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Home My WebLink About00-04874 :""""" ~-' " " - ~~ ' _I.", - '~ ~11; " GOLDBECK McCAFFERTY BY: Joseph A. Goldbeck, Attorney r.D.#16132 Suite 500 - The Bourse Bldg. 111 S. Independence Mall East Philadelphia, PA 19106 215-627-1322 Attorney for Plaintiff & McKEEVER Jr. FIRST NATIONWIDE MORTGAGE CORP. PO Box 9481 Mail Code: 22-528-1011 Gaithersburg, MD 20898-9481 Plaintiff IN THE COURT OF COMMON PLEAS OF CUMBERLAND COUNTY CIVIL ACTION - LAW vs. :ACTION OF MORTGAGE Ridge #591 Carlisle, PA 17013 Defendant(s) Term No. 00 -4P7y ACTION' MORTGAGE CIVIL . FORECLOSURE FORECLOSURE I au,c~ I ROBERT H. CULLEY, A/K/A ROBERT H. CULLEY JR. (Mortgagor(s) and Real Owner(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 You have been sued in court. If you wish to defend against the claims set forth in the following pages, you must take action within twenty (20) days after the Complaint and notice are served, by entering a written appearance personally or by attorney and filing in writing with the court your defenses or objections to the claims set forth against you. You are warned that if you fail to do so the case may proceed without you and a judgment may be entered against you by the Court without further notice for any money claimed in the Complaint or for any other claim or relief requested by the Plaintiff. You may lose money or property or other rights important to you. YOU SHOULD TAKE THIS PAPER TO YOUR LAWYER AT ONCE. IF YOU DO NOT HAVE A LAWYER OR CANNOT AFFORD ONE, GO TO OR TELEPHONE THE OFFICE SET FORTH BELOW TO FIND OUT WHERE YOU CAN GET LEGAL HELP. Cumberland County Bar Association 2 Liberty Avenue, Carlisle, PA (800) 990-9108 Legal Services Inc. 8 Irvine Row, Carlisle, PA 17013 (717) 243-9400 A V ISO LE HAN DEMANDADO A USTED EN LA CORTE. SI DESEA DEFENDERSE CONTRA LAS QUEJAS PERESENTADAS, ES ABSOLUTAMENTE NECESSARIO QUE USTED RESPONDA DENTRO DE 20 DIAS DESPUES DE SER SERVIDO CON ESTA DEMANDA Y AVISO. PARA DEFENDERSE ~S NECESSARIa QUE USTED, 0 SU ABOGADO, REGISTRE CON LA CORTE EN FORMA ESCRITA, EL PUNTa DE VISTA DE USTED Y CUALQUIER OBJECCION CONTRA LAS QUEJAS EN ESTA DEMANDA. RECUERDr.: SI USTED NO REPONDE A ESTA DEMANDA, SE PUEDE PROSEGUIR CON EL PROCESO SIN SU PARTICIPACION. ENTONCES, LA CoU1'E PUEDE, SIN NOTIFICARIO, DECIDIR A FAVOR DEL DEMANDANTE Y REQUERlRA QUE USTED CUMPLA CON TODAS LAS PROVISIONES DE E8TA DEMANDA. POR RAZON DE ESA DECISION, ES POSSIBLE QUE USTED PUEDA PERDER DINERO, PROPIEDAD U OTROS DERECHOS IMPORTANTES. LLEVE ESTA DEMANDA A UN ABOGADO IMMEDIATAMENTE. 81 NO CClNDCE A UN ABOGADO, LLAME AL "LAWYER REFERENCE SERVICEll (SERVICIO DE REFERENCIA DE ABOGAD08), 215-238-6300. Cumberland County Bar Association 2 Liberty Avenue, Carlisle, PA (800) 990-9108 Legal services Inc. 8 Irvine Row, Carlisle, PA 17013 (717) 243-9400 " ~'~~', " ',^,' -- ~,~ ~..,~~ ,"-~,,',. F:! COMPLAINT IN MORTGAGE FORECLOSURE 1. Plaintiff is FIRST NATIONWIDE MORTGAGE CORP., PO Box 9481, Mail Code: 22-528-1011, Gaithersburg, MD 20898-9481. 2. The name(sl and address (es) of the Defendant(sl is/are ROBERT H. CULLEY, A/K/A ROBERT H. CULLEY JR., 375 Longs Gap Road, Carlisle, PA 17013, who is/are the mortgagor(s) and real owner(s) of the mortgaged property hereinafter described. 