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HomeMy WebLinkAbout00-00232 _ '.J ~ '~o""iJ,,', SHERIFF'S RETURN - REGULAR CASE NO: 2000-00232 P COMMONWEALTH OF PENNSYLVANIA: ,__ COUNTY OF CUMBERLAND ' GMAC MORTGAGE CORP OF PA VS MATTHEWS SCOTT A ET AL KATHY CLARKE , Sheriff or Deputy Sheriff of Cumberland County, pensylvania, who being duly sworn according to law, says, the within COMPLAINT - MORT FORE was served upon MATTHEWS KIMBERLY D the DEFENDANT , at 0014:54 HOURS, on the 10th day of February, 2000 at POE: GIANT FOOD CORP HEADQTRS HARRISBURG PIKE CARLISLE, PA 17013 by handing to KIMBERLY MATTHEWS a true and attested copy of COMPLAINT - MORT FORE together with NOTICE and at the same time directing Her attention to the contents thereof. Sheriff's Costs: Docketing Service Affidavit Surcharge 18.00 3.10 .00 10,00 .00 31.10 So Answers: ~~~~( R. Thomas Kline daY,of 02/17/2000 FEDERMAN & PHELAN ti~P~iff By: Sworn and Subscribed to before me this -lS't:::- ~ .;Linn.J A. D. q.'r' Q ~ui~ .~ '. Prothonotary , ~". --;;.:" SHERIFF'S RETURN - NOT FOUND CASE NO: 2000-00232 P COMMONWEALTH OF PENNSYLVANIA COUNTY OF CUMBERLAND GMAC MORTGAGE CORP OF PA VS MATTHEWS SCOTT A ET AL R. Thomas Kline ,Sheriff or Deputy Sheriff, who being duly sworn according to law, says, that he made a diligent search and inquiry for the within named defendant, DEFENDANT MATTHEWS SCOTT A but was unable to locate Him in his bailiwick. He therefore returns the COMPLAINT - MORT FORE Non CE , NOT FOUND , as to the within named DEFENDANT , MATTHEWS SCOTT A DEFT. NO LONGER LIVES AT ADDRESS STATED, BELIEVED TO BE LIVING IN PERRY COUNTY. Sheriff's Costs: Docketing Service Not Found Return Surcharge 6.00 7.44 5.00 10.00 .00 28.44 ~ ';rlY/ ,.J1!f!: ~ R. Thomas Kline ---" Sheriff of Cumberland County FEDERMAN & PHELAN 02/17/2000 Sworn and subscribed to before me this , ,OS" ",,<:> - day ofd~,.,.. I ~ A.D. g Q - ~ cl:' I n... ,PO...), ~ Pro " otary """'''5,- SHERIFF'S RETURN - OUT OF COUNTY CASE NO: 2000-00232 P COMMONWEALTH OF PENNSYLVANIA: COUNTY OF CUMBERLAND GMAC MORTGAGE CORP OF PA VS MATTHEWS SCOTT A 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: MATTHEWS SCOTT A but was unable to locate Him in his bailiwick. He therefore deputized the sheriff of PERRY County, Pennsylvania, to serve the within COMPLAINT - MORT FORE On February 17th, 2000 , this office was in receipt of the attached return from PERRY Sheriff's Costs: Docketing .00 Out of County 9.00 Surcharge .00 Dep. Perry County 58.40 .00 67.40 , '02/17/2000 FEDERMAN & PHELAN County Sworn and subscribed to before me this .J6'C: day of (LJ~ 2fmO A.D. el Q>~ ~- 1~ Prothonotary """'" "I" GMAC Mortgage Corp. of PA. IN THE COURT OF COMMON PLEAS OF THE 41st JUDICIAL DISTRICT OF PENNSYLVANIA PERRY COUNTY BRANCH Versus Scott A. Matthews, at al No. 2000.232 SHERIFF'S RETURN And now January 23, 2000: Served the within name Scott A Matthews the defendant(s) named herin, personally at his place of residence in Spring Township Perry County, PA, on January 23,2000 at 11:00 o'clock AM by handing to Scott A Matthews , an adult member of family 1 true and attested copy(ies) of the within Complaint in Mortgage Foreclosure . and made known to him the contents thereof Sworn and subscribed to before me this-BSl'li 80'"2; c: ~ Prothonotary DeputySheriff of Perry County / OEPUTY P~OTHONOTARY & CLERK OF COURTS '. BLOOMFIELD BORO., PEARY CO., PA MY COMMISSION EXPIRES JAN .5, 2004 ~,~ .'Iff ~....:.=~~ ,- "-Jriiil-~"''''';'''''lIIlIi/IiiililliUllifii- " ~~.~~,'"' 1 - . . ~6 .. "Z -6 "'t < L "'Ie:!:! -0 o E> lI:::::::l .2.... ~~ r~ J , "I -, J ",:j In The Court of Common Pleas of Cumberland County, Pennsylvania GMAC Mortgage C~? of PA Scott A. Matthews, et. al. Serve: Scott A. Matthews No. 2000-232 Civil Now, 1/13/2000 , 20 &0, I, SHERIFF OF CUMBERLAND COUNTY, P A, do hereby deputize the Sheriff of Perry County to execute this Writ, this deputation being made at the request and risk of the Plaintiff. ~ t Affidavit of Service Now, ; 20-, at o'clock M. served the within upon at by handing to a copy of the original and made known to the contents thereof. So answers, Sheriff of County, PA Sworn and subscribed before 'me this day of ,20_ COSTS SERVICE MILEAGE AFFIDAVIT $ $ - ^- , .,,.~- FEDERMAN AND PHELAN By: FRANK FEDERMAN, ESQUIRE IDENTIFICATION NO. 12248 TWO PENN CENTER PLAZA, SUITE 900 PHILADELPHIA, PA 19102 (215) 563-7000 GMAC MORTGAGE CORPORATION OF PA 3451 HAMMOND AVENUE P.O. BOX 780 WATERLOO, IA 50704 ATTORNEY FOR PLNNTIFF COURT OF COMMON PLEAS CNIL DNISION TERM Plaintiff V. NO. c2Q'::D - ,;)]:2 t&J CUMBERLAND COUNTY SCOTT A. MATTHEWS KIMBERLYD. MATTHEWS 3703 ENOLA ROAD NEWVILLE, P A 17241 Defendant( s) CIVIL ACTION - LAW MORTGAGE FORECLOSURE NOTICE PLEASE BE ADVISED THAT THIS FIRM IS A DEBT COLLECTOR ATTEMPTING TO COLLECT A DEBT. ANY INFORMATION RECEIVED WILL BE USED FOR THAT PURPOSE. IF YOU HAVE PREVIOUSLY RECEIVED A DISCHARGE IN BANKRUPTCY AND THIS DEBT WAS NOT REAFFIRMED, THIS CORRESPONDENCE IS NOT AND SHOULD NOT BE CONSTRUED TO BE AN ATTEMPT TO COLLECT A DEBT BUT ONLY ENFORCEMENT OF A LIEN AGAINST PROPERTY. You have been sued in Court. If you wish to defend against the claims set forth in the following pages, you must take action within twenty (20) days after this Complaint and Notice are served, by entering a written appearance personally or by attorney and filing in writing with the court your defenses or objections to the claims set forth against you. You are warned that if you fail to do so the case may proceed without you and a judgment may be entered against you by the court without further notice for any money claimed in the Complaint or for any other claim or relief requested by the Plaintiff. You may lose money or property or other rights important to you. YOU SHOULD TAKE THIS PAPER TO YOUR LAWYER AT ONCE. IF YOU DO NOT HAVE A LAWYER OR CANNOT AFFORD ONE, GO TO OR TELEPHONE THE OFFICE SET FORTH BELOW TO FIND OUT WHERE YOU CAN GET LEGAL HELP. CUMBERLAND COUNTY CUMBERLAND COUNTY BAR ASSOCIATION 2 LIBERTY AVENUE CARLISLE, P A 17013 (717) 249-3166 Loan #: 220870133 We hereby certify the within to be a t;ue and correct copy c'i tho original filed of record FEDERMAN AND PH~LA.M 1. Plaintiff is GMAC MORTGAGE CORPORATION OF PA 3451 HAMMOND AVENUE P.O. BOX 780 WATERLOO, IA 50704 2. The name(s) and last known addressees) of the Defendant(s) are: SCOTT A. MATTHEWS KIMBERLY D. MATTHEWS 3703 ENOLA ROAD NEWVILLE, PAl 7241 who is/are the mortgagor(s) and real owner(s) of the property hereinafter described. 3. On 6/23/93 mortgagor(s) made, executed and delivered a mortgage upon the premises hereinafter described to PLAINTIFF which mortgage is recorded in the Office of the Recorder of CUMBERLAND County, in Mortgage Book No. 1144, Page 720. 4. The premises subject to said mortgage is described as attached. 5. The mortgage is in default because monthly payments of principal and interest upon said mortgage due 5/1/99 and each month thereafter are due and unpaid, and by the terms of said mortgage, upon failure of mortgagor to make such payments after a date specified by written notice sent to Mortgagor, the entire principal balance and all interest due thereon are collectible forthwith. A copy of such notice is attached as Exhibit "A." 6. The following amounts are due on the mortgage: Principal Balance Interest 4/1199 through III 1199 (Per Diem $19.10) Attorney's Fees Cumulative Late Charges 6/23/93 to 1111199 Cost of Suit and Title Search Subtotal $101,386.41 4,087.40 5,069.00 430.56 550.00 111,523.37 Escrow Credit Deficit Subtotal 229.47 0.00 229.47 TOTAL $111,293.90 7. The attorney's fees set forth above are in conformity with the Mortgage documents and Pennsylvania Law, and will be collected in the event of a third party purchaser at Sheriffs Sale. If the Mortgage is reinstated prior to the Sale, reasonable attorney's fees will be charged. 8. This action does not come under Act 6 of 1974 because the original mortgage amount exceeds $50,000. 9. This action does not come under Act 91 of 1983 because the mortgaged premises is not the principal residence of the Defendant(s). 10. Pursuant to the Fair Debt Collection Practices Act, 15 U.S.C. ~ 1692 et seq. (1977), Defendant(s) may dispute the validity of the debt or any portion thereof. IfDefendant(s) do so in writing within thirty (30) days of receipt of this pleading, Counsel for Plaintiff will obtain and provide Defendant(s) with written verification thereof; otherwise, the debt will be assumed to be valid. Likewise, if requested within thirty (30) days of receipt of this pleading, Counsel for Plaintiff will send Defendant(s) the name and address of the original creditor if different from above. WHEREFORE, PLAINTIFF demands an in rem Judgment against the Defendant(s) in the sum of $ 111,293.90, together with interest from 1111199 at the rate of$19.10 per diem to the date of Judgment, and other costs and charges collectible under the mortgage and for the foreclosure and sale of the mortgaged property. Isl Frank Federman FRANK FEDERMAN, ESQUIRE Attorney for Plaintiff J TRUE COpy FROM R:':rt"flfl n TeSflmony whereof, I here .: O";.,:.'.~. J and -!-, {'~ J ,( , un.::! -";:" ~~,~;( Ilanu ,ns ooal 01 Said Court at Curb;.]. F.> This ../9?.., day o~-n...., .. ~ ..............~,....~:~,...w. ProthonD',~~ry , .., '> ' Servicing GMAC Mortgage Corporation P.O. Box 8507f San Diego, CA 92186-5071 3451 Hammond Ave P.O. Box 780 Waterloo, IA 50704-0780 NOTICE OF INTENTION TO FORECLOSE AND ACCELERATE DATE: July 7, 1999 LOoliAc Mortgage CERTIFIED MAIL NO. Z 472890838 TO: SCOTT A MATTHEWS 3703 ENOLA RD NEWVILLE PA 17241 RE: MORTGAGE LOAN NUMBER: MORTGAGED PREMISES: 220870133 45 MARE ROAD CARLISLE, PA 17013.9514 This company is the holder of the FIRST MORTGAGE (AND NOTE) on the above premises, or is the mortqaqe service agent for such holder. (Hereinafter referred to as we, us or ours) . As of the date of this notice, THE MORTGAGE IS IN SERIOUS DEFAULT because you have not made the May 1, 1999 and subsequent monthly payments as listed, and/or for other reasons as indicated below:' 3 payments @ $857.63 $2,572.89 Accrued late charges...... ... ........... ..... .... .$287.04 NSF Check Fees.... . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . $0.00 All other fees accrued to date...... ...... ..........$0.00 , Less available suspense credits ...... ..............$0.00 The total amount now required to cure this default, or in other words, get caught up in your payments as of the date of this letter is................................... .$2,859.93 You may cure this default within THIRTY (30) DAYS of the date of this letter, by paying to us the above amount, plUS any additional monthly payments and late charges which may fall due during this period. Such payment must be made either by cash, cashier's check, certified check or inoL.::-:-t...__'?~de:rr' and made at, or sent to: 3451 Hanunond Avenue,'- P.O. --Box 780, Waterloo, IA 50704-0780. If you do not cure the default within THIRTY (30) DAYS, we intend to exercise our right to accelerate the mortgage payments. This means that whatever is owing on the original amount borrowed will be considered due immediately and you may lose the chance to pay off the original mortgage in monthly installments. If full payment of the amount of default is not made within THIRTY (30) DAYS, we also intend to instruct our attorneys to start a lawsuit to foreclose your mortgaged property. If the mortgage is foreclosed your mortgaged property will be sold by the Sheriff to pay DMS5-BRCHPAC (Page 1 of 2) EXHIBIT A ". .~........ ...., "'~' : GMAC Mortgage Corporation P.O. Box 8507f San Diego, CA 92186-5071 3451 Hammond Ave P.O. Box 780 Waterloo, IA 50704-0780 NOTICE OF INTENTION TO FORECLOSE AND ACCELERATE DATE: July 7, 1999 Servicing LOGue Mortgage CERTIFIED MAIL NO. Z 472890839 TO: SCOTT A MATTHEWS 45 MARE ROAD CARLISLE PA 17013-9514 RE: MORTGAGE LOAN NUMBER: MORTGAGED PREMISES: 220870133 45 MARE ROAD CARLISLE, PA 17013-9514 This company is the holder of the FIRST MORTGAGE (AND NOTE) on the above premises, or is the mortgage service agent for such holder. (Hereinafter referred to as we, us or ours). As of the date of this notice, THE MORTGAGE IS IN SERIOUS DEFAULT because you have not made the May 1, 1999 and subsequent monthly payments as listed, and/or for other reasons as indicated below: * 3 payments @ $857.63 $2,572.89 Accrued late charges.... ....... ....... ............$287.04 NSF Check Fees..................................... .$0.00 All other fees accrued to date...................... $0.00 * Less available suspense credits .............. ......$0.00 The total amount now required to cure this default, or in other words, get caught up in your payments as of the date of this letter is................................... .$2,859.93 You may cure this default within THIRTY (30) DAYS of the date of this letter, by paying to us the above amount, plus any additional monthly payments and late charges which may fall due during this period. Such payment must be made either by cash, cashier's check, certified check or money order, and made at, or sent to: 3451 Hammond Avenue, - P.O. ...Box 780, '~-,~ , " .---.,,- Waterloo, IA 50704-0780. If you do not cure the default within THIRTY (30) DAYS, we intend to exercise our right to accelerate the mortgage payments. This means that whatever is owing on the original amount borrowed will be considered due immediately and you may lose the chance to payoff the original mortgage in monthly installments. If full payment of the amount of default is not made within THIRTY (30) DAYS, we also intend to instruct our attorneys to start a lawsuit to foreclose your mortgaged property. If the mortgage is foreclosed your mortgaged property will be sold by the Sheriff to pay DMS5-BRCHPAC (Page 1 of 2) EXHIBIT A - GMJlC Mortgage Corporalion P.O. Box BS07f San Diego, OA 92166-5071 3451 Hammond Ave P.O. Box7BO Waterloo, IA 50704-0760 NOTICE OF INTENTION TO FORECLOSE AND ACCELERATE DATE: JUly 19, 1999 Servicing LOOMC Mortgage CERTIFIED ~IL NO. Z TO: RIMBERLY D. ~TTHEWS 3703 ENOLA RD NEWVILLE, PA 17241 RE: MORTGAGE LOAN NUMBER: MORTGAGED PREMISES: 220670133 4 5 ~RE ROAD CARLISLE, PA 17013-9514 This company is the holder o~ the FIRST MORTGAGE (AND NOTE) on the above premises. or is the mortqaqe service ~qenc for such holaer. (Hereinafter referred ~o as we, us or ours) . As of the date of this notioe, THE MORTGAGE IS IN SERIOUS DEFAULT because you have not made the May 1, 1999 and subsequent monthly payments as listed, and/or for ocher reasons as indioaced below:' 3 payments 0 $857.63 $2,572.89 Accrued late oharges.. . . . . . . . . . . . . . . . . . . . . . . . . . . . . $322.92 NSF Check Fees................"......................".. $ 0 . 0 0 All other fees aocrued to date............ ........ ..$0.00 * Less available suspense credics ......... ...........$0.00 The total amount now required co cure this default, or in other words; qet cauqhe up in your payments as of ~he date of this letter is................................... .$2,895.Bl You may cure this default within THIRTY (30) DAYS of the date of this 1ecter, by payinq to us che above amounc, plus any additional monthly payments and Inte charqes whieh may fall due durinq this period. Such pa~nent must be made either by cash, cash~er's check, ce~eified check or money order, ana made at, or se~c Co: 3451 Hammond Avenue, ?O. Bo~ 780, Wat~....~:;:.:.,- ::LA -50704-0780. If you do noc cure the defaulc within THIRTY (30) ~AYS, we intend to ex~rcise our right to accelerate the mortqaqe payments. This means chat whateve~ is owinq on the oriqinal amount borrowed will be considered d~e immediacely and you may lose the chance to payoff the oriqinal morcqaqe in mon"hly installmencs. If full payment of the amount of defaul" is not made within THIRTY (30) DAYS, We also intend to ins Cruet o~r ac~orneys to start a lawsuit to foreclose your mortqaqed property. If the mortqaqe is foreclosed your mortqaqed property will be sold by the Sheriff to pay DMSS'BRCHPA (Page 1 of 2) ;;DD~ JV\l[~ SH9 6C;; n;;.2. EXH1B\T A DC:S! 66,'16i(;1 --, - -.-.----. "" ~~",."" , .......""'; GMAC Mortgage Corporation P.O. Box BS07f San Diego, CA 92186-5071 3451 Hammond Ave P.O. Box 780 Waterloo, IA 50704-0780 NOTICE Of INTENTION TO FORECLOSE AND ~CCELERATE DATE; July 19, 1999 Servloing LOoMAc Mortgage CERTIFIED MAIL NO. Z TO: KIMBERLY' D. MATTHEWS 45 MARE ROAD CARISLE. PA 17013-9514 I<E : MORTGAGE LOAN NUMBER. MORTGAGED PREMISES: 220870133 45 ~RI:; ROAD CARLISLE, PA 17013-9514 This company is the holder of Che FIRST MORTGAGE (AND NOTE) on the abovo premises, or is the mortqaqe service aqent for such holder. (Hereinafter referred to as we, us or ours) . As of the dace of chis notice, THE MORTGAGE rs IN SERIOUS DEFAULT because you have noc /!lade the May 1, 1999 and subsequen~ monthly payments as listed, and/or for o~her reasons as indicated below:' J payments ~ $857.63 $2,572.89 Accrued late charges.......... .......... ... .......$322.92 NSF Checl< Fees......... .. . . . ... . . .. . . . . . . .. . .. .. . . . . $0.00 All other fccs accrued to date... ...................$0.00 . Less ava~lable suspense credits ....................$0.00 The total amount now required to cure chis defaul~, or in other words, ge~ cau9ht up in your pa~nents as of the date of this lette:r is... ................................ .$2,895.Bl Y~u may cure chis default within THIRTY (30) DAYS of the dace of this letter, by paying to us the above amount, plus any additional mon~hly payments and late charges which may fall due during chis period. Such payment must be made either by cash, cashier's check, certified cheek or money ordcr, anrJ. made at, or sent to: 3451 Hanunorld Avenue, P.O. Bolt 780, Watc_~~~, !