HomeMy WebLinkAbout99-02992
i
i'•6
.:c
l
iie5t
f
I:
i''
yF,
PRAECIPE FOR WRIT OF EXECUTION - (MORTGAGE FORECLOSURE)
P.R.C.P.3180-3183
COUNTRYWIDE HOME LOANS, INC.
F/K/A COUNTRYWIDE FUNDING
CORPORATION
Plaintiff
Vs.
DARREN M. BECK
JENNIE L. LAVENDER
Defendant(s)
COURT OF COMMON PLEAS
CUMBERLAND COUNTY, PA
NO. 99-2992 CIVIL
PRAE(:IFE FOR WRIT OF F.%FCtMON
(MORTGAGE FURRCI, MUREI
TO THE DIRECTOR OF THE OFFICE OF THE PROTHONOTARY:
Issue writ of execution in the above matter:
Amount Due $91,259.96
Interest from 8/5/99 TO $ 1.890.00 and Costs
12/8/99
(PER DIEM - $15.00)
$93,149.96 Total
FRANK FEDERMAN, ESQUIRE
TWd PENN CENTER PLAZA
SUITE 900;
PHILADELPHIA, PA 19102
Attorney for Plaintiff
Note: Please attach description of property.
J
o ?
O?
a
? W
Ea
E
a ?
? 00
N ? A
m z
cli
?a
ON
00
O
H
E
9
O
a
a
uU
0
z
QH
W
a
H
aH
O
U
ac
a
z
H
00
a
0
to
w
a
H
a
0
u
N
a
w
C.) z
a
za
W
a?w
H
W
h
0
w?
w?
w o
O?
?w
O 'C
w?
W a. "
V
W
ate.
ro
a
W
z
w
a
vw
m h
Ln
O
l? M
O
P4n
a It
c? a
a
b .
ww
O
0b
au
a?i
d
waA
H`m
yu
N
a
4 Go
d
u
b40A
tnz?
Ul
u
N b
N
N
ro
ro
a
ALL THAT CF-RXAIN lot or tract at land situate in 19=pdca
Township, Cumberland county, cc=cmvealth of Pennsylvania, more
particularly bounded and described as follows, to wit,
BRGnwna at a point on the southern right-of-way line of
Xittitinny Drive (64 feet wide private), at the dividing line of
Lot 4103 and Lot 1102, maid point also being located 373.18 feet
Nest of the southwest corner of Kittatinny Drive and Tuas¦y court;
TMMT= by Sine of Lot 107 and paeaiaq thsousrh the
centerline of a partition wall South o7 degrees 57 minutes 58
seconds Nest x.00.00 feet to a point; TRENCH by land of Mountain
View Village Nome Owners Association North 02 degree3 02 minutes 07
seconds West 20.00 feet to a point; THENCE by line of Lot •301 and
passing through the eamter partition, va11 North 07 degrees 57
minutes 58 seconds East 100.00 feet to a point on the southern
right-of-way line of Kittatinny Drive; TUNCE by said right-of-way
lino South a2 acgrees 07 manucea on, ssconaa rant 2a.oo acct to a
point, the place of B%GI:qw=NG-
CCNT7n?M;G 21000 square feet.
Bel$(; Lot #102 on the final SuL•divisien plan of Mountain
VieV Village, Phase IV. Rccorded in plan BooK 60, Page 67B,
Being known as 4155 Kittatinny Drive, Mechanicsburg, PA 17055.
TAX PARCEL NO. 10-15-1285-152
TITLE TO SAID PREMISES IS VESTED IN DARREN M. BECK, SINGLE PERSON AND
JENNIE L. LAVENDER, SINGLE PERSON BY DEED FROM YINGST HOMES, INC. DATED
8/30/95 AND RECORDED 10/4/95 IN DEED BOOK 129, PAGE 291.
LI??f6J
1; is
Lit; L? Can
? 1
1 . . •t
COUNTRYWIDE HOME LOANS, INC. CUMBERLAND COUNTY
F/K/A COUNTRYWIDE FUNDING CORPORATION COURT OF COMMON PLEAS
CIVIL DIVISION
j Vs.
I
DARREN M. BECK
JENNIE L. LAVENDER NO. 99-2992 CIVIL
AFFIDAVIT PURSUANT TO RULE 3129
(Affidavit No. 1)
COUNTRYWIDE HOME LOANS INC F/K/A COUNTRYWIDE FUNDING
CORPORATION, Plaintiff in the above action, by its attorney, FRANK
FEDERMAN, 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 4155 KITTATINNY DRIVE. MECHANICSBURG PA
17055.
1. Name and address of owner (s) or reputed Owner(s):
NAME LAST KNOWN ADDRESS (if address
cannot be reasonably ascertained,
please so indicate)
DARREN M. BECK 4155 KITTATINNY DRIVE
M_ECHANICSBURG, PA 17055
JENNIE L. LAVENDER 26 NORTH 8TH STREET REAR
LEMOYNE,_PA 17043
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)
SECURITY PACIFIC CONSUMER 6520 CARLISLE PIKE. SUITE 155
DISCOUNT COMPANY MECHANICSBURG, PA 17055
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)
ONE
1 .. ,'.\
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 so indicate)
6. Name and address of every other person who has any record
interest in the property and whose interest may be affected by
the sale:
ONE
NAME LAST KNOWN ADDRESS (if address
cannot be reasonably ascertained,
please so indicate)
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
MOUNTAIN VIEW VILLAGE
HOMEOWNER'S ASSOCIATION
TENANT/OCCUPANT
DOMESTIC RELATIONS OF
CUMBERLAND COUNTY
LAST KNOWN ADDRESS (if address
cannot be reasonably ascertained,
please so indicate)
4175 MOUNTAIN VIEW ROAD #102
MECHANICSBURG. PA 17055
4155 KITTATINNY DRIVE
MECHANICSBURG, PA 17055
13 NORTH HANOVER STREET
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 to unsworn
falsification to authorities.
August 5, 1999 I? ?n.vxa?_,J
DATE FRANK FEDERI N, ESQUIRE
Attorney for Plaintiff
I
L);.o
(AI
Cl I' r':
F"
FEDERMAN and PHELAN
By: FRANK FEDERMAN
Identification No. 12248
Suite 900
Two Penn Center Plaza
Philadelphia, PA 19102
(215) 563-7000
COUNTRYWIDE HOME LOANS, INC.
F/K/A COUNTRYWIDE FUNDING CORPORATION
VS.
DARREN M. BECK
JENNIE L. LAVENDER
CERTIFICATION
ATTORNEY FOR PLAINTIFF
CUMBERLAND COUNTY
COURT OF COMMON PLEAS
CIVIL DIVISION
. NO. 99-2992 CIVIL
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:
(XX) an FHA mortgage
( ) non-owner occupied
( ) vacant
( ) 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.
