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Home My WebLink About99-01938 6. The following amounts are due on the mortgage: Principal Balance $25,162.69 Interest 908,82 10/1/98 through 3/1/99 (Per Diem $5.94) Attorney's Fees 800.00 Cumulative Late charges 48.16 3/25/94 to 3/1/99 Cost of Suit and Title Search 550,00 Subtotal 27,469.67 Escrow Credit Deficit Subtotal 0.00 34.70 34.70 TOTAL $27,504.37 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. Notice of Intention to Foreclose has been sent to Defendant(s) by Certified Mail, as required by Act 6 of 1974 of the Commonwealth of Pennsylvania on the date(s) set forth in the true and correct copy(s) of such notice(s) attached hereto as Exhibit "A." 9. Pursuant to the Fair Debt Collection Practices Act, 15 U.S.C. S 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. WHEREFORE, PLAINTIFF demands an in ~ Judgment against the Defendant(s) in the sum of $27,504.37, together with interest from 3/1/99 at the rate of $5.94 per diem to the date of Judgment, and other costs and charges collectible under the mortgage and for the foreclosure and sale of the mortgaged property. ;?:-~~ s Frank Federman FRANK FEDERMAN, ESQUIRE Attorney for Plaintiff r,O Do. 2824 ,.........,..,. 1l0uu0n, Tnu 772S2.2824 . ro: Randy Flnkey Bonnin I. Finkny 1~82 Pln~ lid Carlini. PA 17011 BANK ~J UNITED IIA"E: Januar', I~, 199': SUSJECT: Our~ Intention to (o'ort!cloA(! tht! Murt~n?,,! on Pt'cmlsos: 1 ~82 Pine R'lad renn Twp rA 17011 I.OAN NO.: 601988-1 NOTICE OF INTENTION TO FORECLOSE MORTGAGE rhe MORTGAGE on your proparty located at 1~82 Pine Road Penn Twp PA 17011 IS IN SERIOUS DEFAULT becnuse you have not made the monthly paymentR of $ 396.12 each, for the month. of NOVEMBER. DECEMBER, JANUARY 1999. Late charges have also accrued to this date in the amnunt of $ 70.65. The total amount now required to cure this default, or in other words, get caught up in your payments, as of the date of this letter, is $ 1,274.01. YOU MAY CURE THIS DEFAULT WITHIN THIRTY (10) DAYS OF THE DATE OF THIS LETTER, BY PAYING TO US THE ABOVE AMOUNT $ 1,274.01, PLUS ANY ADDITIONAL MONTHLY PAYMENTS AND LATE CHARGES WHICH MAY FALL DUE DURING THIS PERIOD. Such payments must be made by either cash. cashier's check, certified check, or money order and made at B A Ii K U NIT E D P.O. Box 4864, Houston, Texas 77210-4864 Attn: Payment Processing Drop Code 401 If you do not cure this default within THIRTY (10) DAYS, WE INTEND TO EXERCISE OUR RIGHT TO ACCELERATE THE MORTGAGE PAYMENTS. This means that whatever is owing on the original amount borrowed will be considered due immediately and you may lose the chance to payoff the original mortgage in monthly installments. If full payment of the amount of default is not made within THIRTY (30) DAYS, WE ALSO INTEND TO INSTRUCT OUR ATTORNEYS TO START A LAWSUIT TO FORECLOSE YOUR MORTGAGE PROPERTY. If the mortgage is foreclosed, your property will be sold by the sheriff to pay off the mortgage debt. If wa refer your case to our attorneys, but you cure the default before they begin legal proceedings against you, you will still have to pay the reasonable attorney's fees, actually incurred, up to $50.00. However, if legal proceedings are started against you, you will have to poy the reasonable attorney's fees even if they are over $50.00, Any attorney's fees will be added to whatever you owe us, which may also include our reasonable costs. IF YOU CURE THE DEFAULT WITHIN THE THIRTY DAY PERIOD. YOU WILL NOT BE REQUIRED TO PAY ATTORNEY'S FEES. We may also sue you personally for the unpaid principal balance nnd .11 other sums due under the mortgage. If you have not cured the default within the thirty day p.riod and foreclosure proceedinss have begun, YOU STILL HAVE THE RIGHT TO CURE THE DEFAULT AND PREVENT THE SALE AT ANY TIME EXHIBIT A P.O, 80. 