~ $0704-0780. If you do not cure the default wichin THIRTY (30) DAYS, we intend co exercise our ~ight to acoelera~e the mortgage paymentS. ~~is meanS that whatever is owing on che ori<;iinal amount borrowed will be considered nlle immeaiat:ely and you Inaylose the chance to payoff che oriqinal mortqage in monthly installments. If full payment of che amounc of default is not made within T~IRT~ (30) DAYS, we also intend to instruct our attorneys to start a lawsuit: co foreclose your mortqaged property. If the mortQaqe is foreclosed your mortqagsd property will be sold by the Sheriff to pay DMS5-BRCYPA (paqe 1 of 2) EXHIBIT A voo~ JVJI~ SH9 6~;: n;:,g. H:S, 66 n;: ";:T ~ , , July 19, 1999 Paqc 2 220870133 off the deb~. If we refer your cas@ ~o our attorneys, but you cure the aefaul~ before they begin legal prooeedings aqainst you, you will still have to pay the reasonable ateorney's fees, actually incurred, up to $50.00. However, if leqal prooeedings are started aqainst you, you will have to pay the re.asonable at.t.or:ney's. fees even if they are over $50.00. ),ny attorney's fees will bc added to whatever you owe us, which ma.y ale;o include our reasonable costs. If you oure the default within the thirty day period, yo~ will not b@ required to pay a~~orneY'5 fees. ~emember you are also responsible for keeping all real Cscate taxes c\\rrent.. We may also sue you personally for the unpaid balance and all other sums due under the moreqa.qc.. If you have not c.ured t.he de:fault wit.hin t.he thirty day Period and foreclosure proceedings have begun, you still havc the right to cure the default and prevent the sale at any time up to one hour ~efore ehe Sheriff's foreclosure sale. You may do so by paying the total amount of the unpaid monthly payments plus any lat~ or other ch~rges then due, as well as the reasonable attorney's fec~ and cost~ oonneoted with the foreolosure sale (and perform any other requirements under the mortqaqe). Ie is escimated ehac ehe earliest dace that such a Sheriff's sale could be held woulq be approximately one-hundred and fifty (150) days from the date 'of this letter. A notice of the date of the sheriff's sale will be sent to you before the sale_ Of course, the amount needed to oure the default will inorease the lcn;er you wait. YoU may find out at any time exactly what the required payment will be by oallinq us at the fOllowinq number, 1-800-850-4522. Thc payment must be in cash, cashier's cheCK, cercified check or money order and made paya~le to us aC the address preViouslY stated. You should realize that a Sheriff's sale will end your ownerShip of the mortqa;ed property and your riqht to remain in it. If you continue to live in the property afcer the Sheriff's sale, a lawsuit could be started to evict. you. NOTl:'._~ --' ~.r.bi s" is an attempt to collect a debt and any information obtained will be used for that purpose. You have additional rights to help proteoc your interest in the property. YOU HAVE THE RIGHT TO SELL THE PROPERTY TO OBTAIN MONEY TO PAY OFF THE MORTGAGE DEBT, OR TO BORROW MONEY FROM ANOTHER LENDING INSTIT1l~'ION TO 1'1\'1' OFF THIS DEBT. YOU MAY !lAVE TilE RIGHT TO SELL OR 'I'RANSFER THE PROPERTY SUBJECT TO THE MORTGAGE TO A BUYER OR TR1\NSFEREE WHO WILL ASSUME THE MORTGAGE DEBT, PROVIDED THAT ALL OUTSTANDING PAYMENTS, CHARGES AND 1\TTORNEY'S FEES AND COSTS ARE PAID PRIOR TO OR AT THE SALE, (AND THAT THE OTHER REQUIREMENTS UNDER THE MORTGAGE ARE SATISFIED). CONTACT US TO DE~'ERMINE UNDER WHAT CIRCT1MSTANCES TilE RIGHT MAY EXIS~'. YOU 111\VE T".dE RIGHT TO H~VE THIS DEFAULT CURED BY ANY THIRD PARTY ACTING ON YOUR BEHALF. It you cure the default, ~he mortgaqe will be r~$eored eo the same position as if no default had oecurred. Ho~ever, you are not enticled Co this right to cure your def~ult more th~n three eimes in any calendar year. DMS5-BRCH~A (?age 2 of 2) EXH1B1T A coo Iia JVN~ ~H9 6CZ nz.\2. OC:Sl 66.'16/61 ~ ~~ ..... -i-~ ~i{. ~)~8 hLL THAT CI;:RTAIN trac-t of" l.and in ~~er Frank:ford TownShi' ';'~::':"C'ri~ cum.bQr~and county, Pennsy1.vania, contaJ.n1ng 1.6.892 acres r be ~ :~ the northern most ~art of the ~arm now or fQrmer~y of Nelson i.~ ~ Shughart:.,. and Ruth E. shughart, his. wife,. which farm is :rn E$".n . ~ parl::..icv.~arly looated as being in the Northeast corner :5:;:. :r: Legis1ative Route NQ. 21001., known as Traffio Ro~te No. 994 ~~ ~ Township Road. No. -4.92, thca tract hereby conveyed being Jn9lf~j'iijil r II': I ~Qrticu1a:rly bounded and. described a.s follows: 1.1. ., BECINN:ING a:t:. an iron pin on a line. of land no'W or 'formerly of C.C. Leid.i9"h and land noW' or :forn\e:r1.y of Eugene C. Morrison, North 72 degrees 57 minutes 48 seconds East 1029.522 feet to ~ stOlle pil.e; thenoe Sout:.h 21. deqrees 42 'minutes 1.1. s.econds East 49$_76 ;ree;t to an iron pin and stone pile.; t.hence south ::a 2 degrees 41 minutes 53 seconds East 397.75 ree~ ~o a~ iron pin; thence south 75 degrees 22 minutes 50 seconds West 64~.6e ~eet to an iron pin: thence Nort:.h 45 de~rses 30 minu~es ~7 seconds We6t 981.602 reet ~o the p1ace or beg~nning_ CONTAINING 16.682 acres, more or 1ess. BEING ~he sam~ premise;s that Wa1ter E_ Morrison and Gerald~na L. Morrison, husband and wi~e,. by their deed dated the 28th day of PREMISES: 45 MARE ROAD ~";j,,...~,-~ < "J ! 'I 11 " i-i , :: ,. I; H , i: I': , , I " " " ~ ~~ " VERIFICATION FRANK FEDERMAN, ESQUIRE hereby states that he is attorney for Plaintiff in this matter, that he is authorized to take this Verification, and that the statements made in the foregoing civil Action in Mortgage Foreclosure are true and correct to the best of his knowledge, information and belief. The undersigned understands that this statement is made subject to the penalties of 18 Pa. 4904 relating to unsworn C.S. Sec:. falsification to authorities. ~ :)---~ DATE: _r 1 ~o 0 --~. , 1 \ " \ \ . , ; !-1 i~ " " '1 ,~i I '..1'.' Ii: , :j ;~ i~ :1 ~~ :j , i! I' " :: :';i '! 'oj :,'; i! !:: f': I', 'I 11 ;>! " i! ~;: , ',' '1 :,1 . "'" "">'> '.' '. .......... . . ...... .................. .' '.. ... ....... ........... ........" lri "'I '.;'1" ...... ..((. .' .' . ..<>.......>. ..... . . . ....... ......... ........> -....... .......... .... . .................... ... 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',I.I:.:iii.iiiiiii.ii.ii.iiiii.i.... . .... . . .. . . ..... . .. ....... . . . .. ........ . . . ... . .. ......... ,"~~ ., v.~, . : FEDERMAN AND PHELAN By: FRANK FEDERMAN, ESQUIRE IDENTIFICATION NO. 12248 TWO PENN CENTER PLAZA, SUITE 900 PHILADELPHIA, PA 19102 (215\ 563-7000 GMAC MORTGAGE CORPORATION OF PA 3451 HAMMOND AVENUE P.O. BOX 780 WATERLOO, IA 50704 - ATTORNEY FOR PLAThITffF COURT OF COMMON PLEAS CNIL DNISION TERM Plaintiff V. NO. ~. .;23.;( u;J CUMBERLAND COUNTY SCOTT A. MATTHEWS KIMBERLYD. MATTHEWS 3703 ENOLA ROAD NEWVILLE, PA 17241 Defendant( s) CIVIL ACTION - LAW MORTGAGE FORECLOSURE NOTICE PLEASE BE ADVISED THAT THIS FIRM IS A DEBT COLLECTOR ATTEMPTING TO COLLECT A DEBT. ANY INFORMATION RECEIVED WILL BE USED FOR THAT PURPOSE. IF YOU HAVE PREVIOUSLY RECEIVED A DISCHARGE IN BANKRUPTCY AND THIS DEBT WAS NOT REAFFIRMED, THIS CORRESPONDENCE IS NOT Ai'lD SHOULD NOT BE CONSTRUED TO BE AN ATTEMPT TO COLLECT A DEBT BUT ONLY ENFORCEMENT OF A LIEN AGAINST PROPERTY. You have been sued in Court. If you wish to defend against the claims set forth in the following pages, you must take action within twenty (20) days after this Complaint and Notice are served, by entering a written appearance personally or by attorney and filing in writing with the court your defenses or objections to the claims set forth against you. You are warned that if you fsil 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. ff YOU DO NOT HAVE A LAWYER OR CANNOT AFFORD ONE, GO TO OR TELEPHONE THE OFFICE SET FORTH BELOW TO FIND OUT WHERE YOU CAN GET LEGAL HELP. CUMBERLAND COUNTY CUMBERLAND COUNTY BAR ASSOCIATION 2 LIBERTY AVENUE CARLISLE, PA 17013 (717) 249-3166 We hereby certify the within to be a true and correct COQV of the . . originel med of record FEDERMAN AND PHELAN Loan #: 220870133 . , - .~.- - , 1. Plaintiff is GMAC MORTGAGE CORPORATION OF P A 345 I HAMMOND AVENUE P.O. BOX 780 WATERLOO, IA 50704 2. The name(s) and last known addressees) of the Defendant(s) are: SCOTT A. MATTHEWS KIMBERLY D. MATTHEWS 3703 ENOLA ROAD NEWVILLE, PAl 7241 who is/are the mortgagor(s) and real owner(s) of the property hereinafter described. 3. On 6/23/93 mortgagor(s) made, executed and delivered a mortgage upon the premises hereinafter described to PLAINTIFF which mortgage is recorded in the Office of the Recorder of CUMBERLAND County, in Mortgage Book No. 1144, Page 720. 4. The premises subject to said mortgage is described as attached. 5. The mortgage is in default because monthly payments of principal and interest upon said mortgage due 5/1/99 and each month thereafter are due and unpaid, and by the terms of said mortgage, upon failure of mortgagor to make such payments after a date specified by written notice sent to Mortgagor, the entire principal balance and all interest due thereon are collectible forthwith. A copy of such notice is attached as Exhibit "A." ,.---- Ib.I 6. The following amounts are due on the mortgage: Principal Balance Interest 4/1/99 through 11/1/99 (Per Diem $19.10) Attorney's Fees Cumulative Late Charges 6/23/93 to 11/1/99 Cost of Suit and Title Search Subtotal $101,386.41 4,087.40 5,069.00 430.56 550.00 1ll,523.37 Escrow Credit Deficit Subtotal 229.47 0.00 229.47 TOTAL $111,293.90 7. The attorney's fees set forth above are in conformity with the Mortgage documents and Pennsylvania Law, and will be collected in the event of a third party purchaser at Sheriff's Sale. If the Mortgage is reinstated prior to the Sale, reasonable attorney's fees will be charged. 8. This action does not come under Act 6 of 1974 because the original mortgage amount exceeds $50,000. 9. This action does not come under Act 91 of 1983 because the mortgaged premises is not the principal residence of the Defendant{s). 10. Pursuant to the Fair Debt Collection Practices Act, 15 USe. ~ 1692 et seq. (1977), Defendant{s) may dispute the validity of the debt or any portion thereof. IfDefendant{s) do so in writing within thirty (30) days of receipt of this pleading, Counsel for Plaintiff will obtain and provide Defendant{s) with written verification thereof; otherwise, the debt will be assumed to be valid. Likewise, if requested within thirty (30) days of receipt of this pleading, Counsel for Plaintiff will send Defendant{s) the name and address of the original creditor if different from above. WHEREFORE, PLAINTIFF demands an in rem Judgment against the Defendant{s) in the sum of $ 111,293.90, together with interest from 11/1/99 at the rate of$19. 10 per diem to the date of Judgment, and other costs and charges collectible under the mortgage and for the foreclosure and sale of the mortgaged property. /s/ Frank Federman FRANK FEDERMAN, ESQUIRE Attorney for Plaintiff fRU IE Ct~~py ~:~:_0: ~_~ '-~'r~'~D In Testimony v'oh:rcc', i 11:., ::<0 o;.Y my hand and the seal of SJid ,-cu'!' a'l .'or"..I. po .....,-. , ........... "01\.;:, '...I. This .".../01."". day of~"."".", S2~ ................~/~~."K './J, . // ki::r '..T""~r.~ ~~...~.. ProthoJ1Oi'ory -- GMAC Mortgage Corporalion P.O, Box 6507f San Diego, CA 92166-5071 3451 Hammond Ave p,o, Box 780 Waterloo, IA 50704-0780 NOTICE OF INTENTION TO FORECLOSE AND ACCELERATE DATE: July 7, 1999 Servioing CERTIFIED ~IL NO. Z 472890838 TO: SCOTT A MATTHEWS 3703 ENOLA RD NEWVILLE PA 17241 LOoMAc Mortgage RE: MORTGAGE LOAN NUMBER: MORTGAGED PREMISES: 220870133 45 MARE ROAD CARLISLE, PA 17013-9514 This company is the holder of the FIRST MORTGAGE (AND NOTE) on the above premises, or is the mortgage service agent for such holder. (Hereinafter referred to as we, us or ours) . AS of the date of this notice, THE MORTGAGE IS IN SERIOUS DEFAULT because YOU have not made the May 1, 1999 and subsequent monthly payments as listed, and/or for other reasons as indicated below:' 3 payments @ $857.63 $2,572.89 Accrued late charges.. ........ .......... ....... ...$2B7.04 NSF Check Fees........ . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . $0.00 All other fees accrued to date. .....................$0.00 , Less available suspense credits. ............... ....$0.00 The total amount now required to cure this default, or in other words, get caught up in your payments as of the date of this letter is.................................... $2,859.93 You may cure this default within THIRTY (30) DAYS of the date of this letter, by paying to us the above amount, plus any additional monthly paYments and late charges which may fall due during this period. Such payment must be made either by cash, cashier's check, certified check or inol...,;::J'.,~~t):a:-derf. and made at, or sent to: 3451 Hanunond Avenue,'~ P.O. '~Eox 780, Waterloo, IA 50704-0780. If you do not cure the default within THIRTY (30) DAYS, we intend to exercise our right to accelerate the mortgage payments. This means that whatever is owing on the original amount borrowed will be considered due immediately and you may lose the chance to payoff the original mortgage in monthly installments. If full payment of the amount of default is not made within THIRTY (30) DAYS, we also intend to instruct our attorneys to start a lawsuit to foreclose your mortgaged property. If the mortgage is foreclosed your mortgaged property will be sold by the Sheriff to pay DMS5'BRCHPAC (Page 1 of 2) EXHIBIT A ",,= GMAC Mortgage Corporation P.O. Box 8507f San Diego, CA 92186-5071 3451 Hammond Ave P.O. Box 7BO Waterloo, IA 50704.0780 NOTICE OF INTENTION TO FORECLOSE AND ACCELERATE DATE: July 7, 1999 Servioing LOoMAc Mortgage CERTIFIED ~IL NO. Z 472890839 TO: SCOTT A ~TTHEWS 45 ~RE ROAD CARLISLE PA 17013-9514 RE: MORTGAGE LOAN NUMBER: MORTGAGED PREMISES: 220870133 45 ~RE ROAD CARLISLE, PA 17013-9514 This company is the holder of the FIRST MORTGAGE (AND NOTE) on the above premises, or is the mortgage service agent for such holder. (Hereinafter referred to as we, us or ours) . As of the date of this notice, THE MORTGAGE IS IN SERIOUS DEFAULT because you have not made the May 1, 1999 and sUbsequent monthly payments as listed, and/or for other reasons as indicated below:' 3 payments @ $857.63 $2,572.89 Accrued late charges........ .... ...... ........... .$287.04 NSF Check Fees........... . . . . . . . . . . . . . . . . . . . . . . . . . . . $0.00 All other fees accrued to date..................... .$0.00 * Less available suspense credits ... ........... ......$0.00 The total amount now required to cure this default, or in other words, get caught up in your payments as of the date of this letter is................................... .$2,859.93 You may cure this default within THIRTY (30) DAYS of the date of this letter, by paying to us the above amount, plus any additional monthly payments and late charges which may fall due during this period. Such payment must be made either by cash, cashier's check, certified check or !Ilon.~Y,.C?r~=-::L and made at, or sent to: 3451 Hammond Avenue," P.O. ~-Eox 780, Waterloo, IA 50704-0780. If you do not cure the default within THIRTY (30) DAYS, we intend to exercise our right to accelerate the mortgage payments. This means that whatever is owing on the original amount borrowed will be considered due immediately and you may lose the chance to payoff the original mortgage in monthly installments. If full payment of the amount of default is not made within THIRTY (30) DAYS, we also intend to instruct our attorneys to start a lawsuit to foreclose your mortgaged property. If the mortqage is foreclosed your mortgaged property will be sold by the Sheriff to pay DMS5-BRCHPAC (Page 1 of 2) EXHIBIT A - iliI[1 GMJlC Mortgage Corporation P.O. Box BS07f San Diego, OA 92166-5071 3451 Hammond Ave P.O. Box 780 Waterloo, IA 50704-07BO NOTXCE OF INTENTION TO FORECLOSE AND ACCELERATE DATE: July 19, 1999 ServIcing LOOMC Mortgage CERTIFIED ~IL NO. Z '1'0: RIMBERLY D. l'lJITTHEWS 3703 ENOLA Rl) NEWVILLE, PA 17241 RE: MORTGAGE LOAN NUMBER: MORTGAGED PREMISES: 220870133 45 ~RE ROAD CARLISLE, PA 17013-9514 This company is the holder of the FIRST MORTGAGE (ANlJ NOTE) on thc above pramises, or is the mortqaqe service ~qenc for SUch holder. (Hereinafter refe~red to as we, us or ours) . AS of the date of this notioe, THE MORTGAGE IS IN SERIOUS DE~AUL'l' because yOU have not made the May 1, 1999 and subsequent monthly payments as listed, and/or for ocher rcasons as indioaced beloW:' 3 payments 0 $857.63 $2,572.89 Accrued late oharges...... . . . . . . . . . . . . . . . . . . . . . . . . $322.92 NEll' CheCK Fees...................................... $ 0.00 All other fees accrued to date...................... $0.00 * Less available suspense credics ............._......$0.00 The total amount now required co cure this default, or. in other words, qet cauqht up in your payments as of the date of this letter is... . ..... ....... . .. . ................ $2, 895.81 You may cure this default within THIRTY (30) DAYS of the date of chis letter, Py paying to us che above amounc. plus any additional monthly payments and late Charges which may fall due during this period. Such payment must be made either by cash, cashi.er's check. certified check or money order, and made at, or sene Co: 3451 Hammona Avenue, ?O. Bo~ 780. waf",.':::::.