HomeMy WebLinkAbout02-1422YOU 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
THE ATTORNEY AND FILING IN WRITING WITH THE COURT YOUR DEFENSES
AND 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
SHOULD 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 BAR ASSOCIATION
2 LIBERTY AVENUE
CARLISLE, PA 17013
(717) 249-3166
AND NOW, comes the Plaintiff by its attorneys, Louis P. Vitti and Associates, P.C. and Louis P.
Vitti, Esquire, and pursuant to the Pennsylvania Rules of Civil Procedure Numbers 1141 through 1150, for
its Complaint in Mortgage Foreclosure, sets forth the following:
1. The Plaintiff is a corporation duly authorized to conduct business within the laws of the
Commonwealth of Pennsylvania, having a principal place of business located at 3232 Newmark Drive,
Miamisburg, OH 45342.
2. The Defendant(s) is/are individuals with a last known mailing address of 42 Liberty
Drive, Mt. Holly Springs, PA 17065. The property address is 42 Liberty Drive, Mt. Holly Springs, PA
17065 and is the subject of this action.
3. On the 4th day of December, 1998, in consideration of a loan of One Hundred Fourteen
Thousand, Six Hundred Twenty-Two and 00/100 ($114,622.00) Dollars made by National City Mortgage
Co., an OH corporation, to Defendant(s), the said Defendant(s) executed and delivered to National City
Mortgage Co., an OH corporation, a "Note" secured by a Mortgage with the Defendant(s) as mortgagor(s)
and National City Mortgage Co., as mortgagee, which mortgage was recorded on the 4th day of February,
1999, in the Office of the Recorder of Deeds of Cumberland County, in Mortgage Book Volume 1517, page
1129. The said mortgage is incorporated herein by reference thereto as though the same were set forth fully
at length.
4. The premises secured by the mortgage are:
(See Exhibit "A" attached hereto.)
5. Said mortgage provides, inter alia:
"that when as soon as the principal debt secured shall become due and payable, or in
case default shall be made in the payment of any installment of principal and interest, or any
monthly payment, keeping and performance by the mortgagor of any of the terms, conditions
or covenants of the mortgage or note, it shall be lawful for mortgagee to bring an Action of
Mortgage Foreclosure, or other proceedings upon the mortgage, of principal debt, interest
and all other recoverable sums, together with attorney's fees."
6. Since April 1, 2001, the mortgage has been in default by reason, inter alia, of the failure
of the mortgagor(s) to make payments provided for in the said mortgage (including principal and interest)
and, under the terms of the mortgage, the entire principal sum is due and payable.
7. In accordance with the appropriate Pennsylvania Acts of Assembly and the Pennsylvania
Rules of Civil Procedure, the mortgagor(s) has been advised in writing of the mortgagees intention to
foreclose. The appropriate time period has elapsed since the Notice of Intention to Foreclose has been
served upon the mortgagor(s).
8. The amount due on said mortgage is itemized on the attached schedule.
9. Plaintiff does hereby release the personal representative, heir and/or devisee of the
mortgagor(s) from liability for the debt secured by the mortgage.
WHEREFORE, pursuant to Pennsylvania Rule of Civil Procedure Number 1147(6), Plaintiff
demands judgment for the amount due of One Hundred Thirty-Four Thousand, Nine Hundred Twenty-Seven
and 85/100 Dollars ($134,927.85) with interest and costs.
Respectfully submitted,
LOUIS P. VITTI & ASSOC., P.C.
E . ?//
Louis P. Vitti, Esquire
Attorney for Plaintiff
MULLIS
SCHEDULE OF AMOUNTS DUE UNDER MORTGAGE
Unpaid Principal Balance
Interest 7.3750% from 03/01/01 through
(Plus $22.7969 per day after 3/31/02 )
Late charges through 3/20/02
0 months @ 7.92
Accumulated beforehand
(Plus $7.92 on the 17th day of each month after
Attorney's fee
5,641.27
Escrow deficit 7,361.47
(This figure includes projected additional charges that may be incurred by the Plaintiff
and transmitted to the sheriff as charges on the writ prior to the date of the sheriff's
sale)
3/31/02
112,825.30
9,004.77
95.04
3/20/02 )
BALANCE DUE 1349927.85
Legal Descriptions: All that certain property situated in the BOROUGH OF MT. HOLLY
SPRINGS, in the County of CUMBERLAND, and the Comwnwealth of PENNSYLVANIA, being
described as follows: PARCEL 23-35-2316-076 and being more fully described in a deed
dated 11/13/1998, and recorded 02/04/1999, among the land records of the county and
state set forth above, in Deed Book 193, page 977.
EXHIBIT m Am
AND NOW Louis P. Vitti verifies that the statements made in this Complaint are true
and correct to the best of his knowledge, information and belief. I understand that false statements
herein are made subject to the penalties of 18 Pa.C.S. 4904, relating to unsworn falsification to
authorities.
By virtue of the fact that the Plaintiff is outside the jurisdiction of the court and the
verification cannot be obtained within the time allowed for the filing of this pleading, the pleading
is submitted by counsel having sufficient knowledge, information and belief based upon the
information provided him by the Plaintiff.
Lou' P. Vitti
Dated: March 20, 2002
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IN THE COURT OF COMMON PLEAS OF CUMBERLAND COUNTY, PENNSYLVANIA
NATIONAL CITY MORTGAGE CO.,
Plaintiff,
VS.
ROBERT C. MULLIS and ANGELA L.
MULLIS
CIVIL DIVISION
NO. 02-1422 Civil Term
PRAECIPE FOR DEFAULT
JUDGMENT, CERTIFICATION OF
MAILING AND AFFIDAVIT OF NON-
MILITARY SERVICE
Defendants. Code MORTGAGE FORECLOSURE
Filed on behalf of
Plaintiff
Counsel of record for this
party:
Louis P. Vitti, Esquire
PA I.D. #3810
Supreme Court #01072
Louis P. Vitti & Assoc., P.C.