2824 /lou"oe. Tem 71252.2824 (Page 2 of 2) NOTICE OF INTENTION TO FORECLOSE MORTGAGE BANK lWJ UNITED UP TO ONE HOUR BEFORE THE SHERIFF'S FORECLOSURE SALE. YOU MAY 00 SO BY PAYING THE TOTAL AMOUNT OF THE UNPAID MONTHLY PAYMENTS PLUS ANY LATE OR OTHER CHARGES THEN DUE, AS WELL AS THE REASONABLE ATTORNEY'S FEES AND COSTS CONNECTED WITH THE FORECLOSURE SALE. It Is estimated that th~ earli'~t dote that such a sheriff'g sale could be held would be approximately six months after the date of thig letter. A notice of the date of the sheriff's sale viII be gent to you before the sale. Of cour.e, the amount needed to cure the ddault vi11 increase the longer you wait. You may find out at any time exactly vhat the required payment will be by calling us at the folloving number: 1-800-19~-9801, Thi. payment must be in cash, ca~hier'~ check, certified check, or money order and made payable to u~ at the address stated above. You should realize that a sheriff's sale vi11 end your ownership of the mortgaged property and your right to remain in It. If you continue to live in the property after the sheriff's sale, a lawsuit could be started <):.9.,..evict you, ,"~}::::' . , '{ou have additional rights to help protect your interest in the property. YOU HAVE THE RIGHT TO SELL THE PROPERTY TO OBTAIN MONEY TO PAY OFF THE MORTGAGE DEBT OR TO BORROW MONEY FROM ANOrHER LENDING INSTITUTION TO PAY OFF THIS DEBT. (YOU MAY HAVE THE RIGHT TO SELL OR TRANSFER THE PROPERTY SUBJECT TO THE MORTGAGE TO A BUYER OR TRANSFEREE WHO WILL ASSUME THE MORTGAGE DEBT, PROVIDED THAT ALL THE OUTSTANDING PAYMENTS, CHARGES AND ATTORNEY'S FEES AND COSTS ARE PAID PRIOR TO OR AT THE SALE, (AND THAT THE OTHER REQUIREMENTS UNDER THE MORTGAGE ARE SATISFIED). CONTACT US TO DETERMINE UNDER WHAT CIRCUMSTANCES THIS RIGHT MIGHT EXIST). YOU HAVE THE RIGHT TO HAVE THIS DEFAULT CURED BY ANY THIRD PARTY ACTING ON YOUR BEHALF. IF YOU CURE THE DEFAULT, THE MORTGAGE WILL BE RESTORED TO THE SAME POSITION AS IF NO DEFAULT HAD OCCURRED, HOWEVER, YOU ARE NOT ENTITLED TO THIS RIGHT TO CURE YOUR DEFAULT MORE THAN THREE TIMES IN ANY CALENDER YEAR. If you have any que~tions. call LAURA H. MILNE at (800)395-9803 or toll-free at 1-800-195-9801 BANK UNI1'ED Collection Department Loan Admini~tration **BANK UNITED IS CONTACTING YOU IN ORDER TO COLLECT YOUR LOAN. INFORMATION WHICH YOU GIVE US WILL BE USED BY US TO HELP COLLECTION OF YOUR LOAN. AXY ~XH\B\T po. XC044 021 LHM VERIFICATION FRAN V A TER hereby Slales that h~she is VICE PRESIDENT of BANK UNITED mongagc servicing agent for Plaintiff in this maller, that h~she is authorized to take lhis Verification, and that the statements made in the foregoing Civil Action in Mongage Foreclosure are true and correct to the best of his/her knowledgc, information and belicf. The undersigned understands that this statement is made subject to the penalties of 18 PA. C.S, See, 4904 relating to unsworn falsification to authorities, t!J-dtta DATE: 5/;:!.t/f'i . ~/6d37ffl \J:' ... . " , ,. r ,j ,.. ':J.... . . " m i '. '-" c-' \.c,\i\ .~C;c, !I.~,?-'6 ~~\: .,;.?J~" C\~\. '\~~X v,v,'a'6 'a~'l:S :-.u\ \V,?,'J r;f:''i:J ..."0,,,>'> 'I..~ \'6 \?" ,,\'0', ~1.,", ~~~...' '60,~ v..-{\,,>Y> tlllLO 0080-li.