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Home My WebLink About01-5302#8824 MARTHA E. VON ROSENSTIEL, MARTHA E. VON ROSENSTIEL, 16 SOUTH LANSDOWNE AVENUE PO BOX 457 LANSDOWNE, PA 19050 Attorney ID # 52634 Manufacturers & Traders Trust Company, trustee One M & T Plaza Buffalo, NY 14203-2399 Plaintiff, vs. Pamela Stofko 730 Franklin Street Carlisle, PA 17013, Defendant (s) ESQUIRE P.C. Attorney for Plaintiff COURT OF COMMON PLEAS Cumberland COUNTY CIVIL ACTION - MORTGAGE FORECLOSURE THIS IS AN ATTEMPT TO COLLECT A DEBT ANY INFORMATION OBTAINED WILL BE USED FOR THAT PURPOSE NOTICE ADVISO 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 by the court without further notice for any money claimed in the complaint or for any other claim or relief requested by the plaintiff. You may lose money or property or other rights important to you. YOU SHOULD TAKE THIS PAPER TO YOUR LAWYER AT ONCE. IF YOU DO NOT HAVE A LAWYER OR CANNOT AFFORD ONE. GO TO OR TELEPHONE THE OFFICE SET FORTH BELOW TO FIND OUT WHERE YOU CAN GET LEGAL HELP. Le han demandado a usted en la corte. Si usted quiere defenderse de estas demandas expuestas en las paginas siguientes, usted tiene veinte (20) dias de plazo al partir de la fecha de la demanda y la notificacion. Hace falta a santar una comparencia escrita o en persona o con un abogado y entregar a la corte en forma escrita sus defensas o sus objeciones a las demandas en contra de su persona. Sea a visado que si usted no se defiende, la corte toma ra medidas y puede continuar la demanda en contra suya sin previo aviso o notificacion. Ademas, la corte puede decidir a favor del demandante y requiere que usted cumpla con todas las provisiones de esta demanda. Usted puede perder dinero o sus propiedades o otros de rechos importantes para usted. LLEVE ESTA DEMANDA A UN ABOGADO INMEDIATAMENTE. SI NO TIENE ABOGADO O SI NO TIENE EL DINERO SUFICIENTE DE PAGAR TAL SERVICIO. VAYA EN PERSONA O LLAME POR TELEFONO A LA OFICINA CUYA DIRECCION SE ENCUENTRA ESCRITA ABA JO PARA AVERIGUAR DONDE SE PUEDE CONSEGUIR ASISTENCIA LEGAL. CUMBERLAND COUNTY BAR ASSOCIATION 2 LIBERTY AVENUE CARLISLE, PA 17013 717-249-3166 800-990-9108 MARTHA E. VON ROSENSTIEL, MARTHA E. VON ROSENSTIEL, 16 SOUTH LANSDOWNE AVENUE PO BOX 457 LANSDOWNE, PA 19050 Attorney ID# 52634 Manufacturers & Traders Trust Company, trustee One M & T Plaza Buffalo, NY 14203-2399 Plaintiff, vs. Pamela Stofko 730 Franklin Street Carlisle, PA 17013, Defendant(s) ESQUIRE P.C. Attorney for Plaintiff COURT OF COMMON PLEAS Cumberland COUNTY Case No: Ol--~O~_ CIVIL ACTION - MORTGAGE FORECLOSURE THIS IS AN ATTEMPT TO COLLECT A DEBT ANY INFORMATION OBTAINED WILL BE USED FOR THAT PURPOSE trustee, Plaintiff is Manufacturers & Traders Trust Company, a corporation organized and existing under state law, with offices for the conduct of business at One M Buffalo, NY 14203-2399. 2. Defendant, Pamela Stofko owner of premises 730 hereinafter described, caption. 3. & T Plaza, is the mortgagor and real Franklin Street, Carlisle, PA 17013, whose last known address is listed in the Plaintiff brings this action in mortgage foreclosure against defendant, mortgagor and real owner, to foreclose a certain indenture of mortgage made, executed and delivered by the above named defendant, mortgagor and real owner to Ivy Mortgage Corp. on May 29, 1998, which mortgage is recorded in the Office of the Recorder of Deeds of Cumberland County in Mortgage Book 1459, page 152, secured on premises 730 Franklin Street, Carlisle, PA 17013 a true and correct description of which is attached hereto as Exhibit I. 4. The mortgage has since been assigned to the plaintiff herein. 5. covenant herein by reference thereto. 6. The aforesaid mortgage is in default in that monthly installments of principal and interest have not been made conformity with the terms of the mortgage, from March 29, 1001 Plaintiff alleges each and every term, condition and in the aforesaid mortgage, and hereby incorporates them and each month thereafter, up to and including the present time. 7. Under the terms of the aforesaid mortgage, upon default of payments set forth in the mortgage documents, the entire interest due thereon are collectible an itemized statement of the amount plaintiff under the terms of the aforesaid mortgage: principal balance and all forthwith. 8. The following is due $69,378.00 Principal Balance Interest from 02/28/01 to 09/11/01 At $32.31 per diem $ 6,300.45 Accrued late charges to 07/11/01 $ 317.00 Late charges from 07/15/01 to 08/15/01 At $32.73 per month $ 65.46 Corporate Advances $ 2,102.96 Monthly Inspections from 03/29/01 To 08/29/01 at $15.00 per month $ 90.00 Attorney's Fee $ 3,400.00 Title Information Certificate $ 350.00 Photostats and Postage $ 45.00 Notarizations $ 10.00 TOTAL $82,058.87 9. Plaintiff sent to defendant, mortgagor and real owner a combined Notice and Warning of Intention to Foreclose and Notices of Homeowners' Emergency Mortgage Assistance Act of 1983 of rights available under the statutes. To date have not been received and Act 91 assistance has not time periods provided by advising payments been granted although the applicable statute have expired. WHEI~EFORE, plaintiff demands judgment per diem interest at $32.31 from 09/12/01 to judgment plus monthly late charges of $32.73 for $82,058.87, plus the date of from 09/15/01 to the date of judgment plus monthly inspection costs of $15.00 from 09/29/01 to the date of judgment and foreclosure and sale of the mortgaged premises plus costs thereon. VERIFICATION % verify that the statements made in the foregoing Complaint in Mortgage Foreclosure are true and correct. I understand that false statements herein a~e made subject to penalties of 18 Pa C,S0 SecSion 4904 relating to unsworn falsification to authorities. By: Tara Thomas Dated: DESCRIPTION ALL THAT CERTAIN parcel of real eslate locauxi in the Borough of C~rlisle, County of Cm~berland, $~a~e cf Pennsylvania, more po~.icularly bounded and d~crib~xt in accordanc~ wire a survey by S~ephe~ G. Fisher dated September 27, 1988, a copy of which iz a~ached hereto, as follows: BEGINNING a~ an iron pin in lhe Western right of way line of Franklin Street, which pin is located 65 feet Sou~h of ~he Southern curb llne of "D" $~r~et; thence along ~he said right of way lin~ Sot~ 06 ~legr~s 13 minutes 00 secox~Is West, 85,00 feet to an iron pin i~ the Norr~m lin~. of a 16 f~et wide alley; ~ along said alley North 83 d~grces 47 minutes 00 seconds West 130.50 fee~ to an iron p/n; thence along !