HomeMy WebLinkAbout01-1545 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.,
F/K/A AMERICA'S WHOLESALE LENDER
7105 Corporate Drive
PTX B.35
Plano, TX 75024.3632
plaintiff
IN THE COURT OF COMMON PLEAS
OF CUMBERLAND COUNTY
CIVIL ACTION . LAW
vs.
:ACTION OF MORTGAGE FORECLOSURE
~Ol -/!:q; C:u: L Term
No.
JOSEPH R. BARRETT AND
BARBARA T. BARRETT
(Mortgagor(s) and Real Owner(s))
CIVIL ACTION: MORTGAGE
FORECLOSURE
1654 Holtz Road
Enola, PA 17025
Defendant(s)
THIS LAW FIRM IS A DEBT COLLECTOR AND WE ARE ATTEMPTING
TO COLLECT A DEBT OWED TO OUR CLIENT. ANY INFORMATION
OBTAINED FROM YOU WILL BE USED FOR THE PURPOSE OF
COLLECTING THE DEBT.
NOTICE
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. SI DESEA DEFENDERSE CONTRA LAS QUEJAS PERESENTADAS, ES
ABSOLUTAMENTE NECES5ARIO 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 PUNTa DE VISTA
DE USTED Y CUALQUIER OBJECCION CONTRA LAS QUEJAS EN ESTA DEMANDA.
RECUERDE; 51 USTED 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 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.
SI NO CONOCE A UN ABOGADO, LLAME AL "LAWYER REFERENCE SERVICE" (SERVICIO DE REFERENCIA DE ABOGADOS),
215-238-6300.
Cumberland County Bar Association
2 Liberty Avenue, Carlisle, PA
(800) 990-9108
Legal Services Inc.
8 Irvine Row, Carlisle, PA 17013
(717) 243-9400
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COMPLAINT IN MORTGAGE FORECLOSURE
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1. Plaintiff is COUNTRYWIDE HOME LOANS INC., F/K/AAMERICA'S
WHOLESALE LENDER, 7105 Corporate Drive, PTX B-35, Plano, TX
75024-3632.
2. The name(s) and address (es) of the Defendant(s) is/are
JOSEPH R. BARRETT, 1654 Holtz Road, Enola, PA 17025 and BARBARA T.
BARRETT, 1654 Holtz Road, Enola, PA 17025, who is/are the
mortgagor(s) and real owner(s) of the mortgaged property
hereinafter described.
3. On May 31, 1995, mortgagor(s) made, executed and
delivered a mortgage upon the premises hereinafter described to
COUNTRYWIDE HOME LOANS INC., F /K/A AMERICA'S WHOLESALE LENDER,
which mortgage is recorded in the Office of the Recorder of Deeds
of Cumberland County in Mortgage Book 1266, Page 41. The mortgage
has not been assigned. These documents are matters of public record
and are incorporated herein by reference in accordance with
Pennsylvania Rule of Civil Procedure 1019(g).
4. The premises subject to said mortgage is described as
attached.
5. The mortgage is in default because monthly payments of
principal and interest upon said mortgage due September 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 8/ 1/00
through 2/28/01 at 8.750%
Per diem interest rate at $11.01
Attorney's Fee at 5%
of Principal Balance
Late Charges 9/ 1/00- 2/28/01
Monthly late charge amount at $25.16
Costs of suit and Title Search
Escrow Balance Credit
Monthly Escrow amount $163.73
$ 45,933.71
2,323.11
2,296.69
150.96
560.00
$ 51,264.47
286.02
$ 50,978.45
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(sl 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 $50,978.45, together with interest at the rate of
$11.01, 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:
GOLDBEC
BY: Jos
Attorne
dM
cCAF & McKEEVER
h A. oldbeck, Jr., Esq.
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 to
Date: 3/;./rY I
authorities.
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LelIal Descrintion:
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ALL THAT CERTAIN tract of land situate in the Township of Hampden, County of Cumberland and Commonwealth of
Pennsylvania, more partleniarly bounded and described according to survey plan of Bartman and Associates, Inc., Engineers
and Surveyors, dated June 6, 1994.