> " :LA -50704 - 0780. If yOU do noc cure the default within THIRTY (30) DAYS, we intend to exercise our right to accelerate the mortgage payments. This means chat whate~er is owing on the oriqinal amount borrowed will be considered Que immediacely and you may lose the ehanoe to payoff the oriqinal morc9age in monchly installments. If full payment of the amount of defaulc is not made within THIRTY (30) DAYS, We also intend to ins cruet our attorneys to start a lawsuit to foreclose your mortgaqed property. If the mortgaqe is foreclosed your mortgaged property will be sold by the Sheriff to pay DMS5'BRCHPA (Paqe 1 of 2) zoo~ JVl'l~ St19 6~Z nzS EXH1B1T A O~: 81 66/HlZr ~~ - GMAC Mortgage Corparalion P.O. Box B5071 San Diego, CA 92186-5071 3451 Hammond Ave P.O. Box 760 Waterloo. IA 50704--0760 NOTICE OF INTENTION TO FORECLOSE AND ACCELERATE DATE; July 19, 1999 Servioing LOoMAc Mortgage CERTIFIED ~IL NO. Z TO: KIMBERLY D. ~TTREWS 45 MARE ROiID CARI8LE, PA 17013'9514 RZ : MORTGAGE LOAN NUMBER l MORTGAGED PREMISES: 220670133 45 M/U(j:; ROAD CARLISLE, PA 17013-9514 This company is the holder ot Che FIRST MORTGAGE (AND NOTE) on the above premises, or is the morcQaqe service aqent for such holder. (Herein~ftcr refer~ed to as we! us or curs). As of the dace of this notice, THE MORTGAGE IS IN SERIOUS DEFAULT bccause you have noc made the May I. 1999 and subsequen~ mon~hly payments as listed, and/or for other reasons as indicated below:' 3 payments ~ $857.63 $2,572.89 Accrued late charges..................... ... .... .,$322.92 NSF Cheok ,ees.. _... . . . . .. . . .... . . . . . . . . ..... . .. . . . . $0.00 All other :fees accrued to date... .. ......... .. .... .. $0.00 * Less available suspense credits ............. .... ...$0.00 The total amount now required to cure ~is default, or in other words, qe~ cauqht up in your pa~nents as of the date of this letter is.................................... $2,895. Sl y~U may cure this default within THIRTY (30) DAYS of the dace of this letter, by paying to us the above amount, plUS any additional monthly payments and latc charges which may fall dUe during this period. Suo~ payment ~ust be made either by cash, cashier's cheCk, certified check or money order, and Inade at, or sane to: 3451 H~Nnond Avenue, P.O. Box 7801 Wate_:~~1 I~ 50704"0780. If you do not cure the default wi chin THIRTY (30) DAYS, we incend Co exercise our riqht to accelera~e the mcrtqaq2 paymencs. 1~is means that whatever is owitlq on che original amount borrowed will be considered due imn".diacely and you lnay lese the chance to payoff ch., ori\linal mortq~'l'e in monehly installments. If full payment of che amount or default is not made within THI~TY (30) DAYS, we also intend to instruct our attorneys to start a lawsuic ~o foreclose your mortqaqed property. Ir the mortQage is foreclosed your mortqaged property will be sold by the Sheriff to pay DMS5'BRCHPA (page 1 EXH\B\T A too lEi :)Vl'l~ SH9 61:;; n;;.g, H:S, 66/H/6' . July 19, 1999 Page 2 220B70133 off the debt. If we refer your case ~o our at~orneys, but you cure the defaule before they begin leqal prooeedin9s against you, you will still have ~o pay the reasonable ~ttorney's fees, actually incurred, up to $50.00. However, if leqal proceedings are started ~qainst you, you will h~ve to pay the reasonable atto~neyl5 fees eVen if they are over $50.00. ~ny attorney's fees will be added to whatever you owe us, which may also include our reasonable costs. If you cure the default wi chin the thirty day period, ya~ will not be required to pay a~corneyts fees. Remember you are also responsible for keepinq all real CSCaee taxes Ctlrren e. We may also sue you personally for the unpaid bala~ce and all other sums due under the morcqaqc~ If you have not cured che default within the thirty day period and foreclosure proceedinqs have begun, you still havc the right to cure the default and prevent the sale at any time UP cO one hour before the Sheriff's foreolosure sale. You may do so by paying the total a\noUnc. of the unp!>id monthly payments plUS any late or other ch~rges then due, as well as the reasonable actorneyts fees and costs connected with the foreclosure sale (and ~er1orm any othar requirements under the mortqaqe). Ie is es~imated thac the ear.liest da~e thae such a Sheriff's sale oould be held would be approximately one-hundred and fifty (150) days from the date of this lecter. A notice of the date of the Sheriff's sale will be sent to you bet ore the sale. Of course, the amount needed to cUre the default will inorease the longer you wait. You may find out at any time exactly what the required payment will be by oallinq us at the following number: 1-800-850-4522. The payment must be in cash, cashier's check, cercified check or money order and made payaDle to us de the address previously stated. I I I I I I j I I i I I I , I I You should realize that a Sheriff's sale will end your ownership of the mortqa;ed property and your right Co remain in it. If you continue to live in the property afcer the Sheriff's sale, a lawsuit could be started to evict you. NC'Tl:....~., ffhis-- is an attempt to collect a debt and Any information obcained will be used for that purpose. You have addic.ional rights to help protecc ycur interest in the property. yOU HAVE TH~ RIGHT TO SELL THE PROPERTY TO OETAIN MONEY TO PAY OFF THE MORTGAGE DICBT. OR TO BORROW MeN};;'! FROM ANOTHER LENDING INSTrTU'I'IO~ TO PAY OFF THIS DEBT. YOU MAY !lAVE THE RIGHT TO SELL OR 'I'RANSFER THE PROPERTY SUBJECT TO THE MORTGAGE TO A BuYER OR TRANSFEREE WHO WILL ASSUME THE MORTGAGE DEBT, PROVIDED THAT ALL OUTSTANDING PAYMENTS, CHARGES AND ATTORNEY'S FEES AND COSTS ARE PAID PRIOR TO OR AT THE SALE, (AND THAT ~~E OTHER REQUIREMENTS UNOER THE MORTGAGE ARE SATISFIED). CONTACT US TO DE'I'ERMINE UNDER WBAT CIRC1JMSTANCES THE RIGHT MAY EXIS'I'. YOU HAVE T3E RIGHT TO HAVE TRIS DEFAULT CURED BY ANY THIRD PARTY ACTING ON YOUR BEHALF. If you cure the default, ~he mortgage will be rescored to the same position a9 if no default had occurred. Ro~ever, you are not entitled to this right to cure your defuult more than three ~imes in any calendar year. DMS5-BRCHPA (Page 2 of 2) EXHIB\T A coo~ JVlI:l 91719 61;;: n;:Q. OC:8, 66/"((;/'2:1 . ii{ e:)~r.~ A.LL THAT CltRTAIN trac1:. of ~and in ~~er FrankfoX'd TownShi.:,..l..:=.::.~r=..rl~ CumbGrJ.and county, Pennsy1.van.J.a r con1:a.J.n1nc; 16.892 acres r be '?J'1 ;.;: the northern most ~art or ~he rarm now or ~o~8r~y of Ne1son i.~ ~ Shuqhart:., and Ruth E. Shughart, his wife, which farm is In ~.n . ~ part:..ieular1y looated as being i.n tha Northeast:. corner :fI~ ~ Legislative Route No. 2100~, known as Traffic Rou1:e No. 994 ~~ ~ To'W'n3hip Road No. 4.92, ~e tract hereby oonveyod being "'91sj'ij'iilrl':\ p;artioul;;r.rly bouT'ided and. describoci a.s ~ollows: :1. ." BEGINNING a't an iron pin on a 1.1na. of' land no.... or t'ormerly of C.C. Leidi.gh and l.and noW' or forn\er1y of Eu~ene c. Morrison, North 72 d.eqre.Qs 57 minutes 48 seconds. East 1.029..523 feet to a stone pil.e; thenoe Sou1:.h 21 dElqrees 42 "minu:t:.es 1.1. seconds East 495.75 :fee.t to an iron pin and. stone pile: 1:hence south 22 dec;rrees 4.1 minutes 53 seconds East 397.75 reet to an iron pin: thence South 75 degrees 22 minu~es 50 seconds West 64i.68 Zaet to l1n iron pin; thence North 45 degrees 30 )td.nutes :17 se.conds West 98~.602 ~eee ~o the ~1ace o~ beginning_ ~. CONTAININC 16.582 acres, more or 1ess_ BEING the same. premises that Wa1ter E. Morrison and Gera1dins L. Morrison, husband and wife, by their aeed dated the 28th day of PREMISES: 45 MARE ROAD ~-.~.....--~ --- _",1 . '"'I \ \ 'j \ . VERIFICATION FRANK FEDERMAN, ESQUIRE hereby states that he is attorney for Plaintiff in this matter, that he is authorized to take this Verification, and that the statements made in the ) foregoing civil Action in Mortgage Foreclosure are true and correct to the best of his knowledge, information and belief. The undersigned understands that this statement is made subject to the penalties of 18 Pa. C.S. Sec. 4904 relating to unsworn falsification to authorities. ~ :)---~ DATE: _I; 1-00 '.'.'.'. "".'.' ..:n:?li.iiiiiiiillllilliiiiiliiliiiilillllllllllllll11111111111111111111111111111111111111111!ll>" ""'.'.,.'> ,.','.' .....,'..,..,..... >,ii..--,; .0, ",j, '. ".....,.....,'.,',......".. .' " ",.""","""""""""" ",'" .,. . ,., ," .... ..,.'..... .>""",.""""" ....,..,..,.... i> .., ,>'>> . '. . ..,., . , >.L" ,,' , " , .' "'. , '. 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"- ---------------------- '" ,". '."""""""'.' , .> " .. .. .. .... .. .... ..,.".",""""...'..'"", " . ... ... .... .. . , '"",,':C < > ",",'", ".".".".,' , , ','.' > . "",.". .....,...'.",.. ., ':.',', " ,.-'--,-,-.,-,'-,,,--.,-,.,"-"~ ',"""',',',.,.' >>> ...,......, ...",' \< >.,,' .....> .. . ".",...,........,.,.. , .",'.., "".,',',"...,.",,"..'.. , ',',., ftf. 'iJ~;4 .,~.i .,.., '." :---- .." '....",.'.'.'., '.','.,",' "'" "........' "'<> ",'...........,-.. . ....,.. , ,'.." ....::..:....:>>... ~"",--- L ,".- - FEDERMAN AND PHELAN By: FRANK FEDERMAN, ESQUIRE IDENTIFICATION NO. 12248 TWO PENN CENTER PLAZA, SUITE 900 PHILADELPHIA, PA 19102 (215) 563-7000 GMAC MORTGAGE CORPORATION OF PA 3451 HAMMOND AVENUE P.O. BOX 780 WATERLOO, IA 50704 . ATTORNEY FORPLATINTIFF COURT OF COMMON PLEAS CIVIL DIVISION TERM Plaintiff V. NO. 0la2?- ;23~ ~ CUMBERLAND COUNTY SCOTT A. MATTHEWS KIMBERLY D. MATTHEWS 3703 ENOLA ROAD NEWVILLE, P A 17241 Defendant( s) CIVIL ACTION - LAW MORTGAGE FORECLOSURE NOTICE PLEASE BE ADVISED THAT THIS FIRM IS A DEBT COLLECTOR ATTEMPTING TO COLLECT A DEBT. A,''IY INFORMATION RECEIVED WILL BE USED FOR THAT PURPOSE. IF YOU HAVE PREVIOUSLY RECEIVED A DISCHARGE IN BANKRUPTCY AND THIS DEBT WAS NOT REAFFIR;\1ED. THIS CORRESPONDENCE IS NOT AND SHOULD NOT BE CONSTRUED TO BE AN ATTEMPT TO COLLECT A DEBT BUT ONLY ENFORCEMENT OF A LIEN AGAINST PROPERTY. You have been sued in Court. If you wish to defend against the claims set forth in the following pages, you must take action within twenty (20) days after this Complaint and Notice are served, by entering a written appearance personally or by attorney and filing in writing with the court your defenses or obj ections 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 LA WYER AT ONCE. IF YOU DO NOT HAVE A LAWYER OR CANNOT AFFORD ONE, 00 TO OR TELEPHONE THE OFFICE SET FORTH BELOW TO FIND OUT WHERE YOU CAN GET LEGAL HELP. CUMBERLAND COUNTY CUMBERLAND COUNTY BAR ASSOCIATION 2 LIBERTY AVENUE CARLISLE, PA 17013 (717) 249-3166 Loan #: 220870133 We hereby certify the \v:thin to be 0 true and enr-I "n't ...........f'!H 0"'. iho v ..::;..... ....,....V.;i " origrnal filed OT mcord FEDERMAN AND PHELAN ...-- ~~ ~,' . -- 1. Plaintiff is GMAC MORTGAGE CORPORATION OF PA 3451 HAMMOND AVENUE P.O. BOX 780 WATERLOO, IA 50704 2. The name(s) and last known addressees) of the Defendant(s) are: SCOTT A. MATTHEWS KIl'vIBERL YD. MATTHEWS 3703 ENOLA ROAD NEWVILLE, PAl 7241 who is/are the mortgagor(s) and real owner(s) of the property hereinafter described. 3. On 6/23/93 mortgagor(s) made, executed and delivered a mortgage upon the premises hereinafter described to PLAINTIFF which mortgage is recorded in the Office of the Recorder of CUMBERLAND County, in Mortgage Book No. 1144, Page 720. 4. The premises subject to said mortgage is described as attached. 5. The mortgage is in default because monthly payments of principal and interest upon said mortgage due 5/1/99 and each month thereafter are due and unpaid, and by the terms of said mortgage, upon failure of mortgagor to make such payments after a date specified by written notice sent to Mortgagor, the entire principal balance and all interest due thereon are collectible forthwith. A copy of such notice is attached as Exhibit "A." """- 6. The following amounts are due on the mortgage: Principal Balance Interest 4/1/99 through 11/1/99 (Per Diem $19.10) Attorney's Fees Cumulative Late Charges 6/23/93 to 11/1/99 Cost of Suit and Title Search Subtotal $101,38641 4,087.40 5,069.00 430.56 550.00 111,523.37 Escrow Credit Deficit Subtotal 22947 0.00 22947 TOTAL $111,293.90 7. The attorney's fees set forth above are in conformity with the Mortgage documents and Pennsylvania Law, and will be collected in the event of a third party purchaser at Sheriff's Sale. If the Mortgage is reinstated prior to the Sale, reasonable attorney's fees will be charged. 8. This action does not come under Act 6 of 1974 because the original mortgage amount exceeds $50,000. 9. This action does not come under Act 91 of 1983 because the mortgaged premises is not the principal residence of the Defendant(s). 10. Pursuant to the Fair Debt Collection Practices Act, 15 U.S.c. ~ 1692 et seq. (1977), Defendant(s) may dispute the validity of the debt or any portion thereof. If Defendant(s) do so in writing within thirty (30) days of receipt of this pleading, Counsel for Plaintiff will obtain and provide Defendant(s) with written verification thereof; otherwise, the debt will be assumed to be valid. Likewise, if requested within thirty (30) days of receipt of this pleading, Counsel for Plaintiff will send Defendant(s) the name and address of the original creditor if different from above. WHEREFORE, PLAINTIFF demands an in rem Judgment against the Defendant(s) in the sum of $ 111,293.90, together with interest from 11/1/99 at the rate of $19.10 per diem to the date of Judgment, and other costs and charges collectible under the mortgage and for the foreclosure and sale of the mortgaged property. /s/ Frank Federman FRANK FEDERMAN, ESQUIRE Attorney for Plaintiff TEl"'" 0"; ~..,..., ",~'!: K " "'" "'~~""H", I T _~ : -p )">' ~~"~'" ~ .~ ;: 1~:' ,- :';: ~<:~LtJt~~ n e"trmod;' v~lnJCV!i ! n2-fa unto set my hand and ,-he seal of sa;d fO,!o<j --~ r" [" I r, , \.,. V~ ,"J 'LufliSJG, ,"'a. This ..../~......:.. day o~..........., ~ ..........~. .c ~ ~........ ............. . ........ I _ .... Prothonota y GMAC Mortgage Corporation P.O. Box 85071 San Diego, CA 92166-5071 3451 Hammond Ave P.O. Box 780 Waterloo, IA 50704-0780 NOTICE OF INTENTION TO FORECLOSE AND ACCELERATE DATE: July 7, 1999 .! - , .. I-"~ ;.' _ ,'n_ '>'<,,,,,, , Servioing CERTIFIED MAIL NO. Z 472890838 TO: SCOTT A ~TTHEWS 3703 ENOLA RD NEWVILLE PA 17241 LOoMAc Mortgage RE: MORTGAGE LOAN NUMBER: MORTGAGED PREMISES: 220B70133 45 ~RE ROAD CARLISLE, PA 17013-9514 This company is the holder of the FIRST MORTGAGE <AND NOTE) on the above premises, or is the mortgage service agent for such holder. (Hereinafter referred to as we, us or ours) . As of the date of this notice, THE MORTGAGE IS IN SERIOUS DEFAULT because you have not made the May 1, 1999 and subsequent monthly payments as listed, and/or for other reasons as indicated below:' 3 payments @ $857.63 $2,572.89 Accrued late charges...................... ... .....$287.04 NSF Check Fees........... . . . . . . . . . . . . . . . . . . . . . . . . . . . $ 0 .00 All other fees accrued to date............ ..........$0.00 , Less available suspense credits ...... .... ..........$0.00 The total amount now required to cure this default, or in other words, get caught up in your payments as of the date of this letter is.................................... $2,859.93 You may cure this default within THIRTY (30) DAYS of the date of this letter, by paying to us the above amount, plus any additional monthly payments and late charges which may fall due during this period. Such payment must be made either by cash, cashier's check, certified check or mm'_";:"'-.c'?rd-err and made at, or sent to: 3451 Hammond Avenue, P.O. '-Eox 780, Waterloo, IA 50704-0780. If you do not cure the default within THIRTY (30) DAYS, we intend to exercise our riqht to accelerate the mortgage payments. This means that whatever is owing on the original amount borrowed will be considered due immediately and you may lose the chance to payoff the original mortgage in monthly installments. If full payment of the amount of default is not made within THIRTY (30) DAYS, we also intend to instruct our attorneys to start a lawsuit to foreclose your mortgaged property. If the mortgage is foreclosed your mortgaged property will be sold by the Sheriff to pay DMS5'ERCHPAC (Page 1 of 2) EXHIBIT A GMAC Mortgago Corporation P.O. Box 8507f ' San Diego, CA 92166-5071 3451 Hammond Ave P.O. Box 780 Waterloo, JA 50704-0780 NOTICE OF INTENTION TO FORECLOSE AND ACCELERATE DATE: July 7, 1999 " - ,-I , -_, "'- Servicing CERTIFIED MAIL NO. Z 472890839 TO: SCOTT A ~TTHEWS 45 ~RE: ROAD CARLIS~E PA 17013-9514 LOoMAc Mortgage RE: MORTGAGE LOAN NUMBER: MORTGAGED PREMISES: 220870133 45 ~RE ROAD CARLISLE, PA 17013-9514 This company is the holder of the FIRST MORTGAGE (AND NOTE) on the above premises, or is the mortgaqe service agent for such holder. (Hereinafter referred to as we, us or ours) . As of the date of this notice, THE MORTGAGE IS IN SERIOUS DEFAULT because you have not made the May 1, 1999 and subsequent monthly payments as listed, and/or for other reasons as indicated below: * 3 payments @ $857.63 $2,572.89 Accrued late charges........... ............. ......$2B7.04 NSF Check Fees..................................... .$0.00 All other fees accrued to date......................$O.OO , Less available suspense credits ................. ...$0.00 The total amount nOW required to cure this default, or in other words, get caught up in your payments as of the date of this letter is.................................... $2,859.93 You may cure this default within THIRTY (30) DAYS of the date of this letter, by paying to us the above amount, plus any additional monthly payments and late charges which may fall due during this period-. Such payment must be made either by cash, cashier's check, certified check or money order, and made at, or sent to: 3451 Hammond Avenue, - P.O. ,_Box 780, Waterloo,-iA 50704-0780. If you do not cure the default within THIRTY (30) DAYS, we intend to exercise our right to accelerate the mortgage payments. This means that whatever is owing on the oriqinal amount borrowed will be considered due immediately and you may lose the chance to payoff the original mortgage in monthly installments. If full payment of the amount of default is not made within THIRTY (30) DAYS, we also intend to instruct our atto~eys to start a lawsuit to foreclose your mortgaged property. If the mortgage is foreclosed your mortgaged property will be sold by the Sheriff to pay DMS5-BRCHPAC (Page 1 of 2) EXHIBIT A ~C_ ,...