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HomeMy WebLinkAbout02-3347IN THE COURT OF COMMON PLEAS OF CUMBERLAND COUNTY, PENNSYLVANIA NATIONAL CITY MORTGAGE CIVIL DIVISION `?'"'?' COMPANY, assignee of ACCUBANC Ctvt? l MORTGAGE CORPORATION NO. c?? ?? COMPLAINT IN MORTGAGE FORECLOSURE Plaintiff, vs. DIL E. UHLIN, JR. and NICOLE R. UHLIN, Code -MORTGAGE FORECLOSURE Filed on behalf of Plaintiff Defendants. Counsel of record for this party. Louis P. Vitti, Esquire PA I.D. #3810 Supreme Court 401072 Louis P. Vitti & Assoc., P.C. 916 Fifth Avenue Pittsburgh, PA 15219 (412) 281-1725 COMPLAINT IN MORT A E FO EC OSIlgir, NOTICE YOU HAVE BEEN SUED IN COURT. IF YOU WISH TO DEFEND AGAINST THE CLAIMS SET FORTH IN THE FOLLOWING PAGES, YOU MUST TAKE ACTION WITHIN TWENTY (20) DAYS AFTER THIS COMPLAINT AND NOTICE ARE SERVED, BY ENTERING A WRITTEN APPEARANCE PERSONALLY OR BY THE ATTORNEY AND FILING IN WRITING WITH THE COURT YOUR DEFENSES AND OBJECTIONS TO THE CLAIMS SET FORTH AGAINST YOU. YOU ARE WARNED THAT IF YOU FAIL TO DO SO THE CASE MAY PROCEED WITHOUT YOU AND A JUDGMENT MAY BE ENTERED AGAINST YOU BY THE COURT WITHOUT FURTHER NOTICE FOR ANY MONEY CLAIMED IN THE COMPLAINT OR FOR ANY OTHER CLAIM OR RELIEF REQUESTED BY THE PLAINTIFF. YOU MAY LOSE MONEY OR PROPERTY OR OTHER RIGHTS IMPORTANT TO YOU. YOU SHOULD TAKE THIS PAPER TO YOUR LAWYER AT ONCE. IF YOU SHOULD NOT HAVE A LAWYER, OR CANNOT AFFORD ONE, GO TO OR TELEPHONE THE OFFICE SET FORTH BELOW TO FIND OUT WHERE YOU CAN GET LEGAL HELP. CUMBERLAND COUNTY BAR ASSOCIATION 2 LIBERTY AVENUE CARLISLE, PA 17013 (717) 249-3166 MELA_1NT IN MORTGAGE FORE LO IRE AND NOW, comes the Plaintiff by its attorneys, Louis P. Vitti and Associates, P.C. and Louis P. Vitti, Esquire, and pursuant to the Pennsylvania Rules of Civil Procedure Numbers 1141 through 1150, for its Complaint in Mortgage Foreclosure, sets forth the following: 1. The Plaintiff is a corporation duly authorized to conduct business within the laws of the Commonwealth of Pennsylvania, having a principal place of business located at 3232 Newmark Drive, Miamisburg, Ohio 45342. 2. The Defendant(s) is/are individuals with a last known mailing address of 30 Ramblewood Drive, Etters, PA 17319. The property address is 20 Maple Avenue, Camphill, PA 17011 and is the subject of this action. 3. On the 31st day of January, 2000, in consideration of a loan of One Hundred Five Thousand Eight Hundred Forty Six and 00/100 ($105,846.00) Dollars made by Accubanc Mortgage Corp., a Texas corporation, to Defendant(s), the said Defendant(s) executed and delivered to Accubanc, a TX corporation, a "Note" secured by a Mortgage with the Defendant(s) as mortgagor(s) and Accubanc, as mortgagee, which mortgage was recorded on the 4th day of February, 2000, in the Office of the Recorder of Deeds of Cumberland County, in Mortgage Book Volume 1594, page 727. The said mortgage is incorporated herein by reference thereto as though the same were set forth fully at length. 4. The premises secured by the mortgage are: SEE EXHIBIT "A" ATTACHED HERETO. 5. On the 4th day of February, 2000, Accubanc Mortgage Corporation, a TX corporation, assigned to the Plaintiff, National City Mortgage Company, the said mortgage, that assignment being recorded in the Office of the Recorder of Deeds of Cumberland County on the 4th day of February, 2000, in Mortgage Book Volume 1637, page 151. The said assignment is incorporated herein by reference. 6. Said mortgage provides, inter alia: "that when as soon as the principal debt secured shall become due and payable, or in case default shall be made in the payment of any installment of principal and interest, or any monthly payment, keeping and performance by the mortgagor of any of the terms, conditions or covenants of the mortgage or note, it shall be lawful for mortgagee to bring an Action of Mortgage Foreclosure, or other proceedings upon the mortgage, of principal debt, interest and all other recoverable sums, together with attorney's fees." 7. Since November 1, 2001, the mortgage has been in default by reason, inter alia, of the failure of the mortgagor(s) to make payments provided for in the said mortgage (including principal and interest) and, under the terms of the mortgage, the entire principal sum is due and payable. 8. In accordance with the appropriate Pennsylvania Acts of Assembly and the Pennsylvania Rules of Civil Procedure, the mortgagor(s) has been advised in writing of the mortgagees intention to foreclose. The appropriate time period has elapsed since the Notice of Intention to Foreclose has been served upon the mortgagor(s). 9. The amount due on said mortgage is itemized on the attached schedule. 10. Plaintiff does hereby release the personal representative, heir and/or devisee of the mortgagor(s) from liability for the debt secured by the mortgage. WHEREFORE, pursuant to Pennsylvania Rule of Civil Procedure Number 1147(6), Plaintiff demands judgment for the amount due of One Hundred Twenty Three Thousand Two Hundred Thirty Eight and 511100 Dollars ($123,238.51) with interest and costs. Respectfully submitted, LOUIS P. VITTI & ASSOC., P.C. BY Louis P. Vitti, Esquire Attorney for Plaintiff UHLIN SCHEDULE OF AMOUNTS DUE UNDER MORTGAGE Unpaid Principal Balance Interest @ 8.5000% from 10/01/01 through (Plus $24.3292 per day after 7/31/2002 ) Late charges through 7/8/2002 0 months @ 38.34 Accumulated beforehand (Plus $38.34 on the 17th day of each month after Attorney's fee Escrow deficit 7/31/2002 7/8/2002 ) (This figure includes projected additional charges that maybe incurred by the Plaintiff and transmitted to the sheriff as charges on the writ prior to the date of the sheriffs sale) BALANCE DUE 104,472.59 7,371.76 41.58 5,223.63 6,128.95 123,238.51 -. VERIFICATION AND NOW Louis P. Vitti verifies that the statements made in this Complaint are true and correct to the best of his knowledge, information and belief. I understand that false statements herein are made subject to the penalties of 18 Pa.C.S. 4904, relating to unworn falsification to authorities. By virtue of the fact that the Plaintiff is outside the jurisdiction of the court and the verification cannot be obtained within the time allowed for the filing of this pleading, the pleading is submitted by counsel having sufficient knowledge, information and belief based upon the information provided him by the Plaintiff. ui . Vitti Dated: July 8, 2002 (J Q t- ?l rn;- { l? is r. >`:: 7 rTl ----- -= nv nnTrnTmV SHERIFF'S RETURN - OUT OF COUNTY CASE NO: 2002-03347 P COMMONWEALTH OF PENNSYLVANIA: COUNTY OF CUMBERLAND NATIONAL CITY MORTGAGE CO VS UHLIN DIL E JR ET AL Thomas Kline , Sheriff or Deputy Sheriff who being duly sworn according to law, says, that he made a diligent search and and inquiry for the within named DEFENDANT to wit: UHLIN DIL E JR but was unable to locate Him deputized the sheriff of YORK in his bailiwick. He therefore serve the within COMPLAINT - MORT FORE County, Pennsylvania, to On Au ust 14th 2002 this office was in receipt of the attached return from YORK Sheriff's Costs: Docketing 18.00 Out of County 9.00 Surcharge 10.00 Dep York Co 38.95 Mileage 10.35 86.30 08/14/2002 LOUIS VITTI So answers- f Yt. Thomas Kline Sheriff of Cumberland County Sworn and subscribed to before me this day of -2 A. D. Prothonotary aT-' YORKTOWNE BUSINESS FOMRS • (717) 225-0363 • Fh( (717) 225-0367 r l ?? .Z -Z xf T 33 - aQa TO C?) au, 9,9Ji ,G-wxd 7130 COUNTY OF YORK 1 of 2 OFFICE OF THE SHERIFF y(;;)t771960,? 