3. On October 19,1990, mortgagor(s) made, executed and delivered a mortgage upon the premises hereinafter described to THE COMMONWEALTH NATIONAL BANK, which mortgage is recorded in the Office of the Recorder of Deeds of Cumberland County in Mortgage Book 994, Page 399. By Assignment of Mortgage, the mortgage was assigned to Plaintiff, which Assignment is lodged for recording. 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 payments of principal and interest upon said mortgage due December 1, 1999, 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 11/ 1/99 through 6/30/00 at 8.000% Per diem interest rate at $3.50 Reasonable Attorney's Fee Late Charges 12/ 1/99- 6/30/00 Monthly late charge amount at $19.72 Costs of suit and Title Search $ 15,751. 18 850.50 1,000.00 138.04 560.00 Escrow Balance Deficit Monthly Escrow amount $ $ 18,299.72 189.66 $ 18,489.38 7. The Attorney's Fees set forth above are in conformity with the Mortgage documents and Pennsylvania law, and, will be collected in the event of a third party purchaser at Sheriff's Sale. If the Mortgage is reinstated prior to the Sale reasonable Attorney's Fees will be charged based on work actually performed. , . "" '" ." "~,oi 8. Notice of Intention 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) has/have 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 the sum of $18,489.38, together with interest at the rate of $3.50, 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 of the mortga ed premises. By: GOLDBECK M McKEEVER BY: Joseph A. Goldbec , Jr., Esq. Attorney for Plaintiff J ,~ ...,. "'~' ~'1F~i~.I<ii;," JUN 03 '00 12:13PM P.4/5 VERIFICATION I, as the representative of the Plaintiff corporation within named do hereby verify that I am authorized to and do make t:his 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 16 Pa. C,S. 4904 relating to unsworn falsification to authorities. Date: -;-, /r7D #6838314487 - CULLEY,ROEERT H. "'- ,.. ~ "'-. .., , ""'I6i1iii~",' ~- ' . ..... ..l ~,Il '. ~ -: : Date Request Received: ~ ' EXHmIT "A" First Nationwide M5fe File #00-13-5450 Borrower ,.. Joseph A. Goldbeck, Jr #: FN-0076 Prop }ll.that ce~tain txact of land situate in North Middleton Township, Cumberland County, Peuuaylvania, bounded and described as follows: BEGINNING at a point (an iron pin) in tbe center of ,State Highway Route 12l0n; al.o knOWl1 as the "Long'a Gap Road"; thence along other lands now or formerly of Abram N. Lehman. et ux" the following , cour.es and cI!.tances: North ,76 degree a 58 minutes Edt 221.3 feet , to an iron pin; thence South 10 degrees 58 1IIinute. Eaat. 155 teee to a post on .the line of property now or formerly of John Hays Estate (said property line being the southern aide of a lane); tbence along the southern side of said lane, South 64 degrees 51 udnutes West 221.3 feet to' a point in the center of said Long' 8 Gap Road; thence along , the center of the said Long's Gap ~oad, North 16 degrees 25 minutes West ~75 feet to an iron pin, the place of BEGINNING. COifIAIHING .83 of an acre. [ !{ i., "; 'h i:~ ,,~'" ~. - ~-~ ~ ~"~ 1 _!IO!l<:~~II;jIiWlll~J!_ii c . . 