~ntt$ now or formerly of Theodor~ H. Hogan, North 06 degrees 13 m~m~es 00 secontl~ Hast, 83.68 feet to an iron pin at ~h¢ corner of lauds now or formerly of Harry A. Gill; thence slong t.he Southern line of said lands South 84 degrees 02 minutes 13 seconds East 44.52 f~t to aa iron pin; thence continuins along sniff l~e South 84 degrees 3I minutes 45 seconds East, a clistanc~ of 85.98 feet to an iron pin, 'the place of beg~m'~ag. HAVING erec~:d thereon a frame garage ~.4 dwelling being known as No. 730 Franklin Su~l, Tax Parcel # 06-19-1643-331 SHERIFF'S RETURN - REGULAR CASE NO: 2001-05302 P COMMONWEALTH OF PENNSYLVANIA: COUNTY OF CUMBERLAND MANUFACTURERS & TRADERS TRUST VS STOFKO PAMELA GERALD WORTHINGTON , Sheriff or Deputy Sheriff of Cumberland County,Pennsylvania, who being duly sworn according to law, says, the within COMPLAINT - MORT FORE was served upon STOFKO PAMELA the DEFENDANT , at 1253:00 HOURS, at 730 FRANKLIN STREET CARLISLE, PA 17013 PAMELA STOFKO on the 12th day of September, 2001 by handing to 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 18.00 Service 3.25 Affidavit .00 Surcharge 10.00 .00 31.25 Sworn and Subscribed to before me this /~ day of Pr6thonotary So Answers: 09/13/2001 MARTHA VON ROSENSTIEL Deputy S~iff #8824 Martha E. Von Rosenstiel, P.C. Martha E. Von Rosenstiel 16 South Lansdowne Avenue P.O. Box 457 Lansdowne, PA 19050 610 623-2660 Attorney I.D.# 52634 Manufacturers & Traders Trust Company, trustee One M & T Plaza Buffalo NY 14203-2399 Plaintiff VS. Pamela Stotko 730 Franklin Street Carlisle, PA 17013 Defendants Attorney for Plaintiff COURT OF COMMON PLEAS CUMBERLAND COUNTY No: 01-5302 Civil Term PRAECIPE TO THE PROTHONOTARY: Enter judgment in the sum of $83,560.97 of the above named plaintiff and against the above named defendants for failure to file an answefi~ the above action in Mortgage Foreclosure within twenty (20) days from date of service of the Civil Action, and assess damages. I hereby certify that the correct addresses of plaintiff and defendants are as follows: Plaintiff.' One M & T Plaza Buffalo, NY 14203-2399 Defendants: 730 Franklin Street Carlisle, PA 17013 ~ ~Martha~.//~nstiel Attorney for 1P aintiff Martha E. Von Rosenstiel, P.C. Martha E. Von Rosenstiel 16 South Lansdowne Avenue P.O. Box 457 Lansdowne, PA 19050 610 623-2660 Attorney I.D.# 52634 Manufacturers & Traders Trust Company, trustee One M & T Plaza Buffalo, NY 14203-2399 Plaintiff VS. Pamela Stofko 730 Franklin Street Carlisle, PA 17013 Defendants Attorney for Plaintiff COURT OF COMMON PLEAS CUMBERLAND COUNTY No: 01-5302 Civil Term ASSESSMENT OF DAMAGES TO THE PROTHONOTARY: Kindly assess damages against the above named defendants as per Civil Action in Mortgage Foreclosure, as follows: Total per complaint Additional interest on unpaid balances from 09/12/01 to 10/15/01 at $32.31 per diem Additional late charges from 09/15/01 to 10/15/01 at $32.73 per month Additional monthly inspections from 09/29/01 at $15.00 per month Total assessment AND NOW, to wit, this day of $82,058.87 $ 1,421.64 $ 65.46 $ 15.00 ~83,560.97 __ -~ //~ IV~----atth'~E. Von Rosenstiel Attorney for Plaintiff ,2001, damages are assessed as above. Pro Prothy Martha E. Von Rosenstiel, P.C. Martha E. Von Rosenstiel 16 South Lansdowne Avenue P.O. Box 457 Lansdowne, PA 19050 610 623-2660 Attorney I.D.52634 Attorney for Plaintiff Manufacturers & Traders Trust Company, trustee One M & T Plaza Buffalo NY 14203-2399 Plaintiff VS. Pamela Stofko 730 Franklin Street Carlisle, PA 17013 Defendant(s) COURT OF COMMON PLEAS Cumberland COUNTY No: 01-5302 Civil Term AFFIDAVIT OF NON-M/LITARY SERVICE COMMONWEALTH OF PENNSYLVANIA: SS COUNTY OF MONTGOMERY : Alvin Siler, being duly sworn according to law deposes and says that the defendants 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; That Pamela Stofko is over 21 years of age and resides at 730 Franklin Street, Carlisle, PA 17013. This verification is made subject to the penalties of 18 Pa.C.S. §4904 relating to unsworn falsification to authorities. ~.ldqn Siler -- / ! Foreclosure Speciahst Martha E. Von Rosenstiel, P.C. Martha E. Von Rosenstiel 16 South Lansdowne Avenue P.O. Box 457 Lansdowne, PA 19050 610 623-2660 Attorney I.D.# 52634 Manufacturers & Traders Trust Company, trustee One M & T Plaza Buffalo NY 14203-2399 Plaintiff VS. Pamela Stofko 730 Franklin Street Carlisle, PA 17013 Defendants Attomey for Plaintiff COURT OF COMMON PLEAS CUMBERLAND COUNTY No: 01-5302 Civil Term CERTIFICATION OF SERVICE MARTHA E. VON ROSENSTIEL, ESQUIRE, hereby certifies that she is the attorney for the plaintiff herein, and that service of the Notice under Rule 237.5 in the above matter was made on the defendants on October 4, 2001, as evidenced by the attached postal receipts. This verification is made subject to the penalties of 18 Pa. C.S. Section 4904 relating to unswom falsification to authorities. DATED: Martha E. Von Rosenstiel, Esquire Attorney for Plaintiff October 24, 2001 Martha E. Von Rosenstiel, Martha E. Von Rosenstiel 16 South Lansdowne Avenue P.O. Box 457 Lansdowne, PA 19050 610 623-2660 Attorney I.D.# 52634 p.e. Attorney for Plaintiff Manufacturers & Traders Trust Company, trustee One M & T Plaza Buffalo, NY 14203-2399 Plaintiff VS. Pamela Stofko 730 Franklin Street Carlisle, PA 17013 Defendant : Case No: COURT OF COMMON PLEAS Cumberland COUNTY 01-5302 Civil Term TO: Pamela Stofko 730 Franklin Street Carlisle, PA 17013. Date of Notice: October 3, 2001 IMPORTANT NOTICE YOU ARE IN DEFAULT BECAUSE YOU HAVE FAILED TO ENTER A WRITTEN APPEARANCE PERSONALLY OR BY ATTORNEY AND FILE IN WRITING WITH THE COURT YOUR DEFENSES OR OBJECTIONS TO THE CLAIMS SET FORTH AGAINST YOU. UNLESS YOU ACT WITHIN TEN DAYS FROM THE DATE OF THIS NOTICE, A JUDGMENTMAY BE ENTERED AGAINST YOU WITHOUTA HEARING AND YOU MAY LOSE YOUR PROPERTY OR OTHER IMPORTANT RIGHTS. YOU SHOULD TAKE THIS NOTICE TO A LAWYER AT ONCE. IF YOU DO NOT HAVE A LAWYER OR CANNOT AFFORD ONE, GO TO OR TELEPHONE THE FOLLOWING OFFICE TO FIND OUT WHERE YOU CAN GET LEGAL HELP: U,S* POSTAL SERVICE CERTIFICATE OF MAILING CUMBERLAND COUNTY BAR ASSOCATION Af:~ix fee here in stemps or meter postage and post mark. Inquire of Postmaster for current MAY BE USED FOR DOMEST1C AND INTERNATIONAL MAIL, OOES NOT PROVIDE FOR INSURANCE--POSTMASTER PA~A STOFKO 730 FRANKLIN STREET CARLISLE, PA. 17013 PS Form 3817. Mar. 1989 Martha E. Von Rosenstiel, P.C. Martha E. Von Rosenstiel 16 South Lansdowne Avenue P.O. Box 457 Lansdowne, PA 19050 610 623-2660 Attorney I.D.