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HomeMy WebLinkAbout02-1649FEDERMAN 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 (215) ~63-7000 COUNTRYWIDE HOME LOANS, INC. 7105 CORPORATE DRIVE PLANO, TX 75024-3632 Plaintiff PHILIP A. LOWE 2103 LOGAN STREET CAMP HILL, PA 17011 ATTORNEY FOR PLAINTIPF COURT OF COMMON PLEAS CIVIL DIVISION TERM CUMBERLAND COUNTY Defendant(s) CIVIL ACTION - I.AW **THIS FIRM IS A DEBT COLLECTOR ATTEMPTING TO COLLECT A DEBT AND ANY INFORMATION OBTAINED WILL BE USED FOR THAT PURPOSE. IF YOU HAVE PREVIOUSLY RECEIVED A DISCHARGE IN BANKRUPTCY AND THIS DEBT WAS NOT REAFFIRMED, THIS CORRESPONDENCE IS NOT AND SHOULD NOT BE CONSTRUED TO BE AN ATTEMPT TO COLLECT A DEBT, BUT ONLY ENFORCEMENT OF A LIEN AGAINST PROPERTY. ** You have been sued in Court. If you wish to defend against the claims set forth in the following pages, you must take action within twenty (20) days after this Complaint and Notice are served, by entering a written appearance personally or by attorney and filing in writing with the court your defenses or objections to the claims set forth against you. You are warned that if you fail to do so the case may proceed without you and a judgment may be entered against you by the court without further notice for any money claimed in the Complaint or for any other claim or relief requested by the Plaintiff. You may lose money or property or other rights important to you. YOU SHOULD TAKE THIS PAPER TO YOUR LAWYER AT ONCE. IF YOU DO NOT HAVE A LAWYER OR CANNOT AFFORD ONE, GO TO OR TELEPHONE THE OFFICE SET FORTH BELOW TO FIND OUT WHERE YOU CAN GET LEGAL HELP. CUMBERLAND COUNTY CUMBERLAND COUNTY BAR ASSOCIATION 2 LIBERTY AVENUE CARLISLE, PA 17013 (7 ! 7) 249-3166 Loan #: 5838558 IF THIS IS THE FIRST NOTICE THAT YOU HAVE RECEIVED FROM THIS OFFICE, BE ADVISED THAT~ PURSUANT TO THE FAIR DEBT COLLECTION PRACTICES ACT, 15 U.S.C. § 1692 et seq. (1977), DEFENDANT(S) MAY DISPUTE THE VALIDITY OF THE DEBT OR ANY PORTION THEREOF. IF DEFENDANT(S) DO SO IN WRITING WITHIN THIRTY (30) DAYS OF RECEIPT OF THIS PLEADING, COUNSEL FOR PLAINTIFF WILL OBTAIN AND PROVIDE DEFENDANT(S) WITH WRITTEN VERIFICATION THEREOF; OTHERWISE, THE DEBT WILL BE ASSUMED TO BE VALID. LIKEWISE, IF REQUESTED WITHIN THIRTY (30) DAYS OF RECEIPT OF THIS PLEADING, COUNSEL FOR PLAINTIFF WILL SEND DEFENDANT(S) THE NAME AND ADDRESS OF THE ORIGINAL CREDITOR, IF DIFFERENT FROM ABOVE. THE LAW DOES NOT REQUIRE US TO WAIT UNTIL THE END OF THE THIRTY (30) DAY PERIOD FOLLOWING FIRST CONTACT WITH YOU BEFORE SUING YOU TO COLLECT THIS DEBT. EVEN THOUGH THE LAW PROVIDES THAT YOUR ANSWER TO THIS COMPLAINT IS TO BE FILED IN THIS ACTION WITHIN TWENTY (20) DAYS, YOU MAY OBTAIN AN EXTENSION OF THAT TIME. FURTHERMORE, NO REQUEST WILL BE MADE TO THE COURT FOR A JUDGMENT UNTIL THE EXPIRATION OF THIRTY (30) DAYS AFTER YOU HAVE RECEIVED THIS COMPLAINT. HOWEVER, IF YOU REQUEST PROOF OF THE DEBT OR THE NAME AND ADDRESS OF THE ORIGINAL CREDITOR WITHIN THE THIRTY (30) DAY PERIOD THAT BEGINS UPON YOUR RECEIPT OF THIS COMPLAINT, THE LAW REQUIRES US TO CEASE OUR EFFORTS (THROUGH LITIGATION OR OTHERWISE) TO COLLECT THE DEBT UNTIL WE MAIL THE REQUESTED INFORMATION TO YOU. YOU SHOULD CONSULT AN ATTORNEY FOR ADVICE CONCERNING YOUR RIGHTS AND OBLIGATIONS IN THIS SUIT. Plaintiff is COUNTRYWIDE HOME LOANS, INC. 7105 CORPORATE DRIVE PLANO, TX 75024-3632 The name(s) and last known address(es) of the Defendant(s) are: PHILIP A. LOWE 2103 LOGAN STREET CAMP HILL, PA 17011 who is/are the mortgagor(s) and real owner(s) of the property hereinafter described. On 2/26/99 mortgagor(s) made, executed and delivered a mortgage upon the premises hereinafter described to PLAINTIFF which mortgage is recorded in the Office of the Recorder of CUMBERLAND County, in Mortgage Book No. 1522, Page 1095. The premises subject to said mortgage is described as attached. The mortgage is in default because monthly payments of principal and interest upon said mortgage due 11/1/01 and each month thereafter are due and unpaid, and by the t¢iiiis 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. The following amounts are due on the mortgage: Principal Balance Interest 10/1/01 through 3/1/02 (Per Diem $17.16) Attorney's Fees Cumulative Late Charges 2/26/99 to 3/1/02 Cost of Suit and Title Search Subtotal $88,258.52 2,608.32 1,250.00 123.84 5~o OO $92,790.68 Escrow Credit 0.00 Deficit 14R_g4 Subtotal $14g 84 TOTAL $92,939.52 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. 