28 EAST MARKET ST., YORK, PA 17401 SHERIFF SERVICE INSTRUCTIONS PLEASE TYPE ONLY LINE 1 THRU 12 PROCESS RECEIPT and AFFIDAVIT OF RETURN DO NOT DETACH ANY COPIES 3. SERVE A AT National City Mortgage Company E. Uhlin Jr. et al 5. NAME OF INDIVIDUAL, COMPANY, CORPORATION, ETC. TO 2. CUUHI NUMatK 02 3347 civil 4. TYPE OF WRIT OR COMPLAINT Notice & Canplaint in Mtg Foreclos 'ERTY TO BE LEVIED, ATTACHED, OR SOLD. Dil E. Uhlin Jr. 6. ADDRESS (STREET OR RFO WITH BOX NUMBER, APT. NO., CITY, BORO, TWP., STATE AND ZIP CODE) 30 Ramblewood Drive Etters, PA 17319-9655 7. INDICATE SERVICE: J PERSONAL J PERSON IN CHARGE J DEPUTIZE ? 1ST CLASS MAIL a Fus I eu Zvi nrn NOW JUly 25 2002 I, SHERIFF OF COUNTY, PA, dp hereby deputize the sheriff of York COUNTY to execute thya.? tjr d`r`r ke return th w "ccordin to law. This deputization being made at the request and risk of the plaintiff. SHERIFF O COUNTY Cdffl5er 8. SPECIAL INSTRUCTIONS OR OTHER INFORMATION THAT WILL ASSIST IN EXPEDITING SERVICE'. OUT OF COUNTY n CUMBERLAND ADVANCED FEE PAID BY SHERIFF NOTE: ONLY APPLICABLE ON WRIT OF EXECUTION: N.B. WAIVER OF WATCHMAN - Any deputy sheriff levying upon or attaching any property under within writ may leave same without a watchman, in custody of whomever is found in possession, after notifying person of levy or attachment, without liability on the part of such deputy or the sheriff to any plaintiff herein for any loss, destruction, or removal of any property before sheriffs sale thereof. 9. TYPE NAME and ADDRESS of ATTORNEY / ORIGINATOR and SIGNATURE 10. TELEPHONE NUMBER 11. DATE FILED 7-15-02 12. SEND NOTICE OF SERVICE COPY TO NAME AND ADDRESS BELOW: (This area must be completed if notice is to be mailed). CUMBERLAND CO. SHERIFF 13. 1 acknowledge receipt of the writ 114. DATE RECEIVED m. txpnauomneanng uare complaint aindicated abo /RAHRENS 7-29-02 8-14-02 16 HOW SERVED: PERSONAL Lj' RESIDENCE ( POSTED( ) POE ( ) SHERIFF'S OFFICE ( ) OTHER ( ) SEE REMARKS BELOW 17. -3 I hereby certify and return a NOT FOUND because a able to locale the individual, company, etc. name abov . (See remarks below.) 1 NAME TITLE INDIDUAk S D /UST AD RES H ?F NOT SHOWN ABpVE elalions? efe ant) 19. "teof -/t rvice 2 ` me of Servic r--l, 21ATTEMPTS a T s Int. a Tme es In. Dale ime Miles Int. Tm files Int. Date Tme t. Date Tme Miles Int. 22. REMARKS: 6Z II 23. Advance Cost 24. Service Gosts 25. N/F 26. Mileage 27. Postage 28. Sub Total 29. Pound 30. Notary 31 1 . Surchg. 32. Tot. Costs 33. Costs Due Refund Check No. " 5g0i 00 24.00 10.95 75 34.95 4.00 38-qS 46.05 . 34. Foreian Countv Costs 35. Advance Costs 36. Service Costs 37. Notary Cert. 38. Mileage/Posted/Not Found 39. Total Costs 40. Costs Due or Refund 41. AFFIRMED and subscribed to before me this 44 All UCT 2011.243 ?d ?" y 42. day of NOT RY 46 NDtaria! Seal James VV. Vaminelsi Noterv Pubft Signature of 0 50. I ACKNOWLEDGE RECEIPT OF THE SHERIFF'S RETURN SIGNATURE 151. DATE RECEIVED 1. WHITE - Issuing Anthony 2. PINK -Attorney 3. CANARY - Sheriffs Office 4. BLUE - ShenTS Office 2of2 YORKTOWNE BUSINESS FOMRS • (717) 225-0363 • FAUX (717) 225-0367 COUNTY OF YORK OFFICE OF THE SHERIFF 28 EAST MARKET ST., YORK, PA 17401 SHERIFF SERVICE PROCESS RECEIPT and AFFIDAVIT OF RETURN National City Mortgage Company INSTRUCTIONS PLEASE TYPE ONLY LINE 1 THRU 12 DO NOT DETACH ANY COPIES 2. COURT NUMBER 02-'A'147 Civil 14 TYPE OF WRIT OR COMPLAINT 3. DEFENDANT/S/ Dil E Uhlin Jr. Notlce & Corrtplaint in Mtg FOreclOS SERVE 5. NAME OF INDIVIDUAL, COMPANY, CORPORATION, ETC TO SERVE OR DESCRIPTION OF PROPERTY TO BE LEVIED ATTACHED OR SOLD WIT Nicole R. Uhlin 6. ADDRESS (STREET T O OR RED RFO WITH BOX NUMBER, APT. NO., CITY, BORO, TWP, STATE AND ZIP CODE) AT 30 RaLnblewood Drive Etters, PA 17319 7. INDICATE SERVICE: U PERSONAL U PERSON IN CHARGE U DEPUTIZE U RT AIL J 1ST CLASS MAIL J POSTED J OTHER NOW July 25 20 02 I, SHERIFF OF ;C?UNT , P do hereby d the sheriff of York COUNTY to execu petu ording to law. This deputization being made at the request and risk of the plaintiff. SHERIFF oF41WvcouNTv r an8. SPECIAL INSTRUCTIONS OR OTHER INFORMATION THAT WILL ASSIST IN EXPEDITING SERVICE: OUT OF COUNTY CUMBERLAND ADVANCED FEE PAID BY SHERIFF NOTE: ONLY APPLICABLE ON WRIT OF EXECUTION: N.B. WAIVER OF WATCHMAN - Any deputy sheriff levying upon or attaching any property under within writ may leave same without a watchman, in custody of whomever is found in possession, after notifying person of levy or attachment, without liability on the part of such deputy or the sheriff to any plaintiff herein for any loss, destruction, or removal of any property before sheriffs sale thereof. 10. TELEPHONE NUMBER 11 DATE FILED 9. TYPE NAME and ADDRESS of ATTORNEY I ORIGINATOR and SIGNATURE 7-15-02 LOUIS P VITTI ESQ 12. SEND NOTICE OF SERVICE COPY TO NAME AND ADDRESS BELOW: (This area must be completed if notice is to be mailed). CUMBERLAND CO. SHERIFF __ __. _.., .,? ruo cuoclcc - nn NoT WRITE BELOW THIS LINE 13. 16 1acknowledgereceipt ofthewrit R. AHRENS / or complaint as indicated above. RESIDENCE ( POSTED( ) HOW SERVED: PERSONAL( ) 14, -Da Telvi,L) 7 POE ( ) SHERIFFS OFFICE ( ) OTHER ( EE REMARKS BELOW . 17 7 1 hereby certify and return a NOT FOUND because I am unable to locate the individual parry, etc. name above. (See remarks below.) 19 Da of 5 rvice 20. Time of Service . w 18. O / t NA D,TIT glVl SERVED/ LIST ADDRESS ERE IOT SHOW BO (ROelationship to Defendant-f Date Time I t - Int. Date Time Miles 1 Date lime files Int. Date Time Miles nt. 21. n . ATTEMPTS Date Time nt. Date Time Miles 22. REMARKS: Postage 28. Sub Total 29. Pound 30. Notary 31. Burring. 