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HomeMy WebLinkAbout02-2082FEDERMAN 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) 563-7000 WELLS FARGO HOME MORTGAGE, INC. F/K/A NORWEST MORTGAGE, INC. 5024 PARKWAY PLAZA BOULEVARD CHARLOTTE, NC 28217 Plaintiff V. TIMOTHY M. NORRIS PAULA M. NORRIS 201 EAST ORANGE STREET SHIPPENSBURG, PA 17257 Defendant(s) ATTORNEY FOR PLAINTIFF COURT OF COMMON PLEAS CIVIL DIVISION TERM NO. CUMBERLAND COUNTY CIVIL ACTION - LAW COMPLAINT IN MORTGAGE FORECLOSURE NOTICE "THIS FIRM IS A DEBT COLLECTOR ATTEMPTING TO COLLECT A DEBT AND ANY INFORMATION OBTAINED WILL BE USED FOR THAT PURPOSE. IF YOU HAVE PREVIOUSLY RECEIVED A DISCHARGE IN BANKRUPTCY AND THIS DEBT WAS NOT REAFFIRMED, THIS CORRESPONDENCE IS NOT AND SHOULD NOT BE CONSTRUED TO BE AN ATTEMPT TO COLLECT A DEBT, BUT ONLY ENFORCEMENT OF A LIEN AGAINST PROPERTY. •` You have been sued in Court. If you wish to defend against the claims set forth in the following pages, you must take action within twenty (20) days after this Complaint and Notice are served, by entering a written appearance personally or by attorney and filing in writing with the court your defenses or objections to the claims set forth against you. You are warned that if you fail to do so the case may proceed without you and a judgment may be entered against you by the court without further notice for any money claimed in the Complaint or for any other claim or relief requested by the Plaintiff. You may lose money or property or other rights important to you. YOU SHOULD TAKE THIS PAPER TO YOUR LAWYER AT ONCE. IF YOU DO NOT HAVE A LAWYER OR CANNOT AFFORD ONE, GO TO OR TELEPHONE THE OFFICE SET FORTH BELOW TO FIND OUT WHERE YOU CAN GET LEGAL HELP. CUMBERLAND COUNTY CUMBERLAND COUNTY BAR ASSOCIATION 2 LIBERTY AVENUE CARLISLE, PA 17013 (717) 249-3166 Loan #: 7522967 RMS 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 WELLS FARGO HOME MORTGAGE, INC. F/K/A NORWEST MORTGAGE, INC. 5024 PARKWAY PLAZA BOULEVARD CHARLOTTE, NC 28217 2. The name(s) and last known address(es) of the Defendant(s) are: TIMOTHY M. NORRIS PAULA M. NORRIS 201 EAST ORANGE STREET SHIPPENSBURG, PA 17257 who is/are the mortgagor(s) and real owner(s) of the property hereinafter described. 3. On 12/10/98 mortgagor(s) made, executed and delivered a mortgage upon the premises hereinafter described to FOUNDERS MORTGAGE COMPANY, INC. which mortgage is recorded in the Office of the Recorder of CUMBERLAND County, in Mortgage Book No. 1506, Page 8. By Assignment of Mortgage recorded 12/15/98 the mortgage was assigned to PLAINTIFF which Assignment is recorded in Assignment of Mortgage Book No. 597, Page 868. 4. 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 10/1/01 and each month thereafter are due and unpaid, and by the terms of said mortgage, upon failure of mortgagor to make such payments after a date specified by written notice sent to Mortgagor, the entire principal balance and all interest due thereon are collectible forthwith. 6. The following amounts are due on the mortgage: Principal Balance $107,530.41 Interest 4,294.08 9/1/01 through 4/1/02 (Per Diem $20.16) Attorney's Fees 1,000.00 Cumulative Late Charges 216.00 12/10/98 to 4/1/02 Cost of Suit and Title Search 550.00 Subtotal $113,590.49 Escrow Credit 0.00 Deficit 903.52 Subtotal 903.52 TOTAL $114,494.01 7. The attorney's fees set forth above are in conformity with the Mortgage documents and Pennsylvania Law, and will be collected in the event of a third party purchaser at Sheriffs Sale. If the Mortgage is reinstated prior to the Sale, reasonable attorney's fees will be charged. 8. This action does not come under Act 6 of 1974 because the original mortgage amount exceeds $50,000.00. 9. The Combined Notice has been sent to the Defendant(s) by regular and certified mail as required by 35 P.S. § 1680.403c. 10. The Temporary Stay as provided by the Homeowner's Emergency Mortgage Assistance Program, Act 91 of 1983, has terminated because either: (i) Defendant(s) have failed to meet with the Plaintiff or an authorized Credit Counseling Agency in accordance with Plaintiff s written Notice to Defendants; or (ii.) Defendant(s) application for assistance has been rejected by the Pennsylvania Housing Finance Agency. WHEREFORE, PLAINTIFF demands an in rem Judgment against the Defendant(s) in the sum of $114,494.01, together with interest from 4/1/02 at the rate of $20.16 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. FE ERMAN AND 7N.E1/AN, LLP By: T ?t ?- FRANK FEDERMAN, ESQUIRE LAWRENCE T. PHELAN, ESQUIRE FRANCIS S. HALLINAN, ESQUIRE Attorneys for Plaintiff ALL that certain lot or piece of ground, improved with a dwelling housy, situate at the comer of Prince and Orange Streets, in the Borough of Shippensburb, Cumberland County, Pennsylvania, boundbd and described as follows; ON the South by Orange Street; on the West by Prince Street; on the North by land now or formerly of Deck; on the East by land now or formerly of Hershey. Said lot having frontage on Orange Street of thirty-three (33) feet, more or less, and an even width, a depth from Orange Street of ninety (90) feet to land now or fonnerly of Deck, and further having thereon a frame dwelling house and garage, and being known and numbered as 201 East Orange Street, Shippensburg,Pennsylvania. BEING the same premises which Paul E. Leitne: and Gretchen DeSmidt, now known as Gretchen D. L.eitner, husband and wife, by deed recorded in Cumberland County Deed Book 106, Page 1158 granted and conveyed unto Paul E. Leitner and Gretchen D. Lcitner, husband and wife. PREMISES BEING: 201 EAST ORANGE STREET VERIFICATION TAMMY JOHNSON hereby states that she is ASSISTANT VICE PRESIDENT of WELLS FARGO HOME MORTGAGE, INC. mortgage