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HomeMy WebLinkAbout99-04559FEDERMAN AND PHELAN By: FRANK FEDERMAN, ESQUIRE IDENTIFICATION NO. 12248 TWO PENN CENTER PLAZA, SUITE 900 PHILADELPHIA, PA 19102 (215) 563-7000 COUNTRYWIDE HOME LOANS, F/K/A COUNTRYWIDE FUNDING CORPORATION 6400 LEGACY DRIVE PLANO, TX 75024 V. Plaintiff LYNN R. HAHN ANN E. HAHN 431 PAWNEE DRIVE MECHANICSBURG, PA 17055 Defendant(s) L TERM NO. 99-YSJ9 CUMBERLAND COUNTY CIVIL ACTION - LAW MORTGAGE FORECLOSURE NOTICE THIS FD2M IS A DEBT COLLECTOR ATTEMPTING TO COLLECT A DEBT. ANY INFORMATION WE OBTAIN WILL BE USED FOR THAT PURPOSE. IF YOU HAVE PREVIOUSLY RECEIVED A DISCHARGE IN BANKRUPTCY, THIS CORRESPONDENCE SHOULD NOT BE CONSTRUED TO BE AN ATTEMPT TO COLLECT A DEBT BUT ONLY ENFORCEMENT OF A LIEN AGAINST PROPERTY. You have been sued in Court. If you wish to defend against the claims set forth in the following pages, you must take action within twenty (20) days aller this Complaint and Notice are served, by entering a written appearance personally or by attorney and filing in writing with the court your defenses or objections to the claims set forth against you. You are warned that if you fail to do so the case may proceed without you and a judgment may be entered against you by the court without further notice for any money claimed in the Complaint or for any other claim or relief requested by the Plaintiff. You may lose money or property or other rights important to you. YOU SHOULD TAKE THIS PAPER TO YOUR LAWYER AT ONCE. IF YOU DO NOT HAVE A LAWYER OR CANNOT AFFORD ONE, GO TO OR TELEPHONE THE OFFICE SET FORTH BELOW TO FIND OUT WHERE YOU CAN GET LEGAL HELP. CUMBERLAND COUNTY CUMBERLAND COUNTY BAR ASSOCIATION ATTORNEY FOR PLAINTIFF COURT OF COMMON PLEAS CIVIL DIVISION 2 LIBERTY AVENUE CARLISLE. PA 17013 (717) 249-3166 Plaintiff' is COUNTRYWIDE HOME LOANS. F/K/A COUNTRYWIDE FUNDING CORPORATION 6400 LEGACY DRIVE PLANO, TX 75024 2. The name(s)and last known address(es) of the Defendant(s) are LYNN R. HAHN ANN E. HAHN 431 PAWNEE DRIVE MECHANICSBURG, PA 17055 who is/are the mortgagor(s) and real owner(s) of the property hereinafter described 3. On 11/4/93 mortgagor(s) made, executed and delivered a mortgage upon the premises hereinafter described to LANCORP MORTGAGE COMPANY which mortgage is recorded in the Office of the Recorder of CUMBERLAND County, in Mortgage Book No. 1176, Page 1193. By Assignment of Mortgage dated 8/24/95 the mortgage was assigned to BANCBOSTON MORTGAGE CORPORATION which Assignment is recorded in Miscellaneous Book No. 503, Page 398. By Assignment of Mortgage dated 12/1/95 the mortgage was assigned to PLAINTIFF which Assignment is recorded in Miscellaneous Book No. 311, Page 65. 4. The premises subject to said mortgage is described as attached. 5. The mortgage is in default because monthly payments of principal and interest upon said mortgage duc 12/1/98 and each month thereafter are due and unpaid, and by the terms of said mortgage, upon failure of mortgagor to make such payments after a date specified by written notice sent to Mortgagor, the entire principal balance and all interest due thereon are collectible forthwith. A copy of such notice is attached as Exhibit "A." 6. The following amounts are duc on the mortgage: Principal Balance $162,28653 Interest 7.833.07 11/1/98 through 7/1/99 (Per Dictn $32.23) Attorney's Fees 8,1 14.00 Cumulative Late Charges 410.06 11/4/93 to 7/1/99 Cost of Suit and Title Search 550.00 Subtotal 179,193.66 Escrow Credit 0.00 Deficit 6,993,37 Subtotal 6.893.37 TOTAL $186,087,03 The attorney's fees set forth above are in conformity with the Mortgage documents and Pennsylvania Law, and will be collected in the event of a third party purchaser at Sheriffs Sale. If the Mortgage is reinstated prior to the Sale, reasonable attorney's fees will be charged. 8. This action does not come under Act 6 of 1974 because the original mortgage amount exceeds $50,000.00. The Temporary Stay as provided by the Homeowner's Emergency Mortgage Assistance Program, Act 91 o(1983, has terminated because either: (i.) Defendant(s) have failed to meet with the Plaintiff or an authorized Credit Counseling Agency in accordance with Plaintiffs written Notice to Defendants, a tnne and correct copy of which is attached hereto as Exhibit `B'% or (ii.) Defendant(s) application for assistance has been rejected by the Pennsylvania Housing Finance Agency. 10. Pursuant to the Fair Debt Collection Practices Act, 15 U.S.C. § 1692 et seq. (1977), Defendant(s) may dispute the validity of the debt or any portion thereof. If Defendant(s) do so in writing within thirty (30) days of receipt of this pleading, Counsel for Plaintiff will obtain and provide Defendant(s) with written verification thereof; otherwise, the debt will be assumed to be valid. Likewise, if requested within thirty (30) days of receipt of this pleading, Counsel for Plaintiff will send Defendant(s) the name and address ofthe original creditor if different from above. WHEREFORE, PLAINTIFF demands an in rein Judgment against the Defendant(s) in the sum of $186,087.03, together with interest from 7/1%99 at the rate of $32.23 per diem to the date of Judgment, and other costs and charges collectible under the mortgage and for the foreclosure and sale of the mortgaged property. /s Frank Federman FRANK FEDERMAN, ESQUIRE Attorney for Plaintiff Send Payments to: P.O. Box 10219 Van Nuys, CA 91410.0219 May 26, 1999 Lynn R Hahn & Ann E Hahn 431 Pawnee Dr Mechanicsburg, PA 17055-0000 Certified Mail No. Return Receipt Requested Countrywide Loan # 6124753 Property Address: 431 Pawnee Dr Mechanicsburg, PA 17055-0000 NOTICE OF INTENTION TO FORECLOSE Countrywide Home Loans, Inc. (hereinafter "Countrywide") services serious default because you have not made your required payments. your loan as of the date of this letter is as follows: Monthly Payments: 12/01/1998-05/31/1999 @ $1,171.64 Late Charges: 12101/1998 - 05/31/1999 @ $58.58 Other Charges: Uncollected Costs: TOTAL DUE: your home loan. Your home loan is in The total amount now required to reinstate $7,029.84 $351.48 $1,234.25 $8,615.57 You may cure this default within THIRTY-FIVE (35) DAYS of the date of this letter, by paying to us the above amount of $8,615.57, plus any additional monthly payments, late charges, fees and other applicable charges which may fall due during this period. Such payment must be in the form of certified check, cashier's check or money order, and made payable to Countrywide at P.O. Box 10221, Van Nuys, CA 91410-0221. If your check or other payment is returned to us for insufficient funds or for any other reason, you will not have cured your default. No extension of time to cure will be granted due to a returned payment. If you do not cure this default within THIRTY-FIVE (35) DAYS, we will accelerate the mortgage payments. This means 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 the full payment of the amount of default is not made within THIRTY-FIVE (35) DAYS, we also intend to immediately start a lawsuit to foreclose on your mortgaged property. If the mortgage is foreclosed, your mortgaged property will be sold by the Sheriff to pay off the mortgage debt. If you cure the default before we 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 us, which may also include our reasonable costs. If you cure this default within the thirty-five day period, you will not be required to pay the attorney's fees. YOU HAVE THE RIGHT TO REINSTATE AFTER ACCELERATION AND THE RIGHT TO ASSERT IN THE FORECLOSURE PROCEEDING THE NON-EXISTENCE OF A DEFAULT OR ANY OTHER DEFENSE YOU MAY HAVE TO ACCELERATION AND FORECLOSURE. 