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Home My WebLink About01-04770GOLDBECK McCAFFERTY & McKEEVER BY: JOSEPH A. GOLDBECK, JR. ATTORNEY LD. #16132 SUPPE 500 -TAE BOURSE BLDG. 111 S. INDEPENDENCE MALL EAST PHH.ADELPHIA, PA 19106 (215)627-1322 ATTORNEY FOR PLAINTIFF COUNTRYWIDE HOME LOANS INC. F/K/A COUNTRYWIDE FUNDING CORP. 7105 Corporate Drive PTX B-35 Plano, TX 75024-3632 Plaintiff vs. SUN V. KARAS EDWARD W. KARAS Mortgagor(s) and Reai Owner(s) 1029 Swarthmore Road New Cumberland, PA 17070 Defendant(s) IN THE COURT OF COMMON PLEAS OF Cumberland COUNTY CIVIL ACTION -LAW ACTION OF MORTGAGE FORECLOSURE Neo B/ ~ L/77l/ CIVIL t~CTION: PORTGAGE RORECLOSURE TffiS FIRM IS A DEBT COLLECTOR AND WE ARE ATTEMPTINGTO 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 vrtiting with the court yaw defenses or objections to the chums set forth against you You are waned that if you fail to do so the case may proceed without you and ajudgment may be entered against you by the Court without further notice for any money claim iv the Complaint of for any older claim or relief requested by the Plaintiff. Ycu may lose movey or property or other rights important to you. YOU SHOULD TAKE THIS POPER TO YOUR LAWYER AT ONCE. IF YOU DO NOT HAVE A LAWYER OR CANNOT AFFORD ONE, GO TO OR THLEPHONE THE OFFICE SET FORTH BELOW TO FIND OUT WHERE YOU CAN GET LEGAL HELP. CUMBERLAND COUNTY BAR ASSOCIATION 2 Uberty Avevue Carlisle, PA 17013 LEGAL SERVICES INC S Irvine Row Carlisle, PA 17013 717-243-9400 AVISO LE HAN DEMANDADO A USTED EN LA CORTE. SI DESEA DEFENDERSE CONTRA LAS QUEJAS PERESENTADAS, ES ABSOLUTAMENTB NECESSARIO QUE USTED RESPOFIDA DENTRO DE 20 DIAS DESPUES DE SER SERVIDO CON ESTA DEMANDA Y AVISO. PARR DEPENDHRSE ES NECESSARIO QUE USTED, O SU ABOGADQ REGISTRE CON LA CORTE EN FORMA ESCRTTA, EL PUNTO DE VISTA DE USTED Y CUALQUBiR OB7ECCION 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 REQUER[RA QUE USTED CUMPLA CON TODAS LAS PROVISIONES DE ESTA DEMANDA. POR RAZON DE ESA DECISION, ES POSSIBLE QUE USTED PUHDA PERDER DINERO, PROPIl3DAD U OTROS DERECHOS A~Il'ORTANTES. LLEVE ESTA DEMANDA A UN ABOGADO A9t4EDIATEAMENTE. SI NO CONOCE A UN ABOGADQ L.LAME AL "LAWYER REFERENCE SERVICE" (SERVICIO DE REFERENCIA DE ABOGADOS), (215) 238-6300. CUMBERLAND COUNTY BAR ASSOCIATION 2 Liberty Avenue Carlisle, PA 17013 LEGAL SERVICES INC S Irvine Row Carlisle, PA 17013 717-243-9400 COMPLAINT IN MORTGAGE FORECLOSURE 1. Plaintiff is COUNTRYWIDE HOME LOANS INC. F/K/A COUNTRYWIDE FUNDING CORP., 7105 Corporate Drive, PTX B-35 Plano, TX 75024-3632. 2. The name(s) and address(es) of the Defendant(s) is/aze SUN V. KARAS, 356 Old Baltimore Pike, Newark, DE 19702 and EDWARD W. KARAS, 356 Old Baltimore Pike, Newazk, DE 19702, who is/are the mortgagor(s) and real owner(s) of the mortgaged premises hereinafter described. On January 25, 1993 mortgagor(s) made, executed and delivered a mortgage upon the premises hereinafter described to BANK UNITED OF TEXAS FSB, which mortgage is recorded in the Office of the Recorder of Deeds of Cumberland County as Book 1115 Page 537. The mortgage has not been assigned unless said assignment to the Plaintiff is hereafter mentioned. The aforementioned mortgage was assigned to: COUNTRYWIDE HOME LOANS INC. F/K/A COUNTRYWIDE FUNDING CORP. by Assignment of Mortgage dated June 08, 1995 and recorded on August 04, 1995 as Book 501 Page 186; and these documents aze 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 payment of principal and interest upon said mortgage due December O1, 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 11/01/2000 through 08/31/2001 at 8.3750% Per Diem interest rate at $17.69 Attorney's Fee at 5.0% of Principal Balance Late Charges from 12/01/2000 to 08/31/2001 Monthly late charge amount at $31.38 Costs of suit and Title Search Escrow Monthly Escrow amount $146.93 $77,107.36 $5,377.76 $3,855.37 $282.41 $750.00 $87,372.90 $0.00 $87,372.90 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 Attomey's Fees will be chazged 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 nofice(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 in the sum of $87,372.90, together with interest at the rate of $17.69, per day and other expenses incurred by the Plaintiff which are properly chargeable in accordance with the terms of the mortgage, and for the foreclosure and sale of the mortgaged premises. By: G DBEC McCAFFERTY McKEEVER B 70SEPH A. GOLDBECK, JR., ESQUIRE ATTORNEY FOR PLAINTIFF VERIFICATION I, Michael Vestal, 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 tme 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 unsv~rom falsification to authorities. ~~ Date: _~~~~ //~ Michael Vestal Countrywide Home Loans ALL THAT CERTAIN LOT OF LAND SITUATE [N THE BOROUGH OF NEW CUMBERLAND, COUNTY OF CU1I~BERLAND AND STATE OF PENNSYLVANIA, BOUNDED AND DESCRIBED AS FOLLOWS, TO WIT: BEGINNING AT A POINT ON THE NORTHERLY LINE OF SWARTHMORE ROAD, SAH) POINT BEING LOCATED 937.54 FEET MEASURED EASTWARDLY ALONG SAID LINE FROM THE NORTHEAST CORNER OF SWARTHMORE ROAD AND DREXEL HILLS BOULEVARD; THENCE NORTHWARDLY AT RIGHT ANGLES AND ALONG THE EASTERLY LINE OF LOT NO. 12, BLOCK "A", ON THE HEREINAFTER MENTIONED PLAN 105.00 FEET TO A-POINT; THENCE NORTH 89 DEGREES 14 MINUTES EAST ALONG LINE OF LANDS NOW OR FORMERLY OF ELMER E. ZIMMERMAN, 65.00 FEET TO A POINT; THENCE SOUTHWARDLY AT RIGHT ANGLES AND ALONG THE WESTERLY LINE OF SWARTHMORE ROAD; THENCE BY THE LATTER SOUTH 89 DEGREES 14 MINUTES WEST, 65.00 FEET TO THE PLACE OF BEGINNING. BEING LOT NO. 1.3, BLOCK "A", ON THE PLAN OF LOTS OF SECTION 1, HIGHLAND PARK HILLS AND DREXEL HILLS, SAID PLAN BEING RECORDED IN THE CUMBERLAND COUNTY RECORDER'S OFFICE IN PLAN BOOK 7, PAGE 23. ~; - _ - HAVING THEREON ERECTED A DWELLING HOUSE, BRICKAND FRAME BI-LEVEL; KNOWN AND NUMBERED AS 1029 SWARTHMORE ROAD, NEW CUMBERLAND, FEN]~ISYLVANIA.- - BEING THE SAME PREMISES WHICH YONG HO Y~ AND KUM HUI Yi, HUSBAND AND WIFE BY THEIR DEED DATED JANUARY 25,1993. AND INTENDED TO BE RECORDED IMMEDIATELY PRIOR HERETO, GRANTED-e1ND - CONVEYED UNTO EDWARD W. KARAS AND SUN UN KARAS, HUSBAND AND~WIF~'';~ MORTGAGOR$~iIE$~;71~i-- ~ ~ ~ - - ~_ - Send Correspondence lo: P.O. Box rcCOPOeXa aCOCS7Zu Send Payments to: - P.O. Box xPYPOBXa ' rtPYC51Zu aMAILCSuxMAILZPn - - Certified Mail No. May 02, 2001 Retum Receipt Requested - ~ ~ Regular Mail Sun V. Kares 1029 Swarthmore Road - New Cumberland, PA.17070 - Countrywide Account # 3138241 - Properly Address: - 1029 Swarthmore Road New Cumberland, PA. 17070 _ ~ Current 3ervicer: - Countrywide Home Loans, Inc. ACT 91 NOTICE TAKE ACTION TO SAVE YOUR HOME FROM _ _ - FO~E~LOSURE _ ~- This is an official notice that fhe mortgage on vour home is In dofault and the lender intends to foreclose. - _ - - _ __ Specific Information about the nature of the default is oroviNed In the attached oaoes. _ - The HOMEOWNER'S EMERGENCY MORTGAGE ASSISTANCE PROGRAM IHEMAPI may be able to halo to save - ._ -- - - --- vour home. This Notice explains how the oroorem works. - - ~ -~- To see N 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 tMe Counseling Aaencv. - - _ - The names. addresses and phone numbers of Consumer Credit Counseling Agencies servino vour County are - - This Notice contains-important legal Information. If you have any questions, representatives at the Consumer - Credit Counseling Agency may 6e able to help answer them. You may also want to contact an attorney in your area. The local bar association may be able to help you find alawyer. - LA NOTIFICACIbN EN ADJUNTO'ES DE SOMA IMPORTANCIA, PUES AFECTA SU DERECHO A CONTINUAR VMENDO EN SU CASA. SI NO COMPRENDE EL CONTENIDO DE ESTA NOTIFICACIbN OBTENGA UNA TRADUCC16N INMEDIATAMENTE LLAMANDO ESTA AGENCIA (PENNSYLVANIA HOUSING FINANCE AGENCY) SIN CARGOS AL Nl1MER0 MENCIONADO ARRIBA. PUEDE SER ELEGIBLE PARR UN PR~STAMO POR EL PROGRAMA LLAMADO "HOMEOWNER'S EMERGENCY MORTGAGE ASSISTANCE PROGRAM" EL COAL PUEDE SALVAR SU CASA DE LA PERDIDA DEL DERECHO A REDIMIR SU HIPOTECA. HOMEOWNER'S EMERGENCY MORTGAGE ASSISTANCE PROGRAM YOU MAY BE ELIGIBLE FOR