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Home My WebLink About03-0010GOLDBECK 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 DOVENMUEHLE MORTGAGE CO. LP 1501 Woodfield Road Schaumburg, IL 60173-4982 Plaintiff VS. EMORY G. JOHNSON JR. CATHERINE M. JOHNSON Mortgagor(s) and Real Owner(s) 2225 Ritner Highway Shippensburg, PA 17257 THE UNITED STATES OF AMERICA Defendant(s) IN THE COURT OF COMMON PLEAS OF Cumberland COUNTY CIVIL ACTION - LAW ACTION OF MORTGAGE FORECLOSURE Term No. - 143 RECLOSURE 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 tiling 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 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. 11: 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 NECESSAR[O QUE USTED RESPONDA DENTRO DE 20 DIAS DESPUES DE SER SERVIDO CON ESTA DEMANDA y AVISO. PARA DEFENDERSE ES NECESSAPdO 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 KEQUERIRA 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 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 Plaintiff is DOVENMUEHLE MORTGAGE CO. LP, 1501 Woodfield Road, Schaumburg, IL 60173- 4982. The name(s) and address(es) of the Defendant(s) is/are EMORY G. JOHNSON JR., 2225 Rimer Highway, Shippensburg, PA 17257 and CATHERINE M. JOHNSON, 2225 Ritner Highway, Shippensburg, PA 17257, who is/are the mortgagor(s) and real owner(s) of the mortgaged premises hereinafter described. Defendant, THE UNITED STATES OF AMERICA, is named a Defendant pursuant to 28 U.S.C. Section 2410, and in accordance therewith Plaintiff requests that a judicial sale be held of the property hereinafter set forth. On January 21, 1984 mortgagor(s) made, executed and delivered a mortgage upon the premises hereinafter described to GMAC MORTGAGE CORP., which mortgage is recorded in the Office of the Recorder of Deeds of Cumberland County as Book 1193 Page 234. The mortgage has not been assigned unless said assignment to the Plaintiff is hereafter mentioned. The aforementioned mortgage was assigned to: DOVENMUEHLE MORTGAGE CO. LP by Assignment of Mortgage dated February 08, 1995 as Book 490 Page 936; and these documents are matters of public record and are incorporated herein by reference in accordance with Pennsylvania Rule of Civil Procedure 1019(g). The premises subject to said mortgage is described as attached. The mortgage is in default because monthly payment of principal and interest upon said mortgage due August 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. 7. The following amounts are due on the mortgage: Principal Balance Interest from 07/01/2002 through 12/31/2002 at 7.1250% Per Diem interest rate at $18.11 Attorney's Fee at 5.0% of Principal Balance Late Charges from 08/01/2002 to 12/31/2002 Monthly late charge amount at $44.82 Costs of suit and Title Search Escrow Monthly Escrow amount $192.51 $92,817.33 $3,332.23 $4,640.87 $224.10 $750.00 $101,764.53 $0.00 $101,764.53 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 Defendant(s) has/have not had the required face4o-face meeting within the required time and Plaintiffhas no knowledge of any such meeting being requested by the Defendant(s) through the Plaintiff, the Pennsylvania Housing Finance Agency, or any appropriate Consumer Credit Counseling Agency. 10. THE UNITED STATES OF AMERICA, the above named Defendant, appears to have liens filed of record, set forth in Exhibit 'B' which is attached hereto and made part thereof. .WHEREFORE, Plaintiff demands judgment in mortgage foreclosure in the sum of $101,764.53, together with interest at the rate of $18.11, per day and other expenses incurred by the Plaintiff which are properly chargeable in accordance with the terms of the mortgage, and for the foreclosure and sale of the mortgaged premises. GOL'~"E(~Id/MeCAFFERTY a MeKEEVER By: I~)SEP8 A. GOLDBECK, JR., ESQUIRE ATTORNEY FOR PLAINTIFF VERIFICATION I, , as the representative of the Plaintiff corporation within named do hereby verify that I am authorized to and do make this verification on behalf of the Plaintiff corporation and the facts set forth in the foregoing Complaint are tree and correct to the best of my knowledge, information and belief. I understand that false statements therein are made subject to the penalties of 18 Pa. C.S. 4904 relating to unswom falsification to authorities. Dovenmuehle Mortgage, Inc. SCHEDULE "A" A~L THAT CERTAIN 1~ or tract of land situate in North Newton Township, Cumborl&nd County, Pennsylvania, more fully bounded and described as £ollov~, ~o wit: BEGINNING ~; S~e,~l~o&d Spike in united States Route ~11, et the corner of Jl 'ol~i m S~bdivision Plan of George W. Baker, said plan being reoorded in ~ho Office of the Recorder of Deeds of Cumberland Co~y~. ~e~n~ylvan~a at Plan Book 35, Page 101J thence by ~h8 l~ne sE ~ ~1 on sa~d subdivision plan, North 28 degrees, lands n~ or .fo~orly Of Alfred L. WagnerJ ~hence by Wagner, iron~,, mt ~o: o0rfior of ~t No. 3 on the aforesaid p~an~ thoncm, by ~ No~ 3, South 28 degrees 20 minutes 26 seconds East 373.20 foo~ ~o ~ rallrotd spike In United States R~u~e 11, thence by said road, Sou~h 60 degrees 2 minutes, 50 seconds West, 182.00 feet, to a railro~d~splke in said road, the place of BEGINNING. BEING ~O~ AS 2225 RITNER HIG~AY BEING THE SAME PREMISES which Michael A. Niedwick and Diana G. Niedwick, husband and wife, by Indenture bearing date the ~5~ day of ~t~ 19~ A.D. and intended to be forthwith recorded in the Office for t~e Recording of Deeds, in and for the County of Cumberland, Commonwealth of P~nnsylvania, granted and conveyed unto said Mortgagors, in fee. -Liberty Bell Agency, Inc. 111 South Independence Mall East, The Bourse Bllltt~-~t~ ~, ~i~e~a, (215) 625-3660 · F~: (215) 625-3689 Monday, December 23, 2002 THIS SEARCH COVERS THE PERIOD TO: 12/5/02 PREMISES: 2225 RITNER HIGHWAY Nodh Ne~on Township Cumberland County, PA 17257 [For copy of legal description refer to deed aEached] P~CEL NUMBER: 30-28-2040-019A T~ASSESSMENT: 2002 $123,720.00 OWNER OF RECORD: by deed from Michael A. Niedwick and Diana G. Niedwick Dated: 9/1/93 and re~rded 1/24/94 in Book ~36 page 767 T~ C~IMS: None of re.rd '~DE~L LIENS: ~2000-7070 10/13/00 ~ U.S.A. BANKRUPTCIES: MORTGAGES: PA,,19106 -' ~-.~ LI i. Order:t;#: LBA-14062A $30,656.62 -vs- Emory G. & Catherine M. Johnson None of record Emory G. Johnson and Catherine M. Johnson 8360 Old York Rd., Elkins Park, Pa. 19117 Dated: 1/21/84 Recorded 1/24/84 in Book 1193 page 234 Assigned Tot l~ve~~e ~ 1501 Woodfield Rd., 9~h~'a~burg, ~160173 Recorded 2/8/95 in Book 490 page 936 JUDGMENTS, MUNICIPAL LIENS, MECHANICS CLAIMS and other claims or liens found of record: JUDGMENT #2002-2406 5/16/02 $1,444.94 -vs- Emory G. & Catherine M. Johnson Pa. Dept. of Revenue SUPPORT LIENS: Overdue support payments become liens on all real property owned by an obligor on the date the payment was due. Certifications may need to be obtained to determine the priority of the lien relative to the lien being fomlosed. Pa.R.C.P. 3129 Notice should be sent to: PA Department of Public Welfare Cumberland County Domestic Relations Bureau of Child Support Enforcement P.O. Box 320 Health and Welfare Building - Room 432 Carlisle, Pa 17013 PO Box 2675 Harrisburg, Pa. 17105-2675 REMARKS: None Liberty Bell Agency, Inc. certifies these search results as based upon the examination of evidence recorded in the appropriate public records for those catsgodes seamhed. Upon full payment of the price of this report, liability hereunder, in an amount not exceeding $2000 dollars, is assumed by Liberty Bell Agency, Inc. solely in its capacity as an abstracter for its negligence, mistakes or omissions, and 0nly for the time period seamhed. This report does not constitute title in.s.u_rance, nor Is It a commitment to issue title Insurance. This report shall I~lOT be used In a rea estate or I an aaaiflonal public records may need to be searched, and additional requirements may be added to this report, o settlement or closing, as possible October 17, 2002 Emery G Johnson 2225 Ritner Hwy Shippensburg PA 17257 INCE 1844 EXHIBIT B Loan Number: 0009168121 Current Lender/Servicer: Dovenmuehle Mortgage Inc. HOMEOWNER'S EMERGENCY MORTGAGE ASSISTANCE PROGPJIM YOU MAY BE ELIGIBLE FOR FINANCIAL ASSISTANCE WHICH CAN SAVE YOUR HOME FROM FORECLOSURE AND HELP YOU MAKE FUTURE MORTGAGE PAYMENTS IF YOU COMPLY WITH THE PROVISIONS OF THE HOMEOWNER'S EMERGENCY MORTGAGE ASSISTANCE ACT OF 1983 (THE "ACT"), YOU MAY BE ELIGIBLE FOR EMERGENCY MORTGAGE ASSISTANCE: * IF YOUR DEFAULT HAS BEEN CAUSED BY CIRCUMSTANCES BEYOND YOUR CONTROL, IF YOU HAVE A REASONABLE PROSPECT OF BEING ABLE TO PAY YOUR MORTGAGE PAYMENTS, AND IF YOU MEET OTHER ELIGIBILITY REQUIREMENTS ESTABLISHED BY THE PENNSYLVANIA HOUSING FINANCE AGENCY. TEMPOPJtRY 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 designated consumer credit counseling agencies listed at the end of this Notice. THIS MEETING MUST OCCUR WITHIN THE NEXT (30) DAYS. IF YOU DO NOT APPLY FOR EMERGENCY MORTGAGE ASSISTANCE, YOU MUST BRING YOUR MORTGAGE UP TO DATE. THE PART OF THIS NOTICE CALLED "HOW TO CURE YOUR MORTGAGE DEFAULT", EXPLAINS HOW TO BRING YOUR MORTGAGE UP TO DATE. Dovenmuehle Mortgage, Inc. 1501 Woodfield Road Schaumburg, IL 