servicing agent for Plaintiff in this matter, that she 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 her knowledge, information and belief. The undersigned understands that this statement is made subject to the penalties of 18 Pa. C.S. Sec. 4904 relating to unworn falsification to authorities. DATE: L- O t _ Lt- J :U J 7 U Pi SHERIFF'S RETURN - REGULAR -CASE-NO: 2002-02082 P COMMONWEALTH OF PENNSYLVANIA: COUNTY OF CUMBERLAND WELLS FARGO HOME MORTGAGE INC VS NORRIS TIMOTHY M ET AL KENNETH GOSSERT , Sheriff or Deputy Sheriff of Cumberland County,Pennsylvania, who being duly sworn according to law, says, the within COMPLAINT - MORT FORE was served upon S TIMOTHY M the DEFENDANT , at 1235:00 HOURS, on the 1st day of May 2002 at 201 EAST ORANGE STREET SHIPPENSBURG, PA 17257 by handing to TIMOTHY NORRIS a true and attested copy of COMPLAINT - MORT FORE together with and at the same time directing His attention to the contents thereof. Sheriff's Costs: Docketing Service Affidavit Surcharge So Answers: 18.00 14.49 .00 10.00 R. Thomas Kline' .00 42.49 05/02/2002 FEDERMAN & PHELAN Sworn and Subscribed to before By: me this 17 e-- day of '200z A.D. kuL? Q AOg4. othonotary SHERIFF'S RETURN - REGULAR -CASE-NO: 2002-02082 P COMMONWEALTH OF PENNSYLVANIA: COUNTY OF CUMBERLAND WELLS FARGO HOME MORTGAGE INC VS NORRIS TIMOTHY M ET AL KENNETH GOSSERT , Sheriff or Deputy Sheriff of Cumberland County,Pennsylvania, who being duly sworn according to law, says, the within COMPLAINT - MORT FORE was served upon NORRIS PAULA M the DEFENDANT , at 1235:00 HOURS, on the 1st day of May 2002 at 201 EAST ORANGE STREET SHIPPENSBURG, PA 17257 by handing to TIMOTHY NORRIS, HUSBAND a true and attested copy of COMPLAINT - MORT FORE together with and at the same time directing His attention to the contents thereof. Sheriff's Costs: Docketing Service Affidavit Surcharge So Answers: 6.00 .00 .00 ?? ?!?-????-? 10.00 R. Thomas Kline .00 16.00 05/02/2002 FEDERMAN & PHELAN Sworn and Subscribed to before By: me this day of o1ltpL A.D. ?1.? Q ar??. ,?• r thonotary ,,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 WELLS FARGO HOME MORTGAGE, INC., F/K/A NORWEST MORTGAGE, INC. 5024 PARKWAY PLAZA BOULEVARD CHARLOTTE, NC 28217 CUMBERLAND COUNTY COURT OF COMMON PLEAS CIVIL DIVISION V. Plaintiff, NO. 02-2082 CIVIL TIMOTHY M. NORRIS PAULA M. NORRIS Defendant(s). PRAECIPE FOR JUDGMENT FOR FAILURE TO ANSWER AND ASSESSMENT OF DAMAGES TO THE PROTHONOTARY: Kindly enter judgment in favor of the Plaintiff and against TIMOTHY M. NORRIS and PAULA M. NORRIS, 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 4/2/02 to 6/4/02 TOTAL $114,494.01 $1,290.24 $115,784.25 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 F DERMAN, ESQUIRE Attorney fo Plaintiff DAMAGES ARE HEREBY ASSESSED AS INDICATE DATE: PRO PROTHY FEDERMAN AND PHELAN BY: FRANK FEDERMAN, ESQUIRE Identification No. 12248 1617 John F. Kennedy Boulevard Suite 1400 Philadelphia, PA 19103-1814 Q15) 563-7000 WELLS FARGO HOME MORTGAGE, INC. F/K/A NORWEST MORTGAGE INC. Plaintiff VS. TIMOTHY M. NORRIS PAULA M. NORRIS Defendant(s) TO: TIMOTHY M. NORRIS 201 EAST ORANGE STREET C/? SHIPPENSBURG PA 17257 ,J e DATE OF NOTICE: MAY 22, 2002 Attorney for Plaintiff COURT OF COMMON PLEAS : CIVIL DIVISION CUMBERLAND COUNTY NO. 02-2082 CIVIL CO, 4? 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 F ank Federman, Esquire-- Attorney for Plaintiff _ FEDERMAN AND PBELAN BY: FRANK FEDERMAN, ESQUIRE Identification No. 12248 1617 John F. Kennedy Boulevard Suite 1400 Philadelphia, PA 19103-1814 Q15) 561-7000 WELLS FARGO HOME MORTGAGE, INC. F/K/A NORWEST MORTGAGE INC. Plaintiff Vs. TIMOTHY M. NORRIS PAULA M. NORRIS Attorney for Plaintiff : COURT OF COMMON PLEAS CIVIL DIVISION : CUMBERLAND COUNTY : NO. 02-2082 CIVIL Defendant TO: PAULA M. NORRIS 201 EAST ORANGE STREET SHIPPENSBURG PA 17257 DATE OF NOTICE: MAY 22, 2002 ltF 110A THIS FIRM IS A DEBT COLLECTOR ATTEMPTING TO COLLECT A DEBT. THIS NOTICE IS SENT TO YOU IN AN ATTEMPT TO COLLECT THE INDEBTEDNESS REFERRED TO HEREIN, AND ANY INFORMATION OBTAINED FROM YOU WILL BE USED FOR THAT PURPOSE.IF YOU HAVE PREVIOUSLY RECEIVED A DISCHARGE IN BANKRUPTCY, THIS CORRESPONDENCE IS NOT AND SHOULD NOT BE CONSTRUED TO BE AN ATTEMPT TO COLLECT A DEBT, BUT ONLY AS ENFORCEMENT OF LIEN AGAINST PROPERTY. IMPORTANT NOTICE You are in default because you have failed enter a written appearance personally or by attorney and file in writing with the court your defenses or objections to the claims set forth against you. Unless you act within ten (10) days from the date of this notice, a Judgment may be entered against you without a hearing and you may lose your property or other important rights. You should take this notice to a lawyer at once. If you do not have a lawyer or cannot afford one, go to or telephone the following office to find out where you can get legal help: CUMBERLAND COUNTY CUMBERLAND COUNTY BAR ASSOCIATION 2 LIBERTY AVENUE CARLISLE, PA 17013 (717) 249-3166 Frank Federman, Esquire Attorney for Plaintiff FEDERMAN and PHELAN, LLP By: FRANK FEDERMAN Identification No. 12248 ATTORNEY FOR PLAINTIFF ONE PENN CENTER AT SUBURBAN STATION 1617 JOHN F. KENNEDY BLVD., SUITE 1400 PHILADELPHIA, PA 19103-1814 (215) 563-7000 WELLS FARGO HOME MORTGAGE, INC., F/K/A NORWEST MORTGAGE, INC. 5024 PARKWAY PLAZA BOULEVARD CUMBERLAND COUNTY COURT OF COMMON PLEAS Plaintiff, V. TIMOTHY M. NORRIS PAULA M. NORRIS Defendant(s). CIVIL DIVISION NO. 02-2082 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 TIMOTHY M. NORRIS is over 18 years of age and resides at, 201 EAST ORANGE STREET, SHIPPINSBURG, PA 17257. (c) that defendant PAULA M. NORRIS is over 18 years of age, and resides at, 201 EAST ORANGE STREET, SHIPPINSBURG, PA 