FROM 10/6/05 - 3/8/06 - $3,541.92 AT $22.56 PER DIEM Ally's Comm % Ally Paid $146.80 PlaintilTPaid Date: OCTOBER 7, 2005 Due Prothy $1.00 Other Costs (Seal) By: Deputy REQUESTING PARTY: Name TERRENCE J. MCCABE, ESQUIRE Address: 123 S. BROAD STREET SUITE 2080 PHILADELPHIA, PA 19109 Attorney for: PLAINTIFF Telephone: 215-790-1010 Supreme Court ID No. 16496 McCABE, WEISBERG AND CONWAY, P.C. BY: TERRENCE J. MCCABE, ESQUIRE Attorney for Plaintiff Identification Number 16496 123 South Broad Street, Suite 2080 Philadelphia, PA 19109 215 790-1010 Centex Home Equity Corporation n/dIb/a COURT OF COMMON PLEAS Centex Home Equity Company, LLC v. Cumberland COUNTY Terry E. Hill and Bobbie J. Hill Number 05-4000 AFFIDAVIT PURSUANT TO RULE 3129 I, Terrence J. McCabe, Esquire, attorney for Plaintiff in the above action, set forth as of the date the Praecipe for the Writ of Execution was filed the following information concerning the real property located at: 59 Glendale Drive, Mechanicsburg, P A 17050 (Tax Parcel #38-05- 0435-016), a copy of the description of said property is attached hereto and marked as Exhibit "A." I. Name and address of Owners or Reputed Owners: Name Address Terry E. Hill BC'bbie J. Hill 125 Oak Flat Road Newville" P A 17241 93 Cherry Lane, Carlisle" P A 17013 2. Name and address of Defendants in the judgment: Name Address Terry E. Hill 125 Oak Flat Road Newville" PA 17241 93 Cherry Lane, Carlisle" P A 17013 Bobbie J. Hill 3. Name and last known address of every judgment creditor whose judgment is a record lien on the real property to be sold: Name Plaintiff herein Address 4. Name and address of the last recorded holder of every mortgage ofrecord: Name Plaintiff herein. Address 5. Name and address of every other person who has any record lien on the property: Name None Address 6. Name and address of every other person who has any record interest in the property which may be affected by the sale: Name None Address 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 Tenants Domestic Relations Cumberland County Commonwealth of Pennsylvania Commonwealth of Pennsylvania Inheritance Tax Office Commonwealth of Pennsylvania Bureau of Individual Tax Inheritance Tax Division Address 59 Glendale Drive, Mechanicsburg, PA 17050 P.O. Box 320 Carlisle,PA 17013 Department of Public Welfare P.O. Box 2675 Harrisburg, P A 17105 1400 Spring Garden Street Philadelphia, PA 19130 6th Floor, Strawberry Square Department #280601 Harrisburg, P A 17128 Internal Revenue Service Willow Oak Building P.O. Box 8486 Harrisburg, P A 17105-8486 Technical Support Group, William Green Federal Bldg. Room 3259, 600 Arch Street Philadelphia, PA 19106 Department of Public Welfare TPL Casualty Unit Estate Recovery Program 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. Section 4904 relating to unsworn falsification to authorities. October 5, 2005 .~..,..u.'V7'<~P. /f1('/-~ TERRENCE J. McCABE, ESQUIRE Attorney for Plaintiff DATE "" ::'~~ a c;" -n c' ~,_ ("j -j -...: C') c.) f'-~ . McCABE, WEISBERG AND CONWAY, P.e. BY: TERRENCE J. McCABE, ESQUIRE Identification Number 16496 123 South Broad Street, Suite 2080 Philadelphia, PA 19109 (215) 790-1010 Attorney for Plaintiff Centex Home Equity Corporation n/dIb/a Centex Home Equity Company, LLC Cumberland County Court of Common Pleas vs. Number 05-4000 Terry E. Hill Bobbie J. Hill NOTICE OF SHERIFF'S SALE OF REAL PROPERTY TO: Terry E. Hill 125 Oak Flat Road Newville, PA 17241 Bobbie J. Hill 93 Cherry Lane Carlisle, P A 17013 Your house (real estate) at 59 Glendale Drive, Mechanicsburg, P A 17050 (Tax Parcel #38-05-0435-016), is scheduled to be sold at Sheriffs Sale on March 8, 2006 at 10:00 a.m. in the Commissioner's Hearing Room located on the 2nd Floor ofthe Cumberland County Courthouse, I Courthouse Square, Carlisle, Pennsylvania 17013, to enforce the court judgment of$137,211.20 obtained by Centex Home Equity Corporation n/dIb/a Centex Home Equity Company, LLC 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 canceled if you pay to Centex Home Equity Corporation n/dIb/a Centex Home Equity Company, LLC, the back payments, late charges, costs, and reasonable attorney's fees due. To find out how much you must pay, you may call Terrence J. McCabe, Esquire at (215) 790-1010. 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 the following notice 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 Terrence J. McCabe, Esquire at (215) 790-1010. 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 on the sale. To find out if this has happened, you may call Terrence J. McCabe, Esquire at (215) 790-1010. 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. A schedule of distribution will be filed by the Sheriff on a date specified by the Sheriff not later than 30 days after sale. Distribution will be made in accordance with the schedule unless exceptions are filed thereto within 10 days after the filing of the schedule. 