HomeMy WebLinkAbout98-02603
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PRAECIPE FOR WRIT OF EXECUTION-(MORTGAGE FORECLOSURE)
P.R.C,P. 3180.3183
........................,.......................................,..""........
GE CAPITAL MORTGAGE SERVICES,
INCOItPORATIlD
IN THE COURT OF CO~I:'ION PLEAS OF
CUMBERLAND COUNTY, PENNSYLY ANIA
.......................................................--...................
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No" .."?'b~hJ.lJ...l;l.ns......,,................ Term 19 ....".
...............................................................................
KIlYlN ... CONLEY
cATHERINE A. CON1,EY
PRAECIPE }o"OR WRIT OF EXECUTION
(MORTGAGE FORECLOSURE)
.......................................................-........~............
To the Director DC the OCClce oC
....
~...
Tssue wr!t of execution fn the IIbol'e mAtter:
Amount DUe,
'..1~J.U\"ZJ.......
~
Interest from 7/1"/98 TO SALE $...J.~lJ~.,.~Il....... and Cost..
@ $12.05 PER DIEM
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Note: Ple~e attach description of Property,
...............,-,Let:L~
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ALL THAT CERTAIN real estate situate on the South side of East King Street, known as 404.406
. c f.~st King Street in the Borough of Shippensburg, Cumberland County, Pennsylvania, bounded and
described as follows:
['REMISES "A"
TRACT NO, 1: BEGINNING at a point on East King Street at line of lots now or fonnerly of
Smith, known as 401 East King Street, Shippensburg, Pennsylvania; thence along East King Slreet,
North 45 degrees 44 minutes 30 seconds East, 15,62 feet to II point; thence through the center of a
double house known as 404.406 East King Street, South 44 degrees 28 minutes 43 seconds East,
13.77 feet; thence by the same, North 45 degrees 31 minutes 17 seconds East, 2,30 feet to a point;
thence by the same, South 44 degrees 28 minutes 43 seconds East, 14,11 feet to a point; thence by
Tract No.2, now or formerly of Lynch, SOUlh 45 degrees 43 minutes East, 92.15 feet to a point;
thence along a three bay garage, South 45 degrees 21 minutes 39 seconds West, 3,65 feet to a point:
thence through the center of said three bay garage and along Tract No, 2, now or formerly of
Lynch, South 44 degrees 57 minutes 39 seconds bst. 41. 34 feet to a point at line of lot now or
formerly of Mooney; thence by lhe same, South 45 degrees 44 minutes 30 seconds West, 17, II feet
to an iron pin at line of lot now or formerly of Smilh, known as 402 East King Street; thence by the
same, North 44 degrees 30 minutes West. 176,33 feet 10 the place of BEGINNING,
BEING a portion of Lot No, 10 of the General Plan of the Borough of Shippensburg and known as
404 East King Street. Shippensburg. Pennsylvania,
TAX PARCEL NUMBER: 32..33-1869-078
fREMISES "B"
TRACT NO.2: BEGINNING at a point on East King Street at line of lot now or formerly of
Sollenberger; thence by the same, South 44 degrees 30 minutes East, 257.33 feet to an Iron pin;
thence along East Neff Avenue/, South 45 degrees 44 minutes 30 seconds West, 10.83 feet to an Iron
pin; thence along line of land now or formerly of Mooney, North 44 degrees 30 minutes West,
81.00 feet to an iron pin; thence by the same/, South 45 degrees 44 minutes 30 seconds West, 9,89
feet to a point; thence along Tract No. I, known as 404 East King Street, Shlppensburg,
Pennsylvania, and through the center of a three bay garage, North 44 degrees 57 minutes 39 seconds
West, 41.34 feet to a point; thence by the same, North 45 degrees 43 minutes West, 92.15 feet to
point; thence by the same and through the center of a double house known as 404-406 East King
Street, North 44 degrees 28 minutes 43 seconds West, 14.71 feet to a point; thence by the same,
South 45 degrees 31 minutes 17 seconds West, 2.30 feet to a point; thence by the same, North 44
degrees 28 minutes 43 seconds West, 13.77 feet to a point; thence by the same, South '45 degrees 31
minutes 17 seconds West, 0.57 feet to a point; thence by the same, North 44 degrees 28 minutes 43
seconds West, 14,37 feet to a point on East King Street; thence by the same, North 45 degrees 44
minutes 30 seconds East, 22.21 feet to the place of BEGINNING.
BEING a portion of Lot No. 10 of the General Plan of the Borough of Shippensburg, known as 406
East King Street, Shippensburg, Pennsylvania,
BOTH TRACTS SUBJECT to a right of passage. both pedestrian and vehicular, in the owners, their
heirs and assigns. of the lot adjacent on the West, over the rear of the above described premises and
extending Southerly to East Neff Avenue, having a width of 10 feet, more or less.
TAX PARCEL NUMBER: 32-33..1869-078A
TITLE TO SAID PREMISES "A" AND "B" IS VESTED IN Kevin F, Conley and Catherine A.
Conley. his wife by Deed from Bradley E. Carson and Jacqueline K. Carson, his wife dated
12/30/94 recorded 1/4/95 in Record Book 117 Page 180,
You may need an attornoy to aDS('rt your rights, '1'he sooner
you contact one / the more chanco l/oU ~i.l.ll have of stopping the
sale, (See notice on pilge two on how to obtain an attorney,)
:tQY...1I.AI_~~!Tk~JlJL"l\.I;Jj.JLTQ..~A V E -YQI!R_j>RQ!'_~R T }'._r.~!1_ YOU_JL1\ VFLQIIIM
B.l.l,1~_mrj'L~_jF__'l'!i~...J!!J1!RU'F.!_lL~~_k~.P'Q ~:.EJ. _TM~,fJ.J't.l\gJl.,--
1,
be sold
calling
If the Sheriff's Sale
to the highest bidder.
i2.J_~L21i}-=LQQn '
is not stopped, your property will
You may find out the price bid by
2.
sale if
of YClUr
You may be able to peti tlCln the Court to Get aside the
the bid price was grossly inadequate compilred to the value
propl'Jrty.
