HomeMy WebLinkAbout03-1869GOLDBECK McCAFFERTY & McKEEVER
BY: JOSEPH A. GOLDBECK, JR.
ATTORNEY I.D. #16132
SUITE 500 - THE BOURSE BLDG.
111 S. INDEPENDENCE MALL EAST
PHILADELPHIA, PA 19106
(215) 627-1322
ATTORNEY FOR PLAINTIFF
COLUMBIA NATIONAL INC.
7142 Columbia Gateway Drive
Columbia, MD 21046-2132
Plaintiff
VS.
BARBARA A. BAER
Mortgagor(s) and Real Owner(s)
346 Lincoln Street
Carlisle, PA 17013
Defendant(s)
IN THE COURT OF COMMON PLEAS
OF Cumberland COUNTY
CIVIL ACTION - LAW
ACTION OF MORTGAGE FORECLOSURE
Term
No.
CIVIL ACTION: MORTGAGE
THIS FIRM IS A DEBT COLLECTOR AND WE ARE ATTEMPTINGTO COLLECT
A DEBT OWED TO OUR CLIENT. ANY INFORMATION OBTAINED FROM YOU
WILL BE USED FOR THE PURPOSE OF COLLECTING THE DEBT.
NOTICE
You have been sued in court. If you wish to defend against the claims set forth in the following pages, you must take action within twenty (20) days after the Complaint and notice
are served, by entering a written appearance personally or by attorney and filing in writing with the court your defenses or objections to the claims set forth against you. You are warned that if
you fail to do so the case may proceed without you and a judgment may be entered against you by the Court without further notice for any money claim in the Complaint of for any other claim
or relief requested by the Plaintiff. You may lose money or properly or other rights important to you.
YOU SHOULD TAKE THIS POPER TO YOUR LAWYER AT ONCE. IF YOU DO NOT HAVE A LAWYER OR CANNOT AFFORD ONE, GO TO OR TELEPHONE THE
OFFICE SET FORTH BELOW TO FIND OUT WHERE YOU CAN GET LEGAL HELP.
LEGAL SERVICES INC
8 Irvine Row
Carlisle, PA 17013
717-243-9400
CUMBERLAND COUNTY BAR ASSOCIATION
2 Liberty Avenue
Carlisle, PA 17013
AVISO
LE HAN DEMANDADO A USTED EN LA CORTE. SI DESEA DEFENDERSE CONTRA LAS QUEJAS PERESENTADAS, ES ABSOLUTAMENTE NECESSARIO QUE
USTED RESPONDA DENTRO DE 20 DIAS DESPUES DE SER SERVIDO CON ESTA DEMANDA y AVISO. PARA DEFENDERSE ES NECESSARIO QUE USTED, O SU
ABOGADO, REGISTRE CON LA CORTE EN FORMA ESCRITA, EL PUNTO DE VISTA DE USTED Y CUALQUIER OBJECCION CONTRA LAS QUEJAS EN ESTA DEMANDA.
RECUERDE: SI USTED NO REPONDE A ESTA DEMANDA, SE PUEDE PROSEGUIR CON EL PROCESO SIN SU PARTICIPACION. ENTONCES, LA COUTE PUEDE,
SIN NOTIFICARIO, DECIDIR A FAVOR DEL DEMANDANTE y REQUERIRA QUE USTED CUMPLA CON TODAS LAS PROVISIONES DE ESTA DEMANDA. POR RAZON DE
ESA DECISION, ES POSSIBLE QUE USTED PUEDA PERDER DINERO, PROPIEDAD U OTROS DERECHOS LMPORTANTES.
LLEVE ESTA DEMANDA A UN ABOGADO IMMEDIATEAMENTE.
SI NO CONOCE A UN ABOGADO, LLAME AL "LAWYER REFERENCE SERVICE" (SERVICIO DE REFERENCIA DE ABOGADOS), (215) 238-6300.
LEGAL SERVICES INC
8 Irvine Row
Carlisle, PA 17013
717-243-9400
CUMBERLAND COUNTY BAR ASSOCIATION
2 Liberty Avenue
Carlisle, PA 17013
COMPLAINT IN MORTGAGE FORECLOSURE
o
Plaintiff is COLUMBIA NATIONAL INC., 7142 Columbia Gateway Drive, Columbia, MD 21046-
2132.
The name(s) and address(es) of the Defendant(s) is/are BARBARA A. BAER, 346 Lincoln Street,
Carlisle, PA 17013, who is/are the mortgagor(s) and real owner(s) of the mortgaged premises
hereinafter described.
