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HomeMy WebLinkAbout02-1373GOLDBECK McCAFFERTY & McKEEVER BY: JOSEPH A. GOLDBECK, JR. ATTORNEY I.D. #16132 SUITE 500 - THE BOURSE BLDG. 111 S. INDEPENDENCE MALL EAST PHILADELPHIA, PA 19106 (215) 627-1322 ATTORNEY FOR PLAINTIFF ASSOCIATES CDC A DIVISION OF CITIFINANCIAL SERVICES INC. ITS SUCCESSORS AND/OR ASSIGNS AS THEIR INTEREST MAY APPEAR 7467 New Ridge Road Suite 222 Hanover, MD 21076 Plaintiff VS. CRAIG A. BRUNGARD Mortgagor(s) and Real Owner(s) l 015 Chippenham Road Mechanicsburg, PA 17050 Defendant(s) IN THE COURT OF COMMON PLEAS OF Cumberland COUNTY CIVIL ACTION - LAW ACTION OF MORTGAGE FORECLOSURE No. O --I- q3 CIVIL ACTIOf~; :'~',,,~1'O_~GE FORECLOSURE THIS FIRM IS A DEBT COLLECTOR AND WE ARE ATTEMPTINGTO COLLECT A DEBT OWED TO OUR CLIENT. ANY INFORMATION OBTAINED FROM YOU WILL BE USED FOR THE PURPOSE OF COLLECTING THE DEBT. NOTICE You have been sued in court. If you wish to defend against the claims se~ forth in the following pages, you must take action within twenty (20) days after the Complaint and notice are served, by entefing a written appea~ance 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 claim in the Complaint of for any other claim or relief reqnested by the Plaintiff. You may lose money or property or other fights impertent to you. YOU SHOULD TAKE THIS POPER 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. CUMBEP. L~ND COUNTY BAR. ASSOCIATION 2 Liberty Avenue Carlisle, PA 17013 LEGAL SERVICES INC 8 lrvlne Row Carlisle, PA 17013 717-243-9400 AVISO SI DESEA DEFENDERSE CONTRA LAS QUEJAS pERESENTADAS, ES ABSOLUTAMENTE NECESSARIO QUE LE HAN DEMANDADO A USTED EN LA CORTE. PARA DEFENDERSE ES NECESSARIO QUE USTED, O SU USTED RESPONDA DENTRO DE 20 DIAS DESPUES DE SER SERVIDO CON ESTA DEMANDA Y AVISO. ABOGADO, REGISTRE CON LA CORTE EN FORMA ESCRITA, EL pUNTO DE VISTA DE USTED Y CUALQOIER OBJECCION CONTRA LAS QUEJAS EN ESTA DEMAlqDA. RECUERDE: SI USTED NO REPONDE A ESTA DEMANDA, SE PUEDE PROSEGUIR CON EL PROCESO SIN SU pARTICIFACION. ENTONCES, LA COUTE PUEDE, SIN NOTIFICAR10, DECK)IR A FAVOR DEL DEMANDANTE Y REQUERIRA QUE USTED CUMPLA CON TODAS LAS PROVISIONES DE ESTA DEMANDA. POR RAZON DE ESA DECISION, ES POSSIBLE QUE USTED pUEDA pERDER DINERO, PROPIEDAD U OTROS DERECHOS IMPORTANTES. LLEVE ESTA DEMANDA A UN ABOGADO RvlIVlEDIATEAMENTE. SI NO CONOCE A UN ABOGADO, LLAME AL "LAWYER REFERENCE SERVICE" (SERVIC10 DE REFERENCIA DE ABOGADOS), (215) 238-6300. CUMBERLAND COUNTY BAR ASSOCIATION 2 Liberty Avenue Carlisle, PA 17013 LEGAL SERVICES INC 8 Irvine Row Carlisle, PA 17013 717-243-9400 COMPLAINT IN MORTGAGE FORECLOSURE 1. Plaintiff is ASSOCIATES CDC A DIVISION OF CITIFINANCIAL SERVICES INC. ITS SUCCESSORS AND/OR ASSIGNS AS THEIR INTEREST MAY APPEAR, 7467 New Ridge Road, Suite 222 Hanover, MD 21076. 2. The name(s) and address(es) of the Defendant(s) is/are CRAIG A. BRUNGARD, 1015 Chippenham Road, Mechanicsburg, PA 17050, who is/are the mortgagor(s) and real owner(s) of the mortgaged premises hereinafter described. 3. On December 15, 2000 mortgagor(s) made, executed and delivered a mortgage upon the premises hereinafter described to ASSOCIATES CDCASSOCIATES CDC A DIVISION OF CITIFINANCIAL SERVICES INC. ITS SUCCESSORS AND/OR ASSIGNS AS THEIR INTEREST MAY APPEAR, which mortgage is recorded in the Office of the Recorder of Deeds of Cumberland County as Book 1658 and Page 904. The mortgage has not been assigned unless said assignment to the Plaintiff is hereafter mentioned. These documents are matters of public record and are incorporated herein by reference in accordance with Pennsylvania Rule of Civil Procedure 1019(g). 4. The premises subject to said mortgage is described as attached. 5. The mortgage is in default because monthly payment of principal and interest upon said mortgage due October 01,2001, and each month thereafter are due and unpaid, and by the terms of said mortgage, upon default in such payments for a period of one month, the entire principal balance and all interest due thereon are collectible forthwith. 6. The following amounts are due on the mortgage: Principal Balance Interest from 09/01/2001 through 03/31/2002 at 12.9700% Per Diem interest rate at $26.76 Attorney's Fee at 5.0% of Principal Balance $75,303.33 $4,870.32 $3,765.17 Costs of suit and Title Search Escrow $750.00 $84,688.82 $0.00 $84,688.82 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 Sheriff's Sale. If the Mortgage is reinstated prior to the Sale reasonable Attorney's Fees will be charged based on work actually performed. 8. Notice of Intention to Foreclose and a Notice of Homeowners' Emergency Mortgage Assistance has been sent to Defendant(s) by Certified and regular mail, as required by Act 160 of 1998 of the Commonwealth of Pennsylvania, on the date(s) set forth in the true and correct copy of such notice(s) attached hereto as Exhibit "A". The Defendant(s) has/have not had the required face-to-face meeting within the required time and Plaintiff has no knowledge of any such meeting being requested by the Defendant(s) through the Plaintiff, the Pennsylvania Housing Finance Agency, or any appropriate Consumer Credit Counseling Agency. WHEREFORE, Plaintiff demands judgment in mortgage foreclosure in the sum of $84,688.82, together with interest at the rate of $26.76, per day and other expenses incurred by the Plaintiff which are properly chargeable in accordance with the terms of the mortgage, and for the foreclosure and sale of the mortgaged premises. ~/GOI~DBECK' McCAFFERTY ~lV~c ~ BY: JOSEPH A. GOLDBECK, JR., ES'QUIRE ATTORNEY FOR PLAINTIFF VERIFICATION I, ~ If/'/{"~ / ~~'/~/'/Or/// ., as the representative of the Plaintiff corporation within named do hereby verify that I am authorized to and do make this verification on behalf of the Plaintiff corporation and the facts set forth in the foregoing Complaint are true and correct to the best of my knowledge, information and belief. I understand that false statements therein are made subject to the penalties of 18 Pa. C.S. 4904 relating to unswom falsification to authorities. THIS DEED Lord o1%o thoussn~ n~.ne nu~u~ ~.,,~ o-' ~1~' ~I~B~, ~at in consi~eration ot ~Ig~ ~IV~ ~OUS~ ~/100 ............... ; .......... ($35,000.00) .............. in hand paid, ~e receip~ vhereo~ is he~Y ac~o~ledq~; ~e said Cran2or does hereby 9ran2 and convey to ~he said Grantee, his Heirs and Assigns, ~e ~olloving described property ~o-~l~: A~ ~ C~AIH' lo~ o~ land' ei~ate in Hampden ~o~shiP, CU~rland Co~y, p~sylvania, being Lo~ ~212, gtngswood, Phase ~:~ ~::~ 55, page 93, mot. B~I~I~ ~ a poin~ on ~e West sid~ of chippewas Road, said poin~ also being a distance o~ One H~dr~ ~enty-Five North (125.00') of ~e in~ersec~ion of ~e Nor~ side of Dorset DriVe and the West eid~ of ~ip~a~ ~oadl ~ence by th~ line of ~ ~0. dearees ~lft~-~ree minutes Twenty'~° seconds 198 Sou~ siqh~y-Two -- .... - ~-- Hundr~ ~elve and One-Hund=ed~a lee I - -~ ~- ~--~ees rif~v-~e minutes · and Thir y- Sixty-Six deqre ~i~uees ~ir~y-One seconds ~as~ tn ~-~.~red~l fie~ (142.97') ~o Hu~d~ed ~orty-~ a~d Ni~ety-~even ~" =---- by e~e w.-e- side of ~e~am Roadl_~e poin~ on ~e ~;~nO a radiUS of ~o ~ndrea ~-Y fee= (250.o0~) ~eon .eco~ ----=--~-~s fae~ fSS.35~) ~o ~e pXace o~ Begi~ng* IS 1015 ~ppe~ ROaaf aO~,- - . , 7160 39~1 9844 6~.