FRANK FEDERMAN, ESQUIRE
Attorney for Plaintiff
i ?.
COUNTRYWIDE HOME LOANS, INC.
F/K/A COUNTRYWIDE FUNDING
CORPORATION
VS.
CUMBERLAND COUNTY
COURT OF COMMON PLEAS
CIVIL DIVISION
DARREN M. BECK
JENNIE L. LAVENDER NO. 99-2992 CIVIL
NOTICE. OF SHERIFF'S SALE OF REAL PROPERTY
August 5, 1999
TO: DARREN M. BECK JENNIE L. LAVENDERE
4155 KITTATINNY DRIVE 26 NORTH 8TH STREET REAR
MECHANICSBURGo PA 17055 LEMOYNE, PA 17043
**THIS FIRM IS A DEBT COLLECTOR ATTEMPTING TO COLLECT A
DEBT AND ANY INFORMATION OBTAINED WILL BE USED FOR
THAT PURPOSE. IF YOU HAVE PREVIOUSLY RECEIVED A
DISCHARGE IN BANKRUPTCY, THIS IS NOT AND SHOULD NOT BE
CONSTRUED TO BE AN ATTEMPT TO COLLECT A DEBT, BUT
ONLY ENFORCEMENT OF A LIEN AGAINST PROPERTY.**
Your house (real estate) at 4155 KITTATINNY DRIVE.
MECHANICSBURG, PA 17055, is scheduled to be sold at the Sheriff's
Sale on DECEMBER 8, 1999 at 10:00 a.m. in the Cumberland County
Courthouse, South Hanover Street, Carlisle, PA 17013, to enforce
the court judgment of $91,259.96 obtained by COUNTRYWIDE HOME
LOANS, INC. F/K/A COUNTRYWIDE FUNDING CORPORATION (the mortgagee)
against you. If the sale is postponed, the property will be
relisted for the MARCH 1. 2000 Sheriff's Sale.
NOTICE OF OWNER'S RIGHTS
YOU MAY BE ABLE TO PREVENT THIS SHERIFF'S SALE
To prevent this Sheriff's Sale, you must take immediate
action:
1. The sale will be cancelled if you pay to the mortgagee
the back payments, late charges, costs and reasonable
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.)
y0U MAY STILL BE ABLE TO SAVE YOUR PROPERTY. AND YOU HAVE OTHER
RIGHTS EVEN IF THE SHERIFF'S SALE DOES TARE PLACE.
1. If the Sheriff's Sale is not stopped, your property will
be sold to the highest bidder. You may find out the price bid by
calling (2151 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 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 proposed schedule of distribution of the money
bid for your house will be prepared by the Sheriff not later than
thirty (30) days after the sale. The schedule shall be kept on
file with the SHeriff and will be made available for inspection in
his office. The 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 filing of
the proposed schedule.
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
ALL TR&T CnZAIN lot or tract of land situate in Ilampdon
Towaghip, Cumberland county, commonwealth of Peu?sylvania, more
particularly bounded and dascxibed as follows, to wits
BRCI41MNO at a point on the southern right-of-way line of
Kittatinny Drive (64 feet wide private), at the dividing line of
Lct #103 and Lot #102, said point also being located 373.18 feet
Nest of the southwest corner of Kittatinny Dr1vs and Tusaay court;
T> Ir by line of Lot 107 and passing throusrh the
centerline of a partition wall South 07 degrees 37 ninutas 58
seconds West 100.00 feet to a point) THENCE by land of Mountain
View Village home owners Association North 07 degrees 02 minutes 02
seconds West 20.00 feet to a point) THENCZ by line of Lot 0301 and
passing through the center partition wail North 07 degrees 57
minutes 56 seconds Bast 100.00 feet to a point an the southern
right-of -way line of Kittatinny Drive) THENCE by said right-of-way
lin4 South e2 aeorees oa minutes ca eeeonaa mast ac.oo teat to a
point, the place of esGI.`Y=UG.
CCHTAnTING 21000 8quaZe feet.
BCING Lot #102 ca the Final Subdivision Plan of Mou%tAin
View Village,, Phase Iv. Rcccrded in Plan BOOK 60, Page 67B.
Being known as 4155 Kittatinny Drive, Mechanicsburg, PA 17055.
TAX PARCEL NO. 10-15-1285-152
TITLE TO SAID PREMISES IS VESTED IN DABREN M. BECK, SINGLE PERSON AND
JENNIE L. LAVENDER, SINGLE PERSON BY DEED FROM YINGST HOMES, INC. DATED
8/30/95 AND RECORDED 10/4/95 IN DEED BOOK 129, PAGE 291.
- r-
1 -
r
IN THE COURT OF COMMON PLEAS OF CUMBERLAND COUNTY, PENNSYLVANIA
COUNTRYWIDE HOME LOANS, INC.
F/K/A COUNTRYWIDE FUNDING CORPORATION
Plaintiff CIVIL DIVISION
VS. No. 99-2992 CIVIL
DARREN M. BECK
JENNIE L. LAVENDER
Defendants
AFFIDAVIT OF SERVICE PURSUANT TO RULE 3129
COMMONWEALTH OF PENNSYLVANIA
CUMBERLAND COUNTY
SS:
I, FRANK FEDERMAN, ESQ., attorney for COUNTRYWIDE HOME
LOANS. INC. F/K/A COUNTRYWIDE FUNDING CORPORATION, hereby verify
that on AUGUST 9, 1999, true and correct copies of the Notice of
Sheriff's Sale were served by certificate of mailing to the
recorded lienholder(s), and any known interested party, see
Exhibit "A" attached hereto, and the Notice of Sale was sent to
defendant(s) on AUGUST 9, 1999 by first class mail and certified
mail return receipt requested, see Exhibit "B" attached hereto.
RANK FED RMAN, ESQUIRE
Attorney for Plaintiff
Date: November 8. 1999
O
d
C?
V
z V1
N
O
G
Y d
? O
I
'D L
• R b
u ?l u
a ? +
z<o
I
'osucE _ -----
Fer?FN - - _---._
IAL TE -_
° '" .
_
I
PESr.rnec ccuvFnr
FCCE?Pi Q`
Q
?
9
M '
II.
>EFVICE =ECrr'mrCE -GELUPNREMPT *
j
F
P\1? I'
c' t;'4 P" UCE 4.1 TEES
1
N
SENT TO: " 'NOT PO"R INTERNrmam WL -
(I t 2,.f SIXIAL b
3y9 0
we
I
?, 0 <
N Jplihle: L. +.,iVH6UL•'ri °` G5?' oc
m iu ,'1 XTh STh STGe:ti a::,jjS r
p-. ?r yilY:\d, 2a i 7aS.j c r c
VC
a Nw ( ..