7. You may also have other rights and defenses, or ways of getting your real estate 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. 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. LAWYER REFERRAL SERVICE COUNTY COURT ADMINISTRATOR 4TH FLOOR, CUMBERLAND COUNTY COURTHOUSE CARLISLE, PENNSYL VANIA 17013 (717) 240-6200 OR CUMBERLAND BAR ASSOCIATION 2 LIBERTY AVENUE CARLISLE, P A 17013 (717) 249-3166 ~;;. () C:..") -n l.-~;"1 c, ';:l (".:; [-.1 -, I _J C) (.) .....' 11/02/2005 10:55 FAX 215 790 5990 MWC I4J 002 TGRRENCE J. 1\.1cCABEn'l' MARC S. WEISBERG" [OW ARD D. CONWAY MARGARET GAIRO RITA C BUSCHER'l MONICA (i. CHRISTIE -~. FRANK DUBIN BRENDA L. BROGDON* SEAN GARRETT" BETII L THOMAS tAURF.;NCF.: R, CHASHIN+ SVEN E. PFAHLERT* JOSI:.PI-! VACCARO. MICHELE DELlLLE^ CATANIA TRIGO^ LA W O,I'I(;oS McCABE, WEISBERG & CONWAY, P.C. SUITE 20RO 123 SOU'J'l-J BROAD SfHJ::br PHILADELPHIA, I'A 19109 (215) 790-1010 FAX (215) 790-1274 SUITE 600 21(, HADDON AVENUE WJ;STMONT. NJ 08108 (856) 8,8-7080 .-AX (856) 858-7020 SUITE 205 53 WEST 36TH STREET NEW YORK. NY 10018 (917)351-1188 HX(917)3SI.0363. J(}~EPH F. RIGA. Of Cnun...d . 1.IWl.l~dl"I'i\1ll ~,I .. L,,'ll_~~IPA&N" -.. L~IIt('llil\P^kNM ...L""',....-dll,I./l,.NJkNV t Lil:.ocdini'o"'AC'l' " 1.;"",00:.1;,,1>/',' ~ MtJ'r:Ic"'e 1\11"'1'0" l~rl'l,1 , f\II'">r,lnl:"IU'""~'M'NV November 2, 2005 Via Facsimile Sheriff of Cumberland County One Courthouse Square Carlisle. PA 17013 Re: Centex Home Equity Corporation n/d/b/a Centex Home Equity Company, lLe vs. Terry E. Hill and Bobbie J. [{ill c.c.P. Cumberland County, No. 05-4000 . / Property: 59 Glendale Drh'e, Mechanic..burg,}'A 1705d' Sheriff's Sale Date: March 8. 2006 Dear Sheriff: As you know. the above-captioned property is currently listed for the March 8, 2006 Sheriff's Sale. I am writing to you at this time to request that you stay the Sale. The defendants have fi led Chapter 13 Bankruptcy in the Middle District of P A on October 9, 2005. The case was assigned case number 1 :05-bk-07429-MDF. In addition, pkase return the Writ to the Prothonotary and fOlWard any renlnd due my client. As acknowledgment of this stay, I would appreciate your signing or time-stamping a copy of this letter and faxing the same to my attention. If you have any questions, please contact me. Thank you for your cooperation. 11/10/05 - Original writ returned to the Prothonotary's Office 11/10/05 - Copy of writ and $1500.00 check returned to Attorney McCabe. Very truly yours, 0<LQ.~ M.. ~ ~ TERRENCEJ.McCABE TJM/cmo SHERIFF'S OFFICE-RECEIVED BY: SIGNATURE DATE / , '" IN THE COURT OF COMMON PLEAS OF CUMBERLAND COUNTY, PENNSYL VANIA CIVIL DIVISION ,. FILE NO.: 05-4000 Civil Term Centex Home Equity Corporation n/dIb/a Centex Home Equity Company, LLC v. AMOUNT DUE: $137,211.20 Terry E. Hill Bobbie J. Hill INTEREST: from 10/6/05 - 6/7/06 $5.527.20 at $22.56 Per Diem ATTY'S COMM.: COSTS: TO THE PROTHONOTARY OF SAID COURT: The undersigned hereby certifies that the below does not arise out of a retail installment sale, contract, or account based on a confession of judgment, but if it does, it is based on the appropriate original proceeding filed pursuant to Act 7 of 1966 as amended; and for real property pursuant to Act 6 of 1974 as amended. PRAECIPE FOR EXECUTION Issue writ or execution in the above matter to the Sheriff of Cumberland County, for debt, interest and costs upon the following described property of the defendant(s) 59 Glendale Drive, Mechanicsburg:, P A 17050 (More fully described as attached) PRAECIPE FOR ATTACHMENT EXECUTION Issue writ of attachment to the Sheriff of CUMBERLAND County, for debt, interest and costs, as above, directing attachment against the above-named garnishee(s) for the following property (ifreal estate, supply six copies of the description; supply four copies oflengthy personalty list) and all other property of the defendant(s) in the possession, custody or control of the said gamishee(s). (Indicate) Index this writ against the gamishee( s) as a lis pendens against real estate ofthe defendant( s) described in the attached exhibit. DATE: ih /o/' 'f . Signature: --TA~ t.</ .1'./11 /' ~ Print Name: TERRENCE J. McCABE, ESQUIRE Address: 123 S. Broad Street. Suite 2080 Philadelphia, PA 19109 Attorney for: Plaintiff Telephone: (215) 7901010 Supreme Court ill No. 16496 , . , LEGAL DESCRIPTION , ALL THAT CERTAIN tract of land with improvements thereon situate in the Township of Silver Spring, County of Cumberland, State of Pennsylvania, as follows: BEGINNING at a point at the southeast comer of the property of George W. Weigel, et UX., and at the northeast comer of the property herein described, which point is marked with an angle iron; thence South 02 degrees 59 minutes West and along the center line of a fann lane, a distance of 296 feet to a stake, thence North 86 degrees 55 minutes West and along the northern property line of