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Home My WebLink About00-04657 - MATTLEMAN, WEINROTH & MILLER BY: SHARON ORAS MORGAN, ESQUIRE Attorney ID# 60068 Suite 2226, Land Title Building Broad & Chestnut Streets Philadelphia, P A 19110 (215) 923-2225 CITIMORTGAGE, INC. F/K/ A SOURCE ONE MORTGAGE CORPORATION D/B/A CITICORP MORTGAGE, INC. 27555 FARMINGTON ROAD FARMINGTON HILLS, MI 48334 Plaintiff vs. TERRY L. RAUP, SR. 432 PINE GROVE ROAD GARDNERS, PA 17324 Defendant(s) COURT OF COMMON PLEAS CUMBERLAND COUNTY No.: 00 -~I.S7 Cu~(T€'ArJ CIVIL ACTION MORTGAGE FORECLOSURE COMPLAINT "-,1, . 1'- NOTICE You have been sued in court. If you wish to defend against the claims set forth in the following pages, you must take action within twenty (20) days after this complaint and notice are served, by entering a written appearance personally or by attorney and filing in writing with the court your defenses or objections to the claims set forth against you. You are warned that if you fail to do so the case may proceed without you and a judgement may be entered against you by the court without further notice for any money claimed in the complaint or for any other claim or relief requested by the plaintiff. You may lose money or property or other rights important to you. YOU SHOULD TAKE TillS PAPER TO YOUR LAWYER AT ONCE. IF YOU DO NOT HAVE A LAWYER OR CANNOT AFFORD ONE, GO TO R TELEPHONE THE OFFICE SET FOR THE BELOW TO FIND OUT WHERE YOU CAN GET LEGAL HELP. COURT ADMINISTRATOR 4TII FLOOR CUMBERLAND COUNTY COURTHOUSE CARLISLE, PA 17013 717-240-6200 '" ,- . ,<, ", ***************************************************************************** NOTICE PURSUANT TO FAIR DEBT COLLECTION PRACTICES ACT ***************************************************************************** 1. This communication is from a debt collector. This is an attempt to collect a debt and any information obtained will be used for that purpose. 2. Unless you dispute the validity of this debt, or any portion thereof, within 30 days after receipt of this notice, the debt will be assumed to be valid by our offices. 3. If you notify our offices in writing within 30 days ofreceipt of this notice that the debt, or any portion thereof, is disputed, our offices will provide you with verification of the debt or copy of the Judgment against you, and a copy of such verification or judgement will be mailed to you by our offices. , -."" " , , -,,""""!"... MATTLEMAN, WEINROTH & MILLER BY: SHARON ORAS MORGAN, ESQUIRE Attorney ID# 60068 Suite 2226, Land Title Building Broad & Chestnut Streets Philadelphia, P A 19110 (215) 923-2225 CITIMORTGAGE, INC. F/K/A SOURCE ONE MORTGAGE CORPORATION D/B/A CITICORP MORTGAGE, INC. 27555 FARMINGTON ROAD FARMINGTON HILLS, MI 48334 Plaintiff COURT OF COMMON PLEAS CUMBERLAND COUNTY vs. No.: TERRYL. RAUP, SR. 432 PINE GROVE ROAD GARDNERS, PA 17324 CIVIL ACTION MORTGAGE FORECLOSURE COMPLAINT Defendant(s) CIVIL ACTION MORTGAGE FORECLOSURE COMPLAINT 1. CitiMortgage, Inc. d/b/a CitiCorp Mortgage, Inc. (hereinafter referred to as "Plaintiff") is a mortgage corporation, conducting business under the laws of the Commonwealth of Pennsylvania and brings this action to foreclose in the Mortgage executed between Terry L. Raup, Sr., mortgagors hereinafter referred to as "Defendant" and Source One Mortgage Corporation. Said Mortgage is dated 6/16/99 and was recorded in the Office of the Recorder of Deeds and Mortgages in Cumberland County, Pennsylvania on 6/22/99 in Mortgage Book 1551, page 842. A copy of the Mortgage is attached hereto and made a part hereof as Exhibit "A". Said Plaintiff is the proper party plaintiff herein by way of assignment. 3. The Mortgage secures Defendants' Note dated 6/16/99 in the amount of $92,076.00 ,-, - ~ ~ payable to Plaintiff in monthly installments with an interest rate of 7.5 %. A copy of said Note is attached hereto and made a part hereof as Exhibit "B". 4. The land subject to the mortgage is: 432 Pine Grove Road Gardners, Pennsylvania 17324 A copy of the legal description is attached hereto and incorporated by reference. 5. The Defendant(s), Terry L. Raup, Sr. is the Real Owner of the land subject to the mortgage. The Defendant(s) mailing address is 432 Pine Grove Road, Gardners, Pennsylvania 17324. 6. The Mortgage is now in default due to the failure of the Defendants to make payments as they became due and owing. The following amounts are due: Principal Balance Interest Calculated to June 25, 2000 Escrow Deficiency Late Charges Attorney Fees Total $ 91,896.11 $ 5,059.84 $ 511.68 $ 249.20 $ 4,594.80 $102,311.64 plus interest from 06/26/00 at $18.88 per day, costs of suit and attorney fees. 7. In accordance with the provision of the Act of January 30, 1974, P.L. 13 No.6, Section 403 (41 P.S. 403), a Notice of Intention to Foreclose Mortgage is not required in said proceeding as the bona fide consideration is in excess of $50,000.00. A Notice of Homeowners' Emergency Mortgage Assistance is not required in said proceeding as the same is insured by the Federal Housing Administration under Title II of the National Housing Act (12 U.S. C.A. Section 1707-1715z-18). The Defendants have not cured the default. -"''"-7 ,-' li WHEREFORE, Plaintiff requests the court enter Judgment in Mortgage Foreclosure for the sale of the mortgage property in Plaintiff's favor and against the Defendants, in the sum of $102,311,64 together with interest from 06/26/00 at $18.88 per day, costs of suit and attorney fees. MATTLEMAN, WEINROTH & MILLER BY: Sharon Oras Morgan #60068 00-54354-0 I . ,~c.. _ '" \ VERIFICATION !, J A Al eT L lA, 1T M f1 III , state that I am the Assistant Vice President of CitiMortgage, Inc. Plaintiff herein; that I am acquainted with the facts set forth in the foregoing Complaint; that the same are true and correct to the best of my knowledge, information and belief; that this statement is made subject to the-penalties of 18 Pa.C.S. section 4904 relating to the unsworn falsification to authorities. ~~~~~ Assistant Vice President " ''';, ~ ~~, ,--" ~3~\\ -.0\ '" ~,"".::"; ~:." ~.... --." : . .M:;::'.~:~.ER R::C.OF:~.'::::~ Dr :'E1::;)5 ---, ,~,,,,, ^O"u":'"'J ~A ....I!t.-.'-a,.}. ;" '." :': . '.<' 1 -I ~ ...Uf.j:;!...!\l,_-,,\oJ \J ...... - '99 JUN 22- RA 10 57 PREPARED 8Y: CAROLYN CLARK Patcel Number: WHEN RECORDED RETURN TO: SOURCE ONE MORTGAGE CORPORATION 27555 FARMINGTON RD STE 300 FARMINGTN HLS, MI 48334-3357 FINAL OOCUMENTS sf3 j d-d--- 70226939-7 FHA CeRNo. 44\-6026922-703 2(138 MORTGAGE nus MORTGAGE ("Security Instrument") is given on The Mortgagor is . TERRY L. RAUP SR. JUNE \6TH, \999 ("Borrower"). This Security Iilsttumen.t is given to SOURCE ONE MORT6AGE CORPORATION which is organized and existiDgunder the laws of DELAWARE and whose address is 27555 F ARMINGTDN RD STE' 300 F ARMINGTN HLS. MI 48334-3357 ("Lender"), Borrower owes Lender the princ:ipalsum of NINETY-TWD THOUSAND SEVENTY-SIX AND NOll00 . Do1la1s(U,S.$ 92.076.00 ). This debt is evid~ by Borrower's note dated the lllIIIle date.. this Security Instrwnent ("Note), which provides for monthly payments, with the full debt, if not paid earlier, due and payable. on JULY 1 ST. 2029 . This Security Instrument secures to Lender: (a) the repayment of the debt evidenc:ed by the Note, with inteIest, and aIllel."'....is, Q~~;nns and modifications of the Note; (b) the payment of aU other sumS, with inteIest, advanced under psragrapb 7 to protect the security of this Security Instrument; and (c) the petformance of Borrower's covenants and agteements undertbis Security i ! IlIA PeIuIs1-MorItlaae-lI/fS ~-4RlPA) (100" VMPMDRTGAGEFORMS-(8OOIfi2.1-7291 I( _'018 101tlatl:7t ~r. 02500 70226939-7 1I'IIII'I:llllilllll.1 KS2AO ii i! ; jj ;e iil ."""m ~""~. . ~~__. ~~ -~ ,. , --."",' -~, - -, _'h~' ~ 0: Instrument and the Note, For this purpose, Bottower does hereby mortgage,. grant and convey to the Lender the fonowing described property located in .. -AIlAIIS- Ck.?').J,>W~ County, Pennsylvania: .. . SEE ATTACHED LEGAL DESCRIPTION PAGE(S) which bas the address of 432 PINE GROVE RD, GARDNERS Pennsylvania 17324-8819 l2iP Code] ("Property Address"?; TOGBTHERWITH all the improvements now or hereafter erected on the ~, and all easements, appurteDatll:e!l and fixtures now or hi:reafter a part of the pt'Pllefty. All replPcent""l$liIld lidditions shall also he coven:d bv this Security Instrument, All of the foregomg is iefcuul to in this Security Instrument as the "Property,~ . BORROWER COVENANTS that Borrower is lawMly ~ of the estate hereby conveyed and has the right to. mortgage. ~ and convey the ~ ami that the ProoertY is UI1eIicumbeied, except for eIicumbrances or recOrd, BorrOwer warrants and Will Clcf'end generally the "title to the Property I'gainst all Claims and demandJs, subject to any encumbrances of record, TInS SECURITY INSTRUMENT <:ombines Ubiform c:ovenants for national use and non-Ubifonn covenants with limited variations by jurisdiction to constitute a uniform security instrument covering real property. IS-. ClIy], Bonower and Lender covCll8l1t and agree as follows: UNIFORM COVENANTS. . ~ 1. Payment ClfPrlndPllL Interest and LateCharp., Bottower shall pay when due the principatof, and int.ereston, thedebteW~ ~ the Note and late chargCS clueUbder theNote. 