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HomeMy WebLinkAbout01-0251 FX .\ >~ .~ FEDERMAN AND PHELAN, LLP By: FRANK FEDERMAN, ESQUIRE IDENTIFICATION NO. 12248 ONE PENN CENTER AT SUBURBAN STATION 1617 JOHN F. KENNEDY BOULEVARD SUITE 1400 PHILADELPHIA, PA 19103-1814 (215) 563-7000 ATTORNEY FOR PLAINTIFF COURT OF COMMON PLEAS CIVIL DIVISION FIRST HORIZON HOME LOAN CORPORATION, FIK/A FT MORTGAGE COMPANIES, D/B/A MNC MORTGAGE 4000 HORIZON WAY, IRVING, TX 75063 TERM Plaintiff NO. 61- J-.tn ~L v. CUMBERLAND COUNTY VICKI BOUDMAN C. BLAINE BOUDMAN 26 WEST EPPLEY DRIVE, CARLISLE, P A 17013 Defendant( s) CIVIL ACTION - LAW COMPLAINT IN MORTGAGE FORECLOSURE NOTICE **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 AND TillS DEBT WAS NOT REAFFIRMED, THIS CORRESPONDENCE IS NOT AND SHOULD NOT BE CONSTRUED TO BE AN ATTEMPT TO COLLECT A DEBT, BUT ONLY ENFORCEMENT OF A LIEN AGAINST PROPERTY. ** 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 this 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 TIllS 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 CUMBERLAND COUNTY BAR ASSOCIATION 2 LIBERTY AVENUE CARLISLE,PA 17013 (717) 249-3166 Loan #: 0009165861 I" - ",.'1' , .' 1. Plaintiff is: FIRST HORIZON HOME LOAN CORPORATION, FIKI A FT MORTGAGE COMPANIES, DIBIA MNC MORTGAGE 4000 HORIZON WAY, IRVING, TX 75063 2. The name(s) and last known addressees) of the Defendant(s) are: VICKI BOUDMAN C. BLAINE BOUDMAN 26 WEST EPPLEY DRIVE, CARLISLE, PA 17013 who is/are the mortgagor(s) and real owner(s) of the property hereinafter described. 3. On 12/11/97 mortgagor(s) made, executed and delivered a mortgage upon the premises hereinafter described to PLAINTIFF which mortgage is recorded in the Office of the Recorder of CUMBERLAND County, in Mortgage Book No. 1421, Page 1103. 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 1/1/00 and each month thereafter are due and unpaid, and by the terms of said mortgage, upon failure of mortgagor to make such payments after a date specified by written notice sent to Mortgagor, the entire principal balance and all interest due thereon are collectible forthwith. A copy of such notice is attached as Exhibit" A." .,,~ - --', , L-. , -, ~ I" ,.~- ~= 6. The following amounts are due on the mortgage: Principal Balance Interest 12/1/99 through 12/1/00 (Per Diem $32.08) Attorney's Fees Cumulative Late Charges 12/11/97 to 12/1/00 Cost of Suit and Title Search Subtotal $159,283.96 11,741.28 4,000.00 786.04 750.00 $176,561.28 Escrow Credit Deficit Subtotal TOTAL 0.00 1.498.46 $1.498.46 $178,059.74 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. 8. This action does not come under Act 6 of 1974 because the original mortgage amount exceeds $50,000.00. 9, The Combined Notice has been sent to the Defendant(s) by regular and certified mail as required by 35 P.S. g1680.403c on the date(s) set forth in the true and correct copy of such notice(s) attached hereto as Exhibit "A." 10. The Temporary Stay as provided by the Homeowner's Emergency Mortgage Assistance Program, Act 91 of 1983, has terminated because either: (i.) Defendant(s) have failed to meet with the Plaintiff or an authorized Credit Counseling Agency in accordance with Plaintiff s written Notice to Defendants, a true and correct copy of which is attached hereto as Exhibit "A"; or (ii.) Defendant(s) application for assistance has been rejected by the Pennsylvania Housing Finance Agency. WHEREFORE, PLAINTIFF demands an in rem Judgment against the Defendant(s) in the sum of $178,059.74, together with interest from 12/1/00 at the rate of$32.08 per diem to the date of Judgment, and other costs and charges collectible under the mortgage and for the foreclosure and sale of the mortgaged property. ~:r~ /s7 Frank Federman FRANK FEDERMAN, ESQUIRE Attorney for Plaintiff "~~r- r 1'1 ~- . FIRST HORIZON HOME LOANS 4000 HORIZON WAY IRVING, TX 75063 11/7/00 VICKI BOUDMAN 26 WEST EPPLEY DRIVE CARLISLEPA 17013 ACT 91 NOTICE TAKE ACTION TO SAVE YOUR HOME FROM FORECLOSURE This is an official notice that the mortgage on your home is in default. and the lender intends to foreclose. Specific information about the nature of the default is provided in the attached pages. The HOMEOWNER'S MORTGAGE ASSISTANCE PROGRAM (HEMAP) may be able to help to save your home. This notice explains how the program works. To see if HEMAP can help. you must MEET WITH A CONSUMER CREDIT COUNSELING AGENCYWITHIN 30 DAYS OF THE DATE OF THIS NOTICE. Take this notice with you when you meet with the Counseling Agencv. The name. address and phone number of Consumer Credit Counseling Agencies serving your County are listed at the end of this Notice. Ifvou have any Questions. YOU may call the Pennsvlvania Housing Finance Agencv toll free at 1-800-342-2397. (Persons with impaired hearing can call (707) 780-1869). This Notice contains important legal information. If you have any questions, representatives at the Consumer Credit Counseling Agency may be able to help explain it. You may also want to contact an attorney in your area. The local bar association may be able to help you fmd a lawyer. LA NOTIICACION EN EDJUNTO ES DE SUMA IMPORTANClA, PUES AFECTA SU DERECHO A CONTINUAR VIVIENDO EN SU CASA. SI NO COMPRENDE EL CONTENIDO DE ESTA NOTIFICACION OBTENGA UNA TRADUCCION IMMEDITAMENTE LLAMANDO ESTA AGENCIA (pENNSYL VIAN HOUSING FINANCE AGENCY) SIN CARGOS AL NUMBERO MENCIONADO ARRIBA. PUEDES SER ELEGIBLE PARA UN PREST AMO POR EL PROGRAMA LLAMADO "HOMEOWNER'S EMERGENCY MORTGAGE ASSISTANCE PROGRAM" EL CUAL PUEDE SAL V AR SU CASA DE LA PERDIDA DEL DERECHO A REDIMIR SU HIPOTECA. ~H\B\T A ~u.... . e " ,-, "f FIRST HORIZON HOME LOANS 4000 HORIZON WAY IRVING, TX 75063 11/7/00 C BLAINE BOUDMAN 26 WEST EPPLEY DRIVE CARLISLEPA 17013 S/31 lIoDjrvdr ACT 91 NOTICE TAKE ACTION TO SAVE YOUR HOME FROM FORECLOSURE This is an official notice that the mortgage on your home is in default. and the lender intends to foreclose. Specific information about the nature of the default is provided in the attached pages. The HOMEOWNER'S MORTGAGE ASSISTANCE PROGRAM (REMAP) maY be able to help to save your home. This notice explains how the program works. To see ifHEMAP can help. YOU must MEET WITH A CONSUMER CREDIT COUNSELING AGENCYWITHIN 30 DAYS OF TRE DATE OF THIS NOTICE. Take this notice with YOU when you meet with the Counseling Agencv. The name. address and phone number of Consumer Credit Counseling Agencies serving your County are listed at the end of this Notice. Ifvou have any auestions. YOU may call the Pennsylvania Housing Finance Agencv toll free at 1-800-342-2397. (Persons with impaired hearing can call (707) 780-1869). This Notice contains important legal information. If you have any questions, representatives at the Consumer Credit Counseling Agency may be able to help explain it. You may also want to contact an attorney in your area. The local bar association may be able to help you fmd a lawyer. LA NOTIICACION EN EDJUNTO ES DE SUMA IMPORTANCIA, PUES AFECTA SU DERECHO A CONTINUAR VIVIENDO EN SU CASA. SI NO COMPRENDE EL CONTENIDO DE ESTA NOTIFICACION OBTENGA UNA TRADUCCION IMMEDITAMENTE LLAMANDO ESTA AGENCIA (PENNSYL VIAN HOUSING FINANCE AGENCY) SIN CARGOS AL NUMBERO MENCIONADO ARRIBA. PUEDES SER ELEGIBLE PARA UN PRESTAMO POR EL PROGRAMA LLAMADO "HOMEOWNER'S EMERGENCY MORTGAGE ASSISTANCE PROGRAM" EL CUAL PUEDE SAL V AR SU CASA DE LA PERDIDA DEL DERECHO A REDIMIR SU HIPOTECA. eXH\B\l A. ~ . ~--<,~ ',[ , '?1- ".- . C BLAINE BOUDMAN 26 WEST EPPLEY DRIVE CARLISLE PA 17013 ACCT #9165861 FIRST HORIZON HOME LOANS HOWEOWNER'S EMERGENCY MORTGAGE ASSISTANCE PROGRAM YOU MAY BE ELIGIBLE FOR FINANCIAL ASSISTANCE WHICH CAN SAVE YOUR HOME FROM FORECLOSURE AND HELP YOU MAKE FUTURE MORTGAGE PAYMENTS IF YOU COMPLY WITH THE PROVISIONS OF THE HOMEOWNER'S EMERGENCY MORTGAGE ASSISTANCE ACT OF 1983 (THE" ACT"), YOU, MAYBE ELIGIBLE FOR EMERGENCY MORTGAEG ASSISTANCE: "IF YOUR DEFAULT HAS BEEN CAUSED BY CIRCUMSTANCES BEYOND YOUR CONTROL, "IF YOU HAVE A REASONABLE PROSPECT OF BEING ABLE TO PAY YOUR MORTGAE PAYMENTS, AND "IF YOU MEET OTHER ELIGIBILITY REQUIREMENTS ESTABLISHED BY THE PENNSYLVANIA HOUSING FINANCE AGENCY. TEMPORARY STAY OF FORECLOSURE-Under the Act, you are entitled to a temporary stay of foreclosure on your mortgage for thirty (30) days from the date of this Notice. During that time you must arrange and attend a "face-to-face" meeting with one of the consumer credit counseling agencies listed at the end of this Notice. TIDS MEETING MUST OCCUR WITIDN THE NEXT (30) DAYS. IF YOU DO NOT APPLY FOR EMERGENCY MORTGAGE ASSISTANCE. YOU MUST BRING YOUR MORTGAGE UP TO DATE. THE PART OF THIS NOTICE CALLED "HOW TO CURE YOUR MORTGAGE DEFAULT', EXPLAINS HOW TO BRING YOUR MORTGAE UP TO DATE. CONSUMER CREDIT COUNSELING AGENCIES-If you meet with one of the consumer credit counseling agencies listed at the end of this notice, the lender may NOT take action against you for thirty (30) days after the date of this meeting. The names, addresses and telephone numbers of designated consumer credit counseline aeencies for the county in which the propertY is located are set forth at the end of this Notice. It is only necessary to scbedule one face-to-face meeting. Advise your lender immediatelv of your intentions. APPLICATION FOR MORTGAGE ASSIST ANCE- Your mortgage is in default for the reasons set forth later in this Notice (see following pages for specific information about the nature of your default). I you have tried and are unable to resolve this problem with the lender, you have the right to apply for ["mancial assistance from the Homeowner's Emergency Mortgage Assistance Program. To do so, you must fill out, sign and file a completed a completed Homeowner's Emergency Mortgage Assistance Program Application with one of the designated consumer credit counseling agencies listed at the end of this Notice. Only consumer credit counseling agencies have applications for the program and they will assist you in submitting a complete application to the Pennsylvania Housing Finance Agency. Your application MUST be filed or postmarked within thirty (30) days of your face-to-face meeting. YOU MUST FILE YOUR APPLICATION PROMPTLY. IF YOU FAIL TO DO SO OR IF YOU DO NOT FOLLOW THE OTHER TIME PERIODS ET FORTH IN THIS LETTER, FORECLOUSRE MAY PROCEED AGAINST YOUR HOME IMMEDIA TEL Y AND YOUR APPLICATION FOR MORTGAGE ASSISTANCE WILL BE DENIED. CXHIBIT A ~,.,.~ ~~ '1'" AGENCY ACTION- Available funds for emergency mortgage assistance are very limited. They will be disbursed by the Agency under the eligibility criteria established by the Act. The Pennsylvania Housing Finance Agency has sixty (60) days to make a decision after it receives your application. During that time, no foreclosure nroceediDf!:s will be nursued against vou if vnu have met the time reauirements set forth above. You will be notified directly by the Pennsylvania Housing Finance Agency of its decision on your application. NOTE: IF YOU ARE CURRENTLY PROTECTED BY THE FILING OF A PETITION IN BANKRUPTCY, THE FOLLOWING PART OF THIS NOTICE IS FOR INFORMATION PURPOSES ONLY AND SHOULD NOT BE CONSIDERED AS AN ATTEMPT TOCOLLECT THE DEBT. (If you have filed bankruptcy you can still apply for Emergency Mortgage Assistance). HOW TO CURE YOUR MORTGAGE DEFAULT (Brin!! it np to date). NATURE OF THE DEFAUL T- The MORTGAGE debt held by the above lender on your property located at: 26 WEST EPPLEY DRIVE CARLISLE PA 17013 IS SERIOUSLY IN DEF AUL T because: A. YOU HAVE NOT MADE MONTHLY MORTGAGE PAYMENTS for the following months and the following amounts are now past due: Due 111100-11/1100 Payment Amount Due = $14371.06 Late Charges $786.04 Other charges (explain/itemize): Bad Check Fee $ 0.00 Other Fees $96.98 Minus Suspense = $ 0.00 TOTAL AMOUNT PAST DUE: $ 15254.08 B. YOU HAVE FAILED TO TAKE THE FOLLOWING ACTION (Do not use if not applicable): HOW TO CURE THE DEFAULT-You may cure the default within THIRTY (30) days of the date of this notice BY P A YNG THE TOTAL AMOUNT PAST DUE TO THE LENDER, WHICH IS $ 15254.08 MORTGAGE PAYMENTS AND LATE CHARGES WHICH BECOME DUE DURING THE (30) DAY PERIOD. Payments must be made either by cash, cashier's check, certified check or money order made payable and sent to: First Horizon Home Loans 4000 Horizon Way Irving, TX 75063 Attn: Cashiering You can cure any other default by taking the following action within THIRTY (30) DAYS of the date of this letter: (Do not use ifnot annlicable.) f$XHJBIT Ae, ~r ~"~ I I ~ l~ "' ~-~,.... ~~ "-~ ._~=..!':\ IF YOU DO NOT CURE THE DEF AUL T -If you do not cure the default within TIDRTY (30) DAYS of the date of this Notice, the lender intends to exercise its ril!hts to accelerate the mortl!al!e debt. This means that the entire outstanding balance of this debt will be considered due immediately and you may lose the chance to pay the mortgage in monthly instalhnents. If full payment of the total amount past due is not made within THIRTY (30) DAYS, the lender also intends to instruct its attorneys to start legal action to foreclose unon vour mortl!al!ed propertv. IF THE MORTGAGE IS FORECLOSED UPON-The mortgaged property will be sold by the Sheriff to pay off the mortgage debt. If the lender refers your case to it's attorneys, but you cure the delinquency before the lender begins legal proceedings against you, you will still be required to pay the reasonable attorney's fees that were actually incurred, up to $50.00. However, if legal proceedings are started against you, you will have to pay all reasonable attorney's fees actually incurred by the lender even if they exceed $50.00. Any attorney's fees will be added to the amount you owe the lender, which may also include other reasonable costs. Ifvou cure the default within the THIRTY (30) DAY period. YOU will not be required to pav attorney's fees. OTHER LENDER REMEDIES-The lender may also sue you personally for the unpaid principal balance and all other sums due under the mortgage. RIGHT TO CURE THE DEFAULT PRIOR TO SHERIFF'S SALE-If you have not cured the default within the THIRTY (30) DAY period and foreclosure proceedings have begun, YOU still have the ril!ht to cure the default and prevent the sale at anv tie un to one hour before the Sheriff's Sale. You mav do so bv pavinl! the total amount then past due. plus anv late or other charl!es then due. reasonable attornev's fees and costs connected with the foreclosure sale and any other costs connected with Sheriff's Sale as snecified in writinl! by the lender and by perfonninl! any other requirements under the mortl!al!e. Curing your default in the manner set forth in this notice will restore your mortgage to the same position as if you had neyer defaulted. EARLIEST POSSIBLE SHERIFF'S SALE DATE-It is estimated that the earliest date that such a Sheriff's Sale of the mortgaged property could be held would be approximately Y _months from the date ofthis Notice. A notice of the actual date of the Sheriffs Sale will be sent to you before the sale. Of course, the amount needed to cure the default will increase the longer you wait. You may frod out at any time exactly what the required payment or action will be by contacting the lender. HOW TO CONTACT THE LENDER: First Horizon Home Loans 4000 Horizon Way Irving, TX 75063 Attn: Loan Counseling Dept. 1-800-707-9998 /Phone 1-214-672-3922/Fax EFFECT OF SHERIFF'S SALE- You should realize that a Sheriff's Sale will end your ownership of the mortgaged property and your right to occupy it. If you continue to live in the property after the Sheriff's Sale, a lawsuit to remove you and your furnishings and other belongings could be started by the lender at anytime. ASSUMPTION OF MORTGAGE-You _x_ mayor _ may not (CHECK ONE) sell or transfer your home to a buyer or transferee who will assume the mortgage debt, provided that all the outstanding payments, charges and attorney's fees and costs are paid prior to or at the sale and that the other requirements of the mortgage are satisfied. t>{HIBIT A ~."~"""" YOU MAY ALSO HAVE THE RIGHT .TO SELL THE PROPERTY TO OBTAIN MONEY TO PAYOFF THEMORTGAE DEBT OR TO BORROWER MONEY FROM ANOTHER LENDING INSTITUTION TO PAY OFF 1HIS DEBT. .TOHAVE 1HIS DEFAULT CURED BY ANY THIRT PARTY ACTING ON YOURBEHLF. .TO HAVE THEMORTGAGE RESTORED TO THE SAME POSITOIN AS IF NO DEF AUL THAD OCCURRED, IF YOU CURE THE DEFAULT. (HOWEVER YOU DO NOT HAVE 1HIS RIGHT TO CURE YOUR DEFAULT MORE THAN THREE TIMES IN ANY CALENDAR YEAR.) .TO ASSERT THE NONEXISTENCE OF A DEF AUL T IN ANY FORECLOUSRE PROCEEDING OR ANY OTHER LAWSUIT INSTITUTED UNDER THE MORTGAGE DOCUMENTS. .TO ASSERT ANY OTHER DEFENSE YOU BELIEVE YOU MA Y HAVE TO SUCH ACTION BY THE LENDER. .TO SEEK PROTECTION UNDER THE FEDERAL BANKRUPTCY LAW. Sincerely, Cartier A. Caldwell Default Referral Specialist II CXHlSIT A ,<." ". -1-_1' , "" ~ PENNSYLVANIA HOUSING FINANCE AGENCY HOMEOWNER'S EMERGENCY ASSISTANCE PROGRAM CONSUMER CREDIT COUNSELING AGENCIES (REV. 8/00) CLINTON COUNTY Lycoming~linton Counties Commision for Community Action (STEP) 2138 Lincoln Street P.O, Box 1328 WiIliamsport, P A 17703 (570) 326-1)587 FAX (570) 322-2197 CCCS of Northeastern P A 1631 South Atherton St, Suite 100 State College, PA 16801 (814) 238-3668 FAX (814) 238-3669 CCCS of Northeastern PA 20 I Basin Street WiIliamsport, P A 17703 (570) 323-6627 FAX (570) 323-6626 COLUMBIA COUNTY 31 W. Market Street POB 1127 Wilkes-Barre, P A 18702 (570) 821-0837 or (800) 922-9537 FAX (570) 821-1785 1400 Abington Executive Park: Suite I Clarks Summit PA 18411 (570) 587-9163 or (800) 922-9537 FA..,( (570) 587-9134-9135 Commission on Economics Opportunity ofLuzeme County 163 Amber Lane Wilkes-Barre, P A 18702 (570) 826-1)51 0 or (800) 822-1)359 FAX (570) 829-1665-(Call Before Faxing) (570) 4554994 Hazeltown FAX (570) 455-5631-(Call Before Faxing) (570) 8364090 Tunkhannock CRAWFORD COUNTY Greater Erie Community Action Committee 18 West 9th Street Eric. PA 16501 (814) 4594581 FAX (814) 456-0161 Booker T. Washington Center 1720 Holland Center Eric, P A 16503 (814) 453-5744 FAX (814) 5749 John F. Kennedy Center, Inc. 2021 East 20. Street Erie, PA 16510 (814) 898-0400 FAX (814) 898-1243 Shenango Valley Urban League, Inc. 601 Indiana Avenue Farrell, PA 16121 (412) 981-5310 CUMBERLAND COUNTY Financial Counseling Setvices of Franklin 31 West 3rd Street . Waynesboro, PA 17268 (717)762-3285 eees of Western PeMsylvania, Inc. 2000 Linglestown Road Harrisburg, PA 17102 (717) 541-1757 Urban League of Metropolitan Harrisburg N. 6m Street Harrisburg, PA 17101 (717)234-5925 FAX (717) 234-9459 YWCA of Carlisle 301 "G" Street Carlisle, P A 17013 . (717) 243-3818 FAX (717) 731-9589 Community Action Comm of the Capital Region 1514 Derry Street Harrisburg, PA 17104 (717) 232-9757 FAX (717) 234-2227 Adams County Housing Authority 139-143 Carlisle St GettySburg, P A 17325 (717) 334-1518 FAX 334-8326 PENNSYL VANIA BULLETIN, VOL. 29, NO. 23, JUNE 5, 1999 8)l\4\B\1 A '~ ALL T~T CERTA~N ~ract of ~ana s~tuata ~n south M~dd~eton Townsh~p, cumbe~~and County, Pennsy1van~a~ bounded and described in a~cordanoe w~th a survey prepared by John K. Box~ar. XXX, R.B., dated 2/2s/56 and recorded ~n the Off1ee of the Recorder of Deeds for Cumber~and County in P~an Book 72 page ~~5, rev~sed 4/10/56, as follows: BEGINN~NG a~ an iron ~in on the northern r~ght of way ~ine of West Eppley Drive at a corner of Lot 35. Se~tion 2-A, on the plan of Forgedale Crossing; thence along Lot 35, North 03 degrees ~7 minutes and 0& seconds west, a dist.ance of J.50. 00 .feet:. to a.n iron pin; t.hence a.~ong Lot 30 -A., Phase I, NQrth 86 degrees 42 minuees and 52 seconds Sase, a distance of 100.00 feee to an"iron pin; thence along Lot 33, section 2-A, South 03 ~e9rees 17 minutes and 08 seconds East, a distance Of ~51.02 feee to an. iren pin on che norehern righ~ of way ~~ne of Wes~ Epp~ey Or~ve; thence a~ong ssid northern right of way line of west Eppley Dr~ve, by a curve to =he left having a radius of 495.00 feet and are distance of 3~.B5 feet to a ?o~nt ~n tne ~ight of way 1~n&; thence ~ontinu~ng along tha nortbern r~ght ~f way line of West Eppley DrLve, South 86 degrees 42 mLnutes and 52 seconds We$t, a d~stance Qf 6a~~e fee~ to an iron pin at Lot 35, Section 2- 'I., the pla"'''' of BEGXNN~NG'. . ::ONTAINING :!.5,OOO.00,..,.:square feet and d"'s~g"a.ted as Lot 34, Sect:Lon 2-A of ?lan of ~o~gedale CrOSSing. 3EING THE SAME PREMXSES WHICH John E. Anderson and Pauline E. Anderson. ~usband ano wife, and Robert A. Thomas and Oeborah J. Thomas, husband and ~ife, by deed dated 6/23/97 and recorded 6/26/s7 Ln the Recorder of Deeds JffLCe, in and for Cumberland County. Pennsylvania, in ReCord Book :1.60 page ~G g~&nted and conveyed unto S & A Custom BU11t Homes. Inc.. grantor :1.erei.n. PREMISES ON: 26 WEST EPPLEY DRIVE, CARLISLE, PA 17013 '~:=~, ~~ . 'I- ~. - :~ -~""ffl-~ VERIFICATION RICHARD MINOR hereby states that he is ASSISTANT V.P. of FIRST HORIZON HOME LOANS CORPORATION mortgage servicing agent for Plaintiff in this matter, that he is authorized to take this Verification, and that the statements made in the foregoing Civil Action in Mortgage F orec1osure are true and correct to the best of his knowledge, infonnation and belief. The undersigned understands that this statement is made subject to the penalties of 18 Pa. C.s. Sec. 4904 relating to unsworn falsification to authorities. DATE: 1/ ~/t? I . 1-" ., II I! ~ , ~ . _~'-'_ w "_, " . '~e~'~~' C' - ", - ,_, " -I'--~- ,-~,. ~-'~"'-' <', '" < _''''-'''''''''~a'~'~__'''''"_'_''"__'' ''''<' ~ "-"'-',"' '''''.IIC ~ ~ ~ tv ~ ~ -:;::j c-~l --.. C J " ~ f' -- -,'" ." b SJ ,. - \t; c. -. ;::"J C t1 ~ 'Y-, -~-~ " :.,' ~d" ( -' (~') .._I /::- ):-, :;: :':!] . "@ -~ ~.~ f ~,} f()Ct ~ J~f t-~. ~t) ~ ~ ~,'~~'_'ll!i!l . ". 'c!!}!\lli~ ",",1IIlm .~_ ",l''l)!IIl!I\i~'''';W,,"lI"''j(,L'~'''',i"~.'''nTiw;rc''i~X'''''W4r\'<~W~~~~!lit!~~ill!l'!M~i SHERIFF'S RETURN - NOT FOUND . . C~SE NO: 2001-00251 P COMMONWEALTH OF PENNSYLVANIA COUNTY OF CUMBERLAND FIRST HORIZON HOME LOAN CORP VS BOUDMAN VICKI 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 BOUDMAN VICKI but was unable to locate Her in his bailiwick. He therefore returns the COMPLAINT - MORT FORE NOTICE , NOT FOUND , as to the within named DEFENDANT , BOUDMAN VICKI DEFENDANT NO LONGER RESIDES AT ADDRESS STATED DID NOT RECEIVE FURTHER INSTRUCTIONS FROM ATTY. PRIORTO EXP. DATE, RETURN NOT FOUND AS PER JASON RICCO ON 2/23/01. Sheriff's Costs: Docketing Service Not Found Return Surcharge 18.00 3.10 5.00 10.00 .00 36.10 :O2'"~~ Sheriff of Cumberland County FEDERMAN & PHELAN 02/23/2001 Sworn and subscribed to before me this .z 'J "to. day of J...(..$". e "I .J.lX> \ A . D . n ~' R '---rVI, gp,., . n~ p~oth notary I ''-'('''1 .I""'-l! ,~~~, 'I i , 11 '- SHERIFF'S RETURN - NOT FOUND CASE NO: 2001-00251 P COMMONWEALTH OF PENNSYLVANIA COUNTY OF CUMBERLAND FIRST HORIZON HOME LOAN CORP VS BOUDMAN VICKI 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 BOUDMAN C BLAINE but was unable to locate Him in his bailiwick. He therefore returns the COMPLAINT - MORT FORE NOTICE , NOT FOUND , as to the within named DEFENDANT , BOUDMAN C BLAINE DEFENDANT NO LONGER RESIDES AT ADDRESS STATED, DID NOT RECEIVE FURTHER INSTRUCTIONS FROM ATTY PRIOR ~O EXP. DATE, RETURN NOT FOUND AS PER JASON RICCO ON 2/23/01. Sheriff's Costs: Docketing Service Not Found Return Surcharge 6.00 .00 5.00 10.00 .00 21.00 ~-L~ ~ --~-~t.--:> R. Thomas Kline Sheriff of Cumberland County FEDERMAN & PHELAN 02/23/2001 Sworn and subscribed to before me this "l 7~ day of.1L t"H , ] .:u'?>/ A.D. ('1 .~Q Ivr,!p" ~ ~honotary I ~- , '\ '\, <j', .. FEDERMAN AND PHELAN, LLP By: FRANK FEDERMAN, ESQUIRE IDENTIFICATION NO. 12248 ONE PENN CENTER AT SUBURBAN STATION 1617 JOHN F. KENNEDY BOULEVARD SUITE 1400 PHILADELPHIA, PA 19103-1814 (215) 563-7000 FlRST HORIZON HOME LOAN CORPORATION, FfKJ A FT MORTGAGE COMPANIES, D/B/A MNC MORTGAGE 4000 HORIZON WAY, lRVING, TX 75063 ATIORNEY FOR PLAINTIFF COURT OF COMMON PLEAS CIVIL DIVISION Plaintiff TERM NO. (){-d6/ ~, v. CUMBERLAND COUNTY VICKI BOUDMAN C. BLAINE BOUDMAN 26 WEST EPPLEY DRIVE, CARLISLE, P A 17013 Defendant( s) CIVIL ACTION - LAW COMPLAINT INMORTGAGE FORECLOSURE NOTICE We hereby certify the within to be " true llfld **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 AND THIS DEBT WAS NOT REAFFIRMED, THIS CORRESPONDENCE IS NOT AND SHOULD NOT BE CONSTRUED TO BE AN ATTEMPT TO COLLECT A DEBT, BUT ONLY ENFORCEMENT OF A LIEN AGAINST PROPERTY. ** 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 this 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 TillS PAPER TO YOUR LAWYER AT ONCE. IF YOU DO NOT _a HAVE A LAWYER OR CANNOT AFFORD ONE, GO TO OR TELEPHONE THE OFFICE _O~., SET FORTH BELOW TO FIND OUT WHERE YOU CAN GET LEGAL HELP. ~fJ #o<:&,fJ7 ~~~~#')Y/ 2 LIBERTY AVENUE CARLISLE, P A 17013 (717) 249-3166 Loan #: 0009165861 )'W"'>""~ )Jllr~ .~ r~ 7__"" """ ~>'.''''''''''"'-'''''~'"''''''~P''''1~ " .. 1. Plaintiff is: FIRST HORIZON HOME LOAN CORPORATION, FIK/ A FT MORTGAGE COMPANIES, D/BIA MNC MORTGAGE 4000 HORIZON WAY, IRVING, TX 75063 2. The name(s) andlast known addressees) of the Defendant(s) are: VICKI BOUDMAN C. BLAINE BOUDMAN 26 WEST EPPLEY DRIVE, CARLISLE, PA 17013 who is/are the mortgagor(s) and real owner(s) of the property hereinafter described. 3. On 12/11/97 mortgagor(s) made, executed and delivered a mortgage upon the premises hereinafter described to PLAINTIFF which mortgage is recorded in the Office of the Recorder of CUMBERLAND County, in Mortgage Book No. 1421, Page 1103. 