land of Helen M. Vogelsong, a distance of 400.80 feet to a point at an iron pin; thence North 02 degrees 00 minutes West, and along other lands of Helen M. Vogelsong, a distance of 265 feet to a point at the southern line of property of George W. Weigel, et ux.; thence North 88 degrees 45 minutes East and along the southern line of property of George W. Weigel, et UX., a distance of 425 feet to a point, the point and place of Beginning. CONTlANING 2.654 acres of land. BEING KNOWN AS 59 Glendale Drive, Mechanicsburg, P A 17050 Being the same premises which Joseph Cekovich, Jr., by deed dated the 9/5/200 I, and recorded 9/17/200 I in the Office of the Recorder in and for Cumberland County in Deed Book 248, Page 1959, granted and conveyed to Terry E. Hill and Bobbie J. Hill, in fee. TAX MAP PARCEL NUMBER: 38-05-0435-016 "'> ~\;~ .7,:) 0 ...:-~.. ,-[. ..., :'- ~".-'; :::::1 (::::, 0- % ~ ~ ~ "'- i~!~I~ *=- ~ , ':'\ I j",") "" ... <:> (I" ;=;:: ~ ? o ~.. ~ '" ~ .. ~ --", "- :;'.., ~ -- ~ ~ "-- .--... , ~ .. .-, -...! . .... ~ ~ ~ :/J ~ ~. -< ~ <><:'> ~ ~ WRIT OF EXECUTION andlor ATTACHMENT . COMMoNWEALTH OF PENNSYLVANIA) COUNTY OF CUMBERLAND) N005-4000 Civil CIVIL ACTION - LAW TO THE SHERIFF OF CUMBERLAND COUNTY: To satisfy the debt, interest and costs due CENTEX HOME EQUITY CORPORATION NIDIBIA CENTEX HOME EQUITY COMPANY, LLC Plaintiff (s) From TERRY E. HILL AND BOBBIE J. HILL (I) You are directed to levy upon the property of the defendant (s)and to sell SEE LEGAL DISCRIPTION . (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) 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 helshe has been added as a garnishee and is enjoined as above stated. Amount Due$137,2I1.20 Interest from 10/6/05 - 617/06 $5,527.56 Per Diem L.L. Atty's Comm Atty Paid $159.30 Plaintiff Paid Date: January 5, 2006 % Due Prothy $1.00 Other Costs (Seal) By: Deputy REQUESTING PARTY: Name TERRENCE J. McCABE, ESQ. Address: 123 S. Broad Street, Suite 2080 Philadelphia, P A 19109 Attorney for: Plaintiff Telephone: 215-790-1010 Supreme Court ID No. 16496 TRUE COPY FROM REeOnO In TelltimOny whereof, I hefe unto sel my r~);~.j and ttle seal of said Court at Carlisle, PlI. This ~,~y Of~ ~Cfl(' ~... -./)J? _..J c ProthonOta .'. . McCABE, WEISBERG AND CONWAY, P.C. BY: TERRENCE J. MCCABE, ESQUIRE Attorney for Plaintiff Identification Number 16496 123 South Broad Street, Suite 2080 Philadelphia, PA 19109 215 790-1010 Centex Home Equity Corporation n/d/b/a COURT OF COMMON PLEAS Centex Home Equity Company, LLC v. Cumberland COUNTY Terry E. Hill and Bobbie J. Hill Number 05-4000 AFFIDAVIT PURSUANT TO RULE 3129 I, Terrence J. McCabe, Esquire, attorney for Plaintiff in the above action, set forth as of the date the Praecipe for the Writ of Execution was filed the following information concerning the real property located at: 59 Glendale Drive, Mechanicsburg, P A 17050 (Tax Parcel #38-05- 0435-016), a copy ofthe description of said property is attached hereto and marked as Exhibit "A." I. Name and address of Owners or Reputed Owners: Name Address Terry E. Hill 125 Oak Flat Road Newville" P A 17241 93 Cherry Lane, Carlisle" PA 17013 Bobbie J. Hill 2. Name and address of Defendants in the judgment: Name Address Terry E. Hill 125 Oak Flat Road Newville" PA 17241 93 Cherry Lane, Carlisle" P A 17013 Bobbie J. Hill , '. 3. Name and last known address of every judgment creditor whose judgment is a record lien on the real property to be sold: Name Plaintiff herein Address 4. Name and address of the last recorded holder of every mortgage ofrecord: Name Plaintiff herein. Address 5. Name and address of every other person who has any record lien on the property: Name None Address 6. Name and address of every other person who has any record interest in the property which may be affected by the sale: Name None Address 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 Tenants Domestic Relations Cumberland County Commonwealth of Pennsylvania Commonwealth of Pennsylvania Inheritance Tax Office Commonwealth of Pennsylvania Bureau of Individual Tax Inheritance Tax Division Address 59 Glendale Drive, Mechanicsburg, P A 17050 P.O. Box 320 Carlisle, P A 17013 Department of Public Welfare P.O. Box 2675 Harrisburg, PA 17105 1400 Spring Garden Street Philadelphia, PA 19130 6th Floor, Strawberry Square Department #280601 Harrisburg, P A 17128 .. t Department of Public Welfare TPL Casualty Unit Estate Recovery Program Internal Revenue Service Willow Oak Building P.O. Box 8486 Harrisburg, P A 171 05-8486 Technical Support Group, William Green Federal Bldg. Room 3259, 600 Arch Street Philadelphia, PA 19106 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. Section 4904 relating to unsworn falsification to authorities. January 3,2006 DATE ~~'-"'-' <-<-- t:7. A; /' /~k_ TERRENCE J. McCABE, ESQUIRE Attorney for Plaintiff c~ c_ :", ~ C) -n :-;:l .,C.."""" \~~: i~~::', );::J ....