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HomeMy WebLinkAbout02-1415FEDERMAN AND PHELAN, LLP By: FRANK FEDERMAN, ESQ., Id. No. 12248 LAWRENCE T. PHELAN, ESQ., Id. No. 32227 FRANCIS S. HALLINAN, ESQ., Id. No. 62695 ONE PENN CENTER PLAZA, SUITE 1400 PHILADELPHIA, PA 19103 15) 561-7000 S CENDANT MORTGAGE CORPORATION F/K/A PHH MORTGAGE SERVICES CORPORATION 6000 ATRIUM WAY MOUNT LAUREL, NJ 08054 TERM ATTORNEY FOR PLAINTIFF COURT OF COMMON PLEAS CIVIL DIVISION Plaintiff V. NO. U o L - / y INT CUMBERLAND COUNTY DONALD L. SEVERS ANGELA L. SEVERS 302 WIDDERS DRIVE MECHANICSBURG, PA 17055 Defendant(s) **THIS FIRM IS A DEBT COLLECTOR ATTEMPTING TO COLLECT A DEBT AND ANY INFORMATION OBTAINED WILL BE USED FOR THAT PURPOSE. IF YOU HAVE PREVIOUSLY RECEIVED A DISCHARGE IN BANKRUPTCY AND THIS DEBT WAS NOT REAFFIRMED, THIS CORRESPONDENCE IS NOT AND SHOULD NOT BE CONSTRUED TO BE AN ATTEMPT TO COLLECT A DEBT, BUT ONLY ENFORCEMENT OF A LIEN AGAINST PROPERTY. ** You have been sued in Court. If you wish to defend against the claims set forth in the following pages, you must take action within twenty (20) days after this Complaint and Notice are served, by entering a written appearance personally or by attorney and filing in writing with the court your defenses or objections to the claims set forth against you. You are warned that if you fail to do so the case may proceed without you and a judgment may be entered against you by the court without further notice for any money claimed in the Complaint or for any other claim or relief requested by the Plaintiff. You may lose money or property or other rights important to you. YOU SHOULD TAKE THIS PAPER TO YOUR LAWYER AT ONCE. IF YOU DO NOT HAVE A LAWYER OR CANNOT AFFORD ONE, GO TO OR TELEPHONE THE OFFICE SET FORTH BELOW TO FIND OUT WHERE YOU CAN GET LEGAL HELP. CUMBERLAND COUNTY CUMBERLAND COUNTY BAR ASSOCIATION 2 LIBERTY AVENUE CARLISLE, PA 17013 (717) 249-3166 Loan #:0002075943 IF THIS IS THE FIRST NOTICE THAT YOU HAVE RECEIVED FROM THIS OFFICE, BE ADVISED THAT: PURSUANT TO THE FAIR DEBT COLLECTION PRACTICES ACT, 15 U.S.C. § 1692 et seq. (1977), DEFENDANT(S) MAY DISPUTE THE VALIDITY OF THE DEBT OR ANY PORTION THEREOF. IF DEFENDANT(S) DO SO IN WRITING WITHIN THIRTY (30) DAYS OF RECEIPT OF THIS PLEADING, COUNSEL FOR PLAINTIFF WILL OBTAIN AND PROVIDE DEFENDANT(S) WITH WRITTEN VERIFICATION THEREOF; OTHERWISE, THE DEBT WILL BE ASSUMED TO BE VALID. LIKEWISE, IF REQUESTED WITHIN THIRTY (30) DAYS OF RECEIPT OF THIS PLEADING, COUNSEL FOR PLAINTIFF WILL SEND DEFENDANT(S) THE NAME AND ADDRESS OF THE ORIGINAL CREDITOR, IF DIFFERENT FROM ABOVE. THE LAW DOES NOT REQUIRE US TO WAIT UNTIL THE END OF THE THIRTY (30) DAY PERIOD FOLLOWING FIRST CONTACT WITH YOU BEFORE SUING YOU TO COLLECT THIS DEBT. EVEN THOUGH THE LAW PROVIDES THAT YOUR ANSWER TO THIS COMPLAINT IS TO BE FILED IN THIS ACTION WITHIN TWENTY (20) DAYS, YOU MAY OBTAIN AN EXTENSION OF THAT TIME. FURTHERMORE, NO REQUEST WILL BE MADE TO THE COURT FOR A JUDGMENT UNTIL THE EXPIRATION OF THIRTY (30) DAYS AFTER YOU HAVE RECEIVED THIS COMPLAINT. HOWEVER, IF YOU REQUEST PROOF OF THE DEBT OR THE NAME AND ADDRESS OF THE ORIGINAL CREDITOR WITHIN THE THIRTY (30) DAY PERIOD THAT BEGINS UPON YOUR RECEIPT OF THIS COMPLAINT, THE LAW REQUIRES US TO CEASE OUR EFFORTS (THROUGH LITIGATION OR OTHERWISE) TO COLLECT THE DEBT UNTIL WE MAIL THE REQUESTED INFORMATION TO YOU. YOU SHOULD CONSULT AN ATTORNEY FOR ADVICE CONCERNING YOUR RIGHTS AND OBLIGATIONS IN THIS SUIT. Plaintiff is CENDANT MORTGAGE CORPORATION F/K/A PHH MORTGAGE SERVICES CORPORATION 6000 ATRIUM WAY MOUNT LAUREL, NJ 08054 2. The name(s) and last known address(es) of the Defendant(s) are: DONALD L. SEVERS ANGELA L. SEVERS 302 WIDDERS DRIVE MECHANICSBURG, PA 17055 who is/are the mortgagor(s) and real owner(s) of the property hereinafter described. On 3/1/99 mortgagor(s) made, executed and delivered a mortgage upon the premises hereinafter described to PLAINTIFF which mortgage is recorded in the Office of the Recorder of CUMBERLAND County, in Mortgage Book No. 1524, Page 675. 4. The premises subject to said mortgage is described as attached. 5. The mortgage is in default because monthly payments of principal and interest upon said mortgage due 12/1/01 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 $117,930.47 Interest 2,751.60 11/l/01 through 3/1/02 (Per Diem $22.93) Attorney's Fees 1,250.00 Cumulative Late Charges 464.48 3/1/99 to 3/1/02 Cost of Suit and Title Search 550-00 Subtotal $122,946.55 Escrow Credit 714.84 Deficit (Lo Subtotal (%71484) TOTAL $122,231.71 7. The attorney's fees set forth above are in conformity with the Mortgage documents and Pennsylvania Law, and will be collected in the event of a third party purchaser at Sheriffs Sale. If the Mortgage is reinstated prior to the Sale, reasonable attorney's fees will be charged. 8. This action does not come under Act 6 of 1974 because the original mortgage amount exceeds $50,000.00. WHEREFORE, PLAINTIFF demands an in rem Judgment against the Defendant(s) in the sum of $122,231.71, together with interest from 3/1/02 at the rate of $22.93 per diem to the date of Judgment, and other costs and charges collectible under the mortgage and for the foreclosure and sale of the mortgaged property. FEDERMAN ASUM= By. FRANK FEDERMAN, ESQUIRE LAWRENCE T. PHELAN, ESQUIRE FRANCIS S. HALLINAN, ESQUIRE Attorneys for Plaintiff ALL THAT CERTAIN tract of land situate in Monroe Township, d C t Pennsylvania, being more particularly bounded Cumberlan onn y, and described as follows, to wit: BEGINNING at a point on the northern side of Widdera Drive a fifty (5o) foot wide street; thence along Lot No. 71, North twenty-six (26) degrees ten (10) minutes forty (40) seconds West one hundred forty (140) feet to a point at Lot No. 72; thence along Lot No. 72 and Lot No. 74, North sixty-three (63) degrees forty-five (45) minutes twenty (20) seconds East, on hundred twenty (120) feet to a point at Lot No. 69; thence along Lot No. 69 South twenty-six (26) degrees ten (10) minutes forty (40) seconds East one hundred forty (140) feet to a point on the northern wide of Widdera Drive; thence along the Northern side of Widdera Drive, south sixty-three (63) drees hundred twenty r (120) n feet) to minutes t Point, nt he 2 point and place oof BEGINNING. MING