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HOMESIDE LENDING, INC,
SUCCESSOR BY MERGER TO
BARNETT MORTGAGE COMPANY
Plaintiff
.
IN THE COURT OF COMMON PLEAS
CUMBERLAND COUNTY, PENNSYLVANIA
vs,
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CIVIL ACTION - LAW -
IN MORTGAGE FORECLOSURE
JEFFREY A. GOSS AND MELISSA
A. GOSS
Defendants
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.
NOT ICE
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 Ave., Carlisle, PA 17013
717-249-3166
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 SERVIDO CON ESTA DEMANDA Y AVISO, PARA DEFENDERSE ES NECESSARIO QUE
USTED, 0 SU ABOGADO, REGISTRE CON LA CORTE EN FORMA ESCRITA, EL PUNTO DE VISTA DE
USTED Y CUALQUIER OBJECCION CONTRA LAS QUEJAS EN ESTA DEMANDA.
RECUERDE: SI USTED NO REPONDE A ESTA DEMANDA, SE PUEDE PROSEGUIR CON EL
PROCESO SIN SU PARTICIPACION. ENTONCES, LA COUTE PUEDE, SIN NOTIFICARIO, DECIDIR A
FAVOR DEL DEMANDANTE Y REQUERIRA QUE USTED CUMPLA CON TODAS LAS PROVISIONES DE
ESTA 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.
SI NO CONOCE A UN ABOGADO, LLAME AL "LAWYER REFERENCE SERVICE" (SERVICIO DE
REFERENCIA DE ABOGADOS), 215-238-6300,
Cumberland County Bar As.sociation
2 Liberty Ave., Carlisle, PA 17013
717-249-3166
Legal Services, Inc.
8 Irvine Row, Carlisle, PA 17013
717-243-9400
,
HOMES IDE LENDING, INC.
SUCCESSOR BY MERGER TO
BARNETT MORTGAGE COMPANY
plaintiff
IN THE COURT OF COMMON PLEAS
CUMBERLAND COUNTY, PENNSYLVANIA
NO.
vs.
JEFFREY A. GOSS AND MELISSA
A. GOSS
CIVIL ACTION - LAW -
IN MORTGAGE FORECLOSURE
Defendants
THE FOLLOWING NOTICE IS BEING PROVIDED PURSUANT TO THE
FAIR DEBT COLLECTION PRACTICES ACT, 15 U.S.C. 91601:
The undersigned attorney is attempting to collect a
debt owed to the Plaintiff, and any information
obtained will be used for that purpose. The amount
of the debt is stated in this Complaint. plaintiff
is the creditor to whom the debt is owed. Unless
the Debtor, within thirty (30) days after your
receipt of this notice disputes the validity of the
aforesaid debt or any portion thereof owing to the
Plaintiff, the undersigned attorney will assume
that said debt is valid, If the Debtor notifies
the undersigned attorney in writing within the said
thirty (30) day period that the aforesaid debt, or
any portion thereof, is disputed, the undersigned
attorney shall obtain written verification of the
said debt from the Plaintiff and mail same to
Debtor. Upon written request by Debtor to the
undersigned attorney within said thirty (30) day
period, the undersigned attorney will provide
debtor with the name and address of the original
creditor if different from the current creditor.
PURCELL, KRUG & HALLER
1719 North Front Street
Harrisburg, PA 17102-2392
(717)234-4178
Attorney ID #15700
Attorney for Plaintiff
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HOMES IDE LENDING, INC.
SUCCESSOR BY MERGER TO
BARNETT MORTGAGE COMPANY
Plaintiff
IN THE COURT OF COMMON PLEAS
CUMBERLAND COUNTY, PENNSYLVANIA
NO, fO. '19(. <j 0..MT.u.-
vs.
JEFFREY A, GOSS AND MELISSA
A. GOSS
CIVIL ACTION - LAW -
IN MORTGAGE FORECLOSURE
Defendants
COM P L A I N T
1. Plaintiff, HOMESIDE LENDING, INC. SUCCESSOR BY MERGER TO
BARNETT MORTGAGE COMPANY, is a corporation, with an address of
8120 Nations Way, Building 100, Jacksonville, Florida 32256,
2. Defendant, JEFFREY A, GOSS, is an adult individual whose
last known address is 5018 ERBS BRIDGE ROAD, MECHANICSBURG,
PENNSYLVANIA 17055. Defendant, MELISSA A, GOSS, is an adult
individual whose last known address is 5018 ERBS BRIDGE ROAD,
MECHANICSBURG, PENNSYLVANIA 17055.
3. On or about December 20, 1996, the said Defendants
executed and delivered a Mortgage Note in the sum of $87,400,00
payable to BARNETT MORTGAGE COMPANY, which Note is attached
hereto and marked Exhibit "A".
4. Contemporaneously with and at the time of the execution
of the aforesaid Mortgage Note, in order to secure payment of the
same, Defendants made, executed, and delivered to original
Mortgagee, a certain real estate Mortgage which is recorded in
the Recorder of Deeds Office of the within County and
Commonwealth conveying to original Mortgagee the subject
premises. Homeside Lending, Inc. is Successor by merger to
Barnett Mortgage Company. Said Mortgage is incorporated herein by
reference and attached hereto and marked Exhibit "B".
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5, The land subject to the Mortgage is: 5018 ERBS BRIDGE
ROAD, MECHANICSBURG, PENNSYLVANIA 17055 and is more particularly
described in Exhibit "e" attached hereto,
6, The said Defendants are the real owners of the land
subject to the Mortgage,
7, The Mortgage is in default due to the fact that
Mortgagors have failed to pay the installment due on February 1,
2000 and all subsequent installments thereon, and the following
amounts are due on the Mortgage:
(a) Unpaid principal balance $
84,336.29
(b) Interest at $17.61 per day
from 1/1/00 to 8/1/00
(based on contract rate of 7.625%)
3,733.32
(c) Accumulated Late Charges
152.06
(d) Late charges at $30.44
per month for 7 months
213.08
(e) Escrow Deficit
86,43
(f) 5% Attorney's Commission'
4,216.81
$ 92,737.99
*Together with interest at the per diem rate noted in (b) above
after August 1, 2000 and other charges and costs to date of
Sheriff's Sale.
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 that are actually
incurred by Plaintiff,
8. No judgment has been entered upon said Mortgage in any
jurisdiction.
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9, Notice of intention to forec~ose and accelerate the loan
balance pursuant to Pennsylvania Act No. 6 of 1974 is not
required in that the original principal balance exceeds
$50,000.00.
10, Defendants are not members of the Armed Forces of the
United States of America, nor engaged in any way which would
bring them within the Soldiers and Sailors Relief Act of 1940, as
amended.
11, The within Mortgage is insured by the Federal Housing
Administration under Title II of the National Housing Act and, as
such, is not subject to the provisions of Pennsylvania Act No. 91
of 1983,
WHEREFORE, Plaintiff demands judgment in Mortgage
foreclosure "IN REM" for the aforementioned total amount due
together with interest at the rate of 7.625% ($17.61 per diem),
together with other charges and costs including escrow advances
incidental thereto to the date of Sheriff's Sale and for
foreclosure and sale of the property within described.
PUR~CELL' K HAL
By~
L...-:Geo . Hal
Attorney for Plaintiff
I.D. #15700
1719 N, Front Street
Harrisburg, Pa, 17102
(717) 234-4178
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VERIFICATION
I, Leon P. Haller, Esquire, hereby swear and affirm that the
facts
contained
in
the
foregoing
COMPLAINT
for
Mortgage
Foreclosure are true and correct to the best of my knowledge,
information,
and belief based upon information provided by
Plaintiff Homeside Lending, Inc. Successor by merger to Barnett
Mortgage Company that said facts contained herein are made subject
to the penalties of 18 Pa,C.S. Section 4904 relating to unsworn
falsification to authorities.
Date: July 11, 2000
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Leon P. Haller, Esquire
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HOMESIDE LENDING, INC,
SUCCESSOR BY MERGER TO
BARNETT MORTGAGE COMPANY,
PLAINTIFF
VS.
JEFFREY A, GOSS AND
MELISSA A. GOSS,
DEFENDANTS
IN THE COURT OF COMMON PLEAS
CUMBERLAND COUNTY, PENNSYLVANIA
CIVIL ACTION - LAW
NO. 2000 04969
IN MORTGAGE FORECLOSURE
P RAE C I P E
TO THE PROTHONOTARY OF THE WITHIN COUNTY:
Please enter JUDGMENT "in rem" in favor of the Plaintiff and
against Defendants JEFFREY A. GOSS AND MELISSA A. GOSS for failure
to plead to the above action within twenty (20) days from date of
service of the Complaint, and assess Plaintiff's damages as
follows:
Unpaid principal balance
Interest
(Per diem of $17,61
from 1/1/00 to 8/1/00)
Accumulated late charges
Late charges
($30,44 per month to 8/00)
Escrow Deficit
5% Attorney's Commission
$84,336,29
$ 3,733,32
$ 152,06
$ 213.80
$ 86,43
$ 4.216.81
TOTAL
$92,737.99**
** Together with additional interest at the per diem rate indicated
above from the date herein, based on the contract rate, and other
charges and costs to the date of Sheriff's Sale.
PURCELL, KRUG &
By
Leon P. Hal er #15700
1719 North Front Street
Harrisburg, PA 17102
(717) 234-4178
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HOMES IDE LENDING, INC.
