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Home My WebLink About02-6092GOLDBECK McCAFFERTY & McKEEVER BY: JOSEPH A. GOLDBECK, JR. ATTORNEY I.D. #16132 SUITE 500 - THE BOURSE BLDG. 111 S. INDEPENDENCE MALL EAST PHILADELPHIA, PA 19106 (215) 627-1322 ATTORNEY FOR PLAINTIFF AAMES CAPITAL CORP. 350 S. Grand Avenue 47th Floor Los Angeles, CA 90071 Plaintiff VS. THERESA L. LILLICH WILLIAM V. LILLICH Mortgagor(s) and Real Owner(s) OF Cumberland COUNTY CIVIL ACTION - LAW ACTION OF MORTGAGE FORECLOSURE a -?09a t u t Term No. 5203 Meadowbrook Drive Cl x n1 r 1Gtf Mechanicsburg, PA 17055 Defendant(s) ?OREcws -14UN)o THIS FIRM IS A DEBT COLLECTOR AND WE ARE ATTEMPTINGTO COLLECT A DEBT OWED TO OUR CLIENT. ANY INFORMATION OBTAINED FROM YOU WILL BE USED FOR THE PURPOSE OF COLLECTING THE DEBT. NOTICE You have been sued in court If 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 fmtber notice for any money claim in the Complaint of 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 POPER TO YOUR LAWYER AT ONCE. IF YOU DO NOT HAVE A LAWYER OR CANNOT AFFORD ONE, GO TO OR TELEPHONE THE OFFICE SET FORTH BELOW TO FIND OUT WHERE YOU CAN GET LEGAL HELP. CUMBERLAND COUNTY BAR ASSOCIATION 2 Liberty Avenue Carlisle, PA 17013 LEGAL SERVICES INC 8 Irvine Row Carlisle, PA 17013 717-243-9400 AVISO LE HAN DEMANDADO A USTED EN LA CORTE. SI DESEA DEFENDERSE CONTRA LAS QUEJAS PERESENTADAS, ES ABSOLUTAMENTE NECESSARIO QUE USTED RESPONDA DENTRO DE 20 DIAS DESPUES DE SER SERVIDO CON ESTA DEMANDA Y AVISO. PARA DEFENDERSE ES NECESSARIO QUE USTED, O 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. FOR RAZON DE ESA DECISION, ES POSSIBLE QUE USTED PUEDA PERDER DINERO, PROPIEDAD U OTROS DERECHOS IMPORTANTES. LLEVE ESTA DEMANDA A UN ABOGADO IMMEDIATEAMENTE. 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 Avenue Carlisle, PA 17013 LEGAL SERVICES INC 8 Irvine Row Carlisle, PA 17013 717-243-9400 COMPLAINT IN MORTGAGE FORECLOSURE 1. Plaintiff is AAMES CAPITAL CORP., 350 S. Grand Avenue, 47th Floor Los Angeles, CA 90071. 2. The name(s) and address(es) of the Defendant(s) is/are THERESA L. LILLICH, 5203 Meadowbrook Drive, Mechanicsburg, PA 17055 and WILLIAM V. LILLICH, 5203 Meadowbrook Drive, Mechanicsburg, PA 17055, who is/are the mortgagor(s) and real owner(s) of the mortgaged premises hereinafter described. 3. On September 07, 1999 mortgagor(s) made, executed and delivered a mortgage upon the premises hereinafter described to AAMES FUNDING CORP., which mortgage is recorded in the Office of the Recorder of Deeds of Cumberland County as Book 1569 Page 1046. The mortgage has not been assigned unless said assignment to the Plaintiff is hereafter mentioned. The aforementioned mortgage was assigned to: AAMES CAPITAL CORP. by Assignment of Mortgage dated November 03, 1999 as Book 629 Page 196; and these documents are matters of public record and are incorporated herein by reference in accordance with Pennsylvania Rule of Civil Procedure 1019(g). 4. The premises subject to said mortgage is described as attached. 5. The mortgage is in default because monthly payment of principal and interest upon said mortgage due May 01, 2002, and each month thereafter are due and unpaid, and by the terms of said mortgage, upon default in such payments for a period of one month, the entire principal balance and all interest due thereon are collectible forthwith. 6. The following amounts are due on the mortgage: Principal Balance Interest from 04/01/2002 through 12/31/2002 at 8.8100% Per Diem interest rate at $30.88 Attorney's Fee at 5.0% of Principal Balance Late Charges from 05/01/2002 to 12/31/2002 Monthly late charge amount at $103.22 Costs of suit and Title Search Escrow Debit $127,962.22 $8,491.99 $6,398.11 $1,648.92 $750.00 $145,251.24 +$54.45 $145,305.69 7. The Attorney's Fees set forth above are in conformity with the Mortgage documents and Pennsylvania law, and, will be collected in the event of a third party purchaser at Sheriff's Sale. If the Mortgage is reinstated prior to the Sale reasonable Attorney's Fees will be charged based on work actually performed. Notice of Intention to Foreclose and a Notice of Homeowners' Emergency Mortgage Assistance has been sent to Defendant(s) by Certified and regular mail, as required by Act 160 of 1998 of the Commonwealth of Pennsylvania, on the date(s) set forth in the true and correct copy of such notice(s) attached hereto as Exhibit "A". The date of the postmark on the Notice was the same as the date of the Sent by: AAMES 323 210 5039; Loan No.: PA021402 Property Address: 5203 MEADOWBROOK DRIVE MECHANICSBURG, PENNSYLVANIA 17055 Exhibit NAW l..egal Description 10/04/02 3:00PM;JM& #932;Page 10/26 A" ""'4 CuRTAM' Dieoa yr Vw=Q1 at I.M. tiEWCe is "don 7'o++aohb?, U'Iowa, slasd to wit, Asnnsylveai a- 'hose Pantirulsrly bounded sad dc,ar,l>'ad to lla SMZN UO sr a poir.a etc Eka tourhsartarci lisle ltwaaewhrook A:iva, vhich point ie on ¦ ottlVa to Ch? 1tlfC hs, 14 on snV viaq s ;?641U& of =49 Eaat, an a;o distance of 219.67 teat caatit frorn t aAr l iaseaeien of Daezfiatd Uwaue sad Masdovbrook Drivs; thenao SaeC to oat ldtur d410M Naa4?rauh LTivft an asks r-'. . sa sro distance of 14 feet t ale nQ t*td a nod 7 -on ta* d?ainantr Tssnt.oned exam " said 4avi4tap 1iu&, 9Qath 97 degrees 33 m?mtten 33 aocoDds 178,82 feet to a t#oint at land now er isha ai Qeod itopa rerraea- aaid ldae, Owt? Cl ?taC, ve$ 52 minutaa Zapt, 95.03 lset to Sitsa of ?C now m j late of William Z. Killer; chanae 41cxq paid lice, saut4 so de , Heat, 12f rpe fsae to J and cow ax West, and formerly of Qood Sept, Iasi; th4nas a+aas 14 d line, or ?3044?s 14 mit=t 34 sweonda Wbou, 7.43.44 feat to a t Bald lint, Aoitt, the Place ag= Lac Aso. 7 nn C Resubdivisiea plan of Sectiea A. Plan 6, Qood voila larma, dhicb plat is recorded in j COuutr4 Pena l•aa7a the GtFScs of kha . da: of nsada Cie 7n >alaa 301* s], 71 ?tbtrum ?a ZJ t17. Sent by: AAMES 323 210 5039; Aemes Home Loan EXl IBiT ACT 91 NOTICE 10/04/02 3:07PM;JaLEyA #933; Page 1/12 350 S. Grand Avenue 47th Floor Los Angeles. CA 90071 August 22, 2002 TAKE ACTION TO SAVE YOUR HOME FROM FORECLOSURE This is an official notice that the mortgage on your home is in default and the lender intends to fb*Pc1rtse Specific information about the nature of the default is provided in the attached Mees The HOMEOWNER'S MORTGAGE ASSSISTANCF PROGRAM (HFMAP) may be able to help to save Your home. This Notice explains how the program works. Counseling Agency, The name, address and phone number of Consumer Credit Counseling Aaencies serving your County are This Notice contains important legal information. If you have any questions, representatives at the Consumer Credit Counseling Agency may be able to help explain it. You may also want to contact an attomey in your area. The local bar association may be able to help you find a lawyer. LA NOTIFICACION EN ADJUNTO ES DE SUMA IIvIPORTANCIA, PUES AFECTA SU DERECHO A CONTINUAR VIVIENDO EN SU CASA. SI NO COMPRENDE EL CONTENII]O DE ESTA NOTIFICACION OHTENGA UNA TRADUCCION INMEDIATAMENTE LLAMANDO ESTA AGENCIA (PENNSYLVANIA HOUSING FINANCE AGENCY) SIN CARGOS AL NUMERO MENCIONADO ARRIBA. PUEDES SER ELEGIBLE PARA UN PRESTAMO POR EL PROGRAMA LLAMADO "HOMEOWNER'S EMERGENCY MORTGAGE ASSISTANCE PROGRAM'" EL CUAL PUEDE SALVAR SU CASA DE LA PERDIDA DEL DERECHO A REDIMIR SU HIPOTECA. ru CERTIFIED MAIL RECEIPT r-4 97,1d onj?': %0 Cot el ay" Ve"vido"d) William V. Lillich tr 5203 Meadowbrook Drive n Mechanicsburg, PA 17055 ? 0 F€ 1 L_ - U w E LOAN ACCT. NO,: 9538860 o P°'"°°° ORIGINAL LENDER: Aames Home Loan C3 COMBO Pee CURRENT LENDER/SERVICER: Aames Homo Loan,,,, `? naemc+ea o.u,.y Pee - . ' ? E to QJrwatemont ppuka?q ru TaW Pasta a ?. . C3 A n 0009538860 WILLIAM V. LILLICH Malling Address: PO Box 76930. Las Angeles, CA 90076 wPO s 5103 MEALOWBKOOK DRIVE !E Wig MECFIANICSOURG PA 170,; S _ UNDER Sent by: AAMES 323 210 5039; 10/04/02 3:08PM;JetFaz #933;Page 7/12 g 6-V EXViJB A Aemas Home Loan ACT 91 NOTICE CERTIFIED MAIL RECEIPI (1)o,ne6trc Mall Only,- No /r)surancc Cove.lage I1ruvlQea7)- TARE ACTION TO SAVE YOUR HOME FROM FORECLOSURE This is an official notice that the mortgage on your ome is in default- and the lender intends to foreclose. Specific information about the nature of the default is provided in the attached p4a& The HOMEOWNER'S MORTGAGE ASSISTANCE PROGRAM (HEMAP) may be able to help to save your home. This Notice explains how the gLoo.,ram works. To see if HFMAP can helper you must MEET WITH A CONSUMER CREDIT COLTNSELIN-13 AGENCY WITHIN 30 DAYS OF THE DATE OF THIS NOTICE. Take this Notice with you when you meet with the Counseling AgencLr- This Notice contains important legal information. If you have any questions, representatives at the Consumer Credit Counseling Agency may be able to help explain it. You may also want to contact an attorney in your area. The local bar association may be able to help you find a lawyer. L.A NOTIFICACION EN AD]UNTO ES DE SUMA IMPORTANCIA, PUBS AFECTA SU DERECHO A CONTINUAR VIVIENDO EN SU CASA. SI NO COMPRENDE EL CONTENIDO DE ESTA NOTIFICACION OBTENGA UNA TRADUCCION INMEDIATAMENTE LLAMANDO ESTA AGENCIA (PENNSYLVANIA ROUSING FINANCE AGENCY) SIN CARGOS AL NUMERO MENCIONADO ARRIBA. PUEDES SER ELEGIBLE PARA LIN PRESTAMO POR EL. PROGRAMA LLAMADO "HOMEOWNER'S EMERGENCY MORTGAGE ASSISTANCE PROGRAM" EL COAL PUEDE SALVAR SU CASA DE LA PERDIDA DEL DERECHO A REDIMIR SLI "OT>EACA. Theresa L. Lillich 5203 Meadowbrook Drive Mechanicsburg, PA 17055 LOAN ACCT. NO.: 9538860 ORIGINAL LENDER: Aames Home Loan CURRENT LENDER/SERVICER: Aames Home Loan totalling Address: PO Sox 79990, Leas Angeles. CA 90676 C3 ?.in NWe III ra ? Peaeape >a C3 Certlfled Pew C3 Rehm FMwlp Fee C3 rW) (Eexlerawnent gU m aewrkwd Do,= G Eow"'waL= August 22, 2002 Y'•, a: w a $vrc? v.. ti.r ,ri. eXAM 7D ?t X" ... Yaw P"U" 8 Fees Fjt? 000 9538860 TilEltESA L. LILLICH 5203 MEADO'4 RIL()OK DRIVE MEC H - _ ANIGSIIUftC. PA 117055 350 S. Grand Avenue 47th Floor Los Angeles, CA 90071 Sent by: AAMES Page 2 of 5 323 210 5039; 10/04/02 3:07PMjgjERx #933;Page 2/12 HOMEOWNER'S EMERGENCY MORTGAGE ASSISTANCE PROGRAM IF YOU COMPLY WITH THE PROVISIONS OF THE HOMEOWNER'S EMERGENCY MORTGAGE ASSIS TACE ACT OF 1983 (THE "ACT"), YOU MAY BE ELIGIBLE FOR EMERGENCY MORTGAGE ASSISTANCE: • IF YOUR DEFAULT HAS BEEN CAUSED BY CIRCUMSTANCES BEYOUND YOUR CONTROL, • IF YOU HAVE A REASONABLE PROSPECT OF BEING ABLE TO PAY YOUR MORTGAGE PAYMENTS, AND • IF YOU MEET OTHER ELIGIBILITY REQUIREMENTS ESTABLISHED BY THE PENNSYLVANIA HOUSING FINANCE AGENCY. TEMPORARY STAY OF FORECLOSURE,---Under the Act, you are entitled to a temporary stay of foreclosure on your mortgage for thirty (30) days from the date of this Notice. During that time you must arrange and attend a "face-to-face" meeting with one of the consumer credit counseling agencies listed at the this Notice. It is only necessary to schedule one face-to-face meeting. Advise your lender immediately of your intentions. APPLICATION FOR MORTGAGE ASSISTANCE-Your mortgage is in default for the reasons set forth later in this Notice (see page 3 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 Homeowner's Emergency Mortgage Assistance Program. To do so, you must fill out, sign and file a completed Homeowner's Emergency Assistance Program Application with one of the designated consumer credit counseling agencies listed at the end of this Notice. Only consumer credit counseling agencies have applications for the program and they will assist you in submitting a complete application to the Pennsylvania Housing Finance Agency. Your application MIDST be filed or postmarked within thirty (30) days of your face-to-face meeting. YOU UST 