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Home My WebLink About02-5573 <GOLDBECK McCAFFERTY & McKEEVER By: JOSEPH A. GOLDBECK, JR. ATTORNEYI.D. #16132 SUITE 500 - THE BOURSE BLDG. 111 S. INDEPENDENCE MALL EAST PHILADELPHIA, PA 19106 (215) 627-1322 ATTORNEY FOR PLAINTIFF CITIFINANCIAL MORTGAGE CO. INC. F/KJ A FORD CDC 1111 Northpoint Drive Building 4, Suite 100 Coppell, TX 75019-3931 IN THE COURT OF COMMON PLEAS OF Cumberland COUNTY CIVIL ACTION - LAW Plaintiff ACTION OF MORTGAGE FORECLOSURE vs. SUSAN K. PALUMBO SAMUEL R. PALUMBO Mortgagor(s) and Real Owner(s) 234 E. Old York Road CarIisle,PA 17013 Term No. 0;). -SS1'J C;.~CT'in.J. CIVIL ACTION: MORl GAGE FOReCLOSURE Defendant(s} TillS FIRM IS A DEBT COLLECTOR AND WE ARE ATTEMPTINGTO COLLECT A DEBT OWED TO OUR CLIENT. ANY INFORMATION OBTAINED FROM YOU WILL BE USED FOR THE PURPOSE OF COLLECTING THE DEBT. NOTICE You have been sued in court. If yon wish to defend against the claims set forth in the following pages, you must take action within twenty (20) days after the Complaint and notice are served, by entering a written appearance personally or by attorney and :filing in writing with the court your defenses or objections to the claims set forth against you. You are warned that if you fail to do so the case may proceed without you and a judgment may he entered against you by the Court without further notice for any money claim in the Complaint offor 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 POPER TO YOUR LAWYER AT ONCE. IF YOU DO NOT HAVE A LAWYER OR CANNOT AFFORD ONE, GO TO OR TELEPHONE THE OFFICE SET FORTH BELOW TO FIND OUT WHERE YOU CAN GET LEGAL HELP. CUMBERLAND COUNTY BAR ASSOCIATION 2 Liberty Avenue Carlisle,PA 17013 LEGAL SERVICES INC 8 Irvine Row Carlisle,PA 17013 717-243-9400 AVISO LE HAN DEMANDADO A USTED EN LA CORTE. SI DESEA DEFENDERSE CONTRA LAS QUEJAS PERESENTADAS, ES ABSOLUTAMENTE NECESSARIO QUE USTED RESPONDA DENTRO DE 20 DIAS DESPUES DE SER SERV1DO CON ESTA DEMANDA Y A VISO. PARA DEFENDERSE ES NECESSARIO QUE USTED, 0 SU ABOGADO, REGISTRE CON LA CORTE EN FORMA ESCRITA, EL PUNTO DE VISTA DE USTED Y CUALQUlER OBJECCION CONTRA LAS QUEJAS EN ESTA DEMANDA. RECUERDE: SI USTED NO REPONDE A ESTA DEMANDA, SE PUEDE PROSEGlJIR CON EL PROCESO SIN SU PART1CIPAC10N. ENTONCES, LA COOTE PUEDE, SIN NOTIF1CARIO, DECIDIR A FAVOR DEL DEMANDANTE Y REQUERIRA QUE USTED CUMPLA CON TODAS LAS PROVISIONES DE EST A DEMANDA. POR RAZON DE ESA DECISION, ES POSSIBLE QUE USTEn PUEDA PERDER DINERO, PROPIEDAD U OTROS DERECHOS IMPORTANTES. LLEVE EST A DEMANDA A UN ABOGADO IMMEDIATEAMENTE. S1 NO CONOCE A UN ABOGADO, LLAME AL "LAWYER REFERENCE SERVICE" (SERVICIO DE REFERENCIA DE ABOGADOS), (215) 238-6300. CUMBERLAND COUNTY BAR ASSOCIATION 2 Liberty A venue Carlisle, PA 17013 LEGAL SERVICES INC 8 Irvine Row Carlisle,PA 17013 717-243-9400 COMPLAINT IN MORTGAGE FORECLOSURE I. Plaintiff is CITIFINANCIAL MORTGAGE CO. INC. F/KJA FORD CDC, 1111 Northpoint Drive, Building 4, Suite 100 Coppell, TX 75019-3931. 2. The name(s) and addressees) of the Defendant(s) is/are SUSAN K. PALUMBO, 113 Whiskey Springs Road, DiIlsburg, PA 17019 and SAMUEL R. PALUMBO, 113 Whiskey Springs Road, DiIlsburg, PA 17019, who is/are the mortgagor(s) and real owner(s) of the mortgaged premises hereinafter described. 3. On October 30, 1996 mortgagor(s) made, executed and delivered a mortgage upon the premises hereinafter described to CITIFINANCIAL MORTGAGE CO. INC. F/KJA FORD CDC, which mortgage is recorded in the Office of the Recorder of Deeds ofCumberJand County as Book 1350 Page 267. The mortgage has not been assigned unless said assignment to the Plaintiff is hereafter mentioned. These documents are matters of public record and are incorporated herein by reference in accordance with Pennsylvania Rule of Civil Procedure 1019(g). 4. The premises subject to said mortgage is described as attached. 5. The mortgage is in default because monthly payment of principal and interest upon said mortgage due June 04, 2002, 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 Interest from 05/0412002 through 11/30/2002 at 10.6500% Per Diem interest rate at $23.33 Attorney's Fee at 5.0% of Principal Balance $79,962.80 $4,922.62 $3,998.14 Costs of suit and Title Search $750.00 $8~,633.56 +$3,105.26 +$640.50 +$2,675.00 $96,054.32 Escrow advances Fees DRM Expenses 7. The Attorney's Fees set forth above are in conformity with the Mortgage documents and Pennsylvania law, and, will be collected in the event of a third party purchaser at Sheriffs Sale. If the Mortgage is reinstated prior to the Sale reasonable Attorney's Fees will be charged based on work actually performed. 8. Notice ofIntention to Foreclose and a Notice of Homeowners' Emergency Mortgage Assistance has been sent to Defendant(s) by Certified and regular mail, as required by Act 160 of 1998 of the Commonwealth of Pennsylvania, on the date(s) set forth in the true and correct copy of such notice(s) attached hereto as Exhibit "A". The Defendant(s) haslhave not had the required face-to-face meeting within the required time and Plaintiff has no knowledge of any such meeting being requested by the Defendant(s) through the Plaintiff, the Pennsylvania Housing Finance Agency, or any appropriate Consumer Credit Counseling Agency. WHEREFORE, Plaintiff demands judgment in mortgage foreclosure in the sum of $96,054.32, together with interest at the rate of$23.33, per day and other expenses incurred by the Plaintiff which are properly chargeable in accordance with the terms of the mortgage, and for the foreclosure and sale ofthe mortgaged premises. By: VERIFICATION I, , as the representative of the Plaintiff corporation within named do hereby verify that I am authorized to and do make this verification on behalf of the Plaintiff corporation and the facts set forth in the foregoing Complaint are true and correct to the best of my knowledge, information and belief. I understand that false statements therein are made subject to the penalties of 18 Pa, C.S. 4904 relating to unsworn falsification to authorities. Date: II-l/UV ~'lll'''T_W.''.''lr Oe.od, Sharl Fo'm. Acl 0' 1__........... la, l"t'Iolo.Rfta",I... 11.....,I1.n.l..c..''''',."..,... ~ ~. \J'-...... _ 0 ';'~ . il.~. "'Ilia za [,:i tBttb, ~bi~ MADe THe ;{Cf i.:€. daV Q{ Hay of rlllr I.o/'({ 'II'" th{)II.~f/lId ni1l/' hU1Irfrl'd eightY-four (1984). 10 38 ill the I/ear n/o.'TWJ.;r:,y DAVID G. KUTZ and SHIRLENE M. KUTZ, his wife, of 234 East Old York Road, Carlisle, CUmberland County, Pennsylvania, hereinafter called ,,"', SUSAN K. PALUMBO and SAMUEL R. PALUMBO, her husband, of R. D. 1, G1'11l1fflrS. Box 289A, Lewisberry, PennSYlvania, hereinafter called 1I',TNf.'S.W;TH. 'h" i" ,.""..id"""'i"" "lane Dollar ($1.00) and other G/'f1uft'I!S: I ,~ valuable consideration Dnllr!/'s, i" h"''''''"id. //". ''''','i", "h""""1 i.. h,,.,.,,y ",k,,,,,.,,,,,,,.". II" '"id ",'anl.,.s d" ''''''1>" "mn' ,,"', '''''''''Y ,,, //". .<aid """"""'s. their heirs and assigns as tenants by the entireties: ALL that certain tract of land with the improvements thereon erected, situate in South Middleton Township, CUmberland County, PennSYlvania; bounded and described as follows: 8EGINrJING at a spike in the center of the York Road, at the Eastern line of land of Coyle Lumber Company, Inc.; thence in all Easterly direction along the center line of the York Road, 124 feet 4 inches to a point in said center line; thence in a Southerly direction along land now or formerly of W. Harold Cline, 166 feet to a point at the Tail Race; thence in a Westerly direction along said Tail Race IJS feet to a point on the Eastern line of Coyle Lumber Company, Inc.; thence in a Northerly direction along the Eastern line of said land, 145 feet to the Place of BEGINNING. BEING improved with a frame bungalow and outbuildings: BEING the same property which was conveyed to David G. Kutz and Shirlene M. Rutz, his wife, by Mary E. Rutz, Widow, by deed dated October 29, 1980, and recorded in the Office of the Recorder of Deeds for Cumberland County in Deed Book "Eo, Vol. 29, Page 272. THIS conveyance is from parents to child and spouse. BOU,': K. 30 r,ICE 963 - I I I I I I I I , , I , , r i I I I I I Certified Article Number 7160 3901 9844 0951 3518 SENDERS RECORD ACT 91 NOTICE DATE OF NOTICE: October 3,2002 EXHIBIT A TAKE ACTION TO SAVE YOUR HOME FROM FORECLOSURE This is an official notice that the mortgage on your home is in default, and the lender intends to foreclose. Specific information about the nature of the default is provided in the attached pagcs. The HOMEOWNER'S MORTGAGE ASSISTANCE PROGRAM (HEMAP) may be able to help to save your home. This Notice explains how the prograrn works. To see if HEMAP can help, you must MEET WITH A CONSUMER CREDIT COUNSELING AGENCY WITHIN 30 DAYS OF THE DATE OF THIS NOTICE. Take this Notice with you when you meet with the Counseling Agency. '" rr ;fj . ~ Zt ~ ~ ~ The name, address and phone number of Consumer Credit Counseling Agencies serving our Count are listed at the end of this Notice. If ou have an uestions, ,ou ma , call the Pennsylvania Housing Finance Agency toll free at 1-800-342-2397. (Persons with impaired · hearing can call (71 7) 780-1869.) This Notice contains important legal information. If you have any questions, representatives at the Consumer Credit Counseling Agency may be able to help explain it. You may also want to contact any attorney in your area. The local bar association may be able to help you find a lawyer. La notificacion en adjunto es de suma importancia, pues afecta su derecho a continuar viviendo en su casa. Si no comprende el contenido de esta notification obtenga una traduccion immediatamente llamanda esta agencia (Pennsylvania Housing Finance Agency) sin cargos al numero mencionada arriba. Puedes ser elegible para un prestamo por el prograrna llamado "Homeowner's Emergency Mortgage Assistance Program" el cual puede salvar su casa de Ia perdida del derecho a redimir su hipoteca. Prepared by: GOLDBECK McCAFFERTY & McKEEVER Suite 500 - The Bourse Bldg. III S. Independence Mall East Philadelphia, PA 19106 Fax (215) 627-7734 1 Date: October 3, 2002 Homeowners Name: SAMUEL PALUMBO, SAMUEL PALUMBO, SUSAN PALUMBO and SUSAN PALUMBO Property Address: 234 E. Old York Road, Carlisle, PA 17013 Loan Account No.: 0002688366 Original Lender: FORD CDC Current Lender/Scrvicer: Citifinancial Mortgage Co. Inc. HOMEOWNERS' EMERGENCY MORTGAGE ASSISTANCE PROGRAM YOU MAY BE ELIGIBLE FOR FINANCIAL ASSISTANCE WHICH CAN SAVE YOUR HOME FROM FORECLOSURE AND HELP YOU MAKE FUTURE MORTGAGE PAYMENTS IF YOU COMPLY WITH THE PROVISIONS OF THE HOMEOWNER'S EMERGENCY MORTGAGE ASSISTANCE ACT OF 1983 (THE "ACT"), YOU MAY BE ELIGIBLE FOR EMERGENCY MORTGAGE ASSISTANCE: * IF YOUR DEFAULT HAS BEEN CAUSED BY CIRCUMSTANCES BEYOND YOUR CONTROL, * IF YOU HAVE A REASONABLE PROSPECT OF BEING ABLE TO PAY YOUR MORTGAGE PAYMENTS, AND * IF YOU MEET OTHER ELIGIBILITY REQUIREMENTS ESTABLISHED BY THE PENNSYLVANIA HOUSING FINANCE AGENCY. TEMPORARY STAY OF FORECLOSURE - Under the Act, you are entitled to a temporary stay of foreclosure on your mortgage for thirty (30) days from the date of this Notice. During that time you must arrange and attend a "face-to-face" meeting with one ofthe designated consumer credit counseling agencies listed at the end of this Notice. THIS MEETING MUST OCCUR WITHIN THE NEXT (30) DAYS. IF YOU DO NOT APPLY FOR EMERGENCY MORTGAGE ASSISTANCE, YOU MUST BRING YOUR MORTGAGE UP TO DATE. THE PART OF THIS NOTICE CALLED "HOW TO CURE YOUR MORTGAGE DEFAULT", EXPLAINS HOW TO BRING YOUR MORTGAGE UP TO DATE. CONSUMER CREDIT COUNSELING AGENCIES - If you meet with one of the consumer credit counseling agencies listed at the end of this notice, the lender may NOT take action against you for thirty (30) days after the date of this meeting. The names, addresses and telephone numbers of dcsi nated consumer credit counsel in a encies for the count in which the ro ert is located are set 2 forth at the end ofthis Notice. It is only necessary to schedule one face-to-face meeting. Advise your lender immediately of your intentions. APPLICATION FOR MORTGAGE ASSISTANCE - Your mortgage is in default for the reasons set fOl1h later in this Notice (see following pages for specific information about the nature of your default.) If you have tried and are unable to resolve this problem with the lender, you have the right to apply for tinancial assistance from the Homeowner's Emergency Mortgage Assistance Program. To do so, you must fill out, sign and file a completed Homeowner's Emergency Assistance Program Application with one of the designated consumer credit counseling agencies listed at the end of this Notice. Only consumer credit counseling agencies have applications for the program and they will assist you in submitting a complete application to the Pennsylvania Housing Finance Agency. Your application MUST be filed or postmarked within thirty (30) days of your fact-to-face meeting. YOU MUST FILE YOUR APPLICATION PROMPTLY. IF YOU FAIL TO DO SO OR IF YOU DO NOT FOLLOW THE OTHER TIME PERIODS SET FORTH IN THIS LETTER, FORECLOSURE MAY PROCEED AGAINST YOUR HOME IMMEDIATELY AND YOUR APPLICATION FOR MORTGAGE ASSISTANCE WILL BE DENIED. AGENCY ACTION - Available funds for emergency mortgage assistance are very limited. They will be disbursed by the Agency under the eligibility criteria established by the Act. The Pennsylvania Housing Finance Agency has sixty (60) days to make a decision after it receives your application. During that time, no foreclosure proceedings will be pursued against you if you have met the time requirements set forth above. You will be notified directly by the Pennsylvania Housing Finance Agency of its decision on your application. NOTE: IF YOU ARE CURRENTLY PROTECTED BY TH IN BANKRUPTCY, THE FOLLOWING PA THIS INFORMATION PURPOSES ONLY AND S NOTB ATTEMPT TO COLLECT THE DEBT. (If you have filed bankru Emergency Mo HOW TO CURE YOUR MORTGAGE DEFAULT (Brine: it up to date). NATURE OF THE DEFAULT - The MORTGAGE debt held by the above lender on your property located at: 234 E. Old York Road, Carlisle, P A 17013 IS SERlOUSL Y IN DEFAULT because: A. YOU HAVE NOT MADE MONTHLY MORTGAGE PAYMENTS for the following months and the following amounts are now past due: 3 (a) Monthly payment from 05/04/2002 thru 10/3/2002 (5 mos. at $934.82/month) $4,674.10 (b) Other charges; Escrow, Inspec., NSF Checks (c) Other provisions of the mortgage obligation, if any (d) TOTAL AMOUNT REQUIRED AS OF THIS DATE $4,674.10 HOW TO CURE THE DEFAULT - You may cure the default within THIRTY (30) DAYS ofthe date of this notice BY PAYING THE TOTAL AMOUNT PAST DUE TO THE LENDER WHICH IS $ 4,674.10 , PLUS ANY MORTGAGE PAYMENTS AND LATE CHARGES WHICH BECOME DUE DURING THE THIRTY (30) DAY PERIOD. Payments must be made either by cashier's check, certified check or money order made payable and sent to: CITIFINANCIAL MORTGAGE CO. INC. C/o GOLDBECK, MCCAFFERTY & MCKEEVER Suite 500, The Bourse Bldg III S. Independence Mall East Philadelphia, P A 19106 IF YOU DO NOT CURE THE DEFAULT - If you do not cure the default within THIRTY (30) DAYS of the date of this Notice, the lender intends to exercise its rh!hts to accelerate the morte:ae:e debt. This means that the entire outstanding balance of this debt will be considered due immediately and you may lose the chance to pay the mortgage in monthly installments. Iff till payment of the total amount past due is not made within THIRTY (30) DAYS, the lender also intends to instruct its attorneys to start legal action to foreclose upon your morte:ae:ed property. IF THE MORTGAGE IS FORECLOSED UPON - The mortgaged property will be sold by the Sheriff to pay off the mortgage debt. If the lender refers your case to its attorneys, but you cure the delinquency before the lender brings legal proceedings against you, you will still be required to pay the reasonable attorney's fees that were actually incurred, up to $50.00. However, if legal proceedings are started against you, you will have to pay all reasonable attorney's fees actually incurred by the lender even if they exceed $50.00. Any attorney's fees will be added to the amount you owe the lender, which may also include other reasonable costs. If you cure the default within the THIRTY (30) DAY period, you will not be required to pay attorney's fees. OTHER LENDER REMEDIES - The lender may also sue you personally for the unpaid principal balance and all other sums due under the mortgage. RIGHT TO CURE THE DEFAULT PRIOR TO SHERIFF'S SALE - If you have not cured the default within the THIRTY (30) DAY period and foreclosure proceedings have begun, you still have the ri ht to cure the default and revent the sale at an time u to one hour before the Sheriffs Sale. You ma do so b Ja in the total amount then ast due Ius an late or other char~es then due reasonable attorney's fees and costs connected with the foreclosure sale and any other costs connected with the Sheriff's Sale as s ecified in writin b the lender and b erformin an otherre uirements under the mortgal(e. Curing your default in the manner set forth in this notice will restore your mortgage to the same position as if you had never defaulted. 4 EARLIEST POSSIBLE SHERIFF'S SALE DATE - It is estimated that the earliest date that such a Sheriffs Sale of the mortgaged property could be held would be approximately four (4) to six (6) months from the date of this Notice. A notice of the actual date of the Sheriffs Sale will be sent to you before the sale. Of course, the amount needed to cure the default will increase the longer you wait You may find out at any time exactly what the required payment or action will by contacting the lender. HOW TO CO NT ACT THE LENDER: Name of Lender: CITIFINANCIAL MORTGAGE CO. INC. Address: I I 11 Northpoint Drive Building 4, Suite 100 Coppell, TX 75019-3931 Phone Number: 800-423-8158 xl2447 Fax Number: 972-657-1646 Contact Person: Kay Webb EFFECT OF SHERIFF'S SALE - You should realize that a Sheriffs Sale will end your ownership of the mortgaged property and your right to occupy it If you continue to live in the property after the Sheri ffs Sale, a lawsuit to remove you and your furnishings and other belongings could be started by the lender at any time. ASSUMPTION OF MORTGAGE - You may sell or transfer your home to a buyer or transferee who will assume the mortgage debt, provided that all the outstanding payments, charges and attorney's fees and costs are paid prior to or at the sale and that the other requirements of the mortgage are satisfied. YOU MAY ALSO HAVE THE RIGHT: * TO SELL THE PROPERTY TO OBTAIN MONEY TO PAY OFF THE MORTGAGE DEBT OR TO BORROW MONEY FROM ANOTHER LENDING INSTITUTION TO PAY OFF THIS DEBT. * TO HAVE THIS DEFAULT CURED BY ANY THIRD PARTY ACTING ON YOUR BEHALF. * TO HAVE THE MORTGAGE RESTORED TO THE SAME POSITION AS IF NO DEFAULT HAD OCCURRED, IF YOU CURE THE DEFAULT. (HOWEVER, YOU DO NOT HA VE THIS RIGHT TO CURE YOUR DEFAULT MORE THAN THREE TIMES IN ANY CALENDAR YEAR.) 5 * TO ASSERT THE NONEXISTENCE OF A DEFAULT IN ANY FORECLOSURE PROCEEDING OR ANY OTHER LAWSUIT INSTITUTED UNDER THE MORTGAGE DOCUMENTS. * TO ASSERT ANY OTHER DEFENSE YOU BELIEVE YOU MAY HAVE TO SUCH ACTION BY THE LENDER. * TO SEEK PROTECTION UNDER THE FEDERAL BANKRUPTCY LAW. Contact Person: Kay Webb Phone Number: 800-423-8158 xl2447 6 PENNSYLVANIA HOUSING FINANCE AGENCY HOMEOWNER'S EMERGENCY MORTGAGE ASSISTANCE PROGRAM CONSUMER CREDIT COUNSELING AGENCIES CUMBERLAND COUNTY CCCS OF WESTERN PENNSYL VANIA INC. 2000 LingIestown Road Harrisburg, P A 17102 (717) 541-1757 URBAN LEAGUE OF METROPOLITAN HARRISBURG 2107 N. 6th Street Harrisburg, PA 17101 (717) 234-5925 FAX (717) 234-9459 COMMUNITY ACTION COMM OF THE CAPITAL REGION 1514 Derry Street Harrisburg, PA 17104 (717) 232-9757 FAX 234-2227 FINANCIAL COUNSELING SERVICES OF FRANKLIN 31 West 3rd Street Waynesboro, PA 17268 (717) 762-3285 YWCA OF CARLISLE 301 G Street Carlisle, PA 17013 (717) 243-3818 FAX (717) 731-9589 ADAMS COUNTY HOUSING AUTHORITY 139-143 Carlisle Street Gettysburg, P A 17325 (717) 334-1518 FAX (717) 334-8326 11 ~n (, G 0 ...... - r-- w CI'l--c) -- ~ ~ p::: en , fp f' -0 ,: -. ~ ~ It) ...a \'- C> GOLDBECK McCAFFERTY & McKEEVER By: JOSEPH A. GOLDBECK, JR. AITORNEY LD. #16132 SUITE 500 - THE BOURSE BLDG. 111 S. INDEPENDENCE MALL EAST PHILADELPHIA, P A 19106 (215) 627-1322 A ITORNEY FOR PLAINTIFF IN THE COURT OF COMMON PLEAS OF Cumberland COUNTY CIVIL ACTION - LAW ACTION OF MORTGAGE FORECLOSURE CITIFINANCIAL MORTGAGE CO. INC. F/KJA FORD CDC 1111 Northpoint Drive Building 4, Suite 100 Coppell, TX 75019-3931 Term No. 02-5573 CIVIL TERM Plaintiff vs. SUSAN K. PALUMBO SAMUEL R. PALUMBO 234 E. Old York Road Carlisle, P A 17013 Defendant( s) PRAECIPE TO REINSTATE COMPLAINT Kindly reinstate the Complaint in the above captioned matter. GOLDBECK, McCAFFERTY & McKEEVER f?'t~- By Joseph A. Goldbeck, Jr., Esq. Attorney fur Plaintiff (") 0 0 c W --1'1 ~?f:; (.