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Home My WebLink About99-04715^I 01 v `1 .1 1 IMC MORTGAGE COMPANY VS. ALFRED C. SHEAFFER OVETTA L. SHEAFFER COURT OF COMMON PLEAS CUMBERLAND COUNTY No.: 99-4715 CIVIL AFFIDAVIT PURSUANT TO RULE 3129.1 Plaintiff in the above action sets forth as of the date the Praecipe for the Writ of Execution was filed the following information concerning the real property located at 14 EAST STREET, MOUNT HOLLY SPRINGS, PA 17065: 1. Name and address of Owner(s) or reputed Owner(s): Name Last Known Address (if address cannot be reasonably ascertained, please indicate) ALFRED C. SHEAFFER OVETTA L. SHEAFFER 14 EAST STREET MOUNT HOLLY SPRINGS, PA 17065 14 EAST STREET MOUNT HOLLY SPRINGS, PA 17065 2. Name and address of Defendant(s) in the judgment: ALFRED C. SHEAFFER 14 EAST STREET MOUNT HOLLY SPRINGS, PA 17065 OVETTA L. SHEAFFER 14 EAST STREET MOUNT HOLLY SPRINGS, PA 17065 3. Name and last known address of every judgment creditor whose judgment is a record lien on the real property to be sold: Name Last Known Address (if address cannot be reasonably ascertained, please indicate) None. 4. Name and address of last recorded holder of every mortgage of record: Last Known Address (if address ess cane be indicate) Name reasonably ascertained, please Plaintiff. 5. Name and address of every other person who has any record lien on the property: Last Known Address (if address cannot be Name reasonably ascertained, please indicate) None. and whose 6. Name and address of every other person who has any record interest in the property interest may be affected by the sale. t be Name Cumberland County Domestic Relations Last Known Address (if address canno reasonably ascertained, please indicate) 13 N. Hanover Street Carlisle, PA 17013 Cumberland County Tax Claim Bureau Dept. of Public Assistance 1 Courthouse Square Carlisle, PA 17013-3387 33 Westminster Drive, P.O. Box 599 Carlisle, PA 17013-0599 7. Name and address of every other person of whom the plaintiff has knowledge who has any interest in the property which may be affected by the sale: Last Known Address (if address cannot be Name reasonably ascertained, please indicate) Tenants/Occupants 14 EAST STREET MOUNT HOLLY SPRINGS, PA 17065 I verify that the statements made in this affidavit are true and correct to the best of my stand that stateme C.S.A. 4904'relatingdtorunsworn fall fication tonau horitiesre subject to the knowledge, Penalties of 8 P n 1 ,ESQUIRE for November 10, 2000 71 >- IN THE COURT OF COMMON PLEAS OF CUMBERLAND COUNTY- PENNSYLVANIA IMC MORTGAGE COMPANY :COURT OF COMMON PLEAS :CUMBERLAND COUNTY Plaintiff VS. ALFRED C.SHEAFFER OVETTA L. SHEAFFER 14 EAST STREET MOUNT HOLLY SPRINGS, Defendant PA 17065: No. 99-4715 PRAECIPE FOR JUDGMENT Enter Judgment in favor of Plaintiff and against Defendant(s) Alfred C. & Ovetta L. Sheaffer for want of an Answer. (XXXX) Assess damages as follows: Debt: $81,377.93 Interest through 11 /1 /99 $ 3,317.04 TOTAL $84,694.97 I CERTIFY THAT THE FOREGOING ASSESSMENT OF DAMAGES IS FOR SPECIFIED AMOUNTS ALLEGED TO BE DUE IN THE COMPLAINT AND IS CALCULABLE AS A SUM CERTAIN FROM THE COMPLAINT. I certify that written notice of the intention to file this Praecipe was mailed or delivered to the party against whom judgment is to be entered and to his attorney of record, if any, after the default occurred and at least ten days prior to the date of the filing of this Praecipe. A copy of the notice is attached. R.C.P. 237.1. AND NOW Judgment is entered in favor the sum of as per the above certification. LAW OFFICES OF GREGORY JAVARDIAN Attorney for Plaintiff BY and against by default for want of and damages assessed at dollars ($ PROTHONOTARY IN THE COURT OF COMMON PLEAS OF CUMBERLAND COUNTY- PENNSYLVANIA IMC MORTGAGE COMPANY :COURT OF COMMON PLEAS :CUMBERLAND COUNTY Plaintiff VS. ALFRED C.SHEAFFER OVETTA L. SHEAFFER 14 EAST STREET MOUNT HOLLY SPRINGS, PA 17065: No. 99-4715 Defendant : AFFIDAVIT OF ADDRESSES AFFIDAVIT OF LAST KNOWN ADDRESS BEFORE ME, the undersigned authority, personally appeared GREGORY JAVARDIAN, ESQUIRE, who, being duly sworn according to law, deposes and says that to the best of his knowledge, information and belief that the last known address of the Defendants, Alfred C. & Ovetta L. Sheaffer, is 14 East Street, Mount Holly Springs, PA 17065. I ARDIAN, ESQUIRE Sworn and subscribee]d to before me this a day of ? 1999. NOTARY PUBLIC 003 IN THE COURT OF COMMON PLEAS OF CUMBERLAND COUNTY- PENNSYLVANIA IMC MORTGAGE COMPANY :COURT OF COMMON PLEAS :CUMBERLAND COUNTY Plaintiff VS. ALFRED C.SHEAFFER OVETTA L. SHEAFFER 14 EAST STREET MOUNT HOLLY SPRINGS, PA 17065: No. 99-4715 Defendant : AFFIDAVIT OF NON-MILITARY AFFIDAVIT OF NON-MILITARY SERVICE COMMONWEALTH OF PENNSYLVANIA COUNTY OF BUCKS ss The undersigned, being duly sworn according to law, deposes and says this affidavit is made on behalf of the above plaintiff, being authorized to do so, and it is averred that: (a) Alfred C. & Ovetta L. Sheaffer are over 21 years of age, resides at 14 East Street, Mount Holly Springs, PA 17065 is employed as an unknown at unknown. Deponent further avers that none of the above is within the protection of the Soldiers' and Sailors' Civil Relief Act of 1940, together with the amendments thereto. Sworn to and su scribed before me this" day of °` - , 1999. IMC MORTGAGE COMPANY :COURT OF COMMON PLEAS :CUMBERLAND COUNTY Plaintiff VS. ALFRED C.SHEAFFER OVETTA L. SHEAFFER 14 EAST STREET MOUNT HOLLY SPRINGS, PA 17065: No. 99-4715 Defendant : CERTIFICATION OF MAILING I, Gregory Javardian, Esquire Attorney at Law, do certify that: 1. 1 am counsel for plaintiff in the above entitled case of action. 2. 1 forwarded to the following defendant(s) on the date(s) listed , by regular mail, a copy of the Notice, Rule 237.11: Alfred C. & Ovetta L. Sheaffer 9/7/99 A copy of the notice is attached hereto. 3. 1 certify that the foregoing statements made by me are true. I am aware that if any of the foregoing statements made by me are willfully false, I am subject to punishment. BY: vardian, Esquire G V5,/9 Dated: ///O? IMC MORTGAGE COMPANY In The Court of Common Pleas Plaintiff V. Cumberland County ALFRED C. SHEAFFER No. 99-4715 Civil OVETTA L. SHEAFFER Defendants TO: ALFRED C. SHEAFFER OVETTA L. SHEAFFER DATE OF NOTICE: 9/7/99 NOTICE, RULE 237.1 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 se 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 Bar Association Lawyer Reference Servic 2 Liberty Avenue /I Carlisle, PA 1701 (717) 249-3166 Gregory Javardian, Esquire 44 Second Street Pike, Suite 203 Southampton, Pa 18966 (215) 942-9690 Attorney for Plaintiff Usted se encuentra en estado de rebeldia por no haber tornado la accion requiida de su parte en este caso. Al no tomar la accion debida dentro de un termino de diez (10) dias de esta notification, el tribunal podra, sin necesidad de compararecer usted en cone o escuchar prueba alguna, dictar sentencia en su contra, usted puede perderbienes y otros derechos importantes. Debe llevar esta notification a un abogado immediatemente si usted no tiene abogado, o si no tiene dinero suficiente para tal servicio, vaya en persona o Ilame por telpfono a la oficina, cuya direction se encuentra escrita abajo para averiguar donde se puede conseguir assistencia legal. "NOTICE PURSUANT TO FAIR DEBT COLLECTION PRACTICES ACT THIS IS AN ATTEMPT TO COLLECT A DEBT AND ANY INFORMATION OBTAINED WILL BE USED FOR THAT PURPOSE" (RULE OF CIVIL PROCEDURE NO. 236) - REVISED IN THE COURT OF COMMON PLEASE OF CUMBERLAND COUNTY, PENNSYLVANIA CIVIL ACTION- LAW IMC MORTGAGE COMPANY Plaintiff VS. ALFRED C. SHEAFFER OVETTA L. SHEAFFER 14 EAST STREET MOUNT HOLLY SPRINGS, PA 17065 Defendant :COURT OF COMMON PLEAS :CUMBERLAND COUNTY No. 99-4715 NOTICE PURSUANT TO RULE 236 NOTICE IS GIVEN THAT A JUDGMENT IN THE ABOVE CAPTIONED MATTER HAS BEEN ENTERED AGAINST YOU. PROTHONOTARY, CUMBERLAND COUNTY If you have any questions concerning the above, please contact: Gregory Javardian, Esquire Attorney ID# 55669 44 Second Street Pike, Suite 203 Southampton, PA 18966 (215) 942-9690 Attorney for Plaintiff IN THE COURT OF COMMON PLEAS OF CUMBERLAND COUNTY- PENNSYLVANIA IMC MORTGAGE COMPANY Plaintiff VS. :COURT OF COMMON PLEAS :CUMBERLAND COUNTY ALFRED C.SHEAFFER OVETTA L. SHEAFFER 14 EAST STREET MOUNT HOLLY SPRINGS, PA 17065: No. 99-4715 Defendant NOTICE OF ORDER, DECREE OR JUDGMENT TO: ( ) Plaintiff (x) Defendant ( )Garnishee ( ) Additional Defendant Your are hereby notified that the following order, decree, or Judgment has been entered against you on ( ) Decree Nisi in Equity. ( ) Final Decree in Equity. ( X ) Judgment of ( 1 Confession ( X ? Default ( 1 Non-Pros ( ) Judgment is in the amount of $ ( ) Verdict ( ) Non-Suit () Arbitration Award. ,Plus Costs. ( ) District Justice Transcript of Judgment in CIVIL ACTION in the amount of $ , Plus Costs. ( I If not satisfied within sixty (60) days, your motor vehicle operator's license will be suspended by the Pennsylvania Department of Transportation. Prothonotary BY: Deputy If you have any questions concerning the above, please contact: Gregory Javardian, Esquire Attorney ID# 55669 44 Second Street Pike, Suite 203 Southampton, PA 18966 (215) 942-9690 Attorney for Plaintiff I 1 r s C?l 11. 1 U C•`? U ? ?- l CASE NO: 1999-04715 P SHERIFF'S RETURN - REGULAR COMMONWEALTH OF PENNSYLVANIA: COUNTY OF CUMBERLAND IMC MORTGAGE CO VS. SHEAFFER ALFRED C ET AL DAVID MCKINNEY Sheriff or Deputy Sheriff of CUMBERLAND County, Pennsylvania, who being duly sworn according to law, says, the within COMPLAINT - MORT FORE was served upon SHEAFFER ALFRED C the defendant, at 11:06 HOURS, on the 12th day of August 1999 at 14 EAST ST MOUNT HOLLY, PA 17065 CUMBERLAND County, Pennsylvania, by handing to OVETTA SHEAFFER a true and attested copy of the COMPLAINT - MORT FORE together with NOTICE and at the same time directing Her attention to the contents thereof. Sheriff's Costs. So answers: Docketing 18.00 Service 3.72 Affidavit .00 Surcharge 8.00 ma i?E2"ne, 5 i ,5`ZT." TZ- GR$G07Y JAVARDIAN 08/13/199 9 by ???? Sne21LL Sworn and subscribed to before me this /3l!- day of O.,,,? 19c7j_ A. D. L-ham.,. L? m ono aoo ?Qq? I I rz0 ?"?' SHERIFF'S RETURN - REGULAR CASE NO: 1999-04715 P COMMONWEALTH OF PENNSYLVANIA: COUNTY OF CUMBERLAND IMC MORTGAGE CO VS. SHEAF_ FER ALFRED C ET AL DAVID MCKINNEY Sheriff or Deputy Sheriff of CUMBERLAND County, Pennsylvania, who being duly sworn according to law, says, the within COMPLAINT - MORT FORE was served upon SHEAFFER OVETTA L defendant, at 11:06 HOURS, on the 12th day of August the 1999 at 14 EAST STREET MT HOLLY SPRINGS, PA 17065 CUMBERLAND County, Pennsylvania, by handing to OVETTA SHEAFFER a true and attested copy of the COMPLAINT - MORT FORE together with NOTICE and at the same time directing Her attention to the contents thereof. Sheriff's Costs: So ans??rs: Docketing 6.00 Service .00 Affidavit Surcharge 8.00 $T4-0'U-GR$GORY JAVARDIAN 08/13/1999 by epu y S erh?-?-- Sworn and subscribed to before me this .3 ? / day of 1999 A. D. 04 - 0- lOw !:T IPz_OLnono a y PRAECIPE FOR WRIT OF EXECUTION COMMONWEALTH OF PENNSYLVANIA COUNTY OF CUMBERLAND IMC MORTGAGE COMPANY Plaintiff COURT OF COMMON PLEAS V. ALFRED C. SHEAFFER OVETTA L. SHEAFFER Defendant(s) TO THE PROTHONOTARY: Issue Writ of Execution in the above matter: AMOUNT DUE INTEREST from to At per diem (Costs to be added) CUMBERLAND COUNTY NO. 99-4715 $84,694.97 y TRACT NO. 1 - ALL THAT CERTAIN tract of ground with the improvements thereon erected situate in the BOROUGH OF MOUNT HOLLY SPRINGS, Cumberland County, Pennsylvania, bounded and described as follows: BEGINNING at an iron pipe at comer of lands now or formerly of J.W. Odell and edge of East Street; thence South thirty-nine (39) degrees twenty-two (22) minutes East, a distance of fifty (50) feet along edge of East Street to a stake on the edge of said street; thence South forty-nine (49) degrees fifty-one (51) minutes twenty (20) seconds West, a distance of ninety (90) feet along South Street to a stake and corner of lands now or formerly of Norman D. Kuhn, et ux; thence North thirty-nine (39) degrees twenty-two (22) minutes West, a distance of fifty (50) feet along lands now or formerly of Norman D. Kuhn et ux, to a stake and comer of lands now or formerly of J.W. Odell; thence North forty-nine (49) degrees fifty-one (51) minutes twenty (20) seconds East, a distance of ninety (90) feet along lands now or formerly of J. W. Odell to an iron pipe at the edge of East Street and corner of lands now or formerly of J.W. Odell and place of BEGINNING. SAID description being in accordance with survey of Thomas A. Neff, Registered Surveyor, dated October 14, 1966. TRACT NO.2 - ALL THAT CERTAIN tract of land situate in the BOROUGH OF MOUNT HOLLY SPRINGS, Cumberland County, Pennsylvania, bounded and described as follows, pursuant to a survey by Thomas A. Neff, Registered Surveyor, on October 14, 1966: BEGINNING at a stake the intersection of the northern line of South Street and the eastern line of a public alley; thence by the eastern line of said alley, North thirty-nine (39) degrees twenty- two (22) minutes West, fifty (50) feet to a stake; thence by land now or formerly of J.W. Odell, North forty-nine (49) degrees fifty-one (51) minutes twenty (20) seconds East, eighty-seven; and eighty-one one-hundredths (87.81) feet to a stake; thence South thirty-nine (39) degrees twenty two (22) minutes East, fifty (50) feet to a stake on the northern line of South Street; thence by the northern line of said street, South forty-nine (49) degrees fifty-one (51) minutes twenty (20) seconds West, eighty-seven and eighty-one one-hundredths (87.81) feet to the place of BEGINNING. BEING the same premises which James R. Baughman and Doris L. Baughman, his wife, by Deed bearing date the 2n' day of may, 1994, and recorded in the Office of the Recorder of Deeds in and for Cumberland County, Pennsylvania, on the I I" day of May, 1994, in Record Book 105, page 182, granted and conveyed unto Alfred C. Sheaffer and Ovetta L. Sheaffer, his wife. TAX MAP (23) 32-2336-113 BEING known as 14 East Street, Mount Holly Springs, PA 17065 U L. I? Ci_ C 1 .'1 u\ U IN THE COURT OF CC{MV PLEAS OF CI24EERINID Op WN PF79NSyLVANIA CIVIL DrVISION IMC MORTGAGE COMPANY : File No. 99-4715 : Amount Due 84,694.97 V. ALFRED C. SHEAFFER OVETTA L. SHEAFFER TO THE PROTHONOTARY OF THE SAID COURT: : Atty's Conn . Costs The undersigned hereby certifies that the below does not arise out of a retail .nstallment sale, contract, or account based on a confession of judgment, but if it does, A is based on the appropriate original proceeding filed pursuant to Act 7 of 1966 as mended; and for real property pursuant to Act 6 of 1974 as amended. PRAECIPE FOR EXECUTION Issue writ of execution in the above natter to the Sheriff of CUMBERLAND 3ounty, for debt, interest and costs upon the following described property of the iefendant(s) 14 EAST STREET, MOUNT HOLLY SPRINGS, PA 17065. PRADCIPE FOR ATTACHMENT EXECUTION Issue writ of attachment to the Sheriff of County, for debt, interest and costs, as above, directing attadment 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) 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: DECEMBER 13, 1999 Signature; - Print Javandian Ed v ilce Address: 44 Second StAeet Pike. Suite Southampton, PA 18966 . Interest Attorney for: PX.a.Lnti.6 Telephone: 215-942-9690 Suprerre Court ID No.: 55669 TRACT NO. 1 - ALL THAT CERTAIN tract of ground with the improvements thereon erected situate in the BOROUGH OF MOUNT HOLLY SPRINGS, Cumberland County, Pennsylvania, bounded and described as follows: BEGINNING at an iron pipe at comer of lands now or formerly of J.W. Odell and edge of East Street; thence South thirty-nine (39) degrees twenty-two (22) minutes East, a distance of fifty (50) feet along edge of East Street to a stake on the edge of said street; thence South forty-nine (49) degrees fifty-one (51) minutes twenty (20) seconds West, a distance of ninety (90) feet along South Street to a stake and corner of lands now or formerly of Norman D. Kuhn, et ux; thence North thirty-nine (39) degrees