UC
PS FORM 3800 US Postal Service Receipt for
Certified Mail o
a
- - - - - - - - - - - - - - - -
FEru? N
C4 ?EE LE :'CFY - - - -----
P q
` A
.'1 FCCEIPL F
Z W
Q• ?EFVICE
L:UL.WAGE A).O ICES
N H U AN
SEN
z
(u TE
T TO: FOR TOR INPNAtlON0. MAIL
.' 6
ru L, LL
QO
Ill a a
tip
w
X0
a 0e
PS FOF rM ;FOo US Postal Service Receipt for
Certified Mail g
g
>_
Cr
I
u?S7
CL !.'
?=L
v
tr,
n:
C: !'I
Gl -j
la C_7
."w
STATE OF PENNSYLVANIA, t
COUNTY OF CUMBERLAND J ss.
Robert P Ziegler
h ------------------------------------------------------------------------------ Recorder of
Deeds in and for said County and State do hereby certify that the Sheriff's Deed in which ----------------
Countrywide Home Loans Inc f/k/a Countrywide Funding Corp
------------------------------------------------------------------------------------ is the grantee
the same having been sold to said grantee on the ____8th_______________________________________ day of
December 99
A. D., 19_ 99____, under and by virtue of a writ______________
Execution ----------------issued on the __ 11th
day of ____ August -- --A.D., 19___ 99, out of the Court of Comman Pleas of said County as of
------------------ Civil.--------------------------------------------------------- Term, 19---99-
Number __ZH2-------- at the suit of---- QL?t?9?a@_HP!M-lou-*--IrlrJ! D CPint bYW_0Q 13-LO Corp
Darren M Beck & Jennie L Lavender
-------------------------------against---------------------------------------------------- is
duly recorded in Sheriff's Deed Book No. Page 1138----.
IN TESTIMONY WHEREOF, I have hereunto
set my hand and seal of said office this --- ???___ day
of ---- - ----------- A. D., I9--. ° c y
/V?Jv1t?-
rJ? /Recorder of Deeds
Recorder of Deed; Cumberland CCU* Clftk PA
MY Commasion Esp a the First "4i et in. 2W
Countrywide Home Loans, Inc. In the Court of Common Pleas of
-vs- Cumberland County, Pennsylvania
Darren Beck and Jennie L. Lavander No. 99-2992 Civil Term
Dawn L. Kell, Deputy Sherrff, who being duly sworn according to law, says on
September 28, 1999 at 6:11 o'clock P.M. EDST, she posted a copy of real Estate Writ
Notice Poster and Description in the above entitled action upon the property of Darren
Beck and Jennie L. Lavander located at 4155 Kittatinny Drive, Mechanicsburg,
Cumberland County, Pennsylvania according to law.
Kathy J. Clarke, Deputy Sheriff, who being duly sworn according to law, says on
September 1, 1999 at 10:31 o'clock A.M. EDST, she served true copy of Real Estate
Writ Notice and Description, in the above entitled action upon one of the wihtin named
defendants to wit: Darren Beck, by making known unto Darren Beck at 4155 Kittatinny
Drive, Mechanicsburg, Cumberland County, Pennsylvania, its contents and at the same
time handing to him personally the said true and attested copies of the same.
Michael E. Barrick, Deputy Sheriff, who being duly sworn according to law, says on
August 18, 1999 at 4:30 o'clock P.M. EDST, lie served true copy of real Estate Writ
Notice Poster and Description in the above entitled action upon one of the within named
defendants to wit: Jennie Lavander, by making known unto Jennie Lavander at 26 north
8u' street, Lemoyne, Cumberland County, Pennsylvania, its contents and at the same time
handing to her personally the said true and attested copies of the same.
Dawn L. Kell, Deputy Sheriff, who being duly sworn according to law, says on
September 28, 1999 at 6:11 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: Darren
Beck, by making known unto Darren Beck at 4155 Kittatinny Drive, Mechanicsburg,
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 by first class mail to one of the
within named defendants to wit: Darren Beck to his last known address 4155 Kittatinny
Drive, Mechanicsburg, Pennsylvania. This letter was mailed under the date of September
29, 1999 and never returned to the Sheriff s office.
R. Thomas Kline, Sheriff, who being duly sworn according to law, says he served
the above Real Estate Writ Notice Poster and Description in the following manner: The
Sheriff mailed a notice of the pendency of the action by first class mail to one of the
within named defendants to wit: Jennie L. Lavander to her last known address 4155
Kittatinny Drive, Mechanicsburg, Pennsylvania. This letter was mailed under the date of
October 1, 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 out cry 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 Countrywide Home Loans, Inc., F/K/A Countrywide
Funding Corporation. It being the highest bid and best price received for the same
Countrywide Home Loans, Inc., F/K/A Countrywide Funding Corporation of 6400
Legacy Drive, MS: PTX-35, Plano, Texas being the buyer in this execution paid to
Sheriff R. Thomas Kline the sum of $ 836.47 it being sheriff's costs.
Sheriff's Costs:
Docketing 30.00
Poundage 16.40
Posting Bills 15.00
Advertising 15.00
Acknowledging Deed 30.00
Auctioneer 10.00
Law Library .50
County 1.00
Mileage 35.96
Certified Mail .79
Levy 15.00
Surcharge 24.00
Law Journal 267.50
Patriot News 300.19
Share of Bills 23.63
Distribution of proceeds 25.00
Sheriffs Deed 26.50
$ 836.47 Pd. By Atty
01/07/00
Sworn and Subscribed To Before Me
This apt Day of
S
2000, A.D. )11?g? L
Pr th notary
R. Thomas Kline, Sheriff
By a,.
3e ?•'? e,k.a?3?'i
y s440
PROOF OF PUBLICATION OF NOTICE
IN CUMBERLAND LAW JOURNAL
(Under Act No. 587, approved May 16, 1929), P. L.1784
STATE OF PENNSYLVANIA :
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 following dates,
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 BALE NO. 27
Writ No. 99-2992 Civil
Countrywide Home Loans. Inc.
VS.