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-five (35) day period and foreclosure proceedings have begun, you still have the right to cure the default and prevent the sale at any time up to one hour before the foreclosure sale. You may do so by paying the total due, as well as all reasonable attorney's fees and costs incurred in connection with the foreclosure sale (and perform any other requirements under the mortgage). Pursuant to your loan documents, and because your loan is in default, Countrywide may, at its option, enter upon and conduct an inspection of your property. The purpose of this inspection is to observe the physical condition of your property, to verify that the property is occupied and/or to determine the identity of the occupant. You will be responsible for the cost of any such inspection. It is estimated that the earliest date that such a foreclosure sale could be held would be approximately six (6) months from the date of this letter. A notice of the date of the foreclosure sale will be sent to you before the sale. You may rind out at any time exactly what the required payment will be by calling us at the following number: 800-669-4575. This payment must be in the form of cashier's check, certified check or money order and made payable to us at the address stated above. If you cure this default, the mortgage will be restored to the same position as if no default had occurred. However, you may not cure your default more than three (3) times in any calendar year. You should realize that a foreclosure sale will end your ownership of the mortgaged property and your right to remain in it. If you continue to live in the property after the Sheriffs sale, a lawsuit could be started to evict you. Please write your loan number on all checks and correspondence PENN6 7116197 EXHIBIT A Lynn R Hahn If you are unable to cure your default en or before , Countrywide wants you to be aware of various options that may be available to you through Countrywide to prevent a foreclosure sale of your property. For example: • Repayment Plan It is possible that Countrywide may be able to assist you in keeping your home by offering you some form of payment assistance. Our basic plan requires that you pay Countrywide, up front, at east 'r4 of the amount necessary to bring your account current, and that you pay the balance of your overdue amount, along with your regular monthly payment, over a defined period of time. Other repayment plans also are available. • Loan Modification: Alternatively, it is possible that Countrywide may be able to lower your regular monthly payments by reducing your interest rate, and then capitalize your delinquent payments to your current loan amount, through a modification of your loan. This foreclosure alternative, however, is limited to certain loan types. • Sale of Your Property: Alternatively, it you are willing to sell your home in order to avoid foreclosure, Countrywide may be able to offer you an alternative to foreclosure even if your home is worth less than what is owed on it. • Deed-in-Lieu: Alternatively, if your property is free from otter liens or encumbrances, and if your default is due to a serious financial hardship which is beyond your control, you may be eligible to deed your property directly to Countrywide and avoid the foreclosure sale. If you are interested in discussing foreclosure alternatives with Countrywide, you must contact us immediately. If you request assistance, Countrywide will determine, in its sole discretion, whetter that assistance will be extended to you. In the meantime, Countrywide will proceed with all collection, enforcement and/or foreclosure efforts unless it agrees otherwise in writing. Please be advised that failure to bring your loan current or to enter into a written agreement as outlined above will result in the acceleration of your debt. Time is of the essence!! Should you have any questons concerning this notice, please contact Countywide's office immediately at 1-800-669-4575, extension 6135. z? 4 Kathy Morris Loan Counselor 800-669-4575, Extension 6135 If your loan was in default at the time that it was acquired by Countrywide, please be advised of the following: 1. Countrywide is a debt collector, we are attempting to collect a debt, and any information Countrywide obtains will be used for that purpose. 2. The amount currently owed to Countrywide is $8,615.57 (there may be other accrued interest, costs and expenses). Unless you, within thirty (30) days after receipt of this letter, dispute the validity of the debt owed or any portion of this debt, we will assume the amount to be valid. If you notify us in writing within this thirty (30) day time frame that you dispute the debt or any portion of the debt, we will obtain verification of the debt and mail it to you and, if you so request, provide you with the name and address of the original creditor if it is different from the current creditor. Please direct any written disputes to the following address: Countrywide Home Loans, Inc. Co//ecdons, MS S V-34 Atfendon: Research Counselor P.O. Box 10221 Van Nuys, CA 914100221 EXHIBITA Send Corrrsponor ')lo P O Box 260599 •._ Plano, TX 75026-0599 Send Payments to: P.O. Box 10219 Van Nuys, CA 91410-0219 ACT 91 NOTICE TAKE ACTION TO SAVE YOUR HOME FROM FORECLOSURE May 26, 1999 Sent by Certified Mail/Return Receipt Requested This Date Lynn R Hahn 431 Pawnee Dr Mechanicsburg, PA 17055-0000 Dear Lynn R Hahn: Countrywide Account # 6124753 Premises: 431 Pawnee Dr Mechanicsburg, PA 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 notification an adjunto es de suma importancia, pues afecta su derecho a continuer viviendo en su case. Si no comprende el contenido de esta notification obtenga una traduccion inmediatamente Ilamando a esta agencia (Pennsylvania Housing Finance Agency) sin cargos at numero mencionado aniba. Usted puede set elegible para un prestamo del programa Ifamado "Homeowner's Emergency Mortgage Assistance Program" el coal puede salvar su casa de fa perdida del derecho a redimir su hipoteca. ACT 91 NOTICE 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 AND HELP YOU MAKE FUTURE MORTGAGE PAYMENTS. You may be eligible for financial assistance that will prevent foreclosure 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 all of this Notice. It contains an explanation of your rights. Under the Act, you are entitled to a temporary stay of foreclosure on your mortgage for thirty-five (35) days from the date of this Notice. During that time you must arrange and attend a "face-to-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 must occur in the next thirty-rive (35) 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-five (35) days after the date of this meeting. The name, address and telephone number of our representative is: COUNTRYWIDE, 6400 Legacy Drive, Plano, TX 75024-3697 Telephone Number: 1.80069-4575, Extension 6135. The names and addresses of designated consumer credit counseling agencies are shown on the attached sheel. It is only necessary to schedule one face-to-face meeting. You should advise this lender immediately of your intentions. Your mortgage is in defauh 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 as of the date of this letter is $8,615,57 That sum includes the following: Total of monthly payments from 12/01/1998 to 05/31/1999 including all accrued late charges, if any: $7,381.32 Property inspections and NSF check charges, if any: $43.00 Other charges accrued, if any: ?VU'B?I LI $1,191,25 LESS: Suspense (unappred funds): X 1 X00 TOTAL AMOUNT OF DELINQUENCY: $8,615.57 Send Payments to: P.O. Box 10219 Van Nuys. CA 91410-0219 ACT 91 NOTICE TAKE ACTION TO SAVE YOUR HOME FROM FORECLOSURE May 26, 1999 Ann E Hahn 431 Pawnee Or Mechanicsburg, PA 17055-0000 Dear Ann E Hahn: Sent by Certified Mail/Retum Receipt Requested This Dale Countrywide Account # 6124753 Premises: 431 Pawnee Or Mechanicsburg, PA The Commonwealth of Pennsylvania's Homeovmer'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 notification an adjunto es de suma importancia, pues afecta su derecho a continuar viviendo en su casa. Si no comprende el contenido de esta notification obtenga una traduccion inmediatamente Ilamando a esta agencia (Pennsylvania Housing Finance Agency) sin cargos at numero mencionado arriba. Usted puede ser elegible para on prestamo del programa Ilamado "Homeowner's Emergency Mortgage Assistance Program" el coal puede salvar so casa de la perdida del derecho a redimir su hipoteca. ACT 91 NOTICE 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 AND HELP YOU MAKE FUTURE MORTGAGE PAYMENTS. You may be eligible for financial assistance that will prevent foreclosure 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 all of this Notice. It contains an explanation of your rights. Under the Act, you are entitled to a temporary stay of foreclosure on your mortgage for thirty-five (35) days from the date of this Notice. During that time you must arrange and attend a "face-to-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 must occur in the next thirty-five (35) 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-five (35) days after the date of this meeting. The name, address and telephone number of our representative is: COUNTRYWIDE, 6400 Legacy Drive, Plano, TX 75024-3697 Telephone Number: 1-800.6694575, Extension 6135. 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 default 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 as of the date of this letter is $8,615.57. That sum includes the following: Total of monthly payments from 12101/1998 to 05131/1999 including all accrued late charges, if any: $7,381.32 Properly inspections and NSF check charges, if any: $43.00 $1 191.25 Other charges accrued, if any: , $ 00 LESS: Suspense (unapplied funds): TOTAL AMOUNT OF DELINQUENCY: $8,615.57 , Please wme your loan number on all checks and correspondence PENN91 726197 ' EXHIBIT B Ann E Hahn R19d7r,1-7 .1...-._.... - .-., ?... Please be advised that the total amount is as of the date of this letter, and additional amounts may become due if your default persists. 