-.... ~~ "ii", GMJlC Mortgage Corporation P.O. Box B507f San Diego, OA 92168-5071 3451 Hammond Ave P.O. Box 7BO Waterloo, IA 50704-0760 NOTICE OF INTENTION TO FORECLOSE AND ACCELERATE PATE: JUly 19, 1999 Servicing LOoMAc Mortgage CERTIFIED ~IL NO. Z '1'0: RIMBERL YD. WI'l'TllEWS 3703 ENOLA RD NEWVILLE, PA 17241 &E: MORTGAGE LOAN NUMBER: MORTGAGED PREMISES: 220B70133 45 WIRE ROAD CARLISLE, PA 17013-9514 This company is the holder of the FIRST MORTGAGE (AND NOTE) on thc abo~e premises, or is the mortqaqe servioe aqent for Such holder. (Hereinafcer rererred eo as we, us or ours). As of the date of this notice, THE MORTGAGE IS IN SERIOUS DEFAuLT hecause yoU have not made the May 1, 1999 and subsequent monthly payments as listed. and/or for ocher rc~sons as indicaced belcw:~ 3 payments 0 $857.63 $2,572.89 Accrued late charges..... . . . . . . . . . . . . . . . . . . . . . . . . . $322.92 NS~ cheCK Fees..............................,........$ 0.00 All other fees accrued to date...................... $0.00 * Less availabl~ suspense credics ....................$0.00 The total amount now rcquired Co cure this defaUlt, or in other words, qet cauqht up in your payments as o~ the date ",f this lett~r is................................... .$2,895.81 You may cure this default within THIRTY (30) DAYS of thc date of this lecter, hy payinq to us che above amounc. plus any additional monthly payrnonts and late charges which may fall due during this period. Such p~~nent must be mace either by cash, eashier's chack, certified check or money order, and made at, or se~c Co: 3451 Hammond ~venue, ?O. Eo~ 7801 Wata~:::"''',' IA -50704-0780. If you do noc cure the default within THIRTY (30) DAYS, we intend to exercise our right to accelerate the rnortqaqe payments. This means cha~ whatever is owinq on the original amount borrowed will be considered Q~e imrnediacely and you may lose the chancQ to payoff the original mortqaqe in monchly installmencs. If full p~yment of ehe ~rnount of defaul~ is not made wi~hin THIRTY (30) DAYS, we also intend to i~gCruct our ac~o~eys to start a lawsuit to foreclose your mortgaged prop~rty. If the mortgag~ is foreclosed your mortgaged property will be sold by the sheriff to pay DMSS'BRCH?A (Page 1 of 2) ZOO~ J Vl'l~ SH9 61:Z t:1Z.,g. EXHIB\T A 01::8t 66'tZ:Zt - ~~ <. .~, , '"~',: GMAC Mortgage Corporation P.O. Box B507f San Diego. CA 92186-5071 3451 Hammond Ave P.O. Box 760 Waterloo, IA 50704-0780 NOTICE OF INTENTION TO FORECLOSE AND ACCELERATE DATE: July 19, 1999 Servloing LOoMAc Mortgage CERTIFIED MAIL NO. ~ TO: KIMEERLY D. ~TTHEWS 45 M,>,RE ROAD CARI8LE, PA 17013-95l~ RE : MORTGAGE LOAN NUMBl!:R: MORTGAGED PREMISl!:S: 220B70133 45 MlU<J:; ROAD CARLISLE, PA 17013-9514 This company is the holder of Che FIRST MORTGAGE (AND NOTE) on the abovo premises, or is the rnorc~aqe service aqent for such holder. (Hereinafter referred to as we, us or ours) . As of the dace of this notice, THE MORTGAGE IS IN SERIOUS DEFAULT bccause you have noC made the May 1. 1999 and subsequent monthly payments as listed, and/or for other reasons as indicated below:' 3 payment" '" $857.63 $2,572.89 Accrued late charges..................... .... .....$322.92 NSY Cheok Fees......... . .. . . . .... ., . . . . . . .... . . . . . . . $0.00 All other fccs accrued to date. .....................$0.00 . Less available suspense credits ....................$0.00 The total amount noW required to cure this default, or in other words, qat caught up in your pa~nents as of the date of this letter is................................... .$2,B95.81 You may cure this default within THIRTY (30) DAYS of the date of this letter, by paying to us the above amount, plus any additional monthly payments and latc charges which may fall due during chis period. Such payment must be made either by cash, cashier's check, certified check or money order, and made at, or s.e.ne. t.o: 3451 Ha.lw.nond A.venu.e, P.O. Bo)t 1801 Wate_~~~1 !~ 50704.0780. If you do not cure the default wichin THIRTY (30) DAYS, we intend to exercise our right eo accelera~e the mortqage paymenC$. ~~is means that whatever is owing on che original amount borrowed will be considered rille irnm.,dia.cely and you may lose the chance to payoff che original mortq~(le in monthly installmen~s. If full pa.ymenc of che amOUnC or default is not made within THIRTY (30) DAYS, we also intend to instruct our attorneys to start a lawsuic co foreclose your mortqaqed property. Ir the mortqa.ge is foreclosed your mortqa.ged property will be sold by the Sheriff Co pay DMSS'BRCHPA (paqe 1 of 2) EXHIBIT A ~oo rei ;)Vl'l~ SH9 61;;; O;;.g, 11:: 81 66/1;;/;;r . .; .; " ~ July 19, 1999 Page 2 22d870133 off the debt. If we refer your case CO our attorneys, but you cure the defaulc before they begin legal proceedings against you, you will still have to p~y the reasonable at~orneyls fees, aceuaJly incurred, u~ to $50.00. However, if leqal proeeedinqs are started aqainst you, you will have to pay the reasonable attorney's fees eVen if they are over SSO.OO. Any attorney's :fees will be added t.o whaceV'er you owe us, which may ,also include our reasonable costs. If you oure the default wichin the thirty day period. you will not be required to pay a~corney's fees. Remember you are also responsible for keepinq all real cs~aee taxes c:urrent. we may also sue you personally for t.he unpaid balance and all ot~er ~.~~ due under the mor~qaqc. If you have not cured che default within the thirty day period and foreclosure prooeedings have begun, you still havc the right to oure the default and prevent the Sale at any time up to one hour before ehe Sheriff's foreclosure sale. You may do so by paying the total amounc of the unpaid monthly payments plUS any late or other ch~Iges then due, as well as the reasonable actorney's fec~ and costs connected with the foreclosure sale (and pertorm any other requirements under the. mortqaqej. Ie is estimated tha~ the earliest da~e thae such a Sheriff's sale oould he held would be approximately one-hundred and fifty (150) days from the dace of this leCter. A notioe of the date of the Sheriff's sale will be sent to yo~ betore the sale. of course, the amount needed to c~re the default will increase the lonqer you wait. YoU m~y find out at any time exaccly what the required payment will be by callinq us at the followinq number: 1-800-850-452J. The payment must be in cash. cashier's check, cercified check or money order and made pay~ble to us ac the address previouslY stated. You should realize that a Sheriff's sale will end your ownership ot the mortgaqed property and your riqht to remain in it. If you continue to live in the property after Ch@ Sheriffta sale. a lawsuit co~ld be started to eviC!t you. NC'f1.....i..- ;rhis is a.n att.empt to collect a debt and <1ny information obcained will be used for that purpose. You have addicional rights to help protecc your interest in the property. YOU HAVE THE RIGHT TO SELL THE ??'OPERTY TO OBTAIN MONEY TO PAY OFF THE MORTGAGE D~BT, OR TO BORROW MONEY FROM ANOTHER LENDING INSTITU~'ION TO PAY OFF THIS DEBT. YOU MAY !lAVE THE RIGHT TO SE:LL OR 'I'RANSFER THE PROPERTY SUBJECT TO THE MORTGAGE TO A BUYER OR TRANSFEREE WHO WILL ASSUME THE MORTGAGE DEBT, PROVIDED THAT ALL OUTSTANDING PAYMENTS, CH~~GES AND ATTORNEY'S FEES AND COSTS ARE PAID PRIO~ TO OR AT THE S~LE, (AND THAT ~~~ OTHER REQUIREMENTS UNDER THE MORTGAGE ~RE SATISFIED). CONTACT US TO DE~'ERMINE UNDER WHAT CIRCUMSTANCES TEE RIGHT MAY EXIS1'. YOU l!!WE THE RIGHT TO H~VE T!lIS DEFAULT CURED BY ANY THIRD P~RTY ACTING ON YOUR BEHALF. If you cure the default, the mortgaqe will be r~seored eo the same posiCion as if no default had occurred. However. you are noe entitled to this right eo cure your def~ult more than three times in any calendur year. DMS5-BRCHl'A (?age 2 of 2) 'EXHIBIT A coo~ JYl'i:J SH9 6CZ nz,Q. OC:S! 66/IZ/ZI ~ ~~ 1\LL 'I'tlAT CERTAIN t;raci: of 1and in Lower Frankfc::n;d TownShf~:.(;'~/~'~] cumberl..and county, Pennsy1.van.ia, cont:a.ining J.6. 892 aores r be ':V1 *' the northorn ~o~t part or ~he rarm now or ~ormQr~y o~ Ne1son.~ ~ Sh'uqhart:., and Ruth E. Shuqhart:., his wi1:e, which :t'arm is In Ef-" . ~ pa.r~.ic'Y.larl.'y ).oc~t:.eQ as being in the Northe83t corner :6=::;ll :r Leqie1ative Route No. 2100~, known as Trarf~c ~ou~e No. 994 ~~ € Town.ship Road No. 4.92, the 1:.ract:. hereby conveYCl3d being m91f~i'ijii I r I"! I particul.arJ.y bounded and described os %o11.o'Ws: .1. . I. BECINNINC a't::. an iron pin on a l.in~ of land noy or 't"ormGrly of C.C. Laidi9h and. l.and no,", or :S:ornua:z:o1y of' Eugene C. Mor:r:i.son, North 72 deqraQs 57 minutes 48 seconds. East 1029.523 ~eet to a stone pile; thence Sou~h 21 deqrees 42 Minu~es 11 seconds East 49$.7S :rQ(!,t to Bn iron pin and stone pile.; thence. South 22 deqr~es 4~ minutes 53 seoonds East 397.75 ~eet to a~ iren pin; thQnca South 75 degrees 22 minu~es 50 seconds Wast 641.68 rQet to an iron pin; thence North 4S de9reas 30 minu~es ~7 seconds West 9a1.602 raet to the ~1aee o~ beqinning_ ! CONTAZNINa 16.662 acres, ~ore or 1ass. aZING ~he same. pramises tbat Wa1ter E. Morrison and Gera1dine L. Morriaon, husbana and w1%e, by their deed dated the zath day or PREMISES: 45 MARE ROAD -'-~~~... ,-- ~- """'"'" - :~ . , \ \. , , VERIFICATION FRANK FEDERMAN, ESQUIRE hereby states that he is attorney for plaintiff in this matter, that he is authorized to \ ! take this Verification, and that the statements made in the foreqoinq Civil Action in Mortqaqe Foreclosure are true and correct to the best of his knowledqe, information and belief. The undersiqned understands that this statement is made subject to the penalties of ~8 Pa. C.S. Sec. 4904 relatinq to unsworn falsification to authorities. ~:r~ DATE: -1~ 1 ~o 0 - FEDERMAN AND PHELAN By: FRANK FEDERMAN, ESQUIRE IDENTIFICATION NO. 12248 TWO PENN CENTER PLAZA, SUITE 900 PHILADELPHIA, PA 19102 (215) 563-7000 ATTORNEY FORPLMNTIFF COURT OF COMMON PLEAS CNIL DNISION GMAC MORTGAGE CORPORATION OF PA 3451 HAMMOND AVENUE P.O. BOX 780 WATERLOO, IA 50704 TERM Plaintiff V. NO. 0lQX> - .:23;'< 6?J CUMBERLAND COUNTY SCOTT A. MATTHEWS KIMBERLY D. MATTHEWS 3703 ENOLA ROAD NEWVILLE, P A 17241 Defendant( s) CIVIL ACTION - LAW MORTGAGE FORECLOSURE NOTICE PLEASE BE ADVISED THAT THIS FIRM IS A DEBT COLLECTOR ATTEMPTING TO COLLECT A DEBT. ANY INFORMATION RECEIVED WILL BE USED FOR THAT PURPOSE. IF YOU HAVE PREVIOUSLY RECEIVED A DISCHARGE IN BANKRUPTCY AND THIS DEBT WAS NOT REAFFIRMED, THIS CORRESPONDENCE IS NOT AND SHOULD NOT BE CONSTRUED TO BE AN ATTEMPT TO COLLECT A DEBT BUT ONLY ENFORCEMENT OF A LIEN AGAINST PROPERTY. You have been sued in Court. If you wish to defend against the claims set forth in the following pages, you must take action within twenty (20) days after this Complaint and Notice are served, by entering a written appearance personally or by attorney and filing in writing with the court your defenses or objections to the claims set forth against you. You are warned that if you fail to do so the case may proceed without you and a judgment may be entered against you by the court without further notice for any money claimed in the Complsint or for any other claim or relief requested by the Plaintiff. You may lose money or property or other rights important to you. YOU SHOULD TAKE THIS PAPER TO YOUR LAWYER AT ONCE. IF YOU DO NOT HAVE A LAWYER OR CANNOT AFFORD ONE, GO TO OR TELEPHONE THE OFFICE SET FORTH BELOW TO FIND OUT WHERE YOU CAN GET LEGAL HELP. CUMBERLAND COUNTY CUMBERLAND COUNTY BAR ASSOCIATION 2 LIBERTY AVENUE CARLISLE,PA 17013 (717) 249-3166 Loan #: 220870133 W,e ~ereby certify the WithIn to be Ell';ue and corrs.ct r'al'1~j clJ ""1" ,J ~... )1 i Ll l., "-""]""1 c" "''',.".C 'l'I--10""'~ I ~r-:'~' ~" '-'\...J I I t:,;'t,OfC h;:.)<:'R".li'\" n,,~, ~ '- h'd"i..\1 J"'d\1~.. ".-,'-.tr-~ ~!;\,.iJ ,~ ".i;,4 ~ l! .~L.J.4.:,~ '-"'~~ ... ~ , " 1. Plaintiff is GMAC MORTGAGE CORPORATION OF PA 3451 HAMMOND AVENUE P.O. BOX 780 WATERLOO, IA 50704 2. The name(s) and last known addressees) of the Defendant(s) are: SCOTT A. MATTIIEWS KIMBERLYD. MATTHEWS 3703 ENOLA ROAD NEWVILLE, P A 17241 who is/are the mortgagor(s) and resl owner(s) of the property hereinafter described. 3. On 6/23/93 mortgagor(s) made, executed and delivered a mortgage upon the premises hereinafter described to PLAINTIFF which mortgage is recorded in the Office of the Recorder of CUMBERLAND County, in Mortgage Book No. 1144, Page 720. 4. The premises subject to said mortgage is described as attached. 5. The mortgage is in default because monthly payments of principal and interest upon said mortgage due 5/1/99 and each month thereafter are due and unpaid, and by the terms of said mortgage, upon failure of mortgagor to make such payments after a date specified by written notice sent to Mortgagor, the entire principal balance and all interest due thereon are collectible forthwith. A copy of such notice is attached as Exhibit "A." ~"~ L ,~ 6. The following amounts are due on the mortgage: Principal Balance Interest 4/1/99 through 11/1/99 (Per Diem $19.10) Attorney's Fees Cumulative Late Charges 6/23/93 to 11/1/99 Cost of Suit and Title Search Subtotal $101,386.41 4,087.40 5,069.00 430.56 550.00 111,52337 Escrow Credit Deficit Subtotal 229.47 0.00 229.47 TOTAL $111,293.90 7. The attorney's fees set forth above are in conformity with the Mortgage documents and Pennsylvania Law, and will be collected in the event of a third party purchaser at Sheriff's Sale. If the Mortgage is reinstated prior to the Sale, reasonable attorney's fees will be charged. 8. This action does not come under Act 6 of 1974 because the original mortgage amount exceeds $50,000. 9. This action does not come under Act 9 I of 1983 because the mortgaged premises is not the principal residence of the Defendant(s). 10. Pursuant to the Fair Debt Collection Practices Act, 15 U.S.C. ~ 1692 et seq. (1977), Defendant(s) may dispute the validity of the debt or any portion thereof. IfDefendant(s) do so in writing within thirty (30) days of receipt of this pleading, Counsel for Plaintiff will obtain alld provide Defendant(s) with written verification thereof; otherwise, the debt will be assumed to be valid. Likewise, if requested within thirty (30) days of receipt of this pleading, Counsel for Plaintiff will send Defendant(s) the name and address of the original creditor if different from above. WHEREFORE, PLAINTIFF demands an i!! rem Judgment against the Defendant(s) in the sum of $ 111,293.90, together with interest from 1111/99 at the rate of$19.1O per diem to the date of Judgment, and other costs and charges collectible under the mortgage and for the foreclosure and sale of the mortgaged property. Isl Frank Federman FRANK FEDERMAN, ESQUIRE Attorney for Plaintiff TRUE CC~"'f r:i/,';' ~~r~.PD In Testimony Vl/h0n:o( : - - u~:t;""~~:t~'n~~' hand and the seal of said lOUrl at Cariisie, pa.' This .....19.1.....;.. day o~........., ~ .............~.......g~,..~.. Prothonotary " - ~~- ~~-" GMAC Mortgage Corporation P.O. Box 8507f San Diego, CA 92186-5071 3451 Hammond Ave P.O. Box 780 Waterloo, IA 50704-0780 NOTICE OF INTENTION TO FORECLOSE AND ACCELERATE DATE: July 7, 1999 Servicing LOoMAc Mortgage CERTIFIED MAIL NO. Z 47289083B TO: SCOTT A ~TTHEWS 3703 ENOLA RD NEWVILLE PA 17241 RE: MORTGAGE LOAN NUMBER: MORTGAGED PREMISES: 220870133 45 ~RE ROAD CARLISLE, PA 17013-9514 This company is the holder of the FIRST MORTGAGE (AND NOTE) on the above premises, or is the mortgage service agent for such holder. (Hereinafter referred to as we, us or ours) . As of the date of this notice, THE MORTGAGE IS IN SERIOUS DEFAULT because you have not made the May 1, 1999 and subsequent monthly payments as listed, and/or for other reasons as indicated below: * 3 payments @ $857.63 $2,572.89 Accrued late charges. ............ ..... ..... ...... .$287.04 NSF Check Fees...................................... $ 0 . 00 All other fees accrued to date... .... ...............$0.00 . Less available suspense credits ..... ...............$0.00 The total amount now required to cure this default, or in other words, get caught up in your payments as of the date of this letter is................................... .$2,859.93 You may cure this default within THIRTY (30) DAYS of the date of this letter, by paying to us the above amount, plus any additional monthly payments and late charges which may fall due during this period. Such payment must be made either by cash, cashier's check, certified check or mOL..",.:".....:")rder, and made at/ or sent to: 3451 Hanunond Avenue, - P.O. <-Eox 780, Waterloo, IA 50704-0780. If you do not cure the default within THIRTY (30) DAYS, we intend to exercise our right to accelerate the mortgage payments. This means that whatever is owing on the original amount borrowed will be considered due immediately and you may lose the chance to payoff the original mortgage in monthly installments. If full payment of the amount of default is not made within THIRTY (30) DAYS, we also intend to instruct our attorneys to start a lawsuit to foreclose your mortgaged property. If the mortgage is foreclosed your mortgaged property will be scld by the Sheriff to pay DMS5'BRCHPAC (Page 1 of 2) EXHIBIT A - - I.. Servicing -Jot,: GMAC Mortgage Corporation P.O. Box 6507f San Diego, CA 92186-5071 3451 Hammond Ave P.O. Box 780 Waterloo, IA 50704-0760 NOTICE OF INTENTION TO FORECLOSE AND ACCELERATE DATE: July 7, 1999 LOGue Mortgage CERTIFIED ~IL NO. Z 472B90839 TO: SCOTT A MATTHEWS 45 ~RE ROAD CARLISLE PA 17013-9514 RE : MORTGAGE LOAN NUMBER: MORTGAGED PREMISES: 220870133 45 ~RE ROAD CARLISLE, PA 17013-9514 This company is the holder of the FIRST MORTGAGE (AND NOTE) on the above premises, or is the mortgage service agent for such holder. (Hereinafter referred to as we, us or ours). As of the date of this notice, THE MORTGAGE IS IN SERIOUS DEFAULT because you have not made the May 1, 1999 and subsequent monthly payments as listed, and/or for other reasons as indicated below:' 3 payments @ $857.63 $2,572.89 Accrued late charges......... ....... ......... .... .