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HomeMy WebLinkAbout02-3976FEDERAL NATIONAL MORTGAGE ASSOCIATION Plaintiff vs. 02 TANJA A. JUMPER Defendant IN THE COURT OF COMMON PLEAS CUMBERLAND COUNTY, PENNSYLVANIA JFL CIVIL ACTION - LAW ACTION OF MORTGAGE FORECLOSURE THIS FIRM IS A DEBT COLLECTOR AND WE ARE ATTEMPTINGTO COLLECT A DEBT OWED TO OUR CLIENT. ANY INFORMATION OBTAINED FROM YOU WILL BE USED FOR THE PURPOSE OF COLLECTING THE DEBT. NOTICE You have been sued in court. If you wish to defend against the claims set forth in the following pages, you must take action within twenty (20) days after the Complaint and notice are served, by entering a written appearance personally or by attorney and filing in writing with the court your defenses or objections to the claims set forth against you. You are warned that if you fail to do so the case may proceed without you and a judgment may be entered against you by the Court without further notice for any money claim in the Complaint of for any other claim or relief requested by the Plaintiff. You may lose money or property or other rights important to you. YOU SHOULD TAKE THIS PAPER TO YOUR LAWYER AT ONCE. IF YOU DO NOT HAVE A LAWYER OR CANNOT AFFORD ONE, GO TO OR TELEPHONE THE OFFICE SET FORTH BELOW TO FIND OUT WHERE YOU CAN GET LEGAL HELP. CUMBERLAND COUNTY LAWYER REFERRAL SERVICE CUMBERLAND COUNTY BAR ASSOCIATION 2 LIBERTY AVENUE CARLISLE, PA 17013 717-249-3166 AVISO LE HAN DEMANDADO A USTED EN LA CORTE. SI DESEA DEFENDERSE CONTRA LAS QUEJAS PERESENTADAS, ES ABSOLUTAMENTE NECESSARIO QUE USTED RESPONDA DENTRO DE 20 DIAS DESPUES DE SER SERVIDO CON ESTA DEMANDA Y AVISO. PARA DEFENDERSE ES NECESSARIO QUE USTED, O SU ABOGADO, REGISTRE CON LA CORTE EN FORMA ESCRITA, EL PUNTO DE VISTA DE USTED Y CUALQUIER OBJECCION CONTRA LAS QUEJAS EN ESTA DEMANDA. RECUERDE: SI USTED NO REPONDE A ESTA DEMANDA, SE PUEDE PROSEGUIR CON EL PROCESO SIN SU PARTICIPACION. ENTONCES, LA COUTE PUEDE, SIN NOTIFICARIO, DECIDIR A FAVOR DEL DEMANDANTE Y REQUERIRA QUE USTED CUMPLA CON TODAS LAS PROVISIONES DE ESTA DEMANDA. POR RAZON DE ESA DECISION, ES POSSIBLE QUE USTED PUEDA PERDER DINERO, PROPIEDAD U OTROS DERECHOS IMPORTANTES. LLEVE ESTA DEMANDA A UN ABOGADO IMMEDIATEAMENTE. SI NO CONOCE A UN ABOGADO, LLAME AL "LAWYER REFERENCE SERVICE" (SERVICIO DE REFERENCIA DE ABOGADOS), (215) 238-6300. CUMBERLAND COUNTY LAWYER REFERRAL SERVICE CUMBERLAND COUNTY BAR ASSOCIATION 2 LIBERTY AVENUE CARLISLE, PA 17013 717-249-3166 FEDERAL NATIONAL MORTGAGE ASSOCIATION, Plaintiff vs. TANJA A. JUMPER, Defendant IN THE COURT OF COMMON PLEAS CUMBERLAND COUNTY, PENNSYLVANIA CIVIL ACTION LAW ACTION OF MORTGAGE FORECLOSURE THE FOLLOWING NOTICE IS BEING PROVIDED PURSUANT TO THE FAIR DEBT COLLECTION PRACTICES ACT, 15 U.S.C. 1601 The undersigned attorney is attempting to collect a debt owed to the Plaintiff, and any information obtained will be used for that purpose. The amount of the debt is stated in this Complaint. Plaintiff is the creditor to whom the debt is owed. Unless the Debtor, within thirty (30) days after your receipt of this notice disputes the validity of the aforesaid debt or any portion thereof owing to the Plaintiff, the undersigned attorney will assume that said debt is valid. If the Debtor notifies the undersigned attorney in writing with the said thirty (30) day period that the aforesaid debt, or any portion thereof , is disputed, the undersigned attorney shall obtain written verification of the said debt from the Plaintiff and mail same to Debtor. Upon written request by Debtor to the undersigned attorney within said thirty (30) day period, the undersigned attorney will provide debtor with the name and address of the original creditor if different from the current creditor. PURCELL, KRUG & HALLER 1719 North Front Street Harrisburg, PA 17102 (717) 234-4178 Attorney LD.