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HomeMy WebLinkAbout01-06071 ~'" .O\l'!'l'~.," " FEDERMAN AND PHELAN, LLP By: FRANK FEDERMAN, ESQUIRE IDENTIFICATION NO. 12248 ONE PENN CENTER AT SUBURBAN STATION 1617 JOHNF. KENNEDY BOULEVARD SUITE 1400 PHILADELPHIA, PA 19103-1814 (215) 563-7000 COUNTRYWIDE HOME LOANS, INC. 7105 CORPORATE DRIVE PLANO, TX 75024 ATTORNEY FOR PLAINTIFF COURT OF COMMON PLEAS CIVIL DIVISION TERM Plaintiff Ci()'ll't~ v. NO. DI - (pO"!1 CUMBERLAND COUNTY LINDA S. MATEER JESSICA L. MANSBERGER 223 RENO STREET NEW CUMBERLAND, P A 17070 Defendant( s) CIVIL ACTION - LAW COMPLAINT IN MORTGAGE FORECLOSURE NOTICE **THlS 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 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 may be entered against you by the court without further notice for any money claimed in the Complaint or for any other claim or relief requested by the Plaintiff. You may lose money or property or other rights important to you. YOU SHOULD TAKE THIS PAPER TO YOUR LAWYER AT ONCE. IF YOU DO NOT HAVE A LAWYER OR CANNOT AFFORD ONE, GO TO OR TELEPHONE THE OFFICE SET FORTH BELOW TO FIND OUT WHERE YOU CAN GET LEGAL HELP. CUMBERLAND COUNTY CUMBERLAND COUNTY BAR ASSOCIATION 2 LIBERTY A VBNUE CARLISLE, P A 17013 (717) 249-3166 Loan #: 9909949 "", " ,~ _ r ~''', 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. THE 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 THIS 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. ,""~- I c "~" ~ <0 '",",,"" I. Plaintiff is COUNTRYWIDE HOME LOANS, INC. 7105 CORPORATE DRIVE, PLANO, TX 75024 2. The name(s) and last known address (es) of the Defendant(s) are: LINDA S. MATEER JESSICA L. MANSBERGER 223 RENO STREET NEW CUMBERLAND, P A 17070 who is/are the mortgagor(s) and real owner(s) of the property hereinafter described. 3. On 2/22/01 mortgagor( s) made, executed and delivered a mortgage upon the premises hereinafter described to PLAINTIFF which mortgage is recorded in the Office of the Recorder of CUMBERLAND County, in Mortgage Book No. 1675, Page 850. 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 6/1101 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 are collectible forthwith. A copy of such notice is attached as Exhibit "A." ''-'''''"~, " - ~;.0~".~~' w 6. The following amounts are due on the mortgage: Principal Balance Interest 5/1/01 through 9/1/01 (per Diem $14.11) Attorney's Fees Cumulative Late Charges 2/22/01 to 9/1/01 Cost of Suit and Title Search Subtotal $61,573.24 1,749.64 3,078.00 69045 550.00 $67,020.33 Escrow Credit Deficit Subtotal TOTAL 300.00 0.00 ($ 300.00) $66,720.33 7. The attorney's fees set forth above are in conformity with the Mortgage documents and Pennsylvania Law, and will be collected in the event of a third party purchaser at Sheriff's Sale. If the Mortgage is reinstated prior to the Sale, reasonable attorney's fees will be charged. 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. S 16800403c 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 terminated 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 $66,720.33, together with interest from 9/1/01 at the rate of$14.11 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. }vL.L1W~ Isl Frank Federman FRANK FEDERMAN, ESQUIRE Attorney for Plaintiff '~'1".'_ r .'.- " 1 "", ..- ;~. , , . Countrywide" HOME LOANS Send Correspondence to: P.D. Box 10221 Van Nuys, CA 91410-0221 SEP 2 6 20111 ,July 31,2001 Send Payments to: P.O. Box 660694 Dallas, TX 75266-0694 Certified Mail No. Return Receipt Requested Regular Mail Jessica L Mansberger 223 Reno Street New Cumberland, PA 17070-0000 Account No.: 9909949 Property Address: 223 Reno Street New Cumberland, PA 17070-0000 Current Servicer: Countrywide Home Loans Servicing LP ACT 91 NOTICE TAKE ACTION TO SAVE YOUR HOME FROM FORECLOSURE This is an official notice that the mortnane on your home Is in default. and the lender intends to foreclose. Soeclfic information about the nature of the default Is Droyided In the attached Daaes. The HOMEOWNER'S EMERGENCY MORTGAGE ASSISTANCE PROGRAM CHEMAPl may be able to helD to save your home. This Notice eXDlains how the Droaram works. To see if HEMAP can helD. vou must MEET WITH A CONSUMER ,CREDIT COUNSELING AGENCY WITHIN 30 DAYS OF THE DATE OF THIS NOTICE. Take this Notice with yOU when vou meet with the Counselina Aaencv. The names. addresses and Dhone numbers of Consumer Credit Counsellna Aaencles servlna vour County are listed at the end of this Notice. If vou have any auestIons. YOU may call the Pennsvlvanla HousinG Finance ADencv toll-free At 1..aoo-342-2397. {Persons with ImDalred hearlna can call1-717-78o-1869.l This Notice contains Important legallnfonnatlon. If you have any questions, representatives at the Consumer Credit Counseling Agency may be able to help answer them. You may also want to contact an attorney jn your area. The local bar association may be able to help you find a lawyer. LA NOr.FICACION EN ADJUNro ES DE SUMA IMPORrANCIA, PUES AFEcrA SU DERECHO A CONTINUAR VIVIENDO EN SU CASA. 51 NO COMPRENDE EL CONTENIDO DE EsrA NOTIFICACION OBTENGA UNA TRADUCC'ON INMEDIATAMENTE LLAMANDO EsrA AGENCIA (PENNSYLVANIA HOUS!NG FINANCE AGENCY) SIN CARGOS AL NUMERO MENCIONADO ARRIBA. PUEDE SER ELEGIBLE PARA UN PREsrAMO POR EL PROGRAMA LLAMADO "HOMEOWNER'S EMERGENCY MORTGAGE ASSISTANCE PROGRAM"' EL CUAL PUEDE SALVAR SU CASA DE LA PERDIDA DEL OERECHO A REDIMIR SU HIPOTECA. HOMEOWNER'S EMERGENCY MORTGAGE ASSISTANCE PROGRAM YOU MAY BE ELIGIBLE FOR FINANCIAL ASSISrANCE WHICH CAN SAVE YOUR HOME FROM FORECLOSURE AND HELP VOU MAKE FUTURE MORrGAGE PAYMENTS. IF YOU COMPLY WITH rHE 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 CO!IITROL, 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 write your account number on all checks and correspondence BREACHPA 6/26/2000 9909949-1 JessicaLMansberger 223 Reno Street Alooupto!25.001!4000;-,FLI"MiIbocOOryodlor_h..ltlmodpajlll",t.-..;opl",olhorvt\$Ohmrtodbybw BREACHPA $1,123.46 AS OF September 4, 2001 i2iI "de n1Counbyvvi' HOME LOANS P.O. Box 660694 Dallas, TX 75266-0694 1I".I,IIIIIII,I.lll11l1nll'Il,IlIlIIIIl,llIlIlllIIllIllllllI 990994910001123460112346 EXHIBIT A '.'~";""'m",W'J!:il!' , .,,~ r ~_ ~~ ~~ . , '''~'''''''''!'''I~101 1 ~ ,~ III Countrywide" HOME LOANS Send Correspondence to: P Q. Box 10221 Van Nuys, CA 91410-0221 Send Payments to: P.O. Box 660694 Dallas, TX 75266-0694 Certified Mail No. Return Receipt Requested Regular Mail JUly 31, 2001 Linda S Mateer 223 Reno Street New Cumberland, PA 17070-0000 Account No.: 9909949 Property Address: 223 Reno Street New Cumberland, PA 17070-0000 eurrent Servtcer. Countrywide Home Loans Servicing LP ACT 91 NOTICE TAKE ACTION TO SAVE YOUR HOME FROM FORECLOSURE This is an official notice that the mortaaae on vour home is in default. and the lender Intends to foreclose. Soecific Information about the nature of the default Is DroYided in the attached Daoes. The HOMEOWNER'S EMERGENCY MORTGAGE ASSISTANCE PROGRAM (HEMAPl may be able to helD to save your home. This NoticE! exolains how the Droaram works. To see if HEMAP can helD. YOU must MEET WITH A CONSUMER CREDIT COUNSELING AGENCY WITHIN 30 DAYS OFTHE DATE OF THIS NOTICE. Take this Notice with YOU when vou meet with the Counselina Aaencv. The names. addresses and ohone numbers of Consumer Credit Counselina Aaencles servina your County are listed at the end of this Notice. "YOU have any auestions. you may call the Pennsvlvania Housina Finance Aaencytoll~free at 1..s0Q.342-2397. (Persons with imoaired hearln!] can call1-717~78o-1869.l This Notice contains important legal Information. If you have any questions, representatives at the Consumer Credit Counseling Agency may be 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 a lawyer. LA NOTIFICACION EN ADJUNTO ES DE SUMA IMPORTANCIA, PUES AFECrA SU DERECHO A CONTINUAR VIVIENnO EN SU CASA. SI NO COMPRENOE EL CONTENIDO DE ESrA NOTIFICACION OBTENGA UNA TRADUCCION INMEDIATAMENTE LLAMANDO ESTA AGENCIA (PENNSYLVANIA HOUSING FINANCE AGENCY) SIN CARGOS AL NUMERO MENCIONADO ARRIBA. 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 REDlMIR 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 FurURE MORTGAGE PAYMENrS. IF YOU COMPLY WITH THE PROVISIONS OF THE HOMEOWNER'S EMERGENCY MORTGAGE ASSlsrANCE ACT OF 1983 (THE "ACT"), YOU MAY BE ELIGIBLE FOR EMERGENCY MORTGAGE ASSISTANCE: IF YOUR DEFAULT HAS BEEN CAUSED BY CIRCUMSrANCES BEYOND YOUR CONTROL, IF YOU HAVE A REASONABLE PROSPECT OF BEING ABLE TO PAY YOUR MORTGAGE PAYMENTS, AND IF YOU MEET OTHER ELIGIBILITY REQUIREMENTS ESTABLISHED BY THE PENNSYLVANIA HOUSING FINANCE AGENCY. Please write your account number on all checks and correspondence. BREACHPA 6/26/2000 9909949-1 LrndaSMaleer 223 AenoStreel AI"'4'loS25.00($40.00inFL)willbeoil...godl....."ilrolurrlElOpoym""I",oplll:'lolh"''''SOlltTl'lodbyI"" BREACHPA $1,123.46 AS OF September 4, 2001 IIIcountryvvide- HOME LOANS P.O. Box 660694 Dallas, TX 75266-0694 11.,,1,1.11111.1.11...11..11111111111111111'111.111,1111111111 EXHIBlTA 990994910001123460112346 "'~ '.1, 1 ~ TEMPORARY 5T AY OF FORECLOSURE - Under the Act, you are entitled to a temporary stay of foreclosure on your mortgage for thirty-five (35) days from the date of this Notice. During that time you must arrange and attend a "face-to- tace" meeting with one of the consumer credit counseling agencies listed at the end of this Notice. THIS MEETING MUST OCCUR WITHIN THE NEXT (35\ DAYS. IF YOU DO NOT APPLY FOR EMERGENCY MORTGAGE ASSISTANCE YOU MUST BRING YOUR MORTGAGE UP TO DATE. THE PART OF THIS NOTICE CALLEO "HOW TO CURE YOI'R MORTGAGE DEFAUL TO> EXPLAINS HOW TO BRING YOUR MORTGAGE UP TO DATE. CONSUMER CREDIT COUNSELING AGENCIES - If you meet with one of the consumer credit counseling agencies listed at the end of this notice, the lender may NOT take action against you for thirty-five (35) days after the date of this meeting. THe names addresses and teleohone numbers of desianated consumer credit counselina aoencies fOL.!.!:le countv in whiCh the oroDertv is located are set forth at the end of this Notice. It is only necessary to schedule