SUCCESSOR BY MERGER TO
BARNETT MORTGAGE COMPANY,
PLAINTIFF
VS,
JEFFREY A. GOSS AND
MELISSA A. GOSS,
DEFENDANTS
IN THE COURT OF COMMON PLEAS
CUMBERLAND COUNTY, PENNSYLVANIA
CIVIL ACTION - LAW
NO. 2000 04969
IN MORTGAGE FORECLOSURE
CERTIFICATE OF SERVICE
PURSUANT TO PA. R.C.P. 237.1
I hereby certify that on FEBRUARY 21, 2001 I served the Ten
Day Notice required by Pa. R.C.P, 237.1 on the Defendant(s) in this
matter by regular first class mail, postage prepaid, as indicated
on the attached Notice,
By
Leon P. Haller P I.D. #15700
Attorney for plaintiff
Purcell, Krug & Haller
1719 North Front St,
Harrisburg, PA 17102
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HOMES IDE LENDING, INC,
SUCCESSOR BY MERGER TO
BARNETT MORTGAGE COMPANY
Plaintiff
IN THE COURT OF COMMON PLEAS
CUMBERLAND COUNTY, PENNSYLVANIA
NO. 00 -4969
Vs,
JEFFREY A. GOSS AND MELISSA
A, GOSS
CIVIL ACTION - LAW
IN MORTGAGE FORECLOSURE
Defendants
DATE OF THIS NOTICE: February 21, 2001
TO: JEFFREY A, GOSS
162 EAST PARK STREET
ELI ZABETHTOWN , PA 17022
MELISSA A. GOSS
808 FISHING CREEK ROAD
NEW CUMBERLAND, PA 17070
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.
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:
Lawyer Referral Service
Court Administrator
Cumberland County Courthouse
Carlisle, PA 17013
717-249-3166
By 'URCELL,~UG & ~
Leon P. Haller ~
Attorney for Plaintiff
1. D, #15700
1719 N. Front Street
Harrisburg, PA 17102
717-234-4178
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HOMESIDE LENDING, INC.
SUCCESSOR BY MERGER TO
BARNETT MORTGAGE COMPANY,
PLAINTIFF
VS.
JEFFREY A, GOSS AND
MELISSA A, GOSS,
DEFENDANTS
IN THE COURT OF COMMON PLEAS
CUMBERLAND COUNTY, PENNSYLVANIA
CIVIL ACTION - LAW
NO. 2000 04969
IN MORTGAGE FORECLOSURE
NOTICE OF ENTRY OF JUDGMENT
TO THE ABOVE-NAMED DEFENDANTS:
You
following
captioned
are hereby notified that
judgment has been entered
matter:
on~ /4,~J
against you in the
the
above-
$92,737.99 and for the sale and foreclosure of your property
located at: 5018 ERBS BRIDGE ROAD, MECHANICSBURG, PA 17055
Dated: J, (4-01
c~ ,~
-- PROTH NOTARY ,
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Attorney for Plaintiff:
Leon p, Haller
1719 North Front Street
Harrisburg, PA 17102
Phone: (717) 234 -41 78
I hereby certify that the following person(s) and their respective
addresses are the proper individuals to receive this Notice
pursuant to PA R,C,P. No, 236:
Jeffrey A, Goss
162 East Park Street
Elizabethtown, PA 17022
Melissa A. Goss
808 Fishing Creek Road
New Cumberland, PA 17070
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, IN THE COURT OF COMMON PLEAS OF CUMBERLAND COUNTY, PENNSYLVANIA
CIVIL DIVISION - LAW AT NO. 2000 04969
HOMESIDE LENDING, INC, SUCCESSOR
BY MERGER TO BARNETT MORTGAGE
COMPANY,
PLAINTIFF
TOTAL AMOUNT /
OF JUDGMENT $ 92,737.99 v
Interest at $17.61 per diem
to sale date $ 5,441.49
Late charges at $30,44 per month
to sale date $ 304.40
Escrow Deficit $ 2,000.00
TOTAL $100,483.88*
VS,
JEFFREY A. GOSS AND
MELISSA A, GOSS,
DEFENDANT(S)
*SALE DATE: WEDS.,JUNE 6, 2001
(PROTHONOTARY'S USE)
Plaintiff
Attorney
Sheriff
This Writ
PRAECIPE FOR WRIT OF EXECUTION
MORTGAGE FORECLOSURE - P.R.C.P. 3180-3183
TO THE PROTHONOTARY/CLERK OF SAID COURT:
Attorney for Plaintiff
1719 North Front Street
Harrisburg, PA 17102
(717) 234-4178
Leon p, Haller
PA I,D, #15700
se,
Issue Writ of Execution in the above
Date: March 12, 2001
WRIT OF EXECUTION - MORTGAGE FORECLOSURE
COMMONWEALTH OF PENNSYLVANIA
SS,
COUNTY OF CUMBERLAND
TO THE SHERIFF OF CUMBERLAND COUNTY:
To satisfy the judgment, interest and costs in the above
captioned case, you are directed to levy upon and sell the property
described in the attached description known as 5018 ERBS BRIDGE ROAD,
MECHANICSBURG, PA 17055.
Date:
PROTHONOTARY/CLERK
CIVIL DIVISION
BY
DEPUTY
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ALL THAT CERTAIN house and lot of ground situate in the Township
of Hampden, County of Cumberland and Commonwealth of
Pennsylvania, known as Lot No. 1 in Plan No. 1 of Bungalow sites
as laid out by Charles Eberly, which plan of lots is recorded in
the office for the recording of deeds in and for the County of
Cumberland aforesaid, in Plan Book NO._2, Page 71, and more
particularly bounded and described as follows, to wit:
BEGINNING at a stake on the bank of the Conodoguinet Creek at
Farm Corner; thence along the line of a public street as shown on
plan of Emander Realty Company, South 59 degrees and 15 minutes
West, three hundred seventeen (317) feet, more or less, to a
point; thence along the northern side of a fifty (SO) foot wide
public street, South 37 degrees 30 minutes East, one hundred and
two (102) feet, more or less, to an iron pin; thence along the
western line of a thirty (30) foot wide public street, North 52
degrees 30 minutes East, three hundred and fifteen (315) feet to
a point on the bank of the Conodoguinet Creek; thence up said
Creek, North 37 degrees and 30 minutes West, sixty-five and six-
tenths (65,6) feet, more or less, t.o the place of BEGINNING,
EXCEPTING, however, and not intending to be included in this
conveyance, a tract twenty (20) feet square, more or less,
situate at the southeast corner of the land above-described, and
being the same tract of real estate which Frank A. Childs and
Lulu M, Childs, his wife, by deed dated July 31, 1935, and
recorded in Cumberland County, Pennsylvania, Deed Records,
Vol, 11-0, Page 122, conveyed to C.D. Bonsall and wife.
HAVING THEREON ERECTED A DWELLING KNOWN AS 5018 ERBS BRIDGE ROAD,
MECHANICSBURG, PA,
BEING THE SAME PREMISES WHICH Jeffrey A, Goss and Melissa A, Goss
by deed dated 12/23/99 and recorded 12/27/99 in Deed Book 213 Page
984 granted and conveyed unto Jeffrey A. Goss,
TO BE SOLD AS THE PROEPRTY OF JEFFREY A. GOSS ON JUDGMENT
NO, 2000 04969.
PARCEL:
10-20-1844-078
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HOMESID8 LENDING, INC,
SUCCESSOR BY MERGER TO
BARNETT MORTGAGE COMPANY,
PLAINTIFF
VS,
JEFFREY A. GOSS AND
MELISSA A. GOSS,
DEFENDANTS
IN THE COURT OF COMMON PLEAS
CUMBERLAND COUNTY, PENNSYLVANIA
CIVIL ACTION - LAW
NO, 2000 04969
AFFIDAVIT PURSUANT TO P.R.C.P. 3129.1
Th~ Plaintiff in the above action, by its attorneys, Purcell,
Krug & Baller, sets forth as of the date the praecipe for the writ
of execution was filed, the following information concerning the
real property located at 5018 ERBS BRIDGE ROAD, MECHANICSBURG, PA
17055:
1. Name and address of the Owner(s) or Reputed Owner(s):
Jeffrey A. Goss
a/k/a J~ff Goss
162 East, Park Street
Elizabethtown, PA 17022
2, Name and address of Defendant (s) in the Judgm~nt, if
different from that listed in (1) above:
Melissa A, Goss
808 Fishing Creek Road
New Cumberland, PA 17070
3, Name and address of every judgment creditor whose judgment
appears of record on the real property to be sold:
Keystone Financial Leasing Corporation
717 Constitution Drive
Suite 204
Exton, PA 19341
Krista Olmstead
31 South West Street
Carlisle, PA 17013
Krista Olmstead
637 South College Street
Carlisle, PA 17013
Andrew W. Barbin, Esquire
Attorney for Krista Olmstead
123 State Street
Harrisburg, PA 17101-1025
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Richard E, Phelan
735 S. Hanover Street
Carlisle, PA 17013
Linda L, Phelan
735 S, Hanover Street
Carlisle, PA 17013
Steve Nicholas, Esquire
Attorney for Phelans
4409 N, Front Street
Harrisburg, PA 17110-1709
4. Name and address of last recorded holder of every mortgage
of record:
PLAINTIFF HEREIN
(AND ANY OTHERS AS NOTED BELOW) :
5, Name and address of every other person who has any record
lien on the property: UNKNOWN
6,
interest
sale:
Name and address of every other person who has any record
in the property and whose interest may be affected by the
UNKNOWN
7. Name and address of
Plaintiff has knowledge who has
may be affected by the sale:
every other person of whom the
any interest in the property which
TENANTS IF ANY '"
Domestic Relations Office
Cumberland County Courthouse
Hanover & High Streets
Carlisle, PA 17013
(In the preceding information, where addresses could not be
reasonably ascertained, the same is indicated,)
I verify that the statements made in this Affidavit are true
and correct to the best of my personal knowledge, information and
belief. I understand that false statements herein are mad subject
to the penalties of 18 PA C.S. Section 4904 relatin 0 unsworn
falsification to authorities.
