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MCCABE, WEISBERG AND CONWAY, P.C.
BYt TERRENCE J. McCABE, ESQUIRE
Identification Number 16496
First Union Building
123 South Broad Street, Suite 2080
Philadelphia, Pennsylvania 19109
(215) 790-1010
Attorney for Plaintiff
Beneficial Consumer Discount Cumberland County
Company d/b/a Beneficial Mortgage Court of Common Pleas
Company of Pennsylvania
961 Weigel Drive
P.O. Box 8621
Elmhurst, IL 60126
V.
Barry Deitch a/k/a
Barry L. Deitch
101 East Main Street
Walnut Bottom, PA 17266
and
Gay Deitch a/k/a Gay L. Deitch
101 East Main Street
Walnut Bottom, PA 17266
and
United States of America
c/o United States Attorney
for the Middle District of
Pennsylvania
228 Walnut Street, P.O. Box 11754
Harrisburg, PA 17108
Number 99 •- Aka() el ??
`.IUi( /?
CIVIL ACTION/
MORTrAGE FORE •0 URE
NOTICE AVISO
You have been sued in court. If you wish to defend
against the claims set forth in the following
pages, you matt 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.
Le hen demandado a usted an is torte. Si usted
quiere defenderse de Betas demandas ex-puestes an
lea peginas siguientes, usted tiene veinte (20)
dies de plazo at partir de is fecha de to demands y
la notification. Hace falta asenter me
conparencia escrita o en persons o con un abogado y
entregar a is torte en fares escrita sus defenses o
sus objecicnes a Las demendas an contra de su
persona. Sea avisado que at usted no Be defiende,
la torte temara medidas y puede continuer Is
demanda en contra Buys sin previo aviso o
notification. Ademas, Is torte puede decidir a
favor del demendante y requiere qua usted cuipla
con todas lea provisioner de este deaanda. Usted
puede perder dinero o sus propiededes u otros
derechos importantes pare usted.
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 HELP.
Cumberland County Bar Association
2 Liberty Avenue
Carlisle, PA 17013
(717) 249-3166
LLEVE ESTA DEMANDA A UN ABOGADO
INMEDIATAMENTE. SI NO TIENE ABOGADO O
SI NO TIENE EL DINERO SUFICIENTE DE PAGAR
TAL SERVICO, VAYA EN PERSONA 0 LLAME
POR TELEFONO A LA OFICINA CUYA
DIRECCION SE ENCUENTRA ESCRITA ABAJO
PARA AVERIGUAR DONDE SE PUEDE
CONSEGUIR ASISTENCIA LEGAL.
Cumberland County Bar Association
2 Liberty Avenue
Carlisle, PA 17013
(717) 249-3166
McCABE, WEISBERG AND CONWAY, P.C.
BY: TERRENCE J. McCABE, ESQUIRE
Identification Number 16496
First Union Building
123 South Broad Street, Suite 2080
Philadelphia, Pennsylvania 19109
(215) 790-1010
Beneficial Consumer Discount
Company d/b/a Beneficial Mortgage
Company of Pennsylvania
961 Weigel Drive
P.O. Box 8621
Elmhurst, IL 60126
V.
Barry Deitch a/k/a
Barry L. Deitch
101 East Main Street
Walnut Bottom, PA 17266
and
Gay Deitch a/k/a Gay L. Deitch
101 East Main Street
Walnut Bottom, PA 17266
and
United States of America
c/o United States Attorney
for the Middle District of
Pennsylvania
228 Walnut Street, P.O. Box 11754
Harrisburg, PA 17108
Attorney for Plaintiff
Cumberland County
Court of Common Pleas
Number
1. Plaintiff is Beneficial Consumer Discount Company d/b/a
Beneficial Mortgage Company of Pennsylvania, a corporation duly
organized under the laws of Pennsylvania and doing business at the
above captioned address.
2. The Defendant is Barry Deitch a/k/a Barry L. Deitch, who
is one of the mortgagors and real owners of the mortgaged property
hereinafter described, and his last-known address is 101 East Main
Street, Walnut Bottom, PA 17266.
3. The Defendant is Gay Deitch a/k/a Gay L. Deitch, who is
one of the mortgagors and real owners of the mortgaged property
hereinafter described, and her last-known address is 101 East Main
Street, Walnut Bottom, PA 17266.
4. On February 3, 1998, the Defendant, United States of
America, acquired a lien against the premises hereinafter described
in the sum of $3,281.46, subordinate to the mortgagee hereinafter
referred to, by reason of Federal Tax Lien, Number 1998-623, in
favor of the United States of America against Gay Deitch, and which
is recorded in the Office of the Prothonotary of Cumberland County,
Pennsylvania.
5. Notice of this lien was filed on February 3, 1998, at the
Office of the Prothonotary of Cumberland County, by the Internal
Revenue Service, Scranton, Pennsylvania. A true and correct copy
of Notice of Federal Tax Lien is attached hereto and marked as
Exhibit "A."
6. By the filing of this action, Plaintiff seeks a judicial
sale of the premises hereinafter described.
7. On November 22, 1996, mortgagors 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 1353, Page 636.
8. The premises subject to said mortgage is described in the
mortgage attached as Exhibit "B" and is known as 87 Victory Church
Road, Gardners, PA 17324.
g, The mortgage is in default because monthly payments of
June 1998 and each
principal and interest upon said mortgage due
the terms of
month thereafter are due and unpaid, and by said
for a period of one month, f
mortgage, upon default in such ,
interest due thereon are
the entire principal balance and all
1 '
collectible forthwith. 10. The following amounts are due on the mortgage:
$35,022.09 a!
Principal Balance $ 81628.96
Interest 05/01/98 through. 04/15/99
(plus $13.42 per diem thereafter) $ 1,751.10
Attorney's Fee $ 225.00
Cost of Suit $ 125.00 'a5
Appraisal Fee $_
Title search
$45,952.15
GRAND TOTAL
11. 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
based on work actually performed.
attorney's fees will be charged
Act 6 of 1
iced by f
w
12. Notice of Intention to Foreclose as required
,
the Emergency mortgage
403) and notice required by
1974 (41 P.S. certified 3
been sent to Defendants
4Ff
Act of 1983 have b copies of such
r
mail on the date set forth in the true and correct
Exhibit
notices attached hereto as
I
WHEREFORE, Plaintiff demands Judgment against the Defendants
in the sum of $45,952.15, together with interest at the rate of
$13.42 per diem and other costs and charges collectible under the
mortgage and for the foreclosure and sale of the mortgage property
and that the lien of the United States of America be discharged.
TE ENCE J. Mc E Q RE
Attorney for Plaintiff
The undersigned, Robert F. Elston, hereby certifies that he is
the Foreclosure Specialist of the Plaintiff in the within action,
O-P- f F? (1.1 , and that he is authorized to
make this verification and that the foregoing facts are true and
correct to the best of his knowledge, information and belief and
further states that false statements herein are made subject to the
penalties of 18 PA.C.S. §4904 relating to unsworn falsification to
authorities.
ROBERT F. ELSTON
BS/BS/99 11:35:13 DS17L'1S->
85-65-99 88:07 C
DM9:JAM:kmm
DAVID M. BARASCH
United States Attorney
JOHN A. MORANO, JR.,
Assistant U.S. Attorney
309 Federal Building
Scranton, PA 18501
Phone: (717)348-2821•
Attorneys for Plaintiff
UNITED STATES OF AMERICA,
Plaintiff,
v
OAY DEITCH,
Defendant.
P1
TO: Prothonotary of Cumberland County
Dear Sir Cr Madam!
Fife the attached Abstract of
named, Gay Deitch, whose last known ad
17266, and in fhvor of the United States of
together with interest on unpaid principal ai
in the sum of $441.38; plus interest at the r
judgment, in the stun of 584.56; for filing i
sum of 5150.00; making a torsi due in the i
or^
215 790 1274 RightFBX Page 002
ID-717 P.61
/1 47, 1
IN THE COURT OF COMMON
PLEAS
OF CUMBERLAND COUNTY
CIVIL DIVISION
NO. (OaTEw
meat in your Court against the defendant above
was 101 Bast Main Street, Walmst Bottom, PA
ties, plaintA in the sum of $2,555.52 principal,
rate of 8.00 percent per annum through August 4,
tf 8,00 percent from August 4, 1997 to the date of
glowed pursuant to 28 U.S.C. §2412(ax2) in the
ant of $3,281.46.
r// "'All
BS/BS/99 11:35:54 DS17C15-> Z15 790 1274 RightFAX
8 Page 003
5-65-99 6813B C :D-717
P.92
ABSTRACT OF JUDGMENT
NOTICE
Parsuant 10 TWO 28, United States Cade, Section 3201, this judyiaent. upon the filmy of onto abooaat is the a noet in wW a
notke of tax &a would be tiled uad& paaynpl3 (1) sad (2) o(26 U.S.C. 46323(1), cntotn ¦ line on an rnl Property of the dehadsao($
and boo prlenty over an other Bew of oncvmbranots whiab toe perfated Ure'r in time The lien armed by this Melon is efhcdve, Dakar
r the 2fors0•yeu pe prinnodod of m 70 y preeusvem and Or exmaypnitatiema o(ewedme
u a B(dingea samMice of renow t" lr 18CL 13013C9 13013C9 of M"41 Is filed before th espintbn
or the '
lu(lpneat is filed. the ?murt
vi-proves
-- i vu the reruarsl, the lien shag reiue back to the dm the
Namn zed Addresses of Pudec agsbtot wbom judgmmm have
been obmbxd:
GAY DEITCH
101 Bur Maur Stem
Wahmt Bottom, PA 17266
Of Parries in whose tevos judpaente have ben obtained:
UNITED STAIRS OF AMERICA
(Kook, J.)
3:CM-1653
S ?. SSS. r? PA,.•iml
--?--?-..
S l
t
Noeaable David M. F
neren .
r.?n'
S United Saks Atwr:cy
-- John A. Morsm, Jr..,
TOTAL $3,281,46 309 Federal Buitdid8
Scrarum
PA 18301
PLUS Will= AT THE LEGAL ,
Phonw (717) 348.280(
RATE OF 5.34196
UNITED STATES OF AMMCA, CLERK'S OFFICE
CIVIL ACTION NO.: 3:CV.97-1653
I CERM, That the Foregoing Is a correct)
Dazed January 13,1997
MARY D'.
January 7, 1998
SCrtmmn, PA
MIDDLE DF9Mer OF PENNSYLVANIA
of rite lud
gmeut entered or registered by this Cart.
Clerk
?1
12/00/98 WE M17:a3 FAA 717
? l .lu ,L
24a 0424 JIMFLUAL CANLISLB
OPEN-END MORTGAGE
THIS MORTGAGE SECURES VUTURE ADVANCES WHICH MORTGAGEE
HAS A CONTRACT1141. OBLIGATION TO MAKE
Lloa5
THIS MORTGAGE, entered into this 22ND _ dry of NOVA„ _, 19,x¢., between
BARRY nvr^nR eNn rev nnr'U'it , hereafter called "Mortgagors!' and
S BENEFICIAL. CONSUMER DISCOUNT COMPANY, A. Pennsylvania corporation,
BENEFICIAL CONSUMER DISCOUNT COMPANY d/b/a Beneficial Mortgage Co. of Ponesylvants,
a Pence Corporation, I S HANOVER ST. CARLISLE
her as office and and place business at Pennsylvania,
herer celled •'Mongagea,'•
W11WESSETH, that an wore payment by Mortgagors of '& Credit Line Aecou
d m Allinson t etuRer celled " ement; • of even
ate berewith, by which Mortgagee is obligated to make toms and advances up to S ffE30 , 00 items treer called "Cmdlt
Line" and an other ob Igadom of Mortgagors under the terms and provisions of this MortgageMongsgon do by these presents, sell,
?ranI and c?rhwey to Mortgagee AT 1 c toll described real esta a he Rcx Mortgage, "Pro M situated to the ? City
lomuah ®TW'nship of 9bOTfC Irp I ?tf? , County of LIdfIDL?E?.AND onwealth of Pun
described a follows: - rylvania,
ALL THAT CERTAIN PROPERTY SITUATED IN THE TOWNSHIP OF SOUTH MIDDLETON IN THE COUNTY OF
CUMBERLAND AND COMMONWEALTH OF PENNSYLVANIA. BEING DESCRIBED AS FOLLOWS: TRACT 1 BEING
LOT NO. 4 TRACT NO. 2 BEING LOT NO, 3. BEING MORE FULLY DESCRIBED IN A FEE SIMPLE DEED
DATED 01115/1991 AND RECORDED 01/15/1991, AMONG THE LAND RECORDS OF THE COUNTY AND STATE.
SET FORTH ABOVE, IN VOLUME Y34 PAGE 228.
TAR PARCEL ID: 40-402654-038 R02ERi P.21EGLER
ADDRESS: 87 VICTORY CHURCH RD. ReCORAN COL, D=;pg
GARDNERS, PA. 17324 f"/IdBc RL}!D N7Y-rt.
'9E N911 26 Fill 12 08
Municipal Tax Lot _.. _, Block.. _ .. . Uniform Parcel Identifier 40402654-038 _
Beingpremises eorns?ed3t? Mortgagors bydegdd f cow cyanee duly recorded in the office for the Recording of Deeds in this County in
Deed Book No. -7-, page . Z? , as the Property therein described, g
? if this boa is checked, this Mortgage is subject to a prior mortgage dated .._ .._, 19_.. , executed by
Mortgagors to - as mortgagee,
wNeh priormongage secures payment ofa promissorynntc in the principal amaunt of S_.
n
Book ed on- . .. , 19 with the Recorderof the County of -" ' That prior mortgage , iwas
, p .,_.. , Pennsyvavanie in
TO HAVE AND TO HOLD the Property herebygranlcd and conveyed um Mortgagee, to and for them and behoof of Mona a its
successors and assigns, forever. g fie ,
THIS MORTGAGE IS MADE subject to the following conditions, and Mortgagors agree:
1. Mortgagors will make all payments on the due date thereof and perfurm all other obligalions as required or provided herein and in
the Agreement.
2. This Mortgage secures any and all future advances which Mortgagee shall make to Mortgagor under the Agreement up to the
Credit Lae.
3. Mortgagors will pay when due all taus and assessments levied or assessed against the Property or any pan thereof, and will
deliver receipts for those payments to Mortgagee upon request and if Mortgagee pays any taxes or assessments plus penalties and
costs, the amounts so paid may be added to the unpaid balance of the debt secured by this Mortgage.
4. Mortgagors will keep the improvements on the Property constantly insured against fire and such other hazards, In such amount and
with such carriers u Mortgagee shall approve, with loss, if any, payable to Mortgagee as its interest may appear.
5. Mortgagee, at its option in case of default by Mortgagors of any obligation required of them under parampilis 3 and 4 of this
claims w ortgage, shaMo? the Mt to pay any tones, assessmuu, water and sewer Hots, insurance premiums and alI other charges and
M
rt8ag greed to pa under the terms of the Agreement and this Mortgage, and any and all monies so paid
shall boa part of the debt hereby secured and recoverable as such, in all respects, with interest thereon from the date of such payment.