~rt.lUOli"""'O"lU-ooe ""I 'JI'U(I'l"",al~1 aj'I~-IJV 10 I.KH~'AJO V ''v'!))' ~l'v'IS-l1'v' .,' SHERIFF'S RETURN - REGULAR CASE NO: 1999-01938 P COMMONWEALTH OF PENNSYLVANIA: COUNTY OF CUMBERLAND BANK UNITED VS, FINKEY RANDY ET AL KATHY CLARKE , Sheriff or Deputy Sheriff of CUMBERLAND County, Pennsylvania, who being duly sworn according to law, says, the within NOTICE AND COMPLAINT IN was served upon FINKEY RANDY the defendant, at 14:50 HOURS, on the 12th day of April 1999 at 242 GOODHART ROAD SHIPPENSBURG, PA 17257 ,CUMBERLAND County, Pennsylvania, by handing to SUSAN BARRICK (ROOMATE) a true and attested copy of the NOTICE AND COMPLAINT IN together with MORTGAGE FORECLOSURE and at the same time directing Her attention to the contents thereof, ;db, ~"l FEDERMAN & 04/13/1999 by ~ Sheriff's Costs: Docketing Service Affidavit Surcharge 18.00 10.54 .00 8.00 So :;;~~~t: ~ K.l;no~as K~1ne,1:~ PHELAN y e 1 Sworn and subscribed)to before me this eJ.{j- day of . (CjN f , 19 (r'1 A.D. SHERIFF'S RETURN - REGULAR CASE NO: 1999-01938 P COMMONWEALTH OF PENNSYLVANIA: COUNTY OF CUMBERLAND BANK UNITED VS. FINKEY RANDY ET AL KATHY CLARKE , Sheriff or Deputy Sheriff of CUMBERLAND County, Pennsylvania, who being duly sworn according to law, says, the within NOTICE AND COMPLAINT IN was served upon FINKEY BONNIE L A/KIA BONNIE FINKEY the defendant, at 14:30 HOURS, on the 12th day of April 1999 at 1582 PINE ROAD CARLISLE, PA 17013 ,CUMBERLAND County, Pennsylvania, by handing to JOHN SHELLEHAMER (FIANCE OF BONNIE) a true and attested copy of the NOTICE AND COMPLAINT IN together with MORTGAGE FORECLOSURE and at the same time directing Her attention to the contents thereof. Sheriff's Costs: Docketing Service Affidavit Surcharge 6.00 5.58 .00 8.00 . So answers: Kr:::~~,~1 FEDERMAN & PHELAN 04/13/1999 ~ by ~~c/bh~ :;;J.~.:>~ Sworn and subscribed Ui:lbefore me this o{( 5f day of _e , 19 ti A.. ~o .' . . FEDERMAN AND PHELAN Frank Federman, Esquire Identificat iOIl No. 12248 Two Penn Center Plaza Suite 900 Philadelphia, PA 19102-1799 (215) 563 -7000 BANK UNITED, F/K/A BANK UNITED OF TEXAS, FSB COURT OF COMMON PLEAS ATTORNEY FOR PLAINTIFF CIVIL DIVISION plaintiff CUMBERLAND COUNTY va, NO. 99-193B-CIVIL RANDY FINKEY BONNIE L. FINKEY, AIKIA BONNIE FINKEY Defendant (a) FILE COPy TO I RANDY FINKEY 242 GOODHART ROAD SHIPPENSBURG, PA 17257 DATE OF NOTICE: MAY 4, 1999 THIS FIRM IS A DEBT COLLECTOR ATTEMPTING TO COLLECT A DEBT. ANY INFORMATION WE OBTAIN 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 ENFORCEMENT OF A LIEN AGAINST PROPERTY. IMPORTANT NOTICE You are in default because you have failed to enter a written appearance personally or by attorney and file in writing with the court your defenses or objections to the claims set forth against you. Unless you act within ten (10) days from the date of this notice, a Judgment may be entered against you without a hearing and you may lose your property or other important rights. You should take this notice to a lawyer at once. If you do not have a lawyer or cannot afford one, go to or telephone the following office to find out where you can get legal help: CUMBERLAND COUNTY BAR ASSOCIATION 2 LIBERTY AVENUE CARLISLE, PA 17013 (717) 249-3166 CD~j, ~ Frank Federman, Esquire Attorney for Plaintiff l '0 - . FEDERMAN AND PHELAN Frank Federman, Esquire Identification No. 12248 Two Penn Center Plaza Suite 900 Philadelphia, PA 19102-1799 (215) 563-7000 BANK UNITED, FIKIA BANK UNITED OF TEXAS, FSB Plaintiff ATTORNEY FOR PI.AINTIFF vs. COURT OF COMMON PLEAS CIVIL DIVISION CUMBERLAND COUNTY NO. 99-1938-CIVIL RANDY FINKEY BONNIE L. FINKEY, AIKIA BONNIE FINKEY Defendant(s) TO. BONNIE L'R FOIADNlCEY, A/K/A BONNIE l~i COllly 1582 PINE r CARLISLE, PA 17013 DATE OF NOTICE: MAY 4, 1999 THIS FIRM IS A DEBT COLLECTOR ATTEMPTING TO COLLECT A DEBT. ANY INFORMATION WE OBTAIN 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 ENFORCEMENT OF A LIEN AGAINST PROPERTY. IMPORTANT NOTICE You are in default because you have failed to enter a written appearance personally or by attorney and file in writing with the court your defenses or objections to the claims set forth against you. Unless you act within ten (10) days from the date of this notice, a Judgment may be entered against you without a hearing and you may lose your property or other important rights. You should take this notice to a lawyer at once. If you do not have a lawyer or cannot afford one, go to or telephone the following office to find out where you can get legal help: CUMBERLAND COUNTY BAR ASSOCIATION 2 LIBERTY AVENUE CARLISLE, PA 17013 (717) 249-3166 fD~,^,~~ Frank Federman, Esquire Attorney for Plaintiff ,... (f, '- t.