# 52634 Manufacturers & Traders Trust Company, trustee One M & T Plaza Buffalo NY 14203-2399 Plaintiff VS. Pamela Stofko 730 Franklin Street Carlisle, PA 17013 Defendants Attomey for Plaintiff COURT OF COMMON PLEAS CUMBERLAND COUNTY No: 01~5302 Civil Term CERTIFICATION I hereby certify that I am the attorney of record for the plaintiff in this action against real property, and further certify that the property is: ( ) FHA Tenant Occupied or Vacant ( ) Commercial ( ) As a result of a Complaint in Assumpsit (X) That the plaintiff has complied in all respects with Section 403 of the Mortgage Assistance Action Including but not limited to: (a) Service of the notice on defendants (b) Expiration of 30 days since service of the Notice (c) Defendants failure to request or appear at the meeting with the mortgagee or Consumer Counseling Agency (d) Defendants failure to file application with the Homeowners Emergency Assistance Program. I further agree to indemnify and hold harmless the Sheriff for any false statement~j,~n herein. Dated: October 24, 2001 ~~stiel ~ PRAECIPE FOR WRIT OF EXECUTION COMMONWEALTH OF PENNSYLVANIA COUNTY OF CUMBERLAND Manufacturers & Traders Trust Company, trustee V. Pamela Stofko NO. 01-5302 Civil Term Praecipe for Writ of Execution TO THE PROTHONOTARY: Issue Writ of Execution in the above matter: AIVIOUNT DUE INTEREST from 10/27/00 to SALE DATE At $32.31 perdiem (Costs to be added) $83,560.97 $ $ ALL THAT CERTAIN pazcel of real estate 1o~ in the Borough of C~rl/sle, County of Cumberland, Sure of ?ennsylvania, more part/cuIarly bounded and described in accordance with a survey by Sc~phe~ (3. Fisher dated September 27, 1988, a copy of which L~ attached hereto, as follows: BEGINNING a: m iron pin Lu the Western right of wa>' li~e of F~ ~eet. w~ch p~ ~ l~t~ 6~ fe~ Sou~ of ~e ~u~em c~b ~ of "D" S~t; ~en~ ~o~ ~e ~id fi~t of way 1~ Sou~ 06 ~ 13 mimt~ ~ ~S W~t, t~,~ feet to ~ kon p~ ~ ~e No~cm ~c of a 15 f~t ~e ~ey; ~ ~ng ~ ~ley No~ koa p~; ~en~ ~a~ l.~dq now or folly of ~ ~o~ ~a~h 83.68 feet m m iroap~ at · ~ aong ~e Sou~ ~e of sa~ !~ ~ua 84.d~ 02 mi.ut~ 13 ~eeon~ ~ ~.52 fee[ to an koa p~; ~ce ~n~ng ~g d~ of 85,98 feet m ~ ~on p~. ~e p~ of be~g, HAVING erected thor=on a fram: garage and dwelling §eing known as No. 730 Franklin Tax Parcel # 0~-19-I643-331 Martha E. Von Rosenstiel, P.C. Martha E. Von Rosenstiel 16 South Lansdowne Avenue P.O. Box 457 Lansdowne, PA 19050 610 623-2660 Attorney I.D.# 52634 Manufacturers & Traders Trust Company, trustee One M & T Plaza Buffalo, NY 14203-2399 Plaintiff VS. Pamela Stofko 730 Franklin Street Carlisle, PA 17013 Defendant Attorney for Plaintiff COURT OF COMMON PLEAS CUMBERLAND COUNTY No: 01-5302 Civil Term THIS IS AN ATTEMPT TO COLLECT A DEBT ANY INFORMATION OBTAINED WILL BE USED FOR THAT PURPOSE NOTICE OF SHERIFF'S SALE OF REAL PROPERTY TO: Pamela Stofko 730 Franklin Street Carlisle, PA 17013 Your house and/or real estate at 730 Franklin Street, Carlisle, PA 17013 is scheduled to be sold at Sheriff's Sale on March 6, 2002 at 10:00 a.m. to enforce the court judgment of $82,560.97 obtained by Manufacturers & Traders Trust Company, trustee against you. NOTICE OF OWNERS RIGHTS YOU MAY BE ABLE TO PREVENT THIS SHERIFF'S SALE To prevent this Sheriff's Sale you must take IMMEDIATE action: 1. The sale will be cancelled if you pay to Manufacturers & Traders Trust Company, trustee the back payments, late charges, costs and reasonable attorney's fees due. To find out how much you must pay, you may call 610 623-2660. 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 contact an attorney to assert your rights. The sooner you contact one, the mom 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 Sheriff's Sale is not stopped, your property will be sold to the highest bidder. You may find out the bid price by calling 610 623-2660. 2. You maybe able to petition the Court to set aside the sale if the bid price was grossly inadequate compared to the value of the 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 610 623-2660. 4. If the amount due from the buyer is not paid to the Sheriff, you will remain the owner of the property as if the sale never happened. 5. You have a right to remain in the property until the full amount due is paid to the Sheriff and the Sheriff gives a deed to the buyer. At that time, the buyer may bring legal proceedings to evict you. 6. You may be entitled to a share of the money, which was paid for your house. A schedule of distribution of the money bid for your house will be filed by the Sheriff'on a date to be announced by the Sheriff. This schedule will state who will be receiving that money. The money will be paid out in accordance with this schedule unless exceptions (reasons why the proposed distribution is wrong) are filed with the Sheriff within ten (10) days after the Schedule of Distribution is posted. 7. You may also have other rights and defenses, or ways of getting your house back, if you act immediately after the sale. YOU SHOULD TAKE THIS PAPER TO YOUR LAWYER AT ONCE. IF YOU DO NOT HAVE A LAWYER OR CANNOT AFFORD ONE, GO TO OR TELEPHONE THE OFFICE LISTED BELOW TO FIND OUT WHERE YOU CAN GET LEGAL HELP. COURT ADMINISTRATOR 4TM FLOOR CUMBERLAND COUNTY COURT HOUSE CARLISLE, PA 17013 Telephone: 717 240-6200 CLAIM FOR EXEMPTION To the Sheriff: I, the above named defendant, claim exemption of property from levy or attachment: (1) From my real property in my possession which has been levied upon, (a) I desire that my $300.00 statutory exemption be set-aside in kind (specify real property to be set-aside in kind): I request a prompt court hearing to determine the exemption. Notice of the heating should be given to me at (Address) (Telephone Number) I verify that the statements made in this Claim for Exemption are tree and correct. I understand that false statements heroin are made subject to the penalties of 18 Pa. C.S. Section 4904 relating to unswom falsification to authorities. Date: Signature THIS CLAIM TO BE FILED WITH THE OFFICE OF THE SHERI3'F CUMBERLAND COUNTY COURTHOUSE CARLISLE, PA 17013 717 240-6391 WRIT OF EXECUTION _ (MORTGAGE FORECLOSURE) P.R.C.P. 3180 to 3183 and Rule 3257 Manufacturers and Traders Trust Company, trustee VS. Pamela Stofko IN THE COURT OF COMMON PLEAS OF CUMBERLAND COUNTY, PENNSYLVANIA No. 01-5302-Civil Term NO. Term, 20 ___E.D. Term, 20-_ _ _ A.D. WRIT OF EXECUTION (MORTGAGE FORECLOSURE) Commonwealth of Pennsylvania: County of : TO THE SHERIFF OF CUMBERLAND COUNTY, PENNSYLVANIA: To satisfy the judgment, interest and costs in the above matter you are directed to levy upon and sell the following described property (specifically describe property below): PREMISES: 730 Franklin Street Carlisle, PA 17013 as endorsed. Amount Due $ 83,560.97 Interest from 10/26/01 to Sale Date ~ $32.3 lper diem $ Attorney's fees $ Costs Total Dated (SEAL) By: Prothonotary, Common Pleas Court of Cumberland County, Penna. Deputy ALL THAT CERTAIN pa~el of reaI ~smre loe~-'d in ~¢ Borough of CaHisle, County of C~rhnd, Sm~ of Pe~ylv~a, more pm~c~ly bo~ ~ d~ ~ a~rd~ wire a survey by Smph~ G. Fi~ &red Sep~ber 27, 19~8, a ~py of w~ch ~ amch~ ~reto, m fo~ows: BEGINNING ~ ~n ~on pin ~. the Western right of way line of Ftazakiin b"w~-e£, which pin i~ locat.