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Home My WebLink About01-03054 "~ 'I' "II" II ,. .'"',,1 '-",""",""4 l' "~~\:}" GOLDBECK McCAFFERTY & McKEEVER A PROFESSIONAL CORPORATION ATTORNEY'S AT LAW JOSEPH A. GOLDBECK, JR. GARY E. McCAFFERTY' MICHAEL T. McKEEVER' SENTRY OFFICE PLAZA SUITE 420 216 HADDON AVENUE WESTMONT, NJ 08108 (609) 858-2997 FAX (609) 858-2997 SUITE 500 THE BOURSE BUILDING 1 I I S. INDEPENDENCE MALL EAST PHILADELPHIA, PENNSYLVANIA 19106 (215) 627-1322 FAX (215) 627 7734 RENEE M. POZZUOLI-BUECKER' KRISTINA G. MURTHA' LESLIE E. PUlDA' LISA A. D' ANGELI* *PA&NJBAR PLEASE REPLY TO THE PHILADELPHIA OFFICE September 19,2002 Curt Long Prothonotary of Cumberland County 1 Courthouse Square Carlisle, PAl 70 13 RE: DOVENMUEHLE MORTGAGE CO. LP vs. PAUL A. RHEAUME No. 01-3054 Civil Term Dear Sir: Kindly take Judgment and issue the Writ of Execution and forward the same to the Sheriffs Office. Please return a copy of the enclosed pleadings to my office with your time stamp affixed thereto in the stamped, self-addressed envelope for this purpose. Thank you for your cooperation in this matter. JAG/ / L J~' _ _ I J - . <<':,1 ,~o; I' ." ,- ~'-"'~ ".,J,<, , l~fd GOLDBECK McCAFFERTY BY: Joseph A. Goldbeck, Attorney 1.D.#16132 Suite 500 - The Bourse Bldg. 111 S. Independence Mall East Philadelphia, PA 19106 215 - 62 7 -1322 Attorney for Plaintiff & McKEEVER Jr. DOVENMUEHLE MORTGAGE CO. LP 1501 Woodfield Road Schaumburg, IL 60173-4982 Plaintiff IN THE COURT OF COMMON PLEAS OF CUMBERLAND COUNTY CIVIL ACTION - LAW vs. :ACTION OF MORTGAGE FORECLOSURE PAUL A. RHEAUME (Mortgago~(s) and Real Owner(s)) Term ~. No. 01- .3CSV Coi( ~ CIVIL ACTION: MORTGAGE FORECLOSURE 15 W. Factory Street Mechanicsburg, PA 17055 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 othe~ claim or relief requested by the Plaintiff. You may lose money or property or other rights important to you. YOU SHoVLD 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. Cumberl~nd County Bar Association 2 Liber~Y Avenue, Carlisle, PA (800) 990-9108 Legal services Inc. 8 Irvin@ Row, Carlisle, PA 17013 (717) 2.B-9400 A V ISO LE RAN DEMANDADO A USTED EN LA CORTE. SI DESEA DEFENDERSE CONTRA LAS QUEJAS PERESENTADAS, ES ABSOLUTAMENTE NECESSARIO QUE USTED RESPONDA DENTRO DE 20 DIAS DESPUES DE SER SERVlDO 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. RECUERDS: 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 DERECH09 IMPORTANTES. LLEVE ESTA DEMANDA A UN ABOGADO IMMEDIATAMENTE. 81 NO CONOCE A UN ABOGADO, LLAME AL "LAWYER REFERENCE SERVICE" (SERVIC!O DE REFERENCIA DE ABOGADOS), 215 238-6300. Cumberl~nd County Bar Association 2 Liberty Avenue, Carlisle, PA (800) 990-9108 Legal services Inc. S Irvine Row, Carlisle, PA 17013 (717) 243-9400 ... 'U "1'1 'I , COMPLAINT IN MORTGAGE FORECLOSURE , ..,~ '_"-,C"\""'.'_; .~ 1. Plaintiff is DOVENMUEHLE MORTGAGE CO. LP, 1501 Woodfield Road, Schaumburg, IL 60173-4982. 2. The name(s) and address(es) of the Defendant(s) is/are PAUL A. RHEAUME, 15 W. Factory Street, Mechanicsburg, PA 17055, who is/are the mortgagor(s) and real owner(s) of the mortgaged property hereinafter described. 3. On April 21, 1994, mortgagor(s) made, executed and delivered a mortgage upon the premises hereinafter described to GMAC MORTGAGE CORP. OF PA, which mortgage is recorded in the Office of the Recorder of Deeds of Cumberland County in Mortgage Book 1209, Page 646. By Assignment of Mortgage recorded February 9, 1995, the mortgage was assigned to Plaintiff, which Assignment is recorded in Assignment of Mortgage Book No. 1474, Page 37. These documents are matters of public record and are incorporated herein by reference in accordance with Pennsylvania Rule of Civil Procedure 1019(g). 4. The premises subject to said mortgage is described as attached. 5. The mortgage is in default because monthly payments of principal and interest upon said mortgage due February 1, 2001, and each month thereafter are due and unpaid, and by the terms of said mortgage, upon default in such payments for a period of one month, the entire principal balance and all interest due thereon are collectible forthwith. 6. The following amounts are due on the mortgage: Principal Balance Interest from 1/ 1/01 through 5/31/01 at 8.000% Per diem interest rate at $12.92 Attorney's Fee at 5% of Principal Balance Late Charges 2/ 1/01- 5/31/01 Monthly late charge amount at $41.20 Costs of suit and Title Search Escrow Balance Monthly Escrow amount $357.72 $ 58,958.21 1,938.00 2,947.91 164.80 560.00 $ 64,568.92 $ 64,568.92 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 "I' J'\~ i I - '-' ",J--,;~I .""-' "'" -,<.'-";", '''' ';"', 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 $64,568.92, together with interest at the rate of $12.92, per day and other expenses incurred by the Plaintiff which are properly chargeable in accordance with the terms of the mortgage, and for the foreclos e and sale of the mortgaged premises. By: GOLD BY: oseph A. Goldbeck, Att rney for plaintiff ?L , ,,, ...-1 I. .~ < ~'"~-'; VERIFICATION I, Lynn Coady, as the representative of the Plaintiff corporation within named do hereby verify that I am authorized to and do make this verification on behalf of the Plaintiff corporation and the facts set forth in the foregoing Complaint are true and correct to the best of my lmowledge, information and belief. I understand that false statements therein are made subject to the penalties of 18 Pa. C.S. 4904 relating to unsworn falsification to authorities. .5 II? 10, -- , Date: ,-II " - , ~~1.~~/~~~1 1~:04 1J,/:'::..:l:..:::tf'::/tfb ), ! i n1-/I Jhl,,, I , .....aT..,.,""~~-'ii.~, ~eC IMt-OtouhIe.,...., ' 14"""'1...u._..lilllllo....._ . . i bi)l !lAllE THE i -:2.1>\- d4> .f ~'" \ of ou" to"G 01lI ih-rtl:nd tUm It'N-'\&'l'ed ninet.y four (1994) BETW/IIEN ~ ALD L. S1'OOER.. JR. and J~ J, S'l'ttUi$,; his ...ib, of th BoI;'QU9h ot: Mechanit;Gbul:'9. CI,l!llbetland Cooney, Penn""ylvan1e., I ! Il b 110"[;" F. 11,;;,(0. R€CORPEH OF Dci;OS . ..tt '.;iJ~IB(r,U,:li) COUNH.PA "9'1 APIl 2H AI'! 9 26 iK-tM!i8(t.T Grantdrs 1 .~. p~ A~ 1UiBAUMe. a ail'l91e: man, 'Of Mechanictbl),t"9. Cl.lmbt!-rland eoupty, ~nnsylvani., I i I Grantll'~ : WITNSSSETH. Uutl in c:on$it'l4'J'A~Wtt of sun SIX THOUSAND NINe HlJNDRED----------..- AND NO/1OO------~______~___~__~($66(900.00)--~---------------------~-~U4r., in. h/f.M paitt, t/l.lt "dctint. t>>/tt:t'B(1/ " .\M',bll ~l<<Ig"il. the! 'fdB Df'ltnw.rcs dq 1t.ct'6lJJf aratU Q.fJd cottv'v tf' ~M 14id gra.fl~et , I ALL THAT CBR.ltAINftract or pa'r:'eel of land situate on the !5OVth side of Weat ractoty St.r~, 4-to" WArd. in the E\orough of I'\eChanicsburgl Col.mty ot. C\.mIbedllnd end Stl!lte of p~ylvania, lYOre pa'tticulat'ly bounded anti l3escribed a3 follows: BEGINNING at eo ~int en the southern !in" of E'at;tQry Street, $a10 polnt. bell'\9 taUllut''\td ir\ '" southwest4!dy ditel;.tion t\lo hund~ slll.ty (2GO.OCn feet tr-om the aouthwc-dt COl;l1er at l!"ollCtot:y Street iJOO Market St:ceet; thencl!I l!01Jth 21 dllf9rey 2$ mi,-tutee east alOfl9 the western liM of lan& now Ot: eo~dy of Aa~on C. Kapp ~ distance of one hund~ed nineteeh and sixteen h~ndredthB (119.16) teet to ~ hub on the northe~ lin~ of a fifteen CI5.00) foot wide alley; th.nc~ SQ~~h 71 degree$ 33 Minutes We8t along Baid nQrthel;'n lin~ of alley A dt.tanoe bf ~l~ty-one (61.00) feet to a hub: then~e North 1& d~rees 21 minutes WeI.elt al0h9 the eaatern line ot lands nOlol or to[l!l@t='ly of Jchn H. Weigfi!'l, Jr., II dl'tancll' of OIle l1undred nineteen (119.00) fHt to .. hub on the scutherr'l Until of acr:ory StL"etO!t; l:hence Not't:h 71 aeqt:"ft:J 3) minutee $Ql!It alQng MI(l lK1uth.-m 11 ot hctory Street II': distanr;::e ot tlfty-fO\JC' and eight.y-thne h\1na't~thD (54.63~ feet; to a hub1 the potnt and Place of aEGINNING. RAVING thettlOh er~ted 11 1" stot:y' f~~ dwelling and detached fY:1!ltnlll 9l!11r~9. known and numbeee4 as U Wut I!'aoto-cy Stt'"t. i OODER AND SUW!CT~ ne.lIerthel@.!$I t.o 8$;lfeme:nUI t:estt'idions, r:tiSe~ation&. conditione and t'i~hta ot "ay of rOClon3. i SlUNG the Mtrre pr"'iae" which Eric 8. Hughes and Jean Hughes, h.is wit'e. by their deed datr:d Jlunl) 30, 1992, l!lnd recotded JUly 7, 19921 in ttle ottice of the Recorda-I:' of o.aleds. in and for Cumbet'1and County I in Dl!!ed Book T I volume 35, Pe.9'4! 606, 9"erlted and convey@d unto Donald [,. Stoner, Jr. arld'Jeanna 3. Stoner, ~i~ wife, prantOL"l!I ~ereln. - ~..,! ,.:~ ~'~ ;;{ ,-,~ ;.: l'!'~;; :;l M, ." i~ Y!tJ,ii! <o;n..;Jm ;\ tj!!;"'I";'!' 'f.~~'~" -, ,'. ,.-1 JY,i ~J ;\';; " f~ J !il. :T.' ., ~. 1;.; " ~. ~-. :':1 ~,t, '6' " .'. ~ :. :: " ;~. , '..', ... "\5 ~ <:.!" ':f#( ;:'\-1 t~. :t;. ". ~. .., ~ i~ ." i ti)oi ~./\A ., ',:rr I I i , , I I f8G i I ':.' ~~ l:! Ll ~?! I I ~~~ '" I... ;. ,. :.. ~ Q";;I-.' ,. tiui ...~~.. :~~$1lI I-'At:l'i:. ~.:l . . e , 02-03~Ol , l"'--~3LETTERWRITER ACTIVITY FOR MONTH OF 01-01 KEY""rl:ct:tfo VERS",052 TITLE""PA ACT 91 MORT PROP PTl L6~= OU09196312 LlNES-PER-PAGE..NO DATE=Ol-17 USER=DHQ COND!TIONS",O January 17, 2001 EXHIBIT A Paul A Rheaume 15 W Factory St Mechanicsburg PA 17055 Loan Number: 0009196312 Current LenderjServicer: Dovenmuehle Mortgage Inc. HOMEOWNER\S EMERGENCY MORTGAGE ASSISTANCE PROGRAM YOU MAY BE ELIGIBLE FOR FINANCIAL ASSISTANCE WHICH CAN SAVE YOUR HOME FROM FORECLOSURE AND HELP YOU MAKE FUTURE MORTGAGE PAYMENTS IF YOU COMPLY WITH THE PROVISIONS OF THE HOMEOWNER\S EMERGENCY MORTGAGE ASSISTANCE ACT OF 1983 (THE "ACT"), YOU MAY BE ELIGIBLE FOR EMERGENCY MORTGAGE ASSISTANCE: * IF YOUR DEFAULT HAS BEEN CAUSED BY CIRCUMSTANCES BEYOND YOUR CONTROL, * IF YOU HAVE A REASONABLE PROSPECT OF BEING ABLE TO PAY YOUR MORTGAGE PAYMENTS, AND * IF YOU MEET OTHER ELIGIBILITY REQUIREMENTS ESTABLISHED BY THE PENNSYLVANIA HOUSING FINANCE AGENCY. TEMPORARY_STAY_OF_FORECLOSURE - Under the Act, you are entitled to a temporary stay of foreclosure on your mortgage for thirty (30) days from the date of this Notice. During that time you must arrange and attend a "face-to-face" meeting with one of the designated consumer credit counseling agencies listed at the end-of this Notice. THIS MEETING MUST OCCUR WITHIN THE NEXT (30) DAYS. IF YOU DO NOT APPLY FOR EMERGENCY MORTGAGE ASSISTANCE, YOU MUST BRING YOUR MORTGAGE UP TO DATE. THE PART OF THIS NOTICE CALLED "HOW TO CURE YOUR MORTGAGE DEFAULT II , EXPLAINS HOW TO BRING YOUR MORTGAGE UP TO DATE. I <~~"~ <',-", -'l," ~, 'iL- PAGE 16,538 Ic FORM=LTRH PRINTER=PCTX SECURITY=l " 02-03-01.. f'JI"'''?)LETTERWRlTER ACTIVITY FOR MONTH OF 01-01 KEY",D"LJO VERS=052 TITLE=PA ACT 91 MORT PROP PTl L6~= 0009196312 DATE=Ol-17 USER=DHQ LlNES-PER-PAGE=NO OONDITIONS=O PAGE 2 OF 5 January 17, 2001 P A Rheaume CONSUMER CREDIT COUNSELING AGENCIES - If you meet with one of the consumer credit counseling agencies listed at the end of this Notice, the lender may NOT take action against you for thirty (30) days after the date of this meeting. The names, addresses and telephone numbers of designated consumer c~edit counseling agencies for the county in which the property is located are set forth at the end of this Notice. It is only necessary to schedule one face-to-face meeting. Advise your lender immediately of your intentions. APPLICATION FOR MORTGAGE ASSISTANCE - Your mortgage is in default for the reasons set forth later in this Notice (see following pages for specific information about the nature of your default.) If you have tried and are unable to ~esolve this problem with the lender, you have the right to apply eor financial assisance from the Homeowner\s Emergency Mortgage Assistance Program. To do so, you must fill out, sign and file a completed Homeowner\s Emergency Assistance Program Application with one of the designated consumer credit counseling agencies listed at the eAd of this Notice. Only consumer credit counseling agencies have applications for the program and they will assist you in submitting a complete application to the Pennsylvania Housing Finance Agency. Your application MUST be filed or postmarked within thirty (30) days af your face-to-face meeting. YOU MUST FILE YOUR APPLICATION PROMPTLY. IF YOU FAIL TO DO SO OR IF YOU DO NOT FOLLOW THE OTliER TIME PERIODS SET FORTH IN THIS LETTER, FORECLOSURE MAY PROCEED AGAINST YOUR HOME IMMEDIATELY AND YOUR APPLICATION FOR MORTGAGE ASSISTANCE WILL BE DENIED. AGENCY ACTION - Availabl@ funds for emergency mortgage assistance are very limited. They will be disbursed by the Agency under the eligibility criteria established by the Act. The pennsylvania Housing Finance Agency has sixty (60) days to make a decision after it receives your application. During tha~ time, no foreclosure proceedings will be pursued against you if yOU have met the time requirements set forth above. You will be notitied directly by the pennsylvania Housing Finance Agency of its decision on your Application. NOTE: IF YOU ARE CURRENfLY PROTECTED BY THE FILING OF A PETITION IN BANKRUPTCY, THE FOLLOWINt} PART OF THIS NOTICE IS FOR INFORMATION PURPOSES ONLY AND SHOULD NOT BE CONSIDERED AS AN ATTEMPT TO COLLECT THE DEBT. (If you have fjled bankruptcy you can still apply for Eme~gency Mortgage Assistance.) DL140 ,'-,,>, ,,~-~,,-,,;, ,-,- L J.~-' PAGE 16,539 Ic FORM=LTRH PRINTER=PCTX SECURITY=l ,"'" '"" ",,-I 02-03-01 . l>"-''''" LETTERWRITER ACTIVITY FOR MONTH OF 01-01 KEY~Dbtll VERS=046 TITLE",PA ACT 91 MORT PROP PT2 Ld~~ 0009196312 DATE~01-17 USER~DHO LlNES-PER-PAGE~NO CONDITIONS~O PAGE 3 OF 5 January 17, 2001 P A Rheaume HOW TO CURE YOUR MORTGAGE DEFAULT (Bring it up to date) . NATURE OF THE DEFAULT - The MORTGAGE debt held by the above lender on your property located at: 15 W Factory St Mechanicsburg PA 17055 IS SERIOUSLY IN DEFAULT because: A. YOU HAVE NOT MADE MONTHLY MORTGAGE PAYMENTS for the following months and the following amounts are now past due: (al Monthly payments from November 01, 2000 to present (at $ 861.90 per month) $ 2,509.96 (bl Previous late charges; $ 69.96 (e) Property Inspections; $ 33.53 (d) NSF Charges i $ .00 (e) Other Provisions of the mortgage obligation, if any; $ 69.96 (f) TOTAL AMOUNT OF (al (bl (el (d) and (e) REQUIRED AS OF THIS DATE: $ 2,613.45 YOU HAVE FAILED TO TAKE THE FOLLOWING ACTION (Do not use if not applicable) : HOW TO CURE THE DEFAULT - You may cure the default within THIRTY (30) DAYS of the date of this notice BY PAYING THE TOTAL AMOUNT PAST DUE TO THE LENDER WHICH IS $ 2,613.45, PLUS ANY MORTGAGE PAYMENTS AND LATE CHARGES WHICH BECOME DUE DURING THE THIRTY (30) DAY PERIOD. Payments must be made either by cashier\s check, certified check or money order made payable and sent to: ATTN: Collection Department LENDER NAME: Dovenmuehle Mortgage, Inc. ADDRESS: 1501 Woodfield Road, Suite 400 E, Schaumburg, IL 60173-4982 You can cure any other default by taking the following action within thirty (30) DAYS of the date of this letter. (Do not use if not applicable. ) J.4" i-;_ ,.,,;...' I .~~4f,v PAGE 16,540 Ic FORM~LTRH PRINTER~PCTX SECURITY=l H' _, ~ J 02-03-01. LbAN= ~09~'96312 LINES-PER-PAGE~NO DATE=01-17 USER~DHO CONDITIONS=O rr "~,LETTERWRITER ACTIVITY FOR MONTH OF 01-01 K2Y=D~11r1 VERS=046 TITLE=PA ACT 91 MORT PROP PT2 PAGE 4 OF 5 January 17, 2001 P A Rheaume IF YOU DO NOT CURE THE DEFAULT - If you 00 not cure the default within thirty (30) DAYS of the date of this Notice, the lender intends to exercise its rights to accelerate the mo~tgage debt. This means that the entire outstanding balance of this debt will be considered due immediately and you may lose the chance to pay the mortgage in monthly installments. If full payment of the total amount past due is not made within THIRTY (30) DAYS, the lender also intends to instruct its attorneys to start legal action to foreclose upon your mortgaged property. IF THE MORTGAGE IS FORECLOSED UPON - The mortgaged property will be sold by the Sheriff to payoff the mortgage debt. If the lender refers your case to its attorneys, but you cure the delinquency before the lender begins legal proceedings against you, you will still be required to pay the reasonable attorneY\9 fees that were actually incurred up to $50.00. However, if legal proceedings are started against you, you will have to pay all reasonable attorney\s fees actually incurred by the lender even if they exceed $50.00. Any attorney\s fees will be added to the amount you owe the lender, which may also include other reasonable costs. If you cure the default within the THIRTY (30) DAY period, you will not be required to pay attorney\s fees. OTHER LENDER REMEDIES - The lender may also sue you personally for the unpaid principal balance and all other svms due under the mortgage. RIGHT TO CURE THE DEFAULT PRIOR TO SHERIFF\S SALE - If you have not cured the default within THIRTY (30) DAY period and foreclosure proceedings have begun, you still have t~e right to cure the default and prevent the sale at any time up to one hour before the Sheriff\s Sale. You may do so by paying the total amount then past due, plus any late or other charges then due, reasonable attorney\s fees and costs connected with the foreclosure sale and any other costs connected with the Sheriff\s Sale as specified in writing by the lender and by performing any other requirements under the mortgage. Curing your default in the manner Bet forth in this notice will restore your mortgage to the same position as if you bad never defaulted. EARLIEST POSSIBLE SHERIFF\S SALE DATE - It is estimated that the earliest date that such a Sheriff\s Sale of the mortgaged property could be held would be approximately nine months from the date of this Notice. A Notice of the actual date of the Sheriff\s Sale will be sent to you before the sale. Of course, the amount needed to cure the default will increase the longer you wait. You may find out at any time exactly what the required payment or action will be by contacting the lender. DL141/DHO -""'-')--~ -,'!1 ]'iC':_', PAGE 16,541 Ie FORM=LTRH PRINTER=PCTX SECURITY~l j;!