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Home My WebLink About02-1792HOMESIDE LENDING, INC. IN THE COURT OF COMMON PLEAS Plaintiff CUMBERLAND COUNTY, PENNSYLVANIA VS. CIVIL ACTION - LAW RONALD A. SAYLOR AND ACTION OF MORTGAGE FORECLOSURE MICHELLE K. SAYLOR Defendants ?2 - / ? Q' •Z ? U? IEI? THIS FIRM IS A DEBT COLLECTOR AND WE ARE ATTEMPTINGTO COLLECT A DEBT OWED TO OUR CLIENT. ANY INFORMATION OBTAINED FROM YOU WILL BE USED FOR THE PURPOSE OF COLLECTING THE DEBT. NOTICE You have been sued in court. If you wish to defend against the claims set forth in the following pages, you must take action within twenty (20) days after the 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 claim in the Complaint of 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 LAWYER REFERRAL SERVICE CUMBERLAND COUNTY BAR ASSOCIATION 2 LIBERTY AVENUE CARLISLE, PA 17013 717-249-3166 AVISO LE HAN DEMANDADO A USTED EN LA CORTE. SI DESEA DEFENDERSE CONTRA LAS QUEJAS PERESENTADAS, ES ABSOLUTAMENTE NECESSARIO QUE USTED RESPONDA DENTRO DE 20 DIAS DESPUES DE SER SERVIDO CON ESTA DEMANDA Y AVISO. PARA DEFENDERSE ES NECESSARIO QUE USTED, O SU ABOGADO, REGISTRE CON LA CORTE EN FORMA ESCRITA, EL PUNTO DE VISTA DE USTED Y CUALQUIER OBJECCION CONTRA LAS QUEJAS EN ESTA DEMANDA. RECUERDE: SI USTED NO REPONDE A ESTA DEMANDA, SE PUEDE PROSEGUIR CON EL PROCESO SIN SU PARTICIPACION. ENTONCES, LA COUTE PUEDE, SIN NOTIFICARIO, DECIDIR A FAVOR DEL DEMANDANTE Y REQUERIRA QUE USTED CUMPLA CON TODAS LAS PROVISIONES DE ESTA DEMANDA. POR RAZON DE ESA DECISION, ES POSSIBLE QUE USTED PUEDA PERDER DINERO, PROPIEDAD U OTROS DERECHOS IMPORTANTES. LLEVE ESTA DEMANDA A UN ABOGADO IMMEDIATEAMENTE. SI NO CONOCE A UN ABOGADO, LLAME AL "LAWYER REFERENCE SERVICE" (SERVICIO DE REFERENCIA DE ABOGADOS), (215) 238-6300. CUMBERLAND COUNTY LAWYER REFERRAL SERVICE CUMBERLAND COUNTY BAR ASSOCIATION 2 LIBERTY AVENUE CARLISLE, PA 17013 717-249-3166 HOMESIDE LENDING, INC., IN THE COURT OF COMMON PLEAS Plaintiff CUMBERLAND COUNTY, PENNSYLVANIA VS. RONALD A. SAYLOR AND MICHELLE K. SAYLOR, Defendants CIVIL ACTION LAW ACTION OF MORTGAGE FORECLOSURE THE FOLLOWING NOTICE IS BEING PROVIDED PURSUANT TO THE FAIR DEBT COLLECTION PRACTICES ACT, 15 U.S.C. 1601 The undersigned attorney is attempting to collect a debt owed to the Plaintiff, and any information obtained will be used for that purpose. The amount of the debt is stated in this Complaint. Plaintiff is the creditor to whom the debt is owed. Unless the Debtor, within thirty (30) days after your receipt of this notice disputes the validity of the aforesaid debt or any portion thereof owing to the Plaintiff, the undersigned attorney will assume that said debt is valid. If the Debtor notifies the undersigned attorney in writing with the said thirty (30) day period that the aforesaid debt, or any portion thereof , is disputed, the undersigned attorney shall obtain written verification of the said debt from the Plaintiff and mail same to Debtor. Upon written request by Debtor to the undersigned attorney within said thirty (30) day period, the undersigned attorney will provide debtor with the name and address of the original creditor if different from the current creditor. PURCELL, KRUG & HALLER 1719 North Front Street Harrisburg, PA 17102 (717) 234-4178 Attorney I.D.# 15700 Attorney for Plaintiff HOMESIDE LENDING, INC., Plaintiff VS. IN THE COURT OF COMMON PLEAS CUMBERLAND COUNTY, PENNSYLVANIA CIVIL ACTION - LAW RONALD A. SAYLOR AND ACTION OF MORTGAGE FORECLOSURE MICHELLE K. SAYLOR, Defendant oz - 17 4 ';L' COMPLAINT IN MORTGAGE FORECLOSURE 1. Plaintiff, HOMESIDE LENDING, INC., is a corporation, with an address of 8120 NATIONS WAY, BUILDING 100 JACKSONVILLE, FLORIDA 32256. 2. Defendant, RONALD A. SAYLOR, is an adult individual, whose last known address is 688B WILLS PARK ROAD, BRIDGTON, MAINE 04009. Defendant, MICHELLE K. SAYLOR, is an adult individual, whose last known address is 688B WILLIS PARK ROAD, BRIDGTON, MANIE 04009. 3. On or about, August 05, 1996, the said Defendants executed and delivered a Mortgage Note in the sum of $77,000.00 payable to BARNETT MORTGAGE COMPANY, which Note is attached hereto and marked Exhibit "A". 4. Contemporaneously with and at the time of the execution of the aforesaid Mortgage Note, in order to secure payment of the same, Defendants made, executed, and delivered to original Mortgagee, a certain real estate Mortgage which is recorded in the Recorder of Deeds Office of the within County and Commonwealth in Mortgage Book 1334, Page 1103 conveying to original Mortgagee the subject premises. The Said Mortgage was subsequently assigned to HOMESIDE LENDING, INC. and recorded in the aforesaid County in Mortgage Book 545, Page 679. The Said Mortgage and Assignments are incorporated herein by reference. 5. The land subject to the Mortgage is: 39 BROAD STREET, NEWVILLE, PENNNSYLVANIA 17241 and is more particularly described in Exhibit "B" attached hereto. 6. The said Defendants are the real owners of the property. 7. The Mortgage is in default due to the fact that Mortgagors have failed to pay the installment due on October 01, 2001 and all subsequent installments thereon, and the following amounts are due on the Mortgage: UNPAID PRINCIPAL BALANCE Interest at $17.89 per day From 09/01/2001 To 05/01/2002 ( based on contract rate of 8.875%) Accumulated Late Charges Late Charges $30.63 From 10/01/2001 to 05/01/2002 Escrow Balance Attorney's Fee at 5% of Principal Balance TOTAL $73,608.63 $4,883.97 $183.78 $275.66 $1,457.68 $3,680.43 $84,090.15 "Together with interest at the per diem rate noted above after May 01, 2002 and other charges and costs to date of Sheriff's Sale. The attorney's fees set forth above are in conformity with the Mortgage documents and Pennsylvania law, and will be collected in the event of a third party purchaser at Sheriff's Sale. If the Mortgage is reinstated prior to the sale, reasonable attorney's fees will be charged that are actually incurred by Plaintiff. 8. No judgment has been entered upon said Mortgage in any jurisdiction. 9. Notice of intention to foreclose and accelerate the loan balance pursuant to Pennsylvania Act No. 6 of 1974 is not required in that the original principal balance exceeds $50,000.00. 