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HomeMy WebLinkAbout01-04917~~ ~ . PRAECIPE FOR WRIT OF EXECUTION - (MORTGAGE FORECLOSURE) P.R.C.P.3180-3183 COUNTRYWIDE HOME LOANS, INC., F/K/A COUNTRYWIDE FUNDING CORPORATION Plaintiff, v. No. 01-4917 DAVID A. SPEICHER Defendant(s). TO THE DIRECTOR OF THE OFFICE OF THE PROTHONOTARY: Issue writ of execution in the above matter: Amount Due Interest from 10/25/01 to 03/06/01 (per diem -14.57) TOTAL 88,643.83 1,923.24 and Costs 90,567.07 F C FEDE AN, SQUIRE One Penn Center at Suburban Station 1617 John F. Kennedy Boulevard, Suite 1400 Philadelphia, PA 19103-1814 Attorney for Plaintiff Note: Please attach description of property.No. u~;.; _~ ;:: ~~i«,~.~ m;~,~, ..~~;,µ, w4li~~~ ~~,,... xµun. z o o~ ~~ ~ r~ U zz ~z x ~ z w ~a °~o ~ o ., °z o3~ ~ ~ ~w w~ xa0 ' d ~ ~ 0o Az~ A x A W o~ ~°~ ~ a~ ~~ ~~ H~ pw p U a U b w M 0 PI W v °x a 3 z M H .-r a tom. N ;u;:'. ~~.,. ~~.,~,. ~;°° ..: vk:.:,, a :K';pr.:~~r _ i .~'-.ws;•.';~Ftro~~=«~,..:5tlcd;u?g .- Y 1795 ,3Li. THAT CS;P:II42N tr set of land with the impso•+ementt t1~erCOn erected cic:iOta in resat Pennaboro Ts~rnship, on the 47ortb aide of ?ennaylvania High•+ay Ftwte No- 641. Cua~Cerland County, Pennsylvania, t+ourxled and dmserib?d in accrordance with a au,rsrey mode by T. R. Neff, Registered Surveyor, on June 22, '965, a draft of said survey being attac':ed thereto and fncorpotated therein by reference, a9 folloy+s: i3GGZNNING at a point in the center 11ne of said ?ennsylvania tteute W . 641 at the Southwestern corner of land nov or formerly of Harold Varner; which point o£ beginning is 300 feat T.test of the c~ntQr line oL Tcwnihip ?cad bro. 796 mca.ured along the cenl-er lint of Pennsylvania Foote No- 641; thence fzom said point at the place of beginning along the center line of said Pennsylvania route No. 611, Spsth 77 degrees 30 ininutea West, a dietsnee o_° 100 _°eet to a point at the Soutk+eastern corner e£ innd nov ar £ermatly o£ G'.eozg. Srullvcocd; thcncm alo~+g the eastern line of lard now or formerly of GecrOe SmalZvWd, North 12 degrees 30 minutes west, a dzata*+ce of 160 feet to an iron pipe in line o£ Iand now ar Pocmerly of eharles M. coillLama, Sc.; thence along said land now or Lormarly o[ Charles M. William-.. Sr-. North 77 dogrcea 30 minutca Ea:.t, a distance o£ 100 lgeC tc a ~.i1CYPr inch dri 1,1 ho to in cock at the .•brttrwetarn COCn?L OP 2.and now or formerly of Harold Varnec; ehenoe along the Western Sine pi' ],and now Or fermerly of Harold Varner, South 12 degrees 30 minutes r_~t, a dir,tane4 of 160 Peen to a point in the center lino of 2ennaylvania Foote 641. the Place o[ B,DGINNSN[1- 88ING s11 oP Lot No. 4 os ehcr+n on Plan of Zots of c~arlas M. William:, Sr., sne;orded in the Off ic. of the Facerder of bends in and For Gumberl.and Co,azty, Pennsylvania+ in Plan Hook 4, Page 12. CON'iAIVING 100 feet in From along she enter linc+ of Pennsylvania Raxte No- 64l and extendirt7 northwardly therefrom e t]istarscb of 160 feet. 7tAVING thereon erected a two story alumi nom 3idin9 covor~d dwelli~ house. arr3 Other impcovaments. SgimG the s~ pt?misos vhiCh Craig 1a. :S~cutas and Phy/Iis A, ztomas, his wif?. by Indenture dat®d OCtAter 28, 1988 and recorded at ear'_ials fn she Co~u:ty of Ckenberlerd on Oetolxr 2©, 1488 in Lied Book Q-33, xge 392, e~ranted and corsveyed unto Ztfomas E. Pskerd and Lassie L. nekerd, his .rife, in fee. •_q ~• }~~ 'r9 ~ ~ ~ ~ ~ ~ +~. h ~ _ ~.,> .~ 7 ~ , ~ ~; ~z ~ r\4 17 -[ V J tea- y ,,-e ..,, ., a ...ter . _:.... ~'~+~°^WR;'„ ,. SHERIFF'S RETURN - REGULAR CASE N0: 2001-04917 P COMMONWEALTH OF PENNSYLVANIA: COUNTY OF CUMBERLAND COUNTRYWIDE HOME LOANS INC ETA VS SPEICHER DAVID A KATHY CLARKE Sheriff or Deputy Sheriff of Cumberland County,Pennsylvania, who being duly sworn according to law, says, the within COMPLAINT - MORT FORE was served upon DAVID A the DEFENDANT at 1735:00 HOURS, on the 20th day of September, 2001 at 1513 NEWVILLE RD CARLISLE, PA 17013 by handing to DAVID SPEICHER a true and attested copy of COMPLAINT - MORT FORE together with and at the same time directing His attention to the contents thereof. Sheriff's Costs: Docketing 18.00 Service 3.25 Affidavit .00 Surcharge 10.00 .00 31.25 Sworn and Subscribed to before me this z 7 / day of ~,.Ge.~~ oZnt~ --l~~,, ~~ ~~A. D . o h~xy~~ So Answers: ~~~~a~ R. Thomas Kline 09/21/2001 FEDERMAN & PHELAN By : ~~1u-+"~ Deputy eriff FEDERMAN AND PHELAN By: FRANK FEDERMAN Identification No. 12248 Attorney for Plaintiff ONE PENN CENTER AT SUBURBAN STATION 1617 JOIIN F. KENNEDY BLVD., SUITE 1400 PHLLADELPHIA, PA 19103-1814 (215) 563-7000 COUNTRYWIDE HOME LOANS, INC., F/K/A COUNTRYWIDE FUNDING CORPORATION 7105 CORPORATE DRIVE PLANO, TX 72024 CIVII. DIVISION v. Plaintiff, DAVID A. SPEICHER Defendant(s). PRAECIPE FOR JUDGMENT FOR FAILURE TO ANSWER AND ASSESSMENT OF DAMAGES TO THE PROTHONOTARY: Kindly enter judgment in favor of the Plaintiff and against DAVID A. SPEICHER and , Defendant(s) for failure to file an Answer to Plaintiffs Complaint within 20 days from service thereof and for Foreclosure and Sale of the mortgaged premises, and assess Plaintiffs damages as follows: As set forth in Complaint Interest from 7/1/01 to 10/25/01 TOTAL CUMBERLAND COUNTY COURT OF COMMON PLEAS NO. 01-4917 86,508.58 2,135.25 88,643.83 I hereby certify that (1) the addresses of the Plaintiff and Defendant(s) are as shown above, and (2) that notice has been given in accordance with Rule 237.1, copy attached. FRA~ ~ FEDERMAN, QU1RE Atto ey for Plaintiff DAMAGES ARE HEREBY ASSESSED AS INDICATED. DATE: ~ ,ZW ~ ~ ` ~ PRO PROTHY r (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 CORPORATION 7105 CORPORATE DRIVE Plaintiff, v. DAVID A. SPEICHER Defendant(s). CUMBERLAND COUNTY COURT OF COMMON PLEAS CIVIL DIVISION NO. 01-4917 Notice is given that a Judgment in the above-captioned matter has been entered against you on 2001 . By: DEPUTY If you have any questions concerning this matter, A orney for Plainti O PENN CENTER T SUBURBAN STATION 161 JOHN F. KENNE Y BLVD., SUITE 1400 PHILADELPHIA, PA 19103-1814 (215)563-7000 **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 AND THIS DEBT WAS NOT REAFFIRMED, THIS CORRESPONDENCENDENCE IS NOT AND SHOULD NOT BE CONSTRUED TO BE AN ATTEMPT TO COLLECT A DEBT, BUT ONLY ENFORCEMENT OF A LIEN AGAINST PROPERTY.