- :D>' -~n I ct~~ ......,,.. r;'; .."~ z~,_ I r-f1 m s~- ~r~1CJ cr. :2 -=< ;;':. (..) ~ C -0 ~.. J:-~: :-.r.: , :,'] ..-'/ C) ~,.. ~ .::- C / rn s;; N ,~.) c::: ~-\ Z :J1 r:-~' ~ :q co ~ - SHERIFF'S RETURN - OUT OF COUNTY CASE NO: 2002-05573 P COMMONWEALTH OF PENNSYLVANIA: COUNTY OF CUMBERLAND CITIFINANCIAL MORTGAGE CO VS PALUMBO SUSAN K ET AL R. Thomas Kline , Sheriff or Deputy Sheriff who being duly sworn according to law, says, that he made a diligent search and and inquiry for the within named DEFENDANT , to wit: PALUMBO SUSAN K but was unable to locate Her In his bailiwick. He therefore deputized the sheriff of YORK County, Pennsylvania, to serve the within COMPLAINT - MORT FORE On December 31st , 2002 , this office was in receipt of the attached return from YORK Sheriff's Costs: Docketing Out of County Surcharge Dep York County 18.00 9.00 10.00 62.04 .00 99.04 12/31/2002 GOLDBECK MCCAFFERTY ~~ R. Thomas Kline Sheriff of Cumberland County MCKEEVER Sworn and subscribed to before me /I day of L" ,... ""1 A.D. this .3 A4( d--fJo3 ~ ~- --- L () 1t1~ -I . ~ Prothonotary fiLi SHERIFF'S RETURN - OUT OF COUNTY CASE NO: 2002-05573 P COMMONWEALTH OF PENNSYLVANIA: COUNTY OF CUMBERLAND CITIFINANCIAL MORTGAGE CO VS PALUMBO SUSAN K ET AL R. Thomas Kline , Sheriff or Deputy Sheriff who being duly Sworn according to law, says, that he made a diligent search and and inquiry for the within named DEFENDANT , to wit: PALUMBO SAMUEL R but was unable to locate Him deputized the sheriff of YORK in his bailiwick. He therefore County, Pennsylvania, to serve the within COMPLAINT - MORT FORE On December 31st , 2002 , this office was In receipt of the attached return from YORK Sheriff's Costs: Docketing Out of County Surcharge 6.00 .00 10.00 .00 .00 16.00 12/31/2002 GOLDBECK MCCAFFERTY So answe:rs:, /' ", " ,,', _..----- ~~~--- a< Thomas Kline Sheriff of Cumberland County ",,' MCKEEVER Sworn and JlTv3 subscribed to before me -""\ day OfeA.-.., <.~ ~ 7 ,r this :3 d. A.D. ~. () ~.dP, , ~ Prothonotary -::-~ i ,~.l)? --~--- ~---- I ~YORKTOWNEBUSINESSFOMFiS;(717J225-o:l63'FAX(7i7)-225-OOs7 - - - T-'- - r r r ~ ~ ~ ~ ~ _ _ '~. ,,:~')d cJ3..!? q ;3/, t,.Jf'r-...J 'f!cl. ~ 010 ~~, ;"l~ ~_ , l\.J 0-,.] _UJtJ"'~L- 'S~JlJE.~ _____~~ COUNTY OF YORK ;)002- OFFICE OF THE'SHERIFF 28 EAST MARKET ST., YORK, PA 17401 SERVICE CALL (717) 771.9601 LO. M ( , fC{ltJ~o INSTRUCTIONS PLEASE TYPE ONLY UNE 1 THRU 12 DO NOT DETACH ANY COPIES 2. COUB~~~~ c' SHERIFF SERVICE PROCESS RECEIPT and AFFIDAVIT OF RETURN NOW 8. SPECIAL INSTRUCTIONS OR OTHER INFORMATION THAT WILL ASSIST IN EXPEDITING SERVICE: OUT OF COUNTY CUMBERLAND ADVANCED FEE PAID BY ATTY NOTE: ONLY APPLICABLE ON WRIT OF EXECUTION: N.B. WAIVER OF WATCHMAN - Any deputy sheriff levying upon or attaching any property under within writ may leave same without a watchman, in custody of whomever is found in possession, after notifying person of levy or attachment. without liability on the part of such deputy or the sheriff to any plaintiff herein for any loss, destruction, or removal of any property before sheriffs sale thereof. GOLD (This area must be completed if notice is to be mailed). UI e e ou 111 S. Independence Mall East CUMBERLAND CO. SHERIFF Philadelphia. Pennsylvania 19106 SPACE BEL W FOR USE OF THE SHERIFF - DO NOT WRITE BELOW THIS LINE 14. ~Af~~'iC_'1Y~D 11. DATE FILED 1~'i~:l&-E\kR 9. 13. I acknowledge receipt of the writ or complaint as indicated above. 15. EX~'2t~\f~'b2 Date 16. POSTED ( ) POE( ) SHERIFF'S OFFICE ( OTHER ( SEE REMARKS BELOW 22. 23. Advance Costs 33. Costs Due or Refund Check No. .dn rnC'tC' n.."" ^" D.....(:, ....,.., COUNTY OF YORK OFFICE OF THE<"SHERIFF SERVICE CALL (717) 771-9601 28 EAST MARKET ST., YORK, PA 17401 SHERIFF SERVICE PROCESS RECEIPT and AFFIDAVIT OF RETURN INSTRUCTIONS PLEASE TYPE ONLY LINE 1 THRU 12 DO NOT DETACH ANY COPIES 1. PLAI NTI FF IS/ 2 ,f. ,,':.1 ,,/'; I ! ~-; 4. SERVE .. AT " '.' ,< t )_ - u 3. DEFENljANT/S/ -~ -';~' ~ r { /, ;/1,'\ g/ 6. ADDRESS (STREET OR RFO WI~~ BOX NUMBER. APT. NO. CITY, BORO. TWP., )'TATE AND ZIP CODE)_ -+-- 7. INDICATE SERVICE: -l'1"ERSON IN CHARGE DEPUTIZE ..J CERT. ~AIL 'J 1ST CLASS MAIL J POSTED .JOTHER NOW . . , .20 _ I, SHERIFF OF \?~ OUNTY, PA, do h~r.eby deputize the sheriff of . . ' . .1' . . COUNTY to execute this VYrlt~~;P~~~r~ ~ere.w~in~ to law. ThiS depulization being made at the request and risk of the plaintiff. -1" "'?~"'.."._'" "{.., ,.f ~" ~ . SHERIFF OF ~ COl~NTY 'l~ ~ " 1 :~n~ ~f, , (-lll( :- 8. SPECIAL INSTRUCTIONS OR OTHER INFORMATION THAT WILL ASSIST IN EXPEDITING SERVICE , (.I \~~.~ ~-,:)! ;, ~;;i: n 1" .. ! '. c... , r.' t~-rr\, NOTE: ONLY APPLICABLE ON WRIT OF EXECUTION: N.S. WAIVER OF WATCHMAN - Any deputy sheriff levying upon or attaching any property under within writ may leave same without a watchman, in custody of whomever is found in possession, after notifying person of levy or attachment, without liability on the part of such deputy or the sheriff to any plaintiff herein for any loss, destruction, or removal of any property before sheriffs sale thereof. g... TYPE NAME and ADDRESS of i\TTORNEY./ qflGINATOR and SIGNATURE 10. TELEPHONE NUMBER 11. DATE FILED 12. S I"~ )1'. c c Suite 500 The Bourse Building 111 S. independence Mali East SPACE BELOW FOR USE OF THE SHERIFF - DO NOT WRITE eaM~tJlHlHl:j'fElsylvama 19106 14. qYE Ff~~E,WED 15. (This area must be completed if notice is to be mail 13. I acknowledge receipt of the writ or complaint as indicated above. ~i \<: :~. ,I.) 16. HOW SERVED: PERSONAL (,,1' RESIDENCE (, ) POSTED ( ) POE( ) SHERIFF'S OFFICE ( ) OTHER ( SEE REMARKS BELOW 22 REMARKS' 42. day of 33. Costs Due or Refund Check N 23. Advance Costs 40. Costs Due or Refund , H; , t: 48. Signature of Foreign .(. County Sheriff SiGNATURE 51. DATE RECEIVED WHITE - Issuing Authority 2. PINK - Attomey 3. CANARY - Sheriff's Office 4. BLUE - Sheriff's Office - ~ , deputizatilJ, ~\Nr"-" r ~ J-e,{ v'€ j/fl 0.. ( U., </ . .~ - ~D'lJI'\t{C.ED fH. PAID B'{ 1'\11'i CUMBERLAND CO. SHERIff _ SPACE BELOW FOR US@ THE SHERIFF - ""_ 'Knowledge receipt of the writ complaint as indicated above. R . A I.\R ENS --- 45. DATE 47. DATE 44. Signature 01 Oep. Sheriff . Signature of York County Sheriff vlllLlI'\M M. HOSE ~/~ 12-12-02 49. DATE 48. Signature of foreign county Sheriff ATURE 51. DATE RECEIVED , ",,,,, _..... _'" ,."'" _ _ ,"""" _" "'. "n>' -,- '1 .S .I / \\~~ \1.\ - '1 ---.. ,... --, ..~ -..""",,--- .~' --- '0 S h 21 Md r 2 1l!!;V /f' vU, i':j .. .I >,'(i ~ ...... ~ ""l 1/,_ --- I ~ 1002- COUNTY OF YORK OffiCE OF THE -SHERIFF SERVICF, CALL (717) 771-9601 . 2B EAST MARKET ST.. YORK, PI' 17401 INSTRUCTIONS PLEASE TYPE ONLY LINE 1 THRU 12 00 NOT DETACH ANY COPIES ON THAT WILL ASSIST IN EXPEDITING SERVICE: t4\. tJ.. ( {PY)tJ.,./(l I:J \ _, __........._' ......... '" .,""~.. '0' '",",' ~,," '''~ ,~O"' ...W'""." .m~~ ~~,"".",~, ".., _ ._."......_' ~~ '" ~","""."" _~ ."'"' m ,.,"' _"'~ ,,.,,,,, ,,,""~ 00 ~ ,,,",.,, 00",'''.' ,""",,,..,", herein lor 81'1'/ lOSS. deSlnIcllOIl. orren\Ovalol any property before sheriff's sale thereof and ADDRESS 01" . IGINATOR and SIGNATURE j ADVANCED FEE PAID BY ATTY 10. TELEPHONE NUMBER '7 t .:' 7 '_'72 11. DATE Fit J ",-1 to NAIJ,IE. AND ADDRESS BELOW: (This area must be completed il notice is to be mail _, l _~, l ~"'"' l ~" l "''''''''''"'' , 0,"," ,__.._.""''''''''-' ~ ,..,,,,_~,"l'"'.-''''' 0_- ,,--,~,~, AND Tm.e OF INbMOIJAL SERVED I LIST ADDRESS HERE IF NOT SHOWN ABOVE (Relationship to Delendant) 1. l-~;, -02 l.?-l"-!-.:"I' SEE REMAf 21. ATTeMPTS R.A HREl'lS Time c Time 22. ReMARKS: ~q(\~ Df~ll r 1, , ! i''o. A'i..' ' "j j " ,,"U- ,.,L b~Q, //, - ' / ',- 45. 44. Signature of Oep. Sheriff 46. Signature of York County SheM~ '~,-nLt.lt\i4i t-J\. HOS~ ,1A /, 48. Signature 01 Foreign ,/" ~./ .;.~/ County Sheriff N SIGNATURE 47. ./ / f' -;.>.-:t~I~'-~-~- 49 51. DATE RECEIVE 3. CANARY _ Sheriffs Offlce 4. BLUE - Sheriffs Office CASE NO: 2002-05573 P SHERIFF'S RETURN - REGULAR COMMONWEALTH OF PENNSYLVANIA: COUNTY OF CUMBERLAND CITIFINANCIAL MORTGAGE CO VS PALUMBO SUSAN K ET AL CPL. MICHAEL BARRICK , Sheriff or Deputy Sheriff of CUmberland CountY,PennsYlvania, who being dUly SWorn according to law, says, the within COMPLAINT _ MORT FORE PALUMBO SUSAN K ;EFENDANT was served upon CARLISLE, PA 17013 , at 1649:00 HOURS, on the lQ!E day of January the at 234 E OLD YORK ROAD 2003 - SUSAN K PALUMBO by handing to a true and attested copy of COMPLAINT _ MORT FORE together with and at the same time directing Her attention to the Contents thereof. = Sheriff's Costs: DOcketing Service Affidavit Surcharge 18.00 3.45 .00 10.00 .00 31.45 So Answers: ~:f;~;);;':t~;-,~~::,~'.:,.~ ... R. Thomas Kline . ./:0 .../~.(~ Sworn and Subscribed to before By: 01/13/2003 GOLDBECK MCCAFFER -j le- rne this I 'I ~ day of 97,,/ "''';: AD. ~ t~;; J/IL, ''foZ:;- , rothonotary , In the Court of Common Pleas of Cumberland County CITIFINANCIAL MORTGAGE CO. INC. F/KJA FORD CDC I I I I Northpoint Drive Building 4, Suite 100 Coppell, TX 75019-3931 Plaintiff SUSAN K. PALUMBO SAMUEL R. PALUMBO (Mortgagor(s) and Record Owner(s)) 234 E. Old York Road Carlisle, P A 17013 vs. No. 02-5573 CIVIL TERM Defendant(s) PRAECIPE FOR JUDGMENT THIS LAW FIRM IS A DEBT COLLECTOR AND WE ARE ATTEMPTING TO COLLECT A DEBT OWED TO OUR CLIENT. ANY INFORMATION OBTAINED FROM YOU WILL BE USED FOR THE PURPOSE OF COLLECTING THE DEBT. Enter the Judgment in favor of Plaintiff and against SUSAN K. PALUMBO and SAMUEL R. PALUMBO by default for want of an Answer. Assess damages as follows: Debt $97,734.08 Interest - 05/04/2002 to 02/1 0/2003 Total (Assessment of Damages attached) I CERTIFY THAT FOREGOING ASSESSMENT OF DAMAGES IS FOR SPECIFIED AMOUNTS ALLEGED TO BE DUE IN THE COMPLAINT AND IS CALCULABLE AS A SUM CERTAIN FROM THE COMPLAINT. I certify that written notice of the intention to file this praecipe was mailed or delivered to the party against whom judgment is to be entered and to his attorney of record, ifany, after the default occurred an t least ten days prior to the date of the filing of this praecipe. A copy of the notice is attached. R.C.P. 237.1 AND NOW ')'P.b . /;;;., , ~~6. 3 , Judgment is entered in favor of CITIFlNANCIAL MORTGAGE CO. INC. F/KJA FORD CDC and against SUSAN K. PALUMBO and SAMUEL R. PALUMBO by default for want of an Answer and damages assessed in the urn of$97,734.08 as per the ab certification. GOLDBECK McCAFFERTY & McKEEVER BY: Joseph A: Goldbeck, Jr. Attorney I.D. #16132 Suite 500 - The Bourse Bldg. III S. Independence Mall East Philadelphia, P A 19106 215-627-1322 Attorney for Plaintiff CITIFINANClAL MORTGAGE CO. INC. FIKJA FORD CDC 1111 Northpoint Drive Building 4, Suite 100 Coppell, TX 75019-3931 IN THE COURT OF COMMON PLEAS of Cumberland County Plaintiff vs. CIVIL ACTION LAW SUSAN K. PALUMBO SAMUEL R. PALUMBO (Mortgagor(s) and Record owner(s)) 234 E. Old York Road Carlisle, PA 17013 ACTION OF MORTGAGE FORECLOSURE Defendant( s) No. 02-5573 CIVIL TERM ORDER FOR JUDGMENT Please enter Judgment in favor of CITlFINANCIAL MORTGAGE CO. INC. FIKIA FORD CDC, and against SUSAN K. PALUMBO and SAMUEL R. PALUMBO for failure to file an Answer in the above action within (20) days (or sixty (60) days if defendant is the United States of America) from the date of service of the Complaint, in the sum of$97,734.08. I hereby certifY that the above names are correct and that the precise residence address of the judgment creditor is CITIFINANCIAL MORTGAGE CO.INe. FIKIA FORD CDC 1111 Northpoint Drive Building 4, Suite 100 CoppeIl, TX 75019-3931 and that the name(s) and last known addressees) ofthe Defendant(s) is/are SUSAN K. PALUMBO, 113 Whiskey Springs Road DiIlsburg, P A 17019 and SAMUEL R. PALUMBO, 113 Whiskey Springs Road Dillsburg, P A 17019; GOLDBEC BY: Joseph Attorney for & McKEEVER ASSESSMENT OF DAMAGES TO THE PROTHONOTARY: Kindly assess the damages in this case to be as follows: Principal Balance $79,962.80 Interest from 05/04/2002 through 02/10/2003 $6,602.38 Attorney's Fee at 5,0000% of principal balance $3,998.14 Late Charges $0.00 Costs of Suit and Title Search $750.00 Escrow Advances Fees DRM Expenses $3,105.26 $640.50 $2,675.00 $97,734.08 AND NOW, this J;(fZ. day of )ab , 2003 damages are assessed as above. (J-M-k~ )? ~ Pro Prothy VERIFICATION OF NON-MILITARY SERVICE The undersigned, as the representative for the Plaintiff corporation within named do hereby verify that I am authorized to make this verification on behalf of the Plaintiff corporation and that the facts set forth in the foregoing verification of Non- Military Service are true and correct to the best of my knowledge, information and belief. I understand that false statements therein are made subject to penalties of 18 Pa. C.S. 4904 relating to unsworn falsification to authorities. 1. That the above named Defendant, SAMUEL R. PALUMBO, is about unknown years of age, that Defendant's last known residence is 113 Whiskey Springs Road, Dillsburg, PA 17019, and is engaged in the unknown business located at unknown address. 2. That 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 Action of Congress of 1940 and its Amendments. Date: VERIFICATION OF NON-MILITARY SERVICE The undersigned, as the representative for the Plaintiff corporation within named do hereby verify that I am authorized to make this verification on behalf of the Plaintiff corporation and that the facts set forth in the foregoing verification of Non- Military Service are true and correct to the best of my knowledge, information and belief. I understand that false statements therein are made subject to penalties of 18 Pa. C.S. 4904 relating to unsworn falsification to authorities. 1. That the above named Defendant, SUSAN K. PALUMBO, is about unknown years of age, that Defendant's last known residence is 113 Whiskey Springs Road, Dillsburg, PA 17019, and is engaged in the unknown business located at unknown address. 2. That 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 Action of Congress of 1940 and its Amendments. Date: Rule of Civil P.rocedure No. 236 - Revised IN THE COURT OF COMMON PLEAS OF Cumberland COUNTY, PENNSYL VANIA CIVIL ACTION - LAW CITIFINANCIAL MORTGAGE CO. INC, F/K/A FORD CDC 1111 Northpoint Drive Building 4, Suite 100 Coppell, TX 75019-3931 Plaintiff vs. No. 02-5573 CIVIL TERM SUSAN K. PALUMBO SAMUEL R. PALUMBO (Mortgagors and Record Owner(s)) 234 E. Old York Road Carlisle, P A 17013 Defendant( s) THIS LAW FIRM IS A DEBT COLLECTOR AND WE ARE ATTEMPTING TO COLLECT A DEBT OWED TO OUR CLIENT. ANY INFORMATION OBTAINED FROM YOU WILL BE USED FOR THE PURPOSE OF COLLECTING THE DEBT. NOTICE Notice is given that a judgment in the above-captioned matter has been entered against you. Curt Long Prothonotary By: Deputy If you have any questions concerning the above, please contact: Joseph A. Goldbeck, Jr. Goldbeck McCafferty & McKeever Suite 500 - The Bourse Bldg. I I I S. Independence Mall East Philadelphia, PA 19106 215-627-1322 THIS LAW FIRM IS A DEBT COLLECTOR AND WE ARE ATTEMPTING TO COLLECT A DEBT OWED TO OUR CLIENT. ANY INFORMATION OBTAINED FROM YOU WILL BE USED FOR THE PURPOSE OF COLLECTING THE DEBT. TO: DATE OF TillS NOTICE: January 31,2003 SUSAN K. PALUMBO 113 Whiskey Springs Road DiJIsburg, PA 17019 CITIFINANCIAL MORTGAGE CO. INe. FIKJA FORD CDC 1111 Northpoint Drive Building 4, Suite 100 CoppelI, TX 75019-3931 In the Court of Common Pleas of Cumberland County vs. SUSAN K. PALUMBO SAMUEL R. PALUMBO (Mortgagor(s) and Record Owner(s)) 234 E. Old York Road Carlisle, PA 17013 Plaintiff CIVIL ACTION - LAW ACTION OF MORTGAGE FORECLOSURE Term No. 02-5573 CIVIL TERM Defendant(s) TO: SUSAN K. PALUMBO 113 Whiskey Springs Road Dillsburg,PA 17019 IMPORTANT NOTICE YOU ARE IN DEFAULT BECAUSE YOU HAVE FAILED TO ENTER A WRITTEN APPEARANCE PERSONALLY OR BY ATTORNEY AND FILE IN WRITING WITH THE COURT YOUR DEFENSES OR OBJECTIONS TO THE CLAIMS SET FORTH AGAINST YOU. UNLESS YOU ACT WITHIN TEN (10) DAYS FROM THE DATE OF THIS NOTICE, A JUDGMENT MAY BE ENTERED AGAINST YOU WITHOUT A HEARING AND YOU MAY LOSE YOUR PROPERTY OR OTHER IMPORTANT RIGHTS. YOU SHOULD TAKE THIS NOTICE TO A LAWYER AT ONCE. IF YOU DO NOT HAVE A LAWYER OR CANNOT AFFORD ONE, GO TO OR TELEPHONE THE FOLLOWING OFFICE TO FIND OUT WHERE YOU CAN GET LEGAL HELP: ~.RbMIDCOUNTY BAR ASSOCIATION t.ij:;Y;,'0'''f'18i3 ~W,ALiSfVICES INe r~~~_0tib7013 EVER THIS LAW FIRM IS A DEBT COLLECTOR AND WE ARE ATTEMPTING TO COLLECT A DEBT OWED TO OUR CLIENT. ANY INFORMATION OBTAINED FROM YOU WILL BE USED FOR THE PURPOSE OF COLLECTING THE DEBT. TO: DATE OF THIS NOTICE: January 31,2003 SAMUEL R. PALUMBO 113 Whiskey Springs Road Dillsburg, PA 17019 CITIFINANCIAL MORTGAGE CO. INC, F/KJA FORD CDC 1111 Northpoint Drive Building 4, Suite 100 Coppell, TX 75019-3931 In the Court of Common Pleas of Cumberland County vs. SUSAN K. PALUMBO SAMUEL R. PALUMBO (Mortgagor(s) and Record Owner(s)) 234 E. Old York Road Carlisle, P A 17013 Plaintiff CIVIL ACTION - LAW ACTION OF MORTGAGE FORECLOSURE Term No. 02-5573 CIVIL TERM Defendant(s) TO: SAMUEL R. PALUMBO I 13 Whiskey Springs Road DilIsburg, PA 17019 IMPORTANT NOTICE YOU ARE IN DEFAULT BECAUSE YOU HAVE FAILED TO ENTER A WRIITEN APPEARANCE PERSONALLY OR BY AITORNEY AND FILE IN WRITING Willi lliE COURT YOUR DEFENSES OR OBJECTIONS TO THE CLAIMS SET FORlli AGAINST YOU. UNLESS YOU ACT WIlliIN TEN (I 0) DAYS FROM lliE DATE OF lliIS NOTICE, A JUDGMENT MAY BE ENTERED AGAINST YOU WIlliOUT A HEARING AND YOU MAY LOSE YOUR PROPERTY OR OlliER IMPORTANT RIGHTS. YOU SHOULD TAKE TIIIS NOTICE TO A LAWYER AT ONCE. IF YOU DO NOT HAVE A LAWYER OR CANNOT AFFORD ONE, GO TO OR TELEPHONE lliE FOLLOWING OFFICE TO FIND OUT WHERE YOU CAN GET LEGAL HELP: ~~COUNTY BAR ASSOCIATION Dli!l;i'o!.",lAvfl1!1f3 H~i~VICES me ~~~_~7013 GO B . seph A. Goldbeck, Jr., Esq. Attorney for Plaintiff Suite 500 - The Bourse Bldg. III S. Independence Mall East Philadelphia, PA 19106 215-627-1322 THIS LAW FIRM IS A DEBT COLLECTOR AND WE ARE ATTEMPTING TO COLLECT A DEBT OWED TO OUR CLIENT. ANY INFORMATION OBTAINED FROM YOU WILL BE USED FOR THE PURPOSE OF COLLECTING THE DEBT. TO: DATE OF THIS NOTICE: January 31, 2003 SAMUEL R. PALUMBO 234 E. Old York Road Carlisle, P A 17013 CITlFINANCIAL MORTGAGE CO. INC. F/KJA FORD CDC 1111 Northpoint Drive Building 4, Suite 100 Coppell, TX 75019-3931 Plaintiff IN THE COURT OF COMMON PLEAS of Cumberland County vs. SUSAN K. PALUMBO SAMUEL R. PALUMBO (Mortgagor(s) and Record Owner(s)) 234 E. Old York Road Carlisle, PA 17013 CML ACTION - LAW ACTION OF MORTGAGE FORECLOSURE Defendant(s) Term No. 02-5573 CML TERM TO: SAMUEL R. PALUMBO 234 E. Old York Road Carlisle, PA 17013 IMPORTANT NOTICE YOU ARE IN DEFAULT BECAUSE YOU HA VB FAILED TO ENTER A WRIITEN APPEARANCE PERSONALLY OR BY AITORNEY AND FILE IN WRITING WITII THE COURT YOUR DEFENSES OR OBJECTIONS TO TIIE CLAIMS SET FORTH AGAINST YOU. UNLESS YOU ACT WITIIIN TEN (l 0) 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: ~E.~COUNTY BAR ASSOCIATION tt1:We?'o.Vf'i1lf3 k~*~~VICES INe 7i'?