twenty-two (22) minutes West, a distance of fifty (50) feet along lands now or formerly of Norman D. Kuhn et ux, to a stake and corner of lands now or formerly of J.W. Odell; thence North forty-nine (49) degrees fifty-one (51) minutes twenty (20) seconds East, a distance of ninety (90) feet along lands now or formerly of J. W. Odell to an iron pipe at the edge of East Street and corner of lands now or formerly of J.W. Odell and place of BEGINNING. SAID description being in accordance with survey of Thomas A. Neff, Registered Surveyor, dated October 14, 1966. TRACT NO.2 - ALL THAT CERTAIN tract of land situate in the BOROUGH OF MOUNT HOLLY SPRINGS, Cumberland County, Pennsylvania, bounded and described as follows, pursuant to a survey by Thomas A. Neff, Registered Surveyor, on October 14, 1966: BEGINNING at a stake the intersection of the northern line of South Street and the eastern line of a public alley; thence by the eastern line of said alley, North thirty-nine (39) degrees twenty- two (22) minutes West, fifty (50) feet to a stake; thence by land now or formerly of J.W. Odell, North forty-nine (49) degrees fifty-one (51) minutes twenty (20) seconds East, eighty-seven; and eighty-one one-hundredths (87.81) feet to a stake; thence South thirty-nine (39) degrees twenty two (22) minutes East, fifty (50) feet to a stake on the northern line of South Street; thence by the northern line of said street, South forty-nine (49) degrees fifty-one (51) minutes twenty (20) seconds West, eighty-seven and eighty-one one-hundredths (87.81) feet to the place of BEGINNING. BEING the same premises which James R. Baughman and Doris L. Baughman, his wife, by Deed bearing date the 2nd day of may, 1994, and recorded in the Office of the Recorder of Deeds in and for Cumberland County, Pennsylvania, on the I I" day of May, 1994, in Record Book 105, page 182, granted and conveyed unto Alfred C. Sheaffer and Ovetta L. Sheaffer, his wife. TAX MAP (23) 32-2336-113 BEING known as 14 East Street, Mount Holly Springs, PA 17065 ut IT: V-1 C_ 1" j - U U• U I` 0 caoZ, r v t 0 y I h o IMC MORTGAGE COMPANY V. Plaintiff ALFRED C. SHEAFFER OVETTA L. SHEAFFER Defendant(s) COURT OF COMMON PLEAS CUMBERLAND COUNTY NO. 99-4715 AFFIDAVIT PURSUANT TO RULE 3129.1 IMC MORTGAGE COMPANY, plaintiff in the above action, sets forth as of the date the praecipe for the writ of execution was filed the following information concerning the real estate property located at 14 EAST STREET, MOUNT HOLLY SPRINGS, PA 17065. 1. Name and address of owner(s) or reputed owner(s): Name Address ALFRED C. SHEAFFER OVETTA L. SHEAFFER 14 EAST STREET MOUNT HOLLY SPRINGS, PA 17065 2. Name and address of defendant(s) in the judgment: Name Address ALFRED C. SHEAFFER OVETTA L. SHEAFFER 14 EAST STREET MOUNT HOLLY SPRINGS, PA 17065 3. Name and Address of every judgment creditor whose judgment is a record lien on the real property to be sold: Name Address NONE, 4. Name and address of the last recorded holder of every mortgage of record: Name Address NONE 5. Name and address of every other person who has any record lien on the property: Name Address 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 Address TAX CLAIM BUREAU CUMBERLAND ASSISTANCE OFFICE DOMESTIC RELATIONS CUMBERLAND COUNTY COURTHOUSE 1COURTHOUSESQUARE CARLISLE, PA 17013 33 WESTMINSTER DRIVE P.O. BOX 599 CARLISLE, PA 17013-0599 P.O. BOX 320 CARLISLE, PA 17013 7. Name and address of every other person of whom the plaintiff has knowledge who has any interest in the property, which may be affected by the sale: Name Address TENANTS/OCCUPANTS 14 EAST STREET MOUNT HOLLY SPRINGS, PA 17065 I verify that the statements made in this affidavit are true and correct to the best of my knowledge, information and belief. I understand that false statements herein are subject to the penalties of 18 Pa.C.S.A. 4904 relating to unswom falsification to authorities. Dated: /Zllo AG ?JAVARDIAN TRACT NO. 1 - ALL THAT CERTAIN tract of ground with the improvements thereon erected situate in the BOROUGH OF MOUNT HOLLY SPRINGS, Cumberland County, Pennsylvania, bounded and described as follows: BEGINNING at an iron pipe at comer of lands now or formerly of J.W. Odell and edge of East Street; thence South thirty-nine (39) degrees twenty-two (22) minutes East, a distance of fifty (50) feet along edge of East Street to a stake on the edge of said street; thence South forty-nine (49) degrees fifty-one (51) minutes twenty (20) seconds West, a distance of ninety (90) feet along South Street to a stake and corner of lands now or formerly of Norman D. Kuhn, et ux; thence North thirty-nine (39) degrees twenty-two (22) minutes West, a distance of fifty (50) feet along lands now or formerly of Norman D. Kuhn et ux, to a stake and corner of lands now or formerly of J.W. Odell; thence North forty-nine (49) degrees fifty-one (51) minutes twenty (20) seconds East, a distance of ninety (90) feet along lands now or formerly of J. W. Odell to an iron pipe at the edge of East Street and corner of lands now or formerly of J.W. Odell and place of BEGINNING. SAID description being in accordance with survey of Thomas A. Neff, Registered Surveyor, dated October 14, 1966. TRACT NO.2 - ALL THAT CERTAIN tract of land situate in the BOROUGH OF MOUNT HOLLY SPRINGS, Cumberland County, Pennsylvania, bounded and described as follows, pursuant to a survey by Thomas A. Neff, Registered Surveyor, on October 14, 1966: BEGINNING at a stake the intersection of the northern line of South Street and the eastern line of a public alley; thence by the eastern line of said alley, North thirty-nine (39) degrees twenty- two (22) minutes West, fifty (50) feet to a stake; thence by land now or formerly of J.W. Odell, North forty-nine (49) degrees fifty-one (51) minutes twenty (20) seconds East, eighty-seven; and eighty-one one-hundredths (87.81) feet to a stake; thence South thirty-nine (39) degrees twenty two (22) minutes East, fifty (50) feet to a stake on the northern line of South Street; thence by the northern line of said street, South forty-nine (49) degrees fifty-one (51) minutes twenty (20) seconds West, eighty-seven and eighty-one one-hundredths (87.81) feet to the place of BEGINNING. BEING the same premises which James R. Baughman and Doris L. Baughman, his wife, by Deed bearing date the 2"d day of may, 1994, and recorded in the Office of the Recorder of Deeds in and for Cumberland County, Pennsylvania, on the 1 V' day of May, 1994, in Record Book 105, page 182, granted and conveyed unto Alfred C. Shcaffer and Ovetta L. Sheaffer, his wife. TAX MAP (23) 32-2336-113 BEING known as 14 East Street, Mount Holly Springs, PA 17065 ,;? c_? '- r %. ??_ . _ ?:? ??_ i;?; u.. :f) _ , _i :C ?: r._ ?_: t.: L"' _ - ?'- U c: _? Cl• C i LAW OFFICES OF GREGORY JAVARDIAN BY: GREGORY JAVARDIAN INDENTIFICATION NO. 55669 44 SECOND STREET PIKE SUITE 101 SOUTHAMPTON, PA 18966 (215) 942-9690 IMC MORTGAGE COMPANY V. Plaintiff ALFRED C. SHEAFFER OVETTA L. SHEAFFER Defendant(s) COURT OF COMMON PLEAS CUMBERLAND COUNTY NO. 99-4715 NOTICE OF SHERIFF'S SALE OF REAL PROPERTY TO: ALFRED C. SHEAFFER OVETTA L. SHEAFFER 14 EAST STREET MOUNT HOLLY SPRINGS, PA 17065 Your house (Real Estate) at 14 EAST STREET, MOUNT HOLLY SPRINGS, PA 17065, is scheduled to be sold at Sheriffs Sale on Monday, 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 to enforce the Court Judgment of 84.694.97 obtained by IMC MORTGAGE COMPANY, against you. NOTICE OF OWNER'S RIGHTS YOU MAY BE ABLE TO PREVENT THIS SHERIFF'S SALE To prevent this Sheriffs Sale you must take immediate action: 1. The sale will be canceled if you pay to Gregory Javardian, the back payments, late charges, costs and reasonable attorney's fees due. To find out how much you must pay, you may call Gregory Javardian at telephone (215) 942-9690. 2. You may be able to stop the sale by filing a petition asking the Court to strike or open the Judgment, if the Judgment was improperly entered. You may also ask the Court to postpone the sale for good cause. 3. You may also be able to stop the sale through other legal proceedings. You may need an attorney to assert your rights. The sooner you contact one, the more chance you will have of stopping the sale. (See notice on page two of 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 Sheriffs Sale is not stopped, your property will be sold to the highest bidder. You may find out the bid price by calling Gregory Javardian, Esquire at telephone (215) 942-9690. 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 the 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 Gregory Javardian, Esquire at telephone (215) 942- 9690. 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 house. A schedule of distribution of the money bid for your house will be filed by the Sheriff. This schedule will state who will be receiving that money. The money will be paid out in accordance with this schedule unless exceptions (reasons why the proposed distribution is wrong) are filed with the Sheriff within (10) days. 7. You may also have other rights and defenses, or ways of getting your house 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 BAR ASSOCIATION LAWYER REFERRAL AND INFORMATION SERVICE 4' FLOOR. CUMBERLAND COUNTY COURTHOUSE CARLISLE, PA 17013 (717)240-6200 TRACT NO. I - ALL THAT CERTAIN tract of ground with the improvements thereon erected situate in the BOROUGH OF MOUNT HOLLY SPRINGS, Cumberland County, Pennsylvania, bounded and described as follows: BEGINNING at an iron pipe at comer of lands now or formerly of J.W. Odell and edge of East Street; thence South thirty-nine (39) degrees twenty-two (22) minutes East, a distance of fifty (50) feet along edge of East Street to a stake on the edge of said street; thence South forty-nine (49) degrees fifty-one (51) minutes twenty (20) seconds West, a distance of ninety (90) feet along South Street to a stake and comer of lands now or formerly of Norman D. Kuhn, et ux; thence North thirty-nine (39) degrees twenty-two (22) minutes West, a distance of fifty (50) feet along lands now or formerly of Norman D. Kuhn et ux, to a stake and corner of lands now or formerly of J.W. Odell; thence North forty-nine (49) degrees fifty-one (51) minutes twenty (20) seconds East, a distance of ninety (90) feet along lands now or formerly of J. W. Odell to an iron pipe at the edge of East Street and corner of lands now or formerly of J.W. Odell and place of BEGINNING. SAID description being in accordance with survey of Thomas A. Neff, Registered Surveyor, dated October 14, 1966. TRACT NO. 2 - ALL THAT CERTAIN tract of land situate in the BOROUGH OF MOUNT HOLLY SPRINGS, Cumberland County, Pennsylvania, bounded and described as follows, pursuant to a survey by Thomas A. Neff, Registered Surveyor, on October 14, 1966: BEGINNING at a stake the intersection of the northern line of South Street and the eastern line of a public alley; thence by the eastern line of said alley, North thirty-nine (39) degrees twenty- two (22) minutes West, fifty (50) feet to a stake; thence by land now or formerly of J.W. Odell, North forty-nine (49) degrees fifty-one (51) minutes twenty (20) seconds East, eighty-seven; and eighty-one one-hundredths (87.81) feet to a stake; thence South thirty-nine (39) degrees twenty two (22) minutes East, fifty (50) feet to a stake on the northern line of South Street; thence by the northern line of said street, South forty-nine (49) degrees fifty-one (51) minutes twenty (20) seconds West, eighty-seven and eighty-one one-hundredths (87.81) feet to the place of BEGINNING. BEING the same premises which James R. Baughman and Doris L. Baughman, his wife, by Deed bearing date the 2nd day of may, 1994, and recorded in the Office of the Recorder of Deeds in and for Cumberland County, Pennsylvania, on the 11 " day of May, 1994, in Record Book 105, page 182, granted and conveyed unto Alfred C. Sheaffer and Ovetta L. Sheaffer, his wife. TAX MAP (23) 32-2336-113 BEING known as 14 East Street, Mount Holly Springs, PA 17065 C) F li!`J (V I_l, il) LLB` f_• L. Ql lJ !1_ IMC Mortgage Company .vs. Alfred C. Sheaffer and Ovetta L. Sheaffer In the Court of Common Pleas of Cumberland County, Pennsylvania No. 99-4715 Civil Term R. Thomas Kline, Sheriff, who being duly sworn according to law, says this writ is returned STAYED. Sheriff's Costs: Docketing Poundage Law Library County Levy Postpone Sale Surcharge Sworn and subscribed to before me 30.00 1.93 .50 1.00 15.00 20.00 30.00 $ 98.43 Pd by Atty. 12-21-99 This .o w day of 1999, A.D. r thonotary So answers: R. Thomas Kline, Sheriff BY _ Real Estate Deputy i' S9 L/L -? G ??L 96.39F IMC MORTGAGE COMPANY V. Plaintiff ALFRED C. SHEAFFER OVETTA L. SHEAFFER Defendant(s) COURT OF COMMON PLEAS CUMBERLAND COUNTY NO. 99-4715 AFFIDAVIT PURSUANT TO RULE 3129.1 IMC MORTGAGE COMPANY, plaintiff in the above action, sets forth as of the date the praecipe for the writ of execution was filed the following information concerning the real estate property located at 14 EAST STREET, MOUNT HOLLY SPRINGS, PA 17065. 1. Name and address of owner(s) or reputed owner(s): Name Address ALFRED C.SHEAFFER OVETTA L. SHEAFFER 14 EAST STREET MOUNT HOLLY SPRINGS, PA 17065 2. Name and address of defendant(s) in the judgment: Name Address ALFRED C. SHEAFFER OVETTA L. SHEAFFER 14 EAST STREET MOUNT HOLLY SPRINGS, PA 17065 3. Name and Address of every judgment creditor whose judgment is a record lien on the real property to be sold: Name Address NONE 4. Name and address of the last recorded holder of every mortgage of record: Name Address NONE ,:.,.:- ? , ,,.. ..•r?t i,,,,.n .,n ,!v- ?rnnr•rty' Name ,,,?! „i,t, •_ I,!„ ?4imc *,nnr, r, Name 'tnd arldresti ?'!' ether I?'` '•"`' :,•rnr?i fi'hr mm?erty and whose interest n•. r ? ;,r„-,, OPFI? (. t ;lz 1 l Int `SP Set i ARF. ?dPERL,+.Nn ?'L)(.11T`, rt)t'RTIiO1 Sr.. V, Rj:l I ( i„ -(, - ?, •,?cr?;'fuIIVSTFR IMP.{?/F ,? r) i101'",59 . ART 1SI F.. P\ 7. Name and Of rvcr; ether pcrsnn )F .11nm the Plaintiff has knmvlerlt;e %vho has atty .uklress " r.r+ria by the ;al^ interest ir: ", m c F P-? A- YPt1( I( ( ( I'A``T`? i 4 !-AST STRFT;" mil)(!*J"T FIr)LL`I',PR.TNC,S, PA i7?b5 avit 1 ver n „Miril the ` sWemcnts ,nd hclief mlctndcrstandrf hat falsens>-ttcmcnts herein arehuhjectoto the knowledge, '»orn falsification to authorities. penaltirrs <,F 19 N (' , A nns A t?4 rclacmt J)OC,l 171f,,) j [AVARDIAN ¦ TRACT NO. 1 - ALL THAT CERTAIN tract of ground with the improvements thereon erected situate in the BOROUGH OF MOUNT HOLLY SPRINGS, Cumberland County, Pennsylvania, bounded and described as follows: BEGINNING at an iron pipe at corner of lands now or formerly of J.W. Odell and edge of East Street; thence South thirty-nine (39) degrees twenty-two (22) minutes East, a distance of fifty (50) feet along edge of East Street to a stake on the edge of said street; thence South forty-nine (49) degrees fifty-one (51) minutes twenty (20) seconds West, a distance of ninety (90) feet along South Street to a stake and corner of lands now or formerly of Norman D. Kuhn, et ux; thence North thirty-nine (39) degrees twenty-two (22) minutes West, a distance of fifty (50) feet along lands now or formerly of Norman D. Kuhn et ux, to a stake and comer of lands now or formerly of J.W. Odell; thence North forty-nine (49) degrees fifty-one (51) minutes twenty (20) seconds East, a distance of ninety (90) feet along lands now or formerly of J. W. Odell to an iron pipe at the edge of East Street and comer of lands now or formerly of J.W. Odell and place of BEGINNING. SAID description being in accordance with survey of Thomas A. Neff, Registered Surveyor, dated October 14, 1966. TRACT NO.2 - ALL THAT CERTAIN tract of land situate in the BOROUGH OF MOUNT HOLLY SPRINGS, Cumberland County, Pennsylvania, bounded and described as follows, pursuant to a survey by Thomas A. Neff, Registered Surveyor, on October 14, 1966: BEGINNING at a stake the intersection of the northern line of South Street and the eastern line of a public alley; thence by the eastern line of said alley, North thirty-nine (39) degrees twenty- two (22) minutes West, fifty (50) feet to a stake; thence by land now or formerly of J.W. Odell, North forty-nine (49) degrees fifty-one (51) minutes twenty (20) seconds East, eighty-seven; and eighty-one one-hundredths (87.81) feet to a stake; thence South thirty-nine (39) degrees twenty two (22) minutes East, fifty (50) feet to a stake on the northern line of South Street; thence by the northern line of said street, South forty-nine (49) degrees fifty-one (51) minutes twenty (20) seconds West, eighty-seven and eighty-one one-hundredths (87.81) feet to the place of BEGINNING. BEING the same premises which James R. Baughman and Doris L. Baughman, his wife, by Deed bearing date the 2nd day of may, 1994, and recorded in the Office of the Recorder of Deeds in and for Cumberland County, Pennsylvania, on the 11' day of May, 1994, in Record Book 105, page 182, granted and conveyed unto Alfred C. Sheaffer and Ovetta L. Sheaffer, his wife. TAX MAP (23) 32-2336-113 BEING known as 14 East Street, Mount Holly Springs, PA 17065 . LAW OFFICES OF GREGORY JAVARDIAN BY: GREGORY JAVARDIAN INDENTIFICATION NO. 55669 44 SECOND STREET PIKE SUITE 101 SOUTHAMPTON, PA 18966 (215) 942-9690 IMC MORTGAGE COMPANY V. Plaintiff ALFRED C.SHEAFFER OVETTA L. SHEAFFER Defendant(s) COURT OF COMMON PLEAS CUMBERLAND COUNTY NO. 99-4715 NOTICE OF SHERIFF'S SALE OF REAL PROPERTY TO: ALFRED C. SHEAFFER OVETTA L. SHEAFFER 14 EAST STREET MOUNT HOLLY SPRINGS, PA 17065 Your house (Real Estate) at 14 EAST STREET, MOUNT HOLLY SPRINGS, PA 17065, is scheduled to be sold at Sheriffs Sale on Monday, MARCH 1. 