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 1/1/00 and each month thereafter are due and unpaid, and by the terms of said mortgage, upon failure of mortgagor to make such payments after a date specified by written notice sent to Mortgagor, the entire principal balance and all interest due thereon are collectible forthwith. A copy of such notice is attached as Exhibit "A." -''-'JM:J ^ - -:".,,'-'0 '--1- '1 , ~~~ ~_ " ~ "'0+ ~~~=, ~,,,~M_"',,,,- ~ .. 6. The following amounts are due on the mortgage: Principal Balance Interest 1211/99 through 1211/00 (Per Diem $32.08) Attorney's Fees Cumulative Late Charges 12/11/97 to 12/1/00 Cost of Suit and Title Search Subtotal $159,283.96 11,741.28 4,000.00 786.04 750.00 $176,561.28 Escrow , Credit Deficit Subtotal 0.00 1.498.46 $1.498046 TOTAL $178,059.74 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. 8. This action does not come under Act 6 of 1974 because the original mortgage amount exceeds $50,000.00. 9. The Combined Notice has been sent to the Defendant(s) by regular and certified mail as required by 35 P.S. S 16800403c on the date(s) set forth in the true and correct copy of such notice(s) attached hereto as Exhibit "A." 10. The Temporary Stay as provided by the Homeowner's Emergency Mortgage Assistance Program, Act 91 of 1983, has terminated because either: (i.) Defendant(s) have failed to meet with the Plaintiff or an authorized Credit Counseling Agency in accordance with Plaintiff s written Notice to Defendants, a true and correct copy of which is attached hereto as Exhibit "A"; or (ii.) Defendant(s) application for assistance has been rejected by the Pennsylvania, Housing Finance Agency. WHEREFORE, PLAINTIFF demands an in rem Judgment against the Defendant(s) in the sum of $178,059.74, together with interest from 12/1100 at the rate of$32.08 per diem to the date of Judgment, and other costs and charges collectible under the mortgage and for the foreclosure and sale of the mortgaged property. /s/ Frank Federman FRANK FEDERMAN, ESQUIRE Attorney for Plaintiff ',,~~ -- ~~"f' 0' ~I _1 .~~ - ~,-^... ~~,~~~ 11:~~r, . . FIRST HORIZON HOME LOANS 4000 HORIZON WAY IRVING, TX 75063 11/7/00 VICKI BOUDMAN 26 WEST EPPLEY DRIVE CARLISLE PA 17013 ACT 91 NOTICE TAKE ACTION TO SAVE YOUR HOME FROM FORECLOSURE This is an official notice that the mortgage on vour home is in default. and the lender intends to foreclose. Soecific infonnation about the nature of the default is provided in the attached pages. The HOMEOWNER'S MORTGAGE ASSISTANCE PROGRAM (HEMAP) mav be able to help to save vour home. This notice explains how the program works. To see ifHEMAP can help. vou must MEET WITH A CONSUMER CREDIT COUNSELING AGENCYWITHIN 30 DAYS OF THE DATE OF THIS NOTICE. Take this notice with vou when you meet with the Counseling Agencv. The name. address and phone number of Consumer Credit Counseling Agencies serving vour County are listed at the end of this Notice. Ifvou have anv questions. vou mav call the Pennsvlvania Housing Finance Agencv toll free at 1-800-342-2397. (Persons with impaired hearing can call (707) 780-1869). This Notice contains impottantlegal infonnation. If you have any questions, representatives at the Consumer Credit Counseling Agency may be able to help explain it. You may also want to contact an attorney in your area. The local bar association may be able to help you frod a lawyer. LA NOTIICACION EN EDJUNTO ES DE SOMA IMPORTANCIA, PUES AFECTA SU DERECHO A CONTINUAR VIVIENDO EN SU CASA. SI NO COMPRENDE EL CONTENIDO DE ESTA NOTIFICACION OBTENGA UNA TRADUCCION IMMEDITAMENTE LLAMANDO ESTA AGENCIA (PENNSYL VIAN HOUSING FINANCE AGENCY) SIN CARGOS AL NUMBERO MENCIONADO ARRIBA. PUEDES SER ELEGIBLE PARA UN PRESTAMO POR EL PROGRAMA LLAMADO "HOMEOWNER'S EMERGENCY MORTGAGE ASSISTANCE PROGRAM" EL CUAL PUEDE SAL V AR SU CASA DE LA PERDIDA DEL DERECHO A REDIMIR SU HIPOTECA. t;XH\B\T A :>'M""'I '-, ,_:!"," I I' "C, "r- . . . "",~~~ " ...,"-,.,~,",: . '. . FIRST HORIZON HOME LOANS 4000 HORIZON WAY IRVING, TX 75063 11/7/00 C BLAINE BOUDMAN 26 WEST EPPLEY DRIVE CARLISLE PA 17013 S/31 ";0 Djrv dJ... ACT 91 NOTICE TAKE ACTION TO SAVE YOUR HOME FROM FORECLOSURE This is an official notice that the mortgage on your home is in default. and the lender intends to foreclose. SDecific infonnation about the nature of the default is Droyided in the attached Dages. The HOMEOWNER'S MORTGAGE ASSISTANCE PROGRAM (REMAP) may be able to helD to saYe your home. This notice eXDlains how the Drogram works. To see ifHEMAP can helD. you must MEET WITH A CONSUMER CREDIT COUNSELING AGENCYWITHIN 30 DAYS OF THE DATE OF THIS NOTICE. Take this notice with you when you meet with the Counseling Agency. The name. address and Dhone number of Consumer Credit Counseling Agencies serving your County are listed at the end of this Notice. If YOU haye any auestions. YOU may call the Pennsylyania Housing Finance Agency toll free at 1-800-342-2397. (Persons with imDaired hearing can call (707) 780-1869). This Notice contains important legal infonnation. If you have any questions,representatiyes at the Consumer Credit Counseling Agency may be able to help explain it. You may also want to contact an attorney in your area. The local bar association may be able to help you [md a lawyer. LA NOTlICACION EN EDJUNTO ES DE SUMA IMPORTANCIA, PUES AFECTA SU DERECHO A CONTINUAR VIVIENDO EN SU CASA. SI NO COMPRENDE EL CONTENIDO DE EST A NOTIFICACION OBTENGA UNA TRADUCCION IMMEDITAMENTE LLAMANDO ESTA AGENCIA (PENNSYL VIAN HOUSING FINANCE AGENCY) SIN CARGOS AL NUMBERO MENCIONADO ARRIBA. PUEDES SER ELEGlBLE PARA UN PRESTAMO POR EL PROGRAMA LLAMADO "HOMEOWNER'S EMERGENCY MORTGAGE ASSISTANCE PROGRAM" EL CUAL PUEDE SAL V AR SU CASA DE LA PERDIDA DEL DERECHO A REDIMIR SU HIPOTECA. ~XH'B\T A. ~~,-c__ ~~ "., 11- ~ " --. ~,' '-~""-"''''''''-- . CBLAINEBOUDMAN 26 WEST EPPLEY DRIVE CARLISLEPA 17013 ACCT #9165861 FIRST HORIZON HOME LOANS HOWEOWNER'S EMERGENCY MORTGAGE ASSISTANCE PROGRAM YOU MAYBE ELIGIBLE FOR FINANCIAL ASSISTANCE WHICH CAN SAVE YOUR HOME FROM FORECLOSURE AND HELP YOU MAKE FUTURE MORTGAGE PAYMENTS IF YOU COMPLY WITH THE PROVISIONS OF THE HOMEOWNER'S EMERGENCY MORTGAGE ASSISTANCE ACT OF 1983 (THE "ACT"), YOU MAY BE ELIGIBLE FOR EMERGENCY MORTGAEG ASSISTANCE: "IF YOUR DEFAULT HAS BEEN CAUSED BY CIRCUMSTANCES BEYOND YOUR CONTROL, "IF YOU HAVE A REASONABLE PROSPECT OF BEING ABLE TO PAY YOUR MORTGAE PAYMENTS, AND "IF YOU MEET OTHER ELIGIBILITY REQUIREMENTS ESTABLISHED BY THE PENNSYLVANIA HOUSING FINANCE AGENCY. TEMPORARY STAY OF FORECLOSURE-Under the Act, you are entitled to a temporary stay of foreclosure on your mortgage for thirty (30) days from the date of this Notice. During that time you must arrange and attend a "face-to-face" meeting with one of the consumer credit counseling agencies listed at the end of this Notice. THIS MEETING MUST OCCUR WITHIN THE NEXT (30) DAYS. IF YOU DO NOT APPLY FOR EMERGENCY MORTGAGE ASSISTANCE. YOU MUST BRING YOUR MORTGAGE UP TO DATE. THE PART OF THIS NOTICE CALLED "HOW TO CURE YOUR MORTGAGE DEFAULT'. EXPLAINS HOW TO BRING YOUR MORTGAE UP TO DATE. CONSUMER CREDIT COUNSELING AGENCIES-If you meet with one of the consumer credit counseling agencies listed at the end of this notice, the lender may NOT take action again~t you for thirty (30) days after the date of this meeting. The names. addresses and teleDhone numbers of designated consumer credit counselin2 a2encies for the county in which the DroDertY is located are set forth at the end of this Notice. It is only necessary to schedule one face-to-face meeting. Advise your lender immediatelv of your intentions. APPLICATION FOR MORTGAGE ASSIST ANCE- Your mortgage is in default for the reasons set forth later in this Notice (see following pages for specific information about the nature of your default). I you have tried and are unable to resolve this problem with the lender, you have the right to apply for fmancial assistance from the Homeowner's Emergency Mortgage Assistance Program. To do so, you must fill out, sign and file a completed a completed Homeowner's Emergency Mortgage Assistance Program Application with one of the designated consumer credit counseling agencies listed at the end of this Notice. Only consumer credit counseling agencies have applications for the program and they will assist you in submitting a complete application to the Pennsylvania Housing Finance Agency, Your application MUST be filed or postmarked within thirty (30) days of your face-to-face meeting. YOU MUST FILE YOUR APPLICATION PROMPTLY. IF YOU FAIL TO DO SO OR IF YOU DO NOT FOLLOW THE OTHER TIME PERIODS ET FORTH IN THIS LETTER, FORECLOUSRE MAY PROCEED AGAINST YOUR HOME IMMEDIA TEL Y AND YOUR APPLICATION FOR MORTGAGE ASSISTANCE WILL BE DENIED. ~H'B1T A -<\t~1._, ,~. '0, Idl - ~1 ,.~ ~ , ~--.,=~~"., ~ ~~~~~ . AGENCY ACTION- Available funds for emergency mortgage assistance are very limited. They will be disbursed by the Agency under the eligibility criteria established by the Act. The Pennsylvania Housing Finance Agency has sixty (60) days to make a decision after it receives your application. During that time, no foreclosure proceedings will be pursued against vou if vou have met the time reauirements set forth above. You will be notified directly by the Pennsylvania Housing Finance Agency of its decision on your application. NOTE: IF YOU ARE CURRENTLY PROTECTED BY THE FILING OF A PETITION IN BANKRUPTCY, THE FOLLOWING PART OF THIS NOTICE IS FOR INFORMATION PURPOSES ONLY AND SHOULD NOT BE CONSIDERED AS AN ATTEMPT TOCOLLECT THE DEBT. (If you have filed bankruptcy you can still apply for Emergency Mortgage Assistance). HOW TO CURE YOUR MORTGAGE DEFAULT (Brim! it UP to date). NATURE OF THE DEF AUL T- The MORTGAGE debt held by theabov~ lender onyourproperty located at: 26 WEST EPPLEY DRIVE CARLISLE PA 17013 IS SERIOUSLY IN DEF AUL T because: A. YOU HAVE NOT MADE MONTHLY MORTGAGE PAYMENTS for the following months and the following amounts are now past due: Due 1/1/00-1111/00 PaymentAmountDue = $14371.06 Late Charges $786.04 Other charges (explain/itemize): Bad Check Fee $ 0.00 Other Fees = $96.98 Minus Suspense = $ 0.00 TOTAL AMOUNT PAST DUE: $ 15254.08 B. YOU HA VE FAILED TO TAKE THE FOLLOWING ACTION (Do not use ifnot applicable): HOW TO CURE THE DEF AUL T -You may cure the default within THIRTY (30) days of the date of this notice BY P A YNG THE TOTAL AMOUNT PAST DUE TO THE LENDER, WHICH IS $15254.08 MORTGAGE PAYMENTS AND LATE CHARGES WHICH BECOME DUE DURING THE (30) DAY PERIOD. Payments must be made either by cash, cashier's check, certified check or money order made payable and sent to: First Horizon Home Loans 4000 Horizon Way Irving, TX 75063 Attn: Cashiering You can cure any other default by taking the following action within THIRTY (30) DAYS of the date of this letter: (Do not use if not applicable.) l:XHJBIT A .. .-*-,. ". ,- I'. ~~ "" , IF YOU DO NOT CURE THE DEFAULT -Ifyau da nat cure the default within THIRTY (30) DAYS af the date afthis Natice, the lender intends to exercise its ril!hts to accelerate the mortl!al!e debt. This means that the entire autstanding balance af this debt will be cansidered due immediately and yau may lase the chance ta pay the martgage in manthly installments. If full payment af the tatal amaunt past due is nat made within THIRTY (30) DAYS, the lender alsa intends ta instruct its attarneys ta start legal actian ta foreclose uDon vour mortl!al!ed DrODertv. IF THE MORTGAGE IS FORECLOSED UPON-The martgaged praperty will be said by the Sheriff to pay aff the martgage debt. If the lender refers yaur case ta it's attarneys, but yau cure the delinquency befare the lender begins legal proceedings against yau, yau will still be required ta pay the reasanable attarney's fees that were actually incurred, up ta $50.00. Hawever, if legal proceedings are started against yau, yau will have ta pay all reasanable attarney's fees actually incurred by the lender even if they exceed $50.00. Any attarney's fees will be added ta the amaunt yau awe the lender, which may alsa include ather reasanable casts. Ifvau cure the default within the THIRTY (30) DAY oeriod. vau will nat be reQuired tG Dav attorney's fees. OTHER LENDER REMEDIES-The lender may alsG sue yau persGnally far the unpaid principal balance and all Gther sums due under the mGrtgage. RIGHT TO CURE THE DEF AUL T PRIOR TO SHERIFF'S SALE-If yau have nGt cured the default within the THIRTY (30) DAY periad and fGreclGsure proceedings have begun, VDU still have the riwt tG cure the default and prevent the sale at anv tie uo ta Dne hGur befGre the Sheriff's Sale. Y GU mav da SD bv oaving the tGtalamaunt then past due. plus anv late Dr ather charges then due. reasanable attarnev's fees and casts cannected with the fareclasure sale and anv ather casts cannected with Sheriff's Sale as soecified in writinl! bv the lender and bv oerfarming anv ather reQuirements under the marteage. Curing your default in the manner set forth in this natice will restore your mortgage to the same position as if you had never defaulted. EARLIEST POSSIBLE SHERIFF'S SALE DATE-It is estimated that the earliest date that such a Sheriff's Sale afthe martgaged praperty cauld be held wauld be approximately _9 _months from the date oethis Notice. A natice afthe actual date afthe Sheriff's Sale will be sent tG yau befare the sale. Of caurse, the amaunt needed ta cure the default will increase the langer yau wait. Yau may fmd aut at any time exactly what the required payment ar actian will be by cantacting the lender. HOW TO CONTACT THE LENDER: First Harizan Harne Laans 4000 Harizan Way Irving, TX 75063 Attn: Laan Caunseling Dept. 1-800-707-9998IPhGne 1-214-672-3922/Fax EFFECT OF SHERIFF'S SALE- Yau shauld realize that a Sheriff's Sale will end yaur awnership Gfthe martgaged property and yaur right ta GCcuPY it. Ifyau cGntinue ta live in the praperty after the Sheriffs Sale, a lawsuit tG remGve yau and yaur furnishings and ather belangings CGuld be started by the lender at anytime. ASSUMPTION OF MORTGAGE-Yau _x_ may ar _ may nat (CHECK ONE) sell Gr transfer YGur hGme tG a buyer Gr transferee who will assume the martgage debt, provided that all the outstanding payments, charges and attarney's fees and casts are paid priGr ta ar at the sale and that the ather requirements af the martgage are satisfied. ;XHIBlT A '~"l!;ob'''~'''''""" ~"..""....~ -, o<-~_r. ,,,,,~,",,,~"~,"""RI.~,~,, YOU MAY ALSO HAVE THE RIGHT OTO SELL THE PROPERlY TO OBTAIN MONEY TO PAY OFF THEMORTGAE DEBT OR TO BORROWER MONEY FROM ANOTHER LENDING INSTITUTION TO PAY OFF THIS DEBT. OTO HAVE THIS DEFAULT CURED BY ANY THIRTPARlY ACTING ON YOURBEHLF. OTO HAVE THEMORTGAGE RESTORED TO THE SAME POSITOIN AS IF NO DEF AUL THAD OCCURRED, IF YOU CURE THE DEFAULT. (HOWEVER YOU DO NOT HAVE THIS RIGHT TO CURE YOUR DEF AUL T MORE THAN THREE TIMES IN ANY CALENDAR YEAR.) oTO ASSERT THE NONEXISTENCE OF A DEF AUL T IN ANY FORECLOUSRE PROCEEDING OR ANY OTHER LAWSUIT INSTITUTED UNDER THE MORTGAGE DOCUMENTS. . . . " -',' , - .. . - . ,_.- ... . , oTO ASSERT ANY OTHER DEFENSE YOU BELIEvE YOUMA Y HAVE TO SUCH ACTION BY THE LENDER. OTO SEEK PROTECTION UNDER THE FEDERAL BANKRUPTCY LAW. Sincerely, Cartier A. Caldwell Default Referral Specialist II IOOilBlT A "~~ ,~~.,.- " ., ~~ -, -" 1-, - --, ~--" -. . ~ --'~ PENNSYLVANIA HOUSING FINANCE AGENCY HOMEOWNER'S EMERGENCY ASSISTANCE PROGRA.'\1 CONSUMER CREDIT COUNSELING AGENCIES (REV. 8/00) CLINTON COUNTY ~ Lycoming..clinton Counties Commision for Community Action (STEP) 2138 Lincoln Street P.O. Bo. 1328 Williarnspon, PA 17703 (570) 326-0581 FAX (570) 322-2197 CCCS of Northeastern P A 20 I Basin Street WiIliarnspon, P A 17703 (570)323-6627 FAX (570) 323-6626 COLUMBIA COUNTY 31 W. Market Street POB 1127 Wilkes-Barre, PA 18702 (570) 821-0837 or (800) 922-9537 FAX (570) 821-1785 Commission on Economics OlJportunity ofLuzeme County 163 Amber Lane Wilkes-Barre. P A 18702 (570) 826-0510 or (800) 822-0359 FAX (570) 829-1665-(Call Before Faxing) (570) 455-4994 Hazeltown FAX (570) 455-5631-(Call Before Faxing) (570)836-4090 Tunkhannock CRAWFORD COUl'o"TY Booker T. Washington Center 1720 Holland Center Erie, PA 16503 (814)453-5744 FAX (814) 5749 John F. Kennedy Center, Inc. 2021 East20tll Street Erie, PA 16510 (814) 898-0400 FAX (814) 898-1243 CUMBERLAND COUNTY CCCS of Western Pennsylvania, Inc. 2000 Linglestown Road Harrisburg, PA 17102 (717) 541-1757 Urban league of Metropolitan Harrisburg N. 6th Street Harrisburg, PA 17101 (717) 234-5925 FAX (717) 234-9459 Community Action Comm of the Capital Region 1514 Derry Street Harrisburg, PA 17104 (717) 232-9757 FAX (717) 234-2227 CCCS of Northeastern P A 1631 South Atherton St. Suite 100 State College, PA 16801 (814) 238-3668 FAX (814) 238-3669 1400 _AbingtoD, Executive Park Suite 1 . Clarks Summit P A 18411 (570) 587-9163 or (800) 922-9537 FAX (570) 587-9134-9135 Greater Erie Community Action Committee 18 West 9th Street Erie, PA 16501 (814) 459-4581 FAX (814) 456-0161 Shenango Valley Urban League, Inc. 601 Indiana Avenue Farrell, PA 16121 (412)981-5310 Financial Counseling Services ofFranldin 31 West 3n!. Street . Waynesboro, PA 17268 (717) 762-3285 YWCA of Carlisle 301 "G" Street Carlisle, PA 17013 . (717) 243-3818 FA:X (717) 731-9589 Adams County Housing Authority 139-143 Carlisle St Gettysburg, PA 17325 (717) 334-1518 FAX 334-8326 PENNSYL V Al'llA BULLETIN, VOL. 29. NO. 2], JUNE 5, 1999 8}lH\SrT A -"f , , ALL THAT CERTAIN trace of ~an<:l s:i.tuate in South M:i.dd~..ton Township, Cumber~and CQunty, Pennsy1vania, "bounded'arid described in accordanee w~eh a survey prepare<:l ~y John K, Box~er, XXX, R.S., date<:l 2/2~/S6 and recorded ~n the Off~ce of the Recorder of Peeds for Cumber~and County in P~an Book 72 page 115, revised 4/10/~6, as fol~ows: BEGINNING at an ~ron pin on the northern right of way ~ine of West Eppley Orive a~ a corner of Lot 35, Se~eion 2-A, on the p~an of Forgedale Crossing; thence a~ong Lot 35, North 03 degrees 17 minutes and 08 seconds ;..Jest, a dist.ance of 1.50.00 .feet:. to an iron pin; t:.hence a~ong Lot 30-A, Phase I, North 86 degrees 42 minutes and 52 seconds East, a distance of 100.00 feet to an-iron pin; thenee along Lot 33, Section 2-A, South 03 ~egrees 17 minutes and 08 seconds East, a distance Of 151.02 feet to an iron pin on the norehern righ~ of way 1ine of Wese Eppley nr~ve; thence ~~ong ssid northern right of way line of west, Spp~ey Drive, ~y a curve to =he ~ef~ having a radius of 495.00 feet an<:l arc distance of 3l.B5 feet to a ~=int ip the ~ight of way 1ine; thence ccntinu~ng along the nor~bern r~ght ~f way 1ine of West Epp~ey Orive, South 86 degrees 42 minutes and 52 seconds Wese, a distance of 68.18 feet to an iron pin at Lot 35, Section 2~ 'l., the place of BEGINNING'. . ::ONTAININC :l.5,OOO.OO,.,;square feet and deSignated as Lot 34, SectOion 2-A of ?lan of ~orgeda1e ~roBs~ng. 3EING THE SAME PREMISES WHICH John E. Anderson and pauline E_ Anderson. Lusband ana wife, and Robert A. Thomas and Oeborah J. ~homas, husband and <ife, by deed <:laeed 6/23/97 an<:l recorded 6/26/~7 in the ReCOrder Of Deed6 )ffice, in and for Cumber~and County, Pennsy1vania, in ReoQrd Book ~60 page ~G granted and conveyed unto S & A Custom Built Homes, Inc., graptor .~erei.n.. PREMISES ON: 26 WEST EPPLEY DRIVE, CARLISLE, PA 17013 ~ ,. ~.- ,,-, .",... ""'1 "I . VERIFICATION RICHARD MINOR hereby states that he is ASSISTANT V.P. of FIRST HORIZON HOME LOANS CORPORATION mortgage servicing agent for Plaintiff in this matter, that he is authorized to take this Verification, and that the statements made in the foregoing Civil Action in Mortgage, , " Foreclosure are true and correct to the best of his knowledge, information and belief. The undersigned understands that this statement is made subject to the penalties of 18 Pa. C.S. Sec. 4904 relating to unsworn falsification to authorities. DATE: 1/ ~/t? I ~~ dAfiuor ASSISTANT VICE PAESlDENT ."""" .'.' ., . - ,-,~ ~ ~ ,u 1 " ~=O"~ _ _. at ~ ~ " ~ "" ~"~~ _'~d__'1 . ~ " V'1H'vAlfSNN3d 3lSllHVQ 10. HV LZ 6 21 NVf .uNn0~ (:fJV-".,S,HlO .:IAl1l3HS 3<11 ~O 3nl~dtl W._ ~,~ ,. ~ _ _ ~ cnn:D ~ .........-}, c::::::S lnrt! r~ _~~n _~ > ^. "",",j~tr,,,;~'ltW'?l-1I'!'1'llll~_~~1l''l'lI'jll~iiiWl'"'l_,.,,..J.P_~ilm-~~lliij~~:_~ ._,,_.T~j ,.. FEDERMAN AND PHELAN, LLP By: FRAJ{KFEDE~AN,ESQUTIRE IDENTIFICATION NO. 12248 ONE PENN CENTER AT SUBURBAN STATION 1617 JOHNF, KENNEDY BOULEVARD SUITE 1400 PHILADELPHIA, PA 19103-1814 (215) 563-7000 FIRST HORIZON HOME LOAN CORPORATION, F/K! A FT MORTGAGE COMPANIES, D/B/A MNC MORTGAGE 4000 HORIZON WAY, IRVING, TX 75063 ATTORNEY FOR PLAINTIFF COURT OF COMMON PLEAS CIVIL DNISION TE~ Plaintiff NO. 0 ( - of. f I ~ v. CUMBERLAND COUNTY VICKI BOUDMAN C. BLAINE BOUDMAN 26 WEST EPPLEY DRNE, CARLISLE, PA 17013 Defendant( s) CIVIL ACTION - LAW COMPLAINT IN MORTGAGE FORECLOSURE NOTICE Loan #: 0009165861 **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 AND THIS DEBT WAS NOT REAFFIRMED, THIS CORRESPONDENCE IS NOT AND SHOULD NOT BE CONSTRUED TO BE AN ATTEMPT TO COLLECT A DEBT, BUT ONLY ENFORCEMENT OF A LIEN AGAINST PROPERTY. .. 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 this 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. _O~ ':ft'- ~~<(IY.# ~~~""dY / ~O A~~, I;jJ <( ~..~ < CUMBERLAND COUNTY 9.~ #~{X \Y. CUMBERLAND COUNTY BAR ASSOCIATION , 0 "$:oqf~b," " ~,~, 2 LIBERTY AVENUE !t,\T~ ~"- CARLISLE, PA 17013 .m" ~', ,~'" ~ ~, ' , (717) 249-3166 '\'{.-,. -S-~ ~ . ~~ . We hereby cerUfy the within to be IL\ true and COfl'9ctCOPV of the orIqtnalfUed of record FEDERMAN AND PHElAN I.... .~. - , . ~ 11 -. -,~ ,. -""~"~'''='''''''~"''~~'''''~''''''$=-- 1. Plaintiff is: FIRST HORIZON HOME LOAN CORPORATION, F/KJ A FT MORTGAGE COMPANIES, D/B/A MNC MORTGAGE 4000 HORIZON WAY, IRVING, TX 75063 2. The name(s) and last knoWn address(es) of the Defendant(s) are: VICKI BOUDMAN C. BLAINE BOUDMAN 26 WEST EPPLEY DRIVE, CARLISLE, P A 17013 who islare the mortgagor(s) and real owner(s) of the property hereinafter described. 3. On 12/11/97 mortgagor(s) made, executed and delivered a mortgage upon the premises hereinafter described to PLAINTIFF which mortgage is recorded in the Office of the Recorder of CUMBERLAND County, in Mortgage Book No. 1421, Page 1103. 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 1/1/00 and each month thereafter are due and unpaid, and by the terms of said mortgage, upon failure of mortgagor to make such payments after a date specified by written notice sent to Mortgagor, the entire principal balance and all interest due thereon are collectible forthwith. A copy of such notice is attached as Exhibit "A." '-""1'1'""11 "...... , ~- r' ~ I , , . , ,~ "~""~~ ~~, _ ~ .....- ."'iIffill'iJI'I' ~"," 6. The following amounts are due on the mortgage: Principal Balance Interest 12/1/99 through 12/1/00 (Per Diem $32.08) Attorney's Fees Cumulative Late Charges 12/11/97 to 12/1100 Cost of Suit and Title Search Subtotal $159,283.96 11,741.28 4,000.00 786.04 750.00 $176,561.28 Escrow Credit Deficit Subtotal 0.00 1.498.46 $1,498.46 $178,059.74 TOTAL 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 Sheriffs Sale. If the Mortgage is reinstated prior to the Sale, reasonable attorney's fees will be charged. 8. This action does not come under Act 6 of 1974 because the original mortgage amount exceeds $50,000.00. 9. The Combined Notice has been sent to the Defendant(s) by regular and certified mail as required by 35 P.S. g 1680.403c on the date(s) set forth in the true and correct copy of such notice(s) attached hereto as Exhibit "A." 10. The Temporary Stay as provided by the Homeowner's Emergency Mortgage Assistance Program, Act 91 of 1983, has terminated because either: (i.) Defendant(s) have failed to meet with the Plaintiff or an authorized Credit Counseling Agency in accordance with Plaintiffs written Notice to Defendants, a true and correCt copy of which is attached hereto as Exhibit "A"; or (ii.) Defendant(s) application for assistance has been rejected by the PelU1sylvania Housing Finance Agency. WHEREFORE, PLAINTIFF demands an in rem Judgment against the Defendant(s) in the sum of $178,059.74, together with interest from 12/1/00 at the rate of$32.08 per diem to the date of Judgment, and other costs and charges collectible under the mortgage and for the foreclosure and sale of the mortgaged property. /s/ Frank Federman FRANK FEDERMAN, ESQUIRE Attorney for Plaintiff , , I~,~ ~~~ " ~~, ,~" .