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HomeMy WebLinkAbout02-1528FEDERMAN 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 (2 5) s~~_~ooo MORTGAGE ELECTRONIC REGISTRATION SYSTEMS, INC 8201 GREENSBORO DRNE, SUITE 350 MCLEAN, VA 22102 v. Plaintiff KATHY L. DIPATRIZIO 56 OLNER ROAD ENOLA, PA 17025 Defendant(s) TERM ATTORNEY FOR PLAIN'T'IFF COURT OF COMMON PLEAS CNIL DNISION NO. Qa _ ~J Z~ CUMBERLAND COUNTY **THIS FHtM 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 REAFFHtMED, 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 maybe 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 #: 5935058569 IF THIS I3 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 MORTGAGE ELECTRONIC REGISTRATION SYSTEMS, INC 8201 GREENSBORO DRNE, SUITE 350 MCLEAN, VA 22102 2. Plaintiff, is or will be, the owner of legal title to the mortgage that is the subject of this action, and nominee for the entity indicated below, which is the owner of the entire beneficial interest in the mortgage: WASHINGTON MUTUAL BANK 75 NORTH FAIRWAY DRNE VERNON HILLS, IL 60061 3. The name(s) and last known address(es) of the Defendant(s) are: KATHY L. DIPATRIZIO 56 OLNER ROAD ENOLA, PA 17025 who is/are the mortgagor(s) and real owner(s) of the property hereinafter described. 4. On 12/31/97 mortgagor(s) made, executed and delivered a mortgage upon the premises hereinafter described to ACCUBANC MORTGAGE CORPORATION which mortgage is recorded in the Office of the Recorder of CUMBERLAND County, in Mortgage Book No. 1425, Page 323. By Assignment of Mortgage recorded 7/19/99 the mortgage was assigned to PLAINTIFF which Assignment is recorded in Assignment of Mortgage Book No. 619, Page 517. 5. The premises subject to said mortgage is described as attached. 6. The mortgage is in default because monthly payments of principal and interest upon said mortgage due 11/1/O1 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. 7, The following amounts are due on the mortgage: Principal Balance $68,731.96 Interest 2,103.68 10/1/O1 through 3/1/02 (Per Diem $13.84) Attorney's Fees 1,250.00 Cumulative Late Charges 122.27 12/31/97 to 3/1/02 Cost of Suit and Title Search Ssn no Subtotal $72,757.91 Escrow Credit 0.00 Deficit llLLtt Subtotal $_LQ1.1L TOTAL $72,859.02 8. 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. 9. 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 $72,859.02, together with interest from 3/1/02 at the rate of $13.84 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. By. F~RMAN A~I~p PHELAN, LLP FRANK FEDERMAN, ESQUIRE LAWRENCE T. PHELAN, ESQUIItE FRANCIS S. HALLINAN, ESQUIltE Attorneys for Plaintiff All that certain lot or piece of ground with the buildings and improvements thereon erected, being known as 56 OLIVER ROAD, and being further described on that certain Deed dated 12/31/97and recorded 1/6/98 in the Office of the Recorder of Deeds in CUMBERLAND County in Deed Book No. 170, Page 377. BEING known as 56 OLIVER ROAD VERIFICATION KAREN BATT hereby states that he is VICE PRESIDENTof WASHINGTON MUTUAL BANK, F.A.. mortgage servicing agent for Plaintiff in this matter, that he is authorized to take this Verification, and that the statements made in the foregoing Civil Action 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 unswom falsification to authorities. DATE:./Z~/QZ '.1~1~~~. ~ r~ ~-, ,~~'J' ~' ©` ~ CT I V -i-~ V r ,.. QQ `` ~ m~ i '''~ r __ V~ _ '\ ~ ~ ~ 4 1 ~~ O ~ C_ -: `j\VV n r•.~ ~: r~ -_ ~- v '~ -~ f ~~ SHERIFF'S RETURN - REGULAR CASE NO: 2002-01528 P COMMONWEALTH OF PENNSYLVANIA: COUNTY OF CUMBERLAND MORTGAGE ELECTRONIC REGISTRATI VS DIPATRIZIO KATHY L BRYAN WARD Sheriff or Deputy Sheriff of Cumberland County,Pennsylvania, who being duly sworn according to law, says, the within COMPLAINT - MORT FORE was served upon DIPATRIZIO KATHY the DEFENDANT at 1447:00 HOURS, on the 5th day of April 2002 at 56 OLIVER ROAD PA 17025 by handing to MOHAMAD DIPATRIZIO, HUSBAND 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 10.35 Affidavit .00 Surcharge 10.00 .00 38.35 Sworn and Subscribed to before mennthis ,2~ day of Prothonotary So Answers: R. Thomas Kline 04/09/2002 FEDERMAN & PHELAN By ~ ~~ , 9~ Deputy Sheriff FEDERMAN AND PHELAN By: Frank Federman, Esquire, ID. No. 12248 Lawrence T. Phelan, Esquire, ID. No. 32227 Francis S. Hallinan, Esquire, ID. No. 62695 One Penn Center at Suburban Station Suite 1400 Philadelphia, PA 19103-1814 (215) 563-7000 Attorney for Plaintiff MORTGAGE ELECTRONIC REGISTRATION SYSTEMS, INC. Plaintiff Court of Common Pleas CUMBERLAND County mss, No. 02-1528-CIVIL KATHY L. DIPATRIZIO Defendant(s) PRAECIPE TO SUBSTITUTE LEGAL DESCRIPTION TO THE PROTHONOTARY: Kindly substitute the attached legal description for the legal description originally filed with the complaint in the instant matter. Date Frank Federman, Esquire Lawrence T. Phelan, Esquire Francis S. Hallinan, Esquire Attorneys for Plaintiff ALL THAT CERTAIN tract of land situate in East Pennsboro Township, County of Cumberland and Commonwealth of Pennsylvania, more particularly bounded an described as follows, to wit: BEGINNING at a hub on the Southwest side of Oliver Road (50 feet wide) at the corner of lands now or formerly of Earl W. Reidell, being Lot No. », said point being measured along the said side of Oliver Road, 490.96 feet to the intersection with the Southeast side of Louis Lane North: thence e~ctending from said point of beginning and along the said side of Oliver Road, South 46 degrees 00 minutes East, the distance of 64 feet to a hub at the comer of lands now or formerly of Harry R. Crossland, being Lot No. 57; thence along lands now or formerly of Harry R. Crossland, South 44 decrees 00 minutes West, the distance of 100 feet to a p.k. nail at the corner of lands now or forterly of Administrator of Veterans Affairs; thence along lands now or formerly of Administrator of Veterans Affairs, North 46 degrees 00 minutes West, the distance of 64 feet to a hub at the corner of lands now or formerly of Earl W. Reidell; thence along lands now or formerly of Earl W. Reidell, North 4-1 decrees 00 minutes East, the distance of 100 feet to a point, the place of BEGINNING. BEING Lot No. 56 on the Plan of Louis Park, recorded in the Cumberland County Recorder of Deeds Office in Plan Book 5, Page 50. HAVING THEREON ERECTED a residential family style dwelling house known and numbered as 56 Oliver Road, Enola, Pennsylvania. TAB PARCEL NUMBER: 1?