2. Monthly Pa~ ofTaxes.lnsnranee and Gtheir Charges. Bottower shall include in each mnnthly paymentl togetlier With the principal andint.erest as set forth in the Note and any late charges, a sum for (a) taxes 8nd special ass: ''',-f:s levied or to he levied aga,inst the Property, (b) leasehOld ~Is or ground reilIs on the Property, and (c) premiums for Wsuranc:e requim:l1lI1llq Jl8rairaph 4. In any year in which dte Lender must pay a mortgage Wsuranc:e. ~um. to. the Seereta1yofHousbiaaDil Urban Deve1opment. ("SecrcIary"), orinc: year in wliich such ~um would have been ftqIiredif1.ender still held the Security Instiurnent, monthly payment shall also include eith:~ sum for the IIIIllWIl mortgapinsuranl:e Pll1BUum. to he nald j:ly Lender to the Secretary, or eii) a monthly e iN~tJ ..of a mortgage 1IISUl'lIIlCe ~s S'ecurity . Instrument is held by the Sectetary, in a Ie amOW1t to he determined by the . Except for the. monthly eharae by the Secretary, ihese items are called "Escrow Items" and the SIIIDS paid to are called HEscrow FunldS." . Lender may, at any time, collect and hold lIDIOUDIs for &crow Items in an aggregate IIIDDUIItnot to exceed the maximum amount \bat IIIay he required for Borrower'. escrow IICClllIIIt under the Real Estate Settlement Procedures Act of 1974, 12 U.S.C. SeCtion 2601 et seq,*. implementins regulations, 24 CPR.. Part 3500, as they ilU!Yheamended from time to time ("RESPA"),~:that thec:usbionor reserve permitt.edby RESPAfor unantiCIpated disbursemcnls or disb1"""","""" befoie the Borrower's payments are available in the account may not he b8sedonamountsduefor themortgageiDsurance premium. . _o4RtPA) _11 PQez.ofa 1....18: n R S r-, W['lI;II ~ -~ - "=,-~,~~^ ,~-......"'~ 'I If the amounts held by Lender for &crow Items exceed the amounts petmitted to be held by RESPA, Lender shall account to Borrower for the excess funds as requited by RESPA. If the amounts of funds held by Lender at any time is not sufficient to pay the &crow Items when due, Lender may notify the Borrower and require Borrower tomaknp theshottageas petmitted by RESPA, " , , The Escrow Funds ale pledged as additional security for all sums secuted by this Security Instrument. If Borrower te!llders to Lender the full payment of all such SWIllS, Borrower's acc:ount shall be credited with the balance remaining for all iDstallment items (a), (b), and (c) and any mortgage insUrance premium iMhoIlmenl that Lender has not becoine obligated to pay to the Secretary, and Lender shall promptly refund any excess ftmds to Borrower. Tmm..G'llP1y prior to a foreclosure sale of the Property or its acquisition by Lender, Borrower's acc:ount shall be "credited with any balance felnainil\g for all iDstallments for items (a), (b),. and (c). . 3. Application of Payments. All payments W1der paragraphs 1 and 2 sball be applied by Lender as follows: Fimt, to the mortgage insurance premium to be paid by Lender to the Secretary or to the mMt1)Iy charge by the Secretary Instead of the monthly mortgage insurance premium; Second, to any taxes, special aSH I..~, leasehold payments or ground rents, and fire, flood and other hazard insUrance premiums, as required; Third, to interest due W1derthe Note; Fourth, to amortization of the principal of the Note; anrJl Fifth, to late charges due under the Note. 4. FIre, Flood.aad ~ Hazard Insurance. Borrower sball insute all improvements on the Property, whether now in existea1ce or subsequently erected, agalnst any bazaJds, casualties, and contingencies, including fire, for which Lender requift:s insurance. This insurance sball be maintained in the amounts and for the periods that Lender requift:s, Borrower sball also iDsme,all implOVetD.el1ts on the Property, whether now in existence at subsequently erected, against" loss by floods to the extent required by the Secretary. All insurance sball be carded with compaIIi~ approved by Lender. The hisurance policies and any renewals sball be held by Lender and sball includeloss payable clauses in favor of, and in a form acceptable to, Lender, In the event of loss, Borrower sball give Lender ;mm'l'V'Ite notice by mail. Lender may IIIlIke proof ofloss if not made JPlODlptly by Borrower, Each insurance company concemed is hereby authorized and ditected to IIIlIke payment for such loss directly to I.ender, Instead of to Borrower and to Lender jointly. All or any part of the insurance proceeds may be applied by Lender, at its option, either (a) to the reduction of the indebtedness under the Note and this Security 1nstJ:um.ent, fust to any delinqaentamounts applied in the order in ~ 3, and then to prepayment of principal, or (b) to the restoration or lepair of the dam'lgl'd Property. Any application of the proceeds to the principal shall not extend or postpone the due date of the monthly payments which'. referred to in paragraph 2, or change" the amount of such payllJe1US. Any excess insurance proceeds over an amount requi!ed to pay all OUtstanding indebtedness under the Note and this Security Instrument sball be paid to the entity legally entitled thereto. ... In the event of foreclOS\11C of this Security Instrument or other lrabsfer of title to the Property that extinguishes the indebted11~. all tight, title and intetest of Borrower in and to insurance policies in force shall pass to the purchaser. 5. Oeeraplllll:1, PrltSel'VatioD, Malntenanceaad ProtectIon 01 the Property; Borrower's Loan AP.p.IieatiOIl.;. ~lds. BotroWcf shall occu. P1, establi$h,. alfd use the Property as. Borrow. .. . er's principal n:SiiIence withinsixty days after the ~tion of this Securi!-y Instrument (or within Sixty da~ of a latU sale at lrabsferof theFIO}dty) and shall continue to OCCl1PY the ProPertY as Borrower's principal residmce for at least one yeut after the CIatC of ~,1II11ess Lendir dl'te-iliP.-tbat ~ Will cause undue ~p for B~, or III11ess extenuafil!g ~ exist which are !leYoDd Borrower's control. Bottower Shall ~ ~ of..anyexterwating CJl<"1tnd....res, Bottower shall not COIIIIIlit WllSte.or desIroy, damage or subsfantially change the ProIlertY or allow the Property to deteriorate, reasonable wear and _ ex~ Lenderma. yinspect theProIlCitY. .il' the ~isVlll:llllt. or.bandoned or the loan is indefauIt. Lender may take Ie8SOIIlIble~on top~otecf~~sUchVlll:lllltor~~ed~. Borrowersball;jlso be in default if Borrower, ~ the loan application pracess, gave 11I:= false or inaccurate information or statemeJ1ts to Lender (or faired to proVIde Lender with any' iDfoImation) in connection with the loan GiL-4RlPAI (1804) _3.,. Initia,,, TLR Sr. ". , .~P.!llJ . , "' ~ ~ - ~ evidenced b'Y the Note, including, but not limited to, tepresentations conceming Borrower's occupancy of the Property as a principal residence. If this Security Instrument is on a I_hold. Borrower sba1l comply with the provisions of the lease. If Borrower acquires fee title to the Property, the leasehold and fee title shall not be . merged unless Lender agrees to the merger in writing. . 6. COllldemnatlon. The proceeds of an'Y award or claim for damages, ditect or consequential, in connection with any condemnation or other taking of any part of the Property, or for conveyance in. place of condemnation, IIIe hereby assigned and sba1l be paid to Lender to the extent of the full amount of the indebtedness that remains unpaid under the Note and this Security Jnstrwnent. Lendersba1l. apply such proceeds to the mluction of the indebtedness under the Note and this Security Jnstrwnent, fust to any delinquent aDlounts applied in the order provided in paragraph 3, and then to prepayment of principal, Any application of the proceeds to the principal sba1l not extend or postpone the due date of the monthly payments, which lIle ttlf..ned to in paragraph 2, or change the amount of such payments. Any excess proceeds over an amount required to pay aU oullItaliding indebtedness under the Note and this Security Instrument shall be paid to the entity legally entitled thereto. . . 