2000 at 10:00 A.M., in the Commissioner's Hearing Room located on the Td Floor of the Cumberland County Courthouse, 1 Courthouse Square, Carlisle, Pennsylvania to enforce the Court Judgment of 84.694.97 obtained by IMC MORTGAGE COMPANY, against you. NOTICE OF OWNER'S RIGHTS YOU MAY BE ABLE TO PREVENT THIS SHERIFF'S SALE To prevent this Sheriffs Sale you must take immediate action: 1. The sale will be canceled if you pay to Gregory Javardian, the back payments, late charges, costs and reasonable attorney's fees due. To find out how much you must pay, you may call Gregory Javardian at telephone (215) 942-9690. 2. You may be able to stop the sale by filing a petition asking the Court to strike or open the Judgment, if the Judgment was improperly entered. You may also ask the Court to postpone the sale for good cause. 3. You may also be able to stop the sale through other legal proceedings. You may need an attorney to assert your rights. The sooner you contact one, the more chance you will have of stopping the sale. (See notice on page two of how to obtain an attorney). I . If the Sheriffs Sale is not stopped, your property will be sold to the highest bidder. You may find out the bid price by calling Gregory Javardian, Esquire at telephone (215) 942-9690. 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 the 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 Gregory Javardian, Esquire at telephone (215) 942- 9690. 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 house. A schedule of distribution of the money bid for your house will be filed by the Sheriff. This schedule will state who will be receiving that money. The money will be paid out in accordance with this schedule unless exceptions (reasons why the proposed distribution is wrong) are filed with the Sheriff within (10) days. 7. You may also have other rights and defenses, or ways of getting your house back, if you act immediately after the sale. 11 WN Ub. IF O NOT HAVE A LAWYER OR CANNOT AFFORD ON E. GO TO 3LEPHONE THE OFFrrF r re rcn ,,.. __ __ - CAN GET LEGAL HELP CUMBERLAND BAR ASSOCIATION LAWYER REFERRAL AND INFORMATION SERVICE 4 - FLOOR, CUMBERLAND COUNTY COURTHO_ i_1_CF_ CARLISLE PA 17013 (717) 240-6200 TRACT NO. 1 - ALL THAT CERTAIN tract of ground with the improvements thereon erected situate in the BOROUGH OF MOUNT HOLLY SPRINGS, Cumberland County, Pennsylvania, bounded and described as follows: BEGINNING at an iron pipe at corner of lands now or formerly of J.W. Odell and edge of East Street; thence South thirty-nine (39) degrees twenty-two (22) minutes East, a distance of fifty (50) feet along edge of East Street to a stake on the edge of said street; thence South forty-nine (49) degrees fifty-one (51) minutes twenty (20) seconds West, a distance of ninety (90) feet along South Street to a stake and corner of lands now or formerly of Norman D. Kuhn, et ux; thence North thirty-nine (39) degrees twenty-two (22) minutes West, a distance of fifty (50) feet along lands now or formerly of Norman D. Kuhn et ux, to a stake and corner of lands now or formerly of J.W. Odell; thence North forty-nine (49) degrees fifty-one (51) minutes twenty (20) seconds East, a distance of ninety (90) feet along lands now or formerly of J. W. Odell to an iron pipe at the edge of East Street and corner of lands now or formerly of J.W. Odell and place of BEGINNING. SAID description being in accordance with survey of Thomas A. Neff, Registered Surveyor, dated October 14, 1966. TRACT NO. 2 - ALL THAT CERTAIN tract of land situate in the BOROUGH OF MOUNT HOLLY SPRINGS, Cumberland County, Pennsylvania, bounded and described as follows, pursuant to a survey by Thomas A. Neff, Registered Surveyor, on October 14, 1966: BEGINNING at a stake the intersection of the northern line of South Street and the eastern line of a public alley; thence by the eastern line of said alley, North thirty-nine (39) degrees twenty- two (22) minutes West, fifty (50) feet to a stake; thence by land now or formerly of J.W. Odell, North forty-nine (49) degrees fifty-one (51) minutes twenty (20) seconds East, eighty-seven; and eighty-one one-hundredths (87.81) feet to a stake; thence South thirty-nine (39) degrees twenty two (22) minutes East, fifty (50) feet to a stake on the northern line of South Street; thence by the northern line of said street, South forty-nine (49) degrees fifty-one (51) minutes twenty (20) seconds West, eighty-seven and eighty-one one-hundredths (87.81) feet to the place of BEGINNING. BEING the same premises which James R. Baughman and Doris L. Baughman, his wife, by Deed bearing date the 2n1day of may, 1994, and recorded in the Office of the Recorder of Deeds in and for Cumberland County, Pennsylvania, on the 11" day of May, 1994, in Record Book 105, page 182, granted and conveyed unto Alfred C. Sheaffer and Ovetta L. Sheaffer, his wife. TAX MAP (23) 32-2336-113 BEING known as 14 East Street, Mount Holly Springs, PA 17065 WRIT OF EXECUTION and/or ATTACHMENT COMMONWEALTH OF PENNSYLVANIA) NO, 99-4715 CIVIL 1P Term COUNTY OF CUMBERLAND) CIVIL ACTION • LAW TO THE SHERIFF OF Cnmhprl and COUNTY: To satisfy the debt, interest and costs due IMC Mortgage Company from Alfred C. Sheaffer and Ovetta L. Sheafferr 14 East Street, Mt. Holly Springs, PA 17065 DEFENDANT(S) (1) You are directed to levy upon the property of the defendant(s) and to sell- property at 14 East _strept Mount Holly Springs PA 17065 (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) istare enjoined from paying any debt to or for the account of the defendant(s) and from delivering any property of the defendant(s) or otherwise disposing thereof; (3) If property of thedefendant(s) not levied upon an subject to attachment is found inthe possession of anyone other than a named garnishee, you are directed to notify hirrvher that he/she has been added as a garnishee and is enjoined as above stated. Amount Due $84,694.97 L L $.50 Interest Due Prothy $1.00 Atty's Comm % Other Costs Atty Paid $115.72 Plaintiff Paid Date: December 15, 1999 REQUESTING PARTY: Curtis R. Prothonotary, Civil Division DeputyName Gregory Javardian, Esq. Address: 44 Second Street Pike, Suite Southampton, PA 18966 Attorney for. Plaintiff Telephone: 215-942-9690 Supreme Court ID No. 55669 3 Y interest in the real proporl'i Cumber 1 Joh?r 4y; Pa., /\?II_I:u'li i..:: ..' i,- f???(A6GI %BlJfL/la?G and wiol th:s writ 'ri'd by '.vit, , E5. ??? F? n? °,? X30 O (ED G a LAW OFFICES OF GREGORY JAVARDIAN BY: GREGORY JAVARDIAN, ESQUIRE ATTORNEY I.D. #55669 44 Second Street Pike, Suite 203 Southampton, PA 18966 (215) 942-9690 4501 ERSKINE ROAD SUITE 50 BLUE ASH, OH 45243 Plaintiff VS. ALFRED C. SHEAFFER OVETTA L. SHEAFFER 14 EAST STREET MOUNT HOLLY SPRINGS, PA 17065 Defendant(s) for Plaintiff TRIAL DIVISION CUMBERLAND COUNTY No. W - -4/ da"?l NOTICE You have been sued in Court. If you wish to defend against the claims set forth in the following pages, you must take action within twenty (20) days after this Complaint and notice are served, by entering a written appearance personally or by attorney and filing in writing with the court your defense 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 NOTICE 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 Bar Association 2 Liberty Avenue Carlisle, PA 17013 717-249-3166 W###W##W+###W#W##W#########w**t4##W#W###W*############+WW#W#+#w#WWt#**#W NOTICE PURSUANT TO FAIR DEBT COLLECTION PRACTICES ACT w#w#+##+w#Ww+W*W#+##+*#+#W#W##tt+##*#w#i#W#+#Ww*+Ww#Ww##W##W#w#W###y,WW*# This is an attempt to collect a debt and any information obtained will be used for the purpose. 2. Unless you dispute the validity of this debt, or any portion thereof, within thirty (30) days after receipt of this notice, the debt will be assumed to be valid by our offices. 3. If you notify our offices in writing within thirty (30) days of receipt of this notice that the debt, or any portion thereof, is disputed, our offices will provide you with verification of the debt or copy of the judgment against you, and a copy of such verification or judgment will be mailed to you by our offices. 4. If you notify our offices in writing within thirty (30) days of receipt of this notice, our offices will provide you with the name and address of the original creditor, if different from the current creditor. LAW OFFICES OF GREGORY JAVARDIAN BY: GREGORY JAVARDIAN ID# 55669 44 SECOND STREET PIKE SUITE 203 SOUTHAMPTON, PA 18966 (215) 942-9690 Attorney for Plaintiff IMC MORTGAGE COMPANY 4501 ERSKINE ROAD SUITE 50 BLUE ASH, OHIO 45243 Plaintiff(s) VS. COURT OF COMMUN FLI CUMBERLAND COUNTY No. ALFRED C.SHEAFFER OVETTA L. SHEAFFER 14 EAST STREET MOUNT HOLLY SPRINGS, PA 17065 Defendant(s) COMPLAINT IN MORTGAGE FORECLOSURE CIVIL ACTION MORTGAGE FORECLOSURE 1. IMC Mortgage Company, (hereinafter referred to as "Plaintiff') is an Institution, conducting business under the Laws of the Commonwealth of Pennsylvania and brings this action to foreclosure the mortgage between Alfred C. & Ovetta L. Sheaffer, Mortgagor(s) (hereinafter referred to as "Defendant") and itself as Mortgagee by assignment. Said Mortgage was dated May 21, 1998 and was recorded in the Office of the Recorder of Deeds and Mortgages in Cumberland County in Mortgage Book 1456 page 935. A copy of the Mortgage is attached and made a part hereof as Exhibit `A'. 2. The Mortgage is secured by Defendant(s) Note dated May 21, 1998 in the amount of $73,100.00 payable to Plaintiff in monthly installments with an interest rate of 10.85%. A copy of the Note is attached hereto and made a part hereof as Exhibit ". 3. The land subject to the mortgage is: 14 East Street, Mount Holly Springs, PA 17065. 4. The defendant(s), Alfred C. & Ovetta L. Scheaffer are the real owner(s) of the land subject to the mortgage and the Defendants' address is : 14 East Street, Mount Holly Springs, PA 17065. 5. The Mortgage is now in default due to the failure of the Defendant(s) to make payments as they become due and owing. The following amounts are due: Principal Balance: $72,934.71 Interest to 4/30/99 $ 3,340.61 Accum. Late charges $ 240.73 NSF fees $ 126.88 Insurance Paid $ 1,035.00 Attorney Fee/cost $ 3,700.00 TOTAL: $81,377.93 plus interest from 4/31/99 at $21.68 per day, costs of suit and attorney fees. 6. In accordance with the provisions of the Act of January 30, 1974, P.L. 13 No. 6, Section 403 (41 P.S. 403), a Notice of Intention to Foreclose is not required as this loan is in excess of $60,000.00. A Notice of Homeowners' Emergency Mortgage Assistance is applicable and was sent June 17, 1999. The Defendant(s) have not cured the default. WHEREFORE, Plaintiff requests the court enter judgment in Mortgage Foreclosure for the sale of the mortgaged property in Plaintiffs favor and against the Defendant(s), in the sum of $81,377.93 together with the interest from 4/31/99 at $21.68 per day, costs of suit and attorney fees. Law offices of Gregory Javam BY: G' G?- }z? R) JAVARDIAN ,o,oooa3ss NOTE Cda 40?99/ o May 21, 1998 York Pennsylvania (Den) friLY) [state) 14 EAST STREET , NT HOLLY SPRINGS, PA 17065 (Pmpmy Addreral 1. BORROWER'S PROMISE TO PAY In remm for a loan that I have received, I promise to pay U.S. $ 73,100.00 (this amount is called "principal'D, plus interest, to the order of the Lender. The Lender is MORTGAGE LENDERS NETWORK USA, INC. . I understand that the Lender may transfer this Note. The Lender or anyone who takes this Note by transfer and who is entitled to receive payments under this Note is called the "Note Holder." 2. INTEREST Interest will be charged on unpaid principal until the full amount of principal has been paid. I will pay interest at a yearly rate of 10.8500 %. The interest rate requited by this Section 2 is the rate I will pay both before and after any default described in Section 6(B) of Otis Note. 3. PAYMENTS (A) Time and Place of Payments I will pay principal and interest by making payments every month. I will make my monddy payments on the 27th day of each month beginning on dune 27 1998 . I will make these payments every month until I have paid all of the principal and interest and any other charges described below that I may owe under this Plots. My monthly payments will be applied to interest before principal. If, an May 27 .2028 1 stUl owe amounts under this Note, I will pay those amounts in full on that date, which is called the "Maturity Date." I will make my monthly payments at MIDDLESEX CORP. CENTER 11TH FL, 213 COURT ST., MIDDLETOWN CT 06457 or at a different piece if required by the Note Holder. (B) Amount of Monthly Payments My monthly payment will be in the amount of U.S. $ 687.88 4. BORROWER'S RIGHT TO PREPAY I have the right to make payments of principal at any time before they are due. A payment of principal only is known as a 'prepayment" When I make a prepayment, I will tell the Note Holder in writing that I am doing so. I may make a full prepayment or partial prepayments without paying any prepayment charge. The Note Holder will use all of my prepayments to reduce the amount of principal that I owe under this Note. If I make a partial prepayment, there will be no changes in the due date or in the amount of my monthly payment unless the Note Holder agrees in writmgylo those changes. 5. LOAN CHARGES If a law, which applies to this loan and which sets maximum loan charges, is finally interpreted so that the interest or other loan charges collected or to be collected in connection with this loan exceed the permitted limits, then: (i) any such loan charge shall be reduced by the amount necessary to reduce the charge to the paxniaed limit; and (b) any sums already collected from me which exceeded permitted limits will be refunded to me. The Note Holder may choose to make this refund by reducing the principal I owe under this Note or by making a direct payment to me. if a refund reduces principal, the reduction will be treated as a partial prepayment. 6. BORROWER'S FAILURE TO PAY AS REQUIRED (A) Late Charge for Overdue Payments If the Note Holder has not received the full amount of any monthly payment by the end of 10 calendar days after the date it is due, I will pay a late charge to the Note Holder. The amount of the charge will be 5.0000 % of my overdue payment of principal and interest I will paythis late charge promptly but only onceon each hatepayment. (B) Default If I do not pay the full amount of each monthly payment on the date it is due, r will be in default. MULTISTATE FIXED RATE NOTE-Single Family - FNMAIFHLMO Uniform Instrument 40-SR rytosl.ox Form 3200 12/83 is Amended ?{5519?1? 9 M oft aTGAGE FORMS -(018)797.8 Inhims?)5a,Mr- 2- f Illlf II IIII?I?III?I?III?4I? VIII Pa ? 