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HomeMy WebLinkAbout01-03950McCABE, WEISBERG AND CONWAY, P.C. BY: TERRENCE J. McCABE, ESQUIRE Identification Number 16496 First Union Building 123 South Broad Street, Suite 2080 Philadelphia, Pennsylvania 19104 (215)790-1010 Household Finance Consumer Discount Company 961 Weigel Drive, P.O. Box 8634 Elmhurst, IL 60126-1058 v. Linda Jean Keef, a/k/a Linda J. Keef 944 Cavalry Street Carlisle, PA 17013 Attorney for Plaintiff Cumberland County Court of Common Pleas Number Q ~ - ~qS~ ~1 U t ~, I~2 ~,,, CIVIL ACTION/MORTGAGE FORECLOSURE NOTICE AVISO You have been sued in court If you wish to defend against the claims set forth in the following pages, you must take action wither twenty (20) days after this complaint and notice are served, by entering a written appearance personally or by attorney azid filing in writing with the court your defenses or objections tothe 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 fox any other claim or relief requested by the plaintiff. You may lose money or properly or other rights important to you. Le han demandado a usted en la torte. Si usted quiere defenderse de estas demandas ex-puestas en las paginas siguientes, usted tiene veinte (20) dial de plazo al partir de lafechadelademandaylanotificacion. Hacefaltaasentar una compazencia escrita o en persona o con un abogado y entregaz a la torte en forma escrita sus defenses o sus objeciones a las demandas en contra de su persona. Sea avisado que si usted no se defiende, la torte tomaza medidas y puede continuaz la demands en contra soya sin previo aviso o notification. Ademas, la torte puede decide a favor del demandante y xequiere que usted cumpla con todas las provisiones de esta demands. Usted puede perder dinero o sus propiedades u otros derechos importantes pars usted. YOU SHOULD TAKE THLS PAPER TO YOUR LAWYER AT ONCE. IF YOU DO NOT HAVE A LAWYER OR CANNOT AFFORD ONE, GO TO OR TELEPHONE THE OFPICE SET FORTH BELOW TO FIND OUT WHERE YOU CAN GET HELP. Cumberland County Baz Association 2 Liberty Averrue Cazlisle, PA 17013 (717) 249-3166 LLEVE ESTA DEMANDA A UN ABOGADO INMEDIATAMENTE. SINOTIENEABOGADOOSINO TIENE EL DIIVERO SUFICIENTE DE PAGAR TAL SERVICO, VAYA EN PERSONA O LLAME POR TELEFONO A LA OFICINA CUYA DIItECCION SE ENCUENTRA ESCRITA ABAJO PARA AVERIGUAR DONDE SE PUEDE CONSEGUIR ASISTENCIA LEGAL. Cumberland County Bar Association 2 Liberty Avenue Carlisle, PA 17013 (717) 249-3166 McCABE, WEISBERG AND CONWAY, P.C. BY: TERRENCE J. McCABE, ESQUIRE Identification Number 16496 First Union Building 123 South Broad Street, Suite 2080 Philadelphia, Pennsylvania 19109 (215)790-1010 Household Finance Consumer Discount Company 961 Weigel Drive, P.O. Box 8634 Elmhurst, IL 60126-1058 v. Linda Jean Keef, a/k/a Linda J. Keef 944 Cavalry Street Carlisle, PA 17013 Attorney for Plaintiff Cumberland County Court of Common Pleas Number ~ / - 3 4 SU ~ ~~'~ CIVIL ACTION/MORTGAGE FORECLOSURE 1. Plaintiff is Household Finance Consumer Discount Company, a corporation duly organized under the laws of Pennsylvania and doing business at the above captioned address. 2. The Defendant is Linda Jean Keef, a/k/a Linda J. Keef, who is the mortgagor and real owner of the mortgaged property hereinafter described, and her last-known address is 944 Cavalry Street, Carlisle, PA 17013. 3. On 11/18/99, mortgagor made, executed and delivered a mortgage upon the premises hereinafter described to Plaintiff which mortgage is recorded in the Office of the Recorder of Cumberland County in Mortgage Book 1583, Page 181. 4. The premises subject to said mortgage is described in the mortgage attached as Exhibit "A" and is known as 944 Cavalry Street, Carlisle, PA 17013. 5. Themortgageisindefaultbecausemonthlypaymentsofprincipalandinterestupon said mortgage due 2/1/ 01 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 $113,786.16 Interest 1/1/01 through 6/1/01 $ 3,253.10 (Plus $24.93 per diem thereafter) Attomey's Fee $ 5,689.31 Cost of Suit $ 225.00 Appraisal Fee $ 125.00 Title Search $ 200.00 GRAND TOTAL $123,278.57 The attorney's fees set forth above are inconformity with the mortgage documents and Pennsylvania Law and will be collected in the event of a third party purchaser at Sheriff's Sale. ff 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 as required by Act 6 of 1974 (41 P.S. §403) and notice required by the Emergency Mortgage Assistance Act of 1983 as amended under 12 PA Code Chapter 13, et seq., commonly known as the Combined Notice of Delinquency has been sent to Defendant by certified mail on the date set forth in the true and correct copies of such notices attached hereto as Exhibit "B." WHEREFORE, Plaintiff demands Judgment against the Defendant in the sum of $123,278.57, together with interest at the rate of $24.93 per diem and other costs and charges collectible under the mortgage and for the foreclosure and sale of the mortgage property. TERRENCE J. McCABE, ESQUIRE Attorney for Plaintiff • 1• 713303 MORTGAGE IF SOX IS CIiECKED, TAIS MOH3GAGP IS AN bT+EN-END BpVANCES. MoaxGAGS AND 58CURES Fu'ruRH THIS MQRTGAGE is mach this day ~ g7H of NOVEMBER 19 99 ,between the Mortgagor, a corporation organized an ex~sttng under the laws o pENNSYLVAN i A ,whose addre~5 is The following paragraph preceded by a checked box is applicable. WHEREAS, Borrower is indebted to Lender in the principal sum of $ 115, 196.19 evidenced by Borrower's Loan Repayment and Security Agreement or Secondary ortgage an greement dated NOVEMBER 18, 1998 and any extensions or renewals thereof (herein "Nett"}, providing Por monthly installments of princi and interest, intruding any adjustments to the amount of payments or the contract rate if that rau is variable, with the balance of the indcbtcdacss, if not sooner paid, due and payable on Nt)vEMBER 18 , zDZg ; O WHfiREAS, Borrower is indebted to ).ender in the principal sum of $ , or so much thereof as may be advanced pursuant to Borrower's Revolving