HomeMy WebLinkAbout02-3105FEDERMAN 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 28217-2407
Plaintiff
ATTORNEY FOR PLAINTIFF
COURT OF COMMON PLEAS
CIVIL DIVISION
TERM
V. NO. 0? _ 33/Os?-
CUMBERLAND COUNTY
LARRY E. JUMPER, JR.
102 LONGVIEW DRIVE
SHIPPENSBURG, PA. 17257
Defendant(s)
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 #: 7558448
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 28217-2407
2. The name(s) and last known address(es) of the Defendant(s) are:
LARRY E. JUMPER, JR.
102 LONGVIEW DRIVE
SHIPPENSBURG, PA. 17257
who is/are the mortgagor(s) and real owner(s) of the property hereinafter described.
3. On 2/26/99 mortgagor(s) made, executed and delivered a mortgage upon the premises
hereinafter described to COMMERCIAL AND FARMERS BANK T/A FOUNDERS
MORTGAGE COMPANY which mortgage is recorded in the Office of the Recorder of
CUMBERLAND County, in Mortgage Book No. 1522, Page 957. By Assignment of
Mortgage recorded 9/27/99 the mortgage was assigned to PLAINTIFF which Assignment
is recorded in Assignment of Mortgage Book No. 625, Page 1015.
4. The premises subject to said mortgage is described as attached.
5. The mortgage is in default because monthly payments of principal and interest upon said
mortgage due 2/1/02 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 $81,759.60
Interest 2,459.36
1/1/02 through 6/1/02
(Per Diem $16.18)
Attorney's Fees 1,225.00
Cumulative Late Charges 113.92
2/26/99 to 6/1/02
Cost of Suit and Title Search 550.00
Subtotal $86,107.88
Escrow
Credit 31.90
Deficit 0.00
Subtotal 31.90
TOTAL $86,075.98
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
$86,075.98, together with interest from 6/1/02 at the rate of $16.18 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.
F ERMAN AND/? P AN, LLP
By: ?ftdra d /tg ?.
FRANK FEDERMAN, ESQUIRE
LAWRENCE T. PHELAN, ESQUIRE
FRANCIS S. HALLINAN, ESQUIRE
Attorneys for Plaintiff
85/30/82 18:34:01 -> 215 563 5534 Page 002
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:WHEN RECORDED MAIL T0:
COMMERCIAL L FARMERS BANK t/a
POUNDERS MORTGAGE COMPANY
0018 CENTRE PARK DRIVE, SVITE
100
COLUMBIA, MARYLAND 21045
Loan No. 98-2504
RGDERT Q. ZIEGLER
R£GORD-R Of DEEDS
GUN9ERLAl4D COUNTY-PA
' 99 FEB 26 M 2 25
A&-. rea L. F. 1,e„ g pal _
MORTGAGE
THIS MORTGAGE (" aunty Lwtruntmrq Is Sim 04 FEBRUARY 29, 19,99
Um nloaoey0r L LARRY E. JUMPER JR.
bw4ffi sm a Rxm= M?WM ("Btlerowere). Thi1 -Q=.,'ky lnabvmant If giant m
• 6
which it tLABKdf, AMYMI9D XW GWagM ,
0tglind and e9clu under be lawt of MARYLAND and rh0n ddmt is
0878 CENTRE PARR DRIVE, 9VIT8 100
COLUNSIA, MARYLAND 21045
EIGHTY POUR THOUSAND FLVE HUND ('Loader"). BWWMC owns Larder the Pr(oc(Pai aura of
EIGHTY S 04,550.00 RED PIPTY AND 00/100-••r..e*er
1. Iatt debt is evme by Buroweet am deed as tam: data a tut
Seamry IaNrussw ("Nate"), which provides fm ==* pweamm, with an 1118 d*, if = paid ar0or, due end
pryable ca MARCH 1, 2029 . Thit 9eeudty b*=Mt ratmm an Loader: (8) the repaymat of
Tim debt cA&wsd by the Nom, whh imml, and ail ralewtlt. wasslom and mndinnolnna of the Note: (b) the
paymcd of All oar rstnt, w1W internal, advanced under panaQaple 7 to protect the eswrity of this 9mtdty
k9mu a; and (c) the putcaunnce of amowm'e covearom and eveeawl under this Security lonrueneve and ac
Nuts. For th4 pnrpoae. Borrow, date hereby moaKrde pram bad convey w Loader the f011ewleE described property
roancd In CUMBERLAND County. Phoatylvaela:
LEGAL DESCRIPTION ATTACHED HERL-M AND MALE A FART RMRVP A9 EXHIBIT
vA
which hes the addrm of 102 LONGVIEW nR IVn'
Pttnaylvanit 17257 (p?uperty Addrm,).
[Zip Core)
PNXNMVAMA - 9eNla family - Res He %A& tit umly6W 00MUMM
GRIPPENSBURG
(CY)
h° raes 1v%(" 1 of e)
1Q1K15.' "R 357
85/38/0Z 18:34:18 -> 215 563 5534 Page 983
TQUATHER WrTrl III Its Itu)eoMMIS now err hereafter am on the properly: std eft comments,
' apPUneneocae, end Ponufel now or hmea0or a pull of the property. All wplwmmn and addhlens &an Alan he
covered by thin Security lotnmimt. All of The brogotng Is internal to to tha Seeurity lnststmtant as die 'pioperry "
BORROWER CDWNANTS rbm Borrower ts LIWWY Wined of the estate hereby convoyed and has the right in
trop-a-, pwu and corrvcy Jae laost my and that do property Is uaenamhbered, except fw rncombnecca of runard.
Borrower warrants and will defenses generally the tide m the Property against all Claims and demands, subject to my
wnvmbaanrss of reeecd.
TM5 SECURITY INSTRUMENT C*MW a wlban cpyleaots for optioned use and not-uniform mrmema with
Veiled vuwim by jurbillatloe m mmrliwa a umfann rcmiey inamment mverinp red pmpety.
UNIPORM COVENANTS. Borrower and Lender wvapm and " as fall=&
1. Payutat of Pritd(d and I F r Repgmnsr atl fob L7upa. Borrower shall promptly pay win due
the pdwtpd of sod leksen m the debt widowed by the Now and any pmpaymant and law charga due under the
Note.
2- Fodde fa Tans ON macron. Subject to oppllable law at to a Wllnm wai ver by Lender. Rotruwsr shall
pay to wader on the day =:eldy payinama p die under the Note, until m/ Notes is paid in full. a ram ('A,,&')
for., (a) yarly was mal awaemesn whkh may ausia priority over this securi y fbWvM m a a Ilea on the property;
(b) yearly 1--kid vaymeate or aranad rests an the Poverty, if my; (u) yearly heated or property iemrance
pn mums; (d) yearly Rood Wnra0ea Presidents, It any; (e) dvmly mortgage inmamen ptmniumn, trolly; end (D MY
am payable by Basrower Its Lender, In uwtdama with the provistum of paragraph B, in lien of the psymem of
nourna it insurance pMMH=. Them )tense are called Ticrow Items.' Leader Coy, at any Ilene, alien aid hold
Prods In an amount sae to uuand the oaaleram amsamt a leader for a federally federal Met" Iran mq xequtw
for Borrower's cmWw m ma clear the federal Real Farm Smlmtmt Pmcebum Act of 1910 se amended from time
up time, 12 U. S.G. E Wi R wit, (•RB,WA' ). umws another law due pplW to Ihs Fine wee a lower amount. If
so. Loader may. at sly t1us, collect mid hold Funk is an amust rem to emCad the lower ==I. Linder nwy
And- ft omm of I'ma On all do bass of eurnm dad and raamable stethoscope of eapmdituro or ruture
Beaaw Items or odeatviae in aaemaga wish appliable, law.
The funds ebdl be held in an Institution whose deposits are Insured by a rtstaal macti:y, hutrummalhy, or cc"
(Including Udder, if I.mder is such an imiitutiao) or in nay Fat" flume Lam Bank. tsmder shal apply the Funds
to pay the Escrow Items. Lewin may apt duric Borrower for holding and Applying die fob. seat" a ialptil;
the aaemw wcoual. at valfying the Eanrow IEmw, unkse Larder pays furrm c, mkrcia on the Paed1 ad applicable
law patmite Land- to make such a charge. However, Leda may mom Ramm yr in pay a one.rbne chap fat an
independent real muse tan mportrng eay4x used by Leader in egnncom with dun loan, unless aMICAW, law
provides otbenvdse. Unime an ovan mN Is nude or appllable Law requites iemtest to be paid. Leader IMU rem be
Ipulrtd up pry Bormwa any Iowtaw or un inSi on die Amtis. Harrower and Lablir mp ego to wrIUM, however.
war interest thin he paid on the Funds. larder ahW give to Borrower, without charge, an amid accomtdag of the
Punch, hbuwlm credits and dotsw in the Funds aged the purpow Ser which each debit to the Prods was trade. The
Acme IN pledaed a whhu;mral security fire all srma ecowed by this Sevray Imauosom.