$2B7.04 NSF Check Fees. . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . $0.00 All other fees accrued to date......... ......... ....$0.00 * Less available suspense credits ....................$0.00 The total amount now required to cure this default, or in other words, get caught up in your payments as of the date of this letter is................................... .$2,B59.93 You may cure this default within THIRTY (30) DAYS of the date of this letter, by paying to us the above amount, plus any additional monthly payments and late charges which may fall due during this period. Such payment must be made either by cash, cashier's check, certified check or mon,eyorder, and made at, or sent to: 3451 Hammond Avenue," P.O. ,_Eox 780, Wat;'r'ioo,-:i:A 50704-0780. If you do not cure the default within THIRTY (30) DAYS, we intend to exercise our right to accelerate the mortgage payments. This means that whatever is owing on the original amount borrowed will be considered due immediately and you may lose the chance to payoff the original mortgage in monthly installments. If full payment of the amount of default is not made within THIRTY (30) DAYS, we also intend to instruct our attorneys to start a lawsuit to foreclose your mortgaged property. If the mortgage is foreclosed your mortgaged property will be sold by the Sheriff to pay DMS5-BRCHPAC (Page 1 of 2) EXHIBIT A . ~. "~ ~ ~. GMAC Mortgage Corporation P.O. Box B507f San Diego, 0'>' 921B6-5071 3451 Hammond Ave P.O. Box 7BO Waterloo, IA 50704-0780 NOTICE OF INTENTION TO FORECLOSE AND ACCELERATE DATE: July 19, 1999 Servloing LOoMAc Mortgage CERTIFIED ~IL NO. Z TO: RIMBERLY D. ~TTHEWS 3703 ENOLA RD NEWVILLE, PA 17241 RE: MORTGAGE LOAN NUMBER: MORTGAGED PREMIS:E:S: 220870133 45 ~RE ROAD CARLISLE, PA 17013-9514 This company is the holder of the FIRST MORTGAGE (AND NOTE) on the above premises, or is the mortqaqe service aqenc for SUCh holder. (Hereinafter referred ~o as we, us or curs) . As of the date of this notioe, THE MORTGAGE IS IN SERIOUS DEFA~LT beoause yoU have not made the May 1, 1999 and subsequent monthly payments as listed, and/or for ocher reasons as indicaced below;y 3 payments 0 $857.63 $2,572.89 Acorued late charqes... ........ .............. .....$322.92 NSF Check Fees..............................,....... $ 0 .00 All other fees acorued to date...................... $0.00 * Less available auspense credics ....................$0.00 The total amount now required to cure this defaUlt, or. in other words, get cauqht up in your payments as or the date of this letter is..,................................ .$2,895.Bl You may cure this defaUlt within THIRTY (30) DAYS of thc date of chis letter, by payinq to Us che above amo~nc, plus any additional monthly paymcnts and late charges which may fall due during this periOd. Such pa~nent must be made either by cash, cashier's check, certified check or money order. and made at, or senC co: 3451 Hammond Avenue, ?O. Bc~ 780, W"t"'.c;'".~, :::A ~50704-0780. If you do noc cure the aefaulc within THIRTY (30) DAYS, we intend to exercise our riqht to accelerate the mortgage payments. This meanS chat whatever is owing on the original amount borrowed will be considered due irnmediacely and yOU may lose the chance to payoff the oriqinal morCqage in mon~hly installments. If full payment of che amount of defaUlt is not made wi~hin THIRTY (30) DAYS, We also intend to inscruct our atcorneys to start a lawsuit to foreclose your mortqaqed property. If the mortgaqe is foreclosed your mortgaged property will ~e sold by the Sheri!f to pay DMS5-BRCH?A (paqe 1 of 2) zoo lEi JVI'I:) SV"l9 6~Z nz.Q. EXH\B\T A o~:~t 66!tZIZt - ~~ GMJlC Mortgage Corporation P.O. Box B507f San Diego, OA 92186-5071 2451 Hammond Ave P.O. Box 760 Waterloo,IA 50704--0760 NOTICE OF INTENTION TO FORECLOSE AND ACCELERATE DATE: July 19, 1999 Servloing LOoMAc Mortgage CERTIFIED MAIL NO. Z TO: KIMllEll.LY D. ~TTHEWS 45 WUtE ROAD CAll.!8LE, PA 17013-9514 llE: MORTGAGE LOAN NUMBER: MORTGAGED PREMISES: 220670133 45 MARl:< ROAD CARLISLE, PA 17013-9514 This company is the holder of Cbe FIRST MORTGAGE (AND NOTE) on the above premises, or is the morcqaqe service agent for such holaer. (Hereinafter refer~ed to as we! us or ours). As of the dace of this notice, THE MORTGAGE IS IN SERIOUS DEFAULT because you have noc made the May J., 1999 and Subsequent monthly payments as listed, and/or for other reasons as indicaced below:' 3 payments @ $857.63 $2,572.89 Accrued late charges....................... . . . . . . . $322.92 NSF Check Fees... _ . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . $ 0 . 00 All other fees accrued to date......................$O.OO ~ Less available suspense creaitG .......I..I.........~O.OO The total amount now required to cure chis default, or in other words, get caUght up in your payments as of the dat.e of this letter is................................... .$2,895.81 Y~U may cure this default within THIRTY (30) DAYS of the dace of this letter, bY paying to us the above amount, plus any additional monthly payments and late charges which may fall dUe durinq chis period. Such payment must be made either by cash, cashier's oheck, certified check or money ordcr, and Inade at, or sent to: 3451 RalNnond Avenue, P.O. Bo~ 7BO, Wate_ ':''":'~J - I.:\ 50704-0780. If you do not cure the default wichin THIRTY (30) DAYS, we incend Co exercise our right to aooelerace the mortgage paymenCs. ~nis means that whatever is owinq on che orillina1 amount borrowed will be considered rille immediat.ely alld you may luse the ohanoe to payoff che oriqinal mortq~'l'e in monthlY installments. If full payment of ~he amount. of default is not made within THIRTY (30) DAYS, we also intend to instruct our attorneys to start a lawsuic Co foreclose your mortqaqed property. Ir the mortqaqe is fureolosed your mortqaqed property will be sold by the Sheriff to pay DMS5'BRCHPA (Page 1 of 2) EXHIBIT A too lEi JVl'lCl SH9 6~;: n;:,g, H:Sl 66/16/61 - - i July 19, 1999 Page 2 220B70133 off the debt. If we refer your case eo our attorneys, but you cure the default before they begin legal proceedings against you, you will still have eo pay the reasonable ateorney's fees, aceually incurred, up to $50.00. Howeverf if leqal prooeedings are started ~qain$t you, you will have to pay the rea.sonable attoX"ney's fees even if they are over $50.00. .Any attorney's fees. will be a.d.de.Q. t.o whatever you. owe us, which ma.y also include our reasonable costs. If you cure the default within the thirty day period, yo~ will not be required to pay accorney'5 fees. Remember you are also responsible for keepinq all real C5cate taxes ctlrrent:.. We may also sue you personally for the unpaid balance and all other sums due under the moreqaqc. If you have not cured che default within the thirty day period and foreolosure prooeedings have begun, you still have the right to oure the default and prevent the Sale at any time up to one hour before ehe Sheriff's foreclosure sale. YoU may do so by paying the total amount of the unpaid monthly payments plUS any late or other ch~rges then due, as well as the reasonable attorney's fee> and costs oonnected with the foreclosure sale (and perform any other requirements under the mortqaqe). Ie is estimated thac the ear.liest daee that such a Sheriff's sale could be held would be approximately one-hundred and fifty (150) days from the date of this lecter. A notioe of the date of the Sheriff's sale will be senC to you before the sale. Of course, the amount needed to cure the default will increase the lonqer you wait. You m~y find out at any time exactly what the required payment will be by oallinq us at the followinq number, 1-BOO-850-4522. The payment must be in cash, cashier's cheC~f eercitied check or money order and made payable to us at the address previouslY stated. You should realize that a Sheriff's sale will end your ownership of the mortgaqed property and your right co remain in ic. If you continue to live in the property afcer the Sheriff's sale, a lawsuit could be started to evict you. NC'Tr.....:<::. -' -Phis.' is an a.ttempt to collect a debt and any information obcained will be used for that purpose. You have addi~icnal ~iQhts to help protecc ycu~ ince~es~ in the property. YOU HAVE TH~ ~IGHT TO SELL THE P?'OPERTY TO OBTAIN MONEY TO PAY OFF THE MORTGAGE DEBT, OR TO BORROW JoIONEY FROM ANOTRl':'l\ LENDING INSTITU'I'IOl'l TO 'P>.'f OFF THIS DEBT. YOU ~Y HAVE THE RIGHT TO SEL~ OR ~~ANSFER THE PROPERTY SUBJECT TO THE MORTGAGE TO A BUYER OR TRANSFEREE WHO WILL ASSUME TaR MORTGAGE DEBT, PROVIDED THAT ALL OUTSTANDING PAYMENTS, CHARGES AND ATTORNEY'S FEES AND COSTS ARE PAIn PRIOR TO OR AT THE SALE, (AND THAT THE OTHER REQUIREMENTS UNDER THE MORTGAGE ~RE SATISFIED). CONTACT US TO DE~'ERMINE UNDER lfflAT CIRCUMSTANCES TllE ~IGHT MAY EXIS~'. YOU HAVE THE R!GHT TO ~AVE THIS DEFAULT CURED BY ANY THIRD PARTY ACTING ON YOUR BEHALF. If you cure the aefault, ~he mortgage will be reseored ~o the same posiCion as if no default had oecurred. However, you are no~ entieled ~o this right to cure your def~ult more than three times in any calendar year. DMS5-BRCHl?A (?age 2 of 2) EXHIBlT A coo~ :)\IW~ ~H9 6C;; cn,g, oc: S]: 66.' t6l(;"[ ~~" -:'~'-'~. .. . , "(~I-'" ALL THAT CI'i:RTAIN traci: of ~and in Lower FrankfQ~d TownShf~!.;,~;<~g~i CumbQrl.and. County, Pennsy1.van.1.8, containi.ng 1.6. S92 acres, be ~ ;,~ the northern mo~t part or the fa~ now or ~ormer1y of Ne1son i.~ ~ Shuqhart:., and. Ruth E. Shuqhart:., his wi~El, which rarm is In ~.n . ~5 parl:.ieularl.y looat:.ed. as being i.n the Northeas~ corner fl~ ~ Legislative Route No. 21001., known as Traffio Route No. 994 ~~ ~ Towne-hip Road No. 4.92, t:ha tract hereby convaYQd be:i.n9 mOf'p:ii'iiiillJ'~1 particu1arl.y bounded and describe.d o.s foJ.lows: :1. ,I, SECINNI:NG a'l:, an iron pin on a line. of l.and now or formerl.y of c.c. Leidiqh and l.and no'" or forn\Cl!.r1.y of Eugene C. Morrison, North 72 deqreQs 57 lDinutea 48 seconds. East 1.029.522 :feet to a stone piJ.e; thenee Sou~h 21 4&qrees 42 'minutes 11 secon4s East 495.76 ;eeet to an iron pin and stene. pile; t.hence south 22 de9~QeS 41 minutes 53 seconds East 397.75 ~eet to a~ iron pin; thence south 75 degrees 22 minu~es 50 seeonds Weat 541.68 fQe~ to lIn iron pin: thence North 4-5 degrees 30 )lIinu~es 37 seconds West: 98~.602 ree~ ~o the p1ace or beginning_ 1 CONTAINXNG 16.582 acres, more or ~ess. SEING ~he sama premises that Wa1~er E. Morrison and Gera~dinQ L. Morrison, husbnna and wi~e, by their ~eea dated the 28th day or PREMISES: 45 MARE ROAD ~-.'""O;;"',-~._~ ~, lH ,'^' '"" - "'- , < ~ '.' - 1J '1 . , \ \ \ " , VERIFICATION FRANK FEDERMAN, ESQUIRE hereby states that he is attorney for Plaintiff in this matter, that he is authorized to take this verification, and that the statements made in the , foregoing civil Action in Mortgage Foreclosure are true and correct to the best of his knowledge, information and belief. The undersigned understands that this statement is made subject to the penalties of 18 Pa. c.s. Sec. 4904 relating to unsworn falsification to authorities. ~ :)---~ DATE: -'~ 1 ~o 0 .-- \. f ,., ~ ~ . , " ';' FEDERMAN AND PHELAN BY: FRANK FEDERMAN, ESQUIRE Identification No. 12248 Suite 900 Two Penn Center Plaza Philadelphia, PA 19102 (215) 563-7000 Attorney for Plaintiff GMAC MORTGAGE CORPORATION OF PA PLAINTIFF COURT OF COMMON PLEAS vs. CUMBERLAND COUNTY No. 2000-232-CIVIL SCOTT A. MATTHEWS KIMBERLY D. MATTHEWS DEFENDANT PRAECIPE TO SUBSTITUTE VERIFICATION TO THE PROTHONOTARY: Kindly substitute the attached Verification with respect to the Complaint filed in the instant matter. -1'4 ~d~~v/ FRANK FEDERMAN, ESQUIRE Attorney for Plaintiff Date: January 21, 2000 --..-- .... '. .' .. ~-. -~- - '"-'; r VERIFICA nON SHIRLEY lEADS hereby states that she is FORECLOSURE SPECIALIST ofGMAC MORTGAGE CORPORATION mortgage servicing agent for Plaintiff in this matter, that she is authorized to take this Verification. and that the statements made in the foregoing Civil Action in Mortgage Foreclosure are true and correct to the best of her knowledge, information and belief. The undersigned understands that this statement is made subject to the penalties of 18 Pa. C.S. Sec. 4904 relating to unsworn falsification to authorities. AjP~ DATE: I I JO / en I / !' ,. . , '" --- ALL-sTATELEGAL. 07153 ~ i' '- ADivis.ionofAlI.statelntemational,lrlc. - 800-222.{l510inl'tF9oa-272-o~OO "- , to <.? () C Cl e'n $: '-- vD...:.' :::;~ H1rT; ~~ -n Z:J..l ,.,1- ;=; ZC N _:j-:q (fJ -,,' "'- --,.......,- -<:;, (,) l. r- r--, "'-"'le> <'-- -0 "7'-TI :PC :1.: ~~ Zd )>c !:? ~ ~ - ).> :D .....l -< ,,' ,I 1,1 , .. FEDERMAN AND PHELAN BY: FRANK FEDERMAN, ESQUIRE Identification No. 12248 Two Penn Center Plaza, Suite 900 Philadelphia, PA 19102 (215) 563-7000 Attorney for Plaintiff GMAC MORTGAGE CORPORATION OF PA COURT OF COMMON PLEAS Plaintiff CIVIL DIVISION vs. SCOTT A. MATTHEWS KIMBERLY D. MATTHEWS Cumberland County Defendants No. 2000 232 CIVIL PRAECIPE TO REINSTATE CIVIL ACTION/MORTGAGE FORECLOSURE TO THE PROTHONOTARY: Kindly reinstate the Civil Action in Mortgage Foreclosure with reference to the above captioned matter. ~ Attorney for Plaintiff Date: February 24, 2000 '\ \ ,'. >,lf~ -'illIilli_.iJ"-"'M--""'->"~'V ",. - -, ~~ -..."""",~....~""",JJ.- . ~'" "iRE c ~ 0 3: :r- ==- ~! ::l:I m.::!l I II ~o '"'0 ~8 :x >c t.) ~ - ?& s::- .s;;- -< '".".' ,~, . " ,. ~-- ~""- '. - .- . ~ _ , , .,--, , '_'~"'_"" C _^ ..e.. ~ . "!j I I' I M ~_.~. . ," 1*J[l - ,,~=. ~~-,,~"' .~~ O~ - ~iIi' .: .r' SHERIFF'S RETURN - OUT OF COUNTY CASE NO: 2000-00232 P COMMONWEALTH OF PENNSYLVANIA: COUNTY OF CUMBERLAND GMAC MORTGAGE CORP OF PA VS MATTHEWS SCOTT A 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: MATTHEWS SCOTT A but was unable to locate Him in his bailiwick. He therefore deputized the sheriff of PERRY County, Pennsylvania, to serve the within COMPLAINT - MORT FORE On March 7th , 2000 , this office was in receipt of the attached return from PERRY Sheriff's Costs: Docketing 18.00 Out of County 9.00 Surcharge 10.00 DEP. PERRY CO 35.60 .00 72.60 03/07/2000 FEDERMAN & PHELAN ~~~ R. homa@ Kline Sheriff of Cumberland County Sworn and subscribed to before me this .1(~ day of ~ ~ A.D. ~ L .'-' a. ~d~'-J . ~ . Prothonotary - ,-, < In The Court of Common Pleas of Cumberland County, Pennsylvania GMAC Mortgage Corporation of PA VS. Scott A. Matthews,et. al. Serve, Scott A. Matthews No. 20-232 Civil Now, 3/2/00 , 20~, I, SHERIFF OF CUMBERLAND COUNTY, P A,do hereby deputize the Sheriff of Perry County to execute this Writ, this deputation being made at the request and risk of the Plaintiff. ~~~~t Sheriff of Cumberland County, P A Affidavit of Service >.,,,.,oj Now, March 4 , 20~, at 3: 35 o'clock P M. served the within Reinstated Notice & Complaint in Mortgage Foreclosure upon ScottA. Matthews his residence at & Spring Township, Perry County, Pa. by handing to Scott A. Matthews. Defendant and made known to . him copy of the originalNotice & Complaint in Mortgage Foreclosure the contents thereof. a true and attested S6 answers, vB~ DeputJ;heriffof Perry ~ . County, PA ,20~ COSTS SERVICE MlLEAGE AFFIDAVIT $ DEPUTY PROTHONOTARY & CLERK OF COURTS BLOOMFIELD BORO.~ PERRY CO.. PA MY COMMISSION EXPIRES JAN .5. 2004 $ ............~ .-_ Ii I < FEDERMAN AND PHELAN By: FRANK FEDERMAN Identification No. 12248 Two Penn Center Plaza - Suite 900 Philadelphia, PA 19102 (215) 563-7000 GMAC MORTGAGE CORPORATION OFPA 3451 HAMMOND AVENUE P.O. BOX 780 WATERLOO, IA 50704 Attorney for Plaintiff : CUMBERLAND COUNTY : COURT OF COMMON PLEAS : CML DMSION Plaintiff : NO. 2000-232-CML VS. SCOTT A. MATTHEWS RR 2 BOX 540 LANDISBURG, P A 17040 KIMBERLY D. MATTHEWS 3703 ENOLA ROAD NEWVILLE, P A 17241 Defendant(s) PRAECIPE FOR JUDGMENT FOR FAILURE TO ANSWER AND ASSESSMENT OF DAMAGES TO THE PROTHONOTARY: Kindly enter judgment in favor of the Plaintiff and against SCOTT A. MATTHEWS and KIMBERLY D. MATTHEWS, Defendant(s), for failure to file an Answer to Plaintiffs Complaint within 20 days from service thereof and for foreclosure and sale of the mortgaged premises, and assess Plaintiffs damages as follows: As set forth in Complaint Interest 11/1/99 to 4/7/00 TOTAL $111,293.90 $3.036.90 $114,330.80 I hereby certifY that (1) the addresses of the Plaintiff and Defendant(s) are as shown above, and (2) notice has been given in accordance with Rule 237.1, copy attached. 1- ~ -:ldJ/vVMAM/ FRANK FEDERMAN, ESQUIRE Attorney for Plaintiff DAMAGES ARE HEREBY ASSESSED AS INDICATED. /) ~ DATE: 411(') I/)o /<; / r...1L./f'77A.J 7). , f ' { PROPROT "TIllS FIRM IS A DEBT COLLECTOR ATIEMPTING TO COLLECT A DEBT AND ANY INFORMATION OBTAINED WILL BE USED FOR THAT PURPOSE. IF YOU HAVE PREVIOUSLY RECEIVED A DISCHARGE IN BANKRUPTCY AND THIS DEBT WAS NOT REAFFIRMED. THIS CORRESPONDENCE IS NOT AND SHOULD NOT BE CONSTRUED TO BE AN ATIEMPTTO COLLECT A DEBT, BUT ONLY ENFORCEMENT OF A LIEN AGAINST PROPERTY." ,- '-~,i FEDERMAN AND PHELAN 'Frank Federman, Esquire Identification No. 12248 Two Penn Center Plaza Suite 900 Philadelphia, PA 19102-1799 (215) 563-7000 .