60173-4982 (847) 619-5535 Oct6ber 17, 2002 m m mm mm mm Catherine M Jehnson 2225 Ritner Hwy Shippensburg PA 17257 Lean Number: 0009168121 Current Lender/Servicer: SINCE 1844 EXHIBIT B Dovenmuehle Mortgage Inc. HOMEOWNER'S EMERGENCY MORTGAGE ASSISTANCE PROGRAM YOU HAY BE ELIGIBLE FOR FINANCIAL ASSISTANCE WHICH CAN SAVE YOUR HOME FROM FORECLOSURE AND HELP YOU MAKE FUTURE MORTGAGE PAYMENTS IF YOU COMPLY WITH THE PROVISIONS OP THE HOMEOWNER'S EMERGENCY MORTGAGE ASSISTANCE ACT OF 1983 (THE "ACT"), YOU HAY BE ELIGIBLE FOR EMERGENCY MORTGAGE ASSISTANCE: * IF YOUR DEFAULT HAS BEEN CAUSED BY CIRCUMSTANCES BEYOND YOUR CONTROL, * IF YOU HAVE A REASONABLE PROSPECT OF BEING ABLE TO PAY YOUR MORTGAGE PAYMENTS, AND * IF YOU MEET OTHER ELIGIBILITY REQUIREMENTS ESTABLISHED BY THE PENNSYLVANIA HOUSING FINANCE AGENCY. TEMPORARY STAY OF FORECLOSURE - Under the Act, you are entitled to a temporary stay ef foreclosure on your mortgage for thirty (30) days frem the date ef this Notice. During that time you must arrange and attend a "face-to-face,, meeting with one of the designated consumer credit counseling agencies listed at the end of this Notice. THIS MEETING MUST OCCUR WITHIN THE NEXT (30) DAYS. IF YOU DO NOT APPLY FOR EMERGENCY MORTGAGE ASSISTANCE, YOU MUST BRING YOUR MORTGAGE UP TO DATE. THE PART OF THIS NOTICE CALLED "HOW TO CURE YOUR MORTGAGE DEFAULT", EXPLAINS HOW TO BRING YOUR MORTGAGE UP TO DATE. Dovenmuehle Mortgage, Inc. 1501 Woodfield Road Schaumburg, IL 60173-4982 (847) 619-5535 PAGE 2 OF 5 OctOber 17, 2002 E G Johnson SINCE 1844 CONSUMER CREDIT COUNSELING AGENCIES - If you meet with one of the consumer credit counseling agencies listed at the end of this Notice, the lender may NOT take action against you for thirty (30) days after the date of this meeting. The names, addresses and telephone numbers of designated consumer credit counseling agencies for the county in which the property is located are set forth at the end of this Notice. It is only necessary to schedule one face-to-face meeting. Advise your lender immediately of your intentions. APPLICATION FOR MORTGAGE ASSISTANCE Your mortgage is in default for the reasons set forth later in this Notice (see following pages for specific information about the nature of your default.) If you have tried and are unable to resolve this problem with the lender, you have the right to apply for financial assistance from the Homeowner,s Emergency Mortgage Assistance Program. To do so, you must fill out, sign and file a completed Homeowner,s Emergency Assistance Program Application with one of the designated consumer credit counseling agencies listed at the end of this Notice. Only consumer credit counseling agencies have applications for the program and they will assist you in submitting a complete application to the Pennsylvania Housing Finance Agency. Your application MUST be filed or postmarked within thirty (30) days of your face-to-face meeting. YOU MUST FILE YOUR APPLICATION PROMPTLY. IF YOU FAIL TO DO SO OR IF YOU DO NOT FOLLOW THE OTHER TIME PERIODS SET FORTH IN THIS LETTER, FORECLOSURE MAY PROCEED AGAINST YOUR HOME IMMEDIATELY AND YOUR APPLICATION FOR MORTGAGE ASSISTANCE WILL BE DENIED. AGENCY ACTION - Available funds for emergency mortgage assistance are very limited. They will be disbursed by the Agency under the eligibility criteria established by the Act. The Pennsylvania Housing Finance Agency has sixty (60) days to make a decision after it receives your application. During that time, no foreclosure proceedings will be pursued against you if you have met the time requirements set forth above. You will be notified directly by the Pennsylvania Housing Finance Agency of its decision on your Application. NOTE: IF YOU ARE CURRENTLY PROTECTED BY THE FILING OF A PETITION IN BANKRUPTCY, THE 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.) DL137/BIC Dovenmuehle Mortgage, Inc. 1501 Woodfield Road Schaumburg, IL 60173-4982 (847) 619-5535 PAGE 3 OF 5 October 17, 2002 E G Johnson SINCE 1844 HOW TO CURE YOUR MORTGAGE DEFAULT (Bring it up to date). NATURE OF THE DEFAULT The MORTGAGE debt held by the above lender on your property located at: 2225 Ritner Hwy Shippensburg PA 17257 IS SERIOUSLY IN DEFAULT because: months and the following amounts are now past due: (a) Monthly payments from August 01, 2002 YOU HAVE NOT MADE MONTHLY MORTGAGE PAYMENTS for the following to present (at $ 896.55 per month)$ (b) Previous late charges; $ (c) Property Inspections; $ (d) NSF Charges; $ (e) Other Provisions of the mortgage obligation, if any; $ (f) TOTAL AMOUNT OF (a) (b) (c) (d) and (e) REQUIRED AS OF THIS DATE: YOU HAVE FAILED TO TAKE THE FOLLOWING ACTION applicable): 2,689.65 211.20 8.75 .00 .00 $ $ 2,909.60 (Do not use if not HOW TO CURE THE DEFAULT - You may cure the default within THIRTY (30) DAYS of the date of this notice BY PAYING THE TOTAL ~MOUNT PAST DUE TO THE LENDER WHICH IS $ 2,909.60, PLUS A_NY MORTGAGE PAYMENTS AiqD LATE CHARGES WHICH BECOME DUE DURING THE THIRTY (30) DAY PERIOD. Payments must be made either by cashier's check, certified check or money order made payable and sent to: ATTN: Collection Department LENDER NAME: Dovenmuehle Mortgage, Inc. ADDRESS: 1501 Woodfield Road, Suite 400E Schaumburg, IL 60173-4982 You can cure any other default by taking the following action within thirty (30) DAYS of the date of this letter. (Do not use if not applicable.) Dovenmuehle Mortgage, Inc. 1501 Woodfield Road Schaumburg, IL 60173-4982 (847) 619-5535 PAG~ 4 OF 5 Octeber 17, 2002 E G J©hnson SINCE 1844 IF YOU DO NOT CURE THE DEFAULT - If you do not cure the default within thirty (30) DAYS of the date of this Notice, the lender intends to exercise its 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 property. IF THE MORTGAGE IS FORECLOSED UPON - The mortgaged property will be sold by the Sheriff to pay off the mortgage debt. If the lender refers your case to its attorneys, but you cure the delinquency before the lender 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 fees will be added to the amount you owe the lender, which may also include other reasonable costs. If you cure the default within the THIRTY (30) DAY period, you will not be required to pay attorney's fees. OTHER LENDER REMEDIES - The lender may also sue you personally for the unpaid principal balance and all other sums due under the mortgage. RIGHT TO CURE THE DEFAULT PRIOR TO SHERIFF'S SALE - If you have not cured the default within THIRTY (30) DAY period and foreclosure proceedings have begun, you still have the right to cure the default and prevent the sale at any time up to one hour before the Sheriff's Sale. You may do so by paying the total amount then past due, plus any late or other charges then due, reasonable attorney,s fees and costs connected with the foreclosure sale and any other costs connected with the Sheriff's Sale as specified in writing by the lender and by performing 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 Sheriff's Sale of the mortgaged property could be held would be approximately 9 months from the date of this Notice. A Notice of the actual date of the Sheriff's Sale will be sent to you before the sale. Of course, the amount needed to cure the default will increase the longer you wait. You may find out at any time exactly what the required payment or action will be by contacting the lender. DL138/BIC Dovenmuehle Mortgage, Inc. 1501 Woodfield Road Schaumburg, IL 60173-4982 (847) 619-5535 PAGE 5 OF 5 October 17, 2002 E G Johnson SINCE 1844 HOW TO CONTACT THE LENDER: Dovenmuehle Mortgage, Inc. 1501 Woodfield Road Schaumburg, IL 60173-4982 1-800-669-0340 Fax: 847-330-8032 Contact: Mr. Edward Bagdon EFFECT OF SHERIFF'S SALE - You should realize that a Sheriff's Sale will end your ownership of the mortgaged property and your right to occupy it. If you continue to live in the property after the Sheriff's Sale, a lawsuit to remove you and your furnishings and other belongings could be started by the lender at any time. ASSUMPTION OF MORTGAGE - You MAY or X MAY NOT 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. Dovenmuehle Mortgage, Inc. 1501 Woodfield Road Schaumburg, IL 60173-4982 (847) 619-5535 INCE 1844 ACT 91 NOTICE DATE OF NOTICE: October 17, 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 foreclose. Specific information about the nature of the default is provided in the attached pages. The HOMEOWNER,S MORTGAGE ASSISTANCE PROGPJ~M (HEMAP) may be able to hel£~ to save your home. This Notice explains how the program works. To see if HEM_AP can help, you must MEET WITH A CONSUMER CREDI'I' COUNSELING AGENCY WITHIN 30 DAYS OF THE DATE OF THIS NOTICE. Take this Notice with you when you meet with the Counselinq ~gency~ The name, address and phone number of Consumer Credit Counselin,~ Agencies serving your County are listed at the end of this Notice. If you have any questions, you may call the Pennsylvania Housin~ Finance Agency toll free at 1-800-342-2397. Persons with impaire~l hearinq can call (717) 780-1869. This Notice contains important legal informatmon. If you have any questions, representatives at the Consumer Credit Counseling Agency may be able to help explain it. You may also want to contact any