~4 9421 ACT 91 NOTICE D^TE OF N : i V ruary $' 2002 TAKE ACTION TO SAVE YOUR HOME FROM FORECLOSURE This is an official notice that the mort a e on our home is in default and the lender in__tends to foreclose S ecific information about the nature of the default is rovided in thee attach~ed pa~ges_. The HOMEOWNER'S MORTGAGE ASSISTANCE PROGRAM HEMAP ma be able to hel_[p_to save~your home. This Notice ex lains how the ro am works. To see if HEMAP can hel_p_,_Y_9_g-must MEET WITH A CONSUMER CREDIT COUNSELING AGENC--~-WITHIN 30 DAYS O__F_F THE DATE OF THIS NOTICE. Take this Notice with 3~ou when__y_ou meet with the Counseling Agency.. -- The name~ address an_~-d--P-h°ne number of Consumer Credit Counseli~ ~are listed at the end of this Notice. If ou have an uestions ou ma call the Pen~vania H~Finance A__Ag_cg_9~ toll free at 1-800-342-2397. ~ersons with im a_p__~ hean_g~Eg_can call 7~) 780-186_9.) This Notice contains important legal information. If you have any questions, representatives at the Consumer Credit Counseling Agency may be able to help explain it. You may also want to contact any attorney in your area. The local bar association may be able to help you find a lawyer. La notificacion en adjunto es de suma importancia, pues afecta su derecho a continuar viviendo en su casa. Si no comprende el contenido de esta notification obtenga una traduccion immediatamente llamanda esta agencia (Pennsylvania Housing Finance Agency) sin cargos al numero mencionada arriba. Puedes ser elegible para un prestamo por el programa llamado "Homeowner's Emergency Mortgage Assistance Program" el cual puede salvar su casa de la perdida del derecho a redimir su hipoteca. Prepared by: GOLDBECK McCAFFERTY & McKEEVER Suite 500 - The Bourse Bldg. 1 l 1 S. Independence Mall East Philadelphia, PA 19106 Fax (215) 627-7734 Date: February 5, 2002 Homeowners Name: CRAIG A. BRUNGARD Property Address: 1015 Chippenham Road, Mechanicsburg, PA 17050 Loan Account No.: 3807990200287 Original Lender: ASSOCIATES CDC A DIVISION OF CITIFINANCIAL SERVICES INC. ITS SUCCESSORS AND/OR ASSIGNS AS THEIR INTEREST MAY APPEAR Current Lender/Servicer: ASSOCIATES CDC A DIVISION OF CITIFINANCIAL SERVICES INC. ITS SUCCESSORS AND/OR ASSIGNS AS THEIR INTEREST MAY APPEAR HOMEOWNERS' EMERGENCY MORTGAGE ASSISTANCE PROGRAM YOU MAY BE ELIGIBLE FOR FINANCIAL_ ASSIS~-~--~E WHI~-- CI-i CAN SAVi} YOUR HOME FROM FORECLOSURE AND HELP YOU MAKE FUTURE MORTGAGE PAYMENTS_ IF YOU COMPLY WITH THE PROVISIONS OF THE HOMEOWNER'S EMERGENCY MORTGAGE ASSISTANCE ACT OF 1983 (THE "ACT"), YOU MAY BE ELIGIBLE FOR EMERGENCY MORTGAGE ASSISTANCE: * IF YOUR DEFAULT HAS BEEN CAUSED BY CIRCUMSTANCES BEYOND YOUR CONTROL, * IF YOU HAVE A REASONABLE PROSPECT OF BEING ABLE TO PAY YOUR MORTGAGE PAYMENTS, AND * IF YOU MEET OTHER ELIGIBILITY REQUIREMENTS ESTABLISHED BY THE PENNSYLVANIA HOUSING FINANCE AGENCY. TEMPORARY STAY OF FORECLOSURE - Under the Act, you are entitled to a temporary stay of foreclosure on your mortgage for thirty (30) days from the date of this Notice. During that time you must arrange and attend a "face-to-face" meeting with one of the designated consumer credit counseling agencies listed at the end of this Notice. THIS MEETING MUST OCCUR WITHIN THE NEXT (~_~__DAYS. IF YOU DO NOT APPLY FOR EMERGENCY MORTGAGE ASSISTANCE_~ YOU MUST BRING YOUR MORTGAGE UP TO DATE. THE PART OF THIS NOTICE CALLED "HOW TO CURE YOUR MORTGAGE DEFAULT"~_EXPLAINS HOW TO BRING YOUR MORTGAGE UP TO DATE. CONSUMER CREDIT COUNSELING AGENCIES - If you meet with one of the consumer credit counseling agencies listed at the end of this notice, the lender may NOT take action against you for thirty (30) days after the date of this meeting. The names, ~ddresses and telephone numbers of - · ies for the count_~X_~which the ropy~p~rty is located are set_ desi hated consumer credit co__ou~n.~ge~ schedule one face-to-face meeting. Advise your forth at tl~e eno m mt~ .... ' ' ' ~ . , _~.~.;o ~xT,,tice It ~s only necessary t lender ~ of your intentions. APPLICATION FOR MORTGAGE ASSISTANCE - Your mortgage is in default for the reasons set forth later-in thi-s Notice (see following pages fo~-- r specific information about the nature of your default.) If you have tried and are unable to resolve this problem with the lender, you have the right to apply for financial assistance from the Homeowner's Emergency Mortgage Assistance Program. To do so, you must fill out, sign and file a completed Homeowner's Emergency Assistance Program Application with one of the designated consumer credit counseling agencies listed at the end of this Notice. Only consumer credit counseling agencies have applications for the program and they will assist you in submitting a complete application to the Pennsylvania Housing Finance Agency. Your application MUST be filed or postmarked within thirty (30) days of your fact-to-face meeting. YOU MUST FILE YOUR APPLICATION PROMPTLY. IF YOU FAIL TO DO SO OR IF YOU DO NOT FOLLOW THE OTHER TIME PERIODS SET FORTH IN THIS LETTER, FORECLOSURE MAY PROCEED AGAINST YOUR HOME IMMEDIATELY AND YOUR APPLICATION FOR MORTGAGE ASSISTANCE WILL BE DENIED. AGENCY ACTION - Available funds for emergency mortgage assistance are very limited. They wi~be dis~urse~ tl~e Agency under the eligibility criteria established by the Act. The Pennsylvania Housing Finance Agency has sixty (60) days to make a decision after it receives your application. During that time, no foreclosure proceedings will be pursued against you if you have met the time requirements set forth above. You will be notified directly by the pennsylvania Housing Finance Agency of its decision on your application. HOW TO CURE YOUR MORTGAGE DEFAULT ~ NATURE OF THE DEFAULT - The MORTGAGE debt held by the above lender on your property located at: 1015 Chippenham Road, Mechanicsburg, PA 17050 IS SERIOUSLY IN DEFAULT because: A. YOU HAVE NOT MADE MONTHLY MORTGAGE PAYMENTS for the following months and the following amounts are now past due: (a) Monthly payment from 10/01/2001 thru 2/5/2002 (5 mos. at $835.77/month) $$4,178.85 (b) Partial payment from 9/01 .56 (c) Other charges; Escrow, Inspec., NSF Checks (d) Other provisions of the mortgage obligation, if any (e) TOTAL AMOUNT OF (a) (b) and (c) REQUIRED AS OF THIS DATE: $4,179.41 cure the default within THIRTY (30) DAYS of the THE DEFAULT - You may ....... -~w nil THE LENDER WHICH HOW._TO cURE Ti -w_.~_~ T~E TOTAL AMOumt r~ .... E TO date of this notice BY PA¥1t'~J ~-~ IS $4~179.41, PLUS ANY MORTGAGE PAYMENTS AND LATE CHARGES WHICH BECOME DUE D~-~G THE THIRTY (30) DAY PERIOD. Pa ents must be made either~_by cash~_cas_hier's_ check, certified check or mon_~y o~le and sent to~: CITIFINANCIAL SERVICES INC. 7467 New Ridge Road Suite 222 Hanover, MD 21076 AULT - If you do not cure the default IF YOU DO NOT CURE TH?.DE~F._A_UJ.,~ ~ ~-T^,~ t e lender intends to exercise its rights to_ .., .~:::w---------~¥,m~-v t~m D YS ot'tt~e aate oxuu~ ~,u~x,~,~, the leg accelerate the mort~bt: This me~s that the entire outst~ding bal~ce of this debt will bu ~n~ed due immediately and you may lose the chmce to pay the mo~gage in mon~ly instalments. If full payment of the total amo~t past due is not made within TH~TY (30) DAYS, the lender also intends to instruct its attorneys to st~ legal action to fo~ecl9se upon your mortgaged prope~ IF THE M~RTGAGE IS FO~CLOSED UPO~ - The mo~gaged prope~ will be sold by the Sheriff to pay off the mo~gage d~bt. If the lender refers yo~ c~e to its attorneys, but you c~e the delinquency before the lender brings legal proceedings against you, you will still be required to pay ~e reasonable attorney's fees that were actually inched, up to $50.00. However, if legal proceedings ~e sta~ed against you, you will have to pay all reasonable attorney's fees actually incu~ed by the lender even if they exceed $50.00. ~Y attorney's fees will be added to the mo~t you owe ~e lender, which may also include other reasonable costs. IJ you cure the default within the THIRTY (30) DAm ~, you will no~uired to. pay attorney's fees: OTHER LENDER ~MEDIES - The lender may also sue you personally for the ~paid principal balance ~d all other sins due ~der the mo~gage. ~GHT TO CU~ THE DEFAULT p~OR TO SHE~FF'S S~[ - If you have not c~ed the default within the THIRTY (30) DAY period ~d foreclos~e proceedings have be~, Xou still have ~to cure the default ~d prevent the sale at ~~to one ho~ before ~e Shefifgs Sale. You ma~ total mo~t the~°r other c~ }easonable