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 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 postmarked, within thirty-five (35) days of your face-to-face meeting. 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. It is extremely important that your application is accurate 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 proceedings 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 2.101 North Front Street, Post Office Box 8029, Harrisburg, Pennsylvania 17105. Telephone No. (717) 780-3800 or 1.800-342-2397 (toll free number). Persons with impaired hearing can call 1.800-342.2397. In addition you may receive another notice from this lender under Act 6 of 1974. That notice is called "Notice of Intention to 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. Very truly yours, x4r4 By: Kathy Morris Loan Counselor 1-800-669-4575, Extension 6135 Attention: Kathy Morris Loan No.: 6124753 Sent by Regular Mail, Certificate of Mailing (PS Form 3877) If your loan was in default at the time that it was acquired by Countrywide, please be advised of the following: 1. Countrywide is a debt collector, we are attempting to collect a debt, and any information Countrywide obtains will be used for that purpose. 2. The amount currently owed to Countrywide is $8,615.57 (there may be other accrued interest, costs and expenses). Unless you, within thirty (30) days after receipt of this letter, dispute the validity of the debt owed or any portion of this debt, we will assume the amount to be valid. If you notify us in writing within this thirty (30) day time frame that you dispute the debt or any portion of the debt, we will obtain verification of the debt and mail it to you and, if you so request, provide you with the name and address of the original creditor if it is different from the current creditor. Please direct any written disputes to the following address: Countrywide Home Loans, Inc. Collections, MS SV-34 Attention: Research Counselor cvu'?f? P.O. Box 10221 EXH Van Nuys, CA 91410-0221 Pennsylvania Housing Finance Agency Homeowner's Emergency Mortgage Assistance Program Consumer Credit Counseling Agencies (Rev. 5/99) Lmming-Cliaton Counties Commission For Communic Action (STEP) 2138 Lincoln Street P. O. Box 1328 (S OrR) -058 Pa 1"703 326 FAX (570) 322.2197 CCCS of Narheastern PA wl Basin Street (570) mSPO^ 2 PA 17703 FA-'C (570) 323.6626 31 W. Market Strew, POB U27 Wilkes-Barre, PA 18702 (570) 821-0837 or (800) 922.9537 FAX (570) 821-1785 CLENTO- N COGN'1'C CCCS of Yorthenstern p.A 1631 S Atherton St Suite 100 State College, PA 16801 (814) 2384668 F-4.'( (814) 238.3669 COLL.MBL1 COLtiTY CCCS of' ortheastern Pennsvlvania 1400 Abiagtan Execrative Park Suite 1 Clarks Sumntitt P.4,18411 (570)587.9163 or (800) 922.9537 FAX (570) 587.913419135 Commission an Economics Opportunity of Luzerne County 163 Amber Lane Wilkes-Barre, P.% 18702 (570) 826-0510 or (800) 822-0359 F.AX (570) 829-1665-CALL BEFORE FAXLNG (570) 455-4994 FLAZELTON FAX (570) 455.5631-CALL BEFORE F.AXLNG (570) 8364090 TUNKFLANNOCK Booker T. Washington Center 1720 Holland Street Erie, Pa 16503 (814)453.5744 FAX (814) 453.5749 John F. Kennedy Center, Inc. 2021 East 20th Street Erie, P.A. 16510 (814) 898-0400 FAX (814) 898-1243 CCCS of Western Pennsylvania, Inc. 2000 Linglestown Road Harrisburg, P.A 17102 (717) 541.1757 Urban League of Metropolitan Harrisburg N. 6th Street Harrisburg, PA 17101 (717) 234-5925 FAX (717) 234-9459 Greater Erie Community Action Committee 18 West 9th Street Erie, PA 16501 (814) 4594581 FAX (814) 456-0161 Shenango Valley Urban League, Inc 601 Indiana Avenue Farrell. P.A. 16121 (412) 981.5310 CUrIBEPI A.IID COUNTY Financial Counseling Services of Franklin 31 West 3rd Street Waynesboro. PA 17268 (717)762.3285 YWCA of Carlisle 301 G Street Carlisle. PA 17013 (717) 243.3818 FAX (717) 731-9589 Community Acton Comm of the Capital Region 1514 Derry Street Harrisburg, P.A. 17104 (717) 232.9757 FA'( (717) 234-2227 Adams County Housing Authorirl 139-143 Carlisle St Gettysburg. PA 17325 (717) 334-1518 F.AIX(717)334-8325 EXHIBIT B PENNSYLVANIA BULLETIN, VOL 29, NO. 20, JUNE 5, 1999 ALL THAT CERTAIN piacm, parcel or trace of land situate, lying and 1,eing in Hampden Township, Cumberland CPun Ly. Pennsylvania shown as Lot No. 1, Part of Block "H" Indian Creel, (Plan Book 21, Page 63, Cumberland Cow1Ly Records) on survey prepared by Hartman Associates, Inc., Enaineors and Surveyors dated November 19, 1990, more fully described as follows, to wit: BEGINNING at a point aL a corner of Pawnee DrLva and Osage Wny, sold point being 10' from a concrete curl); thence al.ong Osage Way. South 82 degrees 59 minutes East, a dlat.ance of one hundred ninety-Lwo and fifty hundredths (192.50) feel to a point at corner of Osage Way and lands now or formerly or Realty Company of Pennsylvania; thence along Isod now or formerly of Realty Company of Pennsylvania, North 07 degrees 02 minutes Weal., a distance of one hundred fitly and zero hundredth (150.00) feet to a point at corner of lands now or formerly of Realty Company of Pennsylvania; thence continuing along lands of which this was once a part, known as Lot No. 3,.Nor Ll% 82 degrees 58 minutes East, a distance of one hundred ninety-two ai„I fifty hundredths (192.50) feet to a point at corner of Lot No. 3 and Pawnee Drive, sail point being 10' from a concrete curb; thence along Pawnee Drive South 07 degrees 02 minutes East, a distance of one hundred fifty and zero hundred Ohs (150.00) feet to the point and place of BEC'LNNTNG. BRINC THE SAME PREMISES which Paul F. Noland and Nadia N. Noland, husband and wife, by Deed dated January 17, 1991 and recorded January 22, 1991 in the Office of the Recorder of Deeds in and for Cumberland County in Dead Book 34-Y, Page 400, granted and conveyed unto Paul F. Noland and Nadis N. Noland, husband and wife. Lhe grantors herein- PREMISES: 431 PAWNEE DRIVE VERIFICATION BRANDON SCIUMBATO hereby states that he is VICE-PRESIDENT of COUNTRYWIDE ROME LOANS, INC. mortgage servicing agent for Plaintiff in this matter, that be/she is authorized to take this verification, and that the statements made in the foregoing Civil Action in Mortgage Foreclosure are true and correct to the best of his/her knowledge, information and belief. The undersigned understands that this statement is made subject to the penalties of 18 Pa. C.B. Sec. 4904 relating to unsworn falsification to authorities. BRANDON SCIUMBATO. VICE PRESIDENT DATE: -7- Z2"q9 S. T ? u. n 2 e cc ? a ?"-Sc1 fat - _ti J? V Qj Y- } v OW0ttt4ib M U 015pIUMO zl'WO?.Iti,+,Wnmyy w1V?v cGl[o ? '1v93131v1591Y SHERIFF'S RETURN - REGULAR CASE NO: 1999-04559 P COMMONWEALTH OF PENNSYLVANIA: COUNTY OF CUMBERLAND COUNTRYWIDE HOME LOANS ET AL VS. HAHN LYNN R 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 HAHN LYNN R the defendant, at 14:39 HOURS, on the 30th day of July 1999 at 431 PAWNEE DRIVE MECHANICSBURG, PA 17055 CUMBERLAND County, Pennsylvania, by handing to LYNN R. HAHN 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 answer Docketing 18.00 Service 5.58 7?J Affidavit .00 Surcharge 8.00 omas ine, eri $31.be 8%02 1999 PHELAN by 1 epu y e i Sworn and subscribed to before me this d oC day of al 19 nfq_ A.D. rotnonot-a-ry SHERIFF'S RETURN - REGULAR CASE NO: 1999-04559 P COMMONWEALTH OF PENNSYLVANIA: COUNTY OF CUMBERLAND COUNTRYWIDE HOME LOANS ET AL VS. HAHN LYNN R 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 HAHN ANN E the defendant, at 14:39 HOURS, on the 30th day of July 1999 at 431 PAWNEE DRIVE MECHANICSBURG, PA 17055 CUMBERLAND County, Pennsylvania, by handing to LYNN R. HAHN 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: Docketing 6.00 So answers: Service Affidavit .00 .00 Surcharge 8.00 omas ine, erirr $J.4 . u u FEDERPQAN & 08/02/1999 PHELAN by epu 5 e i Sworn and subscribed to before me this day of 19?? A.D. FEDERMAN AND PHELAN By: FRANK FEDERMAN Identification No. 12248 Two Penn Center Plaza - Suite 900 Philadelphia, PA 19102 (215) 563-7000 COUNTRYWIDE HOME LOANS, F/K/A COUNTRYWIDE FUNDING CORPORATION 6400 LEGACY DRIVE PLANO, TX 75024 Vs. Attorney for Plaintiff CUMBERLAND COUNTY COURT OF COMMON PLEAS . CIVIL DIVISION LYNN R. HAHN ANN E. HAHN 431 PAWNEE DRIVE MECHANICSBURG, PA 17055 NO. 99-4559 CIVIL PRAECIPE FOR JUDGMENT FOR FAILURE TO ANSWER AND ASSESSMENT OF DAMAGES TO THE PROTHONOTARY: Kindly enter judgment in favor of the Plaintiff and against LYNN R. HAHN AND ANN E. HAHN, Defendant(s) for failure to file an Answer to Plaintiff's Complaint within 20 days from service thereof and for Foreclosure and Sale of the mortgaged premises, and assess Plaintiff's damages as follows: As set forth in Complaint Interest - 7/1/99 TO 9/7/99 TOTAL $186,087.03 $ 2,223.87 $188,310.90 I hereby certify that (1) the addresses of the Plaintiff and Defendant(s) are as shown above, and (2) that notice has been given in accordance with Rule 237.1, copy attached. DAMAGES A HEREBY ASSESSED AS INDI DATE FRANK FEDER , ESQUIRE Attorney for Plaintiff : C ?