1ST ", NATIONWIDE MORTGAGE ql~ n~ L/r% P,O, Box 9481 Gaithersburg, MO 2089B-9481 February 24, 2000 Certified Mail ROBERT H CULLEY 375 LONGS GAP ROAD CARLISLE, PA 17013-8554 EXHIBIT A RE: Loan Number 6838314487 Dear Mortgagor: ACT 91 NOTICE TAKE ACTION TO SAVE YOUR HOME FROM FORECLOSURE This is an official notice that the mortgage on vour home is in default. and the lender intends to foreclose. Snecific information about the nature of the default is provided in the attached Dages. The HOMEOWNER'S MORTGAGE ASSISTANCE PROGRAM (REMAP) may be able to helD to save your home. This notice eXDlains how the Drogram works. To see ifHEMAJ> can helD. vou 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 agencv. The name. address. and phone number of the Consumer Credit Counselin~ Agencies serving your County are listed at the end of this Notice. Ifvou have anv questions. vou mav call the Pennsylvania Housing Finance Agency toll free at 1-800-342-2397. (Persons with imDaired hearing can call 717-780-1869.) This Notice contains important legal information. Jfyou 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. 5280 Corporate Drive. Frederick, MD 21703 .:.~'- ::""'- '-.!IlI . ~~ ~ -, b. ~-=""'--1il~til;,.0.7, o o ,.1ST , NATIONWIDE , MORTGAGE ~~i~m '~~Q~~g4ql Loan No:"68J8314487 Page 2 PA Act 91 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 lIamanda esta agencia (pennsylvania Housing Finance Agency) sin cargos al numero mencionada arriba. Puedes ser elegible para un prestamo por el programa lIamado "Homeowner's Emergency Mortgage Assistance Program" el cual puede salvar su casa de la perdida del derecho a redimir su hipoteca. Date: February 24, 2000 Homeowner's Name: ROBERT H CULLEY Property Address: RIDGE # 591 CARLISLE, P A 17013 Loan Account Number: 6838314487 Original Lender: THE LOMAS & NETTLETON CO. Current Lender/Servicer: First Nationwide Mortgage Corporation HOMEOWNERS' EMERGENCY MORTGAGE ASSISTANCE PROGRAM YOU MAY BE ELIGIBLE FOR FINANCIAL ASSISTANCE WHICH CAN SAVE YOUR HOME FROM FORECLOSURE AND HELP YOU MAKE FUTURE MORTGAGRPAYMENTS IF YOU COMPLY WITH THE PROVISIONS OF THE HOMEOWNERS' EMERGENCY MORTGAGE ASSISTANCE ACT OF 1983 (THE "ACT"), YOU MAY BE ELIGIBLE FOR EMERGENCY 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 toa temporary stay offoreclosure 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 of the designated consumer credit counseling agencies listed at the end of this Notice. 5280 Corporate Drive, Frederick, MD 21703 !II- _:!fi,. ~~ """"""~"""""~"_,",,'1<.,"idiw\G2''',. o o . 1ST " NATIONWIDE MORTGAGE F~_, U~~~Ql;hl Loan No. 6838314487 Page 3 PA Act 91 THIS MEETING MUST OCCUR WITHIN THE NEXT (30) DAYS. IF YOU DO NOT APPLY FOREMERGENCY MORTGAGE ASSISTANCE. YOU MUST BRING YOUR MORTGAGE TO DATE. THE PART OF THIS NOTICE CALLED "HOW TO CURE YOUR MORTGAGE DEFAULT." EXPLAINS HOWTO 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 the designated consumer credit counseling agencies for county in which the propertY is located are set forth at the end of this Notice. It is only necessary to schedule one face-to-face meeting. Advise your lender immediately of your intentions. APPLICATIONS FOR MORTGAGE ASSISTANCE - Your mortgage is in default for the reasons set forth 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 financial assistance from the Homeowners' Emergency Mortgage Assistance Program. To do so, you must fill out, sign and file completed Homeowners' Emergency Mortgage 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 face - 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. 