** ~, . IOXY~~ I~~+. ,,b~,:a« ~;aa, ~...,.. „,,. FEDERMAN and PHELAN By: FRANK FEDERMAN Identification No. 12248 ONE PENN CENTER AT SUBURBAN STATION 1617 JOHN F. KENNEDY BLVD., SUITE 1400 PHILADELPffiA, PA 19103-1814 (215)563-7000 COUNTRYWIDE HOME LOANS, INC., F/K/A COUNTRYWIDE FUNDING CORPORATION 7105 CORPORATE DRIVE ATTORNEY FOR PLAINTIFF CUMBERLAND COUNTY COURT OF COMMON PLEAS CIVIL DIVISION v. Plaintiff, NO.Ol-4917 DAVID A. SPEICHER Defendant(s). VERIFICATION OFNON-MILITARY SERVICE FRANK FEDERMAN, 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 defendant(s) is/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 DAVID A. SPEICHER is over 18 years of age and resides at , 1513 NEWVILLE ROAD, CARLISLE,PA 17013 . (c) that defendant is over 18 years of age, and resides at , , . This statement is made subject to the penalties of 18 Pa. C.S. Section 4904 relating to unswom falsification to authorities. ~-- F ~ FEDE AN ESQUIIZE Attorney for Plaintiff 10/29/01 NION 12:17 FAX 2155633826 ., ~ FEDERMAN AND PHELAN, L.L.P. Frank Federman, Esquire identification No. 12248 One Penn Center Plaza at Suburban Station, Suite 1400 Philadelphia, PA 19103-1799 (215) 563-7000 COUNTRYWIDE HOME LOANS, INC., F/K/A COUNTRYWIDE FUNDING CORPORATION Plaintiff vs. DAVID A. SPEICHER Defendant(s) TO: DAVID A. SPEICHER 1513 NEWVILLE ROAD CARLISLE ,PA 17013 DATE OF NOTICE: OCTOBER 11,2001 THIS FIRM IS A DEBT COLLECTOR ATTEMPTING TO COLLECT A DEBT. THIS NOTICE IS SENT TO YOU IN AN ATTEMPT TO COLLECT THE INDEBTEDNESS REFERRED TO HEREIN, AND ANY INFORMATION OBTAINED FROM YOU WILL BE USED FOR THAT PURPOSE. IF YOU HAVE PREVIOUSLY RECEIVED A DISCHARGE IN BANKRUPTCY, THIS CORRESPONDENCE IS NOT AND SHOULD NOT BE CONSTRUED TO BE AN ATTEMPT TO COLLECT A DEBT, BUT ONLY AS ENFORCEMENT OF LIEN AGAINST PROPERTY. IMPORTANT NOTICE You are in default because you have failed enter a written appearance personally or by attorney and file in writing with the court your defenses or objections to the claims set forth against you. Unless you act within ten (10) days from the date of this notice, a Judgment may be entered against you without a hearing and you may lose your property or other important rights. You should take this notice to a lawyer at once. If you do not have a lawyer or cannot afford one, go to or telephone the following office to find out where you can get legal help: CUMBERLAND COiJNTY CUMBERLAND COUNTY BAR ASSOCIATION 2 LIBERTY AVENUE CARLISLE, PA 17013 (717) 249-3166 FEDERNAN AND PHELAN ATTORNEY FOR PLAINTIFF COURT OF COMMON PLEAS CIVIL DIVISION CUMBERLAND COUNTY NO. 01-4917 CIVIL Fra~ an' Esquire Attorney for Plaintiff @l 002 ~ a n ' ~ _. ~, o ' G ~' ~ ~. C-li ~' c ~~ ~i.1j ~ ~ ~ ~ t - M^,1 (,(~q( (~" f 1 3#41~nF.a~,rxw:„m€a~iTeg-: .•."~sR,~iC.,. - ~ ~WtY, Ld~H,.x,.• ~.:: .x '.:,.. -. wn.+ro!c:AEFS&a ::;qf„c.+ -. 4 COUNTRYWIDE HOME LOANS, INC., F/K/A COUNTRYWIDE FUNDING CORPORATION Plaintiff, v. DAVID A. SPEICHER Defendant(s). CUMBERLAND COUNTY COURT OF COMMON PLEAS CIVIL DIVISION NO.Ol-4917 AFFIDAVIT PURSUANT TO RULE 3129 (Affidavit No. 1) COUNTRYWIDE HOME LOANS, INC., F/K/A COUNTRYWIDE FUNDING CORPORATION, Plaintiff in the above action, by its attorney, FRANK FEDERMAN, ESQUIItE, sets forth as of the date the Praecipe for the Writ of Execution was filed the following information concerning the real property located at, 1513 NEWVILLE ROAD, CARLISLE,PA 17013 . 1. Name and address of Owner(s) or reputed Owner(s): NAME LAST KNOWN ADDRESS (If address cannot be reasonably ascertained, please so indicate.) DAVID A. SPEICHER 1513 NEWVILLE ROAD CARLISLE,PA 17013 2. Name and address of Defendant(s) in the judgment: NAME LAST KNOWN ADDRESS (If address cannot be reasonably ascertained, please so indicate.) Same as above 3. Name and address of every judgment creditor whose judgment is a record lien on the real property to be sold: NAME LAST KNOWN ADDRESS (If address cannot be reasonably ascertained, please so indicate.) „; ~;.„. ..~~+~,~ ..~;ua,, ~.,., ~.~... ~.. ~eM4+.. .a;,,,. AWMu .~;.w,. w;:° American General 3120 Parkview Lane, Suite 101 Finance Harrisburg, PA 17103 4. 6. Name and address of the last recorded holder of every mortgage of record: NAME LAST KNOWN ADDRESS (If address cannot be reasonably ascertained, please so indicate.) None Name and address of every other person who has any record lien on the property: NAME LAST KNOWN ADDRESS (If address cannot be reasonably ascertained, please so indicate.) None Name and address of every other person who has any record interest in the property and whose interest maybe affected by the sale: NAME LAST KNOWN ADDRESS (If address cannot be reasonably ascertained, please so indicate.) None Name and address of every other person whom the plaintiff has knowledge who has any interest in the property, which maybe affected by the sale: NAME LAST KNOWN ADDRESS (If address cannot be reasonably ascertained, please so indicate.) Tenant/Occupant 1513 NEWVILLE ROAD CARLISLE,PA 17013 Domestic Relations of 13 North Hanover Street Cumberland County Carlisle, PA 17013 Commonwealth of p0 Box 2675 Welfarelvania Department of Harrisburg, PA 17105 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. Sec. 4904 relating to unsworn falsification to authorities. October 25. 2001 DATE F { FEDERMAN~ESQUIRE Attorney for Plaintiff ~;~;~; ~,.,, i~~' ~,... ~.~.,. ~~:~; w~;,u.. ..~ik.,. .,u~,„~ "»::, nM t.n c ~ c~~ c~ c --- -~a ~, z , ;, ~ r- _- ~_v <: u,`;: o - ~:_ r~ st :: ~ - -_; i ~ ~yc '~ 9 .~l'l a -4 :. ~1 ~+4?~§:`=+'*P- I + <.=~:.a .. s.~^:-~ 4 ~.~ ::=i_ ".. tr"^Ti.'YFV?F`~r'K ' FEDERMAN AND PHELAN, LLP .' ~ By: FRANK FEDERMAN, ESQUIItE IDENTIFICATION NO. 12248 ATTORNEY FOR PLAIN"I'1FF ONE PENN CENTER AT SUBURBAN STATION 1617 JOHN F. KENNEDY BOULEVARD SUITE 1400 PHILADELPHIA, PA 19103-1814 (2151 563-7000 COURT OF COMMON PLEAS CIVIL DIVISION COUNTRYWIDE HOME LOANS, INC., F/K/A COUNTRYWIDE FUNDING CORPORATION 7105 CORPORATE DRIVE PLANO, TX 72024 TERM Plaintiff ' _ ~Q` 7 /7 q~ yam, " "'~ l U l C O 1 NO v. , ,,, . CUMBERLAND COUNTY DAVID A. SPEICHER 1513 NEWVILLE ROAD CARLISLE, PA 17013 Defendant(s) CIVIL ACTION -LAW COMPLAINT IN MORTGAGE FORECLOSURE NOTICE **THIS FIRM IS A DEBT COLLECTOR ATTEMPTING TO COLLECT A DEBT AND ANY INFORMATION OBTAINED WII,L BE USED FOR THAT PURPOSE. IF YOU HAVE PREVIOUSLY RECEIVED A DISCHARGE IN BANKRUPTCY AND THIS DEBT WAS NOT REAFFIRMED, THIS CORRESPONDENCE IS NOT AND SHOULD NOT BE CONSTRUED TO BE AN ATTEMPT TO COLLECT A DEBT, BUT ONLY ENFORCEMENT OF A LIEN AGAINST PROPERTY. ** 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 this Complaint and Notice are served, by entering a written appearance personally or by attorney and filing in writing with the court your defenses or objections to the claims set forth against you. You are warned that if you fail to do so the case may proceed without you and a judgment maybe entered against you by the court without further notice for any money claimed in the Complaint or for any other claim or relief requested by the Plaintif£ You may lose money or property or other rights important to you. YOU SHOULD TAKE THIS PAPER TO YOUR LAWYER AT ONCE. IF YOU DO NOT HAVE A LAWYER OR CANNOT AFFORD ONE, GO TO OR TELEPHONE THE OFFICE SET FORTH BELOW TO FIND OUT WHERE YOU CAN GET LEGAL HELP. CUMBERLAND COUNTY CUMBERLAND COUNTY BAR ASSOCIATION 2 LIBERTY AVENUE CARLISLE, PA 17013 (717) 249-3166 Loan #:5708545 IF THIS IS THE FIRST NOTICE THAT YOU HAVE RECEIVED FROM THIS OFFICE, BE ADVISED THAT: PURSUANT TO THE FAIR DEBT COLLECTION PRACTICES ACT,15 U.S.C. § 1692 et seq. (1977), DEFENDANT(S) MAY DISPUTE THE VALIDITY OF THE DEBT OR ANY PORTION THEREOF. IF DEFENDANT(S) DO SO IN WRITING WITHIN THIRTY (30) DAYS OF RECEIPT OF THIS PLEADING, COUNSEL FOR PLAINTIFF WILL OBTAIN AND PROVIDE DEFENDANT(S) WITH