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 HE DENIED. CONSUMER CREDTT 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 designated Sent by: AAMES 323 210 5039; 10/04/02 3:07PM;Jetrax #933;Page 3/12 Page 3 of 5 AGENCY ACL ION---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 proceeding will be pursued against you if you have met the time requirements set forth above. You will be notified directly by the Pennsylvania Housing Finance Agency of its decision on your application. NOTE; IF YOU ARE CURRENTLY PROTECTED BY THE FILING OF A PETITION IN BANKRUPTCY, TIJ.E FOLLOWING PART OF THIS NOTICE IS FOR INFORMATION PURPOSES ONLY AND SHOULD NOT BE CONSIDERED AS AN ATTEMPT TO COLLECT THE DEBT_ (If you have filed bankruptcy you can still apply for Emergency Mortgage Assistance.) HOW TO CURE YOUR MORTGAGE DEFAULT (Bring it up to date). NATURE OF THE DEFAULT--The MORTGAGE debt held by the above creditor on your property located at: 5203 Meadowbrook Drive, Mechanicsburg, PA 170$5 IS SERIOUSLY IN DEFAULT because: A. YOU HAVE NOT MADE THE MONTHLY MORTGAGE PAYMENTS for the following months and the following amounts are now past due: Description Monthly Payments of $1032.24 per month are due from 05/01/02 to 08/01/02. Late charges of $103.22 per month are due from 05/01/02 to 08/01/02. Uncollected late charges NSF Fee RPA Admin Fee Unapplied Funds Amount due $4128.96 $412.88 $1132.82 $40.00 $5.00 $(550.00) TOTAL AMOUNT PAST DUE: $5169.66 _ w? Sent by: AAMES 323 210 5039; 10/04/02 3:07PM , ,JeffjuL_#933; Page 4/12 Page 4 of 5 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 YS $5169.66, PLUS ANY MORTGAGE PAYMENTS AND LATE CHARGES WHICH BECOME DUE DURING THE THIRTY (30) DAY PERIOD. Payments must be made either by cash cashier's check certified check or money order made payable and sent to: AAMES HOME LOAN 350 South Grand Avenue, 4P Floor Los Angeles, CA 90071 _ 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 leader intends to exercise its rights to accelerate the mortgage 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 attorneys to start legal action to foreclose upon your mortgaged proper y- IF THE MORTGAGE IS FORECLOSED UPON---The mortgaged property will be sold by the Sheriff to pay off the mortgage debt. If the lender refers your case to its attorneys, but you cure the delinquency before the lender 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 will have to pay all reasonable attorney's fees actually incurred by the lender even if they exceed $50.00. Any attorney's fee will be added to the amount you owe the lender, which may also include other reasonable costs. If you cure the default within the THLRTY (30) DAY period, you will not be required to pay attorney's fees. OTHER LENDER REMEDIES--The lender may also sue you personally for the unpaid principal balance and 211 other sums due under the mortgage. wi,unr Liv mr, icnucr ana ov perrormine any other requirements under the mortgage 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 six (6) months from the date of this Notice. A notice of the actual date of the Sheriffs Sale will be sent to you before the We. 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. RIGHT TO CURE THE DEFAULT PRIOR TO SHERIFF'S SALE---If you have not cured the default within the THIRTY (30) DAY period and foreclosure proceeding have begun, you still have the right to cure the default and prevent the sale at any time up to one hour before the Sheriffs Sale You may do so by Sent by: AAMES 323 210 5039; 10/04/02 3:08PM ,JetFaz #933; Page 5/12 Page 5 of 5 HOW TO CONTACT THE LENDER: Aames Home Loan Camp Hill Branch 214 Senate Avenue Suite #600 Camp Hill, PA 17011 Phone Number: (717) 731-1010 Fax Number: (717) 731-0909 Contact Person: Robin Blazina EFFECT OF SHERIFF'S SALE---You should realize that a Sheriffs Sale will end your ownership of the mortgaged property and your right to occupy it. If you continue to live in the property after the Sheriff s Sale, a lawsuit to remove you and your furnishings and other belongings could be started by the lender at any time. ASSUMPTION OF MORTGAGE---You may sell or transfer your home to a buyer or transferee who will assume the mortgage debt, provided that all the outstanding payments, charges and attorney's fees and costs are paid prior to or at the sale and that the other requirements of the mortgage are satisfied. YOU MAY ALSO HAVE THE RIGHT: • TO SELL THE PROPERTY TO OBTAIN MONEY TO PAY OFF THE MORTGAGE, DEBT OR TO BORROW MONEY FROM ANOTHER LENDING INSTITUTION TO PAY OFF THIS DEBT. • TO HAVE THIS DEFAULT CURED BY ANY THIRD PARTY ACTING ON YOUR BEHALF. • TO HAVE THE MORTGAGE RESTORED TO THE SAME POSITION AS IF NO DEFAULT HAD OCCURRED, IF YOU CURE THE DEFAULT. (HOWEVER, YOU DO NOT HAVE THIS RIGHT TO CURE: YOUR DEFAULT 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 HAVE TO SUCH ACTION BY THE LENDER. • TO SEEK PROTECTION UNDER THE FEDERAL BANKRUPTCY LAW. CONSUMER CREDIT COUNSELING AGENCIES SERVING YOUR COUNTY (Please see attached paQe(sl.) Special Assets Department Bertha Torres (800) 697-8974 Sent by: AAMES 323 210 5039; 10/04/02 3:08PM;1fiL[9c N933;Page 6/12 PENNSYLVANIA HOUSING FINANCE AGENCY HOMEOWNER'S EMERGENCY MORTGAGE ASSISTANCE PROGRAM CONSUMER CREDIT COUNSELING AGENCIES CUMBERLAND COUNTY Adams County Housing Authority 139.143 Carlisle St. Gettysburg, PA 17325 (717) 334-1518 CCCS of Western PA 2000 Linglestown Road Harrisburg, PA 17102 (717) 541-1757 Community Action Commission of Captial Region 1514 perry Street Harrisburg, PA 17104 (717) 232-9757 Financial Counseling Services of Franklin 43 Philadelphia Avenue Waynesboro, PA 17268 (717) 762-3285 Loveship, Inc. 2320 North 5th Street Harrisburg, PA 17110 (717) 232-2201 PHFA 2101 North Front Street Harrisburg, PA 17110 800-342-2397 Urban League of Metropolitan Hbg 2107 N. 