1910004395 (C) Notice of Default If I am in default, the date. the Note Holder may r I owe on that amount. That t (D) No Waiver By No Even if, at a time whet Note Holder will still have d (E) Payment of Note I If the Note Holder has back by me for all of its cc include, for example, reasom 7. GIVING OF NnTRrr..R as e Holder may send me a written notice telling me that if I do not pay the overdue amoam by a certain 're too to pay immediately the full amount of principal which has not been paid and all the interest that must be az least 30 days after the date on which the notice is delivered or mailed to me. folder m in default, the Note Holder does not require me to pay immediately in full as described above, the ght to do so if I am in default at a later time. ler's Costs and Expenses rind me to pay immediately in full as described above, the Note Holder will have the right to be paid and expenses in enforcing this Note to the extent not prohibited by applicable law. Those expenses attorneys' fees. Unless applicable law requires a different method, any notice that must be given to me under this Note will be given by delivering it of by mailing it by first class mail to me at the Property Address above or at a different address if I give the Note Holder a notice of my different address. Any notice that most be given to the Note Holder under ft Note will be given by mailing it by first class marl to the Note Holder at the address stated in Section 3(A) above or at a different address if I am given a notice of that different address. S. OBLIGATIONS OF PERSONS UNDER THIS NOTE If more than Note, inoludin n: person signs this Note, each person is fully and personally obligated to keep all of the promises made in this g the promise pay the full amount owed. Any person who is a guarantor, surety or endorser of this Note is also obligated to do these things. Any person who takes over drew obligations, including the obligations of a guarantor, surety or endorser of this Note, is also obligated to keep all of the promises made in this Note. The Note Holder may enforce its rights under this Note inst each owed under [per Note. individually or against all of us together. This means that any one of us may be required to pay all of the amounts 9. WAIVERS I and any other person who has obligations under this Note waive the rights of presentment and notice of dishonor. "Presentment" means the right to require the Note Holder to demand payment of amounts due. "Notice of dishonor" means the right to UNIFORM Sote EHoCURED giveOTE notice to other persons that amounts due have not been paid. This Note is a uniform instrument with limited variations in some jurisdictions. In addition to the protections given to the Note Holder under ft Note, a Mortgage, Deed of Trust or Security Deed (die "Security Insrumene ), dated the satire date as this Note, protects the Note Holder from possible losses which might result if I do not keep the promises which I make in this Note. That Security Instrument describes how and under what conditions I may be required to [Hake immediate payment in full of all amounts I owe under this Note. Some of those conditions are described as follows: Transfer of the Property or a Beneficial Interest in Borrower. If all or any part of the Property or any interest in it is sold or transferred (or if a beneficial interest in Borrower is sold or transferred and Borrower is not a natural person) without Lender's prior written consent, Lender may, at its option, require immediate payment in full of all sums secured by this Security Instrument However, this option shall not be exercised by Lender if exercise is prohibited by federal law as of the date of this Security Instrument If Lender exercises this option, Lender shall give Borrower notice of acceleration. The notice shall provide a period of noc less than 30 days from the date the notice is delivered or mailed within which Borrower must pay all sums secured by this Security Instrument If Borrower fails to pay these sums prior to the expiration of this period, Lender may invoke any remedies permitted by this Security Instrument without further =or ' d on Borrower. WITNESS THE HAND(S) AND SEAL(S) OF TIP UNDERSIGIgF.De/t4IIsA ,?lfe/4??to/1 (Sean `..-?j/J,J??GI?itC.t/Y? / /?• J ALF EO U SHEAFFER (Seal) -aomwer OVETTA L SHEAFFER germwer SSN: 205-52-3321 SSN: 196-56-4305 (Seal) (Seal) SSN: •Borewer SSN: •Homwer (Sign Original Only) 4ai 511 t2tosl.oz Paas Z o12 Form 320012183 4 1010004396 F.R a7 C:.4FY?'q???s`.! t''it i4tiE Parcel Number: (Space Above This fine For Recording Data) MORTGAGE THIS MORTGAGE ("Security Instrument") is given on May 21 , 1998 .The mortgagor is ALFRED C SHEAFFER OVETTA L SHEAFFER C'Borrower"). This Security Instrument isgivcnto MORTGAGE LENDERS NETWORK USA, INC. which is organized and existing under the laws of CONNECTICUT and whose aritimsis MIDDLESEX CORP. CENTER 11TH FL, 213 COURT ST., MIDDLETOWN CT 06457 ("Lender'). Borrower owes LAonder the principal sum of Seventy-Three Thousand One Hundred and No/100 ------- ------------------- ' • Dollars (U.S. $ 73,100.00 I1ds debt is evidenced by Borrower's note dated the same date as this Security Instttnnent ('Note'), which provides for monthly payments, with the full debt, if not paid earlier, due and payable on ,v1ay 27, 2028 . This Security Instrument secures to Lender: (a) the repayment of the debt evidenced by the Note, with interest, and all renewals, extensions and modifications of the Note; (b) the payment of all other sums, with interest, advanced under paragraph,7 to protect the security of this Security Instrument; and (c) the performance or Borrower's covenants and agreements under this Security Instrument and the Note. For this purpose, Burrower does hereby mortgage, grant and convey to Lender the following described property located in CUMBERLAND County, Pennsylvania: SEE ATTACHED SCHEDULE A which has (headdress of 14 EAST STREET MT HOLLY SPRINGS Pennsylvania 17065 IZipCudel ("Property Address'?; Isucct, cityl. PENNSYLVANIA - Single Family - FNMAIFHLMC UNIFORM INSTRUMENT Form7939 9190 (ID -OH(PA)rmo) Amended 12197 ^- -,. VMP MORTGAGE FORMS •(eool'u'iJ2W A7 D a a EXHIBIT A TRACT NO. 1 - ALL THAT CERTAIN tract of ground with the improvements thereon erected situate in the BOROUGH OF MOUNT HOLLY SPRINGS, Cumberland County, Pennsylvania, bounded and described as follows: - BEGINNING at an iron pipe at corner of lands now or formerly of J. W. Odell and edge of East street; thence South thirty-nine (39) decrees twenty-two (22) minutes East, it distance of fifty (50) feet along edge of East Street to a stake on the edge of said street; thence South forty-nine (49) degrees fifty-one (51)., minutes twenty (20) seconds West, a distance of ninety (90) feet along South Street to a stake and corner of lands now or formerly of Norman D. Kuhn, et ux; thence North thirty-nine (39) degrees twenty-two (22) minutes West, a distance of fifty (50) feet along lands now or formerly of Norman D. Kuhn et ux, to a stake and corner of lands now or formerly of J. W. Odell; thence North forty-nine (49) degrees fifty-one (SI) minutes twenty (20) seconds East, a distance of ninety (90) feet along lands now or formerly of J. W. Odell to an iron pipe at the edge of East Street and corner of lands now or formerly of J. W. Odell and place of BEGINNING. SAID description being in accordance with survey of Thomas A. Neff, Registered surveyor, dated October 14, 1966. TRACT NO. 2 - ALL THAT CERTAIN tract of land situate in the BOROUGH OF MOUNT HOLLY SPRINGS, Cumberland County, Pennsylvania, bounded and described as follows, pursuant to a survey by Thomas A. Neff, Registered Surveyor, on October 14, 1966: BEGINNING at a stake the intersection of the northern line of South Street and the eastern line of a public alley; thence by the eastern line of said alley, North thirty-nine (39) degrees twenty-two (22) minutes west, fifty (50) feet to a stake; thence by land now or formerly of J. W. Odell, North fcrty-nine (49) degrees fifty-one (51) minutes twenty (20) seconds East, eighty-seven and eighty-one one-hundredths (87.61) feet to a stake; thence South thirty-nine (39) degrees twenty-two (22) minutes East, fifty (50) feet to a stake on the the northern line of. South Street; thence by the northern line of said street, South forty-nine (49) degrees fifty-one (51) minutes twenty (20) seconds West, eighty-seven and eighty-one one-hundredths (87.81) feet to the place of BEGINNING. BEING the same premises which James R. Baughman and Doris L. Baughman, his wife, by Deed bearing date the 2nd day of May, 1994, and recorded in the office of the Recorder of Deeds in and for Cumberland County, Pennsylvania, on the ;lth day of May, 1994, in Record Book 105, Page 182, granted and conveyed unto Alfred C. Sheaffer and Ovetta L. Sheaffer, his wife. TAX MAP (23) 32-2336-113 40 M 1010004396 and all easements, appurtenances, and TOGETHER WITH all the improvements now or hereafter erected on the property, fixtures now or hereafter a part of the property. AB replacements and additions shall also be covered by this Security Instrument. All of the foregoing is referred to in this Security instrument as the "Property." BORROWER COVENANTS that Borrower is lawfully seised of the estate hereby conveyed and has the tight to mortgage, grant and convey the Property and that the Property is unencumbered, except for encumbrances of record. Borrower warrants and the property against all claims and demands, subject to any encumbrances of record. wrll defend generally the title to THIS SECURITY INSTRUMENT combines uniform covenants for national use and non-uniform covenants with limited variations by jurisdiction to constitute a uniform security instrument covering real property. UNIFORM COVENANTS. Borrower and Lender covenant and agree as follows: 1. Payment of Principal and Interest; Prepayment and Late Charges. Borrower shall promptly pay when due the principal of and interest on the debt evidenced by the Note and any prepayment and late charges due under the Nate. 74 Funds for Taxes and Insurance. Subject to applicable law or to a written waiver by Lender, Borrower shall pay to Lender on Otc day monthly payments are due under the Nom, until the Note is paid in full, a sum CFunds") for: (a) yearly taxes and assessments which may attain priority over this Security Instrument as a Ben on the Property; (b) Yearly leasehold payments or ground rents on the Property. if any, (e) yearly hazard or proper tnsuraacepremiums; (d) yearly flood insurance premiums, if any; (e) yearly mortgage insurance premiums, if any; and (f) any sums payable by Borrower to Lender. in accordance with the provisions of paragraph S, in lieu of the payment of mortgage insurance premiums. These items are called "Escrow Items." Lender may, at any time, collect and hold Funds in an amount not to exceed the maximum amount a lender for a federally related mortgage loan may require for Borrower's escrow account under the federal Real Estate Settlement Procedures Act of 1974 as amended from time to time, 12 U.S.C. Section 2601 et seq. ('RESPA"), unless another law that applies to the Funds sets a lessor amount If so. Lender may, at any time, collect and hold Funds in an amount not to exceed the lesser amount. Leader may estimate the amount of Funds due on the basis of current data and reasonable estimates of expenditures of future Escrow Iterus or otherwise in accordance with applicable law. The Funds shall be held in an institution whose deposits are insured by a federal agency, Instrumentality, or entity ciEsumw Lender, if Lender is such an institution) or in any Federal Home Loan Bank. Lender shag apply the pay the Items. Leader may not charge Borrower for holding and applying the Funds, annually analyzing the escrow account, or verifying the Escrow Items, unless Lender pays Borrower interest on the Funds and applicable law permits Lender to make such a charge. However. Lender may require Borrower to pay a one-time charge for an independent mad estate tax reporting service used by Leader in connection with this loan, unless applicable law provides otherwise. Unless an agreement is made or applicable law requires interest to be paid, Lender shall not be required to pay Borrower any interest or earnings on the Funds. Borrower and Leader may agree in writing, howcvcr, that interest shall be paid on the Funds. Lander shag give to Borrower, without charge, an annual accounting of the Funds, showing credits and debits to the Funds and the purpose for which each debit to the Funds was applicable Instrument. made. The Funds are pledged as additional security for all sum secured held by is Security shag account to Borrower for If the Funds held by Lender exceed the amounts permitted the excess Funds in accordance with the requirements of applicable law. If the amount of the Funds held by Leader at any time is not sufficient to pay the Escrow Items when due, Lender may so notify Borrower in writing, and, in such case Borrower shall pay to Lender the amount necessary to make up the deficiency. Borrower shall make up the deficiency in no more than twelve monthly payments, at Lender's sole discretion. r any Funds Upon payment in full of all sums secured by this Security Instrument, Lender shall promptly fund totB `rro er sale of the held by Lender. If, under paragraph 21, Lender shall acquire or sell the Property. Lender, p acq property, shall apply any Funds held by L.cader at the time of acquisition or sale as a credit against the sums secured by this Security Instrument. 3. Application of Payments. Unless applicable law provides otherwise, all payments received by Lender under paragraphs 1 and 2 shall be applied: first, to any prepayment charges due under the Note; second, to amounts payable under paragraph 2; third, to interest duc; fourth, to principal due; and last, to any late charges due under the Note. 4. Charges; Liens. Borrower shall pay all taxes, assessments. charges, lines and impositions attributable to the Property which may attain priority over this Security Instrument, and leasehold payments or ground rents, if any. Borrower shall pay these obligations in the manner provided in paragraph 2, or if not paid in that manner, Borrower shall pay them on time directly to the person owed payment Borrower shall promptly furnish to Lender all notices of amounts to be paid under this paragraph. If Borrower makes these payments directly. Borrower shall promptly furnish to Lender receipts evidencing the payments. Borrower shall promptly discharge any lien which has priority over this Security Instrument unless Borrower (a) agrees in writing to the payment of the obligation secured by the lien in a manner acceptable , b) conwts in good faith the Hen an operate to prevent the by, or defends against enforcement of the lien in, legal proceedings which in satisfactory the Lender's Lender subordinating the lien to enforcement of the Ben; or (c) secures from the holder of the lien an agreement which may attain priori t over this this Security Instrument. If Lender determines that any part of Ole Property is subject a lien Security Instrument, Lender may give Borrower a notice identifying the lien. Borrower shall satisfy the lien or take one or more of the actions set forth above within 10 days of the giving of notices Form aoas sl9Q? J -6H(PAliaatot Pa9•2ale m 1010004396 payments may no longer be required, at the option of Lender, if mortgage insurance coverage (in the amount and for the period that Leader requires) provided by an insurer approved by Lender again becomes available and is obtained. Borrower shall pay the premiums required to maintain mortgage insurance in effect, or to provide a loss reserve, until the requirement for mortgage insurance ends in accordance with any written agreement between Borrower and Lender or applicable law. 9. Inspection. Lender or its agent may make reasonable entries upon and inspections of the Property. Lender shall give Borrower notice at the time of or prior to an inspection specifying reasonable cause for the inspection. 