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Home My WebLink About00-06883 '~Ii , ~" tilt ~ . GOLDBECK McCAFFERTY BY: Joseph A. Goldbeck, Attorney I.D.#16132 Suite 500 - The Bourse Bldg. 111 S. Independence Mall East Philadelphia, PA 19106 215-627-1322 Attorney for Plaintiff & McKEEVER Jr. , , COUNTRYWIDE HOME LOANS INC. 7105 Corporate Drive PTX B-35 PIano, TX 75024-3632 Plaintiff IN THE COURT OF COMMON PLEAS OF CUMBERLAND COUNTY CIVIL ACTION - LAW vs. :ACTION OF MORTGAGE FORECLOSURE KERMIT W. MOYER AND LISA A. MOYER (Mortgagor(s) and Real Owner(s)) Term No. 00 - /,;,J>J'J C<H{~ 204 North Second Street Wormleysburg, PA 17043 Defendant(s) (NIL ACTION: MORTGAGE fORECLOSURE THIS LAW FIRM IS A DEBT COLLECTOR AND WE ARE ATTEMPTING TO COLLECT A DEBT OWED TO OUR CLIENT. ANY INFORMATION OBTAINED FROM YOU WILL BE USED FOR THE PURPOSE OF COLLECTING THE DEBT. NOTICE You have been sued in court. If you wish to defend against the claims set forth in the following pages, you must take action within twenty (20) days after the Complaint and notice are served, by entering a written ,appearance personally or by attorney and filing in writing with the court your defenses or objections to the claims set forth against you, You are warned that if you' fail to do so the case may proceed without you and a judgment may be entered against you by the Court without further notice for any money claimed in the Complaint or for any other claim or relief requested by the Plaintiff. You may lose money or property or other rights important to you. YOU SHOULD TAKE THIS PAPER TO YOUR LAWYER AT ONCE. IF YOU DO NOT HAVE A LAWYER OR CANNOT AFFORD ONE, GO TO OR TELEPHONE THE OFFICE SET FORTH BELOW TO FIND OUT WHERE YOU CAN GET LEGAL HELP, Cumberland county Bar Association 2 Liberty Avenue, Carlisle, PA (SOO) 990-910'S Legal Services Inc, S Irvine Row, Carlisle, PA 17013 (717) 243~9400 A V ISO LE HAN DEMANDADO A USTED EN LA CORTE. SI DESEA DEFENDERSE CONTRA LAS QUEJAS PERESENTADAS, ES ABSOLUTAMENTE NECESSARIO QUE USTED RESPONDA DENTRO DE 20 DIAS DESPUES DE SER SERVIDO CON ESTA DEMANDA Y AVISO. PARA DEFENDER8E ES NECESSARIa QUE USTED, 0 SU ABOGADO, REGISTRE CON LA CORTE EN FORMA ESCRITA, EL PUNTa DE VISTA DE USTED Y CUALQUIER OBJECCION CONTRA LAS QUEJAS EN ESTA DEMANDA. RECUERDE; SI USTED NO REPONDE A ESTA DEMANDA, SE POEDE PROSEGU1R CON EL PROCESO SIN SU PART1C1PAC10N. ENTONCES, LA COUTE PUEDE, SIN NOTIFICARIO, DECIDIR A FAVOR DEL DEMANDANTE Y REQUERIRA QUE USTED CUMPLA CON TODAS LAS PROV1S10NES DE ESTA DEMANDA, POR RAZON DE ESA DECISION, ES POSSIBLE QUE USTED POEDA PERDER DINERO, PROPIEDAD U OTROS DERECHOS IMPORTANTES, LLEVE ESTA DEMANDA A UN ABOGADO IMMEDIATAMENTE. 81 NO CONOCE A UN ABOGADO, LLAME AL "LAWYER REFERENCE SERVICE" (SERVICIO DE REFERENCIA DE ABOGADOS), 215~23S~6300 . ,;..,:. Cumberland County Bar Association 2 Liberty Avenue, Carlisle, PA ~_ (800) 990-910S Legal Services Inc, S Irvine Row, Carlisle, PA 17013 (717) 243~9400 ", ."...... . -" " -. ~, COMPLAINT IN MORTGAGE FORECLOSURE , - ~ },,~,j ":':::' P',-&~,:"~:--;.,- ':'Y-""":h~~'f1 1. Plaintiff is COUNTRYWIDE HOME LOANS INC., 7105 Corporate Drive, PTX B-35, PIano, TX 75024-3632. 2. The name(s) and address(es) of the Defendant(s) is/are KERMIT W. MOYER, 204 North Second Street, Wormleysburg, PA 17043 and LISA A. MOYER, 204 North Second Street, Wormleysburg, PA 17043, who is/are the mortgagor(s) and real owner(s) of the mortgaged property hereinafter described. 3. On February 26, 1997, mortgagor(s) made, executed and delivered a mortgage upon the premises hereinafter described to COUNTRYWIDE HOME LOANS INC., which mortgage is recorded in the Office of the Recorder of Deeds of Cumberland County in Mortgage Book 1367, Page 300. The mortgage has not been assigned. These documents are matters of public record and are incorporated herein by reference in accordance with pennsylvania Rule of Civil Procedure 1019(g). 4. The premises subject to said mortgage is described as attached. 5. The mortgage is in default because monthly payments of principal and interest upon said mortgage due February 1, 2000, and each month thereafter are due and unpaid, and by the terms of said mortgage, upon default in such payments for a period of one month, the entire principal balance and all interest due thereon are collectible forthwith. 6. The following amounts are due on the mortgage: Principal Balance Interest from 1/ 1/00 through 9/30/00 at 7.500% Per diem interest rate at $14.79 Attorney's Fee at 5% of Principal Balance Late Charges 2/ 1/00- 9/30/00 Monthly late charge amount at $24.92 Costs of suit and Title Search Escrow Balance Deficit Monthly Escrow amount $102.28 $ 71,968.54 4,037.67 3,598.43 199.36 560.00 $ 80,364.00 454.66 $ 80,818.66 7. The Attorney's Fees set forth above are in conformity with the Mortgage documents and pennsylvania law, and, will be collected in the event of a third party purchaser at Sheriff's Sale. If the Mortgage is reinstated prior to the Sale reasonable Attorney's Fees will be charged based on work actually performed. c ~_ ~ 1,-', j , -' _'__r~-J - ~"-^,,.;c,"- .- .';,., "';:'" . ,--" ' B.l1 8. Notice of Intention to Foreclose and a Notice of Homeowners' Emergency Mortgage Assistance has been sent to Defendant(s) by Certified and regular mail, as required by Act 160 of 1998 of the Commonwealth of Pennsylvania, on the date(s) set forth in the true and correct copy of such notice(s) attached hereto as Exhibit "A". The Defendant(s) has/have not had the required face to face meeting within the required time and Plaintiff has no knowledge of any such meeting being requested by the Defendant(s) through the Plaintiff, the Pennsylvania Housing Finance Agency, or any appropriate Consumer Credit Counseling Agency. WHEREFORE, Plaintiff demands judgment in mortgage foreclosure the sum of $80,818.66, together with interest at the rate of $14.79, per day and other expenses incurred by the Plaintiff which are properly chargeable in accordance with the terms of the mortgage, and for the foreclosure and sale of the mortgaged premises. By: GOLDBECK M BY: Joseph A. Goldbec Attorney for plaintiff McKEEVER Jr., Esq. , .' . ~ID IIL..:.tl" ~...a~.(IilJH~,y C21SJ'6277734 -, . ~ -j-- "". , ~ ~':, P.2/2 VERIFICATION I. BRANDON SCIUMBATO as the representative of the Plaintiff corporation within named do hereby verify that I, am authorized to and do make this verification on behalf of the Plaintiff corporation and the facts set forth in the foregoing Complaint are true and correct to the best of my knowledge, information and belief. I understand that false statements therein are made subject to the penalties of 18 Pa. C.S. 4904 relating to Date: It) ~0 ~ if() unsworn falsification to authorities. 8RANDONSCIUMBATO, VICE PRESIDENT ... ;; ~=,' - .~~ ~t , .,'J- "- .< ~" . '."".,~"-" ~~ - ~- ~: , "JIlt. ., _~. 4_ ___.__-'~'_"_"'___'''_ 101-0T-WElmllllY PIl8d-.''l'.ort Forrn-l\d 19ot-Doubla Shl!lat Henry tfltl'. Inc., lndl..n;ll, h. ~bi~ ;mttb t ':~}~\~:~ ~:~i~~;, MADE THE 12th ...y of February of our Lord. one t1wmo;n.. ,nm "u1l<lre.. ninety th~ee (1993) in the year BETWEEN "OlIN H. FIRTH AND XlIERllSA l'J.. FIRTII, his vifa. hereinafter referred to as parties of the first part, Grantor s , and I<I!Rl'II:f 11'/,,; oo.YER AND LIS/\ A. MOYER, his lIife, hereinaffter referred to as parties of the second part, Grv.1ltG6 s : WITNESSETH, Ikllt in C01!$i4eT"liqn of 'SE:VENTi?:~ THOUSAIiID FIVE HUNOImD AND XX/loo---- ---- (~7.2,500.00) Doll4rs, I" luLnd Vttid, I". ",'ooiVI w"...eof is her.by ao/cnQwl<<lq.d, t". .aid grantors de h",by gront tt1l<l oonllfnl to Ihe ."id grq,,,tee ;,. ,~L ~1~E TWO C[RTAIN,lots of ground situate in the,Bo~ugh of Wormleysburg, formerly East Pennsooro 'l'oIInship, COunty of CurrdJerland and CO\llmOnwealth of Pennsylvania, numbere<l 76 end 77 in a Pian of Lots iaid out by V. HUnunel Beryhans and known as "Edgalietei:" Plan No.2" SS amended to show Walnut: St:teet projected to centel;" of :rrack of "N.C.R.R. CO.", as Plan being recorded in CUmberland COUnty Deed Book D. Volume.6, Page 599, said Lots ooing more particularly bounde<l and described as follows, to wit: !lI!x;:INNIllG ;>.t a poi...t on the western side of Second Street, 50 feet above the COrner of Walnut Street: thence up along said Second Street, :;0 feet to the line of Lot No. 731 thence weBtwardly along line of Lot No. 78, 150 feet to i1ill Alley; thence doIm ;>.long 6;>.id lilley, 50 feet to the tine of Lot No. 75; thence along line of Baid Lot eastvardly 150 feet to the place of BllGINNING., HAVING '~ ERECTED a one etory brick fr"",e d"elling nUlllbered 204 2nd Street. BEING THE SAl'IE PREMISr;.s which David M. cuthbertson and Carol II. Cuthbertson, hie vife by Deed dated July 26. 1976 and recorded July 29. 1976 in Cumberland County Deed Book S, Volume 26, Page 290, granted and conveyed unto John 1I. J;'irth and Theresa M. Firth, his wife. UNDER /\NO SueJE(lT to conditions, restrictions and rights of public record. WM-J'A~c. $o1\tlO' Disl Cumbo Co.. ~3-e.. ;J.:'J(d'eol-ElnlJjf.'Tfansfer-~r.~:l ~ Do'Z; ,?//?- ~lmt. :1 tJ 2. ,)v t=lobtrt P. Ziegler Cumbo CD, Di.., Col. A\l1- 8orough ot W~rn--;ey,/ Iw?, Cumb, Co..."" V' iTool eo.o,. Tr_rorllo< D8,.L"'?';;;>'?JAmt. :J~Z..!,,)) Robert P. ZIegler Cumbo Co, Dial Col. Aoi. --, . ~ " <--- ,~~~, ..:..i..;:,: -:... ' i'.r..; Send Correspondence to: P.O. Box 260599 PIano, TX 75026-0599 Send Payments to: P.O. Box 660694 DaDas, TX 75266-0694 July 28, 2000 Certified Mail No. Retum Receipt Requested Regular Mail Usa A Moyer 204 North Second Street Wonnleysburg, PA 17043-0000 <t I- - m -- :r:: >< w Countrywide Loan # 8361396 Properly Address: 204 Nor1h Second Street Wonnleysburg, PA 17043-0000 FHANA Case#: 101060512864 NOTICE OF INTENT TO FORECLOSE YOUR HOME LOAN IS IN DEFAULT FOR THE REASONS SET FORTH IN THIS NOTICE. YOU MUST TAKE ACTION TO SAVE YOUR HOME FROM FORECLOSURE. CountJywide Home Loans, Inc. (hereinafter "Countrywide") services your home loan. Your home -loan is in serious default because you have not made your required payments. The total amount now required to reinstate your loan a~; of the date of this letter is as follows: Monthlv Payments: $1,240,00 $2,492,00 $49.60 $99,68 $46,00 TOTAL DUE: $3,927,28 You may cure this defaultwtthln THIRTY..f1VE (36) DAYS of the date of this letter, by paying to us the above amount of $3,927.28, plus any additional monthly payments; late charges, fees and other applicable charges which may 11111 due during this period. Such payment must be in the form of certified check., cashier's check. or money order, and made payable to Countrywide at P.O. Box 10221, Van Nuys, CA 91410-0221. If your check or other payment is retumed to us for insufficient funds or for any other reason, you will not have cured your default, No extension of time to cure:_:will be granted due to a retumed payment. Late Charaes: 0210112000 - 02/3112000 04/0112000 - 07/3112000 0210112000 - 03/3112000 0410112000 - 0713112000 Uncollected Costs: @ @ @ @ $620,00 $623.00 $24,80 $24.92 other Charaes: If you do not cure this default wilhin THIR'TY-FiVE (35) DAYS, we will accelerate the paymerns due on your home loan, This means whatever is owing on the original amount borrowed will be considered due immediately and you may It~se the chance ,~o payoff your home loan in mo~1y instanments. If the full payment of the amount of default is not madE! within THIRTY-FIVE (36) DAYS, we also intend to immediately start a lawsuit to foreclose on your mortgaged property. YOU MAY BE ELIGIBLE FOR FINANCIAL ASSISTANCE WHICH CAN SAVE YOUR HOME FROM FORECLCISURE AND HELP YOU MAKE FUtURE MORTI3AGE PAYMENTS. The Commonwealth of Pennsylvania's ,Homeowner's Emergency Mortgage Assistance program may be nble to help you. Read the following riotice to 'find out how the program works. La notificacion en adjunto es de suma lmportancia, pues atecta su derecho a co~nuar viViendo en su casa. Si no comprende el contenido de esta r-otificacion obtenga una traduccion inmediatamente lIatnando 11 esta agencia (Pennsylvania Housing, Finan~e Agency) sin cargos al numero mencionad_o arriba. Usted pUE!llte ser elegible para un prestamo del progran1a !Iamado "Homeowner's Emergency Mortgage Assistance Prognlm" el cual puede salvar su casa de Ia perdid~ del derecho a redimir su hipoteca. You may be eligible for financial assistance that will prevent foreclosure on your mortgage if you comply with the provisions of the Homeowners' Emergency Mortgage Assistance Act of 1:983 (the "Actj. You may be eligible for emergency temporary assistance if your ~efault has been caused by circumstances beyond your control, you have a reasonable prospect of resuming your mortgage payments, and if you meet other efigibllity requirements establlslhed by the Pennsylvania Housing Finance Agency. Please read all of this Notice. It contains an explanation of your rights. 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 a representative of this lender, or Please write your loan number on all checks and correspondence. BREACHPA 8361396-8 Lisa AMoy& 204 NorthSec::ondStreel $3,927,28 AS OF 7/28/2000 P,Q. Box 660694 Dallas, TX 75266-0694 lI.u.I.I.I...I.I.II."II..lluull..I.I...)..II.I...I..11I1.11 836139680003927280392728 - ~-~ ~ ~..I"",-~ .. 1-, , ,,;,'- ~ ~;i HUD-Approved Counseling Agencies - Pennsylvania with a designated consumer credit counseling agency. The purpose of this meeting is to attempt to wori( out a repayment plan, or to otherwise settle your delinquency. This meeting must occur in tile next thirty (30) days. If you attend a face--to-face meeting with this lender, or with a consumer credit counsefing agency identified In thiEI notice, no further proceeding in mortgage foreclosure may take place for thirty (30) days after the date of this meeting. The name, address and telephone number of our representative is: COUNTRYWIDE, 6400 Legacy Drive, Piano" Texas 72567, Telephone Number: 1-800--669-4575, Extension 4334.. The names and addresses of, designated consumer credit counseling agencies are shown on the attached sheiN. It is only necessary to schedule one face-to.-face meeting. You should advise Countrywide of your intentions immediatl~ly. If you have tried and are unable to resolve this problem at or after your face-to-face meeting, you have the riglrt 1'0 apply for financial assistance from the Homeowners' Emergency Mortgage Assistance Fund. In order to do this, you must ffll out, sign and file a completed Homeowners' Emergency Assistance Application with one of the designat:ed consumer credit counseling agencies listed on the attachment An application for assistance may onty be obtalned from a consumer credit c::ounseling agency. The consumer credit counseling agency will assist you in filrmg out your application and will submit your completed application to the Pennsylvania Housing Finance Agency. Your application must be filed or post,marked within thirty (30) days of your face-to~face meeting. Available funds for emergency mortgage assistance are very limited. They will be disbursed by the Agency under the eligibility criteria established by the Act It is extremely important that you file your application prompUy. If you do not do so, or if you do not follow the other time periods set forth in this letter, foreclosure may proceed against your home immediately. It is extremely important that your application is accurate and complete in every respect. The Pennsylvania Housing Finance Agency has sixly (60) days to make a decision after it receives your application. During that additional time, no foreclosure proceedings will be pursued against you if you have met the time requin~ments set forth above, You wiU be notified directly by that Agency of its decision on your application. The Pennsylvania Housing Finance Agency is located at 2101 North Front Street, Post Office Box 8029, Hanisburg, Pennsylvania 17105. Telephone No. 1-717-780-3800 or 1-800-342-2397 (toll free number). Persons with impaired hearing can caU 1-800-342-2397, If the mortgage is foreclosed, your mortgaged property will be sold by the Sheriff to payoff the mortgage debt. If you cure the default before we begin legal proceedings against you, you Will still have to pay the reasonable attomevls fees actually incurred, up to $50.00. However, if legal proceedings are started against you, you will have to pay the reasonable attorney's fees even if 'they are over $50.00. Any attorney's fees will be added to whatever you owe us, which mlJY also include our reasonable costs. If you cure this default within the thirty..five day period, you will not be required to ,+ay the attorney's fees, YOU HAVE THE RIGHT TO REINSTATE AFTER ACCELERATION AND THE RIGHT TO ASSlERT IN THE FORECLOSURE PROCEEDING THE NON-EXISTENCE OF A DEFAULT OR ANY OTHER DEFENSlE YOU MAY HAVE TO ACCELERATION AND FORECLOSURE. -,' ~" L =1 10<' ~~ ~ # ~ Send Correspondence to: P,O. Box 260599 PfanrJ, TX 75026-0599 Send Payments to: P.O. Box 680694 DaRes. TX 75268-0694 July 28, 2000 Certified MaD No, Return Receipt Requested Regular Mail Kermn W Moyer 204 North Second street Worrnleysburg, PA 17043-0000 Countrywide Loan # 8361396 Property Address: 204 North Second Street Wormleysburg, PA 17043-0000 FHANA Case #: 101060512864 NOTICE OF INTENT TO FORECLOSE YOUR HOME LOAN IS IN DEFAULT FOR THE REASONS SET FORTH IN THIS NOTICE. YOU MUST TAKE ACTION TO SAVE YOUR HOME FROM FORECLOSURE. Countrywide Home Loans,lnc. (hereinafter "Countrywide") services your home loan. Your home lo~n is in se,rious d~fault be;cause you have not made your required payments. The total amount now required to reinstate your loan as of the date of this letter is as follows: Monthlv Pavrnents: 02/0112000 - 03/3112000 0410112000 - 07/3112000 0210112000 - 03/3112000 04/0112000 - 07/3112000 Uncollected Costs: @ @ @ @ $620,00 $623,00 $24.80 $24,92 $1,240,00 $2,492,00 $49,60 $99,68 $48,00 TOTAL DUE: $3,927.28 You may cure this defaultwilhin THIRTY-FIVE (35) DAYS of the date of this letter, by paying to us the above am()unt of $3;927.28, plus any add"ltional monthly payments, late charges, fees and other applicable, charges which may tolll due during this period. Such payment must be in the form of certified check, cashier's check or mo~ey order, and made payable to Countrywide at P.O. Box 10221, Van Nuys, CA 91410-0221. If your check or other payment is retumel~ to us for insufficient funds or for any other reason, you will not have cured your default. No extension of time to cure.wlll be granted due to a returned payment. Late Charaes: other Charaes: If you do not cure this default within THIRTY-FIVE (35) DAYS, we wiD accelerate the payments due on your hom4! loan. This means whatever is owing on the original amount borrowed will be considered due immediately and you may lose the chanceJo payoff your home loan in monthly installments. If the full payment of the amount of default is not made wfthin THIRrf~FIVE (35) DAYS, we also intend to immediately start a lawsuit to foreclose on your mortgaged property. YOU MAY BE ELIGIBLE FOR FINANCIAL ASSISTANCE WHICH CAN SAVE YOUR HOME FROM FORECLOSURE AND HELP YOU MAKE FUTURE MORTGAGE PAYMENTS. The Commonwealth of Pennsylvania's Homeowner's Emergency Mortgage Assistance program may be able to help you. Read the following notice to find out how the program works. La notificacion en adjunto es de suma importancia, pues afec:ta su derec:ho a continuar viviendo en su ca!