- rp C\j G J ?? U FEDERMAN AND PHELAN Frank Federman, Esquire Identification No. 12248 Two Penn Center Plaza Suite 900 Philadelphia, PA 19102-1799 (215) 563-7000 ATTORNEY FOR PLAINTIFF COUNTRYWIDE HOME LOANS, F/K/A COURT OF COMMON PLEAS COUNTRYWIDE FUNDING CORPORATION CIVIL DIVISION Plaintiff LYNN R. HAHN ANN E. HAHN Defendant(s) CUMBERLAND COUNTY NO. 99-4559-CIVIL VS. TO: ANN E. HAHN 431 PAWNEE DRIVE MECHANICSBURG, PA 17055 DATE OF NOTICE: AUGUST 20, 1999 THIS FIRM IS A DEBT COLLECTOR ATTEMPTING TO COLLECT A DEBT. ANY INFORMATION WE OBTAIN WILL BE USED FOR THAT PURPOSE. IF YOU HAVE PREVIOUSLY RECEIVED A DISCHARGE IN BANKRUPTCY, THIS CORRESPONDENCE IS NOT AND SHOULD NOT BE CONSTRUED TO BE AN ATTEMPT TO COLLECT A DEBT, BUT ONLY ENFORCEMENT OF A LIEN AGAINST PROPERTY. IMPORTANT NOTICE You are in default because you have failed to enter a written appearance personally or by attorney and file in writing with the court your defenses or objections to the claims set forth against you. Unless you act within ten (10) days from the date of this notice, a Judgment may be entered against you without a hearing and you may lose your property or other important rights. You should take this notice to a lawyer at once. If you do not have a lawyer or cannot afford one, go to or telephone the following office to find out where you can get legal help: CUMBERLAND COUNTY BAR ASSOCIATION 2 LIBERTY AVENUE CARLISLE, PA 17013 (717) 249-3166 Frank Federman, Esquire Attorney for Plaintiff FEDERMAN AND PHELAN Frank Federman, Esquire Identification No. 12248 Two Penn Center Plaza Suite 900 Philadelphia, PA 19102-1799 (215) 563-7000 ATTORNEY FOR PLAINTIFF COUNTRYWIDE HOME LOANS, F/K/A COURT OF COMMON PLEAS COUNTRYWIDE FUNDING CORPORATION . CIVIL DIVISION Plaintiff VS. . CUMBERLAND COUNTY . NO. 99-4559-CIVIL LYNN R. MAHN ANN E. HAHN Defendant(s) T0: LYNN R. HAHN 431 PAWNEE DRIVE MECHANICSBURG, PA 17055 DATE OF NOTICE: AUGUST 20, 1999 THIS FIRM IS A DEBT COLLECTOR ATTEMPTING TO COLLECT A DEBT. ANY INFORMATION WE OBTAIN WILL BE USED FOR THAT PURPOSE. IF YOU HAVE PREVIOUSLY RECEIVED A DISCHARGE IN BANKRUPTCY, THIS CORRESPONDENCE IS NOT AND SHOULD NOT BE CONSTRUED TO BE AN ATTEMPT TO COLLECT A DEBT, BUT ONLY ENFORCEMENT OF A LIEN AGAINST PROPERTY. IMPORTANT NOTICE You are in default because you have failed to enter a written appearance personally or by attorney and file in writing with the court your defenses or objections to the claims set forth against you. Unless you act within ten (10) days from the date of this notice, a Judgment may be entered against you without a hearing and you may lose your property or other important rights. You should take this notice to a lawyer at once. If you do not have a lawyer or cannot afford one, go to or telephone the following office to find out where you can get legal help: CUMBERLAND COUNTY 2 LIBERTY AVENUE CARLISLE, PA 17013 (717) 249-3166 BAR ASSOCIATION Frank Federman, Esquire Attorney for Plaintiff (Rule of Civil Procedure No. 236) - Revised IN THE COURT OF COMMON PLEAS OF CUMBERLAND COUNTY, PENNSYLVANIA CIVIL ACTION - LAW COUNTRYWIDE HOME LOANS, F/K/A COUNTRYWIDE FUNDING CORPORATION ) NO. 99-4559 CIVIL Plaintiff VS. LYNN R. HAHN ) ANN E. HAHN ) Defendants Notice is given that a Judgment in the above-captioned matter has been entered against you on _SEPTEMBER O 1999. By: PUTY c' If you have any questions concerning this matter, please contact: R ES UIRE 4A ney y for Party Filing Two Penn Ce ter Plaza, Suite 900 Philadelphia, PA 19102 (215) 563-7000 **THIS FIRM IS A DEBT COLLECTOR ATTEMPTING TO COLLECT A DEBT AND ANY INFORMATION OBTAINED WILL BE USED FOR THAT PURPOSE. IF YOU HAVE PREVIOUSLY RECEIVED A DISCHARGE IN BANKRUPTCY, THIS IS NOT AND SHOULD NOT BE CONSTRUED TO BE AN ATTEMPT TO COLLECT A DEBT, BUT ONLY ENFORCEMENT OF A LIEN AGAINST PROPERTY.** FEDERMAN and PHELAN Bye FRANK FEDERMAN Identification No. 12248 Suite 900 Two Penn Center Plaza Philadelphia, PA 19102 (215) 563-7000 COUNTRYWIDE HOME LOANS, F/K/A COUNTRYWIDE FUNDING CORPORATION Va. LYNN R. HAHN ANN E. HAHN ATTORNEY FOR PLAINTIFF CUMBERLAND COUNTY COURT OF COMMON PLEAS CIVIL DIVISION . NO. 99-4559 CIVIL VERIFICATION OF NON-MILITARY SERVICE FRANK FEDERMAN, ESQUIRE, hereby verifies that he is attorney for the Plaintiff in the above-captioned matter, and that on information and belief, he has knowledge of the following facts, to wit: (a) that the defendant(s) is/are not in the Military or Naval Service of the United States or its Allies, or otherwise within the provisions of the Soldiers, and Sailors, Civil Relief Act of Congress of 1940, as amended. and residesbat 431tPAeWNEE DRIVE, M CH F IICSBURG,rPA 18 years 17055. of age fendant and residescat 431tPAeWNEE DRIVAE,,NMEE. HAHN is CHANICSBURG a PA 8170years 55. of age, This statement is made subject to the penalties of 18 Pa. C.S. Section 4904 relating to unsworn falsification to authorities. F K FEDERM? ESQUIRE Attorney for Plaintiff ? C ? ? ti _, ?, ,.. c,; --- 3 _ ?=- - ? ? -':; _„ "`' ? - CA t.:: (Y, v: ?' r.. ''j ? V7 `_ V Gi J V) ? ? ?? ??? `? PRAECIPE FOR WRIT OF EXECUTION - (MORTGAGE FORECLOSURE) P.R.C.P.3180-3183 COUNTRYWIDE HOME LOANS, F/K/A COUNTRYWIDE FUNDING CORPORATION Plaintiff Vs. LYNN R. HAHN ANN E. HAHN Defendant(s) COURT OF COMMON PLEAS CUMBERLAND COUNTY, PA NO. 99-4559 CIVIL PRAECQ•E FOR WRIT OF E%ECR1 ON (MORTGAGE FORWLOWM TO THE DIRECTOR OF THE OFFICE OF THE PROTHONOTARY: Issue writ of execution in the above matter: / Amount Due $188.310.90 V Interest from 9/7/99 TO $ 2.879.28 and Costs 12/8/99 (PER DIEM - $30.96) $191.190.18 Total JF:M FEDERMAN , ESQUIRE NN CENTS PLAZA 900 PHILADELPHIA, PA 19102 Attorney for Plaintiff Note: Please attach description of property. a co 01 ri N F H UV rn Ln Ln IT a% m z° o? z 0a 0 OV 0 o? z O H 0 O 00 U z H A 0 °u ? aaa R 04 °a da a 0 u O W ? O FkS wC a v v ti w Ln Ln 0 r o, P N U ?i m v v b d d A I m H N ro a $4 m m wu v i >t zr-A& IIz9CR,IaTz0N A"' VA" CoavArd vise, Aarool ar t=act Of land ¦ltuaea, ly"9 and 2e1n9 Sh naapsan Tra+hehiD. C1af9erlans Cam,tY, DaynryL?mlo shown an 'At Po, 11 Part or tBlock NV% Indian CTTeek (PlaA 1-7ok 71, Page 0, Cusbarl?es obunWRR?tttiyyyyi AAeerds) an survey proParac Dy amrs m 19, 19§, flly ar?sOAnsoae bias, QIna aaifl.inae reand wa toyars dated Hmrssber Way. Raa1lACISM at a Dolnt at a wernor of Pawnee Drive and slace ge ft. South of deg alnp as siANtea mast se distance at ans AID;* Meiaroa nlWyby?e- and tiRY alulalreatbo 1192, 50) feet to a Paint. AIL aorn?r as oepe y and Linde now or lomovw]y at sanity ctD"Tr e,: ePMSeylre al themos alont lend now ar ferAarly of Realty C'wpany ar MP?eDa , North et.' de9reee 93 sinWae Wont, 9 d1AMI ea at Darner tir 1"40 now AN,formern ley ortRealty I any of a potne eet Panneyivanl.s7 thence ca?ntAnV °which of nu bee ones a Dart. kenwn as Wes We. aIaworrth lad AAor which Wthin Raet. A rl.tanee of one Dundrad ninuty-ewe AM fifty nundrZedthd said point losiao I*, 9mea aunarLelto eura) tAose* ala?gD Drive, 1 Drive t9et2 97 NM9 Ps.+nr flit end : yard p Da? 07 Alwtas mast • ssoooD ON an. I'votudzed uce: of Y wdfeatR9 (15e.00) ras laei co trio point and plleas of BUINNrNQ. •. 118706 ?te aasS PUMM.92 which Paul P. Noland and Hadia.w. TIGI A . him nd and, wife, byp bead asesd Deoelabur ;1, 1991 ¦nd raeerdad b.seedss lv, 39P.L LW the Ra tusdar or Aeeda office In eau for cr,.heslend aamcy, T"INFlraula, in Dow soak 79a1., Pape ;? VV=RtW aid oan94yed Unto Z nA R_ RAM and Am A. Huhn. husband eau 503 to 999 ; Ul lJ Id FEDERMAN and PHELAN By: FRANK FEDERMAN Identification No. 12248 Suite 900 Two Penn Center Plaza Philadelphia, PA 19102 (215) 563-7000 COUNTRYWIDE HOME LOANS, F/K/A COUNTRYWIDE FUNDING CORPORATION Vs. LYNN R. HAHN ANN E. HAHN CERTIFICATION ATTORNEY FOR PLAINTIFF CUMBERLAND COUNTY COURT OF COMMON PLEAS CIVIL DIVISION . NO. 99-4559 CIVIL FRANK FEDERMAN, ESQUIRE, hereby verifies that he is attorney for the Plaintiff in the above-captioned matter, and that the premises are not subject to the provisions of Act 91 because it is: ( ) an FHA mortgage ( ) non-owner occupied ( ) vacant (XX) Act 91 procedures have been fulfilled This certification is made subject to the penalties of 18 Pa. C.S. Section 4904 relating to unsworn falsification to authorities. F K FEDE ESQUIRE Attorney for Plaintiff ti ?, - . ;- ? ,-. ?,?- ?, ??- - ?? ? -? - « ` ? ? = ? ; , ?.: ., ` - = :? . ? ; -, ?_ ?