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Home My WebLink About01-03220 -"--~ ~. ""-Irt\ - ~' ~- -~ " ~, ;.,,~- ",-~ "L.~' '\. ~, .....; .. PRAECIPE FOR WRIT OF EXECUTION - (MORTGAGE FORECLOSURE) P.R.C.P 3180-3183 Joseph A Goldbeck, Jr, AttorneyLD,#16132 Suite 5000 - Mellon Independence Center 701 Market Street Philadelphia, PA 19106-1532 215-627-1322 Attorney for Plaintiff FIRST NATIONWIDE MORTGAGE CORPORATION PO Box 9481 Mail Code: 22-528-1011 Gaithersburg, MD 20898-9481 IN THE COURT OF COMMON PLEAS Plaintiff of Cumberland County vs, CIVIL ACTION - LAW ' JAMES HOOVER LINDA HOOVER Mortgagor(s) and Record Owner(s) 329 15th Street New Cumberland, P A 17070 ACTION OF MORTGAGE FORECLOSURE No, 01-3220-CIVIL Defendant( s) PRAECIPE FOR WRIT OF EXECUTION TO THE PROTHONOTARY: Issue Writ of Execution in the above matter: Amount Due $21,056,51 Interest from to 09/12/200 I at 0,0100% (Costs to be added) _i!W~'iIi!L4I~'t\:!I!~!~,1"-"~rlit-,,;~,;"'~'i,,,,.i.<h:";;!1i:leiMm'!lt&!t:.\;'~iL"'i,:,r,),,,,",g"',,~,,,,li.!,,,j;;,-i<,'!,,,,, ",_.'li!"".","_.;~i._d.-,;..-~~-",~~iIltm~:ffiW.~'r~ CJJ -< fOl s: Z >-l0 ~~ ;:;~ YO E~u ,,<'> I"; ~l"'(O ~Eo< o~ o~ Zo U fOl =: Eo< ~ ,,!.,]!! 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".,,, H~'.,~> ,_,,^_ l~ ~ .~.,....~ .; -... . 1 it + .;;t '3 ~~ vJ li CI 0-. CB 0-- ~ C1 -...j - .......J "] ~ ~ 'SL oI..t:::i. '0 Jim rj () C .....: "" >,-...~ .~... ~_v._' -"~ ~. 'C '. ". ,~' _0 Tof ..... 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 First Nationwide Mortgage Corp. P.O. Box 9481, Mail Code: 22-528-1011 Gaithersburg, MD 20898-9481 Vs. John O. Osgood (Mortgagor only) Susan C. Osgood (Mortgagor only) 52 Catoctin Court Silver Springs, MD 20906 CUMBERLAND COUNTY COURT OF COMMON PLEAS CIVIL DIVISION NO 01-3220-Civil James Hoover (Real Owner only) Linda Hoover (Real Owner only) 329 15th Street New Cumberland, PA 17070 ALL THAT CERTAIN lot or tract of land situate in the Borough of New Cumberland, County of Cumberland and State of Pennsylvania, more particularly bounded and described as follows according to a survey of D.P. Raffensperger (49-29) dated March 4, 1974, to wit: BEGINNING at a point on the Northern side of 15th Street said point being 870.8 feet west of Bridge Street; thence extending along 15th Street South 62 degrees West 50 feet to a corner of lot number 30 on the hereinafter mentioned plan of lots; thence along lot number 30 north 28 degrees West 195 feet to a point a corner; thence North 62 degrees East 50 feet to a point a corner; thence extending through lot number 31 on said plan South 28 degrees East 195 feet to the point and place of BEGINNING. Being a part of lot numb~r 31 Section E plan of Hillside as recorded in the Cumberland County Recorder's Office in plan Book I, page 75. Having thereon erected a two story frame dwelling and detached frame garage known as 329 15th Street. Tax Parcel #26-23-0541-133 :en.... ~. ,~" - ~<,,~ ~< 'U ," _J ,----J "" ilili!Unw-"-'<--'<- ~' WRIT OF EXECUTION and/or ATTACHMENT COMMONWEALTH OF PENNSYLVANIA) COUNTY OF CUMBERLAND) NO 01-3220 Civil CIVIL ACTION - LAW TO THE SHERIFF OF CUMBERLAND COUNTY: To satisfy the debt, interest and costs due FIRST NATIONWIDE MORTGAGE CORPORATION, Plaintiff (s) From JAMES HOOVER AND LINDA HOOVER (I ) You are directed to levy upon the property of the defendant (s land 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 atlachment has been issued; (h) 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 himlher that he/she has been added as a garnishee and is enj oined as above stated. Amount Due $21,056.51 Interest FROM 9/12/01 AT 0.0100% Ally's Canon % Ally Paid $1486.40 Plaintiffpaid Date: JUNE 8, 2005 L.L. Due Prothy $1.00 Other Costs CURTIS R. LONG (Seal) Prothonotary 2. ~ ~:.4~ . I"l?~~ Deputy REQUESTING PARTY: Name JOSEPH A. GOLDBECK, JR., ESQmRE Address: SmTE 5000 - MELLON INDEPENDENCE CENTER 701 MARKET STREET PHILADELPIDA, PA 19106-1532 Attorney for: PLAINTIFF Telephone: 215-627-1322 Supreme Court ill No. 16132 J'. - ~-"'.;. USBC PAM - LIVE - V2.6 - Docket Report Page 1 of8 CREDS, CLAIMS, 2002, 341Held U.S. Bankruptcy Court Middle District of Pennsylvania (Harrisburg) Bankruptcy Petition #: 1:04-bk-00933-MDF Assigned to: Mary D France Chapter 7 Previous chapter 13 Voluntary No asset Date Filed: 02/18/2004 Date Converted: 01/13/2005 Date Discharged: 05/04/2005 James C Hoover 329 15th Street New Cumberland, P A 17070 SSN: xxx-xx-4306 Debtor represented by James M Bach 352 South Sporting Hill Road Mechanicsburg, P A 17050 717737-2033 Fax; 717 737-4220 Emai1: jamesbach@comcast.net Linda L Hoover 329 15th Street New Cumberland, PA 17070 SSN: xxx-xx-4701 Joint Debtor Leon P. Haller (Trustee) Purcell, Krug and Haller 1719 North Front Street Harrisburg, P A 17102 717234-4178 Trustee represented by James M Bach (See above for address) represented by Leon P Haller Purcell Krug and Haller 1719 North Front Street Harrisburg,PA 17102-2392 717234-4178 Fax: 717 233-1149 Emai1: 1haller@pkh.com Charles J. DeHart, III (Trustee) POBox410 Humme1stown, PA 17036 717 566-6097 TERMINATED: 01/14/2005 Former Trustee United States Trustee PO Box 969 Harrisburg, P A 17108 (717) 221-4515 Asst. U.S. Trustee I Filing Date # Docket Text https://ecf.pamb.uscourts.gov/cgi-bin/DktRpt.p1?791 020500472871-L _82_0-1 6/6/2005 -< ........~ ~~-,;~""'= '- It I:. '"-""'~ ~ -. "'M"~ o ~,. > "-'" .,~ ~M_ >_._ USBC PAM - LIVE - V2.6 - Docket Report Page 2 of 8 02/18/2004 1 Chapter 13 Voluntary Petition. Filing fee due in the amount of$ 194.00 Filed by James M Bach on behalf of James C Hoover, Linda L Hoover. (DD) (Entered: 02/18/2004) 02/18/2004 2 Matrix filed/Creditor List Uploaded Filed by James M Bach on behalf of James C Hoover, Linda L Hoover (RE: related document( s)l ). (DD) (Entered: 02/18/2004) 02/18/2004 .1 Chapter 13 Plan Filed by James M Bach on behalf of James C Hoover, Linda L Hoover (RE: related document(s)l). (DD) (Entered: 02/18/2004) 02/18/2004 4 Motion for Wage Attachment Order Filed by James M Bach on behalf of James C Hoover, Linda L Hoover, (DD) (Entered: 02/18/2004) 02/18/2004 5 Order Granting Motion for Wage Attachment Order (RE: related document(s)[4]). (DD) (Entered: 02/18/2004) 02/18/2004 Receipt of Voluntary Petition Filing Fee. Receipt Number 605387 Fee Amount $ 194.00 (RE: related document(s)1). (DD) (Entered: 02/19/2004) 02/18/2004 Tentative Date for Meeting of Creditors. THIS IS SUBJECT TO CHANGE. 4/8/2004 at 09:00 AM. (DD) (Entered: 02/19/2004) 03/02/2004 6 Request for Notice under 2002 Filed by Alice Whitten on behalf of AmeriCredit , (RCP) (Entered: 03/02/2004) 03/03/2004 1 Request to BNC - Meeting of Creditors. 341(a) meeting to be held on 4/8/2004 at 10:00 AM Federal Bldg, Trustee Hearing Rm, Rm 1160, 11th FI, 228 Walnut St, Harrisburg, P A Proofs of Claims due by 7/7/2004 Last day to Object to Plan Confirmation 8/6/2004 (DP) (Entered: 03/03/2004) 03/05/2004 .8. BNC Certificate of Mailing. Service Date 03/05/2004, (Related Doc # 1) (Admin.) (Entered: 03/0612004) 03/05/2004 2- BNC Certificate of Mailing. ,Service Date 03/05/2004. (Related Doc # 1) (Admin.) (Entered: 03/06/2004) 04/15/2004 10 Certification that 341 Meeting of Creditors Held (Ch. 13) on 04/08/04. (There is no image or paper document associated with this entry,). (dehart, III(ds), Charles) (Entered: 04/15/2004) 07/19/2004 11 Objection to Confirmation of Plan (Plan is underfunded) Filed by Trustee (RE: related document(s)1). (dehart, III(jr), Charles) https://ecf.pamb.uscourts.gov/cgi-bin/DktRpt.pl?791 020500472871- L _82_0-1 6/6/2005 ,-'>:.il_< ,~~ -'- d ,~~ -""< -- ~.~J~_ ~ . ~= -. , , - ........' '-, ',:0;;.;';'._ USBC PAM - LIVE - V2.6 - Docket Report Page 3 of8 (Entered: 07/19/2004) 08/20/2004 12 Objection to Confirmation of Plan Filed by Leslie Puida of Goldbeck McCafferty and McKeever on behalf of First Nationwide Mortgage Corporation (RE: related document(s)U). (CR) (Entered: 08/20/2004) 08/20/2004 U Notice to Parties: (RE: related document(s)[12] ). Hearing scheduled for 9/28/2004 at 09:00 AM at 3rd & Walnut Streets, Bankruptcy Courtroom (3rd Floor), Federal Building, Harrisburg, PA. (Attachments: # 1 Certificate of Service) (CR) (Entered: 08/20/2004) 09/23/2004 11: Amended Chapter 13 Plan and notice to all creditors of objection date Filed by James M Bach on behalf of James C Hoover, Linda L Hoover (RE: related document(s)l,.l). Last day to Object to Plan Confirmation 10/22/2004. (NP) (Entered: 09/24/2004) 09/23/2004 15 Motion for Amended Wage Attachment Order Filed by James M Bach on behalf of Linda L Hoover (RE: related document(s)[ 4], [5]). (DP) (Entered: 09/24/2004) 09/26/2004 16 BNC Certificate of Mailing. (RE: related document(s)14 ). Service Date 09/26/2004. (Admin,) (Entered: 09/27/2004) 09/26/2004 17 BNC Certificate of Mailing. (RE: related document(s) I 4 ). Service Date 09/26/2004. (Admin.) (Entered: 09/27/2004) 09/27/2004 18. Amended Order Granting Motion for Amended Wage Attachment Order (RE: related document(s) [I 5]). (Attachments: # 1 Certificate of Service) (DP) (Entered: 09/27/2004) 09/28/2004 12 Proceeding Memo: Hearing not held. Creditor appeared to inform the Court that Debtor's most recent Amended Plan fIled 9/23/04 does not address their objection. (RE: related document(s)[12], 13.). (JG) (Entered: 09/28/2004) 09/29/2004 20 Praecipe/Withdrawal of Trustee's Objection to Confirmation of Plan Filed by Trustee (RE: related document(s)U). (dehart, lII(jr), Charles) (Entered: 09/29/2004) 10/06/2004 21 Objection to Confirmation of Plan Filed by Leslie E Puida of Goldbeck McCafferty and McKeever on behalf of First Nationwide Mortgage Corporation (RE: related document(s) I 4 ). (CR) (Entered: 10/06/2004) 10/06/2004 22 Notice to Parties: (RE: related document(s)2l ). Hearing scheduled for 11/9/2004 at 09:00 AM at 3rd & Walnut Streets, Bankruptcy https://ecf.pamb.uscourts,gov/cgi-binlDktRpt.pl?791 020500472871-L _82_0-1 6/6/2005 ~~,,,... ~ lJ '"'"':..;."'-~" "'"'"'" .~. , .,".........,. ,~<. ~ '...-~'" USBC PAM - LIVE - V2.6 - Docket Report Page 4 of8 Courtroom (3rd Floor), Federal Building, Harrisburg, PA. (Attachments: # 1 Certificate of Service) (CR) (Entered: 10/06/2004) 11/08/2004 23 Amended Objection to Confirmation of Plan Filed by Leslie E Puida of Goldbeck McCafferty and McKeever on behalf of First Nationwide Mortgage Corporation (RE: related document(s)21, 14). (Attachments: # 1 Amended Plan# 2. Proof of Claim# .3. Certificate of Service)(Puida, Leslie) (Entered; 11/08/2004) 11/09/2004 24 Proceeding Memo: Hearing held. Objection sustained. Plan does not provide for adequate funding. Court to prepare Order giving Attorney Bach 30 days to file legal memorandum as to why language in paragraph 13 of proposed plan should be stricken. (RE: related document(s)22, 21), (JG) (Entered: 11/09/2004) 11/15/2004 .2Ji Order Sustaining Objection to Confirmation of Amended Chapter 13 Plan and Ordering Debtors' Counsel to file Legal Memorandum (RE: related document(s)24, 21 ). (Attachments: # 1 Certificate of Service) (CR) (Entered: 11/18/2004) 11/17/2004 25 Second Amended Chapter 13 Plan Filed by James M Bach on behalf ofJames C Hoover, Linda L Hoover (RE: related document(s)14 ). (Bach, James) (Entered: 11/17/2004) 11/17/2004 26 Motion for Wage Attachment Order (Amended-2nd) Filed by James M Bach on behalf of James C Hoover, Linda L Hoover (RE: related document(s)l8.). (Attachments: # 1 Proposed Order) (Bach, James) (Entered: 11/17/2004) 11/18/2004 27 Request to BNC - Notice re; Amended Ch. 13 Plan (RE: related document(s)14, 25). Last day to Object to Plan Confirmation 12/16/2004. (CR) (Entered: 11/18/2004) 11/20/2004 29 BNC Certificate of Mailing. (RE: related document(s)27 ). Service Date 11/20/2004. (Admin.) (Entered: 11/21/2004) 11/20/2004 lQ BNC Certificate of Mailing. (RE: related document(s)27), Service Date 11/20/2004. (Admin.) (Entered: 11/21/2004) 11/22/2004 31 Order Granting Motion for Second Amended Wage Attachment Order (RE: related document(s)26). (Attachments: # 1 Certificate of Service) (DP) (Entered: 11/22/2004) 11/30/2004 32 Memorandum Filed by James M Bach on behalf of James C Hoover, Linda L Hoover (RE: related document(s)28). (Bach, James) Additional attachment(s) added on 12/1/2004 (NP). (Entered: 11/30/2004) I https://ecf.pamb.uscourts.gov/cgi-binlDktRpt.pl?791 020500472871-L _82_0-1 6/6/2005 '0", ,"<~' ~"~,>_ M -.~, " ,J '-'--'-"'-~""'~",,"I~ -"1~_i USBC PAM - LIVE - V2.6 - Docket Report Page 5 of8 11/30/2004 33 Corrective Entry: previous attachment omitted/incorrect/incomplete Omitted Exhibit A Filed by James M Bach on behalf of James C Hoover, Linda L Hoover (RE: related document(s)32). (Bach, James) (Entered: 11/30/2004) 11/30/2004 34 Motion for Relief from Stay. Filing fee due in the amount of $ 150.00 Filed by Jay B Jones of Federman and Phelan LLP on behalf of Waypoint Bank: as Servicer for the Mortgagee of Record. (Attachments: # 1 Proposed Order) (Jones, Jay) (Entered: 11/30/2004) 11/30/2004 35 Entry of Appearance Filed by Jay B Jones of Federman and Phelan LLP on behalf ofWaypoint Bank: as Servicer for the Mortgagee of Record. (Jones, Jay) (Entered: 11/30/2004) 11/30/2004 36 Certificate of Service for the Entry of Appearance Filed by Jay B Jones of Federman and Phelan LLP on behalf of Way point Bank: as Servicer for the Mortgagee of Record (RE: related document(s)35 ). (Jones, Jay) (Entered: 11/30/2004) 12/01/2004 Receipt of Motion for Relief From Stay(I:04-bk-00933-MDF) [motion,mrlfsty] ( 150.00) filing fee. Receipt number 774913, amount $ 150,00. (U.S. Treasury) (Entered: 12/01/2004) 12/01/2004 11 Order (RE: related document(s)34 ). Answers are due on: 12/16/2004. Hearing scheduled for 12/22/2004 at 09:00 AM at 3rd & Walnut Streets, Bankruptcy Courtroom (3rd Floor), Federal Building, Harrisburg, P A. (CR) (Entered: 12/01/2004) 12/02/2004 38 Certificate of Service for the Motionfor Relieffrom Stay and the Order Setting Hearing on the Motion Filed by Jay B Jones of Federman and Phelan LLP on behalf ofWaypoint Bank: as Servicer for the Mortgagee of Record (RE: related document(s)17, 34 ). (Jones, Jay) (Entered: 12/02/2004) 12/06/2004 39 Returned mail for Creditor (The Associates), Undeliverable as addressed (RE: related document(s)25 ). (CR) (Entered: 12/06/2004) 12/06/2004 40 Answer Filed by James M Bach on behalf of James C Hoover, Linda L Hoover (RE: related document(s)34 ). (Bach, James) Additional attachment(s) added on 12/8/2004 (BW). (Entered: 12/06/2004) 12/07/2004 41 Notice to Filing Party: **The document attached was not signed or dated. Please docket a Corrective Entry (missing/incorrect/incomplete attachment) and upload the correct document (Answer to Motion for RelieffromAutomatic Stay not signed) **. (RE: related document(s) 4,Q). (NP) (Entered; 12/07/2004) I https://ecf.pamb.uscourts.gov/cgi-bin/DktRptpl?791 020500472871-L _82_0-1 6/6/2005 .~ ......., ~,. ~~ "j"~ ~ ".~,~~ ~ --- "-.IlMiIli/iiiJ ""'w ::U", USBC PAM - LIVE - V2.6 - Docket Report Page 6 of8 12/07/2004 42 Corrective Entry: previous attachment omitted/incorrect/incomplete Omitted Attorney Signatures Filed by James M Bach on behalf of James C Hoover, Linda L Hoover (RE: related document(s)40 ). (Bach, James) (Entered: 12/07/2004) 12/22/2004 43 Proceeding Memo hearing cancelled. Stipulation to be filed. Order to be entered. (There is no image or paper document associated with this entry.) (RE: related document(s)37, 34 ). Stipulation due 1/22/2005. (JO) (Entered: 12/27/2004) 12/27/2004 44 Order that Stipulation be filed on or before January 22,2005 or Motion is denied. (RE: related document(s)34 ). Stipulation due 1/22/2005. (Attachments: # 1 Certificate of Service) (CO) (Entered: 12/29/2004) 01/10/2005 45, Motion to terminate wage attachment Filed by James M Bach on behalf of Linda L Hoover (RE: related document( s )31 ). (Attachments: # 1 Proposed Order) (Bach, James) (Entered: 01/10/2005) 01/12/2005 46 Order Granting Motion to terminate wage attachment (RE: related document(s)45). (Attachments: # 1 Certificate of Service) (DP) (Entered: 01/12/2005) 01/13/2005 47 Praecipe to Convert (Absolute Right) from Chapter 13 to Chapter 7. Filing fee due in the amount of$ 15.00 Filed by James M Bach on behalf of James C Hoover, Linda L Hoover (RE: related document(s) 1.). (Attachments: # 1. Statement ofIntention, Amended J, Verification Statement) (Bach, James) (Entered: 01/13/2005) 01/13/2005 Receipt of Praecipe to Convert from Ch. 13 to Ch, 7 (Absolute Right) (1:04-bk-00933-MDF) [misc,abscnv7] (15.00) filing fee. Receipt number 835636, amount $ 15.00. (U.S. Treasury) (Entered: . 01/13/2005) 01/14/2005 48 Notice to Filing Party: ** Please docket the Statement of Intention and Amendment to Schedule J (which were filed as part of the conversion) as separate events **. (RE: related document(s)47). (DP) (Entered: 01/14/2005) 01/14/2005 42 Statement of Intentions Filed by James M Bach on behalf of James C Hoover, Linda L Hoover. (Bach, James) (Entered: 01/14/2005) 01/14/2005 50 Amendment to Schedule J Filed by James M Bach on behalf of James C Hoover, Linda L Hoover (RE: related document(s)l). (Bach, James) (Entered: 01/14/2005) I https://ecf.pamb.uscourts.gov/cgi-bin/DktRpt.pl?79l 020500472871-L _82_0-1 6/6/2005 '^' ~ ~..'~" --~ J~~~ ~~ , .~~- ...J~." J1JiIi:fi(-. ~ USBC PAM - LIVE - V2.6 - Docket Report Page 7 of8 01/18/2005 Trustee Leon p, Haller (Trustee) added to case.. (There is no image or paper document associated with this entry.) Filed by United States Trustee. (united states trustee(wp),) (Entered: 01/18/2005) 01/18/2005 Tentative Date for Meeting of Creditors. THIS IS SUBJECT TO CHANGE. 2/28/2005 at 08:30 AM. (AG) (Entered: 01119/2005) 01/26/2005 .51 Stipulation in Settlement of the Motionfor Relieffrom Stay Filed by Jay B Jones of Phelan Hallinan & Schmieg, LLP on behalf of Waypoint Bank as Servicer for the Mortgagee of Record (RE: related document(s)34 ). (Attachments: # 1 Proposed Order) (Jones, Jay) (Entered: 01/26/2005) 01/27/2005 52 Order approving Stipulation (RE: related document(s)( 43], 34,21), (CR) (Entered: 01128/2005) 01/31/2005 53 Request to BNC - Meeting of Creditors . 341(a) meeting to be held on 2/28/2005 at 09:30 AM Federal Bldg, Trustee Hearing Rm, Rm 1160, II th FI, 228 Walnut St, Harrisburg, P A Last day to oppose discharge or dischargeability is 4/29/2005 (AG) (Entered: 01/31/2005) 02/02/2005 54 BNC Certificate of Mailing. (RE: related document(s)53 ). Service Date 02/02/2005. (Admin.) (Entered: 02/03/2005) 02/09/2005 55 Request for Notice under 2002 Filed by Alice Whitten on behalf of AmeriCredit. (DP) (Entered: 02/09/2005) 03/01/2005 56 Certification that 341 Meeting of Creditors Held (Ch. 7) on 2/28/2005. (There is no image or paper document associated with this entry.). (haller(bp), Leon) (Entered: 03/01/2005) 03/16/2005 57 Final Report Filed by Trustee. (dehart, III(ck), Charles) (Entered: 03/16/2005) 04/04/2005 58 Application to appoint himselfiherself or their law firm as Attorney Filed by Trustee. (Attachments: # 1 Exhibit # 2. Declaration of Attorney# J Proposed Order # 4. Certificate ofService)(haller(bp), Leon) (Entered: 04/04/2005) 04/18/2005 59 Application to Employ Realty Services Group, Inc. as Realtor Filed by Trustee. (Attachments: # 1 Verification# 2. Declaration of Real Estate Agent# J Proposed Order # 4. Certificate of Service) (baller (bp), Leon) (Entered: 04/18/2005) 04/19/2005 60 Order Granting Application of Trustee to appoint self as Attorney (RE: related document(s)58 ). (CK) (Entered: 04/19/2005) https://ecf.pamb.uscourts.gov/cgi -bin/DktRpt.pl?79I 020500472871- L _82_0-1 6/6/2005 -"-, " " ~ri ,,-, "' . -';.,."'"- "", USBC PAM - LIVE - V2.6 - Docket Report Page 8 of8 04/28/2005 61 Order Granting Application to Employ Realty Services Group (RE: related document(s)59 ). (CK) (Entered: 04/2812005) 05/0412005 62 Request to BNC - Discharge of Debtor(s) (Admin.) (Entered: 05/04/2005) 05/06/2005 fiJ BNC Certificate of Mailing of Discharge (Chapter 7) (RE: related document(s)62), Service Date 05/0612005. (Admin.) (Entered: 05/07/2005) 05/1112005 64 Request to BNC - Final Decree VACATED by Order dated 5/20/05, (CK) Modified on 512012005 (DP). (Entered: 0511112005) 05113/2005 65 BNC Certificate of Mailing of Final Decree (RE: related document(s) 64 ). Service Date 05/13/2005. (Admin.) (Entered: 05/14/2005) 05120/2005 66 Order Vacating Final Decree (RE: related document(s)64 ). (CK) (Entered: OS/20/2005) I PACER Service Center I I Transaction Receipt I I 06/06/200514:27:04 I IPACER l~a0060 I Client Code: Login: 1:04-bk-00933-MDF Fit or Ent: Description: Docket Search Fit Doc From: 0 Doc To: Report Criteria: 99999999 Tenn: y Links: n Fonnat: HTMLflnt Billable D810.32 ]1 Pages: https://ecf.pamb.uscourts.gov/cgi-binlDktRpt.pl?791 020500472871-L _82_0-1 6/612005 o/"'~"'~" .. ..1':_ iO"'''' ,~ , "-, _r.,~_ - ~ ~oldbeck McCafferty & McKeever BY: Joseph A. Goldbeck, Jr. AttorneyI.D. #16132 Suite 5000 - Mellon Independence Center 70 I Market Street Phijadelphia, PA 19106-1532 215-627-1322 Attorney for Plaintiff FIRST NATIONWIDE MORTGAGE CORPORATION PO Box 9481 Mail Code: 22-528-1011 Gaithersburg, MD 20898-9481 IN THE COURT OF COMMON PLEAS of Cumberland County Plaintiff vs, CNIL ACTION - LAW JAMES HOOVER LINDA HOOVER (Mortgagor(s) and Record Owner(s)) 329 15th Street New Cumberland, P A 17070 ACTION OF MORTGAGE FORECLOSURE Defelldant( s) No.01-3220-CNIL AFFIDAVIT PURSUANT TO RULE 3129 FIRST NATIONWIDE MORTGAGE CORPORATION, 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 infonnation concerning the real property located at: 329 15th Street New Cumberland, PA 17070 LName and address ofOwner(s) or Reputed Owner(s): JAMES HOOVER 329 15th Street New Cumberland, P A 17070 LINDA HOOVER 329 15th Street New Cumberland, P A 17070 2, Name and address ofDefendant(s) in the judgment: JAMES HOOVER 329 15th Street New Cumberland, PA 17070 LINDA HOOVER 329 15th Street New Cumberland, P A 17070 3, Name and last known address of every judgment creditor whose judgment is a record lien on the property to be sold: DOMESTIC RELATIONS OF CUMBERLAND COUNTY PO Box 320 "'~ . ~~..~_." - . 1- "' ,', ~ -~1U,i . . , Carlisle, PA 17013 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 GREENWOOD TRUST CO, P,O, BOX 11848 HARRISBURG, PA 17108 BELCO COMM, CREDIT UNION 403 N, 2ND STREET HARRISBURG, PA 17101-1322 SOVEREIGN BANK c/o HEATHER A. SOLLEY 60 I Penn Street Reading, PA 19601 WAYPOINTBANK 235 North 2nd Street P,O, Box 1711 Harrisburg, P A 17011 4. Name and address of the last recorded holder of every mortgage of record: FIRST FEDERAL SAVINGS & LOAN 234 N. SECOND STREET HARRISBURG, PA 17101 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, TENANTS/OCCUPANTS 329 15th Street New Cumberland, P A 17070 (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: Jnne 6. 2005 (~&!<t,.i)@.Jw;'IM,'il\Iii,;l'!llt'bi-r"tj';,M'lii,j"("';;;Sf';1il'!1;t;;I*_~A~~,""j:,;''':'4;';;'iJ:'~\i>.oi;';-'!U~'];'I''-'~''~'i!'',,'-t",,''-'ila''_1,i;@;l!i.l'iAAi1>1!JifIUWil!!jili>tW!~IIi.lilllHII~jii~~f~_m~iiro- ~~ D ~: ff~ Zc' 0,~~ '-->1:" :$- .s;" j;Ci c: ~ '" = = c.n L- c::: :z: I Cl) ~ ~:n ::Bt9 g~ Cr; -+I 05 2m ~ ~ -< ;c. ::r; <;? C) U1 - -"~ I . .I [~ " !:I ill Ii , ~J :,1 :1 I .:! .' ilr I ."" ..,;_.,~ " ,-. ".'. ,Y,'. -""'~", . t' OI-3220-CNIL GOLDBECK McCAFFERTY & McKEEVER BY: Joseph A Goldbeck, JT. Atlorney I.D.#16132 Suite 5000- Mellon Independence Center 701 Market Street Philadelphia, PA 19106 215-627-1322 Atlorney for Plaintiff FIRST NATIONWIDE MORTGAGE CORPORATION PO Box 9481 Mail Code: 22-528-1011 Gaithersburg, MD 20898-9481 IN THE COURT OF COMMON PLEAS of Cumberland County Plaintiff CIVIL ACTION - LAW vs, JAMES HOOVER LINDA HOOVER Mortgagor(s) and Record Owner(s) ACTION OF MORTGAGE FORECLOSURE 329 15th Street New Cumberland, P A 17070 Term No.01-3220-CIVIL Defendant( s THIS LAW FIRM IS A DEBT COLLECTOR AND WE ARE ATTEMPTING TO COLLECT A DEBT. THIS NOTICE IS SENT TO YOU IN AN ATTEMPT TO COLLECT A DEBT. ANY INFORMATION OBTAINED FROM YOU WILL BE USED FOR THAT PURPOSE. NOTICE OF SHERIFF'S SALE OF REAL PROPERTY TO: HOOVER, JAMES JAMES HOOVER 329 15th Street New Cumberland, P A 17070 Your house at 329 15th Street, New Cumberland, P A 17070 is scheduled to be sold at Sheriff's Sale on Wednesday, September 07, 2005, at 10:00 AM, in Commissioners Hearing Rm 2nd FL Courthouse to enforce the court judgment of$21,056.51 obtained by FIRST NATIONWIDE MORTGAGE CORPORATION against you, NOTICE OF OWNER'S RIGHTS YOU MAY BE ABLE TO PREVENT THIS SHERIFF'S SALE To prevent this Sheriff's Sale you must take immediate action: 1. The sale will be cancelled if you pay to FIRST NATIONWIDE MORTGAGE CORPORATION, the back payments, late charges, costs and reasonable attorney's fees due, To find out how much you must pay call: 215-627-1322 .. ,.. ~ ~.' l " .l.. I ,. OI-3220-CNIL . 2, You may be able to stop the sale by filing a petition asking the Cour1 to strike or open judgment, if the judgment was improperly entered. You may also ask the Court to postpone the sale for good cause, 3. You may also be able to stop the sale through other legal proceedings. 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 'fAKE PLACE. I, If the Sheriffs Sale is not stopped, your property will be sold to the highest bidder. You may [md 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 Sheriff 0017-240-6390, 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 within 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 TillS PAPER TO YOUR LAWYER AT ONCE, IF YOU DO NOT HAVE A LAWYER OR CANNOT AFFORD ONE, GO TO OR TELEPHONE THE OFFICE LISTED BELOW TO FIND OUT WHERE YOU CAN GET LEGAL HELP, LEGAL SERVICES INC 8 Irvine Row Carlisle, P A 17013 CUMBERLAND COUNTY BAR ASSOCIATION 2 Liberty Avenue Carlisle, P A 17013 . ~ . . , , ~>~, li!i.ili] , Ol-3220-CIVIL ~ . GOLDBECK McCAFFERTY & McKEEVER BY: Joseph A Goldbeck, Jf. Attorney LD,#16132 Suite 5000- Mellon Independence Center 701 Market Street Philadelphia, PA 19106 215-627-1322 Attorney for Plaintiff FIRST NATIONWIDE MORTGAGE CORPORATION PO Box 9481 Mail Code: 22-528-1011 Gaithersburg, MD 20898-9481 IN THE COURT OF COMMON PLEAS of Cumberland County Plaintiff CIVIL ACTION - LAW vs, JAMES HOOVER LINDA HOOVER Mortgagor(s) and Record Owner(s) ACTION OF MORTGAGE FORECLOSURE 329 15th Street New Cumberland, P A 17070 Term No,01-3220-CIVIL Defendant( s THIS LAW FIRM IS A DEBT COLLECTOR AND WE ARE ATTEMPTING TO COLLECT A DEBT. THIS NOTICE IS SENT TO YOU IN AN ATTEMPT TO COLLECT A DEBT. ANY INFORMATION OBTAINED FROM YOU WILL BE USED FOR THAT PURPOSE. NOTICE OF SHERIFF'S SALE OF REAL PROPERTY TO: HOOVER, LINDA LINDA HOOVER 329 15th Street New Cumberland, P A 17070 Your house at 329 15th Street, New Cumberland, PA 17070 is scheduled to be sold at Sheriffs Sale on Wednesday, September 07, 2005, at 10:00 AM, in Commissioners Hearing Rm 2nd FL Courthouse to enforce the court judgment of $21 ,056,51 obtained by FIRST NATIONWIDE MORTGAGE CORPORATION 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 FIRST NATIONWIDE MORTGAGE CORPORATION, the back payments, late cbarges, costs and reasonable attorney's fees due. To find out how much you must pay call: 215-627-1322 , . ~-~ . ., ~ "' '"" -j , ~ OI-3220-CNIL . 2. You may be able to stop the sale by filing a petition asking the Court to strike or open judgment, if the judgment was improperly entered. You may also ask the Court to postpone the sale for good cause. 3. You may also be able to stop the sale through other legal proceedings. 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 find out the price bid price by calling the Sheriff 0017-240-6390. 2. You maybe 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 0017-240-6390. 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 maybe entitled to a share of the money which was paid for your house. A schedule of distribution of the money bid for your house will be filed by the Sheriff within 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 inuuediately after the sale. YOU SHOULD TAKE THIS PAPER TO YOUR LAWYER AT ONCE. IF YOU DO NOT HAVE A LAWYER OR CANNOT AFFORD ONE, GO TO OR TELEPHONE THE OFFICE LISTED BELOW TO FIND OUT WHERE YOU CAN GET LEGAL HELP. LEGAL SERVICES INC 8 Irvine Row Carlisle, P A 17013 CUMBERLAND COUNTY BAR ASSOCIATION 2 Liberty Avenue Carlisle, P A 17013 , ~,;k&-W4l,kl"':ll:~';';~ '-,:~jL"";:;A,;_",i;"j1!.i't?-a_1i"\:i!:J;"Ji';",ji>l'""",,.:~"ie';;kf"t!t!i'_;"!_,''''2",~" ',".-;,~;;;'H~"'_;t';' ,",;..iad.:":ill;NI;i!'!!fi,"l.i'lj4,!/;ImitiW~iMiiliIii'rlil$t:>l!~ : -~ l'" ,- ct u~ .1 "--~ ._~- ~1_"'ll'iI!!IlI (") "" = ~ c: = ~ c.n -q~;9 <- ~ ~~: c: fn:IJ z ~.~ I CO r-.::'-", <....j :21' 2::{) :t>> -rl 6() ::!l: ~.~ )>-c S? 0 :;:..: -oj ...... Cl ?ii -< (Jl -< . . , I !-: " L] i [; ~ II Ii "" , '--""""=~"''''~i!-''" \ GOLDBECK McCAFFERTY & McKEEVER BY: Joseph A. Goldbeck, Jr. Attorney I.D.#16132 Suite 5000 - Mellon Independence Center 70 I Market Street Philadelphia, PA 19106-1532 215-627-1322 Attnme for Plaintiff FIRST NATIONWIDE MORTGAGE CORPORATION PO Box 9481 Mail Code: 22-528-1011 Gaithersburg, MD 20898-9481 FN-0232 CF: OS/25/2001 SD: 09/07/2005 $21,056.51 IN THE COURT OF COMMON PLEAS of Cumberland County Plaintiff CIVIL ACTION - LAW vs. ACTION OF MORTGAGE FORECLOSURE JAMES HOOVER LINDA HOOVER Mortgagor(s) and Record Owner(s) Term No. 01-3220-CIVIL 329 15th Street New Cumberland, P A 17070 Defendant(s) CERTIFICATE OF SERVICE PURSUANT TO Pa.R.C.P. 3129.2 (c) (2) JOSePh. .A. Goldbeck, J.r., ESq. .uire, Attorney for Plaintiff, hereby certJfie. s that se.. rvice on the De:r{~t~theNoticor:S~:iff~~~er;~madeb~lltl.\n,.lY .... dA.) ..... .LQ. J9gt. .......... '. oS..', ~{/'l~r~rvlce~tHe~~~/~ .... .. lJ ( j Certified mail by Joseph A. Goldbeck, Jr. (original green Postal return receipt attached). ( ) Certified mail by Sheriffs Office. ( ) Ordinary mail by Joseph A. Goldbeck, Jr., Esquire to Attorney for Defendant(s) of record (proof of mailing attached). ( ) Acknowledgment of Sheriffs Sale by Attorney for Defendant(s) (proof of acknowledgment attached). ( ) Ordinary mail by Sheriffs Office to Attorney for Defendant(s) of record. IF SERVICE WAS ACCOMPLISHED BY COURT ORDER. ( ) Premises was posted by Sheriffs Office/competent adult (copy of return attached). ( ) Certified Mail & ordinary mail by Sheriffs Office (copy ofreturn attached). ( ) Certified Mail & ordinary mail by Joseph A. Goldbeck, Jr. (original receipt(s) for Certified Mail attached). Pursuant to the Affidavit under Rule 3129 (copy attached), service on all lienholders (if any) has been made by ordinary mail by Joseph A. Goldbeck, Jr., Esquire (copies of proofs of mailing attached). The undersigned understands that the statements herein are subject to the penalties provided Section 4904. .-'I .-'I ru D f,i f:~ _~:! !<. ~..'""~ " ~:; ~'"'~~ " J .:f ''"....~ .::r ..n t'- ru Postage $ Yes .-'I D CI Relum Receipt Fee CJ (Endorsement Requlmd) CI Restricted Delivery Fee ...D (Endol'&)ment Required) .-'I .-'I ~ Certified Fee Total Postage & Faas $ LO CI ant 0 C] HOOVER. LINDA r"- Sfi;n-l"Jiiii7ifo~~---~------.---'_._----"-_._----_u;--------------____n_______ :O,;:bS""NO." 329 15th Stree'c i'iio/,s'""-ZIF;.-New---ettrrrb'erl:arrd-;----f'-A---+'1-e-r{l---- ~.O, ~~">.'. '" IT' .-'l D .::r ..!l t'- ru ~ClFF Poslage .-'l D C] CJ Return Receipt Fee (Endorsement Required) Cartlflad Fee y S CJ Restricted DellVElty Fee ...lJ (Endol'S8"ment RequIred) .-'l .-'l Total Postage & Fees 4. $ VJ : LO _32 9 7 D ,~OVER. 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'1Jw-<-I t1. )>~ 0 It ~ ::0 ~ Cj m ~ ~ J is IJ' <-.. ti jl o Q ." '" g W :s: m m ::0 r )> Z o II'V"Tl ""'0 )> '" _ 0 :::o.(:>.~ g :::0 :z -I fI) U5 rn " :,:mc; ::oOm .0~~ 'UOr )> en '" j~;o~ o Z ~ en ~ r .." "s> ~ o c f.Q.~ Z lio! ~ffi <" ~t! ffi~ 0 c ~fI) '''n 00 oil. ~ ~o mo ~'" m 0 ~'" m:I: ~" m 0 I~" m" " a, o .. Z c 3 ~ ~"O""(/lCl "'IClC:OZ ...-...- III ~>s:;;IG~ ~c)>(IImlll U1m;:;tJQimfi. l::lr"mgOl> "0.... "2: I " -(/l m >-1 m "'0:::0 a )>m (/) m " .... 5- ~ () ". " o DDDDD '" '" '0 " o - 3"mo(')(") ~~ ~g~ ~m~ ~ 3 ~b' ~ =;::l ~ g ~ ~ ~r :< ~. DDDD '" bJ " 8' .<E. cn;c::u;::c lO'm.~ Il ;::l c: _. ~ 3 li a ro~i!.il. o ~ 0 o _. fI) 5,"S. ~ 3 Q' ~ ~s: g ~ ~ . o ~ $ , It 3 '" 6' o g 0""0 Q,Q @::;:;)> ~g ::TO'aij)'~ 'TI (1)...... iir.....::hlll x m Q,~ 9:~~~~ "'T1-.59:<DlllO) ""'''' g-Q,Ul 3 ~ III ::J 3 Q)"'O ro::l IU W I o:I:&Q. 8= <D ffi~ ...... "2.~ m ~g, ffi m,il ~*- -~= - ~., .~. ,~ ~~ ~' _" 1._ - , " "~*" " ~ GOLDBECK McCAFFERTY & McKEEVER BY: Joseph A. Goldbeck, Jr. Attorney I.D.#16132 Suite 5000 - Mellon Independence Center 701 Market Street Philadelphia, P A 19106 215-627-1322 Attorney for Plaintiff FIRST NATIONWIDE MORTGAGE CORPORATION PO Box 9481 Mail Code: 22-528-1011 Gaithersburg, MD 20898-9481 IN THE COURT OF COMMON PLEAS of Cumberland County Plaintiff CIVIL ACTION - LAW vs. ACTION OF MORTGAGE FORECLOSURE JAMES HOOVER LINDA HOOVER Mortgagor(s) and Record Owner(s) Term No. 01-3220-CIVIL 329 15th Street New Cumberland, P A 17070 Defendant( s) AFFIDAVIT PURSUANT TO RULE 3129 FIRST NATIONWIDE MORTGAGE CORPORATION, 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: 329 15th Street New Cumberland, P A 17070 l.Name and address ofOwner(s) or Reputed Owner(s): JAMES HOOVER 329 15th Street New Curoberland, P A 17070 LINDA HOOVER 329 15th Street New Cumberland, P A 17070 2. Name and address ofDefendant(s) in the judgment: JAMES HOOVER 329 15th Street NewCumberland,PA 17070 LINDA HOOVER 329 15th Street New Curober1and, P A 17070 - ~- - ,~ k AL>.. ,~ ,~. -='. ~ ~:it,,' .' , . 3. Name and last known address of every judgment creditor whose judgment is a record lien on the property to be sold: DOMESTIC RELATIONS OF CUMBERLAND COUNTY PO Box 320 Carlisle, PA 17013 PA DEPARTMENT OF PUBLIC WELFARE - Bureau of Child Support Enforcement Health and Welfare Bldg. - Room 432 P.O. Box 2675 Harrisburg, PA 17105-2675 GREENWOOD TRUST CO. P.O. BOX 11848 HARRISBURG, PA 17108 BELCO COMM. CREDIT UNION 403 N. 2ND STREET HARRISBURG, PA 17101-1322 SOVEREIGN BANK c/o HEATHER A. SOLLEY 601 Penn Street Reading, PA 19601 W A YPOINT BANK 235 North 2nd Street P.O. Box 1711 Harrisburg, PA 17011 4. Name and address of the last recorded holder of every mortgage of record: FIRST FEDERAL SAVINGS & LOAN 234 N. SECOND STREET HARRISBURG, PA 17101 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. TENANTS/OCCUPANTS 329 15th Street New Curnberland, PA 17070 (attach separate sheet if more space is needed) 1 verify that the statements made in this affidavit are j:ru~ 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: August 5,2005 ~i~~~~"M<.J;i'~,~;~Btl~"'JW!ijlf'i,-r.Jioih\&!iii&l:iliJ~&i!l!lrn:1"~J!'H,;-j"I;"h'"",#,'l-<ii""J;i<>"",,,t;i\~!llIIli1jJ~"~'~ ~JIR!. ""~.. ~)'lJiltl~'--~ o c S ~~.,.. (,01;- is~:' V......' J;\~'; ~~i:..., ::P'S; L-. ~ -< ,..., "'" = c..n ~ CO' fs [0 ~- ~ " -0 ::1: ~ N ill ~ ::t..,., f11F :g~ b =:C=H 00 Zrn ~ ~ ~, "}~ ~'-~ o_....~<'_b-"" ".<. --. - '> - ~'i~r ~'" , '., First Nationwide Mortgage Corporation VS James Hoover and Linda Hoover In The Court of Common Pleas of Cumberland County, Pennsylvania Writ No. 2001-3220 Civil Term R. Thomas Kline, Sheriff, who being duly sworn according to law, states this writ is returned STAYED pursuant to instructions from Attorney Joseph Goldbeck. Sheriff's Costs: Docketing Poundage Advertising Posting Handbills Levy Surcharge Service Law Journal Patriot News Law Library Prothonotary Share of Bills 30.00 11.25 15.00 15.00 15.00 30.00 23.46 209.60 194.05 1.00 29.32 $ 573.68 paid by attorney 03/01104 Sworn and subscribed to before me So Answers: This .1"'--Ldayof~ ~~'::~t:.~ n . R. Thomas Kline, Sheriff 2004, A.D. ~H O'nulltv, # BY \Jr-1,. ~ Prothonotary Real ~eputy j,r) . ~'1lJl').9 eo. /'II'I{I( "....~~.._" ..".", ~- - -~ '~~" ~ ". 0": ; '>.-.;'" '. fu:b.;;,- . Goldbeck McCafferty & McKeever . iw: Joseph A. Goldbeck, JT. Attorney I.D. #16132 Suite 5000 - Mellon Independence Center 701 Market Street Philadelphia, PA 19106-1532 215-627-1322 Attorney for Plaintiff FIRST NATIONWIDE MORTGAGE CORPORATION PO Box 9481 Mail Code: 22-528-1011 Gaithersburg, MD 20898-9481 IN THE COURT OF COMMON PLEAS of Cumberland County Plaintiff vs. CIVIL ACTION - LAW JAMES HOOVER LINDA HOOVER (Mortgagor(s) and Record Owner(s)) 329 15th Street New Cumberland, P A 17070 ACTION OF MORTGAGE FORECLOSURE Defendant(s) No.01-3220-CIVIL AFFIDAVIT PURSUANT TO RULE 3129 FIRST NATIONWIDE MORTGAGE CORPORATION, Plaintiff in the above action, by its attorney, Joseph A. Goldbeck, JT., Esquire, sets forth as of the date the praecipe for the writ of execution was filed the following informatiou concerning the real property located at: 329 15th Street New Cumberland, P A 17070 l.Name and address ofOwner(s) or Reputed Owner(s): JAMES HOOVER 329 15th Street New Cumberland, P A 17070 LINDA HOOVER 329 15th Street New Cumberland, P A 17070 2. Name and address ofDefendant(s) in the judgment: JAMES HOOVER 329 15th Street New Cumberland, P A 17070 LINDA HOOVER 329 15th Street New Cumberland, P A 17070 3. Name and last known address of every judgment creditor whose judgment is a record lien on the property to be sold: DOMESTIC RELATIONS OF CUMBERLAND COUNTY PO Box 320 Carlisle, PA 17013 r.' ,-~~ ~" . _.