~ -" (-; c' U.I r C"~ < ; ( , ; I i . ".. , c!j. ~". ! :;i 1 ( :-" '" (.J , , , , '" ", .'. - , , ;.:~ ~ . . , ~l! ,-.. :;-j I '. ('':', :5 C U-\ (J \ ~ .J J ~ \ ~ ~ ~ , CH "1' ~ ~ o -1 ~ ~~ ~ ~ ~@~ "< ~ , ... '- "'-+- 'c. "$ J -t t] --., ~ . . . . .Q .Q 0 . . . . . Il:l 0< ., . I . . . . . .... . 00< Z '- '" '" '" ... 0 . Cll ... ... ... ~~ ... .- f<_ ..... , , , Il:l> ::>r.:r ..... e e e ..:1..:1 tJl>: .... Il.>t Ill::> .f< II CI CI III l><r.a 'Z .. .. .. ~~ III 0 .... ..:I 'lC :i: ~~ ....tJ '..:1 Or.:r 'Il. 0 I>: . tJ , . f<0 '1>: >t ~ ....... ~2 ...... e ~Il:l 02: . ::> t!I .>t ..0 ! I>:lC ~'Ill I>:tJ lol Ot!l -lZ ::> ! ~I ...... '1>: 00 I>: . 0 tJ~ !'olO . f< Il.:ll .f< Il:l..:l ...- 'G=':O< =1>: tJ f<r.:r r.:r . III ~ . 2::ll . ...::> Il. .. . tJ Q . r.:r . . . . ..:I . ~ 0 0 ... . Z Z .... . n ,~~.' (i ~:; CO "II "1::(". f..:= _.J ~I,: .,'.- <r:' ,_.. [.:)t N .,::"'.] -' ['\..) <~(S r:~l. -, ~~ (i c":,- . '., :_~jr(j >c._: r,) :.~. _;.1 ::.~ .- :n en -< 1 DESCRIPTION All, Ihal ~ertain house and lot of ground located on the South side of the Pine Road in Penn To\\' IIship, C:ulI1herland County. Penna" more particularly bounded and described as follows: BE(iINNING at a nail in [he center line of the Pine Road at line of lands of Corman: thence by the cellI".. lilll' of said Pine Road. North 88 degrees 00 minutes East 99 feet to a nail in the center line of s;l1l1 1'1",,1: Ihence by lands now or formerly of Wilmer R, Hockley and Constance \Y, Hockley, his wih.'. Soulh 11 L1egn:es 00 minutes East 175,00 feet to a stake at line of lands now or formerly of ('h;lrl~\ :\. llruugh and Ruth P. Brough. his wife: thence along said IanLls. South 88 degrees 00 milllll," West L)') feet to a stake: thence 1'iorth II L1egrees 00 minutes West 175 feet to a nail in the cellll'" lillL' of Ihe Pine Road, the place of beginning, TITLE!~ SAID PR~~IISES IS VESTED IN Randy Finkey and Bonnie Finkey, His Wife by Deed from Wilham W, DreIsbach dated 8/16/85 recorded 8/16/85 in Deed Book 31-K Page 938, '>- y') t: ir: ~ .,' ~~; ,,:. " ,r" ,) ~. , , , !,- --. .. :.:-! C~ C~ ."'-.1 , "c I.!_, . ,;',j , " ., iju_ 1- , , I:.. G'" :-j Co e,;"' U You may need an attorney to assert your rights. The sooner you contact one, the more chance you will have ot stopping the sale. (See notice on page two on how to obtain an attorney.) YOU MAY STILL BE ABLE TO SAVE YOUR PROPERTY AND YOU HAVE OTHER RIGHTS EVEN IF THE SHERIFF'S SALE DOES TA~E PLACE. '. 1- be aold calling If the Sheriff's Sale is not stopped, your property will to the highest bidder. You may find out the price bid by (215\ 563-7000. 2. sale if of your You may be able to petition the Court to set aside the the bid price was grossly inadequate compared to the value property. 3. . The sale will go through only Sheriff the full amount due in the sale. happened, you may call (215) 563-7000. if the buyer pays the To find out if this has 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 on 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 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 TARE 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 ATORNEY REFERRAL CUMBERLAND COUNTY BAR ASOCIATION 2 LIBERTY AVENUE Cumberland county Courthouse CARLISLE, PA 17013 (717) 249-3166 (800) 990-9108 ',. If) , .. (C ..;J , : .