HomeMy WebLinkAbout01-1248 FX
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GOLDBECK McCAFFERTY
BY: Joseph A. Goldbeck,
Attorney I.D.#16132
Suite 500 - The Bourse Bldg.
111 S. Independence Mall East
Philadelphia, PA 19106
215-627-1322
Attorney for Plaintiff
& McKEEVER
Jr.
COUNTRYWIDE HOME LOANS INC.
7105 Corporate Drive
PTX B-35
PIano. TX 75024-3632
Plaintiff
IN THE COURT OF COMMON PLEAS
OF CUMBERLAND COUNTY
CIVIL ACTION - LAW
vs.
:ACTION OF MORTGAGE FORECLOSURE
DONALD M. ROBINDER AND
MARTHA H. ROBINDER
(Mortgagor(s) and Real Owner(s))
Term
NO.O/-IJ.ltf
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253 Bullshead Road
Newville, PA 17241
Defendant(s)
CIVIL ACTION: MORTGAGE
FORECLOSURE
THIS LAW FIRM IS A DEBT COLLECTOR AND WE ARE ATTEMPTING
TO COLLECT A DEBT OWED TO OUR CLIENT. ANY INFORMATION
OBTAINED FROM YOU WILL BE USED FOR THE PURPOSE OF
COLLECTING THE DEBT.
NOTICE
You have been sued in court. If you wish to defend against the claims set forth in the following pages,
you must take action within twenty (20) days after the Complaint and notice are served, by entering a written
appearance personally or by attorney and filing in writing with the court your defenses or objections to the
claims set forth against you. You are warned that if you fail to do so the case may proceed without you and a
judgment may be entered against you by the Court without further notice for any money claimed in the complaint
or for any other claim or relief requested by the Plaintiff. You may lose money or property or other rights
important to you.
YOU SHOULD TAKE THIS PAPER TO YOUR LAWYER AT ONCE. IF YOU DO NOT HAVE A LAWYER OR CANNOT AFFORD ONE,
GO TO OR TELEPHONE THE OFFICE SET FORTH BELOW TO FIND OUT WHERE YOU CAN GET LEGAL HELP.
Cumberland County Bar Association
2 Liberty Avenue, Carlisle, PA
(800) 990-9108
Legal Services Inc.
8 Irvine Row, Carlisle, PA 17013
(717) 243-9400
A V ISO
LE RAN DEMANDADO A USTED EN LA CORTE. 81 DESEA DEFENDERSE CONTRA LAS QUEJAS PERESENTADAS, ES
ABSOLUTAMENTE NECESSARIO QUE USTED RESPONDA DENTRO DE 20 DIAS DESPUES DE SER SERVIDO CON ESTA DEMANDA Y AVISO.
PARA DEFENDERSE ES NECESSARIO QUE USTED, 0 SU ABOGADO, REGISTRE CON LA CORTE EN FORMA ESCRITA, EL PUNTO DE VISTA
DE USTED Y CUALQUIER OBJECCION CONTRA LAS QUEJAS EN ESTA DEMANDA.
RECUERDE; SI USTED NO REPONDE A ESTA DEMANDA, SE PUEDE PR08EGUIR CON EL PROCESO SIN SU PARTICIPACION.
ENTONCES, LA COUTE PUEDE, SIN NOTIFlCARIO, DECIDIR A FAVOR DEL DEMANDANTE Y REQUERlRA QUE USTED CUMPLA CON TODAS
LAS PROVISIONES DE ESTA DEMANDA. POR RAZON DE ESA DECISION, ES POSSIBLE QUE USTED PUEDA PERDER DlNERO, PROPIEDAD
U OTROS DERECHOS IMPORTANTES.
LLEVE ESTA DEMANDA A UN ABOGADO IMMEDIATAMENTE_
S1 NO CONOCE A UN ABOGADO, LLAME AL "LAWYER REFERENCE SERVICE" (SERVICIO DE REFERENCIA DE ABOGADOS) I
215-238-6300.
Cumberland ~ounty Bar Association
2 Liberty Avenue, Carlisle, PA
(BOO) 990-9108
Legal Services Inc.
8 Irvine Row, Carlisle, PA 17013
(717) 243-9400
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COMPLAINT IN MORTGAGE FORECLOSURE
1. Plaintiff is COUNTRYWIDE HOME LOANS INC., 7105 Corporate
Drive, PTX B-35, Plano, TX 75024-3632.
2. The name(s) and address(es) of the Defendant(s) is/are
DONALD M. ROBINDER, 253 Bullshead Road, Newville, PA 17241 and
MARTHA H. ROBINDER, 253 Bullshead Road, Newville, PA 17241, who
is/are the mortgagor(s) and real owner(s) of the mortgaged property
hereinafter described.
3. On November 23, 1998, mortgagor(s) made, executed and
delivered a mortgage upon the premises hereinafter described to
INVESTAID CORP., which mortgage is recorded in the Office of the
Recorder of Deeds of Cumberland County in Mortgage Book 1503, Page
830. By Assignment of Mortgage dated November 23, 1998, the
mortgage was assigned to Plaintiff, which Assignment is recorded in
Assignment of Mortgage Book No. 596, Page 940. These documents are
matters of public record and are incorporated herein by reference
in accordance with Pennsylvania Rule of Civil Procedure 1019(g).
4. The premises subject to said mortgage is described as
attached.
5. The mortgage is in default because monthly payments of
principal and interest upon said mortgage due October 1, 2000, and
each month thereafter are due and unpaid, and by the terms of said
mortgage, upon default in such payments for a period of one month,
the entire principal balance and all interest due thereon are
collectible forthwith.
6. The following amounts are due on the mortgage:
Principal Balance
Interest from 9/ 1/00
through 2/28/01 at 6.500%
Per diem interest rate at $12.19
Attorney's Fee at 5%
of Principal Balance
Late Charges 10/ 1/00- 2/28/01
Monthly late charge amount at $26.73
Costs of suit and Title Search
$
68,428.25
2,194.20
3,421.41
133.65
560.00
$ 74,737.51
Escrow Balance
Monthly Escrow amount $
$ 74,737.51
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
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Sale. If the Mortgage is reinstated prior to the Sale reasonable
Attorney's Fees will be charged based on work actually performed.
8. Notice of Intention to Foreclose and a Notice of
Homeowners' Emergency Mortgage Assistance has been sent to
Defendant(s) by Certified and regular mail, as required by Act 160
of 1998 of the Commonwealth of Pennsylvania, on the date(s) set
forth in the true and correct copy of such notice(s) attached
hereto a.s Exhibit "A". The Defendant(s) has/have not had the
required face to face meeting within the required time and
Plaintiff has no knowledge of any such meeting being requested by
the Defendant(s) through the Plaintiff, the Pennsylvania Housing
Finance Agency, or any appropriate Consumer Credit Counseling
Agency.
WHEREFORE, Plaintiff demands judgment in mortgage foreclosure
the sum of $74,737.51, together with interest at the rate of
$12.19, per day and other expenses incurred by the Plaintiff which
are properly chargeable in accordance with the terms of the
mortgage, and for the foreclosure and sale of the mortgaged
premiseI'.
By:
G Y & McKEEVER
B Joseph A. Goldbeck, Jr., Esq.
Attorney for Plaintiff
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VERIFICATION
I,
, as the representative of the
Plaintiff corporation within named do hereby verify that I am
authorized to and do make this verification on behalf of the
Plaintiff corporation and the facts set forth in the foregoing
Complaint are true and correct to the best of my knowledge,
information and belief. I understand that false statements therein
are made subject to the penalties of 18 Pa. C.S. 4904 relating to
unsworn falsification
Date:3 II 101
to authorities.
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Legal Description:
ALL that certain tract of land in North Newton Township, Cumberland County, Commonwealth of Pennsylvania, more
particularly bounded and described as follows: .
BEGINNING at a point, a comer posts, at lands now or formerly of John Hostetter; thence by lands now or fOl'merly of John
Hostetter, North 37 degrees 59 minutes 51 seconds West 203.56 feet to a comer post; thence by same Sou.th 5" degrees 05
minntes 55 seconds West 1"2.02 feet to a corner post; thence by same North 36 degrees 35 minutes 56 seconds West 211.27 feet
to a comer post; thence by same No.rth 48 degrees 23 mhiutes 30 seconds East 316.31 feet to a comer post; thence by same
South 39. degreeil 43 mbintes 39 seconds EllSt 267.17 feet to. a comer post at the edge of an existing lane; thence by same South
46 clegrees30 minutes 26 seconds West 99.00 feet to an iron pin; thenceby same South 36 degrees 06 minutes 06 seconds East
1730.25 feet to a post; thence by same South 58 degrees 45 miliutes 55 seconds West 83.28 feet to a curve post, the place of
BEGINNING. .
CONSISTING of 2.156 acreS, more or less.
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Send Correspondence to:
P.O. Box 10221
Van Nuys, CA 91410-0221
"
Send PaymEfnts to:
P.O. Box 10219
Van Nuys, CA 91410-0219
Donald M Robinder
253 Bullshead Road
Newville. PA 17241-0000
EXHiBIT A
Certified Mail No.
Return Receipt Requested
Regular Mail
December 1, 2000
Countrywide Loan # 4116736
Property Address:
253 Bullshead Road
Newville, PA 17241-0000
NOTICE OF INTENT TO FORECLOSE
YOUR HOME LOAN IS IN DEFAULT FOR THE REASONS SET FORTH IN THIS NOTICE.
YOU MUST TAKE ACTION TO SAVE YOUR HOME FROM FORECLOSURE.
Countrywide Home Loans, Inc. (hereinafter <<Countrywide") services your home loan. Your home loan is in serious default
because you have not made your required payments. The total amount now required to reinstate your loan as of the
date of this letter is as follows:
Monthlv Payments:
Late Charaes:
other Cha"raes:
10/0112000 -11/3012000
1010112000 -11/3012000
Uncollected Late Charges:
@
@
$534.58
$25.73
$1.069.16
$53.46
$26.73
TOTAL DUE: $1':149:35
You may cure this default within THIRTY-FIVE (35) DAYS of the date of this letter, by paying to us the abpve amount of
$1,149.35, plus any additional monthly payments, late charges, fees and other applicable charges which may fall due
during this period. Such payment must be in the form of certified check, cashier's check or money order, and made
payable to Counbywide at P.O. Box 10221, Van Nuys, CA 91410-0221. If your check or other payment is, returned to us
for insufficient funds or for any other reason, you will not have cured your default. No extension of time to cure will be
granted due to a returned payment.
If you do not cure this default within THIRTY~FIVE (35) DAYS, we will accelerate the payments due on your home loan.
This means whatever is owing on the original amount borrowed will be considered due immediately and you may lose the
chance to payoff your home loan in monthly installments. If the full payment of the amount of default is not made within
THIRTY-FIVE (35) DAYS, we also intend to immediately start a lawsuit to foreclose.on your mortgaged property.
YOU MAY BE ELIGIBLE FOR FINANCIAL ASSISTANCE WHICH CAN SAVE YOUR HOME FROM FORECLOSURE
AND HELP YOU MAKE FUTURE MORTGAGE PAYMENTS.
The Commonwealth of Pennsylvania's Homeowner's Emergency Mortgage Assistance program may be able to
help you. Read 1h~ following notice to find out how the program works.
La notiflCacion en adjunto 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 inmediatamente IlamandQ a esta
agencia (Pennsylvania Housing Finance Agency) sin cargos al numero mencionado arriba. Usted puede ser
elegible para un prestamo del programa lIamado "Homeowner's Emergency Mortgage Assistance Program" el
cual puede salvar su casa de la perdida del derecho a redimir su hipoteca.