Loan Agreement dated and extensions and renewals thereof (herein "Note"}, providing Por monthly installmenc5, and interest at the rate an under the terms specified in the Note, including any adjustments in the ;nterrat rate if that rate is variable, and providing for a credit limit stated' in the principal sum above and an initial advance of $ , TO SECURE to Lender the repayment of (1) the indebtedness evidenced by the Note, with interest thereon, including any increases if the contract rate is variable; (2} future advances under any Revolving Loan Agrcement; (3} the payment of all other sums. wish interest thereon, advanced in accordance herewith to protect the security of this Mortgage; and (4} the performance of the cpvenants and agreements of Borrower herein oentained, Borrower does hereby mortgage, grant and convey to Lender and Lender's successors and assigns the Following described property located in the County of CUMBERLAND Commonwealth of Pennsylvania: ALL THAT CERTAIN PROPERTY SITUATED IN THE TOWNSHIP OF NDRTH MIODLETON IN THE COUNTY OF CUMBERLAND ANp GOMMONwEAL7H OF PENNSYLVANIA, BEINO MORE FULLY OESCRIBEO IN A FEE SIMPLE GEED OATEO 04/15!1983 AND RECORDED 0411811983, AMONG THE LAND RECORDS OF THE COUNTY AND STATE SE7 FORTH ABOVE, IN VOLUME.'30 PAGE 31B. TAk PARCEL ID: 29-19-1639-0'11 XHIBIT "A' os-zo-ss MTG wLe capr ~UgIdI~UUllplplltU~IAQ~g111VAU~A41J~lAl11~11~~IIq~Nq~l~~11{{~I PA00126t z0'd GLZt06LSlZi6 O1 GGLL L1S 0ES Q10H3Sf10H ild Wd 6Z~L I00Z b0 N(lf .. t, -z- TOGETHER with ell the improvements now or hereafter erected on the property, and act easements, tights, appurtenances and rents, all of which shall be dcemed to be and remain a part of the property covered by this Mortgage; and all of the foregoing, together with said property (or the leasehold estate if this Mortgage is on a (easchold) are hereinafter refefted to as the "Property." Borrower covenants [hat Borrower is [awfully Seised o4 the estate hereby wnveyed and has the right to mortgage, grant and convey the Property, and that the properly is unendumberad, except for encumbrances of record- Borrower covenants that Borrower warrants and will defend generally the title to the PropeRy against all claims and demands, subject tv encumbrances of record. UNIFORM COVENANTS. Borrower and Lender covenant and agree as follows: I. Payment of Principal and Interest at Variable Rates. This mortgage eeeures all paymcntsof principal and interest due on a variable rate loan. The contract sate of interest and payment amounts may be subject to change as provided in the Nvte, Borrowers shall promptly pay when due ail amounts required by the Notc, 2. Funds for Taxes and Insurance. Subject to applicable lan• or waiver by Lender, Borrower shall pay to Lander on the day monthly payments of principal and interest are payable under the Note, until the Note is paid in full, a sum (herein "Funds") aqua! to one twelfth of the yearly taxes and assessments {including condominium and planned unit development assessments, if any) which may attain priority over this Mortgage end ground rents on fie Property, if any, plus one-[welfth of yearly premium installments for haaard insurance, plus one twelfth of ytarly premium installments for mortgage insurance, if any, all as reasonably estimated initially and from time to time by Lender on the basis of assessments and bills and reasonable estimates thereof. Borrower shall not be obligated to make such payments of Funds to Lender to the cstcnt that Borrower makes such payments to the holder of a prior mortgage or deed of trust if such holder is an instituti0n81 lender, if Borrower pays'Funds to Lender, ehc Funds shall be he]d in an institution the deposits or accounts of which era insured or. guaranteed by a Federal or state agency (including Lender if Lender is such an institution), Lender shall apply theFvnds to pay said taxes, assessments, insurance premiums and ground rents. Lender may not charge for so holding and, applying the Funds, aralyaing said account or verifying and compiling said assessments and bills, unless Lender. pays Borrower interest on the Funds and applicable law permits Lender to make such a charge. Borrowtr and Lender may agree in writing at the time of execution of ibis Mortgage FhaL interest on [Ice Funds shal- be paid t0 Borrower, and unless such agreement is made or applicable law requires such interest to be paid, Lender shall not be required to'pay Borrower any interest or earnings on the Funds. Lander shall give to Harrower, without charge, an annual accounting of the Funds showing credits and debits to the Funds and the purpose far which each debit to the Funds was made. The Funds era pledge) as additional security for the sums secured by this Mortgage. ]f the smount of the Funds held by Lender, together with the future monthly installments of Funds payable prior to the doe dates of taxes, assessments, insurance premiums and ground rents, shall exceed the amount required to pay said Eaxw, assessments, insurance premiums and ground rents as they fall due, such excess shall be, at Borrower's gpsion, Cither promptly ropaid to Borrower or credited to Borrower on monthly installments of Funds. if the amount of the'.Funds held by Lender shalt not be sufficient to pay taxes, asse~mcnts, insurance premiums and ground rents as they fall due, Borrower shall pay to i.ender any amount necessary to makt up the deficiency in one er more payments as Leader may require. i Upon ~syment in full of ell sums secured by [his Mortgage, Lender shall promptly refund to Borrowtr any funds held Ipy Len;Ber. ]f under paragraph 17 hereof the Property is sold or the Property•is otherwise acquirod by Lender, Lender shall! apply, no later than immediately prior to the sale of the Property or its acquisi lion by Lender, any Funds held by Lcn',der at the time of applica[ion as a credit against the sums secured by this Mortgage. , 3. Application of Payments. )xcept for loans made pursuant to the Pennsylvania Consumer Discount Company ~lct, all payments received by Lender under the Note aad paragraphs 1 and 2 hereof shall be applied by Lcndcr first in payment of amotmts payable to Lander by Borrower under paragraph 2 hereof, than to interest, cad then to the principal. 