On December 09, 1998 mortgagor(s) made, executed and delivered a mortgage upon the premises
hereinafter described to COLUMBIA NATIONAL INC., which mortgage is recorded in the Office of
the Recorder of Deeds of Cumberland County as Book 1504 Page 600. The mortgage has not been
assigned unless said assignment to the Plaintiff is hereafter mentioned. These documents are matters of
public record and are incorporated herein by reference in accordance with Pennsylvania Rule of Civil
Procedure 1019(g).
The premises subject to said mortgage is described as attached.
The mortgage is in default because monthly payment of principal and interest upon said mortgage due
November 01, 2002, and each month thereafter are due and unpaid, and by the terms of said mortgage,
upon default in such payments for a period of one month, the entire principal balance and all interest due
thereon are collectible forthwith.
6. The following amounts are due on the mortgage:
Principal Balance
Interest from 10/01/2002
through 04/30/2003 at 6.5000%
Per Diem interest rate at $14.99
Attorney's Fee at 5.0% of Principal Balance
Late Charges from 11/01/2002 to 04/30/2003
Costs of suit and Title Search
Escrow Debit
$84,174.75
$2,443.37
$4,208.74
$155.97
$900.00
$91,882.83
+ $17.78
$91,900.61
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.
The within mortgage is insured by the Federal Housing Administration under Title II of the National
Housing Act and, as such, is not subject to the provisions of Pennsylvania Act No. 91 of 1983.
WHEREFORE, Plaintiff demands judgment in mortgage foreclosure in the sum of $91,900.61, together with
interest at the rate of $14.99, 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: G , ._~~//~ ~
ATTORNEY FOR PLAINTIFF
VERIFICATION
I, Vernetta M. Watson, 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 forgoing Complaint are true and corrct 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 falsifcation to authorites.
Date:
Vernetta M Watson, Asst. Treasurer
Columbia National Inc.
Dva~n Lincoln St=oat and an alley~ %hen~O along ~he 80u~h aide of
· nco%n Street, South 83 deg~eee 57 ~ute~ zast, ~ d£atance of
Ca_.~, _ ~ ~ ~u~on P~a~ fO= ~h- SchooZ ~l~ ~f
~ln~ a~onq ~ho Northern eida ~ ~
d .... ,f?~ &lle~; ~nco S~h e3
16~.35 feo~ ~o n po~t, tho o6vthouot co'er ~ an in~erse=tlon o~
~iflcoln S~c~ and an al~ ~h~ ~laoe. o~ ~X~.'
19e.~ a_~ _ - ~a~O~ I:~'~arrvV. ~.Y~..__- .... ., ~C~OOl
BOok 4~, Paa~ v -:, renn~y~vamXa, o~ ~v~'~`:~c' uo~o
DEC 84 '98 15:53
SHERIFF'S RETURN - REGULAR
CASE NO: 2003-01869 P
COMMONWEALTH OF PENNSYLVANIA:
COUNTY OF CUMBERLAND
COLUMBIA NATIONAL INC
VS
BAER BARBARA A
HAROLD WEARY , Sheriff or Deputy Sheriff of
Cumberland County, Pennsylvania, who being duly sworn according to law,
says, the within COMPLAINT MORT FORE was served upon
BAER BARBARA A the
DEFENDANT
at 346 LINCOLN STREET
CARLISLE, PA 17013
, at 1118:00 HOURS, on the 28th day of April , 2003
by handing to
BARBARA A BAER
a true and attested copy of COMPLAINT - MORT FORE
together with
and at the same time directing Her attention to the contents thereof.
Sheriff's Costs:
Docketing 18.00
Service 3.45
Affidavit .00
Surcharge 10.00
.00
31.45
Sworn and Subscribed to before
me this 7 5, day of
-~4~. ,,2 z:~' A.D.
~ t~rothonOtary ~ J '
So Answers:
R. Thomas Kline
04/29/2003
GOLDBECK MCCAFFERTY MCKEEVER
By:
' ]Deputy S~ff
In the Court of Common Pleas of Cumberland County
COLUMBIA NATIONAL 1NC.
7142 Columbia Gateway Drive
Columbia, MD 21046-2132
VS.
BARBARA A. BAER
(Mortgagor(s) and Record Owner(s))
346 Lincoln Street
Carlisle, PA 17013
Plaintiff
Defendant(s)
No. 03-1869-CIVIL
PRAECIPE FOR JUDGMENT
THIS LAW FIRM IS A DEBT COLLECTOR AND WE ARE ATTEMPTING TO COLLECT A DEBT
OWED TO OUR CLIENT. ANY INFORMATION OBTAINED FROM YOU WILL BE USED FOR THE PURPOSE
OF COLLECTING THE DEBT.
Enter the Judgmem in favor of Plaintiffand against BARBARA A. BAER by default for want of an Answer.
