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HomeMy WebLinkAbout05-5073 PHELAN HALLINAN & SCHMIEG, LLP LAWRENCE T. PHELAN, ESQ., Id. No. 32227 FRANCIS S. HALLINAN, ESQ., Id. No. 62695 ONE PENN CENTER PLAZA, SUITE 1400 PHILADELPHIA, PA 19103 (215) 563-7000 CITIFINANCIAL MORTGAGE COMPANY, INC., FIKIA ASSOCIATES HOME EQUITY CONSUMER DISCOUNT COMPANY, INC. 8333 RIDGE POINT DRIVE IRVING, TX 75063 ATTORNEY FOR PLAINTIFF COURT OF COMMON PLEAS CIVIL DIVISION TERM C{0~L~r Plaintiff NO. 05 -So7l v. CUMBERLAND COUNTY STEVEN E. TRACE WENDY J. TRACE 297 BONNYBROOK ROAD CARLISLE, P A 17013 Defendants CIVIL ACTION - LAW COMPLAINT IN MORTGAGE FORECLOSURE NOTICE You have been sued in court. If you wish to defend against the claims set forth in the following pages, you must take action within twenty (20) days after this complaint and notice are served, by entering a written appearance personally or by attorney and filing in writing with the court your defenses or objections to the claims set forth against you. You are warned that if you fail to do so the case may proceed without you and a judgment may be entered against you by the court without further notice for any money claimed in the complaint or for any other claim or 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 LA WYER, GO TO OR TELEPHONE THE OFFICE SET FORTH BELOW. THIS OFFICE CAN PROVIDE YOU WITH INFORM A nON ABOUT HIRING A LAWYER. IF YOU CANNOT AFFORD TO HIRE A LAWYER, THIS OFFICE MAY BE ABLE TO PROVIDE YOU WITH INFORMA nON ABOUT AGENCIES THAT MAY OFFER LEGAL SERVICES TO ELIGIBLE PERSONS AT A REDUCED FEE OR NO FEE. Lawyer Referral Service Cumberland County Bar Association 32 South Bedford Street Carlisle, P A 17013 (800)990-9108 File #: 73406 File #: 73406 IF THIS IS THE FIRST NOTICE THAT YOU HAVE RECEIVED FROM THIS OFFICE, BE ADVISED THAT: PURSUANT TO THE FAIR DEBT COLLECTION PRACTICES ACT, 15 U,S.c. ~ 1692 et seq. (1977), DEFENDANT(S) MAY DISPUTE THE VALIDITY OF THE DEBT OR ANY PORTION THEREOF. IF DEFENDANT(S) DO SO IN WRITING WITHIN THIRTY (30) DAYS OF RECEIPT OF THIS PLEADING, COUNSEL FOR PLAINTIFF WILL OBTAIN AND PROVIDE DEFENDANT(S) WITH WRITTEN VERIFICATION THEREOF; OTHERWISE, THE DEBT WILL BE ASSUMED TO BE VALID. LIKEWISE, IF REQUESTED WITHIN THIRTY (30) DAYS OF RECEIPT OF THIS PLEADING, COUNSEL FOR PLAINTIFF WILL SEND DEFENDANT(S) THE NAME AND ADDRESS OF THE ORIGINAL CREDITOR, IF DIFFERENT FROM ABOVE. THE LAW DOES NOT REQUIRE US TO WAIT UNTIL THE END OF THE THIRTY (30) DAY PERIOD FOLLOWING FIRST CONTACT WITH YOU BEFORE SUING YOU TO COLLECT THIS DEBT. EVEN THOUGH THE LAW PROVIDES THAT YOUR ANSWER TO THIS COMPLAINT IS TO BE FILED IN THIS ACTION WITHIN TWENTY (20) DAYS, YOU MAY OBTAIN AN EXTENSION OF THAT TIME. FURTHERMORE, NO REQUEST WILL BE MADE TO THE COURT FOR A JUDGMENT UNTIL THE EXPIRATION OF THIRTY (30) DAYS AFTER YOU HAVE RECEIVED THIS COMPLAINT. HOWEVER, IF YOU REQUEST PROOF OF THE DEBT OR THE NAME AND ADDRESS OF THE ORIGINAL CREDITOR WITHIN THE THIRTY (30) DAY PERIOD THAT BEGINS UPON YOUR RECEIPT OF THIS COMPLAINT, THE LAW REQUIRES US TO CEASE OUR EFFORTS (THROUGH LITIGATION OR OTHERWISE) TO COLLECT THE DEBT UNTIL WE MAIL THE REQUESTED INFORMATION TO YOU. YOU SHOULD CONSULT AN ATTORNEY FOR ADVICE CONCERNING YOUR RIGHTS AND OBLIGATIONS IN THIS SUIT. IF YOU HAVE FILED BANKRUPTCY AND RECEIVED A DISCHARGE, THIS IS NOT AN ATTEMPT TO COLLECT A DEBT. IT IS AN ACTION TO ENFORCE A LIEN ON REAL ESTATE. 1. Plaintiff is CITIFINANCIAL MORTGAGE COMPANY, INC., F/K/A ASSOCIATES HOME EQUITY CONSUMER DISCOUNT COMPANY, INC. 8333 RIDGE POINT DRIVE IRVING, TX 75063 2. The name(s) and last known addressees) of the Defendant(s) are: STEVEN E. TRACE WENDY J. TRACE 297 BONNYBROOK ROAD CARLISLE, PA 17013 who is/are the mortgagor(s) and real owner(s) of the property hereinafter described. 3. On 07/25/2000 mortgagor(s) made, executed and delivered a mortgage upon the premises hereinafter described to PLAINTIFF which mortgage is recorded in the Office of the Recorder of CUMBERLAND County, in Mortgage Book No. 1628, Page: 357. 4. The premises subject to said mortgage is described as attached. 5. The mortgage is in default because monthly payments of principal and interest upon said mortgage due 08/31/2004 and each month thereafter are due and unpaid, and by the terms of said mortgage, upon failure of mortgagor to make such payments after a date specified by written notice sent to Mortgagor, the entire principal balance and all interest due thereon are collectible forthwith. File #: 73406 6. The following amounts are due on the mortgage: Principal Balance Interest 07/31/2004 through 09/27/2005 (Per Diem $22.40) Attorney's Fees Cumulative Late Charges 07/31/2000 to 09/27/2005 Cost of Suit and Title Search Subtotal $87,256.67 9,497.60 1,250.00 0.00 $ 550.00 $ 98,554.27 Escrow Credit Deficit Subtotal 0.00 0.00 $ 0.00 TOTAL $ 98,554.27 7. The attorney's fees set forth above are in conformity with the mortgage documents and Pennsylvania law, and will be collected in the event of a third party purchaser at Sheriffs Sale. If the Mortgage is reinstated prior to the Sale, reasonable attorney's fees will be charged. 8. Notice of Intention to Foreclose as set forth in Act 6 of 1974, Notice of Homeowner's Emergency Assistance Program pursuant to Act 91 of 1983, as amended in 1998, and/or Notice of Default as required by the mortgage document, as applicable, have been sent to the Defendant(s) on the date(s) set forth thereon, and the temporary stay as provided by said notice has terminated because Defendant(s) has/have failed to meet with the Plaintiff or an authorized consumer credit counseling agency, or has/have been denied assistance by the Pennsylvania Housing Finance Agency. 9. This action does not come under Act 6 of 1974 because the original mortgage amount exceeds $50,000. WHEREFORE, PLAINTIFF demands an in rem Judgment against the Defendant(s) in the sum of$ 98,554.27, together with interest from 09/27/2005 at the rate of $22.40 per diem to the date of Judgment, and other costs and charges collectible under the mortgage and for the foreclosure and sale of the mortgaged property. PHELAN HALLINAN & SCHMIEG, LLP /) -'f 1---.-.. f )r/JP- By: IslFrancis S. Hallinan LAWRENCE T. PHELAN, ESQUIRE FRANCIS S. HALLINAN, ESQUIRE Attorneys for Plaintiff File #: 73406 LEGAL DESCRIPTIO~ ALL THA~ CEnTUM lot or parcel of land located in Soqth Hlddle~ Township, C\Ullberland county, Pennsylvania, more particularly bounded. and <ie8<:ribed all fol1owa~ to witl BEGINNING at A point marked at the intersection of lIonnybrook Road (T-S16) and Heiser Lane ('1'-513), thence north 35 degree. 5 lIlinuteslO 8aeonds1Nst along J!onnybrook Road, a disunce of 125 feet to an iron pin; thence north 76 degrees 19 minutes 10 8e<:OndS eut along the boundaxy line between Lot Ii and 7, a distance of 222.'