BEGINNING at a point in the northern tine of land now or formerly of Lawrence T, Joyce at its intersection with the eastern
line of land now or formerly of Nore Ann Fraker; thence north 25 degrees 21 minutes 58 seconds east, along said line of
Fraker lands ,190 feet to a point; thenc,e soutIi 75 degrees 36 minutes 25 seconds east 441.38 feet to a point in the southwest
por.tion of a priva~ road; then~e soutIi 13 degrees 05 minulies 01 seconds east, a dIStance of 185 feet to a pipe in the northern
line of land now or fonnerly' of Daisy Z. Sampson;' thence north 77 degrees 38 minutes 31 seconds west, 424.10 feet to an pin in
the eastern line ofJand n,01\'or filnnerly' ofL&wreDcc T. Joyce aforesaid; thence north 78 degrees 38 minutes 03 secOnds west,
along said line of Joyce lands 138.92 feet to. a point, the place of BEGINNING. '
BEING TIJE SAME P'REMISES whichCtinton A. Oris, Executor of the Last Will and Testament of Warren C. Ortis, late, by
deed dated September dated september 7, 1994 and recorded in the Recorder of Deeds Office in and for Cumberland County,
PAin Deed Book HI, Page 126, granted and conveyed unto Joseph R. Barrett, his. beirs and assigns. . '
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Send Correspondence to:
P.O. Box 10221
Van Nuys, CA 91410-0221
Send payments to:
P.O. Box 10219
Van /lJuys, CA 91410-0219
Octo~er 31, 2000
EXHIBIT A
Certified Mail No.
Return Receipt Requested
Regular Man
Joseph R Barrett
1654 Holtz Road
Enol., PA 17025-0000
Counllywide Loan # 4373649
Property Address:
1654 Holtz Road
EnoIa, PA 17025-0000
!NOTICE OF INTENT TO FORECLOSE
,
YOUR HOME LOAN IS I~ DEFAULT FOR THE REASONS SET FORTH IN THIS NOTICE.
YOU MUST TAKE ~CTION TO SAVE YOUR HOME FROM FORECLOSURE.
Countrywide Home Loans,lnc. {hereinafter QCountrywidej services your home loan. Your home loan is in serious default
becal,JSe you have not made yourlrequired payments. The total amount now required to reinstate your loan as of the
date of this letter is as follows: !
1
09/0112000 i 10/3112000
09/0112000,10/3112000
Uncollected posts:
Monthlv Payments:
Late Charaes:
other Charaes:
@
@
$667,00
$25.16
$1,334,00
$50,32
$20,00
TOTAL DUE: $1.404.32
You roay cure this defaUltwithin~RTY-F1VE (35) DAYS attlle date of this letter, bY. p. aying to us the above amount of
$1,404.32, plus any additional mo Iy payments, late charges, fees and other applicable charges which may fall due
durin9 this period. Such payme must be in the form of certified check, cashie~s check or money order, and made
payable to Countrywide at P.O. Bo 10221, Van Nuys, CA 91410-0221. If your check or other payment is returned to US
for in6Ufficient funds or for any 0 r reason, you Will not have cured your defauft. No extension of time to cure will be
grantt!d due to a returned payme : '
If you do not cure this defaUftwith~" THIRTY-FNE (35) DAYS, we will accelerate the payments due on your home loan.
This means whatever is owing on e original amount borrowed Will be considered due immediately and you may lose the
chanc:e to payoff your home loan monthly instaUments. If the fun payment of the amount of default is not made within
THIRTY-FIVE (35) DAYS, we also intend to immediately start a lawsuft to foreclose on your mortgaged property,
. YOU MAY BE EUGIBLE FOR FI~ANCIAL ASSISTANCE WHICH CAN SAVE YOUR HOME FROM FORECLOSURE
AND HELP YOU MAKE FUTUREIMORTGAGE PAYMENTS.
The Commonwealth of PennsvaJania's Homeowner's Emergency Mortgage Assistance program may be able to
help you. Read the following ~ce to find out how the program works.
!
La notificacion en adjunto es desuma importancia, pues afecta su derecho a continuar viviendo en su casa. 5i
no CQmprende el contenido d esta notificacion obtenga una traduccion inmediatamente llamando a esta
agencia (Pennsylvania Housing 'Finance. Agency) sin _cargos aI nUmero mencionado amDa. Usted pUede ser
elegible para un p...tamo del p rame Ilamado "Homeowner's Emergency Mortgage Assistance Program" el
cual puede salvar su casa de Ia rdida del derecho a redimir su hipoteca.