6. Mortgagors will neither commit nor suffer any strip, waste, impairment or deterioration of the Property, and will maintain The
same in good order and repair.
7. In the event that Mortgagors default in the making of any payment due and payable under the Agreement, or in the kenpping and
er
np an Acon of fggommma by Mortgagors of any of the conditions or covenants of this Mortgage or the Agreement, Mortgagee may in with losu B judgmcos And =uti?to ie rcovcr the Unpaid Balance of the Account plus proceedings but unp this nee oriltatI and
cclluding proceed
, fits
u permitted by law, costs of suit and costs of sale.
At. 4 PA 1041m. Ed. N.. 'ad
B0()K1353FAnE 636
DEC 09 '99 16:41 717 249 9424
PAGE. 05
.r.,xHor r
12/00/08 WED 17:36 FAA 717 240 0424 NYNEe1CIAL CARL1S"
tlooo
8. Uppon wmmencemenl of a suit in foreclosure or this Mongagc,or suit to which Mongagce may be made a Q+rry by reason of this
Mengage, or at arD' t(mc during the pendwry of airy such suit, Mortgagee, upon appllication ro the appproprutn court, at once,
without not(ce to Mortgagor or any person clarmtng undo Mottgagar, and without censrdcm[ron of the adequaq tlf the security or
the solves o[ Mon qor, shall a (rat + receiver for the Property. The roceiver shat{ (I) take posxssion o[ the Bop B (2)
make ropalryrs and keep the Property in proper condit)on and roper, and (1) ppatyy (a) all aus and assessmunrs accruin duin It
mcelvcrship, (b) all unpaid teso:s and usessmcnts unpaid and to sales romelning unredcemed, at or prior ro the foreclosure sale
e
(e) all Insurance prwiums necessary to keep the Property insured in accordance with the provisions of tn?s Mortgage, and (d) the
expanse of she reuivenbip, end apply ilia baleoce, tf arty, ageudt the indcbtedncss secured by this Mortgage.
9. It Mnngognrs wlunterily shell sell or corrvcy the Property, in, whole ar in part, or airy mterost in that Property or by some eat, or
means t°vest themselves of Ude m the Property without obtammgg the written consent of Mortgaggeee, tbea Mongagce, at ita option,
moy declare the entiro balance o[ the loan Piro Interest on the balance Immediatoly duc and payable. This opdon shall not a lth a
(1) the sale of the Property is permiued because the purnha:er's credlturonhincss is satishntory ro Mongagce and (2) that
puabasin, prior to the sale, has «eeutcd a writtan essumptwn agreement conteiWng terms presalbed M Mongagce, including, if
tequlrod. an Inc ase in the to of interest payable under the Agreement.
10. Mongagon, and each of them in this Mongeggee hereby waive and relearn all benefit and relief from any and all appraiaement, stay
and eumption laws, now In tome or hereafmr passed, either for the benefit or relief of Mortgagors which linilt the unrid
principal balance due under the Note to a sin not an caress of the amount actually paid by the purchaser of the Property at a sale of
the Property in any judicial pro" 2"M en ercthe edsdafsale Acre this from Aluehmcn levy orsalcpem er many o provide for
irry stay of motion or other process.
It. Mort Or warrants that (1) the Property has not been used in the put and is not presently used for hazardous and/or toxic waste,
(2) the Property complies with all federal, state and local environmental laws regarding hazardous andlor toxic waste, (3) asbestos
has not been used as a building material on any building material on any building cremed on the Properrryty in the past, (4) the
Property is not presently used for asbestos storage and (5) the Mortgagor complies with all federal, slam, andlocal laws, es well as
regulations, regarding the use and storage of asbestos.
12. Mortgagor convenants and agrees to comply with ail federal, suite, and local em4ronmen W laws in the maintenance and use of the
property.
13. Monge. gor warrants that neither the Property nor the loan prottcds wren or will be used in illegal drug activity, and the Property is
not so ad to selaure by any gevetnilenta authority beeausc of any illegal drug actwity.
BUT PROVIDED ALWAYS, that if Mortgagors do pry or cause this Mortgage and the debt hereby secured to be paid in NO, on the dry
and in the manner provided in the Agreement, then this Mortgage and the estate hereby granted shall cease and determine end became
wid, anything herein to the contrary notwithstanding.
The covenants herein contained shall bind, and the benefits and advantages shall inure to, the respective heirs, motors,
administration, successors, and assigns of the pparties hereto. Whenever used, the singular number shall include the plural, the plural
the singular, and the use of any gender shag be applicable to all genders.
Payment of this Mortgage is subject to the terms and conditions of the Agreement of even date between Mortgagors and Mortgagee.
DV WITNESS Wti]EREOF, Mortgagors have signed this Mortgage, with seal(s) afr md, on the dam fiat above written.
/
Signed, aeale and clivered in the presedcc Of,
((SEAL)
wimaa BARRY DEITZH
(SEAL)
Witness GAY DEITCHSEAL)
Wimcv
COMMONWEALTH OF PENNSYLVANIA )
ss.:
COUNTY OF CMg99:AlM_ _ - -)
On this the ..__3,321- day of _XO=RR-. 1916-., before me, _ CLINTnn M t7A1JG n' _,
(Name of omen)
the undersigned officer, personally appeared BARRY 6GAY DEITCH __ --
(Nand of 130;6 ft')
known to me (or satisfactorily proven) to be the person whose name _!t subscribed to the within instrument and acknowledged
that - MY.- executed the same for the purposes herein contained.
seal, (be day and year atnresald.
BOON 1135-3 PAGE 637
r -S". . war, cc rn:. m •w??. CLINTON H. LLAD
RL 4 '4bdl id. Nav. '94 m.kn Cs'.p:rva J'.•'o t%.2^.nd
?..u,.i Im,abos
DEC 09 '98 16:42 717 249 9424
PAGE. 06
12/09/98 RED 17:57 FAX 111 249 9424 BENEFICIAL CARLISLE
CERTMICATE OF RESIDENCE
10007
?HANGY T. nTTy$L..._ of n NRS2 Ar. ONC?tuaR DISC40BT CO., D./B/A
nErrRRTnra7. HpgpcA-e a_...DF PENNSYLp?gIe ..
Mortgagee named invhe foregoing Mortgage, hereby certify that the correct residence address of the Mortgagee is
, RANnORR ST. CARE M.T. PA I7019
Wflnees nN hP1,.11is i.. 22ND day of N09ElIDER__...._, 9966.
• .• ?!?? Agent or Moep
NMCY' 7. DITZEL
ILL 4 IN 2042aM. Ed. Nw. '94
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DEC 09 '90 16:42 717 249 9424 PRGE.07
LAW OFFICES
MCCABE, WEISBERG & CONWAY, P.C.
SUITE 2080
FIRST UNION BUILDING
SUITE 600
ITE
123 SOUTH BROAD STREET 2i6 HAD
WEH ADDON AVENUE
NJ 08108
TM NT
PHILADELPHIA, PENNSYLVANIA 19109 ,
80
(215) 790.1010 FAX (609) 858.7020
TERRENCE J. MCCABE FAX (215) 790.1274
SUITE 5225
'500 FIFTH AVENUE
NEW YORK, NY 10110
(212)575.1010
FAX (212) 575.2537
May 3, 1999
Occupant(s)
87 Victory Church Road
Gardners, PA 17324
.ACT 91 NOTICE
TAKE ACTION TO SAVE
YOUR NOME FROM
FORECLOSURE
THE COMMONWEALTH OF PENNSYLVANIA'S
HOMEOWNER'S EMERGENCY MORTGAGE
ASSISTANCE PROGRAM MAY BE ABLE TO HELP YOU.
READ THE FOLLOWING NOTICE TO FIND OUT
HOW THE PROGRAM WORKS.
If you need more information, call the Pennsylvania
Housing Finance Agency at 1-800-342-2397.
La notificacion en adjunto es de suma importancia, pues afecta
su derecho a continuar viviendo en su casa. Si no comprende el
contenido de esta notificacion obtenga una traduccion
immediatamente llamanda esta agencia (Pennsylvania Housing Finance
Agency) sin cargos al numero mencionado arriba. Puedes ser
elegible para un prestamo por el programa llamado "Homeowner's
Emergency Mortgage Assistance Program" el cual puede salvar su casa
de la perdida d=_1 derecho a redimir su hipoter_a.
IMPORTANT: NOTICE OF
jrx#Iid lr k4Ci.
HOMEOWNERS' EMERGENCY MORTGAGE
ASSISTANCE PROGRAM
PLEASE READ THIS NOTICE.
YOU MAY BE ELIGIBLE FOR
FINANCIAL ASSISTANCE WHICH CAN
SAVE YOUR HOME FROM FORECLOSURE
TO: Occupant(s)
FROM: Terrence J. McCabe, Esquire
RE: Premises: 87 Victory Church Road, Gardners, PA 17324
Account Number: 711715-26-117182
fo ?osu on your mortgage if you comply with the provisions of
the Homeowners' Emergency Mortgage Assistance Act of 1983 (the
"Act"). You may be eligible for emergency temporary assistance if
your default has been caused by circumstances beyond your control,
you have a reasonable prospect of resuming your mortgage payments,
and if you meet other eligibility requirements established by the
Pennsylvania Housing Finance Agency. Phase read al of thin
Notice, T nnha;ns an exipl _r yoU_ ri9ncs.
Under the Act, you are entitled to a temporary stay of
foreclosure on your mortgage for thirty (30) days from the date of
this Notice. During that time-you must arrange and attend a "face-
to-face" meeting with a representative of this lender, or with a
designated consumer credit counseling agency. The purpose of this
meeting is to attempt to work out a repayment plan, or to otherwise
settle your delinquency. This meeting moat occur in h next, days, If you attend a face-to-face meeting with this lender, or with
a consumer credit counseling agency identified in this notice, no
further proceeding in mortgage foreclosure may take place for
thirty (30) days after the date of this meeting.
The name, address and telephone number of the Beneficial
Consumer Discount Company d/b/a Beneficial Mortgage Company of PA
c/o HFC Processing Services representative is as follows:
Beneficial Consumer Discount Company d/b/a
Beneficial Mortgage Company of PA c/o HFC Processing Services
961 Weigel Drive, P.U. Box 9634
Flmhurs-., IL 60126-3.058
Robert Elston, 1-800-559-3482 Ext.7354
The names and addresses of designated consumer credit
counseling agencies are shown on the attached sheet. It is only
necessary to schedule one face-to-face meeting. You should advise
this lender immediately of your intentions.
Your mnrrgagP is ;n default- because you have failed to pay
promptly installments of g ;n ., Dal and +'nror s
a as reuired, for
period of at least sixty (60) days. The total amount of the
delinquency is $7562.04. That sum includes the following:
principal and interest.
N/A. Your mortgage is also in default for the following reasons:
If you have tried and are unable to resolve this problem at or
after your face-to-face meeting, you have the right to apply for
financial assistance from the Homeowners, Emergency Mortgage
Assistance Fund. In order to do this, you must fill out, sign and
file a completed Homeowners' Emergency Assistance Application with
one of the designated consumer credit counseling agencies listed on
the attachment. An application for assistance may only be obtained
from a consumer credit counseling agency. The consumer credit
counseling agency will assist you in filling out your application
and will submit your completed application to,. the Pennsylvania
Housing Finance Aaencv. vn„r .
It is extremely important that you file your application
promptly. If you do not do so, or if you do not follow the other
time periods set forth in this letter, foreclosure may proceed
against your horse immediately.
Available funds for emergency mortgage assistance are very
limited. They will be disbursed by the agency under the
eligibility criteria established by the Act.
Agency has sixt The Pennsylvania Housing Finance
y (60) days to make a decision after it receives
your application. During that additional time, no foreclosure
proceeding will be pursued against you if you have met the time
requirements set forth above. You will be notified directly by
that Agency of its decision on your application.
The Pennsylvania Housing Finance Agency is located at 2101
North Front Street, Post Office Box 8029, Harrisburg, Pennsylvania
17105; telephone number (717) 780-3800 or 1-800-342-2397 (toll free
number). Persons with impaired hearing can call (71.7) 780-1869.
In arldition you may receive another notice from this lender
under Act 6 of 1974, That notic_ is called a "Notice eaf Intention
to Foreclose." You must read both not.l.ces, since they both explain
right, that you now have under Pennsylvania law. However., if you
choose to exercise your rights described in this notice you cannot
be foreclosed upon while you are receiving that assistance.
NOTE: Unless you notify this office within thirty (30) days
after receiving this notice, that you dispute the validity of this
debt or any portion thereof, this office will assume that the debt
is valid. If you notify this office in writing within thirty (30)
days from receiving this notice, this office will: . obtain
verification of the debt or obtain a copy of judgment and mail you
a copy of such judgment or verification. You are also advised
that any information which you supply to this office may be used by
us in the collection of the debt. If you request this office in
writing within thirty (30) days after receiving this, this office
will provide you with the name and address of the original
creditor.
Very truly yours,
Z41z"7 /' Mc, 6A V C-
TERRENCE J. MCCABE
TJM/mh
PENNSYLVANIA HOUSING FINANCE AGENCY
HOMEOWNERS' EMERGENCY MORTGAGE
ASSISTANCE PROGRAM
CONSUMER CREDIT COUNSELING AGENCIES
Consumer Credit Counseling Service of Western
Pennsylvania, Inc.
2000 Linglestown Road
Harrisburg, Pa 17102
(717) 541-1757
Financial Services Unlimited
117 West 3rd Street
Waynesboro, Pa 17268
(717) 76273285
Urban League of Metropolitan Harrisburg
25 N. Front Street
Harrisburg, Pa 17101
(717) 234-5925
FAX # (717) 232-4985
YWCA of Carlisle
301 G Street
Carlisle, Pa 17013
(717) 243-3818
FAX # (717) 243-3948
LAW OFFICES
MCCABE, WEISBERG & CONWAY, P.C,
SUITE 2080
FIRST UNION BUILDING
123 SOUTH BROAD STREET
PHILADELPHIA, PENNSYLVANIA 19109
(215) 790.1010
TERRENCE J. MCCABE
FAX (215) 790.1274
May 3, 1999
Occupant(s)
87 Victory Church Road
Gardners,4PA 17324
SUITE 600
216 HADDON AVENUE
WESTMONT, NJ 08108
(609) 858.7080
FAX (609) 858.7020
SUITE 5225
S00 FIFTH AVENUE
NEW YORK, NY 10110
(212) 575.1010
FAX (212) 575.2537
l"' 0 /3/Q9
LENDER: Beneficial Consumer Discount Company d/b/a Beneficial
Mortgage Company of PA C/o HFC Processing Services
ACCOUNT NUMBER: 711715-26-117182
REAL ESTATE: 87 Victory Church Road, Gardners, PA 17324
Dear Occupant(s) :
The MORTGAGE held by Beneficial Consumer Discount Company
d/b/a Beneficial Mortgage Company of PA C/o HFC Processing Services
(hereinafter we, us or ours) on your property located at 87 Victory
Church Road, Gardners, PA 17324 IS IN SERIOUS DEFAULT because you
have not made the monthly payments of approximately $477.07 for the
months of May, 1998 through April, 1999, and/or because of this
failure to remit.