10. Condemnation. The proceeds of any award or claim for damages, direct or consequential, in connection with any condemnation or ether taking of any part of the Property, or for conveyance in lieu of condornnadon, are hereby assigned and shall be paid to Lender. In the event of a total taking of the Property, the proceeds shall be applied to the sums secured by this Security Instrument, whether or not then due, with any excess paid to Borrower. In the event of a partial taking of the Property in which the fair market value of the Property immediately before the taking is equal to or greater than the amount of the sums secured by this Security instrument immediately before the taking, unless Borrower and Lender otherwise agree in writing, the sums secured by this Security instrument shall be reduced by the amount of the proceeds multiplied by the following fraction: (a) the total amount of the sums secured immediately before the taking, divided by (b) the fair market valve of the Property immediately before the taking. Any balance shall be paid to Borrower. In the event of a partial taking of the Property in which the fair market vahm of the Property immediately before the taking is less than the amount of the sums secured immediately before the taking, unless Borrower and Lender otherwise agree in writing or unless applicable law otherwise provides, the proceeds shall be applied m the sums secured by this Security Instrument whether or not the sums are then due. if the Property is abandoned by Borrower, or if, after notice by Lender to Borrower that the condemnor offers to make an award or settle a claim for damages, Borrower fails to respond to Lender within 30 days after the date the notice is given, Leader is authorized to collect and apply the proceeds, at its option, either to restoration or repair of the Property or to the stints secured by ttris Security instrument, whether or not then due. Unless Lender and Borrower otherwise agree in writing, any application of proceeds to principal shall not extend or postpone the due date of the monthly payments referred to in paragraphs 1 and 2 or change the amount of such payments. 11. Borrower Not Released; Forbearance By Leader Not a Waiver. Extension of the time for payment or modification of amordradcn of the sums secured by this Security Instrument granted by Lender to any successor in interest of Borrower shall not operate to release the liability of the original Borrower or Borrower's successors in interest. Lender shall not be required to commence proceedings against any successor in interest or refuse to extend time for payment at otherwise modify amortization of the sums secured by this Security Instrument by mason of any demand made by the original Borrower or Borrower's successors in interest. Any forbearance by Lender in exercising any right or remedy shall not be a waiver of or preclude the exercise of any right or rcmody. 12. Successors and Assigns Bound; Joint and Several Liability; C"guem The covenants and agreements of this Security Instrument shall bind and benefit the successors and assigns of Lender and Borrower, subject to the provisions of paragraph 17. Borrower's covenants and agreements shall be joint and several. Any Borrower who co-signs this Security Instrument but does not execute the Note: (a) is co-signing this Security Instrument only to mortgage, grant and convey that Borrower's interest in the Property under the terms of this Security Instrument; (b) is not personally obligated to pay the sours secured by this Security Instrument; and (c) agrees that Lender and any other Borrower may agree to extend, modify, forbear or make any accommodations with regard to the terms of this Security Instrument or the Nate without that Borrowers cerise= 13. Loan Charges. If the loan secured by this Security Instrument is subject to a law which sets' maximum loan charges, and that law is finally interpreted so that the interest or other loan charges collected or to be collected in connection with the loan exceed the permitted limits, then: (a) any such loan charge shall be reduced by the amount necessary to reduce the charge to the permitted limit; and (b) any sums already collected from Borrower which exceeded permitted limits will be refunded to Borrower. Lender may choose to make this refund by reducing the principal owed under the Note or by making a direct payment to Borrower. If a refund reduces principal, the reduction will be treated as a partial prepayment without any prepayment charge tinder the Note. 14. Notices. Any notice to Borrower provided for in this Security Instrument shall be given by delivering it or by mailing it by fast class mail unless applicable law requires use of another method. The notice shag be directed to the Property Address or any other address Borrower designates by notice to lender. Any notice to Lender shall be given by first class mail to Lender's address stated herein or any other address Lcnder designates by notice to Borrower. Any notice provided for in this Security Instrument shall be deemed to have been given to Borrower or Lender when given as provided in this paragraph. 15. Governing Law; Severability. This Security Instrument shag be governed by federal law and the law of the jurisdiction in which the Property is located. In the event that any provision or clause of this Security Instrument or the Note conflicts with applicable law, such conflict shall not affect other provisions of this Security Instrument or the Note which can be given effect without the conflicting provision. To this end the provisions of this Security Instrument and the Note are declared to be severable. Form 30 9 /90 -M(PA)rmo) Pa9o4 of 6 iniuab- 1010004395 5. Hazard or Property Insurance. Borrower shell keep the Improvements now existing or hereafter erected on the Property insured against loss by fire, hazards Included within the term "extended coverage" and any other hazards, including floods or flooding, for which Lender requires insurance. This insurance shall be maintained In the amounts and for the periods that Lender requires. The insurance carrier providing the Insurance shall be chosen by Borrower subject to Lender's approval which shall not be unreasonably withheld. If Borrower fails to maintain coverage described above, Lender may, at Lender's option, obtain coverage to protect Lender's rights in the Property in accordance with paragraph 7. AB insurance policies and renewals shall be acceptable to Lender and shall Include a standard mortgage clause. Lender shag have the right to bold the politics and renewals. If Lender requires, Borrower shall promptly give to Lender all receipts of paid prcmfums and renewal notices. In the event of loss. Borrower shall give prompt notice to the insurance carrier and Lender. Lender may make proof of loss if not made promptly by Borrower. Unless Lender and Borrower otherwise agree in writing. Insurance proceeds shag be applied to restoration or repair of the Properly damaged, if the restoration or repair Is economically feasible and Lender's security Is not lowened. if the restoration or repair is not economically feasible or Lender's security would be lessened, the Insurance proceeds shall be applied to the sums secured by this Security Instrument, whether or not then due, with any excess paid to Borrower. it Borrower abandons the Property, or does not answer within 30 days a notice from Lender that the insurance carrier his offend to settle a claim, then Leader may collect the insurance proceeds. Lender may use the proceeds to repair or rernro the Property or to pay sums secured by this Security Instrument, whether or not then due.7be 30-day period will begin when the notice Is given. Unless Lender and Borrower otherwise agree in writing, any application of proceeds to principal shall not extend or postpone the due date of the monthly payments referred to in paragraphs 1 and 2 or change die amount of the payments. If under paragraph 21 the Property is acquired by Lender. Borrower's right to any Insurance policies and proceeds resulting from damago to the Property prior to the acquisition shall pass to Lender to the extent of the sums secured by this Security Instrument immediately prior to the acquisition. 6. Occupancy, Preservation, Maintenance and Protection of the Property; Borrower's Loan Application; Leaseholds. Borrower shall occupy, establish, and use the Property as Borrower's principal residence within sixty days after the execution of this Security Instrument and shall continuo to occupy the Property as Borrower's principal rtuidcace for at least one year after the date of occupancy, unless Lender otherwise agrees in writing, which consent shall not be unreasonably withheld, or unless extenuating circamsmntes exist which are beyond Borrower's control. Borrower shall not destroy, damage or Impair the Property, allow the Property to deteriorate, or commit waste on the Property. Borrower shall bu in default if any forfeiture action or proceeding, whether civil or criminal, is begun that in Lcrhderhi goad faith judgment could result In forfeiture of tho Property or otherwise materially impair the lien created by this Security Instrument or Lender's security Interest Borrower may cure such a default and reinstate, as provided in paragraph 18, by causing tie action or proceeding to be dismissed with a ruling that, in Lender's good faith determination, precludes fodciiure of the Borrower's interest in the Property or other material impairment of the lien created by this Security Instrument or Lender's security Interest Borrower shall also be in default If Borrower, during the loan application process, gave materially false or inaccurate Informatun or statements to Lender (or failed to provide Lender with arry material information) in connection with the loan evidenced by the Note, including, but not limited to, representations concerning Borrower's occupancy of the Property as a principal residence. If this Security Instrument is on a leasehold. Borrower shall comply with all the provisions or the lease. If Borrower acquires fee due to the Property, the leasehold and the fee title shall not merge unless Lender agrees to the merger in writing. 7. Protection or Letsder's Rights in the Property. If Borrower falls to perform the covenants and agreements contained in this Security Instrument, or them is a legal proceeding that may signillcandy affect Lender's rights m the Property (such as a proceeding in bankruptcy, probate, for condemnation or forfeiture or to enforce laws or regulations), then Lender may do and pay for whatever is necessary to protect the value of the Property and Lender's rights in the Property. Lender's actions may include paying any sums secured by a lien which has priority over this Security Instrument, appearing in coon, paying reasonable attorneys' fees and entering on the Property to make repairs. Although Lender may take action under this paragraph 7, Lender does not have to do so. Any amounts disbursed by Lender under this paragraph 7 shall become additional debt of Borrower secured by this Security Instrument Unless Borrower and Lender agree to other tens or payment, these amounts shall bear interest from the date of disbursement at the Note rate and shall be payable, with interest. upon notice from Lender to Borrower requesting payment. S. Mortgage Insurance. If Lender required mortgage insurance as a condition of making the loan seared by this Security Instrument. Borrower shall pay the premiums required to maintain tie mortgnge insurance in effort If, for any reason, the mortgage insurance coverage required by Lendei lapses or ceases to be in effect, Borrower shall pay the premiums requited to obtain coverage substantially equivalent to the mortgage insurance previously In effect, at a cost substantagy equivalent to the cost to Borrower of the mortgage insurance previously in effect, from an alternate mortgage insurer approved by Leader. If substantially equivalent mortgage insurance coverage is not available, Borrower shall pay to Lender each month a sum equal to one•twelfth or the yearly mortgage Insurance premium being paid by Borrower when tihu insurance coverage lapsed or ceased to be in effect Lender will accept, use and rcWihh these payments as u loss reserve in lieu of mortgage Insurance. Loss reserve Form 30 4W -OH(PA) 104 tai P.0.3 of lnkltl.. ?dV 0 40t?004396 16. Borrower's Copy. Borrower shall be given one conformed copy of the Note and of this Security Instrument. 17. Transfer of the Property or a Beneficial Interest in Borrower. If all or any part of the Property or any interest in it is sold or transferred (or if a beneficial interest in Borrower is sold or transferred and Borrower is not a natural person) without Lender's prior written consent, Lender may, at its option, require immediate payment in full of all sums secured by this Security Instrument. However, this option shall not be exercised by Lender if exercise is prohibited by federal law as of the date of this Security InstnunenL If Lender exercises this option. Lender shall give Borrower notice of acceleration. The notice shall provide a period of not less than 30 days from the date the notice is delivered or mailed within which Borrower must pay all sums secured by this Security Instrument. If Borrower fails to pay these sums prior to the expiration of this period, Lender may invoke any remedies permitted by this Security Instrument without further notice or demand on Borrower. 18. Borrower's Right to Reinstate. If Borrower meets certain conditions, Borrower shall have the right to have enforcement of this Security Instrument discontinued at any time prior to the earlier of: (a) 5 days (or such other period as applicable loco tray specify for reinstatement) before sale of the Property ppursuant to any power of sale contained in this Security IrastrwaenC or (b) entry of a judgment enforcing this Security TnstrvmanL'Ihose condidons azethat Borrower. (a) pays Lender all swats which then would be due under d is Security Instrument and the Note as iC ne acceleration had occurred; (b) cures any default of any other covenants or agrcemena; (c) pays ail expenses incurred in enforcing this Security Insnumen4 including, but not limited te, reasonable attomcys' fees; and (d) takes such xdors as Leader maY reasonably require to assure that the lien of this Seeeaity instrument, Lender's rights in the Property and Borrower's obligation to pay the sums secured by this Security Instrument shall continue unchanged. Upon rcinstatrraent by Borrower, dais Security Insunmrnt and the obligations secured hereby shall remain ftdly ellective as if no accdcmtion had occured. However, this right to reinstate shall not apply in the one of acceleration under paragraph 17. 