- 02-03-01_ 1"_ ')LETTERWRITER ACTIVITY FOR MONTH OF 01-01 KEY~DLl~2 VERS=066 TITLE=PA ACT 91 MORT PROP PT3 . LOAr= Ot09196312 DATE=01-17 USER=DHO LINES-PER-PAGE=NO CONDITIONS=O PAGE 5 OF 5 January 17, 2001 P A Rheaume HOW TO CONTACT THE LENDER: Dovenmuehle Mortgage, Inc. 1501 Woodfield Road Suite 400 East Schaumburg, IL 60173-4982 1-800-669-0340 Fax: 847-330-8032 Contact: Mr. Edward Bagdon EFFECT OF SHERIFF\S SALE - You should realize that a Sheriff\s Sale will end your ownership of the mortgaged property and your right to occupy it. If you continue to live in the property after the Sheriff\s Sale, a lawsuit to remove you and your furnishings and other belongings could be started by the lender at any time. ASSUMPTION OF MORTGAGE - You MAYor X MAY NOT transfer your home to a buyer or transferee who willa"SS1:l:me the mortgage debt, provided that all the outstanding payments charges and atorney\s fees and costs are paid prior to or at the sale and that the other requirements of the mortgage are satisfied. YOU MAY ALSO HAVE THE RIGHT * TO SELL THE PROPERTY TO OBTAIN MONEY TO PAY OFF THE MORTGAGE DEBT OR TO BORROW MONEY FROM ANOTHER LENDING INSTITUTION TO PAY OFF THIS DEBT. * TO HAVE THIS DEFAULT CURED BY ANY THIRD PARTY ACTING ON YOUR BEHALF. * TO HAVE THE MORTGAGE RESTORED TO THE SAME POSITION AS IF NO DEFAULT HAD OCCURRED, IF YOU CURE THE DEFAULT. (HOWEVER, YOU DO NOT HAVE THIS RIGHT TO CURE YOUR DEFAULT MORE THAN THREE TIMES IN ANY CALENDAR YEAR.) * TO ASSERT THE NONEXISTENCE OF A DEFAULT IN ANY FORECLOSURE PROCEEDING OR ANY OTHER LAWSUIT INSTITUTED UNDER THE MORTGAGE DOCUMENTS. * TO ASSERT ANY OTHER DEFENSE YOU BELIEVE YOU MAY HAVE TO SUCH ACTION BY THE LENDER. * TO SEEK PROTECTION UNDER THE FEDERAL BANKRUPTCY LAW. ^,- j !Ii~l':'" ~ , PAGE 16,542 " / le FORM=LTRH PRINTER=PCTX SECURITY=l ,"",~ 'I, "II '~J 02-03-01~ r-<~"'\LETTERWRITER ACTIVITY FOR MONTH KEY==OD-t(2 VERS==066 TITLE=PA ACT 91 MORT , .. WAN=' 06091~6312 LINES-PER-PAGE=NO DATE=Ol-17 USER=DHO CONDITIONS=O ACT 91 NOTICE DATE OF NOTICE: January 17, 2001 TAKE ACTION TO SAVE YOUR HOME FROM FORECLOSURE This_is_an_official_notice_that_the_mortgage_on-your_home_is_in_default, and_the_Iender_intends_to_forecloseo__Specific_information_about_the____ nature_of_the_default_is-provided_in_the_attached-pages. The_HOMEOWNER\S_MORTGAGE_ASSISTANCE_PROGRAM_(HEMAP}_may_be_able_ta_help to_save_your_home.__This_Notice_explains_how_the-program_warks. To see if HEMAP can help, you must MEET WITH A CONSUMER CREDIT COUNSELING AGENCY WITHIN 30 nAYS OF THE-DATE-OF THIS NOTICE. Take~this_Notice_with_you_when-you_meet=with=the_counseling Agency. The_name,_address_and-9hone_number_of_Consumer_Credit_Counseling Agencies_serving-your_County_are_listed_at_the_end_of_this_Notice. If_you_have_any_questions,_you_may_call_the_pennsylvania_Housing Finance_Agency_toll_free_at_l-BOO-342-2397.__(Persons_with_impaired hearing_can_call_(717)_7BO-IB69. This Notice contains important legal information. If you have any questions, representatives at the Consumer Credit Counseling Agency may be able to help explain it. You may also want to contact any attorney in your area. The local bar association may be able to help you find a lawyer. La notificacion en adjunto as de suma importancia, pues afecta su derecho a continuar vivendo en su casa. Si no comprende e1 contenido de esta notificacion obtenga una traduccion immediatamente llamanda esta agencia (pennsylvania Housing Finance Agency) sin cargos al numero mencionada arriba. Puedes ser elegible para un prestamo par el prograrna llamado "HOmeowner\s Emergency Mortgage Assistance program" e1 cula puede salvar su casa de la perdida del derecho a redimir eu hipateca. DL142 OF 01-01 PROP PT3 ~, . I.~ ~~-, , , : '" 'c;,. ',~~ "'-,- PAGE 16,543 Ie FORM=LTRH PRINTER=PCTX SECURITY=! ~iili!f!%l,@;JillJi_~"","i-1"';~r"'.-~rUfuh~'IN;,;;~))J!iHJiJiil:~iiiM~k~r;'x,,",";O~ *,""l;''';;c.\\\;.'ib6\.4>(~f-fuill:r,i{:ffi~ r~~~~~~:itiIillI!iili~~'"--";"" ~ "*8 . ' p "" ~ (Q ~ 9 ~ (t ~ h () 0 (') c:: C) ::?~ ",) 8 (g ut~il :z flirt ;;~ --~-- ...,.., .." .-i- T ...... .<-- ,; ........ ~ I 0~~~ 0) ...... !;( r <.. :r:) ~ c:: c:-: ...... """ =:? ::5 ~ p: "';:.C) '~~,2 $:() 1"- C~ ~ ~': !IV "_d- ~ E.:_ ::--.! :;~ c- .. co :'0 -<: . ~. : f Btb tt "0 ~.p ;10 rn.... . ~~~I ~~,\ ~, ;;t 3 ~ o~ ...... ~' ~1(f ~Jn;:,_:~~rJI]]Hl[tt~~,=,~>_~ ,~~""~_~,-,_e"'''_''~''_^f.~ . _ ~ ~~ "", ,_,~_~"_".~,,,", ~<. _ ,'~~ "". ~, , 'W_ . ,~. ~ " 1 c - ~,j _I j~", I, '"- <"-"'~..,,,;....,,"~, I ~ "'i"" SHERIFF'S RETURN - NOT FOUND CASE NO: 2001-03054 P COMMONWEALTH OF PENNSYLVANIA COUNTY OF CUMBERLAND DOVENMUEHLE MORTGAGE CO LP VS RHEAUME PAUL A R. Thomas Kline ,Sheriff or Deputy Sheriff, who being duly sworn according to law, says, that he made a diligent search and inquiry for the within named defendant, DEFENDANT RHEAUME PAUL A but was unable to locate Him in his bailiwick. He therefore returns the COMPLAINT - MORT FORE , NOT FOUND , as to the within named DEFENDANT , RHEAUME PAUL A ADDRESS IS VALID, BUT UNABLE TO LOCATE DEFT PRIOR TO EXPIRATION. EXPIRED 6/15/01 Sheriff's Costs: Docketing Service Not Found Surcharge 18.00 12.40 5.00 10.00 .00 45.40 mas Kllne iff of Cumberland County GOLDB K MCCAFFERTY & MCKEEVER 06/22/2001 Sworn and subscribed to before me this q"t:- day of ~ ~AD a. ~. pt; P 0 honotary I~ ,,-~--- 1-_1.._ IL I " "~-,, I . ~.O'l'. ',';ii 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. I HEREBY CERTiFY THAT THIS IS A TRUE AND r/;RRECT COpy OF THE OfilC iI\ii',L FILED DOVENMUEHLE MORTGAGE CO. LP 1501 Woodfield Road Schaumburg, IL 60173-4982 Plaintiff IN THE COURT OF COMMON PLEAS OF CUMBERLAND COUNTY CIVIL ACTION - LAW vs. :ACTION OF MORTGAGE FORECLOSURE PAUL A. RHEAUME (Mortgagor(s) and Real Owner(s)) Term ~ NO.OI-JCSY c?;(.)~l I~ CIVIL ACTION: MORTGAGE FORECLOSURE 15 W. Factory Street Mechanicsburg, PA 17055 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 80 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 propexty 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. c~mberland County Bar Association 2 Liberty Avenue, Carlisle, FA (800) 990-9108 Legal Services Inc. 8 Irvine Row, Carlisle, PA 17013 (117) 243-9400 A V ISO L~ RAN DEMANDADO A USTED EN LA CORTE. SI DESEA DEFENDERSE CONTRA LAS QUEJAS PERESENTADAS, ES ABSOLUTAMENTE NECESSARIO QUE USTED RESPONDA DENTRO DE 20 DIAS DESPUES DE SER SERVIDO CON ESTA DEMANDA Y AVISO. PARA DEFENDERSE ES NECESSARIO QUE USTED, 0 SU ABOGADO, REGISTRE CON LA CORTE EN FORMA ESCRITA, EL PUNTO DE VISTA DE USTED Y CUALQUlER OBJECCION CONTRA LAS QUEJAS EN ESTA DEMANDA. WCUERDE: SI USTED NO REPONnE A ESTA DEMANDA, SE PUEDE PROSEGUIR CON EL PROCESO SIN SU PARTICIPACION. ENTONCES, :LA COUTE PUEDE, SIN NOTIFlCARIO, DECIDIR A FAVOR DEL DEMANDANTE Y REQUERI~ QUE USTED CUMPLA CON TODAS LAS PROVISIONES DE ESTA DEMANDA. POR RAZON DE ESA DECISION, ES POSSIBLE QUE USTED PUEDA PERDER DINERO, PROPIEDAD U OTROS DERECHOS IMPORTANTES. LlJEVE ESTA DEMANOA A UN ABOGADO IMMEDIATAMENTE. sl NO CONOCE A UN ABOGADO, LLAME AL ltLAWYER REFERENCE SERVICE" (SERVICIO DE REFERENCIA DE ABOGADOS), 215-238-6300. c~mberland County Bar Association 2 Liberty Avenue, Carlisle, PA (flOO) 990-9108 TRUE copy FROM RECORD In TlI8timooy wileroo!, i 1...;" lHIW_my hand itM tN _ 04 said CWr! at Carlisle, PI. T~:~Y ~:~:~~ L~gal Services Inc. 8 Irvine Row, Carlisle, PA 17013 (117) 243-9400 --- _. .' ~ 1'_ '" "'",, '~- '" -'~'-" J' \ HEREBY C;::8TIFYTHATTHIS IS A TRUE ANC CORRECT copy OF THE OFiiOINAL FILED COMPLAINT IN MORTGAGE FORECLOSURE 1. Plaintiff is DOVENMUEHLE MORTGAGE CO. LP, 1501 Woodfield Road, Schaumburg, IL 60173-4982. 2. The name(s) and address(es) of the Defendant(s) is/are PAUL A. RHEAUME, 15 W. Factory Street, Mechanicsburg, PA 17055, who is/are the mortgagor(s) and real owner(s) of the mortgaged property hereinafter described. 3. On April 21, 1994, mortgagor(s) made, executed and delivered a mortgage upon the premises hereinafter described to GMAC MORTGAGE CORP. OF PA, which mortgage is recorded in the Office of the Recorder of Deeds of Cumberland County in Mortgage Book 1209, Page 646. By Assignment of Mortgage recorded February 9, 1995, the mortgage was assigned to Plaintiff, which Assignment is recorded in Assignment of Mortgage Book No. 1474, Page 37. These documents are matters of public record and are incorporated herein by reference in accordance with Pennsylvania Rule of Civil Procedure 1019(g). 4. The premises subject to said mortgage is described as attached. 5. The mortgage is in default because monthly payments of principal and interest upon said mortgage due February 1, 2001, and each month thereafter are due and unpaid, and by the terms of said mortgage, upon default in such payments for a period of one month, the entire principal balance and all interest due thereon are collectible forthwith. 6. The following amounts are due on the mortgage: Principal Balance Interest from 1/ 1/01 through 5/31/01 at 8.000% Per diem interest rate at $12.92 Attorney's Fee at 5% of Principal Balance Late Charges 2/ 1/01- 5/31/01 Monthly late charge amount at $41.20 Costs of suit and Title Search $ 58,958.21 1,938.00 2,947.91 164.80 560.00 $ 64,568.92 Escrow Balance Monthly Escrow amount $357.72 $ 64,568.92 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 ,. - , ...' ~ ~"I - ., ".." "-;;,:i,i.,:;"," "I, "'B" 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 daters) set forth in the true and correct copy of such notice(sl 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(sl 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 $64,568.92, together with interest at the rate of $12.92, per day and other expenses incurred by the Plaintiff which are properly chargeable in accordance with the terms of the mortgage, and for the foreclos e and sale of the mortgaged premises. Jr., Esq. ".', ,," ,- I'; . - --~ - , '':'-,,-<,-, t ,'" ." .., . '. '<,' "'~' '< " I ~ _ '" VERIFICATION I, Lynn Coady, as the representative of the Plaintiff corporation within named do hereby verify that I anI 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 authorities. 5 II? 10, -- ~ Date: ---- , , ~~1.~~/~~~1 !~:oq i.l':L.j:L~';!.l:lb i ! Jjlll 1'.....'" i iM..vr-_YIIJ"iJllt)> o-r-'m""'. \M '.--.. ....~.._I Mt<IIIy tQlI, I,,",.. 1M........... . . ! . bii' ~, 11\ b !l0"::, f'. lIr;;,tn. ",COIlOfil OF Ol,OS . tt CIJMDlr,lA:lV COIJNTY.PA ~'g'l APll2U AM 9 26 , !lADE THE j ':1\0\. 014. .f At>><- \ of our ut'II oh thlU1l1ftd mM AI(1k(f'lld ninet.y tour (1994) BETWEEN ~ ALO L. S1ONER, JR. anQ JSANNA J, STON~, hi~ wif@, of th 9oC'Qugh of Mechanfcoburg, Cl.Illtterland Coonty, PI!!On.",ylv8n:ial ! i ,ft. tM tC4r ... i I i ! .4 A. Co"t'ty, lUl~J II e.ingt.!l ll\$n. of Meehanic~urq. C\.Jnlb@rland Peruusylvania, Gt-1l3to,.s, OnnUI. : WITNTGSS8TlI, t/UI~ in co",""Mltilm of sun SIX 'tHOUSAND NINe HUNDRED---______ AND NO/l.OO- I ...---..-C$66/900.00)-----------~_____..___DoU4rB. i... 1t4tad paid, the TIJJ~l1t 'lJJAtr6ol ill hw.bv G.ckMw~".ed. t/&" .aid onnto16 do Mrltb:v gmnt Q:ftd omtvtV I,. tA, 4id gNJ-"$i':t , I ALL THAT CBRTJHNitraet Or (MIt:C'el of land situate on the so!)th side of West "",,ctocy St:ret-t, "'tl'l Ward. 1n the ElOrough of MechanicsbtlC91 Col.mty o~ curnbedand and State of P."~eYlvanla, more particularly ~Unded and ~scribad &$ follows: 8BGINNING ae a ~int on the BOuehern Une of Fa~tory Street, said polnt being melUll,lrtd irl a southweatedy direction ttJo hUJ'ld'(eQ sixt.y (260.00> farH; from tha southwedt cOr:J1er of Factory Street: ~nd Mar;K:e-t S1=.r~ti t.hence a()l,Jth 21 mgr@e.v 2$ rtdl1ute!l iast along the wo.stern line of lanM now 01;" tot:'ll'ledy of Aal:'Ct'l C. .!tapp 1m di.e.tanca f)f one hvodred nineteeN and sixt~en hl,lnd~cdthfJ 019.16l -fut:. t.o " h\lb on the nor them iine of a U.ftllt@f\ 05.00) foot. \lid&- aU~y; thence Sq~h 71 <legl:'4!" 33 minutes 9le.,t alow:J tJaid nQt'theT;ll 1i~ of alley . dbtanc::~ bf abty-one (61.00) fut. to a hubt then~~ North La degnHl:s 27 ll1inubl8 W<<$t ah.ong the ~ttlrn line of la.nds nQ\if or fQcmedy of .john H. Weiqelf Jr.. a. djtance of one l'lundred ninet.een (119.(0) tf!4!t; t.o. hlJb on the southern Un. of lIctocy St.reet; th~c:e Not"!;h 7I deq('ees 33 minuteb I!:aat:. ~long said sout.h.rn H ot tr'<<ctory Street ;t. distahr::e ot tJ.tty-fol,l[" end eighty-thn!! huJ1dr:~th" (504.83l f~t to a hub, the poittt and Place of 8EGINNING. HAVING thereoh er~ted . 2% _tory fr~rne dwt!!lling and detached frame gat'e.g8 k:ntwn an(! nunbere4 a. 15 ~t factOty St;reet. i UNDER AND SUBJ!CT1 neyerth.le8$, to e.~ementa, r&str1cti~, ~8Se~vationa, condlti~ ana r1~hta ot yay of record. BSING the same prJrniB1t. which Edc 8. Hughes and .Jean "U91,IlB, h.is wlte. by th.ir deed daJ-.aQ Jlun$ JO, 199:;2:. ana- reco.tQed ,",u1y '. 1992/ in tne OUice of the Roeol'~ of ~, in and fw Cumberland Count.y, in Deed Boo)t T, vC)lume 35, Page 606, 9~ant.ed and eotlveyed unto Donald L. ston@r, Jr. !g'lQ J@atma .1. Stoner, his v1fa, ?r~ntcr8 herein. J-'Ab!::. 11..:1 . . ti'~;~-r!~:~ Ir"";; ~ :'. foE ~l;:!. I:: . t'J I~l :.'1 '1 , ,"'I"."'lf'> ,,;' , 'U ;~. :ll ~.'::~: . 2i .~~ i: :~ ~.g.~ " ~ 'n ~..~ " ;~ . .~ i~'i t~ .o, r:; ',,', Ijt,j :: ;1) ~.I :~ e ,. ~l: " '" a ;; l."-!' r:~ " ;j;' ;,:;; " " 1~ '" I:. ;~ :..1 i ". I 'ij .:1 ~.; m , )il. I 'ill tiJb,,' I ~ " :S.Oi f8IJ i';~ji I lil!l!:f ;': ., I,:({ ~..! 1):' "'.' .. i Ci ,;itI~is1 \lI~3;~;:: J. 02-03-01 t-"C",')LETTERWRITER ACTIVITY FOR MONTH KEY=~~r.rO VERS~052 TITLE~PA ACT 91 MORT . LO~= 0009196312 ~INES-PER-PAGE=NO DATE=01-17 USER~D~O CONDITIONS~O January 17, 2001 EXHIBIT A Paul A Rheaume 15 W Factory St Mechanicsburg PA 17055 Loan Number: 0009196312 Current Lender/Servicer: Dovenmueh1e Mortgage Inc. HOMEOWNER\S EMERGENCY MORTGAGE ASSIS,!'ANCE PROGRAM YOU MAY BE ELIGIBLE FOR FINANCIAL ASSISTANCE WHICH CAN gAVE YOUR HOME FROM FORECLOSURE AND f-lELP YOU MAKE FUTURE MORTGAGE PAYMElITS IF YOU COMPLY WITH THE PROVISIONS OF THE HOMEOWNER\S EMERGENCY MORTGAGE ASSISTANCE ACT OF 1983 (THE "ACT"), YOU MAY BE ELIGIBLE FOR EMERGENCY MORTGAGE ASSISTANCE: . IF YOUR DEFAULT HAS BEEN CAUSED BY CIRCUMSTANCES BEYOND YOUR CONTROL, . IF YOU HAVE A REASONABLE PROSPECT OF BEING ABLE TO PAY YOUR MORTGAGE PAYMENTS, AND . IF YOU MEET OTHER ELIGIBILITY REQVIREMENTS ESTABLISHED BY THE PENNSYLVANIA HOUSING FINANCE AGENCY. TEMPORARY_STAY_OF_FORECLOSURE - Unde~ the Act, you are entitled to a temporary stay of foreclosure on your mortgage for thirty (30) days from the date of this Notice. During that time you must arrange and attend a "face-to-face" meeting with one of the designated consumer credit counseling agencies listed at the end of this Notice. THIS MEETING MUST OCCUR WITHIN THE m:XT (30) DAYS. IF YOU DO NOT APPLY FOR EMERGENCY MORTGAGE ASSISTANCE, YOU MUST BRING YOUR MORTGAGE UP TO DATE. THE PART OF THIS NOTICE CALLED "HOW TO CURE YOUR MORTGAGE DEFAULT", EXPLAINS HOW TO BRING YOUR MORTGAGE UP TO DATE. OF 01-01 PROP PTl d ,',' .' >~i',' ~ ,_ " '.' ~bo PAGE 16,538 lc FORM=LTRH PRINTER~PCTX SECURITY=l ~-L 02-{h-Ol l<"~' \LETTERWRITER ACTIVITY FOR MONTH KEY=D~O VERS=052 TITLE=PA ACT 91 MORT . LOrtN= 0009196312 DATE=01-17 USER=DHO ~INES-PER-PAGE=NO CONDITIONS=O ?AGB 2 OF 5 January 17, 2001 P A Rhe~ume CONSUMER CREDIT COUNSELING AGENCIES - If you meet with one of the consume~ credit counseling agencies listed at the end of this Notice, the len~er may NOT take action against you for thirty (30) days after the date of this meeting. The names, addresses and telephone numbers of designated consumer credit counseling agencies for the county in which tl1e property is located are set forth at the end of this Notice. It is ooly necessary to schedule one face-to-face meeting. Advise your lender immediately of your intentions. APPLlCAfION FOR MORTGAGE ASSISTANCE - Your mortgage is in default for the rea@ona set forth later in this Notice (see following pages for specifiC information about the nature of your default.) If you have tried and are unable to resolve this problem with the lender, you have the right to apply for financial assisance from the Homeowner\s EmergenCY Mortgage Assistance Program. To do so, you must fill out, sign ano file a completed Homeowner\s Emergency Assistance Program Application with one of the designated consumer credit counseling agenciee listed at the end of this Notice. Only consumer credit counseling agencies have applications for the program and they will .assist you in submitting a complete application to the Pennsylvania Housing Finance Agency. Your application MUST be filed or postmarked within thirty (30) days of your face-to-face meeting. YOU MUST FILE YOUR APPLICATION PROMPTLY. IF YOU FAIL TO DO SO OR IF YOU DO NOT FOLLOW THE OTHER TIME PERIODS SET FORTH IN THIS LETTER, FORECLOSURE MAY PROCEED AGAINST YOUR HOME IMMEDIATELY AND YOUR APPLICATION FOR MORTGAGE ASSISTANCE WILL BE DENIED. AGENCY ACTION - Available funds for emergency mortgage assistance are very limited. They will be disbursed by the Agency under the eligibility criteria established by the Act. The Pennsylvania Housing Finance Agency has sixty (60) days to make a decision after it receives your application. During that time, no foreclosure proceedings will be pursued against you if you have met the time requirements set forth above. You will be notified directly by the Pennsylvania Housing Finance Agency of its decision on your Application. NOTE: IF YOU ARE CURRENTLY PROTECTED BY THE FILING OF A PETITION IN BANKRUPTCY, THE FOLLOWING PART OF THIS NOTICE IS FOR INFORMATION PURPOSES ONLY AND SROUW NOT BE CONSIDERED AS AN ATTEMPT TO COLLECT THE DEBT. (If you have filed bankruptcy you can still apply for Emergency Mortgage ~ssistance.) DL140 OF 01-01 PROP PTl 1.1 ".