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 $92,939.52, together with interest from 3/1/02 at the rate of $17.16 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. FF~ERMAN AND PHE , LLP FRANK FEDERMAN, ESQUIRE LAWRENCE T. PHELAN, ESQUIRE FRANCIS S. HALLINAN, ESQUIRE Attorneys for Plaintiff ~I~ a~ a poin~ oa ~he westerly li~ of No~h sou~herl~ line of ~9an s~=ee~ Chance ~n a sou%he=l~ direction ' along ~gan S~reet in an oas~e=1y dt:ectton seven=y--one (71) fee~ ~o a point, ~he place Of BEGINNING- BEING par~ of lo~s soven~y--seven (77), seventy-eight (78), seven~y-nine (79); eigh~ (80), and eighty--one (81), and a. Death Ce~i~ca~e No. &S11&30, taus vua~a--~ ~SES"'BEING: 2103 L~S~ VERIFICATION BRANDON SCIUMBATO hereby states that he is VICE PRESIDENT of COUNTRYWIDE HOME LOANS, INC. 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 in Mortgage Foreclosure are true and correct to the best of his knowledge, information and belief. The understands that this statement is made subject to the penalties of 18 Pa. C.S. S~. 4904 undersigned relating to unswom falsification to authorities. DATE: SHERIFF'S RETURN - REGULAR CASE NO: 2002-01649 P COMMONWEALTH OF PENNSYLVANIA: COUNTY OF CUMBERLAND COUNTRYWIDE HOME LOANS INC VS LOWE PHILIP A RONALD HOOVER , Sheriff or Deputy Sheriff of Cumberland County, Pennsylvania, who being duly sworn according to law, says, the within COMPLAINT - MORT FORE was served upon LOWE PHILIP A the DEFENDANT , at 1722:00 HOURS, on the 8th day of April , 2002 at 2103 LOGAN STREET CAMP HILL, PA 17011 TINA STUEBEN a true and attested copy of COMPLAINT - MORT FORE by handing to LIVE IN GIRLFRIEND together with and at the same time directing Her 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 me this /~ day of ~2oo 2~ A.D. Pr6thonotary · , w So Answers: R. Thomas Kline 04/09/2002 FEDERMAN & PHELAN Deputy Sheriff/' FEDERMAN AND PHELAN, LLP By: FRANK FEDERMAN Identification No. 12248 Attorney for Plaintiff ONE PENN CENTER AT SUBURBAN STATION 1617 JOHN F. KENNEDY BLVD., SUITE 1400 PHILADELPHIA, PA 19103-1814 (215) 563-7000 COUNTRYWIDE HOME LOANS, INC. 7105 CORPORATE DRIVE PLANO, TX 75024-3632 Plaintiff, V. PHILIP A. LOWE Defendant(s). NO. : : : : : : PRAECIPE FOR JUDGMENT FOR FAILURE TO ANSWER AND ASSESSMENT OF DAMAGES CUMBERLAND COUNTY COURT OF COMMON PLEAS CIVIL DIVISION 02-1649-CIVIL TO THE PROTHONOTARY: Kindly enter judgment in favor of the Plaintiff and against PHILIP A. LOWE 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 3/02/02 to 5/13/02 TOTAL $92,939.52 $ 1,252.68 $94~192.~0 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. FRANK FEDEKMJS~, E~QU1RE Attorney for Plaintiff DAMAGES ARE HEREBY ASSESSED AS INDICATED. PRO PROTHY FEDERMAN AND PHELAN BY: FRANK FEDERMAN, ESQUIRE Identification No. 12248 1617 John F. Kennedy Boulevard Suite 1400 Philadelphia, PA 19103-1814 COUNTRYWIDE HOME LOANS, INC. Plaintiff VS. PHILIP A. LOWE Defendant (s) Attorney for Plaintiff : COURT OF COMMON PLEAS : CIVIL DIVISION : CUMBERLAND COUNTY : NO. 02-1649-CIVIL TO: PHILIP A. LOWE 2103 LOC, AN STREET CAMP HILL, PA 17011 DATE OF NOTICE: APRIL 30. 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 to enter a written appearance personally or by attorney and file in writing with the court your defenses or objections to the claims set forth against you. Unless you act within ten (10) days from the date of this notice, a Judgment may be entered against you without a hearing and you may lose your property or other important rights. You should take this notice to a lawyer at once. If you do not have a lawyer or cannot afford one, go to or telephone the following office to find out where you can get legal help: CUMBERLAND COUNTY 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 ONE PENN CENTER AT SUBURBAN STATION 1617 JOHN F. KENNEDY BLVD., SUITE 1400 PHILADELPHIA, PA 19103-1814 (215) 563-7000 COUNTRYWIDE HOME LOANS, INC. 7105 CORPORATE DRIVE PHILIP A. LOWE Plaintiff, Defendant(s). ATTORNEY FOR PLAINTIFF CUMBERLAND COUNTY COURT OF COMMON PLEAS CIVIL DIVISION NO. 02-1649-CIVIL VERIFICATION OF NON-MILITARY SERVICE · FRANK FEDERMAN, ESQUIRE, hereby verifies that he is attorney for the Plaintiff in the above-caPtioned matter, and that on information and belief, he has knowledge of the following facts, to wit: (a) that the defendant(s) is/are not in the Military or Naval Service of the United States or its Allies, or otherwise within the provisions of the Soldiers' and Sailors' Civil Relief Act of Congress of 1940, as amended. (b) that defendant PHILIP A. LOWE is over 18 years of age and resides at, 2103 LOGAN STREET, CAMP HILL, PA 17011 . This statement is made subject to the penalties of 18 Pa. C.S. Section 4904 relating to unswom falsification to authorities. F~ FEDEp~M~q, ESQUIRE Attomey for Plaintiff (Rule of Civil Procedure No. 236) - Revised IN THE COURT OF COMMON PLEAS OF CUMBERLAND COUNTY, PENNSYLVANIA CIVIL ACTION- LAW COUNTRYWIDE HOME LOANS, INC. 7105 CORPORATE DRIVE PHILIP A. LOWE Plaintiff, Defendant(s). CUMBERLAND COUNTY COURT OF COMMON PLEAS CIVIL DIVISION NO. 02-1649-CIVIL Notice is given that a Judgment in the above-captioned matter has been entered against you on 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 BE AN ATTEMPT TO COLLECT A DEBT, BUT ONLY ENFORCEMENT OF A LIEN AGAINST PROPERTY.