~ . ~ ''.l , .< ,II , , I ~. ., " : -" ." N I ." ~ '" '. , , - I;".] lL F' J:l. l~ m _J U (;1 U '~ ....... AI'" !SU IllWl I, . PA ! IOU , SENDER: .C~bO. arrvc' ,a.t~A.~c...y .P"nt '/?JI tWme .m~u on "-_01 rtwt form kJ IN! _~f1Ifur""'" CMd ~"'" _All.." !NIb"'''1N Iror1l' t'J Iht~., or \WIthe.k" ~oo..n04Plfl'''''' .n.n.t\,r"AtuIIlI''''''''101ltlQl'/l''...wtJcII;_~.mIhe''''''''''-'d ConeuIt poltmUter rot fee. '. ~ 40, AnrcJo I'<<Jmber . P 973 215 117 I olio _ 10 ....... the following _allet." axtnlla. lllilealricted 00IMlty .\ . . '4 4b. Servic6 TVpe '1 )( CERTlFlED 7.0al y - I '5. Roc._ By: (Prlnl Name) 8. Addressee'llI Address r-- m;/j;::;;:/~ PS FOAM 3811, December 1994 <itIS.1 I' ,.'. , J "\ I,t., Domestic Return Receipt ."", ,.. . I ;,1. I " ,n (1; L i L'.' r: , ) . i , , c:, ,. " ':. () ! " c".; ..j , i..L , -. , (j :-,.) o- J ./ ".. If) [; C...-: u; Z i':- (':.=: -I~:... , ,. \ _.- " -'-'" , ", ._~ --, '. '-. ~ :- U.~ "1~ C)' , :> Ij) , N .1:--::: :~~! ., ...J iiiO " :::.) -:.1C,1., --, '. " ::> :5 -- c"' U , '.- Alti. IH htt. In IltmPI o ",...'V'I.UHI..net , , P II R I MAY BE uSED FOR DOMESTIC AND INTERNATIONAL MAIL. DOES "OT PROVIDE FDA INSURANCE _POSTMASTER ., "."...., 11/1:'-' 7;,-; - ,,:":' , ,: II/Ii ~ ; I)~! '....~ Q : '!ll,.;", I "'lYi' ~7ii?:fr... .,>' ~ ",":" ~) 1,\.;,tJ,. ': "", ""J I'., ,..'JI,. '\' qr\14 '" I,,;;: \ 41 :=: Id.I j~ ~ 4; JI;~/ Rlcll>lIdFrom: DMK RE: FINKEY. RANDY On. OIICI of ordlnlry mlit .ddr....d to: CUMBERLAND COUNTY DOMESTIC RE1~tIgNS PEP~R;MiNT CUMBERLAND COUNTY COURTHOUSE UNe ~UUKltlUU~e ~4U~~ CARLISLE. PA 17013 PS Form 3817. Mar. 1989 U,5, P TAL S'RV'C' ERTIFI AT MAY BE USED FOR DOMESTI E OF AllI G PROVIDE FOR INSURANCE_P~:~~~~~~~NATlONAL MArl. ODES NOT Received From: DMK AWx fee here in Illmp. cor ""lIt,., palt'AI .nd RE: FINKEY, RANDY One pillce of ordlnarv mail addtetllld 10: TEN.AJIT.'QC'''tTl)ANT 1582 PINE ROAD ~AKLi~L~, fA 17813 PS Form 3817. Mar. 1989 " " ---------------------- "{"-''''j } "'.-""i' U1 '" U1 ru ru ru "I',i'" ;'f ,n~.Tr..u:..,.", POSTMARK DtI DATE '''1'''''''''''11",.0'''1'''' 11""1 ':l, ruT...., f~'...f....-of .flOft[~ SENT TO Hor fOR IN (AlUnoH.U WAIL ", '" a- Q. olAND'! F J.~IKEY "4. '..JUlld...tT YoU^" $b.i.P:!iJ.i.s8t.::h~, ~.~'" IJ~5i PS FORM 3800 IH17K Receipt for Certified Mail US Postal Service ----------------------- -----. ----- ..D '" '" IlETlJR~j } Ill';EIf'r ';[r.'NT ""~ ,T....,~ POSTMARK DR ORTE ru ru ru ", '" a- Q. SENT TO' RE'>Hl'~!roD(lI'o'~JW CE"rWIECfEE .IlEflJflNREr.ElPf rorA<.l-'u:;rAGEA'jOf[ES I NOT FOR INTERNAflONJ,L MAIL . ,Nt, ." ':"~>. -, ~NN1~ ~. FLN~E'l. ~;~/A ~ON~iE Fi~K~'l ,53": ?r:.E ROAD C.\iU.LSI.E, FA lJ01J "'...- {:) ".'..:,., 0 -''';/ ."'-:::.....--- PS FORM 3800 US Postal Service /;41J Receipt for Certified Mail [ I , ~ ~ g ~ z w ~ o ~ 12: ~; ~ = w ~ U ~; ~. w ~ ~ ~ z ~ = o ~ ~ .~ .... 01 b;: '-': l' ~; ,-" . .. (.); '., G:. ..:c.. '.I'j C;-\ , ('\J Cl;. U", -'. 0" u G..: ~. ~2 "-'- r' .. , LL m l 0 U, (") .J Bank United -vs- Randy Finkey and Bonnie Finkey In the Court of Common Pleas of Cumberland County, Pennsylvania No, 99-1938 Civil Tenn Michael E. Barrick, Deputy Shcriff, who bcing duly sworn nccording to law. says on October I, 1999 at5:51 o'clock P.M, EDST, he posted a copy ofRenl Eslnte Writ Notice Poster and Description on the property of Randy and Bonnie Finkey locatcd at 1582 Pine Road, Carlisle, Cumberland County, Pennsylvania according to Iuw, Robert Fink, Deputy Sheriff who being duly sworn according to law, says on August 30,1999 at 12:25 o'clock P,M, EDST, he served a true copy of Real Estate Writ Notice and Description in the above entitled action upon one of the withinnamed defendants to wit: Randy Finkey by making known unto Randy Finkey at 242 