Lot No. 70 of Monroe Acres as shown on Section C, in accordance with a survey by Larsen & Brilhart, Inc., Registered Surveyor, dated March 10, 1972, and recorded in Plan Book 22, Page 98. HAVING thereon erected a brick and aluminum bi-level dwelling known and numbered as 302 Widdera Drive. IT BEING the same premises which Benjamin L. Breneman, single man, and R.L. Sheibley and Edith H. Sheibley, husband and wife, by dated August 24, 1972 and recorded in the Office of the Recorder of Deeds in and for Cumberland County, Pennsylvania, in Deed Book T- unto Donald J. 969* granted and herein.or?er and 24, Pae husband con-?eyed Rosean VERIFICATION MARC J. HMKLE hereby states that he is V.P. of CENDANT MORTGAGE SERVICES mortgage servicing agent for Plaintiff in this matter, that he is authorized to take this Verification, and that the statements trade in the foregoing Civil Action in Mortgage Foreclosure are true and correct to the best of his knowledge, information and belief. The undersigned understands that this statement is made subject to the penalties of 18 Pa. C.S. Sec. 4904 relating to unworn falsification to authorities. DATE: / q / / 63 c w ?i ? CASE NO: 2002-01415 P SHERIFF'S RETURN - REGULAR COMMONWEALTH OF PENNSYLVANIA: COUNTY OF CUMBERLAND CENDANT MORTGAGE CORPORATION VS SEVERS DONALD L ET AL ROBERT BITNER , Sheriff or Deputy Sheriff of Cumberland County,Pennsylvania, who being duly sworn according to law, says, the within COMPLAINT - MORT FORE , was served upon SEVERS ANGELA L the DEFENDANT , at 0945:00 HOURS, on the 27th day of March , 2002 at 1123 RAMAVILLA CAMP HILL, PA 17011 by handing to ANGELA SEVERS 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 6.00 Service 9.66 Affidavit .00 Surcharge 10.00 nn So Answers: leoo?- R. Thomas Kline 03/28/2002 FEDERMAN & PHELAN Sworn and Subscribed to before me this jel day of Qa.,O atN?2 A.D. Prothonotary B Deputy Sheriff CASE NO: 2002-01415 P SHERIFF'S RETURN - REGULAR COMMONWEALTH OF PENNSYLVANIA: COUNTY OF CUMBERLAND CENDANT MORTGAGE CORPORATI VS SEVERS DONALD L ET AL HAROLD WEARY , Sheriff or Deputy Sheriff of Cumberland County,Pennsylvania, who being duly sworn according to law, says, the within COMPLAINT - MORT FORE was served upon SEVERS DONALD L the DEFENDANT at 1330:00 HOURS, on the 26th day of March , 2002 at 302 WIDDERS DRIVE MECHANICSBURG, PA 17055 MnrTTT.n QV1TL'DC by handing to a true and attested copy of COMPLAINT - MORT FORE together with and at the same time directing His attention to the contents thereof. Sheriff's Costs: Docketing 18.00 Service 6.90 Affidavit .00 Surcharge 10.00 .00 34.90 Sworn and Subscribed to before me this /0" day of q.... -o e?Utl.L A.D. P othonotary So Answers: R. Thomas Kline !! 03/28/2002 FEDERMAN & PHELAN By: , V ?S , Deputy S iff FEDERMAN AND PHELAN, LLP 'by: FRANK FEDERMAN Identification No. 12248 Attorney for Plaintiff ONE PENN CENTER AT SUBURBAN STATION 1617 JOHN F. KENNEDY BLVD., SUITE 1400 PHILADELPHIA, PA 19103-1814 (215) 563-7000 CENDANT MORTGAGE CORPORATION, F/K/A . PHH MORTGAGE SERVICES CORPORATION CUMBERLAND COUNTY 6000 ATRIUM WAY COURT OF COMMON PLEAS MOUNT LAUREL, NJ 08054 Plaintiff, V. DONALD L. SEVERS ANGELA L. SEVERS Defendant(s). CIVIL DIVISION NO. 02-1415-CIVIL PRAECIPE FOR JUDGMENT FOR FAILURE TO ANSWER AND ASSESSMENT OF DAMAGES TO THE PROTHONOTARY: Kindly enter judgment in favor of the Plaintiff and against DONALD L. SEVERS and ANGELA L. SEVERS, Defendant(s) for failure to file an Answer to Plaintiffs Complaint within 20 days from service thereof and for Foreclosure and Sale of the mortgaged premises, and assess Plaintiffs damages as follows: As set forth in Complaint $122,231.71 Interest from 3/2/02 to 4/30/02 $1,375.80 TOTAL $123,607.51 I hereby certify that (1) the addresses of the Plaintiff and Defendant(s) are as shown above, and (2) that notice has been given in accordance with Rule 237. 1, copy attached. FE RMAN, ESQUIIZE Attorney for P aintiff DAMAGES ARE HEREBY ASSESSED AS INDICA DATE: ?f? 30 D? MA-? ,,q PRO PROTHY 44 FEDERMAN AND PBELAN BY: FRANK FEDERMAN, ESQUIRE Identification No. 12248 1617 John F. Kennedy Boulevard Suite 1400 Philadelphia, PA 19103-1814 aM) 561-7000 CENDANT MORTGAGE CORPORATION F/K/A PHH MORTGAGE SERVICES CORPORATION Plaintiff VS. DONALD L. SEVERS ANGELA L. SEVERS Attorney for Plaintiff : COURT OF COMMON PLEAS : CIVIL DIVISION : CUMBERLAND COUNTY : NO. 02-1415-CIVIL Defendant(s) TO: DONALD L. SEVERS 302 WIDDER DRIVE MECHANICSBURG, PA 17055 DATE OF NOTICE: APRIL 17. 2002 copy THIS FIRM IS A DEBT COLLECTOR ATTEMPTING TO COLLECT A DEBT. THIS NOTICE IS SENT TO YOU IN AN ATTEMPT TO COLLECT THE INDEBTEDNESS REFERRED TO HEREIN, AND ANY INFORMATION OBTAINED FROM YOU WILL BE USED FOR THAT PURPOSE.IF YOU HAVE PREVIOUSLY RECEIVED A DISCHARGE IN BANKRUPTCY, THIS CORRESPONDENCE IS NOT AND SHOULD NOT BE CONSTRUED TO BE AN ATTEMPT TO COLLECT A DEBT, BUT ONLY AS ENFORCEMENT OF LIEN AGAINST PROPERTY. IMPOR zw ? You are in default because you have failed 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 CUMBERLAND COUNTY BAR ASSOCIATION 2 LIBERTY AVENUE CARLISLE, PA 17013 (717) 249-3166 v `inc Frank Federman, Esquirl? Attorney for Plaintiff DERMAN AND PHELAN BY: FRANK FEDERMAN, ESQUIRE Identification No. 12248 1517 John F. Kennedy Boulevard Suite 1400 Philadelphia, PA 19103-1814 (21_5)561-7000 v CEDANT MORTGAGE CORPORATION F/K/A PHH MORTGAGE SERVICES CORPORATION Plaintiff VS. DONALD L. SEVERS ANGELA L. SEVERS Defendant TO: ANGELA L. SEVERS 1123 RAMAVILLA CAMPHILL, PA 17011 DATE OF NOTICE: APRIL 17. 