-299-041 ~ ~ O -n .~ u, ~ -_a rt-i n : Z .T -~ -'; i ~ r CA ~-- p ~~.. -IU ` ~ -~ i S -' C ~ j *_ ~~ C> -~ C 7 y. ~ ca v r-n 2 ~ ~ cn ~ FEDERMAN AND PHELAN, LLP By: FRANK FEDERMAN IdentiIIcation 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 MORTGAGE ELECTRONIC REGISTRATION SYSTEMS, INC. CUMBERLAND COUNTY 8201 GREENSBORO DRIVE, SUITE 350 COURT OF COMMON PLEAS MCLEAN, VA 22102 v. Plaintiff, CIVIL DIVISION NO. 02-1528-CIVIL KATHY L. DIPATRIZIO Defendant(s). PRAECIPE FOR JUDGMENT FOR FAILURE TO ANSWER AND ASSESSMENT OF DAMAGES TO THE PROTHONOTARY: Kindly enter judgment in favor of the Plaintiff and against KATHY L. DIPATRIZIO, 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 Interest from 3/2/02 to 5/7/02 TOTAL $72,859.02 $927.28 $73,786.30 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. kKANK FE ERMAN, ESQUIltE Attorney for~laintiff DAMAGES ARE HEREBY ASSESSED AS INDICATED. DATE: ~,~ C~~C,(n.~l/~/ PRO PROTHY ~ c> r c-_ r~ ~~ - ' '-< ._,; 7 ~.. ~ CA -r -J -<.:! f~C_": T .C -- _ ~ ,' 1 .x -" J ,~- ` r O _~~ ~t {~.: rr3 ;t7 ~. y[ ,_n r(J (_~, n -1 -G G- FEDERMAN AND PHELAN BY: FRANK FEDERMAN, ESQUIRE Attorney for Plaintiff Identification No. 12248 1617 John F. Kennedy Boulevard Suite 1400 Philadelphia, PA 19103-1814 1215~s~~_7nnn MORTGAGE ELECTRONIC REGISTRATION SYSTEMS, INC. Plaintiff vs. KATHY L. DIPATRIZIO COURT OF COMMON PLEAS CIVIL DIVISION CUMBERLAND COUNTY N0. 02-1528 Defendant(s) TO: KATHY L. DIPATRIZIO 56 OLIVER ROAD ENOLA, PA 17025 DATE OF NOTICE: APRIL 26. 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. 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 COLJN'tY BAR ASSOCIATION 2 LIBERTY AVENUE CARLISLE, PA 17013 (717) 249-3166 Frank Federman, Esquire Attorney for Plaintiff 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 (2151563-7000 MORTGAGE ELECTRONIC REGISTRATION SYSTEMS, INC. 8201 GREENSBORO DRIVE, SUITE 350 Plaintiff, v. KATHY L. DIPATRIZIO Defendant(s). ATTORNEY FOR PLAINTIFF CUMBERLAND COUNTY COURT OF COMMON PLEAS CIVIL DIVISION N0.02-1528-CIVIL VERIFICATION OFNON-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 KATHY L. DIPATRIZIO is over 18 years of age and resides at , 56 OLIVER ROAD, ENOLA, PA 17025 . This statement is made subject to the penalties of 18 Pa. C.S. Section 4904 relating to unsworn falsification to authorities. FRANK FE ERMAN, ESQUIRE Attorney for laintiff (Rule of Civil Procedure No. 236) -Revised IN THE COURT OF COMMON PLEAS OF CUMBERLAND COUNTY, PENNSYLVANIA CIVIL ACTION -LAW MORTGAGE ELECTRONIC REGISTRATION SYSTEMS, INC. 8201 GREENSBORO DRIVE, SUITE 350 CUMBERLAND COUNTY COURT OF COMMON PLEAS Plaintiff, v. KATHY L. DIPATRIZIO Defendant(s). CIVIL DIVISION NO. 02-1528-CIVIL Notice is given that a Judgment in the above-captioned matter has been entered against you on 200 By. / `~! EPUTY If you have any questions concerning this matter, please contact: (((/// FRANK FEDERMAN ESQUIRE Attorney for Plaintiff ONE PENN CENTER AT SUBURBAN STATION 1617 JOHN E KENNEDY BLVD., SUITE 1400 PHILADELPHIA, PA 19103-1814 (215) 563-7000 **THIS FIRM IS A DEBT COLLECTOR ATTEMPTING TO COLLECT A DEBT AND ANY INFORMATION OBTAINED WILL BE USED FOR THAT PURPOSE. IF YOU 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.** J A _~ e~ \ J ~~ ~ c ~, C7~1 ~. i C ~: r-. t~ - ~..~ ~; _ m ~= G ~ -~ _. J G: (_1 f ~ -- C.) ' N ~-n % t_... ~ ~ ... -< PRAECIPE FOR WRIT OF EXECUTION -(MORTGAGE FORECLOSURE) P.R.C.P.3180-3183 MORTGAGE ELECTRONIC REGISTRATION SYSTEMS, INC. Plaintiff, . v' No.02-1528-CIVIL KATHY L. DIPATRIZIO Defendant(s). TO THE DIRECTOR OF THE OFFICE OF THE PROTHONOTARY: Issue writ of execution in the above matter: Amount Due $73,786.30 Interest from 5/7/02 to 9/4/02 (per diem -$12.13) $ 1,455.60 and Costs TOTAL $75,241.90 RANK FED RMAN, ESQUIRE ne Penn Center at Suburban Station 1617 John F. Kennedy Boulevard, Suite 1400 Philadelphia, PA 19103-1814 Attorney for Plaintiff Note: Please attach description ofproperty.No. y w~a oz~ d a U a~ ~"~ h z~ o~ ~a HH w ~' ~~ Wz pp ~O as ~~ N o~ ~~ F ~ ~~ U O N .p", A .a z iC w 0 w a U a N s d 0 W ec ego 0 L7r N N O r .. d a a W ~° ~ d ° T a w ~ d a G d n ~ o C' ~ VV T7 "T7 L~' [~ r --. =cv -i ; ..~ i. T ` <n -.J ' r~ C. -~ - "try ~- ~ -f_: _ ..x .~~i~ -I - ~ .A . cn , ALL THAT CERTAIN tract of land situate in East Pennsboro Township, County of Cumberland and Commonwealth of Pennsylvania, more particularly bounded an described as follows, to wit: BEGINNING at a hub on the Southwest side of Oliver Road (50 feet wide) at the corner of lands now or formerly of Eazl W. Reidell, being Lot No. 55, said point being measured along the said side of Oliver Road, 490.96 feet to the intersection with the Southeast side of Louis Lane North; thence extending from said point of beginning and along the said side of Oliver Road, South 46 degrees 00 minutes East, the distance of 64 feet to a hub at the corner of lands now or formerly of Harry R. Crossland, being Lot No. 57; thence along lands now or formerly of Harry R. Crossland, South 44 degrees 00 minutes West, the distance of 100 feet to a p.k. nail at the corner of lands now or formerly of Administrator of Veterans Affairs; thence along lands now or formerly of Administrator of Veterans Affairs, North 46 degrees 00 minutes West, the distance of 64 feet to a hub at [he corner of lands now or formerly of Earl W. Reidell; thence along lands now or formerly of Earl W. Reidell, North 44 degrees 00 minutes East, the distance of 100 feet to a point, the place of BEGINNING. BEING Lot No. 56 on the Plan of Louis Park, recorded in the Cumberland County Recorder of Deeds Office in Plan Book 5, Page 50. HAVING THEREON ERECTED a residential family style dwelling house known and numbered as 56 Oliver Road, Enola, Pennsylvania. TAX PARCEL NUMBER: 12-2992-041 TITLE TO SAID PREMISES IS VESTED IN Kathy L. Dipatrizio by Deed from Barry L. Woods, single man dated 12/31/1997 and recorded 1/6/1998 in Deed Book 170 Page 377. BEING KNOWN AS: 56 OLIVER ROAD ENOLA, PA 17025 - [~ `\~~/ %> ^' e -f _. ~_ "_.~ ~ .