32. Tot. Costs Mileage 27 N/F 26 5 33. Costs Due or Refund Check No. 23. . . . Advance Costs 24. Service Costs 2 Notary Cert. Service Costs 37 t 36 38. Mileage/PostedlNot Found 39. Total Costs 40. Costs Due or Refund 34. . s . Foreign County Costs 35. Advance Cos 41. AFFIRMED anQ?yf7_sUrjppUi to beforeony thi 44, Signa I , \ 0 42. day of ff?1UU GG JJ II 20 _LL 4? ep. S ll.J pnlihPF / NO ARV 46. Sign ore of ork 47. DATE Coun She / B-12-02 Notar'el 5661 Pub1IC WILL M. HOSE 9. DATE James V-Vangreen, Notary FA city of York, York County, 48. Signature of Foreign 4 .,., cvniutiM Ntaf. 2., 2006 r noty Sheriff J 1>f,30 SERVICE CALL. (717) 771.9601 V OF AUTHORIZED ISSUING AUTHORITY AND TITLE 1. WHITE - Issuing Authority 2. PINK - Attorney 3. CANARY - Sheriffs Office 4. BLUE - Sheriffs Office SHERIFF'S RETURN - OUT OF COUNTY CASE NO: 2002-03347 P COMMONWEALTH OF PENNSYLVANIA: COUNTY OF CUMBERLAND NATIONAL CITY MORTGAGE CO VS UHLIN DIL E JR ET AL R. Thomas Kline , Sheriff or Deputy Sheriff who being duly sworn according to law, says, that he made a diligent search and and inquiry for the within named DEFENDANT to wit: UHLIN NICOLE R but was unable to locate Her deputized the sheriff of YORK in his bailiwick. He therefore serve the within COMPLAINT - MORT FORE County, Pennsylvania, to On August 14th , 2002 , this office was in receipt of the attached return from YORK Sheriff's Costs: Docketing 6.00 Out of County .00 Surcharge 10.00 .00 .00 16.00 08/14/2002 LOUIS VITTI So answer ?i R-. Thomas Kline Sheriff of Cumberland County Sworn and subscribed to before me this 2 day of A L% 7Yt DD ??I ? Prothonotarjl ' IN THE COURT OF COMMON PLEAS OF CUMBERLAND COUNTY, PENNSYLVANIA NATIONAL CITY MORTGAGE CIVIL DIVISION COMPANY, assignee ofACCUBANC MORTGAGE CORPORATION, NO. 02-3347 CIVIL TERM Plaintiff, PRAECIPE FOR DEFAULT JUDGMENT, CERTIFICATION OF MAILING AND AFFIDAVIT OF NON- vs. MILITARY SERVICE DIL E. UHLIN, JR and NICOLE R. UHLIN Code MORTGAGE FORECLOSURE Defendants. Filed on behalf of Plaintiff Counsel of record for this party. Louis P. Vitti, Esquire PA I.D. #3810 Supreme Court #01072 Louis P. Vitti & Assoc., P.C. 916 Fifth Avenue Pittsburgh, PA 15219 (412) 281-1725 IN THE COURT OF COMMON PLEAS OF CUMBERLAND COUNTY, PENNSYLVANIA CIVIL DIVISION NATIONAL CITY MORTGAGE COMPANY, assignee ) NO. 02-3347 CIVIL TERM of ACCUBANC MORTGAGE CORPORATION, ) Plaintiff, ) VS. ) DIL E. UHLIN, JR and NICOLE R. UHLIN, ) Defendants. ) PRAECIPE FOR DEFAULT D DGMENT AND ASSESSMENT OF DAMAGES TO: PROTHONOTARY OF CUMBERLAND COUNTY Enter judgment in Default of an Answer in the amount of $124,990.21, in favor of the National City Mortgage Company, et al, Plaintiff in the above-captioned action, against the Defendants, Dil E. Uhlin, Jr and Nicole R. Uhlin and assess Plaintiffs damages as follows and/or as calculated in the Complaint: Unpaid Principal Balance $104,472.59 Interest from 10/01/01-10/11/02 9,123.46 (Plus $24.3292 per day after 10/11/02) Late charges (Plus $38.34 per month from 07/08/02-03/05/03$306.72) 41.58 Attorney's fee 5,223.63 Escrow Deficit 6,128,950, (Plus any additional charges that may be incurred by the Plaintiff and transmitted to the sheriff as charges on the writ prior to the date of the sheriffs sale) Total Amount Due $124,990.21 The real estate, which is the subject matter of the Complaint, is situate in Twp of Hampton, Cty of Cumberland, Cmwlth of PA. HET a dwg k/a 20 Maple Ave, Camp Hill, PA 17011. Parcel#10-21-0277-101. L uis P. Vitti, Esquire Attorney for the Plaintiff IN THE COURT OF COMMON PLEAS OF CUMBERLAND COUNTY, PENNSYLVANIA CIVIL DIVISION COMMONWEALTH OF PENNSYLVANIA, SS: COUNTY OF ALLEGHENY BEFORE me, the undersigned authority, personally appeared Louis P. Vitti, Esquire, who, being duly sworn according to law, deposes and says that he is advised and believes that DEFENDANT(S) is/are not presently in the active military service of the United States of America and not members of the Army of the United States, United States Navy, the Marine Corps, or the Coast Guard, and not officers of the Public Health Service detailed by proper authority for duty with the Army or Navy; nor engaged in any active military service or duty with any military or naval units covered by the Soldiers and Sailors Civil Relief Act of 1940 and designated therein as military service, and to the best of this affiant's knowledge is/are not enlisted in military service covered by said act, and that the averments herein set forth, insofar as they are within his knowledge, are correct, and true; and insofar as they are based on information received from others, are true and correct as he verily believes. This Affidavit is made under the provisions of the Soldiers and Sailors Civil Relief Act of 1940. Louis P. Vitti, Esquire SWORN to and subscribed before me this 11th day of October, 2002. Public NOTARIAL SEAL IS A EVANGELISTA, NOTARY PUBLIC TY OF PRTSBURGH, ALLEGHENY COUNTY COAMM ION DIPM OMER 17, 2005 rLCMCF IN THE COURT OF COMMON PLEAS OF CUMBERLAND COUNTY, PENNSYLVANIA CIVIL DIVISION NATIONAL CITY MORTGAGE COMPANY, assignee ) NO. 02-3347 CIVIL TERM of ACCUBANC MORTGAGE CORPORATION, ) Plaintiff, ) vs. ) DIL E. UHLIN, JR and NICOLE R. UHLIN, ) Defendants. ) CERTIFICATION OF MAILING I, Louis P. Vitti, do hereby certify that a Notice of Intention to Take Judgment was mailed to the Defendant(s), in the above-captioned case on September 30, 2002 , giving ten (10) day notice that judgment would be entered should no action be taken. LOUIS P. VITTI & ASSOCIATES, P.C. BY: ouis P. Vitti, Esquire Attorney for Plaintiff SWORN to and subscribed before me this 11th day of October, 2002. Notary Public - ARIAL sFAL QV OF A NOTARY Pusuc ,AU.EaNeW couNrr WCOWlAMM pWM 0070KR 17, 2005 IN THE COURT OF COMMON PLEAS OF CUMBERLAND COUNTY, PENNSYLVANIA CIVIL DIVISION NATIONAL CITY MORTGAGE COMPANY, assignee of ACCUBANC MORTGAGE CORPORATION, ; Plaintiff, NO. 02-3347 CIVIL TERM vs. DIL E. UHLIN, JR and NICOLE R. UHLINDefendants. IMPORTANT NOTICE TO: Dil E. Uhlin, Jr. Nicole R. Uhlin 30 Ramblewood Drive Etters, PA 17319 Date of Notice: September 30, 2002 YOU ARE IN DEFAULT BECAUSE YOU HAVE FAILED TO ENTER A WRITTEN APPEARANCE PERSONALLY OR BY ATTORNEY AND FILE IN WRITING WITH THE COURT YOUR DEFENSES OR OBJECTIONS TO THE CLAIMS SET FORTH AGAINST YOU. UNLESS ACT WITHIN TEN (10) DAYS FROM THE DATE OF THIS NOTICE, A JUDGMENT MAY BE ENTERED AGAINST YOU WITHOUT A HEARING AND YOU MAY L YOUR PROPERTY OR U OTHER IMPORTANT RIGHTS. OSE YOU SHOULD TAKE THIS NOTICE TO YOUR LAWYER AT ONCE. IF YOU DO NOT HAVE A LAWYER OR CANNOT AFFORD ONE, GO TO OR TELEPHONE THE FOLLOWING OFFICE SET FORTH BELOW TO FIND OUT WHERE YOU CAN GET LEGAL HELP: CUMBERLAND COUNTY BAR ASSOCIATION 2 LIBERTY AVENUE CARLISLE, PA 17013 (717) 249-3166 LOUIS TI & T"S,C BY: L i itti, Esquire Att orney for Plaintiff 916 Fifth Avenue Pittsburgh, PA 15219 ** THE DEBT COLLECTOR IS ATTEMPTING TO COLLECT A DEBT AND ANY INFORMATION OBTAINED WILL BE USED FOR THAT PURPOSE.** _ ?