6th Street Harrisburg, PA 17101 (717) 234-5925 The PA Housing Finance Agency can he reached TOLL, FREE at 1(800) 342-2397 or 1-717-780-3940 w -Qj o SHERIFF'S RETURN - REGULAR CASE NO: 2002-06092 P COMMONWEALTH OF PENNSYLVANIA: COUNTY OF CUMBERLAND AAMES CAPITAL CORP VS LILLICH THERESA L ET AL RONALD HOOVER , Sheriff or Deputy Sheriff of Cumberland County,Pennsylvania, who being duly sworn according to law, says, the within COMPLAINT - MORT FORE LILLICH WILLIAM V DEFENDANT the , at 1946:00 HOURS, on the 30th day of December , 2002 at 5203 MEADOWBROOK DRIVE MECHANICSBURG, PA 17055 WILLIAM V LILLICH, HUSBAND was served upon by handing to ADULT IN CHARGE a true and attested copy of COMPLAINT - MORT FORE together with and at the same time directing His attention to the contents thereof. Sheriff's Costs: Docketing 6.00 Service .00 Affidavit .00 Surcharge 10.00 .00 16.00 Sworn and Subscribed to before me this j3 day of A.D. ??6thonotary So Answers: R. Thomas Kline 12/31/2002 GOLD13ECK MCCAFFERTY MCKEEVER By. Deputy Sheriff SHERIFF'S RETURN - REGULAR CASE NO: 2002-06092 P COMMONWEALTH OF PENNSYLVANIA: COUNTY OF CUMBERLAND AAMES CAPITAL CORP VS LILLICH THERESA L ET AL RONALD HOOVER , Sheriff or Deputy Sheriff of Cumberland County,Pennsylvania, who being duly sworn according to law, says, the within COMPLAINT - MORT FORR was served upon the LILLICH THERESA L DEFENDANT at 1946:00 HOURS, on the 30th day of December , 2002 at 5203 MEADOWBROOK DRIVE MECHANCISBURG, PA 17055 WILLIAM V LILLICH by handing to a true and attested copy of COMPLAINT - MORT FORE together with and at the same time directing His attention to the contents thereof. Sheriff's Costs: Docketing 18.00 Service 7.59 Affidavit .00 Surcharge 10.00 .00 35.59 Sworn and Subscribed to before me this IJ5 day of JBd3 A. D. Prothonotary So Answers: R. Thomas Kline ' 12/31/2002 GOLDBECK MCCAFFERTY MCKEEVER By: Deputy Sheriff In the Court of Common Pleas of Cumberland County AAMES CAPITAL CORP. 350 S. Grand Avenue 47th Floor Los Angeles, CA 90071 Plaintiff THERESA L. LILLICH VS. WILLIAM V. LILLICH (Mortgagor(s) and Record Owner(s)) 5203 Meadowbrook Drive Mechanicsburg, PA 17055 Defendant(s) PRAECIPE FOR JUDGMENT No. 02-6092C THIS LAW FIRM IS A DEBT COLLECTOR AND WE ARE ATTEMPTING TO COLLECT A DEBT OWED TO OUR CLIENT. ANY INFORMATION OBTAINED FROM YOU WILL BE USED FOR THE PURPOSE OF COLLECTING THE DEBT. Enter the Judgment in favor of Plaintiff and against THERESA L. LILLICH and WILLIAM V. LILLICH by default for want of an Answer. Assess damages as follows: Debt Interest - 04/01/2002 to 01/31/2003 Total (Assessment of Damages attached) $146,366.19 I CERTIFY THAT FOREGOING ASSESSMENT OF DAMAGES IS FOR SPECIFIED AMOUNTS ALLEGED TO BE DUE IN THE COMPLAINT AND IS CALCULABLE AS A SUM CERTAIN FROM THE COMPLAINT. I certify that written notice of the intention to file this praecipe was mailed or delivered to the party against whom judgment is to be entered and to his attorney of record, if any, after the default occurred mat bast ten vs prior to the date of the filing of this praecipe. A copy of the notice is attached. R.C.P. 237.1 / / -x / I I.D. #161,2 V AND NOW /" p?CY33 Judgment is entered in favor of AAMES CAPITAL CORP. and against THERESA L. LILLICH and WILLIAM V. LILLICH by default for t of an Answer and damages assessed in the sum of $146,366.19 as per the above c fication. Prothonotary GOLDBECK McCAFFERTY & McKEEVER BY: Joseph A: Goldbeck, Jr. Attorney I.D. #16132 Suite 506 - The Bourse Bldg. 111 S. Independence Mall East Philadelphia, PA 19106 215-627-1322 Attorney for Plaintiff AAMES CAPITAL CORP. 350 S. Grand Avenue 47th Floor Los Angeles, CA 90071 THERESA L. LILLICH VS. WILLIAM V. LILLICH (Mortgagor(s) and Record owner(s)) 5203 Meadowbrook Drive Mechanicsburg, PA 17055 IN THE COURT OF COMMON PLEAS Plaintiff of Cumberland County CIVIL ACTION LAW ACTION OF MORTGAGE FORECLOSURE Defendant(s) No. 02-6092C ORDER FOR JUDGMENT Please enter Judgment in favor of AAMES CAPITAL CORP., and against THERESA L. LILLICH and WILLIAM V. LILLICH for failure to file an Answer in the above action within (20) days (or sixty (60) days if defendant is the United States of America) from the date of service of the Complain , t the sum of $146,366.19. Joseph A. Gi Attorney for I hereby certify that the above names are correct and that the precise residence address of the judgment creditor is AAMES CAPITAL CORP. 350 S. Grand Avenue 47th Floor Los Angeles, CA 90071 and that the name(s) and last known address(es) of the Defendant(s) is/are THERESA L. LILLICH, 5203 Meadowbrook Drive Mechanicsburg, PA 17055 and WILLIAM V. LILLICH, 5203 Meadowbrook Drive Mechanicsburg, PA 17055; GOLDBECK o lAFMkTT BY: Joseph A. dbeck, Jr. Attorney for Pl ' tiff ASSESSMENT OF DAMAGES TO THE PROTHONOTARY: Kindly assess the damages in this case to be as follows: Principal Balance $127,962.22 Interest from 04/01/2002 through $9,449.27 01/31/2003 Attorney's Fee at 5.0000% of principal $6,398.11 balance Late Charges $1,752.14 Costs of Suit and Title Search $750.00 Escrow Balance Deficit $54.45 ($0.00) BY: Joseph A. Attorney for P] $146,366.19 Jr. AND NOW, this day of 2003 damages are assessed as above. Pro Prothy VERIFICATION OF NON-MILITARY SERVICE The undersigned, as the representative for the Plaintiff corporation within named do hereby verify that I am authorized to make this verification on behalf of the Plaintiff corporation and that the facts set forth in the foregoing verification of Non- Military Service are true and correct to the best of my knowledge, information and belief. I understand that false statements therein are made subject to penalties of 18 Pa. C.S. 4904 relating to unsworn falsification to authorities. 