7, Charges to Borrower and Protection of Lender's Rights in the Property. Borrower sba1l pay all govemmental or municipal charges, fines and impOisiticmS that IIIe not included in paragraph 2. Borrower sba1l . pay thClle obligationson timcditectly to the entity wllich is owed the payment. If failure to pay would adversely affect Lender's interest in the Property, upon Lender's request Borrower shall promptly furbish to Lender receipts evidencing these paymerils. . If I3orrower fails to make these payments or the payments requited by patagtaph 2. or fails to perform any other covenants andagreernMts contained in this Security Instrument, or there is a legal pror-..lll\g that may significantly affect Lender's rights in the Property (such asa ptlX'-'lng in.bankruptcy, for emilI-nation or to enforce laws or regulations), then Lender may do and pay whatever is nee . . "'Y to protect the value of the Property and Lender's rights in the Pfup..rt:y, including payment of taxes, hazard .insurance and other items mentiOlled in paragraph 2. ' My lIllWWlts disbursed by Lender under this paragraph shall become an additional debt of Borrower and be sec\l1'ed by this Security Instrument. These amounts shall bear interest from the date of disbumement, at the Note rate,lIIlld at the option of Lender, shall be Immecliately due and payable. Borrower sba1l promptly discharge any lien which has priority over this Security Instrument unless Bortower: (a) agrees in writing to the payment of the obligation secured by the lien in a manner acceptable to Lender; (b) contests in good faith the lien by, or defends against enforcement of the lien in, legal ~~ whi~ in the Lender's opinion operate to prevent the enfOllCell1ent of the lien; ,or (c) secut<ll fu>ln the holder of the lien an agreement satisfactory to Lender subotdinating the lien to this Security InStrument. If Lender determines that any part of the Property is subject to a lien which may attain priority over this Security Instrument, Lender may give Borrower a notice identifying the lien. Borrower shall satisfy the lien or ta\re'one or more of the actions set forth above .within 10 days of the giving of notice. . 8. Fees. Lender may coJ\ectfees and cbaI:gaI anthorlze;cl by the Secretaly. 9. Groundsror Aeeelentiou. of Debt. (a) Default. Lender ~', ex~ as limited by regulations issued by the Secretary, in the case of ~yment defaults,teqWre .mmNlISJte payment m full of aUS1JIIIS secured by this Security Instrument if: (i) Borrower defaults by failing to pay in full any lJ10nthly paynient requited by this Security IDst.rwnent prior to or on ttiedueaate of the next montJ>lypayment, or (ii) B.orro!,er~ts. by failing, for a period of tbiitjr days, to perform any other obligations CX1IltAlnM m this Secanty JnstruDient. (b) Sale Without Credit ApprovaL Lender sball, if permitted by applicable law (mcluding Section 341(d) of the Garn- SL Germain Depository Institutions Act of 1982, 12 U.S.C. 1701j-3(d)) and with the prior approval of the Secretary, n:qaire Imm"'!l,.te ""~ in full of aU S1JIIIS secured bv this Security Instrument if: ..'" J ~-4RIPAI ($OIl') Pa004of' ~ nR S"r __. ..A .......... .JIIll __ "1l!-.< ~ ~ "-~"~ - ,._~~-~'" '(; (i) AU or part of the Property, or a bene:ficial interest in a trust owning all or part of the Property, is sold or otlierwise traDsfetted (other than by devise or de&eent), and . (ii) The Ptoperty is not OC:CUpled by the pUrchaser or grantee as his or her principal residence, or the purc:haser or ~ does so cx:cupy die. Property bUt his or her credit bas bot been approved in Irccotdam:eWlththerequ.ireinentsofthe~. . . (c) No Waiver. If c:iteum$anc:es llCCUt that would pennit Lender to ~ itmnediate payment in full, but Lender does not rilquire such payments, Lender does not waive its nghts withleS{leCt to subsequent ~~ts, . (d) RegulatiobS of JIUD Sec:retIIry. In many cilcuIIJstances tegulatiObS issued by the SecteIa!y will limit Lender's rights, in the ease of payment defaults, to. requite immediate payment in full and forec:llose if not paid. This Security IbStrume11t does not authorize acc:e1eratiOl1 or foteelosure if bOt permitted bytegUlatiObSofthe Secretary. . . (e) Mol'tpge Not 1Dsund. ~er agrees that if this Security IIIstrument and the Note are bOt <I""......inM to be e1i,ible for ibSuranI:e under the NatiODal Housins Act within 60. days ftom the date hereof, Lender may, at its oplion, teqUite immlldiatepaymentin full of all SIII1ISsec:uted by this Security JnsIIumeI1t. A written ~--t of any authorized.ent of. the Secretary dlued subsecJuent to 60 days from the date hereof, declinins to insure tJiis Secutity Ibstmment and the Note,sba11 be deemed conclusiveproof' of such ineliBibility, Notwi~ the fOtegoins, this optiMmaynot be exen;ised by Lender When. the UllaVailability of insuran<:e is sorely due to I~'s failute to zemi.t a mortgascl insuran<:epremium.tothe~... . . 10, ReInstatement. Borrower has a risJrt to be teinstllted if Le1tder has required itnmPdi_ payment in full because of Borrower's failure to pay an lII1lOUl1t due undIer the Note or this Security Jnsl!ument. This right applies even after foreclosure pfOC:P."'Ai1)8l' are instituted. Tcrcinstatethe Security Jnst.rwnent, Borrower shall tender in a lump sum alllUl1OUl1ls required to brins ~er's accouI1t current in"lndil\g, to the extA:nt they are obli,atiObS of ~er under tJiis Security InsImment., foteeIosure costs and teasrIIlllhJe and customaiy attorneys' fees and ex~ properly _____iat..n with the foteelosure procet'.l;.,g, Upon reinstateInent by Bortower, this Security InsImmentand the obligatiObS that it secures shall temain in effect as if Lender had not required imm...li'lIP. payment in full; However, Lender is not required to permit reinstatement if: (I) Lender bas accepted reinstatement after the COIllDlClDCe.lIt of foreclOSUte ~'Igl' within two :years lmmed.i.tely pnx:eding the cormnencement of a current foteelosure p~il\g, (Ii) reinstatement will pt=lude foteelosure 011 different grounds in the future, or (ill) reinstatement will adVersely affect the priority of the li~ eteated by this Security InstruJIu:nL 11, Borrower Not Released; For~ By Lender Not a Waiver, BxtensiOl1 of the tUne of payment or modification of amortization.of the SIII1IS secured by this Security Jnstlument pmted by Lender to IIIIY succmor in intetest of Borrower shall not operate to release the liability of the. orisinsl Borrower or Borrower's SUCllBsorin inte1\':st. Lender shall not be required to commence ~"g...apiDst any successor in interest or tefuse to extend time for payment or. otherwise modify amortizatiOl1 of the sums secured by this Security InsIrument by reason of IIIIY dP.m......t made by the original. Borrower or Bctwwer'ssucc~ssa!S in inte1\':st. Any forbearanc:e by Lender in exelCisins any riJlht or remedy shall not be.a waiver of or preclude the exeteise of any risJrt or remedy, .. 12. Su___ and Assi.... Bound; Joint and Several Liability; eo.Signers. The coveJlllllls and agreements of this Security Instmment shall bind and benefit the successors and assigns of Lender and Borrower, subject to the provisiObS of~ 9(b). Bonower's CoveJlllllls and agree.!llents shallbe ~ and several. Any Borrower who QO-Si.gns this Security lilsmuneI1t bUt does not execute the Note: <a> is co-si.ping this SllCUfity InsIrument only to lIlort8a&e, grant and convey that.Borrower's interest in the Property UDder the terms of this Security IIlstrument; (b) is .1lOt pemonally obligated to pay the SIII1IS secuted by this Security Jnstnnnent; and (e) agteeS that Lender and IIIIY other Borrower may agree to extend, modify. forbear or II1IIkc lIIIy aecotDlIloclati.ObS with tegatd to the terms of this SllCUfity InsImment or the Note without that Bottower's conseot. 13. Notices. Any notice to Botrower provided for in this Security Instrw:nent shall be Biven by deliverins it or by !lIlIilins it by first el..~ unless l!PPlicab1e law tequires use of another m.ethod. The notice shall be diteetccl to the Property Aaai$s'Gi:' my:. other . address Borrower desipates by notice to IAlder. _-4RIPAl (111011 .....Bof8 Inidala:TLR S"r -'''l''\ ~ ~.rl-""'fi'!"'1~____>_._,..