Assess damages as follows:
Debt
$92,350.31
Interest- 10/01/2002 to 05/30/2003
Total
(Assessment of Damages attached)
I CERTIFY THAT FOREGOING ASSESSMENT OF DAMAGES IS FOR SPECIFIED AMOUNTS ALLEGED TO
BE DUE IN THE COMPLAINT AND IS CALCULABLE AS A SUM CERTAIN FROM THE COMPLAINT.
is to be entered and to his attorney of record, if any, after the default occurred
filing of this praecipe. A copy of the notice is attached. R.C.P. 237.1 (
Joseph
Attorney
I.D. #16~
I certify that written notice of the intention to file this praecipe was mailed or delivered to the party against whom judgment
days prior to the date of the
AND NOW ,,~/,~LA,~..., ~,~ ~I~ ~Jr.
, Judgment is entered in favor of
COLUMBIA NATIONAL INC. and against BARBA~tA A. BAER by default for want of an Answer and damages assessed
in the sum of $92,350.31 as per the above certification.
Prothonotary '
GOLDBECK McCAFFERTY & McKEEVER
BY: $oseph 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
COLUMBIA NATIONAL INC.
7142 Columbia Gateway Drive
Columbia, MD 21046-2132
VS.
BARBARA A. BAER
(Mortgagor(s) and Record owner(s))
346 Lincoln Street
Carlisle, PA 17013
Plaintiff
Defendant(s)
IN THE COURT OF COMIVlON PLEAS
of Cumberland County
CIVIL ACTION LAW
ACTION OF MORTGAGE FORECLOSURE
No. 03-1869-CIVIL
ORDER FOR JUDGMENT
Please enter Judgment in favor of COLUMBIA NATIONAL 1NC., and against BARBARA A. BAER
for failure to file an Answer in the above action within (20) days (or sixt (60) days if defendant is the United
States of America) from the date of service of the Complaint, in the su Df $92,350.31.
Joseph A. Go ~/
Attorney for PI
I hereby certify that the above names are correct and that the premse residence address of the judgment
creditor is COLUMBIA NATIONAL INC. 7142 Columbia Gateway Drive Columbia, MD 21046-2132 and that
the name(s) and last known address(es) of the Defendant(s) is/are BARB ARA A. BAER, 346 Lincoln Street
Carlisle, PA 17013;
GOLDBEC TY & McKEEVER
BY: Joseph A. ~ldl~:qk, Jr.
Attorney for Pla~tif~ x
ASSESSMENT OF DAMAGES
TO THE PROTHONOTARY:
Kindly assess the damages in this case to be as follows:
Principal Balance
Interest from 10/01/2002 through
05/30/2003
Attorney's Fee at 5.0000% of principal
balance
Late Charges
Costs of Suit and Title Search
Escrow Balance Deficit
$84,174.75
$2,893.O7
$4,208.74
GOLDBECK Mci
BY: Joseph A. G(:
Attorney for Plainti
$155.97
$900.00
$17.78
($0.00)
$92,350.31
ProProthy - ' ~
VERIFICATION OF NON-MILITARY SERVICE
The undersigned, as the representative for the Plaintiff
corporation within named do hereby verify that I am authorized to
make this verification on behalf of the Plaintiff corporation and
that the facts set forth in the foregoing verification of Non-
Military Service are true and correct to the best of my
knowledge, information and belief. I understand that false
statements therein are made subject to penalties of 18 Pa. C.S.
4904 relating to unsworn falsification to authorities.
1. That the above named Defendant, BARBARA A. BAER, is
about unknown years of age, that Defendant's last known residence
is 346 Lincoln Street, Carlisle, PA 17013, and is engaged in the
unknown business located at unknown addres~s.
2. That Defendant is not in the Military or Naval Service
of the United States or its Allies, or otherwise within the
provisions of the Soldiers' and Sailors' Civil Relief Action of
Congress of 1940 and its Amendments.
Date: ~1 '~/
THIS LAW FIRM IS A DEBT COLLECTOR AND WE ARE ATTEMPTING TO
COLLECT A DEBT OWED TO OUR CLIENT. ANY INFORMATION OBTAINED
FROM YOU WILL BE USED FOR THE PURPOSE OF COLLECTING THE DEBT.
DATE OF THIS NOTICE: May 19, 2003
TO:
BARBARA A. BAER
346 Lincoln Street
Carlisle, PA 17013
COLUMBIA NATIONAL INC.
7142 Columbia Gateway Drive
Columbia, MD 21046-2132
VS.
BARBARA A. BAER
(Mortgagor(s) and
Record Owner(s))
346 Lincoln Street
Carlisle, PA 17013
Plaintiff
Defendant(s)
In the Court of
Common Pleas
of Cumberland County
CIVIL ACTION - LAW
Action of
Mortgage Foreclosure
Terrfl
No. 03-1869-CIVIL
TO: BARBARA A. BAER
346 Lincoln Street
Carlisle, PA 17013
IMPORTANT NOTICE
YOU ARE IN DEFAULT BECAUSE YOU HAVE FAILED TO ENTER A WR1TI'EN 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:
Attorney fi)r Plaintiff
Suite 500 - The Bourse Bldg.