~a. Si no c:omprende el contenido de esta notificacion obtenga una traduccion inmediatainel$: lIa;nlilndo Oil esta agencia (Pennsylvania Housing Finan~ Agency) sin cargos al Rumero mencionado arri~. Usted. puecle ser elegible para un prestamo del progra~, lIamado "Hom~er's Emergency Mortgage Assistance Ptoglllm" el cual puede salvar su casa de 'Ia perdida: del derec:ho a redimir su hipotecaL You may be eligible for financial assistance that will prevent foreclosure on your mortgage if you comply with the provisions of the Homeowners' Emergen~ Mortgage Assistance Act of 1983 (the "Actj. You may be ellgil~le for emergency temporary assistance if your ~efault has been c~lJsed by circumstances beyond your cd~l. you have a reasonable prospect of resuming your mortgage payments, and if you meet other engibility requirements ~bllshed by the Pennsylvania Housing Finance Agency. Please read all of this Notice. It contains an explanation ofyour:rights. Under the Act, you are entitled to a temporary stay of foreclosure on your mortgage for thirty (30) days fro,m the c1ate of this Notice, During that time you must arrange and attend a "face-to-face" meeting with a representative of this lender, or Please write your loan number on all checks and correspondence, BREACHPA 8361396-8 KermitW Moyer 204 North SElCQnd Slreet $3,927,28 AS OF 7/28/2000 P,O, Box 660694 Dallas, TX 75266-0694 111111.11111I1.1.11111111111111111111.111111111.11111111111111 836139680003927280392728 ,"""~ -. . , ~I .. " "lJ!l; HUD-Approved Counseling Agencies - Pennsylvania with a designated consumer credit counseling agency. The purpose of this meeting is to attempt to work out a repayment plan, or to otherwise setue your delinquency. This meeting must occur in the next thirty (30) days" If you attend a face-to-face meeting with this lender, or with a consumer credit counsefing agency identified in this notice, no further proceeding in mortgage foreclosure may take place for thirty (30) days after the date of this meeting. The name, address and telephone number of our representative is: COUNTRYWIDE, 6400 Legacy Drive, PlanClI, Texas 72567, Telephone Number. 14100..&69-4575, Extension 4334. The names and addresses of designated consumer credit counseling agencies are shown on the attached shEtEtt. It is only necessary to schedule one face-to-face meeting. You should advise Countrywide of your intentions immediately. If you have tried and are unable to resolve this problem at or after your face-to-face meeting, you have the right to apply for financial assistance from the Homeowners' Emergency Mortgage Assistance Fund. In order to do this, you must fill out, sign and file a completed Homeowners' Emergency Assistance Application with one of the deslgP<:- '.'!!d consumer credit counseling agencies listed on the attachment. An application for assistance may only be obtained from a consumer credit counseling agency. The consumer credit counseling agency will assist you in filling out your application and will submit your completed application to the Pennsylvania Housing Finance Agency, Your application must be filed or postmarked within thirty (30) days of your face-to-face meeting. Available funds for emergency mortgage assistance are very limited. They will be disbursed by the ,Agency under the e1igibility criteria established by the Act It is extremely important that you file your application promptly. If you do not do so, or if you do not follow t,he o'Uler time periods set forth in this letter, foreclosure may proceed against your home immediately. It is extremely important that your application Is accurate and complete in every respect. The Pennsylvania Housing Finance Agency has sixty (60) days to make a decision after it receives your application. During that additional time, no foreclosure: proceedings will be pursued against you if you have tnet the time requil'ements set forth above. You win be notified directly by that Agency of its decision on your application. The Pennsylvania Housing Finance Agency is located at 2101 North Front street, Post Office Box 8029, Hal:risburg, Pennsylvania 17105, Telephone No. 1-717-780-3800 or HlO0-342-2397 (Ioillree number), Pe"",ns with impaired hearing can call 1-800-342-2397, If the mortgage is foreclosed, your mortgaged property will be sold by the Sheriff to pay Off the mortgage debt. If you cure the default before we begin legal proceedings against you, you will still have to pay the reasonable attome'y's fees actually incurred, l:IP to $50.00. However,:if legal proceedings are started against you, you will have to pay the reasonable attorney's fees even if they are over $50.00: Any attorney's fees will be added to whatever you owe us, which may also include our reasonable costs. If you cure, this defa':llt within the thirty-five day period, you will not be required w;,pay the altomey's fees, YOU HAVE THE RIGHT TO REINSTATE AFTER ACCELERATION AND THE RIGHT TO ASSERT IN THE FORECLOSURE PROCEEDING THE NON-EXISTENCE OF A DEFAULT OR ANY OTHER DEFENSE YOU MAY HAVE TO ACCELERATION AND FORECLOSURE. ~J.~~~",,~~~Mi1.m.~~j!~_~~OSIl>,'~'%!i,;J,J.- -irA~.' -p ~ ,__~,~"'~"",",",I_''''', ,.~,~,,,,,.,_<_,_,,,,,_,_A;,"," "'__, C,'__"""' '," _"_,,,,1,, ,',,".."'-'''''",'A-_' -'~ <, ....... e- N ~ t ig ~CJ16 ~ 8 ~ ) ,0 ~ ~~ CY I~ 1- J ~ ~ ,,,,-- - iiiMiJL liHulW"'" ~~ilIlIll'llil C) c: v~ nlp- ;~.:: "f i ---",;::::; 0\'. ~~ Pc ;:.:: :< iuW!lrJillillil!:Y 'I ! " <:::> o c.::) ':, .-; , m ='? ~" () -1"1 r:- eo ;':1- ~ '::)("~ o,-'G --I :> ::0 -< 8 . ,".1.. HI," '~-'" ""'lIIlij<:: SHERIFF'S RETURN - NOT FOUND CASE NO: 2000-06883 P COMMONWEALTH OF PENNSYLVANIA COUNTY OF CUMBERLAND COUNTRYWIDE HOME LOANS INC VS MOYER KERMIT W ET AL R. Thomas Kline ,Sheriff or Deputy Sheriff, who being duly sworn according to law, says, that he made a diligent search and inquiry for the within named defendant, DEFENDANT MOYER LISA A but was unable to locate Her in his bailiwick. He therefore returns the COMPLAINT - MORT FORE , NOT FOUND , as to the within named DEFENDANT , MOYER LISA A DEFT. DOES NOT RESIDE AT ABOVE ADDRESS, NOR HER HUSBAND'S NEW ADDRESS. POST OFC HAS NO INFORMATION. Sheriff's Costs: Docketing Service Not Found Return Surcharge 6.00 .00 5.00 10.00 .00 21.00 '~~ R. nomas Kline Sheriff of Cumberland County 00/00/0000 Sworn and subscribed to before me this 31A.-!- day of {fleJ:;;:L dlr7rO A. D . ~C'. ~ ~ Pr onotary / ~, ~ ~~I~ .~ - ,~ I~~_o _~ i -r-~ ~'. ,~ ~ '"":;0,. SHERIFF'S RETURN - REGULAR CASE NO: 2000-06883 P COMMONWEALTH OF PENNSYLVANIA: COUNTY OF CUMBERLAND COUNTRYWIDE HOME LOANS INC VB MOYER KERMIT W ET AL DAVID MCKINNEY , Sheriff or Deputy Sheriff of Cumberland County,Pennsylvania, who being duly sworn according to law, says, the within COMPLAINT - MORT FORE was served upon MOYER KERMIT W the DEFENDANT , at 2010:00 HOURS, on the 19th day of October 2000 at 22 ASHBURG DRIVE MECHANICSBURG, PA 17055 by handing to KERMITT W. MOYER a true and attested copy of COMPLAINT - MORT FORE together with NOTICE and at the same time directing His attention to the contents thereof. Additional Comments DEFT. MOVED FROM WORMLEYSBURG TO NEW ADDRESS STATED ABOVE. Sheriff's Costs: Docketing Service Affidavit Surcharge So Answers: 18.00 4.34 .00 10.00 .00 32.34 ~~~ R. Thomas Kline 10/27/2000 GOLDBECK MCCAFFERTY & MCKEEVER me this 31.-a--r- day of By: ~ ~y~ Depu~snerlff ~ Sworn and Subscribed to before (Jrr.:P... ~ A.D. ~(2 ~~ rothonotary , ", ' L I ~ _.~~ 'iiJ' _;0 . t GOLDBECK McCAFFERTY BY: Joseph A. Goldbeck, Attorney I.D.#16132 Suite 500 - The Bourse Bldg. 111 S. Independence Mall East Philadelphia, PA 19106 215-627-1322 Attorney for Plaintiff & McKEEVER Jr. TIFY THAT THIS \ \-\EI'IE~~ ;~~ CORRECT COpy . ISA TR . ., ,. Gl"AL FilED OF THE 01'11 1~ COUNTRYWIDE HOME LOANS INC. 7105 Corporate Drive PTX B-35 PIano, TX 75024-3632 Plaintiff IN THE COURT OF COMMON PLEAS OF CUMBERLAND COUNTY CIVIL ACTION - LAW vs. :ACTION OF MORTGAGE FORECLOSURE KERMIT W. MOYER AND LISA A. MOYER (Mortgagor(s) and Real Owner(s)) Term No. DO - ",1>18 CiuiCT~ 204 North Second Street Wormleysburg, PA 17043 Defendant(s) (\\nL AGTION: MORTGAGE. FORECLOSURE THIS LAW FIRM IS A DEBT COLLECTOR AND WE ARE ATTEMPTING TO COLLECT A DEBT OWED TO OUR CLIENT. ANY INFORMATION OBTAINED FROM YOU WILL BE USED FOR THE PURPOSE OF COLLECTING THE DEBT. NOTICE You have been sued in court. If you wish to defend against the claims set forth in the following pages, you must take action within twenty (20) days after the Complaint and notice are served, by entering a written appearance personally or by attorney and filing in writing with the court your defenses or objections to the claims set forth against you. You are warned that if you fail to do so the case may proceed without you and a judgment may be entered against you by the Court without further notice for any money claimed in the Complaint or for any other claim or relief requested by the Plaintiff. You may lose money or property or other rights important to you. YOU SHOULD TAKE THIS PAPER TO YOUR LAWYER AT ONCE. IF YOU DO NOT HAVE A LAWYER OR CANNOT AFFORD ONE, GO TO OR TELEPHONE THE OFFICE SET FORTH BELOW TO FIND OUT WHERE YOU CAN GET LEGAL HELP. Cumberland County Bar Association 2 Liberty Avenue, Carlisle, PA {BOQ) 990-910B Legal Services Inc. S Irvine Row, carlisle, PA 17013 (717) 243-9400 AVISO LE RAN DEMANDADO A USTED EN LA CORTE. SI DESEA DEFENDERSE CONTRA LAS QUEJAS PERESENTADAS, ES ABSOLUTAMENTE NE:,CESSARIO QUE USTED RESPONDA DENTRO DE 20 DIAS DESPUES DE SER SERVIDO CON ESTA DEMANDA Y AVISO. PARA DEFEND~RSE .ts NECESSARIO QUE USTED, 0 SU ABOGADO, REGISTRE CON LA CORTE EN FORMA ESCRITA, EL PUNTO DE VISTA DE USTED Y CUALQUIER OBJECCION CONTRA LAS QUEJAS EN ESTA DEMANDA, RECUERDE: SI USTED NO REPONDE A ESTA DEMANDA, SE PUEDE PROSEGUIR CON EL PROCESO SIN SU PARTICIPACION. ENTONCES, LA COU'l'E PUBDE, SIN NOTIFlCARIO, -DECIDIR A FAVOR DEL DEMANDANTE Y REQUERIRA QUE USTEn CUMPLA CON TODAS LAS PROVISIONES DE 8Sm DEMANDA_ POR RAZON DE ESA DECISION, ES POSSIBLE QUE USTED PUEnA PERDER DlNERO, PROPIEDAD U OTROS DERECHOS IMPORTANTES_ LLEVE ESTA DEMANDA A UN ABOGADO IMMEDIATAMENTE. Cumberland County Bar Association 2 Liberty Avenue, Carlisle, PA (SOO) 990-9108 "LAWYER REFERENCE SERVICE" (SERVICIO DE REFERENCIA DE ABOGADOS), TRUE COpy FROM RECORD In Testimony whtlr~, I here unto sat I'I1Ylland aftd tile seal of said, Coo, rt at Carllsle~ '-. ThIA/Jf,,/t.d~Y_ ~(~ ' ')fd-- Prof' ry S I NO CONDCE A UN ABOGADO, LLAME AL 215-23B-6300_ Legal Services Inc_ 8 Irvine Row, Carlisle, PA 17013 (717) 243-9400 ,'~' ~ ;,- , ~ I , COMPLAINT IN MORTGAGE FORECLOSURE ,-' ="' ' ~ " ' " """':j; 1. Plaintiff is COUNTRYWIDE HOME LOANS INC., 7105 Corporate Drive, PTX B-35, PIano, TX 75024-3632. 2. The name(s) and address(es) of the Defendant(s) is/are KERMIT W. MOYER, 204 North Second Street, Wormleysburg, PA 17043 and LISA A. MOYER, 204 North Second Street, Wormleysburg, PA 17043, who is/are the mortgagor (s) and real owner (s) of the mortgaged property hereinafter described. 3. On February 26, 1997, mortgagor(s) made, executed and delivered a mortgage upon the premises hereinafter described to COUNTRYWIDE HOME LOANS INC., which mortgage is recorded in the Office of the Recorder of Deeds of Cumberland County in Mortgage Book 1367, Page 300. The mortgage has not been assigned. These documents are matters of public record and are incorporated herein by reference in accordance with Pennsylvania Rule of Civil Procedure 1019(g). 4. The premises subject to said mortgage is described as attached. 5. The mortgage is in default because monthly payments of principal and interest upon said mortgage due February 1, 2000, and each month thereafter are due and unpaid, and by the terms of said mortgage, upon default in such payments for a period of one month, the entire principal balance and all interest due thereon are collectible forthwith. 6. The following amounts are due on the mortgage: Principal Balance Interest from 1/ 1/00 through 9/30/00 at 7.500% Per diem interest rate at $14.79 Attorney's Fee at 5% of Principal Balance Late Charges 2/ 1/00- 9/30/00 Monthly late charge amount at $24.92 Costs of suit and Title Search ,Escrow Balance Deficit Monthly Escrow amount $102.28 $ 71,968.54 4,037.67 3,598.43 199.36 560.00 $ 80,364.00 454.66 $ 80,818.66 7. The Attorney's Fees set forth above are in conformity with the Mortgage documents and Pennsylvania law, and, will be collected in the event of a third party purchaser at Sheriff's Sale. If the Mortgage is reinstated prior to the Sale reasonable Attorney's Fees will be charged based on work actually performed. .~ . .-,,~..,;.., -,,- - v'''-''.'- _ '-,"," .;-:>. ".~ _ >" ",. . 'ifilf~ , 8. Notice of Intention to Foreclose and a Notice of Hgmeowners' Emergency .Mortgage As.sisti'l,nce has been sent to Defendant(s) by Certified and regular mail, as required by Act 160 of 1998 of the Commonwealth of Pennsylvania, on the date{s) set forth in the true and correct copy of such notice{s) attached hereto as Exhibit "A". The Defendant{s) has/have not had the required face to face meeting within the required time and Plaintiff has no knowledge of any such meeting being requested by the Defendant{s) through the Plaintiff, the Pennsylvania Housing Finance Agency, or any appropriate Consumer Credit Counseling Agency. WHEREFORE, Plaintiff demands judgment in mortgage foreclosure the sum of $80,818.66, together with interest at the rate of $14.79, per day and other expenses incurred by the Plaintiff which are properly chargeable in accordance with the terms of the mortgage, and for the foreclosure and sale of the mortgaged premises. By: GOLDBECK M BY: Joseph A. Goldbec Attorney for Plaintiff. McKEEVER Jr ., Esq. , , ~ -'.. '.L _1__ ~=- _I '~~,I~ -.. "--11 I ....1...,1 \c:.J...})oc:;(rr.j4 (-",,-- ",'~, .' ~'",", " ", P.Z/2 , VERIFICATION !, BRANDON sefUMBATO as the representative of the Plaintiff corporation within named do hereby verify that I am authorized to and do make this verification on behalf of the Plaintiff corporation and the facts set forth in the foregoing Complaint are true and correct to the best of my knowledge, information and belief. I understand that false statements therein are made subject to the penalties of 18 Pa. C.S. 4904 relating to Date: . . \- It> ~0 - t/V unsworn falsification to authorities. BRANDON SCIUMBA TO, VICE PRESIDENT " - - ,J. " ~ ">> J:01-0T_Wlillnrtty ~-.<J1.ort Forrn--I\ct l~ubl.. sh"t Henry trail. Inc., rradl8mil. h. trbtJ JJttb cuii\:f:\:;~:,ii:\, , '93 FEB 17 Pf'l 3 27 MA.DE THE 12th WJ.1I of Fobruali}' of our Lord, on. tl,oUBo;nrJ, ,tine /r.undr.d. ninety throe (1993) in the. year BETWEEN JOlIN H. FIRTH AND THEtU;SA !o\. FIRTlh his wife. he~eioafter referred to as parties of the firet pa~t, (rt-c>ntO?'s, o.nd ~l'~ W/ tlOYER AND LISA A. MOYER, his Wife, hereioaiiter" ref"cred to as parties of the second part, '. " Grcz.nl(I6 s: WiTNESSETH, t~,<t in oon.ictero.!iqn 01 'SEVENTt"WO 'l'llOUSAND FIVE BUNDllED /\NO XX/lOO----- ($n,500.00) Do!lttr$, in /ulnd p"m. th.o Tlltllipt w/r.ereol io /r.....b1/ "ok1wwle<lU..t, t/r.. .aid, urlZn~ d.() /r.er.~v grant and oo;wilv to t/r.. .airL .1'O.nl.e S. , lILt. 'l:HOSE 'lWO C[R'l:/UN lots of ground situate in the, Bo:cough of Worml"ysburg. formed'! East Pennaoot:Q 'J:o>mBhip. County of CUmboriand and COI\<llOtIwealth of P"nnsylvania, ntllllbered 76 and 77 in a Pian of Lata iaid out by V, II-......u a..rghane and kno!Jl). as "Edgewater Plan No.2" 119 amended to show Walnui: Sb;eet projected to center of :!'rack of "N.C.n.R. Co.", a9 Plan being recorded in CUmberland COunty Deed Book 0, volume, 6, Page 599, said Lote being JOOre particularly bounded and descdbed as follows, to wi t: IlS;INNINC at a poi..,t on the western aid. of Second St&eet, 50 feet above the cotner of Walnut Street; thence up along 6aid Second Street, 50 feet to the line of Lot 110. 73; thence westwardly along Un", of Lot No. 75, 150 feet to aill Alley: thence down e-long said Alley, So feet to the line ot Lot No. 75; thence along line of said Lot eastwar<ily 150 feet to the plaoe of m;x;!mIl'lG., HAVING 'THI::Rlrol'I ERIlCTED a one etol:}' brick fraroe d...elling numbered 204 2nd Street. BEING till' SAI'IE PRIlMISES which David M. CUthbertson and Carol A. Cuthbertson, his wife by Deed dated July 26. 1976 and recorded July 29, 1976 in 'Cumberland Co\lnty Deed Book S, Volume 26, Page 290, granted and conveyed unto John 1I. li'irth and Theresa M. Pirth, his \life. . UNDER AND SUBJEe'l' t.o conditions, restrictions and t"ights of public recor-dL .> vvar-,/'AfYG. Scfrooi mSl Cumbo Co.. ~28. ~% ReDi EDlDjf "1~m3.fef T.':f. t.-,,//?-iJ 'j~2,5tJ Dele ~' 'Amt. . hobtn P, Ziegler Cumi;, C,o, Disc Col. Agl. So,ough .tW~,-......./""rJ'v? Cumb. Co.. PI\. 1)f. nul b\Il'. Tr,""for lU: DB'B"--2'/'?'7JArnL 3'2,,,9 lIobert P. ZJevle, Comb. Co. DIsL CoI" Aoi ..,,'" - ~~ <C I- - m ...... :t >< W 00'_ I, "~ ~ .""'> '''"' Send Correspondence' to: P.O. Box 260599 Plana, 1)( 75026-0599 Send Payments to: P,O. Box 680694 Dalas, rx 75266-0694 July 28, 2000 Certified Man No; Return Receipt Requested Regular Mail Lisa A Moyer 204 North Second Street Wormleysburg, PA 17043-ll000 Countrywide Loen # 8361396 Property Address: 204 Nor1h second street Wormleysburg, PA 17043-0000 FHANA C...#: 101060512864 NOTICE OF INTENT TO FORECLOSE YOUR HOME LOAN IS IN DEFAULT FOR THE REASONS SET FORTH IN THIS NOTICE. YOU MUST TAKE ACTION TO SAVE YOUR HOME FROM FORECLOSURE. Countrywide Home loans, Inc. (hereinafter "Country\Yidej services your home loan, Your home Joan is'in serious dlefault because you have not made your required payments. The total amount now required to reinstate your loan as elf the date of this letter is as follows: Monthlv Pavments: Other Charaes: 0210112000 - 0313112000 0410112000 - 0713112000 0210112000 - 0313112000 04/0112000 - 07/3112000 Uncollected Costs: @ @ @ @ $620,00 $623,00 $24.80 $24,92 $1,240,00 $2,492.00 $49.60 $99,68 $46,00 TOTAL DUE: $3,927,28 You may cure this defaultwilhin THIRTY-FIVE (35) DAYS of the date of this letter, by paying to us the above amount of $3,927.28, plus any additional monthly payments. late charges, fees and other applicable charges which may fafil due during this period. Such payment must be, in the form of certified check, cashier's check or money order, and made payable to Countrywide at P.O. Box 10221, Van Nuys, CA 91410-0221. If your check or other payment is returned to us for insufficient funds or for any other reason, you will not have cured your default No extension of time to cure;,; will be granted due to a returned payment. late Charaes: Kyou do not cure 1his default within lHIRTY-FlVE (35) DAYS, we will accelerate1he paymenls due on your home loan, This means whatever is owing on the anginal amount borrowed will be considered due immediately and you may I()SlElthe chan~,~ payoff your home loan in monthly installments. If the full payment of the amount of default is not made within THIRTY-FIVE (35) DAYS, we also Intend to immecr..tely start alawsu~ to foreclose on your mortgaged property. YOU MAY BE EUGIBLE FOR F1NANCIAL,ASSlSTANCE WHICH CAN SAVE YOUR HOME FROM FORECLOSiURE AND HELP YOU MAKE FUTURE MORTGAGE PAYMENTS. The Commonwealth of Pennsylvania's Horneowne"'s Emergency Mortgage Assistance program may be ablle to help you. Read the following notice to'find out hOw the program works. La notificacion en adjunto es de suma imporiancia. pues afecta su derecho a continuar vivie-odo en su casaL Si no comprende el contenido de esta notificacion obtenga una traduccion inmediatamente llamando a ,esta agencia (PeMsyfvania Housing Finance :Agency) sin cargos al numero mencionado arriba. Usted puede ser elegible para un prestamo del programa:llamado "Homeowner"s Emergency Mortgage Assistance Program" el cua' puede salvar su casa de_ 'a perdida del derecho a redimir su hipoteca. You may be eligible for financial assistance that will prevent foreclosure on your mortgage if you comply with the provisions of the Homeowners' EmergencY Mortgage Assistance Act of 1983 (the "Actj. You may be eligiblE~ for emergency temporary assistance if your default has been caused by circumstances beyond your control. you have a reasonable prospect of resuming your mortgage payments, and if you meet other efigibUity requirements established by the Pennsylvania Housing Finance Agency. Please read an of this Notice. It contains an exptanation of your rights. Under the Act, you are entitled to a temporary stay of foreclosure on your mortgage for thirty (30) days from 1he dalle of this Notice. During that time you must arrange and attend a "face-to-face" meeting with a representative of this lender, or Please write your loan number on all checks and correspondence. BREACHPA 8361396-8 u.aA_ 204 North Second Streel $3,927.28 AS OF 7,12812000 P ,0, Box 660694 Dallas, TX 75266-0694 11...lul.lu.I.I.II.lllf.lllullllnl.l,ulull.lrulullll,1l 836139680003927280392728 < ~ <- 10 ,~ '"" ,~ , '-,"-"' ,,.;.,-, ~" .0' ~~"~ HUD-Approved Counseling Agencies - Pennsylvania with a designated consumer credit counseling agency. The pW?ose of this meeting is to attempt to work out a repayment plan, or to otherwise settle your delinquency. This meeting must occur in the next thirty (30) days. If you attend a face-to-face meeting with this lender, or with a consumer crecfd: counseling agency identified in this notice, no--further --proceeding- in -mortgage foreclosure -may take- place for thirty- (3G)"days--after the -date-of this-meeting, The name, address and telephone number of our representative is: COUNTRYWIDE, 6400 Legacy Drive, Piano, Texas 72567, Telephone Number: 1-8011-669-4575, Extension 4334. The names and addresses of. designated consumer credit counseling agencies are shown on the attached sheet. Jt is only necessary to schedule one face-to-face meeting. You should advise Countrywide of your intentions lmmediater". If you have tried and are unable to resolve this problem at or after your face-to-fa~ meeting, you have the riQt1t to apply for financial assistance from the Homeowners' Emergency Mortgage Assistance Fund. In order to do this, you must fill out. sign and file a completed Homeowners' Emergency Assistance Appfication with one of the designat.ed corniUmer credit counseDng agencies fisted on the attachment An application for assistance may onty be obtained from a consumer credit COW1SeI"mg agency. The consumer credit counseUog agency win assist you in fiRing out-your applilt:ation and will submit your completed appncation to the Pennsylvania Housing Finance Agency. Your appfication must bu filed or postmarked within thirty (30) days of your face-to.