4. Prior Mortgagee and Deed of Trust; Charges; Liens. fiorrowcr shall perform all of Borrower's obligations under any tz?ortgage, died of toter or other security agreement with a lien which has priority over this Aortgage, including Borrower's covenants to make payments when due. $orrower shall pay or cause to be paid all taxes, assessments and other charges, fines and impositions autibutsble to the Ptnperty which may attain a priority aver this Ttfortgage, and leesehatd payments or ground rents, if any. a9-2a-99 Mn~ Fllf G9Pt (IRNNI NI~~~O~~NaN~fN911{IfW7ftI~I~~~alllatl~aal~Wll'~H PAt101262 E0' d bL2I06LS I Z I6 Ol b7LL L i 9 0E9 Q"lOH3Sf10H ?Jd Wd 62 ~ L 1001; b0 Nflt -- ~ --- ~ , -3- 5. Hazard Insurance. $orrower shall keep the improvements now existing or hereafter erected on the Property insured against loss by fire, hazards included within the term "eYtendedcoverage," and such other hazards as L-ender may [squire. The insurance carrier providing the insurance shall be chosen by the Borrower subject to approval by Lender; provided, that such approval shall not be unreasonably a-ithhald. ALl insurance policies and renewals thereof shall be in a form acceptable to Lender and shall include a Standard mortgage clause in favor of and in a form acceptabls to Lander. Lender shall Nava the right to hold the policiesand renewalsthereof,subject tothe termsoPany mortgago, deed of trust or othcrsccurity agreement with a lien whiuh has priority over this Mortgage. in the event of loss, Borrower shall give prompt notice to the insurance carrier and Lender. Lender may make proof of loss if not made promptly by Borrower. Ifthe Property is abandcned by Borrower, or if Borrower fails to respond to Lender within 30 days from the date notice is mailed by Lender to Borrower that the insurance carrier offers to settle a claim for insurance benefits, Lender is authorized to collect and apply the insurance proceeds at Lender's option either to restoration or repair of the Property or m the aumssecured by thisMortgage. 6. Preservation and Maintenance of property; Leaseholds; Condominiums; Planned Unit Developments. Borrower shall keep the Property in good repair and shell notcammit waste or permit impairment or deterioration of the Property and shall wmply with the provisions o£ any lease if this Mortgage is on a leasehold. If chis Mortgage is on a unit in a condominium or a planned unit development, Borrower shall perform all of Borrower's obligations under the dxlaration or opvenants erecting or governing the condominium Or planned unit development, the bylaws and regulations of the condominium or planned unit development, and cvnstituentdvcuments. 7. Protection of Lender's Security. If $orrower fails to perform the covenatatsand agreements contained in this ?Nortgago, or if any action or proceeding is commenced which materially affects Lender's interest in the property, than Lender, at Leader's option, upon notice to Borrower, may make such appearances, disburse such sums, including seasonableattarneys fees,andtakesuchactionasisneccssarytoprotccrLender'sinterest. Any amounts disbursed by Lender pursuant to this paragraph 7, with interest thereon, at the contract rate, shall become additional indebtedness of $orrower secured by this Mortgage. Unless Borrower.and Lenderagrcc to othcrtetzns oP payment, Such amounrssttall be payable upon notice from Lender to $orrower requesting payment thereof. Nothing contained in thisparagraph7shaltrequireLendertoincuranyexpenseortakeanyactionhereunder. _ _8._Inspection...Lendec.may_take or. cause.. to be .made.reasonable.entries upon...ancLJnspectpns._pf the.Prpperty, provided that Lender shall give Borrower notice prior to any such inspection specifying reasonablecause thsrefarrelated to Lender's interest in the Property. 9. Condemnation. The proceeds of any award or claim fordamages, direct orconsequential, in connection with any condemnation or other taking of the Property, or part thereof, or for conveyance in lieu of condemnation, are hereby assigned and shall bepaid to Lender, subject to the terms of any mortgage, deed of trust or other security agreem ent with a lien which has priority over this Mortgage. 10. Borrower Not Iteleascd; Forbearavca By Lender Not a 'iJVaiver. Extension of the time for payment or modification of amortization of the gums sxured by this Mortgage granted by Lander to any successor in interest of Borrower shall not operate to release, in any manner, the liability of the original Borrower and $orrower'a successors in interest. Lender shall not be required to commence proceedings against such successor or refuse to extend time for payment or otherwise modify amortization of the sums secured by this Mortgage by reaspn of any demand made by the ' original Borrower and Borrower's successors in interest. Any Forbearance by Lender in exercising any tight or remedy hereunder, or otherwise afforded by applicable law, shall not be a waiver of or preclude the exercise of any such right.or remedy. 1 i. Successors and Assigns Bauud; Joist and Several Liability; Co-signers. The covenants and agreements herein contained 6ha11 bind, and the rights hereunder shall inure to, the respective successors and assigns of Lender and Borrower, subject to the provisions of paragraph 16 hereof. All covenants and agreements of Borrower shall be joint and several. Any Aarrower who cv signs this Mortgage, but does not execute theNote, {a) is co-signing this Mortgageon]y to mortgage, grant and convey that $orrower's interest in the Property to Lender under the termsof this Mortgage, (b) is not personalty liable on the Note or under this Mortgage, and (c) agrees that Lender and any ether Borruwer hereunder may agree to extend, modify, forbear, ur mnke auy otter accvmmud-atiuns with regard iv tltc terms of this Mortgage or the Nate without that Borrower's consent and without releasing that $orrower or modifying this Mortgage as to that Borrower'sinterestinfhe Property. 