Goodhart Road, Shippensburg, Cumberland County, Pennsylvania, its contents and at the same time handing to him personally the said true and attested copies of the same, Dawn L. Kell, Deputy Sheriff, who being duly sworn according to law, says on October 71999 at 3:26 o'clock P,M, EDST, she served a true copy ofRenl Estate Writ Notice Poster and Description in the above entitled action upon one of the within named defendants to wit: Bonnie Finkey by making known unto John Shellhammer. boyfriend nt 162 Amy Drive, Carlisle Cumberland County, Pennsylvania, its contents and at the same time handing to him personally the said true and attested copies of the same, Dawn L. Kell, Deputy Sheriff, who being duly sworn according to law, says on October 4, 1999 at 2: 19 o'clock P,M, EDST, she served a copy of Real Estate Poster in the above entitled action upon one of the within named defendants to wit: Randy Finkey by making known unto Randy Finkey at 242 Goodhart Road. Shippensburg, Cumberland County, Pennsylvania, its contents and at the same time handing to him personally the said true and attested copies of the same, R. Thomas Kline, Sheriff, who being duly sworn according to law, says he served the above Real Estate Writ Notice Poster and Description in the following manner: The Sheriff, mailed a notice of the pendency of the action to one of the within named defendants to wit: Randy Finkey by first class mail to his last known address 2424 Goodhart Road, Shippensburg, Pennsylvania, This letter was mailed under the date of October 5, 1999 and never returned to the Sheriff Office, R. Thomas Kline Sheriff, who being duly sworn according to law, says he served the above Real Estate Writ Notice Poster and Description in the following manner: The Sheriff mailed a notice of the pendency of the action to one of the within named defendants to wit: Bonnie Finkey by first class mail to her last known address 162 Amy Drive, Carlisle, Pennsylvania, This letter was mailed under the date of October 7, 1999 and never returned to the Sheriffs Office, R. Thomas Kline, Sheriff, who being duly sworn according to law, says after due and legal notice had been given according to law, exposed the within described premises at public venue or outcry at Court House, Carlisle, Cumberland County Pennsylvania on December 8,1999 at 10:00 o'clock A.M, EDST, and sold the same for the sum of$ 1.00 to Attorney Dale Shughart, Jr" for Bank United, F/K/A Bank United Of Texas, FSB, It being the highest bid and best price quoted for the same Bank United, F/KJA Bank PROOF OF PUBLICATION OF NOTICE IN CUMBERLAND LAW JOURNAL (Under Act No. 587, approved May 16, 1929), P. L.1784 STATE OF PENNSYL VANIA : COUNTY OF CUMBERLAND : 55. Roger M. Morgenthnl, Esquire, Editor of the Cumberland Luw Journul, oflhe County und Stute uforesuid, being duly sIVom, uccording to luw, deposes und suys that the Cumberlund Luw Joumul. u legul periodicul published in the Borough of Curl isle in the County and Stute ufo resaid, 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 prillted notice or publiealion attached hereto is exactly the same as was printed in the regular editions and issues of the said Cumberland Law Journal on the following dales. viz: OCTOBER 22, 29, NOVEMBER 5. 