You may be eligible for financial assistance that will prevent foreclosure on your mortgage if you comply with the
provisions of the Homeowners' Emergency Mortgage Assistance Act of 1983 (the "Act"). You may be eljgible for
emergency temporary assistance if your default has been caused by circumstances beyond your control, you have a
reasonable prospect of resuming your mortgage payments, and if you meet other eligibility requirements established by
the Pennsylvania Housing Finance Agency. Please read all of this Notice. It contains an explanation of your rights.
Under the Act, you are entitled to a temporary stay of foreclosure on your mortgage for thirty (30) days from the date of
this Notice. During that time you must arrange and attend a "face-to-face" meeting with a representative of this lender, or
with a designated consumer credit counseling agency. The purpose of this meeting is to attempt to work out a
repayment plan, or to othetwise settle your delinquency. This meeting must occur in the next thirty (30) days.
Please write your loan ~umber on all checks and correspondence.
BREACHPA
4116736-2
Donald M Robinder
253 Bullshead Road
$1,149.35ASOF 12/01/2000
P.O. Box 10219
Van Nuys, CA 9141()-0219
11.1'"1.11.1..11111111'1.1111'111.111,11111"'1.11111....11.1
411673620001149350114935
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HUD-Approved Counseling Agencies - Pennsylvania
If yaLl attend a face-ta-face meeting with this lender, or with a consumer credit counseling agency identified in~is notice,
no further proceeding in mortgage foreclosure may take place for thirty (30) days after the date of this meeting. The
name, address and telephone number of our representative is: COUNTRYWIDE, 6400 Legacy Drive, Piano, Texas
72567, Telephone Number: ~-800-669-6654, Extension 7556.
The names and addresses of designated consumer'credit counseling agencies are shown on the attached sheet. It is
only necessary to schedule one face4o-face meeting. You should advise Countrywide .of your intentions immediately.
If you have tried and are unable to resolVe this problem at or after your face-to-face meeting, you have the right to apply
for financial assistance from the Homeowners' Emergency Mortgage Assistance Fund. In order to do this, you must fill
out, $ign and file a completed Homeowners' Emergency Assistance Application with one of the designated consumer
credit counseling agencies listed on the attachment. An application for assistance may only be obtained from a
consumer credit counseling agency. The consumer credit counseling agency will assist you in filling out your application
and will submit your completed application to the Pennsylvania Housing Finance Agency. Your application must be filed
or pQ5tmarked within thirty (30) days of your face-to-face meeting.
Available funds for emergency mortgage assistance are very limited. They will be disbursed by the Agency
under the eligibility criteria established by the Act
It is extremely important that you file your application promptly. If you do not do so, or if you do not follow the other time
periods set forth in this letter, foreclosure may proceed against your home immediately. It is extremely important that your
applioation is accurate and complete in every respect.
The Pennsylvania Housing Finance Agency has sixty (60) days to make a decision after it receives your application.
During that additional time, no foreclosure proceedings will be pursued against you if you have met the time requirements
set forth above. You wifI be notified directly by that Agency of its decision on your application.
The Pennsylvania Housing Finance Agency is located at 2101 North Front Street, Post Office Box 8029, Harrisburg,
Pen~vania 17105. Telephone No. 1-717-780-3800 or 1-800-342-2397 (toll free number). Persons with impaired
heariOg can call 1-800-342-2397.
If the mortgage is foreclosed, your mortgaged property will be sold by the Sheriff to payoff the mortgage debt If you
cure the default before we begin legal proceedings against you, you will still have to pay the reasonable attorney's fees
actually incurred, up to $50.00. However, if legal proceedings are started against you, you will have to pay the reasonable
attorney's fees even if they are over $50.00. Any attorney's fees will be added to whatever you owe us, which may also
include our reasonable costs. If you cure this default within the thirty-five day period, you win not be required to pay the
attorney's fees. YOU HAVE THE RIGHT TO REINSTATE AFTER ACCELERATION AND THE RIGHT TO ASSERT IN
THE FORECLOSURE PROCEEDING THE NON-EXISTENCE OF A DEFAULT OR ANY OTHER DEFENSE YOU
MAY HAVE TO ACCELERATION AND FORECLOSURE.
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Send Correspondence 10:
P.O. Box 10221
Van Nuys, CA 91410-0221
.
Send Paym~nts to:
P.O. Box 10219
Van Nuys. CA 91410-0219
EXHlerr A
Certified Mail No.
Return Receipt Requested
Regular Mail
December 1 , 2000
Martha H Robinder
253 Bullshead Road
Newville, PA 17241-0000
Countrywide Loan # 4116736
Property Address:
253 Bullshead Road
Newville, PA 17241-0000
NOTICE OF INTENT TO FORECLOSE
YOUR HOME LOAN IS IN DEFAULT FOR THE REASONS SET FORTH IN THIS NOTICE.
YOU MUST TAKE ACTION TO SAVE YOUR HOME FROM FORECLOSURE.
Countrywide Home Loans, Inc. (hereinafter ~Counbywide") services your home loan. Your home loan is in serious default
because you have not made your required payments. The total amount now required to reinstate your loan as of 1f1e
date of this letter is as foUows:
Monthlv Payments:
Late Charaes:
Other Charaes:
1010112000 - 1113012000
1010112000 - 11/3012000
Uncollected Late Charges:
@
@
$534.58
$26.73
,
$1,069.16
$53.46
$26.73
TOTAL DUE: $1,149:.35
You may cure 1f1is defaWt within THIRTY-FIVE (35) DAYS of the date of this letter, by paying to us 1f1e above amount of
$1,149.35, plus any additional monthly payments, late charges, fees and other applicable charges which may fall due
during this period. Such payment must be in the form of certified check, cashier's check or money order, and made
payable to Countrywide at P.O. Box 10221, Van Nuys, CA 91410-0221. If your check or o1f1er payment is returned to us
for insufficient funds or for any other reason, you will not have cured your default. No extension of time to cure will be
granted due to a returned payment.
.
If you do not cure this default within THIRTY-FIVE (35) DAYS, we will accelerate 1f1e payments due on your home loan.
This means whatever is owing on the original amount borrowed will be consider~d due immediately and you may lose 1f1e
chance to payoff your Ilome loan in monthly installments. If the tuft payment of the amount of default is not made within
THIRTY..fIVE (35) DAYS, we also intend to immediately start a lawsuit to foreclose on your mortgaged property.
YOU MAY BE ELIGIBLE FOR FINANCIAL ASSISTANCE WHICH CAN SAVE YOUR HOME FROM FORECLOSURE
AND HELP YOU MAKE FUTURE MORTGAGE PAYMENTS.
The Commonwealth of Pennsylvania's Homeowner's Emergency Mortgage Assistance program may be able to
help you. Read the following notiil:e 10 find out how the program worJ[s.
La notificacion en adjunto 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 inmediatamente lIamando a esta
agencia (Pennsylvania Housing 'Finance Agency) sin cargos' al numero mencionado arriba. Usted puede ser
elegible para un prestamo del programa Ilamado "Homeowner's Emergency Mortgage Assistance Program" el
cual puede salvar su casa de la perdida del derecho a redimir su hipoteca.
You may be eligible for financial assistance that will prevent foreclosure on your mortgage if you comply with the
provisions of 1f1e, Homeowners' Emergency Mortgage Assistance Act of 1983 (1f1e "Act;. You may be eligible for
emergency temporary assistance if your default has been caused by circumstances beyond your control, you have a
reasonable prospect of resuming your mortgage paym.ents, and if you meet o1f1er eligibility requirements established by
the Pennsylvania Housing Finance Agency. Please read all of this Notice. It contains an explanation of your rights.
Under the Act, you are entitled to a temporary stay of foreclosure on your mortgage for thirty (30) days from the date of
this Notice. During 1f1at time you must arrange and attend a "face-ta-face" meeting with a representative of this lender, or
with a designated consumer credit counseling agency. The purpose of this meeting is to attempt to work out a
repayment plan, or to o1f1erwise settle your delinquency. This meeting must occur in the next thirty (30) days.
Please write your loan number on all checks and correspondence.
BREACHPA
4116736-2
MarthaHRobinder
253 BuUshead Road
$1,149.35 AS OF 12/01/2000
P.O. Box 10219
Van Nuys, CA 91410-0219
11111111.11111.1111111111111111111111111111111111111.1'11111,1
411673620001149350114935
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HUD-Approved Counseling Agencies" Pennsylvania
If you attend a face-to-face meeting'with this lender, or with a consumer credit counseling agency identified irrfuis notice,
no further proceeding in mortgage foreclosure may take place for thirty (30) days after the date of this meeting. The
name, address and telephone number of our representative is: COUNTRYWIDE, 6400 Legacy Drive, Piano, Texas
72567. Telephone Number: 1-800-669-6654, Exlension 7556.
The names and addresses of designated consumer credit counseling agencies are shown on the attached sheet. It is
only necessary to schedule one face-to-face meeting. You should advise Countrywide of your intentions immediately.
If you have tried and are unable to resolve this problem at or after your face-to-face meeting, you have the right to apply
for. financial assistance from the Homeowners' Emergency Mortgage Assistance Fund. In order to do this, you must fill
out, sign and file a completed Homeowners' Emergency Assistance Application with one of the designated consumer
credit counseling agencies listed on the attachment. An application for assistance may only be obtained from a
consumer credit counseling agency. The consumer credit counseling agency will assist you in filling out your application
and will submit your completed application to the Pennsylvania Housing Finance Agency. Your application must be filed
or postmarked within'thirty (30) days of your face-to-face meeting.
Available funds for emergency mortgage assistance are very limited. They will be disbursed by the Agency
under the eligibility criteria established by the Act
It is extremely important that you file your application promptly. If you do not do so, or if you do not follow the ottler time
periods set forth in this letter, foreclosure may proceed against your home immediately. It is extremely important that your
application is accurate and Complete in every respect.
The Pennsylvania Housing Finance Agency has sixty (60) days to make a decision after it receives your application.
During that additional time, no foreclosure proceedings will be pursued against you if you have met the time requirements
set forth above. You wiD be notified directly by that Agency of its decision on your appUcation.
The Pennsylvania Housing Finance Agency is located at 2101 North Front Street, Post Office Box 8029, Hanisburg,
Pennsylvania 17105. Telephone No. 1-717-780~3800 or 1~800-342-2397 (toll free number). Persons with impaired
hearing can call 1-800-342-2397.
If the mortgage is foreclosed, your mortgaged property will be sold by the Sheriff to payoff the mortgage debt If you
cure the default before we begin legal proceed'mgs against you, you will still have to pay the reasonable attorney's fees
acbJally incurred, up to $50.00. However, if legal proceedilJgs are started against you, you will Have to pay the reasonable
attorney's fees even if they are over $50.00. Any attorney's fees will be added to wh~ever you owe us, which may also
include our reasonable costs. If you cure 1his default VlIithin the thirty-five ~ period,. you witi not be required to pay the
attorney's fees. YOU HAVE THE RIGHT TO REINSTATE AFTERACCELERATlON AND THE RIGHT TO ASSERT IN
THE FORECLOSURE PROCEEDING THE NON-EXlSTENCE OF A DEFAULT OR ANY OTHER DEFENSE YOU
MAY HAVE TO ACCELERATION AND FORECLOSURE.