# 15700 Attorney for Plaintiff FEDERAL NATIONAL MORTGAGE ASSOCIATION, Plaintiff VS. TANJA A. JUMPER, Defendant IN THE COURT OF COMMON PLEAS CUMBERLAND COUNTY, PENNSYLVANIA CIVIL ACTION - LAW ACTION OF MORTGAGE FORECLOSURE COMPLAINT IN MORTGAGE FORECLOSURE 1. Plaintiff, FEDERAL NATIONAL MORTGAGE ASSOCIATION, is a Corporation originated under an Act of Congress and existing pursuant to the Federal National Association Charter Act, acting through its servicing agent of Homeside Lending, Inc., with an address of 8120 Nations Way, Jacksonville, Florida 32256. 2. Defendant, TANJA A. JUMPER, is an adult individual, whose last known address is 16 INDEPENDENCE DRIVE, SHIPPENSBURG, PENNSYLVANIA 17257. 3. On or about, June 30, 2000, the said Defendant, executed and delivered a Mortgage Note in the sum of $132,900.00 payable to HOME FINANCE OF AMERICA, which Note is attached hereto and marked Exhibit "A". 4. Contemporaneously with and at the time of the execution of the aforesaid Mortgage Note, in order to secure payment of the same, Defendant made, executed, and delivered to original Mortgagee, a certain real estate Mortgage which is recorded in the Recorder of Deeds Office of the within County and Commonwealth in Mortgage Book 1522, Page 1060 conveying to original Mortgagee the subject premises. The Mortgage was Re-recorded in the aforesaid County in Mortgage Book 1665, Page 1060. The Mortgage was subsequently assigned to HOMESIDE LENDING, INC. and recorded in the aforesaid County in Mortgage Book 648, Page 333. The Mortgage was subsequently assigned to FEDERAL NATIOAL MORTGAGE ASSOCIATION and sent for recording. The Said Mortgage and Assignments are incorporated herein by reference. 5. The land subject to the Mortgage is: 16 INDEPENDENCE DRIVE, SHIPPENSBURG, PENNSYLVANIA 17257 and is more particularly described in Exhibit "B" attached hereto. 6. The said Defendant is the real owner of the property. 7. The Mortgage is in default due to the fact that Mortgagor has failed to pay the installment due on April 01, 2002 and all subsequent installments thereon, and the following amounts are due on the Mortgage: UNPAID PRINCIPAL BALANCE Interest at $30.07 per day From 03/01/2002 To 09/01/2002 ( based on contract rate of 8.375%) Accumulated Late Charges Late Charges $50.51 From 04/01/2002 to 09/01/2002 Escrow Balance Attorney's Fee at 5% of Principal Balance TOTAL $131,081.61 $6,434.98 $404.08 $353.56 $0.00 $6,554.08 $144,829.21 "Together with interest at the per diem rate noted above after September 01, 2002 and other charges and costs to date of Sheriff's Sale. The attorney's fees set forth above are in conformity with the Mortgage documents and Pennsylvania law, and will be collected in the event of a third party purchaser at Sheriff's Sale. If the Mortgage is reinstated prior to the sale, reasonable attorney's fees will be charged that are actually incurred by Plaintiff. 8. No judgment has been entered upon said Mortgage in any jurisdiction. 9. Notice of intention to foreclose and accelerate the loan balance pursuant to Pennsylvania Act No. 6 of 1974 is not required in that the original principal balance exceeds $50,000.00. 10. Defendant is not a member of the Armed Forces of the United States of America, nor engaged in any way which would bring her within the Soldiers and Sailors Relief Act of 1940, as amended. 11. Plaintiff has complied with the procedures required by Pennsylvania Act 91 of 1983 (Homeowners' Emergency Mortgage Assistance Payments Program) and Defendant has either failed to meet the time limitations as set forth therein or has been determined by the Housing Finance Agency not to qualify for assistance. WHEREFORE, Plaintiff demands judgment in mortgage foreclosure "IN REM" for the aforementioned total amount due together with interest at the rate of 8.375% ($30.07 per diem), together with other charges and costs including escrow advances incidental thereto to the date of Sheriff's Sale and for foreclosure and sale of the property within described. By:_ PURCELL,KRUG & HALLER Leon P. Haller, Esquire Attorney for Plaintiff I.D. # 15700 1719 N. Front Street Harrisburg, PA 17102 (717-234-4178) Hs182496.tit (1696x2800x2 titt) l3) ,??i}I+'..'ATR?"