- 1 U1 f .. McCABE, WEISBERG AND CONWAY, P.e. BY: TERRENCE J. McCABE, ESQUIRE Identification Number 16496 123 South Broad Street, Suite 2080 Philadelphia, PA 19109 (215) 790-1010 Attorney for Plaintiff Centex Home Equity Corporation n/dlb/a Centex Home Equity Company, LLC Cumberland County Court of Common Pleas vs. Number 05-4000 Terry E. Hill Bobbie J. Hill NOTICE OF SHERIFF'S SALE OF REAL PROPERTY TO: Terry E. Hill 125 Oak Flat Road Newville, PA 17241 Bobbie J. Hill 93 Cherry Lane Carlisle, PA 17013 Your house (real estate) at 59 Glendale Drive, Mechanicsburg, PA 17050 (Tax Parcel #38- 05-0435-016) , is scheduled to be sold at Sheriff's Sale on June 7, 2006 at 10:00 a.m. in the Commissioner's Hearing Room located on the 2nd Floor of the Cumberland County Courthouse, I Courthouse Square, Carlisle, Pennsylvania 17013, to enforce the court judgment of $137,211.20 obtained by Centex Home Equity Corporation n/dlb/a Centex Home Equity Company, LLC against you. NOTICE OF OWNER'S RIGHTS YOU MAY BE ABLE TO PREVENT THIS SHERIFF'S SALE To prevent this Sheriff's Sale you must take immediate action: I. The sale will be canceled if you pay to Centex Home Equity Corporation n/dlb/a Centex Home Equity Company, LLC, the back payments, late charges, costs, and reasonable attorney's fees due. To find out how much you must pay, you may call Terrence J. McCabe, Esquire at (215) 790-1010. 2. You may be able to stop the sale by filing a petition asking the Court to strike or open the judgment, ifthe 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 the following notice 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. Ifthe Sheriffs Sale is not stopped, your property will be sold to the highest bidder. You may find out the price bid by calling Terrence J. McCabe, Esquire at (215) 790-1010. 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 on the sale. To find out ifthis has happened, you may call Terrence J. McCabe, Esquire at (215) 790- 1010. 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 a right to remain in the property until the full amount due is paid to the Sheriffand the Sheriff gives a deed to the buyer. At that time, the buyer may bring legal proceedings to evict you. 6. A schedule of distribution will be filed by the Sheriff on a date specified by the Sheriff not later than 30 days after sale. Distribution will be made in accordance with the schedule unless exceptions are filed thereto within 10 days after the filing of the schedule. 7. You may also have other rights and defenses, or ways of getting your real estate 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. 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. LAWYER REFERRAL SERVICE OR COURT ADMINISTRATOR 4TH FLOOR, CUMBERLAND COUNTY COURTHOUSE CARLISLE, PENNSYL VANIA 17013 (717) 240-6200 CUMBERLAND COUNTY BAR ASSOCIATION 2 LIBERTY A VENUE CARLISLE, PA 17013 (717) 249-3166 (} ..-..::'l \-::-c') ~;" (~ :~,:::. ",,";. \ (..n C) .." .-' '~:~~I ')1':-" ",) '''.~ ~ ::''''' ~ ,,-:; / , .' ') ~-(-. , J~ '.Z ~ .J:;' McCA13E, WEISBERG AND CONWAY, P.e. BY: TERRENCE J. McCABE, ESQUIRE IOcntification Number 16496 123 South 13roall Strcet, Suite 2080 Philallclphia, l' A 19109 (215) 790-1010 Attorney for Plaintiff Ccntcx llome Equity Corporation nld/b/a Centex I-Iome ECl'lity Company, LLC Cumberland County Court of Common Pleas vs. Number 05-4000 Terry E. Hill Bobbie J. Hill AHIDA VIT OF SERVICE I, Tcrrcnec J. McCabe, Esquirc, attorncy for the Plaintiff in the within mattcr, hereby certify that on the 3'" day of April 2006, a true and correct copy of the Notice of Sheriffs Sale of Real Propcrty was served on all pertinent licnholder(s) as set forth in the Affidavit Pursuant to 3129 which is attached hcreto as Exhibit "A". Copies of the lctter and certificate of mailing arc also attached hereto, madc a part hereof and mark cd as Exbibit "B." /) il r TERRENCE J. McCABE, ESQUIRE Attorncy for Plaintiff " SWORN TO AND SUBSCRIBED BEFORE ME THIS 3RD DAY Of APRIL, 2006. (<<ursavt~a c?(~ Ii~-Il, NOTARY PUBLIC COMMONWEAL-Tn OF PENNSYt..VANIA NOTARIAL SEAL Chnssandra Shaye Hamilton, Notary Public City of Philadelphia. Phi\~. County . _.~y C?~~'!li!~!?.n ~~p~:~_J~~L~ 2009 ., _._.' McCABE, WEISBERG AND CONWAY, P.e. BY: TERRENCE J. MCCABE, ESQUIRE Attorney for I'laintiff Identification Number 16496 123 South Broad Street, Suite 2080 Philadelphia, I'A 19109 215 790-1010 Centex Home Equity Corporation n/d/bla COURT Of COMMON PLEAS Centex Home Equity Company, LLC v. Cumberland COUNTY Terry E. Hill and Bobbie J. Hill Number 05-4000 AFFIDAVIT PURSUANT TO RULE 3129 I, Terrence J. McCabe, Esquirc, attorney for Plaintiff in the above action, set forth as of the date thc Praecipe for the Writ of Execution was tiled the following information concerning the real property located at: 59 Glendale Drive, Mechanicsburg, PA 17050 (Tax Parcel #38- 05-0435-016), a copy ofthe description of said property is attached