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HomeMy WebLinkAbout00-00611{ McCABE, WEISBERG AND CONWAY, P.C. BY: TERRENCE J. MCCABE, ESQUIRE Identification Number 16496 First Union Building 123 South Broad Street, Suite 2080 Philadelphia, PA 19109 (215) 790-1010 CONSECO FINANCE CONSUMER DISCOUNT: COMPANY F/K/A GREEN TREE CONSUMER: DISCOUNT COMPANY V. MARGARET S. KEEVER Attorney for Plaintiff CUMBERLAND COUNTY COURT OF COMMON PLEAS NUMBER 2000-611 PRAECIPE TO AND REISSUE WRIT OF EXECUTION MORTGAGE FORECLOSURE To the PROTHONOTARY: Kindly reissue the Writ of Execution, in the above matter in the amount of $111,893.91. McCabe Weisberg & Conway, P.C. G ? l By TERRENCE J. McCABE, ESQUIRE Attorney for Plaintiff IN THE COURT OF COMMON PLEAS OF CUMBERLAND COUNTY, PENNSYLVANIA CIVIL DIVISION Conseco Finance Consumer FILE NO.: 2000-611 Civil Term Discount Co. f/k/a Green Tree Consumer Discount Co. AMOUNT DUE: $111,893.91 V. Margaret S. Keever 4603 Hampden Avenue, Camp Hill, PA 17011 INTEREST: from 3/20/00 ATTY'S COMM.: COSTS:$1015.00 TO THE PROTHONOTARY OF SAID COURT: The undersigned hereby certifies that the below does not arise out of a retail installment sale, contract, or account based on a confession of judgment, but if it does, it is based on the appropriate original proceeding filed pursuant to Act 7 of 1966 as amended; and for real property pursuant to Act 6 of 1974 as amended. PRAECIPE FOR EXECUTION Issue writ or execution in the above matter to the Sheriff of Cumberland County, for debt, interest and costs upon the following described property of the defendant(s) 4603 Hampden Avenue, Camp Hill, PA 17011 (More fully described as attached) PRAECIPE FOR ATTACHMENT EXECUTION Issue writ of attachment to the Sheriff of N/A County, for debt, interest and costs, as above, directing attachment against the above-named garnishee(s) for the following property (if real estate, supply six copies of the description; supply four copies of lengthy personalty list) and all other property of the defendant(s) in the possession, custody or control of the said garnishee(s). (Indicate) Index this writ against the garnishee(s) as a lis pendens against real estate of the defendant(s) described in the attached exhibit. October 30, 2001 ?p DATE: Signature: Print Name TERRENCE J. McCABE, ESQUIRE Address: 123 S. Broad Street, Suite 2080 Philadelphia, PA 19109 Attorney for: Plaintiff Telephone: (215) 790 1010 Supreme Court ID No. 16496 IN THE COURT OF CM" PLEAS OF C:[E7WMAW COUNTY, PENNSYLVANIA CIVIL DIVISION Conseco Finance Consumer Discount Co. f/k/a Green Tree Consumer Discount Co. : File No. 00-611 : Amount Due $111,893.91 V. Margaret S. Keever TO THE PROTHONOTARY OF THE SAID COURT: . Interest from 3/20/00 : Atty's : Costs $1.015.00 The undersigned hereby certifies that the below does not arise out of a retail installment sale, contract, or account based on a confession of judgment, but if it does, it is based on the appropriate original proceeding filed pursuant to Act 7 V 19C*6 ash amended; and for real property pursuant to Act 6 of 1974 as amended. n -0 ? PRAECIPE FOR EXECUTION e t+1 1tr; Issue writ of execution in the above matter to the Sheriff of County, for debt, interest and costs upon the following described defendant(s) 4603 Hampden Avenue, Camp Hill, PA 17011 (more fully described as attached) to PRAECIPE FOR ATTACHMENT EXECUTION Issue writ of attachment to the Sheriff of N/A County, for debt, interest and costs, as above, directing attachment against the above-named garnishee(s) for the following property (if real estate, supply six copies of the description; supply four copies of lengthy personalty list) and all other property of the defendant(s) in the possession, custody or control of the said garnishee(s). (Indicate) Index this writ against the garnishee(s) as a lis pendens against real estate of the defendant(s) described in the attached exhibit. DATE : J /n7 3 /0-y Signature:L zey, . Y4'1 Cz ?c? Print Name: Terrence J. McCabe, Esq. Address: 123 S. Broad St., Suite 2080 Philadelphia, PA 19109 Attorney for: Plaintiff Telephone: 215-790-1010 Supreme Court ID No.: 16496 I ALL THAT CERTAIN lot or tract of land situate in the Township of Hampden, County of Cumberland, and State of Pennsylvania, more particularly bounded and described as follows according to a survey of Garrit J. Betz, Registered Surveyor, dated January 11, 1971, to wit: BEGINNING at a point on the northern line of Hampden Avenue, said point being by same measured in a southwesterly direction 90.0 feet from the northwest corner of Clearview Drive and Hampden Avenue; thence South 61 degrees 26 minutes West along said northern line of Hampden Avenue a distance of 72.0 feet to a hub; thence North 38 degrees 34 minutes West along the eastern line of lands now or formerly of George D. Sauers a distance of 100.00 feet to an iron pipe; thence North 61 degrees 26 minutes East along the southern line of lands now or formerly of Roger L. Knecht and Jack H. Forten, respectively, a distance of 72.0 feet to a hub; thence South 38 degrees 34 minutes East along the line of adjoiner between Lots Nos. 191 and 192 on the hereinafter mentioned Plan of Lots a distance of 100.0 feet to a hub, the point and place of BEGINNING. BEING Lot No. 191, Block "J" on the Plan of Clearview Farm recorded in the Recorder's Office of Cumberland County, recorded in Plat Book 9, Page 13. HAVING THEREON ERECTED a one story frame dwelling with carport known and numbered as 4603 Hampden Avenue. Parcel #: 10-21-0279-195 n OT µ r ? ? ? C C Cl? rr? I GEC' C7 ` Y McCABE, WEISBERG AND CONWAY, P.C. BY: TERRENCE J. MCCABE, ESQUIRE Attorney for Plaintiff Identification Number 16496 First Union Building 123 South Broad Street, Suite 2080 Philadelphia, PA 19109 (215) 790-1010 CONSECO FINANCE CONSUMER DISCOUNT: CUMBERLAND COUNTY COMPANY F/K/A GREEN TREE CONSUMER: COURT OF COMMON PLEAS DISCOUNT COMPANY V. MARGARET S. KEEVER NUMBER 2000-611 AFFIDAVIT PURSUANT TO RULE 3129 I, Terrence J. McCabe, Esquire, attorney for Plaintiff in the above action, set forth as of the date the Praecipe for the Writ of Execution was filed the following information concerning the real property located at 4603 Hampden Avenue, Camp Hill, PA 17011, a copy of the description of said property is attached hereto and marked Exhibit "A." 1. Name and address of Owner(s) or Reputed Owner(s): Name Address Margaret S. Keever 2. Name and address of Defendant(s) in the judgment: Name Address Margaret S. Keever 4603 Hampden Avenue Camp Hill, PA 17011 4603 Hampden Avenue Camp Hill, PA 17011 3. Name and last known address of every judgment creditor whose judgment is a record lien on the real property to be sold: Name Address NONE 4. Name and address of the last recorded holder of every mortgage of record: Name Address Conseco Finance Consumer Discount f/k/a Green Tree 7360 Kyrene Road Consumer Discount Company Tempe, AZ 85283 Citifinancial f/k/a Commerc Credit Corp. Inc. Successor in interest to Security Pacific Finance Inc. GREEN TREE RETAIL SERVICES BANK, ONE tal 8335 Century Park Ct. Suite 200 San Diego, CA 92123 Attn: Karen Shields 1400 TURBINE DRIVE RAPID CITY, SD 57701 CITIFINANCIAL F/K/A COMMERCIAL CREDIT CORP CITIFINANCIAL F/K/A 7467 COMMERCIAL CREDIT CORP. 3401 HARTZDALE DR.,STE 126 CAMP HILL, PA 17011 NEW RIDGE ROAD, STE 222 HANOVER, ND 21076 ATTN: DAVID PARKS 5. Name and address of every other person who has any record interest in or record lien on the property and whose interest may be affected by the sale: Name Address None. 6. Name and address of every other person of whom the Plaintiff has knowledge who has any interest in the property which may be affected by the sale: Name Address Occupant(s) 4603 Hampden Avenue Camp Hill, PA 17011 Domestic Relations Cumberland County P.O. Box 320 Carlisle, PA 17015 I verify that the statements made in this Affidavit are true and correct to the best of my personal knowledge or information and belief. I understand that false statements herein are made subject to the penalties of 18 Pa.C.S. Section 49 4 relating to unsworn falsification to authorities. October 30, 2001 DATE TERRENCE J. McCABE, ESQUIRE Attorney for Plaintiff EXHIBIT "N ALL THAT CERTAIN lot or tract of land situate in the Township of Hampden, County of Cumberland, and State of Pennsylvania, more particularly bounded and described as follows according to a survey of Gerrit J. Betz, Registered Surveyor, dated January 11, 1971, to wit: BEGINNING at a point on the northern line of Hampden Avenue, said point being by same measured in a southwesterly direction 90.0 feet from the northwest corner of Clearview Drive and Hampden Avenue; thence South 61 degrees 26 minutes West along said northern line of Hampden Avenue a distance of 72.0 feet to a hub; thence North 38 degrees 34 minutes West along the eastern line of lands now or formerly of George D. Sauers a distance of 100.00 feet to an iron pipe; thence North 51 degrees 26 minutes East along the southern line of lands now or formerly of Roger L. Knecht and Jack H. Forten, respectively, a distance of 72.0 feet to a hub; thence South 38 degrees 34 minutes East along the line of adjoiner between Lots Nos. 191 and 192 on the hereinafter mentioned Plan of Lots a distance of 100.0 feet to a hub, the point and place of BEGINNING. BEING Lot No. 191, Block "J" on the Plan of Clearview Farm recorded in the Recorder's Office of Cumberland County, recorded in Plat Book 9, Page 13. HAVING THEREON ERECTED a one story frame dwelling with car port known and numbered as 4603 Hampden Avenue. Parcel M 10-21-0279-196 IIAH ca 9 _ T' cF a; = ` C rte O } McCABE, WEISBERG AND CONWAY, P.C. BY: TERRENCE J. MCCABE, ESQUIRE Identification Number 16496 First Union Building 123 South Broad Street, Suite 2080 Philadelphia, PA 19109 (215) 790-1010 Attorney for Plaintiff CONSECO FINANCE CONSUMER DISCOUNT: CUMBERLAND COUNTY COMPANY F/K/A GREEN TREE CONSUMER: COURT OF COMMON PLEAS DISCOUNT COMPANY V. MARGARET S. KEEVER NUMBER 2000-611 NOTICE OF SHERIFF'S SALE OF REAL PROPERTY TO: Margaret S. Keever 4603 Hampden Avenue Camp Hill, PA 17011 Your house (real estate) at 4603 Hampden Avenue, Camp Hill, PA 17011 (more fully described as attached) is scheduled to be sold at Sheriff's Sale on, March 06, 2002 at 10:00 a.m. in the Commissioner's Hearing Room located on the 2nd Floor of the Cumberland County Courthouse, 1 Courthouse Square, Carlisle, Pennsylvania 17013, to enforce the court judgment of $111,893.91 obtained by Conseco Finance Consumer Discount Company f/k/a Green Tree Consumer Discount Company against you. NOTICE OF OWNER'S RIGHTS YOU MAY BE ABLE TO PREVENT THIS SHERIFF'S SALE To prevent this Sheriff's Sale you must take immediate action: 1. The sale will be canceled if you pay to Conseco Finance Consumer Discount Company f/k/a Green Tree Consumer Discount Company the back payments, late charges, costs, and reasonable attorney's fees due. To find out how much you must pay, you may call Terrence J. McCabe, Esquire at (215) 790-1010. J ` 2. You may be able to stop the sale by filing a petition asking the Court to strike or open the judgment, if the judgment was improperly entered. You may also ask the Court to postpone the sale for good cause. 3. You may also be able to stop the sale through other legal proceedings. You may need an attorney to assert your rights. The sooner you contact one, the more chance you will have of stopping the sale. (See the following notice 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 Sheriff's Sale is not stopped, your property will be sold to the highest bidder. You may find out the price bid by calling Terrence J. McCabe, Esquire at (215) 790-1010. 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 on the sale. To find out if this has happened, you may call Terrence J. McCabe, Esquire at (215) 790-1010. 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 a 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. A schedule of distribution will be filed by the Sheriff on a date specified by the Sheriff not later than 30 days after sale. Distribution will be made in accordance with the schedule unless exceptions are filed thereto within 10 days after the filing of the schedule. 7. You may also have other rights and defenses, or ways of getting your real estate back, if you act immediately after the sale. a YOU SHOULD TAKE THIS PAPER TO YOUR LAWYER AT ONCE. IF YOU DO NOT HAVE A LAWYER OR CANNOT AFFORD ONE, GO TO OR TELEPHONE THE OFFICE LISTED BELOW TO FIND OUT WHERE YOU CAN GET LEGAL HELP. LAWYER REFERRAL SERVICE COURT ADMINISTRATOR 4TH FLOOR, CUMBERLAND COUNTY COURTHOUSE CARLISLE, PENNSYLVANIA 17013 (717) 240-6200 OR CUMBERLAND COUNTY BAR ASSOCIATION 2 LIBERTY AVENUE CARLISLE, PA 17013 (717) 249-3166 UZI _ G C, i O D• -? lD ? t IN THE COURT OF COMMON PLEAS OF CUMBERLAND COUNTY, PENNSYLVANIA CIVIL DIVISION Conseco Finance Consumer FILE NO.: 2000-611 Civil Term Discount Co. f/k/a Green Tree Consumer Discount Co. AMOUNT DUE: $111,893.91 V. INTEREST: from 3/21/00-12/04/02 $18,169.32 Margaret S. Keever ATTY'S COMM.: 4603 Hampden Avenue, Camp Hill, PA 17011 COSTS: TO THE PROTHONOTARY OF SAID COURT: The undersigned hereby certifies that the below does not arise out of a retail installment sale, contract, or account based on a confession of judgment, but if it does, it is based on the appropriate original proceeding filed pursuant to Act 7 of 1966 as amended; and for real property pursuant to Act 6 of 1974 as amended. PRAECIPE FOR EXECUTION Issue writ or execution in the above matter to the, Sheriff of Cumberland County,, for debt, interest and costs upon the following described property of the defendant(s) 4603 Hampden Avenue, Camp Hill, PA 17011 (More fully described as attached) PRAECIPE FOR ATTACHMENT EXECUTION Issue writ of attachment to the Sheriff of N/A County, for debt, interest and costs, as above, directing attachment against the above-named garnishee(s) for the following property (if real estate, supply six copies of the description; supply four copies of lengthy personalty list) and all other property of the defendant(s) in the possession, custody or control of the said garnishee(s). (Indicate) Index this writ against the garnishee(s) as a lis pendens against real estate of the defendant(s) described in the attached exhibit. September 6, 2002 - e ?C °L_ l 1 1' q ?? DATE : signature: Print Name: TERRENCE J. McCABE, ESQUIRE Address: 123 S. Broad Street, Suite 2080 Philadelphia, PA 19109 Attorney for: Plaintiff Telephone: (215) 790 1010 Supreme Court ID No. 16496 I.? (J v ? w /i?^ 1 V1 C f C C C -to' W .? J q C ? : dl 1 1 ? . 0 ° =) Cam,, "7 _?Y1 cn _„ `D o m z co ALL THAT CERTAIN lot or tract of land situate in the Township of Hampden, County of Cumberland, and State of Pennsylvania, more particularly bounded and described as follows according to a survey of Garrit J. Betz, Registered Surveyor, dated January 11, 1971, to wit: BEGINNING at a point on the northern line of Hampden Avenue, said point being by same measured in a southwesterly direction 90.0 feet from the northwest corner of Clearview Drive and Hampden Avenue; thence South 51 degrees 26 minutes West along said northern line of Hampden Avenue a distance of 72.0 feet to a hub; thence North 38 degrees 34 minutes West along the eastern line of lands now or formerly of George D. Sauers a distance of 100.00 feet to an iron pipe; thence North 51 degrees 26 minutes East along the southern line of lands now or formerly of Roger L. Knecht and Jack H. Forten, respectively, a distance of 72.0 feet to a hub; thence South 38 degrees 34 minutes East along the line of adjoiner between Lots Nos. 191 and 192 on the hereinafter mentioned Plan of Lots a distance of 100.0 feet to a hub, the point and place of BEGINNING. BEING Lot No. 191, Block "J" on the Plan of Clearview Farm recorded in the Recorders Office of Cumberland County, recorded in Plat Book 9, Page 13. HAVING THEREON ERECTED a one story frame dwelling with car port known and numbered as 4603 Hampden Avenue. Parcel #: 10-21-0279-195 McCABE, WEISBERG AND CONWAY, P.C. BY: TERRENCE J. McCABE, ESQUIRE Identification Number 16496 First Union Building 123 South Broad Street, Suite 2080 Philadelphia, PA 19109 (215) 790-1010 CONSECO FINANCE CONSUMER DISCOUNT: COMPANY F/K/A GREEN TREE CONSUMER: DISCOUNT COMPANY V. MARGARET S. KEEVER Attorney for Plaintiff CUMBERLAND COUNTY COURT OF COMMON PLEAS NUMBER 2000-611 AFFIDAVIT PURSUANT TO RULE 3129 I, Terrence J. McCabe, Esquire, attorney for Plaintiff in the above action, set forth as of the date the Praecipe for the Writ of Execution was filed the following information concerning the real property located at 4603 Hampden Avenue, Camp Hill, PA 17011, a copy of the description of said property is attached hereto and marked Exhibit "A." 1. Name and address of Owner(s) or Reputed Owner(s): Name Address Margaret S. Keever 4603 Hampden Avenue Camp Hill, PA 17011 2. Name and address of Defendant(s) in the judgment: Name Address Margaret S. Keever 4603 Hampden Avenue Camp Hill, PA 17011 3. Name and last known address of every judgment creditor whose judgment is a record lien on the real property to be sold: Name Address NONE 4. Name and address of the last recorded holder of every mortgage of record: Name Address Conseco Finance Consumer Discount f/k/a Green Tree 7360 Kyrene Road Consumer Discount Company Tempe, AZ 85283 Citifinancial f/k/a Commercial Credit Corp. Inc. Successor 8335 Century Park Ct. in interest to Security Suite 200 Pacific Finance Inc. San Diego, CA 92123 Attn: Karen Shields GREEN TREE RETAIL SERVICES BANK, ONE 1400 TURBINE DRIVE RAPID CITY, SD 57701 CITIFINANCIAL F/K/A 3401 HARTZDALE DR.,STE 126 COMMERCIAL CREDIT CORP. CAMP HILL, PA 17011 CITIFINANCIAL F/K/A 7467 NEW RIDGE ROAD, STE 222 COMMERCIAL CREDIT CORP. HANOVER, ND 21076 ATTN: DAVID PARKS 5, Name and address of every other person who has any record interest in or record lien on the property and whose interest may be affected by the sale: Name Address None. 6, Name and address of every other person of whom the Plaintiff has knowledge who has any interest in the property which may be affected by the sale: Name Address Tenant(s)/Occupant(s) 4603 Hampden Avenue Camp Hill, PA 17011 Domestic Relations Commonwealth of Pa Cumberland County P.O. Box 320 Carlisle, PA 17015 Department of Welfare P.O. Box 2675 Harrisburg, Pa 17105 I verify that the statements made in this Affidavit are true and correct to the best of my personal knowledge or information and belief, I understand that false statements herein are made subject to the penalties of 18 Pa.C.S. Section 4904 relating to unsworn falsification to authorities. September 6, 2002 r CE J. MCCABE, ESQUIRE DATE AA Plaintiff y for ALL THAT CERTAIN lot or tract of land situate in the Township of Hampden, County of Cumberland, and State of Pennsylvania, more particularly bounded and described as follows according to a survey of Gerrit J. Betz, Registered Surveyor, dated January 11, 1971, to wit: BEGINNING at a point on the northern line of Hampden Avenue, said point being by same measured in a southwesterly direction 90.0 feet from the northwest corner of Clearview Drive and Hampden Avenue; thence South 51 degrees 26 minutes West along said northern line of Hampden Avenue a distance of 72.0 feet to a hub; thence North 38 degrees 34 minutes West along the eastern line of lands now or formerly of George D. Sauers a distance of 100.00 feet to an iron pipe; thence North 51 degrees 26 minutes East along the southern line of lands now or formerly of Roger L. Knecht and Jack H. Forten, respectively, a distance of 72.0 feet to a hub; thence South 38 degrees 34 minutes East along the line of adjoiner between Lots Nos. 191 and 192 on the hereinafter mentioned Plan of Lots a distance of 100.0 feet to a hub, the point and place of BEGINNING. BEING Lot No. 191, Block "J" on the Plan of Clearview Farm recorded in the Recorders Office of Cumberland County, recorded in Plat Book 9, Page 13. HAVING THEREON ERECTED a one story frame dwelling with car port known and numbered as 4603 Hampden Avenue. Parcel 4: 10-21-0279-195 _ _ - NFdYWI am,n,;mmu?ti ? i rJ "ib m r tom, c? ;'-? _; r C> 7 "< CTS McCABE, WEISBERG AND CONWAY, P.C. BY: TERRANCE J. McCABE, ESQUIRE Identification Number 16496 First Union Building 123 South Broad Street, Suite 2080 Philadelphia, PA 19109 (215) 790-1010 Attorney for Plaintiff CONSECO FINANCE CONSUMER DISCOUNT: CUMBERLAND COUNTY COMPANY F/K/A GREEN TREE CONSUMER: COURT OF COMMON PLEAS DISCOUNT COMPANY V. MARGARET S. KEEVER NUMBER 2000-611 NOTI E OF SHERIFF'S SALE OF REAL PROPERTY TO: Margaret S. Keever 4603 Hampden Avenue Camp Hill, PA 17011 Your house (real estate) at 4603 Hampden Avenue, Camp Hill, PA 17011 (more fully described as attached) is scheduled to be sold at Sheriff's Sale on, DECEMBER 4, 2002 at 10:00 a.m. in the Commissioner's Hearing Room located on the 2nd Floor of the Cumberland County Courthouse, 1 Courthouse Square, Carlisle, Pennsylvania 17013, to enforce the court judgment of 134,987.91 obtained by Conseco Finance Consumer Discount Company f/k/a Green Tree Consumer Discount Company against you. NOTICE OF OWNER'S RIGHTS YOU MAY BE ABLE TO PREVENT THIS SHERIFF'S SALE To prevent this Sheriff's Sale you must take immediate action: 1. The sale will be canceled if you pay to Conseco Finance Consumer Discount Company f/k/a Green Tree Consumer Discount Company the back payments, late charges, costs, and reasonable attorney's fees due. To find out how much you must pay, you may call Terrence J. McCabe, Esquire at (215) 790-1010. 2. You may be able to stop the sale by filing a petition asking the Court to strike or open the judgment, if the judgment was improperly entered. You may also ask the Court to postpone the sale for good cause. 3. You may also be able to stop the sale through other legal proceedings. You may need an attorney to assert your rights. The sooner you contact one, the more chance you will have of stopping the sale. (See the following notice 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 Sheriff's Sale is not stopped, your property will be sold to the highest bidder. You may find out the price bid by calling Terrence J. McCabe, Esquire at (215) 790-1010. 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 on the sale. To find out if this has happened, you may call Terrence J. McCabe, Esquire at (215) 790-1010. 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 a 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. A schedule of distribution will be filed by the Sheriff on a date specified by the Sheriff not later than 30 days after sale. Distribution will be made in accordance with the schedule unless exceptions are filed thereto within 10 days after the filing of the schedule. 7. You may also have other rights and defenses, or ways of getting your real estate back, if you act immediately after the sale. YOU SHOULD TAKE THIS PAPER TO YOUR LAWYER AT ONCE. IF YOU DO NOT HAVE A LAWYER OR CANNOT AFFORD ONE, GO TO OR TELEPHONE THE OFFICE LISTED BELOW TO FIND OUT WHERE YOU CAN GET LEGAL HELP. LAWYER REFERRAL SERVICE COURT ADMINISTRATOR 4TH FLOOR, CUMBERLAND COUNTY COURTHOUSE CARLISLE, PENNSYLVANIA 17013 (717) 240-6200 OR CUMBERLAND COUNTY BAR ASSOCIATION 2 LIBERTY AVENUE CARLISLE, PA 17013 (717) 249-3166 ALL THAT CERTAIN lot or tract of land situate in the Township of Hampden, County of Cumberland, and State of Pennsylvania, more particularly bounded and described as follows according to a survey of Garrit J. Betz, Registered Surveyor, dated January 11, 1971, to wit. BEGINNING at a point on the northern line of Hampden Avenue, said point being by same measured in a southwesterly direction 90.0 feet from the northwest corner of Clegrview Drive and Hampden Avenue; thence South 51 degrees 26 minutes West along said northern line of Hampden Avenue a distance of 72.0 feet to a hub; thence North 38 degrees 34 minutes West along the eastern line of lands now or formerly of George D. Sauers a distance of 100.00 feet to an iron pipe; thence North 61 degrees 26 minutes East along the southern line of lands now or formerly of Roger L. Knecht and Jack H. Forten, respectively, a distance of 72.0 feet to a hub; thence South 38 degrees 34 minutes East along the line of adjoiner between Lots Nos. 191 and 192 on the hereinafter mentioned Plan of Lots a distance of 100.0 feet to a hub, the point and place of BEGINNING. BEING Lot No. 191, Block "J" on the Plan of Clearview Farm recorded in the Recorder's Office of Cumberland County, recorded in Plat Book 9, Page 13. HAVING THEREON ERECTED a one story frame dwelling with car port known and numbered as 4603 Hampden Avenue. Parcel #: 10-21-0279-196 9YfYl ? ti s...?