+?9;^n.T.nRTen µ?}rpq.?g}{p. 1PCt Tt"?Yr?MN qy Ilww .. 1 ? U ? Id1 M? , ? . . - . 1HlYi M i1»1f i. wwlwwwa Iswim M"7o. -40 = W.1 ?ga?wwwrW ?- ll7.ilb 00 ' W,rMwnslOd 'I 7 yyw NryMlMll-W+W Y+lMM?r ' My.91t,w1rw ?rws.W , ,. ,. .. 11 IMw+f Ot/Ifw?'?1?W?l11MiSM ?4eYM AF s " MANN IIfl , .? n`-* • .: •11+S.wsi1`' Wdt' 'SbMnWiwW YO'Inl?#wlalfWYW'1/bS.gNtll}IIFip4!'? iyy ? r. A'sMf. tl M1 r C Y Nfj' " L IM li r -IA L`y ' x 1 Sy t MW a. ' "x. . 9Y r' wa Lyr(e) HS182496.tit (1696x2800x2 titt) L41 _.M . 7.1 I YM M 4. ?pMVt}a, ? i 4 - YML'M?gM®Yg1101? YyM?r?4w11M?+1i t ? Y ? t y S l F C'i 7 Hsi82496.tit (169.6x2800x2 titt) 17) COMPANY NAME: FEEffAL rYTTaMI, MIUMM zaa AMM Mum ris sFIWICM PL}IVr C' I- 24= I EUDG, II1C. VERIFICATION I verify that the statements made in the foregoing Complaint are true and correct. 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. Dated x= 19, 2oo2 Tracy Johnson Vice a"Wwit ?J r i ce-I FEDERAL NATIONAL MORTGAGE ASSOCIATION, PLAINTIFF VS. TANJA A. JUMPER, DEFENDANT IN THE COURT OF COMMON PLEAS CUMBERLAND COUNTY, PENNSYLVANIA CIVIL ACTION - LAW NO. 2002 3976 IN MORTGAGE FORECLOSURE P R A E C I P E TO THE PROTHONOTARY OF THE WITHIN COUNTY: Please enter JUDGMENT "in rem" in favor of the Plaintiff and against Defendants TANJA A. JUMPER for failure to plead to the above action within twenty (20) days from date of service of the Complaint, and assess Plaintiff's damages as follows: Unpaid principal balance $131,081.61 Interest $ 6,434.98 (Per diem of $30.07 from 3/1/02 to 9/1/02) Accumulated late charges $ 404.08 Late charges $ 353.56 ($50.51 per month to 9/02) Escrow Deficit $ 5% Attorney's Commission $ 6,554.08 TOTAL $144,828.31** ** Together with additional interest at the per diem rate indicated above from the date herein, based on the contract rate, and other charges and costs to the date of Sheriff's Sale. PURCELL, KRUG & By Leon P. Haller PA I.D. #15700 1719 North Front Street Harrisburg, PA 17102 (717) 234-4178 KAMKF\DOCS\CUMBERLXJUMPER.P FEDERAL NATIONAL MORTGAGE ASSOCIATION, VS. PLAINTIFF TANJA A. JUMPER, DEFENDANT IN THE COURT OF COMMON PLEAS CUMBERLAND COUNTY, PENNSYLVANIA CIVIL ACTION - LAW NO. 2002 3976 IN MORTGAGE FORECLOSURE CERTIFICATE OF SERVICE PURSUANT TO PA. R.C.P. 237.1 I hereby certify that on SEPTEMBER 18, 2002 I served the Ten Day Notice required by Pa. R.C.P. 237.1 on the Defendant(s) in this matter by regular first class mail, postage prepaid, as indicated on the attached Notice. By Leon P. Haller PA I.D. ##15700 Attorney for Plaintiff Purcell, Krug & Haller 1719 North Front St. Harrisburg, PA 17102 FEDERAL NATIONAL MORTGAGE ASSOCIATION Plaintiff VS. IN THE COURT OF COMMON PLEAS CUMBERLAND COUNTY, PENNSYLVANIA NO. 02-3976 TANJA A. JUMPER Defendant CIVIL ACTION LAW IN MORTGAGE FORECLOSURE DATE OF THIS NOTICE: September 18, 2002 TO: TANJA A. JUMPER 16 INDEPENDENCE DRIVE SHIPPENSBURG, PA 17257 THIS LAW FIRM IS A DEBT COLLECTOR AND WE ARE ATTEMPTING TO COLLECT A DEBT OWED TO OUR CLIENT. ANY INFORMATION OBTAINED FROM YOU WILL BE USED FOR THE PURPOSE OF COLLECTING THE DEBT. IMPORTANT NOTICE YOU ARE IN DEFAULT BECAUSE YOU HAVE FAILED TO ENTER A WRITTEN APPEARANCE PERSONALLY OR BY ATTORNEY AND FILE IN WRITING WITH THE COURT YOUR DEFENSES OR OBJECTIONS TO THE CLAIMS SET FORTH AGAINST YOU. UNLESS YOU ACT WITHIN TEN (10) DAYS FROM THE DATE OF THIS NOTICE, A JUDGMENT MAY BE ENTERED AGAINST YOU WITHOUT A HEARING AND YOU MAY