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SHERIFF'S RETURN - NOT SERVED
, CAS\ NO: 2001-01248 P
COMMONWEALTH OF PENNSYLVANIA
COUNTY OF CUMBERLAND
COUNTRYWIDE HOME LOANS INC
VS
ROBINDER DONALD M ET AL
R. Thomas Kline
, Sheriff
, who being duly sworn
according to law, says, that he made a diligent search and inquiry for
the within named DEFENDANT
, to wit:
ROBINDER MARTHA H
but was
unable to locate Her in his bailiwick. He therefore returns the
COMPLAINT - MORT FORE
NOTICE
NOT SERVED , as to
the within named DEFENDANT
, ROBINDER MARTHA H
DEFENDANT IS DECEASED.
Sheriff's Costs:
Docketing
NOT SERVED RETURN
Affidavit
Surcharge
6.00
5.00
.00
10.00
.00
~OO--GOLDBECK, MCCAFFERTY,
03/12/2001
~~
R. THOMAS KLINE
SHERIFF OF CUMBERLAND COUNTY
MCKEEVER
Sworn and subscribed to before me
this
;J,."" 'e day of ~-".J.-.>
.2.InJ) A.D.
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SHERIFF'S RETURN - REGULAR
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CASE NO: 2001-01248 P
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COMMONWEALTH OF PENNSYLVANIA:
COUNTY OF CUMBERLAND
COUNTRYWIDE HOME LOANS INC
VS
ROBINDER DONALD M ET AL
DAWN L KELL
, Sheriff or Deputy Sheriff of
Cumberland County,Pennsylvania, who being duly sworn according to law,
says, the within COMPLAINT - MORT FORE
was served upon
ROBINDER DONALD M
the
DEFENDANT
, at 0014:29 HOURS, on the 9th day of March
2001
at 253 BULLSHEAD ROAD
NEWVILLE, PA 17241
by handing to
DONALD M. ROBINDER
a true and attested copy of COMPLAINT - MORT FORE
together with
NOTICE
and at the same time directing His attention to the contents thereof.
Sheriff's Costs:
Docketing
Service
Affidavit
Surcharge
18.00
8.68
.00
10.00
.00
36.68
S~~~~
R. Thomas Kline
day of
03/12/2001
GOLDBECK, MCCAFFERTY, MCKEEVER
By: C"""\ j) \ I .A
~tJo..uYY\ -&. \UtL
Deputy Sheriff
Sworn and Subscribed to before
me this .;L'1!:::'
I.~ J.."o\ A.D.
~Q~~
. othonotary .
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GOLDBECK McCAFFERTY
BY: Joseph A. Goldbeck,
Attorney I.D.#16l32
Suite 500 - The Bourse Bldg.
111 S. Independence Mall East
Philadelphia, PA 19106
215-627-1322
Attorney for Plaintiff
& McKEEVER
Jr.
U6EREBY CERTIFYTHATTHIS
IS" TRUE AND CORRECT COpy
OFTHE ORIGINAL FILED
COUNTRYWIDE HOME LOANS INC.
7105 Corporate Drive
PTX B-35
PIano, TX 75024~3632
Plaintiff
IN THE COURT OF COMMON PLEAS
OF CUMBERLAND COUNTY
CIVIL ACTION - LAW
VS.
:ACTION OF MORTGAGE FORECLOSURE
DONALD M. ROBINDER AND
MARTHA H. ROBINDER
(Mortgagor(s) and Real Owner(s))
Term C-.,-.
No. 01- /;JI./f CI~l L l~
253 Bullshead Road
Newville, PA 17241
Defendant(s)
CIVIL ACTION: MORTGAGE
FORECLOSURE
THIS LAW FIRM IS A DEBT COLLECTOR AND WE ARE ATTEMPTING
TO COLLECT A DEBT OWED TO OUR CLIENT. ANY INFORMATION
OBTAINED FROM YOU WILL BE USED FOR THE PURPOSE OF
COLLECTING THE DEBT.
NOTICE
You have been sued in court. If you wish to defend against the claims set forth in the following pages,
you must take action within twenty (20) days after the Complaint and notice are served, by entering a written
appearance personally or by attorney and filing in writing with the court your defenses or objections to the
claims set forth against you. You are warned that if you fail to do so the case may proceed without you and a
judgment may be entered against you by the Court without further notice for any money claimed in the Complaint
or for any other claim or relief requested by the Plaintiff. You may lose money or property or other rights
important to you.
YOU SHOULD TAKE THIS PAPER TO YOUR LAWYER AT ONCE. IF YOU DO NOT HAVE A LAWYER OR CANNOT AFFORD ONE,
Ga TO OR TELEPHONE THE OFFICE SET FORTH BELOW TO FIND OUT WHERE YOU CAN GET LEGAL HELP.
Cumberland County Bar Association
2 Liberty Avenue, Carlisle, PA
(800) 990-9108
Legal Services Inc.
8 Irvine Row, Carlisle, PA 17013
(717) 243-9400
A V ISO
LE RAN DEMANDADO A USTED EN LA CORTE. SI DESEA DEFENDERSE CONTRA LAS QUEJAS PERESENTADAS, ES
ABSOLDTAMENTE NECESSARIO QUE DSTED RESPONDA DENTRO DE 20 DIAS DESPUES DE SER SERVIDO CON ESTA DEMANDA Y AVISO.
PARA DEFENDERSE ES NECESSARIO QUE DSTED, 0 SD ABOGADO, REGISTRE CON LA CORTE EN FORMA ESCRITA, EL PUNTO DE VISTA
DE DSTED Y CUALQUIER OBJECCION CONTRA LAS QUEJAS EN ESTA DEMANDA.
RECDERDE: SI DSTED NO REPONDE A ESTA DEMANDA, SE PUEDE PROSEGUIR CON EL PROCESO SIN SU PARTICIPACION.
ENTONCES, LA COUTE PUEDE, SIN NOTIFlCARIO, DECIDIR A FAVOR DEL DEMANDANTE Y REQUERIRA QUE USTED CUMPLA CON TODAS
LAS PROVISIONES DE ESTA DEMANDA. POR RAZON DE ESA DECISION, ES POSSIBLE QUE USTED PUEDA PERnER DINERO, PROPIEDAD
U OTROS DERECHOS IMPORTANTES.
LLEVE ESTA DEMANDA A UN ABOGADO IMMEDIATAMENTE.
81 NO CONOCE A UN ABOGADO, LLAME AL "LAWYER REFERENCE SERVICE" (8ERVICIO DE REFERENCIA DE ABOGADOS),
215-238-6300.
Cumberland County Bar Association
2 Liberty Avenue, Carlisle, PA
(800) 990-9108
TRUE COPY FROM RECORD
In T83timOOy wlIereaI. I here unto. my haM
M!.1 tw. _ 0( said Cuurj at CarIjeIe, Pi.
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Legal Services Inc.
a Irvine Row, Carlisle, PA 17013
(717) 243-9400
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COMPLAINT IN MORTGAGE
,HEREBY CERTIFY THAT THIS
IS A TRUE AND CORRECT COpy
FORECLOSu2~ THE ORIGINAL FILED
,
1. Plaintiff is COUNTRYWIDE HOME LOANS INC., 7105 Corporate
Drive, PTX B-35, PIano, TX 75024-3632.
2. The name(s) and address(es) of the Defendant(s) is/are
DONALD M. ROBINDER, 253 Bullshead Road, Newville, PA 17241 and
MARTHA H. ROBINDER, 253 Bullshead Road, Newville, PA 17241, who
is/are the mortgagor(s) and real owner(s) of the mortgaged property
hereinafter described.
3. On November 23, 1998, mortgagor(s) made, executed and
delivered a mortgage upon the premises hereinafter described to
INVESTAID CORP., which mortgage is recorded in the Office of the
Recorder of Deeds of Cumberland County in Mortgage Book 1503, Page
830. By Assignment of Mortgage dated November 23, 1998, the
mortgage was assigned to Plaintiff, which Assignment is recorded in
Assignment of Mortgage Book No. 596, Page 940. These documents are
matters of public record and are incorporated herein by reference
in accordance with Pennsylvania Rule of Civil Procedure 10l9(g).
4. The premises subject to said mortgage is described as
attached.
5. The mortgage is in default because monthly payments of
principal and interest upon said mortgage due October 1, 2000, and
each month thereafter are due and unpaid, and by the terms of said
mortgage, upon default in such payments for a period of one month,
the entire principal balance and all interest due thereon are
collectible forthwith.
6. The following amounts are due on the mortgage:
Principal Balance
Interest from 9/ 1/00
through 2/28/01 at 6.500%
Per diem interest rate at $12.19
Attorney's Fee at 5%
of Principal Balance
Late Charges 10/ 1/00- 2/28/01
Monthly late charge amount at $26.73
Costs of suit and Title Search
$
68,428.25
2,194.20
3,421.41
133.65
560.00
$ 74,737.51
Escrow Balance
Monthly Escrow amount $
$ 74,737.51
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
.
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Sale. If the Mortgage is reinstated prior to the Sale reasonable
Attorney's Fees will be charged based on work actually performed.
8. Notice of Intention to Foreclose and a Notice of
Homeowners' Emergency Mortgage Assistance has been sent to
Defendant(s) by Certified and regular mail, as required by Act 160
of 1998 of the Commonwealth of Pennsylvania, on the date(s) set
forth in the true and correct copy of such notice(s) attached
hereto as Exhibit "A". The Defendant(s) has/have not had the
required face to face meeting within the required time and
Plaintiff has no knowledge of any such meeting being requested by
the Defendant(s) through the Plaintiff, the Pennsylvania Housing
Finance Agency, or any appropriate Consumer Credit Counseling
Agency.
WHEREFORE, Plaintiff demands judgment in mortgage foreclosure
the sum of $74,737.51, together with interest at the rate of
$12.19, per day and other expenses incurred by the Plaintiff which
are properly chargeable in accordance with the terms of the
mortgage, and for the foreclosure and sale of the mortgaged
premises.
By:
G Y & McKEEVER
B Joseph A. Goldbeck, Jr., Esq.
Attorney for Plaintiff
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VERIFICATION
I,
, as the representative of the
Plaintiff corporation within named do hereby verify that I am
authorized to and do make this verification on behalf of the
Plaintiff corporation and the facts set forth in the foregoing
Complaint are true and correct to the best of my knowledge,
information and belief. I understand that false statements therein
are made subject to the penalties of 18 Pa. C.S. 4904 relating to
unsworn falsification
Date:3/1/01
to authorities.
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Lel!alDescrlntion:
ALL that certaln tract olland in North Newton Township, Cumberland County,.Commonwealth of Pennsylvania, more
particularly bounded and described as follows: .
. .
. .
BEGlNNING at a point, a corner posts, at lands now or formerly of Jobn Hostetter; thence by lands now or fo~merly of Jobn
Hostetter, Ncirtb3.7 degrees 5~ minutes 51 seconds West 203.56 feet to a corner post; thence by same Sou.tb 54 degr~ 05
mbiutes 55 secondS West 142~02 feet to a corner post; thence by same Norlb 36 degrees 35 minutes 56 s~\lnds West 211.27 feet
to a COl'D,er post; .thence by same No.rtb 48 degrees 23 minutes 30 seconds East316.31 feetto aeorner post; thence by .iune
South 39 d~ 43 mhilltes 39 seconds East 267.17 feet to. a corner post at the edge of an existing Jane; thence bysme SOllth
46 degrees 30 minutes 26 seconds West 99.00}eet to an iron pin; thence by same South 36 degi-ees 06 minutes O6SecoDds East
1730,2Sfeetto a taost; thence by same South 58 degrees 45 mlnDtes 55 seconds West 83.28 feet to a curve post, the place of
. BEGINNING. .. . .
CONSISTING of.2.l56 acreS, more or less.