~ - .J ~ ~ "". "-.... ~" t -" 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 GREENWOOD TRUST CO, P.O. BOX 11848 HARRISBURG, PA 17108 BELCO COMM, CREDIT UNION 403 N. 2ND STREET HARRISBURG, PA 17101-1322 4. Name and address of the last recorded holder of every mortgage of record: FIRST FEDERAL SAVINGS & LOAN 234 N. SECOND STREET HARRISBURG, PA 17101 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. TENANTS/OCCUPANTS 329 15th Street New Cumberland, P A 17070 (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: November 18, 2003 ,\~~ ~" . .....'_. .,",j ~ ~> -Ji.m.. ~ -~... -,"".~ ,', ~" 01-3220-CIVIL GOLDBECK McCAFFERTY & McKEEVER BY: Joseph A. Goldbeck, Jr, AttomeyI.D.#16132 Suite 5000- Mellon Independence Center 701 Market Street Philadelphia,PA 19106 215-627-1322 Attorney for Plaintiff FIRST NATIONWIDE MORTGAGE CORPORATION PO Box 9481 Mail Code: 22-528-1011 Gaithersburg, MD 20898-9481 IN THE COURT OF COMMON PLEAS of Cumberland County Plaintiff CIVIL ACTION - LAW vs. JAMES HOOVER LINDA HOOVER Mortgagor(s} and Record Owner(s) ACTION OF MORTGAGE FORECLOSURE 329 15th Street New Cumberland, P A 17070 Term No.01-3220-CIVIL Defendant(s TillS LAW FIRM IS A DEBT COLLECTOR AND WE ARE ATTEMPTING TO COLLECT A DEBT. TillS 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: HOOVER, JAMES JAMES HOOVER 329 15th Street New Cumberland, P A 17070 Your house at 329 15th Street, New Cumberland, PA 17070 is scheduled to be sold at Sheriffs Sale on Wednesday, March 03, 2004, at 10:00 AM, in Commissioners Hearing Rm 2nd FL Courthouse to enforce the court judgment of $10,655.31 obtained by FIRST NATIONWIDE MORTGAGE CORPORATION against you. NOTICE OF OWNER'S RIGHTS YOU MAY BE ABLE TO PREVENT TillS SHERIFF'S SALE To prevent this Sheriff's Sale you must take immediate action: 1. The sale will be cancelled if you pay to FIRST NATIONWIDE MORTGAGE CORPORATION, the back payments, late charges, costs and reasonable attorney's fees due. To find out how much you must pay call: 215-627-1322 ,(' "" - H ~-;,..,-"","-,~, '-"'~ -", . ,. 01-3220-CNIL 2. You may be able to stop the sale by filing a petition asking the Court to strike or open jndgment, if the judgment was improperly entered. You may also ask the Court to postpone the sale for good cause. 3. You may also be able to stop the sale through other legal proceedings. 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. 1. 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 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 ifthe buyer pays the Sheriff the full amount due in the sale. To find out ifthis has happened, you may call the Sheriff of717-240-6390. 4. If the amount due from the Buyer is oot 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 otherrights and defenses, or ways of getting your hOl1se back, if you act immediately after the sale. YOU SHOULD TAKE THIS PAPER TO YOUR LAWYER AT ONCE. IF YOU DO NOT HAVE A LAWYER OR CANNOT AFFORD ONE, GO TO OR TELEPHONE THE OFFICE LISTED BELOW TO FIND OUT WHERE YOU CAN GET LEGAL HELP. LEGAL SERVICES INC 8 Irvine Row Carlisle, P A 17013 CUMBERLAND COUNTY BAR ASSOCIATION 2 Liberty Avenue Carlisle, P A 17013 'c""il''''''''<~-' , ~ . ,. , " ,~ "~.....J'~-'~"r-,'" , "~. , ~ 01-3220-CIVIL GOLDBECK McCAFFERTY & McKEEVER BY: Joseph A. Goldbeck, Jr. Attorney I.D.#16132 Suite 5000- Mellon Independence Center 701 Market Street Philadelphia, PA 19106 215-627-1322 Attorney for Plaintiff FIRST NATIONWIDE MORTGAGE CORPORATION PO Box 9481 Mail Code: 22-528-1011 Gaithersburg, MD 20898-9481 IN THE COURT OF COMMON PLEAS of Cumberland County Plaintiff CIVIL ACTION - LAW vs. JAMES HOOVER LINDA HOOVER Mortgagor(s) and Record Owner(s) ACTION OF MORTGAGE FORECLOSURE 329 15th Street New Cumberland, P A 17070 Term No.01-3220-CIVIL Defendant( s THIS LAW FIRM IS A DEBT COLLECTOR AND WE ARE ATTEMPTING TO COLLECT A DEBT. THIS NOTICE IS SENT TO YOU IN AN ATTEMPT TO COLLECT A DEBT. ANY INFORMATION OBTAINED FROM YOU WILL BE USED FOR THAT PURPOSE. NOTICE OF SHERIFF'S SALE OF REAL PROPERTY TO: HOOVER, LINDA LINDA HOOVER 329 15th Street New Cumberland, P A 17070 Your house at 329 15th Street, New Cumberland, P A 17070 is scheduled to be sold at Sheriffs Sale on Wednesday, March 03, 2004, at 10:00 AM, in Commissiouers Hearing Rm 2nd FLCourthouse to enforce the court judgment of $1 0,655.31 obtained by FIRST NATIONWIDE MORTGAGE CORPORATION 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 inuuediate action: I. The sale will be cancelled if you pay to FIRST NATIONWIDE MORTGAGE CORPORATION, the back payments, late charges, costs and reasouable attorney's fees due. To fmd out how much you must pay call: 215-627-1322 ,~~~ ~ ". , - .,~ ~ < ~ ~- Ii!i.~zt. .~, ~ - 01-3220-CIVIL 2. You may be able to stop the sale by filing a petition asking the Court to strike or open judgment, if the judgment was improperly entered. You may also ask the Court to postpone the sale for good cause. 3. You may also be able to stop the sale through other legal proceedings. 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. 1. 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 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 ouly 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. If the amount due from the Buyer is not paid to the Sheriff, you will remain the owner ofthe 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 Sheriff's Sale. This schedule will state who will be receiving that money. The money will be paid out in accordance with this schedule unless exceptions (reasons why the proposed distribution is wrong) are med 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 HA VB A LAWYER OR CANNOT AFFORD ONE, GO TO OR TELEPHONE THE OFFICE LISTED BELOW TO FIND OUT WHERE YOU CAN GET LEGAL HELP. LEGAL SERVICES INC 8 Irvine Row Carlisle, P A 17013 CUMBERLAND COUNTY BAR ASSOCIATION 2 Liberty Avenue Carlisle, P A 17013 ,~,'iJlltl ~~ . " "n ~,~, '. ~ '","_ GO~DBECK McCAFFERTY & McKEEVER By: Joseph A. Goldbeck, Jr. Attorney I.D. #16132 Suite 500 - The Bourse Bldg. III S. Independence Mall East Philadelphia, PA 19106 (215) 627-1322 ATTORNEY FOR PLAINTIFF First Nationwide Mortgage Corp. P.O. Box 9481, Mail Code: 22-528-1011 Gaithersburg, MD 20898-9481 Vs. John o. Osgood (Mortgagor only) Susan C. Osgood (Mortgagor only) 52 Catoctin Court Silver Springs, MD 20906 CUMBERLAND COUNTY COURT OF COMMON PLEAS : CIVIL DIVISION NO 01-3220-Civil J~es Hoover (Real OWner only) Linda Hoover (Real OWner only) 329 15th Street New Cumberland, PA 17070 ALL THAT CERTAIN lot or tract of land situate in the Borough of New Cumberland, County of Cumberland and State of Pennsylvania, more particularly bounded and described as follows according to a survey of D.P. Raffensperger (49-29) dated March 4, 1974, to wit: BEGINNING at a point on the Northern side of 15th Street said point being 870.8 feet west of Bridge Street; thence extending along 15th Street South 62 degrees West 50 feet to a corner of lot number 30 on the hereinafter mentioned plan of lots; thence along lot number 30 north 28 degrees West 195 feet to a point a corner; thence North 62 degrees East 50 feet to a point a corner; thence extending through lot number 31 on said plan South 28 degrees East 195 feet to the point and place of BEGINNING. Being a part of lot numb~r 31 Section E plan of Hillside as recorded in the Cumberland County Recorder's Office in Plan Book 1, page 75. Having thereon erected a two story frame dwelling and detached frame garage known as 329 15th Street. Tax Parcel #26-23-0541-133 .,__","J.~" ~^~ - - WRIT OF EXECUTION and/or ATTACHMENT COMMONWEALTH OF PENNSYLVANIA) COUNTY OF CUMBERLAND) NO 01-3220 Civil CIVIL ACTION - LAW TO THE SHERIFF OF CUMBERLAND COUNTY: To satisfy the debt, interest and costs dne FIRST NATIONWIDE MORTGAGE CORPORATION, Plaintiff (s) From JAMES HOOVER AND LINDA HOOVER (1) You are directed to levy upon the property of the defendant (s)and to sell SEE LEGAL DESCRIPTION. (2) You are also directed to attach the property of the defendant(s) not levied upon in the possession of GARNISHEE(S) as follows: and to notifY the 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 himlher that he/she has been added as a garnishee and is enjoined as above stated. Amount Due $10,655.31 Interest FROM 9/12/01 AT 0.0100% Atty's Comm % Atty Paid $897.72 Plaintiff Paid Date: NOVEMBER 19, 2003 L.L. Due Prothy $1.00 Other Costs CURTIS R. LONG (Seal) prothonz P 7f '-......J2y: tJ.? 0 "/lAJ r. / Deputy REQUESTING PARTY: Name JOSEPH A. GOLDBECK, JR., ESQIDRE Address: SIDTE 5000 - MELLON INDEPENDENCE CENTER 701 MARKET STREET PHILADELPIDA, PA 19106-1532 Attorney for: PLAINTIFF Telephone: 215-627-1322 Supreme Court ill No. 16132 . Ii/Illiijjj ~ e~":1! il\%; i,Jl7"",-i,-",~,-:,_;o"",,~,,1 :'i' . ',,--,>,--: " ,_ ,_,,< :"_,':;""_,,,,,},,,:,";-1\t'B&f/Bi~>l4'/fi~iMfu[4tjW;Wtti@'~~!'1iiiliiJ-~H'lB:ifiii$m-'i;f~'l~""-~~~WBf&?lt ~.'U.1it~"~~.:~~~ ~ ~ f' Real Estate Sale # 45 On December 01, 2003 the sherifflevied upon the defendant's interest in the real property situated in New Cumberlartd Borough, Cumberland County, P A Known and numbered as 329 15th Street, New Cumberland, more fully described on Exhibit "A" filed with this writ and by this reference incorporated herein. Date: December 01, 2003 By: julIA S ~-C~ Real E~t~Deputy (-J c:;:;;] c:::v:u = cs::E) IN\1 v ~ l~! \1 /\ ~1 : S H ~~ :3 d Ff\ l!~ tz 11 61 AON .a.JL!t!1if~;L' .,: ' _ t~t'W,~ :lI:lIijl!:lI~S ,,,'~: c G 3c,l;j,jHI _ ~_ _ J~_~:_"~ . : ~" __u THE PATRIOT NEWS SUNDAY PATRIOT NEWS THE Proof of Publication Under Act No. 587, Approved May 16, 1929 Commonwealth of Pennsylvania, County of Dauphin} ss Michael Morrow, being duly sworn according to law, deposes and says: That he is the Controller of The Patriot News Co., a corporation organized and exlstin~ under the laws of the Commonweaith of Pennsylvania, with Its principal office and place of business at 812 10 818 Market Street, in the City of Harrisburg, County of Dauphin, State of Pennsylvania, owner and publisher of The Patriot-News and...,IM Sundav Patriot-News newspapers of general circulation, printed and published at 812 10 818 Market Street, in~the City, County and State aforesaid; that The Patriot-News and The Sunday Patriot-News wera 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 20th and 27th day(s) of January and the 3rd day(s} of February 2004. That neither he nor said Company is Interested in the subject matter of said printed notice <:>r advertising, and that all of the allegations of this statement as to the time, place and character of publication are true; and That he has personal knowledge of the facts aforesaid and is duly authorized and empowered to verify this statem-e'nt 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 ollice for the Recording of Deeds in and for said County of u hln In Miscellaneous BooK "M", Volume 14, Page 317. ill PUBLICATION ........................... ........____~................. COpy SALE #45 -~--... JiEAl. ESTATE SALE No. 45 ~ Writ No. 2001-3220 --- Civil Term Rrst NatIonwide _. __ _'==::- _ _ ~ortg~e Corp. - - ~ -Jam-es Hoover ancJ "" - Unda Hoover ""1Uty: Joseph Goldbeck .=! DESCRIPTION Notanal Seal Teny L Russell, Notal'{Public C!lyOlHarrlSbUrg,DauphinCounlY2006 ' NOTARY PUBLIC M c;ommissIoo Expires June 6, y ~_...... />.AOdlllIOnCllNolBCleS My commission expires June 6, 2006 _.r~"~,'._- CUMBERlAND COUNTY SHERIFFS OFFICE CUMBERlAND COUNTY COURTHOUSE CARliSLE, PA. 17013 -.. -=x.tErtIAfwlAIN' lot or tral't of land ,~iitjI in ff]e Borough of New Cumberland, _: :toum.) ofCwuberlandand Slate of Pennsylvania. :'~larTyooundedanddcscnl1edm. ,","{Q1T(lUI~ ~rx:ording 10 a survey of D.P. .. ~ (49-~9) dated March 4, 197-1., 10 '^" ~apointontheNorthern~idc ~~~~~llhs:::, Publisher's Receipt for Advertising Cost ~'::~l:''''''''''''''''l.1OI ~ublisher of The Patriot-News and The Sundav Patriot-News, newspapers of general c _ .Jon,; lot ,umbo, 3:f::"''':~ ~::; receipt of the aforesaid notice and pUblication costs and certifies that the same have bt eel to a poinl acorncr; thenceNort!i'52 150 feet to a point a corner; t1i!iite . ugh.JoL.l11UlJ.ber 31 on said plan ~tk "l;! rl"I;"f'''<Easl195 feet 10 the point and ptiii.il!JlEGINNING , . BEING apart of lot number 31 SeclionEplan .~ a5 recorded in the CumberlandCounly .~""'.SOfficeinPlanBookl,page75, - ~1f!VING thereon erected :l twc-~ry frame ~ and. detu:hed frame garage known ;IS mmSbeet, 'f,!./IPARCEL~'O" 26.23.0l41-1JJ. Statement of Advertising Costs To THE PATRIOT-NEWS CO., Dr. For publishing the notice or publication attached hereto on the above stated dates Total $ 194.05 6y.............,...,.......,..............,........................... " ~ '- j '.' '-," -';'""""~-"" _",-:i>~ -"~.':'ii';;d.i~'/'", REAL ESTATE SALE NO. 45 Writ No. 2001-3220 Civil First Nationwide Mortgage Corp. vs. James Hoover and Linda Hoover Atty.: Joseph Goldbeck ALL THAT CERTAIN lot or tract of land situate in the Borough of New Cumberland, County of Cum- berland and State of Pennsylvania, more particularly bounded and de- scribed as follows according to a survey of D.P. Raffensperger (49-29) dated March 4. 1974. to Wit: BEGINNING at a point on the Northern side of 15th Street said point being 870.8 feet west of Bridge Street; thence extending along 15th Street South 62 degrees West 50 feet to a corner of lot num- ber 30 on the hereinafter mentioned plan of lots; thence along lot num- ber 30 north 28 degrees West 195 feet to a point a corner; thence North 62 degrees East 50 feet to a point a corner; thence extending through lot number 31 on said plan South 28 degrees East 195 feet to the point and place of BEGINNING. Being a part of lot number 31 Section E plan of Hillside as re- corded in the Cumberland County Recorder's Office in Plan Book 1, page 75. Having thereon erected a two story frame dwelling and detached frame garage known as 329 15th Street. Tax Parcel #26-23-0541-133. ,;'~~ ".-,-, 1 i-',,'~, ~""\' ."~ "' '---'0 ~:"'.~ i:!1--'" . , 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 official legal periodical for the publication of all legal notices, and has, since January 2, 1952, been regularly issued weekly in the said County, and that the printed notice or publication attached hereto is exactly the same as was printed in the regular editions and issues of the said Cumberland Law Jounial on the following dates, viz: JANU~,{ 16,23,30,2004 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. SWORN TO AND SUBSCRIBED before me this 30 day of JANU~,{ 2004 SEAL LOIS E. SNYDER, Notary Public Carlisle Boro. Cumberland County My Commission Expires March 5. 2005 . ,~ii-.Ii:!liJ~IllLJl. "~ ~'H~ " 1:"" ~1<rW..;"jv, 01-3220-CNIL GaLDBECK McCAFFERTY & McKEEVER . BY: Joseph A. Goldbeck, Jr. \ AttomeyI.D.#16132 Suite 5000- Mellon Independence Center 701 Market Street Philadelphia, P A 19106 215-627-1322 Attorney for Plaintiff FIRST NATIONWIDE MORTGAGE CORPORATION PO Box 9481 Mail Code: 22-528-1011 Gaithersburg, MD 20898-9481 IN THE COURT OF COMMON PLEAS of Cumberland County Plaintiff CIVIL ACTION - LAW vs. JAMES HOOVER LINDA HOOVER Mortgagor(s) and Record Owner(s) ACTION OF MORTGAGE FORECLOSURE 329 15th Street New Cumberland, P A 17070 Term No.01-3220-CIVIL Defendant( s TillS LAW FIRM IS A DEBT COLLECTOR AND WE ARE ATTEMPTING TO COLLECT A DEBT. TillS 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: HOOVER, LINDA LINDA HOOVER 329 15th Street New Cumberland, P A 17070 Your house at 329 15th Street, New Cumberland, PA 17070 is scheduled to be sold at Sheriffs Sale on Wednesday, March 03, 2g04, at 10:00 AM, in Commissioners Hearing Rm 2nd FL Courthouse to enforce the court judgmeiit of $1 0,655.31 obtained by FIRST NATIONWIDE MORTGAGE CORPORATION 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 FIRST NATIONWIDE MORTGAGE CORPORA nON, the back payments, late charges, costs and reasonable attorney's fees due. To fmd out how much you must pay call: 215-627-1322 , ~ .~.- ,_ J . ~ '" - ~- ' " I" . JML~'~". 01-3220-CIVIL ,- i 2. You may be able to stop the sale by filing a petition asking the Court to strike or open judgment, if the judgment was improperly entered. You may also ask the Court to postpone the sale for good cause. 3. You may also be able to stop the sale through other legal proceedings. 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. 1. If the Sheriff's 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 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 ouly 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 0017-240-6390. 4. If the amount due from the Buyer is not paid to the Sheriff, you will remain the owner ofthe 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 maybe eutitled 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 inuuediately after the sale. YOU SHOULD TAKE THIS PAPER TO YOUR LAWYER AT ONCE. IF YOU DO NOT HAVE A LAWYER OR CANNOT AFFORD ONE, GO TO OR TELEPHONE THE OFFICE LISTED BELOW TO FIND OUT WHERE YOU CAN GET LEGAL HELP. LEGAL SERVICES INC 8 Irvine Row Carlisle, P A 17013 CUMBERLAND COUNTY BAR ASSOCIATION 2 Liberty Avenue Carlisle, P A 17013 IN!jiWiIM~i1Nlilf4I!~~4'jl_j'';Ml,!Mll'iHM.{il1i",<':'lO!>li1Jr''''J-0n''~l~,;c,"'i.o, ;'_ct-".:.',;)};,;," -~~_., ." ~.<"-i;"''0.;0~A~J','iti.lI<jti~~~olb~ ' -....- "'~,(iii&i~IlillI~'~"'~'-ll.ifr""Y'- ~...'~---~~ o ~- -oi.1~' rDf"l"', ~l ~I: J':C' ;;;'c' J;>C :z ::{ " o w ..,. (;~ - ,J) -p ~--... _::- ,,- ~ C) -n \\\~, ;<~J '-;-~ ir..;:> ,0 ,_".-n --;~,~:i, '::-::\ '?O -< . ~".~~ " ',- " .~.~ ,_., - ,,-I~- ,",._"" '~-'=" ,:UI, USBC PAM - LIVE - V2.2 - Docket Report Page 1 of7 CREDS, 2002, CLAIMS, 341Held, PlnCnfrmd, DISMISSED u.s. Bankruptcy Court Middle District of Pennsylvania (Harrisburg) Bankruptcy Petition #: 1:Ol-bk-06400-MDF Assigned to: Mary D France Chapter 13 Voluntary Asset Date Filed: 12/0312001 Date Terminated: 10/22/2003 Date Dismissed: 10/22/2003 James C Hoover 329 15TH STREET NEW CUMBERLAND, P A 17070 SSN: 205-36-4306 Debtor represented by Keith B Dearmond DeArmond Law Firm 1770 E Market St Ste 201 York,PA17402 717-846-8916 Fax: 717-846-8916 Linda L Hoover 329 15TH STREET NEW CUMBERLAND, P A 17070 SSN: 180-40-4701 Joint Debtor Charles J. Dehart, III P.O. BOX 410 HUMMELSTOWN, PA 17036 717 566-6097 Trustee United States Trustee PO Box 969 Harrisburg, PA 17108 717-221-4515 Asst. U.S. Trustee represented by Keith B Dearmond (See above for address) Filing Date # Docket Text 12/03/2001 1 VOLUNTARY PETITION under chapter 13 , [AG], ORIGINAL NIBS DOCKET ENTRY #1 (Entered: 12/03/2001) 12/03/2001 2 NOTICE of intent to dismiss case unless missing documents are filed: due by 12/18/01 Re: Item # 1 [Rescheduled], [AG], ORIGINAL NIBS DOCKET ENTRY #2 (Entered: 12/03/2001) ~I!l 111 ~ 0""'_'." "~;..,, ~" ^,~ --'""",,', ~ '-1>-''''--'' -,'",'- - L]f!j~' ; USBC PAM - LIVE - V2.2 - Docket Report Page 2 of7 01116/2002 3 CORRESPONDENCE to Attorney allowing until January 23, 2002 to file missing documents. Re: Item # 2, [CA], ORIGINAL NIBS DOCKET ENTRY #3 (Entered: 01116/2002) 01/22/2002 4 MOTION for extension of time to file Schedules Re: Item # 2, [AG], ORIGINAL NIBS DOCKET ENTRY #4 (Entered: 01123/2002) 01123/2002 5 ORDER extending time for filing Schedules: due by 02/08/02 Re: Item # 4 [Complied] [Entered: 01123102], [AG] This entry cancels the previous due date. Re: Item # 2, [AG], ORIGINAL NIBS DOCKET ENTRY #S (Entered: 01123/2002) 02/08/2002 Q Schedules, Statements, Plan & Summary and an missing documents Re: Item # 5, [DP], ORIGINAL NIBS DOCKET ENTRY #6 (Entered: 02/1112002) 02/19/2002 7 CERTIFICATE of Mailing of Notice of 341 Meeting. Objections to the plan are due 15 days after meeting held. , [CA], ORIGINAL NIBS DOCKET ENTRY #7 (Entered: 02/19/2002) 03/2112002 8 341 meeting not held-to be rescheduled. , [CA], ORIGINAL NIBS DOCKET ENTRY #8 (Entered: 03/22/2002) 03/29/2002 9 MOTION for relief from stay filed by FIRST NATIONWIDE MORTGAGE CORPORATION as Servicer for the Mortgagee of Record. [fee paid rec#580684 $75.00] [Disposed] [Entered: 03/29/02], [DS] CERTIFICATE OF NON-CONCURRENCE, [DS], ORIGINAL NIBS DOCKET ENTRY #9 (Entered: 03/29/2002) 03/29/2002 10 ORDER that answers are due on 04/19/02 Re: Item # 9, [DS], ORIGINAL NIBS DOCKET ENTRY #10 (Entered: 03/29(2002) 04/05/2002 11 ANSWER by Debtors Re: Item # 9, [BW], ORIGINAL NIBS DOCKET ENTRY #11 (Entered: 04/08/2002) 04/05/2002 14 CERTIFICATE of service of notice of rescheduled 341 Meeting, [CA], ORIGINAL NIBS DOCKET ENTRY #14 (Entered: 04/16/2002) 04/08/2002 12 CERTIFICATE of service Re: Item # 10, [BW], ORIGINAL NIBS DOCKET ENTRY #12 (Entered: 04/08/2002) 04/09/2002 13 CORRESPONDENCE SETTING PRELIMINARY PHONE CONFERENCE on 04/25102 at 03:00 P.M. at Federal Building, Bankruptcy Courtroom [3rd Floor], Third & Walnut Streets, Harrisburg, PA 17101 Re: Item # 9, [BW], ORIGINAL NIBS I .>-- . . i. , ~ , --"'W'_; USBC PAM - LIVE - V2.2 - Docket Report Page 3 of7 DOCKET ENTRY #13 (Entered: 04/09/2002) 04/2512002 15 PROCEEDING MEMO: phone conference held - stip. with trustee concurrence to be filed within 30 days [6 months were given to cure arrearages] Re: Item # 9, [CL], ORIGINAL NIBS DOCKET ENTRY # 15 (Entered: 04/2512002) 05/10/2002 16 341 meeting held., [CA], ORIGINAL NIBS DOCKET ENTRY #16 (Entered: 05/10/2002) 05/1612002 17 OBJECTION to Plan by Trustee. Re: Item # 6 [Disposed], [JR], ORIGINAL NIBS DOCKET ENTRY #17 (Entered: 05/16/2002) 06/04/2002 18 STIPULATION by Parties setting terms and conditions Re: Item # 9, [BW], ORIGINAL NIBS DOCKET ENTRY #18 (Entered: 06/0412002) 06/04/2002 19 ORDER approving stipulation Re: Item # 9, [BW], ORIGINAL NIBS DOCKET ENTRY #19 (Entered: 06/04/2002) 08/08/2002 20 MOTION TO DISMISS BY TRUSTEE WITH NOTICE SETTING HEARING on 09/12102 at 02:00 P.M. at Federal Building, Bankruptcy Courtroom [3rd Floor], Third & Walnut Streets, Harrisburg, PA 17101, [BW], ORIGINAL NIBS DOCKET ENTRY #20 (Entered: 08/0812002) 09/27/2002 21 NOTICE to parties in interest of Objection to Plan by Trustee. Hearing on 11114/02 at 02:00 P.M. at Federal Building, Bankruptcy Courtroom [3rd Floor], Third & Walnut Streets, Harrisburg, PA 17101, [CG], ORIGINAL NIBS DOCKET ENTRY #21 (Entered: 09127/2002) 11118/2002 22 STIPULATION by Parties Re: Item # 17, [BW], ORIGINAL NIBS DOCKET ENTRY #22 (Entered: 1111812002) 1111912002 23 APPROVED by the court. Re: Item # 22, [BW], ORIGINAL NIBS DOCKET ENTRY #23 (Entered: 11119/2002) 12/03/2002 24 PRAECIPE/WITHDRAWAL Re: Item # 17, [BW], ORIGINAL NIBS DOCKET ENTRY #24 (Entered: 12103/2002) 12/12/2002 25 ORDER Confirming Plan, [BW], ORIGINAL NIBS DOCKET ENTRY #25 (Entered: 12/12/2002) 0111712003 26 MOTION for relief from stay filed by Waypoint Bank [fee paid rec#590859 $75.00] [Entered: 01117/03], [DS] CERTIFICATE OF NON-CONCURRENCE, [DS], ORIGINAL I I d~ ,~-, '--- ,~ ~, >.~., .,' ~""" USBC PAM - LIVE - V2.2 - Docket Report Page 4 of7 NIBS DOCKET ENTRY #26 (Entered: 01117/2003) 01117/2003 27 ORDER that answers are due on 02106/03 Re: Item # 26 [Rescheduled], [DS], ORIGINAL NIBS DOCKET ENTRY #27 (Entered: 01117/2003) 01127/2003 28 CERTIFICATE of service Re: Item # 27, [DS], ORIGINAL NIBS DOCKET ENTRY #28 (Entered: 01127/2003) 02119/2003 29 CORRESPONDENCE from Movant requesting new standing order Re: Item # 27, [BW], ORIGINAL NIBS DOCKET ENTRY #29 (Entered: 02/20/2003) 02/2012003 30 ORDER that answers are due on 03/12103 Re: Item # 26 [Rescheduled] (Entered: 02/20/03], [BW] This entry cancels the previous due date. Re: Item # 27, [BW], ORIGINAL NIBS DOCKET ENTRY #30 (Entered: 02120/2003) 03/12/2003 31 CORRESPONDENCE from Movant requesting new order for service Re: Item # 30, [BW], ORIGINAL NIBS DOCKET ENTRY #31 (Entered: 03/12/2003) 03/1212003 32 ORDER that answers are due on 04/01103 Re: Item # 26 [Entered: 03/12/03], [BW] This entry cancels the previous due date. Re: Item # 30, [BW], ORIGINAL NIBS DOCKET ENTRY #32 (Entered: 03/12(2003) 03/14/2003 33 CERTIFICATE of service Re: Item # 32, [DS], ORIGINAL NIBS DOCKET ENTRY #33 (Entered: 03/14/2003) 04/09/2003 34 MOTION for default judgment Re: Item # 26, [BW], ORIGINAL NIBS DOCKET ENTRY #34 (Entered: 04/09/2003) 04/17/2003 35 ANSWER by Debtors Re: Item # 26, [BW], ORIGINAL NIBS DOCKET ENTRY #35 (Entered: 04/18/2003) 04/22/2003 36 MOTION for relief from stay filed by AMERICREDIT FINANCIAL SERVICES, INC. [fee pd. $75.00, rec. #594514-AG] , [BW], ORIGINAL NIBS DOCKET ENTRY #36 (Entered: 04/22/2003) 04/22/2003 37 CERTIFICATE OF NON-CONCURRENCE Re: Item # 36, [BW], ORIGINAL NIBS DOCKET ENTRY #37 (Entered: 04/22/2003) 04/22/2003 38 ENTRY OF APPEARANCE of Richard C. Maider, Esq., on behalf of AMericredit Financial Services, Inc. , [BW], ORIGINAL NIBS DOCKET ENTRY #38 (Entered: 04/22/2003) . , "_ k. - ~- ~. " Wi!tHtl< USBC PAM - LIVE - V2.2 - Docket Report Page 5 of7 04123/2003 39 CORRESPONDENCE SETTING HEARING on 05/21103 at 09:00 A.M. at Federal Building, Bankruptcy Courtroom [3rd Floor], Third & Walnut Streets, Harrisburg, PA 17101 Re: Item # 35, [SP], ORIGINAL NIBS DOCKET ENTRY #39 (Entered: 04/23/2003) 04/28/2003 40 ORDER fixing hearing date on OS/21/03 at 09:00 A.M. at Federal Building, Bankruptcy Courtroom [3rd Floor], Third & Walnut Streets, Harrisburg, PA 17101 Re: Item # 36, [BW], ORIGINAL NIBS DOCKET ENTRY #40 (Entered: 04/28/2003) 05/05/2003 41 Certificate of Service Filed by Richard C Maider of Deily Mooney Glastetter LLP on behalf of AmeriCredit Financial Services, Inc. (RE: related document(s)[36], [40] ). (Wagner, Belinda) (Entered: 05/05/2003) 05/16/2003 42 Answer Filed by Keith B Dearmond of Burke and Hess on behalf of James C Hoover, Linda L Hoover (RE: related document(s)[36] ). (Wagner, Belinda) (Entered: 05/16/2003) 05/21/2003 43 Proceeding Memo (RE: related document(s)[39), [26) ). Stipulation due 6/20/2003. (Weigel, Erma) (Entered: OS/2112003) OS/2112003 Proceeding Memo: Hearing held. Settled - Stipulation within 30 days. Otherwise, proceeding to be dismissed without prejudice. (RE: related document(s)[26]). (Weigel, Erma) (Entered: 05/2112003) OS/2112003 44 Proceeding Memo: Hearing held and continued re: Americredit Fiancial's Motion for relief from stay. (RE: related document(s)[42], [36], [40]). Hearing scheduled for 6/11/2003 at 01:00 PM at 3rd & Walnut Streets, Bankruptcy Courtroom (3rd Floo r), Federal Building, Harrisburg, P A. Attorney Keith DeArmond to notice parties. (Weigel, Erma) (Entered: 05/21/2003) 06/02/2003 45 Certificate of Service of notice rescheduling hearing Filed by Keith B Dearmond of Burke and Hess on behalf of James C Hoover, Linda L Hoover (RE: related document(s)[44], [36], [40) ). Hearing scheduled for 611112003 at 01 :00 PM at 3rd & Walnu t Streets, Bankruptcy Courtroom (3rd Floor), Federal Building, Harrisburg, PA. (Wagner, Belinda) (Entered: 06/02/2003) 06/1112003 46 Proceeding Memo: Hearing held. Order granting relief from stay to be submitted by Attorney Maider's office.(RE: related document(s) [45), [36] ). (JG) (Entered: 06113/2003) 06111/2003 Corrective Entry to change Filed date from 6113/03 to 6/11103. (RE: related document(s)[46] ). (Leon, Kathi) (Entered: 06/16/2003) u ~~ ~--~ - " ~- _'_-0 ,"J.__"""","~.",,,,_j 1-. "'--<" ' -.,. """"'~ ~-'~ ~'" -':< USBC PAM - LIVE - V2.2 - Docket Report Page 6 of7 06/18/2003 47 Order Granting Motion for Relieffrom Stay (RE: related document(s) [36]). (Wagner, Belinda) (Entered: 06/18/2003) 06/20/2003 48 Certificate of Default Filed by Judith Romano of Federman & Phelan on behalf of First Nationwide Mortgage Corporation (RE: related document(s)[18]). (Wagner, Belinda) (Entered: 06/20(2003) 06/30/2003 49 Certificate of Service Filed by Richard C Maider of Deily Mooney Glastetter LLP on behalf of AmeriCredit Financial Services, Inc. (RE: related document(s)[47]). (Morrow, Sue) (Entered: 06/30/2003) 06/30/2003 50 PraecipelWithdrawal Filed by Keith B Dearmond of DeArmond Law Firm on behalf of James C Hoover, Linda L Hoover (RE: related document(s)[35]). (Rimmey, Jennifer) (Entered: 06/30/2003) 07/02/2003 51 Order Granting Motion for Relief from Stay (RE: related document(s) [39], [26]). (Wagner, Belinda) Additional attachment(s) added on 7/17/2003 to replace incorrect image with correct image for this entry. (TH). (Entered: 07/02/2003) 07/09/2003 52 Order granting relief from stay upon certificate of default. (RE: related document(s)[48], [9]). (BW) (Entered: 07/09/2003) 09/12/2003 53 Motion to Dismiss Case for material default and hearing notice to parties. Filed by Charles 1. Dehart III (RE: related document(s)[l]). Hearing scheduled for 10/912003 at 02:00 PM at 3rd & Walnut Streets, Bankruptcy Courtroom (3rd Floor), Federal Building, Harrisburg, PA. (BW) (Entered: 09/12/2003) 10/20/2003 54 Correspondence from Trustee re hearing. No appearance for debtor. Case to be dismissed Filed by Charles J. Dehart III (RE: related document(s)[53] ). (BW) (Entered: 10/20/2003) 10/22/2003 55 Order Granting Motion to Dismiss Case for material default (RE: related document(s)[53] ). (BW) (Entered: 10/22/2003) 10/24/2003 56 BNC Certificate of Mailing. Service Date 10/24/2003. (Related Doc # 55) (Admin.) (Entered: 10125/2003) 10/28/2003 57 Report of Trustee in Dismissed Case Filed by Charles J. Dehart III. (BW) (Entered: 10/29/2003) \1 PACER Service Center II d~' ~ __ J ,_,. ~ _ , j'_,,, -J _~ "'~' " ' Vi USBC PAM - LIVE - V2.2 - Docket Report Page 7 of7 I Transaction Receipt I I 11/11/2003 11:25:26 I Ip ACER Login: l~aOO60 IIClient Code: I IDescription: IIDocket Report IICase Nnm ber: 111:0 l-bk-06400-MDF I IBillable Pages: 113 IICost: 110.21 I \ --~~ ";~ f IJ"".:o' ~' " ",.',..,"."Sfo. PRAECIPE FOR WRIT OF EXECUTION - (MORTGAGE FORECLOSURE) P.R.C.P 3180-3183 ... Joseph A. Goldbeck, Jr. Nt0mey l.D.#16132 Suit; 5000 - Mellon Independence Center 701 Market Street Philadelphia, PA 19106-1532 215-627-1322 Attorney for Plaintiff FIRST NATIONWIDE MORTGAGE CORPORATION PO Box 9481 Mail Code: 22-528-1011 Gaithersburg, MD 20898-9481 IN THE COURT OF COMMON PLEAS Plaintiff of Cumberland County vs. CIVIL ACTION - LAW JAMES HOOVER LINDA HOOVER Mortgagor(s) and Record Owner(s) 329 15th Street New Cumberland, P A 17070 ACTION OF MORTGAGE FORECLOSURE No. 01-3220-CIVIL Defendant( s) PRAECIPE FOR WRIT OF EXECUTION TO THE PROTHONOTARY: Issue Writ of Execution in the above matter: Amount Due $10,655.31 Interest from to 09/12/2001 at 0.0100% (Costs to be added) ~"-~~~"Willi,!l,~l~iNW~~",*>#lmft~~l<iii"i>i!<i;jj00,ij",_;;;.;;",',::;r;M~,)j<,'b'~~tW,r~>>>Wiiii""'-";'" '~.".. 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"'0 ..= ""or> p., ~.~ " <Il "',I il " :! , . t ~ ,~,~ ......' " U1i~l51hi GOLDBECK McCAFFERTY & McKEEVER By: Joseph A. Goldbeck, Jr. Attorney 1.0. #16132 Suite 500 - The Bourse Bldg. 111 S. Independence Mall East Philadelphia, PA 19106 (215) 627-1322 I ATTORNEY FOR PLAINTIFF First Nationwide Mortgage Corp. P.O. Box 9481, Mail Code: 22-528-1011 Gaithersburg, MD 20898-9481 Vs. John o. Osgood (Mortgagor only) Susan C. Osgood (Mortgagor only) 52 Catoctin Court Silver Springs, MD 20906 : CUMBERLAND COUNTY COURT OF COMMON PLEAS : CIVIL DIVISION NO 01-3220-Civil James Hoover (Real Owner only) Linda Hoover (Real Owner only) 329 15th Street New Cumberland, PA 17070 ALL THAT CERTAIN lot or tract of land situate in the Borough of New Cumberland, County of Cumberland and State of Pennsylvania, more particularly bounded and described as follows according to a survey of D.P. Raffensperger (49-29) dated March 4, 1974, to wit: BEGINNING at a point on the Northern side of 15th Street said point being 870.8 feet west of Bridge Street; thence extending along 15th Street South 62 degrees West 50 feet to a corner of lot number 30 on the hereinafter mentioned plan of lots; thence along lot number 30 north 28 degrees West 195 feet to a point a corner; thence North 62 degrees East 50 feet to a point a corner; thence extending through lot number 31 on said plan South 28 degrees East 195 feet to the point and place of BEGINNING. Being a part of lot numb~r 31 Section E plan of Hillside as recorded in the Cumberland County Recorder's Office in Plan Book 1, page 75. Having thereon erected a two story frame dwelling and detached frame garage known as 329 15th Street. Tax Parcel #26-23-0541-133 -~Ia~"'.' .~ ~_~ ""h ~~ WRIT OF EXECUTION and/or ATTACHMENT COMMONWEALTH OF PENNSYLVANIA) COUNTY OF CUMBERLAND) NO 01-3220 Civil CIVIL ACTION - LAW TO THE SHERIFF OF CUMBERLAND COUNTY: To satisfy the debt, interest and costs due FIRST NATIONWIDE MORTGAGE CORPORATION, Plaintiff(s) From JAMES HOOVER AND LINDA HOOVER (1) You are directed to levy upon the property of the defendant (s)and to sell SEE LEGAL DESCRIPTION. (2) You are also directed to attach the property of the defendant(s) not levied upon in the possession of GARNISHEE(S) as follows: and to notify the garnishee(s) that: (a) an attachment has beeu issued; (b) the garnishee(s) is enjoined from payiug any debt to or for the account of the defendant (s) and from delivering any property ofthe defendant (s) or otherwise disposing thereof; (3) If property of the defendant( s) not levied upon an subj ect to attachment is found in the possession of anyone other than a named garnishee, you are directed to notify himlher that he/she has been added as a garnishee and is enjoined as above stated. Amount Due $10,655.31 Interest FROM 9/12/01 AT 0.0100% L.L. Atty's Comm % Atty Paid $897.72 Plaintiff Paid Date: NOVEMBER 19, 2003 Due Prothy $1.00 Other Costs CURTIS R. LONG (Seal) ProthOZ p 7p-/7~ ~.~" rU Deputy REQUESTING PARTY: Name JOSEPH A. GOLDBECK, JR., ESQmRE Address: SmTE 5000 - MELLON INDEPENDENCE CENTER 701 MARKET STREET PHILADELPHIA, PA 19106-1532 Attorney for: PLAINTIFF Telephone: 215-627-1322 Supreme Court 10 No. 16132 . - ~"'''''-~~.'''~i ~ ," .-- - ".'~ w< , Goldbeck McCafferty & McKeever BY: Joseph A. Goldbeck, Jr. AttorneyI:D. #16132 Suite 5000 - Mellon Independence Center 70 I Market Street Philadelphia, PA 19106-1532 215-627-1322 Attorney for Plaintiff FIRST NATIONWIDE MORTGAGE CORPORATION PO Box 9481 Mail Code: 22-528-1011 Gaithersburg, MD 20898-9481 IN THE COURT OF COMMON PLEAS of Cmnberland County Plaintiff vs. CIVIL ACTION - LAW JAMES HOOVER LINDA HOOVER (Mortgagor(s) aIld Record Owner(s)) 329 15th Street New Cmnberland, P A 17070 ACTION OF MORTGAGE FORECLOSURE Defendant( s) No.01-3220-CIVIL AFFIDAVIT PURSUANT TO RULE 3129 FIRST NATIONWIDE MORTGAGE CORPORATION, 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: 329 15th Street New Cumberland, P A 17070 l.Name and address ofOwner(s) or Reputed Owner(s): JAMES HOOVER 329 15th Street New Cumberland, P A 17070 LINDA HOOVER 329 15th Street New Cumberland, P A 17070 2. Name and address ofDefendant(s) in the judgment: JAMES HOOVER 329 15th Street New Cumberland, P A 17070 LINDA HOOVER 329 15th Street New Cumberland, P A 17070 3. Name and last laJ.own address of every judgment creditor whose judgment is a record lien on the property to be sold: DOMESTIC RELATIONS OF CUMBERLAND COUNTY PO Box 320 Carlisle, PA 17013 "'~~~ --"~ -I' ~ ......,., , ',.:. -w,._ ''-"-'--,,~. ~ , P A DEPARTMENT OF PUBLIC WELFARE - Bureau of Child Support Enforcement Health aod Welfare Bldg. - Room 432 P.O. Box 2675 Harrisburg, PA 17105-2675 . GREENWOOD TRUST CO. P.O. BOX 11848 HARRISBURG, PA 17108 BELCO COMM. CREDIT UNION 403 N. 2ND STREET HARRISBURG, PA 17101-1322 4. Name and address of the last recorded holder of every mortgage of record: FIF,ST FEDERAL SAVINGS & LOAN 234 N. SECOND STREET HARRISBURG, PA 17101 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 al!dress of every other person of whom the plaintiff has knowledge who has any record interest in the property which may be afiected by the sale. 7. Name and address of every other person of whom the plaintiff has knowledge who has any interest in the property which may be affected by the sale. TENANTS/OCCUPANTS 329 15th Street New Cumberland, P A 17070 (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. GOLDB BY: Joseph Attorney for DATED: November 18. 2003 ~'W~]~i;iM.mb";dit.;Io.'"Ii:jGi"111'l!i'&ti:;,,,,,;ii",2';;'~~'~ci-}"J:'~~'i';<~'tit'j,"',:,d"Jft",;;'""A;';~;.r.;MIiliM;!'i\;,,~-'''''",," l ,~,,,-,'_~","r."'~'''_~~",,__ _. _,~,.~>."",','''I'- , ,,",' ,~,' ""'''''' ~- ~" lilWiblbl,...,'~'e".iilMil\\iIj,~I~~~"""~" " ~~-, nf1"-"'''~ ~,~ ' 1: 1'1 ~ , "- .. ~" () (") ......, C LJ -'j'J s:. :1J.": -oUJ C?, " , rnf' ,,"- ZT , ZC: t'o ......! (/3",:_;', " t;;~ -......-. c;:C: :J:''' " ' -'(~- -tF ;~:...~; C,') :;;,_. - z:~, \:9 . '~"', I ';, ;J;>c -::J, ~,.o. Z 1..':> ::0 0--' ,,0 -< -,', ~ /-="''''''''''''~ ~-~ ~ -~ ,~, ;~ . , ~ - "j ""'....."FT. ::''<0""\. 