2002 Attorney for Plaintiff : COURT OF COMMON PLEAS : CIVIL DIVISION : CUMBERLAND COUNTY : NO. 02-1415-CIVIL C0 1 `49t THIS FIRM IS A DEBT COLLECTOR ATTEMPTING TO COLLECT A DEBT. THIS NOTICE IS SENT TO YOU IN AN ATTEMPT TO COLLECT THE INDEBTEDNESS REFERRED TO HEREIN, AND ANY INFORMATION OBTAINED FROM YOU WILL BE USED FOR THAT PURPOSE.IF YOU HAVE PREVIOUSLY RECEIVED A DISCHARGE IN BANKRUPTCY, THIS CORRESPONDENCE IS NOT AND SHOULD NOT BE CONSTRUED TO BE AN ATTEMPT TO COLLECT A DEBT, BUT ONLY AS ENFORCEMENT OF LIEN AGAINST PROPERTY. IMPORTANT NOTICE You are in default because you have failed 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 CUMBERLAND COUNTY BAR ASSOCIATION 2 LIBERTY AVENUE CARLISLE, PA 17013 (717) 249-3166 r -/ [v tuvvlr.. Frank Federman, Esquire Attorney for Plaintiff .FEDERMAN and PHELAN, LLP By: FRANK FEDERMAN Identification No. 12248 ATTORNEY FOR PLAINTIFF ONE PENN CENTER AT SUBURBAN STATION 1617 JOHN F. KENNEDY BLVD., SUITE 1400 PHILADELPHIA, PA 19103-1814 (215) 563-7000 CENDANT MORTGAGE CORPORATION, F/K/A . PHH MORTGAGE SERVICES CORPORATION CUMBERLAND COUNTY 6000 ATRIUM WAY COURT OF COMMON PLEAS Plaintiff, v. DONALD L. SEVERS ANGELA L. SEVERS Defendant(s). CIVIL DIVISION NO. 02-1415-CIVIL VERIFICATION OF NON-MILITARY SERVICE FRANK FEDERMAN, ESQUIRE, hereby verifies that he is attorney for the Plaintiff in the above-captioned matter, and that on information and belief, he has knowledge of the following facts, to wit: (a) that the defendant(s) is/are not in the Military or Naval Service of the United States or its Allies, or otherwise within the provisions of the Soldiers' and Sailors' Civil Relief Act of Congress of 1940, as amended. (b) that defendant DONALD L. SEVERS is over 18 years of age and resides at, 302 WIDDERS DRIVE, MECHANICSBURG, PA 17055. (c) that defendant ANGELA L. SEVERS is over 18 years of age, and resides at, 1123 RAMAVILLA, CAMPHILL, PA 17011. This statement is made subject to the penalties of 18 Pa. C.S. Section 4904 relating to unsworn falsification to authorities. RANK FED RMAN, ESQUIRE Attorney for Plaintiff ' C 1LU r? W ?J V PRAECIPE FOR WRIT OF EXECUTION - (MORTGAGE FORECLOSURE) P.R.C.P.3180-3183 CENDANT MORTGAGE CORPORATION, F/K/A PHH MORTGAGE SERVICES CORPORATION Plaintiff, No. 02-1415-CIVIL V. DONALD L. SEVERS ANGELA L. SEVERS Defendant(s). TO THE DIRECTOR OF THE OFFICE OF THE PROTHONOTARY: Issue writ of execution in the above matter: Amount Due $123,607.51 Interest from 5/1/02 to 9/4/02 $2,580.64 and Costs (per diem -$20.32) TOTAL $126,188.15 iF'RANK FEDE AN, ESQUIRE One Penn Center at Suburban Station 1617 John F. Kennedy Boulevard, Suite 1400 Philadelphia, PA 19103-1814 Attorney for Plaintiff Note: Please attach description of property.No. cl? O.-K C05 ? b? c xn x o z oc n 0 a? ?x zo n x? ° zo z o rx ad ? p?? 00 n n ? ? o ?? b z n o a? ? ?o DESCRIPTION ALL THAT CERTAIN tract of land situate in Monroe Township, Cumberland County, Pennsylvania, being more particularly bounded and described as follows, to wit: BEGINNING at a point on the Northern side of Widders Drive a fifty (50) foot wide street; thence along Lot No. 71, North twenty-six (26) degrees ten (10) minutes forty (40) seconds West one hundred forty (140) feet to a point at Lot No. 72; thence along Lot No. 72 and Lot No. 74, North sixty-three (63) degrees forty-five (45) minutes twenty (20) seconds East, one hundred twenty (120) feet to a point at Lot No. 69; thence along Lot No. 69 South twenty-six (26) degrees ten (10) minutes forty (40) seconds East one hundred forty (140) feet to a point on the Northern side of Widders Drive; thence along the Northern side of Widders Drive, South sixty-three (63) degrees forty-nine (49) minutes twenty (20) seconds West, one hundred twenty (120) feet to a point, the point and place of beginning. BEING Lot No. 70 of Monroe Acres as shown on Section C, in accordance with a survey by Larsen & Brilhart, Inc., Registered Surveyor, dated March 10, 1972 and recorded in Plan Book 22, Page 98. HAVING thereon erected a brick and aluminum bi-level dwelling known and numbered as 302 Widders Drive. Tax Parcel #29-2463-056 TITLE TO SAID PREMISES IS VESTED IN Donald L. Severs and Angela L. Severs, husband and wife by Deed from Donald J. Bordner and Roseanna M. Bordner, husband and wife dated 3/1/1999, recorded 3/5/1999, in Deed Book 195, Page 421. e t_. cl? C c" I ca v FEDERMAN and PHELAN, LLP By: FRANK FEDERMAN Identification No. 12248 ONE PENN CENTER AT SUBURBAN STATION 1617 JOHN F. KENNEDY BLVD., SUITE 1400 PHILADELPHIA, PA 19103-1814 (215) 563-7000 CENDANT MORTGAGE CORPORATION, F/K/A PHH MORTGAGE SERVICES CORPORATION V. Plaintiff, DONALD L. SEVERS ANGELA L. SEVERS Defendant(s). ATTORNEY FOR PLAINTIFF CUMBERLAND COUNTY COURT OF COMMON PLEAS CIVIL DIVISION NO. 02-1415-CIVIL CERTIFICATION FRANK FEDERMAN, ESQUIRE, hereby verifies that he is attorney for the Plaintiff in the above-captioned matter, and that the premises are not subject to the provisions of Act 91 because it is: (X) an FHA mortgage ( ) non-owner occupied ( ) vacant () Act 91 procedures have been fulfilled This certification is made subject to the penalties of 18 Pa. C.S. Section 4904 relating to unsworn falsification to authorities. RANK FED AN, ESQUIRE Attorney for Plaintiff CENDANT MORTGAGE CORPORATION, F/K/A PHH MORTGAGE SERVICES CORPORATION Plaintiff, V. DONALD L. SEVERS ANGELA L. SEVERS Defendant(s). NO. 02-1415-CIVIL AFFIDAVIT PURSUANT TO RULE 3129 (Affidavit No. l) CORPORATION, Plaintiff in the above action, by its attorney, FRANK FEDERMAN, 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,302 WIDDERS DRIVE. MECHANICSURG PA 17055 1. Name and address of Owner(s) or reputed Owner(s): Name DONALD L. SEVERS ANGELA L. SEVERS Last Known Address (if address cannot be reasonably ascertained, please indicate) 302 WIDDERS DRIVE MECHANICSBURG, PA 17055 1123 RAMAVILLA CAMPHILL, PA 17011 2. Name and address of Defendant(s) in the judgment: Same as above 3. Name and last known address of every judgment creditor whose judgment is a record lien on the real property to be sold: Name Last Known Address (if address cannot be reasonably ascertained, please indicate) CUMBERLAND COUNTY COURT OF COMMON PLEAS CIVIL DIVISION None 4. Name and address of last recorded holder of every mortgage of record: Name Last Known Address (if address cannot be reasonably ascertained, please indicate) CITIFINANCIAL SERVICES INC. 6520 CARLISLE PIKE, SUITE 155 MECHANICSBURG, PA 17055 5. Name and address of every other person who has any record lien on the property: Name Last Known Address (if address cannot be reasonably ascertained, please indicate) None 6. Name and address of every other person who has any record interest in the property and whose interest may be affected by the sale. Name Last Known Address (if address cannot be reasonably ascertained, please indicate) MONROE ACRES CIVIC ASSOCIATION, 207 FAIRWAY DRVE INC. MECHANICSBURG, PA 17055 7. Name and address of every other person of whom the plaintiff has knowledge who has any interest in the property which may be affected by the sale: Name Last Known Address (if address cannot be reasonably ascertained, please indicate) Tenant/Occupant Domestic Relations of Cumberland County Commonwealth of Pennsylvania Department of Welfare 302 WIDDERS DRIVE MECHANICSURG, PA 17055 13 North Hanover Street Carlisle, PA 17013 PO Box 2675 Harrisburg, PA 17105 I verify that the statements made in this affidavit are true and correct to the best of my personal knowledge or information and belief. I understand that false statements herein are made subject to the penalties of 18 Pa. C.S. Sec. 4904 relating to unworn falsification to authorities. April 24, 2002 2r?10 a n/?n? nn DATE RANK FED RMAN, ESQUIRE Attorney for Plaintiff CENDANT MORTGAGE CORPORATION, F/K/A PHH MORTGAGE SERVICES CORPORATION Plaintiff, V. DONALD L. SEVERS ANGELA L. SEVERS Defendant(s). CUMBERLAND COUNTY No. 02-1415-CIVIL April 24, 2002 TO: DONALD L. SEVERS 302 WIDDERS DRIVE MECHANICSBURG, PA 17055 ANGELA L. SEVERS 1123 RAMAVILLA CAMPHILL, PA 17011 "THIS FIRM IS A DEBT COLLECTOR ATTEMPTING TO COLLECT A DEBT AND ANY INFORMATION OBTAINED WILL BE USED FOR THAT PURPOSE. IF YOU HAVE PREVIOUSLY RECEIVED A DISCHARGE IN BANKRUPTCYAND THIS DEBT WAS NOT REAFFIRMED, THIS IS NOT AND SHOULD NOT BE CONSTRUED TO BE ANA TTEMPT TO COLLECT A DEBT, BUT ONLY ENFORCEMENT OF A LIENAGAINST PROPERTY * * Your house (real estate) at, 302 WIDDERS DRIVE, MECHANICSURG PA 17055, is scheduled to be sold at the Sheriffs Sale on 9/4/02 at 10:00 a.m. in the Cumberland County Courthouse, South Hanover Street, Carlisle, PA 17013, to enforce the court judgment of $123,607.51 obtained by CENDANT MORTGAGE CORPORATION F/K/A PHH MORTGAGE SERVICES CORPORATION (the mortgagee) against you. In the event the sale is continued, an announcement will be made at said sale in compliance with Pa.R.C.P., Rule 3129.3. NOTICE OF OWNER'S RIGHTS YOU MAY BE ABLE TO PREVENT THIS SHERIFF'S SALE To prevent this Sheriffs Sale, you must take immediate action: The sale will be cancelled if you pay to the mortgagee the back payments, late charges, costs and reasonable attorney's fees due. To find out how much you must pay, you may call: (215) 563-7000. 2. You may be able to stop the sale by filing a petition asking the Court to strike or open the judgment, if the judgment was improperly entered. You may also ask the Court to postpone the sale for good cause. 3. You may also be able to stop the sale through other legal proceedings. You may need an attorney to assert your rights. The sooner you contact one, the more chance you will have of stopping the sale. (See notice on page two on how to obtain an attorney.) YOU MAY STILL BE ABLE TO SAVE YOUR PROPERTY AND YOU HAVE OTHER RIGHTS EVEN IF THE SHERIFF'S SALE DOES TAKE PLACE 1. If the Sheriffs Sale is not stopped, your property will be sold to the highest bidder. You may find out the price bid by calling (215) 563-7000. 2. You may be able to petition the Court to set aside the sale if the bid price was grossly inadequate compared to the value of your property. 3. The sale will go through only if the buyer pays the Sheriff the full amount due in the sale. To find out if this has happened, you may call (717) 240-6390. 4. If the amount due from the Buyer is not paid to the Sheriff, you will remain the owner of the property as if the sale never happened. 5. You have the right to remain in the property until the full amount due is paid to the Sheriff and the Sheriff gives a deed to the buyer. At that time, the buyer may bring legal proceedings to evict you. 6. You may be entitled to a share of the money which was paid for your house. A schedule of distribution of the money bid for your house will be filed by the Sheriff within 30 days of the sale. This schedule will state who will be receiving that money. The money will be paid out in accordance with this schedule unless exceptions (reasons why the proposed distribution is wrong) are filed with the Sheriff within ten (10) days after the distribution is filed. 7. You may also have other rights and defenses, or ways of getting your home back, if you act immediately after the sale. YOU SHOULD TAKE THIS PAPER TO YOUR LAWYER AT ONCE. IF YOU DO NOT HAVE A LAWYER OR CANNOT AFFORD ONE, GO TO OR TELEPHONE THE OFFICE LISTED BELOW TO FIND OUT WHERE YOU CAN GET LEGAL HELP. CUMBERLAND COUNTY ATTORNEY REFERRAL CUMBERLAND COUNTY BAR ASSOCIATION 2 LIBERTY AVENUE CUMBERLAND COUNTY COURTHOUSE CARLISLE, PA 17013 (717) 249-3166 (800) 990-9108 ALL THAT CERTAIN tract of land situate in Monroe Township, Cumberland County, Pennsylvania, being more particularly bounded and described as follows, to wit: BEGINNING at a point on the Northern side of Widders Drive a fifty (50) foot wide street; thence along Lot No. 71, North twenty-six (26) degrees ten (10) minutes forty (40) seconds West one hundred forty (140) feet to a point at Lot No. 72; thence along Lot No. 72 and Lot No. 74, North sixty-three (63) degrees forty-five (45) minutes twenty (20) seconds East, one hundred twenty (120) feet to a point at Lot No. 69; thence along Lot No. 69 South twenty-six (26) degrees ten (10) minutes forty (40) seconds East one hundred forty (140) feet to a point on the Northern side of Widders Drive; thence along the Northern side of Widders Drive, South sixty-three (63) degrees forty-nine (49) minutes twenty (20) seconds West, one hundred twenty (120) feet to a point, the point and place of beginning. BEING Lot No. 70 of Monroe Acres as shown on Section C, in accordance with a survey by Larsen & Brilhart, Inc., Registered Surveyor, dated March 10, 1972 and recorded in Plan Book 22, Page 98. HAVING thereon erected a brick and aluminum bi-level dwelling known and numbered as 302 Widders Drive. Tax Parcel #29-2463-056 TITLE TO SAID PREMISES IS VESTED IN Donald L. Severs and Angela L. Severs, husband and wife by Deed from Donald J. Bordner and Roseanna M. Bordner, husband and wife dated 3/1/1999, recorded 3/5/1999, in Deed Book 195, Page 421. WRIT OF EXECUTION and/or ATTACHMENT COMMONWEALTH OF PENNSYLVANIA) COUNTY OF CUMBERLAND) NO 02-1415 Civil CIVIL ACTION - LAW TO THE SHERIFF OF Cumberland COUNTY: To satisfy the debt, interest and costs due CENDANT MORTGAGE CORP f/k/a PHH MORTGAGE SSERVICES CORP. PLANTIFF(S) From DONALD L. SEVERS, 302 WIDDERS DR., MECHANICSBURG PA 17013 and ANGELA L. SEVERS, 1123 