# T O 7 'T7 t t ?? ?i r ? -G -f ? IN THE COURT OF COMMON PLEAS OF CUMBERLAND COUNTY, PENNSYLVANIA NATIONAL CITY MORTGAGE CIVIL DIVISION COMPANY, assignee of ACCUBANC MORTGAGE CORPORATION, NO. 02-3347 CIVIL TERM Plaintiff, PRAECIPE FOR WRIT OF EXECUTION AND AFFIDAVIT OF LAST KNOWN ADDRESS vs. DIL E. UHLIN, JR and NICOLE R. UHLIN Defendants. Code MORTGAGE FORECLOSURE Filed on behalf of Plaintiff Counsel of record for this party: Louis P. Vitti, Esquire PA I.D. #3810 Supreme Court #01072 Louis P. Vitti & Assoc., P.C. 916 Fifth Avenue Pittsburgh, PA 15219 (412) 281-1725 IN THE COURT OF COMMON PLEAS OF CUMBERLAND COUNTY, PENNSYLVANIA CIVIL DIVISION NATIONAL CITY MORTGAGE COMPANY, assignee ) NO. 02-3347 CIVIL TERM of ACCUBANC MORTGAGE CORPORATION, ) Plaintiff, ) VS. ) DIL E. UHLIN, JR and NICOLE R. UHLIN, ) Defendants. ) PRAECIPE FOR WRIT OF EXECUTION IN MORTGAGE FORECLOSURE TO: PROTHONOTARY OF CUMBERLAND COUNTY Issue a Writ of Execution in favor of the Plaintiff and against the Defendant(s) in the above-captioned matter as follows: Amount Due $124,990.21 Interest 10/12/02-03/05/03 3,527.73 Total 12 51 .94 in: The real estate, which is the subject matter of the Praecipe for Writ of Execution is situate Twp of Hampton, Cty of Cumberland, Cmwlth of PA. HET a dwg k/a 20 Maple Ave, Camp Hill, PA 17011. Parcel# 10-21-0277- 10 1. Louis P. Vitti, Esquire Attorney for Plaintiff IN THE COURT OF COMMON PLEAS OF CUMBERLAND COUNTY, PENNSYLVANIA CIVIL DIVISION NATIONAL CITY MORTGAGE COMPANY, assignee ) NO. 02-3347 CIVIL TERM of ACCUBANC MORTGAGE CORPORATION, Plaintiff, vs. ) DIL E. UHLIN, JR and NICOLE R. UHLIN, Defendants. AFFIDAVIT I, Louis P. Vitti, do hereby swear that, to the best of my knowledge, information and belief, the Defendant(s), is/are the owners of the real property on which the Plaintiff seeks to execute . That the Defendants' last known address is 30 Ramblewood Drive, Etters, PA 17319. OOuis. Vitti, Esquire SWORN TO and subscribed before me this 11th day of October, 2002. i l/ k Notary Public NOrARtA? Lots A EVgryC'?A SEAL C P yC0Mt417SBUBQN, PUBLIC OMAMSSION NIEOHENYCOUNTY EXPIRES OCTOBER 17,200,5 c, <:-, r ' -r? ? ?,? --a ?. _ .__ ?:. ?: -- IN THE COURT OF COMMON PLEAS OF CUMBERLAND COUNTY, PENNSYLVANL4 CIVIL DIVISION -- action: PRAECIPE FOR WRIT OF E'.<=ION ( ) Confessed Judgment ( ) Other National City Mortgage Co., et al Dil E. Uhlin and Nicole R. Uhlin V5. File No. 07_3347 ciyu TERM Amount Due $124,990.21 Interest _$ 3,527 73 Atty's Cortm Costs Its THE PR07HONOTARY OF THE SAID COURT: The undersigned hereby certifies that the below does not arise out of a retail nstallment sale, contract, or account based on a confession of judgment, but if it does, it is based on the appropriate or.ginal proceeding filed pursuant to Act 7 of 1966 as vended; and for real property pursuant to Act 6 of 1974 as amended. Issue writ of execution in the above matter to the Sheriff of Cumberland County, for debt, interest and costs upon the following described property of the Defendant(s) See attached legal description PRAE= FOR ATTAC11= EXBC[TTION Issue writ of attach;rent to the Sheriff of Gtunt?r lan County, for debt, interest and costs, as above, directing attachment against tdhe above-naaed garnishee(s) for the following property (if real estate, supply six copies of the description; supply four copies of lengthy personalty list) and all other property of the defendant(s) in the possession, custody or control of the said garnishee(s). (Indicate) Index this writ against the garnishee(s) as a lis pendens against real estate of the defendant(s) described in the attached exhibit. DATE: 10.11.02 Signature: Print Name: Louis P. Vitti =ddress: 916 Fifth Pittsburgh, PA 15219 ttornev for: Plain-tiff ele_:n.or.e: 412.281.1725 ri- ?U]C ? ll? (?i ? ? ? 1i? 11•? (V?, ? c7 , r ,i IN THE COURT OF COMMON PLEAS OF CUMBERLAND COUNTY, PENNSYLVANIA CIVIL DIVISION NATIONAL CITY MORTGAGE COMPANY, assignee ) NO. 02-3347 CIVIL TERM of ACCUBANC MORTGAGE CORPORATION, ) Plaintiff, ) vs. ) DIL E. UHLIN, JR and NICOLE R. UHLIN, ) Defendants. ) LEGAL DESCRIPTION All that certain lot of land situated in the Township of Hampton, County of Cumberland and State of Pennsylvania, more Pennsylvania, more particularly bounded and described as follows, to wit: Beginning at a point on the Western line of Maple Avenue as shown on the Plan of Lots hereinafter referred to said point being three hundred twenty-seven and six tenth (327.6) feet measured Southwardly along the Western line of said Maple Avenue from the Southwest corner of Maple Avenue and Carlisle Turnpike; thence in a Westerly direction along a line at right angles with Maple Avenue; one hundred fifty (150) feet to a point; thence in a Southerly direction along a line parallel with Maple Avenue, sixty (60) feet to a point; thence in an Easterly direction along a line at right angles with Maple Avenue, one hundred fifty (150) feet to Maple Avenue; thence in a Northerly direction along the Western line of Maple Avenue, sixty (60) feet to a point the place of beginning. Being Lot No. 20 on Revised Plan of Maple Avenue, Oakwood Park, Hampton Township, Cumberland County, Pennsylvania, said Plan being recorded in the Office of the Recorder of Deeds in and for said County of Cumberland in Plan Book 3, page 52. Having erected thereon a dwelling known as 20 Maple Ave, Camp Hill, PA 17011 Parcel # 10-21-0277-101 Being the same premises which Richard L. Moyer and Jean C. Moyer by their deed 01/31/2000 and recorded on 04/04/2000 in the Recorder of Deeds Office in Cumberland County, Pennsylvania granted and conveyed Dil E. Uhin, Jr and Nicole R. Uhlin IN THE COURT OF COMMON PLEAS OF CUMBERLAND COUNTY, PENNSYLVANIA CIVIL DIVISION NATIONAL CITY MORTGAGE COMPANY, assignee ) NO. 02-3347 CIVIL TERM of ACCUBANC MORTGAGE CORPORATION, ) Plaintiff, ) VS. ) DIL E. UHLIN, JR and NICOLE R. UHLIN, ) Defendants. ) AFFIDAVIT I, Louis P. Vitti, hereby certify that as representative of National City Mortgage Company, et al am familiar with the above-captioned case and various servicing activities related thereto and that the provisions of the laws of the Commonwealth of Pennsylvania and specifically, Act 91 of 1983, have been complied with in the above-captioned case. Louis P. Vitt,, Esquire Attorney for Plaintiff SWORN to and subscribed before me this I Ith day of October, 2002. Notary Public NOTARIAL SEAL --- LOIS A. EVANGELISTA, NOTARY PUBLIC CRY OF PITTSBURGH, ALLEGHENY COUNTY W COMMISSION E)SRES OCTOBER 17.20: CJ ?-? . CY1 r l, IN THE COURT OF COMMON PLEAS OF CUMBERLAND COUNTY, PENNSYLVANIA CIVIL DIVISION NATIONAL CITY MORTGAGE COMPANY, assignee ) NO. 02-3347 CIVIL TERM of ACCUBANC MORTGAGE CORPORATION, ) Plaintiff, ) VS. ) DIL E. UHLIN, JR and NICOLE R. UHLIN, ) Defendants. ) AFFIDAVIT PURSUANT TO RULE 3129.1 National City Mortgage Company, et al, Plaintiff in the above 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 20 Maple Ave, Camp Hill, PA 17011. 1. Name and address of Owner(s) or Reputed Owner(s): Name: Address (Please indicate if this cannot be reasonably ascertained) Dil E. Uhlin 30 Ramblewood Drive Nicole R. Uhlin Etters, PA 17319 2. Name and address of Defendant(s) in the judgment: Name: Address (Please indicate if this cannot be reasonably ascertained) Same as No. 1 above. 