. feet to an iron pin; tbence south 25 degrees Ii -u-nutes 21 seconds ellst along the boundm:y line botwoen Lot 5 and Ii, a distance of 1S0 feet to an iron pin; thence soutb 80 degrees 53 minutes 28 !Seconds west along Heiser Lane, a disunc:e at 186.34 feet to an iron pin, thence radius 25 feet, a di8~o Of 27.94 feet to an iron piA, the place of BEGINNING. COI11'AIlURG 29,113.98 .quuo fGet. '1'ogether wlth ubtlnq dwelling and imp~nu ~xeon. eOO Lot Bo. 6 of the Plan of LOU for RayIDond ~. Diehl, Genevieve A.. DLehl, 1lcm41d B. Diehl ad Suzanne Diehl, prepared by Stephen 1'. Pishe', ud dated Kov'eIIbel:' 2, 1981, ~h plan 1. of reeard at Plan Book 41, Page ". UNDO AIm SOD.JBC'1', ~, to eUeiIl8llta, reetd.c:1:J.OIUI and rlqhta-of-way of prl.or re<:ord. BEING 'tHE SAME PUHISES which RaJlllOftd E. Dloh1, Donald B. Diehl, Su.zanne Diehl and Geneveive A. Diehl, by their deed dated April <&, 1984 and recorded in the Offic:e of tho RecOrder of Deeds in and for Cultlberland County, PennsylvanJ.a, in Deed Book P, VolUllle 30, Page 925 9X'anted and conveyed unto John L. NOblIer and Ann H. NeImer, JUs' wife, tM Grantora herein. VF.RTFTCA TION THERESA SKINNER hereby states that he/she ~~CRETARY of ~ITIFINANCIAL mortgage servicing agent for Plaintiff in this matter, that he/she is authorized to take this Verification, and that the statements made in the foregoing Civil Action in Mortgage Foreclosure are true and correct to the best of his /her knowledge, information and belief. The undersigned - understands that this statement is made subject to the penalties of 18 Pa. C.S. Sec. 4904 relating to unsworn falsification to authorities. DATE: ~ \''L I \OS .----- p P Tit l- l --t VI .J:: (,..; Ul ..t: -1 \ - ~ -a -- -w.. (n t/l. r.n C> -0 F ~ k (2 t-:..~:; ~ ~ ~ GJ i:.r> .-1 (/) -c -"'I "--"1'\ f-l'l r:\ '-v -\"1 ~, ~~1.~ .- s:?\ -- ~"...,.. .' "')::J c~'" :-<. r..;.:> SHERIFF'S RETURN - NOT FOUND CASE NO: 2005-05073 P COMMONTWEALTH OF PENNSYLVANIA COUNTY OF CUMBERLAND CITIFINANCIAL MORTGAGE COMPANY VS TRACE STEVEN E ET AL R. Thomas Kline ,Sheriff or Deputy Sheriff, who being duly sworn according to law, says, that he made a diligent search and inquiry for the within named DEFENDANT TRACE STEVEN E but was unable to locate Him in his bailiwick. He therefore returns the COMPLAINT - MORT FORE , NOT FOUND , as to the within named DEFENDANT , TRACE STEVEN E 297 BONNYBROOK ROAD CARLISLE, PA 17013 SHARON MCKEEHAN IS LIVING THERE. Sheriff's Costs: Docketing Service Not Found Surcharge 18.00 4.80 5.00 10.00 .00 37.80 so~.wers' ~ <~ ~ ~~ R. Thomas Kline Sheriff of Cumberland County PHELAN HALLINAN SCHMIEG 11/07/2005 Sworn and subscribed to before me . ~/, ^ J I / ? day of / voverr.c,'.,c this dlIO 5" / SHERIFF'S RETURN - NOT FOUND CASE NO: 2005-05073 P COMMONTWEALTH OF PENNSYLVANIA COUNTY OF CUMBERLAND CITIFINANCIAL MORTGAGE COMPANY VS TRACE STEVEN E ET AL R. Thomas Kline ,Sheriff or Deputy Sheriff, who being duly sworn according to law, says, that he made a diligent search and inquiry for the within named DEFENDANT TRACE WENDY J but was unable to locate Her in his bailiwick. He therefore returns the COMPLAINT - MORT FORE , NOT FOUND , as to the within named DEFENDANT , TRACE WENDY J 297 BONNYBROOK ROAD CARLISLE, PA 17013 SHARON MCKEEHAN IS LIVING AT 297 BONNYBROOK ROAD. Sheriff's Costs: Docketing Service Not Found Surcharge 6.00 .00 5.00 10.00 .00 21.00 So answers:. ./C' ~k/~-=... / R. Thomas Kline Sheriff of Cumberland County PHELAN HALLINAN SCHMIEG 11/07/2005 Sworn and subscribed to before me this Iilth day of JlhvelY'\;.JJ- J(x)5~ ~ Pratho otar . SHERIFF'S RETURN - NOT FOUND CASE NO: 2005-05073 P COMMONTWEALTH OF PENNSYLVANIA COUNTY OF CUMBERLAND CITIFINANCIAL MORTGAGE COMPANY VS TRACE STEVEN E ET AL R. Thomas Kline ,Sheriff or Deputy Sheriff, who being duly sworn according to law, says, that he made a diligent search and inquiry for the within named DEFENDANT TRACE WENDY J but was unable to locate Her in his bailiwick. He therefore returns the COMPLAINT - MORT FORE , NOT FOUND , as to the within named DEFENDANT , TRACE WENDY J 45 BALTIMORE STREET CARLISLE, PA 17013 DEFENDANT IS SUPPOSED TO BE LIVING AT 45 BALTIMORE ST, BUT IS NOT HOME TILL LATE AT NIGHT. Sheriff's Costs: Docketing Service Not Found Surcharge 6.00 4.80 5.00 10.00 .00 25.80 So answerJl.;:/-~ . . . _ // / /- - ~~~~~:;;;;- R. Thomas Kline Sheriff of Cumberland County PHELAN HALLINAN SCHMIEG 11/07/2005 Sworn and subscribed to before me this , ",It /0 day of /Jovef"; ,LRr i):(t)s---' AD~ protho~~~ SHERIFF'S RETURN - REGULAR CASE NO: 2005-05073 P COMMONWEALTH OF PENNSYLVANIA: COUNTY OF CUMBERLAND CITIFINANCIAL MORTGAGE COMPANY VS TRACE STEVEN E ET AL RICHARD SMITH , Sheriff or Deputy Sheriff of Cumberland County, Pennsylvania, who being duly sworn according to law, says, the within COMPLAINT - MORT FORE was served upon TRACE STEVEN E the DEFENDANT , at 1748:00 HOURS, on the 29th day of September, 2005 at 102 MEALS DRIVE CARLISLE, PA 17013 by handing to STEVEN TRACE a true and attested copy of COMPLAINT - MORT FORE together with and at the same time directing His attention to the contents thereof. Sheriff's Costs: Docketing Service Affidavit Surcharge So Answers: 6.00 4.80 .00 10.00 .00 20.80 r' R. Thomas Kline ,~ -:r.-e'~ 11/07/2005 PHELAN HALLIN Sworn and Subscribed to before By: st' MI EG ,---- \ eputy Sheriff me this !~tL day of (JJ(2 ~"v\~).(5- . PHELAN HALLINAN & SCHMIEG, LLP LA WRENCE T. PHELAN, ESQ., Id. No. 32227 FRANCIS S. HALLINAN, ESQ., Id. No. 62695 ONE PENN CENTER PLAZA, SUITE 1400 ATTORNEY FOR PLAINTIFF PHILADELPHIA, PA 19103 (2 IS) 563-7000 CITIFINANCIAL MORTGAGE COMPANY, INC., COURT OF COMMON PLEAS F/K/A ASSOCIATES HOME EQUITY CONSUMER DISCOUNT COMPANY, CIVIL DIVISION INe. Plaintiff CUMBERLAND County vs. STEVEN E. TRACE WENDY J. TRACE No. 05-5073 CIVIL TE Defendants PRAECIPE TO REINSTATE CIVIL ACTIONIMORTGAGE FORECLOSURE TO THE PROTHONOTARY: Kindly reinstate the Civil Action in Mortgage Foreclosure with reference to the above captioned matter. PHELAN HALLINAN & SCHMIEG, LLP By: l~ 5 #~-.J~ FRANCIS S. HALLINAN, ESQUIRE LAWRENCE T. PHELAN, ESQUIRE DANIEL G. SCHMIEG, ESQUIRE Attorneys for Plaintiff Date: December 28. 2005 Ijmr, Svc Dept. File# 73406 , ~ '" 1 ~ C::.1 ~ '-- (::J ~Tl .-l .....C-p ;nt~ "';)i,/_; :~;~ ?:~: 2:: , W .-\" C:? '.;_:1~'i\ .~-~ .,> -.; <:I =<: SHERIFF'S RETURN - REGULAR CASE NO: 2005-05073 P COMMONWEALTH OF PENNSYLVANIA: COUNTY OF CUMBERLAND CITIFINANCIAL MORTGAGE COMPANY VS TRACE STEVEN E ET AL DOUGLAS RUZANSKI Sheriff or Deputy Sheriff of Cumberland County, Pennsylvania, who being duly sworn according to law, says, the within COMPLAINT - MORT FORE was served upon TRACE WENDY J the DEFENDANT , at 1953:00 HOURS, on the 6th day of January 2006 at 711 BREEZEWOOD DRIVE MECHANICSBURG, PA 17055 by handing to WENDY J TRACE a true and attested copy of COMPLAINT - MORT FORE together with and at the same time directing Her attention to the contents thereof. Sheriff's Costs: Docketing Service Affidavit Surcharge So Answers: 18.00 11.44 .00 10.00 .00 39.44 "\-,, .1- ::/?'~<,':2.~/~~~~,..c"_" - .,.',- ?/~?/ ""':'~:.~:'::,.-".c.