111 S. In&~endence Mall East
Philadalphia, PA 19106 215-627-1322
Rule Of Civil Procedure No. 236 - Revised
COLUMBIA NATIONAL 1NC.
7142 Columbia Gateway Drive
Columbia, MD 21046-2132
BARBARA A. BAER
(Mortgagors and Record Owner(s))
346 Lincoln Street
Carlisle, PA 17013
IN THE COURT OF COMMON PLEAS
OF Cumberland COUNTY, PENNSYLVANIA
CIVIL ACTION - LAW
Plaintiff
VS.
No. 03-1869-CIVIL
Defendant(s)
THIS LAW FIRM IS A DEBT COLLECTOR AND WE ARE ATTEMPTING TO COLLECT A DEBT
OWED TO OUR CLIENT. ANY INFORMATION OBTAINED FROM YOU WILL BE USED FOR THE
PURPOSE OF COLLECTING THE DEBT.
NOTICE
Notice is given that a judgment in the above- ~captioned matter has been :ntered against you.
Curt Long
Prothonotmy
Deputy
If you have any questions concerning the above, please contact:
Joseph A. Goldbeck, Jr.
Goldbeck McCafferty & McKeever
Suite 500 - The Bourse Bldg.
111 S. Independence Mall East
Philadelphia, PA 19106
215-627-1322
PRAECIPE FOR WRIT OF EXECUTION - (MORTGAGE FORECLOSURE)
P.R.C.P 3180-3183
Joseph A. Goldbeck, Jr.
Attorney I.D.#16132
Suite 500 - The Bourse Bldg.
111 S. Independence Mall East
Philadelphia, PA 19106
215-627-1322
Attorney for Plaintiff
COLUMBIA NATIONAL INC.
7142 Columbia Gateway Drive
Columbia, MD 21046-2132
VS.
BARBARA A. BAER
Mortgagor(s) and Record Owner(s)
346 Lincoln Street
Carlisle, PA 17013
Plaintiff
Defendant(s)
IN THE COURT OF COMMON PLEAS
of Cumberland County
CIVIL ACTION - LAW
ACTION OF MORTGAGE FORECLOSURE
No. 03-1869-CIVIL
PRAECIPE FOR WRIT OF EXECUTION
TO THE PROTHONOTARY:
Issue Writ of Execution in the above matter:
A~ount Due
Interest from
1~)/01/2002 to
05/30/2003 at
6.5000%
(Costs to be added)
$92,350.31
GOLDBECK M~R~y & McKEEVER
BY: oseph A.
Att° eY °r lainV'
ALL THAT CERTAiN TRACT OR LOT OF LAND SITUATE IN THE BOROUGH OF
CARLISLE, CUMBERLAND COUNTY, PENNSYLVANIA, MORE PARTICULARLY
BOUNDED AND DESCRIBED AS FOLLOWS:
BEGINNING AT A POINT ON THE SOUTHEAST CORNER OF AN INTERSECTION
BETWEEN LINCOLN STREET AND AN ALLEY; THENCE ALONG THE SOUTH SIDE OF
LINCOLN STREET, SOUTH 83 DEGREES 57 MINUTES EAST, A DISTANCE OF 49 FEET
TO A POINT; THENCE ALONG THE DIVIDING LINE BETWEEN LOTS 5 AND 6 IN THE
FINAL SUBDIVISION PLAN FOR THE SCHOOL DISTRICT OF CARLISLE, pREPARED
BY LARRY V. NEIDLINGER, R.S. DATED JULY 1, 1985 AND RECORDED NOVEMBER
25, 1985 IN PLAN BOOK 49, PAGE 7, SOUTH 6 DEGREES 30 MINUTES WEST, A
DISTANCE OF 169.35 FEET TO A POINT ALONG THE NORTHERN SIDE OF A 16 FOOT
ALLEY; THENCE NORTH 83 DEGREES 57 MINUTES WEST, ALONG THE NORTHERN
SIDE OF SAID 16 FOOT ALLEY; A DISTANCE OF 49.62 FEET TO A POINT AT THE
NORTHEAST CORNER OF AN INTERSECTION OF TWO ALLEYS; THENCE NORTH 6
DEGREES 15 MINUTES 40 SECONDS EAST ALONG THE EASTERN SIDE OF AN
ALLEY A DISTANCE OF 169.35 FEET TO A POINT, THE SOUTHEAST CORNER OF AN
INTERSECTION OF LINCOLN STREET AND AN ALLEY, THE PLACE OF BEGINNIG.