FINANCIAL A_S_SISTANCE WHICH CAN SAVE YOUR HOME FROM FORECLOSURE AND HELP YOU MAKE FUTURE MORTGAGE PAYMENTS. IF YOU COMPLY WITH THE PROWSIONS OF THE HOMEOWNER'S EMERGENCY MORTGAGE ASSISTANCE ACT OF 7983 (THE "ACT"~, YOU MAY BE ELIGIBLE FOR EMERGENCY MORTGAGE ASSISTANCE: IF YOUR DEFAULT HAS BEEN CAUSED BY CIRCUMSTANCES BEYOND YOUR CONTROL, Please write your loan number on all checks and correspontlence. aMNAMEw aACCTXn-«CHKDGT» P.O. Box «PYPOBXa «PYCSTZa «BARCDE» snsnooB .AOOns» aTOTDUEv AS OF «DUEDTE» '-tWKSCAN~ 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. AYMENTINSTRUCTIONS ' Please Make yourcheck payableNCounhywide HOme Loans _• Don't attach your check to the paymenlcoupon Write your loan number onywrchedc or money order Don't include correspondence Wdte in any addi5anal amounts you are including. (If DonY send qsh total is more than $5000, please send codified check.) - ddilional anwmd•. If you donY spectty the purpose of a5dltlonal amounts Induded, we will apPty Nam gmt to airy outstanding ymanls, escrow da5derxdes, late che~ges endlwfees due. Wa wlll Nen appry any remahdiy amounts as a pMGpal retluGbn. If ' u submtt ap addltlonalpdnGpal paymemwkh your home loan payment, Counhywide will Arsl apply your Iwme loan paymem, Nen e adddional pdndpal payment Yourloan mustbe artem before wean appry any pdnclPal reductton. -. ,.,• Send Correspondence to: - P.O. Box eCOPOBXu aCOCSTZu Send Payments to: P.O. Boz aPYPOBXu «PYCSRu . rcMAILCSuaMAILZPu - Cer9fied Mail No. May 02, 2001 - Retum Receipt Requested - - Regular Mail Sun V. Karas - 358 Old Baltimore Pike Newark, OE.19702 - - Countrywide Account # 3138241 _ Property Address: - 1029 Swarthmore Road New Cumberland, PA. 17.070 - - _ Current Servicer: - Countrywide Home Loans, Inc. ACT 91 NOTICE TAKE ACTION TO -SAVE 1~O~1R .HOME FROM FORECLOSURE _ his Ilan official notice that the-mortgage on vour home is in default and-the lender Intends to foreclose. 8oecific information about the-nature of the defauh is provided in the attached oases. - _ The HOMEOWNER'S EMERGENCY MORTGAGE ASSISTANCE PROGRAM (HEMAPI may be able to halo to save - - - -- - - your home. This-Notice explains how the oroaremworks. ~ - _ - - - - _ T see if HEMAP can halo. you must MEET WITH A CONSUMER CREDIT COUNSELING AGENCY WITHIN 30 =_ - DAYS OFTHE DATE OF THIS NOTICE. Take this Noticewith you when you meet with the Counseling Aaencv. - ThisNofice contains Impertanflegal information. If you have anyquestions, representatives at the Consumer Credit Counseling Agency may be able to help answer them. You.may also want to contact an attorney io 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 NOTIFICACIbN OBTENGA UNA TRADUCCIGN INMEDIATAMENTE LLAMANDO ESTA AGENCIA (PENNSYLVANIA HOUSING FINANCE AGENCY) SIN CARGOS AL NGMERO MENCIONADO ARRIBA. PUEDE SER ELEGIBLE PARA UN PRESTAMO POR EL PROGRAMA LLAMADO "HOMEOWNER'S EMERGENCY MORTGAGE ASSISTANCE PROGRAM" EL COAL PUEDE SALVAR SU CASA DE LA PERDIDA DEL DERECHO A REDIMIR SU HIPOTECA. HOMEOWNER'S EMERGENCY MORTGAGE ASSISTANCE PROGRAM yp MAY BE ELIGIBLE FOR FINANCIAL ASSISTANCE WHICH CAN SAVE YOUR HOME FROM FORECLOSURE AN HELP YOU MAKE FUTURE MORTGAGE PAYMENTS. IF YOU COMPLY WITH THE PROVISIONS OF THE HOMEOWNER'S EMERGENCY MORTGAGE ASSISTANCE ACT OF 1993 (THE "ACT"), YOU MAY BE ELIGIBLE FOR EMERGENCY MORTGAGE ASSISTANCE: IF YOUR DEFAULT HAS BEEN CAUSED BY CIRCUMSTANCES BEYOND - YOUR CONTROL, Please write youf loan number on all checks and correspondence. 828Y2000 aMNAMEa aACCTX»-«CHKDGT» rADDRew aTOTDUE»AS OF «DUEDTE» P.O. Box aPYPOBX» aPYCSTZ» «BARCDE» '~WKSCAN~ maw:. .. .a 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. AYMENTINSTRUCTIONS Please Make yourcheck payable to Courrtryw%Me Home Loarrs Don'l adach your check tithe payment coupon Wdte your loan number on your check or money order Don't include oomespondence Wdte in any addltlonal amounts you are including. (If Don't sand cash total is more than $5000, please send certified check.) dditlanal ammunh. If you don't apedfy the puryose of addNOnal emounb Inducted, we will eppty Mem flrsl to airy ouMmMing yments, esdaw defidendas, late charges andla foes due. We wlll Nen appy any mmelnbg amouns es a pdndpal mdudbn. If u submit an addPoOnal pdndpal pay~nl wiM yourlroma ban payment, Countrnvide wN flrsl apply your home loan paymem, bran l eadditlonal pdndpal payment Yeaf loan must be cwrent heforewe rand ppty any pdndpal redudbn. ,., _ . ' a ~ Send CorresDOndence lo: P.O. Bar aCOPOBXA rcCOCSTZu Send Payments to: P.O. Boz rcPYPOBXu - - rcPYCSTZA a MAIICSAaMA1LZPu Certified Mail No. May 02, 2001 - Return Receipt Requested - Regular Mail Edward W. Kares 1029 Swarthmore Road New Cumbedand, PA. 17070 Countrywide Account # 3138241 - -Property Address: -1029 Swarthmore Road New Cumbedand, PA. 17070 _ - ~ Current Servicer: - - Countrywide Home Loans, Inc. ACT 91 NOTICE TAKE ~cCT10N TO SAVE _ 1(OUF~ _HOME_ FROM FORECLOSURE This Is an official notice that the mortgage on vour home Is In defavl4and the lender intentls to foreclose, Soeciflc information about the nature of the default is pcovlded in the attached pages_ - The HOMEOWNER'S EMERGENCY MORTGAGE ASSISTANCE PROGRAM tHEMAPI may be able tg help to save _ - - -~ - vour home: This Nodee explains how the orogrem works. _- - - _ To see If HEMAP can help.-vou 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 Counselina Aaencv. The names. addresses and phone numbers of Consumer Credit Counselina Agencies serving vour CouMv are - listed at theeml of this Notice. ff ou have an uestions ou ma call the Penns Ivanla Housin Finance _ _ - Aaencv toll-free at 100-342-2397. (Persons with Impalied hearing can call 1-717-780.1869.1 _ - - - This Notce containsimpoftant legal information. If you have any questions, representatives at the Consumer --- - _ _ - Credit Counseling Agency maybe able to help answer them. You may also want to contact an attorney in your - - area. The local bar association may 6e able to help you find a lawyer - - - LA NOTIFICACIGN EN ADJUNTO ES DE SOMA IMPORTANCIA, PLIES AFECTA SU pERECHO A CONTINUAR VIVIENDO EN SU CASA. SI NO COMPRENDE EL-CONTENIDO DE ESTA~NOTIFICACIbN OBTENGA UNA TRADUCC16N INMEDIATAMENTE LLAMANDO ESTA AGENCIA (PENNSYLVANIA HOUSING FINANCE AGENCY) SIN CARGOS AL NGMERO MENCIONADO ARRIBA. PUEDE SER ELEGIBLE PARR UN PR~STAMO POR EL PROGRAMA LLAMADO "HOMEOWNER'S EMERGENCY MORTGAGE ASSISTANCE PROGRAM" EL COAL PUEDE SALVAR SU CASA DE LA PERDIDA DEL DERECHO A REDIMIR SU HIPOTECA. 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, Please write your loan number on all checks and correspondence. 6/28/2000 cMNAME» aACCTXn-aCHKDGT» rADDRS» aTOTDUE»AS OF aDUEDTEn P.O. Box aPYPOBXn aPYCSTZn «BARCDE» '~WKSCANfl ,, 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. Please ' Make your check Dayable to Countrywide Home Loans Wdte your Man numbs on your checkamoney order Wdte in any additional amounts you are includirM. (If -total is more Man $5000, please send cediAed check) • Don't atlach your check to the payment coupon • Don'tincludewnespondence • Don't send cash ddPoOnal amoams. If you dan'1 spap(y Me poryosa of additional amoun6lnduded, we will apply Mem first m any oubmnding ymems, escrow deficontles, late charges andlorfees tlue. We will Men eppN any remaining emounb as a pdncipel retludlon. If u submitan additional pindpel paymemwiN your home loan ~ymerh Counbywitle wgl first appy roar home ban payment Men e addPoOnal pdndpal payment Your loan must be cuaentbelore wean appy am/ pdndpel reduction. ~.. Send Coaespondence to: P.O. Box aCOPOBXu aCOCS7Zu Sentl Payments fo: P.O. Box aPYPOBXu aPYCSTZ» aMAILCSurtMAILZPu - Certified Mail No. May 02, 2001 Retum Receipt Requested Regular Mail Edward W. Kass 356 Old Baltimore Pike Newark, DE.19702 - - Countrywide Account # 3138241 Property Address: 1029 Swarthmore Road _ New Cumberland, PA. 17070 _ Current Servicer: - Countrywide Home Loans, Inc. ACT 91 NOTICE TAKE ACTION TO SAVE - - YOUR HOME FROM -_ FORECLOSURE - - - - _ - - - - - vour home: ~ This Notiee exofains how the oroaram works. ~ - _ - -TO see if HEMAP can halo. you must MEET WITH A CONSUMER CREDIT COUNSELING AGENCY WITHIN 30 - - DAYS OF THE DATE OF THIS NOTICE. Take this Notice with ou when ou meet with the Counselin A enc . - - - - This Notice contains important legal Information. If you have any questions, representatives at the Consumer - Credit Counseling Agencymay be able-to help answer them. You may also want to contact an attorney in your - - area. The Igcal bar associatton-maybe able to help you find a lawyer. LA NOTIFICACION EN ADJUNTO ES DE SUMA IMPORTANCIA, PLIES AFECTA SU DERECHO A CONTINUAR VIVIENDO EN SU CASA. SI NO COMPRENDE EL CONTENIDO DE ESTA NOTIFICACIbN OBTENGA UNA TRADUCCIbN INMEDIATAMENTE LLAMANDO ESTA AGENCIA (PENNSYLVANIA HOUSING FINANCE AGENCY) SIN CARGOS AL NGMERO MENCIONADO ARRIBA. PUEDE SER ELEGIBLE PARA UN PR~STAMO POR EL PROGRAMA LLAMADO "HOMEOWNER'S EMERGENCY MORTGAGE A881STANCE PROGRAM" EL CUAL PUEDE SALVAR SU CASA DE LA PERDIDA DEL DERECHO A REDIMIR SU HIPOTECA. 