WRITTEN VERIFICATION THEREOF; OTHERWISE, THE DEBT WILL BE ASSUMED TO BE VALID. LIKEWISE, IF REQUESTED WITHIN THIRTY (30) DAYS OF RECEIPT OF THIS PLEADING, COUNSEL FOR PLAINTIFF WILL SEND DEFENDANT(S) THE NAME AND ADDRESS OF THE ORIGINAL CREDITOR, IF DIFFERENT FROM ABOVE. TAE LAW DOES NOT REQUIRE US TO WAIT UNTIL THE END OF THE THIRTY (30) DAY PERIOD FOLLOWING FIRST CONTACT WITH YOU BEFORE SUING YOU TO COLLECT THYS DEBT. EVEN THOUGH THE LAW PROVIDES THAT YOUR ANSWER TO THIS COMPLAINT IS TO BE FILED IN THIS ACTION WITHIN TWENTY (20) DAYS, YOU MAY OBTAIN AN EXTENSION OF THAT TIME. FURTHERMORE, NO REQUEST WILL BE MADE TO THE COURT FOR A JUDGMENT UNTIL THE EXPIRATION OF THIRTY (30) DAYS AFTER YOU HAVE RECEIVED THIS COMPLAINT. HOWEVER, IF YOU REQUEST PROOF OF THE DEBT OR THE NAME AND ADDRESS OF THE ORIGINAL CREDITOR WITHIN THE THIRTY (30) DAY PERIOD THAT BEGINS UPON YOUR RECEIPT OF THIS COMPLAINT, THE LAW REQUIRES US TO CEASE OUR EFFORTS (THROUGH LITIGATION OR OTHERWISE) TO COLLECT THE DEBT UNTIL WE MAIL THE REQUESTED INFORMATION TO YOU. YOU SHOULD CONSULT AN ATTORNEY FOR ADVICE CONCERNING YOUR RIGHTS AND OBLIGATIONS IN THIS SUIT. Plaintiff is COUNTRYWIDE HOME LOANS, INC., F/K/A COUNTRYWIDE FUNDING CORPORATION 7105 CORPORATE DRIVE PLANQ TX 72024 2. The name(s) and last known address(es) of the Defendant(s) aze: DAVID A. SPEICHER 1513 NEWVILLE ROAD CARLISLE, PA 17013 who is/are the mortgagor(s) and real owner(s) of the property hereinafter described. 3. On 11/16/95 mortgagor(s) made, executed and delivered a mortgage upon the premises hereinafter described to PROVIDENT MORTGAGE CORPORATION, T/A CONSOLIDATED MORTGAGE CORPORATION which mortgage is recorded in the Office of the Recorder of CUMBERLAND County, in Mortgage Book No. 1291, Page 1086. Said mortgage was modified as set forth in the modification agreement Recorded 12/27/95, in Mortgage Book No.511, Page.142. By Assignment of Mortgage Recorded 11/17/95 the mortgage was assigned to PLAIIVT'IFF which Assignment is recorded in Assignment of Mortgage Book No. 508, Page 542. Said (Assignment of) Mortgage was re-recorded on 5/28/96 in (Assignment of) Mortgage Book No. 520, Page 1134. 4. The premises subject to said mortgage is described as attached. 5. The mortgage is in default because monthly payments of principal and interest upon said mortgage due 12/1/00 and each month thereafter are due and unpaid, and by the terms of said mortgage, upon failure of mortgagor to make such payments after a date specified by written notice sent to Mortgagor, the entire principal balance and all interest due thereon aze collecfible forthwith. A copy of such notice is attached as Exhibit "A." 6. The following amounts are due on the mortgage: Principal Balance $76,173.13 Interest 4,434.75 11/1/00 through 7/1/01 (Per Diem $18.25) Attorney's Fees 3,808.00 Cumulative Late Charges 290.80 11/16/95 to 7/1/01 Cost of Suit and Title Search 750.00 Subtotal $85,456.68 Escrow Credit 0.00 Deficit 1,051.90 Subtotal 1 051.90 TOTAL $86,508.58 7. 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 Sheriffs Sale. If the Mortgage is reinstated prior to the Sale, reasonable attorney's fees will be charged. 8. This action does not come under Act 6 of 1974 because the original mortgage amount exceeds $50,000.00. 9. The Combined Notice has been sent to the Defendant(s) by regular and certified mail as required by 35 P.S. § 1680.403c on the date(s) set forth in the true and correct copy of such notice(s) attached hereto as Exhibit "A." 10. The Temporary Stay as provided by the Homeowner's Emergency Mortgage Assistance Program, Act 91 of 1983, has temunated because either: (i.) Defendant(s) have failed to meet with the Plaintiff or an authorized Credit Counseling Agency in accordance with Plaintiff's written Notice to Defendants, a true and correct copy of which is attached hereto as Exhibit "A"; or (ii.) Defendant(s) application for assistance has been rejected by the Pennsylvania Housing Finance Agency. WHEREFORE, PLAINTIFF demands an in rem Judgment against the Defendant(s) in the sum of $86,508.58, together with interest from 7/1/01 at the rate of $18.25 per diem to the date of Judgment, and other costs and charges collectible under the mortgage and for the foreclosure and sale of the mortgaged property. ~,,~~~~- /s/ Frank Federman FRANK FEDERMAN, ESQUIItE Attorney for Plaintiff ~ Countrywide HOME LOANS Send Correspondence to: Send Payments to: PO. Box 260599 P.O. eax 660694 Plana, TX ]5026-0599 Galles, TX ]5266-0694 Certifietl Mail No. June 1, 2001 Return Receipt Requested Regular Mail David A Speicner 1513 Newviile Road Carlisle, PA 17013-0000 Account No.: 5708545 Property Address: 1513 Newviile Road Carlisle, PA 17013-0000 Current Servicer: Countrywide Home Loans, Inc. ACT 91 NOTICE TAKE ACTION TO SAVE YOUR HOME FROM FORECLOSURE This is an official notice that the monaace on vour home is in default. and the lender intentls to foreclose. ScecBic information about the nature of the default is provided in the attached daces The HOMEOWNER'S EMERGENCY MORTGAGE ASSISTANCE PROGRAM (HEMAPI may be able to halo to save your home. This Notice explains how the oro9ram works. To see if HEMAP can help, you must MEET WITH A CONSUMER CREDIT COUNSELING AGENCY WITHIN 30 DAYS OF THE DATE OF THIS NOTICE. Take this Notice whh you when vau meet with the Counseling Agencv. This Notice contains important legal imormation. M you have any questions, representatives at the Consumer Cretlit Counseling Ageney may be able to help answer them. You may also wan[ to cornea an attorney in your area. The local bar association may be able to help you find a lawyer. LA NOTIFICACION EN ADJUNTO ES DE SUMA IMPORTANCIA, PLIES AFECTA SU DERECHO A CONTINUAR VIVIENDO EN SU CASA. SI NO COMPRENDE EL CONTENIDO DE ESTA NOTIFICACIUN OBTENGA UNA TRADUCCION INMEDIATAMENTE LLAMANDO ESTA AGENCIA (PENNSYLVANIA HOUSING FINANCE AGENCY) SIN CARGOS AL NIIMERO MENCIONADO AFIRIBA. PUEDE SER ELEGIBLE PARA UN PRESTAMO POR EL PROGRAMA LLAMADO "HOMEOWNER'S EMERGENCY MORTGAGE ASSISTANCE PROGRAM" EL CUAL PUEDE SALVAR SU CASA DE LA PERDIDA DEL DERECHO A REDIMIR SU HIPOTECA. HOMEOWNER'S EMERGENCY MORTGAGE ASSISTANCE PROGRAM YOU MAY BE ELIGIBLE FOR FINANCIAL ASSISTANCE WHICH CAN SAVE YOUR HOME FROM FORECLOSURE AND NELP YOU MAKE FUTURE MORTGAGE PAYMENTS. IF YOU COMPLY WITH THE PROVISIONS OF THE HOMEOWNER'S EMERGENCY MORTGAGE ASSISTANCE ACT OF 1983 (THE "ACT"), YOU MAY BE ELIGIBLE FOR EMERGENCY MORTGAGE ASSISTANCE: IF YOUR DEFAULT HAS BEEN CAUSED BY CIRCUMSTANCES BEYOND YOUR CONTROL, IF YOU HAVE A REASONABLE PROSPECT OF BEING ABLE TO PAY YOUR MORTGAGE PAYMENTS, AND IF YOU MEET OTHER ELIGIBILITY REQUIREMENTS ESTABLISHED BV THE PENNSYLVANIA HOUSING FINANCE AGENCY. Please write your account number on all checks and correspontlence. BBEACHPA 6/2 6120 0 0 Davie A Speicher 5708545-8 1513 Newviile Roae $4,593.52 AS OF July 6, 2007 Alx yi,o N5ro1§10 W n RIwI1M1aWpN Ivr[~MUmbprymni eeegaeoPxrbainlW tylsv BPEACMPq ~Countrywide'° HOME LOANS P.O. Box 660694 Dallas, TX 75266-0694 