one face- to-face meeting. Advise your tender immediatelv of your intentions. APPLICATION FOR MORTGAGE ASSISTANCE - Your mortgage is in default for the reasons set forth later in this Notice (see fOllowing pages for specific information about the nature of your default.) If you have tried and are unable to resolve this problem with the lender, you have the right to apply for financial assistance from the Homeowner's Emergency Mortgage Assistance Program. To do so, you must fill out, sign and file a completed Homeowner's Emergency A$sistance Program Application with one of the designated consumer credit counseling agencies listed at the end of this Notice. Only consumer credit counseling agencies have applications for the program and they will assist you in submittIng a complete application to the Pennsylvania Housing Finance Agency. Your application MUST be filed or postmarked within thirty~five (35) days of your face~to-face meeting. YOU MUsr FILE YOUR APPLlCArlON 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 'MMEDIATELY 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 tile Agency uMer the eligibility criteria established by the Act. The Pennsylvania Housing Finance Agency has sixty (60) days to make a decision after it receives your application. During that time, no foreclosure proceedings will be pursued against you if you have met the time requirements set forth above. You will be notified directly by the Pennsylvania Housing Finance Agency of its decision on your application. NOTE: IF YOU ARE CURRENTLY PROTECTED BY THE FILING OF A PETITION IN BANKRUprCY, THE FOLLOWING PART OF rHIS NOTICE IS FOR INFORMATION PURPOSES ONLV AND SHOULD NOT BE CONSIDERED AS AN ATTEMPT TO COLLECT THE DEBT. (If you have filed bankruptcy you can stili 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 - Countrvwlde Home Loans Servlclna LP. (hereinafter "Countrvwide") services your home loan. Your home loan is in serious default because you have not made your required payments. The total amount now required to reinstate your home loan as of the date of this letter is as follows: !V1Q.1l!h!Y PaVffil'lnts: $538.57 Late Charoes: $23.16 O!!J~~haraes: Uncollected Late Charges: Uncollected Costs: $1,077.14 $46.32 TOTAL DUE: $1,123.46 PAYMENT INSTRUCllONS Please . Make your check payable 10 Countrywide Home Loans . Wnte your loan number on YlJurcheck or money order Write in any additionalamoul1tsyou are including. (11 !otal is mon, than $5000, pleiJ.se sendcertllled check.) . Don'!attachyourchecktolhepaymentcoupon Don'tincluclecorrespondence . Don't send cash Payments: All payments will bE) applied to the longest outstanding installment due, unless otherwise expressly prohib~ed by law. Addltlonat amounts.. !t you dOI1't specify the purpose ot adcUtlonal amounts included, we will apply them llrstlo any outstanding payments: escrow deflclencle~ late cnarges,andlor lees due. We will then apply any remaining amounts as a prinCipal reduclilln. It you sub.~11 an add~lonal prinCipal payment with your home 10aR payment, Countrywide will first apply your home loan payment, then the add~lonal ponclpal paymenl Your loan must be current beJore we can apply any principal reduclilln EXHIBIT A "-"""","!\jI_l'I!!T 1_ .__ ". , l~-;' ~ - - "C"fT" ~_ ....." ,''''-, HOW TO CURE THE OEFAULT - You may cure this default within THIRTY-FIVE (35) DAYS of the date of this letter. by paying to us the above amount of $1,123.46, plus any additional monthly payments, late charges, fees and other applicable charges which may fall due during this period. Such payment must be in the form of certified check, cashier's check or money order, and made payable to COuntrywide at P.O. Box 660694, Dallas, TX 75266.0694. If your check or other payment is returned to us for insufficient funds or for any other reason, you witt not have cured your default. No extension of time to cure will be granted due to a returned 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 original amount borrowed will be considered due immediately and you may lose the chance to payoff your home loan in monthly installments. If the full payment of the amount in default is not made within THIRTY.FIVE (35) OAYS, we also intend to immediately start a lawsuit to foreclose on your mortgaged property. IF THE MORTGAGE IS FORECLOSED UPON - If the mortgage is foreClosed, the mortgaged property will be sold by the Sheriff to payoff the mortgage debt. If the default is cured before we begin legal proceedings, Countrywide will be entilled to collect the reasonable attorney's fees actually incurred, up to $50.00. However, if legal proceedings are started, Countrywide will be entitled to collect the reasonable attorney's fees even if they are over $50.00. Any attorney's fees will be added to the secured debt, which may also Include our reasonable cos1s. If you cure 1he default within the THIRTY-FIVE (35) DAY period, you will not be required to pay attorney's fees. YOU HAVE THE RIGHT TO REINSTATE AFTER ACCELERATION AND RIGHr TO ASSERT IN THE FORECLOSURE PROCEEDING THE NON- EXISTENCE OF A DEFAULT OR ANY OTHER DEFENSE YOU MAY HAVE 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 period and foreclosure proceedings have begun, you still have the right to cure the default and prevent the sale at any time up to one hour before the foreclosure sale. You may do so by paying the total amount then past due, plus any late or other charges then due. reasonable attorney's fees and costs connected with the foreclosure sale and any other costs connected with the foreclosure sale as specified in writing by the lender and by performing any other requirements under the mortgage. Curing your default In the manner set forth in this notice will restore your mortgage to the same position as if you had never defaulted. EARLIEST POSSIBLE.FOI=CECLOSURE SALE DATE - It is estimated that the earliest date that a foreclosure sale could be held would be approximately six (6) months from the date of this letter. A notice of the date of the foreclosure sale will be sent to you before the sale. You may find out at any time exactly what the required payment will be by calling us at the following number: 1-800-669-6654. This payment must be in the form of a cashier's check, certified check or money order and made payable to us at the address stated above. If the default is 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) times in any calendar year. HOW TO CONTACr THE LENDER: Name of Lender; Countrywide Home Loans Servicing LP Address: P. O. Box 10221 Van Nuys, CA 91410-0221 Phone Number: 1-800-669-6654 Fax Number: 1.805-577-3432 Contact Person: Melanie Carrillo, MS SV.34 Attention: Loan Counselor EFFECT OF FORECLOSURE SALE - You should realize that a foreclosure sate witt end your ownership of tile mortgaged property 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 furllishings and other belongings could be started by Countrywide at any time. ASSUMPTION OF MORTGAGE - Contact Countrywide Home Loans for information on the possible assumabilit~ 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 OCCUR REO, IF YOU CURE THE OEFAULT, (HOWEVER, YOU DO NOT HAVE THIS RIGHT TO CURE YOUR DEFAULT MORE THAN THREE TIMES IN ANY CALENDAR YEAR.) TO ASSERT THE NONEXISTENCE OF A DEFAULT IN ANY FORECLOSURE PROCEEDING OR ANY DTHER 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 hom~ loan ~ocuments, and because the home loan is in default, Countrywide may, at ils option. enter upon and conduct an inspection of the property. The purpose of this inspection is to observe the physical condition of the pr.operty,. to v~rify 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 loan documents. EXHIBIT A I~ \-T' ,< "'"'"',"V.~""" ,.,. " -,-'~ - If you are unable to cure your default on or before September 4, 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 J,2 of the amount necessary to bring the account current, and that the balance of the overdue amount be paid, along with the regular monthlY payment, over a defined period of time. Other repayment plans also are available. Loan Modification: Alternatively, it is possible that the regular monthly payments can be lowered through a modification 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 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 approved through Countrywide 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 if the default is due to a serious financial hardship which is beyond your control, 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 pursue 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 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 countrywide's office immediately at 1-800-669-6654, extension 7556. 