hereto and marked as Exhibit !lA," I. Name and address of Owners or Reputed Owners: Name Addrcss Terry E. Hill 125 Oak flat Road Newville" PA 17241 Bobbie J. Hill 93 Cherry Lane, Carlisle,. l' A 17013 2. Name and address of Defendants in the judgment: Name Address Terry E. Hill 125 Oak Flat Road Newville" P A 17241 93 Cherry Lane, Carlisle" P A 17013 Bobbie J. Hill r> l~ 'I iL:~ ~ , '.'1 ' "::$- ',I 3. Name and last known address of every judgment creditor whose judgment is a record lien on the real propcrty to be sold: Namc Plaintiff herein Addrcss 4. Name and address of the last recorded holder of every mortgage ofreeord: Name Plaintiff herein. Address 5. Name and address of every other person who has any record lien on the property: Name None Address 6. Name and address of cvery othcr person who has any record interest in the property which may be atlected by the sale: Namc None Address 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 Tenants Domestic Rclations Cumberland County Commonwealth of Pennsylvania Commonwealth of Pennsylvania Inheritance Tax Office Commonwealth of Pennsylvania Bureau of Individual Tax Inheritance Tax Division Address 59 Glendale Drive, Mechanicsburg, P A 17050 P.O. Box 320 Carlisle, P A 17013 Departmcnt of Public Welfarc P.O. Box 2675 Harrisburg, PA 17105 1400 Spring Gardcn Street Philadelphia, P A 19130 6th Floor, Strawberry Square Department #280601 Harrisburg, P A 17128 ^ {=\ l'1~ , Ii" I."c' Department of Public Welfare TPL Casualty Unit Estate Recovery Program Internal Revenue Service Willow Oak Building P.O. Box 8486 Harrisburg. I' A 17105-8486 Technical Support Group, William Green Federal Bldg. Room 325'). 600 Arch Street Philadelphia, P A 19106 I verifY that the statements made in this Affidavit arc true and correct to the best of my personal knowledge or information and belief. I understand that false statements herein arc made subject to the penalties of 18 Pa.C.S. Section 4904 relating to unsworn falsification to authorities. April 3, 2006 "-----:') /)/\. ,. DATE TERRENCE J. McCABE, ESQUIRE Attorney for Plaintiff J '~\ ~'i '.'\ . ~) , McCABE, WEISBERG AND CONWAY, P.e. BY: TERRENCE J. McCABE, ESQUIRE i"dcntification Numbcr 16496 123 South Broad Street, Suite 2080 Philadclphia, Pennsylvania 19109 (215) 790-1010 Attorney for Plnintiff Ccnlex Home Equity Corporation n/d/b/a Centex Home Equity Company, LLC Cumberland County Court ol"Common Pleas vs. Number 05-4000 Terry E. Hill Bobbie J. Hill DATE: April 3, 2006 TO: ALL PARTIES IN INTEREST AND CLAIMANTS NOTICE OF SHERIFF'S SALE OF REAL PROPERTY OWNER(S): Terry E. Hill and Bobbie J. Hill PROPERTY: 59 Glendale Drive, Mechanicsburg, PA 17050 EXH\B\1 B IMPROVEMENTS: Residential Dwelling The above-captioned property is scheduled to be sold at the Sheri ITs Sale on June 7, 2006, at 10:00 a.m. in the Commissioner's Hearing Room located on the 2nd Floor of the Cumberland County Courthouse, I Courthouse Square, Carlisle, Pennsylvania 17013. Our records indicate that you may hold a mortgage or judgments and liens on, and/or other interests in the property which will be extinguished by the sale. You may wish to attend the sale to protect your interests. A schedule of distribution will be filed by the Sheriff on a datc specified by the Sheriff not later than 30 days after sale. Distribution will be made in accordance with the schedule unless exceptions are filcd thereto within 10 days after the filing of the schedule. .~ '" oJ ~.~ '" i ~:=,:'''''']h~ ~ .~ oJ a- ~ ... w N , ~7. 3 go ..,g.~~o v,g. ~.6'2;~~ ~ ~[', (', '5 ~s. 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"" " '" ~~ V> \ ~" ~ '" % P:" 00 - ,'" ~ '"S 0 _:'" it , '" ;!' ~ ~ ~:< ~ 9. .7, " a < '; "'- ..."" ~ ~ 3~ g IF ~ .., 0 " ~ S-- '3 0 .< ;:;;. ;Z' 0;' ~ ~ , ~ ~ ~ 0 " " .., . l' . 0 \\\~~ i ~ ~-~\ .j.. l~ ~~~ ~giU I.." ,', t~ii n9~'" ~~i~ '''I ~i\, ~il-g.;i F/~ nv ~~%,\ ;;t';:j~ U~t :,1%~ ~ ..'~" n~~ 9-~1~' Ill', o;:.,,,..l'- 1""1 ~ ~ :::::-t <:::0 ~ "' .~) --n _-1 )~" r-;~ r....' \~'? ('I L~J COMMONWEALTH OF PENNSYLVANIA COUNTY OF CUMBERLAND }SS: I, Robert P. Ziegler, Recorder of Deeds in and for said County and State do hereby certify that the Sheriffs Deed in which Centex Home Equity Corp is the grantee the same having been sold to said grantee on the 7th day of June A.D., 2006, under and by virtue of a writ Execution issued on the 5th day of Jan, A.D., 2006, out of the Court of Common Pleas of said County as of Civil Term, 2005 Number 4000, at the suit of Centex Home Equity Corp against Terry E Hill & Bobbie J is duly recorded in Deed Book No. 275, Page 3461. IN TESTIMONY WHEREOF, I have hereunto set my hand -tk and al of said office this /~ day of L Centex Home Equity Corporation n/d/b/a Centex Home Equity Home Company, LLC VS Terry E. Hill and Bobbie J. Hill The Court of Common Pleas of Cumberland County, Pennsylvania Writ No. 2005-4000 Civil Term Robert Bitner, Deputy