If the Funds held by Linda timed the amogme parceled to be held by applicable law, Leader AM sosmmt w
Borrows for tha mean Ponds in accordance with the valid hrraa of applictbte law. If rho smouor of the Punts held
by Lendar is my time is not euMMI to pay she Bestow lptma when due, Lender my to notify Borrower to writing,
rod. in such csto Borrower shall pay to Lads the arooua necexnry to make up This de6ctancy. Borrower mall tnsake
up the deficiency in no more Ilan rwdve mnmhly payments, a Ind, 'a sole dhcietinn.
Upon paynhmt ins pall of Ali amen secured by this Sec rlry Instrunuoa Isnds sbdl promptly reparW w Barrnwer
KEY Funds yid by Lamer. if, radar paragraph 21. Lender AaW eeptst o or sell the Pecomy, Lathe. perc m the
wquishion or aide of plan property, shall AWy my I" held by La ides a the time of acquisition no role m a credit
against the sums secured by this Saco" Instrument.
3. Application of F 3 . Vnieve pgiabN law pmvlda adhfswlar an prymmw lmeivW by Laakx ender
parapapha 1 Aid 2 shat] be wiled: ant. ie ANY preprymmr Charges due wader the Now; Adeend, us amounpa able
Mader paragraph 2; weird, k muss, OveK towns, To pChic" tine: and Lost, to my late steam due under die Now.
a. CmgP: Ueda Oanowa Old pay all tare. mmu mmu.
PmMY which my 11119 FAY foes and impositions or ground rsti. to the
r ur ier der 3COM9Y
se p Imein pa and Imsehold payumms or ground xnli, if any.
BoirawVr chest pay "" abligefiao in the roam provides is paragraph 2. at f If aoi paid in that mmhher, Hornrwer
0WI PAY Ul= on rinw directly in the person owed peyumh. Bnsiowa gull promptly flunlsh W Ln d r all notice,
Of ammmit to he paid urake this paragraph. If Borrower make, them paytumo dimcdy, Borrower Sul promptly
furnish to Loader romlpD cridenaig Me payment.
Borrower shall promptly discharge any Ilm which has pswhy aver title Security hwummt unless Borrower: (a)
1111M In writing W the peyi cat of tits obligmioi metered by the Ilse in a mwtrcr tics nWc In I,mda; fill mma[1
Ie good faith the tan by, or defands adval enfmvamamt of the lien in, legal proceedings which in the Leader's opinion
epewtb la prevent the eMbMM= of der dim: at (c) secures from the holder of the lien an agreement. Isdaraaary
on 14WIT mbmdmaing die lies to this Secairy Instructions. If LaWor dtslxmioa th!t coy psi of the property is
abject or I tin which mp some Psarhy ever this Security W tcumrnt. La dis, may give Borrower A m uw idantifyiug
ty dim. Bormwar mm me* The lion or Ieka owe or note or the adons act forth above wmde 10 days of tlN giving
of aetice.
5- swam Cr Ptopary Museum Borrower doll keep the butovenwnw tow exlsdgl or hereafter acted M
me Property inured smart Iwo by fire. herd, inolutkd within the ream vownded coverage' axes wry miter bastard.,
including floods of flooding, for whim Lmlgx wpultet sanctions. ?his hmurwuw shall be mulawlad in the memets
And for the porioda tut !seder retches. The lansranm uwrdw pmvWbg he loan raoR .hull Iro them by animator
mhjecr to Lender's approval which .hull rem he cit m,utabBy whaadd. If attenuates, tabs to iWmsin Cove
described sbave, paragraph my, at Lender', option, ebtiin coverage, w proton Lwdw'o rights in the Property in
amtrdmes with per
FMOI VAM - imer faster .. now merrmede U. UNI par h "Rmrorr Few yore w?i (nap 1 of e)
lmo#1522MB9 258
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' All lasureace pttictes ad renewals shall be acceptable to fee old shall Include a situard mutt lia choose.
• Leader sbdl haw die right to hold the policies and ne ewals. If Under requires. Borrower shag promptly give to
Latin all mop of paid wembm ad renewal notion. In die enm of Ion, Bomowr shall give Prompt MOM to
the bsurance curies ad Landr. Lander my hake pool of hats if mac made worn" by Bono,vr.
Value Lauder sud Bonewr othersener apaa in wrnhtl, Insurance Prwade shall be applied an ruaraloa a
repair of die Ropety damaged. 9 the aemruion of repatr is ammm4yty feasible and Loft's security is not
leneood. If the reomrnion or repair it not eaommically hesdble or Lender's seagiry, would be hemmed. the insutmce
prucurls shall be applied to dm aim memod by this Scarity Iaettumeni, *Led= or not then due. with my euen
paid to Borrower. If Bortotwy sbtdune the Propcny, or duct not answer within 30days a notice from fender that
the ieaarmce worries has mMemd w whle a elmhe, fire leader my milord dw btmsmes proced.. Leader Only ue
the Prnxda in repair OF tame the Property m to pay some --abaci by this Socully Immurm, wbutba or tux new
due. The 3tld.y period will begin Am dw notice u Sim.
Unites Imtler and Bantle othmwma agw Iit wring. any application of ptatxsJs co principal dw tiro cued
or postpone the due due of the mombly payments rclmW to In pwagrephw 1 mid d or dtmgtr the amunt of die
payments. If under Par ssmis 21 the Peoperty N Involved by Lander, Bmnnar's Hiller to my insurance policies and
procash resulting from dmwp to an Propmy pram to the ergtietdoli shell pan to lacdar an the eamnt of the
swm
seemed by this Security Instrument =nW mdy pine to the acquisition.
Q mctaPwbaY, Remvnlm, Yana ono nd ftWcdaa of It Propmp' BcirchWe Loa Appgmdm;
Lessidda. Borrower shag =copy. establish, and we duce Property as Borrower's primltial reddmce within ataaydays
aft thtl srcudon of this $Kathy Imlmmat ad ring C=Lmn to ompy the property u Borsowees prindrd
suidern far ac ire me year after the data of omupmay, old= Lender othuwim agrees m writing, which mums
Mall non be tmremmmbiy withhold, or miss eatemadeg deememmes exist which ere beyond Borrower's comml.
Burrower shall not Oss roy, dmwgc or bmp,dr the Property, allow ere Pmpmy m daodt , or commit wsas = the
property. Baeewer shad he in dehult if my forfugum action or prewoeding, whaler civil at almlad. It begun Me
in Lender's pod fah )udpem could romb In ffirfW tm of Lb Pmpeny or odeomme maneHdly irmalc the Use
aeon by this Sentry Investment or Lendr'a and" bmttnat. Bmrowe may cum such a dcfiult and reimou. as
provided in paragraph !l, by csosfng mu eduon or protecting in be dludetnd with a Initial the, in Leader's Sold faith
dweamimnim, precludes fodeitme of the Br.rawm'x neeren in the Property or olhm material impairmmi of the him
=KW by this Severity Inconstant or Lmdw'a rteatcity )mrert, Burnewan ehdl also be in defsdt if)hormwm, distill
the tom sppBcmpon proven, Sae maMaBy Aim or htsmorme Information or suntan in Lander for failed to
provide Larder with any mantelat lolbmatitm) In connection with die loan "Webcrrl by the Note, michadici , but not
limited to, rwprelrm[atieat cmmedag Borrower's occupancy of the Prapearty a a Prndpal rasidancw If this Scwrrity
Instrument It OF a lwrthold. Borrower sh ll omQly, with all Me provisional of the tern. If Borrower acquires Sa title
W the Property, the iop"d and low be nde shad not mwpr, union candor after, m rte merger in writing.