-.?.?? wa.?...? _ ... ?:- _... .,? . _ . ? ?n ? =? _.4 ? R ? ? ' ' ? .?'n ; " 7-- _/ Cl K`? "C3 ?. '`j'r) t r ? ? r ? ; ? ? p WRIT OF EXECUTION and/or ATTACHMENT COMMONWEALTH OF PENNSYLVANIA) COUNTY OF CUMBERLAND) N000-611 Civil CIVIL ACTION - LAW TO THE SHERIFF OF CUMBERLAND COUNTY: To satisfy the debt, interest and costs due CONSECO FINANCE CONSUMER DISCOUNT CO F/K/A GREEN TREE CONSUMER DISCOUNT CO., Plaintiff (s) From MARGARET S. KEEVER, 4603 HAMPDEN AVENUE, CAMP HILL, PA 17011 (1) You are directed to levy upon the property of the defendant (s)and to sell SEE LEGAL DESCRIPTION. (2) You are also directed to attach the property of the defendant(s) not levied upon in the possession of GARNISHEE(S) as follows: and to notify the gamishee(s) that: (a) an attachment has been issued; (b) the gamishee(s) is enjoined from paying any debt to or for the account of the defendant (s) and from delivering any property of the defendant (s) or otherwise disposing thereof; (3) If property of the defendant(s) not levied upon an subject to attachment is found in the possession of anyone other than a named garnishee, you are directed to notify him/her that he/she has been added as a garnishee and is enjoined as above stated. Amount Due$111,893.91 L.L. Interest FROM 3/21/00-12/4/02 - $18,169.32 Atty's Comm % Due Prothy $1.00 Atty Paid $1593.19 Other Costs Plaintiff Paid Date: SEPTEMBER 10, 2002 CURTIS R. LONG ProthonotaTy ??f f (Seal) `?YP?2C /LAY. Deputy REQUESTING PARTY: Name TERRENCE J.MCCABE, ESQUIRE Address: 123 S. BROAD STREET, SUITE 2080 PHILADELPHIA, PA 19109 Attorney for: PLAINTIFF Telephone: 215-790-1010 Supreme Court ID No. 16496 k Conseco Finance Consumer Discount hi The Court of Common Pleas of F/k/a Green Tree Consumer Discount Cumberland County, Pennsylvania Company Writ No. 2000-611 Civil Term VS Margaret S. Keever R. Thomas Kline, Sheriff, who being duly sworn according to law, states this writ is returned STAYED pursuant to instructions from Attorney Terrence McCabe. Sheriff's Costs Docketing 30.00 Surcharge 20.00 Posting Handbills 15.00 Law Library Prothonotary 1.00 Share of Bills 24.20 Mileage 18.20 Levy 15.00 Advertising 15.00 Certified Mail .82 Poundage 14.55 Postpone Sale 20.00 Law Journal 297.95 Patriot News 270.30 $742.02 Sworn and subscribed to before me paid by attorney 6/06/02 This I I 'day of 2002, A.D. Prothonotary So Answers: R. Thomas Kline, Sheriff BY Real Estat Deputy ',JU Cie ?' ? a McCABE, WEISBERG AND CONWAY, P.C. BY: TERRENCE J. McCABE, ESQUIRE Identification Number 16496 First Union Building 123 South Broad Street, Suite 2080 Philadelphia, PA 19109 (215) 790-1010 CONSECO FINANCE CONSUMER DISCOUNT: COMPANY F/K/A GREEN TREE CONSUMER: DISCOUNT COMPANY V. MARGARET S. KEEVER Attorney for Plaintiff CUMBERLAND COUNTY COURT OF COMMON PLEAS NUMBER 2000-611 AFFIDAVIT PURSUANT TO RULE 3129 I, Terrence J. McCabe, Esquire, attorney for Plaintiff in the above action, set forth as of the date the Praecipe for the Writ of Execution was filed the following information concerning the real property located at 4603 Hampden Avenue, Camp Hill, PA 17011, a copy of the description of said property is attached hereto and marked Exhibit "A." 1. Name and address of Owner(s) or Reputed Owner(s): Name Address Margaret S. Keever 4603 Hampden Avenue Camp Hill, PA 17011 2. Name and address of Defendant(s) in the judgment: Name Address Margaret S. Keever 4603 Hampden Avenue Camp Hill, PA 17011 3. Name and last known address of every judgment creditor whose judgment is a record lien on the real property to be sold: Name Address NONE 4. Name and address of the last recorded holder of every mortgage of record: Name Address Conseco Finance Consumer Discount f/k/a Green Tree 7360 Kyrene Road Consumer Discount Company Tempe, AZ 85283 Citifinancial f/k/a Commerc Credit Corp. Inc. Successor in interest to Security Pacific Finance Inc. GREEN TREE RETAIL SERVICES BANK, ONE ial 8335 Century Park Ct. Suite 200 San Diego, CA 92123 Attn: Karen Shields 1400 TURBINE DRIVE RAPID CITY, SD 57701 CITIFINANCIAL F/K/A COMMERCIAL CREDIT CORP CITIFINANCIAL F/K/A 7467 COMMERCIAL CREDIT CORP. 3401 HARTZDALE DR.,STE 126 CAMP HILL, PA 17011 NEW RIDGE ROAD, STE 222 HANOVER, ND 21076 ATTN: DAVID PARKS 5. Name and address of every other person who has any record interest in or record lien on the property and whose interest may be affected by the sale: Name Address None. 6. Name and address of every other person of whom the Plaintiff has knowledge who has any interest in the property which may be affected by the sale: Name Address Occupant(s) 4603 Hampden Avenue Camp Hill, PA 17011 Domestic Relations Cumberland County P.O. Box 320 Carlisle, PA 17015 I verify that the statements made in this Affidavit are true and correct to the best of my personal knowledge or information and belief. I understand that false statements herein are made subject to the penalties of 18 Pa.C.S. Section 49 4 relating to unsworn falsification to authorities. October 30, 2001 DATE TERRENCE J. McCABE, ESQUIRE Attorney for Plaintiff EXH IBIT`W ALL THAT CERTAIN lot or tract of land situate in the Township of Hampden, County of Cumberland, and State of Pennsylvania, more particularly bounded and described as follows according to a survey of Garrit J. Betz, Registered Surveyor, dated January 11, 1971, to wit: BEGINNING at a point on the northern line of Hampden Avenue, said point being by same measured in a southwesterly direction 90.0 feet from the northwest corner of Clearview Drive and Hampden Avenue; thence South 51 degrees 26 minutes West along said northern line of Hampden Avenue a distance of 72.0 feet to a hub; thence North 38 degrees 34 minutes West along the eastern line of lands now or formerly of George D. Sauers a distance of 100.00 feet to an iron pipe; thence North 61 degrees 26 minutes East along the southern line of lands now or formerly of Roger L. Knecht and Jack H. Forten, respectively, a distance of 72.0 feet to a hub; thence South 38 degrees 34 minutes East along the line of adjoiner between Lots Nos. 191 and 192 on the hereinafter mentioned Plan of Lots at distance of 100.0 feet to a hub, the point and place of BEGINNING. BEING Lot No. 191, Block "J" on the Plan of Clearview Farm recorded in the Recorder's Office of Cumberland County, recorded in Plat Book 9, Page 13. HAVING THEREON ERECTED a one story frame dwelling with car port known and numbered as 4603 Hampden Avenue. ParcelM 10-21-0279495 McCABE, WEISBERG AND CONWAY, P.C. BY: TERRENCE J. McCABE, ESQUIRE Attorney for Plaintiff Identification Number 16496 First Union Building 123 South Broad Street, Suite 2080 Philadelphia, PA 19109 (215) 790-1010 CONSECO FINANCE CONSUMER DISCOUNT: CUMBERLAND COUNTY COMPANY F/K/A GREEN TREE CONSUMER: COURT OF COMMON PLEAS DISCOUNT COMPANY V. MARGARET S. KEEVER NUMBER 2000-611 NOTICE OF SHERIFF'S SALE OF REAL PROPERTY TO: Margaret S. Keever 4603 Hampden Avenue Camp Hill, PA 17011 Your house (real estate) at 4603 Hampden Avenue, Camp Hill, PA 17011 (more fully described as attached) is scheduled to be sold at Sheriff's Sale on, March 06, 2002 at 10:00 a.m. in the Commissioner's Hearing Room located on the 2nd Floor of the Cumberland County Courthouse, 1 Courthouse Square, Carlisle, Pennsylvania 17013, to enforce the court judgment of $111,893.91 obtained by Conseco Finance Consumer Discount Company f/k/a Green Tree Consumer Discount Company against you. NOTICE OF OWNER'S RIGHTS YOU MAY BE ABLE TO PREVENT THIS SHERIFF'S SALE To prevent this Sheriff's Sale you must take immediate action: 1. The sale will be canceled if you pay to Conseco Finance Consumer Discount Company f/k/a Green Tree Consumer Discount Company the back payments, late charges, costs, and reasonable attorney's fees due. To find out how much you must pay, you may call Terrence J. McCabe, Esquire at (215) 790-1010. 2. You may be able to stop the sale by filing a petition asking the Court to strike or open the judgment, if the judgment was improperly entered. You may also ask the Court to postpone the sale for good cause. 3. You may also be able to stop the sale through other legal proceedings. You may need an attorney to assert your rights. The sooner you contact one, the more chance you will have of stopping the sale. (See the following notice 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 Sheriff's Sale is not stopped, your property will be sold to the highest bidder. You may find out the price bid by calling Terrence J. McCabe, Esquire at (215) 790-1010. 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 on the sale. To find out if this has happened, you may call Terrence J. McCabe, Esquire at (215) 790-1010. 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 a 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. A schedule of distribution will be filed by the Sheriff on a date specified by the Sheriff not later than 30 days after sale. Distribution will be made in accordance with the schedule unless exceptions are filed thereto within 10 days after the filing of the schedule. 7. You may also have other rights and defenses, or ways of getting your real estate back, if you act immediately after the sale. YOU SHOULD TAKE THIS PAPER TO YOUR LAWYER AT ONCE. IF YOU DO NOT HAVE A LAWYER OR CANNOT AFFORD ONE, GO TO OR TELEPHONE THE OFFICE LISTED BELOW TO FIND OUT WHERE YOU CAN GET LEGAL HELP. LAWYER REFERRAL SERVICE COURT ADMINISTRATOR 4TH FLOOR, CUMBERLAND COUNTY COURTHOUSE CARLISLE, PENNSYLVANIA 17013 (717) 240-6200 OR CUMBERLAND COUNTY BAR ASSOCIATION 2 LIBERTY AVENUE CARLISLE, PA 17013 (717) 249-3166 ALL THAT CERTAIN lot or tract of land situate in the Township of Hampden, County of Cumberland, and State of Pennsylvania, more particularly bounded and described as follows according to a survey of Garrit J. Betz, Registered Surveyor, dated January 11, 1971, to wit: BEGINNING at a point on the northern line of Hampden Avenue, said point being by same measured in a southwesterly direction 90.0 feet from the northwest corner of Clearview Drive and Hampden Avenue; thence South 61 degrees 26 minutes West along said northern line of Hampden Avenue a distance of 72.0 feet to a hub; thence North 38 degrees 34 minutes West along the eastern line of lands now or formerly of George D. Sauers a distance of 100.00 feet to an iron pipe; thence North 61 degrees 26 minutes East along the southern line of lands now or formerly of Roger L. Knecht and Jack H. Forten, respectively, a distance of 72.0 feet to a hub; thence South 38 degrees 34 minutes East along the line of adjoiner between Lots Nos. 191 and 192 on the hereinafter mentioned Plan of Lots a distance of 100.0 feet to a hub, the point and place of BEGINNING. BEING Lot No. 191, Block "J" on the Plan of Clearview Farm recorded in the Recorder's Office of Cumberland County, recorded in Plat Book 9, Page 13. HAVING THEREON ERECTED at one story frame dwelling with carport known and numbered as 4603 Hampden Avenue. Parcel #: 10-21-0279-196 WRIT OF EXECUTION and/or ATTACHMENT COMMONWEALTH OF PENNSYLVANIA) NO. 00-611 CIVIL UK TERM COUNTY OF CUMBERLAND) CIVIL ACTION - LAW TO THE SHERIFF OF Cumberland COUNTY: To satisfy the debt, interest and costs due Conseco Finance COnstnner Discount Company F/K/A Green Tree Consumer Discount Company PLAINTIFF(S) from Margaret S. Keever, 4603 Hampden Avenue, Camp Hill, PA 17011 DEFENDANT(S) (1) You are directed to levy upon the property of the defendant(s) and to sell Saa T&,-gal Description (2) You are also directed to attach the property of the defendant(s) not levied upon in the possession of Ilk EE(S) as follows: and, to notify 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 the defendant(s) or otherwise disposing thereof; (3) If property of the defendant(s) notlevieduponan subjectto attachment is found in the possession of anyoneother than a named garnishee, you are directed to notify him/he rthat he/she has been added as a garnishee and is enjoined as above stated,'. Amount Due $111, 893.91 L.L. Interest fran 3/20/00 Due Prothy Atty's Comm Atty Paid Plaintiff Paid $1.00 Other Costs $1015.00 Date: November 6, 2001 Curtis R. Long Prothonotary, Civil Division by _ r _ ? . ? 'lam Deputy REQUESTING PARTY: Name Terrence J. McCabe, Esq. Address: 123 S. Broad St., Suite 2080 Philadelphia, PA 19109 Attorney for: Plaintiff Telephone: 215-790-1010 Supreme Court ID No. 16496 ^i??"°'MN 3Se®sae?9S?S§ila'fuu?f@FI?I'I?d'+9•""""••_• :ems. ? ?_??.zx_ - .. ..._... __......__._...??:;I v REAL ESTATE SALE No. 2-9 On November 20, 2001, the sheriff levied upon the defendant's interest in the real property situated in Hampden Township, Cumberland County, PA, known and numbered as 4603 Hampden Avenue, Camp Hill, and more fully described on Exhibit "A" filed with this writ and by this reference incorporated herein. Date: November 20, 2001 By: qt)4 dvn Real Estate Deputy i t a 65 Z ?, AON A REAI.ISTATE SALE No. 28 z _ -- Writ No. 2880.811 ?=°--- Clvil Term Conseco J Finance Consumer - Discount Competry fflda Green Tree Consumer _ Discount Company °" vs Margaret S Keever -` r MDESCRUMOF, ALL-THAT-CERTAIN lot of tract oFland rtuatc -ln the- Township of Hamden, County; -9 t!<fierla0d,_and State of Pennsylvania, more -particularly bounded and described as follows ,-?Kcordugto a survey of Garriti, Betz, Registered j,Sab;cyor, dated January 11, 197i, to wit; -BEGINNING at a point' od the northern Bne of en Avenae? smd point belag by same _ 9-M-cd-in a'bs bthweslerly direction 90.0 feet R out cnonliwesl comer of Clearview D6ve and g?atno n Avenue; thence south 51 degrees 26 t;nmutes- West along said northern line of =Hampden Avenue a distarice of 72.0 feet to a hub; ?-IneneaNodla 38 degrees 34 minutes West along ?Jhe eastern line of lands now or formerly of corgeD. Scotts a distance of 100.00 feet to an ,?SOmerp' -thence Non6 51 degrees 26 minutes mast along the southern line of lands now or __fom¢erly of Roger L. Knecht and lack H. Forten, cspeAely, a distance of 72.0 feet to a hub; -thence_South 38 degrees 34 minutes East along the line of adjoider betwee t Lots Nos. 191 and -192 co the bacttanfter an afiomd Plan of Lacs a distance of 100.0 feet to a hub, the point and place of BEGINNING. -- ?LBWG Lot No. 191, Block "T" on the Plan of Clearview Farm recorded in the Recorder's Office rof Cumberland County, recorded in Plan Hook 9, ,-.Page 13. - -- - - i!H'VIVG THEREON ERECTED a one story frame-dwel8ng with carport known and numbered -as 4603 Hampden Avenue. =-?PAAF_Ca NO.: 10-21-0279-195 ? s THE PATRIOT NEWS THE SUNDAY PATRIOT NEWS Proof of Publication Under Act No. 587, Approved May 16,1929 Commonwealth of Perinsylvania, County of Dauphin) as Michael Morrow being duly sworn according to law, deposes and says: That he is the Asst. Controller of The Patriot News Co., a corporation organized and existing under the laws of the Commonwealth of Pennsylvania, with its principal office and place of business at 812 to 818 Market Street, in the City of Harrisburg, County of Dauphin, State of Pennsylvania, owner and publisher of The Patriot-News and The Sunday Patriot-News newspapers of general circulation, printed and published at 812 to 818 Market Street, in the City, County and State aforesaid; that The Patriot-News and The Sunday Patriot-News were established March 4th, 1854, and September 18th, 1949, respectively, and all have been continuously published ever since; That the printed notice or publication which is securely attached hereto is exactly as printed and published in their regular daily and/or Sunday/ Metro editions which appeared on the 29th day(s) of January and the 5th and 12th day(s) of February 2002. That neither he nor said Company is interested in the subject matter of said printed notice or advertising, and that all of the allegations of this statement as to the time, place and character of publication are true; and That he has personal knowledge of the facts aforesaid and is duly authorized and empowered to verify this statement on behalf of The Patriot-News Co. aforesaid by virtue and pursuant to a resolution unanimously passed and adopted severally by the stockholders and board of directors of the said Company and subsequently duly recorded in the office for the Recording of Deeds in and for said County of Dauphin in Miscellaneous Book "M", Volume 14, Page 317. 1 ! r ,.n PUBLICATION COPY SAL E#28 ........................................ ? 22nd d of F"r rv 2002 A.D. Notadal Seal Tony L. Rusa@s, Notary Public Hartisburg DaupMn County My Commission Expires June 6,2002 N _ ARY PUBLIC Member, Pennsylvania Association of Names My commission expires June 6, 2002 CUMBERLAND COUNTY SHERIFFS OFFICE CUMBERLAND COUNTY COURTHOUSE CARLISLE, PA. 17013 Statement of Advertising Costs To THE PATRIOT-NEWS CO., Dr. For publishing the notice or publication attached hereto on the above stated dates $ 268.80 Probating same Notary Fee(s) $ 1.50 Total $ 270.30 Publisher's Receipt for Advertising Cost The Patriot News Co., publisher of The Patriot-News and The Sunday Patriot-News, newspapers of general circulation, hereby acknowledge receipt of the aforesaid notice and publication costs and certifies that the same have been duly paid. By .................................................................... REAL ESTATE SALE NO. 28 Wilt No. 2000-611 Civil Conseco Finance Consumer Discount Company f/k/a Green Tree Consumer Discount Company VS. Margaret S. Keever Atty.: Terrence J. McCabe ALL THAT CERTAIN lot or tract of land situate in the Township of Hampden, County of Cumberland, and State of Pennsylvania, more particularly bounded and described as follows according to a survey of Garrit J. Betz, Registered Surveyor, dated January 11, 1971, to wit: BEGINNING at a point on the northern line of Hampden Avenue, said point being by same measured in a southwesterly direction 90.0 feet from the northwest corner of Clearview Drive and Hampden Av- enue; thence South 51 degrees 26 minutes West along said northern line of Hampden Avenue a distance of 72.0 feet to a hub; thence North 38 degrees 34 minutes West along the eastern line of lands now or for- merly of George D. Sauers a dis- tance of 100.00 feet to an iron pipe; thence North 51 degrees 26 min- utes East along the southern line of lands now or formerly of Roger L. Knecht and Jack H. Forten, respec- tively, a distance of 72.0 feet to a hub; thence South 38 degrees 34 minutes East along the line of adjoiner between Lots Nos. 191 and 192 on the hereinafter mentioned Plan of Lots a distance of 100.0 feet to a hub, the point and place of BE- GINNING. BEING Lot No. 191, Block "J" on the Plan of Clearview Farm re- corded in the Recorder's Office of Cumberland County, recorded in Plat Book 9, Page 13. HAVING THEREON ERECTED a one story frame dwelling with car port known and numbered as 4603 Hampden Avenue. Parcel #: 10-21-0279-195. PROOF OF PUBLICATION OF NOTICE IN CUMBERLAND LAW JOURNAL (Under Act No. 587, approved May 16, 1929), P. L.1784 STATE OF PENNSYLVANIA COUNTY OF CUMBERLAND : ss. Roger M Morgenthal, Esquire, Editor of the Cumberland Law Journal, of the County and State aforesaid, being duly sworn, according to law, deposes and says that the Cumberland Law Journal, a legal periodical published in the Borough of Carlisle in the County and State aforesaid, was established January 2, 1952, and designated by the local courts as the official legal periodical for the publication of all legal notices, and has, since January 2, 1952, been regularly issued weekly in the said County, and that the printed notice or publication attached hereto is exactly the same as was printed in the regular editions and issues of the said Cumberland Law Journal on the following dates, viz: JANUARY 25, FEBRUARY 1, 8, 2002 Affiant further deposes that he is authorized to verify this statement by the Cumberland Law Journal, a legal periodical of general circulation, and that he is not interested in the subject matter of the aforesaid notice or advertisement, and that all allegations in the foregoing statements as to time, place and character of publication are true. Roger M. Morgenthal, Editor SWORN TO AND SUBSCRIBED before me this 8 day of FEBRUARY. 2002 ?aLO,?IIS.B,E..SS?^W?ONER, l?bli Nolwy Oadsle INV, V Coun MY Cmk" Expires Abft 5, 2005 McCABE, WEISBERG AND CONWAY, P.C. BY: TERRENCE J. MCCABE, ESQUIRE Identification Number 16496 First Union Building 123 South Broad Street, Suite 2080 Philadelphia, PA 19109 (215) 790-1010 CONSECO FINANCE CONSUMER DISCOUNT COMPANY F/K/A GREEN TREE CONSUMER DISCOUNT COMPANY V. MARGARET S. KEEVER Attorney for Plaintiff CUMBERLAND COUNTY COURT OF COMMON PLEAS NUMBER 2000-611 AFFIDAVIT OF SERVICE I, Terrence J. McCabe, Esquire, attorney for the Plaintiff in the within matter, hereby certify that on the 17th DAY OF JANUARY, 2002, a true and correct copy of the Notice of Sheriffs Sale of Real Property was served on all pertinent lienholder(s) as set forth in the Affidavit Pursuant to 3129 which is attached hereto as Exhibit "A" Copies of the letter and certificate of mailing are also attached hereto, made a part hereof and marked as Exhibit "B." SWORN TO AND SUBSCRIBED BEFORE ME THIS 17th DAY OF JANUARY, 2002. gt *&Lc NOTARY PUBLIC NOTA MICHELLE & HOLACIK I ry PW* City of PI Nade"I&, PhK County Comtniecinn Cxnirac k0nrrh PR 300E MCCABE, WEISBERG AND CONWAY, P.C. BY: TERRENCE J. McCABE, ESQUIRE Identification Number 16496 First Union Building 123 South Broad Street, Suite 2080 Philadelphia, PA 19109 (215) 790-1010 Attorney for Plaintiff CONSECO FINANCE CONSUMER DISCOUNT: CUMBERLAND COUNTY COMPANY F/K/A GREEN TREE CONSUMER: COURT OF COMMON PLEAS DISCOUNT COMPANY V. MARGARET S. KEEVER NUMBER 2000-611 AFFIDAVIT PURSUANT TO RULE 3129 I, Terrence J. McCabe, Esquire, attorney for Plaintiff in the above action, set forth as of the date the Praecipe for the Writ of Execution was filed the following information concerning the real property located at 4603 Hampden Avenue, Camp Hill, PA 17011, a copy of the description of said property is attached hereto and marked Exhibit "A." 1. Name and address of Owner(s) or Reputed Owner(s): Name Address Margaret S. Keever 4603 Hampden Avenue Camp Hill, PA 17011 2. Name and address of Defendant(s) in the judgment: Name Address Margaret S. Keever 4603 Hampden Avenue Camp Hill, PA 17011 3. Name and last known address of every judgment creditor whose judgment is a record lien on the real property to be sold: Name Address NONE 4. Name and address of the last recorded holder of every mortgage of record: Name Address Conseco Finance Consumer Discount f/k/a Green Tree 7360 Kyrene Road Consumer Discount Company Tempe, AZ 85283 Citifinancial f/k/a Commercial Credit Corp. Inc. Successor 8335 Century Park Ct. in interest to Security Suite 200 Pacific Finance Inc. San Die CA 92123 tt? en Shields GREEN TREE RETAIL SERVIC 400 T BINE DRIVE BANK, ONE RAPID CITY, SD 57701 CITIFINANCIAL F/K/A 3401 HARTZDALE DR.,STE 126 COMMERCIAL CREDIT CORP. CAMP HILL, PA 17011 CITIFINANCIAL F/K/A 7467 NEW RIDGE ROAD, STE 222 COMMERCIAL CREDIT CORP. HANOVER, ND 21076 ATTN: DAVID PARKS 5. Name and address of every other person who has any record interest in or record lien on the property and whose interest may be affected by the sale: Name Address None. 6. Name and address of Plaintiff has knowledge who has may be affected by the sale: Name every other person of whom the any interest in the property which Address Occupant(s) Domestic Relations 4603 Hampden Avenue Camp Hill, PA 17011 Cumberland County P.O. Box 320 Carlisle, PA 17015 I verify that the statements made in this Affidavit are true and correct to the best of my personal knowledge or information and belief. I understand that false statements herein are made subject to the penalties of 18 Pa.C.S. Section 4904 relating to unsworn falsification to authorities. January 17, 2002 L (\ (\ Q A 4A, 6 DATE TER N . MCCA E, I Attorney ?- for Plaintiff EX? MCCABE, WEISBERG AND CONWAY, P.C. BY: TERRENCE J. McCABE, ESQUIRE Identification Number 16496 123 South Broad Street, Suite 2080 Philadelphia, Pennsylvania 19109 (215) 790-1010 CONSECO FINANCE CONSUMER DISCOUNT: COMPANY F/K/A GREEN TREE CONSUMER: DISCOUNT COMPANY V. MARGARET S. KEEVER DATE: January 17, 2002 Attorney for Plaintiff CUMBERLAND COUNTY COURT OF COMMON PLEAS NUMBER 2000-611 TO: ALL PARTIES IN INTEREST AND CLAIMANTS NOTICE OF SHERIFF'S SALE OF REAL PROPERTY OWNER(S): Margaret S. Keever PROPERTY: 4603 Hampden Avenue, Camp Hill, PA 17011 IMPROVEMENTS: Residential Dwelling The above-captioned property is scheduled to be sold at the Sheriff's Sale on Wednesday, March 06, 2002 at 10:00 a.m. in the Commissioner's Hearing Room located on the 2nd Floor of the Cumberland County Courthouse, 1 Courthouse Square, Carlisle, Pennsylvania 17013. Our records indicate that you may hold a mortgage or judgments on the property which will be extinguished by the sale. You may wish to attend the sale to protect your interests. A schedule of distribution will be filed by the Sheriff on a date specified by the Sheriff not later than 30 days after sale. Distribution will be made in accordance with the schedule unless exceptions are filed thereto within 10 days after the filing of the schedule. 411319 EXHIBIT iS G:d e(3 `? c?°vra k a ? tiF to CV n? a a tad W G Q -4 ,c N 4 .* V ? N O i l > > y w ??; k `°i I vl G w 1 y 0 7] -i m ?z n3 1 ? ? I I ca LO nn ;P ro?r°?dH O N H 1-4 y H m m s d ro H E m 3 H 13 µ x o n 9 HASO O g w !R ff .? m s=??aP? ?Hv ? ??g3g; gy mP oti^ga 318=a2 ji m3m9 Ea N?>Nmn? S? ?{{ggnna a dd?in?G'3 #?n a3 n9 $Ha m??? o ?am1om I 1 I € ? i f I I // ' d,i I? 6A C C yq m 3 M®06) N?Z I I ttpp I ? i - ' ?10a ??P? i t N?