916 Fifth Avenue
Pittsburgh, PA 15219
(412) 281-1725
IN THE COURT OF COMMON PLEAS OF CUMBERLAND COUNTY, PENNSYLVANIA
CIVIL DIVISION
NATIONAL CITY MORTGAGE CO., ) NO.: 02-1422 Civil Term
Plaintiff, )
VS. )
ROBERT C. MULLIS and ANGELA L. MULLIS, )
Defendants. )
PRAFCIPE FOR DEFAULT JUDGMENT
AND ASSESSMENT OF DAMAGES
TO: PROTHONOTARY OF CUMBERLAND COUNTY
Enter judgment in Default of an Answer in the amount of $135,611.76, in favor of
the National City Mortgage Co.,, Plaintiff in the above-captioned action, against the Defendants,
Robert C. Mullis and Angela L. Mullis and assess Plaintiffs damages as follows and/or as
calculated in the Complaint:
Unpaid Principal Balance $112,825.30
Interest from 03/01/01-04/30/02 9,688.68
(Plus $22.7969 per day after 04/30/02)
Late charges (Plus $7.92 per
month from 3/20/02-09/04/02 $39.60) 95.04
Attorney's fee 5,641.27
Escrow Deficit 7,361.47
(Plus any additional charges that may be
incurred by the Plaintiff and transmitted
to the sheriff as charges on the writ prior
to the date of the sheriffs sale)
Total Amount Due $135.611.76
The real estate, which is the subject matter of the Complaint, is situate in Boro of Mt.
Holly Springs, Cumberland Cty, Cmwlth of PA. HET a dwg k/a 42 Liberty Drive, t. Holly Springs,
PA 17065. Parcel # 23-385-2316-076.
Fis P. Vitti, Esquire
Attorney for the Plaintiff
IN THE COURT OF COMMON PLEAS OF CUMBERLAND COUNTY, PENNSYLVANIA
CIVIL DIVISION
NATIONAL CITY MORTGAGE CO., ) NO.: 02-1422 Civil Term
Plaintiff, )
VS. )
ROBERT C. MULLIS and ANGELA L. MULLIS, )
Defendants. )
I, Louis P. Vitti, do hereby certify that a Notice of Intention to Take Judgment was mailed to the
Defendant(s), in the above-captioned case on April 18, 2002, giving ten (10) day notice that judgment
would be entered should no action be taken.
LOUIS P. VITTI & ASSOCIATES, P.C.
A
BY:
Vitti, Esquire
Attorney for Plaintiff
SWORN to and subscribed
before me this 30th day
of April, 2002.
Notary Public
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IN THE COURT OF COMMON PLEAS OF CUMBERLAND COUNTY, PENNSYLVANIA
CIVIL DIVISION
NATIONAL CITY MORTGAGE CO.,
NO. 02-1422
Plaintiff,
vs.
ROBERT C. MULLIS and ANGELA L. MULLIS, :
Defendants,
IMPORTANT NOTICE
TO: Robert C. Mullis
Angela L. Mullis
42 Liberty Drive
Mt. Holly Springs, PA 17065
Date of Notice: April 18, 2002
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 YOUR LAWYER AT ONCE. IF YOU DO NOT
HAVE A LAWYER OR CANNOT AFFORD ONE, GO TO OR TELEPHONE THE FOLLOWING
OFFICE SET FORTH BELOW TO FIND OUT WHERE YOU CAN GET LEGAL HELP:
CUMBERLAND COUNTY BAR ASSOCIATION
2 LIBERTY AVENUE
CARLISLE, PA 17013
(717) 249-3166
LO . VITTI C TES, P.C.
BY:
L is . Vitti, Esquire
Attorney for Plaintiff
916 Fifth Avenue
Pittsburgh, PA 15219
•¦ THE DEBT COLLECTOR IS ATTEMPTING TO COLLECT A DEBT AND ANY
INFORMATION OBTAINED WILL BE USED FOR THAT PURPOSE."
IN THE COURT OF COMMON PLEAS OF CUMBERLAND COUNTY, PENNSYLVANIA
CIVIL DIVISION
COMMONWEALTH OF PENNSYLVANIA, SS:
COUNTY OF ALLEGHENY
BEFORE me, the undersigned authority, personally appeared Louis P. Vitti, Esquire, who,
being duly sworn according to law, deposes and says that he is advised and believes that
DEFENDANT(S) is/are not presently in the active military service of the United States of America
and not members of the Army of the United States, United States Navy, the Marine Corps, or the
Coast Guard, and not officers of the Public Health Service detailed by proper authority for duty with
the Army or Navy; nor engaged in any active military service or duty with any military or naval units
covered by the Soldiers and Sailors Civil Relief Act of 1940 and designated therein as military
service, and to the best of this affiant's knowledge is/are not enlisted in military service covered by
said act, and that the averments herein set forth, insofar as they are within his knowledge, are correct,
and true; and insofar as they are based on information received from others, are true and correct as
he verily believes.
This Affidavit is made under the provisions of the Soldiers and Sailors Civil Relief Act of
1940.
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Lo P. Vitti, Esquire
SWORN to and subscribed
before me this 30th day
of April, 2002.
tom- C??'?j
Notary Public
IN THE COURT OF COMMON PLEAS OF CUMBERLAND COUNTY, PENNSYLVANIA
CIVIL DIVISION
NATIONAL CITY MORTGAGE CO., ) NO.: 02-1422 Civil Tenn
Plaintiff, )
VS. )
ROBERT C. MULLIS and ANGELA L. MULLIS, )
Defendants. )
I, Louis P. Vitti, do hereby swear that, to the best of my knowledge, information and belief,
the Defendant(s), is/are the owners of the real property on which the Plaintiff seeks to execute. That the
Defendants' last known address is 42 Liberty Ave, Mt. Holly Springs, PA 17065.