1. That the above named Defendant, WILLIAM V. LILLICH, is about unknown years of age, that Defendant's last known residence is 5203 Meadowbrook. Drive, Mechanicsburg, PA 17055, and is engaged in the unknown business located at unknown address. 2. That Defendant is not in the military or Naval Service of the United States or its Allies, or otherwise within the provisions of the Soldiers' and Sailors' Civil Relief Action of Congress of 1940 and its Amendments. r, ? Date: VERIFICATION OF NON-MILITARY SERVICE The undersigned, as the representative for the Plaintiff corporation within named do hereby verify that I am authorized to make this verification on behalf of the Plaintiff corporation and that the facts set forth in the foregoing verification of Non- Military Service are true and correct to the best of my knowledge, information and belief. I understand that false statements therein are made subject to penalties of 18 Pa. C.S. 4904 relating to unsworn falsification to authorities. 1. That the above named Defendant, THERESA L. LILLICH, is about unknown years of age, that Defendant's last known residence is 5203 Meadowbrook Drive, Mechanicsburg, PA 17055, and is engaged in the unknown business located at unknown address. 2. That Defendant is not in the Military or Naval Service of the United States or its Allies, or otherwise within the provisions of the Soldiers' and Sailors' Civil Relief Action of Congress of 1940 and its Amendments. n Date: 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. DATE OF THIS NOTICE: January 21, 2003 TO: WILLIAM V. LILLICH 5203 Meadowbrook Drive Mechanicsburg, PA 17055 AAMES CAPITAL CORP. 350 S. Grand Avenue 47th Floor Los Angeles, CA 90071 vs. THERESA L. LILLICH WILLIAM V. LILLICH (Mortgagor(s) and Record Owner(s)) 5203 Meadowbrook Drive Mechanicsburg, PA 17055 TO: WILLIAM V. LILLICH 5203 Meadowbrook Drive Mechanicsburg, PA 17055 Plaintiff Defendant(s) In the Court of Common Pleas of Cumberland County CIVIL ACTION - LAW Action of Mortgage Foreclosure Term No. 02-6092C 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: CUMBERLAND COUNTY BAR ASSOCIATION 2 Liberty Avenue Carlisle, PA 17013 LEGAL SERVICES INC 8 Irvine Row Carlisle, PA 17013 717-243-9400 C ICCAFFER {FEVER B seph A. Goldbeck, Jr., Esq. Attomey for Plaintiff Suite 500 - The Bourse Bldg. 111 S. Independence Mall Fast Philadelphia, PA 19106 215-627-1322 THIS LAW FIRM IS A DEBT COLLECTOR AND WE ARE ATTEMPTING TO COLLECT A DEBT OWED TO OUR CLIENT. ANY INFORMATION OBTAINED FROM YOU WILL BE USED FOR THE PURPOSE OF COLLECTING THE DEBT. DATE OF THIS NOTICE: January 21, 2003 TO: THERESA L. LILLICH 5203 Meadowbrook Drive Mechanicsburg, PA 17055 AAMES CAPITAL CORP. 350 S. Grand Avenue 47th Floor Los Angeles, CA 90071 vs. THERESA L. LILLICH WILLIAM V. LILLICH (Mortgagor(s) and Record Owner(s)) 5203 Meadowbrook Drive Mechanicsburg, PA 17055 TO: THERESA L. MI LLICH 5203 Meadowbrook Drive Mechanicsburg, PA 17055 Plaintiff Defendant(s) In the Court of Common Pleas of Cumberland County CIVIL ACTION - LAW Action of Mortgage Foreclosure Term No. 02-6092C 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: CUMBERLAND COUNTY EAR ASSOCIATION 2 L,!r A-- Carlisle, PA 17013 LEGAL SERVICES INC 8 Irvine Row Carlisle, PA 17013 717-243-9400 4*seph *cCAFFEERR {FEVER A. Goldbeck, Jr., Esq. Attorney for Plaintiff Suite 500 - The Bourse Bldg. 11 I S. Independence Mall East Philadelphia, PA 19106 215-627-1322 Rule of Civil Rrocedure No. 236 - Revised IN THE COURT OF COMMON PLEAS OF Cumberland COUNTY, PENNSYLVANIA CIVIL ACTION - LAW AAMES CAPITAL CORP. 350 S. Grand Avenue 47th Floor Los Angeles, CA 90071 Plaintiff VS. THERESA L. LILLICH WILLIAM V. LILLICH (Mortgagors and Record Owner(s)) 5203 Meadowbrook Drive Mechanicsburg, PA 17055 Defendant(s) No. 02-6092C THIS LAW FIRM IS A DEBT COLLECTOR AND WE ARE ATTEMPTING TO COLLECT A DEBT OWED TO OUR CLIENT. ANY INFORMATION OBTAINED FROM YOU WILL BE USED FOR THE PURPOSE OF COLLECTING THE DEBT. NOTICE Notice is given that a judgment in the above-captioned matter has been entered against you. Curt Long Prothonotary By: . If you have any questions concerning the above, please contact: Joseph A. Goldbeck, Jr. Goldbeck McCafferty & McKeever Suite 500 - The Bourse Bldg. 111 S. Independence Mall East Philadelphia, PA 19106 215-627-1322 ?, o -lz PRAECIPE FOR WRIT OF EXECUTION - (MORTGAGE FORECLOSURE) P.R.C.P 3180-3183 Joseph A. Goldbeck, Jr. Attorney I.D.#16132 Suite 560 - The Bourse Bldg. 111 S. Independence Mall East Philadelphia, PA 19106 215-627-1322 Attorney for Plaintiff AAMES CAPITAL CORP. 350 S. Grand Avenue 47th Floor Los Angeles, CA 90071 vs. THERESA L. LILLICH WILLIAM V. LILLICH Mortgagor(s) and Record Owner(s) 5203 Meadowbrook Drive Mechanicsburg, PA 17055 Plaintiff Defendant(s) IN THE COURT OF COMMON PLEAS of Cumberland County CIVIL ACTION - LAW ACTION OF MORTGAGE FORECLOSURE No. 02-6092C PRAECIPE FOR WRIT OF EXECUTION TO THE PROTHONOTARY: Issue Writ of Execution in the above matter: Amount Due Interest from 04/01/2002 to 01/31/2003 at 8.8100% (Costs to be added) $146,366.19 Vv nlX,rt UArrEKf McKEEVER BY: Joseph oldbeck, Jr. Attorney for intff ?/ f' ?. -t- 'l / ' ?? -!q ?9. ? ? C o ? ? c,., ? ^?? cZ 6? ? c c ? ? d I ? ? ? ? ? ?? \ r. ? ? .? ?, r-? c. :> _ , ?? ?, . y ,yam ?. F.. .. -? l ? p" H b ? U y ? eo ? o 0 x?oQ y U U ? aj 'd ?E w W ro N?? .