attorney in your area. The local bar association may be able to help you find a lawyer. La notificacion en adjunto es de suma importancia, pues afecta su derecho a continuar vivendo en su casa. Si no comprende el contenido de esta notificacion obtenga una traduccion immediatamente llamanda esta agencia (Pennsylvania Housing Finance Agency) sin cargos al numero mencionada arriba. Puedes ser elegible para un prestamo por el programa llamado "Homeowner's Emergency Mortgage Assistance Program,, el cula puede salvar su casa de la perdida del derecho a redimir su hipoteca. THIS DOCUMENT IS AN ATTEMPT TO COLLECT A DEBT & ANY INFORMATION OBTAINED WILL BE USED FOR THAT PURPOSE. DL139/BIC Dovenmuehle Mortgage, Inc. 1501 Woodfield Road Schaumburg, IL 60173-4982 (847) 619-5535 SHERIFF'S RETURN - REGULAR CASE NO: 2003-00010 P COMMONWEALTH OF PENNSYLVANIA: COUNTY OF CUMBERLAND DOVENMUEHLE MORTGAGE CO LP VS JOHNSON EMORY G JR CPL. TIMOTHY REITZ , Sheriff or Deputy Sheriff of Cumberland County,Pennsylvania, who being duly sworn according to law, says, the within COMPLAINT & NOTICE was served upon JOHNSON JR EMORY G the DEFENDANT , at 1124:00 HOURS, on the 16th day of January at 2225 RITNER HIGHWAY SHIPPENSBURG, PA 17257 by handing to CATHERINE M JOHNSON, WIFE a true and attested copy of COMPLAINT & NOTICE , 2003 together with and at the same time directing Her attention to the contents thereof. Sheriff's Costs: Docketing 18.00 Service 8.97 Affidavit .00 Surcharge 10.00 .00 36.97 Sworn and Subscribed to before me this ~7~ day of ~ ~_ ~6V~_~ A.D. So Answers: R. Thomas Kllne .* 01/17/2003 GOLDBECK MCCAFFERTY MCKEEVER SHERIFF'S RETURN - REGULAR CASE NO: 2003-00010 P COMMONWEALTH OF PENNSYLVANIA: COUNTY OF CUMBERLAND DOVENMUEHLE MORTGAGE CO LP VS JOHNSON EMORY G JR CPL. TIMOTHY REITZ , Sheriff or Deputy Sheriff of Cumberland County, Pennsylvania, who being duly sworn according to law, says, the within COMPLAINT & NOTICE was served upon JOHNSON CATHERINE M the DEFENDANT , at 1124:00 HOURS, on the 16th day of January at 2225 RITNER HIGHWAY SHIPPENSBURG, PA 17257 by handing to CATHERINE M JOHNSON a true and attested copy of COMPLAINT & NOTICE , 2003 together with and at the same time directing Her attention to the contents thereof. Sheriff's Costs: Docketing Service Affidavit Surcharge 6 00 00 00 10 00 00 16 00 Sworn and Subscribed to before me this 2A~ day of ~2~ A.D. ! Prothonotary ' ! ' So Answers: R. Thomas Kline 0 /17/2003 GOLDBECK MCCAFFERTY MCKEEVEv By: c~j~/~~ In the Court of Common Pleas of Cumberland County DOVENMUEHLE MORTGAGE CO. LP 1501 Woodfield Road Schaumburg, IL 60173-4982 vs. EMORY G. JOHNSON JR. CATHERINE M. JOHNSON (Mortgagor(s) and Record Owner(s)) 2225 Rimer Highway Shippensburg, PA 17257 THE UNITED STATES OF AMERICA Plaintiff Defendant(s) PRAECIPE FOR JUDGMENT No. 03-10 CIVIL TERM 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 EMORY G. JOHNSON JR. and CATHERINE M. JOHNSON and THE UNITED STATES OF AMERICA by default for want of an Answer. Assess damages as follows: Debt $103,744.22 Interest - 07/01/2002 to 03/11/2003 Total (Assessment of Damages attached) I CERTIFY THAT FOREGOING ASSESSMENT OF DAMAGES IS FOR SPECIFIED AMOUNTS ALLEGED TO BE DUE IN THE COMPLAINT AND IS CALCULABLE AS A SUM CERTAIN FROM THE COMPLAINT. I certify that written notice of the intention to file this praecipe was mailed or delivered to the party against whom judgment is to be entered and to his attorney of record, if any, aider the default occurred~ys prior to the date of the filing of this praecipe. A copy of the notice is attached. R.C.P. 237.1 J o s eptt-A~ ~ll~c~,l J5/ Attorney f{r/Plaint~t~" I.D. #1613~/ V AND NOW /~tO t~ff-~ I q , e,~.t~ ~'~ , Judgm~ tt is entered in favor of DOVENMUEHLE MORTG-AGE CO. LP and against EMORY G. JO~HNSON JR. and CATHERINE M. JOHNSON and THE UNITED STATES OF AMERICA by default for want of an Answer and damages assessed in the sum of $103,744.22 as per ~tS~,x~ the above certification. ~7~, ~-~ . Prothono 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 DOVENMUEHLE MORTGAGE CO. LP 1501 Woodfield Road Schaumburg, IL 60173-4982 VS. EMORY G. JOHNSON JR. CATHERINE M. JOHNSON (Mortgagor(s) and Record owner(s)) 2225 Rimer Highway Shippensburg, PA 17257 Plaintiff Defendant(s) IN THE COURT OF COMMON PLEAS of Cumberland County CIVIL ACTION LAW ACTION OF MORTGAGE FORECLOSURE No. 03-10 CIVIL TERM THE UNITED STATES OF AMERICA ORDER FOR JUDGMENT Please enter Judgment in favor of DOVENMUEHLE MORTGAGE CO. LP, and against EMORY G. JOHNSON JR. and CATHERINE M. JOHNSON for failure to file an Answer in the above action within (20) days (or sixty (60) days if defendant is the United States of America) from the date of service of the Complaint, in the sum of $103,744.22. JosephA. ~trfl~; Jr. Attorney~ ir Plai~ff I hereby certify that the above names are correct and that the precise residence address of the judgment creditor is DOVENMUEHLE MORTGAGE CO. LP 1501 Woodfield Road Schaumburg, IL 60173-4982 and that the name(s) and last known address(es) of the Defendant(s) is/are EMORY G. JOHNSON JR., 2225 Rimer Highway Shippensburg, PA 17257 and CATHERINE M. JOHNSON, 2225 Rimer Highway Shippensburg, PA 17257; BY: Joseph/A. G~dbeck, Jr. Attorney for Plainhff ASSESSMENT OF DAMAGES TO THE PROTHONOTARY: Kindl~, assess the damages in this case to be as follows: Principal Balance $92,817.33 Interest from 07/01/2002 through 03/11/2003 $4,599.93 Attorney's Fee at 5.0000% of principal balance $4,640.87 Late Charges $358.56 Costs of Suit and Title Search $750.00 Escrow Balance Deficit $577.53 ($0.00) $103,744.22 GOLDBEC~~I~TY BY: Joseph A[ ~old~ff Jr. Attorney for I~intifl/ [ & McKEEVER AND NOW, this /~4'~'day of /~a.~, 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, EMORY G. JOHNSON JR., is about unknown years of age, that Defendant's last known residence is 2225 Ritner Highway, Shippensburg, PA 17257, and is engaged in the unknown business located at unknown address. 2. That Defendant is not in the Military or Naval Service of the United States or its Allies, or otherwise within the provisions of the Soldiers' and Sailors' Civil Relief Action of Congress of 1940 and its Amendments. Date: VERIFICATION OF NON-MILITARY SERVICE The undersigned, as the representative for the Plaintiff corporation within named do hereby verify that I am authorized to make this verification on behalf of the Plaintiff corporation and that the facts set forth in the foregoing verification of Non- Military Service are true and correct to the best of my knowledge, information and belief. I understand that false statements therein are made subject to penalties of 18 Pa. C.S. 4904 relating to unsworn falsification to authorities. 1. That the above named Defendant, CATHERINE M. JOHNSON, is about unknown years of age, that Defendant ' s last known residence is 2225 Ritner Highway, Shippensburg, PA 17257, 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 DateC°ngress of 1940 and its Amendments. ~ ~: 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: February 20, 2003 TO: CATHERINE M. JOHNSON 2225 Rimer Highway Shippensburg, PA 17257 DOVENMUEHLE MORTGAGE CO. LP 1501 Woodfield Road Schaumburg, IL 60173-4982 VS. EMORY G. JOHNSON JR. CATHERINE M. JOHNSON (Mortgagor(s) and Record Owner(s)) 2225 Ritner Highway Shippensburg, PA 17257 THE UNITED STATES OF AMERICA Plaintiff Defendant(s) In the Court of Common Pleas of Cumberland County CIVIL ACTION- LAW Action of Mortgage Foreclosure Ternl No. 03-10 CIVIL TERM TO: CATHERINE M. JOHNSON 2225 Ritner Highway Shippensburg, PA 17257 IMPORTANT NOTICE YOU ARE IN DEFAULT BECAUSE YOU HAVE FAILED TO ENTER A WRITYEN 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 LL .'J~'ty Avenue Carlisle, PA 17013 LEGAL SERVICES 8 Irviue Row Carlisle, PA 17013 717-243-9400 Attorney for Plaintiff Suite 500 - The Bourse Bldg. 111 S. Independence Mall East Philadelphia, PA 19106 215-627-1322 THIS LA.W 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: February 20, 2003 TO: EMORY G. JOItNSON JR. 2225 Rimer Highway Shippensburg, PA 17257 DOVENMUEHLE MORTGAGE CO. LP 1501 Woodfield Road Schaumburg, IL 60173-4982 VS. EMORY G. JOHNSON JR. CATHERINE M. JOHNSON (Mortgagor(s) and Record Owner(s)) 2225 Rimer Highway Shippensburg, PA 17257 THE UNITED STATES OF AMERICA Plaintiff Defendant(s) In the Court of Common Pleas of Cumberland County CIVIL ACTION - LAW Action of Mortgage Foreclosure Term No. 03-10 CIVIL TERM TO: EMORY G. JOHNSON JR. 2225 Rimer Highway Shippensburg, PA 17257 IMPORTANT NOTICE YOU ARE IN DEFAULT BECAUSE YOU HAVE FAILED TO ENTER A WRITrEN APPEARANCE PERSONALLY OR BY ATrORNEY 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 C~lisle, PA 17013 LEGAL SERVICES INC 8 Irviue Row Carlisle, PA 17013 717-243-9400 Attorney for Plaintiff Suite 500 - The Bourse Bldg. 111 S. Independence Mall East Philadelphia, PA 19106 215-627-1322 Rule of Civil Proc~edure No. 236 - Revised IN THE COURT OF COMMON PLEAS OF Cumberland COUNTY, PENNSYLVANIA CIVIL ACTION - LAW DOVENMUEHLE MORTGAGE CO. LP 1501 Woodfield Road Schaumburg, IL 60173-4982 Plaintiff VS. No. 03-10 CIVIL TERM EMORY G. JOHNSON JR. CATHERINE M. JOHNSON (Mortgagors and Record Owner(s)) 2225 Rimer Highway Shippensburg, PA 17257 THE UNITED STATES OF AMERICA Defendant(s) THIS LAW FIRM IS A DEBT COLLECTOR AND WE ARE ATTEMPTING TO COLLECT A DEBT OWED TO OUR CLIENT. ANY INFORMATION OBTAINED FROM YOU WILL BE USED FOR THE PURPOSE OF COLLECTING THE DEBT. NOTICE Notice is given that a judgment in the above-captioned matter has been entered against you. Curt Long Prothonotary Deputy 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 w n ~ ~_ "~Sl. ~ ~? ~- ~~ ~ % "~ -r ! i v, -r, V ~~' .1- "" .7 L~ __.. ~ ~~ 1 1 i z _ _ ;, j !