09-20-99 MTG PA061263 r~~E ~e~t INIIQIII~~Q~~illll~llllilllllllll~l~iillll~l8l~llll~llllllll~llllll~~ b0' d bL2I 06LS I it 16 Ol bbLL L 19 0E9 Q~OH35f10H bd Wd 6i? ~ L T 0e2 b0 Nllf -¢ . 12, Notice. Lxcept for any notice requited under applicable law to be given in another manner, (aj any cotter to Borrower provided for in this Mortgage shad be given by delivering it or by mailing such notice by certified mail addressed to Borrower at the Property Address or at such other address as Ilnrrower may designate by notice tv Lender as provided herein, and (b}any Halite to Lendcrahafl bo given by certified mail to Lender's address stated herein or to such other address ag Lender may designate by rtoticc to Borrower as provided herein. Any nett ce provided fur in thisMortgage shall bedeemed to have been given to Borrower or Lenderwhengiven in the mannerdesignated herein. 13. Governing Law; Scvcrabilfty. The state and Local laws applicable to this Mortgage shall be the laws of the jurisdiction in which the Psopertyislocat~d. The foregoing sentence shall not limit the applicability of Federal law to this Mortgage. Tn the event that any provision or clauseaf this Mortgage or the Note conflicts with applicable law, such conflict shall not affect otherprovisions of this Mortgage or the Note which can be given effect without the conflicting provision, and to this end the provisions of this Mortgage and the Note arc declared to be severable. As used herein, "casts." "expenses" and "attorneys' fees" include all sums Lo the extent not prohibited by applicable law or limited ht:roin. 14, Borrower's Capy. Borrower shall be furnished a conformed copy of the Nvtc and of this Mortgage at the Lime of execution orafter recordation hereof. l5. Rehabilitation Loan Agreement Borrower shall fulfill all of Borrower's obligations under any home rehabilitation, improvcmcnt, repair, or other loan agreement which Borrower enters into with Lender. Lender, at Lender'soption,roay require Borrower to execute and deliver to Lender, in a form acceptable to Lender, an assignment of any rights, claims or defenses which Borrower may have against parties who Supply labor, materials or services in connection with improvements made to the Property 16. Transfer of the property. If Borrower sells or transfers all or any part of the Property or an interest theroin, excluding (a) thccreation of a lien or encumbrance subordinate to this Mortgage, (b) a transfer by devise, descent, or by operation of law upon the death of a joint tenant, (c) the grant of any leasehold i ntereac of three years or less not containing an option to purchase, (d} thecrcation of a purchase money security inurest for household appliances, lei a transfer tv a relative resulting from the death of a Borrower, {f) a transfer where the spouse or children of the Borrower become an owner of the properly, (g} a transfer resulting Prom a decree of dissolution of marciage, legal separation agreement, or from an incidental property settlement agreement, by which she spouse of the Borcower becomes an owner of the property, (h) a uansfer loin an inter r-ivos trust in which the Borrower is and remains a beneficiary and which does not relate to a transfer of rights of occupancy in the property, or {i) any other ttansFeror disposition described in regulations presCribetF, by the Federal Elome..Lvan Bank..Board, Borrower shal].canseao besubmitted.information required by Lender to coal uatc the transferee as if a new loan were being made tb the transferee, Borrower will continue to be obli gated under the Note and thisiUortgage unlessLeader releases $orrower in writing, [F Lender does not agree to such sale or transfer, Lender may declare al I of the sums secured by this Mortgage to be imrnediate[y due and paysble, if Lender exercises such option to accelerate, Lender shall mail Borrower notice of acceleration in accordance with paragraph 12 hereof. Such notice shall provide a period of not less than 30 dabs from the data the notice is mailed or deli oared within which Borrower may pay the sums declared due. ff Borrower Faits to pay such sum8 Prior to the expiration of such period, Lender may, without further notice or demand on Borrower, invoke any remedies permitted by paragraph 17 hereof. NONUNIFORM COVENANTS, Borrower and Lender f ur'ther covenant and agree as fol lows: 17. Acceleration; Remedies. Except as providefl in paragraph 16 hereof, upon Borrower's breach of any covenant or agreement of Borrower in this Ivfartgagc, including the covenants to pay when due any sums secured by this Mortgage. Lender prior to acceleration shall give notice to Borrower as provided in paragraph 12 hereof specifying. (!) the bleach; (2) the action inquired to cure such breach; (3) a date, not less than 30 days from the date the notice is mailed to Borrower, by tvhicfi such breach must be cored; and (4) that Failure to cure such breach on or before the date specified in the notice may result in acceleration of the sums sceured by this Mortgage, foreclosure by judicial proceeding, and sale of the Property, The notice shalt further inform Borrower of the right to reinstate after acceleration and the right to assert in the foreclosure proceeding the nonexistence of a default or any other defense of Borrower to acceleration and foreclosure, IS the breach is not cttred on or before the date specified in the notice, Lender, at Leader's option, may declare all of the sums secured by this Mortgage to be immediately due and payable without further demand and may foreclose this Mortgage by judicial proceeding. !ender shall be entitled to collect in such proceeding alt expenses of foreclosure, including, but not