<-j,,", ,,,;,; H" t,;]i PAGE 16,539 lc FORM=LTRH PRINTER=PCTX SECURITY=l " , 02-03-01 r-'"~'''''~LETTERWRlTER ACTIVITY FOR MONTH OF 01-01 KEY=D'b'A'l VERS=046 TITLE=PA ACT 91 MORT PROP PT2 . LOKN= 0009196312 DATE=Ol-17 USER=DHO LlNE3-PER-PAGE=NO ODNDITIONS=O PAGE 3 OF 5 January 17, 2001 P A Rheaume HOW TO CURE YOUR MORTGAGE DEFAULT (Bring it up to date) . NATURE OF THE DEFAULT - The MORTGAGE debt held by the above lender on your property located at: 15 W Factory St Mechanicsburg PA 17055 IS SERIOUSLY IN DEFAULT because: A. YOU HAVE NOT MADE MONTHLY MORTGAGE PAYMENTS for the following months and the following amounts are now past due; (a) Monthly pa~ents from November 01, 2000 to present (at $ 861.90 per month) $ 2,509.96 (b) Previous late charges; $ 69.96 (e) Property Inspections; $ 33 .53 (d) NSF Charges; $ .00 (e) Other Provisions of the mortgage obligation, if any; $ 69.96 (f) TOTAL AMOUNT OF (a) (b) (e) (d) and (e) REQUIRED AS OF THIS DATE: $ 2,613.45 YOU HAVE FAILED TO TAKE THE FOLLOWING ACTION (Do not use if not applicable) : HOW TO CURE THE DEFAULT - You may cure the default within THIRTY (30) DAYS of the date of this notice BY PAYING THE TOTAL AMOUNT PAST DUE TO THE LENDER WHICH IS $ 2,613.45, PLUS ANY MORTGAGE PAYMENTS AND LATE CHARGES WHICH BECOME DUE DURING THE THIRTY (30) DAY PERIOD. Payments must be made either by caShier\s check, certified check or money order made payable and sent to: ATTN: Collection Department LENDER NAME: Dovenmuehle Mortgage, Inc. ADDRESS: 1501 Woodfield Road, Suite 400 E, Schaumburg, IL 60173-4982 You can cure any other default by taking the following action within thirty (30) DAYS of the date of this letter. (Do not use if not applicable. ) ~; " ,'~ ,I,"" "'" ~ ,~ . r, PAGE 16,540 ) Ie FORM~LTRH PRINTER=PCTX SECURITY:l 02-03-01 ~'JLETTERWRITER ACTIVITY FOR MONTH ~,-, -' KEY=DJ1' 1 VERS=046 TITLE=PA ACT 91 MORT LOAN= 00091~6312 DATE=01-17 USER=DHO ~LINES-PER-PAGE=NO CONDITIONS=O PAGE 4 OF 5 January 17, 2001 P A Rheaume IF YOU DO NOT CURE THE DEFAULT - If you do not cure the default within thirty (30) DAYS of the date of this Notice, the lender intends to exercise its rights to accelerate the mortgage debt. This means that the entire outstanding balance of this debt will be considered due immediately and you may lose the chance to pay the mortgage in monthly installments. If full payment of the total amount past due is not made within THIRTY (30) DAYS, the lender also intends to instruct its attorneys to start legal action to foreclose upon your mortgaged property. IF THE MORTGAGE IS FORECLOSED UPON - The mortgaged property will be sold by the Sheriff to payoff the mortgage debt. If the lender refers your case to its attorneys, but you cure the delinquency before the lender begins legal proceedings against you, you will still be required to pay the reasonable attorney\s fees that were actually incurred up to $50.00. However, if legal proceedings are started against you, you will have to pay all reasonable attorney\s fees actually incurred by the lender even if they exceed $50.00. Any attorney\s fees will be added to the amount you owe the lender, which may also include other reasonable costs. If you cure the default within the THIRTY (30) DAY period, you will not be required to pay attorney\s fees. OTHER LENDER REMEDIES - The lender may also sue you personally for the unpaid principal balance and all other sums due under the mortgage. RIGHT TO CURE THE DEFAULT PRIOR TO SHERIFF\S SALE - If you have not cured the default within THIRTY (30) DAY period and foreclosure proceedings have begun, you still have the right to cure the default and prevent the sale at any time up to one hour before the Sheriff\s Sale. You may do so by paying the total amount then past due, plus any late or other charges then due, reasonable attorney\s fees and costs connected with the foreclosure sale and any other costs connected with the Sheriff\s Sale as specified in writing by the lender and by performing any other requirements under the mortgage. CUring your default in the manner set forth in this notice will restore your mortgage to the same position as if you had never defaulted. EARLIEST POSSIBLE SHERIFF\S SALE DATE - It is estimated that the earliest date that such a Sheriff\s Sale of the mortgaged property could be held would be approximately nine months from the date of this Notice. A Notice of the actual date of the Sheriff\s Sale will be sent to you before the sale. of course, the amount needed to cure the default will increase the longer you wait. You may find out at any time exactly what the required payment or action will be by contacting the lender. DL141/DHO OF 01-01 PROP PT2 . " 'I :Jii(l" .d"e- .,' ,'. ,-"~ i PAGE 16,541 lc FORM=LTRH PRINTER=PCTX SECURITY=1 0~-(i3-01 LOAN= 0009196312 DATE=01-17 USER=DHO LINE~-PER-PAGE=NO CONDITIONS=O ~ -~LETTERWRITER ACTIVITY FOR MONTH OF 01-01 KEY=D~t~2 VERS=066 TITLE=PA ACT 91 MORT PROP PT3 PAGE 5 OF 5 Janbary 17, 2001 P A Rheaume HOW TO CONTACT THE LENDER: Dovenmuehle Mortgage, Inc. 1501 Woodfield Road Suite 400 East Schaumburg, IL 60173-4982 1-800-669-0340 Fax: 847-330-8032 Contact: Mr. Edward Bagdon EFFECT OF SHERIFF\S SALE - You should realize that a Sheriff\s Sale will end your ownership of the mortgaged property and your right to occupy it. If you continue to live in the property after the Sheriff\s Sale, a lawsuit to remove you and your furnishings and other belongings could be started by the lender at any time. ASSUMPTION OF MORTGAGE - You MAYor X MAY NOT transfer your home to a buyer or transferee who willassume the mortgage debt, provided that all the outstanding payments charges and atorney\s fees and costs are paid prior to or at the sale and that the other requirements of the mortgage are satisfied. YOU MAY ALSO HAVE THE RIGHT * TO SELL THE PROPERTY TO OBTAIN MONEY TO PAY OFF THE MORTGAGE DEBT OR TO BORROW MONEY FROM ANOTHER LENDING INSTITUTION TO PAY OFF THIS DEBT. * TO HAVE THIS DEFAULT CURED BY ANY THIRD PARTY ACTING ON YOUR BEHALF. * TO HAVE THE MORTGAGE RESTORED TO THE SAME POSITION AS IF NO DEFAULT HAD OCCURRED, IF YOU CURE THE DEFAULT. (HOWEVER, YOU DO NOT HAVE THIS RIGHT TO CURE YOUR DEFAULT MORE THAN THREE TIMES IN ANY CALENDAR YEAR.) * TO ASSERT THE NONEXISTENCE OF A DEFAULT IN ANY FORECLOSURE PROCEEDING OR ANY OTHER LAWSUIT INSTITUTED UNDER THE MORTGAGE DOCUMENTS. * TO ASSERT ANY OTHER DEFENSE YOU BELIEVE YOU MAY HAVE TO SUCH ACTION BY THE LENDER. * TO SEEK PROTECTION UNDER THE FEDERAL BANKRUPTCY LAW. , .' ~ I '~ I . ,~ <,-,~,' ",'<"',',:.-;;.,,. i~LJ:.', PAGE 16,542 lc FORM=LTRH PRINTER~PCTX SECURITY=l ~~~ '. " ,-, 02-'03-01 W"~)LETTERWRITER ACTIVITY FOR MONTH KEY",ri1.i:tli2 VERS",066 TITLE=PA ACT 91 MORT , . . LOAN= 00091~6312 1LlNE~-PER-PAGE=NO DATE=01-17 USER=DHO CONDITIONS=O ACT 91 NOTICE DATE OF NOTICE: January 17, 2001 TAKE ACTION TO SAVE YOUR HOME FROM FORECLOSURE This_is_an_officia1_notice_that_the_mortgage_on_your_home_is_in_default, and_the_1ender_intends_to_foreclose,__Specific_information_about_the____ nature_of_the_default_is-provided_in_the_attached-pages. The_HOMEOWNER \s _MORTGAGE_ASSISTANCE _PROGRAM _ (HEMAP) _may_be _able _ to_help to~save-your_home.__This_Notice_exp1ains_how_the-program_works. To_see _if _ HEMAP _ can_help , _you_must _MEET_WITH _A_CONSUMER ~ CREDIT COUNSELING AGENCY WITHIN 30 DAYS OF THE DATE OF THIS NOTICE. Take_this_Notice_;ith_you_when-you_~eet=with=th~_co~seling Agency, The_name,_address_and-phone_number_of_Consumer_Credit_Counseling Agencies_serving-your_County_are_listed_at_the_end_of_this_Notice. If_you_have_any_questions,_you_may_call_the_pennsylvania_Housing Finance Agency toll free at 1-800-342-2397. (Persons with impaired hearing=can_cal1_(717)_7BO-1869. ~ -- This Notice contains important legal information. If you have any questions, representatives at the Consumer Credit Counseling Agency may be able to help explain it. You may also want to contact any attorney in your area. The local bar association may be able to help you find a lawyer. La notificacion en adjunto es de suma importancia, pues afecta au derecho a continuar vivendo en su casa. 8i no comprende el contenido de esta notificacion obtenga una traduccion immediatamente llamanda esta agencia (Pennsylvania Housing Finance Agency) sin cargos al numero mencionada arriba. Puedes ser elegible para un prestamo par el programa llamado "Homeowner\s Emergency Mortgage Assistance Program" el cula puede salvar su casa de la perdida del derecho a redimir au hipoteca. DL142 . < ~ OF 01-01 PROP PT3 I k """ -1,_",: PAGE 16,543 ) Ic FORM=LTRH PRINTER=PCTX SECURITY"'l 11 I I i I r !'h.'Q ,. ~ ~',' .,. " "" ~,-~' < ,., 'l~{~ ,~,4I1lJ1:li!:W ~" ,~~ '," "0,'""" ,,,,,,. " ,~,,',"; w~~ "', "'.''''t~"", ,,:,qt ",'",.",: "T'""'f',o;~1t'f&lflljt'\-' ,- -""J;{T~l,,~:,.,~t'';(''''~t~eIJiI,:~:iTIJ-''-',"'oAt' [' l.i-'1 0fF\er::: C I": t;\ \1,' ~~1 \~ "F Hie SHERIff _;1,,' .~ CC)lJ~T'f ~ l ~ 1\. \ 3 4t~ Vh v , ,,- , \-., ;~'-,'. l ';--,.~-t,l 1 0. -, c- '-: ~"_: ':I '\ L '.. I"~ \ ~ I' l" L \ ~ ,-;,~, .1l!lll!i!~~~!'i\I1~~.;F"1W,!"M":~,j,~:'!'i""'Of"!""'H$""""?\,,,,,q!'f%~'V~_!fI~"'1~W\)1~H'&;""iff-'l'\~"'ii1l'rn~lill'ptm!W'!Wi~p!! '-,' '" "" I- ~' . ",-' /-.,.,,',' ,I, ;\~'i , JUt 2 02001tP GOLDBECK MCCAFFERTY & MCKEEVER JOSEPH A. GOLDBECK, JR. Attorney I.D.#16132 Suite 500-The Bourse Building 111 S. Independence Mall East Philadelphia, PA 19106 215-627-1322 BY: MICHAEL T. MCKEEVER, ESQUIRE Attorney I.D. #56129 Attorney for Plaintiff DOVENMUEHLE MORTGAGE CO. LP 1501 Woodfield Road Schaumburg, IL 60173-4982 IN THE COURT OF COMMON PLEAS OF CUMBERLAND COUNTY vs No. 01-3054 Civil Term PAUL A. RHEAUME (Mortgagor and Real Owner) 15 W. Factory Street Mechanicsburg, PA 17055 AND NOW, this ORDER J3.t day of :r ~ 2001, upon consideration of the Plaintiff's Motion for Substituted Service under pa.R.C.P. 430(a) and it appearing to the Court that Plaintiff's good faith efforts to ascertain the present whereabouts of Defendant has been unsuccessful, it is, ORDERED and DECREED: that Plaintiff's Motion is granted and the Sheriff and/or Plaintiff is directed to Serve the Complaint in Mortgage Foreclosure upon Defendant by posting a copy of the Complaint upon the premises 15 W. Factory Street, Mechanicsburg, PA 17055 and Plaintiff is directed to serve the Complaint by certified and regular mail to the Defendant's last known address of 15 W. Factory Street, Mechanicsburg, PA 17055 and that all further service of " ,. 'j'J'I""_'--' , /,,' ,1 ";"'{'-J_" ,"', ~" '~~,,";, '"< -, '/i '", ",:1 legal papers, including but not limited to motions, petitions and rules be made by certified and regular mail to Defendant's last known address and that Notice of Sheriff Sale pursuant to Pennsylvania Rule of Civil Procedure 3129 may be made upon Defendants by sending copies of same to Defendant's last known address by certified and regular mail and by posting the premises. .~ ?~ I)'\) <\1}. BY J. " ','^"' ,-, ; 'I' ^' , ' . ,",,-- --- , ^ ~ '^~V::" d:'^^' " ",,- GOLDBECK MCCAFFERTY & MCKEEVER JOSEPH A. GOLDBECK, JR. Attorney 1.0.#16132 Suite 500-The Bourse Building 111 S. Independence Mall East Philadelphia, PA 19106 215-627-1322 BY: MICHAEL T. MCKEEVER, ESQUIRE Attorney 1.0. #56129 Attorney for Plaintiff DOVENMUEHLE MORTGAGE CO. LP 1501 Woodfield Road Schaumburg, IL 60173-4982 IN THE COURT OF COMMON PLEAS OF CUMBERLAND COUNTY vs No. 01-3054 Civil Term PAUL A. RHEAUME (Mortgagor and Real Owner) 15 W. Factory Street Mechanicsburg, PA 17055 : THIS I.AW FIRM IS A DEBT COLLECTOR AND lIE ARE ATl'EMPTING TO COLLECT A DEBT OWIID TO OUR CLIENT. ANY INFORMATION OBTAINED FROM YOU WILL BE USED FOR 'l.'B:E PURPOSE OF COLLECTIlIIG THE DEBT. MOTION FOR SUBSTITUTED SERVICE UNDER PA.R.C.P. 430(a) Plaintiff, by and through its attorney, Michael T. McKeever, Esquire, in support of its Motion for Substituted Service, represents as follows: 1. Plaintiff is the holder of a first mortgage upon the premises 15 W. Factory Street, Mechanicsburg, PA hereinafter, the "mortgaged premises". 17055, 2. Defendant, PAUL A. RHEAUME, is the mortgagor and real owner of the mortgaged premises. 3 . The last known address of Defendant is 15 W. Factory Street, Mechanicsburg, PA 17055 as set forth in Paragraph 2 of the Complaint. "' . . ~, " ~', ."" '-',1-,,,,,,, ',~~,,'--' ;;,) ~< -",' " '" ,~;...; ','-,-- "f ""~(,i 4 . The Sheriff has been unable to effect service of the Complaint upon Defendant at his last known address after numerous attempts. 5. The following investigation was conducted in a good faith attempt to ascertain the whereabouts of Defendant. WHEREFORE, Plaintiff prays that the Court enter the attached order allowing Plaintiff to serve the Complaint upon Defendant by posting the premises and certified and regular mail to the Defendant's last known address. / 'th. mi}i, 1211/( ~ BY: MICHAEL . MCKEEVER, ES IRE , ~ ,>' , '.hJ ,..I "',~ ""', ,--".. ~t ~. ',. ~',. GOLDBECK MCCAFFERTY & MCKEEVER JOSEPH A. GOLDBECK, JR. Attorney I.D.#16132 Suite 500-The Bourse Building 111 S. Independence Mall East Philadelphia, PA 19106 215-627-1322 BY: MICHAEL T. MCKEEVER, ESQUIRE Attorney I.D. #56129 Attorney for Plaintiff DOVENMUEHLE MORTGAGE CO. LP 1501 Woodfield Road Schaumburg, IL 60173-4982 IN THE COURT OF COMMON PLEAS OF CUMBERLAND COUNTY vs No. 01-3054 Civil Term PAUL A. RHEAUME (Mortgagor and Real Owner) 15 W. Factory Street Mechanicsburg. PA 17055 : : VERIFICATION I, MICHAEL T. MCKEEVER, ESQUIRE, Attorney for Petitioner do hereby verify that the facts set forth in the foregoing Motion for Substituted Service are true and correct to the best of my knowledge, information and belief. I understand that false statements therein are made subject to the penalties of 18 Pa. C.S. 4904 relating to unsworn falsification to authorities. '",- " ,~, ,~-'J ^"'i , ~,' " ,,- ~- "C .-' ";,, ' ~'" GOLDBECK MCCAFFERTY & MCKEEVER JOSEPH A. GOLDBECK, JR. Attorney I.D.#16132 Suite 500-The Bourse Building 111 S. Independence Mall East Philadelphia, PA 19106 215-627-1322 BY: MICHAEL T. MCKEEVER, ESQUIRE Attorney I.D. #56129 Attorney for Plaintiff DOVENMUEHLE MORTGAGE CO. LP 1501 Woodfield Road SChaumburg, IL 60173-4982 IN THE COURT OF COMMON PLEAS OF CUMBERLAND COUNTY vs No. 01-3054 Civil Term PAUL A. RHEAUME (Mortgagor and Real OWner) 15 W. Factory Street Mechanicsburg, PA 17055 CERTIFICATE OF SERVICE MICHAEL T. MCKEEVER, Esquire, do hereby certify that true and correct copies of the the foregoing Motion for Substituted Service have been served upon the Defendant this t" day of July, 2001, by first class mail, postage prepaid. BY1t1I~ ~CKEEVER' ESQUIRE , ,.-~'~ ' , '.' .,;,- ';',U,'..<:.c:'-',' ,~''''~-J___ "_""'~' ',"'",,',,-_ _'~;j GOLDJJECK MCCAFFERTY & MCKEEVER JOSEPH A. GOLDBECK, JR. Attorney I.D.#16132 Suite 500-The Bourse Building 111 S. Independence Mall East Philadelphia, PA 19106 215"'627-1322 BY;MIClIAEL T. MCKEEVER, ESQUIRE Attorney I.D. #56129 Attorney for Plaintiff DOVENMUEHLE MORTGAGE CO. LP 1501 WOodfield Road Schaumburg, IL 60173-4982 IN THE COURT OF COMMON PLEAS OF CUMBERLAND COUNTY vs ; No. 01-3054 Civil Term PAUL A. RHEAUME (Mortgagor and Real Owner) 15 W. Factory Street Mechanicsburg, PA 17055 MEMORANDUM OF LAW IN SUPPORT OF MOTION FOR SUBSTITUTED SERVICE UNDER Pa.R.C.P. 430(al Plaintiff has filed a Complaint in Mortgage Foreclosure against Defendant which the Sheriff has been unable to personally serve upon Defendant. As noted in the attached Motion, Plaintiff has made a good faith attempt to ascertain Defendant's whereabouts without success. Accordingly, the Court may approve alternative means of service. See Pa.R.C.P. 430(a). " ".," <,,,,:1 L, --, ,,_,' '".