17257. This statement is made subject to the penalties of 18 Pa. C.S. Section 4904 relating to unworn falsification to authorities. ILFRANK F DERMAN, ESQUIRE Attorney for Plaintiff I ,r _v ? V 1 e CIT Q l CJ S ?V TJ [A?' Ill(1' LIZ P r; b Y? PRAECIPE FOR WRIT OF EXECUTION - (MORTGAGE FORECLOSURE) P.R.C.P. 3180-3183 WELLS FARGO HOME MORTGAGE, INC., F/K/A NORWEST MORTGAGE, INC. Plaintiff, V. No. 02-2082 CIVIL TIMOTHY M. NORRIS PAULA M. NORRIS Defendant(s). TO THE DIRECTOR OF THE OFFICE OF THE PROTHONOTARY: Issue writ of execution in the above matter: Amount Due $115,784.25 Interest from 6/5/02 to 9/4/02 $1,750.76 and Costs (per diem -$19.03) TOTAL $117,535.01 AA N, RANK FEI?V ERMAN, 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. b C fA a k4 W H O W W H 0-1 0-3 H V-3 rA w E= bb rob 22 V) M as bb N N VI V1 J J Oil O H 47 O N C A A yby l? y O z z y w H1 hi rJ C O A . y Mi A?? C 9 y ALL THAT CERTAIN lot or piece of ground, improved with a dwelling house, situate at the corner of Prince and Orange Streets, in the Borough of Shippensburg, Cumberland County, Pennsylvania, bounded and described as follows: ON the South by Orange Street; on the West by Prince Street; on the North by land now or formerly of Deck; on the East by land now or formerly of Hershey. Said lot having a frontage on Orange Street of thirty-three (33) feet, more or less and an even width, a depth from Orange Street of ninety (90) feet to land now or formerly of Deck and further having thereon a frame dwelling house and garage and being known and numbered as 201. East Orange Street, Shippensburg, Pennsylvania. Tax Parcel #34-2415-197 PREMISES BE-KG Kff3k N AS 201 EAST ORANGE STREET, SBIPPINSBURG, PA 17257 TITLE TO SAID PREMISES IS VESTED IN Timothy M. Norris and Paula M. Norris, his wife by Deed from Paul E. Leitner and Gretchen D. Leimer, his wife dated 12/10/98 and recorded 12/15/98, in Record Book 191, Page 1. 7. y c its `'? ? ? C 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 WELLS FARGO HOME MORTGAGE, INC., F/K/A NORWEST MORTGAGE, INC. V. Plaintiff, TIMOTHY M. NORRIS PAULA M. NORRIS Defendant(s). ATTORNEY FOR PLAINTIFF CUMBERLAND COUNTY COURT OF COMMON PLEAS CIVIL DIVISION NO. 02-2082 CIVIL FRANK FEDERMAN, ESQUIRE, hereby verifies that he is attorney for the Plaintiff in the above-captioned matter, and that the premises are not subject to the provisions of Act 91 because it is: Q an FHA MORTGAGE ( ) non-owner occupied ( ) vacant (X) 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. -I A O\A/ RANK FE ERMAN, ESQUIRE Attorney for Plaintiff C) ? T`J T ` vc` ` t. I II CTi • I C- i f'r r rQ -? WELLS FARGO HOME MORTGAGE, INC., F/K/A NORWEST MORTGAGE, INC. Plaintiff, V. TIMOTHY M. NORRIS PAULA M. NORRIS Defendant(s). CUMBERLAND COUNTY COURT OF COMMON PLEAS CIVIL DIVISION NO. 02-2082 CIVIL AFFIDAVIT PURSUANT TO RULE 3129 (Affidavit No. 1) WELLS FARGO HOME MORTGAGE, INC., F/K/A NORWEST MORTGAGE, 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,201 EAST ORANGE STREET, SHIPPENSBURG, PA 17257. 1. Name and address of Owner(s) or reputed Owner(s): Name TIMOTHY M. NORRIS PAULA M. NORRIS Last Known Address (if address cannot be reasonably ascertained, please indicate) 201 EAST ORANGE STREET SHIPPINSBURG, PA 17257 201 EAST ORANGE STREET SHIPPINSBURG, PA 17257 2. Name and address of Defendant(s) in the judgment: Same as above 3. Name and last known address of every judgment creditor whose judgment is a record lien on the real property to be sold: Name Last Known Address (if address cannot be reasonably ascertained, please indicate) None 4. Name and address of last recorded holder of every MORTGAGE of record: Name Last Known Address (if address cannot be reasonably ascertained, please indicate) 4455 ARROWWEST DRIVE NORWEST BANK, N.A. P.O. BOX 49069 COLORADO SPRINGS, CO 80949 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 Domestic Relations of Cumberland County Commonwealth of Pennsylvania Department of Welfare 201 EAST ORANGE STREET SHIPPENSBURG, PA 17257 13 North Hanover Street Carlisle, PA 17013 PO Box 2675 Harrisburg, PA 17105 I verify that the statements made in this affidavit are true and correct to the best of my personal knowledge or information and belief. I understand that false statements herein are made subject to the penalties of 18 Pa. C.S. Sec. 4904 relating to unsworn falsification to authorities. May 30.2002 DATE FED RMAN, ESQUIRE for Plaintiff 7k -' rv WELLS FARGO HOME MORTGAGE, INC., F/K/A NORWEST MORTGAGE, INC. Plaintiff, V. TIMOTHY M. NORRIS PAULA M. NORRIS Defendant(s). CUMBERLAND COUNTY No. 02-2082 CIVIL May 30, 2002 TO: TIMOTHY M. NORRIS 201 EAST ORANGE STREET SHIPPINSBURG, PA 17257 PAULA M. NORRIS 201 EAST ORANGE STREET SHIPPINSBURG, PA 17257 *'THIS FIRM IS A DEBT COLLECTOR ATTEMPTING TO COLLECT A DEBT AND ANYINFORMATION OBTAINED WILL BE USED FOR THAT PURPOSE. IF YOU HAVE PREVIOUSLY RECEIVED A DISCHARGE IN BANKRUPTCYAND THIS DEBT WAS NOT REAFFIRMED, THIS IS NOT AND SHOULD NOT BE CONSTRUED TO BE AN ATTEMPT TO COLLECT A DEBT, BUT ONLY ENFORCEMENT OFA LIEN AGAINST PROPERTY. * * Your house (real estate) at, 201 EAST ORANGE STREET, SHIPPENSBURG, PA 17257, 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 $115,784.25 obtained by WELLS FARGO HOME MORTGAGE, INC., VIVA NORWEST MORTGAGE, INC. (the MORTGAGEe) against you. In the event the sale is continued, an announcement will be made at said sale in compliance with Pa.R.C.P., Rule 3129.3. NOTICE OF OWNER'S RIGHTS YOU MAY BE ABLE TO PREVENT THIS SHERIFF'S SALE To prevent this Sheriffs Sale, you must take immediate action: 1. The sale will be cancelled if you pay to the MORTGAGEe the back payments, late charges, costs and reasonable attorney's fees due. To find out how much you must pay, you may call: (215) 563-7000. 