19. Sale of Hole; Change of Luun Services Tlrc Note or a partial iaterrst in the Note (together with this Security Inswmen[) may 6c snld one or mom times without prior notice to Borrower. A sale may result in a change in the entity (lmown as the "Loan Serviccr") that collects monthly payments due under the Note and this Security Instrument. There also may be one or morn changes of the Loan Servicer unrelated to a sale of the Note. If there is a change of the Loan Servicer, Borrower will be given wriltcta notice of the change in accordance with paragraph 14 above and applicable law. The notice will state the name and address of the new Loan Servicer and the address to which payments should be made. The notice will also contain any other information required by applicable law. 20. Hazardous Substances Borrower shall not cause or permit the presence, use, disposal, storage, or release of any Hazardous Substances on or in the Property. Borrower shall not do, nor allow anyone else to do, anything affecting the Property that is in violation of any Environmental I". The preceding two sentences shall not apply to the presence, use, or storage an the Property of small quantities of Hazardous Substances that arc generally recognized to be appropriate to normal residential uses and to maintenance of the Property. Borrower shall promptly give Lender written notice of any investigation, claim, demand, lawsuit or other action by any governmental or regulatory agency or private party involving the Property and any Hazardous Substance or Environmental Law of which Borrower has actual knowledge. It Borrower learns, or is notified by any governmental or regulatory authority, that any removal or other remediation of any Hazardous Substance affecting the Property is necessary, Borrower shall promptly take all necessary remedial actions in accordance with Environmental Law. As used in this paragraph 20, "Hazardous Substances" are those substances defined as toxic or hazardous substances by Environmental Law and the following substances: gasoline, kerosene, other flammable or toxic petroleum products, toxic pesticides and herbicides, volatile solvents, materials containing asbestos or formaldehyde, and radioactive materials. As used in this paragraph 20, "Environmental Law" means federal laws and laws of the jurisdiction where the Properly is lasted that table to health. safety or environmental protection. NON-UNWORM COVENANTS. Borrower and Lender further covenant and agree as follows: 2L Acceleration; Remedies. Leader shall give notice to Borrower prior to acceleration following Borrower's breach of any covenant or agreement is this Security Instrument tout not prior to acceleration under paragraph 17 unless applicable law provides otherwise). Lender shall notify Borrower or, among other things (a) the default; (b) the action required to cure the default; (c) when the default must be cured; and (d) that rallure to cure the default as specified may result in acceleration of the sums secured by this Security Instrument, foreclosure by judicial proceeding and sale or the Property. Lender shall further inform Borrower of the right to reinstate after acceleration and the right to assert m the foreclosure proceeding the non-existence of a default or any other defense of Borrower to acceleration and foreclosure. If the default is not cured as specified, Lender, at its option, may require immediate payment in full of all sums secured by this Security Instrument without further demand and may foreclose this Security Instrument by judicial proceeding. Lender shall be entitled to collect all expenses incurred in pursuing the remedies provided in this paragraph 21, including, but not limited to, attorneys' fees and costs of title evidence to the extent permitted by applicable law. 22. Release. Upon payment of all sums secured by this Security Instrument, this Security Instrument and the estate conveyed shall terminate and become void. After such occurrence, Lender shall discharge and satisfy this Security Instrtunentto Borrower. Borrower shall pay any recordation costs. Lender may charge Borrower a fee for releasing this Security Instrument but only if the fee is paid to a third party for services rendered and the charging of the fee is permitted under applicable law. 23. Waivers. Borrower, to the extent permitted by applicable law, waives and releases any error or defects in proceedings to enforce this Security Instrument, and hereby waives the benefit of any present or future laws providing for stay of execution, extension of time, exemption from auachment, levy and sale, and homestead exemption. Form711-M ®0.6H(PA) Ice to) rap. a oa 9 rnirl.r. W000a899 24. Reinstatement Period Borrower's time to reinstate provided in paragraph 18 shall extend to one hour prior to the cdmmencement of bidding at a sheriff's sale or other sale pursuant to this Security Instrument. 26. Purchase Money Mortgage. If any of the debt secured by this Security Instrument is lent to Borrower to acquire tide to the property. this Security instrument shall be a purchase money mortgage. is entered on the Note 26. Interest Rate After Judgment. Borrower agrees am ate interest rate payable after a Judgment or in an action of mortgage foreclosure shall be the rate payable from time to time under the Note. 27. Riders to this Security Instrument. If one or more riders am executed by Borrower and recorded together with this supplement Security Instrument, the cents of this Security Instrument as If the rider(s) were part of this Security Instrument. the covenants and and agrcom [Check applicable box(es)] 1 4 Family Rider Adjustable Rau Ride 0 Condominium Rider Graduated Payment Rider Planned Unit Development Rider C3 Biweekly Payment Rider Balloon Rider Rate Improvement Rider ED Second Home Rider F-1 VA Rider O other(s) (specify) a c; BY SIGNING BELOW, Borrower accepts and agrees to die cores and covenants contained in this Security Instrument and in any rider(s) executed by Borrow ecordrd with it. witnesses: l 1 / C (seat) _ ?LL %4 7 /• A ALPHEAFFER l n Barovv .rll ?r 1 (Se OVE TTTA L SHE Bo rower -(Seal) (Si:4 .Bunawar -BamaWCr Cer4ifimte Residence do here calif that the correct address of I,eckn e l? L? r' n "O 2?3 Cov r? S is the within-n? a 8400 is M l C1?? G C X ?yVP CVl k1' ! `? t" L. 1 Ty') k ow; c-r. ?jo??/ 1998 Wimess my hand this 21st day of May Ag IMongcacc COMMONWEALTH OPPENNSYLVANIA, York On this, the2lst day of May personally appeared ALFRED C SHEAFFER A CVETTA L SHEAFFER person(s) whose name( s) subscribed to the within fns executed the semo for the purposes herein conmined. IN WffNPSS WHBREOF, I hereunto set my hand and official My Commission Expires: NOTAaU1 SEAL MANEM L PENMWTON, Notary Pabk Camp MI Dom. CumbsrhmW Co., PA My commiWan Explrw Sept. 10, 7001 County ss: 1998 , before me, the undersigned officer, known to me (or a rily proven) to be the ndaclcnowledaedthat he/sh /they /j Tiuc or officer Form 3039 9190 •aH(Pptwtoh Pw•earo THE LAW Offices of GREGOR YJA VARDIAN JUNE 17, 1999 ALFRED C. SHEAFFER OVETTA L. SHEAFFER 14 EAST STREET MT. HOLLY SPRINGS, PA 17065 First Class and Certified Mail 44 Second Street Pike Suite 203 Southampton, PA 18966 Phone: (215) 942-9690 Fax: (215) 942-9695 Philadelphia Office 2021 Locust Street 2"d Floor Suite Philadelphia, PA 19103 Please reply to Southampton Office IMPORTANT: NOTICE OF HOMEOWNERS' EMERGENCY MORTGAGE ASSISTANCE ACT OF 1983 PLEASE READ THIS NOTICE YOU MAY BE ELIGIBLE FOR FINANCIAL. ASSISTANCE TOWARD YOUR MORTGAGE PAYMENTS RE: Property Address: 14 EAST STREET MT. HOLLY SPRINGS, PA 17065 Account (loan) No. 22111332 TO: ALL INTERESTED PARTIES FROM: IMC Mortgage Company Your Mortgage is in serious default because you have failed to pa? promptly installments of principal and interest, as required, for a period of at least sixty (60) days. The total amount of the delinquency is $ 5. 522.2 5 You may be eligible for financial assistance that will prevent foreclosure on your mortgage if you comply with the provisions of the Homeowners' Emergency 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 and if you meet the eligibility requirements of the Act as determined 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 (30) days from the date of this notice. During that time you have the right to arrange a "face-to-face" meeting with the representative of the lender, or with a designated consumer credit counseling agency. The purpose of that meeting is to attempt to work out a repayment plan, or to otherwise settle your delinquency. That meeting must occur in the next thirty (30) days. If you attend a face-to-face meeting with the lender, or with a consumer credit counseling agency identified in this notice, no further proceedings in mortgage foreclosure may take place for thirty (30) days after the date of that meeting. The name, and telephone number of the representative is: Rebecca Gast, Telephone Number: 1-800-776-2211 ext. 2292. The name(s) and address(es) of the designated consumer credit counseling agency(ies) is(are): see attached It is only necessary to schedule one face-to-face meeting. You should advise the lender immediately of your intentions. 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 Assistance Fund. In order to do this, you must fill out, sign and file a completed Homeowners' Emergency Assistance Application with the Pennsylvania Housing Finance Agency. The consumer credit counseling agency will assist you in filling out your application. It must be filed or postmarked within thirty (30) days of your face-to-face meeting. You must either mail you application to the Pennsylvania Housing Finance Agency, or you must file it at the office of one of the designated consumer credit counseling agencies listed above. The Pennsylvania Housing Finance Agency is located at 2101 North Front Street, P.O. Box 8029, Harrisburg, PA 17105. Telephone Number: (717) 780-3800 or 1-800- 342-2397 (toll free number). An application for assistance may be obtained from the lender, from a consumer credit counseling agency, or directly from the Pennsylvania Housing Finance Agency. 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. That 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 counseling agency will help you fill out the application. 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 time requirements set forth above. You will be notified directly by the Agency of its decision on your application. You have already received, or you will receive shortly, another notice from the lender or its attorney, under Act 6 of 1974. That notice is called a "Notice of Intention to Foreclosure". You must read both notices, since they both explain rights that you now have under the Pennsylvania law. However, if you choose to exercise your rights described in this notice, we cannot foreclosure upon you during that time. Also if you receive financial assistance from the Pennsylvania Housing Finance Agency, your home cannot be foreclosed upon while you are receiving that assistance. Very truly yours, _ i 92ttoy f ender CONSUMER CREDIT COUNSELING AGENCIES (1) Action Housing, Inc. Number Two Gateway Center 9th Floor Pittsburgh, PA 15222 (412) 391-1956 (2) American Red Cross- Hanover Chapter 529 Carlisle Street Hanover, PA 17331 (717) 637-3768 (3) Bucks County Housing Group, Inc. 140 East Richardson Avenue Langhorne, PA 19047 (4) Consumer Credit Counseling Service of Delaware County 1211 Chestnut Street, Suite 411 Philadelphia, PA 19107 (5) Consumer Credit Counseling Service of Lehigh County 3671 Crescent Court East Whitehall, PA 18052 (6) Commission on Economic Opportunity of Luzerne County 211-213 Main Street Wilkes-Barre, PA 18701 (717) 826-0510 Carbon, Columbia, Luzeme, Monroe Schuylkill and Wyoming Counties (7) Consumer Credit Counseling Service of Western PA, Inc. r' 309 Smithfield Street Suite 2000 Pittsburgh, PA 15222 (412) 471-7584 662 North Main Street Greensburg, PA 15601 (412) 838-1290 500-02 3rd Avenue P.O. Box 278 Duncanville, PA (814) 696-3546 1 st Federal Plaza, Suite 406 North Mill Street New Castle, PA 16101 Allegheny, Armstrong, Beaver, Bedford, Blair, Butler, Cambria, Camerton, Clarion, Clearfield, Fayette, Franklin, Fulton Greene, Huntingdon, Indiana, Jefferson, Juniata, Lawrence, Mercer, Mifflin, Synder, Somerset, Union, Venago, Washington & Westmoreland Counties (8) Consumer Credit Counseling Service of Northeastern Pennsylvania Connell Building, Suite 401 Box 169 Scranton, PA 18501 (717) 655-9527 Bradford, Carbon, Columbia, Lackawanna, Luzeme, Lycoming, Monroe, Montour, Northcumberland, Pike, Sullivan, Susquehanna, Tioga, Wayne and Wyoming Counties (9) The Budget Counseling Center 247 North 5th Street Reading, PA 19601 (215) 375-7866 Berks, Chester, Montgomery and Schuylkill Counties (10) Fayette County Community Action Agency, Inc. 48 East Church Street Uniontown, PA 15401 (412) 437-6050 or (412) 4374400 Fayette County Only (11) Indiana County Community Action Program Box 187 Indiana, PA 15701 Armstrong, Cambria, Clearfield, Indiana, Jefferson, & Westmoreland Counties (12) Housing Council of York 116 North George Street York, PA 17401 (717) 854-1541 (13) Housing Association of Delaware Valley 1314 Chestnut Street Suite 900 Philadelphia, PA 19107 (215) 545-6010 658 North Watts Street Philadelphia, PA 19123 (215) 978-0224 (14) Housing Opportunities, Inc. 133 7th Street P.O. Box 9 McKeesport, PA 15132 (412) 664-1590 Allegheny, Beaver, Butler, Washington and Westmoreland Counties (15) Guideline Doane Center Manfield University Mansfield, PA 16933 1-800-332-6718 (717) 662-4214 Bradford, Potter, Sullivan & Tioga Counties (16) John R. Kennedy Center, Inc. 2021 East 20th Street Erie, PA 16510 (814) 898-0400 Crawford & Erie Counties (17) Lycoming - Clinton Counties Commission for Community Action (STEP) 1221 West 3rd Street P.O. Box 1328 Williamsport, PA 17703 (717) 326-0587 Clinton and Lycoming Counties (18) Neighborhood Development Agency 5935 Ogontz Avenue Philadelphia, PA 19141 (215) 549-2344 (19) Philadelphia Council for Community Advancement 1701 Arch Street, Suite 304 Philadelphia, PA 19103 (215) 567-7800 Chester, Delaware, Montgomery and Philadelphia Counties (20) Shenango Valley Urban League, Inc. Housing Counseling Services 39 Chestnut Street Sharon, PA 19146 Mercer, Crawford and Lawrence Counties r (21) Southwest Germantown Community Development Corporation 5003 Wayne Avenue Philadelphia, PA 19144 Philadelphia County only (22) Tabor Community Services, Inc. 320 South Duke Street Lancaster, PA 17602 (717) 397-5182 Chester, Lebanon, & Lancaster Counties (23) Urban League of Metropolitan Harrisburg 28 North 2nd Street Harrisburg, PA 17101 (717) 397-5182 Cumberland, Dauphin and Perry Counties (24) Urban League of Philadelphia Urban Education Foundation 4601 Market Street 2nd Floor South Wing Philadelphia, PA 19139 (215) 476-4040 (25) Urban League of Pittsburgh, Inc. Building of Equal Opportunity 200 Ross Street Pittsburgh, PA 15219 (412) 261-1130 Allegheny County only (26) Warren-Forrect Counties Economic Opportunity Council 204 Liberty Street, P.O. Box 547 Warren, PA 16395 (814) 726-2400 Forest and Warren Counties (27) YMCA of Carlisle 311 South West Street Carlisle, PA 17013 (28) Montgomery County Opportunity Board 530 Church Street, 2nd Floor Norristown, PA 19401 (215) 277-6363 Bucks, Chester, Delaware, Montgomery, & Philadelphia Counties r ++##+tttrtrt##+#+#+t#trt+#rt#+#++rt#+rtrt####+trt##+#######Wrt+###+t####+###+W### NOTICE PURSUANT TO FAIR DEBT COLLECTION PRACTICES ACT ####t#Wrtrt4rtrt+#####it#t#trtttt#+tMrt#rt##+++####+#++######t###++tt##+##+#### 1. This is an attempt to collect a debt and any information obtained will be used for the purpose. 2. Unless you dispute the validity of this debt, or any portion thereof, within thirty (30) days after receipt of this notice, the debt will be assumed to be valid by our offices. 3. If you notify our offices in writing within thirty (30) days of receipt of this notice that the debt, or any portion thereof, is disputed, our offices will provide you with verification of the debt or copy of the judgment against you, and a copy of such verification or judgment will be mailed to you by our offices. 4. If you notify our offices in writing within thirty (30) days of receipt of this notice, our offices will provide you with the name and address of the original creditor, if different from the current creditor. VERIFICATION The undersigned hereby states that the statements made in the foregoing pleading are true and correct to the best of his/her knowledge, information and belief. The undersigned understands that the statements therein are made subject to the penalties of 18 Pa.C.S. Section 4904, relating to unsworn falsification to authorities. ??J?l '/ r h E p Q? NP H OF COW COUNTY OF CUMBERLA D AAA IMC MORTGAGE COMPANY COURT OF COMMON PLEAS CUMBERLAND COUNTY VS. No.: 99-4715 CIVIL ALFRED C. SHEAFFER OVETTA L. SHEAFFER PRAECIPE FOR WRIT OF MORTGAGE FORECLOSURE ION TO THE PROTHONOTARY: Kindly issue Writ of Execution in the above matter. $84,694.97 Amount Due interest from 11/2/99 to Date of Sale $ @ $13.92 per diem Subtotal (Costs to be added) ,ESQUIRE LL, arr..... ? 