-face meeting. Available funds for emergency mortgage assistance are very limited. They WIll be disbursed by the Aglency under the eligibility criteria established by the Act It is extremely important that you file your application prompUy. If you do not do so, or if you do not foDowthe othel' time periods set forth in this letter, foreclosure may proceed against your home immediately. It is extremely important tha1t your application is accurate and complete in every respect. The Pennsylvania Housing Finance Agency has sixty (60) days to make a decision after it receives your application. During that additionaftime, no foreclosure proceedings wiD be pursued against you if you have met tile time requirements set forth above. You will be notified directly by that Agency of its decision on your application. The Pennsylvania Housing Finance Agency is located at 2101 North Front street, Post Office Box 8029, Hanisburg, Pennsylvania 17105. Telephone No. 1-717-780-3800 or 1-800-342-2397 (toll free number). Persons with imp1aired hearing can call 1-800-342-2397, If the mortgage is foreclosed, your mortgaged property will be sold by the Sheriff to payoff the mortgage debt If you cure the default before we begin legal proceedings against you, you wl1l still have to pay. the reasonable attorney's fees actuaUy incurred, up to $50.00. However, if regal proceedings are started against you, .you will have to pay the reasolilable attorney's fees even if they are over $50.00. Any attorney's fees will be added to whatever you owe us. which- mlJ1jr also include our reasonable costs. If you cure this default within the thirty-five day period, you wiD not be required to pay the attorney's fees, YOU HAVE THE RIGHT TO REINSTATE AFTER ACCELERATION AND THE RIGHT TO ASSl:FtT IN THE FORECLOSURE PROCEEDING THE NON-EXISTENCE OF A DEFAULT OR A/f'( OTHER DEFENSE YOU MAY HIWE TO ACCELERATION AND FORECLOSURE. - --'~,,--" I. 1-, ---", f-,i ~~ ~ ~ ~ Send Coneopondence to: P,O. Box 280599 Piano, TX 75026..()599 Send Payments to: P.O. Box660694 Dallas, TX 7526&.0694 July 28, 2000 Ber1ified MaD No, Return Receipt Requested Regular MaD KermH W Moyer 204 North Second Street WormJeysburg, PA 17043-0000 Cou~e Loan # 8361396 Property Address: 204 North Second Street Wormleysburg, PA 17043-0000 FHANA Case #: 101060512664 NOTICE OF INTENT TO FORECLOSE YOUR HOME LOAN IS IN DEFAULT FOR THE REASONS SET FORTH IN THIS NOTICE. YOU MUST TAKE ACTION TO SAVE YOUR HOME FROM FORECLOSURE. Countrywide Home Loans, Inc. (hereinafter "Countrywide") services your home loan. Your home loan is in serious dErfault because you have not made your required payments. The total amount now required to reinstate your loan as oJ the date of this letter is as follows: Monthlv Pavments: 02/0112000 - 0313112000 0410112000 - 07/3112000 02/0112000 - 03/3112000 04/0112000 - 07/3112000 Uncollected Costs: @ @ @ @ $620,00 $623,00 $24,80 $24,92 $1,240,00 $2,492,00 $49,60 $99,68 $46,00 TOTAL DUE: $3,927,28 You may cure this default within THIRTY..f1VE (35) DAYS of the date of this letter, by paying to us the above amount of $3,927.28, plus any additional monthly payments, late charges, fees and other applicable charges which may taU due during this period. Such payment must be in the form of certified check, cashier's check or money order, and made payable to Countrywide at P.O. Box 10221, Van Nuys, CA 91410-0221. If your check or other payment is retume~ to us for insufficient funds or for any other reason, you will not have cured your defauft. No extension of time to cure.-wiD be granted due to a returned payment. Late Charaes: Other Charaes' If you do not cure this default within THIRTY-FIVE (35) DAYS, we will accelerate the payments due on your home loan. This means whatever is owing on the original amount borrowed will be considered due immediately and you may IOSH the chanceJo pay off your home loan in morithfy i~llments. If the full payment of the amount of default is not made within THIRTY-FIVE (35) DAYS, we also intend to immediately start a lawsuitto foreclose on your mortgaged property. YOU MAY BE EUGIBLE FOR FINANCIAL ,ASSISTANCE WHICH CAN SAVE YOUR HOME FROM FORECLOSI~RE AND HELP YOU MAKE FUTURE MORTGAGE PAYMENTS. The Comrnonwealth of Pennsylvania's Homeowner's Emergency Mortgage Assistance program may be ablle to help you. Read the following notice to- find out how the program works. La notificacion en adjunto es de suma impo~cia, pues afecta 50 derecho a continuar viviendo en su C8S8'. Si no comprende el contenido de esta notifICacion obtenga' una traduccion inmediatamente Jlarnando a esta agencia (Pennsylvania Housing Finance Agency) sin cargos al numero mencionado arriba. Usted puede ser elegible para un presta-mo del programa llamado "Homeowner"s Emergency Mortgage Assistance Progran." el cual puede salvar su casa de Ia perdida del derecho a redimir su hipotecaL You may be e6gible for financial assistance that witl prevent foreclosure on your mortgage if you comply with the provisions of the Homeowners' Emergency Mortgage Assistance Act of 1983 (the "Acti. You may be eDgible for emergency temporary assistance if your defauft has been caused by circumstances beyond your controll you have a reasonable prospect of resuming your mortgage payments, and if you meet other e6gibility requirements established by the Pennsylvania Housing Finance Agency. Please read aU of this No1Ice. ft contains an explanation of your rights. 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 ~d a "face-to-face" meeting with a representative of this lendtlf, or Please write your loan number on aU checks and correspondence. BREA<:HPA 8361396-8 Kermit W Moyer 204 North Second Street $3,927,28 AS OF 7/28/2000 P,O, Box 660694 Dallas, TX 75266-0694 11...1.1.111I1.1.1111I11..11111111'111111I1111111.111..1111.11 836139680003927280392728 .~ I" -'Uiilil.i 1- ,~,~C .~ p ,. I " HUD-Approved Counseling Agencies - Pennsylvania with a designated consumer cred"d; counse6ng agency. The purpose of this meeting is to attempt to work out a repayment plan, or to otherwise settle your delinquency. This meeting must occur in the next 'thirty (30) days. If_yo~_attend _8 face-to-face mee~ng witt1 this lender, or with a consumer credit counseUng agency identified in this notice, no-rui1he-rproeeeamg in mortgage foreclosure may take place for thirty (30) days after the- date of 1hls meetIDg:- The name, address and telephone number of our representative is: COUNTRYWIDE, 6400 Legacy Drive, Piano, ~rexas 725G7, Telephone Number: 1-300-869-4575, Extension 4334. The names and addresses of designated consumer credit counseling agencies are shown on the attached sheet. It is only necessary to schedule one face-to-face meeting. You should advise Countrywide of your intentions immediately. If you have bled and are unable to resolve 1his problem at or after your face-to-face meeting, you have the right to apply for financial assistance from the Homeowners' Emergency Mortgage Assistance Fund. In order to do this, you must fiB out, sign and file a completed Homeowners' Emergency Assistance Application with one of the desigPl. ~ comlUmer credit counseling agencies fisted on the attachment. An application for assistance may only be obtained from a consumer cred"d: counseling agency. The consumer crecfit counseling agency Will assist you in tiDing out your appllt:ation and will submit your completed appncation to the Pennsytvania Housing Finance Agency. Your application must bl! filed or postmarked within thirty (JO) days of your face-to-face meeting. Available funds for emergency mortgage assistance are very limited. They will be disbursed by the Aflfency under 1he eligibirlty criteria established by the Act It is extremely important 1hat you file your application promptly. If you do not do so, or if you do notfoltow t;he othelr time periods set forth in this letter, foreclosure may proceed against your home immediately. It is extremely important that your appncation is accurate and complete in every respect, The Pennsylvania Housing Finance Agency has sixty (60) days to make a decision after it receives your appfication. During that additional time, no foreclosure proceedings will be pursued against you if you have met the time requirements set forth above. You win be notified OJfectly by that Agency of its decision on your appfication. The Pennsylvania Housing Finance Agency is located at 2101 North Front Street, Post Office Box 8029, Harrislburg, Pennsylvania 17105, Telephone No, 1-717-7~800 or 1-300-342-2397 (loll free number), Persons with impaired hearing can call 1-800-342-2397. If the mortgage is foreclosed, your mortgaged property will be sold by the Sheriff to payoff the mortgage debt. lit you cure the default before we begin legal proceedings against you, you will stili have to pay the reasonable attorney'sl fees actually incurred, up to $50.00. However, if legal proceedings are started against you, you wiD have to pay the reasonable attorney's fees even if they are over $50.00. Any attorney's fees Will be added to whatever you owe us, which m8)r also include our reasonable costs. If you cure 1his default within the thirty-five day period, you will not be required M:'pl:lIY the attomey's fees, YOU HAVE THE RIGHT TO REINSTATE AFTER ACCELERATION AND THE RIGHT TO ASSERT IN THE FORECLOSURE PROCEEDING THE NON-EXISTENCE OF A DEFAULT OR ANY OTHER DEFENSE YOU MAY,HAVE TO ACCELERATION AND FORECLOSURE. - . ~ ~ fB l1..n.r1 @V .",< ,,', ",.-.1!IMI1'm - ,.,="~ " -~, ,-' .., ""~ ,.,.~ _,~,,1llII!l'W, " ,--. ","..,"-"".,..'.',' T <~~ .,,"-< ,- 'h '<Ui.",_~'_"_n~",~'.J,~' ;;-- I" "'Y"'i~'r 'U'I.F L=.:J i'''''-....~ ~~~ L;,::'...-... ,Ln..XI &----, IO'~ ~.~f~!~) I> " ~,,,,~;_It,nw."'!!$\'_~"I~~~~'BitW4~al]~_~"fr-'l'!~1'li~"5f!;jJ,~~~ , ':"c, I' " ,~ h <-,,' -' , ,~-'.;" -<~, ""~_l DEe 2 7 20~ GOLDBECK MCCAFFERTY & MCKEEVER JOSEPH A. GOLDBECK, JR. Attorney I.D.#16132 Suite 500-The Bourse Building 111 S. Independence Mall East Philadelphia, PA 19106 215-627-1322 BY: LISA D. BLANKENBURG, ESQUIRE Attorney I.D. #78020 Attorney for Plaintiff COUNTRYWIDE HOME LOANS INC. 7105 Corporate Drive PTX B-35 PIano, TX 75024-3632 IN THE COURT OF COMMON PLEAS OF CUMBERLAND COUNTY vs No. 00-6883 KERMIT W. MOYER LISA A. MOYER (Mortgagors and Real Owners) 204 North Second Street Wormleysburg, PA 17043 AND NOW, this ORDER '7.'1 day oro~ 200CP, the Plaintiff I s Motion for Substituted upon consideration of Service under Pa.R.C.P. 430(a) and it appearing to the Court that Plaintiff's good faith efforts to ascertain the present whereabouts of Defendant, Lisa A. Moyer, has been unsuccessful, it is, ORDERED and DECREED: that Plaintiff's Motion is granted and the Sheriff and/or Plaintiff is directed to Serve the Complaint in Mortgage Foreclosure upon Defendant by posting a copy of the Complaint upon the premises 204 North Second Street, Wormleysburg, PA 17043 and Plaintiff is directed to serve the Complaint by certified and regular mail to the Defendant's last known address of 204 North Second street, Wormleysburg, PA 17043 and that all further service J i " I " I I ~ II I i ~ 'M "<,! ~,." ".", ,..,--, ~ rw.'8JJ1, __=,_ -"-, ,"'. ' "',~~,<~._".....-"._, -I" ....,..,-- '--'-''''''''''>~ ~~~- ~-, g ;;" '" j. "! .... '} ] _', /''If'r.~~.1!!t~f~~~ifi:!lm~~~l~--r~ ...,~~l!'J . . '; "' , -~ 1,,-, "'<' .'C ."..:~,~.; "'~ '''-\t.,l of legal papers, including but not limited to motions, petitions and rules be made by certified and regular mail to Defendant's last known address and that Notice of Sheriff Sale pursuant to Pennsylvania Rule of Civil Procedure 3129 may be made upon Defendants by sending copies of same to Defendant's last known address by certified and the premises. J. rr II~ ~l'" llD':I"l. ~~. "-, _q ~ "0 "'~'. ,~,. _F_"~ "", .' , . -.,- .~"' , -, ~- I" 'Iw' ,,',' ;::u-()\~F\Ct. OF ". .,:_:,,,>\,,':~:!,\~}T:\rW nun 1I'-,n ? '\ Ul t. CO,", "'~(... ,.... n fI[,. ~.J ..'" .. . , \ ,1 rC-' -' C1 'I \-"r'--' '- - "- !~ ,..., u"~""" U'I\I,~q""r~l J'':'\~' , \ :; '. 'I' '1 ,~..I'- ,.....' " ,,-, "" ..~' i PENNSYl\Jf\.NV\ ,"'-" ,"~ r"'ll_~IO\\f'\'W8%'\-~f!' . ~~'Jf1~;~, "'U-';';"" 'J"~"w'" ,"'~- ~.~.".' '-'-'" <.~Tl, ;Ij~~l;'!l!,i'-lljiji\!!,_ ,." . Il'l1 "7'''' . r' k "0 . " ';';'-'-';<,'L-&' ..".' GOLDBECK MCCAFFERTY & MCKEEVER JOSEPH A. GOLDBECK, JR. Attorney I.D.#16132 Suite 500-The Bourse Building 111 S. Independence Mall East Philadelphia, PA 19106 215-627-1322 BY: LISA D. BLANKENBURG, ESQUIRE Attorney I.D. #78020 Attorney for Plaintiff COUNTRYWIDE HOME LOANS INC. 7105 Corporate Drive PTX B-35 PIano, TX 75024-3632 IN THE COURT OF COMMON PLEAS OF CUMBERLAND COUNTY vs No. 00-6883 ~IT W. MOYER LISA A. MOYER (Mortgagors and Real Owners) 204 North Second St~eet Wonnleysburg, PA 17043 THIS LAW FIRM IS A DEBT COLLECTOR AND WE ARB ATTEMPTING TO COLLECT A DEBT OilED TO OQRCLIERT _ ANY INFORMATION OBnINlID FROM YOU WILL BE USED FOR TllE PURPOSE OF COLLECTING THE DEBT_ MOTION FOR SUBSTITUTED SERVICE UNDER PA.R.C.P. 430{a) Plaintiff, by and through its attorney, Lisa D. Blankenburg, Esquire, in support of its Motion for Substituted Service, represents as follows: 1. Plaintiff is the holder of a first mortgage upon the premises 204 North Second Street, Wormleysburg, PA 17043, hereinafter, the nmortgaged premisesn. 2. Defendants, KERMIT W. MOYER AND LISA A. MOYER, are the mortgagors and real owners of the mortgaged premises. 3. The last known address of Defendant, Lisa A. Moyer, is 204 North Second Street, Wormleysburg, PA 17043 as set forth in Paragraph 2 of the Complaint. l!." , . -- I I ="~, ~ -', 'L'"'~";' ,-'--j.--"-,- , ~ !Ii,' 4 . The Sheriff has been unable to effect service of the Complaint upon Defendant at his last known address after numerous attempts. 5. The following investigation was conducted in a good faith attempt to ascertain the whereabouts of Defendant, Lisa A. Moyer. WHEREFORE, Plaintiff prays that the Court enter the attached order allowing Plaintiff to serve the Complaint upon Defendant by posting the premises and certified and regular mail to the Defendant's last known address. BY: LISA D. BLANKENBURG, ESQUIRE -.! c___ I "I~ -- , --;",.'" "~\ii!oii[':' GOLDBECK MCCAFFERTY & MCKEEVER JOSEPH A. GOLDBECK, JR. Attorney I.D.#16132 Suite 500-The Bourse Building 111 S. Independence Mall East Philadelphia, PA 19106 215-627-1322 BY: LISA D. BLANKENBURG, ESQUIRE Attorney I.D. #78020 Attorney for Plaintiff COUNTRYWIDE HOME LOANS INC. 7105 Corporate Drive PTX B-35 PIano, TX 75024-3632 IN THE COURT OF COMMON PLEAS OF COMBERLANP COUNTY vs No. 00-6883 KERMIT 'if. MOYER LISA A. MOYER (Mortgagors and Real OWners) 204 North Second Street Wonnleysburg, PA 17043 VERIFICATION I, LISA D. BLANKENBURG, ESQUIRE, Attorney for Petitioner do hereby verify that the facts set forth in the foregoing Motion for Substituted Service are true and correct to the best of my knowledge, information and belief. I understand that false statements therein are made subject to the penalties of 18 Pa. C.S. 4904 relating to unsworn falsification to authorities. LISA D. BLANKENBURG, ESQUIRE 'J _I;;~' ^ ",]c..., ". - '," ~ :,^ GOLDBECK MCCAFFERTY & MCKEEVER JOSEPlI A. GOLDBECK, JR. Attorney I.D.#16132 Suite 500-The Bourse Building 111 S. Independence Mall East Philadelphia, PA 19106 215-627-1322 BY: LISA D. BLANKENBURG, ESQUIRE Attorney I.D. #78020 Attorney for Plaintiff COUNTRYWIDE HOME LOANS INC. 7105 Corporate Drive PTX B-35 PIano, TX 75024-3632 IN THE COURT OF COMMON PLEAS OF CUMBERLAND COUNTY vs No. 00-6883 KERMIT W. MOYER LISA A. MOYER (Mortgagors and Real OWners) 204 North Second Street WOnnleysbur9, PA 17043 CERTIFICATE OF SERVICE LISA D. BLANKENBURG, Esquire, do hereby certify that true and correct copies of the the foregoing Motion for Substituted Service have been served upon the Defendant, Lisa A. Moyer, this oD day of [)eCe..w.'o-w- , 200fl, by first class mail, postage prepaid. ISA D. BLANKENBURG, ESQUIRE ~ ., , .-., >-"- ",,'- , . " -,~, ~'lil~l:f;j, GOLDBECK MCCAFFERTY & MCKEEVER JOSEPH A. GOLDBECK, JR. Attorney I.D.#16132 Suite 500-The Bourse Building 111 S. Independence Mall East Philadelphia, PA 19106 215-627-1322 BY: LISA D. BLANKENBURG, ESQUIRE Attorney I.D. #78020 Attorney for Plaintiff COUNTRYWIDE HOME LOANS INC. 7105 Corporate Drive PTX 16-35 PIano, TX 75024-3632 IN THE COURT OF COMMON PLEAS OF CUMBERLAND COUNTY vs No. 00-6883 KERMIT W. MOYER LISA A. MOYER (Mortgagors and Real Owners) 204 North Second Street Wormleysburg, PA 1704,3 MEMORANDUM OF LAW IN SUPPORT OF MOTION FOR SUBSTITUTED SERVICE UNDER Pa.R.C.P. 430Ca) Plaintiff has filed a Complaint in Mortgage Foreclosure against Defendant which the Sheriff has been unable to personally serve upon Defendant, Lisa A. Moyer. As noted in the attached Motion, Plaintiff has made a good faith attempt to ascertain Defendant's whereabouts without success. Accordingly, the Court may approve alternative means of service. See Pa.R.C.P. 430(a). 1-'- I.~, __ ,;:;,.--. "~ '=B"'".'_ ",,-,,--.-,'- - ;.W, CONCLUSION For reasons stated above and in the attached Motion, the Court should enter an order allowing Plaintiff to serve the Complaint in Mortgage Foreclosure upon Defendant, Lisa A. Moyer, by posting the premises and certified mail and regular mail to the Defendant's last known address. fully submitted, ISA D. BLANKENBURG, ESQUIRE "'-- " . "~ I. ,-.I - .... . , ~ """ ~~.."-M;;"~,,~ r~ PLAYERS NATIONAL LOCATOR AFFIDAVIT OF GOOD FAITH INVESTIGATION Loan Number: CWD-0838 Attorney Firm: GOLDBECK, MCCAFFERTY & MCKEEVER Case Number: Subject: LISA A MOYER AKA,: LISA ANN MOYER Property Address: 204 N. SECOND STREET WORMLEYSBURG, PA 17043 Last Known Address: 204 N. SECOND STREET WORMLEYSBURG, PA 17043 Last Known Number: ( ) - Michael K Gross, being duly sworn according to law, deposes and says: 1. I am employed in the capacity of President for Players National Locator. 2, On 10/09/2000, I conducted an investigation into the whereabouts of the above named defendant(s), The results of my investigation are as follows: CREDIT INFORMATlON- A. SOCIAL SECURITY NUMBER: B, EMPLOYMENT SEARCH: Unable to locate a good employer for Lisa. C, INQUIRY OF CREDITORS: Creditors indicated that Lisa is using 204 N Seco valid home number. One creditor stated Li . INQUIRY OF TELEPHONE COMPANY - A. DIRECTORY ASSISTANCE SEARCH: Directory assistance had no listing. INQUIRY OF NEIGHBORS - Unable to verify with neighbors. INQUIRY OF POST OFFICE - A. NATIONAL ADDRESS UPDATE: As of October 3, 2000 the National Change of Address (NCOA) has no change for Lisa from 204 N Second Street, Mechanicsburg, PA 17043. MOTOR VEHICLE REGISTRATION- A. MOTOR VEHICLE & DMV OFFICE: The Pennsylvania Department of Drivers Licensing has Lisa listed at 204 N Second Street, Mechanicsburg, PA 17043. OTHER INQUIRIES - A. DEATH RECORDS: As of October 3, 2000 the Social Security Administration has no death record on file for Lisa A Moyer and/or a.k.a.'s under her social security number. ---. I.... ~~ . B. PUBLIC LICENSES (PILOT, REAL ESTATE, ETC.): None, ' C, COUNTY VOTER REGISTRATION: The County Voters Registration Office has no listing. OTHER SEARCHES - The social security number provided has been verified. ADDITIONAL INFORMATION ON SUBJECT- A, DATE OF BIRTH: May 1971 ~2 - c ~-:::> L AFFIANT ~~~~~~J.i~,,;;S;~~:~~:Ml St Louis COUl1ty, State of Missouri My Commission Expires 912/2002 J ,~~~ Players National Locator 113 Old State Road, Suite 104 St. Louis, MO 63021 Phone: (636) 230-9922 Fax: (636) 230-0558 ~~ ~ "..........