~ ",;-"j"Ji"~-,: __"'" ,.",,' ~~ CONCLUSION For reasons stated above and in the attached Motion, the Court should enter an order allowing Plaintiff to serve the Complaint in Mortgage Foreclosure upon Defendant by posting the premises and certified mail and regular mail to the Defendant's last known address. Re'P"Ctfully -~/ ;j~v MI LT.. EVER, ESQUIRE '" . -' '" ',;" ^~"' A' .', , PLAYERS NATIONAL LOCATOR AFFIDAVIT OF GOOD FAITH INVESTIGATION Loan Number: DOV-0081 Attorney Firm: GOLDBECK, MCCAFFERTY & MCKEEVER Case Number: Subject: PAUL A RHEAUME AKA: None Property Address: 15 W. FACTORY STREET MECHANICSBURG, PA 17055 Last Known Address: 15 W. FACTORY STREET MECHANICSBURG, PA 17055 Last Known Number: (717) 766-7573 Michael K Gross, being duly swom according to law, deposes and says: 1. I am employed in the capacity of President for Players National Locator. 2. On OS/24/2001, I conducted an investigation into the whereabouts of the above named defendant(s). The results of my investigation are as follows: CREDIT INFORMATION - A SOCIAL SECURITY NUMBER: B. EMPLOYMENT SEARCH: Unable to locate a good employer for Paul. C. INQUIRY OF CREDITORS: The creditors indicated that Paul is living at 15 W Factory Street, Mechanicsburg, Pa. 17055 with a home phone number of 717-766-7573. INQUIRY OF TELEPHONE COMPANY - A DIRECTORY ASSISTANCE SEARCH: The home phone number for Paul Rheaume is 717-766-7573 registered at 15 W Factory Street, Mechanicsburg, Pa. 17055. Called the home number and spoke with Paul who confirmed he is living at this address. INQUIRY OF NEIGHBORS - N1A INQUIRY OF POST OFFICE - A NATIONAL ADDRESS UPDATE: As of May 21, 2001 the National Change of Address (NCOA) has no change for Paul from last known address. MOTOR VEHICLE REGISTRATION - A MOTOR VEHICLE & DMV OFFICE: The Pennsylvania Department of Drivers Licensing has Paul listed at last known address. OTHER INQUIRIES - A DEATH RECORDS: As of May 21, 2001 the Social Security Administration has no death record on file for Paul A Rheaume under his social security number. ., '..0 I "'"'.,> 'k' ~,~" .~'''' _', l.... ,: < \. B. PUBLIC LICENSES (PilOT, REAL ESTATE, ETC. ): , None Found C. COUNTY VOTER REGISTRATION: The Cumberland County Voters Registration Office has Paul listed at last known address. OTHER SEARCHES - Social security number provided was verified. ADDITIONAL INFORMATION ON SUBJECT - A DATE OF BIRTH: 12161 ~__O ~ - "NOTARY SEAL" Kristine M. Scott, Notary Public St. louis County, State of Missouri My Commission Expires 9/2/2002 AFFIANT Players National Locator 113 Old State Road, Suite 104 St. Louis, MO 63021 Phone: (636) 230-9922 Fax: (636) 230-0558 - " " l ~ I ' J .",1 '" ,.-"." <0 .' ,_:,_;_"_,.",.J, i ",. :,,' ",~ ~-li.." JUL 11 2001 13:50 FR CUMBERLAND CO SHERIFF717 240 6397 TO 912156277734 .....J.J..L:oJ.\..J..J.:.... oJ l.\'J.:l.J.V'&'''''''l ~~........... ~""L"....... P.02/02 CASg NO: 2001-03054 P 'COMMONWEALTH OF PENNSYLVANIA COUNTY OF CUMBERLAND DOVENMUEHLE MORTGAGE CO LP VS RHEAUME PAUL A R. Thomas Kline ,Sheriff or Deputy Sheriff, who'being duly sworn according to law, says, that he made a diligent search and inquiry for the within named defendant, DEFENDANT RHEAUME PAUL A but was unable to locate Him in his bailiwick, He therefore returns the COMPLAINT - MORT FORE , NOT FOUND , as to the within named DEFENDANT , RHEAUME PAUL A ADDRESS IS VALID, BUT UNABLE TO LOCATE DEFT PRIOR TO EXPIRATION, EXPIRED 6/15/01 Sheriff's Costs: Docketing Service Not Found Surcharge 18.00 12.40 5.00 10,00 .00 45.40 " mas Kl~ne iff of Cumberland county GOLDBE K MCCAFFERTY & MCKEEVER 06/22/2001 Sworn and subscribed to before me this day of A.D. Prothonotary 07/11/2001 WED 12:27 ** TOTAL PAGE.02 ** [TX/RX NO 6952l t4i 002 ~- 6~ 'i "I I I, . . I I jL. ~ 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 DOVENMUEHLE MORTGAGE CO. LP 1501 Woodfield Road Schaumburg, IL 60173-4982 Plaintiff IN THE COURT OF COMMON PLEAS OF CUMBERLAND COUNTY CIVIL ACTION - LAW vs. :ACTION OF MORTGAGE FORECLOSURE PAUL A. RHEAUME (Mortgagor(s) and Record Owner(s)) 15 W. Factory Street Mechanicsburg, PA 17055 Defendant(s) Term No. 01-3054 (Civil Term) PRAECIPE TO REINSTATE COMPLAINT Kindly reinstate the Complaint in the above captioned matter. GOLDBECK MCCAFFERTY & MCKEEVER BY: , Jr. DOV-0081 ,J/!:!iij;~~~",~.iit~ifili,lb;-ill.-'i1L!'ci_d~,,;:~~rJ~M'Illili&gHi!\ioill""bEti:i\W~j~]~~";'~'.~<:-' '~ ~. ,Jlli~..J! _II ~ , , " " -%>--""",,',""0>',,",'. ~" "",' M ,,-.' ~, ~'''''~l}j;~~-'.''"'': "" 'II ,",' , '"~' (") 0 0 c: " ",. ",. .~ -O~:fl, r= ~~:b 'n zr- I .'_]~Tl ~:E 0.' ,:.J(,:l 'J' r:='--' ~.:j~;~ <\_..... "V ,_;.~ -n ~O ::K 6F"~ ;r>C) ~ c: :Z o;:-l .=<! :::> ~ en ~ ii' '~~ 'i 'I' ^" ',",,','I,~ ~'",'~ '.'~'"' '''''c'''~:;~'''_'''_'>';'''' , , ~ '''"'. 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 DOVENMUEHLE MORTGAGE CO. LP 1501 Woodfield Road Schaumburg, lL 60173-4982 IN THE COURT OF COMMON PLEAS OF CUMBERLAND COUNTY vs. PAUL A. RHEAUME (Mortgagor(s) and Record Owner(s)) Term No. 01-3054 (Civil Term) 15 W. Factory Street Mechanicsburg, PA l7055 CERTIFICATE OF SERVICE JOSEPH A. GOLDBECK, JR. ESQUIRE hereby certifies that on August 10, 2001 he did serve upon Defendant(s) PAUL A. RHEAUME a true and correct copy of the above-captioned Complaint by certified and regular mail in accordance with the Court Order dated July 23, 2001. The undersigned understands that the statements herein and subject to the penalties provided by 18 P.s. Section 4904. Re,pectf~~d' JOSEPH A. GOLDBECK, JR. ESQUIRE ~1'Iiiliiotmiii1)!j~il!I~i-Jill'm~~~'i_~'ia;m'i;tj(1;;,~fj;'ltll,Mi:r:iiwm,j~~!i!ill- fJ!j.LL~d "'" ~r_,_ " ~,,\, '" _" ~ '~~',"~, ,,, ". ,~ ".'''''' "-/":,,,'," ~" 1I!iiriIi~~;' ~1111 ~ .' ,,~, ,~ '" ~'-~Iil~liIIIliilliliil' llainnTr -jl () C' 0 C -::""I'"'i s: ;po ;:RCJC! c: rr y') .M' Z~I" --,r'n ze- '<~~\ cn}2; .;0- 26 ~ "'- r~~~~ :28 - ;::~m )>c - ~ z .::> )>' :< ::n N '< , ,,~" '- .. .~,~, ~ ,I ;11 I J ",I ,';;,.,. ~"""'.t--<TiY SHERIFF'S RETURN - REGULAR -CASE NO: 2001-03054 P COMMONWEALTH OF PENNSYLVANIA: COUNTY OF CUMBERLAND DOVENMUEHLE MORTGAGE CO LP VS RHEAUME PAUL A BRIAN BARRICK , Sheriff or Deputy Sheriff of Cumberland County,Pennsylvania, who being duly sworn according to law, says, the within COMPLAINT - MORT FORE was served upon RHEAUME PAUL A the DEFENDANT , at 2112:00 HOURS, on the 8th day of August , 2001 at 15 W FACTORY ST MECHANICSBURG, PA 17055 by handing to PROPERTY POSTED AT 15 W FACTORY ST MECHANICSBURG ~ a true and attested copy of COMPLAINT - MORT FORE together with and at the same time directing His attention to the contents thereof. Sheriff's Costs: Docketing Service Posting Surcharge So Answers: 18.00 5.85 6.00 10.00 .00 39.85 ~~--(:~ R. Thomas Kline 08/09/2001 GOLDBECK MCCAFFERTY Sworn and Subscribed to before By: me this /5'J,- day of ~.u.~ :u,o I ~ Q. )u,DO~., ln~Zf othonotary ,-, A.D. .g~'i>iIJ!!li'!lt~illiiliiliif1;fi4~~1!i.j;~~illiIM!01JJ",")'~~~ ~ ".,'c""'o<'",-J.~,'~_'f~l.J"";:.'>t"fe,,,~""""- '1Ilid' -.lIiIIllIiiUlillilill ~~ J;p u rrl!ll .... .... , ''''"'' ",",,"'7,~,.' , ."" ",~""~,~ , ,,", ,," ,," ~, .",. ~'iIi~~~~_'mi ," ,," ^,,,~,,~,~ .^ ,',< ,~. ~~w-jlJ '- ~[["q 1 ~. ,I 1'[ . ~ ~ .:" -I . , . , -_~..iiru;'i' In the Court of Common Pleas of Cumberland County DOVENMUEHLE MORTGAGE CO. LP 1501 Woodfield Road Schaumburg, IL 60173-4982 Plaintiff vs. PAUL A. RHEAUME (Mortgagor(s) and Record Owner(s)) 15 W. Factory Street Mechanicsburg, P A 17055 No. 01-3054 Civil Term Defendant( s) PRAECIPE FOR JUDGMENT THIS LAW FIRM IS A DEBT COLLECTOR AND WE ARE ATTEMPTING TO COLLECT A DEBT OWED TO OUR CLIENT. ANY INFORMATION OBTAINED FROM YOU WILL BE USED FOR THE PURPOSE OF COLLECTING THE DEBT. Enter the Judgment in favor of Plaintiff and against PAUL A. RHEAUME by default for want of an Answer. Assess damages as follows: Debt $77,101.56 Interest - 01/01/2001 to 09/19/2002 Total (Assessment of Damages attached) I CERTIFY THAT FOREGOING ASSESSMENT OF DAMAGES IS FOR SPECIFIED AMOUNTS ALLEGED TO BE DUE IN THE COMPLAINT AND IS CALCULABLE AS A SUM CERTAIN FROM THE COMPLAINT. I certilY that written notice of the intention to file this praecipe was mailed or delivered to the party against whom judgment is to be entered and to his attorney of record, if any, after the default occurred and at least ten days prior to the date ofthe filing of this praecipe. A copy ofthe notice is attached. R.C.P. 237.1 Joseph A. Go if Attorney for 1 !.D. #16132 AND NOW ,;)3 ,c-."')'~ ,Judgment is entered in favor of DOVENMUEHLE MORTGAGE CO. LP and against PAUL A. AUME by default for want of an Answer and damages assessed in the sum of$77,101.56 as per the above certification. 1St ad'lf? ~ Prothonotary . / /.Rc- ~i~m.J;i1ol1t~i~'lli~IMb.""'~~~d,i'jj-;:ilb1'?;1)1<*r,~~~~'w.t-~1dll!-'W""\b~ , =_~" ~,.<.. _",~ ~,~~" ,. ,~,,"'\v,"-"" ~-~-", " iMilillli:i ~.-' .... ~ ~ .,..., -....H~:~j '-liMiI -I , e 0 ~ N s::: en ;:;j 2!B 1TI -0 f+l~ Zr;: N ~Ba ~~". (..., o~ ;::::0 ~"t , -u -.... 1 f ig ::x ;.&;:ti '-0 rs> ;;;;;rn ~ ~ N ~ <Xl -< ~" ~ "",. .,,',', "'"'~~""-' "-".=-,~,~,, ,~..,~-, ~" , ., . I ,,,'-- h<~'~r -I~~.. . GOLDBECK McCAFFERTY & McKEEVER BY: Joseph A. Goldbeck, Jr. AttorneyLD. #16132 Suite 500 - The Bourse Bldg. 111 S. Independence Mall East Philadelphia, PA 19106 215-627-1322 Attorney for Plaintiff DOVENMUEHLE MORTGAGE CO. LP 1501 Woodfield Road Schaumburg, IL 60173-4982 IN THE COURT OF COMMON PLEAS Plaintiff of Cumberland County vs. PAUL A. RHEAUME (Mortgagor(s) and Record owner(s)) IS W. Factory Street Mechanicsburg, PA 17055 CNIL ACTION LAW ACTION OF MORTGAGE FORECLOSURE Defendant( s) No. 01-3054 Civil Term ORDER FOR JUDGMENT Please enter Judgment in favor of DOVENMUEHLE MORTGAGE CO. LP, and against PAUL A. RHEAUME for failure to file an Answer in the above action within (20) days (or sixty (60) days if defendant is the United States of America) from the date of service of the Complaint, in the sum of$77,101.56. Joseph A. Goldbe , r. Attorney for Plain' f I hereby certify that the above names are correct and that the precise residence address of the judgment creditor is DOVENMUEHLE MORTGAGE CO. LP f501 Woodfield Road Schaumburg, IL 60173-4982 and that the name(s) and last known addressees) of the Defendant(s) is/are PAUL A. RHEAUME, 15 W. Factory Street Mechanicsburg, PA 17055; GOLDBECK c BY: Joseph A. Idbe Attorney for Pia' tiff TY & McKEEVER Jr. 'J ,I .1 J ;:.,1 . ~ ,,'^ '" "'lie!: . ASSESSMENT OF DAMAGES TO THE PROTHONOTARY: Kindly assess the damages in this case to be as follows: Principal Balance $58,958.21 Interest from 01/01/2001 throngh 09/19/2002 $8,087.92 Attorney's Fee at 5.0000% of principal balance $2,947.91 Late Charges $824.00 Costs of Suit and Title Search $560.00 Escrow Balance Deficit $5,723.52 ($0.00) $77,101.56 GOLDBECK FF BY: Joseph A. 0 dbec Attorney for PI . tiff AND NOW, this d3 day of ~ ,2002 damages are assessed as above. /.$1 ~. ;e.~ Pro Prothy /.e~ p' , <iM~~~~~M4iI~~~'A''':I'~~l1i"t>illci~''ili';j:,,~~,,~I)'''fu~;lilihilii~J<clWEiliMiI.r<llii-~" .",,,_. ~,_ c"' ~'c' "', ~"< ,'. ,,_,^ ~_^ _", 0', ~i ~, ",,",'''', "r'..' 0,. ,', ".' LlI'"'" 0'.". ''', " - " 0 c:' 0 c: f"~ -1'1 <'" "" ., ~W rrl ~ ~1 ;.l:~ rn 'U X Z-- N H<,...m ~'-~ Ge. '''9 <;;. "'" :;-~o !<:C! -0 ~-r. ~o ::.Jr~ 03 zQ :>>0 r;y. ."".....!,; c: ;::\ -,.,. )>' ~ "-.) CO ~ . "_, "","'i"'''''~ ,~,' "'~"" ,',~ ~, .', - ""~!,Ui'"' . VERIFICATION OF NON-MILITARY SERVICE The undersigned, as the representative for the Plaintiff corporation within named do hereby verify that I am authorized to make this verification on behalf of the Plaintiff corporation and that the facts set forth in the foregoing verification of Non- Military Service are true and correct to the best of my knowledge, information and belief. I understand that false statements therein are made subject to penalties of 18 Pa. C.S. 4904 relating to unsworn falsification to authorities. 1. That the above named Defendant, PAUL A. RHEAUME, is about unknown years of age, that Defendant's last known residence is 15 W. Factory Street, Mechanicsburg, PA 17055, and is engaged in the unknown business located at unknown address. 2.' That Defendant is not in the Military or Naval Service of 'theUBited States or its Allies, or otherwise within the provision~ of the Soldiers' and Sailors' Civil Relief Action of Congress of 1940 and its Amendments. Date: a_\~i~~~~il,yJ>4~ ,~-- -W!!iiffil,:lli:,\c.~:,'io1i,,"l\.l-"~H'H,i!ijj~,';-';;;djf'M;~-il:iilIl'i'%l'~-"' "~ili "''''-,'',~= ..- '- "'^ ''''''-','~''P':!,,,,,,,,,~,,,'''~,,..-,,"'' ,- .'"",' ",~ '......""" -" ~8 ,~ ~ .,. "",0-' <',,^" .__ , ^ ,. '-. ~ ,_,,",' e, ~_ ,,~',~", "" ",", . 1,1 Ii I:' t! 1'1 I,' , ::_,j " n ~: I.:. ~i il Ii 'I :i () Cl 0 C I'~ -n :i: en ,'~I ;.g~ 1"'1 ~~ Ie' -0 N "og:j '''( "7 w :r--(') ~(S ::-;'.{L.,' -0 -"".;--ri ~8 ;:J!: :;.~-n '~o >c: r:s> Om ...., ~ "" S; co -< ,., ,~",' .~ ._, ~~ .~ ~ "~ ~--'~--'" ... j '-,"-- ~""'"." '., ~,~; h"Af:" , , TO: PAUL A. RHEAUME 15 W. Factory Street Mechanicsburg, PA 17055 DOVENMUEHLE MORTGAGE CO. LP 1501 Woodfield Road Schaumburg, IL 60173-4982 Plaintiff vs. PAUL A. RHEAUME (Mortgagor(s)) (Record Owner(s)) 15 W. Factory Street Mechanicsburg, PA 17055 Defendant(s) IN THE COURT OF COMMON PLEAS OF CUMBERLAND COUNTY CIVIL ACTION - LAW ACTION OF MORTGAGE FORECLOSURE Term No. 01-3054 (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: PAUL A. RHEAUME 15 W. Factory Street M~chanicsburg, PA 17055 DATE OF THIS NOTICE: August 31, 2001 IMPORTANT NOTICE . yOU ARE IN DEFAULT BECAUSE YOU HAVE FAILED TO ENTER A WRITTEN APPEARhNCE.PERSONALLY OR BY ATTORNEY AND FILE IN WRITING WITH THE COURT YOUR DEFENSES OR OBJECTIONS TO THE CLAIMS SET FORTH AGAINST YOU. UNLESS YOU ACT WITHIN TEN (10) DAYS FROM THE DATE OF THIS NOTICE, A JUDGMENT MAY BE ENTERED AGAINST YOU WITHOUT A HEARING AND YOU MAY LOSE YOUR PROPERTY OR OTHER IMPORTANT RIGHTS. YOU SHOULD TAKE THIS NOTICE TO A LAWYER AT ONCE. IF YOU DO NOT HAVE A LAWYER OR CANNOT AFFORD ONE, GO TO OR TELEPHONE THE FOLLOWING OFFICE TO FIND OUT WHERE YOU CAN GET LEGAL HELP: Cumberland County Bar Association 2 Liberty Avenue, Carlisle, PA (800) 990-9108 /s/ JOdeph --4. (jotdteck. 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 - "^ ., I ,,,,,,"'1_,,",-'. ~ ' I J", " "'l '-' ' TO: TIM COLGAN-ESQ THE WILEY GROUP 1 South Baltimore Street Dillsburg, PA 17019 POVENMUEHLE MORTGAGE CO. LP 1501 Woodfield Road Schaumburg, IL 60173-4982 Plaintiff vs. PAUL A. RHEAUME (Mortgagor(s)) (Record Owner(s)) 15 W. Factory Street Mechanicsburg, PA 17055 Defendant(s) IN THE COURT OF COMMON PLEAS OF CUMBERLAND COUNTY CIVIL ACTION - LAW ACTION OF MORTGAGE FORECLOSURE Term No. 01-3054 (Civil Term) THIS LAW FIRM IS A DEBT COLLECTOR AND. WE ARE ATTEMPTING TO COLLECT A DEBT OWED TO OUR CLIENT. ANY INFORMAT~ON OBTAINED FROM YOU WILL BE USED FOR THE PURPOSE OF COLLECTING THE DEBT. TO: TIM COLGAN-ESQ THE WILEY GROUP 1 South Baltimore Street Dillsburg, PA 17019 DATE OF THIS NOTICE: August 31, 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/ JO:leph .A. (jotdbeck. 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 ~(ijj;jiljiil:U!Mml;);~OOi!~~.~iia~Il:?-Ij~:''''!f,,,,,'''';,",I)~''l'!H'\l:.l,:~fii:<ii~ilIit'-" >, ~ " ,,',. _, ~_-'",~~~_. _ ~." <_ _.~~ =.,W. '1lIiiI ~~~ 1lilIlJlIIl_ ~ ~ \ e 0 0 1" -n ;;:: en --( it -og;; m I:!l ~g:. " ""1 < ~' ~ Z~ N ~g~ ~..: w ,~ () , ~C' -0 ::::JC.l -i- !!i ~8 :x: 7:)~ ~ . C ~ -orn Z N ~ ~ CX> '< ~ ~ ....... ~ ~ Cv 'I) ~ "'<\ ~ '" , ',~ ..~,." ~-^~,~'~,'_.'~"" ~" .~~~~., '-',." ~~I, . . ~' , 1J' _~",~i<."<,.~",, ., Rule of Civil Procedure No. 236 - Revised IN THE COURT OF COMMON PLEAS OF Cumberland COUNTY, PENNSYL VANIA CIVIL ACTION - LAW DOVENMUEHLE MORTGAGE CO. LP 150 I Woodfield Road Schaumburg, IL 60173-4982 Plaintiff No. 01-3054 Civil Term vs. PAULA. RHEAUME (Mortgagors and Record Owner(s)) 15 W. Factory Street Mechanicsburg, P A 17055 Defendant( s) THIS LAW FIRM IS A DEBT COLLECTOR AND WE ARE ATTEMPTING TO COLLECT A DEBT OWED TO OUR CLIENT. ANY INFORMATION OBTAINED FROM YOU WILL BE USED FOR THE PURPOSE OF COLLECTING THE DEBT. NOTICE Notice is given that a judgment in the above-captioned matter has been entered against you. Curt Long Prothonotary By: Deputy If you have any questions conceming the above, please contact: Joseph A. Goldbeck, Jr. Goldbeck McCafferty & McKeever Suite 500 - The Bourse Bldg. 111 S. Independence Mall East Philadelphia, PA 19106 215-627-1322 1H~l1liih~wMiM~llm<~~~~iljl!lliiliii';j.",~~,.""b;:8r,':J~_""=<"''JotI;:nnl''~;sW:'''U;&';1\.;"1" .~.JiIt~jlillll ." "~IilIIlII!I.IOl:lP.'1 """"J:l!IIlJii - " -"',;1 '" tl II II !I I :1 II I II ES t:% y".~~".,.~~,~.~ -~ _ ,'''"''".",'~,,;?)',... _"_ '.~. ',,,",, """"").'''.''~''_.,i-~',,"\,..,''..'''' .,,..t".,,. __',,,'."',~ 'e.' ,oj''''". ,,\,>, ~'d,,~"". ',""_"".~,,~~,,i"''''~_'' ,.~ """~'~'''' "~~""',,%_,-e"".<""''')'-'"''.' ~>, "v" =_,,, T__~ "~ ~ I J.' '.,1" _,._. <'.......;:,." PRAECIPE FOR WRlT OF EXECUTION - (MORTGAGE FORECLOSURE) P.R.c.P 3180-3183 . Joseph A. Goldbeck, Jr. Attorney LD.#16132 Suite 500 - The Bomse Bldg. III S. Independence Mall East Philadelphia, P A 19106 215-627-1322 Attorney for Plaintiff DOVENMUEHLE MORTGAGE CO. LP 1501 Woodfield Road Schaumbmg, II. 60173-4982 IN THE COURT OF COMMON PLEAS Plaintiff vs. of Cumberland County PAUL A. RHEAUME Mortgagor(s) and Record Owner(s) 15 W. Factory Street Mechanicsbmg, P A 17055 CIVIL ACTION - LAW ACTION OF MORTGAGE FORECLOSURE Defendant( s) No. 01-3054 Civil Term PRAECIPE FOR WRIT OF EXECUTION TO THE PROTHONOTARY: Issue Writ of Execution in the above matter: Amount Due $77,101.56 Interest from 01/01/2001 to 09/19/2002 at 8.0000% (Costs to be added) GOLDBECKMcC ER1: BY: Joseph A. Gold eck, Jr Attorney for Plaintiff ~~~!io~@jj~lit~l!mw!lIl"iif~M!fci\1;i",;,::.