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Send Correspondence to:
P.O. Box 10221
Van Nuys, CA 91410-0221
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Send Payments to:
P.O. Box 10219
Van Nuys. CA 91410-0219
Donald M Robinder
253 Bullshead Road
Newville, PA 17241-0000
. EXHIBIT A
Certified Mail No.
Return Receipt Requested
Regular Mail
December 1, 2000
Countrywide Loan # 4116736
Property Adwess:
253 Bullshead Road
Newville, PA 17241-0000
NOTICE OF INTENT TO FORECLOSE
YOUR HOME LOAN IS IN DEFAULT FOR THE REASONS SET FORTH IN THIS NOTICE.
YOU MUST TAKE ACTION TO SAVE YOUR HOME FROM FORECLOSURE.
Countrywide Home Loans, Inc. (hereinafter ~Countrywide") services your home loan. Your home loan is in serious default
because you have not made your required payments. The total amount now required to reinstate your loan as of the
date of this letter is as f9l1ows:
$1,069.16
$53.46
$26.73
TOTAL DUE: ${149jS
You may cure this default within THIRTY-FIVE (35) DAYS of the date of this letter, by paying to us the above amount of
$1,149.35, plus any additional monthly payments, late charges, fees and other applicable charges which may fall due
dwing this period. Such payment must be in the form of certified check, cashier's check or money order, and made
payable to Countrywide at P.O. Box 10221, Van Nuys, CA 91410-0221. If your check or other payment is returned to us
for insufficient funds or for any other reason, you will not have cured your default. No extension of time to cure .will be
granted due to a returned payment
Monthlv Payments:
Late Charaes:
other Charaes:
10/0112000 - 1113012000
10/0112000 - 11/3012000
Uncollected Late Charges:
@
@
$534.56
$26.73
If you do not cure this default wiUlin THIRTY-FIVE (35) DAYS, we will accelerate the payments due on your home loan.
This means whatever is owing on the original amount borrowed wiD be considered due immediately and you may lose the
chance to payoff your home loan in monthly installments. If the full payment of the amount of default is not made within
THIRTY-FIVE (35) DAYS, we also intend to immediately start a lawsuit to foreclose.on your mortgaged property.
YOU MAY BE EUGIBLE FOR FINANCIAL ASSISTANCE WHICH CAN SAVE YOUR HOME FROM FORECLOSURE
AND HELP YOU MAKE FUTURE MORTGAGE PAYMENTS.
The Commonwealth of Pennsylvania's Homeowner's Emergency Mortgage Assistance program may be able to
help you. Read the following notice to find out how the program works.
La notificacion en adjunto es de suma importancia, pues afecta su derecho a continuar viviendo en su casa. Si
no comprende el contenido de esta notificacion obtenga una traduccion inmediatamente IlamandQ a esta
agencia (Pennsylvania Housing Finance Agency) sin cargos al numero mencionado arriba. Usted puede ser
elegible para un prestamo del programa llamado "Homeowner's Emergency Mortgage Assistance Program- eI
cual puede salvar su casa de la perdida del derecho a redimir 50 hipoteca.
You may be eligible for financial assistance that will prevent foreclosure on your mortgage if you comply with the
provisions of the Homeowners' Emergency Mortgage Assistance Act of 1983 (the "Act"). You may be e6gible for
emergency temporary assistance if your default has been caused by circumstances beyond your control, you have a
reasonable prospect of resuming your mortgage payments, and if you meet other eligibility requirements established by
the Pennsylvania Housing Finance Agency. Please read all of this Notice. It contains an explanation of your rights.
Under the Act, you are entiOed to a temporary stay of foreclosure on your mortgage for thirty (30) days from the date of
this Notice. During that time you must arrange and attend a "face-to-face" meeting with a representative of this lender, or
with a designated consumer credit counseling agency. The purpose of this meeting is to attempt to work out a
repayment plan, or to otherwise settle your delinquency. This meeting must occur in the next thirty (30) days.
Please write your loan ~umber on all checks and correspondence.
BREACHPA
4116736-2
Donald M Robinder
253 Bullshead Road
$1,149.35 AS OF 12/01/2000
P.O. Box 10219
Van Nuys, CA 91410-0219
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HUD-Approved Counseling Agencies - Pennsylvania
If you attend a face-ta-face meeting with this lender, or with a consumer credit counseling agency identified intthis notice,
no further proceeding in mortgage foreclosure may take place for thirty (30) days after the date of this meefing. The
name, address and telephone number of our representative is: COUNTRYWIDE, 6400 Legacy Drive, Piano, Texas
72567, Telephone Number: 1-800.669-6654, Extension 7556.
The names and addresses of designated consumer'credit counseling agencies are shown on the attached sheet It is
only necessary to schedule one face-to-face meeting. You should advise Counbywide ~f your intentions immediately.
If you have tried and are unable to fe-solve' this -problem at or after your face-to-face meeting, you have the right to apply
for financial assistance from the Homeowners' Emergency Mortgage Assistance Fund. In order to do this, you must fill
out, sign and file a completed HomeownefS' Emergency Assistance Application with one of the designated consumer
credit counseling agencies listed on the attachment An application for assistance may onlY be obtained from a
consumer credit counseling agency. The consumer credit counseling agency win assist you in filling out your application
and will submit your completed application to the Pennsylvania Housing Finance Agency. Your appfication must be filed
or postmarked within thirty (30) days of your face-ta-face meeting.
Available funds for emergency mortgage assistance are very limited. They will be disbursed by the Agency
under the eligibility criteria established by the Act
It is extremely important 1I1at you file your application promptly. If you do ,not do so, or if you do not follow the other time
periods set forth in this letter, foreclosure may proceed against your home immediately. It is extremely important that your
appJication is accurate and complete in every respect
The Pennsylvania H()using Finance Agency has sixty (60) days to ~ake a decision after it receives your application.
During that additional time, no foreclosure proceedings will be pursued against you if you have met the time requirements
set forth above. You will be notified directly by that Agency of its decision on your appUcation.
The Pennsylvania Housing Finance Agency is located at 2101 North Front Street, Post Office Box 8029, Harrisburg,
Pennsylvania 17105. Telephone No. 1-717-780-3800 or 1-800-342-2397 (toll free number). Persons with impaired
hearing can call 1-800-342-2397.
If the mortgage is foreclosed, your mortgaged property will be sold by the Sheriff to payoff the mortgage debt. If you
cure the default before we begin legal proceedings against you, you will still have to pay 1I1e reasonable attorney's fees
actuaUy incurred, up to $50.00. However, if legal proceedings are started against you, you wiD have to pay 1I1e reasonable
attorney's fees even if they are over $50.00. Any attorney's fees will be added to whatever you owe us, which may also
include our reasonable costs. If you cure this default within 1I1e thirty-five day period, you wiD not be required to pay the
attorney's fees. YOU HAVE THE RIGHT TO REINSTATE AFTER ACCELERATION AND THE RIGHT TO ASSERT IN
THE FORECLOSURE PROCEEDING THE NON-EXISTENCE OF A DEFAULT OR ANY OTHER DEFENSE YOU
MAY HAVE TO ACCELERATION AND FORECLOSURE.
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Send Paym~nts to:
P.O. Box 10219
Van Nuys, CA 91410-0219
Send CorreSpondence to:
P.O. Box 10221
Van Nuys, CA 91410-0221
December 1, 2000
EXHIBiT A
Certified Mail No_.
Return Receipt Requested
Regular Mail
Martha H Robinder
253 BuUshead Road
Newville, PA 17241-0000
Countrywide Loo" # 4116736
Property Address:
253 Bullshead Road
Newville, PA 1724 HlOOO
NOTICE OF INTENT TO FORECLOSE
YOUR HOME LOAN IS IN DEFAULT FOR THE REASONS SET FORTH IN THIS NOTICE.
YOU MUST TAKE ACTION TO SAVE YOUR HOME FROM FORECLOSURE.
Countrywide Home Loans, Inc_ (hereinafter "Countrywide") services your home loan. Your home loail is in serious default
because you have not made your required payments_ The total amount now required to reinstate your loan as of the
date of this letter is as follows:
MonthlvPavments: 1010112000-11/3012000 @ $534.58 $1,069.16
Late Charaes: 10/0112000 ~ 11/3012000 @ $26.73 $53.46
other Charaes: Uncollected Late Charges: $26.73
TOTAL DUE: . $1,149:35
You may cure this default within THIRTY-FIVE (35) DAYS of the date of this letter, by paying to us the above amount of
$1,149.35, plus any additional monthly p~ments, late charges, fees and other appilicable charges which may faU due
.. during this period. Such payment must be m the form of certified check, cashier's Check or money order, and made
payable to Countrywide at P.O. Box 10221, Van Nuys, CA 91410-0221. If your check or oUler payment is returned to us
for insufficient funds or for any oU1er reason, you will not have cured your default. No extension of time to cure wiD be
,t granted due to a returned payment.
If you do not cure this default within THIRTY-FIVE (35) DAYS, we will accelerate the payments due on your home loan.
.This means whatever is owing on the original amount borrowed will be considered due immediately and you may lose the
chance to pay off your home loan in monthly installments. If the full payment of the amount of default is not made within
THIRTY.FIVE (35) DAYS, we also intend to immediately start a lawsuit to foreclose on your mortgaged property.
YOU MAY BE EUGIBLE FOR FINANCIAL ASSISTANCE WHICH CAN SAVE YOUR HOME FROM FORECLOSURE
AND HELP YOU MAKE FUTURE MORTGAGE PAYMENTS.
The Commonwealth of Pennsylvania's Homeowner's Emergency Mortgage Assistance program may be able to
help you. Read the following notice to find out how the prog~m works.
La notificacion en adjunto 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 imnediatamerate llamando a esfa
agencia (Pennsylvania Housing Finance Agency) sin cargos' al numero mencionado arriba. Usted puede ser
elegible para un prestamo del programa llamado "Homeowner's Emergency Mortgage Assistance Program" el
cual puede salVar su casa de la penfida del derecho a redimir su hipoteca.
You may be eligible for financial assistance that will prevent foreclosure on your mortgage if you comply with the
provisions of the, Homeowners' Emergency Mortgage Assistance Act of 1983 (the' "Acti. You may be eDgible for
emergency temporary assistance if your default has been caused by circumstances beyond your control, you have a
reasonable prospect of resuming your mortgage payments, and if you meet other etigibility requirements established by
the Pennsylvania Housing Finance Agency. Please read all of this Notice. It contains ao explanation of your rights.
Under the Act, you are entiUed to a temporary stay of foreclosure on your mortgage for thirty (30) days from the date of
this Notice. During that time you must arrange and attend a "face-to-face" meeting with a representative of this lender, or
with a designated consumer credit counse6ng agency. The purpose of this meeting is to attempt to work out a
repayment plan. or to otherwise settle your delinquency. This meeting must occur in the next thirty (30) days.
Please write your loan number on all checks and correspondence,
BREACHPA
4116736-2
Martha H Robinder
253 Bullshead Road
$1,149.35 AS OF 12/01/2000
P.O, Box 10219
Van Nuys, CA 91410-0219
1111'11I.11.1111...111I.'1.1111111111111111111"1.111.11...11.1
411673620001149350114935
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HUO-Approved Counseling Agencies - Pennsylvania
.
If you attend a face-to-face meeting- with this lender, or with a consumer credit counseling agency identified ilf this notice,
no further proceeding in mortgage foreclosure may take place for thirty (30) days after the date of this meeting. The
name, address and telephone number of our ~epresentative is: COUNTRYWIDE, 6400 Legacy Drive, Piano, Texas
72567, Telephone Number: 1-800..669-6654, Extension 7556.