7. Fan nie= of Leedsl Rom b dial Prepedly. If Bombwer late he portions the covrrnm all Una mn
oamaimd to mice Maturity mermtand, m duct is a klW phi than may ahealgmmly affect Looder's ridtns in me
property (Mesh u a pires" In bnCnpny, prebane. Inc onde®sdon or torten= or to afomw laws or
regululms), mesa Under may do ad pay for wilsor m lambency to prow We vision of the Propanry, and lender's
righv in W property. Ladn't aamu may bolutls ptgbg any am stated by a Jim which bar priority over this
Semmry Inmumend, appearing in caul. Ix7ml rraemebe attameys' tam trod emerfoS m me "aedy to make repMn,
Aldmulu Lander may take sell= under this paragraph 7, Leader does mat hoe to ds $e.
Any annum dttb reed by La idn under dds paragraph 7 del become tiMlonal debt of Borrotrek secmhtd by
We Sweatily instrument. Unless Borrower and Lrdet agree to other trine of payment, thee antrum, aball bar
m0.rint from Iles data of diabowrment an the Nom rte and shag he payable, with interest, upon notice from Lender i
m Botowr cgowing payment,
1. Is- -4, 1 If Lmdr required mortgage immemu a a condition at nothing the Ism arurd by
this Ssrmrity lanmm=, Bortowu shag pay gas premium teryitd n nualtsn dm monutSc naurmta: in affoa. If,
fr mY mmm. the Omtlagm lft mnee eoveya required by Lender laptu or excess m be in eBhet. Beetera r that
pay the premiums ragtdred to obrem mversga submmngy equlvalnt m the monglip tonurem prsrdmudy in nowt,
at a call substantially sgolvdeu to the cat to Borrower of the mortgage la anent previously in effen, 0em at
9=111e mortguge insurer approved by tenter. It robnmtdlY egaiyainl mmtlage Insurant coverage is not
avaltabh, Borrower shag pat m Lender wh coo m a elm equal in =wravegth of the yearly morlap inwanwo
prenum bemS pad by Borrows whim the nsuulxe coverage Upaed OF mead OF be in deal. I - Will U=Pt,
ese and Main Irmo payments u a lose crave in. tiea of morgage insmanm. I= teserw payments may on tortger
be required. at the opal= of Lender. If amngage human=e mverole (m the mom add for die period than Lder
requires) provided by m issuer approved by lender again hseortes available and is obtained. Borrower shut pa, the
pwmiutm requited or =I--- money betmm= in adta, or an provide a Ion reserve. until to requitwntu for
?
mortgage insurance and. in meardmr with my whom alinement bet-nor narrower and teadr or applicable i. ,
9. Inptcti=. Lcodr a IN agent troy ohm fMOMM MW.U Upon ad t"&IM Of dm Prouty. Leger
dial gin Borrower notice a the sum of at pilot ro an inspection sue is fase0atlle cam for me [mpetmn,
10. CEedmm obL the procmds Of ny award r claim er damscu. d;rar at eruedhiantLl, in oulsenied wish
am amWancesbn or tiger R=s Of my Ism of me Propanry, or for com ityaae in ilea of m do mat=, am busby
.aaposd and shall be paid to Lander.
It die mft Of a toe is" Of the property, me Procoooe shed he applied to the sump secured by true 50twity
Inmunmm, whether or nor the due, with my ever paid ro Bccoww. In the ever of a proud nklnl of the Itraperry
in which the Wr market value of the property immediately beibm the eaerhg Is equid to or Steam then the amount
of the mars ,cured by this Security humorous imtrdiudy belie Ilea taking, unlns BUrwwr and Lander otherwise
egret in wfieul, the am= secured by tilt Security Innntmnt sualt be reduced by me Amount of tar proceeds
multiplied by the following Apr eqw: (N the retest Want of the some noticed kmosdiaufy befoe dtw uklal, dlvtded
by (b) me half market value of me Property Imadtahely before the haWnal. Any halt= del be paid to Borrower.
m the Man of a pvnat Wdny Of the PrOMY to which the mlr MOW vdno of rho Property hicaediady before the
tshtmg is Use than W amrum of tb nod actuled Immediately bane the Whnl, Unless Burrower sal Ieadr
otherwise *am In writing m aslrs apPhicenie mw omerwin paavides, rs praande shell be applied to to elute
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85/39/0Z 18:35:35 -> 215 %3 5534 Page 885
• , wwred by this security rnanmat whether in mr the gate we then due.
Jf the Property It abatd=W bry Ibrrower, or If, ads mice by tender to Bortowr tht the coodrnmr offer
Io mate a read or madle a chum for dmagm. Diagram tails m respond m Leader Within 30 days eRr the dam the
ones u PM Leader u dudaind to collest ab *Ply dm prrama, r its option, older in rag agaidee or repair of
the Property W to des s mot sorted by the 9svGty We==, wittiest cc ant rem doe.
Unless Leader ad Detroiter allWWIU acme in "Ifap. MY IPPHmdm of pa0e06 to prWespd than err emend
or poulbox the dm date of de mambly mymmn related to in paetmphe 1 sod 2 or chedte the sooner of web
payauam.
It. Bonmter Na BdMW; Phdra By It Net It Wady. Excitation of eke time for payment or
ttudiBufion of witentiadlm of Iha wing around by thb Ssrffy latmmt tooled by I-A, to my matesmr in
IOMUL of Borrower " not opraa in rolsa the liability of the crlpnml Borrower or Borrower's accerom In
Interest. leader shall mt b: toquhvd to ono mime In dinga against any gucaaer in interest or aAlse m eased
nine for paynrtlt or Marvin modify rmunpu noon of do ester utw! by ales 3tsuray louumvc by mean of rry
dam ed meets Oy the otipat Brawp or Bgrgwu'a ateattn in [teeter. Any drba by reader in sereidng
raw right or ready Mall are be a wither of or ptaiade the deeteise of my right or tmmwy.
12. Mmm m ad Am" aa.a; Iola ad lawaal Lbbl It Co-dines. Thu tavtanmm ad agnammw or Ilia
Semrity Ivataamt bell hied sad beacfii the eooeesmn and mien al:ador grid lionowdr, aubim ke the paviatow
of paragraph 17. Borrower's agreement add argumr shall be Joint and arced. Any B irrawar who to-slime this
Secarky huhuvkm but dos not awme the Nom: (a) is ca.aipeins this Savrity Imtrutnm only w morfdapa gent
end convey the Ibrrowr's W M In the Properly, tender the tams of ads Secondly haw=: (b) is not personally
ablitand to pay the mss swered by thb Sworhy letmarresr; red (e) apraa rbatr Leader and my ather Borrower may
arise to emend. modify. forbear or mate ay tcamamdml m with regret in die tern of this Sam" wlmmem or
the Nola without that EleM m's omrar.
13. Lean C]arBre. If the lom mom ed by this Sanity fmnnm to athJaG to a law which lets maamam lean
charges, ad that taw Is finally interpreted w tint the intnga or other loon otooli a mllmted or to he oale:nd W
connection with the Lou monad the perm, . looks. ties! (a) my mall loan rthateet shall be reduud by thu mount
Nursery to orepee the obnpe to the petmined Heart;, ad (b) my sea already mllamed gram Bomtwer which
emomebad teem reel 1Wite aim be mended to Bmrawr. Ieaae my dinner to teeke this nNed by redeems tile
pradpal owed ands the Noe or bymekldp a Ow payment to Borrower, as resbdd re ttom prlnvoll. the reduction
will be eared a a partial prepayment withat my prepayment ehrpe wader file are.
14. Nodtaa Any notice to Borrower provided tr W etas Sradty Inrmmmnt shell be siea by dNlve ft It or
by l gaieg it by first clad muff voles applicable Sew myrdrs uae of mother oedood. 7be mike ehall he dlrmmrd to
the Property Addmm or my oar addiess ibrmwcr daliom by tmthx to Leader. Any mti c to Ica cr AWI be
plea by iltft Gw mall m Loader's addnm Arad races gr wy ether oddmis t -, dstonewa by mtbo: r Brnmwer.
Any Mace pervaded for in the Savory huubmmt abW be domed to blue here Oven to Horraatr or Leader wbe t
Arm a provi0q in the pffe re".
15. Goamabg LaR Seemab ft Title SawrhY fanneem that be ravened by detail law ad the law of the
Jarediction in which the lhmpeny b Ioesmd. In dot evert iBa my provision or class of We %am" [ttartmat or
eta New =film while epplig" law, mach anll(a abW as e feet ease pgavaWa of tar Seanrt y inetumae in the
Note which ca be given effect wldoa the adfliting provision. To ibis tin the pavidom of iba Security Inetawor
ad the Nos me dalrad to be severable.