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 7883 (THE "ACT"), YOU MAY BE ELIGIBLE FOR EMERGENCY MORTGAGE ASSISTANCE: IF YOUR DEFAULT HAS BEEN CAUSED BY CIRCUMSTANCES BEYOND YOUR CONTROL, Please wrke your loan number on all checks and cormspontlence. 6/26/2000 eMNAMEa aACCTX»-«CHKDGT» woonso aTOTDUE» As oP aDUEDTE» P.O. BOx «PYPOBX» aPYCSTZ» «BARCDE» '-tWKSCAN~ 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. Please Make your check payable to COUntryw(de Horne L08n5 _ • Don't aflach yourcheck to the payment coupon Write your ban number on your check ar money oNer Don't Include conesDorMence Wdte in any additional amounts you are inducting. (If Don't send cash total is mare than $5gW, please send cedfiedcheck.) - - ddXbnal amounts. If you donY spedty Na purpose of addtiional amounts Inducted, we will appty them first b any outdandi~ ymenfa, eacmw deflclendes, late charges enNOr fees tlue. We will Nan appty any remaining amounts as a pdnclpal iaductlon. If u su6mll an additional pdndpal paymem wIN your home ban paymem, Countrywide will first eppy your home ben payment, Nan e additional pNwipal payrcem. Yourban must be arrem befarewe can aDPty any pdndpal retlucfion. a~a: TEMPORARY STAY OF FORECLOSURE -Under the Act, you are entitled to a temporary stay of foreclosure on your mortgage for thirty-five (35) days from the date of this Notice. During that time you must arrange and attend-a "face-to- face" meetng with one of the consumer credit counseling agencies listed al the end of this Notice. THIS MEETING 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-five (35) days after the date of this meeting. Advise your lender immediately of your intentions. It is only necessary to schedule one 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 trietl antl are unable to resolve this problem with the lender, you have the dght to apply for financial assistance from the Homeowner's Emergency Mortgage Assistance Program. To tlo 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 applications far the program and they will assist you in submilfing a complete application to the Pennsylvania Housing Finance Agency. Your application MUST be filetl or postmarked within thirty-fve (35) days of yourface-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 cdteda established by the Act. The Pennsylvania Housing Finance Agency has sixty (60) days to make a decision after it receives your applicatlon. During that time, no foreclosure proceetlings will be pursued against you if you have met the time requirements set forth above. You will be notified tliredlyby the Pennsylvania Housing Finance Agency of its decision onyour application. NOTE: IF YOU ARE CURRENTLY PROTECTED BY THE FILING OF A PETITION IN BANKRUPTCY, THE FOLLOWING PART OF THIS NOTICE tS FOR INFORMATION PURPOSES ONLY AND SHOUL-D NOT BE - __ -CONSIDERED AS AN ATTEMPT TO COLLECT THE DEBT. -- - (If you h_ava Flled bankruptcy you can still apply forEmecgency Mortgage Assistance.) _ ~~ - NOTICE OF INTENT TO FORECLOSE - - - - - YOUR HOME LOAN IS IN DEFAULT FOR THE REASONS SET FORTH IN THIS NOTICE. YOU MUST TAKE ACTION TO SAVE YOUR HOME FROM FORECLOSURE NATURE OF THE DEFAULT -Countrywide Home Loans, Inc. (hereinafter "Countrywide°) services your home loan. Your home loan is in serious default because _yqu have not made your required payments. The total-amount now required to reinstate your home loan as 4f the date of this letter is as follows: Monthly Payments: $764.66, Late Chames: $31.39 Other Chames: Uncollected late Charges: Uncollected Costs: $2,812.30 $156.95 $.00 $2,799.87 TOTAL DUE: $6,880.12 HOW TO CURE THE DEFAULT -You may cure this default wthin THIRTY-FNE (35) DAYS of the date of this letter, by paying to us the above amount of $3,760.20, plus any addi0onal monthly payments, late charges, fees and other applicable charges which may fall due during this period. Such payment must be in the form of cerfi0ed check, pshier's check or money order, and made payable to Countrywide at P.O. Box 660694, Dallas, TX 75268-0694. If your check or other payment is retumed to us for insufficient funds or for any other reason, you will not have cured your default. No extension of time to cure will be granted due to a retumed payment. If you do not cure this default within THIRTY-FIVE (35) DAYS, we will accelerate the payments due on your home loan. This means whatever is owing on the orlginal amount borrowed will be consideretl duo immediately and you may lose the chance to pay off your home loan in monthly installments. If the full payment of the amount in defauk is not matle within THIRTY-FIVE (35) DAYS, we also intend to immediately start a lawsuit to foreclose on your mortgaged properly. - IF THE MORTGAGE IS FORECLOSED UPON - If the mortgage,is foreclosed, the mortgaged property will be sold by the Sherlff to pay off the mortgage debt. ~ If the default is cured before we begin legal proceedings, Countrywide will be - entitled to collect the reasonable attorney's fees actually incurred, up to $50.00. However, if legal proceedings are - - started, Counrywide will be entitled to collect the reasonable attomey's fees even if they are over $50.00. Any - attomey's fees will be added to the secured debt, which may also Include our reasonable costs. If you cure the default within the THIRTY-FIVE (35) DAY perod, you will not be required to pay attomey's fees. YOU HAVE THE RIGHT TO REINSTATE AFTER ACCELERATION AND RIGHT TO ASSERT IN THE FORECLOSURE PROCEEDING THE NON- EXISTENCE OF A DEFADLT OR ANY OTHER DEFENSE YOU MAYHAVE TO ACCELERATION AND - FORECLOSURE. - 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 FORECLOSURE SALE - If you have not cured the default within the - - THIRTY-FIVE (35) DAY pedod and foreclosure proceedings have begun, you sllll have the right to wre the default and - prevent the sale at any time up to one hour before the foreclosure sale. You may do so by paying the total amount then - past due, plus any late or other charges then due, reasonable attomey's fees and costs connected with.the foreclosure sale and any other costs connected with the foreclosure sale as specified in writing by the lender and by performing any _ other requirements under the mortgage. Curing-your default In the [panner set forth in this notice will restore your -_ - mortgage to the same position as If you had rrever defaulted. - - - _ _ EARLIEST POSSIBLE FORECLOSURE SALE DATE - It is estimated that the earliest date that a foreclosure i:ale - _ _ - - - - could be held would be approximately six (6) months frsm the date oTthis letter. A notice of the date of the foreclosure - - sale will be sent to you before the=-sale,.-You may find dut at any time exactly what the required payment will be by - calling us at the following number. 