~~ R. Thomas Kline 01/09/2006 PHELAN HALLINAN / I Sworn and Subscribed to before By: me this ~ /O~ day of A.D. P onot y PHELAN HALLINAN & SCHMIEG, L.L.P. By: DANIEL G. SCHMIEG Identification No. 62205 Attorney for Plaintiff ONE PENN CENTER AT SUBURBAN ST AnON 1617 JOHN F. KENNEDY BLVD., smTE 1400 PHILADELPHIA, PA 19103-1814 (215) 563-7000 CITlFINANCIAL MORTGAGE COMPANY, INC. F/K1A ASSOCIATESS HOME EQUITY CONSUMER DISCOUNT COMPANY, INC. 8333 RIDGE POINT DRIVE IRVING, TX 75063 CUMBERLAND COUNTY COURT OF COMMON PLEAS CIVIL DIVISION Plaintiff, NO. 05-5073 CIVIL TERM v. STEVEN E. TRACE WENDY J. TRACE Defendant(s). PRAECIPE FOR IN REM JUDGMENT FOR FAILURE TO ANSWER AND ASSESSMENT OF DAMAGES TO THE PROTHONOTARY: Kindly enter an in rem judgment in favor of the Plaintiff and against STEVEN E. TRACE and WENDY J. TRACE, Defendant(s) for failure to file an Answer to Plaintiffs Complaint within 20 days from service thereof and for Foreclosure and Sale ofthe mortgaged premises, and assess Plaintiffs damages as follows: As set forth in Complaint Interest from 9/28/05 to 2/13/06 TOTAL $98,554.27 $3,113.60 $101,667.87 I hereby certifY that (1) the addresses of the Plaintiff and Defendant( s) are as shown above, and (2) that notice has been given in accordance with Rule 237.1, copy attached. DAMAGES ARE HEREBY ASSESSED AS INDICATJ2 ~ DATE:~~ 027 ;u-x)b ~ 7 J PR OTHY PHELAN HALLINAN & SCHMIEG, L.L.P. By: DANIEL G. SCHMIEG Identification No. 62205 ATTORNEY FOR PLAINTIFF ONE PENN CENTER AT SUBURBAN STATION 1617 JOHN F. KENNEDY BLVD., SUITE 1400 PIDLADELPIDA, PA 19103-1814 (215) 563-7000 CITIFINANCIAL MORTGAGE COMPANY, INC. FIKI A ASSOCIA TESS HOME EQUITY CUMBERLAND COUNTY CONSUMER DISCOUNT COMPANY, INC. COURT OF COMMON PLEAS 8333 RIDGE POINT DRIVE CIVIL DIVISION Plaintiff, NO. 05-5073 CIVIL TERM v. STEVEN E. TRACE WENDY J. TRACE Defendant(s). VERIFICATION OF NON-MILITARY SERVICE DANIEL G. SCHMIEG, ESQUIRE, hereby verifies that he is attorney for the Plaintiff in the above-captioned matter, and that on information and belief, he has knowledge of the following facts, to wit: (a) that the defendant(s) is/are not in the Military or Naval Service of the United States or its Allies, or otherwise within the provisions of the Soldiers' and Sailors' Civil Relief Act of Congress of 1940, as amended. (b) that defendant STEVEN E. TRACE is over 18 years of age and resides at , 102 MEALS DRIVE, CARLISLE, P A 17013 . (c) that defendant WENDY J. TRACE is over 18 years of age, and resides at , 711 BREEZEWOOD DRIVE, MECHANICSBURG, PA 17055. This statement is made subject to the penalties of 18 Pa. C.S. Section 4904 relating to unsworn falsification to authorities. ,. 't () .(,Q. 70 K ...{) ..-.."0. t- ~ ..~ -"'l '1- \\- () '.,. ~ :-.' - \Y r \ ~ ('\ - -t:. ~ r...... f' ...:t __1 "'-Q -J:: - ~ - -::t --::r ^ ~ -.:r \) f -s:::. -1:.. ~-,.- ~ , --L. (Rule of Civil Procedure No. 236) - Revised IN THE COURT OF COMMON PLEAS OF CUMBERLAND COUNTY, PENNSYLVANIA CIVIL ACTION - LAW CITIFINANCIAL MORTGAGE COMPANY, INC. FIKIA ASSOCIATESS HOME EQUITY CONSUMER DISCOUNT COMPANY, INC. 8333 RIDGE POINT DRIVE CUMBERLAND COUNTY COURT OF COMMON PLEAS CIVIL DIVISION Plaintiff, NO. 05-5073 CIVIL TERM v. STEVEN E. TRACE WENDY J. TRACE Defendant(s). Notice is given that a Judgment in the above-captioned matter has been entered against you on '1pJ, .."2 '7 200 Ie:> Byf0~ If you have any questions concerning this matter, please contact: ~/ DA EL G. SCH , ESQUIRE Att<Srney for Plaintiff ,oNE PENN CENTER AT SUBURB' STATION 1617 JOHN F. KENNEDY BLVD., S ITE 1400 PHILADELPHIA, PA 19103-1814 (215) 563-7000 "THIS FIRM IS A DEBT COLLECTOR ATTEMPTING TO COLLECT A DEBT AND ANY INFORMATION OBTAINED WILL BE USED FOR THAT PURPOSE. IF YOU HA VE PREVIOUSLY RECEIVED A DISCHARGE IN BANKRUPTCY AND THIS DEBT WAS NOT REAFFIRMED, THIS CORRESPONDENCE IS NOT AND SHOULD NOT BE CONSTRUED TO BE AN ATTEMPT TO COLLECT A DEBT, BUT ONLY ENFORCEMENT OF A LIEN AGAINST PROPERTY." CARLISLE, PA 17013 (717) 249-3166 (800) 990-9108 PRAECIPE FOR WRIT OF EXECUTION - (MORTGAGE FORECLOSURE) P.R.C.P.3180-3183 CITIFINANCIAL MORTGAGE COMPANY, INC. F/K/A ASSOCIATESS HOME EQUITY CONSUMER DISCOUNT COMPANY, INC. Plaintiff, No. 05-5073 CIVIL TERM v. STEVEN E. TRACE WENDY J. TRACE Defendant(s). TO THE DIRECTOR OF THE OFFICE OF THE PROTHONOTARY: Issue writ of execution in the above matter: Amount Due $101,667.87 Interest from 2/13/06 to JUNE 7, 2006 (per diem -$16.71) $1,904.94 and Costs TOTAL $103,572.81 Note: Please attach description of property.No. IMPORTANT NOTICE: This property is sold at the direction of the plaintiff. It may not be sold in the absence of a representative of the plaintiff at the Sheriff's Sale. The sale must be postponed or stayed in the event that a representative of the plaintiff is not present at the sale. .0 .0 ~ .-- ... <it ~ ~ ~ ";J ~ ~v ~~ ~'O ~~ <it .;.~u ~ ~~ o~ ~'C~ % ~ ~z ~& ~ C OJ ~~ ~ ~~ ~...~ ~~ "'0 '" o...<it 'Clio< ~o OJ ~rJJ v~~ ...a p z. ....~ ~t ~ ~~ ...0,% ~~ o (j e ~~v OJ rJJ~ ~~~ ...... ~~ ~i '" ,,~... 'i> e~ ~...z. ,;, ~..; ~;c. ~ ... ~~ ~~ r- eM o~~ ~~ ~... OJ ...~ ~ov t~ o~ ~... ~ Ov ....-- ~o~ ~~ ~~ rJJ~ I;;, if, ~~ o~~ \ '[j ~<it~ "'i ! "\ ~~ 1 ~~~ :::: \Z-< ~\ .... .Z ~ ...vo J ~ ...z.v v v.... \) ... ..,~ -!t-n ~ I:.r: ~~-' ~....'.::~=-~ -:d 1 .::: ::. ::. " -:;;~'::. F'--:\\\ \11\ A f:J () <'i <::J ":t' C',Cl() Q, 'C>.. <:) ~ ~ :r Ul.~lil "vi ~ - <) VI G- w-<i ~ N) <<. ro "l (Y) l.1) '~.i_ t ~ ~ ~ \ 1.. ~ st -1 ~....( ;:::::, (j (J Ul rl ::>-' M -::r = -::r - ~ c-- t- :; l:- ~ ~--;. 1t cJ ~ f - .-- -------- WRIT OF EXECUTION and/or ATTACHMENT COMMONWEALTH OF PENNSYLVANIA) COUNTY OF CUMBERLAND) NO 05-5073 Civil CIVIL ACTION - LA W TO THE SHERIFF OF CUMBERLAND COUNTY: To satisfy the debt. interest and costs due CITIFINANCIAL MORTGAGE COMPANY, INC. F/K/A ASSOCIATESS HOME EQUITY CONSUMER DISCOUNT COMPANY INC Plaintiff (s) From STEVEN E. TRACE WENDY J. TRACE (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 gamishee(s) that: (a) an attachment has been issued; (b) the gamishee(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$101,667.87 Interest from 2/13/06 to JUNE 7, 2006 Atty's Comm % Atty Paid $226.84 Plaintiff Paid Date: February 27, 2006 L.L.$.50 (per diem-$16.71) $1,904.94 and Costs Due Prothy $1.00 Other Costs (Seal) By: Deputy REQUESTING PARTY: Name Daniel G. Schmieg, Esq. Address: One Penn Center at Suburban Station 1617 John F. Kennedy boulevard, Suite 1400 Philadelphia, PA 19103-1814 Attorney for: Plaintiff Telephone: Supreme Court ID No. PHELAN HALLINAN & SCHMIEG, L.L.P. By: DANIEL G. SCHMIEG Identification No. 62205 ONE PENN CENTER AT SUBURBAN STATION 1617 JOHN F. KENNEDY BLVD., SUITE 1400 PHILADELPHIA, PA 19103-1814 (215) 563-7000 ATTORNEY FOR PLAINTIFF CITIFINANCIAL MORTGAGE COMPANY, INC. F/K1A ASSOCIATESS HOME EQUITY CONSUMER DISCOUNT COMPANY, INC. CUMBERLAND COUNTY COURT OF COMMON PLEAS Plaintiff, CIVIL DIVISION v. NO. 05-5073 CIVIL TERM STEVEN E. TRACE WENDY J. TRACE Defendant(s). CERTIFICATION DANIEL G. SCHMIEG, ESQUIRE, hereby verifies that he is attorney for the Plaintiff in the above-captioned matter, and that the premises are not subject to the provisions of Act 91 because it is: o an FHA mortgage () non-owner occupied () vacant (X) Act 91 procedures have been fulfilled This certification is made subject to the penalties of 18 Pa. C.S. Section 4904 relating to unsworn falsification to authorities. ~---~ / l , ,,1 - \. CITIFINANCIAL MORTGAGE COMPANY, INC. F/KJA ASSOCIATESS HOME EQUITY CONSUMER DISCOUNT COMPANY, INC. CUMBERLAND COUNTY COURT OF COMMON PLEAS Plaintiff, v. CIVIL DIVISION STEVEN E. TRACE WENDY J. TRACE NO. 05-5073 CIVIL TERM Defendant(s). AFFIDAVIT PURSUANT TO RULE 3129 (Affidavit No. I) CITIFINANCIAL MORTGAGE COMPANY, INC. F/K/A ASSOCIATESS HOME EOUITY CONSUMER DISCOUNT COMPANY. INC., Plaintiff in the above action, by its attorney, DANIEL G. SCHMIEG, ESQUIRE, sets forth as of the date the Praecipe for the Writ of Execution was filed the following information concerning the real property located at ,297 BONNYBROOK ROAD. CARLISLE, P A 17013 . 