~. ~- ATTORNEY FOR PLAINTIFF GMAC MORTGAGE CORPORATION OF PA Plaintiff COURT OF COMMON PLEAS CIVIL DIVISION vs. CUMBERLAND COUNTY SCOTT A. MATTHEWS KIMBERLY D. MATTHEWS NO. 2000-232 CIVIL Defendant(s) TO: SCOTT A. MATTHEWS RR 2 BOX 540 LANDISBURG" FA 17040 DATE OF NOTICE: MARCH 27. 2000 THIS FIRM IS A DEBT COLLECTOR ATTEMPTING TO COLLECT A DEBT. ANY INFORMATION WE OBTAIN WILL BE USED FOR THAT PURPOSE. IF YOU HAVE PREVIOUSLY RECEIVED A DISCHARGE IN BANKRUPTCY, THIS CORRESPONDENCE IS NOT AND SHOULD NOT BE CONSTRUED TO BE AN ATTEMPT TO COLLECT A DEBT, BUT ONLY ENFORCEMENT OF A LIEN AGAINST PROPERTY. IMPORTANT NOTICE You are in default because you have failed enter a written appearance personally or by attorney and file in writing with the court your defenses or objections to the claims set forth against you. Unless you act wi thin ten (10) days from the date of this notice, a Judgment may be entered against you without a hearing and you may lose your property or other important rights. You should take this notice to a lawyer at once. If you do not have a lawyer or cannot afford one, go to or telephone the following office to find out where you can get legal help: CUMBERLAND COUNTY CUMBERLAND COUNTY BAR ASSOCIATION 2 LIBERTY AVENUE CARLISLE, PA 17013 (717) 249-3166 f'lE COr'l Frank Federman, Esquire Attorney for Plaintiff . ~= " .1 , =-~ , ~ '-,..-j FEDERMAN AND PHELAN Frank Federman, Esquire Identification No. 12248 Two Penn Center Plaza Suite 900 Philadelphia, PA 19102-1799 (215) 563-7000 -~ ATTORNEY FOR PLAINTIFF GMAC MORTGAGE CORPORATION OF PA Plaintiff COORT OF COMMON PLEAS CIVIL DIVISION vs. CUMBERLAND COUNTY SCOTT A. MATTHEWS KIMBERLY D. MATTHEWS NO. 2000-232 CIVIL Defendant TO: KIMBERLY D. MATTHEWS C/O THE GIANT FOOD, INC. 1400 HARRISBURG PIKE CARLISLE, PA 17013 DATE OF NOTICE: MARCH 27. 2000 THIS FIRM IS A DEBT COLLECTOR ATTEMPTING TO COLLECT A DEBT. THIS NOTICE IS SENT TO YOU IN AN ATTEMPT TO COLLECT THE INDEBTEDNESS REFERRED TO HEREIN, AND ANY INFORMATION OBTAINED FROM YOU WILL BE USED FOR THAT PURPOSE.IF YOU HAVE PREVIOUSLY RECEIVED A DISCHARGE IN BANKRUPTCY, THIS CORRESPONDENCE IS NOT AND SHOULD NOT BE CONSTRUED TO BE AN ATTEMPT TO COLLECT A DEBT, BUT ONLY AS ENFORCEMENT OF LIEN AGAINST PROPERTY. IMPORTANT NOTICE You are in default because you have failed enter a written appearance personally or by attorney and file in writing with the court your defenses or objections to the claims set forth against you. Unless you act within ten (10) days from the date of this notice, a Judgment may be entered against you without a hearing and you may lose your property or other important rights. You should take this notice to a lawyer at once. If you do not have a lawyer or cannot afford one, go to or telephone the following office to find out where you can get legal help: CUMBERLAND COUNTY CUMBERLAND COUNTY BAR ASSOCIA nON 2 LIBERTY AVENUE CARLISLE, PA 17013 (717) 249-3166 FILE COpy Frank Federman, Esquire Attorney for Plaintiff ...---- ,I '" FEDERMAN AND PHELAN ~rank Federman, Esquire Identification No. 12248 Two Penn Center Plaza Suite 900 Philadelphia, PA 19102-1799 (215...L. 563-70~0 GMAC MORTGAGE CORPORATION OF PA Plaintiff ATTORNEY FOR PLAINTIFF COURT OF COMMON PLEAS CIVIL DIVISION vs. CUMBERLAND COUNTY SCOTT A. MATTHEWS KIMBERLY D. MATTHEWS NO. 2000-232-CIVIL Defendant TO: KIMBERLY D. MATTHEWS 3703 ENoLA ROAD NEWVILLE, PA 17241 FILE Copy - DATE OF NOTICE: MARCH 27. 2000 THIS FIRM IS A DEBT COLLECTOR ATTEMPTING TO COLLECT A DEBT. THIS NOTICE IS SENT TO YOU IN AN ATTEMPT TO COLLECT THE INDEBTEDNESS REFERRED TO HEREIN, AND ANY INFORMATION OBTAINED FROM yOU WILL BE USED FOR THAT PURPOSE.IF YOU HAVE PREVIOUSLY RECEIVED A DISCHARGE IN BANKRUPTCY, THIS CORRESPONDENCE IS NOT AND SHOULD NOT BE CONSTRUED TO BE AN ATTEMPT TO COLLECT A DEBT, BUT ONLY AS ENFORCEMENT OF LIEN AGAINST PROPERTY. IMPORTANT NOTICE You are in default because you have failed enter a written appearance personally or by attorney and file in writing with the court your defenses or objections to the claims set forth against you. Unless you act within ten (10) days from the date of this notice, a Judgment may be entered against you without a hearing and you may lose your property or other important rights. You should take this notice to a lawyer at once. If you do not have a lawyer or cannot afford one, go to or telephone the following office to find out where you can get legal help: CUMBERLAND COUNTY CUMBERLAND COUNTY BAR ASSOCIATION 2 LIBERTY AVENUE CARLISLE, PA 17013 (717) 249-3] 66 Frank Federman, Esquire Attorney for Plaintiff -- " " _.~ _- I ~=j FEDERMAN AND PHELAN Frank Federman, Esquire Identification No. 12248 Two Penn Center Plaza Suite 900 Philadelphia, PA 19102-1799 (215J... 5 63-: 7000 GMAC MORTGAGE CORPORATION OF PA Plaintiff ATTORNEY FOR PLAINTIFF COURT OF COMMON PLEAS CIVIL DIVISION vs. CUMBERLAND COUNTY SCOTT A. MATTHEWS KIMBERLY D. MATTHEWS NO. 2000-232-CIVIL Defendant TO: KIMBERLY D. MATTHEWS 45 MARE ROAD CARLISLE, PA 17013 DATE OF NOTICE: MARCH 27, 2000 THIS FIRM IS A DEBT COLLECTOR ATTEMPTING TO COLLECT A DEBT. THIS NOTICE IS SENT TO YOU IN AN ATTEMPT TO COLLECT THE INDEBTEDNESS REFERRED TO HEREIN, AND ANY INFORMATION OBTAINED FROM YOU WILL BE USED FOR THAT PURPOSE.IF YOU HAVE PREVIOUSLY RECEIVED A DISCHARGE IN BANKRUPTCY, THIS CORRESPONDENCE IS NOT AND SHOULD NOT BE CONSTRUED TO BE AN ATTEMPT TO COLLECT A DEBT, BUT ONLY AS ENFORCEMENT OF LIEN AGAINST PROPERTY. FILE COpy IMPORTANT NOTICE You are in default because you have failed enter a written appearance personally or by attorney and file in writing with the court your defenses or objections to the claims set forth against you. Unless you act wi thin ten (10) days from the date of this notice, a Judgment may be entered against you without a hearing and you may lose your property or other important rights. You should take this notice to a lawyer at once. If you do not have a lawyer or cannot afford one, go to or telephone the following office to find out where you can get legal help: CUMBERLAND COUNTY CUMBERLAND COUNTY BAR ASSOCIATION 2 LIBERTY AVENUE CARLISLE, PA 17013 (717) 249-3166 Frank Federman, Esquire Attorney for Plaintiff ,"' - ..~": FEDERMAN and PHELAN By: FRANKFEDERMAN Identification No. 12248 Suite 900 Two Penn Center Plaza Philadelphia, P A 19102 (215) 563-7000 Attorney for Plaintiff GMAC MORTGAGE CORPORATION OFPA : CUMBERLAND COUNTY Plaintiff : Court of Common Pleas vs. : CIVIL DIVISION SCOTT A. MATTHEWS KIMBERLY D. MATTHEWS Defendant(s) : NO. 2000-232-CIVIL VERIFICATION OF NON-MILITARY SERVICE FRANK FEDERMAN, ESQUIRE, hereby verifies that he is attorney for the Plaintiff in the above-captioned matter, and that on information and belief, he has knowledge of the following facts, to wit: (a) that the defendant(s) is/are not in the Military or Naval Service of the United States or its Allies, or otherwise within the provisions of the Soldiers' and Sailors' Civil Relief Act of Congress of 1940, as amended (b) that defendant SCOTT A. MATTHEWS is over 18 years of age and resides at RR 2 BOX 540, LANDISBURG, P A 17040. (c) that defendant KIMBERLY D. MATTHEWS is over 18 years of age, and resides at 3703 ENOLA ROAD, NEWVILLE, P A 17241. This statement is made subject to the penalties of 18 Pa. C.S. Section 4904 relating to unsworn falsification to authorities. ::; /&M1Jf..I ~ .e,1i A /I/I/i A/YL FRANK FEDERMAN Attorney for Plaintiff , , . , ". ~ , (Rule of Civil Procedure No. 236 - Revised) GMAC MORTGAGE CORPORATION OFPA : CUMBERLAND COUNTY : Court of Common Pleas Plaintiff : CIVIL DIVISION vs. : NO. 2000-232-CIVIL SCOTT A. MATTHEWS KIMBERLY D. MATTHEWS Defendant(s) Notice is given that a Judgment in the above captioned matter has been entered against you on APRIL ID .2000. ~ A.O/lo>" 2. ~~.J])EPUTY 4 If you have any questions concerning this matter, please contact: FRANK FEDERMAN, ESOUIRE Attorney for Filing Party SUITE 900 TWO PENN CENTER PLAZA PHILADELPHIA. PA 19102 (215) 563-7000 **TIDS FIRM IS A DEBT COLLECTOR ATTEMPTING TO COLLECT A DEBT AND ANY INFORMATION OBTAINED WILL BE USED FOR THAT PURPOSE. IF YOU HAVE PREVIOUSLY RECEIVED A DISCHARGE IN BANKRUPTCY AND TIllS DEBT WAS NOT REAFFIRMED, THIS IS NOT AND SHOULD NOT BE CONSTRUED TO BE AN ATTEMPT TO COLLECT A DEBT, BUT ONLY ENFORCEMENT OF A LIEN AGAINST PROPERTY. ** li!liilrMl"'-~-' ,-,L=....~_""L "'1IIillIIII ,~ -.Ii;[ -'~"'~.fi<'"_>lmll!1l&Ml!I-.r..i ..,- .~ ,,"'," '" ., ~ ' ''', '...- , , t 1i. ~ ~ 0 0 C) C C) 7' "Tl 8 l:Jt~ "'" -.--< rnrr -0 Z:::.~ ;0 " ~ ~~, 0~ -,"'fTl -0 F! C C:J ~ I ~c- >_::() ~ R )" :co.. zc) =1':;: ~;~(i5 f' 5>Ci ~ C (51"n - ..... Z :;_4 ~ - - --1 ,'0 -> -< ..... ;':J -< '--'..... , - I t _,; FEDERMAN AND PHELAN By: FRANK FEDERMAN, ESQUIRE IDENTIFICATION NO. 12248 TWO PENN CENTER PLAZA, SUITE 900 PHILADELPHIA, PA 19102 (215) 563-7000 GMAC MORTGAGE CORPORATION OF PA 3451 HAMMOND AVENUE P.O. BOX 780 WATERLOO, IA 50704 ATTORNEY FOR PLAINTIFF COURT OF COMMON PLEAS CIVIL DIVISION TERM Plaintiff V. NO. c:XQD 'd~ c:a;J CUMBERLAND COUNTY SCOTT A. MATTHEWS KIMBERLY D. MATTHEWS 3703 ENOLA ROAD NEWVILLE, P A 17241 Defendant( s) CIVIL ACTION - LAW MORTGAGE FORECLOSURE NOTICE PLEASE BE ADVISED THAT THIS FIRM IS A DEBT COLLECTOR ATTEMPTING TO COLLECT A DEBT. ANY INFORMATION RECEIVED WILL BE USED FOR THAT PURPOSE. IF YOU HAVE PREV!OUSL Y RECEIVED A DISCHARGE IN BANKRUPTCY AND THIS DEBT WAS NOT REAFFIRMED, THIS CORRESPONDENCE IS NOT AND SHOULD NOT BE CONSTRUED TO BE AN ATTEMPT TO COLLECT A DEBT BUT ONLY ENFORCEMENT OF A LIEN AGAINST PROPERTY. You have been sued in Court. If you wish to defend against the claims set forth in the following pages, you must take action within twenty (20) days after this Complaint and Notice are served, by entering a written appearance personally or by attorney and filing in writing with the court your defenses or objections to the claims set forth against you. You are warned that if you fail to do so the case may proceed without you and a judgment may be entered against you by the court without further notice for any money claimed in the Complaint or for any other claim or relief requested by the Plaintiff. You may lose money or property or other rights important to you. YOU SHOULD TAKE THIS PAPER TO YOUR LAWYER AT ONCE. IF YOU DO NOT HAVE A LAWYER OR CANNOT AFFORD ONE, GO TO OR TELEPHONE THE OFFICE SET FORTH BELOW TO FIND OUT WHERE YOU CAN GET LEGAL HELP. CUMBERLAND COUNTY CUMBERLAND COUNTY BAR ASSOCIATION 2 LIBERTY AVENUE CARLISLE,PA 17013 (717) 249-3166 Loan #0 220870133 "~ .~'- -""~: 1. Plaintiff is GMAC MORTGAGE CORPORATION OF PA 3451 HAMMOND AVENUE P.O. BOX 780 WATERLOO, IA 50704 2. The narne(s) and last known addressees) of the Defendant(s) are: SCOTT A. MATTHEWS KIMBERLY D. MATTHEWS 3703 ENOLA ROAD NEWVILLE, P A 17241 who is/are the mortgagor(s) snd real owner(s) of the property hereinafter described. 3. On 6/23/93 mortgagor(s) made, executed and delivered a mortgage upon the premises hereinafter described to PLAINTIFF which mortgage is recorded in the Office of the Recorder of CUMBERLAND County, in Mortgage Book No. 1144, Page 720. 4. The premises subject to said mortgage is described as attached. 5. The mortgage is in default because monthly payments of principal and interest upon said mortgage due 5/1/99 and each month thereafter are due and unpaid, and by the terms of said mortgage, upon failure of mortgagor to make such payments after a date specified by written notice sent to Mortgagor, the entire principal balance and all interest due thereon are collectible forthwith. A copy of such notice is attached as Exhibit "A." - ." ""'""""",: 6. The following amounts are due on the mortgage: Principal Balance Interest 4/1/99 through 11/1/99 (Per Diem $19.10) Attorney's Fees Cumulative Late Charges 6/23/93 to 11/1/99 Cost of Suit and Title Search Subtotal $101,386.41 4,087.40 5,069.00 430.56 550.00 111,523.37 Escrow Credit Deficit Subtotal 229.47 0.00 229.47 TOTAL $111,293.90 7. The attorney's fees set forth above are in conformity with the Mortgage documents and Pennsylvania Law, and will be collected in the event of a third party purchaser at Sheriff's Sale. If the Mortgage is reinstated prior to the Sale, reasonable attorney's fees will be charged. 8. This action does not corne under Act 6 of 1974 because the original mortgage amount exceeds $50,000. 9. 1bis action does not corne under Act 91 of 1983 because the mortgaged premises is not the principal residence of the Defendant(s). 10. Pursuant to the Fair Debt Collection Practices Act, 15 U.S.c. 9 1692 et seq. (1977), Defendant(s) may dispute the validity of the debt or any portion thereof. IfDefendant(s) do so in writing within thirty (30) days of receipt of this pleading, Counsel for Plaintiff will obtain and provide Defendant(s) with written verification thereof; otherwise, the debt will be assumed to be valid. Likewise, if requested within thirty (30) days of receipt of this pleading, Counsel for Plaintiff will send Defendant(s) the name and address of the original creditor if different from above. WHEREFORE, PLAINTIFF demands an in rem Judgment against the Defendant(s) in the sum of $ 111,293.90, together with interest from 11/1/99 at the rate of$19.10 per diem to the date of Judgment, and other costs and charges collectible under the mortgage and for the foreclosure and sale of the mortgaged property. ~,r~ /s/ Frank Federman FRANK FEDERMAN, ESQUIRE Attorney for Plaintiff - GMAC Mortgage Corporation P.O. Box 8507f San Diego, CA 92186-5071 3451 Hammond Ave P.O. Box 780 Waterloo, IA 50704.0780 NOTICE OF INTENTION TO FORECLOSE AND ACCELERATE DATE: JUly 7, 1999 Servicing CERTIFIED MAIL NO. Z 472890838 TO: SCOTT A MATTHEWS 3703 ENOLA RD NEWVILLE PA 17241 LOoMAc Mortgage RE: MORTGAGE LOAN NUMBER: MORTGAGED PREMISES: 220870133 45 MARE ROAD CARLISLE, PA 17013-9514 This company is the holder of the FIRST MORTGAGE (AND NOTE) on the above premises, or is the mortgage service agent for such holder. (Hereinafter referred to as we, us or ours) . As of the date of this notice, THE MORTGAGE IS IN SERIOUS DEFAULT because yoU have not made the May 1, 199.9 and subsequent monthly payments as listed, and/o~ for other reasons as indicated below: * 3 payments @ $857.63 $2,572.B9 Accrued late charges..... ...... ...... ..... ... .....$287.04 NSF Check Fees..................................... .$0.00 All othe:t fees accrued to date...................... $0.00 , Less available suspense credits................... .$0.00 The total amount now required to cure this default, or in other words, get caught up in your payments as of the date of this lette:t is................................... .$2,859.93 You may cure this default within THIRTY (30) DAYS of the date of this letter, by paying to us the above amount, plus any additional monthly payments and late charges which may fall due during this period. Such payment must oe made either by cash, cashier's check, certified check or mbi~';')TderT and made at, or sent to: 3451 Hanunond Avenue,- P.O. ~'-'Box 780, Waterloo, IA 50704-0780. If you do not cure the default within THIRTY (30) DAYS, we intend to exercise our ~ight to accelerate the mortgage payments. This means that whatever is OWing on the original amount borrowed will be considered due immediately and you may lose the chance to payoff the original mortgage in monthly installments. If full payment of the amount of default is not made within THIRTY (30) DAYS, we also intend to instruct our attorneys to start a lawsuit to foreclose your mortgaged property. If the mortgage is foreclosed your mortgaged property will be sold by the Sheriff to pay DMS5-BRCHPAC (Page 1 of 2) EXHIBiT A ," -' "c.... .~. GMAC Mortgage Corporation P.O. Box 65071 San Diego, CA 92186-5071 3451 Hammond Ave P.O. Box 780 Waterloo, IA 50704-0780 NOTICE OF INTENTION TO FORECLOSE AND ACCELERATE DATE: JUly 7, 1999 Servicing LOoMAc Mortgage CERTIFIED MAIL NO. Z 472890839 TO: SCOTT A ~TTHEWS 45 ~RE ROAD CARLISLE PA 17013-9514 RE: MORTGAGE LOAN NUMBER: MORTGAGED PREMISES: 220870133 45 ~RE ROAD CARLISLE, PA 17013-9514 This company is the holder of the FIRST MORTGAGE (AND NOTE) on the above premises, or is the mortgage service agent for such holder. (Hereinafter referred to as we, us or ours) . As of the date of this notice, THE MORTGAGE IS IN SERIOUS DEFAULT because you have not made the May 1, 1999 and subsequent monthly payments as listed, and/or for other reasons as indicated below: * 3 payments @ $857.63 $2,572.B9 Accrued late charges.. .... .... ... ... .... ..... .....$287.04 NSF Check Fees..................................... .$0.00 All other fees accrued to date... ...... ..... ........$0.00 * Less available suspense credits................... .$0.00 The total amount now required to cure this default, or in other words, get caught up in your payments as of the date of this letter is................................... .$2,859.93 You may cure this default within THIRTY (30) DAYS of the date of this letter, by paying to us the above amount, plus any additional monthly payments and late charges which may fall due during this period. Such payment must be made either by cash, cashier's check, certified check or m~~~I>.;>;-~de~, and made at, or sent to: 3451 Hammond Avenue,-'P.O. --B-9x 780, Waterloo, IA 50704-0780. If you do not cure the default within THIRTY (30) DAYS, we intend to exercise our right to accelerate the mortgage payments. This means that whatever is owing on the original amount borrowed will be considered due immediately and you may lose the chance to payoff the original mortgage in monthly installments. If full payment of the amount of default is not made within THIRTY (30) DAYS, we also intend to instruct our attorneys to start a lawsuit to foreclose your mortgaged property. If the mortgage is foreclosed your mortgaged property will be sold by the Sheriff to pay DMS5-BRCHPAC (Page 1 of 2) EXHIBIT A -- ~. - v', --". ". GMJlC Mortgage Corporalion P.O. Box B507f San Diego, OA 92188-5071 3451 Hammond Ave P.O. Box 7BO Waterloo, IA 50704-0780 NOTlcE OF INTENTION TO FORECLOSE AND ACCELERATE DATE: July 19, 1999 ServIcing LOoMAc Mortgage CERTIFIED ~IL NO. Z TO: RIMSERLY D. ~TTHEWS 3703 ENOLA RD NEWVILLE, PA 17241 RE: MORTGAGE LOAN NUMBER: MORTGAGED PREMISES: 220870133 45 ~RE ROAD CARLISLE, PA 17013-9514 This company i~ the holder of the FIRST MORTGAGE (AND NOTE) on thc above premises, or is the mortqaqe service aqent for such holder. (Hereinafter referred eo as we, us or ours) . A~ of the date of this notice, THE MORTGAGE IS IN SERIOUS DEFAULT beeau~e YOU have not made the May 1, 1999 and subsequent monthly payments as listed, and/or for ocher reasons as indica~ed below: * 3 payments 0 $B57.63 $2,572.89 Accrued late oharges.. . . . . . . . . . . . .. . ... .... . . . . . . . $322.92 NilI' Check Fees.................................... ..