Leon P. Haller PA I,D, #15700
Purcell, Krug & Haller
1719 North Front Street
Harrisburg, PA 17102
(717) 234-4178
DATE: March 12, 2001
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HOMES IDE LENDING, INC.
SUCCESSOR BY MERGER TO
BARNETT MORTGAGE COMPANY,
PLAINTIFF
VS,
JEFFREY A. GOSS AND
MELISSA A, GOSS,
DEFENDANTS
IN THE COURT OF COMMON PLEAS
CUMBERLAND COUNTY, PENNSYLVANIA
CIVIL ACTION - LAW
NO. 2000 04969
IN MORTGAGE FORECLOSURE
NOTICE OF SHERIFF'S SALE OF REAL ESTATE
PURSUANT TO
PENNSYLVANIA RULE OF CIVIL PROCEDURE 3129
TAKE NOTICE:
That the Sheriff's Sale of Real Property (real estate) will be
held:
DATE:
WEDNESDAY, JUNE 6, 201
TIME: 10:00 O'clock A.M,
LOCATION: Commissioner's Hearing Room
2nd Floor
Cumberland County Courthouse
Carlisle, Pennsylvania 17013
THE PROPERTY TO BE SOLD is delineated in detail in a legal
description mainly consisting of a statement of the measured
boundaries of the property, together with a brief mention of the
buildings and any other major improvements erected on the land,
(SEE DESCRIPTION ATTACHED)
THE LOCATION of your property to be sold is:
5018 ERBS BRIDGE ROAD
MECHANICSBURG
CUMBERLAND COUNTY
PENNSYLVANIA
THE JUDGMENT under or pursuant to which your property is being
sold is docketed in the within Commonwealth and County to:
NO. 2000 04969
THE NAME(S) OF THE OWNER(S) OR REPUTED OWNERS of this property
is:
JEFFREY A. GOSS - Real OWner
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A SCHEDULE OF DISTRIBUTION, being a list of the persons and/or
governmental or corporate entities or agencies being entitled to
receive part of the proceeds of the sale received and to be
disbursed by the Sheriff (for example, to banks that hold mortgages
and municipalities that are owed taxes) will be filed by the
Sheriff of this County thirty (30) days after the sale and
distribution of the proceeds of sale in accordance with this
schedule will, in fact, be made unless someone objects by filing
exceptions to it within ten (10) days of the date it is filed,
I
Information about the Schedule of Distribution may be obtained
from the Sheriff of the Court of Common Pleas of the within County
at the Courthouse address specified herein,
THIS PAPER IS A NOTICE OF THE TIME AND PLACE OF THE SALE OF
YOUR PROPERTY.
IT HAS BEEN ISSUED BECAUSE THERE IS A JUDGMENT AGAINST YOU.
IT MAY CAUSE YOUR PROPERTY TO BE HELD, TO BE SOLD OR TAKEN TO
PAY THE JUDGMENT.
You may have legal rights to prevent your property from being
taken away, A lawyer can advise you more specifically of these
rights, If you wish to exercise your rights, YOU MUST ACT
PROMPTLY.
YOU SHOULD TAKE THIS PAPER TO YOUR LAWYER AT ONCE. GO TO OR
TELEPHONE THE OFFICE SET FORTH BELOW TO FIND OUT WHERE YOU CAN GET
FREE LEGAL ADVICE:
Cumberland County Bar Association
2 Liberty Avenue
Carlisle, Pennsylvania 17013
717-249-3166
Legal Services, Inc,
8 Irvine Row
Carlisle, PA 17013
717-243-9400
THE LEGAL RIGHTS YOU MAY HAVE ARE:
1, You may file a petition with the Court of Common Pleas of
the within County to open the judgment if you have a meritorious
defense against the perSon or company that has entered judgment
against you. You may also file an petition with the same Court if
you are aware of a legal defect in the obligation or the procedure
used against you,
2, After the Sheriff's Sale you may file a petition with the
Court of Common Pleas of the within County to set aside the sale
for a grossly inadequate price or for other proper cause, This
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,
petition MUST BE FILED BEFORE THE SHERIFF'S DEED IS DELIVERED.
3, A petition or petitions raising the legal issues or rights
mentioned in the preceding paragraphs must be presented to the
Court of Common Pleas of the within County, The petition must be
served on the attorney for the creditor or on the creditor before
presentation to the court and a proposed order or rule must be
attached to the petition.
If a specific return date is desired, such date must be
obtained from the Court Administrator's Office - Civil Division, of
the within County Courthouse, before a presentation of the petition
to the Court.
A copy of the Writ of Execution is attached hereto.
PURCELL, KRUG & HALLER
Attorneys for Plaintiff
1719 North Front Street
Harrisburg, PA 17102
(717) 234-4178
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ALL THAT CERTAIN house and lot of ground situate in the Township
of Hampden, County of Cumberland and Commonwealth of
Pennsylvania, known as Lot No.1 in Plan No.1 of Bungalow sites,
as laid out by Charles Eberly, which plan of lots is recorded in
the office for the recording of deeds in and for the County of
Cumberland aforesaid, in Plan Book No, 2, Page 71, and more
particularly bounded and described as follows, to wit:
BEGINNING at a stake on, the bank of the Conodoguinet Creek at
Farm Corner; thence along the line of a public street as shown on
plan of Emander Realty Company, South 59 degrees and 15 minutes
West, three hundred sev~nteen (317) feet, more or less, to a
point; thence along the northern side of a fifty (50) foot wide
public street, South 37 degrees 30 minutes East, one hundred and
two (102) feet, more or less, to an iron pin; thence along the
western line of a thirty (30) foot ,wide public street, North 52
degrees 30 minutes East, three hundred and fifteen (315) feet to
a point on the bank of the Conodoguinet Creek; thence up said
Creek, North 37 degrees and 30 minutes West, sixty-five and six-
tenths (65,6) feet, more or less, to the place of BEGINNING,
EXCEPTING, however, ,and not intending to be included in this
conveyance, a tract twenty (20) feet square, more or less,
situate at the southeast corner of the land above-described, and
being the same tract of real estate which Frank A, Childs and
Lulu M, C~ilds, his wife, by deed dated July 31, 1935, and
recorded ln Cumberland County, Pennsylvania, Deed Records,
Vol, 11-0, Page 122, conveyed to C,D. Bonsall and wife.
HAVING THEREON ERECTED A DWELLING KNOWN AS 5018 ERBS BRIDGE ROAD,
MECHANICSBURG, PA.
BEING THE SAME PREMISES WHICH Jeffrey A, Goss and Melissa A, Goss
by deed dated 12/23/99 and recorded 12/27/99 in Deed Book 213 Page
984 granted and conveyed unto Jeffrey A. Goss.
TO BE SOLD AS THE PROEPRTY OF JEFFREY A, GOSS ON JUDGMENT
NO, 2000 04969,
PARCEL:
10-20-1844-078
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Homeside Lending, Inc, Succesor by
Merger to Barnett Mortgage Company
-vs-
Jeffrey A. Goss and Melissa Goss
In the Court of Common Pleas of
Cumberland County, Pennsylvania
No, 2000-4969Civil
R, Thomas Kline, Sheriff, who being duly sworn according to law says this writ, is returned Stayed,
Sheriffs Costs:
Docketing
Poundage
Law Library
County
Levy
Surcharge
Postpone Sale
Out of County
30,00
2,29
,50
1.00
15,00
30,00
20,00
18,00
$ 116,79 Paid by Atty
3/22/01
~~~
Sworn and Subscribed To Before Me
This il"t~Dayof ~
2001A.D, ~t2~~-
Prot 0 otary
R. Thomas Kline, Sheriff
By~;L",___j/L~
Real Estate Deputy
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HOMESIDE LENDING, INC.
SUCCESSOR BY MERGER TO
BARNETT MORTGAGE COMPANY,
PLAINTIFF
VS,
JEFFREY A. GOSS AND
MELISSA A. GOSS,
DEFENDANTS
IN THE COURT OF COMMON PLEAS
CUMBERLAND COUNTY, PENNSYLVANIA
CIVIL ACTION - LAW
NO, 2000 04969
IN MORTGAGE FORECLOSURE
AFFIDAVIT PURSUANT TO P.R.C.P. 3129.1
The Plaintiff in the above action, by its attorneys, Purcell,
Krug & Haller, sets forth as of the date the praecipe for the writ
of execution was filed, the following information concerning the
real property located at 5018 ERBS BRIDGE ROAD, MECHANICS BURG , PA
17055:
1, Name and address of the Owner(s) or Reputed Owner(s):
Jeffrey A, Goss
a/k/a Jeff Goss
162 East Park Street
Elizabethtown, PA 17022
2 , Name and address of Defendant (s) in the Judgment, if
different from that listed in (1) above:
Melissa A. Goss
808 Fishing Creek Road
New Cumberland, PA 17070
3. Name and address of every judgment creditor whose judgment
appears of record on the real property to be sold:
Keystone Financial Leasing Corporation
717 Constitution Drive
Suite 204
Exton, PA 19341
Krista Olmstead
31 South West Street
Carlisle, PA 17013
Krista Olmstead
637 South College Stzeet
Carlisle, PA 17013
Andrew W. Barbin, Esquire
Attorney for Krista Olmstead
123 State Street
Harrisburg, PA 17101-1025
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Richard E, Phelan
735 S. Hanover Street
Carlisle, PA 17013
Linda L. Phelan
735 S. Hanover Street
Carlisle, PA 17013
Steve Nicholas, Esquire
Attorney for Phelans
4409 N, Front Street
Harrisburg, PA 17110-1709
4. Name and address of last recorded holder of every mortgage
of record:
PLAINTIFF HEREIN
(AND ANY OTHERS AS NOTED BELOW) :
5, Name and address of every other person who has any record
lien on the property: UNKNOWN
6,
interest
sale:
Name and address of
in the property and
UNKNOWN
every other person who has any record
whose interest may be affected by the
7. Name and address of
Plaintiff has knowledge who has
may be affected by the sale:
every other person of whom the
any interest in the property which
TENANTS IF ANY '"
Domestic Relations Office
Cumberland County Courthouse
Hanover & High Streets
Carlisle, PA 17013
(In the preceding information, where addresses could not be
reasonably ascertained, the same is indicated.)