L is P. Vitti, Esquire
SWORN TO and subscribed
before me this 30th day of
April, 2002.
Notary Public
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IN THE COURT OF COMMON PLEAS OF CUMBERLAND COUNTY, PENNSYLVANIA
NATIONAL CITY MORTGAGE CO., CIVIL DIVISION
Plaintiff, NO. 02-1422 Civil Term
PRAECIPE FOR WRIT OF
VS. EXECUTION AND AFFIDAVIT OF
LAST KNOWN ADDRESS
ROBERT C. MULLIS and ANGELA L.
MULLIS
Code MORTGAGE FORECLOSURE
Defendants.
Filed on behalf of
Plaintiff
Counsel of record for this
party:
Louis P. Vitti, Esquire
PA I.D. #3810
Supreme Court #01072
Louis P. Vitti & Assoc., P.C.
916 Fifth Avenue
Pittsburgh, PA 15219
(412) 281-1725
IN THE COURT OF COMMON PLEAS OF CUMBERLAND COUNTY, PENNSYLVANIA
CIVIL DIVISION
NATIONAL CITY MORTGAGE CO., ) NO.: 02-1422 Civil Tenn
Plaintiff, )
VS. )
ROBERT C. MULLIS and ANGELA L. MULLIS, )
Defendants. )
PRAECIPE FOR WRIT OF
EXECUTION IN MORTGAGE FORECLOSURE
TO: PROTHONOTARY OF CUMBERLAND COUNTY
Issue a Writ of Execution in favor of the Plaintiff and against the Defendant(s) in the
above-captioned matter as follows:
Amount Due $135,611.76
Interest 5/01/02-9/04/02 22,895.21
Total 5138.506.97
The real estate, which is the subject matter of the Praecipe for Writ of Execution is situate
in:
Boro of Mt. Holly Springs, Cumberland Cty, Cmwlth of PA. HET a dwg k/a 42 Liberty Drive, Mt. Holly
Springs, PA 17065. Parcel # 23-385-2316-076.
Louis P. Vitti, Esquire
Attorney for Plaintiff
IN THE COURT OF COIN PLEAS OF CUMBERLAND COUNTY, PENNSYLVANIA
- CIVIL DIVISION _
'aption :
National City Mortgage Co.
V5.
PRAECIPE FOR WRIT OF FX=ION
( ) Confessed Judgment
: ( ) Other
File No.02-1422
Robert C. Mullis and Angela L. Mullis
Amount Due 135,611.76
Interest 2,895.21
Atty's Cann
Costs
TO THE PROTHONOTARY OF THE SAID COURT:
The undersigned hereby certifies that the below does not arise out of a retail
instal.lrmnt sale, contract, or account based on a confession of judgment, but if it does,
it is based on the appropriate ori.ginal proceeding filed pursuant to Act 7 of 1966 as
amended; and for real property pursuant to Act 6 of 1974 as amended.
Issue writ of execution in the above natter to the Sheriff of Cumberland
County, for debt, interest and costs upon the following described property of the
defendant(s)
see attached legal description
PRAE)= FOR ATTAC R-EZM EXB=C N
Issue writ of attachment to the Sheriff of Cumberland County, for debt,
interest and costs, as above, directing attachment against the above-named garnishee(s) for
the following property (if real estate, supply six copies of the description; supply four
copies of lengthy personalty list)
and all other property of the defendant(s) in the possession, custody or control of the
said garnishee(s).
(Indicate) Index this writ against the garnishee(s) as a Lis pendens against
real estate of the defendant(s) described in the attached exhibit. %
DATE: 4.30.02 Signature:
Print Name: Tnnin P_ Vi YYi
Address: 916 Fifth AVe
Pgh PA 15219
.,'t_C t'nev COL: Plaintiff
'ale_?.ore:_? 2Rl 17?s
IN THE COURT OF COMMON PLEAS OF CUMBERLAND COUNTY, PENNSYLVANIA
CIVIL DIVISION
NATIONAL CITY MORTGAGE CO., ) NO.: 02-1422 Civil Term
Plaintiff, )
vs. )
ROBERT C. MULLIS and ANGELA L. MULLIS, )
Defendants. )
LEGAL DESCRIPTION
All that certain tract of land situates in the Borough if Mount Holly Springs, Cumberland County,
Pennsylvania, bounded and described in accordance with a Plamprepared by Walter N. Heine Associates,
Inc., dated December 8, 1989 and recorded in Plan Book 64, page 90, as follows:
Beginning at a point in Eastern right if way of Liberty Drive at corner of Lot No. 59 on said Plan; thence
along Lot No. 59, South 61 degrees 46 minutes 59, seconds East 277.88 feet to a point; thence South l7
degree 48 minutes 45 seconds East 125.0O.feet to a point; thence along Lot No. 57 on said Plan, North
60 degrees 53 minutes 20 seconds West 357.13 feet'to a point in Eastern right of way line of Liberty
Drive; thence along eastern right of way line of Liberty Drive, by a curve to the left having a radius of
262.64 feet and an arc length of 62.17 feet to a'point; thence still along Eastern right of way line of Liberty
Drive North 15 degrees 32 minutes 53 seconds West 20.00 feet to a point, the place of beginning.
Containing.6056 acre and designated as Lot No. 58 on Plan of Liberty Woods.
Parcel# 23-35-2316-076
Being the same premises which Liberty Associates by their Deed dated 11/13/1998 and recorded on
02/04/1999 in the Recorder of Deeds Office in Cumberland County, Pennsylvania, in DBV 193, pg 977,
granted and conveyed unto Robert C. Mullis and Angela L. Mullis.