* * PRAECIPE FOR WRIT OF EXECUTION - (MORTGAGE FORECLOSURE) P.ILC.P. 3180-3183 COUNTRYWIDE HOME LOANS, INC. Plaintiff, PHILIP A. LOWE Defendant(s). No. 02-1649-CIVIL TO THE DIRECTOR OF THE OFFICE OF THE PROTHONOTARY: Issue writ of execution in the above matter: Amount Due Interest from 5/14/02 to 9/4/02 (per diem -$15.48) TOTAL $94,192.20 $ 1,764.72and Co~s $95,956.92 F~EDERMA}q, ESQUIRE One Penn Center at Suburban Station 1617 John F. Kennedy Boulevard, Suite 1400 Philadelphia, PA 19103-1814 Attorney for Plaintiff Note: Please attach description of property. No. ALL THAT CERTAIN PIECE AND PARCEL OF LAND SITUATE IN THE BOROUGH OF CAMP HILL: CUMBERLAND COUNTY, PENNSYLVANIA, MORE PARTICULARLY BOUNDED AND DESCRIBED AS FOLLOWS, TO WIT: BEGINNING AT A POINT ON THE WESTERLY LINEOF NORTH TWENTY-FIRST STREET AT THE INTERSECTION OF SAID STREET WITH THE SOUTHERLY LINE OF LOGAN STREET, THENCE IN A SOUTHERLY DIRECTION~ ALONG NORTH TWENTY-FIRST STREET ONE HUNDRED FORTY-FIVE (145) FEET, MORE OR LESS, TO A POINT. SAID POINT BEING AT A DISTA~NCE OF THIRTY (30) FEET MEASURED IN A NORTHERLY DIRECTION FROM i THE NORTHEI~N PROPERTY LINE OF CAMP HILL CEMETERY ASSOCIATION; TIIENCE IN A WESTERLY DIRECTION ALONG A LINE PARALLEL WITH THE NORTHERLY LINE OF CAMP HH.L CEMETERY ASSOCIATION, SEVENTY-ONE (71) FEET TO A POLNT THENCE IN A NORTHERLY DIRECTION PARALLEL WITH THE WESTERN LINE OF NORTH TWENTY-FIRST STREET ONE HUNDRED FORTY-FIVE (145) FEET, MORE Oi~ LESS, TO A POINT ON THE SOUTHERN LINE OF LOGAN STREET; THENCE ALONG LOGAN STREET IN A-~ EASTERLY DIRECT/ON SEVENTY-ONE (71) FEET TO A POINT, THE PLACE OF BEGI]VNING. BEING PART OF LOTS SEVENTY-SEVEN (77), SEVENTY-EIGHT (78), SEVENTY-NINE (79), EIGHTY (80) AND EIGHTY-ONE (81), AND A PORTION OF LOTS SEVENTY-SIX (76), ON THE PLAN OF LOTS KNOWN AS SECON1} PLAN OF HAMII.TON PLACE, SAID PLAN BEING RECORDED IN THE OFFICE OF THE RECORDER OF DEEDS O1~ CUM]~ERLAND COUNTY !~' PLAN BOOK I, PAGE 46. BEING THE SAME PREMISES WHICH GRAYMOR, INC., A CORPORATION OF THE COMMONV~EALTH O1~ PENNSYLVANIA, BY THE DEED DATED MARCH 9, 1956 AND RECORDED MARCH 15, 1956 BY THE RECORDER OF DEEDS IN AND FOR CUMBERLAND COUNTY IN DEED BOOK A, VOLUME 17, PAGE 283, GRANTED ~ CONVEYED UNTO WILLIAM M. KNAP[K AND GLORIA C. KNAP[K WAS DECEASED OCTOBER 2, 1984, AS EVIDENCED BY HF~R DEATH CERTIFICATE NO.4511430, THUS VESTING SOLE INTEREST TO WILLIAM M. K~APII~ GRANTOR HEREIN. Vested by Deed, dated 2-26-99, g~ven by William M. Kaapik, widower to philip A. Lowe, a single man and "recorded 3-1-99m Book 194 Page 1086 Tax Parcel ID #: 01.21-0271-191 Property Address 2103 Logan Street, Camp Hill, PA 17011 COUNTRYWIDE HOME LOANS, INC. Plaintiff, PHILIP A. LOWE Defendant(s). CUMBERLAND COUNTY COURT OF COMMON PLEAS CIVIL DIVISION NO. 02-1649-CIVIL AFFIDAVIT PURSUANT TO RULE 3129 (Affidavit No. 1) COUNTRYWIDE HOME LOANS~ 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 ~2103 LOGAN STREET~ CAMP HILL~ PA 17011. 1. Name and address of Owner(s) or reputed Owner(s): Name Last Known Address (if address cannot be reasonably ascertained, please indicate) PHILIP A. LOWE 2103 LOGAN STREET CAMP HILL, PA 17011 2. Name and address of Defendant(s) in the judgment: Same as above 3. Name and last known address of every judgment creditor whose judgment is a record lien on the real property to be sold: Naine 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) None 5. Name and address of every other person who has any record lien on the property: Name Last Known Address (if address cannot be reasonably ascertained, please indicate) None 6. Name and address of every other person who has any record interest in the property and whose interest may be affected by the sale. Name Last Known Address (if address cannot be reasonably ascertained, please indicate) 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 Last Known Address (if address cannot be reasonably ascertained, please indicate) Tenant/Occupant 2103 LOGAN STREET CAMP HILL, PA 17011 Domestic Relations of Cumberland County 13 North Hanover Street Carlisle, PA 17013 Commonwealth of Pennsylvania Department of Welfare PO Box 2675 Harrisburg, PA 17105 I verify that the statements made in this affidavit are true and correct to the best of my personal knowledge or information and belief. I understand that false statements herein are made subject to the penalties of 18 Pa. C.S. Sec. 4904 relating to unsworn falsification to authorities. MAY 13, 2002 DATE FR.