I verify that the statements made in this Affidavit are true
and correct to the best of my personal knowledge, information and
belief. I understand that false statements herein are ma~,.subject
to the penalties of 18 PA C.S, Section 4904 relating,~6 unsworn
falsification to authorities, ..//-:/
-"' / _~-r
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Leon P. Hall~r PA I,D. #15700
Purcell, Krug & Haller
1719 North Front Street
Harrisburg, PA 17102
(717) 234-4178
DATE: March 12, 2001
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HOMESIDE LENDING, INC,
SUCCESSOR BY MERGER TO
BARNETT MORTGAGE COMPANY,
PLAINTIFF
VS,
JEFFREY A, GOSS AND
MELISSA A. GOSS,
DEFENDANTS
IN THE COURT OF COMMON PLEAS
CUMBERLAND COUNTY, PENNSYLVANIA
CIVIL ACTION - LAW
NO, 2000 04969
IN MORTGAGE FORECLOSURE
NOTICE OF SHERIFF'S SALE OF REAL ESTATE
PURSUANT TO
PENNSYLVANIA RULE OF CIVIL PROCEDURE 3129
TAKE NOTICE:
That the Sheriff's Sale of Real Property (real estate) will be
held:
DATE:
WEDNESDAY, JUNE 6, 201
TIME: 10:00 O'clock A.M.
LOCATION: Commissioner's Hearing Room
2nd Floor
Cumberland County Courthouse
Carlisle, Pennsylvania 17013
THE PROPERTY TO BE SOLD is delineated in detail in a legal
description mainly consisting of a statement of the measured
boundaries of the property, together with a brief mention of the
buildings and any other major improvements erected on the land.
(SEE DESCRIPTION ATTACHED)
THE LOCATION of your property to be sold is:
5018 ERBS BRIDGE ROAD
MECHANICSBURG
CUMBERLAND COUNTY
PENNSYLVANIA
THE JUDGMENT under or pursuant to which your property is being
sold is docketed in the within Commonwealth and County to:
NO. 2000 04969
THE NAME(S) OF THE OWNER(S) OR REPUTED OWNERS of this property
is:
JEFFREY A. GOSS - Real Owner
,ill- .~
-
, - ~ ' "
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,
A SCHEDULE OF DISTRIBUTION, being a list of the persons and/or
governmental or corporate entities or agencies being entitled to
receive part of the proceeds of the sale received and to be
disbursed by the Sheriff (for example, to banks that hold mortgages
and municipalities that are owed taxes) will be filed by the
Sheriff of this County thirty (30) days after the sale and
distribution of the proceeds of sale in accordance with this
schedule will, in fact, be made unless someone objects by filing
exceptions to it within ten (10) days of the date it is filed.
Information about the Schedule of Distribution may be obtained
from the Sheriff of the Court of Common Pleas of the within County
at the Courthouse address specified herein.
THIS PAPER IS A NOTICE OF THE TIME AND PLACE OF THE SALE OF
YOUR PROPERTY.
IT HAS BEEN ISSUED BECAUSE THERE IS A JUDGMENT AGAINST YOU.
IT MAY CAUSE YOUR PROPERTY TO BE HELD, TO BE SOLD OR TAKEN TO
PAY THE JUDGMENT.
You may have legal rights to prevent your property from being
taken away, A lawyer can advise you more specifically of these
rights, If you wish to exercise your rights, YOU MUST ACT
PROMPTLY.
YOU SHOULD TAKE THIS PAPER TO YOUR LAWYER AT ONCE. GO TO OR
TELEPHONE THE OFFICE SET FORTH BELOW TO FIND OUT WHERE YOU CAN GET
FREE LEGAL ADVICE:
Cumberland County Bar Association
2 Liberty Avenue
Carlisle, Pennsylvania 17013
717-249-3166
Legal Services, Inc,
8 Irvine Row
Carlisle, PA 17013
717-243-9400
THE LEGAL RIGHTS YOU MAY HAVE ARE:
1. You may file a petition with the Court of Common Pleas of
the within County to open the judgment if you have a meritorious
defense against the person or company that has entered judgment
against you, You may also file an petition with the same Court if
you are aware of a legal defect in the obligation or the procedure
used against you,
2, After the Sheriff's Sale you may file a petition with the
Court of Common Pleas of the within County to set aside the sale
for a grossly inadequate price or for other proper cause. This
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,
petition MUST BE FILED BEFORE THE SHERIFF'S DEED IS DELIVERED.
3. A petition or petitions raising the legal issues or rights
mentioned in the preceding paragraphs must be presented to the
Court of Common Pleas of the within County. The petition must be
served on the attorney for the creditor or on the creditor before
presentation to the court and a proposed order or rule must be
attached to the petition.
If a specific return date is desired, such date must be
obtained from the Court Administrator's Office - Civil Division, of
the within County Courthouse, before a presentation of the petition
to the Court.
A copy of the Writ of Execution is attached hereto.
PURCELL, KRUG & HALLER
Attorneys for Plaintiff
1719 North Front Street
Harrisburg, PA 17102
(717) 234-4178
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ALL THAT CERTAIN house and lot of ground situate in the Township
of Hampden, County of Cumberland and Commonwealth of
Pennsylvania, known, as Lot No. 1 in Plan No, 1 of Bungalow sites
as laid out by Charles Eberly, which plan of lots is recorded in
the office for the recording of deeds in and for the County of
CUmberland aforesaid, in Plan Book No.2, Page 71, and more
particularly bounded and described as follows, to wit:
BEGINNING at a stake on the bank of the Conodoguinet Creek at
Farm Corner; thence along the line of a public street as shown on
plan of Emander Realty Company, South 59 degrees and 15 minutes
West, three hundred seventeen (317) feet, more or less, to a
point; thence along the northern,side of a fifty (50) foot wide
public street, South 37 degrees 30 minutes East, one hundred and
two (102) feet, more or less, to an iron pin; thence along the
western line of a thirty (30) foot ,wide public street, North 52
degrees 30 minutes East, three hundred and fifteen (315) feet to
a point on the bank of the Conodoguinet Creek; thence up said
Creek, North 37 degrees and 30 minutes West, sixty-five and six-
tenths (65,6) feet, more or less, to the place of BEGINNING,
EXCEPTING, however, and not intending to be included in this
conveyance, a tract twenty (20) feet square, more or less,
situate at the southeast corner of the land above-described, and
being the same tract of real estate which Frank A, Childs and
Lulu M, C~ilds, his wife, by deed dated July 31, 1935, and
recorded 1n Cumberland County, Pennsylvania, Deed Records,
Vol, 11-0, Page 122, conveyed to C,D, Bonsall and wife,
HAVING THEREON ERECTED A DWELLING KNOWN AS 5018 ERBS BRIDGE ROAD,
MECHANICSBURG, PA.
BEING THE SAME PREMISES WHICH Jeffrey A, Goss and Melissa A. Goss
by deed dated 12/23/99 and recorded 12/27/99 in Deed Book 213 Page
984 granted and conveyed unto Jeffrey A, Goss.
TO BE SOLD AS THE PROEPRTY OF JEFFREY A. GOSS ON JUDGMENT
NO, 2000 04969,
PARCEL:
10-20-1844-078
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WRIT OF EXECUTION and/or ATTACHMENT
COMMONWEALTH OF PENNSYLVANiA).:
COUNTY OF CUMBERLAND) . ,,'
h.
NO. 00-4969 CIVIL 19
CIVIL ACTION. LAW
TO THE SHERIFF OF
CUMBERLAND
COUNTY:
Successor
\,'ro satisfy the debt, interest and costs due Homeside Lending, Inc., by merger to
Bai1'i;:tt Mortgage Company PLAINTIFF(S)
from ,.Jeffrey A. Goss a/k/a Jeff Goss, 162 E. Park St., Elizabethtown PA
1702iand Melissa A. Goss, 808 Fishing Creek Road, New Cumberland PA
17070~
(1) You are directed to levy upon the property of the defendant(s) and to sell
at 5018 Erbs Bridge Road, Mechanicsburg PA 17055.
legal description.)
DEFENDANT(S)
Real estate located
(See attached
(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 notffy the garnisnee(s) that: (a) an attachment has been issued; (b) the garnishee(s) is/are enjoined from paying any
debt to or for the account of the defendant(s) and from delivering any property of the defendant(s) or otherwise disposing
thereof;
(3) If property ofthe defendant(s) not levied upon an subject to attachment is found in the possession of anyone other
than a named garnlshee. you are directed to notify him/herthat he/she has been added as a garnishee and is enjoined as above
stated, '
Due Prolhy
$.50
$1.00
Amount Due $92,737.99
1~~7~1/diem to 6/6/01 $5,441.49
L.L.
Atty's Comm
Atty Paid
Plaintiff Paid
%
OtherCo~s Escrow Defici $2,OOO.00t
Late charges @ $30.44/month to sale
date $303.40
$393.55
Date:
March 14, 2001
CURTIS R. LONG
P otho tary, Civil Division
/
!
by:
Deputy
REQUESTING PARTY:
Name Leon P. Haller, Esq.
1719 N Front St
Address:
Attorney for:
Telephone:
Supreme Court ID No.
Harrisburg PA
Plaintiff
17102
(717) 234 4178
15700
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interest in thf reai
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the snenn ieVleo upon the detenot
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on Exhibit "A" filed with
this writ and by this reference incorporated herein.