~d 65 feet South of the Southern curb Ii~ ~f 'D" Street; ~.h~c~ u~o~g the saie~ ri~t of way lin~ South 06 ~ 13 m{~tes ~ ~s W~, 85.~ feet to ~ ~ou p~ ~ ~e No.em ~e of a 16 f~t ~de ~I~y; ~ ~g s~ ~ey No~ 83 ~ees 47 ~m~s ~ ~con~ W~st 130.50 fe~t to ~ kan p~ ~e~ along ~,~ now or fo~rly of ~do~ H. Hog~, No~ 06 de~s 13 a~ ~ ~o~ ~t, 83.68 feet m m iron p~ at ~e co~r of lu~ ~w or fom~ly of H~ A. G~I; a~ aong ae/ou~ I~e of sa~ I~ ~ua 84 de~ ~ ~i~ut~ 13 seeon~ ~ ~.52 f~et to aa boa p~; ~ce ~n~uing ~g s~ ~ $ou~ 84 d~e~ 3I ~nutes 45 so.ads ~h a d~ of 85.98 feet ~ ~ kou p~, ~e p~ of berg. HAVING erect, ti thereon a frame garage and dwelling being known as No. 730 Franklin S~re.."t. Tax Parcel # 0~-19-1643-331 Martha E. Von Rosenstiel, P.C. Martha E. Von Rosenstiel 16 South Lansdowne Avenue P.O. Box 457 Lansdowne, PA 19050 610 623-2660 Attomey I.D.# 52634 Manufacturers & Traders Trust Company, trustee One M & T Plaza Buffalo NY 14203-2399 Plaintiff VS. Pamela Stofko 730 Franklin Street Carlisle, PA 17013 Defendants Attorney for Plaintiff COURT OF COMMON PLEAS CUMBERLAND COUNTY No: 01-5302 Civil Term AFFIDAVIT OF NOTICE PURSUANT TO RULE 3129.1 COMMONWEALTH OF PENNSYLVANIA: SS COUNTY OF DELAWARE MARTHA E. VON ROSENSTIEL, attorney for the plaimiffin 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 730 Franklin Street, Carlisle, PA 17013. 1. Name and address of owners(s) or reputed owner(s) Pamela Stofko 730 Franklin Street Carlisle, PA 17013 2. Name and address of defendant(s) in the judgment: Pamela Stofko 730 Franklin Street Carlisle, PA 17013 3. Name and address of every judgment creditor whose judgment is a record lien on the real property to be sold: NONE 4. Name and address of the last recorded holder' of every mortgage of record: The Pacesetter Corporation 7487 Whitepine Road Chesterfield, Buisness Center Richmond, VA 23237 5. Name and address of every other person who has any record lien on the property: 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: NONE 7. Name and address of every other person of whom plaintiff has knowledge who has any interest in the property which may be affected by the sale: Family Court/Domestic Relations Office One Courthouse Square Carlisle, PA 17013 Dept. of Public Welfare 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 of 18 Pa. C.S. Section 4904 relating to unswom falsification to authorities. ~~o~enstiel Attorney for Plaintiff MARTHA E. VON ROSENSTIEL, P.C. ATTORNEY AT LAW 16 SOUTH LANSDOWNE AVENUE P.O. BOX 457 LANSDOWNE, PA 19050 PHONE(610)623-2660 October 24, 2001 TO: The Pacesetter Corporation 7487 Whitepine Road Chesterfield, Buisness Center Richmond, VA 23237 FAX(610)623-2745 gel NOTICE OF SALE OF REAL PROPERTY: 730 Franklin Street Carlisle, PA 17013 Amount of Judgment: $83,560.97 Date of Judgment: October 26, 2001 Court Term and Number: Court of Common Pleas of Cumberland County, Dockeff4 01-5302 Civil Term Plaintiff: Manufacturers & Traders Trust Company, trustee Defendants: Pamela Stofko Dear Sir/Madam: Please be advised that the property and residential dwelling, located at and known as 730 Franklin Street Carlisle, PA 17013 will be sold by the Sheriffof Cumberland County on March 6, 2002 at 10:00 a.m. in the Cumberland County Court House, One Court House Square, Carlisle, PA 17013. This notice is being sent to you because my records indicate that you hold a lien on the property secondary to the first mortgage, which is being foreclosed. This property and improvements are being sold pursuant to a judgment entered as indicated above in favor of the above named plaintiff, and against the above named defendants. The name of the owners, real owners, and reputed owners of the aforementioned property are Pamela Stofko. A schedule of distribution will be filed by the Sheriffon a date specified by the Sheriff no later than 30 days after said sale, and distribution will be made in accordance with the schedule unless exceptions are filed thereto within ten (10) days after the date of the filing of said schedule. You should check with the Sheriff's Office by calling 717 240-6391 to determine the actual date of the filing of the schedule. Sincerely yours, ,~stiel MARTHA E. VON ROSENSTIEL, P.C. ATTORNEY AT LAW 16 SOUTH LANSDOWNE AVENUE P.O. BOX 457 LANSDOWNE, PA 19050 PHONE(610)623 -2660 FAX(610)623-2745 October 24, 2001 TO: Family Court/Domestic Relations Office One Courthouse Square Carlisle, PA 17013 NOTICE OF SALE OF REAL PROPERTY: 730 Franklin Street Carlisle, PA 17013 Amount of Judgment: $83,560.97 Date of Judgment: October 26, 2001 Court Term and Number: Court of Common Pleas of Cumberland County, Docketg 01-5302 Civil Term Plaintiff: Manufacturers & Traders Trust Company, trustee Defendants: Pamela Stofko Dear Sir/Madam: Please be advised that the property and residential dwelling, located at and known as 730 Franklin Street Carlisle, PA 17013 will be sold by the Sheriff of Cumberland County on March 6, 2002 at 10:00 a.m. in the Cumberland County Court House, One Court House Square, Carlisle, PA 17013. This notice is being sent to you because my records indicate that you hold a lien on the property secondary to the first mortgage, which is being foreclosed. This property and improvements are being sold pursuant to a judgment entered as indicated above in favor of the above named plaintiff, and against the above named defendants. The name of the owners, real owners, and reputed owners of the aforementioned property are Pamela Stofko. A schedule of distribution will be filed by the Sheriffon a date specified by the Sheriffno later than 30 days after said