Ilrrrlrlrlrrrlrlrllrrrlllrllrllrllrrlrlrrrlrrllrlrrrlrrlrrll0 57085458D004593520459352 ~1-llp~T ap.rr TEMPORARY STAY OF FORECLOSURE -Under the Act, you are entitletl to a temporary stay of foreclosure on your mortgage for thirty-five (35) days frdm the tlate of this Notice. During that time you must arrange antl attend a"face-to- face" meeting with one of the consumer credit counseling agencies listetl at 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 entl of this notice, the lender may NOT take action against you for thirty-five (35) days after the date of this counfv in which the orooerty is located are set forth at the end of this Notice. It is only necessary to schetlule one face- to-face meeting. Advise your lentler immediately of your intentions. APPLICATION FOR MORTGAGE ASSISTANCE -Your mortgage is in default for the reasons set forth later in this Notice (see following pages for specific information about the nature of your default.) If you have tried and are unable to resolve this problem with the lender, you have the fight 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 entl of [his Notice. Only consumer cretlif counseling agencies have applications for the program and they will assist you in submitting a complete application to the Pennsylvania Housing Finance Agency. Your application MUST be filetl or postmarketl within thirty-Five (35) 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 disbursetl by the Agency untler 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 tlecision on your application. NOTE: IF YOU ARE CURRENTLY PROTECTED BY THE FILING OF A PETRION IN 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.) 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 • CouMrvwitle Home Loans. Inc.. (hereinafter "Countrywide") services your home loan. Your home loan is in serious default because you have not made your required payments. The total amount now fequiretl to reinstate your home loan as of the date of this letter is as follows: Monthly Payments: Late Charges: Other Charges: $727.02 $676.78 $29.06 $27.07 Uncollectetl Late Charges: UnCOIIeCIetl Costs: TOTAL DUE: PAYMENT INSTRUCTIONS Please Make yourfheGk payable fo Coanlrywide Home Loans Write your loan number on ypur check or money order Write In any additional amounts you are inGUtling. pl total iS mor8 than $5000, please seatl Genllled Check ) OonY attach yop! Check to the paYmenl Coupon Don't inclutle coaespontlence bony aedtl Gash Payments: All payments well be applietl to the longest oulSlanding in5lallmenl due, unless otherwise expre55ty DmhibAed by law $3,635.10 $676.78 $145.40 $27.07 $87.24 $21.93 $4,593.52 Additional emounk. If you dpnl speciry the purpose of addNanal ampunls inclutletl, wa will apply them first tp any pNSlantling ~~I~'~ u~la payments, escrpw defwMncies, tale charges andlor lees due. We will Ihen apply any remaining amounts as a princpal retludion. If you submA an additbnal prindpal payment wdh youi home ban paymem, Countrywltle will first appty your home loan payment, then the addihpnal pfincipal payment. Your loan mug be cogent before we can apply any principal retluclion. HOW TO CURE YHE DEFAULT -You may cure }his tlefault within THIRTY-FIVE (35) DAYS of the date of this letter, by paying to us the above amount of $4,593.52, plus any additional monthly payments, late charges, fees antl other applicable charges which may fall tlue during this period. Such payment must be in the form of certified check, cashiers check or money order, antl made payable to Countrywide at P.O. Box 660694, Dallas, TX 75266-0694. If your check or other payment is returnetl to us for ihsufficient funds or for any other reason, you will not have cured your tlefault. No extension of time to cure will be grantetl due to a returnetl payment. If you do not cure [his tlefault within THIRTY-FIVE (35) DAYS, we will accelerate the payments tlue on your home loan. This means whatever is owing on the original amount borrowetl will be consitleretl tlue immediately antl you may lose the chance to pay off your home loan in monthly installments. If the full payment of the amount in tlefault is not matle within THIRTY-FIVE (35) DAYS, we also intend to immediately start a lawsuit to foreclose on your mortgagetl property. 6 THE MORTGAGE IS FORECLOSED UPON - tt the mortgage is toreclosetl, the mortgagetl property will be soltl by the Sheriff to pay off the mortgage debt. If the default is cured before we begin legal proceedings, Countrywitle will be entttletl to collect the reasonable attorney's fees actually incurred, up to $50.00. However, if legal proceedings are startetl, Countrywitle will be entttled to collect the reasonable attorney's tees even if they are over $50.00. Any attorney's fees will be added to the secured debt, which may also inclutle our reasonable costs. If you Cure the default within the THIRTY-FIVE (35) DAY period, you will not be required to pay attorney's fees. YOU HAVE THE RIGHT TO REINSTATE AFYER ACCELERATION AND RIGHT TO ASSERT IN THE FORECLOSURE PROCEEDING THE NON- EXISTENCE OF A DEFAULT OR ANY OTHER DEFENSE YOU MAY HAVE TO ACCELERATION AND FORECLOSURE. OTHER LENDE REMEDIES -The lender may also sue you personally for the unpaitl principal balance and all other sums due under the mortgage. RIGHT TO CURE THE DEFAULT PRIOR TO FORECLOSURE SALE - If you have not curetl the default within the THIRTY-FIVE (35) DAY perfod antl 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 foreclosure sale. You may tlo so by paying the total amount then past due, plus any late or other charges then due, reasonable attorney's fees and costs connectetl with the foreclosure sale antl any other costs connected with the foreclosure sale as specified in writing by the lentler antl by performing any other requirements under the mortgage. Cudng your default In the manner set forth in this notice will restore your mortgage to the same posttion as if you had never defaulted. EARLIEST POSSIBLE FORECLOSURE SALE DATE - 11 Is estimated that the earliest date that a foreclosure sale could be held would be approximately six (6) months from the tlate ofthis letter. A notice of the date of the foreclosure sale will be sent to you before the sale. Vou may find out at any time exactly what the required payment will be by calling us at the following number: 1-800-669-4575. This payment must be in the form of a cashier's check, certified check or money order antl matle payable to us at the atltlress statetl above. If the default is cured, the mortgage will be restored to the same position as if no defauN had occurred. However, the default may not be curetl more than three (3) times in any calendar year. HOW TO CONTACT THE LENDER; Name of Lender: Countrywlde Home Loans, Inc Address: P. O. Box 19221 Van Nuys, CA 914160221 Phone Number: 1-806669-4575 Fax Number: 1-805-577-3432 Contact Person: Ashley Canady, MS SV-34 Attention: Loan Counselor EFFECT OF FORECLOSURE SALE -You shoultl realize chat a foreclosure sale will entl your ownership of the mortgagetl