1. Name and address ofOwner(s) orreputed Owner(s): Name Last Known Address (if address cannot be reasonably ascertained, please indicate) STEVEN E. TRACE 102 MEALS DRIVE CARLISLE, P A 17013 WENDY J. TRACE 711 BREEZEWOOD DRIVE MECHANICS BURG, PA 17055 2. Name and address ofDefendant(s) in the judgment: Same as above 3. Name and last known address of every judgment creditor whose judgment is a record lien on the real property to be sold: Name Last Known Address (if address cannot be reasonably ascertained, please indicate) None - .. 4. Name and address oflast recorded holder of every mortgage of record: Name Last Known Address (if address cannot be reasonably ascertained, please indicate) MGIC ASSURANCE CORP. 270 EAST KILBOURN AVENUE MILWAUKEE, WI 53202 ASSOCIATES HOME EQUITY CONSUMER DISCOUNT CO. 5080 C. JONES TOWN ROAD HARRISBURG, P A 17111 S. Name and address of every other person who has any record lien on the property: Name Last Known Address (if address cannot be reasonably ascertained, please indicate) None 6. Name and address of every other person who has any record interest in the property and whose interest may be affected by the sale. Name Last Known Address (if address cannot be reasonably ascertained, please indicate) None 7. Name and address of every other person of whom the plaintiff has knowledge who has any interest in the property which may be affected by the sale: Name Last Known Address (if address cannot be reasonably ascertained, please indicate) Tenant/Occupant 297 BONNYBROOK ROAD CARLISLE, PA 17013 Domestic Relations of Cumberland County 13 North Hanover Street Carlisle, PA 17013 Commonwealth of Pennsylvania Department of Welfare PO Box 2675 Harrisburg, PA 17105 I verify that the statements made in this affidavit are true and correct to the best of my personal knowledge or information and belief. I understand that false statements herein are made subject to the penalties ofl8 Pa. C.S. Sec. 4904 relating to unsworn falsification to authorities. February 22. 2006 DATE ->'. ';'.""', i,," ------- ~ { CITlFINANCIAL MORTGAGE COMPANY, INC. FIKIA ASSOClATESS HOME EQIDTY CONSUMER DISCOUNT COMPANY, INC. Plaintiff, CUMBERLAND COUNTY No. 05-5073 CIVIL TERM v. STEVEN E. TRACE WENDY J. TRACE Defendant(s). February 22, 2006 TO: STEVEN E. TRACE 102 MEALS DRIVE CARLISLE, P A 17013 WENDY J. TRACE 7II BREEZE WOOD DRIVE MECHANICSBURG, PA 17055 ""THIS FIRM IS A DEBT COLLECTOR ATTEMPTING TO COLLECT A DEBT AND ANY INFORMATION OBTAINED WILL BE USED FOR THAT PURPOSE. IF YOU HA VE PREVIOUSLY RECEIVED A DISCHARGE IN BANKRUPTCY AND THIS DEBT WAS NOT REAFFIRMED, THIS IS NOT AND SHOULD NOT BE CONSTRUED TO BE AN ATTEMPT TO COLLECT A DEBT, BUT ONLY ENFORCEMENT OF A LIEN AGAINST PROPERTY."" Your house (real estate) at, 297 BONNYBROOKROAD, CARLISLE, PA 17013, is scheduled to be sold at the Sheriff's Sale on JUNE 7, 2006 at 10:00 a.m. in the Cumberland County Courthouse, South Hanover Street, Carlisle, PA 17013, to enforce the court judgment of $101.667.87 obtained by CITIFINANCIAL MORTGAGE COMPANY. INC. F/K1A ASSOCIATESS HOME EOUITY CONSUMER DISCOUNT COMPANY, INC. (the mortgagee) against you. In the event the sale is continued, an announcement will be made at said sale in compliance with Pa.R.C.P., Rule 3129.3. NOTICE OF OWNER'S RIGHTS YOU MAYBE ABLE TO PREVENT THIS SHERlFF'S SALE To prevent this Sheriff's Sale, you must take immediate action: 1. The sale will be cancelled if you pay to the mortgagee the back payments, late charges, costs and reasonable attorney's fees due. To find out how much you must pay, you may call: (215) 563-7000. 2. You may be able to stop the sale by filing a petition asking the Court to strike or open the judgment, if the judgment was improperly entered. You may also ask the Court to postpone the sale for good cause. 3. You may also be able to stop the sale through other legal proceedings. \ You may need an attorney to assert your rights. The sooner you contact one, the more chance you will have of stopping the sale. (See notice on page two on how to obtain an attorney.) YOU MAY STILL BE ABLE TO SAVE YOUR PROPERTY AND YOU HAVE OTHER RIGHTS EVEN IF THE SHERIFF'S SALE DOES TAKE PLACE. 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 (215) 563-7000. 2. You may be able to petition the Court to set aside the sale if the bid price was grossly inadequate compared to the value of your property. 3. The sale will go through only if the buyer pays the Sheriff the full amount due in the sale. To find out if this has happened, you may call (717) 240-6390. 4. Ifthe amount due from the Buyer is not paid to the Sheriff, you will remain the owner of the property as ifthe sale never happened. 5. You have the right to remain in the property until the full amount due is paid to the Sheriff and the Sheriff gives a deed to the buyer. At that time, the buyer may bring legal proceedings to evict you. 6. You may be entitled to a share of the money which was paid for your house. A schedule of distribution of the money bid for your house will be filed by the Sheriff within 30 days of the sale. This schedule will state who will be receiving that money. The money will be paid out in accordance with this schedule unless exceptions (reasons why the proposed distribution is wrong) are filed with the Sheriff within ten (10) days after the distribution is filed. 7. You may also have other rights and defenses, or ways of getting your home back, if you act immediately after the sale. YOU SHOULD TAKE THIS PAPER TO YOUR LAWYER AT ONCE. IF YOU DO NOT HAVE ALA WYER OR CANNOT AFFORD ONE, GO TO OR TELEPHONE THE OFFICE LISTED BELOW TO FIND OUT WHERE YOU CAN GET LEGAL HELP. IMPORTANT NOTICE: This property is sold at the direction of the plaintiff. It may not be sold in the absence of a representative of the plaintiff at the Sheriff's Sale. The sale must be postponed or stayed in the event that a representative of the plaintiff is not present at the sale. CUMBERLAND COUNTY ATTORNEY REFERRAL CUMBERLAND COUNTY BAR ASSOCIATION 2 LIBERTY AVENUE CUMBERLAND COUNTY COURTHOUSE .,,' I ALL THAT CERTAIN \<Jt or parcel of land loca1ed in South Midd1etown Township, Cumberland County. Pennsylvania. more particularly bounded and described as follows. 