The names and addresses of designated consumer credit counseling agencies are shown on the attached sheet It is
only necessary to schedule one face-to-face meeting. You should advise Counbywide of your intentions immediately.
If you have tried and are unable to resolve this problem at or after your face-to-face meeting, you have the right to apply
for. financial assistance from the Homeowners' Emergency Mortgage Assistance Fund. In order to do this, you must fill
out, sign and file a_ completed Homeowners' Emergency Assistance Application with one of the designated consumer
cred'lt" counseling agencies listed on the attachment. An crpprrcation for assistance may only be obtained from a
consumer credit counsefing agency. The consumer credit counseling agency wiD assist you in filling out your application
and win submit your completed application to the Pennsylvania Housing Finance Agency. Your application must be filed
or posbnarked within_thirty (30) days of your face-to-face meeting.
Available funds for emergency mortgage assistance_ are very limited. They will be disbursec. by the Agency
under the eligibility criteria established by the Act
It is extremely important that you file your application promptly. If you do nat do so, or if you do not follow the other time
periods set forth in this letter, foreclosure may proceed against your home immediately. It is extremely important that your
application is accurate and complete in every respect.
The Pennsylvania Housing Finance Agency has sixty (60) days to make a decision after it receives your application.
During that additional time, no fo..-ectasure proceedings will he pursued against you if you have met the time requirements
set forth above. You will be notified direcUy by fuat Agency of its decision on your application.
The Pennsylvania Housing Finance Agency is located at 2101 North Front Street, Post Office Box 8029, Hanisburg,
Pennsylvania 17105. Telephone No. 1-717-780-3800 or 1-800-342-2397 (toll free number). Persons with impaired
hearing can caD 1-800-342-2397.
If the mortgage is foreclosed, your mortgaged property WIll be sold by the Sheriff to payoff the mortgage debt If you
cure th~ de~ult before _we begin legal proceedings against you, you will still have to pay the reasonable attorney's fees
actually incurred, up to $50.00. However, if legal proceedings are started against you, you will have to pay the reasonable
attorney's fees even if they are over $50.00. Any attorney's fees will be added to whatever you owe us, which may also
include our reasonable costs. If you cure this default within the thirty-five day period, you will not be required to pay the
attorney's fees. YOU HAVE THE RIGHT TO REINSTATE AFTER ACCELERATION AND THE RIGHT TO ASSERT IN
THE FORECLOSURE PROCEEDING THE NON-EXISTENCE OF A DEFAULT OR ANY OTHER DEFENSE YOU
MAY HAVE TO ACCELERATION AND FORECLOSURE.
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(Rule of Civil Procedure No, 236) - Revised
IN THE COURT OF COMMON PLEAS OF'"em.tBIi!RLAND COUNTY, PENNSYLVANIA
CIVIL ACTION - LAW
Countrywide Home Loans, Inc.
, Plaintiff
Vs.
NO. 01-1248-Civil Term
Donald M. Robinder
, Defendant(s)
Notice is given that a Judgment in the above captioned
matter has been entered against you on May If ,2001.
~~(J~"r~~UTY
If you have any questions concerning this matter please
Jo
At
Goldbeck, Jr.
for Plaintiff
contact:
**THIS FIRM IS A DEBT COLLECTOR ATTEMPTING TO COLLECT A DEBT AND ANY
INFORMATION OBTAINED WILL BE USED FOR THAT PURPOSE. IF YOU HAVE
PREVIOUSLY RECEIVED A DISCHARGE IN BANKRUPTCY, THIS IS NOT AND SHOULD
NOT BE CONSTRUED TO BE AN ATTEMPT TO COLLECT A DEBT, BUT ONLY
ENFORCEMENT OF A LIEN AGAINST PROPERTY. **
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GOLDBECK McCAFFERTY & McKEEVER
By: Joseph A. Goldbeck, Jr.
Attorney I.D. #16132
Suite 500 - The Bourse Bldg.
111 S. Independence Mall East
Philadelphia, PA 19106
(?-1 c;) 627-11?-?-
ATTORNEY FOR PLAINTIFF
Countrywide Home Loans, Inc.
7105 Corporate Drive, PTX B-35
P1ano, TX 75024-3632
Vs.
Donald M. Robinder
253 Bu11shead Road
Newville, PA 17241
CUMBERLAND COUNTY
COURT OF COMMON PLEAS
CIVIL DIVISION
NO 01-1248-Civi1 Term
Martha H. Robinder (Deceased)
PRAECIPE FOR JUDGMENT FOR FAILURE TO
ANSWER AND ASSESSMENT OF DAMAGES
TO THE PROTHONOTARY:
Kindly enter judgment in favor of the Plaintiff and against
Donald M. Robinder, Defendant for failure to file an Answer to Plaintiff's
Complaint within 20 days (or 60 days if defendant is the United States of
America) from the date of service of the complain and for foreclosure and sale
of the mortgaged premises, and assess Plaintiff's damages as follows:
As set forth in Complaint
Interest - 3/1/01 - 5/15/01
Late Charges
Escrow Debit
TOTAL
$75,744.14
$ 926.44
$80.19
.$.
$75,744.14
I hereby certify that (1) the addresses of the Plaintiff and Defendant ar,
as shown above, and (2) that notice has been given in accordance with Rule
237.1, copy attached.
Goldbeck, Jr.
for Plaintiff
DATE:
may II, ..JrY.>!
'ND'(r ~
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PRO PROTHY
DAMAGES ARE HEREBY ASSESSED AS
I hereby certify that the above names are correct and that the
precise residence address of the judgment creditor is 7105 Corporate Drive,
PTX B-35, PIano, TX 75024-3632 and that the name and last known address of
the Defendant is:
Donald M. Robinder,
253 Bullshead Road, Newville, PA 17241
Martha H. Robinder (Deceased)
oldbeck, Jr.
r Plaintiff
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TO, DONALD M. ROBINDER
253 Bullshead Road
Newville, PA 17241
COUNTRYWIDE HOME LOANS INC.
7105 Corporate Drive
PTX B-35
PIano, TX 75024-3632
Plaintiff
vs.
DONALD M. ROBINDER AND MARTHA H.
ROBINDER (Mortgagor(s))
(Record Owner(s))
253 Bullshead Road
Newville, PA 17241
Defendant(s)
IN THE COURT OF COMMON PLEAS
OF CUMBERLAND COUNTY
CIVIL ACTION - LAW
ACTION OF MORTGAGE FORECLOSURE
Term
No. 01-1248 CIVIL TERM
THIS LAW FIRM IS A DEBT COLLECTOR AND WE ARE ATTEMPTING TO COLLECT A
DEBT OWED TO OUR CLIENT, ANY INFO~TION OBTAINED FROM YOU WILL BE USED
FOR THE PURPOSE OF COLLECTING THE DEBT.
TO: DONALD M. ROBINDER
253 Bullshead Road
Newville, PA 17241
DATE OF THIS NOTICE: March 30, 2001
IMPORTANT NOTICE
YOU ARE IN DEFAULT BECAUSE YOU HAVE FAILED TO ENTER A WRITTEN
APPEARANCE PERSONALLY OR BY ATTORNEY AND FILE IN WRITING WITH THE COURT
YOUR DEFENSES OR OBJECTIONS TO THE CLAIMS SET FORTH AGAINST YOU. UNLESS
YOU ACT WITHIN TEN (10) DAYS FROM THE DATE OF THIS NOTICE, A JUDGMENT
MAY BE ENTERED AGAINST YOU WITHOUT A HEARING AND YOU MAY LOSE YOUR
PROPERTY OR OTHER IMPORTANT RIGHTS. YOU SHOULD TAKE THIS NOTICE TO A
LAWYER AT ONCE. IF YOU DO NOT HAVE A LAWYER OR CANNOT AFFORD ONE, GO TO
OR TELEPHONE THE FOLLOWING OFFICE TO FIND OUT WHERE YOU CAN GET LEGAL
HELP:
Cumberland County Bar Association
2 Liberty Avenue, Carlisle, PA
(800) 990-9108
/s/ JOde?"- -A. (joldteck. Jr.
GOLDBECK McCAFFERTY & McKEEVER
BY, Joseph A. Goldbeck, Jr., Esq.
Attorney for Plaintiff
Suite 500 - The Bourse Bldg.
111 S. Independence Mall East
Philadelphia, PA 19106
215-627-1322
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GOLDBECK, MCCAFFERTY & MCKEEVER
By: Joseph A. Goldbeck, Jr,
Attorney I.D. #16132
Suite 500-The Bourse Bldg.
111 S. Independence Mall East
Philadelphia, PA 19106
(215) 6/.7-132::!
ATTORNEY FOR PLAINTIFF
COURT OF COMMON PLEAS
CIVIL DIVISION
Countrywide Home Loans, Inc.
Vs.
No. 01-1248-Civil Term
Donald M. Robinder
Martha H. Robinder (Deceased)
CUMBERLAND COUNTY
VERIFICATION OF NON-MILITARY SERVICE
JOSEPH A. GOLDBECK, JR" ESQUIRE, hereby verifies that he is
attorney for the Plaintiff in the above-captioned matter, and that on
information and belief, he has knowledge of the following facts, to
wit:
(a) that the defendant is not in the Military or Naval
Service of the United States or its Allies, or otherwise within the
provisions of the Soldiers' and Sailors' Civil Relief Act of Congress
of 1940, as amended,
(b) that defendant Donald M. Robinder, is over 18 years of
age, and resides at 253 Bullshead Road,Newville, PA 17241.
This statement is made subject to the penalties of 18 Pa.
C.S. Section 4904 relating to unsworn falsification to authorities,
May 16, 2001
. GOLDBECK, JR.
for Plaintiff
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Plaintiff
CUMBERLAND COUNTY
COURT OF COMMON PLEAS
CIVIL DIVISION
Vs.
Donald M. Robinder
Martha H. Robinder (Deceased)
Defendant(s)
NO. 01-1248-Civi1 Term
AFFIDAVIT PURSUANT TO RULE 3129.1
Count~ide Home Loans. Inc., Plaintiff in the above action, by
its attorney, Joseph Goldbeck, Jr" Esquire, sets forth as of the date
the Praecipe for the Writ of Execution was filed the following
information concerning the real property located at
253 Bu11shead Road, Newville. PA 17241.
1. Name and address of owner(s) or reputed owner (s):
Name Address (if address cannot be reasonably
ascertained, please so indicate)
Donald M. Robinder 253 Bullshead Road
Newville. PA 17241
Martha H. Robinder (Deceased)
2, Name and address of defendant(s) in the judgment:
Name
Address (if address cannot be reasonably
ascertained, please so indicate)
Sl>.MF. AS ABOVE
3. Name and address of every judgment creditor whose judgment is a
record lien on the real property to be sold:
Name
Address (if address cannot be reasonably
ascertained, please so indicate)
Hl:mlil
4. Name and address of the last recorded holder of every mortgage of
record:
Name
Address (if address cannot be reasonably
ascertained, please so indicate)
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5. Name and address of every other person who has any record
lien on the property:
Name
Address (if address cannot be reasonably
ascertained, please so indicate)
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6. Name and address of every other person who has any record
interest in the property and whose interest may be affected by the
sale:
Name
Address (if address cannot be reasonably
ascertained, please so indicate)
Cumberland County Dept. of
Domestic Relations
P.O. Box 320
Carlisle. PA 17013
Pa D~t. of Public Welfare
Bureau of Child S~ort Enforcement
Health and Welfare Bldg. Room 432
P.O. Box 2675
Harrisburg. PA 17105
Commonwealth of PA
Bureau of Individual Tax
Inheritance Tax Division
Att: John Murphy
6th Floor. Strawberry Square
Dept. 280601
Harrisburg. PA 17128
Internal Revenue Service
Federated Investors Tower
l3~ Floor. Ste. 1300
1001 Liberty Avenue
Pittsburgh. PA 15222
Dept. of Public Welfare
PPL Casualty Unit
Estate Recovery Program
P.O. Box 8486
willow Oak Building
Harrisburg, PA 17105-8486
7. Name and address of every other person of whom the
plaintiff has knowledge that has any interest in the property
that may be affected by the sale:
Name
Address (if address cannot be reasonably
ascertained, please so indicate)
~
I verify that the statements made in this affidavit are true and
correct to the best of my personal knowledge or information and belief.