J. The sale will go throuCjh only if the buyer pays the
Sheriff the full amount dUB in the sale. To find out if this has
happened, you may call (215) 563-,/000,
4. I f 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 havo the right to r('ma i n in the property unti 1 the
full amount due is paid to the Sheriff and the Sheriff gives a deed
to the buyer, At that time, the buyer may bring legal proceedings
to evict you.
6. You may be entitled to a share of the money which was paid
for your house. A schedUle of distribution of the money bid for
your house will be filed by the Sheriff on This
schedule will state who will be receiving that money. The money
will be paid out in accordance with this SChedule unless exceptions
(reasons why the proposed distribution is wrong) are filed with the
Sheriff within ten (10) days after
7. You may also have other rights and defenses, or ways of
getting your home 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.
CUMDERLAND COUNTY ATORNEY REFERRAL
CUMDERLAND COUNTY DAR ASOCIATION
2 LIDERTY AVENUE
Cumberland County Courthouse
CARLISLE, PA 17013
(717) 249-3166
(BOO) 990-910B
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ALL THAT CERTAIN real estate situate on the South side of East King Street, known as 404-406
'East King Street In the Borough of Shippensburg, Cumberland County, Pennsylvania. bounded and
described as follows:
PREMISES "A"
TRACT NO, I: BEGINNING at a point on East King Street at line of lots now or formerly of
Smith, known as 402 East King Street, Shippensburg, Pennsylvania; thence along East King Street,
North 45 degrees 44 minutes 30 seconds East. 15,62 feet to a point; thence through the center of a
double house known as 404-406 East King Street, South 44 degrees 28 minutes 43 seconds East,
13,77 feet; thence by the same, North 45 degrees 31 minutes 17 seconds East, 2,30 feet to a point;
thence by the same, South 44 degrees 28 minutes 43 seconds East, 14,71 feet to a point: thence by
Tract No.2, now or formerly of Lynch, South 45 degrees 43 minutes East, 92,15 feet to a point;
thence along a three bay garage. South 45 degrees 21 minutes 39 seconds West, 3,65 feet to a point;
thence through the center of said three bay garage and along Tract No.2, now or formerly of
Lynch. South 44 degrees 57 minutes 39 seconds East, 41.34 feet to a point at line of lot now or
fonnerly of Mooney; [hence by the same. South 45 degrees 44 minutes 30 seconds West, 17, II feet
to an iron pin at line of lot now or formerly of Smith, known as 402 East King Street; thence by the
same, North 44 degrees 30 minutes West. 176,33 feet to the place of BEGINNING,
BEING a portion of Lot No. 10 of the General Plan of the Borough of Shippensburg and known as
404 East King Street. Shippensburg. Pennsylvania,
TAX PARCEL NUMBER: 32-33-1869..078
PREMISES "B"
TRACT NO, 2: BEGINNING at a point on East King Street at line of lot now or fonnerly of
Sollenberger; thence by the same, South 44 degrees 30 minutes East, 257,33 feet to an iron pin;
thence along East Neff Avenue, South 45 degrees 44 minutes 30 seconds West, 10,83 feet to an iron
pin; thence along line of land now or formerly of Mooney, North 44 degrees 30 minutes West,
81.00 feet to an iron pin; thence by the same, South 45 degrees 44 minutes 30 seconds West, 9.89
feet to a point; thence along Tract No.1, known as 404 East King Street, Shippensburg,
Pennsylvania, and through the center of a three bay garage, North 44 degrees 57 minutes 39 seconds
West, 41.34 feet to a point; thence by the same, North 45 degrees 43 minutes West, 92.15 feet to
point; thence by the same and through the center of a double house known as 404-406 East King
Street, North 44 degrees 28 minutes 43 seconds West, 14.71 feet to a point; thence by the same,
South 45 degrees 31 minutes 17 seconds West, 2.30 feet to a point; thence by the same, North 44
degrees 28 minutes 43 seconds West, \3,77 feet to a point; thence by the same, South'45 degrees 31
minutes 17 seconds West, OS/ feet to a point; thence by the same, North 44 degrees 28 minutes 43
seconds West, 14,37 feet to a point on East King Street; thence by the same, North 45 degrees 44
minutes 30 seconds East, 22.21 feet to the place of BEGINNING.
BEING a portion of Lot No, 10 of the General Plan of the Borough of Shippensburg, known as 406
East King Street, Shippensburg. Pennsylvania.
BOTH TRACTS SUBJECT to a right of passage, both pedestrian and vehicular, in the owners, their
heirs and assigns. of the lot adjacent on the West, over the rear of the above described premises and
extending Southerly to East Neff Avenue, having a width of 10 feet, more or less,
TAX PARCEL NUMBER: 32-33-1869-078A
TITLE TO SAID PREMISES" A" AND "9" IS VIiS.Ilill...lli Kevin F, Conley and Catherine A.
Conley, his wife by Deed from Bradley E. Carson and Jacqueline K. Carson, his wife dated
12/30/94 recorded 1/4/95 in Record Book 117 Page 180.
D:~BP6 NOC0102
Dwyebr;:;-a;y 17, 1998
'-"'-
NOTICE OF INTENTION TO F~~~~I
MORTGAGE UND~R SECTION 403 OF PA
ACT NO. 6 OF 1974. (READ BOTH
GJiIiflt!!/ ~gi'l1fl!v9'i'l'O.ICE CA.REFULLY.)
I:' 'I. ,';1
KEVIN F CONLEY
404-406 :;: KING
SHIPPENsaUR,
ST
17257
REI GE LOAN # 0030268718
PROPERTY 404-406 EKING ST SHIPPENSBUR, PA 17257
MORTGAGEE. G.E. CAPITAL MORTGAGE SERVICES
The Mortgage held or oervicad by GE capital Mortgage Servicee (hereinafter
we, ue, or ours) on your property noted above is in serioue default
because you have not made the monthly payments aa noted below under (a).
Late charges under (b) and other charges, if any, under (c) noted below,
have also accrued to this date. The total amount now rsquired to cure this
default as of the date of this Istter, is noted below under (e).
(a) OB0197 thru 020198 @ S699.61/month $4,897.27
(b) Late charge(e). $359.58
(0) NSF check charge(s). .00
(d) Lessl credit Balance 464.11
(e) Total amount required ae of this date. $4,792.74
Notice To Borrower Discharged In Banlc.rupt.cy. As a result of your
bankruptcy discharge, you do not have any personal liability for the
payment of Note and Mortgage/Deed of Trust. The bankruptcy discharge,
however, did not affect the lien or security interest in the property
securing the account. The failure to cure the past due amounts as
explained in this letter will result in a foreclosure/reposseasion of your
property subjeot to the Note and Mortgage/Deed of Trust.
You may cure this default within THIRTY (30) days of this letter by paying
to us the amount under (e) above, plus any additional monthly payments and
late charges (and other charges) which may fall due during this period.
such payment must be either by cash, cashier's cheek, certified check, or
money order made payable to o.E.Capital Mortgage Services, 625 Maryville
Centre, St. Louie, MO 63141, Attention. Cashiering Department.
If you do not cure the default within THIRTY (30) days, we intend to
exerciue tho noteholder's right to aocelerate the mortgage payments. This
means that whatever is owing on the original mortgage amount borrowed will
be considered due immediately, and you may lose the chance to payoff the
original mortgage in monthly installments. If full payment of tho amount
of default is not made within THIRTY (30) days, we a180 intend to instruct
our attorneys to start a lawsuit to foreclose your mortgage property. If
the mortgage is foreclosed, your mortgage property will be sold by the
EXHIBIT A
DD~BP6___NOCOI02
D\~ebrUary 17, 1998
GE Capital
NOTICE OF INTENTION TO FORECLOSE
MORTOAOE UNDER SECTION 403 OF PA
GA&fI11ndfl"''Il'IIr,'i<'''1"''4'f (READ BOTH
I'A'\l~$ ~F tllXS' NC:lTfcE CAREFULLY.)
KEVIN F CONLEY
1715 HASTINOS ROAD
BETHLEHEM, PA 18017
RE. GE LOAN # 0030268718
PROPERTY 404-406 EKING ST SHIPPENSBUR, PA 17257
MORTGAGEE I O.E. CAPITAL MORTGAGE SERVICES
The Mortgage held or serviced by GE capital Mortgage Serviceo
(hereinafter we, us, or ours) on your property noted above is in serio~s
defaul~ becauso you have not made the monthly payments as no~ed below
under (a). Late charges under (b) and other charges, if any, under (c)
noted below, have a190 accrued to this date. The total amount now required
to cure this default as of the date of this letter, is noted below under
(e) .
(a) 080197 thru 020198 @ S699.61/month
$4,897.27
(b) Late charge(s).
(c) NSF cheok charge(").
(d) Lese. credit Balance
(e) Total amount required as of this date,
$359.58
.00
464.11
$4,792.74
Notice To Borrower Discharged In Bankruptcy. As a result of your
bankruptcy discharge, you do not have any personal liability for the
payment of Note and Mortgage/Deed of Trust. The bankruptcy discharge,
however, did not affect the lien or security interest in ths property
eecuring the account. The failure to cure the past due amounts as
explained in this letter will reoult in a foreclosure/repoosession of your
property subject to the Note and Mortgage/Deed of Trust.
You may cure this default within THIRTY (30) days of this letter by paying
to us the amount under (e) above, plus any additional monthly payments and
late charges (and other charges) which may fall due during this period.
Such payment must be either by cash, cashier's check, certified check, or
money order made payable to G.E.Capital Mortgage Services, 625 Maryville
Centre, St. I,ouis, MO 6314l, Attention: Cashiering Departmen't.
It you do not cure the default within THIRTY (30) daye, we intond to
exercise the noteholder's right to accelerate the mortgage payments. Thie
meane that whatever is owing on the original mortgage amount borrowed will
be considered due immediately, and you may loae the chance to payoff the
original mortgage in monthly installments. If full payment of the amount
of default ie not made within THIRTY (30) days, we aleo intend to instruct
our attorneys to start a lawsuit to foreclose your mortgage property. If
the mortgage is foreolosed, your mortgage property wiil be sold by the
EXHI\3IT A
O'lBP6 NOCOI02
o " ebr~-;;y 17, 199B
"--' ,
NOTICE OF INTENTION TO FcaeClip1t1l1
MORTGAGE UNDER SECTION 403 OF PA
ACT NO. 6 OF 1974. (READ BOTH
a~~~it'!J~\fIIH~gwllblf~CE CAREFULLY.)
'.- - -- ': ,\ :..','_" -f -:'
CATHERINt A CONLEY
404-406 EKING ST
SHIPPENSBUR, PA 17257
RE. GE LOAN # 003026B718
PROPERTY 404-406 EKING ST SHIPPENSBUR, PA 17257
MORTGAGEE I O.E. CAPITAL MORTGAGE SERVICES
The Mortgage held or serviced by GE Capital Mortgage services
(hereinafter we, us, or ours) on your property noted above is in serious
default because you have not made the monthly payments ae not.ed below
under (al. Late charges under (b) and other charges, if any, under Ic)
noted below, have also accrued to this date. The total &mqunt now requh'ed
to cure this default as of the date of this letter, is noted below under
Ie) .
10.) 080197 thru 020198 @ /month
Ib) Late charge(e).
(c) NSF check charge(s).
(d) Leee. Credit Balance
(e) Total amount required as of this date.