Id. Banter's C1opy. )brrowr stall be given ere codfmrmtd copy of the Nos mod of this Sauriry lnatrtment.
17. Remta at dot [aperty or a BeegW Interest be Betmwv. If m or my part of the Property, r any
ldmaMt in it is told or tratlkrtl (or If a bedeACd hamm W Bortnasr is mid or commented and Borrows re not
a moral permit) without Lmdoes prior written comers, Gear may, at ion option, rafting k®edba Poysem in ell
of al alum scared by eta Sruray latamaT. However, the option tot etch be marched by Lehr if aeraise is
Pra6ibl1od by lard law as of the saw of 04 Smority
W,reumme.
N [seder guides this tepsaa. Lander abet give BOra W Mdm Of BMW=tioa. The notice abtl provide a
period of not Ieaa data 39 days notm die doe dot dodo la mimes r =am when which Bmraw4L meet pay all
tame "WO by the SWMIY WNa1at. If Bonowr (side be pay these amt lift to the e>ayhraa of this pried,
Leader may invoke ay m udia Pumitrd by skit Sanely Warnings Without halo mice or domed on Bon iva.
Ill- Bommweeh Bight to B®mes. N Breewer tomb certain conditions. Botrowst shat have flit right to have
cnfb= mt of Iha ScOdity la m=ct d[somitheiod at tidy that prior in the eedicr of. (a) S days (or rah aria
period u appli ahl. IM may specify dot relnaratmwvm before ale of the Pmperry prnoat in ray power of es1e
co0sinod in this So:urhy Lnerumml: or (b) guy Ufa judgment erorcWg thin Sectedry lostralout. These conditions
an that Borrower: (a) pays Leader all was which that would be due order dda Security Watrutmr and the Not,
a irou gowhmnion had umwnal: (h) cots my dagnll or my other mrwlmeu or a{[wnwalg: (e) pay, all repass
Wtvnwl in whomal tan Swuny hhmutdah, bgaWing. but mi IiatW to, mntnsbte utamcye' neca; and (d) akw
card mtim a Leader may readably regeme to aare mite the lam of the Seemity, ieeawutmm. ledder'c aplen in the
Property ad Bgergwst'e oaigrion To pay the mere awirce by This Somty hravmtm rnell ogaWdc achenged.
UP011mwa®ar by Brawe, this Seamy Initiation ad the oblipatiem am" hereby shall remain fatly
effecrn u b'ng smelarui m Ind marred. Hamer, thb right to ni mme dull mt apply in the cue of eroelesa®
udder preprpla 17.
19. Sale of Nam; Ckagd of Lila Srvlar. The Note or s partial hoarsen in the Note (logadn with this
Sa vrity lnnxommt) may be gold os or more tits whhmt prior mike in Borrower. A sale may meat in a change
in the =try (known m the 'Loa Servmrr') that 0011803 monthly pla'rlmbm dm under eta Note add the 5ecumty
Irotnuraad. Then elm any he one w tan cbmi ea al the loan Serviar -"dared to • esk of dto Now if rirere
ig a chance of the lust Servoer. Borrower will be Otto wrl:icn notice of the chagr in accordance with pnmpmph
It slave and apptaeble law. The rodeo will two the raw and eddrng of (be new. Loan Sevier and the address
(a which paymerm should be made, flit: n0ia will aim mmain any other infomteam mptired by applicable law,
nuolmYAm - male Poly - Pars alwP ado tees td NUM 1NSflUrhrrf fame 3099090 (pest a of 3)
ettoA2t5r PUE M
05/36/0Z 18:36:13 -> Z15 563 5534 Page 006
• 1711. Hmtdato Subeauese. Borrower Abell not owe or permit the proem. alp, diapoul, Worage, a Mleaae
of any Haapou S zed= OR or in the Property. Blenswer shall rot do, cur allow Anyunc else to do. Anything
aBating the a4oMy One Is in violation of any Eavirmemem al I.M. lU prlsediag two smtsncm hall not apply to
0v pnwu. we, or awage on the property of stall quanthics of Hazardous Substances that are gomndly rrcopnind
to be Appropriate Wt wMAL faefflolsl coq and to mdmatwrce of the Property
Borrower shall promp" yivc Lamle mince haler of any mveatigafon, claim, demand, lowautt of ether aelian
by any govemmeetd or regolatory agency or private pally Involving the Property, and any Hazardous Suhaunot ar
Sovironmemal law of which Harrower has aatwl Imowpdge, H Boemwm Icons m is dotifled by any Rovemmcuial
or regulatory uuhorhy, that any removal or gabs r reendWhas of any Hamduus Soltnmse atfaNng the patiently is
cauwuy. Borrowe shall prars" nee all manvan rend al actions In AuNdImee with Srviromowal law.
As uasd In ilia plege&& 201 'Harardme Smommom' we those Ribmames dpBnrA u toxic or hamdom
wbalmN" by FFavUonswmO Law And this Wow ins •..•... : g.mli m kmwep • other flammable or to is
peodtma products, Walt patchier and berbUldm, volatile aolvcnd, IVUUWS ratutning Ubcmm or fotmalduhyde.
and radmearive RlateNaU. Am used in Ibis paragraph 20, "Environuumal Law" spew federal Imra and laws of thr
Jurisdiction. where the Property Is locetod Whin elan in bcdth. me" or eevlmonaRW protection.
NON-UNBaORM COVENAN71. lanower And Iadn funbee covenant and agree as Rlllews:
21. AMtkadm, BemtAes. LAda shall give ootkx to Borrower prior to ac darglon fnlldwhtg Borrower's
b? of my coven.nt w Agreement In dela Simadly hsnnonme (bed not prier to epcckratlan under paragraph 17 AMic" law
the nation roquirodm ? vie ? :: (a1 w debah mum be v cdi of, Among other m (d) that Gi? to (a) Ike 4161111111; (b)
the ddawt in
IpRifid my, rmb to Acoalermlen of the slosh mwd by thh Security Imtruvamt, foreclosure byjudkid proccWhag
and we of dw Pmpmy, under shag fatmet Most Dmj war of the right to mhhaten RBcr acalerarion and the right
to wort in the lbraelosera proeedmg det am xialonw: of a dcfwn m my Orlin dekme of lorrowm to mmkrnim
and fmsrdasum. If the tin%% Is not cued an specified, lands at its option may reVim loweliau payment In fell
of all some aelarre- by this Se mfly lmdrunenl whim forth- denand and may limmic Aa dhy Security hle¢mrom by
Judicial proceeding. Laxkr shall be entitled to slier all meptaau incurred in punmg the tomedlo provided in this
paragraph 21. mduding, bm not limited to, worms' fm and cons see Ado evldseee to the stmt pon amel by
Applicable law.
22. Release, Upon peymcnt of All Amu secured by thte Socusq' fwuumam, ttla Security, brmvmmt and the
was, eonveyd shall Wmmimm mid become void. After Rich eecnamce. LmWw shall dlmluepe And oxcefy this
Security Instrument without chu p to Somywer. Bormww shall pry ou ncordatlon tale.
23. Wdvam Bp"mAa. ld the exten patmuld by Applicable Irv, waivw and rvluawn arty ear or dcfm in
pmcBd rap to Imf sir this Security hen umasn. and hereby watvm 09 bandit of my prcarnt or flnnre Ueda providing
for atay of execution. owe eioR of time. ex"time in= attmhmant. levy ad role, and hnmamd eaamptim.
21, RdaatR®t FWW. Borrower's time to mimme provided in paragraph I1 shall exre d to one hour prim
to the mmmenermani of bidding at a MatIMs sic m other ulc putsemn to thin Swerhy insu m em,
25. Rstoh rte Mmq MWyap. If my of the debt seemed by olds UlMly histru rieu is 1st to Borrower to
Acquire title to the property, this Security lm usuct shall bu a pumhaer money mongge.
26. h swat Rau Aim )a *=. Bd"awcr ugreen that the mimnse rata pgrabie after a judRmmn is aNVred nn
the Noe or in m Action of manggr forgchnum shall be the rue payeble from time m time under the Note.
27. Rldea to Able Sleazily blmeM If one or mere rider; ale asect by Burwwm and recorded togesber
v4tb du
emend S ry lnsnumeh, the evvinmts and egremxne of cut such rider ,ball be moorpwAed into and shalAnd e mend dm umnmts and agreements d this Sauthy Imuum u. n if the rider(t) were a pan of this
Security Inetrument.