~liv: _I ., u .I SHERIFF'S RETURN - NOT FOUND '''"''' ,~,~~,'~ - >i ~'~', ~'''~'"-''''''fp,] I I I , 1 , I , , I I i I CASE'NO: 2000-06883 P 'COMMONWEALTH OF' PENNSYLVANIA COUNTY OF CUMBERLAND COUNTRYWIDE HOME LOANS INC VS MOYER KERMIT W ET AL R. Thomas Kline ,Sheriff or Deputy Sheriff, who being duly sworn according to law, says, that he made a diligent search and inquiry for the within named defendant, DEFENDANT MOYER LISA A but was unable to locate Her in his bailiwick. He therefore returns the COMPLAINT - MORT FORE , NOT FOUND , as to the within named DEFENDANT , MOYER LISA A DEFT. DOES NOT RESIDE AT ABOVE ADDRESS, NOR HER HUSBAND'S NEW ADDRESS. POST OFC HAS NO INFORMATION. Sheriff's Costs: Docketing Service Not Found Return Surcharge So -"'~'--" ---,.,.,~ 6.00 .00 5.00 10.00 .00 21.00 R. llomas Kline Sheriff of Cumberland County 00/00/0000 Sworn and subscribed to before me this day of A.D. Prothonotary ~~= " L.stf<~..%li''''LF.",,,-,,~O~'-'h'''','_1i:Wi$~~.I:>cTI~J>-})8,"Y;;l,U&ii!i,,,*:,,,:.w;~Wll~~~'..........-M1~L:.tilijJJ!~Ij;--'-~~~~~~. ~r~~_,~'.b~,' -'.>1' "' <_ '.._~_^ ~ I , ."~ .-' ,,~- ~. ~} -_. ~~~1.<iA!!I ~u." -. !t'J~ ~. . ~;;:i '. n 0 ,,-) C C:~J --;"\ -',"" :::J .':'-.. V [j.) ~ , n , \;;'! -::'j ;;,: :;?: :-v G) 0" - ~ ::;:! Ch> -< !lj ~~ ,"" . L 1-, .,' " t ~i!;~ GOLDBECK McCAFFERTY & McKEEVER BY: Joseph A. Goldbeck, Jr. Attorney I.D.#16132 Suite 500 - The Bourse Bldg. III S. Independence Mall East Philadelphia, PA 19106 215-627-1322 Attorney for Plaintiff COUNTRYWIDE HOME LOANS INC. IN THE COURT OF COMMON PLEAS 7105 Corporate Drive PTX B-35 OF CUMBERLAND COUNTY PIano, TX 75024-3632 Plaintiff CIVIL ACTION - LAW VS. :ACTION OF MORTGAGE FORECLOSURE KERMIT W. MOYER AND LISA A. Term MOYER (Mortgagor(s) and Record No. 00-6883 CIVIL TERM Owner(s)) 204 North Second Street wormleysburg, PA 17043 Defendant(s) PRAECIPE TO REINSTATE COMPLAINT Kindly reinstate the Complaint in the above captioned matter. BY: & MCKEEVER ck, Jr. CWD-OB3S ~:ll\~i*lOOllliiMili~~~tl~&~I~_dt;t!,jj~""-.<-'~ J3JiigmJiu " ,~-~ _ ~ q N~ -~ ; "'~ ' q' -,," .' ^ o c $: ~jg:: Z:'.! ZC (fJ <c. ~(~ r:::.,----,' ~, >,~ ~S:;2 , ,- 21 ~'-\ -<. , ,~ ,0 .," '1"- ~<a't , CO -~a ,'-" (,,) . .- "-' i;IoIi'. liii",r 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 COUNTRYWIDE HOME LOANS INC. 7105 Corporate Drive PTX B-35 PIano, TX 75024-3632 IN THE COURT OF COMMON PLEAS OF CUMBERLAND COUNTY vs. Term No. 00-6883 CIVIL TERM KERMIT W. MOYER AND LISA A. MOYER (Mortgagor(s) and Record Owner (s) ) 204 North Second Street Wormleysburg, PA 17043 CERTIFICATE OF SERVICE JOSEPH A. GOLDBECK, JR. ESQUIRE hereby certifies that on /lld/f)J he did serve upon Defendant(s) LISA A. MOYER and KERMIT W. MOYER a true and correct copy of the above-captioned Complaint by certified and regular mail in accordance with the Court Order dated DECEMBER 28, 2000. The undersigned understands that the statements herein and subject to the penalties provided by 18 P.S. Section 4904. >> JOSEPH A. GOLDBECK, JR. ESQUIRE ilii ~_4'hfi!:H_~.~1t~r-f.~.tl;l'j~~~1~~.t.;-r@i'!ili~'!t>if_2&ii;[!twtm~ill'lfiiilIi:l'w.M.iljlli'~'" , ~--~-~, ,~~- .~ ~. -, .' "' ". ,,,,,,,-'.",-,^,' =- :,"'( ~tf ~;~~: --<'>' ...~~ -<: c} c=:- ~~ " "Tiiii :,-.. ;,_l: ,-.; ,("', ""- '"~': ,l] ::i :" lll; .........,0)" ' :-~ ~ ,.. ~d .~ "~ ..:.-.1 .. SHERIFF'S RETURN - NOT SERVED CASE NO: 2000-06883 P COMMONWEALTH OF PENNSYLVANIA COUNTY OF CUMBERLAND COUNTRYWIDE HOME LOANS INC VS MOYER KERMIT W ET AL R. Thomas Kline , Sheriff , who being duly sworn according to law, says, that he made a diligent search and inquiry for the within named DEFENDANT , to wit: MOYER KERMIT W but wa:3 unable to locate Him in his bailiwick. He therefore returns the REINSTATED COMPLAINT-MORT NOTICE NOT SERVED , as to the within named DEFENDANT , MOYER KERMIT W PROPERTY POSTED WITH A COPY OF THE COMPLAINT PUR- SUANT TO COURT ORDER ON 1/10/01 AT 7:40 PM. Sheriff's Costs: Docketing Service POSTING Surcl1.arge 18.00 9.30 6.00 10.00 .00 43.30 . THOMAS KLIN SHERIFF OF CUMBERLAND COUNTY GOLDBECK MCCAFFERTY & MCKEEVER 01/12/2001 Sworn and subscribed to before me this ;/3.A-<L day Of~ dl...v I A. D . ~~ C, ~~flI~/J~ Pro\) , otary ~" "I",.. J ~'" -""",.. '. -"'':'1'- . SHERIFF'S RETURN - NOT SERVED CASE NO: 2000-06883 P COMMONWEALTH OF PENNSYLVANIA COUNTY OF CUMBERLAND COUNTRYWIDE HOME LOANS INC VS MOYER KERMIT W ET AL R. Thomas Kline , Sheriff , who being duly sworn according to law, says, that he made a diligent search and inquiry for the within named DEFENDANT , to wit: MOYER LISA A but was unable to locate Her in his bailiwick. He therefore returns the REINSTATED COMPLAINT-MORT NOTICE NOT SERVED , as to the within named DEFENDANT , MOYER LISA A PROPERTY POSTED WITH COpy OF COMPLAINT PURSUANT TO COURT ORDER ON 1/10/01 AT 7:40 PM BY DEP HARRISON. Sheriff's Costs: Docketing Service Affidavit Surcharge 6,00 .00 .00 10.00 .00 16.00 ~~ . THOMAS KLINE SHERIFF OF CUMBERLAND COUNTY GOLDBECK MCCAFFERTY & MCKEEVER 01/12/2001 Sworn and subscribed to before me this 23Mi--. day of ~ ,... "; ~/ A.D. ~. (l ?nd;'J) # Pr notary J ~ ,~ 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 (21 C;) 627-1122 , . "-'--'~-,; " " -' , "iffi~~ ATTORNEY FOR PLAINTIFF Countrywide Home Loans, Inc. 7105 Corporate Center Drive, PTX B-35 P1ano, TX 75024-3632 Vs. Kermit W. Moyer (Mortgagor and Real Owner) 22 Ashburg Drive Mechanicsburg, PA 17055 Lisa A. Moyer (Mortgagor and Real Owner) 204 N. 2nd Street Wormleysburg, PA 17043 PRAECIPE FOR JUDGMENT FOR FAILURE TO ANSWER AND ASSESSMENT OF DAMAGES TO THE PROTHONOTARY: CUMBERLAND COUNTY COURT OF COMMON PLEAS CIVIL DIVISION NO 00-6883-civil Kindly enter judgment in favor of the Plaintiff and against Kermi~ Moyer (Mortgagor and Real OWner) and Liaa A. MQyer (Mortgagor and Real Owner), Defendant(s) for failure to file an Answer to Plaintiff's Complaint within 20 days (or 60 days if defendant is the United States of America) from the date of service of the complain and for foreclosure and sale of the mortgaged premises, and assess Plaintiff's damages as follows: As set forth in Complaint Interest - 10/1/00 - 3/7/01 Late Charges Escrow Debit TOTAL $80,815.66 $ 2,336.82 $ 149.52 S 613.68 $83,918.68 I hereby certify that (1) the addresses of the Plaintiff and Defendants are as shown above, and (2) that notice has been given in accordance with Rule 237.1, copy attached. 'ldbeck, Jr. Att r Plaintiff I I~ i< ) /()M. LA-) /;A" ~ PRO P~ ~~. '1\] I hereby certify that the above names are correct and that the precise residence address of the judgment creditor is 7105 Corporate Center Drive, PTX B-35, PIano, TX 75024-3632 and that the names and last known addresses of the Defendants is: Kermit W. Moyer (Mortgagor and Real Owner) 22 AShburg Drive, Mechanicsburg, PA 17055 Lisa A. Moyer (Mortgagor and Real Owner) 204 N. 2nd Street, Wormleysburg, PA 17043 DAMAGES ARE HEREBY ASSESSED AS DATE: /!!!die. h 1; ;)00 ( . - -'I ~ ,. ,J__ -"', ",- - ,-', - ~ .'",~- nti!ilififilL TO: KERMIT W, MOYER 22 Ashburg Drive Mechanicsburg, PA 17055 COUNTRYWIDE HOME LOANS INC, 7105 Corporate Drive PTX B-35 PIano, TX 75024-3632 Plaintiff vs. KERMIT W. MOYER AND LISA A. MOYER (Mortgagor (s) ) (Record Owner(s)) 204 North Second Street Wormleysburg, PA 17043 Defendant(s) IN THE COURT OF COMMON PLEAS OF CUMBERLAND COUNTY CIVIL ACTION - LAW ACTION OF MORTGAGE FORECLOSURE Term No. 00-6883 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. TO: KERMIT W. MOYER 22 Ashburg Drive Mechanicsburg, PA 17055 DATE OF THIS NOTICE: February 2, 2001 IMPORTANT NOTICE YOU ARE IN DEFAULT BECAUSE YOU HAVE FAILED TO ENTER A WRITTEN APPEARANCE PERSONALLY OR BY ATTORNEY AND FILE IN WRITING WITH THE COURT YOUR DEFENSES OR OBJECTIONS TO THE CLAIMS SET FORTH AGAINST YOU. UNLESS YOU ACT WITHIN TEN (10) DAYS FROM THE DATE OF THIS NOTICE, A JUDGMENT MAY BE ENTERED AGAINST YOU WITHOUT A HEARING AND YOU MAY LOSE YOUR PROPERTY OR OTHER IMPORTANT RIGHTS. YOU SHOULD TAKE THIS NOTICE TO A LAWYER AT ONCE. IF YOU DO NOT HAVE A LAWYER OR CANNOT AFFORD ONE, GO TO OR TELEPHONE THE FOLLOWING OFFICE TO FIND OUT WHERE YOU CAN GET LEGAL HELP: Cumberland County Bar Association 2 Liberty Avenue, Carlisle, PA (800) 990-9108 /s/ JotJeph -.A. goldbeck. Jr. GOLDBECK McCAFFERTY & McKEEVER BY: Joseph A. Goldbeck, Jr., Esq. Attorney for Plaintiff Suite 500 - The Bourse Bldg. 111 S. Independence Mall East Philadelphia, PA 19106 215-627-1322 ~Ol _'_"I. , ",,~ TO: LISA A. MOYER 22 Ashburg Drive Mechanicsburg, PA 17055 COUNTRYWIDE HOME LOANS INC, 7105 Corporate Drive PTX B-35 PIano, TX 75024-3632 Plaintiff vs. KERMIT W, MOYER AND LISA A. MOYER (Mortgagor (s) ) (Record Owner(s)) 204 North Second Street Wormleysburg, PA 17043 Defendant(s) IN THE COURT OF COMMON PLEAS OF CUMBERLAND COUNTY CIVIL ACTION - LAW ACTION OF MORTGAGE FORECLOSURE Term No. 00-6883 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. TO: LISA A. MOYER 22 Ashburg Drive Mechanicsburg, PA 17055 DATE OF THIS NOTICE: February 2, 2001 IMPORTANT NOTICE YOU ARE IN DEFAULT BECAUSE YOU HAVE FAILED TO ENTER A WRITTEN APPEARANCE PERSONALLY OR BY ATTORNEY AND FILE IN WRITING WITH THE COURT YOUR DEFENSES OR OBJECTIONS TO THE CLAIMS SET FORTH AGAINST YOU. UNLESS YOU ACT WITHIN TEN (10) DAYS FROM THE DATE OF THIS NOTICE, A JUDGMENT MAY BE ENTERED AGAINST YOU WITHOUT A HEARING AND YOU MAY LOSE YOUR PROPERTY OR OTHER IMPORTANT RIGHTS. YOU SHOULD TAKE THIS NOTICE TO A LAWYER AT ONCE. IF YOU DO NOT HAVE A LAWYER OR CANNOT AFFORD ONE, GO TO OR TELEPHONE THE FOLLOWING OFFICE TO FIND OUT WHERE YOU CAN GET LEGAL HELP: Cumberland County Bar Association 2 Liberty Avenue, Carlisle, PA (800) 990-9108 /s/ JOdeph -A. (Jotdbeck. Jr. GOLDBECK McCAFFERTY &< McKEEVER BY: Joseph A. Goldbeck, Jr., Esq. Attorney for Plaintiff Suite 500 - The Bourse Bldg. III S. Independence Mall East Philadelphia, PA 19106 215-627-1322 ~~I- , ,. -= h, , ,'-~ '-.. ,~,~':. -, , ili:~l TO: LISA A, MOYER 204 North Second Street Wormleysburg, PA 17043 COUNTRYWIDE HOME LOANS INC. 7105 Corporate Drive PTX B-35 Plano, TX 75024-3632 Plaintiff vs. KERMIT W, MOYER AND LISA A. MOYER (Mortgagor (s) ) (Record Owner(s)) 204 North Second Street Wormleysburg, PA 17043 Defendant (s) IN THE COURT OF COMMON PLEAS OF CUMBERLAND COUNTY CIVIL ACTION - LAW ACTION OF MORTGAGE FORECLOSURE Term No. 00-6883 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. TO: LISA A. MOYER 204 North Second Street Wormleysburg, PA 17043 DATE OF THIS NOTICE: February 2, 2001 IMPORTANT NOTICE YOU ARE IN DEFAULT BECAUSE YOU HAVE FAILED TO ENTER A WRITTEN APPEARANCE PERSONALLY OR BY ATTORNEY AND FILE IN WRITING WITH THE COURT YOUR DEFENSES OR OBJECTIONS TO THE CLAIMS SET FORTH AGAINST YOU" UNLESS YOU ACT WITHIN TEN (10) DAYS FROM THE" DATE OF THIS NOTICE, A JUDGMENT MAY BE ENTERED AGAINST YOU WITHOUT A HEARING AND YOU MAY LOSE YOUR PROPERTY OR OTHER IMPORTANT RIGHTS. YOU SHOULD TAKE THIS NOTICE TO A LAWYER AT ONCE. IF YOU DO NOT HAVE A LAWYER OR CANNOT AFFORD ONE, GO TO OR TELEPHONE THE FOLLOWING OFFICE TO FIND OUT WHERE YOU CAN GET LEG~L HELP: Cumberland County Bar Association 2 Liberty Avenue, Carlisle, PA (800) 990-9108 /s/ JotJeph -A. goldbeck. JI'. GOLDBECK McCAFFERTY & McKEEVER BY: Joseph A, Goldbeck, Jr., Esq. Attorney for Plaintiff Suite 500 - The Bourse Bldg. 111 S, Independence Mall East Philadelphia, PA 19106 215-627-1322 I.."" ' L_u ,. .;. '-" .,"-,~ '-"-'-;'" . ,-c ,:,;,'; "', 0 ~_. ~~ . TO : KERMIT W, MOYER 204 North Second Street Wormleysburg, PA 17043 COUNTRYWIDE HOME LOANS INC, 7105 Corporate Drive PTX B-35 PIano, TX 75024-3632 Plaintiff VB, KERMIT W. MOYER AND LISA A. MOYER (Mortgagor (s) ) (Record Owner(s)) 204 North Second Street Wormleysburg, PA l7043 Defendant(s) IN THE COURT OF COMMON PLEAS OF CUMBERLAND COUNTY CIVIL ACTION - LAW ACTION OF MORTGAGE FORECLOSURE Term No. 00-6883 CIVIL TERM THIS LAW FIRM IS A DEBT COLLECTOR AND WE ARE ATTEMPTING TO COLLECT A DEBT OWED TO OUR CLIENT. ANY INFO~TION OBTAINED FROM YOU WILL BE USED FOR THE PURPOSE OF COLLECTING THE DEBT. TO: KERMIT W. MOYER 204 North Second Street Wormleysburg, PA 17043 DATE OF THIS NOTICE: February 2, 2001 IMPORTANT NOTICE YOU ARE IN DEFAULT BECAUSE YOU HAVE FAILED TO ENTER A WRITTEN APPEARANCE PERSONALLY OR BY ATTORNEY AND FILE IN WRITING WITH THE COURT YOUR DEFENSES OR OBJECTIONS TO THE CLAIMS SET FORTH AGAINST YOU. UNLESS YOU ACT WITHIN TEN (10) DAYS FROM THE DATE OF THIS NOTICE, A JUDGMENT MAY BE ENTERED AGAINST YOU WITHOUT A HEARING AND YOU MAY LOSE YOUR PROPERTY OR OTHER IMPORTANT RIGHTS. YOU SHOULD TAKE THIS NOTICE TO A LAWYER AT ONCE. IF YOU DO NOT HAVE A LAWYER OR CANNOT AFFORD ONE, GO TO OR TELEPHONE THE FOLLOWING OFFICE TO FIND OUT WHERE YOU CAN GET LEG~L HELP: Cumberland County Bar Association 2 Liberty Avenue, Carlisle, PA (800) 990-9108 /s/ JOdeph -A. (jotdteck, Jr. GOLDBECK McCAFFERTY & McKEEVER BY: Joseph A. Goldbeck, Jr., Esq. Attorney for Plaintiff Suite 500 - The Bourse Bldg, III S. Independence Mall East Philadelphia, PA 19106 215-627-l322 ~~I~WW;~l'Lf:<l.!iM,;~fo!~i&~JlilriJ<,~":J~~,4tfj.m,<<.~[>,~limi:b~.14.-li' ",'). ;, , '''-''' -LUi -hili::: M ~'-"~ ~ 'j"" ~, -~""t *"'~~' ~- . " II "l '~ l ~ ! 'I !i I I I II 'I 11 II i' 0 ~ ? ~~~ -!:J C') 0 ~ 8 c: 0 s:- :JI: 'TI i=Rm ::::-1 ., ~ J> (6 uJ ~:D :::a Ftj :::n I r- t5J -<~ '"'9 b". \D -,"", ~.-'J =4 ~CJ :::-'(:J J8 -0 ~Jj -r, 3, +: =>: (")::!1 ::!2 ;,').~() ~ ~ - cFTl .. ~ 1=:3 =< "> ;g Ul ::0 -<; cffi .- ".", 0.. .=,.~~~~"~ -, ,." ~" ,--,; 'I. , ;..,[,,-- ",~,,-"", ~'- _c_ ,j ,,,.,~' "" - -, 'Co_, -;, .iJi:l.~ r ... <---*" , , PRAECIPE FOR WRIT OF EXECUTION - (MORTGAGE FORECLOSURE) P.R.C.P. 3180-3183 Countrywide Home Loans, Inc. Plaintiff COURT OF COMMON PLEAS CUMBERLAND COUNTY, PA Vs. NO: 00-6883-Civi1 Kermit W. Moyer (Mortgagor and Real Owner) Lisa A. Moyer (Mortgagor and Real Owner) Defendant(s) PRAECIPE FOR WRIT OF EXECUTION (MORTGAGE FORECLOSURE) TO THE OFFICE OF THE PROTHONOTARY: Issue writ of execution in the above matter: Amount Due Interest from 3/7/01 to sale date at $13.79 per diem Total $83,918.68 $ and Costs $ . Jos A. ldbeck, Jr. Sui SOD-The Bourse Bldg. 111 S. Independence Mall East Philadelphia, PA 19106 Attorney for Plaintiff Note: Please attach description of property. ~~~i.l,i_P.!:M;':Zi\illi':t~~~~'fll!~lWM~'?~r~~'>!Iif!liJj;~lll:i1.l- rl -..t > o..t U I M DO DO <D I o o i!ql( OH ~~ PIl..:l ..:l>< P<tIl i2;~ ~re o . U>< ~~ o E-: IIlPll ;~ ~ u 1:1 H . rlI 1:1 III o ..:l QJ 8 III QJ '0 o~ +I !l o U rlI :> ~ H~ QJ H !j rl IIlrl QJ III I>: QJ '01>: 1:1'0 III 1:1 III H o H l:l10 III l:l1 l:l111l +I l:l1 H +I o H ~~ ~ H QJ H ~i . :;: . I( +I ...t III e .~ QJ ..:l 10<: i2; o ~~ PIl H M ::3 PIl rlI o i!qrl o U QJ E-< H H 0 ~~ QJ I>: l:l1 o III ~ l:l1 +I I!il H ~~ u~ PIl ~ P< , ~ - ,~ Mili---'--"...""'. - III .. "Ci QJ ,..., -.-1 rz. ,--- j -u"W~__~ III III o ro- rl I( QJ P< > ...t . H lr Q ::3 l:l1.Q H ~ ::3 ...t il 1:1 rlI III 1('5 N~ N OJ OJ QJ H :g ,:t: +I Q) I( Q) P< H +I . tIl l:l1 H '0 ::3 I:I.Q N rlI :>. . QJ ~rl <<t' e ~~ ~ '-...- M <<t' o ro- rl "Ci QJ ~ QJ OJ QJ ,Q %' s OJ H QJ P, to P, QJ H QJ ..c: ~ -)[;1 ~ ~ If! , 'lei ,oi i~1 " H q II ti fI II 11 H ':I ~ I " ti iI \1 II rl " n II II II Ii II il !i I .", .-,--- ~.; ....~......~ . < O' ~, - '.. ~'ij1'<'~-~!<r . , .... 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 PLAINTIF COURT OF COMMON PLEAS CIVIL DIVISION Countrywide Home Loans, Inc. Vs. No. 00-6883-C:lvil Kermit W. Moyer (Mortgagor and Real Owner) Lisa A. Moyer (Mortgagor and Real Owner) CUMBERLAND COUNTY All those two certain lots of ground situate in the Borough of Wormleysburg, formerly East pennsboro Township, County of Cumberland and Commonwealth of Pennsylvania, numbered 76 and 77 in a Plan of Lots laid out by V. Hummel Berhans and known as IIEdgewater Plan No. 211 as amended to show Walnut Street proj ected to center of Tract: of IIN.C.R.R. CO.II, as Plan being recorded in Cumberland County Deed Book D, Volume 6, Page 559,said Lots being more particularly bounded and described as follows, to wit: BEGINNING at a point on the western side of Second Street, 50 feet above the corner of Walnut Street; thence up along said Second Street, 50 feet to the line of Lot No. 73; thence westwardly long line of Lot No. 78, 150 feet to Hill Alley; thence down along said Alley, 50 feet to the line of Lot No. 75; thence along line of said Lot eastwardly 150 feet to the place of BEGINNING. Having thereorL erected a one story brick frame dwelling numbered 204 2nd Street. Being known as 204 N. 2nd Street, Wormleysburg, PA 17043. Tax parcel #47-19-1588-151 .~ - U.~]~~~~~";'----" ,--" '" ~~~~""uio>~;j,,'oioo~i'IP"(;;--"--H' ....' idil~llW"~~= - ,-, ,:-,-',- ..~..,""-':-"""" . t, , II ..,. !,j J:i :;] i'l I; !~i L'I i ,; d " II !i il Ii ri "I d i q 'I fi [I U :i " " II 11 I' J il II i 2 0 n ,....<,< ~ cA - ',"1 - - ~~~6~~~- '$; ::;t ~'o -.s::: "t)ro ".. -J:-~"n- t~ "" p\~,::::;' ~ ~ S. t3 8.~f5UJ ~'1 I -"-1{-r1 jl'b \;0 C) ~C' ::;-J-" P2 -0 S-ri \ \J --r ,0 j~ :Jj:. 'z:.';(~ 80 - 0("11 ~ 6 ., _I -J ) ~ ~ l'V ~ JJ CJl '-< -C 1~t 8 ~ ~ ~ c:r:> 71 ,~'" ~, ~" ....-- I. I"~ '. . -- WRIT OF EXECUTION - (MORTGAGE FORECLOSURE) P.R.C.P. 3180-3183 and RULE 2357 Countrywide Home Loans, Inc. Plaintiff COURT OF COMMON PLEAS CUMBERLAND COUNTY, PA Vs. NO: 00-6883-Civil Kermit W. Moyer (Mortgagor and Real Owner) Lisa A. Moyer (Mortgagor and Real Owner) Defendant(s) WRIT OF EXECUTION (MORTGAGE FORECLOSURE) TO THE SHERIFF OF CUMBERLAND COUNTY, PENNSYLVANIA To satisfy the judgment, interest and costs in the above matter, you are directed to levy upon and sell the following described property (specifically described property below) : Premises: 204 N. 2nd Street, Wormleysburg, PA 17043 (see attached legal description) Amount Due Interest from 3/7/01 to Date of Sale at $13.79 per diem Total $83,918.68 $ $ Plus Costs as endorsed Clerk ~'< ' i:liH,; l;;ti"""";~.:."-\tifi~~~~;Jf~'-.i-A~il:Ii1i1ll'~i~~i~~M~"ti..":!*,~M",_"""'"",,,"""""i"'.';;;"-I!iIlllI'--''':''' J' -"'~~ ." ''''tlill!f ~~ -~ -~,' "" ^ ~'" ........ - I,! ~ 11 .- t ''I fl " 11 ri " " Ii II 'I , f li II fl II ,I fl [j ~ Ii I-l~ Il'I Q) I-l Il'I '" " ~~ 0 '<to II ["- 0 IZl .0: ..-l ["- I, OH ~ ..-l i ~~ .... .0: ..., t) Ill.-l H Q) Po Q) ~ "(j I'l Q) III BOl :> Q) Q) I 1"104 H I:>:: 0) 'n , I-l ~ 04:>- 'I:ll:>:: I-l 01 ..., , ..-l PoOl , 1"1 I-l t:l I-l Ol 01 Q) I 'n ~ m I'l'l:l M ::I 01::1 'I:l I-l Ul ~ III I'l 1"1 m :> Ii!; III 0 I-l-:;J 1'l.5 Q) 'n i 1"1 U 110 0 I-l IZl.... ::I U C\l III ,.Q I , 04 o I-l o u il 'n :>. '" 0 , 010 0) m ~ . 0) >< II <Xl ~~ ~ III 01 Ei I-l Ii!;..-l ~ <Xl III 01 III H 0 .0:..:: e \D ::- ..., 01 ~"" U '<to , 00 III I-l..., C\l ~ 0 ~ Ul 0 o I-l 0) C\l C\l H 0 EiU 0) ~~ I:>:: 01 Q) ~~ 'I:l o III fa' . 'n ~ "" 01 ~ ~ I-l ..., Ul P, Q) I-l 1"1 I-l Ul :>'0) 110 0 Q) Q) 1"11:>:: ..., o :>. H::;:: H I-l III 1"1 !3 ::;::~ u~ "(j Q) ~~ ~ ~ .r:: 0 . 'd ~ U :s: . ...,.0: 110 Q) ri 'n III 'rl e .~ '" 0) 04 ;.; ~L '.<_ _ ",~__"",~ ~_"_H, '''''-"_ ,,-~ " >", >"'~~..^~ ," 'C'" '..I ." ,,~ -~'f'~-~' ~~ ~,~ ~ I J. ."'~im"" .. > .- 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 PLAINTIF COURT OF COMMON PLEAS CIVIL DIVISION Countrywide Home Loans, Inc. Vs. No. 00-6883-civil Kermit W. Moyer (Mortgagor and Real Owner) Lisa A. Moyer (Mortgagor and Real Owner) CUMBERLAND COlillTY All those two certain lots of ground situate in the Borough of Wormleysburg, formerly East pennsboro Township, County of Cumberland and Commonwealth of Pennsylvania, numbered 76 and 77 in a Plan of Lots laid out by V. Hummel Berhans and known as "Edgewater Plan No. 2" as amended to show Walnut Street projected to center of Tract of "N.C.R.R. Co.", as Plan being recorded in Cumberland County Deed Book D, Volume 6, Page 559, said Lots being more particularly bounded and described as follows, to wit: BEGINNING at a point on the western side of Second Street, 50 feet above the corner of Walnut Street; thence up along said Second Street, 50 feet to the line of Lot No. 73; thence westwardly long line of Lot No. 78, 150 feet to Hill Alley; thence down along sa.id Alley, 50 feet to the line of Lot No. 75; thence along line of said Lot eastwardly 150 feet to the place of BEGINNING.Having thereon erected a one story brick frame dwelling numbered 204 2nd Street, Being known as 204 N. 2nd Street, Wormleysburg, PA 17043. Tax parcel #47-19-1588-151 ~~~.w~~~~Mill,l!!;II~lilI'~jiiii~~~~~~-'iill ~ ... "WIiIi<<'iliiI,r1 ~::Wlilill7" , .