attom~ fees ~d costs co~ected with the foreclos~e sale~ o~er costs co~ected with the SherifCs Sale as~ified in ~the lender~°ther re~remems unde~ the m~e. Curing your default in the manner set forth in this notice will restore your mortgage to the same position as if you had never defaulted. EARLIEST POSSIBLE SHERIFF'S SALE DATE_ - It is estimated that the earliest date that such a of the mortgaged property could be held would be approximately ~(6) sent to Sheriffs Sale months from the date of this Notice. A notice of the actual date of the Sheriffs Sale will be you before the sale. Of course, the amount needed to cure the default will increase the longer you wait. You may find out at any time exactly what the required payment or action will by contacting the lender. HOW TO CONTACT THE LEN~DE~R:_ Name of Lender: .CITIFINANCIAL SERVICES INC. Address: 7467 New Ridge Road Suite 222 Hanover, MD 21076 Phone Number: 800-446-7876 x1604 Fax_____Number: _ 710-689-1610 Contact~Per_son: Meryl Kessler EFFECT OF SHERIFF'S SALE - You should realize that a Sheriffs Sale will end your ownership of i-he m--~-gage-d-p-~oproperty and your right to occupy it. If you continue to live in the property after the Sheriffs Sale, a lawsuit to remove you and your furnishings and other belongings could be started by the lender at any time. ASSUMPTION OF MORTGAGE - You may sell or transfer your home to a buyer or transferee who ~e the-mortgage debt, prov-ided that all the outstanding payments, charges and attorney's fees and costs are paid prior to or at the sale and that the other requirements of the mortgage are satisfied. YOU MAY~ALSO HAVE THE RIGHT'.. · OPERTY TO OBTAIN MONEY TO PAY OFF THE MORTGAGE * TO SELL THE PR .......... ~ · ~ND INSTITUTION TO PAY OFF DEBT OR TO BORROW MONEY FROM Arqt2tnr-.r~ ,~ .... lNG THIS DEBT. * TO HAVE THIS DEFAULT CURED BY ANY THIRD PARTY ACTING ON YOUR BEHALF. * TO HAVE THE MORTGAGE RESTORED TO THE SAME POSITION AS IF NO DEFAULT HAD OCCURRED, IF YOU CURE THE DEFAULT. (HOWEVER, YOU DO NOT HAVE THIS RIGHT TO CURE YOUR DEFAULT MORE THAN THREE TIMES IN ANY CALENDAR YEAR.) ISTENCE OF A DEFAULT IN ANY FORECLOSURE . SSERT THE NONEX - - ER THE MORTGAGE TO A ...... ,m TIT INSTITUTED UND PROCEEDING OR ANY OTHEK b~wat~ DocuMENTS- OTHER DEFENSE YOU BELIEVE YOU MAY HAVE TO SUCH * TO ASSERT ANY ACTION BY THE LENDER- * TO SEEK PROTECTION UNDER THE FEDERAL BANKRUPTCY LAW. Contact Person: Meryl Kessler Phone Number: 800-446-7876 x1604 PENNSYLVANIA HOUSING FINANCE AGENCY HOMEOWNER'S EMERGENCY MORTGAGE ASSISTANCE PROGRAM CONSUMER CREDIT COUNSELING AGENCIES CUMBERLAND COUNTY CCCS OF WESTERN PENNSYLVANIA INC. 2000 Linglestown Road Harrisburg, PA 17102 (717) 541-1757 URBAN LEAGUE OF METROPOLITAN HARRISBURG 2107 N. 6th Street Harrisburg, PA 17101 (717) 234-5925 FAX (717) 234-9459 COMMUNITY ACTION COMM OF THE CAPITAL REGION 1514 Derty Street Harrisburg, PA 17104 (717) 232-9757 FAX 234-2227 FINANCIAL COUNSELING SERVICES OF FRANKLIN 31 West 3rd Street Wayaesboro, PA 17268 (717) 762-3285 YWCA OF CARLISLE 301 G Street Carlisle, PA 17013 (717) 243-3818 FAX (717) 731-9589 ADAMS COUNTY HOUSING AUTHORITY 139-143 Carlisle Street Gettysburg, PA 17325 (717) 334-1518 FAX (717) 334-8326 In the Court of Common Pleas of Cumberland County ASSOCIATES CDC A DIVISION OF CITIF1NANCIAL SERVICES INC. ITS SUCCESSORS AND/OR ASSIGNS AS THEIR INTEREST MAY APPEAR 7467 New Ridge Road Suite 222 Hanover, MD 21076 VS. CRAIG A. BRUNGARD (Mortgagor(s) and Record Owner(s)) l015 Chippenham Road Mechanicsburg, PA 17050 Plaintiff Defendant(s) No. 02-1373 CIVIL TERM PRAECIPE FOR JUDGMENT THIS LAW FIRM IS A DEBT COLLECTOR AND WE ARE ATTEMPTING TO COLLECT A DEBT OWED TO OUR CLIENT. ANY INFORMATION OBTAINED FROM YOU WILL BE USED FOR THE PURPOSE OF COLLECTING THE DEBT. Enter the Judgment in favor of Plaintiff and against CRAIG A. BRUNGARD by default for want of an Answer. Assess damages as follows: Debt $86,267.66 Interest - 09/01/2001 to 05/29/2002 Total (Assessment of Damages attached) I CERTIFY THAT FOREGOING ASSESSMENT OF DAMAGES IS FOR SPECIFIED AMOUNTS ALLEGED TO BE DUE IN THE COMPLAINT AND IS CALCULABLE AS A SUM CERTAIN FROM THE COMPLAINT. 1 certify that written notice of the intention to file this praecipe was mailed or del ~ to th ~xarty against whom judgment is to be entered and to his attorney of record, if any, after the default occurred al ~( ,~ prior to the date ofthe filing of this praecipe. A copy of the notice is attached. R.C.P. 237.1 Joseph. gG~ldb~l Attorne~ ~ Plain~/~ I.D. #161 AND NOW V IsIoNo I , 0 , Jud eut is entered favor of ASSOCIATES CDC A DI CITIFINANCIAL SERVICES INC. ITS SUCCESSORS AND/OR ASSIGNS AS THEIR INTEREST MAY APPEAR and against CRAIG A. BRUNGARD by default for want of an Answer and damages assessed in the sum of $86,257.66 as per the above certification.Prothonotary~~ GOLDBECK McCAFFERTY & McKEEVER BY: Joseph A. Goldbeck, Jr. Attorney I.D. #16132 Suite 500 - The Bourse Bldg. 111 S. Independence Mall East Philadelphia, PA 19106 215-627-1322 Attorney for Plaintiff ASSOCIATES CDC A DIVISION OF CITIFINANCIAL SERVICES INC. ITS SUCCESSORS AND/OR ASSIGNS AS THEIR INTEREST MAY APPEAR 7467 New Ridge Road Suite 222 Hanover, MD 21076 Plaintiff VS, CRAIG A. BRUNGARD (Mortgagor(s) and Record owner(s)) 1015 Chippenham Road Mechanicsburg, PA 17050 Defendant(s) IN THE COURT OF COMMON PLEAS of Cumberland County CIVIL ACTION LAW ACTION OF MORTGAGE FORECLOSURE No. 02-1373 CIVIL TERM ORDER FOR JUDGMENT Please enter Judgment in favor of ASSOCIATES CDC A DIVISION OF CITIFINANCIAL SERVICES INC. ITS SUCCESSORS AND/OR ASSIGNS AS THEIR INTEREST MAY APPEAR, and against CRAIG A. BRUNGARD for failure to file an Answer in the above action with~in (20) ~ ys (or sixty (60) days if defendant is the United States of America) from the date of service of the C~t~i Isu~. of $86,267.66. Joseph PI. ~olclbe~ ;Ir. Attome2~r Plai~ I hereby certify that the above names are correct and that the precise residence address of the judgment creditor is ASSOCIATES CDC A DIVISION OF CITIFINANCIAL SERVICES INC. ITS SUCCESSORS AND/OR ASSIGNS AS THEIR INTEREST MAY APPEAR 7467 New Ridge Road Suite 222 Hanover, MD 21076 and that the name(s) and last known address(es) of the Defendant(s) is/are CRAIG A. BRUNGARD, 1015 Chippenham Road Mechanicsburg, PA 17050; GOLD~ BY: Jo~e] Attomq~ t (ERTY & ck, Jr. MeKEEVER ASSESSMENT OF DAMAGES TO THE PROTHONOTARY: Kindly assess the damages in this case to be as follows: Principal Balance $75,303.33 Interest ffomO9/O1/2OOlthrough 05/29/2002 $6,449.16 Attorney's Fee at 5.0000% of principal balance $3,765.17 Late Charges $0.00 Costs of Suit and Title Search $750.00 Escrow Balance Deficit $0.00 ($0.00) GOLDBEC~ BY: Joseph A. Attorney for PI; $86,267.66 AND NOW, this 3[ dayof ~ ,2002 damages are assessed as above. Pro Prothy VERIFICATION OF NON-MILITARY SERVICE The undersigned, as the representative for the Plaintiff corporation within named do hereby verify that I am authorized to make this verification on behalf of the Plaintiff corporation and that the facts set forth in the foregoing verification of Non- Military Service are true and correct to the best of my knowledge, information and belief. I understand that false statements therein are made subject to penalties of 18 Pa. C.S. 4904 relating to unsworn falsification to authorities. 1. That the above named Defendant, CRAIG A. BRUNGARD, is about unknown years of age, that Defendant's last known residence is 1015 Chippenham Road, Mechanicsburg, PA 17050, and is engaged in the unknown business located at unknown address. 