~_~7013 EVER THIS LAW FIRM IS A DEBT COLLECTOR AND WE ARE ATTEMPTING TO COLLECT A DEBT OWED TO OUR CLIENT. ANY INFORMATION OBTAINED FROM YOU WILL BE USED FOR THE PURPOSE OF COLLECTING THE DEBT. TO: DATE OF THIS NOTICE: January 31, 2003 SUSAN K. PALUMBO 234 E. Old York Road Carlisle, PA 17013 CITIFINANCIAL MORTGAGE CO. INe. F/KJA FORD CDC 1111 Northpoint Drive Building 4, Suite 100 Coppell, TX 75019-3931 Plaintiff IN THE COURT OF COMMON PLEAS of Cumberland County vs. SUSAN K. PALUMBO SAMUEL R. PALUMBO (Mortgagor(s) and Record Owner(s)) 234 E. Old York Road Carlisle, PA 17013 CIVIL ACTION - LAW ACTION OF MORTGAGE FORECLOSURE Defendant(s) Term No. 02-5573 CIVIL TERM TO: SUSAN K. PALUMBO 234 E. Old York Road Carlisle, PA 17013 IMPORTANT NOTICE YOU ARE IN DEFAULT BECAUSE YOU HAVE FAILED TO ENTER A WRITTEN APPEARANCE PERSONALLY OR BY ATTORNEY AND FILE IN WRITING WITH THE COURT YOUR DEFENSES OR OBJECTIONS TO THE CLAIMS SET FORTH AGAINST YOU. UNLESS YOU ACT WITHIN TEN (10) DAYS FROM THE DATE OF THIS NOTICE, A JUDGMENT MAYBE ENTERED AGAINST YOU WITHOUT A HEARING AND YOU MAY LOSE YOUR PROPERlY 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: ~fl~coUNTY BAR ASSOCIATION ttl:;w'yp),vl"l/lf3 Irf~AL~2V1eES INe 7i'l!~K~7013 C cCAFFER B . seph A. Go]dbeck, Jr., Esq. Attorney for Plaintiff Suite 500 - The Bourse Bldg. ] ] 1 S. Independence Mall East Philadelphia, PA ]9106 215-627-132 ~ ~ ~ ~ t ?'--' ~A:J () ~ ~ tL 'i . - () l)- _ -- Cl \"J ~ '5 ~ ~ ~ ~ ~ t -J ~J C) Cl C_ t_ <." --,, .'-\"." ri-j - ) ., --.. ---. PRAECIPE FOR WRIT OF EXECUTION - (MORTGAGE FORECLOSURE) PRC.P 3180-3183 Joseph A. Go1dbec~, Jr. Attorney I.D.#16132 Suite 500 - llie Bourse Bldg. 111 S. Independence Mall East Philadelphia, P A 19106 215-627-1322 Attorney for Plaintiff CITIFINANCIAL MORTGAGE CO. INC, F/K/A FORD CDC 1111 Northpoint Drive Building 4, Suite 100 Coppell, TX 75019-3931 IN THE COURT OF COMMON PLEAS of Cumberland County Plaintiff vs. CIVIL ACTION - LAW SUSAN K. PALUMBO SAMUEL R. PALUMBO Mortgagor(s) and Record Owner(s) 234 E. Old York Road Carlisle, PA 17013 ACTION OF MORTGAGE FORECLOSURE No. 02-5573 CML TERM Defendant( s) PRAECIPE FOR WRIT OF EXECUTION TO THE PROTHONOTARY: Issue Writ of Execution in the above matter: Amount Due $97,734.08 ../ Interest from 05/04/2002 to 02/10/2003 at 10.6500% (Costs to be added) KEEVER ALL that certain tract of land with the improvements thereon erected. situate in south MiddletOn TownshiP. cumberland county. pennsylvania; bounded and described as followS: BEGINNING at a spiKe in the center of the YorK Road. at the Eastern line of land of Coyle Lumber company. Inc.: thence in an EasterlY direction along the center line of the york Road. 124 feet 4 inches to a point in said center line: thence in a southerlY direction along land now or formerlY of w. Harold Cline. 166 feet to a point at the Tail Race: thence in a westerlY direction along said Tail Race 135 feet to a point on the Eastern line of Coyle Lumber company. Inc.: thence in a NortherlY direction along the Eastetn line of said land. 145 feet to the place of BEGINNING. . BEING improved with a frame bungalOW and outbuildingS: SHORT DESCRIPTION SOLD '" 1he proport)' of SUSAN K. PALUMBO and SAMUEL R. PALUMBO TAX PARCEL #40_11-0288-009 ?0 ~ ~~ - Vi =+. w- it !~ ....:l f v, q.. IMPROVEMENTS consist of a residential dwelling. BEING PREMISES: 234 E. Old York Road Carlisle, PA 17013 ~~ \2~ -- r.e ,.J;:;) 01 ~ (j-l ~ ~ uy~ Cl"I C ~ C c~ -T" ~>Jo' Crt- \) o ~ ~ ~ 00 ~ -J .\~ --S:> (~ r^ C~'~ c ' " :-r WRIT OF EXECUTION and/or ATTACHMENT COMMONWEALTH OF PENNSYLVANIA) COUNTY OF CUMBERLAND) NO 02-5573 Civil CIVIL ACTION - LAW TO THE SHERIFF OF CUMBERLAND COUNTY: To satisfy the debt, interest and costs due CITIFINANCIAL MORTGAGE CO., INC. f/k/a FORD CDC Plaintiff (s) From SUSAN K. AND SAMUEL R. PALUMBO, 113 WHISKEY SPRINGS ROAD, DILLSBURG PA 17019. (I) You are directed to levy upon the property of the defendant (s)and to sell REAL ESTATE LOCATED AT 234 E. OLD YORK ROAD, CARLISLE PA 17013. (SEE ATTACHED 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) Ifproperty of the defendant(s) not levied upon an subject to attachment is found in the possession of anyone other than a named garnishee, you are directed to notify him/her that he/she has been added as a garnishee and is enjoined as above stated. Amount Due $97,734.08 Interest 5/4/02 TO 2/10/03 @ 10/6500% Atty's Comm % Atty Paid $228.49 Plaintiff Paid Date: FEBRUARY 13, 2003 L. L. $.50 Due Prothy $1.00 Other Costs CURTIS R. LONG (Seal) By: REQUESTING PARTY: Name JOSEPH A. GOLDBECK, JR., ESQ. Address: SUITE 500 - THE BOURSE BLDG. 111 S. INDEPENDENCE BLDG. PHILADELPHIA PA 19106 Attorney for: PLAINTIFF Telephone: (215) 627-1322 Supreme Court ID No. 16132 Goldbeck McCafferty & McKeever BY: Joseph A. Goldbeck, Jr. t\ttorney LD. #16132 Suite 500 - The Bourse Bldg. 111 S. Independence Mall East Philadelphia, PA 19106 215-627-1322 Attorney for Plaintiff CITIFINANCIAL MORTGAGE CO. INC. F/KJA FORD CDC 1111 Northpoint Drive Building 4, Suite 100 Coppell, TX 75019-3931 IN THE COURT OF COMMON PLEAS of Cumberland County Plaintiff vs. CIVIL ACTION - LAW SUSAN K. PALUMBO SAMUEL R. PALUMBO (Mortgagor(s) and Record Owner(s)) 234 E. Old York Road Carlisle, PA 17013 ACTION OF MORTGAGE FORECLOSURE Defendant( s) No. 02-5573 CIVIL TERM AFFIDAVIT PURSUANT TO RULE 3129 CITIFINANCIAL MORTGAGE CO. INC. F/KJA FORD CDC, Plaintiff in the above action, by its attorney, Joseph A. Goldbeck, Jr., Esquire, sets forth as of the date the praecipe for the writ of execution was filed the following information concerning the real property located at: 234 E. Old York Road Carlisle, P A 17013 l.Name and address ofOwner(s) or Reputed Owner(s): SUSAN K. PALUMBO 113 Whiskey Springs Road Dillsburg, P A 17019 SAMUEL R. PALUMBO 113 Whiskey Springs Road Dillsburg, PA 17019 2. Name and address ofDefendant(s) in the judgment: SUSAN K. PALUMBO 113 Whiskey Springs Road DiIlsburg, PA 17019 SAMUEL R. PALUMBO 113 Whiskey Springs Road DiIlsburg, P A 17019 3. Name and last known address of every judgment creditor whose judgment is a record lien on the property to be sold: CUMBERLAND COUNTY ADULT PROBATION Cumberland County Courthouse I Courthouse Square, 3rd Floor Carlisle, P A 17013 PA DEPARTMENT OF PUBLIC WELFARE - Bureau of Child Support Enforcement Health and Welfare Bldg. - Room 432 P.O. Box 2675 Harrisburg, PA 17105-2675 DOMESTIC RELATIONS OF CUMBERLAND COUNTY PO Box 320 Carlisle, PA 17013 4. Name and address of the last recorded holder of every mortgage of record: PENNSYL VANIA HOUSING FINANCE AGENCY 2101 N. Front Street PO BOX 8028 Harrisburg, PA 17110-8028 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: 6. Name and address of every other person of whom the plaintiff has knowledge who has any record interest in the property which may be affected by the sale. 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. (attach separate sheet if more space is needed) 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. GOLDBECK BY: Joseph A. G I Attorney for Pia" i cKEEVER DATED: February 10,2003 f.~ c..J -co r'~ l~:"j 02-5573 CIVIL TERM GotDBECK McCAFFERTY & McKEEVER BY: JosephA. Goldbeck, Jr. . Attorney I.D.#16132 Suite 500 - The Bourse Bldg. 111 S. Independence Mall East Philadelphia, PA 19106 215-627-1322 Attorney for Plaintiff CITIFINANCIAL MORTGAGE CO. INC. F/K/A FORD CDC 1111 Northpoint Drive Building 4, Suite 100 Coppell, TX 75019-3931 IN THE COURT OF COMMON PLEAS of Cumberland County Plaintiff CIVIL ACTION - LAW vs. SUSAN K. PALUMBO SAMUEL R. PALUMBO Mortgagor(s) and Record Owner(s) ACTION OF MORTGAGE FORECLOSURE 234 E. Old York Road Carlisle, PA 17013 Term No. 02-5573 CIVIL TERM Defendant(s THIS LAW FIRM IS A DEBT COLLECTOR AND WE ARE ATTEMPTING TO COLLECT A DEBT. THIS NOTICE IS SENT TO YOU IN AN ATTEMPT TO COLLECT A DEBT. ANY INFORMATION OBTAINED FROM YOU WILL BE USED FOR THAT PURPOSE. NOTICE OF SHERIFF'S SALE OF REAL PROPERTY TO: PALUMBO, SUSAN K. SUSAN K. PALUMBO 113 Whiskey Springs Road Dillsburg, PA 17019 Your house at 234 E. Old York Road, Carlisle, P A 17013 is scheduled to be sold at Sheriffs Sale on Wednesday, June 11,2003, at 10:00 AM, in Commissioners Hearing Rm 2nd FL Courthouse to enforce the court judgment of$97,734.08 obtained by CITIFINANCIAL MORTGAGE CO. INC. F/K/A FORD CDC against you. NOTICE OF OWNER'S RIGHTS YOU MAYBE ABLE TO PREVENT THIS SHERIFF'S SALE To prevent this Sheriffs Sale you must take immediate action: 1. The sale wiIl be cancelled if you pay to CITIFINANCIAL MORTGAGE CO. INC. F/K/A FORD CDC, the back payments, late charges, costs and reasonable attorney's fees due. To fmd out how much you must pay call: 215-627.1322 02-5573 CIVIL TERM ? You may be able to stop the sale by filing a petition asking the Court to strike or open judgment, if the judgment was improperly entered. You may also ask the Court to postpone the sale for good cause. 3. You may also be able to stop the sale through other legal proceedings. You may need an attorney to assert your rights. The sooner you contact one, the more chance you will have of stopping the sale. (See notice below on how to obtain an attorney). YOU MAY STILL BE ABLE TO SAVE YOUR PROPERTY AND YOU HAVE OTHER RIGHTS EVEN IF THE SHERIFF'S SALE DOES NOT TAKE PLACE. 1. If the Sheriffs Sale is not stopped, your property will be sold to the highest bidder. You may fmd out the price bid price by calling the Sheriff of 717-240-6390. 2. You may be able to petition the Court to set aside the sale if the bid price was grossly inadequate compared to the value of your property. 3. The sale will go through only if the buyer pays the Sheriff the full amount due in the sale. To fmd out if this has happened, you may call the Sheriff of717-240-6390. 4. If the amount due from the Buyer is not paid to the Sheriff, you will remain the owner of the property as if the sale never happened. 5. You have 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 house. A schedule of distribution of the money bid for your house will be filed by the Sheriff thirty (30) days from the date of the Sheriffs Sale. This schedule wiIl state who will be receiving that money. The money will be paid out in accordance with this schedule unless exceptions (reasons why the proposed distribution is wrong) are filed with the Sheriff within ten (10) days after the schedule of distribution is filed. 7. You may also have other rights and defenses, or ways of getting your house back, if you act immediately after the sale. YOU SHOULD TAKE THIS PAPER TO YOUR LAWYER AT ONCE. IF YOU DO NOT HA VB A LAWYER OR CANNOT AFFORD ONE, GO TO OR TELEPHONE THE OFFICE LISTED BELOW TO FIND OUT WHERE YOU CAN GET LEGAL HELP. LEGAL SERVICES INC 8 Irvine Row Carlisle, PA 17013 CUMBERLAND COUNTY BAR ASSOCIATION 2 Liberty Avenue Carlisle, P A 17013 02-5573 CIVIL TERM GOLDBECK McCAFFERTY & McKEEVER BY: JosePhA. Goldbeck, Jr. Attr>mey l.D.#16132 Suite 500 - The Bourse Bldg. 111 S. Independence Mall East Philadelphia, P A 19106 215-627-1322 Attorney for Plaintiff CITIFINANCIAL MORTGAGE CO. INC. F/KJA FORD CDC 1111 Northpoint Drive Building 4, Suite 100 Coppell, TX 75019-3931 IN THE COURT OF COMMON PLEAS of Cumberland County Plaintiff CIVIL ACTION - LAW vs. ACTION OF MORTGAGE FORECLOSURE SUSAN K. PALUMBO SAMUEL R. PALUMBO Mortgagor(s) and Record Owner(s) 234 E. Old York Road Carlisle, PA 17013 Term No. 02-5573 CIVIL TERM Defendant(s TillS LAW FIRM IS A DEBT COLLECTOR AND WE ARE ATTEMPTING TO COLLECT A DEBT. TillS NOTICE IS SENT TO YOU IN AN ATTEMPT TO COLLECT A DEBT. ANY INFORMATION OBTAINED FROM YOU WILL BE USED FOR THAT PURPOSE. NOTICE OF SHERIFF'S SALE OF REAL PROPERTY TO: PALUMBO, SAMUEL R. SAMUEL R. PALUMBO 113 Whiskey Springs Road Dillsburg, PA 17019 Your house at 234 E. Old York Road, Carlisle, P A 17013 is scheduled to be sold at Sheriffs Sale on Wednesday, June 11,2003, at 10:00 AM, in Commissioners Hearing Rm 2nd FL Courthouse to enforce the court judgment of $97,734.08 obtained by CITIFINANCIAL MORTGAGE CO. INC. F/KJA FORD CDC against you. NOTICE OF OWNER'S RIGHTS YOU MAY BE ABLE TO PREVENT TillS SHERIFF'S SALE To prevent this Sheriffs Sale you must take immediate action: 1. The sale will be cancelled if you pay to CITIFINANCIAL MORTGAGE CO. INC. F/KJA FORD CDC, the back payments, late charges, costs and reasonable attorney's fees due. To fmd out how much you must pay call: 215-627-1322 02-5573 CIVIL TERM 2. ~Y ou may be able to stop the sale by filing a petition asking the Court to strike or open judgment, if th~ 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 attomey to assert your rights. The sooner you contact one, the more chance you will have of stopping the sale. (See notice below on how to obtain an attorney), YOU MAY STILL BE ABLE TO SAVE YOUR PROPERTY AND YOU HAVE OTHER RIGHTS EVEN IF THE SHERIFF'S SALE DOES NOT TAKE PLACE. 1. If the Sheriffs Sale is not stopped, your property will be sold to the highest bidder. You may fmd out the price bid price by calling the Sheriff of717-240-6390. 2. You may be able to petition the Court to set aside the sale if the bid price was grossly inadequate compared to the value of your property. 3. The sale will go through only if the buyer pays the Sheriff the full amount due in the sale. To find out if this has happened, you may call the Sheriffof717-240-6390. 4. If the amount due from the Buyer is not paid to the Sheriff, you wiIl 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 house. A schedule of distribution of the money bid for your house will be filed by the Sheriff thirty (30) days from the date of the Sheriffs Sale. This schedule will state who will be receiving that money. The money wiIl be paid out in accordance with this schedule unless exceptions (reasons why the proposed distribution is wrong) are filed with the Sheriff within ten (10) days after the schedule of distribution is filed. 7. You may also have other rights and defenses, or ways of getting your house back, if you act immediately after the sale, YOU SHOULD TAKE THIS PAPER TO YOUR LAWYER AT ONCE. IF YOU DO NOT HA VB A LAWYER OR CANNOT AFFORD ONE, GO TO OR TELEPHONE THE OFFICE LISTED BELOW TO FIND OUT WHERE YOU CAN GET LEGAL HELP. LEGAL SERVlCES INC 8 Irvine Row Carlisle, P A 17013 CUMBERLAND COUNTY BAR ASSOCIATION 2 Liberty Avenue Carlisle, PA 17013 ~.-\ [. r,) (~ -, 1 '.J GOLDBECK McCAFFERTY & McKEEVER BY: Joseph A. Goldbeck, Jr. Attorney I.D.#16132 Suite 500 - The Bourse Bldg. 111S.md~ndenceMwlE~t Philadelphia, P A 19106 215-627-1322 Attorne for Plaintiff CITIFINANCIAL MORTGAGE CO. INC. F/KJA FORD CDC 1111 Northpoint Drive Building 4, Suite 100 Coppell, TX 75019-3931 IN THE COURT OF COMMON PLEAS of Cumberland County Plaintiff CNIL ACTION - LAW vs. ACTION OF MORTGAGE FORECLOSURE SUSAN K. PALUMBO SAMUEL R. PALUMBO Mortgagors and Record Owners No. 02-5573 CNIL TERM 234 E. Old York Road Carlisle, P A 17013 Defendants CERTIFICATE OF SERVICE PURSUANT TO Pa.R.C.P. 3129.2 (c) (2) Joseph A. Goldbeck, Jr., Esquire, Attorney for Plaintiff, hereby certifies that service on the Defendants of the Notice of Sheriff Sale was made by: ()O Personal Service by the Sheriffs Office/1J~.,nhnt ALIt (copy of return attached). ( ) Certified mail by Joseph A. Goldbeck, Jr. (original green Postal return receipt attached). ( ) Certified mail by Sheriffs Office. ( ) Ordinary mail by Joseph A. Goldbeck, Jr., Esquire to Attorney for Defendant(s) of record (proof of mailing attached). ( ) Acknowledgment of Sheriffs Sale by Attorney for Defendant( s) (proof of acknowledgment attached). ( ) Ordinary mail by Sheriffs Office to Attorney for Defendant(s) of record. IF SERVICE WAS ACCOMPLISHED BY COURT ORDER. ( ) Premises was posted by Sheriffs Office/competent adult (copy of return attached). ( ) Certified Mail & ordinary mail by Sheriffs Office (copy of return attached). ( ) Certified Mail & ordinary mail by Joseph A. Goldbeck, Jr. (original receipt(s) for Certified Mail attached). Pursuant to the Affidavit under Rule 3129 (copy attached), service on all lienholders (if any) has been made by ordinary mail by Joseph A. Goldbeck, Jr., Esquire (copies of proofs of mailing attached). The undersigned understands that the statements herein are subject to the penalties provided by 18 P.S. Section 4904. Respectfully submitted, 11bO.3901 9644 2550 3410 TO: PALUMBO, SUSAN K. SUSAN K. PALUMBO 113 Whiskey Springs Road Dillsburg, PA 1'1019 SENDER: GOLDBECK MCCAFFERTY & MCKEEVER February 10,2003 REFERENCE: PALUMBO, SUSAN K./ ACD-1599 06/11/03 - Cumberland - RETURN postage RECEIPT Certified Fee SERVICE Return Receipt Fee Restricted Delivery Total postage & Fees . ~ll~) US Postal Service POSTM~\,,"i u,,~ Receipt for . /.~ "~' ...~ -"" .~.:, ~!::' "'>:).;.'.\ Certified Mail ''/, \ .S?} \' '::::'5" ., y" No Insurance Coverage Provided " 1.." ~~/ Do Not Use for International Mall . :I" .~ ~IJ\)'~>/ .~---_. -- ---- .- -- .- - .-..- --------------- ----------------------------------------------------. PS Form 3800 June 2000 AFFIX POSTAGE TO MAIL PIECE TO COVER FIRST CLASS POSTAGE, CERTIFIED FEE, RETURN RECEIPT FEE AND CHARGES FOR ANY SELECTED OPTIONAL SERVICES. 1. Detach the form 3811, Domestic return receipt by tear- ing left to right across perf, Attach to mailpiece by peeling back the adhesive strips and affixing to front of mailpiece if space permits, Otherwise affix to back of mailpiece. 2, If you do not want the receipt postmarked, stick the article # label to the right of the return address, date receipt and retain the receipt. " 3. If you want this receipt postmarked, slip the 3800 receipt between the return receipt, and the mailpiece, and slide the edge of the receipt to the gummed edge of adhesive. This will hold the receipt in place to present to your mai/center, or post office service window, (SEE ILLUSTRATION) ... . III 141 711 ....................dI\..J Dlvld D. 001 la"IIS-\lm,nt"".'IJ",lIanl'" W,'rPOI'IJSOIUlionl, Jnc. lsnSoUlbllluionRd.SulllflO FIUbroot,CAUOU_4112 - Vow Arm ..... 123.... .... 112S4 CIy, _ '.... ----... ,'''!'- -0 ....".................... DaVid D. Doe Le"a. Segment Marketing Manager Walz pO.la' SOlutlon8, Ine. 1588 South MIUlon Rd. Suite 110 FallbroOk. CA 92028-4112 4. Enter fees for the services requested in the appropriate spaces on the front of this receipt. 5, Save this receipt and present it if you make an inquiry. ..~..... '"~''''''' . .... 1[.......... ..... ........ '" 11bO. 3901 9644 2550 3461 TO: PALUMBO, SAMUEL R. SAMUEL R. PALUMBO 113 Whiskey Springs Road Dillsburg, PA 17019 SENDER: PALUMBO, SUSAN K./ ACD-1599 06/11/03 - Cumberland RETURN postage RECEIPT Certified Fee SERVICE Return Receipt Fee Restricted Delivery Total Postage & Fees ; US Postal Service POS~~~~, Receipt for ,~. ! ~, ,t:' I~I ~ r~' t,... 1 ~ ~ ~.\ Certified Mail ,'it, \ ,~. I . ' -.......;: ~ \~\.. Y~~1' No Insurance Coverage Provided :/k-'" (Y Do Not Use for International Mail <~V'.t t4(l'j ---,.~.., ------------.-------------------------- --------------------------------------------------- PS Form 3800 June 2000 '-1 AFFIX POSTAGE TO MAIL PIECE TO COVER FIRST CLASS POSTAGE, CERTIFIED FEE, RETURN RECEIPT FEE AND CHARGES FOR ANY SELECTED OPTIONAL SERVICES. 1. Detach the form 3811, Domestic return receipt by tear- ing left to right across perf, Attach to mailpiece by peeling back the adhesive strip~ and affixjng to front of mailpiece if space permits. Otherwise affix to back of mailpiece. 2. If you do not want the receipt postmarked, stick the article # label to the right of the return address, date receipt and retain the receipt. ' 3, If you want this receipt postmarked, slip the 3800 receipt between the return receipt, and the mailpiece, and slide the edge of the receipt to the gummed edge of adhesive. This will hold the receipt in place to present to your mailcenter, or post office service window, (SEE ILLUSTRATION) I ? i ~I ~ :t ~ ~ 'I ~I 11][fIl- .. . '11 141 711 L.U.................., OnldD.0... LIllIISIllllllnllillrhllnglll'"...r Will POtlIISOlulIO"I,lllC. 158eSoulh MlulonRd. S"II'11G hllbrDoll,CA1l2GU_4112 - .~'-' o ---- L........................ David D. Doe Legal Segment Marketing Uanager Walz POala' Solutions, Inc. 1588 South Minion Rd. Suit. 110 Fallbrook, CA 92028.4112 4. Enter fees for the services requested in the appropriate spaces on the front of this receipt. 5. Save this receipt and present it if you make an inquiry. 1 - r-j -> ..... ..... -> tj' 0 .i Ul .t>. W IV 0.- .....Z '< c W en:! ~ a c>> ~ ~ ...., "'0 ...., ~ ~ '0 )> .' '0 ~ a .. -- ID (D ID s- F ~ CD !!. Ul~r"''';;--i -.. ii....::r "Vi-I ills" [ aid~i~ ." I: :'f..a n ~ :fr':li v 1- f' Illitl1fl.i . g !l~ r Ii,'" lidlt 1l'1fl ji'In Ii fill fIlII l ... gJf l mif" m,'jJ Iff II ;t1-j " 0 Il !!. <' z .. c ";I !: 'V~ f: 9- - 11 0-, 3~ ~ .. '0 o .. 