You may be eligible for financia~, assistance that will prevent foreclosure on your mortgage if you comply with the
provisions of the Homeowners' ergency Mortgage Assistance Act of 1983 (the "Act"). You may be eligible for
emergency temporary assistance your default has been caused by circumstances beyQnd your control, you have a
reasonable prospect of resuming ur mortgage payments, and if you meet other eligibility requirements established by
the pennsylvania Housing Finance ency. Please read an of this Notice. It contains an explanation of your rights.
Under the Act, you are entitled to~' temporary stay of foreclosure on your mortgage for thirty (30) da. ys from the date of
this Notice. During that time you ust arrange and attend a "face-to-face" meeting with a representative of this lender, or
with tl designated consumer cr it counseling agency. The purpose of this meeting is to attempt to work out a
repayment plan, or to otherwise se, e your deDnquency. This meeting must occur in the next thirty (30) days.
~ write your loan number on all checks and correspondence.
BREACHPA
!4373649--5
JosephRBarrelt
1654 Holtz Road
$1,404.32 AS OF 10/31/2000
P.O. Box 10219
Van Nuys, CA 91410-0219
11.1'11I.11.111111.111I11111111111.1111111.11111111I.1111111.1
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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 in'this notice,
no fUrther proceeding in mortgage foreclosure may take place for thirty (30) days ami' the date of this meeting. The
narTIe, address and telephone number of our representative is: COUNTRYWIDE, 6400 LefJacy Drive, Piano, Texas
72567, Telephone Number: 1-800-869-8654, Extension 7556.
The names and addresses of designated consumer credit counsenng agencies are shown on th~ 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 fin
out. sign and file a completed Homeowners' Emergency Assistance Appfication with one of the designated consumer
ereart coWlSeling agencies 6sted on the attachment An appncation for assistance may only be obtained from a
co""urner credit counseling agency. The consumer credit counseling agency will asslst you in filling ou\ your application
and Will submit your completed application to the Pennsylvania Housing FlIlance Agency. Your apprlCation must be filed
or postmarked within thirty (30) days of your face-to-face meeting.
Available funds for emergency mortgage assistallCe 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 prompOy. If you do not do so, or if you do not follow the other time
peri~ds set forth in this letter, foreclosure may proceed against your home immeal8tely. It is extremely important that your
application is accurate and complete in every respect.
The Pennsylvania Housing Fmance Agency has sixty (60) days to make a decision after it receives your application.
During that adaltional time, no foreclosure proceedings will be pursued against you if you have met the time requirements
set forth above. You will be nolilied directly by that AgIWq 01 iIs decision on 'IOU' applica1ion.
The Pennsylvania Housing Finance Agency is located at 2101 North Front Street, Post Office Box 8029, Harrisburg,
Pennsylvania 17105. Telephone No. 1-717-78ll-3800 or 1-8llO-342-2397 (toll free number). Persons with impaired
hearing can call1-800-342-2397.
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 sbll have to pay the reasonable attorneys fees
actually incurred, up to $50.00. However, if legal proceedings are started against you, you wiD have to pay the reasonable
attomey's fees even if they are over $50.00. Any attorney's fees wiD 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
attomey's lees. VOU HAVE THE RIGHT TO REINSTATE AFTER ACCELERATION AND THE RIGHT TO ASSERT IN
THE FORECLOSURE PROCEEDING THE NON-EllISTENCE OF A DEFAULT OR ANY OTHER DEFENSE YOU
MAY HAVE TO ACCELERA1\ON AND FORECLOSURE.
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Send Correspondence to:
P.O. Box 10221
Van Nuys, CA 9141()'()221
Send Payments to;
P.O. Box 10219
Van Nuys, CA 91410-0219 ..
SXH\B\lA
October 31, 2000 ..
Certified Mail No.
Return Receipt Requested
Regular Mail
Barbara T Barrett
1654 Holtz Road
Enola, PA 17025-QOOO
Countrywide Loan # 4373649
Property Address:
1654 Holtz Road
Enola, PA 17025-0000
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. (hfn"einafter "Countrywidej 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 foDows:
MonthlY Payments:
Late Charaes:
other Charaes:
09101120001- 1013112000
09/0112000'- 10131/2000
Uncollected Costs:
@
@
$667,00
$25,16
$1,334.00
$50,32
$20,00
TOTAL DUE: $1,4lI4.32
You may cure this default within ~HIRTY..f1VE (35) DAYS of the date of this letter, by paying to us the aboye amount of
$1,404.32, plus any additional m<!'nthly payments, late charges, fees and other apprlCable charges which may faD 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, B~x 10221, Van Nuys, CA 91410-0221. ffyourcheck 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 wi\! be
granted due to a returned paymerit
If you do not cure this default with'm THIRTY-FIVE (35) DAYS, we will accelerate the payments due on your home loan.