10 wit: BEGINNING at a point marked at the intersection of Bonnybrook Road (T-516) and Heiser Lane (T- 513), thence North 35 degrees 5 minutes 10 seconds West along Donnyhrook Road, a c11R\llnce of 125 feet 10 an iron pin; thence North 76 degrees 19 minutes 10 seconds Easl along the boundary line between Lot 6 and 7. a distance of 722.94 teet 10 an iron pin; thence South 25 degrees 6 minutes 27 seconds Easl along the boundary line between Lot S and 6, a distance of 150 feet to an iron pin; thence South 80 degrees 53 minutes 28 seconds West along Heiser Lane. a distance of 186.34 feet to an iron pin. thence radius 25 feet. a distance of 27.94 feet 10 an iron pin. the place of beginning. CONTAINING 29.113.98 square feet. TOGETHER with existing dweUing and improvements lbereon. BEING Lot No.6 of the plan of lots for Raymond E. Diehl, Genevieve A. Diehl. Donald E. Diehl and Snzaone Diehl. prepared by Stephen F. Fisber. and dated November 2. 1981. which plan is of record at Plan Book 41. Page 66. Tax Parcel #40-10.0634-047 TITLE TO SAID PREMISES IS VESTED IN Steve E. Trace and Wendy J, Trace, his wife by Deed from John L. Neimer and Ann E. Neimer. his wife. dated 4/29/1991 and recorded 4/30/1991 in Deed Book B Volume 35, Page 1035. Premises: 297 Bonnybrook Road, Carlisle, P A 17013 {". P~TIFF CUMBERlAND COUNTY ClTIFINANCIAL MORTGAGE COMPANY, INe. FOOA ASSOClATESS HOME EQUITY CONSUMER DISCOUNT COMPANY, INC. KIO No. 05-5073 CIVIL TERM ACCT. #652065 DEFENl)ANT(S) STEVEN E. TRACE WENDY J. TRACE Type of Action - Notice of SheriW. Sale SERVE STEVEN E. TRACE AT 102 MEALS DRIVE CARLISLE, PA 17013 Sale Date: JUNE 7, 2006 SERVED Served and made known 10 <'I e LI e '" -rr .q L e. . Defendanl, on lbe ad:)!; .0'c1ockL.m.al ,oJ- m,o(s J, C<>,,//s!e (If Odl3 !i rh day of fh"'rL- h ~ " .200b., ! . Commonwealth of Pennsylvania, in the manner described below: L_Defenrlanl personally served. Adult family member wilb whom Defendant(s) reside(s). Name and Relationship is __Adult in charge of Defendanl(s)"s residence who refused 10 give name or relationship. ___Manager/Clerk of place oflodging in which Defendanl(s) reside(s). m_._____Agent or person in charge ofDefendant(s)'s office or usual place of business. ...__.__ an officer of said Defendant(s)'s company. Olber: Description: Ageff-'If H - h - I I, elg t!LQ...... Weighl---LJi..i. Race .1d..- Sex ----'"lL Olber J. )., .~ I!) I; r . a compelent adull, being duly sworn according to law, depose and state that J personally handed a true and correct copy of the Notice of Sheriffs Sale in the manner as set forth herein, issued in the captioned case on the date and at lbe address indicated above. l~otc:rV PL:J!IC NOT SERVED State c; New Jersey ~ of . 200~ at o'clock _.m., Defendant NOT FOUND because: C()rrmissioil Expires June 16, 2008 Moved _ Unknown _ No Answer Vacant I" Attempt: I I Time: 20' Attempt: I I Time: 3rd Attempt: I / Time: Sworn to and subscnoed before me this __ day of . 200 _' Notary: By: Attornev for Plaintiff Daniel G. Schmieg, Esquire - J.D. No. 62205 -', I ,7--- (") c: r:- ~. 0.,) -' ~~ ?.! ~i .._.J :C-q iTir=- w:. "c'" I',) 0-' \,>, !"-.) - lAINTIFF AFFIDAVIT OF SERVICE CUMBERLAND COUNTY CITIFINANCIAL MORTGAGE COMPANY, INC. FIKIA ASSOCIATESS HOME EQIDTY CONSUMER DISCOUNT COMPANY, INC. KlO No. 05-5073 CIVIL TERM ACCT. #652065 DEFENJ1ANT(S) STEVEN E. TRACE WENDY J. TRACE Type of Action - Notice of Sheriff's Sale SERVf w ~;NDY J. TRACE AT "i'! IlREEZEWOOD DRIVE 'c1FCIIANICSBURG, PA 17055 Sale Date: JUNE 7, 2006 Served ~< '1 ",,,Ie known to i ^ J '-11,1 ~ . 6'11.... u ..(j__~_. o'clockL.m, at IrClC.e 7116rl.L"".,J,'ock SERVED ?A day of 1,1",., h i 7~<)<;- ,200C€ .1 . Defendant, on the ~ ,t iI1u["..~, dJ'"J t}> ,COnll1' -,tlth of Pennsylvania, in the manner described below: 1 '.'I(13ot personally served. , II' \[ family member with whom Defendant( s) reside( s). Name and Relationship is ".,l(tll in charge ofDefendant(s)'s residence who refused to give name or relationship. ::, ';"',er/Clerk of place oflodging in which Defendant( s) reside(s). ;,t nr person in charge ofDefendant(s)'s office or usual place of business. an officer of said Defendant(s)'s company. , Hh~r' Descriri:~;!l Age~ Height..i:_~/'" Weight..L.L:.... Race vJ SexL- Other I, --.J"", ('>._ ~ J I , s . a competent adult. being duly sworn according to law, depose and state that I persona;,!" !landed a true and correct copy of the Notice of Sheriff's Sale in the manner as set forth herein, issued in the captiOlwrJ . 1~e on the date and at the address indicated above. NOT SERVED On the ._ day of . 200~ at o'clock _.m., Defendant NOT FOUND because, \.,joved Unknown No Answer Vacant 1st Atk1llpl:. I I Time: 2nd Attempt: I I Time: 3rd All"mpt: I I Time: Sworn if! aiUl subscnbed before T"~' jl'l~, _.____ day of_..200_. Notary By: Attorney J~L~!aiDtiff Daniel C, ':'c.'Junieg, Esquire I.D. No. .,n05 1 '" OJ -... ::c.",... :;-:::; r"-..) (.,.,) f",J :1':- W ., "'I SALE DATE: JUNE 7.2006 IN THE COURT OF COMMON PLEAS OF CUMBERLAND COUNTY, PENNSYLVANIA CIVIL ACTION - LAW CITIFlNANCIAL MORTGAGE COMPANY, INC. F/KIA ASSOCIATESS No.: 05-5073 CIVIL TERM HOME EQillTY CONSUMER DISCOUNT COMPANY, INC. vs. STEVEN E. TRACE WENDY J. TRACE AFFIDAVIT PURSUANT TO RULE 3129.1 AND RETURN OF SERVICE PURSUANT TO Pa. R.C.P. 405 OF NOTICE OF SALE Plaintiff in the above action sets forth as of the date the Praecipe for the Writ of Execution was filed the following information concerning the real property located at: 297 BONNYBROOK ROAD. CARLISLE. P A 17013. As required by Pa. R.C.P. 3129.2(a) Notice of Sale has been given in the manner required by Pa. R.C.P. 3129.2(c) on each of the persons or parties named, at that address set forth on the attached Affidavit No.2 (previously filed) and Amended Affidavit No.2 on the date indicated, and a copy of the notice is attached as an Exhibit. A copy ofthe Certificate of Mailing (Form 3817) and/or Certified Mail Return Receipt stamped by the U.S. Postal Service is attached for each notice. %w;) .JJ.~ DANIEL SCHMIEG, ESQ Attorney for Plaintiff June 2, 2006 , . l:lTJ..lt'INANCIAL MORTGAGE COMPANY, INC. FIKJA ASSOCIATESS HOME EQUITY CONSUMER DISCOUNT COMPANY, INC. CUMBERLAND COUNTY COURT OF COMMON PLEAS Plaintiff, v. CIVIL DIVISION STEVEN E. TRACE WENDY J. TRACE NO. 05-5073 CIVIL TERM Defendant(s). AFFIDAVIT PURSUANT TO RULE 3129 (Affidavit No. I) CITIFINANCIAL MORTGAGE COMPANY. INC. FIKIA ASSOCIATESS HOME EQUITY CONSUMER DISCOUNT COMPANY. INC., Plaintiff in the above action, by its attorney, DANIEL G, SCHMIEG, ESQUIRE, sets forth as of the date the Praecipe for the Writ of Execution was filed the following information concerning the real property located at .297 BONNYBROOK ROAD. CARLISLE. P A 17013 . 