2. That Defendant is not in the Military or Naval Service of the United States or its Allies, or otherwise within the provisions of the Soldiers' and Sailors' Civil Relief Action of Congress of 1940 and its Amendments. Date: THIS LAW FIRM IS A DEBT COLLECTOR AND WE ARE ATTEMPTING TO COLLECT A DEBT OWED TO OUR CLIENT. ANY INFORMATION OBTAINED FROM YOU WILL BE USED FOR THE PURPOSE OF COLLECTING THE DEBT. DATE OF THIS NOTICE: April 15, 200Z TO: CRAIG A. BRUNGARD 1015 Chippenham Road Mechanicsburg, PA 17050 ASSOCIATES CDC A DIVISION OF CITIFINANCIAL SERVICES INC. ITS SUCCESSORS AND/OR ASSIGNS AS THEIR INTEREST MAY APPEAR 7467 New Ridge Road Suite 222 Hanover, MD 21076 VS. CRAIG A. BRUNGARD (Mortgagor(s) and Record Owner(s)) 1015 Chippenham Road Mechanicsburg, PA 17050 Plaintiff Defendant(s) In the Court of Common Pleas of Cumberland County CIVIL ACTION - LAW Action of Mortgage Foreclosure Terli1 No. 02-1373 CIVIL TERM TO: CRAIG A. BRUNGARD 1015 Chippenham Road Mechanicsburg, PA 17050 IMPORTANT NOTICE YOU ARE IN DEFAULT BECAUSE YOU HAVE FAILED TO ENTER A WRITTEN APPEARANCE PERSONALLY OR BY ATTORNEY AND FILE IN WRITING WITH THE COURT YOUR DEFENSES OR OBJECTIONS TO THE CLAIMS SET FORTH AGAINST YOU. UNLESS YOU ACT WITHIN TEN (10) DAYS FROM THE DATE OF THIS NOTICE, A JUDGMENT MAY BE ENTERED AGAINST YOU WITHOUT A HEARING AND YOU MAY LOSE YOUR PROPERTY OR OTHER IMPORTANT RIGHTS. YOU SHOULD TAKE THIS NOTICE TO A LAWYER AT ONCE. IF YOU DO NOT HAVE A LAWYER OR CANNOT AFFORD ONE, GO TO OR TELEPHONE THE FOLLOWING OFFICE TO FIND OUT WHERE YOU CAN GET LEGAL HELP: CUMBERLAND COUNTY BAR ASSOCIATION 2 L/beriy Avenue Carlisle, PA 17013 LEGAL SERVICES [NC 8 hMne Row Ci~rlisle, PA 17013 717 243 O400 Attorney for Plaintiff Suite 500 - ~lae Bourse Bldg. 111 S. Independence Mall East Philadelphia, PA 19106 215-627-1322 Rule of Civil Procedure No. 236 - Revised 1N THE COURT OF COMMON PLEAS OF Cumberland COUNTY, PENNSYLVANIA CIVIL ACTION - LAW ASSOCIATES CDC A DIVISION OF CIT1FINANCIAL SERVICES INC. ITS SUCCESSORS AND/OR ASSIGNS AS THEIR INTEREST MAY APPEAR 7467 New Ridge Road Suite 222 Hanover, MD 21076 Plaintiff VS, No. 02-1373 CIVIL TERM CRAIG A. BRUNGARD (Mortgagors and Record Owner(s)) 1015 Chippenham Road Mechanicsburg, PA 17050 Defendant(s) THIS LAW FIRM IS A DEBT COLLECTOR AND WE ARE ATTEMPTING TO COLLECT A DEBT OWED TO OUR CLIENT. ANY INFORMATION OBTA1NED FROM YOU WILL BE USED FOR THE PURPOSE OF COLLECTING THE DEBT. NOTICE Notice is given that a judgment in the above-captioned matter has been entered against you. Curt Long Protho~tary By: ~'~Lat~ If you have any questions concerning the above, please contact: Joseph A. Goldbeck, Jr. Goldbeck McCafferty & McKeever Suite 500 - The Bourse Bldg. 111 S. Independence Mall East Philadelphia, PA 19106 215-627-1322 PRAECIPE FOR WRIT OF EXECUTION - (MORTGAGE FORECLOSURE) P.R.C.P 3180-3183 Joseph A. Goldbeck, Jr. Attorney I.D.#16132 Suite 500 - The Bourse Bldg. 111 S. Independence Mall East Philadelphia, PA 19106 215-627-1322 Attorney for Plaintiff ASSOCIATES CDC A DIVISION OF CITIFINANCIAL SERVICES INC. ITS SUCCESSORS AND/OR ASSIGNS AS THEIR INTEREST MAY APPEAR 7467 New Ridge Road Suite 222 Hanover, MD 21076 Plaintiff VS. CRAIG A. BRUNGARD Mortgagor(s) and Record Owner(s) 1015 Chippenham Road Mechanicsburg, PA 17050 Defendant(s) IN THE COURT OF COMMON PLEAS of Cumberland County CIVIL ACTION - LAW ACTION OF MORTGAGE FORECLOSURE No. 02-1373 CIVIL TERM PRAECIPE FOR WRIT OF EXECUTION TO THE PROTHONOTARY: Issue Writ of Execution in the above matter: Amount Due Interest from 09/01/2001 to 05/29/2002 at 12.9700% (Costs to be added) $86,267.66 GOLDBECK M BY: Joseph A. q Attorney for Pla FFEI~FY ~eck, yr. ~ff ~ i~cKEEVER Easements, Restrictions, E~uitable Servitudes, ~arges and biens dated Nove~e= 9, 1988 ~ ~ecorde~ Nove~er 10, 1988 in ~erland County Miscellaneous Book ~56, Page 1095. ~ER ~ ~JECT, Also, to all easements a~d restrictions of record and as set for~ on ~e recorded plan ~escr~bed ~ove. ~ ~ ~, Also, to an easemen= five feet (5~) in width on ~e inside of ~e ~ront property line for an underground stone trench to carry drainage waters alongside and under Chigpe~am Road ~rom ~e lot line between lots 222 and 223. ~ access easement for ~e Homeowner's Associat~on baleen Lot No. 220 and Lot No. 221 as shown on ~aid plan has been eliminated in favor of a 10 foot (10') bike path easement to Hampden To,ship centered on ~e lot line between Lot No. 220 and ~t No. 221. 'z~ Recreation Area sho~ on the Final Plan of Kingswood, Phase ~I, as r~ocded in Cumberland County Plan ~ook 55, page 9~, will be eliminated and developed as building lots. BEI~ a part of the same premises which SO~H CE~L SERVICE- CO~., et. al., by their deed dated ~ay 25, 1988, and recorded May 27, 1988 in the Cu~erland County Deed Book 33-J, Page 17 granted and conveyed unto PA~Y D~E~PMENT CO., INC., Grantor herein. ~ The said Grantor Will Specially WAR~NT ~ ~O~VER DEFE~ the ~roperty hereby conveyed. IN WI~SS ~OF, ~e Gr~tor has caused this Deed to be si~ed by its President or a Vice president, and also by-its Secretary, or by an Assistant Secretary, or by i~s Treasurer, or by an Assistant Treasurer, and its Corporate Seal to be hereunto affixed, the day and year firmt above written. ALL T~AT CERTAIN' lot of land' situate in Hampden Towmship, Cumberland County, Pennsylvania, being Lot ~212, Kingswood, Phase II., as recorded in ~mberland County Plan Book 55, Page 93, more particularly bounde~ and described as follows, to wit: ~EGX~X~ at a ~tnt On the West side of Chippe~am Road, ~aid point also being a distance of One Hundred ~enty-Five feet North (125.00') of ~e intersection of the North side of Dorset Drive and the West side of ~ippe~am Road~ thence by the line of ~t No. 198 South Eighty-Two degrees Fifty-Three minutes Twenty-Two West (S 82"53'22" W) a distance of One Hundred Twelve and One One-Hundred~s feet (112.01') to a point at line of Lot No. 199; thence by same Nor~ ~enty-Eight degrees Fifty-One minutes ~irty-Five seconds West (N 28"51'35" W) a distance of Ninety-FiVe and Thirty-Four One-Hundredths feet (95.34') to a point at li~e of ~t No. 211; ~ence by same Nor~ Six92-Six degrees ~enty-E{g~t ' minutes ~irty-One seconds East (N 66"28'31" E) a distance ox Hundred ~orty-Two a~d Ninety-Seven One-Hundred~s feet (142.97 point on the West side of ~ppe~am Road; thence by s~e ~d to the right having a radius of ~o Hundred Fifty feet (2SO.C0') an. ' ar~ length o~ Seventy-One and Fifty-Eight One-Hu~red~s fee= ' (71.58'.) to a point; ~mn=e by s~e Sou~ Seven degrees Seven minu~s Fifteen seconds East (S 07~07'15" E) a distance 0f Fifty-Eight ~i~y-Five One-~dred~s feet (58.3~') to ~e place of Begi~ing. CO~AINI~ 14,246.40 s~are feet, a~ bein~ ~o~ ~d n,.~r~ as 1015 ~ppe~ Road, Mech~lcs~rg, Pe~sylv~la. TAX PARCEL # 10-16-1056-162 SUB.1ECT TO MORTGAGE WRIT OF EXECUTION - (MORTGAGE FORECLOSURE) P.R.C.P. 3180-3183 AND Rule 3257 ASSOCIATES CDC A DIVISION OF CITIFINANCIAL SERVICES INC. ITS SUCCESSORS AND/OR ASSIGNS AS THEIR INTEREST MAY APPEAR 7467 New Ridge Road Suite 222 Hanover, MD 21076 VS. CRAIG A. BRUNGARD 1015 Chippenham Road Mechanicsburg, PA 17050 In the Court of Common Pleas of Cumberland County No. 02-1373 CIVIL TERM WRIT OF EXECUTION (MORTGAGE FORECLOSURE) Commonwealth of Pennsylvania: County of Cumberland 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: PREMISES: 1015 Chippenham Road Mechanicsburg, PA 17050 See Exhibit "A" attached AMOUNT DUE $86,267.66 Interest From 09/01/2001 Through 05/29/2002 (Costs to be added) Dated: Prothonotary, Common Pleas Court of Cumberland County, Pennsylvania Deputy o o~ . Gotdbeck McCafferty & McKeever BY: Joseph A. Goldbeck, Jr. Attorney I.D. #16132 Suite 500 - The Bourse Bldg. 111 S. Independence Mall East Philadelphia, PA 19106 215-627-1322 Attorney for Plaintiff ASSOCIATES CDC A DIVISION OF CITIFINANCIAL SERVICES INC. ITS SUCCESSORS AND/OR ASSIGNS AS THEIR INTEREST MAY APPEAR 7467 New Ridge Road Suite 222 Hanover, MD 21076 Plaintiff VS. CRAIG A. BRUNGARD (Mortgagor(s) and Record Owner(s)) 1015 Chippenham Road Mechanicsburg, PA 17050 Defendant(s) IN THE COURT OF COMMON PLEAS of Cumberland County CIVIL ACTION - LAW ACTION OF MORTGAGE FORECLOSURE No. 