$359.58
.00
464.11
$4,'/92.74
NotioEl To Borrower Dl.scharged In Bankruptcy. As a reeult of YOllr
bankruptcy discharge, you do not have any personal liability for the
payment of Nots and Mortg~ge/DeBd of Trust. The bankruptcy discharge,
however, did not affect the lien or security inte~sst in the property
sec1lting the account. The failure t,o cure the past clue amounte as
explained in this letter will result in a foreclosure/repossession of your
property subject to the Note and Mortgage/Deed of Trust.
You may cure thie default within THIRTY (30) days of this letter by paying
to us the amount under (e) above, plus any additional monthly payments and
late charges (and other charges) which may fall due during this period.
Such payment must be either by cash, cashier's check, certified check, or
money order made payable to O.E.Capital Mortgage Services, 625 Maryville
.
centre, St. Louis, MO 63141, Attention. Cashiering Department.
If you do not cure the default within THIRTY (30) days, we intend to
ey.ercise the noteholder's right to accelerate the mortgage payments. Thie
means that whatever is owing on the original mortgage amount borrowed will
be considered due immediately, and you may lose the chance to payoff the
original mortgage in monthly installments. If full payment of the amount
of default is not made within THIRTY (30) daya, we also intend to inetruct
our attorneys to etart a laweuit to foreclOSe your mortgage property. If
the mortgage ie foreclosed, your mortgage property will be sold by the
EXHIBIT A
DD.~BP6 NOCOI02
D~~'ebr;;;;r~. 17, 1998.
NOTICE OF INTENTION TO f'~a.p""
MORTOAGE UNDER SECTION 403 OF PA
ACT NO. 6 OF 1974. (READ BOTH
n~~m""t/II"'f1''i'~Vi'lf~.l't''1!CE CAREFULLY.)
"'c'! L"'i .,,1,,';1;'" .,'
CATHERINE A CONLEY
1715 IlASTINOS ROAD
BETHLEHEM, PA IB017
~E. GE LOAN # 003026B718
PROPf.RTY 404-406 E KINO ST SHIPPENSBUR, PA 17257
MORTGAOEE. O.E. CAPIT~L MORTGAGE SERVICES
The Mortgage held or serviced by OE Capital Mortgage Services
(hereinafter we, us, or ours) on your property noted above is in serious
default because yo", have not made the monthly payments as noted below
under (a). Late charges under (b) and other chargee, if any, under (~)
noted below, have also accrued to this date. The total amount now required
to cure this default as of the date of this letter, io noted below under
(e) .
(a) 080197 thru 020198 @ /month
(b) Late charge(s).
(C) NSF check charge(s).
(d) Less. Credit Balance
(e) Total amount required as of this date.
$359. S8
.00
464. 11
$4,792.74
Notice To Bor,t'ower Discbarged In Bankruptcy. As a resul,t of your
bankruptcy discharge, you do not havs any personAl liability for the
payment of Note and Mortgage/Deed of Trust. The bankruptcy diecharge,
however, did not affect the lien or security interest in the property
securing the account. The failure to cure the past due amounts As
explained in this letter will result in a forecloeurs/repossession of your
property subject to the Note and Mortgage/Deed of Trust.
You may cure this default within THIRTY (30) days of this letter by paying
to us the amount under (e) above, plus any additional monthly paymente and
late charges (and other charges) which may fall due during this period.
Su~h payment must be either by cash, cashier's check, certified check, or
money order made payable to G.E.Capital Mortgage Services, 625 Maryv1l1e
Centre, St. Louis, MO 63141, Attention. Caohierlng Department.
It you do not cure the default within THIRTY (30) days, we intend to
exercise the noteholder's right to accelerate the mortgage paymente. This
meane that whatever is owing on the original mortgage amount borrowed will
be considered due J.mmediately, and you may lose the chance to pay at! the
original mortgage in monthly installment.s. If full payment of the amount
of default is not made within THIRTY (30) days, we also intend to instruct
our attorneys to start a lawsult to foreclose your mortgage property. If
the mortgage ie foreclosed, YClUl' mortgage property will bA sold by the .
EXHIBIT A
Shlj to payoff the mortgage dobt. I f we refer your case to our
a' .' ya, but you cure tha default before they bagin lagal proceedings
ag t you, you will have to pay the reasonabls attorney's fees actually
incurred ,up to $50.00. However, If legli,l proceedings us started 11fil8Jt{HfIi/
you, you will have to pay the reasonabls attorney'o fess even if they are
ovsr S50.00. Any attorney's fee. will bs added to whatsver you owe uo,
which may also include our reasonable cM."'MI!III~!"~~"e!ii~lIthe default
within the TIlIRTY (30) day period, you will not', be. r.equil:ed to pay
attorney's fess.
If you have not cured the default within the thirty day period, and
foreclosure proceedings have begun, you will still have the right to cUre
the default and prevent the oale at any time up to one hour before the
sheriff's foreclosure sale. Iou may do so by paying the total amount of
the unpaid monthly paymenrs plus any late chargee, charuee then due, as
well as the reasonable attorney's foes and costs connected with the
forsclosure sale (and pet'form any ather requirements under the mortgage).
It is estimated that the earliest date that such shariff's eale could be
held would be approximately FIVE MONTHS FROM THE DATE OF THIS LETTER.
A notice of the date of the sheriff's sale will be sent to you before the
ssle. Of course, the amount ne.ded to cure the default will inorease the
longer you wait. You may find out at any time exactly what the required
payment will be by calling us at he followirlg number.l (800) 326-4322 .
Thin payment must be in cash, cashier's check, certified check, or money
order and made payable to us at the address stated above.
Iou should realize that a sheriff's sale will end your ownership of the
mortgaged property and your right in it. If you continue to live in the
property after the sheriff's sale, a lawsuit could be atarted to evlct
you.
You have additional righte to help protect your interest in the property.
You have the right to sell the property to obtain money to payoff the
mortgage debt, or borrow money from another lending institution to payoff
this debt (you may have the right to sell or transfer the property subject
to the mortgage to a buyer or transferee who will assume the mortgage
debt, provided that all the outstanding payments, charges, attorney's fees
and coats are paid prior to, or at the sale and that ot:her requit'emente
under the Mortgage are satisfied). Contact us to determine under what
oircurnetances this right might exist. You have the right to have this
dsfault cured by any third party acting on your behalf.