3. Name and last known address of every judgment creditor whose judgment is a record lien on the real property to be sold: Name: Address (Please indicate if this cannot be reasonably ascertained) Agway Energy Products 530 E.N. Street Carlise, PA 17013 4. Name and address of the last recorded holder of every mortgage of record: Name Address (Please indicate if this cannot be reasonably ascertained) None 5. Name and address of every other person who has any record lien on the property: Name Address (Please indicate if this cannot be reasonably ascertained) None 6. Name and address of every other person who has any record interest in or record lien on the property and whose interest may be affected by the sale: Name Address (Please indicate if this cannot be reasonably ascertained) None 7. Name and address of every other person of whom the Plaintiff has knowledge who has any interest in the property which may be affected by the sale: Name Address (Please indicate if this cannot be reasonably ascertained) Tax Collector of Hampton Township PAWC Hampton Township Commonwealth of PA -DPW Clerk of Courts Criminal/Civil Division Tax Claim Bureau of Cumberland County Cumberland County Courthouse 5000 Creekview Road Mechanicsburg, PA 17055 P.O. Box 578 Alton, IL 62002 230 Sporting Hill Rd Mechanicsburg, PA 17055 P.O. Box 8016 Harrisburg, PA 17105 One Courthouse Square Carlisle, PA 17013 One Courthouse Square Carlisle, PA 17013 Court of Common Pleas of Cumberland County Domestic Relations Division Bureau of Compliance Tenant/Occupant P.O. Box 320 Carlisle, PA 17013 Clearance Support Section Dept. #281230 Harrisburg, PA 17128-1230 Attn: Susan Blough 20 Maple Ave Camp Hill, PA 17011 I verify that the statements made in this affidavit are true and correct to the best of my personal knowledge or information and belief. I understand that false statements herein are made subject to the penalties of 18 Pa. C.S. Section 4904 relating to unswom falsification to authorities. October 11. 2002 Date SWORN TO and subscribed before me this 1 Ith day of October, 2002. Public i a ? Louis P. Vitti, Esquire Attorney for Plaintiff LOIS A EVANGEUSTA SEA NO y Ptleuc CffyP rrr? r+G+, aLEGNENr cry E?IrtES ocroeEn n, 2005 -? NOTICE OF SHERIFF'S SALE OF REAL ESTATE PURSUANT TO PENNSYLVANIA RULE OF CIVIL PROCEDURE 3129.1 TO: Dil E. Uhlin Nicole R. Uhlin 30 Ramblewood Drive Etters, PA 17319 AND: ALL LIEN HOLDERS TAKE NOTICE that by virtue of the above Writ of Execution issued out of the Court of Common Pleas of Cumberland County, Pennsylvania and to the Sheriff of Cumberland County, directed, there will be exposed to Public Sale in Cumberland County Courthouse on March 05, 2003 at 10:00 A.M., the following described real estate, of which Dil E. Uhlin and Nicole R. Uhlin are owners or reputed owners: Twp of Hampton, Cry of Cumberland, Cmwlth of PA. HET a dwg k/a 20 Maple Ave, Camp Hill, PA 17011.Parcel#10-21-0277-101. The said Writ of Execution has issued on a judgment in the mortgage foreclosure action of National City Mortgage Co.,et a] vs. Dil E. Uhlin and Nicole R. Uhlin at No. 02-3347 CIVIL TERM in the amount of $124,990.21. Claims against property must be filed at the Office of the Sheriff before above sale date. Claims to proceeds must be made with the Office of the Sheriff before the sale date. Schedule of Distribution will be filed with the Office of the Sheriff no later than thirty (30) days from sale date. Exceptions to Distribution or a Petition to Set Aside the Sale must be filed with the Office of the Sheriff no later than ten (10) days from the date when Schedule of Distribution is filed in the Office of the Sheriff. Attached hereto is a copy of the Writ of Execution. It has been issued because there is a judgment against you. It may cause your property to be held or taken to pay the judgment. You may have legal rights to prevent your property from being taken. A lawyer can advise you more specifically of these rights. If you wish to exercise your rights you must act promptly. YOU SHOULD TAKE THIS NOTICE AND THE WRIT OF EXECUTION TO YOUR LAWYER AT ONCE. IF YOU DO NOT HAVE A LAWYER OR CANNOT AFFORD ONE, GO TO OR TELEPHONE THE OFFICE SET FORTH BELOW TO FIND OUT WHERE YOU CAN GET LEGAL ADVICE. CUMBERLAND COUNTY BAR ASSOCIATION 2 LIBERTY AVENUE CARLISLE, PA 17013 (717) 249-3166 You may have legal rights to prevent the Sheriffs Sale and the loss of your property. In order to exercise those rights, prompt action on your part is necessary. A lawyer may be able to help you. You may have the right to prevent or delay the Sheriffs Sale by filing, before the sale occurs, a petition to open or strike the judgment or a petition to stay the execution. If the judgment was entered because you did not file with the Court any defense or objection you might have within twenty (20) days after service of the Complaint for Mortgage Foreclosure and Notice to Defend, you may have the right to have the judgment opened in you promptly file a petition with the Court alleging a valid defense and a reasonable excuse for failing to file the defense on time. If the judgment is opened, the Sheriffs Sale would ordinarily be delayed pending a trial of the issue of whether the Plaintiff has a valid claim to foreclose the Mortgage. You may also have the right to have the judgment stricken if the Sheriff has not made a valid return of service of the Complaint and Notice to Defend or if the judgment was entered before twenty (20) days after service or in certain other events. To exercise this right, you would have to file a petition to strike the judgment. You may also have the right to petition the Court to stay or delay the execution and the Sheriffs Sale if you can show a defect in the Writ of Execution or service or demonstrate any other legal or equitable right. You may also have the right to have the Sheriffs Sale set aside if the property is sold for a grossly inadequate price or if there are defects in the Sheriffs Sale. To exercise this right, you should file a petition with the Court after the sale and before the Sheriff has delivered his Deed to the property. Sheriff will deliver the Deed if no petition to set aside the The sale is filed within ten (10) days from the date when the Schedule of Distribution is filed in the Office of the Sheriff. Luis P. Vitti, Esquire Attorney for Plaintiff 916 Fifth Avenue Pittsburgh, PA 15219 (412) 281-1725 "THE DEBT COLLECTOR IS ATTEMPTING TO COLLECT A DEBT AND ANY INFORMATION OBTAINED WILL BE USED FOR THAT PURPOSE." a C t:= ^I J J`; WRIT OF EXECUTION and/or ATTACHMENT COMMONWEALTH OF PENNSYLVANIA) COUNTY OF CUMBERLAND) N002-3347 Civil CIVIL ACTION - LAW TO THE SHERIFF OF CUMBERLAND COUNTY: To satisfy the debt, interest and costs