02-1373 CIVIL TERM AFFIDAVIT PURSUANT TO RULE 3129 ASSOCIATES CDC A DIVISION OF CITIFINANCIAL SERVICES INC. ITS SUCCESSORS AND/OR ASSIGNS AS THEIR INTEREST MAY APPEAR, Plaintiff in the above action, by its attorney, Joseph A. Goldbeck, Jr., Esquire, sets forth as of the date the praecipe for the writ of execution was filed the following information concerning the real property located at: 1015 Chippenham Road Mechanicsburg, PA 17050 1 .Name and address of Owner(s) or Reputed Owner(s): CRAIG A. BRUNGARD 1015 Chippenham Road Mechanicsburg, PA 17050 2. Name and address of Defendant(s) in the judgmem: CRAIG A. BRUNGARD 1015 Chippenham Road Mechanicsburg, PA 17050 3. Name and last known address of every judgment creditor whose judgment is a record lien on the property to be sold: PA DEPARTMENT OF PUBLIC WELFARE - Bureau of Child Support Enforcement Health and Welfare Bldg. - Room 432 P.O. Box 2675 Hamsburg, PA 17105-2675 DOMESTIC RELATIONS OF CUMBERLAND COUNTY PO Box 320 Carlisle, PA 17013 FEDERAL NATIONAL MORTGAGE ASSOCIATION. PO Box 1169 Milwaukee, WI 53201-0800 ASSOCIATES FINANCIAL SERVICES lq(,,'/ t~ew Ridge Road Hanover, MD 21076 4. Name and address of the last recorded holder of every mortgage of record: FEDERAL NATIONAL MORTGAGE ASSOCIATION 510 Walnut Street Philadelphia, PA 19106 5. Name and address of every other person who has any record interest in or record lien on the property and whose interest may be affected by the sale: 6. Name and address of every other person of whom the plaintiff has knowledge who has any record interest in the property which may be affected by the sale. 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. PAMAY DEVELOPMENT CO INC 5140 East Trindle Road Mechanicsburg, PA 17055 (attach separate sheet if more space is needed) 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 unswornDATED: May 29, 2002falsificati°n to authorities. Jr., Esq. GOLDBECK McCAFFERTY & McKEEVER BY: Joseph A. Goldbeck, Jr. Attorney I.D.#16132 Suite 500 - The Bourse Bldg. 111 S. Independence Mall East Philadelphia, PA 19106 215-627-1322 Attorney for Plaintiff ASSOCIATES CDC A DIVISION OF CITIFINANCIAL SERVICES INC. ITS SUCCESSORS AND/OR ASSIGNS AS THEIR INTEREST MAY APPEAR 7467 New Ridge Road Suite 222 Hanover, MD 21076 Plaintiff VS. CRAIG A. BRUNGARD Mortgagor(s) and Record Owner(s) 1015 Chippenham Road Mechanicsburg, PA 17050 Defendant(s) 1N THE COURT OF COMMON PLEAS of Cumberland County CIVIL ACTION - LAW ACTION OF MORTGAGE FORECLOSURE Teml No. 02-1373 CIVIL TERM THIS LAW FIRM IS A DEBT COLLECTOR AND WE ARE ATTEMPTING TO COLLECT A DEBT. THIS NOTICE IS SENT TO YOU IN AN ATTEMPT TO COLLECT A DEBT. ANY INFORMATION OBTAINED FROM YOU WILL BE USED FOR THAT PURPOSE. NOTICE OF SHERIFF'S SALE OF REAL PROPERTY TO: BRUNGARD, CRAIG A. CRAIG A. BRUNGARD 1015 Chippenham Road Mechanicsburg, PA 17050 Your house at 1015 Chippenham Road, Mechanicsburg, PA 17050 is scheduled to be sold at Sheriffs Sale on Wednesday, September 04, 2002, at 10:00 AM, in Commissioners Hearing Rm 2nd FL Courthouse to enforce the court judgment of $86,267.66 obtained by ASSOCIATES CDC A DIVISION OF CITIFINANCIAL SERVICES INC. ITS SUCCESSORS AND/OR ASSIGNS AS THEIR INTEREST MAY APPEAR against you. NOTICE OF OWNER'S RIGHTS YOU MAY BE ABLE TO PREVENT THIS SHERIFF'S SALE To prevent this Sheriffs Sale you must take immediate action: 1. The sale will be cancelled if you pay to ASSOCIATES CDC A DIVISION OF CITIFINANCIAL SERVICES INC. ITS SUCCESSORS AND/OR ASSIGNS AS THEIR INTEREST MAY APPEAR, the back payments, late charges, costs and reasonable attorney's fees due. To find out how much you must pay call: 215-627-1322 2. You may be able to stop the sale by filing a petition asking the Court to strike or open judgment, if the judgment was improperly entered. You may also ask the Court to postpone the sale for good cause. 3. You may also be able to stop the sale through other legal proceedings. You may need an attorney to assert your rights. The sooner you contact one, the more chance you will have of stopping the sale. (See notice below on how to obtain an attorney). YOU MAY STILL BE ABLE TO SAVE YOUR PROPERTY AND YOU HAVE OTHER RIGHTS EVEN IF THE SHERIFF'S SALE DOES NOT TAKE PLACE. 1. If the Sheriffs Sale is not stopped, your property will be sold to the highest bidder. You may find out the price bid price by calling the Sheriff of 717-240-6390. 2. You may be able to petition the Court to set aside thc 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 Sheriffthe full amount due in the sale. To find out if this has happened, you may call the Sheriff of 717-240-6390. 4. If the amount due from the Buyer is not paid to the Sheriff, you will remain the owner of the property as if the sale never happened. 5. You have a right to remain in the property until the full amount due is paid to the Sheriff and the Sheriff gives a deed to the buyer. At that time, the buyer may bring legal proceedings to evict you. 6. You may be entitled to a share of the money which was paid for your house. A schedule of distribution of the money bid for your house will be filed by the Sheriff thirty (30) days from the date of the Sheriffs Sale. This schedule will state who will be receiving that money. The money will be paid out in accordance with this schedule unless exceptions (reasons why the proposed distribution is wrong) are filed with the Sheriff within ten (10) days after the schedule of distribution is filed. 7. You may also have other rights and defenses, or ways of getting your house back, if you act immediately after the sale. YOU SHOULD TAKE THIS PAPER TO YOUR LAWYER AT ONCE. IF YOU DO NOT HAVE A LAWYER OR CANNOT AFFORD ONE, GO TO OR TELEPHONE THE OFFICE LISTED BELOW TO FIND OUT WHERE YOU CAN GET LEGAL HELP. CUMBERLAND COUNTY BAR ASSOCIATION 2 Liberty Avenue Carlisle, PA 17013 LEGAL SERVICES INC 8 Irvine Row Carlisle, PA 17013 Jospeh A. Goldbeck, Jr. Attorney I.D. #16132 Suite 500 - The Bourse Bldg. 111 S. Independence Mall East Philadelphia, PA 19106 215-627-1322 Attorney for Plaintiff ASSOCIATES CDC A DIVISION OF CIT1FINANCIAL SERVICES INC. ITS SUCCESSORS AND/OR ASSIGNS AS THEIR INTEREST MAY APPEAR 7467 New Ridge Road Suite 222 Hanover, MD 21076 VS. Plaintiff CRAIG A. BRUNGARD Mortgagor(s) and Record Owner(s) 1015 Chippenham Road Mechanicsburg, PA 17050 Defendant(s) IN THE COURT OF COMMON PLEAS of Cumberland County CIVIL ACTION - LAW ACTION OF MORTGAGE FORECLOSURE NO. 02-1373 CIVIL TERM CERTIFICATION AS TO THE SALE OF REAL PROPERTY I, Joseph A. Goldbeck, Jr., Esquire hereby certify that I am the attorney of record for the Plaintiff in this action, and I further certify that this property is subject to Act 91 of 1983 and the Plaintiff has complied with all the provisions of the Act. Jol A.~d~r.t Atto~ ~ pl~fiti[y GOLDBECK McCAFFERTY & McKEEVER BY: Joseph A. Goldbeck, Jr. Attorney I.D.# 16132 Suite 500 - The Bourse Bldg. 111 S. Independence Mall East Philadelphia, PA 19106 215-627-1322 Attorney for Plaintiff ASSOCIATES CDC A DIVISION OF CIT1FINANCIAL SERVICES INC. ITS SUCCESSORS AND/OR ASSIGNS AS THEIR INTEREST MAY APPEAR 7467 New Ridge Road Suite 222 Hanover, MD 21076 vs. Plaintiff CRAIG A. BRUNGARD Mortgagor and Record Owner 1015 Chippenham Road Mechanicsburg, PA 17050 Defendant IN THE COURT OF COMMON PLEAS of Cumberland County CIVIL ACTION - LAW ACTION OF MORTGAGE FORECLOSURE No. 02-1373 CIVIL TERM CERTIFICATE OF SERVICE PURSUANT TO Pa.R.C.P. 3129.2 (c) (2} Joseph A. Goldbeck, Jr., Esquire, Attorney for Plaintiff, hereby certifies that service on the Defendants of the Notice of Sheriff Sale was made by: I) Personal Service by the Sheriffs Office/"~-'~T'_t::~t ' ,|', (copy of return attached). Certified mail by Joseph A. Goldbeck, Jr. (original green Postal return receipt attached). ( ) Certified mail by Sheriffs Office. ( ) Ordinary mail by Joseph A. Goldbeck, Jr., Esquire to Attomey for Defendant(s) of record (proof of mailing attached). ( ) Acknowledgment of Sheriffs Sale by Attorney for Defendant(s) (proof of acknowledgment attached). ( ) Ordinary mail by Sheriffs Office to Attorney for Defendant(s) of record. IF SERVICE WAS ACCOMPLISHED BY COURT ORDER. ( ) Premises was posted by Sheriffs Office/competent adult (copy of return attached). ( ) Certified Mail & ordinary mail by Sheriffs Office (copy of return attached). ( ) Certified Mail & ordinary mail by Joseph A. Goldbeck, Jr. (original receipt(s) for Certified Mail attached). Pursuant to the Affidavit under Rule 3129 (copy attached), service on all lienholders (if any) has been made by ordinary mail by Joseph A. Goldbeck, Jr., Esquire (copies of proofs of mailing attached). The undersigned understands that the statements herein are subject to the penalties provided by 18 P.S. Section 4904. ~h A.