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WRIT OF EXECUTION and/or ATTACHMENT
COMMONWEALTH OF PENNSYLVANIA)
COUNTY OF CUMBERLAND)
NO 02-1422 Civil
CIVIL ACTION - LAW
TO THE SHERIFF OF CUMBERLAND COUNTY:
To satisfy the debt, interest and costs due NATIONAL CITY MORTGAGE CO., Plaintiff (s)
From ROBERT C. MULLIS AND ANGELA L. MULLIS, 42 LIBERTY DRIVE, MT. HOLLY
SPRINGS, PA 17065
(1) You are directed to levy upon the property of the defendant (s)and to sell SEE LEGAL
(2) You are also directed to attach the property of the defendant(s) not levied upon in the possession
of
GARNISHEE(S) as follows:
and to notify the gamishee(s) that: (a) an attachment has been issued; (b) the garnishee(s) is enjoined from
paying any debt to or for the account of the defendant (s) and from delivering any property of the defendant
(s) or otherwise disposing thereof;
(3) 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 $135,611.76
Interest $2,895.21
Arty's Comm %
Arty Paid $120.83
Plaintiff Paid
Date: MAY 10, 2002
REQUESTING PARTY:
Name LOUIS P. VITTI, ESQUIRE
Address: 916 FIFTH AVE.
PITTSBURGH, PA 15219
Attorney for: PLAINTIFF
Telephone: 412-281-1725
Supreme Court ID No. 3810
L.L. $.50
Due Prothy $1.00
Other Costs
CURTIS R. LONG
Prothonotary, Civil Division
By6??
IN THE COURT OF COMMON PLEAS OF CUMBERLAND COUNTY, PENNSYLVANIA
CIVIL DIVISION
NATIONAL CITY MORTGAGE CO., ) NO.: 02-1422 Civil Term
Plaintiff, )
VS. )
ROBERT C. MULLIS and ANGELA L. MULLIS, )
Defendants. )
I, Louis P. Vitti, hereby certify that as representative of National City Mortgage Co., am familiar
with the above-captioned case and various servicing activities related thereto and that the provisions of
the laws of the Commonwealth of Pennsylvania and specifically, Act 91 of 1983, have been complied with
in the above-captioned case.
ouis P. Vitti, Esquire
Attorney for Plaintiff
SWORN to and subscribed
before me this 30th day
of April, 2002.
Notary Public
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IN THE COURT OF COMMON PLEAS OF CUMBERLAND COUNTY, PENNSYLVANIA
CIVIL DIVISION
NATIONAL CITY MORTGAGE CO., ) NO.: 02-1422 Civil Term
Plaintiff, )
VS. )
ROBERT C. MULLIS and ANGELA L. MULLIS, )
Defendants. )
National City Mortgage Co., Plaintiff in the above action, sets forth as of the date the Praecipe for the Writ
of Execution was filed the following information concerning the real property located at 42 Liberty Drive,
Mt. Holly Springs, PA 17065.
1. Name and address of Owner(s) or Reputed Owner(s):
Name: Address (Please indicate if this
cannot be reasonably ascertained)
Robert C. Mullis 42 Liberty Drive
Angela L. Mullis Mt. holly Springs, PA 17065
2. Name and address of Defendant(s) in the judgment:
Name: Address (Please indicate if this
cannot be reasonably ascertained)
Same as No. 1 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:
Address (Please indicate if this
cannot be reasonably ascertained)
None
4. Name and address of the last recorded holder of every mortgage of record:
Name Address (Please indicate if this
cannot be reasonably ascertained)
None
5. Name and address of every other person who has any record lien on the property:
Name Address (Please indicate if this
cannot be reasonably ascertained)
None
6. 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:
Name
Address (Please indicate if this
cannot be reasonably ascertained)
None
7. Name and address of every other person of whom the Plaintiff has knowledge who has any
interest in the property which may be affected by the sale:
Name
Address (Please indicate if this
cannot be reasonably ascertained)
Tax Collector of Mt. Holly Springs
Mt. Holly Springs Municipal
Commonwealth of PA -DPW
Clerk of Courts
Criminal/Civil Division
Court of Common Pleas of
Cumberland County
Domestic Relations Division
Mable Satteson
3 Trine Ave
Mt Holly Springs, PA 17065
200 Harman Street
Mt. holly Springs, PA 17065
P.O. Box 8016
Harrisburg, PA 17105
One Courthouse Square
Carlisle, PA 17013
P.O. Box 320
Carlisle, PA 17013
Bureau of Compliance
Tenant/Occupant
Clearance Support Section
Dept. #281230
Harrisburg, PA 17128-1230
Attn: Susan Blough
42 Liberty Ave
Mt. Holly Springs, PA 17065
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 unworn falsification to authorities.
Ap i] 30 2002
Date
SWORN TO and subscribed
before me this 30th day
of April, 2002.
Nata.?y Pubic
T".
o s P. Vitti, Esquire
Attorney for Plaintiff
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NOTICE OF SHERIFF'S SALE OF
REAL ESTATE PURSUANT TO
PENNSYLVANIA RULE OF CIVIL
PROCEDURE 3129.1
TO: Robert C. Mullis
Angela L. Mullis
42 Liberty Drive
Mt. Holly Springs, PA 17065
AND: ALL LIEN HOLDERS
TAKE NOTICE that by virtue of the above Writ of Execution issued out of the Court of Common
Pleas of Cumberland County, Pennsylvania and to the Sheriff of Cumberland County, directed, there will
be exposed to Public Sale in Cumberland County Courthouse on September 4, 2002 at 10:00 A.M., the
following described real estate, of which Robert and Angela Mullis are owners or reputed owners:
The said Writ of Execution has issued on a judgment in the mortgage foreclosure action of National
City Mortgage Co., vs. Robert and Angela Mullis at No.: 02-1422 in the amount of $135,611.76.
Claims against property must be filed at the Office of the Sheriff before above sale date.
Claims to proceeds must be made with the Office of the Sheriff before the sale date.
Schedule of Distribution will be filed with the Office of the Sheriff no later than thirty (30) days
from sale date.
Exceptions to Distribution or a Petition to Set Aside the Sale must be filed with the Office of the
Sheriff no later than ten (10) days from the date when Schedule of Distribution is filed in the Office of the
Sheriff.