3' .. .. .~ 11 !: . ~ :J .. g, ~ <l .. " :;' '" .. " ., 0' .... 01 __._ --"- -- .-- - - ---' o (0 co ...., OJ 01 .t>. w IV J~~j jli J~r: itf~ ~~l~~ ~g~ ~~!g ~i[~~ ~ - ~ C! ~ >Vol!.~ :::i",g = ::: $I ;:=!:::i if ~ 2~ I :: p 5 :j ~ ~ lM~~ a ; s ~ ~ ~ ~~ a~2 ; .. !2 ;; <;: 'g :!l~:;! .- ~ ;:; r~ q~ '; ~ i ~~ a; g ~ !;; ;1l ~ > to- ~ 0" ~ ~ ~ ~ ("l ("l 'J:I ::!: -< 0 ~ ~ ~ ~ ~ -< it. Q: f Ii' I ...... ~ - "'It ~: ~~~ \II 0 ~ II I · c: i ~ illl ~ ~ ~'II n:a"tl O>CD g:lCN N ....0... ~~... ... ~ 00'" C)\~~ -. -: ... : 000 05n.1l . . ~ . ... rl ~ ;; i g ~~ :7::>>0.",:) !: Q. :t fI a "n .! f~ :l~ ~. . i~ o .. " !l'O ~~ ~ i :,; ~ ~: f :> .., v," .. o- 00 1;; 0," z - ....'0 o ~ r:T ii' ~~ 5-~ .. 0. :l:" ~ .. Q. Q ~ ~ goo>)> iita."~ 5l-'~", :="';a.-- 8::;; 3 cd: '0 )J' g;;i{ . trt ILl 0 ..., ;;' -_OJ ;:J 0 _, .1lI 03- I~ ~.~~. ---4 .. 5' C . PCST~i'io '" .. '::'::rA~ '. .."r' D- .; .' " '~: ,'/~1E -." \ . ,/,:p ;' ;:". \ 'l. ^." , ,) .r."" .II. ,/ .^~, j' c;\Y a . Citifinancial Mortgage Co. Inc. f/k/a Ford CDC VS Susan K. Palumbo and Samuel R. Palumbo In The Court of Common Pleas of Cumberland County, Pennsylvania Writ No. 2002-5573 Civil Term Robert Bitner, Deputy Sheriff, who being duly sworn according to law, states that on March 31, 2003 at 7:30 o'clock PM, he served a true copy ofthe within Real Estate Writ, Notice and Description, in the above entitled action, upon the within named defendant, to wit: Susan K. Palumbo, by making known unto Susan Palumbo, personally, at 234 East Old York Road, Carlisle, Cumberland County, Pennsylvania, its contents and at the same time handing to her personally the said true and correct copy of the same. Richard Smith, Deputy Sheriff, who being duly sworn according to law, states that on March 26,2003 at 1 :08 o'clock PM, he served a true copy ofthe within Real Estate Writ, Notice and Description, in the above entitled action, upon the within named defendant, to wit: Samuel R. Palumbo, by making known unto Samuel Palumbo, personally, in the area of359 Whiskey Spring Rd., South Middleton Township, Cumberland County, Pennsylvania, its contents and at the same time handing to him personally the said true and correct copy of the same. Dawn Kell, Deputy Sheriff, who being duly sworn according to law, states that on April 07, 2003 at 1 :38 o'clock P.M., she posted a true copy of the within Real Estate Writ, Notice, Poster and Description, in the above entitled action, upon the property of Susan K. Palumbo and Samuel R. Palumbo located at 234 East Old York Rd., Carlisle, Pennsylvania, according to law. R. Thomas Kline, Sheriff, who being duly sworn according to law, states he served the above Real Estate Writ, Notice, Poster and Description in the following manner: The Sheriff mailed a notice of the pendency of the action to one of the within named defendants, to wit: Susan K. Palumbo, by regular mail to her last known address of234 E. Old York Road, Carlisle, PA 17013. This letter was mailed under the date of April 04, 2003 and never returned to the Sheriffs Office. R. Thomas Kline, Sheriff, who being duly sworn according to law, states he served the above Real Estate Writ, Notice, Poster and Description in the following manner: The Sheriff mailed a notice ofthe pendency ofthe action to one of the within named defendants, to wit: Samuel R. Palumbo, by regular mail to his last known address of 113 Whiskey Springs Rd., Dillsburg, PA 17019. This letter was mailed under the date of April 04, 2003 and never returned to the Sheriffs Office. Sworn and subscribed to before me This _ day of So AI1~.we~jo ~ /. ,,- . ; ././ ~~.~:;/ -- ~, ,c. " _~, ._ " ,'_ '" . ,/ ..~._-/.~P'>'___~.tJ.tt!/1 ,?- ~;~_ IS ," '~~..f'"' .......-0f9I.... ~_:~:'_. ~ R. Thomas Kline, Sheriff 2003, A.D. Prothonotary Goldbeck McCafferty & McKeever BY: Joseph A. Goldbeck, Jr. Attorney I.D. #16132 Suite 500 - The Bourse Bldg. 111 S. Independence Mall East Philadelphia, PA 19106 215-627-1322 Attorney for Plaintiff CITIFINANCIAL MORTGAGE CO. INC. F/KJA FORD CDC 1111 Northpoint Drive Building 4, Suite 100 Coppell, TX 75019-3931 IN THE COURT OF COMMON PLEAS of Cumberland County Plaintiff CIVIL ACTION - LAW vs. SUSAN K. PALUMBO SAMUEL R. PALUMBO Mortgagors and Record Owners ACTION OF MORTGAGE FORECLOSURE 234 E. Old York Road Carlisle, PA 17013 No. 02-5573 CIVIL TERM Defendants AFFIDAVIT PURSUANT TO RULE 3129 CITIFINANCIAL MORTGAGE CO. INC. FIKJA FORD CDC, Plaintiff in the above action, by its attorney, Joseph A. Goldbeck, Jr., Esquire, sets forth as of the date the praecipe for the writ of execution was filed the following information concerning the real property located at: 234 E. Old York Road Carlisle, P A 17013 l.Name and address of Owners or Reputed Owners: SUSAN K. PALUMBO 113 Whiskey Springs Road Dillsburg, P A 17019 SAMUEL R. PALUMBO 113 Whiskey Springs Road Dillsburg, PA 17019 2. Name and address of Defendants in the judgment: SUSAN K. PALUMBO 113 Whiskey Springs Road Dillsburg, PA 17019 SAMUEL R. PALUMBO 113 Whiskey Springs Road Dillsburg, P A 17019 3. Name and last known address of every judgment creditor whose judgment is a record lien on the property to be sold: CUMBERLAND COUNTY ADULT PROBATION Cumberland County Courthouse 1 Courthouse Square, 3rd Floor Carlisle, PA 17013 P A DEPARTMENT OF PUBLIC WELFARE Bureau of Child Support Enforcement Health and Welfare Bldg. - Room 432 P.O. Box 2675 Harrisburg, PA 17105-2675 DOMESTIC RELATIONS OF CUMBERLAND COUNTY PO Box 320 Carlisle, PA 17013 4. Name and address of the last recorded holder of every mortgage of record: PENNSYLVANIA HOUSING FINANCE AGENCY 2101 N. Front Street PO BOX 8028 Harrisburg, P A 17110-8028 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: 6. Name and address of every other person of whom the plaintiff has knowledge who has any record interest in the property which may be affected by the sale. 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. (attach separate sheet if more space is needed) 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. DATED: May 13.2003 0~ () c: $: -0 tJ:J "", ("t1 (") ~,,~ 1) i.'-~': [T i <, ({) ~~ :i.~ ~~ .;-- o (,A) ;....,-, ~.) " (,:"; o w :J: ~ o "'T1 ~-n ~". \() -=-l~ -... (J -n , I ": C=S. ;;: iTi ..::] -<, Citifinancial Mortgage Co., Inc. flk:Ja Ford CDC VS Susan K. Palumbo and Samuel R. Palumbo In The Court of Common Pleas of Cumberland County, Pennsylvania Writ No. 2002-5573 Civil Term R. Thomas Kline, Sheriff, who being duly swom according to law, states this writ is retumed STAYED pursuant to instructions from Attomey Joseph Goldbeck. Sheriff's Costs: Docketing Poundage Surcharge Law Library Prothonotary Mileage Certified Mail Levy Posting Handbills Advertising Law Joumal Patriot News Share of Bills 30.00 10.91 30.00 .50 1.00 11.04 15.00 15.00 15.00 214.25 188.50 25.24 $ 556.44 paid by attorney 6/11/03 Sworn and subscribed to before me So Answers: r~ ~if.'.-; R. Thomas Kline, Sheriff ByJdl~~ RealE~te Deputy This Fl":-- day of Cf./LJ ~ 2003, AD. Q''f'~Q '"tttJ/~'J,A..PfIi Prothonotary \ ,$'0 Qk. '-1 I IS''') . ~ /y;/31 -, THE PATRIOT NEWS THE SUNDAY PATRIOT NEWS Proof of Publication Under f>d. 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 Ass!. 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 ot 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 atoresaid; 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 April and the 6th day(s) of May 2003, That neither he nor said Company is interested in the subject matter of said printed notice or advertising, and that all of the allegations of this statement as to the time, place and character of publication are true; and That he has personal knowledge of the facts aforesaid and is duly authorized and empowered to verify this statement on behalf of The Patriot-News Co, aforesaid by virtue and pursuant to a resolution unanimously passed and adopted severally by the stockholders and board of directors of the said Company and subsequently duly recorded in the office for the Recording of Deeds in and for said County of Dauphin in Miscellaneous Book "M", Volume 14, Page 317, PUBLICATION COPY SALE #32 RIAJ,.:.,.. ULE NO. 32 WIlt~r ., .1~~~t ".~, AU. T!lAT certain t altn! !and WIth tho '1__ thereon _.,si_ in Snnth, !t\lddIeIlm . TnwnIhi};. Cnmbodand Conntj. ~._bnnndedN>t~..fuIlo>(I: ~Il..~in._nfllie'lntk Rnad, Il . 1!oI1otn.1ino.91 Im>d ,n! eo,Jc LnmbetClllllNY, jnc;;_" an I!Ut<ily d_ elnn8Ih<'_,linonfIh<YootI\nld. 124,feot 4,incMoloi pni",inRid """" \illO; _in aSnnll!of\)l_tlnn&!and1lQWnr fOhllellynfW HlIl\lldClino. Iflliliettoipnll\t,' Total atthetall~;_iniWeatedy,- =~~~la~ Publisher's Receipt for Advertising Cost line nf said land, 145 f<d tn"'tt.: PIoce pi Co" publisher of The Patriot.News and The Sunday Patriot-News. newspapers of general B~ied with i frame bnngalnw anil' ldge receipt of the aforesaid notice and publication costs and certifies that the same have ~'.......nliresidcntial d=~'234.-jI.,9WY\110 Rood. CarIialo..,tiijOu. ' SOLD.. the 'prnfeIt! of S_ It, Palumbo and Samuel, R, . Palumbo. . , TAX PARCl!Lif4lI.l, 1WlJ. ...,...../J.,~".. Sworn to and sub cr' ed before m,e this 14th day of M~~O ,D, NOlanalSea! t7b l/~u/?/uP'./ ~ Teny L. Russell,NotaJy Public /" (/y~\... City Of Harrisburg, Dauphin County My Commission Expires June 6. 2006 NOT Y PUBLIC Member,Pennsyivani.As_nOf~commission expires June 6, 2006 CUMBERlAND COUNlY SHERIFFS OFFICE CUMBERlAND COUNlY COURTHOUSE CARLISLE, PA. 17013 Statement of Advertising Costs To THE PATRIOT-NEWS CO" Dr. For publishing the notice or publication attached hereto on the above stated dates Probating same Notary Fee(s) $ $ $ 186,75 1.75 188,50 By..."".",.".,.".""""."".",."""...",."""""""'" PROOF OF PUBLICATION OF NOTICE IN CUMBERLAND LAW JOURNAL (Under Act No. 587, approved May 16, 1929), P. L.1784 STATEOFPENNSYLVANIA : ss. COUNTY OF CUMBERLAND : 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, VlZ: APRIL 25, MAY 2, 9, 2003 Affiant further deposes that he is authorized to verify this statement by the Cumberland Law Joumal, a legal periodical of general circulation, and that he is not interested in the subject matter of the aforesaid notice or advertisement, and that all allegations in the foregoing statements as to time, place and character of publication are true. REAL ESTATE SALE NO. 32 Wrtt No, 2002-5573 Civil Cltlftnanclal Mortgage Co. Inc.. f/k/a Ford CDC vs, Susan K. Palumbo and Samuel R. Palumbo Atly.: Joseph Goldbeck ALL that certain tract of land with the improvements thereon erected. situate in South Middleton Town- ship. Cumberland County, Pennsyl- vania, bounded and described as follows: BEGINNING at a spike In the center of the York Road. at the East- ern line of land of Coyle Lumber Company, Inc.; thence in an East- erly direction along the center line of the York Road. 124 feet 4 inches to a point in said center line; thence in a Southerly direction along land now or fonnerly of W. Harold Cline. 166 feet to a point at the TaU Race; thence in a Westerly direction along said Tail Race 135 feet to a point on the Eastern line of Coyle Lumber Company. Inc.; thence in a North- erly direction along the Eastern line of said land. 145 feet to the Place of BEGINNING, BEING improved with - a frame bungalow and outbuildings, SHORT DESCRIPTION IMPROVEMENTS consist of a residential dwelling. BEING PREMISES: 234 E, Old York Road, Carlisle, PA 17013, SOLD as the property of SUSAN K. PALUMBO and SAMUEL R. PA- LUMBO, TAX PARCEL #40-11-0288-009, SWORN TO AND SUBSCRIBED before me this 9 day of MAY. 2003_ d--L-0 L, J0<;t:ivv MOTh. (/ LOIS E. SNYDER, t~JY PublIc CartIsIe Boro, Cumberland County My eo.,", 111'111 Expir8s March 5. 2005 ~ ---~..." center of the York l'(OdU, ....... . em line of land of Coyle Lumber Company, Inc.; thence in an East~ edy direction along the center Une of the York Road. 124 feet 4 inches to a point in said center line; thence in a Southerly direction along land now or formerly of W. Harold Cline, 166 feet to a point at the Tail Race; thence in a Westerly direction along said Tail Race 135 feet to a point on the Eastern line of Coyle Lumber Company, Inc.; thence in a North- erly direction along the Eastern line of said land, 145 feet to the Place of BEGINNING, BEING improved with a frame bungalow and outbuildings, SHORT DESCRIPTION IMPROVEMENTS consist of a residential dwel11ng, BEING PREMISES: 234 E, Old York Road, Carlisle, PA 17013, SOLD as the property of SUSAN K. PALUMBO and SAMUEL R. PA- LUMBO, TAX PARCEL #40-II-0288-009, L PRAECIPE FOR WRIT OF EXECUTION - (MORTGAGE FORECLOSURE) P.R.C.P 3180-3183 Joseph A. Goldbeck, Jr. Attonl<"y I.D,#16132 'Suite 5000 - Mellon Independence Center 70 I Market Street Philadelphia, PAl 9 I 06-1532 215-627-1322 Attorney for Plaintiff CITIFlNANCIAL MORTGAGE CO, INe. F/K/ A FORD CDC I I I 1 Northpoint Drive Building 4, Suite 100 Coppell, TX 75019-3931 Plaintiff vs. SUSAN K, PALUMBO SAMUEL R. PALUMBO Mortgagor(s) and Record Owner(s) 234 E. Old York Road Carlisle, PA 17013 Defendant( s) IN THE COURT OF COMMON PLEAS of Cumberland County CIVIL ACTION - LAW ACTION OF MORTGAGE FORECLOSURE No, 02-5573 CIVIL TERM TO THE PROTHONOTARY: PRAECIPE FOR WRIT OF EXECUTION Issue Writ of Execution in the above matter: Amount Due Interest from 05/04/2002 to 02/10/2003 at 10,6500% (Costs to be added) $97,734,08 j ....., z-~ c_ ., -.i-"! .._1 -;-: f"-J l.:' c:) WRIT OF EXECUTION - (MORTGAGE FORECLOSURE) P,R,C.P, 3180-3183 AND Rule 3257 CITIFINANCIAL MORTGAGE CO, INe. F/K/A FORD CDC IIII Northpoint Drive Building 4, Suite 100 Coppell. TX 75019-3931 In the Court of Common Pleas of Cumberland County vs. No, 02-5573 CIVIL TERM SUSAN K, PALUMBO SAMUEL R, PALUMBO 234 E, Old York Road Carlisle, PAl 70 13 WRIT OF EXECUTION (MORTGAGE FORECLOSURE) Commonwealth of Pennsylvania: County of Cumberland To the Sheriff of Cumberland County,_Pennsylvania To satisfy the judgment, interest and costs in the above matter you are directed to levy upon and sell the following described property: PREMISES: 234 E, Old York Road Carlisle, PA 17013 See Exhibit "A" attached AMOUNT DUE $97.734,08 Interest from 05104/2002 thru 02/1 0/2003 (Costs to be added) Dated: Prothonotary, Common Pleas Court of Cumberland County, Pennsylvania Deputy r") "- ,--- '.-- , f'.} C"~ ::,j '" ..l ~ ~z ~o ~~ ~o e 2: u "u r.. E-<~O on,.. "(!lI: "';0> <=:0 ou z'" =: ~ ~ ~ o '"' < i:2 <.;; o ~ 8 ~ ou <0 ou ~ o ::;\ ..-l < ... u ~ ~ '"' ... ~ ... u "' " ~ ~ .,";. ~ "'0" gC!l~'" o~og("fj co~"'Oo::::8 ::;:..-l~ r-- b~8.!6- ..-l,,"Pl~< <' "" ~O::::]:9 .u ........1 ro 0- ~~~ ,,:!, ~'JJ~- Z ~';:;'.". 1;; <t: 0 M U en ~N ~'" OJ) '" t:: o ::;\ ~ z o ... ,.. ;0> u~ ~ ~ '" a r..,s o ii ,.. 8 ~i !lI:~ 0'" r.. 0 ",E, e:: u ~ ~ .=i1t;: ..:J ".c u ,S " '" .g~ - ~ c3<.S ,'" < " ..c E " 0 0.," t5~ ~ ~ " ~ ~ t ~ N ~~ ~ ~ t:: '"7 ~..g-\O a'dgM:3~ >.frcn2::M -." ... ~~~~~ u~ ~ .;g~ yO ,.s::;_ ~:E (; ~N ..::c I r- "'CI ~o ~ .cO ..c :g~ Po< r3 .J.j " '" .' ALL that certain tract of land with the improvements thereon erected, situate in South Middleton Township, Cumqerland County, Pennsylvania; bounded and described as follows: BEGINNING at a spike in the center of the York Road, at the Eastern line of land of Coyle Lumber company, Inc.: thence in an Easterly direction along the center line of the York Road, 124 feet. 4 inches to a point in said center line: thence in a Southerly direction along land now or formerly of W. Harold Cline, 166 feet to a point at the Tail .Race; thence in a Westerly direction along said Tail Race 135 feet to a point on the Eastern line of Coyle Lumber: ,company, Inc.; thence in a Northerly direction along' the Eastetn line ot said land, 145 feet to the Place of BEGINNING4 . BEING improved with a frame bungalow and outbuildings; SHORT DESCRIPTION IMPROVEMENTS consist of a residential dwelling. BEING PREMISES: 234 E. Old York Road Carlisle, PA 17013 SOLD as the property of SUSAN K. PALUMBO and SAMUEL R. PALUMBO TAX PARCEL #40-11-0288-009 "~~ -. ~ ~' ~ t'=0 --.1 ~r o<l ---1 - ?-~} 0- ' ,.J;: I ' \ c~ ~ l~ eE( Gj r ~-- 0-> - -S:) ~ ---. ~~-;-SJ -;-{:' -S\ J\ ~ - --......... ~ ~ '<J-, ~ 0- c::! ~ ,~-.) r-....~ '~-J :- :~j __..: {;-i I" l -i = c) ~, I~'i , / ..,..- WRIT OF EXECUTION and/or ATTACHMENT COMMONWEALTH OF PENNSYLVANIA) COUNTY OF CUMBERLAND) NO 02-5573 Civil CIVIL ACTION - LAW TO THE SHERIFF OF CUMBERLAND COUNTY: To satisfy lhe debt, interest and costs due CITIFINANCIAL MORTGAGE CO., INC. f/k/a FORD CDC Plaintiff (s) From SUSAN K. AND SAMUEL R PALUMBO, 113 WHISKEY SPRING ROAD, DlLLSBURG PA 17019. (I) You are directed to levy upon the property of the defendant (s)and to sell REAL ESTATE LOCATED AT 234 E. OLD YORK ROAD, CARLISLE P A 17013 (SEE ELGAL 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 ofthe 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 $97,734.08 Interest 5/4/02 TO 2/1 0/03 @ 10.6500% L.L. Atty's Cornm % Due Prothy 1.00 Other Cosls Atty Paid $787.43 Plaintiff Paid Date: JANUARY 12,2004 (Seal) CURTIS R. LONG Pro at, h otary / { A L' By/' ~',J-d t1tVv ~~ Deputy U REQUESTING PARTY: Name JOSEPH A. GOLDBECK, JR., ESQ. Address: SillTE 5000-MELLON INDEPENDENCE CENTER 701 MARKET ST., PHILADELPHIA PA 19106-1532 Attorney for: PLAINTIFF Telephone: (215) 627-1322 Supreme Court ID No, 16132 Jospeh A. Goldbeck, Jr. Attorney LD, #16132 Suite 5000 - Mellon Independence Center 70 I Market Street Philadelphia, PA 19106-1532 215-627-1322 Attorney for Plaintiff CITIFINANCIAL MORTGAGE CO, INC, F/K1A FORD CDC IIII Northpoint Drive Building 4, Suite 100 Coppell, TX 75019-3931 Plaintiff vs. SUSAN K. PALUMBO SAMUEL R, PALUMBO Mortgagor(s) and Record Owner(s) 234 E, Old York Road Carlisle, P A 17013 Defendant( s) IN THE COURT OF COMMON PLEAS of Cumberland County CIVIL ACTION - LAW ACTION OF MORTGAGE FORECLOSURE NO. 02-5573 CIVIL TERM CERTIFICATION AS TO THE SALE OF REAL PROPERTY I, Joseph A. Goldbeck, Jr., Esquire hereby certify that I am the attorney of record for the Plaintiff in this action, and I further certify that this property is subject to Act 91 of 1983 and the Plaintiff has complied with all the provisions of the Act. r___ .._' ',i f.; r: Goldbeck McCafferty & McKeever BY~ A, Goldbeck, Ir. Attorney LD, #16132 Suite 5000 - Mellon Independence Center 70 I Market Street Philadelphia, PA 19106-1532 215-627-1322 Attorney for Plaintiff ClTIFINANCIAL MORTGAGE CO, INC, F/K/A FORD CDC I111 Northpoint Drive Building 4, Suite 100 Coppell, TX 75019-3931 IN THE COURT OF COMMON PLEAS of Cumberland County Plaintiff vs, CIVIL ACTION - LAW SUSAN K, PALUMBO SAMUEL R, PALUMBO (Mortgagor(s) and Record Owner(s)) 234 E, Old York Road Carlisle, P A 17013 ACTION OF MORTGAGE FORECLOSURE Defendant(s) No, 02-5573 CIVIL TERM AFFIDAVIT PURSUANT TO RULE 3129 CITIFINANCIAL MORTGAGE CO, INe. F/KJA FORD CDC, Plaintiff in the above action, by its attorney, Joseph A. Goldbeck, Jf., Esquire, sets forth as of the date the praecipe for the writ of execution was filed the following information concerning the real property located at: 234 E, Old York Road Carlisle, P A 17013 1 ,Name and address of Owner(s) or Reputed Owner(s): SUSAN K, PALUMBO 113 Whiskey Springs Road Dillsburg, PA 17019 SAMUEL R. PALUMBO 113 Whiskey Springs Road Dillsburg, PA 17019 2, Name and address ofDefendant(s) in the judgment: SUSAN K, PALUMBO 113 Whiskey Springs Road Dillsburg, PA 17019 SAMUEL R, PALUMBO 113 Whiskey Springs Road Dillsburg, PA 17019 3, Name and last known address of every judgment creditor whose judgment is a record lien on the property to be sold: CUMBERLAND COUNTY ADULT PROBATION Cumberland County Courthouse 1 Courthouse Square, 3rd Floor Carlisle, P A 17013 (-I c c .....,~ CC"_, C~ C) -0 ;-j h'i;'';; - ~~J fT1 , c--, L,''''..''> I--~l "_ .--( ~- .:.-.. -"-,~ ""'.-- r'\,:, - ., ~--, " ) n 02-5573 CIVIL TERM GOLDBECK McCAFFERTY & McKEEVER BY: Joseph A. Goldbeck, Jr. Attorney J.