1. Name and address of Owner(s) or reputed Owner(s): Name Last Known Address (if address cannot be reasonably ascertained, please indicate) STEVEN E. TRACE 102 MEALS DRIVE CARLISLE, P A 17013 711 BREEZEWOOD DRIVE MECHANICSBURG, PA 17055 WENDY J. TRACE 2. Name and address ofDefendant(s) in the judgment: Same as above 3. Name and last known address of every judgment creditor whose judgment is a record lien on the real property to be sold: Name Last Known Address (if address cannot be reasonably ascertained, please indicate) None ,. , 4. Name and address oflast recorded holder of every mortgage of record: Name Last Known Address (if address cannot be reasonably ascertained, please indicate) MGIC ASSURANCE CORP. 270 EAST KILBOURN AVENUE MILWAUKEE, WI 53202 ASSOCIATES HOME EQUITY CONSUMER DISCOUNT CO. 5080 C. JONESTOWN ROAD HARRISBURG, P A 17111 5. Name and address of every other person who has any record lien on the property: Name Last Known Address (if address cannot be reasonably ascertained, please indicate) None 6. Name and address of every other person who has any record interest in the property and whose interest may be affected by the sale, Name Last Known Address (if address cannot be reasonably ascertained, please indicate) None 7. Name and address of every other person of whom the plaintiffhas knowledge who has any interest in the property which may be affected by the sale: Name Last Known Address (if address cannot be reasonably ascertained, please indicate) Tenant/Occupant 297 DONNYBROOK ROAD CARLISLE, P A 17013 Domestic Relations of Cumberland County 13 North Hanover Street Carlisle, P A 17013 Commonwealth of Pennsylvania Department of Welfare PO Box 2675 Harrisburg, P A 17105 I verify that the statements made in this affidavit are true and correct to the best of my personal knowledge or information and belief. I understand that false statements herein are made subject to the penalties ofl8 Pa. C.S. Sec. 4904 relating to unsworn falsification to authorities. ","_____.,___..._u_____._ February 22. 2006 DATE · DArtE: .;) I r;). d- I ()b CITIFINANCIAL MORTGAGE COMPANY, INC. FIK/A ASSOCIATESS HOME EQUITY CONSUMER DISCOUNT COMPANY, INC. vs. STEVEN E. TRACE WENDY J. TRACE TO: ALL PARTIES IN INTEREST AND CLAIMANTS NOTICE OF SHERIFF'S SALE OF REAL PROPERTY OWNER(S): STEVEN E. TRACE WENDY J. TRACE PROPERTY: 297 DONNYBROOK ROAD CARLISLE, P A 17013 Improvements: Residential dwelling Judgment Amount: $101,667.87 CUMBERLAND COUNTY NO. 05-5073 CIVIL TERM The above-captioned property is scheduled to be sold at the Cumberland County Sheriffs Sale on JUNE 7, 2006, at the Cumberland County Courthouse, South Hanover Street, Carlisle, P A at 10:00 a.m.. Our records indicate that you may hold a mortgage, judgment, or other interest on the property, which may be extinguished by the sale. You may wish to attend the sale to protect your interests. If you have any questions regarding the type of lien or the effect of the Sheriff's Sale upon your lien, we urge you to CONTACT YOUR OWN ATTORNEY, as we are not permitted to give you legal advice. The Sheriff will file a schedule of Distribution 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, . l' ~ 00 ~ ~ ~ ~ W N - ~ (II "'0-,1 ~'g ...... ....... ...... ....... ....... ....... "'Z ~ ~ W N - 0 it ~~ J ~~g.~!:l 8 8 =. il Ii Cn~R8E ~li8a~ i i. iJ. s ~ ; g g. ~t.;;;s,~ ~ ~~~ Ei' 2"s g~~~ G' [Ii fi 8 II' ~ ~ 0 aJ;:. ~~ "!1 ~Rilr <l i'ig. ca. <l! [ . i: I' tt.~g. a~Xil -~ ~ ii ~. .,. II ca. 91>Ili 088 a. ~f g.~ i ~ i. Ri . R I ~. *'rll.6 rr~J g. rr ~J. a:: 5 8-g ~~ll f G''9.1> !. ~ ~ ~Oi en gi ~ ~~ tr.I ~i ~ Q II l~ '" Q I Q W II j: ~ Cl ~ ~ ~ ~ ~ ( ~ > ~ 0 ~ t ~ ~ 8 ~ ~ ! ! ~ ~ ~ ~ ! iO 0 ~~ ~ @ ~ s~~ >-geni :;j.~~oo (') N ttl Z 'Tj ~ ~ ~ ~ ~ ~ f !~~j~tI1. en ttl ~ t::l (') 0 tI1 i !~ i ~ ~ til~ ~c; o~... oz o a: ~ 'Tj' 0 of;' ~ ~ Z ~ > l' ::z:: ~ > ~ ~ ~ ~ ~ W ~ 0 Z tI1 >-g-< ~ ~ ~ ~ e;'" 0 en . C'J ><~ ~ s ~ ~~ ~ ~ g ~ ~ ... 9 en en ." ttl ~ > ~ ~ ~ 9 ~ - - - ~ ~ - - ~ W - o ~ ~t-~~ Q ~ . Iff.. (i. ~ .::;"...... ~ I : ~.,,-~ - '---' I'fTNEV I19WEs 02 1A $ 01 .. ~~ . 0004309825 MA ~ ,_550 . MAILED FROM ZIP R 0-1 2006 CODE 19103 ~ n' CD z c 3 tr CD ., 0>2: "'Cl.~ CJ)c=.51 ~ "1 ~ = ~ ~ Cl.~= Sl c=. ""C......o""C a:~6"t:C - om g.-....J""Ct""' oO'~> -ossz ~'Tj()itl ;, ~dl F >~~t""' ......s~t:::::j \O(lI.....L, o~ CJ) >- w g.z ~lS'~Ro ~E.d"'tzl .J:>;$!~() ~J~~ ~ g.~ tiltzl::SO S. t-< ~ ft . ~...... t""' .J:>; . o ;c ~o t"l t"l ... en ::::: m .., a :J.. s: CD ~ CD " (6' 0:: ~ UI :J o - 0- c: :J a. S' ::r CD Q) a. CD .., .., CD o o a. o - a. Q) - Q) UI o c: o ~ ~~ r--:> g ~::1"""\ I en 2: c:? C::) COMMONWEALTH OF PENNSYLVANIA COUNTY OF CUMBERLAND }SS: I, Robert P. Ziegler, Recorder of Deeds in and for said County and State do hereby certify that the Sheriff's Deed in which Citifinancial Mtg Co inc 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 27th day of February, A.D., 2006, out of the Court of Common Pleas of said County as of Civil Term, 2005 Number 5073, at the suit ofCitifinancial Mtg Co against Steven E Trace & Wendy J is duly recorded in Deed Book No. 275, Page 1851. IN TESTIMONY WHEREOF, I have hereunto set my hand and 1 of said office this d 9 -tt day of , A.D, ct tM t Citifinancial Mortgage Company, Inc. f/kla Associated Home Equity Consumer Discount Company, Inc, VS Steven E. Trace and Wendy J. Trace The Court of Common Pleas of Cumberland County, Pennsylvania Writ No. 2005-5073 Civil Robert Bitner, Deputy Sheriff, who being duly sworn according to law, states that on March 08,2006 at 02:58 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: Steven E. Trace, by making known unto Steven Trace, personally, at 102 Meals Drive, Carlisle, Cumberland County, Pennsylvania, its contents and at the same handing him the said true and correct copy of the same. Brian Barrick, Deputy Sheriff, who being duly sworn according to law, states that on March 16,2006 at 06:34 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: Wendy J. Trace, by making known unto Wendy Trace, personally, at 711 Breezewood Drive, Mechanicsburg, Cumberland County, Pennsylvania, its contents and at the same handing her the said true and correct copy of the same. William Cline, Deputy Sheriff, who being duly sworn according to law, states that on April 06, 2006 at 7:40 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 Steven E. Trace and Wendy J. Trace located at 297 Bonnybrook Road, Carlisle, 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: Steven J. Trace and Wendy J. Trace by regular mail to their last known addresses of 102 Meals Drive, Carlisle, PA 17013 and 711 Breezewood Drive, Mechanicsburg, P A 17055, respectively. These letters were mailed under the date of April 06, 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 07, 2006 at 10:00 o'clock A.M. He sold the same for the sum of $1,00 to Attorney Daniel G. Schmieg for Citifinancial Mortgage Company, Inc. f/kla Associates Home Equity Consumer Discount Company, Inc. It being the highest bid and best price received for the same, Citifinancial Mortgage Company, Inc. f/kla Associates Home Equity Consumer Discount Company, Inc. of 8333 Ridge Point Drive, Irving, TX 75063, being the buyer in this execution, paid to SheriffR. Thomas Kline the sum of$910.87. Sheriffs Costs: Docketing Poundage Posting Bills Advertising Acknowledging Deed Auctioneer Law Library Prothonotary Mileage Certified Mail Levy Surcharge Law Journal Patriot News Share of Bills Distribution of Proceeds Sheriffs Deed So Answers: $30.00 17.86 15.00 15.00 30.00 10,00 .50 1.00 19.36 4.88 15.00 30.00 371. 