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Home My WebLink About02-3307 A LAW OFFICES OF PULEO & D'EMILIO, LLC By: Thomas I. Puleo, Esquire Identification No, 27615 660 Sentry Parkway, Suite 210 Blue Bell, PA 19422 (610) 941-3600 Attorney for Plaintiff IN THE COURT OF COMMON PLEAS OF CUMBERLAND COUNTY, PENNSYLVANIA CIVIL ACTION - LAW ATLANTIC MORTGAGE & INVESTMENT CORPORATION, a division of ABN AMRO Mortgage Group, mc, 7159 Corklan Drive Jacksonville, Florida 32258 v, LEROY A. LUTHER and CAROLYN A. GElLING-LUTHER, his wife 830 Doubling Gap Road Newville, PA 17241 : No, D..(- 3$07 GULL 'j-~ CIVIL ACTION - MORTGAGE FORECLOSURE COMPLAINT NOTICE You have been sued in court. If you wish to defend against the claims set forth in the following pages, }(Ill 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 ccourt your defenses or objections to the claims set forth against you. You arewamed 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 TIllS PAPER TO YOUR LAWYER AT ONCE. IF YOU DO NOT HA VB 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 Bar Association 2 Liberty Avenue Carlisle, P A 17013 (717) 249-3166 (800) 990-9108 A VISO Le han demandado a usted en 1a corte. Si usted qui ere defenderse de estas demandas expuestas en las paginas siguientes. usted tiene (20) dias de plazo a partir de la fecha de la demanda y la notificacion. Usted debe presentar una apariencia escrita 0 en persona 0 por abogado y archivar en la corte sus defensas 0 sus objeciones a !as demandas encontra de su persona. Sea avisado que si usted no se defiende, la corte tomara medidas y puede enttar una orden contra usted sin previo aviso 0 ootificacion 0 por cualqier queja 0 alivio que espedido en la peticion de demanda. Usted puede perder dinero. sus propiedades 0 otros derechos importantes para usted. LLEVE ESTA DEMANDA A UN ABOGADO INMEDIA T AMENTE. SI NO TIENE ABOGADO 0 SI NO TIENE EL DINERO SUFICIENTE PARA PAGAR TAL SERVICIO, VA Y A EN PERSONA 0 LLAME POR TELEFONO A LA OFICINA CUY A DIRECCION SE ENCUENTRA ESCRITA ABAJO PARA A VERIGUAR DONDE USTED PUEDE CONSEGUIR ASISTENCIA LEGAL. Cumberland County Bar Association 2 Liberty Avenue Carlisle, PAl 70 13 (717) 249-3166 (800) 990-9108 , CIVIL ACTION - MORTGAGE FORECLOSURE COMPLAINT 1. Plaintiff, ATLANTIC MORTGAGE & INVESTMENT CORPORATION, a division of ABN AMRO Mortgage Group, Inc" is a corporation organized and existing under laws of the State of Delaware with offices at 7159 Corklan Drive, Jacksonville, Florida, 2. Defendants, LEROY A, LUTHER and CAROLYN A, GElLING-LUTHER, his wife, are the mortgagors and real owners of premises 830 Doubling Gap Road, Township of Lower Mifflin, Cumberland County, Pennsylvania, hereinafter described, whose last known address is as stated above, 3, On the 24th day of August, 1999, the above named mortgagors made, executed and delivered a mortgage upon premises hereinafter described to Broadview Mortgage Company, which mortgage is recorded in the Office of the Recorder of Deeds for Cumberland County in Mortgage Book 1567 page 812, 4, The premises subject to the said mortgage is described in Exhibit "A" attached hereto and made a part hereof, 5, The mortgage secures defendants' certain Note dated the same as the mortgage in the amount of $104,448,00 payable in monthly installments with interest at the rate of 8% per annum. A copy ofthe said Note is attached hereto, made a part hereof and marked Exhibit "B", 6, The said mortgage was last assigned to ATLANTIC MORTGAGE & INVESTMENT CORPORATION, a division of ABN AMRO Mortgage Group, Inc" the plaintiff herein, by written assignment which is recorded in the Office of the Recorder of Deeds for Cumberland County in Misc, Book 661 page 1069, 7, The mortgage is in default because the defendants have failed to make the payment of the monthly installment of principal and interest in accordance with the terms of the mortgage for the month -1- of December 2001, and each month thereafter, up to and including the present time, 8, The following amounts are due on the mortgage: Principal Interest at 8% per annum from 11/1/0 I thru 6/30/02 ($22.44 per diem) Late charges accrued thru 6/30/02 ($35.45/month) Escrow deficit (taxes and insurance) ($119,87/month) Attorney's fee (5%) Title information certificate $102,386,08 5,430.48 248,15 839,09 5,119.30 325,00 Total $111,348.10 9, On February 21,2002, plaintiff sent to defendants by certified mail and first class mail Notice of Intention to Foreclose Mortgage in accordance with the provisions of Section 403 of Pennsylvania Act No, 6 of 1974, and Notice of Homeowners' Emergency Mortgage Assistance Program, in accordance with Pennsylvania Act 91 of 1983, a true and correct copy of which is attached hereto, made a part hereof and marked Exhibit "e", Defendants have not had the required face-to-face meeting with the mortgagee within the required time and plaintiff has received no notice that defendants have had a face-to-face meeting with a consumer credit counseling agency, nor has plaintiff received notice that defendants have filed an application with the Homeowners' Emergency Mortgage Assistance Program, WHEREFORE, plaintiff demands judgment in the sum of $111 ,348,10 plus interest, late charges, escrow advances and costs to the date of judgment and foreclosure ofthe said mortgage, IL THOMAS I. ULEO I Attorney for Plaintiff -2- DESCRIPTION ALL THAT CERTAIN tract of land with improvements thereon erected, situate in Lower Mifflin Township, Cumberland County, Pennsylvania, bounded and described in accordance with Plan of Subdivision for Gary E, Bobb, prepared by Larry Vern Neidlinger, Professional Engineer, on October 11, 1977, a drafl of same being recorded in the hereinafter named Recorder's Office in Plan Book 31, page 120, as follows: BEGINNING at a point in the center of the public road leading from Newville to Doubling Gap at the corner of land now or formerly of Viola Armolt, and which point at the place of beginning is 157 feet Northwest from the corner of land now or formerly of Charles Spahr, measured along the center line of said public road; thence from said point at the place of beginning along said line of land now or formerly of Viola.M. Armolt, South 63 degrees 48 minutes West, a distance of 243,56 feet to a point in line of land now or formerly of Milton Walters; thence along said land now or formerly of Milton Walters, North 34 degrees 02 minutes West, a distance of 200.48 feet to an iron pin at the corner of Lot No 3 as shown on said Plan of Subdivision now 'or formerly of Cuisine Management Services, Inc,; thence along the Southern line of said Lot No.1 now or formerly of Cuisine Management Services, Inc, and conlinuing along the Southern line of Lot No, 2 as shown on said Plan of Subdivisions now or formerly of Cuisine Management Services, Inc, , North 67 degrees 15 minutes East, a distance of254,16 feet to a nail in the center line of said public road leading from Newville to Doubling Gap; thence along the center line of said public road leading from Newville to Doubling Gap, the following three (3) courses and distances: (1) South 26 degrees 48 minutes East, a distance of 33,38 feet to a point; (2) South 32 degrees 12 minutes East, a distance of 113 feet to a point; (3) South 33 degrees 50 minutes East, a distance of 37,90 feet to a point at the place of beginning, , ' h aid Plan of Subdivision for Gary E. CONTAINING 1.08 acre and being all of Lot No.1 as s own on s Bobb, recorded as aforesaid, . 'd mbered as 830 Doubling Gap Road, Newville, HAVING thereon erected a dwelling house known an nu Pennsylvania, Tax #05-0413 Parcel #032B EXHIBIT A NOTE THIS LOAN IS NOT ASSUMABLE WITHOUT THE APPROV AL OF THE DEPARTMENT OF VETERANS AFFAIRS OR ITS AUTHORIZED AGENT. AUGUST 24, 1999 [Date] CAMP HILL [City] PENNSYLVANIA [State] 830 DOUBLING' GAP ROAD, NEWV1LLE, PA 17241 [Property Address] 1. BORROWER'S PROMISE TO PAY In return for a loan that I have received, I prdmise to pay U,S. $ 104,448.00 (this amount is called "principal"), plus interest, to the order of the Len~er, The Lender is BROADV I EW MORTGAGE COMPANY, 95 E. WILSON 8RIDGE ROAD, WORTHINGTON, OH 43085 I understand that the Lender may transfer this Nofe. The Lender or anyone who takes this Note by transfer and who is entitled to receive payments under this Note is called the ':Note Holder," 2. INTEREST , Interest will be charged on unpaid principal until the full amount of principal has been paid. I will pay interest at a yearly rate of 8.000 %. The interest rate required by this Section 2 is the rate I will pay both before and after any default described in Section 6(B) of this Note, i , 3. PAYMENTS (A) Time and Place of Payments I will pay principal and interest by making p~yments every month, I will make my monthly payments on the :IST day of each month beginning on OCTOBER, 1999 I will make these payments every month until I have paid all of the principal and interest and any other charges described below that I may owe under this Note, My monthly payments will be applied to interest before principal, If, on SEPTEMBER 1, 2029 , I still owe amounts under this Note, I will pay those amounts in full on that date, which is called the "Maturity Date," I will make my monthly payments at BRO~DVIEW MORTGAGE COMPANY, 95 E WILSON BRIDGE ROAD, WORTHINGTON, OH 43085 or at a different place if required by the Note Holder, (B) Amount of Monthly Payments My monthly payment will be in the amount ofU,S, $ 766.40 4. BORROWER'S RIGIIT TO PREPAY I have the right to prepay at any time, without premium or fee, the entire debt evidenced by this Note, or any part thereof not less than the amount of one inslallmenl, ot $100.00. whichever is less, Any prepayment in full of the debt shall be credited on the date received, and no interest may be charged after that date, Any partial prepayment made on any day other than an installment due date need not be credited until the next following installment due date or 30 days after the date of the partial prepayment, whichever is earlier. ' MULTISTATE FIXED RATE NOTE - Singte Family -UNIFORM INSTRUMENT ITEM 341811 (9508) Oacld 0000001688 (Page 1 of 3 pages) GREATLANO. To Order e.ll: 1-800-530-93930 File 618-791.1131 ACCT# 979880 . EXHIBIT B . 5. L9AN CHARGES I If a law, which applies to this loan and which sets maximum loan charges, is fmally interpreted so that the interest or other loan charges collected or to be collected in ~onnection with this loan exceed the pennitted limits, then: (i) any such loan charge shall be reduced by the amount necessaEy to reduce the charge to the pennitted limi~ and (ii) any sums already collected from me which exceeded pennitted limits will be refunded to me. The Note Holder may choose to make this refund by reducing the principal I owe under this Note or by making a direct payment to me. If a refund reduces principal, the reduction will be treated as a partial prepayment. 1 6. BORROWER'S FAILURE TO PAY AS REQUIRED (A) Late Charge for Overdue Payments If the Note Holder has not received the full amount of any monthly payment by the end of FI FTEEN*******caiendar days after the date it is due. I will pay a late charge to tile Note Holder, The amount of the charge will be 4.00 % of my overdue payment. I will pay this late charge promptly but only once on each late payment. (B) Default ' If I do not pay the full amount of each monthly payment on the date it is due, I will be in default. (C) Notice of Default If I am in default, the Note Holder may send me a written notice telling me that if I do not pay the overdue amount by a certain date, the Note Holder may require me to pay immediately the full amount of principal which has not been paid and all the interest that I owe on that amount. That date must be at least 30 days after the date on which the notice is delivered or mailed to me. ' (D) No Waiver By Note Holder Even if, at a time when I am in default, the Note Holder does not require me to pay immediately in full as descnoed above. the Note Holder will still have the right to :do so if I am in default at a later time, (E) Payment of Note Holder's Costs and Expenses If the Note Holder has required me to pay nhmediately in full as described above, the Note Holder will have the right to be paid back by me for all of its costs and expenses in enforcing this Note to the extent not prohibited by applicable law. Those expenses include, for example, reasonable attorneys' fees, 1 7. GIVING OF NOTICES Unless applicable law requires a different mbthod, any notice that must be given to me under this Note will be given by delivering it or by mailing it by fIrst class mail tci me at the Property Address above or at a differerit address if I give the Note Holder a notice of my different address. 