Sheriff, who being duly sworn according to law, states that on March 03,2006 at 6:38 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: Terry Hill, by making known unto Terry Hill, personally, at 125 Oak Flat Road, Newville, Cumberland County, Pennsylvania, its contents and at the same time handing to him personally the said true and correct copy of the same. Robert Bitner, Deputy Sheriff, who being duly sworn according to law, states that on March 03,2006 at 07:50 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: Bobbie Hill, by making known unto Bobbie Hill, personally, at 93 Cherry Lane, Carlisle, Cumberland County, Pennsylvania, its contents and at the same time handing her the said true and correct copy of the same. Robert Bitner, Deputy Sheriff, who being duly sworn according to law, states that on April 05, 2006 at 10:12 o'clock A.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 Terry E. Hill and Bobbie J. Hill located at 59 Glendale Dr., Mechanicsburg, 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: Terry E. Hill and Bobbie J. Hill by regular mail to their last known address of 125 Oak Flat Road, Newville, P A 17241 and 93 Cherry Lane, Carlisle, P A 17013, respectively. These letters were mailed under the date of April 03, 2006 and never returned to the Sheriffs Office. R. Thomas Kline, Sheriff, who being duly sworn according to law, states that after due and legal notice had been given according to law, he exposed the within described premises at public venue or outcry at the Courthouse, Carlisle, Cumberland County, Pennsylvania on June 7, 2006 at 10:00 o'clock A.M. He sold the same for the sum of $1.00 to Attorney Terrence McCabe for Centex Home Equity Corporation n/d/b/a Centex Home Equity Company, LLC. It being the highest bid and best price received for the same, Centex Home Equity Corporation n/d/b/a Centex Home Equity Company, LLC of250 Highland Drive, Lewisville, TX 75067, being the buyer in this execution, paid to Sheriff R. Thomas Kline the sum of $940.81. Sheriffs Costs: Docketing Poundage Posting Bills $30.00 18.44 15.00 Advertising Acknowledging Deed Auctioneer Law Library Prothonotary Mileage Certified Mail Levy Surcharge Law J oumal Patriot News Share of Bills Distribution of Proceeds Sheriffs Deed 15.00 30.00 10.00 .50 1.00 23.76 4.64 15.00 30.00 335.00 328.40 19.57 25.00 39.50 $ 940.81 ./ r+ So~~ .~A' r~~~ .. R. Thomas Kline, Sheriff By\JC~S~ Real Esta Sergeant 7/:11 /f)~ J),)-; (,,))/ \~) :H ~ ) ,SV (:..It!- 5l}'6J.i ,/.:1; -'/\ f. ';) '1 Ir:.~"" J.~", " ! f , McCABE, WEISBERG AND CONWAY, P.C. BY: TERRENCE J. MCCABE, ESQUIRE Identification Number 16496 123 South Broad Street, Suite 2080 Philadelphia, P A 19109 (215) 790-1010 Centex Home Equity Corporation nJd/b/a Centex Home Equity Company, LLC Attorney for Plaintiff COURT OF COMMON PLEAS v. Cumberland COUNTY C ,-..." c:.;> 0 ,---- <--~ ,. .-::;,;;-" .) ....,.... L. -! -,- -'- :D "'"-'.,... rn ("-.'. f -11 jl1 'j 9 U1 ~::'l ::~- ' , ~'-l c") ',~';;:'~ rn ~ )> :'.G ~. .,.~ ..< ,~- Terry E. Hill and Bobbie J. Hill Number 05-4000 AFFIDAVIT PURSUANT TO RULE 3129 I, Terrence J. McCabe, Esquire, attorney for Plaintiff in the above action, set forth as of the date the Praecipe for the Writ of Execution was filed the following information concerning the real property located at: 59 Glendale Drive, Mechanicsburg, P A 17050 (Tax Parcel #38-05- 0435-016), a copy of the description of said property is attached hereto and marked as Exhibit "A." 1. Name and address of Owners or Reputed Owners: Name Address Terry E. Hill 125 Oak Flat Road Newville" P A 17241 93 Cherry Lane, Carlisle" P A 17013 Bobbie J. Hill 2. Name and address of Defendants in the judgment: Name Address Terry E. Hill 125 Oak Flat Road Newville" P A 17241 93 Cherry Lane, Carlisle" P A 17013 Bobbie J. Hill ~ ,{ 3. . Name and last known address of every judgment creditor whose judgment is a record lien on the real property to be sold: Name Plaintiff herein Address 4. Name and address of the last recorded holder of every mortgage of record: Name Plaintiff herein. Address 5. Name and address of every other person who has any record lien on the property: Name None Address 6. Name and address of every other person who has any record interest in the property which may be affected by the sale: Name None Address 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 Tenants Domestic Relations Cumberland County Commonwealth of Pennsylvania Commonwealth of Pennsylvania Inheritance Tax Office Commonwealth of Pennsylvania Bureau of Individual Tax Inheritance Tax Division Address 59 Glendale Drive, Mechanicsburg, P A 17050 P.O. Box 320 Carlisle, P A 17013 Department of Public Welfare P.O. Box 2675 Harrisburg, P A 17105 1400 Spring Garden Street Philadelphia, P A 19130 6th Floor, Strawberry Square Department #280601 Harrisburg, PAl 7128 . , . Department of Public Welfare TPL Casualty Unit Estate Recovery Program Willow Oak Building P.O. Box 8486 Harrisburg, P A 17105-8486 Technical Support Group, William Green Federal Bldg. Room 3259, 600 Arch Street Philadelphia, P A 19106 Internal Revenue Service I verify that the statements made in this Affidavit are true and correct to the best of my personal knowledge or information and belief. I understand that false statements herein are made subject to the penalties of 18 Pa.C.S. Section 4904 relating to unsworn falsification to authOlities. January 3,2006 ~ . ~ ~"'~~~ c-c.