800-669-5231. This payment must be in the form of a cashier's check, certified -- --- - - check or money order and made payable to-us of the address stated above. If the defaultis cured, the mortgage will be restored to the same position as if no default had occurred. However, the default may not be cured more than three (3) - 8mes in any calendar year. - _ = - - _ - - HOW TO CONTACT THE LENDER: Name of Lender: Countrywide Home Loans, Inc. - - - - - ~ Address: _ P. O. Bdx 10221 Van Nuys, CA 91410.0221 _ _ _. - _ _ ---- -Phone Number: 800.889-5231 - - ~ - Fax Number: 1.805-577-3432 --- - Contact Person: Chasten Rocha, MS SV-34 - - Attention: Loan Counselor EFFECT OF FORECLOSURE SALE -You shoultl realize that a foreclosure sale will end your ownership of the mortgaged property and your right to remain in it. If you continue to live in the property offer the Shertffs sate, a lawsuit to remove you and your furnishings and other belongings could be started by Countrywide at any time. ASSUMPTION OF MORTGAGE -Contact Countrywide Home Loans for Information on the possible assumability of your loan. 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.) AYMENT INSTRUCTIONS Please Make your chede payahle b Countrywide Home Loans Wdte your loan numberon your check or money oNer Wdfe in any addtonal amounts you are including. (Ii total b more than $5000, please send ceNfied check.) • Don't attach yourcheck to Me paymen[ceupon • Don't include cenespondence • DonY send cesh tltligonal amouMS. If you don't apecMy me puryose of additional amounts included, we will appy hem flret m any oubtanding yments, esuow defidendas, Isle charges and/orfees due. We wlli than appy any remabing amounts as a pdnclpal retluctlon. If u submh en additonal pdnclpal peymemwflh your home loan payment Counhywide wdl first appy your home ben pey~nt then e add'NOnal pdnclpal payment Vour loan musthe currem bebre we can apply any pdnclpal retludbn. ,,, 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. - Pursuant to your home loan documents, and because the home loan is in tlefault, Countrywide may, at its option, enter upon and conduct an inspection of the property. The purpose of this inspection is to observe the physical condition of the property, to verify that the property Is occupied and/or to determine the identity of the occupant. The cost of any such inspection will be added to and become part of the secured debt as provided under the terms of the home Idan documents. '~: If you are unable to cure your default on or before June O6, 2001, Countrywide wants you to be aware of various .options that may be available to you through Countrywide to prevent a foreclosure sale of your property. For example: • Reoavment Plan: It is possible that you may be eligible for some form of payment assistance through Countrywide. Our basic plan requires that Countrywide receive, up front, at least % of the amount necessary to bring the account curtent, and that the balance of the overdue amount be paid, along with the regular monthly payment, over a defined pertod of time. Other repayment plans also are available. • Loan Modification: Altematvely, it is possible that the regular monthly payments can be lowered through a modificaton of the loan by reducing the interest rate and then adding the delinquent payments to the current loan balance. This foreclosure alternative, however, is limited to certain loan types. • Sale of Your Procertv: Alternatively, if you are willing to sell your home in order to avoid foreclosure, it is possible that the sale of your home ran be approved through Countrywide even if your home is worth less than what is owed on it. • Deed-in-Lieu: Alternatively, 'rf your property is free from other liens or encumbrences, and if the default is due to a serious financial hardship which is beyond your controf, you may be eligible to-deed your property directly to the Noteholder and avoid the foreclosure sale. - If you are Interested in discussing foreclosure alternatives with Countrywide, you must. contact us immediately. If you - request assistance, Countrywide will determine, in its sole discretion, whether such assistance will be extended to you.- In the meantime, Countrywide will~pureue all of its rights and remedies under the home loan documents and as . permitted by law, unless it agrees otherwise in writing. Please be advised that failure to brng the home loan current or -to enteFinto a written agreement as outlined above will result in the-acceleration of the debt. .. _ -- Time is of the essence. Should you have any questions concerning this notice, please contact Countrywide's office - im/~m~e_Fdi~a~te~ly,•at 8e0~0-88&5231, extension 7149. - - ~ - Christen Royha - _ Loan Counselor - - - -- _ - 800-669-5231, Extension 7149 ~ - - -Please be advised that this communication is from a debt collector. -- - - .i:.-: ~;xwraamm... ``^ (~~V\ ~'n\~ ~~ t '~ ~~ ~'a ~ c4 ~~ ~: r,. J~U r. ~ __ -~ T J ~ CLJ •'L';I _ 7 ~. ~~ (` L C' ~iJ lu' ~4' IsE~mm;l~]Sh~1~,Fe,9R~N1H§k'+`o~INI. _ ...,... j< A PRAECIPE FOR WRIT OF EXECUTION - (MORTGAGE FORECLOSURE) P.R.C.P. 3180-3183 Countrywide Home Loans, Inc. f/k/a Countrywide Funding Corp. Plaintiff Vs. Sun V. Karas Edward W. Karas COURT OF COMMON PLEAS CUMBERLAND COUNTY, PA NO: 01-4770 PRAECIPE FOR WRIT OF EXECUTION (MORTGAGE FORECLOSURE) Defendants TO THE OFFICE OF THE PROTHONOTARY: Issue writ of execution in the above matter: Amount Due Interest from 10/26/01 to sale date at $14.58 per diem Total $88,720.16 Jose A. dbeck, Jr. Suit 500- e Bourse Bldg. 111 S. Independence Mall East Philadelphia, PA 19106 Attorney for Plaintiff and Costs Note: Please attach description of property. a y~, 0 w 0 z o ro x V] ~ W w ~ o z ~Z a v + rob ° s , a ro ~ ~ x U ~ ~ H w $~+ '"U y z ~ ~ o U y ~ ro ro ~' u x ro .s ~ro ~~ 3 ~b W H ~ a ro ~ ~ ~ O o w ~ ~ N W w ~ o ~ ~ v ~ ~ .~ ~ v `° w a q A ~ b ~ ~°` ° x ~ rn ~ m ~ a 3 v ° w~ ~ ~z ro U ~ ~ N N .. ~ ~ N ~ w ~ ~ . 3 a w v am.....m~~,r h~ r -'-rt a.,,i~,}~rmmmwg~sire~ais~an •.ww:•a,, • ~q ' ALL THAT CERTAIN lot of land situate in the borough of New Cumberland, County of Cumberland and State of Pennsylvania, bounded and described as follows, to wit: BEGINNING at a point on the northerly line of Swarthmore Road, said point being located 937.54 feet measured Eastwardly along said line from the Northeast corner of Swarthmore Road and Drexel Hills Boulevard; thence Northwardly at right angles and along the Easterly line of Lot No. 12, Block "A", on the hereinafter mentioned Plan 105.00 feet to a point; thence North 89 degrees 14 minutes East along line of lands now or formerly of Elmer E. Zimmerman, 65.00 feet to a point; thence southwardly at right angles and along the Westerly line of Swarthmore Road; thence by the latter south 89 degrees 14 minutes West, 65.00 feet to the place of BEGINNING. Tax Parcel #26-24-0809 Being known as 1029 Swarthmore Road, New Cumberland, PA 17070 N ~ ~ ~~ q1 nV /I.. ~ W V V l4 $l ~' Q' :`~ ~ ~ C c G I / ~ `I ..I ~ ~ -~ C I ~J ~, T C; ;~ [}'I rte. :.~ J`~~_ ~ t" ,- .~ %~; -u, ~ t. ~r _ I C ~~ ~ .. ~ u .-~~., - ~z .~:~~. iwM.. .z~xsxa~ C'buntrywide Home Loans, Inc. f/k/a Countrywide Funding Corp. Vs. Plaintiff Sun V. Karas Edward W. Karas Defendants CUMBERLAND COUNTY COURT OF COMMON PLEAS CIVIL DIVISION NO. 01-4770 Countrvw~de Home Loans, Inc ~k/a Countrtirw~de Funding orn., 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 X029 Swartknnore Road New CLm~erland. PA 17070. 1. Name and address of owner(s) or reputed owner (s): Name Address (if address cannot be reasonably ascertained, please so indicate) Sun V. Karas 356 Old Baltimore Pike Newark. DE 19702 Edward S9. Karas 356 Old Baltimore Pike Newark DE 19702 2. Name and address of defendant(s) in the judgment: Name Address (if address cannot be reasonably ascertained, please so indicate) 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) 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) -,,.: , 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) 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) Pa Deft. of Public Welfare Health and Welfare Bldg Room 432 Bureau of Child Su~2~ort Enforcement 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) 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. October 29, 2001 Josep A. Gol eck, Jr. Attor y for aintiff C -,,, ~J ti: t~)IT'• <__ I( .,F (-. ~`i __ ~~^ ti ~ti ~.? ~ + ~: ~f ~_ K, l~ i^ ,'-_ I'i !