limited to, reasonable attorneys fees and costs o[ documentary evidence, abstracts and titlereports. a9-29.49 MTG PAOOt264 ~~ ells ~pY IIIII~UI~IIIVaI~~~UUIl~IIll~ll S0' d bL2I06LS I Z I6 Ol bbLL L T9 0E9 Q~OH3SflOH lid Wd 0E ~ L T 00Z b0 N(lf fi'r' J" N __ ,. Y ~ .: 1 _5_ 1S. Borrower's Right to Reinstate. Notwithstanding Lender's accc(cration of the sums by this Mortgage due to Borrower's bleach, Borrower shall have the right tp have at~y proceedings begun by Lender to enforce this Mortgage discontinued at artiy time prior to entry of a judgment enforcing this Mortgage if: (a) Borrower pays Lender all sums which would be then doe under this Mortgage and the Note had no acceleration occurred; (b) Borrower cures sil breeches of any other covenants or agreements of Borrower contained in this Mortgage; (e) Borrower pays all reasonable expansrs incurred b5 Lander in enforcing the covenants and agreements of $orrawcr contained is this Mortgage, and in enforcing Lender's remedies as provided in parngraph 77 heroof, including, but not limited to, reasonablm attorneys' fees; and (d) Borrower takes such action as Lander may rwsonably require to assure that the lien of this Mortgage, Lender's interest in the Property and $orrower's obligation to pay the sums secured by this Mortgage shall continue unimpaired. Upon such payment and cure by Borrower, this Mortgage anfl the obligations smeared hereby shall remain in full force and effect as iF no acceleration had occurred. 19. Assignment of Rents; Appointment of Receiver. As additional security hereunder, Borrpwer hereby assigns to Lender the rents of the Property, provided that Borrower shalt, prior to acceleration under paragraph 17 hereof, in abandonment of the Property, have the right to collect and retain such rents as they bernrne due and payable. :U~on acceleration under paragraph .7, hereof or abandonment of the Property, Lander shall be entitled to have s roccivei• appointed by a. court.to,'entcr upon, take possession of and manage the Property and to collect the rents of the Property including those past due. All rents collected by the receiver Fhall be applied first w payment oP the costs of rnanagcmcnt of the Property and collection of rents, including, bux not limited to, receivers fees, premiums an receivers bonds and reasonable attorneys' feCS, and then to the.sums secured by this Mortgage. The teceivet shall bC liable to account only Por those rents actually received, 20. Release. Upon payment of ail sums secured by this Mortgage, Lender shall release this Mortgage without charge to Borrower. Borrower shall pay all costs of recordation, if any. 2l. Waiver of homestead. Borrower hereby waives alt right of homestead exemption In the Property under state or Federal law. 22, interest Rate After Judgmsat. borrower agrees the interest rate payable after a judgment is entered on the Note or in an action of mortgage foroclosun shall be the taro stated in the Notc. ' A9 Yliitf09 ~'-,~°:"..~~'g, ":tn ~,~,•: ~ "r„ ~ n. ro a m m ~ ,', t tc~s,saJln4~~.•~r, -- n - _ _ :~ :'Atj Mf tr"l~ t'"lf'11 J~ •. ~ ~.1'. ^ ~'.~ ~\'_ 09-2(1-99 A7fG PA007265 F~tE tart IIB~IIIVAIn~NVVVIIIIIII~II~~gIIVVIV~~~~~1~V~lullVll 90' d 6L2 [ 065 I z T 6 Ol bVLL L I9 0E9 Q~OH3Sf10H 21d Wd I6 ~ L 1002 40 Nflf •~ -~- REQUEST POR NOTICE OF DEFAULT ANA FpRECLOSURE UNDER sU1PERIOR ' MpRTGAGES OR DEEDS OF TRUST Borrower and Lender request the holder of any mortgage, decd of trust or other encumbrance with a Tien which has priority over this tl3ortgage to give Notioe to Lender, at Lender's address set forth on page one of this Mortgage, of any default under the etsperior encumbrance and of eny sate or other foreclosure action. JOHN M KEEF (DECEASED) -Sorrewar LINDA J KEEL ~ -Borrower Thereby certify that the precise address of fhe Lender (Mortgagee) is HOUSEHOLD FINANCE 25'GATEWAY'DRIVE MECHANICSBURG PA 17055 4n behatf of theT,ender.I4y: ' RERNIE HEFFEI.FINGER Title: BRANCH MANAGER COit~MONWEALTHpFPENNSYLVANiA, CUMBERLAND Countyss: 1, ANNE A 5FA F F D RD _ _ , a Notary Pubfic in and for said county and state, do hereby certify that personally known to me to be the same person(s) whose name{s) are subscribed to the foregoing instrument, appeared before me this day in person, and acknowledge tf~nt -_,,,Zhu,.~ signed and delivered the said instrument es thpii' free voluntary act, for the uses and purposes therein set forth. Liven under my hand and official seal, this My Commission expires 18th day of ..,,r~i. ~ ia,~~~i ~ N~TA ri1A 1, SEAL ~> '' ~ '••_ ~~ H~ ANNE A. STAFFORD, NOTARY PU6UC ~ >>~~ NAi1PDEN, CU119ERLAAID COUNTY PA rd , YY UOYNISSION EXPIflEB APRIL G$ 2001 7= e ~"„ November , 1939 Cl~zt~N p (~ Notary P This instrument was prepared by: F?Or_!SEHf)LC1 F.A."1CEF Ct1R~CFIATIQ1~f 25 Cap=ewa1+ Qrive, Suite 1f1.T . " MtarhanicsbuYg, ~rn.4A ISpacv Below This Line Reserved For Lender and Recorder) Return To: Rewrds Processing Services 577 Lamont Road Elmhurst, IL 6011b 09-20-99 MTU FILE COPY I II N6l IUII~ III II IU YI~ 1~I'~I I~'~ Yk PA061266 L0'd bLZI06LST2t6 Ol bbLL L19 0£9 Q"lOH3Sf10H bd Wd I£~L I002 b0 Nflf May 14, 2001 Linda Keef 944 Cavalry St. Carlisle, PA 17013 ACT 91 NOTICE TAKE ACTION TO SAVE YOUR HOME FROM ~®RECE®~IJRE This is an official notice that the mort ague on your home is in default. and the lender intends to foreclose. Specific information about the nature of the default is rorovided in the attached pages. The HOMEOWNER'S MORTGAGE ASSISTANCE PROGRAM (HEMAPI 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 RECEIPT OF THIS NOTICE. Take this Notice with~ou when you meet with the Counselin AQenck The name. address and rohone number of Consumer Credit Counseline Agencies serving_your County are listed at the end of this Notice. If you have andquestions, ou ma,~call the Pennsylvania Housing Finance A ency toll free at ] -800-342-2397 (Persons with impaired hearing can call L171780-1869. This Notice contains important legal information. If you have any