~qK 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 (215) 563-7000 COUNTRYWIDE HOME LOANS, INC. Plaintiff, V. PHILIP A. LOWE Defendant(s). ATTORNEY FOR PLAINTIFF CUMBERLAND COUNTY COURT OF COMMON PLEAS CIVIL DIVISION NO. 02-1649-CIVIL CERTIFICATION FRANK FEDERMAN, ESQUIRE, hereby verifies that he is attorney for the Plaintiffin the above-captioned matter, and that the premises are not subject to the provisions of Act 91 becau~ it is: (X) an FHA mortgage ( ) non-owner occupied ( ) vacant ( ) Act 91 procedures have been fulfilled This certification is made subject to the penalties of 18 Pa. C.S. Section 4904 relating to unswom falsification to authorities. F~ FEDE~, ESQUIRE Attorney for Plaintiff COUNTRYWIDE HOME LOANS, INC. Plaintiff, pHILIP A. LOWE Defendant(s). TO: PHILIP A. LOWE 2103 LOGAN STREET CAMP HILL, PA 17011 CUMBERLAND COUNTY No. 02-1649-CIVIL MAY 13, 2002 **THIS FIRM IS A DEBT COLLECTOR .4 TTEMPTING 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 IS NOT AND SHOULD NOT BE CONSTRUED TO BE AN ATTEMPT TO COLLECT A DEBT, BUT ONLY ENFORCEMENT OF A LIEN AGAINST PROPERTY. ** Your house (real estate) at ~ 2103 LOGAN STREET~ CAMP HILL~ PA 17011~ 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 $94~192.20 obtained by COUNTRYWIDE HOME LOANS~ 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: The sale will be cancelled if you pay to the mortgagee the back payments, late charges, costs and reasonable attorney's fees due. To find out how much you must pay, you may call: (215~ 563-7000. You may be able to stop the sale by filing a petition asking the Court to strike or open the judgment, if the judgment was improperly entered. You may also ask the Court to postpone the sale for good cause. 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 S~I,E DOES TAKE PLACE. 1. If the Sheriff's Sale is not stopped, your property will be sold to the highest bidder. You may find out the price bid by calling (215) 563-7000. 2. You may be able to petition the Court to set aside the sale if the bid price was grossly inadequate compared to the value of your property. 3. The sale will go through only if the buyer pays the Sheriffthe full amount due in the sale. To find out if this has happened, you may call (717) 240-6390. 4. If the amount due from the Buyer is not paid to the Sheriff, you will remain the owner of the property as if the sale never happened. 5. You have the right to remain in the property until the full amount due is paid to the Sheriff and the Sheriff gives a deed to the buyer. At that time, the buyer may bring legal proceedings to evict you. 6. You may be entitled to a share of the money which was paid for your house. A schedule of distribution of the money bid for your house will be filed by the Sheriff within 30 days of the sale. This schedule will state who will be receiving that money. The money will be paid out in accordance with this schedule unless exceptions (reasons why the proposed distribution is wrong) are filed with the Sheriffwithin 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 PIECE AND PARCEL OF LAND SITUATE IN THE BOROUGH OF CAMP FIH,L.. CUMBERLAND COUNTY, PENNSYLVANIA, MORE PARTICULARLY BOUNDED AND DESCRIBED AS FOLLOWS~ TO WIT: BEGINNING AT A POINT ON THE WESTERLY LINEOF NORTH TWENTY-FIRST STREET AT THE INTERSECTION OF SAID STREET WITH THE SOUTHERLY LINE OF LOGAN STREET, THENCE IN A SOUTHERLY DIRECTION, ALONG NORTH TWENTY-FIRST STREET ONE HUNDRED FORTY-FIVE (145) FEET, MORE OR LESS, TO A POINT. SAID POINT BEING AT A DISTANCE OF THIRTY (30) FEET MEASURED IN A NORTHERLY DIRECTION FROM THE NORTHERN PROPERTY LINE OF CAMP HILL CEMETERY ASSOCIATION; THENCE IN A WESTERLY DIRECTION ALONG A LINE PARALLEL WITH THE NORTHERLY LINE OF CAMP HILL CEMETERY ASSOCIATION, SEVENTY-ONE (71) FEET TO A POLNT THENCE IN A NORTHERLY DIRECTION PARALLEL WITH THE WESTERN LINE OF NORTH TWENTY-FIRST STREET ONE HUNDRED FORTY-FIVE (145) FEET, MORE LESS, TO A POINT ON THE SOUTHERN Lh~NE OF LOGAN STREET; THENCE ALONG LOGAN STREET IN A-~ EASTERLY DIRECTION SEVENTY-ONE (71) FEET TO A POINT, THE PLACE OF BEGINNING. BEING PART OF LOTS SEVENTY-SEVEN (77), SEVENTY-EIGHT (78), SEVENTY-NINE (79), EIGHTY (80) ANB EIGHTY-ONE (81), AND A PORTION OF LOTS SEVENTY-SIX (76), ON THE PLAN OF LOTS KNOWN AS SECOND PLAN OF ItAM3~.TON PLACE, SAID PLAN BEING RECORDED IN THE OFFICE OF THE RECORDER OF DEEDS OF CUMBERLAND COUNTY IN PLAN BOOK 1, PAGE 46. BEING THE SAME PREMISES WHICH GRAYMOR, INC, A CORPORATION OF THE COMMONAVEALTH O5 PENNSYLV.ANIA, BY THE DEED DATED MARCH 9, 1956 AND RECORDED MARCH 15, 1956 BY THE RECORDER OF DEEDS IN AND FOR CUMBERLAND COUNTY IN DEED BOOK A, VOLUME 17, PAGE 283, GRANTED AND CONVEYED UNTO WILLIAM M. KNAPIK .4a~D GLORIA C. K~'APIK WAS DECEASED OCTOBER 2, 1984, AS EVIDENCED BY HER DEATH CERTIFICATE NO.4~11430, THUS VESTING SOLE L-NTEREST TO WILLIAM M. · KNAPII(~ GRANTOR HEREIN. Vested by Deed, dated 2-26-99, g~ven by William M. Kaapik, widower to Philip A. Lowe, a single man and · recorded 