~ Iill_ _. ~ _""'." . FIRST HORIZON HOME LOANS 4000 HORIZON WAY IRVING, TX 75063 11/7/00 VICKI BOUDMAN 26 WEST EPPLEY DRIVE CARLISLE PA 17013 ACT 91 NOTICE TAKE ACTION TO SAVE YOUR HOME FROM FORECLOSURE This is an official notice that the morll!al!e on your home is in default. and the lender intends to foreclose. Specific information about the nature of the default is provided in the attached pal!es. The HOMEOWNER'S MORTGAGE ASSISTANCE PROGRAM (REMAP\ mav be able to help to save your home. This notice explains how the prol!ram works. To see if HEMAP can help. you must MEET WITH A CONSUMER CREDIT COUNSELING AGENCYWITHIN 30 DAYS OF THE DATE OF THIS NOTICE. Take this notice with yOU when yOU meet with the Counseling Agency. The name. address and phone number of Consumer CreditCounselinl! Agencies serving vour County are listed at the end of this Notice. Ifvou have any questions. you mav call the Pennsvlvania Housing Finance Agencv toll free at 1-800-342-2397. (Persons with impaired hearing can call (707\ 780-1869\. This Notice contains important legal information. If you have any questions, representatives at the Consumer Credit Counseling Agency may be able to help explain it. You may also want to contact an attorney in your area. The local bar association may be able to help you fmd a lawyer. LA NOTIlCACION EN EDJUNTO ES DE SOMA IMPORTANCIA, PUES AFECTA SU DERECHO A CONTINUAR VIVIENDO EN SU CASA. SI NO COMPRENDE EL CONTENIDO DE ESTA NOTIFICACION OBTENGA UNA TRADUCCION IMMEDlTAMENTE LLAMANDO ESTA AGENCIA (PENNSYL VIAN HOUSING FINANCE AGENCY) SIN CARGOS AL NUMBERO MENClONADO ARRIBA. PUEDES SER ELEGIBLE PARA UN PREST AMO POR EL PROGRAMA LLAMADO "HOMEOWNER'S EMERGENCY MORTGAGE ASSISTANCE PROGRAM" EL CUAL PUEDE SAL V AR SU CASA DE LA PERDIDA DEL DERECHO A REDlMIR SU HIPOTECA. t;XH\B\T A, <,llIm , - ~ i '? - " . I' , - ~, ., .. r~,~ =~," . FIRST HORIZON HOME LOANS 4000 HORIZON WAY IRVING, TX 75063 1117/00 C BLAINE BOUDMAN 26 WEST EPPLEY DRIVE CARLISLE PA 17013 S/31 NloDjrvd.L ACT 91 NOTICE TAKE ACTION TO SAVE YOUR HOME FROM FORECLOSURE This is an official notice that the morteage on your home is in default. and the lender intends to foreclose. Soecific infonnation about the nature of the default is orovided in the attached Dages. The HOMEOWNER'S MORTGAGE ASSISTANCE PROGRAM (REMAP) may be able to helD to save your home. This notice exolains how the orogram works. To see ifHEMAP can helD. YOU must MEET WITH A CONSUMER CREDIT COUNSELING AGENCYWITHIN 30 DAYS OF THE DATE OF THIS NOTICE. Take this notice with YOU when you meet with the Counseling Agencv. The name. address and ohone number of Consumer Credit Counseling Agencies serving your County are listed at the end of this Notice. Ifvou have any Questions. YOU may call the Pennsylvania Housing Finance Agencv toll free at 1-800-342-2397. (Persons with imoaired hearing can call (707) 780- I 869). This Notice contains important legal infonnation. If you have any questions, representatives at the Consumer Credit Counseling Agency may be able to help explain it. You may also want to contact an attorney in your area. The local bar association may be able to help you fmd a lawyer. LA NOTIICACION EN EDJUNTO ES DE SUMA IMPORTANCIA, PUES AFECTA SU DERECHO A CONTINUAR VIVIENDO EN SU CASA. SI NO COMPRENDE EL CONTENIDO DE ESTA NOTIFICACION OBTENGA UNA TRADUCCION IMMEDITAMENTE LLAMANDO ESTA AGENCIA (PENNSYL VIAN HOUSING FINANCE AGENCY) SIN CARGOS AL NUMBERO MENCIONADO ARRIBA. PUEDES SER ELEGIBLE PARA UN PREST AMO POR EL PROGRAMA LLAMADO "HOMEOWNER'S EMERGENCY MORTGAGE ASSISTANCE PROGRAM" EL CUAL PUEDE SAL V AR SU CASA DE LA PERDIDA DEL DERECHO A REDIMIR SU HIPOTECA. eXHiBiT A_ '_~'!I'IUlf' "~~ 1---l ~ - ~"=~ -""""",,''1<''~.VO-'''''~ . . C BLAINE BOUDMAN 26 WEST EPPLEY DRIVE CARLISLE P A 17013 ACCT #9165861 FIRST HORIZON HOME LOANS HOWEOWNER'S EMERGENCY MORTGAGE ASSISTANCE PROGRAM YOU MAYBE ELIGIBLE FOR FINANCIAL ASSISTANCE WHICH CAN SAVE YOUR HOME FROM FORECLOSURE AND HELP YOU MAKE FUTURE MORTGAGE PAYMENTS IF YOU COMPLY WlTH THE PROVISIONS OF THE HOMEOWNER'S EMERGENCY MORTGAGE ASSISTANCE ACT OF 1983 (THE "ACT"), YOU MAY BE ELIGIBLE FOR EMERGENCY MORTGAEG ASSISTANCE: "IF YOUR DEFAULT HAS BEEN CAUSED BY CIRCUMSTANCES BEYOND YOUR CONTROL, "IF YOU HAVE A REASONABLE PROSPECT OF BEING ABLE TO PAY YOUR MORTGAE PAYMENTS, AND "IF YOU MEET OTHER ELIGIBILITY REQUIREMENTS ESTABLISHED BY THE PENNSYLVANIA HOUSING FINANCE AGENCY. TEMPORARY STAY OF FORECLOSURE-Under the Act, you are entitled to a temporary stay of foreclosure on your mortgage for thirty (30) days from the date of this Notice. During that time you must arrange and attend a "face-to-face" meeting with one of the consumer credit counseling agencies listed at the end of this Notice. THIS MEETING MUST OCCUR WITHIN THE NEXT (30) DAYS. IF YOU DO NOT APPLY FOR EMERGENCY MORTGAGE ASSISTANCE. YOU MUST BRING YOUR MORTGAGE UP TO DATE. THE PART OF THIS NOTICE CALLED "HOW TO CURE YOUR MORTGAGE DEFAULT". EXPLAINS HOW TO BRING YOUR MORTGAE UP TO DATE. CONSUMER CREDIT COUNSELING AGENCIES-If you meet with one of the consumer credit counseling agencies listed at the end of this notice, the lender may NOT take action against you forthirty (30) days after the date of this meeting. The names. addresses andteleDhone numbers of designated consumer credit counseline aeencies for the county in which the orooerlY is located are set forth at the end of this Notice. It is only necessary to schedule one face-to-face meeting. Advise your lenderimmediatelv of your intentions. APPLICATION FOR MORTGAGE ASSIST ANCE- Your mortgage is in default for the reasons set forth later in this Notice (see following pages for specific information about the nature of your default). I you have tried and are unable to resolve this problem with the lender, you have the right to apply for [mancial assistance from the Homeowner's Emergency Mortgage Assistance Program. To do so, you must fill out, sign and file a completed a completed Homeowner's Emergency Mortgage Assistance Program Application with one of the designated consumer credit counseling agencies listed at the end of this Notice. Only consumer credit counseling agencies have applications for the program and they will assist you in submitting a complete application to the Pennsylvania Housing Finance Agency. Your application MUST be filed or postmarked within thirty (30) days of your face-to-face meeting. YOU MUST FILE YOUR APPLICATION PROMPTLY. IF YOU FAIL TO DO SO OR IF YOU DO NOT FOLLOW THE OTHER TIME PERIODS ET FORTH IN THIS LETTER, FORECLOUSRE MAY PROCEED AGAINST YOUR HOME IMMEDIA TEL Y AND YOUR APPLICATION FOR MORTGAGE ASSISTANCE WILL BE DENIED. GXHlBlT A 'i~~~1!'l"_w -',I.-""'"r ,-., - ~" ~r ,,~ 1>" . AGENCY ACTION. Available funds for emergency mortgage assistance are very limited. They will be disbursed by the Agency under the eligibility criteria established by the Act. The Pennsylvania Housing Finance Agency has sixty (60) days to make a decision after it receives your application. During that time, no foreclosure proceedings will be pursued against vou if von have met the time reQuirements set forth above. You will be notified directly by the Pennsylvania Housing Finance Agency of its decision on your application. NOTE: IF YOU ARE CURRENTLY PROTECTED BY THE FILING OF A PETITION IN BANKRUPTCY, THE FOLLOWING PART OF TIDS NOTICE IS FOR INFORMATION PURPOSES ONLY AND SHOULD NOT BE CONSIDERED AS AN ATTEMPT TOCOLLECT THE DEBT. (If you have filed hankruptcy you can still apply for Emergency Mortgage Assistance). HOW TO CURE YOUR MORTGAGE DEFAULT (Brim! it UP to date), NATURE OF THE DEFAULT-The MORTGAGE debt held by the above lender on your property located at: 26 WEST EPPLEY DRIVE CARLISLEPA 17013 IS SERIOUSLY IN DEF AUL T because: A. YOU HAVE NOT MADE MONTHLY MORTGAGE PAYMENTS for the following months and the following amounts are now past due: Due 1/1/00-11/1/00 Payment Amount Due = $14371.06 Late Charges $786.04 Other charges (explain/itemize): Bad Check Fee $ 0.00 Other Fees = $96.98 Minus Suspense = $ 0.00 TOTAL AMOUNT PAST DUE: $ 15254.08 B. YOU HA VE FAILED TO TAKE TIffi FOLLOWING ACTION (Do not use if not applicable): HOW TO CURE THE DEF AUL T -You may cure the default within THIRTY (30) days of the date of this notice BY PAYNG THE TOTAL AMOUNT PAST DUE TO THE LENDER, WHICH IS $15254.08 MORTGAGE PAYMENTS AND LATE CHARGES WHICH BECOME DUE DURING THE (30) DAY PERIOD. Payments must be made either by cash, cashier's check, certified check or money order made payable and sent to: First Horizon Home Loans 4000 Horizon Way Irving, TX 75063 Attn: Cashiering You can cure any other default by taking the following action within THIRTY (30) DAYS of the date of this letter: (Do not use if not applicable.) , EXHIBIT A ''<!'!~~ ~",. .,.e_'~e,T" '""""" I" ~r r ~"'. . .~Ji=~ . . IF YOU DO NOT CURE THE DEFAULT If you do not cure the default within THIRTY (30) DAYS of the date of this Notice, the lender intends to exercise its ril!hts to accelerate the mortl!al!e debt. This means that the entire outstanding balance of this debt will be considered due immediately and you may lose the cbance to pay the mortgage in monthly installments. If full payment of the total amount past due is not made within THIRTY (30) DAYS, the lender also intends to instruct its attorneys to start legal action to foreclose upon vour mortl!al!ed property. IF THE MORTGAGE IS FORECLOSED UPON-The mortgaged property will be sold by the Sberiffto payoff the mortgage debt. If the lender refers your case to it's attorneys, but you cure the delinquency before the lender begins legal proceedings against you, you will still be required to pay the reasonable attorney's fees that were actually incurred, up to $50.00. However, if legal proceedings are started against you, you will bave to pay all reasonable attorney's fees actually incurred by the lender even if they exceed $50.00. Any attorney's fees will be added to the amount you owe the lender, which may also include other reasonable costs. Ifvou cure the default within the THIRTY (30) DAY period. vou will not be reouired to Dav attorneY's fees. OTHER LENDER REMEDIES-The lender may also sue you personally for the unpaid principal balance and all other sums due under the mortgage. RIGHT TO CURE, THE DEFAULT PRIOR TO SHERIFF'S SALE-If you have not cured the default within the THIRTY (30) DAY period and foreclosure proceedings have begun, vou still have the right to cure the default and prevent the sale at any tie up to one hour before the Sberiff s Sale. You mav do so bv Daving the total amount then Dast due. plus any late or other charges then due. reasonable attorney's fees and costs connected with the foreclosure sale and any otber costs connected with Sheriffs Sale as specified in writing bv the lender and bv performing any other renuirements under the mortgage. Curing your default in the manner set forth in this notice will restore your mortgage to the same position as if you had never defaulted. EARLIEST POSSIBLE SHERIFF'S SALE DATE-It is estimated that the earliest date that such a Sheriffs Sale of the mortgaged property could be beld would be approximately _9 _months from the date oUhis Notice. A notice of the actual date of the Sheriffs Sale will be sentto you before the sale. Of course, the amount needed to cure the default will increase the longer you wait. You may fmd out at any time exactly what the required payment or action will be by contacting the lender. HOW TO CONTACT THE LENDER: First Horizon Home Loans 4000 Horizon Way Irving, TX 75063 Attn: Loan Counseling Dept. 1-800-707-9998 !Phone 1-214-672-3922/Fax EFFECT OF SHERIFF'S SALE- You should realize tbat a Sheriffs Sale will end your ownership oftbe mortgaged property and your right to occupy it. If you continue to live in the property after the Sheriffs Sale, a lawsuit to remove you and your furnishings and otber belongings could be started by tbe lender at anytime. ASSUMPTION OF MORTGAGE-You _x_mayor _ may not (CHECK ONE) sell or transfer your bome to a buyer or transferee who will assume the mortgage debt, provided that all the outstanding payments, ~harges and attorney's fees and costs are paid prior to or at tbe sale and tbat the other requirements of the mortgage are satisfied. t;XH1BlT A !i'p:t!l!Il, '^',. \-"-1 r' I. 1 " ,"""--'': . '. . YOU MAY ALSO HAVE THE RIGHT .TO SELL THE PROPERTY TO OBTAIN MONEY TO PAY OFF THEMORTGAE DEBT OR TO BORROWER MONEY FROM ANOTHER LENDING INSTITUTION TO PAY OFF THIS DEBT. .TO HA VB THIS DEFAULT CURED BY ANY THIRT PARTY ACTING ON YOUR BEHLF. .TO HAVE THEMORTGAGE RESTORED TO THE SAME POSITOIN AS IF NO DEF AUL THAD OCCURRED, IF YOU CURE THE DEFAULT. (HOWEVER YOU DO NOT HAVE THIS RIGHT TO CURE YOUR DEF AUL T MORE THAN THREE TIMES IN ANY CALENDAR YEAR.) .TO ASSERT THE NONEXISTENCE OF A DEF AUL T IN ANY FORECLOUSRE PROCEEDING OR ANY OTHER LA WSUlT INSTITUTED UNDER THE MORTGAGE DOCUMENTS. '., ',,", _, ,- '. t . .TO ASSERT ANY OTHER DEFENSE YOU BELIEVE YOU MA YHAVE TO SUCH ACTION BY THE LENDER. .TO SEEK PROTECTION UNDER THE FEDERAL BANKRUPTCY LAW. Sincerely, Cartier A. Caldwell Default Referral Specialist II 1;XH1BIT A ~n"'!'!il~ I" "~. , .- ~,~, ~ ~ ,., ,n ~" "_"r_",,~,k,t . . ,'-" PENNSYLVANIA HOUSING FINA1'1CE AGENCY HOMEOWNER'S EMERGENCY ASSISTANCE PROGRAM CONSUMER CREDIT COUNSELING AGENCIES (REV, 8/00) CLINTON COUNTY Lycoming..clinton Counties Commision for Community Action (STEP) 2138 Lincoln Sueet P.O. Box 1328 Williamsporl, P A 17703 (570) 326-0587 FAX (570) 322-2197 CCCS of Northeastern P A 1631 South Atherton St, Suite 100 Slate College, PA 16801 (814) 238-3668 FAX (814) 238-3669 CCCS of Northeastern PA 20 I Basin Street Williamsporl, PA 17703 (570) 323-6627 FAX (570) 323-6626 COLUMBIA COUNTY 1400 Abington Executive Park Suite 1 Clarks Summit P A 18411 (570) 587-9163 or (800) 922-9537 FA-X (570) 587-9134-9135 31 W, Market Street POB 1127 Wilkes-Barre, PA 18702 (570) 821-0837 or (800) 922-9537 FAX (570) 821-1785 Commission on Economics Opportunity ofLuzeme County 163 Amber Lane Wilkes-Barre, P A 18702 (570) 826-0510 or (800) 822-0359 FAX (570) 829-1665-{Call Before Faxing) (570) 455-4994 Hazeltown FAX (570) 455-5631-{Cal1 Before Faxing) (570) 836-4090 Tunkbannock CRAWFORD COUNTY Booker T. WashingtOn Center 1720 Holland Center Erie. PA 16503 (814)453-5744 FAX (814) 5749 Greater Erie Community Action Committee 18 West 911I Street Erie. PA 16501 (814)459-4581 FAX(814)456-o161 John F. Kennedy Center, Inc. 2021 East 20tll Street Erie, PA 16510 (814) 898-0400 FAX (814) 898-1243 Shenango Valley Urban League, Inc. 601 Indiana Avenue Farrell, PA 16121 (412)981-5310 CUMBERLAND COUNTY Financial Counseling Services of Frankl in 31 West 3Rt Street . Waynesboro. PA 17268 (7 \7) 762-3285 eees of West em PeMsylvania, Inc. 2000 Linglestown Road Harrisburg, PA 17102 (717) 541-1757 Urban League of Metropolitan Harrisburg N. 6lb. Street Harrisburg, PA 17101 (717) 234-5925 FAX (717) 234-9459 YWCA of Carlisle 301 "G" Street Carlisle. PA 17013 . (717) 243-3818 FAX (717) 731-9589 Community Action Comm of the Capital Region 1514 Deny Street Harrisburg, PA 17104 (717)232-9757 FAJ<(717) 234-2227 Adams County Housing Authority 139-143 Carlisle St Gettysburg, P A 17325 (717) 334-1518 FAX 334-8326 PENNSYL VANIA BULLETIN, VOL. 29, NO. 23. JUNE 5, 1999 8){H\B\l A ,-.'. , , , Il ~ . . ALr.. THAT CSRTAINta'"acl: of ~anc1 sieua,l:e in SouthM.i.c:lelletoI1 Township,' Cumber1and Coun~y, pennsy1vania, bounded and described in accordance with a su~ey prepareel by John K. Boxler, XXI, R.S., dated 2/2S/96 and recordec1 ~n the Off~ce of the Reoorc1er of Peeds for Cumberland County in Plan Book 72 pa~e 115, revised 4/10/96, as fol~ows: BEGINNING ae an ~ron ~in on the nnrl:hern right of way line of West Eppley Drive at a corner of Loe 35, Se~l:ion 2-A, on the p~an of Forgedale Crossing: thenoe along Lot 35, North 03 degrees 17 minutes and 08 seconds i.olest:., it. dist;.ance of J.50. 00 .feet:. to an .iron pin; t.hence al.ong Lot:. 30 -A, PhaBe X, North 86 degrees 42 minuees and 52 seconds East, a distance of ~oo.oo feet to an-iron pin: thence along Lot 33, Section 2-A, South 03 ~egrees 17 minutes and 08 seconds East, a diseance of 151.02 feet to an i~en pin en the northern righ~ of way 1~ne of West Eppley Orive; thence ~long aaiel northern right of way line of West Eppley Drive, by a curve to =he left having a radius of 495.00 feet and arc distance of 31.85 feet eo a ~o~nt ~~ ~he r~ght of way l~ne; thence ~ont1nu~ng a~ong the nor~bern 4~9ht ~f way 1ine o~ West Eppley Orive, Sou~h B6 degrees 42 minu~es and 52 seconds Wese, a distance of 68.18 feet to an iron pin at Loe 35, Section 2. 'l., ~he place of BEGINN:tNG'. - =ONTAINING ~5,OOO.00~quare feel: and des~g"al:e~ as Lot 34, Seo~ion 2-A of ?lan of Pargedale Cross~ng~ 3EING THE SAME PREMISES WHICH John S. Anelerson and Pauline E. Anderson. ~usQanel and wife, and Robere A. Thomas and Deborah J. Thomas, husband and ~ife, by deed dated 6/23/97 and recorded 6/26/97 in the Recorder of Deeds ~ffice, in and for cumberland County, Pennsylvania, in Record Book ~60 page 46 graneed and conveyed unto S & A Custom Built Romes. Inc~. grantor .1.erei.n. PREMISES ON: 26 WEST EPPLEY DRIVE, CARLISLE, PA 17013 I';~r-~", ~ I " I ". "~~^- , . . .. VERIFICATION RICHARD MINOR hereby states that he is ASSISTANf V.P. of FIRST HORIZON HOME LOANS CORPORATION mortgage servicing agent for Plaintiff in this matter, that he is authorized to take this Verification, and that the statements made in the foregoing Civil Action in Mortgage Foreclosure are true and correct to the best of his knowledge, information and belief. The undersigned understands that this statement is made subject to the penalties of 18 Pac C.S. Sec. 4904 relating to unsworn falsification to authorities. DATE: 1/ ~/t? I ,.." --," -,' 1-'1 ., ~ ~ ~ :i :i' 'Ii ~ - ~ - ~"'---"",--'" '",','j- -"''>, "'1"-" ",-,,-.- '" ~ ~ VINVA1ASNH3d :n~IIH'I1() 10. HV LZ 6 21 NUr U"''Il~~ ;"Nl'id8WflQ, 'D\\\9l'1"S 3H1 :10 30b!lJO " " ',,"".' '<" ,,,,. ,. .. I , c~ ,;::--. <, U'lI ,~ ,:::::zc.!i ,~ '-::I> cn.rCl . .,_~"!.,..~_",,,_If"\il'i""'""'~ ..mlXlI ~,_JIlIIJ_ _ ~,-T'- """..J_~~J~~,ejl;"""f"'-.f"'~PII"!cP"!~~~",~Fi!lIm 1~~IfI!jL_,_,c ,_.~ FEDERMAN AND PHELAN BY: FRANK FEDERMAN, ESQUIRE Identification No. 12248 One Penn Center at Suburban Station 1617 John F. Kennedy Boulevard Suite 1400 Philadelphia, PA 19103-1814 (215)563-7000 Attorney for Plaintiff RIST HORIZON HOME LOAN CORPORATION, F/K/A FT MORTGAGE COMPANIES, D/B/A MNC MORTGAGE COURT OF COMMON PLEAS CIVIL DIVISION Plaintiff vs. VICKI BOUDMAN C. BLAINE BOUDMAN Cumberland County No. 01-251 Defendants '. PRAECIPE TO REINSTATE CIVIJ~bION/MORTGAGE FORECLOSURE TO THE PROTHONOTARY: Kindly reinstate the Civil Action in Mortgage Foreclosure with reference to the above captioned matter. ~~~/M RANK FEDE N, ESQUIRE Attorney for Plaintiff Date: March 1, 2001 ""11.,."", I - !~ , ~. ,-, I'! ik ~~J, ~)~- ,-.- ,L_~r I" , "" ,. 'd"~ 4' ~ "- "-, ~"4r.' _~ ,~_,. ~"""~ _ -", .'_"~.~.~_ ,,"., _. o c.: <~ -rJCG I~ ::"--'- ' ?[ ~,"'7 :::.J C::;, ~:-J C:'j ","t ':_-.) -,( 0:) ~_,_ :JiilI~~~"':',_---r~"-'-':"' _,~(...'!fflir""?">;",),~,,.;,,,."","j{""'JI'~~-'~~~j~~~5J~~.!jJ;~il~~re;~1 . . , SHERIFF'S RETURN - OUT OF COUNTY CASE NO: 2001-00251 P COMMONWEALTH OF PENNSYLVANIA: COUNTY OF CUMBERLAND FIRST HORIZON HOME LOAN CORP VS BOUDMAN VICKI ET AL R. Thomas Kline , Sheriff or Deputy Sheriff who being duly sworn according to law, says, that he made a diligent search and and inquiry for the within named DEFENDANT , to wit: BOUDMAN C BLAINE but was unable to locate Him in his bailiwick. He therefore deputized the sheriff of YORK County, Pennsylvania, to serve the within COMPLAINT - MORT FORE/REISSUED (Note: P.O. PROVIDED BY YORK COUNTY DOES NOT HAVE A CORRESPONDING STREET ADDRESS On March 16th , 2001 , this office was in receipt of the attached return from YORK Sheriff's Costs: Docketing 6.00 Out of County .00 Surcharge 10.00 .00 .00 16.00 03/16/2001 FEDERMAN & PHELAN So answer~: " ~ ~ ---~.:-~ -~~~~~~ R. Thomas Kline Sheriff of Cumberland County Sworn and subscribed to before me IV ...., this :L'7 - day of 'Y~ ~/ A.D. ~a~#, prothonot'ary ~In" "" ,- ,-, ,., =. SHERIFF'S RETURN - OUT OF COUNTY CASE NO: 2001-00251 P COMMONWEALTH OF PENNSYLVANIA: COUNTY OF CUMBERLAND FIRST HORIZON HOME LOAN CORP VS BOUDMAN VICKI ET AL R. Tbomas Kline , Sheriff or Deputy Sheriff who being duly sworn according to law, says, that he made a diligent search and and inquiry for the within named DEFENDANT , to wit: BOUDMAN VICKI but was unable to locate Her in his bailiwick. He therefore deputized the sheriff of YORK serve the within COMPLAINT - MORT FORE/REI County, Pennsylvania, to On March 16th , 2001 , this office was in receipt of the attached return from YORK Sheriff's Costs: Docketing 18.00 Out of County 9.00 Surcharge 10.00 Dep. York Co 39.56 .00 76.56 03/16/2001 FEDERMAN & PHELAN SO~~~~7 R. Tomas Kline Sheriff of Cumberland County Sworn and subscribed to before me. this :J.7"1b day of"l11...,.,v .2.f>.o/ A.D. el c.~ '-I'~ prothonot~ '-~"~" ","'-" -, ,. I ,~ "1 1"~ 1 of 2 COUNTY OF YORK OFFICE OF THE SHERIFF SERVICE CALL (717) 771-9601 28 EAST MARKET ST., YORK, PA 174~1 < INSTRUCTIONS SHERIFF SERVICE PLEASE TYPE ONLY LINES 1 TO 12 PROCESS RECEIPT, and AFFIDAVIT OF RETURN DO NOT DETACH ANY COPIES. 1. PLAINTIFFISI 2. COURT NUMBER 01 251 Civil ~F':i.rst Horizon Home Loan Corp. et. ,:::]1 , 4. TYPE.OF WRIT OR ~MPLAINT . ReJ.nstate 3. DEFENDANT/S! Notice & Complaint in Vicki BOlldmnn. et. fl1 . M"rr P"r", { 5. NAME OF INDI,VIDUAL' COMPANY, CORPORATION, ETC. TO SERVE OR DESCRIPTION OF PROPERTY TO BE LEVIED, ATTACHED, OR SOLD. Vicki Boudman 6. ADDRESS (STREET OR RFD WITH BOX NUMBER, APT NO., CITY, BORO, TWP" STATE AND ZIP CODE is ",.... . t:'\,()\J"Sb 7. INDICATE SERVICE: 0 PERSONAL a PERSON IN CHARGE DEPUTlzeCumb'*3Rtsroo 0 1ST CLASS MAil NOW' I f) 101 19 _I, SHERIFF OF"!Il>>.lf< CQIJ 1{ ,do hereby York COUNTY 10 eX"SI.m"ftJ" e to law. This deputation being made at the request and risk of the plaintiff. ~ 8. SPECIAL INsmUCTIONS OR OTHER INFORMATION THAT WILL ASSIST IN EXPEDITING SERVICE: SERVE . AT o POSTED 0 OTHER I e sheriff of according H COUNTY Cumberland OUT OF COUNTY CUMBERLAND ADVANCED FEE PAID BY ATTY. NOTE ONLY APPLICABLE ON WAIT OF EXECUTION: N.B. WAIVER OF WATCHMAN - Any deputy sheriff levying upon or attaching any property under within writ may leave same without a watchman, in custody of whomever Is found In possession, after notifying person of levy or attachment, without liability on the part of such deputy or the sheriff to any plaintiff herein for any loss, destruction, or removal of any property before sheriN's sale thereof. 9. TYPE NAME AND ADDRESS of ATTORNEY/ORIGINATOR and SIGNATURE 10. TELEPHONE NUMBER 11. DATE FILED FEDERMAN & PHELAN Ol1E PENN CETR. SUITE 1400 1617 JI~K BLVD. ra SUBURBAN STA PHIl A 12. SEND NQTICE OF SERVICE COPY TO NAME AND ADDRESS BELOW: (ThIs area must be compll~ted if notice is to be mailed). CUMBERLAND CO. SHERIFF SPACE BELOW FOR USE OF THE SHERIFF ONLY - DO NOT WRITE BELOW THIS LINE SIGNATURE OF AUTHORiZeD CLERK R. AHRENS SEE REMARKS 13. I acknowle.dge receipt of the writ or complaint as indicated above. 16,HOWSERVED: PERSONAL ( ) RESIDENCE ( POSTEDC) POEt ) SHERIFF'SOFF( ) OTHER( ) 17. I hereby certify and retum a NOT FOUND because I am unabla to locate the individual, company, corporation, etc, named above. (See remarks below.) 18. AME AND TITLE OF INDIVIDUAL SERVED I UST ADDRESS HERE IF NOT SHOWN ABOVE (RelationshIp to Defendant) Int. Nor Kt~OVvH i\'r i>.Dm,::ss G"VEN 41.AFFIRM 1 44. Signature of De . Sheriff 45. Signature of York County Sheriff Of? liHLLIr.,l.j N. 46. Signature 0 Foreign Coun Sheriff N SIGNATURE 47.0a1e 48. Da1e 42. day of.. 43, HOSE: I 1/ 3/13/01 49. Date 51.Date Received 4. BLUE. SherIff's Office . 'f ..,-~ -"""""" ,__.1""'"i~~ ~,. ~-, - '^"~ '. - - ~& ,~;-,,~, -- ] ~ {-., he T Wd L ~fJlJ TO, Vd ')jHO,~ J.JP:l.'JHS j() ]011' ,,~::L\~-' :'] '. ~" I"r!!!", ._, f]ili~t ;:;gm1il)!JlP.lf\'i~$~~~ffi'W~,;:!f1';'-_""ff"\~-\'" '"-'4~:1_f~1fti;n;~!~",i":!f,,,-,'iiifi)-~W~",W,J!-~~:1!WllIrm,'JV-<~"'~;1f"',W'1',,~~f(\W!~~~ ./ . .,' ~.. -----~-~-- _..- ,"' -~ 1 01' 2 COUNTY OF YOR~: . OFFICE OF THE SHERIFF SERVICE CALL (717) 771-9601 28 EAST MARKET ST., YD.flK, PA 17401 . SHERIFF SERVICE PROCESS RECEIPT, and AFFIDAVIT OF RETURN INSTRUCTIONS PLEASE TYPE ONLY LINES 1 TO 12 DO NOT DET~CH ANY COPIES. 1.. PLAINTIFF/SI ~, ~irs t 3. DEFENDAf\.lTIS/ 2. COURT NUMBER Ol-~'), CiVl1 Vicki iir' SERVE ___. .'6.~~~RErS~~~~~+ ~A RFD WITH BOX NUMBER, APT NO., CITY, BORO, nNP., STATE AND ZIP CODE AT ::',7:' -r~"",-f; 31m-D';--'N'ke-,-:-fl1:1,._S3?'TFa.z::::::l::I'()-Z\t!_9-_ ~_r....D\JL'J 7. INDICA~~.!?.v~C~: . -:: .QRE.RSiONA.k _ -....0 ~Efl:S.oN.IN .t;,I:IARGE ~ DEPUTIZE:' U It: bIrC~Fh.~1i.. 0 1 ~T CL.AS~.MAIL 0 POSTED NOW ._19 _I, SHERIFF OFYcii'lIK COUNTY, PA, do hereby deputize the sheriff of . "Y",r,'< , " ____.~_.,COUNTY to exec:ute this Writ and make return thereof according to law. This deput",tion being made at the request and risk 0"1 the plaintiff. _, ~~ _~_ __ ~ ___~'...-..-.~ - --""Hf:RIFF OF "YJQI'(IO( COUNTY 8. SPECIAL INSTRUCTIONS QR OTHER INFORMATION THAT WILL ASSIST IN EXPEDITING SERVICE: H(,r; zon Hf)m~ IrOAi' <;:o):.h_eJ:....._,...a.l_~n. = ~_"__ .~~_, ,..__ 4. r4IgFs~Rge~80MPLAINT - Notice & Comnlaint in Bou~m0n" f":~t".. al.. __~.<... ~~ _..'."_.,.__.,. M::'1rt... J.'{)'-P , 5. NAME OF INDIVIDUAL, COMPANY, CORPORATION, ETC. TO SERVE OR DESCRIPTION OF PROPERTY TO BE LEVIED, ATTACHED, OR SOLD. o OTf:lER Cumberland ... OUT O~ SOUNTY CUMBERLJi,ND , AD~ANCE!) FEE P,\ID BY ATTY. NOTE ONLY APPLICABLE ON WRIT OF EXECUTION: N.S. WAIVER OF WATCHMAN - Any deputy sheriff levying upon or attaching any property under within writ may leave same without a watchman, in~custody of whomever is found in possession, ,,;fter notifying person of levy or attachment, without liability on the part of such deputy or the sheriff to any plaintiff hereiry for any loss, ~e_slruction, or rel!loval of.A.n~ .ero~!!tEefore_~~iff':,? s~I~_ther~~~ __ __~_ ~u..__""",.' ._.'" """ _ p.. "', .....,..--._ 9_ TYPE'NAME AND ADDRESS of ATTORNEY/ORIGINATOR anq.SIGNATf,JRE' 1Q. TELEPHONE NUMBER 11. DATE FILED FEGEl<MiI!I .& PHELAN ONE PENH CHR. SUITE 1400 '1617 ,j1{K BLVD. , @uSUBURBAN STb____ _ _. ,PHIlA. PA 21 - -7QOO --5- 12. SEND ~ICE OF SERVICE COPY TO NAME: AND ADDRESS aetow: (This area must be completed if notice Is to be mailed). CUMBERl.A~D CO. SHERIFF ,"-_0' on ~"SPACE BELOW FOR USE OF THE SHERIFF ONLY - DO NOT WRITE BELOW THIS LINE 13_ I acknow~ge receipt 6f the writ SIGNATURE OF AUTHORIZED CLERK 14. Date Received 15. Expiration/Hearing Date or complaint as indicated above. R fi, ~ R ENS --,~._~.