(7 ?z I i I ! I -ti H W a hd o d O xx Z 1-3 rQ H t+] t+] '? Ui H H ? r o Cn H t+] C H tri W 9 cn m co roP- nn rt 0 11 P- a ( t FF, i (D cct w t N• n Y• rt rt P- o ? ° fD aw ` r S n a p rt K5 H < S cn S CT o N a m 0 tm (D N) Fi co 0 N H rYi H (D m w n N n c 'r n o rt N co (D F'- a r nrontj r o a (D Fl. (D W m w H rr m k a n W ¢ ? ra to niF- o a r-r o chi' O H C G to m Agrgi m N qty w ? xxr* ro 0 C) w H G n H (D N It f %a { t:AnIBIT H H rJ H H a m yy z COC w N m [ H _ B td u Pd ti N m r3 H y < :8 n by nw tj H hJ H m y a roN H n. to m °_ qa ¦ n o ? i ? ;0 m im, mn w R 7 o ? STN V n m2 t~ ,m O w ;nA I I 000D0 ? H (D ? w rn 0 O a n m?go " n P) (D m. G] O v 3 & W a ' m (D ? p Ui a m onnn to PC a w V (D (D o ee a n a ° p d dd n ? Ct o sm m 3 s z n m ? - ?a a d d q s s . m m W ?mga$jN m °,m@>ma6i IA?•a ?3 m 3 Td gip` § S e m o rl) M 1a V Di C s Conseco Finance Consumer Discount Co. f/k/a Green Tree Consumer Discount Company -vs- Margaret S. Keever In the Court of Common Pleas of Cumberland County, Pennsylvania No. 2000-611 Civil R. Thomas Kline, Sheriff who being duly sworn according to law, says this writ is returned " terms of sale nor complied with" defendant filed bankruptcy. Sheriff s Costs: Docketing Poundage Posting Bills Advertising Auctioneer Law Library County Mileage Certified Mail Levy Surcharge Law Journal Patriot News Share of Bills 30.00 13.46 15.00 15.00 10.00 .50 1.00 16.12 1.91 15.00 20.00 293.30 261.41 23.53 $ 116 23 Pd by atty 9/21/00 Sworn and Subscribed To Before Me This-Y!t_Day of 2000, A.D. Pro io otary So an9swe R. Thomas Kline, Sheriff By Real Estate Deputy r 1,61D Jam' 101910 McCABE, WEISBERG AND CONWAY, P.C. BY: TERRENCE J. McCABE, ESQUIRE Identification Number 16496 First Union Building 123 South Broad Street, Suite 2080 Philadelphia, PA 19109 (215) 790-1010 Attorney for Plaintiff CONSECO FINANCE CONSUMER DISCOUNT: CUMBERLAND COUNTY COMPANY F/K/A GREEN TREE CONSUMER: COURT OF COMMON PLEAS DISCOUNT COMPANY V. MARGARET S. KEEVER NUMBER 2000-611 AFFIDAVIT PURSUANT TO RULE 3129 I, Terrence J. McCabe, Esquire, attorney for Plaintiff in the above action, set forth as of the date the Praecipe for the Writ of Execution was filed the following information concerning the real property located at 4603 Hampden Avenue, Camp Hill, PA 17011, a copy of the description of said property is attached hereto and marked Exhibit "A." 1. Name and address of Owner(s) or Reputed Owner(s): Name Margaret S. Keever. Address 4603 Hampden Avenue Camp Hill, PA 17011 2. Name and address of Defendant(s) in the judgment: Name Margaret S. Keever Address 4603 Hampden Avenue Camp Hill, PA 17011 S 3. Name and last known address of every judgment creditor whose judgment is a record lien on the real property to be sold: Name NONE Address 4. Name and address of the last recorded holder of every mortgage of record: Name Conseco Finance Consumer Discount f/k/a Green Tree Consumer Discount Company Commercial Credit Corp Address 7360 Kyrene Road Tempe, AZ 85283 To be supplied Citifinancial f/k/a Commercial Credit Corp. Inc. Successor 8335 Century Park Ct. in interest to Security Suite 200 Pacific Finance Inc. San Diego, CA 92123 Attn: Karen Shields 5. Name and address of every other person who has any record interest in or record lien on the property and whose interest may be affected by the sale: Name None. Address 6. Name and address of every other person of whom the Plaintiff has knowledge who has any interest in the property which may be affected by the sale: Name Occupant(s) Domestic Relations Address 4603 Hampden Avenue Camp Hill, PA 17011 Cumberland County P.O. Box 320 Carlisle, PA 17015 I verify that the statements made in this Affidavit are true and correct to the best of my personal knowledge or information and belief. I understand that false statements herein are made subject to the penalties of 18 Pa.C.S. Section 4904 relating to unsworn falsification to authorities. 51a3/W i1CCC DATE TERRENCE J. cCABE, ESQUIRE Attorney for Plaintiff ALL THAT CERTAIN lot or tract of land situate in the Township of Hampden, County of Cumberland, and State of Pennsylvania, more particularly bounded and described as follows according to a survey of Gerrit J. Betz, Registered Surveyor, dated January 11, 1971, to wit: BEGINNING at a point on the northern line of Hampden Avenue, said point being by same measured in a southwesterly direction 90.0 feet from the northwest corner of Clearview Drive and Hampden Avenue; thence South 51 degrees 26 minutes West along said northern line of Hampden Avenue a distance of 72.0 feet to a hub; thence North 38 degrees 34 minutes West along the eastern line of lands now or formerly of George D. Sauers a distance of 100.00 feet to an iron pipe; thence North 51 degrees 26 minutes East along the southern line of lands now or formerly of Roger L. Knecht and Jack H. Forten, respectively, a distance of 72.0 feet to a hub; thence South 38 degrees 34 minutes East along the line of adjoiner between Lots Nos. 191 and 192 on the hereinafter mentioned Plan of Lots a distance of 100.0 feet to a hub, the point and place of BEGINNING. BEING Lot No. 191, Block "J" on the Plan of Clearview Farm recorded in the Recorder's Office of Cumberland County, recorded in Plat Book 9, Page 13. HAVING THEREON ERECTED a one story frame dwelling with car port known and numbered as 4603 Hampden Avenue. Parcel M 10-21-0279-195 McCABE, WEISBERG AND CONWAY, P.C. BY: TERRENCE J. McCABE, ESQUIRE Attorney for Plaintiff Identification Number 16496 First Union Building 123 South Broad Street, Suite 2080 Philadelphia, PA 19109 (215) 790-1010 CONSECO FINANCE CONSUMER DISCOUNT: CUMBERLAND COUNTY COMPANY F/K/A GREEN TREE CONSUMER: COURT OF COMMON PLEAS DISCOUNT COMPANY V. MARGARET S. KEEVER NUMBER 2000-611 NOTICE OF SHERIFF'S SALE OF REAL PROPERTY TO: Margaret S. Keever 4603 Hampden Avenue Camp Hill, PA 17011 Your house (real estate) at 4603 Hampden Avenue, Camp Hill, PA 17011 (more fully described as attached) is scheduled to be sold at Sheriff's Sale on Wednesday, September 6, 2000 at 10:00 a.m. in the Commissioner's Hearing Room located on the 2nd Floor of the Cumberland County Courthouse, 1 Courthouse Square, Carlisle, Pennsylvania 17013, to enforce the court judgment of $111,893.91 obtained by Conseco Finance Consumer Discount Company f/k/a Green Tree Consumer Discount Company against you. NOTICE OF OWNER'S RIGHTS YOU MAY BE ABLE TO PREVENT THIS SHERIFF'S SALE To prevent this Sheriff's Sale you must take immediate action: 1. The sale will be canceled if you pay to Conseco Finance Consumer Discount Company f/k/a Green Tree Consumer Discount Company the back payments, late charges, costs, and reasonable attorney's fees due. To find out how much you must pay, you may call Terrence J. McCabe, Esquire at (215) 790-1010. 2. You may be able to stop the sale by filing a petition asking the Court to strike or open the judgment, if the judgment was improperly entered. You may also ask the Court to postpone the sale for good cause. 3. You may also be able to stop the sale through other legal proceedings. You-may need an attorney to assert your rights. The sooner you contact one, the more chance you will have of stopping the sale. (See the following notice 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 sheriff's Sale is not stopped, your property will be sold to the highest bidder. You may find out the price bid by calling Terrence J. McCabe, Esquire at (215) 790-1010. 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 on the sale. To find out if this has happened, you may call Terrence J. McCabe, Esquire at (215) 790-1010. 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 a 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 real estate. A schedule of distribution of the money bid for your real estate will be filed by the Sheriff on October 6, 2000 . 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 schedule of distribution is wrong) are filed with the Sheriff within ten (10) days after October 6, 2000. 7. You may also have other rights and defenses, or ways of getting your real estate back, if you act immediately after the sale. YOU SHOULD TAKE THIS PAPER TO YOUR LAWYER AT ONCE. IF YOU DO NOT HAVE A LAWYER OR CANNOT AFFORD ONE, GO TO OR TELEPHONE THE OFFICE LISTED BELOW TO FIND OUT WHERE YOU CAN GET LEGAL HELP. LAWYER REFERRAL SERVICE COURT ADMINISTRATOR 4TH FLOOR, CUMBERLAND COUNTY COURTHOUSE CARLISLE, PENNSYLVANIA 17013 (717) 240-6200 OR CUMBERLAND COUNTY BAR ASSOCIATION 2 LIBERTY AVENUE CARLISLE, PA 17013 (717) 249-3166 ? , ALL THAT CERTAIN lot or tract of land situate in the Township of Hampden, County of Cumberland, and State of Pennsylvania, more particularly bounded and described as follows according to a survey of Gerrit J. Betz, Registered Surveyor, dated January 11, 1971, to wit: BEGINNING at a point on the northern line of Hampden Avenue, said point being by same measured in a southwesterly direction 90.0 feet from the northwest corner of Clearview Drive and Hampden Avenue; thence South 51 degrees 26 minutes West along said northern line of Hampden Avenue a distance of 72.0 feet to a hub; thence North 38 degrees 34 minutes West along the eastern line of lands now or formerly of George D. Sauers a distance of 100.00 feet to an iron pipe; thence North 51 degrees 26 minutes East along the southern line of lands now or formerly of Roger L. Knecht and Jack H. Forten, respectively, a distance of 72.0 feet to a hub; thence South 38 degrees 34 minutes East along the line of adjoiner between Lots Nos. 191 and 192 on the hereinafter mentioned Plan of Lots a distance of 100.0 feet to a hub, the point and place of BEGINNING BEING Lot No. 191, Block "J^ on the Plan of Clearview Farm recorded in the Recorder's Office of Cumberland County, recorded in Plat Book 9, Page 13. HAVING THEREON ERECTED a one story frame dwelling with car port known and numbered as 4603 Hampden Avenue. Parcel #: 10-21-0279-195 $107.44 COMMONWEALTH OF PENNSYLVANIA) COUNTY OF CUMBERLAND) TO THE SHERIFF OF Cumberland To satisfy the debt, interest and costs due Conseco Finance Consumer Discount Co. f/k/a Green Tree Consumer Discount Co. oI AIAITICC,Ct from Margaret S. Keever, 4603 Hampden Avenue, Camp Hill, PA 17011 (1) You are directed to levy upon the property of the defendant(s) and to sell See Legal Description WRIT OF EXECUTION and/or ATTACHMENT (2) You are also directed to attach the property of the defendant(s) not levied upon in the possession of GARNISHEE(S) as follows: and to notify the garnishee(s) that: (a) an attachment has been issued; (b) the garnishee(s) is/are enjoined from paying any debt to or for the account of the defendant(s) and from delivering any property of the defendant(s) or otherwise disposing thereof; (9) If property of the defendant(s) not levied upon an subject to attachment is found in the possession of anyone other than a named garnishee, you are directedto notify him/herthat he/she has been added as agarnishee and is enjoined as above stated. Amount Due $111.893.91 Interest from 3/20/00 Atty's Col Atty Paid Plaintiff P Date: NO. 00-611 CIVIL * Term CIVIL ACTION - LAW L.L. Due Prothy $.50 $1.00 Other Costs may 30, 2000 Curtis R. Long Prothonotary, Civil Division Deputy REQUESTING PARTY: Name Terrance J. McCabe, Esq. Address: 123 S. Broad St., Suite 2080 Philadelphia, PA 19109 Attorneyfor: Plaintiff Telephone: 215-790-1010 Supreme Court ID No. 16496 REAL ESTATE SALE jV'o, a? A 2ew-a the sheriff levied upon the defendants Interest in the real property situated in -;I Cumberland County, P2,., Krconrh ?:? numbered as:yla an" ,'as,r i,,;, on Exhibit "A" filed with Jiv, this writ and by this reference incorporated herein. em Cate: G am- %Y. ? vim MCCABE, WEISBERG AND CONWAY, P.C. BY: TERRENCE J. MCCABE, ESQUIRE Identification Number 16496 First Union Building 123 South Broad Street, Suite 2080 Philadelphia, PA 19109 (215) 790-1010 CONSECO FINANCE CONSUMER DISCOUNT COMPANY F/K/A GREEN TREE CONSUMER DISCOUNT COMPANY V. MARGARET S. KEEVER Attorney for Plaintiff CUMBERLAND COUNTY COURT OF COMMON PLEAS NUMBER 2000-611 AFFIDAVIT OF SERVICE I, Terrence J. McCabe, Esquire, attorney for the Plaintiff in the within matter, hereby certify that on the 2"d day of AUGUST, 2000, a true and correct copy of the Notice of Sheriff's Sale of Real Property was served on all pertinent lienholder(s) as set forth in the Affidavit Pursuant to 3129 which is attached hereto as Exhibit "A". Copies of the letter and certificate of mailing are also attached hereto, made a part hereof and marked as Exhibit "B." SWORN TO AND SUBSCRIBED BEFORE ME THIS 2"d DAY OF AUGUST, 2000. r OTARY PUBLIC ;VGTA?tilkl SEAL GLORIA 0 MITCHELL, Notary PUN City of Philadelphia. Phila. County My Commission Expires Jur,e 2. 2 03 ?Q,1KO NZ&- Y. kL C o 9. , TERRENCE J. MICA E, SQUI E McCABE, WEISBERG AND CONWAY, P.C. BY: TERRENCE J. MCCABE, ESQUIRE Identification Number 16496 First Union Building 123 South Broad Street, Suite 2080 Philadelphia, PA 19109 (215) 790-1010 Attorney for Plaintiff CONSECO FINANCE CONSUMER DISCOUNT: CUMBERLAND COUNTY COMPANY F/K/A GREEN TREE CONSUMER: COURT OF COMMON PLEAS DISCOUNT COMPANY V. MARGARET S. KEEVER NUMBER 2000-611 AMENDED AFFIDAVIT PURSUANT TO RULE 3129 I, Terrence J. McCabe, Esquire, attorney for Plaintiff in the above action, set forth as of the date the Praecipe for the Writ of Execution was filed the following information concerning the real property located at 4603 Hampden Avenue, Camp Hill, PA 17011, a copy of the description of said property is attached hereto and marked Exhibit "A." 1. Name and address of Owner(s) or Reputed Owner(s): Name Address Margaret S. Keever 4603 Hampden Avenue Camp Hill, PA 17011 2. Name and address of Defendant(s) in the judgment: Name Address Margaret S. Keever 4603 Hampden Avenue Camp Hill, PA 17011 3. Name and last known address of every judgment creditor whose judgment is a record lien on the real property to be sold: Name Address NONE 4. Name and address of the last recorded holder of every mortgage of record: Name Address Conseco Finance Consumer Discount f/k/a Green Tree 7360 Kyrene Road Consumer Discount Company Tempe, AZ 85283 Citifinancial f/k/a Commercial Credit Corp. Inc. Successor 8335 Century Park Ct. in interest to Security Suite 200 Pacific Finance Inc. San Diego, CA 92123 Attn: Karen Shields GREEN TREE RETAIL SERVICES 1400 TURBINE DRIVE BANK, ONE RAPID CITY, SD 57701 CITIFINANCIAL F/ ,'O1% ZDALE DR.,STE 126 Evula" COMMERCIAL CREDIT P Pn' PA 17011 CITIFINANCIAL F/K/A 7467 NEW RIDGE ROAD, STE 222 COMMERCIAL CREDIT CORP. HANOVER, ND 21076 ATTN: DAVID PARKS 5. Name and address of every other person who has any record interest in or record lien on the property and whose interest may be affected by the sale: Name Address None. 6. Name and address of every other person of whom the Plaintiff has knowledge who has any interest in the property which may be affected by the sale: Name Occupant(s) Address 4603 Hampden Avenue Camp Hill, PA 17011 Domestic Relations Cumberland County P.O. Box 320 Carlisle, PA 17015 I verify that the statements made in this Affidavit are true and correct to the best of my personal knowledge or information and belief. I understand that false statements herein are made subject to the penalties of 18 Pa.C.S. Section 4904 relating to unsworn falsification to authorities. August 1, 2000 t1oS\I l?l Y?1?J?+ DATE RENCE J. C E, E QUIRE Attorney for Plaintiff ai" EXHIBIT 6?AI McCABE, WEISBERG AND CONWAY, P.C. BY: TERRENCE J. McCABE, ESQUIRE Identification Number 16496 123 South Broad Street, Suite 2080 Philadelphia, Pennsylvania 19109 (215) 790-1010 Attorney for Plaintiff CONSECO FINANCE CONSUMER DISCOUNT: CUMBERLAND COUNTY COMPANY F/K/A GREEN TREE CONSUMER: COURT OF COMMON PLEAS DISCOUNT COMPANY V. MARGARET S. KEEVER NUMBER 2000-611 DATE: July 19, 2000 TO: ALL PARTIES IN INTEREST AND CLAIMANTS NOTICE OF SHERIFF'S SALE OF REAL PROPERTY OWNER(S): Margaret S. Keever PROPERTY: 4603 Hampden Avenue, Camp Hill, PA 17011 IMPROVEMENTS: Residential Dwelling The above-captioned property is scheduled to be sold at the Sheriff's Sale on Wednesday, September 6, 2000 at 10:00 a.m. in the Commissioner's Hearing Room located on the 2nd Floor of the Cumberland County Courthouse, 1 Courthouse Square, Carlisle, Pennsylvania 17013. Our records indicate that you may hold a mortgage or judgments on the property which will be extinguished by the sale. You may wish to attend the sale to protect your interests. A schedule of distribution will be filed by the Sheriff on a date specified by the Sheriff not later than 30 days after sale. Distribution will be made in accordance with the schedule unless exceptions are filed thereto within 10 days after the filing of the schedule. EX'HIBIT "B" d u. Y hi T P A T X 'M1 ? m `m g4 D n ¢ ? LS7 ?o L7` s o LU ?' J hers = d ?? ?gtrg p?1? U NLL ^w'%?FJlw ?? N ?m m d R boa o Uj ti LL v'm m B rEa m o`o? a 0 m°c ? m0 @ o tn?o E N_U N L y' Vl N ZZ 4 NN Q ?N m _> 'Y U O N = _ m ? = 2w p m ?. O g O `V ?_ O D an d K ITF y y L t_ -es ? X33 @s ? spp i? mo d LL E E m? m a v u ¢oEW 7 ?p ?L V D nd a j u ? U S{GC,fjl y?c?[??' d (ll n n? y 1 J a (J °v o cJ a 7 D r 1,2Z 97 Y/ „!ijepHxa 1?1 I aI ?, 1 10 1 ^10) "1 1 pI rI r1.21 T1 a_ W??L o??W s E.N 0 EE_°c°cm v?E$Ev ?a€Ag u° E??nci y? G ., c¢ E C N. E$?Em°YNN+ CAC ISO N?cd p O?L??ryN ??EBEE€ O O V ? % c 'gin yyc? G ^-' 0. .Y a S..E .S? C my n--r 9Gp Y?OO$ A aaNE??B, m i€n3E$?'Ci m c d v T w n _s m N ? >Z ? a o U a E ? 2 w m £ m E 0 a d U as m z 2 2 a v 4 s E 9 N t ? G7 A" 35 -_ ??f_'-i' ? r?`?7 -` ?? ' f 'i ?i w ._ ?` ? ' t4 ? TJ ? Y? „? ? ? W ] m C . t Mcr,ABE, WEISBERG AND CONWAY, P.C. BY: TERRENCE J. MCCABE, ESQUIRE Identification Number 16496 First Union Building 123 South Broad Street, Suite 2080 Philadelphia, PA 19109 (215) 790-1010 Attorney for Plaintiff CONSECO FINANCE CONSUMER DISCOUNT CUMBERLAND COUNTY COMPANY F/K/A GREEN TREE CONSUMER COURT OF COMMON PLEAS DISCOUNT COMPANY V. MARGARET S. KEEVER NUMBER 2000-611 AFFIDAVIT OF SERVICE I, Terrence J. McCabe, Esquire, attorney for the Plaintiff in the within matter, hereby certify that on the 19TH day of JULY, 2000, a true and correct copy of the Notice of Sheriff's Sale of Real Property was served on all pertinent lienholder(s) as set forth in the Affidavit Pursuant to 3129 which is attached hereto as Exhibit "A". Copies of the letter and certificate of mailing are also attached hereto, made a part hereof and marked as Exhibit "B." SWORN TO AND SUBSCRIBED BEFORE ME THIS 19TH DAY OF JULY, 2000. 4ARY at - PU I --J? VV NOTARIAL SEAL TRACY, A; RIFF, Notary Public of ,Philadelphia, Phila. County ML mmission Expires Oct. 23, 2000 hQaSUYYAC P Wqa [? TERRENCE J. MICA , E!3QJIIRE MCC-.BE, WEISBERG AND CONWAY, P.C. BY: TERRENCE J. McCABE, ESQUIRE Identification Number 16496 First Union Building 123 South Broad Street, Suite 2080 Philadelphia, PA 19109 (215) 790-1010 CONSECO FINANCE CONSUMER DISCOUNT: COMPANY F/K/A GREEN TREE CONSUMER: DISCOUNT COMPANY V. MARGARET S. KEEVER Attorney for Plaintiff CUMBERLAND COUNTY COURT OF COMMON PLEAS NUMBER 2000-611 AFFIDAVIT PURSUANT TO RULE 3129 I, Terrence J. McCabe, Esquire, attorney for Plaintiff in the above action, set forth as of the date the Praecipe for the Writ of Execution was filed the following information concerning the real property located at 4603 Hampden Avenue, Camp Hill, PA 17011, a copy of the description of said property is attached hereto and marked Exhibit "A." 1. Name and address of Owner(s) or Reputed Owner(s): Name Address Margaret S. Keever 4603 Hampden Avenue Camp Hill, PA 17011 2. Name and address of Defendant(s) in the judgment: Name Address Margaret S. Keever 4603 Hampden Avenue Camp Hill, PA 17011 3. Name and last known address of every judgment creditor whose judgment is a record lien on the real property to be sold: Name Address NONE 4. Name and address of the last recorded holder of every mortgage of record: Name Conseco Finance Consumer Discount f/k/a Green Tree Consumer Discount Company Address 7360 Kyrene Road Tempe, AZ 85283 Commercial Credit Corp To be supplied Citifinancial f/k/a Commercial Credit Corp If d1b Century Park Ct. in interest te 200 Pacific Fin e San Diego, CA 92123 Attn: Karen Shields 5. Name and address of every other person who has any record interest in or record lien on the property and whose interest may be affected by the sale: Name Address None. 6. Name and address of every other person of whom the Plaintiff has knowledge who has any interest in the property which may be affected by the sale: Name Occupant(s) Address 4603 Hampden Avenue Camp Hill, PA 17011 Domestic Relations Cumberland County P.O. Sox 320 Carlisle, PA 17015 I verify that the statements made in this Affidavit are true and correct to the best of my personal knowledge or information and belief. I understand that false statements herein are made subject to the penalties of 18 Pa.C.S. Section 4904 relating to unsworn falsification to authorities. July 19, 2000 Jn A&UaIL ? ( _qJ/r_ e DATE TERRENCE J. Mc0 E, ESQUIRE Attorney for Plaintiff EXHIBIT "A" MCCABE, WEISBERG AND CONWAY, P.C. BY: TERRENCE J. McCABE, ESQUIRE Identification Number 16496 123 South Broad Street, Suite 2080 Philadelphia, Pennsylvania 19109 (215) 790-1010 CONSECO FINANCE CONSUMER DISCOUNT: COMPANY F/K/A GREEN TREE CONSUMER: DISCOUNT COMPANY V. MARGARET S. KEEVER DATE: July 19, 2000 Attorney for Plaintiff CUMBERLAND COUNTY COURT OF COMMON PLEAS NUMBER 2000-611 TO: ALL PARTIES IN INTEREST AND CLAIMANTS NOTICE OF SHERIFF'S SALE OF REAL PROPERTY OWNER(S): Margaret S. Keever PROPERTY: 4603 Hampden Avenue, Camp Hill, PA 17011 IMPROVEMENTS: Residential Dwelling The above-captioned property is scheduled to be sold at the Sheriff's Sale on Wednesday, September 6, 2000 at 10:00 a.m. in the Commissioner's Hearing Room located on the 2nd Floor of the Cumberland County Courthouse, 1 Courthouse Square, Carlisle, Pennsylvania 17013. Our records indicate that you may hold a mortgage or judgments on the property which will be extinguished by the sale. You may wish to attend the sale to protect your interests. A schedule of distribution will be filed by the Sheriff on a date specified by the Sheriff not later than 30 days after sale. Distribution will be made in accordance with the schedule unless exceptions are filed thereto within 10 days after the filing of the schedule. EXHIBIT "B" --------.-.--_._...._-- ael't a° w Y31 A W N O CO W V O) v A w N s w oaz a 3 ? 3 9 ? Y D? ® 7 a 3 }(c?? F ay a d ? 3 ® l: (. ,r c y n O= c Igo r rot o4l, 5 - r AO Cdr; T 9 n ? ? mlJ? Dn 0 mm , N x(66 wwm b ?o 3 EIA ?3 a v N w x m C ? ? w a m n ? n sNw w n o . Do 5- m= 0o ??m s m wOV o m' °o sw wa N `2? d NaN w G N(w x Off _ , N R ?InHPW'?? D T m O-D owl wNO - ?? N6ma cc'm wG P _ d & wd_N ni N N w , yN N W C n? Q d? N00 Cm? w^ ?N O A F n m FC c °o'm?3gm? z 000 1pOC N O c nmD y as -v a jn m•D ? Y. m " AN q o? ?i6a ? i Om N N °-'w3 my $ ?g ? y o?? OT ^u' `?mm TD O. mm.m ?. o ??' ?vo ?D d a?Li w Ny'3N? C A M I T41 ? V06 I j ?Ww ? w0 N _, u?c w ° O, + 3 m 3 °n $ 3 ? 3 - Ttn n m a m ? a 3 ?/ -;-? m= 3 eg?2g m HO yN 6 806001' r.... N mop>>3 ? ?LO??? oast?nr ? ry. 90 %? ncE6>> d , ? m mr r. 39t/1SOd'S'II c r r c. C:i c _°7 IN THE COURT OF am" PLEAS OF CCtmmAm COUNTY, PH*ISYLVANIA. CIVIL DIVISION - Conseco Finance Consumer Discount Co. File No. 00-611 f/k/a Green Tree Consumer Discount Co. . Amount Due $111,893.91 V. Margaret S. Keever Interest from 3/20/00 Atty's Comm Costs $1,015.00 TO THE PROTHONOTARY OF THE SAID COURT: The undersigned hereby certifies that the below does not arise out of a retail installment sale, contract, or account based on a confession of judgment, but if it does, it is based on the appropriate original proceeding filed pursuant to Act 7 of 1966 as amended; and for real property pursuant to Act 6 of 1974 as amended. PRABCIPE FOR EXECUTION Issue writ of execution in the above matter to the Sheriff of County, for debt, interest and costs upon the following described property of the defendant(s) 4603 Hampden Avenue, Camp Hill, PA 17011 (more fully described as attached) PRABCIPE FOR ATTACIME EXEC ON Issue writ of attachment to the Sheriff of N/A County, for debt, interest and costs, as above, directing attachment against the above-named garnishee(s) for the following property (if real estate, supply six copies of the description; supply four copies of lengthy personalty list) and all other property of the defendant(s) in the possession, custody or control of the said garnishee(s). (Indicate) Index this writ against the garnishee(s) as a lis pendens against real estate of the defendant(s) described in the attached exhibit. DATE: 5LA310U Signature: ?QtiLf?n ?