Attached hereto is a copy of the Writ of Execution. It has been issued because there is a judgment
against you. It may cause your property to be held or taken to pay the judgment. You may have legal
rights to prevent your property from being taken. A lawyer can advise you more specifically of these
rights. If you wish to exercise your rights you must act promptly.
YOU SHOULD TAKE THIS NOTICE AND THE WRIT OF EXECUTION 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 ADVICE.
CUMBERLAND COUNTY BAR ASSOCIATION
2 LIBERTY AVENUE
CARLISLE, PA 17013
(717) 249-3166
You may have legal rights to prevent the Sheriffs Sale and the loss of your property. In order to
exercise those rights, prompt action on your part is necessary. A lawyer may be able to help you.
You may have the right to prevent or delay the Sheriffs Sale by filing, before the sale occurs, a
petition to open or strike the judgment or a petition to stay the execution.
If the judgment was entered because you did not file with the Court any defense or objection you
might have within twenty (20) days after service of the Complaint for Mortgage Foreclosure and Notice
to Defend, you may have the right to have the judgment opened in you promptly file a petition with the
Court alleging a valid defense and a reasonable excuse for failing to file the defense on time. If the
judgment is opened, the Sheriffs Sale would ordinarily be delayed pending a trial of the issue of whether
the Plaintiff has a valid claim to foreclose the Mortgage.
You may also have the right to have the judgment stricken if the Sheriff has not made a valid return
of service of the Complaint and Notice to Defend or if the judgment was entered before twenty (20) days
after service or in certain other events. To exercise this right, you would have to file a petition to strike the
judgment.
You may also have the right to petition the Court to stay or delay the execution and the Sheriffs
Sale if you can show a defect in the Writ of Execution or service or demonstrate any other legal or
equitable right.
You may also have the right to have the Sheriffs Sale set aside if the property is sold for a grossly
inadequate price or if there are defects in the Sheriffs Sale. To exercise this right, you should file a petition
with the Court after the sale and before the Sheriff has delivered his Deed to the property. The Sheriff will
deliver the Deed if no petition to set aside the sale is filed within ten (10) days from the date when the
Schedule of Distribution is filed in the Office of the Sheriff.
Attorney for Plaintiff
916 Fifth Avenue
Pittsburgh, PA 15219
(412) 281-1725
Lo Vitti, Esquire
"THE DEBT COLLECTOR IS ATTEMPTING TO COLLECT A DEBT AND ANY
INFORMATION OBTAINED WILL BE USED FOR THAT PURPOSE."
IN THE COURT OF COMMON PLEAS OF CUMBERLAND COUNTY, PENNSYLVANIA
NATIONAL CITY MORTGAGE CO.,
Plaintiff,
CIVIL DIVISION
NO.: 2002-1422
AFFIDAVIT OF SERVICE
vs.
ROBERT C. MULLIS and ANGELA L.
MULLIS
Code MORTGAGE FORECLOSURE
Defendants.
Filed on behalf of
Plaintiff
Counsel of record for this
party:
Louis P. Vitti, Esquire
PA I.D. #3810
Supreme Court #01072
Louis P. Vitti & Assoc., P.C.
916 Fifth Avenue
Pittsburgh, PA 15219
(412) 281-1725
IN THE COURT OF COMMON PLEAS OF CUMBERLAND COUNTY, PENNSYLVANIA
CIVIL DIVISION
NATIONAL CITY MORTGAGE CO., ) NO.02-1422 CIVIL TERM
Plaintiff, )
VS. )
ROBERT C. MULLIS and ANGELA L. MULLIS)
Defendant. )
I, Helen Boyce, do hereby certify that a Notice of Sale has been served upon the
Defendant on May 16, 2002 by the sheriff of Cumberland County and all Lien Holders, by
Certificate of Mailing, for service in the above-captioned case on May 9, 2002, advising them
of the Sheriff's sale of the property at 42 Liberty Ave, Mount Holly Springs, PA 17065, on
September 4, 2002.
LOUIS P. VITTI & ASSOCIATES, P.C.
BY
SWORN to and subscribed
before me this 31st day
of July, 2002.
Eb
Notary Public
Notarial Seal
Theresa S'+, (k, Notary Publio
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Hamner s ennsvNania Association of Notaries
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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 National City Mtg Co is the grantee the same having been sold to said
grantee on the 5th day of Sept A.D., _ )2002, under and by virtue of a writ Execution issued on the 10th
day of May, A.D., ?002, out of the Court of Common Pleas of said County as of Civil Tenn, 2002
Number 1422, at the suit of National City Mtg Co against Robert C Mullis & Angela L is duly recorded
in Sheriff's Deed Book No. 253, Page 3277.
IN TESTIMONY WHEREOF, I have hereunto set my hand
2-0
and seal of said office thi: h day of Sept, A.D. 2002.
- ?o
Recorder of Deeds
National City Mortgage Co.
VS
Robert C. Mullis and
Angela L. Mullis
In The Court of Common Pleas of
Cumberland County, Pennsylvania
Writ No. 2002-1422 Civil Term
Kenneth Gossert, Deputy Sheriff, who being duly sworn according to law, states
that on May 16, 2002 at 3:05 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: Robert C. Mullis, by making known unto Angela L. Mullis, adult in
charge, at 42 Liberty Drive, Mt. Holly Springs, Cumberland County, Pennsylvania, its
contents and at the same time handing to her personally the said true and correct copy of
the same.
Kenneth Gossert, Deputy Sheriff, who being duly sworn according to law, states
that on May 16, 2002 at 3:05 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. Mullis, by making known unto Angela L. Mullis personally
at 42 Liberty Drive, Mt. Holly Springs, Cumberland County, Pennsylvania, its contents
and at the same time handing to her personally the said true and correct copy of the same.