00 267.20 19.57 25.00 39.50 $ 910.87 / ~ r~~ R. Thomas Kline, Sheriff rf /J 8 j()v ryYV -1'1.> '10' ..- _/ 5D I. r../(... 5' It f/J 2..- tl.U/' / FO t.; 3/ CITIFINANCIAL MORTGAGE COMPANY, INC. , FIKIA ASSOCIATESS HOME EQUITY CONSUMER DISCOUNT COMPANY, INC. CUMBERLAND COUNTY COURT OF COMMON PLEAS Plaintiff, v. CIVIL DIVISION STEVEN E. TRACE WENDY J. TRACE NO. 05-5073 CIVIL TERM Defendant(s). AFFIDAVIT PURSUANT TO RULE 3129 (Affidavit No.1) CITIFINANCIAL MORTGAGE COMPANY~ INC. F/KJA ASSOCIATESS HOME EQUITY CONSUMER DISCOUNT COMPANY~ INC., Plaintiff in the above action, by its attorney, DANIEL G. SCHMIEG, ESQUIRE, sets forth as of the date the Praecipe for the Writ of Execution was filed the following information concerning the real property located at ~297 BONNYBROOK ROAD~ CARLISLE~ P A 17013 . 1. Name and address ofOwner(s) or reputed Owner(s): Name Last Known Address (if address cannot be reasonably ascertained, please indicate) STEVEN E. TRACE 102 MEALS DRIVE CARLISLE, P A 17013 WENDY J. TRACE 711 BREEZEWOOD DRIVE MECHANICSBURG, P A 17055 2, Name and address ofDefendant(s) in the judgment: Same as above 3. Name and last known address of every judgment creditor whose judgment is a record lien on the real property to be sold: Name Last Known Address (if address cannot be reasonably ascertained, please indicate) None 4. Name and address of last recorded holder of every mortgage of record: Name Last Known Address (if address cannot be reasonably ascertained, please indicate) MGIC ASSURANCE CORP. 270 EAST KILBOURN AVENUE MILWAUKEE, WI 53202 ASSOCIATES HOME EQUITY CONSUMER DISCOUNT CO. 5080 C. JONESTOWN ROAD HARRISBURG, P A 17111 5. Name and address of every other person who has any record lien on the property: Name Last Known Address (if address cannot be reasonably ascertained, please indicate) None 6. Name and address of every other person who has any record interest in the property and whose interest may be affected by the sale. Name Last Known Address (if address cannot be reasonably ascertained, please indicate) None 7. Name and address of every other person of whom the plaintiff has knowledge who has any interest in the property which may be affected by the sale: Name Last Known Address (if address cannot be reasonably ascertained, please indicate) Tenant/Occupant 297 BONNYBROOK ROAD CARLISLE, PA 17013 Domestic Relations of Cumberland County 13 North Hanover Street Carlisle, PA 17013 Commonwealth of Pennsylvania Department of Welfare PO Box 2675 Harrisburg, PA 17105 I verify that the statements made in this affidavit are true and correct to the best of my personal knowledge or information and belief. I understand that false statements herein are made subject to the penalties ofl8 Pa. C.S. Sec. 4904 relating to unsworn falsification to authorities. February 22. 2006 DATE ~ , CITIFINANCIAL MORTGAGE COMPANY, INC. FIKIA ASSOCIATESS HOME EQUITY CONSUMER DISCOUNT COMPANY, INC. Plaintiff, CUMBERLAND COUNTY No. 05-5073 CIVIL TERM v. STEVEN E. TRACE WENDY J. TRACE Defendant( s). February 22,2006 TO: STEVEN E. TRACE 102 MEALS DRIVE CARLISLE, P A 17013 WENDY J. TRACE 711 BREEZEWOOD DRIVE MECHANICSBURG, P A 17055 * * THIS FIRM IS A DEBT COLLECTOR AITEMPTING TO COLLECT A DEBT AND ANY INFORMATION OBTAINED WILL BE USED FOR THAT PURPOSE. IF YOU HA VE PREVIOUSLY RECEIVED A DISCHARGE IN BANKRUPTCY AND THIS DEBT WAS NOT REAFFIRMED, THIS IS NOT AND SHOULD NOT BE CONSTRUED TO BE AN AITEMPT TO COLLECT A DEBT, BUT ONLY ENFORCEMENT OF A LIEN AGAINST PROPERTY. ** Your house (real estate) at ~ 297 BONNYBROOK ROAD~ CARLISLE~ P A 17013~ is scheduled to be sold at the Sheriffs Sale on JUNE 7 ~ 2006 at 10:00 a.m. in the Cumberland County Courthouse, South Hanover Street, Carlisle, P A 17013, to enforce the court judgment of$101~667.87 obtained by CITIFINANCIAL MORTGAGE COMPANY~ INC. F/K/A ASSOCIATESS HOME EQUITY CONSUMER DISCOUNT COMPANY~ INC. (the mortgagee) against you. In the event the sale is continued, an announcement will be made at said sale in compliance with Pa.R.C.P., Rule 3129.3. NOTICE OF OWNER'S RIGHTS YOU MAY BE ABLE TO PREVENT THIS SHERIFF'S SALE To prevent this Sheriffs Sale, you must take immediate action: 1. The sale will be cancelled if you pay to the mortgagee the back payments, late charges, costs and reasonable attorney's fees due. To find out how much you must pay, you may call: (215) 563-7000. 2. You may be able to stop the sale by filing a petition asking the Court to strike or open the judgment, if the judgment was improperly entered. You may also ask the Court to postpone the sale for good cause. 3. You may also be able to stop the sale through other legal proceedings. . You may need an attorney to assert your rights, The sooner you contact one, the more chance you will have of stopping the sale. (See notice on page two on how to obtain an attorney.) YOU MAY STILL BE ABLE TO SAVE YOUR PROPERTY AND YOU HAVE OTHER RIGHTS EVEN IF THE SHERIFF'S SALE DOES TAKE PLACE. 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 (215) 563-7000. 2. You may be able to petition the Court to set aside the sale if the bid price was grossly inadequate compared to the value of your property, 3. The sale will go through only if the buyer pays the Sheriff the full amount due in the sale. To find out if this has happened, you may call (717) 240-6390. 4. If the amount due from the Buyer is not paid to the Sheriff, you will remain the owner of the property as if the sale never happened. 5. You have the right to remain in the property until the full amount due is paid to the Sheriff and the Sheriff gives a deed to the buyer. At that time, the buyer may bring legal proceedings to evict you. 6. You may be entitled to a share of the money which was paid for your house. A schedule of distribution of the money bid for your house will be filed by the Sheriff within 30 days of the sale. This schedule will state who will be receiving that money. The money will be paid out in accordance with this schedule unless exceptions (reasons why the proposed distribution is wrong) are filed with the Sheriff within ten (10) days after the distribution is filed. 