-? N rn0 a d " good ?a u oa. ? i b w? as " 0 d n °' " ? o E a b n e d a U a n c z a as a °obbN 0 w o Q . kn a " o a v'a d c U ? ALL THAT CERTAIN PIECE OR PARCEL OF LAND, SITUATE IN HAMPDEN TOWNSHIP, CUMBERLAND COUNTY, PENNSYLVANIA, MORE PARTICULARLY BOUNDED AND DESCRIBED AS FOLLOWS, TO WIT: BEGINNING AT A POINT ON THE SOUTHEASTERN LINE OF MEADOWBROOK DRIVE, WHICH POINT IS ON A CURVE TO THE LEFT HAVING A RADIUS OF 245 FEET, AN ARC DISTANCE OF 219.67 FEET FROM THE INTERSECTION OF DEARFIELD AVENUE AND MEADOWBROOK DRIVE; THENCE CONTINUING ALONG MEADOWBROOK'DRIVE ON SAID CURVE, AN ARC DISTANCE OF 90 FEET TO THE LINE DIVIDING LOTS 8 AND 7 ON THE HEREINAFTER MENTIONED PLAN;THENCE ALONG SAID DIVIDING LINE, SOUTH 82 DEGREES 33 MINUTES 33 SECONDS EAST, 1786.82 FEET TO A POINT AT LAND NOW OR LATE OF GOOD HOPE TERRACE; THENCE ALONG SAID LINE, SOUTH 01 DEGREE 52 MINUTES EAST 95.03 FEET TO A POINT AT LAND NOW OR LATE OF WILLIAM C. MILLER; THENCE ALONG SAID LINE SOUTH 88 DEGREES 10 MINUTES WEST 126.54 FEET TO LAND FORMERLY OF GOOD HOPE, INC.; THENCE ALONG SAID LINE NORTH 39 DEGREES 10 MINUTES 30 SECONDS WEST 143.04 FEET TO A POINT, THE PLACE OF BEGINNING. BEING LOT NO. 7 ON RESUBDIVISION PLAN OF SECTION A, PLAN B, GOOD HOPE FARMS, WHICH PLAN IS RECORDED IN THE OFFICE OF THE RECORDER OF DEEDS OF CUMBERLAND COUNTY, PENNSYLVANIA, IN PLAN BOOK 22, PAGE 147. TAX PARCEL #10-18-1319-154 Goldbeck McCafferty & McKeever BY: Joseph A. Goldbeck, Jr. Attorney I.D. #26132 Suite 500 - The Bourse Bldg. 111 S. Independence Mall East Philadelphia, PA 19106 215-627-1322 Attorney for Plaintiff AAMES CAPITAL CORP. 350 S. Grand Avenue 47th Floor Los Angeles, CA 90071 VS. THERESA L. LILLICH WILLIAM V. LILLICH (Mortgagor(s) and Record Owner(s)) 5203 Meadowbrook Drive Mechanicsburg, PA 17055 Plaintiff Defendant(s) AFFIDAVIT PURSUANT TO RULE 3129 No. 02-6092C AAMES CAPITAL CORP., Plaintiff in the above action, by its attorney, Joseph A. Goldbeck, Jr., Esquire, sets forth as of the date the praecipe for the writ of execution was filed the following information concerning the real property located at: 5203 Meadowbrook Drive Mechanicsburg, PA 17055 1.Name and address of Owner(s) or Reputed Owner(s): THERESA L. LILLICH 5203 Meadowbrook Drive Mechanicsburg, PA 17055 WILLIAM V. LILLICH 5203 Meadowbrook Drive Mechanicsburg, PA 17055 2. Name and address of Defendant(s) in the judgment: THERESA L. LILLICH 5203 Meadowbrook Drive Mechanicsburg, PA 17055 WILLIAM V. LILLICH 5203 Meadowbrook Drive Mechanicsburg, PA 17055 3. Name and last known address of every judgment creditor whose judgment is a record lien on the property to be sold: IN THE COURT OF COMMON PLEAS of Cumberland County CIVIL ACTION - LAW ACTION OF MORTGAGE FORECLOSURE PA DEPARTMENT OF PUBLIC WELFARE - Bureau of Child Support Enforcement Health and Welfare Bldg. - Room 432 P.O. Box 2675 Harrisburg, PA 17105-2675 DOMESTIC RELATIONS OF CUMBERLAND COUNTY PO Box 320 Carlisle, PA 17013 4. Name and address of the last recorded holder of every mortgage of record: BENEFICIAL CONSUMER DISCOUNT CO. 961 Weigel Drive Elmhurst, IL 60126 BENEFICIAL CONSUMER DISCOUNT CO. d/b/a BENEFICAL MORTGAGE CO. OF PA 4910 Carlisle Pike, #104 Mechanicsburg, PA 17055 5. Name and address of every other person who has any record interest in or record lien on the property and whose interest may be affected by the sale: 6. Name and address of every other person of whom the plaintiff has knowledge who has any record interest in the property which may be affected by the sale. 7. Name and address of every other person of whom the plaintiff has knowledge who has any interest in the property which may be affected by the sale. (attach separate sheet if more space is needed) I verify that the statements made in this affidavit are true and correct to the best of my personal knowledge or information and belief. I understand that false statements herein are made subject to the penalties of 18 Pa. C.S. Section 4904 relating to unworn falsification to authorities. DATED: January 31, 2003 GOLDBECK M?FEKT) BY: Joseph A. beck, Jr., Attorney for Pla' iff t-:r i ^ L' 02-6092C GOLDBECK McCAFFERTY & McKEEVER BY: Josepl A. Goldbeck, Jr. Attorney I.D.#16132 Suite 500 - The Bourse Bldg. 111 S. Independence Mall East Philadelphia, PA 19106 215-627-1322 Attorney for Plaintiff AAMES CAPITAL CORP. 350 S. Grand Avenue 47th Floor Los Angeles, CA 90071 Plaintiff vs. THERESA L. LILLICH WILLIAM V. LILLICH Mortgagor(s) and Record Owner(s) 5203 Meadowbrook Drive Mechanicsburg, PA 17055 Term No. 02-6092C THIS LAW FIRM IS A DEBT COLLECTOR AND WE ARE ATTEMPTING TO COLLECT A DEBT. THIS NOTICE IS SENT TO YOU IN AN ATTEMPT TO COLLECT A DEBT. ANY INFORMATION OBTAINED FROM YOU WILL BE USED FOR THAT PURPOSE. NOTICE OF SHERIFF'S SALE OF REAL PROPERTY TO: LILLICH, THERESA L. THERESA L. LILLICH 5203 Meadowbrook Drive Mechanicsburg, PA 17055 Your house at 5203 Meadowbrook Drive, Mechanicsburg, PA 17055 is scheduled to be sold at Sheriffs Sale on Wednesday, June 11, 2003, at 10:00 AM, in Commissioners Hearing Rm 2nd FL Courthouse to enforce the court judgment of $146,366.19 obtained by AAMES CAPITAL CORP. against you. NOTICE OF OWNER'S RIGHTS YOU MAY BE ABLE TO PREVENT THIS SHERIFF'S SALE To prevent this Sheriffs Sale you must take immediate action: IN THE COURT OF COMMON PLEAS of Cumberland County CIVIL ACTION - LAW ACTION OF MORTGAGE FORECLOSURE 1 • The sale will be cancelled if you pay to AAMES CAPITAL CORP., the back payments, late charges, costs and reasonable attorney's fees due. To find out how much you must pay call: 215-627-1322 02-6092C 2. Y'ou may be able to stop the sale by filing a petition asking the Court to strike or open judgment, if the judgment was improperly entered. You may also ask the Court to postpone the sale for good cause. 3. You may also be able to stop the sale through other legal proceedings. You may need an attorney to assert your rights. The sooner you contact one, the more chance you will have of stopping the sale. (See notice below on how to obtain an attorney). YOU MAY STILL BE ABLE TO SAVE YOUR PROPERTY AND YOU HAVE OTHER RIGHTS EVEN IF THE SHERIFF'S SALE DOES NOT TAKE PLACE 1. If the Sheriffs Sale is not stopped, your property will be sold to the highest bidder. You may find out the price bid price by calling the Sheriff of 717-240-6390. 2. You may be able to petition the Court to set aside the sale if the bid price was grossly inadequate compared to the value of your property. 