questions, representatives at the Consumer Credit Counseling Agency maybe able to help explain it. You may also want to contact an attorney in your area. The local bar association maybe able to help you find a lawyer. LA NOTIFICACIO EN ADJUNTO ES DE SUMA IMPORT ' DE CONTINUAR VIVIENDO EN SU CASE. SI NO COME,$E DE NOTIFICACION OBTENGA UNA TRADUCCION IMMEDIATAME STA A CIA (PENNSYLVANIA HOUSING FINANCE AGENCY) SIN CARGOS AL NUMERO MENCIONADO ARRIBA. PUEDES SER ELEGIBLE PARA UN PRESTAMO FOR EL PROGRAMA LLAMADO "HOMEOWNER'S EMERGENCY MORTGAGE ASSISTANCE PROGRAM" EL CUAL PUEDE SALVAR SU CASA DE LA PERDIDA DEL DERECHO A REDIMIR SU HIPOTECA. HOMEOWNER'S NAME(S): Linda Keef PROPERTY ADDRESS: 944 Cavalry St. Carlisle. PA 17013 LOAN ACCOUNT NUMBER: 713303-00-9861614 ORIGINAL LENDER: CURRENT LENDER/SERVICER: Household Finance Corporation HOMEOWNER'S EMERGENCY MORTGAGE ASSISTANCE PROGRAM YOU MAY BE ELIGIBLE FOR FINANCIAL ASSISTANCE WHICH CAN SAVE YOUR HOME FROM FORECLOSURE AND HELP YOU MAKE FUTURE MORTGAGE PAYMENTS. IF YOU COMPLY WITH THE PROVISIONS OF THE HOMEOWNER'S EMERGENCY MORTGAGE ASSISTANCE ACT OF 1983 (THE "ACT"),YOU MAY BE ELIGIBLE FOR EMERGENCY MORTGAGE ASSISTANCE: - IF YOUR DEFAULT HAS BEEN CAUSED BY CIRCUMSTANCES BEYOND YOUR CONTROL, - IF YOU HAVE A REASONABLE PROSPECT OF BEING ABLE TO PAY YOUR MORTGAGE PAYMENTS, AND - IFYOUMEETOTHERELIGIBILITYREQUIREMENTSESTABLISHEDBYTHEPENNSYLVANIA 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 receipt of this Notice. During that time you must arrange and attend a "face-to-face" meeting with one of the consumer credit counseling agencies listed at the end of this Notice. THIS MEETING MUST OCCUR WITHIN THE (30) DAYS OF RECEIPT OF THIS NOTICE. IF YOU DONOTAPPLYFOREMERGENCYMORTGAGEASSISTANCE YOUMUSTBRINGYOURMORTGAGE UP TO DATE. THE PART OF THIS NOTICE CALLED "HOW TO CURE YOUR MORTGAGE DEFAULT " EXPLAINS HOW TO BRING YOUR MORTGAGE UP TO DATE. CONSUMER CREDIT COUNSELING AGENCIES--If you meet with one of the consumer credit counseling agencies listed at the end of this notice, the lender may NOT take action against you for thirty (30) days after the date of this meeting. The names, addresses and telephone numbers of designated consumer credit counseling auencies for the county in which the roroperty is located are set forth at the end of this Notice It is only necessary to schedule one face-to-face meeting. Advise your lender immediately of your intentions. APPLICATION FOR MORTGAGE ASSISTANCE--Your mortgage is in default for the reasons set forth later in this Notice (see following pages for specific information about the nature of your default). If you have tried azid 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 a completed Homeowner's Emergency 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 the' applications for the program and they will assist you in submitting a complete application to the Pennsylvania Housing Finance Agency. Your application MUST be filed or postmarked within thirty (30) days of your face-to-face meeting. YOU MUST FILE YOUR APPLICATION PROMPTLY. IF YOU FAIL TO DO SO OR IF YOU DO NOT FOLLOW THE OTHER TIME PERIODS SET FORTH IN THIS LETTER, FORECLOSURE MAY PROCEED AGAINST YOUR HOME IMMEDIATELY AND YOUR APPLICATION FOR MORTGAGE ASSISTANCE WILL BE DENIED. AGENCY ACTION--Available funds for emergency mortgage assistance are very limited. They will be disbursed by the Agency under the eligibility criteria established by the Act. The Pennsylvania Housing Finance Agency has sixty (60) days to make a decision after it receives your application. During that time, no foreclosure _~ . proceedings will be pursued against you if you have met the time requirements set forth above. You will be notified directly by the Pennsylvania Housing Finance Agency of its decision on your application. NOTE: IF YOU ARE CURRENTLY PROTECTED BY THE FILING OF A PETITION 1N BANKRUPTCY, THE FOLLOWING PART OF THIS NOTICE 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 datel. NATURE OF THE DEFAULT--The MORTGAGE debt held by the above lender on your property located at 944 Cavalr~St. Carlisle. PA 17013 IS SERIOUSLY IN DEFAULT because: YOU HAVE NOT MADE MONTHLY PAYMENTS for the following months and the following amounts are now past due: approximately $845.25 for the months of March 2001 through Apri12001 Other TOTAL AMOUNT PAST DUE: 2290.25 HOW TO CURE THE DEFAULT--You may cure this default within THIRTY (30) DAYS of the receipt of this Notice BY PAYING THE TOTAL AMOUNT PAST DUE TO THE LENDER, WHICH IS 2290.25 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: Margaret Smith Household Finance Corporation P.O. Box 4153 Carol Stream, IL 60197-4153 IF YOU DO NOT CURE THE DEFAULT--Ifyou do not cure the default within THIRTY (30) DAYS of the receipt 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 OF RECEIPT OF THIS NOTICE, the lender also intends to instruct its attorneys to start legal action to foreclose upon your mortgaged property. IF THE MORTGAGE IS FORECLOSED UPON--The,mortgaged property will be sold by the Sheriff to pay off the mortgage debt. If the lender refers your case to its attorneys, but you cure the delinquency before the lender begins legal proceedings against you, you will still be required to pay the reasonable attorney's fees that were actually incurred, up to $50.00. However, if legal proceedings are started against you, you will have to pay all reasonable attorney's fees actually incurred by the lender even if they exceed $50.00. Any attorney's fees will be added to the amount you owe the lender, which may also include other reasonable costs. If you cure the default within THIRTY (301 DAYS OF RECEIPT OF THIS NOTICE you will not be required to pay attorney fees. _ , ~I ., OTHER LENDER REMEDIES--The lender may also sue you personally for the unpaid principal balance and all other sums due under the mortgage. RIGHT TO CURE THE DEFAULT PRIOR TO SHERIFF'S SALE--If you have not cured the default within the THIRTY (30) DAY period and foreclosure proceedings have begun, you still have the right to cure the default and prevent the sale at any time up to one hour before the Sheriff s S ale. You may do so by waving the total amount then past due nlus any late or other charges then due reasonable attorney's fees and costs connected with the foreclosure sale and any other costs connected with the Sheriff s Sale as specified in writing by the lender and by performing any other requirements under the mo_rt~aQe, Curing your default in the manner set forth in this notice will restore your mortgage to the same position as if you had never defaulted. EARLIEST POSSIBLE SHERIFF'S SALE DATE--It is estimated that the earliest date that such a Sheriffs Sale of the mortgaged property could be held would be approximately five 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 contactvig the lender. HOW TO CONTACT THE LENDER: Name of Lender: Household Finance Corporation Address: P.O. Box 4153. Carol Stream, IL 60197-4153 Phone Number: 1-800-609-4278. Ext. Fax Number: 630-617-7744 Contact Person: Margaret Smith EFFECT OF SHERIFF'S SALE--You should realize that a Sheriff s Sale will end your ownership of the mortgaged property and your right to occupy it. If you continue to live in the properly after the Sheriffs 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 may or X may not 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 1N 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. FOR CONSUMER CREDIT COUNSELING AGENCIES SERVING YOUR COUNTY, PLEASE SEE THE ATTACHED LIST. NOTE: Unless you notify this office within thirty (30) days after receiving this notice, that you dispute the validity of this debt or any portion thereof, this office will assume that the debt is valid. If you notify this office in writing within thirty (30) days from receiving this notice, this office will: obtain verification of the debt or obtain a copy of judgment and mail you a copy of such judgment or verification. You are also advised that any information which you supply to this office may be used by us in the collection of the debt. If you request this office in writing within thirty (30) days after receiving this, this office will provide you with the name and address of the original creditor. Although we have requested that you make payment or provide a valid reason for nonpayment, you still have the right to make a written request, within thirty days of your receipt of this notice, for more information about the debt. Your rights are described further, hereinafter. THE PURPOSE OF THIS COMMUNICATION IS TO COLLECT A DEBT AND ANY INFORMATION OBTAINED WILL BE USED FOR THIS PURPOSE. SENT VIA REGULAR MAIL AND CERTIFIED MAIL NUMBER 7099 3400 0015 4703 3599 RETURN RECEIPT REQUESTED Enclosure: Validation of Debt Notice Validation of Debt Notice Pursuant to the Fair Debt Collection Practice Act (FDCPA)(15 USC 1692), a consumer debtor is required to be sent the following notice: (1) unless the consumer, within thirty (30) days after receipt of this notice, disputes the validity of the debt or any portion thereof, the debt will be assumed to be valid by the debt collector, (2) if the consumer notifies the debt collector in writing within the thirty day period that the debt or any portion thereof, is disputed, the debt collector will obtain verification of the debt or a copy of a Judgment against the consumer and copy of such verification or Judgment will be mailed to the consumer by the debt collector, and (3) upon the consumer's written request within the thirty (30) day period, the debt collector will provide the consumer with the name and address of the original creditor, if different from the current creditor. Our demand for immediate payment does not eliminate your right to dispute this debt within thirty days of receipt of this notice. If you choose to do so, we are required bylaw to cease our collection efforts until we have mailed that information to you. Although we have requested that you make payment or provide a valid reason for nonpayment, you still have the right to make a written request, within thirty days of your receipt of this notice, for more information about the debt. Your rights are described further, hereinafter. The law office of McCABE, WEISBERG AND CONWAY, P.C. is acting as a debt collector, pursuant to the FDCPA. THIS NOTICE AND LETTER ARE AN ATTEMPT TO COLLSCT A DEBT AND ANY INFORMATION OBTAINED WILL BE USED FOR THAT PURPOSE. The Federal Trade Commission has ruled that The FDCPA does not preclude the institution of legal action prior to the expiration of the thirty day period. Acceptance of funds and reinstatement of the mortgage are both subject to verification by my client. Please note that I may be instructed to proceed with foreclosure and fees, costs and/or advances by the mortgagee may be due in addition to the sum quoted above. Please further note that any funds tendered will be subject to verification and correctness before the matter is concluded. Please feel free to contact this office upon receipt of this notice should you have any questions or concerns. Date: 5/14/01 _..~ ~`~~l (''~~`~(~~ Terrence J. McCabe, Esquire McCabe, Weisberg, & Conway, P.C. First Union Building 123 South Broad Street Suite 2080 Philadelphia, PA 19109 PENNSYLVANIA HOUSING FINANCE AGENCY HOMEOLPNERS' EMERGENCY MORTGAGE ASSISTANCE PROGRAM CONSUMER CREDIT COUNSELING AGENCIES CUMBERLAND COUNTY Consumer Credit Counseling Service of Western Pennsylvania, Inc. 2000 Linglestown Road Harrisburg, Pa 17102 (717) 541-1757 Financial Services Unlimited 117 West 3rd Street sboro, Pa 17268 (717) 762-3285 Urban League of Metropolitan Harrisburg 25 N. Front Street Harrisburg, Pa 17101 (717) 234-5925 FAX # (717) 232-4985 YWCA of Carlisle 301 G Street Carlisle, Pa 17013 (717) 243-3818 FAX # (717) 243-3948 The undersigned, Angela Williams, hereby certifies that she is the Foreclosure Specialist of the Plaintiff in the within action, ~~~x, ha~D ~~nanc~ C orSOrne2bt5Govrn' C.oMPA~~i and that she is authorized to make this verification and that the foregoing facts are true and correct to the best of her knowledge, information and belief and further states that false statements herein are made subject to the penalties of 18 PA.C.S. X4904 relating to unsworn falsification to authorities. ^U V I ~J O 1 ~i P V W C? r. fem. '_ ~~~ L ::' c.