~,_, I:," ',' < _-4RIPA) '9U01, Pap80fl Inilialo: Ii. (( Sf" , , . ,- , ,,.,..,.., _. , ' " ..~ "-~-""'"- . 18. Foreclosure Procedure. If Lender requires Immediate payment in ton under paragraph " Lender may foreclose this Security Instrument by judicial proeeedlng. Lender shall be entitled to collect aU expenses Incurred in pursuing the remedies p~ed in this paragraph 18, including, but not limited to, attorneYs' fees and costs of title evldellee. If the lMtder's interest in this Security Instrument Is held by the Secretary and the Secretary requires Im.......tate Pll1D1ent in full under Paragraph " the Secretary. may invoke the nonJudlclal power of sale provided in the Single FIUIIlJy Mortpae Foreclosure Ad of 1~ (" Ad") (12 V.S.C. 3151 et seq. ) by requesting a foreclosure colllllllssioner designated under t~ Act to commence foreclosureMd to seD the Property 88 provided in the Ad. Nothing in the. p..........I.., sentence shaD deprive the Secretary of any rights otherwise avallable to a IMtder under thlsParagraph 18 or appllc:able law. 1'.llelease. Upon payment of all sums secured by Ibis Security IDstrumeDt, Ibis S~ty Inslrument and the estate conveyed sball ~l,,-' and bec:omo void. After such oc:currence, Lender sballdiscbarge this Security Inslrument witboutcbarge to Borrower, Borrower sball pay any recordation costs. . 20. Waivers. Borrower, to theextentpermitted by applicable law. waives and releases any error or defects in pro--li'lgS to enforce this Security IDstrumeDt, and hereby waives the benefit of any present or toture laws providing for stay of execution, exteDsion of time, exemption from attachment, levy and sale, and homestead exemption, 21~ llelDStatement PerIod. Borrower's time to reinstate provided in pamgraph 10 sball extend to one hour . prior to the oomm~"l't of bidding at a sbcriff's sale or other sale pursuant to Ibis S~ty Instrument. U. Purehase Money Mortgage. If any of the debtSCCUlllld by this Security Inslrument is lent to Borrower to acquire title to the Property. this Security Inslrument sball be a purchase money mortgage. 23. Interest Rate After Judgment. Borrower agrees that the interest tate payable after a judgment is entered on the Note or in an action of mortgage foteclosure sball be the tate payable from time to time under the Note, 24.. Riders to this Security Instrument. If one or more riders are executed by Borrower and recorcied together with this Security IDstrumeDt, the c:ove1111Dt5 of each such rider sball be incorpCIratecl into and sball ~~ supplementtbecovenants and agreemem.s of this Security Instrument as iftbe rider(s) were a part of this Secunty 1iDsllument, [ChechppJicable ~(C!S)]. a CondominiumRider D Growing Equity Rider . D Other [specify] Planned Unit Development Rider D Graduated Payment Rider . . _-4ft(PA) 19l1O1) ....,7018 InI_TLR Sr. l"'j", "1~ _" '. " ..... =~,'~'~ ~', ''''''~lJf''-'' . BY SIGNING BELOW, Borrower accepts and agrees to the terms contained in this Security Insllument and in any rider(s) executed by Borrower and recorded with it. Witnesses: . <,U-v...NlH\ J:.:1: D r....fJ-' ;J - ,-,-- Itil'l~~n. ;Z II~.L (Seal) -&m>we< (Seal) -Iloaower (Seal) -Iloaower (Seal) -Iloaower (Seal) -Ilonower (Seal) -Iloaower (Seal) -Ilonower (Seal) -Ilonower Certificate or Residence I, that the correct address of the within-11lIIIled Lender is , do hereby certify Witness my band this 16TH dayof JUNE , 1999 A8<Dl of Loader COMMONWEALTHOFPENNSYLV ANIA, On this, the 16TH day of JUNE pemonalIyappeared TERRY L. RAUP SR. .\~"JtE (h~ Countyss: 1999 , before me, the unde!signed officer, . pemon . known' to me (or satisfactorily proven) to be the whose name .cA subscribed to the within instmment and aCknowledged that~ executed the same for the JlUl:llOSCSherein contained, IN WITNESS WHEREOF, Ihetew1to set my hand and official seal, My CommissionExpiIes: 4~ ~j71.Jf1 .J 19.(I L,- . I -.:.-~:~>~~!i~?Y5~~;;~;, Notarial Seal Joann Staab, Noiary Public . SDllnge\1SbuF\l Twp., York Countv .' My Commission Explres May 17, 2llO3 ~~~{~~~,~;!~l!~~\;i _-4RlPAl C.OO" ""'~J;, ~ "1~' ,. ~ ~._" ~- ~._~ "' .LEGAL DESCRIPTION ALL THAT CERTAIN LOT OF LAND SITUATE IN THE TOWNSHIP OF DICKINSON. COUNTY OF CUMBERLAND. AND COMMONWEALTH OF PENNSYLV.ANIE, BEING MOR PARTICULARLY DESCRIBED AS LOT NO. 48 ON A FINAL SUBDIVISION PLAN FOR DICKINGSON TOWNSHIP JOINT VENTURE DATED l1W83, REVISED 2/18/84, WHICH SAID PLAII WAS DULY ENTERED OF RECORD ON MARCH 1. 1984 AND APPEARING OF RECORD IN THE OFFICE OF RECORDER OF DEEDS IN AND FOR CUMBERLAND COUNTY IN PLAN BDOK45, PAGE 32, UNDER AND SUBJECT TO ALL LEGAL HIGHWAYS, EASEMENTS, RIGHTS-OR-WAY AND RESTRICTIONS OF RECORD, s .~..' ",' ~'\~:';~.:;:~;i/~~;.::i-',:~~ . . tateofPenns I . ,"', ,', ,,', ,,'J' , County f vvanra} ',;'.j"":',") .:"",':::::'.".:Y\): '. R 0 Cumberland 86 !..." ,".'-- ;"",..,' '-,;'. ecec~. or~~~ikbioffice for the ~6~: 2;;,:;;':.~f<:;,':::2:;>"/:: .~. .... in .8 berland count..ne!'Dsr""'.~'I,~"''''::: , . 0 "0""- y.... ~ ;~~""'; . " ",. .-' VI".n -VI'r.~. P' ~ "; "','. ;'... .....'f.,...,. "".<'" .. V hl!n~ t,~al ' , ".' ".' -,1' ;"'~:'f ie,' . ." . Carlisle I'AlhiS~Ofo ,e:-h,: ;~~:S:%>"J"":~;';,':,, ~ .d ";,...;;>~t':~;~~~~~P:"'" TMIIIVY ; "'1"~'f'_ .. .. ~, - , , w_~, 70 9~&?39~; Multlstate FHA'CueNo. 441~6026922-703 NOTE JUNE 16TH, 1999 [Dolo] 70226939-7 432 PINE GROVE RO GARONERS. PA 17324-8819 (Propotty Add....) 1. PARTIES .. "Borrower" means eaeh person signing at the el1d of this Note, and the person's successors and assigns. "Lender" ~ SOURCE ONE MORTGAGE CORPORATION, A DELAWARE CORPORATION . and ilssuccessors andassigns. 1. BODOWEll'SPIlOMISETOPAY;1NTEREST Inteturn for a loan lCCeived fromLendet. BottoWerpromises to pay the principal SIIIIlof NINETY-TWO THOUSAND SEVENTY-SIX AND NO/l00 DoUlIlS(U.S.$ 92,076.00 ), plus iJItmst, to the llrder of Lender. ~ will be charged on \Ulpaid principal,fromthedateofdisbmsem.entoftheloanproceedsbyLendet,attherateof SEVEN & ONE HALF percent( . 7.50000%}peryearuntilthefu1lamountofprincipalhasbee.npaid. 3. PIl0MISETOPAYSECURED Borrower's pl'011lise to pay is scc:wed by a mortgage, deed ofttustor similarsecurity instrwnenttbatis dated thesame date as this Note and called the "Security IIIstrument." The Security Instrument ~ the Lender from losses wbichmightresu1tifBorrower defaullsunderthisNote. 4. MANNEIlOFPAYMEN'f (A) nme Borrower sbIIli make a payment of principal and interest to VntW on the fustday of eaeh month beginning on AUGUST 1ST ,1999 . Any principalandinteresuemaining on thefustday of JULY, . 2029 , will bedueontbat date, wbich is called the "Maturity Date." (B) ~ SOURCE ONE MORTGAGE CORPORATION Paymentsball be made at 27555 FARMINGTON AD STE 300 FARMINGTN HLS, MI 48334-3357 or at such place as Lender may desi8nate in writing by notice to Borrower. (C) AmOUlllt Eachmontblypaymentofprincipalandinterestwill beintheamountofU,S, $ 643.81 . This amoUut will be part of a larger mnnthly payment required by the Security Instrument, tbat sball be applied to principal. interestandotberitemsin theorderdescribed in the Security Instrument. (D) AIlongetothlsNoteforpaymeutad,lustments If an allonge providing for payment adjustmel1lsis cxecnted by Borrower together with this Note, the c:ovenants oftheallonge sballbeincorpcnated into and sball amend and supplement the cov_ts of this Note as if the allonge were a partofthisNote. [Checkapp1ic:ah1e box] o Graduated Payment Allonge 0 Growing Equity Allonge 0 Other [specify] 5. BODOWEll'SRIGRTTOPllEPAY Borrower has the right to pay.the debt evidenced by this Note, in whole or in part. without charge or penalty, on the fust day of any m.oittb. Lender sball accept prepayment on other days provided tbat Borrower pays interest on tbe amount prepaid for the lel1llIinder of the month to the extent required by Lender and permitted by regulations of the Sc:c:retary, If I'BA MuIlIoIate 1!IIeol.... Note -18JJ5 _.,R (98011 \IMP MnRTAAAF FnRM!; ~ IAnnlfi"'..77tll11 02500 70226939-7 111IIII IIDIIIDIIIIDII III IIIBl11 IllUIIIIIIII MUn. 8029824 IlUnOUDOIHlIIIlHnlllUllIDIIHl1III , W~r'"" ~ ""'1P ,~ I ~.~ ," ~~*. <'^~ '"~-"-"~ ~- ," ~ Borrower makes a partial prepayment, there will be no changes in the due date or in the amountm the monthly payment unless Lender agrees in writing to thosechanges. 6. BOBllOWER.'SFAlLlJIlETOPAY (A) Late CIuIrp for Overdue Payments If Lender has not received the full monthly payment requited by the Security Instmment, as described in Paragraph 4(C) of this Note, by the end of fifteen calendar clays after the payment is due, Lender may co1\ect a late charge in the amount of FOUR percent ( - . 