2. You may be able to stop the sale by filing a petition asking the Court to strike or open the judgment, if the judgment was improperly entered. You may also ask the Court to postpone the sale for good cause. 3. You may also be able to stop the sale through other legal proceedings. You may need an attorney to assert your rights. The sooner you contact one, the more chance you will have of stopping the sale. (See notice on page two on how to obtain an attorney.) YOU MAY STILL BE ABLE TO SAVE YOUR PROPERTY AND YOU HAVE OTHER RIGHTS EVEN IF THE SHERIFF'S SALE DOES TAKE PLACE. 1. If the Sheriffs Sale is not stopped, your property will be sold to the highest bidder. You may find out the price bid by calling (215) 563-7000. 2. You may be able to petition the Court to set aside the sale if the bid price was grossly inadequate compared to the value of your property. 3. The sale will go through only if the buyer pays the Sheriff the full amount due in the sale. To find out if this has happened, you may call (717) 240-6390. 4. If the amount due from the Buyer is not paid to the Sheriff, you will remain the owner of the property as if the sale never happened. 5. You have the right to remain in the property until the full amount due is paid to the Sheriff and the Sheriff gives a deed to the buyer. At that time, the buyer may bring legal proceedings to evict you. 6. You may be entitled to a share of the money which was paid for your house. A schedule of distribution of the money bid for your house will be filed by the Sheriff within 30 days of the sale. This schedule will state who will be receiving that money. The money will be paid out in accordance with this schedule unless exceptions (reasons why the proposed distribution is wrong) are filed with the Sheriff within ten (10) days after the distribution is filed. 7. You may also have other rights and defenses, or ways of getting your home back, if you act immediately after the sale. YOU SHOULD TAKE THIS PAPER TO YOUR LAWYER AT ONCE. IF YOU DO NOT HAVE A LAWYER OR CANNOT AFFORD ONE, GO TO OR TELEPHONE THE OFFICE LISTED BELOW TO FIND OUT WHERE YOU CAN GET LEGAL HELP. CUMBERLAND COUNTY ATTORNEY REFERRAL CUMBERLAND COUNTY BAR ASSOCIATION 2 LIBERTY AVENUE CUMBERLAND COUNTY COURTHOUSE CARLISLE, PA 17013 (717) 249-3166 (800) 990-9108 ALL THAT CERTAIN lot or piece of ground, improved with a dwelling house, situate at the corner of Prince and Orange Streets, in the Borough of Shippensburg, Cumberland County, Pennsylvania, bounded and described as follows: ON the South by Orange Street; on the West by Prince Street; on the North by land now or formerly )f Deck; on the East by land now or formerly of Hershey. Said lot having a frontage on Orange Street >f thirty-three (33) feet, more or less and an even width, a depth from Orange Street of ninety (90) feet o land now or formerly of Deck and further having thereon a frame dwelling house and garage and )eeing known and numbered as 201 East Orange Street, Shippensburg, Pennsylvania. 'ax Parcel #34-2415-197 ?1112ILEs BE NG KNOWN AS 201 EAST ORANGE STREET, SHIPPINSBORG, PA 17257 TITLE TO SAID PREMISES IS VESTED IN Timothy M. Norris and Paula M. Norris, his wife by Deed from Paul E. Leimer and Gretchen D. Leitner, his wife dated 12/10/98 and recorded 12/15/98, in Record Book 191, Page 1. V n - ? J C _ L f 1 -- l 1 - ! I rm u? 'r J i v en ` i PV WRIT OF EXECUTION and/or ATTACHMENT COMMONWEALTH OF PENNSYLVANIA) NO 02-2082 Civil COUNTY OF CUMBERLAND) CIVIL ACTION - LAW TO THE SHERIFF OF CUMBERLAND COUNTY: To satisfy the debt, interest and costs due WELLS FARGO HOME MORTGAGE, INC., F/K/A WNORWEST MORTGAGE, INC. PLANTIFF(S) From TIMOTHY M. NORRIS AND PAUL M. NORRIS (1) You are directed to levy upon the property of the defendant(s) and to sell SEE LEGAL DESCRIPTION (2) You are also directed to attach the property of the defendant(s) not levied upon in the possession of GARNISHEE(S) as follows: and to notify the gamishee(s) that: (a) an attachment has been issued; (b) the garnishee(s) is enjoined from paying any debt to or for the account of the defendant (s) and from delivering any property of the defendant (s) or otherwise disposing thereof; (3) If property of the defendant(s) not levied upon an subject to attachment is found in the possession of anyone other than a named garnishee, you are directed to notify him/her that he/she has been added as a garnishee and is enjoined as above stated. Amount Due $115,784.25 L.L.$.50 Interest FROM 6/5/02 TO 9/4/02 (PER DIEM - $19.03) $1,750.76 AND COSTS Atty's Comm % Any Paid $130.49 Due Prothy $1.00 Other Costs Plaintiff Paid Date: JUNE 4, 2002 REQUESTING PARTY: CURTIS R. LONG Prothonotary, Civil Division By: `n** ? le ?s Name FRANK FEDERMAN, ESQ. Address: ONE PENN CENTER AT SUBURBAN STATION 1617 JOHN F. KENNEDY BOULEVARD, SUITE 1400 PHILADELPHIA, PA 19103-1814 Attorney for: PLAINTIFF Telephone: 215-563-7000 Supreme Court ID No. 12248 AFFIDAVIT OF SERVICE PLAINTIFF WELLS FARGO HOME MORTGAGE, INC., F/K/A NORWEST MORTGAGE, INC. DEFENDANT(S) TIMOTHY M. NORRIS PAULA M. NORRIS SERVE TIMOTHY M. NORRIS AT 201 EAST ORANGE STREET SHIPPINSBURG, PA 17257 CUMBERLAND COUNTY KMD No. 02-2082 CIVIL ACCT. #7522967 Type of Action - Notice of Sheriffs Sale Sale Date: 9/4102 SERVED Served and made known to I a 6L, 0 , o'clock.m., at Pro Defendant, on the 41 day of?, 200_?,? of Pennsylvania, in the manner described below: a-'li Defendant personally served. Adult family member with whom Defendant(s) reside(s). Relationship is ?aL71. Adult in charge of Defendant(s)'s residence who refused to give name or relationship. Manager/Clerk of place of lodging in which Defendant(s) reside(s). Agent or person in charge of Defendant(s)'s