3. The sale will go through only if the buyer pays the Sheriff the full amount due in the sale. To find out if this has happened, you may call the Sheriff of 717-240-6390. 4. If the amount due from the Buyer is not paid to the Sheriff, you will remain the owner of the property as if the sale never happened. 5. You have a right to remain in the property until the full amount due is paid to the Sheriff and the Sheriff gives a deed to the buyer. At that time, the buyer may bring legal proceedings to evict you. 6. You may be entitled to a share of the money which was paid for your house. A schedule of distribution of the money bid for your house will be filed by the Sheriff thirty (30) days from the date of the Sheriffs Sale. This schedule will state who will be receiving that money. The money will be paid out in accordance with this schedule unless exceptions (reasons why the proposed distribution is wrong) are filed with the Sheriff within ten (10) days after the schedule of distribution is filed. 7. You may also have other rights and defenses, or ways of getting your house back, if you act immediately after the sale. YOU SHOULD TAKE THIS PAPER TO YOUR LAWYER AT ONCE. IF YOU DO NOT HAVE A LAWYER OR CANNOT AFFORD ONE, GO TO OR TELEPHONE THE OFFICE LISTED BELOW TO FIND OUT WHERE YOU CAN GET LEGAL HELP. CUMBERLAND COUNTY BAR ASSOCIATION 2 Liberty Avenue Carlisle, PA 17013 LEGAL SERVICES INC 8 Irvine Row Carlisle, PA 17013 ra ?-? ?- _ ,._; -? ?`'?? ? n ? , _ i . . ' ? C ?? `t ? ., ? , y? \. _ ? _ ? l ^ J ?? ?u ?? 02-6092C GOLDBECK McCAFFERTY & McKEEVER BY: Joseph A. Goldbeck, Jr. Attorney I.D.#16132 Suite 500 - The Bourse Bldg. 111 S. Independence Mall East Philadelphia, PA 19106 215-627-1322 Attorney for Plaintiff AAMES CAPITAL CORP. 350 S. Grand Avenue 47th Floor Los Angeles, CA 90071 Plaintiff vs. THERESA L. LILLICH WILLIAM V. LILLICH Mortgagor(s) and Record Owner(s) 5203 Meadowbrook Drive Mechanicsburg, PA 17055 Term No. 02-6092C THIS LAW FIRM IS A DEBT COLLECTOR AND WE ARE ATTEMPTING TO COLLECT A DEBT. THIS NOTICE IS SENT TO YOU IN AN ATTEMPT TO COLLECT A DEBT. ANY INFORMATION OBTAINED FROM YOU WILL BE USED FOR THAT PURPOSE. NOTICE OF SHERIFF'S SALE OF REAL PROPERTY TO: LILLICH, WILLIAM V. WILLIAM V. LILLICH 5203 Meadowbrook Drive Mechanicsburg, PA 17055 Your house at 5203 Meadowbrook Drive, Mechanicsburg, PA 17055 is scheduled to be sold at Sheriffs Sale on Wednesday, June 11, 2003, at 10:00 AM, in Commissioners Hearing Rm 2nd FL Courthouse to enforce the court judgment of $146,366.19 obtained by AAMES CAPITAL CORP. against you. NOTICE OF OWNER'S RIGHTS YOU MAY BE ABLE TO PREVENT THIS SHERIFF'S SALE To prevent this Sheriffs Sale you must take immediate action: IN THE COURT OF COMMON PLEAS of Cumberland County CIVIL ACTION - LAW ACTION OF MORTGAGE FORECLOSURE 1. The sale will be cancelled if you pay to AAMES CAPITAL CORP., the back payments, late charges, costs and reasonable attorney's fees due. To find out how much you must pay call: 215-627-1322 02-6092C 2. You may be able to stop the sale by filing a petition asking the Court to strike or open judgment, if the judgment was improperly entered. You may also ask the Court to postpone the sale for good cause. 3. You may also be able to stop the sale through other legal proceedings. You may need an attorney to assert your rights. The sooner you contact one, the more chance you will have of stopping the sale. (See notice below on how to obtain an attorney). YOU MAY STILL BE ABLE TO SAVE YOUR PROPERTY AND YOU HAVE OTHER RIGHTS EVEN IF THE SHERIFF'S SALE DOES NOT TAKE PLACE. 1. If the Sheriffs Sale is not stopped, your property will be sold to the highest bidder. You may find out the price bid price by calling the Sheriff of 717-240-6390. 2. You may be able to petition the Court to set aside the sale if the bid price was grossly inadequate compared to the value of your property. 3. The sale will go through only if the buyer pays the Sheriff the full amount due in the sale. To find out if this has happened, you may call the Sheriff of 717-240-6390. 4. If the amount due from the Buyer is not paid to the Sheriff, you will remain the owner of the property as if the sale never happened. 5. You have a right to remain in the property until the full amount due is paid to the Sheriff and the Sheriff gives a deed to the buyer. At that time, the buyer may bring legal proceedings to evict you. 6. You may be entitled to a share of the money which was paid for your house. A schedule of distribution of the money bid for your house will be filed by the Sheriff thirty (30) days from the date of the Sheriffs Sale. This schedule will state who will be receiving that money. The money will be paid out in accordance with this schedule unless exceptions (reasons why the proposed distribution is wrong) are filed with the Sheriff within ten (10) days after the schedule of distribution is filed. 7. You may also have other rights and defenses, or ways of getting your house back, if you act immediately after the sale. YOU SHOULD TAKE THIS PAPER TO YOUR LAWYER AT ONCE. IF YOU DO NOT HAVE A LAWYER OR CANNOT AFFORD ONE, GO TO OR TELEPHONE THE OFFICE LISTED BELOW TO FIND OUT WHERE YOU CAN GET LEGAL HELP. CUMBERLAND COUNTY BAR ASSOCIATION 2 Liberty Avenue Carlisle, PA 17013 LEGAL SERVICES INC 8 Irvine Row Carlisle, PA 17013 ? ?. c - ?.; _ T T ti.; i:? ITi; , ?„? / G'- ' ?'