Darren M. Beck and
Jcrime L. Lavender
Atty.: Frank Federman
ALLTHAT CERTAIN lot or tract of
land situate In Hampden Township,
Cumberland County, Conunonwealtl
of Pennsylvania, more particularly
bounded and described as follows, to
wit:
BEGINNING at a point on the
southern right-of-way line of Ititta-
tinny Drive (64 feet wide private), at
the dividing line of Lot # 103 and Lot
#102, said point also being located
373.18 feet west of the southwest
corner of K1ttaUnny Drive and Tus-
say Court;
THENCE by line of Lot 103 and
Passing through the centeltine of a
-?--3. partition wall South 07 degrees 57
j minutes 58 seconds West 100.00ket
r$ to a point: THENCE by land of Moun-
tarn View Village Home Owners Asso-
clait North 82 degrees 02 minutes
02 s .e_nds West 20.00 feel ton pouu;
'. THENCE by llnc of lAlt g101 rind
passing through the center parimon
wall North 07 degrees 57 minutev;113
seconds East 100.00 feel lo a point
on the southern right -ofu•cty iule of
Kittatinny Dive; TIIENCF- by nand
right-of-way line South 82 degi res 02
minutes 02 xconds East 20.00 feel
to a peat, the place of BEGINNING.
.. CONTAINING 2.000 squire fret.
BEING Lot # 102 on tile Pinal Sub-
dlvisiorl Plan of Niountalll View VIl-
]age, Phase IV, Recorded In Plan Balk
60. Page 8713.
IIIIIIIIIIIIIIIR Bc: ng k: "wu as KI(Whlliv
Drive, Mechanicsburg. PA 17055.
TAX PARCEL NO. 10-15-1285-
152.
TITLE TO SAID PREMISES IS
VESTED IN DARREN M. BECK. SIN-
GLE PERSON AND JENNIE L, LAV-
ENDER SINGLE PERSON BY DEED
FROM 17NGS`r HOMES. INC. DATED
8/30/95 AND RECORDED 10/4/05
IN DEED BOOK 129, PAGE. 291.
Ro er M. Morgenthal, Editor
SWORN TO AND SUBSCRIBED before me this
--L _day of NOVEMBER. 1999
NUTARfAt SEAL
L016 E. SNYDER, f,brcry polig,
Carbide 60ro, Cumbodand C,," PA
My Commiuim E#plr" Momh S, 7001
i
1
l
1!
THE PATRIOT NEWS
THE SUNDAY PATRIOT NE rV'S
Proof of Publication
Underact No. 587, Reproved Map 16.1929
Commonwealth of Pennsylvania, County of Dauphin) as
Michael Morrow being duly sworn according to law, deposes and says:
That he is the Assistant Controller of THE PATRIOT-NEWS CO., a corporation organized and existing under the laws
of the Commonwealth of Pennsylvania, with its principal office and place of business at 812 to 818 Market Street, in
the City of Harrisburg, County of Dauphin, State of Pennsylvania, owner and publisher of THE PATRIOT-NEWS and
THE SUNDAY 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 41h, 1854, and September 181h, 1949, respectively, and all have been continuously published ever since;
That the printed notice or publication which is securely attached hereto Is exactly as printed and published in
their regular dally and/or Sunday and Metro editions/issues which appeared on the 26th day of October and the 2nd
and 9th day(s) of November 1999. That neither he nor said Company is interested in the subject matter of said
printed notice or advertising, and that all of the allegations of this statement as to the time, place and character of
publication are true; and
That he has personal knowledge of the facts aforesaid and is duly authorized and empowered to verify this
statement on behalf of The Patriot-News Co. aforesaid by virtue and pursuant to a resolution unanimously passed and
adopted severally by the stockholders and board of dire ors of the said Company and subsequently duly recorded in
the office for the Recording of Deeds In and for said Go ty of Dauphin in Miscellaneous Book W",
Volume 14, Page 317. ( 1 1 / J.\ ?Yl
PUBLICATION 11w I/ I
COPY Sworn to a subscribed ohmic thil5 18th y o Nove e 1 A.D.
S A L E #27 Ta L iussoll, Notary Pub ro
I la „burg, Dauphin County -r
My Commission Expires Jun, 6,200 " NOT Y PUBLIC
Member, Pennsylvania Association of Notaries
My commission expires June 6, 2002
CUMBERLAND COUNTY SHERIFFS OFFICE
COURTHOUSE
CARLISLE, PA. 17013
Statement of Advertising Costs
To THE PATRIOT-NEWS CO., Dr.
For publishing the notice or publication attached
hereto on the above stated dates $ 298.69
Probating same Notary Fee(s) $ 1.50
Total $ 300.19
Publisher's Receipt for Advertising Cost
THE PATRIOT-NEWS CO., publisher of THE PATRIOT-NEWS and THE SUNDAY PATRIOT-NEWS, newspapers of general
circulation, hereby acknowledge receipt of the aforesaid notice and publication costs and certifies that the same have
been duly paid. w•r , ?._ THE PATRIOT-NEWS CO.
REAL ESTATE SALE No. 27 By ..............................
Wrft Na 99.2992
Clvll Term
Countrywide Home
LOAN. r.
L Dmw 11111. Back ind
Jennie L Lavender
Fedeirman
A RIPTION
ALL THAT CERTAtM,tot or tied of lertd
situate N Hmrodon ToimNflp, Cutrtfaarl"
Cortlg Coalmar1 a 1 Penrreylvada,
per arfe , ,age.a ua aerawaa
In of Ld 103 a
Iarerts of a se
seconds West 20.00 fool to a
DE by line of Lot 6101 and
u0h the center part!tlon well
revs 57 minutoc 58 seconds
?eet to a pant on the wuthem
ens of K8lstinny Drive;
MW tipM ai- 0 One South 02
mkwtea 02 sooacIs East
M0 2,006 satwre Mel.
t.nt 9102 on " FMW
knowm al 1155 KRt" 00%%
was is
Pmon ,
i1
tram
and
Pa9a
P-EP-LESTATI SALE NO 27
31,000.00 Advance Costs Paid 8/11/99 Arr. Frank Federman
Assessed Valuation S 6840.00
WRITivO. 99-2992 Civil
dountrywide Home Loans, inc.
VS
Darren M. Beck and Jennie L. Lavender
4155 Kittatinny Drive
Mechanicsburg, PA 17055
REA[. DEBT $ 91,259.96
I\TEREST 8/5/99 to 12/8/99 per diem 15.00 1,890.00
ATT'S FEES
1VKT COSTS ATTY 131.22
ESCROW
LATE CH.•kRGE
SHERIFF'S COSTS
Docketing 30.00
Poundage 16.40
Postine Bills 15.00
Adve::isina 15.00
Ackno%vledeine Deed 30.00
Auctioneer 10.00
La-,v L ibrarv .50
Counr: 1.00
Nfileas. 35.96
Ce-1 Mail .79
Le-,-v 15.00
Postpone Sale
Surciarse 24.00
Leal S>--arch
=.DVrRT1SFNG:
La%v Joumal 267.50
Patriot 300.19
Share of Bills 23.63
Distribution of P;oceecs 25.00
R.t-if s Deus 26.50
ST-kMPS
Pa. Transfe: Tax
T%vp or Boro Tran-fe: Tax
TAPES
Sewer 107.62
4-"
COUNTRYWIDE HOME LOANS, INC.
i F/K/A COUNTRYWIDE FUNDING
CORPORATION
VS.