$0.00 All other fees acorued to date........... .. . .. .. . .. . $0.00 * Less available suspense credics ......... ...........$0.00 The total amount now required co cure this default, or. in other words, gee caught up in your payments as of the date of this letter is......".... . . . . . . . . . . . . . . . . . . . . . . . . . $2,895. B1 You may cure this default within THIRTY (30) DAYS of the date of chis lecter, by paying to Us che above amounc, plUS any additional monthly payments And late charges whioh may fall due during this period. Such paymerlt must be ma.de either by cash. eash:i.er's cheek, c6;t't.ificd che.ck O;J:" money order, a.nd made at, or Sent. co: 3451 Rammonc. Avenue, .r-.O. Bo~_ 7aOl waEe-:::~<':"I~'.-:;:A--S0704 - 0780. If you do noc cure the defaulc within THIRTY (30) DAYS, we intend to exercise our riqht to Aocelerate the mortgage payments. This means chat whaeever is owinq on the ori~inal amount borrowed will be considered Que irnmediacely and you may lose the ohance to payoff the oriqinal morc~age in monchly installmentS. If full payment of the amount of defaule is not made within THIRTY (30) DAYS, We also intend to inscruct our attorneys to start a lawsuit to foreclose your mort~aged property. If the mortgage is foreclosed your mortgaged property will be sold by the Sheriff to pay DMSo"BRCHPA (Page 1 of 2) 1:00 lEi JVI'(:) ~H9 6C1: n1:.2. EXH\B\T A GC:S, 66/,1:/1:, ...-~ ~~ I GMAC Mor\!I!Ige Corporation P.O. Box B507f San Diego, CA 92186-5071 3451 Hammond Ave P.O. Box 760 Waterloo, IA 50704-0760 NOTICE OF INTENTION TO FORECLOSE AND ACCELERATE DATE: July 19, 1999 Servioing WoMAc Mortgage CERTIfIED ~IL NO. Z TO: KIMBERLY D. ~TTHEWS 45 ~RE ROAD CARI8LE, PA 17013'9514 RE : l'lORTGAGE LOAN NUMBER: l'lORTGAGED PREMISES: 220B70133 45 MARt. ROAD CARLISLE, PA 17013-9514 This company is the holder of che FIRST MORTGAGE (AND NOTE) on the abovc premi~es, or is the morc94ge service ~gent for such holaer. (Hereinafter refer~ed to as we! us or ours) . As of the dace of chis notioe, THE MORTGAGE IS IN SERIOUS DEFAULT because YOU haVe noc made the May 1, 1999 and subsequent monthly payments as listed, and/or for othe~ reasons as indicated below:' 3 payments @ $857.63 $2,572.89 Accrued late cha~ges...................... ....... .$322.92 N8F Cheok Fees..................................... .$0.00 ,>.11 other fees accrued to date.... .......... .. . .. ... $0.00 * ~ess available suspense credits ........ ..... ..... ..$0.00 The total amount now required to cure chis default, o~ in other words, get caUght up in your pa~nents as of the dace of this letter is.................................... $2,895.81 Y~U may cure this default within THIRTY (30) DAYS of the dace of this letter, by paying to us the above amount, plus any additional monthly payments and late charges which may fall due during chis period. Such payment must be made either by cash, cashier's check, certified check or money order, and made at, or sent to: 3451 Ralrunond Avenue, ~.O. Box 780, W.J.te:'--;~'9; --!.7la__5.07 04.07 eo. -- If you do not cure the default wi chin THIRTY (30) DAYS, we intend co exercise our riqht to acoelerate the mortgage payments. ~~is means that whatever is owing on che original amount borrowed will be considered ciue imme<lia~ely and you may lose the chance to payoff che oriqinal mortgage in monthly illstallments. If full payment of che amOUnC ot default is not Made within THIRTY (30) DAYS, we also intend to ingtruct our attorneys to start a lawsuic to foreclose your mortqaqed property. Ir the mortgage is foreclosed your mortqage<l property will be sold ~y the Sheriff to pay DMS5-BRCllPA (paqe 1 EXH\B\T A ;;00 I2J JVl'l~ SH9 6ez nz.Q, H:Sl 66/H/Zl -""""",, ~ - "'< ''"- ., ~~"'.> July 19, 1999 Paqc 2 220870133 off the debt. If we refer your cas@ eo our attorneys. but you cure the defaul~ be~ore they begin legal prooeedings against you, you will still have to pay the reasonable attorney's fees, actually incurredl up ~o $50.00. However, if leqal prooeed~nqs are started aqainst you, you ~ill have to pay the rea.sonable attoX'ney's fees eVen if they are over ~50.00. ),ny attor'ne~?, s :fees will be added. to whatever you owe us, which may a1 so include our re~sonable costs. I~ you oure the default wi~hin the thirty day period, you will not be required to pay atcorney'S fees. Remember you ~re also responsible for keeping all real Cscate taxes c\\rrent. we may also s~a yoU ~ersonally for the unpaid balance and all other sums due under the mortgage. If you have not cured ~he default within the thirty day periOd and foreclosure proceedings have beg-un, you still havc the right to dure the default and prevent the sale at any time UP to one hour before, the Sheriff's foreclosure sale. YoU may do so by pa.ying' the total amount of the unpaid monthly payments plus any late or other charges then ducl as well as the reasonable actorney's fec~ and costs connected with the foreclosure sale (ana perform any ~ther requirements under the mortqaqe). It is estimatad thac the ear.liest date that such a Sheriff's sale could be held woula be approximately one-hundrea ana fifty (150) days from the date of this letter. A notice of the d~te of the sheriff's sale will be sent to yoU before the sale_ Of course, the amount needed to cure the aefault will increase the longer you wait. YoU may find out at any time exactly what the required payment will be by oal1ing us at tbe following number: 1-800-850-462.. The payment must be in cash, cashier's check, cercified check or money order and made payable to us ac the address previouslY stated. You should realize that a Sberif~'s sale will end your ownership of the mortqaged property and your riqht to remain in it. If you continue to live in the property afcer the Sheriff's sale, a lawsuit could be started to evict you. NOTI;:':'~""("'. "Tld's-- is an attempt to collect a debt and any informat.ion obcained will be used for that purpose. You have additional rights to help protecc your interest in the property. YOU ~VE TH~ RIGHT TO SELL THE PROPERTY TO OBTAIN MONEY TO PAY OFF THE MORTGAGE D~BT, OR TO BORROW MONEY FROM ANOTHER LENDING INSTITUTION TO ~~Y OFF THIS DEBT. YOU MAY HAVE TilE RIGHT TO SEtlL OR 'I'RANSP'ER THE PROPERTY SUBJECT TO THE MORTGAGE TO A BUYER OR TRANSFEREE WHO WILL ASSUME THE MORTGAGE DEBT, PROVIDED THAT T>.LL OUTSTANDING PAYMENTS, CRAAGES AND ATTORNEY'S FEES AND COSTS ME PAID PRIOR TO OR AT THE SALE, (AND TIIAT TIlE: OTll:ER REQllIREME:NTS llNl:>ER THE MORTGAGE ARE SATISFIED). CONTACT US TO DE1'ERMINE UNDER IfflAT CIRCUMSTANCES TilE RIGHT ~Y EXIS1'. YOU HAVE THE RIGHT TO HAVE THIS DEF~ULT CURED BY ~NY THIRD PARTY ACTING ON YOUR BEIlALF. If you cure the default, the mortgaqe will be r~secred co the same position as if no default had occurred. However I you are not entieled to this right to cure your default more than three time~ in any calendar year. DMS5-BRCH1?A (page 2 of 2) E)(H\B\T A ',00 IEJ JVN~ SH9 BCZ nz.s OC:n 'B6/1'ZIZ1 "-......... ~-."", , :'.'~I-("" ", t.l\.~. .',"'; ALL THAT CERTAIN trac1:. of ].and in ~o",:er Frank:fol:'d TownShf::'"..l~'::" ri~ cumberland County, Pe.nnsy1.vania, contci.J.n1ng' 1.G. 892 aores r be c;.n :~ the northern most part of the farm now or fo~er1y of Nelson f.~ ~ Shughart, and Ruth E. S;huqhart:., his wife, which farm is .In Ef""" . ~ part.icul.arly located as being in the Northeast:. corner :5:;:. ~ Leqislative Route No. 21001, known as Traffic Route No_ 994 ~~ ~ Tovn$hip Road No. 4.92, i:he 'tract:. here.by conveyod being m9lfej'iiiilll'~1 )?OirtiouJ.a.rJ.y bouJ"Idad and described as foJ.J.ows: Ill. . I. BEGINNING a'C an iron pin on a line of land now or formerly of c.c. Le:idigh and ~and noW' or forn\eJ;"~Y of' EU':;jene C. Morrison, North 72 degrees 57 minutes 48 seQQnds.East 1029.S2,a fee.t to a stone pile; thence South 2:1. degrees 42 minutes 11 seconas East 495.76 :f'eet to an iron pin and. stone. pile.; t.hence South 22 degrees 4~ winutes 53 seconds E8S~ 397.75 feet to an iron pin; thence South 75 deqraBS 22 minutes 50 seconds West 64i.6S feet to an iron pin; thence. North ';'5 dSg':rees 30 minutes 37 seoonds West 981.G02 rest ~o the ~1ace of beginnihg. ( CONTAINING 16.682 acres, mQre or ~ess_ BEING ~he same. ~remises ~hat Wa1ter E. Morrison and Gera~din9 L. Morrison, husbQnd and wi~e, by thair aeed date.d ~he 28th day of ( I l PREMISES: 45 MARE ROAD ~-<~~~ ~. llIIIillIW- - '. - .~~~ -'I , - \, \ . \ i \ " ; VERIFICATION FRANK FEDERMAN, ESQUIRE hereby states that he is attorney for Plaintiff in this matter, that he is authorized to take this Verification, and that the statements made in the ) foregoing civil Action in Mortgage Foreclosure are true and correct to the best of his knowledge, information and belief. The undersigned understands that this statement is made subject to the penalties of 18 Pa. C.S. Sec. 4904 relating to unsworn falsification to authorities. ~:r~ DATE: -l~ 1 ~o 0 \~, /.- - '~ FEDERMAN AND PHELAN By: FRANK FEDERMAN, ESQUIRE IDENTIFICATION NO. 12248 TWO PENN CENTER PLAZA, SUITE 900 PHILADELPHIA, PA 19102 (215) 563-7000 GMAC MORTGAGE CORPORATION OF PA ATTORNEY FOR PLAINTIFF COURT OF COMMON PLEAS CIVIL DIVISION v. NO.2000-232 CIVIL SCOTT A.MATTHEWS KIMBERLY D. MATTHEWS CUMBERLAND COUNTY AFFIDAVIT OF SERVICE OF NOTICE OF SHERIFF'S SALE PURSUANT TO P.R.C.P., 404(2)/403 FRANK FEDERMAN, ESQUIRE, Attorney for Plaintiff, hereby certifies that service of the Notice of Sheriff's Sale was made by sending a true and correct copy by certified mail to Defendant, KIMBERLY D. MATTHEWS at 3703 ENOLA ROAD NEWVILLE, PA 17241 which notice of Sheriff's Sale was received by Defendant, KIMBERLY D. MATTHEWS on MAY 19, 2000 as evidenced by the attached return receipt. The undersigned understands that this statement is made subject to the penalties of 18 PA C.S. s 4904 relating to unsworn falsification to authorities. ~~DE IRE JUNE 5, 2000 .1 .' .... ~ ___.......,.7 SENDER: . Check box at right if you require Restricted Delivery. . Print yolJr name and address on the reverse of this form so that we can return this card to you. . Attach this form to the front of the mailpiece, or on the back. if space does not permit. . The Return Receipt win show to whom the article was dellverad and the date delivered. I also wish to receive the following services (for an extra fee): A Restricted Delivery Consult postmaster for fee. 4a Article Number 3. A?icl&.Addressed to: . .' . ,.<.'-' : "lU.."'tDIUu.Y J). 1".AriJm..tS . 1.' J"'''3 ""^,.. ,,,,..,, ,.. {',l ;}~+..rr;:-1':7;!1 P 973 738 509 4b. Service Type )( CERTIFIED ~y '.- .-," 7. Date of Delivery ~-Iq-o I) 8. Addressee's Address Domestic Return Receipt P~,FO M381~ecember 1994,.. 11,:. J.I.~~: ,'.1 ..;, . ..!l! J I . ~ i .. , t"- v ! \i: , ~ - . .lltL.1 mllr'" ~"~'lIIlllil__ /i,' ." +:,:~J ,;~ol"l[~. J~~lr~,-.<,F;~ . "'~~i'I1ilIiiIIIlii,,/J "'.'1 -~ ~c -". ~"'~, -, - '. .- .~ '. l (') 0 0 C 0 " :;: S= --1 -Ow :.1:" rnr'f"i .~ illF Z~n I m~::tm Zr;;,~ '.0 '~G9 Ci1.~ j;JC> -<.-::.- f2CJ .{ --u r,i J.>C; :x i25;Q ~O ..~-~.... "" ~ Orn c: ~ Z G) -:J -.. C1\ -< Ii? -- f , GMAC Mortgage Corporation ofPA -vs- Scott A. Matthews and Kimberly D. Matthews IlH; In the Court of Common Pleas of Cumberland County, Pennsylvania No. 2000-232 Civil R. Thomas Kline, Sheriff, who being duly sworn according to law says this writ, is returned Stayed. Sheriffs Costs: Docketing Poundage Mileage Levy Surcharge Law Library County Postpone Sale Out of County Sworn and Subscribed To Before Me . tv G~>' This .2 7-, Day 0 'fr-i c . i:i-:1;,~_ 2000,A.D.pro~ I). Yh/ii'l# Pro 0 otary 30.00 2,340.66 4.96 15.00 30.00 .50 1.00 20.00 --2"QQ $ 2,451.12 Pd By Arty 7/24/00 So~w~ ~~ ~~-r~ <'.R R. Thomas Kline, Sheriff ByjZt;u4:~ Real Estate Deputy 9 \,&0 CI<... J 'id- 'W f2u-. '191)7 ....-.... I ~ " . "" ! r GMAC Mortgage Corporation ofPA CUMBERLAND COUNTY Plaintiff, v. COURT OF COMMON PLEAS Scott A. Matthews Kimberly D. Mattbews CIVIL DIVISION NO. 2000-232 CIVIL Defendant(s). AFFIDA VII PURSUANT TO RULE 3129 (Affidavit No. I) GMAC Mortl!:al!:e Corooration ofPA, Plaintiff in the above action, by its attorney, FRANK FEDERMAN, ESQUIRE, sets forth as of the date the Praecipe for the Writ of Execution was filed the following information concerning the real property located at 45 Mare Road. Carlisle. P A 17013. 1. Name and address ofOwner(s) or reputed Owner(s): NAME LAST KNOWN ADDRESS (If address cannot be reasonably ascertained, please so indicate.) Scott A. Matthews RR 2, Box 540 Landisburg, P A 17040 Kimberly D. Matthews 3703 Enola Road Newville, PA 17241 2. Name and address ofDefendant(s) in the judgment: NAME LAST KNOWN ADDRESS (If address cannot be reasonably ascertained, please so indicate.) Same as above 3. Name and address of every judgment creditor whose judgment is a record lien on the real property to be sold: NAME LAST KNOWN ADDRESS (If address cannot be reasonably ascertained, please so indicate.) Household Realty Corp. 961 Weigel Drive Elmhurst, IL 60126 .il\\i~_!~~i_~-'--j'JiVm'.tiiIlll~IlillIi~Ul~ ~I.~" ~- '~~--)j lW__ Jill ._ -:o._",,>.i~. .. ,'~,- >. .. .d' ~- -~ .... \ , ... 4. Name and address of the last recorded holder of every mortgage of record: NAME LAST KNOWN ADDRESS (If address cannot be reasonably ascertained, please so indicate.) GMAC Mortgage Corporation of America 1301 Office Center Drive Suite 200 Fort Washington, PA 19117 Household Realty Corporation 25 Gateway Drive Suite 107 Mechanicsburg, P A 17055 5. Name and address of every other person who has any record lien on the property: NAME LAST KNOWN ADDRESS (If address cannot be reasonably ascertained, please so indicate.) None 6. Name and address of every other person who has any record interest in the property and whose interest may be affected by the sale: NAME LAST KNOWN ADDRESS (If address cannot be reasonably ascertained, please so indicate.) None 7. Name and address of every other person whom the plaintiff has knowledge who has any interest in the property, which may be affected by the sale: NAME LAST KNOWN ADDRESS (If address cannot be reasonably ascertained, please so indicate.) Tenant/Occupant 45 Mare Road Carlisle, PA 17013 Domestic Relations of Cumberland County 13 North Hanover Street Carlisle, P A 17013 I verify that the statements made in this affidavit are true and correct to the best of my personal knowledge or information and belief. I understand that false statements herein are made subject to the penalties of 18 Pa. C.S. Sec. 4904 relating to ]ll1swom falsification to authorities. May 8. 2000 DATE F FED Attorney for PI' Iff ~ " ti -~,: !-v-.. ~',"';- ":+\LF~': G'~r1<-),'..}' ,..: " -Q;\~>H - ~ ~\M II p~\<., :; " " .~ 1l'Ill'9&! '<i1\i.8'I!fli' ",,,,~I.*~ ": ,,"'.,F',' 3 53 -;\ ';f~\) l__ l_ i'L'j ~\-l, \;\ .0 .'. r. ,,~~. ~~~8-~~~1 -,-,.~_.~~,~II!I!M.I'." ""~~ - - ,".".d.:;"", .- \. GMAC Mortgage Corporation of P A Plaintiff, CUMBERLAND COUNTY v. No. 2000-232 CIVIL Scott A. Matthews Kimberly D. Matthews Defendant(s). May 8, 2000 TO: Scott A. Matthews RR 2, Box 540 Landisburg, P A 17040 Kimberly D. Matthews 3703 Enola Road Newville, PA 17241 45 Mare Road Carlisle, P A 17013 C/O The Giant Food, Inc. 1400 Harrisburg Pike Carlisle, PA 17013 "THIS FIRM IS A DEBT COLLECTOR ATTEMPTING TO COLLECT A DEBT AND ANY INFORMATION OBTAINED WILL BE USED FOR THAT PURPOSE. IF YOU HAVE PREVIOUSLY RECEIVED A DISCHARGE IN BANKRUPTCY AND THIS DEBT WAS NOT REAFFIRMED, THIS IS NOT AND SHOULD NOT BE CONSTRUED TO BE AN ATTEMPt TO COLLECT A DEBT, BUT ONLY ENFORCEMENT OF A LIEN AGAINST PROPERTY." Your house (real estate) at 45 Mare Road, Carlisle, P A 17013, is scheduled to be sold at the Sheriffs Sale on Seotember 6, 2000 at 10:00 a.m. in the Cumberland County Courhtouse , South Hanover Street, Carlisle, PA 17013, to enforce the court judgment obtained by GMAC Morte-ae-e CoroorationofPA (the mortgagee) against you. If the Sheriffs sale is postponed, the property will be . relisted for the December 6, 2000 Sheriffs Sale. NOTICE OF OWNER'S RIGHTS YOU MAYBE ABLE TO PREVENT THIS SHERIFF'S SALE To prevent this Sheriffs Sale, you must take immediate action: 1. The sale will be cancelled if you pay to the mortgagee the back payments, late charges, costs and reasonable attorney's fees due. To find out how much you must pay, you may call: (215) 563-7000. 2. You may be able to stop the sale by filing a petition asking the Court to strike or open the judgment, if the judgment was improperly entered. You may also ask the Court to postpone the sale for good cause. 3. You may also be able to stop the sale through other legal proceedings. "'I .,' ,~~ ~ You may need an attorney to assert your rights. The sooner you contact one, the more chance you will have of stopping the sale.. (See notice on page two on how to obtain an attorney.). YOU MAY STILL BE ABLE TO SAVE YOUR PROPERTY AND YOU HAVE OTHER RIGHTS EVEN IF THE SHERIFF'S SALE DOES TAKE PLACE. I. If the Sheriff's Sale is not stopped, your property will be sold to the highest bidder. You may find out the price bid by calling (215) 563-7000. 