~..,.....,""'--"'",~, . 3-7-0 16. HOW sEf!vm, PERSONAL ( ) RESIDENC;~( -) ___.. ,PO$!~~ ( ) _.. _ '"" Pb~ (_I~ .__,~H.~~IFF~SS!f.':.U..._. ,PIHE.B.U. ~ SEERE~<)n~S 1~ I hereb_y' certify and return a NOT FO~NO because I. am .un~\?}e ~ _l'?~t~ the..L~\yiQY~1,-99......fr.'Q?.l"\Y, c~r.got.:?,lion~ I'ltq, nam~d aqolJe.. (~rem.arks belQw.) 18."NAME AND TiTlE OF INDIVIDUAL SERVED I UST ADDRESS HERE IF NOT SHOWN ABOVE (Re!ationship to Defendant) 19. Date of Service 20. Time of Service , '1-4-01 'A.:.'.! 21. ATTEMPTS 22. REMARKS: , tm !(N(\l;." A'[' M)Dne:3S GiVEr,; '-, '. I .' h\,lS,t.1 \ 2~. Advanc~sts 75..off 34. Forejgn' County Costs ->1........"" 41. AFRRMED~ and sU~~~~ib~d ,to before me thiS:\ , 13th 44. Signature of .:.. ; De. heriff 42.dayof ~7~~~ 45. Signature of York 43. >>~Z_h > ~ ~- . " <7> /p:f. ;:)HC:;;I:.~e;: ?~..:i02~ ___ ~/' _ , Proth',ota,l)'IN~...l.'ublic .J.' - -. .46. Signature ot Foreign MY COMMISSION EXPIRES :: ':;.7~.f:..- T , . - _. _ _ CQun Sh~rjft . " 50.1 ACKNOWLEDGE RECEIPT'OF~TAE SHERIFF'S REruRN SIG ATtiRE. . _~ ~_, OF AUTHqAIZED ISSUINGAUTI-IOAITY AND :I:tn:i:: - :---. -.~' ~_"~ ___=~ ._~ ~_O___'_~'_"_'''''_~'_d__~'_.,"",,'~' 1. WHITE . Issuing Authority 2. PINK - Attorney 3. CANARY - Sheriffs Office 4. BLUE - Sheriff's,Office ,"'"" ~ , SO ANSWER. 47. Date 48. Dale .----" }/'!3/01 49. Date .~:~~: ~f 51-. Date ~~~;i~~d- "';,h ..:. 2 of 2 COUNTY OF YORK OFFICE OF THE SHERIFF SERVICE CALL (717) 771-9601 28 EAST MARKET ST., YORK, PA 17401 " INSTRUCTIONS SHERIFF SERVICE PLEASE TYPE ONLY LINES 1 TO 12 PROCESS RECEIPT, and AFFIDAVIT OF RETURN DO NOT DETACH ANY COPIES. 1. PLAINTIFF/SJ 2. COURT NUMBER 01-251 Civil . Fi,rsi: Horizon Home Loan Corp. 4. TYPE OF WRIT OR COMPLAINT 3. DEFENDANT/SI Vicki al. Reins. Not/Complaint Boudman et. . 5. NAME OF INDIVIDUAL, COMPANY, CORPORATION, ETC. TO SERVE OR DESCRIPTION OF P- LE I ACHED, OR SOLD. SERVE { . C. Blaine Boudman 6. ADDRESS (STREET OR RFD WITH BOX NUMBER, APT NO., CITY, BORD, lWF., STATE AND ZIP CODE AT ~'" ~-r7QT9--.YlovE6 7. INDICATE SERVICE: 0 PERSONAL 0 PERSON IN CHARGE EPUTIZE Cu:rniJ~R1'Jr.a.md NOW < IF, 101 19_1, RIFFOFJrl!)RKC York COUNTY to exe.!ij to law. This deputation being made at the request and risk of the plaintiff. T. 8. SPECIAL INSTRUCTIONS OR OTHER INFORMATION Tl:IAT WILL ASSIST IN EXPEDITING SERVICE: POSTED 0 OTHER the sheriff of ccording H RIFF 0 . COUNTY Cumberland OUT OF COUNTY ClIMBERLAND AOVANCED FEE PAID BY ATTY. NOTE ONLY APPUCABLE ON WRIT OF EXECUTION: N.S. WAIVER OF WATCHMAN - Any deputy sheriff levying upon or attaching any property under within writ may leave same without a watchman, in custody of whomever is found in possession. after notifying person of levy or attachment, without liability an the part of such deputy or the sheriff to any plainliff herein for any loss, destruction, or removal of any property before sheriff's sale thereof. 9. TYPE NAME AND ADDRESS of ATTORNEY/ORIGINATOR and SIGNATURE 10. TELEPHONE NUMBEA 11. DATE FILED FEDERMAN & PHELAN 3-5-01 12. SEND NOTICE OF SERVICE COpy TO NAME AND ADDRESS BELOW: (This area must be compli~ted if notice is to be mailed). CUMBERLAND CO. SHERIFF SPACE BELOW FOR USE OF THE SHERIFF ONLY - DO NOT WRITE BELOW THIS LINE SIGNATURE OF AUTHORIZED CLERK 14. Date Received 15. Expiration/Hearing Date R. AHRENS 3-7-01 4-4-01 13. I acknowledge receipt of the writ or complaint as indicated above. 16.HOW SERVED: PERSONAL ( ) RESIDENCE ( POSTED ( ) POE ( ) SHERIFF'S OFF ( ) OTHER ( ) SEE REMARKS 17. I hereby certify and return a NOT FOUND because I am unable to locate the individual, company, corporation, ete, named above. (See remarks below.) 16. NAME AND TfTLE OF INDIVIDUAL SERVED I LIST ADDRESS HERE IF NOT SHOWN ABOVE (Rel~ltionship to Defendant) 19. Date of Service 20. lime of Service 21. ATTEMPTS 22. REMARKS: MOVED TO PO BOX 243, BOILING SPRINGS, FA. J.70::l1-'02"43 (ClJMT3!':?J,JlJro CTY) Left no corresponding street address with p..o. Last known a~dress of 26 W. Epply Dr. Carlisle, is "ar.ant 23. Advance Go.sts 13TH 44. Signature of De . S eriff 45. Signature 01 York County Sheriff 47. Date 41. AFFIRMED and subscriped to before me this lc'1, ~ - - --.~ ,',,' ~]A.RCH.' " 48. Date 42. day 0 FOP. WILLIAM M. 46. Signature of Foreign Coun Sheriff RN SIGNATURE HOSE( 3/13/01 43. (/ 49. Date 51. Date Received 2. PINK - Attorney 3. CANARY - Sheriffs Office 4. a'WE . Sheriff's Office ~ ~ _, ,n ~ "- , ."'^~ M: l UJd .~'" - -~ "I'" ~ L Wild r~' e(j, V'c;/ < JJIf.j=lf/0 .\ftlQ,{ .. ,) .ff} ,~ t, G;3/~:;: :~, .,,~:; i) i J~/ J 11_( ~f1iill~L "-,,.d~ .,'~". - -, -- ~.." 'T- "'''re' "'".'.,,,-,-- ,~. ~'". -lllllIHI '. ';f1~~_~!~1!If*~iil!Qli~;'t~\!!'1!p'!l;i"'!lm'i>j";\,1i~'f!"1'~,1'l'if\,":I""~i"'''~n';,'''':~-'''\'''''''''1f;''i-;;::'f'''i,~.t'';'\".;r~hW:N!ifI',';fJ>>,-:''!:l;'j1'l;!f~~tlo1:~I!)fi!lI''.jilff",~~' ~'.f ~ COUNTY OF YORK OFFICE OF THE SHERIFF SERVICE CALL (717) 771-9601 2 of 2 28 EAST MAR'KET ST.;YORK, PA 17401 - -- . - ---- ~-- -. - - --. :,.p INSTRUCTIONS SHERIFF SERVICE PLEASE TYPE ONLY LINES 1 TO 12 PROCESS RECEIPT, and AFFIDAVIT OF RETURN DO NOT DETACH ANY COPIES. 1. PLAINTIFF/SJ 2. COURT NUMBER O~-251 Ci\, i 1 ~Ftrst Horizon Home Lr:>an Carp.. 4. TYPE OF WRIT OR" COMPLAINT - -- - 3. DEFENDA~T/S/ :Rqins. Not /C0;TlD 1 c: ii"\ t V-ir-t.;i Boudman, et . al. . _.J.... _ ~ .~ 5. NAME OF INDIVIDUAL, COMPANY, CORPORATION, ETC. TO SERVE OR DESCRIPTION OF J:>RO"?'EFrtt....rCr:BE LEV1Eb:.ATTACHEO, OR SOLD. -{ ~. B'.ain0 Eoudman 6. ADDRESS (STREET DR RFD WITH BOX NUMBER, APT NO., CITY, BORD, TWP., -STATE AND.ZIP CODE - -- '" ~-'.-ru.rg- - ;-10 \.) E"D D'pE,flS_Olinr;,U;HARG.E-.--~. DEPUT~ECllm[jeEA{i1i'r[i -~ D1s~cl.~SSM.A'L OP.o~TED _ .OOTJ1ER_ 19_1, 5 ERIFF oP'I"O'l'N< COUNTY, PA, do hereby deputiZe the sheriff of Yor k CQUNTY_to exec:ute this Writ and mal\e rEiJ!!rn thereof according to law. This deputation being made at the request and risk of the plaintiff. 8. SPECIAL INSTRUCTIONS OR OTHER INFORMATI.oN THAT WILL ASSIST IN EXPEDITING SERVICE: SERVE . AT 7.INDICATECsERVICE: 0 PE,RSONAL NOW ~ 't: (,jl SHERIFF OF ).{V~f,:. COUNTY Curnher1.and ~ . 1!1" OUT Of COl!NTY CUMBERLAriD ADVA~CEO FEE PAID BY ATTY. NOTE ONLY APPLICABLE .oN WRIT OF EXECUTION: N.S. WAIVER OF WATCHMAN. Any deputy sheriff levYing upon or attaching any property under within writ may leave sa'me without a watchman, in custody of whomever is found in possession. ,ifter notifying person of levy (lr attachment, without liability on the part of such deputy or the sheriff to any plaintiff hi?~ein for any loss, destruction, or_ removal of any property ~efore sh~riff's sale therepf. , , ~ _ _ _ __ 9. TYPE N4ME AND ADDRESS of ATTORNEY/ORIGINATOR and SIGNATURE 110. TELEE'HONE NUMBER F EDl;RMi\r, & PHELAN . ,. 12. SEND NOTICE OF SERVICE COPY TO NANlE AND ADDRESS BELOW: (This arel.l must be completed If notice Is to be mailed). CUMBERLAND CO. SHERIFF , ~" SPACE BELOW FORU$E.ofrH~$HJ;fliFF QNLY ~[)ON.QJWFlr:r:E !;3i;L""Ow.rHIS LINE '13. I acknowJeoge receipt of the writ "" SIGNATURE OF AUTHORIZED CLERK 14. Date Received 15, Expiration/Hearing Date or complaint as indicated above. R~ AHRENS 3-7-01 -'i--4-01 I":OATE FILED 3-5-01 . 16. HOW'SEJ:f;.rED:\ PERSONAL ( ) RESIDENCE ( ) POSTED ( ") P"OE ( ) 'SHEFlIFF'S OFF ( - J 17.:iJ I here~y'_certify and return a NOT FOUND because I am unable to_!<;lc.ate t~e-i~di.vid.~al,_f()!'lpa!l~~Q.l'QoratiCl'n, ~!~,_n.~_J!led .9-bove~ 1 Ii. NAME AN.I? TITLE OF INDIVIDUAL SERVED I LIST ADDRESS-HERE IF NOT SHOWN ABOVE (Relationship to Defendant) OTHER ( ) SEE- REMARKS (S~_ remarks below,} 19, Date of Service 20. Time of Service l<<NED TO PO BOX 243, BOILING SPRIN3S, p;a, 17::01-0243 (CUMBERLAND C'l'Y) Left no correspondi.ng street address with p"o. T,ast known add-'-"'ss nf?6 W. FPr>1y Dr.. r.arlis.le, i~ \1ar'an t _..a. 34. Foreign ' ~-' ~ . ".'"....~~.-. ;'..,... . . 41.AFFIAMED and ~uJjSgribec{ t6_-before~rnellis -- ~ _.'__ '>.;~_..<' _"1" --... _ '. '. +"\~ 42. day of' ~.~"J :' ,,~ . , . /;' I! C 4~._ -~ J!'I!;L-_) .'(':f1 iflnLt;a.r~ f-1.. H.:')!=:-::' ;', ~ I .. .~. ~;onotary/Notary PubU ....- 46. Signature of Foreign MY COMMISSION EXPIREs ,,-~-y c. ~ Coun Sheriff 50. I ACKNOWLEDGE RECEIPT Of E__SHERIFF'S RETURN SIGNATURE .- OF, AUTiI'9BtZED ISSUING AufuoRITY AND TITLE 1. WHITE. IsSuing Aulhority 2. PINK ':.~~omey 3. CANARY - Sheriff's Office 4. BLUE - Sheriff's OffiCE) ',' /'"l_. .. ... ::.' ~~~"'r7 13TH so ANSWeR. 44. Signature of De .-S eriff 45. Signature of York County Sheriff 47. Date 48. Date 3i"!.3/~)j 49. Date 151, Date Received .. - - ~"".. If' , ., FEDERMAN AND PHELAN, LLP By: FRANK FEDERMAN, ESQUIRE IDENTIFICATION NO. 12248 ONE PENN CENTER AT SUBURBAN STATION 1617 JOHN F. KENNEDY BOULEVARD SUITE 1400 PHILADELPHIA, PA 19103-1814 (215) 563-7000 FIRST HORIZON HOME LOAN CORPORATION, F/KI A FT MORTGAGE COMPANIES, DIBI A MNC MORTGAGE 4000 HORIZON WAY, IRVING, TX 75063 ATIORNEY FOR PLAINTIFF C) ,- COURT OF COMMON PLE~ -r" "-.: CIVIL DIVISION 0',;.' :-z..:-;,.:' ~?,~' ~~ ~~~ )> c:..: ?~ TERM =< o c' -,' --~ ~...j ~: ~ Plaintiff No.6l - 2~- , ~ v. CUMBERLAND COUNTY VICKI BOUDMAN C. BLAlNE BOUDMAN 26 WEST EPPLEY DRIVE, CARLISLE, PA 17013 en c"] Defendant(s) ~~~ J!O,{4..q,,<v '? r: '';1I(.'y -9/v" ~J'!: ~:o ^' ~d~ ,?r/f' "fl_ ~D.h.~' V-94'" r', ,,- t,;,.-- (2. ,...., ~:\~~;t, : ,; " : \ ',! ';.:... CIVIL ACTION - LAW COMPLAINT IN MORTGAGE FORECLOSURE NOTICE ~*THlS FIRM IS A DEBT COLLECTOR ATTEMPTING TO COLLECT A DEBT AND ANY IN~RMA TION OBTAINED WILL BE USED FOR THAT PURPOSE. IF YOU HAVE PREVlOUSL Y i' . RE€lEIVED A DISCHARGE IN BANKRUPTCY AND THIS DEBT WAS NOT REAFF[RMED, THIS -~ CO~PONDENCE [S NOT AND SHOULD NOT BE CONSTRUED TO BE AN ATTEMPT TO COLLECT A DEBT, BUT ONLY ENFORCEMENT OF A LIEN AGAINST PROPERTY. ** 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 this 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 LA WYER 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. [.(1?:: if(;;),;;:,. '" I:.S 0::- :...'" l.c.J;$ ;rf~R We hereby certiiv the ~;:: % within 10 0.. E\ irue and jl it! t:;- correct copy of the CUMBERLAND COUNIY Q; 9:: ::-t orlginal filed of record CUMBERLAND COUNIY BAR ASSOCIATION if/?;?' FEDERMAN AND PHELAN 2 LIBERTY AVENUE ,....... . l<: ''It' CARLISLE, PA 17013 , t nuE COpy FROM RECORD (717) 249-3166 IfI TlllItImonyWbereot, I here unto set my haM .. tile seal ilhaid, ':'!l, II CarlilliI, . PI. '- ~./~~ _1; ~.~~ F'rtIthu.I01lnt . ~ - \,~' : Loan #: OO()9165861 ':~~(J/ ~~ 1-"' , - , - _~r-A: , , FEDERMAN AND PHELAN, LLP By: FRANKFEDERMAN,ESQUffiE IDENTIFICATION NO. 12248 ONE PENN CENTER AT SUBURBAN STATION 1617 JOHNF.KENNEDYBOULEVARD SUITE 1400 PHILADELPHIA, PA 19103-1814 (215) 563-7000 FIRST HORIZON HOME LOAN CORPORATION, F!KJ A FT MORTGAGE COMPANIES, DIEI A MNC MORTGAGE 4000 HORIZON WAY, IRVING, TX 75063 ATIORNEY FOR PLAINTIFF COURT OF COMMON PLEAS CIVIL DIVISION TERM Plaintiff v. NO. CUMBERLAND COUNTY VICKI BOUDMAN C. BLAINE BOUDMAN 26 WEST EPPLEY DRIVE, CARLISLE, PA 17013 Defendant(s) CIVIL ACTION - LAW COMPLAINT IN MORTGAGE FORECLOSURE NOTICE "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 AND THIS DEBT WAS NOT REAFFIRMED, THIS CORRESPONDENCE IS NOT AND SHOULD NOT BE CONSTRUED TO BE AN ATTEMPT TO COLLECT A DEBT, BUT ONLY ENFORCEMENT OF A LIEN AGAINST PROPERTY. ** 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 this 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 maybe 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. We hereby certify the within to baa true and correct copy of the original fifsd of record CUMBERLAND COUNTY FEDERMAN AND PHELANUMBERLAND COUNTY BAR ASSOCIATION 2 LIBERTY AVENUE CARLISLE,PA 17013 (717)249-3166 Loan #: 0009165861 )~ I ~ ,. 'M. 1. Plaintiff is: FIRST HORIZON HOME LOAN CORPORATION, FfKI A Ff MORTGAGE COMPANIES, D/B/A MNC MORTGAGE 4000 HORIZON WAY, IRVING, TX 75063 2. The name(s) and last known addressees) of the Defendant(s) are: VICKI BOUDMAN C. BLAINE BOUDMAN 26 WEST EPPLEY DRNE, CARLISLE, PA 17013 who is/are the mortgagor(s) and real owner(s) of the property hereinafter described. 3. On 12/11/97 mortgagor(s) made, executed and delivered a mortgage upon the premises hereinafter described to PLAINTIFF which mortgage is recorded in the Office of the Recorder of CUMBERLAND County, in Mortgage Book No. 1421, Page 1103. 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 1/1/00 and each month thereafter are due and unpaid, and by the terms of said mortgage, upon failure of mortgagor to make such payments after a date specified by written notice sent to Mortgagor, the entire principal balance and all interest due thereon are collectible forthwith. A copy of such notice is attached as Exhibit "A." ").i!~~"~' ~,' ,,-, -. ., 11 " - -[ 6. The following amounts are due on the mortgage: Principal Ba]ance Interest ]211/99 through ]211100 (Per Diem $32.08) Attorney's Fees Cumulative Late Charges ] 2111197 to 12/1100 Cost of Suit and Title Search Subtotal $]59,283.96 11,741.28 4,000.00 786.04 750.00 $] 76,561.28 Escrow Credit Deficit Subtotal 0.00 1.498.46 $1.498.46 TOTAL $]78,059.74 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 Sheriffs Sale. If the Mortgage is reinstated prior to the Sale, reasonable attorney's fees will be charged. 8. This action does not come under Act 6 of ]974 because the original mortgage amount exceeds $50,000.00. 9. The Combined Notice has been sent to the Defendant(s) by regular and certified mail as required by 35 P.S. ~1680.403c on the date(s) set forth in the true and correct copy of such notice(s) attached hereto as Exhibit "A." ] O. The Temporary Stay as provided by the Homeowner's Emergency Mortgage Assistance Program, Act 91 of ]983, has terminated because either: (i.) Defendant(s) have failed to meet with the Plaintiff or an authorized Credit Counseling Agency in accordance with Plaintiff s written Notice to Defendants, a true and correct copy of which is attached hereto as Exhibit "A"; or (ii.) Defendant(s) application for assistance has been rejected by the Pennsylvania Housing Finance Agency. WHEREFORE, PLAINTIFF demands an in rem Judgment against the Defendant(s) in the sum of $178,059.74, together with interest from ]211100 at the rate of$32.08 per diem to the date of Judgment, and other costs and charges collectible under the mortgage and for the foreclosure and sale of the mortgaged property. Isl Frank Federman FRANK FEDERMAN, ESQUIRE Attorney for Plaintiff ,'~1l,1!: ,. - 1001 ,. . - JRrn '. . FIRST HORIZON HOME LOANS 4000 HORIZON WAY IRVING, TX 75063 11/7/00 VICKI BOUDMAN 26 WEST EPPLEY DRIVE CARLISLE PA 17013 ACT 91 NOTICE TAKE ACTION TO SAVE YOUR HOME FROM FORECLOSURE This is an official notice that the mortgage on your home is in default, and the lender intends to foreclose. Specific information about the nature of the default is provided in the attached pages. The HOMEOWNER'S MORTGAGE ASSISTANCE PROGRAM (HEMAP) may be able to help to save your home. This notice explains how the program works. To see if HEMAP can help, you must MEET WITH A CONSUMER CREDIT COUNSELING AGENCYWITHIN 30 VA YS OF THE DATE OF THIS NOTICE. Take this notice with you when you meet with the Counseling Agency. The name, address and phone number of Consumer Credit Counseling Agencies serving your CounlY are listed at the end ofthis Notice. If you haye any questions, you may call the Pennsylvania Housing Finance Agency toll free at 1-800-342-2397. (Persons with impaired hearing can call (07)780-1869). This Notice contains iml'ortantlegal information. If you haye any questions, representatiyes at the Consumer Credit Counseling Agency may be able to help explain it, You may also want to contact an attorney in your area. The local bar association may be able to help you fmd a lawyer. LA NOTIlCACION EN EDJUNTO ES DE SUMA IMPORTANCIA, PUES AFECTA SU DERECHO A CONTINUAR VIVIENPO EN SU CASA. SI NO COMPRENDE EL CON11ENIDO DE ESTA NOTIFICACION OBTENGA UNA TRADUCCION IMMEDITAMENTE LLAMANDO ESTA AGENCIA (PENNSYL VIAN HOUSING FINANCE AGENCY) SIN CARGOS AL NUMBERO MENCIONADO ARRIBA. PUEDES SER ELEGIBLE PARA UN PREST AMO POR EL PROGRAMA LLAMADO "HOMEOWNER'S EMERGENCY MORTGAGE ASSISTANCE PROGRAM" EL CUAL PUEDE SAL V AR SU CASA DE LA PERDIDA DEL DERECHO A REDIMIR SU HIPOTECA. t;)(H\B\T A i:)ij1lfillj...."'.~ 1--, FIRSTHO~ONHOMELOANS 4000 HO~ON WAY IRVING, TX 75063 11/7/00 C BLAINE BOUDMAN 26 WEST EPPLEY DRIVE CARLISLEPA 17013 sf 3) 1/0D/tJOJ- ACT 91 NOTICE TAKE ACTION TO SAVE YOUR HOME FROM FORECLOSURE This is an official notice that the mortgage on vour home is in default. and the lender intends to foreclose. Specific information about the nature of the default is provided in the attached pages. The HOMEOWNER'S MORTGAGE ASSISTANCE PROGRAM (REMAP) mav be able to help to save vour home. This notice explains how the program works. To see ifHEMAP can help. vou must MEET WITH A CONSUMER CREDIT COUNSELING AGENCYWITHIN 30 DAYS OF THE DATE OF THIS NOTICE. Take this notice with vou when vou meet with the Counseling Agencv. The name. address and phone number of Consumer Credit Counseling Agencies serving vour CounlY are listed at the end of this Notice. Ifvou have anv Questions, vou mav call the Pennsvlvania Housing Finance Agencvtoll free at 1.800-342-2397. (Persons with impaired hearing can call (707) 780-1869). This Notice contains important legal information. If you have any questions, representatives at the Consumer Credit Counseling Agency may be able to help explain it. You may also want to contact an attorney in your area. The local bar association may be able to help you fmd a lawyer. LA NOTlICACION EN EDJUNTO ES DE SUMA IMPORTANCIA. PUES AFECTA SU DERECHO A CONTlNUAR VIVIENDO EN SU CASA. SI NO COMPRENDE EL CONTENIDO DE EST A NOTIFICACION OBTENGA UNA TRADUCCION IMMEDITAMENTE LLAMANDO ESTA AGENCIA (PENNSYL VIAN HOUSING FINANCE AGENCY) SIN CARGOS AL NUMBERO MENCIONADO ARRIBA. PUEDES SER ELEGIBLE PARA UN PRESTAMO POR EL PROGRA~,,^ LLAMADO "HOMEOWNER'S EMERGENCY MORTGAGE ASSISTANCE PROGRAM" EL CUAL PUEDE SAL V AR SU CASA DE LA PERDIDA DEL DERECHO A REDIMIR SU HIPOTECA. ~XH\B\T A_ 1~'\o/~l'~""" l , iT' .. r . C BLAINE BOUDMAN 26 WEST EPPLEY DRIVE CARLISLE PAl 70 13 ACCT #9165861 FIRST HORIZON HOME LOANS HOWEOWNER'S EMERGENCY MORTGAGE ASSISTANCE PROGRAM YOU MAYBE ELIGIBLE FOR FINANCIAL ASSISTANCE WHICH CAN SAVE YOUR HOME FROM FORECLOSURE AND HELP YOU MAKE FUTURE MORTGAGE PAYMENTS IF YOU COMPLY WITH THE PROVISIONS OF THE HOMEOWNER'S EMERGENCY MORTGAGE ASSISTANCE ACT OF 1983 (THE" ACT"); YOU MAY BE ELIGIBLE FOR EMERGENCY MORTGAEG ASSISTANCE: .IF YOUR DEFAULT HAS BEEN CAUSED BY CIRCUMSTANCES BEYOND YOUR CONTROL, .IF YOU HAVE A REASONABLE PROSPECT OF BEING ABLE TO PAY YOUR MORTGAE PAYMENTS, AND .IF YOU MEET OTHER ELIGIBILITY REQUIREMENTS ESTABLISHED BY THE PENNSYL VANIA HOUSING FINANCE AGENCY. TEMPORARY STAY OF FORECLOSURE-Under the Act, you are entitled to a temporary stay of foreclosure on your mortgage for thirty (30) days from the date of this Notice. During that time you must arrange and attend a "face-to-face" meeting with one of the consumer credit counseling agencies listed at the end of this Notice. THIS MEETING MUST OCCUR WITHIN THE NEXT (30) DAYS. IF YOU DO NOT APPLY FOR EMERGENCY MORTGAGE ASSISTANCE. YOU MUST BRING YOUR MORTGAGE UP TO DATE. THE PART OF THIS NOTICE CALLED "HOW TO CURE YOUR MORTGAGE DEFAULT", EXPLAINS HOW TO BRING YOUR MORTGAE UP TO DATE. CONSUMER CREDIT COUNSELING AGENCIES-If you meet with one of the consumer credit counseling agencies listed at the end of this notice, the lender may NOT take action against you for thirty (30) days after the date of this meeting. The names. addresses and telephone numbers of designated consumer credit counseling agencies for the counlY in which the propertv is located are set forth at the end of this Notice. It is only necessary to schedule one face-to-face meeting. Advise your lender immediatelv of your intentions. APPLICATION FOR MORTGAGE ASSIST ANCE- Your mortgage is in default for the reasons set forth later in this Notice (see following pages for specific information about the nature of your default). I you have tried and are unable to resolve this problem with the lender, you have the right to apply for [mancial assistance from the Homeowner's Emergency Mortgage Assistance Program. To do so, you must fill out, sign and file'a completed a completed Homeowner's Emergency Mortgage Assistance Program Application with one of the designated consumer credit counseling agencies listed at the end of this Notice. Only consumer credit counseling agencies have applications for the program and they will assist you in submitting a complete application to the Pennsylvania Housing Finance Agency. Your application MUST be filed or posnnarked within thirty (30) days of your face-to-face meeting. YOU MUST FILE YOUR APPLICATION PROMPTLY. IF YOU FAIL TO DO SO OR IF YOU DO NOT FOLLOW THE OTHER TIME PERIODS ET FORTH IN THIS LETTER, FORECLOUSRE MAY PROCEED AGAINST YOUR HOME IMMEDIA TEL Y AND YOUR APPLICATION FOR MORTGAGE ASSISTANCE WILL BE DENIED. GXH1B1T A ;"'~~""', ~~ ' I' ..~ AGENCY ACTION- Available funds for emergency mortgage assistance are very limited. They will be disbursed by the Agency under the eligibility criteria established by the Act. The Pennsylvania Housing Finance Agency has sixty (60) days to make a decision after it receives your application. During that time, no foreclosure Droceedings will be Dursued against vou ifvou have met the time renuirements set forth above. You will be notified directly by the Pennsylvania Housing Finance Agency of its decision on your application. NOTE: IF YOU ARE CURRENTLY PROTECTED BY THE FILING OF A PETITION IN BANKRUPTCY, THE FOLLOWING PART OF THIS NOTICE IS FOR INFORMATION PURPOSES ONLY AND SHOULD NOT BE CONSIDERED AS AN ATTEMPT TOCOLLECT THE DEBT. (If you have filed bankruptcy you can still apply for Emergency Mortgage Assistance). HOW TO CURE YOUR MORTGAGE DEFAULT {Bring it UD to date), NATURE OF THE DEFAUL T- The MORTGAGE debt held by the above lenderon your property located at: 26 WEST EPPLEY DRIVE CARLISLE PA 17013 IS SERIOUSLY IN DEF AUL T because: A. YOU HAVE NOT MADE MONTHLY MORTGAGE PAYMENTS for the following months and the following amounts are now past due: Due 111100-11/1100 Payment Amount Due = $14371.06 Late Charges $786.04 Other charges (explain/itemize): Bad Check Fee $ 0.00 Other Fees $96.98 Minus Suspense = $ 0.00 TOTAL AMOUNT PAST DUE: $ 15254.08 B. YOU HAVE FAILED TO TAKE THE FOLLOWING ACTION (Do not use ifnot applicable): HOW TO CURE THE DEFAULT-You may cure the default within TIlIRTY (30) days of the date of this notice BY P A YNG THE TOTAL AMOUNT PAST DUE TO THE LENDER, WHICH IS $15254.08 MORTGAGE PAYMENTS AND LATE CHARGES WHICH BECOME DUE DURING TIlE (30) DAY PERIOD. Payments must be made either by cash, cashier's check, certified check or money order made payable and sent to: First Horizon Home Loans 4000 Horizon Way Irving, TX 75063 Attn: Cashiering You can cure any other default by taking the following action within TIlIRTY (30) DAYS of the date of this letter: (Do not use ifnot aDDlicable.) exHIBIT A ' ~ .-, -'~'l!f""'Imtrr ~~ . <'0- I~ , . I I I , !