Timothy Reitz, Deputy Sheriff, who being duly sworn according to law, states
that on July 3, 2002 at 8:57 o'clock P.M., he posted a true copy of the within Real Estate
Writ, Notice, Poster and Description, in the above entitled action, upon the property of
Robert C. Mullis and Angela L. Mullis located at 42 Liberty Drive, Mt. Holly Springs,
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: Robert C. Mullis, by regular mail to his last known address of 42
Liberty Drive, Mt. Holly Springs, PA 17065. This letter was mailed under the date of
July 09, 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: Angela L. Mullis, by regular mail to her last known address of 42
Liberty Drive, Mt. Holly Springs, PA 17065. This letter was mailed under the date of
July 09, 2002 and never returned to the Sheriff's Office.
R. Thomas Kline, Sheriff, who being duly sworn according to law, says that after
due and legal notice had been given according to law, exposed the within described
premises at public venue or outcry at the Court House, Carlisle, Cumberland County,
Pennsylvania, on September 5, 2002 at 10:00 o'clock A.M. He sold the same for the sum
of $1.00 to Attorney Louis P. Vitti for National City Mortgage Co. It being the highest
bid and best price received for the same, National City Mortgage Co of 3232 Newmark
Drive, Miamisburg, OH 45342, being the buyer in this execution paid Sheriff R. Thomas
Kline, the sum of $752.49, it being costs.
Sheriff's Costs:
Docketing $30.00
Poundage 14.75
Posting Bills 15.00
Advertising 15.00
Acknowledging Deed 30.00
Auctioneer 10.00
Law Library .50
Prothonotary 1.00
Service 9.66
Certified Mail 4.93
Levy 15.00
Surcharge 30.00
Law Journal 284.00
Patriot News 212.95
Share of Bills 25.20
Distribution of
Proceeds 25.00
Sheriff's Deed 29.50
$752.49 paid by attorney
09/06/02
Sworn and subscribed to before me
SO s s:
This ddayof
2002, A.D. CIII?IR R. Thomas Kline, Sheriff
Prothonotary
BY e) j, 36'11(t6
Real Estate Deputy
u?
3a' ti,
3$09
1.yje-
IN THE COURT OF COMMON PLEAS OF CUMBERLAND COUNTY, PENNSYLVANIA
CIVIL DIVISION
NATIONAL CITY MORTGAGE CO., ) NO.: 02-1422 Civil Tenn
Plaintiff, )
)
VS.
ROBERT C. MULLIS and ANGELA L. MULLIS, )
Defendants. )
AFFIDAVIT PURSUANT TO RULE 3129.1
National City Mortgage Co., Plaintiff in the above action, sets forth as of the date the Praecipe for the Writ
of Execution was filed the following information concerning the real property located at 42 Liberty Drive,
Mt. Holly Springs, PA 17065.
1. Name and address of Owner(s) or Reputed Owner(s):
Name: Address (Please indicate if this
cannot be reasonably ascertained)
Robert C. Mullis 42 Liberty Drive
Angela L. Mullis Mt. holly Springs, PA 17065
2. Name and address of Defendant(s) in the judgment:
Name: Address (Please indicate if this
cannot be reasonably ascertained)
Same as No. 1 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:
Address (Please indicate if this
cannot be reasonably ascertained)
None
4. Name and address of the last recorded holder of every mortgage of record:
Name Address (Please indicate if this
cannot be reasonably ascertained)
None
5. Name and address of every other person who has any record lien on the property:
Name Address (Please indicate if this
cannot be reasonably ascertained)
None
6. 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:
Name Address (Please indicate if this
cannot be reasonably ascertained)
None
7. Name and address of every other person of whom the Plaintiff has knowledge who has any
interest in the property which may be affected by the sale:
Name
Tax Collector of Mt. Holly Springs
Mt. Holly Springs Municipal
Commonwealth of PA -DPW
Clerk of Courts
Criminal/Civil Division
Court of Common Pleas of
Cumberland County
Domestic Relations Division
Address (Please indicate if this
cannot be reasonably ascertained)
Mable Satteson
3 Trine Ave
Mt Holly Springs, PA 17065
200 Harman Street
Mt. holly Springs, PA 17065
P.O. Box 8016
Harrisburg, PA 17105
One Courthouse Square
Carlisle, PA 17013
P.O. Box 320
Carlisle, PA 17013
Bureau of Compliance
Tenant/Occupant
Clearance Support Section
Dept. #281230
Harrisburg, PA 17128-1230
Attn: Susan Blough
42 Liberty Ave
Mt. Holly Springs, PA 17065
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 unworn falsification to authorities.
April 30 2002
Date
SWORN TO and subscribed
before me this 30th day
of April, 2002.
Notary Public
Louis P. Vitti, Esquire
Attorney for Plaintiff
Theresa Slwik, Nota l
Pittsburgh, Allephen
MyCommission Expiros ,,
Member, Pennsylvania As.
NOTICE OF SHERIFF'S SALE OF
REAL ESTATE PURSUANT TO
PENNSYLVANIA RULE OF CIVIL
PROCEDURE 3129.1
NATIONAL CITY MORTGAGE CO., ) NO.: 02-1422 Civil Tenn
Plaintiff, )
VS. )
ROBERT C. MULLIS and ANGELA L. MULLIS, )
Defendants. )
TO: Robert C. Mullis
Angela. L. Mullis
42 Liberty Drive
Mt. Holly Springs, PA 17065
AND: ALL LIEN HOLDERS
TAKE NOTICE that by virtue of the above Writ of Execution issued out of the Court of Common
Pleas of Cumberland County, Pennsylvania and to the Sheriff of Cumberland County, directed, there will
be exposed to Public Sale in Cumberland County Courthouse on September 4, 2002 at 10:00 A.M., the
following described real estate, of which Robert and Angela Mullis are owners or reputed owners:
The said Writ of Execution has issued on a judgment in the mortgage foreclosure action of National
City Mortgage Co., vs. Robert and Angela Mullis at No.: 02-1422 in the amount of $135,611.76.