~3oldbeck, Jr.--' - ~'ney for Plaintiff Associates CDC a Division of Citifinancial In The Court of Common Pleas of Services Inc., its successors and/or assigns Cumberland County, Pennsylvania As their interest may appear Writ No. 2002-1373 Civil Term VS Craig A. Brungard Jason Vioral, Deputy Sheriff, who being duly sworn according to law, states that on June 12, 2002 at 9:51 o'clock AM, he served a tree copy of the within Real Estate Writ, Notice and Description, in the above entitled action, upon the within named defendant, to wit: Craig A. Brungard, by making known unto Craig Brungard personally, at 1015 Chippenham Rd., Mechanicsburg, Cumberland County, Pennsylvania, its contents and at the same time handing to him personally the said true and correct copy of the same. Valerie Weary, Deputy Sheriff, who being duly sworn according to law, states that on July 09, 2002 at 1:25 o'clock P.M., she posted a tree copy of the within Real Estate Writ, Notice, Poster and Description, in the above entitled action, upon the property of Craig A. Brungard located at 1015 Chippenham Road, Mechanicsburg, 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: Craig A. Bmngard, by regular mail to his last known address of 1015 Chippenham Road, Mechanicsburg, PA 17055. This letter was mailed under the date of July 16, 2002 and never returned to the Sheriffs Office. Sworn and subscribed to before me This 2002, A.D. __ day of Prothonotary R. Thomas Kline, ~heriff Real Estate'Deputy GOLDBECK McCAFFERTY & McKEEVER BY: Joseph A. Goldbeck, Jr. Attorney I.D.#16132 Suite 500 - The Bourse Bldg. 111 S. Independence Mall East Philadelphia, PA 19106 215-627-1322 Attorney for Plaintiff ASSOCIATES CDC A DIVISION OF CITIFINANCIAL SERVICES INC. 1TS SUCCESSORS AND/OR ASSIGNS AS THEIR INTEREST MAY APPEAR 7467 New Ridge Road Suite 222 Hanover, MD 21076 Plaintiff vs. CRAIG A. BRUNGARD Mortgagor and Record Owner 1015 Chippenham Road Mechanicsburg, PA 17050 Defendant IN THE COURT OF COMMON PLEAS of Cumberland County CIVIL ACTION - LAW ACTION OF MORTGAGE FORECLOSURE Term No. 02-1373 CIVIL TERM SUPPI,EMENTAL AFFIDAVIT PURSUANT TO RULE 3129 ASSOCIATES CDC A DIVISION OF CITIF1NANCIAL SERVICES INC. ITS SUCCESSORS AND/OR ASSIGNS AS THEIR INTEREST MAY APPEAR, Plaintiff in the above action, by its attorney, Joseph A. Goldbeck, Jr., Esquire, sets forth as of the date the praecipe for the writ of execution was filed the following information concerning the real property located at: 1015 Chippenham Road Mechanicsburg, PA 17050 1 .Name and address of Owner or Reputed Owner: CRAIG A. BRUNGARD 1015 Chippenham Road Mechanicsburg, PA 17050 2. Name and address of Defendant in the judgment: CRAIG A. BRUNGARD 1015 Chippenham Road Mechanicsburg, PA 17050 3. Name and last known address of every judgment creditor whose judgment is a record lien on the property to be sold: FEDERAL NATIONAL MORTGAGE P.O. Box 3147 Milwaukee, WI 53201 PA DEPARTMENT OF PUBLIC WELFARE Bureau of Child Support Enforcement Health and Welfare Bldg. - Room 432 P.O. Box 2675 Harrisburg, PA 17105-2675 DOMESTIC RELATIONS OF CUMBERLAND COUNTY PO Box 320 Carlisle, PA 17013 FEDERAL NATIONAL MORTGAGE ASSOCIATION. PO Box 1169 Milwaukee, WI 53201-0800 ASSOCIATES FINANCIAL SERVICES 7467 New Ridge Road Hanover, MD 21076 4. Name and address of the last recorded holder of every mortgage of record: FEDERAL NATIONAL MORTGAGE ASSOCIATION 510 Walnut Street Philadelphia, PA 19106 5. Name and address of every other person who has any record interest in or record lien on the property and whose interest may be affected by the sale: 6. Name and address of every other person of whom the plaintiff has knowledge who has any record interest in the property which may be affected by the sale. 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. PAMAY DEVELOPMENT CO INC 5140 East Trindle Road Mechanicsburg, PA 17055 (attach separate sheet if more space is needed) 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 unsworn falsification to authorities. DATED: August 16, 2002 ittomey for Plaintiff 7160 3901 9844 8592 3041 TO: CRAIG A. BRUNGARD 1015 Chippenham Road Mechanicsburg, PA 17050 SENDER: GOLDBECK Mcc^FFERTY & MCKEEVER May 29, 2002 REFERENCE: BR~NG~I~, CI~IG A. / ACD-12! ! 09/04/02 - Cumberland PS Form 3800 June 2000 RETURN~ RECEIPT_ I Certified Fee [SERVICE Ret~'~"~R eceipt F..~ee_ ~ ~ted Delivery i~_________~ Postage & Fees US Postal Service Receipt for Certified Mail No Insurance Coverage provided Do Not Use for international Mail AFFIX POSTAGE TO MAIL PIECE TO COVER FIRST CLASS POSTAGE, CERTIFIED FEE, RETURN RECEIPT FEE AND CHARGES FOR ANY SELEC'~ED OPTIONAL SERVICES, 1. Detach the form 3811, Domestic return receipt by tear- ing left to right across peri Attach to mailpiece by peeling back the adhesive strips and affixing to front of mailpiece if space permits. Otherwise affix to back of mailpiece, 2, ff you do not want the receipt postmarked, stick the article # label to the right of the return address date receipt and retain the receipt. ' 3, ff you want this receipt postmarked, slip the 3800 receipt between the return receipt, and the mailpiece, and slide the edge of the receipt to Ihe gummed edge of adhesive. This will hold the receipt in place to present to your mailcenter, or post office service window. (SEE ILLUSTRATION) 4. Enter fees for the services requested in the appropriate spaces Da the front of this receipt, 5. Save this receipt and present it if you make an inquiry. GOLDBECK I~IcCAFFERTY & McKEEVER BY: Joseph A. Goldbeck, Jr. Attorney I.D. #16132 Suite 500- The Bourse Bldg. 111 S. Independence Mall East Philadelphia, PA 19106 215-627-1322 Attorney for Plaintiff ASSOCIATES CDC A DIVISION OF CITIFINANCIAL SERVICES INC. ITS SUCCESSORS AND/OR ASSIGNS AS THEIR INTEREST MAY APPEAR 7467 New Ridge Road Suite 222 Hanover, MD 21076 VS, Plaintiff CRAIG A. BRUNGARD (Mortgagor(s) and Record owner(s)) 1015 Chippenham Road Mechanicsburg, PA 17050 IN THE COURT OF COMMON PLEAS of Cumberland County No. 02-1373 CIVIL TERM PRAECIPE TO DISCONTINUE AND END TO THE PROTHONOTARY: Kindly mark your costs only. the above GOLDB'mC , Z., case Discontinued and Ended upon payment of ESQUIRE Associates CDC, a Division of Citifinancial Services Inc., its successors And/or assigns as their interest may appear VS Craig A. Brungard In The Court of Common Pleas of Cumberland County, Pennsylvania Writ No. 2002-1373 Civil Term R. Thomas Kline, Sheriff, who being duly sworn according to law, states this writ is returned STAYED pursuant to instructions from Attorney Joseph Goldbeck, Jr. Sheriff's Costs: Docketing 30.00 Sumharge 30.00 Law Library .50 Prothonotary 1.00 Mileage 19.32 Levy 15.00 Advertising 15.00 Posting Handbills 15.00 Share of Bills 25.20 Poundage 224.33 Law Journal 618.80 Patriot News 462.55 Certified Mail 2.23 $1,458.93 paid by attorney 09/20/02 Sworn and subscribed to before me So Answers: This ,~ ~'day o~ ~'~,~,~¢~ f~ ~ R. Thomas Kline, Sheriff Prothonotary Real Estate Deputy Goldbeck McCafferty & McKeever