-+r7 C Print Name: Terrence J. McCabe, Esq. Address: 123 S. Broad St., Suite 2080 Philadelphia, PA 19109 Attorney for: Plaintiff Telephone: 215-790-1010 Supreme Court ID No.: 16496 P. Notes: If real property, supply six copies of description including improvements and an original and copy of affidavit of ownership (PaR.C.P. No. 3129). If lengthy personalty list, supply four copies of list. To index writ, file separate praecipe with writ. ALL THAT CERTAIN lot or tract of land situate in the Township of Hampden, County of Cumberland, and State of Pennsylvania, more particularly bounded and described as follows according to a survey of Gerrit J. Betz, Registered Surveyor, dated January 11, 1971, to wit: BEGINNING at a point on the northern line of Hampden Avenue, said point being by same measured in a southwesterly direction 90.0 feet from the northwest corner of Clearview Drive and Hampden Avenue; thence South 51 degrees 26 minutes West along said northern line of Hampden Avenue a distance of 72.0 feet to a hub; thence North 38 degrees 34 minutes West along the eastern line of lands now or formerly of George D. Sauers a distance of 100.00 feet to an iron pipe; thence North 51 degrees 26 minutes East along the southern line of lands now or formerly of Roger L. Knecht and Jack H. Forten, respectively, a distance of 72.0 feet to a hub; thence South 38 degrees 34 minutes East along the line of adjoiner between Lots Nos. 191 and 192 on the hereinafter mentioned Plan of Lots a distance of 100.0 feet to a hub, the point and place of BEGINNING. BEING Lot No. 191, Block "J" on the Plan of Clearview Farm recorded in the Recorder's Office of Cumberland County, recorded in Plat Book 9, Page 13. HAVING THEREON ERECTED a one story frame dwelling with car port known and numbered as 4603 Hampden Avenue. ParcelM 10-21-0279-195 rj- g ? ? t 1 bJ r e) 3 1 ? ? p m ? o -r; a? k D MCCABE, WEISBERG AND CONWAY, P.C. BY: TERRENCE J. MCCABE, ESQUIRE Identification Number 16496 First Union Building 123 South Broad Street, Suite 2080 Philadelphia, PA 19109 (215) 790-1010 CONSECO FINANCE CONSUMER DISCOUNT: COMPANY F/K/A GREEN TREE CONSUMER: DISCOUNT COMPANY V. MARGARET S. KEEVER Attorney for Plaintiff CUMBERLAND COUNTY COURT OF COMMON PLEAS NUMBER 2000-611 AFFIDAVIT PURSUANT TO RULE 3129 I, Terrence J. McCabe, Esquire, attorney for Plaintiff in the above action, set forth as of the date the Praecipe for the Writ of Execution was filed the following information concerning the real property located at 4603 Hampden Avenue, Camp Hill, PA 17011, a copy of the description of said property is attached hereto and marked Exhibit "A." 1. Name and address of Owner(s) or Reputed Owner(s): Name Margaret S. Keever Address 4603 Hampden Avenue Camp Hill, PA 17011 2. Name and address of Defendant(s) in the judgment: Name Margaret S. Keever Address 4603 Hampden Avenue Camp Hill, PA 17011 3. Name and last known address of every judgment creditor whose judgment is a record lien on the real property to be sold: Name Address NONE 4. Name and address of the last recorded holder of every mortgage of record: Name Conseco Finance Consumer Discount f/k/a Green Tree Consumer Discount Company Address 7360 Kyrene Road Tempe, AZ 85283 Commercial Credit Corp To be supplied Citifinancial f/k/a Commercial Credit Corp. Inc. Successor 8335 Century Park Ct. in interest to Security Suite 200 Pacific Finance Inc. San Diego, CA 92123 Attn: Karen Shields 5. Name and address of every other person who has any record interest in or record lien on the property and whose interest may be affected by the sale: Name Address None. 6. Name and address of every other person of whom the Plaintiff has knowledge who has any interest in the property which may be affected by the sale: Name Occupant(s) Address 4603 Hampden Avenue Camp Hill, PA 17011 Domestic Relations Cumberland County P.O. Box 320 Carlisle, PA 17015 I verify that the statements made in this Affidavit are true and correct to the best of my personal knowledge or information and belief. I understand that false statements herein are made subject to the penalties of 18 Pa.C.S. Section 4904 relating to unsworn falsification to authorities. gl a 3/00 r c r_ v l°t c ce2 DATE TERRENCE S. cCABE, ESQUIRE Attorney for Plaintiff ALL THAT CERTAIN lot or tract of land situate in the Township of Hampden, County of Cumberland, and State of Pennsylvania, more particularly bounded and described as follows according to a survey of Gerrit J. Betz, Registered Surveyor, dated January 11, 1971, to wit: BEGINNING at a point on the northern line of Hampden Avenue, said point being by same measured in a southwesterly direction 90.0 feet from the northwest corner of Clearview Drive and Hampden Avenue; thence South 51 degrees 26 minutes West along said northern line of Hampden Avenue a distance of 72.0 feet to a hub; thence North 38 degrees 34 minutes West along the eastern line of lands now or formerly of George D. Sauers a distance of 100.00 feet to an iron pipe; thence North 51 degrees 26 minutes East along the southern line of lands now or formerly of Roger L. Knecht and Jack H. Forten, respectively, a distance of 72.0 feet to a hub; thence South 38 degrees 34 minutes East along the line of adjoiner between Lots Nos. 191 and 192 on the hereinafter mentioned Plan of Lots a distance of 100.0 feet to a hub, the point and place of BEGINNING. BEING Lot No. 191, Block "J" on the Plan of Clearview Farm recorded in the Recorder's Office of Cumberland County, recorded in Plat Book 9, Page 13. HAVING THEREON ERECTED a one story frame dwelling with car port known and numbered as 4603 Hampden Avenue. Parcel #: 10-21-0279-195 O 7 t0 ..? "'-McCABE, WEISBERG AND CONWAY, P.C. BY: TERRENCE J. McCABE, ESQUIRE Attorney for Plaintiff Identification Number 16496 First Union Building 123 South Broad Street, Suite 2080 Philadelphia, PA 19109 (215) 790-1010 CONSECO FINANCE CONSUMER DISCOUNT: CUMBERLAND COUNTY COMPANY F/K/A GREEN TREE CONSUMER: COURT OF COMMON PLEAS DISCOUNT COMPANY V. MARGARET S. KEEVER NUMBER 2000-611 NOTICE OF SHERIFF'S SALE OF REAL PROPERTY TO: Margaret S. Keever 4603 Hampden Avenue Camp Hill, PA 17011 Your house (real estate) at 4603 Hampden Avenue, Camp Hill, PA 17011 (more fully described as attached) is scheduled to be sold at Sheriff's Sale on Wednesday, September 6, 2000 at 10:00 a.m. in the Commissioner's Hearing Room located on the 2nd Floor of the Cumberland County Courthouse, 1 Courthouse Square, Carlisle, Pennsylvania 17013, to enforce the court judgment of $111,893.91 obtained by Conseco Finance Consumer Discount Company f/k/a Green Tree Consumer Discount Company against you. NOTICE OF OWNER'S RIGHTS YOU MAY BE ABLE TO PREVENT THIS SHERIFF'S SALE To prevent this Sheriff's Sale you must take immediate action: 1. The sale will be canceled if you pay to Conseco Finance Consumer Discount Company f/k/a Green Tree Consumer Discount Company the back payments, late charges, costs, and reasonable attorney's fees due. To find out how much you must pay, you may call Terrence J. McCabe, Esquire at (215) 790-1010. 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. p' 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 the following notice 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 Sheriff's Sale is not stopped, your property will be sold to the highest bidder. You may find out the price bid by calling Terrence J. McCabe, Esquire at (215) 790-1010. 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 on the sale. To find out if this has happened, you may call Terrence J. McCabe, Esquire at (215) 790-1010. 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 a 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 real estate. A schedule of distribution of the money bid for your real estate will be filed by the Sheriff on October 6, 2000 . 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 schedule of distribution is wrong) are filed with the Sheriff within ten (10) days after October 6, 2000. 7. You may also have other rights and defenses, or ways of getting your real estate back, if you act immediately after the sale. YOU SHOULD TAKE THIS PAPER TO YOUR LAWYER AT ONCE. IF YOU DO NOT HAVE A LAWYER OR CANNOT AFFORD ONE, GO TO OR TELEPHONE THE OFFICE LISTED BELOW TO FIND OUT WHERE YOU CAN GET LEGAL HELP. LAWYER REFERRAL SERVICE COURT ADMINISTRATOR 4TH FLOOR, CUMBERLAND COUNTY COURTHOUSE CARLISLE, PENNSYLVANIA 17013 (717) 240-6200 OR CUMBERLAND COUNTY BAR ASSOCIATION 2 LIBERTY AVENUE CARLISLE, PA 17013 (717) 249-3166 ? O .?•C7 S+ n O w q .r +j '!T 4.3 C,3 J 1 OFFICE OF THE PROTHONOTARY COURT OF COMMON PLEAS CUMBERLAND COUNTY COURTHOUSE, CARLISLE, PA 17013 Curtis R. Long Prothonotary To: Margaret S. Keever 4603 Hampden Avenue Camp Hill, PA 17011 Conseco Finance Consumer Discount Company f/k/a Green Tree Consumer Discount Company V. Margaret S. Keever CUMBERLAND COUNTY COURT OF COMMON PLEAS NUMBER 2000-611 NOTICE Pursuant to Rule 236, you are hereby notified that a JUDGMENT has been entered in the above proceeding as indicated below. Curtis R. Long Prothonotary X Judgment by Default Money Judgment Judgment in Replevin Judgment for Possession If you have any questions concerning this Judgment, please call Terrence J. McCabe, Escruire at (215) 790-1010. McCABE, WEISBERG AND CONWAY, P.C. BY: TERRENCE J. McCABE, ESQUIRE Attorney for Plaintiff Identification Number 16496 First Union Building 123 South Broad Street, Suite 2080 Philadelphia, PA 19109 (215) 790-1010 Conseco Finance Consumer CUMBERLAND COUNTY Discount Company f/k/a Green COURT OF COMMON PLEAS Tree Consumer Discount Company V. Margaret S. Keever NUMBER 2000-611 ASSESSMENT OF DAMAGES AND ENTRY OF JUDGMENT TO THE PROTHONOTARY: Kindly enter judgment by default in favor of Plaintiff and against Defendant in the above-captioned matter for failure to answer Complaint as required by Pennsylvania Rules of Civil Procedure and assess damages as follows: Principal $109,481.87 Interest from 12/18/99 through 3/20/00 $ 2,412.04 TOTAL $111,893.91 TERRENCE J. cCABE, E IRE AND NOW, this day of , 2000, Judgment is entered in favor of Plaintiff, Conseco Finance Consumer Discount Company f/k/a Green Tree Consumer Discount Company and against Defendant Margaret S. Keever and damages are assessed in the amount of $111,893.91, plus interest and costs. BY THE PROTHONOTARY: MCCABE, WEISBERG AND CONWAY, P.C. BY: TERRENCE J. MCCABE, ESQUIRE Identification Number 16496 First Union Building 123 South Broad Street, Suite 2080 Philadelphia, PA 19109 (215) 790-1010 Attorney for Plaintiff Conseco Finance Consumer CUMBERLAND COUNTY Discount Company f/k/a Green COURT OF COMMON PLEAS Tree Consumer Discount Company V. Margaret S. Keever NUMBER 2000-611 AFFIDAVIT OF NON-MILITARY SERVICE COMMONWEALTH OF PENNSYLVANIA: SS. COUNTY OF PHILADELPHIA The undersigned, being duly sworn according to law, deposes and says that the Defendant is 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; and that the Defendant, Margaret S. Keever, is over eighteen (18) years of age, and resides at 4603 Hampden Avenue, Camp Hill, PA 17011. SWORN TO AND SUBSCRIBED BEFORE ME THIS CW? '- DAY OF Halm 2000. NOTARY P LIC ? npzq? "- & (-, TE TERRENCE J. MCCABE, UIRE Attorney for Plaintiff NOTARIAL SEAL TRACY A. RIFF, Notary Public City of Philadelphia, Phila. County MY Commission Expires Oct. 23, 2000 McCABE, WEISBERG AND CONWAY, P.C. BY: TERRENCE J. MCCABE, ESQUIRE Identification Number 16496 First Union Building 123 South Broad Street, Suite 2080 Philadelphia, PA 19109 (215) 790-1010 Conseco Finance Consumer Discount Company f/k/a Green Tree Consumer Discount Company V. Margaret S. Keever Attorney for Plaintiff CUMBERLAND COUNTY COURT OF COMMON PLEAS NUMBER 2000-611 Terrence J. McCabe, Esquire, attorney for Plaintiff, being duly sworn according to law, deposes and says that he deposited in the United States Mail a letter notifying the Defendant that judgment would be entered against him/her within ten (10) days from the date of said letter in accordance with Rule 237.5 of the Pennsylvania Rules of Civil Procedure. A copy of said letter is attached hereto and marked as Exhibit "A." SWORN TO AND SUBSCRIBED BEFORE ME THIS L_9/S>_ DAY OF M,vak, , 2000. //l TERRENCE J. cCABE, ESQUIRE Attorney for Plaintiff NOTARY BLIC NOTARIAL SEAL TRACY A. RIFF, Notary Public City of Philadelphia, Phila. County MY Commission Expires Oct. 23, 2000 VERIFICATION The undersigned, TERRENCE J. McCABE, ESQUIRE, hereby certifies that he is the attorney for the Plaintiff in the within action and that he is authorized to make this verification and that the foregoing facts are true and correct to the best of his knowledge, information and belief and further states that false statements herein are made subject to the penalties of 18 PA.C.S. Section 4909 relating to unsworn falsification to authorities. TERRENCE J. MCCABE, SQUIRE OFFICE OF THE PROTHONOTARY COURT OF COMMON PLEAS CUMBERLAND COUNTY COURTHOUSE, CARLISLE, PA 17013 LAWRENCE E. WELKER Prothonotary To: Margaret S. Keever 4603 Hampden Avenue Camp Hill, PA 17011 February 29, 2000 Conseco Finance Consumer CUMBERLAND COUNTY Discount Company f/k/a Green COURT OF COMMON PLEAS Tree Consumer Discount Company V. Margaret S. Keever NUMBER 2000-611 NOTICE, RULE 237.5 NOTICE OF PRAECIPE TO ENTER JUDGMENT BY DEFAULT IMPORTANT NOTICE You are in default because you have failed toy 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: Court Administrator Cumberland County Courthouse Carlisle, PA 17013 (717) 240-6200 NOTIFICACION IMPORTANTE Usted as encuentra an estado de rebeldia por no haber presentado una comparecencia escrita, ya sea persona Lmente o por abogado y por no haber radicado por escrito con este Tribunal sus defenses u objeciones a Los recLemos formulados an contra suyo. At no tomar to action debida dentro de diez (10) dias de la fecha de esta notification, at Tribunal podra, sin necesidad de comperecer usted an torte u oir preuba aLguna, dictar sentencia an su contra y usted podrie perder bienes u otros derechos importantes. Debe LLevar esta notification a un abogado inmediatamente. Si usted no tiene abogado, o si no tiene dinero suficiente pars tat servicio, vaya an persona o items por tetefono a Is oficina, nombrada pars averiguar si puede consegufr asistencia Legal. Court Administrator Cumberland County Courthouse Carlisle, PA 17013 (717) 240-6200 If you have any questions concerning this notice, please call: Terrence J. McCabe, Esquire McCABE, WEISBERG AND CONWAY, P.C. First Union Building 123 South Broad Street, Suite 2080 Philadelphia, Pennsylvania 19109 TJM/tr at this telephone number: (215) 790-1010 EXHIBIT "A. a.r Q? J c+ ?C) ?c na -? m SV L7'Y' y :n cn SHERIFF'S RETURN - REGULAR CASE NO: 2000-00611 P COMMONWEALTH OF PENNSYLVANIA: COUNTY OF CUMBERLAND CONSECO FINANCE CONSUMER DIS VS KEEVER MARGARET S J. MICHAEL ICKES Sheriff or Deputy Sheriff of Cumberland County, Pensylvania, who being duly sworn according to law, says, the within COMPLAINT - MORT FORE was served upon KEEVER S the DEFENDANT , at 0012:50 HOURS, on the 7th day of February , 2000 at 4603 HAMPDEN AVE CAMP HILL, PA 17011 by handing to STEVEN KEEVER (ADULT SON) a true and attested copy of COMPLAINT - MORT FORE together with NOTICE and at the same time directing His attention to the contents thereof. Sheriff's Costs: Docketing 18.00 Service 7.44 Affidavit .00 Surcharge 10.00 .00 35.44 Sworn and subscribed to before 4,- me this .24 - day of 7c? ;2 OZ-6 A. D. 9 JProthonotary T? So Answers: 2 R. Thomas Kline 02/09/2000 MCCABE, WEISBERG & CONWAY By: Deputy Sheriff McCABE, WEISBERG AND CONWAY, P.C. BY: TERRENCE J. MCCABE, ESQUIRE Identification Number 16496 First Union Building 123 South Broad Street, Suite 2080 Philadelphia, Pennsylvania 19109 (215) 790-1010 Conseco Finance Consumer Discount company f/k/a Green Tree Consumer Discount Company 7360 Kyrene Road Tempe, AZ 85283 V. Margaret S. Keever 4603 Hampden Avenue Camp Hill, PA 17011 Attorney for Plaintiff Cumberland County Court of Common Pleas Number a©00 /? l to; ?7 CIVIL AA TI?RTGAGE FORECLOSURE NOTICE You have been sued in court. If you wish to defend against the claims set forth in the following pages, you must take action within twenty (20) days after this complaint and notice are served, by entering a written appearance personally or by 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 HELP. Cumberland County Bar Association 2 Liberty Avenue Carlisle, PA 17013 (717) 249-3166 AVISO Le hen demandado a usted an is torte. Si usted quiere defenderse de sates demandas ex-puestas an Los paginas siguientes, usted tfene veinte (20) dies de plaza at partir de Is fecha de Is demands y to notificacion. Race fatta asentar una comparencie escrita o an persona o can un abogado y entregar a la torte en forma escrita sus defenses o sus objectones a les demandas an contra de su persona. Sea avisado qua sf usted no se defiende, Is torte tomara medidas y puede continuer to demands an contra suya sfn previo aviso a notificacion. Ademas, to carte puede decidir a favor del demandante y requiere qua usted cumpla con todes [as provisions de esta demands. Usted puede perder dinero o sus propfedades u otros derechos importantes pare usted. LLEVE ESTA DEMANDA A UN ABOGADO INMEDIATAMENTE. SI NO TIENE ABOGADO 0 SI NO TIENE EL DEJERO SUFICIENTE DE PAGAR TAL SERVICO, VAYA EN PERSONA O LLAME POR TELEFONO A LA OFICINA CUYA DIRECCION SE ENCUENTRA ESCRITA ABAJO PARA AVERIGUAR DONDE SE PUEDE CONSEGUIR ASISTENCIA LEGAL. Cumberland County Bar Association 2 Liberty Avenue Carlisle, PA 17013 (717) 249-3166 McCABE, WEISBERG AND CONWAY, P.C. BY: TERRENCE J. McCABE, ESQUIRE Identification Number 16496 First Union Building 123 South Broad Street, Suite 2080 Philadelphia, Pennsylvania 19109 (215) 790-1010 Conseco Finance Consumer Discount Company, f/k/a Green Tree Consumer Discount Company 7360 Kyrene Road Tempe, AZ 85283 Attorney for Plaintiff Cumberland County Court of Common Pleas V. Margaret S. Keever 4603 Hampden Avenue Camp Hill, PA 17011 Number CIVIL ACTION/MORTGAGE FORECLOSURE 1. Plaintiff is Conseco Finance Consumer Discount Company, f/k/a Green Tree Consumer Discount Company, a corporation duly organized and doing business at the above captioned address. 2. The Defendant is Margaret S. Keever, who is the mortgagor and real owner of the mortgaged property hereinafter described, and her last-known address is 4603 Hampden Avenue, Camp Hill, PA 17011. 3. On August 7, 1997, mortgagor 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 1398, Page 847. 4. The premises subject to said mortgage is described in the mortgage attached as Exhibit "A" and is known as 4603 Hampden Avenue, Camp Hill, PA 17011. 5. The mortgage is in default because monthly payments of principal and interest upon said mortgage due 9/12/99 and each month thereafter are due and unpaid, and by the terms of said mortgage, upon default in such payments for a period of one month, the entire principal balance and all interest due thereon are collectible forthwith. 6. The following amounts are due on the mortgage: Principal Balance $99,454.85 Interest 8/99 through 12/17/99 $ 3,211.79 (Plus $25.66 per diem thereafter) Attorney's Fee $ 4,972.74 Late Charges (8/99 through 12/17/99) $ 1,260.90 Escrow Advances $ 31.59 Cost of Suit $ 225.00 Appraisal Fee $ 125.00 Title Search 8 200.00 GRAND TOTAL $109,481.87 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 based on work actually performed. 8. Notice of Intention to Foreclose as required by Act 6 of 1974 (41 P.S. §403) and notice required by the Emergency Mortgage Assistance Act of 1983 as amended under 12 PA Code Chapter 13, et seq., commonly known as the Combined Notice of Delinquency has been sent to Defendant by certified mail on the date set forth in the true and correct copies of such notices attached hereto as Exhibit 11B. 11 WHEREFORE, Plaintiff demands Judgment against the Defendant in the sum of $109,481.87, together with interest at the rate of $25.66 per diem and other costs and charges collectible under the mortgage and for the foreclosure and sale of the mortgage property. TERRENCE J. Mc E, ESQUIRE Attorney for Plaintiff The undersigned, Harold Williams, verifies that he is a Foreclosure Specialist of the Plaintiff in the within action, Conseco, and is authorized to make this verification and that the foregoing facts are true and correct to the best of his knowledge, information and belief and further states that false statements herein are made subject to the penalties of 18 PA.C.S. §4904 relating to unsworn falsification to authorities. (4,V-0 dwte?? HAROLD WILLIAMS Commonwealth of Pennsylvania Space Above This Line For Recording Data OPEN-END MORTGAGE Applicat1?an ^ 0011000606 This Mortgage secures future advances. 1. DATE AND PARTIES. The date of this Mortgage (Security Instrument) is ,,,August 7, 1997 ................................ patties, their addresses and tax identification numbers, if required, are as follows: MORTGAGOR: Margaret S Keever ? if checked, refer to the attached Addendum incorporated herein, for additional Mortgagors, their acknowledgments. LENDER: Green Tree Consumer Discount Company 3401 Hartzdale Drive, Suite 132 Camp Hill, PA 17011 the and 2. CONVEYANCE. For good and valuable consideration, the receipt and sufficiency of which is acknowlt.?d,'ind t secure the Secured Debt (defined below) and Mortgagor's performance under this Security Instrument, MongafSgraiis -p gains, conveys and mortgages to Lender the following described property: r cr o ra See Exhibit A !`-r Z rl -? O A - v -O OO tV 17 ,C t7 N t n .? o m Co rn n The property is located in ....... Cumberland ..........................................................,,..., at (CODUty) .. 11 .............._._... ..,................... ......,,............ _..?...._.,...................... nnsylvani Pe a........... .. ......... - (Address) (City) (ZIP C e) Together with all rights, easements. appurtenances, royalties, mineral rights. oil and gas rights, all water and Lipari rights, ditches, and water stock and all existing and future improvements, sttucnures, fixtures; and replacements•that'miyn w, or at any time in the future, be part of the real estate described above (all referred to as "Property"). 3. MAXIMUM OBLI TIONL The total amount secured b this Secunt Instrument at an one time -hall not &0 p II1f. principal by y Y exceed $ ................... !.T? ............................ This limitation of amount does not include imerest'and other fees and charges validly made pursuant to this Security Instrument. Also, this limitation does not apply to advances made under the terms of this Security Instrument to protect Lender's security and to perform any of the covenants contained in this Security Instrument. 4. SECURED DEBT AND FUTURE ADVANCES. The term "Secured Debt" is defined as follows: t1. Debt incurred under the terms of all promissory note(s), contract(s), guaranty(s) or other evidence of debt escribed below and all their extensions, renewals. modifications or substitutions. (When referencing the debts bile w it is suggested that you include items such at borrowers' names, note amounts, interest rates, maturin• dares, etc.) Note dated August 7, 1997, between and Margaret S Keever-, for _$100,700.00 maturing,Augusth.:12, 2027.-" PENNSYLVANIA -MORTGAGE INOT FOR FN A. FN F N I K13JV PAci: 0747 rP 1 of 6J '91^94 BaN,„• ?Yerom•. Ine., St. CIaW. MN tl-BOO39T•2]411 rm 0.E- Z la4 tlTp4 B. All future advances from Lender to Mortgagor or other future obligations of Mortgagor to Lender under any promissory note, contract, guaranty, or other evidence of debt executed by Mortgagor in favor of Lender executed after this Security Instrument whether or not this Security Instrument is specifically referenced. If more than one person signs this Security Instrument, each Mortgagor agrees that this Security instrument will secure all fume advances and future obligations that are given to or incurred by any one or more Mortgagor, or any one or more Mortgagor and others. All future advances and other future obligations are secured by this Security Instrument even though all or part may not yet be advanced. All future advances and other future obligations are secured as if made on the date of this Security Instrument. Nothing in this Security Instrument shall constitute a commitment to make additional or future loans or advances in any amount. Any such commitment must be agreed to in a separate writing. C. All obligations Mortgagor owes to Lender, which may later arise, to the extent not prohibited by law, including, but not limited to, liabilities for overdrafts relating to any deposit account agreement between Mortgagor and Lender, D. All additional sums advanced and expenses incurred by Lender for insuring, preserving or otherwise protecting the Property and its value and any other sums advanced and expenses incurred by Lender under the terms of this Security Instrument. This Security Instrument will not secure any other debt if Lender fails to give any required notice of the tight of rescission. 5. PAYMENTS. Mortgagor agrees that all payments under the Secured Debt will be paid when due and in accordance with the terms of the Secured Debt and this Security Instrument. 6. WARRANTY OF TITLE. Mortgagor warrants that Mortgagor is or will be lawfully seized of the estate conveyed by this Security Instrument and has the right to grant, bargain, convey, sell, and mortgage the Property. Mortgagor also warrants that the Property is'unencumbered, except for encumbrances of record. e: 7. PRIOR SECURITY INTERESTS. With regard to any other mortgage, deed of trust, security agreement or othcr lien document that created a prior security interest or encumbrance on the Property, Mortgagor agrees: A. To make_01 payments when due and to perform or comply with all covenants. B. To promptly deliver to Lender any notices that Mortgagor receives from the holder. C. Not to a low any modification or extension of, nor to request any fume advances under any note or agreement secured by the lien document without Lender's prior written consent. 8. CLAIMS AGAINST TITLE. Mortgagor will pay all taxes, assessments, liens, encumbrances, lease payments, ground rents, utilities, and other charges relating to the Property when due. Lender may require Mortgagor to provide to Lender copies of all -notices-that_such-amounts-are-due?and=the=receipts=evidencing-Mortgagors.payment-Nfongagor will.