DARREN M. BECK
JENNIE L. LAVENDER
CUMBERLAND COUNTY
COURT OF COMMON PLEAS
CIVIL DIVISION
NO. 99-2992 CIVIL
NOTICE OF SHERIFF'S SALE OF REAL PROPERTY
August 5, 1999
TO: DARREN M. BECK JENNIE L. LAVENDERE
4155 KITTATINNY DRIVE 26 NORTH 8TH STREET REAR
MECHANICSBURG, PA 17055 LEMOYNE, PA 17043
**THIS FIRM IS A DEBT COLLECTOR ATTEMPTING TO COLLECT A
DEBT AND ANY INFORMATION OBTAINED WILL BE USED FOR
THAT PURPOSE. IF YOU HAVE PREVIOUSLY RECEIVED A
DISCHARGE IN BANKRUPTCY, THIS IS NOT AND SHOULD NOT BE
CONSTRUED TO BE AN ATTEMPT TO COLLECT A DEBT, BUT
ONLY ENFORCEMENT OF A LIEN AGAINST PROPERTY.**
Your house (real estate) at 4155 KITTATINNY DRIVE,
MECHANICSBURG, PA 17055, is scheduled to be sold at the Sheriff's
Sale on DECEMBER 8. 1999 at 10:00 a.m. in the Cumberland County
Courthouse, South Hanover Street, Carlisle, PA 17013, to enforce
the court judgment of $91,259.96 obtained by COUNTRYWIDE HOME
LOANS, INC. F/K/A COUNTRYWIDE FUNDING CORPORATION (the mortgagee)
against you. If the sale is postponed, the property will be
relisted for the MARCH 1. 2000 Sheriff's Sale.
NOTICE OF OWNER'S RIGHTS
YOU MAY BE ABLE TO PREVENT THIS SHERIFF'S SALE
To prevent this Sheriff's Sale, you must take immediate
action:
1. The sale will be cancelled if you pay to the mortgagee
the back payments, late charges, costs and reasonable
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 1 ?,gment, 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.)
YOU MAY STILL BE ABLE TO SAVE YOUR PROPERTY AND YOU HAVE OTHER
RIGHTS EVEN
E
IF TH SHERIFFS SALE DOES TARE PLACE.
1. If the Sheriff's Sale is not stopped, your property will
be sold to the highest bidder. You may find out the price bid by
calling (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 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 proposed schedule of distribution of the money
bid for your house will be prepared by the Sheriff not later than
thirty (30) days after the sale. The schedule shall be kept on
file with the SHeriff and will be made available for inspection in
his office. The 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 filing of
the proposed schedule.
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
y .
ALL TA2.T C 9 AZN lot or OraCt of land situate in tt=pdca
Townghip, Cumberland County, Ccmmcm+ealth Of DennX71vania, Wore
particularly bounded and desczibed as follows, to Witi
Bxeian7Na at a point on the southern right-of-way line of
Xittatinny Drive (61 feet vide private). at the dividing line of
Lot 4103 and Lot 0102, said point also being located 373.18 feet
West of the southwest corner or itlttatiaay Drive and v4ssay court;
TMM= by line of Lot 100 and pasaing through the
centsrline of a partition wall South 07 degrees 57 ninutes 58
seconds West 1.00.00 feet to a point) THENCH by land of eountain
View Village Roma owners Association North 82 degrees 02 minutes 01
seconds West 20.00 feet to a point; THENCE by line of Lot 0107• and
passing through the Center Partition wall North 07 degrees 57
minutes 58 seconds Bast 100.00 feet to a point on the southern
rie.0-of-way line of Kittatinny Drive; TIMNCE by said right-of-way
73E6I: mZn tea ea seeonan tiaec aa.ao s.ee r.* a
lino South 82, acgrees 03
point, the
CCHTAMMG 21000 square feet.
BeING Lot i10Z an the Final Sukdivisicn plan of mountain
View Village', Phase IV. Rccoaded in Flan BOOK 60, Page 87B.
Being known as 4155 Kittatinny Drive, Mechanicsburg, PA 17055.
TAX PARCEL NO. 10-15-1285-152
TITLE TO SAID PREMISES IS VESTED IN DARREN M. BECK, SINGLE PERSON AND
PAGE S 29HOMES, INC. DATED 8/30/95
JENNIE L AND RECORDED SINGLE PERSON DEED BOOK F129, ROM
COUNTRYWIDE HOME LOANS, INC.
F/K/A COUNTRYWIDE FUNDING CORPORATION
Vs.
. CUMBERLAND COUNTY
. COURT OF COMMON PLEAS
. CIVIL DIVISION
DARREN M. BECK
JENNIE L. LAVENDER NO. 99•-2992 CIVIL
AFFIDAVIT PURSUANT TO RULE 3129
(Affidavit No. 1)
CORPORATION, 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 4155 KITTATINNY DRIVE MECHANICSBURG PA
17055.
1. Name and address of Owner(s) or reputed Owner(s):
NAME LAST KNOWN ADDRESS (if address
cannot be reasonably ascertained,
please so indicate)
DARREN M. BECK 4155 KITTATINNY DRIVE
MECHANICSBURG, PA 17055
JENNIE L. LAVENDER 26 NORTH STH STREET REAR
LEMOYNE, PA 17043
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:
N? LAST KNOWN ADDRESS (if address
cannot be reasonably ascertained,
please so indicate)
SECURITY PACIFIC CONSUMER 6520 CARLISLE PIKE SUITE 155
DISCOUNT COMPANY MECHANICSBURG. PA 17055
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)
ON
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 so indicate)
ONE
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 so indicate)
NONE
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)
MOUNTAIN VIEW VILLAGE 4175 MOUNTAIN VIEW ROAD #102_
80MEOWNERIS ASSOCIATION MECHANICSBURG, PA 17055
TENANT/OCCUPANT 4155 KITTATINNY DRIVE
MECHANICSBURG, PA 17055
DOMESTIC RELATIONS OF 13 NORTH HANOVER STREET
CUMBERLAND COUNTY 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 IS Pa. C.S. Sec. 4904 relating to unsworn
falsification to authorities.