-- _. . 0 C> () C ..,1 ;;::: ::J: ~$~ pg iW, ".. ;:0 ';:0 I -nfTl ~ W ;09 '-.Jc, ;.:::0 -+-r" -0 X-rl ~8 ::II: 05 " - am - :;;! ~ N ~ ..J " ,-...- " . ,~ I"',. ~ ~..J " ~_l ~."...,....,~~ GOLDBECK, MCCAFFERTY & MCKEEVER By: Joseph A. Goldbeck, Jr. Attorney I.D. #16132 Suite SOO-The Bourse Bldg. 111 S. Independence Mall East Philadelphia, PA 19106 (21 S) h/.7-112/. ATTORNEY FOR PLAINTIFF COURT OF COMMON PLEAS CIVIL DIVISION Countrywide Home Loans, Inc. Vs. No. 00-6BB3-Civil Kermit W. Moyer (Mortgagor and Real Owner) Lisa A. Moyer (Mortgagor and Real Owner) CUMBERLAND COUNTY VERIFICATION OF NON-MILITARY SERVICE JOSEPH A. GOLDBECK, JR., ESQUIRE, hereby verifies that he is attorney for the plaintiff in the above-captioned matter, and that on information and belief, he has knowledge of the following facts, to wit: (a) that the defendants are 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 Act of Congress of 1940, as amended. (b) that defendant Kermit W. Moyer (Mortgagor and Real Owner), is over IB years of age, and resides at 22 Ashburg Drive,Mechanicsburg, PA 17055. (c) that defendant Lisa A. Moyer (Mortgagor and Real Owner), is over lB years of age, and resides at Present Whereabouts are Unknown. This statement is made subject to the penalties of lB Pa. C.S. Section 4904 relating to unsworn falsification to authorities. March 7, 2001 Bi!iiWii.a__Ja~'~ru'ljM~~'~~;i!'~l'J'IiiiiL~'!~i\t;;G,"~"i;1'~~~~i1~ -:il!tl. I, '.'~ '~~-1 ' '--'Iilllll C) ~ d, ~ ~~ ~ ~O ~ '%8 7~ "."'~' "' I" , :i !ii " o -n .-1 ;(, -n~,' .-,., -0 ,b,o ...:;:.. ~'1", ,~."-n (")6 :?-fr' - 9 ~ ~ " . ,. -, ;, - '*111 ''''''''''' , . Countrywide Home Loans, Inc. Plaintiff CUMBERLAND COUNTY COURT OF COMMON PLEAS CIVIL DIVISION Vs. Kermit W. Moyer (Mortgagor and Real Owner) Lisa A. Moyer (Mortgagor and Real Owner) Defendant(s) NO. 00-6883-Civil AFFIDAVIT PURSUANT TO RULE 3129.1 Countrywide Home Loans. Inc., Plaintiff in the above action, by its attorney, Joseph 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 204 N. 2nd Street. Wormleysburg. PA ~7043. 1. Name and address of owner(s) or reputed owner (s): Name Address (if address cannot be reasonably ascertained, please so indicate) Kermi t W. Mo.yer (Mortgagor and Real Owner) 22 Ashburg Drive Mechanicsburg. PA ~7055 Lisa A. Mo.yer 204 N. 2nd Street (Mortgagor and Real Owner) Wormle.ysburg. PA ~7043 (Present Whereabouts are Unknownl 2. Name and address of defendant(s) in the judgment: Name Address (if address cannot be reasonably ascertained, please so indicate) SAME AS ABOVE 3. Name and address of every judgment creditor whose judgment is a record lien on the real property to be sold: Name Address (if address cannot be reasonably ascertained, please so indicate) None 4. Name and address of the last recorded holder of every mortgage of record: Name Address (if address cannot be reasonably ascertained, please so indicate) . S' A D' " f C1ty Mortgage erv1ces. 1V1S1on 0 City National Bank of West Virginia. A National Banking Association 17748 S~ark Boulevard. #lQU Irvine. CA 926~4 ".......-~-. ~ '- I " I ,: ' ,- ^,^',-, _ .-,,- --.' _- ~i/ ,'....- $.: ~ I 5. Name and address of every other person who has any record lien on the property: Name Address (if address cannot be reasonably ascertained, please so indicate) NQne 6. Name and address of every other person who has any record interest in the property and whose interest may be affected by the sale: Name Address (if address cannot be reasonably ascertained, please so indicate) ~umberland Coun~ Dept. of DomAS tic Relations P.O. Box 320 Carlisle. PA 17013 pa Dept. of Public welfare Bureau of Child Support Enforcement Health and Welfare Bldg. Room 432 P.O. Box 2675 Harrisburg. PA 17105 7. Name and address of every other person of whom the plaintiff has knowledge that has any interest in the property that may be affected by the sale: Name Address (if address cannot be reasonably ascertained, please so indicate) NQne 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. #4904 relating to unsworn falsification to authorities. March 7, 2001 ~.' Jw~i-'i'.r;!d"-1:\!_~~Ii1;,,*~N!'4!o~;I;g;i~~..4,,#~j@:5~~'ilI1!i~' ~~~. ' - ~ ~-- 1iW" ~'illi__Li , -'-.' (') 0 ~ ~ :x :::-3 "'tItP ",. .~-h'"n 9!!rn =0 ::0 'oF;; i~ I IJ:l -UC' r'") ( r::: ' ~C) !< -0 :r: -l~ i ~O :x C)'f' :;;8 7"(') Om ~ N ~ ...t -< ,-. II . , i , 11 't I f , " , '-~p~ ~"~, ~, t-M\iM~:-~_,i"vl' ~'. " - ~- b_ -,I t " ",:--l . , - .;2 _ - \- ' ,--_ ~ '~,', ._ ~. ..-~; 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 (;US) fi/.7-1 '\22 ATTORNEY FOR PLAINTIFF Countrywide Home Loans, Inc. Plaintiff CUMBERLAND COUNTY COURT OF COMMON PLEAS CIVIL DIVISION Vs. Kermit W. Moyer (Mortgagor and Real OWner) Lisa A. Moyer (Mortgagor and Real OWner) Defendant(s) NO.00-6883-Civil NOTTeR OF RHRRIFF' R RAT,R OF RF.AT, F.RTATF. TO: Kermit W. Moyer (Mortgagor and Real OWner) 22 Ashburg Drive Mechanicsburg, PA 17055 THIS FIRM IS A DEBT COLLECTOR ATTEMPTING TO COLLECT A DEBT AND ANY INFORMATION OBTAINED WILL BE USED FOR THAT PURPOSE. IF YOU HAVE PREVIOUSLY RECEIVED A DISCHARGE IN BANKRUPTCY, THIS IS NOT AND SHOULD NOT BE CONSTRUED TO BE AN ATTEMPT TO COLLECT A DEBT, BUT ONLY ENFORCEMENT OF A LIEN AGAINST PROPERTY. Your house (real estate) at 204 N. 2nd street. Wormleysburg. p~ 17043. is scheduled to be sold at the Sheriff's Sale on June 6. ~ at 10:00 a.m., in Cumberland County, Cumberland County Courthouse, Commissioners Hearing Room, 200 Floor, Carlisle, PA 17013 to enforce the court judgment of S83.9l8.68 obtained by Cnunt~ide Home Loans. Inc. (the mortgagee) against you. NOTICE OF OWNER'S RIGHTS YOU MAY BE ABLE TO PREVENT THIS SHERIFF'S SALE To prevent this Sheriff's Sale, you must take immediate action: 1. The sale will be cancelled if you pay to the mortgagee the Back payments, late charges, costs and reasonable attorneys Fees due. To find out how much you must pay, you may call: (215) 627-1322 2. You may be able to stop the sale by filing a petition asking the Court to strike or open the judgment, if the judgment was improperly entered. You may also ask the Court to postpone the sale for good cause. 3. You may also be able to stop the sale through other legal proceedings. .~ ..~ .- ' You may need an attorney to assert your rights. The sooner you contact one, the more chance you will have of stopping the sale. (See notice on page two on how to obtain an attorney.) YOU MAY STILL BE ABLE TO SAVE YOVR PROPERTY AND YOU HAVE OTHER RIGHTS EVEN IF THE SHERIFF'S SALE DOES TAKE PLACE. 1. If the Sheriff's Sale sold to the highest bidder. calling (2JS) 627-11/.2 is not stopped, your property will be You may find out the price bid by 2. You may be able to petition the Court to set aside the sale if the bid price was grossly inadequate compared to the value of your property. 3. The sale will go through only if the buyer pays the Sheriff the full amount due in the sale. To find out if this has happened, you may call the Sheriff's office at (717) /.40-6190. 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 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 this 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 proposed schedule of distribution of the money bid for your house will be prepared by the Sheriff within 30 days of the 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 posting of the Schedule of Distribution. 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 Bar Association 2 Liberty Avenue Carlisle, PA 17103 (800) 990-9108 Legal Services, Inc. 8 Irvine Row Carlisle, PA 17103 (717) 243-9400 . ~""'~~'L';' II};';'-;;-"'"';:!,; , iIJ_~jniT~~:lf-IH~__~~"~j,.Biti!:<iii'ii'~J~~J~.'i!"';ii,jj~""i-\i~~ .: -,~- " lIiImm.II~l[:l!.:Vllr-~' ~~I~:2~'~b "~ ~ n c::- :-0&3 1$ ;S~ ~O ~D $.'0 ~ =< c- O .~ ~ fl1 "_.~~ o ::J: """ :::0 I l.O -0 ::r.: ::;: ~;'i ,;YifJJ ::;:;rn ,"/'.:.19 l~_) ".!,. ~J(~ 0';;1, ::;;! ::tJ -< - .. Ii, I, !~ !! . .. I-: I' Ii:! I',','. Ii,:.,: f: II Ii' lh ,i'! " -"1~t~'" ..J 1_ ~.... I ,- ,- ..... iirnc THE PATRIOT NEWS THE SUNDAY PATRIOT NEWS Proof of Publication Under Act No, 587, Approved May 16,1929 Commonwealth of Pennsylvania, County of Dauphin} ss James L. Clark being duly sworn according to law, deposes and says: That he is the Acounts Receivable Manager of The Patriot News Co" a corporation organized and existing under the laws of the Commonwealth of Pennsyivania, 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 Th e Patriot-NRws and The Sundav Patriot-News newspapers of generai circulation, printed and published at 812 to 818 Market Street, in the City, County and State atoresaid; 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 24th day(s) of April and the 1 st and 8th day(s) of May 2001. 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 recordEld in ':;'~:,::~:~:i"' " Do~. " ,", fu'~'":"="~"P"'"t'I'""~'=mm COpy Sworn to am's 21st d of 2001 AD, S ALE #22 Notarial Seal Terry L. Russell, NolaI'{ Public HlltllsbUrg, Dauphin County My Commission Expire. June 6, 2Ot2 Member, PennsylVania Association at Notan.. My commission expires June 6, 2002 CUMBERLAND COUNTY 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 $ 186.?5 1.S0 188,:!5 Publisher's Receipt for Advertising Cost The Patriot News Co" publisher of The Patriot-News and The Sundav Patriot-News, newspapers of genl,rai circulation, hereby acknowledge receipt of the aforesaid notice and publication costs and certifies that the same 11ave been duly paid, By....""""""""..........,....""""""""""",.",.,.", ~.4 "" , ' ,BEAL ESTATE SALE No, 2.1 V@No,2000.6883 Counlrywlde Home , Loans,mc, vs ~e!mit Wo Moyer l..l~A.MoyeT Ally: ,JoS'pn A. GoJdbec~ "Jr, DEScRIPTION ALL THOSE two 'e~~i~ hJh of Sfounci :.lll1J.lt' 10 , the BotQuSb of ~'~.onnl~\-\>i:ttl1'_g., torm.~d\' tJ.S.t , H:nn~l.mro JOlI'nsJlIp, COllilt''," pftumlX'rl.lnd ;md CummonwoIth .A, 0:1'lI'l_wtw_nLI. t1uinbt'lr.'d :":] <1lJd,,;7 in .1 Plan o( Lol.:. l:lid Ol.,lt br Y. Hummd "fh:r1iJns and \...ncl\l'll'<l~ "t:~i2,,~1\',1ter; PI.lI1 \0, 2'; J~ , JlTit'ndt.'d to ,~bow \\'"lnui S!;~'t'r prilit:cil'd to_ t"nkr OJ' tort,ot ''-,\..C.R./{, ~o,~. ,J:> Plan .bdr(~ n.'(ordt.>d. In- Cumberi.lnd COlmlv D'2ed Book D, ,_ ,'uJumt' 6, P..ib~" S3\1, ~,1id L6b bt.ing mor~' ',fclrticu!.lrl,\' nOI.l.DJed Jnd Je':tmbt;d.)$ 10[10\\,<:, to II'it: ' ~[Gb;.ir~G' ~t ~ 'point UIl lh~ 1-\'~sl~'m ~id\J oj St::OOIl'd 5tred"S{1 il'd ,1DO\(> tbe (OJ,ll'r ofW"ITlu\ ~lil't:t; lhl'nt~:' up Jlong ~3id 3~,,)nd 51rl'l.'t, 10 t'''-d tci'tht'urll' uf lO,t ~o<7;; thenn'\'\'slll,lrdl!'Jlofli; .tir.'" ui Lol ~o, :S: '51) fl'd 10 Hill ,\\\~'\'; ti1l'i1C~' -qo\l'tt along ~1iJ ..\J1c,I, 'i0 f~d to lhc 1in~ of Lo! , ,;';Y..7Y. lhl.'l1ce J\tJn::; lint' Ilf ~,lil:) trJi e'l~\\\';ndh' , 150 f~d to thi: rlJ-;~ ot BrG!:\'\'[\C, fb'ifl~ :. : lh('~~qn, \'\"!-'((t.'d ;) <ope.~~ol'Y r.nrk {ramt,; dWl'mng 'minibl'M 2(4 2M Str~t.'t. ,..'tI:l'C k110WD a< 214 ~~, 2110. sired. ,:\\\JnnJ~'5Pur~,p), 1;'(14:\, i:J.ixp..r~~l Ri-)'9.1~8,g.15t . ,~ - I ~,~ .~.t...~1iM PROOF OF PUBLICATION OF NOTICE IN CUMBERLAND LAW JOURNAL (Under Act No. 587, approved May 16, 1929), P. 1.1784 STATE OF PENNSYLVANIA : ss. COUNTY OF CUMBERLAND : Roger M. Morgentha1, Esquire, Editor ofthe 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 officia11ega1 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: APRIL 27, MAY 4,11, 2001 Affiant further deposes that he is authorized to veritY 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. ~~ R er M. Morgenthal, Editor SWORN TO AND SUBSCRIBED before me this 11 day of MAY. 2001 ". NOTARIALSEAl . . L~ E. SNYDER,NoIaIy Public CarIl8Ie.IIonl. CumberIaniI ~ . "My CoIIu1Iis8i1l.I ExpiIIs'March 5, 200s .0' ~I- " ........c' -,- ~ J!!IWillifBh~~1..r:;I~lB:"jt,)j( "'_.-....~."' -'-'0 ~-"=-:, -....LiI ~~ REAL ESTATE SALE NO. 22 Writ #2000-6883 Civil CountIywide Home Loans, Inc. vs. Kennit W. Moyer and Lisa A. Moyer Ally.: Joseph A. Goldbeck. Jr. .All those two certain lots of ground sUuate In the Borough of Worm- leysburg, formerly East Pennsboro Township. County of Cumberland and Commonwealth of Pennsy\y'~- nia. nwnhered 76 and 77 in a Plan of Lots laid out by V. Hummel Berhans and known as "Edgewater Plan No.2" as amended to show Walnut Street projected to center of Tract of "N.C.RR. Co:'. as Plan be- ing recorded in Cumberland County Deed Book D. Volwne 6. Page 559. said Lots being more particularly bounded and described as follows, to wit: BEGINNING at a point on the western side of Second Street, 50 feet above the carner of Walnut Street: thence up along said Sec- ond Street. 50 feet to the line of Lot No. 73: thence westwardly long line of Lot No. 78, 150 feet to Hill Alley; thence down along said Alley, 50 feet to the line of Lot No. 75: thence along line of said Lot eastwardly 150 feet to the place of BEGINNING. Having thereon erected a one story brick frame dwelling nwnbered 204 2nd Street. Being known as 204 N. 2nd Street. Wormleysburg, PA 17043. Tax parcel #47-19-1588-151. -~IW .h ,~- - . ~- t: -L H~ > ~ '=@I.., 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 (/.15) fi27-13/.2 ATTORNEY FOR PLAINTIFF COURT OF COMMON PLEAS Countrywide Home Loans, Inc. Vs. CUMBERLAND COUNTY CIVIL DIVISION NO. 00-6883-Civil Ker.mit W. Moyer (Mortgagor and Real Owner) Lisa A. Moyer (Mortgagor and Real Owner) CF.RTTFTCATTON JOSEPH A. GOLDBECK, JR., ESQUIRE, hereby states that he is the attorney for the Plaintiff in the above captioned matter and that the premises are not subject to the provisions of Act 91 because it is: ( ) an FHA Mortgage ( ) non-owner occupied () vacant (X) Act 91 procedures have been fulfilled This certification is made subject to the penalties of 18 Pa. C.S. i!l 4.904 relating to unsworn falsification to authorities. . oldbeck, Jr. or Plaintiff iII~.:;,,,~I,,~~~. ~-'-~~tl""'"'"~~~li!!~hl>...m~.<ij~";' - .~ ^_.~ - -. -,~ - , ~ ~ ~,_ c.- " ~ -,'''"",'' '--,-. - ~,-y _, _,>,,~~,n, r= ,~"'.~_ -., ~ ~w. ~ ~e j% ~ "' ~. ~"- .-, t I,i) ! II I:: I! 'ii c::: ~ ..... .----;-. -n nip "" ':'i~\q '2,(:) ~~ ~ 00 :$ "5('f', _ A ;. ~ - :s ~ \ 0$) _I ""I..;~, J~_ <" '. -;0,-, GOLDBECK McCAFFERTY & McKEEVER BY; Joseph A. Goldbeck, Jr. Attorney I.D.#16132 Suite 500 - The Bourse Bldg. III S. Independence Mall East Philadelphia, PA 19106 215-627-1322 Attorney for Plaintiff COUNTRYWIDE HOME LOANS INC. 7105 Corporate Drive PTX B-35 PIano, TX 75024-3632 Plaintiff vs. KERMIT W. MOYER AND LISA A. MOYER (Mortgagors and Real Owners) 204 North Second Street Wormleysburg, PA 17043 Defendants IN THE COURT OF COMMON PLEAS OF CUMBERLAND COUNTY CIVIL ACTION - LAW ACTION OF MORTGAGE FORECLOSURE Term No. 00-6883 CIVIL TERM CERTIFICATE OF SERVICE PURSUANT TO Pa.R.C.P. 3129.2(0) (2) Joseph A. Goldbeck, Jr., Esquire, Attorney for Plaintiff, hereby certifies that service on the Defendants of the Notice of Sheriff Sale was m~by: (~ Personal Service by the Sheriff's Office/competent adult (copy of return attached) Pet( 1::'1I'll:'1 (!.shenffr oepT'Dfl If/I tj 101 ( ~ Certified mail by Joseph A. Goldbeck, Jr. (original green Postal return receipt attached) . I<'E:Am"Vtf. moIER.. Certified mail by Sheriff's 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 Sheriff's Office to Attorney for Defendant(s) of record. I~ERVICE WAS ACCOMPLISHED BY COURT ORDER. (<lIIII( , Premises was posted by Sheriff's Office: return attached) .fer t::1tTH1 Q. Sh~r:t:(S Dt.(JT Ofl ( ) Certified Mail & ordinary mail by Sheriff's attached) . Certified Mail & ordinary mail by Joseph A. Goldbeck, Jr. (original receipt(s) for Certified Mail attached). trtiJ . (copy of Ifll 01' Office (copy of return (r) 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. _~nm I ,',j j ~ __."..~._"__,'i.~__,_~__., , 2. Article Number ,,,"_ ., lill. ,4!~1I~ ms Li!'\Il i!ai!1I lIS'lL 3, .seniice Type CERTIFIED MAIL 4. Restricted Delivery? (Extra Fee) 1. Article Addressed to:_ DVes,,_, _' .'.:,. KERMIT W. MOYER . . 204 North Second Street, wormleysburg, PA 17043 iT J:J i, I "' ii" ..,I ,w r ''''''''''lit'''." o Agen1 . 0 Addressee , D- ON' 1 ; .!'1'f"'{ CUMBERLAND ".0 """~_"" ~~,.,"~.,,' , ", "'~~-'",,-,-- 710b ~575 129~ 2820 n58~ , TO: LISA A. MOYER 204 North Second Street Wormleysburg, PA 17043 CUMBERLAND SENDER: REFERENCE: GOLDBECK MCCAFFERTY & MCKEEVER. March 7, 2001 MOYER,KERMIT pWD-OB3B PS Form 3800 June 2000 6/ 6/01 . RETURN Postage RECEIPT C rt"f" d F SERVICE e r Ie ee Return Receipt Fee Restricted Delivery Total Postage & Fees W. / lit...",'! US Postal Service Receipt for Certified Mail -' ::/ POSTMA.RK OR DATE No Insurance Coverage' ProvIded Do Not Use for InternaUonal Mail ;..~"#-:,~ 110b"~515 1294 2820 0591 TO: KERMIT'W.1\iiOYER 204 North Second Street, Wormleysburg, PA 17043 CUMBERLAND SENDER: REFERENCE: GOLDBECK McCAFFERTY & MCKEEVER 0 March 7, 2001 MOYER,KERMIT CWD-OB3B PS Form 3800. June 2000 6/ 6/01 - W. / RETURN Postage RECEIPT Certified Fee SERVICE Return Receipt Fee Restricted Delivery _n._. . Total Postage & Fees , 1//,.,:', '. ....' ift,.,.'\ -'\"> US Postal Service POSTMARK OR DATE-' ::~.: ' j,--)'. 1 Receipt for , Certified Mail 1 ; 1 No Insurance Coverage Provided Do Not Use for International Mail .no I.. . - :3 <J <n .... 0 ~ 3 0 w ~ -< '" ..... ..... 0 ,... }- ~ ~ ~ I '" '" '" 0 ~ ~ ~ ,I I o o 3 '0 ! .. 0- '< .... 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Iii 'g g[ii; ~~g:~ ~Q, 3 ~ DODD Ji . 0::10;0 1Il.-.:<llGlo o:t '-iac ;:)'~ g_ i3 I.~ ~ :J $\ 0.:;:0 ~,6 ~~ @ g" -s: ;l>:J ;(j ~~B ~ :t;!!!..n Q' ~~ $: -c . . 3 .. ~ '" " . . <5' .- _C a;~ 0 DO c "'. Om z o. 5' oil. ~ . ~ ~ ;;- il - '" c Ji'" il '" .'" o=;: ~;;u ~~ 0-1;; ..~ ~~ ~ "" iF8 2:~~~ (1).0'0 x 'Tlcn ~;;;!;. ~o 2:~3 a:a-o -ncn li?'1J g (p ~ lI:::z: Cb~ @.oa 03' 8 ~=;: ;;r{g:ii~ ~~ijj (II (J) D) m =~ @::J ::s (J) Jl:D ~.Q.. 2.SO a.. ([I 0 ~ ... '" . 3 .~ "I 1;:"" J -',",'o"'c.,,", "'.....--~fI!!fjj;" GOLDBECK McCAFFERTY & McKEEVER BY: Joseph A. Goldbeck, Jr. Attorney I.D.#16132 Suite 500 - The Bourse Bldg. III S. Independence Mall East Philadelphia, PA 19106 215-627-1322 Attorney for Plaintiff COUNTRYWIDE HOME LOANS INC. 7105 Corporate Drive PTX B-35 PIano, TX 75024-3632 IN THE COURT OF COMMON PLEAS OF CUMBERLAND COUNTY CIVIL ACTION - LAW Plaintiff :ACTION OF MORTGAGE FORECLOSURE vs. KERMIT W. MOYER AND LISA A. MOYER (Mortgagor(s) and Record Owner (s) ) Term No. 00-6883 CIVIL TERM 204 North Second Street Wormleysburg, PA 17043 Defendant(s) SUPPLEMENTAL AFFIDAVIT PURSUANT TO RULE 3129 COUNTRYWIDE HOME LOANS INC., Plaintiff in the by its attorney, Joseph A. Goldbeck, Jr., Esquire, of the date the praecipe for the writ of execution following information concerning the real property above action, sets forth as was filed the located at: 204 North Second St~eet, Wormleysburg, PA 17043 1. Name and address of Owner(s) or Reputed Owner(s): KERMIT W. MOYER 204 North Second Street Wormleysburg, PA 17043 LISA A. MOYER 204 North Second Street Wormleysburg, PA 17043 2. Name and address of Defendant(s) in the judgment: LISA A. MOYER 204 North Second Street ~- I. ,,1"- ~ '_ '->' h' " "','"' :fi{&! . Wormleysburg, PA 17043 KERMIT W. MOYER 204 North Second Street Wormleysburg, PA 17043 3. Name and last known address of every judgment creditor whose judgment is a record lien on the property to be sold: PA DEPT. OF PUBLIC WELFARE-BUREAU OF CHILD SUPPORT ENFORCMENT-HEALTH & WELFARE BLDG., ROOM 432 P.O. BOX 2675 HARRISBURG, PA 17105 CUMBERLAND CO. DEPT. OF DOMESTIC RELATIONS P.O. BOX 320 CARLISLE, PA 17013 4. Name and address of the last recorded holder of every mortgage of record; A DIVISION OF CITY CITY MORTGAGE SERVICES NATIONAL BANK OF WV, A NATIONAL BANKING ASSOC. 17748 SKYPARK BOULEVARD, #100 IRVINE, CA 92614 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. CARLISLE SUBURBAN AUTHORITY 240 Clearwater Drive Carlisle, PA 17013 - .". I"~, .~,- -.l~> J . (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 unsworn falsification to authorities DATED: March 21, 2001 BY ltii~j' =1 >~~.l1lliJ.2!1~~""~' L---'$l!.iliOm~<<~~"",,",i--' "l.'""-'"~""'-"'~'iIii- ......,.'M i . ' o -o~ QJr.