1Jtet4<<ie ~ Melanie Carrillo Loan Counselor 1-800-669-6654. extension 7556 Please be advised that this communication is from a debt collector. EXHIBIT A , ,~ , . . PENNSYLVANIA HOUSING FINANCE AGE:'iCY HOMEOWNER'S EMERGENCY ASSISTANCE PROGRAM CONSUMER CREDIT COUNSELING AGE:'iCIES (REV. 8/00) CLINTON COUNTY eees ofNonheastem PA 1631 South Atherton St., Suite 100 State College, PA 16801 (81-1) 238-3668 FAX (81-1) 238-3669 Lycoming~Clinton Counties Commision for Community Action (STEP) 2138 Lincoln Street P.O. Box 1328 Williamspon, PA 17703 (570) 326-0587 F~'{ (570) 322-2197 eees of Northeast em PA 20 I Basin Street WiJliamspon, PA 17703 (570) 323-6627 F~'{ (570) 323-6626 COLUMBIA COL':'l"TY 1400 Abington Executive Park Suite I Clarks Summit PA 18411 (570) 587-9163 or (800) 922-9537 Fl,X (570) 587-913-1-9135 31 W. Market Street POB 1127 Wilkes-Barre. PA 18702 (570) 821-0837 or (800) 922-9537 FAX (570) 821-1785 Commission on Economics Opportunity of Luzemt: County 163 Amber Lane Wilkes-Barre. PA 18702 (570) 826-0510 or (800) 822-0359 FAX (570) 829-1 665-(Call Before Faxing) (570) 455-4994 Hazeltown FAX (570) 455-5631-(Call Before Faxing) (570) 836-4090 Tunkhannock CRAWFORD COL"NTY Greater Erie Community ACtion Comminee 18West9tbStreet Erie, PA 16501 (81-1) 459-4581 F~X (814) 456-0161 Booker T. Washington Center 1720 Holland Center Eric, PA 16503 (814) 453-5744 F~,{ (814) 5749 John r. Kennedy Center, Inc. 2021 East 20th Street Erie, PA 16j10 (81-1) 898-0400 F~'{ (814) 898-12-13 Shenango Valley Urban League, Inc. 60 lindiana Avenue Farrell, PA 16121 (412) 981-53JD CCCS of West em Pennsylvania, Inc. 2000 Linglestown Road Harrisburg, P A 17102 (717) 54l-1757 CUMBERLAND COUNTY Financial Counseling Services of Franklin 31 West3'dStreet Waynesboro, PA 17268 (717) 762-3285 Urban League of Metropolitan Harrisburg N. 6lh Street Harrisburg, PA 17101 (71 7) 23-1-5925 FAX (717) 234-9459 yV{CA of Carlisle 301 "0" Street Carlisle. PA 17013 . (717) 243-3818 FAA (717)-731-9589 Community Action Comm afthe Capital Region 15 J 4 Derry Srreet Harrisburg, PA 17104 (717) 232-9757 FAX (717) 234-2227 Adams Counry Housing Authority l39-143 Carlisle St. Genysburg, PA 17325 (717) 334-1518 FAA 334-8326 PENNSYL V Al~L\ BULLETIN, VOL. 29, ~O. 23. JL'NE 5, 1999 EXHIBIT A ;oc"" .. T ,F,GA T, OF,SrRTPTION All that certain lot or piece of ground with the buildings and improvements thereon erected, being known as 223 Reno Street, New Cumberland Borough, Cumberland county, and being further described on that certain Deed dated 2/22/01 and recorded 3/1101 in the Office of the Recorder of Deeds in CUMBERLAND County in Deed Book No.240, Page 303. Parcel No. 25-25-0006-256 BEING known as: 223 RENO STREET NEW CUMBERLAND, PA 17070 ;~"'\''*1'l<<l,",",. , ._, ~,~, , " , I, ~, '! ,-~ " "~-~ ~ ,-...I f" , VBRIFICATION 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 Foreclosur~ are true and correct to the best of his knowledge, information and belief. The undersigned understands that this statement is made subject to the penalties of 18 Pa. C.s. Sec. 4904 relating to unsworn falsification to authorities. DATE: 10/;10/ I " ;'-c~~";"j""~l!I"'I'~, ~~, r~ ~ ""''''~""", - -,-,- - ~ j.~ ........ ~ ~ "'" "~dT"F'T~T"fl"il!l' 11 ,Ull rH. '''~'~'f~ ...... ~ ..... t'..J ~ '4\. 1:: ~p g v-, ,D.- r;tJ~ ~~ J- () 0 n c .1 ~' C) ~~j n -;-, -l f':;; 8 Z'f"-- e0 " c~ ~j; , ... ~~~A ~~ <1...-' sE Pr-) (.5 ;? 60 .-;r~ ) Pc: ;~m Z N ~ :::2 """ ::0 -< ~ ~ ~ ",~~".. ,~ ~ -"'mJ~',~,,~l':j' "~"""l!l,,,,,,,,,,,,,. ';_ ~J l [~~~~~~ijfllN~~'$F4'\l'l'l"l!t'I'1P""--'~"i):''''I1''.;P1''<"'','''-'-' .,,0'11._ --. '";'''"-!'T;'-&If'?,'t'''~j-';'W'':W';l!!lIi\1W'''0J8'Y~':i'.fWV')'_W'1f;iPf~!i1~~;, it' ... , FEDERMAN AND PHELAN By: Frank Federman, Esquire Atty. J.D. No_: 12248 One Penn Center at Suburban Station Suite 1400 Philadelphia, P A 19103-1814 (215) 563-7000 Attorney for Plaintiff COUNTRYWIDE HOME LOANS, INC. Plaintiff Court of Common Pleas CUMBERLAND County No. 01-6071 CIVIL vs. LINDA S. MATEER JESSICA 1. MANSBERGER Defendant(s) PRAECIPE TO SUBSTITUTE LEGAL DESCRIPTION TO THE PROTHONOTARY: Kindly substitute the attached legal description for the legal description originally filed with the complaint in the instant matter. Date ,ii -? j /)) . I ~~ q-.Jt,_ Frank Federman Attorney for Plaintiff ,;)'-""'~'1!'\~",. , . ,__,.,- _ ~ .,.".~. "1 I", "~ I .- , , << Property Address: 223 Reno Street, New Cumberland, P A 17070 County: Cumberland LeIlal DeseriDtion: ALL THAT CERTAIN TRACT OR PARCEL OF LAND AND PREMISES, SITUATE, LYING AND BEING IN THE BOROUGH OF NEW CUMBERLAND IN THE COUNTY OF CUMBERLAND AND COMMONWEALTH OF PENNSYLVANIA, MORE P ARTICULARL Y DESCRIBED AS FOLLOWS: BEGINNING AT A POINT ON THE SOUTHEAST CORNER OF RENO AND TAYLOR A VENUE; THENCE SOUTHW ARDL Y AWNG SAID RENO STREET 16 112 FEET TO THE DIVIDING LINE OR WALL ON PROPERTY NOW OR LATE OF D.Y. LENHART; THENCE EASTW ARDL Y ALONG SAID DIVIDING LINE AND AT RIGHT ANGLES WITH RENO STREET 140 FEET TO THE LINE OF CEDAR A VENUE; THENCE NORTHW ARDL Y ALONG SAID CEDAR A VENUE AND PARALLEL WITH RENO STREET 16 1/2 FEET TO TAYLOR A VENUE; THENCE WESTW ARDL Y ALONG THE LINE OF SAID T A nOR A VENUE 140 FEET TO THE POINT OR PLACE OF BEGINNING. HAVING THEREON ERECTED A FRAME DWELLING HOUSE KNOWN AND NUMBERED AS 223 RENO STREET. BEING THE SAME PREMISES WHICH RlGHARD LEHMAN AND BARBARA L. ILEHMAN, H/W, BY THEIR DEED DATED FEBRUARY 22, 2001, AND ABOUT TO BE RECORDED HEREWITH IN THE OFFICE OF THE RECORDER OF DEEDS OF CUMBERLAND COUNTY, PENNSYLVANIA, GRANTED AND CONVEYED UNTO LINDA S. MATEER AND JESSICA L. MANSBERGER, MORTGAGORS HEREIN. ",-"~- -~ '~-~~">,~~,^,,,,'.~'~' ,'.- ".~ _'c.""'<'~ -''''-"''''"'~''''''''',"-,"''VQ""',,,,,,,,,,,,,,~,,-,.,~._-. <~'-.l[jlii-l o c 2~ (~:~.~ ~ :;;;,'--" ~;c~, " :::J -<~ ES flJ/ III illll.liii"'TiJilllT'WIIIl . C) ~ -~:; ,,, :.D'''' c:- m ;;"!I.!mmI!li1!l!f'_~~__ ~1OO1i.,_,=.=." .1~1<'_IIll1II!llmI~r~~~~~~~~,~~*~~-1W'J>><'t'W'-i"''''''''''"'G--;'''"tt:'.,">4,,.q'f'[';",~""fW$iI'W'tll"11#m(fI"+"llIEi",":";'~P'I~~', '-, -"';'(""L':~',il .\\y,;;;~'_~g~,F;A'ijt'iiM;W!f&~tli~~'!l\~~WJI1!@1t~ SHERIFF'S RETURN - OUT OF COUNTY . CASE NO: 2001-06071 P COMMONWEALTH OF PENNSYLVANIA: COUNTY OF CUMBERLAND COUNTRYWIDE HOME LOANS INC VS MATEER LINDA S R. Thomas Kline , Sheriff or Deputy Sheriff who being duly sworn according to law, says, that he made a diligent search and and inquiry for the within named DEFENDANT , to wit: MATEER LINDA S but was unable to locate Her in his bailiwick. He therefore deputi~ed the sheriff of DAUPHIN County, Pennsylvania, to serve the within COMPLAINT - MORT FORE On November 13th, 2001 , this office was in receipt of the attached return from DAUPHIN Sheriff's Costs: Docketing 18.00 Out of County 9.00 Surcharge 10.00 Dep Dauphin Co 29.25 .00 66.25 11/13/2001 FEDERMAN & PHELAN ~~ R. Thomas Kline Sheriff of Cumberland County Sworn and subscribed to before me this ,;){, ~ day of ~~~. ~ c2tr0/ A.D. 0<r L D 'fl" h" 't ~;; Prothonota y "",:,;,.",-'ll't~~ ~ . , ~- I -,-,- "~'i<.,~~, ',/";:-\),'-S';f.~:-~ii!i.\~\\~'_'1;:-/;'f,,!}!!:I'!':~0:;?~"J1tJ!!~~?''J!l","f,'" ,_",__,,,,,,, ,""~~ "'_ _ -.. , ,~, .e<. SHERIFF'S RETURN - REGULAR CASE NO: 2001-06071 P COMMONWEALTH OF PENNSYLVANIA: COUNTY OF CUMBERLAND COUNTRYWIDE HOME LOANS INC vs MATEER LINDA 6 GERALD WORTHINGTON Sheriff or Deputy Sheriff of Cumberland County, Pennsylvania, who being duly sworn according to law, says, the within COMPLAINT - MORT FORE was served upon MANS BERGER JESSICA L the DEFENDANT , at 1900:00 HOURS, on the 30th day of October ,2001 at 223 RENO STREET NEW CUMBERLAND, PA 17070 by handing to ANTHONY BRAXTON, BOYFRIEND a true and attested copy of COMPLAINT - MORT FORE together with and at the same time directing His attention to the contents thereof. Sheriff's Costs: Docketing Service Affidavit Surcharge 60 Answers: 6.00 11.05 .00 10.00 .00 27.05 ~~~~' R. Thomas Kline 11/13/2001 FEDERMAN & PHELAN SWorn and Subscribed to before me this day of By' A1J..{ D)~ Deputy eriff A.D. Prothonotary -,-~~,,~ -.~- -~! "~ - , "'I , @iiitt of t1r~ ~4~:riff William T. Tully Solicitor J. Daniel Basile Chief Deputy Mary Jane Snyder Real Estate Deputy Michael W. Rinehart Assistant Chief Deputy Dauphin County Harrisburg, Pennsylvania 17101 ph: (717) 255-2660 fax: (717) 255-2889 Jack Lotwick Sheriff Commonwealth of Pennsylvania COUNTRYWIDE HOME LOANS, INC vs County of Dauphin MATEER LINDA S. Sheriff's Return No. 3137-T - -2001 OTHER COUNTY NO. 01-6071 I, Jack Lotwick, Sheriff of the County of Dauphin, State of Pennsylvania, do hereby certify and return, that I made diligent search and inquiry for MATEER LINDA S. the DEFENDANT named in the within COMPLAINT IN MORTGAGE FORECLOSURE and that I am unable to find him/her in the County of Dauphin, and therefore return same NOT FOUND, November 7, 2001 NEED A BETTER ADDRESS NO SUCH NUMBER ON LAKE DRIVE IN MIDDLETOWN OR IN HARRISBURG ~ '~.~~=~. 2001 Jf~ Sworn and subscribed to Sheriff of Dauphin County, Pa. PROTHONOTARY By Deputy Sheriff Sheriff's Costs: $29.25 PD 11/01/2001 RCPT NO 156147 ~-~':""--'- ",~...,..... ~<" - 'I ' , ~...,.,. ~~~- In The Court of Common Pleas of Cumberland County, Penmsylvania Countrywide Horne Loans Inc. V3. Linda S. Mateer et a1 SERVE: same No. 01 6071 civil N October 31, 2001 ow, , I, SHERIFF OF CUJ\1BERLAND COUNTY, P A, do hereby deputize the Sheriff of Dauphin County to execute this Writ, this deputation being made at the request and risk ofthe Plaintiff. ~/?..,p/ ~ -r ~~~~7.:~ Sheriff of Cum berland County, P A Affidavit of Service Now, , 20_, at o'clock M. served the within upon at by handing to copy of the original a and made known to the contents thereof. So answers, Sheriff of County, PA Sworn and subscribed before me this _ day of , 20 COSTS SERVICE MILEAGE AFFIDA VIT $ :]; -">"'rW<~~ -, Wi\:! > ~. ,,, "?, . ~ c e ..M . FEDERMAN AND PHELAN, LLP By: FRANK FEDERMAN, ESQUIRE IDENTIFICATION NO. 12248 ONE PENN CENTER AT SUBURBAN STATION 1617 JOHN F. KENNEDY BOULEVARD SUITE 1400 PHILADELPHIA, PA 19103-1814 (215) 563-7000 ATTORNEYFORPLAINT~F COURT OF COMMON PLEAS CIVIL DIVISION COUNTRYWIDE HOME LOANS, INC. 7105 CORPORATE DRIVE PLANO, TX 75024 Plaintiff TERM No.OI-I..07/ <!,u~L CJ~ v. CUMBERLAND COUNTY LINDA S. MATEER JESSICA L. MANSBERGER 223 RENO STREET NEW CUMBERLAND, PA 17070 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 WILL 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 may be entered against you by the court without further notice for any money claimed in the Complaint or for any other claim or relief requested by the Plaintiff. You may lose money or property or other rights important to you. YOU SHOULD TAKE THIS PAPER TO YOUR LAWYER AT ONCE. ~ 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. loan #: 9909949 We nereoy carmy the within to be a true and correct oopy of the TRUE COPY FROM RECORD original filed of record In Testimonywhareof, I here unto set my hand FEDERMAN AND PHELAN and the seal of said Court at Carlisle, Pa. This ~day of ~ ~~ '--..0~'? ~_vQ~_~ Prot notary CUMBERLAND COlTh'TY CUMBERLAND COUNTY BAR ASSOCIATION 2 LIBERTY AVENUE CARLISLE, P A 17013 (717) 249-3166 ~ ';'f"''''''''' ; r , _'~ _, _ ,__ . ,_ < " , ", = 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. THE 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 THIS 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. ')"'''''''''~~ , "q;1 ~~ " " , 1. Plaintiff is COUNTRYWIDE HOME LOANS, INC. 7105 CORPORATE DRIVE PLANO, TX 75024 2. The name(s) and last known address (es) of the Defendant(s) are: LINDA S. MATEER JESSICA L. MANSBERGER 223 RENO STREET NEW CUMBERLAND, P A 17070 who islare the mortgagor(s) and real owner(s) of the property hereinafter described. 