sale, and distribution will be made in accordance with the schedule unless exceptions are filed thereto within ten (10) days after the date of the filing of said schedule. You should check with the Sheriff's Office by calling 717 240-6391 to determine the actual date of the filing of the schedule. ~iel~Sincerely yours, MARTHA E. VON ROSENSTIEL, P.C. ATTORNEY AT LAW 16 SOUTH LANSDOWNE AVENUE P.O. BOX 457 LANSDOWNE, PA 19050 PHONE(610)623-2660 FAX(610)623-2745 October 24, 2001 TO: Dept. of Public Welfare Box 2675 Harrisburg, PA 17105 NOTICE OF SALE OF REAL PROPERTY: 730 Franklin Street Carlisle, PA 17013 Amount of Judgment: $83,560.97 Date of Judgment: October 26, 2001 Court Term and Number: Court of Common Pleas of Cumberland County, Docketg 01-5302 Civil Term Plaintiff: Manufacturers & Traders Trust Company, trustee Defendants: Pamela Stofko Dear Sir/Madam: Please be advised that the property and residential dwelling, located at and known as 730 Franklin Street Carlisle, PA 17013 will be sold by the Sheriff of Cumberland County on March 6, 2002 at I0:00 a.m. in the Cumberland County Court House, One Court House Square, Carlisle, PA 17013. This notice is being sent to you because my records indicate that you hold a lien on the property secondary to the first mortgage, which is being foreclosed. This property and improvements are being sold pursuant to a judgment entered as indicated above in favor of the above named plaintiff, and against the above named defendants. The name of the owners, real owners, and reputed owners of the aforementioned property are Pamela Stofko. A schedule of distribution will be filed by the Sheriffon a date specified by the Sheriffno later than 30 days after said sale, and distribution will be made in accordance with the schedule unless exceptions are filed thereto within ten (10) days after the date of the filing of said schedule. You should check with the Sheriff's Office by calling 717 240-6391 to determine the actual date of the filing of the schedule. Sincerely yours, //~artha E. Von Rosenstiel Martha E. Von Rosenstiel, P.C. Martha E. Von Rosenstiel 16 South Lansdowne Avenue P.O. Box 457 Lansdowne, PA 19050 610 623-2660 Attorney I.D.# 52634 Manufacturers & Traders Trust Company, trustee One M & T Plaza Buffalo NY 14203-2399 Plaintiff VS. Pamela Stoflco 730 Franklin Street Carlisle, PA 17013 Defendants Attorney for Plaintiff COURT OF COMMON PLEAS CUMBERLAND COUNTY No: 01-5302 Civil Term #8824 $¢ AFFIDAVIT OF SERVICE OF N6TICES PURSUANT TO RULE 3129.1 COMMONWEALTH OF PENNSYLVANIA: SS COUNTY OF DELAWARE MAP, TIaA E. VON ROSENSTIEL, attorney for the plaintiff in the above action, hereby certifies that service of the Notice under Rule 3129.1, in the above matter was made on the defendants via certified mail, return receipt requested (unless otherwise stated) and on all interested parties, set forth below, by regular first class mail, postage prepaid, as evidenced by the attached certificates of mailing: 1. Name and address of owners(s) or reputed owner(s) Pamela Stofko 730 Franklin Street Carlisle, PA 17013 2. Name and address of defendant(s) in the judgment: Pamela Stofko 730 Franklin Street Carlisle, PA 17013 3. Name and address of every judgment creditor whose judgment is a record lien on the real property to be sold: NONE 4. Name and address of the last recorded holder of every mortgage of record: The Pacesetter Corporation v~ 7487 Whitepine Road Chesterfield, Buisness Center Richmond, VA 23237 5. Name and address of every other person who has any record lien on the property: 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: Family Court/Domestic Relations Office '/ One Courthouse Square Carlisle, PA 17013 Dept. of Public Welfare Box 2675 Harrisburg, PA 17105 I verify that the statements made in this affidavit are tree 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 unswom falsification to authorities. ~enstiel Attorney for Plaintiff PAMELA STOFKO ~"'~ 730 FRANKLIN STREET CARLISLE. PA. V.S. POST^C SE.V~CE CERTIFICATE OF MAILING MAY BE USED FOR DOMESTIC AND INTERNATIONAL MAIL, DOES NOT PROVIDE FO~ ~,~.~.A.N. CE -- p OSTMASTER ~,n~ ~.~vuN ~u~EN$11EL .,~,,~ F~m: 16 8. LANSDOWNE AVE. P O_ COX LANSDOWNE, PA 19050 PAMELA STOFK0 730 FRANKLIN STREET CARLISLE, PA. 17013 ~S Form 3817, Mar. 1989 .aC) · Complete items 1, 2, and 3. Nso complete Rem 4 if Restricted Delivery is desired. · print your name and eddr~s on the. reverse · Attach this card to the back of the mailplece. 1. Axtlgle .N:tclmaesd to: PAMELA'STOFKO 730 FRANKLIN STREET CARLISLE, PA. 17013 D.m~ [] [] Insured Mall i"l C.O.D. 4. mest~ct~d Oe~ve~y? ~ Fee) 2. Article Number (Copy from sen/ce PS Form 3811, July 1~9 ,r Memhandlse []yes 102595~0-M'~952 Martha E. Von Rosenstiel 16 South Lansdowne Avenue P.O. Box 457 Lansdowne, PA 19050 (610) 623-2660 Attorney I.D. #52634 Attorney for Plaintiff/Movant Manufacturers & Traders Trust Company, trustee Plaimiff VS. Pamela Stofko De~ndants COURT OF COMMON PLEAS Cumberland COUNTY Case No:01-5302 civil Term TO THE PROTHONTARY: Dated: April 4, 2002 Martha E. Von Rosenstiel Attorney for Plaintiff STATE OF PENNSYLVANIA, ~ COUNTY OF CUMBERLANDI ss. Robert P Ziegler I, .............................................................................. Recorder of Deeds in and for said County and State do'hereby certify that the Sheriff's Deed in which ................ Manufacturers & Traders Tr Co, Tr .................................................................................... ~ the grantee the same Imving be~m sold to Said grantee on the 6th ............................................... day of ........ _M__a_r_c_h .......................... A. O., .,' 200_2_ .... under and by virtue of a writ .............. Execution ................................................ i~ued on the 1 s t day o/__3/Qygllkb.%~ .............. A. D.,2001 ..... ~ out of the Court of Comman Pleas d said County'as of Civil 2001 . 5302 Nmn{mex &t~h .... :,~t Manufacturers & Traders Tr Co, Tr Pa~e la Stofko ................................... against .................................................... is 250 4741 duly recorded in Sheriff's Deed Book No ............. , Page ............. IN TESTIMONY WHEREOF, I have hereunto set my hand and seal of said office this _~_?