~ -~ GOLDBECK McCAFFERTY & McKEEVER BY: MICHAEL T. McKEEVER, ESQUIRE Attorney I.D.#56129 Suite 500 - The Bourse Bldg. 111 S. Independence Mall East Philadelphia, PA 19106 215-627-1322 Attorney for Plaintiff DOVENMUEHLE MORTGAGE CO. LP Plaintiff Ve EMORY G. JOHNSON JR. CATHERINE M. JOHNSON AND UNITED STATES OF AMERICA Defendants 1N THE COURT OF COMMON PLEAS OF Cumberland COUNTY CIVIL ACTION - LAW ACTION OF MORTGAGE FORECLOSURE Term No. 03-10 CIVIL TERM STIPULATION It is hereby stipulated and agreed by and between DOVENMUEHLE MORTGAGE CO. LP, plaintiff, and the defendant, United States of America, as follows: 1. That the premises referred to in the Plaintiff's Complaint is owned by the defendants, EMORY G. JOHNSON JR. and CATHERINE M. JOHNSON. 2. The plaintiff filed an action in mortgage foreclosure to the above number and term, and named as defendants, EMORY G. JOHNSON JR. and CATHERINE M. JOHNSON. 3. The parties hereby agree that the United States of America shall, and hereby is, named as a party in the above action, in accordance with 28 U.S.C. § 2410 et seq. 4. The United States of America hereby accepts service of the complaint and waives its right to file an answer or other responsive pleading thereto, and waives any objection it may have to the judgment entered against the defendant. 5. The United States of America has one tax liens against the property which are subject to the action of mortgage foreclosure, U.S.A.-#2000-7070, totaling $30,656.62, both entered in the Prothonotary's office of Cumberland County Pennsylvania. 6. That the Federal Tax Liens described in Exhibit "A" to this Stipulation are junior in time to the Plaintiff's mortgage set forth in paragraph three (3) of plaintiff's Complaint. 7. That the Defendant, United States of America, agrees to the entry in this action of a judgment in favor of the Plaintiff and against the United States of America for foreclosure and sale of the mortgaged property. 8. That the defendant, United States of America, is not indebted to the plaintiff. 9. That the aforesaid premises shall be sold at a judicial sale, notice of which was served on the defendant, United States of America. 10. That the judicial sale of said property shall discharge the Federal Tax Lien described in Exhibit "A". 11. That the proceeds of sale shall be divided and distributed as the parties may be entitled and any funds due the United States shall be sent to the Internal Revenue Service, P.O. box 1267, Harrisburg, PA 17108-1267. The check shall be made payable to "United States Treasury" and shall include the name and social security number of the taxpayer. 12. That the defendant, United States of America, preserves its right of redemption as provided in Title 28 United States Code, Section 2410 (c). 13. The parties to this Stipulation shall bear their own respective costs in this proceeding. Dated: February 21, 2003 By: Dated: THOMAS A. MARINO United ~3ta-~ Attorney Josep . TE ",,~ssista~t U {.~. Attorney A'tter,~ for United States of America C1 r --'` te -~. --~ ! n~E, ;~~ .~_ GF __ ..} }.._ rr~. ~ ~~ - 3 ~{ .'7~-. i t-- ~ _ ~ f J -°< PRAECIPE FOR WRIT OF EXECUTION - (MORTGAGE FORECLOSURE) P.R.C.P 3180-3183 Joseph A. Goldbeck, Jr. Attorney I.D.# 16132, Suite 500 - The Bourse Bldg. 111 S. Indepegdence Mall East Philadelphia, PA 19106 215-627-1322 Attorney for Plaintiff DOVENMUEHLE MORTGAGE CO. LP 1501 Woodfield Road Schaumburg, IL 60173-4982 VS. EMORY G. JOHNSON JR. CATHERINE M. JOHNSON Mortgagor(s) and Record Owner(s) 2225 Ritner Highway Shippensburg, PA 17257 THE UNITED STATES OF AMERICA Plaintiff Defendant(s) IN THE COURT OF COMMON PLEAS of Cumberland County CIVIL ACTION - LAW ACTION OF MORTGAGE FORECLOSURE No. 03-10 CIVIL TERM PRAECIPE FOR WRIT OF EXECUTION TO THE PROTHONOTARY: Issue Writ of Execution in the above matter: Amount Due Interest from 07/01/2002 to 03/11/2003 at 7.1250% $103,744.22 (Costs tobe added) 'r c ~~ (~ aV /h~~.J ~I '~ ~4 ~`6Q' -fi. e~ ~ 1 ~ ~ C` ~'? ~ o c ..p ~ a ~ ~s~88 w C~ ~-~ =~ .~ ^' 1 ~J ~ `~ -<: SCHEDULE "A" ALL THAT CKRTAZN lU~ or tract of land situate in North ]4swoon Township, Cumberland county, Pennsylvania, more fully bounded and described as ~o11~, to wit: pl~ ~l~ ~ .t~ ]~ ~be OEfi~ of th~ ~ecorder of Deeds of ~mbmrland Coun~y~.~n~ylvania at Plan Book 35, Page 101; thence by the line of ~t~1 on laid subd~vision plan, North 28 de~rae~, 13 ~inu~e~ 44 ~eo~ ~elt 341.32 feet to an iron p~n, at line of lands n~ or .fo~ly Of Alfred L. Wagner; thence by Wagner, Nor~ S0 ~mgr~%l~; ~..~nu~es, 30 seconds East, lSS.O0 feet, to mn Lron ~Ln m~ ~e: obchl= of ~t No. 3 on the aforesaid plan; 3?3.20 tOO~ to a rallrold spice In United States aou~e ~1, thence by said road, Sou~h 60 degrees 2 ninutes, 5o seconds West, ~82.00 feet, to a railro~d~ap~ke ~. sa~d road, the place of B~INNING. BEING .O~ AS 2225 'RITNER HIG~AY SHORT DESCRIPTION IMPROVEMENTS consist of a residential dwelling. BEING PREMISES : 2225 Ritner Highway Shippensburg, PA 17257 SOLD as the property ofEMORY G. JOHNSON JR. and CATHERINE M. JOHNSON TAX PARCEL #30-28-2040-019A WRIT OF EXECUTION and/or ATTACHMENT COMMONWEALTH OF PENNSYLVANIA) COUNTY OF CUMBERLAND) NO 03-10 Civil CIVIL ACTION - LAW TO THE SHERIFF OF CUMBERLAND COUNTY: To satisfy the debt, interest and costs due DOVENMUEHLE MORTGAGE CO. LP, Plaintiff (s) From EMORY G. JOHNSON, JR. AND CATHERINE M. JOHNSON, 2225 RITNER HIGHWAY, SHIPPENSBURG, PA 17257 ~ THE ~ STATES OF ~CA, 6].5 ~ · 5 H-II , 10 ~{l~od ar~e~ ~e~y upo~n~ of~e d]'e~e]n~a6ant (s)and to sell SEE LEGAL DESCRIPTION. (2) You are also directed to attach the property of the defendant(s) not levied upon in the possession of GARNISHEE(S) as follows: and to notify the garnishee(s) that: (a) an 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 $103,744.22 Interest FROM 7/1/02 TO 3/11/03 AT 7.1250% Atty's Comm % Atty Paid $134.97 Plaintiff Paid Date: MARCH 14, 2003 (Seal) REQUESTING PARTY: Name JOSEPH A. GOLDBECK, JR., ESQUIRE Address: SUITE 500 - THE BOURSE BLDG. 111 S. INDEPENDENCE MALL BLDG. PHILADELPHIA, PA 19106 Attorney for: PLAINTIFF Telephone: 215-627-1322 Supreme Court ID No. 16132 L.L. $.50 Due Prothy $1.00 Other Costs CURTIS R. LONG Deputy Jospeh 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 DOVENMUEHLE MORTGAGE CO. LP 1501 Woodfield Road Schaumburg, IL 60173-4982 Plaintiff VS. EMORY G. JOHNSON JR. CATHERINE M. JOHNSON Mortgagor(s) and Record Owner(s) 2225 Rimer Highway Shippensburg, PA 17257 Defendant(s) IN THE COURT OF COMMON PLEAS of Cumberland County CIVIL ACTION - LAW ACTION OF MORTGAGE FORECLOSUR~ NO. 03-10 CIVIL TERM THE UNITED STATES OF AMERICA CERTIFICATION AS TO TI-IE SALE OF REAL PROPERTY I, Joseph A. Goldbeck, Jr., Esquire hereby certify that I am the attorney of record for the Plaintiff in this action, and I further certify that this property is subject to Act 91 of 1983 and the Plaintiff has complied with all the provisions of the Act. Joseph A~. Attorney fo~lain~f[ C ° ~ ~ ~' I--i -~7 -.- ~" -j ~-, ~ . ~ ~~ rte ::%1 '',> ~ ~C Goldbeck McCafferty & McKeever BY: Joseph A. Goldbeck, Jr. Attorney I.D. #16132 Suite 500 - The Bourse Bldg. 111 S. Independence~VIall East Philadelphia, P/~t 19106 215-627-1322 Attorney for Plaintiff DOVENMUEHLE MORTGAGE CO. LP 1501 Woodfield Road Schaumburg, IL 60173-4982 Plaintiff VS. EMORY G. JOHNSON JR. CATHERINE M. JOHNSON (Mortgagor(s) and Record Owner(s)) 2225 Rimer Highway Shippensburg, PA 17257 Defendant(s) THE UNITED STATES OF AMERICA IN THE COURT OF COMMON PLEAS of Cumberland County CIVIL ACTION - LAW ACTION OF MORTGAGE FORECLOSURE No. 03-10 CIVIL TERM AFFIDAVIT PURSUANT TO RULE 3129 DOVENMUEHLE MORTGAGE CO. LP, 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: 2225 Rimer Highway Shippensburg, PA 17257 1.Name and address of Owner(s) or Reputed Owner(s): EMORY G. JOHNSON JR. 2225 Rimer Highway Shippensburg, PA 17257 CATHERINE M. JOHNSON 2225 Rimer Highway Shippensburg, PA 17257 2. Name and address of Defendant(s) in the judgment: EMORY G. JOHNSON JR. 2225 Rimer Highway Shippensburg, PA 17257 CATHERINE M. JOHNSON 2225 Rimer Highway Shippensburg, PA 17257 THE UNITED STATES OF AMERICA 615 Chestnut Street Suite 1250 Philadelphia, PA 19106 3. Name and last known address of every judgment creditor whose judgment is a record lien on the property to be sold: DOMESTIC RELATIONS OF CUMBERLAND COUNTY PO Box 320 Carlisle, PA 17013 PA DEPARTMENT OF PUBLIC WELFARE - Bureau of Child Support Enforcement Health and Welfare Bldg. - Room 432 P.O. Box 2675 Harrisburg, PA 17105-2675 PENNSYLVANIA DEPT. OF REVENUE Dept. 280946 Harrisburg, PA 17128 4. Name and address of the last recorded holder of every mortgage of record: 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 unswom falsification to authorities. DATED: March 11, 2003 GOLDBE & McKEEVER BY: Joseph A. ~oldbec~k,/Jr., Esq. Attorney for P~intiff ~i f ;~ 4V V / f~ T . . V l ~."'1H ~_:: . '~ ~ - ~ , .'c i -.. r~. ) ~F-( ~ ~,~' rn ~_ p :,'.~ -., ~ V ~ 03-10 CIVIL TERM GOLDBECK McCAFFERTY & McKEEVER BY: Joseph A. Goldbeck, Jr. Attorney I.D .#16132 Suite 500 - Th[ Bourse Bldg. 111 S. In, dependence Mall East Philadelphia, PA 19106 215-627-1322 Attorney for plaintiff DOVENMUEHLE MORTGAGE CO. LP 1501 Woodfield Road Schaumburg, IL 60173-4982 Plaintiff VS. EMORY G. JOHNSON JR. CATHERINE M. JOHNSON Mortgagor(s) and Record Owner(s) 2225 Ritner Highway Shippensburg, PA 17257 THE UNITED STATES OF AMERICA Defendant(s IN THE COURT OF COMMON PLEAS of Cumberland County CIVIL ACTION - LAW ACTION OF MORTGAGE FORECLOSURE Terlrl No. 03-10 CIVIL TERM 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: JOHNSON, CATHERINE M. CATHERINE M. JOHNSON 2225 Rimer Highway Shippensburg, PA 17257 Your house at 2225 Rimer Highway, Shippensburg, PA 17257 is scheduled to be sold at Sheriffs Sale on Wednesday, September 03, 2003, at 10:00 AM, in Commissioners Hearing Rm 2nd FL Courthouse to enforce the court judgment of $103,744.22 obtained by DOVENMUEHLE MORTGAGE CO. LP 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 mediate action: 1. The sale will be cancelled if you pay to DOVENMUEHLE MORTGAGE CO. LP, the back payments, late charges, costs and reasonable attorney's fees due. To f'md out how much you must pay call: 215-627-1322 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. 03-10 CIVIL TERM 3. You ~rnay also be able to stop the sale through other legal proceedings. 'fou may need an attorney to assert your fights. 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 STII,L BE ABLE TO SAVE YOUR PROPERTY AND YOU ItAVE OTItER 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 fred 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 f'md 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 Shefiff and the Shefiff 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 fights and defenses, or ways of getting your house back, if you act immediately after the sale. YOU SHOULD TAKE THIS PAPER TO YOUR LAWYER AT ONCE. IF YOU DO NOT HAVE A LAWYER OR CANNOT AFFORD ONE, GO TO OR TELEPHONE THE OFFICE LISTED BELOW TO FIND OUT WHERE YOU CAN GET LEGAL HELP. LEGAL SERVICES INC 8 Irvine Row Carlisle, PA 17013 CUMBERLAND COUNTY BAR ASSOCIATION 2 Liberty Avenue Carlisle, PA 17013 r ~. ~ ~ ~~ C ~ ~ tz l F ; -'~ E -- ~ 4 ( ) ~ - k Z_~ ~~ .Si. ~ °,l ~~7 ~C- J :~ssn _~ -{ ""~ ~ ~ -c 03-10 CIVIL TERM 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 DOVENMUEHLE MORTGAGE CO. LP 1501 Woodfield Road Schaumburg, IL 60173-4982 Plaintiff VS. EMORY G. JOHNSON JR. CATHERINE M. JOHNSON Mortgagor(s) and Record Owner(s) 2225 Ritner Highway Shippensburg, PA 17257 THE UNITED STATES OF AMERICA Defendant(ff IN THE COURT OF COMMON PLEAS of Cumberland County CIVIL ACTION - LAW ACTION OF MORTGAGE FORECLOSURE Tel-in No. 03-10 CML TERM 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: JOHNSON JR., EMORY G. EMORY G. JOHNSON JR. 2225 Rimer Highway Shippensburg, PA 17257 Your house at 2225 Rimer Highway, Shippensburg, PA 17257 is scheduled to be sold at Sheriffs Sale on Wednesday, September 03, 2003, at 10:00 AM, in Commissioners Hearing Rm 2nd FL Courthouse to enforce the court judgment of $103,744.22 obtained by DOVENMUEHLE MORTGAGE CO. LP against you. NOTICE OF OWNER'S RIGHTS YOU MAY BE ABLE TO PREVENT THIS SHERIFF'S SALE To prevent this Sheriffs Sale you must take immediate action: 1. The sale will be cancelled if you pay to DOVENMUEHLE MORTGAGE CO. LP, the back payments, late charges, costs and reasonable attorney's fees due. To find out how much you must pay call: 215-627-1322 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. 03-10 CIVIL TERM 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 fred 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 mount due in the sale. To f'md 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. LEGAL SERVICES INC 8 Irvine Row Carhsle, PA 17013 CUMBERLAND COUNTY BAR ASSOCIATION 2 Liberty Avenue Carlisle, PA 17013 r-; ~ J (_4 om . _ r t { K.~ ~w ~L1 ~. ^".. ~, i _ .~.a .~f - ~ <:. . __. _ t._~' ~L~ .~. C. w~ ~< r ~A 03-10 CIVIL TERM GOLDBECK McCAFFERTY & McKEEVER BY: Joseph P~. 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 DOVENMUEHLE MORTGAGE CO. LP 1501 Woodfield Road Schaumburg, IL 60173-4982 Plaintiff vs. EMORY G. JOHNSON JR. CATHERINE M. JOHNSON Mortgagor(s) and Record Owner(s) 2225 Rimer Highway Shippensburg, PA 17257 THE UNITED STATES OF AMERICA Defendant(s] IN THE COURT OF COMMON PLEAS of Cumberland County CIVIL ACTION - LAW ACTION OF MORTGAGE FORECLOSURE Terrrl No. 03-10 CML TERM 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: THE UNITED STATES OF AMERICA 615 Chestnut Street Suite 1250 Philadelphia, PA 19106 Your house at 2225 Ritner Highway, Shippensburg, PA 17257 is scheduled to be sold at Sheriffs Sale on Wednesday, September 03, 2003, at 10:00 AM, in Commissioners Hearing Rm 2nd FL Courthouse to enforce the court judgment of $103,744.22 obtained by DOVENMUEHLE MORTGAGE CO. LP against you. NOTICE OF OWNER'S RIGHTS YOU MAY BE ABLE TO PREVENT THIS SHERIFF'S SAI,E To prevent this Sheriffs Sale you must take immediate action: 1. The sale will be cancelled if you pay to DOVENMUEHLE MORTGAGE CO. LP, the back payments, late charges, costs and reasonable attorney's fees due. To fred out how much you must pay call: 215-627-1322 2. You may be able to stop the sale by filing a petition asking the Court to slrike or open judgment, if the judgment was improperly entered. You may also ask the Court to postpone the sale for good cause. 03-10 CIVIL TERM 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 OTI-1ER 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 f'md 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 mount due in the sale. To f'md 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 Sheriff's Sale. This schedule will state who will be receiving that money. The money will be paid out in accordance with this schedule unless exceptions (reasons why the proposed distribution is wrong) are filed with the Sheriff within ten (10) days after the schedule of distribution is filed. 7. You may also have other rights and defenses, or ways of getting your house back, if you act immediately after the sale. YOU SHOULD TAKE THIS PAPER TO YOUR LAWYER AT ONCE. IF YOU DO NOT HAVE A LAWYER OR CANNOT AFFORD ONE, GO TO OR TELEPHONE THE OFFICE LISTED BELOW TO FIND OUT WHERE YOU CAN GET LEGAL HELP. LEGAL SERVICES INC 8 Irvine Row Carlisle, PA 17013 CUMBERLAND COUNTY BAR ASSOCIATION 2 Liberty Avenue Carlisle, PA 17013 Goldbeck McCafferty & McKeever BY: Joseph A. Goldbeck, Jr. Attomey I.D. #16132 Suite 500 - The Bourse Bldg. 111 S. Independence Mall East Philadelphia, PA 19106 215-627-1322 Attorney for Plaintiff DOVENMUEHLE MORTGAGE CO. LP 1501 Woodfield Road Sehaumburg, IL 60173-4982 Plaintiff VS. EMORY G. JOHNSON JR. CATHERINE M. JOHNSON (Mortgagor(s) and Record Owner(s)) 2225 Ritner Highway Shippensburg, PA 17257 Defendant(s) THE UNITED STATES OF AMERICA IN THE COURT OF COMMON PLEAS of Cumberland County CML ACTION- LAW ACTION OF MORTGAGE FORECLOSURE No. 03-10 CIVIL TERM AFFIDAVIT PURSUANT TO RULE 3129 DOVENMUEHLE MORTGAGE CO. LP, 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: 2225 Rimer Highway Shippensburg, PA 17257 1.Name and address of Owner(s) or Reputed Owner(s): EMORY G. JOHNSON JR. 2225 Rimer Highway Shippensburg, PA 17257 CATHERINE M. JOHNSON 2225 Rimer Highway Shippensburg, PA 17257 2. Name and address of Defendant(s) in the judgment: EMORY G. JOHNSON JR. 2225 Rimer Highway Shippenaburg, PA 17257 CATHERINE M. JOHNSON 2225 Rimer Highway Shippensburg, PA 17257 THE UNITED STATES OF AMERICA 615 Chestnut Street Suite 1250 Philadelphia, PA 19106 3. Name and last known address of every judgment creditor whose judgment is a record lien on the property to be sold: DOMESTIC RELATIONS OF CUMBERLAND COUNTY PO Box 320 Carlisle, PA 17013 PA DEPARTMENT OF PUBLIC WELFARE - Bureau of Child Support Enforcement Health and Welfare Bldg. - Room 432 P.O. Box 2675 Harrisburg, PA 17105-2675 PENNSYLVANIA DEPT. OF REVENUE Dept. 280946 Harrisburg, PA 17128 4. Name and address of the last recorded holder of every mortgage of record: 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 unswom falsification to authorities. DATED: March I 1, 2003 BY: Joseph A. ~]oldbe~ Attorney for P~intiff , ~& McKEEVER C ~ ~ " ~ ~' '?~ --~ ~ "' - __~ s "'~ _, Y `~;~ ~ ~ ~ J' r~ ~~ ~ ~ r.~ ~~ °~-c .~ COMMONWEALTH OF PENNSYLVANIA COUNTY OF CUMBERLAND .~ SS: I, Robert P. Ziegl~r, Recorder of Deeds in and for said County and State do hereby certify that the Sheriff's Deed in which Federal Natl Mtg Assoc is the grantee the same having been sold to said grantee on the 3rd day of Se~t A.D., 2003, under and by virtue ora writ Execution issued on the 14th day of March, A.D., 2003, out of the Court of Common Pleas of said County as of Civil Term, 2003 Number 10, at the suit of Dovenmuehle Mtg Co L P against Emorv G Johnson Jr & Catherine M is duly recorded in Sheriff's Deed Book No. 259, Page 3339. IN TESTIMONY WHEREOF, I have hereunto set my hand and seal of said office this ,~/t~t.