LOSE YOUR PROPERTY OR OTHER IMPORTANT RIGHTS. YOU SHOULD TAKE THIS NOTICE TO A LAWYER AT ONCE. IF YOU DO NOT HAVE A LAWYER OR CANNOT AFFORD ONE, GO TO OR TELEPHONE THE FOLLOWING OFFICE TO FIND OUT WHERE YOU CAN GET LEGAL HELP: CUMBERLAND COUNTY LAWYER REFERRAL SERVICE CUMBERLAND COUNTY BAR ASSOCIATION 2 LIBERTY AVENUE CARLISLE, PA 17013 717-249-3166 800-990-9108 PURCELL, KRUG & H R LEON P. HALLER, Attorney for Plaintiff I.D. # 15700 1719 N. Front St., Harrisburg, PA 17102 (717) 234-4178 FEDERAL NATIONAL MORTGAGE ASSOCIATION, VS. PLAINTIFF TANJA A. JUMPER, DEFENDANT CIVIL ACTION - LAW NO. 2002 3976 IN MORTGAGE FORECLOSURE NON-MILITARY AFFIDAVIT COMMONWEALTH OF PENNSYLVANIA COUNTY OF DAUPHIN IN THE COURT OF COMMON PLEAS CUMBERLAND COUNTY, PENNSYLVANIA SS Personally appeared before me, a Notary Public in and for said Commonwealth and County, LEON P. HALLER, ESQUIRE who being duly sworn according to law deposes and states that the Defendant (s) above named are not in the Military or Naval Service nor are they engaged in any way which would bring them within the Soldiers and Sailors Relief Act of 1940, as amended. Sworn to and subscribed before me this o2_ day of 20v? 49"y Pu lic NOTARIAL SEAL MARYLAND K. FERRETTI, Notary Public Lower Paxton Twp., Dauphin County My Commission Expires Aug. 8, 2006 LEON V. HALLER, ESQUIRE c? C-7) ^ ` - ?.... IN THE COURT OF COMMON PLEAS OF CUMBERLAND COUNTY, PENNSYLVANIA CIVIL DIVISION - LAW AT NO. 2002 3976 FEDERAL NATIONAL MORTGAGE ASSOCIATION, PLAINTIFF VS. TANJA A. JUMPER, DEFENDANT(S) TOTAL AMOUNT OF JUDGMENT $144,828.31 Interest at $30.07 per diem to sale date $ 5,562.95 Late charges at $50.51 per month to sale date $ 252.55 Escrow Deficit $ 2,000.00 TOTAL $152,643.81* *SALE DATE: WEDS.,MARCH 5, 2003 (PROTHONOTARY'S USE) Plaintiff Attorney Sheriff This Writ PRAECIPE FOR WRIT OF EXECUTION MORTGAGE FORECLOSURE - P.R.C.P. 3180-3183 TO THE PROTHONOTARY/CLERK OF SAID COURT: Issue Writ of Execution in the above captioned case. Date: December 2, 2002 Attorney for Plaintiff 1719 North Front Street Leon P. Haller Harrisburg, PA 17102 PA I.D. #15700 (717) 234-4178 WRIT OF EXECUTION - MORTGAGE FORECLOSURE COMMONWEALTH OF PENNSYLVANIA COUNTY OF CUMBERLAND SS TO THE SHERIFF OF CUMBERLAND COUNTY: To satisfy the judgment, interest and costs in the above captioned case, you are directed to levy upon and sell the property described in the attached description known as 16 INDEPENDENCE DRIVE, SHIPPENSBURG, PA 17257. Date: PROTHONOTARY/CLERK CIVIL DIVISION BY DEPUTY K:\M KF\DOCS\CUMBERLA\J UMP. W ww 'c4 ?c c? y Cr( ? ! I 1 l {li{" y 1 ALL the following described real estate, together with improvements thereon erected, lying and being Southampton Township, situate in particularly described Cumberland County, Pennsylvania, more as fGl.Ioy;s: BEGINNING at a point on the southerly side of Independence Drive at corner of Lot D12 on the hereinafter referred to plan of lots; thence by said Lot D12, South 38 degrees 24 minutes 45 seconds West 152.39 feet to a ccncrete monument at other lands of the Grantors herein; thence by said other lands of the Grantor herein, North 62 degrees 25 minutes 25 seconds West 95.65 feet to a concrete monument;' thence by the same, Ncrth 13 degrees 31 minutes 30 seconds West 47.66 feet to a point at corner of Lot D10 on said plan of lots; thence by said Lot D10, North 5S degrees 57 minutes 6 seconds East 161.27 feet to a point on the southerly side of Independence Drive; thence with the southerly side of Independence Drive, on a curve to the left having a radius of 275 feet, a chord bearing of South 42 degrees 49 minutes 4 seconds East and a chord length of 63.85 feet to a point, the place of beginning, containing 18,238 square feet. - BEING Lot Dll on subdivision plan prepared by Carl D. Bert dated June 26, 1998, entitled "Land