BEING LOT NO. 6 ON THE FINAL SUBDIVISION PLAN FOR THE SCHOOL DISTRICT
OF CARLISLE, PREPARED BY LARRY V. NEIDLINGER, R.S., DATED JULY 1, 1985,
AND RECORDED IN THE OFFICE OF THE RECORDER OF DEEDS IN AND FOR
CUMBERLAND COUNTY, PENNSYLVANIA, ON NOVEMBER 25, 1985, IN PLAN BOOK
49, PAGE 7.
WRIT OF EXECUTION and/or ATTAC]~IMENT
COMMONWEALTH OF PENNSYLVANIA) NO 03-1869 Civil
COUNTY OF CUMBERLAND) CIVIL ACTION - LAW
TO THE SHERIFF OF CUMBERLAND COUNTY:
To satisfy the debt, interest and costs due COLUMBIA NATIONAL INC., Plaintiff (s)
From BARBARA A. BAER, 346 LINCOLN STREET, CARLISLE, PA 17013
(1) You are directed to levy upon the property of the defendant (s)aml to sell SEE LEGAL
DESCRIPTION.
(2) You are also directed to attach the property o f the defendant(s) not levied upon in the possession
of
GARNISHEE(S) as follows:
and to notify the garnishee(s) that: (a) an attachment has been issued; (b} the garnishee(s) is enjoined from
paying any debt to or for the account of the defendant (s) and from delivering any property of the defendant
(s) or otherwise disposing thereof;
(3) If property of the defendant(s) not levied upon an subject to attachraent is found in the possession
of anyone other than a named garnishee, you are directed to notify him/her that he/she has been added as a
garnishee and is enjoined as above stated.
Amount Due $92,350.31 L.L. $.50
Interest FROM 10/1/02 TO 5/30/03 AT 6.5000%
Atty's Comm % Due Prothy $1.00
Arty Paid $113.45 Other Costs
Plaintiff Paid
Date: JUNE 3, 2003
(Seal)
CURTIS R. LONG
Prothono~
Deputy
REQUESTING PARTY:
Name JOSEPH A. GOLDBECK, JR., ESQUIRE
Address: GOLDBECK McCAFFERTY & McKEEVER
SUITE 500 - THE BOURSE BLDG.
111 S. INDEPENDENCE MALL EAST
PHILADELPHIA, PA 19106
Attorney for: PLAINTIFF
Telephone: 215-627-1322
Supreme Court 1D No. 16132
Goldbeck McCafferty & McKeever
BY: Joseph A. Goldbeck, Jr.
Attorney I.D. #16132
Suite 500 - The Bourse Bldg.
111 S. Independence Mall East
Philadelphia, PA 19106
215-627-1322
Attorney for Plaintiff
COLUMBIA NATIONAL INC.
7142 Columbia Gateway Drive
Columbia, MD 21046-2132
VS.
BARBARA A. BAER
(Mortgagor(s) and Record Owner(s))
346 Lincoln Street
Carlisle, PA 17013
Plaintiff
Defendant(s)
IN THE COURT OF COMMON PLEAS
of Cumberland County
CIVIL ACTION - LAW
ACTION OF MORTGAGE FORECLOSURE
No. 03-1869-CIVIL
AFFIDAVIT PURSUANT TO RULE 3129
COLUMBIA NATIONAL INC., Plaintiffin the above action, by its attorney, Joseph A. Goldbeck, Jr., Esquire, sets
forth as of the date the praecipe for the writ of execution was filed the following information concerning the real property
located at:
346 Lincoln Street
Carlisle, PA 17013
1.Name and address of Owner(s) or Reputed Owner(s):
BARBARA A. BAER
346 Lincoln Street
Carlisle, PA 17013
2. Name and address nf Defendant(s) in the judgment:
BARBARA A. BAER
346 Lincoln Street
Carlisle, PA 17013
3. Name and last known address of every judgment creditor whose judgment is a record lien on the property to be sold:
DOMESTIC RELATIONS OF CUMBERLAND COIINTY
PO Box 320
Carlisle, PA 17013
PA DEPARTMENT OF PUBLIC WELFARE - Bureau of Child Support Enforcement
Health and Welfare Bldg. - Room 432
P.O. Box 2675
Hamsburg, PA 17105-2675
4. Name and address of the last recorded holder of every mortgage of record:
GOLDBECK McCAFFERTY & McKEEVER
BY: Joseph A. Goldbeck, Jr.
Attorney LD.#16132
Suite 500 - The Bourse Bldg.
111 S. Independence Mall East
Philadelphia, PA 19106
215-627-1322
Attorney for Plaintiff
03 - 1869-CIVIL
COLUMBIA NATIONAL INC.