Late charges, and other charges have also accrued to this date
in the amount of $n/a. 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 $7562.04.
You may cure this default within THIRTY (30) DAYS of the date
of this letter, by paying to us the above amount of $7562.04 plus
any additional monthly payments and la"e charge which may fall due
during this period. Such payment must be made either by cash,
cashier's check, certified check or money order and made to
Beneficial Consumer Discount Company d/b/a Beneficial
Mortgage Company of PA c/o HFC Processing Services
961 Weigel Drive, P.O. Box 9634
Elmhurst, IL 60126-1058
If you do not cure the default within THIRTY (30) 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
pay off the original mortgage in monthly installments. If full
payment of the amount of default is not made within THIRTY (30)
DAYS, I have been instructed to start a lawsuit to foreclose your
mortgaged property. If the mortgage is foreclosed, your mortgaged
property will be sold by the Sheriff to pay off the mortgage debt.
Once this matter is referred to me for suit, but you cure the
default before I 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 pay the reasonable attorney's fees
even if they ate over $50.00. Any attorney's fees will be added to
whatever you owe, which may also include 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 and all other sums due under the mortgage. If you have not
cured the default within the thirty day period and foreclosure
proceedings have begun, you still have the right to cure the
default and prevent the sale at any time up to one hour before the
Sheriff's Foreclosure Sale. You may do 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 (and perform any other
requirements under the mortgage). It is estimated that the
earliest date that such a Sheriff's Sale could be held would be
approximately 5 months.
A notice of the date of the Sheriff Sale will be sent to you
before the sale. Of course, the amount needed to cure the default
will increase the longer you wait. You may find out at any time
exactly what the required payment will be by calling the following
number: , Ext. . This payment must be in cash, cashier's check,
certified check or money order and made payable to us at the
address stated above.
You should realize that a Sheriff's Sale will 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 to evict you.
i
You have additional rights to help protect your interest in
You have the right to sell the property to obtain
this prop ert or to borrow money from another
money to pay off the mortgage debt, have the right
lending institution to pay off this debt. (You may
he
to sell or transfer the property subject to t morYOVgdedothatuall debt or transferee who will assume t
charges andta torney is fees and costs are
the outstanding payments, he ot nder
at the sale, . a Contactthat to hdete qmineuiremunderents
paid prior to or
the mortgage the circumstances this right might exactingaon yourrbight to ehalf have
this default cured by any third party
If you cure the default, the mortgage will be restored to the
ou are not j,
same position as if no default had occurred default moreever, three times
entitled to this right to cure your L.
in any calendar year.
NOTE: Unless you notify this office within thirty (30) days
after receiving this notice, that you dispute the validity of this
debt or any portion thereof, this office will assume that the debt
office within will thirty (30) : obtain
is valid. If you notify this office in writin
days from receiving this notice, this and mail you
verification of the debt or obtain a copy of judgment You
advi
also
are
sed a copy of such judgment or you supply tonthis office may be used by
that any information which yo P. Y you re uest this office in
us in the collection of the des after if receiving this, this office
writing within thirty day
will provide you with th the name and address of the original
creditor. .?.., s„v
Very truly?r? f i• ,i'_
Uil
TERRENCE J. MCCAEE
TJM/mh
SENT VIA CERTIFIED MAIL
NUMBER Z 282 004 722
RETUF.N RECEIPT REQUESTED
LAW OFFICES
McCABE, WEISBERG & CONWAY, P.C.
SUITE 2080
FIRST UNION BUILDING
123 SOUTH BROAD STREET
PHILADELPHIA, PENNSYLVANIA 19109
(215)790.1010
TERRENCE J. MCCABE FAX (215) 790.1274
May 3, 1999
Gay Deitch a/k/a Gay L. Deitch
101 East Main Street
Walnut Bottom, PA 17266
. ACT 91 NOTICE
TAKE ACTION TO SAVE
YOUR HOME FROM
FORECLOSURE
THE COMMONWEALTH OF PENNSYLVANIA'S
HOMEOWNER'S EMERGENCY MORTGAGE
ASSISTANCE PROGRAM MAY BE ABLE TO HELP YOU.
READ THE FOLLOWING NOTICE TO FIND OUT
HOW THE PROGRAM WORKS.
SUITE 600
216 HADDON AVENUE
WESTMONT, N7 08108
(609) 858.7080
FAX (609) 858.1020
SUITE 5225
•500 FIFTH AVENUE
NEW YORK, NY 10110
(212)575.1010
FAX (212) 575.2537
If you need more information, call the Pennsylvania
Housing Finance Agency at 1-800-342-2397.
La notification en adjunto es de suma importancia, pues afecta
su derecho a continuar viviendo en su casa. Si no comprende el
contenido de estz notification obtenga una traduccion
immediatamente llamanda esta agencia (Pennsylvania Housing Finance
Agency) sin cargos al numero mencionado arriba. Puedes 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.
IMPORTANT: NOTICE OF
HOMEOWNERS' EMERGENCY MORTGAGE
ASSISTANCE PROGRAM
PLEASE READ THIS NOTICE.
YOU MAY BE ELIGIBLE FOR
FINANCIAL ASSISTANCE WHICH CAN
SAVE YOUR HOME FROM FORECLOSURE
TO: Gay Deitch a/k/a Gay L. Deitch
FROM: Terrence J. McCabe, Esquire
RE: Premises: B7 Victory Church Road, Gardners, PA 17324
Account Number: 711715-26-117182
YOU M
Qra2 osure on your mortgage if you comply with the provisions of
the Homeowners' Emergency Mortgage Assistance Act of 1983 (the
"Act"). You may be eligible for emergency temporary assistance if
your default has been caused by circumstances beyond your control,
you have a reasonable prospect of resuming your mortgage payments,
and if you meet other eligibility requirements established by the
Pennsylvania Housing Finance Agency. Please read & of this
_G ,-; rrhta
Under the Act, you are entitled to a temporary stay of
foreclosure on your mortgage for thirty (30) days from the date of
this Notice. During that time you must arrange and attend a "face-
to-face" meeting with a representative of this lender, or with a
designated consumer credit counseling agency. The purpose of this
meeting is to attempt to work out a repayment plan, or to otherwise
settle your delinquency. This - must occur ?n the n 01
days.
If you attend a face-to-face meeting with this lender, or with
a consumer credit counseling agency identified in this notice, no
further proceeding in mortgage foreclosure may take place for
thirty (30) days after the date of this meeting.
The name, address and telephone number of the Beneficial
Consumer Discount Company d/b/a Beneficial Mortgage Company of PA
c/o HFC Processing Services representative is as follows:
Beneficial Consumer Discount Company, d/b/a
Beneficial Mortgage Company of. PA c/o HFC Processing Services
961 Weigel Drive, P.O. Box. 9634
Elmhurst, IL 60126-1058
Robert Elston, 1-800-959-3482 Ext. 7354
The names and addresses of designated consumer credit
counseling agencies are shown on the attached sheet. It is only
necessary to schedule one face-to-face meeting. You should advise
this lender immediately of your intentions.
Your mor gag is ;n d f „tr because you have failed to pay
promptly installments of principal and ;n res as required, for
a period of at least sixty (60) days. The total amount of the
delinquency is $7562.04. That sum includes the following:
principal and interest.
NIA. mortgage is also in default for the following reasons:
If you have tried and are unable to resolve this problem at or
after your face-to-face meeting, you have the right to apply for
financial assistance from the Homeowners' Emergency Mortgage
Assistance Fund. In order to do this, you must fill out, sign and
file a completed Homeowners' Emergency Assistance Application with
one of the designated consumer credit counseling agencies listed on
the attachment. An application for assistance may only be obtained
from a consumer credit counseling agency. The consumer credit
counseling agency will assist you in filling out your application
and will submit your completed application to the Pennsylvania
Housing Finance Acrencv. Ynvr
It is extremely important that you file your application
promptly. If you do not do so, or if you do not follow the other
time periods set forth in this letter, foreclosure may proceed
against your home immediately.
Available funds for emergency mortgage assistance are very
limited. They will be disbursed by the agency under the
eligibility criteria established by the Act.
a.u ,tp ece in ev rv r ap t The Pennsylvania Housing Finance
Agency has sixty (60) days to make a decision after it receives
your application. During that additional time, no foreclosure
proceeding will be pursued against you if you have met the time
requirements set forth above. You will be notified directly by
that Agency of its decision on your application.
The Pennsylvania Housing Finance Agency is located at 2101
North Front Street, Post Office Box 8029, Harrisburg, Pennsylvania
17105; telephone number (717) 780-3800 or 1-800-342-2397 (toll free
number). Persons with impaired hearing can call (717) 780-1869.
In addition you may receive another notice from this lender
under Act- 6 of 1974. That notice is called a "Notice of Intention
tc• Foreclose." You must read both notices, since they both explain
rights that you now have under Pennsylvania :law. However, if you
choose to exercise your rights described in this notice you cannot
be foreclosed upon while you are receiving that assistance.
NOTE: Unless you notify this office within thirty (30) days
after receiving this notice, that you dispute the validity of this
debt or any portion thereof, this office will assume that the debt
is valid. If you notify this office in writing within thirty (30)
days from receiving this notice, this office will: . obtain
verification of the debt or obtain a copy of judgment and mail you
a copy of such judgment or verification. You are also advised
that any information which you supply to this office may be used by
us in the collection of the debt. If you request this office in
writing within thirty (30) days after receiving this, this office
will provide you with the name and address of the original
creditor.
Very truly yours,
/ .
TERRENCE J. McCABE
TJM/mh
PENNSYLVANIA HOUSING FINANCE AGENCY
HOMEOWNERS' EMERGENCY MORTGAGE
ASSISTANCE PROGRAM
CONSUMER CREDIT COUNSELING AGENCIES
Consumer Credit Counseling Service of Western
Pennsylvania, Inc.
2000 Linglestown Road
Harrisburg, Pa 17102
(717) 541-1757
Financial Services Unlimited
117 West 3rd Street
Waynesboro, Pa 17268
(717) 762-3285
Urban League of Metropolitan Harrisburg
25 N. Front Street
Harrisburg, pa 17101
(717) 234-5925
FAX # (717) 232-4985
YWCA of Carlisle
301 G Street
Carlisle, Pa 17013
(717) 243-3818
FAX # (717) 243-3948
TERRENCE I. MOCABE
LAW OFFICES
McCABE, WEISBERG & CONWAY, P.C.
SUITE 2080 SUITE 600
FIRST UNION BUILDING 216 HADDON AVENUE
123 SOUTH BROAD STREET WESTMONT, N108108
PHILADELPHIA, PENNSYLVANIA 19109 (609) 858.7080
(215) 790.1010 FAX (609) 858-7020
FAX (215) 790.1274 SUITE 5225
600 FIFTH AVENUE
NEW YORK,NY 10110
(212)575.1010
FAX (212) 575.2537
May 3, 1999
Gay Deitch a/k/a Gay L. Deitch
101 East Main Street
Walnut Bottom, PA 17266
LENDER: Beneficial Consumer Discount Company d/b/a Beneficial
Mortgage Company of PA C/o HFC Processing Services
ACCOUNT NUMBER: 711715-26-117182
REAL ESTATE: 87 Victory Church Road, Gardners, PA 17324
Dear Gay Deitch a/k/a Gay L. Deitch:
The MORTGAGE held by Beneficial Consumer Discount Company
d/b/a Beneficial Mortgage Company of PA C/o HFC Processing Services
(hereinafter we, us or ours) on your property located at 87 Victory
Church Road, Gardners, PA 17324 IS IN SERIOUS DEFAULT because you
have not made the monthly payments of approximately $477.07 for the
months of May, 1998 through April, 1999, and/or because of this
failure to remit.
Late charges, and other charges have also accrued to this date
in the amount of $n/a. 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 $7562.04.
You may cure this default within THIRTY (30) DAYS of the date
of this letter, by paying to us the abc.-ve amount of $7562.04 plus
any additional monthly payments and late charge which may fall due
during this period. Such payment must be made either by cash,
cashier's check, certified check or money order and made to
Beneficial Consumer Discount Company d/b/a Beneficial
Mortgage Company of PA c/o HFC Processing Services
961 Weigel Drive, P.O. Box 9634
Elmhurst, IL 60126-1058
If you do not cure the default within THIRTY (30) 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
pay off the original mortgage in monthly installments. If full
payment of the amount of default is not made within THIRTY (30)
DAYS, I have been instructed to start a lawsuit to foreclose your
mortgaged property. If the mortgage is foreclosed, your mortgaged
property will be sold by the Sheriff to pay off the mortgage debt.
Once this matter is referred to me for suit, but you cure the
default before I 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 pay the reasonable attorney's fees
even if they are over $50.00. Any attorney's fees will be added to
whatever you owe, which may also include 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 and all other sums due under the mortgage. If you have not
cured the default within the thirty day period and foreclosure
proceedings have begun, you still have the right to cure the
default and prevent the sale at any time up to one hour before the
Sheriff's Foreclosure Sale. You may do 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 (and perform any other
requirements under the mortgage). It is estimated that the
earliest date that such a Sheriff's Sale could be held would be
approximately 5 months.
A notice of the date of the Sheriff Sale will be sent to you
before the sale. of course, the amount needed to cure the default
will increase the longer you wait. You may find out at any time
exactly what the required payment will be by calling the following
number: , Ext. . This payment must be in cash, cashier's check,
certified check or money order and made payable to us at the
address stated above.
You should realize that a Sheriff's Sale will 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 lawsui.c could be started to evict you.
You 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 another
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 calendar year.
NOTE: Unless you notify this office within thirty (30) days
after receiving this notice, that you dispute the validity of this
debt or any portion thereof, this office will assume that the debt
is valid. If you notify this office in writing within thirty (30)
days from receiving this notice, this office will: obtain
verification of the debt or obtain a copy of judgment and mail you
a copy of such judgment or verification. You are also advised
that any information which you supply to this office may be used by
us in the collection of the debt. If you request this office in
writing within thirty (30) days after receiving this, this office
will provide you with the name and address of the original
creditor.
Very truly yours,
T,&?? /.
TERRENCE J. McCABE
TJM/mh
SENT VIA CERTIFIED MAIL
NUMBER Z 262 004 721
RETURN RECEIPT REQUESTED
TERRENCE J. MCCABE
LAW OFFICES
McCABE, WEISBERG & CONWAY, P.C.
SUITE 2080
FIRST UNION BUILDING
SUITE 600
ITE
123 SOUTH BROAD STREET 216 16 HAD
HAD ON AVENUE
AVENU
PHILADELPHIA, PENNSYLVANIA 19109 WESTMONT, N E
(215) 790-1010 ( 80
FAX (609) 858.7020
FAX (215) 790.1274 SUITE 5225
-500 FIFTH AVENUE
NEW YORK, NY 10110
(212) 575-1010
FAX (112) 575-2537
May 3, 1999
Barry Deitch a/k/a Barry L. Deitch
101 East Main Street
Walnut Bottom, PA 17266
ACT 91 NOTICE
TAKE ACTION TO SANE
YOUR HOME FROM
FORECLOSURE
THE COMMONWEALTH OF PENNSYLVANIA'S
HOMEOWNER'S EMERGENCY MORTGAGE
ASSISTANCE PROGRAM MAY BE ABLE TO HELP YOU.