propertry and your right to remain in it. If you continue to live in the property after the Sheriff's sale, a lawsuit to remove you and your furnishings antl other belongings coultl be started by Countrywide at any time. ASSUMPTION OF MORTGAGE -Contact Countrywide Home LOanS for information on the possible assumability of your loan. VOU 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 YO CURE YOUR DEFAULT MORE THAN THREE TIMES IN ANV CALENDAR YEAR.) TO ASSERT THE NONEXISTENCE OF A DEFAULT IN ANY FORECLOSURE PROCEEDING OR ANY OTHER LAWSUIT INSTITUTED UNDER THE MORTGAGE DOCUMENTS. TO ASSERT ANY OTHER DEFENSE YOU BELIEVE YOU MAY HAVE TO SUCH ACTION BY THE I-ENDER. TO SEEK PROTECTION UNDER THE FEDERAL BANKRUPTCY LAW Pursuant to your home loan documents, antl because the home loan is in tlefault, Countrywitle may, at its option, enter upon antl conduct an inspection of the property. The purpose of this Inspection is to observe the physical contlition of the properly, to verify that the property is occupietl antl/or to determine the itlentiry of the occupant. The cost of any such inspection will be atldetl to and became part of the secured debt as provided untler the terms of the home loan documents. E)Cti1Bl1" "/~" Ii you are unable to cure your tlefault on or before July 6, 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 propeny. 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 h of the amount necessary to bring the account current, and that the balance of the overdue amount be paitl, along with the regular monthly payment, over a tlefinetl periotl of time. Other repayment plans also are available. • Loan Motlification: Alternatively, it is possible that the regular monthly payments can be lowered through a modification of the loan by reducing the interest rate antl then atltling the tlelinquen[ payments to the cu«ent loan balance. This foreclosure alternative, however, is limited to certain loan types. • Sale of Your Prooertv: Alternatively, If you are willing to sell your home in order to avoid foreclosure, it is possible that the sale of your home can be approvetl through Coun[rywitle even if your home is worth less than what is owed on it. • Deed-in-Lieu: Alternatively, if your property is free from other liens or encumbrances, and ii the default is due to a serious financial hartlship which is beyond your control, you may be eligible to deed your properly directly to the Noteholder and avoid the foreclosure sale. If you are interested in tliscussing foreclosure alternatives with Countrywide, you must contact us immediately. If you request assistance, Countrywide will determine, in its sole tllsCretion, whether such assistance will be extended t0 you. In the meantime, Countrywide will pursue all of its rights antl remedies under the home loan documents and as permitted by law, unless it agrees otherwise in wrhing. Please be advised that failure to bring the home loan current or to enter into 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 Countrywitle's office immediately at 1-800-669-4575, extension 7149. Ashley Canady Loan Counselor 1-800-669-4575, extension 7149 Please be advised that this communication is from a tlebt collector. l'•VL1IB~-1 x/'1h PENNSYLVANIA HOUSING FINANCE AGENCY HOMEOWNER'S EMERGENCY ASSISTANCE PROGRA,Y[ COYSUMER CREDIT COUNSELING AGENCIES (REV. 8/00) CLINTON COUNTY Lycoming-Clinton Counties Commision for CCCS ofNortheastem P.4 Community Action (STEP) 1631 South Atherton St, Suite l00 2138 Lincoln Sveet P.O. Box 1328 State College, PA 16801 Williamsport, PA 17703 (814) 238-3668 FAX (814) 238-3669 (570) 326-0587 FAX (i10) 322-2197 CCCS of Noriheastem PA 201 Basin Sveet Williamsport, PA 17703 (570) 323-6627 FAX (570) 323fi626 3l W. Mazket Sveet POB l l27 Wilkes-Barre, PA 18702 (570)821.0837 or (800)922-9537 FAX (570) 821-1785 COLUMBIA COUNTY Commission on Economics Opportwiry of Luzeme County 163 Amber Lane Wilkes-Bane, PA 18702 (570) 326.05 (0 or (800) 822-0359 FAX (570) 829-1665--(Call Before Faxing) (570) 455-'3994 Hamltown FAX (570) 455-1631--(Call Before Faxing) (570) 836.4090 Twkhawock Booker T. Washington Center 1720 Holland Center Erie, PA 16503 (8l4) 453.5744 FAX (8l4) 5749 John F. Kennedy Center, Inc. 2021 Eas[ 20i° Street Erie, PA 16510 (8!4)398.0400 FAX (814) 898-1243 CCCS of Western Pennsylvania, Inc. 2000 Linglestown Road Hamisbiug, PA 17102 (717)541-1757 Urban League of Mewpolitw Harrisburg N. 6'" Sveet Harrisburg, PA 17101 (717) 234x925 FAX (717) 234-9459 Commwity Action Comm of the Capital Region 1514 Derry Street Harrisburg, PA 17104 (717) 232-9757 FAX (717) 234-2227 CRAWFORD COUNTY CUhIBERLAW COUNTY 1400 Abington Executive Park Suite t Clarks Summit PA 18411 (570) 587-9163 or (800) 922.9537 FAX (570) i87-9134-9135 Greater Erie Community Action Comminee 18 West 9" Svee[ Erie, PA 16501 (814) 459-[581 FAX (8!4)156-0161 Shenango Valley Urban League, inc. 60l Indiana Avenue Farrell, PA 1612( (412)981-5310 Financial Counseling Services of Franklin 31 Wes[ 3i° Sveet Waynesboro, PA 17268 (7!7)762-3285 YWCA of Carlisle 301 "G" Street Carlisle, PA 17013 (7(7) 243x818 FAXC (717) 731.9589 Adams Cowry Housing Authority 139-143 Carlisle St Gettysburg, PA 17325 (717) 334-1118 FAX 334-8326 PEyNSYLVA.YW BULLETIN, VOL. 29, NO.23, JUNE 5, 1999 ~/if'AIBI~ ®ABt ALL that certain tract of land with the improvements thereon situate in West Pennsboro Township, Cumberland County, Pennsylvania, bounded and described according to a survey made by T.A. Neff; R.S., dated Jutte 22, 1965; as recorded with prior deeds of record, as follows: BEGINNING at a point in the centerline of Pennsylvania Route No. 641, at the southwestern corner of land now or formerly of 19arold Varner, which point is 300,00 feet west o1' the centerline of Township Road No. T-706 measured along the centerline of Pennsylvania Route No. 641; thence along the centerline of said Pennsylvania Route No. 641, Sou[h 77 degrees 30 minutes West, a distance of !00.00 feet to a point at the southeastern wrner of land now or formerly of George Smallwood; thence along the latter, North 12 degrees 30 minutes West, a distance of 160,00 feet to an iron pipe in the line of land now or formerly of Charles M. Williams, Sr„ thence along the fatter, North 77 degrees 30 minutes Last, a distance of 100.00 feet to a quarter inch drill hole in rock at the northwestern corner of land now or formerly of Harold Varner, thence along the latter, Soutft 12 degrees 30 minutes East, a distance of 160,00 feet to a paint in the centerline of Pennsylvania Route No, 641, the Ptnce of BEGINNTNG, ISli,1NG the=same property which CRA1G A. THOMAS and Pl-TYLLSS E.'fi-IOMAS, his wife, grvtted and conveyed to THOMAS G. L-CKERD and CABBIE" L. LCKCRD, his wife, by deed doled October 28, 1988, and recorded in the once of the Cumberland County Recorder of Deeds in Deed Dook "'Q", Volume 33, Page 392. The said Thomas C. Eckerd and Cassie L. L'ekerd divorced on June 3, 1991, whereupon, subsequently Thomas F. Cckerd married Sharon A. Lckerd and Cassie L. Lekerd married Stanley L•. Richwine. Sharon A, Eckerd attd Stanley L. Tichwine join herein to convey any marital interest they ntay !rave in the premises conveyed. AND the said grantors hereby covenant and agree that they will warrant specially the property hereby conveyed. PREL+IISES ON : 1513 NEWVILLE ROAD VERIFICATION BRANDON SCIUMBATO hereby states that he is VICE PRESIDENT of COUNTRYWIDE HOME LOANS, INC. mortgage servicing agent for Plaintiff in this matter, that he is authorized to take this Verification, and that the statements made in the foregoing Civil Action in Mortgage Foreclosure are tme and correct to the best of his lmowledge, information and belief. The undersigned understands that this statement is made subject to the penalties of 18 Pa. C.S. Sec. 4904 relating to unswom falsification to authorities. DATE: 0' ~ S~ 0 I ~ ~ ~~ . ~ ~~ ~ ~ O v r ~ r',~. r^t z' _! o ~ ~~ ~ ~ ~- ~~ y __ ~ ~~ F~ 4. .f 1 T, Y ._. r.. :~ ~, c > <' _ uM ~ ;, ,.: ,..»r,W~~&~APla-'?