>>",#16132 Suite )000- Mellon Independence Center 701 Market Street Philadelphia, P A 19106 215-627-1322 Attorney for Plaintiff CITIFINANCIAL MORTGAGE CO. INe. F/KJA FORD CDC 1111 Northpoint Drive Building 4, Suite 100 Coppell, TX 75019-3931 IN THE COURT OF COMMON PLEAS of Cumberland County Plaintiff CIVIL ACTION - LAW vs. SUSAN K. PALUMBO SAMUEL R, PALUMBO Mortgagor(s) and Record Owner(s) ACTION OF MORTGAGE FORECLOSURE 234 E. Old York Road Carlisle, P A 17013 Term No. 02-5573 CIVIL TERM Defendant( s) THIS LAW FIRM IS A DEBT COLLECTOR AND WE ARE ATTEMPTING TO COLLECT A DEBT. THIS NOTICE IS SENT TO YOU IN AN ATTEMPT TO COLLECT A DEBT. ANY INFORMATION OBTAINED FROM YOU WILL BE USED FOR THAT PURPOSE. NOTICE OF SHERIFF'S SALE OF REAL PROPERTY TO: PALUMBO, SUSAN K. SUSAN K. PALUMBO 113 Whiskey Springs Road Dillsburg, PA 17019 Your house at 234 E, Old York Road, Carlisle, P A 17013 is scheduled to be sold at Sheriffs Sale on Wednesday, June 09, 2004, at 10:00 AM, in Commissioners Hearing Rm 2nd FL Courthouse to enforce the court judgment of$97,734,08 obtained by CITIFINANCIAL MORTGAGE CO. INC. FIKIA FORD CDC against you, NOTICE OF OWNER'S RIGHTS YOU MAY BE ABLE TO PREVENT TmS SHERIFF'S SALE To prevent this Sheriffs Sale you must take immediate action: I. The sale will be cancelled if you pay to CITIFINANCIAL MORTGAGE CO, INC, FIKIA FORD CDC, the back payments, late charges, costs and reasonable attorney's fees due. To fmd out how much you must pay call: 215-627-1322 ~~ ,"c." C':::- c:;: .'.:i'j '- , ~-."~ .' gh_ -C' f'.' , -) , r , -. , UNITED STATES BANKRUPTCY COURT MIDDLE DISTRICT OF PENNSYL VANIA IN RE: SUSAN K. PALUMBO CASE NO.: 1-03-03368 CllAPl'ER 13 Debtor(l) OJIDER DI~M"qINQ CASE At, Harrisburg, in SlIid district, on this laty ofDBCEMBER, 2003, Upon Motion of the Trustceto Dismiss Case, and it having been determined atlernoticeand hearing that the case should be dismissed, it i5 ORDERED that the case of the above-DlIIDed debtor(s) be and it hereby is dismissed and it is further ORDERED that the truBtcehereby is discbarged from further responsibility in this case. and it is further ORDERED that all pending advemary proceedings in this case be and they hereby are dismissed, and it is further ORDERED that any outstanding fees are immediately due and payable to the U.S. BaDlcruptcy Court. BY THE COURT: FilED HARRISBURG PA ~,~ :~CY JUDGE ~~ DEe 1 2 2003 );; Clerk, U.S. Bankwptcy Court 045500 045500 44708045592011 ,s.j r_:-. Co ,'->.) :;:; <- ,..' i'.~' 01/12/2004 11:36 FAX 215 627 7734 GOLDBECK USBC PAM - LIVE - V2.3 - Docket Report Il1i 002 Page 1 of4 CREDS, 34IHeld, PlnCnfrmd, DISMISSED, CLAIMS U.S. Bankruptcy Court Middle District of Pennsylvania (Harrisburg) Bankruptcy Petition #: 1:03-bk.03368-MDF Assigned to: Mary D France Chapter 13 Voluntary Asset Date Filed: 06/06/2003 Date Terminated: 12/12/2003 Date Dismissed: 12/12/2003 Susan K Palumbo 234 East Old York Road Carlisle, PA 17013 SSN: xxx-xx-6505 Debtor represented by Henry W Van Eck, Esq Cunningham & ChernicoffPC 2320 NORTH SECOND 8T PO BOX 60457 HARRISBURG, PA 17106-0457 7I 7238-6570 Charles J DeHart, HI PO Box 410 Hummelstown, P A 17036 717-566-6097 Trustee United States Trustee PO Box 969 Harrisburg, P A 17108 (717) 221-4515 Asst U.S. Trustee Filing Date # Docket Text 06/06/2003 1 Chapter 13 Voluntary Petition Missing Summary of Schedules, Schedule5 A-J, Statement of Financial Affairs, Attomey Compensation, Chapter 13 Plan, and Mailing Matrix. Filing fee due in the amount of$ 185.00 Filed by Henry W VanEck Esq of Cunningham & Chernicoff PC on behalf of Susan K Palumbo. (Peterson, Deborah) (Entered: 06/06/2003) 06/06/2003 Receipt of Voluntary Petition Filing Fee. Receipt Number 596195 Fee Amount $ 185,00 (RE: related document(s)1). (peterson, Deborah) (Entered: 06/09/2003) 06/13/2003 Tentative Date for Meeting of Creditors (Case missing matrix or plan), THIS IS SUBJECT TO CHANGE. 7/17/2003 at 09:00 AM. (Anthony, Carol) (Entered: 06/13/2003) 01/12/2004 11:36 FAX 215 627 7734 GOLDBECK USBC PAM - LIVE - V2J - Docket Report I4J 003 Page 2 of 4 06113/2003 2 Matrix filed/Creditor List Uploaded Filed by Henry W VanEck Esq of Cunningham & Chernicoff PC on behalf of Susan K Palumbo (RE: related document(s)l), (Garner, April) (Entered: 06/16/2003) 06/16/2003 3 Motion to Extend Time to file Schedules/Statements and Chapter 13 Plan Filed by Henry W VanEck Esq of Cunningham & Chernicoff PC on behalfofSusanK Palumbo (RE: related document(s)l) . (Gamer, April) (Entered: 06/17/2003) 06/17/2003 4 Order Gl'anting Motion to Extend Time (RE: related document(s) [3]). (Gamer, April) (Entered: 06/17/2003) 06/18/2003 Tentative Date for Meeting of Creditors (Case missing matrix or plan). THIS IS SUBJECT TO CHANGE, 7/24/2003 at 09:00 AM. (Anthony, Carol) (Entered: 06/18/2003) 06/24/2003 Tentative Date for Meeting of Creditors (Case missing matrix or plan). THIS IS SUBJECT TO CHANGE. 7/31/2003 at 09:00 AM. (Anthony, Carol) (Entered: 06/24/2003) 07/16/2003 Tentative Date for Meeting of Creditors (Case missing matrix or plan). THIS IS SUBJECT TO CHANGE. 8/21/2003 at 09:00 AM. (CA) (Entered: 07/16/2003) 07/21/2003 ,~ Schedules A -1 , Statement of Disclosure of Compensation of Attorney for Debtor, Statement of Financial Affairs, Summary of Schedules Filed by Henry W VanEck Esq of Cunningham & Chemicoff PC on behalf of Susan K Palumbo (RE: related document(s)l), (AG) (Entered; 07/2412003) 07/21/2003 Q Chapter 13 Plan Filed by Henry W VanEck Esq of Cunningham & Chemicoff PC on behalf of Susan K Palumbo (RE: related document (s)l). (AG) (Entered: 07/24/2003) 07/21/2003 Tentative Date for Meeting of Creditors. THIS IS SUBJECT TO CHANGE. 8/28/2003 at 09:00 AM. (AG) (Entered: 07/24/2003) 07/24/2003 Tentative Date for Meeting of Creditors (Case missing matrix or plan). TIDS IS SUBJECT TO CHANGE. 8/28/2003 at 09:00 AM. (CA) (Entered: 07/24/2003) 07/25/2003 7 Objection to Claim 1 ofCitiFinancial Mortgage Company Filed by Henry W VanEck Esq of Cunningham & Chemicoff PC on behalf of Susan K Palumbo, (NP) (Entered: 07/2812003) 07/28/2003 8 Notice sent to counsel for mailing fixing answer/objection date (RE: related document(s)[7] ). (NP) (Entered: 07/28/2003) 01/12/2004 11:36 FAX 215 627 7734 GOLDBECK USBC PAM - LIVE - V2.3 - Docket Report I4i 004 Pagd of 4 07/3012003 9 Certificate of mailing of notice sent by counsel Filed by Henry W Van Eck Esq of Cunningham & ChemicoffPC on behalf of Susan K Palumbo (RE: related document(s)[7] ). Objections due by 8/28/2003. (NF) (Entered: 07/31/2003) 08/05/2003 lQ Request to BNe - Meeting of Creditors. 341(a) meeting to be held On 8/28/2003 at 12:00 PM Federal Bldg, Trustee Hearing Rm, Rm 1160, 11th Fl, 228 Walnut St, Harrisburg, PA Proofs of Claims due by 11/26/2003 (CA) (Entered: 08/05/2003) 08/07/2003 11 BNC Certificate of Mailing, Service Date 08/07/2003. (Related Doc # lQ) (Admin.) (Entered: 08/08/2003) 08107/2003 12 BNC Certificate of Mailing , Service Date 08/07/2003, (Related Doc # lQ) (Admin.) (Entered: 08/08/2003) 08/28/2003 13 Certification of Trustee that 341 Meeting of Creditors Held Filed by Charles J DeHart, III. Last day to Object to Plan ConflIDlation 9/13/2003. (DP) (Entered: 08/29/2003) 09/19/2003 14 Order Confirming Chapter 13 Plan (RE: related document(s)!i, [13] ). (KZ) (Entered: 09/19/2003) 1011412003 15 Motion to Dismiss Case for material default and hearing notice to parties. Filed by Charles J DeHart, III (RE: related document(sll,l). Hearing scheduled for 11/13/2003 at 02:00 PM at 3rd & Walnut Streets, Bankruptcy Courtroom (3rd Floor), Federal Building, Harrisburg, PA, (NF) (Entered: 10/14/2003) 10/14/2003 16 Motion for Relief from Stay with Certificate of non-concurrence, Filing fee due in the amount of $ 75,00 Filed by Gary E McCafferty of Goldberg McCafferty and McKeever on behalf of CitiFinancial Mortgage Co lnc , (NP) (Entered: 10/1412003) 10/1412003 Receipt of Motion for Relief from Stay Filing Fee. Receipt Number 600864 Fee Amount $ 75 (RE: related document(s)[16] ). (NP) (Entered: 10115/2003) 10/15/2003 17 Order (RE: related document(s)[16) ). Answers are due on; 10/30/2003. Hearing scheduled for 11/5/2003 at 09:00 AM at 3rd & Walnut Streets, Bankruptcy Courtroom (3rd Floor), Federal Building, Harrisburg, P A. (NP) (Entered: 10/15/2003) 10/20/2003 18 Certificate of Service Filed by Gary E McCafferty of Goldberg McCafferty and McKeever on behalf of CitiFinancial Mortgage Co lnc (RE: related document(s)[16], [17]). (NF) (Entered: 10/21/2003) 01/12/2004 11:36 FAX 215 627 7734 GOLDBECK I4i 005 Page 4 of 4 USBC PAM - LIVE - V2,3 - Docket Report 10123/2003 19 Answer to Motil for Relief from Automatic Stay Filed by Henry W VanEck Esq of Cunningham & Cherrucoff PC on behalf of Susan K Palumbo (RE: related document(s)[16]). (NP) (Entered: 10/24/2003) 11105/2003 20 Proceeding Memo: Hearing held on Motion of CitiFinancial for relief from stay. Settled - Stipulation within 30 days, othenvise, proceeding to be dismissed without prejudice. (RE: related document(s)[19], [16)). Stipulation due 12/5/2003, (EW) (Entered: 11/06/2003) 11/19/2003 21 Correspondence from Trustee re hearing. No appearance for debtor. Case to be dismissed Filed by Charles J DeHart, III (RE: related document(s)[l5) ). (NP) (Entered: 11119/2003) ~-, { 12/12/2003 '2.2 Order Granting Motion to Dismiss Case for material default (RE: ~ related document(s)[15]). (NP) (Entered: 12/1212003) 12/14/2003 23 BNC Certificate of Mailing, SerVice Date 12/14/2003. (Related Doc # 22) (Admin_) (Entered: 12/15/2003) 12/1812003 24 Final Report of Trustee in Dismissed Case Filed by Charles J DeHart, III. (NP) (Entered: 12/18/2003) I I I 01/12/200410:11:51 Ip ACER Login: W.0060 JIClient Code: I IDescription: IlDocket Repon Ilca.. Number: 1I1:03-bk-03368-MDF I IBillable Pal/;es; 112 JICost; 110.14 - I PACER Service Center Transaction Receipt Citifinancial Mortgage Co. Inc. VS Susan K. Palumbo and Samuel R. Palumbo In The Court of Common Pleas of Cumberland County, Pennsylvania Writ No. 2002-5573 Civil Term R. Thomas Kline, Sheriff, who being duly swom according to law, states this writ is returned STAYED per instructions from Attorney Joseph Goldbeck. Sheriff's Costs: Docketing Poundage Posting Handbills Advertising Law Library Prothonotary Levy Mileage Surcharge Postpone Sale Out of County York County Law Joumal Patriot News Share of Bills 30.00 13.10 15.00 15.00 1.00 15.00 8.28 30.00 20.00 9.00 40.13 209.60 232.51 29.26 $ 667.88 Sworn and subscribed to before me So AnS~ ~ This 3, ~( day of ~.ciE",,~ ,~ ' () Q. . A i?A2"" R. Thomas Kli,ne, Sheriff 2004, A.D.~. . ~ ,''r'7 BY JocLJ.-l,&vut~ Prothonotary Real E;~& Deputy , j.1J"O .., Gk.. l{ 7 0;1. fl.. ;0'10(, r... Goldbeck McCafferty & McKeever BY: Joseph A. Goldbeck, Jr. AttorneyLD, #16132 Suite 5000 - Mellon Independence Center 701 Market Street Philadelphia, P A 19106-1532 215-627 -1322 Attorney for Plainti]!' CITIFINANCIAL MORTGAGE CO, INe. F/K/A FORD CDC 1111 Northpoint Drive Building 4, Suite 100 Coppell, TX 75019-3931 IN THE COURT OF COMMON PLEAS of Cumberlaud County Plaintiff vs, CIVIL ACTION - LAW SUSAN K. PALUMBO SAMUEL R. PALUMBO (Mortgagor(s) and Record Owner(s)) 234 E, Old York Road Carlisle, P A 17013 ACTION OF MORTGAGE FORECLOSURE Defendant( s) No, 02-5573 CIVIL TERM AFFIDAVIT PURSUANT TO RULE 3129 CITlFINANCIAL MORTGAGE CO, INC, F/KI A FORD CDC, Plaintiff in the above action, by its attorney, Joseph A, Goldbeck, Jr" Esquire, sets forth as of the date the praecipe for the writ of execution was filed the following information concerning the real property located at: 234 E, Old York Road Carlisle, PA 17013 I ,Name and address ofOwner(s) or Reputed Owner(s): SUSAN K, PALUMBO 113 Whiskey Springs Road Dillsburg, PA 17019 SAMUEL R, PALUMBO 113 Whiskey Springs Road Dillsburg, PA 17019 2. Name and address ofDefendant(s) in the judgment: SUSAN K. PALUMBO 113 Whiskey Springs Road Dillsburg, P A 17019 SAMUEL R. PALUMBO 113 Whiskey Springs Road Dillsburg, PA 17019 3, Name and last known address of every judgment creditor whose judgment is a record lien on the property to be sold: CUMBERLAND COUNTY ADULT PROBATION Cumberland County Courthouse I Courthouse Square, 3rd Floor Carlisle, P A 17013 PA DEPARTMENT OF PUBLIC WELFARE - Bureau of Child Support Enforcement Health and Welfare Bldg. - Room 432 P,O, Box 2675 Harrisburg, P A 17105-2675 DOMESTIC RELATIONS OF CUMBERLAND COUNTY PO Box 320 Carlisle, P A 17013 4. Name and address of the last recorded holder of every mortgage of record: PENNSYLVANIA HOUSING FINANCE AGENCY 2101 N, Front Street PO BOX 8028 Harri,burg, P A 17110-8028 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: 6. Name and address of every other person of whom the plaintiff has knowledge who has any record interest in the property which may be affected by the sale, 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, TENANTS/OCCUPANTS 234 E, Old York Road Carlisle, P A 17013 (attach separate sheet if more space is needed) 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. GOLOB BY: Joseph Attorney for RTY & McKEEVER , Jr" Esq, DATED: January 8,2004 02-5573 CIVIL TERM GOLDBECK McCAFFERTY & McKEEVER BY: Joseph A, Goldbeck, Jr. Attorney I.D,#16132 Suite 5000- Mellon Independence Center 701 Market Street Philadelphia, PA 19106 215-627-1322 Attorney for Plaintiff CITIFINANCIAL MORTGAGE CO, INe. FIKJA FORD CDC 1111 Northpoint Drive Building 4, Suite 100 Coppell, TX 75019-3931 IN THE COURT OF COMMON PLEAS of Cumberland County Plaintiff CIVIL ACTION - LAW vs, SUSAN K. PALUMBO SAMUEL R. PALUMBO Mortgagor(s) and Record Owner(s) ACTION OF MORTGAGE FORECLOSURE 234 E, Old York Road Carlisle, P A 17013 Term No, 02-5573 CIVIL TERM Defendant( s) THIS LAW FIRM IS A DEBT COLLECTOR AND WE ARE ATTEMPTING TO COLLECT A DEBT. THIS NOTICE IS SENT TO YOU IN AN ATTEMPT TO COLLECT A DEBT. ANY INFORMATION OBTAINED FROM YOU WILL BE USED FOR THAT PURPOSE. NOTICE OF SHERIFF'S SALE OF REAL PROPERTY TO: PALUMBO, SUSAN K, SUSAN K. PALUMBO 113 Whiskey Springs Road Dillsburg, P A 17019 Your house at 234 E. Old York Road, Carlisle, PA 17013 is scheduled to be sold at Sheriff's Sale on Wednesday, June 09, 2004, at 10:00 AM, in Commissioners Hearing Rm 2nd FL Courthouse to enforce the courtjudgrnent of$97,734,08 obtained by CITIFINANCIAL MORTGAGE CO. INe. FIKIA FORD CDC against you. NOTICE OF OWNER'S RIGHTS YOU MAYBE ABLE TO PREVENT THIS SHERIFF'S SALE To prevent this Sheriff's Sale you must take immediate action: I. The sale will be cancelled if you pay to CITIFINANCIAL MORTGAGE CO, INe. FIKIA FORD cnc, the back payments, late charges, costs and reasonable attorney's fees due, To fmd out how much you must pay call: 215-627-1322 02-5573 CIVIL TERM 2, You may be able to stop the sale by filing a petition asking the Court to strike or open 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, Yau may need an attorney to assert your rights. The sooner you contact one, the more chance you will have of stopping the sale, (See notice below on how to obtain an attorney), YOU MAY STILL BE ABLE TO SAVE YOUR PROPERTY AND YOU HAVE OTHER RIGHTS EVEN IF THE SHERIFF'S SALE DOES NOT TAKE PLACE. I, If the Sheriffs Sale is not stopped, your property will be sold to the highest bidder. You may fmd out the price bid price by calling the Sheriff of717-240-6390, 2, You may be able to petition the Court to set aside the sale if the bid price was grossly inadequate compared to the value of your property, 3. The sale will go through only if the buyer pays the Sheriff the full amount due in the sale, To fmd out if this has happened, you may call the Sheriffof717-240-6390, 4, If the amount due from the Buyer is not paid to the Sheriff, you will remain the owner of the property as if the sale D<'ver 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 house, A schedule of distribution of the money bid for your house will be filed by the Sheriff thirty (30) days from the date of the Sheriffs Sale. This schedule will state who will be receiving that money, The money will be paid out in accordance with this schedule unless exceptions (reasons why the proposed distribution is wrong) are filed with the Sheriff within ten (10) days after the schedule of distribution is filed. 7, You may also have other rights and defenses, or ways of getting your house back, if you act immediately after the sale, YOU SHOULD TAKE THIS PAPER TO YOUR LAWYER AT ONCE, IF YOU DO NOT HAVE A LAWYER OR CANNOT AFFORD ONE, GO TO OR TELEPHONE TIlE OFFICE LISTED BELOW TO FIND OUT WHERE YOU CAN GET LEGAL HELP. LEGAL SERVICES INC 8 Irvine Row Carlisle, PA 17013 CUMBERLAND COUNTY BAR ASSOCIA nON 2 Liberty Avenue Carlisle, PA 17013 02-5573 CIVIL TERM GOLDBECK McCAFFERTY & McKEEVER BY; Joseph A. Goldbeck, Jr. Attorney I.D,#16132 Suite 5000- Mellon Independence Center 701 Market Street Philadelphia, P A 19106 215-627-1322 Attorney for Plaintiff CITIFINANCIAL MORTGAGE CO. INe. FIKIA FORD CDC 1111 Northpoint Drive Building 4, Suite 100 CoppelJ, TX 75019-3931 IN THE COURT OF COMMON PLEAS of Cumberland County Plaintiff CIVIL ACTION - LAW vs. SUSAN K. PALUMBO SAMUEL R, PALUMBO Mortgagor(s) and Record Owner(s) ACTION OF MORTGAGE FORECLOSURE 234 E, Old York Road Carlisle, P A 17013 Term No, 02-5573 CIVIL TERM Defendant(s) THIS LAW FIRM IS A DEBT COLLECTOR AND WE ARE ATTEMPTING TO COLLECT A DEBT. THIS NOTICE IS SENT TO YOU IN AN ATTEMPT TO COLLECT A DEBT. ANY INFORMATION OBTAINED FROM YOU WILL BE USED FOR THAT PURPOSE. NOTICE OF SHERIFF'S SALE OF REAL PROPERTY TO: PALUMBO, SAMUEL R, SAMUEL R. PALUMBO 113 Whiskey Springs Road Dillsburg,PA 17019 Your house at 234 E. Old York Road, Carlisle, PA 17013 is scheduled to be sold at Sheriff's Sale on Wednesday, June 09, 2004, at 10:00 AM, in Commissioners Hearing Rm 2nd FL Courthouse to enforce the court judgment of $97,734.08 obtained by CITIFINANCIAL MORTGAGE CO. INC. FIKI A FORD CDC against you, NOTICE OF OWNER'S RIGHTS YOU MAY BE ABLE TO PREVENT THIS SHERIFF'S SALE To prevent this Sheriffs Sale you must take immediate action: I, The sale will be cancelled if you pay to CITIFINANCIAL MORTGAGE CO, INe. FIKIA FORD CDC, the back payments, late charges, costs and reasonable attorney's fees due. To fmd out how much you must pay call: 215-627-1322 02-5573 CIVIL TERM 2, You may be able to stop the sale by filing a petition asking the Court to strike or open 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 througb other legal proceedings, You may need an attorney to assert your rights. The sooner you contact one, the more chance you will have of stopping the sale, (See notice below on how to obtain an attorney), YOU MAY STILL BE ABLE TO SAVE YOUR PROPERTY AND YOU HAVE OTHER RIGHTS EVEN IF THE SHERIFF'S SALE DOES NOT TAKE PLACE. I, If the Sheriffs Sale is not stopped, your property will be sold to the highest bidder. You may find out the price bid price by calling the Sheriff 0017-240-6390, 2, You may be able to petition the Court to set aside the sale if the bid price was grossly inadequate compared to the value of your property, 3, The sale will go through only if the buyer pays the Sheriff the full amount due in the sale, To fmd out if this has happened, you may call the Sheriffof7l7-240-6390, 4, If the amount due from the Buyer is not paid to the Sheriff, you will remain the owner of the property as if the sale never happened, 5, You have 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 house, A schedule of distribution of the money bid for your house will be filed by the Sheriff thirty (30) days from the date of the Sheriffs Sale, This schedule will state who will be receiving that money, The money will be paid out in accordance with this schedule unless exceptions (reasons why the proposed distribution is wrong) are filed with the Sheriff within ten (10) days after the schedule of distribution is filed. 