~: .L-~ _.,' ~~'~2~ ~CJ )> zO >2 z =< . ~~" ,.- -- " ,~,- I:! I i r' , r:; ( ':i . " i I:i o ~ :.;:I x- -u :::l:1 f',) 0'''' ::c:,c') --'-'-::-;'.1 -..~ --r-, ~(i OiTl oc'-I' ?ii -< ::IT; r;." J:'" . ~ " '" ". ,~ "--" -.'-, "~, '. -'C,~ ..._ il:J -." -'~- .. PRAECIPE FOR WRIT OF EXECUTION - (MORTGAGE FORECLOSURE) P.R.C.P. 3180-3183 Countrywide Home Loans, Inc. Plaintiff COURT OF COMMON PLEAS CUMBERLAND COUNTY, PA Vs. NO: 00-6883 Kermit W. Moyer Lisa A. Moyer PRAECIPE FOR WRIT OF EXECUTION (MORTGAGE FORECLOSURE) Defendants TO THE OFFICE OF THE PROTHONOTARY: Issue writ of execution in the above matter: Amount Due Interest from 3/7/01 to sale date at $13.79 per diem Total $83,918.68 $ $ and CostB oldbeck, Jr. o The Bourse Bldg. S. dependence Mall East Philadelphia, PA 19106 Attorney for Plaintiff Note: Please attach description of property. ,.:LID;"'T"'Ja...~~~1 - ":'''L '" co co \0 I o o I!<o.o: OH ~~ 1'1..:1 ..:1>1 11ft/) lZi~ ~~ o - U>I ~~ o E-tU ~~ I'II>l =1'1 ~~ . ~ "-wr~lij~w.ilii~'"",,",,"ili.~i,i;;'l!iI' aliillitJ tl C H - rI.l C III o ..:I CD 6 = CD 'tl .~ .j.J g U rI.l :> H CD H >..CD o >.. :E:~ . :;: . .0: .j.J .... III B .~ CD ..:I loo: ~ ~Ql 1'1 H ~ :::t 1'1 rI.l o I!<o..-t o U CD E-t H H 0 ~I!<o CD I>l tll 011I Jl:. tll .j.J 1'1 H ~~ U~ a I1f "= '~"~ ~~~'~ililll .. '0 OJ rl 'r! Ii< III III o r- .-l .0: CD I1f :- .... - H tll Q H :::t tll.Q H rI.l :::t tl :2 "2 rI.l III .o:.r: tl ~~ OJ OJ OJ H '0 ~ - .j.J CD.o: CD I1f H .j.J - t/) tll H 'tl :::t C.Q N rI.l >.. . CD lZi..-t '" B o 0 N:;: '" '" o r- .-l '0 OJ ~ OJ OJ OJ .Q ~ S OJ H OJ P, <1l P, OJ H Q) ~ -"'fI "1" I.i i,'I" .1.'. J' li I " I " '1, I, ! ;j: II 't, ~. ... , .I 0_,,', L ,,- . , I~! ---" . 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 PLAINTIF COURT OF COm~ON PLEAS CIVIL DIVISION Countrywide Home Loans, Inc. Vs. No. 00-6883-Civil Kermit W. Moyer (Mortgagor and Real Owner) Lisa A. Moyer (Mortgagor and Real Owner) CUMBERLAND COUNTY All those two certain lots of ground situate in the Borough of Wormleysburg, formerly East Pennsboro Township, County of Cumberland and Commonwealth of pennsylvania, numbered 76 and 77 in a Plan of Lots laid out by V. Hummel Berhans and known as "Edgewater Plan No. 2" as amended to s.how Walnut;St,reet proj ected to center of Tract - of "N.C.R.R. Co.", as P],an being re'co.:tded in Cumberland County Deed Book D, Volume 6, Page 559, said Lots' being more particularly bounded and described as follows, to wit: BEGINNING at a point on the western side of Second Street, 50 feet above the corner of Walnut Street; thence up along said Second Street, 50 feet to the line of Lot No. 73; thence westwardly long line of Lot No. 78, 1'50. fe.et.to Hill Alley; thence down along E'aid Alley, 50 feet to the line of Lot No. 75; thence along line of said Lot eastwardly 150 feet to the place of BEGINNING.Having thereon erected a one story brick frame dwelling numbered 204 2"d Street:. Being known as 204 N. 2nd Street, Wormleysburg, PA 17043. Tax parcel #47-19-1588-151 ~;" ~::l,~~~~,~~ft~q\fll~t1!r~!f"","iUl'~'I.lm:::L.!l:tT 'i'~ ~' ....ll?~' "'0" 0' _ . ,/ \:!I I:;' i:i ;ii '!' I.: :j, ill b i i ,. I': I, i~ ii: ~: ii' " i': ~! ,11 Y 7'J (:J ~ ~ ~ ~ ~ ~ t {'q -0 t} "'- lU Iv ft :--.. .f/} ~ ~ ~ r- - ~ " , . 0 . 0 . s i.., ...... 0 ~ D I>? t.J . 0 0 0 :::::: ~ () 6"- C c 8 c: ''1''1 () () C ..0 -l:: ~ {J') ("- ~ / I , I -oU] rrt I"- l I I m,T; -0 E:'~l "') rJ~ Z::IJ W Z~. _'o:':l-'1 ~ CO "~ en"", ,-, , - & -<-,.,<:.' ";::;C) 0' , ~C) . ~ , .. ~ ... -0 -~ .or. " ~ ... ... ... ... J;C] 3 ~~.:;() ~12 :":=( J (SCt) ~ " ... :PC ~ "\ ~ , ---t " ~ . Z ~ ...., .... .... " =< ... ':f:t- <.11 -< o~~ , I,,,,~ ^,,~~d ' - ",',~"-, ",,,; ",,"' ' ,,, ......'''''''''~"'''''';'!i>;, , .. Countrywide Home Loans, Inc. Plaintiff : CUMBERLAND COUNTY COURT OF COMMON PLE1\.S CIVIL DIVISION Vs. Kermit W. Moyer Lisa A. Moyer NO. 00-6883 Defendants AFFIDAVIT PURSUANT TO RULE 3129.1 Countrywide Home Loans. Inc., Plaintiff in the above action, by its attorney, Joseph 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 204 N. 2nd Street. Wor.m1eysburg. PA 17043. 1. Name and address of owner(s) or reputed owner (s): Name Address (if address cannot be reasonably ascertained, please so indicate) Koar.mit W. Moyer 22 Ashburg Drive Mechanicsburg. PA 17055 Lisa A. Moyer 204 N. 2nd Street Wor.mleysburg. PA 17043 2. Name and address of defendant(s) in the judgment: Name Address (if address cannot be reasonably ascertained, please so indicate) S"Mll AS ABOVE 3. Name and address of every judgment creditor whose judgment is a record lien on the real property to be sold: Name Address (if address cannot be reasonably ascertained, please so indicate) None 4. Name and address of the last recorded holder of every mortgage of record: Name Address (if address cannot be reasonably ascertained, please so indicate) City Mortgage Services. a Division of city National Bank of West Virginia. A National Banking Association 17748 Skypark BO\11evard. fil.~ IrvinA. CA 92614 C~rlisle Suburban Authority 240 Clearwater Drive Carlisle. PA 17013 ~ ~ , I......... L "'; ",-"-'." ".. ;1-~ " L' l~~~ .. 5. Name and address of every other person who has any record lien on the property: Name Address (if address cannot be reasonably ascertained, please so indicate) N'onli 6. Name and address of every other person who has any record interest in the property and whose interest may be affected by the sale: Name Address (if address cannot be reasonably ascertained, please so indicate) Cumberland County DElj;)t. of Domestic Relations P.O. Box 320 Carlisle. PA 17013 Pa DElj;)t. of Public Welfare Bureau of Chi1d S'llP.port RnforcetnAnt Health and Welfare Bldg. Room 432 P.O. Box 2675 Harrisburg. PA 17105 7. Name and address of every other person of whom the plaintiff has knowledge that has any interest in the property that may be affected by the sale: Name Address (if address cannot be reasonably ascertained, please so indicate) N'onli 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. e.s. #4904 relating to unsworn falsification to authorities. September 11, 2001 dbeck, Jr. Plaintiff .~'lH.ili'~H;~:t~<W;jK~'<11'~@"-"'M!'.i!#J1Jt~@fuI!liiI~tUilr .~_.;.,,-',,,. J'li!J!_'~iI'l1.i1i!iliS111i!IU ,; " ~ . (') 0 0 C -:'?" -n ;:get: en "., P1 [1"; -0 ;1 ,--, -:;:0--:1'" i'= 2r' c.' ',I ~';.' co ,......; -,=,~ T ~t) ~-~ :::,~-:) ~C': -- .. ~C) -"'- ~~~ c ,,- z :;;: :::;:! (n :D -< -, :i.., <; !i . ~i ,{ 1 '- ~._- I , ~- ". '",;. _'Ii__. ;",,,,~:i.<,' "',~ oi,- ,. ., rIll,i' 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 (21 '1) 6/.7-] 3?? ATTORNEY FOR PL1UNTIFF COURT OF COMMON PLEAS Countrywide Home Loans, Inc. Vs. CUMBERLAND COUNTY CIVIL DIVISION NO. 00-6883 Remit W. Moyer Lisa A. Moyer CERTIFICATION JOSEPH A. GOLDBECK, JR., ESQUIRE, hereby states that he is the attorney for the Plaintiff in the above captioned matter and that the premises are not subject to the provisions of Act 91 because it is: ( ) an FHA Mortgage () non-owner occupied ( ) vacant (X) Act 91 procedures have been fulfilled This certification is made subject to the penalties of 18 Pa. C.S. ~ 4904 relating to unsworn falsification to authorities. dbeck, Jr. r Plaintiff ~"t~.'F..fu<iA"".~i\i;ID""~~!EufJ'~~J<.~-/E;I~~.1r >~~...... ...'"",.; L. ",-,'of 'J~" ',;. o C ?> -0-0.. f'TjQ:J Zll. -00 ::0 ""-C-oo C-<J "",:,. ;::s;;"'i~ ~,,-i :!Eo ~(- .:P-C ;z: ~ J, - UJ ""' ~'i) II ,-1 :1 :1 I II l; fl! '- I' ., I , a o -;''/ &:l ;ry "U <:::> ~- ~,:::' ~:9 -0 -"",. --ko. .~:;~~;Q -.,,, " 3j~~1 o:-! ~> ::0 "< ;r:;- I 'J.li~i....L .- . ' ,;' ",.'~. " '-'~,' ," "" ~'-~, ~ ~'U~!( " 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 (/.15) 627-1322 ATTORNEY FOR PLAINTIFF Countrywide Home Loans, Inc. CUMBERLAND COUNTY : COURT OF COMMON PLEAS CIVIL DIVISION Plaintiff Vs. Kermit W. Moyer Lisa A. Moyer NO.00-6883 Defendants NOTTCF. OF SHF.RTFF' S SAT,F. OF RF.AJ, F.STATE TO: Kermi t W. Moyer 22 Ashburg Drive Mechanicsburg, PA 17055 THIS FIRM IS A DEBT COLLECTOR ATTEMPTING TO COLLECT A DEBT ~~ ANY INFORMATION OBTAINED WILL BE USED FOR THAT PURPOSE. IF YOU HAVE PREVIOUSLY RECEIVED A DISCHARGE IN BANKRUPTCY, THIS IS ~)T AND SHOULD NOT BE CONSTRUED TO BE AN ATTEMPT TO COLLECT A DEBT, BUT ONLY ENFORCEMENT OF A LIEN AGAINST PROPERTY. Your house (real estate) at 204 N. 2nd Street. Worm1ey..burg. Pi\ 17043. is scheduled to be sold at the Sheriff's Sale on Dec...mber 5. 2001 at 10:00 a.m., in Cumberland County, Cumberland County Courthouse, Commissioners Hearing Room, 2nd Floor, Carlisle, PA 17013 to enforce the court judgment of S83.918.68 obtained by Count~ide Home Loans. Inc. (the mortgagee) against you. NOTICE OF OWNER'S RIGHTS YOU MAY BE ABLE TO PREVENT THIS SHERIFF'S SALE To prevent this Sheriff's Sale, you must take immediate action: 1. The sale will be cancelled if you pay to the mortgagee the Back payments, late charges, costs and reasonable attorneys Fees due. To find out how much you must pay, you may call: (215) 627-1322 2. You may be able to stop the sale by filing a petition asking the Court to strike or open the judgment, if the judgment was improperly entered. You may also ask the Court to postpone the sale for good cause. 3. You may also be able to stop the sale through other legal proceedings. I 1-., I, ....1..... ,', J 'I-'~ ',,' ..~_ " ""~",,, ~~~ <~ t\;..,,,' . 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 on page two on how to obtain an attorney.) YOU MA.Y STILL BE ABLE TO SAVE YOUR PROPERTY AND YOU HAVE OTHER RICUi'l'S. EVEN IF THE SHERIFF'S SALE DOES TAKE PLACE. 1. If the Sheriff's to the highest bidder. (7.15) 67.7-] 17.7.. Sale is not stopped, your property will be sold You may find out the price bid by calling 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 yom:' property. 3. The sale will go through full amount due in the sale. may call the Sheriff's office only if the buyer pays the Sheriff the To find out if this has happened, you at (717) 240-6190. 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 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 this 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 proposed schedule of distribution of the money bid for your house will be prepared by the Sheriff within 30 days of the 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 posting of the Schedule of Distribution. 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 H1WE A LAWYER OR CANNOT AFFORD ONE, GO TO OR TELEPHONE THE OFFICE LISTED BELOW TO FIND OUT WHERE YOU CAN GET LEGAL HELP. Cumberland County Bar Association 2 Liberty Avenue Carlisle, PA 17103 (800) 990-9108 Legal Services, Inc. 8 Irvine Row Carlisle, PA 17103 (717) 243-9400 ~~illh!'i~iii;1!f,@!idg\,i'4c~jf,Hl.iJI~~"-~,<<BK.:1i:,~if~2?dIl@:,~i!..MJ ~ ~~, <' " ~~ at.' ~ '"-.-...."" - .~) ,; ","' <' t! !;j ':1 ,ll I~i :', rj ;1 II " lj ! n " ;i rl ... ,," ,( \ i~'! il II II ~ ~ " I I 0 0 (J C ~'\.l ;e;: U) -oP'--' f"'1 m;:-::Y. z~H -0 , )rsL~ Zr;:: mqr"" , :r--: 0>.,.. <::0 ~~~S -<,,,' ~O ~9 :3 '~:,-~~ - "?~ .' ~-\..-) ;;:- QIT] Pc Z ::.-..,::1 -' ""'..; -< (J> =< . , ..IM' ~~ ~ " ..I, '"~ ,,' ,,'I, . ~~l;; Countrywide Home Loans, Inc. VS Kermit W. Moyer and Lisa A. Moyer In The Court of Common Pleas of Cumberland County, Pennsylvania Writ No. 2000-6883 Civil Term R, Thomas Kline, Sheriff, who being duly sworn according to law, states this writ is returned STAYED pursuant to instructions from Attorney Joseph Goldbeck, Jr. Sheriffs Costs: Docketing Surcharge Posting Handbills Law Library Prothonotary Share of Bills Mileage Levy Advertising Certified Mail Poundage Postpone Sale Law Journal Patriot News 30.00 30.00 15.00 .50 1.00 25.09 14.26 15.00 15.00 11.74 20.00 232.85 188.25 $598.69 paid by attorney 09-18-01 Sworn and subscribed to before me so~w: ~ ~. I ~,J~~"f"-e: ~~ This !'flY day of ~ 2001, A.D. ~ a ~UP;j Prothonotary R. Thomas Kline, Sheriff B~S~ Real Es te Deputy 1."'-0 t{ 339'13 ~, mOl.. .'",.~-~. I "'~. ~ " L, j I , " fuJ'n " . Countrywide Home Loans, Inc. Plaintiff CUMBERLAND COUNTY : COURT OF COMMON PLEAS CIVIL DIVISION Vs. l . Kermi t W. Moyer (Mortgagor and Real Owner) Lisa A. Moyer (Mortgagor and Real Owner) Defendant(s) NO. 00-6883-Civil AFFIDAVIT PURSUANT TO RULE 3129.1 Count~ide Home Loans. Inc., Plaintiff in the above action, by its attorney, Joseph 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 204 N. 2nd Street. Wormleysburg. PA 17043. 1. Name and address of owner(s) or reputed owner (s): Name Address (if address cannot be reasonably ascertained, please so indicate) Kermit W. Moyer (Mortgagor and Real Owner) 22 Ashburg Drive Mechanicsburg. PA 17055 Lisa A. Moyer 204 N. 2nd Street (Mortgagor and Real Owner) Wormlaysburg. FA 17043 (Present Whereabouts are UnknoWT~ 2. Name and address of defendant(s) in the judgment: Name Address (if address cannot be reasonably ascertained, please so indicate) SlIMw. AS ABOVE 3. Name and address of every judgment creditor whose judgment is a record lien on the real property to be sold: Name Address (if address cannot be reasonably ascertained, please so indicate) None 4. Name and address of the last recorded holder of every mortgage of record: Name Address (if address cannot be reasonably ascertained, please so indicate) . . .. f Cit.y Mortg"ge Serv1ces. A D1v1s1on 0 City National Bank of West Virginia. A National Banking Association 17748 Skypark Boulevard. 1I1LJl!l. Irvine. CA 92614 =-"'<" ,,~~&~,I '" L. 1.- ' '~," L, _ j;K', / 1 5. Name and address of every other person who has any record lien on the property: Name Address (if address cannot be reasonably ascertained, please so indicate) HQne 6. Name and address of every other person who has any record interest in the property and whose interest may be affected by the sale: Name Address (if address cannot be reasonably ascertained, please so indicate) Cumberland Count;y D~t. of Domes,tic Relations P.O. Box 320 Carlisle. PA 17013 Pa D~t. of Public Welfare Bur~au o~ Chi1d ~upport Enfarc8ment Health and Welfare Bl<%T. Re.om 432 P.O. Box 2675 Harrisburg. PA 17105 7. Name and address of every other person of whom the plaintiff has knowledge that has any interest in the property that may be affected by the sale: Name Address (if address cannot be reasonably ascertained, please so indicate) HQne 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. e.s. #4904 relating to unsworn falsification to authorities. March 7, 2001 ,'JldJ ~~ L...,~ , -L~ ~. ' " "!lii' I I 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 (21 S) 6:1.7-13:1.2 ATTORNEY FOR PLAINTIFF Countrywide Home Loans, Inc. Plaintiff CUMBERLAND COUNTY COURT OF COMMON PLEAS CIVIL DIVISION Vs. Kermit W. Moyer (Mortgagor and Real Owner) Lisa A. Moyer (Mortgagor and Real Owner) Defendant(s) NO.00-6883-Civi1 NOTICE OF SHERTFF I S SAT,E OF REAT, ESTATE TO: Kermi t W. Moyer (Mortgagor and Real Owner) 22 Ashburg Drive Mechanicsburg, PA 17055 THIS FIRM IS A DEBT COLLECTOR ATTEMPTING TO COLLECT A DEBT AND ANY INFORMATION OBTAINED WILL BE USED FOR THAT PURPOSE. IF YOU HAVE PREVIOUSLY RECEIVED A DISCHARGE IN BANKRUPTCY, THIS IS NOT AND SHOULD NOT BE CONSTRUED TO BE AN ATTEMPT TO COLLECT A DEBT, BUT ONLY ENFORCEMENT OF A LIEN AGAINST PROPERTY. Your house (real estate) at 204 N. 2nd Street. Worm1p~sburg. PA 17043. is scheduled to be sold at the Sheriff's Sale on June 6. ~ at 10:00 a.m., in Cumberland County, Cumberland County Courthouse, Commissioners Hearing Room, 200 Floor, Carlisle, PA 17013 to enforce the court judgment of $83.918.68 obtained by Countrywide Home Loans. Inc. (the mortgagee) against you. NOTICE OF OWNER'S RIGHTS yOU MAY BE ABLE TO PREVENT THIS SHERIFF'S SALE To prevent this Sheriff's Sale, you must take immediate action: 4. The sale will be cancelled if you pay to the mortgagee the Back payments, late charges, costs and reasonable attorneys Fees due. To find out how much you must pay, you may call: (2151 627-1322 5. You may be able to stop the sale by filing a petition asking the Court to strike or open the judgment, if the judgment was improperly entered. You may also ask the Court to postpone the sale for good cause. 6. You may also be able to stop the sale through other legal proceedings. '.l. _~.,I, ,~ I ; I,~ '""'-~" .= -" ~ 'u.m,j ~ . ( 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 on page two 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 TAKE PLACE. 1. If the Sheriff's Sale sold to the highest bidder. calling (2]5) 6?7-13?? is not stopped, your property will be You may find out the price bid by 2. You may be able to petition the Court to set aside the sale if the bid price was grossly inadequate compared to the value of your property. 3. The sale will go through only if the buyer pays the Sheriff the full amount due in the sale. To find out if this has happened, you may call the Sheriff's office at (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 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 this 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 proposed schedule of distribution of the money bid for your house will be prepared by the Sheriff within 30 days of the 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 posting of the Schedule of Distribution. 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 Bar Association 2 Liberty Avenue Carlisle, PA 17103 (800) 990-9108 Legal Services, Inc. 8 Irvine Row Carlisle, PA 17103 (717) 243-9400 AIl'~ " " { " . .' .;- '.';",<"-"',:", "<--':.'0 '." "iIli;l . 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 PLAINTIF COURT OF COMJvION PLEAS CIVIL DIVISION Countrywide Home Loans, Inc. Vs. No. 00-6883-Civil Kermit W. Moyer (Mortgagor and Real Owner) Lisa A. Moyer (Mortgagor and Real Owner) CUMBERLAND COUNTY All those two certain lots of ground situate in the Borough of Wormleysburg, formerly East Pennsboro Township, County of Cumberland and Commonwealth of Pennsylvania, numbered 76 and 77 in a plan of Lots laid out by V. Hummel Berhans and known as "Edgewater Plan No. 2" as amended to show Walnut Street projected to center of Tract of "N.C.R.R. Co.", as Plan being recorded in Cumberland County Deed Book D, Volume 6, Page 559, said Lots being more particularly bounde:d and described as follows, to wit: BEGINNING at a point on the western side of Second Street, 50 feet above the corner of Walnut Street; thence up along said Second Street, 50 feet to the line of Lot No. 73; thence westwardly long line of Lot No. 78, 150 feet to Hill Alley; thence down along said Alley, 50 feet to the line of Lot No. 75; thence along line of said Lot eastwardly 150 feet to the place of BEGINNING.Having thereon erected a one story brick frame dwelling numbered 204 2nd Street:. Being known as 204 N. 2nd Street, Wormleysburg, PA 17043. Tax parcel #47-19-1588-151 ~I~- ~ -. L "~ ~-\', . .. WRIT OF EXECUTION and/or A IT ACHMENT COMMONWE;AL TH OF I"ENNSYL VANIA) COUNTY OF CUMBERLAND} TO THE SHERIFF OF Cumberland NO. OO-fiRRl CIVIL liSt--'lJWn CIVIL ACTION - LAW COUNTY: To satisfy the debt, interest and costs due Count:r::ywide Homes Loans. Inc PLAINTIFF(S) from Keonit W. Moyer (Mortgagor and Real CMner) Lisa A. Moyer (Mortgagor and Real Owner) DEFENDANT(S) (1) You are directed to levy upon the property of the defendant(s) and to sell Sae J\t-t-A",herl r"'-gil1 DeRC!ript-ion . . :i}')l(:ll', ',:,t,,; ,j ,':~ \' i (2) You are also directed to attach the property of the defendant(s) not levied upon in the possession of __ " ',"~ "-""" --~,,,,,,,,,,,~,,,,~,,,." ,1i,.:' "'.'" ;')",~i 1..' Irn(i:c . ..-...___."";_."GARNISHEE(S) as follows: ,""'i' . . ""i .r ""'$ ~I-.- "llIIi' 1 1\,.'.' .'! ',) ~Lf {"i, \. "'.1"1': ~ II\! and to notify the garnishee(s) that: (a) an attachment has been issued; (b) the garhisliee s} Is/are enjoined from paying any debt to or for the account of the defendant(s) and from delivering any property of the defendant(s) or otherwise disposing thereof; . , .. .,. .,.,.,l,ttr",: ' (3) If property of the defendant(s) not levied upon an subject to attachment is found inthe possession of anyone other than a named garnishee, you are directed to notify him/herthat he/she has been added as a garnishee and is enjoined as Blbove slated. Amount Due $83, Q18 6R From 3/7/01 to sale date at $13.79 Interest p€lr di@m Ally's Comm % Atty Paid 184.64 Plaintiff Paid L.L. ~nc': Due Prothy Other Costs 1.00 by: 'ision Date: March 9, 2001 I~ REQUESTING PARTY: Name Joseph A. Goldbeck, Jr. Esquire Address: 111 S Tnrl".f"'nrlAn"'e MAll F,ARt- Suite 500- - ThEi Bourse Bldg. Philadelphia, PA 19106 Allorney fOr) PJ aintiff Telephone: (215) 627-1322 Supreme Court ID No. ",~,,;. ;""'~" ~,~ , ~' " '~- .,",,' ,''''~''', j., lb'dL~~I~:j<llilii>-";lii\!!"