10. Defendants are not members of the Armed Forces of the United States of America, nor engaged in any way which would bring them within the Soldiers and Sailors Relief Act of 1940, as amended. 11. Plaintiff has complied with the procedure required by Pennsylvania Act 91 of 1983 (Homeowners' Emergency Mortgage Assistance Payments Program) and Defendants have either failed to meet the time limitations as set forth therein or have been determined by the Housing Finance Agency not to qualify for assistance. WHEREFORE, Plaintiff demands judgment in mortgage foreclosure "IN REM" for the aforementioned total amount due together with interest at the rate of 8.875% ($17.89 per diem), together with other charges and costs including escrow advances incidental thereto to the date of Sheriffs Sale and for foreclosure and sale of the property within described. By: PURCELL, KRU HALLER Leon P. Haller, Esquire Attorney for Plaintiff I.D. # 15700 1719 N. Front Street Harrisburg, PA 17102 (717-234-4178) Hs161436.tit (1696x2800x2 titt) L31 LOAM AVMT 46. 10" OWN w •. SCHRO M'6 FROM M TO PAY b raLln for . bn ON 1 errs I pamr• m Ma a it GL%d Ta4MW& pus m Go wdw A, IrY YILMMMIL dM-rN lM?f 1111% ? 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Haller, Esquire, hereby swear and affirm that the facts contained in the foregoing COMPLAINT for Mortgage Foreclosure are true and correct to the best of my knowledge, information, and belief based upon information provided by Plaintiff HOMESIDE LENDING, INC. Said facts contained herein are made subject to the penalties of 18 Pa.C.S. Section 4904 relating to unsworn falsification to authorities. Date: April 8, 2002 -i 17 Leon P. Haller, Esquire w ? I 2 ' n c. { ?s r C7 ?D i '- 1 11 t ?^t 6 SHERIFF'S RETURN - NOT FOUND CASE NO: 2002-01792 P COMMONWEALTH OF PENNSYLVANIA COUNTY OF CUMBERLAND HOMESIDE LENDING INC VS SAYLOR RONALD A ET AL R. Thomas Kline Sheriff or Deputy Sheriff, who being duly sworn according to law, says, that he made a diligent search and inquiry for the within named defendant, DEFENDANT SAYLOR RONALD A but was unable to locate Him in his bailiwick. He therefore returns the COMPLAINT - MORT FORE NOT FOUND as to the within named DEFENDANT SAYLOR RONALD A HOUSE IS VACANT. SAYLOR BELIEVED TO BE LIVING IN BRIDGTON, ME. Sheriff's Costs: So answers Docketing 18.00 Service 8.28 f? Not Found 5.00 Thomas Kline Surcharge 10.00 Sheriff of Cumberland County .00 41.28 PURCELL KRUG HALLER 04/19/2002 Sworn and subscribed to before me this o2Sirr- day of o2avz A. D. L), a Prot otary 4j'4? SHERIFF'S RETURN - NOT FOUND CASE NO: 2002-01792 P COMMONWEALTH OF PENNSYLVANIA COUNTY OF CUMBERLAND HOMESIDE LENDING INC VS SAYLOR RONALD A ET AL R. Thomas Kline ,Sheriff or Deputy Sheriff, who being duly sworn according to law, says, that he made a diligent search and inquiry for the within named defendant, DEFENDANT SAYLOR MICHELLE K but was unable to locate Her in his bailiwick. He therefore returns the COMPLAINT - MORT FORE , the within named DEFENDANT NOT FOUND , as to SAYLOR MICHELLE K HOUSE VACANT. SAYLOR BELIEVED TO BE LIVING IN BRIDGTON, ME. Sheriff's Costs: So ans Docketing 6.00 Service .00/ Affidavit .00 R. omas Kline Surcharge 10.00 Sheriff of Cumberland County .00 16.00 PURCELL KRUG HALLER 04/19/2002 Sworn and subscribed to before me this a5 day of aoDZ A.D. C? Pr Notary HOMESIDE LENDING, INC. Plaintiff IN THE COURT OF COMMON PLEAS CUMBERLAND COUNTY, PENNSYLVANIA vs. RONALD A. SAYLOR AND MICHELLE K. SAYLOR CIVIL ACTION - LAW ACTION OF MORTGAGE FORECLOSURE Defendants No. 02-1792 CIVIL TERM TO THE PROTHONOTARY; RETURN OF SERVICE Kindly file the Out of State Service Return on the above captioned matter. DATE: July 8, 2002 PURCELL, BY Leon . Haller 1719 North Front Street Harrisburg, Pa. 17102 Attorney for Plaintiff Attorney ID# 15700 COURT OF COMMON PLEAS OF CUMBERLAND COUNTY 9T" JUDICIAL DISTRICT COMMONWEALTH OF PENNSYLVANIA AFFIDAVIT OF SERVICE OF PROCESS HOMESIDE LENDING, INC. Plaintiff versus RONALD A. SAYLOR AND MICHELLE K. SAYLOR Defendant NO.2002-01792 CIVIL ACTION -LAW IN MORTGAGE FORECLOSURE Know all persons by these presents that I, Daniel Collis execute this service upon the following defendant: RONALD SAYLOR at 4 EAGLE LEDGE ROAD MEREDITH NEW HAMPSHIRE 03253. I hereby depose and say: 1) That I am of the necessary age and sound mind to execute said service. 2) That I am not a party to the action or have any interest in it. per. I hereby certify that on June ? copy of the NOTICE AND CO?vlpL,glNT?were se ed onl the al b e?-nameri?Pamm, or witness nothe t following manner: ? I personally delivered them into the hands of the person to be served. ® By leaving a copy at his/her usual place of abode with Michelle Savlor ,whose relationship to the defendant is spouse and also residing therein. ,and who is of suitable age and discretion ? By leaving a copy with defendant resides. the manageNclerk of place of lodging in which ? By leaving a copy with usual place of business. Job title or position of agent she agent in charge of defendant's office or ? After due and diligent efforts, described below, I was unable to serve the process because: Description of Recipient: Sex: F Race: W Approximate Height: ,??!' FURTHER AFFIDAVIT SAYTH NOT Sign- Process Server Daniel Collis, Sheriff Belknap County, New Hampshire Approximate Weight: ?]3 Approximate Age: 40 Subscribed and sworn to before me this 1 y ? day of June , 2002. Notary Public a, °', ? ?* 5 ?-? :^';"P.CI,?FICIAL SEAL „?. EVELYN B. SANVILLE PUatIC NOTARY PUBLIC NEWHAMPSHIRE Comm. Expires Nov. 7, 2006 COURT OF COMMON PLEAS OF CUMBERLAND COUNTY 9T" JUDICIAL DISTRICT COMMONWEALTH OF PENNSYLVANIA AFFIDAVIT OF SERVICE OF PROCESS HOMESIDE LENDING, INC. Plaintiff versus RONALD A. SAYLOR AND MICHELLE K. SAYLOR Defendant NO. 2002-01792 CIVIL ACTION - LAW IN MORTGAGE FORECLOSURE Know all persons by these presents that I, Daniel Collis execute this service upon the following defendant: MICHELLE SAYLOR at 4 as assigned to duly EAGLE LEDGE ROAD MEREDITH NEW HAMPSHIRE 03253. 1 hereby depose and say: 1) That I am of the necessary age and sound mind to execute said service. 2) That I am not a party to the action or have any interest in it. 3) ues? ??