_. , - ?? : V: : .? t•_ ' ? ? ?' U Imo, COUNTRYWIDE HOME LOANS, F/K/A COUNTRYWIDE FUNDING CORPORATION CUMBERLAND COUNTY COURT OF COMMON PLEAS . CIVIL DIVISION VS. LYNN R. HAHN ANN E. HAHN . NO. 99-4559 CIVIL AFFIDAVIT PURSUANT TO RULE 3129 (Affidavit No. 1) Plaintiff in the above action, by its attorney, FRANK FORMAN, ESQ., sets forth as of the date the Praecipe for the Writ of Execution was filed the following information concerning the real property located at 431 PAWNEE DRIVE. MECHANICSBURG PA 17055 1. Name and address of owner(s) or reputed Owner(s): NAME LAST KNOWN ADDRESS (if address cannot be reasonably ascertained, please so indicate) LYNN R. HAHN 431 PAWNEE DRIVE MECHANICSBURG, PA 17055 ANN E. HAHN 431 PAWNEE DRIVE MECHANICSBURG, PA 17055 2. Name and address of Defendant(s) in the judgment: NAME LAST KNOWN ADDRESS (if address cannot be reasonably ascertained, please so indicate) SAME AS ABOVE 3. Name and address of every judgment creditor whose judgment is a record lien on the real property to be sold: NAME LAST KNOWN ADDRESS (if address cannot be reasonably ascertained, please so indicate) NONE 4. Name and address of the last recorded holder of every mortgage of record: NAME LAST KNOWN ADDRESS (if address cannot be reasonably ascertained, please so indicate) COUNTRYWIDE HOME LOANS. INC 155 N. LAKE AVENUE PASADENA, CA 91109 J 5. Name and address of every other person who has any record lien on the property: NAME LAST KNOWN ADDRESS (if address cannot be reasonably ascertained, please so indicate) NONE 6. Name and address of every c_her person who has any record interest in the property and whose interest may be affected by the sale: NAME LAST KNOWN ADDRESS (if address cannot be reasonably ascertained, please so indicate) NONE 7. Name and address of every other person whom the plaintiff has knowledge who has any interest in the property which may be affected by the sale: NAME TENANT/OCCUPANT DOMESTIC RELATIONS OF CUMBERLAND COUNTY LAST KNOWN ADDRESS (if address cannot be reasonably ascertained, please so indicate) 431 PAWNEE DRIVE MECHANICSBURG, PA 17055 13 NORTH HANOVER STREET CARLISLE, PA 17013 I verify that the statements made in this affidavit are true and correct to the best of my personal knowledge or information and belief. I understand that false statements herein are made subject to the penalties of 18 Pa. C.S. Sec. 4904 relating to unsworn falsification to authorities. September 7, 1999 i DATE FPNK FEDER ESQUIRE Attorney f Plaintiff GJ ?? U I COUNTRYWIDE HOME LOANS, F/K/A COUNTRYWIDE FUNDING CORPORATION CUMBERLAND COUNTY COURT OF COMMON PLEAS VS. CIVIL DIVISION LYNN R. HAHN ANN E. HAHN NO. 99-4559 CIVIL NOTICE OF SHERIFF'S SALE OF REAL PROPERTY September 7, 1999 TO: LYNN R. HAHN ANN E. HAHN 431 PAWNEE DRIVE MECHANICSBURG, PA 17055 **THIS FIRM IS A DEBT COLLECTOR ATTEMPTING TO COLLECT A DEBT AND ANY INFORMATION OBTAINED WILL BE USED FOR THAT PURPOSE. IF YOU HAVE PREVIOUSLY RECEIVED A DISCHARGE IN BANKRUPTCY, THIS IS NOT AND SHOULD NOT BE CONSTRUED TO BE AN ATTEMPT TO COLLECT A DEBT, BUT ONLY ENFORCEMENT OF A LIEN AGAINST PROPERTY.** Your house (real estate) at 431 PAWNEE DRIVE. MECHANICSBURG PA 17055, is scheduled to be sold at the Sheriff's Sale on DECEMBER 8. 1999 at 10:00 a.m. in the Cumberland County Courthouse, South Hanover Street, Carlisle, PA 17013, to enforce the court judgment of $188,310.90 obtained by COUNTRYWIDE HOME LOANS, F/K/A COUNTRYWIDE FUNDING CORPORATION (the mortgagee) against you. If the sale is postponed, the property will be relisted for the MARCH 1, 2000 Sheriff's Sale. NOTICE OF OWNER'S RIGHTS YOU MAY BE ABLE TO PREVENT THIS SHERIFF'S SALE To prevent this Sheriff's Sale, you must take immediate action: 1. The sale will be cancelled if you pay to the mortgagee the back payments, late charges, costs and reasonable attorney's fees due. To find out how much you must pay, you may call: (215) 563-7000. 2. You may be able to stop the sale by filing a petition asking the Court to strike or open the judgment, if the judgment was improperly entered. You may also ask the Court to postpone the sale for good cause. 3. You may also be able to stop the sale through other legal proceedings. t You may need an attorney to assert your rights. The sooner you contact one, the more chance you will have of stopping the sale. (See notice on page two on how to obtain an attorney.) YOU MAY STILL BE ABLE TO SAVE YOUR PROPERTY AND YOU HAVE OTHER RIGHTS EVEN IF THE SHERIFF'S SALE DOES TAKE PLACE 1. If the Sheriff's Sale is not stopped, your property will be sold to the highest bidder. You may find out the price bid by calling (215) 563-7000. 2. You may be able to petition the Court to set aside the sale if the bid price was grossly inadequate compared to the value of your property. 3. The sale will go through only if the buyer pays the Sheriff the full amount due in the sale. To find out if this has happened, you may call (717) 240-6390. 4. If the amount due from the Buyer is not paid to the Sheriff, you will remain the owner of the property as if the sale never happened. 5. You have the right to remain in the property until the full amount due is paid to the Sheriff and the Sheriff gives a deed to the buyer. At that time, the buyer may bring legal proceedings to evict you. 6. You may be entitled to a share of the money which was paid for your house. A proposed schedule of distribution of the money bid for your house will be prepared by the Sheriff not later than thirty (30) days after the sale. The schedule shall be kept on file with the Sheriff and will be made available for inspection in his office. The schedule will state who will be receiving that money. The money will be paid out in accordance with this schedule unless exceptions (reasons why the proposed distribution is wrong) are filed with the Sheriff within ten (10) days after the filing of the proposed schedule. 7. You may also have other rights and defenses, or ways of getting your home back, if you act immediately after the sale. YOU SHOULD TAKE THIS PAPER TO YOUR LAWYER AT ONCE. IF YOU DO NOT HAVE A LAWYER OR CANNOT AFFORD ONE, GO TO OR TELEPHONE THE OFFICE LISTED BELOW TO FIND OUT WHERE YOU CAN GET LEGAL HELP. CUMBERLAND COUNTY ATORNEY REFERRAL CUMBERLAND COUNTY BAR ASOCIATION 2 LIBERTY AVENUE CUMBERLAND COUNTY COURTHOUSE CARLISLE, PA 17013 (717) 249-3166 (800) 990-9108 1:rat. I)!$CMLXPTZOIN i'-*. wAhP cmv=w etace, Boreal or trace or land ¦ltuaea, lying and].Doino. ll,"AWFort doal?6khIp. Ctsberland County, ba,,nrylvonla al. PROS 0. Cuaberleaa ObUn RecoOUft rds) ?nn oun'rva1' Crook (flag parad Xly Hartman, Aaaaolabse, 2nc., m as, 1990, soma fully desulmd as foland low, toyvit: doted He raswr V. ag;11°DC2n0 at a point at a ournar or kennee Pslve and cuapa «e, soLLtA itndegrees so aiau6esa most, aediissHecenai on , htmirruaaQ° ynlais9am :Arty AW,l11 5 (292.50) Role to a palnk all comer or am"* y and lands env or los+a:ly ar Realty coup.ar e,: p'ermnYlvan#%I Lhaaoe ales' land 0w or laraerly at aaalty fbrpany of lawnaylnnim. aerta $V dogWwoa ba aimrAm Pont. a dieta:da of *no hundred ritzy and zero aRnaradtn (150.001 last to a polne at oetner or laada aOn am- rerorriy or saalty Company of Ounce 4 Part?rkaarn°g0 Lea 00. 9, alrez'T la dogroee which aiiutaa salt, a dietaaee or and bundeaa( n4,et2-ono and r1Ry nWWrrdMs to a t 120= DEMM, laid-Point be a aO-rre/aa coadfaate cu")NeD Bas al" pa Drive. DoivV aauc 67 course@ 07 aiaukam Rant, a alltanee ad donee I'mor irac Arty and »re buudxv4ths (M-001 fast to the point and pine/ or IMUNTUa. bUNG Va aaaa FRENltta Alan p?ul P. Poland and Nadia .R. Noland, honband and, wife, by Aamd alit" 0aoaabev Z7, 1991 and recerdsd brlgbea 17, Lop.L id the aacoroor or Asada Offlem in ads yes e.,nborlow mammy, fnOMylvania, in Dana Book )l-L, pope 11, granted and conveyed lints Ipnn k- N.hn and inn A. Hain: hamband arm viva, COrI 503 00 8.49 fi- w U; 111" o? U IN THE COURT OF COMMON PLEAS OF CUMBERLAND COUNTY, PENNSYLVANIA COUNTRYWIDE HOME LOANS, F/K/A COUNTRYWIDE FUNDING CORPORATION Plaintiff VS. LYNN R. HAHN ANN E. HAHN Defendants CIVIL DIVISION No. 99-4559 CIVIL AFFIDAVIT OF SERVICE PURSUANT TO RULE 3129 COMMONWEALTH OF PENNSYLVANIA CUMBERLAND COUNTY SS: I, FRANK FEDERMAN, ESQ., attorney for COUNTRYWIDE HOME LOANS, F/K/A COUNTRYWIDE FUNDING CORPORATION , hereby verify that on SEPTEMBER 9, 1999, true and correct copies of the Notice of Sheriff's Sale were served by certificate of mailing to the recorded lienholder(s), and any known interested party, see Exhibit "A" attached hereto, and the Notice of Sale was sent to defendant(s) on SEPTEMBER 9, 1999 by first class mail and certified mail return receipt requested, see Exhibit. "B" attached hereto. ?ilavl.L ,q w FRANK FE RMAN, ESQU E Attorney for Plaintiff Date: November 8. 1999 Ire"s8€ \ CA t`f ? nS ? '" Q5n CU e ?g ?. ?? ? . ? N b 5O€G LL RE a` ?a O N E $ S5 w m ?yy?w op _n C l 6LL ?W ?n 989 ?$ a 3 Ns SE e$ ?S q 5 v? 32 m >° gL S5e ?° ¢ g €' E _?? IV ?n?E?U }' Bn S. ? ? $ d ?E p O J ED W ? c S ]? g di o E 2 y a a M d `w g N E C s w a 0 + N o L r_1 W ? (y p fFq a i ? 04 a o e E0 Q p a ? Z W Em y y LM cn z> {y? * * LL ® Z it * 5 a N 49 i*i E > a=I yCy it 41 ii i a N y Q .I N M < U) t0 I? CO 0) O ^ ^ .?