~ day of ~g-~-~ , A.D. 2003 t~- ~-~-aT C~Re~rder o f Deeds Recorder of Deeds, Cumberland Coucly, C~11~, PA My Commission Ex, res the F~ bloa~ay ~ ~la~, 2~ Dovenmuehle Mortgage co. LP VS Emory G. Johnson, Jr. And Catherine M. Johnson In The Court of Common Pleas of Cumberland County, Pennsylvania Writ No. 2003~10 Civil Term Timothy Reitz, Deputy Sheriff, who being duly sworn according to law, states that on May 15, 20(}3 at 6:45 o'clock PM, he served a true copy of the within Real Estate Writ, Notice and Description, in the above entitled action, upon the within named defendant, to wit: Emory G. Johnson, Jr., by making known unto Catherine Johnson, wife of defendant, at 2225 Ritner Highway, Shippensburg, Cumberland County, Pennsylvania, its contents and at the same time handing to her personally the said true and correct copy of the same. Timothy Reitz, Deputy Sheriff, who being duly sworn according to law, states that on May 15, 2003 at 6:45 o'clock PM, he served a true copy of the within Real Estate Writ, Notice and Description, in the above entitled action, upon the within named defendant, to wit: Emory G. Johnson, Jr., by making known unto Catherine Johnson, wife of defendant, al 2225 Ritner Highway, Shippensburg, Cumberland County, Pennsylvania, its contents and at the same time handing to her personally the said true and correct copy of the same. Brian Barrick, Deputy Sheriff, who being duly sworn according to law, states that on July 9, 2003 at 6:49 o'clock P.M., he posted a true copy of the within Real Estate Writ, Notice, Poster and Description, in the above entitled action, upon the property of Emory G. Johnson, Jr. and Catherine M. Johnson located at 2225 Ritner Highway, Shippensburg, Pennsylvania, according to law. R. Thomas Kline, Sheriff, who being duly sworn according to law, states he served the above Real Estate Writ, Notice, Poster and Description in the following manner: The Sheriffmailed a notice of the pendency of the action to one of the within named defendants, to wit: Emory G. Johnson, Jr., by regular mail to his last known address of 2225 Ritner Highway, Shippensburg, PA 17257. This letter was mailed under the date of July 3, 2003 and never returned to the Sheriffs Office. R. Thomas Kline, Sheriff, who being duly sworn according to law, states he served the above Real Estate Writ, Notice, Poster and Description in the following manner: The Sherift'mailed a notice of the pendency of the action to one of the within named defendants, to wit: Catherine M. Johnson, by regular mail to her last known address of 2225 Ritner Highway, Shippensburg, PA 17257. This letter was mailed under the date of July 03, 2003 and never returned to the Sheriff's Office. R. Thomas Kline, Sheriff, who being duly sworn according to law, states that after due and legal notice had been given according to law, he exposed the within described premises at public venue or outcry at the Courthouse, Carlisle, Cumberland County, Pennsylvania on September 3, 2003 at 10:00 o'clock A.M. He sold the same for the sum of $1.00 to Attorney Joseph Goldbeck for Federal National Mortgage Association. It being the highest bid and best price received for the same, Federal National Mortgage Association of Two Galleria Tower, Suite 600, 13455 Noel Road, Dallas, TX 75240-5003, being the buyer in this execution, paid to Sheriff R. Thomas Kline the sum of $724.14. Sheriff's Costs: Docketing $30.00 Poundage 14.20 Posting Bills 15.00 Advertising 15.00 Acknowledging Deed 30.00 Auctioneer 10.00 Law Library .50 Prothonotary 1.00 Mileage 20.70 Levy 15.00 Surcharge 30.00 Law Journal 242.15 Patriot News 207.19 Share of Bills 28.90 Distribution of Proceeds 25.00 Sheriff's Deed 39.50 $ 724.14 Sworn and subscribed to before me So Answer~.; This ge dayof ~c~_.~ R. Thomas Kline, 2003, ^.D. BY Re . Goldbeck McCafferty & McKeever BY: Joseph A. Goldbeck, Jr. gdtorney I.D. #16132 Suite 500 - The Bourse Bldg. !. 11 S. Independence Mall East Philadelphia, PA 19106 215-627-1322 Attorney for Plaintiff DOVENMUEHLE MORTGAGE CO. LP 1501 Woodfield Road Schaumburg, IL 60173-4982 Plaintiff VS. IN THE COURT OF COMMON PLEAS of Cumberland County EMORY G. JOHNSON JR. CATHERINE M. JOHNSON (Mortgagor(s) and Record Owner(s)) 2225 Ritncr Highway Shippensburg, PA 17257 Defendant(s) CIVIL ACTION - LAW ACTION OF MORTGAGE FORECLOSURE THE UNITED STATES OF AMERICA No. 03-10 CIVIL TERM AFFIDAVIT PURSUANT TO RULE 3129 DOVENMUEHLE MORTGAGE CO. LP, 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: 2225 Ritner Highway Shippensburg, PA 17257 1.Name and address of Owner(s) or Reputed Owner(s): EMORY G. JOHNSON JR. 2225 Rimer Highway Shippensburg, PA 17257 CATItERINE M. JOHNSON 2225 Ritner Highway Shippensburg, PA 17257 2. Name and address of Defandant(s) in the judgment: EMORY G. JOHNSON JR. 2225 Ritner Highway Shippenaburg, PA 17257 CATHERINE M. JOHNSON 2225 Ritner Highway Shippensburg, PA 17257 THE 1.JNITED STATES OF AMERICA 615 Chestnut Stxeet Suite 1250 Philadelphia, PA 19106 3. Name and last known address of every judgmant creditor whose judgment is a record lien on the property to be sold: DOMESTIC RELATIONS OF CUMBERLAND COUNTY PO l%x 320 Carlisle, PA 17013 PA DEPARTMENT OF PUBLIC WELFARE - Bureau of Child Support Enforcement Health and Welfare Bldg. - Room 432 P.O. Box 2675 Hamsburg, PA 17105-2675 PENNSYLVANIA DEPT. OF REVENUE Dept. 280946 Hamsburg, PA 17128 4. Name and ad&ess of the last recorded holder of every mortgage of record: 5. Name and ad&ess 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 ad&ess 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 ad&ess of every other person of whom the plainfiffhas 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 unswom falsification to authorities. DATED: March 11, 2003 GOLDBECK~~ & MeKEEVER BY: Joseph A.~oldbe~x4Jr., Esq. Attorney for Plfmtiff 03-10 CIVIL TERM 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 DOVENMUEHLE MORTGAGE CO. LP 1501 Woodfield Road Schaumburg, IL 60173-4982 Plaintiff IN THE COURT OF COMMON PLEAS of Cumberland County VS. CIVIL ACTION - LAW EMORY G. JOHNSON JR. CATHERINE M. JOHNSON Mortgagor(s) and Record Owner(s) ACTION OF MORTGAGE FORECLOSURE 2225 Rimer Highway Shippensburg, PA 17257 THE UNITED STATES OF AMERICA Term No. 03-10 CML TERM Defendant(s) 'ri:liS LAW ~ IS A DEBT COLLECTOR AND ViE ARE ATTEMPTING TO COLLECT A DEBT. THIS NOTICE IS SENT TO YOU IN AN ATi'E, MI~T TO COLLECT A DEBT. ANY INFORMATION OBTAINED FROM YOU W'ILL BE USED FOR THAT PURPOS~E. NOTICE OF SHERIFF'S SALE OF REAL PROPERTY TO: JOHNSON, CATHER~E M. CATHERINE M. JOHNSON 2225 Rimer Highway Shippensburg, PA 17257 Your house at 2225 Rimer Highway, Shippensburg, PA 17257 is scheduled to be sold at Sheriffs Sale on Wednesday, September 03, 2003, at 10:00 AM, in Commissioners Hearing Pan 2nd FL Courthouse to enforce the court judgment of $103,744.22 obtained by DOVENML~HLE MORTGAGE CO. LP against you. NOTICE OF OWNER'S RIGHTS YOU MAY BE ABLE TO PREVENT THIS SHERIFF'S SALE To prevent this Sheriffs Sale you must take immediate action: 1. The sale will be cancelled if you pay to DOVENMUEHLE MORTGAGE CO. LP, the back payments, late charges, costs and reasonable attorney's fees due. To f'md out how much you must pay call: 215-627-1322: 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/mproperly entered. You may also ask the Court to postpone the sale for good cause. 03-10 CIVIL TERM 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 ]tAVE OTHER RIGIITS EVEN IF TI-IE SHERIFF'S SALE DOES NOT TAKE PLACE. 1. If the Sheritt's Sale is not stopped, your property will be sold to the highest bidder. You may fred 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 iftha buyer pays the Sheriff the full amount due hr the sale. To fred out if this has happened, you may call the Sheriff of 717-240-6390. 4. If the mount due from the Buyer/s 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 Sheriffgives 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 sehednle unless exceptions (reasons why the proposed distribution is wrong) are filed with the Sheriffwithhr ten (10) days after the schedule of distribution is fried. 7. You may also. have other rights and defenses, or ways of getting your house back, if you act immediately after the sale. YOU SHOULD TAKE THIS PAPER TO YOUR LAWYER AT ONCE. IF YOU DO NOT HAVE A LAWYER OR CANNOT AFFORD ONE, GO TO OR TELEPHONE THE OFFICE LISTED BELOW TO FIND OUT WHERE YOU CAN GET LEGAL HELP. LEGAL SERVICES INC 8 Irvine Row Carlisle, PA 17013 CUMBERLAND COUNTY BAR ASSOCIATION 2 Liberty Avenue Carlisle, PA 17013 03-10 CIVIL TERM 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 DOVENMUEHLE MORTGAGE CO. LP 1501 Woodfield Road Schaumburg, IL 60173-4982 Plaintiff IN THE COURT OF COMMON PLEAS of Cumberland County vs. CIVIL ACTION - LAW EMORY G. JOHNSON JR. CATHERINE M. JOHNSON Mortgagor(s) and Record Owner(s) ACTION OF MORTGAGE FORECLOSURE 22~5 Rimer Highway Shippansburg, PA 17257 THE UNITED STATES OF AMERICA Term No. 03-10 CIVIL TERM Defendant(s) THIS LAW FIRM IS A DEBT COLLECTOR AND WE ARE ATTEMPTING TO COLLECT A DEBT. THIS NOTICE IS SENT TO YOU IN AN ATTEMPT TO COLLECT A DEBT. ANY INFORMATION OBTAINED FROM YOU WILL BE USED FOR THAT PURPOSE. NOTICE OF SI-II~,RIFF'S SALE OF REAL PROPERTY TO: JOHNSON JR., EMORY G, EMORY G. JOHNSON JR. 2225 Rimer Highway Shippensburg, PA 17257 Your house at 2225 Rimer Highway, Shippensburg, PA 17257 is scheduled to be sold at Sheriffs Sale on Wednesday, September 03, 2003, at I0:00 AM, in Commissioners Hearing Rm 2nd FL Courthouse to enfome the court judgment of $103,744.22 obtained by DOVENMUEHLE MORTGAGE CO. LP against you. NOTICE OF OWNER'S RIGHTS YOU MAY BE ABLE TO PREVENT THIS SHERIFF'S SALE To prevent this Sherffi's Sale you must take immediate action: 1. The sale will be cancelled if you pay to DOVENMUEHLE MORTGAGE CO. LP, the back payments, late charges, costs and reasonable attorney's fees due. To fred out how much you must pay call: 215-627-1322 2. You may be abl6 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. 