44 Second Street Pike, 101 Southamptort, PA (215) 942-9690 COMMONWEALTH OF PENNSYLVANIA COUNTY OF CUMBERLAND IMC MORTGAGE COMPANY COURT OF COMMON PLEAS VS. CUMBERLAND COUNTY ALFRED C. SHEAFFER No.: 99-4715 CIVIL OVETTA L. SHEAFFER PRAECIPE FOR WRIT OF EXECUTION MORTGAGE FORECLOSURE TO THE PROTHONOTARY: Kindly issue Writ of Execution in the above matter. Amount Due $84,694.97 Interest from 11/2/99 to Date of Sale @ $13.92 per diem $ Subtotal (Costs to be added) ESQUIRE 1.D. #55669 V 44 Second Street Pike, Suite 101 Southampton, PA 18966 (215) 942-9690 TRACT NO. I - ALL THAT CERTAIN tract of ground with the improvements thereon erected situate in the BOROUGH OF MOUNT HOLLY SPRINGS, Cumberland County, Pennsylvania, bounded and described as follows: BEGINNING at an iron pipe at corner of lands now or formerly of J.W. Odell and edge of East Street; thence South thirty-nine (39) degrees twenty-two (22) minutes East, a distance of fifty (50) feet along edge of East Street to a stake on the edge of said street; thence South forty-nine (49) degrees fifty-one (51) minutes twenty (20) seconds West, a distance of ninety (90) feet along South Street to a stake and comer of lands now or formerly of Norman D. Kuhn, et ux; thence North thirty-nine (39) degrees twenty-two (22) minutes West, a distance of fifty (50) feet along lands now or formerly of Norman D. Kuhn et ux, to a stake and comer of lands now or formerly of J.W. Odell; thence North forty-nine (49) degrees fifty-one (51) minutes twenty (20) seconds East, a distance of ninety (90) feet along lands now or formerly of J. W. Odell to an iron pipe at the edge of East Street and corner of lands now or formerly of J.W. Odell and place of BEGINNING. SAID description being in accordance with survey of Thomas A. Neff, Registered Surveyor, dated October 14, 1966. TRACT NO.2 - ALL THAT CERTAIN tract of land situate in the BOROUGH OF MOUNT HOLLY SPRINGS, Cumberland County, Pennsylvania, bounded and described as follows, pursuant to a survey by Thomas A. Neff, Registered Surveyor, on October 14, 1966: BEGINNING at a stake the intersection of the northern line of South Street and the eastern line of a public alley; thence by the eastern line of said alley, North thirty-nine (39) degrees twenty- two (22) minutes West, fifty (50) feet to a stake; thence by land now or formerly of J.W. Odell, North forty-nine (49) degrees fifty-one (51) minutes twenty (20) seconds East, eighty-seven and eighty-one one-hundredths (87.81) feet to a stake; thence South thirty-nine (39) degrees twenty two (22) minutes East, fifty (50) feet to a stake on the northern line of South Street; thence by the northern line of said street, South forty-nine (49) degrees fifty-one (51) minutes twenty (20) seconds West, eighty-seven and eighty-one one-hundredths (87.81) feet to the place of BEGINNING. BEING the same premises which James R. Baughman and Doris L. Baughman, his wife, by Deed bearing date the 2nd day of may, 1994, and recorded in the Office of the Recorder of Deeds in and for Cumberland County, Pennsylvania, on the l I' day of May, 1994, in Record Book 105, page 182, granted and conveyed unto Alfred C. Sheaffer and Ovetta L. Sheaffer, his wife. TAX MAP (23) 32-2336-113 BEING known as 14 East Street, Mount Holly Springs, PA 17065 P - - 13 LAW OFFICES OF GREGORY JAVARDIAN By: GREGORY JAVARDIAN, ESQUIRE IDENTIFICATION NO. 55669 44 SECOND STREET PIKE, SUITE 101 SOUTHAMPTON, PA 18966 (215) 942-9690 IMC MORTGAGE COMPANY Vs. ALFRED C. SHEAFFER OVETTA L. S14EAFFER COURT OF COMMON PLEAS CUMBERLAND COUNTY No.: 99-4715 CIVIL CERTIFICATION TO SHERIFF OF CUMBERLAND COUNTY AS TO THE SALE OF REAL ESTATE I hereby certify that I am the attorney for the Plaintiff in this Mortgage Foreclosure Action and further certify this Property is: () FHA () Tenant Occupied O Vacant O Commercial () As a result of Complaint in Assumpsit (7) Act 91 complied with /l ARDIAN, ESQUIRE W 77 ;: LAW OFFICES OF GREGORY JAVARDIAN By: GREGORY JAVARDIAN, ESQUIRE IDENTIFICATION NO. 55669 44 SECOND STREET PIKE, SUITE 101 SOUTHAMPTON, PA 18966 (215)942-9690 IMC MORTGAGE COMPANY COURT OF COMMON PLEAS VS. CUMBERLAND COUNTY ALFRED C. SHEAFFER No.: 99-4715 CIVIL OVETTA L. SHEAFFER NOTICE OF SHERIFF'S SALE OF REAL PROPERTY TO: ALFRED C. SHEAFFER OVETTA L. SHEAFFER 14 EAST STREET MOUNT HOLLY SPRINGS, PA 17065 Your house (real estate) at 14 EAST STREET. MOUNT HOLLY SPRINGS PA 17065, is scheduled to be sold at Sheriffs Sale on MARCH 7. 2001 at 10:00 A.M. in the Cumberland County Courthouse, 1 Courthouse Square, Carlisle, PA 17013, to enforce the court judgment of $84,694.97, obtained by IMC MORTGAGE COMPANY, against you. NOTICE OF OWNER'S RIGHTS YOU MAY BE ABLE TO PREVENT THIS SHERIFF'S ALE To prevent this Sheriffs Sale, you must take immediate action: L The sale will be cancelled if you pay to the mortgagee the back payments, late charges, costs and reasonable attorneys fees due. To find out how much you must pay, you may call: 2? 942-9690. 2. You may be able to stop the sale by filing a petition asking the Court to strike or open the judgment, if the judgment was improperly entered. You may also ask the Court to postpone the sale for good cause. 3. You may also be able to stop the sale through other legal proceedings. You may need an attorney to assert your rights. The sooner you contact one, the more chance you will have of stopping the sale. (See notice on page two on how to obtain an attorney.) I 1. If the Sheriffs Sale is not stopped, your property will be sold to the highest bidder. You may find out the price bid by calling (215) 942-9690. 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 Gregory Javardian, Esquire at (215) 942-9690. 4. If the amount due from the Buyer is not paid to the Sheriff, you will remain the owner of the property as if the sale never happened. 5. You have the right to remain in the property until the full amount due is paid to the Sheriff and the Sheriff gives a deed to the buyer. At that time, the buyer may bring legal proceedings to evict you. 6. You may be entitled to a share of the money which was paid for your house. A schedule of distribution of the money bid for your house will be filed by the Sheriff. This schedule will state who will be receiving that money. The money will be paid out in accordance with this schedule unless exceptions (reasons why the proposed distribution is wrong) are filed with the Sheriff within ten (10) days. 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 BAR ASSOCIATION 2 LIBERTY AVENUE CARLISLE, PA 17013 TELEPHONE: (717) 249-3166 (800) 990-9108 TRACT NO. 1 - ALL THAT CERTAIN tract of ground with the improvements thereon erected situate in the BOROUGH OF MOUNT HOLLY SPRINGS, Cumberland County, Pennsylvania, bounded and described as follows: BEGINNING at an iron pipe at comer of lands now or formerly of J.W. Odell and edge of East Street; thence South thirty-nine (39) degrees twenty-two (22) minutes East, a distance of fifty (50) feet along edge of East Street to a stake on the edge of said street; thence South forty-nine (49) degrees fifty-one (51) minutes twenty (20) seconds West, a distance of ninety (90) feet along South Street to a stake and corner of lands now or formerly of Norman D. Kuhn, et ux; thence North thirty-nine (39) degrees twenty-two (22) minutes West, a distance of fifty (50) feet along lands now or formerly of Norman D. Kuhn et ux, to a stake and corner of lands now or formerly of J.W. Odell; thence North forty-nine (49) degrees fifty-one (51) minutes twenty (20) seconds East, a distance of ninety (90) feet along lands now or formerly of J. W. Odell to an iron pipe at the edge of East Street and corner of lands now or formerly of J.W. Odell and place of BEGINNING. SAID description being in accordance with survey of Thomas A. Neff, Registered Surveyor, dated October 14,1966. TRACT NO. 2 - ALL THAT CERTAIN tract of land situate in the BOROUGH OF MOUNT HOLLY SPRINGS, Cumberland County, Pennsylvania, bounded and described as follows, pursuant to a survey by Thomas A. Neff, Registered Surveyor, on October 14,1966: BEGINNING at a stake the intersection of the northern line of South Street and the eastern line of a public alley; thence by the eastern line of said alley, North thirty-nine (39) degrees twenty- two (22) minutes West, fifty (50) feet to a stake; thence by land now or formerly of J.W. Odell, North forty-nine (49) degrees fifty-one (51) minutes twenty (20) seconds East, eighty-seven and eighty-one one-hundredths (87.81) feet to a stake; thence South thirty-nine (39) degrees twenty two (22) minutes East, fifty (50) feet to a stake on the northern line of South Street; thence by the northern line of said street, South forty-nine (49) degrees fifty-one (51) minutes twenty (20) seconds West, eighty-seven and eighty-one one-hundredths (87.81) feet to the place of BEGINNING. BEING the same premises which James R. Baughman and Doris L. Baughman, his wife, by Deed bearing date the 2"° day of may, 1994, and recorded in the Office of the Recorder of Deeds in and for Cumberland County, Pennsylvania, on the I I' day of May, 1994, in Record Book 105, page 182, granted and conveyed unto Alfred C. Sheaffer and Ovetta L. Sheaffer, his wife. TAX MAP (23) 32-2336-113 BEING known as 14 East Street, Mount Holly Springs, PA 17065 ?LI ?l ? 11 ?J Y no ooivuu: o, vi..? iu:uueionneu,ei -? mu?nnur i,:, yJUFT?'?'?LV t -^"?'?' Sent by: GREG JAVARDIAN LAW OFFICE 2154429727; 08/09/00 2:53PM;j9 Fj p49; Page 2/2 IN THE UNITED STATES BANKRUPTCY COURT FOR THE MIDDLE DISTRICT OF PENNSYLVANIA IN RE: Alfred C. Sheaffer Oveua L. Sheaffer Citifinacial Mortgage Company fllr/a IMC Mortgage Company Movant V. Alfred C. Sheaffer Ovetta•L. Sheaffer Debtor(s) Chapter 13 Proceeding 99-05198 RJW DEFAULT ORDER AND NOW, this 15 day of.41 ?- , 2000, upon Movants' Motion to Enter a Default Order it is hereby ORDERED AND DECREED that the Automatic Stay be modified to permit, Citifinacial Mortgage Company Mda IMC Mortgage Company and/or its successors and assigns to proceed with foreclosure on the property located at 14 East Street, Mt Holly Springs, PA 17065 and obtain all other Relief available under the Non-Bankruptcy law. it is further ORDERED AND DECREED that should this Chapter 13 Proceeding be converted to a Chapter 7 the Automatic Stay will remain modified to permit, Citifinacial Mortgage Company f/k/a IMC Mortgage Company and/or its successors and assigns to proceed with foreclosure on the property located at 14 East Street, Mt Holly Springs, PA 17065 and obtain all other Relief available under the Non-Bankruptcy law. BY THE COURT: /s/ Robed J. Woodside Robert J. Woodside Chief Bankruptcy Judge Interested Parties: Gregory Javardian, Esquire Attorney for Citifinacial Mortgage Company f Wa WC Mortgage James M. Bach, Esquire Attorneys for Debtor(s) hUG 15 2000 Charles J. DeHart, III, Esquire IMC MORTGAGE COMPANY VS. ALFRED C. SHEAFFER OVETTA L. SHEAFFER COURT OF COMMON PLEAS CUMBERLAND COUNTY No.: 99-4715 CIVIL SUPPLEMENTAL AFFIDAVIT PURSUANT TO RULE 3129.1 Plaintiff in the above action sets forth as of the date the Praecipe for the Writ of Execution was filed the following information concerning the real property located at 14 EAST STREET. MOUNT HOLLY SPRINGS PA 17065: 3. Name and last known address of every judgment creditor whose judgment is a record lien on the real property to be sold: Name Last Known Address (if address cannot be reasonably ascertained, please indicate) Borough of Mount Holly Springs 200 Harman Street Mount Holly, PA 17065 4. Name and address of last recorded holder of every mortgage of record: Name Last Known Address (if address cannot be reasonably ascertained, please indicate) None. 5. Name and address of every other person who has any record lien on the property: Name None. Last Known Address (if address cannot be reasonably ascertained, please indicate) 6. Name and address of every other person who has any record interest in the property and whose interest may be affected by the sale. Name Last Known Address (if address cannot be reasonably ascertained, please indicate) None. 7. Name and address of every other person of whom the plaintiff has knowledge who has any interest in the property which may be affected by the sale: Name None. Last Known Address (if address cannot be reasonably ascertained, please indicate) I verify that the statements made in this affidavit are true and correct to the best of my knowledge, information and belief. I understand that false statements herein are subject to the penalties of 18 Pa. C.S.A. 4904 relating to unswom falsific4tion to authorities. ? /lam GR?O Y VARDIAN, ESQUIRE January 2, 2001 Attorney for Plaintiff ?,? ;;: -. - _., •. LAW OFFICES OF GREGORY JAVARDIAN BY: GREGORY JAVARDIAN, ESQUIRE IDENTIFICATION NO. 55669 44 SECOND STREET PIKE, SUITE 101 SOUTHAMPTON, PA 18966 (215) 942-9690 IMC MORTGAGE COMPANY vs. ALFRED C. SHEAFFER OVETTA L.SHEAFFER COURT OF COMMON PLEAS CUMBERLAND COUNTY No.: 99-4715 CIVIL AFFIDAVIT OF SERVICE PURSUANT TO RULE 3129.1 I hereby certify that I have sent copies of the Notice of Sheriff Sale to the Defendants' certified and regular United States mail and all lien holders or judgment creditors of record as required by Pa.R.C.P. by first class United States mail, postage prepaid, on the date set forth below. (See attached Exhibit "A"). Cumberland County Domestic Relations 13 N. Hanover Street Carlisle, PA 17013 Cumberland County Tax Claim Bureau I Courthouse Square Carlisle, PA 17013-3387 ALFRED C. SHEAFFER 14 EAST STREET , MOUNT HOLLY SPRINGS, PA 17065 OVETTA L. SHEAFFER 14 EAST STREET ` MOUNT HOLLY SPRINGS, PA 17065 Dept. of Public Assistance 33 Westminster Drive, P.O. Box 599 Carlisle, PA 17013-0599 Tenants/Occupants 14 EAST STREET MOUNT HOLLY SPRINGS, PA 17065 Dated: //3/7 Borough of Mount Holly Springs 200 Harman Street Mount Holly, PA 17065 i 2 GR ORY V RDIAN, ESQUIRE Attorney orP amtiff U.S. POSTAL SERVICE CERTIFICATE OF MAILING MAY BE USED FOR DOMESTIC AND INTERNATIONAL MAIL, DOES NOT PROVIDE FOR INSURANCE-POSTMASTER RaceNSd From: THELAWOFFICESOF GREGORYJdAROIAN n SUITE 101 11, 0 C? t , L One plece of ordinary mall addressed to: " r Y b N 0 DEPT. OF PUBLIC ASSISTANCE 33 WESTMINSTER DRIVE, P.O. LADi TOtC DA 17013 0599 BOX 599 RE: SHEAFFER PS Form 3817, Mar. 1989 POSTAL SERVICE CERTIFICAT E F AILING MAY BE USED FOR DOMESTIC AND INTERNATIONAL MAIL, DOES NOT PROVIDE FOR INSURANCE-POSTMASTER Raceleed From: THE LAW OFFICES OF GREGORYIdARDIAN SUITE 101 gdSn -NUUMAMPION, PA 1139 6 UL o c One plea of ordinary mall addressed to: TENANTS /OCCUPANTS - Z. 6 ^U? Spa 14 EAST STREET NO11NT N0117L SPRINGS P A 17065 , RE: SHEAFFER FS Form 3817, Mar. 1989 Received From THE LAW OFFICES OF GREGORYJhVARUTAN SUITE 101 11-111.11.1 ,v,., in 103uu w0 One pleoe of ordinary mail addressed to: d NO ALFRED C. SHEAFFER 14 EAST STREET MGU=_snr r y SPRINGS, 12A 1-7Ag? PS Form 3817, Mar, Affixfesharin stamps I t or tog,F'nd at ar . ulra? of 1 oumslar f arrant __ 4A D. t 1? U ?1 tiI I y ? C D IlY r Ti Affix fee here In stamps or 90 age?nd I ? 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NU,:?w P(A? ? G ?iy Sfeid, ZIPN S1 EAST STR 14 LLrT MOUNT HdCV S Ln CMilied F. LI'1 Return Receipt Fn (Endorsement Rpuired 0 O Resbiwed Delivery FN C3 (Endomanimt Rpuired G Total Postage { Feel (Pbas Pnn l Gat Z Apl -1, L G ; , . ZIPN' M1 I I ?rF ? ALFRED C. SHEAFFER N SOUTHAMPTON. PA 18966 OVETTA L. SHEAFFER _J MOUNT HM'Lg$ 6S T-F 1 0 Certified Fee t .,k Return Receipt Fee nQ? (Endorsement Rpuire e i Restnctnd DNivery Fee (EndomementRpuired) bd NOy Total Postage { Fees $ fI p: m R e+ 1? O ? C 66 m T ? 7 9 $ H Y 3 ? N h 3 O c A ~ m S irS N 6 y T a H 9 3 y ? O ?> MM tsl O Z y T T O 7d S a Ap ? t m o T nr Co j `off ?" o , 4 \ y 3?3 > zl _? `n 3 r ION D HL O y 0i c m I V m m b S N O m d m m 3•JV1sVd Sn I a,' f H31M3N g,' av- 0 9e a Rl 12: K) to z (D .. • O O 0. 0(!A O^ mm? (n ft x N c e Qo ° 01° Aor ? x n _ xs 3 imm (o SD uD? CA P) M F ? N SD p 0. ?? rn ti c, -+ S zo' m M R O c c ? m ?Z m m I m K rrt Ue °z? vn on N Z° o yo ; a n rF ? v O ° n . -°-?? o ?' ! y M P NC i n r En 5 r ? ~ £ G D NVf bd NOL • 30V1SOd'Sn MOM ; t s m3N ad O n a • ';' • .i .T 3 SD u nv d o 3 c ?9SE November 10, 2000 TO: OWNER(S): PLAINTIFF/SELLER: DEFENDANT(S): PROPERTY: CUMBERLAND C.C.P. NO. NOTICE OF SHERIFF'S SALE OF REAL PROPERTY ALL PARTIES IN INTEREST AND CLAIMANTS ALFRED C. SHEAFFER and OVETTA L. SHEAFFER IMC MORTGAGE COMPANY ALFRED C. SHEAFFER and OVETTA L. SHEAFFER 14 EAST STREET MOUNT HOLLY SPRINGS, PA 17065 99-4715 CIVIL The above captioned property is scheduled to be sold at Sheriffs Sale on MARCH 7. 