- r J C a c 6 m `o Y C d 3 a E 0 V I LL m 2 °u co 0 a Id lloW algelunooob 1oj TIFF Ln N N ru .n a- a NStAf.E RELURtI g?ppN/i lO VMOM pgtE ANp nESiRi RECEIPT ADOPSi50F pELrvERV ? pEUVE SERVICE CEROREOFEE-RE TURN REC&ITT TOTAL RQStAGE AIRS FEES SENT TO: Nor FOR INiERNAnowLw AA!. E. eAtIN 43i P"INEa.9RIVE :hE61tANIC;BURG, PA 17055 PS FORM 3800 US Postal Service POSTMARff OR DATE, c : ?i 2 .. LL C n 0 a o: W CU N W U a D. Receipt for Certified Mail g S 7 N N r_. ir o- a POSTAGE RETURN TO V/MM OPTS ANp RESTRX RECEIPT E. Env CEti'.E; SERVICE CERTIFIED FEE•RENRN RECEIPT TOTAL POSTAGE AND FEES SENT TOE Nor FOR.WWNMAn0NALM LM R. HAHN 431 PAWNEE• DRIVE KEInANICSHURG, PA 17055 /'•KN I.__ u PS FORM 3800 US Postal Service Receipt for Certified Mail a? Uri N L_ CD W O i-J 4- J? STATE OF PENNSYLVANIA, COUNTY OF CUMBERLAND SS. Robert P Ziegler h - ------------------------------- ------------- Recorder of Deeds in and for said County and State do hereby certify that the Sheriff's Deed in which ----- --------------------- E!Kqra!! Natl Mtg Assoc___-______-_--______________________ is the grantee the same having been sold to said grantee on the ------ th________ _______________ _ __ day of ___-____ December - --------------------------- A. D., 19__99 ___, under and by virtue of a writ______________ Execution ------------------------------------------------ issued on the 8th - -- -- -- ------- September day of --------- Civil Tenn, 19--i2-- Number ----- at the suit of --- Countrywide Home Leand f/k/a Countrywide Funding Corp ----- ------------------------------------------------- Lynn R hahn & Ann E ------------------- against--------------------------------- duly recorded in Sheriffs Deed Book No.Page__1106 IN TESTIMONY WHEREOF, I have hereunto set my hand and seal of said office this ___-day of ---- A. D., i? 2 to ?,Z Recorder o feeds Ml i?imtdlwi?itryts&ypwirIMk`SU A. D., out of the Court of Comman Pleas of said County as of Countrywide Home Loans, F/K/A In the Court of Common Pleas of Countrywide Funding Corporation Cumberland County, Pennsylvania -vs- No. 99-4559 Civil Term Lynn R. Hahn and Ann E. Hahn Dawn L. Kell, Deputy Sheriff, who being duly sworn according to law, says on September 28, 1999 at 7:15 o'clock P.M. EDST. She posted a copy of Real Estate Writ Notice Poster and Description in the above entitled action upon the property of Lynn R. Hahn and Ann E. Hahn located at 431 Pawnee Drive, Mechanicsburg, Cumberland County, Pennsylvania, according to law. Dawn L. Kell, Deputy, Sheriff, who being duly sworn according to law, says on September 28, 1999 at 7:15 o'clock P.M. EDST, she served a true copy of Real Estate Writ Notice Poster and Description in the above entitled action upon one of the within named defendants to wit: Lynn R. Hahn, by making known unto Lynn Hahn at 431 Pawnee Drive, Mechanicsburg, Cumberland County, Pennsylvania, its contents and at the same time handing to him personally the said true and attested copies of the same. Dawn L. Kell, Deputy Sheriff, who being duly sworn according to law, says on September 28, 1999 at 7:15 o'clock P.M. EDST, she served a true copy of Real Estate Writ Notice Poster and Description in the above entitled action upon one of the wihtin named defendants to wit: Ann E. Hahn by making known unto Lynn Hahn Husband at 431 Pawnee Drive, Mechanicsburg, Cumberland County, Pennsylvania, its contents and at the same time handing to him personally the said true and attested copies of the same. R. Thomas Kline, Sheriff, who being duly sworn according to law, says he served the above Real Estate Writ Notice Poster and Description in the following manner: The Sheriff mailed a notice of the pendency of the action to one of the wihtin named defendants to wit: Lynn R. Hahn to his last known address 431 Pawnee Drive, Mechanicsburg, Pennsylvania. This letter was mailed under the date of September 29, 1999 and never returned to the Sheriff's Office. R. Thomas Kline, Sheriff, who being duly sworn according to law, says he served the above Real Estate Writ Notice Poster and Description in the following manner: The Sheriff mailed a notice of the pendency of the action by First Class Mail to one of the within named defendants to wit: Ann E. Hahn to her last known address 431 Pawnee Drive, Mechanicsburg, Pennsylvania. This letter was mailed under the date of September 29, 1999 and never returned to the Sheriff's Office. R. Thomas Kline, Sheriff, who being duly sworn according to law, says after due and legal notice had been given according to law, exposed the within described premises at public venue or outcry at Court House, Carlisle Cumberland County, Pennsylvania on December 8, 1999 at 10:00 o'clock A.M. EDST, and sold the same for the sum of $ 1.00 to Attorney Dale Shughart for Federal National Mortgage Association. It being the highest bid and best price received for the same Federal National Mortgage Association being the buyer in this execution paid to Sheriff R. Thomas Kline the sum of $ 962.35 it being Sheriffs costs. Sheriffs Costs: Docketing 30.00 Poundage 18.87 Posting Bills 15.00 Advertising 15.00 Acknowledging Deed 30.00 Auctioneer 10.00 Law Library .50 County 1.00 Mileage 8.06 Certified Mail .79 Levy 15.00 Surcharge 24.00 Law Journal 275.00 Patriot News 444.00 Share of Bills 23.63 Distribution of Proceeds 25.00 Sheriff's Deed 26.50 $ 962.35 Pd by Atty 01-06-00 Sworn and Subscribed To Before Me This a 9 a` Day of 1J ? -y So answee?l? 2000, A.1 4P ra!i_urep .A r? P t notary R. Thomas Kline, Sheriff By Real Estate Deputy 0A 1, 5 ct.17YOt PROOF OF PUBLICATION OF NOTICE IN CUMBERLAND LAW JOURNAL (Under Act No. 587, approved May 16, 1929), P. L.1784 STATE OF PENNSYLVANIA : COUNTY OF CUMBERLAND : SS. Roger M. Morgenthal, Esquire, Editor of the Cumberland Law Journal, of the County and State aforesaid, being duly swom, according to law, deposes and says that the Cumberland Law Journal, a legal periodical published in the Borough of Carlisle in the County and State aforesaid, was established January 2, 1952, and designated by the local courts as the official legal periodical for the publication of all legal notices, and has, since January 2, 1952, been regularly issued weekly in the said County, and that the printed notice or publication attached hereto is exactly the same as was printed in the regular editions and issues of the said Cumberland Law Journal on the following dates, Affiant further deposes that he is authorized to verify this statement by the Cumberland Law Journal, a legal periodical of general circulation, and that he is not interested in the subject matter of the aforesaid notice or advertisement, and that all allegations in the foregoing statements as to time, place and character of publication are true. REAL ESTATE SALE NO. 51 Writ No. 99-4559 Civil Countrywide Home Loans, F/K/A Countywide Funding Corporation VS. Lyrm R. Hahn and Ann E. Hahn Ally.: Frank Federman ALL THAT CERTAIN piece, parcel or tract of land situate, lying and being in Hampden Township, Cum. berland County. Pennsylvania shown as Lot No. 1, Part of Block "H" Indian Creek (Plan Book 21, Page 63. Cum- berland County Records) on survey prepared by Hartman Associates, Inc.. Engineers and Surveyors dated No. vember 19, 1990, more fully described as follows, to wit: BEGINNING at a point at a corner of Pawnee Drive and Osage Way, said Point being 10' from a concrete curb: Roger M. Morgenthal, Editor SWORN TO AND SUBSCRIBED before me this 5 dayof_NOVEMBER, 1999 NOTARIAL SEAL LOIS E. SNYDER, Nofory Pubk CarlWo Eoro, Cumbodand County, PA My Co raiWon Eapir" Morch S, 2001 (Under Act No. 587, approved May 16, 1929), P. L.1784 STATE OF PENNSYLVANIA : SS. COUNTY OF CUMBERLAND : Roger M. Morgenthal, Esquire, Editor of the Cumberland Law Journal, of the County and State aforesaid, being duly sworn, according to law, deposes and says that the Cumberland Law Journal, a legal periodical published in the Borough of Carlisle in the County and State aforesaid, was established January 2, 1952, and designated by the local courts as the official legal periodical for the publication of all legal notices, and has, since January 2, 1952, been regularly issued weekly in the said County, and that the printed notice or publication attached hereto is exactly the same as was printed in the regular editions and issues of the said Cumberland Law Journal on the following dates, 1999 Affdant further deposes that he is authorized to verify this statement by the Cumberland Law Journal, a legal periodical of general circulation, and that he is not interested in the subject matter of the aforesaid notice or advertisement, and that all allegations in the foregoing statements as to time, place and character of publication are true. REAL ESTATE BALE NO. 51 writ No. 99-4559 Civil Coun'vywlde Home Loans. F/K/A Countrywide Funding Corporation VS. Lynn R. Hahn and Ann E. Hahn Atty.: Frank Federman ALL THAT CERTAIN piece, parcel or tract of land situate, lying and being in Hampden Township, Cum- berland County, Pennsylvania shown as Lot No. 