~" ,~"~' J,i . l,". 'll' ,.' T in ~~ ""-~r' .. . ~ '. ~ '..; ~""i' '. REAL ESTATE SALE No. J~ >" ., Ull t1~ /3,;)001 the sheriff levied upon the d8terM:lIuhil Interest In the real orooprt\' "i''1~ted in tJ'CfVr>' o.:r~ 861~h... Cumberland County, Pd ""'own arm numbered as: Jot} 1\1.;2 "do 5+: tJ~and more tuu,'j d<sc.fioed onExhtbtt "A" flied with this writ and by this reference incorporated herein. BY:~~-' nata: rrL~ 13, "lOOI Vlt-!.,~ ^-l~, S NN3d -, ",/ ,'\'p,,, -, " ! \" ',) 101 Hd S€ I ZI HUH J~~~'.(\_"h, ItJGHrl:i S31<,J. j/Jl3.?!.:I.lO .., .---'^ - ~- - -. - '. ~~ ~ ~ CV1l CV1l w::;::::::J W liVil '\<:i.. \ '. - ,;'-i II I! II !I ~I 'I . l!''"''''"'' ~'- ' , ;,I' ,]. ",',,,"' '~'., ,~. " > 'ii;.jj GOLDBECK McCAFFERTY & McKEEVER BY: Joseijh 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 COUNTRYWIDE HOME LOANS INC. 7105 corporate Drive, PTX B-35 Plano, TX 75024-3632 Plaintiff vs. KERMIT W. MOYER AND LISA A. MOYER 204 North Second Street Wormleysburg, PA 17043 Defendants IN THE COURT OF COMMON PLEAS OF CUMBERLAND COUNTY CIVIL ACTION - LAW ACTION OF MORTGAGE FORECLOSURE Term No. 00-6883 CIVIL TERM CERTIFICATE OF SERVICE PURSUANT TO Pa.R.C.P. 3129.2{c) (2) Joseph A. Goldbeck, Jr., Esquire, Attorney for Plaintiff, hereby certifies that service on the Defendants of the Notice of Sheriff Sale was ma~ by: ( <<) Personal Service ~ the Sheriff's Oft;icef. <,_L_.i~ a.1u.LL (copy of return attached) .lre,....,. W.....'f&l'. ( ) Certified mail by Joseph A. Goldbeck, Jr. (original green Postal return receipt attached). ( Certified mail by Sheriff's 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 Sheriff's Office to Attorney for Defendant(s) of record. IF.~RVICE WAS ACCOMPLISHED BY COURT ORDER. (f'J Premises was postep by Sheriff' s Office/,-~.,....._"~_..~ UUU.L~ (copy of return attached) .USf'r Pt. f"r)oVtP-' ( ) Certified Mail & ordinary mail by Sheriff's 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 thestatem penalties provided by 18 P.S. Section 4904 are subject to the '" EEVER Jr. ~I -,;.~~.- ,-,---'-"-'-,,--'---------- ._--,," "".- - 7llliIb li!i?S1i!"111 libDli as 72 ToJa,lSA A. MOYER 204 North seQond Street, Wormleysburg, PA 17043 CUMBERLAND SENDER: REFERENCE: GOLDBECK MCCAFFERTY & MCKEEVER. september 11, 2001 MOYER, KERMIT W. I CWO-llll38 PS Form 3800 June 20fl-1 5/01 . 'I, RETURN Postage RECEIPT Certified Fee , SERVICE . ",',,;' '. Return Receipt Fee Restricted Delivery Totgtt J:os!~ & Fees US Postal Service POSTMARK oil DATE }t }'. 5-- M l: ( -.~" f '~"'.. '. \':"~ ....,.,/ f \,,"'~ '~.:_'--;' " ~ ~-~2-, '41< Receipt for Certified Mail No Insurance Coverage Provided Do Not Use for International Mail -1-- . ~' ~--" u. ~,'" -~--,~-"".."",..-~c~ ~ Ii 1 cl " 7:Lm. li.5?i :L!'11f ItWJIf 1!tI,'1 TO: KERMIT W. MO~ER 22 AShburg DriVe Mechanicsburg, PA 17055 ! Cvf'(\"Btt-UlWD i SENDER: GOLDBECK McCAFFERT'I . McKEEVER- ! September 11, 2001 I: REFERENCE: 11 MOYER, KERMIT W. I .' 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" ~~ c u r~ " ..<>. u ~ ".,..1. - I:: ~ i! . . " ; !' ~ i ~ . " u " o ~ @ = " i 00009 o .. ~ 8~~W~ o~~~:a n.~::(Zl ~ g, l) . 3 " booo'" l)O 1110 ~~~)> &aC~ ~o'" s;;; alCAo ... - a. as" Q;~3 ""(0 0"1) ~tlJ'O ::1:010 g(t::r _t/) fl) III < ~ ~ - Q,~ ~(I).....ro 8 ~:::;; dlO:bX."2..~~' lbO) ell:=;'" :::OL$.5. ~~.~ CD Ol~ -~ P. T ~ 3 . iif , \ ,~,,<-- ~-~ 't,~ ,,~ ;'~;:o__ Countrywide Home Loans, Inc, VS Kermit W, Moyer and Lisa A. Moyer In The Court of Common Pleas of Cumberland County, Pennsylvania Writ No. 2000-6883 Civil Term Richard E. Smith, DJputy Sheriff, who being duly sworn according to law, states that on Sept. 27, 2001 at 6:50 o'clock P.M., E.D.S.T., 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: Kermit W. Moyer, by making known unto Kermit Moyer personally, at 77 Autumn Lane, Enola, Pennsylvania, its contents and at the same time handing to him personally the said true attested copy of the same. Kenneth E. Gossert, Deputy Sheriff, who being duly sworn according to law, states that on Sept. 26, 2001 at 7:29 P.M., E.D.S.T., 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: Lisa A. Moyer, by posting a true copy on the premises located at 204 North 2nd Street, Wormleysburg, PA 17043 pursuant to a court order. Tirnothy Reitz, Deputy Sheriff, who being duly sworn according to law, states that on October 01,2001 at 9:05 P.M., E.D.S.T., he posted a true copy of the within Real Estate Writ, Notice, Poster and Description, in the above entitled action, upon the property o(Kermit W. Moyer and Lisa A. Moyer; located at 204 North 2n Street, WoTInl.eysburg,Pennsylvania, according to law. , . R, Thomas Kline, Sheriff, who beingd\lly swol!laccording to law' says he served the above Real Estate Writ, Notice, Poster and Description in the following manner: The Sheriff mailed a notice of the pendency of the action to one of the within named defendants to wit: Kermit W. Moyer, by regular mail to his last known address 7 Autumn Lane, Enola, P A 17025, This letter was mailed under the date of October 3, 2001 and never returned to the Sheriffs Office. R. Thomas Kline, Sheriff, who being duly sworn according to law says he served the above Real Estate Writ, Notice, Poster and Description in the following manner: The Sheriff mailed a notice of the pendency of the action to one of the within named defendants to wit: Lisa A. Moyer, by regular mail to her last known address of204 North 2nd St., Wormleysburg, PA 17043. This letter was mailed under the date ofOctober3, 2001 and returned to the Sheriffs Office on October 09, 2001 with reason checked "unclaimed." Sworn and subscribed to before me , ' This ' .'.. day of -., So Ans;V}IJ~ . ~ ?~!.iJ'1t"~-r-~~ R, ThomasKline, Sheriff 2001, A.D. . Prothonotary By~)~JMd:h Real Est te Deputy 'i---- .~ I~ .~I ~I' .. ' ,J " I~ " J,,,, .,,,,'<. _. , \', '-- ~ .l:\,1j..-<< Countrywide Home Loans, Inc. Plaintiff CUMBERLAND COUNTY COURT OF COMMON PLE,AS CIVIL DIVISION Vs. Kermit W. Moyer Lisa A. Moyer NO. 00-6883 Defendants AFFIDAVIT PURSUANT TO RULE 3129.1 Countrywide Home Loans. Inc., Plaintiff in the above action, rr~ its attorney, Joseph 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 204 N. 2nd Street. Wormleysburg. PA 17043. 1. Name and address of owner(s) or reputed owner (s): Name Address (if address cannot be reasonably ascertained, please so indicate) Kermit W. Moyer 22 Ashburg Drive Mechanicsburg. PA 17055 Lisa A. Moyer 204 N. 2nd Street Worm1eysburg. PA 17043 2. Name and address of defendant(s) in the judgment: Name Address (if address cannot be reasonably ascertained, please so indicate) SAME AS ABOVE 3. Name and address of every judgment creditor whose judgment is a record lien on the real property to be sold: Name Address (if address cannot be reasonably ascertained, please so indicate) :tI'mle 4. Name and address of the last recorded holder of every mortgagre of record: Name Address (if address cannot be reasonably ascertained, please so indicate) City Mortgage Services. a Division of City National Bank of West V~rginia. A National Banking Association 17748 S~ark Boulevard. #lQ.o. Irvine. CA 92614 Carlisle Suburban Authority 240 Clearwater Drive Carlisle. PA 17013 ",'~"" . "lllIi- ;" ~~ " '" ~' ~'''~~~" ' 5. Name and address of every other person who has any record lien on the property: Name Address (if address cannot be reasonably ascertained, please so indicate) HQna 6. Name and address of every other person who has any record interest in the property and whose interest may be affected ~( the sale: Name Address (if address carIrlot be reasonably ascertained, please so indicate) Cumberland County D~pt. of Domestic Relations P.O. Box 320 Carlisle. PA 17013 Pa Dept. of Public Welfare Bureau of Child SQpport Enforcement Health and Welfare BIQQ. Roam 432 P.O. Box 2675 Harrisburg. PA 17105 7. Name and address of every other person of whom the plaintiff has knowledge that has any interest in the propertjr that may be affected by the sale: Name Address (if address carIrlot be reasonably ascertained, please so indicate) HQna 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. #4904 relating to unsworn falsification to authorities. September 11, 2001 dbeck, Jr. r Plaintiff ,:'= ~ ~ ~,~L ,..I ~L "'''C' ~;ilk'ij NOV 2 0 2001 V' Joseph A. Goldbeck, Jr. A Professional Corporation Attorney I.D.#16132 Suite 500 - The Bourse Bldg. 111 S. Independence Mall East Philadelphia, PA 19106 215-627-1322 Attorney for Plaintiff COUNTRYWIDE HOME LOANS INC. IN THE COURT OF COMMON PLEAS 7105 Corporate Drive PTX B-35 OF CUMBERLAND COUNTY PIano, TX 75024-3632 Plaintiff CIVIL ACTION - LAW VS. ,ACTION OF MORTGAGE FORECLOSURE KERMIT W. MOYER AND LISA A. Term MOYER (Mortgagor(s) and Record No. 00-6883 CIVIL TERM Owner (s) ) 204 North Second Street Wormleysburg, PA 17043 Defendant(s) RULE AND NOW, a rule is entered upon Defendant(s) to show cause why the relief requested in Plaintiff's Motion for Reassessment of Damages should not be gra~e~ Rule returnable Date: 111)7/0 , . ~. J. .~ ~\~ ;w ~ " , ,,"" !""".., ~~. 1\IlllII11M-, ~r. , ~, "~ o~~"~c .-0\<"' "-.','.' "'~'.'RY Cq-- '__,T,:rc..;it~.l O~ NOV 28 j)H G: 2(: CUMEEHi'p,:\JU COUNTY PENNSYLvANIA ~.~ ~~ ..... '-.. """""""'~!!\ll~~~."'. ~"I'r~."^;~""--,:,! '".~~~,. '" ,,,"",' ", ,-' ,. ~ ~,Li ;, d..., .' ," ''-'-- '....:.d Joseph A. Goldbeck, Jr. A Professional Corporation Attorney I.D.#16132 suite 500 - The Bourse Bldg. 111 S. Independence Mall East Philadelphia, PA 19106 215-627-1322 12/ 5/01 Attorney for Plaintiff COUNTRYWIDE HOME LOANS INC. 7105 Corporate Drive PTX B-35 Plano, TX 75024-3632 Plaintiff IN THE COURT OF COMMON PLEAS OF CUMBERLAND COUNTY : CIVIL ACTION - LAW vs. :ACTION OF MORTGAGE FORECLOSURE KERMIT W. MOYER AND LISA A. MOYER 204 North Second Street Wormleysburg, PA 17043 Defendant(s) No. 00-6883 CIVIL TERM ORDER AND NOW, this day of , 2001, upon consideration of the Petition of COUNTRYWIDE HOME LOANS INC. for Reassessment of Damages, it is, ORDERED: That reassessment of damages is granted and Plaintiff's judgment is hereby reassessed to $98,330.14, plus interest and costs. BY THE COURT: J. :'1 c 10,/" >L" , . J:fi Joseph A. Goldbeck, Jr. A Professional Corporation Attorney I.D.#16132 Suite 500 - The Bourse Bldg. 111 S. Independence Mall East Philadelphia, PA 19106 215-627-1322 Attorney for Plaintiff COUNTRYWIDE HOME LOANS INC. 7105 Corporate Drive PTX B-35 Plano, TX 75024-3632 Plaintiff IN THE COURT OF COMMON PLEAS OF CUMBERLAND COUNTY CIVIL ACTION - LAW vs. ,ACTION OF MORTGAGE FORECLOSURE KERMIT W. MOYER AND LISA A. MOYER 204 North Second Street wo~leysburg, PA 17043 Defendant(s) No. 00-6883 CIVIL TERM THIS IS LAW FIRM IS A DEBT COLLECTOR AIm WE ARB ATTEMPTING TO COLLECT A DEBT OWED TO OUR CLIENT. ANY INFORMATION OBTAINED FROM yOU WILL BE USED FOR THE PURPOSE OF COLLECTING THE DEBT. PLAINTIFF'S PETITION FOR REASSESSMENT OF DAMAGES AND NOW, this Plaintiff, COUNTRYWIDE HOME LOANS INC., petitions the Court for Reassessment of Damages for the following reClsons, 1. Plaintiff's Complaint in Mortgage Foreclosure was filed on October 6, 2000. 2. On March 9, 2001, judgment in mortgage foreclosure was entered in favor of Plaintiff and against Defendants in the amount of $83,918.68, based upon the demand in Plaintiff's Complaint. 3. The mortgage in question is insured by the Veterans AdIninistration. ,'"' ~L"j~.::liC. " ~ '. , -~" "".~" j '"-,.,,, " ~.fII<~.' 4. Execution on the judgement was delayed by the failure of the Veterans Administration to obtain an appraisal and issue a bid. 5. Since the filing of the Complaint, interest has been accruing as have the escrow balance deficit and late charges under the terms of the mortgage contract involved. 6. Due to the delay of proceedings, Plaintiff's judgment is now insufficient to satisfy the amounts due and owing on the mortgage and the mortgage lien on the property in question. 7. Upon disposition of this petition and the scheduling of a Sheriff's Sale on December 5, 2001, the amounts due and owing on the mortgage will be as follows: Principal balance $71,968.54 Interest from 1/ 1/00 through "a,.,l.$:/O,_' at 7.500% Per diem interest rate at $14.79 10,404.63 Attorney's Fee at 5% of principal balance Escrow Balance Deficit 3,598.42 11,302.55 Late Charges 496.00 Costs of Suit and Title Search 560.00 $98,330.14 WHEREFORE, Plaintiff prays damages be reassessed and Plaintiff's Judgment be increased to $98,330.14, plus interest and costs. sq. ," L,c.... I,,' ,',,-; I..~', ,.",,' "'~':Ii " 'Itl~, Joseph A. Goldbeck, Jr. A Professional Corporation Attorney I.D.#16l32 Suite 500 - The Bourse Bldg. 111 S. Independence Mall East Philadelphia, PA 19106 215-627-1322 Attorney for Plaintiff COUNTRYWIDE HOME LOANS INC. 7105 Corporate Drive PTX B-35 Plano, TX 75024-3632 Plaintiff IN THE COURT OF COMMON PLEAS OF CUMBERLAND COUNTY CIVIL ACTION - LAW vs. :ACTION OF MORTGAGE FORECLOSURE KERMIT W. MOYER AND LISA A. MOYER 204 North Second Street Wormleysburg, PA 17043 Defendant(s) No. 00-6883 CIVIL TERM VERIFICATION Ga.ry E. McCafferty, Esq., hereby states that he is the attorney for Petitioner within named and that all of the facts set forth within the attached Petition for Reassessment of Damages are true and correct to the best of his knowledge, information and belief. The undersigned understands that the foregoing statements are made subject to the penalties 18 P.S. Section 49 Gary ~= ~I 1.'0 1,< l.~"'. Joseph A. Goldbeck, Jr. A Professional Corporation Attorney I.D.#16l32 Suite 500 - The Bourse Bldg. 111 S. Independence Mall East Philadelphia, PA 19106 215-627-1322 Attorney for Plaintiff COUNTRYWIDE HOME LOANS INC. 7105 Corporate Drive PTX B-35 PIano, TX 75024-3632 Plaintiff IN THE COURT OF COMMON PLEAS OF CUMBERLAND COUNTY CIVIL ACTION - LAW vs. :ACTION OF MORTGAGE FORECLOSURE KERMIT W. MOYER AND LISA A. MOYER 204 North Second Street Wor.mleysburg, PA 17043 Defendant(s) No. 00-6883 CIVIL TERM MEMORANDUM OF LAW IN, SUPPORT OF PLAINTIFF'S PBTITION FOR REASSBSSMENT OF DAMAGES Plaintiff is entitled to the amounts due and owing on the mortgage contract at the time of the Sheriff's Sale of property involved. For reasons stated in the within motion, Plaintiff's judgment in mortgage foreclosure is insufficient to compensate Plaintiff for the amount due and owing under the mortgage. Specifically, interest charges, the escrow balance deficit and late charges have all been accruing while Plaintiff's action in mortgage foreclosure was stayed by Defendant(s) bankruptcy petition. ,1' t ",Ii',," 'Of' .'''." , li__,'"" CONCLUSION For the reasons stated above and in the within petition, Plaintiff respectfully requests that the damages be reassessed and Plaintiff's judgment be increased to $98,330.14, plus interest and costs. Respectfully submitted, ,,,,.... I ,I,,' .,;.J~it, ~__ I ~ > ' ;';' ," ,,'< "" ",'h.., ,. ""'"h Joseph A. Goldbeck, Jr. A Professional Corporation Attorney I.D.#16132 Suite 500 - The Bourse Bldg. 111 S. Independence Mall East Philadelphia, PA 19106 215-627-1322 Attorney for Plaintiff COUNTRYWIDE HOME LOANS INC. 7105 Corporate Drive PTX B-35 Plano, TX 75024-3632 Plaintiff IN THE COURT OF COMMON PLEAS OF CUMBERLAND COUNTY CIVIL ACTION - LAW vs. :ACTION OF MORTGAGE FORECLOSURE KERMIT W. MOYER AND LISA A. MOYER 204 North Second Street Wormleysburg, PA 17043 Defendant(s) No. 00-6883 CIVIL TERM CERTIFICATION OF SERVICE Gary E. McCafferty, Esquire, attorney for Plaintiff hereby certifies that a copy of Plaintiff's Petition for Reassessment of Damages was mailed by first class mail, postage prepaid to Defendant(s) KERMIT W. MOYER at 22 ASHBURG DRIVE, MECHANICSBURG, PA 17055 AND LISA A. MOYER at 204 NORTH 2ND STREET, WORMLEYSBURG, PA 17043 and KERMIT W. MOYER AND LISA A. MOYER at P.O. BOX 1241 MECHANICSBURG, PA 17055 on NOVEMBER 13, 2001. squire ill"'" ,l"--~~R~Jl~~'iffiLGii~~~'1~P'-"-~;~'~''''''''' '....=~""'='"'--~ ,~ -~, - .'"..,.;.'. . "Ii! __ J,i"."':' () c: :i;":"- ~(:n Zr~ ZF:::;' F?3F s::-CI :!Eo 5>0 L :z ::;!.. ~', ~'- ,,-- o ;;e Cj ~ <b -r, ---< j;4~;;! ~ ~B@I (-', 4.. ,.::;() .'r~f; c5'1 20 c:51-n ;j:;! Xl -< 'D -r:" ~ co (J'J Ji! O!lil ,~ ~~ < ~I J ~~ STATE OF PENNSYLVANIA, COUNTY OF CUMBERLAND } ss. Robert P Ziegler I, _____________________________________________________~________________________Ilecorderof Deeds in and for said County and State do 'herdly certify that the Sherifrs Deed in which ________________ Secretary of Veterans Affairs . __________________________ .____________________ ____________________________________ IS the grantee 5th the same having been sold to said grantee on the _______________________________________________ day of 01 Dee ________________________________________ A. D., ; _____, under and by virtue of a wriL_____________ 18th Execution . ______________________________________ ___ _ _ _____ ISSUed on the ___ _ __ __ ___ _ ______ ____ __ _____________ September 01 , day of __________________________ Ao Do, _____, out of the Court of Cornman Pleas of said County as of Civil 00 ------------------------------,,------- ----- - ---- -- -------------- ------ -----______ Term, : 6883 Countrywide Home Loans Ine Number ______________, at the suit of _______________________________________________________________ o Kermit W Moyer & Lisa A Moyer __________________ __________ _______ agalOst_ __ __n_ __ _ _______ _____ ____ ______ ____ ____ ____ __ _____ is ul -'--' . f 249 4824 d y reoo.u<:u In Sheri rs Deed Book No. ____________, Page ____________. IN TESTIMONY WHEREOF, I have hereunto I ,71:- d and seal of said office this _/L_______ day - ~~~)!j~Y!ll~_ ~~:~:~.~-~ My ColntftisS\on Expires Ille filst MoIIdaJ a1JiUl. -- I~~,.~~j =,.~ ,.o~ 1,.........oJ ..1 ""~ (,d Countrywide Home Loans, Inc. VS Kermit W. Moyer and Lisa A. Moyer In The Court of Common Pleas of Cumberland County, Pennsylvania Writ No. 2000-6883 Civil Term Richard E. Smith, Deputy Sheriff, who being duly sworn according to law, states that on Sept. 27, 2001 at 6:50 o'clock P.M., E.D.S,T" 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: Kermit W. Moyer, by making known unto Kermit Moyer personally, at 77 Autumn Lane, Eno1a, Pennsylvania, its contents and at the same time handing to him personally the said true attested copy of the same. Kenneth E. Gossert, Deputy Sheriff, who being duly sworn according to law, states that on Sept. 26, 2001 at 7:29 P.M., E.D.S.T., 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: Lisa A. Moyer, by posting a true copy on the premises located at 204 North 2nd Street, W ormleysburg, P A 17043 pursuant to a court order. Timothy Reitz, Deputy Sheriff, who being duly sworn according to law, states that on October 01, 2001 at 9:05 P.M., E.D.S.T., he posted a true copy of the within Real Estate Writ, Notice, Poster and Description, in the above entitled action, upon the property of Kermit W. Moyer and Lisa A. Moyer, located at 204 North 2n Street, Wormleysburg, Pennsylvania, according to law. R. Thomas Kline, Sheriff, who being duly sworn according to law says he served the above Real Estate Writ, Notice, Poster and Description in the following mamIer: The Sheriff mailed a notice ofthe pendency of the action to one ofthe within named defendants to wit: Kermit W. Moyer, by regular mail to his last known address 7 Autumn Lane, Eno1a, P A 17025. This letter was mailed under the date of October 3, 2001 and never returned to the Sheriff s Office. R. Thomas Kline, Sheriff, who being duly sworn according to law says he served the above Real Estate Writ, Notice, Poster and Description in the following mamIer: The Sheriff mailed a notice of the pendency of the action to one of the within named defendants to wit: Lisa A. Moyer, by regular mail to her last known address of204 North 2nd St., W ormleysburg, P A 17043. This letter was mailed under the date of October 3, 2001 and returned to the Sheriffs Office on October 09, 2001 with reason checked "unclaimed." R. Thomas Kline, Sheriff, who being duly sworn according to law, states that after due and legal notice had been given according to law, exposed the within described premises at public venue or outcry at the Court House, Carlisle, Cumberland County, Pennsylvania, on December 5,2001 at 10:00 A.M., EST. He sold the same for the sum of$1.00 to Attorney Joseph A. Goldbeck for The Secretary of Veterans Affairs. It being the highest bid and best price received for the same, The Secretary of Veterans Affairs of 5000 Wissabickon Avenue, Philadelphia, PA 19144, being the buyer in this execution paid SheriffR. Thomas Kline the sum of$731.70, it being costs. ~., ~ "l~"" ~ '"""--~ "^ Sheriffs Costs: Docketing Poundage Advertising Posting Bills Acknowledging Deed Auctioneer Prothonotary Mileage Certified Mail Levy Surcharge Postpone Sale Law Journal Patriot News Share of Bills Distribution of Proceeds Sheriffs Deed $30.00 14.35 15.00 15.00 30.00 10.00 1.00 31.20 4.54 15.00 30.00 232.85 225.60 25.66 25.00 26.50 $731.70 Sworn and subscribed to before me This /'(t dayO~.....'