(Check applirahle box(er))
? "JUMtb Rost Ritlrr
? Qndwal Pay=., Ruler
? RAIIND Rider
? QmaR) IMM1101
? Cmdemmium Hitler
? Flamed L'dt Dmbplmu Ri
? Rob Impmvenwnl Rider
? li Family Rider
? ht-e Wy Payawol Rider
? ermad I10 M Rider
PRNrmvLVANA . Shute PAnd y - Nis atuMseft IW wmvmN aerrmtaM,
Penn ran one Gyr S.( dl
1EDh1522fur aft
95/3B/9Z 19:36:41 -> 215 563 5534
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BY SIGNING BELOW, Borrower rccLpte no eQeM to the Nato Ned NNTaM, uomxmnd In Ma 1 U n Sih
6 of this Smu" tnarmmmt and In Nzil, ridee(s) eaeunod by Borrower and remNed with it.
Wltnrn: WitaNe:
r
LARRY E. iPER JR. ("e -BMW (sea[)
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_(Sad) (see)
• earn »> - BMW
%-I (Sad)
tottorr . Amour
COMMONWBALTH OF' PBNNSYLYANIA, Cu,yh, trer ?Ra? Cmmy NN:
On this. the 26{-4% deyof r'.(rrw,w ry t 1441
Staff the emteetiOted oaleer,penmel{y W OM LARRY 8. JUMPER in.
Prorea) W be the
no dmowmAed tbA k'C kwwd to me (or eejj,,&,to
tuboubW
ln the within matvme?it Vftn
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executed Ike su
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Gulminmi,
IN WITNESS WHEREOF. I bum= rct my trend ad official aC
My CAm wagim "Pim:
Llr-'-?YYt a?.
WC??nidWeh Ap.N ,
?'(•e.r?Pal(re
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19'NMVAXIA ..Sim* Yuib - pe.W bfi gr, ur Nrr tna p ai tnettttnxrrrr
"°"n ev)p AVeleye d or a)
IOOK1522mi r962
Page 997
sit ALL the following described real estate lying and being
uates in Shippensburg Township, Cumberland county, Pennsylvania,
more particularly described as ,follow,.
BEGINNING at a point on the eastern edge of Longview
Drive at common corner of Lot 3-C and Lot 5-C as shown on
subdivision plan for G 4 C Associates dated June 28,
1988; thence along Lot 3-C, North 47 d
seconds East 125.02 feet to an egrees 7 minutes 92
existing iron pin; thence
along lands now or formerly of a a, c Associates South 42
degrees 52 minutes 18 seconds East 89.91 feet to an
existing iron pin; thence along lands now or formerly of
Arthur Eick, South 38 degrees 34 minutes 39 seconds West
126.42 feet to an existing s iron pin on the eastern edge
of Longview Drive;
Longview Drive, south along the eastern edge of
East 108.71 feet to 42 degrees 52 minutes seconds
Longview Drive, a point the eastern n edge of
consisting of 22,415espoint and d place of beginning,
quare feet, more or lass.
BEING all of Lot 3-C on subdivision plan for G 6. c
58, Page x123®eorded in Cumberland County, Pa., plan Hook
PREMISES ON: 102 LONGVIEW DRIVE
VERIFICATION
JERRY WAUGH hereby states that she is ASSISTANT SECRETARY 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 unswom
falsification to authorities.
s
DATE: 101 I (y y MP_
JERRY LEE WAUGH, ASST. SECRETAR
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SHERIFF'S RETURN - REGULAR
CASE NO: 2002-03105 P
COMMONWEALTH OF PENNSYLVANIA:
COUNTY OF CUMBERLAND
WELLS FARGO HOME MORTGAGE INC
VS
JUMPER LARRY E JR
RONALD HOOVER , Sheriff or Deputy Sheriff of
Cumberland County,Pennsylvania, who being duly sworn according to law,
says, the within COMPLAINT - MORT FORE
was served upon
JUMPER LARRY E JR the
DEFENDANT
at 1615:00 HOURS, on the 9th day of July , 2002
at 102 LONGVIEW DRIVE
SHIPPENSBURG, PA 17257 by handing to
JEAN RICHARDSON, FRIEND
a true and attested copy of COMPLAINT - MORT FORE together with
and at the same time directing Her attention to the contents thereof.
Sheriff's Costs:
Docketing 18.00
Service 13.80
Affidavit .00
Surcharge 10.00
.00
41.80
Sworn and Subscribed to before
me this day of
-?, A. D.
rothonotary
So Answers:
R. Thomas Kline
07/10/2002
FEDERMAN & PHELAN
By: Deputy Sheriff
FEDERMAN AND PHELAN, LLP
By: FRANK FEDERMAN
Identification No. 12248
Attorney for Plaintiff
ONE PENN CENTER AT SUBURBAN STATION
1617 JOHN F. KENNEDY BLVD., SUITE 1400
PHILADELPHIA, PA 19103-1814
(215) 563-7000
WELLS FARGO HOME MORTGAGE, INC. F/K/A
NORWEST MORTGAGE, INC. CUMBERLAND COUNTY
5024 PARKWAY PLAZA BOULEVARD COURT OF COMMON PLEAS
CHARLOTTE, NC 28217-2407
CIVIL DIVISION
Plaintiff,
V. NO. 02-3105 CIVIL
LARRY E. JUMPER, JR.
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 LARRY E. JUMPER, JR.,
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 $86,075.98
Interest from 6/2/02 to 8/12/02 $ 1,164.96
TOTAL $87,240.94
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.
RANK FE ERMAN, ESQUIRE
Attorney for Plaintiff
DAMAGES ARE HEREBY ASSESSED AS INDICATED.
DATE: V-1 d' -(j ? ( U
PRO PROTHY
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. CUMBERLAND COUNTY
5024 PARKWAY PLAZA BOULEVARD COURT OF COMMON PLEAS
CIVIL DIVISION
V.
Plaintiff,
NO. 02-3105 CIVIL
LARRY E. JUMPER, JR.
Defendant(s).
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 LARRY E. JUMPER, JR. is over 18 years of age and resides at,
102 LONGVIEW DRIVE, SHIPPENSBURG, PA 17257.
This statement is made subject to the penalties of 18 Pa. C.S. Section 4904 relating to
unworn falsification to authorities.
FRANK FE ERMAN, ESQUIRE
Attorney for Plaintiff
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FEDERMAN AND PHELAN
BY: FRANK FEDERMAN, ESQUIRE
Identification No. 12248
1617 John F. Kennedy Boulevard Suite 1400
Philadelphia, PA 19103-1814
(?15) 563-7000
WELLS FARGO HOME MORTGAGE,
INC. F/K/A NORWEST MORTGAGE,
INC.
Plaintiff
vs.
LARRY E. JUMPER, JR.
Defendant(s)
TO: LARRY E. JUMPER, JR.
102 LONGVIEW DRIVE
SHIPPENSBURG, PA 17257
DATE OF NOTICE: JULY 30. 2002
i?
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
Attorney for Plaintiff
: COURT OF COMMON PLEAS
: CIVIL DIVISION
: CUMBERLAND COUNTY
NO. 02-3105 CIVIL
rank Feder an, Esquire
Attorney for Plaintiff
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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. 02-3105 CIVIL
LARRY E. JUMPER, JR.
Defendant(s).
TO THE DIRECTOR OF THE OFFICE OF THE PROTHONOTARY:
Issue writ of execution in the above matter:
Amount Due $87,240.94
Interest from 8/13/02 to 12/04/02 $ 1,634.76 and Costs
(per diem -$14.34)
TOTAL $88,875.70
FRANK FEIDERMAN, 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.
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ALL THE FOLLOWING described real estate lying and being situate in Shippensburg Township,
Cumberland County, Pennsylvania, more particularly described as follows:
BEGINNING at a point on the eastern edge of Longview Drive at common corner of Lot 3-C and Lot
5-C as shown on subdivision plan for G & C Associates dated June 28, 1988; thence along Lot 3-C,
North 47 degrees 7 minutes 42 seconds East 125.02 feet to an existing iron pin; thence along lands now
or formerly of G & C Associates South 42 degrees 52 minutes 18 seconds East 89.91 feet to an existing
iron pin; thence along lands now or formerly of Arthur Eick, South 38 degrees 34 minutes 39 seconds
West 126.42 feet to an existing iron pin on the eastern edge of Longview Drive; thence along the
eastern edge of Longview Drive, South 42 degrees 52 minutes 18 seconds East 108.71 feet to a point
on the eastern edge of Longview Drive, the point and place of beginning, consisting of 12,415 square
feet, more or less.