-- (/, ~ r /~-_. TERRENCE J. McCABE, ESQUIRE Attorney for Plaintiff DATE . McCABE, WEISBERG AND CONWAY, P.C. BY: TERRENCE J. McCABE, E~QUlRE Identification Number 16496 123 South Broad Street, Suite 2080 Philadelphia, P A 19109 (215) 790-1010 Attorney for Plaintiff Centex Home Equity Corporation nJdlb/a Centex Home Equity Company, LLC Cumberland County Court of Common Pleas r-.' c.:? ~.....::-> ,:.5"' c_ ::': vs. Number 05-4000 I (J1 Terry E. Hill Bobbie J. Hill E: NOTICE OF SHERIFF'S SALE OF REAL PROPERTY TO: Terry E. Hill 125 Oak Flat Road Newville, P A 17241 Bobbie J. Hill 93 Cherry Lane Carlisle, P A 17013 Your house (real estate) at 59 Glendale Drive, Mechanicsburg, P A 17050 (Tax Parcel #38- 05-0435-016) , is scheduled to be sold at Sheriffs Sale on June 7, 2006 at 10:00 a.m. in the Commissioner's Hearing Room located on the 2nd Floor of the Cumberland County Courthouse, 1 Courthouse Square, Carlisle, Pennsylvania 17013, to enforce the court judgment of $137,211.20 obtained by Centex Home Equity Corporation nJdlb/a Centex Home Equity Company, LLC against you. NOTICE OF OWNER'S RIGHTS YOU MAY BE ABLE TO PREVENT THIS SHERIFF'S SALE To prevent this Sheriffs Sale you must take immediate action: 1. The sale will be canceled if you pay to Centex Home Equity Corporation n/d/b/a Centex Home Equity Company, LLC, the back payments, late charges, costs, and reasonable attorney's fees due. To find out how much you must pay, you may call Terrence 1. McCabe, Esquire at (215) 790-1010. 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 the following notice 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 1. 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 Terrence J. McCabe, Esquire at (215) 790-1010. 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 on the sale. To find out if this has happened, you may call Terrence J. McCabe, Esquire at (215) 790- 1010. 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. A schedule of distribution will be filed by the Sheriff on a date specified by the Sheriff not later than 30 days after sale. Distribution will be made in accordance with the schedule unless exceptions are filed thereto within 10 days after the filing of the schedule. 7. You may also have other rights and defenses, or ways of getting your real estate 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. 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. LAWYER REFERRAL SERVICE OR COURT ADMINISTRATOR 4TH FLOOR, CUMBERLAND COUNTY COURTHOUSE CARLISLE, PENNSYLVANIA 17013 (717) 240-6200 CUMBERLAND COUNTY BAR ASSOCIATION 2 LIBERTY AVENUE CARLISLE, PA 17013 (717) 249-3166 LECAL DESCRIPTION ALL THAT CERTAIN tract ofland with improvements thereon situate in the Township of Silver Spring, County of Cumberland, State of Pennsylvania, as follows: BEGINNING at a point at the southeast comer of the property of George -V.l. Weigel, et ux., and at the northeast comer of the property herein described, which point is marked with an angle iron; thence South 02 degrees 59 minutes West and along the center line of a farm lane, a distance of 296 feet to a stake, thence North 86 degrees 55 minutes West and along the northern property line of land of Helen M. Vogelsong, a distance of 400.80 feet to a point at an iron pin; thence North 02 degrees 00 minutes West, and along other lands of Helen M. Vogelsong, a distance of 265 feet to a point at the southern line of property of George W. Weigel, et UX.; thence North 88 degrees 45 minutes East and along the southern line of property of George W. Weigel, et ux., a distance of 425 feet to a point, the point and place of Beginning. CONTIANING 2.654 acres of land. BEING KNOWN AS 59 Glendale Drive, Mechanicsburg, P A 17050 Being the same premises which Joseph Cekovich, Jr., by deed dated the 9/5/2001, and recorded 9/17/2001 in the Office of the Recorder in and for Cumberland County in Deed Book 248, Page 1959, granted and conveyed to Terry E. Hill and Bobbie J. Hill, in fee. TAX MAP PARCEL NUMBER: 38-05-0435-016 WRIT OF EXECUTION and/or ATTACHMENT - . COMMONWEALTH OF PENNSYLVANIA) COUNTY OF CUMBERLAND) N005-4000 Civil CIVIL ACTION - LA W TO THE SHERIFF OF CUMBERLAND COUNTY: To satisfy the debt, interest and costs due CENTEX HOME EQUITY CORPORATION NfD/B/A CENTEX HOME EQUITY COMPANY, LLC Plaintiff (s) From TERRY E. HILL AND BOBBIE J. HILL (I) You are directed to levy upon