_= ..... day ---- Manufacturers & Traders Trust Company, Trustee VS Pamela Stofko In The Court of Common Pleas of Cumberland County, Pennsylvania Writ No. 2001-5302 Civil Term Douglas Donsen, Deputy Sheriff, who being duly sworn according to law, states ' k that on November 7, 2001 at 4:55 o cloc P.M., EST, he served a true copy of the within Real Estate Writ, Notice and Description, in the above entitled action, upon the within named defendant, to wit: Pamela Stofko, by making known unto Dean Stofko, adult in charge, at 730 Franklin Street, Carlisle, Cumberland County, Pennsylvania, its contents and at the same time handing to her personally the said true and correct copy of the same. Brian Barrick, Deputy Sheriff, who being duly sworn according to law, states that on January 03, 2002 at 8:48 o'clock A.M., E.S.T., he posted a true copy of the within Real Estate Writ, Notice, Poster and Description, in the above entitled action, upon the property of Pamela Stofko located at 730 Franklin Street, Carlisle, pennsylvania, according to law. R. Thomas Kline, Sheriff, who being duly sworn according to law says he served the above Real Estate Writ, Notice, Poster and Description in the following manner: The Sheriff mailed a notice of the pendency of the action to one of the within named defendants to wit: Pamela Stofko, by regular mail to her last known address of 730 Franklin Street, Carlisle, PA 17013. This letter was mailed under the date of January 18, 2002 and never returned to the Sheriff's Office. R. Thomas Kline, Sheriff, who being duly sworn according to law, says that after due and legal notice had been given according to law, exposed the within described premises at public venue or outcry at the Court House, Carlisle, Cumberland County, Pennsylvania on March 6, 2002 at 10:00 o'clock A.M., E.S.T. He sold the same for the sum of $1.00 to Attorney Martha E. Von Rosenstiel for Manufacturers & Traders Trust Company as trustee for Securitization Series 1998-2, Agreement dated 6/1/98, its successors and assigns. It being the highest bid and best price received for the same, Manufacturers & Traders Trust Company as trustee for Securitization Series 1998-2, Agreement dated 6/1/98, its successors and assigns of One M & T Plaza, Buffalo, NY 14203-2399, being the buyer in this execution paid SheriffR. Thomas Kline the sum of $742.08, it being costs. Sheriff's Costs: Docketing $30.00 Poundage 14.55 Advertising 15.00 Posting Handbills 15.00 Acknowledging Deed 30.00 Auctioneer 10.00 Law Library .50 Prothonotary 1.00 Mileage 6.50 Certified Mail 1.63 Levy 15.00 Surcharge 20.00 Law Journal 256.10 Patriot News 251.10 Share of Bills 24.20 Distribution of Proceeds 25.00 Sheriff's Deed 26.50 $742.08 Paid 3/12/02 Sworn and subscribed to before me This o"~ day of__~ 2002, A.D. (~tlo,z,~, tG_ ~ ~' ¥{otho~otary ' R. Thomas Kline, Sheriff Real Estate Deputy The Pacesetter Corporation 7487 Whitepine Road Chesterfield, Buisness Center Richmond, VA 23237 5. Name and address of every other person who has any record lien on the property: NONE whose 6. Name and address of every other person who has any record interest in the property and interest may be affected by the sale: NONE 7. Name and address of every other person of whom plaintiff has knowledge who has any interest in the property which may be affected by the sale: Family Court/Domestic Relations Office One Courthouse Square Carlisle, PA 17013 Dept. of Public Welfare 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 of 18 Pa. C.S. Section 4904 relating to unsworn falsification to authorities. A~A~nstiel ttomey for Plaintiff MARTHA E. VON ROSENSTIEL, P.C. ATTORNEY AT LAW 16 SOUTH LANSDOWNE AVENUE P.O. BOX 457 LANSDOWNE, PA 19050 PHONE(610)623-2660 October 24, 2001 TO: The Pacesetter Corporation 7487 Whitepine Road Chesterfield, Buisness Center Richmond, VA 23237 FAX(610)623-2745 NOTICE OF SALE OF REAL PROPERTY: 730 Franklin Street Carlisle, PA 17013 Amount of Judgment: $83,560.97 Date of Judgment: October 26, 2001 Court Term and Number: Court of Common Pleas of Cumberland County, Docketg 01-5302 Civil Term Plaintiff: Manufacturers & Traders Trust Company, trustee Defendants: Pamela Stofko Dear Sir/Madam: Please be advised that the property and residential dwelling, located at and known as 730 Franklin Street Carlisle, PA 17013 will be sold by the Sheriff of Cumberland County on March 6, 2002 at 10:00 a.m. in the Cumberland County Court House, One Court House Square, Carlisle, PA 17013. This notice is being sent to you because my records indicate that you hold a lien on the property secondary to the first mortgage, which is being foreclosed. This property and improvements are being sold pursuant to a judgment entered as indicated above in favor of the above named plaintiff, and against the above named defendants. The name of the owners, real owners, and reputed owners of the aforementioned property are Pamela Stofko. A schedule of distribution will be filed by the Sheriff on a date specified by the Sheriff no later than 30 days after said sale, and distribution will be made in accordance with the schedule unless exceptions are filed thereto within ten (10) days after the date of the filing of said schedule. You should check with the Sheriff's Office by calling 717 240-6391 to determine the actual date of the filing of the schedule. Sincerely yours, ,~stiel MARTHA E. VON ROSENSTIEL, P.C. ATTORNEY AT LAW 16 SOUTH LANSDOWNE AVENUE P.O. BOX 457 LANSDOWNE, PA 19050 PHONE(610)623-2660 FAX(610)623-2745 October 24, 2001 TO: Family Court/Domestic Relations Office One Courthouse Square Carlisle, PA 17013 NOTICE OF SALE OF REAL PROPERTY: 730 Franklin Street Carlisle, PA 17013 Amount of Judgment: $83,560.97 Date of Judgment: October 26, 2001 Court Term and Number: Court of Common Pleas of Cumberland County, Dockerg 01-5302 Civil Term Plaintiff: Manufacturers & Traders Trust Company, trustee Defendants: Pamela Stofko Dear Sir/Madam: Please be advised that the property and residential dwelling, located at and known as 730 Franklin Street Carlisle, PA 17013 will be sold by the Sheriffof Cumberland County on March 6, 2002 at 10:00 a.m. in the Cumberland County Court House, One Court House Square, Carlisle, PA 17013. This notice is being sent to you because my records indicate that you hold a lien on the property secondary to the first mortgage, which is being foreclosed. This property and improvements are being sold pursuant to a judgment entered as indicated above in favor of the above named plaintiff, and against the above named defendants. The name of the owners, real owners, and reputed owners of the aforementioned property are Pamela