RAMAVILLA, CAMP HILL PA 17013. (1) You are directed to levy upon the property of the defendant(s) and to sell REAL ESTATE LOCATED AT 302 WIDDERS DR., MECHANICSBURG PA 17055. (SEE ATTACHED LEGAL DESCRIPTION.) (2) You are also directed to attach the property of the defendant(s) not levied upon in the possession of GARNISHEE(S) as follows: and to notify the garnishee(s) that: (a) an attachment has been issued; (b) the garnishee(s) is/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) If property of the defendant(s) not levied upon an subject to attachment is found in the possession of anyone other than a named garnishee, you are directed to notify him/her that he/she has been added as a gamishee and is enjoined as above stated. Amount Due $123,607.51 L.L. $.50 Interest 5/1/02 - 9/4/02 @ $20.32/diem $2,580.64 Due Prothy $1.00 Atty's Comm % Atty Paid $132.16 Other Costs Plaintiff Paid Date: APRIL 30, 2002 CURTIS R. LONG Prothonotary, Civil Division By: but REQUESTING PARTY: Name FRANK FEDERMAN, ESQ. Address: ONE PENN CENTER @ SUBURBAN STATION 1617 JFK BLVD., SUITE 1400 PHILADELPHIA PA 19103-1814 Attorney for: PLAINTIFF Telephone: (215) 563-7000 Supreme Court ID No. 12248 FTI,A AFFIDAVIT OF SERVICE PLAINTIFF CENDANT MORTGAGE CORPORATION, F/K/A PHH MORTGAGE SERVICES CORPORATION DEFENDANT(S) DONALD L. SEVERS ANGELA L. SEVERS SERVE DONALD L. SEVERS AT 302 WH)DERS DRIVE MECHANICSBURG, PA 17055 CUMBERLAND COUNTY KMD No. 02-1415-CIVIL ACCT. #0002075943 Type of Action - Notice of Sheriffs Sale Sale Date: 9/4/02 SERVED , Defendant, on the ---L day of > 2009 Served and made known to 1-ONa I C!? 1t 5 ?W d ?erCS eCl ? cs ?a Commonwealth at ?> o'clock f.m, at 6 a W` r R' l of Pennsylvania, in the manner described below: Defendant personally served. Adult family member with whom Defendant(s) reside(s). Relationship is Adult in charge of Defendant(s)'s residence who refused to give name or relationship. Manager/Clerk of place of lodging in which Defendant(s) reside(s). Agent or person in charge of Defendant(s)'s office or usual place of business. an officer of said Defendant(s)'s company. Other: Description: Age AE- Height / Weight ? U Race W(^Sex ? Other ?7 I d?"o t jr ? Gatw R a competent adult, being duly sworn according to law, depose and state that I personally handed issued in the captioned case on the date and at a true and correct copy of the N rice of Sheriffs Sale in the the address indicated above. NOTARIAL SEAL RIIbNC ?lwp F?NOONO Sworn to and sub?srycn/Lb?ed befor a this -{? day 18' Z N a 20 be m ?lJy' PLEAS ATTEMPT SE ICE AT LEAST 3 TIMES. I ICATE D & TIMES OF SERVICE ATTEMPTED. NOT SERVED On the day of 200_, at o'clock _.m., Defendant NOT FOUND because: Moved Unknown No Answer I" Attempt: Time: Vacant 2nd Attempt: Time: 3rd Attempt: Time: Sworn to and subscribed before me this day of 200 Notary: By: Attorney for Plaintiff Frank Federman, Esquire - I.D. No. 12248 I n o 0 iii iV • ) , `n FG =? fi'' W AFFIDAVIT OF SERVICE CUMBERLAND COUNTY I{NID PLAINTIFF CENDANT MORTGAGE CORPORATION, F/K/A PHH MORTGAGE SERVICES No. 02-1415-CIVIL CORPORATION ACCT. #0002075943 DEFENDANT(S) DONALD L. SEVERS Type of Action ANGELA L. SEVERS - Notice of Sheriffs Sale SERVE ANGELA L. SEVERS AT 1123 RAMAVILLA Sale Date: 9/4/02 CAMPHILL, PA 17011 / SERVED j4 Served and made known to ?N a 1? ?ev`'e rt S Defendant, on the /n day of 2004 Commonwealth at o'clock in., at of Pennsylvania, in the manner described below: / I I Defendant personally served. ?"` ICi 5 ?,,N 1. e0 Adult family member with whom Defendant(s) reside(s). Relationship is 0 Adult in charge of Defendant(s)'s residence who refused to give name or relationship. Manager/Clerk of place of lodging in which Defendant(s) reside(s). Agent or person in charge of Defendant(s)'s office or usual place of business. an officer of said Defendant(s)'s company. Other: Desch tion: Age /,[,,T Height Weight 1.JG Race WV Sex Other I eUce. C. , a competent adult, being duly sworn according to law, depose and state that I personally handed a true and correct copy of the once of Sheriff s Sale in the manner as set forth herein, issued in the captioned case on the date and at the address indicated above. NO-IMKW& Sworn to and subscribed QMN T*P., F=* Cwo before a this -JAg- ay E70n Dr.19, = of d ``, 200?Nk'? Notary: G M C u? i?By PLEA TIMES OF SERVICE ATTEMPTED. ATTEMPT SERVICE AT LEA 3 TIMES. DI ATE & NOT SERVED On the day of 200_, at o'clock _.m., Defendant NOT FOUND because: Moved Unknown No Answer 1st Attempt: Time Vacant 2nd Attempt: / ___L _Time: 3rd Attempt: Time: Sworn to and subscribed before me this day of , 200 By: Notary: w Attorney for Plaintiff Frank Federman, Esquire - I.D. No. 12248 IN THE COURT OF COMMON PLEAS OF CUMBERLAND COUNTY, PENNSYLVANIA RE: CENDANT MORTGAGE CORPORATION, F/K/A PHH MORTGAGE SERVICES CORPORATION CIVIL ACTION VS. DONALD L. SEVERS ANGELA L. SEVERS CIVIL DIVISION NO. 02-1415- CIVIL AFFIDAVIT OF SERVICE PURSUANT TO RULE 3129 COMMONWEALTH OF PENNSYLVANIA ) SS: COUNTY OF CUMBERLAND ) I, FRANK FEDERMAN, ESQUIRE attorney for CENDANT MORTGAGE CORPORATION, F/K/A PHH MORTGAGE SERVICES CORPORATION hereby verify that on 4130102 true and correct copies of the Notice of Sheriffs sale were served by certificate of mailing to the recorded lienholders, and any known interested party see Exhibit "A" attached hereto. Notice of Sale was sent to the Defendant(s) on 4130102 by certified mail return receipt requested see Exhibit "B" attached hereto. DATE: July 17, 2002 FRA K FEDERMA , ESQUIRE Attorney for Plaintiff 4 a# 0 0 F tie N? ? F off.. a?f W " U Ox, ?zW Azd wOax. 1 7 L Gtl N 'C L L y a 9 r zao Pf, v 'T L? ?S4LZL9 d d . i tl3a3i19d `. i e A F z 0 U U z zA O W d ? N ; F .a W C7 ? z t Uvv', AWN U ti Rn in ?7F UW o z a o o ?Fa in 0 0 z s kn O? wa 5ul? a a w Ewa F wa zo en A O pd ?Crr? Wdn v i 0Ca W ip ? z w a ? N 04w? w oA w O w ? w w p A z wQ UAw?. Og Aeh?" ? ..U ?in, U o Oo AW9, Wow FRx en A..U (r? fl. • az • N M VS ,O r- 00 cs ? .-+ M 7160 3901 9844 8032 3020 TO: ANGELA L. SEVERS 1123 RAMAVILLA CAMPHILL, PA 17011 SENDER: KMD SALES 0002075943 REFERENCE: PS Forth 3800 June 2000 RETURN Postage '? 1.. RECEIPT Certltied Fee • 1 , SERVICE Retum Receipt Fee . 3.'