due NATIONAL CITY MORTGAGE COMPANY, ASSIGNEE OF ACCUBANC MORTGAGE COMPANY, Plaintiff (s) From DIL E. UHLIN AND NICOLE R. UHLIN, 30 RAMBLEWOOD DRIVE, ETTERS, PA 17319 (1) You are directed to levy upon the property of the defendant (s)and to sell SEE LEGAL DESCRIPTION. (2) You are also directed to attach the property of the defendant(s) not levied upon in the possession of GARNISHEE(S) as follows: and to notify the garnishee(s) that: (a) an attachment has been issued; (b) the garnishee(s) is enjoined from paying any debt to or for the account of the defendant (s) and from delivering any property of the defendant (s) or otherwise disposing thereof; (3) If property of the defendant(s) not levied upon an subject to attachment is found in the possession of anyone other than a named garnishee, you are directed to notify him/her that he/she has been added as a garnishee and is enjoined as above stated. Amount Due $124,990.21 L.L. $.50 Interest $3,527.73 Atty's Comm % Due Prothy $1.00 Atty Paid $179.30 Other Costs Plaintiff Paid Date: OCTOBER 15, 2002 CURTIS R. LONG Prothonotary (Seal) y? ?.B O? a . / r/inn r . ?- Deputy REQUESTING PARTY: Name LOUIS P. VITTI, ESQUIRE Address: 916 FIFTH AVENUE PITTSBURGH, PA 15219 Attorney for: PLAINTIFF Telephone: 412-281-1725 Supreme Court ID No. 3810 oa- J3417 C,?u?[ NOTICE OF SHERIFF'S SALE OF REAL ESTATE PURSUANT TO PENNSYLVANIA RULE OF CIVIL PROCEDURE 3129.1 TO: Dil E. Uhlin Nicole R. Uhlin 30 Ramblewood Drive Etters, PA 17319 AND: ALL LIEN HOLDERS TAKE NOTICE that by virtue of the above Writ of Execution issued out of the Court of Common Pleas of Cumberland County, Pennsylvania and to the Sheriff of Cumberland County, directed, there will be exposed to Public Sale in Cumberland County Courthouse on March 05, 2003 at 10:00 A.M., the following described real estate, of which Dil E. Uhlin and Nicole R. Uhlin are owners or reputed owners: Twp of Hampton, Cty of Cumberland, Cmwlth of PA. HET a dwg k/a 20 Maple Ave, Camp Hill, PA 17011. Parcel#10-21-0277-101. The said Writ of Execution has issued on a judgment in the mortgage foreclosure action of National City Mortgage Co.,et al vs. Dil E. Uhlin and Nicole R. Uhlin at No. 02-3347 CIVIL TERM in the amount of $124,990.21. Claims against property must be filed at the Office of the Sheriff before above sale date. Claims to proceeds must be made with the Office of the Sheriff before the sale date. Schedule of Distribution will be filed with the Office of the Sheriff no later than thirty (30) days from sale date. Exceptions to Distribution or a Petition to Set Aside the Sale must be filed with the Office of the Sheriff no later than ten (10) days from the date when Schedule of Distribution is filed in the Office of the Sheriff. Attached hereto is a copy of the Writ of Execution. It has been issued because there is a judgment against you. It may cause your property to be held or taken to pay the judgment. You may have legal rights to prevent your property from being taken. A lawyer can advise you more specifically of these rights. If you wish to exercise your rights you must act promptly. YOU SHOULD TAKE THIS NOTICE AND THE WRIT OF EXECUTION TO YOUR LAWYER AT ONCE. IF YOU DO NOT HAVE A LAWYER OR CANNOT AFFORD ONE, GO TO OR TELEPHONE THE OFFICE SET FORTH BELOW TO FIND OUT WHERE YOU CAN GET LEGAL ADVICE. CUMBERLAND COUNTY BAR ASSOCIATION 2 LIBERTY AVENUE CARLISLE, PA 17013 (717) 249-3166 You may have legal rights to prevent the Sheriffs Sale and the loss of your property. In order to exercise those rights, prompt action on your part is necessary. A lawyer may be able to help you. You may have the right to prevent or delay the Sheriffs Sale by filing, before the sale occurs, a petition, to open or strike the judgment or a petition to stay the execution. If the judgment was entered because you did not file with the Court any defense or objection you might have within twenty (20) days after service of the Complaint for Mortgage Foreclosure and Notice to Defend, you may have the right to have the judgment opened in you promptly file a petition with the Court alleging a valid defense and a reasonable excuse for failing to file the defense on time. If the judgment is opened, the Sheriffs Sale would ordinarily be delayed pending a trial of the issue of whether the Plaintiff has a valid claim to foreclose the Mortgage. You may also have the right to have the judgment stricken if the Sheriff has not made a valid return of service of the Complaint and Notice to Defend or if the judgment was entered before twenty (20) days after service or in certain other events. To exercise this right, you would have to file a petition to strike the judgment. You may also have the right to petition the Court to stay or delay the execution and the Sheriffs Sale if you can show a defect in the Writ of Execution or service or demonstrate any other legal or equitable right. You may also have the right to have the Sheriffs Sale set aside if the property is sold for a grossly inadequate price or if there are defects in the Sheriffs Sale. To exercise this right, you should file a petition with the Court after the sale and before the Sheriff has delivered his Deed to the property. Sheriff will deliver the Deed if no petition to set aside the sale is filed within ten (10) days from the date when the Schedule of Distribution is filed in the Office of the Sheriff. 4uis P. Vitti, Esquire Attorney for Plaintiff 916 Fifth Avenue Pittsburgh, PA 15219 (412) 281-1725 "THE DEBT COLLECTOR IS ATTEMPTING TO COLLECT A DEBT AND ANY INFORMATION OBTAINED WILL BE USED FOR THAT PURPOSE." - .: Z ? 171 IN THE COURT OF COMMON PLEAS OF CUMBERLAND COUNTY, PENNSYLVANIA NATIONAL CITY MORTGAGE COMPANY, assignee of ACCUBANC MORTGAGE CORPORATION, CIVIL DIVISION NO.02-3347-CIVIL TERM Plaintiff, VS. DIL E. UHLIN and NICOLE R. UHLIN, AFFIDAVIT OF SERVICE Filed on behalf of Plaintiff Counsel of :record for this party: Louis P. Vitti, Esquire PA I.D. #3810 Defendant. Supreme Court #01072 Louis P. Vitti & Assoc., P.C. 916 Fifth Avenue Pittsburgh, PA 15219 (412) 281-1725 IN THE COURT OF COMMON PLEAS OF BEAVER COUNTY, PENNSYLVANIA CIVIL DIVISION NATIONAL CITY MORTGAGE COMPANY, ) assignee of ACCUBANC MORTGAGE CORP., ) Plaintiff, ) vs. ) DIL E. UHLIN and NICOLE R. UHLIN, ) Defendants. ) NO. 02-3347 CIVIL TERM AFFIDAVIT OF SERVICE I, Helen Boyce, do hereby certify that a Notice of Sale has been served upon the Defendants on January 13, 2003 Certified Mail and all Lien Holders, by Certificate of Mailing, for service in the above-captioned case on October 18, 2002, advising them of the Sheriffs sale of the property at 20 Maple Ave, Camp Hill, PA 17011-4118 on March 5, 2003. SWORN to and subscribed before me this 27th day of January, 2003. LOUIS P. VITTI &. ASSOCIATES, P.C. Helen Boyce BY D?a Notary Public NTARIAL sEAt. LOIS evAEUSTA, NOTARY pUgW CITYPITTSRGH, ALLEGHENY COUNTY MEXPIRES O CTOBER 17, 2?5 CA U.S. POSTAL SERVICE CERTIFICATE OF MAILING MAY BE USED FOR DOMESTIC AND INTERNATIONAL MAIL, DOES NOT PROVIDE FOR INSURANCE-POSTMASTER Received From: E" PITTSBURGH, FAA 1 a -1I- yr (412) One piece of ordinary mail addressed to: 2[? M 2pL2 Ave VM, PS Form 3817, January 2001 i Q u `,.1 III n u.s. POSTAL SERVICE CERTIFICATE OF MAILING MAY BE USED FOR DOMESTIC AND INTERNATIONAL MAIL, DOES NOT PROVIDE FOR INSURANCE-POSTMASTER Received From c One Piece of ordinary mail addressed to: *1 Affix fee here in stamps or meter postage and post mad: Inquire of , Postindster for current ` fee. Afro fee here in stamps or meter stage and Post n7Ark. Inquire of Postr/ial for current fee ?i ti` • F ;.