~ m 1 -..J ( ~ 7 -'C_ N m u7 r ~ (/ ^ (S1 ~ U ~ ~ ~ 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 MORTGAGE ELECTRONIC REGISTRATION SYSTEMS, INC. Plaintiff, v. KATHY L. DIPATRIZIO Defendant(s). ATTORNEY FOR PLAINTIFF CUMBERLAND COUNTY COURT OF COMMON PLEAS CIVIL DIVISION NO. CERTIFICATION 02-1528-CIVIL FRANK FEDERMAN, ESQUIRE, hereby verifies that he is attorney for the Plaintiff in the above-captioned matter, and that the premises aze not subject to the provisions of Act 91 because it is: (X) an FHA mortgage () non-owner occupied () vacant Q Act 91 procedures have been fulfilled This certification is made subject to the penalties of 18 Pa. C.S. Section 4904 relating to unswom falsification to authorities. ~~~,'~/ RANK FE ERMAN, ES/ V Q Attorney for laintiff c> ca ~ c_' rv ,a " L-_ °~. ~ ~ -In Cn7-- .~ ,.7 t7 r ' _1 c`~ ~" -~ r ~~ C ~ J R'i ~ 1 ...a C17 MORTGAGE ELECTRONIC REGISTRATION SYSTEMS, INC. v. Plalntiff, KATHY L. DIPATRIZIO Defendant(s). CUMBERLAND COUNTY COURT OF COMMON PLEAS CIVIL DIVISION N0.02-1528-CIVIL AFFIDAVIT PURSUANT TO RULE 3129 (Affidavit No. l) MORTGAGE ELECTRONIC REGISTRATION SYSTEMS INC., 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 ,56 OLIVER ROAD, ENOLA. PA 17025 1. Name and address of Owner(s) or reputed Owner(s): Name KATHY L. DIPATRIZIO Last Known Address (if address cannot be reasonably ascertained, please indicate) 56 OLIVER ROAD ENOLA, PA 17025 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) 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) NORTHWEST CONSUMER DISCOUNT 4813 JONESTOWN ROAD, SUITE 107 COMPANY HARRISBURG, PA 17109 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 maybe affected by the sale. Name EAST PENNSBORO TOWNSHIP Last Known Address (if address cannot be reasonably ascertained, please indicate) 98 S. ENOLA DRIVE ENOLA, PA 17025 DANIEL G. DIPATRIZIO 56 OLIVER ROAD ENOLA, PA 17025 7. Name and address of every other person of whom the plaintiff has knowledge who has any interest in the property which maybe affected by the sale: Name TenanUOccupant Last Known Address (if address cannot be reasonably ascertained, please indicate) 56 OLIVER ROAD ENOLA, PA 17025 Domestic Relations of Cumberland County Commonwealth of Pennsylvania Department of Welfare 13 North Hanover Street Carlisle, PA 17013 PO Box 2675 Harrisburg, PA 17105 I verify that the statements made in this affidavit aze true and con•ect 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 unsworn falsification to authorities. MAY 7. 2002 DATE FRANK FE ERMAN, ESQUIRE Attorney for Plaintiff r .: C'7 ~~ O C.: N -n "" l;' :C~ ~! T G"> ' y •-e ~' . i j Y' '" 't !V :~~~~ . ., t ~ <n ~ MORTGAGE ELECTRONIC REGISTRATION SYSTEMS, INC. Plaintiff, v. KATHY L. DIPATRIZIO Defendant(s). CUMBERLAND COUNTY No.02-1528-CIVIL MAY 7, 2002 TO: KATHY L. DIPATRIZIO 56 OLIVER ROAD ENOLA, PA 17025 "TH/S F/RM /S A DEBT COLLECTOR ATTEMPTING TO COLLECT A DEBT AND ANY /NFORMAT/ON OBTA/NED WILL BE USED FOR THAT PURPOSE. IF YOU HAVE PREVIOUSLY RECEIVED A D/SCHARGE /N BANKR UPTCYAND THIS DEBT WAS NOT REAFFIRMED, THIS /S NOT AND SHOULD NOT BE CONSTRUED TO BE ANATTEMPT TO COLLECT A DEBT, BUT ONLY ENFORCEMENT OFA LIENAGAINST PROPERTY. "' Your house (real estate) at ~OLIVER ROAD ENOLA PA 17025 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, Cazlisle, PA 17013, to enforce the court judgment of 73 786.30 obtained by MORTGAGE ELECTRONIC REGISTRATION SYSTEMS INC. (the mortgagee) against you. In the event the sale is continued, an announcement will be made at said sale in compliance with Pa.R.C.P., Rule 3129.3. NOTICE OF OWNER'S RIGHTS YOU MAYBE ABLE TO PREVENT THIS SHERIFF'S SALE To prevent this Sheriffs Sale, you must take immediate action: 1. The sale will be cancelled if you pay to the mortgagee the back payments, late chazges, costs and reasonable attorney's fees due. To find out how much you must pay, you may call: (2151563-7000. 2. You maybe 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 attomey to assert your rights. The sooner you contact one, the more chance you will have of stopping the sale. (See notice on page two on how to obtain an attomey.) YOU MAY STILL BE ABLE TO SAVE YOUR PROPERTY AND YOU HAVE OTHER RIGHTS EVEN IF THE SHERIFF'S SALE DOES TAKE PLACE. 1. If the Sheriffs Sale is not stopped, your property will be sold to the highest bidder. You may find out the price bid by calling (2151563-7000. 2. You maybe able to petition the Court to set aside the sale if the bid price was grossly inadequate compazed 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) aze 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 East Pennsboro Township, County of Cumberland and Commonwealth of Pennsylvania, more particularly bounded an described as follows, to wit: BEGINNING at a hub on the Southwest side of Oliver Road (50 feet wide) at the corner of lands now or formerly of Earl W. Reidell, being Lot No. 55, said point being measured along the said side of Oliver Road, 490.96 feet to the intersection with the Southeast side of Louis Lane North; thence extending from said point of beginning and along the said side of Oliver Road, South 46 degrees 00 minutes East, the distance of 64 feet to a hub at the corner of lands now or formerly of Harry R. Crossland, being Lot No. 57; thence along lands now or formerly of Harry R. Crossland, South 44 degrees 00 minutes West, the distance of 100 feet to a p.k. nail at the corner of lands now or formerly of Administrator of Veterans Affairs; thence along lands now or formerly of Administrator of Veterans Affairs, North 46 degrees 00 minutes West, the distance of 64 feet to a hub at the corner of lands now or formerly of Earl W. Reidell; thence along lands now or formerly of Earl W. Reidell, North 44 degrees 00 minutes East, the distance of 100 feet to a point, the place of BEGINNING. BEING Lot No. 56 on the Plan of Louis Park, recorded in the Cumberland County Recorder of Deeds Office in Plan Book 5, Page 50. HAVING THEREON ERECTED a residential family style dwelling house known and numbered as 56 Oliver Road, Enola, Pennsylvania. TAX PARCEL NUMBER: 12-2992-041 TITLE TO SAID PREMISES IS VESTED IN Kathy L. Dipatrizio by Deed from Barry L. Woods, single man dated 12/31/1997 and recorded 1/6/1998 in Deed Book 170 Page 377. BEING KNOWN AS: 56 OLIVER ROAD ENOLA, PA 17025 a c, - ~-, c . ~~ ,_ U: ... ..J __~` ;~ ~ 1 " N ~. f r~ C. J a -: ~n ~ WRIT OF EXECUTION and/or ATTACHMENT COMMONWEALTH OF PENNSYLVANIA) COUNTY OF CUMBERLAND) NO 02 -1528 CIVI CTL IACIVI CTL IA ONCILAW9-- TO THE SHERIFF OF _-rnnrtaFCr n ~-.___.____ __C OUN TY: To satisfy the debt, interest and costs due Mortgage_ Electronic Registration Irom - ------ -------- PLAINTIFF(S) --Kathy L~_1)e_natrizio, 56 Oliver Rd., -Enola PA 17025. (t) You are directed to levy upon the properly of the defendant(s) and to sell Real estatDeFlooate(d) 6-~}3~ 25. 