7, You may also have other rights and defenses, or ways of getting your house back, if you act inunediately 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, LEGAL SERVICES INC 8 Irvine Row Carlisle, PA 17013 CUMBERLAND COUNTY BAR ASSOCIA nON 2 Liberty Avenue Carlisle, PA 17013 WRIT OF EXECUTION andlor ATTACHMENT COMMONWEALTH OF PENNSYLVANIA) COUNTY OF CUMBERLAND) NO 02-5573 Civil CIVIL ACTION - LAW TO THE SHERIFF OF CUMBERLAND COUNTY: To satisfy the debt, interest and costs due CITIFINANCIAL MORTGAGE CO., INC. tlkla FORD CDC Plaintiff(s) From SUSAN K. AND SAMUEL R PALUMBO, 113 WHISKEY SPRING ROAD, DlLLSBURG PA 17019. (1) You are directed to levy upon the property of the defendant (s)and to sell REAL ESTATE LOCATED AT 234 E. OLD YORK ROAD, CARLISLE P A 17013 (SEE ELGAL 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) Ifproperty of the defendant(s) not levied upon an subject to attachment is found in the possession of anyone other than a named garnishee, you are directed to notify himlher that helshe has been added as a garnishee and is enjoined as above stated, Amount Due $97,734.08 Interest 5/4/02 TO 2/10/03 @ 10.6500% Ally's Comm % Ally Paid $787.43 Plaintiff Paid L.L. Due Prothy 1.00 Other Costs Date: JANUARY 12,2004 (Seal) CURTIS R. LONG prothJ, otary;J~~ By:.' ~ " I . ~. / \ Deputy REQUESTING PARTY: Name JOSEPH A. GOLDBECK, JR., ESQ. Address: SUITE 5000-MELLON INDEPENDENCE CENTER 701 MARKET ST., PHILADELPHIA PA 19106-1532 Attorney for: PLAINTIFF Telephone: (215) 627-1322 Supreme Court ID No, 16132 Real Estate Sale #35 On March 02, 2004 the sheriff levied upon the defendant's interest in the real property situated in South Middleton Township, Cumberland County, P A Known and numbered as 243 E. Old York Road, Carlisle, more fully described on Exhibit "A" filed with this writ and by this reference incorporated herein. Date: March 02, 2004 By:)cCl '/)vvu-tL1 Real Estate Deputy ~ ~ ~ ;,,,-' .:i j i~! . PROOF OF PUBLICATION OF NOTICE IN CUMBERLAND LAW JOURNAL (Under Act No. 587, approved May 16, 1929), P. L.1784 STATE OF PENNSYLVANIA : ss. COUNTY OF CUMBERLAND : 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, V1Z: APRIL 16,23,30,2004 Affiant further deposes that he is authorized to verify this statement by the Cumberland Law Journal, a legal periodical of general circulation, and that he is not interested in the subject matter of the aforesaid notice or advertisement, and that all allegations in the foregoing statements as to time, place and character of publication are true. REAL ESTATE SALE NO. 35 WIlt No, 2002-5573 ClvlJ '~M)~J~~ SWORN TO AND SUBSCRIBED before me this 30 day of APRIL 2004 Cltifinancial Mortgage Co.. Inc., f/k/ a Ford CDC vs, Susan K. Palumbo and Samuel R Palumbo Atty,: Joseph Goldbeck SHORT DESCRlPTION ALL TIiAT CERTAIN tract ofland with the improvements thereon erect~ ed. situate in South Middleton Town~ ship. Cumberland County, Pennsyl~ vania. bounded and described as fonows: BEGINNING at a spike in the center of the York Road, at the East~ em line of land of Coyle Lumber Company, Inc.: thence in an East- erly dlrectlon along the center lIne of the York Road, 124 feet 4 inches to a point in said center line: thence in a Southerly direction along land now or formerly of W. Harold Cline, liiQ feet to a Doint at the Tail Race: ~J~)}>._J~ ~Aj!ML SEAL rf LOIS E. SNYDER, Notary Public Carlisle 8oro, Cumberland County My Commission Expires March 5, 2005 VUH l'1/U. ~Vu~-n::)f.3 CIVIl , Cidftnancial Mortgage Co., Inc., f/k/a Ford CDC vs, Susan K. Palumbo and Samuel R Palumbo Atty.: Joseph Goldbeck SHORT DESCRIPTION ALL THAT CERTAIN tract of land with the improvements thereon erect- ed, situate in South Middleton Town- ship, Cumberland County, Pennsyl~ vania, bounded and described as fonows: BEGINNING at a spike in the center of the York Road, at the East~ em line of land of Coyle Lumber Company, Inc.: thence in an East- erly direction along the center line of the York Road, 124 feet 4 inches to a point 1n said center line: thence in a Southerly direction along land now or formerly of W. Harold Cline, 166 feet to a point at the Tail Race: thence in a Westerly direction along said Tail Race 135 feet to a point on the Eastern line of Coyle Lumber Company, Inc.: thence in a North- erly direction along the Eastern line of said land, 145 feet to the Place of BEGINNING, BEING improved with a frame bungalow and outbuildings. IMPROVEMENTS consist of a residential dwelllng. BEING PREMISES: 234 E, Old York Road, Carlisle, PA 17013, SOLD as the property of Susan K. Palumbo and Samuel R. Palumbo. TAX PARCEL #40-li-0288-009, rft SWORN n 30 ~~~ - LOI CaM My Co - 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 Michael Morrow, 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~ Sunday Palriot-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 27th day(s) of April and the 4th and 11th day(s) of May 2004. 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 Cou ty of D phin in Miscellaneous Book "M", Volume 14, Page 317, PUBLICATION COPY SALE #35 Statement of Advertising Costs To THE PATRIOT-NEWS CO., Dr, ~J;;~fI!o!._h.II11'" For publishing the notice or publication attached 'I. '" \~t'U,,! c...... hereto on the above stated dates 'i. ~I'l.t ... ~ Total $ 232,51 · .mlGN.U.'W::'-ot- ~ ,. ,JI lIJe Publisher's Receipt for Advertising Cost ., ,.,_ ,{ IU;400lo' ','&" ." ... . lit . ":-"~'1ii:~ Y''''':; ;0" publisher of The Patriot-News and The Sunday Patriot-News, newspapers of general CUMBERLAND COUNTY SHERIFFS OFFICE CUMBERLAND COUNTY COURTHOUSE CARLISLE, PA. 17013 By"""""..".,..,.,.".,.,..,.",.,.."""""",...""",..,.,. . GOLDBECK McCAFFERTY & McKEEVER BY: Joseph A. Goldbeck, Jr. Attorney l.D,#16132 Suite 5000 - Mellon Independence Center 701 Market Streel Philadelphia, PA 19106-1532 215-627-1322 Attome for Plaintiff CITIFINANCIAL MORTGAGE CO, INC. F/K/A FORD CDC 1111 Northpoint Drive Building 4, Suite 100 Coppell, TX 75019-3931 ACD-1599 03/02/2005 $97,734,08 IN THE COURT OF COMMON PLEAS of Cumberland County CIVIL ACTION - LAW Plaintiff vs, ACTION OF MORTGAGE FORECLOSURE SUSAN K. PALUMBO SAMUEL R, PALUMBO Mortgagor(s) and Record Owner(s) Term No, 02-5573 CIVIL TERM 234 E, Old York Road Carlisle, P A 17013 Defendant( s) CERTIFICATE OF SERVICE PURSUANT TO Pa.R.c.P. 3129.2 (c) (2) Joseph A, Goldbeck, Jr" Esquire, Attorney for Plaintiff, her~:by certifies that service on the Defendants of the Notice of Sheriff Sale was made by: ~ ( ) ( ) Personal Service by the Sheriffs Office/.: r~'~~. ", (copy of return attached), Certified mail by Joseph A, Goldbeck, Jr. (original green Postal return receipt attached), Certified mail by Sheriffs Office, Ordinary mail by Joseph A, Goldbeck, Jr., Esquire to Attorney for Defendant(s) of record (proof of mailing attached). Acknowledgment of Sheriffs Sale by Attorney for Defendant( s) (proof of acknowledgment attached), ( ) Ordinary mail by Sheriffs Office to Attorney for Defendiant(s) of record. IF SERVICE WAS ACCOMPLISHED BY COURT ORDER. ( ) Premises was posted by Sheriffs Office/competent adult (copy of return attached), ( ) Certified Mail & ordinary mail by Sheriffs Office (copy of return attached), ( ) Certified Mail & ordinary mail by Joseph A, Goldbeck, Jr. (original receipt(s) for Certified Mail attached), ( ) Pursuant to the Affidavit under Rule 3129 (copy attached), service on all lienholders (if any) has been made by ordinary mail by Joseph A, Goldbeck, Jr., Esquire (copies of proofs of mailing attached), 7160 3901 9&4& 64&4 0907 TO: PALuMBO, SAMUEL R, SAMUEL R. PALUMBO 113 Whiskey Springs Road Dillsburg, PA 17019 SENDER: GOLDBECK MCCAFFERTY & MCKEEVER November 27,2004 REFERENCE: PALUMBO, SUSAN K./ ACD-1599 03/02/05 - Cumberland PS Fo 3800 J 2000 rm une RETURN Postage RECEIPT Certified Fee SERVICE Return Receipt Fee Restricted Delivery Total Postage & Fees US Poslal Service POSTMARK OR DATE \ Receipt for Certified Mail No Insurance Coverage Provided 00 Not Use for International Mail ..............-----...........--...---------.. ....._________n__........________........._........ AFFIX POSTAGE TO MAIL PIECE TO COVER FIRST CLASS POSTAGE, CERTIFIED FEE, RETURN RECEIPT FEE AND CHARGES FOR ANY SELECTED OPTIONAL SERVICES, 1 Detadl the form 3811, Domestic return receipt by tear- ing left to ri~lh( across perf Attach to mailpiece by peeling back the adhesive strips and affixing to front of mailpiece if space permits Otherwise affix to back of mailpiece 2. If you do nol Wiln! the receipt postmarked, stick the article # Iilbellu tile null! of the mlUl1l dddress, date receipt and retJin the receipt 3 If yuu w,1nllhis receipt postmarked, slip the 38UO receipt between the wlurn receipt, and the mailpiece, and slide the edGe of the wceipt to the (}ummed ed[Jl.': of adhesive, This will hold the receipt in place to present to your mililccnter, or post office service window. (SEE IllUSTRATION) .,.11.. ,.. I..,".',".".".' 0,"'0.000 t"" "'""" ~."",,,M.,,.,, ;,~': :~:::' ;;~'~,~:":,r~:", ". ""'"o',CO.""",,, - YOUIl'lrm_ '23_-"1_ ClI't.llIIIt lZM1 .,,,,,,d, o -~- IL.,IJ"I""",,,"'~., DovldO,Do. l09aISe9mu,U.,kotln9Uono9", Wolz Penal S.I"t1c~o, Inc. H5H9o"'h Miulon Rd,Suj'.110 Follb,cQk,CA9202B.4112 4 Enter fees for the ~elVlces leqwskd in the uppropriate spaces on the front of this receipt 5 Silve tillS receipt (Jlld present it It you make an Inquiry 1160 3901 964& 64&4 0&91 TO: PALUMBO, SUSAN K. SUSAN K. PALUMBO 113 Whiskey Springs Road Dillsburg, PA 17019 SENDER: GOLDBECK. MCCAFFERTY & MCKEEVER November 27,2004 REFERENCE: PALUMBO, SUSAN K./ ACD-1599 03/02/05 - Cumberland PS Form 3800 June 2000 RETURN Postage RECEIPT Certified Fee SERVICE Return Receipt Fee Restricted Delivery Total Postage & Fees " US Postal Service POSTMARK OR O)l;fE Receipt for Certified Mail No Insurance Coverage Provided Do Not Use for International Mail ,...........................----------.--...... ---------------------------.-.........-------.------ AFFIX POSTAGE TO MAIL PIECE TO COVER FIRST CLASS POSTAGE, CERTIFIED FEE, RETURN RECEIPT FEE AND CHARGES FOR ANY SELECTED OPTIONAL SERVICES, 1 Detach the form 3811, Domestic rflturn receipt by teen- inlJ left to ri~lht deross pert Attach to mailpiece by peeling b[lck the adhesive strips and affixing to Ironl of mailpicce if space permits. Otherwise affix to back of m3i1piece 2 If you do not Wcln! the receipt postmarked, stick the article # label to the right of the rallllll ,1ddrc~;s, dale receipt and rcttJill the receipt 3 If you will11lhis receipt postmarked. slip the 3800 receipt between the relurn receipt, and the mailpiece, and slide the edge of the receipt to the gummed edge of adhesive This will hold the receipt in place to present to your mailcenter. or post office service wlIldow. (SEE IllUSTRATION) (Fonn 3BOO) ftII .Ul'U 711 1."I..,I"II'.,.","'.l "..;'0.'0' ~'.~: I .~'. ~:.:; I ;,~:~:t.' ~~, u,,'." ~::~,~~~'.'"~'~;::,",~,:';" ". v....F1..._ ,11:I__.,,_ C;eJ."'D16 .111 o ____....--.....m "",,,..",,,....-1 OovldO.Ooa Logol 80gmo"' "'of~o'ing "'.nog.' Wa..Pco,aISOlullono, 1"0. 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I~ 1 I 1--1 i . 1-- --1- --I -- I .' t-- ---l -1-1 ~ - I' ,- I ~d1~Q16~)> I ~ l!if~ iJ"H~~ rn s.~ g: II) ~ c: (f) ;:0'" 5~f\l~ar .~: gQ,313 CD::l ~ ~ m"O J~;;r,-gQ. ~5' if 'ilil ij'" ii :::;;)> :~~ Ilil 1;i~I. ,ffi ~ " ,:::;;ffi """ o~ ,,~ ~ ~o ffio I:~I ffiI ~" im 0 ,"';:0 Iffi"! Citifinancial Mortgage Co, Inc. f/kla Ford CDC VS Susan K. Palumbo and Samuel R. Palumbo The Court of Common Pleas of Cumberland County, Pennsylvania Writ No. 2002-5573 Civil Term R. Thomas Kline, Sheriff, who being duly swom according to law, states that he made a diligent search and inquiry for the within named defendant, to wit: Samuel R, Palumbo, but was unable to locate him in his bailiwick. He therefore deputized the Sheriff of York County, Pennsylvania, to serve the within Real Estate Writ, Notice of Sale and Description according to law. York County Retum: And Now: December 27, 2004 at 2:00 pm served the within Real Estate Writ, Notice & Description upon Samuei It Palumbo by personally handing to Samuel Palumbo, one true attested copy of the original Real Estate Writ, Notice & Description and making known to him the contents thereof at 113 Whiskey Springs Road, Dillsburg, PA 17019. So Answers: William Hose, Sheriff, Robert Bitner, Deputy Sheriff, who being duly sworn according to law, states that on January 24, 2005 at 4:20 o'clock PM, he served a true copy ofthe within Real Estate Writ, Notice of Sheriffs Sale and Description, in the above entitled action, upon the within named defendant, to wit: Susan K. Palumbo, by making known unto Susan Palumbo personally, at 234 East Old York Road, Carlisle, C\unberland County, Pennsylvania, its contents and at the same time handing to h,:r personally the said true and correct copy of the same. Kurt Haag, Deputy Sheriff, who being duly swom according to law, states that on January 03, 2005 at 1:51 o'clock P.M., he posted a true copy of the within Real Estate Writ, Notice, Poster and Description, in the above entitled action, upon the property of Susan K. Palumbo and Samuel It Palumbo, located at 234 East Old York Road, Carlisle, 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: Samuel It Palumbo, by regular mail to his last known address of 113 Whiskey Springs Road, Dillsburg, P A 17019, This letter was mailed under the date of January 19,2005 and never returned to the Sheriffs Office. R, Thomas Kline, Sheriff, who being duly sworn according to law, states he served the above Real Estate Writ, Notice, Poster and Description in the following manner: The Sheriff mailed a notice of the pendency of the action to the within named defendant, to wit: Susan K. Palumbo, by regular mail to her last known address of234 East Old York Road, Carlisle, P A 17013. This letter was mailed under the date of January 25, 2005 and never returned to the Sheriffs Office. Swom and subscribed to before me This _ day of So Answers: /~ ;?'~~ ?f---~ R. Thomas Kline, Sheriff 2005, A.D.8 Prothonotary B~ JIJ~ (Jf~ GOLDBECK McCAFFERTY & McKEEVER BY: Joseph A, Goldbeck, Jr. Attorney I.D,#16132 Suite 5000 - Mellon Independence Center 701 Market Street Philadelphia, PA 19106-1532 215-627-1322 Attorney for Plaintiff CITIFINANCIAL MORTGAGE CO, INe. F/KIA FORD CDC 1111 Northpoint Drive Building 4, Suite 100 Coppell, TX 75019-3931 IN THE COURT OF COMMON PLEAS of Cwnberland County Plaintiff CIVIL ACTION - LAW vs, ACTION OF MORTGAGE FORECLOSURE SUSAN K, PALUMBO SAMUEL R. PALUMBO Mortgagor(s) and Record Owner(s) Term No. 02-5573 CIVIL TERM 234 E, Old York Road Carlisle, PA 17013 Defendant(s) SUPPLEMENTAL AFFIDAVIT PURSUANT TO RULE 3129 CITIFINANCIAL MORTGAGE CO, me. F/KJA FORD CDC, Plaintiff in the above action, by its attorney, Joseph A, Goldbeck, Jr., Esquire, sets forth as of the date the praecipe for the writ of execution was filed the following information concerning the real property located at: 234 E. Old York Road Carlisle, PA 17013 I ,Name and address of Owner(s) or Reputed Owner(s): SUSAN K. PALUMBO 113 Whiskey Springs Road Dillsburg, PA 17019 SAMUEL R. PALUMBO 113 Whiskey Springs Road Dillsburg, P A 17019 2, Name and address ofDefendant(s) in the judgment: SUSAN K, PALUMBO 113 Whiskey Springs Road Dillsburg, PA 17019 SAMUEL R, PALUMBO 113 Whiskey Springs Road Dillsburg, PA 17019 3, Name and last known address of every judgment creditor whose judgment is a record lien on the property to be sold: CUMBERLAND COUNTY ADULT PROBATION Cumberland County Courthouse I Courthouse Square, 3rd Floor Carlisle, PA 17013 P A DEPARTMENT OF PUBLIC WELFARE - Bureau of Child Support Enforcement Health and Welfare Bldg, - Room 432 P,O, Box 2675 Harrisburg, PA 17105.2675 DOMESTIC RELATIONS OF CUMBERLAND COUNTY PO Box 320 Carlisle, P A 17013 4, Name and address of the last recorded holder of every mortgage ofrecord: PENNSYLVANIA HOUSING FINANCE AGENCY 211 North Front Street PO BOX 15057 Harrisburg, PA 17101 PENNSYL VANIA HOUSING FINANCE AGENCY 2101 N, Front Street PO BOX 8028 Harrisburg, P A 1711 0-8028 5, Name and address of every other person who has any record interest in orrecord lien on the property and whose interest may be affected by the sale: 6, Name and address of every other person of whom the plaintiff has knowledge who has any record interest in the property which may be affected by the sale, 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, TENANTS/OCCUPANTS 234 E, Old York Road Carlisle, PA 17013 (attach separate sheet if more space is needed) I verify that the statements made in this affidavit are true and correct to the best of my personal knowledge or infonnation and belief. I understand that false statemenls herein are made subject to the penalties of 18 Pa, C.S, Section 4904 relating to unsworn falsification to authorities. DATED: February I, 2005 ~' ,~-, ,'\ ....'f~, ...'-"" " t;"'J .r-* ....'n ..'" .:~- , ' .,,""; ., ....' O. PRAECIPE FOR WRIT OF EXECUTION - (MORTGAGE FORECLOSURE) P,R.C.P 3180-3183 . Joseph A. Goldbeck, Jr, AttorneyI.D,#16132 Suite 5000 - Mellon Independence Center 70 I Market Street Philadelphia, PA 19106-1532 215-627-1322 Attorney fOT Plaintiff CITIFINANCIAL MORTGAGE CO, INC, F/KIA FORD CDC 1111 Northpoint Drive Building 4, Suite 100 Coppell, TX 75019-3931 IN THE COURT OF COMMON PLEAS of Cumberland County Plaintiff vs, CIVIL ACTION - LAW SUSAN K. PALUMBO SAMUEL R. PALUMBO Mortgagor(s) and Record Owner(s) 234 E, Old York Road Carlisle, P A 17013 ACTION OF MORTGAGE FORECLOSURE No, 02-5573 CIVIL TERM Defendant(s) PRAECIPE FOR WRIT OF EXECUTION TO THE PROTHONOTARY: Issue Writ of Execution in the above matter: Amount Due $97,734,08 Interest from 05/04/2002 to 02/1 012003 at 10.6500% (Costs to be added) FERTY & McKEEVER ~ ~ N ~ f s 'P. ::..J.-- \A ~ ~~ 9-J V1 ~ ~~ -4:\ -lA - \) () o :E ~&1. -fI.\. 6 "(A~..CI~~ ~~(f~-;; . " . T" 'w '\t\)\;~"O.z:::J::..o Q \) _ cv()C~..2::CrtC'.1:.0 \ \ \ \ I I \ I \ \ ~v _ ::""'::'::"::; :::u.F- ::, - ~ _::.::. - - ~r::t~ - --~:t- 'f-. --l. c? ri'1 c> I 2) c:, -------- ~ 'il ~ ...'<'> \'-' .. OJ ~ <I. ,... 70 ~ ;:; .... ~" v, ~ C!;,. G <.:> on \'-' -0 'il " ~~ ~ ~ 0 ~~ ~ ~l ~S~ ~~ gO ~-o ;;.~ ~ O~O""" <.:> ,~ ?'\'" OJ " g-tJlO"'C'i ~~ 0.... ...$ ~~ ~-d"""-'~ ci ~ "pOo O't "O~ ~;S1Z<r- ~O 0 ~~~t;. ....'0 0"" ~ ~ 'a p..." ~ 'G0 J, ~~,~~~< r: d.~ ~ S ~ ,~ 'b tu; <<.P ? c.-..~ go~ e ~~.... 0.<" ....r'0 00 {i 0 0-0; ~ 'I:t.'i-Ll~~;'= ~t. tJ:~ ;J. \ r- ~ ~% % ~~\~~ ...Q $. ~g ~ ?'\ ~o p... 00 if> ,,<" ....'" 00 ~ ;Jif>~ e: ~.1? 7<?,\ if> 0 U u 6 1 iJ, tll ~ .... ~ ~ ~ \'-' .... ~ 0 - -- ALL that certain tract of land with the improveme~ts thereon erected, situate in South Midqleton Township; Cumqerland County, Pennsylvania; bounded and described as follows: BEGINNING at: a spike in the center of the York Road, at the Eastern line of land of Coyle Lumber Company, Inc.; thence in all Easterly direction along the center line of the York Road, 124 feet 4 inches to a point in said center line: thence in a southerly direction along land now or formerly of W. Harold Cline, 166 feet to a point at the Tail Race; thence in a Westerly direction along said Tail Race 135 feet to a point on the Eastern line of Coyle Lumber company , Inc. i thence in a Northerly direction along' the Eastetn line of said land, 145 feet to the Place of BEGINNING. . BgING improved with a frame bungalow and outbUildings: SHORT DESCRIPTION IMPROVEMENTS consist of a residential dwelling. BEING PREMISES: 234 E. old York Road Carlisle, PA 17013 SOLD as the property of SUSAN K. PALUMBO and SAMUEL R. PALUMBO TAX PARCEL #40-11-0288-009 IN THE UNITED STATES BANKRUPTCY COURT FOR THE MIDDLE DISTRICT OF PENNSYLVANIA IN RE: Susan Kay Palumbo CHAPTER 7 Debtor CitiFinancial Mortgage Company, Inc., FKA Ford CDC Moving Party NO. 04-03487 MDF vs. Susan Kay Palumbo Debtor Marklan R. Slobodian Esq. 11 U.S.C. Section 362 Trustee ORDER AND NOW, this 3 ~ day of ~b.u.., 2004 at Harrisburg, upon failure of Debtor and the Trustee to file and Answer or otherwise plead, it is ORDERED AND DECREED that: The Automatic Slay of all proceedings, as provided under Section 362 of the Bankruptcy Refonn Act of 1978 (The Code) 11 U.s.C. Section 362, is modified to allow CitiFinancial Mortgage Company, Inc., FKA Ford CDC and its successor in title to proceed with the execution process through, among other remedies but not limited to Sheriffs Sale regarding the premises 234 E. Old York Road Carlisle, PA 17013 and a possessory action ifnecessary, cc: See attached service Jist :\ ~g~ B ~O . ! ~ ~ 'fv '\~ ~\SI 3 2004 FILED HARRISBURG PA NOV Clerk, U.S. Bankruptcy Court . WRIT OF EXECUTION and/or ATTACHMENT COMMONWEALTH OF PENNSYLVANIA) COUNTY OF CUMBERLAND) NO 02-5573 Civil CIVIL ACTION - LAW TO THE SHERIFF OF CUMBERLAND COUNTY: To satisfy the debt, interest and costs due CITIFINANCIAL MORTGAGE CO. me. F/K/A FORD CDC, Plaintiff (s) From SUSAN K. PALUMBO AND SAMUEL R. PALUMBO (I ) You are directed to levy upon the property of the defendant (s)and to sell SEE LEGAL DESCRIPTION (2) You are also directed 10 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 10 or for the accounl ofthe defendant (s) and from delivering any property of the defendant (s) or otherwise disposing thereof; (3) Ifproperty of the defendant(s) not levied upon an subjecl 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 ahove stated, Amount Due $97,734.08 Interest FROM 5/4/02 TO 2/10/03 AT 10.6500% L.L. Atty's Comm % Due Prothy $1.00 Other Costs Atty Paid $1480.31 Plaintiff Paid Date: DECEMBER 1, 2004 CURTIS R. LONG (Seal) ProthO~ 2 2J;u '-Jty: 0/1.0 7Z.ar-.Lcr----- Deputy REQUESTING PARTY: Name JOSEPH A. GOLDBECK, JR., ESQUIRE Address: SUITE 5000 - MELLON INDEPENDENCE CENTER 701 MARKET STREET PHILADELPHIA, PA 19106-1532 Attorney for: PLAINTIFF Telephone: 215-627-1322 Supreme Court ID No, 16132 USBC PAM - LIVE - V2.5 - Docket Report Page I of4 CREDS, CLAIMS, 341Held U.S. Bankruptcy Court Middle District of Pennsylvania (Harrisburg) Bankruptcy Petition #: 1:04-bk-03487-MDF Assigned to: Mary D France Chapter 7 Previous chapter 13 Voluntary No asset Date Filed: 06/08/2004 Date Converted: 07/06/2004 Susan Kay Palumbo 234 E Old York Road Carlisle, P A 17013 SSN: xxx-xx-6505 Debtor represented by Philip C Briganti 74 W Pomfret 5t Carlisle, PA 17013 717 -960-0005 Fax: 717-960-9940 Markian R Slobodian (Trustee) 80 I North Second Street Harrisburg, PA 17102 717232-5180 Trustee Charles J. DeHart, III (Trustee) PO Box 410 Hummelstown, P A 17036 717 566-6097 TERMINATED: 07/06/2004 Former Trustee United States Trustee PO Box 969 Harrisburg, PA 17108 (717) 221-4515 Asst. U.S. Trustee Filing Date # Docket Text 06/08/2004 I Chapter 13 Voluntary Petition missing Schedules Statements and Plan. Filing fee due in the amount of$ 194.00 Filed by Philip C Briganti on behalf of Susan Kay Palumbo, (DD) (Entered: 06/08/2004) 06/08/2004 2 Matrix filed/Creditor List Uploaded Filed by Philip C Briganti on behalf of Susan Kay Palumbo (RE: related document(s)! ). (DD) (Entered: 06/08/2004) https:! /ecf.pamb.uscourts,gov/cgi-binlDktRpt.pl?32I 627453524245-L _82_0-1 11/27/2004 USBC PAM - LIVE - V2.5 - Docket Report Page 2 of 4 06/08/2004 Tentative Date for Meeting of Creditors (Case missing matrix or plan). THIS IS SUBJECT TO CHANGE. 