I understand that false statements herein are made subject to the
penalties of 18 Pa. C.S. #4904 relating to unsworn falsification to
authorities.
May 16, 2001
. Goldbeck, Jr.
for Plaintiff
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GOLDBECK, MCCAFFERTY & MCKEEVER
By: Joseph A. Goldbeck, Jr.
Attorney I.D. #16132
Suite 500-The Bourse Bldg.
111 S. Independence Mall East
Philadelphia, PA 19106
(?1 <;) h27-J ~??
ATTORNEY FOR PLAINTIFF
COURT OF COMMON PLEAS
Countrywide Home Loans, Inc.
Vs.
CUMBERLAND COUNTY
CIVIL DIVISION
NO. 01-1248-civil
Term
Donald M. Robinder
Martha H. Robinder (Deceased)
r.F.R'f'TFH~A'f'TON
JOSEPH A. GOLDBECK, JR" ESQUIRE, hereby states that he is the
attorney for the Plaintiff in the above captioned matter and that the
premises are not subject to the provisions of Act 91 because it is:
( ) an FHA Mortgage
( ) non-owner occupied
( ) vacant
(X) Act 91 procedures have been fulfilled
This certification is made subject to the penalties of 18 Pa. C.S.
~ 4904 relating to unsworn falsification to authorities.
Jo
At
. Goldbeck, Jr,
for Plaintiff
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GOLDBECK McCAFFERTY & McKEEVER
By: Joseph A. Goldbeck, Jr.
Attorney I,D. #16132
Suite 500 - The Bourse Bldg.
111 S. Independence Mall East
Philadelphia, PA 19106
(?1 C;) 627-11??
ATTORNEY FOR PLAINTIFF
Countrywide Home Loans, Inc.
CUMBERLAND COUNTY
COURT OF COMMON PLEAS
CIVIL DIVISION
Plaintiff
Vs.
Donald M. Robinder
Martha H. Robinder (Deceased)
Defendant(s)
NO.Ol-1248-Civil Term
NOTICF. OF SHERIFF'S SAT,F. OF REAl, F.STATF.
TO: Donald M. Robinder
253 Bullshead Road
Newville, PA 17241
THIS FIRM IS A DEBT COLLECTOR ATTEMPTING TO COLLECT A DEBT
AND ANY INFORMATION OBTAINED WILL BE USED FOR THAT PURPOSE.
IF YOU HAVE PREVIOUSLY RECEIVED A DISCHARGE IN BANKRUPTCY,
THIS IS NOT AND SHOULD NOT BE CONSTRUED TO BE AN ATTEMPT TO
COLLECT A DEBT, BUT ONLY ENFORCEMENT OF A LIEN AGAINST
PROPERTY.
Your house (real estate) at 253 Bullshead Road. Newville. PA
17241. is scheduled to be sold at the Sheriff's Sale on S~tember 5.
~ at 10:00 a.m., in Cumberland County, Cumberland County Courthouse,
Commissioners Hearing Room, 200 Floor, Carlisle, PA 17013 to enforce the
court judgment of S75.744.14 obtained by Countrywide Home Loans. Inc.
(the mortgagee) against you.
NOTICE OF OWNER'S RIGHTS
YOU MAY BE ABLE TO PREVENT THIS SHERIFF'S SALE
To prevent this Sheriff's Sale, you must take immediate action:
1. The sale will be cancelled if you pay to the mortgagee the
Back payments, late charges, costs and reasonable attorneys
Fees due. To find out how much you must pay, you may call:
(215\ 627-1322
2. You may be able to stop the sale by filing a petition asking the
Court to strike or open the judgment, if the judgment was
improperly entered. You may also ask the Court to postpone the
sale for good cause.
3. You may also be able to stop the sale through other legal
proceedings.
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You may need an attorney to assert your rights. The sooner you
contact one, the more chance you will have of stopping the sale. (See
notice on page two on how to obtain an attorney.)
YOU MAY STILL BE ABLE TO SAVE YOUR PROPERTY AND YOU HAVE OTHER RIGHTS
EVEN IF THE SHERIFF'S SALE DOES TAKE PLACE.
1. If the Sheriff's
to the highest bidder.
1:<] <;) fi/.7-1322
Sale is not stopped, your property will be sold
You may find out the price bid by calling
2. You may be able to petition the Court to set aside the sale if
the bid price was grossly inadequate compared to the value of your
property.
3. The sale will go through
full amount due in the sale.
may call the Sheriff's office
only if the buyer pays the Sheriff the
To find out if this has happened, you
at (717) 240-fi390
4. If the amount due from the Buyer is not paid to the Sheriff, you
will remain the owner of the property as if the sale never happened.
5. You have the right to remain in the property until the full amount
due is paid to the Sheriff and the Sheriff gives a deed to the buyer.
At this time, the buyer may bring legal proceedings to evict you.
6. You may be entitled to a share of the money which was paid for
your house. A proposed schedule of distribution of the money bid for
your house will be prepared by the Sheriff within 30 days of the Sale.
This schedule will state who will be receiving that money. The money
will be paid out in accordance with this schedule unless exceptions
(reasons why the proposed distribution is wrong) are filed with the
Sheriff within ten (10) days after the posting of the Schedule of
Distribution.
7. You may also have other rights and defenses, or ways of getting
your home back, if you act immediately after the sale.
YOU SHOULD TAKE THIS PAPER TO YOUR LAWYER AT ONCE. IF YOU DO NOT HAVE
A LAWYER OR CANNOT AFFORD ONE, GO TO OR TELEPHONE THE OFFICE LISTED
BELOW TO FIND OUT WHERE YOU CAN GET LEGAL HELP.
Cumberland County Bar Association
2 Liberty Avenue
Carlisle, PA 17103
(800) 990-9108
Legal Services, Inc.
8 Irvine Row
Carlisle, PA 17103
(717) 243-9400
.
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PRAECIPE FOR WRIT OF EXECUTION - (MORTGAGE FORECLOSURE)
P.R.C.P. 3180-3183
Countrywide Home Loans, Inc.
Plaintiff
COURT OF COMMON PLEAS
CUMBERLAND COUNTY, PA
Vs.
NO: 01-1248-Civil Ter.m
Donald M. Robinder
Martha H. Robinder (Deceased)
Defendant(s)
PRAECIPE FOR WRIT OF EXECUTION
(MORTGAGE FORECLOSURE)
TO THE OFFICE OF THE PROTHONOTARY:
Issue writ of execution in the above matter:
Amount Due
Interest from 5/15/01 to sale date
at $12.45 per diem
Total
$75,744.14
$
$
and Costs
i:'
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i"
ph Goldbeck, Jr.
S te O-The Bourse Bldg.
111 S. Independence Mall East
Philadelphia, PA 19106
Attorney for Plaintiff
Note: Please attach description of property.
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ALL THAT CERTAIN tract ofland situate in North Newton Township, Cumberland
County, Commonwealth of Pennsylvania, more particularly bounded and described as
follows:
BEGINNING at a point, a comer post, at lands now or formerly of John Hostetter; thence
by lands now or formerly of John Hostetter, North 37 degrees 59 minutes 51 seconds
West 203.56 feet to a comer post; thence by same South 54 degrees 05 minutes 55
seconds West 142.02 feet to a comer post; thence by same North 36 degrees 35 minutes
56 seconds West 211.27 feet to a comer post; thence by same North 48 degrees 23
minutes 30 seconds East 316.31 feet to a comer post; thence by same South 39 degrees
43 minutes 39 seconds East 267.17 feetto a comer post at the edge of an existing lane;
thence by same South 46 degrees 30 minutes 26 seconds West 99.00 feet to an iron pin;
thence by same South 36 degrees 06 minutes 06 seconds East 173.25 feet to a post;
thence by same South 58 degrees 45 minutes 55 seconds West 83.28 feet to a comer post,
the place of BEGINNING.
Tax parcel #30-08-0593-038
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GOLD~ECK.~CCAFFERTY & McKEEVER
BY: Joseph A. Goldbeck, Jr.
Attorney I.D.#16132
Suite 500 - The Bourse Bldg.
111 S. Independence Mall East
Philadelphia, PA 19106
215-627-1322
Attorney for Plaintiff
COUNTRYWIDE HOME LOANS INC.
7105 Corporate Drive
PTX B-35
PIano, TX 75024-3632
Plaintiff
vs.
DONALD M. ROBINDER AND
MARTHA H. ROBINDER
253 Bul1shead Road
Newville, PA 17241
Defendant
IN THE COURT OF COMMON PLEAS
OF CUMBERLAND COUNTY
CIVIL ACTION - LAW
ACTION OF MORTGAGE FORECLOSURE
Term
No. 01-1248 CIVIL TERM
CERTIFICATE OF SERVICE
PURSUANT TOPa.R.C.P. 3129.2(c) (2)
Joseph A. Goldbeck, Jr., Esquire, Attorney for Plaintiff, hereby
certifies that service on the Defendants of the Notice of Sheriff Sale was
made by:
( ) Personal Service by the Sheriff's Office/competent adult (copy of
return attached) .
lC) Certified mail by Joseph A. Goldbeck, Jr. (original green Postal
return receipt attached) .Dokol\<.D Ro61f1fDcR.....
Certified mail by Sheriff's Office.
Ordinary mail by Joseph A. Goldbeck, Jr., Esquire to Attorney for
Defendant(s) of record (proof of mailing attached) .
Acknowledgment of Sheriff's Sale by Attorney for Defendant(s) (proof
of acknowledgment attached) .
Ordinary mail by Sheriff's Office to Attorney for Defendant(s) of
record.
IF SERVICE WAS ACCOMPLISHED BY COURT ORDER.
( ) Premises was posted by Sheriff's Office/competent adult (copy of
return attached).
certified Mail & ordinary mail by Sheriff's Office (copy of return
attached) .
Certified Mail & ordinary mail by Joseph A. Goldbeck, Jr. (original
receipt(s) for Certified Mail attached).
Pursuant to the Affidavit under Rule 3129 (copy attached), service on all
lienholders (if any) has been made by ordinary mail by Joseph A. Goldbeck,
Jr., Esquire (copies of proofs of mailing attached).
The undersigned understands that the stateme
penalties provided by 18 P.S. Sectio 904.
are subject to the
submitted,
~FFERTY & McKEEVER
A. Goldbeck, Jr.
r Plaintiff
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GOLDBECK McCAFFERTY & McKEEVER
BY: Joseph A. Goldbeck, Jr.
Attorney I.D.#16132
Suite 500 - The Bourse Bldg.
111 S. Independence Mall East
Philadelphia, PA 19106
215-627-1322
Attorney for Plaintiff
COUNTRYWIDE HOME LOANS INC.
7105 Corporate Drive
PTX B-35'.