August 5, 1999 / aL? mil` ?'(- )
DATE FRANK FEDERMAN, ESQUIRE
Attorney for Plaintiff
WRIT OF EXECUTION and/or ATTACHMENT
COMMONWEALTH OF PENNSYLVANIA) NO. 99-2992 CIVIL ft Term
COUNTY OF CUMBERLAND) CIVIL ACTION - LAW
TO THE SHERIFF OF Cumberland COUNTY:
To satisfy the debt. Interest and costs due Count M de Hgm-Loans . Tnc.
from Darren M. Beck and Jennie L. Lavender
DEFENDANT(S)
(1) You are directed to levy upon the property of the defendant(s) and to sell see legal description
(2) You are also directed to attach the property of the defendant(s) not levied upon in the possession of
GARNISHEE(S) as follows:
and to 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) Ifpropertyofthedefendant(s)notlevied upon ansubject toattachment isfoundinthepossessionofanyoneother
than a named garnishee, you are directed to notify him/her that he/she has been added as a garnishee and is enjoined as above
stated.
Amount Due $91,259.96
Interest 8/5/99 to 12/8/99.$1,890.00 _
Ally's Comm (per diem $15.00)
%
Ally Paid $131.22
Plaintiff Paid
Date: August 11, 1999
REQUESTING PARTY:
Name Frank Federman, Esq.
Address: Two Penn Center Plaza, Suite 900
L.L. $.50
Due Prothy $1.00
Other Costs
Curtis R. Long
I ?1(Prothonotary, Civil Division
by: f? a t n V 1 1??C11(ll _1??
Deputy
Philadelphia, PA 19102
Attomey tor: Plaintiff
Telephone: 215-563-7000
Supreme Court ID No. _ 1224
REAL ESTATE SALE No,17
on ``°??' `g49 the sheriff levied upon the defendants
interest in the real property situated in
Cumberland County, Pa.. known and numbered as:
and more fully described on EAhVt "A" filed with
this writ and by this reference incorporated herein.
Date:-AAr. Z ea , 994
BY'
dlNdAI SNN3d
71c;; j 1V`)
661 Rd ge E Bill
JAURS 71U J0 331"0
FEDERMAN AND PHELAN
By: FRANK FEDERMAN, ESQUIRE
IDENTIFICATION NO. 12248
TWO PENN CENTER PLAZA, SUITE 900
PHILADELPHIA, PA 19102
(2151 563-7000
COUNTRYWIDE HOME LOANS INC.
F/K/A COUNTRYWIDE FUNDING CORPORATION
6400 LEGACY DRIVE
MS: PTX-35
PLANO, TX 75024-3632
V.
Plaintiff
DARREN M. BECK
JENNIE L. LAVENDER
4155 KITTATINNY DRIVE
MECHANICSBURG, PA 17055
Defendant(s)
ATTORNEY FOR PLAINTIFF
COURT OF COMMON PLEAS
CIVIL DIVISION
TERM
NO.
CUMBERLAND COUNTY
CIVIL ACTION - LAW
MORTGAGE FORECLOSURE
NOTICE
THIS IS AN ATTEMPT TO COLLECT A DEBT AND ANY
INFORMATION OBTAINED WILL BE USED FOR THAT PURPOSE.
You have been sued in court. if you wish to defend against the
claims set forth in the following pages, you must take action
within twenty (20) days after this Complaint and Notice are
served, by entering a written appearance personally or by
attorney and filing in writing with the court your defenses or
objections to the claims set forth against you. You are warned
that if you fail to do so the case may proceed without you and a
judgment may be entered against you by the court- without further
notice for any money claimed in the Complaint or for any other
claim or relief requested by the Plaintiff. You may lose money
or property or other rights important to you.
YOU SHOULD TAKE THIS PAPER TO YOUR LAWYER AT ONCE. IF YOU DO NOT
HAVE A LAWYER OR CANNOT AFFORD ONE, GO TO OR TELEPHONE THE OFFICE
SET FORTH BELOW TO FIND OUT WHERE YOU CAN GET LEGAL HELP.
CUMBERLAND COUNTY
CUMBERLAND COUNTY BAR ASSOCIATION
2 LIBERTY AVENUE
CARLISLE, PA 17013
(717) 249-3166
1. Plaintiff is
COUNTRYWIDE HOME LOANS, INC.
F/K/A COUNTRYWIDE FUNDING CORPORATION
6400 LEGACY DRIVE
MS: PTX-35
PLANO, TX 75024-3632
2. The name(s) and last known address(es) of the Defendant(s)
are
DARREN M. BECK
JENNIE L. LAVENDER
4155 KITTATINNY DRIVE
MECHANICSBURG, PA 17055
who is/are the mortgagor(s) and real owner(s) of the
property hereinafter described.
3. On 9/6/95 mortgagor(s) made, executed and delivered a
mortgage upon the premises hereinafter described to
SOVEREIGN BANK which mortgage is recorded in the Office of
the Recorder of CUMBERLAND County, in Mortgage Book No.
1285, Page 556. By Assignment of Mortgage recorded 5/6/96
the mortgage was assigned to PLAINTIFF which Assignment is
recorded in Assignment of Mortgage Book No. 519, Page 478.
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 1/1/99 and
each month thereafter are due and unpaid, and by the terms
of said mortgage, upon default in such payments for a period
of one month, the entire principal balance and all interest
due thereon are collectible forthwith.
6. The following amounts are due on the mortgage:
Principal Balance $82,255.24
Interest 2,757.06
12/1/98 through 5/1/99
(Per Diem $18.02)
Attorney's Fees 4,112.00
Cumulative Late Charges 121.56
9/6/95 to 5/1/99
Cost of Suit and Title Search 550.00
Subtotal 89.795.86
Escrow
Credit 283.84
Deficit 0.00
Subtotal (283.84)
TOTAL $89,512.02
7. The attorney's fees set forth above are in conformity with
the Mortgage documents and Pennsylvania Law, and will be
collected in the event of a third party purchaser at
Sheriff's Sale. If the Mortgage is reinstated prior to the
Sale, reasonable attorney's fees will be charged.
8. This action does not come under Act 6 of 1974 because the
original mortgage amount exceeds $50,000.
9. 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.
WHEREFORE, PLAINTIFF demands an in rem Judgment against the
Defendant(s) in the sum of $89,512.02, together with interest
from 5/1/99 at the rate of $18.02 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
hr'r. TH26T CERTAIN lot or tract of land situate in Hampden
Tbwnship, Cumberland County, Commonwealth of Pennaylvania, more
particularly bounded sad described as•follows, to. wits ine BEG33MMIG
(s at a 1poixxt DEL * the wide private) ,, ate theg divid,iag line Of
Kittatinny Drive (64 feet t w
Lot 0103 and Lot #102, said Point also being ve and Tussey Court; Iccated 373.18 feet
Croat of the southwoAt earner of KietatiaaY Dr
THENCE by line of riot 103 and passing through the
centerline of a partition wall South 07 dagreew 57 aaiautes 58
.View village Home owners As ociationtNorth a'28 deby, gre s 02 minutes, 02
seconds Nest 20 .00 feat to a point; THENCE by •llae of Lot i`r101 and
passing through the center partition. well North 07 degrees 57
the southern
minutes SS seconds East 100.00 feet to a poiaq oa
right-of-way line of Kittatinny Drive; THENCE by said right-of-way
minutes 02 seconds East 20.00 feet to a
line South 62 degrees BEGINNING.
point, the place
CONTA339IIrC3 2,000 square feet.