This means whatever is owing on ~e original amount borrowed will be considered due immediately and yoU may lose the
chance to payoff your home loanlin monUtly instaDmen1s. If the full payment of the amount of default is not made within
THIRTY-fIVE (3&1 DAYS, we alsd intend to immediately start a lawsuij to toreclose on your mortgaged property.
" YOU MAY BE EUGIBLE FOR F1~CIAL ASSISTANCE WHICH CAN SAVE YOUR HOME FROM FORECLOSURE
AND HELP YOU MAKE FUTURIj MORTGAGE PAYMENTS.
~ The Commonwealth of Pennsylttania's Homeowne('s Emergency Mortgage Assistance program may be able to
help you. Read the following ~ice to find out how the program works.
La notificacion en adjunto es d~ suma importancia, pues afecta su derecho a continuar viviendo en su caSilI. Si
no comprende el contenido 1 esta notiflC8cion obtenga una traduccion inmediatamente Ilcpnando a esta
agencia (P. ennsytvania Housin Finance Agency) s_in cargos al nwnero mencionado, amba., UStec:l puede ser
e1egible para un prestamo del J'Ograma llamado "Homeowne(s Emergency Mortgage Assistance Program" el
cual puede salvar so casa de Ia ,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' ~mergency Mortgage Assistance Act of 1983 (the "Acf'). You may be eligible for
emergency temporary assistancei i your default has been caused by' circumstances beyond your control, you have a
reasonable prospect of resuming Your mortgage payments, and i you meet other eligibirlty requirements established by
the Pennsylvania Housing Finance Agency. Please read aD of this Notice. it contains an explanation of your rights.
Under the Act, you are entitled to ~ temporary stay of foreclosure on your mortgage for thirty (30) days from the date of
this Notice. During that time you rl;1ust arrange and attend a 'Tace-to-face~ meeting with a representative of this lender, or
with a designated consumer cre~1t counsermg agency. The p1,UpOSe of this meeting is to attempt to work out a
repayment plan, or to otherwise setue your delinquency. This meeting must occur in the next thirty (30) days.
Please write your loan number on an checks and correspondence.
BREACHPA
4373649-5
Barbam T Barrett
1654 Holtz Road
$1,404.32 AS OF 10/31/2000
P.O. Box 10219
Van Nuys. CA 91410-0219
11.11111I11.1111111111111I111111I1.1111111.111I1111111111111.1
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HUD-Approved Counseling Agencies - Pennsylvania
I, If you attend a face-to-face meeting with this lender, or wiUl a consumer credit counse,ling agency identified in~this notice,
110 further proceeding in mortgage foreclosure may take place for thirty (30) days attar the date of this meeting. The
name, address and telephone number of our representative is: COUNTRYWIDE, 6400 Legacy Drive, Piano, Texas
12567, Telephone Number: 14lO0-6694lO54, Extension 7556.
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The names and addresses of designated consumer cre<fJl: counseling agencies are shown on the' attached sheet. It is
only necessary to schedule one face-la-face meeting. You should advise Counbywide ofyolD" intentions immediately.
II you have \lied and are unable I<> resolve \his problem at or after your face-k>-Ia<:e meeting, you have \he right I<> apply
for financial assistance from the Homeowners' Emergency Mortgage Assistance Fund. In order to do this, you must fiU
out, sign and file a compteted Homeowners' Emergency Assistance App6cation with one of the designated consumer
crecfJl: counseling agencies listed on the attachment. An appncation for assistance may only be obtained from a
consumer credit counseling agency. The consumer credit counsermg agency will assist you in filting out your application
and will subm~ your cornpIeled application I<> \he Pe~nia Hou.ing Finance Agency. Your appflCalion must be tiled
or postmarked within 1I1irly (30) days of your faClHD-lace meeting.
Available funds for emergency mortgage assistance are very limited. They will be disbursed by the Agency
.nder the eligibility criteria established by the Act
It is extremely important that you file your application promptly. ffyou 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
app6cation 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 win be pursued against you If you have met the time requirements
set forth above. You will be notified d"rrectly by that Agency of its decision on your application.