3. On 2/22/01 mortgagor(s) made, executed and delivered a mortgage upon the premises hereinafter described to PLAINTIFF which mortgage is recorded in the Office of the Recorder of CUMBERLAND County, in Mortgage Book No. 1675, Page 850. 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 61110 I 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 are collectible forthwith. A copy of such notice is attached as Exhibit "A." "~l"Ci;""o,,,, ~-'., _ f _ ' I' ~~ ,-,-'" " ~- , ~." 6. The following amounts are due on the mortgage: Principal Balance Interest 5/1/01 through 9/1/01 (Per Diem $14.11) Attorney's Fees Cumulative Late Charges 2/22/01 to 9/1/01 Cost of Suit and Title Search Subtotal $61,573.24 1,749.64 3,078.00 69 A5 550.00 $67,020.33 Escrow Credit Deficit Subtotal TOTAL 300.00 0.00 ($ 300.00) $66,720.33 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 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. ~ 1680A03c 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 terminated because either: (i.) Defendant(s) have failed to meet with the Plaintiff or an authorized Credit Counseling Agency in accordance with Plaintiffs 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 $66,720.33, together with interest from 9/1/01 at the rate of$14.11 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. Isl Frank Federman FRANK FEDERMAN, ESQUIRE Attorney for Plaintiff '-~ -,' ~ j , ^' ., ,-- ~~ 'q,""ry;",~o,_._~_! ~ "d ~Countrywl e' HOME LOANS Tj Correspondence to '" So;, 10221 ,Vuys_ CA 91,; 1 0-0?2 I 5EP 2 6 2UU\ Sp.nd PaYnleo!sto POBox 660694 Dallas, TX 75266.069.. Certified Mail No Return Receipt Requested Regular Mail 1"i.,:11 2001 ."<'-IC8 L fv1R.nsherqPf :j Reno Strpel Np'A Curnl1ertand, PA 17070-0000 Account No.: 9909949 Property Address: 223 Reno Street New Cumberland. PA 17070-0000 Current Servicer: Countrywide Home Loans Servicing LP ACT 91 NOTICE TAKE ACTION TO SAVE YOUR HOME FROM FORECLOSURE This is an official notice that the mortClaCle on vour home is in default. and the lender intends to foreclose. Soecific information about the nature of the default is orovided in the attached oaoes. The_HOMEOWNER'S EMERGENCY MORTGAGE ASSISTANCE PROGRAM (HEMAP) may be able to helD to save vour home. This Notice eXDlalns how the oroaram works, To see if HEMAP can helD. YOU must MEET WITH A CONSUMER CREDIT COUNSELING AGENCY WITHIN 30 pAYS OF THE DATE OF THIS NOTICE. Take this Notice with you when you meet with the CounselinCl Aoeng.. The names, addresses and ohone numbers of Consumer Credit Counseling AClencies servina your Countv are listed at the end of this Notice. If you have any auestions. YOU may call the Pennsylvania Housina Finance Aaencv toll-free at 1-800-342.2397, (Persons with imDaired hearinG can call 1-717 -780-1669.) This Notice contains important legal information. If you have any questions, representatives at the Consumer. Credit Counseling Agency may be 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 a lawyer. LA NOTIFICACION EN ADJUNTO ES DE SUMA IMPORTANCIA. PUES AFECTA SU DERECHO A CONTiNUAR VIVIENOO EN SU CASA. SI NO COMPRENDE EL CONTE Nino DE EsrA NOTIFICACION OBTENGA UNA TRADUCCION INMEDIATAMENrE LLAMANDO ESTA AGENCIA (PENNSYLVANIA HOUSING FINANCE AGENCY) SIN CARGOS AL NUMERO MENCIONAno ARRIBA. PUEDE SER ELEGIBLE PARA UN PRESTAMO POR EL PROGRAM A LLAMADO "HOMEOWNER'S EMERGENCY MORrGAGE ASSISTANCE PROGRAM" EL CUAL PUEDE SALVAR SU CASA DE LA PERllIDA DEL DERECHO A REllIMIR SU HIPorECA. HOMEOWNER'S EMERGENCY MORTGAGE ASSISTANCE PROGRAM YOU MAY BE ELIGIBLE FOR FINANCIAL ASSISTANCE WHICH CAN SAVE YOUR HOME FROM FORECLOSURE AND HELP YOU MAKE FUTUR'E MORTGAGE PAYMENTS. IF YOU COMPLY WITH THE PROVISIONS OF THE HOMEOWNER'S EMERGENCY MORTGAGE ASSISTANCE ACT OF 1983 (THE "ACT'"), VOU MAY BE ELIGIBLE FDA EMERGENCY MORTGAGE ASSISTANCE: IF YOUR DEFAULT HAS BEEN CAUSED BY CIRCUMSTANCES BEYOND YOUR CONTROL, IF YOU HAVE A REASONABLE PROSPECT OF BEiNG ABLE TO PAY YOUR MORTGAGE PAYMENTS. AND IF YOU MEET OTHER ELIGIBILITY REQUIREMENTS ESTABLISHED BY THE PENNSYLVANIA HOUSING FINANCE AGENCY. ptease writ(.] your account number on all checks and correspondenC8 E3f1EACHPA fi:26,2000 9909949-1 Je~s'cJ-L MmlC.be,\!e, 223 Aeno Str"p" '\''''''JO,,';:I'>oo ;'Or.~"'FLJ~~),.,'h"'9od lor "och '0"'-000 POl'""'" "''''DI~'''''"'"'-''''''''-'''''''l'h $1 123.46 AS OF September 4,2001 llREAClIf'A IiICountrywide HOME LOANS POBox 660694 Dallas. TX 75266-0694 11"11,111",1,1.1111,111111,,,,11,,1,1'1111111,1,.,1,,1..1,1I EXH1BiT A 990994910001123460112346 ",^. p ,^ !l]Countrywide^ HOME LOANS I Correspondence to' Box IO?21 NuVs, CA 9/410-0221 31 2001 Send PaymenlS 10' POBox 660694 Dallas, TX 15266-0694 Certified Mail No. Return Receipt Requested Regular Mail 'Ja S M;lteer '~)', Reno Street Ne'.'1 Cumberland. PA 17070.0000 Account No.: 9909949 Property Address: 223 Reno Street New Cumberland. PA 17070-0000 Current Servtcer: Countrywide Home Loans Servicing LP ACT 91 NOTICE TAKE ACTION TO SAVE YOUR HOME FROM FORECLOSURE This is an official notice that the mortaaoe on vour home Is in default. and Ute lender intends to foreclose. Soacinc information about the nature of the default is orovided in the attached oaoes. The HOMEOWNER'S EMERGENCY MORTGAGE ASSISTANCE PROGRAM (HEMAPl may be able to helD to save vour home. This Notice exolains tiow the Droaram works. To see If HEMAP can helD. YOU must MEET WITH A CONSUMER CREDIT COUNSELING AGENCY WITHIN 30 DAYS OF THE DATE OF THIS NOTICE. Take this Notice with YOU when vou meet with the Counsellna Aaencv. The names. addresses and Dhone numbers of Consumer Credit Counsellna Aaencies servina your County are listed at the end of this Notice. If YOU have any ,Questions. vou mav call the Pennsylvania Houslna Finance Aaencv toll-free at 1-800-342-2397. (Persons with ImDalred hearln!] can call1-717~78o-1869.l This Notice contains important legallntormation. It you have any questions. representatives at the Consumer Credit Counseling Agency may be 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 a lawyer. LA NOTIFICACION EN ADJUNTO ES DE SUMA IMPORTANCIA. PUES AFEcrA SU DERECHO A CONTINUAR VIVIENOO EN SU CASA. SI NO COMPRENDE EL CONTENIDO DE ESTA NOTIFICACION OBTENGA UNA TRADUCCION INMEDIATAMENTE LLAMANDO ESTA AGENCIA (PENNSYLVANIA HOUSING FINANCE AGENCY) SIN CARGOS AL NUMERO MENCIONADO ARRIBA. PUEDE SER ELEGIBLE PARA UN PRESTAMO POR EL PROGRAMA LLAMADO '"HOMEOWNER'S EMERGENCY MORTGAGE ASSISTANCE PROGRAM" EL CUAL PUEOE SALVAR SU CASA DE LAPERDIDA DEL DERECHO A REDlMIR SU HIPOTECA. HOMEOWNER'S EMERGENCY MORTGAGE ASSISTANCE PROGRAM YOU MAY BE ELIGIBLE FOR FINANCIAL ASSlsrANCE WHICH CAN SAVE YOUR HOME FROM FORECLOSURE AND HELP YOU MAKE FUTURE MORTGAGE PAYMENTS. IF YOU COMPLY WITH THE PROVISIONS OF THE HOMEOWNER'S EMERGENCY MORTGAGE ASSISTANCE ACT OF 1983 (THE "ACT"), YOU MAY BE ELIGIBLE FOR EMERGENCY MORTGAGE ASSISTANCE: IF YOUR DEFAULT HAS BEEN CAUSED BY CIRCUMSTANCES BEYOND YOUR CONTROL, IF YOU HAVE A REASONABLE PROSPECT OF BEING ABLE TO PAY YOUR MORTGAGE PAYMENTS. AND IF YOU MEET OTHER ELIGIBILITY REQUIREMENTS ESTABLISHED BY THE PENNSYLVANIA HOUSING F1NANCE AGENCY. Please wnte your account number on all ch(.'cks and correspondence 8REACHPA 6:?6;?OOO 9909949-1 llndaSM,,!ee, 223 Reno $1'eeT "''''''''oS2<;OO I!-lOOO., FL\.". ".<"",~.d 'or .""" '.,""''''' p'\,""'"'"'<''''''' 0'''''''''''''''''''''''1>1'''' $1.123.46 AS OF September 4.2001 BREACHPll, II] Countrywide HOME LOANS P O. Box 660694 Dallas, TX 75266-0694 1111I111.1...1.1.11...111111'1111111111..,1.,11.111,1,,1,,1,11 EXHlBIT A 990994910001123460112346 '--;",-,.wrrl:otl.<:::.. ,. '.' , or ,. '~n..,_~ ,. ~~_ . ,_ ,. , j EMPORARY STAY OF FORECLOSURE - Urlder the Act, you are entitled to a temporary stay of toreclosufIJ all your l'l\ortgage for thirty-five (35) days from the date 01 this Notice. During that tune you must arrange and attend a "'ace-to- I.lce" meeting with one of the consumer credit counseling agencies listed at the end of this Nollee. THIS MEETING MUST OCCUR WITHIN THE NEXT (35) DAYS. IF YOU DO NOT APPLY FOR EMERGENCY MORTGAGE .\SSISTANCE YOU MUST I3R1NG YOUR MORTGAGE UP TO DATE, THE PART OF THIS NOTICE CALLE:D "HOVV I 0 6JRE -YOUR -MO-RTG'AG"E"DEFAULT";-EXPL-AINSHOW"TOBRINGy'OURMORTGA-GEUPTO-OATE -- .. 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 at thIs Ineetmg. The .names E!.ddresses and teleohone numbers 01 desionated consumer credit counse~ng f!9.enci~~_"f()r JD.