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SHERIFF'S RETURN - NOT FOUND
CASE NO: 2000-04969 P
COMMONWEALTH OF PENNSYLVANIA
COUNTY OF CUMBERLAND
HOMES IDE LENDING INC
VS
GOSS JEFFREY A ET AL
R. Thomas Kline
,Sheriff or Deputy Sheriff, who being
duly sworn according to law, says, that he made a diligent search and
inquiry for the within named defendant, DEFENDANT
GOSS MELISSA A
but was
unable to locate Her in his bailiwick. He therefore returns the
COMPLAINT - MORT FORE
REINSTATED WITH NOTICE
, NOT FOUND , as to
the within named DEFENDANT
, GOSS MELISSA A
DEFENDANT NO LONGER RESIDES AT ADDRESS STATED
DID NOT LEAVE A FORWARDING WITH THE P,O,
Sheriff's Costs:
Docketing
Service
NOT FOUND RETURN
Surcharge
18.00
6.20
5,00
10,00
,00
39.20
so~~ /
;7ir:~;line -
Sheriff of Cumberland County
PURCELL, KRUG & HALLER
12/14/2000
Sworn and subscribed to before me
this
Jrf3:::
day of ~_j,
.2b7ro A, D.
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Pr t onotary I
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SHERIFF'S RETURN - OUT OF COUNTY
CASE NO: 2000-04969 P
COMMONWEALTH OF PENNSYLVANIA:
COUNTY OF CUMBERLAND '
HOMES IDE LENDING INC
VS
GOSS JEFFREY A ET AL
R, Thomas Kline
, Sheriff or Deputy Sheriff who being
duly sworn according to law, says, that he made a diligent search and
and inquiry for the within named DEFENDANT
, to wit:
GOSS MELISSA A
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 -RE
On December 14th, 2000 , this office was in receipt of the
attached return from YORK
Sheriff's Costs:
Docketing
Out of County
DEPUTIZE YORK CO
,00
9.00
45.35
.00
,00
54.35
12/14/2000
PURCELL, KRUG
~,.
So answe : ~
R, Thomas Kline
Sheriff of Cumberland County
& HALLER
Sworn and subscribed to before me
this IYT!::-
da.yof ~
.20v-0 A. D,
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' Prothonota y
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
i, "INSTRUCTIO"$ " "
'P,LEA~l::tyIl'EONLY LINE 1 TO 12
',' .DONOT DETACH ANY COpiES
1. PLAINTlFFlSJ
Hnmeside Lenclin
3. DEFENDANT/SI
Inc.
et.
a.1_.
2. COURT NUMBER
20-4969 Civil
4. lYPE OF WRIT OR COMPLAINT
Retnsatated /Nottce &
1
T/?V G, t a~.
5. NAME OF INDIVIDUAL GOMPANY, CORPORATION, ETC. TO SERVE OR DESCRIPTION OF PROP
SERVE
..
AT
{
]VIe'i,ssa A. Goss PERSONAL
6. ADDRESS (STREET OR FIFO WITH BOX NUMBER, APT NO., CITY, BORC, lVVP., STATE AND ZIP CODE
808 Fishtng Creek Road, New Cumber1_and, PA 17070
7. INDICATE SERVICE: 0 PERSONAL 0 PERSON IN CHARGE )Q DEPUTIZ!f' 11m ~qISP1TFf#~ a 1 ST CLASS MAIL
NOW" 1; I?R/OO ,20_I,SHERIFFOFX@HKX:.9~.WA,.dohereb
York COUNTY to ex ~ker
to law, This deputation being made at the request and risk of the plaintiff, ~
SHERIF 'OF Y.
PERSONAL SERVICE ONLY
lJ POSTED 0 OTHEA
'ize the sheriff of
er~of according
"
UNTY
cumber -'.and
OUT OF COUNTY
CUMBERLAND
8. SPECIAL INSTRUCTIONS OR OTHER INFORMATION THAT WILL ASSIST IN EXPEDITING SERVICE:
ADVANCE 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 removai of any property before sheriff's sale thereof.
9, TY~Ep~D~~: AR&5':EY I ORIGINATOR and SIGNATURE
171S)N. FRClNTST.",HARRISBURG, PA 17102-2392
10. TELEPHONE NUMBER
11. DATE FILED
(717) 234-4178
11/22/00
12. SEND NOTICE OF SERVICE COPY NAME AND ADDRESS BELOW: (ThiS area must be completed if notlce IS to be mailed).
CUMBERLAND COlMTY SHERIFF
SPACE BELOW FOR USE OF TH," SHER,IFF . DO NOT WRITE BELOW THIS LINE
13. I acknowledge receipt of the writ 14. DATE ReCEIVED 15. Expiration/Hearing Date
or complaint as indicated above. J. LUCWIG 12/1/00 12/22/00
21.A
POSTED (
POE( )
SHERIFF'S OFF ( )
OTHER (
SEE REMARKS
16. HOW SERVED: PERSONAL <
22. REMARKS
1~,zlcO
heck No.
o/3}J5
,
42. day of
44, Signature of
Oep.Sheriff
45. Signature of York
County Sheriff
NILLIAM M. HOSE
46. Signature of Foreign
County SheriN
SIGNATURE
~..e..:ttx;:::;;;'
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4?:iE f { 6V
48. OAT
51. DATE RECEIVED
1. WHITE ~ Issuing Authority 2. PINK. Attorney 3. CANARY - Sheriff's Office 4. BLUE - Sheriff's Office
" REOflYElJ'"
OFTICE OF SHEIOfF
YORK, PA
'OOOEe 1 PM 1 28
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HOMESIDE LENDING, INC,
SUCCESSOR BY MERGER TO
BARNETT MORTGAGE COMPANY
Plaintiff
IN THE COURT OF COMMON PLEAS
CUMBERLAND COUNTX, PENNSYLVANIA
NO. dO-1..j q~4
(}jvi/
...--
I e. orll
vs,
JEFFREY A. GOSS AND MELISSA
A. GOSS
CIVIL ACTION - LAW -
IN MORTGAGE FORECLOSURE
Defendants
~
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.
NOT ICE
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 'r:fJ<E 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 Ave" Carlisle, PA 17013
717-249-3166
"
Legal Services, Inc.
a Irvine Row, Carlisle, PA 17013
717-243-9400
A V ISO
LE BAN 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 ES NECESSARIO QUE
USTED, 0 SU ABOGADO, REGISTRE CON LA CORTE EN FORMA ESCRITA, EL PUNTO DE VISTA DE
USTED Y CUALQUIER OBJECCION CONTRA LAS QUEJAS EN ESTA DEMl\NDA,
RECUERDE: SI US TED NO REPONDE A ESTA DEMANDA, SE PUEDE PROSEGUIR CON EL
PROCESO SIN SU PARTICIPACION, ENTONCES, LA COUTE PUEDE, SIN NOTIFICARIO, DECIDIR A
FAVOR DEL DEMANDANTE Y REQUERIRA QUE USTED CVMPLA CON TODAS LAS PROVISIONES DE
ESTA DEMANDA, POR RAZON' DE ESA DECISION, ES POSSIBLE QUE US TED PUEDA PERDER
DINERO, PROPIEDAD U OTROS DERECHOS IMPORTANTES,
LLEVE ESTA DEMANDA A UN ABOGADO IMMEDIATAMENTE,
SI NO CONOCE A UN AJ30GADO, LLlIME AL "LAWYER REFERENCE SERVICE" (SERVICIO DE
REFERENCIA DE ABOGADOS), 215-238-6300,
Cumberland County Bar Association
2 Liberty Ave" Carlisle, PA 17013
717-249-3166
Legal Services', Inc.
a Irvine Row, Carlisle, PA 17_013
717-243-9400
T~ copy FROM RECORD
III T Mtlmutty whereof, I heftl UlIto Sit my nan.1
_tile. ~k1 C<<.n at . Carlisle. Pi.
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HOMESIDE LENDING, 'INC.
SUCCESSOR BY MERGER TO
BARNETT MORTGAGE COMPANY
Plaintiff
IN THE COURT OF COMMON PLEAS
CUMBERLAND COUNTY, PENNSYLVANIA
NO.
,vs.
JEFFREY A. GOSS AND MELISSA
A. GOSS
CIVIL ACTION - LAW -
IN MORTGAGE FORECLOSURE
Defendants
~
THE FOLLOWING NOTICE IS' BEING PROVIDED PURSUANT TO THE
FAIR DEBT COLLECTION PRACTICES ACT, 15 U,S,C. 91601:
The undersigned attorney is attempting to collect a
debt owed to the Plaintiff, and any information
obtained will be used for that purpose. The amount
of the debt is stated in this Complaint. Plaintiff
is the creditor to whom the debt is owed. Unless
the Debtor, within thirty (30) days after your
receipt of this notice disputes the validity of the
aforesaid ,debt or any portion thereof owing to the
Plaintiff, the undersigned attorney will assume
that said debt is valid. If the Debtor notifies
the undersigned attorney in writing within the said
thirty (30} day period that the aforesaid debt, or
any portion thereof, is disputed, the undersigned
attorney shall obtain written verification of the
said debt from the plaintiff and mail same to,
Debtor. Upon written request by Debtor to the
undersigned attorney within said thirty (30) day
period, the undersigned attorney will provide
debtor with the "name and address of the original
creditor if different from the current creditor.
PURCELL, KRUG & HALLER
1719 North Front Street
Harrisburg, PA 17102-2392
(717}234-4178
Attorney ID #15700
Attorney for Plaintiff
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HOMESIDE LENDING, INC.
SUCCESSOR BY MERGER TO
BARNETT MORTGAGE COMPANY
Plaintiff
IN THE COURT OF COMMON PLEAS
CUMBERLAND COUNTy, PENNSYLVANIA
NO.
vs.