-] C ~; 1'i -J ~? ~V wow ~,~,~::a~,we;erwx'~7+... ,. :~ss~.^z~ F. 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 1 6 7-i Countrywide Home Loans, InC. f/k/a Countrywide Funding Corp. Vs. Sun V. Karas Edward w. Karas ATTORNEY FOR PLAINTIFF COURT OF COMMON PLEAS CUMBERLAND COUNTY CIVIL DIVISION NO. 01-4770 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. Joseph Gol eck, Jr. Attor for laintiff L ~ -I n~ _~ - _ Ci~ ' _ J _ r L. ~t. G _T -C t,~ _ ~~~ .., RtY~Y e -=J"at ~I.TSri~ n d +.NYR'sga .~s~`nh 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 ( T 1 6 7-~ Countrywide Home Loans, Inc. f/k/a Countrywide Funding Corp. Vs. Plaintiff Sun V. Karas Edward W. Karas Defendants ATTORNEY FOR PLAINTIFF CUMBERLAND COUNTY COURT OF COMMON PLEAS CIVIL DIVISION NO.O1-4770 riOTT O H T ~ AT O R AT STAT T0: Sun V. Karas 356 Old Baltimore Pike Newark, DE 19702 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 1029 Swarthmore Road, New Cumberland, PA 17070, is scheduled to be sold at the Sheriff's Sale on March 6, 2002 at 10:00 a.m., in Cumberland County, Cumberland County Courthouse, Commissioners Hearing Room, 2"d Floor, Carlisle, PA 17013 to enforce the court judgment of $88 720.16 obtained by Countrvwide Home Loans Inc. f/k/a Countr~.wide Funding Cuero. (the mortgagee) against you. NOTICE OF OWNER'S RIGHTS vp env g as3 m0 REVE '~'HT HER'r A 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. 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.) vOU ~av SmTLi BE p,BrE m0 SAVE vOUR PROPERmv araD YOU HAVE OTHER RTrxTS EVEN TF THE SHERIFF'S SALE DOES TAKE PLACE. 1. If the Sheriff's Sale is not stopped, your property will be sold to the highest bidder. You may find out the price bid by calling _( ~ ) 6 7-i 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) 240-6390. 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 ~~ _~ 'T7 Gf. l_.'1 171f~~ ..._ - .__ Z- 1 _' ~. ~;__. _ . `y. ~1 .<. J 1f) -y. f_~ ~ZS GOLDBECK McCAFFERTY & McKEEVER By: Joseph A. Goldbeck, Jr. Attorney I.D. #16132 Suite 500 - The Bourse Bldg. ill S. Independence Mall East Philadelphia, PA 19106 ( 151 6 7-~'i Countrywide Home Loans, Inc. f/k/a Countrywide Funding Corp. 7105 Corporate Drive, PTX B-35 Plano, TX 75024-3632 Vs. Sun V. Karas 356 Old Baltimore Pike Newark, DE 19702 Edward W. Karas 356 Old Baltimore Pike Newark, DE 19702 ATTORNEY FOR PLAINTIFF CUMBERLAND COUNTY COURT OF COMMON PLEAS CIVIL DIVISION NO O1-4770 PRAECIPE FOR JUDGMENT FOR FAILURE TO ATVSS"~'R AND ASSESSMENT OF DA4~nGES TO THE PROTHONOTARY: Kindly enter judgment in favor of the Plaintiff and against Sun V K-r-s -n'• Edw-+-d ~• Karas, Defendants 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 $87,372.90 Interest - 9/1/01 - 10/26/01 $ 990.64 Late Charges $ 62.76 Escrow Debit S 293.86 TOTAL $88,720.16 I hereby certify that (1) the addresses of the Plaintiff and Defendants are as shown above, and (2) that notice has been given in accordance with Rule 237.1, copy attached. Jos ~ A. G eck, Jr. Att ney fo Plaintiff DAMAGES ARE HEREBY ASSESSED AS DATE: ,sl(k~(~ /i aDOL INDI D. PRO PROTHY ~~ I hereby certify that the above names are correct and that the precise residence address of the judgment creditor is 7105 Corporate Drive, PTX B-35, Plano, TX 75024-3632 and that the names and last known addresses of the Defendants are: Sun V. Karas, 356 Old Baltimore Pike, Newark, DE 19702 Edward W. Karas, 356 Old Baltimore Pike, Newark, DE 19702 Jose A. Go eck, Jr. Att ey fo laintiff 'iLI1S L:1~V FIRIt1 6S A i)I~~S'I' C;ULL~E:C:TC1R ANi) R'E: ARE A'I"i'EM. Y'L'IN(~ TO COLL,FC`T A DIt:Li'1' O6VE:D 'I'O C1UR CLLE;NT. ANY' LNFOR1ViATION OBT'AINEL) E'It()Di 1`()U ~VI(.,[. I3E USE;I) F012'THIi PC}RYOSF bF COLL,N:CI'li'VC. T13E 1)F.L3'1'. DA'lF?. OF'CFIIS NO'1'1Ch: September 19, addl. I.(i. suN v. T~uxas 3i6 Oki Ltatttmpre Pil:a Ne}a:uk, I ~AEt ] STO~ C(3lJN'1'R4'WII7F:I{O~~IE LO:~NSiT~rC, I~r"Iti'A COL3NTR`i'WIF.?~I3Ir[.)IvL"1LNC C:OItY. 7105 C.'cn~porate E)riv~ PT\ I3- i5 I'}xnca 'T:~. 75024-303 2 ~ s. Sl}N V. K..~.RAS E:fi~~rARD ~~". T'.AI2AS {f~Iortgag<rrf:i) cant/ Rec(7f'd CD'wrrCr{51) IO;29 Suvairttrtuure Iioxcl Ne14+ Cumberl:~nd, Ya4 17(170 TCl: SI-IN~ ~'. KARAS 35G CJId B.alnrnore I'ikc; Newark, LlE !970?, - Plaintiff Dcfernlarrtt'a) IM. I'ORTA1V'T NOTICE IIY `1'H1i COLJRT UFO COMMON PLLA.S of Cumberland County= CIVIL ACTION - LACY ACTION OF.MORTCiACsT PORE3CT..OSURE Term Na. 01-4770 VOU ARt IN I2GI+AUL.'1" B,FCAL.rSE YOU f~IAVE FAILLI) TO .E;NTER A WRT'I'I`EN Af'YEARANCE P}RSONAI_L1' OR. I3Y,' ATTORNEY ANT) FILE TN WRITING W[TFI 'I`EiE COLfl't"1" YOUR 10$FFNSES OR OI3J'C,CI'kONS'T'O'T.LIIi: C],hLAIS SETT FORT"EI AC;.AINS'1' YOU'. LJNLEsSS 1°OCF AC'T WI"I`Fli~i-t'L`IN (10)'1)AYS FRO'~1 Tlffi I')A'I`L C)}r THIS NO'I'1C'li, .A JIJL)CINEFu"NT 1VtAY T3E EN'ITR13T) AGAINST YOi.i WI7"ROUT A fLEAItINO ANT) ~:'OU Mt\Y LOSE YOUR. PROPER'T'Y OR O'.I7-IER LMPORTAN"1' RICifI'I~. YOLJ SI3OULI:D I","oKli TFI[S NCD"II('L; 'ICD A L.A~~'YE.R AT' C)NCE. ]F YOL} ID(:1 NOT' HAY73 A T.:A~G'YER OR. CANNO'T' AF`EtCiP,l~ CDNE. C;O TC? Oit 'I'.E1:I?PEIONE 'Fl [l FOL:LOW7NCi O.F.F.ICE `I"C) F'IN1J OL"I' W,EI'EIZE YOU C'E1N taki"I' LG:GAE., IIFiLP: ~,~ 1'~d~.'19R4 S~~,x'TM~ n' x:ne s'aocu+:nnn Lt~IIA L. LF;19Cl5IPR' iyy :+ ~I~'w$i.P~i~~`nt~. .-..~__.-.- .C 7c(',~FFF.R ~ EEYFIR ll ~ aepfi A.l}uldbecJq Jx., t'sQ- Attomcy 5or Plnirtitl' $uilc 6fjb -'17~e 13<rm'sc Bide. I l A ti, Independence A~1a11 Bast Phile+.ielphxa, !'A 1910P+ 2I5{+:'-]~.2 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. DATE OF THIS NOTICE: September 19, 2001 TO: SUN V. KARAS 356 Old Baltimore Pike Newark, DE 19702 COUNTRYWIDE HOME LOANS INC. F/K/A COUNTRYWIDE FUNDING CORP. 7105 Corporate Drive PTX B-35 Plano, TX 75024-3632 vs. SUN V. KARAS EDWARD W. KARAS (Mortgagor(s) and Record Owner(s)) 1029 Swarthmore Road New Cumberland, PA 17070 Plaintiff Defendant(s) TO: SUN V. KARAS 356 Old Baltimore Pike Newark, DE 19702 IN THE COURT OF COMMON PLEAS of Cumberland County CIVIL ACTION -LAW ACTION OF MORTGAGE FORECLOSURE Term No. 01-4770 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: E COONTY nARAS50CfA'rION arl~5e~, ~~~3 ~~')~~~b ors ~,r G C icCAFFER Z EVER B seph A. Goldbeck, rr, Esq. Attorney for Plaintiff Suite 500 -The Bourse Bldg. 111 S. Independence Mall East Philadelphia, PA 19106 215-627-1322 -. ~:~r~- 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. DATE OF THIS NOTICE: September 19, 2001 To: EDWARD W. KARAS 1029 Swarthmore Road New C~ruiberland, PA 17070 COUNTRYWIDE HOME LOANS INC. F/K/A COUNTRYWHE FUNDING CORP. 7105 Corporate Drive PTX B-35 Plano, TX 75024-3632 vs. SUN V. KARAS EDWARD W. KARAS (Mortgagor(s) and Record Owner(s)) 1029 Swarthmore Road New Cumberland, PA 17070 Plaintiff Defendant(s) TO: EDWARD W. KARAS 1029 Swartbmore Road New Cumberland, PA 17070 IN THE COURT OF COMMON PLEAS of Cumberland County CIVIL ACTION -LAW ACTION OF MORTGAGE FORECLOSURE Term No. 01-4770 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: ~Jf~IDE COUNTY BAR ASSOCIATION a,1~S~ "f98fs ~it`l"f4~l~s ~a b oc3 s me ~rcCAFFER T EVER B ~ sepfi A. Goldbeck, Jr., Esq. Attorney for Plaintiff Suite 500 -The Bourse Bldg. 111 S. Independence Mal] East Philadelphia,PA 19106 2t5-627-132 .