PIano, TX 75024-3632
IN THE COURT OF COMMON PLEAS
OF CUMBERLAND OUNTY
Plaintiff
CIVIL A ION - LAW
vs. :ACTION OF MORTGAGE FORECLOSURE
DONALD M. ROBINDER AND MARTHA H. Term
ROBINDER (Mortgagor(s) and No. 01-1248 CIVIL TERM
Record Owner(s))
253 Bullshead Road
Newville, PA 17241
Defendant(s)
SUGGESTION OF DEATH
It is respectfully suggested that Defendant MARTHA H.
ROBINDER is deceased, having departed this life on December 27,
2000. Accordingly, the title vests soley in DONALD M. ROBINDER,
cCAFFERTY & McKEEVER
h A. Goldbeck, Jr.
for Plaintiff
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qountrywide Home Loans, Inc.
Plaintiff
CUMBERLAND COUNTY
COURT OF COMMON PLEAS
CIVIL DIVISION
Vs.
Donald M. Robinder
Martha H. Robinder (Deceased) NO. 01-1248-Civil Term
Defendant(s)
S"ppL(mCAITJ't-LAFFIDAVIT PURSUANT TO RULE 3129.1
Countrywide Home Loans, Inc., Plaintiff in the above action, by
its attorney, Joseph Goldbeck, Jr., Esquire, sets forth as of the date
the Praecipe for the Writ of Execution was filed the following
information concerning the real property located at
253 Bullshead Road. Newville. PA 17241.
1. Name and address of owner(s) or reputed owner (s):
Name Address (if address cannot be reasonably
ascertained, please so indicate)
Donald M. Robinder 253 Bullshead Road
Newville. PA 17241
Martha H. Robinder (Deceased)
2. Name and address of defendant(s) in the judgment:
Name
Address (if address cannot be reasonably
ascertained, please so indicate)
SAME AS ABOVE
3. Name and address of every judgment creditor whose judgment is a
record lien on the real property to be sold:
Name
Address (if address cannot be reasonably
ascertained, please so indicate)
Hone
4. Name and address of the last recorded holder of every mortgage of
record:
Name
Address (if address cannot be reasonably
ascertained, please so indicate)
Hone
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5. Name and address of every other person who has any record
lien on the property:
Name
Address (if address cannot be reasonably
ascertained, please so indicate)
NQna
6. Name and address of every other person who has any record
interest in the property and whose interest may be affected by the
sale:
Name
Address (if address cannot be reasonably
ascertained, please so indicate)
Cumberland County Dept. of
Domestic Relations
P.O. Box 320
Carlisle. PA 17013
Pa Dapt. of Public Welfare
Bureau of Child S~port Enforcement
Health and Welfare Bldg, Room 432
P.O. Box 2675
Harrisbl1rg. PA 17105
Commonwealth of PA
Bureau of Individual Tax
Inheritance Tax Division
Att: John Murphy
6th Floor. Strawberry SqIlare
Dept. 280601
Harrisbl1rg. PA 17128
Internal Revenue Service
Federated Investors Tower
13~ Floor. Ste. 1300
1001 Liberty Avenl1e
Pittsburgh. PA 15222
Dept. of Public Welfare P.O. Box 8486
PPL Casualty Unit Willow Oak Building
Estate Recovery Program Harrisburg, PA 17105-8486
,
1\ /3 K I po So" 3.>0
L/l1 t+N e 0 Ol"" mEA-L 'Wutc.. o-ler, P It- I q 3 [j 1- 035,.6
7. Name and address of every other person of whom the
plaintiff has knowledge that has any interest in the property
that may be affected by the sale:
Name
Address (if address cannot be reasonably
ascertained, please so indicate)
NQna
I verify that the statements made in this affidavit are true and
correct to the best of my personal knowledge or information and belief.
I understand that false statements herein are made subject to the
penalties of 18 Pa. C.S. #4904 relating to unsworn falsification to
authorities.
May 16, 2001
. Goldbeck, Jr.
for Plaintiff
i 7106 4575 1294 3042 8853
1.' TOpONALD M. gOi3INriER
253 SuI/shead Road
j Newville, PA 17241 '
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CUM8ERLAND
SENDER:
REFERENCE:
GOLDBECK MCCAFFERTY & MCKEEVER'
May 15, 1998
ROBINDER,DONALD
CWD-1070
'f!1 5/01
M. 1
: PS Form 3800 June 200 .
RETURN Postaga
RECEIPT Certified Fee
SERVICE
Return ~eceipt Fee
I Restricted Deliverv
Total Postage & Fees ......-:--.....
I . ~"'^ ~
! US Postal Servjce POSThJ~e.l</o~,~~t,
i Receipt for
! ~(". )~
>- '...J' s-
i Certified Mail U:l >
I:; ~
j \ V:. . "
No Jnsurance (.overage Provided ,.......-...--~~f ,,'
i Do Not Use for International Mail ..~'
...-...-.---_.-.-._~-~_. . .. ^ ..-- ~ - . - ~
,_~__.,.....________"'........'l.---.---.-.-.----~_.~_...__.~._.___OM
I T'T IIII
D. I d' address diffeTtlnt from item 11
If YES, enter delivery address betClW:
0_
[;JNo
3. Service "TYpe CERTIFIED MAIL
4. Restricted Delivery? (Extra Fee)
1. ArtiCle Addressed to:
,DYes
'J:
DONALD M. ROSINDER
253 Bullshead ROad,
Newvllle, PA 17241
CUMBERLAND
RE<<OBINDER,DONALDM.1 CWif-.f&ro91 5/d1'~DER: GOlilBECK MCCAFFER1Y & MCKEEVER. May 15; "."
PS Form 31.111, June 2000 Domestic Return Receipt
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Countrywide Home Loans, Inc.
In The Court of Common Pleas of
Cumberland County, Pennsylvania
Writ No. 2001-1248 Civil Term
VS
Donald M. Robinder and Martha H.
Robinder (deceased)
R. Thomas Kline, Sheriff, who being duly sworn according to law, states this writ
is returned STAYED pursuant to instructions from Attorney Joseph A. Goldbeck, Jr.
Sheriffs Costs:
Docketing
Surcharge
Posting Handbills
Law Library
Prothonotary
Share of Bills
Mileage
Levy
Advertising
Certified Mail
Poundage
Postpone Sale
Law Journal
Patriot News
30.00
20.00
15.00
.50
1.00
25.66
17.78
15.00
15.00
2.39
11.92
228.20
225.60
$608.05 paid by attorney
09-20-0 I
Sworn and SUbSCri:,o,before me . .;;~/~~,,< ~
This 1M- day oflYUdu , ( .
r\ . R. Thomas Kline, Sh.. er...iff
2001, A.D.~ {l ~ /!ftj, BY ()Irlvj~
Prothonotary R~e Deputy
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th... 3 YO /3
~ 11'1/30
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Countrywide Home Loans, Inc.
Plaintiff
CUMBERLAND COUNTY
COURT OF COMMON PLEAS
CIVIL DIVISION
Vs.
Donald M. Robinder
Martha H. Robinder (Deceased)
Defendant(s)
NO. Ol-1248-Civil Term
AFFIDAVIT PURSUANT TO RULE 3129.1
Countrywide Home Loans, Inc., Plaintiff in the above action, by
its attorney, Joseph Goldbeck, Jr., Esquire, sets forth as of the date
the Praecipe for the Writ of Execution was filed the following
information concerning the real property located at
253 Bullshead Ro~d, Newville. PA 17241.
1. Name and address of owner(s) or reputed owner (s):
Name Address (if address cannot be reasonably
ascertained, please so indicate)
Donald M. Robinder 253 Bullshead Road
Newville, PA 17241
Martha H. RobindAr (Deceased)
2. Name and address of defendant(s) in the judgment:
Name
Address (if address cannot be reasonably
ascertained, please so indicate)
SAME AS ABOVE
3. Name and address of every judgment creditor whose judgment is a
record lien on the real property to be sold:
Name
Address (if address cannot be reasonably
ascertained, please so indicate)
None
4. Name and address of the last recorded holder of every mortgage of
record:
Name
Address (if address cannot be reasonably
ascertained, please so indicate)
None
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5.
Name and address of every other person who has any record
lien on the property:
Name
Address (if address cannot be reasonably
ascertained, please so indicate)
:tl.Qne
6, Name and address of every other person who has any record
interest in the property and whose interest may be affected by the
sale:
Name
Address (if address cannot be reasonably
ascertained, please so indicate)
Cumberland County Dept. of
Domestic Relations
P.O. Box 320
Carlisle. PA 17013
Pa Dept. of Public Welfare
Bureau of Child Support Enforcement
Health and Welfare Bldg. Room 432
P.O. Box 2675
Harrisburg. PA 17105
6th Floor. Strawberry SQ}lare
Dept. 280601
Harrisburg. PA 17128
Commonwealth of PA
Bureau of Individual Tax
Inheritance Tax Division
Att: John Murphy
Internal Revenue Service
Federated Investors Tower
13~ Floor. Ste. 1300
1001 Liberty Avenue
Pittsburgh. PA 15222
Dept. of Public Welfare
PPL Casualty Unit
Estate Recovery Program
P.O. Box 8486
willow Oak Building
Harrisburg. PA 17105-8486
7. Name and address of every other person of whom the
plaintiff has knowledge that has any interest in the property
that may be affected by the sale:
Name
Address (if address cannot be reasonably
ascertained, please so indicate)
:tl.Qne
I verify that the statements made in this affidavit are true and
correct to the best of my personal knowledge or information and belief.
I understand that false statements herein are made subject to the
penalties of 18 Pa. C.S. #4904 relating to unsworn falsification to
authorities.
o
May 16, 2001
. Goldbeck, Jr.
for Plaintiff
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GOLDBECK McCAFFERTY & McKEEVER
By: Joseph A. Goldbeck, Jr.
Attorney I.D. #16132
Suite 500 - The Bourse Bldg.
111 S.Independence Mall East
Philadelphia, PA 19106
(215) 6/.7c] 3/./.
ATTORNEY FOR PLAINTIFF
Countrywide Home Loans, Inc.
Plaintiff
CUMBERLAND COUNTY
COURT OF COMMON PLEAS
CIVIL DIVISION
Vs.
Donald M. Robinder
Martha H. Robinder (Deceased)
Defendant(s)
NO.01-1248-Civil Term
NOTTeR OF SHERIFF' S Sl'-T,F. OF RRl'-T. ESTl'-TR
TO: Donald M. Robinder
253 Bullshead Road
Newville, PA 17241
THIS FIRM IS A DEBT COLLECTOR ATTEMPTING TO COLLECT A DEBT
AND ANY INFORMATION OBTAINED WILL BE USED FOR THAT PURPOSE.
IF YOU HAVE PREVIOUSLY RECEIVED A DISCHARGE IN BANKRUPTCY,
THIS IS NOT AND SHOULD NOT BE CONSTRUED TO BE AN ATTEMPT TO
COLLECT A DEBT, BUT ONLY ENFORCEMENT OF A LIEN AGAINST
PROPERTY.
Your house (real estate) at 253 Bul1shead Road. Newville. PA
17241, is scheduled to be sold at the Sheriff's Sale on September 5.
2QUl at 10:00 a.m., in Cumberland County, Cumberland County Courthouse,
Commissioners Hearing Room, 2nd Floor, Carlisle, PA 17013 to enforce the
court judgment of $75.744.14 obtained by COlLntrywide Home Loans, Inc.
(the mortgagee) against you.
NOTICE OF OWNER'S RIGHTS
YOU MAY BE ABLE TO PRRVENT THIS SHERIFF'S SALE
To prevent this Sheriff's Sale, you must take immediate action:
1. The sale will be cancelled if you pay to the mortgagee the
Back payments, late charges, costs and reasonable attorneys
Fees due. To find out how much you must pay, you may call:
(215) 627-1322
2. You may be able to stop the sale by filing a petition asking the
Court to strike or open the judgment, if the judgment was
improperly entered. You may also ask the Court to postpone the
sale for good cause.