Subdivision for Line Estates, Phases I and II," and recorded in Cumberland County, Pa., Plan Book 77, Page 64. HAVING THEREON ERECTED A RESIDENTIAL DWELLING HOUSE KNOWN AS 16 INDEPENDENCE DRIVE, SHIPPENSSURG, PA 17257 BEING THE SAME PREMISES WHICH J. Gary Rine and Virginia B. Rine by deed dated 6/19/00 and recorded 7/3/00 in Deed Book 224 Page 687 granted and conveyed unto Tanja A. Jumper. TO BE SOLD AS THE PROPERTY OF TANJA A. JUMPER ON JUDGMENT NO. 2002 3976. ASSESSMENT # 39-37_2092_079 FEDERAL NATIONAL MORTGAGE ASSOCIATION, PLAINTIFF VS. TANJA A. JUMPER, DEFENDANT IN THE COURT OF COMMON PLEAS CUMBERLAND COUNTY, PENNSYLVANIA CIVIL ACTION - LAW NO. 2002 3976 IN MORTGAGE FORECLOSURE AFFIDAVIT PURSUANT TO P.R.C.P. 3129.1 The Plaintiff in the above action, by its attorneys, Purcell, Krug & Haller, sets forth as of the date the praecipe for the writ of execution was filed, the following information concerning the real property located at 16 INDEPENDENCE DRIVE, SHIPPENSBURG, PA 17257: 1. Name and address of the Owner(s) or Reputed Owner(s): Tanja A. Jumper 16 Independence Drive Shippensburg, PA 17257 2. Name and address of Defendant(s) in the Judgment, if different from that listed in (1) above: SAME 3. Name and address of every judgment creditor whose judgment appears of record on the real property to be sold: 4. Name and address of last recorded holder of every mortgage of record: PLAINTIFF HEREIN (AND ANY OTHERS AS NOTED BELOW): GMAC Mortgage Corportion d/b/a Ditech.com 3200 Park Center Drive Suite 150 Costa Mesa, CA 92626 5. Name and address of every other person who has any record lien on the property: KWKFDOCSVCUMBERLAWUMP.PTF UNKNOWN 6. Name and address of every other person who has any record interest in the property and whose interest may be affected by the sale: UNKNOWN 7. Name and address Plaintiff has knowledge who may be affected by the sale: of every other person of whom the has any interest in the property which TENANTS IF ANY ... Troy Bigler 16 Independence Drive Shippensburg, PA 17257 Domestic Relations Office Cumberland County Courthouse Hanover & High Streets Carlisle, PA 17013 (In the preceding information, where addresses could not be reasonably ascertained, the same is indicated.) I verify that the statements made in this Affidavit are true and correct to the best of my personal knowledge, information and belief. I understand that false statements herein are made subject to the penalties of 18 PA C.S. Section 4904 relating to unsworn falsification to authorities. Leon P. Haller P I.D. #15700 Purcell, Krug & Haller 1719 North Front Street Harrisburg, PA 17102 (717) 234-4178 DATE: December 2, 2002 FEDERAL NATIONAL MORTGAGE ASSOCIATION, PLAINTIFF VS. TANJA A. JUMPER, DEFENDANT IN THE COURT OF COMMON PLEAS CUMBERLAND COUNTY, PENNSYLVANIA CIVIL ACTION - LAW NO. 2002 3976 IN MORTGAGE FORECLOSURE NOTICE OF SHERIFF'S SALE OF REAL ESTATE PURSUANT TO PENNSYLVANIA RULE OF CIVIL PROCEDURE 3129 TAKE NOTICE: held: That the Sheriff's Sale of Real Property (real estate) will be DATE: WEDNESDAY, March 5, 2003 TIME: 10:00 O'clock A.M. LOCATION: Commissioner's Hearing, Room 2nd Floor Cumberland. County Courthouse Carlisle, Pennsylvania 17013 THE PROPERTY TO BE SOLD is delineated in detail in a legal description mainly consisting of a statement of the measured boundaries of the property, together with a brief mention of the buildings and any other major improvements erected on the land. (SEE DESCRIPTION ATTACHED) THE LOCATION of your property to be sold is: 16 INDEPENDENCE DRIVE SHIPPENSBURG CUMBERLAND COUNTY PENNSYLVANIA THE JUDGMENT in the amount of $144,828.31 under or pursuant to which your property is being sold is docketed in the within Commonwealth and County to: NO. 2002 3976 is: THE NAME (S) OF THE OWNER (S) OR REPUTED OWNERS of this property TANJA