•.rrss~az~-~iw~- u THIS LAW FIRM IS A DEBT COLLECTOR AND WE ARE ATTEMPTING TO COLLECT A DEBT OWED TO OUR CLIENT. AIYY INFORMATION OBTAINED FROM YOU WILL BE USED FOR THE PURPOSE OF COLLECTING THE DEBT. DATE OF THIS NOTICE: September 19, 2001 To: suN v. xnRas 1029 Swarthmore Road New Ctimtberland, PA 17070 COUNTRYWIDE HOME LOANS INC. F/K/A COUNTRYWIDE FUNDING CORP. 7105 Corporate Drive PTX B-35 Plano, TX 75024-3632 vs. SUN V. KARAS EDWARD W. I{ARAS (Mortgagor(s) and Record Owner(s)) 1.029 Swarthmore Road New Cumberland, PA 17070 Plaintiff Defendant(s) To: SUN v. KAI2A5 1029 Swarthmore Road New Chmberland, PA 17070 IN THE COURT OF COMMON PLEAS of Cumberland County CIVIL ACTION -LAW ACTION OF MORTGAGE FORECLOSURE Term No. 01-4770 IMPORTANT NOTICE YOU ARE IN DEFAULT BECAUSE YOU HAVE FAILED TO ENTER A WRITTEN APPEARANCE PERSONALLY OR BY ATTORNEY AND FILE IN WRTITNG 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 LO5E 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 TFIE FOLLOWING OFFICE TO FII~ID OUT WHERE YOU CAN GET LEGAL HE~LP~:~~ ~arl"1 'FA I'/61] OONrY BAR ASSOCIAr10N GAL ~EwR'VICES INC ~'R~- 3ap~o~a G $ QcCAFFER T EVER B ~ seph A. Goldbeck, Jr, Esq. Attorney £or Plaintiff Suite 500 -The Bourse Bldg. I I I S. Independence Mall East Philadelphia, PA 19106 215-627-]32 -._. _., GOLbBECK, MCCAFFERTY & MCKEEVER By: Joseph A. Goldbeck, Jr. Attorney I.D. #16132 Suite 500-The Bourse Bldg. 111 S. Independence Mall East Philadelphia, PA 19106 (~51 6 .7-~ 3 .2 Countrywide Home Loans, Inc. f/k/a Countrywide Funding Corp. Vs. Sun V. Karas Edward W. Karas ATTORNEY FOR PLAINTIFF COURT OF COMMON PLEAS CIVIL DIVISION NO. 01-4770 CUMBERLAND COUNTY 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 Sun V. Karas, is over 18 years of age, and resides at 356 Old Baltimore Pike, Newark, DE 19702. (c) that defendant Edward W. Karas, is over 18 years of age, and resides at 356 Old Baltimore Pike, Newark, DE 19702. This statement is made subject to the penalties of 18 Pa. C.S. Section 4904 relating to unsworn falsification to authorities. JOSE ~ A. GO BECK, JR. Atto ey fo Plaintiff October 29, 2001 Y (Rule of Civil Procedure No. 236) - Revised IN THE COURT OF COMMON PLEAS OF CUMBERLAND COUNTY, PENNSYLVANIA CIVIL ACTION - LAW Countrywide Home Loans, Inc. f/k/a Countrywide Funding Corp. Plaintiff Vs. N0. 01-4770 Sun V. Karas Edward W. Karas Defendants Notice is given that a Judgment in the above captioned /~U. matter has been entered against you on 6c'^~r ~ 2001. EPUTY If you have any questions concerning this matter please contact: Joseph A. beck, Attorney fo laint f **THIS F.TRM 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. ** _~ N~ ~ C ~? _ ~ - r., -_~ _ ~ <'~~ ~~ _ \ ~ ~ ~ y ) ~ ~~_~ d ~~ ~ ~ -~ „~ ~ _ a n -< ~ ~S ~"~ 4 .. .T.~~ b '::.:. Y .w.r.~3I'~6#3i6t:.a[k'i?d~3~E!. ' GOLDBECK McCAFFERTY & McKEEVER BY: Joseph A. Goldbeck, Jr. Attorney I.D.#16132 Suite 500 -The Bourse Bldg. 111 S. Independence Mall East Philadelphia, PA 19106 215-627-1322 Attorney for Plaintiff COUNTRYWIDE HOME LOANS INC. F/K/A COUNTRYWIDE FUNDING CORP. 7105 Corporate Drive PTX B-35 P1ano,TX 75024-3632 Plaintiff vs. SUN V. KARAS EDWARD W. KARAS Mortgagors 1029 Swarthmore Road New Cumberland, PA 17070 CERTIFICATE OF SERVICE PURSUANT TO Pa.R.C.P. 404 Term No. 01-4770 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) by certified mail on August 29, 2001 IN THE COURT OF COMMON PLEAS of Cumberland County CIVIL ACTION -LAW ACTION OF MORTGAGE FORECLOSURE w_ 2. Ardcle Number ~ ~ -' A..Necelved bY,IFlee9~'~RileACieeriy} ~B.'[]ate of Uel Q Signature ~ ~AI ] A~ _ 71~ y~5 ~~ ~~ 97~ :dam . ~ _. X ~^ tl. ~edelNery addm i9ge ~ ^Yi'yE3, enter delivery ad C reM from t[em 17 ~ Y¢ tlrees tielav: [] N 3. Service.TypeCERTIFIED MAIL 4. ReslrlcteQ Delivery? (Ektre Fee) ^ Yes 5. Artlcle Addressedtd:~ ._ .. _ . - "" I KARAS,-SUN V. 1 1 ~ suN v. KARAS 356 Olcl Baltimore Pike ~ ~~y .~ ~~~' Newark, DE 19702 'bb 2. Article, Number r A, I E ~~ ,. . .,. i , , ~~ ` ~ ', ~ . C. C .; X 71(]6 4575 129V 4603 9739 ,.;. o. i 3. Service Type CERTIFIED MAIL - 4. Restricted Delivery? (Extra Fee) - ^ Yes 1. Article Addiessed to: - "" KARAS, EDWARD W.. ~ EDWARD W KARAs 356 Old Baltimore Pike Newark, DE 19702 7CAR15. SUN V. / CWD-1393 2D00 Return ~ry address different horn item i? enter delvery address below: Ores t-l No ' ~~~~~~ c =~ ~ ; , Ji;~. r S n~~- ~ -, _ .r .-.- __ v G?~~. rT: =i ~'C ~. ' 7 ~~ W.) Goldbeck, McCafferty & McKeever BY: Joseph A. Goldbeck,. Jr. Attorney I:D. #1613 Suite 500 - Tt'.~e Bourse Bldg. 111 S. Independence Mall East Philadelphia, PA 19106 215-627-1322 Attorney for Plaintiff Countrywide Home Loans, Inc. f/k/a Countrywide Funding Corp. 7105 Corporate Drive, PTX B-35 Plano, TX 75024-3632 Plaintiff Vs. Sun V. Karas Edward W. Karas 1029 Swarthmore Road New Cumberland, PA 17070 Defendants IN THE COURT OF COMMON PLEAS . OF C~A18EiWWD COUNTY CIVIL ACTION - LAW ACTION OF MORTGAGE FORECLOSURE TERM No. 01-4770 CERTIFICATE OF SERVICE PURSUANT TO Pa.R.C.P. 3129.2 (c) (2) Joseph A. Goldbeck, Jr., Esquire, Attorney for Plaintiff, hereby certifies that service on the Defendants of the Notice of Sheriff Sale was made by: ( ) Personal Service by the Sheriff's Office/competent adult (copy of return attached). (~ 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). ( ) Acknowledgement of Sheriff's Sale by Attorney for Defendant(s) (proof of acknowledgement 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. y ~'i~mitted, Goldb k McCafff rty & McKeever By: eph A. ldbeck, Jr. Attor y for Pl intiff ~_ . 2. Artcle Number _„_,~,. _ _. jz •' v_ ~ , , 7160 3901 `3844 51`38 8999 3. Service Type CERTIFIED MAIL 4. Restricted Delivery? (Extra Feel ^ Yes 1. Article Addressed to: KARAS, SUN V. SUN V. KARAS 356 (71d Baltimore Pike Newark, DE 19702 C: Signature r b. Is delhrery adtlresa tllgerenf ham Ilan If YES, enter tlellvery atltlresa helow: 7 ' Q Agent Vas No ~CGOLDBEQK MCCAFFERTY &MCKEEVER vaese $r~~v ha rsea r .,~~~ ~acrvvcn: ~ / ~ l /q`-~ f 'V r ~ 871, d~Jr~Qt, Domesuc Return Receipt . 2. R~tlc-Te Flumtierr.,,~,.._._. 3. Setvic -Type CERTIFED MAIL 4. ~Ftestgcted Delivery?(Ea4ra Fee) ^Yes 1. ArticleAddressed to: ICARAS, EDWARD W. EDWARD W. KARAS 356 Uld Baltimore Pike Newark, DE 19702 YES, enter tlelitrery sdtlress below: "~ ~ ~~'t/ Agent , Adtlressea Yea Na . ,PSF,o~m 181!1,!~iprgl ~D4T ~' 7160 39d~3, 9844 57,9, 987~9~ ~; F;_ARA9. F.:(~s54'ARD thI euwarao w. Euaruys 3SL O(Q &aitimorc Pike Neµac.~k, DF L97U2 5Eh1DER: Gzzt,ooFC'IZ.atrc'arrsx~rvemcr~rr:v}sx acr:~l~ur zv, zant REFEREhHCE: K,1R1& 6UN 1'.1 C`tV17-13R} - Cmn6a~lnnd FiET17I~iY8 ! Fb,:l9„' 19EGEtK"T Cu~lifi, SEE3VICE Fir~turn ~ '-'aCil F'nstagn ~4 Fnns 1~F:° i°C.Jii1s wi:?St~iW L, ~~~~~ ~~~ Gv ray„ t rg:. i-r Irt`,»ita,hrn-! F.ec_ ~ _, ~:;;;' . 716® 39f71 96 4 5198 8999 _~: KABA3, 9l1?I Y. s8J1+1 w lCAttAS 356 Cld Ba}titnore Pi kxs SEN®ER: CC/L.1)Rhc K mcc~nFrExrY.~ hu.~tsveu, r)rioizcr 29, :tG(e! FtEFEREt~lCE: IkdRAS, SCIty V. f CN'F>-is?3:i - Cetmbcrtued I'iE iURlJ ! 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V' ~ 0 0 ~ n ~ M tl0 1 ~~a 1 T u ~ I x ~ ~ ~ ~~1 a m __ __ __ __ - .» 3 w ^~~~a 0 1 V r ~ y O ~ D a s a i m ° u S q n 0 ° C 0. u " 5 3 0 ^[7^ b n = oo°jom n o o > ~ n ? ° u A bm 0 ~b o v' c^ ~ a v.3o'uao-+ ~m A D D m c n 7• m~ ~~ aone a'°a ~ 3 m == R?m m u _3 aS2e m e om ~c boo ~ a m °n ~ , g>ssb; rv w i ~* ' ~,43 wm ° "' .~ .A VI M4A im'~-~Op~ W 4D 00 ~ ~n a jb~ooo~ ~~ i0tl ~i ~ s. a - aa~ R`~'T'~ g a o ~ ~ C 2 a ~ d ~'~ n O W b__r C 3 M ~ T b ~~ tl 6O aa 11 ~ l S ~ y ~o"p NO g $ ~ y .'Z VI ~ aya N G`i N v° eg ~$~ m '` ~3~ G Z 'V a~ ~ :so3 ~ i m ~.~ ~' moo w0 3~0° s ~ NON a~ 3 x a~=3.b~. ab ~ ~ i.i +~+ A.~9a3i nnaaa° ~ W "b n m w - nm^~b Qr S rl w,U- Da Old ' ~<~~m~~ , a s ~ =Sosa• i a ¢3~ ~3 ~ o vi~c - my g i i ~,~ m m g a H1LA Pq • ~. o~o~a3 ° e~ 1 ~ i n~ Sp ua hp~ ~ m o,=fib 3 3 ~ 3 m ~ ~ .,Ai ,.: v..,, C a ^!~a rn i p ~ ~ O~ Q Y' « J CJ <n 2 gym: ~oK JO N ~' n°ev°m d 1rV3N 1N~~ O 3 w N N a 0 v O m F i 0 a m O ti .a 1~ ;~ 1 1~ y ~~ m 0 H m N o, a" 1 Countrywide Home Loans, Inc. f/k/a Countrywide Funding Corp. Plaintiff . CUMBERLAND COUNTY COURT OF COMMON PLEAS CIVIL DIVISION Vs. Sun V. Karas Edward W. Karas N0. 01-4770 Defendants oun +-~ty'de Home Toans Inc f/k/a Countrvw~de Fund+ng orn , 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 ~~79 Swarthmo+-e Road New CLml~erland PA 17070. 1. Name and address of owner(s) or reputed owner (s): Name Address (if address cannot be reasonably ascertained, please so indicate) Sun V. Karas 356 Old Baltimore Pike Newark. DE 19702 Edward W. Karas 356 Old Baltimore Pike Newark. DE 19702 2. Name and address of defendant(s) in the judgment: Name Address (if address cannot be reasonably ascertained, please so indicate) 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) 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) Household Realty Coro 25 Gateway Drive Gateway Sure. Ste. 707 Mechanicsburg. PA 17055 ~x~_ 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) None 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) ya Degt of Pub~~c Welfare Heath and We~fare Bldg. Room 432 Rnrea, o h~'1d upDO+-t Enfio+-cement 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) 1 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. October 29, 2001 Josep Gol eck, Jr. Attor y for aintiff ~ P ~ J n nom,. ~" -~-' n c.