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 lolbws: end to notify the garnishee(s) that: (a) an attachment has been issued; (b) the garnishee(s) is/are enjoined from debt to or for the account of the defendant(s) and from delivering any properly of the defendant(s) or otherwise disposing thereof; PeYin9 any (3) ItPropertyotthedetendant(s)rwtlevieduponansubjecttoattachmentistoundinlhe Thana namedgamishee, you are directedto notify hinVherthat he/she has been addedas a gamishee and is enjoined as above stated. Possessronotanyoneother Amount Due S73 , 786.30 Interest 5/7/02 - 9/4/02 51,455.60 Afrv'c (:nmr.. ' Any Paid 5110.35 Plaintiff Paid Date. ----- ----tom„ a~' _2_. 00 REQUESTING PARTY: Name ___Frank Fe--~an_ESg_ nddr ----- L.L. $ . 50 Due Prothy ____. $1, 0 0 Other Costs ___. CURTIS R Protho otary, Civil Division by . Deputy ess __ 1617 JFK Blvd. L_Ste_1400 Philadelphia__pp, 19103 Attorney Ior _ -- - ---- 1814 _ Plain 'fp -- Telephone: ---- Supreme Court ID No. --~ d R ,,~ ~ 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 (2151 563-7000 MORTGAGE ELECTRONIC REGISTRATION SYSTEMS, INC. 8201 GREENSBORO DRIVE, SUITE 350 MCLEAN, VA 22102 Plaintiff, v. CUMBERLAND COUNTY COURT OF COMMON PLEAS CIVIL DIVISION NO. 02-1528-CIVIL KATHY L. DIPATRIZIO Defendant(s). PRAECIPE FOR JUDGMENT FOR FAILURE TO ANSWER AND ASSESSMENT OF DAMAGES TO THE PROTHONOTARY: Kindly enter judgment in favor of the Plaintiff and against KATHY L. DIPATRIZIO, 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 Interest from 3/2/02 to 5/7/02 TOTAL $72,859.02 $927.28 $73,786.30 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. ~p 0~ n n RANK F ~ERMAN, ESQUIRE Attorney for Plaintiff DAMAGES ARE HEREBY ASSESSED AS INDICATED. DATE: ~~ C~~(.~~.~f/JJ o PRO PROTHY ~° . _ y ~"' ~ ~~ ° c ;, 'cis' tj f'~i;~ ~.r ~c -r-~ ~ C.fJ.' .J ~~ f -C -~ --~ ~ y *i fi f_~ t.: - "" C. N r. i_i ~ - ~_ -I c .T" '~ ' ~ FEDERMAN AND PHELAN BY: FRANK FEDERMAN, ESQUIRE Identification No. 12248 1617 John F. Kennedy Boulevard Suite 1400 Philadelphia, PA 19103-1814 (~~SF~-7nno MORTGAGE ELECTRONIC REGISTRATION SYSTEMS, INC. Plaintiff vs. KATHY L. DIPATRIZIO Defendant(s) TO: ItATHY L. DIPATRIZIO 56 OLIVER ROAD ENOLA, PA 17025 DATE OF NOTICE: APRIL 26. 2002 Attorney for Plaintiff COURT OF COMMON PLEAS CIVIL DIVISION CUMBERLAND COUNTY NO. 02-1528 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. 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 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 (2151563-7000 MORTGAGE ELECTRONIC REGISTRATION SYSTEMS, INC. 8201 GREENSBORO DRIVE, SUITE 350 CUMBERLAND COUNTY COURT OF COMMON PLEAS Plaintiff, v. KATHY L. DIPATRIZIO Defendant(s). CIVIL DIVISION N0.02-1528-CIVIL VERIFICATION OFNON-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 lrnowledge of the following facts, to wit: (a) that the defendant(s) is/aze 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 KATHY L. DIPATRIZIO is over 18 yeazs of age and resides at , 56 OLIVER ROAD, ENOLA, PA 17025 . This statement is made subject to the penalties of 18 Pa. C.S. Section 4904 relating to unsworn falsification to authorities. RANK FE ERMAN, ESQUIItE Attorney for laintiff (Rule of Civil Procedure No. 236) -Revised IN THE COURT OF COMMON PLEAS OF CUMBERLAND COUNTY, PENNSYLVANIA CIVIL ACTION -LAW MORTGAGE ELECTRONIC REGISTRATION SYSTEMS, INC. 8201 GREENSBORO DRIVE, SUITE 350 CUMBERLAND COUNTY COURT OF COMMON PLEAS Plaintiff, v. KATHY L. DIPATRIZIO Defendant(s). CIVIL DIVISION NO. 02-1528-CIVIL Notice is given that a Judgment in the above-captioned matter has been entered against you on 200 r By: ~ EPUTY If you have any questions concerning this matter, please contact: FRANK FEDERMAN. ESQUIRE Attorney for Plaintiff ONE PENN CENTER AT SUBURBAN STATION 1617 JOHN F. KENNEDY BLVD., SUITE 1400 PHILADELPHIA, PA 19103-1814 (215)563-7000 **THIS FIRM IS A DEBT COLLECTOR ATTEMPTING TO COLLECT A DEBT AND ANY INFORMATION OBTAINED WILL BE USED FOR THAT PURPOSE. IF YOU HAVE PREVIOUSLY RECEIVED A DISCHARGE IN BANKRUPTCY AND THIS DEBT WAS NOT REAFFIRMED, THIS CORRESPONDENCE IS NOT AND SHOULD NOT BE CONSTRUED TO BEAN ATTEMPT TO COLLECT A DEBT, BUT ONLY ENFORCEMENT OF A LIEN AGAINST PROPERTY.** J ~ C-v ?„t~ ~ ~ ~ ~, c-~ `\ I ~ ~ j~~ N Ufn ... C.r a ~ `` N PRAECIPE FOR WRIT OF EXECUTION - (MORTGAGE FORECLOSURE) P.RC.P. 3180-3183 MORTGAGE ELECTRONIC REGISTRATION SYSTEMS, INC. . Plaintiff, . v. No.02-1528-CIVIL KATHY L. DIPATRIZIO Defendant(s). TO THE DII2ECTOR OF THE OFFICE OF THE PROTHONOTARY: Issue writ of execution in the above matter: Amount Due $73,786.30 Interest from 5/7/02 to 9/4/02 $ 1,455.60 and Costs (per diem -$12.13) TOTAL $75,241.90 1Ld~M~~~ RANK FED RMAN, ESQUIRE ne 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. N O r w~a ox~. a~ a~' ~ °' v z zz z~; o~ a` W ~ ~ U ~+ o w~ z 00 0 ~~ F aA ~~ O F a w ~ ~ m W a H~ z~ "" U -~ F a A a F z 0 Y ~~ W ~ w_ o; H c ~w Ox w~ WQa W a w a 0 z ~ w ~ w ° a T w ~ O °~ N F y 'O c~ ~ ;~ C- N T7 ~a ~ ~ t.~i '^a~a~ ..... Lam., U? -.J r'~. - ~-'rI t7 -.-i ^ r -- te -:. (J'. r ', ALL THAT CERTAIN tract of land situate in East Pennsboro Township, County of Cumberland and Commonwealth of Pennsylvania, more particulazly bounded an described as follows, [o wit: BEGINNING at a hub on the Southwest side of Oliver Road (50 feet wide) at the corner of lands now or formerly of Earl W. Reidell, being Lot No. 55, said point being measured along the said side of Oliver Road, 490.96 feet to the intersection with the Southeast side of Louis Lane North; thence extending from said point of beginning and along the said side of Oliver Road, South 46 degrees 00 minutes East, the distance of 64 feet to a hub at the corner of lands now or formerly of Harry R. Crossland, being Lot No. 57; thence along lands now or formerly of Harry R. Crossland, South 44 degrees 00 minutes West, the distance of 100 feet to a p.k. nail at the corner of lands now or formerly of Administrator of Veterans Affairs; thence along lands now or formerly of Administrator of Veterans Affairs, North 46 degrees 00 minutes West, the distance of 64 feet to a hub at the corner of lands now or formerly of Earl W. Reidell; thence along lands now or formerly of Earl W. Reidell, North 44 degrees 00 minutes East, the distance of 100 feet to a point, the place of BEGINNING. BEING Lot No. 56 on the Plan of Louis Park, recorded in the Cumberland County Recorder of Deeds Office in Plan Book 5, Page 50. HAVING THEREON ERECTED a residential family style dwelling house known and numbered as 56 Oliver Road, Enola, Pennsylvania. TAX PARCEL NUMBER: 12-2992-041 TITLE TO SAID PREMISES IS VESTED IN Kathy L. Dipatrizio by Deed from Barry L. Woods, single man dated 12/31/1997 and recorded 1/6/1998 in Deed Book 170 Page 377. BEZNG KNOWN AS: 56 OLIVER ROAD ENOLA, PA 17025 `^~~'~_ 1 C `~ c~ ~ o rT~- ~ -, -- t{ 1 ~ "C~ i~ C_ .. .