4.00000%) of the ove!duc amount of each payment. (8) Default . If Borrower defaults by failing to pay in full any mOJl1thly payment,.then Lender may, except as limited by regulations of the Secretary in the case of payment defaults, require imm...lipt'l payment in full of the principal balance remainil1g due lIIlld all acc.tUed interest. Lender may choose not.to exercise this option without waiving its rights in the event of any subsequent default, In many circumstances regulations issued by the Secretary wi1\ limit Lender's rights to require immediate payment in full in the case of payment defaullm. This Note does not authorize l\CCllleration when not permitted by HUD regulatioJis. & used in this Note, .Secretary" means the Sectelary of Housing and Utblln Developmentor his or her designee. . (C) PaymentotCostsandExpeuses If Lender has requited imm...liate payment in full, as described. above, Lender may require Borrower to pay costs and expenses including rea.cnn....\e and customary attomeys' fees for enforcing this Note to the extent not prohibited by applicable law. Such fees and costs shaU bear interest from. the date of disI:nl~erot at the same rate as the principal of this Note. 7, WAIVERS B....tu_ and any other person who has obligations under this Note waive the rights of presentment and notice of dishonor, "Pre-o!bIlent" means the right to require Lender to clemAfld payment of IiInoUIlts due, "Notice of dishonor" means the right to require Lender to give notice to other peISOIIS that amounts due have not been paid 8, GIVING OF N011CES Unless applicable law requites a different method, any notice that must be given 10 Borrower under this Note will be given by delivering it or by mailing.it by first class lDaiI to Borrower at the property addtess above or at a different addtess ifBonower has given Lender al1Qtice of Borrower's different address. Any notice that must be given to Lender under this Note wiUbe given by first class mail to Lender at the addtess stated in Paragraph 4(8) or at a different addtess if Borrower is given anotice of that different address. ',OBLIGA11CliNSOFPERSONSUNDER TBISNOTE If mote than one person signs this Note, each person is fully and peISODlilIy obligated to keep all of the piomises lIlade in this Note, including the promise to pay the full amount owl!d Any persoi1 who is a guarantor, sutety or endo!SCl' of this Note is aI50 obligated to do the$llbings. Any person who takes over the$l obligations, including the obligations of a guarantor, surety or endorser of this Note, is also obligated to keep all of the pJOlnises lIlade in this Note. Lender may enforce its rights under this Note against each person individoally or against all signatories together. Any one person signing this Note may be requited 10 pay all of the ~ owed under this Note, .' BY SIGNING BELOW, Borrower accepts and agrees tothe terms and covenants containedin this Note. (Seal) -BoIIDW<< I~~' .;( ~~-/'.. (Seal) -Bcmowcr (Seal) -Bcmowcr (Seal) -Bcmowcr (Seal) -Bcmowcr (Seal) -Bcmowcr PAY 10 THE Ol'lDER 01' VI'lTHOUT RECOURse ~ . (Seal) -Bcmowcr (Seal) -Borrower ~~~,-" RIll P - ~ "=-~ ~"" - ~." ;~ ~~, "~" ifj ,- '--. - ,",. ' ,~"-"~-w~..<l.,-_~~w'" '" ""~,,<".i_-""i--"/" 1"'\;1,'J'"",O" f? (J ! i,g, 'i "6 ~ q Ct 8 '-0 B 8 () () L-:> (,) ....... c: 0 -n ~ Q"- I $: '- --, ~ -o"'T~ c= ,'c,_ m};~~ '''';{;P ;";1-:.:1 I _ ,,) o~ 2::0 ~ ?i~i ~0 =tg -.l) ~ \.D !<CJ ~l) )>,""", r",_ ( J-:o~ ~ -~,~" J :;;';'( ) ~C) 1',) "-"q ""c ,,-./. -".- ;;,:-; ~ ........-., ...;-'" -, :0 --.I -< ~ ~_~ ",,~~\W~!~"!)!"~"FW!!ijj'H;"'Wf<<,,~'~H';.;1ff[)~~I!I'll!\'.flili~Il!!N1l\ffiI~~~H~Sl ~.,..._ '-,--,'.' OFFICE OF THE PROTHONOTARY COURT OF COMMON PLEAS OF CUMBERLAND COUNTY Prothonotary TO: Terry L. Raup CITIMORTGAGE, INC. FIK./ A SOURCE ONE : COURT OF COMMON PLEAS MORTGAGE CORPORATION D/B/A CITICORP: CUMBERLAND COUNTY MORTGAGE, INC. 27555 Farmington Road Farmington Hills, MI 48018 Plaintiff vs, No.: 00-4657 CIVIL TERM TERRY L. RAUP, SR. 432 Pine Grove Road Gardners, PA 17324 Defendants NOTICE PURSUANT TO RULE 236 NOTICE Pursuant to Rule 236 of the Supreme Court of Pennsylvania, you are hereby notified that a Judgment has been entered against you in the above proceeding as indicated below, Prothonotary MORTGAGE FORECLOSURE JUDGMENT BY DEFAULT IF YOU HAVE ANY QUESTIONS CONCERNING THIS NOTICE, PLEASE CALL: SHARON ORAS MORGAN, ESQUIRE #60068 MATTLEMAN, WEINROTH & MILLER 215/923-2225 291/54354 I R COLLECTION ~RACTICES.ACl THIS COMMUNICATION IS FROM A DEBT COLLECTOR. THIS IS AN ATTEMPT TO COLLECT A DEBT AND ANY INFORMATION OBTAINED WILL BE USED FOR THAT PURPOSE. <:-, "- . MATTLEMAN, WEINROTH & MILLER BY: SHARON ORAS MORGAN, ESQUIRE Attorney ID# 60068 Suite 2226 - Land Title Building Broad & Chestnut Streets Philadelphia, P A 19110 215/923-2225 Attorneys for Plaintiff CITIMORTGAGE, INC. F/K/A SOURCE ONE : COURT OF COMMON PLEAS MORTGAGE CORPORATION D/B/A CITICORP: CUMBERLAND COUNTY MORTGAGE, INC. Plaintiff vs. No.: 00-4657 CIVIL TERM TERRY L. RAUP, SR. Defendants PRAECIPE TO ENTER DEFAULT JUDGMENT TO THE PROTHONOTARY Kindly enter Default Judgment in favor of Plaintiff, Citimortgage, Inc., f7k/a Source One Mortgage Corporation d/b/a Citicorp Mortgage, Inc. and against Terry L. Raup, Sr. for failure to Answer the Complaint in Civil Action - Mortgage Foreclosure. Service was made on the Defendant, Terry L. Raup, Sf. by the Sheriff of Cumberland County as follows: 7/13/2000 via personal service '\,<,'"-,^,",' ~ .., ~ ~ Assess damages as follows: Principal and Interest $102,31 t 64 Interest from 6/26/2000 to 9/13/2000 1,491.52 Increase in Escrow Deficiency since 6/26/00 1,029.56 Increase in Late Charges since 6/26/00 93.4 5 Increase in Property Inspections since 6/26/00 14.00 Co~ n1.~ TOTAL AMOUNT OF JUDGMENT $ 105,171.73 MATTLEMAN, WEINROTH & MILLER BY: SHARON ORAS #60068 ^;,,~", -, '<-'- . . . MATTLEMAN, WEINROTH & MILLER BY: SHARON ORAS MORGAN, ESQUIRE Attorney ID #60068 Suite 2226 - Land Title Building Broad and Chestnut Streets Philadelphia, P A 19110 215/923-2225 Attorneys for Plaintiff CITIMORTGAGE, INC. F/KJA SOURCE ONE COURT OF COMMON PLEAS MORTGAGE CORPORATION D/B/A CITICORP: CUMBERLAND COUNTY MORTGAGE, INC. Plaintiff vs. No.: 00-4657 CIVIL TERM TERRYL. RAUP, SR. Defendants AFFIDAVIT OF ADDRESSES COMMONWEALTH OF PENNSYLVANIA: SS COUNTY OF CUMBERLAND: I, Sharon Oras Morglm, Esquire, being du1y sworn according to law, upon my oath, depose and say: 1, I certifY that the Plaintiff's address is 27555 Farmington Road, Farmington Hills, MI 48018; 2. I certify that the Defendant's address is as follows: 432 Pine Grove Road, Gardners, PA 17324. 3. I certify that the foregoing information is true and correct to the best of my knowledge, information and belief Sworn and SubscQQlld to MATTLEMAN, WEINROTH & MILLER beformue. his PP day o~ ~ ,2000. ~Wl1W 1'\'\0"'1"5 \.\51" I"l'll'l of l\EVlIEI\SE.'I O"'R'I9UllllC 12/'41200\ \'0\ 1'1'\ . '" n'lreS '5<:\00 t;Jly Comm\ - c-;v;, , ' _ ~1 MATTLEMAN, WEINROTH & MILLER BY: SHARON ORAS MORGAN, ESQUIRE Attorney ID # 60068 Suite 2226 - Land Title Building Broad and Chestnut Streets Philadelphia, PA 19110 Attorneys for Plaintiff CITIMORTGAGE, INC. FIK! A SOURCE ONE : COURT OF COMMON PLEAS MORTGAGE CORPORATION D/B/A CITICORP: CUMBERLAND COUNTY MORTGAGE, INC. Plaintiff vs, No.: 00-4657 CIVIL TERM TERRYL. RAUP, SR. Defendants AFFIDAVIT OF NON-MILITARY SERVICE COMMONWEALTH OF PENNSYLVANIA SS COUNTY OF CUMBERLAND I, Sharon Oras Morgan, Esquire, Attorney at Law, being duly sworn according to law, upon my oath, depose and say: 1. That the Defendants are not in the Military, Naval of Air Services of the United States of any other Country within the provision of the Soldiers' and Sailors' Civil Relief Action of Congress, as amended; and 2. That the Defendants are at least 21 years of age and reside at 432 Pine Grove Road, Gardners, PA 17324. ';'7"_ . ' ---, . M_~ The affiant has ascertained the foregoing information by persona inquiry and knowledge and makes this Affidavit with the authority. Sworn and SubscrjJ:lf.d to before e this Jf"'" day f 2000, \,>Oliop.S I>. I>.NN "'i \I~'II \~\l'i>t1 \..