-~__)lii;'!<!.-iliill~{J;iiiM,~~ r_~ . " " H t, Ii Ii I; l~ i: I; " i I: ,. rt il '. -. e 0 ~ N ~ >- ...... ~ ~~ en .-l ~ V\. ~~lv~ !Tl :c ~ "1J h1p >J ~ ':' ~~' ~ ~~ N ~.~ Vv :t;: c:.,~ I'> ~~~~~ ~\S ~::.>. ~ ~ -0 ~..,.. ". ~n :J:.,fj ~ ::x 0'= r f r: r~ j>o r:-: ~.~ r . " ~ N ~ . (D -< ^ . , ~ ~~ ~~ ~ "- ~ 'l.J ~ ~ ~ ~ l" ",,' ~, ~,._~ .,~_, ~ . ~~_" ,.,~.~, ,"_'~'""~' ,0 ,,,~,~ '".,'~~~ ,~, ,,~,', _~f"~_',"'" .,A'_~~ ,., 3", ~.-~,r ,~ '. V; ".~. ".,"'>",~ 'V ~~,._~_,__~"~P' ,~,~ '''. "" ,ro " ,', __ ,,"' , ,'.,,~, ",",. .-. "''''''''C<"+,,,;\,"*';;''''''''j>.d'''''_,.i'ii'':'''"'~ftl~1r"= (;lWll!:,' Iilll>tiIlI/;&it~Mri~~ '" Z <( "" 0 0< .-l .... .-l 0 ~ f-< ~ ;;> ;.. U ~ " U~ SZ P.I " ", 0< " ~ :s <-' <n ,,0 " 0 :-: ... :;;~ -< :;:O"r- 0< i;l " "d !l.l ...... 1<;.$ :J~"'-< ;:;0 i=:2 -<0'" o ~ i:-Ll u >-.~ Suu 0 gJ ,,~ ^ f-< is vi ~ 0 01) ".".1<; :;: ~ ~ ~~ > -0 u " 1-<:80 P.I . := ~ ..0 ~ ~ ~ tn <<\f-< .-l ~ . u " 8~ ;r:: .-l ~ ::;: .~ ~.. P.I ;:J~ ~ 01:: ~ <r;Otn...c:: I<; 0 00 p.. tlt).--< U 0<6 Zu " " 0< ~ 'iF :;: ;.. is .... ;r:: > 6 u I-< 0 ~ Z 0 .... "" ."." ... " t . t; " 01)" ~:s~\O YCQ::::lO ~ iU ~- o(l~::;\~'" f~~~~ ~pQ)..g d't- ~ 1=1..... M ~ Q)..r:: \0 ~ I fr%tA :;S8]alN .:iltr) !';::: Y~u:i~ Q,)..... - .c"- -0"'- - - o " "",~-"~'_".,.,.._,,.,v,,,,~.."~,.,,"'"",,,", ~"'~^,_~"N"~","_,,__,' '_"" ,.,-,,_,~,,~__~__~_"'_",""',' ,_".,>,"~_,. ~~ =^..,--, , _~ , "i II: ", ,j; "1 . , ,-I I:: !:! iii Iii :!i Ii! r: Iii !"I iii , ii! Ii! II il 11 I II I I, 'I i I, ~' II ^ ,\i1illi'lliil'i\H$~\'(~,~ilIl_&j!l\M.--1Ji!i:;iI'_~l:ii~I~~n1<-WiI!.\t"~~ili.i<[f<.\;'''PH.,JT~~O'!;,"'h'<.b.~"~..,,~j'",,,'J:i")~~ !II. ""~"-',",- :(j;-~'-'1I!i;1iiIf:~. " ~ -" ""'-',-" ,'.- ~i rl ~i :! 'I Ii [,I i,1 'I 'I Ii :i 'i I 'I II Ii I' :1 I j . i r ALL THAT CERTAINltcact or pa~cel of land situate on the sooth side of Weat "octory Street, .jtl1 liard, in the Borough of I\l><:hanic.burg, County of Cumberland end St..ate of P4n1eylVania, mre particularly ~Unded and described as follows: BeGINNING at a pJint on the 6Outh~rn lin~ of Fa~tory Street, eaid polnt boihg meoour&d iq a southwesterly direction t~ hundr.o .ixty (260.00) feet [t'Om the Bouthwedt cor;t1e-r ot Factory Street ;and Mark.et St.t"eet: th~"ce .8Ol,lth 21 dagr~~ 2$ minutes East Along the western lin~ of lands now Or fo~rly ol Aaron C. Kapp ~ di$tancft of on~ hundred nineteeh and sixteen hondt'~thB (119.16) feet to jo hub on the nortl1ern iine of a fift....n (15.00) foot ..Ide alley; th8nc~ SOl,l~h 71 C~~~e~ 33 minute3 WeBt along said nQrthe~n lin~ of Alley A dt.t8nee bf 8i~ty-one (61.00) feet to a hub: thence No~th 18 degrees 27 minutes W~~t a~o~ th~ eGBtern line of lands nQW or (Q~rly of John H. W.igel, Jr., A dif'tance of one hundred nin@t~en (119.00) feet to a hub on the south<<rn line of ~cto~ Str~~t; th~oe North 71 degcoes 33 minutea East along said ltOuth.rn lin of "~ctory Stree:t a di:!t&.nc8' of tifty-fol,lr: and eighty-th["ee hundrodth. (54.83) f~t to a hub, tho point and Place of 8EGINNING. ; HAVING thereon er~ted ~ 21 story fr~me dwelling and detached frame garagv l<nown and number"" a. i5 Weat Factory Street. i UNDER AND suaJECT~ neverthele8$, to eaeement8, reBtriction~, reservationa, condition$ anC ri~ht. of yoy o( racord. TAX PARCEL # 19-22-0519-083 ~ 0 ~ N en --< ~l~ fTl ;~:n m -0 ::IJ '.'r e- N -om ~~ w ;J.?9 ~Q ~O -0 ~j: --H ~o ~ 9~ 5>0 ry 0 <= ~ ,,.,, ~ ()j -< _~w ,=~~~ ,~ ,-~ ~-<.",..", ~.~".~--" ..,-."-"" "',-',,",'"',, =" c .- "- ,<, ,~, . ~"~_ ~ "7Y_ ,N ~ , . .~ ~ " ,--,--,~i I ,I'. 11 I ~ ___.d.'. , " . '-'-- ,.;--~~~-,~,;.- '~-: WRIT OF EXECUTION and/or A TT ACHMENT COMMONWEALTH OF PENNSYLVANIA) COUNTY OF CUMBERLAND) NO 01-3054 Civil CIVIL ACTION - LAW TO THE SHERIFF OF CUMBERLAND COUNTY: To satisfy the debt, interest and costs due Dovenmuehle Mortgage Co. LP 1501 Woodfield Road, Schaumburg, IL 60173-4982 Plaintiff(s) From Paul A. Rheaume 15 W. Factory Street Mechanicsburg, P A 17055 (I) You are directed to levy upon the property of the defendant (s)and to sell SEE LEGAL DESCRIPTION. (2) You are also directed to attach the property of the defendant(s) not levied upon in the possession of GARNISHEE(S) as follows: and to notify the garnishee(s) that: (a) an attachment has been issued; (b) the garnishee(s) is enjoined from paying any debt to or for the account of the defendant (s) and from delivering any property of the defendant (s) or otherwise disposing thereof; (3) Ifproperty of the defendant(s) not levied upon an subject to attachment is found in the possession of anyone other than a named garnishee, you are directed to notify him/her that he/she has been added as a garnishee and is enjoined as above stated. Amount Due$77101.56 L.L.$.50 Interest FROM 01/01/2001 TO 9/19/2002 AT 8.0000% Atty's Conun % Due Prothy $1.00 Atty Paid $157.25 Other Costs Plaintiff Paid Date: September 23,2002 (Seal) CURTIS R. LONG Prothonotary By: '1t/~ ~- Z:;~. W Deputy REQUESTING PARTY: Name Joseph A. Goldbeck, Jr. Address: Suite 500 - The Bourse Bldg. 111 S. Independence Mall East Philadelphia, PA 19106 Attorney for: Plaintiff Telephone: 215-627-1322 Supreme Court ID No. 16132 1l[ t;, 8-18- 2 4:32 PM ;HARVEY PENNINGTON 2155677323;# 2/ 5 " . f '- , . UNITED STATES BANKRUPTCY COURT FOR THE MIDDLE DISTRICT OF PENNSYLVANIA-HARRISBURG Chapter 13 In re: Bankruptcy Case No. 1-01-05473 PAUL A. RHEAUME, Debtor. STIPULATED ORDER RESOLVING MOTION FOR RELIEF FROM THE AUTOMATIC STAY, WITH RESPECT TO REAL PROPERTY AND IMPROVEMENTS LOCATED AT 15 WEST FACTORY STREET, MECHANICSBURG, PENNSYLVANIA 17055, FILED ON BEHALF OF DOVENMVEHLE MORTGAGE, INC. Dovenmuehle Mortgage. Inc. ("DMI"). and Paul A. Rheaume (the "Debtor"), by and through their respective undersigned counsel. having settled all issues related to the Motion for Relief from the Automatic Stay with Respect to Real Propeny and Improvements Located at 15 West FactoI)' Street. Mechanicsburg, Pennsylvania 17055, Filed 011 BehalfofDovenmuehle Mortgage, Inc. (the "Motion"). hereby stipulate as follows: I. DMI is the holder of the recorded first Mongage against the Debtor's foregoing real property and improvements thereon (the "Property"). 2. Subsequent to commcncement of this casc, the Debtor has defaulted in the payment of rcgular monthly mortgage payments. and the post-petition arrearages, as of February 14, 2002, inclusive onatc charges ofS23.32 for each late payment. total S3,309.40, plus costs and attorneys fees ofS800.00. FILED HarrisburgiPA . TIME .A.M.-P.M. ','. fEB 2 O,200~ 09/18/2002 WED 15:16 [TX/RX ;\0 7086 J t4i 002 0.' ' ''',' ., ~ ~--- 8-18- 2 4:32 PM iHARVEY PENNINGTON 2155677323;# 3/ 5 (, , ,. . 3. For the foregoing reasons, DMI is entitled to relief from the automatic stay; provided, that the Debtor has offered to cure the foregoing post-petition arrearage amounts, and to remain current in future mortgage payments, as follows: a. Payment of the total post-petition arrearages in the amount of $4,209.40 as follows: $2,472.00 upon execution of this Stipulated Order, $824,03 on February 20, 2002, the regular March mortgage payment of $824.03 on March 6, 2002, and S893.28 on or before March 20, 2002; b. Upon entry of this Order, timely payment of all future regular monthly mortgage payments to OM! pursuant to the Debtors' Note and Mortgage. If all of the foregoing payments are made when due. DMI shall forbear from proceeding to foreclosure and sale of the Property. Ifany of the foregoing payments required by Paragraphs 3,a and 3.b is received by DMI more than fifteen (15) calendar days past the due date therefor, then DMI shall file a Certificate of Default with the Court. and forward copies thereof to the Debtor and Debtor's counsel. If the Debtor fails to cure the default cited in the Certificate of Defauh within ten days of the filing thereof. then DMI shall be free to proceed with foreclosure and sale of the Properly. at its option, without further order of this Court. 4. The parties have evidenced their consenl 10 the ternlS of this Stipulated .Otder by the signatures of their respective counsel affixed below and request that the Court enler this Stipulated Order. ID'" . ! J;izdh '.1. intcrstein, Jr., Esq. All ey for Dovenmuehle Mortgage, Inc. Timothy Attorney for Debtor IT IS SO ORDERED. 09/18/2002 WED 15:16 [TXlRX NO 7086 J i4i 003 , .. 9-18- 2 4:32 p~ ;HARVEY PENNINGTON 1'. . " " BY THE COURT; 'lIJflGbe/IJ. ~ , Hon. Robert Woodside ChiefU.S, Bankruptcy Judge Done this 4th day of April. 2002 , Harrisburg, PA FILED TlME_A.M.-P.M. APR'--.4. Clerk y~ruplcy Court . Deputv Clerk Per I 09/18/2002 WED 15:16 -, 1",-' h<_ '"~, '. ~_'_ ",-, ""wt 2155677323;# 4/ 5 [TX/RX NO 7086] i4i 004 , , '-, I "" I~.; , "';"," - ,'~ '~""'''''- 9-18- 2 4:32 PM ;HARVEY PENNINGTON c:1J~677323;# 5/ 5 UNITED STATES BANKRUPTCY COURT FOR THE MIDDLE DISTRICT OF PENNSYLVANIA-HARRISBURG Chapter 13 Inre: Bankruptcy Case No. 1-01-05473 PAUL A, RHEAUME, Debtor. TRUSTEE'S CONSENT TO STIPULATED ORDER RESOLVING MOTION FOR RELIEF FROM THE AUTOMATIC STAY, WITH RESPECT TO REAL PROPERTY AND IMPROVEMENTS LOCATED AT 15 WEST FACTORY STREET, MECHANICSBURG, PENNSYL VANIA 17055, . FILED ON BEHALF OF DOVRNMlTRHLE MORTGAGE, INC. ,- Charles J. DeHart, ill, the Chapter 13 Trustee in the above-captioned case, hereby consents to the foregoing Order, filed with the Court on February 20, 2002. Respectfully submitted, . ~ / f r 1l(ff .,fl- C es J. DeHart, illl , --- .- . Ch~pter 13 Trustee P.O. Box 410 HummelGtovvIl, P A 17036 FILED Harrisburg, PA TIME _A.M.-P.M. APR 4 2002 Clerk, Per 09/18/2002 WED 15:16 [TX/RX NO 7086 j i;1j 005 cil~~l:'~~~,ii$I~j~~'tt':b:J;.<'-'\Jf>~jil';m\!t.&m::,m\i')~~-@!!C""I"";d,,;,_;;.-:,g;j!"~";~;"@i;;~'r,:l''''''''''''''''.1j.di$-,m:&..' ~- ~"'-f' i7~ ~,!"~ ..~J" ", ~'" 0, ,,_, """~". ,~ ," .', r" ,~^ __~, ,~, ' ,.,' ,,~'T',~_ ~, _ . ~. Illi".~jj'itl " " - .. l , i I I I ! I I I () 0 .. ~ N fi? en ~}Ti fTI -< .C . :Xl -0 ir'j-:n 85 S;,. N r-' ::Qm ~.c{ w .uO ("'.... ' :;::c -0 ~(:, ~O ~.l,.. :x ;-<---M 0 <Jr C ~ Z J ~ On'l "> ~ (Xl 2i! > , I j ",I , , " "~,'"" ~~" C.;>ldbeck McCafferty & McKeever , BY, Joseph A. Goldbeck, Jr. Attorney LD. #16132 Suite 500 - The Bourse Bldg. 111 S. Independence Mall East Philadelphia, P A 19106 215-627-1322 Attorney for Plaintiff DOVENMUEHLE MORTGAGE CO. LP 1501 Woodfield Road Schaumburg, IL 60173-4982 IN THE COURT OF COMMON PLEAS Plaintiff of Cumberland County vs. PAUL A. RHEAUME (Mortgagor(s) and Record Owner(s)) 15 W. Factory Street Mechanicsburg, PA 17055 CIVIL ACTION - LAW ACTION OF MORTGAGE FORECLOSURE Defendant( s) No. 01-3054 Civil Term AFFIDAVIT PURSUANT TO RULE 3129 DOVENMUEHLE MORTGAGE CO. LP, Plaintiff in the above action, by its attorney, Joseph A. Goldbeck, Jr., Esquire, sets forth as of the date the praecipe for the writ of execution was filed the following information concerning the real property located at: IS W. Factory Street Mechanicsburg, P A 17055 I.Name and address of Owner(s) or Reputed Owner(s): PAULA. RHEAUME 15 W. Factory Street Mechanicsburg, PA 17055 2. Name and address of Defendant(s) in the judgment: PAUL A. RHEAUME IS W. Factory Street Mechanicsburg, PA 17055 3. Name and last known address of every judgment creditor whose judgment is a record lien on the property to be sold: P A DEPARTMENT OF PUBLIC WELFARE - Bureau of Child Support Enforcement Health and Welfare Bldg. - Room 432 P.O. Box 2675 Hanisburg, PA 17105-2675 DOMESTIC RELATIONS OF CUMBERLAND COUNTY PO Box 320 Carlisle, P A 17013 BENEFICIAL CONSUMER DISCOUNT CO. ... ~ I ." t.,..., -, L" ,- ';' ~ ~"''MJ>i',,"', . 4910 Carlisle Pike, Suite 104 Mechanicsburg, PA 17055 .. BENEFICIAL CONSUMER DISCOUNT CO. 961 Weigel Drive Elmhurst, IL 60126 4. Name and address of the last recorded holder of every mortgage of record: PENNSYLVANIA HOUSING FINANCE AGENCY 2101 N. Front Street Harrisburg, P A 5. Name and address of every other person who has any record interest in or record lien on the property and whose interest may be affected by the sale: 6. Name and address of every other person of whom the plaintiff has knowledge who has any record interest in the property which may be affected by the sale. 7. Name and address of every other person of whom the plaintiff has knowledge who has any interest in the property which may be affected by the sale. TIM COLGAN-ESQ The Wiley Group I South Baltimore Street Drillsburg, PA 17019 (attach separate sheet if more space is needed) I verify that the statements made in this affidavit are 1me and correct to the best of my personal knowledge or information and belief I understand that false statements herein are made subject to the penalties of 18 Pa. C.S. Section 4904 relating to unsworn falsification to authorities. GOLDBECK BY: Joseph A. dbec Attorney for Plaintiff & McKEEVER L,Esq. DATED: September 19, 2002 ~iiii~<W.iM.~J._iI!i:_._..a1Iim~"cii+_euiili.:......~f1l.....l;jfillj.~~.@1I~liIl!<>;~~.i1 ~. '-' tr -,- .,~-~--. --.~- ~."'" .,= ". ,~ ="" .. Iil~"""""___m'li ~~,~,~, "_, ,~"__ ,'_,~, ,~O"" < g ~.R1 ;J:j '"" :h. ~i!5 l8 !:::: ~ f.& ;q -0 I\) W -0 ::1: r\) " .0< :7:: if?;:; ;j?b1 ~<'O '""'6 :::;i__, ;~ji -:J(" ?::n< Q. ,>"1 ~~ ::0 --< N co ,;, . ;, F I I I. , L . 5i? ~ ..<,. ,-, . I ',' ~ ,,' ~.",~;(, 01-3054 Civil Term .. GOLDBECK McCAFFERTY & McKEEVER BY: Joseph A. Goldbeck, Jr. Attorney LD.#16132 Suite 500 - The Bourse Bldg. III S. Independence Mall East Philadelphia, P A 19106 215-627-1322 Attorney for Plaintiff DOVENMUEHLE MORTGAGE CO. LP 1501 Woodfield Road Schaumburg, IL 60173-4982 IN THE COURT OF COMMON PLEAS of Cumberland County Plaintiff vs. CIVIL ACTION - LAW PAUL A. RHEAUME Mortgagor(s) and Record Owner(s) ACTION OF MORTGAGE FORECLOSURE 15 W. Factory Street Mechanicsburg, P A 17055 Term No. 01-3054 Civil Term Defendant(s THIS LAW FIRM IS A DEBT COLLECTOR AND WE ARE ATTEMPTING TO COLLECT A DEBT. THIS NOTICE IS SENT TO YOU IN AN ATTEMPT TO COLLECT A DEBT. ANY INFORMATION OBTAINED FROM YOU WILL BE USED FOR THAT PURPOSE. NOTICE OF SHERIFF'S SALE OF REAL PROPERTY TO: RHEAUME, PAUL A. PAUL A. RHEAUME 15 W. Factory Street Mechanicsburg, PA 17055 Your house at 15 W. Factory Street, Mechanicsburg, PA 17055 is scheduled to be sold at Sheriffs Sale on Wednesday, March 05,2003, at 10:00 AM, in Commissioners Hearing Rm 2nd FL Courthouse to enforce the court judgment of$77,101.56 obtained by DOVENMUEHLE MORTGAGE CO. LP against YOll. NOTICE OF OWNER'S RIGHTS YOU MAY BE ABLE TO PREVENT THIS SHERIFF'S SALE To prevent this Sheriffs Sale you must take immediate action: 1. The sale will be cancelled if you pay to DOVENMUEHLE MORTGAGE CO. LP, the back payments, late charges, costs and reasonable attorney's fees due. To fmd out how much you must pay call: 215-627-1322 2. You may be able to stop the sale by filing a petition asking the Court to strike or open judgment, if the judgment was improperly entered. You may also ask the Court to postpone the sale for good cause. . ~.. 'v . -,~ Ito' 01-3054 Civil Term . 3. You may also be able to stop the sale through other legal proceedings. You may need an attorney to assert your rights, The sooner you contact one, the more chance you will have of stopping the sale. (See notice below 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 NOT TAKE PLACE. I. If the Sheriffs Sale is not stopped, your property will be sold to the highest bidder. You may fmd out the price bid price by calling the Sheriff of717-240-6390. 2. You may be able to petition the Court to set aside the sale if the bid price was grossly inadequate compared to the value of your property. 3. The sale will go through only if the buyer pays the Sheriff the full amount due in the sale. To fmd out if this has happened, you may call the Sheriff of717-240-6390. 4. Ifthe amount due from the Buyer is not paid to the Sheriff, you will remain the owner of the property as if the sale never happened. 5. You have a right to remain in the property until the full amount due is paid to the Sheriff and the Sheriff gives a deed to the buyer. At that time, the buyer may bring legal proceedings to evict you. 6. You may be entitled to a share of the money which was paid for your house. A schedule of distribution of the money bid for your house will be filed by the Sheriff thirty (30) days from the date of the Sheriffs 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 schedule of distribution is filed. 7. You may also have other rights and defenses, or ways of getting your house back, if you act immediately after the sale. YOU SHOULD TAKE THIS PAPER TO YOUR LAWYER AT ONCE. IF YOU DO NOT HAVE A LAWYER OR CANNOT AFFORD ONE, GO TO OR TELEPHONE THE OFFICE LISTED BELOW TO FIND OUT WHERE YOU CAN GET LEGAL HELP. CUMBERLAND COUNTY BAR ASSOCIA nON 2 Liberty Avenue Carlisle, PA 17013 LEGAL SERVICES INC 8 Irvine Row Carlisle, PA 17013 ~~~1I1_m~~~~.8:clIa~~i;mmk)!!J",~J.Yllfu<,~il.,j,"'J..rJ,;M~1bo:~?~'<"'L"l!'",,~;'~'~""'';-~tklf.Qi!l.~IIUlldW~'-- ~. J _ _ .~". _~ mc~_ ~-~ ""'''~~~ ~~, .