READ THE FOLLOWING NOTICE TO FIND OUT
HOW THE PROGRAM WORKS.
If you need more information, call the Pennsylvania
Housing Finance Agency at 1-800-342-2397.
La notificacion en adjunto es de sums importancia, pues afecta
su derecho a continuar viviendo en su casa. Si no comprende el
contenido de esta notificacion obtenga una traduccion
immediatamente llamanda esta agencia (Pennsylvania Housing Finance
Agency) sin cargos al numero mencionado arriba. Puedes 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.
IMPORTANT: NOTICE OF
HOMEOWNERSI EMERGENCY MORTGAGE
ASSISTANCE PROGRAM
PLEASE READ THIS NOTICE.
YOU MAY BE ELIGIBLE FOR
FINANCIAL ASSISTANCE WHICH CAN
SAVE YOUR HOME FROM FORECLOSURE
TO: Barry Deitch a/k/a Barry L. Deitch
FROM: Terrence J. McCabe, Esquire
RE: Premises: 87 Victory Church Road, Gardners, PA 17324
Account Number: 711715-26-117182
on your mortgage if you comply with the provisions of
the Homeowners' Emergency Mortgage Assistance Act of 1983 (the
"Act"). You may be eligible for emergency temporary assistance if
your default has been caused by circumstances beyond your control,
you have a reasonable prospect of resuming your mortgage payments,
and if you meet other eligibility requirements established by the
Pennsylvania Housing Finance Agency. Please +es? =7i of tr;p
Notice, it rnntn;na an eXnlanat;-- of yoLL _r_j h s.
Under the Act, you are entitled to a temporary stay of
foreclosure on your mortgage for thirty (30) days from the date of
this Notice. During that time you must arrange and attend a "face-
to-face" meeting with a representative of this lender, or with a
designated consumer credit counseling agency. The purpose of this
meeting is to attempt to work out a repayment plan, or to otherwise
settle your delinquency. Thi meeting must occur in h next (an)
days.
If you attend a face-to-face meeting with this lender, or with
a consumer credit counseling agency identified in this notice, no
further proceeding in mortgage foreclosure may take place for
thirty (30) days after the date of this meeting.
The name, addrevs and telephone number of the Beneficial
Consumer Discount Company d/b/a Beneficial Mortgage Company of PA
c/o HFC Processing Services representative is as follows:
Beneficial Consumer Discount Company d/b/a
Beneficial Mortgage Company of 1,1, c/o HFC Processing Services
961 Weigel Drive, P.O. Box 9634
Elmhurst, IL 60126-105f,
Robert Elston 1-800-959-3482, Ext.7354
The names and addresses of designated consumer credit
counseling agencies are shown on the attached sheet. It is only
necessary to schedule one face-to-face meeting. You should advise
this lender immediately of your intentions.
Your mortgage is in d fault because you have failed to pay
promptly installments of principal and interest, as required, for
a period of at least sixty (60) days. The total amount of the
delinquency is $7562.04. That sum includes the following:
principal and interest.
Your mortgage is also in default for the following reasons:
N/A.
If you have tried and are unable to resolve this problem at or
after your face-to-face meeting, you have the right to apply for
financial assistance from the Homeowners' Emergency Mortgage
Assistance Fund. In order to do this, you must fill out, sign and
file a completed Homeowners' Emergency Assistance Application with
one of the designated consumer credit counseling agencies listed on
the attachment'. An application for assistance may only be obtained
from a consumer credit counseling agency. The consumer credit
counseling agency will assist you in filling out your application
and will submit your completed application to the Pennsylvania
Housing Finance Agency. Your application must be filed or
nngtmarkaA. wit-hi.n fhi rfv /9111 Aa%rc of vnnir fanc_tn_f?nc me of-inn
It is extremely important that you file your application
promptly. If you do not do so, or if you do not follow the other
time periods set forth in this letter, foreclosure may proceed
against your home immediately.
Available funds for emergency mortgage assistance are very
limited. They will be disbursed by the agency under the
eligibility criteria established by the Act.
and complete in every respect, The Pennsylvania Housing Finance
Agency has sixty (60) days to make a decision after it receives
your application. During that additional time, no foreclosure
proceeding will be pursued against you if you have met the time
requirements set forth above. You will be notified directly by
that Agency of its decision on your application.
The Pennsylvania Housing Finance Agency is located at 2101
North Front Street, Post Office Box 8029, Harrisburg, Pennsylvania
17105; telephone number (717) 780-3800 or 1-800-342-2397 (toll free
number). Persons with impaired hearing can call (717) 780-1869.
In addition you may receive another notice from this lender
under Act 6 of lg74. That notice is called a "Notice of Intention
to Foreclose." You must re:r.d bor.h notices, since they both explain
rights that you now have under Pennsylvania law. However, if you
choose to exercise your rights described in this notice you cannot
be foreclosed upon while you are receiving that assistance.
NOTE: Unless you notify this office within thirty (30) days
after receiving this notice, that you dispute the validity of this
debt or any portion thereof, this office will assume that the debt
is valid. If you notify this office in writing within thirty (30)
days from receiving this notice, this office will: obtain
verification of the debt or obtain a copy of judgment and mail you
a copy of such judgment or verification. You are also advised
that any information which you supply to this office may be used by
us in the collection of the debt. If you request this office in
writing within thirty (30) days after receiving this, this office
will provide you with the name and address of the original
creditor.
Very truly yours,
TERRENCE J. McCABE
TJM/mh
PENNSYLVANIA HOUSING FINANCE AGENCY
HOMEOWNERS' EMERGENCY MORTGAGE
ASSISTANCE PROGRAM
CONSUMER CREDIT COUNSELING AGENCIES
Consumer Credit Counseling Service of Western
Pennsylvania, Inc.
2000 Linglestown Road
Harrisburg, Pa 17102
(717) 541-1757
Financial Services Unlimited
117 West 3rd Street
Waynesboro, Pa 17268
(717) 762-3285
Urban League of Metropolitan Harrisburg
25 N. Front Street
Harrisburg, Pa 17101
(717) 234-5925
FAX # (717) 232-4985
YWCA of Carlisle
301 G Street
Carlisle, Pa 17013
(717) 243-3818
FAX # (717) 243-3948
LAW OFFICES
MCCABE, WEISBERG & CONWAY, P.C.
SUITE 2080
FIRST UNION BUILDING
123 SOUTH BROAD STREET
PHILADELPHIA, PENNSYLVANIA 19109
(215)790.1010
TERRENCE J. McCABE
FAX (215) 790-1274
May 3, 1999
Barry Deitch a/k/a Barry L. Deitch ,
101 East Main Street
Walnut Bottom, PA 17266
SUITE 600
216 HADDON AVENUE
WESTMONT, NJ 08108
(609)858.7080
FAX (609) 858.7020
SUITE 5225
500 FIFTH AVENUE
NEW YORK, NY 10110
(212) 575.1010
FAX (212) 575.2537
31yY
LENDER: Beneficial Consumer Discount Company d/b/a Beneficial
Mortgage Company of PA C/o HFC Processing Services
ACCOUNT NUMBER: 711715-26-117182
REAL ESTATE: 87 Victory Church Road, Gardners, PA 17324
Dear Barry Deitch a/k/a Barry L. Deitch:
The MORTGAGE held by Beneficial Consumer Discount company
d/b/a Beneficial Mortgage Company of PA c/o HFC Processing Services
(hereinafter we, us or ours) on your property located at 87 Victory
Church Road, Gardners, PA 17324 IS IN SERIOUS DEFAULT because you
have not made the monthly payments of approximately $477.07 for the
months of May, 1998 through April, 1999, and/or because of this
failure to remit.
Late charges, and other charges have also accrued to this date
in the amount of $n/a. 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 $7562.04.
You may cure this default within THIRTY (30) DAYS of the date
of this letter, by paying to us the above amount of $7562,04 plus
any additional monthly payments and late charge which may fall due
during this period. Such payment must be made either by cash,
cashier's check, certified check or money order and made to
Beneficial Consumer Discount Company d/b/a Beneficial
Mortgage Company of PA c/o HFC Processing Services
961 Weigel Drive, P.O. Box 9634
Elmhurst, IL 60126-1058
If you do not cure the default within THIRTY (30) 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
pay off the original mortgage in monthly installments. If full
payment of the amount of default is not made within THIRTY (30)
DAYS, I have been instructed to start a lawsuit to foreclose your
mortgaged property. If the mortgage is foreclosed, your mortgaged
property will be sold by the Sheriff to pay off the mortgage debt.
Once this matter is referred to me for suit, but you cure the
default before I 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 pay the reasonable attorney's fees
even if they are over $50.00. Any attorney's fees will be added to
whatever you owe, which may also include 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 and all other sums due under the mortgage. If you have not
cured the default within the thirty day period and foreclosure
proceedings have begun, you still have the right to cure the
default and prevent the sale at any time up to one hour before the
Sheriff's Foreclosure Sale. You may do 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 (and perform any other
requirements under the mortgage). It is estimated that the
earliest date that such a Sheriff's Sale could be held would be
approximately 5 months.
A notice of the date of the Sheriff Sale will be sent to you
before the sale. Of course, the amount needed to cure the default
will increase the longer you wait. You may find out at any time
exactly what the required payment will be by calling the following
number: , Ext. . This payment must be in cash, cashier's check,
certified check or money order and made payable to us at the
address stated above.
You should realize that a Sheriff's Sale will 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 to evict you.
You 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 another
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 calendar year.
NOTE: Unless you notify this office within thirty (30) days
after receiving this notice, that you dispute the validity of this
debt or any portion thereof, this office will assume that the debt
is valid. If you notify this office in writing within thirty (30)
days from receiving this notice, this office will: obtain
verification of the debt or obtain a copy of judgment and mail you
a copy of such judgment or verification. You are also advised
that any information which you supply to this office may be used by
us in the collection of the debt. If you request this office in
writing within thirty (30) days after receiving this, this office
will provide you with the name and address of the original
creditor.
THE PURPOSE OF THIS COMMUNICATION IS TO COLLECT A DEBT AND- ANY
INFORMATION OBTAINED WILL BE USED FOR THIS PURPOSE,
Very truly yours,
TERRENCE J. McCABE
TJM/mh
SENT VIA CERTIFIED MAIL
NUMBER Z 282 004 720
RETURN RECEIPT REQUESTED
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McCABE, WEISBERG AND CONWAY, P.C.
BY: TERRENCE J. MCCABE, ESQUIRE
Identification Number 16496
First Union Building
123 South Broad Street, Suite 2080
Philadelphia, Pennsylvania 19109
(215) 790-1010
BENEFICIAL CONSUMER DISCOUNT
COMPANY d/b/a BENEFICIAL
MORTGAGE CO. OF PENNSYLVANIA
V.
BARRY DEITCH, a/k/a
BARRY L. DEITCH
GAY DEITCH, a/k/a
GAY L. DEITCH
UNITED STATES OF AMERICA
Attorney for Plaintiff
CUMBERLAND COUNTY
COURT OF COMMON PLEAS
NUMBER 99-4200
It is hereby stipulated and agreed by and between counsel for
Plaintiff, Beneficial Consumer Discount company, d/b/a Beneficial
Mortgage Co. of Pennsylvania, and the Defendant, United States of
America, as follows:
1. That the premises referred to in Exhibit "B" of the
Complaint is owned by the Defendant.
2. That the Federal tax lien referred to in paragraph four
(4) of the Plaintiff's Complaint is junior in time to the
Plaintiff's mortgage set forth in paragraph seven (7) of said
Complaint.
3. That the Defendant, United States of America, is not
1999 A 27 Al S '36
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indebted to the Plaintiff.
4. That the Defendant, United States of America, agrees to
the entry in this action of a judgment in favor of the Plaintiff
and against the United States of America for foreclosure and sale
of the mortgaged property.
5. That the aforesaid premises shall be sold at a judicial
sale, notice of which shall be served on the Defendant, United
States of America.
6. That the judicial sale of said property shall discharge
the Federal lien referred to in paragraph four (4) of said
Complaint.
7. That the proceeds of sale shall be divided and
distributed as the parties may be entitled.
8. That the Defendant, United States of America, preserves
its right of redemption as provided in Title 28 United States
Codes, Section 2410(c).
9. The parties to this Stipulation shall bear their own
respective costs in this proceeding.
DAVID M. BARASCH
%rf"e3\States Attorney
Jos H TER2
ss11ita-9 U.S. Attorney
A ney for the United States
of America
TERRENCE J. McCABE
Attorney for Plaintiff
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SHERIFF'S RETURN - REGULAR
CASE NO: 1999-04200 P
COMMONWEALTH OF PENNSYLVANIA:
COUNTY OF CUMBERLAND
BENEFICIAL CONSUMER DISCOUNT
VS.
DEITCH BARRY ET AL
KATHY CLARKS , Sheriff or Deputy Sheriff of
CUMBERLAND County, Pennsylvania, who being duly sworn according
to law, says, the within COMPLAINT - MORT FORE was served
upon TERRE/TENNANT the
defendant, at 1151:00 HOURS, on the 21st day of July
1999 at 87 VICTORY CHURCH ROAD
GARDNERS, PA 17324 CUMBERLAND
County, Pennsylvania, by handing to MARK STOUGH (TENANT)
a true and attested copy of the COMPLAINT - MORT FORE
together with NOTICE
and at the same time directing His attention to the contents thereof.
Sheriff's Costs: So answers:
Docketing 6.00 ./) J
Service 6.82
Affidavit .00
Surcharge 8.00 RAP" mas i e, 5 eri
$20.n C?ABE WEISBERG & REIS
08 02/1999
by
u y e i
Sworn and subscribed to before me
this 1&4%- day of CZ(
19 /
i t a L lin r ?^ 0
U vrgtnonota-ry
v V?
SHERIFF'S RETURN - REGULAR
CASE NO: 1999-04200 P
COMMONWEALTH OF PENNSYLVANIA:
COUNTY OF CUMBERLAND
BENEFICIAL CONSUMER DISCOUNT
VS.
DEITCH BARRY ET AL
DAVID E. MCKINNEY 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 DEITCH GAY A/K/A DEITCH GAY L the
defendant, at 18:55 HOURS, on the 15th day of July
1999 at 101 EAST MAIN ST
WALNUT BOTTOM, PA 17266 CUMBERLAND
County, Pennsylvania, by handing to GAY DEITCH
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: So answ
Docketing 6.00
Service .00f / Q
Affidavit ,00 i
Surcharge 8.00 K. I
o as i
e i
$T4-.T-0-MC WEISBERG & REIS
08M /1999
by Q /27G
iuepncy s i
Sworn and subscribed to before me
this d ?.c day of
1919 q9 A.D.