3-1.99.m Book 194 Page 1086 Tax Parcel ID #: 01-21-0271-191 Property Address 2103 Logan SWeet, Camp Hill, PA 17011 WRIT OF EXECUTION and/or ATTACHMENT COMMONWEALTH OF PENNSYLVANIA) NO 02-1649 Civil COUNTY OF CUMBERLAND) CIVIL ACTION - LAW TO THE SHERIFF OF Cumberland COUNTY: To satisfy the debt, interest and costs due COUNRYWIDE HOME LOANS, INC. PLANTIFF(S) From PHILIP A, LOWE, 2103 LOGAN ST., CAMP HILL PA 17011.. (1) You are directed to levy upon the property of the defendant(s) and to sell REAL ESTATE LOCATED AT 2103 LOGAN ST., CAMP HILL PA 17011. (SEE ATTACHED LEGAL DESCRIPTION.) (2) You are also directed to attach the property of the defendant(s) not levied upon in the possession of GARNISHEE(S) as follows: and to notify the garnishee(s) that: (a) an attachment has been issued; (b) the garnishee(s) is/are enjoined from paying any debt to or for the account of the defendant (s) and from delivering any property of the defendant (s) or otherwise disposing thereof; (3) If property of the defendant(s) not levied upon an subject to attachment is found in the possession of anyone other than a named garnishee, you are directed to notify him/her that he/she has been adde'd as a garnishee and is enjoined as above stated. Amount Due $94,192.20 L.L. Interest 5/14/02 - 9/4/02 ($15.48/day) $1,764.72 DueProthy Atty's Comm % Other Costs Atty Paid $110.35 $.50 $1.00 Plaintiff Paid Date: MAY 13, 2002 REQUESTING PARTY: Name FRANK FEDERMAN, ESQ. Address: 1717 JFK BLVD., STE 1400 PHILDELPHIA PA 19103-1814 Attorney for: PLAINTIFF Telephone: (215) 563-7000 Supreme Court ID No. 12248 CURTIS R. LONG Prothonotary, Civil Division PLAINTIFF DEFENDANT(S) AFFIDAVIT OF SERVICE COUNTRYWIDE HOME LOANS, INC. pHII,IP A. LOWE SERVE PHILIP A. LOWE AT 2103 LOGAN STREET CAMP HILL, PA 17011 CUMBERLAND COUNTY KMD No. 02-1649-CIVIL ACCT. #5 Type of A~ - Notice oi Sale Date: SERVED Served and made known to ~ I~ p ~. L~r~l_t~ ~,, Defendant, on thq._._~'~/~ at ~, o'clock ~.m., at DI{_'~)3 ] t~n ~'--__. C~t~p [~ of Pennsylvania, in the manner described below: '~,,~ .Defendant personally served. __ Adult family member with whom Defendant(s) reside(s). Relationship is __ Adult in charge of Defendant(s)'s residence who refused to give name or relationship. __ Manager/Clerk of place of lodging in which Defendant(s) reside(s). __ Agent or person in charge of Defendant(s)'s office or usual place ofbnsiness. an officer of said Defendant(s)'s coiiipany. Other: Descr~~;e ~_._~ Heigh_~/ ttWei,ht/75 Race~Se~l I,/!~./~tC~O//O ~ t//-~competent adult, being duly sworn according to law, del a true and correct copy of the NOrfice of Sheriff's Sale in the manner as set forth herein, issued in the address indicated above. Sworn to and subscribed before me this _/~ day of ~ .200 ~. No tary/k~~--~ .~ By: PLEASE ATTEMPT SERVICE AT LEAST 3 TIMES. INDICATE DATES & TIMES Notafla~ Se~J Lisa M. ~, Notmy Publk: NOT SERVED Carlisle Boro, Cumbeflarid Cou~y c mi ion · 200__, at o'clock __.m., Dct'cndant NC Moved __ Unknown__ No Answer __ Vacant 1st Attempt: / / Time: : 3rd Attempt: / / Time: : By: Sworn to and subscribed before me this day of ,200 _. Notary: Attorney for Plaintiff Frank Federman, Esquire - I.D. No. 12248 2ad Attempt: / 838558 '.tion Sheriff's Sale 9/4/02 day o fs~e~t~l~_, 200_~;~ Commonwealth )ther ose and state that I personally handed :he captioned case on the date and at DF SERVICE ATTEMPTED. T FOUND because: Time: : IN THE COURT OF COMMON PLEAS OF CUMBERLAND COUNTY, PENNSYLVANIA RE: COUNTRYWIDE HOME LOANS, INC. ) ) CIVIL ACTION VS. PHILIP A. LOWE ) CIVIL DIVISION ) NO. 02-1649-CIVIL AFFIDAVIT OF SERVICE PURSUANT TO RULE 3129 COMMONWEALTH OF PENNSYLVANIA ) COUNTY OF CUMBERLAND ) SS: I, FRANK FEDERMAN, ESQUIRE attorney for COUNTRYWIDE HOME LOANS, INC. hereby verify that on 5/13102 true and correct copies of the Notice of Sheriff's 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 5113102 by certified mail return receipt requested see Exhibit "B" attached hereto. DATE: July 12, 2002 FRArNK FEDERMAN, ESQUIRE Attorney for Plaintiff 7160 3901 9844 8031 6275 TO: PHILIP A. LOWE 2103 LOGAN STREET CAMP HILL, PA 17011 SENDER: KMD -SALES #5838558 REFERENCE: PS Form 3800, June 2000 iR~'ruR. [Postage RECEIPT |Ce~lied Fee SERVICE LRetum Receipt Fee  Reetricted Deliver/ I Total Postage & Fees US Postal Service Receipt for Certified Mail No Insurance Coverage Provided Do Not Use for International Mail .34 2.10 t.50 O.OO Pos ~ ~D^~¢~ Countrywide Home Loans, Inc. VS Philip A. Lowe In The Court of Common Pleas of Cumberland County, Pennsylvania Writ No. 2002-1649 Civil Term R. Thomas Kline, Sheriff, who being duly sworn according to law, states this writ is returned STAYED pursuant to instructions from Attorney Frank Federman. Sheriff's Costs: Docketing 30.00 Surcharge 20.00 Law Library .50 Prothonotary 1.00 Mileage 20.70 Levy 15.00 Advertising 15.00 Posting Handbills 15.00 Share of Bills 25.20 Poundage 255.18 Law Journal 358.40 Patriot News 280.15 Certified Mail 3.47 $1039.60 paid by attorney 09/05/02 Sworn and subscribed to before me This jJ ? dayof~ 2002, A.D.