-i fii cr ~^ \ G 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 MORTGAGE ELECTRONIC REGISTRATION SYSTEMS, INC. v. Plaintiff, KATHY L. DIPATRIZIO Defendant(s). ATTORNEY FOR PLAINTIFF CUMBERLAND COUNTY COURT OF COMMON PLEAS CIVIL DMSION NO. 02-1528-CIVIL FRANK FEDERMAN, ESQUIRE, hereby verifies that he is attorney for the Plaintiff in the above-captioned matter, and that the premises aze not subject to the provisions of Act 91 because it is: (X) an FHA mortgage () non-owner occupied () vacant Q 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. i y~v a RANK FE ERMAN, ESQUII2E Attorney for Plaintiff c7 c~ ~-, C. ~~ -, =n ~ .~: ~.: `t ,r ~4 i i~ ~' .-~ ~- ~.. ti za --;~. .~; -; =c rv ; ri _ •• -=i -. cn -: MORTGAGE ELECTRONIC REGISTRATION SYSTEMS, INC. Plaintiff, v. KATHY L. DIPATRIZIO Defendant(s). N0.02-1528-CIVIL AFFIDAVIT PURSUANT TO RULE 3129 (Affidavit No. l) MORTGAGE ELECTRONIC REGISTRATION SYSTEMS, INC., 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 ,56 OLIVER ROAD, ENOLA, PA 17025 . 1. Name and address of Owner(s) or reputed Owner(s): Name KATHY L. DIPATRIZIO Last Known Address (if address cannot be reasonably ascertained, please indicate) 56 OLIVER ROAD ENOLA, PA 17025 2. Name and address of Defendant(s) in the judgment: Same as above 3. Name and last lmown address of every judgment creditor whose judgment is a record lien on the real property to be sold: Name Last Known Address (if address cannot be reasonably ascertained, please indicate) None CUMBERLAND COUNTY COURT OF COMMON PLEAS CIVIL DIVISION 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) NORTHWEST CONSUMER DISCOUNT 4813 JONESTOWN ROAD, SUITE 107 COMPANY HARRISBURG, PA 17109 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 maybe affected by the sale. Name Last Known Address (if address cannot be reasonably ascertained, please indicate) EAST PENNSBORO TOWNSHIP DANIEL G. DIPATRIZIO 98 S. ENOLA DRIVE ENOLA, PA 17025 56 OLIVER ROAD ENOLA, PA 17025 7. Name and address of every other person of whom the plaintiff has knowledge who has any interest in the property which maybe 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 56 OLIVER ROAD ENOLA, PA 17025 13 North Hanover Street Carlisle, PA 17013 PO Box 2675 Harrisburg, PA 17105 I verify that the statements made in this affidavit aze 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 unsworn falsification to authorities. MAY 7.2002 DATE FRANK FE ERMAN, ESQUIRE Attorney for Plaintiff r..,~ C7 O O C': r:~ -n -< - - .. _._{ C MORTGAGE ELECTRONIC REGISTRATION SYSTEMS, INC. Plaintiff, v. KATHY L. DIPATRIZIO Defendant(s). CUMBERLAND COUNTY No.02-1528-CIVIL MAY 7, 2002 TO: KATHY L. DIPATRIZIO 56 OLIVER ROAD ENOLA, PA 17025 * *TH/S F/RM /S A DEBT COLLECTOR ATTEMPT/NG TO COLLECT A DEBT AND ANY /NFORMAT/ON OBTAINED WILL BE USED FOR THAT PURPOSE. IF YOU HAVE PREVIOUSLY RECEIVED A D/SCHARGE /N BANKR UPTCYAND THIS DEBT WAS NOT REAFFIRMED, THIS /S NOT AND SHOULD NOT BE CONSTRUED TO BE AN ATTEMPT TO COLLECT A DEBT, BUT ONLY ENFORCEMENT OF A LIENAGAINST PROPERTY. Your house (real estate) at , 56 OLIVER ROAD, ENOLA, PA 17025, 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, Cazlisle, PA 17013, to enforce the court judgment of 73$ ,786.30 obtained by MORTGAGE ELECTRONIC REGISTRATION SYSTEMS, INC. (the mortgagee) against you. In the event the sale is continued, an announcement will be made at said sale in compliance with Pa.R.C.P., Rule 3129.3. NOTICE OF OWNER'S RIGHTS YOU MAY BE ABLE TO PREVENT THIS SHERIFF'S SALE To prevent this Sheriffs Sale, you must take immediate action: 1. The sale will be cancelled if you pay to the mortgagee the back payments, late chazges, costs and reasonable attorney's fees due. To find out how much you must pay, you may call: (215) 563-7000. 2. You maybe 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 X215) 563-7000. 2. You maybe able to petition the Court to set aside the sale if the bid price was grossly inadequate compazed 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 maybe entitled to a shaze 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) aze 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 East Pennsboro Township, County of Cumberland and Commonwealth of Pennsylvania, more particularly bounded an described as follows, to wit: BEGINNING at a hub on the Southwest side of Oliver Road (50 feet wide) at the corner of lands now or formerly of Earl W. Reidell, being Lot No. 55, said point being measured along the said side of Oliver Road, 490.96 feet to the intersection with the Southeast side of Louis Lane North; thence extending from said point of beginning and along the said side of Oliver Road, South 46 degrees 00 minutes East, the distance of 64 feet to a hub at the comer of lands now or formerly of Harry R. Crossland, being Lot No. 57; thence along lands now or formerly of Harry R. Crossland, South 44 degrees 00 minutes West, the distance of 100 feet to a p.k. nail at the corner of Lands now or formerly of Administrator of Veterans Affairs; thence along lands now or formerly of Administrator of Veterans Affairs, North 46 degrees 00 minutes West, the distance of 64 feet to a hub at the corner of lands now or formerly of Earl W. Reidell; thence along lands now or formerly of Earl W. Reidell, North 44 degrees 00 minutes East, the distance of 100 feet to a point, the place of BEGINNING. BEING Lot No. 56 on the Plan of Louis Park, recorded in the Cumberland County Recorder of Deeds Office in Plan Book 5, Page 50. HAVING THEREON ERECTED a residential family style dwelling house known and numbered as 56 Oliver Road, Enola, Pennsylvania. TAX PARCEL NUMBER: 12-2992-041 TITLE TO SAID PREMISES IS VESTED IN Kathy L. Dipatrizio by Deed from Barry L. Woods, single man dated 12/31/1997 and recorded 1/6/1998 in Deed Book 170 