Claims against property must be filed at the Office of the Sheriff before above sale date.
Claims to proceeds must be made with the Office of the Sheriff before the sale date.
Schedule of Distribution will be filed with the Office of the Sheriff no later than thirty (30) days
from sale date.
Exceptions to Distribution or a Petition to Set Aside the Sale must be filed with the Office of the
Sheriff no later than ten (10) days from the date when Schedule of Distribution is filed in the Office of the
Sheriff.
Attached hereto is a copy of the Writ of Execution. It has been issued because there is a judgment
against you. It may cause your property to be held or taken to pay the judgment. You may have legal
rights to prevent your property from being taken. A lawyer can advise you more specifically of these
rights. If you wish to exercise your rights you must act promptly.
YOU SHOULD TAKE THIS NOTICE AND THE WRIT OF EXECUTION 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 ADVICE.
CUMBERLAND COUNTY BAR ASSOCIATION
2 LIBERTY AVENUE
CARLISLE, PA 17013
(717) 249-3166
You may have legal rights to prevent the Sheriffs Sale and the loss of your property. In order to
exercise those rights, prompt action on your part is necessary. A lawyer may be able to help you.
You may have the right to prevent or delay the Sheriffs Sale by filing, before the sale occurs, a
petition to open or strike the judgment or a petition to stay the execution.
If the judgment was entered because you did not file with the Court any defense or objection you
might have within twenty (20) days after service of the Complaint for Mortgage Foreclosure and Notice
to Defend, you may have the right to have the judgment opened in you promptly file a petition with the
Court alleging a valid defense and a reasonable excuse for failing to file the defense on time. If the
judgment is opened, the Sheriffs Sale would ordinarily be delayed pending a trial of the issue of whether
the Plaintiff has a valid claim to foreclose the Mortgage.
You may also have the right to have the judgment stricken if the Sheriff has not made a valid return
of service of the Complaint and Notice to Defend or if the judgment was entered before twenty (20) days
after service or in certain other events. To exercise this right, you would have to file a petition to strike the
judgment.
You may also have the right to petition the Court to stay or delay the execution and the Sheriffs
Sale if you can show a defect in the Writ of Execution or service or demonstrate any other legal or
equitable right.
You may also have the right to have the Sheriffs Sale set aside if the property is sold for a grossly
inadequate price or if there are defects in the Sheriffs Sale. To exercise this right, you should file a petition
with the Court after the sale and before the Sheriff has delivered his Deed to the property. The Sheriff will
deliver the Deed if no petition to set aside the sale is filed within ten (10) days from the date when the
Schedule of Distribution is filed in the Office of the Sheriff.
Louis P. Vitti, Esquire
Attorney for Plaintiff
916 Fifth Avenue
Pittsburgh, PA 15219
(412) 281-1725
"THE DEBT COLLECTOR IS ATTEMPTING TO COLLECT A DEBT AND ANY
INFORMATION OBTAINED WILL BE USED FOR THAT PURPOSE."
IN THE COURT OF COMMON PLEAS OF CUMBERLAND COUNTY, PENNSYLVANIA
CIVIL DIVISION
NATIONAL CITY MORTGAGE CO.,
NO.: 02-1422 Civil Term
Plaintiff, )
vs. )
ROBERT C. MULLIS and ANGELA L. MULLIS, )
Defendants. )
LEGAL DESCRIPTION
All that certain tract of land situate in the Borough if Mount Holly Springs, Cumberland County,
Pennsylvania, bounded and described in accordance with a Plan Prepared by Walter N. Heine Associates,
Inc., dated December 8, 1989 and recorded in Plan Book 64, page 90, as follows:
Beginning at a point in Eastern right if way of Liberty Drive at comer of Lot No. 59 on said Plan; thence
along Lot No. 59, South 61 degrees 46 minutes 59, seconds East 277.38 feet to a point; thence South 1 e
degree 48 minutes 45 seconds East 125.00 feet to a point; thence along Lot No. 57 on said Plan, North
60 degrees 53 minutes 20 seconds West 357.13 feet to a point in Eastern right of way line of Liberty
Drive; thence along eastern right of way line of Liberty Drive, by a curve to the left having a radius of
262.64 feet and an arc length of 62.17 feet to a point; thence still along Eastern right of way line of Liberty
Drive North 15 degrees 32 minutes 53 seconds West 20.00 feet to a point, the place of beginning.
Containing.6056 acre and designated as Lot No. 58 on Plan of Liberty Woods.
Parcel# 23-35-2316-076
Being the same premises which Liberty Associates by their Deed dated 11/13/1998 and recorded on
02/04/1999 in the Recorder of Deeds Office in Cumberland County, Pennsylvania, in DBV 193, pg 977,
granted and conveyed unto Robert C. Mullis and Angela L. Mullis.
WRIT OF EXECUTION and/or ATTACHMENT
COMMONWEALTH OF PENNSYLVANIA)
-1422 L 02 Civil
COUNTY OF CUMBERLAND) CIVI
CI VIL ACTION - LAW
TO THE SHERIFF OF CUMBERLAND COUNTY:
To satisfy the debt, interest and costs due NATIONAL CITY MORTGAGE CO., Plaintiff (s)
From ROBERT C. MULLIS AND ANGELA L. MULLIS, 42 LIBERTY DRIVE, MT. HOLLY
SPRINGS, PA 17065
(1) You are directed to levy upon the property of the defendant (s)and to sell SEE LEGAL
DESCRIPTION.
(2) You are also directed to attach the property of the defendant(s) not levied upon in the possession
of
GARNISHEE(S) as follows:
and to notify the garnishee(s) that: (a) an attachment has been issued; (b) the garnishee(s) is enjoined from
paying any debt to or for the account of the defendant (s) and from delivering any property of the defendant
(s) or otherwise disposing thereof,
(3) If property of the defendant(s) not levied upon an subject to attachment is found in the possession
of anyone other than a named garnishee, you are directed to notify him/her that he/she has been added as a
garnishee and is enjoined as above stated.