1999 Affiant further deposes that he is authorized to verify this statement by the Cumberland Law Journal, a legal periodical of general circulation, and that he is not interested in the subject matter of the aforesaid notice or advertisement, and that all allegations in the foregoing statements as to time, place and character of publication are true, REAL ESTATE SALE NO, II ~?4/{ ger M, K1orgenthal, Editor-------- IVrtt No. 99-1938 CJvtI Bank UnJted V5. Randy Plnkey and BonnJe F'lnkey Atty.: Frank Federman DE:SCRlPTION ALL that certain house and lot of ground located on the South side of the Pine Road In Penn Township. Cumberland County. Penna" more particularly bounded and described as follows: BEGINNING at a nallln lhe center line of the PIne Road at line of lands of Corman: thence by lhe center line of said PIne Road. North 88 degrees 00 mtnutes East 99 feet to a naU In lhe center line ofsaJd road; thence by SWORN TO AND SUBSCRIBED before me this -Ldayof NOVEMBER. 1999 AlSfAl l0l6 f. SNYDER. Nola'Y Public Carlisi. Sorc, Cumb.rland County, PA My Commiuion Expite. Match 5, 2001 I lands now Dr formerly of Wilmer R. i Hockley and Constance W. Hockley. j his Wife. South 11 de({rees 00 mtn. , utes East 175.00 feet to a stake at ' Hne of lands now or formerly of Char- les A. Brough and Ruth P. Brough. his Wife: thence along said lands. South 88 degrecs 00 minutes West 99 feet to a stakc: thence North II degrees 00 minutes West 175 feet to a nall tn the center !Jne of the Pine , Road. the place of beginning. TITLE: TO SAID PRE:MISE:S IS VESfED IN Randy Flnkey ami Bon. nle Flnkey, His Wife by Deed from William W. Dreisbach dated 8/ 16/85 recorded 8/16/85 In Deed Book 31- K Page 938, '" THE PATRIOT NEWS THE SUNDAY PATRIOT NEWS Proof of Publication Under A,t NO,587, Annmeed May 16. 1929 Commonwealth 01 Pennaylvanla, County of Dauphin} aa Michael Morrow being duty sworn according to law, deposes and says: That ho Is Iho Asslstanl Controllor 01 THE PATRIOT-NEWS CO" a corporalion organlzod and exlsllng under Iho laws 01 the Commonweallh of Pennsylvania, wilh i1s principal olllce and place 01 business al 812 10 818 Market Street, In tho Clly 01 Harrisburg, County 01 Dauphin, Slate of Pennsylvania, owner and publisher of THE PATRIOT-NEWS and THE SUNDAY PATRIOT-NEWS newspapers of general circulation, printed and published at 812 to 818 Market Street, In Ihe City, County and Stale aforesaid; Ihal THE PATRIOT.NEWS and THE SUNDAY PATRIOT-NEWS were established March 41h, 1854, and Seplember 181h, 1949, respectively, and all have been continuously published ever since; That Ihe printed notice or publication which Is securely allached hereto Is axacliy as prinled and published In their regular dally and/or Sunday and Melro edillons/issues which appaared on Ihe 261h day of October and the 2nd and 9th day(a) of November 1999, That neilhar he nor said Company is interested In the subject matler of said printed notice or advortlslng, and that all of the allegations of Ihis stalament as 10 the time, place and character of publica lion are true; and That he has personal knowledge of the facts aloresaid and is duly authorized and empowered to verify this statement on behalf of The Patriot-Naws Co, aforesaid by virtue and pursuant to a resolution unanimously passed and adopted severally by the stockholders and board of directors of the said Company and subsequently duly recorded in the ollire for the Recording of Deeds in and for said County 01 Dauphin in Miscellanaous Book "M", Volume 14, Page 317. PUBLICATION COpy SALE '5 Sworn to and subs ibed before me this 18th day of er 1999 A.D, /j---; Nol rI; Seal . /J ~.J Tony L r~lJS . NOlary Public /' / Harnsburg, Dauphin County M Commission E)'pircr. June 6. 2002 NO ARY PUB Lie Y A 'Ion 01 1{1'~9mmission expires June 6, 2002 Member, Pennsylv.lma SSQCI J . CUMBERlAND COUNTY SHERIFFS OFRCE OOURTl-OJSE CARLISLE, PA, 17013 Statement of Advertisino 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) $ ~~ $ 221.25 1.50 222.75 , .' .,.' ,,',' . '. ']sher's Receipt for Advertising Cost '~W1~UR~~::;~:'rO;~~ ler of THE PATRIOT-NEWS and THE SUNDAY PATRiOT-NEWS: newspapers of general H!