If YOLl cure the default, the mortgage "ill be restoretl to the same
position as if no default had occurred. However, you are not entitled to
this right more than three times in a calendar year.
Sincerely,
30268718
Renee cowsen, Colleotions Representative
l (BOO) 326-4322
GE Capital Mortgage Services, Inc.
We understand that t,his debt has been discharged in bankruptcy. You will
have no personal liability if the mortgage loan is not paid. Despite
this, we are providing certain information to facilitate your decision
rsgarding the lien on your property s.curing the debt because the lien was
not affected by your discharge and if the mortgage is not paid,
foreclosure may occur. Certain stats laws and, for certain loans that we
ssrvice, federal law may require u. to (i) identify ourselves as a debt
collector and (il) say that this is an attempt to collect a debt and that
any information obtained will be used for that purpose. t. ,vt'ii~.'.!n(\ A
t_-...,1 '" IJ ~_ ,I & n
.' the Act, you 9re entitled to a temporary stay of for.eclosure on your
e fo~ thirty (30) days 'rom the date of thl.s Notice. . Durl.ng that
t ou must Ilrrang8 and attend a "face-to-face" meeting with a
representative of thia lander, or with a deaignatad consumer crel~BpitBI
ccunaelingagency. The purpo.. of thia meet ingis to attempt to work out a
....r..p..ym..nt. plan, or to otharwiae ..ttle your delinquenc'y. This meeting must
occur in the naxt thirty (30) days. GECilpil.,Morlg.g,Sorvio",/IIC.
. "1,', I/;.I'/!\I'i'fll,/'I" 1.._','I"'I:I:.'ii'.'
If you attend a tace-to-face meeting with till.' ~encleti:'(1lV'lfith 1\ consumer
credit counaeling agency identified in this notice, no further proceeding
,-_".. .....'-,.'J"!I'..",.,;./
in mortgage forecloaure may take place for thirty "( 3'0) days aftet' the date
of this meeting. The name, address, and telephone number of our
representative is.
a.E. capital Mortgage Servicee
2000 West Loop South, suite 1300
Iloueton, Texa. 77027
1 (800) 326-4322
The names and addresees of deeignated consumer credit counseling agenciee
are ahown on the attached sheet. It is only neceuary to sohedule one
face-to-face meeting. You should advise GE capital Mortgage Services. Inc.
imm..diately of your intentions.
Your mortgage is in default because one or more installments of principal
and interest, have not been paid for a~ least sixty (60) days. The total
amount of the delinquency is S4,792.74. That sum includes the followingl
payments due OB/Ol/97 through the first of this month and late chargee.
Your mortgage is also in default for the following reason.
Loss of rent.
Notice To Borrower Diecharged In Bankruptcy. ~s a result of your
bankruptcy discharge, you do not have any personal liability for t~e
paymant of Note and Mortgage/Dud of Trust. The bankruptcy discharge,
however, did not aUeot the lien or security intereet in the property
securing the account. The failurs to cure the past due amounts as
explained in thie letter will result in a foreclosure/repoasession of your
property subject to the Note and Mortgage/Deed of Trust.
If you have tried and are unable co resolve this problem at or after our
face~to-faoe meeting, you have the right to apply for financial asaiatance
from the Homaownors' Emergency Mortgage AssIstance Fund. In order to do
this, YOIl muet fill out, sign and file a completed Homeowners' !mergenoy
Assistance Application with one of the designated consumer credit
counseling agencies listed on ths attachment. An application for
assistance may only be obtained from a consumer credit counseling agency.
The consumer credit counseling agenoy will assist you in filling out your
application and will submit your completed application to the pennsylvania
Housing Finance Agenoy. Your application must be filed or postmarked,
within thirty (30) days of your face-to-face meeting.
EXHIBIT 8
.el'tremelY important that you file your application promptly. It you
, ,
~ do so, or if you do not follow other time period. .et forth in thi.
1 , forecloaure may proceed againat your home in~ediately.
, GE CapilBI
Availabla fl~nd. for emergency mortgage aesiltance are very limiteel. TtlllY
--'-"-"W-iTibe di.buriilia -by t"ile 'Aqlirio{-uiiijer-\;jiit..itTi~ ibiUtycrItli-i-u..hbl i.hed
by t he ACT. ~~I~~;':~~/ i'i~~i'~i'er~r~~!~~~~~;):i~i~;'!J1I
_'II!}!j \''/il\,' {uili};"'1111 '1'1/['11",00
It i. eKtrlJmely ,important that your applJicat'l.drl"iI.""aI:lCllllllt:lt and complete in
every rupect. The pennsy Ivania HOulingur~n,a.!"p~" ~,\I'~~lcy hu sixty (60) day.
to make a decision after it receives yourapplicaelon. During that
additional time, no foreclosure proceedings will be puraued againat you if
you nave m..t the t:ime requiuments set forth above. You will be notl.tied
direct:ly by the Agency of it. decision on your application.
The Pennsylvania Housing Finance Agency is locat:ed at 2101 North Front
Street, Post office BoX 8029, Harrisburg, pennsylv1nia 17105. Telephone
NO. (717) 780-3800 or 1-800-342-2397 (toll free number). Persona with
impaired hearing can call 1-800-342.'2397.
In addition, you may receive anothsr notice from GE capital Mortgage
Servicec, Inc. under Act 6 of 1974. That notice ia called a "Notice of
Intention to Foreclose." 'lou must read both notices, since they both
explain rights that you now havlO under pennsylvartia law. However, if you
chooes t:o exercise your rights described in this notice, you cannot be
foreclosed upon while you are receivi"g that aeaistanoe.
Sincerely,
30268718
Renee Cowsen, Collectione Representat:ive
1 (800) 326-4322
GE Capital Mort:gage Services, Inc.