1 Any notice that must be given to the Note Holder under this Note will be given by mailing it by fIrst class mail to the , Note Holder at the address stated in Section 3(A) above or at a different address if I am given a notice of that different address. 8. OBLIGATIONS OF PERSONS UNDER THIS NOTE If more than one person signs this Note, each person is fully and personally obligated to keep all of the promises made in this Note, including the promise to pay the full amount owed. Any person who is a guarantor, surety or endorser of this Note is also obligated to do these things, Any perso~ who takes over these obligations, including the obligations of a guarantor, surety or endorser of this Note, is also obligated ;to keep all of the promises made in this Note. The Note Holder may enforce its rights under this Note against each person individually or against all of us together, This means that anyone of us may be required to pay all of the amounts owed under this Note, 9. WAIVERS I and any other person who has obligatiol)s under this Note waive the rights of presentment and notice of dishonor, "Presentment" means the right to require the Nqte Holder to demand payment of amounts due. "Notice of dishonor" means the right to require the Note Holder to give notice to other persons that amounts due have not been paid. , ITEM 341 el2 (9508) Oocld 0000001588 (Pog.2 of 3 pag"j GREATlANOW To Order Call: 1.800-S30-S393DFax81S-791-1131 ACCT# 979880 10. UNIFORM SECURED NOTE This Note is a uniform instrument with limited variations in some jurisdictions, In addition to the protections given to the Note Holder under this Note, a Mortgage, Deed of Trost or Security Deed (the "Security Instrument"). dated the same date as this Note, protects the Note Holder from possible losses which might result if I do not keep the promises which I make in this Note. That Security Instrument descnoes how and under what conditions I may be required to make immediate payment in full of all amounts I owe under this Note. Some of those conditions are described as follows: Transfer of the Property. This loan may be declared immediately due and payable upon transfer of the Property securing such loan to any transferee, unless the acceptability of the assumption of the loan is established pursuant to Section 3714 of Chapter 37, Title 38, United States Code. If Lender exercises this option, Lender shall give Borrower notice of acceleration. The notice shall provide a period of not less than 30 days from the date the notice is delivered or mailed within which Borrower must pay all sums secured by this Security Instrument If Borrower fails to pay these sums prior to the expiration of this period. Lender may invoke any remedies permitted by this Security Instrument without further notice or demand on Borrower. (Seal) -Borrower (Seal) .Borrowcr (Seal) -Borrower (Seal) .BOlIowcr :UTHOU'l' RE':OU'.: .. .''1: 'l'O THE ORDER OT!: [Sign Original Only] Rosemary Howard Vice President ITEM S41SL3 (9508) Oocld 0000001588 (Pag. 3 of 3 pages) GREATLANO. T' 0"'" C.II: HOO'''A'C'c9 V' ~~~li~30 *** D 13 .:V': .>Co::;,. ,',- .... ........ 03-17-02 MSP LETTERWRITER ACTIUITY FOR MONT~ LOAN- 0001177688 DATE-02-21 USER-CEl KEY-DR133,UERS-Ol0 TITLE-act91/6 LINES-PER-PAGE-NO CONDITIONS-O ATLANTIC MORTGAGE & INUESTMENT CORPORATION 7159 CORKLAN DRIUE JACKSONUILLE, FLORIDA 32258 February 21, 2002 INUESTOR NO.: 011/L COUNTY CODE: 73 Leroy A Luther 830 DoubllD3-0ap Rd Newville PA 172~1 Loan Number: 0001177688 Current Lender/Servicer:Atlantic Mortgage & Investment Corporation TEMPORARY STAY OF FORECIOSURE--Under the Act, you are entitled to a temporary stay of foreclosure on your mortgage for thirty (30) days from the date of this Notice. Durinq that time you must arranqe and attend a "face-to-face" meeting with one of the consumerlcredit counseling agencies listed at ~he end of this Notice. : THIS MEETING MUST OCCUR WITHIN THE NEXT (30) DAYS, IF YOU DO NOT APPI Y FOR EMERGFNCY ~IORTGAGE ASSISTANCE. YOU MUST BB.ING YOUR MORTGAGE UP TO DATE. THF PART OF THTS NonCE CAli ED "HOW HLCllBF YOUR DFFAIJl T" , EXPLAINS HOW TO BRING YOUR MORTGAGE UP TO DATE. r:oNSllMtR CRFOn COlINSFI TNG AGFNCTFS-- If you meet with one of the consumer credit coun6elinQ aqencies listed at the end oJ this no_tLc_~l...____ the lender may NOT taKe action against you for thirty (30) days after the date of this meeting. The names, addresses, and tplpphonp numQers of desiqnated consumer credit counseLinq agencies for the county in which the property is located arp set forth at the end of this Noti~e. It is only necessary to schedule one face-to face meeting. Advise your lender immediately of your intentions. . . DR133 EXHIBIT C :=J. 198. 585 I RITY-l . 11!1.!..Ui.... *** E- -13 *'ii:* 03-17-02 MSP LETTERWRITER ACTIUITY FOR MONTH OF LOAN- 0001177588 DATE-02-21 USER-CEl KEY-DRl~O UERS=Ol~ TITLE-ACT91/5 LINES PER PAGE-NO CONDITIONS-O LOdn Number:000:177588 AP~ ICATION FOR MORTGAGE ASSISTANCE- Your mortgage is In default for the reasons set forth later In this Notice (see following pages for specific Information about 'th~ n,ture of your default). If you have tried and are unable to resolve this problem with the lender, you have the right to apply for finnncial assistance from the Homeowner's Emerqency Assistance Proqram. To do 50. you must fill out. sign, and file a completed Homeowner's Emergency Assistance Program qpplication with one of the designated consumer credit counselinR ~qencies listed at the end of this Notice. Only consumer credit ~oungelln9 agencies have aprtications for the program and they will assist you in submitting a complete application to the Pennsylvania HousinR Finance ARency. Your application MUST be filed or postmarked within thirty (30) days of your face to face meeting, YOU MUST'FILE YOUR APPLICATION PROMPTLY. IF YOU FAIL TO DO SO OR IF VOU DO NOT FOLLOW THE OTHER TIME PERIODS SET FORTH IN THIS LETTER. FORECLOSURE MAY PROCEED AGAINST YOUR HOME IMMEDIATELY AND YOUR APPLICATION FOR MORTGAGE ASSISTANCE WILL BE DENIED. AGFNCY ACTION--Avallable funds for emergency m"ortgage assistance are very limited. They will be disbursed by the Aqency under the eligibility criteria established by the Act. The Pennsylvania Housing Finance Agency has sixty (50) days to make a decision after It receives your application. Durinq that time. no foreclosure proceedings will be pursued against you if you have met the time requirements set forth above, You will be notified directly by the Pennsylvania HOU6inQ Finance Aqerlcy of its decision on your application. NOTE: IF YOU ARE-CURRENTLY PROTECTED BY THE FILING OF A PETITION IN BANKRUPTCY, THE FOLLOWING PART OF THIS NOTICE IS FOR INFORMATION PURPOSES ONLY AND SHOULD -NOT BE CDrISIDERED AS AN ATTEMPT TO COLLECT THE DEBT. (If you have filed bankruptcy you can still apply for Emergency Mortgage Assistance) HOW TO CURE YOUR MORTGAGE DEFAW T (Brln. it UP to dote), NATlJRF OF THF DFFAlJl T--The MORTGAGE debt held by the above lender on your property located at: 830 Doubling Gap Rd, NelNIlle PA 172~1 IS SERIOUSLY IN DEFAULT because: A." YOU HAUE NOT MADE MONTHLY MORTGAGE PAYMENTS for the fa llowing months and the followlnq amounts are now past due: (1) Monthly payments from December 01. 2001 thru February 1.2002 Cat $885.27 per month) $2(;58,81 Monthly payments from thru (at $ per month) (2) Previous late charges; $ $ $ 105....3.5..-_ ?2.....50 (3) Other charges; Escrow. Inspection, NSF checks (<f) Other provis ions of the mortgage obllsat.ion, if any $ , an 8EQUIRED AS OF THIS DATE *** *** G 13 *** 103-17-02 MSP LETTERWRITER ACTIUITY FOR MONTH OF 02-02 LOAN= 0001177688 DATE=02-21 USER=CE1 KEY=DR1~1 UER9=010 TITLE=~ct 91/6 LINES-PER-PAGE=NO CONDITIONS=O Loan Number:0001177688 B. YOU HAUE FAILED TO TAKE THE FOLLOWING ACTION (00 not use if not appl icable): HOW TO ClJRE THE DEFAIII T--You may cure the default within THIRTY (30) DAYS DE THE DATE of the date of this Noticel BY PAYING THE TOTAL AMOUNT PAST DUE TO THE LENDER, WHICH IS $ 2,787.66 PLUS ANY MORTGAGE PAYMENTS AND LATE CHARGES WHICH BECOME DUE DURING THE THIRTY (30) DAY PERIOD. Pavments mUAt be made either bv cash, c~~hier.~ checK. cprtified chp.ck~ or money ordp~ made pay~blp. ~nd sent to: ATTN: COLLECTION DEPARTMENT ATLANTIC MORTGAGE & INUESTMENT CORPORATION 7159 CORKLAN DRIUE JACKSONUILLE, ELDRIDA 32258 You can cure any other default by taking the following action within THIRTY (30) DAYS of the date of this letter: (Do not use if not applicable). IF YOII DO NOT ClJRE THE DEEAIII T-- If you do not cure the default within t THIRTY (30) DAYS of the date of this Notice, the lenner intenns.-Lo. exercise its riqhts to accelerate the mortqaqe debt. This means that the entire outstanding balance. of this debt will be considered due immediately and you may lose the chance to pay the morlgage in monthlv installments. If full payment of the total amount past due is not made within THIRTY (30) DAYS, the lender also intends to instruct its attorneys to start legal action to forecloAe upon vOllr mortqaqed property. IF THE MORTGAGE IS FORFCIOSED lJPON-- The mortgaged property wi II be sold by the Sheriff to pav off the mortgage debt. If the le~der refers your case to its attorneys, but you cure the delinquency before the lender begins legal proceedings 'against you, you will still be required to p~y 'he reasonable attorney's fees that were actually incurred, up to $50.00, However, if legal proceedings are started against you, you will have to pay all reasonable attorney's fees actually incurred by the lender even if they exceed $50.00. Anv attorney's fees will be added to the amount you owe the lender, which maY a LSD inc lude other reasonab le costs. If YOll curE" thE" def~LJ-l t within tQe THIRTY (30) DAY period. vou will not be required to pav attorn?', 5 fpes "0 OTHER LENDER REMEDIES-- The lender may also sue you personally for the unpaid principal balance and all other sums due under the mortgage. RIGHT TO CURE THF: DEFAUI T PRIOR TO SHERIFF'S SAI E-- If yoU have not .______ ___...m cured the default within the THIRTY (30) DAY period and foreclosure . proceedings have begun, VOll 5t i il have the riQht to cure the defnult and prevent the sale at anv time UP to one hour before the Sheriff's Sa Ie. YOll mav do AO bv pav i nQ the tota I amollnt th~~ ~a~t d~~~ ; l~A nnv latp or other charqps thpn dlJP. reasonnhle attorney's fees and costs connected ~ith the foreclosure sale and other costs ccnnected with the Sheriff A Sale aA "ppcifipd in writinQ bvjhe leru:i~Lil.ruLb.Y pprforminQ any othpr reQuirempnts undpr thp mort9ll.9..f......... Curing your default in the manner set forth in this notice will rEstore your mortgage to the same position as if you have never defaulted. T"'n1......1 uelaUll ,il ,.'iL_ 1l1lJ,fi1ll;; :.>Ll. IUI Ltl Jtt "'..l..;;" !I\)l~'...".. w~.." L~;_'_'.'_ iiiort'ga-ge--to the'samepo-5Ttion-as'--iTyo~-ha-ve nec'er defau l ted, DR1'l1 *** H 13 *** 03-17-02 MSP LETTERWRITER ACTIUITY FOR MONTH OF 02--02 LOAN= 0001177b88 DATE=02-21 USER=CEl KEY=DR142 UERS=010 TITLE-act 91/(1 , LINES-PER-PAGE-NO CONDITIONS-O Loan Number:0001177688 EARLIEST POSSISI F SHERIFF'S SAI E DATE -- It is estimated that the ear l iest date that such a Sheriff's Sale of the mor~Jaged property , could be held would be approximately six (6) months from the date of this Notice, A notice of the act ua l date of the Sheriff's Sale wi II be sent to you before the sale. Of course, the amount needed to cure , the default wi II increase the lonqer YOU wait. You may find out at any -<r- time exactly what the required payment or action wi II be by contacting the lender. HOW TO r.ONIACT THE I ENDFR: ----..-.-.-.--.-- Name of Lendel- : ATLANTIC MORTGAGE & INUESTMENT CORPORATION .