SHERIFF'S RETURN - REGULAR
CASE NO: 1999-04200 P
COMMONWEALTH OF PENNSYLVANIA:
COUNTY OF CUMBERLAND
BENEFICIAL CONSUMER DISCOUNT
VS.
DEITCH BARRY ET AL
DAVID E. MCKINNEY , 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 DEITCH BARRY A/K/A DEITCH BARRY L the
defendant, at 18:55 HOURS, on the 15th day of July
1999 at 101 EAST MAIN ST
WALNUT BOTTOM, PA 17266 ,CUMBERLAND
County, Pennsylvania, by handing to BARRY DEITCH
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 answ r J/
Docketin 18.00
Service g 8.68 ?- e
Affidavit
Surcharge 8.00 m s i e e i
0C AR2 9WEISBERG & REIS
by _ ???e'iJ'
epuy5 e i
Sworn and subscribed to before me
this A, _ day of
19 9? A.D.
L , ee,? ax
?-7-'-Pr n ry ??`'
SHERIFF'S RETURN - OUT OF COUNTY
CASE NO: 1999-04200 P
COMMONWEALTH OF PENNSYLVANIA:
COUNTY OF CUMBERLAND
BENEFICIAL CONSUMER DISCOUNT
VS.
DEITCH BARRY ET AL
R. Thomas Kline Sheriff, who being duly sworn according
to law, says, that he made a diligent search and inquiry for the within
named defendant, to wit: UNITED STATES OF AMERICA C/O
UNITED STATED ATTORNEY MIDD CT
but was unable to locate Them in his bailiwick. He therefore
deputized the sheriff of DAUPHIN County, Pennsylvania.
to serve the within NOT. & COMP. IN MORT/FORECLOS
On August 2nd 1999 , this office was in receipt of
the attached return from DAUPHIN County, Pennsylvania.
Sheriff's Costs: So answ
Docketing 6.00 i
Out of County 9.00
Surchargge 8.00 omas ine, eri
DEP. DAUPHIN CO 25.70
Q CCABE, WEISBERG & REIS
08/02/1999
Sworn and subscribed to before me
this 1 ?C day of _ .lam
19 99 A.D.
r ono ar
(A?,ftCE of *9 ?4Priff
Marv Jane Snydcr :.?:•?
Rcol Estatc Deputy :?'U'•:
William T. Tully
Solicitor
Ralph G. McAllister
Chief Deputy
Michael W. Rinehart
Assistant Chief Deputy
Dauphin County
Harrisburg, Pennsylvania 17101
ph:(717)255-2660 fax:(717)255-2889
Jack Lotwick
Sheriff
Commonwealth of Pennsylvania BENEFICIAL CONSUMER DISCOUNT
vs
County of Dauphin UNITED STATES OF AMERICA
Sheriff's Return
No. 1447-T - - -1999
OTHER COUNTY NO. 99-4200
AND NOW: July 13, 1999 at 10:27AM served the within
NOTICE & COMPLAINT IN CIVIL ACTION upon
UNITED STATES OF AMERICA by personally handing
C/O UNITED STATES ATTORNEY/MIDDLE DISTRI
to PHILYIS MITCHELL, REC 1 true attested copy(ies)
of the original NOTICE & COMPLAINT IN CIVIL ACTION and making known
to him/her the contents thereof at 228 WALNUT STREET
PO BOX 11754
HARRISBURG, PA 17108-0000
Sworn and subscribed to
before me this 13TH day oJULY, 1999
) rJ
PROTHONOTARY
So Answers,
?leAl(.
Sheriff of Dauphin County, Pa.
,
ey
Deputy Sh riff
Sheriff's Costs: $25.70 PD 07/12/1999
RCPT NO 125838
RH
1,i he Court of Common Pleas of Cumberland County, Pennsylvania
,eneficial Consumer Discount Company
VS.
Barry Deitch, a/k/a Barry L. Deitch, et. al.
SertiA: United States of America, c/Ro. 99-4200 Civil
Unfired States Attorney
NOW, 7/9/99
19_, I, SHERIFF OF CUMBERLAND COUNTY, PA, do
hereby deputize the Sheriff of Dauphin
County to execute this Writ, this
deputation being made at the request and risk of the Plaintiff.
Sheriff of Cuunberland" County, PA
Affidavit of Service
Now,
within
upon
at
by handing to
a
and made known to
So answers,
the contents thereof.
Sheriff of
Sworn and subscribed before
me this _ day of 19
copy of the original
COSTS
SERVICE _
MILEAGE _
AFFIDAVIT
County, PA
19 , at o'clock M. served the
DAUPHIN COUNTY
SHERIFF'S OFFICE
DAUPHIN COUNT f COURTHOU}
HARRISSURG PA 1730!
99 AL 12 rMl 9: 2 !
RECEIVED
9p JITL`
7 ¦
CASE NO: 1999-04200 P
COMMONWEALTH OF PENNSYLVANIA:
COUNTY OF CUMBERLAND
I
BENEFICIAL CONSUMER DISCOUNT
VS - o..?
DEITCH BARRY ET AL
KATHY CLARKE , Sheriff or Deputy Sheriff of
CUMBERLAND County, Pennsylvania, who being duly sworn according
to law, says, the within COMPLAINT - MORT FORE was served
upon TERRE/TENNANT the
defendant, at 1151:00 HOURS, on the 21st day of July
1999 at 87 VICTORY CHURCH ROAD
GARDNERS PA 17324 CUMBERLAND
County, Pennsylvania, by handing to MARK STOUGH (TENANT)
a true and attested copy of the COMPLAINT - MORT FORE
together with NOTICE
and at the same time directing His attention to the contents thereof.
Sheriff's Csts: So answers: ?I
Docketing 6.00
Affidavit 6.00
Surcharge 8.00 1?3Ybm?R ine, S i
$2082 MCCABE WEISBERG & REIS
08/02/1999
by
u y i-
Sworn and subscribed to before me
this day of
19 A.D.
-------Prot?!onoZary
i
MCCABE, WEISBERG AND CONWAY, P. C.
BYs TERRENCE J. MQCABE, ESQUIRE
Identification Number 16496
Firat Union Building
123 South Broad street, Suite 2080
Philadelphia, PA 19109
(215) 790-1010
I
COMPANYd b/a CONSUMER 8 NEFICIAL DISCOUNT MORTGAGE
COMPANY OF PENNSYLVANIA
BARRY DEITCH A/K/A
BARRY L. DEITCH
GAY DEITCH A/K/A
GAY L. DEITCH
UNITED STATES OF AMERICA
Attorney for Plaintiff
CUMBERLAND COUNTY
COURT OF COMMON PLEAS
NUMBER 99-4200
A3S a +,•• OF DAMnGc
--?_ ?s^J _Elv t ?n
TO THE PROTHONOTARY:
Kindly enter judgment by default in favor of Plaintiff and
against Defendants, Barry Deitch a/k/a Barry L. Deitch and Gay
Deitch a/k/a Gay L. Deitch, in the above-captioned matter for
failure to answer Complaint as required by Pennsylvania Rules of
Civil Procedure and assess damages as follows:
Principal
Interest from 4/15/99-9/7/99 545;942,x,0
TOTAL
$47,898.05
TFRRF?NCE aCr+BE/' n
-,('ESQUIRg
,
II/n? Attorney for Plaintiff
AND NOW, this C?6 71 day of e pl[? N_-P e -
Judgment is entered in favor of Plaintiff, 1999,
Beneficial Consumer
Discount Company d/b/a Beneficial Mortgage Company of
Pennsylvania and against Defendants, Barry Deitch a/k/a Barry L.
Deitch and Gay Deitch a/k/a Gay L. Deitch and damages are
assessed in the amount of $47,898,05, plus interest and costs.
BY THE PROTHONOTARY:
t-'
MCCABE, WEISBERG AND CONWAY, p. C.
BY: TERRENCE J. MCCABE, ESQUIRE
Identification Number 16496
First Union Building
123 South Broad Street, Suite 2080
Philadelphia, PA 19109
(215) 790-1010
BENEFICIAL CONSUMER DISCOUNT
COMPANY d/b/a BENEFICIAL MORTGAGE
COMPANY OF PENNSYLVANIA
V.
BARRY DEITCH A/K/A
BARRY L. DEITCH
GAY DEITCH A/K/A
GAY L. DEITCH
UNITED STATES OF AMERICA
COMMONWEALTH OF PENNSYLVANIA:
COUNTY OF CUMBERLAND SS.
Attorney for Plaintiff
CUMBERLAND COUNTY
COURT OF COMMON PLEAS
NUMBER 99-4200
The undersigned, being duly sworn according to law, deposes
and says that the Defendants 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; and that the Defendants, Barry
Deitch a/k/a Barry L. Deitch and Gay Deitch a/k/a Gay L. Deitch,
is over eighteen (18) years of age, and resides at 101 East Main
Street, Walnut Bottom, PA 17266.
SWORN TO AND SUBSCRIBED
BEFORE ME THIS /0"? DAY
OF 1999.
I AA DMCB. MC
Go?,Qr.L
TERRENCE J. MCCABE, ESQUIRE
Attorney for Plaintiff
OTARY PUBLIC
NOTARIAL SEAL PuNic
EOF9A D. VCHELI. NotaY
iy of P adelphie, Phila Co
Cortumssm^ £xpaes June 2.
MCCABE, WEISBERG AND CONWAY, P.C.
BY: TERRENCE J. MCCABE, ESQUIRE
Identification Number 16496
First Union Building
123 South Broad Street, Suite 2060
Philadelphia, PA 19109
(215) 790-1010
BENEFICIAL CONSUMER DISCOUNT
COMPANY d/b/a BENEFICIAL MORTGAGE
COMPANY OF PENNSYLVANIA
V.
BARRY DEITCH A/K/A
BARRY L. DEITCH
GAY DEITCH A/K/A
GAY L. DEITCH
UNITED STATES OF AMERICA
Attorney for Plaintiff
CUMBERLAND COUNTY
COURT OF COMMON PLEAS
NUMBER 99-4200
Terrence J. McCabe, Esquire, attorney for Plaintiff, being
duly sworn according to law, deposes and says that he deposited
in the United States Mail a letter notifying the Defendant that
judgment would be entered against them within ten (10) days from
the date of said letter in accordance with Rule 237.5 of the
Pennsylvania Rules of Civil Procedure. A copy of said letter is
attached hereto and marked as Exhibit °A."
SWORN TO AND SUBSCRIBED Mccet,(
TERRENCE J. McCABE, ESQUIRE
BEFORE ME THIS DAY Attorney for Plaintiff
OF ? 1999.
/NOTARY PUBLIC
GLORIA NOTA
C1N OA RIAL SEAL
0 M1iCHElI ry
M f Phdadelphla, Ph 1a18C Pubrylic
v Commission Exwres d_ u__ c?e?t]0?
f
The undersigned, TERRENCE J. McCABE, ESQUIRE, hereby
certifies that he is the attorney for the Plaintiff in the within
action and that he is authorized to make this verification and
that the foregoing facts are true and correct to the best of his
knowledge, information and belief and further states that false
statements herein are made subject to the penalties of 18 PA.C.S.
Section 4909 relating to unsworn falsification to authorities.
TERRENCE J. Mc ABE, ESQUIRE
OFFICE OF THE PROTHONOTARY
COURT OF COMMON PLEAS
CUMBERLAND COUNTY COURTHOUSE, CARLISLE, PA 17013
LAWRENCE E. WELRER
Prothonotary
To: Barry Deitch a/k/a August 13, 1999
Barry L. Deitch
101 East Main Street
Walnut Bottom, PA 17266
Beneficial Consumer Discount Company CUMBERLAND COUNTY
d/b/a Beneficial Mortgage Company of COURT OF COMMON PLEAS
Pennsylvania
V. NUMBER 1999-04200
Barry Deitch a/k/a Barry L. Deitch
Gay Deitch a/k/a Gay L. Deitch
United States of America
NOTICE, RULE 237.5
NOTICE OF PRAECIPE TO ENTER JUDGMENT BY DEFAULT
IMPORTANT NOTICE NOTIFICACION IMPORTANTE
You are in default because you have fat led to Usted as encuentra an estedo de rebeldle par
enter a written appearance personally or by no haber presentado me comperecencia escrita,
attorney and file in writing with the Court ya sea personalmente o par abogado y par no
your defenses or objections to the claims set haber redicado par escrito eon este TrlbunaL
forth against you. Unless you act within ten sue defenses u objeclones a Los reclemas
(10) days from the date of this notice, a formuledos an contra suyo. Al no tamer La
judgment nay be entered against you without action debida dentro de diez (10) dies de is
e hearing and you may Lose your property or facha de esta notification, at Tribunal padre,
other important rights. You should take this sin necesidad de coaparecer usted an carte u
notice to a lawyer at once. If you do not air preuba aLgune, dictar sentencla an su
have a lawyer or cannot afford one, go to or contra y usted podria perder biers u otros
telephone the following office to find out JerLchos importances. Debt Ltevar mete
where you can get legal help: IpMjcacion a un abogado frmatemente. Si
t ne abogedo, o at no tiene dlnera
f tat servicia, vaya an persons
o l r to oficina, nombrada
pare eve 1 e conseguir asistenc(a
legal 'r`
Court Administrator Court Administrator 01
Cumberland County Courthouse Cumberland County Courthouse
Carlisle, PA 17013 Carlisle, PA 17013
(717) 240.6200 (717) 21.0.6200
If you have any questions concerning this notice, please call:
Terrence J. McCabe, Esquire
McCABE, WEISBERG AND CONWAY, P.C.
First Union Building
123 South Broad Street, Suite 2080
Philadelphia, Pennsylvania 19109
at this telephone number: (215) 790-1010
TJM/db
OFFICE OF THE PROTHONOTARY
COURT OF COMMON PLEAS
CUMBERLAND COUNTY COURTHOUSE, CARLISLE, PA 17013
LAWRENCE E. WELKER
Prothonotary
To: Gay Deitch a/k/a
Gay L. Deitch
101 East Main Street
Walnut Bottom, PA 17266
August 13, 1999
Beneficial Consumer Discount Company
d/b/a Beneficial Mortgage Company of
Pennsylvania
V.
Barry Deitch a/k/a Barry L. Deitch
Gay Deitch a/k/a Gay L. Deitch
United States of America
CUMBERLAND COUNTY
COURT OF COMMON PLEAS
NUMBER 1999-04200
NOTICE, RULE 237.5
NOTICE OF PRAECIPE TO ENTER JUDGMENT BY DEFAULT
IMPORTANT NOTICE NOTIFICACION IMPORTANTE
You are in default bocause you have failed to
enter a written appearance personalty 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:
Usted as encuentra an estedo de rebeldia par
no haber presentado una comparecencfa escrita,
ya sea personalmente o par ebogedo y par no
haber radicedo par escrita can este Tribunal
sus defenses u objecionea a tea reclamos
formulados an contra suyc. At no tamer Is
action debida dentra do diez (10) dies de to
fecha de sate notfficacion, at Tribunal podra,
sin necesidad de comparecer usted an torte u
air preubs atguna, dieter sentenele an ou
contra y usted podria perder bienes u otros
derechos importantes. Dabs llevar ests
notfficacion a un abogado im¢dfatemente. Si
usted no tfene obogado, o s1 no tfene dinero
suficlente pare tat servfcfo, vaya an persona
o lleme par telefono a to oficina, nombrada
pars averiguer sf puede conseguir astetencis
legal.