Page 377. BEING KNOWN AS: 56 OLIVER ROAD ENOLA, PA 17025 c> c-, `, ~~- ~., -, z; ~:: -_: ` ~;, ~. < •, ~ ,.,; ,z,, _~ c ='-_~ ~~ ~ „ ,: ;a -- ~ ; ~ ~ _1 -~ cn ~ WRIT OF EXECUTION and/or ATTACHMENT COMMONWEALTH OF PENNSYLVANIA) NO. 02 -1528 COUNTY OF CUMBERLAND) - CIVIL 19 CIVIL ACTION - I_gyy - TO THE SHERIFF OF _~~~_ __ COUNTY: To satisfy the debt, interest and costs due __MOrtgage_ Electronic Registration Sys#~ms,-Tnr~------------ -_---- ---- PLAINTIFF(S) from __xathy ~~__Denatrizio, 56 Oliver Rd., Enola PA 17025. - -- ----- DEFENDANT(S) (1) You are directed to levy upon the property of the defendant(s) and to sell Real estate located at-56-01ive~ 25. See attached legal description) (2) You are also directed to attach the property of the defendant(s) not levied upon in the possession of as folbws: 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) Ilpropertyofihedefendant(s)notlevieduponansubjecttoattachmentisfoundinthepo&sessionofarryoneother than a named gamishee, you are directed to notify him/her that he/she has been added as a gamishee and is en)oined as above stated. Amount Due $73, 786.30 Interest 5/7/02 - 9/4/02 $1,455.60 Atty's Comm AttyPaid $110.35 Plaintilf Paid L.L. $ . 5 0 Due Prothy $1.00 Other Costs Date. - ------ MaY~- HEOUESTING PARTY: Name-___Frank Federman, Esg• __-___CURTIS R rON Protho otary, Civil Division by -- Deputy Address: ___ 1617 JFK Blvd. L_ Ste_1,400 __, Philadelphia- PA__19103.1814 Attorney for _ plaintiff _____ _ Telephone: ! 21 1 64 7nOn Supreme Court ID No. t ~~q fi IN THE COURT OF COMMON PLEAS OF CUMBERLAND COUNTY, PENNSYLVANIA RE: MORTGAGE ELECTRONIC REGISTRATION SYSTEMS, INC. CIVIL ACTION vs. KATHY L. DIPATRIZIO ) CIVIL DIVISION NO. 02-1528-CIVIL AFFIDAVIT OF SERVICE PURSUANT TO RULE 3129 COMMONWEALTH OF PENNSYLVANIA ) COUNTY OF CUMBERLAND ) SS: I, FRANK FEDERMAN, ESQUIRE attorney for MORTGAGE ELECTRONIC REGISTRATION SYSTEMS, INC. hereby verify that on 5J7102 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 5/7/2 by certified mail return receipt requested see Exhibit "B" attached hereto. DATE: July 18.2002 F NK FEDE MAN, ESQUIRE Attorney for Plaintiff OQp ht ti d w ._ C O Y Y C ~ L ~ f7 ~ Uj O I~. '~ ~ L a`, d ~ C p" ~ y ~' U r C O. v ~a ~ ~~ ~Oa. t 0 A h L 'O R 'O ~d ~. d 'O C d W 0 a. ~ t . 7160 3901 9844 8032 41401_, TO: KATHY '-, DIPA.TRIZIO { 56 OLIVER ROAD i - ~ ENOLA, PA 17025 i i i SENDER: KMD SALES/5935058569 REFERENCE: j PS Form 3800 June 2000 ~j RETURN Postage ,34 1 RECEIPT Certified Fee 2.10 _ SERVICE ~ Retum Receipt Fee 1.50 3.20 i Restricted Delivery - ... Total Postage & Fees "~ k ` ~ 7 ~"~ ti -O US Postal Service POST RDA ' Receipt for ~ ~ y , ? ~ d y~'' Certified Mail ~s~ 8 ~~ No Insurance Coverage Provided Do Not Use for International Mail n ~-, v llil.: ~ r~ ~\~ U ;_ it r';- ~ ~q ; b i G :.~ ; ~ t_ ~ 11 ~-t " ~,.~, .~.7 FJ _~, C'. ~.. -, ~~,~ .~~ ;, lZ ~nr AiF;, , ',i'~ COMMONWEALTH OF PENNSYLVANIA COUNTY OF CUMBERLAND } SS: I, Robert P. Zieeler, Recorder of Deeds in and for said County and State do hereby certify that the Sheriffs Deed in which ashineton Mutual Bank FA is the grantee the same having been sold to said grantee on the 4th day of Sent A.D., 2002, under and by virtue of a writ Execution issued on the 7th day of Mav, A.D., 2002, out of the Court of Common Pleas of said County as of Civil Term, 2002 Number 1528, at the suit of Morteaee Electronic Ree Svstems Inc against Kathv L DiPatrizio is duly recorded in Sheriff's Deed Book No. 254, Page 379. IN TESTIMONY WHEREOF, I hav/e hereunto set my hand and seal of said office this ~/~~ day of --J%~~', A.D. 2002 (~ Recorder of Deeds Mortgage Electronic Registration Systems, Inc. VS Kathy L. Dipatrizio In The Court of Common Pleas of Cumberland County, Pennsylvania Writ No. 2002-1528 Civil Term Brian Barrick, Deputy Sheriff, who being duly sworn according to law, states that on May 10, 2002 at 7:59 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: Kathy L. Dipatrizio, by making known unto Kathy L. Dipatrizio personally, at 56 Oliver Rd., Enolal, Cumberland County, Pennsylvania, its contents and at the same time handing to him 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 08, 2002 at 12:22 o'clock P.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 Kathy L. Dipatrizio located at 56 Oliver Rd., Enola, 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: Kathy L. Dipatrizio, by regular mail to her last known address of 56 Oliver Road, Enola, PA 17025. This letter was mailed under the date of July 12, 2002 and never returned to the Sheriffls Office. R. Thomas Kline, Sheriff, who being duly sworn according to law, states that after due and legal notice had been given according to law, he exposed the within described premises at public venue or outcry at the Court House, Carlisle, Cumberland County, Pennsylvania, on September 4, 2002 at 10:00 AM. He sold the same for the sum of $1.00 to Attorney Frank Federman for Washington Mutual Bank, FA. It being the highest bid and best price received for the same, Washington Mutual Bank, FA of 75 North Fairway Drive, Vernon Hills, IL 60061, being the buyer in this execution, paid Sheriff R. Thomas Kline the sum of $850.48, it being costs. Sheriffs Costs: Docketing $ 30.00 Poundage 16.68 Posting Bills 15.00 Advertising 15.00 Acknowledging Deed 30.00 Auctioneer 10.00 Law Library Prothonotary Mileage Certified Mail Levy .50 1.00 20.70 .80 15.00 Surcharge Law Journal Patriot News Share of Bills Distribution of Proceeds Sheriffs Deed 20.00 335.15 260.95 25.20 25.00 29.50 $ 850.48 paid by attorney 10/14/02 Sworn and subscribed to before me This / 7 `~ day of ~/,,,_ R. Thomas Kline, She-riff 2002, A.D._ i~ ~ .. n e P~.i ~ B~='~ r thonotary Real Estat eputy ~~ ~. cv ~~ ~ i.~° u,.38scs Dom. ~~~ 7a a MORTGAGE ELECTRONIC REGISTRATION SYSTEMS, INC. v. Plaintiff, KATHY L. DIPATRIZIO Defendant(s). CUMBERLAND COUNTY COURT OF COMMON PLEAS CIVIL DIVISION N0.02-1528-CIVIL AFFIDAVTT PURSUANT TO RULE 3129 (Affidavit No. 1) MORTGAGE ELECTRONIC REGISTRATION SYSTEMS INC., 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 ,56 OLIVER ROAD. ENOLA. PA 17025 . 