-~~_r IF YOU DO NOT CURE THE DEFAULT-If you do not cure the default within THIRTY (30) DAYS of the date of this Notice, the lender intends to exercise its ril!hts to accelerate the mortl!al!e debt. This means that the entire outstanding balance of this debt will be considered due immediately and you may lose the cbance to pay the mortgage in monthly installments. If full payment of the total amount past due is not made within THIRTY (3D) DAYS, the lender also intends to instruct its attorneys to start legal action to foreclose upon vour mortl!al!ed property. IF THE MORTGAGE IS FORECLOSED UPON-The mortgaged property will be sold by the Sheriff to pay off the mortgage debt. If the lender refers your case to it's attorneys, but you cure the delinquency before the lender begins legal proceedings against you, you will still be required to pay the reasonable attorney's fees that were actually incurred, up to $50.00. However, if legal proceedings are started against you, you will have to pay all reasonable attorney's fees actually incurred by the lender even if they exceed $50.00. Any attorney's fees will be added to the amount you owe the lender, which may also include other reasonable costs. Ifvou cure the default within the THIRTY (30) DAY period. vou will not be reuuired to nav attorney's fees. OTHER LENDER REMEDIES-The lender may also sue you personally for the unpaid principal balance and all other sums due under the mortgage. RIGHT TO CURE THE DEF AUL T PRIOR TO SHERIFF'S SALE-If you have not cured the default within the THIRTY (30) DAY period and foreclosure proceedings have begun, vou still have the ricin to cure the default and Drevent the sale at anv tie UD to one hour before the Sheriff s Sale. You mav do so bv Daving the total amount then Dast due. plus anv late or other charges then due. reasonable attornev's fees and costs connected with the foreclosure sale and anv other costs connected with Sheriffs Sale as specified in writing bv the lender and bv Derforming anv other reuuirements under the mortgage. Curing your default in the manner set forth in this notice will restore your mortgage to the same position as if you had never defaulted. EARLIEST POSSIBLE SHERIFF'S SALE DATE-It is estimated that the earliest date that such a Sheriffs Sale of the mortgaged property could be held would be approximately Y _mouths from the date oUhis Notice. A notice of the actual date of the Sheriffs Sale will be sentto you before the sale. Of course, the amount needed to cure the default will increase the longer you wait. You may fmd out at any time exactly what the required payment or action will be by contacting the lender. HOW TO CONTACT THE LENDER: First Horizon Home Loans 4000 Horizon Way Irving, TX 75063 Attn; Loan Counseling Dept. 1-800-707-9998/Phone 1-214-672-3922/Fax EFFECT OF SHERIFF'S SALE- You should realize that a Sheriffs Sale will end your ownership of the mortgaged property and your right to occupy it. If you continue to live in the property after the Sheriff s Sale, a lawsuit to remove you and your furnishings and other belongings could be started by the lender at anytime. ASSUMPTION OF MORTGAGE-You _x_ mayor _ may not (CHECK ONE) sell or transfer your home to a buyer or transferee who will assume the mortgage debt, provided that all the outstanding payments, charges and attorney's fees and costs are paid prior to or at the sale and that the other requirements of the mortgage are satisfied. t;XHIBlT A , -, ~ r" ., YOU MAY ALSO HAVE THE RIGHT *TO SELL THE PROPERTY TO OBTAIN MONEY TO PAY OFF THEMORTGAE DEBT OR TO BORROWER MONEY FROM ANOTHER LENDING INSTITUTION TO PAY OFF THIS DEBT. *TO HAVE THIS DEFAULT CURED BY ANY THIRT PARTY ACTING ON YOUR BEHLF. *TO HAVE THEMORTGAGE RESTORED TO THE SAME POSITOIN AS IF NO DEF AUL THAD OCCURRED, IF YOU CURE THE DEFAULT. (HOWEVER YOU DO NOT HAVE THIS RIGHT TO CURE YOUR DEF AUL T MORE THAN THREE TIMES IN ANY CALENDAR YEAR.) *TO ASSERT THE NONEXISTENCE OF A DEF AUL T IN ANY FORECLOUSRE PROCEEDING OR ANY OTHER LAWSUIT INSTITUTED UNDER THE MORTGAGE DOCUMENTS. , " . . ." . '. *TO ASSERT ANY OTHER DEFENSE YOU BELIEVE YOU MA Y HAVE TO SUCH ACTION BY THE LENDER. *TO SEEK PROTECTION UNDER THE FEDERAL BANKRUPTCY LAW. Sincerely, Cartier A. Caldwell Default Referral Specialist II ~IBrr A 1:."".... . ~---""" " -, I y. "~ ~ PENNSYLVANIA HOUSING FINANCE AGENCY HOMEOWNER'S EMERGENCY ASSISTANCE PROGRA,\1 CONSUMER CREDIT COUNSELING AGENCIES (REV. 8/00) Lycoming..clinton Counties Cornmision for Community Action (STEP) 2138 Lincoln Street P.O. Box 1328 Williamsport, P A 17703 (570) 326-0587 FAX (570) 322-2197 CLINTON COUNTY CCCS of Northeastern P A 1631 South Atherton St. Suite 100 Slate College, PA 16801 (814) 238-3668 FAX (814) 238-3669 cecs of Northeastern P A 201 Basin Street Williamsport, P A 17703 (570)323-6627 FAX(570)323-6626 COLUMBIA COUNTY 1400 Abington Executiv.e Park Suite"J Clarks Summit PA 18411 (570) 587-9163 or (800) 922-9537 FAX (570) 587-9134-9135 31 W. Market Street roB 1127 Wilkes-Barre, PA 18702 (570) 821-0837 or (800) 922-9537 FAX (570) 821-1785 Cc>mmission on Economics Opportunity of Luzeme County 163 Amber Lane Wilkes-Barre. P A 18702 (570) 826-0510 or (800) 822-0359 FAX (570) 829-1665-{Call Before Faxing) (570) 4554994 HazeItown FAX (570) 455-5631-{CaJl Before Faxing) (570)836-4090 Tunkhannock CRAWFORD COUNTY Gre:ner Erie Communicy Action Committee 18 West 91b Street Erie. PA 16501 (814) 4594581 FAX (814) 456-0161 Booker T. Washington Center 1720 Holland Center Erie. PA 16503 (814) 453-5744 FAX (814) 5749 John F. Kennedy Center, Inc. 2021 East 20. Street Erie, PA 16510 (814) 898-0400 FAX (814) 898-1243 Shenango Valley Urban League, Inc. 601 Indiana Avenue Fanel~ PA 16121 (412)981-5310 cees of West em PeMsytvania, Inc. 2000 LingJestown Road Harrisburg, PA 11102 (717) 541-1757 Urban League ofMelropolicin Harrisburg N. 61tJ Street Harrisburg. P A 1710 I (717) 234-5925 FAX (717) 234-9459 CUMBERLAND COUl'tTY Financial Counseling Services of Franklin 31 West 3rd Street . Waynesboro, PA 17268 (717) 762-3285 YWCA of Carlisle 301 "0- Street Carlisle,PA 17013 . (717) 243-3818 FAX (717) 731-9589 Community Action Comm of the Capital Region 1514 Deny Street Harrisburg, P A 17104 (717) 232-9757 FAX (717) 234-2227 Adams County Housing Authority 139-143 Carlisle St Gettysburg. P A 17325 (117) 334-1518 FAX 334-8326 PENNSYLVANIA BULLETIN, VOL.l9, NO. 23. JUNE S. 1999 S}lH\B\1 A . ALL THAT CERTAIN'la.act of' ~and situate in. South. Middleton Township, Cumber1and County, Pennsy1van~a, bounded ,and'descr~bed in accordance with a survey prepared by John K. Boxler, XXX, a.s., dated 2/2~/96 and recorded in the Off~ce of the Recorder of Deeds for Cumberland County in Plan Book 72 page 115, revised 4/10/96, as follows: BEGINNING at an iron ~in on the n~rthern right of way line of West Eppley Dri~e at a corner of Lot 35, Se~~Lon 2-A, on the plan of Forgeda~e ~rossing: thenoe a10ng Lot 35, North 03 degrees ~7 minuces and OS seconds ~est, a dist::.ance of J.50.00 .feet to a.n i.ron pin; t:.hence a~ong Lot 30-A, ~ha8e I, North 66 degrees 42 minuees and S2 seconds East, a d~stance of 100.00 feee to an"iron pin; thence a10ng Lo~ 33, Section 2-A, South 03 ~eg~ees ~7 m~nuees and OS seconds East, a d~stance of ~51.02 fee~ to an' iron pin on the norehern right of way 1ine of West Eppley Or~ve; chence .long said northern right of way lLne of West Eppley Prive, by a curve to ohe left hav~ng a radius of 495.00 feet and are distance of 3~.B5 feet to a ?oint ~n che right of way l~ne; thence cont~nu~ng a~ong thQ northern r~sht ~f way 1ine of West Eppley Drive~ South 8& degrees 42 m~nutes and 52 ;econds West, a distance of 68~1e feet to an iron pin at Lot 35# Sect~on 2~ ~. tohe place of BEGINN:l:NG.. . ~ON~AINXNG ~5,OOO.00~quare feet and designated as Lot 34, Section 2-A of ?la~ of ~orgedale ~roBsing. lEX~G THE SAME PREMISES WHICH John E. Anderson and Pauline E. Anderson. lusband and wife, and Robert A. Thomas and Deborah J. Thomas, husband and <ife, by deed dated 6/23/97 and recorded 6/26/97 in the Recorder of Deeds )f~ice, ~n and for Cumber~and County, Pennsy1van~a, in Reco~d BoOk 160 page ~6 granted and conveyed unto S & A Cuscom Built Home6, Inc., gra~~or lere-i.n ~ - 'REMISES ON: 26 WEST EPPLEY DRIVE, CARLISLE, PA 17013 ~iK~IiiIm'll~__ ., , VERIFICATION RICHARD MINOR hereby states that he is ASSISTANT V.P. of FIRST HORIZON HOME LOANS CORPORATION mortgage servicing agent for Plaintiff in this matter, that he is authorized to take this Verification, and that the statements made in the foregoing Civil Action in Mortgage Foreclosure are true and correct to the best of his knowledge, information and belief. The undersigned understands that this statement is made subject to the penalties of 18 Pac C.S. Sec. 4904 relating to unsworn falsification to authorities. DATE: 1/ ~/tJ I i-~~~l ="""" 1-' ' - tfi) :;Yl.l ,~ ,~ ~ !:nnJ ], I "I.m~rti'l ^~ _0_ .'~ ,. VINVA1ASNN3d Tl C' I"]"';:") _~ ..J [I iI \'" 10. Wd 6S E 5 HVW .l.lNnoo CIfQ'lliJGHDO JI.:IIUiiHS 3111 40 301.:1.:10' ? .;' . .,.,.,...", ~,~__~; " ,~-~",!I1lM1Rml!r _ "<-'"-,_~_",__,,,,_',",__>~_"'_"'-"k'~ ~,_ "" il'ie> iniil ~ ,;:u . '(s f'(j _c;; r '~ k ~ ~ ~ - ) f. ~:;J ~, _.._,..", -=",_, _ ~'m>'IWif"""''1o,m,';"''11FN''-'''H'''N'*iil'i!_ml1~;;!!~~jf$If<;f~~O\'l;;W!'i\i~",Y-J~~I!!"~: ~ . .., FEDERMAN AND PHELAN, LLP By: FRANK FEDERMAN, ESQUIRE IDENTIFICATION NO, 12248 ONE PENN CENTER AT SUBURBAN STATION 1617 JOHN F. KENNEDY BOULEVARD SUITE 1400 PHILADELPHIA, PA 19103-1814 (215) 563-7000 FIRST HORIZON HOME LOAN CORPORATION, FfKJ A Ff MORTGAGE COMPANIES, D/Bf A MNC MORTGAGE 4000 HORIZON WAY, IRVING, TX 75063 ATIORNEY FOR PLAINTIFF o r- COURT OF COMMON PLE~ -p;:=-:. CNIL DMSION ,-f,,.,' :-z:. :-5.... ZC C!~' 0:.: ~~; ~.~; ~..:.; TERM ="2 Q ;;',.-' ~., '-"'",. '-.'''-' -~-~:; (-:- -'~.; ""'0 :-:2 I ,~"f .~~ 5~ ~. --," ~. ,- ..- Plaintiff NO,6l- 2~-' ~, v, CUMBERLAND COUNTY VICKI BOUDMAN C BLAINE BOUDMAN 26 WEST EPPLEY DRNE, CARLISLE, PA 17013 lJ- L. ~ ("') Defendant( s) ~ 41); '.!:~01. A Oh 1011- '2" r:rt{/~.. of/v ~J'~:r~v~ 11'~~a~' "'l/~lfi}~", ... 1,2: ::.~ S ..::'':: E-= LJ --'- u- C-.., :;:... (j) .. ~i L'--~; r- <,) cJ ~~ :_,1 L':;::" - ~ ~. CIVIL ACTION.. LAW COMPLAINT IN MORTGAGE FORECLOSURE NOTICE **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 RiR:EIVED A DISCHARGE IN BANKRUPTCY AND THIS DEBT WAS NOT REAFFIRMED, THIS .> CORRESpONDENCE IS NOT AND SHOULD NOT BE CONSTRUED TO BE AN ATTEMPT TO COLLECT ':) A DEBT, BUT ONLY ENFORCEMENT OF A LIEN AGAINST PROPERTY. ** 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 this 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 TIlE OFFICE~ SET FORTH BELOW TO FIND OUT WHERE YOU CAN GET LEGAL HELP. ;.t!)' It: i[&~ '" . 0::: ,,,,~.::.~ ~- N rv ~ q;. (i;' We hlllrebv certify the ~ ~ ~ within to OEl 8 true and $f '* /;!;t correct copy of the CUMBERLAND COUNrY fl: ~ Sf' original filed of record CUMBERLAND COUNrY BAR ASSOCIATION lil..~", C:) <il.t',,~,' FEDERMAN AND PHELAN 2 LIBERTY AVENUE TRuE COPY HIOM R!!!CO CARLISLE, PA 1701fn TOOt' ""- ,II; RD (717)249-3166 ,.;. !fflOOyW .,I-ltlUlwsetmYhand , ;~~~~~~ Loan #, 0009165861 ~~'!il~_ I', - p'. , -~~ #>> FEDERMAN AND PHELAN, LLP By: FRANK FEDERMAN, ESQUIRE IDENTIFICATION NO. 12248 ONE PENN CENTER AT SUBURBAN STATION 1617 JOHN F. KENNEDY BOULEVARD SUITE 1400 PHILADELPHIA, PA 19103-1814 (215) 563-7000 Frn.ST HORIZON HOME LOAN CORPORATION, F/KJ A FT MORTGAGE COMPANIES, D/BI A MNC MORTGAGE 4000 HORIZON WAY, rn.VING, TX 75063 ATTORNEY FOR PLAINTIFF COURT OF COMMON PLEAS CNIL DNISION TERM Plaintiff v. NO. CUMBERLAND COUNTY VICKI BOUDMAN C. BLAINE BOUDMAN 26 WEST EPPLEY DRIVE, CARLISLE, PA 17013 Defendant(s) CIVIL ACTION - LAW COMPLAINT IN MORTGAGE FORECLOSURE NOTICE **THIS FIRM IS A DEBT COLLECTOR ATTEMPTING TO COLLECT A DEBT AND ANY IN FORMA TION OBTAINED WILL BE USED FOR THAT PURPOSE. IF YOU HAVE PREVIOUSLY RECEIVED A DISCHARGE IN BANKRUPTCY AND THIS DEBT WAS NOT REAFFIRMED, THIS CORRESPONDENCE IS NOT AND SHOULD NOT BE CONSTRUED TO BE AN ATTEMPT TO COLLECT A DEBT, BUT ONLY ENFORCEMENT OF A LIEN AGAINST PROPERTY. ** 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 this 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 maybe 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 TillS 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. We hereby certify the within to baa true and correct copy of the original filed of record CUMBERLAND COUNTY FEDERMAN AND PHELANUMBERLAND COUNTY BAR ASSOCIATION 2 LIBERTY AVENUE CARLISLE, PA 17013 (717)249-3166 Loan #, 0009165861 ""1_ 1-1 . ~ Ie -I' 1'- . 1. Plaintiff is: FIRST HORIZON HOME LOAN CORPORATION, F/KlA FT MORTGAGE COMPANIES, D/B/A MNC MORTGAGE 4000 HORIZON WAY, IRVING, TX 75063 2. The name(s) and last known address(es) of the Defendant(s) are: VICKI BOUDMAN C. BLAINE BOUDMAN 26 WEST EPPLEY DRIVE, CARLISLE, PA 17013 who is/are the mortgagor(s) and real owner(s) of the property hereinafter described. 3. On 12/11/97 mortgagor(s) made, executed and delivered a mortgage upon the premises hereinafter described to PLAINTIFF which mortgage is recorded in the Office of the Recorder of CUMBERLAND County, in Mortgage Book No. 1421, Page 1103. 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 1/1/00 and each month thereafter are due and unpaid, and by the terms of said mortgage, upon failure of mortgagor to make such payments after a date specified by written notice sent to Mortgagor, the entire principal balance and all interest due thereon are collectible forthwith. A copy of such notice is attached as Exhibit "A." "~-" ~ ., e, 1-1 6. The following amounts are due on the mortgage: Principal Balance Interest 12/1/99 through 1211/00 (Per Diem $32.08) Attorney's Fees Cumulative Late Charges 12/11/97 to 12/1/00 Cost of Suit and Title Search Subtotal $159,283.96 11,741.28 4,000.00 786.04 750.00 $176,561.28 Escrow Credit Deficit Subtotal TOTAL 0.00 1.498.46 $1.498.46 $178,059.74 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 Sheriffs Sale. If the Mortgage is reinstated prior to the Sale, reasonable attorney's fees will be charged. 8. This action does not come under Act 6 of 1974 because the original mortgage amount exceeds $50,000.00. 9. The Combined Notice has been sent to the Defendant(s) by regular and certified mail as required by 35 P.s. g1680.403c on the date(s) set forth in the true and correct copy of such notice(s) attached hereto as Exhibit "A." 10. The Temporary Stay as provided by the Homeowner's Emergency Mortgage Assistance Program, Act 91 of 1983, has terminated because either: (i.) Defendant(s) have failed to meet with the Plaintiff or an authorized Credit Counseling Agency in accordance with Plaintiff s written Notice to Defendants, a true and correct copy of which is attached hereto as Exhibit "A"; or' (ii.) Defendant(s) application for assistance has been rejected by the Pennsylvania Housing Finance Agency. WHEREFORE, PLAINTIFF demands an in rem Judgment against the Defendant(s) in the sum of $178,059.74, together with interest from 12/1/00 at the rate of$32.08 per diem to the date of Judgment, and other costs and charges collectible under the mortgage and for the foreclosure and sale of the mortgaged property. Isl Frank Federman FRANK FEDERMAN, ESQUIRE Attorney for Plaintiff -"-[.:", " " l'i 'I . FIRST HORIZON HOME LOANS 4000 HORIZON WAY IRVING, TX 75063 11/7/00 VICKI BOUDMAN 26 WEST EPPLEY DRIVE CARLISLE PA 17013 ACT 91 NOTICE TAKE ACTION TO SAVE YOUR HOME FROM FORECLOSURE This is an official notice that the mortgage on vour home is in default. and the lender intends to foreclose. Soecific information about the nature of the default is orovided in the attached Dages. The HOMEOWNER'S MORTGAGE ASSISTANCE PROGRAM (HEMAP) mav be able to helo to save vour home. This notice exolains how the orogram works. To see if HEMAP can helo. vou must MEET WITH A CONSUMER CREDIT COUNSELING AGENCYWITHIN 30 DAYS OF THE DATE OF THIS NOTICE. Take this notice with vou when vou meet with the Counseling Agencv. The name. address and ohone number of Consumer Credit Counseling Agencies serving your County are listed at the end o(this Notice. I(vou have anv Questions. VOU mav call the Pennsvlvania Housing Finance Agencv toll free at 1-800-342-2397. (Persons with imoaired hearing can call (707) 780-1869). This Notice contains important legal information. If you have any questions, representatives at the Consumer Credit Counseling Agency may be able to help explain it. You may also want to contact an attorney in your area. The local bar association may be able to help you find a lawyer. LA NOTIICACION EN EDJUNTO ES DE SUMA IMPORTANCIA, PUES AFECTA SU DERECHO A CONTINUAR VIVIENDO EN SU CASA. SI NO COMPRENDE EL CONTENIDO DE ESTA NOTIFICACION OBTENGA UNA TRADUCCION IMMEDITAMENTE LLAMANDO ESTA AGENCIA (PENNSYL VIAN HOUSING FINANCE AGENCY) SIN CARGOS AL NUMBERO MENCIONADO ARRIBA. PUEDES SER ELEGIBLE PARA UN PRESTAMO POR EL PROGRAMA LLAMADO "HOMEOWNER'S EMERGENCY MORTGAGE ASSISTANCE PROGRAM" EL CUAL PUEDE SAL V AR SU CASA DE LA PERDIDA DEL DERECHO A REDIMIR SU HIPOTECA. t;XH\B\T A -~~b ,~ 1-- . -",l~~!1!Jl FIRST HORIZON HOME LOANS 4000 HORIZON WAY IRVING, TX 75063 11/7/00 C BLAINE BOUDMAN 26 WEST EPPLEY DRIVE CARLISLE PA 17013 S/31 ~OD/tvOL ACT 91 NOTICE TAKE ACTION TO SAVE YOUR HOME FROM FORECLOSURE This is an official notice that the mortgage on vour home is in default. and the lender intends to foreclose. SDecific information about the nature of the default is Drovided in the attached oages. The HOMEOWNER'S MORTGAGE ASSISTANCE PROGRAM (HEMAP) mav be able to helo to save vour home. This notice explains how the orogram works. To see ifHEMAP can helo. vou must MEET WITH A CONSUMER CREDIT COUNSELING AGENCYWITHIN 30 DAYS OF THE DATE OF THIS NOTICE. Take this notice with vou when vou meet with the Counseling Agencv. The name. address and phone number of Consumer Credit Counseling Agencies serving vour County are listed at the end of this Notice. Ifvou have anv Questions. vou mav call the Pennsvlvania Housing Finance Agencv toll free at I -800-342-2397. (Persons with impaired hearing can call (707) 780-1869). This Notice contains important legal information. If you have any questions, representatives at the Consumer Credit Counseling Agency may be able to help explain it. You may also want to contact an attorney in your area. The local bar association may be able to help you fmd a lawyer. LA NOTIICACION EN EDJUNTO ES DE SUMA IMPORTANCIA, PUES AFECTA SU DERECHO A CONTINUAR VIVIENDO EN SU CASA. SI NO COMPRENDE EL CONTENIDO DE EST A NOTIFICACION OBTENGA UNA TRADUCCION IMMEDITAMENTE LLAMANDO ESTA AGENCIA (PENNSYL VIAN HOUSING FINANCE AGENCY) SIN CARGOS AL NUMBERO MENCIONADO ARRIBA. PUEDES SER ELEGIBLE PARA UN PRESTAMO POR EL PROGRAMA LLAMADO "HOMEOWNER'S EMERGENCY MORTGAGE ASSISTANCE PROGRAM" EL CUAL PUEDE SAL V AR SU CASA DE LA PERDIDA DEL DERECHO A REDIMIR SU HIPOTECA. ~}(H\B\1 A. r' 1 ! . . C BLAINE BOUDMAN 26 WEST EPPLEY DRIVE CARLISLE PA 17013 ACCT#9165861 FIRST HORIZON HOME LOANS HOWEOWNER'S EMERGENCY MORTGAGE ASSISTANCE PROGRAM YOU MAY BE ELIGIBLE FOR FINANCIAL ASSISTANCE WHICH CAN SAVE YOUR HOME FROM FORECLOSURE AND HELP YOU MAKE FUTURE MORTGAGE PAYMENTS IF YOU COMPLY WITH THE PROVISIONS OF THE HOMEOWNER'S EMERGENCY MORTGAGE ASSISTANCE ACT OF 198.3 (THE "ACT"), YOU MAY BE ELIGIBLE FOR EMERGENCY MORTGAEG ASSISTANCE: 'IF YOUR DEFAULT HAS BEEN CAUSED BY CIRCUMSTANCES BEYOND YOUR CONTROL, 'IF YOU HAVE A REASONABLE PROSPECT OF BEING ABLE TO PAY YOUR MORTGAE PAYMENTS, AND 'IF YOU MEET OTHER ELIGIBILITY REQUIREMENTS ESTABLISHED BY THE PENNSYLVANIA HOUSING FINANCE AGENCY. TEMPORARY STAY OF FORECLOSURE-Under the Act, you are entitled to a temporary stay of foreclosure on your mortgage for thirty (30) days from the date of this Notice. During that time you must arrange and attend a "face-to-face" meeting with one of the consumer credit counseling agencies listed at the end of this Notice. THIS MEETING MUST OCCUR WITHIN THE NEXT (30) DAYS. IF YOU DO NOT APPLY FOR EMERGENCY MORTGAGE ASSISTANCE. YOU MUST BRING YOUR MORTGAGE UP TO DATE. THE PART OF THIS NOTICE CALLED "HOW TO CURE YOUR MORTGAGE DEFAULT'. EXPLAINS HOW TO BRING YOUR MORTGAE UP TO DATE. CONSUMER CREDIT COUNSELING AGENCIES-If you meet with one of the consumer credit counseling agencies listed at the end of this notice, the lender may NOT take action against you for thirty (30) days after the date of this meeting. The names. addresses and telephone numbers of designated consumer credit counseling agencies for the counl1l in which the prooertv is located are set forth at the end of this Notice. It is only necessary to schedule one face-to-face meeting. Advise your lender immediatelv of your intentions. .. APPLICATION FOR MORTGAGE ASSIST ANCE- Your mortgage is in default for the reasons set forth later in this Notiee (see following pages for specific information about the nature of your default). I you have tried and are unable to resolve this problem with the lender, you have the right to apply for fmancial assistance from the Homeowner's Emergency Mortgage Assistance Program. To do so, you must fill out, sign and file a completed a completed Homeowner's Emergency Mortgage Assistance Program Application with one of the designated consumer credit counseling agencies listed at the end of this Notice. Only consumer credit counseling agencies have applications for the program and they will assist you in submitting a complete application to the Pennsylvania Housing Finance Agency. Your application MUST be filed or postmarked within thirty (30) days of your face-to-face meeting. YOU MUST FILE YOUR APPLICATION PROMPTLY. IF YOU FAIL TO DO SO OR IF YOU DO NOT FOLLOW THE OTHER TIME PERIODS ET FORTH IN THIS LETTER, FORECLOUSRE MAY PROCEED AGAINST YOUR HOME IMMEDIATELY AND YOUR APPLICATION FOR MORTGAGE ASSISTANCE WILL BE DENIED. t;XH1B1T A <~,-, " ~" -, ~'C:- "I 11 I; . - AGENCY ACTION- Available funds for emergency mortgage assistance are very limited. They will be disbursed by the Agency under the eligibility criteria established by the Act. The Pennsylvania Housing Finance Agency has sixty (60) days to make a decision after it receives your application. During that time, no foreclosure proceedings will be pursued against vou if vou have met the time requirements set forth above. You will be notified directly by the Pennsylvania Housing Finance Agency of its decision on your application. NOTE: IF YOU ARE CURRENTLY PROTECTED BY THE FILING OF A PETITION IN BANKRUPTCY, THE FOLLOWING PART OF THIS NOTICE IS FOR INFORMATION PURPOSES ONLY AND SHOULD NOT BE CONSIDERED AS AN ATTEMPT TOCOLLECT THE DEBT. (If you have filed bankruptcy you can still apply for Emergency Mortgage Assistance). HOW TO CURE YOUR MORTGAGE DEFAULT (Brin!! it UP to date). NATURE OF THE DEFAUL T- The MORTGAGE debt held by the above Iender.on your property located at: 26 WEST EPPLEY DRIVE CARLISLE PA 17013 IS SERIOUSLY IN DEF AUL T because: A. YOU HAVE NOT MADE MONTHLY MORTGAGE PAYMENTS for the following months and the following amounts are now past due: Due 111/00-11/1100 PaymentAmountDue = $14371.06 Late Charges $786.04 Other charges ( explain/itemize): Bad Check Fee $ 0.00 Other Fees $96.98 Minus Suspense = $ 0.00 TOTAL AMOUNT PAST DUE: $ 15254.08 B. YOU HAVE FAILED TO TAKE THE FOLLOWING ACTION (Do not use if not applicable): HOW TO CURE THE DEFAULT-You may cure the default within THIRTY (30) days of the date of this notice BY P A YNG THE TOTAL AMOUNT PAST DUE TO THE LENDER, WHICH IS $15254.08 MORTGAGE PAYMENTS AND LATE CHARGES WHICH BECOME DUE DURING THE (30) DAY PERIOD. Payments must be made either by cash, cashier's check, certified check or money order made payable and sent to: First Horizon Home Loans 4000 Horizon Way Irving, TX 75063 Attn: Cashiering You can cure any other default by taking the following action within THIRTY (30) DAYS of the date of this letter: (Do not use if not aPDlicable.) t;XHJBIT A . p ... ~,i.:I1U;-, ~ ~- 1 " ,~ . . IF YOU DO NOT CURE THE DEF AUL T -If you do not cure the default within THIRTY (30) DAYS of the date of this Notice, the lender intends to exercise its ril!hts to accelerate the morll!al!e debt. This means that the entire outstanding balance of this debt will be considered due immediately and you may lose the chance to pay the mortgage in monthly installments. If full payment of the total amount past due is not made within THIRTY (30) DAYS, the lender also intends to instruct its attorneys to start legal action to foreclose upon vour mOrll!al!ed prooertv. IF THE MORTGAGE IS FORECLOSED UPON-The mortgaged property will be sold by the Sheriff to pay off the mortgage debt. If the lender refers your case to it's attorneys, but you cure the delinquency before the lender begins legal proceedings against you, you will still be required to pay the reasonable attorney's fees that were actually incurred, up to $50.00. However, iflegal proceedings are started against you, you will have to pay all reasonable attorney's fees actually incurred by the lender even if they exceed $50.00. Any attorney's fees will be added to the amount you owe the lender, which may also include other reasonable costs. Ifvou cure the default within the THIRTY (30) DAY period. vou will not be required to oav attorney's fees. OTHER LENDER REMEDIES-The lender may also sue you personally for the unpaid principal balance and all other sums due under the mortgage. RIGHT TO CURE THE DEFAULT PRIOR TO SHERIFF'S SALE-If you have not cured the default within the THIRTY (30) DAY period and foreclosure proceedings have begun, vou still have the right to cure the default and prevent the sale at anv tie UP to one hour before the Sheriff's Sale. You mav do so bv paving the total amount then oast due. OlllS anv late or other charges then due. reasonable attornev's fees and costs connected with the foreclosure sale and anv other costs connected with Sheriff's Sale as soecified in writing bv the lender and bv performing anv other requirements under the mortgage. Curing your default in the manner set forth in this notice will restore your mortgage to the same position as if you had never defaulted. EARLIEST POSSIBLE SHERIFF'S SALE DATE-It is estimated that the earliest date that such a Sheriff's Sale of the mortgaged property could be held would be approximately _9 _months from the date ofthis Notice. A notice of the actual date of the Sheriff's Sale will be sent to you before the sale. Of course, the amount needed to cure the default will increase the longer you wait. You may fmd out at any time exactly what the required payment or action will be by contacting the lender. HOW TO CONTACT THE LENDER: First Horizon Home Loans 4000 Horizon Way Irving, TX 75063 Attn: Loan Counseling Dept. 1-800-707-9998/Phone 1-214-672-3922/Fax EFFECT OF SHERIFF'S SALE- You should realize that a Sheriffs Sale will end your ownership of the mortgaged property and your right to occupy it. If you continue to live in the property after the Sheriff s Sale, a lawsuit to remove you and your furnishings and other belongings could be started by the lender at anytime. ASSUMPTION OF MORTGAGE-You _x_ mayor _ may not (CHECK ONE) sell or transfer your home to a buyer or transferee who will assume the mortgage debt, provided that all the outstanding payments, charges and attorney's fees and costs are paid prior to or at the sale and that the other requirements of the mortgage are satisfied. \:}(HlalT A ';\nJi!iI,~~~ - ,-~.