Court Administrator
Cumberland County Courthouse
Carlisle, PA 17013
(717) 240.6200
Court Administrator
Cumberland County Courthouse
Carlisle, PA 17013
(717) 240.6200
If you have any questions concerning this notice, please call:
Terrence J. McCabe, Esquire
MCCABE, WEISBERG AND CONWAY, P.C.
First Union Building
123 South Broad Street, Suite 2080
Philadelphia, Pennsylvania 19109
at this telephone number: (215) 790-1010
TJM/db
MCCABE, WEISBERG AND CONWAY, P.C.
BY: TERRENCE J. MCCABE, ESQUIRE
Identification Number 16496
First Union Building
123 South Broad Street, Suite 2080
Philadelphia, PA 19109
(215) 790-1010
BENEFICIAL CONSUMER DISCOUNT
COMPANY d/b/a BENEFICIAL
MORTGAGE CO. OF PENNSYLVANIA
V.
BARRY DEITCH, a/k/a
BARRY L. DEITCH
GAY DEITCH, a/k/a
GAY L. DEITCH
UNITED STATES OF AMERICA
Attorney for Plaintiff
CUMBERLAND COUNTY
COURT OF COMMON PLEAS
NUMBER 99-4200
Terrence J. McCabe, Esquire, attorney for the Plaintiff in the
within action, being duly sworn according to law, deposes and says
that on July 26, 1999, a true and correct copy of Complaint in
Mortgage Foreclosure was served by United States registered mail,
return receipt requested, upon the following:
The United States of America
The Honorable Janet Reno
Attorney General of the United States
United States Department of Justice
10th and Constitution Avenues Northwest
Room 4400
Washington, DC 20530
A true and correct copy of the letter and green card, article
number R 298 019 327, is attached hereto, made a part hereof, and
marked Exhibit "A."
SWORN TO AND SUBSCRIBED
BEFORE ME THIS/;Y4, DAY
OF {?. F yN? p?J 1999.
NOTARY-p
L-?
ARI, ARIA
TRACY A. RIFF, Notary P.,City of Philadelphia. Ph,a. Cc •?ry
_f'1v C011i," an Expires O. • "3 2 co.
TERRENCE J. M E
Attorney for PlaintiffQUIRE
LAW OFFICES
McCABE, WEISBERG & CONWAY, P.C.
SUITE 2080 SURE 600
FIRST UNION BUILDING
TERRENCE 1, MCCABE 123 SOUTH BROAD STREET 216 HADDON AVENUE
WESTMONT. NJ 08108
PHILADELPHIA. PENNSYLVANIA 19109 (609) 858.7080
(215)790.1010 FAX (609) 858.7020
FAX (215) 790.1274
SURE 1503
52 VANDERBILT AVENUE
NEW YORK, NY 10017
(212) 697-0011
FAX (212) 953-0986
July 22, 1999
The United States of America
The Honorable Janet Reno
Attorney General of the United States
United States Department of Justice
10th and Constitution Avenues Northwest
Room 4400
Washington, DC 20530
Re: Beneficial Consumer Discount Company, d/b/a Beneficial
Mortgage Company of PA v. Barry Deitch, a/k/a Barry L. Deitch,
Gay Deitch, a/k/a Gay L. Deitch, and the USA
Cumberland County; C.C.P.; Number 99-4200 Civil Term
Dear Ms. Reno:
Enclosed please find a true and correct copy of Complaint in
Mortgage Foreclosure, the original of which has been duly filed of
record with the Court of Common Pleas of Cumberland County,
Pennsylvania on July 9, 1999.
Very truly yours,
TERRENCE J. McCABE
TJM/ld
Enclosure
REGISTERED MAIL NUMBER tv)", ' a 4 j I
RETURN RECEIPT REQUESTED R 298 019 327 E9MM t.,
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OFFICE OF THE PROTHONOTARY
COURT OF COMMON PLEAS
CUMBERLAND COUNTY COURTHOUSE, CARLISLE, PA 17013
LAWRENCE E. WELKER
Prothonotary
To: United States of America August 13, 1999
228 Walnut Street
P.O. Box 11754
Harrisburg, PA 17108
Beneficial Consumer Discount Company CUMBERLAND COUNTY
d/b/a Beneficial Mortgage Company of COURT OF COMMON PLEAS
Pennsylvania
V. NUMBER 1999-04200
Barry Deitch a/k/a Barry L. Deitch
Gay Deitch a/k/a Gay L. Deitch
United States of America
NOTICE, RULE 237.5
NOTICE OF PRAECIPE TO ENTER JUDGMENT BY DEFAULT
IMPORTANT NOTICE NOTIFICACION IMPORTANTE
You are in default because you have failed to Usted as encuentra an estado de rebeldla por
enter a written appearance personally or by no haber presentedo una comparecencle escrita,
attorney and file in writing with the court yo sea personelmente o por abogado y por no
your defenses or objections to the claims set hater radicado par escrito con cote Tribunal
forth against you. Unless you act within ten sus defenses u objeciones a Los rectamos
(10) days from the date of this notice, a formulados an contra suyo. Al no tomar to
Judgment may be entered against you without accfon debide dentro de diez (10) dies de to
a hearing and you may lose your property or fecha de esto notification, at Tribunal padre,
other Important rights. You should take this sin necesidad de comparecer usted an torte u
notice to a lawyer at once. If you do not oir preuba alguna, dieter sentencia an ou
have a lawyer or cannot afford one, go to or contra y usted podria perder Manse u otros
telephone the following office to find out derechos Importantes. Dabs tLevar esto
where you eon get legal help: notificacfon a un obagedo irmediataments. of
usted no tlene abogado, o si no Liens dinero
suffeiente pare tat servicio, vaya an persona
o (lane por telefono a to oficina, nombrada
pare averiguar si puede conseguir asistenefe
legal.
Court Administrator Court Administrator
Cumberland County Courthouse Cumberland County Courthouse
CarLfate, PA 17013 Carlisle, PA 17013
(717) 240.6200 (717) 240-6200
If you have any questions concerning this notice, please call:
Terrence J. McCabe, Esquire
McCABE, WEISBERG AND CONWAY, P.C.
First Union Building
123 South Broad Street, Suite 2080
Philadelphia, Pennsylvania 19109
at this telephone number: (215) 790-1010
TJM/db
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OFFICE OF THE PROTHONOTARY
COURT OF COMMON PLEAS
CUMBERLAND COUNTY COURTHOUSE, CARLISLE, PA 17013
Curtis R. Long
Prothonotary
To: Barry Deitch a/k/a
Barry L. Deitch
101 East Main Street
Walnut Bottom, PA 17266
BENEFICIAL CONSUMER DISCOUNT
COMPANY d/b/a BENEFICIAL MORTGAGE
COMPANY OF PENNSYLVANIA
V.
BARRY DEITCH A/K/A
BARRY L. DEITCH
GAY DEITCH A/K/A
GAY L. DEITCH
UNITED STATES OF AMERICA
NOTICE
CUMBERLAND COUNTY
COURT OF COMMON PLEAS
NUMBER 99-4200
Pursuant to Rule 236, you are hereby notified that a
JUDGMENT has been entered in the above proceeding as indicated
below.
Curtis R. Long
Prothonotary
x Judgment by Default
Money Judgment
Judgment in Replevin
Judgment for Possession
If you have any questions concerning this Judgment-, please call
OFFICE OF THE PROTHONOTARY
COURT OF COMMON PLEAS
CUMBERLAND COUNTY COURTHOUSE, CARLISLE, PA 17013
Curtis P. Long
Prothonotary
To: Gay Deitch a/k/a
Gay L. Deitch
103. East Main Street
Walnut Bottom, PA 17266
BENEFICIAL CONSUMER DISCOUNT
COMPANY d/b/a BENEFICIAL MORTGAGE
COMPANY OF PENNSYLVANIA
V.
BARRY DEITCH A/K/A
BARRY L. DEITCH
GAY DEITCH A/K/A
GAY L. DEITCH
UNITED STATES OF AMERICA
NOTICE
CUMBERLAND COUNTY
COURT OF COMMON PLEAS
NUMBER 99-4200
Pursuant to Rule 236, you are hereby notified that a
JUDGMENT has been entered in the above proceeding as indicated
below.
Curtis R. Long
Prothonotary
--X_ Judgment by Default
Money Judgment
Judgment in Replevin
Judgment for Possession
If you have any questions concerning this Judgment, please call
Terrence J M Qab Esquire at (215) 790 1" n
CIO
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IN THE 00URT OF COMMON PLEAS OF CL*MRLAND COUMT, PENNSYLVANIA
CML DMSION
BENEFICIAL CONSUMER DISCOUNT COMPANY, File No. 99-4200
d/b/a BENEFICIAL MORTGAGE CO. OF
PENNSYLVANIA
BARRY DEITCH, a/k a
BARRY L. DEITCH and
GAY DEITCH, a/k/a GAY L. DEITCH AND
UNITED STATES OF AMERICA
: Amount Due $47,898.05
. Interest from 9/8/99
: Atty's Comm
. Costs
TO THE PR0Tti0NOTARY OF THE SAID COURT:
The undersigned hereby certifies that the below does not arise out of a retail
installment sale, contract, or account based on a confession of judgment, but if it does,
it is based on the appropriate original proceeding filed pursuant to Act 7 of 1966 as
amended; and for real property pursuant to Act 6 of 1974 as amended.
PRAECIPE FOR EXECUTION
Issue writ of execution in the above matter to the Sheriff of Cumberland
County, for debt, interest and costs upon the following described property of the
defendant(s) 87 Victory Church Road, Gardners, PA 17324
(See attached description).
PRAECIPE FOR ATTACFPUW E E CEMON
Issue writ of attachment to the Sheriff of Cumberland County, for debt,
interest and costs, as above, directing attachment against the above-named garnishee(s) for
the following property (if real estate, supply six copies of the description; supply four
copies of lengthy personalty list) N/A
and all other property of the defendant(s) in the possession, custody or control of the
said garnishee(s).
(Indicate) Index this writ against the garnishee(s) as a lis pendens against
real estate of the defendant(s) described in the attached exhibit.
DATE: 12/13/99
Signature:
_?_?M
Print Name: Terrence J. McCabe, Esq.
Address: 123 S. Broad St., Suite 2080
Phila., PA 19109
Attorney for: Plaintiff
Telephone: (215) 790-1010
Supreme Court ID No.: 16,/Q 6
Notes: If real property, supply six copies of description including improvements and an
original and copy of affidavit of ownership (paR.C.p. No. 3129).
If lengthy personalty list, supply four copies of list.
To index writ, file separate praecipe with writ.
ALL THOSE TWO (2) lots of ground situate in South Middleton Township,
Cumberland County, Pennsylvania, bounded and described in accordance with a
Final Minor Subdivision Plan for Black Associates, by Stephen G. Fisher,
Professional Land Surveyor, and recorded in Cumberland County Plan Book 47,
Page 116, as follows:
TRACT NO. 1: BEGINNING at a point in the center line of Victory Church Road
(LR 21005), at corner of lands now or formerly of William K. Peffer; thence by the
center line of said Victory Church Road, North 58 degrees 56 minutes West
150.00 feet to a point being Southeast comer of Lot No. 3 on the aforementioned
Plan; thence by the said Lot No. 3, North 31 degrees 04 minutes East, 300.00 feet
to a point on line of Lot No. 1 on the aforementioned Plan; thence by Lot No.1 on
said Plan, South 58 degrees 66 minutes East 165.37 feet to a point on line of
lands now or formerly of the said William K. Peffer; thence by said Peffer lands,
South 34 degrees West 300.39 feet to a point, the place of BEGINNING.
CONTAINING 43539.888 square feet and being Lot 4 on said Plan.
TRACT NO. 2: BEGINNING at a point in the center line of Victory Church Road
(LR 21005), at the Southwest comer of Lot No. 4 on the aforementioned Plan;
thence by the center line of the said Victory Church Road, North 58 degrees 56
minutes West, 150.00 feet to a point, being the Southeast comer of Lot No. 1 on
the aforementioned Plan; thence by Lot No. 1 on said Plan; North 21degrees 04
minutes East 300.00 feet to a point; thence by the same, South 68 degrees 66
minutes East 150.00 feet to a point, being the Northwest corner of Lot No. 4 on
said Plan; thence by Lot No. 4 South 31 degrees 04 minutes West 300.00 feet to a
point, the place of BEGINNING.
CONTAINING 41,250.00 square feet and being Lot No. 3 on said Plan.
TAX OR PARCEL # 40.40-2654.037 & 40.40.2654.038
Being known as 87 Victory Church Road, Gardners, PA 17324.
Improvements consist of a single family dwelling.
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MCCABE, WEISBERG AND CONWAY, P.C.
BY: TERRENCE J. McCABE, ESQUIRE
Identification Number 16496
First Union Building
123 South Broad Street, Suite 2080
Philadelphia, PA 19109
(215) 790-1010
Attorney for Plaintiff
BENEFICIAL CONSUMER DISCOUNT CUMBERLAND COUNTY
COMPANY d/b/a BENEFICIAL COURT OF COMMON PLEAS
MORTGAGE CO. OF PENNSYLVANIA
V.
BARRY DEITCH, a/k/a
BARRY L. DEITCH
GAY DEITCH, a/k/a
GAY L. DEITCH
UNITED STATES OF AMERICA NUMBER 99-4200
AFFIDAVI'T' RTjH,9UANT TO RULE 3129
I, Terrence J. McCabe, Esquire, attorney for Plaintiff in
the above action, set forth as of the date the Praecipe for the
Writ of Execution was filed the following information concerning
the real property located at 87 Victory Church Road, Gardners, PA
17324, a copy of the description of said property is attached
hereto and marked Exhibit "A."
1. Name and address of Owner(s) or Reputed Owner(s):
Name
Barry Deitch, a/k/a
Barry L. Deitch
Address
101 E. Main St.
Walnut Bottom, PA 17266
Gay Deitch, a/k/a
Gay L. Deitch
101 E. Main St.
Walnut Bottom, PA 17266
2. Name and address of Defendant(s) in the judgment:
Name
Barry Deitch, a/k/a
Barry L. Deitch
Gay Deitch, a/k/a
Gay L. Deitch
United States of America
c/o U.S. Attorney for the
Middle District of PA
Address
101 E. Main St.
Walnut Bottom, PA 17266
101 E. Main St.
Walnut Bottom, PA 17266
235 North Washington St.
Scranton, PA 18503
or
Federal Building
228 Walnut Street
P.O. Box 11754
Harrisburg, PA 17108
3. Name and last known address of every judgment creditor
whose judgment is a record lien on the real property to be sold:
Name
Unemployment Compensation
Fund
Address
16th Floor
L&I Building
Harrisburg, PA 17121
United States of America
c/o U.S. Attorney for the
Middle District of Pa.