~ - 1 ~_ (.- lJ NP'itT, W'A°~, :lip'd,*tii{~43TyaI'uH,.~+.sRl~,i~^FiLM~&`I§ry3+3rv?:if~%4]'i Y 1 C ~ 235 SOUTH 13TH STREET PHILADELPHIA, PA 19107 Philadelphia PHONE: (215) 546-7400 Assoeiaeion of FAX: 215-985-0169 Professional Process Serves B ~~~ services for Profesatonais Inc. AFFIDAVIT OF SERVICE PLAINTIFF(S) CASE NO. DATE RECEIVED _ o ~,„~° DEFENDANT(S) Court of Common Pleas °,~,, c ,.. ~,- SERVEAT Type of Service Civil. Action Mortgage Foreclost.~re. I'~-5 Mocka.ngbird Drive P{~ioeni x City AL COMPANY CONTROL NO. REFERENCE NO. SERVE BY: August 15; 2~J0] Accepted Ry:', Served and made known to on the ~ fdb day of ~XJG ~'-~T , 20 ~_Z , at ~(~1 ~ o'clock, at f ,~ ra (~igc•X~~ d~_~~isJ4' ~4~nc y~ Ll~(i ~ 1~'l,J IPgin~ Commonwealth of Pennsylvania, in the manner described below: 1 Defendant(s) personally served. Adult family member with whom said Defendant(s) reside(s). Relationship is ^ Adult in charge of Defendant's residence who refused to give name or relationship. Manager/Clerk of placing of lodging in which Defendant(s) reside(s). Agent or person in charge of Defendant's office or usual place of business. Posted Other GFSCRIPTTON ACE HEIGHT WEIGHT ;ACE SEX __________________________________^_----------___i___-_---____-- On the day of 19 at o cloc,., M., n,=fenclant not found Moved ____Unknawn ____No Ans ,Vacant ____Other DEPU7IZEp SERVTCE Now, this day of 19 I do hereby deputize the Sheriff of County to serve this ____5ummons ,Complaint ,,,,,,,Other and make return t.herof and according to Lal•J. Iy (Competent Adult) County Sheriff's Check ~ *~* Special Instructions ~~~~ ASAP Service NAME OF SERVER NpTaty PubIl~Mduscogee County, Georgia Sworn to & subscri d afore me Oti PYr7C2SE' SerVeYbeingdulyswornaccordingtolaw, ~~ day Of 2C~ deposes andgsays that he/she is process server herein names; and ~ ~ (~ ,.n that the facts herein set forth above are true and correct to the best of I 'I '•IAJI I their knowled e, information and belief. Sheriff Process Se Competent ATTEST Pr~*h C1~t~ PRO PROTHY Law Firm an r - h U,--~--,r Gs:I~~~C1-w~r~, 2 r Attorney's Name T r r nC~-L°'I .f'-~~. , E~q - For o 1 ~ ; n t 4 ~f Address 1.2 ~ ~~ CILt h ~Y C1cI d C.it7" a t ~ ll aft 2QRD Qh; Made. i~~~ia~PA~1 ~1n9 Telephone# 7gCi-1 C11n Identification# ®2000 Philadelphia Assoc. of Professional Process Servers Rev 7 TI I) v 1 F , ~~fln~1 DATE M.; ...~.~ n awls , ,ate=.,_ , 'Rae.*' u~ s _~:~~a*,. Rs~c€w+s~uraw^ ,- _d~~~r+wrs-sF+~s~wsmn;~..~~.~rs-.}~.~~a~~ rv t.. ,.F_,. _. -..- . x,. !~fl~AYlT 9F ~El~V~GE State of GEORGIA County of MUSCOGEE Case Ntumher: 01 ~~0 CIVILTEFG+f Plaintiff: FitJ1iSEHOLa FINANCE CONSUMER DiCOUNT COMPANY vs. LINDA JEAN KEEF allc.a LINDA J. KEEP For: Terrence McCabe First Urtinn Building 123 SauOt x#2080 Philadelphia PE 19109 Common Pleas Court I~eceivaad by $ & R S€ftV1CES on this 2nd day of August, 2001 at 11:27 am to b$ served on LINDA JEAN KEEF afk/s LINDA J. KEEF, 195 MOCKINGBIRD DRIVE, PHENDC CITY, ALABAMA 36869. f, Jart~s Edir~cEs: Jr-. being duty adrom, aerd say that orr 3rEt dslr of 2~'t at 11:15 am, l: persona8y served the wittrin parson with a true Dopy of the CiVtl ~4CT TGAGE FORECLOSURE WITH EXHIBIT "A" & "B" i certify that-t am a Citiaert of tha I.Irtite<! States, i am arv€~ 18 years of age, have rto ' in ilia abDVa 2r~ion and i am a >vovrt Appointed Process in the crnarrly invuhich the prosaesg was sarv®d. 3rd to b ore m® on the 1 by a affiant who is My Comn'iissidn Expires Bur Jab 5eria1 Number: 2001000843 HUGH E. LAMB ..~ c .,, ~a-mat emweee.~.-~eeecessxverb~vsa~ fYlaly Publig t. , PourdY, Geo~ _ ~ ~iommissia~ ~.- . .'d 18, 200 s B & R SERVICES 235 3,13th SY. Philadelphia, PA 19107 ~z15~ s46aaao ~F.. c, ~ o c-. ~- --, a ~: ,:7 ~ _ .- , a7? ~ ._ < ' - ~ . . . ~. _ ~, (~_ ~- • w .. _ j { 1 ~t~ aJ "` T.% 4 - ~,~ '.. ., "wmxa*snM. PyB~rc., -, ^~~ ,KFC .sn nvav ~w. ae .'+4,fiaMa£+~~4~-" SHERIFF'S RETURN - U.S. CERTIFIED MAIL 3 CASE NO: 2001-03950 P COMMONWEALTH OF PENNSYLVANIA COUNTY OF CUMBERLP.ND HOUSEHOLD FINANCE CONSUMER DIS VS. LINDA JEAN R. Thomas Kline Sheriff of Cumberland County, Pennsylvania, who being duly sworn according to law served the within named DEFENDANT ,KEEF LINDA JEAN by United States Certified Mail postage prepaid, on the 6th day of July ,2001 at 0000:00 HOURS, at 105 MOCKINGBIRD DR PHOENIX CITY, AL 36869 a true and attested copy of the attached COMPLAINT - MORT FORE Together with The returned receipt card was signed by NO SIGNATURE OR POSTMARK on 00/00/0000 . Additional Comments: Sheriff's Costs: Dpcketing 18.00 Service 3.25 Cert Mail 4.63 Surcharge 10.00 .00 35.88 Paid by MCCABE WEISBERG & CONWAY Sworn and subscri ed to before me this 13,uc day of ~~A.D. thonotar So answe s: ~ ~~-'_. Thomas Kline Sheriff of Cumberland County on 07/13/2001 ~, a ^ Complete items 1, 2, and 3. Also complete item 4 if Restricted Delivery is desired. ^ Print ypur,name and address on the reverse so that we can return the caid to you. ^ Attach this card to the back of the mailpiece, or on the front if space permits. 7. Article Atldressed to: Linda Keef 105 Mockingbird Dr. Phoenix City, AL 36869 A Received by (Please Prlnf Clearly) ~ B. Date C. Signature ~ ^ Agent X ^ Addressee D. Is delivery address different from hem 17 ^ Yes If YES, enter delivery address helow: ^ No 3. Service Type ~ Certified Mail ^ Express Mall ^ Registered ^ Retum Receipt for Merchandise ^ Insured Mail ^ C.O.D. 4. Restricted Delivery? (Extra Fee) ^ yes 2. Article Nurnber(Gopy horn service label) - 7099 3~2b `bOb4'1573'3b44 01-3'95b`civil" PS Form 3811, July 1899 Domestic Return Receipt 102585-00-M~0952