JEFFREY A. GOSS AND MELISSA
A. GOSS
CIVIL ACTION - LAW -
IN MORTGAGE FORECLOSURE
Defendants
~
COM P L A I N T
1. Plaintiff, HOMES IDE LENDING, INC. SUCCESSOR BY MERGER TO
BARNETT MORTGAGE COMPANY, is a corporation, with an address of
8120 Nations Way, Building 100, Jacksonville, Florida 32256.
2. Defendant, JEFFREY A. GOSS, is an adult individual whose
last known address is 5018 ERBS BRIDGE ROAD, MECHANICSBURG,
PENNSYLVANIA 17055. Defendant, MELISSA A. GOSS, is an adult
.-,.
individual whose last known address is 5018 ERBS BRIDGE ROAD,
MECHANICSBURG, PENNSYLVANIA 17055.
3. On,or about December 20, 1996, the said Defendants
executed and delivered a Mortgage Note in the sum of $87,400.00
payable to BARNETT MORTGAGE COMPANY, which Note is attached
hereto and marked Exhibit "A".
4. Contemporaneously with and at the time of the execution
0f the aforesaid Mortgage Note, in order to secure payment of the
same, Defendants made, executed, and delivered to original
Mortgagee, a certain real estate Mortgage which is recorded in
the Recorder of Deeds Office of the within County and
Commonwealth conveying to original Mortgagee the subject
premises. Homeside Lending, Inc. is Successor by merger to
Barnett Mortgage Company. Said Mortgage is incorporated herein by
reference and attached hereto and marked Exhibit "B".
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5, The land subject to the Mortgage is: 5018 ERBS BRIDGE
ROAD, MECHANICSBURG, PENNSYLVANIA 17055 and is more particularly
,..~
described in Exhibit "C" attached hereto.
6. The said Defendants are the real owners of the land
subject to the Mortgage.
7. The Mortgage is in default due to the fact that
Mortgagors have failed to pay th~ installment due on February 1,
2000 and all subsequent installments thereon, and the following
amounts are due on the Mortgage:
(a) Unpaid principalbalance $
(b) Interest at $17.61 per day
from 1/1/00 to 8/1/00
(based on contract rate of 7.625%)
84,336.29
3,733.32
(c) Accumulated Late Charges
152.06
(d) Late 'charges at $30.44
per month for 7 months
213.08
(e) Escrow Deficit
86.43
(f) 5% Attorney's Commission
4,216.81
$ 92,737.99
*Together with interest at the per diem rate noted in (b) above
after August 1, 2000 and other charges and costs to date of
Sherif.f's Sale.
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 that are actually
incurred by Plaintiff.
8.No judgment has been entered upon said Mortgage in any
jurisdiction.
-- ~..>~
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9, Notice of intention to foreclose and accelerate the loan
balance pursuant to Pennsylvania Act No, 6 of 1974 is not
required in that the original principal balance exceeds
$50,000.00.
10. Defendants are not members of the Armed Forces of the
United States of America, nor engaged in any way which would
bring them within the Soldiers a~d Sailors Relief Act of 1940, as
amended.
11. The within Mortgage is insured by the Federal Housing
Administration under Title II of the National Housing Act and, as
such, is not subject to the provisions of Pennsylvania Act No. 91
of 1983.
WHEREFORE, Plaintiff demands judgment in Mortgage
foreclosure "IN REM" for the aforementioned total amount due
together with interest at the rate of 7.625% ($17.61 per diem),
together with other charges and costs including escrow advances
incidental ,thereto to the date of Sheriff's Sale and for
foreclosure and sale of the property within described.
PURCELL, K&
-~....-
,.----
By" ,/'/
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Attorney for Plaintiff
I.D. #15700 0
1719 N. Front street
Harrisburg, Pa. 17102
(717) 234-4178
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VERIFICATION
I, Leon P. Haller, Esquire, hereby swear and affirm that the
facts
contained in the
f ~.
orego~ng
COMPLAINT
for
Mortgage
Foreclosure are true and correct to the best of my knowledge,
Mortgage Company that said facts contained herein are made subject
to the penalties of 18 Pa.C.S. Section 4904 relating to unsworn
falsification to authorities.
~
Date: July 11, 2000
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Leon P. Haller, Esquire
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HOMESIDE LENDING, INC.
SUCCESSOR BY MERGER TO
BARNETTMORTGAOECO~ANY
Plaintiff
'oS,
JEFFREY A. ClOSS AND MELISSA
A. GOSS
Defendants
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: IN THE COURT OF COMMON PLEAS
: CUMBERLAND COUNTY, PENNSYL VANIA
: NO. 00-4969 CIVIL TERM
: CIVIL ACTION - LAW
: IN MORTGAGE FORECLOSURE
PRAECIPE TO REINSTATE CO~LAINT
TO THE PROTHONOTARY:
Kindly reinstate the complaint on the above captioned matter.
DATE: November 21, 2000
PURCELL, KRUG & HALLER
BY
Leon P. Haller
1719 North Front Street
Harrisburg, PA 17102
Attorney for Plaintiff
Attorney ID# 15700
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SHERIFF'S RETURN - NOT FOUND
CASE NO: 2000-04969 P
i COMMONWEALTH OF PENNSYLVANIA
COUNTY OF CUMBERLAND
HOMES IDE LENDING INC
VS
GOSS JEFFREY A ET AL
R. Thomas Kline
,Sheriff or Deputy Sheriff, who being
duly sworn according to law, says, that he made a diligent search and
inquiry for the within named defendant, DEFENDANT
GOSS MELISSA A - 5018 ERBS BRIDGE RD, MECHANICSBURG, PA
but was
unable to locate Her in his bailiwick. He therefore returns the
COMPLAINT - MORT FORE
REINSTATED
, NOT FOUND , as to
the within named DEFENDANT
, GOSS MELISSA A
DEFENDANT NO LONGER RESIDES AT ADDRESS STATED,
BELIEVED TO BE IN LANCASTER CO.
Sheriff's Costs:
Docketing
Service
Not Found Return
Surcharge
18.00
6.20
5.00
10.00
.00
39.20
~
R. Thomas Kline,
Sheriff of Cumberland County
PURCELL, KRUG & HALLER
11/16/2000
Sworn and subscribed to before me
this
2J~
day of ~
..J,.~ A.D.
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P 0 honotary 'v
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SHERIFF'S RETURN - NOT FOUND
~ASE NO: 2000-04969 P
COMMONWEALTH OF PENNSYLVANIA
COUNTY OF CUMBERLAND
HOMES IDE LENDING INC
VS
GOSS JEFFREY A ET AL
R. Thomas Kline
,Sheriff or Deputy Sheriff, who being
duly sworn according to law, says, that he made a diligent search and
inquiry for the within named defendant, DEFENDANT
GOSS MELISSA A
-783 Hamilton Ct. Carlisle. PA
but was
unable to locate Her in his bailiwick. He therefore returns the
COMPLAINT - MORT FORE
REINSTATED
, NOT FOUND , as to
the within named DEFENDANT
, GOSS MELISSA A
DEFENDANT IS NOT KNOWN AT ABOVE ADDRESS.
Sheriff's Costs:
Docketing
Service
Not Found Return
Surcharge
.00
3.10
5.00
.00
.00
8.10
~
. Thomas Kline
Sheriff of Cumberland County
PURCELL, KRUG & HALLER
11/16/2000
Sworn and subscribed to before me
this .<:l ~
day of~
.1cnrV A. D.
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Pro h notary ,
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SHERIFF'S RETURN - OUT OF COUNTY
~ASE NO: 2000-04969 P
COMMONWEALTH OF PENNSYLVANIA:
COUNTY OF CUMBERLAND
HOMES IDE LENDING INC
VS
GOSS JEFFREY A ET AL
R. Thomas Kline
, Sheriff or Deputy Sheriff who being
duly sworn according to law, says, that he made a diligent search and
and inquiry for the within named DEFENDANT
, to wit:
GOSS MELISSA A
but was unable to locate Her
in his bailiwick. He therefore
deputized the sheriff of LANCASTER
County, Pennsylvania, to
serve the within COMPLAINT - MORT FORE (RE
on November 16th, 2000 , this office was in receipt of the
attached return from LANCASTER
Sheriff's Costs:
Docketing
Out of County
Dep. Lancaster Co
.00
9.00
53.20
.00
.00
62.20
11/16/2000
PURCELL, KRUG
~~
R. Thomas Kline
Sheriff of Cumberland County
& HALLER
Sworn and subscribed to before me
this ;2QM..d. day of~",,,, t...-.
~&1n? A.D.
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Prothonotary
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SHERIFF'S OFFICE
.
50 NORTH DUKE STREET, P.O. BOX 83480, LANCASTER, PENNSYLVANIA 17808-3480 . (717) 299-8200
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2. COURT NUMBER
20-4969 Civil
Inc. ,
et.
a1.
.
SHERIFF SERVICE
PROCESS RECEIPT, and AFFIDAVIT OF RETURN
.'1. PLAINTIFF/S/
Homeside Lending,
3. DEFENDANT /S/
Jeffr
S;E {
AT
4. TYPE OF WRIT OR COMPLAINT'
Reinstated Notice &
Complaint in Mort/Fore
5. NAME OF INDIVIDUAL, COMPANY, CORPORATION, ETC., TO BE SERVED.
Melissa A. Goss
6, ADDRESS (Street or RFD, Apartment No" City, Boro, Twp., State and ZIP Code)
lh? Po P~rk ~r, ~1;7~h~thtown P!