BESNG Lot #102 on the Final Subdivision Plan of Mountain
view Village, Phase Iv. Recorded in Plan BOOK 60, page 878.
BS=NG PART OF TSE SAME PREMMSES which The SSS Group, a
hip by doing business am
Pegnsylvaania limited partnership trading and
dated April 10S
Group. a Pennaylvania general p
1994, and recorded April 29, 1994 in the Of flce of the Recorder of
Yingat iHom s ?rIne. a
Deeds in and for ranted and conveyad Puntoennsylvani
104, Page 779,
PenasyLvanla corporation, the Grantors herein.
PREMISES BEING: 4155 KITTATINNY DRIVE
VERIFICATION
C.?z?bcEh Q;VAhereby states that he/she is ?Ce-
CecS?c?C??
of CourjEt.,:V. at lkow.e 1...oran5 ,T.*Je-.
mortgage servicing agent for Plaintiff in this matter, that he/she
is authorized to take this verification, and that the statements
made in the foregoing Civil Action in Mortgage Foreclosure are true
and correct to the best of his/her knowledge, information and
belief. The undersigned understands that this statement is made
subject to the penalties of 18 Pa. -C-S- 'Sec. 4904 relating to
unsworn falsification to authorities.
u
i {3 9
DATE: -5
Q
OCOL X99 ("!.
M61 Vd'? r'IOP i .r.
MEW JaluaO
NV 13Hd aNY N V AE-Ki:j
Mill". M - ' uiWtltW
-1 IM9N?W qn. uv N Y?ruuu y
11.10 'IrAl a:rs n.
SHERIFF'S RETURN - REGULAR
CASE NO: 1999-02992 P
COMMONWEALTH OF PENNSYLVANIA:
COUNTY OF CUMBERLAND
COUNTRYWIDE HOME LOANS INC
VS.
BECK DARREN M ET AL
DAWN KELL
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 BECK DARREN M the
defendant, at 18:08 HOURS, on the 25th day of May
1999 at 4155 KITTATINNY DRIVE
MECHANICSBURG, PA 17055 CUMBERLAND
County, Pennsylvania, by handing to DARREN BECK
a true and attested copy of the NOTICE AND COMPLAINT IN
together with MORTGAGE FORECLOSURE
and at the same time directing His attention to the contents thereof.
Sheriff's Costs: So answers:
Docketing 18.00
Service 8.68 L
Affidavit .00
Surcharge 8.00 omas ine, ri --'
$34.b8-FEDERKAN & PHELAN
05/27/1999 IJ nQ
by o iAl'I l ?C Ate.
e u y arieriff
Sworn and subscribed_ro before me
this A?L day of
A SHERIFF'S RETURN - REGULAR
CASE NO: 1999-02992 P
COMMONWEALTH OF PENNSYLVANIA:
COUNTY OF CUMBERLAND
COUNTRYWIDE HOME LOANS INC
VS.
BECK DARREN M ET AL
RICHARD SMITH , 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 LAVENDER JENNIE L the
defendant, at 16:29 HOURS, on the 26th day of May
1999 at 26 N 8TH REAR
LEMOYNE, PA 17043 CUMBERLAND
County, Pennsylvania, by handing to JENNIE LAVENDER JAMES
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
v
6.00 So answers:
.00
10.00
.00
8.00 R-:" omas ine, 5 e
4 FEDER 05/27/1999
by
Sworn andsubscribed to before me
this /19 day of Lt1U
FEDERMAN AND PHELAN
BY: FRANK FEDERMAN
ATTORNEY I.D. NO. 12248
SUITE 900
TWO PENN CENTER PLAZA
PHILADELPHIA, PA 19102
(215) 563-7000
COUNTRYWIDE HOME LOANS, INC.
F/K/A COUNTRYWIDE FUNDING
CORPORATION
ATTORNEY FOR PLAINTIFF
Court of Common Pleas
Civil Division
CUMBERLAND COUNTY
DARREN M. BECK VS. NO. 99-2992 CIVIL
JENNIE L. LAVENDER
AFFIDAVIT OF SERVICE OF NOTICE OF SHERIFF'S SALE
PURSUANT TO P R C P 404(2)/403
FRANK FEDERMAN, ESQUIRE, Attorney for Plaintiff, hereby certifies
that service of the Notice of Sheriff's Sale was made by sending
a true and correct copy by certified mail to Defendant (s) DARREN M.
BECK at 4155 KITTATINNY DRIVE, MECHANICSBURG, PA 17055 which notice
of Sheriff's Sale was received by Defendant(s) DARREN M. BECK on
AUGUST 12, 1999 as evidenced by the attached return receipt.
The undersigned understands that this
the penalties of 18 PA C.S. s
falsification to authorities.
statement is made subject to
4904 relating to unsworn
FRANK FEDERMAN, ESQUIRE
DATE: AUGUST 18. 1999
s Check box sl right it yd, MI Resbk.YeC pdAVry, ..
P" ? mrro " BOO" I the mdse d ft brm so Ihl w eri ielurn M4 cW
s Atlorh U* lamb the ITW of the msibka, 11 IM back k specs do" not p"J.
e The F1eNm Racebt wYl W.
to vnnm the sedge ey dsMI enl Ile me wheirey.
t m W
( `ti%4155 Y.3$111?lumn muiz ab.
x' Wue? IPA 17055 ? t y5 ?I.
I
t.. `°'c yr, .J- >•kt'
z ,a' t3yp
7.
5. Reca(ved B _ .?..(??. ,. .
5.S
X
PS FORM 381,1 De er 1
t11 `il juL lliLLI t
r
I also With to rectI
fdlowin0 eer kes (kr an azL? i
Ae rkted Delivery
Co 1 poetrnastor for fee.
b Number
P 973 222 991
X CERTIFIED
CV 7
U? U
t !
L r N
]u,
U
Cif U
B
FEDERMAN AND PHELAN
BY: FRANK FEDERMAN
ATTORNEY I.D. NO. 12248
SUITE. 900
TWO PENN CENTER PLAZA
PHILADELPHIA, PA 19102
(215) 563-7000
COUNTRYWIDE HOME LOANS, INC.
F/K/A COUNTRYWIDE FUNDING
CORPORATION
Vs.