\$ o~\c \l~ I'~ I t'ijO\ ~~lIo . It \I\l1~\\ <,v"e' 'it\\S~\ot\ Co'" '~I""-"I ,~ MATTLEMAN, WEINROTH & MILLER BY: Sharon Oras Morgan, Esquire #60068 MATTLEMAN, WEINROTH & MILLER BY: SHARON ORAS MORGAN, ESQUIRE Attorney ill #60068 Suite 2226 - Land Title Building Broad and Chestnut Streets Philadelphia, P A 19110 215/923-2225 Attorneys for Plaintiff CITIMORTGAGE, INC. F/K/ A SOURCE ONE COURT OF COMMON PLEAS MORTGAGE CORPORATION D/B/A CITICORP: CUMBERLAND COUNTY MORTGAGE, INC. Plaintiff vs. No.: 00-4657 CIVIL TERM TERRY L. RAUP, SR. Defendants AFFIDAVIT OF SERVICE COMMONWEALTH OF PENNSYL VANIA SS COUNTY OF CUMBERLAND I, Sharon Oras Morgan, Esquire, Attorney at Law, being duly sworn according to law, upon my oath, depose and say: 1. I am a member of the firm of Mattie man, Weinroth & Miller, attorneys for Plaintiff in the above entitled cause of action. 2. I hereby certifY that a written notice of intention to file the Praecipe for Judgment, in accordance with Rule 237.1, was forwarded to the Defendant(s), place of residence by regular mail on August 21,2000 and has not been returned to this office, so it can be assumed that same has been delivered to Defendant. Sworn and Subscribed to . before' me this day L ,2000. haron Oras Morgan, Esquire 60068 ,.\-101<111-5 \.\51' p.l'll'l Of lit'll ltl\St'I 1I01~R~ PUBLIC. .l/",Z001 . . n t.y-p,res Comffi\SS\O . ~~ '.,. , -" .,- 1. - ~~: SHERIFF'S RETURN - REGUJJ" "'. LAd P5'-i'ysq CASE NO: 2000-04657 P COMMONWEALTH OF PENNSYLVANIA: COUNTY OF CUMBERLAND CITIMORTGAGE INC ET AL VS RAUP TERRY L SR DAVID MCKINNEY , Sheriff or Deputy Sheriff of Cumberland County, Pensylvania, who being duly sworn according to law, says, the within COMPLAINT - MORT FORE was served upon RAUP TERRY L the DEFENDANT , at 1012:00 HOURS, on the 13th day of July , 2000 at 432 PINE GROVE ROAD GARDNERS, PA 17324 by handing to TERRY L. RAUP SR. a true and attested copy of COMPLAINT - MORT FORE together with and at the same time directing His attention to the contents thereof. Sheriff's Costs: Docketing Service Affidavit Surcharge 18.00 8.06 .00 10.00 .00 36.06 So Answers: r~~ R. Thomas Kline 07/14/2000 MATTLEMAN WEINROTH & MILLER Sworn and Subscribed to before By: ~~-/$~~~ Deputy Sheriff . me this day of A.D. Prothonotary <;J , ,=~"~I..t, ~ ,~ Y'!W':"_ -"~ -', OFFICE OF THE PROTHONOTARY COURT OF COMMON PLEAS Prothonotary TO: Terry L. Raup, Sr. August 21, 2000 CITIMORTGAGE, INC. F/K/A SOURCE ONE MORTGAGE CORPORATION D/B/A CITICORP MORTGAGE, INC. Plaintiff COURT OF COMMON PLEAS CUMBERLAND COUNTY vs. No.: 00-4657 CIVIL TERM TERRYL. RAUP, SR. Defendant NOTICE., RULE 237.1 IMPORTANT NOTICE You are in default because you have failed to take action required of you in this case. Unless you act within ten (10) days from the date of this notice, a judgment may be entered against you without a hearing and you may lose your property or other important rights. You should take this notice to a lawyer at once. If you do not have a lawyer or cannot afford one, go to or telephone the following office to find out where you can get legal help. Court Administrator 4th floor, Cumberland County Courthouse Carlisle, PA 17013 (717) 240-6200 291/53809 NOTICE PURSUANT TO FAIR DEBT COLLECTION PRACTICES ACT. THIS COMMUNICATION IS FROM A DEBT COLLECTOR. THIS 1S AN ATTEMPT TO COLLECT A DEBT AND ANY INFORMATION OBTAINED WILL BE USED FOR THAT PURPOSE. "~,",'r--"1.".~,""",__ ""~ . . R~; . '!,,"..---P--' - t~ ~ ~ r () ~- ~ j :t ~ ~ fU .... W ~ rt () t-t- ~ ~ .~, ~ "!ilt~~~~~_l;lji~_ ~ !I!riMI'I~ ^ - -~ ~,.- ~~=<'< , . -~ . (') (:) 0 C (:) :c::- -n vO) en -' ~m r>1 f'h;g z'.1.' ." (I) t;: N TIITl -<"'''Y f'0 :,60 r:"'- f') 1 ~o -0 :~:j~? >' zC) ::Jl: ~~~ j;;O c: - GfD Z .. -.; =< C'" ~ f-v -< ,>T~~~ _ '. +,'W' . ~ ~ C',',.. W'.' 'iJ SHERIFF'S RETURN - REGULAR CASE NO: 2000-04657 P COMMONWEALTH OF PENNSYLVANIA: COUNTY OF CUMBERLAND CITIMORTGAGE INC ET AL , f- VS f* RAUP TERRY L SR , DAVID MCKINNEY Sheriff or Deputy Sheriff of Cumberland County, Pensyl vania , who being duly sworn according to law, says, the within COMPLAINT - MORT FORE was served upon RAUP TERRY L the DEFENDANT , at 1012:00 HOURS, on the 13th day of July , 2000 at 432 PINE GROVE ROAD GARDNERS, PA 17324 by handing to TERRY L. RAUP SR. a true and attested copy of COMPLAINT - MORT FORE together with I I"j and at the same time directing His attention to the contents thereof. Sheriff's Costs: Docketing Service Affidavit Surcharge So Answers: r~~ 18.00 8.06 .00 10.00 .00 36.06 R. Thomas Kline 07/14/2000 MATTLEMAN WEINROTH & MILLER Sworn and Subscribed to before By: ~~i$~ ~ Depu y Sherif ~ me this I~ day of ~~ ..)./TVO A.D. lk. 0_ In,,) P,. d ~< r thonotary I ", , ~ ~~,'~" -~,~ ~_ Y"'~' ~/,'- :- r .,~- '~~t. IN 'IHE CXJURT. OF (XMol)N PLE'AS OF aH3ERLI\ND CXXJNI'Y. PmNSYLVlINIA CIVIL DIVISION c...." 1: CitiMortgage, Inc., et al. vs. File No. 00-4657-CivU Arrount Due $105,171.73 Interest from 9/22/00 to 3/7/01 $2,887.43 Atty's Corrrn Costs Terry L. Raup, Sr. TO THE PROIHONOTARY OF THE SAID COURT: The undersigned hereby certifies that the below does not arise out of a retail installrrent sale, contract, or account based on a confession of judgment, but if it does, it is based on the appropriate original proceeding filed pursuant to Act 7 of. 1966 as amehded; arld for real property pursuant to Act 6 of 1974 as amended. PRAEX:IPE FOR EXECUTION Issue writ of execution in the above rratter to the Sheriff of Cumberland County, for debt, interest and costs upon the following described property of the defendant(s) 432 Pine Grove Road, Gardners, PA 17324 (See attached legal description) PRAEX:IPE FOR ATT1\CI-t1ENl' EXECUTION Issue writ of attachment to the Sheriff of County, for debt, interest and costs, as above. ,directing attachment qgainst the above-named' garnishee( s) for the following property (if real estate, supply six copies of the description; supply four copies of lengthy personalty list) and all other property of the defendant(s) in the possession, custody or control of the said garnishee(s). (Indicate) Index this writ against the garnishee( s) as a lis pendens against real estate of the defendant(s) described in the attached exhibit. ""E, "'''/00 ::'::, ~.q:~. Address: 100 S. Broad Street. Suite 2226 PhUadelph:.a, J'A 19110 Attorney for: CitiMortgage, Inc., et a1. Telephone: (215) 923-2225 Supreme Court ID No.: 60068 ~y,':(<:;'--' ,',~ '-> ',c_':n',,- ALL THAT CERTAIN lot ofland situate in the Township of Dickinson, County of Cumberland, and Commonwealth of Pennsylvania, being more particularly described as Lot No. 48 on a [mal subdivisioll of plan for Dickinson Township joint venture dated 11/4/83, revised 2/18/84, which said plan was duly entered ofrecord on March 1, 1984 and appearing of record in the Office of Recorder of Deeds in and for Cumberland County in plan Book 45, page 32, under and subject to all legal highways, easements, rights-of-way and restrictions of record. IMPROVEMENTS THEREON: a residential dwelling Parcel No.: 08-40-2641-024 -'O'!', '~-'- "'f:"'~~23;t,;;~:!F'~ - , XJ t g ~ tv JQ 8 0 'J ,(q. ~ ........ 0 "1'1 It ~...o Ir) f' "1 "tJ~ ;::, --{ & r'1 ..,.. , 8 CI , n1rn r-~;TI ~C' V) 0 n 0 Z::o -:o!? f' :z:c I --- ........ C"c 0 (j' 0 <:r.!.!O' c.n 2i _, <> ~ I rsz ..,"? , ~o :I> :,C..,.., -l::: bJ I ~o :x o~ ~ - 't-- [?OV 20 s> 4~ Pc 0 ~ r- :z: :;;} -0 - " ~r ~ ':Jl ~ " - ~ ~ 0,)' U\:J~ , ~ ~-c. , I II I ':'Ii ,- , ~~..,...........- _~.,...,l~_~ ~_mlll~~~~""!fI'W\1""_~<!l!lIM!lIl!'!fX__W~" ~I'!\i!"_ ~ " ., -" u f~!!~!n'~~-"'.(-"'~ '0 .'_ ~_" , MATTLEMAN, WEINROTH & MILLER BY: SHARON ORAS MORGAN, ESQUIRE SUITE 2226 - LAND TITLE BUILDING BROAD & CHESTNUT STREETS PHILADELPHlA,PAI9110 215/923-2225 Attorneys for Plaintiff CITIMORTGAGE, INC. F/KIA SOURCE ONE MORTGAGE CORPORATION DIB/ AI CITICORP MORTGAGE, INC. Plaintiff COURT OF COMMON PLEAS CUMBERLAND COUNTY vs. NO.: 00-4657-CIVIL TERRY L. RAUP, SR. Defendant AFFIDAVIT PURSUANT TO RULE 3129.1 COMMONWEALTH OF PENNSYLVANIA COUNTY OF PIDLADELPIllA CitiMortgage, Inc. flkla Source One Mortgage Corporation d/b/a CitiCorp Mortgage, Inc., Plaintiff in the above entitled cause of action, sets forth as of the date the Praecipe for Writ of Execution was fIled the following information concerning the real property located at 432 Pine Grove Road, Gardners, P A 17324: 1. Name and address of Owner(s) or Reputed Owner(s): Terry L. Raup, Sr. 432 Pine Grove Road Gardners, PA 17324 2. Name and address of Defendant(s) in the Judgment: Terry L. Raup, Sr. 432 Pine Grove Road Gardners, P A 17324 I. , -, , -~ ., 3. Name and address of every judgment creditor whose judgment is a record lien on the real property to be sold: CitiMortgage, Inc. f/kla Source One Mortgage Corporation d/b/a CitiCorp Mortgage, Inc. (plaintiff herein) 27555 Farmington Road Farmington Hills, MI 48018 Child Support Enforcement Agency 1 Courthouse Square Carlisle, PA 17013-3387 4. Name and address of the last recorded holder of every mortgage of record: CitiMortgage, Inc. f/kla Source One Mortgage Corporation d/b/a CitiCorp Mortgage, Inc.. (plaintiff herein) 27555 Farmington Road Farmington Hills, MI 48018 5. Name and address of every other person who has any record lien on the property: None known. 