A. JUMPER - REAL OWNER A SCHEDULE OF DISTRIBUTION, being a list of the persons and/or governmental or corporate entities or agencies being entitled to receive part of the proceeds of the sale received and to be disbursed by the Sheriff (for example, to banks that hold mortgages and municipalities that are owed taxes) will be filed by the Sheriff of this County thirty (30) days after the sale and distribution of the proceeds of sale in accordance with this schedule will, in fact, be made unless someone objects by filing exceptions to it within ten (10) days of the date it is filed. Information about the Schedule of Distribution maybe obtained from the Sheriff of the Court of Common Pleas of the within County at the Courthouse address specified herein. THIS PAPER IS A NOTICE OF THE TIME AND PLACE OF THE SALE OF YOUR PROPERTY. IT HAS BEEN ISSUED BECAUSE THERE IS A JUDGMENT AGAINST YOU. IT MAY CAUSE YOUR PROPERTY TO BE HELD TO BE SOLD OR TAKEN TO PAY THE JUDGMENT. You may have legal rights to prevent your property from being taken away. A lawyer can advise you more specifically of these rights. If you wish to exercise your rights, YOU MUST ACT PROMPTLY. YOU SHOULD TAKE THIS PAPER TO YOUR LAWYER AT ONCE. GO TO OR TELEPHONE THE OFFICE SET FORTH BELOW TO FIND OUT WHERE YOU CAN GET FREE LEGAL ADVICE: Cumberland County Bar Association 2 Liberty Avenue Carlisle, Pennsylvania 17013 717-249-3166 Legal Services, Inc. B Irvine Row Carlisle, PA 17013 717-243-9400 THE LEGAL RIGHTS YOU MAY HAVE ARE: I. You may file a petition with the Court of Common Pleas of the within County to open the judgment if you have a meritorious defense against the person or company that has entered judgment against you. You may also file an petition with the same Court if you are aware of a legal defect in the obligation or the procedure used against you. After the Sheriff's Sale you may file a petition with the Court of Common Pleas of the within County to set aside the sale for a grossly inadequate price or for other proper cause. This petition MUST BE FILED BEFORE THE SHERIFF'S DEED IS DELIVERED. 3. A petition or petitions raising the legal issues or rights mentioned in the preceding paragraphs must be presented to the Court of Common Pleas of the within County. The petition must be served on the attorney for the creditor or on the creditor before presentation to the court and a proposed order or rule must be attached to the petition. If a specific return date is desired, such date must be obtained from the Court Administrator's Office - Civil Division, of the within County Courthouse, before a presentation of the petition to the Court. A copy of the Writ of Execution is attached hereto. PURCELL, KRUG & HALLER Attorneys for Plaintiff 1719 North Front Street Harrisburg, PA 17102 (717) 234-4178 ALL the following described real estate, together with improvements thereon erected, lying and being situate in Southampton Township, Cumberland County, Pennsylvania, more particularly described as fellows: BEGINNING at a point on the southerly side of the hereinafterere D rrive at ed to plan of rlots; to nce by said L ot D12, South 38 degrees 24 minutes 45 seconds West 152.39 feet to a concrete monument at other lands of the Grantors herein; thence by said other lands of the Grantor, herein, North 62 degrees 25 minutes 25 seconds West 95.65 feet to a concrete monument; thence by the same, North 13 degrees 31 minutes 30 seconds West 47.66 feet to a point at corner of Lot D10 on said plan of lots; thence by said Lot D10, North 55 degrees 57 minutes 6 seconds East 161.27 feet to a point on the southerly side of Independence Drive; thence with the southerly side of Independence Drive, on a curve to the left having a radius of 275 feet, a chord bearing of South 42 degrees 49 minutes 4 seconds East and a chord