~ ,,~ - 1"'1 II " , , . YOU MAY ALSO HAVE THE RIGHT .TO SELL THE PROPERTY TO OBTAIN MONEY TO PAY OFF THEMORTGAE DEBT OR TO BORROWER MONEY FROM ANOTHER LENDING INSTITUTION TO PAY OFF THIS DEBT. .TO HAVE THIS DEFAULT CURED BY ANY THIRT PARTY ACTING ON YOUR BEHLF. .TO HAVE THEMORTGAGE RESTORED TO THE SAME POSITOIN AS IF NO DEF AUL THAD OCCURRED, IF YOU CURE THE DEFAULT. (HOWEVER YOU DO NOT HAVE THIS RIGHT TO CURE YOUR DEF AUL T MORE THAN THREE TIMES IN ANY CALENDAR YEAR.) .TO ASSERT THE NONEXISTENCE OF A DEF AUL T IN ANY FORECLOUSRE PROCEEDING OR ANY OTHER LAWSUIT INSTITUTED UNDER THE MORTGAGE DOCUMENTS. , . . '. . " " . . .' . . . ..TO ASSERT ANY OTHER DEFENSE YOUBELIEVEYOUMA Y HAVE TO SUCH ACTION BY THE LENDER. .TO SEEK PROTECTION UNDER THE FEDERAL BANKRUPTCY LAW. Sincerely, Cartier A. Caldwell Default Referral Specialist II t;)(H1BIT A '~::~mJl!l"F1 ~_, '0 ,., " 1"- -~- . . PENNSYLVANIA HOUSING FINAl'ICE AGENCY HOMEOWNER'S EMERGENCY ASSISTANCE PROGRAM CONSUMER CREDIT COUNSELING AGENCIES (REV. 8/00) CLINTON COUNTY Lycoming-Clinton Counties Commision for Community Action (STEP) 2138 Lincoln Street P.O. Box 1328 Williamsport, P A 11703 (570) 326-0587 FAX (570) 322-2197 CCCS ofNonheastern PA 201 Basin Street WiIliamsport, P A 11703 (570)323-6627 FAJ< (570) 323-6626 COLUMBIA COUNTY 31 W. Market Street POB.1l27 Wilkcs-Barre,PA 18702 (570) 821-0837 or (800) 922-9537 FAJ< (570) 821-1785 Commission on Economics Opportunity ofLuzeme County 163 Amber Lane Wilkes-Barre. P A 18702 (570) 826-0510 or (800) 822-0359 FAX (570) 829-1665-{Call aefore Faxing) (570) 455-4994 Hazeltown FAJ< (570) 455-5631-{Call Before Faxing) (570)836-4090 Tunkhannock CRAWFORD COUNTY Booker T. Washington Center t 720 Holland Center Eric, PA 16503 (814) 453-5744 FAJ< (814) 5749 John F. Kennedy Center, Inc. 2021 Eas,20. Slree' Eric, PA 16510 (814) 898-0400 FAJ< (814) 898-1243 eees ofWcstem Pennsylvania, Inc. 2000 Linglestown Road Harrisburg. P A 11102 (717) 541-1757 CUMBERLAND COUl'<TY Urban Leaiue ofMetropoJitan Harrisburg N.6.S....t Harrisburg. PA 17101 (717) 234-5925 F AJ< (717) 234-9459 Community Action Comm of the Capital Region 1514 Deny Sir.., Harrisburg, P A 171 04 (717)232-9757 FAJ<(717)234-2227 PEll/NSYL V All/IA BULLETIN, VOL 29, NO. 23. JUNE 5, 1999 -".~'~-,""",,~~ ,." eees ofNorth=m PA 1631 South AthertOn St, Suite 100 State College, P A 16801 (814) 238-3668 FAJ< (814) 238-3669 1400 Abington Executive Park Suite.l Clarks Summit PA 18411 (570) 587-9163 or (800) 922-9537 FAX (570) 587-9134-9135 Greater Erie Community Action Committee 18 West 9th Street Erie, PA 16501 (814) 459-4581 FAJ< (814) 456-0161 Shenango Valley Urban League,Inc. 601 IndianaAvenue Farren, PA 16121 (412) 981-5310 Financial Counseling Services of Franklin 31 West 31lt Street . Wayncsboro. PA 17268 (717) 762-3285 YWCA of Carlisle 301 "0" S...., Carlisle, PA 17013 . (717)243-3818 FAJ<(717) 731-9589 Adams County Housing Authority 139-143 Carlisle St Gettysburg, P A 17325 (717) 334-1518 FAJ< 334-8326 B{H\B\1 A . hLL THAT ClSR'l'AINtract: .of.~a:nel situate in South l'4.i.ddlet:on Township, Curnber1and County, Pennsy1vania, bounded -and 'described in aecordance w~th a survey prepared by John K. Box~er. III. R.S.. dated 2/2~/~6 and recorded in the Office of the Reco~eler of Oeeds for Cumberland County in Plan Book 72 page 115. ~evised 4/10/96. as fol~ows: BEGINNING ~t: an iron pin on the nnrt:hern right of way line of West Eppley Orive at a corner of Lot 35, Se~c~on 2-A, on ehe plan of Fo~gedale Crossing; ~henee along Lot 35, North 03 degrees 17 minutes and OS seconds 'lese, a distance of 150.00 .feet:. to a.n iron pin. t.bence a1.ong Lot. 30-A, ~haBe X, N~rth 66 degrees 42 minuees and S2 seconds East, a distance of 100.00 feee to an'iron pin; thenee along Lot 33. Section 2-A, South 03 ~egrees 17 minutes and 08 seconds East, a distance Of ~51.02 feet to an. iron pin on the nort:hern right of way line of West: Eppley nrive, t:hence .long said northern right of way line of West Eppley nrive. by a curve to ~he left having a radius of 495.00 feet anel are distance of 31.85 feec co a ?o~nt in t~e right of way l~ne; thence cQntinu~ng a~ong ~he nor~h&rn r1ght ~f way 1ine of West Epp1ey Dr~ve, South 86 degrees 42 minuees and 52 ;econds WesC, a discance Qf 68~1e feet to an iron pin at Lot 35~ Section 2- ~, the plaC'e of BEGINN:tNG'. . :ONTAINING 15.000.0o~quare feet anel desisuat:eel as Lot 34. Seccion 2-A of ?lan of ~orgedale Cross~ng~ 3EING THE SAME PREMISES WHICH John E. Anderson and Pauline E. Anderson, \usband and wife, and Robert A. Thomas and Oehorah J. Thomas, husband and life, by deeel daced 6/23/~7 and recorded 6/26/~7 in t:he Re=order of Deeds )f~ice, in and for Cumberland County, Pennsy1vania, in Record Book 160 page ~6 granted and conveyed unto S & A Custom Buile Homes. Inc., grantor le:r:.-e.i.n. . . 'REMISES ON: 26 WEST EPPLEY DRIVE, CARLISLE, PA 17013 '!i1if~, r . VERlFICATION RICHARD MINOR hereby states that he is ASSISTANT V.P. of FIRST HORIZON HOME LOANS CORPORATION mortgage servicing agent for Plaintiff in this matter, that he is authorized to take this Verification, and that the statements made in the foregoing Civil Action in Mortgage Foreclosure are true and correct to the best of his knowledge, information and belief. The undersigned understands that this statement is made subject to the penalties of 18 Pa. C.S. Sec. 4904 relating to unsworn falsification to authorities. DATE: 1/ ~t? I k~ ";,ASSISTANT vie PRESiDENT ,~ 4J ('J/~:"-t ',; (-)J i::./f ;lL"""'"~"" I-! ,. 1'- H l _>".,. _ . ! ,_^,H.~ I. . ,- " --~." __'ri_ __ ~ ". . --"" ~ ~~ ttl'l ~ ./", '11\ 11 ~ _, ' "C;,,- (?';: :' 7 S';7 ~ :: rfJ d ~ (I 'cl/O rs:~. .D. ~1rJ 65 C' ._;2) ~ (, S II t'-ulJ ~ .. AJ.NfiO^ " UH L"-,";;' ;;;;o.:::;:\#J/1/3,,;J ",>i""" u U ,"""~ ..S 3id "dOH' t~ ~.' ,:J03r,,;dO .~ ~ ,,,;:j:IO .{i~. ~ , -~" _~....gm~Ji~r.:, _~~ , ~~~~!f 'JOO :;r """,. ~ ,,",1'7 -'>'11f';' ~W-"fl"""'_-_,,"_,~,"""f'~~"~":"1;"!iC';;;'FI'-~l~! iSm<'}'l!P<\\-~l!!!~; ~. - . ,,,~ ,~~ w!W~ ,~~iIj!IiI!I ,~,l@: ~rm!~~, ; :-., f"" " ~ ~ !...J ~ ~ 0;~_ ':i# PO ('> f: &:::; ~ '--s-C~~. ~. liUf! ~ b - ~... ~\ ~~ ~ : ~, l'iY\l e seJ -J M"' ~ r -.. iMl 'f~~_, ,$ . . . FEDER\/IAN AND PHELAN BY; Michele M. Bradford, Esq. Atty. !.D. #69849 1617 John F. Kennedy Boulevard Suite 1400 PhiladeJphia, PA 19103-1814 (21 'i) 5(;,.7000 FIRST 1lORIZON HOME LOAN CORPORATION, F/KIA FT MORTGi\GE COMPANIES, DIE. \ ::~CMORTGAGE ATTORNEY FORPLATINTITF COURT OF COMMON PLEAS CIVIL DIVISION Vs. CUMBERLAND COUNTY VICKI BOUDMAN C.] LP;:'!;: BOUDMAN NO. 01-251 CRRTlFWATION OF SF.RVTCF. I, Michele M. Bradford, Esquire, herby certify that a copy of the Motion for Ser\'ice Pmsuant to Special Order of Court has been sent to the individual(s) as indicated below by Le/::'" mail, postage prepaid, on the date listed below. VICKi :lOUDMAN 26 WEST EPPLEY DRIVE CARLISLE PA 17013 C. BLAINE BOUDMAN 26 WEST EPPLEY DRIVE CARLISLE P A 17013 400 JADE CIRCLE JE~'';:' ;3L:ACH, FL 34957 '; .he undersigned understands that this statement is made subject to the penalties of 18 Pa. C.S. 0~ .J relating to unsworn falsification to authorities. D~ i c: IV:> Y.3..2illll "j1udJJ IA. ~ Michele M. Bradford, Esquire Attorney for Plaintiff li:lMail1 F'-'11115/motions/county.comp . I! FEDERMAN AND PHELAN BY: Michele M. Bradford, Esq. Atty. !.D. #69849 1617 John F. Kennedy Boulevard Suite 1400 Philadelphia, PAl 9103- 1 8 1 4 (21~) ~(i1-7000 ATTORNEY FOR PLArnTITF F~STHO~ONHOMELOAN CORPORATION, F/KIA FT MORTGAGE COMPANIES, D/B/A MNC MORTGAGE COURT OF COMMON PLEAS CIVIL DIVISION vs. CUMBERLAND COUNTY VICKI BOUDMAN C. BLAINE BOUDMAN NO. 01-251 ORDER ANDNOW,this~dayof ~ ,2001, upon consideration of Plaintiff's Motion for Service Pursuant to Special Order of Court and the Affidavit of Reasonable Invesl i galion attached thereto, it is hereby ORDERED that Plaintiff may obtain service of the Comr!~int on the above captioned Defendant(s) VICKI BOUDMAN and C. BLAINE BOUDMAN, by mailing a true and correct copy of the Complaint by certified mail and regular mail to the Defendant's last known address, and to the mortgaged premises located at 26 WEST EPl'LEY DRIVE, CARLISLE, PA 17013. Service of the aforementioned mailings is effective upon the date of mailing and is to be done by Plaintiff's attorney, who will file with the Prothonotary's Office an Affidavit as to the mailing. J.~ f o(,.\J \j \ [A-\\ H:/Milrll Forms/motions/county.comp "i'-~"'" "0' I 1 " ~~, ---- ~ liiN\\~lA8Nr{3d }J'lnr,r"\ 'i\(,r1:",")ql!'1nO )'-1 \\._'<" _,' '-, ":._-',,J; , 1'"1 'r' ,. "" . () I ~'-J r! I I' \! :~i1 \ ,) t) '! >{) l"~: 'j ,,' ',,-, },JJ\/ Y. "" ~= b.u ";-'-~'='"{~, ~.",,-''>--~~'-'' '. -';b,'~_ "'"-,,"-='''''lirr:or '~lL~r~'t"~b'~-/J _r",,,,,~_~!/lI'lI~~~~~~~r UlJ:i_~ "".~~~Iji~J;I"~llifl,."",-,:ry-WCi"'_"jr'l,""","",_,,,,,,",JiiN';'i"">~",*:2':~il:il,j<1i<;,;:.tl:$'!!~~",~~~~~~~_ _i; FEDERMAN AND PHELAN BY: Michele M. Bradford, Esq. Atty. LD. #69849 1617 JohnF. Kennedy Boulevard Suite 1400 PhilJc!clphia, PA 19103-1814 (?1~) ~lii-7000 ATTORNEY FORPLArnTITF flRSTHO~ONHOMELOAN CORPORATION, F!KJA FT MORTGAGE COMPANIES, DIB/,^, MNC MORTGAGE COURT OF COMMON PLEAS CIVIL DIVISION vs. CUMBERLAND COUNTY VICKI BOUDMAN C. BLAlNE BOUDMAN NO. 01-251 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 AND THIS DEBT WAS NOT REAFFIRMED, THIS CORRESFONDENCE IS NOT AND SHOULD NOT BE CONSTRUED TO BE AN ATTEMPT TO COLLECT A DEBT, BUT ONLY ENFORCEMENT OF A LmN AGAINST PROPERTY. MOTION FOR SERVICE PURSUANT TO !,;PF,CI AT, ORnF,R OF c.mmT Plaintiff, by its counsel, Michele M. Bradford, Esquire, moves this Honorable Court for an Order directing service of the Complaint upon the above-captioned Defendant(s) by Certified mail and regular mail to the Defendant's last known address and mortgaged premises located at 26 WEST EPPLEY DRIVE, CARLISLE, P A 17013 and in support thereof avers the following: 1. Attempts to serve Defendant( s) with the Complaint have been unsuccessful, as indicated by the Sheriff's Return of Service attached hereto as Exhibit "A". 2. Pursuant to Pennsylvania Rule of Civil Procedure 430, Plaintiff has made a good faith effort 10 locate the Defendant(s). An Affidavit of Reasonable Investigation setting forth the specific inquiries made and the results is attached hereto as Exhibit "B". H:IMaill Fnl'llls/motions/county.comp ,~~~~ "," - r~ -',' 'C, , I I!' '-1 I' I ' .~ 3. Plaintiff submits that it has made a good faith effort to locate the defendants, but has been unable to do so. WHEREFORE, Plaintiff respectfully requests this Honorable Court enter an Order pursuant to Pennsylvania Rule of Civil Procedure 430 directing service of the Complaint by certifi~d mail and regular mail. ~dw2r 7ft"~ Michele M. Bradford, Esquire v H:/Main Forms/rnotions/county.comp , . i!lllmll.,~"," ]"\" - FEDERMAN AND PHELAN BY: Michele M. Bradford, Esq. Atty. LD. #69849 1617 J olm F. Kennedy Boulevard Suite 1400 Philadelphia, P A 19103-1814 (71~) ~hl-7000 FIRST HORIZON HOME LOAN CORPORATION, F/KIA FT MORTGAGE COMPANIES, D/B/A MNC MORTGAGE ATTORNEY FORPLAJNTITF vs. COURT OF COMMON PLEAS CIVIL DlVISION CUMBERLAND COUNTY NO. 01-251 VICKI BOUDMAN C. BLAINE BOUDMAN MFMORANnTTM OF I ,A W Pennsylvania Rille of Civil Procedure 430(a) specifically provides: (a) If service cannot be made under the applicable rule, the plaintiff may move the Court for a special order directing the method of service. The l\;jotion shall be a.ccompanied by an Affidavit stating the nature and extent of the investigation which has been made to detennine the where:,llollls ur the Defendant(s) and the reasons why service cannot be made. Note: A Sheriff's ft:turD of "Not Found" or the fact that a Defendant has moved without leaving a new forwarding address is insufficient evidence of concealment. Grm'7Alp.~ VI: Pnli<:, 238 Pa. Super. 362, 357 A.2d 580 (1976). "Notice of intended adoption mailed to last known address requires a good faith effort to discover the correct address." Artoption ofW~lkp.r 468 Pa. 165,360 A.2d 603 (1976). An illustration of good faith effort to locate the defendant includes (1) inquires of postal authorities including inquiries pursuant to the Freedom of In lonnation Act, 39 C.F.R. Part 265, (2) inquiries of relatives neighbors, friends and employers of the Defendant and (3) examinations of local telephone directories, voter registration records, local tax records, and motor vehicle records. As indicated by the attached Sheriff's Return of Service, attached hereto and marked as Exhibit "N', the Sheriff has been unable to serve the Complaint. A good faith effort to discover the wherenbouts of the Defendant(s) has been made as evidenced by the attached Affidavit of Reasonable Investigation, marked Exhibit "B". WHEREFORE, Plaintiff respectfully requests service of the Complaint by certified mail and regular mail. Respectfully submitted: ~~/Jl.~~ Michele M. Bradford, Esquire H:IM"ill FOTms/motions/county.comp ^,'f\Ill!'Il " . I" B&_R Services for Pro!essionals Inc. 235 SOUTH 13TH STREET PHILADELPHIA, PA 19107 PHONE: (215) 546-7400 FAX: 215-985-0169 Philadelphia Association of Professional Process Servers PLAINTII'F(S) FiTSi::' DEFENDANT(S) \l :i. c: k:!. SERVE AT ~iorizon HOMe Loan 'AFFIDAVIT OF SERVICE CASE NO. 01-~~~.)1 DATE RECEIVED .Janu<'ilrl' 2~.:5" 2~:1 .' BnudNan - , '"'c'c" \. ,.,' c, , ,. ~<, ~ of CUMberland County " . ~"" v .,.~..,. Civil Action Mortgage Fore(:losure 4\:~!!l .JadE; Cil"t:J.f~ Jensen Beach FL 34957 SERVE BY: February 8, 2i COMPANY CONTROL NO. CS1.45:1.49A REFERENCE NO. ~P...,-.t'pl.\"::d Lt,,, Served and made known to Vicki Boudpli,ll1 on the day of ,20_,at o'clock, M. at Commonwealth of Pennsylvania, in the manner described below: o Defendant(s) personally served. D Adult family member with whom said Defendant(s) reside(s). Relationship is o Adult in charge of Defendant's residence who refused to give name or relationship. D Manager/Clerk 01 placing of lodging in which Delendant(s) reside(s). o Agent or person in charge of Defendant's office or usual place of business. D Posted D OI?r.SCF(IPTIDN AGE HEIGHT \JEIGHT RACE SEX .... .... .....-....... - -- ...... ...----.... .... ..-- --..- --..-~. 4...... ... ..- .... -.. ..- -- .....-........ ---.. - ..- ....-.. ....-.... -.. -....... -- ."w-j'1.'11" .... .... -.. -.. -......... -.. -- --.... ". .... .... .... ...... -.. -.. .... -..... .. --~~:.;~~:~:~;~;;5~;::d~~~t:::~:=~~~~~~r;K;.;~.i:.l~:~~T,_:,I~:;::~l~Cf~:I~~.~:~=~~~ :\~:::::::~~::::::: ==~=====:===::=========================================::========================:=== DEPUTIZED SERVICE Now, this _____ day of __________, :1.9____, I do hereby deputize the Sheriff of _______________ County to serve this ___SuMMons __..CoMplaint ___Other ____________ and Make return therof and according to LaWn By (COMpetent Adult) ______________________ County Sheriff's Check $ ==~===================:======================================================:====== *** Special Instructions *** At)AP ~h:.~rv:i.cE~ EXHIBIT A NAME 01' SERVER p)- (JC (.?~~f:j B€~)- ve.!"' Sworn to & subscribed before me this ~ day of k:hr~o~ #',,",,"" Sheryl Randy Swiderski. *W *My Commission CC650 '''''0''\'''' Expires May 26, 2001 being duly sworn according to law, deposes and says that he/she is process server herein names; and that the facts herein set forth above are true and correct to the best of their knOWledge, information and belief. r ., . t. f - PI ....d'J.II..L.... Blvd. i< ,law Firm i .ttorney'e Name 1dress Process Server / Competent Adult -ererMan . le.an Frank FederMan? Esquile Sui. t." 14\!l1il, 1 FC"III L."d.'" 16J.1" -I" F ..Ffr. Hli.lad.dph.ld H.l 1~.1.\!\3..1B.l.4 lephone # ~j 6 ;~ -.. i" Q\ \!l ~) Identification # ,'~oo PhilCl,delphia Assoc. of Professional Process Servers Rev 1 94-07 Sheriff PRO PROTHY ...l.t:1Y1Uar.y :l:l , 20!!l:l 12 ;:'Hl DATE -'-' ,'~"W'lW'l"',,_'ffi'.';"'I'W"'1""-"" '-- '-'--'r"-"['-"Y"II'i'11l:\!'~ililJljjW"f,,,,.~,II}~~I~~,,,,,!"11fr-,---.,,""~n".;'-""~"'0<"~~J'_N"i~~ _l!!\_ O~;~, ,,~ :. .,_,,^,,~.~jWj;j;lil'iIlM"~'";~ffiii'~~ SHERIFF'S RETURN - NOT FOUND CASE NO: 2001-00251 P COMMONWEALTH OF PENNSYLVANIA COUNTY OF CUMBERLAND FIRST HORIZON HOME LOAN CORP VS BOUDMAN VICKI 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 BOUDMAN VICKI but was unable to locate Her in his bailiwick. He therefore returns the COMPLAINT - MORT FORE NOTICE , NOT FOUND , as to the within named DEFENDANT , BOUDMAN VICKI DEFENDANT NO LONGER RESIDES AT ADDRESS STATED DID NOT RECEIVE FURTHER INSTRUCTIONS FROM ATTY. PRIORTO EXP. DATE, RETURN NOT FOUND AS PER JASON RICCO ON 2/23/01. So ~answ~E!_~ / y:j::'/ .~#Y~ R. homas Kl ine I Sheriff of Cumberland County Sheriff's Costs: Docketing Service Not Found Return Surcharge 18.00 3.10 5.00 10.00 .00 36.10 FEDERMAN & PHELAN 02/23/2001 Sworn and subscribed to before me this day of A.D. I?rothonotary EXHIBIT A . '"1;~" " G~ .^--' J- ~, " SHERIFF '.S RETURN - NOT FOUND CASE NO: 2001-00251 p. COMMONWEALTH OF PENNSYLVANIA COUNTY OF CUMBERLAND FIRST HORIZON HOME LOAN CORP VS BOUDMAN VICKI 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 BOUDMAN C BLAINE but was unable to locate Him in his bailiwick. He therefore returns the COMPLAINT - MORT FORE NOTICE , NOt FOUND , as to the within named DEFENDANT , BOUDMAN C BLAINE DEFENDANT NO LONGER RESIDES AT ADDRESS STATED, DID NOT RECEIVE FURTHER INSTRUCTIONS FROM ATTY PRIOR ~O EXP. DATE, RETURN NOT FOUND AS PER JASON RICCO ON 2/23/01. Sheriff's Costs: Docketing Service Not Found Return Surcharge 6.00 .00 5.00 10.00 .00 21.00 ~~-~~/ R. Thomas Kline Sheriff of Cumberland County FEDERMAN & PHELAN 02/23/2001 Sworn and subscribed to before me this day of A.D. Prothonotary EXHIBIT A iD_~ r! PLAYERS NATIONAL LOCATOR AFFIDAVIT OF GOOD FAITH INVESTIGATION Loan Number: 0009165861 Attorney Firm: TRACK STARS Case Number: Subject: VICKI & C BLAINE BOUDMAN AKA.: C B BOUMAN, C B BOUDMAN Last Known Address: 26 W. EPPLEY DRIVE CARLISLE, PA 17013 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 01/02/2001, 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:476-68-7541 184-38-2202 B. EMPLOYMENT SEARCH: Unable to locate a good employer for Vicki or C Blaine Boudman. C. INQUIRY OF CREDITORS: Creditors indicated that Vicki and C Blaine Boudman are using 50 Brian Drive, Carlisle, PA 17013 with no valid home number. Vicki and C Blaine filed chapter 7 in July 2000, case #2000-03103, and released in October 2000, with attorney Stephen B Lipson. INQUIRY OF TELEPHONE COMPANY - A. DIRECTORY ASSISTANCE SEARCH: Directory assistance had no listing. INQUIRY OF NEIGHBORS - We contacted 717-258-4444 at 25 W Eppley Drive and spoke to a neighbor who stated Vicki and C Blaine Boudman moved from the last known address. INQUIRY OF POST OFFICE - A. NATIONAL ADDRESS UPDATE: As of December 28, 2000 the National Change of Address (NCOA) has no change for Vicki or C Blaine Boudman from the last known address. MOTOR VEHICLE REGISTRATION- A. MOTOR VEHICLE & DMV OFFICE: The Pennsylvania Department of Drivers Licensing has Vicki and C Blaine Boudman listed at the last known address. OTHER INQUIRIES - A. DEATH RECORDS: As of December 28, 2000 the Social Security Administration has no death records on file for Vicki or C Blaine Boudman and/or a.k.a.'s under their social security numbers. EXHIBIT B 'il~"""""",,,,~ ~~." , 'T - ~~~ ~ ""'" . . B. PUBLIC LICENSES (PILOT, REAL ESTATE, ETC.):, None C. COUNTY VOTER REGISTRATION: The County Voters Registration Office has no listing. ADDITIONAL INFORMATION ON SUBJECT- A. DATE OF BIRTH: Vicki - February 1955 C Blaine - April 1948 ~ _C) ~ AFFIANT Michael K Gross " NOTARY SEAL" Kristine M. Scott, Notary Public SI. Louis County, State of Missouri My Commission Expires 9/2/2002 Players National Locator 113 Old State Road, Suite 104 St. Louis, MO 63021 Phone: (636) 230-9922 Fax: (636) 230-0558 EXH\B\T B -"':mil ,~ . .~ ~~ ;~~.. VRRIFTCATION Michele M. Bradford, Esquire, hereby states that she is the Attorney for the Plaintiff in this action, that she is authorized to take this Affidavit, and that the statements made in the foregoing MOTION FOR SERVICE PURSUANT TO SPECIAL ORDER OF COURT are true and correct to the best of her knowledge, information and belief. The undersigned understands that this statement herein is made subject to the penalties of 18 Pa. C.S. Sec. 4904 relating to unsworn falsification to authorities. Date: M~y' ?001 'IU1'~ /J1.~ /huIfuI Michele M. Bradford, Esquire H:/Main Forms/motions/county.comp ')',qotIl' "~ " ., r ~~ "I; FEDERMAN AND PHELAN BY: FRANK FEDERMAN, ESQUIRE Identification No. 12248 One Penn Center at Suburban Station 1617 John F. Kennedy Boulevard Suite 1400 Philadelphia, PA 19103-1814 (215)563-7000 Attorney for Plaintiff FIRST HORIZON HOME LOAN CORPORATION, F/K/A FT MORTGAGE COMPANIES, D/B/A MNC MORTGAGE COURT OF COMMON PLEAS CIVIL DIVISION Plaintiff vs. VICKI BOUDMAN C. BLAINE BOUDMAN Cumberland County No. 01-251 CIVIL Defendants PRAECIPE TO REINSTATE CIVIL ACTION/MORTGAGE FORECLOSURE TO THE PROTHONOTARY: Kindly reinstate the Civil Action in Mortgage Foreclosure with reference to the above captioned matter. ~~ FRANK FEDERMAN, ESQUIRE Attorney for Plaintiff Date: May 23, 2001 ;-'~~"" ,__(." 0 _ ~ ~ . ! -) "", "'- r:-' . _.,C..,..". ",., '" ._~ "L'< ~~.=.. !/Ib\~ .- "~.', ,- "''''.L'>!, C" ~"-'""'"""~"-';"._,,,~-,,,,, 'C"<0-,-,',"",_-q~L,_- -. -"j--~-~~'mrlItll-~'iLr[{(r~t:r' o ~ -0;:' , rnr.--' z~' ::~:c: S~ ~.~;_ ~(,-' .:r~. "..i ::~? r~,,) (T. --::; . , -;';' ._1 --_.~ \ ."):::. \ ,-J -'-.''''''_,"" .__"r'T'~ -",-,. ,~-'J'""~1""~\r"i~"";"~"'l:t'!!nl~~.'f'_"''"'_'"'''''~ - -~~iIII!I1PII'!IjI!." .,i;!)ic FEDERMAN AND PHELAN BY: FRANK FEDERMAN, ESQUIRE Identification No. 12248 One Penn Center at Suburban Station 1617 John F. Kennedy Boulevard Suite 1400 Philadelphia, PA 19103-1814 (7 1 ~) ~Ii1- 7000 Attorney for Plaintiff FIRST HORIZON HOME LOAN CORPORATION, F/KJA FT MORTGAGE COMPANIES, D/B/A MNC MORTGAGE : COURT OF COMMON PLEAS : CNILDMSION Plaintiff vs. : CUMBERLAND COUNTY VICKI BOUDMAN C. BLAINE BOUDMAN : NO. 01-251 Defendant( s) AFFIDAVIT OF SERVICE OF COMPLAINT RV MATI. PITRSTJANT TO C.OITRT ORnF.R I hereby certify that a true and correct copy of the Civil Action Complaint in Mortgage Foreclosure in the above captioned matter was sent by regular and certified mail, return receipt requested, to the following persons, to VICKI BOUDMAN at 26 WEST EPPLEY DRIVE, CARLISLE, PA 17013 and 400 JADE CIRCLE, JENSEN BEACH, FL 34957 AND C. BLAINE BOUDMAN at 26 WEST EPPLEY DRIVE, CARLISLE, P A 17013 on May JO, 2ll.Ill, in accordance with the Order of Court dated MAY 14,2001. The undersigned understands that this statement is made subject to the penalties of 18 Pa. C.S. g4904 relating to unsworn falsification to authorities. Date: May 10,7001 ~~ FRANK FEDERMAN, ESQUIRE Attorney for Plaintiff if:~. ~ -~, -~~ " "1-", "~ rr'tflTl\fll'lII!m_~ __".;Il,"~l!!I;!'l!~ ,.~M >,~ " 't"'"-~'"'"_~.~ ~_,__,~=,~~_ ,',,"" .,.-_ """ _ IIIIiIIJ~r 'j . Jr" Q 0 0 -o~ " t.- ....; 1m c: ;}~,; :z: .~ I ~~f;'; .1'"" :';:JC;:' a~ ;:::0 '-4. C" -0 -,.~ -ri ~o :Jl: t:i ,.~ '" (') :J>f? z " ra a" ~ CJ'l ~ -< ""~" _.~~'i!:!m>~IW~"'"]:fI'~"'''IW'''!~''1!r1{''''W''B~;:<i%~-,>e,I~"1f:l'ffil~"W~R~Q~~,' FEDERMAN AND PHELAN By: FRANKFEDERMAN Identification No. 12248 One Penn Center at Suburban Station Suite 1400 Philadelphia,Pp. 19103-1814 (215) 563-7000 ~THO~ONHOMELOAN CORPORATON, FIKIA Ff MORTGAGE COMPANIES, D/B/A MNC MORTGAGE 4000 HO~ON WAY IRVING, TX 75063 Attorney for Plaintiff : CUMBERLAND COUNTY : COURT OF COMMON PLEAS : CIVIL DMSION Plaintiff : NO. 01-251-CIVIL vs. VICKI BOUDMAN C. BLAINE BOUDMAN 26 WEST EPPLEY DRIVE CARLISLE, PA 17013 Defendant(s) PRAECIPE FOR JUDGMENT FOR FAILURE TO ANSWER AND ASSESSMENT OF DAMAGES TO THE PROTHONOTARY: Kindly enter judgment, in rem. in favor of the Plaintiff and against VICKI BOUDMAN and C. BLAINE BOUDMAN, Defendant(s), for failure to file an Answer to Plaintiff's Complaint within 20 days from service thereof and for foreclosure and sale of the mortgaged premises, and assess Plaintiff's damages as follows: As set forth in Complaint Interest 12/1/00 TO 7/6/01 $178,059.74 $6.993.44 TOTAL $185,053.18 I hereby certifY that (I) the addresses of the Plaintiff and Defendant(s) are as shown above, and (2) notice has been given in accordance with Rule 237.1, copy attached. \4J1.MtI(.::{ QJiQ(f1lU) FRANK FEDERMAN, ESQUIRE Attorney for Plaintiff DAMAGES ARE HEREBY ASSESSED AS INDICATED. DATE: ~ ~ ,..)6V/ /$/ ~ /- X% PRO PRO /€L- **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 AND THIS DEBT WAS NOT REAFFIRMED, THIS CORRESPONDENCE IS NOT AND SHOULD NOT BE CONSTRUED TO BE AN ATTEMPr TO COLLECT A DEBT, BUT ONLY ENFORCEMENT OF A UEN AGAINST PROPERTY. ** ::fW1~ , I' ~~-~~~~~.,-" .. <~_~_1OI FEDERMAN AND PHELAN BY: Michele M. Bradford, Esq. Atty. LD. #69849 1617 John F.Kennedy Boulevard Suite 1400 Philadelphia, PA 19103-1814 ~? 1~) ~()"'-7000 ATTORNEY FOR PLc\.INTIH, AY 11 Z001 FIRST HORIZON HOME LOAN COIU'ORATION, FIK/A FT MORTGAGE COMPANIES, D/B/A MNC MORTGAGE COURT OF COMMON PLEAS CIVIL DIVISION vs. CUlv1BERLAND COUNTY VICKI BOUDMAN C. BLAiNE BOUDMAN NO. 01-251 AND NOW, this /fl-h , 200 I, upon consideration of day of Plaintiffs Motion for Service Pursuant to Special fCourt and the Affidavit of Reasonable Invc,~;~minn attached thereto, it is hereby ORDERED that Plaintiff may obtain service of the Comi'~'lil1t on the above captioned Defendant(s) VICKI BOUDMAN and C. BLAINE BOUDMAN, by mailing a true and correct copy of the Complaint by certified mail and regular mail to the Defendant's last known address, and to the mortgaged premises located at 26 WEST EPl'l.EY DRIVE, CARUSL~,pA 17013. Service of the aforementioned mailings is effective upon the date of mailing and is to be done by Plaintiff's attorney, who will file with the Prothonotary's Office an Affidavit as to the mailing. ," - . - , BY THE COURT: r/0d2AJ 15. 