7142 Columbia Gateway Drive
Columbia, MD 21046-2132
vs.
BARBARA A. BAER
Mortgagor(s) and Record Owner(s)
346 Lincoln Street
Carlisle, PA 17013
Plaintiff
Defendant
iN THE COURT OF COMMON PLEAS
of Cumberland County
CIVIL ACTION - LAW
ACTION OF MORTGAGE
FORECLOSURE
Term
No. 03-1869-CIVIL
THIS LAW FIRM IS A DEBT COLLECTOR AND V(E ARE ATTEMI~TING TO
COLLECT A DEBT. THIS NOTICE IS SENT TO YOU EN AN ATTEMPT TO
COLLECT A DEBT. ANY INFORMATION OBTAINED FROM YOU WILL BE
USED FOR THAT PURPOSE.
NOTICE OF S H E RIFF'S SALE OF REAl_, PROPERTY
TO: BAER, BARBARA A.
BARBARA A. BAER
346 Lincoln Street
Carlisle, PA 17013
Your house at 346 Lincoln Street, Carlisle, PA 17013 is scheduled to be sold at Sheriff's Sale on
Wednesday, September 03, 2003, at 10:00 AM, in Commissioners Hearing Rm 2nd FL Courthouse to
enforce the court judgment of $92,350.31 obtained by COLUMBIA NATIONAL INC. against you.
NOTICE OF OWNER'S RIGHTS
YOU MAY BE ABLE TO PREVENT THIS SHERIFF'S SALE
To prevent this Sheriffs Sale you must take immediate action:
1. The sale will be cancelled if you pay to COLUMBIA NATIONAL INC., the back payments, late
charges, costs and reasonable attorney's fees due. To find out how much you must pay call:
215-627-1322
2. You may be able to stop the sale by filing a petition asking the Court to strike or open judgment, if
the judgment was improperly entered. You may also ask the Court to postpone the sale for good cause.
3. You may also be able to stop the sale through other legal proceedings.
03-1869-CIVIL
You may need an attorney to assert your fights. The sooner you contact one, the more chance you
will have of stopping the sale. (See notice below on how to obtain an ttttomey).
YOU MAY STILL BE ABLE TO SAVE YOUR PROPERTY AND YOU HAVE OTHER RIGHTS
EVEN IF THE SHERIFF'S SALE DOES NOT TAKE PLACE.
1. If the Sheriffs Sale is not stopped, your property will be sold to the highest bidder. You may f'md
out the price bid price by calling the Sheriffof 717-240-6390.
2. You may be able to petition the Court to set aside the sale if the bid price was grossly inadequate
compared to the value of your property.
3. The sale will go through only if the buyer pays the Sheriff the full amount due in the sale. To f'md
out if this has happened, you may call the Sheriff of 717-240-6390.
4. If the amount due from the Buyer is not paid to the Sheriff, you will remain the owner of the
property as if the sale never happened.
5. You have a fight to remain in the property until the full amount due is paid to the Sheriff and the
Shefiff gives a deed to the buyer. At that time, the buyer may bring legal proceedings to evict you.
6. You may be entitled to a share of the money which was paid for your house. A schedule of
distribution of the money bid for your house will be filed by the Shefiff thirty (30) days from the date of the
Sheriff's Sale. This schedule will state who will be receiving that money. The money will be paid out in
accordance with this schedule unless exceptions (reasons why the proposed distribution is wrong) are filed
with the Sheriffwithin ten (10) days after the schedule of distribution is filed.
7. You may also have other rights and defenses, or ways of gettktg your house back, if you act
immediately after the sale.
YOU SHOULD TAKE THIS PAPER TO YOUR LAWYER AT ONCE. IF YOU DO NOT HAVE A
LAWYER OR CANNOT AFFORD ONE, GO TO OR TELEPHONE THE OFFICE LISTED BELOW TO
FIND OUT WHERE YOU CAN GET LEGAL HELP.
LEGAL SERVICES 1NC
8 Irvine Row
Carlisle, PA 17013
CUMBERLAND COUNTY BAR ASSOCIATION
2 Liberty Avenue
Carlisle, PA 17013
C¢
¢.0 2D
Columbia National Inc.
VS
Barbara A. Baer
In The Court of Common Pleas of
Cumberland County, Pennsylvania
Writ No. 2003-1869 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.
Sheriff's Costs:
Docketing 30.00
Poundage 40.00
Surcharge 20.00
Law Library .50
Prothonotary 1.00
Mileage 3.45
Levy 15.00
$ 109.95 paid by attorney
6/24/03
Sworn and subscribed to before me
This ] a~ day of
Prothonotary
So An~a:s:,~,
R. Thomas Kline, Sheriff
Real Estate Deputy
Goldbeck McCafferty & McKeever
BY: Joseph A. Goldbeck, Jr.