7/29/2004 at 09:00 AM. (DD) (Entered: 06/08/2004) 06/08/2004 Receipt of Voluntary Petition Filing Fee. Receipt Number 609670 Fee Amount $ 194.00 (RE: related document(s)l ). (DD) (Entered: 06/08/2004) 06/21/2004 3 Motion to Extend Time to file the required documents Filed by Philip C Briganti on behalf of Susan Kay Palumbo (RE: related document(s) 1) . (AG) (Entered: 06/22/2004) 06/28/2004 1: Order Granting Motion to Extend Time to file the required documents. Documents are due on/before July 7, 2004. (RE: related document(s) [3] ), (AG) (Entered: 06/28/2004) 07/06/2004 5 Praecipe to Convert (Absolute Right) from Chapter 13 to Chapter 7. Filing fee due in the amount of$ 15.00 Filed by Philip C Briganti on behalf of Susan Kay Palumbo (RE: related document(s)1 ). (SP) (Entered: 07/06/2004) 07/06/2004 Receipt of Conversion Fee. Receipt Number 610624 Fee Amount $ 15,00 (RE: related document(s)[5]). (SP) (Entered: 07/06/2004) 07/06/2004 Trustee Markian R Slobodian (Trustee) added to case.. (There is no image or paper document associated with this entry.) Filed by U.S. Trustee. (united states trustee(wp),) (Entered: 07/0612004) 07/06/2004 6 Amended Matrix filed/Creditor List Uploaded Filed by Philip C Briganti on behalf of Susan Kay Palumbo (RE: related document(s) [2] ). (BR) Inserted missing text, changed relationship from I - Modified on 7/9/2004 (BW). (Entered: 07/08/2004) 07/06/2004 7 Schedules A-J , Statement of Disclosure of Compensation of Attorney for Debtor, Statement of Financial Affairs, Summary of Schedules Filed by Philip C Briganti on behalf of Susan Kay Palumbo (RE: related document(s)1). (BR) (Entered: 07/08/2004) 07/06/2004 Receipt of Amended Matrix Filing Fee, Receipt Number 610622 Fee Amount $ 26, (RE: related document(s)[6] ), (JR) (Entered: 07/08/2004) 07/07/2004 Tentative Date for Meeting of Creditors, THIS IS SUBJECT TO CHANGE, 8/13/2004 at 08:30 AM, (SM) (Entered: 07/07/2004) 07/12/2004 E Final Report Filed by Trustee. (dehart, III(ck), Charles) (Entered: 07/12/2004) https:llecf.pamb.uscourts,gov/cgi-binlDktRpt.pl?321627453524245-L 82 0-1 11/27/2004 USBC PAM - LIVE - V2,5 - Docket Report Page 3 of 4 07/22/2004 2. Request to BNC - Meeting of Creditors . 341(a) meeting to be held on 8/13/2004 at 11 :00 AM Federal Bldg, Trustee Hearing Rm, Rm 1160, 11th FI, 228 Walnut St, Harrisburg, PA Last day to oppose discharge or dischargeabili ty is I 0/12/2004 (DB) (Entered: 07/22/2004) 07/24/2004 1Q BNC Certificate of Mailing, Service Date 07/24/2004. (Related Doc # 2) (Admin.) (Entered: 07/25/2004) 08/17/2004 U Request to BNC - Meeting of Creditors Rescheduled. 341(a) meeting to be held on 9/15/2004 at 10:30 AM at Federal Bldg, Trustee Hearing Rm, Rm 1160, 11th FI, 228 Walnut St, Harrisburg, P A. (DB) (Entered: 08/17/2004) 08/19/2004 12 Certification that 341 Meeting of Creditors (Ch, 7) Not Held on 08/13/04. To be Rescheduled. (There is no image or paper document associated with this entry.), (slobodian(jh), Markian) (Entered: 08/19/2004) 08/19/2004 13 BNC Certificate of Mailing, (RE: related document(s)ll), Service Date 08/19/2004, (Admin.) (Entered: 08/20/2004) 09/17/2004 14 Certification that 341 Meeting of Creditors Held (Ch. 7) on 11115/04, Trustee's Report of No Distribution: Trustee requests discharge and certifies under FRBP 5009: the estate has been fully administered; I have neither received nor distributed any non-exempt property; ! have diligently inquired about the debtor(s) financial affairs and location of estate property. The estate has no non-exempt property to distribute, (There is no image or paper document associated with this entry,). (slobodian(jh), Markian) (Entered: 09/17/2004) 09/22/2004 15 Corrective Entry Incorrect Meeting Date, Meeting date should be 9/15/04, (slobodian(jh), Markian) (Entered: 09/22/2004) 10/07/2004 16 Motion for Relief from Stay. Filing fee due in the amount of$ 150.00 Filed by Leslie E Puida of Goldbeck McCafferty and McKeever on behalf of CitiFinancial Mortgage Company, !nc" et a1.... (Attachments: # 1 Proposed Order) (Puida, Leslie) (Entered: 10/07/2004) 10/08/2004 Receipt of Motion for Relief From Stay(1 :04-bk-03487-MDF) [motion,mrlfsty] ( 150,00) filing fee. Receipt number 614063, amount $ 150.00, (Parker) (Entered: 10/0812004) 10/08/2004 17 Order (RE: related document(s)16 ), Answers are due on: 10/23/2004, Hearing scheduled for 11/3/2004 at 09:00 AM at 3rd & Walnut Streets, Bankruptcy Courtroom (3rd Floor), Federal Building, Harrisburg, PA. (CA) (Entered: 10/0812004) https:llecf.pamb.uscourts,govlcgi-bin/DktRpt.pl?321627 453 524245- L _ 82 _0-1 11/27/2004 USBC PAM - LIVE - V2.5 - Docket Report Page 4 of 4 10/11/2004 18. Certificate of Service Filed by Leslie E Puida of Goldbeck McCafferty and McKeever on behalf of CitiFinancial Mortgage Company, Inc., et al... (RE: related document(s) I 6, 11). (Puida, Leslie) (Entered: 10/11/2004) 11/03/2004 19 Order Granting Motion for Relief from Stay (RE: related document( s) lQ). (CA) (Entered: 11/03/2004) PACER Login: PACER Service Center Transaction Receipt 11/27/200411:44:31 ~a0060 I Client Code: 1 :04-bk-03487-MDF Fil or Ent: Docket Search Fil Doc From: 0 Doc To: Description: Report Criteria: 99999999 Term: y Links: n Format: HTMLfmt DEJI014 Billable Pages: https:/ /ecf.pamb.uscourts.gov/cgi-bin/DktRpt.pl?321627453524245-L 82_0-1 11/27/2004 Goldbeck McCafferty & McKeever BY:.Joseph A. Goldbeck, Jr. . Attorney LD, #16132 Suite 5000 - Mellon Independence Center 701 Market Street Philadelphia, PA 19106-1532 215-627-1322 Attorney for Plaintiff CITlFINANCIAL MORTGAGE CO, INC. FIK/A FORD CDC 1111 Northpoint Drive Building 4, Suite 100 Coppell, TX 75019-3931 IN THE COURT OF COMMON PLEAS of Cumberland County Plaintiff vs, CIVIL ACTION - LAW SUSAN K, PALUMBO SAMUEL R, PALUMBO (Mortgagor(s) and Record Owner(s)) 234 E, Old York Road Carlisle, P A 17013 ACTION OF MORTGAGE FORECLOSURE Defendant(s) No, 02-5573 CIVIL TERM AFFIDAVIT PURSUANT TO RULE 3129 CITIFINANCIAL MORTGAGE CO, INe. FIKIA FORD CDC, Plaintiff in the above action, by its attorney, Joseph A Goldbeck, Jr., Esquire, sets forth as of the date the praecipe for the wril of execution was filed the following information concerning the real property located at: 234 E, Old York Road Carlisle, P A 17013 l.Name and address ofOwner(s) or Reputed Owner(s): SUSAN K, PALUMBO 113 Whiskey Springs Road Dillsburg, P A 17019 SAMUEL R, PALUMBO 113 Whiskey Springs Road Dillsburg, PA 17019 2, Name and address of Defendant(s) in the judgment: SUSANK, PALUMBO 113 Whiskey Springs Road Dillsburg, PA 17019 SAMUEL R, PALUMBO 113 Whiskey Springs Road Dillsburg, P A 17019 3, Name and last known address of every judgment creditor whose judgment is a record lien on the property to be sold: CUMBERLAND COUNTY ADULT PROBATION Cumberland County Courthouse . 1 Courthouse Square, 3rd Floor Carlisle, P A 17013 . PA DEPARTMENT OF PUBLIC WELFARE - Bureau of Child Support Enforcement Health and Welfare Bldg, - Room 432 P,O, Box 2675 Harrisburg, PA 17105-2675 DOMESTIC RELATIONS OF CUMBERLAND COUNTY PO Box 320 Carlisle, P A 17013 4, Name and address of the last recorded holder of every mortgage of record: PENNSYLVANIA HOUSING FINANCE AGENCY 2101 N, Front Street PO BOX 8028 Harrisburg, P A 17110-8028 5, Name and address of every other person who has any record interest in or record lien on the property and whose interesl may he affected by the sale: 6, Name and address of every other person of whom the plainriff has knowledge who bas any record inlerest in the property which may be affected by the sale, 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, TENANTS/OCCUPANTS 234 E, Old York Road Carlisle, P A 17013 (attach separate sheet if more space is needed) ] 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. DATED: November 27, 2004 / GOLDBECK ERTY & McKEEVER BY: Joseph A. , d e k, Jr., Esq, Attorney for Pi 11> if ~ n ("- .-.:> ,,;::,~:) (,::;,~ ~ c~J r>\ l......) - ?":' ~J'" ~: o -- 02-5573 ClVIL TERM \ GOLDBECK McCAFFERTY & McKEEVER BY: Joseph A. Goldbeck, Jr, Attorney 1.0,#16132 Suire 5000- Mellon Independence Center 70 I Market Street Philadelphia, P A 19106 215-627-1322 Attorney for Plaintiff CITIFINANCIAL MORTGAGE CO, INC. F/KJA FORD CDC 1111 Northpoint Drive Building 4, Suite 100 Coppell, TX 75019-3931 IN THE COURT OF COMMON PLEAS of Cumberland County Plaintiff CNIL ACTION - LAW vs, SUSAN K. PALUMBO SAMUEL R, PALUMBO Mortgagor(s) and Record Owner(s) ACTION OF MORTGAGE FORECLOSURE 234 E. Old York Road Carlisle, PA 17013 Term No, 02-5573 CNIL TERM Defendant(s THIS LAW FIRM IS A DEBT COLLECTOR AND WE ARE ATTEMPTING TO COLLECT A DEBT. THIS NOTICE IS SENT TO YOU IN AN ATTEMPT TO COLLECT A DEBT. ANY INFORMATION OBTAINED FROM YOU WILL BE USED FOR THAT PURPOSE. NOTICE OF SHERIFF'S SALE OF REAL PROPERTY TO: PALUMBO. SAMUEL R. SAMUEL R. PALUMBO 113 Whiskey Springs Road Oillsburg, PA 17019 Your house at 234 E, Old York Road, Carlisle, P A 17013 is scheduled to be sold at Sheriffs Sale on Wednesday, March 02,2005, at 10:00 AM, in Commissioners Hearing Rm 2nd FL Courthouse to enforce the court judgment of $97,734.08 obtained by ClTlFlNANCIAL MORTGAGE CO, lNC, FIKJ A FORD COC against you, NOTICE OF OWNER'S RIGHTS YOU MAY BE ABLE TO PREVENT THIS SHERIFF'S SALE To prevent this Sherifl1s Sale you must take immediate action: 1. The sale will be cancelled if you pay to CITlFINANCIAL MORTGAGE CO, lNC. F/K/A FORO CDC, the back payments, late charges, costs and reasonable attorney's fees due, To find out how much you must pay call: 215-627-1322 \ 02-5573 CIVIL TERM . 2, You may be able to stop the sale by filing a petition asking the Court to strike or open judgment, if the judgment was improperly entered. You may also ask the Court to postpone the sale for good cause, 3, You may also be able to stop the sale through other legal proceedings, You may need an attorney to assert your rights, The sooner you contact one, the more chance you will have of stopping the sale, (See notice below on how to obtain an attorney), YOU MAY STILL BE ABLE TO SAVE YOUR PROPERTY AND YOU HAVE OTHER RIGHTS EVEN IF THE SHERIFF'S SALE DOES NOT TAKE PLACE. I, If the Sheriff's Sale is not stopped, your property will be sold to the highest bidder, You may find out the price bid price by calling the Sheriffof717-240-6390, 2, You may be able to petition the Court to set aside the sale if the bid price was grossly inadequate compared to the value of your property, 3, The sale will go through only if the buyer pays the Sheriff the full amount due in the sale, To fmd out iftbis bas happened, you may call the Sheriffof717-240-6390, 4, If the amount due from the Buyer is not paid to the Sheriff, you will remain the owner of the property as if the sale never happened, 5, You have a right to remain in the property until the full amount due is paid 10 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 thirty (30) days from the date of the Sheriff's Sale, This schedule will state who will be receiving that money, The money will be paid out in accordance with this schedule unless exceptions (reasons why the proposed distribution is wrong) are filed with the Sheriff within ten (!O) days after the schedule of distribution is filed, 7, You may also have other rights and defenses, or ways of getting your house back, if you act immediately after the sale, YOU SHOULD TAKE THIS PAPER TO YOUR LAWYER AT ONCE, IF YOU DO NOT HAVE A LAWYER OR CANNOT AFFORD ONE, GO TO OR TELEPHONE THE OFFICE LISTED BELOW TO FIND OUT WHERE YOU CAN GET LEGAL HELP, LEGAL SERVICES INC 8 Irvine Row Carlisle, P A 17013 CUMBERLAND COUNTY BAR ASSOClA nON 2 Liberty Avenue Carlisle, P A 17013 ...., " C,~,. ~- C) rn C) s: ~? c.'"') 02-5573 CIVIL TERM GOLDBECK McCAFFERTY & McKEEVER ,BY: Joseph A. Goldbeck, Jr, Attorney LD,#16132 Suite 5000- Mellon Independence Center 70 I Markel Street Philadelphia, P A 19106 215-627-1322 Attorney for Plaintiff CITIFINANCIAL MORTGAGE CO, INC, F/KIA FORD CDC 1111 Northpoint Drive Building 4, Suite 100 Coppell, TX 75019-3931 IN THE COURT OF COMMON PLEAS of Cumberland County Plaintiff CIVIL ACTION - LAW vs, SUSAN K. PALUMBO SAMUEL R, PALUMBO Mortgagor(s) and Record Owner(s) ACTION OF MORTGAGE FORECLOSURE 234 E, Old York Road Carlisle, PAl 70 I3 Term No. 02-5573 CIVIL TERM Defendant( s THIS LAW FIRM IS A DEBT COLLECTOR AND WE ARE ATTEMPTING TO COLLECT A DEBT. THIS NOTICE IS SENT TO YOU IN AN ATTEMPT TO COLLECT A DEBT. ANY INFORMATION OBTAINED FROM YOU WILL BE USED FOR THAT PURPOSE. NOTICE OF SHERIFF'S SALE OF REAL PROPERTY TO: PALUMBO, SUSAN K, SUSAN K. PALUMBO 113 Whiskey Springs Road Dillsburg, PA 17019 Your house at 234 E. Old York Road, Carlisle, PA 17013 is scheduled to be sold at Sheriffs Sale on Wednesday, March 02, 2005, at 10:00 AM, in Commissioners Hearing Rm 2nd FL Courthouse to enforce the court judgment of$97,734,08 obtained by CITIFINANCIAL MORTGAGE CO, INC, F/K/A FORD CDC against you, NOTICE OF OWNER'S RIGHTS YOU MAY BE ABLE TO PREVENT THIS SHERIFF'S SALE To prevent this Sheriffs Sale you must take immediate action: I, The sale will be cancelled if you pay to CITIFINANCIAL MORTGAGE CO, INC. FIKJA FORD CDC, the back payments, late charges, costs and reasonable attorney's fees due, To find out how much you must pay call: 215-627-1322 02-5573 ClVIL TERM -2, You may be able to stop the sale by filing a petition asking the Court to strike or open 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, Yau 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 helow 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 NOT TAKE PLACE. I, If the Sheriffs Sale is not stopped, your property will be sold to the highest bidder. You may find out the price bid price by calling the Sheriff of717 -240-6390, 2, You may be able to petition the Court to set aside the sale if the bid price was grossly inadequate compared to the value of your property, 3, The sale will go through only if the buyer pays the Sheriff the full amotmt due in the sale, To find out if this has happened, you may call the Sheriff of 717-240-6390, 4, If the amotmt 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 house, A schedule of distribution of the money bid for your house will be filed by the Sheriff thirty (30) days from the date of the Sheriffs Sale, This schedule will state who will he receiving that money, The money will be paid out in accordance with this schedule unless exceptions (reasons why the proposed distribution is wrong) are filed with the Sheriff within ten (10) days after the schedule of distribution is filed, 7, You may also have other rights and defenses, or ways of getting your house back, if you act immediately after the sale, YOU SHOULD TAKE THIS PAPER TO YOUR LAWYER AT ONCE, IF YOU DO NOT HAVE A LAWYER OR CANNOT AFFORD ONE, GO TO OR TELEPHONE THE OFFICE LISTED BELOW TO FIND OUT WHERE YOU CAN GET LEGAL HELP, LEGAL SERVICES INC 8 Irvine Row Carlisle, P A 17013 CUMBERLAND COUNTY BAR ASSOCIATION 2 Liberty Avenue Carlisle, P A 17013 f) ,-, C~';'J C~:'::J oL- e} P'i <.,-") , () ~'n :.;1 r-;~:!J t;9 (~) ::";:; 1-",; \\1 <;:? a COMMONWEALTH OF PENNSYLVANIA COUNTY OF CUMBERLAND }SS: 0::2 - -5-:5-73 I, Robert p, Ziegler, Recorder of Deeds in and for said County and State do hereby certi y that the Sheriff's Deed in which Citifinancial Mtg Co Inc is the grantee the same having been sold t said grantee on the 2nd day of March AD" 2005, under and by virtue of a writ Execution issued on he Ig day ofDec, AD., 2004, out of the Court of Common Pleas of said County as of Civil Term, 20 2 Number 5573, at the suit ofCitifinancial Mtg Co Inc against Susan K Palumbo & Samuel R is Iy recorded in Sheriff's Deed Book No, 268, Page 1967, IN TESTIMONY WHEREOF, I have hereunto set y hand ,~ and seal of said office this 9 day of 1l1/2;}! ,AD, tfJ()0.. Recorder fDeeds ..do, eu__ Cou ,C_, ~ ion Expires the Firat of Jan. 2001 Citifinancial Mortgage Co. rnc, f/k1a Ford CDC VS Susan K. Palumbo and Samuel R. Palumbo The Court of Common Pleas of Cumberland County, Pennsylvania Writ No, 2002-5573 Civil Term R, Thomas Kline, Sheriff, who being duly sworn according to law, states that h made a diligent search and inquiry for the within named defendant, to wit: Samuel R. Palumbo, but was unable to locate him in his bailiwick, He therefore deputized the Sheriff of York County, Peunsylvania, to serve the within Real Estate Writ, Notice of Sale and Description according to law. York County Return: And Now: December 27,2004 at 2:00 pm served the within Real Estate Writ, Notice & Description upon Samuel R. Palumbo by personally handing to Samuel Palumbo, one true attested copy of the original Real Estate Writ, Notice & Description and making known to him the contents thereof at I 13 Whiskey Springs Road, DiIIsburg, PA 17019. So Answers: William Hose, Sheriff. Robert Bitner, Deputy Sheriff, who being duly sworn according to law, states t t on January 24, 2005 at 4:20 o'clock PM, he served a true copy of the within Real Estat Writ, Notice of Sheriff's Sale and Description, in the above entitled action, upon the within named defendant, to wit: Susan K. Palumbo, by making known unto Susan Palumbo personally, at 234 East Old York Road, Carlisle, Cumberland County, Pennsylvania, its contents and at the same time handing to her personally the said true and correct copy of the same, Kurt Haag, Deputy Sheriff, who being duly sworn according to law, states that January 03, 2005 at 1 :51 o'clock P,M" he posted a true copy ofthe within Real Estate Writ, Notice, Poster and Description, in the above entitled action, upon the property of Susan K. Palumbo and Samuel R. Palumbo, located at 234 East Old York Road, Carlisi, 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: Samuel R. Palumbo, by regular mail to his last known address of 1 13 Whiskey Springs Road, DiIlsburg, PA 17019. This letter was mailed under the date of January 19, 2005 and never returned to the Sheriff's Office, R. Thomas Kline, Sheriff, who being duly sworn according to law, states he served the above Real Estate Writ, Notice, Poster and Description in the following manner: The Sheriff mailed a notice of the pendency of the action to the within named defendant, to wit: Susan K. Palumbo, by regular mail to her last known address of234 East Old York Road, Carlisle, PA 17013. This letter was mailed under the date of January 25, 2005 and never retumed to the Sheriff's Office, R. Thomas Kline, Sheriff, who being duly sworn according to law, states that after due and legal notice had been given according to law, he exposed the within described premises at public venue or outcry at the Courthouse, Carlisle, Cumberland County, Pennsylvania on March 2, 2005 at 10:00 o'clock A.M, He sold the same for the sum of $1.00 to Attorney Joseph Goldbeck for Citifinancial Mortgage Company rnc, flkl Ford CDC, It being the highest bid and best price received for the same, Citifinancial Mortgage Company rnc, flkla Ford CDC of 1 I I 1 Northpoint Drive, Building 4, Suite ~ / \ --\ \ <> il.VI " .