----- B.d.d..c.e s..s. : 7159 CORK LAN DRIVE JACKSONVILLE, FLORIDA 32258 Phone number: 1-800-288-2542 Fax number: 1-904-288-5057 ._~-~~-- Contact Person: Robert Pi larski EFFECT OF SHERIFF'S SALE-- You should realize that a Sheriff's Sa le . will end.your ownership of the mortgaged property and your right to occupy it. If you continue to live in the property after the Sheriff's Sale. a lawsuit to remove you and your furnishinqs and other belonqinqs could be started by the lender at any time. ASSUMPTION OF MORTGAGE-- Your mortqaQe MAY be a!;sumable, You may se II or transfer your home to a buyer or transferee who wi II assume the mortgage deb~. provided that all the outstanding payments, charges, and attorney s fees and costs are~i.sLErior to or at the sale and - that the other requirements of th~ mortgage are satisf ied. YOU MAY ALSO HAVE THE RIGHT: TO SELL THE PROPERTY TO OBTAIN MONEY TO PAY OFF THE MORTGAGE DEBT OR TO BORROW MONEY FROM ANOTHER LENDING INSTITUTION TO PAY OFF -~~-- THIS DEBT. TO HAUE THIS DEFAULT CURED BY ANY THIRD PARTY ACTING ON.YOURBEHALF, TO HAVE THE MORTGAGE RESTORED TO THE SAME POSITION AS IF NO DEFAULT HAD OCCURRED. IF YOU CURE THE DEFAULT. (HOWEUER, YOU DO NOT HAUE THIS RIGHT TO CURE YOUR DEFAULT MORE THAN THREE TIMES IN ANY CALENDAR YEAR). TO ASSERT THE NONEXISTENCE OF A DEFAULT IN ,ANY FORECLOSURE PROCEEDING OR ANY OTHER LAWSUIT INSTITUTED UNQ~R THE MORTGAGE DOCUMENTS, i TO ASSERT ANY OTHER DEFENSE YOU BELIEUE YOU MAY HAUE TO SUCH ACTION BY THE LENDER. --~.- TO SEEK PROTECTIDN UNDER THE FEDERAL BANKRUPTCY LA~I. --._----- ~ _______.._________u".._._.~..___ . GQ1'l~UMFR CRFDIT COUNSFI ING AGFNCIFS SFRUING YOllR COUNTY (Please 6ee attached) --_._~_.,,---...- Please be advised that Atlantic Mortgage & Investment Corporation is a debt collector; any information obtained wi II be used for that -...--------- purpose. By: . Robert Pi larsKi -_.~ iiobe;;j Pi l~~ski DR142 *** I 13 *** , 03-17-02 MSP LETTERWRITER ACTIUITY FOR ~10W:-j OF O;~-OC LOAN= 0001177688 DATE-02-21 USER-CEl KEY-DR135 UERS=008 TITLE=act9V5 ___ ____m_____ LINES-PER-PAGE-NO CONDITIONS::.O ATLANTIC MORTGAGE & INUESTMENT CORPORATION -- 7159 CORKLAN DRIUE JACKSONUILLE, FLORIDA 32258 February 21. 2002 INIJESTOR NO. : 01VL COUNTY CODE: 73 -._--,.-._- ._-~--- Carolyn A Ge i ling-Luther 830 D~ub l inq Gap Rd . ----- Newvi lle PA 172'11 Loan Number: 0001177688 -----~-_._--_._.,-_.- Current Lender/Servicer:Atlantic Murtgage & Investment Corporation .HOMEOWNER'S EMERGENCY MORTGAGE ASSISTANCE PROGRA~1 YOU MAY BE ElIGIBLE FOR FINANCIAL ASSISTANCE WHICH CAN SA~~ ~~lJR HOMF FROM FORFCI OSIJRF AND HEI P YOU MAKF FUTURF t10RTGAGF P M & . IF YOU COMPLY WITH THE PROUISIONS OF THE HOMEOWNER'S UIERGENCY - MORTGAGE ASSISTANCE ACT OF 1983 (THE " ACT" ) , YOU MAY BE ELIGIBLE FOR EMERGENCY MORTGAGE ASSISTANCE: IF YOUR DEFAULT HAS BEEN CAUSED BY CIRCUMSTANCES BEYOND YOUR CONTROL, IF YOU HAUE A REASONABLE PROSPECT OF BEING ABLE TO PAY YOUR MORTGAGE PAYMENTS, AND . IF YOU MEET OTHER ELISIBILITY REQUIREMENTS ESTABLISHED .----- BY THE PENNSYLUANlti HOUSING FINANCE AGENCY. o. TEMPORARY STAY OF FORECI OSIJRE --Under the Act , you are entitled to a 'temporary stay of for"closure on your mortgage for thirty (30) days from the date of thic Notice. Durinq thatl time YOU must arranqe and attenc "face-to-face " . meet ing with of the c ,'ed i t a one consumer~ counse Ling agencies listed at the end of this Notice, THIS MEETING MUST OCCUR WITHIN THE NEXT (30) DAYS. IF YOU DO NOT 0 APPL Y FOR EMFRGFNCY MORTGAGE ASSISTANCE. YOU MIJST BRING YOIJR t10RTGAG.E UP TO OATF. THF PART OF THIS NOTICE CALI FO "HOW IILJ:.URF YOIJR OFFAUU" , EXPLAINS HOW TO BRING YOUR MORTGAGE UP TO DATE: . ."--- -- CONSIJMEH CRF 0 I L CilllliSE.L I NG AGFNr.IFS-- If ylou meet with one of the con6umer credit coun6elina aqencies listedl at the end of this notice. ------_. - _...- the lender may NOT taKe action against yo~ for th.rty (30) days after the date of this meeting_ Thp ni'lmp!='.. ilddn'pssps. i'lnd tp I pphonp n.umb...e.rs of desiqnated credit counse l inQ , , for the county in conSUfTlE'r 6.QenCleS .---------.. - ------ which thp propprty is locnted ?Ire ~pt forth nt thp pnn of thl", Notice. It is only necessary to schedule one face~1:o face meeting. Ad\.Jise your lender immediately of your intentions. .__~..___._m ______ , DR135 . .----..--.--....- . - ;.----..---...--.- *** J 13 *** 03-17-02 t1SP LETTERWRITER ACTIUITY FOR MONTH OF 02-0: - LOAN- 0001177588 DATE-02-21 j.JSER-CEl KEY=DR1<10 UERS=Ol<1 TITLE-ACT91/5 -----_.~ .-.- LINES-PER-PAGE-NO COND IT IONS=O Loan Number:0001177588 ~...- --...--....-- 8EELlCflll.QN FOR MORTGAGE" ASSTSTANCF-- Your mortgage is in default for. the reasons <;et forth later' in this Noti c e (see folLowing pages for specific info .t ion about the n.ature of your default), If YOL.. .~ have tried and ?_f 0.: ,mable to resolve ~his probLem wit ~) thp. t~nder, > JU have the right to appLy for financiaL a.s51stance from the Homeowner s Emerqency Assistanc~ Proqram. To do so . YOU must fill .--- - out, sign, and file completed Homeowner , Emergency Assistance a s Program App l icat ion with one d the designat.ed c. nsumer credit coun6etinq aqencies list ed at the end of this lh.. t ice. O"lv consumer ---~-'~- .--- credit counseling .agencies have appl icat ions for the \rogr'am and t'",ev wi II assist you in submitting a complete appL icat ion to the Pen""lsyt.vania Housinq Finance Aqer.!J;,i' . Your app Llcat ior, MIJST be filed or postmarked .-.---- -_.. -- --. .~- - within thirty (30) cays of your face-to-fac.. meeting. YOU MUST FILE YOUR APPLICATION PROMPTLY, IF YOU FAIL TO DO SO OR IF _._--_.~--.-.-- YOU DO NOT FOLLOW THE OTHER TIME PERIODS SET FORTH IN THIS LETTER, ---.- FORECLOSURE MAY PROCEED AGAINST YOUR HOME IMMEDIATELY AND YOUR APPLICATION FOR MORTGAGE ASSISTANCE WILL BE DENIED, .------ AGFNCY ACTTON--AvailabLe funds for emerge'lcy mo,'t gage assistance are very L imi ted. They wi Ll be disbursed bv the Agencv under the . eLigibi lity criteria established by the Act , The PennsyLvania Housing' Finance Agency h',s sixty (60) days to make a decision after it receive6 your application. Durinq that time. no foreclosure . proceedings wi LL be pursued against YOU if you have met the time . requirements set forth above. You wi L L be notified direct ly by the Pennsvlvania Housinq Finance Aqencv of its. dec ision on your ~plication. NOTE: IF YOU ARE CURRENTLY PROTECTED EY THE FILING OF A PETITION IN BANKRUPTCY, THE FOLLOWING PART OF THIS NOTICE IS FOR INFORMATION PURPOSES ONLY AND SHOULD NOT BE CONSIDERED AS AN ATTEMPT TO COLLECT THE DEBT. (If you have fiLed bankruptcv YOU can st ill appLv for Emergency Mortgage Assistance) I HOW TO CURE YOUR MORTGAGE DEFAULT (Brinq it UP to date), --------....---..-- . NATlJRF OF THF OFFAUl T--The MORTGAGE debt held by the above lender ~our propertv located at: 830 Doub ling Gap Rd, Newville PA 172'11 IS SERIOUSLY IN DEFAULT because: A. YOU HAUE NOT MADE MONTHLY MORTGAGE PAYMENTS for the following months and the fot Lowinq amounts are now pest due: .- (1) MonthLy payments from Oecember 01. 2001 ......lft2558 ,81 thru Februarv 1.2002 (at $885, 27 ~r month) .---..---.-.. --.- MonthLy payments from $ --~-----_.- thru (at $ per~ month) . ------~_.----- ., (2) Previous Late charges; i ~--.1Q6....3S (3) Other charges; Escrow, Inspection, ~. ??SO -- -----~- NSF checks ('1) Other provisions of the mortgage ~ ----_._-_.~ -- ----- obi igat ion, if any ( S ) I U I AL AMOUN I O~ (1), (2) and (3) ~ b . , REQUIRED AS OF THIS DATE l~* ~ q:1 *'bf L *** L 13 *** 03:"'17-02 MSP LETTERWRITER ACTIUITY FOR MONTH OF 02- LOAN- 0001177688 DATE=02-21 USER~CE1 KEY=DRt~l UERS=010 TITLE=~ft 91/5 LINES-PER-PAGE-NO CONDITIONS-O Loan Number:0001177688 B. YOU HAUE FAILED TO TAKE THE FOLLOWING ACTION (Co not use if not applicable): HOW TO [IIRF THE DFFAIJl T--You ~may cure the default within THIRTY (30) DAYS OF THE DATE of the date of this Notice BY P~YING THE TOTAL AMOUNT PAST DUE TO THE LENDER. WHICH IS $ 2,787.66 PLUS ANY MORTGAGE PAYMENTS AND LATE CHARGES WHICH BECOME DUE DURING THE THIRTY (30) DAY PERIOQ. Payments must be made either by cash, caRhier's chpck. cprtifipn chpck.. or m(l~ordpr [nndP P?tYnhlp nnd sent to: ATTN: COLLECTION DEPARTMENT ATLANTIC MORTGAGE & INUESTMENT CORPORATION 7159 CORKLAN DRIUE JACKSDNUILLE. FLORIDA 32258 You can cure any THIRTY (30) DAYS ~ppl ir~blp). other default by taking the of the date of this letter: . f following action within (Do not use if not IF YOU DO NOT CIJRF THE OFFAUI T If you 'do not cure the default within THIRTY (30) DAYS of the date of this Notice. the lender intends to exercise its riqhts to accelerate the mortqaqe debt, This means that the entire outstanding balance of this debt will be considered due immediately and you may lose the chancelto pay the mortgage in monthly installments. If full payment of the total amount past due is not ma~e within THIRTY (30) DAYS) the lender also intends to instruct its attorneys to start legal action to foreclose upon YO.lli: mortqaqed property. 1 IF THF MORTGAGF IS FORFCIOSFO UPON ThJ mortgaged property will be sold by the Sheriff to payoff the mdrtqaqe debt. If the lender refers your case to its attorneys, but ~ou cure the delinquency ~efore the lender begins legal proceedings aQainst yo~. you will still be required to pay the reasonable attorney's fees that were actually incurred, up to $50.00. However, if legal proceedings ore started against you, you will have to pay all r~asonable attorney s fees actually incurred by the lender even if they exceed $50.00. Any attorney's fees will be added to the amount you owe the lender, which may also include other reasonable costs. If YOll cure the defau{t within t~e THIRTY (30) DAY period. you will not be required to pay nttornev s f?p.s. OTHER LENDER REMEDIES-- The lender may also sue you personal~r th~ unpaid principal balance and all other sums due under the mortgage. RIGHT TO CURE THE DEFAULT PRIOR TO SHERIFf' S SALE -- If 'y_ou.Aave_-"ot ~.__.~,__.._ cured the default within the THIRTY (30) ~AY period and foreclosure proce~din9s h~ve begun. YOll still hnvp thp riQht to Cllrp the r.IpfC'ltdt bnd preVEnt the sale at any time UP to une hour before the Sheriff's Snlf>. You m?JY do 90 bv pa..JlnQ the toti'll i'lmount thpn Pnst (hIP. plus any lr\tp or othpr r.hnrQPs then nllP. rpC'lsoni'lhle f'lttornpv's fpps r\no costs connected ~ith the foreclosure sale and other CORts connected with the SherIff 5 S~le as specified i~tinq by the lender ~nd hx performinq E!.nv other rp-quirempnt!'io llndpr thf' mortQ!'IQP. Curing your default in the manner set furth in this notice will restore your mort~age to the same position as if you have never defaulted. nRl<'ll 03-17-02 I. IMSP LETTERWRITER ACTIUITY FOR MONTH,OF 02-02 LOAN- 0001177688 DATE~02-21 USER-CEl KEY-DR142 UERS-Ol0 TITLE=act 91/6 LINES-PER-PAGE-NO CONDITIONS=O Loan Numb~r:0001177688 EARl TFST POSSTRI F SHFRTFF'S SAI F DATE--It is est imated that. the earliest date that such a Sheriff's Sale of the mortgaged property could be held would be approximately six (6) months from the date of this Notice, A notice of the actual date of the Sheriff's Sale will be sent to you before the sale. Of course, the amount needed to cure the default will Increase the lonqer you wait. You may find out at any time exactly what the required payment or action will be by contacting the lender. HOW TO CONTACT THE LENDER: Hame of Lender: ATLANTIC MORTGAGE & IHUESTMENT CORPORATION ~ddress: 7159 CORKeAN DRIUE . JACKSONUILLE, FLORIDA a2258 Phone number: 1 800-288-2642 Faxlnumber: 1-904-288-5067 Contact Person: Robert PilarsKi I EFFECT OF SHERIFF'S SALE-- You should real~ze that a Sheriff's Sale will end your' ownership of the mortgaged property and your right to OCCUpy it. If you continue to live in the property after the Sheriff's Sale. a lawsuit to remove YOU and your furnishlnqsand other belunqinRs coul~ be started by the lender at any time. ASSUMPTION OF MORTGAGE Your mortqaqe MAY be assumable. You may sell or transfer your home to a buyer or transferee who will assume the mortgage debt, provided that all the outstanding payments, charges, and attorney's fees and costs are paid prior to or at the sale and that the other requirements of the mortgage are satisfied. YOU MAY ALSO HAUE THE RIGHT: TO SELL THE PROPERTY TO OBTAIN MONEY TO PAY OFF THE MORTGAGE DEBT OR TO BORROW MONEY FROM ANOTHER LENDING INSTITUTION TO PRY OFF THIS DEBT. TO HAUE THIS DEFAULT CURED BY ANY THIRD PARTY ACTING ON YOUR BEHALF. TO HAUE THE MORTGAGE RESTORED TO THE SAME POSITION AS IF NO DEFAULT HAD OCCURRED. IF YOU CURE THE DEFAULT. (HOWEUER , YOU DO NOT HAUE TIJIS RIGHT TO CURE YOUR DEFAULT MORE THAN THREE7 TIMES IN ANY CALENDAR YEAR). TO ASSERT THE NONEXISTENCE OF A DEFAULT IN ANY FORECLOSURE PROCEEDING OR ANY OT ERLA SUIT NSTI ED U DER T ORTGAGE DOCUMENTS. . TO ASSERT ANY OTHER DEFENSE YOU BELIEUE YOL MAY HAUE TO SUCH ACTION BY THE LENDER. r TO SEEK PROTECTION UNDER THE FEDERAL BANKRUPTCY LAW, CONSlJMFR CRFDn CDIINSFI TNG AGFNCIES SFRUTNG YOIJ8 COlJNTY CPleasp Gee attached) ~ Please be advised that Atlantic Mortgage ~ Investment Corporation is a debt collector; any information obtained will be used for that purpose. I By: Robert PilarsKi DR142 *** A 14 *** VERIFICA nON Mr. Edward M. Johns hereby states that he is Assist, Vice President of Atlantic Mortgage & Investment Corporation mortgage servicing agent in this matter, that he is authorized to take this Verification, and that the statement made in the foregoing Civil Action Mortgage Foreclosure Complaint are true and correct to the best of his knowledge, infonnation and belief, The undersigned understands that this statement is made to the penalties of 18 Pa .C, S,A. Sec, 4904 relating to unsworn falsification to authorities, c~ Edward M. Johns Vice President Date: I}- 3. dt7o;:). SHERIFF'S RETURN - REGULAR CA~E NO: 2002-03307 P COMMONWEALTH OF PENNSYLVANIA: COUNTY OF CUMBERLAND ATLANTIC MORTGAGE & INVESTMENT VS LUTHER LEROY A ET AL GERALD WORTHINGTON Sheriff or Deputy Sheriff of Cumberland County,Pennsylvania, who being duly sworn according to law, says, the within COMPLAINT - MORT FORE was served upon LUTHER LEROY A the DEFENDANT , at 1520:00 HOURS, on the 15th day of July at 830 DOUBLING GAP ROAD , 2002 NEWVILLE, PA 17241 by handing to LEROY A LUTHER 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 18,00 8,28 .00 10.00 ,00 36.28 So Answers: .rg~""~~"""l:'4~ ,. R. Thomas Kline 07/16/2002 PULEO & DEMILIO Sworn and Subscribed to before me this ~ /"oAI day of BY~. /A)~ Deputy Sh ff Oq;.. :;;:'d/:,~ r thonotary SHERIFF'S RETURN - REGULAR CASE NO: 2002-03307 P COMMONWEALTH OF PENNSYLVANIA: COUNTY OF CUMBERLAND ATLANTIC MORTGAGE & INVESTMENT VS LUTHER LEROY A ET AL GERALD WORTHINGTON , Sheriff or Deputy Sheriff of Cumberland County,Pennsylvania, who being duly sworn according to law, says, the within COMPLAINT - MORT FORE was served upon LUTHER CAROLYN A GElLING the DEFENDANT at 1520:00 HOURS, on the 15th day of July at 830 DOUBLING GAP ROAD 2002 NEWVILLE, PA 17241 by handing to LEROY A LUTHER, 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 6.00 .00 ,00 10,00 .00 16,00 So Answers: .".., 00;7' ~r/,,'J;" .~ ..'~ ~". ".q. J~ " ,,~:::':, . , ~/h ~,,~::;:/; _0 .,,_<;..,~ R, Thomas Kline 07/16/2002 PULEO & DEMILIO Sworn and Subscribed to before BY:A'~!A)~ Deputy Sh iff me this J~ day of 01t; d.bb.v A D -Q.~,~ P othonotary , ?i ....... ~ ~ .... o o ig. ~ a c, ~ D c-; -u f. F 6-$ ~ o C ?' ""t'l(1:l #T1rn ~-r'l 65~~ r€;:.r:, <\.~ :1" '_ 2't,"-", :i>~ =< o N '- c:: r- ~ .-; :1:." lllr= -rym --':1........., 1:5(1) .,_~.i:-i"l t?~ (~5j"'n -';.:! .:.0 -< f'V :r-... :4; If? :::> c::> LAW OFFICES OF PULEO &. D'EMILIO, LLC By: Thomas 1. Puleo, Esquire Identification No, 27615 660 Sentry Parkway, Suite 210 Blue Bell, PA 19422 (610) 941-3600 Attorney for Plaintiff IN THE COURT OF COMMON PLEAS OF CUMBERLAND COUNTY, PENNSYLVANIA CIVIL ACTION - LAW ATLANTIC MORTGAGE & INVESTMENT CORPORATION, a division of ABN AMRO Mortgage Group, Inc, : No. 02-3307 Civil Term v, LEROY A. LUTHER and CAROLYN A. GElLING-LUTHER, his wife PRAECIPE FOR JUDGMENT Enter judgment in favor ofthe Plaintiff and against the Defendant(s) for want of an answer and assess damages as follows: Principal Debt Interest from 11/1/01 through 8/21/02 Late charges accrued through 8/21/02 Escrow deficit Attorney fees Title information certificate $102,386,08 6,597.36 319.05 1,078,83 5,119.30 325,00 Total $115,825.62 I CERTIFY THAT THE FOREGOING ASSESSMENT OF DAMAGES IS FOR SPECIFIED AMOUNTS ALLEGED TO BE DUE IN THE COMPLAINT AND IS CALCULABLE AS A SUM CERTAIN FROM THE COMPLAINT, I certify that written notice of the intention to file this Praecipe was mailed or delivered to the party against whom judgment is to be entered and to his att~~cord, if any, aft r the default occurred and ;;i":" "'" d,l" pri~ <0 "'" "'" of"'" fi!;o, of <hi, ~~ rot iJ" ti,,;, ...",,,1. P,R.c.P. 1~~ ~ULEO, ESQUIRE Attorney for Plaintiff AND NOW {}u.s;;r c:2 b , 2002, Judgment is entered in favor of aintiff and against defendants and damages assessed as per the above certification, LAW OFFICES OF PULEO & D'EMILIO, LLC By: Thomas I. Puleo, Esquire Identification No, 27615 660 Sentry Parkway, Suite 210 Blue Bell, P A 19422 (610) 941-3600 Attorney for Plaintiff IN THE COURT OF COMMON PLEAS OF CUMBERLAND COUNTY, PENNSYLVANIA CML ACTION - LAW ATLANTIC MORTGAGE & INVESTMENT CORPORATION, a division of ABN AMRO Mortgage Group, Inc, : No, 02-3307 Civil Term v, LEROY A. LUTHER and CAROLYN A. GElLING-LUTHER, his wife To: Mr, Leroy A. Luther 830 Doubling Gap Road Newville, P A 17241 Date of Notice: August 6, 2002 NOTICE OF INTENTION TO FILE PRAECIPE FOR ENTRY OF DEFAULT JUDGMENT UNDER Pa,R,C.P.237.l IMPORTANT NOTICE YOU ARE IN DEFAULT BECAUSE YOU HA VB 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 DAYS FROM THE DATE OF TillS NOTICE, A JUDGMENT MAY BE ENTERED AGAINST YOU WITHOUT A HEARING AND YOU MAY LOSE YOUR PROPERTY AND OTHER IMPORTANT RIGHTS, YOU SHOULD TAKE TillS NOTICE TO A LAWYER AT ONCE, IF YOU DO NOT HA VB A LAWYER OR CANNOT AFFORD ONE, GO TO OR TELEPHONE THE FOLLOWING OFFICE TO FIND OUT WHERE YOU CAN GET LEGAL HELP: Cumberland County Bar Association 2 Liberty Avenue Carlisle, PA 17013 g:';;l;~:;::: ~ TOMAS I, PULEO Attorney for Plaintiff LAW OFFICES OF PULEO & D'EMILlO, LLC By: Thomas I. Puleo, Esquire Identification No, 27615 660 Sentry Parkway, Suite 210 Blue Bell, PA 19422 (610) 941-3600 Attorney for Plaintiff IN THE COURT OF COMMON PLEAS OF CUMBERLAND COUNTY, PENNSYL VANIA CIVIL ACTION - LAW ATLANTIC MORTGAGE & INVESTMENT CORPORATION, a division of ABN AMRO Mortgage Group, Inc. : No, 02-3307 Civil Term v, LEROY A, LUTHER and CAROLYN A. GElLING-LUTHER, his wife To: Ms, Carolyn A. Geiling-Luther 830 Doubling Gap Road Newville, PA 17241 Date of Notice: August 6, 2002 NOTICE OF INTENTION TO FILE PRAECIPE FOR ENTRY OF DEFAULT JUDGMENT UNDER Pa,R.C.P,237,1 IMPORT ANT NOTICE YOU ARE IN DEF AUL T BECAUSE YOU HAVE FAILED TO ENTER A WRITTEN APPEARANCE PERSONALLY OR BY A TIORNEY AND FILE IN WRITING WITH THE COURT YOUR DEFENSES OR OBJECTIONS TO THE CLAIMS SET FORTH AGAINST YOU. UNLESS YOU ACT WITHIN TEN DAYS FROM THE DATE OF THIS NOTICE, A JUDGMENT MAYBE ENTERED AGAINST YOU WITHOUT A HEARING AND YOU MAY LOSE YOUR PROPERTY AND 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 Bar Association 2 Liberty Avenue Carlisle, PA 17013 (717) 249-3166 (800) 990-9108 ~ ~ l.) ./.Q. 'i -0 9 ~ 0 Cl ...., - ~ C N ~ti F aU <': ",. ..., ") i55 ~ if( n1rrl c:: ~'!~t:g "'/"--r- r;-.. - .L._ ._~ 6 -,.( N '--;1 ~ r ~~~-~ cr. r:,:' ~ r.::;c'_: --;r:,i ~- -.-, , ''':. ~c:. ~'. . " IU -.,'. " 0 $~; (,:; ~''-1 , }' R .:-:-'1 .::~ '" '1>- '::n -< '.oJ -< I LAW OFFICES OFpULEO & D~M1L'O, Ltc By: Thomas I, Puleo, Esquire Identification No, 27615 660 Sentry Parkway, Suite 210 Blue Bell, PA 19422 (6 JO) 941-3600 Attorn"" fo, PI.." ff IN THE COURT OF COMMON PLEAS OF CllMBERLAND COUNTy. PENNSYL Y A1wA CIVIL ACTION _ LA W ATLANTIC MORTGAGE & INvESTMENT CORPORATION, a division of ABN AMRO Mortgage Group, Inc, v, : No, 02-3307 Civil Tenn LEROy A. LUTHER and CAROL YN A. GElLING-LUTHER, his wife AFFIDAYIT OF NON-MILITARY SERVIC.g COMMONwEALTH OF PENNSYL V ANJA COUNTY OF MONTGOMERY SS, T"" c""ry, A G';Ii'g-U.lb~;, o,~ 21 _ of '/lO, ""d" " 830 Do'bliog G'P Rood. NeWVille, PennsYlVania, and is employed by/as lUlknown, n", Lorny A L,th~""'~ 21 - '''Ii'. "'I"", " 830 Do'bli'g G,p R"'d, N''''''ill,. PennsYlVania, and is employed bY/as unknown. TROMAS L PULEo, b,;og doly 'w"," ""''''in8 I, I,w d,,,,,,,,, "'" "Y' "", .. "'f",","~,) I.", '" " th, Mill"", " N,,,. S,,,,,~ ,f ill, U"'''' S."" 0' ,,, Alii", ""b'OWI., Millin th, prn""o", of th, 801di,,,,, ,"d S"lo~' C;'il R'Ii'f A~ of Co_, ofJ 940, " ""'"'oil; SWORN TO AND SUBSCRIBED BEFORE ME THIS 6th DA Y (") c' (~ C N ..~ T\ ,s:: ~ -ocr:: (;., " rnn": '7~ r'o' "::""_.A 1'.) :z:~- (f.)",,:' 0, , " -<L_ ._J ~":: ~C) .. -f"1 .'):-...C~ =~:: . ~, C) ~() -="'--: ':? ";: .PC: ~, z =2 ,'" :Xi ,,,.. -< COMMONWEALTH OF PENNSYLVANIA COUNTY OF CUMBERLAND ATLANTIC MORTGAGE & INVESTMENT COURT OF COMMON PLEAS CORPORATION, a division of ABN AMRO Mortgage Group, Inc" Plaintiff, NO, 02-3307 Civil Term v, LEROY A, LUTHER and CAROLYN A, GElLING-LUTHER, his wife, Defendant( s), PRAECIPE FOR WRIT OF EXECUTION TO THE PROTHONOTARY: Issue Writ of Execution in the above matter: AMOUNT DUE $115,825,62 INTEREST FROM 8/22/02 @ $22.44 per diem $ COSTS TO BE ADDED $ 126,78 August 19,2002 ~ r- .[J 9? ~7t tL--~ r ~ 3 st ~. +- if ~ ~ r- ~~ v, ,--... o 0 D f-~ ,. - "'" ..... ""' ~..ogr~c.v~ ::') !-J '1 ' , . 0- h "'i} D ()C;O~& I () (\ C' \J I I I I I ~ - - ::: - ~ rr - - - - - - ~ ~ ~ ..:; -- ~ ..... . '9'-( DESCRIPTION ALL THAT CERTAIN tract of land with improvements thereon erected, situate in Lower Mifflin Township, Cumberland County, Pennsylvania, bounded and described in accordance with Plan of Subdivision for Gary E. Bobb, prepared by Larry Vern Neidlinger, Professional Engineer, on October 11, 1977, a draft of same being recorded in the hereinafter named Recorder's Office in Plan Book 31, page 120, as follows: BEGINNING at a point in the center of the public road leading from Newville to Doubling Gap at the comer of land now or formerly of Viola Annolt, and which point at the place of beginning is 157 feet Northwest from the comer of land now or formerly of Charles Spahr, measured along the center line of said public road; thence from said point at the place of beginning along said line of hl.lld now or formerly of Viola.M. Armolt, South 63 degrees 48 minutes West, a distance of 243.56 feet to a point in line of land now or formerly of Milton Walters; thence along said land now or formerly of Milton Walters, North 34 degrees 02 minutes West, a distance of 200.48 feet to an iron pin at the comer of Lot No 3 as shown on said Plan of Subdivision now or formerly of Cuisine Management Services, Inc.; thence along the Southern line of said Lot No. 1 now or formerly of Cuisine Management Services, Inc. and continuing along the Southern line of Lot No.2 as shown on said Plan of Subdivisions now or formerly of Cuisine Management Services, !pc" North 67 degrees 15 minutes East, a distance of 254.16 feet to a nail in'the center line of said public road leading from Newville to Doubling Gap; thence aiong the center line of said public road leading from Newville to Doubling Gap, the following three (3) courses and distances: (1) South 26 degrees 48 minutes East, a distance of 33,38 feet to a point; (2) South 32 degrees 12 minutes East, a distance of 113 feet to a point; (3) South 33 degrees 50 minutes East, a distance of 37.90 feet to a point at the place of beginning, CONTAINING 1.08 acre and being all of Lot No, 1 as shown on said Plan of Subdivision for Gary E. B!>bb, recorded as aforesaid, HAVING thereon erected a dwelling house known and numbered as 830 Doubling Gap Road, Newville, Pennsylvania. Tax #05-0413 Parcel #032B ,. ~ , C') c.::> 0 C N -n ;;:: ".. -0 CD C " mrr: G") r;;,;; Z:n N ~:m -.~ ;''1C.1 (n" 0' <.:~~~) _/ ". r~t,.-:} \:' .'::--1""1 < ~.;C; ::r ~('"5 ~Cj :;.? (jfll )>c: ~ .z: '0 'TI =< .~ =< LAW OFFICES OF PULEO & D'EMILIO 660 Sentry Parkway, Suite 210 Blue Bell, PAl 9422 (610) 941-3600 By: Thomas 1. Puleo, Esquire Identification No. 276 I 5 Attorney for PLAINTIFF IN THE COURT OF COMMON PLEAS OF CUMBERLAND COUNTY, PENNSYL VANIA CIVIL ACTION - LAW ATLANTIC MORTGAGE & INVESTMENT CORPORATION, a division of ABN AMRO Mortgage Group, Inc" NO, 02-3307 Civil Term Plaintiff v. LEROY A. LUTHER and CAROLYN A. GElLING-LUTHER, his wife, Defendant AFFIDAVITUNDERPA. RCP RULE 3129 THOMAS I. PULEO, attorney for Plaintiff in the above captioned mortgage foreclosure action, sets forth as of the date the praecipe for the Writ of Execution was filed, the following information concerning the real property located at 830 Doubling Gap Road, Newville, Cumberland County, Pennsylvania, was true and correct to the best of its knowledge, information and belief, I, Name and address of each Owner and/or Reputed Owner: Leroy A. Luther Carolyn A. Geiling-Luther 830 Doubling Gap Road Newville, PA 17241 2. Name and address of each Defendant named in the judgment: Leroy A, Luther Carolyn A, Geiling-Luther 830 Doubling Gap Road Newville, PA 17241 3, Name and last known address of every judgment creditor whose judgment is a record lien on the real property to be sold: None 4, Name and address of the last recorded holder of every mortgage of record: None other than executing mortgagee, 5, Name and address of every other person or entity which has any record lien on the property: None 6, Name and address of every other person or entity which has any record interest in the property and whose interest may be affected by the sale: Cumberland County Domestic Relations 13 N, Hanover Street Carlisle, P A 17013 Commonwealth ofPA Department of Public Welfare p, 0, Box 2675 Harrisburg, PA 17105 7, Name and address of every other person of whom lhe Plaintiff has knowledge who may have an interest in the property which may be affected by the sale: None I verilY that the statements made in this Affidavit are true and correct to the best of my personal knowledge, information and belief. I understand that false statements herein are made subject to the penalties of 18 Pa.C,S, Section 4904 relating to unsworn falsification to authorities, Date: August 19,2002 OMAS I. PU EO, ESQUIRE Attorney for Plaintiff (") <:::> 0 c: N " s:: :!