~ ~ c- . ~, Jr. !L~ `~ ~~ G', L r i_: c_~ FS STATE OF PENNSYLVANIA, t COUNTY OF CUMBERLAND S ss. --Robert P Ziegler I+---------- ---------- Recorder of Deeds in and for said County and State do~hereby certify that the Sheriff's Deed in which ________________ Secretary of Veterans Affairs -----°-----------------°----------------------------------------------------------isthe grantee the same having been sold to said grantee on the -_--------521'1? -------------------------------- day of March 2002 ---------------------------------------- A. D.,? -----,under and by virtue ofa writ--------___-_- __-_Execution ^ 1st - --°-------------°-----------issued ontho ------------------------------------- Nov 2001 day of ______________________..___ A. D., _____~ out of the Court of Comman Pleaz of said County~az of Civil 2001 ------------------------------.,.------------------------------------------------'- Term,: •----- Ntunber4770________,atthesuitof____Countrywide Home Loans Inc fka Countrywide P ----------------------Fttxc~ifrg-~~•~}} Sun V Karas & Edward W °'__°------'---------°^---'---__ against°-^---------------------------------°------------- ~ duly recorded inShetiffsDeedISookNo.______ 250- Pago _-____--4897 of IN TESTIMONY WHEREOF, I have hereunto sot my hand and seal of said office this ~ ~~__ day Countrywide Home Loans, Inc. f/k/a Countrywide Funding Corp. VS Sun V. Karas and Edward W. Karas In The Court of Common Pleas of Cumberland County, Pennsylvania Writ No. 2001-4770 Civil Term R. Thomas Kline, Sheriff, who being duly sworn according to law, states that he served the within Real Estate Writ, Notice and Description in the following manner: The Sheriff mailed a notice of the pendency of the action by Certified Mail, Return Receipt Requested, Restricted Delivery, Deliver to Addressee Only to one of the within named defendants, to wit, Sun V. Karas, to her last known address of 356 Old Baltimore Pike, Newark, DE 19702. This letter was mailed under the date of November 6, 2001. Sun V. Karas received the letter on an unknown date (post office did not record date on return receipt card). Return receipt card was returned to the Cumberland County Sheriff's Office on November 16, 2001 signed by Sun V. Karas. R. Thomas Kline, Sheriff, who being duly sworn according to law, states that he served the within Real Estate Writ, Notice and Description in the following manner: The Sheriff mailed a notice of the pendency of the action by Certified Mail, Return Receipt Requested, Restricted Delivery, Deliver to Addressee Only to one of the within named defendants, to wit, Edward W. Karas, to his last known address of 356 Old Baltimore Pike, Newark, DE 19702. This letter was mailed under the date of November 6, 2001. Edward W. Karas received the letter on an unlrnown date (post office did not record date on return receipt card). Return receipt card was returned to the Cumberland County Sheriff's Office on November 16, 2001 signed by Edward W. Karas. Timothy Reitz, Deputy Sheriff, who being duly sworn according to law, states that on January 04, 2002 at 1:55 o'clock P.M., E.S.T., he posted a true copy of the within Real Estate Writ, Notice, Poster and Description, in the above entitled action, upon the property of Sun V. Karas and Edward W. Karas located at 1029 Swarthmore Road, New Cumberland, Pennsylvania, according to law. R. Thomas Kline, Sheriff, who being duly sworn according to law says 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 one of the within named defendants to wit: Sun V. Karas, by regular mail to his last known address of 356 Old Baltimore Pike, Neward, DE 19702. This letter was mailed under the date of January 18, 2002 and never returned to the Sherift s Office. R. Thomas Kline, Sheriff, who being duly sworn according to law says 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 one of the within named defendants to wit: Edward W. Karas, by regular mail to his last known address of 356 Old Baltimore Pike, Newark, DE 19702. This letter was mailed under the date of January 18, 2002 and never returned to the Sherift s Office. R. Thomas Kline, Sheriff, who being duly sworn according to law, says that after due and legal notice had been given according to law, exposed the within described premises at public venue or outcry at the Courthouse, Carlisle, Cumberland County, Pennsylvania on March 6, 2002 at 10:00 o'clock A.M., EST. He sold the same for the sum of $1.00 to Attorney Joseph Goldbeck for Secretary of Veterans Affairs. It being the highest bid and best price received for the same, Secretary of Veterans Affairs of 5000 Wissahickon Ave., Philadelphia, PA 19144, being the buyer in this execution paid Sheriff R. Thomas Kline the sum of $694.90, it being costs. Sheriff s Costs: Docketing $30.00 Poundage 13.63 Advertising 15.00 Posting Handbills 15.00 Acknowledging Deed 30.00 Auctioneer 10.00 Law Library .50 Prothonotary 1.00 Mileage 11.05 Certified Mail 15.42 Levy 15.00 Surcharge 30.00 Legal Search Law Journal 218.90 Patriot News 212.70 Share of Bills 24.20 Distribution of Proceeds 25.00 Sheriff's Deed 27.50 $694.90 Sworn and subscribed to before me This p'er' day of 2002, A.D.~~ p,~ rothonotary " ~l" ~ So Answers; R. Thomas Kline, Sheriff By D J~(~ Real state Deputy ~`',~~ ~. 3~~ v (~~ ~,~,, ~a3~8~ a ~, . ~ ~<.~ _ _ ~ ,~~~~, _ . r ~ Countrywide Home Loans, Inc. f/k/a Countrywide Funding Corp. Plaintiff Vs. Sun V. Karas Edward W. Karas Defendants CUMBERLAND COUNTY COURT OF COMMON PLEAS CIVIL DIVISION NO. 01-4770 CountrtiR.+de 'dome Tons, Tnc f/~/a Cou*+trvw~de Funding orn , 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 1~~9 Swarthmore Road 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) Edward W. Karas 356 Old Baltimore Pike Newark D8 19702 2. Name and address of defendant(s) in the judgment: Name Address (if address cannot be reasonably ascertained, please so indicate) 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) 4. Name and address of the last recorded holder of every mortgage o€ record: Name Address (if address cannot be reasonably ascertained, please so indicate) Household Realty ~~„- 25 Gateway Drive Gatewa,~v Sure Sty 1_(17 Mechanicsburg. PA ?7055 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) None 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) pa ~@pt of P+u1~~c Welfare Health and welfare Bldg Room 432 Bureau of Ch~~d S~ggort Enforcement 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) 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. October 29, 2001 Josep Gol eck, Jr. Attor y for aintiff 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 7 1 6 7-73 Countrywide Home Loans, Inc. f/k/a Countrywide Funding Corp. ATTORNEY FOR PLAINTIFF CUMBERLAND COUNTY COURT OF COMMON PLEAS CIVIL DIVISION Plaintiff Vs. Sun V. Karas Edward W. Karas NO.O1-4770 Defendants Nr1TTCF O GH T ~ SAT O RFAT F4TATF TO: Sun V. Karas 356 Old Baltimore Pike Newark, DE 19702 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 1029 Swarthmore Road New CT±mt,erland PA 17070, is scheduled to be sold at the Sheriff's Sale on March 6. 