1. Name and address of Owner(s) or reputed Owner(s): Name KATHY L. DIPATRIZIO Last Known Address (if address cannot be reasonably ascertained, please indicate) 56 OLIVER ROAD ENOLA, PA 17025 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) None s 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) NORTHWEST CONSUMER DISCOUNT COMPANY 4813 JONESTOWN ROAD, SUITE 107 HARRISBURG, PA 17109 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 maybe affected by the sale. Name Last Known Address (if address cannot be reasonably ascertained, please indicate) EAST PENNSBORO TOWNSHIP DANIEL G. DIPATRIZIO 98 S. ENOLA DRIVE ENOLA, PA 17025 56 OLIVER ROAD ENOLA, PA 17025 7. Name and address of every other person of whom the plaintiff has knowledge who has any interest in the property which maybe affected by the sale: Name Last Known Address (if address cannot be reasonably ascertained, please indicate) TenanUOccupant Domestic Relations of Cumberland County Commonwealth of Pennsylvania Department of Welfare 56 OLIVER ROAD ENOLA, PA 17025 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 unsworn falsification to authorities. MAY 7. 2002 DATE FRANK FE ERMAN, ESQUIRE Attorney for Plaintiff MORTGAGE ELECTRONIC REGISTRATION CUMBERLAND COUNTY SYSTEMS, INC. Plaintiff, No. 02-1528-CIVIL v. KATHY L. DIPATRIZIO Defendant(s). MAY 7, 2002 TO: KATHY L. DIPATRIZIO 56 OLIVER ROAD ENOLA, PA 17025 * *THIS F/RM /S A DEBT COLLECTOR ATTEMPTING TO COLLECT A DEBT AND ANY INFORMATION OBTA/NED WILL BE USED FOR THAT PURPOSE. IF YOU HAVE PREVIOUSLYRECEIVED A D/SCHARGE IN BANKR UPTCYAND THIS DEBT WAS NOT REAFFIRMED, THIS !S NOT AND SHOULD NOT BE CONSTRUED TO BE AN ATTEMPT TO COLLECT A DEBT, BUT ONLY ENFORCEMENT OF A L/EN AGAINST PROPERTY. * * Your house (real estate) at , 56 OLIVER ROAD, ENOLA, PA 17025, 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 $73,786.30 obtained by MORTGAGE ELECTRONIC REGISTRATION SYSTEMS, INC. (the mortgagee) against you. In the event the sale is continued, an announcement will be made at said sale in compliance with Pa.R.C.P., Rule 3129.3. NOTICE OF OWNER'S RIGHTS YOU MAY BE ABLE TO PREVENT THIS SHERIFF'S SALE To prevent this Sheriffs Sale, you must take immediate action: I. 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 maybe 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 maybe able to petition the Court to set aside the sale if the bid price was grossly inadequate compazed 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 maybe entitled to a shaze 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) aze 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 East Pennsboro Township, County of Cumberland and Commonwealth of Pennsylvania, more particularly bounded an described as follows, to wit: BEGINNING at a hub on the Southwest side of Oliver Road (50 feet wide) at the corner of lands now or formerly of Earl W. Reidell, being Lot No. 55, said point being measured along the said side of Oliver Road, 490.96 feet to the intersection with the Southeast side of Louis Lane North; thence extending from said point of beginning and along the said side of Oliver Road, South 46 degrees 00 minutes East, the distance of 64 feet [o a hub at the corner of lands now or formerly of Harry R. Crossland, being Lot No. 57; thence along lands now or formerly of Harry R. Crossland, South 44 degrees 00 minutes West, the distance of 100 feet to a p.k. nail at the corner of lands now or formerly of Administrator of Veterans Affairs; thence along lands now or formerly of Administrator of Veterans Affairs, North 46 degrees 00 minutes West, the distance of 64 feet to a hub at the corner of lands now or formerly of Earl W. Reidell; thence along lands now or formerly of Earl W. Reidell, North 44 degrees 00 minutes East, the distance of 100 feet to a point, the place of BEGINNING. BEING Lot No. 56 on the Plan of Louis Park, recorded in the Cumberland County Recorder of Deeds Office in Plan Book 5, Page 50. HAVING THEREON ERECTED a residential family style dwelling house known and numbered as 56 Oliver Road, Enola, Pennsylvania. TAX PARCEL NUMBER: 12-2992-041 TITLE TO SAID PREMISES IS VESTED IN Kathy L. Dipatrizio by Deed from Barry L. Woods, single man dated 12/31/1997 and recorded 1/6/1998 in Deed Book 170 Page 377. BEING KNOWN AS: 56 OLIVER ROAD ENOLA, PA 17025 a WRIT OF EXECUTION and/or ATTACHMENT COMMONWEALTH OF PENNSYLVANIA) COUNTY OF CUMBERLAND) TO 7HE SHERIFF OF - GUMBERI,ABIR- _ COUNTY. To satisfy the debt, interest and costs due _ Mortgage. Sgstems, Irom .Kathy. L...._P~gatrizio,_ 56 Oliver Rd., Enola PA 17025. _ -"---- DEFENDANT(S) (t) You are directed to levy upon the property of the defendant(s) and to sell Real estate located at ~6-0liuer--Ready F^~+~~ PA 17025.~See attached legal description) (2) You are also directed to attach the progeny 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; NO 02 -1528 CIVIL 19 __ CIVIL ACTION -LAW Electronic Registration (3) If propertyolthedefendant(s)notlevieduponansubjecttoatlachmentisfoundinthepossessionofanyoneolher t han a named garnishee, you are directed tonotify him/he r t hat he/she has been added as a garnishee and is enjoined as above stated. Amount Due $73, 786.30 Interest 5/7/02 - 9/4/02 $1,455.60 Atty's Comm ~o L.L. Due Prolhy Other Costs $.50 $1.00 Atty Paid __ $110.35 Plaintiff Paid Date... -- -- - Ma~~-.-.~0.~2 -_. --- by --ti yc~/ 0 ____. CURTIS R, LONG Protho otary, Civil Division Deputy REQUESTING PARTY: Name Frank Federman,-Esg. - _ ------ Address: 1617 JFK Blvd. , Ste 1400 ,.Philadelphia- PA 19103 1814 -- - Attorneyfor _ _ plaintiff ______- Lelephone __(_~1-~) 563 7000 Supreme Court ID No. Real Estate Sale #0'f On May 9, 2002 the sheriff levied upon the defendant's interest in the real property situated in East Pennsboro Township, Cumberland County, PA known and numbered as 56 Oliver Road, Enola, and more fully described on Exhibit "A" filed with this writ and by this reference incorporated herein. Date: May 9, 2002 By: Job./ ~. Sy~ Real Estate Deputy °; ~ a ~n ~~ a 9T ~ 1 A7~ ~.~., .. ~` p ~llk; ~~a5 3~Id~-`.its.' _~. _:~ i?1j.~0 THE PATRIOT NEWS THE SUNDAY PATRIOT NEWS Proof of Publication UnderAd 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 Pa_ mot-Neves andLhg 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 ...