-" n . . (j 0 0 c: N ~ ..,., en -:;;j rr'I ;?;:n " i-a r- s: N ;g,m ~-z w ;;-7 ;,:::c " -~C> ~Q :-.r=+: "'-0 :x ~?5 :i>c: ~ om ~i -:-I N ~ '""'. co 'f[ I" _" ...,. -", -". .Ji~~"_ , Jospeh A. Goldbeck, Jr. Attorney LD. #16132 Suite 500 - The Bourse Bldg. III S. Independence Mall East Philadelphia, PA 19106 215-627-1322 Attorney for Plaintiff DOVENMUEHLE MORTGAGE CO. LP 1501 Woodfield Road Schaumburg, II. 60173-4982 Plaintiff IN THE COURT OF COMMON PLEAS vs. PAULA. RHEAUME Mortgagor(s) and Record Owner(s) IS W. Factory Street Mechanicsburg, P A 17055 of Cumberland County CIVIL ACTION - LAW Defendant(s) ACTION OF MORTGAGE FORECLOSURE NO. 01-3054 Civil Term CERTIFICATION AS TO THE SALE OF REAL PROPERTY I, Joseph A. Goldbeck, Jr., Esquire hereby certify that I am the attorney of record for the Plaintiff in this action, and I further certify that this property is subject to Act 91 of 1983 and the Plaintiff has complied with all the provisions of the Act Joseph A. Goldbe Jr. Attorney for plain' f ~~MWJlii~~~"~\l'!if-j;;"';!Ii;;,/i:ll.Q:"~:I!<li<iliir.Ia<""~$.sl<"'E'''''}!.?hi,:,''il'''''';\''''!"'.'llijillJ!lb!l!i<1.ili\I';jii~""''''~'''--''''''liiiIl' ." _,~<<, _ ,_'~_ ~~~~~ "~., tt~_~ "~,<"",,,_,, .",_,,"_ "~_ _,~"~, ~,-" _~_, _~~""'",.>. ,,',"~''''-;~'~" 'N ~" '" .~ ~ ._~~, ~ .,~_ ,..,. ,~ ii2i:-1l:lI:~11~1~"~ ~." ." -." .-, - ~" , .~ <::> (':) N .'" V> '-1 rr'I :r--,., " (Or. N ,""rn ~.~ <..) ~~oO ;;:::0 C:;\S i8 " x-' :x 2~ ~ I\J -m .. ~ I'.> ~ CO .....< ~ ,,~. m "", , 0"-' ~ - -1", '~ " ".~ -,,',~ "'~- '~"",'-" . " "~ ,.., -...,-.....,.',...~ ~', ~. <", i ~tL THAT ~AINit~act Or ~~cel of land situate on the sooth side of Weet ractory Str""t, 4th ""rd. in the Borough of /1l>chanicsburg, County of CUl!Ib<>rland .nd St.ate of .Pvn1~YIVania(' more particularly bounded and oescribed as tol1owst BECINNING at a pJi~t on th. BOuth~rn 11~e of Fa~tory Street, said POint bei"9 mea.ur~ i~ . southwesterly direction t~ hundred sixty (260.00) feet It''OIn the C1outhW'edt COtl14Jr of Factory Street land M.!Irket Street: thence lIOoth 21 d&qr~e~ 2$ mi~te8 East along the western line of landa now Or formerly of Aaron c. KApp p dietance of on~ hundred nineteen and sixteen hundredths (119.16) foot to i> hub on the northern iine of a fifteen (15.00) foot "ide alley: th.nce S01J~ 71 Q~t"ee3 33 mlnute3 Weat along Baid n9~th~ro lin~ Qf alley a distance of sixty-one (61.00) feet to a hub: thence North 18 degree3 27 minuteo W~~t aaong th@ taatern line ot lands n~ or !o~er1y of John H. Weigel, Jr., a dif'tancm of on~ hundred nin~teen (119.00) f~t to a hub on the aouthern line of acto~ Street; th~ce Nor~h 71 ~~e~3 33 minutee East alQng saId 5Outh.rn 11n or ~<<ctory Street a distAhce ot ttfty-tou~ end eighty-thcee hundredtha (54.a31 feet to a hub, the point and Place of aBGINNING. , "~VINC thereoh er~ted a 2% story fr~me dw~lling and detached frame garagv kno<m and numbere<j as 15 w.oet r4ctory Street. i OOOER AND Sl,JeJtcT~ neverthelealj:, to Cl:asements, .cBBtrictions, reservations, conditione and rights of "ay of record. i TAX PARCEL # 19-22-0519-083 PROPERTY ADDRESS: 15 W. Factory Street, Mechanicsburg, PA 17055 IMPROVEMENTS: A residential dwelling. SOLD AS THE PROPERTY OF: PAUL A. RHEAUME I, : ~J.>rili!il'IM<m;lIl!:lil>:iM;li,\;<IIi/!!!M;H3,,g,-~~~~~'1~OO!li;Ja~i'i-,~~.6.;g!.,,.:;""'''''i!!1lii\tdd.~iilli!iw,;~~~ ~~ ~~IM 1. r IILlUI ~~' " I ~JJ]II,U] Ll)J!m~',mL =J.,-,J", ^ .""x, ,,,~.,,~,J>J!~._ " ,~ "'-"'~"";">""""~~~"'~""~' ,",.=,_., "~,, ' ,__ ~"~ ~ ~'- ~.4 - .~ , . <r;,__r . ,~., '.".~' "7"'M_ "~~ I 1;i !'i , Ii I il " ':1 I: t! Ii 'I ii 'I II il II I !! , '"~, -~ , ,- ~"' " "N'. < --~ ,: .. In the Court of Common Pleas of Cumberland County DOVENMUEHLE MORTGAGE CO. LP 1501 Woodfield Road Schaumburg, IL 60173-4982 Plaintiff vs. PAUL A. RHEAUME (Mortgagor(s) and Record Owner(s)) 15 W. Factory Street Mechanicsburg, PA 17055 No. 01-3054 Civil Term Defendant( s) PRAECIPE FOR JUDGMENT THIS LAW FIRM IS A DEBT COLLECTOR AND WE ARE ATTEMPTING TO COLLECT A DEBT OWED TO OUR CLIENT. ANY INFORMATION OBTAINED FROM YOU WILL BE USED FOR THE PURPOSE OF COLLECTING THE DEBT. Enter the Judgment in favor of Plaintiff and against PAUL A. RHEAUME by default for want of an Answer. Assess damages as follows: Debt $77,101.56 Interest - 0 I/O 1/200 1 to 09/19/2002 Total (Assessment of Damages attached) I CERTIFY THAT FOREGOING ASSESSMENT OF DAMAGES IS FOR SPECIFIED AMOUNTS ALLEGED TO BE DUE IN THE COMPLAINT AND IS CALCULABLE AS A SUM CERTAIN FROM THE COMPLAINT. I certify that written notice of the intention to file this praecipe was mailed or delivered to the party against whom judgment is to be entered and to his attorney of record, if any, after the default occurred and at least ten days prior to the date of the filing of this praecipe. A copy ofthe notice is attached. R.C.P. 237.1 Attorney for !.D. #16132 AND NOW , , Judgment is entered in favor of DOVENMUEHLE MORTGAGE CO. LP and against PAUL A. RHEAUME by default for want of an Answer and damages assessed in the sum of $77,101.56 as per the above certification. Prothonotary 8-18- 2 4:32 PM ;HARVEY PENNINGTON 2155677323;# 2/ 5 , , UNITED STATES BANKRUPTCY COURT FOR THE MIDDLE DISTRICT OF PENNSYL VANIA-HARRISBURG Chapter 13 In re: PAUL A. RHEAUME, Bankruptcy Case No. 1-01-05473 Debtor. STIPULATED ORDER RESOLVING MOTION FOR RELIEF.FROM THE AUTOMATIC STAY, WITH RESPECT TO REAL PROPERTY AND IMPROVEMENTS LOCATED AT 15 WEST FACTORY STREET, MECHANICSBURG, PENNSYLV ANI..\ 17055, FILED ON BEHALF OF DOVENMUEHLE MORTGAGE, INC. DovenmuehJe Mortgage. Inc. ("DMI"). and Paul A. Rheaume (the "Debtor"), by and through their respective undersigned counsel. ha\'ing settled all issues related to the Motion for Relief from the Automatic Stay with Rcspect to Rcal Property and Improvements Located at 15 West Factory Street. Mechanicsburg. Pennsylvania 17055. Filed on BehalfofDovenmuehle Mortgage, Inc. (the "Motion"), hereby stipulate as follows: L DMl is the holdcr of thc rccordcd first Mortgagcagainst the Debtor's foregoing real property and impro\'cmcnts thcrcon (the "Propcrt.y"). 2. $ubscquenlto commenecment of this case. the Dcbtor has dcfaultcd in the paymcnt of regular monthly mortgagc paymcnts. and thc post-petition arrearages, as of February 14,2002, inclusive oflate charges ofS23.32 for each laIc paymCl1\. lotal $3,309.40, plus costs and attorneys fees ofS800.00. FilED Hamsburg;PA . TIME _.A.M.' P.M. '.... FEB 2 O~<<O~ Cterk, Per 09/18/2002 WEO 15:15 (TX/RX NO 70R6) id.1 0(,2 9-18- 2 4:32 PM ;HARVEY PENNINGTON 2155677323;# 3/ 5 " ,. . 3. For the foregoing reasons, DMI is entitled to relief from the automatic stay; provided, that the Debtor has offered to cure the foregoing post-petition arrearage amounts, and to remain current in future mortgage payments, as follows: a. Payment of the total post-petition arrearages in the amount of $4,209.40 as follows: $2,472,00 upon execution of this Stipulated Order, $824.03 on February 20, 2002, tIle regular March mortgage payment of $824.03 on March 6. 2002, and $893,28 on or before March 20, 2002; b, Upon entry of this Order. timely payment of all future regular monthly mortgage payments to DMl pursuant to the Debtors' Note and Mortgage, If all of the' foregoing payments are made when due, DMI shall forbear from proceeding to foreclosure and sale of the Property, If any of the foregoing payments required by Paragraphs 3,a and 3,b is received by DMI more than fifteen (15) calendar days past the due date therefor, then DMI shall file a Certificate of Default with the Court, and forward copies thereof to the Debtor and Debtor's counsel. (fthe Debtor fails to cure the dcfaull cited in the Certificate of Default within ten days of the filing thereof, then DMI shall be free to proceed with foreclosure and sale of the Property. at its option, without further order of this Court, 4. The parties have e\'idenced their consent to the lemlS of this Stipulated Order by the signatures of their respective counscl affixed below and rcqucst that the Court enter this Stipulated Order. UDcbtorU ~. Allomey for Dcbtor ID'" . !~(h: 'J. interstein. Jr.. Esq. All ey for Dovenmuehle Mortgage, IIlC, IT IS SO ORDERED. 09/18/2002 WED 15:16 (TX/RX NO 7086 J i;t 003 .' . 9-18- 2 4:32 PM ;HARVEY PENNINGTON ~ " BY THE COURT: lllRobe1tJ. ~ . Hon. Robert Woodside Chief U.S. Bankruptcy Judge Done this 4th day of April, 2002 , Harrisburg, PA FILED TlME__A.M.-P,M. ~~4. . Clerk ~Rari'krup\Oy Court . VLT'" 0 u CIeri< Per 09/18/2002 WED 15:16 .. ~',~" '~',I ~..' ,_, ,. "J.. ,-,' , '-, 'ii~',_ ,. '1'. 2155677323;# 4/ 5 lTX/RX NO 7086] i4i 004 ,-, ,," , I '""."~' , ~ .,;,,' ~"i" 9-18- 2 4:32 PM jHARVEY PENNINGTON ~~677323;# 5/ 5 UNITED STATES BANKRUPTCY COURT FOR THE MIDDLE DISTRICT OF PENNSYL V ANIA-HARRlSBURG lnre: Chapter 13 . Bankruptcy Case No. 1-01-05473 PAUL A. RHEAUME, . Debtor. TRUSTEE'S CONSENT TO STIPULATED ORDER RESOLVING MOTION FOR RELIEF FROM THE AUTOMATIC STAY, WITH RESPECT TO REAL PROPERTY AND IMPROVEMENTS LOCATED AT 15 WEST FACTORY STREET, MECHANICSBURG, PENNSYLVANIA 17055, . FTLRD ON BER ALF OF DOVRNMlJRlTLR MORTGAGR, TNC. ,- Charles J. DeHart, TII, the Chapter 13 Trustee in the above-captioned case, hereby consents to the foregoing Order, filed with the Court on February 20, 2002. Respectfully submitted, . ,/ I / __ ;:~d--ft1111---ri:Lf r C;;re;J.Dmart, IIII , --- Ch\('pter 13 Trustee P.o. Box 410 Hummelstown, P A 17036 FILED Harrisburg, PA TIME_A.M.-P.M. APR 4 2002 Clerk, Per 09/18/2002 WED 15:16 (TXlRX liD 7086 J @005 ",,~I, .'.> '.., , "","~ '.'~'~'''-' i ., JUt 2 02001 rfJ " GOLDBECK MCCAFFERTY & MCKEEVER JOSEPH A. GOLDBECK, JR. Attorney 1.0.#16132 Suite 500-The Bourse Building 111 S. Independence Mall East Philadelphia, PA 19106 215-627-1322 BY: MICHAEL T. MCKEEVER, Attorney 1.0. #56129 Attorney for Plaintiff vs COURT OF COMMON PLEAS DOVENMlJEHLE MORTGAGE CO. LP 1501 Woodfield Road Schaumburg, IL 60173-4982 OF CUMBERLAND COUNTY No. 01-3054 Civil Term PAUL A. RHEAUME (Mortgagor and Real Owner) 15 W. Factory Street 'Mechanicsburg, PA 17055 ORDER ? 2rd AND NOW, this A...J day of :J l,L~ 2001, upon consideration of the Plaintiff's Motion for Substituted Service under Pa.R.C.P. 430(a) and it appearing to the Court that Plaintiff's good faith efforts to ascertain the present whereabouts of Defendant has been unsuccessful, it is, ORDERED and DECREED: that Plaintiff's Motion is granted and the Sheriff and/or Plaintiff is directed to Serve the Complaint in Mortgage FOreclosure upon Defendant by posting a copy of the the premiseS~15 W. Factory Street, Mechanicsburg, Complaint upon PA 17055 and Plaintiff is directed to serve the Complaint by certified and regular mail to the Defendant's last known address Of~5 W. Factory Street, Mechanicsburg, PA 17055 and that all further service of .~ - . legal papers, including but not limited to motions, petitions and rules be made by certified and regular mail to Defendant's last known address and that Notice of Sheriff Sale pursuant to Pennsylvania Rule of Civil Procedure 3129 may be made upon Defendants by sending copies of same to Defendant's last known address by certified and regular mail and by posting the premises, BY THE COURT: /?/ tJ'1(JU! E ~'jL) J', ." '" .~" 'I -'~. '" .-', ~, ",-, _1 ' , ,"-,- -. .'- 0..:...,'" 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 DOVENMUEHLE MORTGAGE CO. LP 1501 Woodfield Road Schaumburg, IL 60173-4982 IN THE COURT OF COMMON PLEAS OF CUMBERLAND COUNTY vs. PAUL A. RHEAUME -(Mortgagor (s) and Record Owner(s)-) Term No. 01-3_054 (Civil Term) 15 W. Factory Street Mechanicsburg, PA ~7055 CERTIFICATE OF SERVICE - - JOSEPH A. GOLDBECK,'cJR; ESQUIRE herePy certifies that on August 10, 2001 he did serve upon-Defendant(s) PAUL A. RHEAUME a true andcorrecLcopy of toe above-captioned Complaint by certified and regular mail in accordance with the Court Order dated July 23, 2001. The undersigned understands that the statements herein and subject to the penalties provided by 18 P.S. Section 4904. R"'P"'tf~~d' JOSEPH A. GOLDBECK, JR. ESQUIRE ,"",,,,,,," ,. .'. ~- ~" li-"f SHERIFF'S RETURN - REGULAR CASE NO: 2001-03054 P COMMONWEALTH OF PENNSYLVANIA: COUNTY OF CUMBERLAND DOVENMUEHLE MORTGAGE CO LP VS RHEAUME PAUL A BRIAN BARRICK , Sheriff or Deputy Sheriff of cumberland County,pennsylvania, who being duly sworn according to law, says, the within COMPLAINT - MORT FORE was served upon RHEAUME PAUL A the DEFENDANT , at 2112:00 HOURS, on the 8th day of Au~ust , 2001 at 15 W FACTORY ST ME CHAN I CSBURG , PA 17055 by handing to PROPERTY POSTED AT 15 W FACTORY ST MECHANICSBURG a true and attested copy of COMPLAINT - MORT FORE together with and at the same time directing His attention to the contents thereof. Sheriff's Costs: Docketing Service posting surcharge So Answers: 18.00 5.85 6.00 10.00 .00 39.85 ~~'-~<:-?,~ R. Thomas Kline 08/09/2001 GOLDBECK MCCAFFERTY Sworn and Subscribed to before By: me this day of A.D. Prothonotary ,,~ I "~! '_ I I' , ;..,,1 ,~" ' ... , .,'~' i ~'v",",- ""'-'" ,"~.L :lil, TO: PAUL A. RHEAUME 15 W. Factory Street Mechanicsburg, PA 17055 DOVENMUEHLE MORTGAGE CO. LP 1501 Woodfield Road Schaumburg, IL 60173-4982 Plaintiff vs. PAUL A. RHEAUME (Mortgagor(s)) (Record Owner(s)) 15 W. Factory Street Mechanicsburg, PA 17055 Defendant(s) IN THE COURT OF COMMON PLEAS OF CUMBERLAND COUNTY CIVIL ACTION - LAW ACTION OF MORTGAGE FORECLOSURE Term No. 01-3054 (Civil Term) THIS LAW FIRM IS A DEBT COLLECTOR AND WE ARE ATTEMPTING TO COLLECT A DEBT OWED TO OUR CLIENT. ANY INFORMATION OBTAINED FROM YOU WILL BE USED FOR THE PURPOSE OF COLLECTING THE DEBT. TO: PAUL A. RHEAUME 15 W. Factory Street Mechanicsburg, PA 17055 DATE OF THIS NOTICE: August 31, 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 Is! Joa~oh ..A. (jotdbeck. Jr. GOLDBECK McCAFFERTY I'< 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 , " ''"-, , "', . "" ." '''' . fi<' :,_~ _~"' ,~i'_J,"' ,"' 1'" ", TO: TIM COLGAN-ESQ THE WILEY GROUP 1 South Baltimore Street Dillsburg, PA 17019 DOVENMUEHLE MORTGAGE CO. LP 1501 Woodfield Road Schaumburg, IL 60173-4982 Plaintiff vS. PAUL A. RHEAUME (Mortgagor(s)) (Record Owner(s)) 15 W. Factory Street Mechanicsburg, PA 17055 Defendant(s) IN THE COURT OF COMMON PLEAS OF CUMBERLAND COUNTY CIVIL ACTION - LAW ACTION OF MORTGAGE FORECLOSURE Term No. 01-3054 (Civil Term) THIS LAW FIRM IS A DEBT COLLECTOR lWD WE ARE ATTEMPTING TO COLLECT A DEBT OWED TO OUR CLIENT. ANY INFORMATION OBTAINED FROM YOU WILL BE USED FOR THE PURPOSE OF COLLECTING THE DEBT. TO: TIM COLGAN-ESQ THE WILEY GROUP 1 South Baltimore Street Dillsburg, PA 17019 DATE OF THIS NOTICE: August 31, 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/ JO:Jeph .A. (jotdbect. 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 Rule of Civil Procedure No. 236 - Revised IN THE COURT OF COMMON PLEAS OF Cumberland COUNTY, PENNSYLVANIA CIVIL ACTION - LAW DOVENMUEHLE MORTGAGE CO. LP 1501 Woodfield Road Schaumburg, II. 60173-4982 Plaintiff No. 01-3054 Civil Term vs. PAUL A. RHEAUME (Mortgagors and Record Owner(s)) 15 W. Factory Street Mechanicsburg, PA 17055 Defendant( s) THIS LAW FIRM IS A DEBT COLLECTOR AND WE ARE ATTEMPTING TO COLLECT A DEBT OWED TO OUR CLIENT. ANY INFORMATION OBTAINED FROM YOU WILL BE USED FOR THE PURPOSE OF COLLECTING THE DEBT. NOTICE Notice is given that a jndgment in the above-captioned matter has been entered against you. Curt Long Prothonotary By: Deputy If you have any questions concerning the above, please contact: Joseph A. Goldbeck, Jr. Goldbeck McCafferty & McKeever Suite 500 - The Bourse Bldg. 111 S. Independence Mall East Philadelphia, PA 19106 215-627-1322 ,-~~ ~ j" ,-I ,- I~ ~ ~~- ,,,,;',, "".- -,"," ,,,<--,,''] 'J:.if, GOLDBECK McCAFFERTY & McKEEVER BY: Joseph A. Goldbeck, Jr. Attorney LD. #16132 Suite 500 - The Bourse Bldg. III S. Independence Mall East Philadelphia, PA 19106 215-627-1322 Attorney for Plaintiff DOVENMUEHLE MORTGAGE CO. LP 1501 Woodfield Road Schaumburg, IL 60173-4982 IN THE COURT OF COMMON PLEAS Plaintiff of Cumberland County VS. PAUL A. RHEAUME (Mortgagor(s) and Record owner(s)) 15 W. Factory Street Mechanicsburg, P A 17055 CIVIL ACTION LAW ACTION OF MORTGAGE FORECLOSURE Defendant( s) No. 01-3054 Civil Term ORDER FOR JUDGMENT Please enter Judgment in favor of DOVENMUEHLE MORTGAGE CO. LP, and against PAUL A. RHEAUME for failure to file an Answer in the above action within (20) days (or sixty (60) days if defendant is the United States of America) from the date of service of the Complaint, in the sum of$77,101.56. Joseph A Goldbe Attorney for Plain 'f I hereby certify that the above names are correct and that the precise residence address of the judgment creditor is DOVENMUEHLE MORTGAGE CO. LP 1501 Woodfield Road Schaumburg, II. 60173-4982 and that the name(s) and last known address(es) of the Defendant(s) is/are PAUL A. RHEAUME, 15 W. Factory Street Mechanicsburg, PA 17055; TY & McKEEVER Jr. , ,[ '. ~ - 1_ J TO THE PROTHONOTARY: ASSESSMENT OF DAMAGES Kindly assess the damages in this case to be as follows: Principal Balance Interestfrom 01101/2001 through 09/19/2002 Attorney's Fee at 5.0000% of principal balance Late Charges Costs of Suit and Title Search Escrow Balance Deficit AND NOW, this day of $58,958.21 $8,087.92 $2,947.91 $824.00 $560.00 $5,723.52 ($0.00) "' -,I ~ ~-, "- ,-'" ,.O"hf' $77,101.56 , 2002 damages are assessed as above. GOLDBECK \\FF Y & McKEEVER BY: Joseph A. 0 dbeck Attomey for PIal tiff Pro Prothy . ,l 1'1 ~,~,' " _, 0 ; ~'~\.'" -, "; ~*,;,-- k....""JJi VERIFICATION OF NON-MILITARY SERVICE The undersigned, as the representative for the Plaintiff corporation within named do hereby verify that I am authorized to make this verification on behalf of the Plaintiff corporation and that the facts set forth in the foregoing verification of Non- Military Service are true and correct to the best of my knowledge, information and belief. I understand that false statements therein are made subject to penalties of 18 Pa. C.S. 4904 relating to unsworn falsification to authorities. 