1. Part of Block 'H' Indian Creek (Plan Book 21, Page 83, Cum- berland County Records) on survey prepared by Hartman Associates, Inc.. Engineers and Surveyors dated No- vember 19, 1990, more fullydescribed as follows, to wit: BEGINNING at a point at a corner of Pawnee Drive and Osage Way, said point being 10' Gom a concrete curb; thence along Osage Way, South 32 degrees 59 minutes East, a distance of one hundred ninety-two and fifty hundredths (192.50) feet to a point at corner of Osage Way and lands now or formerly of Realty Company of Pennsylvania: thence along land now or formerly of Realty Company of Pennsylvania, North 07 degrees 02 minutes West, a distance ofone hun- dred fifty and zero hundredth (150.00) feet to a point at corner of lands now or formerly of Realty Com. pany of Pennsylvania; thence con. tnuing along lands of which this was once a part, known as Lot No. 3, North 82 degrees 58 minutes East, a distance of one hundred ninety-two and ally hundredths (192.50) feel to a point at corner of Lot No. 3 and Pawnee Drive, said point being 10' from a concrete curb; thence along Pawnee Drive South 07 degrees 02 minutes East. a distance of one hun- dred fifty and zero hundredths (150.00) feet to the plant and place of BEGINNING. BEING THE SAME PREMISES which Paul F. Noland and Nadia N. Noland, husband and wife, by Deed dated January 17, 1991 and record. ed January 22, 1991 In the Office of the Recorder of Deeds In and for Cumberland County In Deed Book 34-Y. Page 400, granted and con- veyed unto Paul F. Noland and Nadia N. Noland, husband and wife, the grantors herein. PREMISES: 431 PAWNEE DRIVE. Roger M. Morgenthal, Editor SWORN TO AND SUBSCRIBED before me this 5 day of NOVEMBER. 1999 NOTARIAL SEAL LOIS E. SNYDER, Notary Public Corlel* Sam, Cumberland County, PA My Commivion Expirm March S. 2001 i . r THE PATRIOT NEWS THE SUNDAY PATRIOT NEWS Proof of Publication Under 9ct No. 5117. 9oorou d May 16. 1929 Commonwealth of Pennsylvania, County of Dauphin) as Michael Morrow being duly sworn according to law, deposes and says: That he Is the Assistant Controller of THE PATRIOT-NEWS CO., a corporation organized and existing under the laws of the Commonwealth of Pennsylvania, with its principal office and place of business at 812 to 818 Market Street, In the City of Harrisburg, County of Dauphin, State of Pennsylvania, owner and publisher of THE PATRIOT-NEWS and THE SUNDAY PATRIOT-NEWS newspapers of general circulation, printed and published at 812 to 818 Market Street, in the City, County and State aforesaid; that THE PATRIOT-NEWS and THE SUNDAY PATRIOT-NEWS were established March 41h, 1854, and September 18th, 1949, respectively, and all have been continuously published ever since; That the printed notice or publication which is securely attached hereto is exactly as printed and published In their regular daily and/or Sunday and Metro editions/issues which appeared on the 26th day of October and the 2nd and 9th day(s) of November 1999. That neither he nor said Company is interested in the subject matter of said printed notice or advertising, and that all of the allegations of this statement as to the time, place and character of publication are true; and That he has personal knowledge of the facts aforesaid and Is duly authorized and empowered to verify this statement on behalf of The Patriot-News Co. aforesaid by virtue and pursuant to a resolution unanimously passed and adopted severally by the stockholders and board of direc rs of the said Company and subsequently duly recorded in the office for the Recording of Deeds in and for said Cou ty pf Daup) in in Miscellaneous Book "M", Volume 14, Page 317. I 1c) ,.j d-_, PUBLICATION UCT IN VW) V?__ COPY S 1!!n to and s jT jlbef (te me is 181 y Nove? 9 A.D. S A L E 051 Terry L. Hasson,lrcolaPatl'c Harrisburg, UauU',?n 0'.,n 44r My Comnassun Ernams Ju ,N02 OTA4 PUBLIC , Member, Pennsylvania A,SOC,2t,On e. Nolar:ee ,?ffo,6f My commission expires June 6, 2002 a r -s s CUMBERLAND COUNTY SHERIFFS OFFICE •r Lpptp; COURTHOUSE rt ,W`','1 F CARLISLE, PA. 17013 Nldtn Statement of Advertising Costs Hafln To THE PATRIOT-NEWS CO., Dr. Aft FnFinan For publishing the notice or publication attached DE ON ALl;7FU1T Parcel or hereto on the above stated dates $ 452.50 tract 0 " being in Probating same Notary Fee(s) $ 1.50 HarhhDdwi County, Total $ 444.00 PenMyNaNa Wes) Lot pim 1', Pan of BIOCI{ "H; Indian r(Plan. Book 21, Pegs 63, -,Coast Records) aer'a Receipt for Advertising Cost ex1 raanNye,p?apit?dx,by,-Hartman Iptaat of ; ftEaglnaers' and of THE PATRIOT-NEWS and THE SUNDAY PATRIOT-NEWS, newspapers of general 8Ur5iyeryidMad hkwerrlber',19,' 199o,sipt of the aforesaid notice and publication costs and certifies that the same have r?lotrJity!daaoribedrbifawe to wit THE PATRIOT-NEWS CO. BEQj (H(h1<? at a Pdtd at s mrear of hNil and O)ppe,Way said point j1N?lrom By ................................................................... ^.a'r'dlgtdtOe of J land now or formerly of Realty Company of Pe ms*ar%W. North 07 degrees 02 edaees Wes4 a dNpnoe of one hundred and filly, and zgda:hundiedam (150.00) test ro'a palti!'M''aaGllrtel of lands now or form ery ofn,')t"'" company of Pedrroylvanla7 continuing along larrd><. of " ' was once a part. linoyla a8 Lot North e2 degrees 58 of one hundred hineytwo: ' -undredeha (192.50) fed ii:'A of Lot No. 3 and plant" point being to 'from a CCIIpe1p S' along Pawnee 8otigj raise o2 minutes East, end Zero hun ){eat to the point and (..... Nis. E PREMISES which F'+ and Nadia N. Noland, ..L.d.Y`r..?._ . n Anton t i.? 1 ZEA1 .S-?.T= is L j 51 S1.000.00Ad':ance'_ostsPaid 9/9/99 Air. Frank Federman Assessed'valuadon S 22970.00 %LRI7iv0. 99-4559 Civil Countrywide Home Loans, F/K/A Countrywide Funding Corporation Lynn R. HahnSand Ann E. Hahn 431 Pawnee Drive Mechanicsburg, PA 17055 REAL DEBT $ 188,310.90 I.`TER-EST fr 9/7/99 to 12/8/99 @ 30.96 per diem 2,879.28 A Ii' S Z=EES VK7 C05TS ATT i' ESCROW LATE CH.a.RGE SHEP Fr-'S C057S Dock-tine Poundaze Pos:in_o Bill: Ad':enlsina Ackno%vIedeine De Auctioneer - La%v io-Zar,' Counr: ?Iilr^ Cerl M2il L-%-, Postpone Saic Surcharst Le-?al Starch `.DV_.--' TISC:0: La,.%- Jou-mal Patio[ Snare of Bills Distribution of P:xeecs SG_ai s D?eC_ STAMPS Pa. : ans f?: 1 a>; Tk,.-p or Boro Transfer T -x, T?. 'ES 117.58 30.00 18.87 15.00 15.00 30.00 10.00 .50 1.00 8.06 .79 15.00 24.00 275.00 444.00 23.63 25.00 26.50 COUNTRYWIDE HOME LOANS, F/K/A COUNTRYWIDE FUNDING CORPORATION vs. LYNN R. HAHN ANN E. HAHN . CUMBERLAND COUNTY . COURT OF COMMON PLEAS . CIVIL DIVISION . NO. 99-4559 CIVIL AFFIDAVIT PURSUANT TO RULE 3129 (Affidavit No. 1) COUNTRYWIDE HOME LOANS, F/K/A COUNTRYWIDE FUNDING CORPORATION, Plaintiff in the above action, by its attorney, FRANK FEDERMAN, ESQ., sets forth as of the date the Praecipe for the Writ of Execution was filed the following information concerning the real property located at 431 PAWNEE DRIVE, MEC.LWICSBURG, PA 17055. 1. Name and address of Owner (s) or reputed Owner(s): NAME LAST KNOWN ADDRESS (if address cannot be reasonably ascertained, please so indicate) LYNN R. HAHN 431 PAWNEE DRIVE MECHANICSBURG, PA 17055 ANN E. HAHN 431 PAWNEE DRIVE MECHANICSBURG, PA 17055 2. Name and address of Defendant(s) in the judgment: NAME LAST KNOWN ADDRESS (if address cannot be reasonably ascertained, please so indicate) SAME AS ABOVE 3. Name and address of every judgment creditor whose judgment is a record lien on the real property to be sold: NAME LAST KNOWN ADDRESS (if address cannot be reasonably ascertained, please so indicate) NONE 4. Name and address of the last recorded holder of every mortgage of record: NAME LAST KNOWN ADDRESS (if address cannot be reasonably ascertained, please so indicate) COUNTRYWIDE HOME LOANS. INC. 155 N. LAKE AVENUE PASADENA, CA 91109 5. Name and address of every other person who has any record lien on the property: NAME LAST KNOWN ADDRESS (if address cannot be reasonably ascertained, please so indicate) NONE 6. Name and address of every other person who has any record interest in the property and whose interest may be affected by the sale: NAME LAST KNOWN ADDRESS (if address cannot be reasonably ascertained, please so indicate) NONE 7. Name and address of every other person whom the plaintiff has knowledge who has any interest in the property which may be affected by the sale: NAME TENANT/OCCUPANT DOMESTIC RELATIONS OF CUMBERLAND COUNTY LAST KNOWN ADDRESS (if address cannot be reasonably ascertained, please so indicate) 431 PAWNEE DRIVE MECHANICSBURG, PA 17055 13 NORTH HANOVER STREET CARLISLE. PA 17013 I verify that the statements made in this affidavit are true and correct to the best of my personal knowledge or information and belief. I understand that false statements herein are made subject to the penalties of 18 Pa. C.S. Sec. 4904 relating to unsworn falsification to authorities. September 7, 1999 RAZA / DATE F K FEDER , ESQUIRE ttorney f Plaintiff COUNTRYWIDE HOME LOANS, F/K/A COUNTRYWIDE FUNDING CORPORATION CUMBERLAND COUNTY COURT OF COMMON PLEAS Vs. LYNN R. HAHN ANN E. HAHN CIVIL DIVISION NO. 99-4559 CIVIL NOTICE OF SHERIFF'S SALE OF REAL PROPERTY September 7, 1999 TO. LYNN R. HAHN ANN E. HAHN 431 PAWNEE DRIVE MECHANICSBURG, PA 17055 **THIS FIRM IS A DEBT COLLECTOR ATTEMPTING TO COLLECT A DEBT AND ANY INFORMATION OBTAINED WILL BE USED FOR THAT PURPOSE. IF YOU HAVE PREVIOUSLY RECEIVED A DISCHARGE IN BANKRUPTCY, THIS IS NOT AND SHOULD NOT BE CONSTRUED TO BE AN ATTEMPT TO COLLECT A DEBT, BUT ONLY ENFORCEMENT OF A LIEN AGAINST PROPERTY.