~ countv in which the DrODertv is located are sel forth at the end of this Notice. It is only necessary to SChedule one lace. lo-Iace meeting. Advise your lender immediately of your intentions. ,APPLICATION FOR MORTGAGE ASSISTANCE - Your mortgage is in default for the reasons sel forth later In this Nolrce (see following pages for speCific information about the nature of your default) If you have tried and are unable I ) resolve thiS prOblem with the lender, you have the right to apply for financial aSSIstance from the Homeowner's Emergency Mortgage Assistance Program. To do 50, you must fill out, sign and file a completed Homeowner's Emergency Assistance Program Application With one of the designated consumer credil counsehng agencies listed at IlIe end of thiS Notice. Only consumer credit counseling agencies have applications for the program and they will assist 'Iou In 5ubmlllmg a complete application to the Pennsylvania Housing Finance Agency. Your application MUST be filed ,,( postmarked 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 dISbursed by tile Agency under the eligibility criteria established by the Act. The Pennsylvania Housing Finance Agency has sixty IIIO) days to make a deCision alter II receives your application. DUring that time. no foreclosure proceedings Will be f.ursued agamst you if you have met the time requirements set forth above You will be notified directly by the I 'ennsylvama Housing Finance Agency at its decision on your application. NOTE: IF YOU ARE CURRENTLY PROTECTED BY THE FILING OF A PETITION IN BANKRUPTCY. THE FOLLOWING PART OF THIS NOTICE IS FOR INFORMATION PURPOSES ONLY AND 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 t-JATURE OF THE DEFAULT. CountrYWide Home Loans Serviclna LP. (hereinafter ~Countrvwide") services your llome loan Your home loan is in seflous default because you have not made your required payments. The total ilmount now required to reinstate your home loan as of the date 01 this letter is as fOllows: l.1o.nLhlY ~~Yfll~f1~. $538.57 I at'LC.hargg~ $23.16 , lHler C11<lrges Uncollected Late Charges Uncollected Costs. $1,077.14 $46.32 TOTAL DUE: $1,123.46 PA YME~T-,NSTRUCTION~ Please M,,~<o yow neck paydole 10 l~Jlin/ryWllje /-;[lme L"dflS l/n[,., YOIII )~n nlllnt,er on jrJ\lr Ltll:~ck 01 money OfrJr.r 'I\'r,:,~ III ,-,r., .,)rJI1IOIlJI ~mou(lI:; you are inCluding III Ir~\. il I~ nIL 11 'IIIJII :):)1 JUG pled~i' c.end certlllr~(j Cllec~ I DOf\latlachyourcheckwlllepaymelltcollprll Don I InClu,Je corresponrJence Don I sallJ ca~l. Payments Ad DaymenlS Will be applied to !!le longeSI oulstalldmg mSlallmerl1 due, unless oltJerwlse expressly prohibited by law Additional amounts._ If you doni specify lhe purpose ot additional amounl~ Included, we Wilt apply them lilsllo any oul~'andlng Da'/menl~ ~sc;,jw deflclEncles.lale ct1arges and.lor fees dUE We will then apply ,lny remaining amounts as a pllnclpal reduc1ion. II IlJlI ~lIbmll drl J<Jolllonal pnnClpal payment wIlh your home loan payment, Counlrywids Will first apply youl home loan paymenl, then rt,fad'11110ndll'UIClpalpavmen! YourlO,ln musl be curlem betole we can appll "qyprrnClpalleduCTion EXHl8lT A. '.-F'P''''~$!l!I!,,~ _,_~ <-- -~_"!1'."""~ '~,.. _'.~~'''!'"_'I ,"'" h"~ HOW TO CURE THE DEFAULT. You may cure ttlis default within THIRTY~FIVE (35) DAYS of the date ottl115 letter_ l1V iJaYII1Q to us till': above amount of $1,123.46, plus any additional monthly payments. late charges. fees and otller nppl/cable ctlarges which may fall due during this period. Such payment must be in the form of certified check. casHier"s check or money order. and made payable to Countrywide at P.O. Box 660694. Dallas. TX 75266-0694 I! 'IOtH check or otller payment is returned to us for insufficient funds or for any other reason. YOll Will not have cured vn'n JetaulL No exlenSlon of tune to cure Will be granted due to a returned payment '11/ou do not cure this delault within THIRTY-FIVE {35} DAYS, we will accelerate t\1e payments duE'. on your home 1(1::1.11. rtllS means '!l/Ilatever is owing on the original amount borrowed will be considered due immediately and yOIl may lose the chancl'! tn payoff your home loan in monthly installments. If the full payment of the amollnt in default is not mMe '.VlltWl THIRTY-FIVE (35) DAYS. we also intend to immediately start a lawsuit to foreclose on your mortgaged propNt',.- lUHE MpRTGAGE IS FORECLOSED UPON - If the mortgage is foreclosed, the mortgaged property will be solel !ov 111e Sheriff to payoff the mortgage debt. 11 the default is cured before we begin legal proceedings. Countrywide will be pnlitlpd to collect the reasonable attorney's fees actually incurred. up to $50.00. However. if legal,proceedlnqs are ~tarted, Countrywide will be entitled to collect the reasonable attorney's lees even if they are over SSO.OO AnI' ;j\torney's leBs will be added to the secured debt, which may also include our reasonable costs. If you cure the default vitllin Ihe THIRTY-FIVE (35) DAY period. you will not be required to pay attorney.s fees, YOU HAVE THE RIGHT TO REINSTATE AFTER ACCELERATION AND RIGHT TO ASSERT IN THE FORECLOSURE PROCEEDING THE NON- EXISTENCE OF A DEFAULT DR ANY OTHER DEFENSE YOU MAY HAVE TO ACCELERATION AND FORECLOSURE OTHER LENDER REMEDIES The lender may also sue you personally for the unpaId principal balance find all ollll:'r -iwnS due under the mortgage. RIGHT TO CURE THE DEFAULT PRIOR TO FORECLOSURE SALE - If you have not cured ltle default wlth11l Ille THIFHY -FIVE (35) DAY period and foreclosure proceedings have begun, you still have the right to cure the default ilnd Tlrev€nf Itle sale at any time up to one hour before the foreclosure sale. You may do so by paying the total amoLlnl tllen past due. plus any late or other charges then due. reasonable attorney's fees and costs connected wiltl the Jorectosure sale and any other costs connected with the foreclosure sale as specified in writing by the lender and by pertorming Hrw 'lther reqUirements under the mortgage. Curing your default in the manner set forth in this notice will restore your mortgage to the same position as if you had never defaulted. EARLIEST POSSIBLE 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 date of this letter. A notice of the date of HIe foreclosure sale will be sent to you before the sale. You may find out at any time exactly what the required payment will be by r:alling us at the following number: 1-800-669-6654, This payment must be in the form of a cashier"s check. cert111ed cllec:k or money order and made payable to us at the address stated above_ If the default IS cured. the mortgage Will be l%tored \0 the same position as if no default had occurred. However, the default may not be cured more than three '.3\ timeS In any calendar year HOW TO CONTACT THE LENDER, Name of Lender: Address: phone Number: Fax Number: ~ontact Person: Countrywide Home Loans Servicing LP P. O. Box 10221 Van Nuys, CA 91410-0221 1-800-669-6654 '~805.577.3432 Melanie Carrillo, MS SV-34 Attention: Loan Counselor ~FFECT_..QE FORECLOSURE SALE - You stlOuld realize that a foreclosure sale Will end yQUf ownerstllp of Iltp mortgaged property and your right to remain in it. If you continue to live in the property afler the Stleriff"s sale. a lalJ.'sUlI tn remove you and your furnishings and other belongings could be started by Countrywide at any time 4.SSUMPTION OF MORTGAGE - Contact Countrywide Home Loans lor inlormation on the possible assumab,llty nt your loan YOU MAY ALSO HAVE THE RIGHT: TO SELL THE PROPERTY TO OBTAIN MONEY TO PAY OFF THE MORTGAGE DEBT OF~ 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 ~lIGHT TO CURE YOUR DEFAULT MORE THAN THREE TIMES IN ANY CALENDAR YEAR) TO ASSERT THE NONEXISTENCE OF A DEFAULT IN ANY FORECLOSURE PROCEEDING OR ANY OTHER LAWSUIT INSTITUTED UNDER THE MORTGAGE DOCUMENTS. TO ASSERT ANY OTHER DEFENSE YOU BELIEVE YOU MAY HAVE TO SUCH ACTION 8Y THE LENDER TO SEEK PROTECTION UNDER THE FEDERAL BANKRUPTCY LAW. I'ursuant to your Ilome loan documents. and because the home ioan is in delaull. Countrywide may. at Its optlon_ enter IlpOI) and comjuct an inspection of the property_ The purpose of this inspection is to observe thl? pllysical conditif)11 of 1I1P property, In veTlly that the property 1S occupied and/or to determine the Idenllty of the occupant The cost of Clnv ';IICll Inspection Will be added to and become part 01 the secured debt as provided under tile lerms oj Il1e llOnw Inan I JoC'ull1ents "", .'-.".-"r \ ' .-. ",--) r t;,}\""j ; .~" , ' ,.; --....-. j> ~ -,. ,,-),- '-'i\""""",~~ , II you are unable to cure your default on or before September 4 2001. Countrjwlde wants you to be aware 01 various ol.JIlun", 1lldl IHay blO dVallable tu you ltlrouyll Countrywide 10 prevell! a 10rE:c.:losuf€ ;;<:Ile 01 your properly_ Fur 8XHllIIJk Ber;avment Plan: It is posSible that you may be eligible lor some form 01 payment assistance through Countrywide Our basIc plan reqUIres that Countrywide receive, up front, at least 1;2 01 the amount necessary to bring tile account current. and that ltle balance 01 the overdue amount be paId, along wIB, the regular monthly payment, over a delmed penod of time. Other repayment plans also are available. Loan Modification: Alternatively, it is possible that the regular monthly payments can be lowered througt\ a modificatIOn of tile loan by reducing the mterest rate and then adding the delinquent payments to the current loan balance This foreClosure alternative, however, is limited to certain loan types. Sg.IILQLYQ!JLPr91!~rtY- Alternatively, if you are willing to sell your home in order to avoid forecloslHe. It is pOSSible that the saie of your home can be approved through Countrywide even if your !lame is worth less than wllat is owed on It Deed-in-lieu: Alternatively. if your property is free lrom other liens or encumbrances. and if the default is due to a serious financial hardship which is beyond your control. 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 iis sole discretion. whether sue!l assistance Will be extended to you III 1tw It wan time, Countrywide Will pursue all of its fights and remedies under the home loan documents and as permllted by law, unless It agrees otherwise in writing. Please be advised that failure to bring the home loan current 01 to enter mto a written agreement as outlmed above will result in the acceleration of the debt. Time IS of tile essence Should you have any questions concerning III is notice. please contact Countrywide's oltlce Immediately at t -800-669-6654. extenSion 7556. ?Jtdwue ea'/lZitto Meianie Carrillo loan Counselor 1-800.669-6654. extenSion 7556 Please be advised that this communlcalion is from a debt collector CV1'!i"')'...r A \..;.Ali ; .C;) 1 . ,. "~-,~- -I"' '. ,,," ,~ , PE:-INSYLVA.l'lIA HOlSI:-IG FI:'i,~'1CE AGE:'iCY HOMEOW:'iER'S E:vIERGENCY ASSIST,~'1CE PROGRA,Yl CONSUMER CREDIT COlNSELlNG AGE:'iCIES (REV. 8/00) CLINTON COl:-lTY Lycommg~Climon Cuunties Commision for Community A~tlon (STEP) 2138 Lmcoln Street POBox 13"28 Williamsport. PA 1 n03 (570) 326-0:;87 F,-\.'\ (570) 322-2197 CCCS of~orthe::l.Stem P.-\ 1631 South Athenan St.. Suite 100 State College. P.-\. 1680 I (Sl~)238-3668 F.-\.'(lSl.+):'38-3609 CCCS at":"icHtheastem PA ::Ol Basin Street Williamspol1. PA 17703 (570) 323-6627 FA..;< \570) 323-6626 3 I W Market S [reet P08 1127 Wilkes-Barre. P A 18i02 (570) 321-0837 or (800) 922-9537 FAX (570) 82 t -! 785 COLuMBIA COt",-"y 1 ~OO .-\blngton E:'(ecuuve Park SUite I Clarks Summil?.-\ IS..l.[ 1 (570) 587-9163 Qf (800) 922-953-:- F..\.'