01-3220-CIVIL , GOI.1DBECK McCAFFERTY & McKEEVER BY: JQseph A. Goldbeck, Jr. httomey1.D.#16132 Suite 5000- Mellon Independence Center 701 Market Street Philadelphia, P A 19106 215-627-1322 Attorney for Plaintiff FIRST NATIONWIDE MORTGAGE CORPORATION PO Box 9481 Mail Code: 22-528-1011 Gaithersburg, MD 20898-9481 IN THE COURT OF COMMON PLEAS of Cumberland County Plaintiff CIVIL ACTION - LAW vs. JAMES HOOVER LINDA HOOVER Mortgagor(s) and Record Owner(s) ACTION OF MORTGAGE FORECLOSURE 329 15th Street New Cumberland, P A 17070 Term No.01-3220-CIVIL Defendant(s THIS LAW FIRM IS A DEBT COLLECTOR AND WE ARE ATTEMPTING TO COLLECT A DEBT. THIS NOTICE IS SENT TO YOU IN AN ATTEMPT TO COLLECT A DEBT. ANY INFORMATION OBTAINED FROM YOU WILL BE USED FOR THAT PURPOSE. NOTICE OF SHERIFF'S SALE OF REAL PROPERTY TO: HOOVER, JAMES .JAMES HOOVER 329 15th Street New Cumberland, P A 17070 Your house at 329 15th Street, New Cumberland, P A 17070 is scheduled to be sold at Sheriffs Sale on Wedoesday, March 03, 2004, at 10:00 AM, in Commissioners Hearing Rm 2nd FL Courthouse to enforce the court judgment of$10,655.31 obtained by FIRST NATIONWIDE MORTGAGE CORPORATION 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 inuuediate action: 1. The sale will be cancelled if you pay to FIRST NATIONWIDE MORTGAGE CORPORATION, the back payments, late charges, costs and reasonable attorney's fees due. To find out how much you must pay call: 215-627-1322 "-~-' -,I . ~, ,- 10., --~- ".-, ~,-- 01-3220-CIVIL 2, ' f You may be able to stop the sale by filing a petition asking the Court to strike or open judgment, if t~ judgment was improperly entered. You may also ask the Court to postpone the sale for good cause. 3. You may also be able to stop the sale through other legal proceedings. 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. 1. 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 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 Sheriff of717-240-6390. 4. If the amount due from the Buyer is not paid to the Sheriff, you will remain the owner ofthe 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 inuuediately after the sale. yOU SHOULD TAKE THIS PAPER TO YOUR LAWYER AT ONCE. IF YOU DO NOT HAVE A LAWYER OR CANNOT AFFORD ONE, GO TO OR TELEPHONE THE OFFICE LISTED BELOW TO FIND OUT WHERE YOU CAN GET LEGAL HELP. LEGAL SERVICES INC 8 Irvine Row Carlisle, P A 17013 CUMBERLAND COUNTy BAR ASSOCIATION 2 Liberty Avenue Carlisle, P A 17013 ~~i!ioo.~ik,MW-..,t,j.;"li1ill1;F;,jh;t-"iii&ki;'<>i&~;&IIf:-M!~~~-iJl€,;IW.j;~'~,*,',~""!I1;S;'b;;0.J~i~JiN;;;","~,;'i1i&~ilm'it!ljf-- 'iI'jt~ - ~ "''j,~~ ~~ .<;' Li:r I':" 1i!1....". l'" ~ t' lLiif"- Jt ~ /.L'" z:-.~O? ,~,~"",O,'_ ,"~ .,,~ ~'Odn>~~ ,,~~. ~~ ~ . ^ ,I ,> ~~ -~'''' '.''''-'' >-~~^'.." o c ~ q) tf\ ~_c' . -.zr... {f),..,- -<. .,'. ~c,; ;E;c be-, J"C 2 -" .-( ~'"~"". ., c-:> 0> - ~~~ ,.0 .,.."" -..','- -;"" -, o -1"1 I-Y' J I- I) 5'~ ~9 '.v u:> ";':-fA ~; :P -<; n .lll . . 1',1 . ~ ~ ~ ~ ~ ~ r A W N ~ 0 CO CO -oJ 0> '" A W N 5' . . ~ . ,.,... v r-< ~ en .0 <;"m '" -n ~- 0 crZ 3 ~ 0 ",3 w .0 Ol . , ~ .... ~o .~ ~... '" )> .. .~ a ~ '" u> '" "i1 C. \ o (\J \f'l }J & &- '- ~ S- G '" . if t '" s! 9. w~ ~: II.l'Zo 0..10". n IlJ,: E I>.) 0 ~ .....1 OQ ii.~ "'0'.00 o ('"d ct !! ~). ri . o,_S!. 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V g ~",(f)G t:::.J,oooaato (t"'ff}!l ",,(JlCJ\~ i;.SO!;,. ~~Ii' ~t1~~ ? g.0;l~ '<:t1Q ~~i a:s:...l<l' r>> ..- :::l~S: ~gg:~ Q\ t,Q tl1 ~ DOOOg " o ~ -< u . a 8~~i o~"i}q: 0...... , . . ~ 3 :' ~ 0000. ~~~~ o-"J+' ~ i ~ ~ ~ =r ~ 0 ... ill:::r ~~~~a.~ <l>~ 3 ~ ;; ~. -s g :0 i3 ~ l Q ". ~@- 00 g. =;; $ on z 5: ll- ."l 2 . Q' " c " f 5: , ~ . ~ c Co. ~ tt ~ '" 5'0 " :>- -' 0 3 0_ Q:~~ X ?1U::l lr ~~ :I ~" u ~ 0- or ~" . . OJ ~ -2- ".83 '" X. "2.l\l ~. tl) ~:= 0 c :::. 0 t5 " Q. -- a. "" JI 3 ~ " " . a " . " ~ ". . ,~'--. . .I~.~"...~_~ N" - ',';"e',-" _l'1l1&. . GOLDBECK McCAFFERTY & McKEEVER BY: Jo.seph '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 FIRST NATIONWIDE MORTGAGE CORP. PO Box 9481 Mail Code: 22-528-1011 Gaithersburg, MD 20898-9481 Plaintiff vs. JAMES HOOVER AND LINDA HOOVER (Mortgagor(s) and Record Owner(s)) (Record Owner(s)) IN THE COURT OF COMMON PLEAS OF CUMBERLAND COUNTY CIVIL ACTION - LAW ACTION OF MORTGAGE FORECLOSURE 329 15th Street New Cumberland, Term No. 01-3220 CIVIL PA 17070 Defendant(s) CERTIFICATE OF SERVICE PURSUANT TO Pa.R.C.P. 3129.2(cl (2) Joseph A. Goldbeck, Jr., Esquire, Attorney for Plaintiff, hereby certifies that service on the Defendants of the Notice of Sheriff Sale was made by: ( ) Personal Service by the Sheriff's Office/competent adult (copy of ~ return attached) . ( ) Certified mail by Joseph A. Goldbeck, Jr. (original green Postal return receipt attached). ( ) Certified mail by Sheriff's Office. ( ) Ordinary mail by Joseph A. Goldbeck, Jr., Esquire to Attorney for Defendant(s} of record (proof of mailing attached). Acknowledgment of Sheriff's Sale by Attorney for Defendant(s) (proof of acknowledgment attached). Ordinary mail by Sheriff's Office to Attorney for Defendant(s) of record. IF SERVICE WAS ACCOMPLISHED BY COURT ORDER. ( ) Premises was posted by Sheriff's Office/competent adult (copy of return attached}. Certified Mail & ordinary mail by Sheriff's Office (copy of return attached) . Certified Mail & ordinary mail by Joseph A. Goldbeck, Jr. (original receipt(s) for Certified Mail attached). Pursuant to the Affidavit under Rule 3129 (copy attached), service on all lienholders (if any) has been made by ordinary mail by Joseph A. Goldbeck, Jr., Esquire (copies of proofs of mailing attached). The undersigned understands that the statements herein are subject to the penalties provided by 18 P.S. Section 4904. Respectfully ~ ~ --.. - =------.=_-- _ lIii!Hi ."llt !tWIll O'1lJ11 T01'lr\It)A HOOvl:R 329 15th street New Cumberland, PA 17070 j I I SENDER: a I ~! REFERENCE: Zj ;! II '1,'., i }"c I I I I i "" GOLDBECK MCCAFFERTY & McKEEVER - september 12, 2001 HOOVER,JAMES / FN.0232 12/5/01 . PS form 3800, June 2000 RETURN Postage ~EIPT Certified Fee . SERVICE Return Receipt Fee RestriCted Delive Total Postage & Fees US Postal Service Receipt for Certified Mail No Insurance Coverage Provided 00 Not Use for International Mail ~~ I' -,~". ~, _, '"" ~, ,,-- ,0.,' "''''''''''_''#<;' 7& ItS1S .'" Ul4 .. TO~AMES HOOIl]:" 329 15th street New Cumberland, PA 17070 SENDER: REFERENCE: :1 I ;,1 L US Postal Service Receipt for Certified Mail No Insurance Coverage Provided Do Not Use for, International Mail GOLDBECK McCAFFERTY & MCKEEVER. septeml:)er 12, 2001 HOOVER,JAMES / FN-0232 12/ 5/01 . -~....". " I IIIII1 :: D7D~ Yv'-.. , ' o Agent o Addressee DYes DNa - 3. Se'i'ice Type CERTIFIED MAil 4. Restricted Delivery? (Extra Fae) 1. Artlcle.Addressed to: DYes :'>Ii....,,? O. [s delivery address different from item 11 .fYES. enter delivery address belOW:: RE: HOOVER,JAMES I FN-Q232 12/ 5/01 .. ,SENDER: GOLDBECK MCCAFfERTY &. McKEEVER. september 'I PS Form 3811, June 2000 Domesl1c Return Receipt -........,. -<'"~- -..,....--c, 'LINDA HOOVER 32,9 15th street New cumberland, PA 17070 11 nllllll 71010 qS75 1C!'1~ qWqOIo'lll 3.' Service Type CERTIFIED "MAIL- 4. 'Restricted Delivery? (Extra Fee) 1. Article Addressed to: DYes C. Signature X,r-': '-^-ct",-- ~~ D. Is delivery address different from Jlem 11 JfYES. enter dellvery address below: o Agent o Addressee DVes ON' JAMES HOOVER 329 15th Street New Cumberland, PA 17070 RE:HOOVER,JAMES I FN-0232 12/5/01 .. SENDER: GOLDBECK MCCAFFERrf ~,-M:;KEEVER -September PS Form 3811, June 2000 Domestic Return Receipt -~,- - "- "~'''" l REAL. 1!lSlJl\<!.!Jl SlliLE N0. 53 Writ No. 2001-3220 CiVil First Nationwide Mortgage Corp. vs. , Jo,'m O. Osgood (Mortgagor Only) Susan C. Osgood (Mortgagor Only) James Hoover (Real OWner Only) Urjda Hoover (Real OWner Only) . Atty.: Joseph Goldbeck All TIIAT CERTAIN lot or tract of land sItuate in the Borough of New Cumberland, County of Cum- berland and State of Pennsylvania, more particularly bounded and de- scrtbed as follows according to a survey of D.P. Raffensperger (49.29) dated March 4, 1974, to wit: BEGINNING at a point on the Northern side of 15th Street said point being 870.8 feet west of , Bridg~, Stre~t; thence- extending along 15th street_~<i<!grees West 50 feet to a comer of lot num- ber 30 on the hereinafter mentioned plan of lots: thence along lot num- ber 30 north 28 degrees West 195 feet to a point a corner; thence North 62 degrees East 50 feet to a paint a corner; thence extending through lot number 31 on said plan South 28 degrees East 195 feet to the point and place of BEGINNING. Being a part of lot number 31 Section E plan of Hillside as re- corded In the Cumberland County Recorder's Office in Plan Book 1, page 75. '~{avlng thereon erected a two story frame dwell1ng and detached frame garage known as 329 15th Street. ' Tax Parcel #26-23-0541-133. <. -,' -,~,.._' - - ~~-;.;., ~'" '%d -"'i~~'~ "' c - L..~ _ --,.,,-, . PROOF OF PUBLICATION OF NOTICE IN CUMBERLAND LAW JOURNAL (Under Act No. 587, approved May 16, 1929), P. L.1784 STATEOFPENNSYLVANIA : ss. COUNTY OF CUMBERLAND : Roger M. Morgenthal, Esquire, Editor ofthe Cumberland Law Journal, of the County and State aforesaid, being duly sworn, according to law, deposes and says that the Cumberland Law Journal, a legal periodical published in the Borough of Carlisle in the County and State aforesaid, was established January 2, 1952, and designated by the local courts as the official legal periodical for the publication of all legal notices, and has, since January 2, 1952, been regnlarly issued weekly in the said County, and that the printed notice or publication attached hereto is exactly the same as was printed in the regnlar editions and issues of the said Cumberland Law Journal on the following dates, viz: October 12, 19,26,2001 Affiant further deposes that he is authorized to verify this statement by the Cumberland Law Journal, a legal periodical of general circulation, and that he is not interested in the subject matter of the aforesaid notice or advertisement, and that all allegations in the foregoing statements as to time, place and character of publication are true. R~ SWORN TO AND SUBSCRIBED before me this 26 day of OCTOBER. 2001 , NOTARIAl SEAL LOIS E. SNYDER, Notary Public CarlIsle Ilow, CUm!lel1and County My Commiaslon ExpiIllS March 5, 2005 ,'RE'AL!:S1l\TE'SALE No:53 Writ No. ~OOl-322D Cl'o'fJTenri . ''Fl,rst Natlonw~e Mo'rtgage 'CorP. " vs .' . . , ' ,," 'Joh~ O. Osgoocl (Mol1gagor Only) , , , , ,SusanC. Osgodd (Mdrtgagor'Only) James Hoover {Real Owner Only) Unda Hoover (Real Owner Only) ,Atty: Josoph Golclberg DESCRIPTION . ~ THAT'CERTAIN,.Iot oi' trng 6l' land sUu<lle ::in the Bonmgh .of 1'4':.\1'- Cumbe{land, County of . Cllmbeclalfd and Sli"t~ lJf Pclln~y!van1a, more .'particularly timmlied 'aud des<:obed as follows '-according ul" a 'sl1t\rey of D.~. Raffensperger (49- ..2-9rciated March 4, 1974,.towit~ . . .BEGlNNlNG ,'at 'a: ~oint on: th~ N"orthem s(dc of , 1 Sth, Sl:!eet said pOint beiri~ 870.13' feet west of .Btidge'Strect;.1hence exfendmg alon.g 15th Street . Sllufu 't")2 degrees Wcit_50 fee). to a romer of lot number 30 on ,the hci'clnafter mtntkmed plan of . 1m;' thenc~...alim:g 101. ;1I~mJjC1' 30 north .28 ifc&rce;; West 195 feet to a 'point'a' comet; thence Nart/162 -degrees &.~UO'feet to a point a colJler,'E!lcl!Cc , "extendil,lg, tliroltgh lot 'tit{tfl'ber J 1 ,on ~aId plan ".'S@th Ufrlegrees'East 195 ject to the pciiut and ."iliace 01 BEGINNING. " 'SEll'fG a -part of lot numberS{ s..,"dwn Epian of }lJThide ~ recrirded in the Curi:lbcrland ~GUnly "RciXJtd6:::-. Offjce In Pla~'Book 1, page is, ""HAVING thereon ~ted a rWo '*nt)" frame "Ilwelling and det'aclx1 frame g:t'rtIge' fmOwn aii 31'9 J5th'SireeL " ' " , ," __2~~Il!E~#2o.:?2:P~.!1~\. _~__ __" .,1 ~- ~..-~ ,,, , ~,;-: . .......... - . . THE PATRIOT NEWS THE SUNDAY PATRIOT NEWS Proof of Publication Under Act No. 587, Approved May 16, 1929 Commonwealth of Pennsylvania, County of Dauphin} ss James L. Clark being duly sworn according to law, deposes and says: That he is the Acounts Receivable Manager of The Patriot News Co., a corporation organized and existing under 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 Sundav Patriot-News newspapers of general circulation, printed and published at 812 to 818 Market Street, in the City, County and State aforesaid; that The Patriot-News and The Sunday Patriot-News were established March 4th, 1854, and September 18th, 1949, respectively, and all have been continuously published ever since; That the printed notice or publication which is securely attached hereto is exactly as printed and published in their regular daily and/or Sunday/ Metro editions which appeared on the 23rd and 30th day(s} of October and the 6th day(s) of November 2001. That neither he nor said Company is interested in the subject matter of said printed notice or advertising, and that all of the allegations of this statement as to the time, place and character of publication are true; and That he has personal knowledge of the facts aforesaid and is duly authorized and empowered to verify this statement on 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 CQUnty of Dauphin in Miscellaneous Book "M", V:~:L;::~::~~Lm COPY S' before e this 19th d of Nove ber 2001 A.D. S ALE #53 Notarial Sea' Terry L Ausse", Notary PUb Hamsburg, DauphIn County My Commission Expires Juna s, 2002 TARY PUBLIC M9mber, Pennsylvanls ASSOCIation 0' NotaMt6 commission expires June 6, 2002 CUMBERLAND COUN1Y SHERIFFS OFFICE CUMBERlAND COUN1Y COURTHOUSE CARLISLE, PA. 17013 I Statement of Advertising Costs To THE PATRIOT-NEWS CO., Dr. For publishing the notice or publication attached hereto on the above stated dates $ Probating same Notary Fee(s) $ Total $ 196.08 1.50 197.58 Publisher's Receipt for Advertising Cost The Patriot News Co., publisher of The Patriot-News and The Sundav Patriot-News, newspapers of general circulation, hereby acknowledge receipt of the aforesaid notice and publication costs and certifies that the same have been duly paid. By.................................................................... i , I" , i '" . ,/<. ~'"*' . ~ ~ " , , " First Nationwide Mortgage Corp. VS John O. Osgood (Mortgagor Only) Susan C. Osgood (Mortgagor Only) James Hoover (Rea! Owner Only) Linda Hoover (Rea! Owner Only) In The Court of Common Pleas of Cumberland County, Pennsylvania Writ No. 2001-3220 Civil Term , , ~-"~~ '8liiil~3U.d '"' R. Thomas Kline, Sheriff, who being duly sworn according to law, states this writ is returned STAYED pursuant to instructions from Attorney Joseph A. Goldbeck. Sheriffs Costs: Docketing Surcharge Posting Handbills Law Library Prothonotary Share of Bills Mileage Levy Advertising Certified Mail Poundage Postpone Sale Law Journal Patriot News 30.00 50.00 15.00 .50 . 1.00 25.66 22.10 15.00 15.00 5.64 12.30 237.50 197.58 $627.28 paid by attorney Sworn and subscribed to before me ;;JJZ~J<~~ This 1:Jt-dayof A.!u~L".) 200l,A.D. C)Y1'- (). ~,~, R. Thomas Kline, Sheriff BY~~~ R a! E ate Deputy Prothonotary \'''~LA~'1 '1'\1 ~. 119m "' <;--,"' "' --~- -~"", ~-; ~'-'-,"., .-.'" , ,". <-< First Nationwide Mortgage Corp. Plaintiff : CUMBERLAND COUNTY COURT OF COMMON PLEAS CIVIL DIVISION , \ Vs. 1 John o. Osgood (Mortgagor only) Susan C. Osgood (Mortgagor only) James Hoover (Real Owner only) Linda Hoover (Real Owner only) Defendants : NO. 01-3220-Civil AFFIDAVIT PURSUANT TO RUT,E 3129.1 First Nationwide Mortgage Co~., Plaintiff in the above action, by its attorney, Joseph Goldbeck, Jr., Esquire, sets forth as of the date the Praecipe for the Writ of Execution was filed the following information concerning the real property located at 329 15th Street. New Cllmherl",nd. PA 17070. 1. Name and address of owner(s) or reputed owner (s): Name Address (if address cannot be reasonably ascertained, please so indicate) James Hoover (Real Owner only) 329 15th Street New Cumberland. PA 17070 329 15th Street New Cumberland. PA 17070 Linda Hoover (Real Owner only) 2. Name and address of defendant(s) in the judgment: Name Address (if address cannot be reasonably ascertained, please so indicate) ,Tnhn O. Osgnod (Mortgagor only) 52 Catoctin Court Silver springs. MD 20906 Sl1san C. Osgood (Mortgagor only) 423 Market Street Ne~ort. PA 17074 3. Name and address of every judgment creditor whose judgment is a record lien on the real property to be sold: Name Address (if address cannot be reasonably' ascertained, please so indicate) Greenwood Trust Co. P.O. Box 11848 Harrisburg. PA 17108 B~lco Cnmm. Credit Union no! 403 N. 2 Street HarriRburg. PA 17101-1322 ~ ~ =_. '~, l" , ,~, ., .... 4. Name and address of the last recorded holder of every mortgage of record: . Name , Address (if address cannot be reasonably ascertained, please so indicate) 1 Fir~t Federal Savings & Loan 234 N. 200 Street Harrisburg. PA 17101 5. Name and address of every other person who has any record lien on the property: Name Address (if address cannot be reasonably ascertained, please so indicate) HQna 6. Name and address of every other person who has any record interest in the property and whose interest may be affected by the sale: Name Address (if address cannot be reasonably ascertained, please so indicate) Cnmherland County D~t. of DnmRstic Relations P.O. Box 320 Carlisle. PA 17013 Pa "apt_ of Public Welfare BurRau of Child S~ort Enforcement Health and Welfare Bldg. Room 432 P.O. Box 2675 Harrisburg. PA 17105 7. Name and address of every other person of whom the plaintiff has knowledge that has any interest in the property that may be affected by the sale: Name Address (if address cannot be reasonably ascertained, please so indicate) HQna I verify that the statements made in this affidavit are true and correct to the best of my personal knowledge or information and belief. I understand that false statements herein are made subject to the penalties of 18 Pa. C.S. #4904 relating to unsworn falsification to authorities. September 12, 2001 ldbeck, Jr. r plaintiff ,. ", ~,~ ~tJ .'l!~J!!O.MJ.!!itl<_",,_"~= "O~, ~.= -- ,J I. '-.1 - ,-'- """ ,NO: ~".~t' < , "":i..j .. 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 (?l~) 6?7-B22 ATTORNEY FOR PLAINTIFF I First Nationwide Mortgage Corp. Plaintiff CUMBERLAND COUNTY COURT OF COMMON PLEAS CIVIL DIVISION Vs. John O. Osgood (Mortgagor only) Susan C. Osgood (Mortgagor only) James Hoover (Real Owner only) Linda Hoover (Real Owner only) Defendants NO.0~-3220-civil NOTIr.F: OF' SHF:RIF'F" S SAT,F, OF' RF:AT, ESTATF. TO: James Hoover (Real Owner only) 329 15th Street New Cumberland, PA 17070 THIS FIRM IS A DEBT COLLECTOR ATTEMPTING TO COLLECT A DEBT AND ANY INFORMATION OBTAINED WILL BE USED FOR THAT PURPOSE. IF YOU HAVE PREVIOUSLY RECEIVED A DISCHARGE IN BANKRUPTCY, THIS IS NOT AND SHOULD NOT BE CONSTRUED TO BE AN ATTEMPT TO COLLECT A DEBT, BUT ONLY ENFORCEMENT OF A LIEN AGAINST PROPERTY. Your house (real estate) at 329 ~5th Street. New Cumberland. FA 17070. is scheduled to be sold at the Sheriff's Sale on December 5. 2001 at 10:00 a.m., in Cumberland County, Cumberland County Courthouse, Commissioners Hearing Room, 2nd Floor, Carlisle, PA 17013 to enforce the court judgment of $10.665.31 obtained by First Nationwide Mortgage Corp_ (the mortgagee) against you. NOTICE OF OWNF.R'S RIGHTS YOU MAY BE ABLE TO PREVENT THIS SHERIFF'S SALE To prevent this Sheriff's Sale, you must take immediate action: 1. The sale will be cancelled if you pay to the mortgagee the Back payments. late charges, costs and reasonable attorneys Fees due. To find out how much you must pay, you may call: (2151 627 -1322 2. You may be able to stop the sale by filing a petition asking the Court to strike or open the judgment, if the judgment was improperly entered. You may also ask the Court to postpone the sale for good cause. 3. You may also be able to stop the sale through other legal proceedings. ~ ~-"='~ ,- ",~ ~ -~~--~ . ~ ~ ~..., ~~ L___~" ~ " ~, "-> '. j' c' .1~ 'w .~'/ , " You may need an attorney to assert your rights. The sooner you contact one, the more chance you will have of stopping the sale. (See notice on page t~o on .how to obtain an attorney.) YOU MAY STILL BE ABLE TO SAVE YOUR PROPERTY AND YOU HAVE OTHER RIGHTS EVEN IF THE SHERIFF'S SALE DOES TAKE PLACE. " 1. If the Sheriff's Sale sold to the highest bidder. calling (215\ 627-1~??. is not stopped, your property will be You may find out the price bid by 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's office at (717) 240-6~90 4. If the amount due from the Buyer is not paid to the Sheriff, you will remain the owner of the property as if the sale never happened. 5. You have the right to remain in the property until the full amount due is paid to the Sheriff and the Sheriff gives a deed to the buyer. At this time, the buyer may bring legal proceedings to evict you. 6. You may be entitled to a share of the money which was paid for your house. A proposed schedule of distribution of the money bid for your house will be prepared by the Sheriff within 30 days of the Sale. This schedule will state who will be receiving that money. The money will be paid out in accordance with this schedule unless exceptions (reasons why the proposed distribution is wrong) are filed with the Sheriff within ten (10) days after the posting of the Schedule of Distribution. 7. You may also have other rights and defenses, or ways of getting your home back, if you act immediately after the sale. YOU SHOULD TAKE THIS PAPER TO YOUR LAWYER AT ONCE. IF YOU DO NOT HAVE A LAWYER OR CANNOT AFFORD ONE, GO TO OR TELEPHONE THE OFFICE LISTED BELOW TO FIND OUT WHERE YOU CAN GET LEGAL HELP. Cumberland County Bar Association 2 Liberty Avenue Carlisle, PA 17103 (800) 990-9108 Legal Services, Inc. 8 Irvine Row Carlisle, PA 17103 (717) 243-9400 '1t'-r~'- ...:- .<i ~""'. '-.:.. - _ lLl.f,",~.. "= v , 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) fi?7-132? ATTORNEY FOR PLAINTIFF .. First Nationwide Mortgage Corp. CUMBERLAND COUNTY COURT OF COMMON PLEAS CIVIL DIVISION Plaintiff Vs. John O. Osgood (Mortgagor only) Susan C. Osgood (Mortgagor only) James Hoover (Real Owner only) - Linda Hoover (Real Owner only) Defendants NO.01-3220-Civil NOTTr.E OF SHF.RTFF' S SAT,F. OF REAr, F.STA'T'F. TO: Linda Hoover (Real Owner only) 329 15th Street New Cumberland, PA 17070 THIS FIRM IS A DEBT COLLECTOR ATTEMPTING TO COLLECT A DEBT AND ANY INFORMATION OBTAINED WILL BE USED FOR THAT PURPOSE. IF YOU HAVE PREVIOUSLY RECEIVED A DISCHARGE IN BANKRUPTCY, THIS IS NOT AND SHOULD NOT BE CONSTRUED TO BE AN ATTEMPT TO COLLECT A DEBT, BUT ONLY ENFORCEMENT OF A LIEN AGAINST PROPERTY. Your house (real estate) at 329 15th Street. New Cumberland. PA 17070. is scheduled to be sold at the Sheriff's Sale on December 5. 2001 at 10:00 a.m., in Cumberland County, Cumberland County Courthouse, Commissioners Hearing Room, 2nd Floor, Carlisle, PA 17013 to enforce the court judgment of $10.665.31 obtained by First Nationwide Mortgage Corp. (the mortgagee) against you. NOTICE OF OWNER'S RIGHTS YOU MAY BE ABLE TO PREVENT THIS SHERIFF'S SALE To prevent this Sheriff's Sale, you must take immediate action: 1. The sale will be cancelled if you pay to the mortgagee the Back payments, late charges, costs and reasonable attorneys Fees due. To find out how much you must pay, you may call: (215) 627-1322 2. You may be able to stop the sale by filing a petition asking the Court to strike or open the judgment, if the judgment was improperly entered. You may also ask the Court to postpone the sale for good cause. 3. You may also be able to stop the sale through other legal proceedings. "~_. ~. " "'u~. ,,'-"~ ,.'~'~~~~~ ." ~, ~- '[ '"""" ~. Ill"" '. " ,~.I -... "; ~"" , ll!l.. ,., j.-' . You may need an attorney to assert your rights. The sooner you contact one, the more cha~ce ~ou will have of stopping the sale. (See notice on page two on how to obtain an attorney.) YOU MAY STILL BE ABLE TO SAVE Yotm PROPERTY AND YOU HAVE OTHER RIGHTS EVEN IF THE SHERIFF'S SALE bo~s TAKE PLACE. . 1. If the Sheriff's Sale sold to the highest bidder. calling (21~) 6?7-13??. is not st;.opped, your property will be You may find out the price bid by 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's office at (7]7) 240-6~90 4. If the amount due from the Buyer is not paid to the Sheriff, you will remain the owner of the property as if the sale never happened. 5. You have the right to remain in the property until the full amount due is paid to the Sheriff and the Sheriff gives a deed to the buyer. At this time, the buyer may bring legal proceedings to evict you. 6. You may be entitled to a share of the money which was paid for your house. A proposed schedule of distribution of the money bid for your house will be .prepared by the Sheriff within 30 days of the Sale. This schedule will state who will be receiving that money. The money will be paid out in accordance with this scheduleunles,s exceptions (reasons why the proposed distribution is wrong) are filed with the Sheriff within ten (10) days after the posting of the Schedule of Distribution. 7. You may also have other rights and defenses, or ways of getting your home back, if you act immediately after the sale. YOU SHOULD TAKE THIS PAPER TO YOUR LAWYER AT ONCE. IF YOU DO NOT HAVE A LAWYER OR CANNOT AFFORD ONE, GO TO OR TELEPHONE THE OFFICE LISTED BELOW TO FIND OUT WHERE YOU CAN GET LEGAL HELP. Cumberland County Bar Association 2 Liberty Avenue Carlisle, PA 17103 (800) 990-9108 Legal Services, Inc. 8 Irvine Row Carlisle, PA 17103 (717) 243-9400 ~- ,. ,,-~ " .J ~ . ',-, \" . "",,-.., f "., GOLDBECK McCAFFERTY & McKEEVER By: Joseph A. Goldbeck, Jr. Attorney I.D. #16132 f Suite 500 - The Bourse Bldg. 111 S. Independence Mall East Philadelphia, PA 19106 (215) 6/.7-11/.2 ATTORNEY FOR PLAINTIFF First Nationwide Mortgage Corp. CUMBERLAND COUNTY COURT OF COMMON PLEAS CIVIL DIVISION Plaintiff Vs. John o. Osgood (Mortgagor only) Susan C. Osgood (Mortgagor only) James Hoover (Real Owner only) Linda Hoover (Real Owner only) Defendants NO.01-3220-Civi1 NOTTeF. OF' SHF.RTF'F" S SAT,F. OF' RF.AT, F.STATE TO: Susan C. Osgood (Mortgagor only) 52 Catoctin Court Silver Springs, MD 20906 THIS FIRM IS A DEBT COLLECTOR ATTEMPTING TO COLLECT A DEBT AND ANY INFORMATION OBTAINED WILL BE USED FOR THAT PURPOSE. IF YOU HAVE PREVIOUSLY RECEIVED A DISCHARGE IN BANKRUPTCY, THIS IS NOT AND SHOULD NOT BE CONSTRUED TO BE AN ATTEMPT TO COLLECT A DEBT, BUT ONLY ENFORCEMENT OF A LIEN AGAINST PROPERTY. Your house (real estate) at 329 15th Street. New ~nnberland. PA 17070. is scheduled to be sold at the Sheriff's Sale on December 5. 2001 at 10:00 a.m., in Cumberland County, Cumberland County Courthouse, Commissioners Hearing Room, 2M Floor, Carlisle, PA 17013 to enforce the court judgment of S10.665_31 obtained by First Nationwide Mortgage Co~. (the mortgagee) against you. NOTICE OF OWNER'S RIGHTS YOU MAY BE ABLE TO PREVENT THIS SHERIFF'S SALE To prevent this Sheriff's Sale, you must take immediate action: 1. The sale will be cancelled if you pay to the mortgagee the Back payments, late charges, costs and reasonable attorneys Fees due. To find out how much you must pay, you may call: (215) 627-1322 2. You may be able to stop the sale by filing a petition asking the Court to strike or open the judgment, if the judgment was improperly entered. You may also ask the Court to postpone the sale for good cause. 3. You may also be able to stop the sale through other legal proceedings. '-;-'", "'"" (, r"'''-~~ ~~ I' _ 'j "Co "- -~- ". I , You may need an attorney to assert your rights. The sooner you contact one, the more chance you will have of stopping the sale. (See notice on page two on 'how to obtain an attorney.) YOU MAY STILL BE ABLE TO SAVE YOUR PROPERTY AND YOU HAVE OTHER RIGHTS EVEN IF THE SHERIFF'S SALE DOES TAKE PLACE. 1. If the Sheriff's Sale sold to the highest bidder. calling (215) n?7-1322. is not stopped, your property will be You may find out the price bid by 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's office at (717) ?40-n190 4, If the amount due from the Buyer is not paid to the Sheriff, you will remain the owner of the property as if the sale never happened. 5. You have the right to remain in the property until the full amount due is paid to the Sheriff and the Sheriff gives a deed to the buyer. At this time, the buyer may bring legal proceedings to evict you. 6. You may be entitled to a share of the money which was paid for your house. A proposed schedule of distribution of the money bid for your house will be prepared by the Sheriff within 30 days of the Sale. This schedule will state who will be receiving that money. The money will be paid out in accordance with this schedule unless exceptions (reasons why the proposed distribution is wrong) are filed with the Sheriff within ten (10) days after the posting of the Schedule of Distribution. 7. You may also have other rights and defenses, or ways of getting your home back, if you act immediately after the sale. YOU SHOULD TAKE THIS PAPER TO YOUR LAWYER AT ONCE. IF YOU DO NOT HAVE A LAWYER OR CANNOT AFFORD ONE, GO TO OR TELEPHONE THE OFFICE LISTED BELOW TO FIND OUT WHERE YOU CAN GET LEGAL HELP. Cumberland County Bar Association 2 Liberty Avenue Carlisle, PA 17103 (800) 990-9108 Legal Services, Inc. 8 Irvine Row Carlisle, PA 17103 (717) 243-9400 ~!','lilllk~" -~'. -~. ~~-. ~,' -'1-< " ,.... ,-" ~-:: . '-d";' ""~~~;: "\ '<.-, GOLDBECK McCAFFERTY & McKEEVER ~, By: Joseph A. Goldbeck, Jr. , Attorney I.D. #16132 Suite 500 - The Bourse Bldg. i III S. Independence Mall East Philadelphia, PA 19106 (21 S) h27-11?2 ATTORNEY FOR PLAINTIFF First Nationwide Mortgage Corp. Plaintiff CUMBERLAND COUNTY COURT OF COMMON PLEAS CIVIL DIVISION Vs. John O. Osgood (Mortgagor only) Susan C. Osgood (Mortgagor only) James Hoover (Real Owner only) Linda Hoover (Real Owner only) Defendants NO.01-3220-Civi1 NOTT~F. OF SHERIFF'S SA1.F. OF REAl. F.S1'A1'F. TO: John O. Osgood (Mortgagor only) 52 Catoctin Court Silver Springs, MD 20906 THIS FIRM IS A DEBT COLLECTOR ATTEMPTING TO COLLECT A DEBT ,AND ANY INFORMATION OBTAINED WILL BE USED FOR THAT PURPOSE. IF YOU HAVE PREVIOUSLY RECEIVED A DISCHARGE IN BANKRUPTCY, THIS IS NOT AND SHOULD NOT BE CONSTRUED TO BE AN ATTEMPT TO COLLECT A DEBT, BUT ONLY ENFORCEMENT OF A LIEN AGAINST PROPERTY. Your house (real estate) at 329 15th Street. New CUmberland. PA 17070. is scheduled to be sold at the Sheriff's Sale on December 5. 2001 at 10:00 a.m., in Cumberland County, Cumberland County Courthouse, Commissioners Hearing Room, 200 Floor, Carlisle, PA 17013 to enforce the court judgment of S10.665.31 obtained by First Nationwide Mortgage Co~. (the mortgagee) against you. NOTICE OF OWNER'S RIGHTS YOU MAY BE ABLE TO PREVENT THIS SHERIFF'S SALE To prevent this Sheriff's Sale, you must take immediate action: 1. The sale will be cancelled if you pay to the mortgagee the Back payments, late charges, costs and reasonable attorneys Fees due. To find out how much you must pay, you may call: (215) 627-1322 2. You may be able to stop the sale by filing a petition asking the Court to strike or open the judgment, if the judgment was improperly entered. You may also ask the Court to postpone the sale for good cause. 3. You may also be able to stop the sale through other legal proceedings. "-~~ ~"" WII",.,j' . lit ,. - "'- i L. I . _.J. .,- ~'~~",. '" ""{'>. ,,' You may need an attorney to assert your rights. The sooner e' y?u contact one, the more chance you will have of stopping the sale. (See notice on page two. on ~ow to obtain an attorney.) . I YOU MAY STILL BE ABLE TO SAVR YOUR PROPERTY AND YOU HAVE OTHER RIa~TS EVEN IF THE SHERIFF'S SALE DOES TAKE PLACE. 1. If the Sheriff's Sale sold to the highest bidder. calling (7.1S) 67.7-117.7. is not stopped, your property will be You may find out the price bid by 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's office at (717) 7.40-61QO 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. S. You have the right to remain in the property until the full amount due is paid to the Sheriff and the Sheriff gives a deed to the buyer. At this time, the buyer may bring legal proceedings to evict you. 6. You may be entitled to a share of the money which was paid for your house. A proposed schedule of distribution of the money bid for your house ,will be prepared by the Sheriff within 30 days of the Sale. This schedule will state who will be receiving that money. The money will be paid out in accordance with this schedule unless exceptions (reasons why the proposed distribution is wrong) are filed with the Sheriff within ten (10) days after the posting of the Schedule of Distribution. 7. You may also have other rights and defenses, or ways of getting your home back, if you act immediately after the sale. YOU SHOULD TAKE THIS PAPER TO YOUR LAWYER AT ONCE;. IF YOU DO NOT HAVE A LAWYER OR CANNOT AFFORD ONE, GO TO OR TELEPHONE THE OFFICE LISTED BELOW TO FIND OUT WHERE YOU CAN GET LEGAL HELP. Cumberland County Bar Association 2 Liberty Avenue Carlisle, PA 17103 (800) 990-9108 Legal Services, Inc. 8 Irvine Row Carlisle, PA 17103 (717) 243-9400 'iI':"''' " - 'd ,',or',; r' _",'c.;;,,~, ',,1:',-'-"' ">\'~"- '~" , '%~, ";"~~'- ' , 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 First Nationwide Mortgage Corp. P.O. Box 9481, Mail Code: 22-528-1011 Gaithersburg, Me 20898-9481 Vs. John o. Osgood (Mortgagor only) Susan C. Osgood (Mortgagor only) 52 Catoctin Court Silver Springs, Me 20906 CUMBERLAND COUNTY : COURT OF COMMON PLEAS CIVIL DIVISION NO Ol-3220-Civil James Hoover (Real Owner only) Linda Hoover (Real Owner only) 329 15th Street New Cumberland, PA 17070 ALL THAT CERTAIN lot or tract of land situate in the Borough of New Cumberland, County of Cumberland and State of Pennsylvania, more particularly bounded and described as follows according to a survey of D.P. Raffensperger (49-29) dated March 4, 1974, to wit: BEGINNING at a point on the Northern side of 15th Street said point being 870.8 feet west of Bridge Street; thence extending along 15th Street South 62 degrees West 50 feet to a corner of lot number 30 on the hereinafter mentioned plan of lots; thence along lot number 30 north 28 degrees West 195 feet to a point a corner; thence North 62 degrees East 50 feet to a point a corner; thence extending through lot number 31 on said plan South 28 degrees East 195 feet to the point and place of BEGINNING. Being a part of lot number 31 Section E plan of Hillside as recorded in the Cumberland County Recorder's Office in Plan Book I, page 75. Having thereon erected a two story frame dwelling and detached frame garage known as 329 15th Street. Tax Parcel #26-23-0541-133 ~.."..^- ~" "~ " ~.....;.~~.~"'" "'. 'cj ""''''" ~~':' ""';.;:" WRIT OF EXECUTION anC!/orATTACHMENT " .. 4 COMMONWEALTH OF PENNSYLVANIA) COUNTY OF CUMBERLAND) NO. 01-3220 CIVIL 1~ TERM CIVIL ACTION -LAW TO THE SHERIFF OF Cumberland COUNTY: To satisfy the debt, interest and costs due First Nationwide Mortqaqe Corp. PLAINTlFF(S) John O. Osgood (Mortgagor only) 52 Catoctin Court, Silver Springs, MD 20906, Susan C. Osgood (Mortgagor only), 423 Market Street, Newport, PA 17074, James Hoover and Linda Hoover (Real Owners only) 329 15th St., New Cumberland, PA 17070 DEFENDANT(S) from (1) You are directed to levy upon the property of the defendant(s) and to sell See Legal Description (2) You are also directed to attach the property of the. defendant(s) not levied upon in the possession of GARNISHEE(S) as follows: and to not~y the garnishee(s) that: (a) an attachment has been issued; (b) the garnishee(s) is/are enjoined from paying any debt to or for the account of the defendant(s) and from delivering any property of the defendant(s) or otherwise disposing thereof; (3) If property 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. L.L. Due Prothy Other Costs $.50 Amount Due $10,665.31 fram Y/ll/Ul to sale date at Interest'" $1 7') pAr niPl11 Arty's Comm "10 Arty Paid $252.94 Plaintiff Paid 51.00 Date: September 18, 2001 Curtis R. Long Prothonotary, Civil Division ___by: ~4? L. 2. ~en.-?-('W.. r Deputy REQUESTING PARTY: Joseph A. Goldbeck, Jr. Suite 500 - The Bourse Bldg. 111 G. IndepeOOcficc Hall EaGt Philadelphia, PA 19106 Name Address: Attorney for: Plaintiff Telephone: 215-627-1322 Supreme Court 10 No. 16132 1,,;-:t.;l!:,jjiM~&(;f.,b<ili-itDifIj,'i-!HI!W;~\i/ri'~"''''fj;;;'''_'f'';'il'_~j,''lh__"",,,,-j":,,~~' "":,,,,,,,~'-O~"',':.Hj,,~2\\I~tjjJLill" - ~''"''''''''D_~1ll1nj :~1~\ll'-~i>'ll!0'fJ;iilil~00llr..llii' c. REAl ESTATE SALE No. 53 On September 19, 2001, the sheriff levied upon the defendant's interest in the real property situated in Borough of New Cumberland, Cumberland County, PA, known and numbered as 329 15th St., New Cumberland, and more fully described on Exhibit "A" filed with this writ and by this reference incorporated herein. Date: September 19,2001 By: CJ~ ~ Real Estate Deputy ,H.