. ' Restricted Delivery Total Postage & Fees ' OR p US Postal Service • ""' Receipt for 3 Certified Mail M No insurance Coverage Provided Do Not Use for International Mail 7160 3901 9844 8032 3013 TO: DONALD L. SEVERS 302 WIDDERS DRIVE MECHANICSBURG, PA 17055 SENDER: KMD M SALES 0002075943 REFERENCE: RETURN Postage .34 RECEIPT Certified Fee 1.90 SERVICE Return Receipt Fee 1.50 - Restricted Delivery ? Total Postage & Fees A ' US Postal Service tytc OR DA x o. Receipt for Certified Mail ', 5 Y , No Insurance Coverage Provided Do Not Use for International Mail _ ........................._.__._.._._______. ......._......_... ._.__......, ------------- I in y - ?.J tJ I71 N -< c on a n r- S Co C O rn tp ? COMMONWEALTH OF PENNSYLVANIA COUNTY OF CUMBERLAND I SS: I, Robert P. Ziegler, Recorder of Deeds in and for said County and State do hereby certify that the Sheriff's Deed in which Cendant Mtg Corp fVa PHH Mtg Ser Corp is the grantee the same having been sold to said grantee on the 4th day of Sept A.D., 2002, under and by virtue of a writ Execution issued on the 30th day of April, A.D., 2002, out of the Court of Common Pleas of said County as of Civil Term, 2002 Number 1415, at the suit of Cendant Mtg Coro f/k/a/ PHH Mtg Ser Corp against Donald L Severs & Angela L is duly recorded in Sheriff's Deed Book No. 253, Page 3713. IN TESTIMONY WHEREOF, I have hereunto set my hand and seal of said office this A day of , A.D. 2002 - is 10 r V Recorde?of Deeds conunba? Dqft, th CAmfteW Cafte, Cendant Mortgage Corporation, f*/a In The Court of Common Pleas of PHH Mortgage Services Corporation Cumberland County, Pennsylvania VS Writ No. 2002-1415 Civil Term Donald L. Severs and Angela L. Severs Brian Barrick, Deputy Sheriff, who being duly sworn according to law, states that on May 10, 2002 at 6:30 o'clock PM, 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: Donald L. Severs, by making known unto Donald Severs personally, at 302 Widders Dr., Mechanicsburg, Cumberland County, Pennsylvania, its contents and at the same time handing to him personally the said true and correct copy of the same. Brian Barrick, Deputy Sheriff, who being duly sworn according to law, states that on May 10, 2002 at 6:56 o'clock PM, 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: Angela L. Severs, by making known unto Christine Leo, Mother of Defendant, at 1123 Rana Villa Ave., Camp Hill, Cumberland County, Pennsylvania, its contents and at the same time handing to her personally the said true and correct copy of the same. Dawn Kell, Deputy Sheriff, who being duly sworn according to law, states that on July 8, 2002 at 9:17 o'clock A.M., she posted a true copy of the within Real Estate Writ, Notice, Poster and Description, in the above entitled action, upon the property of Donald L. Severs and Angela L. Severs located at 302 Widders Drive, 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: Angela L. Severs, by regular mail to her last known address of 1123 Ranavilla Ave., Camp Hill, PA 17011. This letter was mailed under the date of July 12, 2002 and never returned to the Sheriff s Office. 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: Donald L. Severs, by regular mail to his last known address of 302 Widders Drive, Mechanicsburg, PA 17055. This letter was mailed under the date of July 12, 2002 and never returned to the Sheriffs Office. R. Thomas Kline, Sheriff, who being duly sworn according to law, states that after due and legal notice had been given according to law, exposed the within described premises at public venue or outcry at the Courthouse, Carlisle, Cumberland County Pennsylvania, on September 4, 2002 at 10:00 o'clock A.M. He sold the same for the sum of $1.00 to Attorney Frank Federman for Cendant Mortgage Corporation, Fk/a PHH Mortgage Services Corporation. It being the highest bid and the best price received for the same Cendant Mortgage Corporation, Vk/a PHH Mortgage Services Corporation of 6000 Atrium Way, Mount Laurel, NJ 08054, being the buyer in this execution paid Sheriff R. Thomas Kline, the sum of $805.77, it being costs. Sheriff's Costs: Docketing Poundage Posting Handbills Advertising Acknowledging Deed Auctioneer Law Library Prothonotary Mileage Certified Mail Levy Surcharge Law Journal Patriot News Share of Bills Distribution of Proceeds Sheriff s Deed $30.00 15.80 15.00 15.00 30.00 10.00 .50 1.00 22.08 2.29 15.00 30.00 307.25 232.15 25.20 25.00 29.50 805.77 paid by attorney 9/23/02 Sworn and subscribed to before me S Answers: This 16'?" day of z4 R. Thomas 0000 K ine, w-.. 2002, A.D. -JIB Prothonotary Real Estate eputy &Ak- P-11- 30. ?v 1 ' a Cie-, 3 F-Z37 & , 2;,vvey .CENDANT MORTGAGE CORPORATION, F/K/A PHH MORTGAGE SERVICES CORPORATION V. Plaintiff, CUMBERLAND COUNTY COURT OF COMMON PLEAS DONALD L. SEVERS ANGELA L. SEVERS CIVIL DIVISION NO. 02-1415-CIVIL Defendant(s). AFFIDAVIT PURSUANT TO RULE 31'29"' (Affidavit No. 1) 71.E CENDANT MORTGAGE CORPORATION FIKIA PHH MORTGAGE SERVICES CORPORATION, Plaintiff in the above action, by its attorney, FRANK FEDERMAN, 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,302 WIDDERS DRIVE, MECHANICSURG PA 17055 1. Name and address of Owner(s) or reputed Owner(s): Name DONALD L. SEVERS ANGELA L. SEVERS Last Known Address (if address cannot be reasonably ascertained, please indicate) 302 WIDDERS DRIVE MECHANICSBURG, PA 17055 1123 RAMAVILLA CAMPHILL, PA 17011 2. Name and address of Defendant(s) in the judgment: Same as above 3. Name and last known address of everyjudgment creditor whose judgment is a record lien on the real property to be sold: Name Last Known Address (if address cannot be reasonably ascertained, please indicate) None 4. Name and address of last recorded holder of every mortgage of record: Name Last Known Address (if address cannot be reasonably ascertained, please indicate) CITIFINANCIAL SERVICES INC. 6520 CARLISLE PIKE, SUITE 155 MECHANICSBURG, PA 17055 5. Name and address of every other person who has any record lien on the property: Name Last Known Address (if address cannot be reasonably ascertained, please indicate) None 6. Name and address of every other person who has any record interest in the property and whose interest may be affected by the sale. Name Last Known Address (if address cannot be reasonably ascertained, please indicate) MONROE ACRES CIVIC ASSOCIATION, INC. 207 FAIRWAY DRVE MECHANICSBURG, PA 17055 7. Name and address of every