•defend title.-to-the Property against any claims that would impair the lien of this Security Instrument. Mortgagor agrees to assign to Lender, as requested by Lender, any rights, claims or defenses Mortgagor may have against parties who supply labor or materials to maintain or improve the Property. 9. DUE ON SALE OR ENCUMBRANCE. Lender may, at its option, declare the entire balance of the Secured Debt to be immediately due and payable upon the creation of, or contract for the creation of, any lien, encumbrance. transfer or sale of the Property. This right is subject to the restrictions imposed by federal law (12 C.F.R. 591), as applicable. This covenant shall tun with the Property and shall remain in effect until the Secured Debt is paid in full and this Security Insmitnent is released. 10. PROPERTY CONDITION, ALTERATIONS AND INSPECTION. Mortgagor will keep the Property in good condition and snake all repairs that are reasonably necessary. Mortgagor shall not commit to allow any waste, impairment, or deterioration of the Property. Mortgagor will keep the Property free of noxious weeds and grasses. Mortgagor agrees that the nature of the occupancy and use will not substantially change without Lender's prior written consent. Mortgagor will not permit any change in any license, restrictive covenant or easement without Lender's prior written consent. Mortgagor will notify Lender of all demands, proceedings, claims and actions against Mortgagor, and of any loss or damage to the Property. •A •??. i. iv.'a 80o61398ra 848 (page 2of 6) 1994 Da em SYMMm, Inc.. Ss C:46a, MN'?t•900.397-13411 rnm MWT0-PA 17f19194 Lender or Lender's agents may, at Lender's option, enter the Property at any reasonable time for the purpose of inspect rig the Property. Lender shall give Mortgagor notice at the time of or before an inspection specifying a reasonable purpose for the inspection. Any inspection of the Property shall be entirely for Lender's benefit and Mortgagor will in no way rely on Lender's inspection. I 11. AUTHORITY TO PERFORM. If Mortgagor fails to perform any duty or any of the covenants contained in this Security Instrument, Lender may, without notice, perform or cause them to be performed. Mortgagor appoints Lender as attorney in fact to sign Mortgagor's name or pay any amount necessary for performance, Lender's right to perform for Mortgag r shall not create an obligation to perform, and Lender's failure to perform will not preclude Lender from exercising any of L nder's other rights under the law or this Security Instrument. If any construction on the Property is discontinued or not carried on in a reasonable manner, Lender may take all steps necessary to protect Leader's security interest in the Property, ituding completion of the construction. 12. ASSIGNMENT OF LEASES AND RENTS. Mortgagor irrevocably grants, bargains, conveys and mortgages to Lander as additional security all the right, title and interest in and to any and all existing or future leases, subleases. and any other written or verbal agreements for the use and occupancy of any portion of the Property, including any extensions. re wall, modifications or substitutions of such agreements (alf referfed't as'"Leases") and rents, isstieS and profits (all rdfe d to as "Rents"). Mortgagor will promptly provide Lender with true and correct copies of all existing and future Leases. M rtgagor may collect, receive, enjoy and use the Rents so long as Mortgagor is not in default under the terms of this ecuriry Instrument. Mortgagor agrees that this assignment is immediately effective between the parties to this Security Instruntent and effective as to third parties on the recording of this Security instrument, and this assignment will retrain effective until the Obligations are satisfied. Mortgagor agrees that Lender is entitled to notify Mortgagor or Mortgagor's tenants to make payments of Rents due or to become due directly to Lender after such recording, however Lender agrees not to notify Mortgagor's tent{ until Mongagor defaults and Lender notifies Mortgagor of the default and demands drat Mortgagor and Mortgagor's tenants pay all Rents due or to become due directly to Lender, On receiving notice of default, Mortgagor will endorse and deliver to Lender any payment of Rents in Mortgagor's possession and will receive any Rents in trust for Lender and will not commingle the Rents with any other funds. Any amounts collected will be applied as provided in this Security Instrument. Mortgagor yvarrants that no default exists under the Leases or any applicable landlord/tenant law. Mortgagor also agrees to maintain and require any tertant to comply with the terms of the Leases and applicable law. 13. LEASEHOLDS; CONDOMINIIMI ; PLANNED UNIT DEVELOPMENTS. Mortgagor agrees to comply oth the provisions of any lease if this Security Instrument is on a leasehold. If the Property includes a unit in a condomirthrm. or a planned unit development. Mortgagor will perform all of Mortgagor's duties under the covenants, by-laws, or regulations of the condominium or planned unit development, I 14. DEFAULT. Mortgagor will be in default if any party obligated on the Secured Debt fails to main payment when due. ny other dttcumem ex uted for Mongagoi will be in default if a breach occurs under the terms of this Security Instrumem or any-other, the purpose of creating, securing or guarantying the Secured Debt. A good faith belief by Lender that Lender at an? time is insecure with respect to any person or entiry obligated on the Secured Debt or that the prospect of any payment or the value of the Property is impaired shall also constitute an event of default. 15. REMEDIES ON DEFAULT. In some instances, federal and state law will require Lender to provide Mongagor with notice of the right to cure or other notices and may establish time schedules for foreclosure actions. Subject to these lieu tions, if any, Lender may accelerate the Secured Debt and foreclose this Security Instrument in a manner provided by law if ortgagor is in default. At the option of lender. all or any part of the agreed fees and charges, accrued interest and principal shall become ' ed-ately due and payable, after giving notice if required by law, upon the occurrence of a default or anytime thereafter. In addition. Lender shall be entitled to all the remedies provided by law, the terms of the Secured Debt, this Security lnstrumen and any related documents. All remedies are distinct. cumulative and not exclusive, and the Lender is entitled to all remed ics provided at law or egtdry, whether or not expressly set forth. The acceptance by Lender of any sum. in payment or partial pa mom on the Secured Debt after the balance is due or is accelerated or after foreclosure proceedings are filed shall not conctimt a waiver of Lender's right to require complete curer of any existing default. By not exercising any remedy on Mortgagor default. Lender does not waive Leftdel',S'•ri¢littto'tateei,cotisider the evmt,a default if it continues or happens again, 8001(iM PAGE 849 tP I9 9 3 of o! 91994 tlaMers 8yq+m+, Ina, St. GI"utl. MN 11.80"91-23111 Form RE•MT[vP4 12!19!84 16. EXPENSES; ADVANCES ON COVENANTS; ATTORNEYS' FEES; COLLECTION COSTS. Ezcapc when protiibited by law, Mortgagor agrees to pay all of Lender's expenses if Mortgagor breaches any covenant in this Security Instrument. Mortgagor will also pay on demand any amount incurred by Lender for insuring, inspecting, preserving or otherwise protecting the Property and Lender's security interest. These expenses will bear interest from the date of the payment until paid in full at the highest interest rate in effect as provided in the terms of the Secured Debt. Mortgagor agrees to pay all costs and expenses incurred by Lender in collecting, enforcing or protecting Lender's rights and remedies under this Security Instrument. This amount may include, but is not limited to, attorneys' fees, court costs, and other legal expenses. This Security Instrument shall retrain in effect until released. Mortgagor agrees to pay for any recordation costs of such release. 17. ENVIRONMENTAL LAWS AND HAZARDOUS SUBSTANCES. As used in this section, (1) Environmental Law means, without limitation, the Comprehensive Environmental Response, Compensation and Liability Act (CERCLA, 42 U.S.C. 9601 et seq.), and all other federal, state and local laws, regulations, ordinances, court orders, attorney general opinions or interpretive letters concerning the public health, safety, welfare, environment or a hazardous substance: and (2) Hazardous Substance means any toxic, radioactive or hazardous material, waste, pollutant or contaminant which has characteristics which render the substance dangerous or potentially dangerous to the public health, safety, welfare or environment. The term includes, without limitation, any substances defined as "hazardous material," "toxic substances." "hazardous waste' or hazardous, substaNi,," -der any Environmental Law..... Mortgagor represents, warrants and agrees that: A, Except as previously disclosed and acknowledged in writing to Lender, no Hazardous Substance is or will be located. stored or released on or in the Property. This restriction does not apply to small quantities of Hazardous Substances that are generally recognized to be appropriate for the normal use and maintenance of the Property. B. Except as previously disclosed and acknowledged in writing to Lender, Mortgagor and every tenant have been are, and shall remain in full compliance with any applicable Environmental Law. C. Mortgagor shall immediately notify Lender if a release or threatened release of a Hazardous Substance occurs ou, under or about the Property or there is a violation of any Environmental Law concerning the Property. In such an event. Mortgagor shall take all necessary remedial action in accordance with any Environmental Law. D. Mortgagor shall immediately notify Lender in writing as soon as Mortgagor has reason to believe there is any pending or threatened investigation, claim, or proceeding relating to the release or threatened release of any Hazardous Substance or the violation of any Environmental Law. 18. CONDEMNATION. Mortgagor will give Lender prompt notice of any pending or threatened action, by private or public entities to purchase or take any or all of the Property through condemnation, eminent domain, or any other means. Mortgagor authorizes Lender to intervene in Mortgagor's name in any of the above described actions or claims. Mortgagor assigns to Lender the proceeds-of any award or claim-for-damages connected-with-a condemnation or other taking.of all or any parr of.the _ Property. Such proceeds shall be considered payments and will be applied as provided in this Security Instrument. This assignment of proceeds is subject to the terms of any prior mortgage, deed of trust, security agreement or other lien document. 19. INSURANCE. Mortgagor shall keep Property insured against loss by fire, flood, theft and other hazards and risks reasonably associated with the Property due to its type and location. This insurance shall be maintained in the amounts and for the periods that Lender requires. The insurance carrier providing the, insurance shall be chosen by Mortgagor subject to Lender's approval. which shall not be unreasonably withheld. If Mortgagor fails to maintain the coverage described above. Lender may. at Lender's option, obtain coverage to protect Lender's rights in the Property according to the terms of this Security Instrument. All insurance policies and renewals shall be acceptable to Lender and shall include a standard "mortgage clause' and. where applicable, 'loss payee clause." Mortgagor shall immediately notify Lender of cancellation or termination of the insuriuI•e. Lender shall have the right to hold the policies and renewals. If Lender requires, Mortgagor shall immediately give to Lender all receipts of paid premiums and renewal notices. Upon loss, Mortgagor shall give immediate notice to the insurance curter and Lender. Lender may make proof of loss if not made immediately by Mortgagor. soai< M PAG9, 856 gage -of 6; 91899 a"Nns $W... Ina, S1. ClouM* MN p-BG03B,1 23411' Furor AE-MTG-PA 12119/86 Unless otherwise agreed in writing, all insurance proceeds shall be applied to the restoration or repair of the Property orto the Secured Debt, whether or not then due, at Lender's option. Any application of proceeds to principal shall not ext Ind or postpone the due date of the scheduled payment nor change The amount of any payment. Any excess will be paid to the Mortgagor. If the Property is acquired by Lender, Mortgagor's right to any insurance policies and proceeds Tesultin from damage to the Property before the acquisition shall pass to Lender to the extent of the Secured Debt immediately bef re the acquisition. 26. ESCROW FOR TAXES AND INSURANCE. Unless otherwise provided in a separate agreement, Mortgagor will not be required to pay to Lender funds for taxes and insurance in escrow. 21. FINANCIAL REPORTS AND ADDITIONAL DOCUMENTS. Mortgagor will provide to Lender upon requeTa, any financial statement or information Lender may deem reasonably necessary. Mortgagor agrees to sign, deliver, and file any additional documents or certifications that Lender may consider necessary to perfect, continue, and preserve Mortiagoi s obligations under this Security Instrument and Lender's lien status on the Property. 22. JOINT AND INDIVIDUAL LIABILITY; CO-SIGNERS; SUCCESSORS AND ASSIGNS BOUND. All duties under this Security Instrument are joint and individual. If Mortgagor signs &s Security Instrument WE does not sign an evidence f debt. Mortgagor does so only to mortgage Mortgagor's interest in the Property to secure payment of tine Secured D bt and Mortgagor does not agree to be personally liable on the Secured Debt, If this Security Instnnnem secures a guaranty tween Lender and Mortgagor, Mortgagor agrees to waive any rights that may prevent Lender from bringing any action o claim against Mortgagor or any patty indebted under the obligation. These rights may include, but are not limited o, any and-deficiency or one-action laws. Mortgagor agrees that Lender and any party to Us Security Instrument may extend, modify or make any change in the terms of this Security Instrument or any evidence of debt without Mortgagor's consent. Such a change will not release Mortgagor from the terms of this Security Instrument. The dudes and benefits of this ?ecurity instrument shall bind and benefit the successors and assigns of Mortgagor and Lender. 23. APPLICABLE LAW; SEVERABILIPY; INTERPRETATION. This Security Instrument is governed by the la of the jurisdiction in which Lender is located, except to the extent otherwise required by the laws of the jtrrisdicnon w ere the Property is located. This Security Instrument is complete and folly integrated. This Security Instrument may not be am' nded or modified by oral agreement. Any section in this Security Instrument, attachments. or any agreement related to the ecured Debt that conflicts with applicable law will not be effective, unless that law expressly or impliedly permits the varia'ons by written agreement. If any section of this Security Instrument cannot be enforced according to its terms, that section will be severed and will not affect the enforceability of the remainder of this Security Instrument. Whenever used, the singu at shall include the plural and the plural the singular. The captions and headings of the sections of this Security Instrume are for convenience only and are not to be used to. interpret or define the terms of this Security Instrument. Time is of the essence in this Security Instrument. 24. NOTICE. Unless otherwise,required by law, any nodce shall be given by delivering it or by mailing it by first clas mail to the appropriate party's address on page I of this Security Instrument, or to any other address designated'ia writing..,, once to one mortgagor will be deemed to be notice to all mortgagors. `.?`, 25. WAIVERS. Except to the extent prohibited by law, Mortgagor waives any right to appraisementirel' pinto the Property 10 •'n ,'Iti "J1? .............. . Ki398 racy 851 r.= Jr. 5 of 61 V1994 9anken Symems. Ins.. St. Claud. MN 11.900-307.23611 Form HE-MrG.PA 12/19194 _..?...L.... _.._..._ .-. -wnwrwv+ .._ ?Ix?IttYitl i 26. OTHER TERMS. If checked, the following are applicable to this Security Instrument: ? Line of Credit. The Secured Debt includes a revolving line of credit provision. Although the Secured Debt may be reduced to a zero balance, this Security Instrument will remain in effect until released. ? Construction Loan. This Security Instrument secures an obligation incurred for the construction of an improvement on the Property. R1 Fixture Filing. Mortgagor grants to Lender a security interest in all goods That Mortgagor owns now or in the future and that are or will become fixtures related to the Property. This Security Instrument suffices as a financing statement and any carbon, photographic or other reproduction may be filed of record for purposes of Article 9 of the Uniform Commercial Code. ? Purchase Money. This Security Instrument secures advances by Lender used in whole or in par to acquire the Property. Accordingly, this Security Instrument, and the lien hereunder, is and shall be construed as a purchase money mortgage with all of the rights, priorities and benefits thereof under the laws of the Commonwealth of Pennsylvania. ? NOTICE TO BORROWER: THIS DOCUMENT CONTAINS PROVISIONS FOR A VARIABLE INTEREST RATE. ? Riders. The covenants and agreements of each of the riders checked below are incorporated into and supplement and amend the terms of this Security Instrument. [Check all applicable boxes) ? Condominium Rider ? Planned Unit Development Rider ? Other ................................................... ? Additional Terms. SIGNATURES: By signing below, Mortgagor, intending to be legally bound hereby, agrees to the terms and covenants contained in this Security Instrument and in any attachments. Mortgagor also acknowledges receipt of a copy of this Security Instrument on the date stated on page 1. ............................................................... ............. (signature). M rgaret VKeever (Date) (s6-) (Dace) v ................................................ (Witness) (w'itnen) ACKNOWLEDGMENT.- Pennsylvania COMMONWEALTH OF .......................................... UNTY OF .............................. ........... pmh5a9,u On this. the ....7th.........'.... day of .....August........... `3..7.......••, before me .............................. the undersigned officer, Personally appeared . M.....ar.......garet ............................. a Keever ................................................ .......................................................................................... known to me (or satisfactorily proven) to be the person(s) whose name(s) is subscribed to the within instrument, and acknowledged that he/she executed the same for the purposes therein contained. I hereunto set my hand and official seal. It is hereffy 3401 Hart ,-address of the 1 uite i3....3air: DK139$ PAGE 852 rote oe i . Tree Consumer Discount Company :nder within named is... Green . ........................................................................ eburg, PA 17011 ......................................................................................................... .?j 1994 9ant.n syremv, Ire.. St Gl4ul, MN fl -80P397-23413 -80P39r-29411 Form a9•MTG-PA 12/19/94 )Page 6 of 6J \\.. CONSECO. CONSECO FINANCE SERVICING CORP. - 736o S K,vrene Road Tempe, Arizona 85=83-454? Date: December 3, 1999 388-315-8733 ACT 91 NOTICE IMPORTANT: NOTICE OF HOMEOWNERS' EMERGENCY MORTGAGE ASSISTANCE ACT OF 1983 PLEASE READ THIS NOTICE. YOU MAY BE ELIGIBLE FOR FINANCIAL ASSISTANCE TOWARD YOUR MORTGAGE PAYMENTS MARGARET KEEVER 4603 HAMPDEN AVE. CAMP HILL, PA 17011 LoanNo. 6800130020 Date: December 3, 1999 Mortgaged Premises: 4603 HAMPDEN AVE. CAMP HILL, PA 17011 Certified Mail #: Z 235 342 515 FROM: Conseco Finance Consumer Discount Company Social Security No: 186340367 YOUR MORTGAGE IS IN SERIOUS DEFAULT because you have not paid promptly installments of principal and interest and escrow, as required, for a period of at least SIXTY (60) days. The total amount of the delinquency is 4625.9 That sum includes the following: $864.95 due 9/12/99, $83336 & 833.36 due 10/12/99 & 11/12/99, and $833.36 due 12/12/99, plus late charges of $1260.90 and return check fees of $0.00. YOU MAY BE ELIGIBLE FOR FINANCIAL ASSISTANCE THAT WILL PREVENT FORECLOSURE on your mortgage if you comply with the provisions of the HOMEOWNERS' EMERGENCY MORTGAGE ASSISTANCE ACT OF 1983 (the "Act"). You may be eligible for emergency temporary assistance if your default has been caused by circumstances beyond your control, and if you meet the eligibility requirements of the Act as determined by the Pennsylvania Housing Finance Agency. PLEASE READ ALL OF THIS NOTICE. IT CONTAINS AN EXPLANATION OF YOUR RIGHTS. Under the Act, you are entitled to a temporary stay of foreclosure on your mortgage for thirty (30) days from the day of this Notice. During that time you have the right to arrange a "face-to-face" meeting with a representative of this lender, or with a designated consumer credit counseling agency. The purpose of that meeting is to attempt to work out a repayment plan, or to otherwise settle your delinquency. THAT MEETING MUST OCCUR IN THE NEXT THIRTY (30) DAYS. If you attend a face-to-face meeting with this lender, or with a consumer credit counseling agency identified in this notice, no further proceedings in mortgage foreclosure may take place for thirty (30) days after the date of that meeting. The name, address and telephone number of our representative is: Ruth Hernandez Conseco Finance Mortgage Services Division 7360 S Kyrene Road Tempe, AZ 85283 (800) 603-1109 EXHIBIT "B" IN. CONS ECO. CONSECO FINANCE SERVICING CORP. 7 i 6o S Kvrene Road Tempe, Arizona 85z83-4583 888-3 ., t S-87; i The names and addresses of designated consumer credit counseling agencies are on the enclosed list. It is only necessary to schedule one face-to-face meeting. You should advise this lender immediately of your intentions. If you have tried to and are unable to resolve this problem at or after your face-to-face meeting, you have the right to apply for financial assistance from the Homeowners' Emergency Assistance Fund. In order to do this, you must fill out, sign and file a completed Homeowners' Emergency Assistance Application with the Pennsylvania Housing Finance Agency. The consumer credit counseling agency will assist you in filling out your application. IT MUST BE FILED, OR POSTMARKED, WITHIN THIRTY (30) DAYS OF YOUR FACE-TO-FACE MEETING. You must either mail your application to the Pennsylvania Housing Finance Agency, or you must file it at the office of one of the designated consumer credit counseling agencies on the enclosed list. The Pennsylvania Housing Finance Agency is located at: 2101 North Front Street, P. O. Box 8029, Harrisburg, PA 17105. Telephone Number: (717) 780-3800 or 1-800-342-2397 (toll free number). Persons with impaired hearing can call (717) 780-1869. An application for assistance may be obtained from this lender, from a consumer credit counseling agency, or directly from the Pennsylvania Housing Finance Agency. IT IS EXTREMELY IMPORTANT THAT YOU FILE YOUR APPLICATION PROMPTLY. IF YOU DO NOT DO SO, OR IF YOU DO NOT FOLLOW THE OTHER TIME PERIODS SET FORTH IN THIS LETTER, FORECLOSURE MAY PROCEED AGAINST YOUR HOME IMMEDIATELY. Available funds for emergency mortgage assistance are very limited. They will be disbursed by the Agency under the eligibility criteria established by the Act. IT IS EXTREMELY IMPORTANT THAT YOUR APPLICATION IS ACCURATE AND COMPLETE IN EVERY RESPECT. The counseling agency will help you to fill out the application. The Pennsylvania Housing Finance Agency has sixty (60) days to make a decision after it receives your application. During that additional time, no foreclosure proceedings will be pursued against you if you have met the time requirements set forth above. You will be notified directly by that Agency of it's decision on your application. In addition, you will receive another notice from this lender under Act 6 of 1974. That notice is called a "Notice of Intention to Foreclose". You must read both notices since they both explain rights that you now have under Pennsylvania law. However, if you choose to exercise your rights described in this notice, we cannot foreclose upon you during that time. Also, if you receive financial assistance from the Pennsylvania Housing Finance Agency, your home cannot be foreclosed upon while you are receiving assistance. Sincerely, Kelly Holding Mortgage Collections Supervisor Conseco Finance Mortgage Services Division (800) 603-1109 Enclosures: Pennsylvania Consumer Credit Counseling Agency List cc: Customer File o ? ? dd N r., t !' F?3 i :> ? r tX3 MCCABE, WEISBERG AND CONWAY, P.C. BY: TERRENCE J. MCCABE, ESQUIRE Identification Number 16496 First Union Building 123 South Broad Street, Suite 2080 Philadelphia, PA 19109 (215) 790-1010 CONSECO FINANCE CONSUMER DISCOUNT . COMPANY F/K/A GREEN TREE CONSUMER . DISCOUNT COMPANY V. MARGARET S. KEEVER Attorney for Plaintiff CUMBERLAND COUNTY COURT OF COMMON PLEAS NUMBER 2000-611 AFFIDAVIT OF SERVICE I, Terrence J. McCabe, Esquire, attorney for the Plaintiff in the within matter, hereby certify that on the, 25tnDAY OF OCTOBER, 2002, a true and correct copy of the Notice of Sheriff's Sale of Real Property was served on all pertinent lienholder(s) as set forth in the Affidavit Pursuant to 3129 which is attached hereto as Exhibit "A" Copies of the letter and certificate of mailing are also attached hereto, made a part hereof and marked as Exhibit "B." ,- -?o mot TERRET E J. MCCABE, ESQUIRE SWORN TO AND SUBSCRIBED BEFORE ME THIS 25th DAY OF OCTOBER, 2002. X, _G 6 NOTARY PUBLIC WTAR MSEAL ".afCHEtLE A. NOLACIK, Notary Public City of Philadelphia, Phila. Covenryry Cammisslcn E>mares 9??h 28 ?21a0v ? McCABE, WEISBERG AND CONWAY, P.C. BY: TERRENCE J. MCCABE, ESQUIRE Identification Number 16496 First Union Building 123 South Broad Street, Suite 2080 Philadelphia, PA 19109 (215) 790-1010 Attorney for Plaintiff CONSECO FINANCE CONSUMER DISCOUNT: CUMBERLAND COUNTY COMPANY F/K/A GREEN TREE CONSUMER: COURT OF COMMON PLEAS DISCOUNT COMPANY V. MARGARET S. KEEVER NUMBER 2000-611 AFFIDAVIT PURSUANT TO RULE 3129 I, Terrence J. McCabe, Esquire, attorney for Plaintiff in the above action, set forth as of the date the Praecipe for the Writ of Execution was filed the following information concerning the real property located at 4603 Hampden Avenue, Camp Hill, PA 17011, a copy of the description of said property is attached hereto and marked Exhibit "A.