{'4th :• ?L.l?(?QtIC D alt •(1f1n.['? ? t ?,,; i 1J r% A PS Form 3817, January 2 1 Mm,* S u5a(-? U.S. POSTAL SERVICE MAY BE USED FOR DOMESTIC CERTIFICATE OF MAILING PROVIDE FOR INSURANCE-POSANDD N ERNATIONAL MAIL, DOES NOT Received From. 5 One piece of ordina ry mail addressed to: n ? 1 lrr t, . n5 ?? ? t 04 3? ,. ' PS Form 3817, January 2001 All fee tiers in staplpe or meter postage and post fem. Inquirl, of Post ter for current a. 1 "YiAA i.?.) ti:?vY _ P . U.S. POSTAL SERVICE CERTIFICATE OF MAILING MAY BE USED FOR DOMESTIC AND INTERNATIONAL MAIL, DOES NOT PROVIDE FOR INSURANCE-POSTMASTER Received From: LO IS P VITTI CIS A% r11 (412) P r - One piece of ordinary mail addressed to: ? e O 1 Cavvkee- PS Form 3517, January 2001 U.S. POSTAL SERVICE Vib • U 4L? CERTIFICATE OF MAILING MAY BE USED FOR DOMESTIC AND INTERNATIONAL MAIL, DOES NOT PROVIDE FOR INSURANCE-POSTMASTER Affix fee here in stamps or meter postaga and post mark, tnquire of Postmaster for current fee. f- x s` , S 1 Affix fee haw dnsi amps or meteypostage and post park. Inquire of Posta"r for current fee. -7 x4 ,z Received From: LOUIS P V1TTI & ASkt I.? One piece of ordinary mail addressed to: l Ar ,r-fS ?,rirn1llQll?f`li,'1 t'?fi5?mn ??'t?.....,.?'. t-r- _ rY ha SSE Stn' ,nro. PS Form 3817, January 2001 L? QQ ?l I r, 1-i)• U.S. POSTAL SERVICE CERTIFICATE OF MAILING MAY BE USED FOR DOMESTIC AND INTERNATIONAL MAIL, DOES NOT PROVIDE FOR INSURANCE-POSTMASTER ReceivedFront-OlIS P VITTI & ASS0Gj-, 916 FIFTW A\/CSL It 1412) 281- One piece of ordinary mail addressed to: LJUen14 \ 4 Pa - 11PI . r..: - Affix fee here in stamps or meter postage and post mark. Inquire of Postmaster for current fee. . -0?-iV i s .0 co Po. (bolf Arw,?%-%Ihum PA tr o? =J PS Form 3817, January 2001 U.S. POSTAL SERVICE CERTIFICATE OF MAILING MAY BE USED FOR DOMESTIC AND INTERNATIONAL MAIL, DOES NOT PROVIDE FOR INSURANCF_Pncneecrco Received From'`, u f v rI V11 13 `? 916 FIFTH AVENUU.: PA 1? One Piece of ordinary mail addressed to: r V Ck-, cv-d %T? i PS Form 3817, January 2001 1.0 k4j. OYL zml EPROVID?EE STAL SECE TE OF MAILING O 14 _RA_ ED FOR DOMESTIC AND INTERNATIONAL MAIL, DOES NOT Received From: - r V11 if 6 ? 918 FIFT$ x . n i-r-, Ili Ak Affoc fee he%in stamps or meteroostage and Post mSrk. Inquire of Postme erforcurrent fee. 'y r Affix fee here in stamps or meter postage and post mark. Inquire of Postmaster for current fee. .1't One Piece of ordinary mail addressed to: Qp a t .?.19wC Y 4 Form 3817, January 2001 ,, oo M„ ?'O . U r ut..l/rv U.S. POSTAL SERVICE CERTIFICATE OF MAILING MAY BE USED FOR DOMESTIC AND INTERNATIONAL Affor fee here in stamps URANCE_pOAND I- ER MAIL, DOES NOT or meter Postage and PROVIDE FOR INSURANCE Post mark. Inquire of Received %4: P V I A c? Postmaster fDr, current tr tJ TTI & fee. PITTSBURGH PA 1. ?.-? (412)281- 25 One Piece of ordinary mail addressed to: ` f "`wJ n 3 ?. 1 J ?rn ? a ??1 r] Cl ? - "5 , fly r :"?." PS Form 3817, January 2001 L ?N g I'll U.S. POSTAL SERVICE CERTIFICATE OF MAILING MAY BE USED FOR DOMESTIC AND INTERNATIONAL AM, fee here in k PROVIDE FOR INSURANCE-POSTMASTER MAIL, DOES NOT ?tf(+ Q /? h? ^? or melar Postage ato re of, f9rireof Received C tS "' "TM' a AS(? 7t CLi, PoSfmararks for t R VI' ° p .; a to feestMP o:`; te 916 FIFTH AVFNur PITTSBURGH, PA 15?^;,R4 ?.. L One piece of ordinary mail addressed to: ',? ? tv n l? ' F PS Form 3817, January 2001 Le,- tjh1 •3 5 o-Z f? - C - r G ' c c. f_ ccn w ?C cT COMMONWEALTH OF PENNSYLVANIA COUNTY OF CUMBERLAND I SS: I, Robert P. Ziegler, Recorder of Deeds in and for said County and State do hereby certify that the Sheriff's Deed in which National City Mtg Co is the grantee the same having been sold to said grantee on the 5th day of March A.D., 2003, under and by virtue of a writ Execution issued on the 15th day of October, A.D., 2002, out of the Court of Common Pleas of said County as of Civil Term, 2002 Number 3347, at the suit of National City Mtg Co against Dil E Uhlin Jr & Nicole R is duly recorded in Sheriff's Deed Book No. 256, Page 2845. IN TESTIMONY WHEREOF, I have hereunto set my hand and seal of said office this / &o day of A.D. 2003 of Deeds lNoordK dD??, 0uebMird Orlwl?,'11 My GomrNWonE?pinsllrFlr?tAA 1dJm.?00? National City Mortgage Company In The Court of Common Pleas of Assignee of Accubanc Mortgage Cumberland County, Pennsylvania Corporation Writ No. 2002-3347 Civil Term VS Dil E. Uhlin, Jr. and Nicole R. Uhlin R. Thomas Kline, Sheriff, who being duly sworn according to law, states that he made a diligent search and inquiry for the within named defendant, to wit: Dil E. Uhlin, Jr., but was unable to locate him in his bailiwick. He therefore deputized the Sheriff of York County, Pennsylvania to serve the within Real Estate Writ, Notice and Description, in the above entitled action, according to law. YORK COUNTY RETURN: Served the within named defendant, Dil Uhlin on November 18, 2002 at 7:52 o'clock PM by handing to Dil Uhlin, at 30 Ramblewood Drive, Etters, PA 17319, a true and correct copy of the within Real Estate Writ, Notice and Description, and making known unto him the contents thereof. R. Thomas Kline, Sheriff, who being duly sworn according to law, states that he made a diligent search and inquiry for the within named defendant, to wit: Nicole R. Uhlin, but was unable to locate her in his bailiwick. He therefore deputized the Sheriff of York County, Pennsylvania to serve the within Real Estate Writ, Notice and Description, in the above entitled action, according to law. YORK COUNTY RETURN: Served the within named defendant, Nicole R. Uhlin on November 18, 2002 at 7:52 o'clock PM by handing to Dil Uhlin, adult in charge for defendant, at 30 Ramblewood Drive, Etters, PA 17319, a true and correct copy of the within Real Estate Writ, Notice and Description, and making known unto him the contents thereof. Michael Barrick, Deputy Sheriff, who being duly sworn according to law, states that on January 08, 2003 at 6:47 o'clock P.M., he posted a true copy of the within Real Estate Writ, Notice, Poster and Description, in the above entitled action, upon the property of Dil E. Uhlin, Jr. and Nicole R. Uhlin located at 20 Maple Ave., Camp Hill, 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 one of the within named defendants, to wit: Dil E. Uhlin, Jr. by regular mail to his last known address of 30 Ramblewood Drive, Etters, PA 17319. This letter was mailed under the date of January 13, 2003 and never returned to the Sheriffs Office. 