7. INDICATE UNUSUAL SERVICE: Xl DEPUTIZE 0 OTHER '
Now,ll/17Lnn 20 ,I,SHERIFFOF
T"ancas her County to execute thi
to law. This deputation being made at the request and risk of the plaintiff,
8. SPECIAL INSTRUCTIONS OR OTHER INFORMATION THAT WILL ASSIST IN EXPEDITING SERVICE,
".:~-i.'-"_::'O~' -
SHERIFF OF
COUNTY
PURCELL KRUG & HALLER
.1719 N FRONT ST
HARRISBURG PA 17102-2392
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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 liabilityon
the pad of such deputy or the sheriff to any plaintiff herein for any loss, 'destruction or removal of any such property before sheriff's sale thereof.
g, SIGNATURE of ATTORNEY or other ORIGINATOR 10. TELEPHONE NUMBER 11. DATE
717 234-4178 10/4/00
12. SEND NOTICE OF SERVICE COPY TO NAME AND ADDRESS BELOW: (This area must be eompleted if notlee is to be mailed)
13. I acknowledge receipt of the writ I
or compl~intas indicated above, r
ANNETTE WALTON 717-295-3609
15. Expiration/Hearing date
11/3/00
16.1 here CERTIFY and RETURN that I 0 have personally served, 0 have legal evidence of service as shown in "Remarks",O have executed as shown in
"Re rks", the writ or complaint described on the individual, company, corporation, etc., at the address shown above oran the individual, company, cor-
por ion, etc., at the address inserted below by handing a TRUE and ATTESTED COPY thereof.
17. I hereby certify and return a NOT FOUND because I am unable to tocate the individual, company, corporation, etc., named above. (See remarks below)
18. Name and title of individual served (if not shown above) (Relationship to Defendant) 19. ONoService
See Remarks Below (No. 30)
21. Date of Service 22. Time
20. Address of where served (complete only if different than shown above) (Stieet orRFD,Apartment No., City, Bora, Twp.
State and Zip Code)
/.
AM
PM
EST
EDST
S.TA<
N,~{JP
0- '32 .go
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/VO L~k H i-IN"lf'P"&, f)&-Jlt/sJ3IIiVD CU/1M.5 3,.Vtr L-NCS SC7H$Z<.J~ IN
,A/PJ &Ht3f:;72.hf1./p ?/1,;" p~ bPPtcc- :5~ H~L IS 'Pez.!1A5f<.r;p W t-/M:~
e,t. ')5D3p
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Dep.lnt.
23. ATTEMPTS
24. Advance Costs
Rll1457 100.00
30. REMARKS:
37.
33, Date
11-6 -or
36 0 . -U c9
l--r:
34. day of
1. WHITE - Issuing Authority 2. PINK - Attomey 3. CANARY - Sheriff's Office 4. BLUE - Sheriffs Office
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HOMES IDE LENDING, INC.
SUCCESSOR BY MERGER TO
BARNETT MORTGAGE COMPANY
Plaintiff
vs.
JEFFREY A. GOSS AND MELISSA
A. GOSS
Defendants
~~= , " ". "~.-
: IN THE COURT OF COMMON PLEAS
: CUMBERLAND COUNTY, PENNSYLVANIA
: NO. 00-4969 CIVIL TERM
: CIVIL ACTION - LAW
: IN MORTGAGE FORECLOSURE
PRAECIPE TO REINSTATE COMPLAINT
TO THE PROTHONOTARY:
Kindly reinstate the complaint on the above captioned matter.
DATE: September 29, 2000
PURCELL, KRUG & HALLER
BY
Leon P. Haller
1719 North Front Street
Harrisburg, P A 17102
Attorney for Plaintiff
Attorney ID# 15700
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SHERIFF'S RETURN - OUT OF COUNTY
CASE NO: 2000-04969 P
COMMONWEALTH OF PENNSYLVANIA:
COUNTY OF CUMBERLAND
HOMES IDE LENDING INC
VS
GOSS JEFFREY A ET AL
R. Thomas Kline
, Sheriff or Deputy Sheriff who being
duly sworn according to law, says, that he made a diligent search and
and inquiry for the within named DEFENDANT
, to wit:
GOSS JEFFREY
but was unable to locate Him
in his bailiwick. He therefore
deputized the sheriff of LANCASTER
County, Pennsylvania, to
serve the within COMPLAINT - MORT FORE
On Auqust
15th , 2000 , this office was in receipt of the
attached return from LANCASTER
Sheriff's Costs:
Docketing
Out of County
Surcharge
Dep. Lancaster Co
18.00
9.00
10.00
48.20
.00
85.20
08/15/2000
PURCELL, KRUG
S~~
R. homas Kline
Sheriff of Cumberland County
& HALLER
Sworn and subscribed to before me
this JStB- day of
()..~AD
(2, "JJ.t<{j."-i~
Prothonotary
. =
SHERIFF'S RETURN - NOT FOUND
CASE NO: 2000-04969 P
COMMONWEALTH OF PENNSYLVANIA
COUNTY OF CUMBERLAND
HOMESIDE LENDING INC
VS
GOSS JEFFREY A ET AL
R. Thomas Kline
,Sheriff or Deputy Sheriff, who being
duly sworn according to law, says, that he made a diligent search and
inquiry for the within named defendant, DEFENDANT
GOSS MELISSA A
but was
unable to locate Her in his bailiwick. He therefore returns the
COMPLAINT - MORT FORE
NOTICE
, NOT FOUND , as to
the within named DEFENDANT
, GOSS MELISSA A
DEFENDANT COULD NOT BE LOCATED AT ADDRESS STATED
PRIOR TO EXP. DATE, LEFT NO FWDG WITH THE P.O.
Sheriff's Costs:
Docketing
Service
Not Found Return
Surcharge
6.00
12.40
5.00
10.00
.00
33.40
~ ~?
.. ~~~
R. 'Thomas Kline
Sheriff of Cumberland County
PURCELL, KRUG & HALLER
08/15/2000
Sworn and subscribed to before me
this /'i~
day of
;lrnro A . D .
~~n~'~
SHERIFF'S OFFICE
..
50 NORTH DUKE STREET, P.O< BOX 83480. LANCASTER, PENNSYLVANIA 17808-3480 . (717) 299-8200
SHERIFF SERVICE
PROCESS RECEIPT, and AFFIDAVIT OF RETURN
.:t. PLAINTlFF/SI
Homeside Lending,
3 DEFENDANT/SI
Jeffn',," ron~~ At. ,,1
SERVE {5' NAME OF INDIVIDUAL, COMPANY, CORPORATION, ETC., 1"0 BE SERVED,
Melissa A. Goss
. 6, ADDRESS (St,"e' or RFD< Apartment No" City, Bora, Twp" State and ZIP Code)
AT l(i? R P"rk <::,. l"li7<lo<?t1:Jt0l\'n. P^ 17022
7, INDICATE UNUSUAL SERVICE;)O DEPUTIZE 0 OTHER
Now, 1 1 /1 7 Inn 20 _ . I, SHERIFF OF OUNTY,
r~Clnca'" t-er County to execute thi
to law, This deputation being made at the request and risk of the plaintiff,
8, SPECIAL INSTRUCTIONS OR OTHER INFORMATION THAT WILL ASSIST IN EXPEDITING SERVICE:
--,-'\., , -
..
Inc. I
et.
PURCELL KRUG & HALLER
1719 N FRONT ST
HARRISBURG PA 17102-2392
aid
PLEASE TYPE
DO NOT DETACH ANY COPIES.
2, COURT NUMBER
20-4969 Civil
4. TYPE OF WRIT OR COMPLAINT:
Reinstated Notice &
Complaint in Mort/Fore
"",..'
.",fumberland)
------------------,
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NOTE ONLY APPLICABLE ON WRIT OF EXECUTION: N.B, WAIVER OF WATCHMAN - Any deputy sheriff levying upon or attaching allY 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 plaintilf herein for any loss, destruction or removal of any such property before sheriffs sale thereat
9. SIGNATURE of ATTORNEY or other ORIGINATOR 10, TELEPHONE NUMBER 11, DATE
717 234-4178 10/4/00
12. SEND NOTICE OF SERVICE COPY TO NAME AND ADDRESS BELOW: (This area must be completed if nobce is to be mailed)
SPACE BELOW FOR USE OF SHERIFF ONLY - DO NOT WRITE BELOW THIS LINE
13. I acknowledge receipt of the writ' NAME of Authorized Lese Deputy or Clerk 14. Date Received 15, Expiration/Hearing date
or complaint as indicated above. r ANNETTE WALTON 717-295-3609 10/20/00 11/3/00
I
16. I here CERTIFY and RETURN thatl (J have personally served, 0 have legal evidence of service as shown in "Remarks", 0 have executed as shown in
~Ae rks", the writ or complaint described on the individual. company, corporation, etc., at the address shown above oron the individual, company, cor-
por ion, etc., at the address Inserted below by handing a TRUE and ATTESTED COpy thereof.
17. I hereby certify and return a NOT FOUND because \ am unable to locate the individual, company, corporation, etc" named abo\le. (See remarks beloW)
18. Name and title of individual served (if not shown above) (Relationship to Defendant) 19
o No Service
See Remarks Below (No, SO)
,21, Date of Service 22.
20, Address of where served (complete ol'\ly if ditferentthan shown above) (Street or RFO, ApartmentNo..City,Boro, Twp.
State and Zip Code)
23. ATTEMPTS
24, Advance Costs
Rll1457 100.00
30. REMARKS:
j..,o ~O;<.l~ 1FT ,U/./e "".0 ,
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A/~J CL;H$e;;Z.Ut./j) FA.
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$,T.A.:
34. day of
37.
Time
AM
PM
EST
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33. Date
II &. -01/
36 D '7 -t:)O
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i. WHITE - Issuing Authority 2. PINK - Attomey 3. CANARY - Sheriff's Office 4. SLUE - Sheriffs Office
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HOMESIDE LENDING, INC.
SUCCESSOR BY MERGER TO
BARNETT MORTGAGE COMPANY
Plaintiff
IN THE COURT OF COMMON PLEAS
CUMBERLAND COUNTy, PENNSYLVANIA
vs.