Stofko. A schedule of distribution will be filed by the Sheriff on a date specified by the Sheriff no later than 30 days after said sale, and distribution will be made in accordance with the schedule unless exceptions are filed thereto within ten (10) days after the date of the filing of said schedule. You should check with the Sheriff's Office by calling 717 240-6391 to determine the actual date of the filing of the schedule. Sincerely yours, stiel MARTHA E. VON ROSENSTIEL, P.C. ATTORNEY AT LAW 16 SOUTH LANSDOWNE AVENUE P.O. BOX 457 LANSDOWNE, PA 19050 PHONE(610)623-2660 FAX(610)623-2745 October 24, 2001 TO: Dept. of Public Welfare Box 2675 Harrisburg, PA 17105 NOTICE OF SALE OF REAL PROPERTY: 730 Franklin Street Carlisle, PA 17013 Amount of Judgment: $83,560.97 Date of Judgment: October 26, 2001 Court Term and Number: Court of Common Pleas of Cumberland County, Docket-g 01-5302 Civil Term Plaintiff: Manufacturers & Traders Trust Company, trustee Defendants: Pamela Stofko Dear Sir/Madam: Please be advised that the property and residential dwelling, located at and known as 730 Franklin Street Carlisle, PA 17013 will be sold by the Sheriffof Cumberland County on March 6, 2002 at 10:00 a.m. in the Cumberland County Court House, One Court House Square, Carlisle, PA 17013. This notice is being sent to you because my records indicate that you hold a lien on the property secondary to the first mortgage, which is being foreclosed. This property and improvements are being sold pursuant to a judgment entered as indicated above in favor of the above named plaintiff, and against the above named defendants. The name of the owners, real owners, and reputed owners of the aforementioned property are Pamela Stofko. A schedule of distribution will be filed by the Sheriff on a date specified by the Sheriff no later than 30 days after said sale, and distribution will be made in accordance with the schedule unless exceptions are filed thereto within ten (10) days after the date of the filing of said schedule. You should check with the Sheriff's Office by calling 717 240-6391 to determine the actual date of the filing of the schedule. Sincerely yours, ./~artha E. Von Rosenstiel Martha E. Von Rosenstiel, P.C. Martha E. Von Rosenstiel 16 South Lansdowne Avenue P.O. Box 457 Lansdowne, PA 19050 610 623-2660 Attorney I.D.# 52634 Manufacturers & Traders Trust Company, trustee One M & T Plaza Buffalo, NY 14203-2399 Plaintiff VS. Pamela Stofko 730 Franklin Street Carlisle, PA 17013 Defendant Attorney for Plaintiff COURT OF COMMON PLEAS CUMBERLAND COUNTY No: 01-5302 Civil Term THIS IS AN ATTEMPT TO COLLECT A DEBT ANY INFORMATION OBTAINED WILL BE USED FOR THAT PURPOSE NOTICE OF SHERIFF'S SALE OF REAL PROPERTY TO: Pamela Stofko 730 Franklin Street Carlisle, PA 17013 Your house and/or real estate at 730 Franklin Street, Carlisle, PA 17013 is scheduled to be sold at Sheriff's Sale on March 6, 2002 at 10:00 a.m. to enforce the court judgrnent of $82,560.97 obtained by Manufacturers & Traders Trust Company, trustee against you. NOTICE OF OWNERS RIGHTS YOU MAY BE ABLE TO PREVENT THIS SHERIFF'S SALE To prevent this Sheriff's Sale you must take IMMEDIATE action: 1. The sale will be cancelled if you pay to Manufacturers & Traders Trust Company, trustee the back payments, late charges, costs and reasonable attorney's fees due. To find out how much you must pay, you may call 610 623-2660. 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 contact 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 attomey) 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 Sheriff's Sale is not stopped, your property will be sold to the highest bidder. You may find out the bid price by calling 610 623-2660. 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 the property. 3. The sale will go through only if the buyer pays the Sheriffthe full amount due in the sale. To find out if this has happened you may call 610 623-2660. 4. If the amount due from the buyer is not paid to the Sheriff, you will remain the owner of the property as if the sale never happened. 5. You have a right to remain in the property until the full amount due is paid to the Sheriff and the Sheriff gives a deed to the buyer. At that time, the buyer may bring legal proceedings to evict you. 6. You may be entitled to a share of the money, which was paid for your house. A schedule of distribution of the money bid for your house will be filed by the Sheriff on a date to be announced by the Sheriff. 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 ¢~ithin ten (10) days after the Schedule of Distribution is posted. 7. You may also have other rights and defenses, or ways of getting your house back, if you act immediately after the sale. YOU SHOULD TAKE THIS PAPER TO YOUR LAWYER AT ONCE. 13' 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. COURT ADMINISTRATOR 4TM FLOOR CUMBERLAND COUNTY COURT HOUSE CARLISLE, PA 17013 Telephone: 717 240-6200 CLAIM FOR EXEMPTION To the Sheriff: I, the above named defendant, claim exemption of property from levy or attachment: (1) From my real property in my possession which has been levied upon, (a) I desire that my $300.00 statutory exemption be set-aside in kind (specify real property to be set-aside in kind): I request a prompt court hearing to determine the exemption. Notice of the hearing should be given to me at (Address) (Telephone Number) I verify that the statements made in this Claim for Exemption are true and correct. I understand that false statements herein are made subject to the penalties of 18 Pa. C.S. Section 4904 relating to unswom falsification to authorities. Date: Signature THIS CLAIM TO BE FILED WITH THE OFFICE OF THE SHERIFF CUMBERLAND COUNTY COURTHOUSE CARLISLE, PA 17013 717 240-6391 WRIT OF EXECUTION - (MORTGAGE FORECLOSURE) P.R.C.P. 3180 to 3183 and Rule 3257 Manufacturers and Traders Trust Company, trustee VS. Pamela Stofko IN THE COURT OF COMMON PLEAS OF CUMBERLAND COUNTY, PENNSYLVANIA No. 01-5302-Civil Term No. Term, 20 .... E.D. Term, 20-. - - A.D. WRIT OF EXECUTION (MORTGAGE FORECLOSURE) Commonwealth of Pennsylvania: County of : TO THE SHERIFF OF CUMBERLAND COUNTY, PENNSYLVANIA: To satisfy the judgment, interest and costs in the above matter you are directed to levy upon and sell the following described property (specifically describe property below): PREMISES: 730 Franklin Street Carlisle, PA 17013 as endorsed. Amount Due Interest from 10/26/01 to Sale Date ~ $32.3 lper