We understand that this debt haa been discharged in bankruptcy. Yo~ will
have no personal liability if the mortgage loan is not paid. De.pita thi.,
we are providing certain informat:ion to facilitate your decision regarding
the lien on your property sec~ring the debt because the lien was not
affected by your discharge and if the mortgage is not paid, foreclo.ure may
ocour. Certain .tate lawe and, for certain loans that we .ervice, federal
law may require us to (i) identity ours6llves aD a debt: collector and (ii)
lay that thi. is an attempt to collect: a debt and that any infol~ation
obtained will be used for that purpose.
EXHIBIT P
DESCRIPTIOrs
ALL THA T CERTAIN real estate siIuate on the South side of East King Street, known as 404-406
East King Street in the Borough of Shippensburg, Cumberland County, Pennsylvania. bounded and
described as follows:
PREMISES" A"
TRACT NO.1: BEGINNING at a point on East King Street at line of lots now or formerly of
Smith, known as 402 East King Street, Shippensburg, Pennsylvania; thence along East King Street,
North 45 degrees 44 minutes 30 seconds East, 15,62 feet to a point; thence through the center of a
double house known as 404.406 EasI King Street, South 44 degrees 28 minutes 43 seconds East,
13,77 feet; thence by the same, North 45 degrees 31 minutes 17 seconds East, 1.30 feet 10 a point;
thence by the same, South 44 degrees 28 minuIes 43 seconds East, 14.71 feet 10 a point; thence by
TracI No, 2, now or formerly of Lynch, South 45 degrees 43 minutes East, 92,15 feet to a point;
thence along a three bay garage, South 45 degrees 21 minutes 39 seconds West. 3,65 feet 10 a point;
thence through the center of said three bay garage and along Tract No, 2, now or fonnerly of
l.ynch, South 44 degrees 57 minutes 39 seconds East, 41,34 feet to a point at line of lot now or
formerly of Mooney; thence by the same, South 45 degrees 44 minutes 30 seconds West, 17,11 feet
to an iron pin at line of lot now or formerly of Smith, known as 402 East King SIreet; thence by the
same, North 44 degrees 30 minuIes West. 176,33 feet to rhe place of BEGINNING,
BEING a portion of Lot No, 10 of the General Plan of the Borough of Shippensburg and known as
404 East King Street, Shippensburg, Pennsylvania,
TAX PARCEL NUMBER: 32-33-1869-078
pREMISES "B"
TRACT NO.1: BEGINNING at a point on East King Street at line of lot now or formerly of
Sollenberger; thence by the same, South 44 degrees 30 minutes East, 257.33 feet 10 an iron pin:
thence along East Neff Avenue, South 45 degrees 44 minutes 30 seconds West, 10,83 feel to an iron
pin; thence along line of land now or formerly of Mooney, North 44 degrees 30 minutes West,
81.00 feet to an iron pin: thence by the same, South 45 degrees 44 minutes 30 seconds West, 9,89
feet to a point; thence along Tract No, 1, known as 404 East King Street, Shippensburg,
Pennsylvania, and through the center of a three bay garage, North 44 degrees 57 minutes 39 seconds
West. 41.34 feet to a point; thence by the same, North 45 degrees 43 minutes West, 92,15 feet 10
point; thence by the same and through the center of a double house known as 404-406 EasI King
Street, North 44 degrees 28 minutes 43 seconds West, 14,71 feet to a point; thence by the same.
South 45 degrees 31 minutes 17 seconds West. 2,30 feet to a point; thence by the same, North 44
degrees 28 minutes 43 seconds West. 13,77 feet to a point; thence by the same, South 45 degrees 31
minutes 17 seconds West, 0,57 feet to a point; thence by the same, North 44 degrees 28 minutes 43
seconds West, 14,37 feet to a point on East King Street: thence by the same, North 45 degrees 44
minutes 30 seconds East, 22,21 feet to the place of BEGINNING,
BEING a portion of LCIl No, 10 of the General Plan of the Borough of Shippensburg, known as 406
East King Street, Shippensburg, Pennsylvania,
BOTH TRACTS SllBJECT to a right of passage, both pedestrian and vehicular, in the owners, their
heirs and assigns. of the lot adjacent on the West. over the rear of the above described premises and
extending Southerly [() East Neff Avenue, having a width of 10 feet. more or less,
TAX PARCEL NUMBER: 32-33-1869-078A
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ALL THA T CERTAIN real estate situate on the South side of East King Street, known as 404-406
,East King Street in the Borough of Shippensburg, Cumberland CoUnty, Pennsylvania. bounded and
described as follows:
PREMISES "A"
TRACT NO, 1: BEGINNING at a point on East King Street at line o~'lots now or formerly of
Smith, known as 402 East King Street, Shippensburg, Pennsylvania: thence along East King Street,
North 45 degrees 44 minutes 30 seconds East, 15,62 feet to a point; thence through the center of a
double house known as 404-406 East King Street, South 44 degrees 28 minutes 43 seconds East,
13,77 feet; thence by the same, North 45 degrees 31 minutes 17 seconds East, 2,30 feet to a point;
Ihence by the same, South 44 degrees 28 minutes 43 seconds East, 14,71 feet to a point; thence by
Tract No, 2, now or formerly of Lynch, South 45 degrees 43 minutes East, 92,15 feel [() a point;
thence along a three bay garage. South 45 degrees 21 minutes 39 seconds West, 3,65 feet to a poi,nt;
thence through the center of said three bay garage and along Tract No, 2, now or formerly of
Lynch, South 44 degrees 57 minutes 39 seconds East, 41.34 feet to a point at line of lot now or
formerly of Mooney; thence by the same, South 45 degrees 44 minutes 30 seconds West, 17, II feet
to an iron pin at line of lot now or formerly of Smith. known as 402 East King Street; thence by the
same, North 44 degrees 30 minutes West. 176,33 feet to the place of BEGINNING,
BEING a portion of Lot No, 10 of the General Plan of the Borough of Shippensburg and known as
404 Enst King Street. Shippen5burg, Pennsylvnnia,
TAX PARCEL NUMBER: 32-33-1869-078
PREMISES "B"
TRACT NO.2: BEGINNING at a point on East King Street at line of lot now or formerly of
Sollenberger; thence by the same, South 44 degrees 30 minutes East, 257,33 feet to an iron pin;
thence along East Neff Avenue, South 45 degrees 44 minutes 30 seconds West. 10.83 feet to an iron
pin; thence along line of land now or formerly of Mooney, North 44 degrees 30 minutes West,
81.00 feet to an iron pin; thence by the same. South 45 degrees 44 minutes 30 seconds West. 9,89
feet to a point; thence along Tract No, 1, known as 404 East King Street, Shippensburg. ,
Pennsylvania. and through the center of a three bay garage, North 44 degrees 57 minutes 39 seconds
West, 41.34 feet to a point; thence by the same. North 45 degrees 43 minutes West, 92.15 feet to
point; thence by the same and through the center of a double house known as 404.406 East King
Street. North 44 degrees 28 minutes 43 seconds West, 14,71 feet to a point; thence by the same,
South 45 degrees 31 minutes 17 seconds West. 2,30 feet to a point; thence by the same, North 44
degrees 28 minutes 43 seconds West, 13.77 feet to a point; thence by the same, South '45 degrees 31
minutes 17 seconds West, 0,57 feet to a point; thence by the same, North 44 degrees 28 minutes 43
seconds West, 14,37 feet to a point on East King Street; thence by the same, North 45 degrees 44
minutes 30 seconds East, 22,21 feet to the place of BEGINNING.