Amount Due $135,611.76 L.L. $30
Interest $2,895.21
Any's Comm % Due Prothy $1.00
Any Paid $120.83
Other Costs
Plaintiff Paid
Date: MAY 10, 2002
CURTIS R. LONG
Prothonotary, Civil Division
REQUESTING PARTY:" d
Name LOUIS P. VITTI, ESQUIRE
Address: 916 FIFTH AVE.
PITTSBURGH, PA 15219
Attorney for: PLAINTIFF
Telephone: 412-281-1725
Supreme Court ID No. 3810
Real Estate Sale # 24
On May 13, 2002 the sheriff levied upon the
defendant's interest in the real property situated in
the Borough of Mt. Holly Springs, Cumberland County, PA
known and numbered as 42 Liberty Drive, Mt. Holly
Springs, more frilly described on Exhibit "A" filed
with this writ and by this reference incorporated herein.
Date: May 13, 2002
By: Je d?k/ S
/rya r° & /a it bqv?v
0
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0
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. 24
Writ No. 2002-1422 Civil
National City Mortgage Co.
VS.
Robert C. Mullis and
Angela L. Mullis
Atty.: Louis P. Vitti
LEGAL DESCRIPTION
All that certain tract of land situ-
ate in the Borough if Mount Holly
Springs. Cumberland County, Penn-
sylvania, bounded and described in
accordance with a Plan prepared by
Walter N. Heine Associates, Inc.,
dated December 8, 1989 and re-
corded in Plan Book 64, page 90,
as follows:
Beginning a; a poiurL in Eabiern
right if way of Liberty Drive at cor-
ner of Lot No. 59 on said Plan:
thence along Lot No. 59, South 61
degrees 46 minutes 59, seconds
East 277.88 feet to a point; thence
South 17 degree 48 minutes 45 sec-
Rog M. Morgenthal, Editor
SWORN TO AND SUBSCRIBED before me this
9 day of AUGUST, 2002
NOTiAW16BAL
LOIS E. SNYDEPs Notary
Cale Boron cwlberlarw Public
courdy
W Qwffilssim Exphes Minch 55, 2005
onds East 125.00 feet to a point;
thence along Lot No. 57 on said
Plan, North 60 degrees 53 minutes
20 seconds West 357.13 feet to a
point in Eastern right of way line of
Liberty Drive; thence along eastern
right of way line of Liberty Drive,
by a curve to the left having a ra-
dius of 262.64 feet and an are
length of 62.17 feet to a point;
thence still along Eastern right of
way line of Liberty Drive North 15
degrees 32 minutes 53 seconds
West 20.00 feet to a point, the place
of beginning.
Containing .6056 acre and des-
ignated as Lot No. 58 on Plan of
Liberty Woods.
Parcel #23-35-2316-076.
Being the same premises which
Liberty Associates by their Deed
dated 11/13/1998 and recorded on
02/04/1999 in the Recorder of
Deeds Office in Cumberland Coun-
ty, Pennsylvania, in DBV 193, pg
977, granted and conveyed unto
Robert C. Mullis and Angela L. Mullis.
?f
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 verity 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. r y
PUBLICATION
. ......................................................................
. /........ :.:.:
COPY .
Sworn to and subscribed bef r jktfsl14th day of'At?q 002 A.D.
.•?r`
SALE #24 Notarial Sealo ;
` .
Terry L. Russell, Notary Public All
REAL ESTATE SALE No. 24 City Of Harrisburg, Dauphin County
Writ No. 2002-7422 My Commission Expires June 6, 2006 NOTARY PUBLIC
CIvII Term
National City Mortgage Co.
Member. Pennsylvania Association Of NotariesMy commission expires June 6, 2006
vs
Robert C. Mullis and
Angela L. Mullis CUMBERLAND COUNTY SHERIFFS OFFICE
Atty: Louis P. Vittl CUMBERLAND COUNTY COURTHOUSE
DESCRIPTION
ALL that certain tract of land situate in the CARLISLE, PA. 17013
Borough of Mount Holly Springs, Cumberland
County, Pennsylvania, bounded and described in
ith a Plan prepared by Walter N.
d
Statement of Advertising Costs
ance w
accor
Heine Associates, Inc., dated December 9, 1989
and recorded in Plan Book 64, page
To THE PATRIOT-NEWS CO., Dr.
follows:
t in Eastern right of way
i For publishing the notice or publication attached
n
BEGINNING at a po
of Liberty Drive at comer of Lot No. 59 on said $ 211.20
hereto on the above stated dates
Plan; thence along Lot No. 59, South 61 degrees Probating same Notary Fee(s) $ 1.75
46 minutes 59 seconds East 277.88 feet to a
uth 17 degrees 48 minutes 45
S Total $ 21 2.95
o
point; thence
seconds East 125.00 feet to a point; thence along
North 60 degrees 53
id Plan
,
Lot No. 57 on sa
minutes 20seconds west357.13feet toapoint in 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 acknowledge receipt of the aforesaid notice and publication costs and certifies that the same have
been duly paid.
r,astcn right of way line of Liberty Dive, thence
elong eastern right of way line of Liberty Drive.
)N a curve to the left having a radius of 262.64
feet and an arc length of 62.17 feet to a point;
thence still along Eastern right of way line of
Liberty Drive North f5 degrees 32 minutes 53
seconds West 20.00 feet to a point, the place of
beginning.
Containing .6056 acres and designated as Lot No.
58 on plan of Liberty Woods.
Parcel IC23-35-^_t16-076.
By........
the same premises which Liberty
Being
A d
Associates by their Deed dated 11113/1998 an
recorded on 0210411999 m t h e RPennsylvania Deeds
Office in C 977 County, conveyed unto
DBV bert page obert G Mullis and Angela L. Mullis.
Ro