The Pennsylvania Housing Finance Agency is Iocall!d at 2101 Nor1h F'ont Stree~ Post Office Box 8029, Hanisburg.
Pennsylvania 17105. Telephone No. 1-717-780-3800 or 1-800-342-2397 (1<>11 free n.mber). Persons with impaired
hearing can caR 1-800-342-2397.
~ the morlgage is foreclosed, your mortgaged properly will be sold by 1I1e Sherilf to payoff the morlgage debt If you
cure the default before we begin legal proceedings against you, you will sti1I 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 lees even ~ 1hey are over $50.00. Any attorney's fees will be added I<> whatever you owe us, _ may also
il1clude'our reasonable costs. If you cure this default within the thirty-five day period, you will not be required to pay the
attorney's lees. 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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. 'CASE NO: 2001.01545 P
SHERIFF'S ,RETURN - REGULAR
..
COMMONWEALTH OF PENNSYLVANIA:
I
COUNTY OF CUMBERLAND
COUNTRYWIDE HOME LOANS INC
VS
BARRETT JOSEPH R ET AL
JASON VIORAL
, :Sheriff or Deputy Sheriff of
Cumberland County, Pennsylvania, who being duly sworn according to law,
says, the within COMPLAINT . MORT FORE
was served upon
BARRETT JOSEPH R
the
DEFENDANT
, at 0013:15 HOU~S, on the 22nd day of March
, 2001
at 1654 HOLTZ ROAD
ENOLA, PA 17025
by handing to
BARBARA BARRETT
a true and attested copy of COM~LAINT - MORT FORE
together with
NOTICE
and at the same time directing ~ attention to the contents thereof.
Sheriff's Costs:
Docketing
Service
Affidavit
Surcharge
18.00
9.30
.00
10.00
.00
37.30
so;n~4!
R. Thomas Kline
Oi3/23/2 0 0 1
dOLDBECK, MCCAFFERTY, MCKEEVER
Sworn and Subscribed to before
By:
(~~~;;::.::t>
11?eputy <theriff
, /
V
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me this Ol'i ~
day of
~ 2<J.o I A.D.
C}F/XJJeO )]",/;,. ~
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SHERIFF'S RETURN. REGULAR
~ASE NO: 2001-01545 P
,COMMONWEALTH OF PENNSYLVANIA:
COUNTY OF CUMBERLAND
COUNTRYWIDE HOME LOANS INC
VS
BARRETT JOSEPH R ET AL
JASON VIORAL
, Sheriff or Deputy Sheriff of
Cumberland County,Pennsylvania, who being duly sworn according to law,
says, the within COMPLAINT . MORT FORE
was served upon
BARRETT BARBARA T
the
DEFENDANT
, at 0013:15 HOURS, on the 22nd day of March
, 2001
at 1654 HOLTZ ROAD
ENOLA, PA 17025
by handing to
BARBARA BARRETT
a true and attested copy of COMPLAINT . MORT FORE
together with
NOTICE
and at the same time directing Her attention to the contents thereof.
Sheriff's Costs:
Docketing
Service
Affidavit
Surcharge
6.00
.00
.00
10.00
.00
16.00
;;i2~~c~t
R. Thomas Kline
03/23/2001
GOLDBECK, MCCAFFERTY, MCKEEVER
Sworn and subscribed to before
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me this ~9 ~ day of
By:
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Deputy Stferiff
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GOLDBECK, McCAFFERTY & McKEE~ER
Suite 500 - The Bourse Bldg.
111 S. Independence Mall East
P4iladelphia, PA 19106
215-627-1322
BY: MICHAEL T. MCKEEVER, ESQUIRE
Attorney I.D. #56129
Attorney for Plaintiff
COUNTRYWIDE HOME LOANS INC.,
F/K/A AMERICA'S WHOLESALE LENDER
7105 Corporate Drive
PTX B.35
PIano, TX 75024.3632
IN THE COURT OF COMMON PLEAS
OF CUMBERLAND COUNTY
vs.
Term
No. 01-1545 Civil Term
JOSEPH R. BARRETT, BARBARA T.
BARRETT, AND 1654 HOLTZ ROAD
(Mortgagor(s))
(Record Owner(s))
1654 Holtz Road
Enola, PA 17025
PRAECIPE TO pISCONTINUE AND END
TO THE PROTHONOTARY:
Kindly mark the above ca~e Discontinued and Ended upon
payment of your costs only. .
CK, JR., ESQUIRE
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