BEING a portion of Lot No, 10 of the General Plan of the Borough of Shippensburg. known as 406
East King Street, Shippensburg, Pennsylvania,
BOTH TRACTS SUBJECT 10 a right of passage, both pedesIrian and vehicular, in the owners, their
heirs and assigns. of Ihe lot adjacem on the West. over the rear of the above described premises and
extending Southerly to East Neff Avenue, having a width of 10 feet. more or less,
TAX PARCEL NUMBER: 32.33-1869-078A
TILLE TO SAID PREMISES "A" AND "B" IS VESTED IN Kevin F, Conley and Catherine A.
Conley. his wife by Deed from Bradley E. Carson and Jacqueline K. Carson, his wife dated
12/30/94 recorded 1/4/95 in Record Book 117 Page 180.
/....
You may need an attorney to assert your rights. The sooner
you contact one, the I~ore ch,lnce you wl.ll llilve of stopping the
sale. (See nOtJ.C~1 on page t'No on ho\~ t.o obtain an attorney.)
XQ.!1 MAY STl~IULl\.!tt.1L'!'Q.__SA~YOUR~J'RQnRTY ANI>, YOU HAVE OTHE~
lU.qu,T..LU~RJ.F_.TIUL1lli~Rl~r-'-!!_!l.l\t;!;_".P'Q~,I;l.._.'rM_!;:;__l'.Ml\c..ru
1.
be sold
oa lling
If the Sheriff's Sale
to the highest. bidder.
Lil.?.L563 =-70.QQ.
is not stopped, your property will
You may find out the price bid by
2. You may be able to petition the Court to set asicle the
sale if the bid price was grossly inadequate compared to the value
of your property.
J. The sale wi 11 go throllgh on 1 y if the buyer pays the
Sheriff the full amount due in the sale. To find dut if this has
happened, you may call (2l5) 563-7000.
4. I f the amount due from the BUY'3r is not pa id to the
Sheriff, you will remain the owner of the property as if the sale
never happened.
5. You have the right to remain in the property until the
full amount due is paid to the Sheriff and the Sheriff gives a deed
to the buyer. At that time, the buyer may bring legal proceedings
to evict you.
6. You may be entitled to a share of the money which was paid
for your house. A schedule of distribution of the money bid for
your house will be filed by the Sheriff on This
schedule will state who will be receiving that money. The money
will be paid out in accordance with this schedule unless exceptions
(reasons why the proposed distribution is wrong) are filed with the
Sheriff within ten (10) days after _
7. You may also have other rights and defenses, or ways of
getting your home back, if you act immediately after the sale.
YOU SHOULD TAKE THIS PAPER TO YOUR LAWYER AT ONCE. IF YOU ,DO NOT
HAVE A LAWYER OR CANNOT AFFORD ONE, GO TO OR TELEPHONE THE OFFICE
LISTED BELOW TO FIND OUT WHERE YOU CAN GET LEGAL HELP.
CUMBERLAND COUNTY ATORNEY REFERRAL
CUMBERLAND COUNTY BAR ASOCIATION
2 LIBERTY AVENUE
Cumberland County Courthouse
CARLISLE, PA 17013
(717) 249-3166
(800) 990-9108
-,'
".
ALL THAT CERTAIN real estate situate on the South side of East King Street, known as 404.406
,East King Street in the Borough of Shippensburg, Cumberland County, Pennsylvania, bounded and
clescribed as follows:
PREMISES "A"
TRACT NO.1: BEG[NN[NG at a paine on East King Street at line of 101.1 now or formerly of
Smith, known as 402 gast King Screet, Shippensburg, Pennsylvania; thence along East King Street.