BEING all of Lot 3-C on subdivision plan for G & C Associates recorded in Cumberland County, PA,
Plan Book 58, Page 123.
BEING Tax Map #35-2385 and Parcel #111.
TITLE TO SAID PREMISES IS VESTED IN Larry E. Jumper, Jr. by Deed from Orrstown Bank
dated 2/26/1999 and recorded 2/26/1999 in Record Book 194 Page 1066.
Premises: 102 LONGVIEW DRIVE, SHIPPENSBURG, PA, 17257
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WELLS FARGO HOME MORTGAGE, INC. F/K/A :
NORWEST MORTGAGE, INC. CUMBERLAND COUNTY
Plaintiff, COURT OF COMMON PLEAS
V.
LARRY E. JUMPER, JR.
Defendant(s).
CIVIL DIVISION
NO. 02-3105 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,102 LONGVIEW DRIVE, SHIPPENSBURG, PA 17257.
1. Name and address of Owner(s) or reputed Owner(s):
Name
Last Known Address (if address cannot be
reasonably ascertained, please indicate)
LARRY E. JUMPER, JR. 102 LONGVIEW DRIVE
SHIPPENSBURG, 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)
CITIFINANCIAL, INC. 244 S. FAYETTE STREET
SHIPPENSBURG, PA 17257
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)
TERESA D. JUMPER 102 LONGVIEW DRIVE
SHIPPENSBURG, PA 17257
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
102 LONGVIEW DRIVE
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.
July 31, 2002
DATE FRANK FE ERMAN, ESQUIRE
Attorney for Plaintiff
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WELLS FARGO HOME MORTGAGE, INC. F/K/A CUMBERLAND COUNTY
NORWEST MORTGAGE, INC.
Plaintiff, No. 02-3105 CIVIL
V.
LARRY E. JUMPER, JR.
Defendant(s).
AUGUST 12, 2002
TO: LARRY E. JUMPER, JR.
102 LONGVIEW DRIVE
SHIPPENSBURG, 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
AN ATTEMPT TO COLLECT A DEBT, BUT ONLY ENFORCEMENT OF A LIEN AGAINST PROPERTY s+
Your house (real estate) at, 102 LONGVIEW DRIVE SHIPPENSBURG PA 17257, is
scheduled to be sold at the Sheriffs Sale on 12/04/02 at 10:00 a.m. in the Cumberland County
Courthouse, South Hanover Street, Carlisle, PA 17013, to enforce the court judgment of $87,240.94
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: (2151563-7000.
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
DESCRIPTION
ALL THE FOLLOWING described real estate lying and being situate in Shippensburg Township,
Cumberland County, Pennsylvania, more particularly described as follows:
BEGINNING at a point on the eastern edge of Longview Drive at common comer of Lot 3-C and Lot
5-C as shown on subdivision plan for G & C Associates dated June 28, 1988; thence along Lot 3-C,
North 47 degrees 7 minutes 42 seconds East 125.02 feet to an existing iron pin; thence along lands now
or formerly of G & C Associates South 42 degrees 52 minutes 18 seconds East 89.91 feet to an existing
iron pin; thence along lands now or formerly of Arthur Eick, South 38 degrees 34 minutes 39 seconds
West 126.42 feet to an existing iron pin on the eastern edge of Longview Drive; thence along the
eastern edge of Longview Drive, South 42 degrees 52 minutes 18 seconds East 108.71 feet to a point
on the eastern edge of Longview Drive, the point and place of beginning, consisting of 12,415 square
feet, more or less.
BEING all of Lot 3-C on subdivision plan for G & C Associates recorded in Cumberland County, PA,
Plan Book 58, Page 123.
BEING Tax Map #35-2385 and Parcel #111.
TITLE TO SAID PREMISES IS VESTED IN Larry E. Jumper, Jr. by Deed from Orrstown Bank
dated 2/26/1999 and recorded 2/26/1999 in Record Book 194 Page 1066.
Premises: 102 LONGVIEW DRIVE, SHIPPENSBURG, PA, 17257
DESCRIPTION
ALL THE FOLLOWING described real-estate lying and being situate in Shippensburg Township,
Cumberland County, Pennsylvania, more particularly described as follows:
BEGINNING at a point on the eastern edge of Longview Drive at common comer of Lot 3-C and Lot
5-C as shown on subdivision plan for G & C Associates dated June 28, 1988; thence along Lot 3-C,
North 47 degrees 7 minutes 42 seconds East 125.02 feet to an existing iron pin; thence along lands now
or formerly of G & C Associates South 42 degrees 52 minutes 18 seconds East 89.91 feet to an existing
iron pin; thence along lands now or formerly of Arthur Eick. South 38 degrees 34 minutes 39 seconds
West 126.42 feet to an existing iron pin on the eastern edge of Longview Drive; thence along the
eastern edge of Longview Drive, South 42 degrees 52 minutes 18 seconds East 108.71 feet to a point
on the eastern edge of Longview Drive, the point and place of beginning, consisting of 12,415 square
feet, more or less.
BEING all of Lot 3-C on subdivision plan for G & C Associates recorded in Cumberland County, PA,
Plan Book 58, Page 123.
BEING Tax Map #35-2385 and Parcel #111.
TITLE TO SAID PREMISES IS VESTED IN Larry E. Jumper, Jr. by Deed from Orrstown Bank
dated 2/26/1999 and recorded 2/26/1999 in Record Book 194 Page 1066.
Premises: 102 LONGVIEW DRIVE, SHIPPENSBURG, PA, 17257
TAY
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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
ATTORNEY FOR PLAINTIFF
WELLS FARGO HOME MORTGAGE, INC. F/K/A
NORWEST MORTGAGE, INC.
V.
Plaintiff,
LARRY E. JUMPER, JR.
Defendant(s).
CUMBERLAND COUNTY
COURT OF COMMON PLEAS
CIVIL DIVISION
NO. 02-3105 CIVIL
CERTIFICATION
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:
O 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 unworn
falsification to authorities.
FRANK F DERMAN, ESQUIRE
Attorney for Plaintiff
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IN THE COURT OF COMMON PLEAS OF CUMBERLAND COUNTY,
PENNSYLVANIA
RE: WELLS FARGO HOME MORTGAGE,
INC. F/WA NORWEST MORTGAGE, INC. ) CIVIL ACTION
vs.
LARRY E. JUMPER, JR. ) CIVIL DIVISION
NO. 02-3105-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/WA NORWEST MORTGAGE, INC. hereby verify that on
8/12/02 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
8/12/02 by certified mail return receipt requested see Exhibit "B" attached hereto.
DATE: November 4 2002 FRANKK F?EEDDERRMAW -
Attorney for Plaintiff
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7160 3901 9844 9260 4940
TO: LARRY E. JUMPER, JR.
102 LONGVIEW DRIVE
SHIPPENSBURG, PA 17257
SENDER:
KMD-SALES
REFERENCE: # 7558448
l
PS Form 3800 June 2000
RETURN Postage
j RECEIPT Certified Fee
SERVICE 21
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Restricted Delivery
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Total Postage & Fees
.94
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COMMONWEALTH OF PENNSYLVANIA
COUNTY OF CUMBERLAND I SS:
I, Robert P. Ziegler, Recorder of Deeds in and for said County and State dhereby certify that
the Sheriff's Deed in which Federal Home LoanMtg Coro is the grantee the sane having been sold to
said grantee on the 5th day of March A.D., 2003, under and by virtue of a writ ecution issued on the
12th day of Au ust, A.D., 2002, out of the Court of Common Pleas of said Coin y as of Civil Term,
2002 Number 3105, at the suit of Wells Fargo Home Mtg Inc fka Norwest Mtjzc against Larry E
Jumper Jr is duly recorded in Sheriff's Deed Book No. 256, Page 949.
IN TESTIMONY WHEREOF, I have hereunto set my hand
and seal of said office this A day of
A.D. 2003
Recorder of Deeds
Wells Fargo Home Mortgage, Inc. In The Court of Common
f/k/a Norwest Mortgage, Inc. Cumberland County, Pem
VS Writ No. 2002-3105 Civil
Larry E. Jumper, Jr.