# i?k# =? ree0Un4yj44WVVykm,9ed.Pfii?raIe g I hereby certify that on June 13 z,200bt approximately __2_; I]axm. Xllp m. a true and correct copy of the NOTICE AND COMPLAINT were served on the above-named party or witness in the following manner: 9 1 personally delivered them into the hands of the person to be served. ? By leaving a copy at his/her usual place of abode with relationship to the defendant is whose and also residing therein. and who is of suitable age and discretion ? By leaving a copy with defendant resides, the manager/clerk of place of lodging in which ? By leaving a copy with the agent in charge of defendant's office or usual place of business. Job title or position of agent is ? After due and diligent efforts, described below, I was unable to serve the process because: Description of Recipient: Sex: F Race: -W_ Approximate Height:5' 2" Approximate Weight: 113 Approximate Age: 40 FU IDAVIT SAYTH NOT. Signature of Process Server Daniel Collis, Sheriff Belknap County, New Hampshire , Subscribed and sworn to before me this /y '* day of June 2002. - &64(22 Notary Pu lic mPMKAIEAL NoTAeY EVELYN B. SANVILLE PUBLIC NOTARY PUBLIC t NEW HAMPSHIRE MY Comm. Expires Nov. 7, 20o6 a c v ? ? l l l Mil Z ? tJ tU l « v17 rn u < cn - HOMESIDE LENDING, INC. Plaintiff : VS. RONALD A. SAYLOR AND MICHELLE K. SAYLOR Defendants IN THE COURT OF COMMON PLEAS CUMBERLAND COUNTY, PENNSYLVANIA NO. 02-1792 CIVIL TERM CIVIL ACTION - LAW - IN MORTGAGE FORECLOSURE P R A E C I P E TO THE PROTHONOTARY OF THE WITHIN COUNTY: Please enter JUDGMENT "in rem" in favor of the Plaintiff and against Defendants Ronald A. Saylor and Michelle K. Saylor for failure to plead to the above action within twenty (20) days from date of service of the Complaint, and assess Plaintiff's damages as follows: Unpaid principal balance $73,608.63 Interest $ 4,883.97 (Per diem of $17.89 from 9/1/01 to 5/1/02) Accumulated late charges and Late charges $ 459.44 ($30.63 per month to 5/02) Escrow Deficit $ 1,457.68 5% Attorney's Commission $ 3.680.43 TOTAL $84,090.15** ** Together with additional interest at the per diem rate indicated above from may 1, 2002, based on the contract rate, and other charges and costs to the date of Sheriff's Sale. PURCELL, KRUG BY d11 P. Haller PA I.D. #15700 1719 North Front Street Harrisburg, PA 17102 (717) 234-4178 HOMESIDE LENDING, INC. Plaintiff VS. RONALD A. SAYLOR AND MICHELLE K. SAYLOR Defendants IN THE COURT OF COMMON PLEAS CUMBERLAND COUNTY, PENNSYLVANIA NO. 02-1792 CIVIL TERM CIVIL ACTION - LAW - IN MORTGAGE FORECLOSURE NON-MILITARY AFFIDAVIT COMMONWEALTH OF PENNSYLVANIA COUNTY OF DAUPHIN SS Personally appeared before me, a Notary Public in and for said Commonwealth and County, LEON P. HALLER, ESQUIRE who being duly sworn according to law deposes and states that the Defendant(s) above named are not in the military or Naval Service nor are they engaged in any way which would bring them within the Soldiers and Sailors Relief Act of 1940, as amended. Sworn to and sub cr,}}•bed : bef` ?re me this ju bed : of Tp4i tbLV 20 0a NOTARIAL SEAL ANGELA J. GLASS, Notary Public City of Harrisburg Dauphin County -qty Commission Expires May 12, 2003 t4 . HALLER, ESQUIRE HOMESIDE LENDING, INC. IN THE COURT OF COMMON PLEAS Plaintiff CUMBERLAND COUNTY, PENNSYLVANIA VS. NO. 02-1792 CIVIL TERM RONALD A. SAYLOR AND MICHELLE CIVIL ACTION - LAW - K. SAYLOR IN MORTGAGE FORECLOSURE Defendants CERTIFICATE OF SERVICE I hereby certify that on July 10, 2002 I served the Ten Day Notice required by Pa. R.C.P. 237.1 upon the Defendant(s) in this matter by regular first class mail, postage prepaid, as indicated on the attached Notice. PURCELL, KRUG & HALLER By Le Haller PA I.D. #15700 rney for Plaintiff 1719 North Front Street Harrisburg, PA 17102 Dated: September 10, 2002 HOMESIDE LENDING, INC. Plaintiff VS. IN THE COURT OF COMMON PLEAS CUMBERLAND COUNTY, PENNSYLVANIA NO. 02-1792 CIVIL TERM RONALD A. SAYLOR AND MICHELLE K. SAYLOR Defendants DATE OF THIS NOTICE: July 10, 2002 TO: RONALD A.SAYLOR 4 EAGLE LEDGE ROAD MEREDITH, NEW HAMPSHIRE 03253 MICHELLE K. SAYLOR 4 EAGLE LEDGE ROAD MEREDITH, NEW HAMPSHIRE 03253 CIVIL ACTION LAW IN MORTGAGE FORECLOSURE THIS LAW FIRM IS A DEBT COLLECTOR AND WE ARE ATTEMPTING TO COLLECT A DEBT OWED TO OUR CLIENT. ANY INFORMATION OBTAINED FROM YOU WILL BE USED FOR THE PURPOSE OF COLLECTING THE DEBT. 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 LAWYER REFERRAL SERVICE CUMBERLAND COUNTY BAR ASSOCIATION 2 LIBERTY AVENUE CARLISLE, PA 17013 (717) 249-3168 (800) 990-9108 PURCELL EON P. HALLER, Attomey or Plaintiff I.D. # 15700 1719 N. Front St., Harrisburg, PA 17102 (717) 234-4178 -Ti r_ n ri c n -: HOMESIDE LENDING, INC. IN THE COURT OF COMMON PLEAS Plaintiff : CUMBERLAND COUNTY, PENNSYLVANIA VS. NO. 02-1792 CIVIL TERM RONALD A. SAYLOR AND CIVIL ACTION - LAW - MICHELLE K. SAYLOR IN MORTGAGE FORECLOSURE Defendants PRAECIPE FOR WRIT OF EXECUTION (MORTGAGE FORECLOSURE) P.R.C.P. 3180-3183 TO THE PROTHONOTARY: Issue Writ of Execution in the above matter on the real estate located at 39 Broad Street, Newville, PA 17241 as follows: Amount due pursuant to Judgment $84,090.15 Interest (Per diem of $17.89 from 5/1/02 to 12/4/02) $ 3,882.13 Late Charges at $30.63 (5/02 to 12/02) $ 214.41 Escrow deficit $ 1,500.00 TOTAL WRIT $89,686.69** ** Together with any additional interest, char nd costs to the date of Sheriffs Sale. By Dated: September 10, 2002 -,-CbEON P. HALLER IA). #15700 ATTORNEY FOR PLAINTIFF 1719 North Front Street Harrisburg, PA 17102 (717) 234-4178 Attached is a description of the real estate. ?` C b C C b C b c? , a o N , 77 ti T c"I LEGAL DESCRIPTION ALL that certain tract or parcel of land and premises, situate, lying and being in the Borough of Newville in the County of Cumberland and Commonwealth of Pennsylvania, more particularly bounded and described as follows: BEGINNING at a point in the Southern side of Broad Street, which point is a corner of lot now or formerly of Gerald Reid; thence in a southwardly direction along lot now or formerly of Gerald Read, a distance of one hundred eighty (180) feet to a point in the Northern side of an alley thirty (30) feet in width; thence along the Northern side of said alley in a Westwardly direction a distance of thirty-three (33) feet, nine (9) inches to a point in line of lot now or formerly of Jeffrey Shearer; thence in a Northwardly direction along lot now or formerly of Jeffrey Shearer, a distance of one hundred eighty (180) feet to a point in the Southern side of said Broad Street; thence in an Eastwardly direction along the Southern side of said Broad Street, a distance of thirty-three (33) feet, nine (9) inches to a point, the place of BEGINNING. HAVING THEREON ERECTED A DWELLING KNOWN AS 39 Broad Street, Newville, Pennsylvania BEING THE SAME PREMISES which Joseph J. Butchko and Ann K. Butchko, by Deed dated August 5, 1996 and recorded August 5, 1995 in Deed Book 143, Page 920, granted and conveyed unto Ronald A. Saylor and Michelle K. Saylor. TO BE SOLD AS THE PROPERTY OF RONALD A. SAYLOR AND MICHELLE K. SAYLOR UNDER JUDGMENT NO. 2002-1792 CIVIL TERM PARCEL NO. 28-21-0361-067 HOMESIDE LENDING, INC. Plaintiff VS. RONALD A. SAYLOR AND MICHELLE K. SAYLOR Defendants IN THE COURT OF COMMON PLEAS CUMBERLAND COUNTY, PENNSYLVANIA NO. 02-1792 CIVIL TERM CIVIL ACTION - LAW - IN MORTGAGE FORECLOSURE AFFIDAVIT PURSUANT TO P.R.C.P. 3129.1 The Plaintiff in the above action, by its attorneys, Purcell, Krug & Haller, sets forth as of the date the praecipe for the writ of execution was filed, the following information concerning the real property located at 39 Broad Street, Newville, PA 17241: 1. Name and address of the Owner(s) or Reputed Owner(s): Ronald A. Saylor 4 Eagle Ledge Road Meredith, NH 03253 Michelle K. Saylor 4 Eagle Ledge Road Meredith, NH 03253 2. Name and address of Defendant(s) in the Judgment, if different from that listed in (1) above: SAME 3. Name and address of every judgment creditor whose judgment appears of record on the real property to be sold: UNKNOWN 4. Name and address of last recorded holder of every mortgage of record: PLAINTIFF HEREIN (AND ANY OTHERS AS NOTED BELOW): Cityscape Corp. 565 Taxter Road Elmsford, NY 10523 5. Name and address of every other person who has any record lien on the property: UNKNOWN 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: UNKNOWN 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: TENANTS IF ANY ... Tenant/Occupant 39 Broad Street Newville, PA 17241 DOMESTIC RELATIONS OFFICE 13 North Hanover Street Carlisle, PA 17013 (In the preceding information, where addresses could not be reasonably ascertained, the same is indicated.) I verify that the statements made in this Affidavit are true and correct to the best of my personal knowledge, information and belief. I understand that false statements herein are made subject to the penalties of 18 PA C.S. Section 4904 relating to unsworn falsification to authorities. Le Haller PA I.D. #15700 urcell, Krug & Haller 1719 North Front Street Harrisburg, PA 17102 (717) 234-4178 DATE: September 10, 2002 1 !] ? ? { mr r ; ?;-_ r.- .. ? -. _ - Y its i ; 1i HOMESIDE LENDING, INC. Plaintiff VS. RONALD A. SAYLOR AND MICHELLE K. SAYLOR Defendants IN THE COURT OF COMMON PLEAS CUMBERLAND COUNTY, PENNSYLVANIA NO. 02-1792 CIVIL TERM CIVIL ACTION - LAW - IN MORTGAGE FORECLOSURE NOTICE OF SHERIFF'S SALE OF REAL ESTATE PURSUANT TO PENNSYLVANIA RULE OF CIVIL PROCEDURE 3129 TAKE NOTICE: held: That the Sheriff's Sale of Real Property (real estate) will be DATE:WEDNESDAY, DECEMBER 4, 2002 TIME:10:00 O'clock A.M. LOCATION: Commissioner's Hearing Room 2nd Floor Cumberland County Courthouse Carlisle, Pennsylvania 17013 THE PROPERTY TO BE SOLD is delineated in detail in a legal description mainly consisting of a statement of the measured boundaries of the property, together with a brief mention of the buildings and any other major improvements erected on the land. (SEE DESCRIPTION ATTACHED) THE LOCATION of your property to be sold is: 39 BROAD STREET, NENVILLE, PA 17241 THE JUDGMENT under or pursuant to which your property is being sold is docketed in the within Commonwealth and County to: 2002-1792-CIVIL is: THE NAME(S) OF THE OWNER(S) OR REPUTED OWNERS of this property RONALD A. SAYLOR AND MICHELLE K. SAYLOR ersons and/or DISTRIBIITION, being a list of the entitled to IILE OF age ncies being A SCHED corporate entities or and to be governmental or proceeds of the sale receive th8 hold mortgages art of the for example' to banks receive P the Sheriff ( will be filed by the disbursed by that are owed taxes) after the sale and and municipalities thirty (30) days Sheriff of this county thirty of sale in accordanceeC sh byffiling distribution of'the p is fil ll, in fact, be made unless £ the date it schedule wi ed. exceptions ll it within ten (10) days be obtained Information ? Distribution may County out the Court of schedule pleas of the within from the Sheriff of the specified herein. at the Courthouse address xwn PLACB OF THE SALE OF YOIIR PROPERTY. PAY THE JIID? from being you may have legal rights to prevent your property . A lawyer can advise you more specifically of these rights YOU MAST ACT taken away . If you wish to exercise your rights, PROMPTLY. Go TO OR LAwY ONCE - YOU STHE OFFICE SETSFORTHRBELOWOTO FINDEOUTTWHERE YOU CAN GET TELEPHONE FREE LEGAL ADVICE: Cumberland County Bar Association 2 Liberty Avenue Carlisle, Pennsylvania 17013 Phone (800-990-9108 ) 9 6 THE LEGAL RIGHTS YOU MAY HAVE ARE: 1. You may file a petition with the Court of Common Pleas of the within County to open the judgment if you have a meritorious defense against the person or company that has entered judgment against you. You may also file an petition with the same Court if you are aware of a legal defect in the obligation or the procedure used against you. 2. After the Sheriff's Sale you may file a petition with the Court of Common Pleas of the within County to set aside the sale for a grossly inadequate price or for other proper cause. This petition MUST BE FILED BEFORE THE SHERIFF'S DEED IS DELIVERED. 3. A petition or petitions raising the legal issues or rights mentioned in the preceding paragraphs must be presented to the Court of Common Pleas of the within County. The petition must be served on the attorney for the creditor or on the creditor before presentation to the court and a proposed order or rule must be attached to the petition. If a specific return date is desired, such date must be obtained from the Court Administrator's Office - Civil Division, of the within County Courthouse, before a presentation of the petition to the Court. A copy of the Writ of Execution is attached hereto. PURCELL, KRUG & HALLER Attorneys for Plaintiff 1719 North Front Street Harrisburg, PA 17102 (717) 234-4178 LEGAL DESCRIPTION ALL that certain tract or parcel of land and premises, situate, lying and being in the Borough of Newville in the County of Cumberland and Commonwealth of Pennsylvania, more particularly bounded and described as follows: BEGINNING at a point in the Southern side of Broad Street, which point is a corner of lot now or formerly of Gerald Reid; thence in a southwardly direction along lot now or formerly of Gerald Read, a distance of one hundred eighty (180) feet to a point in the Northern side of an alley thirty (30) feet in width; thence along the Northern side of said alley in a Westwardly direction a distance of thirty-three (33) feet, nine (9) inches to a point in line of lot now or formerly of Jeffrey Shearer; thence in a Northwardiy direction along lot now or formerly of Jeffrey Shearer, a distance of one hundred eighty (180) feet to a point in the Southern side of said Broad Street; thence in an Eastwardly direction along the Southern side of said Broad Street, a distance of thirty-three (33) feet, nine (9) inches to a point, the place of BEGINNING. HAVING THEREON ERECTED A DWELLING KNOWN AS 39 Broad Street, Newville, Pennsylvania BEING THE SAME PREMISES which Joseph J. Butchko and Ann K. Butchko, by Deed dated August 5, 1996 and recorded August 5, 1995 in Deed Book 143, Page 920, granted and conveyed unto Ronald A. Saylor and Michelle K. Saylor. TO BE SOLD AS THE PROPERTY OF RONALD A. SAYLOR AND MICHELLE K. SAYLOR UNDER JUDGMENT NO. 2002-1792 CIVIL TERM PARCEL NO. 28-21-0361-067 T ,,,: -? ?u? ', ,, : _ _,, _. . , , _ ? :. - ? ?= - .. _, ; ?, <n WRIT OF EXECUTION and/or ATTACHMENT COMMONWEALTH OF PENNSYLVANIA) COUNTY OF CUMBERLAND) NO 02-1792 Civil CIVIL ACTION - LAW TO THE SHERIFF OF CUMBERLAND COUNTY: To satisfy the debt, interest and costs due HOMESIDE LENDING, INC. Plaintiff (s) From RONALD A. SAYLOR AND MICHELLE K. SAYLOR (1) You are directed to levy upon the property of the defendant (s)and to sell SEE ATTATCHED LEGAL DESCRIPTION. (2) You are also directed to attach the property of the defendant(s) not levied upon in the possession of GARNISHEE(S) as follows: and to notify the garnishee(s) that: (a) an attachment has been issued; (b) the garnishee(s) is enjoined from paying any debt to or for the account of the defendant (s) and from delivering any property (s) or otherwise disposing thereof; of the defendant (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$84,090.15 L.L.$.50 Interest (PER DIEM OF $17.89 FROM5/1/02 TO 12/4/02) $3,882.13 Late charges at $30.63 (5/02 to 12/02) $214.41 Any's Comm % Due Prothy $1.00 Atty Paid $129.28 Other CostsEscrow deficit $1,500.00 Plaintiff Paid Date: September 10, 2002 Together with any additional interest, charges and costs to the date of Sheriff's Sale. CURTIS R. LONG (Seal) Prothonotary By --vall_ REQUESTING PARTY: Deputy Name Leon P. Haller, Esq. Address: 1719 North Front Street Harrisburg, PA 17102 Attorney for: Plaintiff Telephone: 717-234-4178 Supreme Court ID No. 15700 HOMESIDE LENDING, INC. IN THE COURT OF COMMON PLEAS Plaintiff : CUMBERLAND COUNTY, PENNSYLVANIA vs. NO. 02-1792 CIVIL TERM RONALD A. SAYLOR AND CIVIL ACTION - LAW - MICHELLE K. SAYLOR IN MORTGAGE FORECLOSURE Defendants RETURN OF SERVICE I hereby certify that I have deposited in the U.S. Mails at Harrisburg, Pennsylvania on 9-t7_ /J? , a true and correct copy of the Notice of Sale of Real Estate pursuant to PA R.C.P. 3129.1 to the Defendants herein and all lienholders of record by regular first class mail (Certificate of Mailing form in compliance with U.S. Postal Form 3817 is attached hereto as evidence), and also to the Defendants by Certified Mail, which mailing receipts are attached. Service addresses are as follows: Ronald A. Saylor 4 Eagle Ledge Road Meredith, NH 03253 Michelle K. Saylor 4 Eagle Ledge Road Meredith, NH 03253 Cityscape Corp. 565 Taxter Road Elmsford, NY 10523 Tenant/Occupant 39 Broad Street Newville, PA 17241 DOMESTIC RELATIONS OFFICE 13 North Hanover Street Carlisle, PA 17013 f? By ruxcrn', -KRUG & HALLER A orneys for Plaintiff 1719 North Front Street Harrisburg, PA 17102 (717) 234-4178 LAW OFFICES JOHN W.PURCELL HOWARD B. KRUG LEON P. HALLER JOHN W.PURCELLJR. BRIAN J. TYLER JILL M. WINEKA NOTICE TO: Ronald A. Saylor 4 Eagle Ledge Road Meredith, NH 03253 Michelle K. Saylor 4 Eagle Ledge Road Meredith, NH 03253 Cityscape Corp. 565 Taxter Road Elmsford, NY 10523 Tenant/Occupant 39 Broad Street Newville, PA 17241 DOMESTIC RELATIONS OFFICE 13 North Hanover Street Carlisle, PA 17013 (717) 533,3836 JOSEPH NISSLEY(1910-1982) ANTHONY DiSANTO OF COUNSEL HERSHEY 1099 GOVERNOR ROAD NOTICE IS HEREBY GIVEN to the Defendants in the within action and those parties who hold one or more mortgages, judgments or tax liens against the real estate which is the subject of the Notice of Sale pursuant to Pennsylvania Rule of Civil Procedure 3129.1 attached hereto. YOU ARE HEREBY NOTIFIED that by virtue of a Writ of Execution issued out of the Court of Common Pleas of the within county on the judgment of the Plaintiff named herein the said real estate will be exposed to public sale as set forth on the attached Notice of Sale. YOU ARE FURTHER NOTIFIED that the lien you hold against the said real estate will be divested by the sale and that you have an opportunity to protect your interest, if a ng notified of said Sheriff's Sale. By: LL Haller PA I D.15700 PLO?CELL, "UGAAVJZ4LLER 1719 NORTH FRONT STREET HARRISBURG, PENNSYLVANIA 17102-2392 TELEPHONE (717) 234-4178 FORECLOSURE DEPT. FAX (717) 234-1206 Attorney for Plaintiff HOMESIDE LENDING, INC. Plaintiff VS. IN THE COURT OF COMMON PLEAS CUMBERLAND COUNTY, PENNSYLVANIA NO. 02-1792 CIVIL TERM RONALD A. SAYLOR AND CIVIL ACTION - LAW - MICHELLE K. SAYLOR IN MORTGAGE FORECLOSURE Defendants NOTICE OF SHERIFF'S SALE OF REAL ESTATE PURSUANT TO PENNSYLVANIA RULE OF CIVIL PROCEDURE 3129 TAKE NOTICE: held: That the Sheriff's Sale of Real Property (real estate) will be DATE:WEDNESDAY, DECEMBER 4, 2002 TIME:10:00 O'clock A.M. LOCATION: Commissioner's Hearing Room 2nd Floor Cumberland County Courthouse Carlisle, Pennsylvania 17013 THE PROPERTY TO BE SOLD is delineated in detail in a legal description mainly consisting of a statement of the measured boundaries of the property, together with a brief mention of the buildings and any other major improvements erected on the land. (SEE DESCRIPTION ATTACHED) THE LOCATION of your property to be sold is: 39 BROAD STREET, NENVILLE, PA 17241 THE JUDGMENT under or pursuant to which your property is being sold is docketed in the within Commonwealth and County to: 2002-1792-CIVIL THE NAME(S) OF THE OWNER(S) OR REPUTED OWNERS of this property is: RONALD A. SAYLOR AND MICHELLE K. SAYLOR A SCHEDULE OF DISTRIBUTION, being a list of the persons and/or governmental or corporate entities or agencies being entitled to receive part of the proceeds of the sale received and to be disbursed by the Sheriff (for example, to banks that hold mortgages and municipalities that are owed taxes) will be filed by the Sheriff of this County thirty (30) days after the sale and distribution of the proceeds of sale in accordance with this schedule will, in fact, be made unless someone objects by filing exceptions to it within ten (10) days of the date it is filed. Information about the Schedule of Distribution may be obtained from the Sheriff of the Court of Common Pleas of the within County at the Courthouse address specified herein. THIS PAPER IS A NOTICE OF THE TIME AND PLACE OF THE SALE OF YOUR PROPERTY. IT HAS BEEN ISSUED BECAUSE THERE IS A JUDGMENT AGAINST YOU. IT MAY CAIISE YOUR PROPERTY TO BE HELD TO BE SOLD OR TAKEN TO PAY THE JUDGMENT. You may have legal rights to prevent your property from being taken away. A lawyer can advise you more specifically of these rights. If you wish to exercise your rights, YOU MUST ACT PROMPTLY. YOU SHOULD TAKE THIS PAPER TO YOUR LAWYER AT ONCE. GO TO OR TELEPHONE THE OFFICE SET FORTH BELOW TO FIND OUT WHERE YOU CAN GET FREE LEGAL ADVICE: Cumberland County Bar Association 2 Liberty Avenue Carlisle, Pennsylvania 17013 Phone (717) 249-3166 800-990-9108 THE LEGAL RIGHTS YOU MAY HAVE ARE; 1. You may file a petition with the Court of Common Pleas of the within county to open the judgment if you have a meritorious defense against the person or company that has entered judgment against you. You may also file an petition with the same Court if you are aware of a legal defect in the obligation or the procedure used against you. 2. After the Sheriffs Sale you may file a petition with the Court of Common Pleas of the within County to set aside the sale for a grossly inadequate price or for other proper cause. This petition MUST BE FILED BEFORE THE SHERIFF'S DEED IS DELIVERED. 3. A petition or petitions raising the legal issues or rights mentioned in the preceding paragraphs must be presented to the Court of Common Pleas of the within County. The petition must be served on the attorney for the creditor or on the creditor before presentation to the court and a proposed order or rule must be attached to the petition. If a specific return date is desired, such date must be obtained from the Court Administrator's Office - Civil Division, of the within County Courthouse, before a presentation of the petition to the Court. , A copy of the Writ of Execution is attached hereto. PURCELL, KRUG & HALLER Attorneys for Plaintiff 1719 North Front Street Harrisburg, PA 17102 (717) 234-4178 LEGAL DESCRIPTION ALL that certain tract or parcel of land and premises, situate, lying and being in the Borough of Newville in the County of Cumberland and Commonwealth of Pennsylvania, more particularly bounded and described as follows: BEGINNING at a point in the Southern side of Broad Street, which point is a corner of lot now or - formerly of Gerald Reid; thence in a southwardly direction along lot now or formerly of Gerald Read, a distance of one hundred eighty (180) feet to a point in the Northern side of an, alley thirty (30) feet in width; thence along the Northern side of said alley in a Westwardly direction a distance of thirty-three (33) feet, nine (9) inches to a point in line of lot now or formerly of Jeffrey Shearer; thence in a Northwardiy direction along lot now or formerly of Jeffrey Shearer, a distance of one hundred eighty (180) feet to a point in the Southern side of said Broad Street; thence in an Eastwardly direction along the Southern side of said Broad Street, a distance of thirty-three (33) feet, nine (9) inches to a point, the place of BEGINNING. h HAVING THEREON ERECTED A DWELLING KNOWN AS 39 Broad Street, Newville, Pennsylvania BEING THE SAME PREMISES which Joseph J. Butchko and Ann K. Butchko, by Deed dated August 5, 1996 and recorded August 5, 1995 in Deed Book 143, Page 920, granted and conveyed unto Ronald A. Saylor and Michelle K. Saylor. TO BE SOLD AS THE PROPERTY OF RONALD A. SAYLOR AND MICHELLE K. SAYLOR UNDER JUDGMENT NO. 2002-1792 CIVIL TERM PARCEL NO. 28-21-0361-067 COURT OF COMMON•PLEAS OF CUMBERLAND COUNTY 9T" JUDICIAL DISTRICT COMMONWEALTH OF PENNSYLVANIA AFFIDAVIT OF SERVICE OF PROCESS HOMESIDE LENDING, INC. NO. 02-1792 Plaintiff CIVIL ACTION - LAW versus IN MORTGAGE FORECLOSURE RONALD A. SAYLOR AND MICHELLE K. SAYLOR Defendant Know all persons by these presents that I, Thomas C. Alden , was assigned to duly execute this service upon the following defendant: MICHELLE K. SAYLOR at 4 EAGLE LEDGE ROAD, MEREDITH, NH 03253 1 hereby depose and say: 1) That I am of the necessary age and sound mind to execute said service. 2) That I am not a party to the action or have any interest in it. 3) That I am an ale#.IasgAd?ar®trpl?e??rte ew mpsh,Deputy Sheriff in and for the County of Belknap in the State of I hereby certify that on 10/3/2002 at approximately 1:05 ? Km. ®p.m. a true and correct copy of the NOTICE OF SHERIFF'S SALE were served on the above-named party or witness in the following manner: X8 I personally delivered them into the hands of the person to be served. ? By leaving a copy at his/her usual place of abode with whose relationship to the defendant is and who is of suitable age and discretion and also residing therein. ? By leaving a copy with the manager/clerk of place of lodging in which defendant resides. ? By leaving a copy with the agent in charge of defendant's office or usual place of business. Job title or position of agent is ? After due and diligent efforts, described below, I was unable to serve the process Description of Recipient: Sex: F Race: W Approximate Heights' A Approximate Weight: 130 Approximate Age: 28 FURTHER AFFIDAVIT SAYTH NOT. Signature of Process Server Thomas C. Alden, Deputy Sheriff Belknap County Sheriff's Department Subscribed and sworn to before me this 7 of day of October 2002. aA, c?g Notary P lic oFFCIAL SEAL [&:ECVE LYN B. SANVILLE NOTARY PUBLIC NEW HAMPSHIRE M. ftpires Nov. 7, 2006 COURT OF COMMON PLEAS OF CUMBERLAND COUNTY 9TH JUDICIAL DISTRICT COMMONWEALTH OF PENNSYLVANIA AFFIDAVIT OF SERVICE OF PROCESS HOMESIDE LENDING, INC. NO. 02-1792 Plaintiff versus CIVIL ACTION - LAW IN MORTGAGE FORECLOSURE RONALD A. SAYLOR AND MICHELLE K. SAYLOR Defendant Know all persons by these presents that I, Thomas C. Alden was assigned to duly execute this service upon the following defendant: RONALD A. SAYLOR at 4 EAGLE LEDGE ROAD, MEREDITH, NH 03253 1 hereby depose and say: 1) That I am of the necessary age and sound mind to execute said service. 2) That I am not a party to the action or have any interest in it. 3) That I am an 2rt?e+?E,#€is?k#F=a®??lyea?a? #IRa".= Deputy Sheriff in and for the County of Belknap in the State of New Hampshire I hereby certify that on 10/3/02 at approximately 1: Q5 Elmm. Xrp.m. a true and correct copy of the NOTICE OF SHERIFF'S SALE were served on the above-named party or witness in the following manner: ? I personally delivered them into the hands of the person to be served. M By leaving a copy at his/her usual place of abode with _ Mi che7 le x SaylMose relationship to the defendant is spouse and who is of suitable age and discretion and also residing therein. ? By leaving a copy with the manager/clerk of place of lodging in which defendant resides. ? By leaving a copy with the agent in charge of defendant's office or usual place of business. Job title or position of agent is ? After due and diligent efforts, described below, I was unable to serve the process hard ica. Description of Recipient: Sex: F Race: W Approximate Height: 5 ' 4 "Approximate -' Weight: J-3-Q_ Approximate Age: 9,9_ FURTHER AFFIDAVIT SAYTH NOT. Signature of Process Server Thomas C. Alden, Deputy Sheriff Belknap County Sheriff's Department Subscribed and sworn to before me this 7 day of October , 2002. 110 0 Notary blic ff <' ' ` bENt. S EAL ..j EVELYN B. SANVINOTARY PUBLIC NEW HAMPSHIRE y Comm. Expires Nov. 7 Homeside v. Saylor Cumberland County sale 12/4/02 U. S. POSTAL SERVICE CERTIFICATE OF MAILING (In compliance with Postal Service Form 3877) Received from: Purcell, Krug & Haller Postage: 1719 North Front Street Harrisburg, PA 17102 One piece of ordinary mail addressed to: Postmark: Ronald A. Saylor 4 Eagle Ledge Road Meredith, NH 03253 U. S. POSTAL SERVICE CERTIFICATE OF MAILING an compliance with Postal Service Form 3877) Received from: Purcell, Krug & Haller Postage: 1719 North Front Street Harrisburg, PA 17102 One piece of ordinary mail addressed to: Postmark: Michelle K. Saylor 4 Eagle Ledge Road Meredith, NH 03253 U. S. POSTAL SERVICE CERTIFICATE OF MAILING f SaSFe? an compliance with Postal Service Form 3877) lQ tiQQti Received from: e. ??? 01 Purcell, Krug & Haller Postage: 17 .dgBSl?t 1719 North Front Street Harrisburg, PA 17102 One piece of ordinary mail addressed to: Cityscape Corp. 565 Taxter Road Elmsford, NY 10523 4 A? ' f ?. `•, is i? , i. : , . y __.__..?_ a - Homeside v. Saylor Cumberland County sale 12/4/02 U. S. POSTAL SERVICE CERTIFICATE OF MAILING Qn compliance with Postal Service Form 38771 Received from: Purcell, Krug & Haller Postage: 1719 North Front Street Harrisburg, PA 17102 One piece of ordinary mail addressed to: Postmark: Tenant/Occupant 39 Broad Street Newville, PA 17241 U. S. POSTAL SERVICE CERTIFICATE OF MAILING an compliance with Postal Service Form 38771 Received from: Purcell, Krug & Haller 1719 North Front Street Harrisburg, PA 17102 Postage: One piece of ordinary mail addressed to: DOMESTIC RELATIONS OFFICE 13 North Hanover Street Carlisle, PA 17013 Postmark: _ 5 < /6 t1 ( fta ?J1 ? a- Y E . a? ? Y I ? la ?sasn }} 4 L? P I 4 c ? 5 J? b°esiaad?i`. t- , ?, :Y. ?;,; :; ,L - ;; _, ,? .. ? ?:? , .,. _ COMMONWEALTH OF PENNSYLVANIA COUNTY OF CUMBERLAND } SS: I, Robert P. Ziegler, Recorder of Deeds in and for said County and State do hereby certify that the Sheriff's Deed in which Midfirst Bank is the grantee the same having been sold to said grantee on the 4th day of Dec A.D., 2002, under and by virtue of a writ Execution issued on the I Oth day of Sent. A.D., 2002, out of the Court of Common Pleas of said County as of Civil Term, 2002 Number 1792, at the suit of Homeside Lending Inc against Michelle K Saylor & Ronald A is duly recorded in Sheriff's Deed Book No. 255, Page 1261. IN TESTIMONY WHEREOF, I have hereunto set my hand and seal of said office this P day of A.D.2002 Recorder of Deeds RecoMar of Deeds, Cumberland Cwly, CaM, PA My Commission Expires the Fast Monday of Jan. 2006 Homeside Lending, Inc. In The Court of Common Pleas of VS Cumberland County, Pennsylvania Ronald A. Saylor and Michelle K. Saylor Writ No. 2002-1792 Civil Term Dawn Kell, Deputy Sheriff, who being duly sworn according to law, states that on October 3, 2002 at 9:25 o'clock A.M., she posted a true copy of the within Real Estate Writ, Notice, Poster and Description, in the above entitled action, upon the property of Ronald A. Saylor and Michelle K. Saylor located at 39 Broad Street, Newville, Pennsylvania, according to law. R. Thomas Kline, Sheriff, who being duly sworn according to law, states that after due and legal notice had been given according to law, exposed the within described premises at public venue or outcry at the Court House, Carlisle, Cumberland County, Pennsylvania, on December 4, 2002 at 10:00 o'clock A.M. He sold the same for the sum of $1.00 to Attorney Leon Haller for Midfirst Bank. It being the highest bid and best price received for the same, Midfirst Bank of 999 NW Grand Boulevard, Suite 110, Oklahoma City, OK 73118, being the buyer in this execution paid Sheriff R. Thomas Kline the sum of $857.61, it being costs. Sheriffs Costs Docketing 30.00 Poundage 16.82 Posting Bills 15.00 Advertising 15.00 Acknowledging Deed 30.00 Auctioneer 10.00 Law Library .50 Prothonotary 1.00 Mileage 8.28 Certified Mail 18.51 Levy 15.00 Surcharge 30.00 Law Journal 307.25 Patriot News 270.55 Share of Bills 25.20 Distribution of Proceeds 25.00 Sheriffs Deed 39.50 $857.61 Sworn and Subscribed to Before Me So we This iD 6? Day of ?