office or usual place of business. an officer of said Defendant(s)'s company. Commonwealth Other: Desc Age Z4P, Heightkt" Weight Race &)Sex/ Other I, competent adult, being duly sworn according to law, depose and state that I personally handed a true and correct copy of the No 'ce of Sheriffs Sale in the manner as set forth herein, issued in the captioned case on the date and at the address indicated above. Sworn to and subscribed before me this if day of 2 N By: oPLEASE ATT T OSERVICE AT LEAST 3 TIMES. INDICATE DATES & TIMES OF SERVICE ATTEMPTED. Notarial Seal Lisa M.Qreaeon, Notary Public NOT SERVED CadtaM Born, Cumberland County cMySimmisslon Ex ' pt. 9, 200`r _ - , 200, at o'clock _.m., Defendant NOT FOUND because: Moved Unknown No Answer 1" Attempt: / / Time: Vacant 2°d Attempt: / / Time: 3rd Attempt: Time: Sworn to and subscribed before me this day of 200 Notary: By: Attorney for Plaintiff Frank Federman, Esquire - I.D. No. 12248 AFFIDAVIT OF SERVICE PLAINTIFF WELLS FARGO HOME MORTGAGE, INC., F/K/A NORWEST MORTGAGE, INC. DEFENDANT(S) TIMOTHY M. NORRIS PAULA M. NORRIS SERVE PAULA M. NORRIS AT 201 EAST ORANGE STREET SHIPPINSBURG, PA 17257 CUMBERLAND COUNTY KMD No. 02-2082 CIVIL ACCT. #7522967 Type of Action - Notice of Sheriffs Sale Sale Date: 9/4/02 SERVED Served and made known to Defendant on the NJ day of . ?UA10 2063, at o'clocke.m, at of Pennsylvania, in the manner Defendant personally served. Adult family member with whom Defendant(s) reside(s). Relationship is Adult in charge of Defendant(s)'s residence who refused to give name or relationship. Manager/Clerk of place of lodging in which Defendant(s) reside(s). Agent or person in charge of Defendant(s)'s office or usual place of business. an officer of said Defendant(s)'s company. Commonwealth Other: 14rdp C / r Description: Age /q F d leigh? Weight Race 601 Sex 1 Other I, '?\ Ao a competent adult, being duly sworn according to law, depose and state that I personally handed a true and correct copy of the 14otice of Sheriff's Sale in the manner as set forth herein, issued in the captioned case on the date and at the address indicated above. Sworn to and subscribed befor me this / T day of , 200P,. i C Nota . ?- By: AT LEAST 3 TIMES. INDICATE DATES & TIMES OF SERVICE ATTEMPTED. Notarial Seal Use M. aremon, Notary Public NOT SERVED Carlisle Boro, Cumberland County My Commission Expires Sept. 9. 2002 , i the y 200_, at o'clock _.m., Defendant NOT FOUND because: - Moved Unknown No Answer Vacant l't Attempt: Time: 2°d Attempt: / / Time: 3rd Attempt: Time: Sworn to and subscribed before me this day of 200-. Notary: By: Attorney for Plaintiff Frank Federman, Esquire - I.D. No. 12248 IN THE COURT OF COMMON PLEAS OF CUMBERLAND COUNTY, PENNSYLVANIA RE: WELLS FARGO HOME MORTGAGE, INC. F/K/A NORWEST MORTGAGE, INC. ) CIVIL ACTION vs. TIMOTHY M. NORRIS PAULA M. NORRIS CIVIL DIVISION NO. 02-2082 CIVIL AFFIDAVIT OF SERVICE PURSUANT TO RULE 3129 COMMONWEALTH OF PENNSYLVANIA ) COUNTY OF CUMBERLAND ) SS: I, FRANK FEDERMAN, ESQUIRE attorney for WELLS FARGO HOME MORTGAGE, INC. F/K/A NORWEST MORTGAGE, INC. hereby verify that on 614/02 true and correct copies of the Notice of Sheriffs sale were served by certificate of mailing to the recorded lienholders, and any known interested party see Exhibit "A" attached hereto. Notice of Sale was sent to the Defendant(s) on 6/4/02 by certified mail return receipt requested see Exhibit "B" attached hereto. DATE: July 17. 2002 FRANK FEDER AN, ESQUIRE Attorney for Plaintiff w a, ` aP?+tc? 1 a a.? j a ?I n3i3xee Id ci s5 1 0? („° N iayispdS'II d o ° a / a O °°o y . A x 6 ?+ Uj w'R kr C ° W n C/] o `a ° W N O ? a d ? U Qow C7 P. d ° n° " v w ? C7 a o ??? W z Ep a ??cn W ? MZ z ? a a O M p,, •--? ? VI ?--{ W eats w w ? > & L p???WA o U w to 8A A ? ? ? 3 ?, P4 ova $ w> O p O s`g y a° w ?-yUS a -N 00 $ a N o W N U] MS z-+ O N z C/? ?i A TO e t vi v' ON u 'a o ?a UU E w " w O i (Sa ?D a Z Q OU l^ ?L z-. ?y F° a L `u d °a v V N 4. T O ? 9 ? Q ? d L p .--i N M V vl ? .%V7 F 0 z< 7160 3901 4844 8593 4610 k TO: PAULA M. NORRI S, 201 EAST ORANGE STREET, SHIPPINSBURG, PA 17257 SENDER: KMD e REFERENCE: SALES ' PS Form 3800, June 2000 RETURN Postage 3, _ RECEIPT SERVICE Certified Fee - 1.91 Return Receipt Fee .1.5( Restricted Delivery 3.2( Total Postage & Fees N; . jo US Postal Service POS < OR DATE jB Receipt for C Certified Mail D ?w No Insurance Coverage Provided I Do Not Use for International mail e ---- - ----------------- -- ------ ----------------- 7160 3901 9844 8593 4603 TO: TIMOTHY M. NORRIS, 201 EAST ORANGE STREET, SHIPPINSBURG , PA 17257 Y E i 1 t i SENDER: KMD REFERENCE: SALES E F i t PS Form 3800 June 2000 RETURN Postage .34 s ! RECEIPT Certified Fee 1.90 I SERVICE Return Receipt Fee 1.50 ` j Restricted Delivery 3.20 £ Total Postage & Fees :- 94 C POST Aq US Postal Servloe E Receipt for CIA N _ i Certified Mail $ -' No Insurance Coverage Provided ?1?V30 N - Do Not Use for International Mail --------------- ------------------ ----- -- - ----- -- V n ca 0 1- c? C?j COMMONWEALTH OF PENNSYLVANIA COUNTY OF CUMBERLAND I SS: I, Robert P. Ziegler, Recorder of Deeds in and for said County and State do hereby certify that the Sheriff's Deed in which Federal Natl Mt Assoc is the grantee the same having been sold to said grantee on the 4th day of Sept A.D., )2002, under and by virtue of a writ Execution issued on the 4th day of June, A.D.,. )2002, out of the Court of Common Pleas of said County as of Civil Term, 2002 Number 2082, at the suit of Wells Fargo Hm Mta Inc fka Noarwest Mtg Inc against Timothy M Norris & Paula m is duly recorded in Sheriff's Deed Book No. 253, Page 3265. IN TESTIMONY WHEREOF, I have hereunto set my hand 2f-? and seal of said office this . day