5280 Corporate Drive, Frederick, MD 21703 ""r-"~~'= -"~' "'" " ~U'i<#;,lW;;ti:M",.' o o . 1ST '. NATIONWIDE MORTGAGE F'~, ;W~~~qQl1 Loan No. 6838314487 Page 4 PA Act 91 . HOW TO CURE YOUR MORTGAGE DEFAULT (Brine it un to date) NATURE OF THE DEFAULT - The MORTGAGE debt held by the above lender on your property located at: RIDGE # 591 CARLISLE, PA 17013 IS SERIOUSLY INDEF AUL T because: YOU HAVE NOT MADE YOUR MONTHLY MORTGAGE PAYMENTS for the following months and the following amounts are now past due: 3 Months @ 394.36 = o Months@OOOO.OO= o Months@ 0000.00 = $1,183.08 $0000.00 $0000.00 Late charges Bad check fees Foreclosure Fees Baokruptcy Fees Other fees Less Suspense balance $ 47.31 $ $ $ $ 7.00 $ TOTAL AMOUNT DUE $1,237.39 AS OF THIS DATE HOW TO CURE THE DEFAULT - You may cure the default within THIRTY (30) DAYS of the, date of this notice BY PAYING THE TOTAL AMOUNT PAST DUE TO THE LENDER WHICH IS $1,237.39, PLUS ANY MORTGAGE PAYMENTS AND LATE CHARGES WHICH BECOME DUE DURING THE THIRTY (30) DAY PERIOD. Pavments must be made either by cash. cashier's check. certified check. or money order made oayab1e and sent to: 5280 Corporate Drive. Frederick, MD 21703 ,~ - ;;,j<~"-'-;- e o . 1ST , .' NATIONWIDE MORTGAGE ]f~~ ~~Zo?JJ-g,Ql Loan No. 6838314487 Page 5 PAAct 91 First Nationwide'Mortl!al:e Cornoration 5280 COrDorate Drive. Frederick MD 21703 Mailinl: Address: Dent. 0107 Palatine IL 60055-0107 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 ril!hts to accelerate the mortl!al!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. If full payment of the total amount past due is not made within THIRTY (30) DAYS, the lender also intends to instruct its attomeys to start legal action to foreclose unon your mortl!al!ed pronertv. IF THE MORTGAGE IS FORECLOSED UPON - The mortgaged property will be sold by the Sheriff to payoff the mortgage debt. If the lender refers your case to its attorneys, but you cure the delinquency before the lender begins 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 wilt have to pay all reasonable attorneys' fees 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 neriod. you will not be required to pay attorneys' 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 THE SHERIFF'S SALE - If you have not cured the default within the TmRTY (30) DAY period and foreclosure proceedings have begun, you still have the ril!ht to cure the default and Drevent the sale at any time un to one hour before the Sheriff s Sale. You mav do so by Davinl! the total amount then Dast due. Dlus any late or other charl!es then due. reasonable attornevs' fees and cost connected with the foreclosure sale and other cost connected with the Sheriff s Sale as specified in writinl! by the lender and by the performing any other requirements under the mortl!al!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. 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 6 months from the date ofthis Notice. A notice of the actual date of the Sheriffs Sale will be 5280 Corporate Drive. Frederick. MD 21703 -~-". -~ o o . 