6. Name and address of every other person who has any record interest in the property and whose interest may be affected by the sale: Occupant, 432 Pine Grove Road Gardners, P A 17324 7. Name and address of every person of whom the plaintiff has knowledge who has any interest in the property which may be affected by the sale: Occupant, 432 Pine Grove Road Gardners, P A 17324 , -~",~,~<~ .., .:"..~,,'C::::.: 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. .~~, SHARON ORAS MOR , ESQUIRE #60068 Sworn and Subscribed to before me this~ -#I day of Oc;tClDtr 2000. ~~~ JUDITH ANN HITCHNER A Notary Public of New Jersey My Commission Expires 6/25/2001 ~,- '''---~ ~ tBk\i:ml,u~%'~~,,~ r;~ ! i .1 II I! Ii I Ii 1..1 fi. ~f -, - ~- ~ , ~." ~.,..,~.~ 0 g 0 C ~. --n <::7 -oUl M .-1 rTlrn T; ~;:{) n rn:D I -n,in (f,S: c.n :dy --<2 ,'") t;: c; ;0. .:::t.{J ~O =l:,"7J 3 { ):0 >0 ':? -~-O Lm c:: 0 :z: ?5 =< (.11 (,.} -< ,.~~li]~'lJ.Nl~11'l!Wl~~1'!IIra,_,<>.~,",,>~,~ ,~!'l1~I~ -, NOTICE OF SHERIFF'S SALE OF REAL PROPERTY TO: ALL PARTIES IN INTEREST AND CLAIMANTS OWNER(S): TERRYL. RAUP, SR. PLAINTIFF/SELLER: CITIMORTGAGE, INC. FIK/A SOURCE ONE MORTGAGE CORPORATION D/B/A CITICORP MORTGAGE, INC. DEFENDANT(S): TERRY L. RAUP, SR. PROPERTY: 432 PINE GROVE ROAD GARDNERS, PA 17324 NO. :00-4657 -CIVIL The above captioned property is scheduled to be sold at Sheriffs Sale on March 7, 2001 at 10:00 am in the Cumberland County Courthouse, South Hanover Street, Carlisle, P A 17013 . You may hold a mortgage or judgment on the property which will be extinguished by the sale. You may wish to attend the sale to protect your interest. A schedule of distribution will be filed by the Sheriff on a date specified by the Sheriff not late than 30 days after sale. Distribution will be made in accordance with the schedule unless exceptions are filed thereto within 10 days after the filing of the schedule. Sincerely, Sharon Oras Morgan, E~ MATTLEMAN, WEINROTH & MILLER Suite 2226 - Land Title Building Broad & Chestnut Streets Philadelphia, PA 19110 215/923-2225 291/54354 -'.l~" ~_ ." -, -- . . ~ "~ .,.:1 . l!!!lJ.;" ..h __'"'" ." ~~ ",'. ,_,Co, "",' ~~" 0 0 0 c:: 0 "tJ~ .., <::7 --, !pFfi ,"", <;riFQ n z::O , w!i: \1-f'ri ;::;;:z' <;"'1 :l10 '-'~l ) .-0 ':::'j'C) ~ ~ ~,~". 'T" 2:0 ...A ;..,:ri 5>-0 9 2,0 c:: I~m ~ t..'1 ?5 eA> -< ,~~., w~~l!llJ!'WM~f!~~~~~I!l!!''''~~1II ,. " ~.",' - .,. MATTLEMAN, WEINROTH & MILLER BY: SHARON ORAS MORGAN, ESQUIRE Attorney ill #60068 Suite 2226 - Land Title Building Broad & Chestnut Streets Philadelphia, P A 19110 (215) 923-2225 Attorneys for Plaintiff CITIMORTGAGE, INC. F/K/A SOURCE ONE MORTGAGE CORPORATION D/B/A CITICORP MORTGAGE, INC. Plaintiff COURT OF COMMON PLEAS CUMBERLAND COUNTY vs. NO.: 00-4657-CIVIL TERRY L. RAUP, SR. Defendant :NOTICE OF SHERIFF'S SALE OF :REAL PROPERTY :PURSUANT :TO PENNSYL V ANlA RULE OF :CML PROCEDURE 3129 TAKE NOTICE: Your house (real estate) at 432 Pine Grove Road, Gardners, PA 17324 is scheduled to be sold at Sheriffs Sale on March 7,2001 at 10:00 am in Cumberland County Courthouse, South Hanover Street, Carlisle, PA 17013 to enforce the Court Judgment of $105,171.73 obtained by CitiMortgage, Inc. flkla Source One Mortgage Corporation d/b/a CitiCorp Mortgage, Inc. 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 Sharon Oras Morgan, Attorney for Plaintiff, back payments, late charges, costs and reasonable attorneys fees due. To fmd out how much you must pay, you may call Sharon Oras Morgan at 215-923-2225. 2. You may be able to stop the Sale by filing a petition asking the court to strike or open the Judgment, if the Judgment was improperly entered. You may also ask the Court to postpone the Sale for good cause. 3. You may also be able to stop the Sale through other legal proceedings. You may need an attorney to assert your rights. The sooner you contact one, the more i-"!-,!_",~ " __~e ,~_ .., - ,"'. - - ~~,,' , j\",,.,. .f" -. ~, . chance you will have of stopping the Sale. (See Notice below and how to obtain an attorney). YOU MAY STILL BE ABLE TO SAVE YOUR PROPERTY AND YOU HAVE OTHER RIGHTS EVEN IF THE SHERIFF'S SALE DOES TAKE PLACE. l. If the Sheriffs Sale is not stopped, your property will be sold to the highest bidder. You may (rod out the bid price by calling Sharon Oras Morgan at 215-923-2225. 2. You may be able to petition the Court to set aside the Sale if the bid price was grossly inadequate compared to the market value of your property. 3. The Sale will go through only if the Buyer pays the Sheriff the full amount due on the Sale. To frod out if this has happened you may call Sharon Oras Morgan at 215-923-2225. 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 on April 6, 2001. 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. 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 TIDS PAPER TO YOU 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. Cumberland County Court Administrator 4th Floor Cumberland County Courthouse Carlisle, P A 17013 1-717-240-6200 291/54354 , i: Ii I' ii :i I: ,I I: Ii II Ii I I' I II ," ~~ ~_.~ - , IlJiII!!lm~~ 'II, ,,^ '., ~~ " . " (') C) 0 c: 0 -n <: 0 "'Ow "..1 M :1:" rnr'rl: ("") Z,:J:J i .~ '1 p:::. z;;; I :'i1p ~Z ,n --.) 0 !<'C :l:>> :;l'i ~o ::lI: ~~ >8 ':? ~ ~ Ul ~ W " ~l1!lll!ilM!J!ll!lQ""""~'"~~"""lWl"~'l~i~l"'tJ'f-;.]I\Ill'~'!~~i!l'lIlI!1iliW:l!f1l'i~",,,",JllI!II!I~~PI/l!III!Jlil:Il~ ""'''''..- 'ii, '"',_ . , , Citimortgage, Inc. -vs- In The Court of Common Pleas of Cumberland County, Pennsylvania No.2000-4657Civil Terry L. Raup, Sr. R. Thomas Kline, Sheriff, who being duly sworn according to law, says this writ is returned STAYED. Sheriff s Costs: Docketing Poundage Posting Bills Advertising Law Library County Levy Postpone Sale Surcharge Certified mail Mileage Law Journal Patriot News Out of County Share of Bills 30.00 7.63 15.00 15.00 .50 1.00 15.00 20.00 20.00 2.30 6.20 167.75 88.66 25.53 $412.57 Pd by atty 02/27/01 Sworn and subscribed to before me r~l~-<'~ R. Thomas Kline, Sheriff This .:)'i..- day of d.&-... A'"} 200<1, A.D. 9:r' a))", pp; ,~ r thonotary ByPJ_<<.Al~ Real Estate Deputy ~ . r J,6D cJv 3 }:5&) ~ )/)fj).33 ".~ Oi/--- '--U'.'~,'_"',';'" "~1':",.~\,,,. ,'~,,:~-';", ~"". ,.:-;~,,-,,- " "'-,',," -,'->"',,:"'.'" -'. ,. ,,,,,,:""'~~:,,'1",,,,,,-;,,""-'" '--"""-"'''''''''~''~'''''-'~,'''''''';.-'''''1'"'''-'''':f~-'0'__."c'," ~"""'"'''_'f ""'1'-,~;"'~';"'W~,~",~",(~",\,,.J,"'-',~\;;,,,,....,,.'~"''''i\\",-~~:"'''.o;~'~\!,,,;J1'''',''1'~-''~''''~~'" , . .. MATTLEMAN, WEINROTH & MILLER BY: SHARON ORAS MORGAN, ESQUIRE SUITE 2226 - LAND TITLE BUILDING BROAD & CHESTNUT STREETS PHILADELPHIA, PA 19110 215/923-2225 Attorneys for Plaintiff CITIMORTGAGE, INC. FIK/A SOURCE ONE MORTGAGE CORPORATION D/B/ AI CITICORP MORTGAGE, INC. Plaintiff COURT OF COMMON PLEAS CUMBERLAND COUNTY vs. NO.: 00-4657-CIVIL TERRY L. RAUP, SR. Defendant AFFIDAVIT PURSUANT TO RULE 3129.1 COMMONWEALTH OF PENNSYLV ANlA COUNTY OF PHILADELPHIA CitiMortgage, Ine. fIkIa Source One Mortgage Corporation d/b/a CitiCorp Mortgage, Ine., Plaintiff in the above entitled cause of action, sets forth as of the date the Praecipe for Writ of Execution was filed the following information concerning the real property located at 432 Pine Grove Road, Gardners, PA 17324: 1. Name and address of Owner(s) or Reputed Owner(s): Terry L. Raup, Sr. 432 Pine Grove Road Gardners, P A 17324 2. Name and address of Defendant(s) in the Judgment: Terry L. Raup, Sr. 432 Pine Grove Road Gardners, P A 17324 --:'1IIOJ!'Ii!'"~[I",IJ-r.~~",,,~iffiF~i,wj:~"~n'~ff-9"'4;"?fl''l{!1'~*l~I1l'f'I'''i!i<lrTIi~riljf!i">~~~"''U!')m!wim!;(1F~R''iIH':/IIl''#'''~~~~'''''''iffij~~~~, ~:R ,-' '~-': . . ",~m""""~'ffl",,~hl'1~~~~'~'ro'iW''1i~';'"!~;_''''f,in1'"''J-;''''''i"--''':'''''n''W';';'i'':1'''''''~!I-'';'!'-'' !!I 1-". ,',m'.~"?^'~",,_' "";,~~,W~~:;">>,,>o';;:.:'~t'i.,)( J.""~'~ :~~' ., ;;;.:.' ,~" _,-,'~, ,', 1 ',:- .- ':'_'I"':" ','," .,;;,-,:%",~;.:,~,,:,;o,,_:"" - .,'., "(:_,'-iJt~ ,,'.:,i~1'*;:2;.