Attorney I.D. #16132
Suite 500 - The Bourse Bldg.
111 S. Independence Mall East
Philadelphia, PA 19106
215-627-1322
Attorney for Plaintiff
COLUMBIA NATIONAL INC.
7142 Columbia Gateway Drive
Columbia, MD 21046-2132
VS.
BARBARA A. BAER
(Mortgagor(s) and Record Owner(s))
346 Lincoln Street
Carlisle, PA 17013
Plaintiff
Defendant(s)
IN THE COURT OF COMMON PLEAS
of Cumberland County
CIVIL ACTION - LAW
ACTION OF MORTGAGE FORECLOSURE
No. 03-1869-CIVIL
AFFIDAVIT PURSUANT TO RULE 3129
COLUMBIA NATIONAL INC., Plaintiff in the above action, by its attorney, Joseph A. Goldbeck, Jr., Esquire, sets
forth as of the date the praecipe for the writ of execution was filed the following information eonceming the real property
located at:
346 Lincoln Street
Carlisle, PA 17013
1.Name and address of Owner(s) or Reputed Owner(s):
BARBARA A. BAER
346 Lincoln Street
Carlisle, PA 17013
2. Name and address of Defendant(s) in the judgment:
BARBARA A. BAER
346 Lincoln Street
Carlisle, PA 17013
3. Name and last known address of every judgment creditor whose judgment is a record lien on the property to be sold:
DOMESTIC RELATIONS OF CUMBERLAND COUNTY
PO Box 320
Carlisle, PA 17013
PA DEPARTMENT OF PUBLIC WELFARE - Bureau of Child Support Enforcement
Health and Welfare Bldg. - Room 432
P.O. Box 2675
Harrisburg, PA 17105-2675
4. Name and address of the last recorded holder of every mortgage of record:
5. Name and address of every other person who has any record interest in or record lien on the property and whose interest
may be affected by the sale:
6. Name and address of every other person of whom the phfmtiff 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.
TENANTS / OCCUPANTS
346 Lincoln Street
Carlisle, PA 17013
(attach separate sheet if more space is needed)
I verify that the statements made in this affidavit are tree 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: May 30, 2003 'Q~'~ /
GOLDBECKMc~kF~I~Y & McKEEVEK
BY: Joseph A. G{¥ t1'~ Jx~, Esq.
AttomeyforPla'ml~ff ' ~
03 - 1869-CIVIL
GOLDBECK McCAFFERTY & McKEEVER
BY: Joseph A. Goldbeck, Jr.
Attorney I.D.#16132
Suite 500 - The Bourse Bldg.
111 S. Independence Mall East
Philadelphia, PA 19106;
215-627-1322
Attorney for Plaintiff
COLUMBIA NATIONAL INC.
7142 Columbia Gateway Drive
Columbia, MD 21046-2132
IN THE COURT OF COMMON PLEAS
of Cumberland County
Plaintiff
vs.
CIVIL ACTION - LAW
BARBARA A. BAER
Mortgagor(s) and Record Owner(s)
346 Lincoln Street
Carlisle, PA 17013
ACTION OF MORTGAGE
FORECLOSURE
Term
No. 03 - 1869-CIVIL
Defendant(s)
THIS LAW FIRM IS A DEBT COLLECTOR AND WE ARE ATTEMPTING TO
COLLECT A DEBT. THIS NOTICE IS SENT TO YOU IN AN ATTEMPT TO
COLLECT A DEBT. ANY INFORMATION OBTAINED FROM YOU WILL BE
USED FOR THAT PURPOSE.
NOTICE OF S-I~:RIFF'S SALE OF REAL PROPERTY
TO:
BAER, BARBAIZA A.
BARBARA A. BAER
346 Lhicohi Street
Carlisle, PA 17013
Your home at 346 Lincoln Street, Carlisle, PA 17013 is scheduled to be sold at Sheriffs Sale on
Wednesday, September 03, 2003, at 10:00 AM, in Commissioners Hearing Rna 2nd FL Courthouse to
enforce the court judgment of $92,350.31 obtained by COLUMBIA NATIONAL INC. against you.
NOTICE OF OWNER'S RIGHTS
YOU MAY BE ABLE TO PREVENT THIS SHERIFF'S SALE
To prevent this Sheriffs Sale you must take immediate action:
1. The sale will be cancelled if you pay to COLUMBIA NATIONAL INC., the back payments, late
charges, costs and reasonable attorney's fees due. To find out how much you must pay call:
215-627-1322
2. You may be able to stop the sale by ~ing a petition asking the Court to strike or open judgment, if
the judgment was improperly entered. You may also ask the Court to postpone the sale for good cause.