1ST . , . NATIONWIDE MORTGAGE F~~,~~~QAQl1 Loan No. 6838314487 Page 6 PAAct91 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 be by contacting the lender. HOW TO CONTACT THE LENDER: First Nationwide Mortl!al!e Corporation 5280 Cornorate Drive Frederick MD 21703 Denartment 252 1-800-888-5002 EFFECT OF THE SHERIFF'S SALE - You should realize that the Sheriff's 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 Sheriff's Sale, a lawsuit to remove you and your furnishings and other belongings could be started by ,the lender '~t any tiine. ASSUMPTION OF MORTGAGE -You; UPON OUR CONSENT may sell or transfer your home to a buyer or transferee who \vl.ll assume th~ mortgage debt, provided that all the outstanding payments, charges and ~ttomey'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: .z. 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 DEF AUL T HAD OCCURRED, IF YOU CURE THE DEF AUL T. (HOWEVER, YOU DO NOT HAVE THIS RIGHT TO CURE YOUR DEF AUL T MORE THAN THREE TIMES IN ANY CALENDAR YEAR.) 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 HA VB TO SUCH ACTION BY THE LENDER TO SEEK PROTECTION UNDER THE FEDERAL BANKRUPTCY LAW. * * * * * 5280 Corporate Drive, Frederick, MD 21703 ..y;.., "".. """_",,,,,_,,,,,,,,,,",,,,..,w "..,.,i,,,,,",,"..'o,,,%~,,,',,,WU".~i"""'_."'___ o ~ L,) ~ -IQ. (t-fJ nr~ '" ~ /1. ~;:J 0 F~ ~ g , 1'v ~~~~ ~;~ 1Iii~~~~l () a C C). ~ ~:.::: 'db n'fT: ,'- Z::D ze- (I).)> C) -<::c:: ~c "0 d<c::: .,~.... Zc :Po-' [-:::J '-- z :=> ::::! (T> () -" U -1._ , "-J-::" ~t~ {(i \__1 s! C, ~, ~~ -.; - 8 , - , . ",' , " "~ ~, -" SHERIFF'S RETURN - REGULAR CASE NO: 2000-04874 P COMMONWEALTH OF PENNSYLVANIA: COUNTY OF CUMBERLAND FIRST NATIONWIDE MORTGAGE CORP VS CULLEY ROBERT H ET AL RICHARD SMITH , Sheriff or Deputy Sheriff of Cumberland County, Pensylvania, who being duly sworn according to law, says, the within COMPLAINT - MORT FORE CULLEY ROBERT H A/K/A CULLEY ROBERT H JR was served upon the DEFENDANT , at 0018:18 HOURS, on the 25th day of July , 2000 at 375 LONGS GAP ROAD CARLISLE, PA 17013 by handing to ROBERT H. CULLEY a true and attested copy of COMPLAINT - MORT FORE together with NOTICE and at the same time directing His attention to the contents thereof. Sheriff's Costs: Docketing Service Affidavit Surcharge 18.00 3.10 .00 10.00 .00 31.10 So ~~~~~~ R. Thomas Kline 07/26/2000 GOLDBECK, MCCAE Sworn and Subscribed to before By: me this day of A.D. ~ .~,o__ ~ . "0 . , ^l!I.:lMii:_"" . GOLDBECK, McCAFFERTY & McKEEVER Suite 500 - The Bourse Bldg. 111 S. Independence Mall East Philadelphia, PA 19106 215-627-1322 BY: MICHAEL T. MCKEEVER, ESQUIRE Attorney I.D. #56129 Attorney for Plaintiff FIRST NATIONWIDE MORTGAGE CORP. PO Box 9481 Mail Code: 22-528-1011 Gaithersburg, MD 20898-9481 IN THE COURT OF COMMON PLEAS OF CUMBERLAND COUNTY vs. Term No. 00-4874 CIVIL TERM ROBERT H. CULLEY, A/K/A ROBERT H. CULLEY JR. (Mortgagor(s)) (Record Owner(s)) Ridge #591 Carlisle, PA 17013 PRAECIPE TO DISCONTINUE AND END TO THE PROTHONOTARY: Kindly mark the above case Discontinued and Ended upon payment of your costs only. . GOLD , JR., ESQUIRE '~ c_ ~~,,;.~ ' -<- .-_--:a~M:.r iilI'""'~~'~IlI~ ~ -"" """'''',"' ",~,;. . 1_,~ ,,'"-' C . ",:." . 0 Cl 0 C 0 -n s: boo -...f ""Om c:: ~~ n'lrr,' c., z::() 'f--- 655;: !>> --~j2j f'-.) :-;3(~ -<"c: <c ~-~'" '" ~,;; .'\"j ~() ::r:: :s~~ ;:Cf If! - C 'C-i ""7 -- Ul :0 -< 0 -<