BY: Joseph A. Goldbeck, Jr. Attorney I.D. #16132 Suite 500 The Bourse Bldg. 111 S. Independence Mall East Philadelphia, PA 19106 215-627-1322 Attorney for Plaintiff ASSOCIATES CDC A DIVISION OF CITIFINANCIAL SERVICES INC. ITS SUCCESSORS AND/OR ASSIGNS AS THEIR INTEREST MAY APPEAR 7467 New Ridge Road Suite 222 Hanover, MD 21076 Plaintiff VS. CRAIG A. BRUNGARD (Mortgagor(s) and Record Owner(s)) I 015 Chippenham Road Mechanicsburg, PA 17050 Defendant(s) IN THE COURT OF COMMON PLEAS of Cumberland County CIVIL ACTION - LAW ACTION OF MORTGAGE FORECLOSURE No. 02-1373 CIVIL TERM AFFIDAVIT PURSUANT TO RULE 3129 ASSOCIATES CDC A DIVISION OF CITIFINANCIAL SERVICES INC. ITS SUCCESSORS AND/OR ASSIGNS AS THEIR INTEREST MAY APPEAR, Plaintiff in the above action, by its attorney, Joseph A. Goldbeck, Jr., Esquire, sets forth as of the date the praecipe for the ~vrit of execution was filed the following information concerning the real property located at: 1015 Chipper~ham Road Mechanicsburg, PA 17050 1.Name and address of Owner(s) or Reputed Owner(s): CRAIG A. BRUNGARD 1015 Chippenham Road Mechanicsburg, PA 17050 2. Name and address of Defendant(s) in the judgment: CRAIG A. BRUNGARD 1015 Chippenham Road Mechanicsburg, PA 17050 3. Name and last ka~own address of every judgment creditor whose judgment is a record lien on the property to be sold: PA DEPARTMENT OF PUBLIC WELFARE - Bureau of Child Support Enforcement Health and Welfare Bldg. - Room 432 P.O. Box 2675 Harrisburg, PA 17105-2675 DOMESTIC RELATIONS OF CUMBERLAND COUNTY PO Box 320 Carlisle, PA 17013 FEDERAL NATIONAL MORTGAGE ASSOCIATION. PO Box 1169 Milwaukee, WI 53201-0800 ASSOCIATES FINANCIAL SERVICES ]q~? ~tew Ridge Road Hanover, MD 21076 4. Name and address of the last recorded holder of every mortgage of record: FEDERAL NATIONAL MORTGAGE ASSOCIATION 510 Walnut Street Philadelphia, PA 19106 5. Name and address of every other person who has any record interest in or record lien on the property and whose interest may be affected by the sale: 6. Name and address of every other person of whom the plaintiffhas knowledge who has any record interest in the property which may be affected by the sale. 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. PAMAY DEVELOPMENT CO INC 5140 East Trindle Road Mechanicsburg, PA 17055 (attach separate sheet if more space is needed) I verify that the statements made in this affidavit are true and correct to the best of my personal knowledge or information and beliefi I understand that false statements herein are made subject to the relating to unsworn falsification to authorities. ~OL12 BY: Jo,~ Att°n~i DATED: ~May 29, 2002 >enalties of 18 Pa. C.S. Section 4904 I'y & McKEEVER Ir., Esq. 06/08/2002 TlR[ 13:12 FAX ~OlO/Olg GOLDBECK McCAFFERTY & McKEEVER BY: lo~cph A. Goldbcck, Ir. Attnmey I.D.'~J 61 ~2 Suite 500 -- '1 he Uool~e Uldg.' 111 S. ~depend~e Mall East Philnddph[a, PA 1910G 215-627-[322 A~om~ for Plah~ ASSOCIATES CDC A DIVISION OF CITIFINANCIAL S 'I/RVICES INC. ITS SUCCESSORS AND/OR ASSIGNS AS THEIR INTEREST MAY APPEAR 7467 New Ridge Road SQite 222 Hanover, MD 21076 Plaintiff CKAIG A. F~RUNGARD Mortgagor(~) and Record Owllar(s) 10 t 5 Chippenham Road ' Mcchan/csburg, PA 17050 Defandam(s) IN ~ COURT OF COMMON PLEAS of Cumberland County CI'VIL ACI1ON - LAW ACTION OF MORTGAGE FORBCLOSUF,.E Term No. 02-I373 CIVIL TI~RM '1'111~ LAW FIRM IS A DEBT COLLECTOR AND WE ARE ATT~MPTIING TO COLLECT A DEBT. Ti-IlS NOTICE IS SENT TO YOU IN AN ATTEM. PT TO COLLECT A DEBT, ANY LNFORMATION OBTAINED FROM YOU WILL BE USED FOR TIIAI' PUP. POSE. NOTICE OF SIIEKIFF'S SALE OF REAL I~ROPERTY CRAIG A. BRUNGARD l 0 ] 5 Ckippcnham Road Mechanicaburg PA 17050 ¥Otlf IlOtlSe al 1015' ~ippcnham Road, Mech~csburg, PA 17050 is scheduled to be sold at ShedlTs Sale un We~asday, S~mb~r 04, 2002, at 10:00 AM, in Commia~ione~ Ilea~g Rm 2nd ~ Courthousc tn enforce the cou~j~dgm~t of $86,267.66 ebbed by ASSOCiATeS ~C A D~SION OF CITIF~ANC~L SERVICES iNC. ITS SUC~SS0~ AND/OK ASSIGNS AS ~ ~ST MAY APPEAR agaim( you. NOTICE OF OWNER'S RICIZT,~ YOU iVL~y BE ABLE TO PREVI~NT Tills SHERIFF'S SALE To prevellt this SherilTs Sale you must take imm~fliate a¢~ioIl: 1. The ~ale w/Ii be cancelled if you pay to ASSOCIATI~S CDC A DWISION OF CITiFLN'ANCIAL SgliVICE S INC. ITS SUCCESSORS AND/OR ASSIGNS AS THEIR INTEREST MAY APPEAR, the back payments, late charges, co$ls and r~a~on~blc allomcy's f'e~s du~. To filld ott[ how much you must pay call: 215-627-1322 06/06/2002 THU 13:12 2. You may be able to stop thc sale bv filing a pefit~oo askinR the Court to ~USk¢ or oPen jud~cnt 3. You may aho be able ~o szop zhe sole fl~ough o~ kgal ~i11 have of ~topping thc aalc. [Sce notice below on how to obtain an a~m~). ' YOU MAY STILL BE~BLg TO SAW YOI~ PROPERTY ~D YOU ~ OTI~R ], Il l ile Sheriffs Sale is not stopped, yo~ll' plUpel~ will be sold to time hi.est biddy. You may find nut thc. pricc bid pHec by calling the Sheriffaf 71%240-~3P0. 2, You may bc able to p~ition the Caul [[o ~c[ a~ide ~e su]c if the bid price was g~ssly inadequa~ zumpa~'d to thc value nf your pfopelW. 3. The sale will go U~uttgh only if file buyer pays ~h~ Sheriff ~u full amount du~ iii ~ sale, To Fed our if lllis/la~ fla~eucd, you may call the Sh~r{ffof 717-240.6390, 4. If lhe ~lllOOfi[ due ~m thc Buyer is not paid to file Sh~rifl~ you wiU remain tho owner of PCOpe~'W ~s if file sale never happened. 5. You have a right to ~lllfl~ hi The propmy until fl~e ~11 amount due ~ paid to thc ~heriff and ghe~ff giv:s o deed to The btly~. At ~t time, file ]~yer may br~g legal p~uccdings to evict you. 6. Yo11 may be e~ttillud to a share of the lUOlley which was paid for your house. A schedule of dlSlrlbutiun el' Ihe money hid f~r your house will be Cried by 5~c SMriffgfil~ (30) days from ~e dam of the Sheriffs Sale. 'l~is schedule will s~te who wffi be routing ~at mooey, ~lm money ~11 bm paid out id ,crurdancc with this schedule unless ~x~llona (~asom why th~ proposed disl~buti~ h ~ong)'are with the Sheriff within r~{l (i0) days aacr ibc srh~dulm of dish'iburion is 7. Yoo may also have oflmcr ~gh~ alld deletes, or ways of getting your kouse hack if~u a~ immediately after the sale, YOU SHOt II.D TAKE THIS P.~'ER TO YOIIR LAW~'ER AT ONCE. 1F YOU DO NOT HAVE A I.AW'Y'ER OR CANNOT AFFORD ONE, GO TO OR T. fiLI/FIION.[/THE OFFICE LISTED BELOW TO I"IND tOLl r wi IEKff YOU CAN GET LEGAL IIELP. CUMBERLAND COUNTy BAR ASSOCIATION 2 Libcrty Avenue Carlisle, PA 17013 L~OAL SERVICES INC i lrvine Row Carlisle, PA { 7013 AEL THAT CERTAIN'lot of land situate in Hampden Township, Cumberland County, Penn,ylvania, being Lot ~212, Kingswood, Phase particula~ly bounded and described as follows, to wit: BEGIN~IN~ at a point on the West side of Chtppenham Road, · said point sl~o being a d/stance Of One Hundred Twenty-Five feet North (125.00'} of the intersection of the North side of Dorset Drive and the West side of Cbtppenhsm Road; thence by the line of Lot NO. 198 South Eighty-Two degrees Fifty-Three minutes Twenty-Two seconds West (S 82"53~22'' W) a distance of one Hundred Twelve and One One-Hundredths feet (112.01') tn a point et line of Lot No. 199; thence by same North Twenty-Eight degrees Fifty-One minutes Thirty-Five seconds West (N 28"51'35" W) a d/stance of Ninety-Five and Thirty-Four One-Hundredths feet (95.34') to a point at line of Lot No. 211; thence by same North Slx~y-~ix,degrees Twenty-Eight minutes Thirty-One seconds East (N 66 28 31 E) ~ distance of One HUndred Forty-Two and Ninety-Seven One-Hundredths feet (142.97 to the right having e radius Of Two Hundred Fifty feet (2~0.O0f) an - ' are length of Seventy-One and Fifty-Eight One-Hundredths feet teen seconds East (S' 07°07'15 ~ Thirty-Five One-Hundredths feet (88.35~} to the place of Beginning, CONTAININ~ 14,246.40 square feet, and being known and numbered am 1015 Ch/ppenb. am Road, Mechenlcsburg, Penneylv~la. ~ND~ ~]~L~E~'~, I~g~k~u~LESS, to Declaration of Covenants, Easements, Restrictions, E~uitabie Servitudes, Charges and Liens dated November 9, 1988 and recorded November 10, 1988 in C~mberland County Miscellaneous Book ~56, Page 1095. UNDER ~ SUBJECT, Also, to all easements and restrictions of record and as set forth on t~he recorded plan described above. U~E~ ~ ~3~JEC-~, Al~o, to an easement five feet width on the inside of the front property ~tna for an underground stone trench to carry drainage waters alongside and under Chippenham Road from the lot line between lots 222 and 223. Lot No. 220 and Lot No. 221 as shown on said plan has been eliminated in favor Of a 10 foot (10') bike path easement to Hampden Township centered on the lot line between Lot Ne. 220 and Lot No. 221. THE Recreation Area ohown on the Final Plan of Ktngswood, Phase II, as recorded in Cumberland County Plan Book 55, Fags 93, will be eliminated and developed as building lots. BEING a part of the same premises which SOUTH CENTRAL SERVICE CO~., et. al., by their deed dated May 26, 1988, and recorded May 27, 1988 in the Cumberland County Deed Book 33-J, Fags 17 granted and AND The said Grantor Will Specially WARRANT AND FOREVER DEFEND the property hereby conveyed. IN WI~$S WHE~EOF, the Grantor has caused this Deed to be signed, by its President or a Vice President, end also by its TAX PARCEL #10-16-1056-162 SUB]ECT TO MORTGAGE WRIT OF EXECUTION. a~d/or ATTACHMENT COMMONWEALTH OF PENNSYLVANIA) NO 02-1373 Civil COUNTY OF CUMBERLAND) CIVIL ACTION - LAW TO THE SHERIFF OF Cumberland COUNTY: To satisfy the debt, interest and costs due ASSOCIATES CDC, A DIV. OF CITIFINANCIAL SERVICES 1NC., ITS SUCCESSORS AND/OR ASSIGNS AS THEIR INTEREST MAY APPEAR PLANTIFF(S) From CRAIG A. BRUNGARD, 1015 CHIPPENHAM RD., MECHANICSBURG PA 17050. (1) You are directed to levy upon the property of the defendant(s) and to sell REAL ESTATE LOCATED AT 1015 CHIPPENHAM ROAD, MECHANICSBURG PA 17050 (SEE ATTACHED LEGAL DESCRIPTION.) (2) Y°u are als° directed to attach the property of the defendant(s) not levied upon in the possession o£ GARNISHEE(S) as follows: and to notify the garnishee(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 defendant (s) and from delivering any property of the defendant (s) or otherwise disposing thereof; (3) Ifpr°perty °f 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 $86,267.66 Interest 9/1/01 - 5/29/02 ~ 12.9700% Atty's Comm % Arty Paid $109.66 Plaintiff Paid L.L. $.50 Due Prothy $1.00 Other Costs Date: MAY 31, 2002 REQUESTING PARTY: Name JOSEPEH A. GOLDBECK, JR., ESQUIRE Address: STE 500 - THE BOURSE BLDG. 111 S. INDEPENDENCE MALL EAST PHILADELPHIA PA 19106 Attorney for: PLAINTIFF Telephone: (215) 627-1322 Supreme Court ID No. 16132 CURTIS R. LONG Prothonotary, Civil Division Real Estate Sale # 40 On June 7, 2002 the sherifflevied upon the defendant's interest in the real property situated in Hampden Township, Cumberland County, PA known and numbered as 1015 Chippenham Road, Mechanicsburg, more fully described on Exhibit "A" filed with this writ and by this reference incorporated herein. Date: June 7, 2002 By: '~Joo~ ~'~1 Real Estate Deputy 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 JournaI, 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 OH the following dates, viz: JULY 26, AUGUST 2, 9, 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. ~ F~TAT~ ~ NO. 40 Writ No. 2002-1373 Civil Associates CDC a Di~sion of Cltiflrmncial Services Inc. its successors and/or assigns as their interest may appear VS. Crmg ~ Brurtgard Atty.: Joseph Goldbeck. Jr. ALL THAT CERTAIN lot of land situate in Hampden Township, Cum- beriand County. Pennsylvania. be- ing Lot #212 Kingswood, Phase II., as recorded in Cumberland County plan Hook 55, Page 93, more par- ticularly bounded and described as follows, to wit: BEGINNING at a point on the West side of Chippenham Road. said point also being a distance of One Hundred T~renty-Five feet North (125.00'1 of the intersection of the Nnr~h side of Dorset Drive and the ~ditor SWORN TO AND SUBSCRIBED before me this 9 .day of AUGUST, 2002 I ~ll~o,_l_l_l_l_l_l_l_l_l~. ~'-~'~'z , having a radius of Two Hundred Fifty feet 1250.00') an a~c length of Seventy-One and Fifty-Eight One- Hundredths feet [71.58') to a point; thence by same South Seven de- grees Seven minutes Fifteen sec- onds East (S 07° 07 15" E) a dis- tance of Fifty-Eight and Thirty-Five One-Hundredths feet (58.35') to the place of Beginning. CONTAINING 14,246.40 square feet, and being known and hum bered as 1015 Chippenham Road, Mechaniesburg. Pennsylvania. UNDER AND SUBJECT, NEVER- THELESS, to Declaration of Cov- enants. Easements, Restrictions, Equitable Servitudes, Charges and Liens dated November 9. 1988 and recorded November 10, 1988 in Cumberland County Miscellaneous Book 356, Page 1095. UNDER AND SUBJECT, Also. to ail easements and restrictions of record and as set forth on the re corded plan described above. UNDER AND SUBJECT, Also, to an easement five feet (5') in width on the inside of the front property line for an underground stone trench to carry drainage waters alongside and under Chippenham Road from the lot line between lots 222 and 223. THE access easement for the Homeowner's Association between Lot No. 220 and Lot No. 221 as shown on said plan ha~ been elimi- nated in favor of a 10 foot (10') bike path easement to Hampden Town- ship centered on the lot line between Lot No. 220 and Lot No. 22i. THE Recreation Area shown on the Final Plan of Klngsweod, Phase II, as recorded in Cumberland Coun- ty Plan Book 55, Page 93, will be eliminated and developed a~ build- lng lots. BEING a part of the same prem- ises which SOUTH CENTRAL SERV- ICE CORP., et. al., by their deed dated May 26, 1988, and recorded May 27, 1988 in the Cumberland County Deed Book 33~J, Page 17 granted and conveyed unto PAMAY DEVELOPMENT CO., INC., Grantor herein. AND The said Grantor Will Spe- cially WARRANT AND FOREVER DE- FEND the property hereby conveyed. IN WITNESS WHEREOF, the Grantor has caused this Deed to be signed by its President or a Vice President, and also by its Secretary. or by an A~sistant Secretary, or by its Treasurer, or by an Assistant Treasurer, and its Corporate Seal to be hereunto aflLxed, the day and yea~ first above written. IMPROVEMENTS consist of a res- idential dwelling. BEING PREMISES: 1015 Chip~ penham Road. Mechanicsburg. PA 17050. SOLD as the property of CRAIG A. BRUNGARD, TAX PARCEL #10-16-1056-162. SUBJECT TO MORTGAGE. THE PATRIOT NEWS THE SUNDAY PATRIOT NEWS Proof of Publication Under Ad: No. 587, Approved May 16, 1929 Commonwealth of Pennsylvania, County of Dauphin} ss Frank J. Epler being duly sworn according to law, deposes and says: That he is the 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 Th~ n tri t-N 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 23rd and 30th day(s) of July and the 6th day(s) of August 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 office for the Recording of Deeds in and for said County of Dauphin in Miscellaneous Book "M", Vel,me 14, Page 317. PUB, c^, o. ................................. ...... .......... COPY Sworn to and subscribed before ~ 14th day ~g~002 A.D. C~ ~ ~sbu~, ~' ~ ' ~ ~ ~ ~mi~on ~r~ U~e 6, ~ [ NO~RY'PUBLIC ~m~r, PennsCvania~n~N~s My commission expires June 6, 2006 CUMBERLAND COUNTY SHERIFFS OFFICE CUMBERLAND COUNTY COURTHOUSE CARLISLE, PA. 17013 Statement of Advertising Costs To THE PATRIOT-NEWS CO., Dr. For publishing the notice or publication attached hereto on the above stated dates Probating same Notary Fee(s) Total $ 460.80 $ 1.75 $ 462.55 Publisher's Receipt for Advertising Cost The Patriot News Co., publisher of The Patriot-News and ~ Patr~, newspapers of general circulation, hereby acknowledge receipt of the aforesaid notice and publication costs and certifies that the same have been duly paid.