4ij H:JM<1in Formsfmotions/county.comp FEDERMAN AND PHELAN BY: FRANK FEDERMAN, ESQUIRE Identification No. 12248 One Penn Center at Suburban Station 1617 JohnF. Kennedy Boulevard Suite 1400 Philadelphia, PA 19103-1814 (7 1 ~) <;li1- 7000 Attorney for Plaintiff Plaintiff o 0 ~ <- COURT OF COMMON PL~~ ! ~~ -0 ~8 :x :l> c: ~ ~ CIVIL DMSION o "Tl ._i :r:~ r"'l'''''.~ .-;;rn 6.9. ;::19 -.--ti Qi',) orn ~ c.n '< FIRST HORIZON HOME LOAN CORPORATION, F/KJA FT MORTGAGE COMPANIES, D/B/A MNC MORTGAGE vs. 'I CUMBERLAND COUNTY VICKl BOUDMAN C. BLAINE BOUDMAN : NO. 01-2FEDERMANAND~iEI..AN _._ ,< ATTORNEY FJ ' l~~~ORINE:F1L[COpt PLEASE R~lt ry PLEASE RETURN M'FIDA VIT OF SERVICE OF COMPLAINT RV MATI. PTlRSlJ A NT TO COTlRT OR.~ . ,,.rJia~"^1 L ',."'"'>0- l!1{fft9i.' --, (It JillJRfU1 c ,'1,1. I hereby certify that a true and correct copy of the Civil Actiop. ~11'!!f~WlJ~~~f~ge' ^ - Foreclosure in the above captioned matter was sent by regular and certified mail, refutrtreceipt Defendant( s) requested, to the following persons, to VICKI BOUDMAN at 26 WEST EPPLEY DRIVE, CARLISLE, P A 17013 and 400 JADE CIRCLE, JENSEN BEACH, FL 34957 AND C. BLAINE BOUDMAN at 26 WEST EPPLEY DRIVE, CARLISLE, PA 17013 on MlIY 10, 2111ll, in accordance with the Order of Court dated MAY 14,2001. Tm: undersigned understands ":-',~~E~~7/~7;i,-: ~ ~ ' that this statement is made subject to the penalties of 18 Pa. C.S. !l4904i~~~lP?~t~.unswom.,,\, r. ,ft __,,\,"&Q,~'.'j ''\1 i~"t,"k~.,~j-\N - :;'CL:j~~{:;(_,~"I-",_!:1" I'" \, "j J falsification to authdfr~.-i.k.lf:'C-..; !i~i.f\\~', ..c; .'._. '..'.'.;.\\1\1 <,,,;:,0;!.2;:' Fi/- ., <I 1\.rrORNEY !~il_l. L";' ~ -'. t,',:t,::"" "nli'''iI\('''!'JIf',r::-,iJ''''(-,Jfl'\\ r:'J. ' ~ rt ..~":-' I ,; ,'I"~ j IL ~ ~ l"ltl G' r,....,:.,,~.~<.J.:-. (:,~. '. Date: May 10. 7001 FRANK FEDERMAN, ESQUIRE Attorney for Plaintiff . "'W"~l1fl o __, _ '_ _ ~ I',! -, I" I r ~~ , ~,~.,.,...,_. ~'.~l~lf,IT~", . FEDERMAN AND PHELAN, L.L.P. Frank Federman, Esquire Identification No. 12248 One Penn Center Plaza at Suburban Station, Suite 1400 Philadelphia, PA 19103-1799 (215) 563-7000 ATTORNEY FOR PLAINTIFF COURT OF COMMON PLEAS FIRST HORIZON HOME LOAN CORPORATION, F/K/A FT MORTGAGE COMPANIES, D/B/A MNC MORTGAGE CIVIL DIVISION CUMBERLAND COUNTY vs. VICKI BOUDMAN C. BLAINE BOUDMAN NO. 01-251 Defendant(s) TO: VICKI BOUDMAN 26 WEST EPPLEY DRIVE CARLISLE,PA17013 DATE OF NOTICE: JUNE 21.2001 THIS FIRM IS A DEBT COLLECTOR ATTEMPTING TO COLLECT A DEBT. THIS NOTICE IS SENT TO YOU IN AN ATTEMPT TO COLLECT THE INDEBTEDNESS REFERRED TO HEREIN, AND ANY INFORMATION OBTAINED FROM YOU WILL BE USED FOR THAT PURPOSE. IF YOU HAVE PREVIOUSLY RECEIVED A DISCHARGE IN BANKRUPTCY, THIS CORRESPONDENCE IS NOT AND SHOULD NOT BE CONSTRUED TO BE AN ATTEMPT TO COLLECT A DEBT, BUT ONLY AS ENFORCEMENT OF LIEN AGAINST PROPERTY. IMPORTANT NOTICE You are in default because you have failed 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 CUMBERLAND COUNTY BAR ASSOCIATION 2 LIBERTY AVENUE CARLISLE, PA 17013 (717) 249-3166 Frank Federman, Esquire Attorney for Plaintiff , ., IY -, ~ FEDERMAN AND PHELAN, L.L.P. Frank Federman, Esquire Identification No. 12248 One Penn Center Plaza at Suburban Station, suite 1400 Philadelphia, PA 19103-1799 (215) 563-7000 ATTORNEY FOR PLAINTIFF FIRST HORIZON HOME LOAN CORPORATION, F/K/A FT MORTGAGE COMPANIES, D/B/A MNC MORTGAGE COURT OF COMMON PLEAS CIVIL DIVISION CUMBERLAND COUNTY vs. VICKI BOUDMAN C. BLAINE BOUDMAN NO. 01-251 Defendant(s) TO: VICKI BOUDMAN 400 JADE CIRCLE JENSEN BEACH, FL 34957 DATE OF NOTICE: JUNE 21.2001 THIS FIRM IS A DEBT COLLECTOR ATTEMPTING TO COLLECT A DEBT. THIS NOTICE IS SENT TO YOU IN AN ATTEMPT TO COLLECT THE INDEBTEDNESS REFERRED TO HEREIN, AND ANY INFORMATION OBTAINED FROM YOU WILL BE USED FOR THAT PURPOSE. IF YOU HAVE PREVIOUSLY RECEIVED A DISCHARGE IN BANKRUPTCY, THIS CORRESPONDENCE IS NOT AND SHOULD NOT BE CONSTRUED TO BE AN ATTEMPT TO COLLECT A DEBT, BUT ONLY AS ENFORCEMENT OF LIEN AGAINST PROPERTY. IMPORTANT NOTICE You are in default because you have failed 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 CUMBERLAND COUNTY BAR ASSOCIATION 2 LIBERTY AVENUE CARLISLE, PA 17013 (71 7) 249-3 I 66 Frank Federman, Esquire Attorney for Plaintiff ~,~~ ,'''' , ~ - 1"! I., -,-_., FEDERMAN AND PHELAN Frank Federman, Esquire Identification No. 12248 One Penn Center Plaza at Suburban Station, Suite 1400 Philadelphia, PA 19103-1799 (215) 563-7000 ATTORNEY FOR PLAINTIFF FIRST HORIZON HOME LOAN CORPORATION, F/K/A FT MORTGAGE, COMPANIES, D/B/A MNC MORTGAGE COURT OF COMMON PLEAS CIVIL DIVISION plaintiff CUMBERLAND COUNTY vs. :NO.01-251 VICKI BOUDMAN C. BLAINE BOUDMAN Defendant TO: C. BLAINE BOUDMAN 26 WEST EPPLEY DRIVE CARLISLE,PA17013 DATE OF NOTICE: JUNE 21.2001 THIS FIRM IS A DEBT COLLECTOR ATTEMPTING TO COLLECT A DEBT. THIS NOTICE IS SENT TO YOU IN AN ATTEMPT TO COLLECT THE INDEBTEDNESS REFERRED TO HEREIN, AND ANY INFORMATION OBTAINED FROM YOU WILL BE USED FOR THAT PURPOSE. IF YOU HAVE PREVIOUSLY RECEIVED A DISCHARGE IN BANKRUPTCY, THIS CORRESPONDENCE IS NOT AND SHOULD NOT BE CONSTRUED TO BE AN ATTEMPT TO COLLECT A DEBT, BUT ONLY AS ENFORCEMENT OF LIEN AGAINST PROPERTY. IMPORTANT NOTICE You are in default because you have failed 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 CUMBERLAND COUNTY BAR ASSOCIATION 2 LIBERTY AVENUE CARLISLE, PA 17013 (717) 249-3166 Frank Federman,Esquire Attorney for Plaintiff :$. 'j; - ~" FEDERMAN and PHELAN By: FRANK. FEDERMAN Identification No. 12248 OooPennC~teratSMurbmStatioo Suite 1400 Philadelphia,pJ\ 19103-1814 (215) 563-7000 Attorney for Plaintiff FIRST HORIZON HOME LOAN CORPORATON, FIKIA Ff MORTGAGE COMPANIES, D/B/A MNC MORTGAGE : CUMBERLAND COUNTY : Court of Common Pleas : CML DMSION Plaintiff : NO. 01-251- CML vs. VICKI BOUDMAN C. BLAINE BOUDMAN Defendant(s) VERIFICATION OF NON-MILITARY SERVICE FRANK FEDERMAN, 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 defendant(s) 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 VICKI BOUDMAN is over 18 years of age and, HER WHERE ABOUTS ARE UNKNOWN. c) that defendant C. BLAINE BOUDMAN is over 18 years of age and, HIS WHEREABOUTS ARE UNKOWN. This statement is made subject to the penalties of 18 Pa. C.S. Section 404 relating to the unsworn falisificaton to authorities. ctAo.nK dJd i rrtJll{) FRANK FEDERMAN Attorney for Plaintiff ~~ "' . , "'~"'." (Rule of Civil Procedure No. 236 - Revised) ~THOmzONHOMELOAN CORPORATON, FIKIA Ff MORTGAGE COMPANIES, D/B/A MNC MORTGAGE : CUMBERLAND COUNTY : Court of Common Pleas : CIVIL DMSION Plaintiff : NO. 01-251- CIVIL vs. VICKI BOUDMAN C. BLAINE BOUDMAN Defendant(s) Notice is given that a Judgment in the above captioned matter has been entered against you on JULY ~ .2000. By DEPUTY If you have any questions concerning this matter, please contact: FRANK FEDERMAN. ESOUIRE Attorney for Filing Party One Penn Center at Suburban Station Suite 1400 Philadelphia,PJ\ 19103-1814 (215) 563-7000 "nQSFIRM 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 AND THIS DEBT WAS NOT REAFFIRMED, THIS IS NOT AND SHOULD NOT BE CONSTRUED TO BE AN ATTEMPT TO COLLECT A DEBT, BUT ONLY ENFORCEMENT OF A LIEN AGAINST PROPERTY. " 0'.'11$1': .-,.' I T -~ ~~~ ~.- ~ ,~~ Iil '\ ",. ,'" :-'"' ,. -=,. mrill1nr ~ ~, ~ ~ ~ Ci c.: \ ~ ~ -r~ r. -' ....,. , L;:_~ .~~._ - ~' ....... -t:. ~ ~ /. \.. \~1 ~ en " ~ t~-:i.=-- .-1:-: ~ .::::: c: "c__' )> .. ., "- --" oJ -', -< QJ. ,~" __'~:_ ....~:'~"'~ _ ~'~~!f~~1'Ji''llO<~~ ,--_~'",~II!MIII"r !~_ ",~lw.c'lj'-''ff;;''';:,'',"y~;>n:-:'''!'~''';'Y'''-'';'!-_~lffiWI!l~Ri'~;il:t'''';<~f,~_Wk~'fEr:w~il:1~~ffi!!l_~" '~: .'1"- ~ .- ,f " PRAECIPE FOR WRIT OF EXECUTION - (MORTGAGE FORECLOSURE) P.R.C.P.3180-3183 FIRST HORIZON HOME LOAN CORPORATION, FOOA FT MORTGAGE COMPANIES, D/B/A MNC MORTGAGE CUMBERLAND COUNTY No.01-251-CIVIL Plaintiff, v. VICKI BOUDMAN C. BLAINE BOUDMAN Defendant( s). TO THE DIRECTOR OF THE OFFICE OF THE PROTHONOTARY: Issue writ of execution in the above matter: Amount Due $185,053.18 Interest from 7/6/01 to 12/5/01 (per diem - $30.42) $4,623.79 and Costs TOTAL $189,676.97 Note: Please attach description of property.No. i::r'lll'__,~' ~ "~ " , ~ , " - ^ ,,- ~ -- '". ----:r", , '.,' $ ,- '-", '^ "d"Y. ~",'~-"" -'->~(.llfftLir ~,;.--,-;,- :'"-__Y-~":]rL_'___- _~"_' Trrilr~j f"rw:,~.'-"1trt:'-1 . " ~ ..., ... 0 to- ... < ~ r4' ...l m ... ....::1 Z ~ OZ i'lli'll m< ~~ 0 U <> ~ ... ~ ~~~ E-< I'll...l ::g ~ -d ...l>< U ;: ~m 0!2!2 l:l " ZZ ...l00 ~~ ~'F l:l ~ OZ I'll::g::g I'll = >< OJ ::g~ .... ~ I'll " 6t:u 0<:: ...l .n ::g . l:ll'll ~ ~ O~ =<~ '" ~Z E-< .. ~ S uz Z~< .; 0< ;:~ OJ ....~ .. ~...l ... Of,,;;;- ~~ " 00 ~ . ee t;;!~ ~~ g. E-<U Zl:l uU Q, ~l:l 00 . 01:: " ~~ =...m > .... c '" ~ E-<I'll I'll 6 N ~ 8~ E-<~~ ~ ... i'lli'll ~o~ U =~ s~ ~ .;,; E-<::g " 00 ~ .~ z~ UU ~ .... ...u ~ ~, " ...""..".,..t.~I!ii~'I " .-"..,,~ _~lll~"n _lU~ ~__l!Rlli~~~IT"'(;""';;"M"""'-"-f1-",<",!,~,,",;y,.'>-J!"'W'l'f'~,rel!i1~~i'll'nl!ffiW!!(,!j"-"i'i"!fiil'f"fl;:nf_'I!1iffl'..;"~'''l~~~-' ~~"'" <-, ,~ y " '. .. ALL THAT CERTAIN tract of land situate in South Middletown Township, Cumberland County, Pennsylvania, bounded and described in accordance with a survey prepared by John K. Boxler, III, R.S., dated 2/29/96 and recorded in the Office of rhe Recorder of Deed~ for Cumberland County in Plan Book 72 page liS, revised 4110/96. as follows: BEGINNING at an iron pin on the northern right of way line of West Eppley Drive at a corner of Lot 35, Section 2-A, on the plan of Forgedaie Crossing; thence along Lot 35, North 03 degrees 17 minutes and 08 seconds West, a distance of 1.50.00 feet to an iron pin: thence along Lot 30-A, Phase I, North 86 degrees 42 minutes and .5::: seconds East, distance of 100.00 feet to an iron pin; thence along Lot 33, Section 2-A, South 03 le:;rees 17 minutes and 08 second~ East, a distance of 151.02 feet to an iron pin on the northern right of way line of West Eppley Drive'; thence along said northern right of way line of West Eppley Dri'le, by a curve to the left having.a radius of 495,00 feet and arc distance of 31.85 feet to a point in .the right of way line; thence continuing along the northern right of way line of West Eppley Drive, South 86 degrees 42 minutes and 52 seconds West, a distance Of 68.18 feet to an iron pin ar Lor 35, Section 2~A, the placeof BEGINNING~ CONTAINING 15,000.00 Square feet and jesignated as Lot 34, Section 2-A of Plan of Forgedale Crossing. Tax Parcel #40-10-0636-309 TITLE TO SAID PREMISES IS VESTED IN C. Blaine Boudman and Vicki Boudman. husband and wife by Deed from S & A. Custom Built Homes, Inc., a PA Corp., dated 12/lI/97. recorded 12116/97, in Deed Book 169, Page 429. ~:~""._- - ,~-""",,' , j -t ~ --~ ~ . ~ , I I ~ ~ .,"=~,~ ~ "I ~>~>' .~~ .. .. .... .."""iilil,(tl'WuJmr'fj tit' 1'"'11' . ,"'n' """'''.0' '-'-'-'-"<___,"'j'_'""_7_'''_'","'__~ 'O"(:"'!iiil:'.r' _ : ____ . .. P -4l ~ ~ 4 t> Cv -.... ~ ~ 0 0 0 ?d - f' lJ" f' ~ c: " } C, $:: "" -"1 It \) ~ 0 C\ B V? 8 "Om Pl ;~; ,'1 0 .... mrn v C 0 0 Z:r ' I ,;:::;;~ C f' zr" :';~ J I I cn~ 0 "- ~ ~ I (! ~5 ..... ~ ~ ;K ::> . '.~ -l't :J>-) ::l.: ~(~ r' r , Zc ~ , , , "- ::- :i>f! 9? f::5m -. "' ~ ~ , ~~ );! -. ~ W ::0 , -. rv -< -. " "" " .~ , ~ ',< ~"~""~m"[!!fu;";mN'!i"3'f';""'.fJ"^"t"n'?,1>m:;,'H,,l!""I!iIiiill'$~~" ~"I!lIQIflIIN'~ ""'...". _ ~~~~.~._.. , _"_"W,~ ,il!111rl@.i;;l~i!Ii!ilRMIi!l1 ^.~",.","... . FEDERMAN AND PHELAN BY: Michele M. Bradford, Esq. Atty. 1.0. #69849 1617 John F. Kennedy Boulevard Suite 1400 Philadelphia, P A 191 03-18l4 (71 'i) 'ih,-7000 ATTORNEY FOR PLAINTIFl4AY 1 1 ZOO) FIRST HORIZON HOME LOAN CORPORATION. F!KJA FT MOR: ',AGE COMPANIES. DIB!:\ :,INC MORTGAGE COURT OF COMMON PLEAS CIVIL DIVISION vs. CUMBERLAL"\ID COUNTY VICKI BOUDMAN C. Df.\f1\E BOUDtvlAN NO. 01-251 AND NOW, this /1f-h , 200 I, upon consideration of day of Plaintiffs Motion for Service Pursuant to Special fCourt and the Affidavit of Reasonable InY(" '::;:li;')!l attached thereto. it is hereby ORDERED that Plaintiff may obtain service of the Com;'::lint on the above captioned Defendant(s) VICKI BOUDMAN and C. BLAINE BOUDMAN, by mailing a true and correct copy of the Complaint by certified mail and regular mail to the Defendant's last known address, and to the mortgaged premises located at 26 WEST EPI'I.EY ORIVE, CARLISLE, PA 17013. Service of the aforementioned mailings is effective upon the date of mailing and is to be done bv Plaintiffs attorney, who will file with the Prothonotary's Office an Affidavit as to the mailing., BY THE COURT: ;s/~AL f5 411' I , I I H:IM..irl Forrnslmotionslcounty.comp 'n_~ , ~ - ,~- I I I ,I j :J i i ., I I I I j ~"~llilI"I!I~''''''''' FEDE~ANandPHELAN By: FRANK FEDE~AN Identification No. 12248 Suite 1400 One Penn Center at Suburban Station Philadelphia, PA 19103 (215) 563-7000 ATTORNEY FOR PLAINTIFF FIRST HORIZON HOME LOAN CORPORATION, F/K1A FT MORTGAGE COMPANIES, D/B/A MNC MORTGAGE CUMBERLAND COUNTY COURT OF COMMON PLEAS Plaintiff, CML DIVISION v. NO.01-25I-ClVIL VICKI BOUDMAN C. BLAINE BOUDMAN Defendant(s). CERTIFICATION FRANK FEDERMAN, ESQUIRE, hereby verifies that he is 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 9 I procedures have been fulfilled This certification is made subject to the penalties of 18 Pa. C.S. Section 4904 relating to unsworn falsification to authorities. , . . :ii , -<;-- , A' _', <<_. ~~_ ,~, v__ ~ "-'~'[.'",;;",?f-_~ '-"\ "'.1mriifll!llUlNl r '""'"'Iif (") 0 () C -n ;s: (/) "'O:;i ('T1 ~m -U :JJ ::D , zr- ~'38 ~~: 0 :;_~; (:1 ~o "'" -,.-' '-r, )>0 ::>: ~~(~ 2:0 5>c OJ CSI'Tl ~ ._~ :..:> )> :::0 N -< ~.~",_~I~U!lll~\I~t~lllll ,.__ ~~ . ~ "~-I':ll?~,IIi!IJIIiIII~n~~~41. '!'(~l'C-{1i'll3~W~W;~lmf-l'ff!fflm"""'f""_f<$:~~~~\"~_7''''''''~~~1II!!IIIIIUI ';,' j ....._~ ~- \ i' 11 I: I' 11 Il Ii 'I : ~ !" i' ji i., I:! j:' I;' 1-: !j: , i _~ ,~... ' FIRST HORIZON HOME LOAN CORPORATION, FfKlA FT MORTGAGE COMPANIES, D/B/A MNC MORTGAGE CUMBERLAND COUNTY COURT OF COMMON PLEAS Plaintiff, v. CIVIL DMSION VICKI BOUDMAN C. BLAINE BOUDMAN NO.01-251-CIVIL Defendant(s). AFFIDAVIT PURSUANT TO RULE 3129 (Affidavit No. I) FIRST HORIZON HOME LOAN CORPORATION, F/KJA FT MORTGAGE COMPANIES, D/B/A MNC MORTGAGE, Plaintiffin the above action, by its attorney, FRANK FEDERMAN, ESQUIRE, sets forth as ofthe date the Praecipe for the Writ of Execution was filed the following information concerning the real property located at 26 WEST EPPLEY DRIVE, CARLISLE. P A 17013 1. Name and address ofOwner(s) or reputed Owner(s): NAME LAST KNOWN ADDRESS (If address cannot be reasonably ascertained, please so indicate.) VICKI BOUDMAN 26 WEST EPPLEY DRIVE CARLISLE, P A 17013 C. BLAINE BOUDMAN 26 WEST EPPLEY DRIVE CARLISLE, PA 17013 2. Name and address ofDefendant(s) in the judgment: NAME LAST KNOWN 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 LAST KNOWN ADDRESS (If address cannot be reasonably ascertained, please so indicate.) None . . . ~, .nr ~" '" '" ~ - . .. ~ ~ ... 4. Name and address of the last recorded holder of every mortgage of record: NAME LAST KNOWN ADDRESS (If address cannot be reasonably ascertained, please so indicate.) None 5. Name and address of every other person who has any record lien on the property: NAME LAST KNOWN ADDRESS (If address cannot be reasonably ascertained, please so indicate.) None 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 LAST KNOWN ADDRESS (If address cannot be reasonably ascertained, please so indicate.) None 7. Name and address of every other person whom the plaintiff has knowledge who has any interest in the property, which may be affected by the sale: NAME LAST KNOWN ADDRESS (If address cannot be reasonably ascertained, please so indicate.) Tenant/Occupant 26 WEST EPPLEY DRIVE CARLISLE, P A 17013 Domestic Relations of Cumberland County 13 North Hanover Street Carlisle, P A 17013 Commonwealth of Pennsylvania Department of Welfare PO Box 2675 Harrisburg, PA 17105 , -I' I verify that the statements madi!l<1ll this affidavit are true and correct to the best of my personal knowledge or information and belieii' understand that false statements herein are made subject to the penalties ofl8 Pa. C.S. Sec. 4904 relating to unsworn falsification to authorities. August 2. 2001 DATE iJ.... ~ _ ~~ 'V,. _ y" I" ~ ill r" ~" ,~ . _.-.~, !l'lW ,!<:oIll~ ~'I~ ~"""~,,,.t. _, ~;~,_<," ,~-";~<"":i'S:t";;HiH""'1~W;i._ti"f-"''''?I'ffiP;~~~~~~Wl'il!i'JF.fJ'lIlJ!Hi't.;g.[J ;,~'-_ ~ - ~ 'C'_;,,__,' l' ~'C--"" ""-'\.5-",.,-"~" ';", "."J< ',o,,'~-,.~,,~'l& '"[[[tUft "C-'::.'r''f',"-l-'-^~~'Irj'' ,,. ''''. 0 0 0 S;;;; -,-, -os.. tr) ::;:} mF!'i /'T1 Z:tJ -0 ,";", '1'1 ZC :~f:;:j C,lJ-<;:..': 0 . ,_~CJ ~L:~ ,<"",,1 :.::0 "'" '::::iC) Po ~~- -r, 2:0 :::r.-: ~]~~ )>c: 9? Om ~ W j:! N :0 -< FIRST HORIZON HOME LOAN CORPORATION, FiKlA FT MORTGAGE COMPANIES, D/B/A MNC MORTGAGE CUMBERLAND COUNTY No.01-251-CIVIL Plaintiff, v. VICKI BOUDMAN C. BLAINE BOUDMAN Defendant(s). August 29, 2001 TO: VICKI BOUDMAN 26 WEST EPPLEY DRIVE CARLISLE, PA 17013 C. BLAINE BOUDMAN 26 WEST EPPLEY DRIVE CARLISLE, PA i7013 "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 AND THIS DEBT WAS NOT REAFFIRMED, 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 26 WEST EPPLEY DRIVE, CARLISLE, PA 17013is scheduled to be sold at the Sheriffs Sale on DECEMBER 5, 2001 at 10:00 a.m. in the Cumberland County Courthouse, South Hanover Street, Carlisle, PA 17013, to enforce the court judgment obtained by FIRST HORIZON HOME LOAN CORPORATION. F/KJA FT MORTGAGE COMPANIES. D/B/A MNC MORTGAGE (the mortgagee) against you. If the Sheriffs sale is postponed, the property will be relisted for the MARCH 6, 2002 Sheriffs Sale. 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 the mortgagee the back payments, late charges, costs and reasonable attorney's fees due. To find out how much you must pay, you may call: (215) 563-7000. 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 ,.! 'i:.rm_-, "I , ~ , ~ I 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 Sheriffs Sale is not stopped, your property will be sold to the highest bidder. You may find out the price bid by calling (215) 563-7000. 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 (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 that time, the buyer may bring legal proceedings to evict you. 6. You may be entitled to a share of the money which was paid for your house. A schedule of distribution of the money bid for your house will be filed by the Sheriff 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 distribution is filed. 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 ATTORNEY REFERRAL CUMBERLAND COUNTY BAR ASSOCIATION 2 LIBERTY AVENUE CUMBERLAND COUNTY COURTHOUSE CARLISLE, P A 17013 (717) 249-3166 (800) 990-9108 """'F~'''''*'~ , , it ALL THAT CERTAIN tract of land situate in South Middletown Township, Cumberland County, Pennsylvania, bounded and described in accordance with a survey prepared by John K. Bolder, III, R.S., dated 2/29/96 and recorded in the Offlce of the Recorder of Deeds for Cumberland County in Plan Book 72 page 115, revised 4/10/96, as follows: . . BEGINNING at an iron pin on the northern right of way line of West Eppley Drive at a corner of Lot 35, Section 2-A, on the plan of Forgedale Crossing: thence along Lot 35, North 03 degrees 17 minutes and 08 seconds West, a distance or 150.00 feet to an iron pin: thence along Lot 30-A, Phase I, North 86 degrees 42 minutes and 5: seconds E:lst, distance or 100.00 feet to an iron pin; thence along Lot 33, Section 2-A, South 0:: iegrees 17 minutes and 08 seconds East, a distance of 151.02 feet to an iron pin on the northern r:ght of W:lY line of West Eppley Drive; thence along said northern right of way line of West Eppley [Ii'!e, by a curve to the left having a radius of 495.00 feet and arc distance of 31.85 feet to a point in the right of way line; thence continuing along the northern right of way line of West Eppley 1:'r:ve, South 86 degrees 42 minutes and 52 seconds West, a distance of 68.18 feet to an iron pin at Lot 35, Section 2-A, the place of BEGINNING. CONTAINING 15,000.00 Square feet and Jesignated as Lot 34, Section 2-A of Plan of Forgedale Crossing. Tax Parcel #40-10-0636-309 TITLE TO SAID PREMISES IS VESTED IN C. Blaine Boudman and Vicki Boudman. husbanc and wife by Deed from S & A. Custom Built Homes, Inc., aPA Corp., dated 12/11/97. recorded 12/16/97, in Deed Book 169, Page 429. .~'I'l~- _ , , ~ ~ ~ .~ ~ -=~" ~~~, . ,.~^ ~ "> .~ ~- , '"~'IilLlll:' , t e 0 C) -,1 $: (/) .~-, ""OCt:' ,., ~i:@ [flrp "V Z_.C ~c a ~ ~:~:. ~_~'::'(:i '-0 ~ ;:0. , '" ZO :x L);;:J :i>2 '!? ~~t~ ~) -, ~ ,-,) 5 N -< !IIlIriIln!~~""J'!!!fP';1~i;~-"V'""!F!;"f1I"1!ThW-f.l'i\l,!,,"';:;~IU~~~~-'"I~l!lIlfllf.__< 'lI'I!"'~ , I , , SALE DATE: DECEMBER 5.2001 IN THE COURT OF COMMON PLEAS OF CUMBERLAND COUNTY, PENNSYLVANIA CIVIL ACTION - LAW FmSTHO~ONHOMELOAN CORPORATION, F/KIA FT MORTGAGE COMP ANlES, D/B/A MNC MORTGAGE No.: 01-2Sl-CIVIL vs. VICKI BOUDMAN C. BLAINE BOUDMAN AFFIDAVIT PURSUANT TO RULE 3129.1 AND RETURN OF SERVICE PURSUANT TO Pa. R.C.P. 405 OF NOTICE OF SALE Plaintiff in the above action sets forth as of the date the Praecipe for the Writ of Execution was filed the following information concerning the real property located at: 26 WEST EPPLEY DRIVE. CARLISLE. P A 17013. As required byPa. R.C.P. 3l29.2(a) Notice of Sale has been given in the manner required by Pa. R.C.P. 3l29.2(c) on each of the persons or parties named, at that address set forth on the attached Affidavit No.2 (previously filed) and Supplemental Affidavit No.2 on the date indicated, and a copy of the notice is attached as an Exhibit. A copy of the Certificate of Mailing (Form 3817) and/or Certified Mail Return Receipt stamped by the U.S. Postal Service is attached for each notice. November 30,2001 ;'ip,t__,. I,' ,. FIRST HORIZON HOME LOAN CORPORATION, FfKJA FT MORTGAGE COMPANIES, D/B/A MNC MORTGAGE CUMBERLAND COUNTY COURT OF COMMON PLEAS Plaintiff, v. CIVIL DIVISION VICKI BOUDMAN C. BLAINE BOUDMAN NO.OI-251-CIVIL Defendant(s). AFFIDAVIT PURSUANT TO RULE 3129 (Affidavit No.1) FIRST HORIZON HOME LOAN CORPORATION, F/KJA FT MORTGAGE COMPANIES, D/B/A MNC MORTGAGE, Plaintiff in the above action, by its attorney, FRANK FEDERMAN, ESQUIRE, sets forth as of the date the Praecipe for the Writ of Execution was filed the following infonnation concerning the real property located at 26 WEST EPPLEY DRIVE, CARLISLE, P A 17013 1. Name and address ofOwner(s) orreputed Owner(s): NAME LAST KNOWN ADDRESS (If address cannot be reasonably ascertained, please so indicate.) VICKI BOUDMAN 26 WEST EPPLEY DRIVE CARLISLE, P A 17013 C. BLAINE BOUDMAN 26 WEST EPPLEY DRIVE CARLISLE, P A 17013 2. Name and address ofDefendant(s) in the judgment: NAME LAST KNOWN 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 LAST KNOWN ADDRESS (If address cannot be reasonably ascertained, please so indicate.) None ~'W1W, " ,- ,~~ ~ .r , ., ~'"- . . Name and address of the last recorded holder of every mortgage of record: 'NAME LAST KNOWN ADDRESS (If address carmot be reasonably ascertained, please so indicate.) None Name and address of every other person who has any record lien on the property: NAME LAST KNOWN ADDRESS (If address carmot be reasonably ascertained, please so indicate.) None 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 LAST KNOWN ADDRESS (If address cannot be reasonably ascertained, please so indicate.) None Name and address of every other person whom the plaintiff has knowledge who has any interest in the property, which may be affected by the sale: NAME LAST KNOWN ADDRESS (If address cannot be reasonably ascertained, please so indicate.) Tenant/Occupant 26 WEST EPPLEY DRIVE CARLISLE, PA 17013 Domestic Relations of Cumberland County 13 North Hanover Street Carlisle, P A 17013 Commonwealth of Pennsylvania Department of Welfare PO Box 2675 Harrisburg, PA 17105 I verify that the statements made in this affidavit are true and correct to the best of my personal Jwledge or information and belief. I understand that false statements herein are made subject to the lalties oflS Pa. C.S. Sec. 4904 relating to unsworn falsification to authorities. gust 2. 200 I ,TE \(]1ffi~ ,.~~~ DATE: August 2,2001 TO: ALL PARTIES IN INTEREST AND CLAIMANTS NOTICE OF SHERIFF'S SALE OF REAL PROPERTY OWNER(S) VICKI BOUDMAN C. BLAINE BOUDMAN PROPERTY: 26 WEST EPPLEY DRIVE CARLISLE, PA 17013 Improvements: Residential Property CUMBERLAND COUNTY The above-captioned property is scheduled to be sold at the Sheriff's Sale on DECEMBER 5, 2001 at 10:00 a.m. in Cumberland Countv Courthouse. South Hanover Street. Carlisle. P A. Our records indicate that you may hold a mortgage or judgment on the property, which may be extinguished by the sale. You may wish to attend the sale to protect your interests. A schedule of Distribution will be filed by the Sheriff on a date specified by the Sheriff not later than 30 days after sale. Distribution will be made in accordance with the schedule unless exceptions are filed thereto within 10 days after the filing of the schedule. LH '.- . "1l-i CD"g. m~ z ,00 Cii'3 arC" 0.!Jl ~a '" '" ~ 0. !Jl U1llllll ~d @iif ~.~ 0.- 0> 3 -15 "1l~ ~Q. 0::9. ",'" fJ m ;tJ"1l '" 0 n "' ",- <,3 -.0> ~ "' "'- m~ 3"1l "9.'" o ~ "'- "'Z ",0> -3 '" sa. ~ '" ~ ... ~ '" ~ N ~ ~ co ..... 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""1"1: ^ - - ^. ,. <v ..., ."<'d"''''''''''''~'i "", ";f"I'Ji1Hi'lr:tr'nfllllllnnlli"irn' .tl,l"~i ~ . ,......,~.........."~.~~~ . . 0 c) C s', D 'TJ C'; ["-'1 rn r-;' c, Z -T' ;~ f-- I '"' D) }.-: we, ~ (' ~.!'1 P () -, ;i> 0 "" c:: ~;:..::) Z en >. ~.~ ::r:; -< (..) -< .1!!!~"'mI'!;lo\ll!',\!j!!I\1~>;$'i~'''~~~''''''''''= ~_.!!! .. ~~~!I!W~ 110; '''*.