> ._j -Ow .:= T ;q mnl :;~.., Z:r) 1',) -;",1 i....n Z~: '--', (j) "C. 0-' '( -/ - ~-j r::~c u -11 ):'-: C -",. , (') ~..", ....::;.- ~.- (~; ,.. j":~ c.: S,,;"l ~:~ ~"'-- .'0 -:':.J ::;J ,.,. =< LAW OFFICES OF PULEO & D'EMILIO 660 Sentry Parkway, Suite 210 Blue Bell, P A 19422 (610) 941-3600 By: Thomas 1. Puleo, Esquire Identification No. 27615 Attorney for PLAINTIFF IN THE COURT OF COMMON PLEAS OF CUMBERLAND COUNTY, PENNSYL VANIA CIVIL ACTION - LAW ATLANTIC MORTGAGE & INVESTMENT: CORPORATION, a division of ' ABN AMRO Mortgage Group, Inc" Plaintiff NO, 02-3307 Civil Term v. LEROY A. LUTHER and ! CAROLYN A. GElLING-LUTHER, his wife, i Derendant I NOTICE OF SHERIFF'S SALE OF REAL PROPERTY TO: Leroy A, Luther Carolyn A, Geiling-Luther 830 Doubling Gap Road Newville, PA 17241 Your house at 830 Doubling Gap Road, City of Newville, Cumberland County, is scheduled to be sold by the Cumberland County Sheriffs Department to enforce the Court judgment of$115,825,62 obtained by Plaintiff Ailanlic Mortgage & Investment Corporation, a division of ABN AMRO Mortgage Group, Inc, against you, The Sheriffs Sale will be conducted on Wednesday, December 4,2002, at 10:00 A.M" Cumberland County Courthouse, 2nd Floor, Commissioner's Hearing Room, Carlisle, Pennsylvania, NOTICE OF OWNERS' RIGHTS YOU MAYBE ABLE TO PREVENT THIS SHERIFF'S SALE To prevent this Sheriff's Sale, you must take immediate action: I. This sale will be canceled if you pay to Atlantic Mortgage & Investment Corporation, a division of ABN AMRO Mortgage Group, Inc, the back payments, late charges, costs and reasonable attorneys' fees due, To find out how much you must pay, you may call (610) 941-3600, 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 below 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, I, If the Sheriff's Sale is not stopped, your property will be sold to the highest bidder, You may find out the price bid by calling the Cumberland County Sheriff's Department at (717) 240-6390, 2, You may be able to petition the Court to set aside the sale if the bid price was grossly inadequate compared 10 the value of your property, 3, The sale will go through only if the buyer pays the Sheriff the full amount bid in the sale, To find out if this has happened, you may call the Cumberland County Sheriff's Department at (717) 240-6390, 4, If the amount due from the buyer is not paid to lhe Sheriff, you will remain the owner of the property as if the sale had 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 Cumberland County Sheriff on or about thirty (30) days from the date of Sheriff's 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 sheet is posted, 7, You may also have other rights and defenses, or ways of getting your house 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 BELOW TO FIND OUT WHERE YOU CAN GET LEGAL HELP, Court Administrator 4th Floor, Cumberland County Courthouse Carlisle, P A 17013 (717) 240-6200 C"') 0 0 C r......) " 1 Z "'" I ;:;t,"i3 c:: , :~ r'" c,-, ~:~:, f'.) , " (f'L,. 0-.' ",)0 ::.t.,.. ,-,;.C! r--. G -" -< -...i ~ r-._' !..2 E,) " () .,:::- IP j> ~? i..1 ~ .-\ ~ ." ?Ii ,r;- -< DESCRIPTION . ALL. THAT CERTAIN tract of land with improvements thereon erected, situate in Lower Mifflin Township, Cumberland County, Pennsylvania, boUnded and described in accordance with Plan of Subdivision for Gary E. Bobb, prepared by Larry Vern Neidlinger, Professional Engineer, on October II, 1977, a draft of same being recorded in the hereinafter named Recorder's Office in Plan Book 31, page 120, as foJJows: BEGINNING at a point in the center of the public road leading from NeWVille to Doubling Gap at the comer of land now or fonnerly of Viola Annolt, and which point at the place of beginning is 157 feet Northwest from the comer of land now or fonnerly of Charles Spahr, measured along the center line of said public road; thence from said point at the place of beginning along said line of land now or fonnerly of ViolaM, Annolt, South 63 degrees 48 minutes West, a distance of 243.56 feet to a point in line of land now or fonnerly of Milton Walters; thence along said land now or fonnerly of Milton Walters, North 34 degrees 02 minutes West, a distance of 200.48 feet to an iron pin at the comer of Lot No 3 as shown on said Plan of Subdivision now or fonnerly of Cuisine Management Services, Inc.; thence along the Southern line of said Lot No, I now or fonnerly of Cuisine Management Services, Inc. and continuing along the Southern line of Lot No, 2 as shown on said Plan of Subdivisions now or fonnerly of Cuisine Management Services, Inc" North 67 degrees 15 minutes East, a distance of254,16 feet to a nail in the center line of said public road leading from NeWVille to Doubling Gap; thence along the center line of said public road leading from NeWVille to Doubling Gap, the foJJowing three (3) courses and distances: (I) South 26 degrees 48 minutes East, a distance of 33,38 feet to a point; (2) South 32 degrees 12 minutes East, a distance of 113 feet to a point; (3) South 33 degrees 50 minutes East, a distance of 37,90 feet to a point at the place of beginning. CONTAINING 1.08 acre and being all of Lot No. I as shown on said Plan of Subdivision for Gary E. Bpbb, recorded as aforesaid, HAVING thereon erected a dwelling house known and numbered as 830 Doubling Gap Road, Newville, Pennsylvania, Tax #05-0413 Parcel #032B WRIT OF EXECUTION and/or ATTACHMENT COMMONWEALTH OF PENNSYLVANIA) COUNTY OF CUMBERLAND) NO 02-3307 Civil CIVIL ACTION - LAW TO THE SHERIFF OF CUMBERLAND COUNTY: To satisfy the debt, interest and costs due ATLANTIC MORTGAGE & INVESTMENT CORPORATION, A DIVISION OF ABN AMRO MORTGAGE GROUP, INC" Plaintiff (s) From LEROY A. LUTHER AND CAROLYN A, GElLING-LUTHER, 830 DOUBLING GAP ROAD, NEWVILLE, PA 17241 (I) 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) Ifproperty 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 himlher that he/she has been added as a garnishee and is enjoined as above stated. Amount Due $115,825.62 Interest FROM 8/22/02 @ $22.44 PER DIEM Atty's Comm % Ally Paid $129.28 Plaintiff Paid Date: AUGUST 26, 2002 L.L. $.50 Due Prothy $1.00 Other Costs $126.78 CURTIS R. LONG (Seal) Prothonotary '-BY: aO/k 11 r Deputy ry'/?/24)(< ;---- REQUESTING PARTY: Name THOMAS I. PULEO, ESQUIRE Address: 660 SENTRY PARKWAY, SUITE 210 BLUE BELL, PA 19422 Attorney for: PLAINTIFF Telephone: 610-941-3600 Supreme Court ill No. 27615 LAW OFFICES OF PULEO & D'EMILIO 660 Sentry Parkway, Suite 210 Blue Bell, PA 19422 (610) 941-3600 By: Thomas I. Puleo, Esquire Identification No, 27615 Attorney for PLAINTIFF IN THE COURT OF COMMON PLEAS OF CUMBERLAND COUNTY, PENNSYL VANIA CIVIL ACTION - LAW ATLANTIC MORTGAGE & INVESTMENT CORPORATION, a division of ABN AMRO Mortgage Group, Inc., NO. 02-3307 Civil Term Plaintiff v. LEROY A. LUTHER and I CAROLYN A. GElLING-LUTHER, his wife, 1 Defendant I AFFIDAVIT OF SERVICE I, Lucy Fuentes, Legal Assistant to Thomas I. Puleo, Esquire, attorney for plaintiff, being duly sworn according to law, deposes and says that he mailed by ordiI).ary mail a Notice of Sale pursuant to Pa.R.C.P 3129.2 upon the persons listed below on theJJ51" day of~/()6"I, 2002 as evidenced by the U.S. Postal Service Certificate of Mailing (Form 3817), which is attached hereto as Exhibit "A"; Cumberland County Domestic Relations 13 N. Hanover Street Carlisle,PA 17013 Commonwlealth ofPA Department of Public Welfare P. O. Box 2675 Harrisburg, P A 171 05 ~) ~ '-. . , C/t .' -:Il~? we FUEN~, Legal ",1_, to Thomas I. Puleo SWORN TO AND SUBSCRIBED BEFORE ME THIS3\"-\" DAY OF 0 cJw'O..if , 2002. For Accountable Mail 'U "'ll Cd ..... ..... ..... ..... ..... ..... r 9.>f C/l <.n ~ eN f\) ..... 0 co co -.J 0> <.n ~ eN f\) ..... s- "T1 21S' .. f8:3 0 ~z 3 ;,i. .!lc: l:l. "' Co) ",3 ..i ~ !i I" ..... 0.0 ~~ CD_ - ~" !~ ~ "T1 ~ 39. 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Geiling- Luther In The Court of Common Pleas of Cumberland County, Pennsylvania Writ No. 2002-3307 Civil Term R. Thomas Kline, Sheriff, who being duly sworn according to law, states this writ is returned STAYED pursuant to instructions from Attorney Thomas Puleo. Sheriffs Costs: Docketing Surcharge Advertising Posting Bills Law Library Prothonotary Mileage Levy Certified Mail Law Journal Patriot News Poundage Postpone Sale Share of Bills 30.00 30.00 15.00 15.00 .50 1.00 17.94 15.00 5.11 404.90 299.35 17.58 20.00 25.20 $ 896.58 paid by attorney 03/06/03 Sworn and subscribed to before me So Answers: r~~<~ This /02 eday of --fvt.LuJ.....J ~ R. Thomas Kline, Sheriff 2003, A.D. 11.t , f2 )vuJp.{,--/ i AIL.~ S. ~ i f7 BY h..~ VVttAY\ Real Es~e Deputy Prothonotary J. :)D UL l{ 0-00 Y Ru... /355'0 f PROOF OF PUBLICATION OF NOTICE IN CUMBERLAND LAW JOURNAL (Under Act No. 587, approved May 16, 1929), P. L.1784 STATE OF PENNSYLVANIA: ss. COUNTY OF CUMBERLAND : Roger M. Morgenthal, Esquire, Editor ofthe 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 ofthe said Cumberland Law Journal on the following dates, VIZ: OCTOBER 25, NOVEMBER 1, 8, 2002 Affiant further deposes that he is authorized to verify this statement by the Cumberland Law Journal, a legal periodical of general circulation, and that he is not interested in the subject matter of the aforesaid notice or advertisement, and that all allegations in the foregoing statements as to time, place and character of publication are true. REAL ESTATE SALE NO. 14 Writ No. 2002-3307 Civil Atlantic Mortgage & Investment Corporation, a division of ABN AMRO Mortgage Group. Inc. vs. Leroy A Luther and Carolyn A Gelling-Luther Atty.: Thomas 1. Puleo DESCRIPTION ALL TIlAT CERTAIN tract of land with improvements thereon erected. situate in Lower Mifflin Township. Cumberland County. Pennsylvania. bounded and described in accor- dance with Plan of Subdivision for Gary E. Bobb, prepared by Larry Vern Neidlinger, Professional Engi- neer, on October 11. 1977. a draft of same being recorded in the here- inafter named Recorder's Office in Plan Book 31. page 120, as follows: BEGINNING at a point in the cen- ter of the public road leading from Newville to Doubling Gap at the cor- ner of land now or formerly of Viola Annolt. and which point at the place of beginning i3 157 feet Northwest from the corner of land now or for- merly of Charles Spahr. measured ~Editor--- SWORN TO AND SUBSCRIBED before me this 8 day of NOVEMBER. 2002 N SEAl LOIS E ~~~!n.-:;"~ f\!."taly PublIc "'--::1<,:~,.,,'.' 'J. ,"n .'....::..;.:::.;'..,::~....,.,~ ~ \A.U h...,:.::; .. t"..,,~ ~" - -_"!-~, ""I' lU UuCo.~ae,;;f';',,, ~:,;;,:;~;',,;';~...._A. 5 '"I Inn~....~. I ~~""~H~il:I flS'Ni'UWI , along the center line of said public road; thence from said point at the place of beginning along said line of land now or formerly of Viola M. Annolt, South 63 degrees 48 min- utes West. a distance of 243.56 feet to a point in line of land now or for- merly of Milton Walters; thence along said land now or formerly of Milton Walters. North 34 degrees 02 min- utes West. a distance of 200.48 feet to an iron pin at the corner of Lot No 3 as shown on said Plan of Sub- division now or formerly of Cuisine Management Services, Inc.: thence !:lIlnnt1' th.... c;;:."uf........."........... 