Jason Vioral, Deputy Sheriff, who being duly sworn according tc
on September 04, 2002 at 7:36 o'clock PM, he served a true copy of the
Estate Writ, Notice and Description, in the above entitled action, upon tr
defendant, to wit: Larry Jumper, Jr., by making known unto Larry Juml
Longview Drive, Shippensburg, Cumberland County, Pennsylvania, its c
the same time handing to him personally the said true and correct copy o
Dawn Kell, Deputy Sheriff, who being duly sworn according to L
October 3, 2002 at 10:57 o'clock A.M., she posted a true copy of the wit:
Writ, Notice, Poster and Description, in the above entitled action, upon tl
Larry E. Jumper, Jr. located at 102 Longview Drive, Shippensburg, PA a
R. Thomas Kline, Sheriff, who being duly sworn according to lave
the above Real Estate Writ, Notice, Poster and Description in the followil
Sheriff mailed a notice of the pendency of the action to one of the within
defendants to wit: Larry E. Jumper, Jr., by regular mail to his last known
Longview Drive, Shippensburg, PA 17257. This letter was mailed under
October 1, 2002 and never returned to the Sheriff's Office.
R. Thomas Kline, Sheriff, who being duly sworn according to law
after due and legal notice had been given according to law, he exposed th
described premises at public venue or outcry at the Courthouse, Carlisle,
County, Pennsylvania on March 5, 2003 at 10:00 o'clock A.M. He sold tl
sum of $1.00 to Attorney Frank Federman for Federal Home Loan Mort&
Corporation. It being the highest bid and best price received for the same
Loan Mortgage Corporation of Foreclosure Unit, Mail Stop 61, P.O. Box
VA 22183-5000, being the buyer in this execution, paid to Sheriff R. Thoi
sum of $801.17, it being costs.
Sheriffs Costs:
Docketing $30.00
Poundage 15.71
Posting Bills 15.00
Advertising 15.00
Acknowledging Deed 30.00
Auctioneer 10.00
Law Library .50
Prothonotary 1.00
Mileage 27.60
Certified Mail 5.11
Levy 15.00
Surcharge 20.00
eas of
ylvania
erm
law, states that
vithin Real
within named
er Jr., at 102
>ntents and at
the same.
w, states that on
in Real Estate
e property of
cording to law.
says he served
g manner: The
address of 102
the date of
states that
within
umberland
- same for the
Federal Home
000, Vienna,
tas Kline the
Postpone Sale 20.00
Law Journal 284.00
Patriot News 222.55
Share of Bills 25.20
Distribution of Proceeds 25.00
Sheriffs Deed 39.50
$801.17
Sworn and subscribed to before me So Ans?rs:
%/y?'?"r'?C -?
This daY of
2003, A.D R. Thomas Kline, Sheriff
A.D.
ro onotary By OW I
Real Estate Deputy
3u. `"D
Cjz_ d/3
lac.. J3G S3S?
WELLS FARGO HOME MORTGAGE, INC. F/K/A
NORWEST MORTGAGE, INC.
Plaintiff,
V.
LARRY E. JUMPER, JR.
Defendant(s).
CUMBERLAND COUNTY
COURT OF COMMON PLEAS
CIVIL DIVISION
NO. 02-3105
AFFIDAVIT PURSUANT TO RULE 3129
(Affidavit No. l)
FARGO HOME MORTG.
the above action, by its attorney, FRANK FEDERMAN, ESQUIRE, sets
Praecipe for the Writ of Execution was filed the following information cc
located at,102 LONGVIEW DRIVE, SHIPPENSBURG, PA 17257.
1. Name and address of Owner(s) or reputed Owner(s):
Name
Last Known Address (if
reasonably ascertained, l
LARRY E. JUMPER, JR.
102 LONGVIEW DRIVE
SHIPPENSBURG, PA 17
2. Name and address of Defendant(s) in the judgment:
Same as above
3. Name and last known address of every judgment creditor whose
property to be sold:
Name Last Known Address (if
reasonably ascertained,1
None
4J1 .':.
_ _-Ils
CGAGE, INC., Plaintiff in
h as of the date the
rning the real property
;s cannot be
indicate)
is a record lien on the real
;s cannot be
indicate)
WELLS FARGO HOME MORTGAGE, INC. F/K/A CUMBERLAND COUNTY
NORWEST MORTGAGE, INC.
V.
Plaintiff,
LARRY E. JUMPER, JR.
Defendant(s).
No. 02-3105 CIVIL
AUGUST 12, 2
TO: LARRY E. JUMPER, JR.
102 LONGVIEW DRIVE
SHIPPENSBURG, PA 17257
* *THIS FIRM IS A DEBT COLLECTOR ATTEMPTING TO COLLECT A DEBT AN ANY INFORMATION
OBTAINED WILL BE USED FOR THATPURPOSE. IF YOUHAVEPREVIOUSLYRECEIV DA DISCHARGE IN
BANKRUPTCYAND THIS DEBT WAS NOT REAFFIRMED, THIS IS NOT AND SHOULD N T BE CONSTRUED TO BE
ANA TTEMPT TO COLLECTA DEBT, BUT ONLYENFORCEMENT OFA LIENAGAINST ROPF.RTY **
Your house (real estate) at, 102 LONGVIEW DRIVE, SHIPPENSB
scheduled to be sold at the Sheriffs Sale on 12/04/02 at 10:00 a.m. in the Cum
Courthouse, South Hanover Street, Carlisle, PA 17013, to enforce the court juc
obtained by WELLS FARGO HOME MQRTr-A V-F nvr L111VI A 7?Tl'k1Mx-
v 1' / 17
(the mortgagee) against you. In the event the sale is continued, an
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
costs and reasonable attorney's fees due. To find out how much
call: (215) 563-7000.
PA 17257, is
I County
of $87,240.94
will be made at said
cents, late charges,
must pay, you may
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 o e, the more chance
you will have of stopping the sale. (See notice on page two on how to obtain an a tornev_)
YOU MAY STILL BE ABLE TO SAVE YOUR PROPERTY AND
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 ighest 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 rice 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
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
property as if the sale never happened.
5. You have the right to remain in the property until the full amount
and the Sheriff gives a deed to the buyer. At that time, the buyer may bring
you.
6. You may be entitled to a share of the money which was paid for yot
distribution of the money bid for your house will be filed by the Sheriff within
schedule will state who will be receiving that money. The money will be paid
this schedule unless exceptions (reasons why the proposed distribution is wron
Sheriff within ten (10) days after the distribution is filed.
due in the sale. To
the owner of the
is paid to the Sheriff
I proceedings to evict
house. A schedule of
0 days of the sale. This
it in accordance with
are filed with the
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 TH OFFICE LISTED
BELOW TO FIND OUT WHERE YOU CAN GET LEGAL HELP.
CUMBERLAND COUNTY ATTORNEY REFERR?
CUMBERLAND COUNTY BAR ASSOCIATION
2 LIBERTY AVENUE
CUMBERLAND COUNTY COURTHOUSE
CARLISLE, PA 17013
(717) 249-3166
(800) 990-9108
:? DESCRIPTION
ALL-THE FOLLOWING described .real -estate-lying and :being situate-in: Shippensburg Township,
Cumberland County, Pennsylvania, more particularly described as follows:
BEGINNING at a point on the eastern edge of Longview Drive at common corner of Lot 3-C and Lot
5-C as shown on subdivision plan for G & C Associates dated June 28, 1988;1 thence along Lot 3-C,
North 47 degrees 7 minutes 42 seconds East 125.02 feet to an existing iron pin; thence along lands now
or formerly of G & C Associates South 42 degrees 52 minutes 18 seconds East 9.91 feet to an existing
iron pin; thence along lands now or formerly of Arthur Eick, South 38 degrees 34 minutes 39 seconds
West 126.42 feet to an existing iron pin on the eastern edge of Longview rive; thence along the -
eastern edge of Longview Drive, South 42 degrees 52 minutes 18 seconds Eas 108.71 feet to a point
on the eastern edge of Longview Drive, the point and place of beginning, cons sting of 12,415 square
feet, more or less.
BEING all of Lot 3-C on subdivision plan for G & C Associates recorded in Cumberland County, PA,
Plan Book 58, Page 123.
BEING Tax Map #35-2385 and Parcel #111.
TITLE TO SAID PREMISES IS VESTED IN Larry E. Jumper, Jr. by Deed Irom Orrstown Bank
dated 2/26/1999 and recorded 2/26/1999 in Record Book 194 Page 1066.