diem $ Attorney's fees $ Costs $. Total $. Dated (SEAL) 83,560.97 Prothonotary, Common Pleas Court of Cumberland County, Penna. By: Deputy WRIT OF EXECUTION and/or A'I-rACHMENT COMMONWEALTH OF PENNSYLVANIA) COUNTY OF CUMBERLAND) TO THE SHERIFF OF C~nberland To satisfy the debt, interest and costs due NO. 01-5302 CIVIL CIVIL ACTION - LAW COUNTY: Manufacturers & Traders Trust Ccmpany, trustee PLAINTIFF(S) from Psmela Stofko, 730 Franklin Street, Carlisle, PA 17013 DEFENDANI(S) (1) You are directed to levy upon the property of the defendant(s) and to sell See Legal Description (2) You are also directed to attach the property of the defendant(s) not levied upon in the possession of __ GARNISHEE(S) as follows: and to notify the gamishee(s) that: (a) an attachment has been issued; (b) the garnishee(s) is/are enjoined from paying any debt to or for the account of the delendant(s) and from delivering any property of the defendant(s) or othenvise disposing thereof; (3) If property of lhe defendant(s) not levied upon an subject to attachment is found inthe possession of anyone other than a named garnishee, you are directed to notify him/herlhat he/she has been added as a garnishee and is enjoined as above stated. Amount Due $83,560.97 frc[n 10/27/00 to sale date at Interest ~-~o '~1 ~,=,~ Atty's Corem % Atty Paid $103.25 Plaintiff Paid Due Prothy Other Costs $.50 $1.00 Date: Nov~nber 1, 2001 REQUESTING PARTY: Name Martha E. Von Rosenstiel, Esq. 16 South Lansdowne Avenue Address: Lansdowne, PA 19050 Atlorney for: Plaintiff Telephone: 610-623-2660 Supreme Court ID No, 52634 Curtis R. Long Prothonotary, Civil Division ~. Deputy EAL'ESTATE SALE On November 07, 2001, the sheriff levied upon the defendant's interest in the real property situated in Carlisle Borough, Cumberland County, PA, known and numbered as 730 Franklin Street, Carlisle, and more fully described on Exhibit "A" filed with this writ and by this reference incorporated herein. Date: November 07, 2001 Real Estate Deputy THE PATRIOT NEWS THESUNDAY PATRIOT NEWS Proof of Publication UnderAct No. 587, Approved May 16, 1929 Commonwealth of Pennsylvania, County of Dauphin} ss Michael Morrow being duly sworn according to law, deposes and says: That he is the Asst. Controller of The Patriot News Co., a corporation organized and existing under the laws of the Commonwealth of Pennsylvania, with its principal office and place of business at 812 to 818 Market Street, in the City of Harrisburg, County of Dauphin, State of Pennsylvania, owner and publisher of The Patriot-News and The Sunday Patriot-News newspapers of general circulation, printed and published at 812 to 818 Market Street, in the City, County and State aforesaid; that The Patriot-News and The Sunday Patriot-News were established March 4th, 1854, and September 18th, 1949, respectively, and all have been continuously published ever since; That the printed notice or publication which is securely attached hereto is exactly as printed and published in their regular daily and/or Sunday/ Metro editions which appeared on the 29th day(s) of January and the 5th and 12th day(s) of February 2002. That neither he nor said Company is interested in the subject matter of said printed notice or advertising, and that all of the allegations of this statement as to the time, place and character of publication are true; and That he has personal knowledge of the facts aforesaid and is duly authorized and empowered to verify this statement on behalf of The Patriot-News Co. aforesaid by virtue and pursuant to a resolution unanimously passed and adopted severally by the stockholders and board of directors of the said Company and subsequently duly recorded in the °ffice f°r the Rec°rding °f Deeds in and f°r said C°ul. ti~ii.i.i .i.iii 'ii.".VOlume 14, Page 317. PUBLICATION ..................... S A L E #25 I Member, Pennsylvania Assoc~tloa ot No~ My commission expires June 6, 2002 :. ~ CUMBERLAND COUNTY SHERIFFS OFFICE /, i CUMMBERLAND COUNTY COURTHOUSE CARLISLE, PA. 17013 Statement of Advertising Costs To THE PATRIOT-NEWS CO., Dr. For publishing the notice or publication attached hereto on the above stated dates Probating same Notary Fee(s) Total $ 249.6O $ 1.50 $ 251.10 Publisher's Receipt for Advertising Cost i., publisher of The p~tri0t-New~ and The Sunday Patriot-News, newspapers of general circulation, hereby acknowledge receipt of the aforesaid notice and publication costs and certifies that the same have been duly paid. PROOF OF PUBLICATION OF NOTICE IN CUMBERLAND LAW JOURNAL (Under Act No. 587, approved May 16, 1929), P. L.1784 STATE OF PENNSYLVANIA : : COUNTY OF CUMBERLAND : SS. Roger M. Morgenthal, Esquire, Editor of the Cumberland Law Journal, of the County and State aforesaid, being duly sworn, according to law, deposes and says that the Cumberland Law Journal, a legal periodical published in the Borough of Carlisle in the County and State aforesaid, was established January 2, 1952, and designated by the local courts as the official legal periodical for the publication of all legal notices, and has, since January 2, 1952, been regularly issued weekly in the said County, and that the printed notice or publication attached hereto is exactly the same as was printed in the regular editions and issues of the said Cumberland Law Journal on the following dates, viz: JANUARY 25, FEBRUARY, 1, 8, 2002 Affiant further deposes that he is authorized to verify this statement by the Cumberland Law Journal, a legal periodical of general circulation, and that he is not interested in the subject matter of the aforesaid notice or advertisement, and that all allegations in the foregoing statements as to time, place and character of publication are true. REAL E~rA~E Ka~ NO. 25 Writ No. 2001-5302 Civil Manufacturers & Traders Trust Company, trustee VS. Pamela Stofko Atty.: Martha E. Von Rosenstiel ALL THAT CERTAIN parcel of real estate located in the Borough of Carlisle, County of Cumberland, State of Pennsylvania, more particu- larly bounded and described in ac- cordance with a survey by Stephen G. Fisher dated September 27, 1988, a copy of which is attached hereto, as follows: BEGINNING at an iron pin in the Western right of way line of Franldin Street, which pin is located 65 feet South of the Southern curb line of ~D' Street; thence along the said right of way line South 06 degrees 13 SWORN TO AND SUBSCRIBED before me this 8 day of FEBRUARY, 2002_ I ~.C~..E._Sm, OER, t~a~yF,ueae I / uan~,~~ I