~ ~\ ',.. <L-~...~,"_~ "' ,,_. , ,e,,<, ,~_ _ .,,'_^, ,___~>_~_'., .'. .~" "'.._ '-"'~ ~- "~~, ..L -mi' l'- } CVil CVil c:::::;, G=e) &vii ~ !!l , ~" , ,J. .<l.~111 ~~ -\ " .. , '~"'-'-,.h--~,_--,_ -- '-\liliA".Y~~. .-' , ,i t 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 17.1<;) 627-1322 ATTORNEY FOR PLAINTIFF First Nationwide Mortgage Corp. Plaintiff CUMBERLAND COUNTY : COURT OF COMMON PLEAS CIVIL DIVISION Vs. John O. Osgood (Mortgagor only) Susan C. Osgood (Mortgagor only) James Hoover (Real OWner only) Linda Hoover (Real OWner only) Defendants NO.01-3220-Civil NOTICE OF SHERIFF' ~ ~AT,E OF REAL E~TATE TO: John O. Osgood (Mortgagor only) 52 Catoctin Court Silver Springs, MD 20906 THIS FIRM IS A DEBT COLLECTOR ATTEMPTING TO COLLECT A DEBT AND ANY INFORMATION OBTAINED WILL BE USED FOR THAT PURPOSE. IF YOU HAVE PREVIOUSLY RECEIVED A DISCHARGE IN BANKRUPTCY, THIS IS NOT AND SHOULD NOT BE CONSTRUED TO BE AN ATTEMPT TO COLLECT A DEBT, BUT ONLY ENFORCEMENT OF A LIEN AGAINST PROPERTY. Your house (real estate) at 329 15th Street. New Cumberland. p~ 17070. is sCheduled to be sold at the Sheriff's Sale on December 5. 2001 at 10:00 a.m., in Cumberland County, Cumberland County Courthouse, Commissioners Hearing Room, 2M Floor, Carlisle, PA 17013 to enforce the court judgment of S10.665.31 obtained by First Nationwide Mortgage Co~. (the mortgagee) against you. NOTICE OF OWNER'S RIGHTS YOU MAY BE ABLE TO PREVENT THIS SHERIFF'S S~LE To prevent this Sheriff's Sale, you must take immediate action: 1. The sale will be cancelled if you pay to the mortgagee the Back payments, late charges, costs and reasonable attorneys Fees due. To find out how much you must pay, you may call: (215) 627~1322 2. You may be able to stop the sale by filing a petition asking the Court to strike or open the judgment, if the judgment was improperly entered. You may also ask the Court to postpone the sale for good cause. 3. You may also be able to stop the sale through other legal proceedings. .~~",k -'~r ..,.of f' ~ - ,,' , , . ~- J'lw.' You may need an attorney to assert your rights. The sooner you contact one, the more chance you will have of stopping the sale. (See notice on page two on how to obtain an attorney.) YOU MAY STILL BE ABLE TO SAVE YOUR PROPERTY AND YOU HAVE OTHER RIGHTS EVEN IF THE SHERIFF'S SA~E DOES TAKE PLACE. 1. If the Sheriff's Sale sold to the highest bidder. calling (/.15) 627-1322. is not stopped, your property will be You may find out the price bid by 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's office at (7]7) /.40-6390 4. If the amount due from the Buyer is not paid to the Sheriff, you will remain the owner of the property as if the sale never happened. 5. You have the right to remain in the property until the full amount due is paid to the Sheriff and the Sheriff gives a deed to the buyer. At this time, the buyer may bring legal proceedings to evict you. 6. You may be entitled to a share of the money which was paid for your house. A proposed schedule of distribution of the money bid for your house will be prepared by the Sheriff within 30 days of the Sale. This schedule will state who will be receiving that money. The money will be paid out in accordance with this schedule unless exceptions (reasons why the proposed distribution is wrong) are filed with the Sheriff within ten (10) days after the posting of the Schedule of Distribution. 7. You may also have other rights and defenses, or ways of getting your home back, if you act immediately after the sale. YOU SHOULD TAKE THIS PAPER TO YOUR LAWYER AT ONCE. IF YOU DO NOT HAVE A LAWYER OR CANNOT AFFORD ONE, GO TO OR TELEPHONE THE OFFICE LISTED BELOW TO FIND OUT WHERE YOU CAN GET LEGAL HELP. Cumberland County Bar Association 2 Liberty Avenue Carlisle, PA 17103 (800) 990-9108 Legal Services, Inc. 8 Irvine Row Carlisle, PA 17103 (717) 243-9400 _bJ~~~~i~""i;,js,,',J"'iihl1f;;jif'i~.i!!~~.i;:;!I~:tl.li:Kl[&:f'<fl,:!lli,j"I?'"'";;;'L,,"'"f{"!:l&,"tlli'L~,~,,~,,;jili~' ~", .~ll!!i&,'1f ~.~. "-"-,^, ~ ^'~ l~-" I. 'rL'trJ!IlMIill!Ir J]~rr!fm "' ~,~ ~'-'~-'-~"~ ,-._~ - =~ ~." ,~.~. - Ill! ;t1 0 0 c: s: V) vCD 01 trIG"' -U Z.~, ZC OJ ~~_:' !;::C! ""1;) -- .J.-":>...--, .) Z"-...:::; ,....C' )>.C Y? '-.--' "7 ~ ~. ~ "<-.,; =< :S;) CO -< j.. "I .) ,Ifuo!~t\ Ii t ~Jl... -<. , . ' , -1, ~,L . '" ." "-",~';";-j~ ' ''', . , """'-'W,',_ PRAECIPE FOR WRIT OF EXECUTION - (MORTGAGE FORECLOSURE) P.R.C.P. 3180-3183 First Nationwide Mortgage Corp. Plaintiff COURT OF COMMON PLEAS CUMBERLAND COUNTY, PA Vs. NO: 01-3220-Civi1 John O. Osgood (Mortgagor only) Susan C. Osgood (Mortgagor only) James Hoover (Real Owner only) Linda Hoover (Real Owner only) Defendants PRAECIPE FOR WRIT OF EXECUTION (MORTGAGE FORECLOSURE) TO THE OFFICE OF THE PROTHONOTARY: Issue writ of execution in the above matter: Amount Due Interest from 9/12/01 to sale date at $1.75 per diem Total $10,665.31 $ $ and Costs eck, Jr. Sui 500- Bourse Bldg. 111 S. Independence Mall East Philadelphia, PA 19106 Attorney for Plaintiff Note: Please attach description of property. ;,.,-' ",." ,,~ - ~..";";k:til.if~;"-.~" I , .' n' ~""~-"'~U''''''''''''''''''-"'''"''~-'''-''fiJ'''''''ici-:'~ '."0:,;;1,,,, "'-i"~it,,,,,,-,,,,,u,~~'-'<iril! ~*JfiI%-'M~;\$.Wj),k")""""""=o"""""''''~",,,,; '''~~.", - -_ ~ ~<~~ -";""'11tlJ ~ ,~ u \0 0 0\ 0 N .0: . ~ i2l !2 1>0 ~ ~-- 0 H fr .-l.-l >- >- 0 .j,l .j,lq< "d ~ I'll'l.-l.-l H H (1)1'- <JJ <Il 0 o 0 I'l I'l 8 ::l . 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I , 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 First Nationwide Mortgage Corp. P.O. Box 9481, Mail Code: 22-528-1011 Gaithersburg, Me 20898-9481 Vs. John O. Osgood (Mortgagor only) Susan C. Osgood (Mortgagor only) 52 Catoctin Court Silver Springs, Me 20906 CUMBERLAND COUNTY COURT OF COMMON PLEAS CIVIL DIVISION NO 01-3220-Civi1 James Hoover (Real Owner only) Linda Hoover (Real Owner only) 329 15th Street New CUmberland, PA 17070.' ALL THAT CERTAIN lot or tract of land situate in the Borough of New Cumberland, County of Cumberland and State of Pennsylvania, more particularly bounded and described as follows according to a survey of D.P. Raffensperger (49C29) dated March 4, 1974, to wit: BEGINNING at a point on the Northern side of 15th Street said point being 870.8 feet west of Bridge Street; thence extending along 15th Street South 62 degrees West 50 feet to a corner of lot number 30 on the hereinafter mentioned plan of lots; thence along lot number 30 north 28 degrees West 195 feet to a point a corner; thence North 62 degrees East 50 feet to a point a corner; thence extending through lot number 31 on said plan South 28 degrees East 195 feet to the point and place of BEGINNING. Being a part of lot number 31 Section E plan of Hillside as recorded in the Cumberland County Recorder's Office in Plan Book 1, page 75. Having thereon erected a two story frame dwelling and detached frame garage known as 329 15th Street. Tax Parcel #26-23-0541-133 ~~~&ili"-4i.i!m~~gt;~~~"'4MJ2""tll!t""",II>.~I;fu-ill>_~~,";!>l~.'l>~,,~1Ii:! . . . \ , , ~ (J ~ ~ t ~ "- --.) ..... ~ (") 0 :fq~ err ~ ..... "-Ct.J ~il ..0 ~ f' ~ r- 6"- b..() c ~ . , 'I ~ tI) . . d () () -orr.1 :Tl -r ~ ~ 8 ...0 ~ llJ 0 0 D ..:> 0 o;!Lp -U .- ....... C C C ",-,-.' ....... -C ..( C C 0 6YS~ ' ',,'--, ~~ C 0 co - I I -<~~. -> ,-..' j ( yO -~ _:--1"', l' [} \ ~r--. ':'.-1"1 ~-) ;;:~ ( ~f! :z>~ ~5~r1 ,-0 LJ ~~ J>'r ~ .. ... .. .. ... , ~ ... .. Z; l"" 13 .. .. ... .. ... ~ ... :::z ... co -< .. ::; ... - ~~ " .. " ..... ... ..... ..... .... ~ - YJI.. _.'; UJJLU';'.[;,.[..UIJtRl RcrUJ!!!lI~"~~,_ "'"~_ ,___",_~. __~_~ ._, ~~a ~"~""".,~_,_ 0,' ,_ ~ ,." --~.J"" ';, - -I. ."". ... ~ 'r (Rule of Civil Procedure No. 236) - Revised IN THE COURT OF COMMON PLEAS OF CUMBERLAND COUNTY, PENNSYLVANIA CIVIL ACTION - LAW First Nationwide Mortgage Corp. , Plaintiff Vs. NO. 01-3220-Civil John o. Osgood (Mortgagor only) Susan C. Osgood (Mortgagor only) James Hoover (Real Owner only) Linda Hoover (Real Owner only) , Defendants Notice is given that a Judgment in the above captioned matter has been entered against you on September ~, 2001. ~: 40~()P.~'It.~TY If you have any questions concerning this matter please contact: eck, Jr. Plaintiff **THIS FIRM IS A DEBT COLLECTOR ATTEMPTING TO COLLECT A DEBT AND ANY INFORMATION OBTAINED WILL BE USED FOR THAT PURPOSE. IF YOU HAVE PREVIOUSLY RECEIVED A DISCHARGE IN BANKRUPTCY, THIS IS NOT AND SHOULD NOT BE CONSTRUED TO BE AN ATTEMPT TO COLLECT A DEBT, BUT ONLY ENFORCEMENT OF A LIEN AGAINST PROPERTY. ** . ~'" .........~ ;- -j > k -,~,,_ . "'~ ,:.o.,~~,~,,,,--,,~,,,',~_i'_, ,_" 0 -, _ . '," GOLDBECK, MCCAFFERTY & MCKEEVER By: Joseph A. Goldbeck, Jr. Attorney I.D. #16132 Suite 500-The Bourse Bldg. 111 S. Independence Mall East Philadelphia, PA 19106 (::>1 'i) 627-11::>::> ATTORNEY FOR PLAINTIFF COURT OF COMMON PLEAS CIVIL DIVISION First Nationwide Mortgage Corp. Vs. No. 01-3220-civil John O. Osgood (Mortgagor only) Susan C. Osgood (Mortgagor only) CUMBERLAND COUNTY VERIFICATION OF NON-MILITARY SERVICE JOSEPH A. GOLDBECK, JR., ESQUIRE, hereby verifies that he is attorney for the Plaintiff in the above-captioned matter, and that on information and belief, he has knowledge of the following facts, to wit: (a) that the defendants are not in the Military or Naval Service of the United States or its Allies, or otherwise within the provisions of the Soldiers' and Sailors' Civil Relief Act of Congress of 1940, as amended. (b) that defendant John o. Osgood (Mortgagor only), is over 18 years of age, and resides at 52 Catoctin Court, Silver Springs, MD 20906. (c) that defendant Susan C. Osgood (Mortgagor only), is over 18 years of age, and resides at 423 Market Street, Newport, PA 17074. (d) that defendant James Hoover (Real Owner only), is over 18 years of age, and resides at 329 15th Street, New Cumberland, PA 17070. (e) that defendant Linda Hoover (Real Owner only), is over 18 years of age, and resides at 329 15th Street, New Cumberland, PA 17070. This statement is made subject to the penalties of 18 Pa. C.S. Section 4904 relating to unsworn falsification to authorities. September 12, 2001 .~~~I1i<<7(?;;l;B]li!tff.'Ii\\fu1<-ili'ti~iJ!iJ!;!~1iIlli'l1I~~~jl"'''''MJI',itk'i!>Oi''i;L,'*1:!il!:t.<f!1lV~jf!i_~llIiL"": ~ -';;idll ,j.,,'.~ '... .~_t'" \ <;e}t"J\;tg.ffHl",.., """.rceN'-""""~~' .~~_"',_, ,< ",' ,. ,~. ",.,<, v", ~.Q __'C<-"'" .. "'~- ==-=-,,~ "llUlllill!lM'~~~ () c: ;0;: -0 'CD mfT~ z::c) ZC CP ..>~ .:< ;:: [20 1>C-' Z-" -0 )>-c: Z. =< ~~", o :n ;'1"\ -0 , ~ ., "lj?, C--:, "r';: 00 ,.::c,;. , \cl~l "--',C7 ..." -.:.Go ,,-', ' ~:f~~~ '[jFA -'-l -Co- <Or-'< ~, -< t;-;? ,,- ('1) E~ I '~ii:J~' l ~.,j . " , ~, ~- . - , ,I ,;.,_. ^Jill-Sd!b,', . ' Nationwide Mortgage Corp. CUMBERLAND COUNTY COURT OF COMMON PLEAS CIVIL DIVISION Plaintiff Vs. John O. Osgood (Mortgagor only) Susan C. Osgood (Mortgagor only) James Hoover (Real Owner only) Linda Hoover (Real Owner only) Defendants NO. 01-3220-Civil AFFIDAVIT PURSUANT TO RULE 3129.1 First Nationwide Mortgage Co~., Plaintiff in the above action, by its attorney, Joseph Goldbeck, Jr., Esquire, sets forth as of the date the Praecipe for the Writ of Execution was filed the following information concerning the real property located at 329 15th Street. New Cumberland. PA 17070. 1. Name and address of owner(s) or reputed owner (s): Name Address (if address cannot be reasonably ascertained, please so indicate) James Hoover (Real Owner only) 329 15th Street New Cumberland. PA 17070 Linda Hoover (Real Owner only) 329 15th Street New Cumberland. PA 17070 2. Name and address of defendant(s) in the judgment: Name Address (if address cannot be reasonably ascertained, please so indicate) John o. Osgood (Mortgagor only) 52 Catoctin Court Silver Springs. NO 20906 Susan C. Osgood (Mortgagor only) 423 Market Street Ne~ort. PA 17074 3. Name and address of every judgment creditor whose judgment is a record lien on the real property to be sold: Name Address (if address cannot be reasonably ascertained, please so indicate) Greenwood Trust Co. P.O. Box 11848 Harrisburg. PA 17108 B 1 C Cred1t Un10n 403 N. 2~ Street e co omm. .. ___ __ _ ______ Harrisburg. PA 17101-1322 ,,~' '" "~- ~ .,100.. '"', " Ai/ 'V 4. "~ '-""""""1 [.1-.",,--,",).' ,.. Name and address of the last recorded holder of every mortgage of record: Name Address (if address cannot be reasonably ascertained, please so indicate) First Federal Savings & Loan nd 234 N_ 2 Street Harrisburg. PA 17101 5. Name and address of every other person who has any record lien on the property: Name Address (if address cannot be reasonably ascertained, please so indicate) HQne 6. Name and address of every other person who has any record interest in the property and whose interest may be affected by the sale: Name Address (if address cannot be reasonably ascertained, please so indicate) Cumberland County D~t. of Domestic Relations P.O. Box 320 Carlisle. PA 17013 Pa Dept. of Public Welfare Bureau of Child S~port Enforcement Health and Welfare Bldg. Room 432 P.O. Box 2675 Harrisburg. PA 17105 7. Name and address of every other person of whom the plaintiff has knowledge that has any interest in the property that may be affected by the sale: Name Address (if address cannot be reasonably ascertained, please so indicate) HQne I verify that the statements made in this affidavit are true and correct to the best of my personal knowledge or information and belief. I understand that false statements herein are made subject to the penalties of 18 Pa. C.S. #4904 relating to unsworn falsification to authorities. September 12, 2001 ldbeck, Jr. r Plaintiff ~~~~ii&~lli'lJl"-~1N,l<i"'iI'$"'0i:,,,"j;"''::i1.&''':Mi''.t'krj,d;!'J;'''j'''o_\i,i-'1"-:,,,,";,t,~,fifl~"",",l'.&lL'bj1l&&!!~'~ ~~---"'W"'':'''''"''.J ,",)L"~M~"_ '" ~, _,,".' ~V, _ , ~ ~ ._ - _0- '_""''''' Ul!: ^,' 'U!![! :;;7,1': r" , I,:'):' i (".,"~i (") 0 C-., C "Il ~ VJ -Ow r'1 mm " Z""'l--, -_....' Zr;:: CD if) "" -<...,.~ ~C " PC' ::.Ji;: ;._'-11 Z J ':.dC) -.0 u'-;"] >s:::; :'..J L. <:- =:-~ =< :.b CO -< l.ilj "',:~,u....", ~ : ; -'~ ,-.','-,,,,-, IJ&~_, < 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 FIRST NATIONWIDE MORTGAGE CORP. PO Box 9481 Mail Code: 22-528-1011 Gaithersburg, MD 20898-9481 IN THE COURT OF COMMON PLEAS OF CUMBERLAND COUNTY CIVIL ACTION - LAW Plaintiff :ACTION OF MORTGAGE FORECLOSURE vs. JAMES HOOVER AND LINDA HOOVER (Mortgagor(s) and Record Owner (s) ) Term No. 01-3220 CIVIL 329 15th Street New Cumberland, PA 17070 Defendant(s) AFFIDAVIT PURSUANT TO RULE 3129 FIRST NATIONWIDE MORTGAGE CORP., 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: 329 15th Street, New Cumberland, PA 17070 1. Name and address of Owner(s) or Reputed Owner(s): JAMES HOOVER 329 15th Street New Cumberland, PA 17070 2. Name and address of Defendant(s) in the judgment: JAMES HOOVER 329 15th Street New Cumberland, PA 17070 LINDA HOOVER ,,,'8"" . . .,~ ';'--,. '"~~~j 329 15th Street New Cumberland, PA 17070 3. Name and last known address of every judgment creditor whose judgment is a record lien on the property to be sold: PA DEPT OF PUBLIC WELFARE, BUREAU OF CHILD SUPPORT ENFORCEMENT, HEALTH & WELFARE BLDG., ROOM 432 P.O. BOX 2675 HARRISBURG, PA 17105 CUMBERLAND CO. DEPT. OF DOMESTIC RELATIONS P.O. BOX 320 CARLISLE, PA 17013 GREENWOOD TRUST CO. P.O. BOX 11848. HARRISBURG, PA17108 BELCO COMM. CREDIT UNION 403 N. 2ND ST~EET HARRISBURG; PA 17101-1322 4. Name and address of the last recorded holder of every mortgage of record: FIRST FEDERAL SAVINGS & LOAN 234 N. 2ND STREET HARRISBURG, PA 17101 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. - , ,ll , - , -:- . ~~~ ,--"'~, (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. & McKEEVER , Jr., Esq. tiff DATED: November 27, 2001 BY: ~ ",^J- ')(__"t;'ilinS~~I~~~l!t~~<iH~W':L4't;~i1.!k1l-.l;:~"""t.iHi<;:~tlo~MDJiMI?:lJJJ.iflfSill!liiilllill.'if' _~ ~ ~. ;,,~, ...., ~, '~;-",~~.""'"~'._'-" - "~,, ~ ~~~ ~ ,~,'" ~","- ~ .. ."", -~ - ,~ ~flJrm T (") s.; ui7i,,: q}(f-:' :;;:;1_, -c CO_,'~' ;~(- 2:.Cn ~(-') pr:. ~ - ""1 , . o ,-, '-' " :r: o ,~ ~::j -,"'n ~- N tD -,"!"n ~;~~ ~l,~,~ ~ -< l"~ -,,_:. ~0 Ul -- - . '" - ,---" " 0'-_' 11I'''' , 'I GOLDBECK, McCAFFERTY & McKEEVER A PROFESSIONAL CORPORATION ATTORNEYS AT LAW SUITE 5000 MELLON INDEPENDENCE CENTER 701 MARKET STRTEET PHILADELPHIA, PA 19106 (215) 627-1322 FAX (215) 627-7734 Joseph A. Goldbeck, Jr. Gary E. McCafferty Michael T. McKeever CUMBERLAND COUNTY COURTHOUSE JUDGE KEVIN A. HESS' CHAMBERS 1 COURTHOUSE SQUARE CARLISE, PA 17013 RE: FIRST NATIONWIDE MORTGAGE CORPORATION VS. HOOVER NO.01-3220-CIVIL Dear Robbie: Per our conversation today, please find the PETITION TO MAKE RULE ABSOLUTE with reference to the above captioned matter. I have sent one to the defendant (s) again an one extra envelope for you too) and also an extra copy to be sent back after it is filed in the Prothonotary's office. Robbie, I hope that is what you had stated in our phone call. If there is any problem please do not hesitate to contact me at my direct number @215-825-6342. Thank you for your coop /mrw Enclosures ,. " -' -~'-'l: . -'N ,1 f <\l:_.,. Goldbeck McCafferty & McKeever A PROFESSIONAL CORPORATION JOSEPH A. GOLDBECK, JR. GARY E. MCCAFFERTY* MICHAEL T. MCKEEVER* RENEE M. POZZUOLl-BUECKER* KRISTINAG. MURTHA* LESLIE E. PumA * LISA A. D' ANGELI* ArrORNEY'S AT LAW SENTRY OFFICE PLAZA SUITE 420 216 HADDON AVENUE WESTMONT, NJ 08108 (856) 85S-3242 FAX (856) 858.2997 SUITE 5000 MELLON INDEPENDENCE CENTER 701 MARKET STREET PHILADELPHIA, PENNSYLVANIA 19106- 1532 (215) 627-1322 FAX(215) 627.7734 PLEASE REPLY TO THE PHILADELPHIA OFFICE *PA&NJ BAR WW.GOLDBECKLA W.COM January 23, 2004 CUMBERLAND COUNTY COURTHOUS JUDGE KEVIN A. HESS CHAMBERS 1 Courthouse Square Carlisle, PA 17013 ATTENTION: ROBBIE MARCH RE: FIRST NATIONWIDE MORTGAGE CORPORATION V5. JAMES HOOVER and LINDA HOOVER NO. 01-3220-CIVIL Dear Sirs: Enclosed herewith please find an original and a copy of Plaintiff's Motion to make Rule Absolute with regard to the above-referenced matter. Kindly file the same of record with the Court and return a time-stamped copy in the self-addressed stamped envelope enclosed herewith. --- GEM/mrw Enclosures Cc: JAMES HOOVER & LINDA HOOVER 329 15th Street New Cumberland, PA 17070 _"' o' , .~ ~ . ,~'L, ~ "-,.,~ , ~' JAN 1 5 2004 ~ GOLDBECK McCAFFER'IY & McKEEVER BY: Gary E. McCafferty Attorney I.D.#42386 Suite 5000 - Mellon Independence Center 701 Market Street Philadelphia, PA 19106-1532 215-627-1322 Attorney for Plaintiff FIRST NATIONWIDE MORTGAGE CORPORATION PO Box 9481 Mail Code: 22-528-1011 Gaithersburg, MD 20898-9481 IN THE COURT OF COMMON PLEAS of Cumberland County Plaintiff VS. CIVIL ACTION - LAW JAMES HOOVER and LINDA HOOVER 329 15th Street New Cumberland, P A 17070 ACTION OF MORTGAGE FORECLOSURE Defendant( s) No.01-3220-CIVIL ORDER AND NOW, this day of , 2004, upon consideration of the Petition of FIRST NATIONWIDE MORTGAGE CORPORATION to Amend Judgment and Motion to Make Rule Absolute, it is, ORDERED: - That the Rule is hereby made absolute and the petition is granted and Plaintiff's judgment is hereby reassessed to , plus interest and costs. BY THE COURT: J. <..;;w~ ",~ - ," ,~, "-- - ~ " ~~~';'.' ~' JAN 1 5 2004 ~i GOLDBECK McCAFFERTY & McKEEVER BY: Gary E. McCafferty Attorney I.D.#42386 Suite 500Q - Mellon Independence Center 701 Market Street Philadelphia, PA 19106-1532 215-627-1322 Attorney for Plaintiff FIRST NATIONWIDE MORTGAGE CORPORATION PO Box 9481 Mail Code: 22-528-1011 Gaithersburg, MD 20898-9481 IN THE COURT OF COMMON PLEAS of Cumberland County Plaintiff vs. CIVIL ACTION - LAW JAMES HOOVER and LINDA HOOVER 329 15th Street New Cumberland, PA 17070 ACTION OF MORTGAGE FORECLOSURE Defendant( s) No.01-3220-CIVIL ORDER AND NOW, this day of , 2004, upon consideration of the Petition of FIRST NATIONWIDE MORTGAGE CORPORATION to Amend Judgment and Motion to Make Rule Absolute, it is, ORDERED: ." That the Rule is hereby made absolute and the petition is granted and Plaintiff's judgment is hereby reassessed to , plus interest and costs. BY THE COURT: J. ir*~tt;';~~~jt:vt9jj;r:::s\it:!:>N~;ft:9:;0';:.~~t1;_~::C:::>};:~t;"?wlM~~X~J~~ \' " ~" . 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Ii..,.",',:,;; . c', ~ o r-- o r-- ~ <( a... o I-Z a: a: UJ<( UJUJUJo:! >>a:UJ got;co IOI:2 II-:J CI.l<(l!)() ~O~$ <(Z~UJ -,...JC')Z 1OiiI: ~~Z;f,1Wiitie.Jtt;?i\tft'ffr,J;j:~8m;,{@;~i#A~'}01:-~1tJy;'::;ft:iiw:rJ;)r"'8g;;i ,. '. Ie _~ o~ ~^~"_';":':' _' ,~ '_' "_,. . , ", \ GOLDBECK McCAFFERTY & McKEEVER BY: Gary E. McCafferty Attorney I.D.#42386 Suite 5000 - Mellon Independence Center 701 Market Street Philadelphia, PA 19106-1532 215-627-1322 Attorney for Plaintiff FIRST NATIONWIDE MORTGAGE CORPORATION PO Box 9481 Mail Code: 22-528-1011 Gaithersburg, MD 20898-9481 IN THE COURT OF COMMON PLEAS ofCumberiand County Plaintiff YS. CIVIL ACTION - LAW JAMES HOOVER and LINDA HOOVER 329 15th Street New Cumberland, P A 17070 ACTION OF MORTGAGE FORECLOSURE Defendant( s) No.01-3220-CIVIL ORDER AND NOW, this </'" day of f'~ ,2004, upon consideration of the Petition of FIRST NATIONWIDE MORTGAGE CORPORATION to Amend Judgment and Motion to Make Rule Absolute, it is, ORDERED: That the Rule is hereby made absolute and the petition is granted and Plaintiff's judgment is hereby reassessed to $21,056.51, plus interest and costs. BY THE COURT:, ~ 4/1 l-Ce-otf- C~ ~L~. ~vl{ ~ fvlc-~+kj/4~, ~ j~t ~~1JlJ'<.r ~ ~ite-G, l:li'.~'o;""-,,. *~.mil!liJJ:Mj~'~'--';_~~18Urif:ii'M~~<lWl\>il~" :..;.'; "'--~" '^ '"-"~,,,-,-,~,", . ,- - '~'-","=";-- - -~ \.1"""-""'1":1 1 iil\{\'/\l!\\)i\l''IJ...lO "N' J/lf'{i !J',r'!l',,!~:,:Mnr'l I\J.. J i',,-,',__, \,'" ;'.'_.".'f H J S2 If: I~d s- lB.:l ~UOZ Al::!\ilONOHlOOd 31-11 ~O 301:Ho-G3l\:J _ _ _ _, M' '_m """! : I ~ ;'~=" . ~~- ~ u . ~ ", , ", ' -, . ~ 0" ~,C,__ '< " ". ,'. '" "" "~ '~, GOLDBECK McCAFFERTY & McKEEvER BY: Gary E. McCafferty . Attorney I.D.#42386 Suite 5000 - Mellon Independence Center 701 Market Street Philadelphia, PA 19106-1532 215-627-1322 Attoml:Y for Plaintiff FIRST NATIONWIDE MORTGAGE CORPORATION PO Box 9481 Mail Code: 22-528-1011 Gaithersburg, MD 20898-9481 IN THE COURT OF COMMON PLEAS of Cumberland County Plaintiff vs. CIVIL ACTION - LAW JAMES HOOVER and LINDA HOOVER 329 15th Street New Cumberland, P A 17070 ACTION OF MORTGAGE FORECLOSURE No. 01-3220-CIVIL Defendant( s) MOTION TO MAKE RULE ABSOLUTE AND NOW, this Plaintiff, FIRST NATIONWIDE MORTGAGE CORPORA nON, moves to make a rule absolute for the following reasons: 1. Plaintiff filed a Petition to Amend Judgment on DECEMBER 11. 2003 (True and correct copy attached hereto). 2. A Rule was issued by the Court with a return date of 20 DAYS after service. 3. Plaintiff's Affidavit of Service is attached hereto. 4. No response to the Petition has been made. WHEREFORE, Plaintiff prays that the Court make the rul absolute and enter the attached Order. -" ~ ~ '. " GOLDBECK McCAFFERTY & McKEEVER BY: Gary E. McCafferty Attorney I.D.#42386 Suite 5000 - Mellon Independence Center 701 Market Street Philadelphia, PA 19106-1532 215-627-1322 ", . t ~- ~ ~ ,~ - ....... -~ -,. "; ~ .,- """""'I@'",", Attorney for Plaintiff FIRST NATIONWIDE MORTGAGE CORPORATION PO Box 9481 Mail Code: 22-528-1011 Gaithersburg, MD 20898-9481 Plaintiff vs. JAMES HOOVER and LINDA HOOVER 329 15th Street New Cumberland, PA 17070 Defendant( s) AFFIDAVIT IN THE COURT OF COMMON PLEAS of Cumberland County CIVIL ACTION - LAW ACTION OF MORTGAGE FORECLOSURE No.01-3220-CIVIL Gary E. McCafferty, Esquire., subject to the penalties of 18 P.S. Section4904, deposes and says that he is the attorney for the within named Plaintiff and that all the facts set fort within the attached a Motion to Make Rule Absolute are true and correct to the best of his SWORN TO AND SUBSCRIBED: Before me this;Z;:;; day: Of?UkL , 2004 d~' Notary Public NOTARIAL SEAL Kathleen M. Lion, NotaryPublic City of Phil,delphi., Phil.. County My Call"n!..I.. l!l<pi"" MAy i4, 2004 formation and belief. ""....w. -~~, ,~ '. \ GOLDBECK McCAFFERTY & McKEEVER BY: Gary E. McCafferty Attorney I.D.#42386 Suite 5000 - Mellon Independence Center 701 Market Street Philadelphia, PA 19106-1532 215-627-1322 . L'_ ,'_ '" - ., ,~ , :, " ,_ ",_'," ' l!Lli:~,,;, Attorney for Plaintiff FIRST NATIONWIDE MORTGAGE CORPORATION PO Box 9481 Mail Code: 22-528-10 11 Gaithersburg, MD 20898-9481 Plaintiff vs. JAMES HOOVER and LINDA HOOVER 329 15th Street New Cumberland, P A 17070 Defendant( s) IN THE COURT OF COMMON PLEAS of Cumberland County CIVIL ACTION - LAW ACTION OF MORTGAGE FORECLOSURE No. 0l-3220-CIVIL AFFICA VIT OF SERVICE Gary E. McCafferty, Esquire., attorney for Plaintiff, being duly sworn according to law, hereby certifies that he did serve Defendants JAMES HOOVER and LINDA HOOVER, a copy of Plaintiffs Motion to Make Rule Absolute by first class mail on J VARY 23, 2004 at32915th Street, New Cumberland, PA 1707 SWORN TO AND SUBSCRIBED: Before me this 2' day: Of ~r-- , 2004 1/../" ~Ar '$..lJ/f/~ Notary Public NOTARIAL SEAL '1. K,~~leen M.. Lion, Notary Public , (, ,tI' .,rphiladdphia, Phila. County ! :-";' Commi$lilon &c.pires May 14, 2004 ,,= ~ .~_~ ~"l I. '.. .0'" L.1!ll~",>\!'~-. '. I " GOLDBECK McCAFFERTY & McKEEVER BY: Gary E. McCafferty Attorney I.D.#42386 Suite 5000 - Mellon Independence Center 701 Market Street Philadelphia, PA 19106-1532 215-627-1322 Attorney for Plaintiff FIRSTNATIONWIDE MORTGAGE CORPORATION PO Box 9481 Mail Code: 22-528-1011 Gaithersburg, MD 20898-9481 IN THE COURT OF COMMON PLEAS of Cumberland County Plaintiff CNIL ACTION - LAW vs. JAMES HOOVER and LINDA HOOVER 329 15th Street New Cumberland, P A 17070 ACTION OF MORTGAGE FORECLOSURE No.01-3220-CNIL Defendant( s) CERTIFICATION OF SERVICE Gary E. McCafferty, Esquire, attorney for Plaintiff hereby certifies that a copy of Plaintiff's Petition to Amend Judgment with RULE RETURNABLE date of twenty December 19, 2003 ~-~.;- - efendant(s) JAMES and, PA 17070 on (20)days was mailed by first class mail, postage , " HOOVER and L1NDA'HOOVER at 329 15th Street, e o~iIIlJ~ ( , , ~,' ~ _.~,.,~: '. GOLDBECK McCAFFERTY & McKEEVER A Professional Corporation Attorney's at Law SUITE 5000 MELLON INDEPENDENCE CENTER 701 Market Street PHILADELPHIA, PA 19106-1532 (215) 627-1322 fax (215) 627-7734 JOSEPH A. GOLDBECK, JR. GARY E. McCAFFERTY' MICHAEL T. McKEEVER' KRISTINA G. MURTHA' . 12 119 12003 JAMES HOOVER 329 15th Street New Cumberland, PA 17070 LINDA HOOVER 329 15th Street New Cumberland, PA 17070 RE: FIRST NATIONWIDE MORTGAGE CORPORATION vs. JAMES HOOVER and LINDA HOOVER NO. 01-3220-CIVIL Dear JAMES HOOVER and LINDA HOOVER: Enclosed please find a copy of Plaintiff's Petition to Amend judgment, the original of which has been duly filed of record with the Court. GEMlmrw Enclosure RE: #6838320381 - JAMES HOOVER and LINDA HOOVER ~-"-~ _~_liIliiIt.'L,.. - ,,'-' ~ ,_ 1_ ~ " ,- ~tl.f- r" ; " GOLDBECK McCAFFERTY & McKEEVER JOSEPH A. GOLDBECK, JR. A Professional Corporation Suite 5000 - Mellon Independence Center 701 Market Street Philadelphia,PA 19106-1532 (215) 627-1322 FAX (215) 627-7734 JOSEPH A. GOLDBECK, JR. GARY E. McCAFFERTY MICHAEL T. McKEEVER December 19, 2003 PROTHONOTARY OF CUMBERLAND COUNTY Prothonotary of Cumberland County 1 Courthouse Square Carlisle, P A 17013 RE: JAMES HOOVER and LINDA HOOVER No: 01-3220-CNIL To The Prothonotary: Enclosed herewith please find an original and a copy of Plain tift's CERTIFICATION OF SERVICE with regard to the above-referenced matter. Kindly file the same of record with the Court and return a time-stamped copy in the self-addressed stamped envelope enclosed herewith. Very truly yours, ~fJ::rY GEM/mrw Enclosure - .' c ...~ :'-~~~"'- " GOLDBECK McCAFFERTY & McKEEVER BY: Gary E. McCafferty Attorney I.D.#42386 Suite 5000 - Mellon Independence Center 701 Market Street Philadelphia, PA 19106-1532 215-627-1322 Attorney for Plaintiff FIRST NATIONWIDE MORTGAGE CORPORATION PO Box 9481 Mail Code: 22-528-1011 Gaithersburg, MD 20898-9481 IN THE COURT OF COMMON PLEAS of Cumberland County CIVIL ACTION - LAW Plaintiff ys. ACTION OF MORTGAGE FORECLOSURE JAMES HOOVER and LINDA HOOVER 329 15th Street New Cumberland, PA 17070 No.01-3220-CIVIL Defendant( s) RULE AND NOW, a rule is entered upon Defendant(s) to show cause why the relief requested in Plaintiff's Motion to Amend Judgment should not be granted. Rule returnable lk~ ga:;: gf ,).0 ~ Date:~>lI\J llD1 j.{)()3 )5 ~. J. :,. . -.~. ... C;",~k , '"" " <" ,--. "l0.!_~, '. . '. GOLDBECK McCAFFERTY & McKEEVER BY: Gary E. McCafferty Attorney I.D.#42386 Suite 5000 - Mellon Independence Center 701 Market Street Philadelphia, PA 19106-1532 215-627-1322 Attorney for Plaintiff FIRST NATIONWIDE MORTGAGE CORPORATION PO Box 9481 Mail Code: 22-528-1011 Gaithersburg, MD 20898-9481 IN TIlE COURT OF COMMON PLEAS of Cumberland County Plaintiff CNIL ACTION - LAW VS. ACTION OF MORTGAGE FORECLOSURE JAMES HOOVER and LINDA HOOVER 329 15th Street New Cumberland, P A 17070 No.01-3220-CNIL Defendant( s) ORDER AND NOW, this day of ,2003, upon consideration of the Petition ofFIRST NATIONWIDE MORTGAGE CORPORATION to Amend its Judgment, it is, ORDERED: That the petition is granted and Plaintiffs judgment is hereby amended to $21,056.51, plus interest and costs. BY THE COURT: J. __~ . ~H'. ~_~;;;: '"'~~"'~ ~-.'~" ~~~,~,. '. GOLDBECK McCAFFERTY & McKEEVER BY: Gary E. McCafferty i\ttorneyI.D.#42386 Suite 5000 - Mellon Independence Center 701 Market Street Philadelphia, Pi\ 19106-1532 215-627-1322 i\ttorney for Plaintiff 0 c::> 0 c W -n ~ 0 '4 -OG:' rrt ~;2 (I1t!'"! n Z,J] --"jr\"\ 70- <nZ^" '''-'<:''1 ~6 C)O -0 ::;f'..,-j '--n ~0 :;!l;: C)(~ ~-c,;;) '-i! 6rn "'c ~ ~ .j.- -< FIRST NATIONWIDE MORTGAGE CORPORATION PO Box 9481 Mail Code: 22-528-1011 Gaithersburg, MD 20898-9481 IN TIlE COURT OF COMMON PLEAS of Cumberland COlll1ty Plaintiff vs. CIVIL ACTION - LAW JAMES HOOVER and LINDA HOOVER 329 15th Street New Cumberland, Pi\ 17070 ACTION OF MORTGAGE FORECLOSURE Defendant( s) No.01-3220-CIVIL TIDS IS LAW FIRM IS A DEBT COLLECTOR AND WE ARE i\TTEMPTING TO COLLECT i\ DEBT OWED TO OUR CLIENT. ANY INFORMA.TION OBTi\INED FROM YOU WILL BE USED FOR THE PURPOSE OF COLLECTING THE DEBT. PLAINTIFF'S PETITION TO AMEND JUDGMENT AND NOW, this Plaintiff, FIRST NATIONWIDE MORTQAGE CORPORATION, petitions the Court to Amend Judgment for the following reasons: 1. Plaintiff's Complaint in Mortgage Foreclosure was filed on May 25,2001 . 2. On September 18, 2001, judgment in mortgage foreclosure was entered in favor of Plaintiff and against Defendants in the amount of$10,655.31, based upon the demand in Plaintiff's Complaint. (Copies of the Complaint and Judgment are attached hereto collectively as Appendix III) ;,;~"__o ~_ , L__ .~ .~ ~"~~~,.J..i. '. 3. On December 03, 2001 Defendants filed a petition in bankruptcy in the United States Bankruptcy Court for the Middle District of Pennsylvania (No. 01-06400) which stayed further prosecution of Plain tift's action in mortgage foreclosure. 4. By order of United States Bankruptcy Court dated October 22, 2003 Plaintiff was granted relief from the automatic stay imposed by the Bankruptcy Code. 5. Since the filing of the Complaint, interest has been accruing as have the escrow balance deficit and late charges under the terms of the mortgage contract involved. 6. Due to the stay of proceedings, Plaintiff's judgment is now insufficient to satisfy the amounts due and owing on the mortgage and the mortgage lien on the property in question. 7. Upon disposition of this petition and the scheduling of a Sheriff's Sale on March 03,2004, the amounts due and owing on the mortgage will be as follows: Principal Balance $7,635.80 Interest from 1 % 1/00 thrn 03/0S/04 at 8.250% Per diem interest rate at $2,159.40 Attorney's Fee at 5.0000% of principal balance $1,250.00 Late Charges per Complaint $568.24 Costs of Suit and Title Search $750.00 Escrow Balance Deficit $8,693.07 TOTAL $21.056.51 ,r""" '. ~~ "" ,,-,,-. ,~ -~~,:, -, ~r -ml'rlUl!:~'r:M WHEREFORE, Plaintiff prays that the Petition be granted and Plaintiff's Judgment be amended to $21,056.51, plus interest and costs. ~ Respect ! ~~ " - - ili,i' .1 " . " ,. '. . , GOLDBECKM~AmrnRIT&Mc~E~R BY: Gary E. McCafferty Attorney 1.D.#42386 Suite 5000 - Mellon Independence Center 701 Market Street Philadelphia, PA 19106-1532 215-627-1322 Attorney for Plaintiff FIRST NATIONWIDE MORTGAGE CORPORATION PO Box 9481 Mail Code: 22-528-1011 Gaithersburg, MD 20898-9481 IN THE COURT OF COMMON PLEAS of Cumberland County Plaintiff VS. CNIL ACTION - LAW JAMES HOOVER and LINDA HOOVER 329 15th Street New Cumberland, P A 17070 ACTION OF MORTGAGE FORECLOSURE Defendant( s) No.01-3220-CNlL VERIFICATION Gary E. McCafferty, Esq., hereby states that he is the attorney for Petitioner within named and that all of the facts set forth within the attached Petition to Amend its Judgment are true and correct to the best of his knowledge, informa' n and b ief. The undersigned understands that the foregoing statements are made subject t t Gary E. ,Esq. . '",,-~~- -~'"' r-" - _l. "' - , -"""',.~;,,",',' " " GOLDBECK McCAFFERTY & Mc~E~R BY: Gary E. McCafferty Attorney I.D.#42386 Suite 5000 - Mellon Independence Center 701 Market Street Philadelphia, PA 19106-1532 215-627-1322 Attorney for Plaintiff FIRST NATIONWIDE MORTGAGE CORPORATION PO Box 9481 Mail Code: 22-528-1011 Gaithersburg, MD 20898-9481 IN THE COURT OF COMMON PLEAS of Cumberland County CNILACTION -LAW Plaintiff YS. ACTION OF MORTGAGE FORECLOSURE JAMES HOOVER and LINDA HOOVER 329 15th Street New Cumberland, P A 17070 No.01-3220-CIVIL Defendant(s) MEMORANDUM OF LAW IN SUPPORT OF PLAINTIFF'S PETITION TO AMEND JUDGMENT Plaintiff is entitled to the amounts due and owing on the mortgage contract at the time of the Sheriffs Sale of property involved. For reasons stated in the within motion, Plaintiffs judgment in mortgage foreclosure is insufficient to cornpensate Plaintiff for the amount due and owing under the mortgage. Specifically, interest charges, the escrow balance deficit and late charges have all been accruing while Plaintiffs action in mortgage foreclosure was stayed by Defendant(s) bankruptcy petition. "';0,... .. . - 'Cd ,~~ "' ""'" ~ ~&it__~ ^. ' CONCLUSION For the reasons stated above and in the within petition, Plaintiff respectfully requests that the petition be granted and Plaintiff's judgment be amended to $21,056.51, plus interest and costs. ~--~ - GOLDBECK McCAFFERIT & McKEE~R BY: Gary E. McCafferty Attorney I.D.#42386 Suite 5000 - Mellon Independence Center 701 Market Street Philadelphia, PA 19106-1532 215-627-1322 Attorney for Plaintiff ,........ , I ,'<-~ "',(~'II>fi10', '" <- ~".-- FIRST NATIONWIDE MORTGAGE CORPORATION PO Box 9481 Mail Code: 22-528-1011 Gaithersburg, MD 20898-9481 Plaintiff YS. JAMES HOOVER and LINDA HOOVER 329 15th Street New Cumberland, P A 17070 Defendant(s) . IN THE COURT OF COMMON PLEAS of Cumberland County CNlL ACTION - LAW ACTION OF MORTGAGE FORECLOSURE No.01-3220-CIVIL CERTIFICATION OF SERVICE Gary E. McCafferty, Esquire, attorney for Plaintiff hereby certifies that a copy of Plaintiffs Petition to Amend Judgment was mailed by first class mail, postage prepaid to Defendant(s) JAMES HOOVER and LINDA HOOVER at 329 15th Street, New Cumberland, PA 17070 on December 9, 2003 . ~ 7 ~,")l,.t<f.'!(l!!fI ..1'- ,,,,",-. '.. GOLDBECK McCAFFERTY & McKEEVER A Professional Corporation Attorney's at Law SUITE 5000 MELLON INDEPENDENCE CENTER 701 Market Street PHILADELPHIA, PA 19106-1532 (215) 627-1322 fax (215) 627-7734 JOSEPH A. GOLDBECK, JR. GARYE.McCAFFER~ MICHAEL T, McKEEVER" KRISTINA G, MURTHA" I:J- lOr 12003 JAMES HOOVER 329 15th Street New Cumberland, PA 17070 LINDA HOOVER 329 15th Street New Cumberland, PA 17070 RE: FIRST NATIONWIDE MORTGAGE CORPORATION vs, JAMES HOOVER and LINDA HOOVER NO, 01-3220-CIVIL Dear JAMES HOOVER and LINDA HOOVER: Enclosed ple'ase find a copy of Plaintiff's Petition to Amend Judgment, the original of which has been duly filed of record with the Court, Very truly yours, ets: GEM/mrw Enclosure RE: #6838320381 - JAMES HOOVER and LINDA HOOVER ''',",-. ~~~, :'- -,,-'" lIIil..1i~~" GOLDBECK McCAFFERTY & McKEEVER A Professional Corporation Attorney's at Law SUiTE 5000 MELLON INDEPENDENCE CENTER 701 Market Street PHiLADELPHIA, PA 19106-1532 (215) 627-1322 fax (215) 627-7734 JOSEPH A. GOLDBECK, JR, GARY E, McCAFFERTY" MICHAEL T, McKEEVER' KRISTINA G. MURTHA' /J 1 tJ9 12003 JAMES HOOVER 329 15th Street New Cumberland, PA 17070 LINDA HOOVER 329 15th Street New Cumberland, PA 17070 RE: FIRST NATIONWIDE MORTGAGE CORPORATION vs, JAMES HOOVER and LINDA HOOVER NO. 01-3220-CIVIL Dear JAMES HOOVER and LINDA HOOVER: Enclosed please find a copy of Plaintiff's Petition to Amend Judgment, the original of which has been duly filed of record with the Court. GARY E. McCAFFERTY GEMlmlW Enclosure RE: #6838320381 - JAMES HOOVER and LINDA HOOVER = ,.