< ' ;~O) ;8; -9134-913; CommIssion on Economics Opportunity of Luzeme Counry 163 .-\mber LUll:: Wilkes-Barre. PA 18702 (5-:'0) 326~05 to or (800) 8:2-0359 FAX \510) 8:9-\665---1.Call Before Fax.ingj t570) 455-4994 Hazeltown FA...X (570) -l55~563 [---(COlli Before Faxmg) (570) 836-4090 Tunkhannock Booker 1. Washington C;:mer 1720 Holland Center Erie, PA 16503 (814) 453-5744 FA.X (814) 5749 CIU WFORD CO!.",-TY Gre:l.ter Erie Commumr\' .-\ctlon C.Jmmirt~~ 18 ~.'v'est 9111 Street . Ene. P.-\ 16501 1814)459-1;81 F..\.'<1,814)456-0161 John F. Kennedv Center. [nc 2021 East :0'11 Street Ene,P.-\ 16.510 (814) 898-0400 F,U 1814) ~98-1:43 Shenango Valley l.rban L~ague. Inc 601 indiana Avenue F""ell. P.-\ 161:1 (4!:) 981.5310 Cu~IBERL\~D CO!. "'iTY CCCS of West em Pennsylvania. Inc. 2000 Lmglestown Road Harrisburg, Pc\. 17102 i71!) 541.1757 FinanCIal Counsding ServIces of Franklin 31 '-,....est 3'd Street - W3~l1esboro, Pc\. 17268 (717) 762~3285 Urban LeaglJe of~ktropoiitan Hamsburg :-.I. 6\J1 Street Harrisburg, P.-\ lilOl (':'17):3-+-5925 F.-\.,'((717) 23..!.-9459 y-v.,'c.-\ of Carlisle 301 "G" Street Carlisle, P.-\ 17013 .. C"!:'1 243-381S FA..'< 1,(17)~731~95.39 Cummunity ;\cuon Cumm ufrhe CapItal R..egion 151-+ Derry Streer Harrisburg, PA. 1710-+ ('717)2.32-975'7 f.-\"'(171'7)2.34~2:22i Adams Count) Housing .-\uthorir:- U9-i-L;ClrliskSt. Gerr;.sburg, P.-\ 17325 CI:i3.34-1513 F.-\.:"<33..j.~8326 PE~:-;SYLVA.~L\ BULET!:'i. VOL. Z9, ~O. Z3. H."'iE 5. 1999 EXHiBIT A ,~",,'ffliI'_ ~:r "",...,~--- , T rcr.A T. nFSrRTPTTON All that certain lot or piece of ground with the buildings and improvements thereon erected, being known as 223 Reno Street, New Cumberland Borough, Cumberland county, and being further described on that certain Deed dated 2/22/01 and recorded 3/1/01 in the Office of the Recorder of Deeds in CUMBERLAND County in Deed Book No.240, Page 303. Parcel No. 25-25-0006-256 BEING known as: 223 RENO STREET NEW CUMBERLAND, P A 17070 ,"(':?; 'I" , ,. l, ;~ . VERIFICATION BRANDON SCIUMBATO hereby states that he is VICE PRESIDENT of COUNTRYWIDE HOME LOANS, INe. 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 true and correct to the best of his knowledge, information and belief. The undersigned understands that this statement is made subject to the penalties of 18 Pa. C.S. Sec. 4904 relating to unsworn falsification to authorities. DATE: / afro I { .'!~""~W, .~_ i' - , _ ~ ""."" ,"___" ~~",~iii~~,K:i~JE~'i!i;$i;~iJlli.~~':C~'''f,)~,,,,~:;;",,;,'~,>-_''''';r,'i'''iai,,, :>4i':'-ii!Wii~fr1lli:",;j>i;,1llil'il:~'-'-'~":!I dzld~.iW.~1i~_____ 3JL~ l&J ~ ~ ~. ~ ~ <S. . d <;~ ~/ u..._".'_ O,Ff; .~ pcr 2il ,") f_ I', I'; ~~=~ ".c"'''''-"",_~"",,_ ",,"'-' _~ _ _ , ",'"~",~ ,g~, ~_" _ .~ ~= H,f:;{:1:rf. ";i"{fJ-)f 'J v 35 Ii lJ: I L; \ . ,~ ~- .-, ~ -'H:~j CC;U:'j 7 '( '~r-l~,'-~fFF"S OFFie:: '. I ;. 'i " I ~-ii l' C C-, ~I i: j ~ ,. ;:. , ...:~ :',', :;:;). C I r'i\il~1 - 1 t~;i 8: 53 r'"j I'",~ " '-.1 '=,. i \,1 ,.io) ~,~ -~ ~~ FEDERMAN AND PHELAN BY: FRANK FEDERMAN, ESQUIRE Identification No. 12248 1617 JohnF. Kennedy Boulevard Suite 1400 Philadelphia, PA 19103-1814 (? 1 'i) 'i/ii- 7000 Attorney for Plaintiff COUNTRYWIDE HOME LOANS, INC. COURT OF COMlVION PLEAS Plaintiff CIVIL DIVISION vs. LINDA S. MATEER JESSICA L. MANSBERGER Cumberland County Defendants No. 01-6071 CIVIL TERM PRAECIPE TO REINSTATE CIVIL ACTION/MORTGAGE FORECLOSURE TO THE PROTHONOTARY: Kindly reinstate the Civil Action in Mortgage Foreclosure with reference to the above captioned matter. ~p~ FRANK FEDERMIlli', ESQUIRE Attorney for Plaintiff Date: November 20, 2001 MXM,SVC DEPT '",,"'ll'. , ~. < ., "I "" 1;:__ ~, - -~ -.'-'< ~'~" """ "~ .~~~;jII!\~, ,,-~~~-- "- " ".d ""," ,<' p"W,,", " " Il~ I i IT1 Tin 0 c::> Cj C <'" Z "1:J['0 0 me': "t:: L:L" "0 2r" ~1;~~ CT\ r:r=: <-' " ~c) "'-C" 5c: L,) -"y " <- :< ~ -, ~~ lru~ilfnn' irr',~f"'i" 1l,J ,M~~~~~'~:p,~""W'~M"'),,"''';'''-j!'i).fHii>'-Wt"~~lll>'\itjl~~~~JifJWifi~~~~~. ".,. ~ 1 . SHERIFF'S RETURN - OUT OF COUNTY CASE NO: 2001-06071 P COMMONWEALTH OF PENNSYLVANIA: COUNTY OF CUMBERLAND COUNTRYWIDE HOME LOANS INC VS MATEER LINDA S R. Thomas Kline , Sheriff or Deputy Sheriff who being duly sworn according to law, says, that he made a diligent search and and inquiry for the within named DEFENDANT , to wit: MATEER LINDA S but was unable to locate Her in his bailiwick. He therefore deputized the sheriff of DAUPHIN County, Pennsylvania, to serve the within COMPLAINT - MORT FORE On December 11th, 2001 , this office was in receipt of the attached return from DAUPHIN Sheriff's Costs: Docketing 18.00 Out of County 9.00 Surcharge 10.00 Dep Dauphin Co 29.25 .00 66.25 12/11/2001 FEDERMAN & PHELAN So an~ //. /'_~~ ~~ ~/ /' ~." R 'Thomas Kline Sheriff of Cumberland County Sworn and subscribed to before me this /2 ~ day of ~ ;J.6-tJ1 A.D. ~a.~ . prothonoca~ '-'~:'W!':,~'Vl _ "'"~"'~'"" ,... .. ""~f1 , c , ,I' @iiitt of t4~ ~4~:riff William T. Tully Solicitor J. Daniel Basile Chief Deputy Mary Jane Snyder Real Estate Deputy Michael W. Rinehart Assistant Chief Deputy Dauphin County Harrisburg, Pennsylvania 17101 ph: (717) 255-2660 fax: (717) 255-2889 Jack Lotwick Sheriff Commonwealth of Pennsylvania COUNTRYWIDE HOME LOANS INC vs County of Dauphin MATEER LINDA S 717-944-3978 Sheriff's Return No. 3376-T - -2001 OTHER COUNTY NO. 01-6071 AND NOW: December 5, 2001 at 5: 20PM served the wi thin COMPLAINT IN MORTGAGE FORECLOSURE upon MATEER LINDA S by personally handing to HER 1 true attested copy(ies) of the original COMPLAINT IN MORTGAGE FORECLOSURE and making known to him/her the contents thereof at LISA LAKE TRAILER PARK 111 LAKE DR. MIDDLETOWN, PA 17057-0000 DEFENDANTS PHONE NUMBER IS 717-944-3978. ~.~~) PROTHONOTARY So Answers, JR~ Sworn and subscribed to efore me this 6TH day of DECEMBER, 2001 Sheriff of Dauphin County, Pa. / .":0 I}~ill-- BY~ "i . /f~t-~ Deputy Sheriff Sheriff's Costs: $29.25 PD 11/28/2001 RCPT NO 157167 MARTIN '-"}'IGl?\"~~,_,_, ^"'. In The Court of Common Pleas of Cumberland County, Pennsylvania Countrywide Heme Loans Inc. VS. Linda S. Mateer et al SERVE: Linda S. Mateer No. 01 6071 civil Now, Novembel:- 27, 2001 , I, SHERIFF OF CUMBERLAND COUNTY, P A, do hereby deputize the Sheriff of Dauphin County to execute this Writ, this deputation being made at the request and risk of the Plaintiff. .../?/- v0' ~~~-4'" , , Sheriff of Cumberland County, PA Affidavit of Service Now, , 20_, at 0' clock M. served the within upon at by handing to a copy of the original and made known to the contents thereof. So answers, Sheriff of County, PA Sworn and subscribed before methis_dayof ,20_ COSTS SERVICE MILEAGE AFFIDAVIT $ $ ,,~"'''''~.~_ ,>'", ",t~ .~- - ~ ~, ~ , -,~- -~ ~, ~ -- " -" " \ FEDERMAN AND PHELAN By: FRANK FEDERMAN Identification No. 12248 Attorney for Plaintiff ONE PENN CENTER AT SUBURBAN STATION 1617 JOHN F. KENNEDY BLVD., SillTE 1400 PHILADELPHIA, PA 19103-1814 (215) 563-7000 COUNTRYWIDE HOME LOANS, INC. 7105 CORPORATE DRIVE PLANO, TX 75024 CUMBERLAND COUNTY COURT OF COMMON PLEAS Plaintiff, CIVIL DIVISION v. NO. 01-6071 CIVIL LINDA S. MATEER JESSICA L. MANSBERGER Defendant(s). PRAECIPE FOR JUDGMENT FOR FAILURE TO ANSWER AND ASSESSMENT OF DAMAGES TO THE PROTHONOTARY: Kindly enter judgment in favor ofthe Plaintiff and against LINDA S. MATEER and JESSICA L. MANSBERGER, 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 9/2/01 to 1/21/02 TOTAL $66,720.33 $2,003.62 $68,723.95 I hereby certify that (1) the addresses ofthe Plaintiff and Defendant(s) are as shown above, and (2) that notice has been given in accordance with Rule 237.1, copy attached. FRANK FEDERMAN, ESQUIRE Attorney for Plaintiff DAMAGES ARE HEREBY ASSESSED AS INDICATED. DATE: _~ --.!:I, ~OO"' ~ ',"'1"M~" '.t' I~" =-" - <..< . ~~ FEDERMAN AND PHELAN Frank Federman, Esquire Identification No. 12248 One Penn Center Plaza at Suburban Station, Suite 1400 Philadelphia, PA 19103-1799 (215) 563 -7000 ATTORNEY FOR PLAINTIFF COURT OF COMMON PLEAS COUNTRYWIDE HOME LOANS, INC. CIVIL DIVISION Plaintiff vs. CUMBERLAND COUNTY LINDA S. MATEER JESSICA L. MANSBERGER NO.01-6071 CIVIL Defendant TO: JESSICA L. MANS BERGER 223 RENO STREET NEW CUMBERLAND,PA 17070 DATE OF NOTICE: DECEMBER 27. 2001 THIS F.IRM IS A DEBT COLLECTOR ATTEMPTING Th~itECT A DEBT. THIS NOTICE IS SENT TO YOU IN AN ATTEMPT 1<<1 ~~rE INDEBTEDNESS REFERRED TO HEREIN, AND ANY INF il~P.JOBTAINED 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 COUNTY CUMBERLAND COUNTY BAR ASSOCIATION 2 LIBERTY AVENUE CARLISLE, PA 17013 (717) 249-3166 2f/ 2c/ Frank Federman,Esquire Attorney for Plaintiff ,""'''"..,\~ ~ .-^> I' 0 " - ,-,', .'iP . iEDERMAN 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 ATTORNEY FOR PLAINTIFF COURT OF COMMON PLEAS COUNTRYWIDE HOME LOANS, INC. CIVIL DIVISION Plaintiff CUMBERLAND COUNTY vs. NO. 01-6071 CIVIL LINDA S. MATEER JESSICA L. MANS BERGER Pefendant(s) TO: LINDA S. MATEER 111 LAKE DRIVE MIDDLETOWN,PA 17057 PATE OF NOTICE: DECEMBER 27. 2001 . ~ THIS FIRM IS A DEBT COLLECTOR AT;E~P\~~'tOLLECT A DEBT. THIS NOTICE IS SENT TO YOU IN AN ATTE~~~OLLECT 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 COUNTY CUMBERLAND COUNTY BAR ASSOCIATION 2 LIBERTY AVENUE CARLISLE, PA 17013 (717) 249-3166 )Y?./ Frank Federman, Esquire Attorney for Plaintiff 'O_"_""'~"". ";_":' '.