2. You may be able to petition the Court to set aside the sale if the bid price was grossly inadequate compared to the value of your property. 3. The sale will go through only if the buyer pays the Sheriff the full amount due in the sale. To find out if this has happened, you may call (717) 240-6390. 4. If the amount due from the Buyer is not paid to the Sheriff, you will remain the owner of the property as if the sale never happened. 5. You have the right to remain in the property until the full amount due is paid to the Sheriff and the Sheriff gives a deed to the buyer. At that time, the buyer may bring legal proceedings to evict you. 6. You may be entitled to a share of the money which was paid for your house. A schedule of distribution of the money bid for your house will be filed by the Sheriff within 30 days of the sale. This schedule will state who will be receiving that money. The money will I)e paid out in accordance with this schedule unless exceptions (reasons why the proposed distribution is wrong) are filed with the Sheriffwithin ten (10) days after the distribution is filed. 7. You may also have other rights and defenses, or ways of getting your home back, if you act immediately after the sale. YOU SHOULD TAKE THIS PAPER TO YOUR LAWYER AT ONCE. IF YOU DO NOT HAVE ALA WYER OR CANNOT AFFORD ONE, GO TO OR TELEPHONE THE OFFICE LISTED BELOW TO FIND OUT WHERE YOU CAN GET LEGAL HELP. CUMBERLAND COUNTY ATTORNEY REFERRAL CUMBERLAND COUNTY BAR ASSOCIATION 2 LIBERTY AVENUE CUMBERLAND COUNTY COURTHOUSE CARLISLE, PA 17013 (717) 249-3166 (800) 990-9108 .- ~ . - --, .' ,," ;~L:li" \.. \ \0 "', "-. DESCRIPTION ALL THAT CERTAIN tract ofland in Lower Frankford Township Cumberland County, Pennsylvania, containing 16.892 acres, being the northern most part of thefarnnow or formerly of Nelson H. Shughart, and Ruth E. Shughart, his wife, which farm is more particularly located as being in the Northeast comer of Legislative Route No. 21001, known as Traffic Route No. 994 and Township Road No. 492, the tract hereby conveyed being more particularly bounded and described as follows: " BEGINNING at an iron pin on a line of land now or formerly of C.C. Leidigh and land now or formerly of Eugene C. Morrison, North 72 degrees 57 minutes 48 seconds East 1029.522 feet to a stone pile; thence South 21 degrees 42 minutes 11 seconds East 495.76 feet to an iron pin and stone pile; thence South 22 degrees 41 minutes 53 second East 397.75 feet to an iron pin; thence South 75 degrees 22 minutes 50 seconds West 641.68 feet to an iron pin; thence North 45 degrees 30 minutes 37 seconds West 981. 602 feet to the place of beginning. CONTAINING 16.6.82 acres, more or less. Tax Parcel #14-04-0381-040 TITLE TO SAID PRElYlISES IS VESTED IN Scott A, Matthews and Kimberly D. Matthews, his wife by Deed from Walter E. Morrison. dated 6/23/93 recorded 6/23/93 in Deed Book 36-1 Page 1133. ~" "-~,,' \t .~.. , WRIT OF EXECUTION and/or ATTACHMENT 11 Ii .. COMMONWEALTH OF PENNSYLVANIA) COUNTY OF CUMBERLAND) NO. 2000-232 CIVIL 19 CIVIL ACTION - LAW I: i,r TO THE SHERIFF OF (]unh~rl Fmn COUNTY: To satisfy the debt, interest and costs due GMAC Mortaaoe Corporation of PA PLAINTIFF(S) from Scott A. Matthews and Kimberly D. Matthews 45 Mare Road Carlisle, PA 17055 DEFENDANT(S) (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 notWy the garnishee(s) that: (a) an attachment has been issued; (b) the garnishee(s) is/are enjoined from paying any debt to or for the account of the defendant(s) and from delivering any property of thedefendant(s) or otherwise disposing thereof; (3) If property oflhe defendant(s) nollevied upon an subjecllo attachment is found inthe possession of anyone other than a named garnishee, you are direcledto notny him/herthat he/she has been added as a garnishee and is enjoined as above stated. Amount Due $114,330.80 Interest from 4/7/00-9/6/00 $2,856.08 (per diem - $18.79) Ally's Comm % Ally Paid 5271.54 Plaintiff Paid L.L. $.50 and Costl!Je Prothy $1. 00 Other Costs Date: Mav 10, 2000 Curtis R. Lana Prothonotary, Oivil Division by: ,,;~O K. ~-4. V;" Deputy REQUESTING PARTY: Name Address: Frank Fedennan. Esa. Two Penn Center Plaza Suite 900 Philadelnhia. PA 19102 Attorney for: Plaintiff Telephone: t2J 5) 563-7000 Supreme Court ID No. 1 n48 .' .;'.~)~' 11i- I _~~i<iii1"" :f -~.J.&ti ~~~..~ ~M!IIIIl~ . ,. ,- "".~ Lo"", ~~'. ,'.., 'ill"' """"'l!W" II" V E S~LE. ha. Rb\\.. ES1 ~ 1 UIl /YVI. ~ ;;. ~ the sheriff levied upon the defendants interest in the real property situated in,,{, #. E",,- f!- J~~1""'~ Cumberland County, Pi " " ~umbered as: 0/..5' AlI,;_ J ~ L- a. 4.P..~ and mOff , on Exhibll "A" IUed with this writ and by this reference ' i.:orporated herein. 'J8te.".L111r-</J 1:( :2.--b T Jjf~l ::.'n,,',.rUIA.,. _ ~t-~ (",""U3d 1- ) 'r' ~ '. , '-, \. ,\ ,,/1 ,1_ ,'" \ \ I', .' " ~~~ . , ~','; t, \ \ C~. ' . "'I~ l"J' " .: ,~\i .X(\ Itil.~i(:,.;,('" ;1-.) ,t\,1 - :a!if~l%~\il'i " ' .,,"~.. < I _ (-J c:w CViI &:::::::I Gi) 00\l II ---<1''''''''1<1 "M" - ",. " l"""\ PRAECIPE FOR WRIT OF EXECUTION - (MORTGAGE FORECLOSURE) P.R.c.P. 3180-3183 GMAC Mortgage Corporation ofPA Plaintiff, Cumberland County v. No. 2000-232 CIVIL Scott A. Matthews Kimberly D. Matthews Defendaut(s). TO THE DIRECTOR OF THE OFFICE OF THE PROTHONOTARY: Issue writ of execution in the above matter: Amount Due $114.330.80 / ., Interest from 4/7/00 - 9/6/00 $2.856.08 and Costs (per diem - $18.79) $114.330.80 TOTAL ~~Q~ TWO PENN C TER PLAZA SUITE 900 PHILADELPHIA, PA 19102 Attorney for Plaintiff Note: Please attach description of property. No. 45. !vi.tPr-L R{)~ C-adi<J c Pit /7() /~ ill "~,,~I!l_ U ~ ...::t ~ M :z: t-::- .. :::><( UjQ - 00=.- ~"'- :::c O~ C I~:X= 0- t\?; ~r- 7Y 0 Cl 3(D ~::. -7 UJ-'- 0::'2: EtUJ >- uJU.J :C "'" COO- x: -- I-- .2: ~ 0 :::> 0 0 > >rj -= t":ls! ~. ~ ~~ p. - C".l ~ (1) P.- ~ l"'Jg:] '" t":l @ ~ .... t":l ~t":l (1) t"'~00 i~ ~OO a= ~~ (l = ., o ""l 0 >0 [l->~ ::\.0 I;7'S ::\. j .g .....>iI >- 1lCl::O ~ ;; a: t":l~ = . 00 (l ~=. ~~ q'?- IlCl = 0 ~ .. e""l '" - a ... ~ ~a= -<I t":l Zt":l \0 IlCl Ul = ~ ~ ~ ....;; Sl ~ a=~ 0 ~o \0 ... \0 -=Qi:' ~o 'Cl ~a= 0' > ~ = cr 0 > (1) O'''''l &t~ ; -=a= ~ '" .... '" ~ l"'J ~o ~ ... (1) ~ '" ~. ::! ... ~ 0 .... -e- = ZZ (1) Q '" P. t":l 0 00-= ... ><t"' S ~ t"'l"'J .... <> ZtHe1 0 >00 z zo .. --'l . ....""l ~ = e > tHO' ...:~tD - = ., ~Q~ - -==t:::I >~ . ....oa= t:::l~= .... ::t: .... cr ~ '" \-- - .- -"" ......"'-.. lHW.li;!'n~_~ ~_ ~- ~ ~~"rl"'_".j""l"!"'f!r"lll'(1W!'J'i"'m~"'~Rj~~~~~IIlJII~~ ~---- I ~ d' . ,_ . ,'_.-,:;. , 'it ' t' ..... DESCRIPTION ALL THAT CERTAIN tract of land in Lower Frankford Township Cumberland County, Pennsylvania, containing 16.892 acres, being the northern most part of thefaranow or formerly of Nelson H. Shughart, and Ruth E. Shughart, his wife, which farm is more particularly located as being in the Northeast corner of Legislative Route No. 21001, known as Traffic Route No. 994 and Township Road No. 492, the tract hereby conveyed being more particularly bounded and described as follows: ~ .. BEGINN)}l'G a~ an iron pin on a line of land now or formerly of C.C. Leidigh and land now or formerly of Eugene C. Morrison, North 72 degrees 57 minutes 48 seconds East 1029.522 feet to a stone pile; thence South 21 degrees 42 minutes 11 seconds East 495.76 feet to an iron pin and stone pile; thence South 22 degrees 41 minutes 53 second East 397.75 feet to an iron pin; thence South 75 degrees 22 minutes 50 seconds West 641.68 feet to an iron pin; thence North 45 degrees 30 minutes 37 seconds West 981.602 feet to the place of beginning. CONTAINING 16.682 acres, more or less. Tax Parcel #14-04-0381-040 TITLE TO SAID PREMISES IS VESTED IN Scott A. Matthews and Kimberly D. Matthews, his wife by Deed from Walter E. Morrison elated 6/23/93 recorded 6/23/93 in Deed Book 36-1 Page 1133. ~R ~ ~ \0, ~& '-..J \ ~~''''l<,Oj~ilIlt. ---- c-[::J \'. wf ._~ '"" "" .,~ 9-> -J r::u ~ -- G- '..J- () ---J ~ 5(, ~ ?t' ar-- ~~~,~-~,\ \~~ ~ ~~~ C) (j -I '~iMjJJIT III -,'c' ~^'''''", , r I" -, ,!I'-~:" -, J,.: ~.. .<,_<___, I ,_ .." -,,,o~,,_, -r ,_, ','._ ~'- -' '-, ,,- -,-..:. , "'""' ,...", " ~ 0 0 ~ C 0 -~ :c: :~-T1 "'" -a OJ ):>0 en;=; nirn -< Z::IJ ~3~ ZC 0 ~~:: Si-? !;CO -0 i5~ ~() :x Zen "-0 - ~ :t>c .. ~ Z w :< c- -< ~-,~,~. 'r6i:;" FEDE~ANandPHELAN By: FRANK FEDERMAN Identification No. 12248 Suite 900 Two Penn Center Plaza Philadelphia, PA 19102 (215) 563-7000 ATTORNEY FOR PLAINTIFF GMAC Mortgage Corporation ofPA Plaintiff, CUMBERLAND COUNTY COURT OF COMMON PLEAS v. CIVIL DIVISION Scott A. Matthews Kimberly D. Matthews NO. 2000-232 CIVIL Defendant(s). CERTIFICATION FRANK FEDERMAN, ESQUIRE, hereby verifies that he is attorney for the Plaintiff in the above-captioned matter, and that the premises are not subject to the provisions of Act 91 because it is: () an FHA mortgage () non-owner occupied () vacant (X) Act 91 procedures have been fulfilled This certification is made subject to the penalties of 18 Pa. C.S. Section 4904 relating to unsworn falsification to authorities. F FED A orney for Plain ff .-~.-- ,~,.;J.~~'~~k1Wi~,~~,~~iU - , ~, ............ - . ~~, 0 0 Q, C Cl "Z' :;i: ;:;:l -065 ::<. j'1'-12J rrl rn -om Z'";9. CJO,? ffi ).~ 0 ~~~a 2;5 -0 cc:B -- :;,:. qa ~o -~rn _0 - '3, :pc .. ~ :z. (..) :2. ~ "- ~~ -~~ - . ,.".,". ~""l " .. GMAC Mortgage Corporation ofPA CUMBERLAND COUNTY Plaintiff, v. COURT OF COMMON PLEAS Scott A. Matthews Kimherly D. Matthews CML DIVISION NO. 2000-232 CIVIL Defendant(s). AFFIDA VII PURSUANT TO RULE 3129 (Affidavit No.1) GMAC Mortl!:al!:e Corporation ofPA, Plaintiff in the above action, by its attorney, FRANK FEDERMAN, ESQUIRE, sets forth as of the date the Praecipe for the Writ of Execution was filed the following information concerning the real property located at 45 Mare Road. Carlisle. P A 17013. 1. Name and address ofOwner(s) or reputed Owner(s): NAME LAST KNOWN ADDRESS (If address cannot be reasonably ascertained, please so indicate.) Scott A. Matthews RR 2, Box 540 Landisburg, P A 17040 Kimberly D. Matthews 3703 Enola Road Newville, PA 17241 2. Name and address of Defendant(s) in the judgment: NAME LAST KNOWN ADDRESS (If address cannot be reasonably ascertained, please so indicate.) Same as above 3. Name and address of every judgment creditor whose judgment is a record lien on the real property to be sold: NAME LAST KNOWN ADDRESS (If address cannot be reasonably ascertained, please so indicate.) Household Realty Corp. 961 Weigel Drive Elmhurst, IL 60126 ~--.,.,.-- ~ ~ ." - 1- '"a:-:\ " "" 4. Name and address of the last recorded holder of every mortgage of record: NAME LAST KNOWN ADDRESS (If address cannot be reasonably ascertained, please so indicate.) GMAC Mortgage Corporation of America 1301 Office Center Drive Suite 200 Fort Washington, P A 19117 Household Realty Corporation 25 Gateway Drive Suite 107 Mechanicsburg, lP A 17055 5. Name and address of every other person who has any record lien on the property: NAME LAST KNOWN ADDRESS (If address cannot be reasonably ascertained, please so indicate.) None 6. Name and address of every other person who has any record interest in the property and whose interest may be affected by the sale: NAME LAST KNOWN ADDRESS (If address cannot be reasonably ascertained, please so indicate.) None 7. Name and address of every other person whom the plaintiff has knowledge who has any interest in the property, which may be affected by the sale: NAME LAST KNOWN ADDRESS (If address cannot be reasonably ascertained, please so indicate.) Tenant/Occupant 45 Mare Road Carlisle, P A 17013 Domestic Relations of Cumberland County 13 North Hanover Street Carlisle, P A 17013 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 ofl8 Pa. e.S. Sec. 4904 relating to unsworn falsification to authorities. Mav 8. 2000 DATE F FED Attorney for PIa' !Ill -, ,_J"_~o:.lu_'-"-'-'-"""'""~~"1i~lli,'lili<il'i.'U;llikt''''''Jt.j'bL+''''~:~~ 11_~1 - '=~_- " ~ .-~ -~ IliM :...~ ~~ ~ ',. , "'"""..- .'. . " ! '" q Cl 0 C- d ',1 - ::r,: ---I <c -OeD ""'" 'if! TTlfTl -< ;-~i- z:x:: ""~~ wS;,: c::> -=< .L.. ~~-l . GO -0 "'r -r-~ 5>c. ::;!: ;..:...:;: :r3 ~("') ~c'1 - (Srn >c ." ---I Z :.> ~ ~ ~ -< .~ E ~" ~'y- _< ~. v, - ~, 'i.;: \ GMAC Mortgage Corporation ofPA Plaintiff, CUMBERLAND COUNTY v. No. 2000-232 CIVIL Scott A. Matthews Kimberly D. Matthews Defendant(s). May 8, 2000 TO: Scott A. Matthews RR 2, Box 540 Landisburg, P A 17040 Kimberly D. Matthews 3703 Enola Road Newville, PA 17241 45 Mare Road Carlisle, PAl 70 13 C/O The Giant Food, Inc. 1400 Harrisburg Pike Carlisle, P A 17013 **THIS FIRM IS A DEBT COLLECTOR ATTEMPTING TO COLLECT A DEBT AND ANY INFORMA nON OBTAINED WILL BE USED FOR THAT PURPOSE. IF YOU HAVE PREVIOUSLY RECEIVED A DISCHARGE IN BANKRUPTCY AND THIS DEBT WAS NOT REAFFIRMED, THIS IS NOT AND SHOULD NOT BE CONSTRUED TO BE AN ATTEMPT TO COLLECT A DEBT, BUT ONLY ENFORCEMENT OF A LIEN AGAINST PROPERTY. ** Your house (real estate) at 45 Mare Road. Carlisle. P A 17013, is scheduled to be sold at the Sheriffs Sale on September 6. 2000 at 10:00 a.m. in the Cumberland County Courhtouse , South Hanover Street, Carlisle, P A 17013, to enforce the court judgment obtained by GMAC Morte:ae:e Corporation ofPA (the mortgagee) against you. Ifthe Sheriff's sale is postponed, the property will be relisted for the December 6, 2000 Sheriff's Sale. NOTICE OF OWNER'S RIGHTS YOU MAY BE ABLE TO PREVENT THIS SHERIFF'S SALE To prevent this Sheriffs Sale, you must take immediate action: L The sale will be cancelled if you pay to the mortgagee the back payments, late charges, costs and reasonable attorney's fees due. To fmd out how much you must pay, you may call: (215) 563-7000. 2. You may be able to stop the sale by filing a petition asking the Court to strike or open the judgment, if the judgment was improperly entered. You may also ask the Court to postpone the sale for good cause. 3 . You may also be able to stop the sale through other legal proceedings. ~............~ ~-"'" L.~ . ''',. , \ , You may need an attorney to assert your rights. The sooner you contact one, the more chance you will have of stopping the sale. (See notice on page two on how to obtain an attorney.) YOU MAY STILL BE ABLE TO SAVE YOUR PROPERTY AND YOU HAVE OTHER RIGHTS EVEN IF THE SHERIFF'S SALE DOES TAKE PLACE. 1. If the Sheriffs Sale is not stopped, your property will be sold to the highest bidder. You may fmd out the price bid by calling (215) 563-7000. 2. You may be able to petition the Court to set aside the sale if the bid price was grossly inadequate compared to the value of your property. 3. The sale will go through only if the buyer pays the Sheriff the full amount due in the sale. To fmd out if this has happened, you may call (717) 240-6390. 4. If the amount due from the Buyer is not paid to the Sheriff, you will remain the owner of the property as if the sale never happened. 5 . You have the right to remain in the property until the full amount due is paid to the Sheriff and the Sheriff gives a deed to the buyer. At that time, the buyer may bring legal proceedings to evict you. 6. You may be entitled to a share of the money which was paid for your house. A schedule of distribution of the money bid for your house will be filed by the Sheriff within 30 days of the sale. This schedule will state who will be receiving that money. The money will be paid out in accordance with this schedule unless exceptions (reasons why the proposed distribution is wrong) are filed with the Sheriff within ten (10) days after the distribution is filed. 7. You may also have other rights and defenses, or ways of getting your home back, if you act immediately after the sale. YOU SHOULD TAKE TillS PAPER TO YOUR LAWYER AT ONCE. IF YOU DO NOT HAVE ALA WYER OR CANNOT AFFORD ONE, GO TO OR TELEPHONE THE OFFICE LISTED BELOW TO FIND OUT WHERE YOU CAN GET LEGAL HELP. CUMBERLAND COUNTY ATTORNEY REFERRAL CUMBERLAND COUNTY BAR ASSOCIATION 2 LmERTY AVENUE CUMBERLAND COUNTY COURTHOUSE CARLISLE, P A 17013 (717) 249-3166 (800) 990-9108 ~- - . -.ll:._' , I . .... .~ -. DESCRIPTION ALL THAT CERTAIN tract of land in Lower Frankford Township Cumberland County, Pennsylvania, containing 16.892 acres, being the northern most part of thefarnnow or formerly of Nelson H. Shughart, and Ruth E. Shughart, his wife, which farm is more particularly located as being in the Northeast comer of Legislative Route No. 21001, known as Traffic Route No. 994 and Township Road No. 492, the tract hereby conveyed being more particularly bounded and described as follows: ~ BEGINNING at an iron pin on. a line of land now or formerly of C.C. Leidigh and land now or formerly of Eugene C. Morrison, North 72 degrees 57 minutes 48 seconds East 1029.522 feet to a stone pile; thence South 21 degrees 42 minutes 11 seconds East 495.76 feet to an iron pin and stone pile; thence South 22 degrees 41 minutes 53 second East 397.75 feet to an iron pin; thence South 75 degrees 22 minutes 50 seconds West 641.68 feet to an iron pin; thence North 45 degrees 30 minutes 37 seconds West 981.602 feet to the place of beginning. CONTAINING 16.682 acres, more or less. Tax Parcel #14-04-0381-040 TITLE TO SAID PREMISES IS VESTED IN Scott A. Matthews and Kimberly D. Matthews, his wife by Deed from Walter E. Morrison dated 6/23/93 recorded 6/23/93 in Deed Book 36-I Page 1133. I. ~lIiiilIiilOW\.' ~-""""'~i'I<#'''''-''llI<>ilMlli~~~" - >~"-'"' " ~ , . 0 Cl 0 C 0 'T1 .".. :x -0"'":'1 .-~l mq,. ". "'11<1 Zr<l -< "F :D zr JS~ (f).J::" c::> -<2 0 r:'\..j -0 -:i' - ~ -L -Ii /Q :-'.4: 9-5 Z J j;~ - oiTI .. ~' Z ':.4 =< .1"" ::Q I ,-