03-10 CIVIL TERM 3. You may also be able to stop the sale through other legal proceedings. You may need an attorney to assert your fights. 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 OTttER RIGHTS EVEN IF TIlE SItERIFF~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 mount due in the sale. To fred 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 mount 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 distxibution of the money bid for your house will be filed by the Sheriffthirty (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 Sheriffwithin ten (10) days after the schedule of distribution is filed. 7. You may also have other rights and defenses, or ways of getting your house back, if you act immediately after the sale. YOU SHOULD TAKE THIS PAPER TO YOUR LAWYER AT ONCE. IF YOU DO NOT HAVE A LAWYER OR CANNOT AFFORD ONE, GO TO OR TELEPHONE THE OFFICE LISTED BELOW TO FIND OUT WHERE YOU CAN GET LEGAL HELP. LEGAL SERVICES INC 8 Irvine Row Carlisle, PA 17013 CUMBERLAND COUNTY BAR ASSOCIATION 2 Liberty Avenue Carlisle, PA 17013 SCHEDULE "A" A~ THAT CERTAIN 10~ or ~rac~ of l~nd situate in North Newton Township, Cumberland CoUnty, Pennsylvania, more fully bounded and deeoribsd as follov~, to wit: BEGINNING at · railroad spike in United States Route ~11, a~ the lands n~ or .fo~l~ Of Alfred L. Wmgner~ ~henoe by Wagner, ~=o~ p~ I~ ~:~IF Of ~t No. 3 on the afore=a~d plan; 373.20 ~eet ~o a r&Llro&d sp~ko ~n Un,ted SCa~ee Rou~e ~1, thenoe by ea~d road, Sou~h 60 degrees 2 m£nu~o5, S0 seconde West~ 182.00 feet, to a railro~d~Sp~ke in said road, the place o~ BEgINNInG. BEING KNOWN AS 2225 IRITNER HIGHWAY SHORT DESCRIPTION IMPROVEMENTS consist of a residential dwelling. BEINGPREMISES: 2225 Ritner Highway Shippensburg, PA 17257 SOLD as the property ofEMORY G. JOHNSON JR. and CATHERINE M. JOHNSON TAX PARCEL #30-28-2040-019A WRIT OF EXECUTION and/or ATTACHMENT COMMONWEALTH OF PENNSYLVANIA) ~ NO 03-10 Civil COUNTY OF CUMBERLAND) CIVIL ACTION - LAW TO THE SHERIFF OF CUMBERLAND COUNTY: To satisfy the debt, interest and costs due DOVENMUEHLE MORTGAGE CO. LP, Plaintiff (s) From EMORY G. JOHNSON, JR. AND CATHERINE M. JOHNSON, 2225 RITNER HIGHWAY, SHIPPENSBURG, PA 17257 t~D THE I.~'rea~ STATES OF i~-~RICAo 615 ~ , 25 , lc{II IA, 9 0 ~oot{ are~recte~to ~evy upo~rty ofp& ~egt~en0~Sant (s)and to sell SEE LEGAL DESCRIPTION. (2) You are also directed to attach the property of the defendant(s) not levied upon in the possession of GARNISHEE(S) as follows: and to notify the garnishee(s) that: (a) an 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 $103,744.22 Interest FROM 7/1/02 TO 3/11/03 AT 7.1250% Al~y's Corem % Any Paid $134.97 Plaintiff Paid Date: MARCH 14, 2003 (Seal) CURTIS R. LONG Frothono Deputy L.L. $.50 Due Prothy $1.00 Other Costs REQUESTING PARTY: Name JOSEPH A. GOLDBECK, JR., ESQUIRE Address: SUITE 500 - THE BOURSE BLDG. 111 S. INDEPENDENCE MALL BLDG. PHILADELPHIA, PA 19106 Attorney for: PLAINTIFF Telephone: 215-627-1322 Supreme Court ID No. 16132 Real Estate Sale # 15 On May 2, 2003 the sheriff levied upon the defendant's interest in the real property situated in North Newton Township, Cumberland County, PA known and numbered as 2225 Rimer Highway, Shippensburg, more fully described on Exhibit "A" filed with this writ and by this reference incorporated herein. Date: May 2, 2003 Real Egtate Deputy THE PATRIOT NEWS THESUNDAY PATRIOT NEWS Proof of Publication UnderAct No. 587, Approved May16, 1929 Commonwealth of Pennsylvania, County of Dauphin} ss Joseph A. Dennison, being duly sworn according to law, deposes and says: That he is the Asst. Controller of The Patriot News Co., a corporation organized and existing under the laws of the Commonwealth of Pennsylvania, with its principal office and place of business at 812 to 818 Market Street, in the City of Harrisburg, County of Dauphin, State of Pennsylvania, owner and publisher of The Patriot-News and The Sunday Patriot-News newspapers of general circulation, printed and published at 812 to 818 Market Street, in the City, County and State aforesaid;; that The Patriot-News and The Sunday Patriot-News were established March 4th, 1854, and September 18th, 1949, respectively, and all have been continuously published ever since; That the printed notice or publication which is securely attached hereto is exactly as printed and published in their regular daily and/or Sunday/ Metro editions which appeared on the 22nd and 29th day(s) of July and the 5th day(s) of August 2003. That neither he nor said Company is interested in the subject matter of said printed notice or advertising, and that all of the allegations of this statement as to the time, place and character of publication are true; and That he has personal knowledge of the facts aforesaid and is duly authorized and empowered to verify this statement on behalf of The Patriot-News Co. aforesaid by virtue and pursuant to a resolution unanimously passed and adopted severally by the stockholders and board of directors of the said Company and subsequently duly recorded in the office for the Recording of Deeds in and for said County of Dauphin in Miscellaneous Book "M", Volume 14, Page 317. COPY Sworn to ~(p..~ubscribedft / .-.--~ .-before me/jth~ 13th day of.~ust/~ A.D. n~y c~mmission Exiles June 6, 2~06 MyJ commission expires June 6, 2006 Memb~. PenmY~aNa Assodak~ Of No,aC, es CUMBERLAND COUN'rY SHERIFFS OFFICE CUMBERLAND COUNTY COURTHOUSE CARLISLE, PA. 17013 Statement of Advertising Costs To THE PATRIOT-NEWS CO., Dr. For publishing the notice or publication attached hereto on the above stated dates Probating same Notary Fee(s) Total $ 205.44 $ 1.75 $ 207.19 Publisher's Receipt for Advertising Cost The Patriot News Co., publisher of The Patriot-News and The Sunday Patriot-News, newspapers of general circulation, hereby acknowledge receipt of the aforesaid notice and publication costs and certifies that the same have been duly paid. PROOF OF PUBLICATION OF NOTICE IN CUMBERLAND LAW JOURNAL (Under Act No. 587, approved May 16, 1929), P. L.1784 STATE OF PENNSYLVANIA : : COUNTY OF CUMBERLAND : SS. Lisa Marie Coyne, Esquire, Editor of the Cumberland Law Journal, of the County and State aforesaid, being duly sworn, according to law, deposes and says that the Cumberland Law Journal, a legal periodical published in the Borough of Carlisle in the County and State aforesaid, was established January 2, 1952, and designated by the local courts as the official legal periodical for the publication of all legal notices, and has, since January 2, 1952, been regularly issued weekly in the said County, and that the printed notice or publication attached hereto is exactly the same as was printed in the regular editions and issues of the said Cumberland Law Journal on the following dates, viz: JULY 18, 25, 2003 AUGUST 1, 2003 Affiant further deposes that he is authorized to verify this statement by the Cumberland Law Journal, a legal periodical of general circulation, and that he is not interested in the subject matter of the aforesaid notice or advertisement, and that all allegations in the foregoing statements as to time, place and character of publication are true. REAL ~TATE ~ALE NO. 15 Writ No. 2003 10 Civil Dovenmuehle Mortgage Co. LP VS. Emory G. Johnson, Jr. and Catherine M. Johnson Att~.: Joseph Goldbeck SCHEDULE "A' ALL THAT CERTAIN lot or Lract of land situate ir, North Newton Town- ship, Cumberland County, Pennsyl- vania, more fully bounded and de- scribed as follows, to wit: BEGINNING at a railroad spike in United States Route # l 1, at the corner of Lot # 1 on a Subdivision plan of George W. Baker, said plan being recorded in the Office of the Recorder of Deeds of Cumberland County, Pennsylvania at Plan Book 35. Page 101; thence by the lh~e of Lot #1 on said subdivision plan, North 28 degrees, 13 minutes 44 seconds West 341.32 feet to an iron ,~sa Marie Coyne, Edi~ SWORN TO AND SUBSCR, DSq~D before me this 1 dayof AUGUST, 2003 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 p!aintiff DOVENMUEHLE MORTGAGE CO. LP 1501 Woodfield Road Schaumburg, IL 601734982 Plaintiff VS. EMORY G. JOHNSON JR. CATHERINE M. JOHNSON Mortgagors and Record Owners THE UNITED STATES OF AMERICA 2225 Rimer Highway Shippensburg, PA 17257 Defendants IN THE COURT OF COMMON PLEAS of Cumberland