3. You may also be able to stop the sale through other legal
proceedings.
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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 $HERIFF'S SALE DOES TAKE PLACE.
1. If the Sheriff's
to the highest bidder.
(7.15) (127-] 322
Sale is not stopped, your property will be sold
You may find out the price bid by calling
2. You may be able to petition the Court to set aside the sale if
the bid price was grossly inadequate compared to the value of your
property.
3. The sale will go through
full amount due in the sale.
may call the Sheriff's office
only if the buyer pays the Sheriff the
To find out if this has happened, you
at (717) 7.40-(1390
4. If the amount due from the Buyer is not paid to the Sheriff, you
will remain the owner of the property as if the sale never happened.
5. You have the right to remain in the property until the full amount
due is paid to the Sheriff and the Sheriff gives a deed to the buyer.
At this time, the buyer may bripg legal proceedings to evict you.
6. You maybe entitled to a share of the money which was paid for
your house. A proposed schedule, of distribution of the money bid for
your house will be prepared by the Sheriff within 30 days of the Sale.
This schedule will state who will be receiving that money. The money
will be paid out in accordance with this schedule unless exceptions
(reasons why the proposed distr;Lbution is wrong) are filed with the
Sheriff within ten (10) days after the posting of the Schedule of
Distribution. .
7. You may also have other rights and defenses, or ways of getting
your home bacj<, .if you act immediately after the sale.
YOU SHOULD TAKE THIS PAPER TO YOUR LAWYER AT ONCE. IF YOU DO NOT HAVE
A LAWYER OR CANNOT AFFORD ONE, GO TO OR TELEPHONE THE OFFICE LISTED
BELOW TO FIND OUT WHERE YOU CAN GET LEGAL HELP.
Cumberland County Bar Association
2 Liberty Avenue
Carlisle, PA 17103
(800) 990-9108
Legal Services, Inc.
8 Irvine Row
Carlisle, PA 17103
(717) 243-9400
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ALL THAT CERTAIN tract ofland situate in North Newton Township, Cumberland
County, Commonwealth of Pennsylvania, more particularly bounded and described as
follows:
BEGINNING at a point, a comer post, at lands now or formerly of John Hostetter; thence
by lands now or formerly of John Hostetter, North 37 degrees 59 minutes 51 seconds
West 203.56 feet to a comer post; thence by same South 54 degrees 05 minutes 55
seconds West 142.02 feet to a comer post; thence by same North 36 degrees 35 minutes
56 seconds West 211.27 feet to a comer post; thence by same North 48 degrees 23
minutes 30 seconds East 316.31 feet to a comer post; thence by same South 39 degrees
43 minutes 39 seconds East 267.17 feet to a comer post at the edge of an existing lane;
thence by same South 46 degrees 30 minutes 26 seconds West 99.00 feet to an iron pin;
thence by same South 36 degrees 06 minutes 06 seconds East 173.25 feet to a post;
thence by same South 58 degrees 45 minutes 55 seconds West 83.28 feet to a comer post,
the place of BEGINNING.
Tax parcel #30-08-0593-038
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WRIT b~,~~~tUTION and/or ATTACHMENT
COfx\MONWEAlTH OF PENNSYLVANIA)
COUNTY OF CUMBERLAND)
NO. 01-1248 CIVIL 1F 'TERn
CIVIL ACTION - LAW
TO THE SHERIFf'0F
Cumberland
COUNTY:
To satil\fythe debt, interest and costs due Countrvwide HOlle Loans, Inc.
PLAINTIFF(S)
from Donal<l M. Robinder and Martha H. Robinder, 253 Bullshead Road, Newville, PA 17241
(1) You are directed to levy upon the property olthe defendant(s) and to sell
DEFENDANT(S)
See Leqa1 Description
(2) You are also directed to attach the property of the defendant(s) not levied upon in the possession of
'..:'
GARNISHEE(S) as follows:
and to notny the garnishee(s) that: (a) an attachment has been iSSl!ed; (b) the garnishee(s) is/are erijpined from paying any
debt to or for the account of the defendant(s) and from' deiivering aliy property of the defendant(~). or otherwise disposing
thereof;
(3) If property ofthe defendant(s) not levied upon an subjectto attachment is found in the possession of anyone other
than a named garnishee, you are directed to notify him/her that he/she has been added as a garnishee and is enjoined as above
stated.
Due Prothy
Other Costs
$.50
$1.00
Amount Due $75,744.14
frati5/15/01 to' sale 'date at
Interest -<> 12 4J d' et1
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Atty's Comm %
Atty Paid $129.68
Plaintiff Paid
L.L.
Dale:
May 18, 2001
Curtis R. Long
Prothonotary, Civil Division
--.by' kJr;- ~ >E!_7p~. /
Deputy
REQUESTING PARTY:
Name
Address:
Joseph A. Goldbeck, Jr.
SUlte ~uu - The l:lOursel:!lag.
111 ~ looependen-:-e M"ll F,,,,,t-
Philadelphia, PA 19106
Attorney for: Plaintiff
Telephone:
Supreme Court ID No,
214-627-1322
16132
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interest in the real prmv:,,-hr situ:lfe:d fn. 1) 6L:il.. Il~ -c~
Cumberland County, Pa.,~(\()WY12f1Cl numbered as: ~5.::S ~c.d (oed
1:R.-Wv1..f.b. and mort fully de.~oo Exhibit II A" filed with
this writ and by this referenoi'\'1rated herein.
l1ate: f1. "1 i2 3. ;} 00 I
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THE PATRIOT NEWS
THE SUNDAY PATRIOT NEWS
Proof of Publication
Under Act No. 587, Approved May 16, 1929
Commonwealth of Pennsylvania, County of Dauphin} ss
James L. Clark being duly sworn according to law, deposes and says:
That he Is the Acounts Receivable Manager of The Patriot News Co., a corporation organized and existing
under the iaws of the Commonwealth of Pennsylvania, with its principal office and place of business at 612 to 818
Market Street, in the City of Harrisburg, County of Dauphin, State of Pennsylvania, owner and publisher of Th e
Patriot-News and The Sundav 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 24th and 31st day(s} of July and the 7th
day(s) of August 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 behall of The Patriot-News Co. aforesaid by virtue and pursuant to a resolution unanimously passed and
adopted severally by the stockholders and board of directors of the said Company and subsequently duly recorded in
the office for the Recording of Deeds in and for said County of Dauphin in M1ellaneous Book "M",
Volume 14, Page 317. ~
PUBLICATION
COPY
SALE#17
...,-
Sworn to and sub ri
Notarial Seal / //
Terry 1.. Russell, Notary p.ubirc /
Harrisburg. Dauphin coffntY
My Com""sslon Expires June 6, 2002 N 'TARY PUBLIC
Member, PennsYNania Association of ~commission expires June 6, 2002
REAL esTATE SALE No. 17
...=,.=.~Writ No. 2001-1248
_ __ Civil Term
~'Coun-tryWide -Home
Loans, Inc.
~_ _ vs
Donald M. Robinder
~ ' Martha H. Roblnder
. _~_(Doceased)
AIty: Joseph />.. Goldbeck, Jr.
DESCRIPTION
CUMBERLAND COUNTY SHERIFFS OFFICE
CUMBERlAND COUNTY COURTHOUSE
CARLISLE, PA. 17013
ALL THAT. CERTAIN tr.:l.ct of land siltiat~ in
",~}.~orth N~1Q.n Towl1ship, Cu.ml?erland County,
~-'t$nrlTronwc-a]th of Pennsylvania. more
-- rfuhicuTiirryllpuildcd and ck~cribcd as follow~:
~~Jlli.ylNt-:1N.J:i;!.t a point,-a comer post. a[ lands
ltow . or formerly of John Hostetter; thence by
. lands' now..or fo~rly of John Hostetter, North
37 degrc~s"'59 minU{~ 51 ~onds W~st ~03~~6
. feet to 'a coiner post; thence by S<lmc South. 54
- dc(!rees 05 minutes 55 ~ccon(EWest 14::!.02 fect.
'to a .:;omer post; thence~by same North 36 l.k:grces .,. . .
35' rninutes 56 St,X'onds Wes1 ~1L27 feet to a Publisher s Receipt for AdvertiSing Cost
_ comer post~' thence by same North 48 degrees ::!3.. .
=:roi.TIQtes 30 seconds East 316.31 fce! to a comer ,., publisher of The Patnot-News and The Sundav Patnot-News, newspapers of general
"p~fC\T1qlC.~!I s~l.nc South. Jy..".dS.~3cs. ...3 be receipt of the aforesaid notice and publication costs and certifies that the same have
r--mmutcs 39'Seconds fast 207,17 leet to a comer
~. po~i at lh~"cdgc of an c:d,ting: lanc: thence by ,
.sanlc Soutl1-:+6 degrees 30 minutes :6 ..,.::conds
We~t 99.00 Jeet to an iron pin; thence by ~ame
SOUth ~_Jcgre~'s 06 minutes 06 seconds. East
173.~.kct to" a post; t~nce by same So~n 5'&
deg:ret:'s45minule~55sccond, \\'es183.28fet:llo.
a .comer pOSt. the place of BEmNMNG.
Tax Parcel #30-08-0593-038.
Statement of Advertising Costs
To THE PATRIOT-NEWS CO., Dr.
For publishing the notice or publication attached
hereto on the above staled dates
Probating same Notary Fee(s)
Total
$
$
$
224.10
1.50
225.60
By....................................................................
REAL ESTATE SALE NO. 17
Writ No. 200]-]248 Civil
Countrywide Home Loans. Inc.
vs.
Donald M. Robinder and
Martha H. Robinder (Deceased)
Atty.: Joseph A Goldbeck. Jr.
ALL TIIAT CERTAIN tract of land
situate In North Newton Township.
Cu1nberland County. Commonwealth
of Pennsylvania, more particularly
bounded and described as follows:
BEGINNING at a point. a corner
post. at lands now or formerly of
John Hostetter; thence by lands
now or formerly of John Hostetter.
North 37 degrees 59 minutes 5] sec-
onds West 203.56 feet to a carner
past; thence by same South 54 de-
gree. 05 min1.!tes 5li ~~COrnl' West
142.02 feet to a comer post; thence
by same North 36 degrees 35 min-
utes .56 seconds West 211.27 feet
to a corner post; thence by same
North 48 degrees 23 minutes 30
seconds East 316.31 feet to a cor-
ner post; thence by same South 39
degrees 43 minutes 39 seconds East
267.17 feet to a comer post at the
edge of an existing lane; thence by
same South 46 degrees 30 minutes
26 seconds West 99.00 feet to an
iron pin; thence by same South 36
degrees 06 minutes 06 seconds
East 173.25 feet to a post: thence
by same South 58 degrees 45 min-
utes 55 seconds West 83.28 feet to
a corner post, the place of BEGIN-
NING.
Tax parcel #30-08-0593-038.
...
1 . ~ l _ l _
~
"llf---O"'J/~--."",
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,
VlZ:
JULY 20, 27, AUGUST 3, 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.
~~
Roger . Morgenthal, EdItor
,
SWORN TO AND SUBSCRIBED before me this
3 day of AUGUST. 2001
Not
.. NOTARIACSEAt.
LOIS E.. SNYDER. NoIaryPublIc
Cam.reBonl Cumbeltancl ColInIY
My CclmH 'Tllni Expi/II MIn:h S;2Oll5