the property of the defendant (s)and to sell SEE LEGAL D~CRIPTION . (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$137,211.20 Interest from 10/6/05 - 6/7/06 $5,527.56 Per Diem L.L. ...9:) Atty's Comm Atty Paid $159.30 Plaintiff Paid Date: January 5, 2006 % Due Prothy $1.00 Other Costs pro{~~ (Seal) By: Deputy REQUESTING PARTY: Name TERRENCE J. McCABE, ESQ. Address: 123 S. Broad Street, Suite 2080 Philadelphia, P A 19109 Attorney for: Plaintiff Telephone: 215-790-1010 Supreme Court ID No. 16496 Real Estate Sale # 16 On February 08, 2006 the Sheriff levied upon the defendant's interest in the real property situated in Silver Spring Township, Cumberland County, P A Known and numbered as 59 Glendale Drive, Mechanicsburg, more fully described on Exhibit "A" filed with this writ and by this reference incorporated herein. Date: February 08, 2006 By: \ i V .--1. l..-l cv:a c:;:;;] c::::::J G=e> Ii\tiI Real Estate Sergeant s n :l d L \ ~~r qUGl , .. : '. .+\ \v,,) U ,,\~u'j~H\:'; \(; ,"";,;IS 3L\1 3D J'J\.:dO .:l.:1\tbn \l . . PROOF OF PUBLICATION OF NOTICE IN CUMBERLAND LAW JOURNAL (Under Act No. 587, approved May 16, 1929), P. L.1784 COMMONWEAL TH OF PENNSYL VANIA SSe 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, VIZ: April 7,14,21,2006 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. SW AND SUBSCRffiED before me this 21 day of April. 2006 ~~~)'~~A) 1 1\, . ,~., ' ,', )"Ji ~ i 1 r:'~ .- ' .', -". ,.. f)",\!.:c g, ..." ", - ;'.~ ~ Cf:: ;:,. Cun,')(:~ i '~ ~~ REAL ESTATE SALE NO. 16 Writ No. 2005-4000 Civil Centex Home Equity Corporation njd/b/a Centex Home Equity Company, LLC vs. Terry E. Hill and Bobbie J. Hill Atty.: Terrence McCabe LEGAL DESCRIPTION ALL THAT CERTAIN tract of land with improvements thereon situate in the Township of Silver Spring, County of Cumberland, State of Pennsylvania, as follows: BEGINNING at a point at the southeast corner of the property of George W. Weigel, et ux., and at the northeast corner of the prop- erty herein described, which point is marked with an angle iron; thence South 02 degrees 59 minutes West and along the center line of a farm lane, a distance of 296 feet to a stake, thence North 86 degrees 55 minutes West and along the north- ern property line of land of Helen M. Vogelsong, a distance of 400.80 feet to a point at an iron pin; thence North 02 degrees 00 minutes West, and along other lands of Helen M. Vogelsong, a distance of 265 feet to a point at the southern line of prop- erty of George W. Weigel, et ux.; thence North 88 degrees 45 min- utes East and along the southern line of property of George W. Weigel, et ux., a distance of 425 feet to a point, the point and place of Begin- ning. CONTIANING 2.654 acres of land. BEING KNOWN AS 59 Glendale Drive, Mechanicsburg, PA 17050. Being the same premises which Joseph Cekovich, Jr., by deed dated the 9/5/2001, and recorded 9/17/ 2001 in the Office of the Recorder in and for Cumberland County in Deed Book 248, Page 1959, granted and conveyed to Terry E. Hill and Bobbie J. Hill, in fee. TAX MAP PARCEL NUMBER: 38- 05-0435-016. . ;. , 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 19th and 26th day(s) of April and the 3rd day(s) of May 2006. 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 SALE#16 Sworn to NOT AR PUBLIC My commission expires June 6, 2006 CUMBERLAND COUNTY SHERIFF'S OFFICE CUMBERLAND COUNTY COURTHOUSE CARLISLE, PA. 17013 REAL ESTATE SALE No. 11 WIll.. WI IllJ.U"'" c.,. ............ ColfM...... nIdbI8 C8IdIxI:lome~ . CoInpMIy, lJ.C VS Teny E. HIM... Bobbie J. Hilt ~Terrenpe IIcC8IMt DESCRIP'noN All.. TIIAT CERl'AIN. tract of land with improvenms tbereOIl situaIe in the Township of Silver Spring, Coanty of Cumberland, State of Pemlsylvaaia, as follows: BEGINNING at a point at the Southeast comer of the property of George W. Weigel, et UX., and at . the Nmheast comer of the property herein described, which point is marked wilh an angle iron; thence South 02 degrees 59 minutes West and along the center line of a farm lane, a distance of 296 feet to a stake. tbcnce North 86 degrees 55 minutes West and along the Northern property line of land of Helen M:\'bgeIsoog, a distance of 400.80 feet to a point at an iron pin; tbcnce Notth 02 degrees 00 mi!IIlIes West1 and ~ olher lands of HelenM. VogelSong, a~ of f65 feet to a point at the SouIbem line of property of George W. Wei&d,et ux; tbcnce Ncdl 88 degrees 45 minutes East and aloog the SouIbem line of property of George W. Weigel, et us.. a distance of 425 feet to a point,the point and place W BEGINNING. CONTAINING 2.654 acres of land BEING KNOWN AS 59 Glendale Drive, Mechanicsbutg,PA 11050 BEING TIlE SAME. pRIBIises which Joseph Cekovicb, Jr., J,y tbd daIEd the 915/2001, and rec<<ded 9117/2001 in the Offire of the Recorder in lIIId (or Camliedad Couuty in Deed Book 248, ~ 1959.... and Q)Ilveyed to Terry E. Hill and ......Uil.. fee. TAlMAPMlClil.No. ~3s..o16