other person of whom the plaintiff has knowledge who has any interest in the property which may be affected by the sale: Name Tenant/Occupant Domestic Relations of Cumberland County Last Known Address (if address cannot be reasonably ascertained, please indicate) 302 WIDDERS DRIVE MECHANICSURG, PA 17055 13 North Hanover Street Carlisle, PA 17013 Commonwealth of Pennsylvania Department of Welfare PO Box 2675 Harrisburg, PA 17105 I verify that the statements made in this affidavit are true and correct to the best of my personal knowledge or information and belief. I understand that false statements herein are made subject to the penalties of 18 Pa. C.S. Sec. 4904 relating to unswom falsification to authorities. April 24, 2002 ? [i.?? ??Q a /? lli n n DATE $KANK FEDNRMAN, ESQUIRE Attorney for Plaintiff CENDANT MORTGAGE CORPORATION, F/K/A PHH MORTGAGE SERVICES CORPORATION Plaintiff, V. DONALD L. SEVERS ANGELA L. SEVERS Defendant(s). CUMBERLAND COUNTY No. 02-1415-CIVIL April 24, 2002 TO: DONALD L. SEVERS 302 WIDDERS DRIVE MECHANICSBURG, PA 17055 ANGELA L. SEVERS 1123 RAMAVILLA CAMPHILL, PA 17011 "THIS FIRM IS A DEBT COLLECTOR ATTEMPTING TO COLLECT A DEBT AND ANY INFORMATION OBTAINED WILL BE USED FOR THAT PURPOSE. IF YOUHAVE PREVIOUSLYRECEIVED A DISCHARGE IN BANKR UPTCYAND THIS DEBT WAS NOT REAFFIRMED, THIS IS NOT AND SHOULD NOT BE CONSTRUED TO BE ANA 7TEMPT TO COLLECT A DEBT, BUT ONLY ENFORCEMENT OF A LIENAGAINST PROPERTY. * * Your house (real estate) at, 302 WIDDERS DRIVE MECHANICSURG PA 17055 is scheduled to be sold at the Sheriffs Sale on 9/4/02 at 10:00 a.m. in the Cumberland County Courthouse, South Hanover Street, Carlisle, PA 17013, to enforce the court judgment of $123,607.51 obtained by CENDANT MORTGAGE CORPORATION F/K/A PHH MORTGAGE SERVICES CORPORATION (the mortgagee) against you. In the event the sale is continued, an announcement will be made at said sale in compliance with Pa.R.C.P., Rule 3129.3. NOTICE OF OWNER'S RIGHTS YOU MAY BE ABLE TO PREVENT THIS SHERIFF'S SALE To prevent this Sheriffs Sale, you must take immediate action: The sale will be cancelled if you pay to the mortgagee the back payments, late charges, costs and reasonable attorney's fees due. To find out how much you must pay, you may call: (215) 563-7000. 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 Courtto postpone the sale for good cause. 3. You may also be able to stop the sale through other legal proceedings. You may need an attorney to assert your rights. The sooner you contact one, the more chance you will have of stopping the sale. (See notice on page two on how to obtain an attorney.) YOU MAY STILL BE ABLE TO SAVE YOUR PROPERTY AND YOU HAVE OTHER RIGHTS EVEN IF THE SHERIFF'S SALE DOES TAKE PLACE 1. If the Sheriffs Sale is not stopped, your property will be sold to the highest bidder. You may find out the price bid by calling (215) 563-7000. 2. You may be able to petition the Court to set aside the sale if the bid price was grossly inadequate compared to the value of your property. 3. The sale will go through only if the buyer pays the Sheriff the full amount due in the sale. To find out if this has happened, you may call (717) 240-6390. 4. If the amount due from the Buyer is not paid to the Sheriff, you will remain the owner of the property as if the sale never happened. 5. You have the right to remain in the property until the full amount due is paid to the Sheriff and the Sheriff gives a deed to the buyer. At that time, the buyer may bring legal proceedings to evict you. 6. You may be entitled to a share of the money which was paid for your house. A schedule of distribution of the money bid for your house will be filed by the Sheriff within 30 days of the sale. This schedule will state who will be receiving that money. The money will be paid out in accordance with this schedule unless exceptions (reasons why the proposed distribution is wrong) are filed with the Sheriff within ten (10) days after the distribution is filed. 7. You may also have other rights and defenses, or ways of getting your home back, if you act immediately after the sale. YOU SHOULD TAKE THIS PAPER TO YOUR LAWYER AT ONCE. IF YOU DO NOT HAVE A LAWYER OR CANNOT AFFORD ONE, GO TO OR TELEPHONE THE OFFICE LISTED BELOW TO FIND OUT WHERE YOU CAN GET LEGAL HELP. CUMBERLAND COUNTY ATTORNEY REFERRAL CUMBERLAND COUNTY BAR ASSOCIATION 2 LIBERTY AVENUE CUMBERLAND COUNTY COURTHOUSE CARLISLE, PA 17013 (717) 249-3166 (800) 990-9108 ALL THAT CERTAIN tract of land situate in Monroe Township, Cumberland County, Pennsylvania, being more particularly bounded and described as follows, to wit: BEGINNING at a point on the Northern side of Widders Drive a fifty (50) foot wide street; thence along Lot No. 71, North twenty-six (26) degrees ten (10) minutes forty (40) seconds West one hundred forty (140) feet to a point at Lot No. 72; thence along Lot No. 72 and Lot No. 74, North sixty-three (63) degrees forty-five (45) minutes twenty (20) seconds East, one hundred twenty (120) feet to a point at Lot No. 69; thence along Lot No. 69 South twenty-six (26) degrees ten (10) minutes forty (40) seconds East one hundred forty (140) feet to a point on the Northern side of Widders Drive; thence along the Northern side of Widders Drive, South sixty-three (63) degrees forty-nine (49) minutes twenty (20) seconds West, one hundred twenty (120) feet to a point, the point and place of beginning. BEING Lot No. 70 of Monroe Acres as shown on Section C, in accordance with a survey by Larsen & Brilhart, Inc., Registered Surveyor, dated March 10, 1972 and recorded in Plan Book 22, Page 98. HAVING thereon erected a brick and aluminum bi-level dwelling known and numbered as 302 Widders Drive. Tax Parcel #29-2463-056 TITLE TO SAID PREMISES IS VESTED IN Donald L. Severs and Angela L. Severs, husband and wife by Deed from Donald J. Bordner and Roseanna M. Bordner, husband and wife dated 3/1/1999, recorded 3/5/1999, in Deed Book 195, Page 421. WRIT OF EXECUTION and/or ATTACHMENT COMMONWEALTH OF PENNSYLVANIA) COUNTY OF CUMBERLAND) NO 02-1415 Civil CIVIL ACTION- LAW TO THE SHERIFF OF Cumberland COUNTY: To satisfy the debt, interest and costs due CENDANT MORTGAGE CORP f/k/a PHH MORTGAGE SSERVICES CORP. PLANTIFF(S) From DONALD L. SEVERS, 302 WIDDERS DR., MECHANICSBURG PA 17013 and ANGELA