~i~:zrta~tr. _,.;.fls~[,~#~Y~Ya'.35-.. o-pcrF AFFIDAVIT OF SERVICE PLAINTIFF COUNTRYWIDE H014IE, LOANS, INC:, F/K/A ..:COUNTRYWIDE FUNDING CORPORATION DEFENDANT (S) DAVID A. SPEICHER SERVE DAVID A. SPEICHER AT 1513 NEWVILLE ROAD CARLISLE,PA 17013 No. 01-4917 CUMBERLAND COUNTY Type of Action -Notice of Sheriff s Sale Sale Date: MARCH 6, 2002 ~~//~~ 11 SERVED Served and made known to V ay ` C ~ ~ S~ e- ` ~- ~~; Defendant, on the /G ~ day of ~ V ' , 200 I, ~ .. pp 1 .p 1 ..~:.. at 5 ' / ~ ,o'clock ~.m., at ~Jr(3 r ewv 11\~ Y~~ . Ca~,'~6\ ~ ,Commonwealth w, of Pennsylvania, in the manner described below: ~_Defendant personally served. Adult familymember with whom Defendant(s) reside(s). Relationship is Adult in chazge of Defendant(s)'s residence who refused to give name or relationship. Manager/Clerk of place of lodging in which Defendant(s) reside(s). Agent or person in charge of Defendant(s)'s office or usual place of business. an officer of said Defendant(s)'s company. Other: _ yRs ,~ _,a s Description: Age .~5 Height S~~ Weight ~b Race ll)~ Sex I=, Other 9 ~ a5 5 ~f.5 fir: , I, ~' ~a~1CcN ~Q ~ • C'a'2~ , a competent adult, being duly sworn according to law, depose and state that I personally handed a tme and correct copy of the Noti a of Sheriff's Sale in the manner as set forth herein, issued in the captioned case on the date and at the address indicated above NOTARIAL SEAL Sworn to and subscribed ANNE G. B~ YAN, Notary Publ~ before me this ~9r`da Chamltersbu Boro, Frankl' y My Cammission Expires 1 of ddtvx&.w 200 ..,„, O NOT SERVED "''""' On the day of , 200_, at o'clock - m., Defendant NOT FOUND because: "' _ Moved Unknown _ No Answer Vacant Other: Sworn to and subscribed before me this day of .200 _. Notary: By: Attorney for Plaintiff Frank Federman, Esquire - I.D. No. 12248 One Penn Center at Suburban Station 1617 Tohn F. Kennedy Boulevard, Suite 1400 Philadelphia, PA 19103-1814 (215)563-7000 ..~.. .«~. . yu . t-, ~ '=; -~ Li°s r--, ;C: -~ ~'~ -- i' ~ ~~ w I~S V'' _ _ ._ _. ~,.. - _..`JYt!° _... ..~e~m~a s~: v;,za d,~P~e~ U3amg„vW,~'fi~u. I~~ v FCr~ AFFIDAVIT OF SERVICE CUMBERLAND COUNTY PLAINTIFF COUNTRYWIDE HOME- LOANS, INC., F/K/A COUNTRYWIDE FUNDING CORPORATION No. 01-4917 DEFENDANT (S) DAVID A. SPEICHER Type of Action -Notice of Sheriff s Sale SERVE DAVID A. SPEICHER AT 1513 NEWMLLE ROAD Sale Date: MARCH 6, 2002 CARLISLE,PA 17013 ~~((~~ SERVED Served and made known to V ay ` ~ ~ ~ S~ ~` ~- ~~~; Defendant, on the /G ~ day of ~ U , , 200 1, ~ .. ~ r 1 ~p 1 ..~,._ at J` ' 10 ,o'clock ~.m., at ~s~ 3 Ne`^'v 11\e- 1^~. ~`a~~~S\'~ ,Commonwealth w, of Pennsylvania, in the manner described below: ~_Defendant personally served. Adult familymember with whom Defendant(s) reside(s). Relationship is Adult in charge of Defendant(s)'s residence who refused to give name or relationship. Manager/Clerk of place of lodging in which Defendant(s) reside(s). Agent or person in charge of Defendant(s)'s office or usual place of business. an officer of said Defendant(s)'s company. Other: Description: Age .3'~ Height S~~ Weight ~g Race ~~ Sex ~ Other ~ ~ a5 5'e5 ~R, I, ~'.~a~`-N ce G.. CaYt~, a competent adult, being duly sworn according to law, depose and state that I personally handed a true and correct copy of the Notre of Sheriff s Sale in the manner as set forth herein, issued in the captioned case on the date and at the address indicated above NiDd~F°~L SEAL Sworn to and subscribed A~9NE ~'~ ~ ~ v`:knl ~1® iasibllC before me this I9Y`'da Ghatnhers~OP GCr~, ~i'OOkO' y ley C~tnmissi®n Ex~ifns i of /L~odc~,b-~ .200 ~;• NOT SERVED "' On the day of 200_, at o'clock _ m., Defendant NOT FOUND because: ~'~' _ Moved _ Unknown _ No Answer Vacant Other: Sworn to and subscribed before me this day of , 200 _. Notary: By: Attorney for Plaintiff Frank Federman, Esquire - I.D. No. 12248 One Penn Center at Suburban Station 1617 John F. Kennedy Boulevard, Suite 1400 Philadelphia, PA 19103-1814 (215)563-7000 ,.uu.. ...a:. _~. .... FEDERMAN and PHELAN By: FRANK FEDERMAN Identification No. 12248 ONE PENN CENTER AT SUBURBAN STATION 1617 JOHN F. KENNEDY BLVD., SUITE 1400 PHILADELPHIA, PA 19103-1814 (215)563-7000 COUNTRYWIDE HOME LOANS, INC., F/K/A COUNTRYWIDE FUNDING CORPORATION v. Plaintiff, DAVH) A. SPEICHER Defendant(s). ATTORNEY FOR PLAINTIFF CUMBERLAND COUNTY COURT OF COMMON PLEAS CIVIL DIVISION • ~~.~,. NO. 01-4917 CERTIFICATION FRANK FEDERMAN, ESQUIRE, hereby verifies that he is 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 O non-owner occupied () vacant (X) Act 91 procedures have been fulfilled This certification is made subject to the penalties of 18 Pa. C.S. Section 4904 relating to unsworn falsification to authorities. F { FEDERMAN ESQUIRE Attorney for Plaintiff ~~',... ,,,4,,,. +,,,. . ~~,. ~~.~„ ~„,µ,. W u.. ~ r 4~ c ~ -~ ~;.. ;~ ZJ ~„~_; ~- -~ -=-~ , ~i ~" U - -_ _... % <~ ~ • _ ~ .~ ~~ ~ ' _ Countrywide Home Loans, Inc. f/k/a Countrywide Funding Corporation VS David A. Speicher In The Court of Common Pleas of Cumberland County, Pennsylvania Writ No. 2001-4917 Civil Term R. Thomas Kline, Sheriff, who being duly sworn according to law, states this writ is returned STAYED pursuant to instructions from Attorney Frank Federman. Sheriff s Costs Docketing 30.00 Surcharge 20.00 Posting Handbills 15.00 Law Library .50 Prothonotary 1.50 Share of Bills 24.20 Mileage 6.50 Levy 15.00 Advertising 15.00 Certified Mail Poundage 2.54 Postpone Sale Law Journal Patriot News $129.74 paid by attorney Sworn and subscribed to before me So Answers: This -~ d ~*day of ( ~~C ~~/-..P ~T R. Thomas Kline, heriff 200.x; A.D. ~ ~JBY Prothonotary R al Est to Deputy l.