° 1. Name and address of Owner(s) or Reputed Owner(s): Name Address Margaret S. Keever 4603 Hampden Avenue Camp Hill, PA 17011 2. Name and address of Defendant(s) in the judgment: Name Address Margaret S. Keever 4603 Hampden Avenue Camp Hill, PA 17011 3. Name and last known address of every judgment creditor whose judgment is a record lien on the real property to be sold: Name Address NONE 4. Name and address of the last recorded holder of every mortgage of record: Name Address Conseco Finance Consumer Discount f/k/a Green Tree 7360 Kyrene Road Consumer Discount Company Tempe, AZ 85283 Citifinancial f/k/a Commercial Credit Corp. Inc. Successor 8335 Century Park Ct. in interest to Security Suite 200 Pacific Finance Inc. San Diego, CA 92123 Attn: Karen Shields GREEN TREE RETAIL SERVICES 1400 TURBINE DRIVE BANK, ONE CITY, SD 57701 EXHIDIT CITIFINANCIAL F/K/A 3401 HARTZDALE DR.,STE 126 COMMERCIAL CREDIT CORP. CAMP HILL, PA 17011 CITIFINANCIAL F/K/A 7467 NEW RIDGE ROAD, STE 222 COMMERCIAL CREDIT CORP. HANOVER, ND 21076 ATTN: DAVID PARKS 5. Name and address of every other person who has any record interest in or record lien on the property and whose interest may be affected by the sale: Name Address None. 6. Name and address of Plaintiff has knowledge who has may be affected by the sale: Name Tenant(s)/Occupant(s) Domestic Relations Commonwealth of Pa Address 4603 Hampden Avenue Camp Hill, PA 17011 Cumberland County P.O. Box 320 Carlisle, PA 17015 Department of Welfare P.O. Box 2675 Harrisburg, Pa 17105 I verify that the statements made in this Affidavit are true and correct to the best of my personal knowledge or information and belief. I understand that false statements herein are made subject to the penalties of 18 Pa.C.S. Section 4904 relating to unsworn falsification to authorities. October 25, 2002 ,I ER M ESQUIRE Attorney for Plaint DATE every other person of whom the any interest in the property which McCABE, WEISBERG AND CONWAY, P.C. BY: TERRENCE J. McCABE, ESQUIRE Identification Number 16496 123 South Broad Street, Suite 2080 Philadelphia, Pennsylvania 19109 (215) 790-1010 CONSECO FINANCE CONSUMER DISCOUNT: COMPANY F/K/A GREEN TREE CONSUMER: DISCOUNT COMPANY V. MARGARET S. KEEVER DATE: October 25, 2002 Attorney for Plaintiff CUMBERLAND COUNTY COURT OF COMMON PLEAS NUMBER 2000-611 TO: ALL PARTIES IN INTEREST AND CLAIMANTS NOTICE OF SHERIFF'S SALE OF REAL PROPERTY OWNER(S): Margaret S. Keever PROPERTY: 4603 Hampden Avenue, Camp Hill, PA 17011 IMPROVEMENTS: Residential Dwelling The above-captioned property is scheduled to be sold at the Sheriff's Sale on Wednesday, DECEMBER 4, 2002 at 10:00 a.m. in the Commissioner's Hearing Room located on the 2nd Floor of the Cumberland County Courthouse, 1 Courthouse Square, Carlisle, Pennsylvania 17013. Our records indicate that you may hold a mortgage or judgments on the property which will be extinguished by the sale. You may wish to attend the sale to protect your interests. A schedule of distribution will be filed by the Sheriff on a date specified by the Sheriff not later than 30 days after sale. Distribution will be made in accordance with the schedule unless exceptions are filed thereto within 10 days after the filing of the schedule. " " r. in r N M N r N r -, s,o m? nz Wg m m2 N Gf A W N OJ -Pp (O t J A W -,-4f4- ?N 4 < 0 i a rn < ° u, f n D cI 1. I i a f7 C7 H C1 C1 "d[y' h C'1C7C) 6 0 m 5 " 5 On m C n - p d m Ma -:,54 0,0 m m E 0 p, C 7f '+7 w, fn? tj y'w m m .+. pro, p ? ?. o o 0C... C] '?? p9 C]ya n O y N O b A y QM ? vp?l? ? n Wn WW (? m n rn rn O ? P' G d u 0 o m y;G76" ?k 'O xx O d b a` ? oN N x ??? T? ? N 0 ro Hrn p, ?. Z x?i GH+ a f Fi . mac. tY rn 3°v tlO OC N?, O r'D H i IVG i n2 m *b?7 iEw ?M p - O 'dG W d P? Q' 'O EL ? co Q' ' ?n b ?.9 ?° j P N? ; =. 0m iP.- O J . i N XrlIG J C y ln.i C N ?O e + o Wy ? *? v, ? o? morn o .G ae i sip x wP, y _ ? + iF _ / ? (? A, m a mm VJ ? N o? m c nm N N mm c ? 0 om O? 11V Pry m-ie ion Si r is re Co fi ti S E t-ii ncu rg R x R ?stri ke ? D V6 $ O u R •p A m A w m n a n > °n m ? T N N T' T dye ? CGi m -:Z T s?ZO :)Owz v '?On 1?f9 a TJ n IDo 29 m z n3 m e 0 V ?g r S co m L O] O C r k-0 t- ice, r 0 0 mj y N N N m m m w 3 s m m 8oN? m my-- fag esm2? ,?mW e mmm??? m i5 SL ma•m c ? @3? yvm 41¢?W%mm mgm?8m? a??Y,o Am Np $3O1a3 m?ma'S?m aa?_m5 ?m'Z -01m6 T3om ?o??mAo afoz"? ?m?g?ma 3??3 @D@ mgg? a o 4 DO F 3 ??mgg??oa 3v3 s :30000 0 p m b 0 P F 0 0 m 3330 ?• v y o z, 0000 y 0 A m3° m Q 1 PR S p ? 0 m ? J??48?b a ISO ? gm3 'm ¦B 77 nor ??m W?:a deetre?eeY+?zra?as? `' - re3 a..?mtavawe? .? -?'?«wzwiw wet 'CSR: c"' __ P1l [''? ._... -- f,. (!?>: U1 ., ?.?? C i ??, ? ?J4? ?_-U ? C ? `gym --'-? J (J -G McCABE, WEISBERG AND CONWAY, P.C. BY: TERRENCE J. McCABE, ESQUIRE Identification Number 16496 First Union Building 123 South Broad Street, Suite 2080 Philadelphia, PA 19109 (215) 790-1010 CONSECO FINANCE CONSUMER DISCOUNT COMPANY F/K/A GREEN TREE CONSUMER DISCOUNT COMPANY V. MARGARET S. KEEVER Attorney for Plaintiff CUMBERLAND COUNTY COURT OF COMMON PLEAS NUMBER 2000-611 AFFIDAVIT OF SERVICE I, Terrence J. McCabe, Esquire, attorney for the Plaintiff in the within matter, hereby certify that on the, 14th DAY OF NOVEMBER, 2002, a true and correct copy of the Notice of Sheriff's Sale of Real Property was served on all pertinent lienholder(s) as set forth in the Affidavit Pursuant to 3129 which is attached hereto as Exhibit "A" Copies of the letter and certificate of mailing are also attached hereto, made a part hereof and marked as Exhibit "B." ?, /V 04t,-? TERRENC J. McCABE, ESQUIRE SWORN TO AND SUBSCRIBED BEFORE ME THIS 14th DAY OF NOVEMBER, 2002. /Z? NOTARY PUBLIC ?_ NOTAAIMSM 4410HELLE A. HOLACIK Notaryftk City of Pfrflade)OL Rik ?fntY "Ocmmi^sior, Eroives ?R^rrh 28, _P McCABE, WEISBERG AND CONWAY, P.C. BY: TERRENCE J. MCCABE, ESQUIRE Identification Number 16496 First Union Building 123 South Broad Street, Suite 2080 Philadelphia, PA 19109 (215) 790-1010 CONSECO FINANCE CONSUMER DISCOUNT: COMPANY F/K/A GREEN TREE CONSUMER: DISCOUNT COMPANY V. MARGARET S. KEEVER Attorney for Plaintiff CUMBERLAND COUNTY COURT OF COMMON PLEAS NUMBER 2000-611 AMENDED AFFIDAVIT PURSUANT TO RULE 3129 I, Terrence J. McCabe, Esquire, attorney for Plaintiff in the above action, set forth as of the date the Praecipe for the Writ of Execution was filed the following information concerning the real property located at 4603 Hampden Avenue, Camp Hill, PA 17011, a copy of the description of said property is attached hereto and marked Exhibit "A." 1. Name and address of Owner(s) or Reputed Owner(s): Name Address Margaret S. Keever 4603 Hampden Avenue Camp Hill, PA 17011 2. Name and address of Defendant(s) in the judgment: Name Address Margaret S. Keever 4603 Hampden Avenue Camp Hill, PA 17011 3. Name and last known address of every judgment creditor whose judgment is a record lien on the real property to be sold: Name Address INDIAN ROCKS POA INC. OF LEDGEDALE P.O. BOX 540 GREENTOWN, PA 18426 U.S. TREASURY DEPT P.O. BOX 12051 PHILADELPHIA, PA 19105 4. Name and address of the last recorded holder of every mortgage of record: Name Address Conseco Finance Consumer Discount f/k/a Green Tree 7360 Kyrene Road Consumer Discount Company Tempe, AZ 85283 Citifinancial f/k/a Commercial Credit Corp. Inc. Successor 8335 Century Park Ct. in int&ABAT A !! Suite 200 Pacifi San Diego, CA 92123 Attn: Karen Shields GREEN TREE RETAIL SERVICES BANK, ONE CITIFINANCIAL F/K/A COMMERCIAL CREDIT CORP 1400 TURBINE DRIVE RAPID CITY, SD 57701 3401 HARTZDALE DR.,STE 126 CAMP HILL, PA 17011 CITIFINANCIAL F/K/A 7467 NEW RIDGE ROAD, STE 222 COMMERCIAL CREDIT CORP. HANOVER, ND 21076 ATTN: DAVID PARKS 5. Name and address of every other person who has any record interest in or record lien on the property and whose interest may be affected by the sale: Name Address None. 6. Name and address of Plaintiff has knowledge who has may be affected by the sale: Name every other person of whom the any interest in the property which Tenant(s)/Occupant(s) Domestic Relations Commonwealth of Pa Address 4603 Hampden Avenue Camp Hill, PA 17011 Cumberland County P.O. Box 320 Carlisle, PA 17015 Department of Welfare P.O. Box 2675 Harrisburg, Pa 17105 I verify that the statements made in this Affidavit are true and correct to the best of my personal knowledge or information and belief. I understand that false statements herein are made subject to the penalties of 18 Pa.C.S. Section 4904 relating to unsworn falsification to authorities. wa November 14, 2002 DATE TERR E J. c E, ESQUIRE Attorney for Plaintiff ?i !! AHIES&IT McCABE, WEISBERG AND CONWAY, P.C. BY: TERRENCE J. McCABE, ESQUIRE Identification Number 16496 123 South Broad Street, Suite 2080 Philadelphia, Pennsylvania 19109 (215) 790-1010 CONSECO FINANCE CONSUMER DISCOUNT: COMPANY F/K/A GREEN TREE CONSUMER: DISCOUNT COMPANY V. MARGARET S. KEEVER DATE: October 25, 2002 Attorney for Plaintiff CUMBERLAND COUNTY COURT OF COMMON PLEAS NUMBER 2000-611 TO: ALL PARTIES IN INTEREST AND CLAIMANTS NOTICE OF SHERIFF'S SALE OF REAL PROPERTY OWNER(S): Margaret S. Keever PROPERTY: 4603 Hampden Avenue, Camp Hill, PA 17011 IMPROVEMENTS: Residential Dwelling The above-captioned property is scheduled to be sold at the Sheriff's Sale on Wednesday, DECEMBER 4, 2002 at 10:00 a.m. in the Commissioner's Hearing Room located on the 2nd Floor of the Cumberland County Courthouse, 1 Courthouse Square, Carlisle, Pennsylvania 17013. Our records indicate that you may hold a mortgage or judgments on the property which will be extinguished by the sale. You may wish to attend the sale to protect your interests. A schedule of distribution will be filed by the Sheriff on a date specified by the Sheriff not later than 30 days after sale. Distribution will be made in accordance with the schedule unless exceptions are filed thereto within 10 days after the filing of the schedule. CAH Li OT "By' k a N r)r H o (P A '? W ? N y i p cO W V 1 01 I (T i A ? W i N ? ? I ? ? 3 y3 ? ? ? ? ? CI n m m i ? (? D m N Wp o m m Oh ? - C w a s?? m Z ? z a ?z ,Z d Q 4. °®n 8 ?o ?z0 T Om O 0 y M G ? N tl ? 0 c W -V oooo?z w m ? (b O n x mOm V / ? ?? N n 3 n g ? d v o ° Q z. 9 Como 3 a E o ;m m m ? a z ° FTn?n?V A o82' m m m !2 61 g2 ?I m m ?.mW N. °a ? ?'ac-g? me ? =g OV8E$^-D 0$ ?x 'o3' m ?m om?3oc m m m ggmm ui ?I?'w ?? 3pm?Qm m 3 m c nmm - ° m'?`a98` m? ma.. a . F mm Mm g = 3 mom n mx?^e j= »D m?O3 S?m g ? ?c d ?n 'a?aomfi? 8 'c"ma.?W01 mm any°s ° nm ?nm ?'in? q a my °? oom ?`? m3 ? ? fl cc m? a m m d 4 °'fA EiN O?u ? O a al SzM C Om =?0 8 23 m?&m ?3 /? l" om O? o gd ? a fDL6L k91? i/' Jr 1 m 20 '7L a06°00 m= u z z z a 3E)vzsoa •s•n a s Lll 19° ii s! Tp mp L^ i 11 D .LLd?44MS0 3RIMiY?1kWWSiiibYl?AMi341mYd-"•., J' B3[a5edl.£::06Y4:?'W6'"llLHdtltkikewVWA3Y-E"i161B6?1. ..? ? -•..•??••??.. -..? •••,•,? ._... ... ..-• -.. ••.?_.... _......?u.ur]i:?a..? ?1 a ??_ -C'i n ,, ?.: ,,,? Ui?:z _..... - ra' 1 _ y,: --GI C? -< Conseco Finance Consumer Discount In The Court of Common Pleas of Company f/k/a Green Tree Consumer Cumberland County, Pennsylvania Discount Company Writ No. 2000-611 Civil Term VS Margaret S. Keever R. Thomas Kline, Sheriff, who being duly sworn according to law, states this writ is returned STAYED pursuant to instructions from Attorney Terrence McCabe. Sheriff's Costs: Docketing 30.00 Surcharge 20.00 Law Library Prothonotary 1.00 Mileage 17.94 Levy 15.00 Advertising 15.00 Posting Handbills 15.00 Share of Bills 25.20 Poundage 13.32 Law Journal 293.30 Patriot News 232.15 Certified Mail 1.53 $ 679.44 paid by attorney 12/02/02 Sworn and subscribed to before me ..tom This P ° day of k' .«,,,,?.w R. Thomas Kline, Sheriff 2002, A. / r Q yh ??0y BY`JOqJj SYl IVLI/1 Prothonotary Real E to Deputy J A (SNP, 3 %o `-13 &. / jj r McCABE, WEISBERG AND CONWAY, P.C. BY: TERRENCE J. MCCABE, ESQUIR9 Identification Number 16496• First Union Building 123 South Broad Street, Suite 2080 Philadelphia, PA 19109 (215) 790-1010 MARGARET S. KEEVER AFFIDAVIT PURSUANT TO RULE 3129 1. Name and address of Owner(s) or Reputed Owner(s): Name Address Margaret S. Keever 2. Name and address of Defendant(s) in the judgment: Name Address Margaret S. Keever NONE Conseco Finance Consumer Discount f/k/a Green Tree 7360 Kyrene Road Consumer Discount Company Tempe, AZ 85283 CONSECO FINANCE CONSUMER DISCOUNT: COMPANY F/K/A GREEN TREE CONSUMER: DISCOUNT COMPANY V. I, Terrence J. McCabe, Esquire, attorney for Plaintiff in the above action, set forth as of the date the Praecipe for the Writ of Execution was filed the following information concerning the real.- property located at 4603 Hampden Avenue, Camp Hill, PA 17011, a copy of the description of said property is attached hereto and marked Exhibit "A." 3. Name and last known address of every judgment creditor whose judgment is a record lien on the real property to be sold: Name Address 4. Name and address of the last recorded holder of every mortgage of record: Name Address Attorney for Plaintiff CUMBERLAND COUNTY COURT OF COMMON PLEAS NUMBER 2000-611 4603 Hampden Avenue Camp Hill, PA 17011 4603 Hampden Avenue Camp Hill, PA 17011 Citifinancial f/k/a Commercial Credit Corp. Inc. Successor 8335 Century Park Ct. in interest to Security Suite 200 Pacific Finance Inc. San Diego, CA 92123 Attn: Karen Shields GREEN TREE RETAIL SERVICES BANK, ONE 1400 TURBINE DRIVE RAPID CITY, SD 57701 CITIFINANCIAL F/K/A 3401 HARTZDALE DR.,STE 126 S f COMMERCIAL CREDIT CORP CITIFINANCIAL F/K/A 7467 COMMERCIAL CREDIT CORP. CAMP HILL, PA 17011 NEW RIDGE ROAD, STE 222 HANOVER, ND 21076 ATTN: DAVID PARKS 5. Name and address of every other person who has any record interest in or record lien on the property and whose interest may be affected by the sale: Name Address None. 6. Name and address of every other person of whom the Plaintiff has knowledge who has any interest in the property which may be affected by the sale: Name Address Tenant(s)/Occupant(s) 4603 Hampden Avenue Camp Hill, PA 17011 Domestic Relations Commonwealth of Pa Cumberland County P.O. Box 320 Carlisle, PA 17015 Department of Welfare P.O. Box 2675 Harrisburg, Pa 17105 I verify that the statements made in this Affidavit are true and correct to the best of my personal knowledge or information and belief. I understand that false statements herein are made subject to the penalties of 18 Pa.C.S. Section 4904 relating to unsworn falsification to authorities. September 6, 2002 DATE TERR CE J. McCABE, ESQUIRE Attor ey for Plaintiff ALL THAT CERTAIN lot or tract of land situate in the Township of Hampden, County of Cumberland, and State of Pennsylvania, more particularly bounded and described as follows according to a survey of Gerrit J. Betz, Registered Surveyor, dated January 11, 1971, to wit: BEGINNING at a point on the northern line of Hampden Avenue, said point being by same measured in a southwesterly direction 90.0 feet from the northwest corner of Clearview Drive and Hampden Avenue; thence South 51 degrees 26 minutes West along said northern line of Hampden Avenue a distance of 72.0 feet to a hub; thence North 38 degrees 34 minutes West along the eastern line of lands now or formerly of George D. Sauers a distance of 100.00 feet to an iron pipe; thence North 51 degrees 26 minutes East along the southern line of lands now or formerly of Roger L. Knecht and Jack H. Forten, respectively, a distance u of 72.0 feet to a hub; thence South 38 degrees 34 minutes East along the line of adjoiner between Lots Nos. 191 and 192 on the hereinafter mentioned Plan of Lots a distance of 100.0 feet to a hub, the point and place of BEGINNING. BEING Lot No. 191, Block "J" on the Plan of Clearview Faint recorded in the Recorder's Office of Cumberland County, recorded in Plat Book 9, Page 13. HAVING THEREON ERECTED a one story frame dwelling with car port known and numbered as 4603 Hampden Avenue. Parcel 4: 10-21-0279-195 MCCABE., WEISBERG AND CONWAY, P.C. BY: TERRENCE J. MCCABE, ESQUIRE' Identification Number 16496 First Union Building 123 South Broad Street, Suite 2080 Philadelphia, PA 19109 (215) 790-1010 CONSECO FINANCE CONSUMER DISCOUNT: COMPANY F/K/A GREEN TREE CONSUMER: DISCOUNT COMPANY V. MARGARET S. KEEVER Attorney for Plaintiff CUMBERLAND COUNTY COURT OF COMMON PLEAS NUMBER 2000-611 NOTICE OF SHERIFF'S SALE OF REAL PROPERTY TO: Margaret S. Keever 4603 Hampden Avenue Camp Hill, PA 17011 Your house (real estate) at 4603 Hampden Avenue, Camp Hill, PA 17011 (more fully described as attached) is scheduled to be sold at Sheriff's Sale on, DECEMBER 4, 2002 at 10:00 a.m. in the Commissioner's Hearing Room located on the 2nd Floor of the Cumberland County Courthouse, 1 Courthouse Square, Carlisle, Pennsylvania 17013, to enforce the court judgment of 134,987.91 obtained by Conseco Finance Consumer Discount Company f/k/a Green Tree Consumer Discount Company against you. NOTICE OF OWNER'S RIGHTS YOU MAY BE ABLE TO PREVENT THIS SHERIFF'S SALE To prevent this Sheriff's Sale you must take immediate action: 1. The sale will be canceled if you pay to Conseco Finance Consumer Discount Company f/k/a Green Tree Consumer Discount Company the back payments, late charges, costs, and reasonable attorney's fees due. To find out how much you must pay, you may call Terrence J. McCabe, Esquire at (215) 790-1010. 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. a 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 the following notice 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 Sheriff's Sale is not stopped, your property will be sold to the highest bidder. You may find out the price bid by calling Terrence J. McCabe, Esquire at (215) 790-1010. 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 on the sale. To find out if this has happened, you may call Terrence J. McCabe, Esquire at (215) 790-1010. 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 a 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. A schedule of distribution will be filed by the Sheriff on a date specified by the Sheriff not later than 30 days after sale. Distribution will be made in accordance with the schedule unless exceptions are filed thereto within 10 days after the filing of the schedule. 7. You may also have other rights and defenses, or ways of getting your real estate back, if you act immediately after the sale. YOU SHOULD TAKE THIS PAPER TO YOUR LAWYER AT ONCE. IF YOU DO NOT HAVE A LAWYER OR CANNOT AFFORD ONE, GO TO OR TELEPHONE THE OFFICE LISTED BELOW TO FIND OUT WHERE YOU CAN GET LEGAL HELP. LAWYER REFERRAL SERVICE COURT ADMINISTRATOR 4TH FLOOR, CUMBERLAND COUNTY COURTHOUSE CARLISLE, PENNSYLVANIA 17013 (717) 240-6200 OR CUMBERLAND COUNTY BAR ASSOCIATION 2 LIBERTY AVENUE CARLISLE, PA 17013 (717) 249-3166 ALL THAT CERTAIN lot or tract of land situate in the Township of Hampden, County of Cumberland, and State of Pennsylvania, more particularly bounded and described as follows according to a survey of Gerrit J. Betz, Registered Surveyor, dated January 11, 1971, to wit: BEGINNING at a point on the northern line of Hampden Avenue, said point being by same measured in a southwesterly direction 90.0 feet from the northwest corner of Clearview Drive and Hampden Avenue; thence South 51 degrees 26 minutes West along said northern line of Hampden Avenue a distance of 72.0 feet to a hub; thence North 38 degrees 34 minutes West along the eastern line of lands now or formerly of George D. Sauers a distance of 100.00 feet to an iron pipe; thence North 51 degrees 26 minutes East along the southern line of lands now or formerly of Roger L. Knecht and Jack H. Forten, respectively, a distance of 72.0 feet to a hub; thence South 38 degrees 34 minutes East along the line of adjoiner between Lots Nos. 191 and 192 on the hereinafter mentioned Plan of Lots a distance of 100.0 feet to a hub, the point and place of BEGINNING. BEING Lot No. 191, Block "J" on the Plan of Clearview Farm recorded in the Recorder's Office of Cumberland County, recorded in Plat Book 9, Page 13. HAVING THEREON ERECTED a one story frame dwelling with car port known and numbered as 4503 Hampden Avenue. Parcel M 10-21-0279-195 WRIT OF EXECUTION and/or ATTACHMENT COMMONWEALTH OF PENNSYLVANIA) N000-611 Civil COUNTY OF CUMBERLAND) CIVIL ACTION- LAW TO THE SHERIFF OF CUMBERLAND COUNTY: To satisfy the debt, interest and costs due CONSECO FINANCE CONSUMER DISCOUNT CO F/K/A GREEN TREE CONSUMER DISCOUNT CO., Plaintiff (s) From MARGARET S. KEEVER, 4603 HAMPDEN AVENUE, CAMP HILL, PA 17011 (1) You are directed to levy upon the property of the defendant (s)and to sell SEE LEGAL DESCRIPTION. (2) You are also directed to attach the property of the defendant(s) not levied upon in the possession of GARNISHEE(S) as follows: and to notify the gamishee(s) that: (a) an attachment has been issued; (b) the garnishee(s) is enjoined from paying any debt to or for the account of the defendant (s) and from delivering any property of the defendant (s) or otherwise disposing thereof; (3) If property of the defendant(s) not levied upon an subject to attachment is found in the possession of anyone other than a named garnishee, you are directed to notify him/her that he/she has been added as a garnishee and is enjoined as above stated. Amount Due$111,893.91 L.L. Interest FROM 3/21/00-12/4/02 - $18,169.32 Atty's Comm % Due Prothy $1.00 Atty Paid $1593.19 Other Costs Plaintiff Paid. Date: SEPTEMBER 10, 2002 CURTIS R. LONG Prothonot (Seal) cf` By: Deputy REQUESTING PARTY: Name TERRENCE J.MCCABE, ESQUIRE Address: 123'S. BROAD STREET, SUITE 2080 PHILADELPHIA, PA 19109 Attorney for: PLAINTIFF Telephone: 215-790-1010 Supreme Court ID No. 16496 Real Estate Sale # 28 On September 13, 2002 the sheriff levied upon the defendant's interest in the real property situated in Hampden Township, Cumberland County, PA known and numbered as 4603 Hampden Ave., Camp Hill --' more fully described on Exhibit "A" filed with this writ and by this reference incorporated herein. Date: September 13, 2002 B ? Y•'? e ?," v = Real Estate Deputy . PJLAL ESTATE SALE NO. 28 Writ No. 2000-611 Civil Conseco Finance Consumer Discount Company, f/k/a Green Tree Consumer Discount Company VS. Margaret S. Keever Atty.: Terrence McCabe ALL THAT CERTAIN lot or tract of land situate in the Township of Hampden, County of Cumberland, and State of Pennsylvania, more particularly bounded and described as follows according to a survey of Garrit J. Betz, Registered Surveyor, dated January 11, 1971, to wit: BEGINNING at a point on the northern line of Hampden Avenue, said point being by same measured in a southwesterly direction 90.0 feet from the northwest corner of Clearview Drive and Hampden Av- enue; thence South 51 degrees 26 minutes West along said northern line of Hampden Avenue a distance of 72.0 feet to a hub; thence North 38 degrees 34 minutes West along the eastern line of lands now or for- merly of George D. Sauers a dis- tance of 100.00 feet to an iron pipe; thence North 51 degrees 26 min- utes East along the southern line of lands now or formerly of Roger L. Knecht and Jack H. Forten, respec- tively, a distance of.72.0 feet to a hub; thence South 38 degrees 34 minutes East along the line of ad- joiner between Lots Nos. 191 and 192 on the hereinafter mentioned Plan of Lots a distance of 100.0 feet to a hub, the point and place of BEGINNING. BEING Lot No. 191. Block "J" on the Plan of Clearview Farm re- corded in the Recorder's Office of Cumberland County, recorded in Plat Book 9, Page 13. HAVING THEREON ERECTED a one story frame dwelling with car port known and numbered as 4603 Hampden Avenue. Parcel #: 10-21-0279-195. PROOF OF PUBLICATION OF NOTICE IN CUMBERLAND LAW JOURNAL (Under Act No. 587, approved May 16, 1929), P. L.1784 STATE OF PENNSYLVANIA COUNTY OF CUMBERLAND : ss. Roger M. Morgenthal, Esquire, Editor of the Cumberland Law Journal, of the County and State aforesaid, being duly sworn, according to law, deposes and says that the Cumberland Law Journal, a legal periodical published in the Borough of Carlisle in the County and State aforesaid, was established January 2, 1952, and designated by the local courts as the official legal periodical for the publication of all legal notices, and has, since January 2, 1952, been regularly issued weekly in the said County, and that the printed notice or publication attached hereto is exactly the same as was printed in the regular editions and issues of the said Cumberland Law Journal on the following dates, viz: OCTOBER 25, NOVEMBER 1, 8, 2002 Affiant further deposes that he is authorized to verify this statement by the Cumberland Law Journal, a legal periodical of general circulation, and that he is not interested in the subject matter of the aforesaid notice or advertisement, and that all allegations in the foregoing statements as to time, place and character of publication are true. Roger M. Morgenthal, Editor SWORN TO AND SUBSCRIBED before me this _--j _day of NOVEMBER. 