1. That the above named Defendant, PAUL A. RHEAUME, is about unknown years of age, that Defendant's last known residence is 15 W. Factory Street, Mechanicsburg, PA 17055, and is engaged in the unknown business located at unknown address. 2. That Defendant is not in the Military or Naval Service of the United States .or its Allies, or otherwise within the provisions of the Soldiers' and Sailors' Civil Relief Action of Congress of 1940 and its Amendments. Date: "~ ,. ".- , " ,'~' ~"",-"..,;;-- .". ',- I~ Goldbeck McCafferty & McKeever BY: Joseph A. Goldbeck, Jr. Attorney LD. #16132 Suite 500 - The Bourse Bldg. III S. Independence Mall East Philadelphia, P A 19106 215-627-1322 Attorney for Plaintiff DOVENMUEHLE MORTGAGE CO. LP 1501 Woodfield Road Schaumburg, II. 60173-4982 IN THE COURT OF COMMON PLEAS Plaintiff of Cumberland County vs. PAUL A. RHEAUME (Mortgagor(s) and Record Owner(s)) 15 W. Factory Street Mechanicsburg, PAl 7055 CIVIL ACTION - LAW ACTION OF MORTGAGE FORECLOSURE Defendant( s) No. 01-3054 Civil Term AFFIDAVIT PURSUANT TO RULE 3129 DOVENMUEHLE MORTGAGE CO. LP, Plaintiff in the above action, by its attorney, Joseph A. Goldbeck, Jr., Esquire, sets forth as of the date the praecipe for the writ of execution was filed the following information concerning the real prope11y located at: 15 W. Factory Street Mechanicsburg, P A 17055 LName and address ofOwner(s) or Reputed Owner(s): PAUL A. RHEAUME 15 W. Factory Street Mechanicsburg, PA 17055 2. Name and address of Defendant(s) in the judgment: PAUL A. RHEAUME 15 W. Factory Street Mechanicsburg, P A 17055 3. Name and last known address of every judgment creditor whose judgment is a record lien on the property to be sold: P A DEPARTMENT OF PUBLIC WELFARE - Bureau of Child Support Enforcement Health and Welfare Bldg. - Room 432 P.O. Box 2675 Harrisburg, PA 17105-2675 DOMESTIC RELATIONS OF CUMBERLAND COUNTY PO Box 320 Carlisle, P A 17013 BENEFICIAL CONSUMER DISCOUNT CO. " -'-I -~ ~,. ," "~"" " ,-, --l'-'-"'rk: 4910 Carlisle Pike, Suite 104 Mechanicsburg, PAl 7055 BENEFICIAL CONSUMER DISCOUNT CO. 96 I Weigel Drive Elmhurst,IL 60126 4. Name and address of the last recorded holder of every mortgage of record: PENNSYLVANIA HOUSING FINANCE AGENCY 210 I N. Front Street Harrishurg, P A 5. Name and address of every other person who has any record interest in or record lien on the property and whose interest may be affected by the sale: 6. Name and address of every other person of whom the plaintiff has knowledge who has any record interest in the property which may be affected by the sale. 7. Name and address of every other person of whom the plaintiff has knowledge who has any interest in the property which may be affected by the sale. TIM COLGAN-ESQ The Wiley Group I South Baltimore Street DriIlsburg, PA 17019 (attach separate sheet if more space is needed) I verify that the statements made in this affidavit are true and correct to the best of my personal knowledge or information and belief. I understand that false statements herein are made subject to the penalties of 18 Pa. C.S. Section 4904 relating to unsworn falsification to authorities, DATED: September 19,2002 GOLDBECK & McKEEVER r., Esq. .0 '"". --'-'-'",1 ,=, ," '-".-- .' ,.. > --.~ ~~.- '~'""-~';;j:; 01-3054 Civil Term GOLDBECK McCAFFERTY & McKEEVER BY: Joseph A. Goldbeck, Jr. Attorney LD.#16132 Suite 500 - The Bourse Bldg. IllS. Independence Mall East Philadelphia, PA 19106 215-627-1322 Attomey for Plaintiff DOVENMUEHLE MORTGAGE CO. LP 1501 Woodfield Road Schaumburg, II. 60173-4982 IN THE COURT OF COMMON PLEAS of Cumberland County Plaintiff vs. CIVIL ACTION - LAW PAUL A. RHEAUME Mortgagor(s) and Record Owner(s) ACTION OF MORTGAGE FORECLOSURE 15 W. Factory Street Mechanicsburg, P A 17055 Term No. 01-3054 Civil Term Defendant( s THIS LAW FIRM IS A DEBT COLLECTOR AND WE ARE ATTEMPTING TO COLLECT A DEBT. THIS NOTICE IS SENT TO YOU IN AN ATTEMPT TO COLLECT A DEBT. ANY INFORMATION OBTAINED FROM YOU WILL BE USED FOR THAT PURPOSE. NOTICE OF SHERIFF'S SALE OF REAL PROPERTY TO: RHEAUME, PAULA. PAUL A. RHEAUME 15 W. Factory Street Mechanicsburg, PA 17055 Your house at 15 W. Factory Street, Mechanicsburg, P A 17055 is scheduled to be sold at Sheriffs Sale on Wednesday, March 05, 2003, at 10:00 AM, in Commissioners Hearing Rm 2nd FL Courthouse to enforce the court judgment of $77, 101.56 obtained by DOVENMUEHLE MORTGAGE CO. LP against you. NOTICE OF OWNER'S RIGHTS YOU MAY BE ABLE TO PREVENT THIS SHERIFF'S SALE To prevent this Sheriffs Sale you must take immediate action: I. The sale will be cancelled if you pay to DOVENMUEHLEMORTGAGE CO. LP, the back payments, late charges, costs and reasonable attorney's fees due. To find out how much you must pay call: 215-627-1322 2. You may be able to stop the sale by filing a petition asking the Court to strike or open judgment, if the judgment was improperly entered. You may also ask the Court to postpone the sale for good cause. ~ , . '" .-,,-- ',^d 01-3054 Civil Term 3. You may also be able to stop the sale through other legal proceedings. You may ueed an attomey to assert your rights. The sooner you contact one, the more chance you will have of stopping the sale. (See notice below on how to obtain an attomey). YOU MAY STILL BE ABLE TO SAVE YOUR PROPERTY AND YOU HAVE OTHER RIGHTS EVEN IF THE SHERIFF'S SALE DOES NOT TAKE PLACE. I. If the Sheriffs Sale is not stopped, your property will be sold to the highest bidder. You may find out the price bid price by calling the Sheriff 0017-240-6390. 2. You may be able to petition the Court to set aside the sale if the bid price was grossly inadequate compared to the value of your property. 3. The sale will go through only if the buyer pays the Sheriff the full amount due in the sale. To find out if this has happened, you may call the Sheriff of 71 7-240-6390. 4. If the amount due from the Buyer is not paid to the Sheriff, you will remain the owner of the property as if the sale never happened. 5. You have a right to remain in the property until the full amount due is paid to the Sheriff and the Sheriff gives a deed to the buyer. At that time, the buyer may bring legal proceedings to evict you. 6. You may be entitled to a share of the money which was paid for your house. A schedule of distribution of the money bid for your house will be filed by the Sheriff thirty (30) days from the date of the Sheriffs 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 (l0) days after the schedule of distribution is filed. 7. You may also have other rights and defenses, or ways of getting your house back, if you act immediately after the sale. YOU SHOULD TAKE THIS PAPER TO YOUR LAWYER AT ONCE. IF YOU DO NOT HAVE A LAWYER OR CANNOT AFFORD ONE, GO TO OR TELEPHONE THE OFFICE LISTED BELOW TO FIND OUT WHERE YOU CAN GET LEGAL HELP. CUMBERLAND COUNTY BAR ASSOCIA TJON 2 Liberty Avenue Carlisle, PA 17013 LEGAL SERVICES INC 8 Irvine Row Carlisle, PA 17013 ~. .. -,'. "'-"~ >'~ PRAECIPE FOR WRIT OF EXECUTION - (MORTGAGE FORECLOSURE) P.R.C.P 3180-3183 Joseph A. Goldbeck, Jr. Attomey LD.#16132 Suite 500 - The Bourse Bldg. III S. Indepeudeuce Mall East Philadelphia, P A 19106 215-627-1322 Attorney for Plaintiff DOVENMUEHLE MORTGAGE CO. LP 1501 Woodfield Road Schaumburg, II. 60173-4982 IN THE COURT OF COMMON PLEAS Plaintiff vs. of Cumberlaud Couuty PAUL A. RHEAUME Mortgagor(s) and Record Owner(s) 15 W. Factory Street Mechanicsburg, P A 17055 CIVIL ACTION - LAW ACTION OF MORTGAGE FORECLOSURE Defendant( s) No. 01-3054 Civil Term PRAECIPE FOR WRIT OF EXECUTION TO THE PROTHONOTARY: Issue Writ of Execution in the above matter: Amouut Due Iuterest from 01/01/2001 to 09/19/2002 at 8.0000% $77,101.56 (Costs to be added) GOLDBECK McC ER'I: BY: Joseph A. Gold eck, Jr Attomey for Plaiutiff - ., ,~. ..' -I, ~ rLJ Z "" 0 < >-l ..... il 1"1 ~ ~ ~ - >-l 0 ~ ~ ~ M ~ i>< U ~ U~ " ~::E~\O aZ ~ ~~....~ s:J ~ ~~"'O ~~ (j :;;:0"1"- 1"1 iJ: " .,- -< "- ....$ ~~~~N (j ~]~~ cg8<~ ~ oil .~ 0 <r: u >. A.. E-< ::: "",,:QBp,."7 !iuu 0 ~~~~ CI,) (l)"'!j e'G"'r--- ....... :;;: on ~i !fir:: ".~ N > ~ Cl) ,.J:::l \0 E-<:g0 ~ . e ~,.o U I e-..B<.,', ~C';l~13 "'E-< >-l-;;;-~ 'S ~.. ~g]~~ 8~ 01:: ~ ~~V)] ...~ ..::.::lr) :;:l 00 ~ --< bO_ u rJ~u5~ """ " I"I~ ov....._ Zu ~ :;;: ..0"_ i>< :gr/.:l_ 1"1 ~ ..... ~ 0 U 0 == > 6 ~ " E-< 0 ~ "' i>< ",-03 {'_,_' '~ '" '.N;26f = -" , ,-" " '~~.'~ ""'~':- i' WRIT OF EXECUTION - (MORTGAGE FORECLOSURE) P.R.C.P. 3180-3183 AND Rule 3257 DOVENMUEHLE MORTGAGE CO. LP 1501 Woodfield Road Schaumburg, II. 60173-4982 In the Court of Common Pleas of Cumberland County vs. PAUL A. RHEAUME 15 W. Factory Street Mechanicsburg, P A 17055 No. 01-3054 Civil Term Commonwealth of Pennsylvania: WRIT OF EXECUTION (MORTGAGE FORECLOSURE) County of Cumberland To the Sheriff of Cumberland Connty,_Pennsylvania To satisfy the judgment, interest and costs in the above matter you are directed to levy upon and sell the following described property: PREMISES: 15 W. Factory Street Mechanicsburg, PA 17055 See Exhibit "A" attached AMOUNT DUE $77,101.56 Interest From 01/01/2001 Through 09/19/2002 (Costs to be added) Dated: Prothonotary, Common Pleas Court of Cumberland County, Pennsylvania Deputy ... ~ , , :.'""- ,;.~:"",,-~ ",' ,< ,"",j,,~~, on on 0.. 0 ~ en C: -< -' '" ~ . t:i Ul 0 -< ~ " on" -' U 0.. 0 ::S::::g~\O 0.. e? z,-... .......~ ~lt:1 ~lXl~~ E Z Ul OUt- 0 Ul ~ Mt- .", i'A::;E0\(',I ~ 0 -< 2: -" -"", ~ .S ~I-o .....(',1 2: 00 boo U '" "u CO 0 ;::J,-....S! ~..9 '" Y7 EI':l EI':l EI':l -"- -fo u-<_ .;; 2: ~ -< 00 c U U ,,0.. lXl5.c..r-!, 0 w1::'cd Ul ~ '0 M ~ v "'0 cd~(',I EU u 0 :1:0-" X 0 0<2 ..s:::: l=: ..... \0 2: ~ ~ ~ ~ Ul'" .,., ~ E-< ~.:a'-'" u" '" > . t 2: U -< U U I lU"il~ bon 0 Ul -< 0 '" on ,.d g ~8]~~ 0 " OgJ, "i ~ -' -,2: :1: U b1: U'" ,.:;::lrI :--::: :3 ::J M ~~ ::J Ul c/l ;;;: 0 1: yvu:i..s:::: 0 ~ -< ;,:6 ;0-;0-0 ~.5..... 0... ,; 0.. C Z u 2: 0 "':I: Q. "=cn::: Ul Z 'g o Q. ~ OJ: Ul >-~E-<b~ b > '" E :I:~~",<il :?; 0 is' E-<~E-<o...'''''' 0 O"Oj;I.;l~ u b"'O :I: ~;;; on ......~ E-< ;::l o:lE-<~o...r.ncno"'" W r.n 0... 4-< ~ ow{/) cnOJ:1,; .....4 P::: E-< E-< ~ . <r:: ~cn C/)l.+:: 0.0 . ~~8 80]631 <" ',,"'I' ""'-~ ". ""'" ,-. -, c, ,'. - ~<" ,'-J.- -,"" - 'jjj-i~ Jospeh A. Goldbeck, Jr. Attorney LD. #16132 Suite 500 - The Bourse Bldg. III S. Independence Mall East Philadelphia, PA 19106 215-627-1322 Attorney for Plaintiff DOVENMUEHLE MORTGAGE CO. LP 1501 Woodfield Road Schaumburg, II. 60173-4982 Plaintiff IN THE COURT OF COMMON PLEAS vs. PAUL A. RHEAUME Mortgagor(s) and Record Owner(s) 15 W. Factory Street Mechanicsburg, P A 17055 of Cumberland County CIVIL ACTION - LAW Defendant(s) ACTION OF MORTGAGE FORECLOSURE NO. 01-3054 Civil Term CERTIFICATION AS TO THE SALE OF REAL PROPERTY I, Joseph A. Goldbeck, Jr., Esquire hereby certify that I am the attorney of record for the Plaintiff in this action, and I further certify that this property is subject to Act 91 of 1983 and the Plaintiff has complied with all the provisions of the Act. ~~ ,'" " ',..~ -.. .....-,;" ,..,. I ALL THAT C&RTAINlt<aot 0< p"~ee1 of land situate on the sooth .ide of West Facto", Str""t, ~th ll4I'd, in the l\o<ough of I'\e<:hanic.bt><g, COlmty ot ClJIIIbedand .na state of Pen1eylvanlo, ~re pa<ticulo~ly bounded and degcci~ as follows. aeGINNING at d pJint on the 5Oueh~rn line of Fa~tory Street, eaid polnt bei"9 ...oeu<Od irl s eouth""atec1y dicection two hundred a!Kty (260.oo) feet from the e.outhwe~t CO't11er ot F'e.ctory Stre.et. ~OO &t:"ket Street: th~nC6 80lJth 21 dG9r~c~ 2$ mirlUte~ East Along the western line of land4 now o~ forme~ly of Aacon C. Kapp ~ di$tance Qf one hundred nineteeh and sixteen hvndredthe (119.16) feet to ~ hub on ~le nocth.<n line ot a fifteen (15.00) toot ~Ide Alley. th.nc~ SQu~h 11 Q49r~~Q 33 roinut~~ Wedt along said nQ~the~n line of olley s d!otenoe pf eixty-one (61.00) foet to a hub: thence Noeth 16 degreee 27 ~inute8 W~$t along th~ eAstern line ot lands n~ or !o~erly of ~ohn H~ W.ige1, Jr., A dif'tance of one hundred nineteen t119.00) feet to a hub on the south.rn lin~ of acto~ Stre~t; then~ No'th 71 ~~Q~S 33 minutes Ea~t along 5alo 5Outh.~n Iin of ~~ctory Street a distAhce or tifty-four and eighty-lh~ee hUnO<odthe (54.63) feet to a hub, tho point and Placo of 9EOINNrNG. I i "^VING theceon ..r'ICted a Z~ oto<y fca.... dw..Uing and detaolled fra... garag" knot.m .00 n~t:'~ a.!l lS We.elt 1'1lctO(y St.r-.,et. i UNDER AND suaJECT~ n8ve~th.le~4, to ea~ement$, restrictions, reservati~, <:<>adiUONl and ri~hta of vay Q( r.c.o<d. j ,,-"- TAX PARCEL # 19-22-0519-083 ~~ . -, . .. ~,<, ....,., ','"-" I ALL THAT CIlR!I'AINiteact oe parcel of land dtuat. on the south .ide of We5t ractory Ste"",t, 4th liard, in the 6oeouqh of I'(echanicabUt'q, County of Cln11berland and State of Penrtaylvania, moee particularly bounded and o5acribed aa follows, i BEGINNING at a P41ht on the BOuth~(n linv of Fa~tory Street, ~8id point beill9 meaaUClt<li~' southweate1;1y ~irection t\lO hunde"" aixty (260.OQ) feet It:'O<<l the ooulhwe t co~e-r' of F8.ctot:y Street ~nd Ma."Ck.et Street; thence SQ\Jth 21 deqraee 2$ m! t~8 East along the weB tern line of lan~ new Or fOrMecly ol Aaron C. KA~ di$tance of one hvnd~ed nioeteeh and sixteen h~ndredthB (119.16) t.et to ~ hub on the noethern Une of a titteen (15.00) toot "ide al1~y: th.nc~ sou~h 71 o69r~e~ 33 minute3 west along oaid northern lin~ pf &lley & distanc~ of 81xty-ane (61.00) feet to a hub~ thence No~t:.h 16 deg~ee~ 27 ~inutQ9 W~~t a~onq th~ eAstern lin~ of lands n~ or lo~@rly of ~ohn Ha ~igel, Jr., a dif'tance of one hundred nin~teen (119.00) feet to a hub on the southern line of 3CtO~ Str~et; th~oe North 71 ~coe3 33 minutes ~at ~lonq said DOuth.rn lin ot ~<<ctory Street ~ distance or fifty-tour and eighty-three hlll'oOndth. (54.63\ [~t to a hub, the point and Place of BWU1NING. , H~VINC the <eon er~ted . 2~ .to<y f<ame dWelling and detached trame garagv known and nUlfbet'~ as 15 West r.actocy St::.r~et ~ I UNDER AND SVSJECT1 nev~rth81e~$, to ~aGQments, ~e5trl~tions, reservationA, C<ll\ditiOM 6nd d~ht.. of ,,"y of eecow. I . ' , TAX PARCEL # 19-22-0519-083 PROPERTY ADDRESS: 15 W. Factory Street, Mechanicsburg, P A 17055 IMPROVEMENTS: A residential dwelling. SOLD AS THE PROPERTY OF: PAUL A. RHEAUME L.-, 1- ,', J,. -,~ ....'V,.".~" ...,'...,......._,~ I ALL THAT CERTAINit<act 0< pa~cel ot land altuate on the south side ot Weet ractor:y Stre\l't, "th Ward, in tM Elo<augh of f'\I><>hanic.bu<g, County of Cumbe~lllnd and State of Pon1aYlvonia, more pa'ticu1a~ly bounded and described a. tollows: BEGINNING at a ~int on th~ southern line of F~~tory Street, said POint bei"9 me08u<lI<l 1 a aoothwute~1y di~ection two hundr.o .ixty (260.00) feet from the "outhwe t corner ol Factory Street 000 MarKet Street: thence 8O\1th 21 dttgr@es 2$ miriute~ East along the western lin~ of !",nds now Or tOrMet"1y of Aa~on c. Kapp ~ dietance of one hundred nineteeh and sixteen nund(edtha (119.16) fe.t to ~ hub on ~'e northe<n iine of a titteen (15.00) foot wide all~y: th.nc~ sou~h 71 degree~ 33 Mlnute3 weat along said nQrth~~n line of .11~y · dJetance pf 81xty-one (61.00) feet to a hub: thence North 16 degrees 27 minutes W~~t a~o~ thQ t8BteLn line o{ lands n~ or fQ~r1y of John H. ~igel, Jr., d dif'tanoe of one hundred nineteen (l19.00) feet to. hub on the 80uthern 1im. of actot:'y SI:I:eet; thence North 71 deoq('ee.s 33 minutee East: along said 50uthern 110 ol ~<<ctory St~&et ~ dist4nce or tifty-tou~ snd eighty-th~ee hundredth. (54.83) !~t to a hub. tho point and Placo ot ijEOIMNING. i HAVINe thareon e:r-tcted a 2~ lSl;.OtY tr$me dwelling and detached frall'le gare.g_ Jtno..m and n~t:'~ as 15 ~t l'.actoq St.reet. i ONDER AND SU83ECT~ nevertheleA$t to e~GQmente, ~eBtrictions, res~rvation&, conditione on6 ri~ht. of ~oy of reco<d. . TAX PARCEL # 19-22-0519-083 ~~~IiiIWI@l~ii->",\lill'icill'",mi~-lm;;~--'IIl1._~lilim:ii($!1(0j:'2:::,,-'t.tbcl;,,.ili';,J>~~,il,"",ll.;Uii<WEl-I1~,~itiIl~l!i~iVt ~ ~s-- l;o _ ~,:)t.~,x, ,_ .~.< 111fT J..J ;'" ~,~W -~ - ~",."'~ ",""""",~,"'~~""'-""'~ ,-, " ."- "",--='-' 1,7 1'1'"' '(. o:J) :;0 ',' LW .< ~"""",........." " '<~I7i~r~''''' ~ '~. -- ~ ., -- ~ p ~ _1Ii!~OilllIIilli'lllliil!lll':!ll ~"I lJ1 ~ ._-~~~- ,I. 1,[_ " I, ~ , o'~_1!!t" . , Dovenmuehle Mortgage Co. LP VS Paul A. Rheaume In The Court of Common Pleas of Cumberland County, Pennsylvania Writ No. 2001-3054 Civil Term R. Thomas Kline, Sheriff, who being duly sworn according to law, states this writ is returned STAYED pursuant to instructions from Attorney Joseph Goldbeck. Sheriffs Costs: Docketing Surcharge Advertising Posting Bills Law Library Prothonotary Mileage Levy Certified Mail Law Journal Patriot News Ponndage Share of Bills 30.00 20.00 15.00 15.00 .50 1.00 13.80 15.00 1.63 260.75 263.20 40.00 25.21 $ 701.09 paid by attorney 03/07/03 Sworn and subscribed to before me So _^::w2J: . IX' V1_' . ..P""""~~I"'C~~d ThIS /J ~ day of IY~ 1 '" -- ~') .