~ "~~l "~ . ~ .. GOLDBECK McCAmrnRTY & McKEE~R BY: Gary E. McCafferty Attorney I.D.#42386 Suite 5000 - Mellon Independence Center 701 Market Street Philadelphia, PA 19106-1532 215-627-1322 Attorney for Plaintiff . j ~,- - 'Ji>l""",,-_~,,<" DEe 1 2 2003 ATTO~~7jEY , ' i ;;~:.~ '1~l ' ~,,,. Ii ~ ~ COpy FIRST NATIONWIDE MORTGAGE CORPORATION PO Box 9481 Mail Code: 22-528-1011 Gaithersburg, MD 20898-9481 Plaintiff Ys. JAMES HOOVER and LINDA HOOVER 329 15th Street New Cumberland, PA 17070 Defendant(s) IN THE COURT OF COMMON PLEAS of Cumberland County CNlL ACTION - LAW ACTION OF MORTGAGE FORECLOSURE No.01-3220-CIVIL RULE AND NOW, a rule is entered upon Defendant(s) to show cause why the relief requested in Plaintiff's Motion to Amend Judgment should not be granted. Rule returnable tb" ad;,: €If J. (J.~ Date: Du-orm1wJ II. i(lQ3 . J. ~ <1-" ,', ,." ~ _"l:4~..,,,,-.._~' '. GOLDBECK McCAmrnRTY &Mc~E~R BY: Gary E. McCafferty Attorney I.D.#42386 Suite 5000 - Mellon Independence Center 701 MarketStreet Philadelphia, PA 19106-1532 215-627-1322 Attorney for Plaintiff FIRST NATIONWIDE MORTGAGE CORPORATION PO Box 9481 Mail Code: 22-528-1011 Gaithersburg, MD 20898-9481 IN THE COURT OF COMMON PLEAS of Cwnberland County Plaintiff CIVIL ACTION - LAW YS. ACTION OF MORTGAGE FORECLOSURE JAMES HOOVER and LINDA HOOVER 329 15th Street New Cwnberland, P A 17070 No.01-3220-CNlL Defendant( s) ORDER AND NOW, this day of , 2003, upon consideration of the Petition of FIRST NATIONWIDE MORTGAGE CORPORATION to Amend its Judgment, it is, ORDERED: That the petition is granted and Plaintiff's judgment is hereby amended to $21,056.51, plus interest and costs, BY THE COURT: J, ;1=;_,~L, - , , -<'O\!&IWlt~",i: , GOLDBECK McCAmrnRTY & McKEE~R BY: Gary E. McCafferty Attorney I.D.#42386 Suite 5000 - Mellon Independence Center 701 Market Street Philadelphia, PA 19106-1532 215-627-1322 Attorney for Plaintiff 0 0 0 ~ <.-J -n 'S>- \:::1 --~ ""'Ocr.' ,'1 I,:<}l mF e' _r;(':: .? :);~ ~-3~ :2S,. (f)..... ~c, --u -rl;;<):D ~o 3'; ~;7Q -,-\11 0 '.f? St 5>c ~ .;:- ~ - FIRST NATIONWIDE MORTGAGE CORPORATION PO Box 9481 Mail Code; 22-528-1011 Gaithersburg, MD 20898-9481 IN THE COURT OF COMMON PLEAS of Cumberland County Plaintiff YS. CNIL ACTION - LAW JAMES HOOVER and LINDA HOOVER 329 15th Street New Cwnberland, P A 17070 ACTION OF MORTGAGE FORECLOSURE Defendant( s) No,Ol-3220-CNIL THIS IS 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. PLAINTIFF'S PETITION TO AMEND JUDGMENT AND NOW,.,this Plaintiff, FlRST NATIONWIDE MORTQAGE CORPORATION, petitions the Court to Amend Judgment for the following reasons: 1. Plaintiff's Complaint in Mortgage Foreclosure was filed on May 25,2001 . 2, On September 18, 2001, judgment in mortgage foreclosure was entered in favor of Plaintiff and against Defendants in the amount of $1 0,655.31, based upon the demand in Plaintiff's Complaint. (Copies of the Complaint and Judgment are attached hereto collectively as Appendix III) ~,',t,"",,"'~ .. '" ,~ ,~- - _ J , ~~_M" = '" ,e '.' '. 3. On December 03, 2001 Defendants filed a petition in bankruptcy in the United States Bankruptcy Court for the Middle District of Pennsylvania (No. 01-06400) which stayed further prosecution of Plaintiff's action in mortgage foreclosure. 4. By order of United States Bankruptcy Court dated October 22, 2003 Plaintiff was granted relief from the automatic stay imposed by the Bankruptcy Code, 5, Since the filing of the Complaint, interest has been accruing as have the escrow balance deficit and late charges under the terms of the mortgage contract involved, 6. Due to the stay of proceedings, Plaintiff's judgment is now insufficient to satisfy the amounts due and owing on the mortgage and the mortgage lien on the property in question. 7. Upon disposition of this petition and the scheduling of a Sheriff's Sale on March 03,2004, the amounts due and owing on the mortgage will be as follows: Principal Balance $7,635.80 Interest from 10/01/00 thrn 03/0S/04 at 8.250% Per diem interest rate at $2,159.40 Attorney's Fee at 5.0000% of principal balance $1,250.00 . Late Charges per Complaint $568.24 Costs of Suit and Title Search $750:00 Escrow Balance Deficit $8,693,07 TOTAL $21.056.51 '-'~_~u ~~ .' __~H , ~" ' ",- ~-A","",' WHEREFORE, Plaintiff prays that the Petition be granted and Plaintiff's Judgment be amended to $21,056,51, plus interest and costs, Respec ; ~~ -- ~ ~ ,- " "Ill.o"""''';: '. ' GOLDBECK McCAmrnRTY & Mc~E~R BY: Gary E. McCafferty Attorney I.D.#42386 Suite 5000 - Mellon Independence Center 701 Market Street Philadelphia, PA 19106-1532 215-627-1322 Attorney for Plaintiff FIRST NATIONWIDE MORTGAGE CORPORATION PO Box. 9481 Mail Code: 22-528-1011 Gaithersburg, MD 20898-9481 IN THE COURT OF COMMON PLEAS Plaintiff YS. of Cumberland County CNlL ACTION - LAW JAMES HOOVER and LINDA HOOVER 329 15th Street New Cumberland, PA 17070 ACTION OF MORTGAGE FORECLOSURE Defendant( s) No.01-3220-CNlL VERIFICATION Gary E, McCafferty, Esq" hereby states that he is the attorney for Petitioner within named and that all of the facts set forth within the attached Petition to Amend its Judgment are true and correct to the best of his knowledge, informa' n and b lief, . The undersigned understands that the foregoing statements are made subject t Gary E. ~iI!'l!ii1' " ~ I , < ,,, '0 -.' ._~~~~1t:" '. ' GOLDBECK McCAFFERTY & McKEEVER BY: Gary E. McCafferty Attorney I.D.#42386 Suite 5000 - Mellon Independence Center 701 Market Street Philadelphia, PA 19106-1532 215-627-1322 Attorney for Plaintiff FIRST NATIONWIDE MORTGAGE CORPORATION PO Box 9481 Mail Code: 22-528-1011 Gaithersburg, MD 20898-9481 IN THE COURT OF COMMON PLEAS of Cumberland County CIVIL ACTION -LAW Plaintiff YS. ACTION OF MORTGAGE FORECLOSURE JAMES HOOVER and LINDA HOOVER 329 15th Street New Cumberland, P A 17070 No.01-3220-CNIL Defendant( s) MEMORANDUM OF LA W IN SUPPORT OF PLAINTIFF'S PETITION TO AMEND JUDGMENT Plaintiff is entitled to the amounts due and owing on the mortgage contract at the time of the Sheriff's Sale of property involved. For reasons stated in the within motion, Plaintiffs judgment in mortgage foreclosure is insufficient to compensate Plaintiff for the amount due and owing under the mortgage. Specifically, interest charges, the escrow balance deficit and late charges have all been accruing while Plaintiffs action in mortgage foreclosure was stayed by Defendant(s) bankruptcy petition. ~_".~ l._ _. , - ',:" L. "~_ L l.'. .. , ""J<i__",",,>, CONCLUSION For the reasons stated above and in the within petition, Plaintiff respectfully requests that , the petition be granted and Plaintiff's judgment be amended to $21,056.51, plus interest and costs. ,~ '"", I " ~ l~lllll!l:'I.'iiilM~'!'ll'_"'-"_. '. GOLDBECK McCAmrnRTY & McKEE~R BY: Gary E. McCafferty Attorney I.D.#42386 Suite 5000 - Mellon Independlence Center 701 Market Street Philadelphia, PA 19106-1532 215-627-1322 Attorney for Plaintiff FIRST NATIONWIDE MORTGAGE CORPORATION PO Box 9481 Mail Code: 22-528-1011 Gaithersburg, MD 20898-9481 IN THE COURT OF COMMON PLEAS of Cumberland County Plaintiff CNIL ACTION - LAW YS. JAMES HOOVER and LINDA HOOVER 329 15th Street New Cumberland, P A 17070 ACTION OF MORTGAGE FORECLOSURE No.01-3220-CNlL Defendant(s) . CERTIFICATION OF SERVICE Gary E, McCafferty, Esquire, attorney for Plaintiff hereby certifies that a copy of Plaintiffs Petition to Amend Judgment was mailed by first class mail, postage prepaid to Defendant(s) JAMES HOOVER and LINDA HOOVER at 329 15th Street, New Cumberland, PA 17070. on December 9,2003 " ;;;~~~ < " . GOLDBECK McCAFFERTY & McKEEVER A Professional Corporation Attorney's at Law SUITE 5000 MELLON INDEPENDENCE CENTER 701 Market Street PHILADELPHIA, PA 19106-1532 (215) 627.1322 fax (215) 627.7734 JOSEPH A. GOLDBECK, JR. GARY E. McCAFFERTY* MICHAEL T, McKEEVER" KRISTINA G, MURTHA" / ~ 101 12003 JAMES HOOVER 329 15th Street New Cumberland,PA 17070 LINDA HOOVER 329 15th Street New Cumberland, PA 17070 RE: FIRST NATIONWIDE MORTGAGE CORPORATION vs, JAMES HOOVER and LINDA HOOVER NO, 01-3220-CIVIL Dear JAMES HOOVER and LINDA HOOVER: Enclosed please find a copy of Plaintiff's Petition to Amend Judgment, the original of which has been duly filed of record with the Court, Very truly yours, r7f'::::--- G~M~~ GEM/mrw Enclosure RE: #6838320381 - JAMES HOOVER and LINDA HOOVER f. ,'_ ~~~'" .,".....'~, ~~~ ~- -~ -"'- ,I .:.:...,., ~""""'"' ~~.""'\~" '. . Goldbeck McCafferty & McKeever A PROFESSIONAL CORPORATION JOSEPH A. GoLDBECK, JR. GARY E. MCCAFFERTY' MICHAEL T. McKIlEvER' RENEE M. PoZZUOU-BlJECKER* KRlSTINA G. MURTHA' LEsLIE E. PulDA' LISA A. D' ANGELI' ATIORNBY'S AT lAw SIlNTRY OFFICE PLAzA SUITE 420 216 HADDON A VllNUIl WESTMONT, NJ 08108 (856) 858-3242 FAX (856) 858-2997 'PA&NJBAR SUITE 5000 MELLON INDEPENDENCE CENTER 701 MARKET STREET I'HlLADELPHlA, PENNSYL V ANlA 19106- 1532 (215) 627-1322 FAX (215) 627-7734 PLEASE REPLY TO THE PHILADELPHIA OFFICE WW.GOLDBECKLAW.COM January 12, 2004 Prothonotary of Cumberland County 1 Courthouse Square Carlisle, PA 17013 RE: FIRST NATIONWIDE MORTGAGE CORPORATION V5. JAMES HOOVER and LINDA HOOVER NO. 01-3220-CIVIL Dear Sirs: Enclosed herewith please find an original and a copy of Plaintiffs Motion to .m,!ke Rule Absolute with regard to the above-referenced matter. Kindly file the same of record with the Court and return.S! time-stamped copy in the self-addressed stamped envelope enclosed herewith, <25- - Y E. FERTY GEM/mrw Enclosures ~"~ - , ~-",.. , , ~- ~~ '~. ~" " , Goldbeck McCafferty & McKeever A PROFESSIONAL CORPORATION JOSEPH A, GoLDBECK, JIt. GARY E. MCCAFFERTY" MICHAEL T. McKEEvER" RBNBEM. POzzUOU-BUBCKER" KRIsTINA G. MURTIIA" LESLIE E. PUIDA" LIsA A. D' ANGELl" ATTORNEY'S AT LAw SENTRY OFFICE PLAzA SUITE 420 216llADDoN AVENUE WESTMOm, NJ 08108 (856) 858-3242 FAX (856) 858-2997 "PA & NJ BAR SUITE 5000 MEu.oN INDEPENDENCE CENTllR 701 MARKEr STREET PHILADELPlIlA, PENNSYLYANIA 19106- 1532 (215) 627-1322 FAX (215) 627-7734 PLEASE RBPLYTO THE PHILADELPHIA OFFICE WW.GOLDBECKLA W.COM January 12, 2004 Prothonotary of Cumberland County 1 Courthouse Square Carlisle, PA 17013 RE: FIRST NATIONWIDE MORTGAGE CORPORATION vs. JAMES HOOVER and LINDA HOOVER NO. 01-3220.CIVIL Dear Sirs: Enclosed herewith please find an original and a copy of Plaintiffs Motion to make Rule Absolute with regard to the above-referenced matter, Kindly file the same of record with the Court and return a time-.stamped copy in e self-addressed stamped envelope enclosed herewith. ,. GEM/mrw Enclosures Cc: JAMES HOOVER & LINDA HOOVER 32915th Street New Cumberland, PA 17676 ,k; -"~. _,j .-' .1.0 ~, GOLDBECK McCAFFERTY & McKEE~R BY: Gary E. McCafferty Attorney I.D.#42386 Suite 5000 - Mellon Independence Center 701 Market Street Philadelphia, PA 19106-1532 215-627-1322 Attorney for Plaintiff Dr B 20UJ v FIRST NATIONWIDE MORTGAGE CORPORATION PO Box 9481 Mail Code: 22-528-1011 Gaithersburg, MD 20898-9481 IN THE COURT OF COMMON PLEAS of Cumberland County CIVIL ACTION - LAW Plaintiff Ys. ACTION OF MORTGAGE FORECLOSURE JAMES HOOVER and LINDA HOOVER 329 15th Street New Cumberland, PA 17070 No.01-3220-CIVIL Defendant( s) RULE AND NOW, a rule is entered upon Defendant(s) to show cause why the relief requested in Plaintiff's Motion to Amend Judgment should not be granted, ,. ;to .rt:.rVJ b- . Rule returnable tRG Bay sf J. Date: JJw-Jv If, Zt#J ,0) \~ \V ~~Mli~~1i,~;<fhtiL,*"~m-~~~i!_~,\ffil""IW_f,\l\Jlj,~~"""A."'<5">;:4\;.~~~&<;!i~~.~iillIiiL~* ""llrilOitlill^ :i" ;a:ui<lli:>'UIiJi..ld'~ ~: JLJJl!.Jl!I!l., I I ~lrY?:r7i\"lr\S':\!I'~,l~1~t, i\,J.;":I".,.,',i --::'1<\1(1"" .'--" ,.1'",,1 I ~ :2 H~ 9! 33Q EOOl }.f:NWNOHIOl:Jd 3H.l :10 ~J~)l.i;O-{I31I~ _ ,.JI11JL_",,,~,",,,,-,~~,,"^","_" ,,";V~'~ ."",,_" ,-",,,a~;-<,,,,, ",,-'_'...~ .., ., ~ ~ ~. ,.. ,~" ,,'~, ~^ " .., IT' ~. " " ."",-,' ,2"~ ,- '-"~, ~ ~-,,-= "' -'~ ,t ~;J " :_,~ ~ - ~ -" -', . " "-~- .........."i<< GOLDBECK McCAFFERTY & Mc~E~R BY: Gary E. McCafferty Attorney I.D.#42386 Suite 5000 - Mellon Independence Center 701 Market Street Philadelphia, PA 19106-1532 215-627-1322 Attorney for Plaintiff FIRST NATIONWIDE MORTGAGE CORPORATION PO Box 9481 Mail Code: 22-528-1011 Gaithersburg, MD 20898-9481 IN THE COURT OF COMMON PLEAS of Cumberland County Plaintiff CIVIL ACTION - LAW YS. ACTION OF MORTGAGE FORECLOSURE JAMES HOOVER and LINDA HOOVER 329 15th Street New Cumberland, P A 17070 No.01-3220-CNlL Defendant( s) ORDER AND NOW, this day of , 2003, upon consideration ofthe Petition of FIRST NATIONWIDE MORTGAGE CORPORATION to Amend its Judgment, it is, ORDERED: That the petition is granted and Plaintiff's judgment is hereby amended to $21,056,51, plus interest and costs. BY THE COURT: J. ."-- - - .,-~- '"' .... , j . , ",..;,;,. -.'1Jr.~", GOLDBECK McCAmrnRTY & Mc~E~R BY: Gary E. McCafferty Attorney I.D.#42386 Suite 5000 - Mellon Independence Center 701 Market Street Philadelphia, PA 19106-1532 215-627-1322 Attorney for Plaintiff FIRST NATIONWIDE MORTGAGE CORPORATION PO Box 9481 Mail Code: 22-528-1011 Gaithersburg, MD 20898-9481 IN THE COURT OF COMMON PLEAS of Cumberland County Plaintiff Ys. CIVIL ACTION - LAW JAMES HOOVER and LINDA HOOVER 329 15th Street New Cumberland, PA 17070 ACTION OF MORTGAGE FORECLOSURE Defendant( s) No.01-3220-CNIL THIS IS 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. PLAINTIFF'S PETITION TO AMEND JUDGMENT AND NOW, this Plaintiff, FIRST NATIONWIDE MORTQAGE CORPORATION, petitions the Court to Amend Judgment for the following reasons: 1, Plaintiff's Complaint in Mortgage Foreclosure was filed on May 25, 2001 . 2. On September 18, 2001, judgment in mortgage foreclosure was entered in favor of Plaintiff and against Defendants in the amount of $10,655.31, based upon the demand in Plaintiff's Complaint. (Copies of the Complaint and Judgment are attached hereto collectively as Appendix III) <>ilIii16IiIlII~-'" , " ---~~ . ~ I ~". ~' \,~. '~ ....~ml~*;j->-" 3~ On December 03,2001 Defendants filed a petition in bankruptcy in the United States Bankruptcy Court for the Middle District of Pennsylvania (No, 01-06400) which stayed further prosecution of Plaintiff's action in mortgage foreclosure. 4. By order of United States Bankruptcy Court dated October 22, 2003 Plaintiff was granted relief from the automatic stay imposed by the Bankruptcy Code, 5. Since the filing of the Complaint, interest has been accruing as have the escrow balance deficit and late charges under the terms of the mortgage contract involved. 6, Due to the stay of proceedings, Plaintiff's judgment is now insufficient to satisfy the amounts due and owing on the mortgage and the mortgage lien on the property in question. 7, Upon disposition of this petition and the scheduling of a Sheriff's Sale on March 03, 2004, the amounts due and owing on the mortgage will be as follows: Principal Balance $7,635.80 Interest from 10/01/00 thrn 03/0S/04 at 8.250% Per diem interest rate at $2,159.40 Attorney's Fee at 5.0000% of principal balance $1,250.00 Late Charges per Complaint $568.24 Costs of Suit and Title Search $750,00 Escrow Balance Deficit $8,693.07 TOTAL $21.056.51 ~"~.'~ ~ ... '.' J ~ ~L -~~~ WHEREFORE, Plaintiff prays that the Petition be granted and Plaintiff's Judgment be Respec amended to $21,056.51, plus interest and costs. Gary E, ~c i i ..-' L J- .~,- GOLDBECK McCAFFERTY & Mc~E~R BY: Gary E. McCafferty Attorney I.D.#42386 Suite 5000 - Mellon Independence Center 701 Market Street Philadelphia, PA 19106-1532 215-627-1322 Attorney for Plaintiff FIRST NATIONWIDE MORTGAGE CORPORATION PO Box 9481 Mail Code: 22-528-1011 Gaithersburg, MD 20898-9481 IN THE COURT OF COMMON PLEAS of Cumberland County Plaintiff YS. CIVIL ACTION - LAW JAMES HOOVER and LINDA HOOVER 329 15th Street New Cumberland, P A 17070 ACTION OF MORTGAGE FORECLOSURE Defendant( s) No.01-3220-CNlL VERIFICATION Gary E. McCafferty, Esq., hereby states that he is the attorney for Petitioner within named and that all of the facts set forth within the attached Petition to Amend its Judgment are true and correct to the best of his knowledge, informa' understands that the foregoing statements are made subject t Gary E. . , - --, " ' " , i ,. ....~"'~~--"j GOLDBECK McCAmrnRTY & Mc~E~R BY: Gary E. McCafferty Attorney I.D.#42386 Suite 5000 - Mellon Independence Center 701 Market Street Philadelphia, PA 19106-1532 215-627-1322 Attorney for Plaintiff FIRST NATIONWIDE MORTGAGE CORPORATION PO Box 9481 Mail Code: 22-528-1011 Gaithersburg, MD 20898-9481 IN THE COURT OF COMMON PLEAS of Cumberland County CIVIL ACTION - LAW Plaintiff ys. ACTION OF MORTGAGE FORECLOSURE JAMES HOOVER and LINDA HOOVER 329 15th Street New Cumberland, P A 17070 No.01-3220-CIVIL Defendant( s) MEMORANDUM OF LAW IN SUPPORT OF PLAINTIFF'S PETITION TO AMEND JUDGMENT Plaintiff is entitled to the amounts due and owing on the mortgage contract at the time of the Sheriffs Sale of property involved. For reasons stated in the within motion, Plaintiffs judgment in mortgage foreclosure is insufficient to compensate Plaintiff for the amount due and owing under the mortgage. Specifically, interest charges, the escrow balance deficit and late charges have all been accruing while Plaintiffs action in mortgage foreclosure was stayed by Defendant(s) bankruptcy petition. " ., ~~,- ,~ , - -, c ,- ,. ~ _.~ CONCLUSION For the reasons stated above and in the within petition, Plaintiff respectfully requests that the petition be granted and Plaintiff's judgment be amended to $21,056,51, plus interest and costs. ~- _1,,-", _ GOLDBECK McCAFFERTY & Mc~E~R BY: Gary E. McCafferty Attorney I.D.#42386 Suite 5000 - Mellon Independence Center 701 Market Street Philadelphia, PA 19106-1532 215-627-1322 Attorney for Plaintiff ,_Ll . <.IiI 'W'<'" FIRST NATIONWIDE MORTGAGE CORPORATION PO Box 9481 Mail Code: 22-528-1011 Gaithersburg, MD 20898-9481 Plaintiff YS. JAMES HOOVER and LINDA HOOVER 329 15th Street New Cumberland, P A 17070 Defendant( s) IN THE COURT OF COMMON PLEAS of Cumberland County CIVIL ACTION - LAW ACTION OF MORTGAGE FORECLOSURE No.01-3220-CIVIL CERTIFICATION OF SERVICE Gary E, McCafferty, Esquire, attorney for Plaintiff hereby certifies that a copy of Plaintiff's Petition to Amend Judgment was mailed by first class mail, postage prepaid to Defendant(s) JAMES HOOVER and LINDA HOOVER at 329 15th Street, New Cumberland, PA 17070 on December 9,2003 ;~,...:.. ~ t . GOLDBECK McCAmrnRTY & Mc~E~R BY: Gary E. McCafferty Attorney I.D.#42386 Suite 5000 - Mellon Independence Center 701 Market Street Philadelphia, PA 19106-1532 215-627-1322 Attorney for Plaintiff "" --, - ~,' , ",,' " ""~H.. ;;';;.~-- \-,' ; ~' ." FIRST NATIONWIDE MORTGAGE CORPORATION PO Box 9481 Mail Code: 22-528-1011 Gaithersburg, MD 20898-9481 Plaintiff VS. JAMES HOOVER and LINDA HOOVER 329 15th Street New Cumberland, P A 17070 Defendant( s) IN THE COURT OF COMMON PLEAS of Cumberland County CIVIL ACTION - LAW ACTION OF MORTGAGE FORECLOSURE No.01-3220-CIVIL CERTIFICATION OF SERVICE Gary E. McCafferty, Esquire, attorney for Plaintiff hereby certifies that a copy of Plaintiff's Petition to Amend Judgment with RULE RETURNABLE date of twenty (20)days was mailed by first class mail, postage HOOVER and LINDA HOOVER at 329 15th Street, e December 19, 2003 ~'!'ft... ~ efendant(s) JAMES and, PA 17070 on 1-....-~~" - ,~ , ,.I ~o "~ ,L~'- ,~, ~-", ~.-- ~'~t,- ; ... GOLDBECK McCAFFERTY & McKEEVER A Professional Corporation Attorney's at Law SUITE 5000 MELLON INDEPENDENCE CENTER 101 Market Street PHILADELPHIA, PA 19106-1532 (215) 621-1322 fax (215) 621.1134 JOSEPH A. GOLDBECK, JR. GARY E, McCAFFERTY' MICHAEL T, McKEEVER' KRISTINA G, MURTHA' . 12 119 12003 JAMES HOOVER 329 15th Street New Cumberland, PA 17070 LINDA HOOVER 329 15th Street New Cumberland, PA 17070 RE: FIRST NATIONWIDE MORTGAGE CORPORATION vs, JAMES HOOVER and LINDA HOOVER NO. 01-3220-CIVIL Dear JAMES HOOVER and LINDA HOOVER: Enclosed please find a copy of Plaintiff's Petition to Amend Judgment, the original of which has been duly filed of record with the Court. GEM/mrw Enclosure RE: #6838320381 - JAMES HOOVER and LINDA HOOVER "" - , . -_. ,"if. _ l . ".~.... ~'~ ' . " "~M1;I,:~_ ! ,"" GOLDBECK McCAFFERTY & McKEEVER A Professional Corporation Attorney's at Law SUITE 5000 MELLON INDEPENDENCE CENTER 701 Market Street PHILADELPHIA, PA 19106-1532 (215) 627.1322 fax (215) 627-7734 JOSEPH A. GOLDBECK, JR. GARYE,McCAFFERTr MICHAEL T, McKEEVER' KRISTINA G. MURTHA' I ~ /()~ /2003 JAMES HOOVER 329 15th Street New Cumberland, PA 17070 LINDA HOOVER 329 15th Street New Cumberland, PA 17070 RE: FIRST NATIONWIDE MORTGAGE CORPORATION vs, JAMES HOOVER and LINDA HOOVER NO, 01-3220-CIVIL Dear JAMES HOOVER and LINDA HOOVER: Enclosed ple-ase find a copy of Plaintiff's Petition to Amend Judgment, the original of which has been duly filed of record with the Court, Very truly yours, G~ GEM/mrw Enclosure RE: #6838320381 - JAMES HOOVER and LINDA HOOVER ~~~~hD4~~iJe>;~'~~~~lil-'b-EJ"""L~."jiii-i;!;-*_~~_* r' ~...., "~'~~ "", ) u ..'," Jf" ~ ,_~ ~o ""_ '.~lli. e <=> ~ w <r c:> ;:Hi;'; ._, ..'.- r" ~J~' Tl' r r-~ C) Z:o., , ll~ Z!~-. ;f:~8 Ci)~'r -<,.-'.: ('-~; , ~C", :':,0 "-0 ~;~~~ ~O 3 ~CJ W ";~-'rn 'c C) ~ ~"'i ~ .;:" ~ -< . ,,'ll.iJi1!iaik'~~'-.. '''-<rt:l'1lf nJllIMill!\ilil~~>"."~~' - ",j - ~- -. " 'r"" iflliI.I'" .~~ ~ ~'";.;'>'(<Ii~I~"" GOLDBECK MCCAFFERTY & MCKEEVER A PROFESSIONAL CORPORATION SUITE 5000, MELLON INDEPENDENCE CENTER 701 MARKET STREET PHILADELPHIA, PA 19106 188130 . F1 RSTRUST 3,7380-2360 12/9/2063 o . o c o " ~ o PAY TO THE ORDER OF Prothonotary of Cumberland County $ **9.60 11'1.88 I. :lOll' .: i'!:l (;07 :l8o 1.1: 70 I. 1.000 1.811' In DOLLARS i ~ . , . ~ f w , Nine and 00/100* * ** * * * * ** * ** * * * * ** * * *** * ** * * ** * * * * * ** * ** * * * * * * ** * ** * * * ** * ** * * * * * * * *. MEMO Hoover GOLDBECK MCCAFFERTY & MCKEEVER Prothonotary of Cumberland County 12/9/2003 188130 9.00 . Mortgage Disburse Hoover 9.00 ~illIlIiW!llCUII~..~. "- . ~> ~,,~ , , I , ' ~~ 0' ~_ ",< '-.. ",' <',,;5 j - '.',,-.--,. 'ii-;-. , GOLDBECK McCAFFERTY & McKEEVER By: Joseph A, Goldbeck, Jr, Attorney I,D. #16132 Suite 500 - The Bourse Bldg, 111 S, Independence Mall East Philadelphia, PA 19106 (?1 '0) 627-1 'I?? ATTORNEY FOR PLAINTIFF First Nationwide Mortgage Corp. P.O. Box 9481, Mail Code: 22-528-1011 Gaithersburg, MD 20898-9481 Vs. John O. Osgood (Mortgagor only) Susan C. Osgood (Mortgagor only) 52 Catoctin Court Silver Springs, MD 20906 CUMBERLAND COUNTY COURT OF COMMON PLEAS CIVIL DIVISION NO 01-3220-Civil James Hoover (Real Owner only) Linda Hoover (Real Owner only) 329 15th Street New Cumberland, PA 17070 PRAECIPE FOR JUDGMENT FOR FAILURE TO ANSWER AND ASSESSMENT OF DAMAGES TO THE PROTHONOTARY: Kindly enter judgment in favor of the Plaintiff and against John O. Osgood (Mortgagor only). Susan C. Osgood (Mortgagor only) . James Hoover (Real Owner only) and Linda Hoover (Real Owner only), Defendant(s) for failure to file an Answer to Plaintiff's Complaint within 20 days (or 60 days if defendant is the United States of America) from the date of service of the complain and for foreclosure and sale of the mortgaged premises, and assess Plaintiff's damages as follows: As set forth in Complaint Interest - 6/1/01 - 9/12/01 Late Charges TOTAL $10,412.35 $ 183.04 S 69.92 $10,665.31 I hereby certify that (1) the addresses of the Plaintiff and Defendants are as shown above, and (2) that notice has been given in accordance with Rule 237.1, copy attached, DATE: DAMAGES ARE HEREBY ASSESSED AS INDIC I hereby certify that the above names are correct and that the precise residence address of the judgment creditor is P,O. Box 9481, Mail Code: 22-528-1011, Gaithersburg, MD 20898-9481 and that the names and last known addresses of the Defendants are: John O. Osgood (Mortgagor only), 52 Catoctin Court, Silver Springs, MD 20906 Susan C. Osgood (Mortgagor only), 423 Market Street, Newport, PA 17074 James Hoover (Real Owner only), 329 15th Street, New Cumberland, PA 17070 Linda Hoover (Real Owner only), 329 15th Street, New Cumberland, PA 17070 Idbeck, Jr. r Plaintiff "' . , " I _ "' ~ , " ,-^.,,,,,, ,'~ - ~ ,,'" ",' "0 ."~f- "j -" ~~c,,' TO, JOHN O. OSGOOD 423 Market Street Newport, PA 17074 FIRST NATIONWIDE MORTGAGE CORP, PO Box 9481 Mail Code, 22-528-1011 Gaithersburg, MD 20898-9481 Plaintiff vs. JOHN O. OSGOOD AND SUSAN C. OSGOOD (Mortgagor (s) ) JAMES HOOVER AND LINDA HOOVER (Record Owner(s) ) 329 15th Street New Cumberland, PA 17070 Defendant(s) IN THE COURT OF COMMON PLEAS OF CUMBERLAND COUNTY CIVIL ACTION - LAW ACTION OF MORTGAGE FORECLOSURE Term No, 01-3220 CIVIL 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: JOHN 0, OSGOOD 423 Market Street Newport, PA 17074 DATE OF THIS NOTICE: August 20, 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 Isl J03eph --4. (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 ,c I L ~, . ,"~ ; . <-" l~"""'-"-~1'i TO: SUSAN C. OSGOOD 423 Market Street Newport, PA 17074 FIRST NATIONWIDE MORTGAGE CORP, PO Box 9481 Mail Code: 22-528-1011 Gaithersburg, MD 20898-9481 Plaintiff vs. JOHN O. OSGOOD AND SUSAN C, OSGOOD (Mortgagor ( s) ) JAMES HOOVER AND LINDA HOOVER (Record Owner(s) ) 329 15th Street New Cumberland, PA17070 Defendant(s) IN THE COURT OF COMMON PLEAS OF CUMBERLAND COUNTY CIVIL ACTION - LAW ACTION OF MORTGAGE FORECLOSURE Term No, 01-3220 CIVIL 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: SUSAN C, OSGOOD 423 Market Street Newport, PA 17074 DATE OF THIS NOTICE: August 20, 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 Isl JO:J~Dh .A. (jotdbech. 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 ,'';'';'' < ~ ~~~ ~ 0-. ,-,' -",,", .~< TO : JAMES HOOVER 423 Market Street Newport, PA 17074 FIRST NATIONWIDE MORTGAGE CORP. PO Box 9481 Mail Code: 22-528-1011 Gaithersburg, MD 20898-9481 Plaintiff vs. JOHN O. OSGOOD AND SUSAN C. OSGOOD (Mortgagor (s) ) JAMES HOOVER AND LINDA HOOVER (Record Owner (s) ) 329 15th Street New Cumberland, PA 17070 Defendant(s) IN THE COURT OF COMMON PLEAS OF CUMBERLAND COUNTY CIVIL ACTION - LAW ACTION OF MORTGAGE FORECLOSURE Term No, 01-3220 CIVIL 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: JAMES HOOVER 423 Market Street Newport, PA 17074 DATE OF THIS NOTICE: August 20, 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 Isl JO:Jeph -A. (fo!Jbeck. 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 ,~ " , '", . .~ '''-'''''''?'-'_'C',_, -jJ~i;:' TO: LINDA HOOVER 423 Market Street Newport, PA 17074 FIRST NATIONWIDE MORTGAGE CORP, PO Box 9481 Mail Code: 22-528-1011 Gaithersburg, MD 20898-9481 Plaintiff vs. JOHN O. OSGOOD AND SUSAN C, OSGOOD (Mortgagor (s) ) JAMES HOOVER AND LINDA HOOVER (Record Owner (s) ) 329 15th Street New Cumberland, PA 17070 Defendant(s) IN THE COURT OF COMMON PLEAS OF CUMBERLAND COUNTY CIVIL ACTION - LAW ACTION OF MORTGAGE FORECLOSURE Term No. 01-3220 CIVIL 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: LINDA HOOVER 423 Market Street Newport, PA 17074 DATE OF THIS NOTICE: August 20, 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 Isl JOdeph JJ. (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 .-," " - .c .-, ---' ;,<,,ci '-'-' TO: JOHN O. OSGOOD 52 Catoctin Court Silver Springs, MD 20906 FIRST NATIONWIDE MORTGAGE CORP, PO Box 9481 Mail Code: 22-528-1011 Gaithersburg, MD 20898-9481 Plaintiff vs. JOHN 0, OSGOOD AND SUSAN C, OSGOOD (Mortgagor (s) ) JAMES HOOVER AND LINDA HOOVER (Record Owner (s) ) 329 15th Street New Cumberland, PA 17070 Defendant(s) IN THE COURT OF COMMON PLEAS OF CUMBERLAND COUNTY CIVIL ACTION - LAW ACTION OF MORTGAGE FORECLOSURE Term No, 01-3220 CIVIL 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: JOHN 0, OSGOOD 52 Catoctin Court Silver Springs, MD 20906 DATE OF THIS NOTICE: August 20, 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 Isl JOdeph -.A. (jotdtech. 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 , - , ~" ~~ -" '" '"' 0 ~ _ <.__,,~. _, "" it~, TO, SUSAN C. OSGOOD 52 Catoctin Court Silver Springs, MD 20906 FIRST NATIONWIDE MORTGAGE CORP, PO Box 9481 Mail Code, 22-528-1011 Gaithersburg, MD 20898-9481 Plaintiff vs. JOHN O. OSGOOD AND SUSAN C, OSGOOD (Mortgagor (s) ) JAMES HOOVER AND LINDA HOOVER (Record Owner (s) ) 329 15th Street New Cumberland, PA 17070 Defendant(s) IN THE COURT OF COMMON PLEAS OF CUMBERLAND COUNTY CIVIL ACTION - LAW ACTION OF MORTGAGE FORECLOSURE Term No, 01-3220 CIVIL 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: SUSAN C, OSGOOD 52 Catoctin Court Silver Springs, MD 20906 DATE OF THIS NOTICE: August 20, 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 Isl 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 - , -~- - - ~ ,-,', ,. ';" """'~""Ji TO: JAMES HOOVER 52 Catoctin Court Silver Springs, MD 20906 FIRST NATIONWIDE MORTGAGE CORP, PO Box 9481 Mail Code: 22-528-1011 Gaithersburg, MD 20898-9481 Plaintiff vs. JOHN O. OSGOOD AND SUSAN C, OSGOOD (Mortgagor (s) ) JAMES HOOVER AND LINDA HOOVER (Record Owner (s)) 329 15th Street New Cumberland, PA 17070 Defendant(s) IN THE COURT OF COMMON PLEAS OF CUMBERLAND COUNTY CIVIL ACTION - LAW ACTION OF MORTGAGE FORECLOSURE Term No, 01-3220 CIVIL 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: JAMES HOOVER 52 Catoctin Court Silver Springs, MD 20906 DATE OF THIS NOTICE: August 20, 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 Isl Joaeph -A. (jotdbeck. Jr. GOLDBECK McCAFFERTY & McKEEVER BY: Joseph A, Goldbeck, Jr" Esg, Attorney for Plaintiff Suite 500 - The Bourse Bldg. 111 S, Independence Mall East Philadelphia, PA 19106 215-627-1322 - ,<,' " 1. ,-,,~,~ -',--. ~,,' TO: LINDA HOOVER 52 Catoctin Court Silver Springs, MD 20906 FIRST NATIONWIDE MORTGAGE CORP. PO Box 9481 Mail Code: 22-528-1011 Gaithersburg, MD 20898-9481 Plaintiff vs. JOHN 0, OSGOOD AND SUSAN C. OSGOOD (Mortgagor (s) ) JAMES HOOVER AND LINDA HOOVER (Record Owner (s)) 329 15th Street New Cumberland, PA 17070 Defendant(s) IN THE COURT OF COMMON PLEAS OF CUMBERLAND COUNTY CIVIL ACTION - LAW ACTION OF MORTGAGE FORECLOSURE Term No, 01-3220 CIVIL 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: LINDA HOOVER 52 Catoctin Court Silver Springs, MD 20906 DATE OF THIS NOTICE: August 20, 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 Isl JOdeph --4. goldbeck. J,.. 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 ,p~ " L J. TO: LINDA HOOVER 329 15th Street New Cumberland, PA 17070 FIRST NATIONWIDE MORTGAGE CORP, PO Box 9481 Mail Code: 22-528-1011 Gaithersburg, MD 20898-9481 Plaintiff vs. JOHN 0, OSGOOD AND SUSAN C, OSGOOD (Mortgagor (s)) JAMES HOOVER AND LINDA HOOVER (Record Owner (s)) 329 15th Street New Cumberland, PA 17070 Defendant(s) IN THE COURT OF COMMON PLEAS OF CUMBERLAND COUNTY CIVIL ACTION - LAW ACTION OF MORTGAGE FORECLOSURE Term No. 01-3220 CIVIL 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: LINDA HOOVER 329 15th Street New Cumberland, PA 17070 DATE OF THIS NOTICE: August 20, 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 Isl JO:Jeph .A. (jotdteckJ 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 -,,;~~. ~ , 0'.1-, =~,i" -.;;;'" "0 ~,,' -i_ .,.";,.,',,,:, TO: JAMES HOOVER 329 15th Street New Cumberland, PA 17070 FIRST NATIONWIDE MORTGAGE CORP. PO Box 9481 Mail Code: 22-528-1011 Gaithersburg, MD 20898-9481 Plaintiff VEl. JOHN O. OSGOOD AND SUSAN C, OSGOOD (Mortgagor (s) ) JAMES HOOVER AND LINDA HOOVER (Record Owner (s)) 329 15th Street New Cumberland, PA 17070 Defendant(s) IN THE COURT OF COMMON PLEAS OF CUMBERLAND COUNTY CIVIL ACTION - LAW ACTION OF MORTGAGE FORECLOSURE Term No, 01-3220 CIVIL 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: JAMES HOOVER 329 15th Street New Cumberland, PA 17070 DATE OF THIS NOTICE: August 20, 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 Isl JOdeph --4. (loldbeck. 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, "' ,~ ; , '-,; ., "~ ',S 0" ~', ''',," , Hi "j' TO: SUSAN C. OSGOOD 329 15th Street New Cumberland, PA 17070 FIRST NATIONWIDE MORTGAGE CORP. PO Box 9481 Mail Code: 22~528~1011 Gaithersburg, MD 20898~9481 Plaintiff vs. JOHN 0, OSGOOD AND SUSAN C. OSGOOD (Mortgagor (s)) JAMES HOOVER AND LINDA HOOVER (Record Owner (s)) 329 15th Street New Cumberland, PA 17070 Defendant(s) IN THE COURT OF COMMON PLEAS OF CUMBERLAND COUNTY CIVIL ACTION - LAW ACTION OF MORTGAGE FORECLOSURE Term No. 01~3220 CIVIL 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: SUSAN C, OSGOOD 329 15th Street New Cumberland, PA 17070 DATE OF THIS NOTICE: August 20, 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 Isl JOdeph -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 "' , . ~, i',__ >~.- . ".,," It ~ , . TO : JOHN O. OSGOOD 329 15th Street New Cumberland, PA 17070 FIRST NATIONWIDE MORTGAGE CORP. PO Box 9481 Mail Code: 22-528-1011 Gaithersburg, MD 20898-9481 Plaintiff vs, JOHN O. OSGOOD AND SUSAN C. OSGOOD (Mortgagor (s) } JAMES HOOVER AND LINDA HOOVER (Record Owner(s) } 329 15th Street New Cumberland, PA 17070 Defendant(s) IN THE COURT OF COMMON PLEAS OF CUMBERLAND COUNTY CIVIL ACTION - LAW ACTION OF MORTGAGE FORECLOSURE Term No, 01-3220 CIVIL THIS LAW FIRM IS A DEBT COLLECTOR AND WE ARE ATTEMPTING TO COLLECT A DEBT OWED TO OUR CLIENT. ANY INFQRMATION OBTAINED FROM YOU WILL BE USED FOR THE PURPOSE OF COLLECTING THE DEBT. TO: JOHN 0, OSGOOD 329 15th Street New Cumberland, PA 17070 DATE OF THIS NOTICE: Aug~st 20, 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 Isl JOdeph --4. goldbeck. Jr. GOLDBECK McCAFFERTY & McKEEVER BY: Joseph A, Goldbeck, Jr" Esq. Attorney for Plaintiff Suite 500 - The Bourse B1dg, III S. Independence Mall East Philadelphia, PA 19106 215-627-1322 ~m~ik<lii;",~lWt~b&!".:l~~'fi,?ii:-'I~j.t\i1,~i.<~~%,I&tWJfi'tWi,.#oift<~*illI.i!~liijl~:t!iil~ li - ii .;ldWIIl '..... ~Lf i!!4t,.:~~j,,";.}j,~ , 1 =~~..L__N ~, ,." _~.,,",~ '.. ...~, '=~".""=" ~'_' '."_,~"",~_~" ~,"~ ~ ^ " 1 0 c:> C} C "n 7 cn ~ -orY' j"11 ~ G !Ili''-- .'0 'tV ..() L:) It zr . ~3E CO Ii:. 0 <CJ -0 0 2;;0 :::J;~ r ....... ~ =.:::C) "- V ><;,~ t;-:; "- ;} :~ .. l ~ () CO 'f'- ~ r LJ - tv rt ~ . 1'" - ~ ~~ ,-,< ",' ,-- ,,~,,' "~~~ ~l 1 ,.. '. 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 FIRST NATIONWIDE MORTGAGE CORP. PO Box 9481 Mail Code: 22-528-1011 Gaithersburg, MD 20898-9481 IN THE COURT OF COMMON PLEAS OF CUMBERLAND COUNTY vs, Term No. 01-3220 CIVIL JOHN 0, OSGOOD AND SUSAN C, OSGOOD (Mortgagor(s)) JAMES HOOVER AND LINDA HOOVER (Record Owner(s)) 329 15th Street New Cumberland, PA 17070 CERTIFICATE OF SERVICE PURSUANT TO Pa.R.C.P. 404 Joseph A, Goldbeck, Jr" Esquire, hereby certifies that a true and correct copy of the above-captioned Complaint in Mortgage Foreclosure was served upon Defendant(s) John & Susan Osgood by certified mail , JR, ""~ ;t,~~ -. ~, -~~ ~~~ >>.. " .,,. - ~~ ~._..2:.~Articl;'N~~~.r.......~U.d~..~~~_.~.__.._d~.__...m.~~.._~.U. I: ' 111~'IIUlll ii I' 7W1o ..575loi!"III ..b0373'l1 3. serVice, Type .- CERTIFIED MAiL 4. Restricted Delivery? (Extra Fee) 1. Article' Addressed to: I: " " I: i: Ii I: 'I: -!: II li I: I: i: I: " --: ,; l. I: Ii Re:f1\JOq.~~/;,,~t ..~, ,:,PS Form 3811, .June 2000 ,1...', DYes Susan C, Osgood 52 Catoctin Court - Silver Spring;MD 20906 .~~ " ~, - 1[L~. ,.' .S.E,NP.,Efl: Domestic Return Receipt ~ :i 7W1i ..575 Jo2'l!t IfI:o[$ 711..5 ,.. " ,; 3. Service Type CERllFIED MAil ,. i; 4. Restricted Delivery? (Extra Fee) ,. II 1. Article Addressed to: I; I: 'II I: i: " " I: I; " :1 " Ii I' " ii DYes John O. Osgood 52 Catoctin Court Silver Spring, MD 20906 (~ RE:fftvb~3~/'t;}t~J,~ i P" l;":f:IQ":R:' PSFo.rm 3811, june 2000 Dqm..llcRetu,n Receipt ,., \'; " ".\ ~~~k"W,~f-!l1~lm;,s:.t.l_1fmi*~~~ml~'''''F<i'i!;j,;,!,,!j''''''')_\41,~.i't#o~f~~~~iIlI""_- ~ 'i:0l:,\~::'&'.;,J,)~,o'I~~^,"~'"~"''',,,,,~~,,,,,<,,W-~.'''~''''''' ",,"". >~_ '" ",..",-"~'''''''",,=...~ _ ",,, '" '_','"^"'~' <y~=~, ," "' ~ i ~ .' .... " 0 C::J r-.- ~E: J."'" -0 (JJ rTlrf~ ~.;") Z:T.! " , Z C en h__, -< ~r. .'1) -.l?' (~~ Zc :'~J ~~ )>F' ,- ,-" Z '''' ~ ::2 (';\ -< ".. 'I I , "".,0 ~i~~ -- .~ '-~. 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 FIRST NATIONWIDE MORTGAGE CORP. IN THE COURT OF COMMON PLEAS PO Box 9481 Mail Code: 22-528-1011 OF CUMBERLAND COUNTY Gaithersburg, MD 20898-9481 Plaintiff CIVIL ACTION - LAW VS, :ACTION OF MORTGAGE FORECLOSURE JOHN O. OSGOOD AND SUSAN C, Term OSGOOD (Mortgagor(s)) No. 01-3220 CIVIL JAMES HOOVER AND LINDA HOOVER (Record Owner(s)) 329 15th Street New Cumberland, PA 17070 Defendant(s) PRAECIPE TO REINSTATE COMPLAINT Kindly reinstate the Complaint in the above captioned matter, BY: Jr. GOLDBECK M FN-0232 1<' '&'"" ~~ ,r>. ",,",,-. ","___' ,- ,,-, ',i_o '""""h , ""'j["\l, .. -. ""< ! GOLDBECK, McCAFFERTY & McKEEVER Suite 500 - The Bourse Bldg. 111 S. Independence Mall East PhiladeLphia, PA 19106 215-627-1322 BY: MICHAEL T. MCKEEVER, ESQUIRE Attorney I,D, #56129 Attorney for Plaintiff FIRST NATIONWIDE MORTGAGE CORP, PO Box 9481 Mail Code: 22-528-1011 Gaithersburg, MD 20898-9481 IN THE COURT OF COMMON PLEAS OF CUMBERLAND COUNTY vs, Term No. 01-3220 CIVIL JOHN 0, OSGOOD AND SUSAN C, OSGOOD (Mortgagor(s)) JAMES HOOVER AND LINDA HOOVER (Record Owner(s)) 329 15th Street New Cumberland, PA 17070 PRAECIPE TO SATISFY JUDGMENT as to Defendants John and Susan Osgood TO THE PROTHONOTARY: As to the defendants John Osgood and Susan Osgood, kindly satisfy the judgment in the above captioned matter upon payment of your costs only. , JR" ESQUIRE ~_~~~Ii;;'Offii:~i'"~iHiIllt~.w.m~i;W;I'!