~~~~~ COPY ~..................................... Swo NotariafSea me 's 14th da~Au t 2002 A.D. SALE # 4 Terry L Russell, Notary Public City Of Hartisburg, Dauphin Cou ~ My Commission Expires June 6,2 NO ARY PUBLIC Memher, Pennsylvania Association Or Notaries My commission expires June 6, 2006 CUMBERLAND COUNTY SHERIFFS OFFICE CUMBERLAND COUNTY COURTHOUSE CARLISLE, PA. 17013 Statement of Advertising Costs nf,J To THE PATRIOT-NEWS CO., Dr. For publishing the notice or publication attached hereto on the above stated dates $ 259.20 Probating same Notary Fee(s) $ 1,75 Total $ 260.95 Publisher's Receipt for Advertising Cost The Patriot News Co., publisher of The Patriot-News and The Sundav 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. B y .................................................................... _ __ _ ___ REAL ESTXTE SALE No. 4 Wrlt No. 2002-1528 Clvll Term Mortgage Electronic Regletratlon Syateme, Ina. ve Kathy L. Dlpatrizlo Atty: Frank Federman DESCR[PI7ON ALL THAT CERTAIN Vact of land situate in East Pennsboro Township, County of Cumberland and Commonwealth of Pennsylvania, more particularly bounded and described as follows, (o,wft: BEGA7NING at a hub on the Southwest side of Oliver Road (60 feetl!vide) at [he comer of lands now or formerly of Earl W. Reidell, being Lat No. 55, said point being measured along the said side of Oliver Road, 490.96 feet m the imxmution with Me Southeast side of Louie Lane North; thence extending fmm said point of beginning and along Use said side of Oliver Road, South 46 degrees GO minutes East, the distance of 64 feet m a hub at the comer of lands now or formerly of Harty R. Crossland, being IA[ No. 57; thence along lands now or formerly of Harty R. Crossland, South 44 degrees QO minutes West, the distance of 100 feet to a p.k. nail e! Ibe comer of lands now or formerly of AdminisVamr of Veterans Affairs; thence along lands now or formuly of Adminlatramr of Veterans Affairs, NaM 46 degrees 00 minotea West, the distance' of 64 feet [o a hub at [he comer of lands now or formerly of Earl W Reidell; thence along lands now or formerly of Earl W. Reidell, North 44 degrees 00 minutes East, the distance of 100 feet to a point, the place a° BEGBVNING. BEING Lot No. Sti~ an the Plan of Louis Park, recorded in the Cum(ierland County Reorder of 'Deeds Office in Plan Bod3, Page 50. HAVING THEREON EkECTED a residential family style dwelling house known and numbered as 56 Oliver Road, Enola, Pennsylvania. TAX PARCEL NUMBER: 12-2992-041. TITLE TO SAN PREMISES is vested in Kathy L. Dipahizio by Deed fmm Barty L. Woods, single man, dated 12/3111997 and recmNed Il6l 1998 in Deed Book 170 Page 377. BEING KNOWN A5: 56 Oliver Road, Enola, PA I 17025. PROOF OF PUBLICATION OF NOTICE IN CUMBERLAND LAW JOURNAL (iJnder 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 Joumal, 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, 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. 4 Writ No. 2002-1525 Civil Ro er M. Morgenthal, Editor Mortgage Electronic Registration Systems, Inc. vs. Eathy L. Dipatrizio Atty.: Frank Federman ALL THAT CERTAIN tract of ]and situate in East Pennsboro Township, County of Cumberland and Com- monwealth of Pennsylvania, more pazticulazly bounded an described as follows, to wit: BEGINNING at a hub on the Southwest side of Oliver Road (50 feet wide) at the comer of lands now or formerly of Eazl W. Reidell, be- ing Lot No. 55, said point being measured along the said side of Oliver Road, 490.96 feet to the in- tersection with the Southeast side of Louis Lane North; thence extend- ing from said point of begiruung and SWORN TO AND SUBSCRIBED before me this 9 day of AUGUST. 2002_ L09S E. ~NYDER, Ndery PubAC CStNSIS Q8t0, C.IpI1bBf(8t14 My Carmhsion El~kss Memh S, .~. a~.... -. vs. Kathy L. Dipatrizio Atty.: Frank Federman ALL THAT CERTAIN tract of ]and situate in East Pennsboro Township. County of Cumberland and Com- monwealth of Pennsylvania, more pazticulazly bounded an described as follows. to wit: BEGINNING at a hub on the Southwest side of Oliver Road (50 feet wide) at the corner of lands now or formerly of Earl W. Reidell, be- ing Lot No. 55, said point being measured along the said side of Oliver Road. 490.96 feet to the in- tersection with the Southeast side of Louis Lane North: thence e#end- ing from said point of beginning and along the said side of Oliver Road. South 46 degrees 00 minutes East, the distance of 64 feet to a hub at the corner of lands now or formerly of Hazry R. Crossland, being Lot No. 57: thence along lands now or for- merly of Harry R. Crossland. South 44 degrees 00 minutes West, the distance of 100 feet to a p.k. nail at the corner of lands now or formerly of Administrator of Veterans Affairs; thence along ]ands now or formerly of Administrator of Veterans Affairs, North 46 degrees 00 minutes West, the distance of 64 feet to a hub at the comer of lands now ar formerly of Earl W. Reidell; thence along lands now or formerly of Eazl W. Reidell. North 44 degrees 00 min- utes East, the distance of 100 feet to a point, the place of BEGINNING. BEING Lot No. 56 on the Plan of Louis Pazk, recorded in the Cum- berland County Recorder of Deeds Office in Plan Book 5, Page 50. HAVING THEREON ERECTED a residential family style dwelling house known and numbered as 56 Oliver Road. Enola, Pennsylvania. TAX PARCEL NUMBER: 12-2992- 041. TITLE TO SAID PREMISES IS VESTED IN Kathy L. Dipatrizio by Deed from Bazry L. Woods, single man dated 12/31/1997 and record- ed 1 /6/ 1998 in Deed Book 170 Page 377. BEING KNOWN AS: 56 OLIVER ROAD, ENOLA. PA 17025. 9 day of AUGUST. 2002 LQIS E. SNYDER, NMary PudlC ri0f~9iS(0 8(Si0~ G`UtlibBf(8(Ia bly Cocr~esron El~kee AlerCh 5, PHELAN HALLINAN £~ SCHMIEG, LLP Lawrence T. Phelan, Esq., Id. No. 32227 Francis S. Hallinan, Esq., Id. No. 62695 Daniel G. Schmieg, Esq., Id No. One Penn Center at Suburban Station 1617 John F. Kennedy Boulevard, Suite 1400 Philadelphia, PA 19103-1814 (215)563-7000 ATTORNEY FOR PLAINTIFF Mortgage Electronic Registration Systems, Inc. Court of Common Pleas Civil Division Plaintiff ~ Cumberland County vs Kathy L. DiPatrizio No. 02-1528-Civil PHS# 57956 Defendant PRAECIPE TO THE PROTHONOTARY: Please mark the above referenced case Discontinued and Ended without prejudice. Please mark the above referenced case Settled, Discontinued and Ended. _X_Please mark Judgments satisfied and the Action Discontinued and Ended. Please Vacate the judgment entered and mark the action discontinued and ended without prejudice. Please withdraw the complaint and mark the action discontinued and ended without prejudice. Date: April 12, 2007 /~ Francis Hallinan Attorney for Plaintiff 1 ~ ~`~ t._ ~~l `' YC'~ i ~ ~.rt~ {T'. _ ~~ ~ i ~.~ ~'a {~~ if r ' ~ _ r~