DARREN M. BECK
JENNIE L. LAVENDER
ATTORNEY FOR PLAINTIFF
Court of Common Pleas
Civil Division
CUMBERLAND COUNTY
NO. 99-2992 CIVIL
AFFIDAVIT OF SERVICE OF NOTICE OF SHERIFF'S SALE
PURSUANT TO P.R.C.P. .404(2)/403
FRANK FEDERMAN, ESQUIRE, Attorney for Plaintiff, hereby certifies
that service of the Notice of Sheriff's Sale was made by sending
a true and correct copy by certified mail to Defendant(s) JENNIE L.
LAVENDER at 26 NORTH 8TH STREET REAR, LEMOYNE, PA 17043 which
notice of Sheriff's Sale was received by Defendant(s) JENNIE L.
LAVENDER on AUGUST 12, 1999 as evidenced by the attached return
receipt.
The undersigned understands that this statement is made subject to
the penalties of 18 PA C.S. s 4904 relating to unsworn
falsification to authorities.
FRANK FEDERMAN, ESQUIRE
DATE: AUGUST 19, 1999
SENU e I also wlsh to recolvo the
• Clwck hov at rWltl it ycvuwrylw nnaliKbsl U!Ilwvy
• oln it Romp eM edlmaa al tlw mwmo or Ibla f.,,, ao IN t we con ntmn INa uN fQlOwlrlg 6 .ea ((Or an extra fee) You.
e Attach IN, lam to INI 1=1 or tho =11116 CO, ricled Dolit "t
ce, Of on IN, bock N awe does Rol m". ry.
• TM rlnlurn Racal" ws Show to whmn the utkb wee dethmrad aM en dots dolhdsd. Il pO9lnlaetef for .1 rt ?oa? roe 4s. Ikikb Numbor, i, rfY
4b.saPnc 973 222 9921 ??,
1*S* PA 11043
k' a t r /r/%I -'A "I
n " CERTIFIED
7. Data of
6. Receive, ,8y. (Pont Name1 - - 8. Addresse '9 Add ss .....
6. gnat : (Address ga t)
PS F 1d 38 ?49ece a ssa ; ... ::. Domestic Return Receipt
CC)
U-1 C%j
r
=
Cl)
cli
W'
_tJ CJ
LL.
C? C?
Cn
U
El *
FEDERMAN AND PHELAN
By: FRANK FEDERMAN
Identification No. 12248
Two Penn Center Plaza - suite goo
Philadelphia, PA 19102
(2.15) 563-7000
COUNTRYWIDE HOME LOANS, INC.
F/K/A COUNTRYWIDE FUNDING CORPORATION
6400 LEGACY DRIVE MS PTX-35
PLANO, TX 75024-3632
Vs.
DARREN M. BECK
4155 KITTATINNY DRIVE
MECHANICSBURG, PA 17055
JENNIE L. LAVENDER
26 NORTH 8TH STREET REAR
LEMOYNE, PA 17043
Attorney for Plaintiff
CUMBERLAND COUNTY
COURT OF COMMON PLEAS
CIVIL DIVISION
NO. 99-2992 CIVIL
PRAECIPE FOR JUDGMENT FOR FAILURE TO
ANSWER AND ASSESSMENT OF DAMAGES
TO THE PROTHONOTARY:
Kindly enter judgment in favor of the Plaintiff and against
DARREN M. BECK AND JENNIE L. LAVENDER, Defendant(s) for failure to
file an Answer to Plaintiff's Complaint within 20 days from service
thereof and for Foreclosure and Sale of the mortgaged premises, and
assess Plaintiff's damages as follows:
As set forth in Complaint
Interest - 5/1/99 TO 8/5/99
TOTAL
$89,512.02
$ 1,747.94
$91,259.96
I hereby certify that (1) the addresses of the Plaintiff and
Defendant(s) are as shown above, and (2) that notice has been given
in accordance with Rule 237.1, copy attached.
FRANK FEDERMAN, ESQUIRE
Attorney for Plaintiff
DAMAGES ARE HEREBY ASSESSED AS
DATE: Q :1 II -%f
INDICATEV.
P PROTHY \ ?'
;.FEDERMAN AND PHELAN
Frank Federman, Esquire
Identification No. 12248
Two Penn Center Plaza
Suite 900
Philadelphia, PA 19102-1799
(215) 563-7000
COUNTRYWIDE HOME LOANS, INC.
F/K/A COUNTRYWIDE FUNDING
CORPORATION
Plaintiff
Vs.
DARREN M. BECK
JENNIE L. LAVENDER
Defendant(s)
TO: JENNIE L. LAVENDER
26 NORTH 8TH REAR
LEMOYNE, PA 17043
DATE OF NOTICE: JUNE 16, 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
ATTORNEY FOR PLAINTIFF
: COURT OF COMMON PLEAS
. CIVIL DIVISION
CUMBERLAND COUNTY
NO. 99-2992
Frank Federman, Esquire
Attorney for Plaintiff
r,FEDERMAN AND PHELAN
Frank Federman, Esquire
Identification No. 12248
Two Penn Center Plaza
Suite 900
Philadelphia, PA 19102-1799
(215) 563-7000
ATTORNEY FOR PLAINTIFF
COUNTRYWIDE HOME LOANS, INC. COURT OF COMMON PLEAS
F/K/A COUNTRYWIDE FUNDING
CORPORATION CIVIL DIVISION
Plaintiff CUMBERLAND COUNTY
VS.
DARREN M. BECK
JENNIE L. LAVENDER
Defendant(s)
TO: DARREN M. BECK:
4155 KITTATINNY DRIVE
MECHANICSBURG, PA 17055
DATE OF NOTICE:
JUNE 16, 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 ANT
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
NO. 99-2992
Frank Federman, Esquire
Attorney for Plaintiff
J .
FEDERMAN and PHELAN
By: FRANK FEDERMAN
Identification No. 12248
suite 900
Two Penn Center Plaza
Philadelphia, PA 19102
(215) 563-7000
COUNTRYWIDE HOME LOANS, INC.
F/K/A COUNTRYWIDE FUNDING CORPORATION
VS.
DARREN M. BECK
JENNIE L. LAVENDER
ATTORNEY FOR PLAINTIFF
CUMBERLAND COUNTY
COURT OF COMMON PLEAS
CIVIL DIVISION
. NO. 99-2992 CIVIL
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 DARREN M. BECK is over 18 years of
age and resides at 4155 KITTATINNY DRIVE, MECHANICSBURG, PA 17055.
(c) that defendant JENNIE L. LAVENDER is over 18 years
of age, and resides at 26 NORTH 8TH STREET REAR, LEMOYNE, PA 17043.
This statement is made subject to the penalties of 18 Pa.
C.S. Section 4904 relating to unsworn falsification to authorities.
FRANK FEDERMAN, ESQUIRE
Attorney for Plaintiff
I
I
l ;
I C