1.;.......... ~~ ~_.:..J T _.L ~ -- 01 beginnIng i3 157 feet Ncrthv~"est from the corner of land now or for merly of Charles Spahr. measured - along the center line of said public road; thence from said point at the place of beginning along said line of land now or formerly of Viola M, Annolt. South 63 degrees 48 min- utes West, a distance of 243,56 feet to a point in line of land now or for- merly of Milton Walters: thence along said land now or formerly of Milton Walters. North 34 degrees 02 min- utes West, a distance of 200.48 feet to an iron pin at the corner of Lot No 3 as shown on said Plan of Sub- division now or formerly of Cuisine Management Services. Inc.; thence along the Southern line of said Lot No. I now or fonnerIy of Cuisine Man- agement Services, Inc. and continu- ing along the Southern line of Lot No. 2 as shown on said Plan of Sub- divisions now or formerly of Cuisine Management Services. Inc., North 67 degrees 15 minutes East, a dis- tance of 254,16 feet to a nail in the center line of said public road lead- ing from Newville to Doubling Gap: thence along the center line of said public road leading from NeWViIIe to Doubling Gap. the following three (3) courses and distances: (1) South 26 degrees 48 minutes East, a dis- tance of 33.38 feet to a point; (2) South 32 degrees 12 minutes East. a distance of 113 feet to a point: (3) South 33 degrees 50 minutes East, a distance of 37.90 feet to a point at the place of beginning, CONTAINING 1.08 acre and be- ing all of Lot No. 1 as shown on said Plan of Subdivision for Gary E. Bobb. recorded as aforesaid. HAVING thereon erected a dwell- ing house known and numbered as 830 Doubling Gap Road. Newville. Pennsylvania, Tax #05-0413 Parcel #032B, ~ 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 S ALE #14 Notarial Seal Teny L. Russell, Notary Public CIty Of Harrisburg, Dauphin County My CommiSSiOO ExpIres Jl.Ile 6, 2006 Member. Pennsylvania AssoCiation Of Notaries NO ARY PUBLIC My commission expires June 6, 2006 CUMBERLAND COUNTY SHERIFFS OFFICE CUMBERLAND COUNTY COURTHOUSE CARLISLE, PA. 17013 Statement of Advertising Costs To THE PATRIOT-NEWS CO., Dr. For publishing the notice or publication attached hereto on the above stated dates $ Probating same Notary Fee(s) $ Total $ 297.60 1.75 299.35 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...... ......... ...... ........ ............. .......... ................ ~ LAW OFFICES OF PULEO & D'EMILIO 660 Sentry Parkway, Suite 2] 0 Blue Bd1, PA 19422 (6I'J) 941-3600 By: Thomas 1. Puleo, Esquire Identification No. 27615 Attorney for PLAINTIFF IN THE COURT OF COMMON PLEAS OF CUMBERLAND COUNTY, PENNSYLVANIA CIVIL ACTION - LAW ATLANTIC MORTGAGE & INVESTMENT i CORPORATION, a division of : ABN AMRO Mortgage Group, Inc., i NO, 02-3307 Civil Term Plaintiff v. LEROY A, LUTHER and CAROLYN A, GElLING-LUTHER, his wife, , Defendant : AFFIDAVIT OF SERVICE I, Lucy Fuentes, Legal Assistant to Thomas 1. Puleo, Esquire, attorney for plaintiff, being duly sworn according to law, deposes and says that he mailed by ordinary mail a Notice of Sale pursuant to Pa,R,C,P 3129,2 upon the persons listed below on the J l~ay of)1(){[try ,2005 as evidenced by the U,S, Postal Service Certificate of Mailing (Form 3817), which is attached hereto as Exhibit "A": Cumberland County Domestic Relations 13 N, Hanover Street Carlisle, PA 17013 Commonwealth ofPA Department of Public Welfare p, 0, Box 2675 Harrisburg, PA 17105 ii~~ ~. A; Lucy Fuen , Legal assistant to Thomas 1. Puleo SWORN TO AND SUBSCRIBED BEFQREME THI 7!-,j)AY O~p~: . ru' 2005,. ~ /7' . ,/ lJ-i Ll h--'-- OTARY PUBLIC LISA", " Whltp,," ' h My Comm;,' :,cAL ili!ary PubUc PI:'l~D;~~ for ~ccoun\ab\e N\aU ~i\ c ~ '" .... :> ..... ..... .... co (1\ "'" Ci> .. ..... ..... ..... 0 <!> <J;/ -0 . <;<1 ..... Ci> '" ..... ih ()) (1\ "'" .., %,1;. ~"'" Q, z .. 3 ~\ %i ~ ~ ,,- ~ t-..., ':::i \:6:9.- 'l1> ~ -1 " .., 'f ~ ~ ","'';; P"':.: , c: ,,0 ~ "'",0 'Z:... ~ ~:O~ ~ ",,,,,,; t 0>-'.( 0 '" p ,,; ".... p"..... \\ li 9 ~ ~<.>>~o !:""'~ ~ 8.~ p:,?~% , '" ljj~ 0 r.e.. ~t/l ",,,, " ;\ ~ 0 ~ o ';!. '2 cr. \>>"~~ ~ t->~f; -><j ~ ~ ~ ~ ~~'" ('0\\ ~ ':l ~.~ ';1>-: 0 \ t~ fl 1'\ ~ 0 ~ \ \ V''2 -J ... '"' "'" '" ~ ~\ o '(j) ~. 0 >-,l:t g '" <'>>0 ()) \11 " (<'> ~ 0 .. ':;0 ~ ..." r- '" ~ -0 0 ::r> 'l "''! ~ ';:;; 0 0 -0 \ ~ ~ ""'r ~~' (0 i Os . g~ ." \ b ~ ~ z ~ " . .. i ~ ~gdl \ a '" U2: :n ~ !~ t h1& s. :> !!1"iS~~ ., -0 ~~- s. ~ o -fG , .." 3 :2 '& ~~\t "\ '< ~t .. ~ -a. 111"9- ~ .. 0" ~ .. ,.. ~ i~~~\i o{PO:ll Cl II ~ ~~~ Gl g ~ ~ ~~~~>< ~ \,"1 %0:\ 6"1\'2..\ o ~ lh "'\1 ; a ~'~Pl\~ If - ~ ~ \; ... If \t 9. ~~ % \ ~ , ~l \\\\ ~~~ ~ ~ ~\~1i59.~ ,,5' G - ~t 2. - h\\il~ ~~~l ..! ,..\. .':- -'" ",.,. h i9..'; a'~ "iii9U~ ~rf) ;;t '$)(. lO:\\%\' ~i . r-.. -1 ~ " i"f~~ 1" g~ \\~ $<1> a ~' ~~~\wi 0 'I\> ~ .;. hi"St ~!i :n ""I ~<1>. " l" <Ci>liJ> a ~. ~ \ g~t3-t~ i'~~' .,.J ~...%~~ ~ 'CD 3'S9 ~ \!\\~ r''';' l.." ~'<J. \oJ \ 0 19.\~~~ " r',~' . .. \ ~h\b ~ co:> , (';l t \hgg~ ' \..1'1 g "\ , ~~\n, \ /~~~~~ ',I .-\ \ ".:) r~~~ 0' r.....1 / "''''' COMMONWEALTH OF PENNSYL VANIA COUNTY OF CUMBERLAND ATLANTIC MORTGAGE & INVESTMENT CORPORATION, a division of ABN AMRO Mortgage Group, Ine" Plaintiff, COURT OF COMMON PLEAS NO. 02-3307 Civil Term v, LEROY A. LUTHER and CAROLYN A, GElLING-LUTHER, his wife, Defendant(s). PRAECIPE FOR WRIT OF EXECUTION TO THE PROTHONOTARY: Issue Writ of Exeeution in the above matter: AMOUNT DUE $115,825,62 INTEREST FROM 8/22/02 @ $22.44 per diem $ COSTS TO BE ADDED $ 1,038,36 November 23, 2004 HOMAS 1. ULEO, ESQUIRE Attorney for Plaintiff r0 9- ~ - Q C) (::l 1{fl ~ ~ ~ + ~ --.J r ~ s ? 1- ~ ~ ~ ~ 0';) w - ..() - ~ V( \) V\~{"". \) \,oJ -..n 0, '\1' ~ (', "<;) Ir\. ''1\ vt Q "0 V \)J '\)\JC"'<:> \ \ G'"" C' C '\ ()"'V , \ \ \ :: :::~r - - _ -, -, ~ 0 ~ ,...., 0 c;:'':.I -0 C""~ _>\ .;,... :=r:~ ~,t,__ -11'1"~ C::.) m .-:. ~~~j C? (;,') <::) C) O'r[~~, ~? t~~; - -~ ...0 ,./ . . .. - . . IN THE UNITED STATES BANKRUPTCY COURT FOR THE MIDDLE DISTRICT OF PENNSYL VANIA In re: : Chapter \3 LEROY A. LUTHER and Bankruptcy No, 1 - 02-0652I-MDF CAROLYN A, GElLING-LUTHER: Debtors ORDER AND NOW, this ~jQ., day of J~ ,2004, upon consideration of the Motion of ABN AMRO Mortgage Group, Inc" formerly known as Atlantic Mortgage & Investment Corporation, for relief from stay pursuant to 1 I U,S,C, Section 362, and good cause having been shown, it is ORDERED that the automatic stay is terminated as to Movant which may proceed to enforce its mortgage by foreclosure and sheriffs sale of the premises 830 Doubling Gap Road, Newville, Pennsylvania, and exercise any other rights and remedies it has under the mortgage, By the Court: '...............":'....' ""',"",", /) j. '"Y'''~''~''''- Honorabl~ MMfD,h~ce~.6'lt. United Sthtes 'Bankruptcy Judge Mr, Leroy A. Luther 830 Doubling Gap Road Newville, P A 17241 I FIL!,D ""~~~,. I NfW-~--'1 I . .. ,J~' i. ~;-:-7-;--;' ..." ,.~; ',' .. ! <.J.,rk, !J.B, ,,,.," . ,t ,PE'r ~._......_ 1.~"'Jn~ C~lk -~~......,..,...- ....:;.__":".:."..:.;..._. '~ Ms. Carolyn A. Geiling-Luther 830 Doubling Gap Road Newville, PA 17241 Paul Bradford Orr, Esquire 50 East High Street Carlisle, PAl 70 1 3 Charles 1. DeHart, III, Esquire P.O, Box 410 Hwnme]stOWll, P A 17036 {I WRIT OF EXECUTION andlor ATTACHMENT COMMONWEALTH OF PENNSYLVANIA) COUNTY OF CUMBERLAND) NO 02-3307 Civil CIVIL ACTION - LAW TO THE SHERIFF OF CUMBERLAND COUNTY: To satisfy the debt, interest and costs due ATLANTIC MORTGAGE & INVESTMENT CORPORATION, A DIVISION OF ABN AMRO MORTGAGE GROUP, INC., Plaintiff(s) From LEROY A. LUTHER AND CAROLYN A, GElLING-LUTHER, HIS WIFE (1) You are directed to levy upon the property of the defendant (s)and to selI 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 himlher that he/she has been added as a garnishee and is enjoined as above stated. Amount Due $1l5,825.62 Interest FROM 8/22/02 @ $22.44 PER DIEM Atty's Comm % Ally Paid $1038.36 Plaintiff Paid Date: NOVEMBER 30, 2004 L.L. Due Prothy $1.00 Other Costs CURTIS R. LONG (Seal) protho,& ~ O/l. r;7, p. 7fOZ/J/Y-c/ Deputy REQUESTING PARTY: Name THOMAS I. PULEO, ESQUIRE Address: 660 SENTRY PARKWAY, SUITE 210 BLUE BELL, PA 19422 Attorney for: PLAINTIFF Telephone: 610-941-3600 Supreme Court 1D No. 27615 ... \ LAW OFFICES OF PULEO & D'EMILIO 660 Sentry Parkway, Suite 2\ 0 Blue Bell, P A 19422 (610) 941-3600 By: Thomas 1. Puleo, Esquire Identification No. 27615 Attorney for PLAINTIFF IN THE COURT OF COMMON PLEAS OF CUMBERLAND COUNTY, PENNSYLVANIA CIVIL ACTION - LAW ATLANTIC MORTGAGE & INVESTMENT: CORPORA TION, a division of i ABN AMRO Mortgage Group, Inc" NO, 02-3307 Civil Term Plaintiff v. LEROY A. LUTHER and i CAROLYN A, GElLING-LUTHER, his wife, : Defendant i AFFIDA VIT UNDERPA, RCP RULE 3129 THOMAS 1. PULEO, attorney for Plaintiff in the above captioned mortgage foreclosure action, sets forth as ofthe date the praecipe for the Writ of Execution was filed, the following information concerning the real property localed at 830 Doubling Gap Road, Newville, Cumberland County, Pennsylvania, was true and correct to the best of its knowledge, information and belief, I, Name and address of each Owner and/or Reputed Owner: Leroy A, Luther Carolyn A, Geiling-Luther 830 Doubling Gap Road Newville, PA 17241 2. Name and address of each Defendant named in the judgment: Leroy A, Luther Carolyn A, Geiling-Luther 830 Doubling Gap Road Newville, PA 17241 - . 3. Name and last known address of every judgment creditor whose judgment is a record lien on the real property to be sold: None 4, Name and address of the last recorded holder of every mortgage of record: None other than executing mortgagee. 5, Name and address of every other person or entity which has any record lien on the property: None 6. Name and address of every other person or entity which has any record interest in the property and whose interest may be affected by the sale: Cumberland County Domestic Relations 13 N. Hanover Street Carlisle, PA 17013 Commonwealth ofPA Department of Public Welfare p, 0, Box 2675 Harrisburg, P A 17105 7. Name and address of every other person of whom the Plaintiff has knowledge who may have an interest in the property which may be affected by the sale: None I verify that the statements made in this Affidavit are true and correct to the best of my personal knowledge, information and belief. I understand that false statements herein are made subject to the penalties of 18 Pa,C.S, Section 4904 relating to unsworn falsification to authorities. Date: November 23, 2004 ~AZ -mOMAS 1. PUrEO, ESQUIRE Attorney for Plaintiff ...-' c:;:~ 0 c.;::::J -n f-- -:''l'~ 1:;5 ..:: (",) C;J cS \.C,> -- - ~ LAW OFFICES OF PULEO & D'EMILIO 660 Sentry Parkway, Suite 210 Blue Bell, P A 19422 (610) 941-3600 By: Thomas 1. Puleo, Esquire Identification No. 27615 Attorney for PLAINTIFF IN THE COURT OF COMMON PLEAS OF CUMBERLAND COUNTY, PENNSYLVANIA CIVIL ACTION - LAW ATLANTIC MORTGAGE & INVESTMENT CORPORATION, a division of ABN AMRO Mortgage Group, Inc" Plaintiff NO, 02-3307 Civil Term v. LEROY A, LUTHER and CAROLYN A, GElLING-LUTHER, his wife, Defendant NOTICE OF SHERIFF'S SALE OF REAL PROPERTY TO: Leroy A. Luther Carolyn A. Geiling-Luther 830 Doubling Gap Road Newville, PA 17241 Your house at 830 Doubling Gap Road, City of Newville, Cumberland County, is scheduled to be sold by the Cumberland County Sheriffs Department to enforce the Court judgment of $115,825.62 obtained by Plaintiff Atlantic Mortgage & Investment Corporation, a division of ABN AMRO Mortgage Group, Inc, against you, The Sheriffs Sale will be conducted on Wednesday, March 2, 2005, at 10:00 A,M" Cwnberland County Courthouse, 2nd Floor, Commissioner's Hearing Room, Carlisle, Pennsylvania. NOTICE OF OWNERS' RIGHTS YOU MAY BE ABLE TO PREVENT THIS SHERIFF'S SALE To prevent this Sheriffs Sale, you must take immediate action: 1. This sale will be canceled if you pay to Atlantic Mortgage & Investment Corporation, a division of ABN AMRO Mortgage Group, Inc. the back payments, late charges, costs and reasonable attorneys' fees due, To find out how much you must pay, you may call (610) 941-3600, 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 below 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 the Cumberland County Sheriffs Department at (717) 240-6390, 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 ifthe buyer pays the Sheriffthe full amount bid in the sale, To find out if this has happened, you may call the Cumberland County Sheriffs Department at (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 had 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 Cumberland County Sheriff on or about thirty (30) days from the date of Sheriffs 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 sheet is posted, . 