of Sept, A.D. 2002. Recorder of Deeds Wells Fargo Home Mortgage, Inc., F/K/A Norwest Mortgage, Inc Vs Timothy M. Norris and Paula M. Norris In the Court of Common Pleas of Cumberland County, Pennsylvania Writ No. 2002-2082 Civil Term Jason Vioral, Deputy Sheriff, who being duly sworn according to law, states that on June 17, 2002 at 9:10 o'clock PM, he served a true copy of the within Real Estate Writ, Notice and Description, in the above entitled action, upon the within named defendant, to wit: Timothy M. Norris, by making known unto Timothy M. Norris, at 201 East Orange Street, Shippensburg, Cumberland County, Pennsylvania, its contents and at the same time handing to him personally the said true and correct copy of the same. Jason Vioral, Deputy Sheriff, who being duly sworn according to law, states that on June 17, 2002 at 9:10 o'clock PM, he served a true copy of the within Real Estate Writ, Notice and Description, in the above entitled action, upon the within named defendant, to wit: Paula M. Norris, by making known unto Timothy M. Norris, adult in charge of residence at, 201 East Orange Street, Shippensburg, Cumberland County, Pennsylvania, its contents and at the same time handing to him personally the said true and correct copy of the same. Ronald E. Hoover, Deputy Sheriff, who being duly sworn according to law, states that on July 9, 2002 at 4:25 o'clock P.M., he posted a true copy of the within Real Estate Writ, Notice, Poster and Description, in the above entitled action, upon the property of Timothy M. Norris and Paula M. Norris located at 201 East Orange Street, Shippensburg, Pennsylvania, according to law. R. Thomas Kline, Sheriff, who being duly sworn according to law says he served the above Real Estate Writ, Notice, Poster and Description in the following manner: The Sheriff mailed a notice of the pendency of the action to one of the within named defendants to wit: Timothy M. Norris, by regular mail to his last known address of 201 East Orange Street, Shippensburg, PA 17257. This letter was mailed under the date of July 17, 2002 and never returned to the Sheriff's Office. R. Thomas Kline, Sheriff, who being duly sworn according to law says he served the above Real Estate Writ, Notice, Poster and Description in the following manner: The Sheriff mailed a notice of the pendency of the action to one of the within named defendants to wit: Paula M. Norris, by regular mail to her last known address of 201 East Orange Street, Shippensburg, PA 17257. This letter was mailed under the date of July 17, 2002 and never returned to the Sheriff's Office. R. Thomas Kline, Sheriff, who being duly sworn according law, says that after due and legal notice had been given according to law, exposed the within described premises at public venue or outcry at the Court House, Carlisle, Cumberland County Pennsylvania, on September 4, 2002 at 10:00 o'clock A.M. He sold the same for the sum of $ 1.00 to Attorney Frank Federman for Federal National Mortgage Association. It being the highest bid and the best price received for the same Federal National Mortgage Association, of 1900 Market Street, Suite 800, Philadelphia, PA 19103, being the buyer in this execution, paid Sheriff R. Thomas Kline the sum of $689.83, it being costs. Sheriffs Costs Docketing: 30.00 Poundage 13.52 Posting Bills 15.00 Advertising 15.00 Acknowledging Deed 30.00 Auctioneer 10.00 Law Library .50 Prothonotary 1.00 Milage 27.60 Certified Mail 5.51 Levy 15.00 Surcharge 30.00 Law Journal 232.85 Patriot News 184.15 Share of Bills 25.20 Dist. of Proceeds 25.00 Sheriffs Deed 29.50 $689.83 paid by attorney 9/12/02 Sworn and subscribed to before me sw Thi ? - s day of 4".Z. , , 2002, A.D.Qh,???.", - R. Thomas Kline, heriff . Prothonotary i BYE ftb- 14 'e ??'vUU Real Estat ,beputy 30 ,_jZ_ 3S/47 Pte, /a991Y WELLS FARGO HOME MORTGAGE, INC., F/K/A NORWEST MORTGAGE, INC. V. Plaintiff, CUMBERLAND COUNTY COURT OF COMMON PLEAS TIMOTHY M. NORRIS PAULA M. NORRIS CIVIL DIVISION NO. 02-2082 CIVIL ? G d) AFFIDAVIT PLIRS ANT TO RULE 3129 ?Affid it No. l) WELLS FARGO HOME MORTGAGE INC. F/K/A NORWEST MORTGAGE 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,201 EAST ORANGE STREET SHIPPENSBURG PA 17257 1. Name and address of Owner(s) or reputed Owner(s): Name TIMOTHY M. NORRIS PAULA M. NORRIS Last Known Address (if address cannot be reasonably ascertained, please indicate) 201 EAST ORANGE STREET SHIPPINSBURG, PA 17257 201 EAST ORANGE STREET SHIPPINSBURG, PA 17257 2. Name and address of Defendant(s) in the judgment: Same as above 3. Name and last known address of every judgment creditor whose judgment is a record lien on the real property to be sold: Name Last Known Address (if address cannot be reasonably ascertained, please indicate) None 4. Name and address of last recorded holder of every MORTGAGE of record: Name Last Known Address (if address cannot be reasonably ascertained, please indicate) 4455 ARROWWEST DRIVE NORWEST BANK, N.A. P.O. BOX 49069 COLORADO SPRINGS, CO 80949 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 Domestic Relations of Cumberland County Commonwealth of Pennsylvania Department of Welfare 201 EAST ORANGE STREET SHIPPENSBURG, PA 17257 13 North Hanover Street Carlisle, PA 17013 PO Box 2675 Harrisburg, PA 17105 I verify that the statements made in this affidavit are true and correct to the best of my personal knowledge or information and belief. I understand that false statements herein are made subject to the penalties of 18 Pa. C.S. Sec. 4904 relating to unswom falsification to authorities. May 30. 