- 1",.'_cV'<(JJ:;;.'f':'f. ':"-" :'-'A',"~\',,'~ '"' ,,~,'/;' :'''''";''~'';'''~_?~'','':\''<"'~~'!-;':.~~':>t,,,.,~',"'~i-1i1' -'-'ft!~':'" ~Y'1,-!;ll"'il.@J;'{W,<ij:;':"'~<;1j;"i" '. 3. Name and address of every judgment creditor whose judgment is a record lien on the real property to be sold: CitiMortgage, Inc. flkla Source One Mortgage Corporation d/b/a CitiCorp Mortgage, Inc. (plaintiff herein) 27555 Farmington Road Farmington Hills, MI 48018 Child Support Enforcement Agency 1 Courthouse Square Carlisle, PA 17013-3387 4. Name and address of the last recorded holder of every mortgage of record: CitiMortgage, Inc. flkla Source One Mortgage Corporation d/b/a CitiCorp Mortgage, Inc.. (plaintiff herein) 27555 Farmington Road Farmington Hills, MI 48018 5. Name and address of every other person who has any record lien on the property: None known. 6. Name and address of every other person who has any record interest in the property and whose interest may be affected by the sale: Occupant, 432 Pine Grove Road Gardners, P A 17324 7. Name and address of every person of whom the plaintiff has knowledge who has any interest in the property which may be affected by the sale: Occupant, 432 Pine Grove Road Gardners, P A 17324 , , - ". - ' -, '. . , ,". - , - - . - . . , . , ,- ," -- ,..., '--lqW~~[l)O"I'''''!"'IJliW'II!\$III!lI1i'II~r&l'~li!l~f~'IJ~i;I'''I'R'::J'Fo%<~'ill'~11I!IIWl'im'l1n'11f1'W!;~fl1W;;ojlj]lfflI'l~~~I'i!"1';~;<ffflj~,_ ~__n:J!~ _~"'~~~,.,.,"""""'..'" """''''''"''''tf<I'~'mlF!i'E''lr:ci-~i!IU'"''~'''>"'"'''~''''''1I~~''1'''''":'''..-'':';4 -""'~""""-""";' """'L it,,' ,"I;' "'i',L,~,,,'t'f<l::l>f~;:;,~,.....--,">-:'4";',[*"'..l>:L"'i:'li'_:,.h;;,#~,_~.',,.'1',<-."1-;,-"",,, ;, " _C_,__ ,,1 '''\ "."-"';:-'8,"'- . '., "'.','-,,>," " """'",'<1-"-1"';".' "",\::r c_, "",,,"'f:-:,:t<! _1o,~,-' ,)c','~;~' 7'<'\- ,:~+\;:~",~<",-"~"'-'C)'l"~?,,_>::C'r,;'''-1,,,., c' '_'('-_">'-"'-.1 ,-' , .'i, . .. 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. ~4> . SHARON ORAS MOR , ESQUIRE #60068 Sworn and Subscribed to before methis;}U-fl1 day of Odilb.t...- 2000. ~ fiJH-mhU-t JUDITH ANN HITCHNER A Notary Public 01 New Jersey My Commission Expires 6/25/2001 !';;'~~W;"lf'j1r'I'Iff1ffil"'f';l"lf!r'!~h!IP'!f1jrr!""C-"fM!'l1$I!~"i!W'~~lIl"Ill\!i:~~~J_~~"~'~,'>rl'''''m~ . " ," ~ ~ ,~='" .N~~,''''''''' '~'1 """~"" "~"'~""'''''''''1'''~':'''''''''Pf~'''''-' ,"'" ~;~~""l'"'"1,':'~""'r"'''<:~["' /iF" . "-;,'f :~c;-F' :.'_(.1tt;,'';;;4<,,",nf.--;<<~<,\'l!',AI,~r,~I~__'<--;'_o,.,.''l'''r'''*'!l''',,<~iI";",:>r-';}~,rf"'!<'.v",_ff<;,--'-,,,"'''''''_~,,:,.... _",~",:~,,'J'1:'!"-::lIW'~f.:'''''!''"'7' ,',:e--'l"""'''?-''''''~ ",-~~~',~",~_'''':Xl~~~'''''';'iil:'''''!I!o/"''''''' ~,'~'---r}'~"f~'''Q'''.'(:-,,,.,c,,,,~;~,o-'~r":'-'---''''''7-::''" . '~ .. MATTLEMAN, WEINROTH & MILLER BY: SHARONORAS MORGAN, ESQUIRE Attorney ill #60068 Suite 2226 - Land Title Building Broad & Chestnut Streets Philadelphia, P A 19110 (215) 923-2225 Attorneys for Plaintiff CITIMORTGAGE, INC. FIK/A SOURCE ONE MORTGAGE CORPORATION D/B/A CmCORP MORTGAGE, INC. Plaintiff COURT OF COMMON PLEAS CUMBERLAND COUNTY vs. NO.: 00-4657-CIVIL TERRYL. RAUP, SR. Defendant :NOTICE OF SHERIFF'S SALE OF :REAL PROPERTY :PURSUANT :TO PENNSYL V ANlA RULE OF :CIVIL PROCEDURE 3129 TAKE NOTICE: Your house (real estate) at 432 Pine Grove Road, Gardners, PA 17324 is scheduled to be sold at Sheriffs Sale on March 7, 2001 at 10:00 am in Cumberland County Courthouse, South Hanover Street, Carlisle, P A 17013 to enforce the Court Judgment of $105,171.73 obtained by CitiMortgage, Inc. f/kIa Source One Mortgage Corporation d/b/a CitiCorp Mortgage, Inc. NOTICE OF OWNER'S RIGHTS YOU MAY BE ABLE TO PREVENT THIS SHERIFF'S SALE To prevent this Sheriff's Sale you must take immediate action: 1. The Sale will be cancelled if you pay to Sharon Oras Morgan, Attorney for Plaintiff, . back payments, late charges, costs and reasonable attorneys fees due. To fmd out how much you must pay, you may call Sharon Oras Morgan at 215-923-2225. 2. You may be able to stop the Sale by filing a petition asking the court to strike or open the Judglnent, if the Judgment was improperly entered. You may also ask the Court to postpone the Sale for good cause. 3 . You may also be able to stop the Sale through other l~gal proce~dings. . .... . Y oumayneed an attorney to assert your rights. The sooner youconiact one, the more . . , ';;'E;fII'!~~IWrn'.I":c:mIm11f'11"'rr':"'!1l,"1U",:;; ~1'I'1",,-'p;I"rr'!""'iI'T"'~iHiEl1'1'" 'f1{f ,-n,- ''''''J''''' '-',':C""i;,~' ;'-<'~" ;_c:+:"-:;7~ -"'_0-'_""-.X:c~:",;'.-"",:".:c~1'-e"_'!-;-"',:J.":;;",;::"i~i,'~"Y~",-i!*-m+,'r-.l:"";f'4'!I'.'}:;,r~~_~\,~~n~.:."",~.,~~",\"~,~~~,,,,,~}~('fff;~"'=''''''''c",:.i~'f'~.,: ","'W:' ,:",:,,'t$l7'?'f-";'~" '!"?'~*_~'~'''T*'~>''''\,,'i7r,~"';':;':::''<' "~ "'. .. chance you will have of stopping the Sale. (See Notice below and how to obtain an attorney). YOU MAY STILL BE ABLE TO SAVE YOUR PROPERTY AND YOU HAVE OTHER RIGHTS EVEN IF THE SHERIFF'S SALE DOES TAKE PLACE. 1. If the Sheriff s Sale is not stopped, your property will be sold to the highest bidder. You may find out the bid price by calling Sharon Oras Morg~ at 215-923-2225. 2. You may be able to petition the Court to set aside the Sale if the bid price was grossly inadequate compared to the market value of your property. 3. The Sale will go through only if the Buyer pays the Sheriff the full amount due on the Sale. To fmd out if this has happened you may call Sharon Oras Morgan at 215-923-2225. . 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 on April 6, 2001. 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. . 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 TIllS PAPER TO YOU 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. Cumberland County Court Ailm;n;~trator 4th Floor Cumberland County Courthouse Carlisle, PA 17013 . 1-717-240-6200 291/54354 , .' -, . - - , ," , ' . H'11!~~"r""1!1'lPiRi~:",!';U';j1"lI"JIt'!~':1~1~!:Ti'I'1l'>~iB'!'ffi!WJ'liY_'''9"'~!"lflf'lf"W~)!f'W~~~I;liI<r",,!i"'W)V"i~"lC'1i[O'l'!i'i1!Jil!lI",,"'iI'Wl~~~I!.fi!!l1't!"!"""~l'~"''iI!!iffIl'ffll'ill~'W'ffl!ll\~~i!WIflff!IJ",^'!lFWllf)fl~'!!'\'1i'-*'1i'!FIl>'''~'''''1'''''~:'';f''''.",,",""-i, ''''''-''''"''''''''''''1. ":,,,,'.~!'-""-"_ . . WRIT OF EXECUTION and/or ATTACHMENT COMMONWEALTH OF PENNSYLVANIA) COUNTY OF CUMBERLAND) NO. 00-4657 CIVIL TERm CIVIL ACTION - LAW TO THE SHERIFF OF Cumberland COUNTY: CitiMortgage, Inc. To satisfy the debt, interest and costs due PLAINTIFF(S) from Terry L. Raup, Sr., 432 pine Grove Road, Gardners, PA 17324 (1) You are directed to levy upon the property of the defendant(s) and to sell DEFENDANT(S) See Legal Description (2) You are also directed to attach the property of the defendant(s)' not levied upon il) the possession of :,.':,~~;,~:'; "."''''.- :-'~-:r-"< ,.,,:'.:'t'.:,': GARNISHEE(S) as follows: , ,'",~,. ; ,~#;;:,,;.~ ' :"" and to iiOmy the garnishee(s) that: (a) an attachment has been issued; (b) the garnishee(s) is/are enjoined from paying any debt to or for the account of the defendant(s) and from delivering any property of the defend1!f1I(s):pr"otherwise disposing thereof; (3) If property ofthe defendant(s) noUeviedupon an subjectto attachment iSfoUrd !'1the possession of anyone other than a named garnishee, you are directed to notifyhim/herthat he/she has been addedas3garhiSfl1le and is enjoined as above stated. Amount Due $1 O'i, 171 .71 Interest from 9/22/00 to 3/7/01 - $2.887.43 L.L. Due Prothy Other Costs $.50 $1. 00 AllY'S Comm Ally Paid Plain,", Paid % $108.06 Date: December 5, 2000 Curtis R. Long Prothonotary, Civil Division U-W.-"L, p. 7p0Z/'~1 ) h\l.:. REQUESTING PARTY: Deputy Name Sharon Oras Morqan, Esq. Address: 100 S. Broad Street, Suite 2226 Philadelphia. PA 19110 Attorney for: Plaintiff Telephone: ?1 'i-Q?l-???'i Supreme Court ID No. 60068 \. ...:,,," , " -/":: REAL ESTATE SALE No.. /5 ," ~ 7, ~ the sheriff levied UP<<Ul too defendant::> interest in the real property situated inJa~t--1.rY:'" ~..~.&jJ:~ Cumberland County, Pa, known and numbered as:4".>.2;2:p t.~ ~A2.0~ and more ful"oscribed on Exhibit "A" filed with this writ and by this reference incorporated herein. ,...e:lJ,.~-iJ~ {?~ ~~~ Vtlt~^l^ SNIHJJ 31S11H'ta DO. HV EI" 9 330 . MJlflfi'l.'.'''\'.'.. . iIIJIj ... ' ,," I d 'a I'I6a liS MffJ.JO"U18D ;']" ~ .~~~."~~!'!' _"""'" '~~', ~_'IliJ~~~I~1.rp;~.~~UJ,~I\IIQ,,",~ ~~ , . ,~ ,~, ,~~ ,l e1 c:;a I:ViJ c::::.=I ~ ffi~~~~",,_