2002 at 10:00 a.m., in Cumberland County, Cumberland County Courthouse, Commissioners Hearing Room, Ina Floor, Carlisle, PA 17013 to enforce the court judgment of $88.720.16 obtained by Countrywide Home Loans Inc. f/k/a Countywide Funding corn. (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: x,151 627-1322 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. ~~~~ • 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.) vOU NLav Smrr r BE agr E m0 SAWN' `TOUR PROPERmv 1~rarD vOU H_aVE OmHFR RT("F:TC FVF7Q TF THE SHERTFF~S GAL.F' DOE4 mauF. pLACQ 1. If the Sheriff's Sale is not stopped, your property will be sold to the highest bidder. You may find out the price bid by calling ~ iS) 6 7-~ 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 (7171 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 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 ' 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- Countrywide Home Loans, Inc. f/k/a Countrywide Funding Corp. Plaintiff Vs. ATTORNEY FOR PLAINTIFF CUMBERLAND COUNTY COURT OF COMMON PLEAS CIVIL DIVISION Sun V. Karas Edward W. Karas NO.O1-4770 Defendants T~TOTT O H T ~ SAT OF A TAT TO: Edward W. Karas 356 Old Baltimore Pike Newark, DE 19702 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 1029 Swarthmore Road, New Cumberland, PA 17070, is scheduled to be sold at the Sheriff's Sale on March 6 2002 at 10:00 a.m., in Cumberland County, Cumberland County Courthouse, Commissioners Hearing Room, Ina Floor, Carlisle, PA 17013 to enforce the court judgment of 588.720.16 obtained by Countrywide Home Loans, Inc. f/k/a Countrywide Funding coTro. (the mortgagee) against you. NOTICE OF OWNER'S RIGHTS YO T ~nY $F RT F TO R V NT TjIT HTi' T F~ A F 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. 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.) vOU Ninv gmTLL BE ABLF' m0 SAVF vOUR PROpFUmv AND YOU unVE O'r'HER RTf HTS EVEN TF mH~' SHERTF~" S SALE DOES 'T'AKE PT A~~ 1. If the Sheriff's Sale is not stopped, your property will be sold to the highest bidder. You may find out the price bid by calling ( i 1 6.7-~'~ 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"171 a0-6 0. 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 WRIT OF EXECUTION and/or ATTACHMENT COMMONWEALTH OF PENNSYLVANIA) COUNTY OF CUMBERLAND) NO. 01-4770 CIVIL 1~ TE1~1 CIVIL ACTION -LAW TO THE SHERIFF OF Clamberland To satisfy the debt, interest and costs due Countrywide Hane Loans Inc. f Jk/a Countrywide ELndina Coro PLAINTIFF(S) from Sun V. Karas and F.dwa~l W. Karas, 356 Old Baltimore Pike, Newark, DE 19702 DEFENDANT(S) (i) You are directed to levy upon the property of the defendant(s) and to sell See Leaal 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 notrfy the garnishee(s) that: (a) an agachment 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) Ifpropertyofthedefendant(s)notlevieduponansubjecttoattachrnentisfoundimthe'possessionofarlyoneother than a named garnishee, you are directed to notify himlherihat he/she has been=added as a garnishee and is enjoined as above stated. Amount Due $88,720.16 L.L, $.50 Interest fran 10/26/01 to sale date at $14.55 Due Prothy S1 _n0 Atty's Gomm % Other Costs Atty Paid 572.00 Plaintiff Paid Date: Novenber 1, 2001 Curtis R. Long Prothonotary, Civil Division REQUESTING PARTY: Name Joseph A. Goldbeck Jr., Esa. Address: Suite 500 -The Bourse Bldg. Philadelphia PA 19106 Attorney for: Plaintiff Telephone: t -6 7-1 22 Supreme Coun ID No. t 67 Deputy REAL ESTATE S,~LE Na. ~ ~ On November 06, 2001, the sheriff levied upon the defendant's interest in the real property situated in New Cumberland Borough, Cumberland County, PA, known and numbered as 1029 Swarthmore Road, New Cumberland, and more fully described on Exhibit "A" filed with this writ and by this reference incorporated herein. Date: November 06, 2001 By'~ ~U~1~ Real stat Deputy ~.: -, ~, ~' ~'.: ~ ~; ~;. ~; ~3 r 1 THE PATRIOT NEWS THE SUNDAY PATRIOT NEWS Proot 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 Asst. Controller of The Patriot News Co., a corporation organized and existing under the laws of the Commonwealth of Pennsylvania, with its principal office and place of business at 812 to 818 Market Street, in the City of Harrisburg, County of Dauphin, State of Pennsylvania, owner and publisher of The Patriot-News and The 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 29th day(s) of January and the 5th and 12th day(s) of February 2002. 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 Countyf of Dauphin in Miscellaneous Book "M", Volume 14, Page 317. f J ' ~~ (~ ,-~ PUBLICATION .................. ....'..`..:v....-'...................................... COPY this 22nd da t Fe ary 2002 A.D. SALE #24 NoterNl eal Terry L Ruec@fl, Public l HaMSburg; Dauphin County My Commissfon Expires June 6, 2002 N ARY PUBLIC Member,PennsyroanlaASSOCiatbnotNOtatl~y commlSSlon eXplres June 6, 2002 CUMBERLAND COUNTY SHERIFFS OFFICE CUMMBERLANDCOUNTYCOURTHOUSE CARLISLE, PA. 17013 Statement of Advertising Costs To THE PATRIOT-NEWS CO., Dr. For publishing the notice or publication attached hereto on the above stated dates $ 211 .20 Probating same Notary Fee(s) $ 1.50 Total $ 212.7p Publisher's Receip4 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 .................................................................... RFpL Edift7~titiLe na.zV - ::.... W cEt Na.:t6ta9 -- CivtlTana- - - ..Cbnnhywid® Hotna Loans, Inc,-- fi{kta Ctiunfrywida Fundit4g GeiF• vs -..-'3uaY. Kssrgs -Edwsrif:W. Kama -Rfty:9ad~ep9i Goldbeck bi S4,$St 17FLW - - - ALL 11161=C.431in1N h r aV haul m7vnR la the N ifdw p~'. Isrwtn9 su;cL Gec i;e i4cau! w.g ]ar P.ucei TiixS - -- ,:: VfF:.[Ti('r. xnbaii a5 lt1'23 ".i•,tiiithmuu P.wd, :Nzx~ Ckdr.IreiTxl>71. E*t ]2ll":;. ____-- PROOF OF PUBLICATION OF NOTICE IN CUMBERLAND LAW JOURNAL (Under Act No. 587, approved May 16, 1929), P. L.1784 STATE OF PENNSYLVANIA COUNTY OF CUMBERLAND ss. Roger M. Morgenthal, Esquire, Editor of the Cumberland Law Journal, of the County and State aforesaid, being duly sworn, according to law, deposes and says that the Cumberland Law Journal, a legal periodical published in the Borough of Carlisle in the County and State aforesaid, was established January 2, 1952, and designated by the local courts as the official legal periodical for the publication of all legal notices, and has, since January 2, 1952, been regularly issued weekly in the said County, and that the printed notice or publication attached hereto is exactly the same as was printed in the regular editions and issues of the said Cumberland Law Journal on the following dates, viz: JANUARY 25, FEBRUARY 1, 8, 2002 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. ~- Ro er M. Morgenthal, Editor SWORN TO AND SUBSCRIBED before me this 8 day of FEBRUARY. 2002 !.®IS E. 5N'lDER, Notary Pubnc CerHsle P.~~, Cu.~r,~eda~ Count9 r Exp~¢as 5, 2i REAL ESTATE SALE NO. 24 Writ No. 2001-4770 Civil Countrywide Home Loans, Inc. f/k/a Countrywide Funding Corp. vs. Sun V. Kazas and Edwazd W. Kass Atty.: Joseph Goldbeck ALL THAT CERTAIN lot of ]and situate in the borough of New Cum- berland. County of Cumberland and State of Pennsylvania, bounded and described as follows, to wit: BEGINNING at a point on the northerly line of Swarthmore Road, said point being located 937.54 feet measured Eastwazdly along said line from the Northeast corner of Swarth- more Road and Drexel Hills Bovle- vard; thence Northwazdly at right angles and along the Easterly line of Lot No. 12. Block "A", on the here- inafter mentioned Plan 105.00 feet to a point; thence North 89 degrees 14 minutes East along line of lands now or formerly of Elmer E. Zimmer- man, 65.00 feet to a point: thence southwazdly at right angles and along the Westerly line of Swarth- more Road; thence by the latter south S9 degrees 14 minutes West, 65.00 feet to the place of BEGIN- NING. Tax Pazcel #26-24-OS09. Being known as 1029 Swazth- more Road, New Cumberland. PA 17070. GOLDBECK McCAFFERTY & MCKEEVER BY: Joseph A. Goldbeck, Jr. Attorney I.D. #16132 Suite 500 -The Bourse Bldg. 111 S. Independence Mall East Philadelphia, PA 19106 215-627-1322 Attorney for Plaintiff COUNTRYWIDE HOME LOANS INC. F/K/A COUNTRYWIDE FUNDING CORP. 7105 Corporate Drive PTX B-35 Plano, TX 75024-3632 Plaintiff vs. SUN V. KARAS EDWARD W. KARAS (Mortgagor(s) and Record owner(s)) 1029 Swarthmore Road New Cumberland, PA 17070 PRAECIPE TO SATISFY JUDGMENT TO THE PROTHONOTARY: No. 01-4770 Kindly Satisfy the Judgment in the above captioned matter upon payment of your costs only. IN THE COURT OF COMMON PLEAS of Cumberland County ~„~ 4a:a ~) ~- ?S7 -n 1 °Lz Ct. ap ~ -i ~ CP1~_', - '- ' _ r c_ -~ -- ~ C ` ~ ` 1~ n CJ _~ ir,