North 45 degrees 44 minutes 30 seconds East, 15,62 feet co a paine; thence through the cemer of a
double house known as 404.406 East King Street, South 44 degrees 28 minutes 43 seconds East,
13,77 feet; thence by the same, North 45 degrees 31 minutes 17 seconds East, 2,30 feet to a point;
thence by the same, South 44 degrees 28 minutes 43 seconds East, 14.71 feet to a poim; thence by
Tract No, 2, now or formerly of Lynch, South 45 degrees 43 minutes East, 92,15 feet CO a poine;
thence along a three bay garage, South 45 degrees 21 minutes 39 seconds West, 3,65 feet to a point;
thence through the cencer of said three bay garage and along Tract No, 2. now or formerly of
Lynch, South 44 degrees 57 minutes 39 seconds East, 41. 34 feet to a poine at line of lot now or
formerly of Mooney; thence by the same, South 45 degrees 44 minutes 30 seconds West. 17, II feet
co an iron pin at line of lot now or formerly of Smith, known as 402 East King Street; thence by the
same, North 44 degrees 30 minutes West, 176,33 feet to the place of BEGINN[NG,
BE[NG a porIion of Lot No, 10 of the General Plan of the Borough of Shippensburg and known as
404 East King Slreet. Shippensburg, Pennsylvania,
TAX PARCEL NUMBER: 32-33-[869-078
FREMISES "B"
TRACT NO.2: BEGINNING at a point on East King Street at line of lot now or formerly of
Sollenberger; thence by the same, South 44 degrees 30 minutes East. 257,33 feet to an iron pin;
thence along East Neff Avenue. South 45 degrees 44 minutes 30 seconds West, 10.83 feet to an iron
pin; thence along line of land now or formerly of Mooney, North 44 degrees 30 minutes West,
81.00 feet to an iron pin; thence by the same, South 45 degrees 44 minutes 30 seconds West, 9.89
feet to a point; thence along Tract No.1, known as 404 East King Street. Shippensburg,
Pennsylvania, and through the center of a three bay garage. North 44 degrees 57 minutes 39 seconds
West, 41.34 feet to a point; thence by the same, North 45 degrees 43 minutes West, 92.15 feet to
point; thence by the same and through the center of a double house known as 404-406 East King
Street. North 44 degrees 28 minutes 4~ seconds West. 14.71 feet co a point; thence by the same.
South 45 degrees 31 minutes 17 seconds West, 2.30 feet to a point; thence by the same, North 44
degrees 28 minutes 43 seconds West, 13.77 feet co a point; thence by the same, South"45<degrees 31
minutes 17 seconds West, 0.57 feet to a point; thence by the same, North 44 degrees 28 minutes 43
seconds West, 14,37 feet to a point on East King Street; thence by the same, North 45 degrees 44
minutes 30 seconds East, 22.21 feet to the place of BEGINNING,
BEING a pan ion of Lot No, 10 of the General Plan of the Borough of Shippensburg, known as 406
EasI King Street, Shippensburg. Pennsylvania.
BOTH TRACTS SUBJECT to a righI of passage. both pedestrian and vehicular, in the owners. their
heirs and assigns. of the lot adjacem on the West. over the rear of the above described premises and
extending Southerly to East Neff A venue, having a width of 10 feet, more or less,
TAX PARCEL NUMBER: 32-33-1869-078A
TITLE TO SAID PREMISES" A" AND "B" IS VESTE...ILlli Kevin F, Conley and Catherine A.
Conley, his wife by Deed from Bradley E. Carson and Jacqueline K, Carson, his wife dated
12/30/94 recorded 1/4/95 in Record Book 117 Page 180.
WRIT OF EXECUTION and/or AnACHMENT
COMMONWEALTH OF PENNSYLVANIA)
COUNTY OF CUMBERLAND)
NO. J!.f!:.?:603 ___ CIVllll1l J'E~
CIVil ACTION. LAW
TO THE SHERIFF OF ._.~\!l1~!:!1!n<1.._..... .., ._..... COUNTY:
To satisfy the debt, inlerest and cosls due._C'.,.E..Qa1>l.tI!L.Mo~J:llil9Q Se!:YJS.Elf'l.JJJ9.L___.__,
.~.-----.,--..-.----.._.".-.--_..-.-..-_..---".-,.,---.-u----,.---____._______,____PlAINTIFF(S)
from .___!$evirU~.,_Canl!lY.... Ca ~J:l.!'l! ine ."'-,..C;an~L..J?l~__'.la8 thigt'. Boad, Be thlehem, p~_..__
_....J.lilll1__. _..,__c.__."'....___,.._. ......'__._._'._'.__....______._______..__,_.__.,..____._____
-----.----------..----------------.--__u___.___....DEFENDANT(S)
(1) You are directed to levy upon the property of the delendant(s) and to sell
_....J 04 -406 E. Ki~9.... S t.r:ee t.L1,hipIX:.n8l~uE(!!..l'<:~L_!2_~ '/ ..-'-See _^J:_tached _~8cript i()~_ of Proper!}:)
-.._._------~.._--_._'--_._--~_.._-----_.---_._-
-~~.....---~--__._...____._.n..___~._.._.__~___._.._~__~.__.___~___.
(2) You are also directed to attach the property of the defendant(s) not levied lIpon In the possession of _._
.-----.-.---
----_.---------........_---~-~._._,-------_._---._---._-
-------_.._-~~--
--~-~-~---.~-_._-----_.._-_._-----
-----_._.._~.._._-,---_._~~
GARNISHEE(S) as follows:
and to notlly the garnlghee(s) that: (a) an attachment has been issued; (b) the garnlshee(s) Is/are enjoined from paying any
debt to or for the account of the defendant(s) and from delivering any property of the defendant(s) or otherwise disposing
thereot;
(3)11 property olthe defendant(s) not levied upon an subject 10 attachmontls found in the possession of anyone other
than a named garnishee, you are directed to notify him/her lhat he/she has been added as a garnishee and Is enjoined as llbove
stated,
Amount Due. S 7).320.73 :-:--=-r-
7/18/98 To Sale @S12.05 Per D1em
Interest 1,71'1.2.0_______
Atty's Comm____. %
Atty Paid. 192.00
Plalntnf Paid
LL SO.50
Due Prothy ----....L.PO
Other Costs
Date:
.July 30. 1998
Curtis Il.. Lana
Prothonotary, Civil Division
by: --41'" (;) 'h"N;_,
Dsputy
REQUESTING PARTY:
Name Frar,k Fedennan.-Es.Q......
Address: 'IWo Penn Center Pl~fu.lill!.te 900.
Philadelphia, Pa. 19102
Morney for: _~tiff
Telephone: (215) 56~-7000
Supreme Court 10 No, 12248