- R. Thomas Kline, heriff 2003,A.D( /flL CI~,~ BY~~ Prothonotary Real Estate Deputy 1.St> Q'-lbDiJ.-> ~. /}J'f90. , , I I , ~',I~ '" " , ",,-~-, "l-' " '" ,.-= -0 '0" '- I';", li " Goldbeck McCafferty & McKeever . BY: Joseph A. Goldbeck, Jr. Attorney LD. #16132 Suite 500 - The Bourse Bldg. III S. Independence Mall East Philadelphia, P A 19106 215-627-1322 Attorney for Plaintiff DOVENMUEHLE MORTGAGE CO. LP 1501 Woodfield Road Schaumburg, II. 60173-4982 IN THE COURT OF COMMON PLEAS Plaintiff of Cumberland County vs. PAUL A. RHEAUME (Mortgagor(s) and Record Owner(s)) 15 W. F actory Street Mechanicsburg, P A 17055 CIVIL ACTION - LAW ACTION OF MORTGAGE FORECLOSURE Defendant( s) No. 01-3054 Civil Term AFFIDAVIT PURSUANT TO RULE 3129 DOVENMUEHLE MORTGAGE CO. LP, Plaintiff in the above action, by its attomey, JosephA. 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: 15 W. Factory Street Mechanicsburg, P A 17055 l.Name and address ofOwner(s) or Reputed Owner(s): PAUL A. RHEAUME 15 W. Factory Street Mechanicsburg, PA 17055 2. Name and address of Defendant(s) in the judgment: PAUL A. RHEAUME 15 W. Factory Street Mechanicsburg, P A 17055 3. Name and last known address of every judgment creditor whose judgment is a record lien on the property to be sold: P A DEPARTMENT OF PUBLIC WELFARE - Bureau of Child Support Enforcement Health and Welfare Bldg. - Room 432 P.O. Box 2675 HaITisburg, P A 17105-2675 DOMESTIC RELATIONS OF CUMBERLAND COUNTY PO Box 320 Carlisle, PA 17013 BENEFICIAL CONSUMER DISCOUNT CO. I I -,~" , ~' I" "'" "-'c."" ~'.J~ .. 4910 Carlisle Pike, Suite 104 Mechanicsburg, P A 17055 BENEFICIAL CONSUMER DISCOUNT CO. 961 Weigel Drive Elmhurst, IL 60126 4. Name and address of the last recorded holder of every mortgage of record: PENNSYL VANIA HOUSING FINANCE AGENCY 2101 N. Front Street Harrisburg, P A 5. Name and address of every other person who has any record interest in or record lien on the property and whose interest may be affected by the sale: 6. Name and address of every other person of whom the plaintiff has knowledge who has any record interest in the property which may be affected by the sale. 7. Name and address of every other person of whom the plaintiff has knowledge who has any interest in the property which may be affected by the sale. TIM COLGAN-ESQ The Wiley Group I South Baltimore Street Drillsburg, PA 17019 (attach separate sheet if more space is needed) I verify that the statements made in this affidavit are true and correct to the best of my personal knowledge or information and belief. I understand that false statements herein are made subject to the penalties of 18 Pa. C.S. Section 4904 relating to unsworn falsification to authorities. GOLDBECK Y & McKEEVER r.,Esq. DATED: September 19,2002 , t , I I,' , , -" ~, ' _~' ~ "~'_" ~" 0 "^'; .. 01-3054 Civil Term GOLDBECK McCAFFERTY & McKEEVER BY; Joseph A. Goldbeck, Jr. Attorney LD,#16132 Suite 500 - The Bourse Bldg. III S. Independence Mall East Philadelphia, P A 19106 215-627-1322 Attorney for Plaintiff DOVENMUEHLE MORTGAGE CO. LP 1501 Woodfield Road Schaumburg, II. 60173-4982 IN THE COURT OF COMMON PLEAS of Cumberland County Plaintiff vs. CIVIL ACTION - LAW PAUL A. RHEAUME Mortgagor(s) and Record Owner(s) ACTION OF MORTGAGE FORECLOSURE 15 W. Factory Street Mechanicsburg, P A 17055 Term No. 01-3054 Civil Term Defendant(s THIS LAW FIRM IS A DEBT COLLECTOR AND WE ARE ATTEMPTING TO COLLECT A DEBT. THIS NOTICE IS SENT TO YOU IN AN ATTEMPT TO COLLECT A DEBT. ANY INFORMATION OBTAINED FROM YOU WILL BE USED FOR THAT PURPOSE. NOTICE OF SHERIFF'S SALE OF REAL PROPERTY TO: RHEAUME, PAULA. PAUL A. RHEAUME 15 W. Factory Street Mechanicsburg, PA 17055 Yom house at IS W. Factory Street, Mechanicsburg, PA 17055 is scheduled to be sold at Sheriffs Sale on Wednesday, March 05, 2003, at 10;00 AM, in Commissioners Hearing Rm 2nd FL Courthouse to enforce the comt judgment of $77,101.56 obtained by DOVENMUEHLE MORTGAGE CO. LP against you. NOTICE OF OWNER'S RIGHTS YOU MAY BE ABLE TO PREVENT THIS SHERIFF'S SALE To prevent this Sheriffs Sale you must take immediate action: 1. The sale will be cancelled if you pay to DOVENMUEHLEMORTGAGE CO. LP, the back payments, late charges, costs and reasonable attorney's fees due. To find out how much you must pay call: 215-627-1322 2. You may be able to stop the sale by filing a petition asking the Court to strike or open judgment, if the judgment was improperly entered. You may also ask the Court to postpone the sale for good cause. . , " ~" " '-~ ,__ ~,~ ~"~W ~,~ ~ ~ ^,-" .. 01-3054 Civil Term 3. Y Oll may also be able to stop the sale through other legal proceedings. You may need an attorney to assert your rights. The sooner you contact one, the more chance you wilI have of stopping the sale. (See notice below 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 NOT TAKE PLACE. I. If the Sheriff's Sale is not stopped, your property will be sold to tbe highest bidder. YOll may find out the price bid price by calling the Sheriff of717-240-6390. 2. You may be able to petition the Court to set aside the sale if the bid price was grossly inadequate compared to the value of your property. 3. The sale will go through only if the buyer pays the Sheriff the full amount due in the sale. To find out if this has happened, you may call the Sheriffof717-240-6390. 4. Ifthe amount due from the Buyer is not paid to the Sheriff, you will remain the owner of the property as if the sale never happened. 5. You have a right to remain in the property until the full amount due is paid to the Sheriff and the Sheriff gives a deed to the buyer. At that time, the buyer may bring legal proceedings to evict you. 6. You may be entitled to a share of the money which was paid for your house. A schedule of distribution of the money bid for your house will be filed by the Sheriff thirty (30) days from the date ofthe Sheriffs 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 schedule of distribution is filed. 7. You may also have other rights and defenses, or ways of getting your house back, if you act immediately after the sale. YOU SHOULD TAKE THIS PAPER TO YOUR LAWYER AT ONCE. IF YOUDO 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, P A 17013 LEGAL SERVICES INC 8 Irvine Row Carlisle, P A 17013 I I .",; ~'"O__ '. o;{~"_?'''''''~'"' c" , ,Ie :_; .~" ,'., '.-,-^, .-~^,'-.; I ALL THAT cl\R'I'Amitract or po<cel of land situate on the south side of Weet roctory Stre.>t, -Ith IilIrd, in the 6orough of l'\l>Chanic.burg, County of Curnb<!rland and State or Pvn1eylVania, more particularly bounded and described ~~ tollows: BEGINNING at G ~iht on th~ south~rn line of Fa~tory Street, eaid po~nt being meoour$d i . southwesterly di<ection tWQ hundr.o sixty (260.00) feet tt."Clm the aouthwe t corner ot Factory Street ii!od K!Jrket Strettt: th~IlC& aouth 21 degt."ee~ 2$ mlrlute~ East along the western line of lan~ now o~ fo~~ly of Aaron C. KApp ~ di$tance of on~ hvndred nineteen and sixteen hundr~thB (119.16) teet to ~ hub on the northern line ot a Uftoen (15.00) toot "Ido alley; th.nc~ Sou~h 71 C~re~~ 33 minute~ West along said no~thern line of .ll~y a distance of 81xty-on~ (61.00) teet to a hub: thenc~ North 18 degrees 27 minut~s W~~t along th~ eaatern line of lands now or formerly of John H. W<<igel, Jr., Q dif'tanca of on~ hundred nineteen (119.00) f~t to a hub on the southern line of ~cto~ Str~et; thence North 71 de9ree3 33 minut~s Ea8t along $aId 5OUth.~n lin of ~~ctory St~&et ~ distahce or lifty-tour and eighty-thr~e h~nd'odtho (54.83) f~t to . hub, tho point and Place of EEGINNING. I HAVINe th~reon er~ted a 2~ eeo~ trame dw~lling ~nd dvtached fraMe gara9v ~ and n~~e4 as l5 Weet Factocy Str~et. i ONDER AND S08JECT~ neverthele8$, to ea~ement$, restrictions, re5ervatf~, condition$ and ri~hts of ~ay of record. TAX PARCEL # 19-22-0519-083 ill""'''-'' ," ,~ " _' J I; r~ ~l> ~" ,,' ," , L WRIT OF EXECUTION and/or ATTACHMENT . ' COMMONWEALTH OF PENNSYLVANIA) COUNTY OF CUMBERLAND) NO 01-3054 Civil CIVIL ACTION - LAW TO THE SHERIFF OF CUMBERLAND COUNTY: To satisfy the debt, interest and costs due Dovenmueble Mortgage Co. LP 1501 Woodfield Road, Schaumburg, IL 60173-4982 PIaintiff(s) From Paul A. Rheaume 15 W. Factory Street Mechanicsburg, P A 17055 (I) You are directed to levy upon the property of the defendant (sland to sell SEE LEGAL DESCRIPTION. (2) You are also directed to attach the property of the defendant(s) not levied upon in the possession of GARNISHEE(S) as follows: and to notify the garnishee(s) that: (a) an attachment has been issued; (b) the garnishee(s) is enjoined from paying MY debt to or for the account of the defendant (s) and from delivering any property ofthe defendant (s) or otherwise disposing thereof; (3) Ifproperty of the defendant(s) not levied upon an subject to attachment is found in the possession of anyone other than a named garnishee, you are directed to notify him/her that he/she has been added as a garnishee and is enjoined as above stated. Amount Due$77101.56 L.L.$.50 Interest FROM 01/01/2001 TO 9/19/2002 AT 8.0000% Arty's Comm % Atty Paid $157.25 Plaintiff Paid Date: September 23, 2002 Due Prothy $1.00 Other Costs (Seal) CURTIS R. LONG Prothonotary By: 1~ K~. W Deputy REQUESTING PARTY: Name Joseph A. Goldbeck, Jr. Address: Suite 500 - The Bourse Bldg. 111 S. Independence Mall East Philadelphia, PA 19106 Attorney for: Plaintiff Telephone: 215-627-1322 Supreme Court ID No. 16132 - ,(;c." d;,"j,(, "",J,,,,,,;,,,,:,.,,x>it'f4~--illrHiJ,i;I;\J;~..J;;;a;'Wil'>!i:~""Ai~~~E""d:hM\IriiW~~.Q!ikl!111 "~"~i1'-" - "-;i;;"'~"~'"!"~ '&Iii Real Estate Sale # 12 On October 29, 2002 the sherifflevied upon the defendant's interest in the real property situated in Mechanicsburg Borough, Cumberland County, P A known and numbered as 15 West Factory Street, Mechanicsburg, more fully described on Exhibit "A" filed with this writ and by this reference incorporated herein. Date: October 29, 2002 By: ,JGriMi 5rnJjJ, Real E4tate Deputy 1) pr< i',;: CjJ Ad Jdn,,:~ ' ,;,1 , : ,~-:t.-~ "'. ~o. ~ L,~,. ~ _H, .~, ~" ~ _ I., ~w~'" " ".~. ~~ ,.~,' ,_,~. "" ''''''Ji;, ~ ~ &:::::::I 'G2) Iiii;J J!T .'.~"'~- - ,'" 'I.... 'I, ~I ~~--. ~~I'''''','-' PROOF OF PUBLICATION OF NOTICE IN CUMBERLAND LAW JOURNAL (Under Act No. 587, approved May 16, 1929), P. L.1784 STATE OF PENNSYLVANIA : SS. COUNTY OF CUMBERLAND : Lisa Marie Coyne, 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 officia11egal periodical for the publication of all legal notices, and has, since January 2, 1952, been regularly issued weekly in the said County, and that the printed notice or publication attached hereto is exactly the same as was printed in the regular editions and issues of the said Cumberland Law Journal on the following dates, VIZ: JANUARY 31, FEBRUARY 7,14,2003 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. '/ WORN TO AND SUBSCRIBED before me this 14 day of FEBRUARY. 2003 NOll LOIS E. SIINllER, Mowry Publk: Cfirill!llllilm'(j, Clil;:J~'~:Ji,d CooI1tv My Cllr.:~ El.jliooo i'JlaII:h 5, 2005 'tin ~ ,. REAL ESTATE SALE NO. 12 Writ No. 2001-3054 Civil Dovenmuehle Mortgage Co. LP vs. Paul A. Rheaume Atty.: Joseph Goldbeck ALL THAT CERTAIN tract or par- cel of land situate on the south side of West Factory Street. 4th Ward. in the Borough of Mechanicsburg. County of Cumberland and State of Pennsylvania. more particularly bounded and described as follows: BEGINNING at a poInt on the southern line of Factory Street, said point being measured in a south- westerly direction two hundred sixty (260.00) feet from the southwest corner of Factory Street and Mar- ket'Street: thence south 21 degrees 25 mh1utes East along the western line of lands now or formerly of Aaton c. Kapp a distance of one hun- dred nineteen and sixteen hun- dredths (119.16) feet to a hub on the northern line of a fifteen (15.00) foot wlde alley; thence South 71 degrees 33 minutes West along said northern line of alley' a distance of sixty-one (61.00) feet to a hub; thence North 18 degrees 27 min- utes West along the eastern line of lands now or formerly of John H, Weigel. Jr., a distance of one hun- dred nineteen (119.00) feet to a hub on the southern line of Factory Street; thence North 71 degrees 33 minutes East along said southern line of FactolY Street a distance of fifty-four and eighty-three hun- dredths (54.83) feet to a hub. the point and Place of BEGINNING. HAVING thereon erected a 2 1/2 story frame dwelling and detached frame garage known and numbered as 15 West Factory Street. UNDER AND SUBJECT. never- theless, to easements. restrictions, reseIVations, conditions and rights of way of record. TAX PARCEL #19-22-0519-083. c" ~ - ~"- " ,j "I II I. I ,~;-> , :'" ~. 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 JOSEPH A. DENNISON being duly sworn according to law, deposes and says: That he is the Ass!. Controller of The Patriot News Co., a corporation organized and existing under the laws of the Commonwealth of Pennsylvania, with its principal office and place of business at 812 to 818 Market Street, in the City of Harrisburg, County of Dauphin, State of Pennsylvania, owner and publisher of The Patriot-News and The Sunday Patriot-News newspapers of general circulation, printed and published at 812 to 818 Market Street, in the City, County and State aforesaid; that The Patriot-News and The Sunday Patriot-News were established March 4th, 1854, and September 18th, 1949, respectively, and all have been continuously published ever since; That the printed notice or publication which is securely attached hereto is exactly as printed and published in their regular daily and/or Sunday/ Metro editions which appeared on the 28th day(s} of January and the 4th and 11th day(s) of February 2003. 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, piace and character of publication are true; and That he has personal knowledge of the facts aforesaid and is duly authorized and empowered to verify this statement on behalf of The Patriot-News Co. aforesaid by virtue and pursuant to a resolution unanimously passed and adopted severally by the stockholders and board of directors of the said Company and subsequently duly recorded in the office for the Recording of Deeds in and for said County of Dauphin in Miscellaneous Book "M", Volume 14, Page 317. PUBLICATION COpy S ALE #12 Sworn to and subs NoIarial Seal Tany L. Russell. NoIary Public City Of Harrisburg, Dauphin County My Commission Expires June 6, 2006 Member. Pennsylvania Association Of Notaries My commission expires June 6, 2006 , . r CUMBERLAND COUNTY SHERIFFS OFFICE CUMBERLAND COUNTY COURTHOUSE CARLISLE, PA. 17013 '. ; Statement of Advertising Costs To THE PATRIOT-NEWS CO., Dr. For publishing the notice or publication attached hereto on the aboye stated dates $ Probating same Notary Fee(s) $ Total $ 261.45 1.75 263.20 Publisher's Receipt for Advertising Cost The Patriot News Co., publisher of The Patriot-News and The Sunday Patriot-News, newspapers of general circulation, hereby acknowledge receipt of the aforesaid notice and publication costs and certifies that the same have been duly paid. By................. n n..................................... n........ -,',"' ~=RcAl:'ESTATC5A1:E'N'o..I%-'--- L)o,..,... Writ No. 2001-3054 . f' ClvUi"erm .. ... ::.".': :Doveilmuehle' , . . )1'Iort98ge Co. LP " 'va 'Paul A. Rheaume Atti: Joseph Goldbeck . ; DESCfOlPTION ',",ALL THAT CEK':A'z'.f tract ot parcel of land ,'situate on'the SOl!1b side of West factory Street, 4th Ward, in 'kie Borough of Mechanic.burg. ,:CoUnty"":O( t:umberla1i9, and :State 'of : :,Pennsy[ValJ~MmOre particularly bounded and 'tlescribedasfollows: :' BEGINNING at a point on the, southern,~ "of :'~t9ry Street, s~d ~oint b'eing measured i.n a -":"':~'ouffiwcsterly drrec[]on t\\'O hundred SIX-ty ,:'(260,00) feet,from the southwest, comer ,01 "P.u;tory Street and Market Stree,l; (ben,ce ~9mh,21 'degrees 15 fiiinutes &,\ along the westeirdfne 'of : lands n9W, 9r fOlmctly of Aaron C. Kapp a "dis'tance of one "hundred !1inetee,n and sixtee,n ,..::1J.undredtbs..C1.L9.J 6)..f~t 10, a hub on the north~m )inc..of,a)ifteen (15.00) fOOl, wide alley; thence "..:South 71, ,deg~, 3,3 minutes We.s! ~Qllg..saJ,d ':,northem fine of alley a dl~lan:ce- of'six'ly-one ..'::'(61.00) teeL!'o 'a,bubj thencc: North lS"degr,eeii27, ':'JuJlJ.utes-'Ve.l alQng the eastern line of lailils now ' ': :':or formerly of John J, WeigeJ"k, a di5lance of ':":1me,.hurulred..ninetee.n (lt9,liiJ) feet to a hub on' "tbe"i;i'>ut1ierii'line'OiFaclorv'Street; thence North.. .-71 degrees,~,:,((lillute',EaSl(llongsaidwuthem' .:: ,line...oC Factory ~tt"~t a' (Jislal).ce of fifty-four and ' ,::'-',e!~h.ty':1hreeJlUliii;reditt~ (54.83) feet to a huh, the ': pOluland rtace ofBl::.iJll'<'NING. ,HAVIN'G lIe,reon,erecled' a"2112 story frame, dwelling' O!~'~, 'deiached frame g!u'age ~nown and' numben:id,p$ 15WestFactoryStreet. UNDER AND SUBJECT, n~\lerth.eless. to' "easements"restrictioos, reservations, conditions , :::~n(rrlgl1tS'ijr\vay'orrec(,rd, ~TA.X:P~~~i!~~'2.05J9-:08J~_,__