~ 3~3~9 (~ 7~vs'3 ~,r, COU7•TTRYWIDE_HOMELOANS,ING, F/K/A COUNTRYWl'DE FUNDING CORPORATION Plaintiff, v. DAVID A. SPEICHER Defendant(s). CUMBERLAND CO~JNTI' COURT OF COMMON PLEAS CIVIL DIVISION NO.Ol-4917 AFFIDAVIT PURSUANT TO RULE 3129 (Affidavit No. l) w:: «.: ..,+w, Plaintiff in the above action, by its attorney, FRANK FEDERMAN, 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, 1513 NEWVILLE ROAD, CARLISLE,PA 17013 . - 1. Name and address of Owner(s) or reputed Owner(s): ::~~.: NAME LAST KNOWN ADDRESS (If address cannot be °""'° . ~,.. reasonably ascertained, please so indicate.) ;; DAVID A. SPEICHER 1513 NEWVILLE ROAD CARLISLE,PA 17013 2. Name and address of Defendant(s) in the judgment: NAME LAST KNOWN ADDRESS (If address cannot be reasonably ascertained, please so indicate.) Same as above 3. Name and address of property to be sold: NAME American General Finance every judgment creditor whose judgment is a record lien on the real :; LAST KNOWN ADDRESS (If address cannot be :~~. reasonably ascertained, please so indicate.} • ~: 3120 Parkview Lane, Suite 101 Harrisburg, PA 17103 ~„ 4. Name.and addre~ o~the last recorded holder of every mortgage of record: NAME LAST KNOWN ADDRESS (If address cannot be reasonably ascertained, please so indicate.) None Name and address of every other person who has any record lien on the property: NAME LAST KNOWN 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 maybe affected by the sale: NAME LAST KNOWN ADDRESS (If address cannot be reasonably ascertained, please so indicate.) None Name and address of every other person whom the plaintiff has knowledge who has any interest in the property, which maybe affected by the sale: NAME LAST KNOWN ADDRESS (If address cannot be reasonably ascertained, please so indicate.) Tenant/Occupant 1513 NEWVILLE ROAD CARLISLE,PA 17013 Domestic Relations of 13 North Hanover Street Cumberland County Carlisle, PA 17013 Commonwealth of p0 Box 2675 Pennsylvania Department of Welfare Harrisburg, PA 17105 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. Sec. 4904 relating to unsworn falsification to authorities. October 25.2001 DATE F ~ FEDERMAN SQUIRE Attorney for Plaintiff :.;:. .:.... . ~.. _~;«. ::»~: ..~. _~... w°' . w«. ~:.;W„. ..~W- COUNTRYWIDE.HOMELQANS, INC., F/K/A Ct3UfY1'RYWIDE FUNDING CORPORATION .Plaintiff, v. DAVHa r1: SPEICHER Defendant(s). CUMBERLAND COUNTY No. 01-4917 ., • . ,w,.. . ~:... ~. . J;. ..:.: October 25, 2001 TO: DAVID A. SPEICHER 1513 NEWVILLE ROAD CARLISLE,PA 17013 **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 AND THIS DEBT WAS NOT REAFFIRMED, 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 ,1513 NEWVILLE ROAD, CARLISLE,PA 17013, is scheduled to be sold at the Sheriffs Sale on MARCH 6, 2002 at 10:00 a.m. in the Cumberland County Courthouse, South Hanover Street, Carlisle, PA 17013, to enforce the court judgment of $90,567.07obtained by • •~ COUNTRYWIDE HOME LOANS INC. F/K/A COUNTRYWIDE FUNDING CORPORATION „: (the mortgagee) against you. If the Sheriff's sale is postponed, the property will be relisted for the .~• JiJNE 5, 2002 Sheriff's Sate. "~`~ NOTICE OF OWNER'S RIGHTS YOU MAY BE ABLE TO PREVENT THIS SHERIFF'S SALE To prevent this Sheriffs Sale, you must take immediate action: The sale will be cancelled if you pay to the mortgagee the back payments, late charges, costs and reasonable attorney's fees due. To find out how much you must pay, you may call: (2151563-7000. 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 attomey.) YOU MAY STILL BE ABLE TO SAVE YOUR PROPERTY AND YOU HAVE OTHER RIGHTS EVEN IF THE SHERIFF'S SALE DOES TAKE PLACE. 1. If the Sheriffs Sale is not stopped, your property will be sold to the highest bidder. You may find out the price bid by calling (2151563-7000. 2. You maybe able to petition the Court to set aside the sale if the bid price was grossly inadequate compared to the value of your property. 3. The sale will go through only if the buyer pays the Sheriff the full amount due in the sale. To find out if this has happened; you may call (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 that time, the buyer may bring legal proceedings to evict you. 6. You maybe entitled to a share of the money which was paid for your house. A schedule of distribution of the money bid for your house will be filed by the Sheriff within 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) aze filed with the Sheriff within ten (10) days after the distribution is filed. 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 ATTORNEY REFERRAL CUMBERLAND COUNTY BAR ASSOCIATION 2 LIBERTY AVENUE CUMBERLAND COUNTY COURTHOUSE CARLISLE, PA 17013 (717) 249-3166 (800)990-9108 ~,. t»:~ ' ..,~. -,.•^~+- x795 T.L,i. RSi.~IT t~AII4LN er act of lan4 with the imptovamentc eiier¢on erected cicwta in wear Fennsboro ~rnsfiip, on the North aide of ?ennaylzania Highway Route No. 6q1, Cumberland cbunty, Pennsylvania, bound=d and dssczib?d in aecordanes with a auri-ey made Dy T. A. NeFE, Registered Surveyor, on June 22, •965. a QraPt oP said sur.,ey beirsg attached thereto and incorporated therein by reEerenee, as follows: DL°GINNING at a point in the cenczr Line of said 2ennaylvania Peuca No. 641 at thQ Southwestern corner of land nov or formerly of Harold Varner: ~.~hich point o£ beginning La 300 PQQt ..QCt oP the cnnear lira oP '*cwnnhip Poad Ne. 706 mcaaurad along the center line of Pennsylvania Route No. 641; thence from said point at thQ place of beginning along the center Lirw_ of said Pennsylvania Peut¢ No. 6ai, South 77 degrcee 30 minute. We :t, o dietanee o= 100 :eat to a ?Dint at the SO~.;t1'wactarn corner eF lid nov er formerly o~ C'aozge Sn. a'_lwocd} tkpnc+s ,along the eastern line of land nov or formerly of Georoe Smallwood, North 12 degrees 30 minutes sit, a dz9tanee of l60 feet to an iron pipe in line o£ land now or Focmezly of Qlazles M. aoiiliams, 5c.; thence along said Tana rx;w ar [ormariy o[ Charlca M. willies, Sr.. North 77 dcgrcca 30 minute East. a distance of 100 ev4t fro a yu~rtat ineF+ drit,l hots in cock wt the WottlT.+msesrn eocnsr of land now or formerly of aarold Varner; chance along the 9Pe¢tecn line oi' land now Oc Ferm.rly o£ Iiareld L•arrwr, South 12 de<jraae 30 minutes ,,;set, n di.;tane? of 160 Feat w a Doinc in the canter lira oP Psnnaytvania mute 641. the Place of SDGINt+1INC3- BSSNG all of Lot No. 4 as stxr+n on Plan or Lots og Gtiarles M. willi~m.!. Sr., raaerd.d in the OE£iw of the Idseorder of Dsads in and £er C~m~berland County, Pennsylvania, in PZan Hook 4. Fage 12. GAINING 100 feet in Front along the cent¢z line of Pennsylvania Route No. 641 and extendirx3 northwardly therefrom a c7ixtaanc= oC 260 f?st. WINING thereon mrected a tvo story e'_uminum sidirx7 covered duelling haearo and other i~covomnnts. sSID7G t1ap aalm pt?wises~ uFaieh Craig a_ :f+amas and Phy/li~ R. 