** Your house (real estate) at 431 PAWNEE DRIVE, MECHANICSBURG PA 17055, is scheduled to be sold at the Sheriff's Sale on DECEMBER 8. 1999 at 10:00 a.m. in the Cumberland County Courthouse, South Hanover Street, Carlisle, PA 17013, to enforce the court judgment of 5188,310.90 obtained by COUNTRYWIDE HOME LOANS F/K/A COUNTRYWIDE FUNDING CORPORATION (the mortgagee) against you. If the sale is postponed, the property will be relisted for the MARCH 1. 2000 Sheriff's Sale. NOTICE OF OWNER'S RIGHTS YOU MAY BE ABLE TO PREVENT THIS SHERIFF'S SALE To prevent this Sheriff's Sale, you must take immediate action: The sale will be cancelled if you pay to the mortgagee the back payments, late charges, costs and reasonable attorney's fees due. To find out how much you must pay, you may call: (215) 563-7000. 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. You may also be able to stop the sale through other legal proceedings. You may need an attorney to assert your rights. The sooner you contact one, the more chance you will have of stopping the sale. (See notice on page two on how to obtain an attorney.) YOU MAY STILL BE ABLE TO SAVE YOUR PROPERTY AND YOU HAVE OTHER RIGHTS EVEN IF THE SHERIFF'S SALE DOES TAKE PLACE. 1. If the Sheriff's Sale is not stopped, your property will be sold to the highest bidder. You may find out the price bid by calling (215) 563-7000. 2. You may be able to petition the Court to set aside the sale if the bid price was grossly inadequate compared to the value of your property. 3. The sale will go through only if the buyer pays the Sheriff the full amount due in the sale. To find out if this has happened, you may call (717) 240-6390. 4. If the amount due from the Buyer is not paid to the Sheriff, you will remain the owner of the property as if the sale never happened. 5. You have the right to remain in the property until the full amount due is paid to the Sheriff and the Sheriff gives a deed to the buyer. At that time, the buyer may bring legal proceedings to evict you. 6. You may be entitled to a share of the money which was paid for your house. A proposed schedule of distribution of the money bid for your house will be prepared by the Sheriff not later than thirty (30) days after the sale. The schedule shall be kept on file with the SHeriff and will be made available for inspection in his office. The schedule will state who will be receiving that money. The money will be paid out in accordance with this schedule unless exceptions (reasons why the proposed distribution is wrong) are filed with the Sheriff within ten (10) days after the filing of the proposed schedule. 7. You may also have other rights and defenses, or ways of getting your home back, if you act immediately after the sale. YOU SHOULD TAKE THIS PAPER TO YOUR LAWYER AT ONCE. IF YOU DO NOT HAVE A LAWYER OR CANNOT AFFORD ONE, GO TO OR TELEPHONE THE OFFICE LISTED BELOW TO FIND OUT WHERE YOU CAN GET LEGAL HELP. CUMBERLAND COUNTY ATORNEY REFERRAL CUMBERLAND COUNTY BAR ASOCIATION 2 LIBERTY AVENUE CUMBERLAND COUNTY COURTHOUSE CARLISLE, PA 17013 (717) 249-3166 (800) 990-9108 T..d .AL I)ZBCRIPTZOH TMV': CMAT^3X Minas, Moroni Or tract or land altuaeo. 171"4 and wing In -alblol Tewnehip. Ctsbarland Ceenty, sanhrylvsnLa snows as lot No. 1, Part of 5100% NU` Indian Croak (Flap sack 71. Pogo 411, Gubarlana eeufttly !decade) on out- -7 Froperma by Rartaman llaaceiabso, inc., X"In¦¦rs and surveyors dated Walromber r9, 1950, gocm roily delifiaed as follows, to wit: 1WGSIDCSMG at a Point at a .manor or Pawnee Drive and 0:1age Way, maid pelne beirQ to, from a concrace eurCl %nonce &10119 Osage Mayl south. it 1144Caas as minutes Beat. a distance of one lnu+drmd hismcy-te land littY 001vlrmdtbe (192_50) foot to • oiet: not corner cpmuyavanilatmahanea?e).ol~ Ssndos+.wly at m.a1tY rgns o'1: Of pennayleani•, north Ill degaeewga siMtee Want a dlatwam nY of one handraa fitey and veto annarmatn (150.00) foot re a VeLne at oeroer or lamas now ell farferly or Realty Coap"y of Ponneylvanla7 thence tantAx"inq along lamas or wbich "to A u once a part, known ae Lee No. a, Noath to degrees de alms Cna RAIL, a diatamaa at one aaadrrd ninatr-tam and ti!!y hunalradthe (152.00) 9,801 to a Po1Rt at cotaer of Lot Ile. ] and /arndo bitIve. said MOLnt pm3ng 30• sons a oenawate cu") boneo alert' pet:nr DELVE :OYt2 07 "QraY 02 liamaas Bast ¦ 4106.0100 of aee t.endr" firty and 'Zero eundtadtlls (150.00) r"L to the point and place of ndI51frva. •. •at11r. TIM saris PR=1E12 b&leh laal F. NoSaa?& and Radio U. NOlabll, hnnband and, wits, 6 Dead dated Osoeebar 17, loll and raearded b-erbol 17, rpp•t La that Recorder Or MUMS 0tfias in sad few Mebarland county. PRMn6Y1vania, in Do" Ymk »-L, Page 13, yrORtad and conveyed unto lynn B_ Uolam and ann a. mahn, ha¦bama and visal eat 502 pas( ti99 nA11v 99 rRl G:1.: ILL THAT CERTAIN piece, parcel or trace of land situate, lying and 11.1.ne in ismpden Township, Cumberland Cooney. Pennsylvania shown as LoL No. I, Part of ]hock -11" Indian Creel, (Plc,,, Hook 21, Page 53, Cun,berlanJ Coun Ly Rocorda) on iurvcy prepared 15y Hartman Associates, Inc.. Engineers and Surveyors daLed VovemAor 19, 1990, more fully described as follows, to wic: IIEGINNINO aL a point IL n corner of Pawnee Drive and Osage Way, said point 11e.ing 30' from a aonc rote curb; thence a].ont; Ocagr_ Way, South 92 deg roe:; 59 mi nu Las Gast, a dlat.ance of one hundred ninety-L,oo anti fifty hundredths (192.50) fact. Co a point at eorncr of Osage Way acid lands now or formerly of Realty Company uF Pennsylvania; chance .nloug ].and now or formerly of. Realty (:ompany or I'znnsylvanin, North 07 degrees 02 minutee West.., a diacance of one hundred fifty anti zero 11 .... dredeh (150.00) feet to a poil'L at corner of lands now or formerly uF Realty Company of Pennsylvania: thence continuing along lands of which this ,,as once a part, known as Lot No. 7,-North 82 degrees 58 minutes EasL, a distance of one hundred ninety-cwt, wud fi£Ly hundredths (192.50) feet to a point at corner of Lot No. 3 and Pawnee Drive, ;nid point being 10' from a concrete curl); thence ,,lung Pswnee Drive South 07 degrees 02 minutes East, a distance of one hundred ri Fty and zero hundredrhs (150.00) feet to the point anti place of BL•'CINNTNO. 11RING TH L• SAMC PRPa11SES which Paul. F. Noland and Nadia N. Noland, husband and ioife, by Dead dated January 17, 1991 and recorded January 22, 1991 in the Ofr.ir.e of the Recorder of Deeds in end for Cumberland County in Decd Book 34-Y, Pose 600, granted ar.d conveyed unto Paul F. Noland and Nadia N. Noland, husband and w1fe, Lbe grantors herein. I- PREMISES: 431 PAWNEE DRIVE WRIT OF EXECUTION and/or ATTACHMENT COMMONWEALTH OF PENNSYLVANIA) COUNTY OF CUMBERLAND) NO. gg_4ar;9 CIVIL 19 _ CIVIL ACTION • LAW TO THE SHERIFF OF Ctmberland COUNTY: To satisfy the debt, interest and costs due Countrywide Home Loans, F/K/A Countrywide Funding Cg=ration PLAINTIFF(S) from Lynn R. Hahn and Ann E. Hahn (1) You are directed to levy upon the property of the defendant(s) and to sell (2) You are also directed to attach the property of the defendant(s) not levied upon in the possession of 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 properly of the defendant(s) or otherwise disposing thereof; (3) If properlyof thedetendant(s) notlevied uponansubject to attachment isfound in the possession of anyoneother than a named garnishee, you are directed to notify hfm/herthat he/she has been added as a garnishee and is enjoined as above stated. Amount Due $188,310.90 fxnm 9/7/99 to 12/8/99 Interest (Ppr nip _ 7q n_q6) $9,879.711 Ally's Co. Ally Paid Plaintiff Paid Date: September 8, 1999 REQUESTING PARTY: Name -Prink Federman. Esq. Address: Wn Penn Center Plaza Suitp- 900, L.L. $.50 Due Prothy. Other Costs Curtis R. Long Prothonotary, Civil Division by Deputy Attorney for: Plaintiff Telephone: (asa) g6Z_7ann Supreme Court ID No. 12248 _ REAL ESTATE SALE Jo,? On lele2LL-- 9, /999 the sheriff levier) upon the defenoania interest in the real property situated in MI w (ED - v, Cumberland County, Pa., known and numbered as: 41319"A M ? CUM 0 and more fully described on Exhibit "A" filed with G-E Y am this writ and by this reference incorporated herein. Date: .L?s._2 1949 B N -O T m C? X: C'; W 7= ,o co )Y ?-n t T c0