2002 DATE {FED RMAN, ESQUIRE Attorney for Plaintiff WELLS FARGO HOME MORTGAGE, INC., F/K/A NORWEST MORTGAGE, INC. Plaintiff, V. TIMOTHY M. NORRIS PAULA M. NORRIS Defendant(s). CUMBERLAND COUNTY No. 02-2082 CIVIL May 30, 2002 TO: TIMOTHY M. NORRIS 201 EAST ORANGE STREET SHIPPINSBURG, PA 17257 PAULA M. NORRIS 201 EAST ORANGE STREET SHIPPINSBURG, PA 17257 "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 BANKR UPTCYAND THIS DEBT WAS NOT REAFFIRMED, THIS IS NOT AND SHOULD NOT BE CONSTRUED TO BE ANATTEMPT TO COLLECT A DEBT, BUT ONLY ENFORCEMENT OF A LIEN AGAINST PROPERTY. * * Your house (real estate) at, 201 EAST ORANGE STREET, SHIPPENSBURG PA 17257, 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 $115,784.25 obtained by WELLS FARGO HOME MORTGAGE, INC., F/K/A NORWEST MORTGAGE INC (the MORTGAGEe) against you. In the event the sale is continued, an announcement will be made at said sale in compliance with Pa.R.C.P., Rule 3129.3. NOTICE OF OWNER'S RIGHTS YOU MAY BE ABLE TO PREVENT THIS SHERIFF'S SALE To prevent this Sheriffs Sale, you must take immediate action: 1. The sale will be cancelled if you pay to the MORTGAGEe the back payments, late charges, costs and reasonable attorney's fees due. To find out how much you must pay, you may call: (215) 563-7000. 2. You may be able to stop the sale by filing a petition asking the Court to strike or open the judgment, if the judgment was improperly entered. You may also ask the Court to postpone the sale for good cause. You may also be able to stop the sale through other legal proceedings. You may need an attorney to assert your rights. The sooner you contact one, the more chance you will have of stopping the sale. (See notice on page two on how to obtain an attorney.) YOU MAY STILL BE ABLE TO SAVE YOUR PROPERTY AND YOU HAVE OTHER RIGHTS EVEN IF THE SHERIFF'S SALE DOES TAKE PLACE 1. If the Sheriffs Sale is not stopped, your property will be sold to the highest bidder. You may find out the price bid by calling (215) 563-7000. 2. You may be able to petition the Court to set aside the sale if the bid price was grossly inadequate compared to the value of your property. 3. The sale will go through only if the buyer pays the Sheriff the full amount due in the sale. To find out if this has happened, you may call (717) 240-6390. 4. If the amount due from the Buyer is not paid to the Sheriff, you will remain the owner of the property as if the sale never happened. 5. You have the right to remain in the property until the full amount due is paid to the Sheriff and the Sheriff gives a deed to the buyer. At that time, the buyer may bring legal proceedings to evict you. 6. You may be entitled to a share of the money which was paid for your house. A schedule of distribution of the money bid for your house will be filed by the Sheriff within 30 days of the sale. This schedule will state who will be receiving that money. The money will be paid out in accordance with this schedule unless exceptions (reasons why the proposed distribution is wrong) are filed with the Sheriff within ten (10) days after the distribution is filed. 7. You may also have other rights and defenses, or ways of getting your home back, if you act immediately after the sale. YOU SHOULD TAKE THIS PAPER TO YOUR LAWYER AT ONCE. IF YOU DO NOT HAVE A LAWYER OR CANNOT AFFORD ONE, GO TO OR TELEPHONE THE OFFICE LISTED BELOW TO FIND OUT WHERE YOU CAN GET LEGAL HELP. CUMBERLAND COUNTY ATTORNEY REFERRAL CUMBERLAND COUNTY BAR ASSOCIATION 2 LIBERTY AVENUE CUMBERLAND COUNTY COURTHOUSE CARLISLE, PA 17013 (717) 249-3166 (800) 990-9108 ALL THAT CERTAIN lot or piece of ground, improved with a dwelling house, situate at the corner of Prince and Orange Streets, in the Borough of Shippensburg, Cumberland County, Pennsylvania, bounded and described as follows: DN the South by Orange Street; on the West by Prince Street; on the North by land now or formerly )f Deck; on the East by land now or formerly of Hershey. Said lot having a frontage on Orange Street )f thirty-three (33) feet, more or less and an even width, a depth from Orange Street of ninety (90) feet o land now or formerly of Deck and further having thereon a frame dwelling house and garage and wing known and numbered as 201. East Orange Street, Shippensburg, Pennsylvania. 'ax Parcel #34-2415-197 ,,RIL'ES BE-NG KNOWN AS 201 EAST ORANGE STREET, SHIPPINSBORG, PA 17257 TITLE TO SAID PREMISES IS VESTED IN Timothy M. Norris and Paula M. Norris, his wife by Deed from Paul E. Leitner and Gretchen D. Leitner, his wife dated 12/10/98 and recorded 12/15/98, in Record Book 191, Page 1. WRIT OF EXECUTION and/or ATTACHMENT COMMONWEALTH OF PENNSYLVANIA) COUNTY OF CUMBERLAND) NO 02-2082 Civil CIVIL ACTION - LAW TO THE SHERIFF OF CUMBERLAND COUNTY: To satisfy the debt, interest and costs due WELLS FARGO HOME MORTGAGE, INC., F/K/A WNORWEST MORTGAGE, INC. PLANTIFF(S) From TIMOTHY M. NORRIS AND PAUL M. NORRIS (1) You are directed to levy upon the property of the defendant(s) and to sell SEE LEGAL DESCRIPTION (2) You are also directed to attach the property of the defendant(s) not levied upon in the possession of GARNISHEE(S) as follows: and to notify the garnishee(s) that: (a) an attachment has been issued; (b) the garnishee(s) is enjoined from paying any debt to or for the account of the defendant (s) and from delivering any property of the defendant (s) or otherwise disposing thereof; (3) If property of the defendant(s) not levied upon an subject to attachment is found in the possession of anyone other than a named garnishee, you are directed to notify him/her that he/she has been added as a garnishee and is enjoined as above stated. Amount Due $115,784.25 L.L.$.50 Interest FROM 6/5/02 TO 9/4/02 (PER DIEM - $19.03) $1,750.76 AND COSTS Any's Comm % Atty Paid $130.49 Due Pmthy $1.00 Other Costs Plaintiff Paid Date: JUNE 4, 2002 REQUESTING PARTY: CURTIS R. LONG Prothonotary, Civil Division By: _ _O rr ?