/!.r""",,~!'''''!;,dil~-'i;'i1iij;-J:.l~,~~1i.iI!lllll:"''':'~~~'l"'i*lliIiiiliiilr"'. '"""'" .,' .'.~'. _ ~ .~' e~ .. ~~ "!j;; '. . .- t '~ ~ 0 .. ~ C) ~ ;;; '-'\ ..... 0- fR05 f!S ''f'i g ~r,., ;K::I' );:' '<:;: :iJ ..... ~.,~- ~ ~ ..... ~fj 1"'< CJ) "" ." f 5;; c, "" ..., ;?:,---. ~ ~ \>> ~C5 '::::i{~, ..c ....t-.;;.. '1"'_;-J --l\ Ii (:5.--rl t.o ;o.'t~ ~ '. 'Srrj -- 5;;! I\) :ss "" f0 -N ~ 1""""0;.>"<_"",,,,,,",.,, , __~~,?.... ~"~_,, ,e' ,~. ~"- ,. '\\'ill'~' ~': ~ r : ' --, ~ '.,', ,"" -~~" - -'-'"" '~~'~ tl!OO1.Aii~1it~i!IlU>J". SHERIFF'S RETURN - NOT FOUND 'CASE NO: 2001-03220 P COMMONWEALTH OF PENNSYLVANIA , COUNTY OF CUMBERLAND FIRST NATIONWIDE MORTGAGE CORP VS OSGOOD JOHN 0 ET AL R, Thomas Kline ,Sheriff or Deputy Sheriff, who being duly sworn according to law, says, that he made a diligent search and inquiry for the within named defendant, DEFENDANT OSGOOD JOHN 0 but was unable to locate Him in his bailiwick,. He therefore returns the COMPLAINT - MORT FORE , NOT FOUND , as to the within named DEFENDANT , OSGOOD JOHN 0 OSGOODS MOVED OVER 20 YEARS AGO. NO KNOWN ADDRESS. Sheriff's Costs: Docketing Service Affidavi t Surcharge 18,00 11.70 .00 10.00 .00 39.70 ~~ R. Thomas Kli.e Sheriff of Cumberland County GOLDBECK MCCAFFERTY & MCKEEVER 07/11/2001 Sworn and subscribed to before me this day of ~ ,:",' . k "" ~. "'~~ _ . ~O"~. '. ~';; tilLUil '. to~,,*J!i, SHERIFF'S RETURN - NOT FOUND .CASE NO: 2001-03220 P COMMONWEALTH OF PENNSYLVANIA COUNTY OF CUMBERLAND , FIRST NATIONWIDE MORTGAGE CORP VS OSGOOD JOHN 0 ET AL R. Thomas Kline ,Sheriff or Deputy Sheriff, who being duly sworn according to law, says, that he made a diligent search and inquiry for the within named defendant, DEFENDANT OSGOOD SUSAN C but was unable to locate Her in his bailiwick. He therefore returns the COMPLAINT - MORT FORE , NOT FOUND , as to the within named DEFENDANT , OSGOOD SUSAN C OSGOODS MOVED OVER 20 YEARS AGO. NO KNOWN ADDRESS. Sheriff's Costs: Docketing Service Affidavit Surcharge So 6.00 ,00 ,00 10.00 .00 16.00 R" homas Kline Sheriff of Cumberland County GOLDBECK MCCAFFERTY & MCKEEVER 07/11/2001 Sworn and subscribed to before me ....-/ this I r -iCt day of J t.vltt , ~= ~ - ~ - _ l., ~ '.,~~ ,""," -'* . "J~ SHERIFF'S RBTURN - RBGULAR CA$E NO: 2001-03220 P COMMONWEALTH OF PENNSYLVANIA: I COUNTY OF CUMBERLAND FIRST NATIONWIDE MORTGAGE CORP VS OSGOOD JOHN 0 ET AL GERALD WORTHINGTON , Sheriff or Deputy Sheriff of Cumberland county, Pennsylvania, who being duly sworn according to law, says, the within COMPLAINT - MORT FORE was served upon HOOVER JAMES the DEFENDANT , at 1945:00 HOURS, on the 30th day of May , 2001 at 329 15TH STREET NEW CUMBER~D, PA 17070 by handing to LINDA HOOVER, WIFE a true and attested copy of COMPLAINT - MORT FORE together with and at the same time directing Her attention to the contents thereof, Sheriff's Costs: Docketing Service Affidavit Surcharge So Answers: 6.00 .00 .00 10.00 .00 16,00 .r~~~~~ R. Thomas Kline 07/11/2001 GOLDBECK MCCAFFERTY & MCKEEVER Sworn and Subscribed to before (~+e.. day of By' ~ ' o. M L~q,n ~ Deputy S. riff c~UWl~ '_" i r- '"''''''''-''''1'"",""",,"~ r.'~~w.:.~" SHERIFF'S RETURN - REGULAR CASE NO: 2001-03220 P 1- COMMONWEALTH OF PENNSYLVANIA: COUNTY OF CUMBERLAND FIRST NATIONWIDE MORTGAGE CORP VS OSGOOD JOHN 0 ET AL GERALD WORTHINGTON , Sheriff or Deputy Sheriff of Cumberland County,Pennsylvania, who being duly sworn according to law, says, the within COMPLAINT - MORT FORE was served upon HOOVER LINDA the DEFENDANT , at 1945:00 HOURS, on the 30th day of May , 2001 at 329 15TH STREET NEW CUMBERLAND, PA 17070 by handing to LINDA HOOVER a true and attested copy of COMPLAINT - MORT FORE together with and at the same time directing Her attention to the contents thereof. Sheriff's Costs: Docketing Service Affidavit Surcharge So Answers: 6.00 .00 .00 10,00 .00 16.00 <"/?/ L~ ~~.?e'<:~~ R, Thomas Kline 07/11/2001 GOLDBECK MCCAFFERTY & MCKEEVER Sworn and Subscribed to before me this day of BY:~'~fi Deputy Sh ff p= ~- ~- '.J,n__ '> .J " ",,^', , ~-~~ ~,"~ ~ GOLDBECK, MCCAFFERTY & MCKEEVER By: Joseph A. Goldbeck, Jr. Attorney I.D. #16132 Suite SOO-The Bourse Bldg. 111 S, Independence Mall East Philadelphia, FA 19106 (/.1 sl 6/.7-132/. ATTORNEY FOR PLAINTIFF COURT OF COMMON PLEAS First Nationwide Mortgage Corp. Vs. CUMBERLAND COUNTY CIVIL DIVISION NO, 01-3220-Civil John O. Osgood (Mortgagor only) Susan C. Osgood (Mortgagor only) James Hoover (Real Owner only) Linda Hoover (Real Owner only) CERTTFICATION JOSEPH A. GOLDBECK, JR., ESQUIRE, hereby states that he is the attorney for the Plaintiff in the above captioned matter and that the premises are not subject to the provisions of Act 91 because it is: ( ) an FHA Mortgage ( ) non-owner occupied ( ) vacant (X) Act 91 procedures have been fulfilled This certification is made subject to the penalties of 18 Pa, C.S. ~ 4904 relating to unsworn falsification to authorities. lclbeck, Jr. r Plaintiff ,~'-t"""',....~ ~" -" =, ~.~ I "~~jw" SHERIFF'S RETURN - OUT OF COUNTY ...,.. . . '. CASE NO: 2001-03220 P COMMONWEALTH OF PENNSYLVANIA: COUNTY OF CUMBERLAND FIRST NATIONWIDE MORTGAGE CORP VS OSGOOD JOHN 0 ET AL R, Thomas Kline , Sheriff or Deputy Sheriff who being duly sworn according to law, says, that he made a diligent search and and inquiry for the within named DEFENDANT , to wit: OSGOOD JOHN 0 but was unable to locate Him in his bailiwick. He therefore deputized the sheriff of PERRY County, Pennsylvania, to serve the within COMPLAINT - MORT FORE On Auqust 22nd , 2001 , this office was in receipt of the attached return from PERRY Sheriff's Costs: Docketing Out of County Surcharge Dep Perry County 18,00 9.00 10.00 40.24 .00 77 .24 08/22/2001 GOLDBECK MCCAFFERTY SO~ R. homas Kl in" .~ Sheriff of Cumberland County MCKEEVER Sworn and subscribed to before me this .xi ff- day of ()'i,u..d' ;1.0-<>/ A.D, 0y~ a~'jf1 Prot 0 a 1 ,,~'"-"'~..-:..~l.""~J ....." >~ "-- ,~_.~.. "" - ,,~~~ (Wl;ij ,~, ~,~ SHERIFF'S RETURN - OUT OF COUNTY 'l!' ... CASE NO: 2001-03220 P COMMONWEALTH OF PENNSYLVANIA: COUNTY OF CUMBERLAND FIRST NATIONWIDE MORTGAGE CORP VS OSGOOD JOHN 0 ET AL R, Thomas Kline , Sheriff or Deputy Sheriff who being duly sworn according to law, says, that he made a diligent search and and inquiry for the within named DEFENDANT , to wit: OSGOOD SUSAN C but was unable to locate Her in his bailiwick. He therefore deputized the sheriff of PERRY County, Pennsylvania, to serve the within COMPLAINT - MORT FORE On August 22nd , 2001 , this office was in receipt of the attached return from PERRY Sheriff's Costs: Docketing Out of County Surcharge 6.00 .00 10.00 ,00 .00 16.00 08/22/2001 GOLDBECK MCCAFFERTY ,O~ R.homas Kline Sheriff of Cumberland County MCKEEVER Sworn and subscribed to before me this .20 ~ d f" . ay 0 1t'..0'...r- :krol A.D, C),~fLp~t~y I~ .r -~,"""."~ ~, ~ = ". .. ,j " " ~ bllM:.~,,;: ~ ~ First Nationwide Mort Corp. IN THE COURT OF COMMON PLEAS OF THE 41st JUDICIAL DISTRICT OF PENNSYLVANIA, PERRY COUNTY BRANCH Versus Susan Osgood No, 01-3220 SHERIFF'S RETURN And now August 17,2001: Served the within name Susan Osgood the defendant(s) named herin, personally at her place of residence in Newport Borough Perry County, PA, on August 17, 2001 at 12:00 o'clock PM by handing to Susan Osgood , an adult member of family, 1 true and attested copy(ies) of the within Complaint in Mortgage Foreclosure and made known to her the contents thereof Sworn and subscribed to before me this(}OJA day of ,cJool Sheriff of Perry County D NOTARIAI.SEAl. 1IARCNllTF. fUCKlNGal, NOTARYPUBUC 8IlIOMf1E1.Il BORG.. PERRY COUNTY N .162004 _~~"...!.-l_, , ~'J '. ,~ ~..~" "': "\ SHERIFF'S RETURN In the Court of Common Pleas Of the 41 sl Judicial District of Pennsylvania-Perry Connty Branch First Nationwide Mortgage Corp. vs John O. Osgood 423 Market St. Newport, Pa.17074 NO, 01-3220 George W. Frownfelter, Sheriff, who being duly sworn according to law, says that he made a diligent search and inquiry for the within named Defendant(s) to wit John O. Osgood, but was unable to locate himlher in his bailiwick. He therefore returns Complaint in Mortgage Forclosure NOT FOUND ", as to the within named John O. Osgood at 423 Market St. Newport, Pa. Defendant lives at 52 Catoctin Court, Silver Springs, MD, Sworn and subscribed to before me this day of , 2001. S~J. George W, Frownfelter Sheriff of Perry County ~ , ~H ^',,- l,~ " ~ "< -L',~~ 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, lA" T.....,. ")'~-::;-,:-;,,,-;'1 ,_I,', Ui!~~~~ 'r I /!-Oil~\if' I ~r\ ~"" "~ 1 .,/ . -~-~-----^~_.j I HEREBY CERTIFY THAT THlS IS A TRUf AND CORRECT copy OFlHE ORiGINAL FlLED FIRST NATIONWIDE MORTGAGE CORP. PO Box 9481 Mail Code: 22-528-1011 Gaithersburg, MD 20898-9481 Plaintiff IN THE COURT OF COMMON PLEAS OF CUMBERLAND COUNTY CIVIL ACTION - LAW vs. :ACTION OF MORTGAGE FORECLOSURE JOHN O. OSGOOD AND SUSAN C, OSGOOD (Mortgagor(s)) Term No, ~, JAMES HOOVER AND LINDA HOOVER (Real Owner(s)) 329 15th Street New Cumberland, PA 17070 Defendant(s) CIVIL ACTION: MORTGAGI?' FORECLOSURE : -",~ ( " ) J:;t 01- 3 ? 2-c) ~-~;- ,~-, -~~ '-.,.., , , J 0,.," )> ~-:.; ~:,:~ -< ~,_l Oi '":::- '1'HIS LAW FIRM IS A DEBT COLLECTOR AND WE ARE ATTEMPTING '1'0 COLLECT A DEBT OWED TO OUR CLIENT. ANY INFORMATION OBTAINED FROM YOU WILL BE USED FOR THE PURPOSE OF COLLECTING THE DEBT. :'r-! -< 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 ~ay be entered against you by the Court without further notice for any uloney claimed in the complaint or for any other claim or relief requested hy rhe Plaintiff Vnll m~~ l~~~ money or ~ror~rty rr ^~h~r -ight~ iffi~or~dn~ tu you. YOU SHOULD TAKE THIS PAPER TO YOUR LAWYER AT ONCE. IF YOU DO NOT HAVE A IJ\..WYER OR CANNOT AFFORD ONE, GO TO OR TELEPHONE THE OFFICE SET FORTH BELOW TO FIND OUT WHERE YOU CAN GET LEGAL HELP. Lumberland County Bar Association 2 Liberty Avenue, Carlisle, PA (800) 990-9108 Legal Services Inc. a Irvine Row, Carlisle, PA 17013 (717) 243-9400 A V ISO LE HAN DEMANDADO A liSTED EN LA CORTE. 81 DEBEA DEFENDERBE CONTRA LAS QUEJAS PERESENTADAS, ES ABSOLUTAM8NTE NECESSARIO QUE USTED RESPONDA DENTRO DE 20 DIAS DESPUES DE SER SERVIDO CON ESTA DEMANDA Y AVISO. PARA DEFENDERSE ES NECESSARIO QUE USTED, 0 SU ABOGADO, REGISTRE CON LA CORTE EN FORMA ESCRITA, EL PUNTO DE VISTA DE USTED Y CUALQUIER OBJECCION CONTRA LAS QUEJAS EN ESTA DEMANDA. RECUERDE: SI USTED NO REPONDE A ESTA DEMANDA, SE PUEDE PROSEGUIR CON EL PROCESO SIN SU PARTICIPACION. ENTONCES, LA COUTE PUEDE, SIN NOTIFICARIO, DECIDIR.A FAVOR DEL DEMANDANTE Y REQUERIRA QUE USTED CUMPLA CON TODAS LAS PROVIBIONES DE ESTA DEMANDA. FOR RAZON DE ESA DECISION, ES POSSIBLE QUE USTED PUEDA PERDER DINERO, PROPIEDAD U OTROS n8RECHOS IMPORTANTES. LLEVE ESTA DEMANDA A UN ABOGADO IMMEDIATAMENTE_ 81 NO CONDCE A UN ABOGADO, LLAME AL "LAWYER REFERENCE SERVICE" (SERVICIO DE REFERENCIA DE ABOGADOS), 215238 6300 TRUE COpy FROM RECORD m T~Y \vtWet&i. I 00-", \l!l\(l SlOt my MIlO aM 1M _ ijf ~ Coort at c.vl~. Pi_ <T~g!~~~~~:J~J~__ ~1iCIm'Y Cumberland County Bar Association 2 Liberty Avenue, CarliBle, PA (BOO) 990-910B Legal Services Inc. 8 Irvine Row, Carlisle, (717) 243-9400 PA 17013 ,.- >~- ~ - . ~ -~ . "co<> -------------.-------.- ~_:;:_--;1 \ '"'" n " ' iF \ AT I Ui.'~:a.~~ '11 \ I COP'll COMPLAINT IN MORTGAGE FOREC~~y CERTIFY THAT nus IS A. TRUE AND CORRECT copy 1, plaintiff is FIRST NATIONWIDE MORT~G1!iE&f1.!l'l.t_!ALiS-E2ox 9481, Mail Code: 22-528-1011, Gaithersburg, MD 20898-9481. 2, The name(s) and address(es) of the Defendant(s) is/are JOHN O. OSGOOD, 329 15th Street, New Cumberland, PA 17070 and SUSAN C, OSGOOD, 329 15th Street, New Cumberland, PA 17070, who is/are the mortgagor(s), and JAMES HOOVER, 329 15th Street, New Cumberland, PA 17070, and LINDA HOOVER, 329 15th Street, New Cumberland, PA 17070, who is/are the record owner(s) of the mortgaged property hereinafter described. 3 , On March 27, 1974, mortgagor (s) made, executed and delivered a mortgage upon the premises hereinafter described to ADVANCE MORTGAGE CORP., which mortgage is recorded in the Office of the Recorder of Deeds of Cumberland County in Mortgage Book 575, Page 1071, By Assignment of Mortgage, the mortgage was assigned to Plaintiff, which Assignment is lodged for recording. 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 lS described as attached, 5. The mortgage is in default because monthly payments of principal and interest upon said mortgage due October 1, 2000, and each month thereafter are due and unpaid, and by the terms of said mortgage, upon default in such payments for a period of one month, the entire principal balance and all interest due thereon are collectible forthwith. 6, The following amounts are due on the mortgage: Principal Balance Interest from 9/ 1/00 through 5/31(01 at 8,250% Per diem interest rate at $1,76 Reasonable Attorney's Fee Late Charges 10/ 1/00- 5/31/01 Monthly late charge amount at $17.48 Costs of suit and Title Search $ 7,803.99 478,72 1,000.00 139.84 560,00 $ 9,982,55 429,80 Escrow Balance Deficit Monthly Escrow amount $ $ 10,412,35 7. The Attorney's Fees set forth above are in conformity with the Mortgage documents and pennsylvania law, and, wil.l ~e collected in the event of a third party purchaser at Sherlff s ".~, ' ~ f. ,', -~ 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 nAn. 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 $10,412.35, together with interest at the rate of $1.76, per day and other expenses inrlHTPO by the Plaintiff which are properly chargeable in accordance with the terms of the mortgage, and for the foreclosure and sale of the mortgaged premises, ~oV---- By: GOLDB CK Mc FFERTY & McKEEVER BY: oseph A, Goldbeck, Jr., Esq, Attorney for Plaintiff , .,,',~ , , "',~~. ~" ',0' VERIFICATION I, Dennis Kieft as the representative of the Plaintiff corporation within named do hereby verify that I am authorized to and do make this verification on behalf of the Plaintiff corporation and the facts set forth in the foregoing Complaint are true and correct to the best of my knowledge, information and belief. I understand that false statements therein are made subject to the penalties of 18 Pa. C,S. 4904 relating to unsworn falsification to authorities. Date: ,.5" ],'1 '3 k I - 1 ./ , . ~ I ,. , ! i , ! i " , . , , ,i '. I I ! '~, , , I , ,i i " '\ i ,I ,\ i i , '", ,'; . 'M~""';;'-"~l 1~l;;iW UUllIU<:>;...r.OJlU, \.juullUY WI UU'IIUC;.~ClIIU, OtlU ....uQ"g 1..11 I tlllll;:JY..r.VOll..L~1 . and arant/)1'6. JAMES C. HOOVER and LINDA ,L. HOOVER, hia wife, of Sunbury, Pennsylvaria, Grontee a : WITNESSETH, that in oonsideration of Fi fty One Thouaand ------------------------------ -------($51,ooo.00)-----------------Dolmr~ in hand. paid, tke receipt whereof is hereby acknowledged, the .aid grantors do hereby grant and. convey to tke said grantees, their heirs and assigna, , ' ALL THAT CERTAIN lot, or traGt of land aituate in the Borough of New Cumberlend, County of Cumberlend end State of Pennsylvania, more partiGularly bounded and dssGribed as follows aGGording to a survey of D.P. Raffensperger (49-29) dated MarGh 4, 1974, to wit: .--= BEGINNING at a point on the Northern eide of 15th Street said point being B7o.8 feet west of Bridge Street; thenGe extending along 15th Street South 62 degrees West 50 feet to a Gorner of lot number 3D on the hereinafter mentioned plan of lots; thanGe along lot number 3D north 2B degrees West 195 feet to a point a Gorner; thenGe North 62 dagrees East 50 feet to a point a Gorner; thenGe extending through lot number 31 on said plan South 2B degrees East 195 feet to the point 'and pI aGe of BEGINNING. BEING e part of lot number 31 Section E Plan of Hillside as recorded in the Cumberland County Recorder's Office in Plan Book 1, Page 75. HAVING thereon erected a two story frame dwelling and detachad frama garage known as 329 15th Street. BEING the same premises which Louis N. Kelly end Ruth K. Kelly, his wife, by deed dated March 27, ,1974, and recorded in the Office of the Recorder of Deeds in and for Cumberland County in Deed Book N, Volume 25, Page 1040, granted and conveyed..unto John O. Osgood and Susan C. Osgood, his wife, the Grantors herein. " ..;. THE ABOVE DESCRIBED premises ere conveyed under end eubject to Mortgage to Advance Mortgage Corporation, the unpeid balance of which ie $28,006.02 ~ Dollars which the Grantees assume and agree to pey aGcording to the terms end conditions of said mortgage and aCGompanying bond. ~..g~ .I~~~~# 71/~fi{,~ Cumb, Co" P.. School 0;.1, Cumb, Co" P., :!:"A. Rut E1ht. TUllIS'" 1... -!:!- ~n' t.1h~6 1'UM.{4r Tn "7 --.,_//1 . :;l..!,S~ r'>--?'!... Amt,d;;:::S:'g.q A;7;;;;~:'1i.t?~ o.~~<- j/..~ Curn~ Co. Dht. Col. A,.. ~ C\lrnb. Co. Dhl. Co\. Ag't. ~ \ eoovV28 P^GE 39 .. ...,...'~.~,,'---- U,. ._~___~_~~_ ___ __ ~___ -- __'__ .__..._~.~_,....,.r."._......._"'..___ _~_.__~_. '. . "'"" l'l ,,', ~ ~'.1 ",';"> , ' ',,~, " " ..E r'f/Ol.PlJ57S r;;:H3 O:J-<{o -'13& ~ EXHIBiT A EO, Box 94Bl Gaithersburg. MO 20898.9481 December 22, ~OOO Certified Mail Return Receip Requested James Hoover / 329 15th St New Cumberland PA 17070-1312 RE: Loan No, 6838320381 Dear Mortgagor: Act 91 Notice Take Action to Save Your Home From Foreclosure This is an official notice that the mortgage on your home is in default. and the lender intends to foreclose. Specific information about the nature of the default is provided in the attached pages. The HOMEOWNER'S MORTGAGE ASSISTANCE PROGRAM (HEMAP) may be able to help to save your home. This notice explains how the program works. To see if HEMAP can help. YOU must MEET WITH A CONSUMER CREDIT COUNSELING AGENCY WITHIN 30 DAYS OF THE DATE OF THIS NOTICE. Take this notice with YOU when you meet with the counseling aqency. The name. address. and phone number of the 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 Housinq Finance Agency toll-free at 1-800-342-2397. (Persons with impaired hearing can call (717\780-1869.\ This Notice contains important legal information. If you have any questions. representatives at the Consumer Credit Counseling Agency may be able to help explain it. You may also want to contact 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 su derecho a continuar viviendo en su casa. si no comprende el contenido de esta notification obtenga una traduccion immediatamente ilamanda esta agencia (Pennsylvania Housing Finance Agency) sin cargos al numero mencionada arriba. Puedes ser elegible para un prestamo por el programa llamado "Homeowner's Emergency Mortgage Assistance Program" el cual puede salvar su casa de la perdida del derecho a redimir su hipoteca. DF350-002/COY 5280 Corporate Drive, Frederick, MD 21703 ~, ';..' ~~~>"'i : .. 1ST i .MlmE 'l ) 0\0 l.J 51..S 1 d- Cj :J \jd.'4 () 'fJ P,Q. Box 9491 Gaithersburg. MO 20898-9481 Linda Hoover 329 15th st New Cumberland PA 17070-1312 / December 22. 2000~ Certified Mail~ Return Receipt Requested RE: Loan No. 6838320381 Dear Mortgagor: Act 91 Notice Take Action to Save Your Home From Foreclosure This is an official notice that the mortgage on your home is in default. and the lender intends to foreclose. Specific information about the nature of the default is provided in the attached pages. The HOMEOWNER'S MORTGAGE ASSISTANCE PROGRAM (REMAP) may be able to help to save your home. This notice explains how the program works. To see if REMAP can help. you must MEET WITH A CONSUMER CREDIT COUNSELING AGENCY WITHIN 30 DAYS OF THE DATE OF THIS NOTICE. Take this notice with yOU when YOU meet with the counseling agency. The name. address. and phone number of the Consumer Credit Counseling Agencies serving vourCountv are listed at the end of this Notice. If YOU have any auestions. YOU may call the pennsylvaniaH~using Finance Agency toll-free at 1-800-342-2397. (Persons with impaired hearing can call (717)780-1869.) This Notice contains important legal information. If you have any questions. representatives at the Consumer Credit counseling Agency may be able to help explain it. You may also want to contactcany 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 su derecho a continuar viviendo en su casa. 8i no comprende el contenido de esta notification obtenga una traduccion immediatamente llamanda esta agencia (Pennsylvania Housing Finance Agency) sin cargos al numero mencionada arriba. Puedes ser elegible para un prestamo por el programa llamado "Homeowner's Emergency Mortgage Assistance Program" el cual puede salvar su casa de la perdida del derecho a redimir su hipoteca. DP356-001/COY >;')Ofl f'nmn.."t", nr,,,,, I=rorlprirk- Mn 717n1 '" ~ 'c'" ,_ _ ,'" '. " .' 1ST . . '. NA"n(jNwIDE . ' MJRTGA6E '11 (j<P LJS'l") I d-~) O~yo \t-:?,~ PO Box 9481 Gaithersburg. MO 20898.9481 December 22. 2000 ~ Certified Mail ..../ Return Receipt Requested Susan C. OSgOOd/. 329 15th St New Cumberland, PA 17070 RE: Loan No. 6838320381 Dear Mortgagor: Act 91 Notice Take Action to Save Your This is an offHQm~cFXQmJ~'oQt~~lp~yr~me is in default, and the lender intends to foreclose. Specific information about the nature of the default is provided in the attached pages. The HOMEOWNER'S MORTGAGE ASSISTANCE PROGRAM (HEMAP) may be able to help to save your home. This notice explains how the program works. To see if HEMAP can help, you must MEET WITH A CONSUMER CREDIT COUNSELING AGENCY WITHIN 30 DAYS OF THE DATE OF THIS NOTICE. Take this notice with you when YOU meet with the counseling agency. The name, address, and phone number of the Consumer Credit Counseling Agencies serving your County are listed at the en4 o~ thisNotice~ 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 call (717)780-1869.) This Notice contains important legal information. If you have any questions, representatives at the Consumer Credit Counseling Agency may be able to help explain it, You may also want to contact 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 su derecho a continuar viviendo en su casa. Si no comprende el contenido de esta notification obtenga una traduce ion immediatamente llamanda esta agencia (Pennsylvania Housing Finance Agency) sin cargos al numero mencionada arriba. Puedes ser elegible para un prestamo por el programa llamado "Homeowner's Emergency Mortgage Assistance Program" el cual puede salvar su casa de la perdida del derecho a redimir su hipoteca. DF352-001/COY -', ." ";. ," " " ~'"'' cit"'rr' , . . 1ST '.. NATIONWI. DE , MORTGAGE .~) \ OCp Cj '5 ')5 Id'l::l 6a~ ~3'13 P'Q, Box 94Bl Gaithersburg. MD 20698.9481 December 22. 2000 Certified Mail~ Return Receipt Requested John 0 Osgood ~ 329 15th ST ~ _ New Cumerland. PA 17070 Dear Mortgagor: RE: Loan No. 6838320381 Act 91 Notice Take Action to Save Your This is an offHQ~cFJQijlEQr~~lo~yt:~me is in default. and the lender intends to foreclose. Specific information about the nature of the default is provided in the attached pages. The HOMEOWNER'S MORTGAGE ASSISTANCE PROGRAM (HEMAP) may be able to help to save your home. This notice explains how the program works. To see if HEMAP can help, YOU must MEET WITH A CONSUMER CREDIT COUNSELING AGENCY WITHIN 30 DAYS OF THE DATE OF THIS NOTICE. Take this notice with you when YOU meet with the counselinq aqency. The name, address, and phone number of the Consumer Credit Counseling Agencies ,serVing YOUr County are listed ,.2!. theenlii of this~otic~. If YOU have any questions, YOU may call the Pennsylvania Housinq Finance Agency toll-free, at 1-800-342-2397. (Persons with impaired hearing can call (717)780-1869.) This Notice contains important legal information. If you have any questions, representatives at the Consumer Credit Counseling Agency may be able to help explain it. You may also want to contact 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 su derecho a continuar viviendo en su casa. Si no comprende el contenido de esta notification obtenga una traduce ion immediatamente llamanda esta agencia (Pennsylvania Housing Finance Agency) sin cargos al numero mencionada arriba. puedes ser elegible para un prestamo por el programa llamado "Homeowner's Emergency Mortgage Assistance program" el cual puede salvar su casa de la perdida del derecho a redimir su hipoteca. DF352-001/COY ~"^" ,,______~_ ("\_'h_ C~_.l~.;_~ ~M) ?1"U,. ,-'. ., '. "" .,c ~ > - '",' '. " .~ ' ~, .'-' , " December 22, 2000 Loan No. 6838320381 Page 2 PA Act 91 Homeowner's Name: James Hoover Property Address: 329 15th St New Cumberland PA 17070 Loan Account No.: 6838320381 Original Lender: Advance Mortgage Corporation Current Lender/Servicer: First Nationwide Mortgage 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 HOMEOWNERS' EMERGENCY MORTGAGE ASSISTANCE ACT OF 1983 (THE "ACT"), YOU MAY BE ELIGIBLE FOR EMERGENCY 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 pA~S, 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 J<<EETING,MUSTOCCURWITHIN THE NEXT (30) DAYS. IFWUDO NOT APPLY FOR_~GENCY MORTGAGE ASSISTANCE, YOU MUST BRING YOUR MORNAGE '1lO, DATE. THE p~T OF THIS NOTICE CALLED "HOW TO CURE YOUR MORTGAGE DE~AULT," EXPLA:t~S HOw TO BRING YOUR MORTGAGE UP TO DATE. DF353~001/COY ""~' " -, ~~. _.,~. December 22. 2000 Loan No. 6838320381 Page 3 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 the designated consumer credit counseling agencies for 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. APPLICATIONS 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 resolve this problem with the lender, you have the right to apply for financial assistance from the Homeowner's Emergency Mortgage Assistance Program. To do so, you must fill out, sign and file completed Homeowners' Emergency Mortgage Assistance Program Application with one of the designated consumer credit counseling agencies listed at the end of this Notice. Only consumer credit counseling agencies have applications for the program and they will assist you in sUbmitting a complete application to the pennsylvania Housing Finance Agency. Your application MUST be filed or postmarked within thirty (30) days of your face-to-face meeting, YOU MUST FILE YOUR APPLICATION PROMPTLY. IF YOU FAIL TO DO SO OR IF YOU DO NOT FOLLOW THE OTHER TIME PERIODS 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 eligi- bility criteria established by the Act. The Pennsylvania Housing DF353-001/COY ~',,,t ~ ' !', ) "---, " December 22, 2000 Loan No. 6838320381 Page 4 PA Act 91 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, TH~ FOLLOWING PART OF THIS IS FOR INFORMATION PURPOSES ONLY AND SHOULD NOT BE CONSIDERED AS AN ATTEMPT TO COLLECT THE DEBT. (If you have filed bankruptcy you can still apply for Emergency Mortgage Assistance.) 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: 329 15th St New Cumberland PA 17070 IS SERIOUSLY IN DEFAULT because: YOU HAVE NOT MADE YOUR MONTHLY MORTGAGE PAYMENTS for the following months and the following amounts are now past due: 1 Months at $349.79 = 349. 79 ~ 1 Months at $442.04 = 442.04 ,/ ./ 1 Months at $356.37 = 356.37/ Late Charges 87.89 Bad Check Fees .00 Foreclosure Fees .00 Bankruptcy Fees .00 Other Fees / 7.00 Less Suspense Balance __ .00 TOTAL AMOUNT DUE V 1,243.09 AS OF THIS DATE HOW TO CURE THE DEFAULT - y~u ~a,y cure the default Wi,t,hin T~Il~ (30) DAYS of the date of this not'ce BY PAYING THE TOTAL AMOUNT PAST DUE TO THE LENDER WHICH IS $ 1, 43.09 PLUS ANY MORTGAGE PAYMENTS AND LATE CHARGES WHICH BECOME DUE DURING THE THIRTY (30) DAY PERIOD. Payments must be made either by cash, caShier's check, certified check, or money order made payable and sent to: First Nationwide Mortgage Corporation Dept. 0107 palatine, IL 60055-0107 DF354-001/COY .x ,~ ',l '"' -,,'1--'_,' -, --- ,,~,~', ~",~ '~~::J . 'Po .. December 22, 2000 Loan No. 6838320381 Page 5 PA Act 91 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 attor- neys to start legal action to foreclose upon your mortgaged property. IF TH~ 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 lende~ 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 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. DF354-001/COY ;1, -,'-,'",,-, ~ . . . . December 22, 2000 Loan No. 6838320381 Page 6 PA Act 9 aIGHT TO CURE THE DEFAULT PRIOR THE SHERIFF'S SALE - If you have not cured the default within the THIRTY (30) DAY period and foreclosure proceedings have begun, you still have the 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 cost connected with the foreclosure sale and other cost 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 lIlannerset forth in this notice will restore your mortgage to the same ~osition 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 mqrtgage property could be held would be approximately 6 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. HOW TO CONTACT THE LENDER: First Nationwide Mortaage Corporation 5280 Corporate Drive Frederick, MD 21703 Department 252 1-800-888-4333 EFFECT OF THE SHERIFF'S SALE - You should realize that the 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, UPON OUR CONSENT may sell or transfer your home to a buyer or transferee who will assume the mortgage debt, provided that all the outstanding payments, charges and attorney's fees and costs are paid prior to or at the sale and that the other requirements of the mortgage are satisfied. 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. DF355-001/COY . "~ . L ~. '_J ',-, ,,--,' , .... ;', ~ ." ,'" , ;', ,1:1 , , RECEIPT FOR PAYMENT =================== Cumberland County Prothonotary's Office Carlisle, Pa 17013 Rece~pt Date Rece:j.pt Time Rece~pt No, 5/25/2001 16:13:36 112088 FIRST NATIONWIDE MORTGAGE CORP (VS) OSGOOD JOHN 0 ET AL Case Number 2001-03220 Received of PD ATTY JOSEPH A GOLDBECK JR JHS Total Check.,. + Total Cash.." + Change..".,.. - Receipt total, = 45.50 ,00 .00 45.50 Check No. 140630 ------------------------ Distribution Of Payment ---------------------------- Transaction Description Payment Amount COMPLAINT TAX ON CMPLT SETTLEMENT JCP FEE 35,00 ,50 5.00 5,00 CUMBERLAND CO GENERAL FUND BUREAU OF RECEIPTS AND CONTROL CUMBERLAND CO GENERAL FUND BUREAU OF RECEIPTS AND CONTROL 45.50 :#.:M~_~ ''!!'.!iiI\\f~hihll~"W' . ;Wfl,!'h'Il~J!tiM~~'ok<""p)~"i1,~,,d,._"'Ac...",,;1,, ,:'lmct-\!;~M~Y;gji;iliiilli~;tlmr ~~illlm ' ~'-lIInlilL.J'dd. &S j:P' 0) I U, .:::) "'" - Q ;; ~, ::r~ cC L':..; ~::\_>_. /-d.-. ':..;. ,J.!_;~, ~~i 55'- v;Q. \lIN\J'.1- ..,,'. ,i) 10, .tl",~ 44' "'tee ' 1I]I-/S ~,- ~,""',,-'''''<='''' -~. :::-' ~ I ." (j':'J':I ., ".::J j "".-., { (iF f: 9Z tr :" J"~ -1-:"; '_",n,J'a "',)1"'/0 .~ ~ -" ~ ""'~ 'fir . ~lIi1l.rii::k.2.ti' -", . , ,-,,~-'" ~,' k_ "~ .;,,,,_ A'_' -< ;' "'~'l1(~11.i' " GOLDBECK McCAFFERTY BY: Joseph A, Goldbeck, Attorney I,D.#16132 Suite 500 - The Bourse Bldg, III S, Independence Mall East Philadelphia, PA 19106 215-627-1322 Attorney for Plaintiff & McKEEVER Jr. FIRST NATIONWIDE MORTGAGE CORP. PO Box 9481 Mail Code: 22-528-1011 Gaithersburg, MD 20898-9481 Plaintiff IN THE COURT OF COMMON PLEAS OF CUMBERLAND COUNTY CIVIL ACTION - LAW vs, :ACTION OF MORTGAGE FORECLOSURE JOHN 0, OSGOOD AND SUSAN C, OSGOOD (Mortgagor(s)) Term No. JAMES HOOVER AND LINDA HOOVER (Real Owner(s)) 329 15th Street New Cumberland, PA 17070 Defendant(s) CIVIL ACTION: MOliTGAGE FORECLOSURE Jj 01 - 31i-o ~ THIS LAW FIRM IS A DEBT COLLECTOR AND WE ARE ATTEMPTING TO COLLECT A DEBT OWED TO OUR CLIENT. ANY INFORMATION OBTAINED FROM YOU WILL BE USED FOR THE PURPOSE OF COLLECTING THE DEBT. NOTICE You have been sued in court. If you wish to defend against the claims set forth in the following pages, you must take action within twenty (20) days after the Complaint and notice are served, by entering a written appearance personally or by attorney and filing in writing with the court your defenses or objections to the claims set forth against you. You are warned that if you fail to do so the case may proceed without you and a judgment may be entered against you by the Court without further notice for any money claimed in the Complaint or for any other claim or relief requested by the Plaintiff, You may lose money or property or other rights important to you. YOU SHOULD TAKE THIS PAPER TO YOUR LAWYER AT ONCE. IF YOU DO NOT HAVE A LAWYER OR CANNOT AFFORD ONE, GO TO OR TELEPHONE THE OFFICE SET FORTH BELOW TO FIND OUT WHERE YOU CAN GET LEGAL HELP. Cumberland County Bar Association 2 Liberty Avenue, Carlisle, PA (800) 990-9108 Legal Services Inc. 8 Irvine Row, Carlisle, PA 17013 (711) 243-9400 A V I 8 0 LE BAN DEMANDADO A USTED EN LA CORTE. SI DESEA DEFENDERSE CONTRA LAS QUEJAS PERESENTADAS, ES ABSOLUTAMENTE NECESSARIO QUE USTED RESPDNDA 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 E8CRITA, EL PUNTO DE VISTA DE USTED Y CUALQUIER OBJECCION CONTRA LAS QUEJAS EN ESTA DEMANDA. RECtfERDE: 81 USTED NO REPONDE A ESTA DEMANDA, SE PUEDE PROSEGUIR CON EL PROCESO SIN SU PARTICIPACION. ENTONCES, LA COUTE PUEDE, SIN NOTIFICARIO, DECIDIR A FAVOR DEL DEMANDANTE Y REQUERlRA 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. LLEVE ESTA DEMANDA A UN ABOGADO IMMEDIATAMENTE, SI :NO CONDCE A UN ABOGADO, LLAME AL "LAWYER REFERENCE SERVICE" (SERVICIO DE REFERENCIA DE ABOGADOS), 215 238-6300, Cumberland County Bar Association 2 Liberty Avenue, Carlisle, PA (800) 990-9108 Leg~l Services Inc. 8 I~vine Row, carlisle, PA 17013 (71"1) 243-9400 , ",~ t- , -~ COMPLAINT IN MORTGAGE FORECLOSURE 1. Plaintiff is FIRST NATIONWIDE MORTGAGE CORP" PO Box 9481, Mail Code: 22-528-1011, Gaithersburg, MD 20898-9481. 2, The name(s) and address(es) of the Defendant(s) is/are JOHN O. OSGOOD, 329 15th Street, New Cumberland, PA 17070 and SUSAN C, OSGOOD, 329 15th Street, New Cumberland, PA 17070, who is/are the mortgagor(s), and JAMES HOOVER, 329 15th Street, New Cumberland, PA 17070, and LINDA HOOVER, 329 15th Street, New Cumberland, PA 17070, who is/are the record owner(s) of the mortgaged property hereinafter described, 3, On March 27, 1974, mortgagor(s) made, executed and delivered a mortgage upon the premises hereinafter described to ADVANCE MORTGAGE CORP" which mortgage is recorded in the Office of the Recorder of Deeds of Cumberland County in Mortgage Book 575, Page 1071. By Assignment of Mortgage, the mortgage was assigned to plaintiff, which Assignment is lodged for recording, These documents are matters of public record and are incorporated herein by reference in accordance with Pennsylvania Rule of Civil Procedure 1019(g), 4, The premises subject to said mortgage is described as attached. 5, The mortgage is in default because monthly payments of principal and interest upon said mortgage due October 1, 2000, and each month thereafter are due and unpaid, and by the terms of said mortgage, upon default in such payments for a period of one month, the entire principal balance and all interest due thereon are collectible forthwith, 6. The following amounts are due on the mortgage: Principal Balance Interest from 9/ 1/00 through 5/31/01 at 8,250% Per diem interest rate at $1,76 Reasonable Attorney's Fee Late Charges 10/ 1/00- 5/31/01 Monthly late charge amount at $17.48 Costs of suit and Title Search $ 7,803.99 478,72 1,000.00 139.84 560,00 $ 9,982,55 429.80 Escrow Balance Deficit Monthly Escrow amount $ $ 10,412.35 7. The Attorney's Fees set forth above are in conformity with the Mortgage documents and Pennsylvania law, and, will be collected in the event of a third party purchaser at Sheriff's . . ~- ';;,'~ "" . Sale. If the Mortgage is reinstated prior to the Sale reasonable Attorney's Fees will be charged 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 $10,412.35, together with interest at the rate of $1.76, per day and other expenses incurred by the Plaintiff which are properly chargeable in accordance with the terms of the mortgage, and for the foreclosure and sale of the mortgaged premises, By: ~oJ-A- GOLDB CK Mc FFERTY & McKEEVER BY: oseph A, Goldbeck, Jr., Esq. Attorney for Plaintiff -"'''' -~ ~~~ - "'c_;,,_; VERIFICATION I, Dennis Kieft , as the representative of the Plaintiff corporation within named do hereby verify that I am authorized to and do make this verification on behalf of the Plaintiff corporation and the facts set forth in the foregoing Complaint are true and correct to the best of my knowledge, information and belief. I understand that false statements therein are made subject to the penalties of 18 Pa. C.B, 4904 relating to unsworn falsification to authorities. Date:, r J()3 h, ') i I ./ I I 'I 1 '1 1 i .