L. SEVERS, 1123 RAMAVILLA, CAMP HILL PA 17013. (1) You are directed to levy upon the property of the defendant(s) and to sell REAL ESTATE LOCATED AT 302 WIDDERS DR., MECHANICSBURG PA 17055. (SEE ATTACHED 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 defendant (s) and from delivering any property of the defendant (s) or otherwise disposing thereof; (3) If property of the defendant(s) not levied upon an subject to attachment is found in the possession of anyone other than a named garnishee, you are directed to notify him/her that he/she has been added as a garnishee and is enjoined as above stated. Amount Due $123,607.51 L.L. $.50 Interest 511102 - 9/4/02 @ $20.32/diem $2,580.64 Due Prothy $1.00 Atty's Comm % Other Costs Arty Paid $132.9 Plaintiff Paid Date: APRIL 30, 2002 CURTIS R. LONG Prothonotary, Civil Division By: REQUESTING PARTY: Name FRANK FEDERMAN, ESQ. Address: ONE PENN CENTER @ SUBURBAN STATION 1617 JFK BLVD., SUITE 1400 PHILADELPHIA PA 19103-1814 Attorney for: PLAINTIFF Telephone: (215) 563-7000 Supreme Court ID No. 12248 Real Estate Sale # 10 J " On May 9, 2002 the sheriff levied upon the defendant's interest in the real property situated in Monroe Township, Cumberland County, PA Known and numbered as 302 Widders Drive, Mechanicsburg, and more fully described on Exhibit "A" filed with this writ and by this reference incorporated herein. Date: May 9, 2002 By: C( Cex? I1 (? . ?? ?? Ad 1 AqW 0 ?7 THE PATRIOT NEWS THE SUNDAY PATRIOT NEWS Proof of Publication Under Act No. 587, Approved May 16, 1929 Commonwealth of Pennsylvania, County of Dauphin) ss 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 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 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", Volume 14, Page 317. PUBLICATION f' .... `.` .. .'X_6 ............ COPY . Sworn to and subscribed before me this 14th day of ?fgust 0402 A.D. S A L E #10 Notarial Seal ` : Terry L. Russell. Notary Public REAL ESTATE SALE No. 10 Writ No. E SAL 415 City Of Harrisburg, Dauphin County My Commission Expires June 6,2006 NOTARY PUBLIC CIvIITerm Cendant Mortgage Corp., Member, Pennsylvania Association Of NotariesMy commission expires June 6, 2006 F/k/a PHH Mortgage Services Corp. Vs CUMBERLAND COUNTY SHERIFFS OFFICE Donald L. Severs Angela L. Severs CUMBERLAND COUNTY COURTHOUSE Atty: Frank Federman CARLISLE, PA. 17013 DESCRIPTION ALL THAT CERTAIN tract of land situate in Monroe Township, Cumberland County. Statement of Advertising Costs Pennsylvania, being more particularly bounded and described as follows, to wit: TO THE PATRIOT-NEWS CO., Dr. BEGINNING at a point on the Northern side of For publishing the notice or publication attached Widders Drive a fifty (50) foot wide street; thence along Lot No. 71, North twenty-six (26) degrees hereto on the above stated dates $ 230.40 ten (10) minutes forty (40) seconds West one Probating same Notary Fee(s) $ 1.75 hundred fortv (140) feet to a point at Lot No. 72; thence along Lot No. 72 and Lot No. 74, North Total $ 232.15 sixty-three (63) degrees forty-five (45) minutes twenty (20) seconds East, one hundred twenty (120) feet to a pant at Lot No. 69: thence along Publisher's Receipt for Advertising Cost The Patriot News Co. , publisher of The Patriot-News and The Sunday Patriot-News, newspapers of general circulation, hereby acknowledg e receipt of the aforesaid notice and publication costs and certifies that the same have been duly paid. Lot No 69 south twenty-six (26) aegrees ten (10) minutes fortv 140) seconds East one hundred forty (140) feet to a point on the Northern side of Widders Drive; thence along the Northem side of Widders Drive, South sixty-three (53) degrees fortv-nine (49) minutes twenty (20) seconds West, one hundred twenty (120) feet to a po ot, the point and place of beginning. BEING Lot No. 70 of Monroe Acres as shown on Section C, in accordance with a survey by Larsen & Brihart, Inc., Registered Surveyor, dated March 10, 1972 and recorded in Plan Book 22, Page 98. HAVING thereon erected a brick and aluminum bi-level dwelling known and numbered as 302 Widders Diis°e By Tax Parcel #29-2463-056. TITLE TO SAID PREMISES is vested in Donald L. Severs and Angela L. Severs, husband and wife, by Deed from Donald J. Bordner and Roseanna M. Bordner, husband and wife, dated 3/ 1/1999, recorded 3/5/1999, in Deed Book 195, Page 421. 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: 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. REAL ESTATE SALE NO. 10 Writ No. 2002-1415 Civil Cendant Mortgage Corporation, F/K/A PHH Mortgage Services Corporation vs. Donald L. Severs and Angela L. Severs Atty.: Frank Federman DESCRIPTION ALL THAT CERTAIN tract of land situate in Monroe Township, Cum- berland County, Pennsylvania, be- ing more particularly bounded and described as follows, to wit: BEGINNING at a point on the Northern side of Widders Drive a fifty (50) foot wide street; thence along Lot Nu. 71, North cwenty-sir (26) degrees ten (10) minutes forty (40) seconds West one hundred forty (140) feet to a point at Lot No. 72; thence along Lot No. 72 and Lot R ger M. Morgenthal, Editor SWORN TO AND SUBSCRIBED before me this 9 day of AUGUST. 2002 LOIS E. SWDER, NdWY PJ* 5.2W5 No. 74, North sixty-three (63) de- grees forty-five (45) minutes twenty (20) seconds East, one hundred twenty (120) feet to a point at Lot No. 69; thence along Lot No. 69 South twenty-six (26) degrees ten (10) minutes forty (40) seconds East one hundred forty (140) feet to a point on the Northern side of Widders Drive; thence along the Northern side of Widders Drive, South sixty-three (63) degrees forty- nine (49) minutes twenty (20) sec- onds West, one hundred twenty (120) feet to a point, the point and place of beginning. BEING Lot No. 70 of Monroe Acres as shown on Section C, in accor- dance with a survey by Larsen & Brilhart, Inc., Registered Surveyor, dated March 10, 1972 and recorded in Plan Book 22, Page 98. HAVING thereon erected a brick and aluminum bi-level dwelling known and numbered as 302 Wid- ders Drive. Tax Parcel #29-2463-056. TITLE TO SAID PREMISES IS VESTED IN Donald L. Severs and Angela L. Severs, husband and wife by Deed from Donald J. Bordner and Roseanna M. Bordner, husband and wife dated 3/l/1999, recorded 3/5/1999, in Deed Book 195, Page 421. ?S