-,._" '"~ ,~ j'. . ,FEDERMAN and PHELAN By: FRANK FEDERMAN Identification No. 12248 ONE PENN CENTER AT SUBURBAN STATION 1617 JOHN F. KENNEDY BLVD., SUITE 1400 PIDLADELPIDA, PA 19103-1814 (215) 563-7000 ATTORNEY FOR PLAINTIFF COUNTRYWIDE HOME LOANS, INC. 7105 CORPORATE DRIVE CUMBERLAND COUNTY COURT OF COMMON PLEAS Plaintiff, CIVIL DIVISION v. NO. 01-6071 CIVIL LINDA S. MATEER JESSICA L. MANSBERGER Defendant(s). VERIFICATION OF NON-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 LINDA S. MATEER is over 18 years of age and resides at , III LAKE DRIVE, MIDDLETOWN, P A 17057 . (c) that defendant JESSICA L. MANSBERGER is over 18 years of age, and resides at, 223 RENO STREET, NEW CUMBERLAND, PA 17070. This statement is made subject to the penalties of 18 Pa. C.S. Section 4904 relating to unsworn falsification to authorities. J -----l>> / FRANK FEDERMAN, ESQUIRE Attorney for Plaintiff ~T~,. "~ , I ~ , . , 1>-' . (Rule of Civil Procedure No. 236) - Revised IN THE COURT OF COMMON PLEAS OF CUMBERLAND COUNTY, PENNSYLVANIA CIVIL ACTION - LAW COUNTRYWIDE HOME LOANS, INC. 7105 CORPORATE DRIVE CUMBERLAND COUNTY COURT OF COMMON PLEAS Plaintiff, CIVIL DIVISION v. NO. 01-6071 CIVIL LINDA S. MATEER JESSICA L. MANSBERGER Defendant(s). Notice is given that a Judgment in the above-captioned matter has been entered against you on . J:i.b AI 200:1". " Jiy' 4;>p DEPUTY P.7f~ If you have any questions concerning this matter, please contact: FRANK FEDERMAN. ESQUIRE Attorney for Plaintiff ONE PENN CENTER AT SUBURBAN STATION 1617 JOHNF. KENNEDY 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."" "'~~~""f~,1 >" ". _: lm___ '_"". =._h^_'~O ~ . ~'~'''=~~'. ',c"~-,;:' "~-- ,,- '''''"-''''~-6' ,. _"dM'" .~ ,~ '.- ._- . t ~ (.J ~ n C::-" ~ ,-,.:, i . s~ ~'1 () -Vi-:' rq 92~~;.. a"J C> I ...;c CI~ F ~(~': -" "- ...... ~ ';-:,:.(j- r";CJ ",. :j~t lU ~ );; ;" ~:.. j - ~t) 6rn iN (5 PC:: 'f! -, 1v z <0- QJ' ~ J -I ,,- ::0 "-....) -<. 0 -< M r Es sJ-/ P'r1!1f -~~~lII'l~~"I~~t$1"',""''V~'''i'''''~'''''l't.''''"'',,-:---n,,~'':;-'''_JU"-"':;!:'IW""i!i!<'''';:;!'>;'''~:''''#''-.~W;H'-''''''t!!';_'i'''~1'Jr.!i~~f!'',clJ,,, ~_~J,_!~;"- "*,J,~:,.. ~ _~ <: -~ " PRAECIPE FOR WRIT OF EXECUTION - (MORTGAGE FORECLOSURE) P.R.C.P. 3180-3183 COUNTRYWIDE HOME LOANS, INe. Plaintiff, v. LINDA S. MATEER JESSICA L. MANSBERGER Defendant(s). No. 01-6071 CIVIL TO THE DIRECTOR OF THE OFFICE OF THE PROTHONOTARY: Issue writ of execution in the above matter: Amount Due Interest from 1/22/02 to 6/5/02 (per diem -11.30) TOTAL $68,723.95 $1,514.20 and Costs $70,238.15 F~EDErl,1~ 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. " "' . .~~ 1II1i~ . ~ ~ ~,~> .~~" ~..' , ~~ ',;'", ,'~c":'"""~"""",Y.,,,,,,-,'__'i. .'';-''.,. ..",,",,--,.,,-,..".~.,~.~ 1111 liill'"<YeY'''llliJlrnlilillirrrr , 0 I- 0 I- ,.., 1-< 1Il~ o . ~~ ~;j Z~ ...< ~i:Q Oz Z O:::J oo~ U 0 ""~ .... ~u ~~ Z "" '""~ .... ~ ~ '""00 (I) ~ u ~~ .,j ~~ ~ ~~ ~]' OJ :::J . ~ o~ 0 ~ = ."" ~~ '" ~~ '" :::J~ '"" ~i:Q Iio< Q OJ ~>< ~ ""00 Oc:l ..0 <~ OJ ~ 0"" "" .. ~f;; uz 0 .; ::::J i:a~ s ...~ IIi .. ~~ ~~ ~ 00 ~ <J OJ ...u ~ ~< ~~ j~ g. ~~ ~ Zu 0.... 0- lio< S ,.., "" OJ ........ .... '" '""00 ~:::J ... ....'" OJ 8;j 00 ~'-' ~ "" r:; .... u '" ~~ ~ '" ~~ ~ .;j j 0 OJ ~ z~ u .~ ~ ....u 1!lI~, " ._ ."~~~"...","~~~..4;lI.!'!!'l~J'lll~\'Wll!l~~i['T""""iO';r.'0"'".,q,.,,,,.,...<co";'" j'>'";-1!'<!Nl'1J1~fW~~"W1W!'ft'j-;'l;:8;~;m~ii!I'~!f~)~r"; .. Propeny Address: 223 Reno Street. :'Iew Cumberland. PA 17070 County: Cumberland Le2al DescriDtion: ALL THAT CERTAIN TRACT OR PARCEL OF LA."D A'''D PREMISES, SITUATE, LYING A,"D BEING IN THE BOROUGH OF ;o;EW CUMBERLA."D IN THE COUNTY OF CUMBERLAND A;-lO COMMONWEALTH OF PE;-lNSYLVA,'IIlA. MORE PARTICULARLY DESCRIBED AS FOLLOWS: BEGINNING AT A POINT ON THE SOUTHEAST CORNER OF RENO A'''D TAYLOR A VENUE; THE:'iCE SOUTHW ARDL Y ALONG SAID RE:'iO STREET 16 1/2 FEET TO THE DIVIDING LINE OR WALL ON PROPERTY NOW OR LATE OF 0.'1'. LE:"IHART; THENCE EASTW.....RDLy ALONG SAID DIVIDING LINE .....:'iD .....T RIGHT ANGLES WITH RENO STREET 140 FEET TO THE LINE OF CEDAR A VENUE; THENCE :"10 RTHWARDL 'I' ALONG SAID CEDAR A VENUE A.ND PARALLEL WITH RENO STREET 16 lf2 FEET TO TA YLOR A VENUE; THENCE WESTWARDL Y ALONG THE LINE OF SAID TA YLOR A VENUE 140 FEET TO THE POINT OR PLACE OF BEGINNING. HA VING THEREON ERECTED A FRAME DWELLING HOUSE K."IOWN AND :'lUMBERED AS 223 RE:'iO STREET. BEING THE SANtE PREMISES WHICH RICHARD LEHMA." AND BARBARA L. LEHMAN, H1W, BY THEIR DEED DATED FEBRUARY 22, 2001. AND ABOUT TO BE RECORDED HEREWITH IN THE OFFICE OF THE RECORDER OF DEEDS OF CUMBERLAND COUNTY, PENNSYLVANIA, GRANTED AND CONVEYED UNTO LINDA S. MATEER AND JESSICA L. MANSBERGER. MORTGAGORS HEREIN. ,~'14<;r;~ - ~~ z - tv ~ -....J ;-,,~ -- .". "" "",."",.'--~. I':>' '-"__', ";'_"'';;;;'0 ,;;,;,-.."."~~',~,- ','. '''L';''''';' I"'. rr]IiIIITr"rill~Ii'r"m'rf~'iili".~,""7r' -- ...J ~ Q, :C9.~ > ':-.. B ~ I ~(f c c.v ..0 ~ Cl'f" R., ~ ";'- , ~ r--f"-:J ~ ~ 0 ~ ~,l)l) b 111 DO <>>1il6) 0 . ~p! ~ ~ ~ ~ ~ =~ t ..~r .. .. " '" ........ .... ...... ...... o c: :s=:.::. ""0 [L' n1p. Z::t.: -~r 65::>- -<:>- g::c ~~~ p~ z: :< .' c.") 1'0 ..." 1"'1 CO 1 C-;'l -_.~ -.-., -- '.,.J ~~: -il~ '-:_~C) co '_._i- ;5r~ "" :6 -< j:"" (;:1 $ .~_I !<;!__~ _ ~...~"'~I';"""";'f<i"'A""".;':T-j"~-'i_'r_",,"_,-,_,,-,~'#""""':-'!~"%j;'!oo"!!1.'l'\'1n"JJ''i!R,j'ilF('''"F''!"''''t1~1!jlj;m~~~~~w, .'- '\'W\""":"'~__" . COUNTRYWIDE HOME LOANS, INC. CUMBERLAND COUNTY Plaintiff, v. COURT OF COMMON PLEAS LINDA S. MATEER JESSICA L. MANSBERGER CIVIL DIVISION NO. 01-6071 CIVIL Defendant(s). AFFIDA VII PURSUANT TO RULE 3129 (Affidavit No. I) ~OUNTRYWIDE HOME LOANS. INC., Plaintiff in the above action, by its attorney, FRANK FEDERMAN, ESQUIRE, sets forth as ofthe date the Praecipe for the Writ of Execution was filed the following information concerning the real property located at .223 RENO STREET. NEW CUMBERLAND. P A 17070 . ]. Name and address ofOwner(s) or reputed Owner(s): Name Last Known Address (if address cannot be reasonably ascertained, please indicate) LINDA S. MATEER 111 LAKE DRIVE MIDDLETOWN, P A 17057 JESSICA L. MANSBERGER 223 RENO STREET ~WClnVDBEFUL}JN1),PA 17070 2. Name and address ofDefendant(s) in the judgment: LINDA S. MATEER 111 LAKE DRIVE MIDDLETOWN, P A 17057 JESSICA L. MANSBERGER 223 RENO STREET ~W ClnVDBEFUL}JN1), P A 17070 3. Name and last known 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 indicate) None. , ~" . 10 , , . 4, Name and address oflast recorded holder of every mortgage of record: Name Last Known Address (if address cannot be reasonably ascertained, please indicate) None, 5, 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 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 Last Known Address (if address cannot be reasonably ascertained, please indicate) None, 7, Name and address of every other person of whom the plaintiff has knowledge who has any interest in the property which may be affected by the sale: Name Last Known Address (if address cannot be reasonably ascertained, please indicate) Tenant/Occupant 223 RENO STREET ~VVClTIVDBEFlLPU\[),PAI7070 Domestic Relations of Cumberland County 13 North Hanover Street Carlisle, P A 17013 Commonwealth of Pennsylvania Department ofVVelfare PO Box 2675 Harrisburg, P A 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, January 21, 2002 DATE q.~ '11 - FRANK FEDERMAN, ESQUIRE Attorney for Plaintiff ,.:'''~'V~:''l!'I''i, < ^ "'"'I 1,'- , ^ ~~ '~iilillffl.g "I'!II'!!I ,~ ~", P'lL,o,,~ "",-= ^.~,"-. ~~" - 00" {':':) 1'--":" --r; ;....." G'.J ~r'-"~~'J."'illliFlnrlI ., ~- .' :.':J!:> ~ ('~! --f ~M :0 -< co ~; < u{}: Q]fT: LC~ ~:~> r-.----; ~....~ ZO ~(J .-~ ~ \D ,;:- CO 4 ",~~lIR"~~~;iI1'll'ffll-~~~""l'ffl~,~_~O"""I""""",,:$'1",""~;~"~~"'V'''-'>.;;';V'0'~rf'''':;""'''-,"'11,*~f'''-c''jI1'f:~"~'i,~"I'''j'f;;;r(~,,,-'\;&"-%€~~~~"=-;"f!,~':,-"~~~' FEDERMAN and PHELAN By: FRANK FEDERMAN Identification No. 12248 ONE PENN CENTER AT SUBURBAN STATION 1617 JOHNF.KENNEDYBLVD., SUITE 1400 PIDLADELPIDA, PA 19103-1814 (215) 563-7000 ATTORNEY FOR PLAINTIFF COUNTRYWIDE HOME LOANS, INe. Plaintiff, CUMBERLAND COUNTY COURT OF COMMON PLEAS v. CIVIL DIVISION LINDA S. MATEER JESSICA L. MANSBERGER NO. 01-6071 CIVIL Defendant(s). 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 ( ) 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. i'/L~l/ FRANK FED AN, ESQUIRE Attorney for Plaintiff :-_-.'i~""'~ ., ." t. --~ - "W~w.JIl ........4J1;\, C) C' C) ~;:: 1"-'.'> --n :";., ,.., -".':I r ~-- m rn (~. ::;-0 -7 "'C ,- '.7r:: " .' ~~;,~-- C) ~C:] ::;;: 1~: -r, ~';-i2 *'1"1 1> -, ..A C.::S :Z;..,~; '-:? {5 m )>c: S z t:"'" :;;1 'jJ Cl ~~ ES eJ( ~(I;l!J",..,....,,.. ~ "",-I!'l~,,",J~,~- ~!!'i!l''''-,-~~"!,,,~~!i1I\l!r~~~*m"~H''-fl\'1'-''_','i'''''''. >'--',,,;[,,,~'WI"';-""'--'~F!ffi'';1)'itr,:;.';-?l''!i!\;lflfjo/~,!.)1-'m-\!>-,~,,;j''}-~~"--!l!QjIl'~f" ~]' ., \ COUNTRYWIDE HOME LOANS, INC. Plaintiff, CUMBERLAND COUNTY '. v. No. 01-6071 CIVIL LINDA S. MATEER JESSICA L. MANSBERGER Defendant(s). January 21, 2002 TO: LINDA S. MATEER 111 LAKE DRIVE MIDDLETOWN, PA 17057 JESSICA L. MANSBERGER 223 RENO STREET NEW CUMBERLAND, PA 17070 "THIS FIRM IS A DEBT COLLECTOR A TTEMPTING TO COLLECT A DEBT AND ANY INFORMA TION OBTAINED WILL BE USED FOR THAT PURPOSE IF YOU HA VE 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, 223 RENO STREET. NEW CUMBERLAND. PA 17070, is scheduled to be sold at the Sheriffs Sale on JUNE 5, 2002 at 10:00 a.m. in the Cumberland County Courthouse, South Hanover Street, Carlisle, P A 17013, to enforce the court judgment of 68,723.95 obtained by COUNTRYWIDE HOME LOANS, INC. (the mortgagee) against you. In the event the sale is continued, an announcement will be made at said sale in compliance with Pa.R.C.P., Rule 3129.3. NOTICE OF OWNER'S RIGHTS YOU MAY BE ABLE TO PREVENT THIS SHERIFF'S SALE To prevent this Sheriffs Sale, you must take immediate action: I. The sale will be cancelled if you pay to 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: (215) 563-7000. 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 attorney.) ~~'~'!lOffll ["_":_~_ --I ',r'" , . , 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 (215) 563-7000. 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 ifthis 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 ofthe 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 may be entitled to a share of the money which was paid for your house. A schedule of distribution ofthe money bid for your house will be filed by the Sheriff within 30 days ofthe 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 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, P A 17013 (717) 249-3166 (800) 990-9108 .,>>~~ . I >. "" " . ~ I -~ ,- , -",. 