~~_~,~/ Prothonotary So Answers: R. Thomas Kline, Sheriff Real EsOte Deputy COUNTRYWIDE HOME LOANS, INC. Plaintiff, PHILIP A. LOWE : CUMBERLAND COUNTY : : COURT OF COMMON PLEAS : : CIVIL DIVISION Defendant(s). :: NO. 02-1~J~VI~ ~FmAVIT PreSOrT TO RULE 3129~ (Affidavit No. 1) COUNTRYWIDE HOME LOANS~ INC., Plaintiffin 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 ~2103 LOGAN STREET~ CAMP H1LL~ PA 17011. 1. Name and address of Owner(s) or reputed Owner(s): Name Last Known Address (if address cannot be reasonably ascertained, please indicate) PHILIP A. LOWE 2103 LOGAN STREET CAMP HILL, PA 17011 2. Name and address of Defendant(s) in the judgment: Same as above 3. Name and last known address of every judgment creditor whose judgment is a record lien on the real property to be sold: Natne Last Known Address (if address cannot be reasonably ascertained, please indicate) None COUNTRYWIDE HOME LOANS, INC. Plaintiff, PHILIP A. LOWE CUMBERLAND COUNTY COURT OF COMMON PLEAS : CIVIL DIVISION Defendant(s). :~ NO. 02-1~J~ AFFIDAVIT PURSUANT TO RULE 3129~ ~ ~ ,'7~, , Z" ~ ,~ COUNTRYWIDE HOME LOANS~ 1NC., Plaintiffin 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 ~2103 LOGAN STREET~ CAMP HILL~ PA 17011. 1. Name and address of Owner(s) or reputed Owner(s): Name Last Known Address (if address cannot be reasonably ascertained, please indicate) PHILIP A. LOWE 2103 LOGAN STREET CAMP HILL, PA 17011 2. Name and address of Defendant(s) in the judgment: Same as above 3. Name and last known address of every judgment creditor whose judgment is a record lien on the real property to be sold: NalTle None Last Known Address (if address cannot be reasonably ascertained, please indicate) 4. Name and address of last recorded holder of every mortgage of record: SaBle Last Known Address (if address cannot be reasonably ascertained, please indicate) None 5. Name and address of every other person who has any record lien on the property: Name Last Known Address (if address cannot be reasonably ascertained, please indicate) None 6. Name and address of every other person who has any record interest in the property and whose interest may be affected by the sale. Name Last Known Address (if address cannot be reasonably ascertained, please indicate) 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 Last Known Address (if address cannot be reasonably ascertained, please indicate) Tenant/Occupant 2103 LOGAN STREET CAMP HILL, PA 17011 Domestic Relations of Cumberland County 13 North Hanover Street Carlisle, PA 17013 Commonwealth of Pennsylvania Department of Welfare PO Box 2675 Harrisburg, PA 17105 I verify that the statements made in this affidavit are tree and correct to the best of my personal knowledge or information and belief. I understand that false statements herein are made subject to the penalties of 18 Pa. C.S. Sec. 4904 relati ,ng to unswom falsification to authorities. MAY 13, 2002 DATE FR,~aNK FEDERMAN, ESQUIRE Attorney for Plaintiff COUNTRYW~ID~ ~HOME LOANS, INC. : Plaintiff, : PHILIP A. LOWE : Defendant(s). : TO: PHILIP A. LOWE 2103 LOGAN STREET CAMP HILL, PA 17011 CUMBERLAND COUNTY No. 02-1649-CIVIL MAY 13, 2002 **THIS FIRM IS A DEBT COLLECTOR ATTEMPTING TO COLLECTA DEBTAND ANY INFORMATION OBTAINED WILL BE USED FOR THAT PURPOSE. IF YOU HA VE PREVIOUSLY RECEIVED A DISCHARGE IN BANKRUPTCYAND THIS DEBT WAS NOTREAFFIRMED, THIS IS NOTAND SHOULD NOTBE CONSTRUED TO BE AN ATTEMPT TO COLLECT A DEBT, BUT ONLY ENFORCEMENT OF A LIEN A GAINST PROPER TE * * Your house (real estate) at ~ 2103 LOGAN STREET~ CAMP HILL~ PA 17011, is scheduled to be sold at the Sherifl"s 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 $94~192.20 obtained by COUNTRYVirlDE HOME LOANS~ 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 To prevent this Sheriffs Sale, you must take immediate action: k The sale will be cancelled if you pay to the mortgagee the back payments, late charges, costs and reasonable attorney's fees due. To find out how much you must pay, you may call: (215) 563-7000. You may be able to stop the sale by filing a petition asking the Court to strike or open the judgment, if the judgment was improperly entered. You may also ask the Court to postpone the sale for good cause. 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 IHE SHERIFF'S SALE DOES TAKE PLACE 1. If the Sheriffs Sale is not stopped, your property will be sold to the highest bidder. You may find out the price bid by calling (215) 563-7000. 2. You may be able to petition the Court to set aside the sale if the bid price was grossly inadequate compared to the value of your property. 