Premises: 102 LONGVIEW DRIVE, SHIPPENSgUgG, PA, 17257
DESCRIPTION
ALL 'THE FOLLOWING described real estate lying and being situate in Shippensburg Township,
Cumberland County, Pennsylvania, more. particularly described as follows:
BEGINNING at. a point on the eastern edge of Longview Drive at common corner of Lot 3-C and Lot
5-C as shown on subdivision plan for G & C Associates dated June 28, 1988; thence along Lot 3-C,
North 47 degrees 7 minutes 42 seconds East 125.02 feet to an existing iron pin; ence along lands now
or formerly of G & C Associates South 42 degrees 52 minutes 18 seconds East 89.91 feet to an existing
iron pin; thence along lands now or formerly of Arthur Eick, South 38 degrees 34 minutes 39 seconds
West 126.42 feet to an existing iron pin on the eastem edge of Longview Drive; thence along the
eastem edge of Longview Drive, South 42 degrees 52 minutes 18 seconds East 108.71 feet to a point
on the eastern edge of Longview Drive, the point and place of beginning, cons sting of 12,415 square
feet, more or less.
BEING all of Lot 3-C on subdivision plan for G & C Associates recorded in Cumberland County, PA,
Plan Book 58, Page 123.
BEING Tax Map #35-2385 and Parcel #111.
TITLE TO SAID PREMISES IS VESTED IN Larry E. Jumper, Jr. by Deed from Orrstown Bank
dated 2/26/1999 and recorded 2/26/1999 in Record Book 194 Page 1066.
Premises: 102 LONGVIEW DRIVE, SHIPPENSBURG, PA, 17257
WRIT OF EXECUTION and/or ATTACHMENT
COMMONWEALTH OF PENNSYLVANIA) NO 02-3105 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
NORWEST MORTGAGE, INC. Plaintiff (s)
From LARRY E. JUMPER, JR., 102 LONGVIEW DR., SHIPPENSBURG PA 7257
(1) You are directed to levy upon the property of the defendant (s)and to sell REAL STATE
LOCATED AT 102 LONGVIEW DR., SHIPPENSBURG PA 17257. (SEE ATTACHED LEGAL
DESCRIPTION.).
(2) You are also directed to attach the property of the defendant(s) not levied upon in a 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 proper 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 ha been added as a
garnishee and is enjoined as above stated.
Amount Due $87,240.94 L.L. $.50
Interest 8/13/02-12/4/02@$14.34/diem $1.634.76
Atty's Comm % Due Prothy $1.00
Atty Paid $113.80
Plaintiff Paid
Other Costs
Date: AUGUST 12, 2002
(Seal)
REQUESTING PARTY:
Name FRANK FEDERM,AN, ESQ.
Address: ONE PENN CENTER @ SUBURGAN STATION
1617 JFK BLVD., SUITE 1400
CURTIS R. LONG
By:
PHILADELPHIA PA 19103-1814
Attorney for: PLAINTIFF
Telephone: (215) 563-7000
Supreme Court ID No. 12248
Deputy
Real Estate Sale # 17
On August 30, 2002 the sheriff levied upon the
defendant's interest in the real property situated in
Shippensburg Township, Cumberland County, PA
known and numbered as 102 Longview Dr., Shippensburg
more fully described on Exhibit "A" filed with this
writ and by this reference incorporated herein.
Date: August 30, 2002 By: j0
Real Estate Deputy
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PROOF OF PUBLICATION OF NOTICE
IN CUMBERLAND LAW JOURNAL
(Under Act No. 587, approved May 16, 1929), P,. L.1784
STATE OF PENNSYLVANIA :
COUNTY OF CUMBERLAND :
ss.
Roger M. Morgenthal, Esquire, Editor of the Cumberland Law Journal, of the County
and State aforesaid, being duly sworn, according to law, deposes and says that the Cumberland
Law Journal, a legal periodical published in the Borough of Carlisle in the County and State
aforesaid, was established January 2, 1952, and designated by the local courts as the official legal
periodical for the publication of all legal notices, and has, since January 2, 1952, been regularly
issued weekly in the said County, and that the printed notice or publication attached hereto is
exactly the same as was printed in the regular editions and issues of the said Cumberland Law
Journal on the following dates,
viz:
OCTOBER 25, NOVEMBER 1, 8, 2002
Affrant 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 riot 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. 17
Writ No. 2002-3105 Civil
Wells Fargo Home Mortgage, Inc.,
f/k/a Norwest Mortgage, Inc.
VS.
Larry E. Jumper, Jr.
Atty.: Frank Federman
DESCRIPTION
ALL THE FOLLOWING described
real estate lying and being situate
in Shippensburg Township, Cum-
berland County, Pennsylvania, more
particularly described as follows:
BEGINNING at a point on the
eastern edge of Longview Drive at
common corner of Lot 3-C and Lot
5-C as shown on subdivision plan
for G & C Associates dated June 28.
1988; thence along Lot 3-C, North
47 degrees 7 minutes 42 seconds
East 125.02 feet to an existing iron
pin: thence along lands now or for-
Rog r M. Morgenthal, Editor
SWORN TO AND SUBSCRIBED before me this
8 day of NOVEMBER, 2002
'Itt
merly of G & C Associates South 42
degrees 52 minutes 18 seconds
East 89.91 feet to an existing iron
pin; thence along lands now or for-
merly of Arthur Eick, South 38 de-
grees 34 minutes 39 seconds West
126.42 feet to an existing iron pin
on the eastern edge of Longview
Drive; thence along the eastern edge
of Longview Drive, South 42 de-
grees 52 minutes 18 seconds East
108.71 feet to a point on the east-
ern edge of Longview Drive, the point
and place of beginning, consisting
of 12,415 square feet, more or less.
BEING all of Lot 3-C on subdivi-
sion plan for G & C Associates re-
corded in Cumberland County, PA,
Plan Book 58, Page 123.
BEING Tax Map #35-2385 and
Parcel #111.
TITLE TO SAID PREMISES IS
VESTED IN Larry E. Jumper, Jr.
by Deed from Orrstown Bank dated
2/26/1999 and recorded 2/26/
1999 in Record Book 194 Page
1066.
Premises: 102 LONGVIEW
DRIVE, SHIPPENSBURG, PA
17257.
1"N
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 me,,thtis114th day oy?ovqrfper 2002 A.D.
SALE #17
REAL ESTATE SALE No. 17
Writ No. 2002-3105
Civil Term
Wells Fargo Home
Mortgage, Inc. f!k/a
Norwest Mortgage, Inc.
vs
Larry E. Jumper, Jr.
Atty: Frank Federman
DESCRIPTION
ALL THE FOLLOWING described real
estate lying and being situate in
Shippensburg Township, Cumberland
County, Pennsylvania, more particularly
described as follows:
BEGINNING at a point on the eastern edge
of Longview Drive at common corner of
Lot 3-C and Lot 5-C as shown on
subdivision plan for G&C Associates dated
June 28 1988 the I L 3
Notarial Seal ,vf
Terry L. Russell, Notary Public
City Of Harrisburg, Dauphin County NOT RY PUBLIC
My Commission Expires June 6, 2006
Member, Pennsylvania Association Of Notaries "y commission expires June 6, 2006
CUMBERLAND COUNTY SHERIFFS OFFICE
CUMBERLAND COUNTY COURTHOUSE
CARLISLE, PA. 17013
Statement of Advertising Costs
To THE PATRIOT-NEWS CO., Dr.
For publishing the notice or publication attached
hereto on the above stated dates $ 220.80
Probating same Notary Fee(s) $ 1.75
Total $ 222.55
nceaong of -c, North 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.
By ....................................................................
47 degrees 7 minutes 42 seconds East
125.02 feet to an existing iron pin; thence
along lands now or formerly of G & C
Associates South 42 degrees 52 minutes 18
seconds East 89.91 feet to an existing iron
pin thence along lands now or formerly of
Arthur Eick, South 38 degrees 34 minutes
39 seconds West 126.42 feet to an existing
iron pin on the eastern edge of Longview
Drive; thence along the eastern edge of
Longview Drive. South 42 degrees 52
minutes 18 seconds East 108.71 feet to a
point on the eastern edge of Longview
Drive, the point and place of beginning,
consisting of 12,415 square feet, more or
less.
BEING all of Lot 3-C on subdi- vision plan
for G & C Associates recorded in
Cumberland County, PA, Plan Book 58,
Page 123.
BEING Tax Map #35-2385 and Parcel
#111.
TITLE TO SAID PREMISES IS VESTED
IN Larry E. Jumper, Jr. by Deed from
Orrstown Bank dated 2/26/1999 and
recorded 2/26/1999 in Record Book 194
Page 1066.
PREMISES: 102 Longview Drive,
Shippensburg,PA 17257.