>ddeY, hla wife, SOu!II';.ll;;~;OO aceipt of the aforesaid notice and publication costs and certifies that the same have :::,,=~1~.~,,::g,="':. THE PATRIOT-NEWS CO, ='and~=iia~ OO'mInut8s~ 99f8etto a _; tti8nce By....,......,........................,............,..,....,......,.., I North 11 dea_ ~mInutas,. ., .. W, ., 175 feet to a naB In Ilia centei'1Ine 01 the PIne Road, the llIaee 01 beglnnm" ' " , TITLE 10 SAID EMISES IS VESTED IN Randy FInby' Bonnie F1nkey, HIa WIle by lleed from W111lam w. Dreisbach da18d8l1818518COn1ed 8/18/85 In Deed Book 31.K Page 938. " .' DANK UNITED, F/K/A BANK UNITED OF TEXAS, FSD CUMBERLAND COUNTY COURT OF COMMON PLEAS CIVIL DIVISION VB. RANDY FINKEY DONNIE L. FINKEY, A/K/A BONNIE FINKEY : NO. 99-1938 CIVIL AFFIDAVIT PURSUANT TO RULE 3129 IAffidavit No. 11 DANK UNITED, F/K/A BANK UNITED OF TEXAS, FSB, Plaintiff in the above action, by its attorney, FRANK FEDERMAN, ESQ., sets forth as of the date the Praecipe for the Writ of Execution was filed the'" following information concerning the real property located at 1582 PINE ROAD. CARLISLE, PA 17013. 1. Name and address of Owner(s) or reputed Owner(s): NAME LAST KNOWN ADDRESS (if address cannot be reasonably ascertained, please so indicate) RANDY FINKEY 242 GOODHART ROAD SHIPPENSBURG. PA 17257 BONNIE L. FINKEY, A/KIA BONNIE FINKEY 1582 PINE ROAD CARLISLE. PA 17013 2. Name and address of Defendant(s) in the judgment: NAME LAST KNOWN ADDRESS (if address cannot be reasonably ascertained, please so indicate) SAME AS ABOVE 3. Name and address of every jUdgment creditor whose judgment is a record lien on the real property to be sold: NAME LAST KNOWN ADDRESS (if address cannot be reasonably ascertained, please so indicate) NONE 4. Name and address of the last recorded holder of every mortgage of record: NAME LAST KNOWN ADDRESS (if address cannot be reasonably ascertained, please so indicate) NONE 5. Name and address of every other person who has any record lien on the property: HAm; LAST KNOWN ADDRESS (if address cannot be reasonably ascertained, please so indicate) H2mi 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: l:fAl:U; LAST KNOWN ADDRESS (if address cannot be reasonably ascertained, please so indicate) CUMBERLAND COUNTY DOMESTIC RELATIONS DEPARTMENT CUMBERLAND COUNTY COURTHOUSE ONE COURTHOUSE SOUARE CARLISLE, PA 17013 7. Name and address of every other person 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 so indicate) TENANT/OCCUPANT 1582 PINE ROAD CARLISLE. PA 17013 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 ::.:n::~r:,::'Si'ic.tion to .uthor~i:::;;[, I\~ DATE FRANK FEDE~~N, ESQUIRE Attorney for Plaintiff ~ " You m~y need an attorn~y 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.) YOU MAY STILL BE ABLE TO SAVE !OUR PROPERTY AND YOU IIAVE OTHER RIGHTS EVEN IF THE SHERIFF'S SAL~!1QE!! !~!H; ~LACE. '. 1- be sold calling If the Sheriff's Sale is not stopped, your property will to the highest bidder. You may find out the price bid by (215) 563-7000. 2. sale if of your You may be able to petition the Court to set aside the the bid price was grossly inadequate compared to the value 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 (215) 563-7000. 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 distributio~f the money bid for your house will be filed by the Sheriff on ~:? JtJoo. This schedule will state who will be receiving ~ at mo ey. The money will be paid out in accordance with this schedule unless exceptions (raasons why the proposed distributi~is wrong) are filed with the Sheriff within ten (10) days after ''''"b 7 J(/1'O. (j . 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 ATORNEY REFERRAL CUMBERLAND COUNTY BAR ASOCIATION 2 LIBERTY AVENUE Cumberland County Courthouse CARLISLE, PA 17013 (717) 249-3166 (800) 990-9108