United States of America
Coyle Lumber Co., Inc
Cumberland County Adult
Probation
228 Walnut Street
P.O. Box 11754
Harrisburg, PA 17108
Internal Revenue Service
Federated Investors Tower
1001 Liberty Avenue
Thirteenth Floor
Suite 1300
Pittsburgh, PA 15222
42 West High Street
Carlisle, PA 17013
One Courthouse Square
Carlisle, PA 17013
Plaintiff herein.
r
4. Name and address of the last recorded holder of every
mortgage of record:
Name Address
Plaintiff herein.
5. Name and address of every other person who has any
record interest in or record lien on the property and whose
interest may be affected by the sale:
Name
Address
None.
6. 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
Address
Occupant(s) 87 Victory Church Road
Gardners, PA 17324
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. Section 4904 relating to
unsworn falsification to authorities.
1.2 i 6 -]L A 1,6 G ff/ r (-X k
DATE TERRENCE J. MCCABE, ESQUIRE
Attorney for Plaintiff
I
ALL THOSE TWO (2) lots of ground situate In South Middleton Township,
Cumberland County, Pennsylvania, bounded and described in accordance with a
Final Minor Subdivision Plan for Black Associates, by Stephen G. Fisher,
Professional Land Surveyor, and recorded in Cumberland County Plan Book 47,
Page 116, as follows:
TRACT N0. 1: BEGINNING at a point in the center line of Victory Church Road
(LR 21006), at corner of lands now or formerly of William K. Peffer; thence by the
center line of said Victory Church Road, North 68 degrees 66 minutes West
150.00 feet to a point being Southeast comer of Lot No. 3 on the aforementioned
Plan; thence by the said Lot No. 3, North 31 degrees 04 minutes East, 300.00 feet
to a point on line of Lot No. 1 on the aforementioned Plan; thence by Lot No.1 on
said Plan, South 68 degrees 56 minutes East 165.37 feet to a point on line of
lands now or formerly of the said William K. Peffer; thence by said Peffer lands,
South 34 degrees West 300.39 feet to a point, the place of BEGINNING.
CONTAINING 43,539.888 square feet and being Lot 4 on said Plan.
TRACT NO.2: BEGINNING at a point in the center line of Victory Church Road
(LR 21005), at the Southwest comer of Lot No. 4 on the aforementioned Plan;
thence by the center line of the said Victory Church Road, North 58 degrees 56
minutes West, 150.00 feet to a point, being the Southeast comer of Lot No.1 on
the aforementioned Plan; thence by Lot No. 1 on said Plan; North 21degrees 04
minutes East 300.00 feet to a point; thence by the same, South 58 degrees 56
minutes East 150.00 feet to a point, being the Northwest comer of Lot No. 4 on
said Plan; thence by Lot No. 4 South 31 degrees 04 minutes West 300.00 feet to a
point, the place of BEGINNING.
CONTAINING 41,250.00 square feet and being Lot No. 3 on said Plan.
TAX OR PARCEL # 40-40-2654.037 & 40-40-2654-038
Being known as 87 Victory Church Road, Gardners, PA 17324.
AWR Y
EXHIBIT
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MCCABE, WEISBERG AND CONWAY, P.C.
BY: TERRENCE J. MCCABE, ESQUIRE
Identification Number 16496
First Union Building
123 South Broad Street, Suite 2050
Philadelphia, PA 19109
(215) 790-1010
BENEFICIAL CONSUMER DISCOUNT
COMPANY d/b/a BENEFICIAL
MORTGAGE CO. OF PENNSYLVANIA
V.
BARRY DEITCH, a/k/a
BARRY L. DEITCH
GAY DEITCH, a/k/a
GAY L. DEITCH
UNITED STATES OF AMERICA
Attorney for Plaintiff
CUMBERLAND COUNTY
COURT OF COMMON PLEAS
NUMBER 99-4200
I, Terrence J. McCabe, Esquire, attorney for the Plaintiff
in the within matter, hereby certify that on the 13th day of
December, 1999, a true and correct copy of the Notice of
Sheriff's Sale of Real Property was served on all pertinent
lienholder(s) as set forth in the Affidavit Pursuant to 3129
which is attached hereto as Exhibit "A".
Copies of the letter and certificate of mailing are also
attached hereto, made a part hereof and marked as Exhibit "B."
TERRENC J. cCABE, E QUIRE
SWORN TO AND SUBSCRIBED
BEFOR ME THIS I.u5 DAY
OF ?CCQ.?nL eL, 1999.
NOTARY PUBLI
=FF EL
ary Pubt
hila. Cou
Oct. 23.
Lyi a?W.?¢ry
McCABE, WEISBERG AND CONWAY, P.C.
BY: TERRENCE J. McCABE, ESQUIRE
Identification Number 16496
First Union Building
123 South Broad Street, Suite 2080
Philadelphia, PA 19109
(215) 790-1010
BENEFICIAL CONSUMER DISCOUNT
COMPANY d/b/a BENEFICIAL
MORTGAGE CO. OF PENNSYLVANIA
V.
BARRY DEITCH, a/k/a
BARRY L. DEITCH
GAY DEITCH, a/k/a
GAY L. DEITCH
UNITED STATES OF AMERICA
Attorney for Plaintiff
CUMBERLAND COUNTY
COURT OF COMMON PLEAS
NUMBER 99-4200
AFFIDAVIT RURSU&NT TO RULE 3129
I, Terrence J. McCabe, Esquire, attorney for Plaintiff in
the above action, set forth as of the date the Praecipe for the
Writ of Execution was filed the following information concerning
the real property located at 87 Victory Church Road, Gardners, PA
17324, a copy of the description of said property is attached
hereto and marked Exhibit "A."
1. Name and address of Owner(s) or Reputed Owner(s):
Name
Barry Deitch, a/k/a
Barry L. Deitch
Address
101 E. Main St.
Walnut Bottom, PA 17266
Gay Deitch, a/k/a
Gay L. Deitch
101 E. Main St.
Walnut Bottom, PA 17266
EXHIBIT "xy
2. Name and address of. Defendant (s) in the judgment:
Name Address
Barry Deitch, a/k/a
Barry L. Deitch
101 E. Main St.
Walnut Bottom, PA 17266
Gay Deitch, a/k/a
Gay L. Deitch
United States of America
C/o U.S. Attorney for the
Middle District of PA
101 E. Main St.
Walnut Bottom, PA 17266
235 North Washington St.
Scranton, PA 18503
or
Federal Building
228 Walnut Street
P.O. Box 11754
Harrisburg, PA 17108
3. Name and last known address of every judgment creditor
whose judgment is a record lien on the real property to be sold:
Name
Unemployment Compensation
Fund
Address
16th Floor
L&I Building
Harrisburg, PA 17121
United States of America
c/o U.S. Attorney for the
Middle District of Pa.
228 Walnut Street
P.O. Box 11754
Harrisburg, PA 17108
United States of America Internal Revenue Service
Federated Investors Tower
1001 Liberty Avenue
Thirteenth Floor
Suite 1300
Pittsburgh, PA 15222
Coyle Lumber Co., Inc
42 West High Street
Carlisle, PA 17013
Cumberland County Adult
Probation
One Courthouse Square
Carlisle, PA 17013
Plaintiff herein.
4. Name and address of the last recorded holder of every
mortgage of record:
Name Address
Plaintiff herein.
5. Name and address of every other person who has any
record interest in or record lien on the property and whose
interest may be affected by the sale:
Name
Address
None.
6. 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
Address
Occupant(s) 87 Victory Church Road
Gardners, PA 17324
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. Section 4904 relating to
unsworn falsification to authorities.
r
DATE TERRENCE J. McCABE, ESQUIRE
Attorney for Plaintiff
ALL THOSE TWO (2) lots of ground situate in South Middleton Township,
Cumberland County, Pennsylvania, bounded and described In accordance with a
Final Minor Subdivision Plan for Black Associates, by Stephen G. Fisher,
Professional Land Surveyor, and recorded In Cumberland County Plan Book 47,
Page 118, as follows:
TRACT NO. 1: BEGINNING at a point in the center line of Victory Church Road
(LR 21006), at corner of lands now or formerly of William K. Peffer; thence by the
center line of said Victory Church Road, North 68 degrees 56 minutes West
150.00 feet to a point being Southeast comer of Lot No. 3 on the aforementioned .
Plan; thence by the said Lot No. 3, North 31 degrees 04 minutes East, 300.00 feet
to a point on line of Lot No. 1 on the aforementioned Plan; thence by Lot No. 1 on
said Plan, South 68 degrees 56 minutes East 165.37 feet to a point on line of
lands now or formerly of the said William K. Peffer; thence by said Peffer lands,
South 34 degrees West 300.39 feet to a point; the place of BEGINNING.
CONTAINING 43,539.888 square feet and being Lot 4 on said Plan.
TRACT NO. 2: BEGINNING at a point in the center line of Victory Church Road
(LR 21005), at the Southwest comer of Lot No. 4 on the aforementioned Plan;
thence by the center line of the said Victory Church Road, North 68 degrees 66
minutes West, 160.00 feet to a point, being the Southeast comer of Lot No. 1 on
the aforementioned Plan; thence by Lot No. 1 on said Plan; North 21degrees 04
minutes East 300.00 feet to a point; thence by the same, South 58 degrees 56
minutes East 150.00 feet to a point, being the Northwest comer of Lot No. 4 on
said Plan; thence by Lot No. 4 South 31 degrees 04 minutes West 300.00 feet to a
point, the place of BEGINNING.
CONTAINING 41,250.00 square feet and being Lot No. 3 on said Plan.
TAX OR PARCEL # 40.40-2654.037 & 40-40.2654-038
Being known as 87 Victory Church Road, Gardners, PA 17324.
EXHIBIT 66 911
McCABE, WEISBERG AND CONWAY, P.C.
BY: TERRENCE J. MCCABE, ESQUIRE
Identification Number 16496
First Union Building
123 South Broad Street, Suite 2080
Philadelphia, PA 19109
(215) 790-1010
BENEFICIAL CONSUMER DISCOUNT
COMPANY d/b/a BENEFICIAL
MORTGAGE CO. OF PENNSYLVANIA
V.
BARRY DEITCH, a/k/a
BARRY L. DEITCH
GAY DEITCH, a/k/a
GAY L. DEITCH
UNITED STATES OF AMERICA
Attorney for Plaintiff
CUMBERLAND COUNTY
COURT OF COMMON PLEAS
NUMBER 99-4200
DATE: December 13, 1999
TO: ALL PARTIES IN INTEREST AND CLAIMANTS
NOTICE OF SHERIFF'S SALE OF REAL PROPERTY
OWNER(S): Barry Deitch, a/k/a Gay L. Deitch and
Gay Deitch, a/k/a Gay L. Deitch
PROPERTY: 87 Victory Church Road, Gardners, PA 17324
IMPROVEMENTS: Residential Dwelling
The above-captioned property is scheduled to be sold at the
Sheriff's Sale on March 1, 2000 at 10:00 a.m. in the
Commissioner's Hearing Room located on the 2nd Floor of the
Cumberland County Courthouse, 1 Courthouse Square, Carlisle,
Pennsylvania 17013. Our records indicate that you may have an
interest in the property which will be extinguished by the sale.
You may wish to attend the sale to protect your interests.
A schedule of distribution will be filed by the Sheriff on a date
specified by the Sheriff not later than 30 days after sale.
Distribution will be made in accordance with the schedule unless
exceptions are filed thereto within 10 days after the filing of
the schedule.
EXHIBIT "boft
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MCCABE, WEISBERG AND CONWAY, P.C.
BY: TERRENCE J. MCCABE, ESQUIRE
Identification Number 16496
First Union Building
123 South Broad Street, Suite 2080
Philadelphia, PA 19109
(215) 790-1010
BENEFICIAL CONSUMER DISCOUNT
COMPANY d/b/a BENEFICIAL
MORTGAGE CO. OF PENNSYLVANIA
V.
BARRY DEITCH, a/k/a
BARRY L. DEITCH
GAY DEITCH, a/k/a
GAY L. DEITCH
UNITED STATES OF AMERICA
Attorney for Plaintiff
CUMBERLAND COUNTY
COURT OF COMMON PLEAS
NUMBER 99-4200
NOTICE OF SHERIFF' ALE OF REAL PROPERTY
TO: Barry Deitch, a/k/a Barry L. Deitch
Gay Deitch, a/k/a Gay L. Deitch
101 E. Main St.
Walnut Bottom, PA 17266
Your house (real estate) at 87 Victory Church Road,
Gardners, PA 17324 (more fully described as attached) is
scheduled to be sold at Sheriff's Sale on March 1, 2000 at 10:00
a.m. in the Commissioner's Hearing Room located on the 2nd Floor
of the Cumberland County Courthouse, 1 Courthouse Square,
Carlisle, Pennsylvania 17013, to enforce the court judgment of
$47,898.05 obtained by Beneficial Consumer Discount Company,
d/b/a Beneficial Mortgage Company of Pennsylvania against you.
NOTICE OF OWNER'S RIGHTS
YOU MAY BE ABLE TO PREVENT THIS SHERIFF' SALE
To prevent this Sheriff's Sale you must take immediate a ion:
1. The sale will be canceled if you pay to Beneficial
Consumer Discount Company, d/b/a Beneficial Mortgage
Company of Pennsylvania the back payments, late
charges, costs, and reasonable attorneys fees due. To
find out how much you must pay, you may call Terrence
J. McCabe, Esquire at (215) 790-1010.
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 the following notice on how to obtain an attorney.)
YOU M_nv am B?_
- ILL ABLE mO aAVE ?O rR PRnoZ
AND YOU HAVE ....HER
EVEN TF THE SHERTFF?S SALE DO c AXE 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 Terrence J. McCabe, Esquire at (215) 790-1010.
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 on the sale. To find out if this has
happened, you may call Terrence J. McCabe, Esquire at (215)
790-1010.
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 a 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 real estate. A schedule of distribution of the
money bid for your real estate will be filed by the Sheriff
on _March ?o nnn 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 schedule of distribution is wrong) are filed
with the Sheriff within ten (10) days after March 10 2000
7. You may also have other rights and defenses, or ways of
getting your real estate back, if you act immediately after
the sale.