? - 1_? ? . __ _ (_. ? _ WRIT OF EXECUTION and/or ATTACHMENT COMMONWEALTH OF PENNSYLVANIA) NO 02-6092 Civil COUNTY OF CUMBERLAND) CIVIL ACTION - LAW TO THE SHERIFF OF CUMBERLAND COUNTY: To satisfy the debt, interest and costs due AAMES CAPITAL CORP., Plaintiff (s) From THERESA L. LILLICH AND WILLIAM V. LILLICH, 5203 MEADOWBROOK DRIVE, MECHANICSBURG, PA 17055 (1) You are directed to levy upon the property of the defendant (s)and to sell SEE LEGAL DESCRIPTION. (2) You are also directed to attach the property of the defendant(s) not levied upon in the possession of GARNISHEE(S) as follows: and to notify the gamishee(s) that: (a) an attachment has been issued; (b) the garnishee(s) is enjoined from paying any debt to or for the account of the defendant (s) and from delivering any property of the defendant (s) or otherwise disposing thereof, (3) If property of the defendant(s) not levied upon an subject to attachment is found in the possession of anyone other than a named garnishee, you are directed to notify him/her that he/she has been added as a garnishee and is enjoined as above stated. Amount Due $146,366.19 L.L. $.50 Interest FROM 4/1/02 TO 1/31/03 AT 8.8100% Atty's Comm % Due Prothy $1.00 Atty Paid $133.59 Other Costs Plaintiff Paid Date: FEBRUARY 3, 2003 CURTIS R. LONG P?r? othonota (Seal) /D? D P - Deputy Deputy REQUESTING PARTY: Name JOSEPH A. GOLDBECK, JR., ESQUIRE Address: GOLDBECK McCAFFERTY & McKEEVER SUITE 500 - THE BOURSE BLDG. 111 S. INDEPENDENCE MALL EAST PHILADELPHIA, PA 19106 Attorney for: PLAINTIFF Telephone: 215-627-1322 Supreme Court ID No. 16132 JOHN GERARD DEVLIN & ASSOCIATES, P.C. 100 Pine Street, Suite 260 Harrisburg, PA 17101 Phone: (717) 720-0700 By: John Gerard Devlin, Esquire I.D. #32858 Howard D. Kauffman, Esquire LD. #38963 Our File No.: 068-19374-JGD/h JUDITHA. EJO S Plaintiff v. THE COURT OF COMMON PLEAS CUMBERLAND COUNTY ST. PAULS EVANGELICAL LUTHERAN CHURCH OF CARLISLE, Defendant NO. 02-6097-Civil CIVIL ACTION - LAW : JURY TRIAL DEMANDED PRAECIPE TO SUBSTITUTE VERIFICATION TO THE PROTHONOTARY: Please substitute the enclosed Verification of Richard A. Ruff for Devlin the Verification of John Gerard Esquire to the Answer with New Matter previously filed in the above-captioned action. Respectfully submitted, JOHN GERARD DEVLIN & ASSOCIATES, p. C. BY: Howar . Kauffman, Mn. Esquire JOHN Street, DEj'I'IN It ASSOCIATES Harrisburg' PA Suite 260 , P.C. Phone: 17101 By: John(7Gera)r?d 20-0700 LD. #32858 Devlin, Esquire Howard D. Kaufrnan, Esquire I.D. #38963 Our File No.: 068.19374.JGD/h JUDITH A. JONES, Plaintiff V. ST. PAULS EVANGELIC LUTHERAN CHURCH OF CARLISLE, Defendant IN THE COURT OF CO YONPLEAS CUMBERLAND COUNT NO. 02-6097-Civil CIVIL ACTION _ LAW : JURY TRIAL DEMANDED CERTIFICATE OF SERVICE AND NOW, this 31 day of f of the Law Offices of John ? 2003, I, Howard D. Ka Gerard Devlin & Associates, P. , Esquire Evangelical Lutheran Church C'' counsel for Defendant, St. pauls of Carlisle, affirm that I served the foregoing p raecipe to Substitue Verification by depositing same in the United States Mail, postage prepaid in Harrisburg, Pennsylvania Karl E. Rommger, Esquire 155 South Hanover Street Carlisle, PA 17013 JOHN GERARD DEVLIN & ASSOCIATES, P.C. HOW • KAUFFMAN, ESQUTIRE JOHN GEC D DEVLIN & AS By: John Gerard Devlin, SOCIATES, P. C. I. D. No: 32858 Esquire 100 Pine Street, Suite 260 Harrisburg, PA 17101 717-720-0700 Our File NO.068-19373-JGD/h JUDITH A. JONES V. ST. PAULS EVANGELICAL LUTHERAN CHURCH OF CARLISLE CUMBERLAND COUNTY COURT OF COMMON PLEAS JURY TRIAL DEMANDED NO. 02-6097 -civil RIFICATION I, Ptch a r A, of Carlisle, hereby deposes and says a representative of St. Paul's Evangelical Lutheran Church are true and correct to the best that th of my knowledge and New Matter the statements therein information and belief are made subject to the 'and that I understand that unswo penalties of 18 Pa, C.S. Section 4904 rn falsification to authorities. relating to DATE i i a representative of St. Paul's Evangelical Lutheran Carlisle Church of AAMES Capital Corp. VS Theresa L. Lillich and William V Lillich In The Court of Common Pleas of Cumberland County, Pennsylvania Writ No. 2002-6092 Civil Term R. Thomas Kline, Sheriff, who being duly sworn according to law, states this writ is returned STAYED pursuant to instructions from Attorney Joseph Goldbeck Jr. Sheriff s Costs: Docketing 30.00 Poundage 1.66 Surcharge 30.00 Law Library .50 Prothonotary 1.00 Mileage 6.82 Levy 15.00 $ 84.98 paid by attorney 6/02/03 Sworn and subscribed to before me This day of 2003, A.DL Prothonotary Answers: R. Thomas Kline, heriff B Real Est to Deputy 1'5") (x W03o 4. 13FS7G Real Estate Sale # 10 On February 4, 2003 the sheriff levied upon the defendant's interest in the real property situated in Hampden Township, Cumberland County, PA known and numbered as 5203 Meadowbrook Dr., Mechanicsburg, more fully described on Exhibit "A" filed with this writ and by this reference incorporated herein. Date: February 4, 2003 Byv?D ?:rvulYt Real Estate Deputy D? GOLDBECK McCAFFERTY & McKEEVER BY: Michael T. McKeever Attorney I.D. #56129 Suite 5000 - Mellon Independence Center 701 Market Street Philadelphia, PA 19106-1532 215-627-1322 Attorney for Plaintiff AAMES CAPITAL CORP. 350 S. Grand Avenue 47th Floor Los Angeles, CA 90071 vs. THERESA L. LILLICH WILLIAM V. LILLICH 5203 Meadowbrook Drive Mechanicsburg, PA 17055 Plaintiff Defendants TO THE PROTHONOTARY: PRAECIPE TO VACATE JUDi Kindly vacate the judgment upon payment I THE COURT OF COMMON PLEAS OF CUMBERLAND COUNTY No. 02-6092C of your costs only. MICHAEL T. MrKEEVER, ESQUIRE ??? ??.. ' ? rv ?' __ ?a ° ? C:? c?a ? ?? .?..s r, ?, .,,,, .. - ?`? ?;,? GOLDBECK McCAFFERTY & McKEEVER ATTORNEY FOR PLAINTIFF BY: Michael T. McKeever Attorney I.D. #56129 Suite 5000 - Mellon Independence Center 701 Market Street Philadelphia, PA 19106-1532 215-825-6321 AAMES CAPITAL CORP. 350 S. Grand Avenue 47th Floor Los Angeles, CA 90071 vs. THERESA L. LILLICH WILLIAM V. LILLICH 5203 Meadowbrook Drive Mechanicsburg, PA 17055 TO THE PROTHONOTARY: IN Plaintiff Defendants T Kindly mark the above case Discontinued and Ended Michael T. I Attorney for COURT OF COMMON PLEAS CUMBERLAND COUNTY No. 02-6092C payment of your costs only. , Esquire Cl