3. The sale will go through only if the buyer pays the Sheriffthe 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 wilt be paid out in accordance with this schedule unless exceptions (reasons why the proposed distribution is wrong) are filed with the Sheriff within ten (10) days after the distribution is filed. 7. You may also have other rights and defenses, or ways of getting your home back, if you act immediately after the sale. YOU SHOULD TAKE THIS PAPER TO YOUR LAWYER AT ONCE. IF YOU DO NOT HAVE A LAWYER OR CANNOT AFFORD ONE, GO TO OR TELEPHONE THE OFFICE LISTED BELOW TO FIND OUT WHERE YOU CAN GET LEGAL HELP. CUMBERLAND COUNTY ATTORNEY REFERRAL CUMBERLAND COUNTY BAR ASSOCIATION 2 LIBERTY AVENUE CUMBERLAND COUNTY COURTHOUSE CARLISLE, PA 17013 (717) 249-3166 (800) 990-9108 Legal Descriotion: ALL THAT CERTAIN PIECE AND PARCEL OF LAND SITUATE IN THE BOROUGH OF CAMP HILL. CUMBERLAND COUNTY, PENNSYLVANIA, MORE PARTICULARLY BOUNDED AND DESCRIBED AS FOLLOWSi TO WIT: BEGINNING AT A POINT ON THE WESTERLY LINEOF NORTH TWENTY-FIRST STREET AT THE INTERSECTION OF SAID STREET WITH THE SOUTHERLY LINE OF LOGAN STREET, THENCE IN A SOUTHERLy DIRECTION. ALONG NORTH TWENTY-FIRST STREET ONE HUNDRED FORTY-FIVE (145) FEET, MORE OR LESS, TO A POINT. SAID POINT BEING AT A DISTANCE OF THH~TY (30) FEET MEASURED IN A NORTHERLY DIRECTION FRoM THE NORTHER~N PROPERTY LINE OF CAMP HILL CEMETERY ASSOCIATION; THENCE IN A WESTERLY DIRECTION ALONG A LINE PARALLEL WITH THE NORTHERLY LINE OF CAMP HILL CEMETERY ASSOCIATION, SEVENTY-ONE (71) FEET TO A POLNT THENCE IN A NORTHERLY DIRECTION PARALLEL WITH THE WESTERN LINE OF NORTH TWENTY-FIRST STREET ONE HUNDRED FORTY-FIVE (145) FEET, MORE Oi~ LESS, TO A POINT ON THE SOUTHERN LINE OF LOGAN STREET; THENCE ALONG LOGAN STREET IN A_N EASTERLY DIRECT/ON SEVENTY-ONE (71) FEET TO A POINT, THE PLACE OF BEGINNING. BEING PART OF LOTS SEVENTY. SEVEN (77), SEVENTY-EIGHT (78), SEVENTY-NINE (79), EIGHTY (80) ANI} EIGHTY-ONE (81), AND A PORTION OF LOTS SEVENTY-SIX (76), ON THE PLAN OF LOTS KNOWN AS SECONU PLAN OF HAMILTON PLACE, SAID PLAN BEING RECORDED IN THE OFFICE OF THE RECORDER OF DEEDS CUMBERLAND COUNTY IN PLAN BOOK l, PAGE 46. BEING THE SAM~ PREMISES WHICH GRAYMOR, INC., A CORPORATION OF THE COMMONWEALTH OF PENNSYLV,ANIA, BY THE DEED DATED MARCH 9, 1956 AND RECORDED MARCH 15, 1956 BY THE RECORDEI~ OF DEEDS IN AND FOR CUMBERLAND COUNTY IN DEED BOOK .4, VOLUME 17, PAGE 283, GRANTED AND CONVEYED UNTO WILLL4aM M. KNAP[K AND GLORIA C. I~'APIK WAS DECEASED OCTOBER 2, 1984, AS EVIDENCED BY HER DEATH CERTIFICATE NO.4~11430, THUS VESTING SOLE INTEREST TO WILLIAM M. KNAPIK, GRANTOR HEREIN. Vested by Deed, dated 2-26-99, ipven by WHlinm M. KnapLk, widower to Philip A. Lowe, a single man and recorded 3-1-99 m Book 194 Page 1086 Tax Parcel ID #: 01-21-0271-191 Property Address 2103 Logan Street, Camp Hill, PA 1701 ! WRIT OF EXECUTION and/or ATTACHMENT COMMONWEALTH OF PENNSYLVANIA) NO 02-1649 Civil COUNTY OF CUMBERLAND) CIVIL ACTION - LAW TO THE SHERIFF OF Cumberland COUNTY: To satisfy the debt, interest and costs due COUNRYWlDE HOME LOANS, INC. PLANTIFF(S) From PHILIP A, LOWE, 2103 LOGAN ST., CAMP HILL PA 17011.. ( 1 ) You are directed to levy upon the property of the defendant(s) and to sell REAL ESTATE LOCATED AT 2103 LOGAN ST., CAMP HILL PA 17011. (SEE ATTACHED LEGAL DESCRIPTION.) (2) You are also directed to attach the property of the defendant(s) not levied upon in the possession of GARNISHEE(S) as follows: and to notify the garnishee(s) that: (a) an attachment has been issued; (b) the garnishee(s) is/are enjoined from paying any debt to or for the account of the defendant (s) and f~om 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 $94,192.20 L.L. Interest 5/14/02 - 9/4/02 ($15.48/day) $1,764.72 Due Prothy Atty's Comm % Other Costs AttyPaid $110.35 Plaintiff Paid $.50 $1.00 Date: MAY 13, 2002 REQUESTING PARTY: Name FRANK FEDERMAN, ESQ. Address: 1717 JFK BLVD., STE 1400 PHILDELPHIA PA 19103-1814 Attorney for: PLAINTIFF Telephone: (215) 563-7000 Supreme Court ID No. 12248 CURTIS R. LONG Prothonotary, Civil Division By: X~i ~_~ Real Estate Sale # 43 On June 7, 2002 the sherifflevied upon the defendant's interest in the real property situated in Borough of Camp Hill, Cumberland County, PA Known and numbered as 2103 Logan Street, Camp Hill, and more fully described on Exhibit "A" filed with this writ and by this reference incorporated herein. Date: June 7, 2002 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. 