.' ) 2002, A.D., ~ () ~~ Pr 0 otary L - o'u_., Li So answers: r~-"~~ R. Thomas Kline, Sheriff BY C~O~"jvU.71J\ Real state eputy ~~ 2/).llO ~~ 1.00 Ck .J';{':l~3 R.u- l;Lo(.3~ -' i ~ J_._ '-,-" ~, ,,' "." '" ' ,~ , ~ '''''Mti, 4" I. / Countrywide Home Loans, Inc. Plaintiff CUMBERLAND COUNTY COURT OF COMMON PLEAS CIVIL DIVISION Vs. Kermit W. Moyer Lisa A. Moyer NO. 00-6883 Defendants AFFIDAVIT PURSUANT TO RULE 3129.1 Countrywide Home Loans. Inc., Plaintiff in the above action, by its attorney, Joseph 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 204 N. 2nd Street. Worm1eysburg. PA 17043. 1. Name and address of owner(s) or reputed owner (s): Name Address (if address cannot be reasonably ascertained, please so indicate) Kermit W. Moyer 22 Ashburg Drive Mechanicsburg. PA 17055 Lisa A. Moyer 204 N. 2nd Street Wormleysburg. PA 17043 2. Name and address of defendant(s) in the judgment: Name Address (if address cannot be reasonably ascertained, please so indicate) Sll.Mw. AS ABOVE 3. Name and address of every judgment creditor whose judgment is a record lien on the real property to be sold: Name Address (if address cannot be reasonably ascertained, please so indicate) HQna 4. Name and address of the last recorded holder of every mortgage of record: Name Address (if address cannot be reasonably ascertained, please so indicate) City Mortgage Services. a Division of City National Bank of West Virginia. A National Banking Association 17748 Sk,ypark Boulevard. #l!l..ll. Irvine. CA 92614 / Carlisle Suburban Authority 240 Clearwater Drive Carlisle. PA 17013 . ,~ fiP. .. I. l, I" - '- ' " - .. ". ',~. j",'" rt'.'t!:, , , 5. Name and address of every other person who has any record lien on the property: Name Address (if address cannot be reasonably ascertained, please so indicate) N.cne 6. Name and address of every other person who has any record interest in the property and whose interest may be affected b}' the sale: Name Address (if address cannot be reasonably ascertained, please so indicate) Cumberland County Dapt. of Domestic Relations P.O. Box 320 Carlisle. PA 17013 Pa Dept. of Public Welfare Bureau of Child S~port Enforcement Health and Welfare Bldg. R"om 432 P.O. Box 2675 Harrisburg. PA 17105 7. Name and address of every other person of whom the plaintiff has knowledge that has any interest in the property' that may be affected by the sale: Name Address (if address cannot be reasonably ascertained, please so indicate) N.cne 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. #4904 relating to unsworn falsification to authorities. September 11, 2001 dbeck, Jr. Plaintiff ". " ."" " . " '" .., ~ iUr.<i' ~ i 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 InS) 6/.7-1 ::J2? ~ , ATTORNEY FOR PLAINTIFF Countrywide Home Loans, Inc. Plaintiff CUMBERLAND COUNTY COURT OF COMMON PLEAS CIVIL DIVISION Vs. Kermit W. Moyer Lisa A. Moyer : NO.00-6883 Defendants NOTICE OF RHERIFF' R RAr,E OF REAr, ERTATE TO: Lisa A. Moyer 204 N. 2nd Street Worm1eysburg, PA 17043 THIS FIRM IS A DEBT COLLECTOR ATTEMPTING TO COLLECT A DEBT ~mD ANY INFORMATION OBTAINED WILL BE USED FOR THAT PURPOSE. IF ~)U HAVE PREVIOUSLY RECEIVED A DISCHARGE IN BANKRUPTCY, THIS IS NOT AND SHOULD NOT BE CONSTRUED TO BE AN ATTEMPT TO COLLECT A DEBT, BUT ONLY ENFORCEMENT OF A LIEN AGAINST PROPERTY. Your house (real estate) at 204 N. 2nd Street. Worm1~sburg. Pj~ 17043. is scheduled to be sold at the Sheriff's Sale on DeC!ember 5. 2001 at 10:00 a.m., in Cumberland County, Cumberland County Courthouse, Commissioners Hearing Room, 2nd Floor, Carlisle, PA 17013 to enforce the court judgment of S83.918.68 obtained by Countrywide Ho~ LORna. Inc. (the mortgagee) against you. NOTICE OF 9WNER'S RIGHTS YOU MAY BE ABLE TO PREVENT THIS SHERIFF'S SALE To prevent this Sheriff's Sale, you must take immediate action: 1. The sale will be cancelled if you pay to the mortgagee the Back payments, late charges, costs and reasonable attorneys Fees due. To find out how much you must pay, you may call: (215) 627-1322 2. You may be able to stop the sale by filing a petition asking the Court to strike or open the judgment, if the judgment was improperly entered. You may also ask the Court to postpone the sale for good cause. 3. You may also be able to stop the sale through other legal proceedings. ,~~'<~ ~ - , ~ L......J 1- J" -':". ' JiI " ~"........ ,1M, . J ... You may need--a:n attorney to assert your rights. The sooner you contact one, the more chance you will have of stopping the sale. (See notice on page two on how to obtain an attorney.) ,. YOU MAY STILL BE ABLE TO SAVE YOUR PROPERTY AND YOU HAVE OTHER RICmTS EVEN IF THE SHERIFF'S SALE DOES TAKE PLACE. 1. If the Sheriff's to the highest bidder. (7.15) 627-1 ~22. Sale is not stopped, your property will be sold You may find out the price bid by calling 2. You may be able to petition the Court to set aside the sale i.f the bid price was grossly inadequate compared to the value of your property. 3. The sale will go through full amount due in the sale. may call the Sheriff's office only if the buyer pays the Sheriff t:he To find out if this has happened, you at (717) 240-6~90 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 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 this 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 proposed schedule of distribution of the money bid for your house will be prepared by the Sheriff within 30 days of the 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 posting of the Schedule of Distribution. 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 Bar Association 2 Liberty Avenue Carlisle, PA 17103 (800) 990-9108 Legal Services, Inc. 8 Irvine Row Carlisle, PA 17103 (717) 243-9400 ,g'r . . .~. " '. l-:..I -"<j(" ,:,j\;jl-, ,4' . J ... 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 PLAINTIF COURT OF COM~[ON PLEAE CIVIL DIVISION Countrywide Home Loans, Inc. Vs. No. 00-6883-Civil Kermit W. Moyer (Mortgagor and Real Owner) Lisa A. Moyer (Mortgagor and Real Owner) CUMBERLAND COUNTY All those two certain lots of ground situate in the Borough of Wormleysburg, formerly East Pennsboro Township, County of Cumberland and Commonwealth of Pennsylvania, numbered 76 and 77 in a Plan of Lots laid out by V. Hummel Berhans and known as "Edgewater Plan No. 2" as amended to show walnut Street projected to center of Tract of "N.C.R.R. Co.", as Plan being recorded in Cumberland County Deed Book D, Volume 6, Page 559, said Lots being more particularly bounded and described as follows, to wit: BEGINNING at a point on the western side of Second Street, 50 feet above the corner of Walnut Street; thence up along said Second Street, 50 feet to the line of Lot No. 73; thence westwardly long line of Lot No. 78, 150 feet to Hill Alley; thence down along said Alley, 50 feet to the line of Lot No. 75; thence along line of said Lot eastwardly 150 feet to the place of BEGINNING.Having thereon erected a one story brick frame dwelling numbered 204 2nd Street. Being known as 204 N. 2nd Street, Wormleysburg, PA 17043. Tax parcel #47-19-1588-151 , 09/19/2001 11 :.34 FAX 2'15 6277734 GOLDJ3ECK I ,j , ~I"""",-,~ , ~' "'~ifi .. CUMBERLAND SO ~002 " , . GOLD! ,ECK McCAFFERTY & McKEEVER By: C'oseph A, Goldbeck, Jr. Attolney I.D. #16132 SuitE 500 - The Bourse Bldg. 111 !" Independence Mall East Fhili.delphia, FA 19106 J2.l5.: Ii::? 7 - U22. ATTORNEY FOR PLAINTIFF Plaintiff CUMBERLAND COUNTY COURT OF COMMON PLEAS CIVIL DIVISioN Counl :rywide Home Loans, Inc. VS. Kerm;. t W. Moyer Lisa A. Moyer : NO.00-6883 Defendants NOTTC"'F, ClF SHF.RTF'F' A S:r.T,F. OF RF.AT, E8'T'ATF. TO: Kermit W. Moyer 22 Ashburg Drive Mechanicsburg, PA 17055 THIS FIRM IS A DEBT COLLECTOR ATTEMPTING TO COLLECT A DEBT AN.) ANY INFORMATION OBTAINED WILL BE USED FOR THAT PURPOSE. iF YO'J HAVE PREVIOUSLY RECEIVED A DISCHARGE IN BANKRUPTCY, THIS IS NOT AND SHOULD NOT BE CONSTRUED TO BE AN ATTEMPT TO COLLECT A DEBT, BUT ONLY ENFORCEMENT OF A LIEN AGAINST PROPERTY. Your house (real estate) at 204 N 2nd ~treet. Wnrmleysburg. PA ~~ is scheduled to be sold at the Sheriff's Sale on I!.e.C.Il11h..r 5. 2001 at 10:00 a.m., in Cumberland County, Cumberland County CouIthouse, Commissioners Hearing Room, 2M Floor, Carlisle, PA 17013 to enfcrce the court judgment ot' ~B3.91B.6B obtained by .cmmtz:yw:ld.. Home r.Mans. Inc. (the mortgagee) against you. NOTICE OF OWNER'S RT~HTS YOU ~y BE lIBI,E TO PREVENT THIS SHERIFF'S SALE To prevent this Sheriff's Sale, you must take immediate action: , 1. The sale will be cancelled if you pay to the mortgagee the Back payments, late charges, costs and reasonable attorneys Fees due. To find out how much you must pay, you may call: (2151, 627-1322 I 2. You may be able to stop the sale by filing a petition asking the Court to strike or open the judgment, if the judgment was improperly entered. You roayalso ask the Court.to postpone the sale for good cause. 3. You may also be able to stop the sale through other legal proceedings. ik,~'0; SEP 19 20C1 12'53 215 627 7734 PAGE. 02 - ~ . I H 09/19/2001 11:34 FAX 215 627 7734 GOLDBECK .. CUMBERLAND SO I4J 003 . , , You may need an attorney to assert your rights. The sooner you cont.\ct on,;, the l1\Ore chance you will have of stopping the sale. (See noti,;e on page two on how to obtain an attorney.) :IQII.JlAY STILL BR ABT.F. EYER IF THE SHERIFF'S TO SAVE yom PROPF.RTY ~NTl YOU HAVE OTHER RTc:lll:m SALE nOES T~XF. PLACF.. : Sale is not stopped, your prop~rty will be sold You may find out the price bid by calling 1. If the Sheriff's to tle highest bidder. l.2.l.5.' li27-1 :022 2. You may be able to petition the Court to set aside the sale if the Jid price was grossly inadequate compared to the value of your prop~rty. 3. The sale will go through full amount due in the sale. may call the Sheriff's office only if the buyer pays the Sheriff the To find out if this has happened, YO\;, at (717) 24D-li190 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 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 t1is 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 proposed schedule of distribution of the money bid for your house will be prepared by the Sheriff within 30 days of the SaIl;. Thie 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 posting of the Schedule of Distribution. 7. You may also have other right's and defenses, or ways of getting your home back, if you act immediately after the sale. I YOU SHOULD TAKE THIS PAPER TO YOUR LAWYER AT ONCE. IF YOU DO NOT HA:\TE A Ll WYER OR CANNOT AFFORD ONE, GO!l'O OR TELEPHONE THE OFFICE LISTED BELeW TO FIND OUT WHERE YOU CAN GE~ LEGAL HELP. Cumberland Co~ty Bar Association 2 Libel-ty Avenue Carlisl.e, PA 17103 (800) 990-9108 Legal Services, Inc. 8 Irvine Row Carlisle, PA 17103 (717) 243-9400 .1, " Se? 19 2001 12:53 :' ,~:,'h;';""-~~i"\i~.."tj" ~w:~i,' 215 627 7734 I PAGe, 03 :~ . ~- " I . , I , - . "'"ii~' .. ~ . , GOLDBECK, MCCAFFERTY & MCKEEVER By: Joseph A. Goldbeck, Jr. Attorney I.D. #16132 Suite SOO-The Bourse Bldg. 111 S. Independence Mall East Philadelphia, PA 19106 (215) 627-1322 ATTORNEY FOR PLAINTIF COURT OF COMtJlON PLEAE CIVIL DIVISION Countrywide Home Loans, Inc. Vs. No. 00-6883-civil Kermit W. Moyer (Mortgagor and Real Owner) Lisa A. Moyer (Mortgagor and Real Owner) CUMBERLAND COUNTY All those two certain lots of ground situate in the Borough of Wormleysburg, formerly East pennsboro Township, County of Cumberland and Commonwealth of Pennsylvania, numbered 76 and 77 in a Plan of Lots laid out by V. Hummel Berhans and known as "Edgewater Plan No. 2" as amended to show Walnut Street projected to center of Tract of "N.C.R.R. Co.", as Plan being recorded in Cumberland County Deed Book D, Volume 6, Page 559, said Lots being more particularly bounded and described as follows, to wit: BEGINNING at a point on the western side of Second Street, 50 feet above the corner of Walnut Street; thence up along said Second Street, 50 feet to the line of Lot No. 73; thence westwardly long line of Lot No. 78, 150 feet to Hill Alley; thence down along said Alley, 50 feet to the line of Lot No. 75; thence along line of said Lot eastwardly 150 feet to the place of BEGINNING. Having thereon erected a one story brick frame dwelling numbered 204 2nd Street:. Being known as 204 N. 2nd Street, Wormleysburg, PA 17043. Tax parcel #47-19-1588-151 '"",. ~ , ~..., I. ,I o. 'l!Ol,Ol" WRIT OF EXECUTION and/or ATTACHMENT COMMONWEALTH OF PENNSYL VANIA) COUNTY OF CUMBERLAND) TO THE SHERIFF OF CUmberland NO. 00-6883 CIVIL HIX TEI@ CIVIL ACTION - LAW COUNTY: To satisly the debt, interest and costs due Count:rywide Hone Loans, Inc. . PLAINTIIFF(S) from Kermit W. Moyer, 22 Ashburg Drive, Mechanicsburg, PA 17055 and Lisa A. Moyer, 204 N. 2nd Street, Mechanicsburg, PA 17043 (1) You are directed to levy upon the property of the defendanl(s) and 10 sell DEFENDANT(S) See Leqal Description (2) You are also directed 10 attach the property 01 the delendant(s) not levied upon in the possession 01 __ GARNISHEE(S) as follows: and 10 notffy Ihe garnishee(s) that: (a) an attachment has been is~ued; (b) the garnishee(s) is/are enjoined Irom paying, any debt to or lor the account 01 the delendanl(s) and lrom delivering any property 01 the delendant(s) or otherwise dispc1sing thereol; (3) II property 01 the delendant(s) not levied upon an subject to attachment is lound in the possession 01 anyone other than a named garnishee, you are directed to notffy himlherthat he/she has been added as a garnishee and is enjoined as above stated. Amount Due $83,918.68 from 3/7/01 to sale date at Interest $13 79 r=r niPlTl Atty's Comm % Atty Paid $795.83 Plaintffl Paid L.L. Due Prothy Other Costs $1.00 Date: September 18, 2001 Curtis R. Long Prothonotary, Civil Division ~. An- tI Q .7!?:~~ Deputy REQUESTING PARTY: Name Joseph A. Goldbeck, Jr., Esq. Suite 500-The Bourse HLdg. 111 s. I~ndooCli' M(;>" R""t- Philadelphia, PA 19106 Plaintiff Address: Attorney for: Telephone: Supreme Court ID No. 215-627-1322 16132 .J .. "', u!!.ii .m.~~~~;;jl!i',,'MN~~rMi~lW,j;+J\'4~i'~~j!Ml.~~~l~'~~ ~Ill.l!SiilMiOOi~~iIO!AMlii~'e ili.:.i ' " .' ^ REAL ESTATE SALE No. ~3 !: On September 19,2001, the sherifflevied upon the defendant's interest in the real property situated in Borough of W orm1eysburg, Cumberland County, P A, known and numbered as 204 North 2nd St., Worm1eysburg, and more fully described on Exhibit "A" filed with this writ and by this reference incorporated herein. Date: September 19, 2001 By: 9~ ~ Real Estate Deputy €9 ~ ~ ~ It; " ~ ~ '. .~ ."k,tl!.j ~" I' ,,- _: '- .hI .~ '.II~_'hi'"':",,,.' THE PATRIOT NEWS THE SUNDAY PATRIOT NEWS Proof of Publication Under Act No. 587, Approved May 16, 1929 Commonwealth of Pennsylvania, County of Dauphin} ss James L. Clark being duly sworn according to law, deposes and says: That he is the Acounts Receivable Manager of The Patriot News Co., a corporation organized and eXllsting 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 andlor Sundayl Metro editions which appeared on the 23rd and 30th day{s) of October and tho 6lh day{s} of November 2001. That neither he nor said Company is interested in the subject matter of said printl9d notice or advertising, and that all of the allegations of this statement as to the time, plae:e 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 recordod in the office for the Recording of Deeds in and for said County of Dau1n in Miscellaneous Book "M", Volume 14, Page 317. {} 4 PUBLICA liON ..................... ./............................................................... ........ COpy S om . 19th day of ovem r 2001 AD. Notarta' Saa' S ALE #55 Teny L Ru.sa", Notary Public M C Harrisburg, DauPhin COunly r y omnllss'oI1 Expiras June 6, 2002 NOT< RY PUBLIC '-.... Member, PennSylvania Assoc:' liOn fa 01 Notartllt commission expires June 6, 2002 I CUMBERLAND COUNTY SHERIFFS OFFICE CUMBERLAND COUNTY COURTHOUSE CARLISLE, PA. 17013 I 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 $ 224.W 1.50 225.130 Publisher's Receipt for Advertising Cost The Patriot News Co., publisher of The Patriot-News and The Sundav 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. By..................................................................., " JIt'.-. " - n-FiEAL ESTATE SALE No. 55 Writ No. 2000-6663 Clvll Term Countrywide Home Loans, Inc. vs . KermitW. Moyer Lisa A. Moyer Ally, Joseph Goldbeck DESCRIP110~ ALL those two c('(lii'in lots uf ground situate in the Borough of' Wonnleysbul'J, formerly East Pennsboro Townsti)p, County of Cumberland and Coinnilinweulth ,or Pennsylvania, numbered 76 and 77 in a Plan' ~\I Lots laid out by V,. Hummel Ber1uuL~ and knov.'n a, '"Edb'ewater Plan No.2" "S <1mended to show Walnut Street projected to tenter of Tract of "N.C.R.R. Co.". as Plan being w.corded in Cumberland County Deed Book D. Volume 6, Page 559, said Lolli being more pro1icularly bounded mld descnbed as follows, to wit: BEG:JNN1.NG at a poiat on lbe \re;;tem side of Second Street, 50 feet abovll the wmer of Walnut Street; thence up along said Second Street, SO feel to the line of Lot NO. 73; thence wesrn',udlv almig line of Lot No. 18m. 150 feet to Hill Alley; thence down along said Alley, 50 feet to the line of Lot No. 75; Thence along line of said Lot ..::astwardly 150 fed (0 the place of BEGINNING. Raving thereon erected a llIIe-story hrick frame dwelling numDerr 12D4 2nd Street BEING Jmowrr-~> <'IS 2Q4 N. 2nd Street, Womlley.sburg, P:\' 1704:1 _ ,r~J.?~r~!;:1jf47.12-1~]?-15!-,-__ \ , L'~~'~ ' I 'W'~lj;!!!l"" , , PROOF OF PUBLICATION OF NOTICE IN CUMBERLAND LAW JOURNAL (Under Act No. 587, approved May 16, 1929), P. 1.1784 STATE OF PENNSYL VANIA : ss. COUNTY OF CUMBERLAND : Roger M. Morgenthal, 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 fue 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 al11ega1 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, V1Z: October 12, 19,26,2001 Affiant further deposes that he is authorized to veritY 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. Ro er M. Morgenthal, Editor SWORN TO AND SUBSCRIBED before me this 26 day of OCTOBER. 2001 NOlAR LOIS E. SNYDER. Hillary Public Cat1IsIll Boro. CUmberiand County My Commis8lon ExpiI'llS Marl:h 5, 2005 ~il'iO~~I"~~i'.ii:~~~#-lri',h~;,~-""..c.'bSiM'~~a;!:il;l~!11i1l11t ' '"""" " ':iIt.~"-- I . REAL ESTATE MiLE NO. 55 Writ No. 2000-6883 Clvil Countrywide Home Loans, Inc. vs. Kermit W. Moyer and Usa A. Mayer At1y., Joseph Goldbeck All those two certaIn lots of ground situate In the Borough of Wormleysburg. formerly East Pennsboro TownshIp. County of Cumberland and Commonwealth of Pennsylvania, numbered 76 and 77 in a Plan of Lots laid out by V. Hummel Berhans and known as "Edgewater Plan No.2" as amended to show Walnut Street projected to center of Tract of "N.C.R.R. CO.," as Plan being recorded in Cumberland County Deed Book D, Volwne 6, Page 559, said Lots be- ing mare particularly bounded and descrtbed as follows. to Wit: BEGINNING at a point on the western side of Second Street. 50 feet above the carner of Walnut Street; thence up along said Sec- ond Street, 50 feet to the line af Lot No. 73: thence westwardly long line of Lot No. 78, 150 feet to Hill Alley: !hence down along said Alley, 50 feet to the line of Lot No. 75: thence along line of said Lot eastwardly 150 feet to the place of BEGINNING. Having thereon erected a one story brick frame dwelling numbered 204 2nd Street. BeIng known as 204 N. 2nd Street, Wormleysburg, PA 17043. Tax parcel #47-19-1588-151. ,~.....l...-~ lIiiIIiilft;R I: r , 'i: i I " ri (: