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Home My WebLink About01-06189 , PRAECIPE FOR WRIT OF EXECUTION - (MORTGAGE FORECLOSURE) P.R.C.P. 3180-3183 COUNTRYWIDE HOME LOANS, INC. F/KIA AMERICA'S WHOLESALE LENDER Plaintiff, v. No. 01-6189 JOSEPH R. BARRETT BARBARA T. BARRETT Defendant(s). TO THE DIRECTOR OF THE OFFICE OF THE PROTHONOTARY: Issue writ of execution in the above matter: Amount Due $48,417.57 v/ Interest from 12/6/01 to 3/6/02 (per diem -8.11) $971.10 and Costs TOTAL $49,388.67 ~~u~ FRANK FEDE , ESQUIRE One Peun 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. "~r_~'" ~,"!'~ " -, " 1 , ,~~~-, - '~,'~ ,~ ~"' '_~"'----o>' ~~ >, ,_",,,,_,,,,,,,"'~'~~'''"'''' ---o~-"""' -=. '""'"' ~.""",~""""""",,,-,,,, - ~.~' '';''''''",^'' <d' ''''''''-J11~ ~ trl N 0 r-- .... ...~ ~ z ~ OZ .'" <' oo~ U~ 0 ZZ ... ...:i <...:i ... 0 "'~ ...", ;;l ~oo ..,r...:i U Z .,j ...... 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Of HART:Y1A.'i A:'<"D .~SSOCIATE . 1:'iC.. EClGINEERS ......'1D SURVEYORS. D.-\TED .n::-Ilc 6, 1994. / BEGINNING AT A POI:-iT IN THE :'IORTHER.'1 LINE Of LAND NOW Of F~LY OR LA\VRE:'iCE T. JOYCE ..H ITS INTERSECTION WITH THE EASTER. "I LINE Of LAND NOW OR FOR....IERL Y Of NORA A:'iN FR.-\KER: THE:'ICE NORTH 2S DEGREES 21 ML'IUTES S8 SECONDS EAST, ALONG SAID LINE Of FR.-\KER L..>....'1DS 190 FEET TO A POINT; THE:>ICE SOUTH 75 DEGREES 36 MINUTES 25 SECONDS EAST ~I.38 FEET TO .-\ POL.....T IN THE SOUTHWEST PORTION OF A PRIVATE ROAD; THENCE SOUTH 13 DEGREES 05 MINUTES 01 SECONDS EAST. A DIST.-\NCE Of 185 FEET To A PIPE L'I THE :"10RTHER.'1LlNE Of LAND .'10W OR FOR....IERL Y OF DAISY Z. SAMPSON; THE:"1CE NORT\-{ 77 DEGREES 38 ;.IINl.'TES 31 SECONDS WEST, ~::.UO FEET TO A:'IIRON PI;,! c'l THE EAST~INE OF LAND 'lOW OR FORMERLY OF LA WRE;-ICE T. JOYCE .-\FORESAID; THE:>ICE :>IORTH 78 DEGREES J~INUTES 03 ~ECONDS WEST, ALONG SAID LINE Of JOYCE LA:>IDS 138.9:: FEET TO A POIl'iT, THE /PLACE OF BEGfNNING. _.:====-=-~ Tax PareelID '*: 10-12-2987-003 F~~'!IlI!flI". t_~Il!''llj.,~ " ~~ "1"<"'0 - N ~ , ........ \!l~~ ~ \ "'f" .~ ~ '. ^-,--',"'^,>....~.--~,.~'". ~' '~-o'~ ~ ~Do ~' ;:F'~ . , :.:)rJ.~ ;;:['-" VJ~'" '" ; ~~~: ~ ~. t)'. ~ -{::-. ~.~ . 0,\ ~~ ~t'~ :J' ;~'" ~~-~~~ ' co = TI .., ---< """'[ . ~ ", . Es B4 .j~!~IL. .- _~'W!lili'smt',-t!~ ~1l<'I!i!'";jf"~.;iM"j'f!'-""'''''_.,..'''',W,';,,'-''' :'1'):;;0);'''''' " ~'O'~;'\1"'-"" "~,,--,",:, j"',"f."'-.if~~JN"i"1~'!'>"~j""P<tf"J,ii"i~;;?Wo><,r~~~"'8ifif~~Z .~v ,:,:--1 r" '" 'FEDERMAN AND PHELAN By: FRANKFEDERMAN Identification No. 12248 Attorney for Plaintiff ONE PENN CENTER AT SUBURBAN STATION 1617 JOHN F. KENNEDY BLVD., SUITE 1400 PHILADELPHIA, PA 19103-1814 (215) 563-7000 COUNTRYWIDE HOME LOANS, INe. FIKIA AMERICA'S WHOLESALE LENDER 7105 CORPORATE DRIVE PLANO, TX 75024-3632 CUMBERLAND COUNTY COURT OF COMMON PLEAS CIVIL DIVISION Plaintiff, v. NO. 01-6189 JOSEPH R. BARRETT BARBARAT.BARRETT Defendant(s). PRAECIPE FOR JUDGMENT FOR FAILURE TO ANSWER AND ASSESSMENT OF DAMAGES TO THE PROTHONOTARY: Kindly enter judgment in favor of the Plaintiff and against JOSEPH R. BARRETT and BARBARA T. BARRETT, 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 10/1/01 to 12/6/01 TOTAL $47,694.64 $722.93 $48,417.57 I hereby certify that (I) the addresses of the Plaintiff and Defendant(s) are as shown above, and (2)"" "otico "" b= ~'OO i. ~dooco wilh Ru~ U L FRANK FEDERMAN, ESQUIRE Attorney for Plaintiff DAMAGES ARE HEREBY ASSESSED AS INDICATE DATE: 1;),- f {- ()( o~ "CiW!'."... , ") r, , ~, ",. ',-,,,,,"' ~~ (Rule of Civil Procedure No. 236) - Revised IN THE COURT OF COMMON PLEAS OF CUMBERLAND COUNTY, PENNSYLVANIA CIVIL ACTION - LAW COUNTRYWIDE HOME LOANS, INC. F/KIA AMERICA'S WHOLESALE LENDER 7105 CORPORATE DRIVE CUMBERLAND COUNTY COURT OF COMMON PLEAS CIVIL DIVISION Plaintiff, v. NO. 01-6189 JOSEPH R. BARRETT BARBARA T. BARRETT Defendant(s). Notice is given that a Judgment in the above-captioned matter has been entered against you on I J /~ tI 2001. By: If you have any questions concerning this matter, please contact: FRANK FEDERMAN. ESQUIRE Attorney for Plaintiff ONE PENN CENTER AT SUBURBAN STATION 1617 JOHN F. KENNEDY BL YD., 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 HA VE PREVIOUSLY RECEIVED A DISCHARGE IN BANKRUPTCY AND TillS DEBT WAS NOT REAFFIRMED, TillS CORRESPONDENCENDENCE IS NOT AND SHOULD NOT BE CONSTRUED TO BE AN ATTEMPT TO COLLECT A DEBT, BUT ONLY ENFORCEMENT OF A LIEN AGAINST PROPERTY." , '- ~ , ~ < ~ , ,~ -~ I ~, , , r ~1- MI, M' " , " ,~~ " ".""",,,,<>W"-'''' '<'> "'''' "'"' "''',--l'' ",,"~' "'~.~~~,""'''' o s-:: ,- <:'It~j rTlf";'! ;';::T1 ~!~-, ~:~:< ~~;~ 2:, -:;: llrnri'iTIl .., ,.., ~"'-' c~ -T1 f~~ CJ- 'v ~ h) '.-; -:.:.!. "iJ '-<. :un l". ~Lrft_~",-"",,,.,..,,~lJl'Jf~,,,,,!''''''''I'~''~\'f;:;ry..'..)EW'''''''i-'''''''''l'i'",~:""'(;"'-''0,1[ """-i""H,'iW!~l'iI'_~~~',1JJ~~:pMl~~7.\~_.@I_~ FEDERMAN AND PHELAN Frank Federman, Esquire Identification No. 12248 One Penn Center Plaza at Suburban Station, Suite 1400 Philadelphia, PA 19103-1799 . (2l5) 563-7000 ATTORNEY FOR PLAINTIFF COURT OF COMMON PLEAS COUNTRYWIDE HOME LOANS, INC. F/K/A AMERICA'S WHOLESALE LENDER Plaintiff CIVIL DIVISION CUMBERLAND COUNTY vs. NO.01-6189 CIVIL JOSEPH R. BARRETT BARBARA T. BARRETT Defendant TO: BARBARA T. BARRETT 1654 HOLTZ ROAD ENOLA,PA 17025 ~f DATE ::1:0::::: I:O:~:: ::~L::::R ATTE~~~TO COLLECT A DEBT. THIS NOTICE IS SENT TO YOU IN AN ATTEMPT TO COLLECT THE INDEBTEDNESS REFERRED TO HEREIN, AND ANY INFORMATION OBTAINED FROM YOU WILL BE USED FOR THAT PURPOSE. IF YOU HAVE PREVIOUSLY RECEIVED A DISCHARGE IN BANKRUPTCY, THIS CORRESPONDENCE IS NOT AND SHOULD NOT BE CONSTRUED TO BE AN ATTEMPT TO COLLECT A DEBT, BUT ONLY AS ENFORCEMENT OF LIEN AGAINST PROPERTY. IMPORTANT NOTICE You are in default because you have failed enter a written appearance personally or by attorney and file in writing with the court your defenses or objections to the claims set forth against you. Unless you act within ten (10) days from the date of this notice, a Judgment may be entered against you without a hearing and you may lose your property or other important rights. You should take this notice to a lawyer at once. If you do not have a lawyer or cannot afford one, go to or telephone the following office to find out where you can get legal help: CUMBERLAND COUNTY CUMBERLAND COUNTY BAR ASSOCIATION 2 LIBERTY AVENUE CARLISLE, P A 17013 (717)249-3166 -]~y~ / Frank Federman,Esquire Attorney for Plaintiff ""'-"l\'''f'll , ,~ ~ " ~' , " ,~ ~. FEDERMAN AND PHELAN, L.L.P. Frank Federman, Esquire Identification No. 12248 One Penn Center Plaza at suburban Station, Suite 1400 Philadelphia, PA 19103-1799 (215) 563-7000 ATTORNEY FOR PLAINTIFF COURT OF COMMON PLEAS COUNTRYWIDE HOME LOANS, INC. F/K/A AMERICA'S WHOLESALE LENDER plaintiff CIVIL DIVISION CUMBERLAND COUNTY vs. NO. 01-6189 CIVIL JOSEPH R. BARRETT BARBARA T. BARRETT Defendant(s) TO: JOSEPH R. BARRETT 1654 HOLTZ ROAD ENOLA,PA 17025 DATE OF NOTICE: NOVEMBER 21. 2001 THIS FIRM IS A DEBT COLLECTOR ATTE TO COLLECT A DEBT. THIS NOTICE IS SENT TO YOU IN AN TO COLLECT THE INDEBTEDNESS REFERRED TO HEREIN, INFORMATION OBTAINED FROM YOU WILL BE USED FOR THAT PURP E OU HAVE PREVIOUSLY RECEIVED A DISCHARGE IN BAN ~~, THIS CORRESPONDENCE IS NOT AND SHOULD NOT BE ONBTRUED 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, P A 17013 (717) 249-3166 J_/)~/~ Frank Federman, Esquire Attorney for Plaintiff "8f.~WJ ~ ".-" ,"" ' I' '~ . ~ '*'l,_ " FEDERMAN and PHELAN By: FRANK FEDERMAN Identification No. 12248 ONE PENN CENTER AT SUBURBAN STATION 1617 JOHN }'. KENNEDY BLVD., SUITE 1400 PHILADELPHIA, P A 19103-1814 (215) 563-7000 COUNTRYWIDE HOME LOANS, INC. FfK/A AMERICA'S WHOLESALE LENDER 7105 CORPORATE DRIVE Plaintiff, v. JOSEPH R. BARRETT BARBARA T. BARRETT Defendant(s). ATTORNEY FOR PLAINTIFF CUMBERLAND COUNTY COURT OF COMMON PLEAS CIVIL DIVISION NO. 01-6189 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 JOSEPH R. BARRETT is over 18 years of age and resides at , 1654 HOLTZ ROAD, ENOLA, PA 17025. (c) that defendant BARBARA T. BARRETT is over 18 years of age, and resides at , 1654 HOLTZ ROAD, ENOLA, PA 17025. This statement is made subject to the penalties of 18 Pa. C.S. Section 4904 relating to unsworn falsification to authorities. ~- -~ " -~"'I ~ 1 4~~~ FRANK FEDERMAN, ESQUIRE Attorney for Plaintiff ~""-'" v" '~ -.-j" "- ' ' ,- , ~"" -""--', ,. '.- . -"-' ~ '"' ,~ ~<. < ~ ~ ~-R -- 'l'r- -- ~ @D~ ~ ......! ~ 0' ~ f , ~ ~ y r\) 0 C~; r'" ~:::: ~;:,.. r--::l ---, 'U CU tq en Lr' c') -- Z : - :::-:~ [' - en ~. ~,; ~, -~--' ~ ".U C) ._.tOo J; CJ Sy c::: -:;.' ""- ,- ::;! I " =-q -< ~5 6H :ill~ 1 ~, ~'_~ ,1"", _~~ ,~~~l "'.," '" '", }l'\"", '~,', ,r. ,_ .,~~jjj~'-'~J!;l~~, ~ , _H~fWttl!"o/..#~~v-,r!'';!<ilJfi'-,<"",,\+:~,'"qJ''r0'-;;~''i;';''{'.Ml'l')1!j~~~~ll'1)Ji\jijl~%i~~~ .~ J" r ~ ep,. l ^. COUNTRYWIDE HOME LOANS, INC. FIK/A AMERICA'S WHOLESALE LENDER CUMBERLAND COUNTY Plaintiff, COURT OF COMMON PLEAS v. CIVIL DIVISION JOSEPH R. BARRETT BARBARA T. BARRETT NO. 01-6189 Defendant(s). AFFIDAVIT PURSUANT TO RULE 3129 (Affidavit No.1) COUNTRYWIDE HOME LOANS, INC. F/K1A AMERICA'S WHOLESALE LENDER, 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, 1654 HOLTZ ROAD, ENOL^, FA 17025. 1. Name and address ofOwner(s) orreputed Owner(s): Name Last Known Address (if address cannot be reasonably ascertained, please indicate) JOSEPH R. BARRETT 1654 HOLTZ ROAD ENOLA, PA 17025 BARBARA T. BARRETT 1654 HOLTZ ROAD ENOLA, P A 17025 2. Name and address ofDefendant(s) in the judgment: JOSEPH R. BARRETT 1654 HOLTZ ROAD ENOLA, P A 17025 BARBARAT.BARRETT 1654 HOLTZ ROAD ENOLA, PA 17025 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. "io,'-lij'~,J__, __"'''' " '--' - I" j, --~ ~ " I'.~'_ llif " .I. 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) HOUSEHOLD REALITY CORPORATION TO BE DETERMINED 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 1654 HOLTZ ROAD ENOLA, P A 17025 Domestic Relations of Cumberland County 13 North Hanover Street Carlisle, P A 17013 Commonwealth of Pennsylvania Department of Welfare PO Box 2675 Harrisburg, P A 171 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. December 6. 2001 DATE ~J1~ FRANK FEDERMAN, ESQUIRE Attorney for Plaintiff ',-'--%W-'.'~,~-" "', ~,'''' r" "1' "-~'"'-- 1 "1 ~~ . "e...- J'h ;. _1 "I.., L![IIUW.~W '''''~_,' ,_mTI~~~t,[1~H~'2q, 'N~ . ^-,~ ^"r,~"",~,,,'-;" ;-,<-'"-' ,t"",'''' -,,," '~"-"i'-~'''''''f:''"~' :,:~~'l~"r '" l!J'1{,im'~c~:5t!'{;;]X;'f{~t[ > . 0 0 c '. l-:-::J ___J 'i:; C"] "~-'I n'j L~~' ,-"") -,; .-<.- [':' ~ij -.- ~:2 ~:~' r- C~' ~TJ ~% :,-".. () ..k ;.: C) :,,) ., c: 2.':: ~. ~1'_' -< p..J :'c>:J -c":; f::. ~ (31+ I ~.. ~_" Jl",~_~,.._l1~~~~-!'M'N"",'ir"i';m'L'_;'-t''''Ir;%"",:,~""~,~",,,~"~Ji'~"~~i':"~_~~,mfil)(\N;I,"fl![!~U~!f1~~~llt, F,EDE~andPHELAN By: FRANK FEDERMAN Identification No. 12248 ONE PENN CENTER AT SUBURBAN STATION 1617 JOHN F. KENNEDY BLVD., smTE 1400 PIDLADELPIDA,PA 19103-1814 (215) 563-7000 ATTORNEY FOR PLAINTIFF COUNTRYWIDE HOME LOANS, INC. F/K/A AMERICA'S WHOLESALE LENDER CUMBERLAND COUNTY COURT OF COMMON PLEAS Plaintiff, v. CIVIL DIVISION JOSEPH R. BARRETT BARBARA T. BARRETT NO. 01-6189 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: o 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. j-~/ F FEDERMAN, ESQUIRE Attorney for Plaintiff """':'-:;~'?~'~-" ~,,:' ~ ",~',," t" ')' ,'" l,-' - ,~. .e'"'". q~ ,~ 1.!lfI.m1li. .~ 4,., ",' ,,'-"" ,.",c,._",__, ""<"-"~'-""_",..M~""'"" 3"o'~" ,~ ~".. .'",..~.."." ."". f'l"""1lI1l 0 Cf ,.~-. C .~ ,~ ~~: C:J rll ;':~:~ ,-'1 :?~ ~';'~; '---) c- U) ~< .'---. r-:: ,. ~'~~ ,-V , ::r;: ,;:; r-', )> r-~ :',,) >=-; ;2 ~- ~ :< .0 :-,0 ""'( . _" .' ,. " ,,' ~ ~_~ _ 'l' _li!~"!''!!l\ll1m1't\~<'Ilil'i!!:1~~''K~f*ji~~.;::ii!H'"~''':lt\':-'''!(i'''''-'W''''-0;i'.1te,\:;,t:~i!\jj!'if'''!J'~jl_''Wli,.'1t11i",-~J~''!ffi.'1'R~)t!Jijjii'?\'ii'{;~~'~~'~ . ~ .~. COUNTRYWIDE HOME LOANS, INC. FIKIA AMERICA'S WHOLESALE LENDER Plaintiff, CUMBERLAND COUNTY No. 01-6189 v. JOSEPH R. BARRETT BARBARAT.BARRETT Defendant(s). December 6, 2001 TO: JOSEPH R. BARRETT 1654 HOLTZ ROAD ENOLA, PA 17025 BARBARA T. BARRETT 1654 HOLTZ ROAD ENOLA, PA 17025 **THIS FIRM IS A DEBT COLLECTOR A TTEMPTING TO COLLECT A DEBT AND ANY INFORMATION OBTAINED WILL BE USED FOR THAT PURPOSE. IF YOU HAVE PREVIOUSLY RECEIVED A DISCHARGE IN BANKRUPTCY AND THIS DEBT WAS NOT REAFFIRMED, THIS IS NOT AND SHOULD NOT BE CONSTRUED TO BE AN ATTEMPT TO COLLECT A DEBT, BUT ONLY ENFORCEMENT OF A LIEN AGAINST PROPERTY. ** Your house (real estate) at, 1654 HOLTZ ROAD, ENOLA, PA 17025, is scheduled to be sold at the Sheriffs Sale on MARCH 6,2002 at 10:00 a.m. in the Cumberland County Courthouse, South Hanover Street, Carlisle, PA 17013, to enforce the court judgment of 48,417.57 obtained by COUNTRYWIDE HOME LOANS, INC. F/K/A AMERICA'S WHOLESALE LENDER (the mortgagee) against you. If the Sheriffs sale is postponed, the property will be relisted for the JUNE 5, 2002 Sheriffs Sale. NOTICE OF OWNER'S RIGHTS YOU MAYBE ABLE TO PREVENT THIS SHERIFF'S SALE To prevent this Sheriffs Sale, you must take immediate action: 1. The sale will be cancelled if you pay to the mortgagee the back payments, late 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.) <:;;'-";17),_ , ~,""'"'.-~ " ~~~~, r$ " '^ - 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 Sheriff's 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 ifthe 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 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, PAl 7013 (717) 249-3166 (800) 990-9108 "JtHir~:,>>""".,",,__p,,_~___~ ,07. .. ,,'- ",~-, ,~, I" . ",' ~..J!i;' -- . ~ -~ ----==------============--~=======================================================~============== // ALL TH.-\T CERTAIN TR-\CT OR P...RCEL 01' LA.'iD SITLATE rN THE TO\":'iSHIP 9l H.-\)[PDE.'i. C.OL'in 01' CV"IBERLA:'lD .-\;-.ID COM 1.10 i'iWEA l TH 01' PE:-INSYL V A:-I I..... V10RE P....RTlCLr...(RL Y 80L'IDED ....'iD DESCRlBED>.CCORDI;-.IC TO St:RliEY PlX'i 01' HART:'<L"':-; A:'iD .-\SSOC1....TE~i:-ic.. ENGI'iEER5-\.'iD SCRVEYORS. DATED Jt:~I". 6. 1994. / / BEGINNI:'iG AT A POINT IN THE '10RTHER'l LINE 01' lA:-ID :'iOW 01' F~lY OR UWRE'ICE T. .JOYCEH ITS INTERSECTION WITH THE EASTER 'I LI:-<E Of lA:-<D 'lOW OR FOR."ERl YOI' '10R.-\ A:'i:'i" FRAKER: THE:-ICE :'IORTH 25 DEGRf.ES:l :'tIL"LTES 58 SECONDS EAST. ALONG SAlD U:'iE OF FR...KER lA.'1DS 190 FEET TO A POli'iT; THE:'iCE SOt;TH '75 DEGREES 36 ML"'f!iTES 25 SECONDS EAST -141.38 FEET TO A POl"T [N THE SOl'1'HWEST PORTION OF A PRIVATE ROAD; THE:'iCE SOCTH l3 DEGREES 1)5 vlINLTES III SECONDS EAST.'" DISTANCE 01' 185 FEET TO... PIPE IN THE :-IORTHER.'1 LINE 01' LAND .'10W OR F01V,IERL YOI' DAISY Z. SAMPSON: THE:-ICE 'iORTH 7i DEGREES 38 vllNLTES 31 SECONDS WEST. 4:4.10 FEET TO A.'l IRON Pl."'" E'i THE EAST~INE OF LA.'1D'IOW OR FORMERLY 01' lA WRE:'iCE T. JOYCE AFORESAID: THE:-ICE 'iORTH 78 I D..eGREES 3~INt;TES OJ 'iECONDS WEST. ALONG SAID LINE 01' JOYCE U:-IDS 138.9: FEET TO A PO ['IT, THE /PLAC'E 01' BEGF'IN1;'1G. L~"J1 Oesc:-iorion: Tax ParcellD #: 10-1:-:987-003 ''''''''-T,W" ="'" 1-' .. ,-,- " -" ,,.= n -.--.. <<<-, W"~ __,,,_~,<,,,,_ ~JT' ..-"",.,.~,~~ ~.. ~_ c --,-- l~--'" --, "r 'G",>",,""'~__'.'___ '\fIJ@.,,~ J!l1j,-m:!t~~_~!WM1l!'}Y<+'';'la'''-!'''''; ~<".-~,,"'-'~"-~~~~"-"<= ,-~~"'~ () f; i}~?:: -;..> ". L:-~l- ~O-- -, .., ~~2 ? ~ ~ '-:-:1 --'1 ., j cJ -.ii~ -:.0 .C'~ f0 M__~~'-" ,. .,' C;~ 'I" ,-:;- ~ ::'0 -~ E"s (34 .. FEDERMAN AND PHELAN, LLP By: FRANK FEDERMAN, ESQUIRE IDENTIFICATION NO. 12248 ONE PENN CENTER AT SUBURBAN STATION 1617 JOHN F. KENNEDY BOULEY ARD SUITE 1400 PHILADELPHIA, PA 19103-1814 (215) 563-7000 COUNTRYWIDE HOME LOANS, INC. F/KIA AMERICA'S WHOLESALE LENDER 7105 CORPORATE DRIVE PLANO, TX 75024-3632 ATTORNEY FOR PLAINTIFF COURT OF COMMON PLEAS CNIL DNISION TERM Plaintiff NO. 01 -t./Pr Cju~L ~€/l..~ v. CUMBERLAND COUNTY JOSEPH R. BARRETT BARBARA T. BARRETT 1654 HOLTZ ROAD ENOLA, P A. 17025 Defendant( s) CIVIL ACTION - LAW COMPLAINT IN MORTGAGE FORECLOSURE NOTICE **TillS 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 TillS PAPER TO YOUR LAWYER AT ONCE. IF YOU DO NOT HA YE 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 YENUE CARLISLE, PA 17013 (717) 249-3166 Loan #: 4373649 -"~~l1~i~!n. ,,~" ~, ,,1--- ^""'" ~ ; 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. EYEN 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. "-,,:,~j!'t1-_ ---~~ '" 1. Plaintiff is COUNTRYWIDE HOME LOANS, INC. F/KIA AMERICA'S WHOLESALE LENDER 7105 CORPORATE DRIVE PLANO, TX 75024-3632 2. The name(s) and last known addressees) ofthe Defendant(s) are: JOSEPH R. BARRETT BARBARA T. BARRETT 1654 HOLTZ ROAD ENOLA, P A. 17025 who is/are the mortgagor(s) and real owner(s) of the property hereinafter described. 3. On 5/31/95 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. 1266, Page 41. 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 6/1/01 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." 7-:~\.Uii!~"J _ -"1'- - 1 - . - ~"_...III!' 6. The following amounts are due on the mortgage: Principal Balance Ioterest 5/1/01 through 10/1/01 (Per Diem $10.79) Attorney's Fees Cumulative Late Charges 5/31/95 to 10/1/01 Cost of Suit and Title Search Subtotal $44,373.73 1,661.66 1,000.00 125.80 550.00 $47,711.19 Escrow Credit Deficit Subtotal TOTAL 16.55 0.00 ($ 16.55) $47,694.64 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 .8. 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 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 $47,694.64, together with interest from 10/1/01 at the rate of$10.79 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. ~M/U<4 Isl Frank Federman FRANK FEDERMAN, ESQUIRE Attorney for Plaintiff '-~~fl!m~ ,_ ~. '" ,~'" IICountlYWideo HOME LOANS Send Correspondence to; P.O. Box 1CJ221 Van Nuys, CA 91410--0221 Send Paymenls to; P.O, 80)(660694 Dallas, TX 75266-0694 CertWlad Mall No. Return Receipt Requested Regular Mati C cq August 24, 2001 Joseph A Barrett 1654 Holtz Road Enola. PA 17025-0000 Accaunt No.: 4373649 Property Address: 1654 Holtz Road Enola, PA 17025-0000 Current Servlcer: Countrywide Home loans Servicing LP ACT 91 NOTICE TAKE ACTION TO SAVE YOUR HOME FROM FORECLOSURE This is an official notice that the mortasos on vout home Is In default. and the lender Intends to 1areclase. 90ecitlc Intonnatlan about. the nature at the default Is Drovlded in.the attached oaaes. The HOMEOWNER'S EMERGENCY MORTGAGE ASSISTANCE PROGRAM lHEMAP\ roav be able to helD to save your home. This NotICe eXDlalns how the DfOaram Works. To see ff HEMAP can helD. vau must MEET WITH A CONSUMER CREDIT CDUNSELING AGENCY WITHIN 30 DAYS OF THE OATE OF THIS NOTICE. Take this Notice with YOU when vou meet with the Counsellna Aaencv. The names. addreaea and Dhone numbers of Consumer Credit Counsellno Aaencles servlno vaur Countv are listed at the end 01 this Notice. If, vau have am; Questions. vau may call.the Pennsvlvanla HousinG Finance Aaem:v toll..free at 1..a00.3424397. 'Persons with ImDSlred.hearlna_can call1..717-78Q..1869.l This Nollce contains Importanllegalll1fonnBtlon. ff you hava any questions, representa1lves at the Consumer Credit Counseling Agency may be able to help answer them. You may also want to contact en attorney In your area. The local bar association may be able to help you find a lawyer. LA NOTIFlCACr6N EN ADJUNfO ES DE SUMA IMPORTANCIA, PUES AFECTA SU DERECHO A CONfINUAR VIVIENDO EN SU CASA. SI NO CQMPRENDE EL CONTENIDO DE ESTA NOTIFlCACI6N OBTENGA UNA TRADUCCI6N 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 REDIMIR SU HIPOTECA. HOMEOWNER'S EMERGENCY MORTGAGE ASSISTANCE PROGRAM YOU MAY BE ELIGIBLE FOR FINANCIAL ASSISTANCE WHICH CAN SAVE YOUR HOME FROM FORECLOSURE AND HELP YOU MAKE FUTURE MORTGAGE PAYMENTS. IF YOU COMPLY WITH THE PROVISIONS OF THE HOMEOWNER'S EMERGENCY MORTGAGE ASSISTANCE ACT OF 1983 (THE "ACT"), YOU MAY BE ELIGIBLE FOR EMERGENCY MORTGAGE ASSISTANCE: IF YOUR DEFAULT HAS BEEN CAUSED BY CIRCUMSTANCES SEYOND 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 chl:lcks and correspondence. BAEACHPA 612612000 4373649-5 JOliephA Barrelt 18S4HolI::r:Road 2001 $2.049.14 AS OF September 28, ~_"Io$25CO($40.00I:lR.J"'bo~laOlll;hribMd~....u<llllniMo~boJbw. BA€AOHPA IllCountrywide' HOME LOANS P.O. S"" 660694 Dallas. TX 75266-0694 11'1,1.1.11'11.1.llu.IIIIIIIIIIIIIII.II1IIIIII,lull..I..I.11 437364950002049140204914 EXH\B\T A ~;k^N,'!;Y.f1h"c ,., ~~ - ~. ~~ ~ --T{!!W<#""iIlI ,_,_",___, ,",.,._~ ",",_ IlCounlrywide' HOME LOANS Send correspondence to~ P.O. BOil 10221 Van Nuys, CA 9141o-0221 Send Paymenls to: P.D. Box 660694- Dallas, TX 75266-0694- Certified Mall No. Return Receipt Requested Regular Mail OCT 2 ~ 2nm August 24, 2001 Barbara T Barrett 1654 Holtz Road Enola, PA 17025-0000 Account No.: 4373649 Property Address: 1654 HoRz Road Enola, PA 17025-??oo CUrrent Servlcet: Countrywfde Home Loans Servicing LP ACT 91 NOTICE TAKE ACTION TO SAVE YOUR HOME FROM FORECLOSURE This Is an official notice that the IMrtaaae on your hame ls In default. and the lender intends to foreclose. Soecttlc Inlarl11Rtlon about the nature of the default Is DrOvlded In the attached DRaBS. The HOMEOWNER'S EMERGENCY MORTGAGE ASSISTANce-PROGRAM iHEMAPl maY be able to helD to save va", homa. ThIA Notice exolalns how the ~fDaram wDrks. To Me H HEM~P eaR helD. vau must MEET wtrH A eoNSUMER CREDIT COUNSELING AGENCY WITHIN 30 DAYS OFTHE DATE OF 1'HIS NOTICE:. Take this No<<ca with you when YOU mBP..t with the Counsellna Aoenev. The names. addresses and chane numbet9 of CanBum&r Credit Counsellna AaBneles servlna vaur CountY are listed at the end ofth's Notice. "YOu have anY aiJeSlloll!i~ YOU mfiv c811 the Penmwlvanla' Houslna Finance Aaencv toll..free at 1..aoo.342-2:J97. (Persons with .moa.red hearlna can call1...717..78(J..1869.1 This Nollce contains Important legallnfonnatlon. If you have eny questions, represell!lltlves et the Consumer Credit Counseflng Agency mey be able 10 help answer them. You mey also want 10 contact an attorney In your area. The local bar assocletlon may be able to halp you 1I11d a lawyer. LA NOTIFICACION EN ADJUNTO ES DE SUMA IMPORTANCIA, PUES AFECTA SU DERECHO A CONTINUAR VIVIENDO EN SU CASA. SI NO COMPRENDE EL CONTENIDO DE EST A NOTlFICACION OBTENGA UNA TRADUCCION INMEDIATAMENTE UAMANDO ESTA AGENCIA (PENNSYLVANIA HOUSING FINANCE AGENCY) SIN CARGOS AL NllMERO 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 DERECHD A REDIMIR SU HIPOTECA. HOMEOWNER'S EMERGENCY MORTGAGE ASSISTANCE PROGRAM YOU MAY BE ELIGIBLE FOR FINANCIAL ASSISTANCE WHICH CAN SAVE YOUR HDME FROM FORECLOSURE AND HELP YOU MAKE FUTURE MORTGAGE PAYMENTS. IF YOU COMPLY WITH THE PRDVISIONS 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 FINANCE AGENCY. Please write your account number On all chacks and coltsspondance. BAEACHPA 6/26/2000 4373649-5 BarbalaTBEItnllt 1654HaltzRoad 2001 $2,049.14 AS OF September 26, A!to'4l"'~.oo($olO,OOItR.)wIl".~ktr.-ellloll21*l~lDI:.ll!IlllIlwIWe~rrilI<lirt1lH<. 'RliAOHPA IBlCountrvwide- HOME LOANS P.O. Box 660694 Dallas. TX 75266.0694 1I1111.1.I'1J1.1,lIu,llulluulllll.lmlult.lIllI1111,1,11 EXH\B\T A: 437364950002049140204914 '-I ,~" ~r l~ TEMPORARY STAY OF FORECLOSURE - Under the Act, you are entitled to a temporary stay of foreclosure on your mortgage for thlrty.flve (35) days from the date of this Notice. During that time you must arrange and attend a "tace.to. face" meeting with one of the consumer credit counseling agencies listed at the end of this Notice, THIS MEETING MUST OCCUR WITHIN THE NEXT (351 DAYS IF YOU DO NOT APPLY FOR EMERGENCY MORTGAGE ASSISTANCE. YOU MUST BRING YOUR MORTGAGE UP TO DATE "THE PART OF THIS NOTICE CALLED 'HDW TO CURE YOUR MORTGAGE DEFAUL r EXPLAINS HOW TO BRING YOUR MORTGAGE UP TO DATE. CONSUMER CREDIT COUNSELING .AGENCIES - If you meet with one of the consumer credtt counseling agencies lISted althe end of thIS nOllce, the lender may NOT Jake octlon against you for thlrty.flve (35) days aner the data 01 this meellng. The names addresses and teleohone numbers at desionated oonsumer credit CDunseUna aaencles for the countv In which the oroDei'tv is lOMJ:ed are set forth at the end of this Notice. It is only necessary to schedule one face. to.face meeting. Advise your lender Immediatelv at your Intentions. APPLlCAnON FOR MQRTGAGI; ,ASSISTANCE - Your mortgage Is in default for the reasons set forth later in this Nollce (see following pages for specific Infonnatlon about the nature of your default) If you have tried and are unable to resolVe Ihls 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 ftle a completed Homeowner's Emergency Assistance Program Application with one of the designated consumer credft counselfng agencies fisted at the end of Ihls NotiCe. Only consumer ctedll counseling agencies have applications for the program and they wlll assist you In submitting a complete application to the pennsylvanIa HousIng Finance Agency. Your application MUST be flied or postmarked within thlrty~fiva (35) days of your face-to-face meeting. YOU MUST FILE YOUR APPUCATION PROMPTLY. IF YOU FAIL TO 00 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 AFPUCATlON FOR MORTGAGE ASSISTANCE WILL BE DENIED. AGENCY ACTION - Available funds for emergency mortgage assistance are very limited. They wiD be disbursed by lhe Agency under Ihe eligibility crile~a established by IheAct. The Pennsylvanie Housing Finance Agency has Sixty (60) days 10 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 WID be notified directly by the Pennsylvania Housing Finance Agency of Its decision on your application. NOTE: IF YOU ARE CURRENTLY PROTECTED BY THE FILING OF A PETITION IN BANKRUPTCY, THE FOLLOWING PART OF THIS NOTICE IS FOR INFORMATION PURPOSES ONLY AND SHOULD NOT BE CONSIDERED AS AN AITEMPT TO COLLECT THE DEBT. (tf you have tiled 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 "CQuntrvwldeM) services your home loan. Your home loan Is in serious default because you have not made your required payments. The total amount now fSquJred to reinstate your home loan as 01 the date of this letter Is as follows: Mon1h[v pavrnents: $656.50 $644.00 $25.16 $25.16 Uncollected La1e Charges: Uncollected Costs: TOTAL DUE: $656.50 $1.288.00 $25.16 $50.32 $25.15 $4.00 $2,04S.14 Late Charoes: Other Charaes: PAYMENT INSTRUCTIONS Please . MakeyourCheckpayableroCOtmtryw/d8f{(JmeLoans . Wrlteyour!oannumberonyoutcheckormOO8yorder . Wrile In any additlonal amOllnlsyou are Including. (II lotal is mlll'8 lhan $5000, please sendcartllledckack.) . DOIl'lattachyourchecklOlhapaymenlOOllpon . Don'lintlLKfacnrrespondence . Don'tsendcasll Payments: All payments wKI be llJlpJled to Ihe Ionges oUlstandlrig Installment ooa, unless otherwise e;qJfessty plCtllbtted by law. AddlUol\ll1 amounts. It you don' speQly the purpose of aQdlllonal amounts included, we will apply llI11m 11151 to any outstanding paymGA~ esCl'OW deliciondes, late charges and'or feas due. We Wi! then apply any remaining amounts as a prlndpal f'tIducUoll. If yoll submit an adlilronal prindpal payment with your home lOan pavmOll~ Counlrywlde wllll!Jst apply your nome loan payment, then .lf1e additional j)lindpal paytn&l1l. Your lOan mllst be current bfllore we can appty any principal reduction. EXH\6\T A ""~.J_., ; 'h.'~", "~ ,-', - "l', . ..."",;~~!:~, HOW TO CURE THE DEFAULT. You may cure this delau~ within TIlfRTY-FIVE (35) DAYS of the date ot this letter. by paying to us the above amount of $2,049.14, 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 lnsufflolent funds or tor any other reason, you will not have cured your defaull No extension of time '0 cure will be granted due to a returned payment. n you do not cure this defaull within THIRTY-FIVE (35) DAYS. we will accelerate Ine payments due an your name loan. This means whatever is owing on the original amount bOf1'01Nec will be considered due immediately and you may lose the chance to pay off your tlome loan In monthly Installments. If the fuU payment of the amount in default Is not made will1ln THIRTY-FIVE (35) DAYS. we also Intend to Immedletely start a lawsu~ to foreclose an your mortgaged properly. IF THE MORTGAGE IS FORECLOSED UPON - If the mortgage Is foreclosed, the mortgagad property will be said by the Sherlff fa payoff the mortgage debt. If the defautt Is cured before we begin legal proceedings. Countrywide will be entitled to collect the reaeenable attorneys fees actually Incurred. up 10 $50.00. However. It legal proceedings are started, COuntrywide will be enlltfed to collect the reasonable attorneys 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 costs. If you cure the default wlll1ln the THIRTY-FIVE (35) OAY period. you will not be required to pay attorney's tees. YOU HAVE THE RIGHT TO REtNSTATE APlCR ACCELERATION AND RIGHT TO ASSERT IN THE FORECLOSURE PROCEEDING TIlE NON- EXISTENCE OF A OEFAULT OR ANY OTHER OEFENSE YOU MAY HAVE TO ACCELERATION ANO FORECLOSURE. OTHER LENDER REMEDIES - The lender may also sue you personally for 1he unpaid prIncipal balance and all other sums due under the mortgage. RIGHI' TO C;U~E THE ItEFAULT PRIOR TO FORECLOSURE SALE -If you I1eve not cured the defauft within the THIRTY-FIVE (35) OA Y p'ertod and fOl'ootosure proceedings have begun. you still have the right to cure the default and prevent the safe at any time up to one hour before the foreClosure sale. You may do so by paying the total amount then past due. piUS any late or ather charges then due, reasonable attorney's fees and costs connected With the forec:losure sale and any other costs connected with the foreclosure sale as speclfled In writing by the lender and by performing any other requIrements under the mortgage. Curing your default in the manner set forth 1n this notice will restore your mortgage to the same position as If you had never defaulted. EARLIEST POSSIBLE ~ORECLOSURE SALE DATE, It Is estlmeted thattne earliest dale lhat a foreclosure sete could be held wOuld be epproxlmately elX (6) months from the date of lI1is leUer. A notice ot the date ot lI1e farecfasure sale will be sent to you before flle sale. You may find out at any time exactly what the required payment will be by catUng us at the following number. 1-800--66~6654. This payment must be in the form of a cash fer'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 sarna poslt!an as If no default had occurred. However, the default may nat be cured more than three (::Ie) times In any calendar year. HOW TO CONTACT THE LENDER: Name of Lander: Countrywide Home Loans Servicing LP Add,...: P. O. Box T022T Van Nuys, CA 9141tJ.0221 Phone Number: 1-000-669-6654 Fax Number: 1-805-577-3432 Contact Person: Melanie Carrillo, MS SV..a4 Attention: Loan Counselor EFFECT OF FORECLOSURE SALE - You should realize that a foreclosure sale will end your ownership Of the mortgaged property and your right to remain In it. If you continue to Jive in the property after the Sheriff's sale, a lawsuit to remove you and your furnishings and other belongings could be started by Countrywide at any time. ASSUMPTION OF MORTGAGE - Contact Countrywide Home Loans for lnfonnatlon on the possible assumablllty of your loan. YOU MAY ALSO HAVE rHE RIGHT: TO SELL THE PROPERTY TO OBTAIN MONEY TO PAY OFF THE MORTGAGE OEBT OR TO BORROW MONEY FROM ANOTHER LENDING INSTITUTION TD PAY OFF rHIS OEBT. TO HAVE THIS OEFAULT CURED BY ANY THIRO PARTY ACTING ON YOUR BEHALF. TO HAVE THE MORTGAGE RESrORED TO THE SAME POSITION AS IF NO DEFAULT HAD OCCURRED. IF YOU CURE THE OEFAULT. (HOWEVER. YOU DO NOT HAVE THIS RIGHT TO CURE YOUR OEFAULT MORE THAN THREE TIMES IN ANY CALENDAR YEAR.) TO ASSERT THE NONEXISTENCE OF A OEFAULT IN ANY FORECLOSURE PROCEEDING OR ANY OTHER LAWSUIT INSTITUTED UNDER THE MORTGAGE DOCUMENTS. TO ASSERr ANY OTHER DEFENSE YOU BELIEVE YDU MAY HAVE TO SUCH ACTIDN BY THE LENDER. TO SEEK PROTECTION UNDER THE FEDERAL BANKRUPTCY LAW. Pursuant to your hame loan documents, and because the home lOan Is in default, Countrywide may, at its option, enter upon and conduct an Inspection at the property. The purpose of thIS Inspection Is to observe the physical condition of the property, to verify that the property Is occupied andfor 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 laan documents. EXH1BlT A ,'.''^ , , ~ ,. .~. , . , ,. It you are unable to cure your default on or before September 28, 2001. Countrywide wants you to be aware of \l8rlous options Illat may be available to you through Countrywide to prevent a foreclosure sale of your property. For example: . ReOBvmellt Plan: It Is possible that you may be eligible far some form of payment assistance through Countrywide. Our basic plan requires that Countrywide receive, up frOnt, at least 1i. of the amount necessary to bring the account current, and that the balance of the overdUB amount be paid. along with the regular monthly payment, over a defined period of time. Other repayment plans also afe available. . Loan Modification; Alternatively, it Is possible that the regular monthly payments can be lOwered through a mOrJirlcatlon of tile loan by reducing the Interest rate and then adding the delinquent payments to the current loan balance. ThiS toreclosure alternatNe. however, is limited to certain loan types. Sale of Your prooertv: Alternatively, "you are wnllng to sell your home In orderto 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-inMLiau; Alternatively, if your property Is free from other liens or encumbrances, and If t~e default is due to a serious financial hardship which is beyond your controi. you may be eligible to deed your property directly to the Noteholder and avoid the foreclosure sale. If you are Interesled in discussing foreclosure alternatives wKh Countrywide, you must conteot us Immedlalely. If you request assistance. CountfyWlde 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 advisad that failure to bring the home loan current or to entsr In10 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. 1Ite14Peie ~ Melanie Carrillo Loan Counselor 1.80o-669~6654, extension 7556 Please be advised that this communicatIon Is from a debt collector. E){H\\3,1 p.. ~'''<,.;; ,-, .~,"",""~ -", --I ~- '1" . . \~'bL",.., PENNSYL V A1~IA HOUSING FINA1~CE AGE:-.'CY HOMEOWNER'S EMERGENCY ASSISTA1~CE PROGRAM CONSUMER CREDIT COUNSELING AGENCIES (REV. 8/00) CLINTON COUNTY Lycoming-C]inton Counties Commision for Community Action (STEP) 2138 Lincoln Street P.O. Box 1328 Williarnsport, PA [7703 (570) 326-0587 FAX (570) 322-2197 CCCS of Northeastern P A 20 [ Basin Street Williamsport, P A 17703 (570) 323-6627 FAX (570) 323-6626 COLUMBIA COL~TY 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 Luzeme County 163 Amber Lane Wilkes~Barre. P A 18702 (570) 826-0510 or (800) 822-0359 FAX (570) 829-1665-(Call Before Faxing) (570) 455-4994 Hazeltown FAX (570) 455-5631-(Call Before Faxing) (570)836-4090 Tunkhannock CRAWFORD COL'NTY Booker T. Washington Center 1720 Holland Center Erie. PA 16503 (814) 453-5744 FAX (814) 5749 John F. Kennedy Center, Inc. 2021 East 20th Street Erie, PA 16510 (814) 398-0400 FAX (814) 39S-1243 eccs of Western Pennsylvania, Inc. 2000 Linglestown Road Harrisburg, PA 17102 (717) 541-1757 CUMBERLAND COL'NTY Urban League of Metro pal it an Harrisburg N. 6th Street Harrisburg, PA 17101 (717) 234-5925 FAX (717) 234-9459 Community Action Camm of the Capital Region 1514 Derry Street Harrisburg, PA ]7104 (717) 232-9757 FAX (717) 234-2227 CCCS of Northeastern PA 1631 South Atherton St., Suite 100 State College, PA 16801 (814) 238-3668 FAX (814) 238-3669 1400 Abington Executive Park Suite I Clarks SummiL P A 18411 (570) 587-9163 or (800) 922-9537 FAX (570) 587-9134-9135 Greater Erie Community Action Committee 18 West 9111 Street Erie. PA 16501 (814)459-4581 FAX(814)456-0161 Shenango Valley Urban League, Inc. 601 Indiana Avenue Farrell, PA 16121 (412) 981-5310 Financial Counseling Services of Franklin 31 West 3rd Street Waynesboro, PA 17268 (717) 762-3285 YWCA of Carlisle 30 I -'0" Streer Carlisle, PA 17013 . (717)243-3818 FAX (717)'731.9539 Adams County Housing Authority 139wl43 Carlisle St. Gettysburg, PA 17325 (717) 334-1518 FAX 334.8326 PENNSYLVANIA BULLETIN. VOL. 29, NO. 23, .fl-';'o/E 5, 1999 ~,'--\ - '-~-'" ,. " EXH\B\T A lVI TFAT CERTAIN tract or parcel of land situate in the Township of Hampden, County of Cumberland and Commonwealth of Pennsylvania, more particularly bounded and described according to survey plan of Hartman and Associates, Inc., Engineers and Surveyors, dated June 6, 1994. BEGINNING at a point in the northern line of land now or formerly of Lawrence T. Joyce at its intersection with the eastern line of land now or formerly of Nora Ann Fraker: thence north 2S degrees 21 minutes 58 seconds east, along said line of Fraker lands 190 feet to a point; thence south 75 degrees 36 minutes 25 seconds east 441.38 feet to a point in the south~est portion of a. private road; thence south 13 degrees 05 minutes 01 seconds east, a distance of 185 feet to a pipe in the northern line of land now or formerly of Daisy Z. Sampson; thence north 77 degrees 38 minutes 31 seconds west, 424.10 feet to an iron pin in the eastern line of land now or formerly of Lawrence T. Joyce aforesaid; thence north 78 degrees 38 minutes 03 seconds west, along said line of Joyce lands 138.92 feet to a peine, the place ef BEGINNING. BEING THE SAME PREMISES which Clinton A. Orris, Executor of the Last will and Testament of Warren C. Orris, late, by deed dated September 7, 1994 and recorded in the Recorder of Deeds Office in and fer CUmberland County, PA in Deed Boek Ill, paae 726~ granted and conveyed unto Joseph R. Barrett his heirs and ass~gns. I PREMISES ON: 1654 HOL%Z ROAD "-.)'-"'~I~I__~ _,,,,,, ~ . ~, ,- ~ I ~ ,~ . . , , I ".x~~'.. . . . ~":'('-". - YERIFICATION BRANDON SCIUMBATO hereby states that he is YICE 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 F orec1osur~ are true and correct to the best of bis 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 unswom falsification to authorities. DATE: /o/;J-Lf/(Jf . -" ., 1--- '" ~ ~I"-~ _.~ . . - (::J 1t~ ~ \' ~ ~ ;:()t \; -~, - -tit- -.t i9. ~ b"t c5 dO~ I () D- ~~ t1 '-C, .. o r ~. <-. -OG~ Q)!X! ~~' 1-~;~ ~d "'c z -l -< r:.) C"-:) :-"") -'"i f'\.J \1::' . . ~ 1! ,l!1"jfi ~!;!fflI'~-"~~~~~~1'lIii~1J~'F!~~'w>}~I'i\Il1\;-,~<W!i;"''''*or''.E''-''P'' ""-"-"~1';''''-'$t",,'liVi'''''_'iR~!W-'!''i:Ji',;,m'1'''_'"f:;<t~'!,;;:1WM\\:~ffl'C~~i&.~~~~~ :;_;u :::::: C) ~I ~~ f"-.:l AFFIDAVIT OF SERVICE r CUMBERLAND COUNTY PLAINTIFF COUNTRYWIDE HOME LOANS, INC. F/K/A AMERICA'S WHOLESALE LENDER No. 01-6189 ACCT. #4373649 DEFENDANT(S) JOSEPH R. BARRETT BARBARA T. BARRETT Type of Action - Notice of Sheriff's Sale SERVE JOSEPH R. BARRETT AT 1654 HOLTZ ROAD ENOLA, PA 17025 Sale Date: MARCH 6, 2002 '\; s~ ~ Served and made known to -Jo at ~. 5"'), O'clockfm., at J CS1- SERVED ,s.;)l':.'f- ~~efendant on the .:z 3 I l '~~ld- /I:~ II day of --IJIt C ,2001, , Commonwealth of Pennsylvania, in the manner described below: Defendant personally served. 'f.. Adult family member with whom Defendant(s) reside(s). Relationship is W \ <:\ ~ Adult in charge of Defendant(s)'s residence who refused to give name or relationship. Manager/Clerk of place oflodging in which Defendant(s) reside(s). Agent or person in charge ofDefendant(s)'s office or usual place of business. an officer of said Defendant(s)'s company. Other: II I /I ",' . PeSCri~tion: Age S'~ Height S C Weight J 60 Race ~ Sex --E- Other /JO 5 \CS5<'5 I, C~e'lJC ~ L, eX ~'(. a competent adult, bemg duly sworn according to law, depose and state that I personally handed a true and correct copy of the Notice of Sheriffs Sale m the manner as set forth herein, issued in the captioned case on the date and at the address indicated above. . 6'd\\.b~;;J- T 6;}.l(,~:",\\ , NOTARIAl. SEAL . M,NE G. BOI'IYA/J 11I0"'''' Sworn to and subscnbed ChambersbllH" "..,'n' ~ '~kYI' b ~ tho ~. J f"-r'd M C " f.)v, v, rran e ore me IS ~ ay Y a.mmission Expires of ~~200j Notary:~1U... ~ ~ PLEASE ATTEMPT SERVICE AT LEAST 3 TIMES. INDICATE DATES & TIMES OF SERVICE ATTEMPED. 9 By: NOT SERVED On the day of ,200_, at o'clock _.m., Defendant NOT FOUND because: Moved Unknown No Answer Vacant Other: Sworn to and subscribed before me this _ day of , 200 _. Notary: By: Attornev for Plaintiff Frank Federman, Esquire - I.D. No. 12248 One Penn Center at Suburban Station 1617 John F. Keunedy Boulevard, Suite 1400 Philadelphia, PA 19103-1814 (215) 563-7000 -"'~-,fIIl'i!'t'J);m"", _ __"_,,. ' c ' ,.. _~"""'i""l_ .. " ~ - n I~r'~rl' ~ ~. ,-," '", ~~,.='"~~:-"~ "~ -~ n c' < 'VEL mr-;~ ~~; -<L. ~C) >G ~C~ )>C Z -< -< . CJ !"..:':' "' ':".'J;o ;~ 10" -0 7:: o .,~~ p;s BII ~~w, . ,~,""Jl__J;)i<_"_;m"..t'~I),"![l!l1l!,.,, ~~",.~""",?",",,~~,,'>'!iI"'je~~""iIWW~"r" i,;cO;;<__.:!'_f.'Wn'An:~''''W-{1_0';W#''i'\JF~m;:ll~'''-n_'-'<'';N'''''i%'''W;!~~]"''fi!)!j'-'li'1''"'W~'Wl'~ AFFIDAVIT OF SERVICE 7fZ , CUMBERLAND COUNTY PLAINTIFF COUNTRYWIDE HOME LOANS, INC. F/K/A AMERICA'S WHOLESALE LENDER No. 01-6189 ACCT. #4373649 DEFENDANT(S) JOSEPH R. BARRETT BARBARA T. BARRETT Type of Action - Notice of Sheriff's Sale SERVE BARBARA T. BARRETT AT 1654 HOLTZ ROAD ENOLA, PA 17025 Sale Date: MARCH 6, 2002 Served and made known to .73 j:.~ day of '0 ~c.., ,200l, at .51,tJ , o'clock f.m., at of Pennsylvania, in the manner described below: "'- Defendant personally served. -----r"- Adult family member with whom Defendant( s) reside( s). Relationship is Adult in charge ofDefendant(s)'s residence who refused to give name or relationship. Manager/Clerk of place oflodging in which Defendant(s) reside(s). Agent or person in charge ofDefendant(s)'s office or usual place of business. an officer of said Defendant( s)' s company. I " . I!.~ . Description: Age S~ Height !i G Weight /fi;o Race It0 Sex f' Other VJo S ~55e> I, C\~"Oc. ~ l\ C1\C..~ 1!a'competent adult, being duly sworn according to law, depose and state that I personally handed a true and correct copy of the No .ce of Sheriffs Sale in the er as set forth herein, issued in the captioned case on the date and at the address indicated abov NOT ARIAt SEAL ANNE G. BORY AN, Notary Public / Sworn to and subscribed ChamlJersburg Boro. Franklin . . before me this Z<lt"'-day My Co.mmission Expires 0 5 X~' 1 of Praf/l.O"....., 2001.. r u-: Notary: ~J1n.J1- (; ~ By: ~ / PLEASE ATTEMPT SERVICE AT LEAST 3 TIMES. INDICATE DATES & Ir , Commonwealth Other: / S OF SERVICE ATTEMPED. NOT SERVED On the day of ,200_, at o'clock _.m, Defendant NOT FOUND because: Moved Unknown No Answer Vaeant Other: Sworn to and subscribed before me this _ day of , 200 _' Notary: By: Attornev for Plaintiff Frank Federman, Esquire - I.D. No. 12248 One Penn Center at Suburban Station 1617 John F. Kennedy Boulevard, Suite 1400 Philadelphia, PA 19103-1814 (215) 563-7000 '-"<~?" "'" - , -*- ""f'-_~ ;~ ,< .., !' - . "'W -- ,_.; ... ~- ,"N-' '''' ""_~_,_~_,, ='<-0 ~-- -~". ,- ~ """".,,>~- """,,,--,-~,;,,,,,,," '-~" " '-~'^"''''''O-'___ _ '" o ~ ~~ f'~,',~ ~,f~': uJ. "':-~ ~::L, ~2 :z:: =< ~-,": r~"::- ~- -0 --.". , , ":': r:.:J "r;"" f:'s Ell """",,,,~rn - _~~~.~1F'I'~ll:~~~~~wm;~'1'~'k~'jWI.;",,,,,Wi:')-;-;"'''''''''''; ",tI-'.'i'''-T''''~!.:""~''',i-,,,1ij!F;x~'0~-'1~n:f-),,-,,'',!';i~'~'';""",:,:'11,' ,~~q~;"-?:~;;:{~(jf,~~~ .' ' . SHERIFF'S RETURN - REGULAR CASE NO: 2001-06189 P COMMONWEALTH OF PENNSYLVANIA: COUNTY OF CUMBERLAND COUNTRYWIDE HOMES LOANS INC VS BARRETT JOSEPH R ET AL SHANNON SUNDAY , Sheriff or Deputy Sheriff of Cumberland County, Pennsylvania, who being duly sworn according to law, says, the within COMPLAINT - MORT FORE was served upon BARRETT JOSEPH R the DEFENDANT at 1443:00 HOURS, on the 31st day of October ,2001 at 1654 HOLTZ ROAD ENOLA, PA 17025 by handing to BARBARA BARRETT, WIFE a true and attested copy of COMPLAINT - MORT FORE together with and at the same time directing Her attention to the contents thereof. Sheriff's Costs: Docketing Service Affidavit Surcharge So Answers: 18.00 10.40 .00 10.00 .00 38.40 r~~.,<t:~ R. Thomas Kline Sworn and Subscribed to before me this fir!:=: day of 11/01/2001 FEDERMAN & PHELAN By: (j) '--,~., (' ~)~ rfl.~~ Deputy Sheriff J- I'LtO-<U w a.../ .:L&ol A. D. ~a)ud/~,:?# prothonotar -' "j'-'''')!/;t.'f.~ , _ '_"._ < ~"~ . < "~ r '-~ " - ~ - .~~._"T_~,~.j..!lr~\i!"F' SHERIFF'S RETURN - REGULAR CASE NO: 2001-06189 P COMMONWEALTH OF PENNSYLVANIA: COUNTY OF CUMBERLAND COUNTRYWIDE HOMES LOANS INC VS BARRETT JOSEPH R ET AL SHANNON SUNDAY , Sheriff or Deputy Sheriff of Cumberland County, Pennsylvania, who being duly sworn according to law, says, the within COMPLAINT - MORT FORE was served upon BARRETT BARBARA T the DEFENDANT , at 1443:00 HOURS, on the 31st day of October 2001 at 1654 HOLTZ ROAD ENOLA, PA 17025 by handing to BARBARA BARRETT a true and attested copy of COMPLAINT - MORT FORE together with and at the same time directing Her attention to the contents thereof. Sheriff's Costs: Docketing Service Affidavit Surcharge So Answers: 6.00 .00 .00 10.00 .00 16.00 ~~~~ R. Thomas Kline 11/01/2001 FEDERMAN & PHELAN me this 9f!:: day of By: ~~ 'tn. S- Deputy Sherif~ Sworn and Subscribed to before ~~h' IL" .:JJnJI A.D. ~ Q 1"</;,,, ~ Prothonotary , I",~ ,~,-- - " ,Jf~^ -. " -~ _. . ~___~""-"'I''"''''''''T~'''''''1 1:.':0' Countrywide Home Loans, Inc. f7k/a America's Wholesale Lender YS Joseph R. Barrett and Barbara T. Barrett In The Court of Common Pleas of Cumberland County, Pennsylvania Writ No. 2001-6189 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 Advertising Certified Mail Poundage Law Jouma1 Patriot News 30.00 30.00 15.00 .50 1.00 24.20 18.20 15.00 15.00 .82 182.58 265.40 203.10 $800.80 paid by attorney 3-08-02 Sworn and subscribed to before me So Answers: This JI./E'dayof 'f!tt..{",JJ ~~~ ~ . R. Thomas Kline, Sheriff 2002, A.D. ~'''__ 0 Tw,(L .Onc;, . . "T']'ByJ03ttt~ Prothonotary Real Estate Deputy ""-"h"~"?)-?;"~ =,,~,._'i!'l'll".~ 1,{1.l ~ 3:(?1-,( ~ IV f'f~ ~.~..".,..,.. ~"FllIll.f.,Ib'"T""""'~ , COUNTRYWIDE HOME LOANS, INC. F/KIA AMERICA'S WHOLESALE LENDER .. CUMBERLAND COUNTY Plaintiff, COURT OF COMMON PLEAS v. CIVIL DIVISION JOSEPH R. BARRETT BARBARA T. BARRETT NO. 01-6189 Defendant(s). AFFIDA YIT PURSUANT TO RULE 3129 (Affidavit No.1) COUNTRYWIDE HOME LOANS. INC. F/K/A AMERICA'S WHOLESALE LENDER, 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, 1654 HOLTZ ROAD. ENOLA. PA 17025. 1. Name and address of Owner(s) or reputed Owner(s): Name Last Known Address (if address cannot be ,reasonably ascertained, please indicate) JOSEPH R. BARRETT 1654 HOLTZ ROAD ENOLA, P A 17025 BARBARAT.BARRETT 1654 HOLTZ ROAD ENOLA, P A 17025 2. Name and address ofDefendant(s) in the judgment: JOSEPH R. BARRETT 1654 HOLTZ ROAD ENOLA, PA 17025 BARBARA T. BARRETT 1654 HOLTZ ROAD ENOLA, P A 17025 3. Narne 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. "'-""".'f'__"""i'~_~, "'~I ,- , ,~~ ~ ~ ~.."""'o [ml ";-YY'f""'_'""~"~'>l"" 4. Narne and address of last recorded holdef'of every mortgage of record: , Narne Last Known Address (if address carmot be reasonably ascertained, please indicate) HOUSEHOLD REALITY CORPORATION TO BE DETERMINED 5. Name and address of every other person who has any record lien on the property: Name Last Known Address (if address carmot 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. Narne 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 carmot be reasonably ascertained, please indicate) Tenant/Occupant 1654 HOLTZ ROAD ENOLA, P A 17025 Domestic Relations of Cumberland County 13 North Hanover Street Carlisle, PA 17013 Commonwealth of Pennsylvania Department of Welfare 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. December 6,2001 DATE ~~ 1lv-- FRANK FEDERMAN, ESQUIRE Attorney for Plaintiff -~_',,' I""" '-I , ,,',',- c r,~T o ,~.~ , ~ ~ 1\ ~l ~ iI COUNTRYWIDE HOME LOANS, INC. F/K/A AMERICA'S WHOLESALE LENDER Plaintiff, CUMBERLAND COUNTY No. 01-6189 v. JOSEPH R. BARRETT BARBARAT.BARRETT Defendant(s). December 6, 2001 TO: JOSEPH R. BARRETT 1654 HOLTZ ROAD ENOLA, PA 17025 BARBARAT.BARRETT 1654 HOLTZ ROAD ENOLA, PA 17025 **THIS FIRM IS A DEBT COLLECTOR ATTEMPTING TO COLLECT A DEBT AND ANY INFORMATION 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, 1654 HOLTZ ROAD. ENOLA. PA 17025, is scheduled to be sold at the Sheriffs Sale on MARCH 6. 2002 at 10:00 a.m. in the Cumberland County Courthouse, South Hanover Street, Carlisle, PA 17013, to enforce the court judgment of 48,417.57 obtained by COUNTRYWIDE HOME LOANS, INC. FIKlA AMERICA'S WHOLESALE LENDER (the mortgagee) against you. Ifthe Sheriffs sale is postponed, the property will be relisted for the JUNE 5, 2002 Sheriff s Sale. NOTICE OF OWNER'S RIGHTS YOU MAY BE ABLE TO PREVENT THIS SHERIFF'S SALE To prevent this Sheriffs Sale, you must take immediate action: l. 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.) -"'-:_";';'''''~ ~ , , ~,;~ ~[ 1-- _~" 0 ~ YOU MAY STILL BE ABLE TO SAVE YOUR PROPERTY AND YOU HA YE 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 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 arnount 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 -'-"W.'"'~_"'" .. ~~ ~- ~~ , ~_..o ~. l'~-'~ --" ======----=============--~===================--=================================~~===========~ /' /' // ALL TRH CERT.\I:'< TR.\CT OR PARCEL 01' LA.'iD SITL.HE [,'i THE TO\'.:'<SHI.P 9! HA:Y1PDE:'<. COL'iTY OF' CDIBERLA.'1D\.'1D COM ,"fOc'iWEAL TH 01' PE:'INSYL \i.\.'iIA. "fORE P\RTICr~~L Y BOL''1DED A.'iD DESCRIBED ACCORD1:'iC ro SLR\iEY PL.\:'i 01' HART:.L\:'i .\YD .ASSOCl.An::;;: 1:'iC.. E'iGl'iEERS~'iD SLR\iEYORS. D.ATED Jl.::'II'~ 6. 1994. // / BEGINNING .\ T A POINT IN THE '10RTHER.'1 LINE 01' LA'ID :'lOW OF' I'~L Y OR LA WRE:'<CE T. JOYCE .A T (TS I:'iTERSECTI0N WITH THE E....STER.'1 L1:'1E 01' LA.'ID 'lOW OR FOR."IERL YOI' :'IORA \.'i'l FRAKER; THE:'ICE :'lORTH Z5 DEGRns:l :I1L'lLTES 58 SECONDS EAST. .ALONG SAID Ll'iE 01' FR.\KER LA.'iDS 190 FEET TO\ POINT; THE:'ICE SOI.TH 75 DEGREES 36 :I1L'lUTES Z5 SECONDS EAST 441.38 FEET TO A POl'iT [1'1 THE SOGTHWEST PORTION 0,...... PRIVATE ROAD; THE:'ICE SOCTH 13 DEGREES 05 :YU:'ILTES IJl SECOI'iDS EAST..A DIST.\NCE 01' 185 FEET Tll .A PIPE [:'/ THE :"fORTHER.'1L.INE Of' LA:'-iD :'lOW OR FOR."lERL Y Of' DAISY Z. SA~PSON; THENCE :"fORTH 1i DEGREES 38 :YU:'/LTES 31 SECONDS WEST. -1:-1.10 FEET TO ..\..'1 IRON Pl."! l:'i THE EAST~NE Of' LA.'1D :"lOW OR FOR~ERL Y OF LA WR.E:'ICE T. .JOYCE ..\.FORESAID; THE:'ICE NORTH 78 D..eCREES 3~INGTES OJ 'iECONDS WEST, ALONG SAID LINE Of' JOYCE LANDS 138.9: FEET TO A PO [:'IT. THE IhACE 01' BE(;{NNI:'IG. . . , L~"J1 Oesc:-iot:lon: Tax PareellD ci, 10-IZ-Z987-003 _~""'''''_;-ri_'li'J ,"" ~ ~"" - .. "~ i'~ . '. ",- ~. - " COMMONWEALTH OF PENNSYLVANIA) COUNTY OF CUMBERLAND) WRIT OF EXEOUTIGIq ~hd/or ATTACHMENT NO. 01-6189 CIVIL 19 CIVIL ACTION - LAW TO THE SHERIFF OF . CUMBERLAND ___COUNTY: Countrywide Home Loans, Inc., f/k/a To satisfy the debt. interest and costs due America's Wholesale Lender trom.. Joseph R. & Barbara T. Barrett, 1654 Holtz Road, Eno1a PA PLAINTIFF(S} 17025. DEFENDANT(S) You are directed to levy upon the property of the defendant(s) and to sell Real estate located Holtz Road, Enola PA 17025. (See attached legal description.) (1) at 1654 (2) You are also directed to attach the property of the delendant(s) not levied upon in the possession of GARNISHEE(S) as follows: and to notify the garnishee(s) that: (a) an attachment has been issued; (b) the-garnishee(s) is/are enjoined from paying any debt to or for the account of the defendant(s) and from delivering any property of the defendant(s) or otherwise disposing thereof; (3) If property of the defendant(s) not levied upon an subject to attachment is found inthe possession of anyoneolher than a named garnishee, you are directed to notify him/herthat he/she has been added as agarnishee and is enjoined as above stated Amount Due $48,417.57 LL Due Prothy Other Costs $.50 $1. 00 Interest 12/6/01 to 3/6/02 $971.10 Atty's Comm ($8.11 per c1foem) Atty Paid $126 .40 Plaintiff Paid Date: December 11, 2001 CURTIS R. LONG vision by Deputy REOUESTiNG PARTY: Name Frank Federman, Esq. 1617 JFK Blvd., -ste 1400 Phil~dclphi~ P~ 19103 1814 Plaintiff (215) 563 7000 12248 Address: Attorney for: Telephone: Supreme Court tD No. "",-,,-\'~m'~~~-l'!', .",-..tl\4-.~ ,Ill '~I I' III ill "I. '~"< " " ~,~, " r~ -, '''';'' - ""~-, . ~ '''-.. ,"'~- .,." .-,,,,-~, ."--",, -,,'~ -'--"'-",' ~ ~'" -- ~=~~O' ,>~ < "~ REAL ESTATE SALE No. 5L( On December 13, 2001, the sherifflevied upon the defendant's interest in the real property situated in Hampden Township, Cumberland County, P A, known and numbered as 1654 Holtz Road, Enola and more fully described on Exhibit "A" filed Date: December 13,2001 By: 9od..u ~ Real Estate Deputy ~ ~ .~ ~. with this writ and by this reference incorporated herein. C~~'}d 'l'<j ~\~,' r\ 1\\"\ - -, , . \ -, -, - , ' < .,. " $'i tf. t, 1\ \~ ~ .< .,\".0:. ~.(\2;" -it""",'!' l)-''''l}~ ""l"\":"J;. ,:;j - ;1~ "3\~~ ,;~ , -. nll'&r1"w'Jm~'fl~11~'.;{$1:.~'~~~~",~FJ!,~Wj1'.':C"";'~C)C_3'-''';:''> ,.. ",,'---~ ~ , ! . '", THE PATRIOT NEWS THE SUNDAY PATRIOT NEWS Proof of Publication Under Act No. 587, Approved May 16, 1929 Commonwealth of Pennsylvania, County of Dauphin} ss Michael Morrow being duly sworn according to law, deposes and says: That he is the Ass!. Controlier of The Patriot News Co., a corporation organized and existing under the laws of the Commonwealth of Pennsylvania, with its principal office and place of business at 812 to 818 Market Street, in the City of Harrisburg, County of Dauphin, State of Pennsylvania, owner and publisher of The Patriot-News and The Sundav Patriot-News newspapers of general circulation, printed and published at 812 to 818 Market Street, In the City, County and State aforesaid; that The Patriot-News and The Sunday Patriot-News were established March 4th, 1854, and September 18th, 1949, respectively, and ali have been continuously published ever since; That the printed notice or publication which is securely attached hereto is exactly as printed and published in their regular daily and/or Sunday/ Metro editions which appeared on the 29th day(s} of January and the 5th and 12th day(s) of February 2002. That neither he nor said Company is interested in the subject matter of said printed notice or advertising, and that ali of the aliegations of this statement as to the time, place and character of publication are true; and That he has personal knowledge of the facts aforesaid and is duly authorized and empowered to verify this statement on behalf of The Patriot-News Co. aforesaid by virtue and pursuant to a resolution unanimously passed and adopted severaliy by the stockholders and board of directors of the said Company and subsequently duly recorded in the office for the Recording of Deeds in and for said Co n of Dauphin\in Miscelianeous Book "M", Volume 14, Page 317. PUBLICATION COPY SALE#54 NoIa~11 S"I Tony L. Russ"" Noll!\, PubUC Hlrrlsburg. Dluphln County My Comroisslon Explres June 6, 2002 Member, PennsylVania ASsoclltlon 01 NOIIrt Y commission expires June 6. 2002 . cI CUMBERLAND COUNIY SHERIFFS OFFICE CUMBERLAND COUNTY COURTHOUSE CARLISLE, PA. 17013 Statement of Advertisi ng Costs To THE PATRIOT-NEWS CO., Dr. For publishing the notice or publication attached hereto on the above stated dates $ Probating same Notary Fee(s) $ Total $ 201.60 1.50 203.10 Publisher's Receipt for Advertising Cost . . The Patriot News Co., publisher of The Patriot-News and The Sundav Patriot-News, newspapers of general Circulation, hereby acknowledge receipt of the aforesaid notice and publication costs and certifies that the same have been duiy paid. By.................................................................... '^".,.>~""1":'-1'!""':Ill",,'-.-..:"~_ ~_t~b _ ___._~ =" -~-- ~r' 1=. .~~REA(EsfATE~SALE.No.-54 Writ No. 2001-6189 Civil Term Countrywide Home Loans, Inc. Flkla America's Wholesale Lender ,.'- vs _" C~~_ Joseph A. Ssrrell _ __ --: - and Barbara T. Barrett /' _ Atty: Frank Federman - DESCRll'TION . ~ALL THAT CERTAIr~ tract or parcel of land ~s1ti1ate in the Township of Hampden, County of jL.Cumb..e.dand_ __ and Commonwealth of ~~nslllyania. more particularly bOWlded and ~eSCribed according to survey plan of Hartman ~d. As_~iates, Inc., Engineers and Surveyors, ~,datedJune6, 1994. ~EGINNING at a poinl in the northern line of ~rand now or fonned)l of Lawrence T. Joyce at ~itsj_ntersection with the eastern line of land now ::;orforrnerly of Nora Ann Fraker, thence north =-~25 d_egrees 21 minutes 58 seconsd east, along ~d_line of Franker lands 190' feet to a point; ~thence south 75 degrees 36 minutes 25 seconds ~t 441.38 feet to a point in the southwest ~ portion of -a private road; thence south 13 ~d~~l;S OS minutes 0.1 secQnds east, a distance ~QfJ85f~t to a pipe in the northern line of land '" = now or fonnerly of Daisy Z. Sampson; thence ",...mrth 77 degrees 38 minutes 31 seconds west, 424.10 feet to an irou'pin in the eastern line of _land now or fonnerly of Lawrence T. Joyce aforesaid; thence north 78 degrees 38 minutes 03 seconds west, a1oc.g said tine of Joyce lands 138.92 feet to a point, the place of BEGINNJNG. ThxParcel ID NO.: 10-12-2987.003. - PROOF OF PUBLICATION OF NOTICE IN CUMBERLAND LAW JOURNAL (Under Act No. 587, approved May 16, 1929), P. L.1784 STATEOFPENNSYLVANIA : SS. COUNTY OF CUMBERLAND : Roger M. Morgenthal, Esquire, Editor of the Cumberland Law Journal, of the County and State aforesaid, being duly sworn, according to law, deposes and says that the Cumberland Law Journal, a legal periodical published in the Borough of Carlisle in the County and State aforesaid, was established January 2, 1952, and designated by the local courts as the official legal periodical for the publication of all legal notices, and has, since January 2, 1952, been regularly issued weekly in the said County, and that the printed notice or publication attached hereto is exactly the same'as was printed in the regular editions and issues of the said Cumberland Law Journal on the foUowing dates, V1Z: JAmJARY 25, FEBRUARY I, 8,2002 Affiant further deposes that he is authorized to verifY this statement by the Cumberland Law Journal, a legal periodical of general circulation, and that he is not interested in the subject matter of the aforesaid notice or advertisement, and that all allegations in the foregoing staterp.ents as to time, place and character of publication are true. ~ SWORN TO AND SUBSCRIBED before me this 8 day of FEBRUARY. 2002 NOrM LOIS E. SNYDER, NoIaiy Public CarIIIle BolO, Cumberland County My CommIssIon ExpiI'llS Man:h 5, 2!lO5 ~'-,~'" """l:'P'1iiiJM><., 1i\lill'T"OOJ!;',~~'~'~' '~'_!I\. I ~" '., . ~ , MAL ESTATE SALE NO. 54 Writ No. 2001-6189 Civil CountIyWide Home Loans. Inc. f/k/a America's Wholesale Lender vs. Joseph R. Barrett and Barbara T. Barrett Atty.: Frank Federman LEGAL DESCRIPTION: ALL TIIAT CERTAIN tract or par- cel of land situate in the Township of Hampden. County of Cumberland and Commonwealth of Pennsylva- nia. more particularly bonnded and described according to smvey plan of Hartman and Associates, Inc.. Engineers and Surveyors. dated June 6. 1994. BEGINNING at a point in the northern line of land now or formerly of Lawrence T. Joyce at its intersec- tion with the eastern line of land now or formerly of Nora Ann Fraker: thence North 25 degrees 21 min- utes 58 seconds East. along said line of Fraker lands 190 feet to a point: thence South 75 degrees 36 minutes 25 seconds East 441.38 feet to a point in the southwest por- tion of a private road; thence South 13 degrees 05 minutes 01 seconds East, a distance of 185 feet to a pipe in the northern line of land now or formerly of Daisy Z. Sampson; thence North 77 degrees 38 min- utes 31 seconds West. 424.10 feet to an iron pin in the eastern line of land now or formerly of Lawrence T. Joyce aforesaid: thence North 78 degrees 38 minutes 03 seconds West. along said line of Joyce lands 138.92 feet to a point. the place of beginning. TaxParcelJD#: 10-12-2987-003. -,:;::~t~~lllJlII' ,'" ,,', '.~ "I 'r- ,. FEDERMAN AND PHELAN, LLP By: Frank Federman, Esquire Atty. I.D. No.: 12248 One Penn Center at Suburban Station Suite 1400 Philadelphia, PA 19103-1814 (215) 563-7000 Attorney for Plaintiff COUNTRYWIDE HOME LOANS, INC. FfKlA AMERICA'S WHOLESALE LENDER Plaintiff Court of Common Pleas CUMBERLAND County No. 01-6189-CIVIL TERM vs. JOSEPH R. BARRETT BARBARA T. BARRETT Defendant(s) . PRAECIPE TO WITHDRAW COMPLAINT, WITHOUT PREJUDICE, WITHDRAW JUDGMENT AND DISCONTINUE AND END ~ TO THE PROTHONOTARY; Kindly withdraw the complaint filed in the instant matter, without prejudice, withdraw the judgment entered on or around 12/07/01 in the amount of $48,417.57 and mark this case discontinued and ended, upon payment of your costs only. -1-Uuelc 2eo/t ~ Frank Federman Attorney for Plaintiff Date \~. - ""'~ "~ , ,[, . f." "-,.~,, f ,--.. - "<. , .', ,.." -", ~ ~r _=- . . 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