7. You may also have other rights and defenses, or ways of getting your home back, if you act immediately after the sale. YOU SHOULD TAKE THIS PAPER TO YOUR LAWYER AT ONCE. IF YOU DO NOT HAVE A LAWYER OR CANNOT AFFORD ONE, GO TO OR TELEPHONE THE OFFICE LISTED BELOW TO FIND OUT WHERE YOU CAN GET LEGAL HELP. IMPORTANT NOTICE: This property is sold at the direction of the plaintiff, It may not be sold in the absence of a representative of the plaintiff at the Sheriff's Sale. The sale must be postponed or stayed in the event that a representative of the plaintiff is not present at the sale. CUMBERLAND COUNTY ATTORNEY REFERRAL CUMBERLAND COUNTY BAR ASSOCIATION 2 LIBERTY AVENUE CUMBERLAND COUNTY COURTHOUSE ALL THAT CERT AlN lot or parcel of land located in South Middletown Township, Cumberland County. Pennsylvania, more particularly bounded and described as follows, to wit: BEGINNING at a point marked at the intersection of Bonnybrook Road (T-SI6) and Heiser Lane (1'- 513). thence North 35 degrees 5 minutes 10 seconds West along Bonnybrook Road, a distmce of 125 feet to an iron pin; thence North 76 d~ 19 minutes 10 seconds EasI: along the boundary line between Lot 6 and 1, a distance of 722.94 feet to an iron pin; thence South 25 degrees 6 minutes 27 seconds East along the boundary line between Lot 5 and 6, a distance of 150 feet to an iron pin; thence South 80 degrees 53 minutes 28 seconds West along Heiser Lane, a distance of 186.34 feet to an iron pin, thence radius 25 feet, a distance of 27.94 feet to an iron pin. the place of beginning. CONTAINING 29.113.98 square feet. TOGETHER with existing dwelling and improvements tberoon. BEING Lot No.6 of the plan of lots for Raymond E. Diehl, Genevieve A. Diehl, Donald E. Diehl and Suzanne Diehl, prepared by Stephen F, Fisher. and dated November 2, 1981, which plan is of record at Plan Book 41, Page 66. Tax Parcel #40-10-.0634-047 TITLE TO SAID PlWMISES IS VESTED IN Steve E. Trace and Wendy J. Trace, his wife by Deed from John L. Neimer and Ann E. Neimer, his wife, dated 4f291l991 and recorded 4/30/1991 in Deed Book B Volume 35. Page 1035. Premises: 297 Bonnybrook Road, Carlisle, PA 17013 WRIT OF EXECUTION and/or ATTACHMENT COMMONWEALTH OF PENNSYLVANIA) COUNTY OF CUMBERLAND) NO 05-5073 Civil CIVIL ACTION - LAW TO THE SHERIFF OF CUMBERLAND COUNTY: To satisfy the debt, interest and costs due CITIFINANCIAL MORTGAGE COMPANY, INC. F/K/A ASSOCIATESS HOME EQUITY CONSUMER DISCOUNT COMPANY INC Plaintiff (s) From STEVEN E. TRACE WENDY J. TRACE (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 garnishee(s) that: (a) an attachment has been issued; (b) the garnishee(s) is enjoined from paying any debt to or for the account of the defendant (s) and from delivering any property of the defendant (s) or otherwise disposing thereof; (3) If property of the defendant(s) not levied upon an subject to attachment is found in the possession of anyone other than a named garnishee, you are directed to notify himlher that he/she has been added as a garnishee and is enjoined as above stated. Amount Due$101,667,87 Interest from 2/13/06 to .JlJl'\"'E 7, 2006 Atty's Comm % Atty Paid $226,84 Plaintiff Paid Date: February 27, 2006 L.L.$,50 (per diem-$16.71) $1,904.94 and Costs Due Prothy $1.00 Other Costs (Seal) By: Deputy REQUESTING PARTY: Name Daniel G. Schmieg, Esq. Address: One Penn Center at Suburban Station 1617 John F. Kennedy boulevard, Suite 1400 Philadelphia, PA 19103-1814 Attorney for: Plaintiff Telephone: Supreme Court ID No. Real Estate Sale # 73 On March 06, 2006 the Sheriff levied upon the defendant's interest in the real property situated in South Middleton Township, Cumberland County, P A filed with this writ and by this reference incorporated herein. ~ cu=u CVi1 t::::::J ~ IniiJ Known and numbered as 297 Bonnybrook Road, Carlisle, more fully described on Exhibit "A" Date: March 06, 2006 By: _J C ct~-t Vyu ( L1 Real Estate Sergeant o 11 :01 \-1 -. V c: - tWW qaDZ ~, l .'. ..;_ "j ( Ii"; -" I ~ " "- . I ~ :J: ..J .::i I (j .:1 Ii S j 0 .:~ '1/ (~ in ~...~. ..:J.:Jv ,~ 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 S ALE #73 . CUMBERLAND COUNTY SHERIFF'S OFFICE CUMBERLAND COUNTY COURTHOUSE CARLISLE, PA. 17013 REAL ESTATE.... No. 73 ",._. ",1m ~u , CidTerm I~~=:~= Consumer .DIlIcaUnt~y, Inc. VS Steven E.1\'ace and Wendy J. . TnIce Attorney DanIId SchmIeg DESC8IPTION AIL TIIAT CElUAIN lot or parcel of land located in South Middletown Township, Cumberland County, Pamsylvania, more particularly llouDd aud described as follows, to wit: BEGINNlNG at a point marked at the intenCction of BoonybrootRoad (1'-516) and Heiser Lane (T-5I3), tIal:eNorth 35 degrees 5 minutes 10 secoDds West aIoDg hmybroci: Road, a distance of 125 feet to an ~ pin; thence North 76 degrees J 9 minutes 10 secoods. East along the boundary line between Lot 6 aud 7, a dislance of 72294 feet to an _ pin; tbeate SouIh 25 degrees 6 minuIes 'l1 sec:oods But abIg' the bolmdaty line between Lot 5l1111l6, a cIiilIIDce m i~ feet to !JIl iron pin; tbmce south 80,~ 53 miDutes 28 secoods West aloog ~'r.aDe, a distaIlce of 18634 feet to an _ pin,dIeocc JBdius 25 feet, a distance of 'l194 feet to an iron pin. the place of BEGINNING. CONTAINING 29,1 13,9hplire feet. TOGETHER .with 'e~ dwelling . and imp:ovanents tbenlon. BEING Lot No. ft of the plan of lots for Raymond E.DiehI, Geuevjeve A.Diehl, Dooald E. Diehlllllll Suzanne Dial.,JiIIPlRdby Stephen F. Fisber,8Dd dared~, 1981, wbich plan is of reaxdaa PIIn Book 41 ,Page 66. TAXPARCIlLf 4()..16-0634-047 1Tn.E ro sAID PRI!MISES is vC$d in SIeveII E. ~._ WcmdY J. Trace, his wife by DeellfBlm JolIn L. NeiDIIr. -- E; Naurl. his wife. ..411911991..........413011991 in~~.~3S,...1035 WmrW ;..... .ilJl.m..... Cadi8Ie, FA: m3 PROOF OF PUBLICATION OF NOTICE IN CUMBERLAND LAW JOURNAL (Under Act No. 587, approved May 16,1929), P. L.1784 COMMONWEALTH OF PENNSYLVANIA 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. , Editor ORN TO AND SUBSCRIBED before me this 21 day of April, 2006 NOT {..,P!AL SEAL LO!S E. ;:Y'WDER. Noiary Public Q.. (',,,.\ 1.,,1-\ Bf'"" ("Lln'b':;'..!'lll'< ('. Ol.lnty. I I...._'I..:.'_.L. -~!t;'f .,'~ I vii!.,", \1 VI - , ~'~\' C.........,,,,j..,",.,,., l\""""h 5 '\')0" ~_ .,\of,.--l 1,-/,; ~!, \ ~,-1!',~1 ic1t;. ~l \; f"_', -~., kl1ia..IIII.Jr.....lIo.l' IlIRilfilliM~>tW\[Il,Je'\V'_M'8:l'/J ~~__~m*~.,;:!)\.I"..,.,..... REAL ESTATE SALE NO. 73 Writ No. 2005-5073 Civil Citifinanc1al Mortgage Company, Ine, f/k/ a Associates Home Equity Consumer Discount Company, Inc. vs. Steven E. Trace and Wendy J. Trace Atty,: Daniel Schmieg ALL THAT CERTAIN lot or par- cel of land located in South Middletown Township. Cumberland County, Pennsylvania, more par- ticularly bounded and described as follows, to wit: BEGINNING at a point marked at the intersection of Bonnybrook Road (T -516) and Heiser Lane (T- 513), thence North 35 degrees 5 minutes 10 seconds West along Bonnybrook Road, a distance of 125 feet to an iron pin; thence North 76 degrees 19 minutes 10 seconds East along the boundary line be- tween Lot 6 and 7, a distance of 72~.94 feet to an iron pin; thence South 25 degrees 6 minutes 27 sec- onds East along the boundary line between Lot 5 and 6, a distance of 150 feet to an iron pin; thence South 80 degrees 53 minutes 28 seconds West along Heiser Lane, a distance of 186.34 feet to an iron pin. thence radius 25 feet, a distance of 27.94 feet to an iron pin, the place of be- ginning. CONTAINING 29, I I3.98 square feet. TOGETHER with existing dwell- ing and improvements thereon. BEING Lot No.6 of the plan of lots for Raymond E. Diehl, Genevieve A. Diehl. Donald E. Diehl and Suzanne Diehl, prepared by Stephen F. Fisher, and dated No- vember 2, 1981, which plan is of record at Plan Book 41, Page 66. Tax Parcel #40-10-0634-047 TITLE TO SAID PREMISES IS VESTED IN Steve E. Trace and Wendy J. Trace, his wife by Deed from John L. Neimer and Ann E. Neimer. his wife, dated 4/29/1991 and recorded 4/30/1991 in Deed Book B Volume 35, Page 1035. Premises: 297 Bonnybrook Road, Carlisle, PA 17013.