- " '. 'I J I , i '- , , " I ,; I " 'j ~ i ,I i j 'j i . 1\lt:llJ l..oUlIIUI::l.L';ii:ll IU ~ 1./UUIIl.oY U I _1' I l..oUIIIUt;::.L'.i:i:lIIU, t1l1U Oloi:llotl' Ul _ c~,"""",j~,>.,',~_,kj"_,,,~ 0,:"", '" r-tI'lII I::JYJ.Vt1IIJ.t:I, ~.N_ ~\i . lhanttwB , and JAMES C. HOOVER and LINDA ,L. HOOVER, his wifa, of Sunbury, Pennsylvafl1a, Grantee a : WITNESSETH, that in consideration of Fifty One Thousand ------------------------------ -------($51,OOO.00)-----------------Dolmr~ in hand paid, the receipt whereof is hereby acknowledged, the said urant01's do hereby gr<IJnt and convey to t~e said grantee s, their hairs and assigns, ALL THAT CERTAIN lot, or tract of land situate in the Borough of New Cumberland, County of Cumberland and Stata of Pennsylvania, more particularly bounded and described as follows according to a survey of D.P. Raffensperger (49-29) dated March 4, 1974, to wit: BEG,INNING at a point on the Northern aide of 15th Street said point being 870.B feet west of Bridge Street; thence extending elong 15th Street South 62 degrees West 50 feet to a corner of lot number 30 on the hereinafter mentioned plan of lots; thence along lot number 30 north 2B degreas West 195 feet to a point a corner; thence North 62 degrees East 50 feet to a point a corner; thence extending through lot number 31 on said plan South 2B degrees East 195 feet to the point and placa of BEGINNING. BEING a part of lot number 31 Section E Plan of Hillside as recorded in the Cumberland County Recorder's Offica in Plan Book 1, Page 75. HAVING thereon eracted a two story frame dwelling and detached frame garege known as 329 15th Street. BEING the same premises which Louis N. Kelly and Ruth K. Kelly, his wife, by deed dated March 27, ,1974, and recorded in the Office of the Recorder of Deeds in end for Cumberland County in Deed Book N, Volume 25, Page 1040, granted and conveyed..!,mto John O. Osgood and Susan C. Osgood, his wife, the Grantors herein. " TH' ABOVE DESCRIBED premises are conveyed under and subject to Mortgage to Advance Mortgage Corporation, the unpaid balance of which is $2B,006.02 ~ Dollars which the Grantees assume and agree to pay according to the terms and conditions of said mortgage and accompanying bond. o .....gfi .?b:.~-:.~~ 7(/JP,~ Cumb, Co., Po. ' Sohool Di,l. Cumbo Co., Po, ~ Real ~tatll Trud., Tn ~ Real Estate Tran,f.r TAIl , d-.'>- - 0(/ O '7 -~.77 d...i,-:S'~ 7~...-7[ AmI, ....~:"'-" (;=;;j;:::;::"7i.~~ D~~,- If'~ Cum~ Co. Oisl. Col. Agt, ~ _ C\lmb. Co. Dist. Col. A,t. , \ 6Oor/V'28 P^GE 39 --.--"------.-.--,--.---.-.- ..- --_..,.,- -,. ~...__._~---- - --.-,,-~--.....,,~_...~.~..._~- -".... '"'""'~ ~' '"~^'" .. :'TIONWlDE , ...........,A~ ' IVIUrllllMlJl: 'lIOlftJ.i57S 1";;/13 Od.-<.{Q ~8& ~ EXHIBiT A P'Q, Box 9481 Gaithersburg. MD 20696-9481 December 22, 2~OO Certified Mail Return Receip Requested James Hoover / 329 15th St New Cumberland PA 17070-1312 RE: Loan No. 6838320381 Dear Mortgagor: Act 91 Notice Take Action to Save Your Home From Foreclosure This is an official notice that the mortqage on your home is in default, and the lender intends to foreclose. Specific information about the nature of the default is provided in the attached pages. The HOMEOWNER'S MORTGAGE ASSISTANCE PROGRAM (HEMAP) maybe able to help to save your home. This notice explains how the program works. To see if HEMAP can help. yOU must MEET WITH A CONSUMER CREDIT COUNSELING AGENCY WITHIN 30 DAYS OF THE DATE OF TRIS ,NOTICE. Take this notice with yOU when YOU meet with the counSelinq agency. The name, address, and phone number of the Consumer Credit Counselinq Agencies servinq vour County are listed at the end of this, Notice. If YOU have any questions, youIilay call the PennsvlvaniaHous1ng F1nance Agency ,toll-free, at 1-,800-342-2397. (Persons with impaired hearing can call (717)780-1869.) This Notice contains important legal information. If you have any questions, representatives at the Consumer Credit Counseling Agency may be able to help explain it. You may also want to contact 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 su derecho a continuar viviendo en su casa. 8i no comprende el contenido de esta notification obtenga una traduccion immediatamente llamanda esta agencia (Pennsylvania Housing Finance Agency) sin cargos al numero mencionada arriba. puedes ger elegible para un prestamo per el programa llamado "Homeowner's Emergency Mortgage Assistance ' Program" el cual puede salvar su casa de la perdida del derecho a redimir su hipoteca. DF350-002/COY 5280 Corporate Drive. Frederick. MD 21703 '" . , ~ - - - ~ -'" .. .... . ~.nONWIDE .. MORTGAGE 'l ) 0\0 l./)" 1"-5' 1 d- ~ :J \ja'-l 0 "fJ P.O, Box 9481 Gaithersburg. MO 2089B,94B1 Linda Hoover 329 15th St New Cumberland PA 17070-1312 / December 22. 2000~ Certified Mail(.../"'" Return Receipt Requested RE: Loan No. 6838320381 Dear Mortgagor: Act 91 Notice Take Action to Save Your Home From Foreclosure This is an official notice that the mortgage on your home is in default, and the lender intends to foreclose. Specific information about the nature of the default is provided in the attached pages, The HOMEOWNER'S MORTGAGE ASSISTANCE PROGRAM (HEMAPl may be able to help to save your home. This notice explains how the proaram 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 with YOU when YOU meet with the counse11nQ agency. The name. address, and phone number of the Consumer Credit Counseling Agencies servinq 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 hearina can call (717}780-1869.) This Notice contains important legal information. If you have any questions. representatives at the Consumer Credit Counseling Agency may be able to help explain it. You may also want to contact 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 su derecho a continuar viviendo en su casa. Si no comprende el contenido de esta notification obtenga una traducc10n irnmediatamente llamanda esta agencia (Pennsylvania Housing Finance Agency) sin cargos al numero mencionada arriba. Puedes ser elegible para un prestamo por el programa llamado "Homeowner's Emergency Mortgage Assistance Program" el cual pUede salvar su casa de la perdida del derecho a redimir su hipoteca. DF356-001/COY J;:?M I'n"v""~D Or;"" J:rMMi"J.o Mfl ?17n.1 J~~ .'. J~ '. ~ ~. :!i.J '..DE I) D<P lIS'1-) I )~) O~yo 'J'14 PO, Box 9481 Gaithersburg. MO 20898-9481 December 22, 2000 ~ Certified Mail ...-'" Return Receipt Requested Susan C. Osgood ~ 329 15th St -"... New Cumberland, PA 17070 RE: Loan No. 6838320381 Dear Mortgagor: Act 91 Notice Take Action to Save Your This is an offllQmkcFiQIlla:toQ{,~lP~oyr~me is in default, and the lender intends to foreclose. Specific information about the nature of the default is provided in the attached pages. The HOMEOWNER'S MORTGAGE ASSISTANCE PROGRAM (HEMAP) may be able to help to save your home. This notice explains how the proqram 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 with yOU when YOU meet with the counseling a4ency. The name, address, and phone number of the Consumer Credit Counselinq Agencies servinq 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 1-8.00-342-2397. (Persons with impaired hearing can call (717)780-1869.) This Notice contains important legal information. If you have any questions, representatives at the Consumer Credit Counseling Agency may be able to help explain it. You may also want to contact 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 su derecho a continuar viviendo en su casa. Si no comprende el contenido de esta notification obtenga una traduccion immediatamente llamanda esta agencia (Pennsylvania Housing Finance Agency) sin cargos al numero mencionada arriba. Puedes ser elegible para un prestamo por el programa llamado "Homeowner's Emergency Mortgage Assistance Program" el cual puede salvar su casa de la perdida del derecho a redimir su hipoteca. DF352-001/COY .' , ' 'ti";" .' 1ST , NATIONWIDE , MORTGAGE '-) \ OCp Cj'S "5 Id9:) (Jdl.{J) ~3'l3 P.O, Box 9481 Gaithersburg, MO 20898,9481 December 22. 2000 Certified Mail~ Return Receipt Requested John 0 Osgood ~ 329 15th 5T ~ ' New Cumerland. PA 17070 RE: Loan No. 6838320381 Dear Mortgagor: Act 91 Notice Take Action to Save Your This is an offtwmecfxQWe EQr.eplo~Y~~me is in default. and the lender intends to foreclose. Specific infomation about the nature of the default is provided in the attached pages. The HOMEOWNER'S MORTGAGE ASSISTANCE PROGRAM (HEMAP) may be able to help to save your home. This notice explains how the program works. To see if REMAP can help, yOU must MEET WITH A CONSUMER CREDIT COUNSELING AGENCY WITHIN 30 DAYS OF THE DATE OF THIS NOTICE. Take this notice with you when yOU meet with the counseling agency. The name, address. and phone number of the 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 liousing Finance Aqency toll-free at 1-800-342-2397. (Persons with impaired hearing can call (717) 780-1869.) This Notice contains important legal infomation. 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 su derecho a continuar viviendo en su casa. Si no comprende el contenido de esta notification obtenga una traduccion immediatamente llamanda esta agencia (pennsylvania Housing Finance Agency) sin cargos al numero mencionada arriba. Puedes ser elegible para un prestamo por el programa llamado "Homeowner's Emergency Mortgage Assistance program" el cual puede salvar su casa de la perdida del derecho a redimir su hipoteca. DF352-001/COY ~........... "u____~~ ...._:.._ r-._..I~.:~L ~An ?1"1n':l ,-.,' 0' ,:_" o._"""".",;;".~ December 22, 2000 Loan No, 6838320381 Page 2 PA Act 91 Homeowner's Name: James Hoover Property Address: 329 15th St New Cumberland PA 17070 Loan Account No.: 6838320381 Original Lender: Advance Mortgage Corporation Current Lender/Servicer: First Nationwide Mortgage HOMEOWNER'S EMERGENCY MORTGAGE ASSISTANCE PROGRAM YOU MAY BE ELIGIBLE FOR FINANCIAL ASSISTANCE WHICH CAN SAVE YO'URHOME FROM FORECLOSUaEAND HELP YOU. MAKE FUTURE MORTGAGE PAYMENTS IF YOU COMPLY WITH THE PROVISIONS OF THE HOMEOWNERS' EMERGENCY MORTGAGE ASSISTANCE ACT OF 1983 (THE "ACT"), YOU MAY BE ELIGIBLE FOR EMERGENCY 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. THISBETXWO MUST.OCCUR WITHIN THE NEXT (30) DAYS. IF.YOlJ.DO NOT APPLY FOR~ft~MORTGAGE ASSiSTANCE, YOU HUST B~}NGV~~<,~&9!~T.Q , DATE. THE P_T. OF, THrB NOT!CE CALLED nHOWTO CURE. YOUR MORNAlGEDEFAUL'1' , n EXPLAINS HOW TOBRIifG 'lOtJRMORTGAGE UP '1'0 DATE. DF353-001/COY ," -'1-.'.':" ", < ~ ), " ""'" ' ~ ',,",1', " , """'-- ,. December 22, 2000 Loan No. 6838320381 Page 3 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 the designated consumer credit counseling agencies for 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. APPLICATIONS 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 resolve this problem with the lender, you have the right to apply for financial assistance from the Homeowner's Emergency Mortgage Assistance Program. To do so, you must fill out. sign and file completed Homeowners' Emergency Mortgage Assistance Program Application with one of the designated consumer credit counseling agenCies listed at the end of this Notice. only consumer credit counseling agencies have applications for the program and they will assist you in submitting a complete application to the Pennsylvania Housing Finance Agency. Your application MUST be filed or postmarked within thirty (30) days of your face-to-face meeting. YOU MUST FILE YOUR APPLICATION PROMPTLY. IF YOU FAIL TO DO SO OR IF YOU DO NOT FOLLOW THE OTHER TIME PERIODS SET FORTH IN THIS LETTER. FORECLOSURE MAY PROCEED AGAINST YOUR HOME IMMEDIATELY AND YOUR APPLICATION FOR MORTCAGE ASSISTANCE WILL BE DENIED. AGENCY ACTION: Available funds for emergency mortgage assistance are very limited. They will be disbursed by the Agency under the eligi- bility criteria established by the Act. The Pennsylvania Housing DF353-001/COY December. 22. 2000 Loan No. 6838320381 Page 4 PA Act 91 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 IS FOR INFORMATION PURPOSES ONLY AND SHOULD NOT BE CONSIDERED AS AN ATTEMPT TO COLLECT THE DEBT. (If you have filed bankruptcy you can still apply for Emergency Mortgage Assistance.) HOW TO CURE YOUR MORTGAGE DBFAULT (Bring it UP to elate) NATURE OF THE DEFAULT - The MORTGAGE debt held by the above lender on your property located at: 329 15th St New Cumberland PA 17070 IS SERIOUSLY IN DEFAULT because: YOU HAVE NOT MADE YOUR MONTHLY MORTGAGE PAYMENTS for the following months and the following amounts are now past due: 1 Months at $349.79 = 349. 79 ~ 1 Months at $442.04 = 442.04 0./ ./ 1 Months at $356.37 = 356.37 ./' Late Charges 87,89 Bad Check Fees .00 Foreclosure Fees .00 Bankruptcy Fees .00 Other Fees / 7.00 Less Suspense Balance __ .00 TOTAL AMOUNT DUE V 1.243.09 AS OF THIS DATE HOW TO CURE THE DEFAULT - Y*u ~ay cure th.e default within THIRTY (30) DAYS of the date of this not ce BY PAYING THE TOTAL AMOUNT PAST DUE TO THE LENDER WHICH IS $ 1, 43.09 PLUS ANY MORTGAGE PAYMENTS AND LATE CHARGES WHICH BECOME DUE DURING THE THIRTY (30) DAY PERIOD. Payments must be made either bv cash, cashier's check, certified check. or monev order made payable and sent to: First Nationwide Mortgage Corporation Dept. 0107 Palatine, XL 60055-0107 DF354-001/COY "'.........,~ 'I: ~ I 'Ii'" "1lI'JfiMny'J December 22, 2000 Loan No. 6838320381 Page 5 FA Act 91 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 riahts to accelerate the mortaaae 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 attor- neys to start legal action to foreclose upon your mortaaaed 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 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. DF354-001/COY ,;..~"-.... ., . ,,' <,,- ,.'. . December 22, 2000 Loan No. 6838320381 Page 6 PA Act 9 RIGHT TO CURE THE DEFAULT PRIOR THE SHERIFF'S SALE - If you have not cured the default within the THIRTY (30) DAY period and foreclosure proceedings have begun, YOU still have the 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 paving the total amount then past due, plus any late or other charges then due. reasonable attornev's fees and cost connected with the foreclosure sale and other cost.connec:ted with the Sheriff's Sale as specified in writing bv 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 mortgage property could be held would be approximately 6 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. HOW TO CONTACT THE LENDER: First Nationwide Mortgage Corporation 5280 Corporate Drive Frederick, 10) 21703 Department. '252 1-800-888-4333 EFFECT OF THE SHERIFF'S SALE - You should realize that the 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, UPON OUR CONSENT may sell or transfer your home to a buyer or transferee who will assume the mortgage debt, provided that all the outstanding payments, charges and attorney's fees and costs are paid prior to or at the sale and that the other requirements of the mortgage are satisfied. 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. DF355-001/COY Mi~~~~'-" Ju.UlhIW~ltJ~ -0l::r;;r%1,j'~-"';;;11ti;i!!il'\",#j;,~H~~..dWJl is\6f .U,{lJ!llIll1 .~",~, ,~.<= "'~~'" ", ' ,," . ~"" ">""" ~~ '" l"""j~",:,,~ Ji:>JiliHa ~ ^ .);:::, ~~ ~ -- -- 'iL is: ~ -- ~ ~ cJ: ~ ~ '"'-' ~ -, '^' ~. ~) ~ C>~ <J'o, ' \ <:::: ~ , .",,~"=, -, " ',~ ..,. " , " " ~ ~" ~ .0' ~ ="'~hlli;j;' . ~ r' c::: i~ Ci :s: ~','''' _..~ .' .~" :"-,) <.J: c_~ '71 .' (~ (5 ill :::;-1 ~ .1,.. :;';.3 .,' =2 ~Jl (Jl . ",~~b\,w~ "~ ,". ...... ~ ~~'~" ~~lltl.i1l.' """"""~~,,-,;,i 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 ,J ~~EfJl CERTIFY THAT THIS OF..... AND CORRECT COPy onE ORiGWAL FlLEO FIRST NATIONWIDE MORTGAGE CORP. PO Box 9481 Mail Code: 22-528-1011 Gaithersburg, MD 20898-9481 Plaintiff IN THE COURT OF COMMON PLEAS OF CUMBERLAND COUNTY CIVIL ACTION - LAW vs, :ACTION OF MORTGAGE FORECLOSURE JOHN 0, OSGOOD AND SUSAN C, OSGOOD (Mortgagor(s)) Term No, JAMES HOOVER AND LINDA HOOVER (Real Owner(s)) 329 15th Street New Cumberland, PA 17070 Defendant(s) CIVIL ACTION: MOHTGAGE FORECLOSURE -tI ()/- 3'LLcJ {iM.I-~ 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 ~ction within twenty (20) days after the Complaint and notice are served, by entering a written appearance personally or by attorney and filing in writing with the court your defenses or objections to the claims set forth against you. You are warned that if you fail to do so the case may proceed without you and a judgment may be entered against you by the Court without further notice for any money claimed in the Complaint or for any other claim or relief requested by the Plaintiff. You may lose money or property or other rights important to you. YOU SHOULD TAKE THIS PAPER TO YOUR LAWYER AT ONCE. IF YOU DO NOT HAVE A LAWY!i:R OR CANNOT AFFORD ONE, GO TO OR TELEPHONE THE OFFICE SET FORTH BELOW TO FIND OUT WHERE YOU CAN GET LEGAL HELP. _.J CUmberland County Bar Association 2 Liberty Avenue, Carlisle, PA (800) 990-9108 Legal Services Inc. 8 Irvine Row, Carlisle, PA 17013 (717) 243-9400 A V ISO LE RAN DEMANDADO A U8TED EN LA, CORTE. 81 DESEA DEFENDER8E CONTRA LAS QUEJAS PERESENTADA8, ES ABS01UTAM,ENTE NECESSARIO QUE DSTED RESPONDA DENTRO DE 20 DrAS DESPlJES DE SER SERVIDO CON ESTA DEMANDA Y AVISO. PARA DEFENDERSE ES NECESSARIO QUE USTED, 0 SU ABOGADO, REGISTRE CON LA CORTE EN FORMA ESCRITA, EL PUNTO DE VISTA DE USTED Y CUALQUIER OBJECCION CONTRA LAS QUEJAS EN ESTA DEMANDA. RECUERDE: SI USTED NO REPONDE A ESTA DEMANDA, BE PUEDE PROSEGUIR CON EL PROCESO SIN SU PARTIC1PACION. ENTONCES, LA COUTE PUEDE, SIN NOTIFlCARIO, DECIDIR A FAVOR DEL DEM1INDANTE Y RE:QUERlRA 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. LLEVE ESTA DEMANDA A UN ABOGADO IMMEDIATAMENTE. Cumberland County Bar Association 2 Liberty Avenue, Carlisle, PA (800) 990-9108 "LAWYER REFERENCE SERVICE" (SERVICIO DE REFERENCIA DE ABOGADOS) , In~E COPY FROM RECORD and ~. Whe~. I here unto set my hand r . ~ot saId Cood at CarliSle Pa ^ d y, 01 '~I It ~ c::x......V(rprorn .~ 81 NO CONOCE A UN ABOGADO, LLAME AL 215-238-6300. Legal Services Inc. a Irvine Row, Carlisle, PA 17013 (717) 243-9400 "'~-~ , ~~ ~ IIl:Lllli."~~~, I HEREBY CERTIFY THAT T~ IS A TRUE MID CORRECT COPy OF THE ORIGINAL FIlED COMPLAINT IN MORTGAGE FORECLOSURE 1. Plaintiff is FIRST NATIONWIDE MORTGAGE CORP" PO Box 9481, Mail Code: 22-528-1011, Gaithersburg, MD 20898-9481. 2. The name(s) and address(es) of the Defendant(s) is/are JOHN O. OSGOOD, 329 15th Street, New Cumberland, PA 17070 and SUSAN C, OSGOOD, 329 15th Street, New Cumberland, PA 17070, who is/are the mortgagor(s), and JAMES HOOVER, 329 15th Street, New Cumberland, PA 17070, and LINDA HOOVER, 329 15th Street, New Cumberland, PA 17070, who is/are the record owner (s) of the mortgaged property hereinafter described. 3 . On March 27, 1974, mortgagor (s) made, execut.ed and delivered a mortgage upon the premises hereinafter described to ADVANCE MORTGAGE CORP., which mortgage is recorded in the Office of the Recorder of Deeds of Cumberland County in Mortgage Book 575, Page 1071. By Assignment of Mortgage, the mortgage was assigned to Plaintiff, which Assignment is lodged for recording. These documents are matters of public record and are incorporated herein by reference in accordance with pennsylvania Rule of civil Procedure 1019(g). 4. The premises subject to said mortgage is described as attached. 5, The mortgage is in default because monthly payments of principal and interest upon said mortgage due October 1, 2000, and each month thereafter are due and unpaid, and by the terms of said mortgage, upon default in such payments for a period of one month, the entire principal balance and all interest due thereon are collectible forthwith. 6. The following amounts are due on the mortgage: Principal Balance Interest from 9/ 1/00 through 5/31/01 at 8,250% Per diem interest rate at $1,76 Reasonable Attorney's Fee Late Charges 10/ 1/00- 5/31/01 Monthly late charge amount at $17,48 Costs of suit and Title Search $ 7,803.99 478,72 1,000.00 139,84 560,00 $ 9,982,55 429,80 Escrow Balance Deficit Monthly Escrow amount $ $ 10,412.35 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 ~ ~ '"'" ~ l' ~, 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 $10,412.35, together with interest at the rate of $1.76, per day and other expenses incurred by the Plaintiff which are properly chargeable in accordance with the terms of the mortgage, and for the foreclosure and sale of the mortgaged premises, By: ~oV----- GOLDB CK Me- FFERTY & McKEEVER BY: oseph A. Goldbeck, Jr" Esq. Attorney for Plaintiff ,"_<l'~.'-'.__ ., .. ~< " - ""~ , ~.;,.. Lit, VERIFICATION I, Dennis Kieft , as the representative of the Plaintiff corporation within named do hereby verify that I am authorized to and do make this verification on behalf of the Plaintiff corporation and the facts set forth in the foregoing Complaint are true and correct to the best of my knowledge, information and belief. I understand that false statements. therein are made subject to the penalties of 18 Pa. C,S. 4904 relating to unsworn falsification to authorities. Date :" ]:1'3 k I h'<ill~"",~~-'~" O' d'''''__' " ~ '''''_.'_ , I~OW I..lUIIJUl::i,l....qIIU, i.JUulluy UI ,.."'..iIiJWl::i.l.~ClIIU, o.lJU UuQuC Ul . Cltll~Y"'VqllJ,.!:J, =~"""> I .1 I I " , .! . and GTantorB JAMES C. HOOVER and LINDA ,L. HOOVER, hia wife, of Sunbury, Penneylvania , I , I , i WITNESSETH, tlult in ooMideration of Fifty One Thouaand ------------------------------ -------($51,OOO.00)-----------------Dolmr~ in Iulnd paid, the receipt whereof is hereby aokMwledged, the 8aid grantor s do hereby grant and convey to the 8aid grantees, their heirs and sssigns, , . <hantee a : ALL 'THAT CERTAIN lot, or tract of land situate in the Borough of New Cumberland, County of Cumbarland and State of Pennsylvania, more particularly bounded and described as follows according to a survey of D.P. Raffensperger (49-29) dated March 4, 1974, to wit: ._r.: BEGINNING at a point on the Northarn aide of 15th Street said point being 870.8 feet west of 8ridge Street; thence extending along 15th Street South 62 degrees Wast 50 feet to a cornar of lot number 3D on the hereinafter mentioned plan of lots; thence along lot number 3D north 28 degrees West 195 feet to a point a corner; thence North 62 degrees East 50 feet to a point a corner; thence extending through lot number 31 on said plan South 2B degrees East 195 feet to the point 'and place of BEGINNING. .: BEING a part of lot number 31 Section E Plen of Hillside es recorded in the Cumberland County Recorder's Office in Plan Book 1, Page 75. HAVING thereon erected a two'story frame dwelling and detachsd frame garage known ss 329 15th Street. '. BEING ths same premises which Louis N. Kelly and Ruth K. Kelly, his wife, by deed dated March 27, ,1974, and recorded in the Office of the Recorder of Deeds in and for Cumberland County in Deed Book N, Volume 25, Page 1040, granted and conveyed, unto John, O. Osgood and Susan C. Osgood, his wife, the Grantors herein. . " ~ THE ABOVE DESCRI8ED premises sre conveyed under and subject to Mortgage to Advance Mortgage Corporation, the unpaid balance of which is $28,006.02 Dollars which the Grantees sssume snd agree to pey according to the terms and conditions of said mortgage snd accompanying bond. ~'.g~ 'I~~;'~ 7(/a-Jd~ Cumbo Co., P.. School Di,t. Cumbo Co., P.. ~ Rut ~htl!l Trud., 111.. ~ ~eal Eltate Tran,f" 1a: '7 -:>-...71 d..i,-:5'0J! 7~?--7.r.... Aml.d:!?s..g!! Dol. .:2....... AmI. ........ D.~...J.'.;,...:: /..1 Act ~;;..""-/l.<<!-~ v/~.{, II-.~ Cumb.. Co. Oilt. Col. ^9t. ~ Cum\J. Co. Dilt. Col. Av'. rts REGISTEREO BY THE HOF EWCiJMBERLAND ./~ ~ ,I I I , i , . .j , d , " ., 1 \. MWv'Z8 P^GE 39 f ,I 'j i , ~..' '''__.n~ __.__,.,_ .__" _ _ ~.--""__...w~._ ._~.. ..oi ..." "'-"~_~ _ ;"'" ..1ST " NATIONWIDE . MOFITGAGE T7/0i.PJ-157S /';)C}3 O;;2.l{O "-I3(g'~ EXHIBiT A P,O. Box 9481 Gaithersburg. MO 20698.9481 December 22. 2~00 Certified Mail Return Receip Requested James Hoover / 329 15th St ' New Cumberland PA 17070-1312 RE: Loan No., 6838320381 Dear Mortgagor: Act 91 Notice Take Action to Save Your Home From Foreclosure This is an official notice that the mortgage on your home is in default. and the lender intends to foreclose. Specific information about the nature of the default is provided in the attached pages. The HOMEOWNER'S MORTGAGE ASSISTANCE PROGRAM (HEMAP) maybe able to help to save your home. This notice explains how the program works. To see if HEMAP can help, you must MEET WITH A CONSUMER CREDIT COUNSELING AGENCY WITHIN 30 DAYS OF THE DATE OF THIS NOTICE. Take this notice with yOU when you meet with the counseling agency. The name. address. and phone number of the Consumer Credit Counselina Agencies serving your County are listed at the end of this Notice. If you have any questions, yOU may call the Pennsylvania Housing Finance Aqency toll-free at 1-800-342-2397. (Persons with impaired hearinq can call (717) 780-1869.) This Notice contains important legal information. If you have any questions, representatives at the Consumer Credit Counseling Agency may be able to help explain it. You may also want to contact 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 su derecho a continuar viviendo en su casa. Si no comprende el contenido de esta notification obtenga una traduccion immediatamente ilamanda esta agencia (Pennsylvania Housing Finance Agency) sin cargos al numero mencionada arriba. Puedes ser elegible para un prestamo por el programa llamado "Homeowner's Emergency Mortgage Assistance Program" el cual puede salvar su casa de la perdida del derecho a redimir su hipoteca. DF350-002/COY 52BO Corporate Drive. Frederick. MD 21703 - _I " Lll1l 1~;"A : .. 1ST ..' NATIONWIDE , MORTGAGE 'l ) 0\0 l.J)" 1-5' 1 d- <I:J \ja'l 0 "fJ P.O. Box 9481 8eirhersburg, MD 20898.9481 Linda Hoover 329 15th St New Cumberland PA 17070-1312 / December 22. 2000~ Certified Mail("./'" Return Receipt Requested RE: Loan No. 6838320381 Dear Mortgagor: Act 91 Notice Take Action to Save Your Home From Foreclosure This is an official notice that the mortgage on your home is in default, and the lender intends to foreclose. Specific information about the nature of the default is provided in the attached paqes. The HOMEOWNER'S MORTGAGE ASSISTANCE PROGRAM (HEMAP) may be able to help to save your home. This notice explains how the proqram 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 with yOU when yOU meet with the counseling aqency. The name, address, and phone number of the 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 call (717)780-1869.) This Notice contains important legal information. If you have any questions, representatives at the Consumer Credit Counseling Agency may be able to help explain it. You may also want to contact 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 su derecho a continuar viviendo en su casa. Si no comprende el contenido de esta notification obtenga una traduce ion immediatamente llamanda esta agencia (Pennsylvania Housing Finance Agency) sin cargos al numero mencionada arriba. Puedes ser elegible para un prestamo por el programa llamado "Homeowner's Emergency Mortgage Assistance Program" el cual pue9.e salvar su casa de la perdida del derecho a redimir su hipoteca. DF356-001/COY ""on rMnn."tc n.;,,<> ~rp.rjt>ri('1o! Mn 7170:\ ~~ O~,~ k~ " , ~ . 1ST . . . NA"ONwlDE . ' MORTGAGE '11()<P LJS":rr j)q) 001YS> \J'],' PO, Box 9481 Gaithersburg, MO 20898-9481 December 22, 2000 ~ Certified Mail ,..../ Return Receipt Requested Susan C. OSgOOdL 329 15th St New Cumberland. PA 17070 RE: Loan No. 6838320381 Dear Mortgagor: Act 91 Notice Take Action to Save Your This is an offaQmficFtQIlletoQt~~lp~yr~me is in default, and the lender intends to foreclose. Specific information about the nature of the default is provided in the attached pages. The HOMEOWNER'S MORTGAGE ASSISTANCE PROGRAM (HEMAP) may be able to help to save your home. This notice explains how the program works. To see if HEMAP can help, YOU must MEET WITH A CONSUMER CREDIT COUNSELING AGENCY WITHIN 30 DAYS OF THE DATE OF THIS NOTICE. Take this notice with vou when vou meet with the counseling agency. The name, address, and phone number of the Consumer Credit Counseling Agencies serving your County are listed at the end of this Notice. If you have anv questions, YOU may call the Pennsvlvania Housing Finance Agency toll-free at 1-800-342-2397. (Persons with impaired hearing can call (717)780-1869.) This Notice contains important legal information. If you have any questions, representatives at the Consumer Credit Counseling Agency may be able to help explain it. You may also want to contact any attorney in your area. The local bar association may be able to help you find a lawyer. La notificacion en adjunto es de sumairnportancia, pues afecta su derecho a continuar viviendo en su casa. Si no comprende el contenido de esta notification obtenga una traduccion immediatamente llamanda esta agencia (pennsylvania Housing Finance Agency) sin cargos al numero mencionada arriba. Puedes ser elegible para un prestamo por el programa llamado "Homeowner's Emergency Mortgage Assistance program" el cual puede salvar su casa de la perdida del derecho a redimir su hipoteca. DF352-001/COY - - ~ '-~-'~-'*1M-r,: .- 1ST i NATIONWIDE MORTGAGE -) \ O(P ~ '5 ')5 l"dq:l Od'-ti) ~3'13 PoD. Box 94B1 Gaithersburg, MD 20B99-94B1 December 22, 2000 Certified Mail~ Return Receipt Requested John 0 Osgood ~ 329 15th ST ~ . New Cumerland, PA 17070 RE: Loan No. 6838320381 Dear Mortgagor: Act 91 Notice Take Action to Save Your This is an offHQlJJGcFJQQ;1EQr~plo~Y~~me is in default, and the lender intends to foreclose. Specific information about the nature of the default is provided in the attached pages. The HOMEOWNER'S MORTGAGE ASSISTANCE PROGRAM (HEMAP) may be able to help to save your home. This notice explains how the program works. To see if HEMAP can help, YOU must MEET WITH A CONSUMER CREDIT COUNSELING AGENCY WITHIN 30 DAYS OF THE DATE OF THIS NOTICE. Take this notice with YOU when YOU meet with the counseling agenCY. The name, address, and phone number of the 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 call (717) 780-1869.) This Notice contains important legal information. If you have any questions, representatives at the Consumer Credit Counseling Agency may be able to help explain it. You may also want to contact 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 su derecho a continuar viviendo en su casa. Si no comprende el contenido de esta notification obtenga una traduccion immediatamente llamanda esta agencia (pennsylvania Housing Finance Agency) sin cargos al numero mencionada arriba. puedes serelegible para un prestamo por el programa llamado "Homeowner's Emergency Mortgage Assistance Program" el cual puede salvar su casa de la perdida del derecho a redimir su hipoteca. DF352-001/COY ~~^^ "..~_._._ n_:.._ t.~..l~~;~L ~An 'l17f1'::J "< '4~,.. December 22, 2000 Loan No. 6838320381 Page 2 PA Act 91 Homeowner's Name: James Hoover Property Address: 329 15th St New Cumberland PA 17070 Loan Account No.: 6838320381 Original Lender: Advance Mortgage Corporation Current Lender/Servicer: First Nationwide Mortgage HOMEOWNER'S EMERGENCY MORTGAGE ASSISTANCE PROGRAM YOU MAY BE ELIGIBLE FOR FINANCIAL ASSISTANCE walCH CAN SAVE YOUR HOME FROM FORECLOSURE AND HELP YOU MAKE FUTURE MORTGAGE PAYMENTS IF YOU COMPLY WITH THE PROVISIONS OF THE HOMEOWNERS' EMERGENCY MORTGAGE ASSISTANCE ACT OF 1983 (THE "ACT"). YOU MAY BE ELIGIBLE FOR EMERGENCY 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 MOST OCCUR WITHIN THE NEXT (30) DAYS. IF YOU DO ,NOT APPLY FOR EME~GPCYMORTGAGE ASSISTANCE, YOU MUST BRING YOURHORTGAGETb DATE. THE PART OF THIS NOTICE CALLED "HOW TO CURE YOUR MORTGAGE DEFAULT,. EXPLAINS HOW TO BRING YOUR MORTGAGE UP TO DATE. DF353-001/COY '''"''''''''',<1''=.- -. " '" 1._ "~-,.;., "->~ if -"jb!;'Hlhll'-' December 22, 2000 Loan No. 6838320381 Page 3 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 the designated consumer credit counselinq aqencies for 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. APPLICATIONS 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 resolve this problem with the lender, you have the right to apply for financial assistance from the Homeowner's Emergency Mortgage Assistance Program. To do so, you must fill out, sign and file completed Homeowners' Emergency Mortgage Assistance Program Application with one of the designated consumer credit counseling agencies listed at the end of this Notice. Only consumer credit counseling agencies have applications for the program and they will assist you in submitting a complete application to the Pennsylvania Housing Finance Agency. Your application MUST be filed or postmarked within thirty (3D) 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 eligi- bility criteria established by the Act. The Pennsylvania Housing DF353-001/COY ,-" 0_' :, ~- - 1 j ~',;,.- ..; :.....,.,~~L ~IJI&"~,-,,<-g.>': " December 22, 2000 Loan No. 6838320381 Page 4 PA Act 91 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 CUaRENTLY PROTECTED BY THE FILING OF A PETITION IN BANKRUPTCY, THE FOLLOWING PART OF THIS IS FOR INFO~TION PURPOSES ONLY ANI) SHOULD NOT BE CONSIDERED AS AN ATTEMPT TO COLLECT THE DEBT. (If you have filed bankruptcy you can still apply for Emergency Mortgage Assistance.) HOW TO CURE YOUR MORTGAGE DEFAULT (Bring it UP to datel NATURE OF THE DEFAULT - The MORTGAGE debt held by the above lender on your property located at: 329 15th St New Cumberland PA 17070 IS SERIOUSLY IN DEFAULT because: YOU HAVE NOT MADE YOUR MONTHLY MORTGAGE PAYMENTS for the following months and the following amounts are now past due: 1 Months at $349.79 = 349. 79 ~ I Months at $442.04 = 442.04 v / 1 Months at $356.37 = 356.37 ~ Late Charges 87.89 Bad Check Fees .00 Foreclosure Fees .00 Bankruptcy Fees .00 Other Fees / 7.00 Less Suspense Balance __ .00 TOTAL AMOUNT DUE l/ 1,243.09 AS OF THIS DATE HOW TO CURE THE DEFAULT -y~. u ~ay cure the default within THIRTY (30) DAYS of the date of this not ce BY PAYING THE TOTAL AMOUNT PAST DUE TO THE LENDER WHICH IS $ 1. 43.09 PLUS ANY MORTGAGE PAYMENTS AND LATE CHARGES WHICH BECOME DUE DURING THE THIRTY (30) DAY PERIOD. Payments must be made either bY cash, caShier's check, certified check, or money order made payable and sent to: First Nationwide Mortgage Corporation Dept. 0107 Palatine, IL 60055-0107 DF354-001/COY --,,-- ,~ - ,. '-j'I,._ ,~ '~ ,"' ~ !a~~h> .' December 22. 2000 Loan No. 6838320381 Page 5 PA Act 91 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 attor- neys 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 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. DF354-001/COY I " ~~ , iBL '..~., . ." December 22, 2000 Loan No. 6838320381 Page 6 PA Act 9 RIGHT TO CURE THE DEFAULT PRIOR THE SHERIFF'S SALE - If you have not cUred the default within the THIRTY (30) DAY periOd and foreclosure proceedings have begun, YOU still have the 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 charqes then due, reasonable attorney's fees and cost connected with the foreclosure sale and other cost 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 mortgage property could be held would be approximately 6 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. HOW TO CONTACT THE LENDER: First Nationwide Mortgaae Corporation 5280 Corporate Drive Frederick, MD 21703 Department 252 1-800-8118-4333 EFFECT OF THE SHERIFF'S SALE - You should realize that the 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, UPON OUR CONSENT may sell or transfer your home to a buyer or transferee who will assume the mortgage debt, provided that all the outstanding payments, charges and attorney's fees and costs are paid prior to or at the sale and that the other requirements of the mortgage are satisfied. 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. DF355-001/COY ~~Mtr~~~jj~!W~~~!::\""";",,j'-~~"",_'_"i'-\'E1,W,W!",,*",~H~<f.ol!~jj~:j\.~lli!lll:l'ff 11 LlJ;~-riMll:.'ffl<~J!lMMQl'ffit!J8! ~ " ~ ~~ ~ ItiP;n/J i <Jwt '^IC"'l.,I1' ~riHv!\ \ 1\':) N 1'll:_O T~: (, _ ,,~H,~; Ill. ~~ IS II 62 uH 'Y1" J.,lKn(:~ ~, ' ie'"'' ,UI\l3HS 'It\;. :JC 3~lJjO ~--') "",.,,,,,,,," .. "~, ., ~ ~,' ~= ~",'".~.' ".'.'..~M'""..h ..,.~ ,~ , ~ .,.~ _,j <._ - ".", 7 ~'.. ~. . "~'" ':J~,,~'~ "' -..j ,', "',- '" '. ... '-" ~" -~^ --'rl@""C,. 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 I~ ~~~; ~~R~~~J~~ OF THE ORIGINAL FlLEO Y FIRST NATIONWIDE MORTGAGE CORP. PO Box 9481 Mail Code: 22-528-10Il Gaithersburg, MD 20898-9481 Plaintiff IN THE COURT OF COMMON PLEAS OF CUMBERLAND COUNTY CIVIL ACTION - LAW vs. :ACTION OF MORTGAGE FORECLOSURE JOHN O. OSGOOD AND SUSAN C. OSGOOD (Mortgagor(s)) Term No. JAMES HOOVER AND LINDA HOOVER (ReaIOwner(s)) 329 15th Street New Cumberland, PA 17070 Defendant(s) CIVIL ACTION: MORTGAGE FORECLOSURE -t1 0/- 3 UtJ (!