45 Writ No. 2002-1649 Civil Countrywide Home Loans, Inc. VS, Philip A~ Lowe Atty.: Frank Federrnan Legal Description: ALL THAT CERTAIN piece and parcel of land situate in the Bor- ough of Camp Hill, Cumberland Coma- ty, Pennsylvania. more particularly bounded and described as follows, to wit: BEGINNING at a point on the westerly line of North Twenty-First Street at the intersection of said street with the southerly line of Lo- gan Street, thence in a southerly direction along North Twenty-First Street one hundred forty-five {145) feet, more or less, to a point, said point being at a distance of thirty (30) feet measured in a northerly direction from the northern prop- erty line of Camp Hill Cemete ~ry As- sociation: thence in a westerly dj- SWORN TO AND SUBSCRIBED before me this 9 day of AUGUST 20.~9_~_02 46. BEING the same premises which Graymor. Inc.. a corporation of the Commonwealth of Pennsylvania, by the deed dated March 9, 1956 and recorded March 15, 1956 by the Recorder of Deeds in and for Cum- berland County in Deed Book A, Volume 17, Page 283, granted and conveyed unto William M. P~apik and Gloria C. KuapLk was deceased October 2. 1984. as evidenced by her death certificate No. 4511430, thus vesting sole interest to William M. Knaplk, grantor herein. Vested by Deed. dated 2-26-99, given by William M. ICuapik. wid- ower to Philip A. Lowe, a single man and recorded 3-1-99 in Book 194 Go~ Page 1086. THE PATRIOT NEWS SUNDAY PATRIOT NEWS Proof of Publication UnderAct No. 587, Approved May 16, 1929 mmonweaith of Pennsyivania, County of Dauphin} ss ly sworn according to law, deposes and says: he Patriot News Co., a corporation organized and existing under the laws of the its principal office and place of business at 812 to 818 Market Street, in the ~in, State of Pennsylvania, owner and publisher of ~ and Tho general circulation, printed and published at 812 to 818 Market Street, in the n to and subscribed before n;m'T~s 14th day 9/-~A~g~2002 A D My Commission Expires June 6. 2006 I NO'I~ARY PUBLI~ r Member. Pennsylvania Association Of NotadeSrvty commission expires June 6, 2006 CUMBERLAND COUNTY SHERIFFS OFFICE CUMBERLAND COUNTY COURTHOUSE CARLISLE, PA. 17013 Statement of Advertising Costs To THE PATRIOT-NEWS CO., Dr. For publishing the notice or publication attached hereto on the above stated dates Probating same Notary Fee(s) Total $ 278.40 $ 1.75 $ 280.15 Publisher's Receipt for Advertising Cost ,s Co., publisher of ~and Th n a Patdot-N w , newspapers of general wledge receipt of the aforesaid notice and publication costs and certifies that the same have PUBLICATION COPY S A L E #43 REAL ESTATE SALE NO~ 43 Writ No. 2002-1848 C6 ClvllTerm ntrywlde Home Loanl, Inc. ~ Phll~ A. Lowe ; Arty: Frank Federmen DESCRIPTION AU~ THAT CI~TAIN l~ce and l~cel of land simm in t~ B0mu~ of Camp Eill, Cum~r- hou~tt~ 8escri~Is follows to ~it: BF~INN]NG ata po~t on th~ wes~rly linc of N?~ Tw~ty-Fir~t ,~u~t ~t th~ intorscainu of ~d strut ~th ~ ~uthe~y li~ of Lo~n S~ct, dicnee i'~ ~ ~tit~rly 8irccllon Nor~ Twenty-Flint Street o~c hundred fo.y-five (145) feet, more m' I~ss, to a point, said point b~ing at a distance of ~ (30) feet m~t in ]mc of Camp I-fill Cemete~ A.oci~on; thence in a .w_~t~rIy direct/on along a line pa~ e with t~ 'northerly line of Camp Hill Cemet~ Association, seveaty-oae (71) feet to a point thence in a nort~ direction pandlel Nth the western fine of Nor~ Twenty-Fire St~t one hundm/fo~-~ 045) fe~ mom or Feint on thc southenl linc of Logan aloag Logan $~et in a~ ~rly ~ir~tion ~w~nty-one (71) f~et to a point, the phce of BEGINNING. BEING pm of I~ ~nty-se.~n (77), allht (78), se'~ty-nth* (79), eighty (80) and Hgh~-oae (8l), aal a Ixntion of lots ~'~'enty-sin (76),.°e the pthn bf lot~ lmowa ~ S*nr~:l Hah of ltaml~a Place, ~ pla~ being recon~ in the Office of th* Rmader of ~ of Cum~rlan~ Couoty in Phn l~xY, t l~ page 46, BEING the same l~emizs which Graymot, ]nc., a corporation of tl~ Commonw~lth of hramylvadi[ by ~ deed dated March 9 1956 and reeora~l M~, 195ti by the R~conter of Dee. ds in and for Cu~berinnd County in Deed Book A, ~inme 17, Page 283, granted md conv~ unto Wlllinm l~. Knapik and Ginria C. Cit' Tax Parcel ID #01-21-0271-191. Property Address 2103 Logan S~[ Street, Camp HIlL PA 17011. Cit~, ....... · ~ tt 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. · FEDERMAN AND PHELAN, LLP By: Frank Federman, Esquire Atty. I.D. No.: 12248 One Penn Center at Suburban Station Suite 1400 Philadelphia, PA 19103-1814 (215) 563-7000 Attorney for Plaintiff COUNTRYWIDE HOME LOANS, INC. Plaintiff VSo Court of Common Pleas CUMBERLAND County No. 02-1649-CIVIL PHILIP A. LOWE Defendant(s) PRAECIPE TO WITHDRAW COMPLAINTt WITHDRAW JUDGMENT AND DISCONTINUE AND_ END ACTION, WITHOUT PREJUDICE_ TO THE PROTHONOTARY: Kindly withdraw the complaint filed in the instant matter, without prejudice, withdraw the judgment entered on 05/13/02 in the amount of $94,192.20 and mark this case discontinued and ended, upon payment of your costs only. Date Frank Federman Attorney for Plaintiff