2002 LOIS E. SWDER, Notary Pu611o CNN* Boro * = 5 THE PATRIOT NEWS THE SUNDAY PATRIOT NEWS Proof of Publication Under Act No. 587, Approved May 16,1929 Commonwealth of Pennsylvania, County of Dauphin) ss Frank J. Epler being duly sworn according to law, deposes and says: That he is the Controller of The Patriot News Co., a corporation organized and existing under the laws of the Commonwealth of Pennsylvania, with its principal office and place of business at 812 to 818 Market Street, in the City of Harrisburg, County of Dauphin, State of Pennsylvania, owner and publisher of The Patriot-News and The Sunday Patriot-News newspapers of general circulation, printed and published at 812 to 818 Market Street, in the City, County and State aforesaid; that The Patriot-News and The Sunday Patriot-News were established March 4th, 1854, and September 18th, 1949, respectively, and all have been continuously published ever since; That the printed notice or publication which is securely attached hereto is exactly as printed and published in their regular daily and/or Sunday/ Metro editions which appeared on the 22nd and 29th day(s) of October and the 5th day(s) of November 2002. That neither he nor said Company is interested in the subject matter of said printed notice or advertising, and that all of the allegations of this statement as to the time, place and character of publication are true; and - That he has personal knowledge of the facts aforesaid and is duly authorized and empowered to verify this statement on behalf of The Patriot-News Co. aforesaid by virtue and pursuant to a resolution unanimously passed and adopted severally by the stockholders and board of directors of the said Company and subsequently duly recorded in the office for the Recording of Deeds in and for said County of Dauphin in Miscellaneous Book "M", Volume 14, Page 317. PUBLICATION ...... ................................... COPY Sworn to and subscribed before is 14th daoNo er 2002 A.D. SALE #28 L. Russell, Notary Public ? ? iamstwrg,Dauphin County NOTARY PUBLIC nission Expires June 6, 2005 _ My commission expires June 6, 2006 CUMBERLAND COUNTY SHERIFFS OFRCE CUMBERLAND COUNTY COURTHOUSE CARLISLE, PA. 17013 main house and lot of ground he Borough of Carlisle, County and _and State of Pennsylvania, S described as follows: itb by -property of the Estate of ler, deceased, on the East by rd Street; on the South by lot of lene R. Leonard, Jr., and on the auey. frontage of Twenty (20) feet on Bedford Street and'extending in oven width a distance of One Statement of Advertising Costs To THE PATRIOT-NEWS CO., Dr. For publishing the notice or publication attached hereto on the above stated dates $ 230.40 Probating same Notary Fee(s) $ 1.75 Total $ 232.15 ny(120)feet, tosaid alleyon Publisher's Receipt for Advertising Cost ved with the Northern half of -publisher of The Patriot-News and The Sunday Patriot-News, newspapers of general story frame dwetiing house, , receipt of the aforesaid notice and publication costs and certifies that the same have numbered 406 North $edfoad Street.. I PARCEL. N0.02-20-1800-258. By.... McCABE, WEISBERG & CONWAY, P.C. BY: TERRENCE J. McCABE, ESQUIRE Identification Number 16496 123 South Broad Street, Suite 2080 Philadelphia, Pennsylvania 19109 Telephone: (215) 790-1010 CONSECO FINANCE CONSUMER DISCOUNT COMPANY f/k/a GREEN TREE CONSUMER DISCOUNT COMPANY V. MARGARET S. KEEVER Attorney for Plaintiff Cumberland County Court of Common Pleas Number 2000-611 WITHDRAWAL OF ENTRY OF APPEARANCE TO THE OFFICE OF JUDICIAL SUPPORT: Kindly withdraw my appearance for Plaintiffs in the above captioned matter. Date: 3 AC/ C/ TERRENCE J. McC E, ESQUIRE ENTRY OF APPEARANCE TO THE OFFICE OF JUDICIAL SUPPORT: Kindly enter my appearance for Plaintiffs in the above captioned matter. Date: Vl °{ N[? / dt,, ' J. UDRE , ESQUIRE -u Cm rr. ; tel. 4l -. .l UDREN LAW OFFICES, P.C. ATTORNEY FOR PLAINTIFF BY: Mark J. Udren, Esquire ATTY I.D. NO. 04302 WOODCREST CORPORATE CENTER 111 WOODCREST ROAD, SUITE 200 CHERRY HILL, NJ 08003-3620 856-669-5400 pleadingsCudren.com Conseco Finance Consumer :COURT OF COMMON PLEAS Discount Company, f/k/a Green :CIVIL DIVISION Tree Consumer Discount Company :Cumberland County Plaintiff V. :MORTGAGE FORECLOSURE Margaret S. Keever NO. 2000-611 46D5 Hampden Avg Defendant(s) Caamp I4i iI PA 1,7o?I PRAECIPE TO ISSUE WRIT OF EXECUTION TO THE PROTHONOTARY: Issue Writ of Execution in the above matter: Amount due $111,893.91 Interest From 3/21/00 74,593.62 to Date of Sale 3/5/08 Ongoing Per Diem of 25.66 to actual date of sale including if sale is held at a later date (Costs to be added) $ UDREN LAW OFFICES, P.C. k J. dren, ES A ORNEY FOR PLAINTIFF IN THE UNITED STATES FOR THE MIDDLE DISTR IN RE: MARGARET SUFFEL KEEVER DEBTOR(S) GREEN TREE CONSUMER DISCOUNT COMPANY MOVANT V. MARGARET SUFFEL KEEVER CHARLES J. DEHART, III, ESQUIRE RESPONDENTS f?4`KRUPTCY COURT OF PENNSYLVANIA 13 PROCEEDING -02-bk-06475 MDF ORDER Upon consideration of Green Tree Consumer Discount Company's Request to Relist the Motion for Relief from Stay hearing and the Certification of Default it is hereby ORDERED AND DECREED that the Automatic Stay be modified to permit, Green Tree Consumer Discount Company and/or its successors and assigns to proceed with foreclosure on the property located at 4603 Hampden Avenue, Camp Hill, PA 17011 and obtain all other Relief available under the Non-Bankruptcy law. It is further ORDERED AND DECREED, that relief granted by this order shall survive the conversion of this bankruptcy case to a case under any other Chapter of the Bankruptcy Code. By the +Comi., P/04? Ba F , Imip This document is electronically signed and filed on the same date. Dated: September 5, 2007 UDREN LAW OFFICES, P.C. ATTORNEY FOR PLAINTIFF BY: Mark J. Udren, Esquire ATTY I.D. NO. 04302 WOODCREST CORPORATE CENTER 111 WOODCREST ROAD, SUITE 200 CHERRY HILL, NJ 08003-3620 856-669-5400 pleadings@udren.com Conseco Finance Consumer :COURT OF COMMON PLEAS Discount Company, f/k/a Green :CIVIL DIVISION Tree Consumer Discount Company :Cumberland County Plaintiff V. :MORTGAGE FORECLOSURE Margaret S. Keever :NO. 2000-611 Defendant(s) C E R T I F I C A T E Mark J. Udren, Esquire, hereby states that he is the 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 insured mortgage ( ) Non-owner occupied ( ) Vacant ( x ) Act 91 procedures have been fulfilled. ( } Over 24 months delinquent. This certification is made subject to the penalties of 18 Pa. C.S. Sec. 4904 relating to unsworn falsification to authorities. UDREN LAW OFFICES, P.C. aV J. Udren, ESQUIRE TTORNEY FOR PLAINTIFF UDREN LAW OFFICES, P.C. BY: Mark J. Udren, Esquire ATTY I.D. NO. 04302 WOODCREST CORPORATE CENTER 111 WOODCREST ROAD, SUITE 200 CHERRY HILL, NJ 08003-3620 856-669-5400 pleadings@udren.com Conseco Finance Consumer Discount Company, f/k/a Green Tree Consumer Discount Company Plaintiff V. Margaret S. Keever Defendant (s) ATTORNEY FOR PLAINTIFF :COURT OF COMMON PLEAS :CIVIL DIVISION :Cumberland County :MORTGAGE FORECLOSURE :NO. 2000-611 AFFIDAVIT PURSUANT TO RULE 3129.1 Conseco Finance Consumer Discount Company, f/k/a Green Tree Consumer Discount Company, Plaintiff in the above action, by its attorney, Mark J. Udren, ESQ., sets forth as of the date the Praecipe for the Writ of Execution was filed the following information concerning the real property located at: 4603 Hampden Avenue, Camp Hill, PA 17011 1. Name and address of Owner(s) or reputed Owner(s): Name Address Margaret S. Keever 4603 Hampden Avenue Camp Hill, PA 17011 2. Name and address of Defendant(s) in the judgment: Name Address SAME AS 41 ABOVE 3. Name and address of a record lien on the r Name Indian Rocks POA, Inc. 4. Name and address of of record: Name every judgment creditor whose judgment is eal property to be sold: Address P.O. Box 540, Greentown, PA 18426 the last recorded holder of every mortgage Address Conseco Finance Consumer Discount Company, f/k/a Green Tree Consumer Discount Company Commercial Credit Corp. 7360 South Kyrene Road Tempe, AZ 85283 3401 Hartzdale Drive, Suite 126 Camp Hill, PA 17011 1 5. Name and address of every other person who has any record lien on the property: Name Address Township of Hampden 230 South Sporting Hill Road Mechanicsburg, PA 17055 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 Address Real Estate Tax Department Domestic Relations Section Commonwealth of PA, Department of Revenue 1 Courthouse Square Carlisle, PA 17013 13 North Hanover Street Carlisle, PA 17013 Bureau of Compliance, PO Box 281230 Harrisburg, PA 17128-1230 7. Name and address of every other person of whom the plaintiff has knowledge who has any interest in the property which may be affected by the sale: Name Address Tenants/Occupants 4603 Hampden Avenue Camp Hill, PA 17011 I verify that the statements made in this affidavit are true and correct to the best of my personal knowledge or information and belief. I understand that false statements herein are made subject to the penalties of 18 Pa.C.S. sec. 4904 relating to unsworn falsification to authorities. UDREN LAW OFFICES, P.C. DATED: October 1, 2007 Vtork J.n, ESQ. rney for Plaintiff w UDREN LAW OFFICES, P.C. ATTORNEY FOR PLAINTIFF BY: Mark J. Udren, Esquire ATTY I.D. NO. 04302 WOODCREST CORPORATE CENTER 111 WOODCREST ROAD, SUITE 200 CHERRY HILL, NJ 08003-3620 856-669-5400 pleadings@udren.com Conseco Finance Consumer :COURT OF COMMON PLEAS Discount Company, f/k/a Green =CIVIL DIVISION Tree Consumer Discount Company :Cumberland County Plaintiff V. :MORTGAGE FORECLOSURE Margaret S. Keever NO. 2000-611 Defendant(s) NOTICE OF SHERIFF'S SALE OF REAL PROPERTY To: Margaret S. Keever 4603 Hampden Avenue Camp Hill, PA 17011 Your house (real estate) at 4603 Hampden Avenue, Camp Hill, PA 17011 is scheduled to be sold at the Sheriff's Sale on March 5, 2008, at 10:00 am in the Commissioners Hearing Room, 2nd Floor, Courthouse, Carlisle, PA, to enforce the court judgment of $111,893.91, obtained by Plaintiff above (the mortgagee) against you. If the sale is postponed, the property will be relisted for the Next Available Sale. NOTICE OF OWNER'S RIGHTS YOU MAY BE ABLE TO PREVENT THIS SHERIFF'S SALE To prevent this Sheriff's Sale, you must take immediate action: 1. The sale will be cancelled if you pay to the mortgagee the back payment, late charges, costs and reasonable attorney's fees. To find out how much you must pay, you may call: (856) 669-5400. 2. You may be able to stop the sale by filing a petition asking the Court to strike or open the judgment, if the judgment was improperly entered. You may also ask the Court to postpone the sale for good cause. 3. You may also be able to stop the sale through other legal proceedings. You may need an attorney to assert your rights. The sooner you contact one, the more chance you will have of stopping the sale. (See notice on page two on how to obtain an attorney.) w 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 Sheriff's Sale is not stopped, your property will be sold to the highest bidder. You may find out the price bid by calling 856-669- 5400. 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 856-669-5400. 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 after 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 Schedule of Distribution is filed. 7. You may also have other rights and defenses, or ways of getting your home back, if you act immediately after the sale. YOU SHOULD TAKE THIS PAPER TO YOUR LAWYER AT ONCE. IF YOU DO NOT HAVE A LAWYER OR CANNOT AFFORD ONE, GO TO OR TELEPHONE THE OFFICE LISTED BELOW TO FIND OUT WHERE YOU CAN GET LEGAL HELP. LAWYER REFERRAL SERVICE Cumberland County Bar Association 2 Liberty Avenue, Carlisle, PA 17013 (717)249-3166 & (800)990-9108 ASSOCIATION DE LICENCIDADOS Cumberland County Bar Association 2 Liberty Avenue, Carlisle, PA 17013 (717)249-3166 & (800)990-9108 WRIT OF EXECUTION and/or ATTACHMENT COMMONWEALTH OF PENNSYLVANIA) COUNTY OF CUMBERLAND) NO 00-611 Civil CIVIL ACTION - LAW TO THE SHERIFF OF CUMBERLAND COUNTY: To satisfy the debt, interest and costs due CONSECO FINANCE CONSUMER DISCOUNT COMPANY f/k/a GREEN TREE CONSUMER DISCOUNT COMPANY, Plaintiff (s) From MARGARET S. KEEVER (1) You are directed to levy upon the property of the defendant (s)and to sell SEE LEGAL DESCRIPTION. (2) You are also directed to attach the property of the defendant(s) not levied upon in the possession of GARNISHEE(S) as follows: and to notify the garnishee(s) that: (a) an attachment has been issued; (b) the garnishee(s) is enjoined from paying any debt to or for the account of the defendant (s) and from delivering any property of the defendant (s) or otherwise disposing thereof; (3) If property of the defendant(s) not levied upon an subject to attachment is found in the possession of anyone other than a named garnishee, you are directed to notify him/her that he/she has been added as a garnishee and is enjoined as above stated. Amount Due $111,893.91 L.L. $.50 Interest from 3/21/00 to Date of Sale 3/05/08 ongoin Per Diem of $25.66 to actual date of sale including if sale is held at a later date -- $74,593.62 Atty's Comm % Due Prothy $2.00 Atty Paid $2,296.63 Plaintiff Paid Date: 10/05/07 (Seal) REQUESTING PARTY: Name MARK J. UDREN, ESQUIRE Address: UDREN LAW OFFICES, P.C. Other Costs P, " dp -0 ko C 5 C rtis R. Long, Prothonot By: &W a- z . " . ? Deputy WOODCREST CORPORATE CENTER 111 WOODCREST ROAD, SUITE 200 CHERRY HILL, NJ 08003-3620 Attorney for: PLAINTIFF Telephone: 856-669-5400 Supreme Court ID No. 04302 UDREN LAW OFFICES, P.C. ATTORNEY FOR PLAINTIFF MARK J. UDREN, ESQUIRE - ID #04302 STUART WINNEG, ESQUIRE - ID #45362 LORRAINE DOYLE, ESQUIRE - ID #34576 ALAN M. MINATO, ESQUIRE - ID #75860 CHANDRA M. ARKEMA, ESQUIRE - ID #203437 WOODCREST CORPORATE CENTER 111 WOODCREST ROAD, SUITE 200 CHERRY HILL, NJ 08003-3620 856-669-5400 Conseco Finance Consumer :COURT OF COMMON PLEAS Discount Company, f/k/a Green =CIVIL DIVISION Tree Consumer Discount Company =Cumberland County Plaintiff ENO. 2000-611 V. Margaret S. Keever Defendant(s) CERTIFICATE OF SERVICE The undersigned, hereby certifies that they have served true and correct copies of the Notice of Sale upon the following person(s) named herein at their last known address or their attorney of record. xxxxxx Regular First Class Mail xxxxxx Certified Mail Other (certificate of mailing) Date Served: January 22, 2008 TO: USA, US Attorney US Department of Justice 228 Walnut Street, P.O. Box 11754 Harrisburg, PA 17108 UDREN LAW OFFICES, P.C. ,/8??• -G.? BY: A:2, Attorneys foV aintiff MARK J. UDREN, ESQUIRE STUART WINNEG, ESQUIRE LORRAINE DOYLE, ESQUIRE ALAN M. MINATO, ESQUIRE CHANDRA M. ARKEMA, ESQUIRE qh ; I 2 H 0 x?vto cl (ZI n 00oo?? ?to K . "mw [ tr o F- ¢t rn f? x0tj lQ h' rrr H r-rr ? ' (D rr 0 o ??Fj ?j (D o (D (D t-h (71- F' y o G 00 N rr n (D O O 010'0 ?o X-M :0 Z$C-)p n ?M? `Mom ?--??C-) D O D r ?vzn 5E 0 O Retum Receipt Fee Postmark p p (Endorsement Required) Here C3' M .? 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U N D d U- 0 v o?0 0 MC c Li W y cn ;- _ co . UDREN LAW OFFICES, P.C. ATTORNEY FOR PLAINTIFF MARK J. UDREN, ESQUIRE - ID #04302 STUART WINNEG, ESQUIRE - ID #45362 LORRAINE DOYLE, ESQUIRE - ID #34576 ALAN M. MINATO, ESQUIRE - ID #75860 CHANDRA M. ARKEMA, ESQUIRE - ID #203437 WOODCREST CORPORATE CENTER 111 WOODCREST ROAD, SUITE 200 CHERRY HILL, NJ 08003-3620 856-669-5400 Conseco Finance Consumer Discount COURT OF COMMON PLEAS Company, f/k/a Green Tree :CIVIL DIVISION Consumer Discount Company l Cumberland County 7360 South Kyrene Road Tempe, AZ 85283 Plaintiff V. Margaret S. Keever 4603 Hampden Avenue NO. 2000-611 Camp Hill, PA 17011 Defendant(s) AFFIDAVIT OF SERVICE PURSUANT TO Pa.R.C.P.RULE 3129.1 Plaintiff, by its/his/her Attorney, Mark J. Udren, Esquire, hereby verifies that: 1. A copy of the Notice of Sheriff's Sale, a true and correct copy of which is attached hereto as Exhibit "A", was sent to every recorded lienholder and every other interested party known as of the date of the filing of the Praecipe for the Writ of Execution, on the date(s) appearing on the attached Certificates of Mailing. 2. A Notice of Sheriff's.Sale was sent to Defendant(s) by regular mail and certified mail on the date appearing on the attached Return Receipt, which was signed for by Defendant(s) on the date specified on the said Return Receipt. Copies of the said Notice and Return Receipt are attached hereto as Exhibit "B". 3. If a Return Receipt is not attached hereto, then service was by personal service on the date specified on the attached Return of Service, attached hereto as Exhibit "B". 4. If service was by Order of Court, then proof of compliance with said order is attached hereto as Exhibit "B". All Notices were served within the time limits set forth by Pa Rule C.P. 3129. This Affidavit is made subject to the penalt' s of 8 Pa.C.S. Section 4904 relating to unsworn falsification to autho ties. Dated: January 8, 2008 OFFICES, P.C. Y: At-torne ys?_f__o_ra i nt i f f MARK RUD EN, ESQUIRE STUART WINNEG, ESQUIRE /LORRAINE DOYLE, ESQUIRE ALAN M. MINATO, ESQUIRE CHANDRA M. ARKEMA, ESQUIRE UDREN LAW OFFICES, P.C. ATTORNEY FOR PLAINTIFF MARK J. UDREN, ESQUIRE - ID #04302 STUART WINNEG, ESQUIRE - ID #45362 LORRAINE DOYLE, ESQUIRE - ID #34576 ALAN M. MINATO, ESQUIRE - ID #75860 CHANDRA M. ARKEMA, ESQUIRE - ID #203437 WOODCREST CORPORATE CENTER 111 WOODCREST ROAD, SUITE 200 CHERRY HILL, NJ 08003-3620 856-669-5400 Conseco Finance Consumer :COURT OF COMMON PLEAS Discount Company, f/k/a Green "CIVIL DIVISION Tree Consumer Discount Company :Cumberland County Plaintiff V. :MORTGAGE FORECLOSURE Margaret S. Keever :NO. 2000-611 Defendant (s) AMENDED AFFIDAVIT PURSUANT TO RULE 3129.1 Conseco Finance Consumer Discount Company, f/k/a Green Tree Consumer Discount Company, Plaintiff in the above action, by its attorney, Mark J. Udren, ESQ., sets forth as of the date the Praecipe for the Writ of Execution was filed the following information concerning the real property located at: 4603 Hampden Avenue, Camp Hill, PA 17011 1. Name and address of Owner(s) or reputed Owner(s): Name Address Margaret S. Keever 4603 Hampden Avenue Camp Hill, PA 17011 2. Name and address of Defendant(s) in the judgment: Name Address SAME AS #1 ABOVE 3. Name and address of every judgment creditor whose judgment is a record lien on the real property to be sold: Name Address Indian Rocks POA, Inc. P.O. Box 540, Greentown, PA 18426 Conseco Finance Consumer 7360 Kyrene Road Discount Company Tempe, AZ 85283 Bureau of Compliance Department 280946 Harrisburg, PA 17128 4. Name and address of the last recorded holder of every mortgage of record: Name Address Conseco Finance Consumer 7360 South Kyrene Road Discount Company, f/k/a Tempe, AZ 85283 Green Tree Consumer Discount Company Commercial Credit Corp. 3401 Hartzdale Drive, Suite 126 Camp Hill, PA 17011 Green Tree Retail Services 1400 Trubine Drive Bank, One Rapid City, SD 57701 5. Name and address of every other person who has any record lien on the property: Name Address Township of Hampden 230 South Sporting Hill Road Mechanicsburg, PA 17055 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 Address USA, US Attorney US Department of Justice 228 Walnut Street, P.O. Box 11754 Harrisburg, PA 17108 Internal Revenue Service Technical Support Group US Attorney General US Department of Justice Real Estate Tax Department Domestic Relations Section Commonwealth of PA, Department of Revenue William Green Federal Building 600 Arch Street, Phila., PA 19106 Main Justice Building, Room 5111 10TH & Constitution Avenue NW Washington, DC120531 1 Courthouse Square Carlisle, PA 17013 13 North Hanover Street Carlisle, PA 17013 Bureau of Compliance, PO Box 281230 Harrisburg, PA 17128-1230 7. Name and address of every other person of whom the plaintiff has knowledge who has any interest in the property which may be affected by the sale: Name Address Tenants/Occupants 4603 Hampden Avenue Camp Hill, PA 17011 I verify that the statements made in this affidavit are true and correct to the best of my personal knowledge or information and belief. I understand that false statements herein are made subject to the penalties of 18 Pa.C.S. sec. 4904 relating to unsworn falsification to authorities. UDREN DATED: January 8, 2008 BY: Attorn tiff MARK J. UDREN, ESQUIRE STUART WINNEG, ESQUIRE LORRAINE DOYLE, ESQUIRE ALAN M. MINATO, ESQUIRE CHANDRA M. ARKEMA, ESQUIRE UDREN LAW OFFICES, P.C. BY: Mark J. Udreo, Esquire ATTY I.D. NO. 04$02 WOODCREST CORPORATE CENTER 111 WOODCREST ROAD, SUITE 200 CHERRY HILL, NJ 08003-3620 856-669-5400 Conseco Finance Consumer Discount Company, f/k/a Green Tree Consumer Discount Company Plaintiff V. Margaret S. Keever Defendant(s) ATTORNEY FOR PLAINTIFF COURT OF COMMON PLEAS CIVIL DIVISION Cumberland County NO. 2000-611 TO: ALL PARTIES IN INTEREST AND CLAIMANTS NOTICE OF SHERIFF'S SALE OF REAL PROPERTY OWNER(S): Margaret S. Keever PROPERTY: 4603 Hampden Avenue, Camp Hill, PA 17011 Improvements: RESIDENTIAL DWELLING The above captioned property is scheduled to be sold at the Cumberland County Sheriffs Sale on March 5. 2008, at 10:00 am, in the Commissioners Hearing Room 2ND Floor, Courthouse, Carlisle, Pa. Our records indicate that you may hold a mortgage or judgment on the property which will be extinguished by the sale. You may wish to attend the sale to protect your interests. A Schedule of Distribution will be filed by the Sheriff on a date specified by the Sheriff not later than 30 days after sale. Distribution will be made in accordance with the schedule unless exceptions are filed thereto within 10 days after the filing of the schedule. EXHIBIT A CD w aJ LL W W L 7 a ngH c a?w ca m E in E N E,RW?OB ?N V $ m W O E W O C ? C E E o m C6ci Wo=NIE m _ N 'a of = ?j y- ? y _ L O,p O C ? m 7 W W Co LL - QcEv N O O ' 8sg w C O m N . g W o n m 2 ._ a7 _ y 42 cc it LL m?mmNo L O O M C7 C p ?, p 0 a E2a a) c a p 9 C mmmf°O W E C N 2 4)0 Cl) 0 EM W y,g W W? x'Ca?:o y 4 Q y D cmE=o C7 co . mEE ? c o E o c L to - a ? C ? ? W t+ p '? , ? W O N C C 42 CO) 7" 7 OE E a. 0 cc , . a a ? 8 m? o o >gNa? a3 m L_ yL_ d D)? > C d `O p.? pO° > v??? mt - e m?WgB c° T U E 9 w. r r a E m I m co E c o m _ a d LL m co N bo O a -> o _ h N ? o ? 150 U `- Q Q ? o ?? ? ? a w a a w m ° CD m o z o Z Q _ m d y w a U. L c a z Om S c9 d o O w Vi- O -j W z = u 4C o cn E eh c J p " c w x ca L J- ° t?N? E c u?Q Uo mN m m a g -) U- OZ V Q co Za ?0 CO 0 y z pui o o U•- °-'O g: oco g to a° a ¢ a o 0 4W} = Jiro ca N OW ZN W'? mc? W ow a a 2j E _, d W Zp? Z go vv o z 0 a o ° ?9i 0 Q o m? j o I a E 00 a i ? w L 0 aco ? o c w m o 0 0 a Go = c cc z UU oc0 00? U •- UU r y e+ O m 'a m a co N o ? m N 'C Q z r• N c E E ° w Z 4 O , 1 N r r F r N f0 't U , ,0 'co 01 - e J EXHIBIT A c 0. IL m L 0 Y C d Q. H m m Q 0 U d a as O U. CF) _rn Z' cu 2 U- ti 00 M E O LL d C c4 co co 0 O et O M 0 L Y N ca 2) c0 m LL q W m uw W atl' W W O O E Q L W E m agW8:1e WEmf'W W g W E U C C ID LL . ? 0 >; ?COa U) W EEnwE°^ c y m ? v " 9 0` d 'y 0 Q? CO) LL E?m m5 W "c W V? W W c ORA Ts N V . N _ N O W C r %. 0 2 W G !t C O m 9 ? . m LL mE?$oOo mE? L U m E n L C p 'tl ? E L ? 0 c W mo??W ? C1 Ew m ° c? 0 yVp gY m? 1FF6EEro f E &m ?o q ?t 3DVAOd -S'[1 ki313V? fld v m c> f t c X10.6 Z 1?© 1 Z = s 9 W ? N L M ? ? ® ? 9 A i(. ? { C 'G CCC? ? ? C m . c E -6 > m r? i.ens a ? ES!_ _' l?'?3' W 5? :0: E , . a'O G 7 ¢ ... - c _WOR W 'O c rg Q -. C E W ° ? m ?L Y :C ? . W W w.- v ?j m >oEc Ug?? t =U C ? °'OEQc W E y 7 , _E ? w 0 ?.. $? _a _ ? ip lp F sN W E m ? r LL o EW u m , ???? QQ m H W GO) 0- e 079 m i. ? m ?UCS? x 2) "- m m E a a E { Z F V) V m m ? 8 F- m n m a z W 0 w CD g V o m V N a L E t6 = :0 m ac N N W ca ~ m m t $ E o O., qp dr W ao d- m c r a ca y Go o m 0 0 7 ? E N C ¢ - N a V??y ?O?W to m >? O Cad r ' c U E M ON C> W Z a L a to O O p C d1 O y ci , ad m v,n . U to a ? UJ ?lLp} Q >'z < W O .=? 0 c? a °p0 a M V `o .E Q m c t o ? m ?+ a LL :E co LU 10 W m E ?? m ?U 89 w "3 E 0 z oo?x ?j ?irV z QU5 Q ujo a m° ma my c m ?.r- -cpo C 9? 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N ` ? ?C?r r e C.) v = i < xvp* 0 .