~ 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 rou have been sued in court. If you wish to defend against the claims set forth in the following pages, you must take action within twenty (20) days after the Complaint and notice are served, by entering a written appearance personally or by attorney and filing in writing with the court your defenses or objections to the claims set forth against you. You are warned that if you fail to do so the case may proceed without you and a judgment may be entered against you by the Court without further notice for any money claimed in the complaint or for any other claim or relief requested by the Plaintiff. You may lose money or property or other rights important to you. '/OU SHOULD TAKE THIS PAPER TO YOUR LAWYER AT ONCE. IF YOU DO NOT HAVE A LAWYER OR CANNOT AFFORD ONE, GO TO OR TELEPHONE THE OFFICE SET FORTH BELOW TO FIND OUT WHERE YOU CAN GET LEGAL HELP. Cumberland County Bar Association 2 Liberty Avenue, Carlisle, PA (800) 990-9108 vegal Services Inc. a Irvine Row, Carlisle, PA 17013 (717) 243-9400 A V ISO I,E HAN DEMANDADO A USTED EN LA CORTE. SI DESEA DEFENDERSE CONTRA LAS QUEJAS PERESENTADAS, ES ABSOLUTAMENTE NECESSARIO QUE USTED RESPONDA DENTRO DE 20 DrAS DESPUES DE SER SERVIDO CON ESTA DEMANDA Y AVISO. PARA DEFENDERSE ES NECESSARIO QUE USTED, 0 SD ABOGADO, REGISTRE CON LA CORTE EN FORMA ESCRITA, EL PUNTa DE VISTA DE USTED Y CUALQUIER OBJECCION CONTRA LAS QUEJAS EN ESTA DEMANDA. FECUERDE: SI USTED NO REPONDE A ESTA DEMANDA, SE PUEDE PROSEGUIR CON EL PROCESO SIN SU PARTICIPACION. ENTONCES, LA COUTE PUEDE, SIN NOTIFICARlO, DECIDIR A FAVOR DEL DEMANDANTE Y REQUERIRA QUE USTED CUMPLA CON TODAS LAS PROVlSIONES DE ESTA DEMANDA. pOR RAZON DE ESA DECISION, ES POSSIBLE QUE USTED PUEDA PERnER DINERO, PROPIEDAD U OTROS DERECHOS IMPORTANTES. uLEVE ESTA DEMANDA A UN ABOGADO IMMEDIATAMENTE. Cumberland County Bar Association ~ Liberty Avenue, Carlisle, PA (800) 990-9108 "LAWYER REFERENCE SERVICE" (SERVIClO DE REFERENCIA DE ABOGADOS), IlrIJe COpy FROM ReCORD and :=~hereof, I here unto set my halld r of Sall1 Coutt at Car/iSle Pa d y, at ~(, " or ry "'- 9 I NO CONOCE A UN ABOGADO, LLAME AL 215-238-6300. ~egal Services Inc. e Irvine Row, Carlisle, PA 17013 (717) 243-9400 .---,,,~~., ~ r - =" j,~ - '" .~ ~ - ~ "~\ I HEREBY CERTIFY THAT TI-Ui IS A TRUE AND CORRECT COPY OF THE ORIGINAL FILED COMPLAINT IN MORTGAGE FORECLOSURE I. Plaintiff is FIRST NATIONWIDE MORTGAGE CORP., PO Box 9481, Mail Code: 22-528-1011, Gaithersburg, MD 20898-948l. 2. The name(s) and address (es) of the Defendant(s) is/are JOHN O. OSGOOD, 329 15th Street, New Cumberland, PA 17070 and SUSAN C. OSGOOD, 329 15th Street, New Cumberland, PA 17070, who is/are the mortgagor(s), and JAMES HOOVER, 329 15th Street, New Cumberland. PA 17070. and LINDA HOOVER. 329 15th Street, New Cumberland. PA 17070, who is/are the record owner (s) of the mortgaged property hereinafter described. 3. On March 27, 1974, mortgagor(s) made, executed and delivered a mortgage upon the premises hereinafter described to ADVANCE MORTGAGE CORP., which mortgage is recorded in the Office of the Recorder of Deeds of Cumberland County in Mortgage Book 575, Page 1071. By Assignment of Mortgage, the mortgage was assigned to Plaintiff, which Assignment is lodged for recording. These documents are matters of public record and are incorporated herein by reference in accordance with Pennsylvania Rule of Civil Procedure 1019(g). 4. The premises subject to said mortgage is described as attached. 5. The mortgage is in default because monthly payments of principal and interest upon said mortgage due October I, 2000, and each month thereafter are due and unpaid, and by the terms of said mortgage. upon default in such payments for a period of one month, the entire principal balance and all interest due thereon are collectible forthwith. 6. The following amounts are due on the mortgage: Principal Balance Interest from 91 l/oo through 5/31/01 at 8.250% Per diem interest rate at $1.76 Reasonable Attorney's Fee Late Charges lol l/oo- 5/31/01 Monthly late charge amount at $17.48 Costs of suit and Title Search $ 7,803.99 478.72 I,OOO.OO 139.84 560.00 $ 9,982.55 429.80 Escrow Balance Deficit Monthly Escrow amount $ $ 10,412.35 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 ,,--' '. , ~~~ " """', J ,l'(ffo.~r~:~ 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(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 $IO,412.35, together with interest at the rate of $l.76, per day and other expenses incurred by the Plaintiff which are properly chargeable in accordance with the terms of the mortgage, and for the foreclosure and sale of the mortgaged premises. ~oV-- By: GOLDB CK Mc FFERTY & McKEEVER BY: oseph A. Goldbeck, Jr., Esq. Attorney for Plaintiff ~ '. b' ,~, .00.,- . , .', - _ ,- - _ ,,' _ , "'~i;f.^', VERIFICATION I, Dennis Kieft f as the representative of the Plaintiff corporation within named do hereby verify that I am authorized to and do make this verification on behalf of the Plaintiff corporation and the facts set forth in the foregoing Complaint are true and correct to the best of my knowledge f 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. Date:," }()'3 hi '"-''''"''''"'''''''' ,: i I ./ I I 'I ,\ I ! i .: . j .1 I 1 , i . . ,j , ,I , " 'I 1 i I , 1 '1 i , .-.' -"". """. ~" , ~ _I.,', ,,,,..,,, '. '",,;"'_H- 'i'F-' ;~ I\1CiW UUIlIUCi....C'lU_ .LJuui,~'i Ul WUlll~Ci.l.~CJIIUJ QIIU UUC.UC Ul I CJIJI~Y""VC'I""!i3J . and GTantorB , JAMES C. HOOVER and LINDA ,L. HOOVER, his wife, of Sunbury, Pennsylvarie, <hantee a : WITNESSETH, tlult in ooMiderationof Fifty One Thousand ----------------~------------- -------($51,OOO.00)-----------------Dolmr8 , in hand paid, the receipt whereof is hereby ackMwledged, the 8aid grantors do hereby grant and convey to t~e 8aid gran~ee s, their heirs and assigna, ALL THAT CERTAIN lot. or tract of land aituata in the 8orough of New Cumberland, County of Cumberland and Steta of Pennsylvania, more particularly bounded and described as follows according to a survey of D.P. Raffenspsrger (49-29) dated March 4, 1974, to wit: BEGINNING at a point on the Northern side of 15th Street said point being 870.8 feet west of 8ridge Street; thence extending along 15th Street South 62 degrees West 50 feet to a corner of lot number 3D on the hereinafter mentioned plan of lots; thence along lot number 3D north 28 degrees West 195 feet to a point a corner; thence North 62 degrees East 50 feet to a point a corner; thence extending through lot number 31 on said plan South 28 degrees East 195 feet to the point and pIece of BEGINNING. BEING a part of lot number 31 Section E Plan of.Hillside as recorded in the Cumberland County Recorder's Office in Plan Book 1, Page 75. HAVING thereon erected a two story frame dwelling and detached frame garage known as 329 15th Street. 8EING the same premises which Louis N. Kelly and Ruth K. Kelly, his wife, by deed dated March 27, .1974, and recorded in the Office of the Recorder of Deeds in and for Cumberland County in Deed Book N, Volume 25, Page 1040, granted and conveyed.Jmto John. O. Osgood and Susan C. Osgood, his wife, the Grantors herein. " THE A80VE DESCRIBED premises are conveyed under and subject to Mortgage to Advance Mortgage Corporation, the unpaid balance of which is $28,006.02 ~ Dollars which the Grantees assume end agree to pay according to the terms and conditions of said mortgage and accompanying bond. . ~..g~ 'f~~;,~(f 7(/a-Jd~ Cumbo Co., P.. School Di.t. Cumbo Co., P.. ~ Ro.1 htat. Trull., Tn ~ R.eal E't"t~ Tru.fer 1a: _ D "7 _;1-.71 d..i,-:5-0J! r?--7l... Amt.~~.~:g!! Ad7i:Z..:"t.t?-~ D't?~.{, II-.~ Cumb.. Co. Dllt. Col. ^gt. ~ Cllm\).,Co. Did. Col. A;t,rts . " eoovY28 pm 39 .... n_.._. .....".._..~.. .'.~._..~._.... .. ...-_ ...._. n.. _._...____.____.~_. __. ."___~__~.__,... _~~ e;o<......lI.___...____ ,_ _. ''''''' , , , --L. ,,-, .' '..ill - '-St!j'~: .. .' 1ST . .~E r'f/O(P)../57S /-;)03 O;;2<.{o -'13& ~ EXHIBIT A P,O, Box 9481 Gaithersburg, MO 20898-9481 December 22, ~OOO Certified Mail Return Receip Requested James Hoover / 329 15th St New Cumberland PA 17070-1312 RE: Loan No. 6838320381 Dear Mortgagor: Act 91 Notice Take Action to Save Your Home From Foreclosure This is an official notice that the mortgage on your home is in default, and the lender intends to foreclose. specific information about the nature of the default is provided in the attached pages. The HOMEOWNER'S MORTGAGE ASSISTANCE PROGRAM (HEMAP) may be able to help to save your home. This notice explains how the program works. To see if HEMAP can help, yOU must MEET WITH A CONSUMER CREDIT COUNSELING AGENCY WITHIN 30 DAYS OF THE DATE OF THIS NOTICE. Take this notice with yOU when yOU meet with the counselinq aqency. The name, address, and phone number of the Consumer Credit Counseling Aqencies servinq your County are listed at the end of this Notice. If yOU have any questions, you may call the Pennsylvania Housinq Finance Agency toll-free at 1-800-342-2397. (Persons with impaired hearing can call (717)780-1869.) This Notice contains important legal information. If you have any questions, representatives at the Consumer Credit Counseling Agency may be able to help explain it. You may also want to contact 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 su derecho a continuar viviendo en su casa. Si no comprende el contenido de esta notification obtenga una traduccion immediatamente 11amanda esta agencia (Pennsylvania Housing Finance Agency) sin cargos al numero mencionada arriba. puedes ser elegible para un prestamo por el programa llamado "Homeowner's Emergency Mortgage Assistance ' Program" el cual puede salvar su casa de la perdida'del. derecho a redimir su hipoteca. DF350-002/COY 5280 Corporate Drive, Freoorick, MD 21703 _ J. ,,' '.~ ' " ., . "<_-L--_ 'ifr . "" .. 1ST ., !!~E 'l } 0'0 l.j)' 1-5" 1 d- tt J \Ja'-l 0 'fJ ~O. Box 94B1 Gaithersburg, MO 2089B-9481 Linda Hoover 329 15th St New Cumberland PA 17070-1312 / December 22, 2000~ Certified MailV' Return Receipt Requested RE: Loan No. 6838320381 Dear Mortgagor: Act 91 Notice Take Action to Save Your Home From Foreclosure This is an official notice that the mortgage on your home is in default, and the lender intends to foreclose. Specific information about the nature of the default is provided in the attached pages. The HOMEOWNER'S MORTGAGE ASSISTANCE PROGRAM (HEMAP) may be able to help to save your home. This notice eXPlains how the program works. To see if HEMAP can help, YOU must MEET WITH A CONSUMER CREDIT COUNSELING AGENCY WITHIN 30 DAYS OF THE DATE OF THIS NOTICE. Take this notice with YOU when YOU meet with the counseling agency. The name, address. and phone number of the 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 Aqency toll-free at 1-800-342-2397. (Persons with imPaired hearing can call (717)780-1869.) This Notice contains important legal information. If you have any questions, representatives at the Consumer Credit Counseling Agency may be able to help explain it. You may also want to contact 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 su derecho a continuar viviendo en su casa. Si no comprende el contenido de esta notification obtenga una traduccion immediatamente llamanda esta agencia (Pennsylvania Housing Finance Agency) sin cargos al numero mencionada arriba. puedes ser elegible para un prestamo por el programa llamado "Homeowner's Emergency Mortgage Assistance Program" el cual puede salvar su casa de la perdida del derecho a redimir su hipoteca. DF356-001/COY i:;'Jon f'",,.,nr,,t.. nriu.. I=rPrl"'If'~ Mn ?11n:l . . --, '--- '"" '" J' ~ ' , -" -. _,' .~ .:~ .... ~.""~0NWl. '.' ~E . MJfTG.6tiE '1 ) ()<p II )1"f I -;) ~) O~Y@ '4"1" P.O. Box 9481 Gaithersburg, MO 20898.9481 December 22, 2000 ~ Certified Mail .-/ Return Receipt Requested Susan C. Osgood ~ 329 15th St --'A' New Cumberland, PA 17070 RE: Loan No. 6838320381 Dear Mortgagor: Act 91 Notice Take Action to Save Your This is an offaQm~cFJ:QIlle~om~~lp~"r~me is in default, and the lender intends to foreclose. Specific information about the nature of the default is provided in the attached pages. The ROMEOWNER'S MORTGAGE ASSISTANCE PROGRAM (REMAP) may be able to help to save your home. This notice explains how the program works. To see if REMAP can help, YOU must MEET WITH A CONSUMER CREDIT COUNSELING AGENCY WITHIN 30 DAYS OF THE DATE OF THIS NOTICE. Take this notice with YOU when YOU meet with the counseling agency. The name. address, and phone number of the 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 call (717)780-1869.) This Notice contains important legal information. If you have any questions, representatives at the Consumer Credit Counseling Agency may be able to help explain it. You may also want to contact 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 su derecho a continuarviviendo en su casa. 3i no comprende e1 contenido de esta notification obtenga una traduccion immediatamente 11amanda esta agencia (Pennsylvania Housing Finance Agency) sin cargos al numero mencionada arriba. puedes ser elegible para un prestamo por el programa llamado "Homeowner's Emergency Mortgage Assistance program" el cual puede salvar su casa de la perdida del derecho a redimir su hipoteca. DF352-001/COY "U ',- '-.'~ ~ - )" , , . _.,,-,,_...\'t, , .. ." 1ST , " NA1l0, NWIDE . a........,,^l'1" , IYJUJlIlJMIlC '11 O~ L) 'S ")5 /'&9:) 6d\.W ~3'13 P.O. Box 9481 Gaithersburg. MO 20898-9481 December 22, 2000 Certified Mail~ Return Receipt Requested John 0 Osgood /' 329 15th ST ~ - New Cumer1and, PA 17070 RE: Loan No. 6838320381 Dear Mortgagor: Act 91 Notice Take Action to Save Your This is an offHQ~cfJQQ;lEQr~plo~Y~~me is in default, and the lender intends to foreclose. Specific information about the nature of the default is provided in the attached pages. The HOMEOWNER'S MORTGAGE ASSISTANCE PROGRAM (HEMAP) may be able to help to save your home. This notice explains how the program works. To see if HEMAP can help, YOU must MEET WITH A CONSUMER CREDIT COUNSELING AGENCY WITHIN 30 DAYS OF THE DATE OF THIS NOTICE. Take this notice with yOU when YOU meet with the counseling agency. The name, address, and phone number of the Consumer Credit Counseling Agencies serving your County are listed at the end of this Notice. If vou have anyouestions, yOU may call the Pennsylvania Housing Finance Agency toll-free at 1-800-342-2397. (Persons with impaired hearing can call (717)780-1869.) This Notice contains important legal information. If you have any questions, representatives at the Consumer Credit Counseling Agency may be able to help explain it. You may also want to contact 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 su derecho a continuar viviendo en su casa. Si no comprende el contenido de esta notification obtenga una traduccion immediatamente llamanda esta agencia (pennsylvania Housing Finance AgenCY) sin cargos al numero mencionada arriba. Puedes ser elegible para un prestamo por el programa llamado "Homeowner's Emergency Mortgage Assistance Program" el cual puede salvar su casa de la perdida del derecho a redimir su hipoteca. DF352-001/COY .....^'"' ......____._ n_:.._ C:._~~.:~I, ~In ?t7n'J ~, ---. - , "....", -,"-'c '.' .,"_" '~'. ". December 22, 2000 Loan No. 6838320381 Page 2 PA Act 91 Homeowner's Name: James Hoover Property Address: 329 15th St New Cumberland PA 17070 Loan Account No.: 6838320381 Original Lender: Advance Mortgage Corporation Current Lender/Servicer: First Nationwide Mortgage 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 HOMEOWNERS' EMERGENCY MORTGAGE ASSISTANCE ACT OF 1983 (THE "ACT"), YOU MAY BE ELIGIBLE FOR EMERGENCY 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 EDttOENCY MORTGAGE ASSISTANCE, YOU MUS.T BRING YOBMOR'l'tiSB'W DA'l'E. THEPAR'l' OF THIS, NOTICE CALLED "HOW TO CURt!: YOUR MORTl3AGE DEFJ5:UtT," EXPLAINS HOW TO BRING YOUR MORTGAGE UP TO DATE. DF353-001/COY ~ " -, 1-- ~~ '~, December 22, 2000 Loan No. 6838320381 Page 3 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 the designated consumer credit counseling agencies for 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. APPLICATIONS 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 resolve this prOblem with the lender, you have the right to apply for financial assistance from the Homeowner's Emergency Mortgage Assistance Program. To do so, you must fill out, sign and file completed Homeowners' Emergency Mortgage Assistance Program Application with one of the designated consumer credit counseling agencies listed at the end of this Notice. only consumer credit counseling agencies have applications for the program and they will assist you in sUbmitting a complete application to the PennsYlvania Housing Finance Agency. Your application MUST be filed or postmarked within thirty (30) days of your face-to-face meeting. YOU MUST FILE YOUR APPLICATION PROMPTLY. IF YOU FAIL TO DO SO OR IF YOU DO NOT FOLLOW THE OTHER TIME PERIODS 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 eligi- bility criteria established by the Act. The Pennsylvania Housing DF353-001/COY _'0" ., > . ..., ,,~ ~- - . ", " December 22, 2000 Loan No. 6838320381 Page 4 PA Act 91 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 IS FOR INFORMATION PURPOSES ONLY AND SHOULD NOT BE CONSIDERED AS AN ATTEMPT TO COLLECT THE DEBT. (If you have filed bankruptcy you can still apply for Emergency Mortgage Assistance.) 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: 329 15th St New Cumberland PA 17070 IS SERIOUSLY IN DEFAULT because: YOU HAVE NOT MADE YOUR MONTHLY MORTGAGE PAYMENTS for the following months and the following amounts are now past due; 1 Months at $349.79 = 349. 79 ~ 1 Months at $442.04 = 442.04 v /' 1 Months at $356.37 = 356.37 ./ Late Charges 87.89 Bad Check Fees .00 Foreclosure Fees .00 Bankruptcy Fees .00 Other Fees / 7.00 Less Suspense Balance __ .00 TOTAL AMOUNT DUE L/ 1,243.09 AS OF THIS DATE HOW TO CURE THE DEFAULT - y~u ~ay cure the default with,in THIRTY (30) DAYS of the date of this not ce BY PAYING THE TOTAL AMOUNT PAST DUE TO THE LENDER WHICH IS $ 1, 43.09 PLUS ANY MORTGAGE PAYMENTS AND LATE CHARGES WHICH BECOME DUE DURING THE THIRTY (30) DAY PERIOD. Pavrnents must be made either bY cash, caShier's check, certified check. or money order made payable and sent to: First Nationwide Mortgage Corporation Dept. 0107 Palatine, IL 60055-0107 DF354-001/COY ~ " ",-.' L __, "- "" ~J 'h"i, '"'-'-~, . December 22. 2000 Loan No. 6838320381 Page 5 PA Act 91 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 riahts to accelerate the mortgaae 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 attor- neys 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 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. DF354-001/COY , '''-'-' ~^j' l-_ -, - ,-, ^ J lJ::UCl:..ii'f . .' " December 22, 2000 Loan No. 6838320381 Page 6 PA Act 9 RIGHT TO CURE THE DEFAULT PRIOR THE SHERIFF'S SALE - If you have not cured the default within the THIRTY (30) DAY period and foreclosure proceedings have begun, you still have the 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 cost connected with the foreclosure sale and other cost 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 mortgage property could be held would be approximately 6 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. HOW TO CONTACT THE LENDER: First Nationwide Mortgage Corporation 5280 Corporate Drive Frederick, MD 21703 Department 252 1-800-888-1333 EFFECT OF THE SHERIFF'S SALE - You should realize that the 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, UPON OUR CONSENT may sell or transfer your home to a buyer or transferee who will assume the mortgage debt, provided that all the outstanding payments, charges and attorney's fees and costs are paid prior to or at the sale and that the other requirements of the mortgage are satisfied. 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. DF355-001/COY :~t.;';''''''J- -_I~~~'ii&)f'~;'~'~'''''",filci2,\ii;o~.li;ti,1lO",,~~~'_~_~"''''''~"''' '..,",.;;....... , -1 " r.1 \;'1 ")Jd 'f:Il~!'dJ\" -\i~;',~ " I "~:;-'l z:;'~!-:~. !~', '." ",n n'l II" ,.,' ~'J \J : ...>: ~; 'J " -~ I UIH1C::l ;J. ;:\;:\Il\:!HS "' .~ 61 kU" t,,'.~,IJtin~) ,j;' 3 :)\;LHI <hr- ~~~. -,~~-~ ~ \fUll c.].@ '(g 'i1fU ~! " ~"U lfi=' fB) nn rE' Q~ J~ IF] W IS &:::~ F~J , ""'IlIil"""'''''''' t, _......_~ , ~~ -_. 1l"l\"L"'Jlil~ . ~ First Nationwide Mortgage Corp. VS James Hoover and Linda Hoover The Court of Common Pleas of Cumberland County, Pennsylvania Writ No. 2001-3220 Civil Term Sharon Lantz, Deputy Sheriff, who being duly sworn according to law, states that on June 22, 2005 at 5:46 o'clock PM, she served a true copy of the within Real Estate Writ, Notice of Sheriffs Sale and Description, in the above entitled action, upon the within named defendants, to wit: James C. Hoover and Linda 1. Hoover, by making known unto Linda Hoover, personally and wife of James C. Hoover, at 329 15th Street, New Cumberland, Cumberland County, Pennsylvania, its contents and at the same time handing to her personally the said true and correct copy of the same. Gerald Worthington, Deputy Sheriff, who being duly sworn according to law, states that on July 07, 2005 at 4:54 o'clock P.M., he posted a true copy of the within Real Estate Writ, Notice, Poster and Description, in the above entitled action, upon the property of James C. Hoover and Linda L. Hoover, located at 329 15th Street, New Cumberland, Pennsylvania, according to law. R. Thomas Kline, Sheriff, who being duly sworn according to law, states he served the above Real Estate Writ, Notice, Poster and Description in the following manner: The Sheriff mailed a notice of the pendency of the action to the within named defendants, to wit: James C. Hoover and Linda 1. Hoover, by regular mail to their last known address of 329 15th Street, New Cumberland, P A 17070. These letters were mailed under the date of July 05, 2005 and never returned to the Sheriffs Office. R. Thomas Kline, Sheriff, who being duly sworn according to law, states this writ is returned STAYED per instructions from Attorney Joseph Goldbeck. Sheriffs Costs: Docketing Poundage Advertising Posting Handbills Mileage Certified Mail Levy Surcharge Postpone Sale Prothonotary 30.00 435.30 15.00 15.00 27.20 1.75 15.00 30.00 20.00 1.00 I- 00 O-tt- Pi'tU> rOf nO f'l,/ Sworn and subscribed to before me This ~ day of j1!oVitnk 2005, A.D. Law Journal Patriot News Share of Bills , , J 263.00 248.39 18.20 $1119.84 Sc;~sJjli1l's b4 r~~~~ R. Thomas Kline, Sheriff BY J~~~ Real Estate rgeant Prothonotary J.(T'J ,-. ~"U.illi. .J 'i. ,jk Ck... 5/~J,.O /2.v in,"""""'!;; ".~"' . ~"- . ""'<" ~~ "~- -, ~ ---li .~ ~~~ ,--. ,<\ , , 1 'Goldbeck McCafferty & McKeever BY: Joseph A. Goldbeck, Jr. AttorneyI.D, #16132 Suite 5000 - Mellon Independence Center 70 I Market Street Philadelphia, P A 19106-1532 215-627-1322 Attorney for Plaintiff FIRST NATIONWIDE MORTGAGE CORPORATION PO Box 9481 Mail Code: 22-528-1011 Gaithersburg, MD 20898-9481 IN THE COURT OF COMMON PLEAS of Cumberland County Plaintiff vs. CIVIL ACTION - LAW JAMES HOOVER LINDA HOOVER (Mortgagor(s) and Record Owner(s)) 329 15th Street New Cumberland, P A 17070 ACTION OF MORTGAGE FORECLOSURE Defendant( s) No.01-3220-CrvIL AFFIDAVIT PURSUANT TO RULE 3129 FIRST NATIONWIDE MORTGAGE CORPORATION, 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: 329 15th Street New Cumberland, P A 17070 l.Name and address ofOwner(s) or Reputed Owner(s): JAMES HOOVER 329 15th Street New Cumberland, PA 17070 LINDA HOOVER 329 15th Street New Cumberland, P A 17070 2. Name and address ofDefendant(s) in the judgment: JAMES HOOVER 329 15th Street New Cumberland, P A 17070 LINDA HOOVER 329 15th Street New Cumberland, P A 17070 3. Name and last known address of every judgment creditor whose judgment is a record lien on the property to be sold: DOMESTIC RELATIONS OF CUMBERLAND COUNTY PO Box 320 ~. .Ilib.._- - ; . ~.,' .."'~~ ,."-'- ~ ~ . ""~--"'~~"'-;;. , j Carlisle, P A 17013 P A DEPARTMENT OF PUBU.c WELFARE - Bureau of Child Support Enforcement Health and Welfare Bldg. - Room 432 P.O. Box 2675 Harrisburg, PA 17105-2675 GREENWOOD TRUST CO. P.O. BOX 11848 HARRISBURG, PA 17108 BELCO COMM. CREDIT UNION 403 N. 2ND STREET HARRISBURG, PA 17101-1322 SOVEREIGN BANK c/o HEATHER A. SOLLEY 601 Penn Street Reading, P A 19601 WAYPOINTBANK 235 North 2nd Street P.O. Box 1711 Harrisburg. P A 17011 4. Name and address of the last recorded holder of every mortgage of record: FIRST FEDERAL SAVINGS & LOAN 234 N. SECOND STREET HARRISBURG, PA 17101 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. 1. Name and address of every other person of whom the plaintiff has knowledge who has any interest in the properly which may be affected by the sale. TENANTS/OCCUPANTS 329 15th Street New Cumberland, P A 17070 (attach separate sheet ifmore 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. CoSo Section 4904 relating to unsworn falsification to authorities. GOLDBEC M BY: JosephA. G I Attorney for Plain DATED: June 6. 2005 ,'~ _F-l -~ ~ '. ,J' -~ - ~ ~. ," Ii '(' - ~ - .i~'" OI-3220-CIVIL GOLDBECK McCAFFERTY & McKEEVER BY: Joseph A. Goldbeck, Jr. Attorney I.D.#16132 Suite 5000- Mellon Independence Center 701 Market Street Philadelphia, PAl 9 I 06 215-627-1322 Attorney for Plaintiff FIRST NATIONWIDE MORTGAGE CORPORATION PO Box 9481 Mail Code: 22-528-1011 Gaithersburg, MD 20898-9481 IN TIIE COURT OF COMMON PLEAS of Cumberland County Plaintiff CIVIL ACTION - LAW vs. JAMES HOOVER LINDA HOOVER Mortgagor(s) and Record Owner(s) ACTION OF MORTGAGE FORECLOSURE 329 15th Street New Cumberland, P A 17070 Term No.01-3220-CIVIL Defendant( s THIS LAW FIRM IS A DEBT COLLECTOR AND WE ARE ATTEMPTING TO COLLECT A DEBT. THIS NOTICE IS SENT TO YOU IN AN ATTEMPT TO COLLECT A DEBT. ANY INFORMATION OBTAINED FROM YOU WILL BE USED FOR THAT PURPOSE. NOTICE OF SHERIFF'S SALE OF REAL PROPERTY TO: HOOVER. JAMES .JAMES HOOVER 329 15th Street New Cumberland, PAl 7070 Your house at 329 15th Street, New Cwnberland, PA 17070 is scheduled to be sold at Sheriffs Sale on Wednesday, September 07, 2005, at 10:00 AM, in Connnissioners Hearing fun 2nd FL Courthouse to enforce the court judgment of $2 I ,056.5 I obtained by FIRST NATIONWIDE MORTGAGE CORPORATION against you. NOTICE OF OWNER'S RIGHTS YOU MAY BE ABLE TO PREVENT TillS SHERIFF'S SALE To prevent this Sheriffs Sale you must take immediate aclioo: 1. The sale will be cancelled if you pay to FIRST NATIONWIDE MORTGAGE CORPORATION, the back payments, late charges, costs and reasonable attorney's fees due. To fmd out how much you must pay call: 215-627-1322 ,~,~- "~ .'" I ,.;,'=< ~ ' , Ol-3220-CIVIL 2. You may be able to stop the sale by filing a petition asking the Court to strike or open judgment, if the judgment was improperly entered. You may also ask the Court to postpone the sale for good cause. 3. You may also be able to stop the sale through other legal proceedings. 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 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 amoWltdue in the sale. To find out if this has happened, you may call the Sheriff 0017-240-6390. 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 Wltil the full amouot 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 distributioo of the money bid for your house will be filed by the Sheriff within 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 SHODID TAKE THIS PAPER TO YOUR LAWYER AT ONCE. IF YOU DO NOT HA VB A LAWYER OR CANNOT AFFORD ONE, GO TO OR TELEPHONE TIlE OFFICE LISTED BELOW TO FIND OUT WHERE YOU CAN GET LEGAL HELP. LEGAL SERVICES INC 8 Irvine Row Carlisle, P A 17013 CUMBERLAND COUNTY BAR ASSOCIATION 2 Liberty Avenue Carlisle, P A 17013 ,= - ~~.- -~-- . .~~ - '"' Ol-3220-CIVIL GOLDBECK McCAFFERTY & McKEEVER BY: Joseph A. Goldbeck, Jr. AttorneyLD.#16132 Suite 5000- Mellon Independence Center 701 Market Street Philadelphia, P A 19106 215-627-1322 Attorney for Plaintiff FIRST NATIONWIDE MORTGAGE CORPORATION PO Box 9481 Mail Code: 22-528-1011 Gaithersburg, MD 20898-9481 IN THE COURT OF COMMON PLEAS of Cumberland County Plaintiff CIVll.. ACTION - LAW vs. JAMES HOOVER LINDA HOOVER Mortgagor(s) and Record Owner(s) ACTION OF MORTGAGE FORECLOSURE 329 15th Street New Cumberland, P A 17070 Term No. 01-3220-CIVll.. 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: HOOVER, UNDA LINDA HOOVER 329 15th Street New Cumberland, P A 17070 Your house at 329 15th Street, New Cumberland, P A 17070 is scheduled to be sold at Sheriffs Sale on Wednesday, September 07,2005, at 10:00 AM, in Commissioners Hearing fun 2nd FL Courthouse to enforce the court judgmeot of $21 ,056.51 obtained by FIRST NATIONWIDE MORTGAGE CORPORATION 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 FIRST NATIONWIDE MORTGAGE CORPORATION, the back payments, late charges, costs and reasonable attorney's fees due. To find out how much you must pay call: 215-627-1322 ~l~'~. -~ .~- , , . ' Ol-3220-CNlL 2. You may be able to stop the sale by filing a petition asking the Court to strike or open judgment, if the judgment was improperly entered. You may also ask the Court to postpone the sale for good cause. 3. You may also be able to stop the sale through other legal proceedings. 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 Sheriff's 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 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 Sheriff of717-240-6390. 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 within thirty (30) days from the date of the Sheriff's Sale. This schedule will state who will be receiving that money. The money will be paid out in accordance with this schedule unless exceptions (reasons why the proposed distribution is wrong) are filed with the 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. LEGAL SERVICES INC 8 Irvine Row Carlisle, PA 17013 CUMBERLAND COUNTY BAR ASSOCIATION 2 Liberty Avenue Carlisle, P A 17013 - . "" ~ " "' , ' ., . ~"-~ ,,~ ," ~" .' '-1:'"". :~1 - ", GOLDBECK McCAFFERTY & MCKEEVSR 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 First Nationwide Mortgage Corp. P.O. Box 9481, Mail Code: 22-528-1011 Gaithersburg, MD 20898-9481 Vs. John o. Osgood (Mortgagor only) Susan C. Osgood (Mortgagor only) 52 Catoctin Court Silver Springs, MD 20906 CUMBERLAND COUNTY COURT OF COMMON PLEAS CIVIL DIVISION NO 01-3220-Civil James Hoover (Real OWner only) Linda Hoover (Real OWner only) 329 15th Street New Cumberland, PA 17070 ALL THAT CERTAIN lot or tract of land situate in the Borough of New Cumberland, County of Cumberland and State of Pennsylvania, more particularly bounded and described as follows according to a survey of D.P. Raffensperger (49-29) dated March 4, 1974, to wit: BEGINNING at a point on the Northern side of 15th Street said point being 870.8 feet west of Bridge Street; thence extending along 15th Street South 62 degrees West 50 feet to a corner of lot number 30 on the hereinafter mentioned plan of lots; thence along lot number 30 north 28 degrees West 195 feet to a point a corner; thence North 62 degrees East 50 feet to a point a corner; thence extending through lot number 31 on said plan South 28 degrees East 195 feet to the point and place of BEGINNING. Being a part of lot numb~r 31 Section E plan of Hillside as recorded in the Cumberland County Recorder's Office in Plan Book 1. page 75. Having thereon erected a two story frame dwelling and detached frame garage known as 329 15th Street. Tax Parcel #26-23-0541-133 .-- ,'~ ,-,- ,. ., "'. ,'"""- ",,0 'J _L_ "-~...~~.L ., ~, c~JU",-",.,\--,," -. -',' " "~i WRIT OF EXECUTION and/or ATTACHMENT COMMONWEALTH OF PENNSYLV ANTA) COUNTY OF CUMBERLAND) NO 01-3220 Civil CIVIL ACTION - LAW TO THE SHERIFF OF CUMBERLAND COUNTY: To satisfy the debt, interest and costs due FIRST NATIONWIDE MORTGAGE CORPORATION, Plaintiff (s) From JAMES HOOVER AND LINDA HOOVER (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 himlher that helshe has been added as a garnishee and is enjoined as above stated. Amount Due $21,056.51 Interest FROM 9112101 AT 0.0100% L.L. Arty's Comm % Atty Paid $1486.40 Plaintiff Paid Date: JUNE 8, 2005 Due Prothy $1.00 Other Costs CURTIS R. LONG (Seal) Prothonotary ~ __By: iZw"1'!.- P. 'l2/J-,L~ Deputy REQUESTING PARTY: Name JOSEPH A. GOLDBECK, JR., ESQUIRE Address: SIDTE 5000 - MELLON INDEPENDENCE CENTER 701 MARKET STREET PHILADELPHIA, FA 19106-1532 Attorney for: PLAINTIFF Telephone: 215-627-1322 Supreme Court ill No. 16132 ~ ~ @ r:;::;::1 ~ lOL.:t:'} ~ ~" -~ . -- ., ... ~ ~PFFi.9E OF HiE. \".H1fh. PI fl."'.. .'f,SI HERIFF ''',f,',"' 'I"TV P' ."1,", [", i J, /,\ l005 JUN -q A q: 38 Real Estate Sale #66 On June 13, 2005 the SheriffIevied upon the defendant's interest in the real property situated in New Cumberland Borough, Cumberland County, P A Known and numbered as 329 15th Street, New Cumberland, more fully described on Exhibit "A" filed with this writ and by this reference incorporated herein. Date: June 13,2005 ByJ(Jrlu~l Real E;t~ Deputy .. I Tf1~~~~ ,~-.I"".,.,!;j, , ~_ ,-il! "~,4""" ".~,~~.~~tlIIlJI(IJ~'~~"!!'1""'fW'(i"~~';:""W'~i';ii'~~~~,:,':'l~~~:W;#;~Jlj!lfl'~;L~'!'R~"'J'l~\L\'''''''-''"~'1''''i'!f''~'''l>lr~~j1!R1~'';j_~ - ., , J~ . " "', , :",-, '''I .hl ,. . """" '1,"'..,'4".".",.. ~~ " " ~ 'i~' '] '" _ _ATE SALE Neil. 8ti Writ No. 2001-3220 Civil 'First Nationwide Mortgage Corp. vs. James Hoover and Linda Hoover Atty.: Joseph Goldbeck ALL THAT CERTAIN lot or tract of land situate in the Borough of New Cumberland, County of Cumberland and State of Pennsyl- vania. more particularly bounded and described as follows according to a survey of D.P. Raffensperger (49-29) dated March 4. 1974. to wit: BEGINNING at a point on the Northern side of 15th Street said point being 870.8 feet west of Bridge Street; thence extending ,.along 15th Street South 62 degrees West 50 feet to a corner of lot num- ber 30 on the hereinafter mentioned plan of lots; thence along lot num- ber 30 north 28 degrees West 195 feet to a point a corner; thence North 62 degrees East 50 feet to a point a corner; thence extending through lot number 31 on said plan South 28 degrees East 195 feet to the point and place of BEGlNNlNG. Being a part of lot number 31 Section E plan of Hillside as re- corded in the Cumberland County Recorder's Office in Plan Book 1. page 75. Having thereon erected a two story frame dwellJng and detached frame garage known as 329 15th Street. Tax Parcel 11-26-23-0541-133. "-I=.~" ~.-, ,'" .'-',," . "",",,,,';"-'-" v,'"'_.,..',;,;; ~"- PROOF OF PUBLICATION OF NOTICE IN CUMBERLAND LAW JOURNAL (Under Act No. 587, approved May 16, 1929), P. L.1784 COMMONWEALTH 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 official legal periodical for the publication of all legal notices, and has, since January 2, 1952, been regularly issued weekly in the said County, and that the printed notice or publication attached hereto is exactly the same as was printed in the regular editions and issues of the said Cumberland Law Journal on the following dates, VIZ: July IS, 22, 29, 2005 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. TO AND SUBSC ED before me this 29 day of Julv, 2005 NOTARIA SEAL LOIS E. SNYDER, Notary Public Carlisle BolO. Cumbelland County My Commission Expires March 5. 2009 ,.".,"".-~.',~,'.- , .'_.~.' "" ,. ,.'. 1,.~:'~".0;::"~'^"'" ~~.fu."'..~~~~"~'.~~'~ . 'Cl;'1rr~i:in .. .. ':\:l~t~itrridN . . ' ...:.:.::....,..,. If!~i '!'lrdi(id~b.' \9J.4to "e .. .,.... ." _!It . :.~ .,""",:'.:,-"':;',':'i'i,',''' , ':';":'~':'::: ,;:. ~t!f c~1!:i~'...'_~75.,-.._... ,'Tf',.: ____~' _'__ __ -,,;,,.'"...:0---- -' - - .- :;:: . , ~~ " I ~~ d '" - .,,"," , ~ , .. )'" ~ '. , 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 Assistant Controller of The Patriot News Co., a corporatiou 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 Dauphir!, 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 19th and 26th day(s) of July and the 2nd day(s) of August 2005. That neither he nor said Company is interested in the subject matter of said printed notice or advertising, and that all of the allegations of this statement as to the time, place and character of publication are true; and That he has personal knowledge of the facts aforesaid and is duly authorized and empowered to verify this statemeut 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 Miscellaneo ook "M", Volume 14, Page 317. PUBLICATION COpy SALE #66 CUMBERLAND COUNTY SHERIFFS OFFICE CUMBERLAND COUNTY COURTHOUSE CARLISLE, PA. 17013 Statement of Advertising Costs . To THE PATRIOT-NEWS CO. For publishing the notice or publication attached hereto on the above stated dates 248.39