7, You may also have other rights and defenses, or ways of getting your house 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 BELOW TO FIND OUT WHERE YOU CAN GET LEGAL HELP, Court Administrator 4th Floor, Cumberland County Courthouse Carlisle, P A 17013 (717) 240-6200 DESCRIPTION . ALL THAT CERTAIN tract of land with improvements thereon erected, situate in Lower Mifflin Township, Cumberland County, Pennsylvania, bounded and described in accordance with Plan of Subdivision for Gary E, Bobb, prepared by Larry Vern Neidlinger, Professional Engineer, on October 11, 1977, a draft of same being recorded in the hereinafter named Recorder's Office in Plan Book 31, page 120, as follows: BEGINNING at a point in the center of the public road leading from Newville to Doubling Gap at the comer of land now or formerly of Viola Armolt, and which point at the place of beginning is 157 feet Northwest from the corner of land now or formerly of Charles Spahr, measured along the center line of said public road; thence from said point at the place of beginning along said line of land now or formerly of ViolaM. Armolt, South 63 degrees 48 minutes West, a distance of 243,56 feet to a point in line of land now or formerly of Milton Walters; thence along said land now or formerly of Milton Walters, North 34 degrees 02 minutes West, a distance of 200.48 feet to an iron pin at the corner of Lot No 3 as shown on said Plan of Subdivision now or formerly of Cuisine Management Services, Inc.; thence along the Southern line of said Lot No, 1 now or formerly of Cuisine Management Services, Inc, and continuing along the Southern line of Lot No. 2 as shown on said Plan of Subdivisions now or formerly of Cuisine Management Services, Inc" North 67 degrees 15 minutes East, a distance of 254 ,16 feet to a nail in' the center line of said public road leading from Newville to Doubling Gap; thence along the center line of said public road leading from Newville to Doubling Gap, the following three (3) courses and distances: (1) South 26 degrees 48 minutes East, a distance of 33.38 feet to a point; (2) South 32 degrees 12 minutes East, a distance of 113 feet to a point; (3) South 33 degrees 50 minutes East, a distance of 37,90 feet to a point at the place of beginning, CONTAINING 1.08 acre and being all of Lot No, 1 as shown on said Plan of Subdivision for Gary E. Bpbb, recorded as aforesaid, HAVING thereon erected a dwelling house known and numbered as 830 Doubling Gap Road, Newville, Pennsylvania. Tax #05-0413 Parcel #032B "'" ~:~:> C";:' ""- c:~ -.;;;: (,c," C::.::J (5 Q. ,-\ ;,: -<1 I 11 r;"'~ -("11""1\ -be) \;'-':~{S ".~C -i'". ("~~ ~~,~ ~")IT1 '::"~ ~~ ,0 --- /'.;). 330 l COMMONWEALTH OF PENNSYLVANIA COUNTY OF CUMBERLAND } SS: I, Robert p, Ziegler, Recorder of Deeds in and for said County and State do hereby ce ify that the Sheriffs Deed in which Sectetarv of Veterans Affairs is the grantee the same having bee sold to said grantee on the 2nd day of March A.D" 2005, under and by virtue of a writ Execution iss ed on the 30th day of Nov, A.D" 2004, out of the Court of Common Pleas of said County as of Civil T , 2002 Number 3307, at the suit of Atlantic Mtg & Inv Corp against Lero A Luther & Carol Luther is duly recorded in Sheriffs Deed Book No. 268, Page 296. IN TESTIMONY WHEREOF, I have hereunto s t my hand and seal of said office this ~3 day of tv'U"<..-(l., ,A,D. ;ADOS '"rv RllCOId.. 01 Deeds, Cumborlllnd County, ea.tJoIe, PA My CommlSSion ElqlIr.. the First MondaV of Jon. 2llOt of Deeds Atlantic Mortgage & Investment Corp, VS Leroy A. Luther and Carolyn A. Geiling-Luther The Court of Common Pleas of Cumberland County, Pennsylvania Writ No, 2002-3307 Civil Term Gerald Worthington, Deputy Sheriff, who being duly sworn according to law, states that on December 16, 2004 at 5:00 o'clock PM, he served a true copy of the with n Real Estate Writ, Notice of Sheriffs Sale and Description, in the above entitled action, upon the within named defendants, to wit: Leroy A. Luther and Carolyn A, Geiling- Luther, by making known unto Carolyn Luther, personally and adult in charge for Lero A. Luther, at 830 Doubling Gap Rd" Newville, Cumberland County, Pennsylvania, its contents and at the same time handing to her personally the said true and correct copy the same, Kurt Haag, Deputy Sheriff, who being duly sworn according to law, states that n January 03, 2005 at 10:56 o'clock A,M" he posted a true copy of the within Real Estat Writ, Notice, Poster and Description, in the above entitled action, upon the property of Leroy A, Luther and Carolyn A, Geiling-Luther, located at 830 Doubling Gap Road, Newville, Pennsylvania, according to law. R. Thomas Kline, Sheriff, who being duly sworn according to law, states 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 the within named defendants, to wit: Leroy A, Luther and Carolyn A. Geiling-Luther, by regular mail to their last known address of 830 Doubling Gap Road, Newville, P A 17241. These letter were mailed under the date of December 29,2004 and never returned to the Sheriffs Office, R, Thomas Kline, Sheriff, who being duly sworn according to law, states that after due and legal notice had been given according to law, he exposed the within described premises at public venue or outcry at the Courthouse, Carlisle, Cumberland County, Pennsylvania on March 02, 2005 at 10:00 o'clock A.M. He sold the same for t e sum of $1,00 to Attorney Thomas I. Puleo for Secretary of Veterans Affairs, his successors and assigns. It being the highest bid and best price received for the same, Secretary of Veterans Affairs, his successors and assigns of Wissahickon A venue & Manheim Streets, P,O, Box 8079, Philadelphia, P A 19101, being the buyers in this execution, paid to SheriffR. Thomas Kline the sum of$I,046,23, it being costs. Sheriffs Costs: Docketing Poundage Posting Bills Advertising Acknowledging Deed Auctioneer Law Library $30,00 20,51 15.00 15,00 30,00 10,00 bt. J. F / '. ,JA 1'1 b ~ 'l I yO t) I /q r.'-t Prothonotary Mileage Certified Mail Levy Surcharge Law Journal Patriot News Share of Bills Distribution of Proceeds Sheriffs Deed 1.00 17,76 8,84 15,00 30,00 381.65 376.26 30,73 25,00 39.50 $ 1046,23 Sworn and subscribed to before me so~ ~ ~ '-~~_Y' ~ This .3.L- day of '1Y\a..-< d.... R. Thomas Kline, Sheriff 2005,A'D,~,.J.:1'fI.e<.L." ~ ) ~j~ Prothonotary 'BY "- a Real Estate eputy ,r . LAW OFFICES OF PULEO & D'EMILIO 660 Sentry Parkway, Suite 210 Blue Bell, PA ]9422 (610) 941-3600 By: Thomas I. Puleo, Esquire Identification No. 27615 (0) 0 If. ~ If'' Attorney for PLAINTIFF IN THE COURT OF COMMON PLEAS OF CUMBERLAND COUNTY, PENNSYL V A IA CIVIL ACTION - LAW ATLANTIC MORTGAGE & INVESTMENT: CORPORATION, a division of i ABN AMRO Mortgage Group, Inc" : NO. 02-3307 Civil Term Plaintiff I v. LEROY A, LUTHER and CAROLYN A. GElLING-LUTHER, his wife, : Defendant ' AFFIDAVIT UNDER P A, RCP RULE 3129 THOMAS 1. PULEO, attorney for Plaintiff in the above captioned mortgage fored sure action, sets forth as of the date the praecipe for the Writ of Execution was filed, the follow g information concerning the real property located at 830 Doubling Gap Road, Newville, Cumberland County, Pennsylvania, was true and correct to the best of its knowledge, info ation and belief, I, Name and address of each Owner and/or Reputed Owner: Leroy A. Luther Carolyn A, Geiling-Luther 830 Doubling Gap Road Newville, P A 17241 2. Name and address of each Defendant named in the judgment: Leroy A, Luther Carolyn A, Geiling-Luther 830 Doubling Gap Road Newville, P A 17241 f 3. Name and last known address of every judgment creditor whose judgment is a record lien on the real property to be sold: None 4, Name and address of the last recorded holder of every mortgage of record: None other than executing mortgagee, 5, Name and address of every other person or entity which has any record lien on the property: None 6, Name and address of every other person or entity which has any record interest in t e property and whose interest may be affected by the sale: Cumberland County Domestic Relations 13 N. Hanover Street Carlisle, PA \70\3 Commonwealth of P A Department of Public Welfare P. 0, Box 2675 Harrisburg, PA \7105 7. Name and address of every other person of whom the Plaintiff has knowledge who may have an interest in the property which may be affected by the sale: None I verify that the statements made in lhis Affidavit are true and correct to the best 0 my personal knowledge. information and belief. I understand that false statements herein are ade subject to the penalties of 18 Pa,C,S. Section 4904 relating to unsworn falsification to aut orities, Date: November 23,2004 OMAS I. PU EO, ESQUIRE Attorney for Plaintiff " LAW OFFICES OF PULEO & D'EMILIO 660 Sentry Parkway, Suite 210 Blue Bell, P A 19422 (610) 941-3600 By: Thomas 1. Puleo, Esquire Identification No. 27615 Attorney for PLAINTIFF IN THE COURT OF COMMON PLEAS OF CUMBERLAND COUNTY, PENNSYL V NIA CIVIL ACTION - LAW ATLANTIC MORTGAGE & INVESTMENT: CORPORATION, a division of i ABN AMRO Mortgage Group, Inc., i Plaintiff NO. 02-3307 Civil Term v. LEROY A, LUTHER and i CAROLYN A, GElLING-LUTHER, his wife, : Defendant i NOTICE OF SHERIFF'S SALE OF REAL PROPERTY TO: Leroy A. Luther Carolyn A, Geiling-Luther 830 Doubling Gap Road Newville, PA 17241 Your house at 830 Doubling Gap Road, City of Newville, Cumberland County, is scheduled to be sold by the Cumberland County Sheriffs Department to enforce the Cou judgment of$115,825,62 obtained by Plaintiff Atlantic Mortgage & Investment Corporati n, a division of ABN AMRO Mortgage Group, Inc. against you, The Sheriffs Sale will be conducted on Wednesday, March 2, 2005, at 10:00 A,M" Cumberland County Courthous ,2nd Floor, Commissioner's Hearing Room, Carlisle, Pennsylvania, NOTICE OF OWNERS' RIGHTS YOU MAY BE ABLE TO PREVENT THIS SHERIFF'S SALE To prevent this Sheriffs Sale, you must take immediate action: I. This sale will be canceled if you pay to Atlantic Mortgage & Investment Corporation, a division of ABN AMRO Mortgage Group, Inc, the back pa ments, late charges, costs and reasonable attorneys' fees due, To find out how m h you must pay, you may call (610) 941-3600, ( . 2. You may be able to stop the sale by filing a petition asking the Court to strik or open the Judgment, if the judgment was improperly entered, You may also sk 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 m re chance you will have of stopping the sale. (See notice below 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 PLA E. I, If the Sheriff's Sale is not stopped, your property will be sold to the highest idder. You may find out the price bid by calling the Cumberland County Sheriff's Department at (717) 240-6390. 2, You may be able to petition the Court to set aside the sale if the bid price w s 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 id in the sale, To find out ifthis has happened, you may call the Cumberland C nty Sheriff's Department at (717) 240-6390. 