>to Cl. \ lP) \ 100, Coppell, TX 75019-3931, being the buyer in this execution, paid to SheriffR, Thomas Kline the sum of $732.25, it being costs, Sheriffs Costs: Docketing Poundage Posting Bills Advertising Acknowledging Deed Auctioneer Law Library Prothonotary Mileage Certified Mail Levy Surcharge Out of County York County Law Journal Patriot News Share of Bills Distribution of Proceeds Sheriffs Deed $30,00 14.36 15,00 15.00 30.00 10,00 $ 1.00 3,70 1.95 15.00 30,00 9,00 44,26 218.90 198.85 30.73 25.00 39.50 732.25 So~~~: ~~,)r..~ #~ This#dayof aF,' . - t.~ R.Tho=K1ioe,Sheriff 2005, A.D. D.. .. ~ ' [. n Prothonotary BY)O ~' t~ Real Est e eputy Swom and subscribed to before me , , Goldbeck McCafferty & McKeever BY: Joseph A. Goldbeck, Ir. Attorney I,D, #16132 Suite 5000 - Mellon Independence Center 70 I Market Street Philadelphia, PA 19106-1532 215-627-1322 Attorney for Plaintiff CITIFINANCIAL MORTGAGE CO, INC, F/K/A FORD CDC 1111 Northpoint Drive Building 4, Suite 100 Coppell, TX 75019-3931 IN THE COURT OF COMMON PL AS of Cumberland County Plaintiff vs, CIVIL ACTION - LAW SUSANK. PALUMBO SAMUEL R, PALUMBO (Mortgagor(s) and Record Owner(s)) 234 E, Old York Road Carlisle, P A 17013 ACTION OF MORTGAGE FORECL URE Defendant( s) No, 02-5573 CIVIL TERM AFFIDAVIT PURSUANT TO RULE 3129 CITIFlNANCIAL MORTGAGE CO, INC. F/KJA FORD CDC, Plaintiff in the above action, by its attorne , Joseph A, Goldbeck, Jr" Esquire, sets forth as of the date the praecipe for the writ of execution was filed the following info ation concerning the real property located at: 234 E. Old York Road Carlisle, P A 17013 l.Name and address ofOwner(s) or Reputed Owner(s): SUSAN K, PALUMBO 113 Whiskey Springs Road Dillsburg, P A 17019 SAMUEL R, PALUMBO 113 Whiskey Springs Road Dillsburg, PA 17019 2, Name and address ofDefendant(s) in the judgment: SUSAN K, PALUMBO 113 Whiskey Springs Road Dillsburg, P A 17019 SAMUEL R, PALUMBO I 13 Whiskey Springs Road Dillsburg, P A 17019 3, Name and last known address of every judgment creditor whose judgment is a record lien on the property to be old: CUMBERLAND COUNTY ADULT PROBATION Cumberland County Courthouse I 1 Courthouse Square, 3rd Floor Carlisle, PA 17013 P A DEP ARTMENT OF PUBLIC WELFARE - Bureau of Child Support Enforcement Health and Welfare Bldg, - Room 432 P,O, Box 2675 Harrisburg, PA 171 05-2675 DOMESTIC RELATIONS OF CUMBERLAND COUNTY PO Box 320 Carlisle, P A 170 I3 4, Name and address of the last recorded holder of every mortgage of record: PENNSYLVANIA HOUSING FINANCE AGENCY 2101 N, Front Street PO BOX 8028 Harrisburg, P A 1711 0-8028 5. Name and address of every other person who has any record interest in or record lien on the property and whose i terest may be affected by the sale: 6, Name and address of every other person of whom the plaintiff has knowledge who has any record interest in the operty which may be affected by the sale, 7, Name and address of every other person of whom the plaintiff has knowledge who has any interest in the proper! which may be affected by the sale, TENANTS/OCCUPANTS 234 E. Old York Road Carlisle, PA 17013 (attach separate sheet ifmore space is needed) I verify that the statements made in this affidavit are true and correct to the best of my personal knowledg or infonnation and belief I understand that false statements herein are made subject to the penalties of 18 Pa, C.S, Se tion 4904 relating to unsworn falsification to authorities. GOLDBECK BY: Joseph A, Attorney for PI 1 DATED: November 27, 2004 02-5573 CIVIL TE M GOLDBECK McCAFFERTY & McKEEVER BY: Joseph A. Goldbeck, Jr. AttomeyI.D,#16132 Suite 5000- Mellon Independence Center 70 I Market Street Philadelphia, PA 19106 215-627 -1322 Attorney for Plaintiff CITIFINANCIAL MORTGAGE CO, INC. FIKJA FORD CDC 1111 Northpoint Drive Building 4, Suite 100 Coppell, IX 75019-3931 IN THE COURT OF COMMON PLEA of Cumberland County Plaintiff CIVIL ACTION - LAW vs, SUSAN K, PALUMBO SAMUEL R. PALUMBO Mortgagor(s) and Record Owner(s) ACTION OF MORTGAGE FORECLOSURE 234 E. Old York Road Carlisle, P A 17013 Term No. 02-5573 CIVile TERM Defendam(s) THIS LAW FIRM IS A DEBT COLLECTOR AND WE ARE ATTEMPTING TO COLLECT A DEBT. THIS NOTICE IS SENT TO YOU IN AN ATTEMPT TO COLLECT A DEBT. ANY INFORMATION OBTAINED FROM YOU WILL BE USED FOR THAT PURPOSE. NOTICE OF SHERIFF'S SALE OF REAL PROPERTY TO: PALUMBO, SAMUEL R, SAMUEL R. PALUMBO 113 Whiskey Springs Road Dillsburg, PA 17019 Your house at 234 E, Old York Road. Carlisle. PA 17013 is scheduled to be sold at Sheriffs Sale on Wednesday, March 02,2005, at 10:00 AM, in Commissioners Hearing Rm 2nd FL Courthouse to enforce the court judgment of$97,734,08 obtained by CITIFINANCIAL MORTGAGE CO,INC. FIKJA FORD CDC against you, NOTICE OF OWNER'S RIGHTS YOU MAY BE ABLE TO PREVENT THIS SHERIFF'S SALE To prevent this Sheriffs Sale you must take immediate action: 1. The sale will be cancelled if you pay to CITIFINANCIAL MORTGAGE CO, INC, FIKJA FORD CDC, the back payments, late charges, costs and reasonable attorney's fees due, To fmd out how much you must pay call: 215-627-1322 02-5573 CIVIL TE 2, You may be able to stop the sale by filing a petition asking the Court to strike or open 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 yo will bave of stopping the sale, (See notice below on how to obtain an attorney), YOU MAY STILL BE ABLE TO SAVE YOUR PROPERTY AND YOU HAVE OTHER RIGHTS EVEN IF THE SHERIFF'S SALE DOES NOT TAKE PLACE. . I, If the Sheriffs Sale is not stopped, your property will be sold to the highest bidder, You may find oul the price bid price by calling the Sheriff of 717-240-6390, 2, You may be able to petition the Court to set aside the sale if the bid price was grossly inadequate compared to the vallie 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 the Sheriff 0017-240-6390, 4, If the amount due from the Buyer is not paid to the Sheriff, you will remain the owner of the property as if the sale never happened, 5, You have 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 house, A schedule of distribution of the money bid tor your house will be filed by the Sheriff thirty (30) day~ from tht: uatt: uflht: Sheriffs Sale, This schedule will state who will be receiving that money, The money will be paid out in accordance with this schedule unless exceptions (reasons why the proposed distribution is wrong) are filed with the Sheriff within ten (10) days atter the schedule of distribution is filed, 7, You may also have other rights and defenses, or ways of getting your house back, if you act immediately atter 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, LEGAL SERVICES INC 8 Irvine Row Carlisle, PA 17013 CUMBERLAND COUNTY BAR ASSOCIATION 2 Liberty Avenue Carlisle, P A 17013 02-5573 CIVIL TE GOLDBECK McCAFFERTY & McKEEVER BY: Joseph A. Goldbeck, JT. AttorneyI,D,#16132 Suite 5000- Mellon Independence Center 70 I Market Street Philadelphia, P A 19106 215-627-1322 Attorney for Plaintiff CITIFINANCIAL MORTGAGE CO. INC, F/K/A FORD CDC 1111 Northpoint Drive Building 4, Suite 100 Coppell, TX 75019-3931 IN THE COURT OF COMMON PLEAS of Cumberland County Plaintiff CNIL ACTION - LAW vs, SUSAN K. PALUMBO SAMUEL R, PALUMBO Mortgagor(s) and Record Owner(s) ACTION OF MORTGAGE FORECLOSURE 234 E, Old York Road Carlisle, PA 17013 Term No, 02-5573 CNIL TERM Defendant(s) THIS LAW FIRM IS A DEBT COLLECTOR AND WE ARE ATTEMPTING TO COLLECT A DEBT. THIS NOTICE IS SENT TO YOU IN AN ATTEMPT TO COLLECT A DEBT. ANY INFORMATION OBTAlNED FROM YOU WILL BE USED FOR THAT PURPOSE. NOTICE OF SHERIFF'S SALE OF REAL PROPERTY TO: PALUMBO, SUSAN K, SUSAN K. PALUMBO 113 Whiskey Springs Road Dillsburg, P A 17019 Your house at 234 E. Old Yark Road, Carlisle, P A 17013 is scheduled to be sold at Sheriff's Sale on Wednesday, March 02,2005, at 10:00 AM, in Commissioners Hearing Rm 2nd FL Courthouse to enforce the courljudgment of$97,734.08 obtained by CIT1FlNANCIAL MORTGAGE CO, INC, F/KlA FORD CDC against you, NOTICE OF OWNER'S RIGHTS YOU MAY BE ABLE TO PREVENT THIS SHERIFF'S SALE To prevent this Sheriffs Sale you must take immediate action: 1. The sale will be cancelled if you pay to CITIFINANCIAL MORTGAGE CO, INC, F/KlA FORD CDC, the back payments, late charges, costs and reasonable attorney's fees due, To find out how much you must pay call: 215-627-1322 02-5573 CIVIL TE 2, You may be able to stop the sale by filing a petition asking the Court to strike or open 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 yo will have of stopping the sale, (See notice below on how to obtain an attorney), YOU MAY STILL BE ABLE TO SAVE YOUR PROPERTY AND YOU HAVE OTHER RIGHTS EVEN IF THE SHERIFF'S SALE DOES NOT TAKE PLACE. 1, If the Sheriff's Sale is not stopped, your property will be sold to the highest bidder. You may fin out the price bid price by calling the Sheriff 01'717-240-6390, 2, You may be able to petition the Court to set aside the sale if the bid price was grossly inadequat compared to the value of your property, 3, The sale will go through only if the buyer pays the Sheriffthe full amount due in the sale. To fin out if this has happened, you may call the Sheriff of717-240-6390, 4, If the amount due from the Buyer is not paid to the Sheriff, you will remain the owner of the property as if the sale never happened, 5, . You have 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 house, A schedule of distribution of the money Lid fur yuur huuse wiil be filed by the Sheriff thiny (30) days from the date of . e Sheriffs Sale, This schedule will state who will be receiving that money, The money will be paid out in accordance with this schedule unless exceptions (reasons why the proposed distribution is wrong) are file with the Sheriff within ten (10) days atter the schedule of distribution is filed, 7, You may also have other rights and defenses, or ways of getting your house back, if you act immediately after the sale, YOU SHOULD TAKE THIS PAPER TO YOUR LAWYER AT ONCE, IF YOU DO NOT HAVE A LAWYER OR CANNOT AFFORD ONE, GO TO OR TELEPHONE THE OFFICE LISTED BELOW T FIND OUT WHERE YOU CAN GET LEGAL HELP, LEGAL SERVICES INC 8 Irvine Row Carlisle, P A 17013 CUMBERLAND COUNTY BAR ASSOCIATION 2 Liberty A venue Carlisle, P A 17013 ALL that certain tract of land with the improvements thereon erected, situate in South Middleton Township, CUmPerland County, Pennsylvania; bounded and described as follows: BEGINNING at a spike in the center of the York Road, at the Eastern line of land of Coyle Lumber Company, Inc.; thence in an Easterly direction along the center line of the York Road, 124 feet 4 inches to a point in said center line; thence in a Southerly direction along land now or formerly of W. Harold Cline, 166 feet to a point at the Tail Race; thence in a Westerly direction along said Tail Race 135 feet to a point on the Eastern line of Coyle Lumber ,company, Inc_; thence in a Northerly direction along the Easte!n line of said land, 145 feet to the Place of BEGINNING. . BEING improved with a frame bungalow and outbuildings; SHORT DESCRIPTION IMPROVEMENTS consist of a residential dwelling. BEING PREMISES: 234 E. Old York Road Carlisle, PA 17013 SOLD as the property of SUSAN K. PALUMBO and SAMUEL R. PALUMBO TAX PARCEL #40-11-0288-009 WRIT OF EXECUTION and/or ATTACHMENT COMMONWEALTH OF PENNSYLVANIA) COUNTY OF CUMBERLAND) NO 02-5573 Civil CIVIL ACTION - LA TO THE SHERlFF OF CUMBERLAND COUNTY: To satisfy the debt, interest and costs due CITIFINANCIAL MORTGAGE CO. INC. F/K1A FORD CDC, Plaintiff (s) From SUSAN K. PALUMBO AND SAMUEL R. PALUMBO (I) You are directed to levy upon the property of the defendant (s)and to sell SEE LEGAL DESCRIPTION (2) You are also directed to attach the property of the defendant(s) not levied upon in the possession of GARNISHEE(S) as follows: and to notify the garnishee(s) that: (a) an attaclunent has been issued; (b) the garnishee(s) is enjoined fr m paying any debt to or for the account of the defendant (s) and from delivering any property of the defen ant (s) or otherwise disposing thereof; (3) Ifproperty of the defendant(s) not levied upon an subject to attaclunent 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 a a garnishee and is enjoined as above stated, Amounl Due $97,734.08 L.L. Interest FROM 5/4/02 TO 2/10/03 AT 10.6500% Atty's Comm % Due Prothy $1.00 Ally Paid $1480.31 Other Costs Plaintiffpaid Date: DECEMBER 1, 2004 CURTIS R. LONG (Seal) By: Deputy REQUESTING PARTY: Name JOSEPH A. GOLDBECK, JR., ESQUIRE Address: SUITE 5000 - MELLON INDEPENDENCE CENTER 701 MARKET STREET PHILADELPHIA, PA 19106-1532 Attorney for: PLAINTIFF Telephone: 215-627-1322 Supreme Court ID No, 16132 Real Estate Sale #33 On December 02, 2004 the Sherifflevied upon the defendant's interest in the real property situated in South Middleton Township, Cumberland County, PA Known and numbered as 234 E. Old York Road, Carlisle, more fully described on Exhibit "A" filed with this writ and by this reference incorporated herein. Date: December 02, 2004 21:( d 1-:nO~OOl Vd 'A1rlnG:; OWJl~3a\oln3 .:I.:II1:I3\-1S 3\-11 .:10331.:1.:10 By:J ~ M~^' ,:J.-A Real Est;~~p'~ ~ I::ii;J C::'-J ~:-~:' PROOF OF PUBLICATION OF NOTICE IN CUMBERLAND LAW JOURNAL (Under Act No. 587, approved May 16, 1929), p, L.1784 COMMONWEALTH OF PENNSYLVANIA ss. COUNTY OF CUMBERLAND Lisa Marie Coyne, Esquire, Editor of the Cumberland Law Journal, of the Count and State aforesaid, being duly sworn, according to law, deposes and says that the Cumberlan Law Journal, a legal periodical published in the Borough of Carlisle in the County and State afi resaid, 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 reg larly issued weekly in the said County, and that the printed notice or publication attached heret is exactly the same as was printed in the regular editions and issues ofthe said Cumberland aw Joumal on the following dates, VIZ: January 14, 21, 28, 2005 Affiant further deposes that he is authorized to verify this statement by the Cumbe and Law Journal, a legal periodical of general circulation, and that he is not interested in the s ject matter of the aforesaid notice or advertisement, and that all allegations in the foregoing statements as to time, place ?'1d character of publication are true. TO AND SUBSCRIBED before me t is 28 day of Januarv. 2005 ~-,~)J: ~dLV Notary REAL ESTATE SALE NO. 33 Wrtt No, 2002-5573 CMI Citifinancial Mortgage Co. Inc. f/k/a Ford CDC vs, Susan K. Palumbo and Samuel R. Palumbo Atty.: Joseph Goldbeck ALL that certain tract DEland with the improvements thereon erected, situate in South Middleton Town- ship, Cumberland County. Pennsyl- vania. bounded and described as follows: BEGINNING at a spike in the center ofllie York Road, at the East- ern line of land of Coyle Lumber Company, Jnc.; thence in an East- erly direction along the center line of the York Road. 124 feet 4 inches to a point in said center line; thence in a Southerly direction along land now or formerly of W. Harold Cline, 166 feet to a point at the Tail Race; thence in a Westerly direction along said Tail Race 135 feet to a point on the Eastern line of Coyle Lumber Company, Inc.; thence in a North- erly direction along the Eastern line of said land. 145 feet to the Place of BEGlNNING, BEING improved with a frame bune:alow and outbuildings. SHORT DESCRIPTION IMPROVEMENTS consist of a residential dwelling. BEING PREMISES: 234 E, Old York Road, Carlisle, PA 17013. SOLD as the property of SUSAN K, PALUMBO and SAMUEL R. PALUMBO, TAX PARCEL #40-11-0288-009, 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 James L. Clark, being duly sworn according to law, deposes and says: That he is the Accounts Receivable Manager of The Patriot News Co" a corporation organized and isting under the laws of the Commonwealth of Pennsylvania, with its principal office and place of business at 812 t 818 Market Street, in the City of Harrisburg, County of Dauphin, State of Pennsylvania, owner and publisher of e Patriot-News and The Sunday Patriot-News newspapers of general circulation, printed and published at 812 I 818 Market Street, in lhe City, County and State aforesaid; that The Patriot-News and The Sunday Patriol-News ere established March 4lh, 1854, and September 18th, 1949, respectively, and all have been continuously publis d ever since; That the printed notice or publication which is securely attached hereto is exactly as printed and pu ished in their regular daily andlor Sunday/ Metro editions which appeared on the 18th and 25th day(s) of January a d the 1st day(s) of February 2005, That neilher he nor said Company is interested in the subject matter of said pri ted notice or advertising, and that all of the allegalions of this statement as to the time, place and character of pu lication are true; and That he has personal knowledge of the facts aforesaid and is duly aulhorized and empowered to ve fy this statement on behalf of The Patriot-News Co, aforesaid by virtue and pursuant to a resolulion unanimously p ssed and adopted severally by lhe stockholders and board of directors of the said Company and subsequently dul recorded in the office for lhe Recording of Deeds in and for said County of Dauphin in Miscellaneous Book 'M", Volume 14, Page 317, PUBLICATION ~ / { """"""""""'''''''''''''''''''''' "."'"',..""1...",............,..,.,..,..",,..,., COpy S ALE #33 Sworn to and subscribed t\OTARIAl. Terry L. Russell, N Qly of Harrisburg, My commission EJ<plres ...... A Y PUBLIC I I Anocla1ionofNO ,r e~ . Memb.r, Ptnnsy van a ~My COlDll11SSlOn exprres June 6. 2006 ~ , CUMBERLAND COUNTY SHERIFFS OFFICE CUMBERLAND COUNTY COURTHOUSE ONE COURTHOUSE SQUARE CARLISLE, PA. 17013 Statement of Advertising Costs To THE PATRIOT-NEWS CO, For publishing the notice or publicalion attached hereto on the above stated dates 198,85 Publisher's Receipt for Advertising Cost The Patriot News Co" publisher of The Patriot-News and The Sunday Patriot-News, newspapers of gener I circulation, hereby acknowledge receipt of the aforesaid nolice and publication costs and certifies that lhe ame have been duly paid, By"""""""""""""""""""""""", """"""""" i.:o....--' 'CJ' REAL ESTATE SALE No. 33 Writ No. 2002-5573 ClvIlTenn CltHlnariclal ~ Co. Inc. We Ford CDC VB SU8lIII K. Palumbo lUlCI &11III81 R. Palumbo Atty:.Io8aph G_ DESCRIPTION ,,.. ... AIL TIIAT ~"'" of land willI the improvementsthere..')jf erected. situate in South Mid-dIeton TowDship, Cumberland COWll)', PeonsylvaDia, booDded and de-saibed as follows: BEGlNNINGal. spike in the ceorerofthe YorltRoad, althe ~lineoflandofCoyle Lomber Company, Inc,; thence in an Easterly direclion aIongthe center line of theYorl< Road, 124 feet 4 inches to a point in said center line; thence in. Soothedy direction along land 1lOW or formerlyofW, IIa!oldCline, 166 feet to. point al the Tail Race; thence in a Westerly direcrion along said Tail Race 135 feet to a point on the Eastern line of Coyle Lumber Cmnpany,lnc,; thence in. NorlherlydirectionaloogtheEa1.tunlineofsaid land. 145 feet to the Place of BEGINNING, BEING improveo.lwillI. fnme bonglllow and ootboildings, IMPROVEMENTS consist of a residential dwelling, '~ BEING PREMlSES: 234 E. Old Yorl< Road, Carlisle, PA 17013, SOI1l as the JlIUP<'lY of S.... K. PalWDbo IlllI SamocIR. Palumbo, Tn Pmt.l t40-lI-lllSS-Orn,