County CIVIL ACTION - LAW ACTION OF MORTGAGE FORECLOSURE No. 03-10 CIViL TERM CERTIFICATE OF SERVICE PURSUANT TO Pa. ILC.P. 3129.2 (c} Joseph A. Goldbeck, Jr., Esquire, Attorney for Plaintiff, hereby certifies that service on the Defendants of the Notice of Sheriff Sale was made by: ) ) ) Personal Service by the Sheriffs Office/competent adult (copy of return attached). Certified mail by Joseph A. Goldbeck, Jr. (original green Postal return receipt attached). Certified mail by Sheriffs Office. Ordinary mail by Joseph A. Goldbeck, Jr., Esquire to Attorney for Defendant(s) of record (proof of mailing attached). Acknowledgment of Sheriff's Sale by Attorney for Defendant(s) (proof of acknowledgment attached). Ordinary mail by Sheriffs Office to Attorney for Defendant(s) of record. IF SERVICE WAS ACCOMPLISHED BY COURT ORDER. ( ) Premises was posted by Sheriffs Office/competent adult (copy of return attached), ( ) Certified Mail & ordinary mail by Sheriffs Office (copy of return attached). ( ) Certified Mail & ordinary mail by Joseph A. Goldbeck, Jr. (original receipt(s) for Certified Mail attached). Pursuant to the Affidavit under Rule 3129 (copy attached), service on all lienholders (if any) has been made by ordinary mail by Joseph A. Goldbeck, Jr., Esquire (copies of proofs of mailing attached). The undersigned understands that the statements herein are subject to the penalties provided by 18 P.S. Section 4904. Respectfully submitted, BY./~os~ph A~. Goldbeck, Jr. A~ney for Plaintiff 7160 3901 9844 3519 5283 7160 3901 9844 3519 5290 TO: JOHNSON JR., EMORY G. '~"Q; JOHNSON, CATHERINE M. EMORY G. JOHNSON JR. CATHERINIE M. JOHNSON 2225 Rifler Highway 2225 Rifler Highway Shippensburg, PA 17257 Shippensburg, ]PA 17257 SENDER: GOLDBECK MCCAFFERTY & MCKEEVER March 11, 2003 GOLDBECK MCCAFFERTY & MCKEEVER SENDER: March 11, 2003 REFERENCE: JOHNSON, EMORY G. JR. / DOV-0147 REFERENCE• ' JOHNSON EMORY G JR / DOV O9/03/O;~ -Cumberland , . . -0147 09/03/03 -Cumberland PS Form 3800, June 2000 PS For 3800 J RETURN Postage _ m RETURN , une 2000 - '- Postage --- RECEIPT _ SERVICE Certified Fee RECEIPT Certified Fee R - SERVICE eturn Receipt Fee Return Receipt Fee _ Restricted Delivery ~ ~ Restricted Deliver _ y Total Postage & Fees ~ ; , n \.~}~`, Total Postage & Fees r-- '~ " `~ ~ ~ _ ~ ~. i US Postal Service ~' ~ P ARK 9~ DATE _. I Jy US Postal Service POS ~K OR DATE ~~'4, Recei t for p tr yo `ti-~r~rj r ~_-.:~~~/ Receipt for z i ~ ~- ~. ; ,;~.j; a~ , o Certified Mail fQ~~ ~-' Certified M il ~ a ~9,0~ No Insurance Coverage Provided Do Not Use for lnterr~alional Mari No Insurance Coverage Provided Do Not Use Yor International Mail ?160 3901 9844 3519 5306 1'Q; THE UNITED STATES OF AMERICA 615 Chestnut Street Suite 1250 Philadelphia, PA 19106 SENDER' GOLDBECK MCCAFFERTY & MCKEEVER March 11, 2003 REFERENCE: JOHNSON, EMORY G. JR. / DOV-0147 09/03/03 -Cumberland PS Form 3800, June 2000 RETURN Postage RECEIPT Certified Fee SERVICE - Return Receipt Fee Restricted Delivery Total Postage & Fees US Postal Service P r. ,; ; ARK OFt`DAT ? Z Receipt for y ~;; o `' ~ Certified Mail ,y,~ No Insurance r;wer3ge Prnvide~.t Go Not Use for internaGanal Mad AFFIDAVIT OF SERV~ICE State of PA, County of CUMBERLAND Circuit Court Case Number 03-10 Plaintiff: Dovenmuehle Nortgage Co., LP Vs Defendant: Emory G. Johnson Jr. For: JOSEPH A. GOLDBECK, JR GOLDBECK, MCCAFFERTY & MCKEEVER Received by DEFAULT-LINK INVESTIGATIONS, INC. on 3/26/03 to be served on The United States of America, Attn: Chie, Civil Div., Federal Bldg., 228 Walnut Sl~, Room 116,2, Harrisl?urg~ PA 17108- 1754. I,~0~,tJ ¢.~0~ , being duly sworn, depose and say t!~at on the ~day of ~4&vf-~ , 2003, at ~__:~t~ .m., executed ~ervice by delivering a txue copy of the Notice of Sheriff Sale in accordance with state statues in the manner marked below: Title of person ~ a'~.4c-4~t~(° of the within-named agency. 01~ AUTHORIZED TO ACCEPT SERVICE ( ) NON SERVE FOR THIS REASON BELOW: ( ) OWNER OCCUPIED ( ) PROPERTY IS VACANT ( ) PER ATTORNEY ( ) NOT MARRIED COMMENTS: Housing Type: ( ) Single ( ) Duplex ( ) Mobile Home ( ) Triplex ( ) Other Addresses for additional units, Etc.: I certify that I have no interest in the above action, am of legal age and have prompter authority in the jurisdiction in which this Subscribed and sworn to before me on the ~,- day of_~:::~,~,2~ by the affiant who is personally /][tROCESSSE~RV'ERg' t/If/ [ ] APPO II~FED IN ACCORDANCE ~l'l~lt ST~ STATUTES tary Public 5449 S. SEMORP~ BLVD. SUITE 235 ORLANDO, FL 32822 N©TARIAL SEAL (877) 737-4155 dENNIEER R. DR©W, Notar~ Public Harrisburg, Dauphin County My Commission Expires April 29, 2006 Matter No: DOV-0147 Dovenmuehle Mortgage co. LP VS Emory G. Johnson, Jr. And Catherine M. Johnson In The Court of Common Pleas of Cumberland County, Pennsylvania Writ No. 2003,-10 Civil Term Timothy Reitz, Deputy Sheriff, who being duly sworn according to law, states that on May 15, 2003 at 6:45 o'clock PM, he served a true copy of the within Real Estate Writ, Notice and Description, in the above entitled action, upon the within named defendant, to wit: Emory G. Johnson, Jr., by making known unto Catherine Johnson, wife of defendant, at 2225 Ritner Highway, Shippensburg, Cumberland County, Pennsylvania, its contents and at the same time handing to her personally the said tree and correct copy of the same. Timothy Reitz, Deputy Sheriff, who being duly sworn according to law, states that on May 15, 2003 at 6:45 o'clock PM, he served a true copy of the within Real Estate Writ, Notice and Description, in the above entitled action, upon the within named defendant, to wit: Emory G. Johnson, Jr., by making known unto Catherine Johnson, wife of defendant, at 2225 Rimer Highway, Shippensburg, Cumberland County, Pennsylvania, its contents and at the same time handing to her personally the said true and correct copy of the same. Brian Barfick, Deputy Sheriff, who being duly sworn according to law, states that on July 9, 2003 at 6:49 o'clock P.M., he posted a true copy of the within Real Estate Writ, Notice, Poster and Description, in the above entitled action, upon the property of Emory G. Johnson, Jr. and Catherine M. Johnson located at 2225 Rimer Highway, Shippensburg, Pennsylvania, according to law. R. Thomas Kline, Sheriff, who being duly sworn according to law, states he served the above Real Estate Writ, Notice, Poster and Description in the following manner: The Sheriffmalled a notice of the pendency of the action to one of the within named defendants, to wit: Emory G. Johnson, Jr., by regular mall to his last known address of 2225 Rimer Highway, Shippensburg, PA 17257. This letter was mailed under the date of July 3, 2003 and never returned to the Sheriffs Office. R. Thomas Kline, Sheriff, who being duly sworn according to law, states he served the above Real Estate Writ, Notice, Poster and Description in the following manner: The Sheriffmailed a notice of the pendency of the action to one of the within named defendants, m wit: Catherine M. Johnson, by regular mail to her last known address of 2225 Rimer Highway, Shippensburg, PA 17257. This letter was mailed under the date of July 03, 2003 and never returned to the Sheriffs Office. Sworn and subscribed to before me This 2003, A.D. day of Prothonotary R. Thomas Ki[ine, Sheriff Real Estatk.~)eputy 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 DOVENMUEHLE MORTGAGE CO. LP 1501 Woodfield Road Schaumburg, IL 601734982 Plaintiff VS. EMORY G. JOHNSON JR. CATHERINE M. JOHNSON Mortgagors and Record Owners THE UNITED STATES OF AMERICA 2225 Rimer Highway Shippensburg, PA 17257 Defendants IN THE COURT OF COMMON PLEAS of Cumberland County CIVIL ACTION - LAW ACTION OF MORTGAGE FORECLOSURE No. 03-10 CIVIL TERM AFFIDAVIT PURSUANT TO RULE 3129 DOVENMUEHLE MORTGAGE CO. LP, 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: 2225 Rimer Highway Shippensburg, PA 17257 1 .Name and address of Owners or Reputed Owners: EMORY G. JOHNSON JR. 2225 Rimer Highway Shippensburg, PA 17257 CATHERINE M. JOHNSON 2225 Ritner Highway Shippensburg, PA 17257 2. Name and address of Defendants in the judgment: EMORY G. JOHNSON JR. 2225 Rimer Highway Shippensburg, PA 17257 CATHERINE M. JOHNSON 2225 Ritner Highway Shippensburg, PA 17257 THE UNITED STATES OF AMERICA 615 Chesmut Street Suite 1250 Philadelphia, PA 19106 3. Name and last known address of every judgment creditor whose judgment is a record lien on the property to be sold: DOMESTIC RELATIONS OF CUMBERLAND COUNTY PO Box 320 Carlisle, PA 17013 PA DEPARTMENT OF PUBLIC WELFARE Bureau of Child Support Enforcement Health and Welfare Bldg. - Room 432 P.O. Box 2675 Harrisburg, PA 17105-2675 PENNSYLVANIA DEPT. OF REVENUE Dept. 280946 Harrisburg, PA 17128 4. Name and address of the last recorded holder of every mortgage of record: 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 tree and correct tn the best of my personal knowledge or information and belief. I understand that false statements herein are made subject to the penalties of 18 Pa. C.S. Section 4904 relating to unsworn falsification to authorities. DATED: July 31. 2003 OO/I~D~BECK I~C, ~,AFFERTY & McKEEVER B~: J/6seph A. Goldb¢ck, Jr., Esq. Atto?ney for Plaintiff