~ -"~. , FEDERMAN AND PHELAN By: FRANK FEDERMAN, ESQUIRE IDENTIFICATION NO. 12248 ONE PENN CENTER AT SUBURBAN STATION, SUITE 1400 PHILADELPHIA, PA 19103-1814 (71 ';) ';(;1-7000 FIRST HORIZON HOME LOAN CORPORATION, F/KJA FT MORTGAGE COMPANIES, D/B/A MNC MORTGAGE vs. VICKI BOUDMAN C. BLAINE BOUDMAN ATTORNEY FOR PLAINTIFF COURT OF COMMON PLEAS CIVIL DMSION CUMBERLAND COUNTY No.: 01-251-CNIL AFFIDAVIT I hereby certify that a true and correct copy of the Notice of Sheriff Sale in the above captioned matter was sent by regular mail and certified mail, return receipt requested, to VICKI BOUDMAN and C. BLAINE BOUDMAN on 09/10/01 at 26 WEST EPPLEY DRNE, CARLISLE, P A 17013, in accordance with the Order of Court dated 05/14/01. The undersigned understands that this statement is made subject to the penalties of 18 PA C.S. s 4904 relating to unsworn falsification to authorities. Date: Novemh"" 10 7001 . " ~ ~,~ 1- I F '.. , JlIi1i;i.; ". <I FEDERMAN AND PHELAN By: FRANK FEDERMAN, ESQUIRE IDENTIFICATION NO. 12248 ONE PENN CENTER AT SUBURBAN STATION, SUITE 1400 PHILADELPHIA, PA 19103-1814 (11 'i) 'i1i1-7000 ATTORNEY FOR PLAINTIFF COURT OF COMMON PLEAS CIVIL DMSION FmSTHO~ONHOMELOAN CORPORATION, FIK/A FT MORTGAGE COMPANIES, D/B/A MNC MORTGAGE CUMBERLAND COUNTY No.: 01-251-CIVIL V$. VICKI BOUDMAN C. BLAINE BOUDMAN ~"CC.'\l. ~ n. ".r.."'.'. C'~~'.' '.'.' '.'.':.= ;.Ic'-'il (C. '....... \.\1.. . .... ...11= """ ~, u U:~~ -[ J~ u ~: ((...7""(0 r==.."'~.f. L;u . "fV\\ , - ',- -/ .\~ 1;,1 ' .;3 ,~". . f. AFFIDAVIT I hereby certify that a true and correct copy of the Notice of Sheriff Sale in the above captioned matter was sent by regular mail and certified mail, return receipt requested, to VICKI BOUDMAN and C. BLAINE BOUDMAN on 09/10/01 at 26 WEST EPPLEY DRIVE, CARLISLE, PA 17013, in accordance with the Order of Court dated 05/14/01. The Wldersigned understands that this statement is made subject to the penalties of 18 P A C.S. s 4904 relating to unsworn falsification to authorities. Date: Nov",mh",r 10 1001 c.~~ - - . -" . ,-~ .' , FEDERMAN AND PHELAN BY: Michele M. Bradford, Esq. Atty. J.D, #69849 1617 John F. Kennedy Boulevard Suite 1400 Philadelphia, P A 19103-1814 171 ") "ri"i-70()() ATTORNEY FOR PLAINTIF~AY 1 1 iDOl FIRST HORIZON HOME LOAN CORl'ORATION. F/K!A FT MOR: 'JAGE COMPANIES, D!B/f\ :vlNC MORTGAGE COURT OF COMMON PLEAS CIVIL DIVISION vs. CUMBERLAJ'iD COUNTY VICKI BOUDMAN C. rr..\[i':E BOUDIYfAN NO, 01-251 AND NOW, this ;rf-h day of , 200 I, upon consideration of Plaintiffs Motion for Service Pursuant to Special f Court and the Affidavit of Reasonable Inw' ':'p:i\)l1 attached thereto. it is hereby ORDERED that Plaintiff may obtain service of the COl11::,int on the above captioned Defendant(s) VICKI BOUDMAN and C. BLAINE BOUDMAN, by mailing a true and correct copy of the Complaint by certified mail and regular mail to the Defendant's last known address, and to the mortgaged premises located at 26 WEST EPPlEY DRIVE, CARLISLE, PA 17013. Service of the aforementioned mailings is effective upon the date of mailing and is to be done l,v Plaintiff's attorney, who will file with the Prothonotary's Office an Affidavit as to the mailil1~.. 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'~. l -"--'~ .,.~;'-""-':" i ;> i f t f ~ ~ ,. I, i r "';j , :Q':!: ; tr' ~E t HY i~ i ~! ~ ~8 I' . - ..1.0 ,--ii l'l,2 :E ~~..~-.;;..~ "'~.Q. ... ,"'Ui___ ~- -'--.!! .~q;... Q). - '/t.'U -- '" Q).t: => ..a:. Q) .0 \1 I, I. 11 i: 1 I. I !. i \ I, ii " i ~ ~! if, '" m m o .... %~ ." ." ii '" '" I" r i- I, \ i. i i :', i~ 1; I 1. t ~ "Ill h ~i ~m :s ~ 8- ~:3 ~"5 _z ~8 l'l ~ .. '" 0; ~ '" => - - ~ as _:E a'tl' .- Q) <<1)= o~. Q) Q) 1:1:0 .' ..:'- ~', :,~:.. '.' ~. .",.. ,.~...; ;-:--"-;::.::.""'./;::->~. ~.,. .... . ..... -~' ~ .' .. ' :}~,; 2 .. " EDERMAN AND PHELAN BY: Michele M. Bradford. Esq. Atty. LD. #69849 1617 John F. Kennedy Boulevard Suite 1400 Philadelphia, PA 19103-1814 (71'" 'ih"1-7000 ATTORNEY FOR PLAINTIF,t4AY 1 1 (00) FIRST HORIZON HOME LOAN CORPORATION. FIKlA FT MOKl (,AGE COMP ANIES, DIBI,\ :VINC MORTGAGE COURT OF COMMON PLEAS CIVIL DIVISION vs. CUMBERLAl'\iD COuNTY VICKI BOUDMAN C. rf.\f:'E BOUDMAN NO. 01-251 A;-{D NOW, this N/-h day of , 2001, upon consideration of Plaintiffs Motion for Service Pursuant to Special f Court and the Affidavit of Reasonable Inve. '::;:1Ii,)[1 attached thereto. it is hereby ORDERED that Plaintiff may obtain service of the COl11~':li[1t on the above captioned Defendant(s) VICKI BOUDMAN and C. BLAINE BOUDMAN, by mailing a true and correct copy of the Complaint by certified mail and regular mail to the Defendant's last known address, and to the mortgaged premises located at 26 WEST EPl'l.EY DRIVE, CARLISLE, PA 17013. Service of the aforementioned mailings is effective upon the date of mailing and is to be done l'v Plaintiffs attorney, who will file with the Prothonotary's Office an Affidavit as to the mailil1g. BY THE COURT: JS/tJjL1Al!? 4/f -,,.-,.., '".. "" . , , .;.",~. . 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II) lL"G) - c.\!l.. o":t: IL 11):.1:: ~.c Cl) II: .0., i: -g~ t ~"". j! li:~ .. &" t, eli ~l'" . ~~i ~- 11 .~.% fl' J!!8 R ~ " i.: r i 1: \ i ! \~ 8 ~ .. tJ) ~ (l tJ) ::> j, = ]\! t ... as '%'! !I .2 := \t \ a.."'2 ~E I -- ,., 0";: 1 8;s ~~ I CD ... ~J f II: B ~~ \ d , .' . .~~:-:..:: .""~ :: ::,::::~-: ,..~;~ .,"'; .,' -'.,-~: '.', ..,-;....,.-:..: STATE OF PENNSYLVANIA, COUNTY OF CUMBERLAND } 55. Robert P Ziegler I, ______________________________________________________________________________Ilecorderol Deeds in and for said County and State do 'hereby cenify that the Sheriffs Deed in which ____________n__ Secretary if Veterans Affairs . -------------------------------------------------___________________________________ ~ thegranree the same having been sold to said grantee on the ______~~~______________________________________ day of Dec 01 ________________________________________ A. D., r _____, under and by virtue of a wriL_____________ 10th Execution . -------________________________________n_______lSSued on the ________________________________n___ Sept day of __________________________ A. D., Civil ------------------------------.., ----- ---- --- ----- -- ------- --------- --__ ____ ____ ___ Term, : . 251 First Horizon HOme Ln Corp fka FT Mtg Co dba MNC Mtg Number ______________, at the suit of ---------------------------_____________________u_____________ Vicki Boudman & C Blaine -----------------------____________against____________________________________________________ ~ 01 -----, out of the Court of Cornman Pleas of said County'as of 01 duly recorded in Sheriffs Deed Book No. ______~~~___, Page __________~~: 3 IN TESTIMONY WHEIlEOF, I have hereunto set my hand and seal of said office this ___!..t____ day of --____~_u______ A. D., :MJ 0 I ---!Y-\~--~-~+-ql;l-~ Reco er of Recorder of Deeds, Cumberland County, Cartisle, PA My Commissi<m hpires the filSl Monday 01 Jan. 2002 ~ .. ~ " ~I~ First Horizon Home Loan Corporation F/k/a FT Mortgage Companies, d/b/a MNC Mortgage VS Vicki Boudman and C. Blaine Boudman In The Court of Common Pleas of Cumberland County, Pennsylvania Writ No. 2001-251 Civil Term Gerald Worthington, Deputy Sheriff, who being duly sworn according to law, states that on Oct. 03, 2001 at 9:31 A.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 Vicki Boudman and C. Blaine Boudman, located at 26 West Eppley Dr., Carlisle, Pennsylvania, according to law. R. Thomas Kline, Sheriff, who being duly sworn according to law, states that he served the within Real Estate Writ, Notice and Description in the following manner: The Sheriff mailed a notice of the pendency of the action by Certified Mail, Return Receipt Requested, Restricted Delivery, Deliver to Addressee Only to one ofthe within named defendants, to wit, C. Blaine Boudman, to his last known address of 26 West Eppley Drive, Carlisle, PA 17013. This letter was mailed under the date of October 01, 2001. C. Blaine Boudman received the letter on October 05, 2001. Return receipt card was returned to the Cumberland County Sheriffs Office on October 09, 2001 signed by C. Blaine Boudman. R. Thomas Kline, Sheriff, who being duly sworn according to law, states that he served the within Real Estate Writ, Notice and Description in the following manner: The Sheriff mailed a notice of the pendency of the action by Certified Mail, Return Receipt Requested, Restricted Delivery, Deliver to Addressee Only to one of the within named defendants, to wit, Vicki Boudman, to her last known address of 26 West Eppley Drive, Carlisle, PA 17013. This letter was mailed under the date of October 01, 2001. The unopened letter was returned to the Cumberland County Sheriffs Office on October 22, 2001 with the reason checked "unclaimed." 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: C. Blaine Boudman by regular mail to his last known address of 26 West Eppley Dr., Carlisle, PA 17013. This letter was mailed under the date of October 9, 200 I and never retumed 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 manner: The Sheriff mailed a notice of the pendency of the action to one of the within named defendants to wit: Vicki Boudman by regular mail to her last known address of 26 West Eppley Dr., Carlisle, PA 17013. This letter was mailed under the date of October 23, 2001. 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 o'clock A.M., EST. He sold the same for ., , , ~~ ~ the sum of $1.00 to Attorney Frank Federman for Secretary of Veterans Affairs, an Officer of The United States of America. It being the highest bid and best price received for the same, Secretary of Veterans Affairs, an Officer of The United States of America ofVaro Cleveland (MDP 262 PHI) P.O. Box 99640, Cleveland, OH 44199, being the buyer in this execution paid SheriffR. Thomas Kline the sum of$871.75, it being costs. Sheriffs Costs: Docketing Posting Handbills Advertising Acknowledging Deed Auctioneer Law Library Prothonotary Mileage Certified Mail Levy Surcharge Postpone Sale Law Joumal Patriot News Share of Bills Distribution of Proceeds Sheriffs Deed Poundage $30.00 15.00 15.00 30.00 10.00 .50 1.00 3.25 15.61 15.00 30.00 330.50 281.64 25.66 25.00 26.50 17.09 $ 871.75 Sworn and subscribed to before me This.1.L %.ay of ~ ~O Prothonotary 2001, A.D. --""I'01'Pi""~' ~~ ~~. .",., ~_ I i'-' so~' ~ '1-< ~~ R. Thomas Kline, t"h;i'ff ~'~4o~S~ Real Est te Deputy ~.~ v'1l 31'1.6"0 . ck. 3:fb StJ' L 119971,. - 1- ,~. ~ .4 __, FIRST HORIZON HOME LOAN CORPORATION, FfKlA FT MORTGAGE COMPANIES, D/B/A MNC MORTGAGE CUMBERLAND COUNTY COURT OF COMMON PLEAS Plaintiff, v. CIVIL nIVlSION VICKl BOUDMAN C. BLAINE BOUDMAN NO.01-251-CIVIL Defendant(s). AFFIDAVIT PURSUANT TO RULE 3129 (Affidavit No.1) FIRST HORIZON HOME LOAN CORPORATION. F/K1A FT MORTGAGE COMPANIES. D/B/A MNC MORTGAGE, Plaintiff in the above action, by its attorney, FRANK FEDERMAN, 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 26 WEST EPPLEY DRIVE. CARLISLE. PA 17013 1. Name and address ofOwner(s) or reputed Owner(s): NAME LAST KNOWN ADDRESS (If address cannot be reasonably ascertained, please so indicate.) VICKI BOUDMAN 26 WEST EPPLEY DRIVE CARLISLE, P A 17013 C. BLAINE BOUDMAN 26 WEST EPPLEY DRIVE CARLISLE, PA 17013 2. Name and address ofDefendant(s) in the judgment: NAME LAST KNOWN 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 so Id: NAME LAST KNOWN ADDRESS (If address cannot be reasonably ascertained, please so indicate.) None '~1""'- -J l~'" . l!'1I _.~~_~ . \ . ~ 4. Name and address of the last recorded holder of every mortgage of record: NAME LAST KNOWN ADDRESS (If address cannot be reasonably ascertained, please so indicate.) None 5. Name and address of every other person who has any record lien on the property: NAME LAST KNOWN ADDRESS (If address cannot be reasonably ascertained, please so indicate.) None 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 LAST KNOWN ADDRESS (If address cannot be reasonably ascertained, please so indicate.) None 7. Name and address of every other person whom the plaintiff has knowledge who has any interest in the property, which may be affected by the sale: NAME LAST KNOWN ADDRESS (If address cannot be reasonably ascertained, please so indicate.) Tenant/Occupant 26 WEST EPPLEY DRIVE CARLISLE, P A 17013 Domestic Relations of Cumberland County 13 North Hanover Street Carlisle, P A 17013 Commonwealth of Pennsylvania Department of Welfare PO Box 2675 Harrisburg, PA 17105 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. Sec. 4904 relating to unsworn falsification to authorities. August 2. 2001 DATE "*,..".",,.~ , , ... FIRST HORIZON HOME LOAN CORPORATION, FOOA FT MORTGAGE COMPANIES, D/B/A MNC MORTGAGE CUMBERLAND COUNTY No.01-251-CIVIL Plaintiff, v. VICKI BOUDMAN C. BLAINE BOUDMAN Defendant(s). August 29, 2001 TO: VICKI BOUDMAN 26 WEST EPPLEY DRIVE CARLISLE, PA 17013 C. BLAINE BOUDMAN 26 WEST EPPLEY DRIVE CARLISLE, P A i 7013 "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 AND THIS DEBT WAS NOT REAFFIRMED, 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 26 WEST EPPLEY DRIVE, CARLISLE, PA 17013is scheduled to be sold at the Sheriffs Sale on DECEMBER 5, 2001 at 10:00 a.m. in the Cumberland County Courthouse, South Hanover Street, Carlisle, PA 17013, to enforce the court judgment obtained by FIRST HORIZON HOME LOAN CORPORATION. F/KJA FT MORTGAGE COMPANIES. D/B/A MNC MORTGAGE (the mortgagee) against you. lfthe Sheriffs sale is postponed, the property will be relisted for the MARCH 6, 2002 Sheriffs Sale. 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 the mortgagee the back payments, late charges, costs and reasonable attorney's fees due. To find out how much you must pay, you may call: (215) 563-7000. 2. You may be able to stop the sale by filing a petition asking the Court to strike or open the judgment, ifthe 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 I. ,- , ~~ ,~,.. - ","".'~' ,~ You may need an attorney to assert your rights. 1'he 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. I. If the Sheriffs Sale is not stopped, your property will be sold to the highest bidder. You may find out the price bid by calling (215) 563-7000. 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 (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 that time, the buyer may bring legal proceedings to evict you. 6. You may be entitled to a share of the money which was paid for your house. A schedule of distribution of the money bid for your house will be filed by the Sheriff 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 distribution is filed. 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 ATTORNEY REFERRAL CUMBERLAND COUNTY BAR ASSOCIATION 2 LIBERTY AVENUE CUMBERLAND COUNTY COURTHOUSE CARLISLE, P A 17013 (717) 249-3166 (800) 990-9108 '~-"""'''' ~ ,,~ "1-, ALL THAT CERTAIN tract of land situate in South Middletown Township, Cumberland County, Pennsylvania, bounded and described in accQrdance with a survey prepared by John K. Boxler, III, R.S., dated 2/29/96 and recorded in the Of:ice of [he Recorder of Deeds (or Cumberland County in Plan Book 72 page ll5, revised 4/l0/96, as follows: . BEGINNING at an iron pin on the northern r'.~ht of way line of West Eppley Drive at a corner of Lot 35, Section 2-A, on the plan of Forgedale Crossing; thence along Lo[ 35, North 03 degrees 17 minutes and 08 seconds West, a distance of 150.00 feet to an iron pin: thence along Lot 30-A, Phase I, North 86 degrees 42 minutes and 5: ieconds East, distance of 100.00 feet to an iron pin; thence along Lot 33, Section 2-A, South 03le;;rees 17 minutes and 08 seconds East, a distance of 151. 02 feet to an iron pin on the northern right of 'Nay line of West Eppley Drive; thence along said northern right of way line of West Eppley Drive, by a curve to the left having a radius of 495.00 feet and arc distance of 31. 85 feet to a poim in [he right of way line; thence continuing along the northern right of way line of West Eppley Drive, South 86 degrees 42 minutes and 52 seconds West, a distance of 68.18 feet to an iron pin It Lor 35, Section 2-A, the place of BEGINNING. CONTAINING 15,000.00 Square feet and iesi~na[ed as Lot 34, Section 2-A of Plan of Forgedale Crossing. Tax Parcel #40-10-0636-309 TITLE TO SAID PREMISES IS VESTED IN C. Blaine Boudman and Vicki Boudman. husbam: and wife by Deed from S & A. Custom Built Homes, Inc., a PA Corp., dated 12/11197. recordd 12/l6/97, in Deed Book 169, Page 429. ';J!;l"""''flIII!lI!wPi\ -1, ,,~~ ~ ~ ~ ~, p WRIT OF EXECUTION'alld/or ATTACHMENT COMMONWEALTH OF PENNSYLVANIA) COUNTY OF CUMBERLAND) NO.01-2')1 CIVILlm TERM CIVIL ACTION - LAW TO THE SHERIFF OF Cunberland COUNTY: To satisfy the debt, interest and costs due First Horizon Herne Loan Corporation F /K/A Ft. Mortgage Canpanies D/B/A MNC Mortgage PLAINTIFF(S) from "irk; Rrmrlmi9n r.. Rli9ine BOllilman 26 West Epplev Drive, Carlisle, Pa. 17013 DEFENDANT(S} (1) You are directed to levy upon the property of the defendant(s) and to sell (2) You are also directed to attach the property of the defendant(s) nollevied upon in the p0ssession of GARNISHEE(S} as follows: and to notijy the garnishee(s) that: (a) an attachment has been issued; (b) .the garnishee(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; (3) If property ofthe 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 hirnlherthat he/she has been added as a garnishee and is enjoined as above stated. Amount Due $] 8').053.18 From 7/6/01 to 12/5/01 (per dlem-~JU.4L) Interest <1 h?l 7q . Ally's Comm Ally Paid Plaintiff Paid % L.L. SO. 50 Due Prolhy 1 no Other Costs 221. 66 Date: Sp['TPmhf>r 10. 2001 Curtis R. Lonq Prothonotary, Civil Division by: (hk-' (2 ~ REQUESTING PARTY: Deputy Name Fri9nk Fmp.Tman. ESQ)l;re Address: One Penn Center at Suburban Station -Suite 1400 Philadelnhia. Pa. 19103 Attorney for: Telephone: Supreme Court ID No. ~~l"""",,,,<,m l ~"~'I""""'l'='" ,b . ,~."".,~" <~,~ ~,,~- REAL ESTATE SALE No,'s\ On September 18,2001, the sherifflevied upon the defendant's interest in the real property situated in South Middleton Township, Cumberland County, PA, known and numbered as 26 West Eppley Drive, Carlisle, and more fully described on Exhibit "A" filed with this writ and by this reference incorporated herein. Date: September 18, 2001 By: qrxid 5 ifU.L-tl Real Estate Deputy V1\\f/\'-i ,I ';..:; ~.i ~,!1d 10, ~!d OT Ii II d~S A1Ni:~: i ndlift0 HIl13H ~I i;~,,; ;; :IL:IAO ., II @i} CV\l CV\l r;::::::::2 <SV G\iil ~ ^ ~~ . ~"'"~' '~"""'~~~N1''f1ptt~IJ'I!l'!:\EI!-j!I;~I$1I!l''ffiJl~~f!'!!'i'''M!l'.'Iff''''~~''if-'li'~'''~r~'c<T'''-m'u;'?'''''~';>FI~~'i'!r,;j,<li't;';;;!O~,.1Vil~~Il\1Iii!~.~~ijll!ljlj~Ii!iI'", _ _ _~i ~'RE"Al-ESTATE--SA[cNo~ 51---~~-~- r.I' Wrjt~~.2001.251 .. _,_' elvilTerm ;!i--ArstH~rizon Home Loan Corporation ;, -,-- fMa FT ~ortgage Companies, " d/b/a MNC Mortgage ~-j - -vs '==-=- Vicki Boudman and --c. Blaine Boudman . Atty: Frank Federman _DESCRIPTION 4ill., TJ;iAT CERTAIN tract of land situated in ~uth Middleton Township, Cumberland County. ~ylvf!l1ia, bounded and descnned ir, !Mfc.oj;danc.~tb a slf:v_e)' prepared by John K, ~%Jer,_m,-R.S., dated 2/29196 and recorded in f-ffie. Office. of the Rewrder of Deeds fo.: fQJ~1and County in Plan Book 72 page 115, :::-J'C'lised4110l96,asfollows: tBiGINNING at an iron pin on the northern right t:QLway,Jine of West Eppley Drive-at a corner of ~- y,~ Section 2-A, on the plan of Forgeda1~ , _ '~; thenc.e,-UlQ11gLot 35, l'o:'orth 03 degrees Tiffifiutes and 08 seconds West, a distanl.'e cf ,!:crOWfeener-mirori pin; thence along Lot 30-A, ::Page T, North 86 degrees 42 lninutes am:! 52 fEJfQnd.~ East, distance of 100.00. feet to an iron m.. lli-ence along Lot 33, Section 2MA, South C3 _ ' g!ees 17 minutes and 08seconds East, a '-iSfiifice of 151.02 feet to an iron pin on the ~]J~e!Qrigb.t of way line of West Eppley Driv=; ;W:e..n~~9.n,g~?li!Ln~rQ.1cm right of way line of .:::\WStEppley Urive, by 11 curve-to lbeleft naving a ~Uli of 495.00 feet and arc distance of 31.85 ;reett.o_<l point in !be right of way line; thence ic}:l:JijlIDumtalong the n~em right of way line Jf West Eppley Drive, South 86 degrees 42 minutes "","and 52 seconds.West, 11 distmlce of 68.[8 feet. to =anjrQn pin at Lot 35, Section 2-A, !be place of ~BEGlli_G. ;;comAINING 15,000.00 Square feet and _dcSigmitc.d gs: Let 34, Section 2-A of Plan of -FO}'ge.dale.Crossing. ~arcel #40-10.0636-309. i.e. E.TO SAID prcmisc:s is vested in C. Blaine ~J!dm~ and Vi~_B~udman, husband and ""ife, ~f'i'Qi'ilS&A Custom Butlt Homes. Inc., a ~~~dt~t.~~1r~~dC.~~.~I~,_i~ PROOF OF PUBLICATION OF NOTICE IN CUMBERLAND LAW JOURNAL (Under Act No. 587, approved May 16, 1929), P. L.1784 STATE OF PENNSYLVANIA : 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 the Borough of Carlisle in the County and State aforesaid, was established January 2, 1952, and designated by the local courts as the official legal periodical for the publication of all legal notices, and has, since January 2, 1952, been regularly issued weekly in the said County, and that the printed notice or publication attached hereto is exactly the same as was printed in the regular editions and issues of the said Cumberland Law Journal on the following dates, VIZ: October 12, 19,26,2001 Affiant further deposes that he is authorized to verify this statement by the Cumberland Law Journal, a legal periodical of general circulation, and that he is not interested in the subject matter of the aforesaid notice or advertisement, and that all allegations in the foregoing statements as to time, place and character of publication are true. ~w,- , SWORN TO AND SUBSCRIBED before me this 26 day of OCTOBER. 2001 NOTARIAlS LOIS E. SNYDER, NoIary Public CaIIlsIe Bom. Cumberland County. My Commlssion ExpiIes March 5, 2005 ~,~~ ~, ,. 1 'I I L " -~ REAL EsTATE SALE NO. 51 Writ No. 2001-251 Civil First Hornon Home Loan Corporation. f/k/a IT Mortgage Companies, d/b/a MNC Mortgage vs. Vicki Boudman and C. BlaJne Boudman Atty.: Frank Fedennan ALL THAT CERTAIN tract of land situate in South Mtddleto'tm To'W'I1- ship. Cumberland County, Pennsyl- vania. bounded and described in accordance With a survey prepared by John K. BoxIer. lll. R.S., dated 2/29/96 and recorded in the Of- fice of the Recorder of Deeds for Cumberland County" in Plan Book 72 page 115. revised 4/10/96. as follows: BEGlNNING at an Iron pin on the northern right of way line of West Eppley Dr:lve at a corner of Lot 35. Sect:iC'D 2-A. on the plan of Forge- dale Crossing; thence along Lot 35, North 03 degrees 17 minutes and 08 seconds West. a distance of 150.00 feet to an Iron pin: thence along Lot 3D-A. Phase 1. North 86 degrees 42 minutes and 52 seconds East, "distance of--100.00 feet to an tron pin; thence along Lot 33, sec- tion 2-A, South 03 degrees 17 mm- utes and 08 seconds East. a dis- tance of 151.02 feet to an Iron pin on~the northern right of way line of West Eppley Drive; thence along said northem right of way line of We5t Eppley Drive. by a curve to the left having a radius of 495.00 feet and arc distance of 31.85 feet to a point 1n the right of way line; thence continutng along the north- ern right of way line of West Eppley Drive. South 86 degrees 42 min- utes and 52 seconds \-Vest. a dis- tance of 68.18 feet to an .iron pin at Lot 35. Section 2-A. the place of BEGINNING. CONTAINING 15.000.00 Square feet and designated as Lot 34. Sec- tion 2-A of Plan of Forgedale Cross- ing. Tax Parcel #40-10-0636-309. TITLE TO SAID PREMlSES IS VESTED IN C. Bla1ne Boudman and Vicki Boudman, husband and wJ.fe by Deed from S & A Custom BuUt Homes, Inc., a PA Corp.. dated 12/ 11/97. recorded 12/16/97. In Deed Book 169. page 429. -----1 '" 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 tne laws of the Commonwealth of Pennsylvania, with its principal office and place of business at 812 to 818 Market Street, in the City of Harrisburg, County of Dauphin, State of Pennsylvania, owner and publisher of The Patriot-News and The Sunday Patriot-News newspapers of general circulation, printed and published at 812 to 818 Market Street, in the City, County and State aforesaid; that The Patriot-News and The Sunday Patriot-News were established March 4th, 1854, and September 18th, 1949, respectively, and all have been continuously published ever since; That the printed notice or publication which is securely attached hereto is exactly as printed and published in their regular daily and/or Sunday/ Metro editions which appeared on the 23rd and 30th day(s} of October and the 6th day(s) of November 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 benalf of The Patriot-News Co. aforesaid by virtue and pursuant to a resolution unanimously passed and adopted severally by the stockholders and board of directors of the said Company and subsequently duly recorded in the office for the Recording of Deeds in and for said County of D..au1in in Miscellaneous Book "M", Volume 14, Page 317. ' ~ . PUBLICATION .... .................. ..'t......................................... ............................. COpy S ALE #51 worn to and III It.llli\l~d before me Terry L. Russell, Notary Public Harrisburg, Dauphin County My COmmission Expires June 6. 20 Member, Pennsylvania ASSOCiation of Notaries My commission expires June 6, 2002 CUMBERLAND COUNTY SHERIFFS OFFICE CUMBERlAND COUNTY COUR1HOUSE 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 $ 290.14 1.50 291.64 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.................................................................... niJ_l.ltL ", '" < ._'0' ", ~_ , -