length of 83.85 feet to a point, the place of beginninu 18,238 square feet, containing BEING Lot D11 on subdivision plan prepared by Carl D. Bert dated June 26, 1998, entitled "Land Subdivision for Rine Estates, Phases I and II," and recorded in Cumberland County, Pa., Plan Book 77, Page 64 HAVING THEREON ERECTED A RESIDENTIAL DWELLING HOUSE KNOWN AS 16 INDEPENDENCE DRIVE, SHIPPENSBURG, PA 17257 BEING THE SAME PREMISES WHICH J. Gary Rine and Virginia B. Fine by deed dated 6/19/00 and recorded 7/3/00 in Deed Book 224 Page 687 granted and conveyed unto Tanja A. Jumper. TO BE SOLD AS THE PROPERTY Or TANJA A. JUMPER ON JUDGMENT NO. 2002 3976. ASSESSMENT 4 39-37-2092-079 c:? ' ??; _, . ?`: . .. . ??. ? ?a:, ? -? WRIT OF EXECUTION and/or ATTACHMENT COMMONWEALTH OF PENNSYLVANIA) COUNTY OF CUMBERLAND) NO 02-3976 Civil CIVIL ACTION - LAW TO THE SHERIFF OF CUMBERLAND COUNTY: To satisfy the debt, interest and costs due FEDERAL NATIONAL MORTGAGE ASSOCIATION, Plaintiff (s) From TANJA A. JUMPER, 16 INDEPENDENCE DRIVE, SHIPPENSBURG, PA 17257 (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 $144,828.31 L.L. $.50 Interest AT $30.07 PER DIEM TO SALE DATE $5,562.95 Atty's Comm % Due Prothy $1.00 Atty Paid $119.49 MONTH TO SALE DATE $252.55 Plaintiff Paid Date: DECEMBER 3, 2002 (Seal) Other Costs LATE CHARGES AT $50.51 PER ESCROW DEFICIT $2,000.00 REQUESTING PARTY: Name LEON P. HALLER, ESQUIRE Address: 1719 NORTH FRONT STREET HARRISBURG, PA 17102 Attorney for: PLAINTIFF CURTIS R. LONG Prothonot Deputy Telephone: 717-234-4178 Supreme Court ID No. 15700 FEDERAL NATIONAL MORTGAGE ASSOCIATION, Plaintiff VS. TANJA A. JUMPER, Defendant TO THE PROTHONOTARY: IN THE COURT OF COMMON PLEAS CUMBERLAND CO., PENNSYLVANIA CIVIL ACTION - LAW NO. 2002-3976 Civil Term IN MORTGAGE FORECLOSURE P R A E -C I P E Please Vacate the Judgment entered against the Defendant in the above captioned matter, because the mortgage has been reinstated and the default cured. ,PURCELL, KRUG & HALLER B yl- Leon P. Haller I No. 15700 Attorney for Plain iff 1719 North Front Street Harrisburg, PA 17102 (717) 234-4178 DATE: February 26, 2003 +it '-??j L?7C` 141) cn ? Federal National Mortgage Association VS Tanja A. Jumper In The Court of Common Pleas of Cumberland County, Pennsylvania Writ No. 2002-3976 Civil Term R. Thomas Kline, Sheriff, who being duly sworn according to law, states this writ is returned STAYED pursuant to instructions from Attorney Leon Haller. Sheriff's Costs: Docketing 30.00 Surcharge 20.00 Advertising 15.00 Posting Bills 15.00 Law Library .50 Prothonotary 1.00 Mileage 26.22 Levy 15.00 Certified Mail 3.91 Law Journal 325.85 Patriot News 281.89 Poundage 15.19 Share of Bills 25.21 $ 774.77 Sworn and subscribed to before me This g L day of 2003, A.D. Prothonotary paid by attorney 02/21/03 So Answers:% AK R. Thomas Kline, Sheriff BY P Real Esta e Deputy `fro ?3R??'1 Real Estate Sale # 46 On December 9, 2002 the sheriff levied upon the defendant's interest in the real property situated in Southampton Township, Cumberland County, PA known and numbered as 16 Independence Drive, Shippensburg, more fully described on Exhibit "A" filed with this writ and by this reference incorporated herein. Date: December 9, 2002 By-'j o Real Esta Deputy A J 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 #46 REAL ESTATE SALE No. 46 Writ. No. 2002-3976 Civil Term Federal National Mortgage Assoc. VS Tanta A. Jumper Atty: Leon Haller DESCRIPTION ALL the i ;flowing described real estate, together with improvements thereon °rected, lying and being situate in Southampton Township. Cumberland County, Pennsylvania, more particularly described as follows: BEGINNING at a point on the southerly side of independence Drive at corner of Lot D12 on the hereinafter referred to Plan of Lots: thence by said Lot D12, South 38 degrees 