'EhC11475, his rife, by Indenture dated xtober 29, 1988 and recorded ac t:arlisla fn the county o£ Gaaberlerr] on Oete6er 28, 1968 in Lead Hook Q-33, ~_age 392, granted and oonveyad unto ~hamaa L. Lekerd and cassia L. i~ekerd, his wiFe, in fee. WRIT OF EXECUTION and/or ATTACHMENT COMMONWEALTH OF PENNSYLVANIA) COUNTY OF CUMBERLAND) NO. D1-4917 CIVIL ~ 'I'E~ CIVIL ACTION -LAW TO THE SHERIFF OF Cumberland COUNTY: To satisfy the debt, interest and costs due rnnntrvwide Hcme Loans, Inc. , F/K/A Countwide _ Ftutdinq Corporation ~ PLAINTIFF(S) from David A. Speicher, 1513 Newville Road, Carlisle, PA 17013 DANT(S) (1) You are directed to levy upon the properly of the defendant(s) and to sell~ee~g~ nPCnr;ct;on (2) You are also directed to attach the property of the defendant(s) not levied upon in the possession of GARNISHEE(S) as foibws: and to notify the garnishee(s) that: (a) an attachment has been issued; (b)ihe garnishee(s) isiare enjoined from paying any debt to or for the account of the defendant(s) ahd from delivering any property of the defendant(s) or otherwise disposing thereof; (3) Iipropertyofthedefendant(s)rgtlevleduponansubjecttoattaohmentisfoundinthepossessionofanyoneother than a namedgamishee, you are directedtonotify hinvherthat he/she has been addedas a garnishee andis enjoined as above stated. Amount Due 588,643.83 L.L. $.50 from 10/25JO1 to 3/6/02 (per disn Interest $~4~7) ~ Q23 24-and-Casts Due Prothy $1 .n0 Atty's Comm °l Other Costs AttyPaid ~j,03,25 _ Plaintiff Paid Date: October 302001 ___~ REQUESTING PARTY: Name Frank Federntan, Esq. Curtis R. Long (n/ ~ Prothonotary~CivilJDivision Deputy Address: One Penn Center at Suburban Station Suite 1400 _~hiladelnhia~~L 19103-1814 Attorneyioc pta;nt;ff Telephone: X15-Sh'2-7000 Supreme Court ID No. 7~~~ C~P~ ~~~~ €~~~~~'~ in T~s~ir~of~y~ u~lt~~sol, i s`;avr~ unto se'~ rt3y It~nt7 ar~1 fine s~~i of siii Uo~i; ai Carilsl~, i~a. Thi~tday of , Pro tpnntary REAL ESTATE SALE No. ~a On November O1, 2001, the sheriff levied upon the defendant's interest in the real property situated in West Pennsboro Township, Cumberland County, PA, known and numbered as 1513 Newville Road, Carlisle, and more fully described on Exhibit "A" filed with this writ and by this reference incorporated herein. Date: November O1, 2001 By: ~oa~Sv Real state eputy _, ~'; I"-~ n:~ ~~ it ~J ..p F.3 ! i iti ~nNn.L:P~. ~ '~ :i O s+ . I ~JR~S a:~5[..~...:w r ~ s ~~< r_ .51w~ b' ~ .- r Y ~ ~~8~" i~x~p ~. , COUNTRYWIDE HOME LOANS, INC., F/K/A COUNTRY FUI~TDING CORPORATION Plaintiff, v. DAVID A:: SPEICHER Defendant(s). CUMBERLAND COUNTY - No.O1-4917 .. . .... ..i:.. ' ..::.. . *::. October 25, 2001 TO: DAVID A. SPEICHER 1513 NEWVILLE ROAD CARLISLE,PA 17013 '"*xHIS 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 AND THIS DEBT WAS NOT REAFFIRMED, THIS IS NOT AND SHOULD NOT BE CONSTRUED TO BEAN ATTEMPT TO COLLECT A DEBT, BUT ONLY ENFORCEMENT OF A LIEN AGAINST PROPERTY.** Your house (real estate) at ,1513 NEWVILLE ROAD, CARLISLE,PA 17013, is scheduled to be sold at the Sheriffs Sale on MARCH 6, 2002 at 10:00 a.m. in the Cumberland County Courthouse, South Hanover Street, Carlisle, PA 17013, to enforce the court judgment of $90,567.07obtained by ~-~ ~.. COUNTRYWH)E HOME LOANS INC. F/K/A COUNTRYWIDE FUNDING CORPORATION .~~i (the mortgagee) against you. If the Sheriff s sale is postponed, the property will be relisted for the "»-~ JUNE S, 2002 Sheriffs Sale. "~~ NOTICE OF OWNER'S RIGHTS YOU MAY BE ABLE TO PREVENT THIS SHERIFF'S SALE To prevent this Sheriffs Sale, you must take immediate action: 1. The sale will be cancelled if you pay to the mortgagee the back payments, late chazges, costs and reasonable attorney's fees due. To find out how much you must pay, you may call: (2151563-7000. 2. You maybe 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. "°' .fi ~ You may need. an attorney ao. 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.) 1. If the Sheriffs Sale is not stopped, your property will be sold to the highest bidder. You may find out the price bid by calling (215) 563-7000. 2. You maybe able to petition the Court to set aside the sale if the bid price was grossly inadequate compazed 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 (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 that time, the buyer may bring legal proceedings to evict you. 6. You maybe entitled to a shaze of the money which was paid for your house. A schedule of distribution of the money bid for your house will be filed by the Sheriff within 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) aze filed with the Sheriff within ten (10) days after the distribution is filed. 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 CANNUT AFFORD ONE, GO TO OR TELEPHONE THE OFFICE LISTED BELOW TO FIND OUT WHERE YOU CAN GET LEGAL HELP.- CUMBERLAND COUNTY ATTORNEY REFERRAL CUMBERLAND COUNTY BAR ASSOCIATION 2 LIBERTY AVENUE CUMBERLAND COUNTY COURTHOUSE CARLISLE, PA 17013 (717) 249-3166 (800) 990-9108 ~::: w... ',w.` :::~ :.~;:: ..a;. ::~: ..~;. ,, <, _. ~ _..._ ~~ s7ss ALL TRAT CSRTASN tract of land with the w~eat Pennsboro Taumship, on the `bttb 641. CumCerland County, Penrsayivania, auri-ey .voile tq+ T. A. Vert, Registered said survey being attaetied thereto arv follows: i{gprO'lCmCrtLL' t1]CrOOn QLCCCCd s:i L:3atC in aide o£ Pennayl~ania Hi9b.+ay iZoute No. bound=d and d?sczib?d in accordance with a Surveyor, on .n:ne 22, 1965, a draft or 3 incorporated therein by re£erenee, as IISGTNNING,at a point in the cencez line of said Pennsylvania stouce Np. 64i at thQ 9outhWestern corner o£ land nov or £ormeciy of Harold Varner; wt+ich point o£ beginning ire 300 fQ¢t Fleet oP the canter ii:ux oP ^bwn~hip Road No. 706 mca.urad along the center lint of Pennsylvania Foute No. 641; thence from said point at the plate of beginning alcng the tent=r line of said Pennsylvania Imute tb. 641, Soutn 77 degrees 30 minutes F7e~t, a dieta:+ce o_' 100 ~eet to a Poirtt at the Sputl+martern corrfar o£ lard nv., or £armarly o£ G'corga Suis'_lwood; thonee ,along the eastern line of land nov or formerly of GeorOe StnalisiooC, North 12 degreee 30 a~inute3 fit, a di9tance o£ 160 £eet to an iron pipe in tine o£ land never oc focmeriy of Charles M. w111fama. Sr.; thence along said latro0 tx~w or Porvwrly of Chsrlco M. willia+n~, Sr.. North 77 dcgreea 30 minutca East, a di3tance of 100 t~qC te7 a quarrpc inch dri7,1 hpla in cock wt the Ntsrcho.?r tern eoetz<tr of 2.and now or formerly of Flarold earner; thence along the aPesLern line or land nos or £orm.rly o£ iia.ro].d L•arrmr, South 12 d~ro>R 30 mi nutwc :usL, a dirtanco of 260 fe•L ro a pvinC in the canter lira of Pennsylvania Route 6?l. the 81ace or SDGINt~iIN6_ HSING all o! Iqt NU- 4 qe °.iX)wn on Plan or Lots or C:+arlea M. Willi am.;. Sr-. raoordwd in the O£Eida e£ the Reeerder e£ Deeds in and £er Cumteeriand County, Rennsylvania! in Plan Book ~, Yag¢ 12. CON'iAINING 100 feet in fronC along the eerat¢r line of Pennuylvania Poute No. 641 and extendirx,7 northWardly therefrom a viRtanc4 of 160 £°at. HAVING tkereon erected a two vtosy a:sni num sidicx~ ~oavred dvQlling hwrw and OthoZ improvom¢nts. 8S2DiG th? rata? Pr~tirer which Craig n. :i,gvar qnd Phyllis R. 1SiottlFis, his vif?, by sndoncurtt dac®d October 28, 1488 and rgeorded ac Carlisle in the County of Ctanberlet+d en t~tober 2fl, 1988 in Deed Hook Q-33, page 392, granted and eonveynd unto ahovtas E. Sckerd and Casale L. rbkerd, his wife, in fee. C? L~ ~~, i_a r t ~{jj, y.._ (R q ~ __-r r. , Z ~.• .a.._ K C-3 . ~. ` ' 1~. ~ ` ~~ _ , %~ ~ Oi r ~_ ~ ~ ~+5 ~~ _ ~ n: ~~~ .. .. . _ _. _~fis_a•Te,.., . ~ . ~ . as. -x{ . RWYN~ti..;,_ }3+ , ~o~s'fiY+ xeFaazW*~M1~=,