3. You may also be able to stop the sale through other legal proceedings.
ALL THAT CERTAIN TRACT OR LOT OF LAND SITUATE 1N THE BOROUGH OF
CARLISLE, CUMBERLAND COUNTY, PENNSYLVANIA, MORE PARTICULARLY
BOUNDED AND DESCRIBED AS FOLLOWS:
BEGINNING AT A POINT ON THE SOUTHEAST CORNER OF AN INTERSECTION
BETWEEN LINCOLN STREET AND AN ALLEY; THENCE ALONG THE SOUTH SIDE OF
LINCOLN STREET, SOUTH 83 DEGREES 57 MINUTES EAST, A DISTANCE OF 49 FEET
TO A POINT; THENCE ALONG THE DIVIDING LINE BETWEEN LOTS 5 AND 6 IN THE
FINAL SUBDIVISION PLAN FOR THE SCHOOL DISTRICT OF CARLISLE, PREPARED
BY LARRY V. NEIDLINGER, R.S. DATED JULY 1, 1985 AND RECORDED NOVEMBER
25, 1985 IN PLAN BOOK 49, PAGE 7, SOUTH 6 DEGREES 30 M1NUTES WEST, A
DISTANCE OF 169.35 FEET TO A POINT ALONG THE NORTHERN SIDE OF A 16 FOOT
ALLEY; THENCE NORTH 83 DEGREES 57 MINUTES WEST, ALONG THE NORTHERN
SIDE OF SAID 16 FOOT ALLEY; A DISTANCE OF 49.62 FEET TO A POINT AT THE
NORTHEAST CORNER OF AN INTERSECTION OF TWO ALLEYS; THENCE NORTH 6
DEGREES 15 M1NUTES 40 SECONDS EAST ALONG THE EASTERN SIDE OF AN
ALLEY A DISTANCE OF 169.35 FEET TO A POINT, THE SOUTHEAST CORNER OF AN
INTERSECTION OF LINCOLN STREET AND AN ALLEY, THE PLACE OF BEGINNIG.
BEING LOT NO. 6 ON THE FINAL SUBDIVISION PLAN FOR THE SCHOOL DISTRICT
OF CARLISLE, PREPARED BY LARRY V. NEIDL1NGER, R.S., DATED JULY 1, 1985,
AND RECORDED IN THE OFFICE OF THE RECORDER OF DEEDS IN AND FOR
CUMBERLAND COUNTY, PENNSYLVANIA, ON NOVEMBER 25, 1985, IN PLAN BOOK
49, PAGE 7.
WRIT OF EXECUTION and/or ATTACHMENT
COMMONWEALTH OF PENNSYLVANIA) NO 03-1869 Civil
COUNTY OF CUMBERLAND) CIVIL ACTION - LAW
TO THE SHERIFF OF CUMBERLAND COUNTY:
To satisfy the debt, interest and costs due COLUMBIA NATIONAL INC., Plaintiff (s)
From BARBARA A. BAER, 346 LINCOLN STREET, CARLISLE, PA 17013
(1) You are directed to levy upon the property of the defendant (s)and to sell SEE LEGAL
DESCRIPTION.
(2) You are also directed to attach the property of the defendant(s) not levied upon in the possession
of
GARNISHEE(S) as follows:
and to notify the gamishee(s) that: (a) an attachment has been issued; (b) the garnishee(s) is enjoined from
paying any debt to or for the account of the defendant (s) and from delivering any property of the defendant
(s) or otherwise disposing thereof;
(3) If property of the defendant(s) not levied upon an subject to attachment is found in the possession
of anyone other than a named garnishee, you are directed to notify him/her that he/she has been added as a
garnishee and is enjoined as above stated.
Amount Due $92,350.31 L.L. $.50
Interest FROM 10/1/02 TO 5/30/03 AT 6.5000%
Atty's Comm % Due Prothy
Atty Paid $113.45 Other Costs
Plaintiff Paid
Date: JUNE 3, 2003
(Seal)
CURTIS R. LONG
Prothonot/a~
Deputy
$1.00
REQUESTING PARTY:
Name JOSEPH A. GOLDBECK, JR., ESQUIRE
Address: GOLDBECK McCAFFERTY & McKEEVER
SUITE 500 - THE BOURSE BLDG.
111 S. INDEPENDENCE MALL EAST
PHILADELPHIA, PA 19106
Attorney for: PLAINTIFF
Telephone: 215-627-1322
Supreme Court 1D No. 16132
Real Estate Sale # 42
On June 6, 2003 the sherifflevied upon the
defendant's interest in the real property situated in
Carlisle Borough, Cumberland County, PA
known and numbered as 346 Lincoln Street,
Carlisle, more fully described on Exhibit "A"
filed with this writ and by this reference incorporated herein.
Date: June 6, 2003
By: jOC~ ~1
Real Estate Deputy