-?-? R. Thomas Kline, Sheriff 2002, A.D. zl?- -L? Prothonotary BY11J - VjLt? Real Estate Deputy 3p ti? I? 39J3y l-33?Is? Real Estate Sale # 42 On September 16, 2002 the sheriff levied upon the defendant's interest in the real property situated in Newville Borough, Cumberland County, PA known and numbered as 39 Broad St., Newville, more fully described on Exhibit "A" filed with this writ and by this reference incorporated herein. Date: September 16, 2002 By." -)(, j t, Real Estatef)eputy THE PATRIOT NEWS THE SUNDAY PATRIOT NEWS Proof of Publication Under Act No. 587, Approved May 16, 1929 Commonwealth of Pennsylvania, County of Dauphin) ss Frank J. Epler being duly sworn according to law, deposes and says: That he is the Controller of The Patriot News Co., a corporation organized and existing under the laws of the Commonwealth of Pennsylvania, with its principal office and place of business at 812 to 818 Market Street, in the City of Harrisburg, County of Dauphin, State of Pennsylvania, owner and publisher of The Patriot-News and The Sunday Patriot-News newspapers of general circulation, printed and published at 812 to 818 Market Street, in the City, County and State aforesaid; that The Patriot-News and The Sunday Patriot-News were established March 4th, 1854, and September 18th, 1949, respectively, and all have been continuously published ever since; That the printed notice or publication which is securely attached hereto is exactly as printed and published in their regular daily and/or Sunday/ Metro editions which appeared on the 22nd and 29th day(s) of October and the 5th day(s) of November 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 Sworn to and subscribed before 14th day of ve 2002 A.D. S A L E #42 Notarial Seal 7 Terry L. Russell, Notary Public REAL ESTATE SALE No. 42 Writ No. 2002-1792 City Of Harrisburg, Dauphin County My Commission Expires June 6, 2006 NOT AY PUBLIC Civil Term Homeside Lending, Inc. Member, Pennsylvania Association of Notaries My commission expires June 6, 2006 vs Ronald A. K. Saylor Saylor and Michelle CUMBERLAND COUNTY SHERIFFS OFFICE Atty: Leon P. Haller CUMBERLAND COUNTY COURTHOUSE LEGAL DESCRIPTION ALL that certain tract or parcel of land and CARLISLE, PA. 17013 premises, situate, lying and being in the Borough of Newville in the County of Cumberland and Commonwealth of Pennsylvania more Statement of Advertising Costs , particularly bounded and described as follows: BEGINNING at a point in the Southern side of To THE PATRIOT-NEWS CO., Dr. Broad Street, which point is a comer of lot now For publishing the notice or publication attached or formerly of Gerald Reid; thence in a southwardly direction along lot now or formerly hereto on the above stated dates $ 268.80 of Gerald Read, a distance of one hundred eighty Probating same Notary Fee(s) $ 1.75 (180) feet to a point in the Northern side of an Total $ 270.55 alley thirty (30) feet in width; thence along the Northern side of said alley in a Westwardly direction a distance of thirty-three (33) feet, nine (9) inches to a point in line of lot now or formerly Publisher's Receipt for Advertising Cost The Patriot News Co., publisher of The Patriot-News and The Sunday Patriot-News, newspapers of general circulation, hereby acknowledge receipt of the aforesaid notice and publication costs and certifies that the same have been duly paid. of Jeffrey Shearer; thence in a Northwardly direction along lot now or formerly of Jeffrey Shearer, a distance of one hundred eighty (180) feet to a point in the Southern side of said Broad Street; thence in an Eastwardly direction along the Southern side of said Broad Street, a distance of thirty-three (33) feet, nine (9) inches to a Deed Book 143, Page 920, granted and conveyed point, the place of BEGINNING. unto Ronald A. Saylor and Michelle K. Saylor. HAVING THEREON ERECTED A DWELLING TO BE SOLD AS THE PROPERTY OF Ronald KNOWN AS 39 Broad Street, Newville, A. Saylor and Michelle K. Saylor under Pennsylvania. Judgment No. 2002-1792 Civil Term. BEING THE SAME PREMISES which Joseph J. PARCEL NO. 28-21-0361-067. Butchko and Ann K. Butchko, by Deed dated August 5, 1996 and recorded August 5, 1995 in 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.fournal, 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: OCTOBER 25, NOVEMBER 1, 8, 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. 42 Writ No. 2002-1792 Civil Homeside Lending, Inc. vs. Ronald A. Saylor and Ro r M. Morgenthal, Editor Michelle K. Saylor Atty.: Leon P. Haller SWORN TO AND SUBSCRIBED before me this LEGAL DESCRIPTION ALL that certain tract or parcel 8 day of NOVEMBER, 2002 of land and premises, situate, lying and being in the Borough of Newville in the County of Cumberland and Commonwealth of Pennsylvania, a / more particularly bounded and de- r scribed as follows: N&AMks BEGINNING at a point in the lOM E. 8; aI TSI, N?, t :? rpuWk Southern side of Broad Street, which point is a corner of lot now or for- C.S? .,o ?fl9"?, ;gls ?l cmn Y C+OSI"ZlkW106 rW 15 merly of Gerald Reid; thence in a , - southwardly direction along lot now or formerly of Gerald Read, a dis- tance of one hundred eighty (180) feet to a point in the Northern side of an alley thirty (30) feet in width; thence along the Northern side of said alley in a Westwardly direction a distance of thirty-three (33) feet, nine (9) inches to a point in line of lot now or formerly of Jeffrey Shear- er: thence in a Northwardly direc- tion along lot now or formerly of Jeffrey Shearer, a distance of one hundred eighty (180) feet to a point in the Southern side of said Broad Street: thence in an Eastwardly di- rection along the Southern side of said Broad Street, a distance of thirty-three (33) feet, nine (9) inches to a point, the place of BEGINNING. HAVING THEREON ERECTED A DWELLING KNOWN AS 39 Broad Street, Newville, Pennsylvania. BEING THE SAME PREMISES which Joseph J. Butchko and Ann K. Butchko, by Deed dated August 5, 1996 and recorded August 5, 1995 in Deed Book 143, page 920, granted and conveyed unto Ronald A. Saylor and Michelle K. Saylor. TO BE SOLD AS THE PROPER- TY OF RONALD A. SAYLOR AND MICHELLE K. SAYLOR UNDER JUDGMENT NO. 2002-1792 CIVIL TERM. PARCEL NO. 28-21-0361-067. rC?