24 minutes 45 seconds West 152.39 feet to a concrete monument at other lands of the Grantors herein; thence by said other lands of the Grantor herein, North 62 degrees 25 minutes 25 seconds west Notarial Seal - Terry L Russell, Notary Public City Of Harrisburg, Dauphin Cou mrrtisston Expires June 6, 2006 Member, Pennsylvania Association Of NoW ies this 14th d of FetSru y 2003 A.D. NOTARY 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 $ 280.14 Probating same Notary Fee(s) $ 1.75 Total $ 281.89 95.65 feet to a concrete monumem.thence bythe 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. same. North 13 degrees 31 minutes 30 seconas West 47.66 feet to a point at corner of Lot D10 on said Plan of Lots; thence by said Lot D10, North 55 degrees 57 minutes 6 seconds East 161.27 feet to a point on the southerly side of Independence Drive; thence with the southerly side of Independence Drive, on a curve to the left having a radius of 275 feet, a chord bearing of South 42 degrees 49 minutes 4 seconds East and a chord length of 83.85 feet to a point, the place of beginning, containing 18,238 square feet. BEING Lot DI I on subdivision plan prepared by Carl D. Bert dated June 26, 1998, entitled !Land Subdivision for Rine Estates, Phases I and IIJ and recorded in Cumberland County, Pa., Plan Book 77, Page 64. By......... HAVING thereon erected a residential dwelling house known as 16 Independence Drive, Shippensburg, PA 17257. BEING THE SAME PREMISES WHICH J. Gary Rine and Virginia B. Rine by deed dated 6/ 19/00 an recorded 7/3/00 in Deed Book 224 Page 687 granted and conveyed unto Tanja A. Jumper. TO BE SOLD AS THE PROPERTY of Tanja A. Jumper on Judgment No. 2002 3976. ASSESSMENT #39-37-2092-079. 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. 46 Writ No. 2002-3976 Civil Federal National Mortgage Association vs. Tanja A. Jumper Atty.: Leon Haller ALL the following described real estate, together with improvements thereon erected, lying and being situate in Southampton Township, Cumberland County, Pennsylvania, more particularly described as fol- lows: BEGINNING at a point on the southerly side of Independence Drive at corner of Lot D12 on the hereinafter referred to plan of lots; thence by said Lot D12, South 38 degrees 24 minutes 45 seconds West 152.39 feet to a concrete monument at other lards of the Grantors herein; thence by said other lands of the Grantor herein, North 62 de- Editor SWORN TO AND SUBSCRIBED before me this 14 day of FEBRUARY 2003 LOISE.pCCp.ryt??R??IusYDOERri, P ry PLgqyyi??pp???c Cr?h ls Y r V, irS:? '«" Y ki 0,v i/ My Catz r"m EWas4« ?? 5, grees 25 minutes 25 seconds West 95.65 feet to a concrete monument; thence by the same, North 13 de- grees 31 minutes 30 seconds West 47.66 feet to a point at corner of Lot D 10 on said plan of lots; thence by said Lot D10, North 55 degrees 57 minutes 6 seconds East 161.27 feet to a point on the southerly side of Independence Drive; thence with the southerly side of Independence Drive, on a curve to the left having a radius of 275 feet, a chord bear- ing of South 42 degrees 49 minutes 4 seconds East and a chord length of 83.85 feet to a point, the place of beginning, containing 18,238 square feet. BEING Lot D 11 on subdivision plan prepared by Carl D. Bert dated June 26, 1998, entitled "Land Sub- division for Rine Estates, Phases I and II," and recorded in Cumberland County, Pa.. Plan Book 77, Page 64. HAVING THEREON ERECTED A RESIDENTIAL DWELLING HOUSE KNOWN AS 16 INDEPENDENCE DRIVE, SHIPPENSBURG, PA 17257. BEING THE SAME PREMISES WHICH J. Gary Rine and Virginia B. Rine by deed dated 6/19/00 and recorded 7/3/00 in Deed Book 224 Page 687 granted and conveyed unto Tanja A. Jumper. TO BE SOLD AS THE PROPER- TY OF TANJA A. JUMPER ON JUDG- MENT NO. 2002 3976. ASSESSMENT #39-37-2092-079. i J 41 ?0'