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 one of the within named defendants, to wit: Nicole R. Uhlin by regular mail to her last known address of 30 Ramblewood Drive, Etters, PA 17319. This letter was mailed under the date of January 13, 2003 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 5, 2003 at 10:00 o'clock A.M. He sold the same for the sum of $1.00 to Attorney Louis Vitti for National City Mortgage Co.. It being the highest bid and best price received for the same, National City Mortgage Co. of 3232 Newmark Drive, Miamisburg, OH 45342, being the buyer in this execution, paid to Sheriff R. Thomas Kline the sum of $5,000.00. Sheriffs Costs: Docketing $30.00 Poundage 700.00 Posting Bills 15.00 Advertising 15.00 Acknowledging Deed 30.00 Auctioneer 10.00 Law Library .50 Prothonotary 1.00 Mileage 8.97 Certified Mail 3.10 Levy 15.00 Surcharge 30.00 Law Journal 302.60 Patriot News 272.53 Share of Bills 25.21 Distribution of Proceeds 25.00 Sheriffs Deed 39.50 $1,523.41 Sworn and subscribed to before me So . This 30 q--1 day of r R. Thomas Kline, Sheriff 2003, A.D. A?q ro onotary By Real state eputy WY- o y l 9j--' PROOF OF PUBLICATION OF NOTICE IN CUMBERLAND LAW JOURNAL (Under Act No. 587, approved May 16, 1929), P. L.1784 STATE OF PENNSYLVANIA : COUNTY OF CUMBERLAND : ss. Lisa Marie Coyne, Esquire, Editor of the Cumberland Law Journal, of the County and State aforesaid, being duly sworn, according to law, deposes and says that the Cumberland Law Journal, a legal periodical published in the Borough of Carlisle in the County and State aforesaid, was established January 2, 1952, and designated by the local courts as the official legal periodical for the publication of all legal notices, and has, since January 2, 1952, been regularly issued weekly in the said County, and that the printed notice or publication attached hereto is exactly the same as was printed in the regular editions and issues of the said Cumberland Law Journal on the following dates, viz: JANUARY 31, FEBRUARY 7, 14, 2003 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. 18 Writ No. 2002-3347 Civil National City Mortgage Company, assignee of Accubanc Mortgage Corporation V9. Dil E. Uhlin, Jr. and Nicole R. Uhlin Atty.: Louis P. Vitti LEGAL DESCRIPTION All that certain lot of land situ- ated in the Township of Hampton, County of Cumberland and State of Pennsylvania, more Pennsylvania, more particularly bounded and de- scribed as follows, to wit: Beginning at a point on the West- ern line of Maple Avenue as shown on the Plan of Lots hereinafter re- ferred to said point being three hun- dred twenty-seven and six tenth (327.6) feet measured Southwardly along the Western line of said Maple f Lisa Marie Coyne/Aitor SWORN TO AND SUBSCRIBED before me this 14 day of FEBRUARY. 2003 LOIS E. Avenue from the Southwest corner of Maple Avenue and Carlisle Turn- pike; thence in a Westerly direction along a line at right angles with Ma- ple Avenue; one hundred fifty (150) feet to a point; thence in a Souther- ly direction along a line parallel with Maple Avenue, sixty (60) feet to a point; thence in an Easterly direc- tion along a line at right angles with Maple Avenue, one hundred fifty (150) feet to Maple Avenue; thence in a Northerly direction along the Western line of Maple Avenue, sixty (60) feet to a point the place of be- ginning. Being Lot No. 20 on Revised Plan of Maple Avenue, Oakwood Park, Hampton Township, Cumberland County, Pennsylvania, said Plan be- ing recorded in the Office of the Re- corder of Deeds in and for said County of Cumberland in Plan Book 3, page 52. Having erected thereon a dwell- ing known as 20 Maple Ave, Camp Hill, PA 17011. Parcel #10-21-0277-101. Being the same premises which Richard L. Moyer and Jean C. Moyer by their deed 01/31/2000 and re- corded on 04/04/2000 in the Re- corder of Deeds Office in Cumber- land County, Pennsylvania granted and conveyed Dil E. Uhin, Jr. and Nicole R. Uhlin. . 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 JOSEPH A. DENNISON being duly sworn according to law, deposes and says: That he is the Asst. 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 28th day(s) of January and the 4th and 11th day(s) of February 2003. 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 SALE #18 REAL ESTATE SALE No. ]s Writ No. 2002-3347 Civil Term National City Mortgage Co., Assignee of Accubanc Mortgage Corporation vs DII E. Uhlin, Jr. and Nicole R. Uhlln ALouis P. I DESCRIPTION ALL that certain lot of land situated in the Township of Hampton, County of Cumberland and State of Pennsylvania, more particularly bounded and described as follows, to wit: BEGINNING at a point on the Western line of Maple Avenue as shown on the Plan of Lots hereinafter referred to said point being three hundred twenty-seven and six-tenths (327.6) feet measured Southwardly along the Western line of said Maple Avenue from the Southwest comer of Maple Avenue and Carlisle Turnpike; thence in a Westerly direction along a line at right angles Notarial Seta./ Terry L. Russell, Notary Public City Of Harrisburg, Dauphin County _ My Commission Expires June 6, 2006 Member, Pennsylvania Association Of Notaries ...f?_.'."Z m s 14th day Fe ry 2003 A. D. A7 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 $ 270.78 $ 1.75 $ 272.53 with Maple Avenue: one hundredfifty(150)feet 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. to a point; thence in a Southerly direction along a line parallel with Maple Avenue, sixty (60) feet to a point; thence in an Easterly direction along a line at right angles with Maple Avenue, one hundred fifty (150) feet to Maple Avenue; thence in a Northerly direction along the Western line of Maple Avenue, sixty (60) feet to a point the place of BEGINNING. BEING Lot No. 20 on Revised Plan of Maple Avenue, Oakwc)d Park, Hampton Township, Cumberland County, Pennsylvania, said Plan being recorded in the Office of the Recorder of Deeds in and for s id County of Cumberland in Plan Book 3, page n. By ............. HAVING erected thereon a dwelling known as 20 Maple Ave., Camp Hill, PA 17011. PARCEL #10-21-0277-101. BEING the same premises which Richard L. Moyer and Jean C. Moyer by their deed 011311 2000 and recorded on 04/04/2000 in the Recorder of Deeds Office in Cumberland County, . Pennsylvania granted and conveyed Dil E. Uhlin, Jr. and Nicole R. Uhlin.