LAWYER REFERRAL SERVICE
COURT ADMINISTRATOR
4TH FLOOR,
CUMBERLAND COUNTY COURTHOUSE
CARLISLE, PENNSYLVANIA 17013
(717) 240-6200
OR CUMBERLAND COUNTY
BAR ASSOCIATION
2 LIBERTY AVENUE
CARLISLE, PA 17013
(717) 249-3166
ALL THOSE TWO (2) lots of ground situate in South Middleton Township,
Cumberland County, Pennsylvania, bounded and described In accordance with a
Final Minor Subdivision Plan for Black Associates, by Stephen G. Fisher,
Professional Land Surveyor, and recorded In Cumberland County Plan Book 47,
Page 116, as follows:
TRACT NO. 1: BEGINNING at a point in the center line of Victory Church Road
(LR 21005), at corner of lands now or formerly of William K. Peffer; thence by the
center line of said Victory Church Road, North 68 degrees 66 minutes West
160.00 feet to a point being Southeast comer of Lot No. 3 on the aforementioned
Plan; thence by the said Lot No. 3, North 31 degrees 04 minutes East, 300.00 feet
to a point on line of Lot No. 1 on the aforementioned Plan; thence by Lot No.1 on
said Plan, South 68 degrees 66 minutes East 166.37 feet to a point on line of
lands now or formerly of the said Wiliam K. Peffer; thence by said Peffer lands,
South 34 degrees West 300.39 feet to a point, the place of BEGINNING.
CONTAINING 43639.888 square feet and being Lot 4 on said Plan.
TRACT NO. 2: BEGINNING at a point in the center line of Victory Church Road
(LR 21005), at the Southwest comer of Lot No. 4 on the aforementioned Plan;
thence by the center line of the said Victory Church Road, North 68 degrees 66
minutes West, 150.00 feet to a point, being the Southeast comer of Lot No. 1 on
the aforementioned Plan; thence by Lot No. 1 on said Plan; North 21degrees 04
minutes East 300.00 feet to a point; thence by the same, South 68 degrees 56
minutes East 160.00 feet to a point, being the Northwest corner of Lot No. 4 on
said Plan; thence by Lot No. 4 South 31 degrees 04 minutes West 300.00 feet to a
point, the place of BEGINNING.
CONTAINING 41,260.00 square feet and being Lot No. 3 on said Plan.
TAX OR PARCEL # 40.40-2654.037 & 40-40-2654-038
Being known as 87 Victory Church Road, Gardners, PA 17324.
Improvements consist of a single family dwelling.
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Beneficial Consumer Discount Company In the Court of Common Pleas of
D/b/a Beneficial Mortgage Co of Cumberland County, Pennsylvania
Pennsylvania No. 99-4200 Civil
-vs-
Barry Deitch aka Barry L. Deitch and
Gay Deitch aka Gay L. Deitch and
The United States of America
R. Thomas Kline, Sheriff, who being duly sworn according to law, says this writ
is returned STAYED.
Sheriffs Costs:
Docketing 30.00
Poundage 64.00
Posting Bills 30.00
Advertising 30.00
Law Library .50
County 1.00
Mileage 16.12
Certified Mail 1.95
Levy 30.00
Postpone Sale 20.00
Surcharge 30.00
Share of Bills 25.08
Law Journal 381.65
Patriot News 306.23
$ 966.53 Pd By Any
03-02-00
So answers:
??_?-r•,r..cG ?/!EEC
Sworn and subscribed to before me
This G R. Thomas Kline, Sheriff
°-' day of
1999, A.D. P? J BY?
Prothonotary Real Estate Deputy
1. f4 tl?. .2 -7G is
Opt< . 9122.31
XcCABE, WEISBERG AND CONWAY, P.C.
BY: TERRENCE J. MCCABE, ESQUIRE
Identification Number 16496
First Union Building
123 South Broad Street, Suite 2080
Philadelphia, PA 19109
(215) 790-1010
BENEFICIAL CONSUMER DISCOUNT
COMPANY d/b/a BENEFICIAL
MORTGAGE CO. OF PENNSYLVANIA
V.
BARRY DEITCH, a/k/a
BARRY L. DEITCH
GAY DEITCH, a/k/a
GAY L. DEITCH
UNITED STATES OF AMERICA
Attorney for Plaintiff
CUMBERLAND COUNTY
COURT OF COMMON PLEAS
NUMBER 99-4200
AFFIDAVIT PURSUANT TO RULE 3129
I, Terrence J. McCabe, Esquire, attorney for Plaintiff in
the above action, set forth as of the date the Praecipe for the
Writ of Execution was filed the following information concerning
the real property located at 87 Victory Church Road, Gardners, PA
17324, a copy of the description of said property is attached
hereto and marked Exhibit "A."
1. Name and address of Owner(s) or Reputed Owner(s) :
Name
Barry Deitch, a/k/a
Barry L. Deitch
Gay Deitch, a/k/a
Gay L. Deitch
Address
101 E. Main St.
Walnut Bottom, PA 17266
101 E. Main St.
Walnut Bottom, PA 17266
i'ad;
2. Name and address of Defendant(s) in the judgment:
Name
Barry Deitch, a/k/a
Barry L. Deitch
Gay Deitch, a/k/a
Gay L. Deitch
United States of America
c/o U.S. Attorney for the
Middle District of PA
Address
101 E. Main St.
Walnut Bottom, PA 17266
101 E. Main St.
Walnut Bottom, PA 17266
235 North Washington St.
Scranton, PA 18503
or
Federal Building
228 Walnut Street
P.O. Box 11754
Harrisburg, PA 17108
3. Name and last known address of every judgment creditor
whose judgment is a record lien on the real property to be sold:
Name
Unemployment Compensation
Fund
Address
16th Floor
L&I Building
Harrisburg, PA 17121
United States of America
c/o U.S. Attorney for the
Middle District of Pa.
United States of America
Coyle Lumber Co., Inc
Cumberland County Adult
Probation
228 Walnut Street
P.O. Box 11754
Harrisburg, PA 17108
Internal Revenue Service
Federated Investors Tower
1001 Liberty Avenue
Thirteenth Floor
Suite 1300
Pittsburgh, PA 15222
42 West High Street
Carlisle, PA 17013
One Courthouse Square
Carlisle, PA 17013
Plaintiff herein.
4. Name and address of the last recorded holder of every
mortgage of record:
Name
Address
Plaintiff herein.
5. Name and address of every other person who has any
record interest in or record lien on the property and whose
interest may be affected by the sale:
Name
Address
None.
6. Name and address of every other person of whom the
Plaintiff has knowledge who has any interest so the property
which may be affected by the sale:
Name
Address
Occupant(s) 87 Victory Church Road
Gardners, PA 17324
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. Section 4904 relating to
unsworn falsification to authorities.
DATE I ' / C j Y ' li+
TERRENCE J. McCABE, ESQUIRE
Attorney for Plaintiff
ALL THOSE TWO (2) lots of ground situate In South Middleton Township,
Cumberland County, Pennsylvania, bounded and described in accordance with a
Final Minor Subdivision Plan for Black Associates, by Stephen G. Fisher,
Professional Land Surveyor, and recorded in Cumberland County Plan Book 47,
Page 116, as follows:
TRACT NO. 1: BEGINNING at a point in the center line of Victory Church Road
(LR 21005), at corner of lands now or formerly of William K. Peffer; thence by the
center line of said Victory Church Road, North 68 degrees 56 minutes West
150.00 feet to a point being Southeast comer of Lot No. 3 on the aforementioned .
Plan; thence by the said Lot No. 3, North 31 degrees 04 minutes East, 300.00 feet
to a point on line of Lot No. 1 on the aforementioned Plan; thence by Lot No.1 on
said Plan, South 68 degrees 66 minutes East 165.37 feet to a point on line of
lands now or formerly of the said William K. Peffer; thence by said Peffer lands,
South 34 degrees West 300.38 feet to a point, the place of BEGINNING.
CONTAINING 43538.888 square feet and being Lot 4 on said Plan.
TRACT N0.2: BEGINNING at a point in the center line of Victory Church Road
(LR 21005), at the Southwest comer of Lot No. 4 on the aforementioned Plan;
thence by the center line of the said Victory Church Road, North 68 degrees 66
minutes West, 160.00 feet to a point, being the Southeast comer of Lot No.1 on
the aforementioned Plan; thence by Lot No. 1 on said Plan; North 21degrees 04
minutes East 300.00 feet to a point; thence by the same, South 58 degrees 68
minutes East 150.00 feet to a point, being the Northwest comer of Lot No. 4 on
said Plan; thence by Lot No. 4 South 31 degrees 04 minutes West 300.00 feet to a
point, the place of BEGINNING.
CONTAINING 41,250.00 square feet and being Lot No. 3 on said Plan.
TAX OR PARCEL # 40-40-2654.037 & 40.40.2654-038
Being known as 87 Victory Church Road, Gardners, PA 17324.
MINI' 6i9?
.1
McCABE, WEISBERG AND CONWAY, P.C.
BY: TERRENCE J. McCABE, ESQUIRE
Identification Number 16496
First Union Building
123 South Broad Street, Suite 2080
Philadelphia, PA 19109
(215) 790-1010
BENEFICIAL CONSUMER DISCOUNT
COMPANY d/b/a BENEFICIAL
MORTGAGE CO. OF PENNSYLVANIA
V.
BARRY DEITCH, a/k/a
BARRY L. DEITCH
GAY DEITCH, a/k/a
GAY L. DEITCH
UNITED STATES OF AMERICA
Attorney for Plaintiff
CUMBERLAND COUNTY
COURT OF COMMON PLEAS
NUMBER 99-4200
NOTICE OF SHERIFF'S SALE OF REAL PROPERTY
TO: Barry Deitch, a/k/a Barry L. Deitch
Gay Deitch, a/k/a Gay L. Deitch
101 E. Main St.
Walnut Bottom, PA 17266
Your house (real estate) at 87 Victory Church Road,
Gardners, PA 17324 (more fully described as attached) is
scheduled to be sold at Sheriff's Sale on March 1, 2000 at 10:00
a.m. in the Commissioner's Hearing Room located on the 2nd Floor
of the Cumberland County Courthouse, 1 Courthouse Square,
Carlisle, Pennsylvania 17013, to enforce the court judgment of
$47,898.05 obtained by Beneficial Consumer Discount Company,
d/b/a Beneficial Mortgage Company of Pennsylvania against you.
NOTICE OF OWNER'S RIGHTS
YOU MAY BE ABLE TO PREVENT THIS SHERIFFS SALE
To prevent this Sheriff's Sale you must take immediate action:
1. The sale will be canceled if you pay to Beneficial
Consumer Discount Company, d/b/a Beneficial Mortgage
Company of Pennsylvania the back payments, late
charges, costs, and reasonable attorneys fees due. To
find out how much you must pay, you may call Terrence
J. McCabe, Esquire at (215) 790-1010.
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 the following notice on how to obtain an attorney.)
YOU MAY STILL BE ABLE TO SAVE FOUR PROPERTY
AND YOU HAVE OTHER RIGHTS
EVEN IF THE SHERIFF'S SALE DOES T x LACE
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 Terrence J. McCabe, Esquire at (215) 790-1010.
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 on the sale. To find out if this has
happened, you may call Terrence J. McCabe, Esquire at (215)
790-1010.
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 a 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 real estate. A schedule of distribution of the
money bid for your real estate will be filed by the Sheriff
on March 30. 2000. 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 schedule of distribution is wrong) are filed
with the Sheriff within ten (10) days after March 30. 2000.
7. You may also have
getting your real
the sale.
other rights and defenses, or ways of
estate back, if you act immediately after
LAWYER REFERRAL SERVICE
COURT ADMINISTRATOR
4TH FLOOR,
CUMBERLAND COUNTY COURTHOUSE
CARLISLE, PENNSYLVANIA 17013
(717) 240-6200
OR CUMBERLAND COUNTY
BAR ASSOCIATION
2 LIBERTY AVENUE
CARLISLE, PA 17013
(717) 249-3166
ALL THOSE TWO (2) lots of ground situate in South Middleton Township,
Cumberland County, Pennsylvania, bounded and described in accordance with a
Final Minor Subdivision Plan for Black Associates, by Stephen G. Fisher,
Professional Land Surveyor, and recorded in Cumberland County Plan Book 47,
Page 116, as follows:
TRACT NO. 1: BEGINNING at a point in the center line of Victory Church Road
(LR 21006), at corner of lands now or formerly of William K. Peffer; thence by the
center line of said Victory Church Road, North 58 degrees 56 minutes West
150.00 feet to a point being Southeast comer of Lot No. 3 on the aforementioned
Plan; thence by the said Lot No. 3, North 31 degrees 04 minutes East, 300.00 feet
to a point on line of Lot No. 1 on the aforementioned Plan; thence by Lot No. 1 on
said Plan, South 68 degrees 66 minutes East 166.37 feet to a point on line of
lands now or formerly of the said William K. Peffer; thence by said Peffer lands,
-SoutTi 3d degrees We 300:3) met ?a point the plane of BEGINNING.-
CONTAINING 43539.888 square feet and being Lot 4 on said Plan.
TRACT NO. 2: BEGINNING at a point in the center line of Victory Church Road
(LR 21005), at the Southwest comer of Lot No. 4 on the aforementioned Plan;
thence by the center line of the said Victory Church Road, North 68 degrees 66
minutes West, 150.00 feet to a point, being the Southeast comer of Lot No. 1 on
the aforementioned Plan; thence by Lot No. 1 on said Plan; North 21degrees 04
minutes East 300.00 feet to a point; thence by the same, South 58 degrees 56
minutes East 160.00 feet to a point, being the Northwest corner of Lot No. 4 on
said Plan; thence by Lot No. 4 South 31 degrees 04 minutes West 300.00 feet to a
point, the place of BEGINNING.
CONTAINING 41,250.00 square feet and being Lot No. 3 on said Plan.
TAX OR PARCEL # 40-40-2654.037 & 40.40-2664-038
Being laiown as 87 Victory Church Road, Gardners, PA 17324.
Improvements consist of a single family dwelling.
WRIT OF EXECUTION and/or ATTACHMENT
COMMONWEALTH OF PENNSYLVANIA) NO. 99-4200 CIVIL fg?Term
COUNTY OF CUMBERLAND) CIVIL ACTION - LAW
TO THE SHERIFF OF Cumberland COUNTY:
To satisfy the debt, interest and costs due Beneficial Consumer Discount Company, d/b/a Beneficial
Mortgage Co. of Pennsylvania PLAINTIFF(S)
from Beta Deitch, a/k/a Barry L. Deitch and Gay Deitch a/k/a Gay L Deitch and United
States of America, 87 Victory Church Road, Gardners, PA 17324
DEFENDANT(S)
(1) You are directed to levy upon the property of the defendant(s) and to sell 87 Victory Church Road
Gardners, A 17324 (See a a hed dew r;ption)
(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) lfpropertyof thedefenclant(s) notlevieduponan subjectto attachment is found in the possession of anyoneother
than a named garnishee, you are directed to notify hinVher that he/she has been added as a garnishee and is enjoined as above
stated.
Amount Due $47,898.05 L.L $.50
Interest €., 9/849 Due Prothy st _nn
Any's Comm % Other Costs
Ally Paid 5199.20
Plaintiff Paid
Date: 15, 199 - December REQUESTING PARTY:
Name Terrence J. McCabe, Esq.
Address: 123 S. Broad St., Suite 2080
Philadelphia, PA 19109
Attorney for: Plaintiff
Telephone
215-790-1010
Curtis R. Long
Prothonotary, Civil Division
Deputy
Supreme Court ID No. 16496
REAL ESTATE SALE NO
l7, 1995 the she:(f 4MM f.mmr, the defendants
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