'r ," - . ~ :e i Property Address: Z2J Reno Slreet. :"lew Cumberland. PA 17070 County: Cumberland Lel!al DescriDtion: ALL THAT CERTAIN TRACT OR PARCEL OF LAND A.ND PREMISES. SITUATE. LYING A8D BEING IN THE BOROUGH OF :"lEW CUMBERLA8D [1'1 THE COUNTY OF CUMBERLA;'lD A;'ID CClMMONWEAL TH OF PENNSYL VA.''lIA. MORE PARTlCULARL Y DESCRIBED AS FOLLOWS: BEGINNING AT A POINT ON THE SOUTHEAST CORNER OF RE:-IO Ai.'1D TAYLOR A VE:-IUE; THE.'ICE SOUTHWARDL Y ALONG SAID RENO STREET 16 112 FEET TO THE DIVIDING LINE OR WALL ON PROPERTY NOW OR LATE OF D.Y. LE;'IfHART; THE:-ICE EASTWARDLY ALONG SAID DIVIDING LL'IE A..'ID AT RIGHT ANGLES WITH RENO STREET l-<<l FEET TO THE LINE OF CEDAR A VEI'ffiE; THE:-ICE NORTHWARDLY ALONG SAID CEDAR A VENUE .-\i.'1D PARALLEL WITH RENO STREET 16 1/2 FEET TO TA YLOR A VENUE: THE.'ICE WESTWARDL Y ALONG THE LINE OF SAID TAYLOR A VENUE 140 FEET TO THE POINT OR PLACE OF BEGINNING. HA VING THEREON ERECTED A FRA;WE DWELLING HOUSE K.'10WN A8D .'1UMBERED .-\S Z2J RENO STREET. BEING THE SAME PREMISES WHICH RIG HARD LEHMAi.'1 Ai.'ID BARBARA L. LEHMAN. H/W, BY THEIR DEED DATED FEBRUARY Z2.2001, AND ABOUT TO BE RECORDED HEREWITH IN THE OFFICE OF THE RECORDER OF DEEDS OF CUMBERLAi.'1D COUNTY, PE;>lNSYLVANIA, GRANTED AND CONVEYED UNTO LINDA S. MATEER Ai.'ID JESSICA L. MANSBERGER. MORTGAGORS HEREIN. i"0'>1J._l",,,,,.~,,,, - "1 - 4~_""M_ ~I_..;%,,-~- ~"~ .'_~, ~..~' '~h~ ~- '",~ C) ~;. < ~~- {~~::-, r---.:::r--' ~'-~ ZC:- ;:;:--(1 Pc Z ::;! liiJlIr~'IlI~lIJn"' II" l o 1'0 ;'j ':ri -" 1"1 eX) I ~~ '--:-t I-~. ~ ~ c> " ]~~ C)fTl '-I ?6 -< co .,- = ES Sf! "g__" .~" " .~W!!!l!l~">lf'!"S~jlll~fflffij;;&r.~!I!l~~~~~,~,~Jl':&1<;~I\'P'if'-"--':;'-J." ,,"' '~""'~--";"'-JY_"'IJ\';r"j!;p"",'WOi~.,i'1~,t'if"i!~F';:'F"'~1;q""m:fl["ljM1l!$t!I~" Countrywide Home Loans, Inc. VS Linda S. Mateer and Jessica L. Mansberger In The Court of Common Pleas of Cumberland County, Pennsylvania Writ No. 2001-6071 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 Surcharge Posting Handbills Law Library Prothonotary Share of Bills Mileage Levy Out of County Dauphin County Advertising Certified Mail Poundage Law Journal Patriot News 30.00 30.00 .50 1.00 11.04 15.00 9.00 29.25 2.52 $128.31 paid by attorney 3-18-02 Sworn and subscribed to before me So ~ This .2o~ day of ~ ~ ';l"AI~''':;J-<:'~~ ('/A < R. Thomas Kline, S.heriff 2002, A.D.~. r1. ~. ~ __ ! . B~rl..l !~ lrn-d-b-, Prothonotary Real Est!te Deputy /,61[) Ve. 35'941 L. /13&'1/ --'>P;:''''"'<<>-O'''''''''''~"'''';Jl!:~""", "'V""; !l "1"'" "~ . ~ - '"''''''''~~''''''~'''''-=' ... COUNTRYWIDE HOME LOANS, INC. CUMBERLAND COUNTY Plaintiff, v. COURT OF COMMON PLEAS LINDA S. MATEER JESSICA L. MANSBERGER CIVIL DIVISION NO. 01-6071 CIVIL Defendant(s). AFFIDAVIT PURSUANT TO RULE 3129 (Affidavit No.1) COUNTRYWIDE HOME LOANS, INC., 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 ,223 RENO STREET, NEW CUMBERLAND, P A 17070 . 1. Name and address of Owner(s) or reputed Owner(s): Name Last Known Address (if address cannot be reasonably ascertained, please indicate) LINDA S. MATEER III LAKE DRIVE MIDDLETOWN, P A 17057 JESSICA 1. MANSBERGER 223 RENO STREET NEW CUMBERLAND, P A 17070 2. Name and address ofDefendant(s) in the judgment: LINDA S. MATEER III LAKE DRIVE MIDDLETOWN, P A 17057 JESSICA 1. MANSBERGER 223 RENO STREET NEW CUMBERLAND, P A 17070 3. Name and last known 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 indicate) None. "~"" ,. ~1"~ .' '1, "'" , 4. Name and address of last recorded holder of every mortgage of record: Name Last Known Address (if address cannot be reasonably ascertained, please indicate) None. 5. 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 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 Last Known Address (if address cannot be reasonably ascertained, please indicate) None. 7. Name and address of every other person of whom the plaintiff has knowledge who has any interest in the property which may be affected by the sale: Name Last Known Address (if address cannot be reasonably ascertained, please indicate) Tenant/Occupant 223 RENO STREET NEW CUMBERLAND, P A 17070 Domestic Relations of Cumberland County 13 North Hanover Street Carlisle, PA 17013 Commonwealth of Pennsylvania Department of Welfare PO Box 2675 Harrisburg, PAl 71 05 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 ofl8 Pa. C.S. Sec. 4904 relating to unsworn falsification to authorities. January 2 L 2002 DATE 1- --.J; "-\ ~l FRANK FEDERMAN, ESQUIRE Attorney for Plaintiff A-;Jl';~'@.j~:<J>'t~t'~"" -- ~- ,. - _"" '"'~T_ '''- I ". _~ '. , ~ t . . COUNTRYWIDE HOME LOANS, INC. Plaintiff, CUMBERLAND COUNTY v. No. 01-6071 CIVIL LINDA S. MATEER JESSICA L. MANSBERGER Defendant(s). January 21,2002 TO: LINDA S. MATEER 111 LAKE DRIVE MIDDLETOWN, PA 17057 JESSICA L. MANSBERGER 223 RENO STREET NEW CUMBERLAND, P A 17070 "THIS FIRM IS A DEBT COLLECTOR ATTEMPTING TO COLLECT A DEBT AND ANY INFORM A TION OBTAINED WILL BE USED FOR THAT PURPOSE. IF YOU HA VE 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, 223 RENO STREET, NEW CUMBERLAND, PA 17070, is scheduled to be sold at the Sheriff's Sale on JUNE 5, 2002 at 10:00 a.m. in the Cumberland County Courthouse, South Hanover Street, Carlisle, P A 17013, to enforce the court judgment of 68,723.95 obtained by COUNTRYWIDE HOME LOANS, INC. (the mortgagee) against you. In the event the sale is continued, an announcement will be made at said sale in compliance with Pa.R.C.P., Rule 3129.3. NOTICE OF OWNER'S RIGHTS YOU MAYBE 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 attorney's fees due. To find out how much you must pay, you may call: (215) 563-7000. 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 attorney.) '",,:<::"I_--~ ~- "' ."., . I" 1 ~. YOU MAY STILL BE ABLE TO SAVE YOUR PROPERTY AND YOU HAVE OTHER RIGHTS EVEN IF THE SHERIFF'S SALE DOES TAKE PLACE. I. If the Sheriffs Sale is not stopped, your property will be sold to the highest bidder. You may find out the price bid by calling (215) 563-7000. 2. You may be able to petition the Court to set aside the sale ifthe 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 may be entitled to a share of the money which was paid for your house. A schedule of distribution of the money bid for your house will be filed by the Sheriff within 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 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 <"-;'<''''f''''''''''';,_ ~I - Property Address: 223 Reno Street.. :'Iew Cumberland. PA [7070 County: Cumberland L<I!al DescriDtion: ALL THAT CERTAIN TRACT OR PARCEL OF LAc'lD .-\1'1D PREMISES, SITUATE, LYING AND BEING IN THE BOROUGH OF :'IEW CUMBERLAND IN THE COUNTY OF CUMBERLAND .-\ND CaMMO~IWEAL TH OF PENNSYL VA,'1IA, .MORE PARTlCULARL Y DESCRIBED AS FOLLOWS: BEGINNING AT A POINT ON THE SOUTHEAST COR..'1ER OF RE:'IO AND TA YLOR A VE:'IUE; THE:'fCE SOUTHWARDLY ALONG SAID RENO STREET 16 1/2 FEET TO THE DIVIDING LINE OR WALL ON PROPERTY :'lOW OR LATE OF D. Y. LE:'IHART; THE:'ICE EASTWARDLY ALONG SAID DIVIDI;>IG LL'IE .-\1'fD AT RIGHT ANGLES WITH RE;-lO STREET [-10 FEET TO THE LINE OF CEDAR A VENUE; THENCE :'!ORTHWARDL Y ALONG SAID CEDAR A VENUE ,-\1'1D PAR.-\LLEL WITH RENO STREET \6 [/2 FEET TO TAYLOR A VENUE; THENCE WESTWARDL Y ALONG THE LINE OF SAID TA YLOR A VENUE \-10 FEET TO THE POINT OR PLACE OF BEGINNING. HA VING THEREON ERECTED A FRAME DWELLING HOUSE J(,'10WN AND :'lUMBERED AS 223 RENO STREET. BEING THE SAME PREMISES WHICH RIG HARD LEHMAc'f Ac'ID BARBARA L. LEHMAN, HIW, BY THEIR DEED DATED FEBRUARY 22, 2001, AND ABOUT TO BE RECORDED HEREWITH [1'1 THE OFFICE OF THE RECORDER OF DEEDS OF CUMBERLAJ'ID COUNTY, PENNSYLVANIA, GRAi'lTED AJ'fD CONVEYED UNTO LINDA S. MATEER Ac'ID JESSICA L. MANSBERGER. MORTGAGORS HEREIN. ",-~, t-,. 'I.. , , , """F"7"'"""""""''''''>1~0I>_r'''' . WRIT OF EXJ<;GUTION and/or ATTACHMENT COMMONWEALTH OF PENNSYLVANIA) COUNTY OF CUMBERLAND) NO 01-6071 Civil CIVIL ACTION - LAW TO THE SHERIFF OF CUMBERLAND COUNTY: To satisfy the debt, interest and costs dne COUNTRYWIDE HOME LOANS, INC., PLANTIFFCS) From LINDA S. MATEER, 111 LAKE DRIVE MIDDLETOWN, P A 17057 AND JESSICA L. MANSBERGER, 223 RENO STREET, NEW CUMBERLAND, PA 17070 Cl) You are directed to levy upon the property of the defendantCs) and to sell SEE LEGAL DESCRIPTION (2) You are also directed to attach the property of the defendantCs) not levied upon in the possession of GARNISHEECS) as follows: and to notify the garnisheeCs) that: Ca) an attachment has been issned; Cb) the garnisheeCs) is enjoined from paying any debt to or for the account of the defendant Cs) and from delivering any property of the defendant C s) or otherwise disposing thereof; (3) Ifproperty of the defendantCs) not levied upon an subject to attachment is found in the possession of anyone other than a named garnishee, you are directed to notify him/her that he/she has been added as a garnishee and is enjoined as above stated. Amount Due $68, 723.95 L.L. $.50 Interest FROM 1/22/02 TO 6/5/02 CPER DIEM - 11.30) $1,514.20 AND COSTS Atty's Comm % Due Prothy $1.00 Atty Paid $231.55 Other Costs Plaintiffpaid Date: FEBRUARY 4, 2002 CURTIS R. LONG Prothonotary, Civil Division ~: ~~D,Q 7p~~ REQUESTING PARTY: Name FRANK FEDERMAN, ESQffiRE Address: ONE PENN CENTER AT SUBURBAN STATION 1617 JOHN F. KENNEDY BOULEVARD, SffiTE 1400 PHILADELPIDA, PA 19103-1814 Attorney for: PLAINTIFF Telephone: 215-563-7000 Supreme Court ID No. 12248 ~-~-~,-, -, - .~- ..~ " ~~. ~ - .-- .." -. ". '_.W... ""'.' .~, ,,,'.. '. '-- '" '-""'''1i.~._' ur ".' ITIlJriIUf"''''jnli? REAL ESTATE SALE No. I ~ On February 7,2002, the sherifflevied upon the defendant's interest in the real property situated in New Cumberland Borough, Cumberland County, PA, known and numbered as 223 Reno street, New Cumberland, and more fully described on Exhibit "A" filed with this writ and by this reference incorporated herein. Date: February 7,2002 By: .JULM jvvu:hk Real Estate Deputy ___'-\ 0\3(\ ,'\ \ '--','0' . , ~. \:~ -.- v" \ \\ >._~ ' \ ';;' -'" \\ \ 'n'n ~ "'ilt ,,,,,: t \j\ \' ;~~i~~; c:: ~-;\ ,r\'J ""'11) ;.."...\,\: :\0 ).! .'" ~ p.,5 g' c:u:il c;ryl ~ ~ ~ '~_~~JIIIl!l. U;~I'""""'"':tI~UJjl!llilIIil!!l'ilfjMmiilJ!li~~11lJ.TjW1f'!if':!II!';w;".,~~t"',1~_",w""[-"rr.,'W<"v,,'11,"""0~"(!I'''","1'!'1_SjfHift(!If(lJ$J'fY-'l';-''''''o''", -'''' " - v-,,,,~,,.'!'J"_''''\'^-'-'''W-_\I.-,1'}'f"'''\'''''i1>i>9;'j'f;t;f.'''!~~~"'~r;-