NO. 06 - "Iqfe.~
C.u{ <-r~
JEFFREY A. GOSS AND MELISSA
A. GOSS
CIVIL ACTION - LAW
IN MORTGAGE FORECLOSURE
Defendants
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.
.,._". ~,~,...'~" 'n",- 't'4::''''E'd'
You have been sued .in court. If you wish to defend against the claims set
forth in the following pagesl yoP must take action within twenty (20) days after
the Complaint and notice are serVed, by entering a written appearance -p.ersonally
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 Ave., Carlisle, PA 170~3
717-249-3166
Legal Services, Inc.
S Irvine Row, Carlisle, PA 17013
717-243-9400
AVISO
LE RAN 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 ES NECESSARIO QUE
USTED, 0 SU ABOGADO, REGISTRE CON LA CORTE EN FORMA ESCRITA, EL PUNTO .DE VISTA DE
USTED Y CUALQUIER OBJECCION CONTRA LAS QUEJAS EN ESTA DEMANDA.
RECUERDE: SI USTED NO REPONDE A ESTA DE~DA, SE PUEDE PROSEGUIR CON EL
PROCESO SIN SU PARTICIPACION. ENTONCES, LA COUTE PDEDE, SIN NOTIFICARIO, DECIDIR A
FAVOR DEL DEMANDANTE Y REQUERIRA QUE USTED CUMPLA CON TODAS LAS PROVISIONES DE
ESTA DEMANDA. PORRAZON DE ESA DECISION, ES POSSIBLE QUE USTED PUEDA PERDER
DINERO, PROPIEDAD U OTROS DERECHOS IMPORTANTES.
LLEVE ESTA DEMANDAA UN ABOGADO IMMEDIATAMENTE.
SI NO CONOCE A UN ABOGADO, LLAME AL "LAWYER REFERENCE SERVICE" (SERVICIO DE
REFERENCIA DE ABOGADOS), 215-238-6300.
CUmberland County Bar Association
2 Liberty Ave., Carlisle, PA 17013
717-249-3~66
--
TRUE COpy FROM RECORD '
111 Testimony whereof, Ill6re ill1:0 S$t my hand .
~d tOO ~ said Court at Carlisle. Fa.
,~ ", aYfi~r~~-';~
lI0n0tary
Legal Services, Inc.
S Irvine Row, Carlisle, PA 17013
717-243-9400
" '
, "
." ,
, -,
HOMESIDE LENDING, INC.
SUCCESSOR BY MERGER TO
BARNETT MORTGAGE COMPANY
Plaintiff
IN THE COURT OF COMMON PLEAS
CUMBERLAND COUNTY, PENNSYLVANIA
NO.
vs.
JEFFREY A. GOSS AND MELISSA
A. GOSS
CIVIL ACTION - LAW -
IN MORTGAGE FORECLOSURE
Defendants
THE FOLLOWING NOTICE IS BEING PROVIDED PURSUANT TO THE
FAIR DEBT COLLECTION PRACTICES ACT, 15 U.S.C. 91601:
.-,e,,?-,,~e.i,"
'.~-'.<' ,,,,",,.l~ i'''i~..t;. ,',,- ;,_';0,.,;......,..,. ,,,:.<,_,,,-
The undersigned attorney is attempting to collect a
debt owed to the Plaintiff, and any ipformation
.obtained will be used for that purpose. The amount
of the debt is stated in this Complaint. Plaintiff
is the creditor to whom the debt is owed. Unless
the Debtor, within thirty (30) days after your
receipt of. this notice disputes the validity of the
aforesaid debt or any portion thereof owing to the
Plaintiff, the undersigned attorney will assume
that said debt is valid. If the Debtor notifies
the undersigned attorney in writing within the said
thirty (30) day period that the aforesaid debt, or
any portion thereof, is disputed, the undersigned
attorney shall obtain written verification of the
said debt from the Plaintiff and mail same to
Debtor. Upon written request by Debtor to the
undersigned attorney within said thirty (30) day
period, the undersigned attorney will provide
debtor with the name and address of the original
creditor if different, from the current creditor.
PURCELL, KRUG & HALLER
1719 North Front Street
Harrisburg, PA 17102-2392
(717)234-4178
Attorney ID #15700
Attorney for Plaintiff
,;
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HOMESIDE LENDING, INC.
SUCCESSOR BY MERGER TO
BARNETT MORTGAGE COMPANY
Plaintiff
IN THE COURT OF COMMON PLEAS
CUMBERLAND COUNTY, PENNSYLVANIA
NO.
vs.
JEFFREY A. GOSS AND MELISSA
A. GOSS
CIVIL ACTION - LAW -
IN MORTGAGE FORECLOSURE
Defendants
COM P L A I N T
1. Plaintiff, HOMESIDE LENDING, INC. SUCCESSOR BY MERGER TO
l -_:L",.....,.."'}--'.
.,-'j3~Ei!!_J'IORTGAGE COMPANY, is a corporati9n",,~with anaddr~ss (),t"
8120 Nations Way, Building 100, Jacksonville, Florida 32256.
2. Defendant, JEFFREY A. GOSS, is an adult individual whose
.
last known address is 5018 ERBS BRIDGE ROAD, MECHANICSBURG,
PENNSYLVANIA 17055. Defendant, MELISSA A. GOSS, is an adult
individual whose last known address is 5018 ERBS BRIDGE ROAD,
MECHANICSBURG, PENNSYLVANIA 17055.
3. On or about December 20, 1996, the said Defendants
executed and delivered a Mortgage Note in the sum of $87,400.00
payable to BARNETT MORTGAGE COMPANY, which Note is attached
hereto and marked Exhibit "A".
4. Contemporaneously with and at the time of the execution
ef the aforesaid Mortgage Note, in order to secure payment of the
same, Defendants made, executed, and delivered to. original
Mortgagee, a certain real estate Mortgage which is recorded in
the Recorder of Deeds Office of the within County and
Commonwealth conveying to original Mortgagee the subject
premises. HomesideLending, Inc. is Successor by merger to
Barnett Mortgage Company. Said Mortgage is incorporated herein by
reference and attached hereto and marked Exhibit "B".
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5. The land subject to the Mortgage is: 5018 ERBS BRIDGE
ROAD, MECHANICSBURG, PENNSYLVANIA 17055 and is more particularly
described in Exhibit "C" attached hereto.
6. The said Defendants are the real owners of the land
subject to the Mortgage.
7. The Mortgage is in default due to the fact that
Mortgagors have failed to pay the installment due on February 1,
2000 and all subsequent installments thereon, and the following
amounts are due on the Mortgage:
~",<--:f,,-",__,
(a)
Unpaid principal balance
" ,.+"
J;
84,336.29
(b)
Interest at $17.61 per day
from 1/1/00 to 8/1/00
(based on contract rate of 7.625%)
(c) Accumulated Late Charges
3,733.32
152.06
(d) Late charges at $30.44
per month for 7 months
213.08
(e) Escrow Deficit
86.43
(f) 5% Attorney's Commission
4,216.81
$ 92,737.99
*Together with interest at the per diem rate noted in (b) above
after August 1, 2000 and other charges and costs to date of
Sheriff's Sale.
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 that are actually
incurred by Plaintiff.
8. No judgment has been entered upon said Mortgage in any
jurisdiction.
,.1
-'~"
b.~~~,
----,
9 .
Notice of intention to foreclose and accelerate the loan
balance pursuant to Pennsylvania Act No. 6 of 1974 is not
required in that the original principal balance exceeds
$50,000.00.
10. Defendants are not members of the Armed Forces of the
United Sta.tes of America, nor engaged in any way which would
bring them within the Soldiers and Sailors Relief Act of 1940, as
amended.
11. The within Mortgage is insured by the Federal Housing
Administra.t;:i,Wl under Title "II o:t;."thel)[i3-tional Housing Act and, as
such, is not subject to the provisions of Pennsylvania Act No. 91
of 1983.
WHEREFORE, Plaintiff demands judgment in Mortgage
foreclosure "IN REM" for the aforementioned total amount due
together with interest at the rate of 7.625% ($17.61 per diem),
together with other charges and costs including escrow advances
incidental thereto to the date of Sheriff's Sale and for
foreclosure and sale of the property within described.
PURC~E~" K&HAL. //. ._
By ~ "
~o~ . Hal .
Attorney for Plaintiff
I.D. #15700 :
1719 N. Front Street
Harrisburg, Pa. 17102
(717) 234-4178
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VERIFICATION
facts
contained in the
I, Leon P. Haller, Esquire, hereby swear and affirm that the
foregoing COMPLAINT
for Mortgage
'Foreclosure are true "and correct to the best of my knowledge,
<,'l_S.'.';,,,,.
Pla'i'h~ f'E""~1:de'L€mding,
information, and belief based upon information provided by
" [;)..-_1,"'
Inc.
Successor by m~e'I'to~Ba:tnet t .^,.._~,",.c'
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Mortgage Company that said facts contained herein are made subject
to the penalties of 18 Pa.C.S. Section 490~ relating to unsworn
falsification to authorities.
Date: July 11, 2000
~/---
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"Leon p. Haller, Esquire
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HOMESIDE LENDING, INC.,
SUCCESSOR BY MERGER TO BARNETT
MORTGAGE COMPANY,
PLAINTIFF
IN THE COURT OF COMMON PLEAS
CUMBERLAND COUNTY, PENNSYLVANIA
',VS.
NO. 2000 - 04969
JEFFREY A. GOSS AND
MEL!SSA A. GOSS,
DEFENDANTS
CIVIL ACTION - LAW
IN MORTGAGE FORECLOSURE
P RAE C I P E
TO THE PROTHONOTARY:
Kindly satisfy the judgment in the above captioned action.
PURCELL, KRUG & HALLER
By:
Leon P. Hal ID #15700
Attorney f r Plaintiff
1719 North Front Street
Harrisburg, PA 17102
(717) 234-4178
DATE: June 14. 2001
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