- e?/:Y_ 4t?O Name FRANK FEDERMAN, ESQ. Address: ONE PENN CENTER AT SUBURBAN STATION 1617 JOHN F. KENNEDY BOULEVARD, SUITE 1400 PHILADELPHIA, PA 19103-1814 Attorney for: PLAINTIFF Telephone: 215-563-7000 Supreme Court ID No. 12248 Real Estate Sale # 52 On June It, 2002 the sheriff levied upon the defendant's interest in the real property situated in the Borough of Shippensburg, Cumberland County, PA Known and numbered as 201 East Orange Street, Shippensburg, and more fully described on Exhibit "A" filed with this writ and by this reference incorporated herein. Date: June 11, 2002 i,J - - ,- t, end ?` A27 C;D THE PATRIOT NEWS THE SUNDAY PATRIOT NEWS Proof of Publication Under Act No. 587, Approved May 16, 1929 Commonwealth of Pennsylvania, County of Dauphin) ss Frank J. Epler being duly sworn according to law, deposes and says: That he is the Controller of The Patriot News Co., a corporation organized and existing under the laws of the Commonwealth of Pennsylvania, with its principal office and place of business at 812 to 818 Market Street, in the City of Harrisburg, County of Dauphin, State of Pennsylvania, owner and publisher of The Patriot-News and The Sunday Patriot-News newspapers of general circulation, printed and published at 812 to 818 Market Street, in the City, County and State aforesaid; that The Patriot-News and The Sunday Patriot-News were established March 4th, 1854, and September 18th, 1949, respectively, and all have been continuously published ever since; That the printed notice or publication which is securely attached hereto is exactly as printed and published in their regular daily and/or Sunday/ Metro editions which appeared on the 23rd and 30th day(s) of July and the 6th day(s) of August 2002. That neither he nor said Company is interested in the subject matter of said printed notice or advertising, and that all of the allegations of this statement as to the time, place and character of publication are true; and That he has personal knowledge of the facts aforesaid and is duly authorized and empowered to verify this statement on behalf of The Patriot-News Co. aforesaid by virtue and pursuant to a resolution unanimously passed and adopted severally by the stockholders and board of directors of the said Company andl 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 mes 4th day of ugus 2 A.D. S A L E #52 Notarial Seal Terry L. Russell, Notary Public REAL ESTATE SALE No. 52 City Of Harrisburg, Dauphin County Writ No. 2002-2082 My Commission Expires June 6,2t:6 NOT Y PUBLIC Civil Term Home Mortgage Inc., Member, Pennsylvania Association Of Notaries My commission expires June 6, 2006 Vida Norwest Mortgage, Inc. vs Timothy M. Norris CUMBERLAND COUNTY SHERIFFS OFFICE Paula M. Norris CUMBERLAND COUNTY COURTHOUSE Atty: Frank Federman DESCRIPTION CARLISLE, PA. 17013 ALL THAT CERTAIN lot or piece of ground, improved with a dwelling house, situate at the corner of Prince and Orange Streets, in the Statement of Advertising Costs Borough of Shippensburg, Cumberland County, To THE PATRIOT-NEWS CO., Dr. Pennsylvania, bounded and described as follows: ON the South by Orange Street; on the West by For publishing the notice or publication attached Prince Street; on the North by land now or hereto on the above stated dates $ 182.40 formerly of Deck; on the East by land now or formerly of Hershey. Said lot having a frontage on Probating same Notary Fee(s) $ 1.75 Orange Street of thirty-three (33) feet, more or Total $ 184.15 less and an even width, a depth from Orange Street of ninety (90) feet to land now or formerly of Deck and further having thereon a frame 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. dwelling house and garage and being known and numbered as 201 East Orange Street, Shippensburg, Pennsylvania. Tar Parcel #34-2415-197. PREMISES being known as 201 East Orange Street, Shippensburg, PA 17257. TITLE TO said premises is vested in Timothy M. Norris and Paula M. Norris, his wife, by Deed from Paul E. Leimer and Gretchen D. Leitner, his wife, dated 11/10198 and recorded 12115198, in record Book 191. Page 1. By .......................... PROOF OF PUBLICATION OF NOTICE IN CUMBERLAND LAW JOURNAL (Under Act No. 587, approved May 16, 1929), P. L.1 "784 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 sand 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. 52 Writ No. 2002-2082 Civil Wells Fargo Home Mortgage, Inc., F/K/A Norwest Mortgage, Inc. vs. Timothy M. Norris and Paula M. Norris Atty.: Frank Federman ALL THAT CERTAIN lot or piece of ground, improved with a dwell- ing house, situate at the corner of Prince and Orange Streets, in the Borough of Shippensburg. Cumber- land County, Pennsylvania, bound- ed and described as follows: ON the South by Orange Street; on the West by Prince Street; on the North by land now or formerly of Deck; on the East by land now or formerly of Hershey. Said lot hav- ing a frontage - Orange Street of R ger M. Morgenthal, Editor SWORN TO AND SUBSCRIBED before me this 9 day of AUGUST', 2002 NOTARK SEAL.----?- LOtS E. SNYDER, Notay pubAc co" Boro, cwtww qty My CWffl6W n E*= Maft 55, W thirty-three (33) feet, more or less and an even width, a dept from orange Street of ninety (90) feet land now or formerly of Deck and further having thereon a frame dwelling house and garage and be- ing known and numbered as 201 East Orange Street, Shippensburg, Pennsylvania. Tax Parcel #34-2415-197. PREMISES BEING KNOWN AS 201 EAST ORANGE STREET, SHIP- PENSBURG, PA 17257. TITLE TO SAID PREMISES IS VESTED IN Timothy M. Norris and Paula M. Norris, his wife by Deed from Paul E. Leitner and Gretchen D. Leitner, his wife dated 12/10/98 and recorded 12/ 15/98, in Record Book 19 1, Page 1 .