= Q? 0 m gM0 M U.S. Postal Service CERTIFIED MAIL Rc-k:;EIPT w' m -(DOme-s-tic Maii Only; No Insurance Coverage Provided) m- W. .r -0 OFFICIAL UZ11,311= I .0 r-3 r-4 Postage $ ` OI O Certified Fee I C3 Return Receipt Fee Postmark O C3 Q (Endorsement Required) Here -- a o Restricted Delivery Fee rr?ra O Q (Endorsement Required) r Lrl Lill -2- -1- Total Postage 8 Fees r Mii t7l ant o INTERNAL REVENUE SERVICE ?.•.??. a I oa TECHNICAL SUPPORT GROUP ------------- M C3 ' or Po e, WILLIAM GREEN FEDERAL BUILDING ti cir ; s1$ 600 ARCH STREET, ROOM 3259 PHILADELPHIA, PA 19106 EXHIBIT A MR N 00 J ?n z oOdH LW6.000•Zo-ML NSd (OW-OH) 9ooz PnOnV'0088 uuoj Sd ./aInbul ue 6upew uegsl 31 tussaid pue idloosi s1U3 •AB$ '.1NV180dW1 • lew pus eBelsod 411M legal xws pue 4004ep'pepeeu lou sl ldleoaJ IIBW POIJIVOO 841 uo ewlsod a;I Bul)pewisod jo; eolBo isod e4i le elo -lue eta luesaid eseel 'pealsep sl idlem I19W polili1eO a4l uo >Nuwisod e P ¦ Rani; peP.0sey„ lueweswpue e4i Lalm aoeldllew e4i )Iaew jo Nielo e4i eslApV •3 eBe pezpo4lns s,eesseippe Jo eesssipps 843 o1 pelouisei eq Aew ANenllep 'eel leuowppe ue` and ¦ 91 idleosu IIuiN pewlieO inoA uo Maewisod ®Sdsn a 'Idle= uanlea e1e11Onp e Jo; JOARm ee; a eNRm of '.Pelsenbeu Aeoeu wmey eosOpw esaoPu3 •eej e41 JeAoo of eBelsod elgeolidde ppe pug elopm e4i of 14486 uuOj Sd) idWOU wnleu a gwuv pus eleldwoo eseeld "njes ldleoeu wnleu ulelgo of ?4eNlep ;o;oad upload of pelsenbea eq ?Csw wffloey wnley a 'ee; IsuOwPpe us iod ¦ -lwvj JOd TOW Pa91POO LlMm a330U$ Ouud 81 3? d 0 3ONV U SNIT ON ¦ 'flew leuol;ewelul ;o soup Auu x4 elgepune lou sI IRW pewusO ¦ *IMW 4JWd JO ®0eW sselO.lsA-i 4nM peulquwo aq AINO Auw IMM PBIiWeO ¦ :a wpu;uoU SuWodiu; siveA oru4 Jo; eolAJOS FOWOd e4i Aq KeI Aienpep 1O pjooq V ¦ ',. omolpw inoA JOi JWWPI enblun V ¦ 49M 6u01sw V ¦ :SOPlead 11ON POIJIIJ93 EXH1BITA °I Ice w? tl o7dG'> ? H 0 * 41 O F-+ Cr„ t?l d y y u?0rA H zd d H tai rA 41. O O C m W: a X00 00 mpT ETCU) o? rop ? m ?w p ro V US. Postal Service CERTIFIED MAIL RECEIPT •P:-ovided) try I Ln (Domestic MI M I**- r -1-IIAIIIIIIINIM A U co: 43 Postage $ 1 r-1 r-1 O ! C3 Cerutled Fee Postmark r? 1 Here ? ; p Return Receipt Fee O I C7 (Endorsement Required) O Q Restricted Dellvery Fee O (Endorsement Requre e i O Q -j- r Total Postage & Fees $ m, m sent ro US ATTORNEY GENERAL C] O Street, US DEPARTMENT OF JUSTICE p m or PO r MAIN JUSTICE BUILDING, ROOM 5111 sf:10T" & CONSTITUTION AVENUE NW WASHINGTON, DC 20531 r EXHIBIT A )6* 9 CA) z 05 w tga oze, . o Val t7 a ' pt-< A? 0-3 sail G bd 0 ?}3a ro m t1d 81= do O C3 a p ao K C3 013 i g 02 -? ? ? w w tr o ? 3 1313 1313 C LW6.000.mDCgL NSd (e&-ed 11002 WMV'0096 uJOzlSd i •l?lBbul ue 6ulgeul uegm Il Iussead pue Idlessi slgl BARS ;LNV180dW1 •llew Pug e6g;sod L11 legal 6ul?y xule Pug 4 p;rwu;ou s Id to IleW Pellll1eJ "I uo ??1I?awisod s ll eugsod col eawo X es 1g 010 -Ills 641 lueswd esseld'pwlsep sI ldlaow IIgW P9WjjeC) ey; uo )Ijsugsod a 11 ¦ 041 411M soeldlletu eyi Wgw jo)f.rep e#4; esj Imu POzzlay a seewess ppe ,o ee989JPPO ey; 01 P%Wisei eq Few NeAllep `eel RWPIPPB us ,od ¦ 91;dlem lion peo.wec) anoA uo m.rew;sod ®SdS(19 Ildleow wnM e1=0ll2np a col J"BM eel g enleow oy '.Pelsenbeu 10woU wrueu eoeldllew eslopu3 'eel 811 Jenoo of e6e;sod elgualidds ppe Pug elolpe ey10; It WS wed Sd) idleoeU wrgeU a Wnu pus eleldtuoo esge d "/uss;c4eoeu wr4% ulsl4o ol'/+eMIeP 1o pad ep.md o; pe;senbei eq Avw jalw&y waled Wee; IguolllPPe us Jo j ¦ IIE" peaelopeu jo pernsul aeplsuoo esseld 'selggmgA ?oj '11181V Pemlieo 4AM 03alAOUd SI 3oVU3Aoo 3ONVUf1SNl ON ¦ 'flew Ieuopwelul to esep hue aol elggleng lou sl IIgW pelpeo ¦ '011eW Agjopd Jo ®l!en salo-m1=1 tW Peulquwo eq A-INO Am IIBW poWoo ¦ mispuilueli lueliodwl alga( OAQ col 901AJOS lulsod etp dq;de)l fjoAllep 10 iljoo .r V ¦ eoeK4mtu ino6 jol Je1111uePl enblun V • As= 6ulllew v ¦ :SBPIAad HOW P9111IJ93 V ?ti• UDREN LAW OFFICES, P.C. ATTORNEY FOR PLAINTIFF MARK J. UDREN, ESQUIRE - ID #04302 STUART WINNEG, ESQUIRE - ID #45362 LORRAINE DOYLE, ESQUIRE - ID #34576 ALAN M. MINATO, ESQUIRE - ID #75860 CHANDRA M. AR2=4A, ESQUIRE - ID #203437 WOODCREST CORPIORATE CENTER 111 WOODCREST 9OAD, SUITE 200 CHERRY HILL, NU 08003-3620 856-669-5400 Conseco Finance Consumer `COURT OF COMMON PLEAS Discount Company, f/k/a Green ;CIVIL DIVISION Tree Consumer Discount Company ;Cumberland County Plaintiff ::NO. 2000-611 V. Margaret S. Keever Defendant(s) CERTIFICATE OF SERVICE The undersigned, hereby certifies that they have served true and correct copies of the Notice of Sale upon the following person(s) named herein at their last known address or their attorney of record. XXXxxX Regular First Class Mail Certified Mail Other (certificate of mailing) Date Served: January 22, 2008 TO: USA, US Attorney US Department of Justice 228 Walnut Street, P.O. Box 11754 Harrisburg, PA 17108 UDREN LAW OFFICES, P.C. BY: Attorneys fo aintiff MARK J. UDREN, ESQUIRE STUART WINNEG, ESQUIRE LORRAINE DOYLE, ESQUIRE ALAN M. MINATO, ESQUIRE CHANDRA M. ARKEMA, ESQUIRE EXHIBIT B i . H i O K oo ?'?I. pD ?X?l Fj i W F-+ rtt F-4 (D rt rt rt (D (D 0 N (D t„h rt 0 rt >7 (D i O 0 Z .a ? y 70 Q ? Z -I Z 0 ? p x© %C"n' 0- -4 X n Cpl -1 m ?OMl r? vrncw) 2- v pip -0, -o -? CO Cc ? 0 0 Postage $ r -I 1 r q Certified Fee p 1 p ---??? p p Retum Recelpt Fee (Endorsement Required) F ° I ° RsshWed Fee t p 1 p (Endorsement q gWred Ln 1-n m j m Total Postage & Fees on' o. USA, US AT1'(?RNBy ! n c -n MMO c3, US DAPA " JUSTI CE pip MPOHFEDERAL-I;UIL3?G 228 city s 1f[TI STI?T PO „ . BOX 117,54 HARRISBURG, PA 17108 fps R '`' EXHIBIT B y" t?4 .?....r.y.,..u,•..,.,.,.,.•,.........?.?w.s?,?.....,,, -.,i,i,.ue eta ,?.,".dd•.t? CD ' O W OD n 3 ?I 4 N z It .J C3 O Ir I w to ?C3 O O tC3 la tp it I ?.1 C3 A . Qi O O r - f o n 3 °' o Am Zr »' ? 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N CO V L O t o n t 7D O r r c; 0 t - J LT rn L m LL ti LC co O LL CO IL EXHIBIT 90 Conseco Finance Consumer Discount Company In the Court of Common Pleas of f/k/a Green Tree Consumer Discount Company Cumberland County, Pennsylvania VS Writ No. 2000-611 Civil Term Margaret S. Keever Kenneth Gossert, Deputy Sheriff, who being duly sworn according to law, states that on December 04, 2007 at 2055 hours, he served a true copy of the within Real Estate Writ, Notice and Description, in the above entitled action, upon the within named defendant, to wit: Margaret S. Keever, by making known unto Stephan Keever, adult son of Margaret S. Keever, at 4603 Hampden Ave., Camp Hill, Cumberland County, Pennsylvania its contents and at the same time handing to him personally the said true and correct copies of the same. Cpl. Timothy Reitz, Deputy Sheriff, who being duly sworn according to law, states that on January 10, 2008 at 1050 hours, he posted a true copy of the within Real Estate Writ, Notice, Poster and Description, in the above entitled action, upon the property of Margaret S. Keever located at 4603 Hampden Ave., Camp Hill, Cumberland County, Pennsylvania according to law. R. Thomas Kline, Sheriff, who being duly sworn according to law, states he served the above Real Estate Writ, Notice, Poster and Description in the following manner: The Sheriff mailed a notice of the pendency of the action to the within named defendant, to wit: Margaret S. Keever by regular mail to her last known address of 4603 Hampden Ave., Camp Hill, PA 17011. This letter was mailed under the date of January 8, 2008 and never returned to the Sheriffs Office. R. Thomas Kline, Sheriff, who being duly sworn according to law, states this writ is returned STAYED per letter of request from Attorney Udren. Sheriffs Costs: Docketing 30.00 Poundage 19.10 Posting Bills 15.00 Advertising 15.00 Law Library .50 Prothonotary 2.00 Mileage 28.80 Levy 15.00 Surcharge 20.00 Postpone Sale 40.00 Law Journal 389.00 Patriot News 383.54 Share of Bills 16.17 J -alb ?r/b $ 974.11 So Answers: -??''?? R. Thomas Kline, Sheriff BY Real Estate rgeant Co. Lh? G y739 .iN z.s I UDREN LAW OFFICES, P.C. ATTORNEY FOR PLAINTIFF BY: Xark J. Udren, Esquire ATTY I.D. NO. 04302 WOODCREST CORPORATE CENTER 111 WOODCREST ROAD, SUITE 200 CHERRY HILL, NJ 08003-3620 856-669-5400 pleadings@udren.com Conseco Finance Consumer =COURT OF COMMON PLEAS Discount Company, f/k/a Green ':.CIVIL DIVISION Tree Consumer Discount Company ;Cumberland County Plaintiff V. :MORTGAGE FORECLOSURE Margaret S. Keever ::NO. 2000-611 Defendant(s) AFFIDAVIT PURSUANT TO RULE 3129.1 Conseco Finance Consumer Discount Company, f/k/a Green Tree Consumer Discount Company, Plaintiff in the above action, by its attorney, Mark J. Udren, ESQ., sets forth as of the date the Praecipe for the Writ of Execution was filed the following information concerning the real property located at: 4603 Hampden Avenue, Camp Hill, PA 17011 1. Name and address of Owner(s) or reputed Owner(s): Name Address Margaret S. Keever 4603 Hampden Avenue Camp Hill, PA 17011 2. Name and address of Defendant(s) in the judgment: Name Address SAME AS #1 ABOVE 3. Name and address of a record lien on the r Name Indian Rocks POA, Inc. 4. Name and address of of record: Name every judgment creditor whose judgment is eal property to be sold: Address P.O. Box 540, Greentown, PA 18426 the last recorded holder of every mortgage Address Conseco Finance Consumer Discount Company, f/k/a Green Tree Consumer Discount Company Commercial Credit Corp. 7360 South Kyrene Road Tempe, AZ 85283 3401 Hartzdale Drive, Suite 126 Camp Hill, PA 17011 i 5. Name and address of every other person who has any record lien on the property: Name Address Township of Hampden 230 South Sporting Hill Road Mechanicsburg, PA 17055 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 Address Real Estate Tax Department 1 Courthouse Square Carlisle, PA 17013 Domestic Relations Section 13 North Hanover Street Carlisle, PA 17013 Commonwealth of PA, Bureau of Compliance, PO Box 281230 Department of Revenue Harrisburg, PA 17128-1230 7. Name and address of every other person of whom the plaintiff has knowledge who has any interest in the property which may be affected by the sale: Name Address Tenants/Occupants 4603 Hampden Avenue Camp Hill, PA 17011 I verify that the statements made in this affidavit are true and correct to the best of my personal knowledge or information and belief. I understand that false statements herein are made subject to the penalties of 18 Pa.C.S. sec. 4904 relating to unsworn falsification to authorities. UDREN LAW OFFICES, P.C. DATED: October 1, 2007 rk J. Udrtn, ESQ. torney for Plaintiff r UDREN LAW OFFICES, P.C. ATTORNEY FOR PLAINTIFF BY: Mark J. Udren, Esquire ATTY I.D. NO. 04302 WOODCREST CORPORATE CENTER 111 WOODCREST ROAD, SUITE 200 CHERRY HILL, NJ 08003-3620 856-669-5400 pleadings@udren.com Conseco Finance Consumer :COURT OF COMMON PLEAS Discount Company, f/k/a Green :CIVIL DIVISION Tree Consumer Discount Company :Cumberland County Plaintiff V. :MORTGAGE FORECLOSURE Margaret S. Keever :NO. 2000-611 Defendant (s) NOTICE OF SHERIFF'S SALE OF REAL PROPERTY To: Margaret S. Keever 4603 Hampden Avenue Camp Hill, PA 17011 Your house (real estate) at 4603 Hampden Avenue, Camp Hill, PA 17011 is scheduled to be sold at the Sheriff's Sale on March 5, 2008, at 10:00 am in the Commissioners Hearing Room, 2nd Floor, Courthouse, Carlisle, PA, to enforce the court judgment of $111,893.91, obtained by Plaintiff above (the mortgagee) against you. If the sale is postponed, the property will be relisted for the Next Available Sale. NOTICE OF OWNER'S RIGHTS YOU MAY BE ABLE TO PREVENT THIS SHERIFF'S SALE To prevent this Sheriff's Sale, you must take immediate action: 1. The sale will be cancelled if you pay to the mortgagee the back payment, late charges, costs and reasonable attorney's fees. To find out how much you must pay, you may call: (856) 669-5400. 2. You may be able to stop the sale by filing a petition asking the Court to strike or open the judgment, if the judgment was improperly entered. You may also ask the Court to postpone the sale for good cause. 3. You may also be able to stop the sale through other legal proceedings. You may need an attorney to assert your rights. The sooner you contact one, the more chance you will have of stopping the sale. (See notice on page two on how to obtain an attorney.) , YOU MAY STILL BE ABLE TO SAVE YOUR PROPERTY AND YOU HAVE OTHER RIGHTS EVEN IF THE SHERIFF'S SALE DOES TAKE PLACE. 1. If the Sheriff's Sale is not stopped, your property will be sold to the highest bidder. You may find out the price bid by calling 856-669- 5400. 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 856-669-5400. 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 after 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 Schedule of 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 TARE THIS PAPER TO YOUR LAWYER AT ONCE. IF YOU DO NOT HAVE A LAWYER OR CANNOT AFFORD ONE, GO TO OR TELEPHONE THE OFFICE LISTED BELOW TO FIND OUT WHERE YOU CAN GET LEGAL HELP. LAWYER REFERRAL SERVICE Cumberland County Bar Association 2 Liberty Avenue, Carlisle, PA 17013 (717)249-3166 & (800)990-9108 ASSOCIATION DE LICENCIDADOS Cumberland County Bar Association 2 Liberty Avenue, Carlisle, PA 17013 (717)249-3166 & (800)990-9108• ALL THAT CERTAIN [at or tract of land situate in the Township of Hampden, County of Cumberland, and State of Pennsylvania, more particularly bounded and described as follows according to a survey of Garrit J. Betz, Registered Surveyor, dated January 11, 1971, to wit: BEGINNING at a point on the northern litre of Hampden Avenue, said point being by same measured in a southwesterly direction 90.0 feet from the northwest corner of Clearview Drive and Hampden Avenue; thence South 61 degrees 26. minutes West along. said northern line of Hampden Avenue a distance of 72.0 feet to a hub; thence North 38 degrees 34 minutes West along the eastern line of lands now or formerly of George D. Sauers a distance of 100.00 feet to an Iron pipe; thence North 61 degrees 26 minutes East along the southern line of lands now or formerly of Roger L. Knecht and Jack H. Forten, respectively, a distance of 72.0 feet to a hub; thence South 38 degrees 34 minutes East along the line of adjoiner between Lots Nos. 191 and 192 on the hereinafter mentioned Plan of Lots a distance of 100.0 feet to a hub, the point and place of BEGINNING. BEING Lot No. 191, Block "J" on the Plan of Clearview Farm recorded in the Recorder's Office of Cumberland County, recorded in Plat Book 9, Page 13. HAVING THEREON ERECTED a one story frame dwelling with car port known and numbered as 4603 Hampden Avenue.. Parcel #: 10-21-0279-196 BEING KNOWN AS: 4603 HAMPDEN AVENUE, CAMP HILL, PA 17011 PROPERTY ID NO.: 21-0279-195 TITLE TO SAID PREMISES IS VESTED IN MARGARET S. KEEVER BY DEED FROM FREDERICK W. KEEVER, II, AND MARGARET S. KEEVER, HIS WIFE DATED 11/23/88 RECORDED 1/6/89 IN DEED BOOK 33-T PAGE 320. WRIT OF EXECUTION and/or ATTACHMENT CONWONWEALTH OF PENNSYLVANIA) COUNTY OF CUMBERLAND) NO 00-611 Civil CIVIL ACTION - LAW TO THE SHERIFF OF CUMBERLAND COUNTY: To satisfy the debt, interest and costs due CONSECO FINANCE CONSUMER DISCOUNT COMPANY f/k/a GREEN TREE CONSUMER DISCOUNT COMPANY, Plaintiff (s) From MARGARET S. KEEVER (1) You are directed to levy upon the property of the defendant (s)and to sell SEE LEGAL DESCRIPTION. (2) You are also directed to attach the property of the defendant(s) not levied upon in the possession of GARNISHEE(S) as follows: and to notify the garnishee(s) that: (a) an attachment has been issued; (b) the garnishee(s) is enjoined from paying any debt to or for the account of the defendant (s) and from delivering any property of the defendant (s) or otherwise disposing thereof; (3) If property of the defendant(s) not levied upon an subject to attachment is found in the possession of anyone other than a named garnishee, you are directed to notify him/her that he/she has been added as a garnishee and is enjoined as above stated. Amount Due $111,893.91 L.L. $.50 Interest from 3/21/00 to Date of Sale 3/05/08 ongoin Per Diem of $25.66 to actual date of sale including if sale is held at a later date - $74,593.62 Atty's Comm % Due Prothy $2.00 Atty Paid $2,296.63 Plaintiff Paid Other Costs Date: 10/05/07 (Seal) REQUESTEgG PARTY: Name MARK J. UDREN, ESQUIRE Address: UDREN LAW OFFICES, P.C. isi ,ls?c, ?. (. era Cuftis R. Long, ProthonotaA't ryBy: Deputy WOODCREST CORPORATE CENTER 111 WOODCREST ROAD, SUITE 200 CHERRY HILL, NJ 08003-3620 Attorney for: PLAINTIFF Telephone: 856-669-5400 Supreme Court ID No. 04302 Real Estate Sale #29 On November 1, 2007 the Sheriff levied upon the defendant's interest in the real -property situated in Hampden Township, Cumberland County, PA Known and numbered as 4603 Hampden Ave. Camp Hill, more fully described on Exhibit "A" filed with this writ and by this reference incorporated herein. Date: November 1, 2007 By"' Real Es a Sergeant C r L 09Z PROOF OF PUBLICATION OF NOTICE IN CUMBERLAND LAW JOURNAL (Under Act No. 587, approved May 16, 1929), P. L.1784 COMMONWEALTH OF PENNSYLVANIA COUNTY OF CUMBERLAND ss. Lisa Marie Coyne, Esquire, Editor of the Cumberland Law Journal, of the County and State aforesaid, being duly sworn, according to law, deposes and says that the Cumberland Law Journal, a legal periodical published in the Borough of Carlisle in the County and State aforesaid, was established January 2, 1952, and designated by the local courts as the official legal periodical for the publication of all legal notices, and has, since January 2, 1952, been regularly issued weekly in the said County, and that the printed notice or publication attached hereto is exactly the same as was printed in the regular editions and issues of the said Cumberland Law Journal on the following dates, viz: January 25, February 1 and February 8, 2008 Affiant further deposes that he is authorized to verify this statement by the Cumberland Law Journal, a legal periodical of general circulation, and that he is not interested in the subject matter of the aforesaid notice or advertisement, and that all allegations in the foregoing statements as to time, place and character of publication are true. Marie SWORN TO AND SUBSCRIBED before me this 8 day of Febr1gM 2008 Notary NOTARIAL SEAL DE80RAH A COLLINS Notory Public CARLISLE BORO, CUMBERLAND COUNTY My Commission Expires Apr 28, 2010 i" mum a"s NO." Writ No. 2000-611 Civil Conseco Finance Consumer Discount Company f/k/a Green Tree Consumer Discount Company vs. Margaret S. Keever Atty.: Mark Udren DESCRIPTION ALL THAT CERTAIN lot or tract of land situate in the Township of Hampden, County of Cumberland, and State of Pennsylvania, more particularly bounded and described as follows according to a survey of Garrit J. Betz, Registered Surveyor, dated January 11, 1971, to wit: BEGINNING at a point on the northern line of Hampden Avenue, said point being by same measured in a southwesterly direction 90.0 feet from the northwest corner of Clearview Drive and Hampden Av- enue; thence South 51 degrees 26 minutes West along said northern line of Hampden Avenue a distance of 72.0 feet to a hub; thence North 38 degrees 34 minutes West along the eastern line of lands now or formerly of George D. Sauers a distance of 100.00 feet to an iron pipe; thence North 51 degrees 26 minutes East along the southern line of lands now or formerly of Roger L. Knecht and Jack H. Forten, respectively, a dis- tance of 72.0 feet to a hub; thence South 38 degrees 34 minutes East along the line of adjoiner between Lots Nos. 191 and 192 on the here- inafter mentioned Plan of Lots a distance of 100.0 feet to a hub, the point and place of BEGINNING. BEING Lot No. 191, Block'J" on the Plan of Clearview Farm recorded in the Recorder's Office of Cumber- land County, recorded in Plat Book 9, Page 13. HAVING THEREON ERECTED a one story frame dwelling with car port kw m and numbered as 4603 Hats pdm Avenue. Pond #:10-21-0279-195. KNt3`111N AB: 4603 HAMP- DEN AVENUE, CAMP HILL, PA 17011. PROPERTY ID NO.: 21-0279- 195. TITLE TO SAID PREMISES IS VESTED IN Margaret S. Keever by deed from Frederick W. Keever, II, and Margaret S. Keever, his wife dated 11/23/88 recorded 1/6/89 in Deed Book 33-T Page 320. The Patriot-News Co. 812 Market St. Harrisburg, PA 17101 Inquiries - 717-255-8292 CUMBERLAND COUNTY SHERIFFS OF CUMBERLAND COUNTY COURT HOUSE CARLISLE PA 17013 thtPatriot News Now you know THE PATRIOT NEWS THE SUNDAY PATRIOT NEWS Proof of Publication Under Act No. 587, Approved May 16, 1929 Commonwealth of Pennsylvania, County of Dauphin} ss Joseph A. Dennison, being duly sworn according to law, deposes and says: That he is the Assistant Controller of The Patriot News Co., a corporation organized and existing under the laws of the Commonwealth of Pennsylvania, with its principal office and place of business at 812 to 818 Market Street, in the City of Harrisburg, County of Dauphin, State of Pennsylvania, owner and publisher of The Patriot-News and The Sunday Patriot-News newspapers of general circulation, printed and published at 812 to 818 Market Street, in the City, County and State aforesaid; that The Patriot-News and The Sunday Patriot-News were established March 4th, 1854, and September 18th, 1949, respectively, and all have been continuously published ever since; That the printed notice or publication which is securely attached hereto is exactly as printed and published in their regular daily and/or Sunday/ Metro editions which appeared on the date(s) indicated below. That neither he nor said Company is interested in the subject matter of said printed notice or advertising, and that all of the allegations of this statement as to the time, place and character of publication are true; and That he has personal knowledge of the facts aforesaid and is duly authorized and empowered to verify this statement on behalf of The Patriot-News Co. aforesaid by virtue and pursuant to a resolution unanimously passed and adopted severally by the stockholders and board of directors of the said Company and subsequently duly recorded in the office for the Recording of Deeds in and for said County of Dauphin in Miscellaneous Book "M", Volume 14, Page 317. PUBLICATION COPY This ad ran on the date(s) shown below: 01/30/08 02/06/08 02/13/08 108 A. D. COMMONWEALTH OF PENNSYLVANIA Notarial Seal Shwb L Kerrer, Notary Public City Of Wwrisburg; Dauphin County My Cafa tiiiiw Expires Nov. 26, 2011 Member, Pennsylvania Association of Notaries REAL ESTATE SALE NO. 29 Writ No. 2000-611 Civil Term Conseco Finance Consumer Discount Company f/k(a Green Tree Consumer Discount Company VS Margaret S. Keever Attorney Mark Udren DESCRIPTION ALL THAT CERTAIN lot or tract of land situate in the Township of Hampden, County of Cumberland, and state of Pennsylvania, more particularly bounded and described as follows according to a survey of Garrit J. Betz, Registered Surveyor, dated January 11, 1971, to wit: BEGINNING at a point on the northern line of Hampden Avenue, said point being by same measured in a southwesterly direction 90.0 feet from the northwest comer of Ciearview Drive and Hampden Avenue; thence South 51 degrees 26 minutes West along said northern line of Hampden Avenue a distance of 72.0 feet to a hub; thence North 38 degrees 34 minutes West along the eastern line of lands now or formerly of George D. Sauers a distance of 100.00 feet to an iron pipe; thence North 51 degrees 26 minutes East along the southern We of lands now or formerly of Roger L. Knecht and Jack H. Forten, respectively, a distance of 72.0 feet to a hub; thence South 38 degrees 34 minutes East along the line of adjoiner between Lots Nos. 191 and 192 on the hereinafter mentioned Plan of lots a distance of 100.0 feet to a hub, the point and place of BEGINNING. BEING Lot No. 191, Block "J" on the Plan of Clearview Farm recorded in the Recorder's Office of Cumberland County, recorded in Plat Book 9, Page 13. HAVING THEREON ERECTED a one story frame dwelling with car port known and numbered as 4603 Hampden Avenue. Parce- #:10-21-0279-195 BFING KNOWN AS: 4603 HAMPDEN AVE=` "JE, CAMP HILL., PA 17011 PROPPRTY ID NO-: 21-0279-195 TITLE TO SAID PREMISES IS VESTED IN MARGARET S. KEEVER BY DEED FROM FREDERICK W. KEEVER, II, AND MARGARET S. KEEVER, HIS WIFE DATED 11123188 RECORDED 1/6189 IN DEED BOOK I VT PAGE 320. UDREN LAW OFFICES, P.C. MARK J. UDREN, ESQUIRE - ID #04302 STUART WINNEG, ESQUIRE - ID #45362 LORRAINE DOYLE, ESQUIRE - ID #34576 ALAN M. MINATO, ESQUIRE - ID #75860 CHANDRA M. ARKEMA, ESQUIRE - ID #203437 LOUIS A. SIMONI, ESQUIRE - ID #200869 WOODCREST CORPORATE CENTER 111 WOODCREST ROAD, SUITE 200 CHERRY HILL, NJ 08003-3620 856-669-5400 pleadings@udren.com Conseco Finance Consumer Discount Company, f/k/a Green Tree Consumer Discount Company 7360 South Kyrene Road Tempe, AZ 85283 Plaintiff V. Margaret S. Keever 4603 Hampden Avenue Camp Hill, PA 17011 Defendant(s) ATTORNEY FOR PLAINTIFF COURT OF COMMON PLEAS CIVIL DIVISION Cumberland County NO. 2000-611 SUGGESTION OF BANKRUPTCY To the Prothonotary: Kindly note on the record that the above Defendant, Margaret S. Keever has filed Chapter 13 Bankruptcy in the Middle District of Pennsylvania on February 26, 2008, Bankruptcy Case No. 08-00627. UDREN LAW OFF S, P.C. • BY: Attorn ys for Plaintiff MARK J. UDREN, ESQUIRE STUART WINNEG, ESQUIRE LORRAINE DOYLE, ESQUIRE ALAN M. MINATO, ESQUIRE CHANDRA M. ARKEMA, ESQUIRE ,-• UIS A. SIMONI, ESQUIRE ©3ay ooc ??.. ?:7 r_-r fir. ??, ?rz? ' x 3 ?._'{ ?.. ' , ?.. ... C? _t. ^-C