4, If the amount due from the buyer is not paid to the Sheriff, you will remain the owner of tbe property as if the sale had never happened, 5. You have the right to remain in the property until the full amount due is pa d to the Sheriff and the Sheriff gives a deed to the buyer. At that time, the buy may bring legal proceedings to evict you, 6, You may be entitled to a share ofthe money which was paid for your hous , A schedule of distribution of the money bid for your house will be filed by t Cumberland County Sheriff on or about thirty (30) days from the date of S eriff's Sale, This schedule will state who will be receiving that money, The mo ey will be paid out in accordance with this schedule unless exceptions (reasons wythe proposed distribution is wrong) are filed with the Sheriff within ten (10) d ys after the distribution sheet is posted, 7, You may also have other rights and defenses, or ways of getting your house if you act immediately after the sale. YOU SHOULD TAKE THIS PAPER TO YOUR LAWYER AT ONCE, IF YOU DO NO HAVE A LAWYER OR CANNOT AFFORD ONE, GO TO OR TELEPHONE THE OFF BELOW TO FIND OUT WHERE YOU CAN GET LEGAL HELP, Court Administrator 4th Floor, Cumberland County Courthouse Carlisle, PAl 70 13 (7 I 7) 240-6200 ~ . DESCRIPTION ALL THAT CERTAIN tract of land with improvements thereon erected, situate in Lo er Mifflin Township, Cumberland County, Pennsylvania, bounded and described in accordance w Plan of Subdivision for Gary E, Bobb, prepared by Larry Vern Neidlinger, Professional Engineer, n October II, 1977, a draft of same being recorded in the hereinafter named Recorder's Office in PI Book 31, page 120, as follows: BEGINNING at a point in the center of the public road leading from Newville to Doubling Gap at the corner of land now or formerly of Viola Armolt, and which point at the place of beginning 's 157 feet Northwest from the corner of land now or formerly of Charles Spahr, measured along the nter line of said public road; thence from said point at the place of beginning along said line of I d now or formerly of ViolaM. Armolt, South 63 degrees 48 minutes West, a distance of 243,56 fee to a point in line of land now or formerly of Milton Walters; thence along said land now or formerl of Milton Walters, North 34 degrees 02 minutes West, a distance of 200.48 feet to an iron pin at th corner of Lot No 3 as shown on said Plan of Subdivision now or formerly of Cuisine Management Se ices, Inc.; thence along the Southern line of said Lot No, 1 now or formerly of Cuisine Management Ser ices, Inc, and continuing along the Southern line of Lot No. 2 as shown on said Plan of Subdivisio now or formerly of Cuisine Management Services, Inc., North 67 degrees 15 minutes East, a distan of254.16 feet to a nail in the center line of said public road leading from Newville to Doubling Gap; th nee along the center line of said public road leading from Newville to Doubling Gap, the followin three (3) courses and distances: (1) South 26 degrees 48 minutes East, a distance of 33,38 feet to a point; (2) South 32 degrees 12 minutes East, a distance of 113 feet to a point; (3) South 33 degrees minutes East, a distance of 37.90 feet to a point at the place of beginning, CONTAINING 1,08 acre and being all of Lot No, I as shown on said Plan of Subdivision fo Gary E, Bpbb, recorded as aforesaid, HA VING thereon erected a dwelling house known and numbered as 830 Doubling Gap Road, ewville, Pennsylvania. Tax #05-0413 Parcel #032B WRIT OF EXEC.UTION and/or ATTACHMENT COMMONWEALTH OF PENNSYL VANIA) COUNTY OF CUMBERLAND) NO 02-3307 Civil CIVIL ACTION - LAW TO THE SHERIFF OF CUMBERLAND COUNTY: To satisfy the debt, interest and costs due ATLANTIC MORTGAGE & INVESTMENT CORPORATION, A DIVISION OF ABN AMRO MORTGAGE GROUP, INC., Plaintiff (s) From LEROY A. LUTHER AND CAROLYN A. GElLING-LUTHER, HIS WIFE (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 fro paying any debt to or for the account of the defendant (s) and from delivering any property of the defend t (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 garnishee and is enjoined as above stated. Amount Due $115,825.62 Interest FROM 8/22/02 @ $22.44 PER DIEM Atty's Carom % Atty Paid $1038.36 PlaintitTPaid Date: NOVEMBER 30,2004 L.L. Due Prothy $1.00 Other Costs CURTIS R. LONG (Seal) REQUESTING PARTY: Name THOMAS 1. PULEO, ESQUIRE Address: 660 SENTRY PARKWAY, SUITE 210 BLUE BELL, PA 19422 Attorney for: PLAINTIFF Telephone: 610-941-3600 Supreme Court 1D No. 27615 Real Estate Sale #23 On December 01, 2004 the Sheriff levied upon the defendant's interest in the real property situated in Lower Mifflin Township, Cumberland County, PA Known and numbered as 830 Doubling Gap Road, Newville, more fully described on Exhibit "A" filed with this writ and by this reference incorporated herein, Date: December 01, 2004 It] :E d OE ^ON ~OOl \I'd "lb'IUJ U,:V iiLm'JiI:J .:i.:lHJ3HS 3Hl .:/0 3::11.:1.:10 By:JD~jS~ Real Est~e Deputy ~ ~ ..~-:'\ (.~\.ru c~;::::I (;;;V "':..J '."-~ \.)~ '. THE PATRIOT NEWS THE SUNDAY PATRIOT NEWS Proof of Publication Under Act No. 587, Approved May 16,1929 Commonwealth of Pennsylvania, Connty of Dauphin) ss James L. Clark, being duly sworn according to law, deposes and says: That he is the Accounts Receivable Manager of The Patriot News Co., a corporation organized and e 'sting under the laws of the Commonwealth of Pennsylvania, with its principal office and place of business at 812 to 18 Market Street, in the City of Harrisburg, County of Dauphin, State of Pennsylvania, owner and publisher of 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 w re established March 4th, 1854, and September 18th, 1949, respectively, and all have been continuously publish ever since; That the printed notice or publication which is securely attached hereto is exactly as printed and publ shed in their regular daily and/or Sunday! Metro editions which appeared on the 18th and 25th day(s) of January a the 1st day(s) of February 2005. That neither he nor said Company is interested in the subject matter of said prin d notice or advertising, and that all of the allegations of this statement as to the time, place and character of pub 'cation are true; and That he has personal knowledge of the facts aforesaid and is du1y authorized and empowered to veri this statement on behalf of The Patriot-News Co. aforesaid by virtue and pursuant to a resolution unanimously pa ed 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' ", Volume 14, Page 317. PUBLICATION /J I / / Lf. L ,. ,."."..,..,.".".."."."..,..,.".,/.."..,."(,,,,.".".,.".,."."",..,.",.".".". ( COpy S ALE #23 Sworn to and subscribed before me t . NOTARIAl SEAl ;{! Terry l. Russell, Noto~ ic City of Horrlsburg. Oou . My Commission Expires June 6. 2 A PUBLIC Member, Pennsyl....anlaAssocl . ,~ion expires June 6, 2006 CUMBERLAND COUNTY SHERIFFS OFFICE CUMBERLAND COUNTY COURTHOUSE ONE COURTHOUSE SQUARE CARLISLE, PA. 17013 Statement of Advertising Costs To THE PATRIOT-NEWS CO. For publishing the notice or publication attached hereto on the above stated dates 376.24 Publisher's Receipt for Advertising Cost The Patriot News Co., publisher of The Patriot.News and The Sunday Patriot-News, newspapers of genera circulation, hereby acknowledge receipt of the aforesaid notice and publication costs and certifies that the e have been duly paid. By................................................... ................ REAL ESTATE SALE No. 23 WrIt No. 1II11J 33W CIvIl,... AlIIInUc lIor1g11ge" 1_ Col'pondIon, .01_ 01 ABNAMIlO lIorlg8g8$roup, Inc. V. l.8nIy A..~_ C8nlIyn A."'IIng-~ AIIJ: 1IIcIinM L Pul80 DESCRIPTION AlL '1lIAT CI3KfAJN "'" ollaod with ~_...c...t._i1ll.owrr Mifflin Township. Cumberland County, Pelmsyl...... bouDded . and d,.aibld in . _1II!".Ili>..flrll8yll. ..... > . ...,...,-......- ... --.'......11. I977, .... ri _ ... ...... . 'die ioaoiooIor -,.' Rf<ooIer'. 0l6ee in PJall_ 31, page tlG, as . follows: j~ BEGINNING ai.. point in 1he center of"'" _roaaleacJingfiumNewvilletoiloul!liw a., It 1he """" ol\land oow or fOlllleiltri __andwl&bpointlt1heplacel1l bcIiIoning ;s IS? fee< NorIhwest from 'die ..- <i land oow or fOlllleily of Charles Sf*, measurecJaloug1hecenterlineofsailpollli<: roacI:dJta:efromsailpoinl..lbop/ol:eof ~alongsaidlineoflaodooworbDoedy ofViolaM._Saulh63c1epea48_ West, .disIInl:eof243.56loetli>.poinli1llineof laod oow or fOlllleily of MiIIoo Wabcrs; ""'"" alongsaidlaodooworfmmerlyof_ Waltm. North 34 ~ 02...... West,.... '- of 200.48 fea ilJn iron pin.. 1he cmor of Lot No. 3 IS shown 011 said Plan of SubcIMaioa ooworlOlllleilyofCuisine~ Scrvices,1n<.;_atong1heSoulhmolineof said Lot No, I now or ro.-!y of Cuisine__ _ ScMces, In<. and con-tinning along 1he Son1hem line <i Lot No.2 IS shown 011 said Plan iifSulxliYisionsooworfOlllltrly of Cuisine Maoagem<nt ScMces, IDe.. North 67 degrees IS ......East,.m..- ol254.Hifee<1i> .oailin 1he"""'lineofsaidpulllicroodleadingfrom Newville Ii> Doubling Gap: tb= along 1he center line of said public rood leading from Newville Ii> Donb-liog Gap, 1he following _ (3)~and_: (l)Soutb26degrees 48 ...... East, . diHance of 3338 feet Ii> . point, (2) Saulh 32 cIepea 12 minutes East, . dis,- of 113 fee< II> . point, (3) South 33 degrees SO_EasI,.m..-of37!XI feet 10. point.. 1he p1ace of BEGINNING. CONTAINING 1.08 ~ and being all of Lot No. 1 IS shown 011 said PJall of Subttivisioo for GaryR Bobb,_asaforesaid. HAVING \biO"""-' dwel-ling house known and _as 830 Doubling Gap \load. New-viUe, PennsylvaDia. ThxilO5-04l3 Pan:elf032B PROOF OF PUBLICATION OF NOTICE IN CUMBERLAND LAW JOURNAL (Under Act No. 587, approved May 16, 1929), p, L.1784 COMMONWEALTH OF PENNSYLVANIA ss. COUNTY OF CUMBERLAND Lisa Marie Coyne, Esquire, Editor of the Cumberland Law Journal, of the Count and State aforesaid, being duly sworn, according to law, deposes and says that the Cumberland aw Journal, a legal periodical published in the Borough of Carlisle in the County and State afo esaid, 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 regul Iy issued weekly in the said County, and that the printed notice or publication attached hereto s exactly the same as was printed in the regular editions and issues ofthe said Cumberland L Journal on the following dates, VIZ: Janu 14,21,28,2005 Affiant further deposes that he is authorized to verify this statement by the Cumberla d Law Journal, a legal periodical of general circulation, and that he is not interested in the subj ct matter of the aforesaid notice or advertisement, and that all allegations in the foregoing ~tatements as to time, place and character of publication are true, --- , Editor SWORN TO AND SUBSCRIBED before me this 28 day of January, 2005 d-,~) L .k. y.d.lN Notary . REAL ESTATE SALE NO, 23 Writ No. 2002-3307 Civil Atlantic Mortgage & Investment Corporation. a Division of ABN AMRO Mortgage Group, Inc. VS. Leroy A Luther and Carolyn A. Geiling-Luther Atty.: Thomas L Puleo DESCRlPTION ALL THAT CERTAIN tract ofland v.rl.th improvements thereon erected, situate in Lower Mifflin Township. Cumberland County, Pennsylvania, bounded and described in accory dance \Vith Plan of Subdivision for Gary E. Bobb. prepared by Larry VeTn Neidlinger, Professional Eng:i~ neer, on Oc,tober 11. 1977, a draft of same being recorded in the here~ inafter named Recorder's Office in Plan Book 31, page 12-0, as follows: BEGINNING at a point in the cen- ter of the pubHc road leading from Nev.rv:ille to Doubling Gap at the cor~ nef of land now or formerly of Viola Armolt. and which point at the place of beginning is 157 feet Northwest from the corner of land now Dr for- merly of Charles Spahr, measured along the center line of said public road; thence from said point at the place of beginning along said Hne of land now or formerly of Viola M. Armolt, South 63 degrees 48 min- utes West, a distance of 243.56 feet to a point in line of land now or for- merly of Milton Walters; thence along said land now or formerly of MUton Walters, North 34 degrees 02 min- utes West, a distance of 200.48 feet to an iron pin at the comer of Lot No 3 as shown on said Plan of Sub~ division now or formerly of Cuisine Management Services, Inc.; thence along the Southern line of sajd Lot No. 1 now or formerly of Cuisine Man- agement SeIVices, Inc. and continu~ ing along the Southern line of Lot NO.2 as shown on said Plan of Sub- divisions now or formerly of Cuisine Management Services, Inc., North 67 degrees 15 minutes East, a dis~ tance of254.16 feet to a nail in the center line of said public road lead- ing from Newville to Doubling Gap; thence along the center line of said public road leading from Newville to Doubl1ng Gap, the foUawing three (3) courses and distances: (1) South 26 degrees 48 minutes East. a dis- tance of 33.38 feet to a point; (2) South 32 degrees 12 minutes East. a distance of 113 feet to a point: (3) South 33 degrees 50 minute East. a distance of 37.90 feet to a point at the place of beginning. CONTAINING 1.08 acre and be- ing all of Lot No. 1 as shown on said Plan of Subdivision for Gary E. Bobb, recorded as aforesaid. HAVING thereon erected a dwel1~ ing house known and numbered as 830 Doubling Gap Road, Newville, Pennsylvania. Tax #05.0413 Parcel #032B. II II Ii I II 1\ II 1\ II 1\ II \1 II \ II II II II II \ I I THOMAS 1. PULEO, LLC By: Thomas I. Puleo, Esquire Identification No. 27615 660 Sentry Parkway, Suite 210 Blue Bell, PA 19422 (610) 941-3600 Attorney for Plaintiff IN THE COURT OF COMMON PLEAS OF CUMBERLAND COUNTY, PENNSYLV N1A CIVIL ACTION - LAW ATLANTIC MORTGAGE & INVESTMENT CORPORA nON, a division of ABN AMRO MOligage Group, Inc., Plaintiff NO, 02-3307 v, LEROY A, LUTHER and CAROLYN A, GElLING - LUTHER, Defendant ASSIGNMENT OF BID THOMAS I. PULEO, ESQUIRE, attorney for Atlantic Mortgage & Investment Corpo tion, a division of ABN AMRO Mortgage Group, Inc" hereby assigns all rights, title, and inte st in premises 830 Doubling Gap Road, Newville, Pennsylvania, 17241,23, March 2,2005 Sheriff' Sale, to secretary of Veterans Affairs, his successors and assigns. SWORN TO AND SUBSCRIBED BEFORE ME THIS J IJI'J DAY OF Ilk! /.. ~ ,2005, \__-/'/ '/1 .~-I /-! '/1 A - J 1-/ ! i" ff u -, NOTARY PUBLIC . .._.~._._._--,- NOT:-\Fi;:'L:~cf\L ~ LUZ N FUENTES Nnlary PUbliC WhItpam T wp r",1(\ilj(:l\~mery County My Commission E~Jl:C?~~_~!~:::~SL2~~ -7f:. , './:.-t'--:7