2001 at 10:00 A.M., in the Cumberland County Courthouse, 1 Courthouse Square, Carlisle, PA 17013. You may hold a judgment on the property, which may be extinguished by the sale. You may wish to attend the Sheriffs Sale to protect your interest. 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. S' G gory Javardian Esquire Law Offices of Gregory Javardian 44 Second Street Pike, Suite 101 Southampton, PA 18966 (215) 942-9690 n, _' __ i.J LAW OFFICES OF GREGORY JAVARDIAN By: GREGORY JAVARDIAN, ESQUIRE IDENTIFICATION NO. 55669 44 SECOND STREET PIKE, SUITE 101 SOUTHAMPTON, PA 18966 (215) 942.9690 IMC MORTGAGE COMPANY Vs. COURT OF COMMON PLEAS CUMBERLAND COUNTY ALFRED C. SHEAFFER No.: 99-4715 CIVIL OVETTA L. SHEAFFER 14 EAST STREET MOUNT HOLLY SPRINGS, PA 17065 PRAECIPE TO MARK JUDGMENT TO USE PLAINTIFF TO THE PROTHONOTARY: Kindly mark the Judgment to Use Plaintiff, "THE CHASE MANHATTAN BANK, AS TRUSTEE OF IMC HOME EQUITY LOAN TRUST 1998-6 UNDER THE POOLING AND SERVICING AGREEMENT DATED AS OF SEPTEMBER 1, 1998", relative to the above matter. G mO J ARDIAN, ESQUIRE ey or intiff Date: January 8. 2001 ENTRY OF APPEARANCE TO THE PROTHONOTARY: Kindly enter my appearance on behalf of, "THE CHASE MANHATTAN BANK, AS TRUSTEE OF IMC HOME EQUITY LOAN TRUST 1998-6 UNDER THE POOLING AND SERVICING AGREEMENT DATED AS OF SEPTEMBER 1, 1998", Use Plaintiff, 5901 East Fowler Avenue, Tampa, FL 33617 G EGO %r ARDIAN,ESQUIRE homey for intiff Date: January 8, 2001 .? ' ?' (?- ?. ? ?; ? 1 ? ? 235 SOUTH 1) 54 STREET . PHILADELPHIA, PA 19107 PhilnJ<Iphn , PHONE: (215) 546-7400 Awwi.niun ..f ?. FAX: 215.985.0169 Pr,ne.,ional AB& Pnwew &n•rn eentce? ror Prof eeetonda lac. AFFIDAVIT OF SERVICE 61 ' PLAINTIFF(S) CAS. DATE RECEIVED IMC Mortgagge Co. 99% %71S-Civil December 13, 2000 DEFENDANT(S) r? Cf ClfTPfOTt- s Alfred Sheaffer of Cumberlaafnd County 314 E. Roosevelt Dr. Anderson SC 29624 Notice of Real Estate Sale SERVE BY: December 27, 2000: Served and made known to Alfred \C-. Sheaffer 2 ow-AQ S1\eGi'Kr on the day of .)O.?Ua f L ? 20 , at 5' S3 o'clock, 1' M., Commonwealth of Pennsylvania, in the manner described below: ? Defendant(s) personally served. ® Adult family member with whom said Defendant(s) reside(s). Relationship is W,A _ ? Adult in charge of Defendant's residence who refused to give name or relationship. ? Manager/Clerk of placing of lodging in which Defendant(s) reside(s). ? Agent or person in charge of Defendant's office or usual place of business. ? Posted DESRIPTION AGE LA 65 HEIGHT S 'l WEIGHT t S0 RACE W SEX ------------ On the ----------- day of --------------------- 19_ ----- , at ------------- o -------- 'clock, M., Defendant not found: -Moved -Unknown _No Ans -Vacant -Other DEPUTIZED SERVICE Now, this day of 19_, I do County to serve this -Summons and make return therof and according to Law. hereby deputize the Sheriff of -Complaint -Other By (Competent Adult) County Sheriff's Check $ ------------------------------------------------------------------------------- **-Special Instructions* ASAP Service. 1 of 2 NAME OF SERVER Sworn to & subscri before me this Process Server being duty Swom according to law, ? day of 2QQL deposes and says that he/she is process server herein names; and that the facts herein set forth above are true and correct to the best of their knowledge, intonation and belief. - Process Server / Competent Adult. r Firm cwv' 1 .,cvai a.aa „ .a-,.au ...L a - nay's Norma For Second t TelephoneM "` ---- Identification 02000PhKade1phia Rseoc. of ProlesumalPocesseemers Rey I PRO PROTHY March 7, 2001 DATE 6P s o L U ?:" s m o .o f R235 SOUTH 13TH STREET PHILADELPHIA, PA 19107 Philadelphia PHONE: (215) 546-7400 q,uxlmiun n( FAX: 215.985-0169 Pmfeuinnnl 8ervlcee }ur Proteufonde lac. Pnxe>.Sewers AFFIDAVIT OF SERVICE Court of Common Pleas Type of Service Notice of Real Estate Sale 314 E. Roosevelt Dr. Anderson SC 29624 SERVE BY: December 27, 2000 C ry' ad and made known to flvet t a 1 Shpaffar Accepted By: N J 1? m e.-14(a +h the I T-) day of ?G v?l l ar ?( 20 at S o'clock, P M., ??1Lli, )A E Roosege ommonweallh of Pennsylvania, in the manner described below: Defendant(s) personally served. Adult family member with whom said Defendant(s) reside(s). Relationship Is ? Adult in charge of Defendant's residence who refused to give name or relationship. ? Manager/Clerk of placing of lodging in which Defendant(s) reside(s). ? Agent or person in charge of Defendant's office or usual place of business. ? Posted ? Other DESCRIPTION AGE I?Q rs HEIGHTS WEIGHT ? C6C) On the day of 19_, at _ Defendant not found: -Moved -Unknown _No Ans DEPUTIZED SERVICE RACE SEX F o'clock, M., Vacant -Other Now, this day of 19_, I do hereby deputize the Sheriff of - County to serve this -Summons -Complaint -Other and make return therof and according to Law. By (Competent Adult) County Sheriff's Check $ ** Special Instructions *** Asap Service. 2 of 2 OFSERVER Process Server being duly sworn according to law, deposes and says that he/she is process server herein names: and that the facts herein set forth above are true and correct to the best of their knowledge, information and belief. Firm Process Server/ Competent Adult Name Gregory Javardian. Esquire For Plaintiff Sworn to 8 subscribed before me this _ a day of A.- 200;ff PRO PROTHY hone # 94Z-9690 Identification N DATE Phlledelphle Assoc. of professional process servers Rey I ? 7 ' 1 y ei •? ?? en STATE OF PENNSYLVANIA, 1 COUNTY OF CUMBERLAND J SS. Robert P Ziegler h ------------------------------------------------------------------------------ Recorder of Deeds in and for said County and State do hereby certify that the Sheriff's Deed in which ________________ IMC Home Equity Loan Trust 1998-6 Tr ------------------------------------------------------------------------------------ is the grantee the same having been sold to said grantee on the ------------ 7th ------------------------------- day of March 01 ---------------------------------------- A. D.,' -----,under and by virtue of a writ -------------- 17th ----Execution --------------------------------issued on the--------------------- --------------- Nov 00 day of __________________________ A. D., ----- y out of the Court of Comman Pleas of said County as of Civil 1999 ------------------------------ ------------------------------- Tenn, ------ 4715 IMC Mtg Co Number--------------, at the suit of--------------------------------------------------------------- Alfred C & Ovetta L Sheaffer ----------------------------------- against ---------------------------------------------------- is 241 414 duly recorded in Sheriffs Deed Book No -------------- Page ___________-. IN TESTIMONY WHEREOF, I have hereunto set my hand and seal of said office this __!!!l ___ day of ---/_4-------------- A. D.,-49-2411 -4`- --- ------ Recorder-of Dee f Dee ds IMC Mortgage Company In the Court of Common Pleas of -vs- Cumberland County, Pennsylvania Alfred C. Sheaffer and Ovetta L. Sheaffer No. 1999-4715 Civil Haro!d J. Weary Deputy Sheriff, who being duly sworn according to law, says on January 5, 2001 at 2:14 o'clock P.M. EST, he posted a copy of Real Estate Writ Notice Poster and Description on the property of Alfred C. Sheaffer and Ovetta L. Sheaffer located at 14 East Street, Mt Holly Springs, Cumberland County, Pennsylvania according to law. R. Thomas Kline, Sheriff, who being duly sworn according to law, says he served the above Real Estate Writ Notice Poster and Description in the following manner: The Sheriff mailed a notice of the pendency of the action to one of the within named defendants to wit: Alfred C Sheaffer by Certified Mail Return Receipt requested, Restricted Delivery, Deliver To Addressee Only to his last known address 3600 Vista Trail, Anderson, SC. This letter was mailed under the date of January 22, 2001 And received by Alfred Sheaffer on January 25, 2001 the return receipt card signed by Alfred Sheaffer. R. Thomas Kline, Sheriff who being duly sworn according to law, says he served the above Real Estate Writ Notice Poster and Description in the following manner: The Sheriff mailed a notice of the pendency of the action to one of the within named defendants to wit: Ovetta Sheaffer by Certified Mail Return Receipt Requested, Restricted Delivery, Deliver To Addressee Only to her last known address 3600 Vista Trail, Anderson, SC. This letter was mailed under the date of January 22, 2001 and received by Ovetta Sheaffer on January 25, 2001 the return receipt card signed by Ovetta Sheaffer R. Thomas Kline, Sheriff who being duly sworn according to law, says he served the above Real Estate Writ Notice Poster and Description in the following manner: The Sheriff mailed a notice of the pendency of the action to one of the within named defendants to wit: Alfred C. Sheaffer by regular mail to his last known address 3600 Vista Trial, Anderson SC. This letter was mailed under the date of January 30, 2001 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 to one of the within named defendants t wit: Ovetta L. Sheaffer by regular mail to her last known address 3600 Vista Trail, Anderson SC. This letter was mailed under the date of January 30, 2001 and never returned to the Sheriffs Office. R. Thomas Kline, Sheriff, who being duly sworn according to law, says that after due and legal notice had been given according to law, exposed the within described premises at public venue or outcry at the Court House, Carlisle, Cumberland County, Pennsylvania, on March 7, 2001 at 10:00 o'clock A.M., E.S.T. and sold the same for the sum of $1.00 to Attorney Dale Shughart for The Chase Manhattan Bank, as trustee of IMC Home Equity Loan Trust 1998-6 under the pooling and servicing agreement dated as of September 1, 1998. It being the highest bid and the best price received for the same The Chase Manhattan Bank, as trustee of IMC Home Equity Loan Trust 1998-6 under the pooling and servicing agreement dated as of September 1, 1998. Of 5901 E. Fowler Avenue, Tampa, FL, being the buyer in this execution paid Sheriff R. Thomas Kline, the sum of $1,124.11 it being costs. Sheriffs Costs Docketing 30.00 Poundage 22.04 Posting Bills 30.00 Advertising 30.00 Acknowledging Deed 30.00 Auctioneer County Mileage Certified Mail Levy Surcharge Law Journal Patriot News Share of Bills Distribution of Proceeds Sheriffs Deed 10.00 1.00 7.44 14.30 30.00 30.00 474.65 337.65 25.53 25.00 26.50 $1,124.11 paid by attorney 03-21-01 Sworn and subscribed to before me This 6?-6- day of p ' 2001 A.D.? ry 7tu 2? Pr t onotary So antcs er R. Thomas Kline, Sheriff By d C?(D Real Estate Deputy 315 6 AA- IMC MORTGAGE COMPANY VS. ALFRED C. SHEAFFER OVETTA L. SHEAFFER COURT OF COMMON PLEAS CUMBERLAND COUNTY No.: 99-4715 CIVIL AFFIDAVIT PURSUANT TO RULE 3129.1 Plaintiff in the above action sets forth as of the date the Praecipe for the Writ of Execution was filed the following information concerning the real property located at 14 EAST STREET. MOUNT HOLLY SPRINGS. PA 17065: 1. Name and address of Owner(s) or reputed Owner(s): Name Last Known Address (if address cannot be reasonably ascertained, please indicate) ALFRED C. SHEAFFER OVETTA L. SHEAFFER 14 EAST STREET MOUNT HOLLY SPRINGS, PA 17065 14 EAST STREET MOUNT HOLLY SPRINGS, PA 17065 2. Name and address of Defendant(s) in the judgment: ALFRED C. SHEAFFER 14 EAST STREET MOUNT HOLLY SPRINGS, PA 17065 OVETTA L. SHEAFFER 14 EAST STREET MOUNT HOLLY SPRINGS, PA 17065 3. Name and last known address of every judgment creditor whose judgment is a record lien on the real property to be sold: Name Last Known Address (if address cannot be reasonably ascertained, please indicate) None. 4 4. Name and address of last recorded holder of every mortgage of record: Name Last Known Address (if address cannot be reasonably ascertained, please indicate) Plaintiff. 5. Name and address of every other person who has any record lien on the property: Name Last Known Address (if address cannot be reasonably ascertained, please indicate) None. 6. Name and address of every other person who has any record interest in the property and whose interest may be affected by the sale. Name Cumberland County Domestic Relations Cumberland County Tax Claim Bureau Dept. of Public Assistance Last Known Address (if address cannot be reasonably ascertained, please indicate) 13 N. Hanover Street Carlisle, PA 17013 1 Courthouse Square Carlisle, PA 17013-3387 33 Westminster Drive, P.O. Box 599 Carlisle, PA 17013-0599 7. Name and address of every other person of whom the plaintiff has knowledge who has any interest in the property which may be affected by the sale: Name Last Known Address (if address cannot be reasonably ascertained, please indicate) Tenants/Occupants 14 EAST STREET MOUNT HOLLY SPRINGS, PA 17065 I verify that the statements made in this affidavit are true and correct to the best of my knowledge, information and belief. I understand that false statements herein are subject to the penalties of 18 Pa. C.S.A. 4904 relating to unworn falsification to authorities. R`f?J1V IAN, ESQUIRE GFe A y fo r PI 'tiff November 10, 2000 LAW OFFICES OF GREGORY JAVARDIAN By: GREGORY JAVARDIAN, ESQUIRE IDENTIFICATION NO. 55669 44 SECOND STREET PIKE, SUITE 101 SOUTHAMPTON, PA 18956 (215) 942.9690 IMC MORTGAGE COMPANY COURT OF COMMON PLEAS VS. CUMBERLAND COUNTY ALFRED C. SHEAFFER No.: 99-4715 CIVIL OVETTA L. SHEAFFER NOTICE OF SHERIFF'S SALE OF REAL PROPERTY TO: ALFRED C. SHEAFFER OVETTA L. SHEAFFER 14 EAST STREET MOUNT HOLLY SPRINGS, PA 17065 Your house (real estate) at 14 EAST STREET. MOUNT HOLLY SPRINGS. PA 17065, is scheduled to be sold at Sheriffs Sale on MARCH 7. 2001 at 10:00 A.M., in the Cumberland County Courthouse, 1 Courthouse Square, Carlisle, PA 17013, to enforce the court judgment of $84,694.97, obtained by IMC MORTGAGE COMPANY, against you. YOU MAY BE ABLE TO PREVENT THIS SHERIFF'S SALE To prevent this Sheriffs Sale, you must take immediate action: 1. The sale will be cancelled if you pay to the mortgagee the back payments, late charges, costs and reasonable attorney's fees due. To find out how much you must pay, you may call: 2? 942-9690. 2. You may be able to stop the sale by filing a petition asking the Court to strike or open the judgment, if the judgment was improperly entered. You may also ask the Court to postpone the sale for good cause. 3. You may also be able to stop the sale through other legal proceedings. You may need an attorney to assert your rights. The sooner you contact one, the more chance you will have of stopping the sale. (See notice on page two on how to obtain an attorney.) x 1. If the Sheriffs Sale is not stopped, your property will be sold to the highest bidder. You may find out the price bid by calling (215) 942-9690. 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 Gregory Javardian, Esquire at (215) 942-9690. 4. If the amount due from the Buyer is not paid to the Sheriff, you will remain the owner of the property as if the sale never happened. 5. You have the right to remain in the property until the full amount due is paid to the Sheriff and the Sheriff gives a deed to the buyer. At that time, the buyer may bring legal proceedings to evict you. 6. You may be entitled to a share of the money which was paid for your house. A schedule of distribution of the money bid for your house will be filed by the Sheriff. This schedule will state who will be receiving that money. The money will be paid out in accordance with this schedule unless exceptions (reasons why the proposed distribution is wrong) are filed with the Sheriff within ten (10) days. 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 BAR ASSOCIATION 2 LIBERTY AVENUE CARLISLE, PA 17013 TELEPHONE: (717) 249-3166 (800) 990-9108 TRACT NO. I - ALL THAT CERTAIN tract of ground with the improvements thereon erected situate in the BOROUGH OF MOUNT HOLLY- SPRINGS, Cumberland County, Pennsylvania, bounded and described as follows: BEGINNING at an iron pipe at corner of lands now or formerly of J.W. Odell and edge of East Street; thence South thirty-nine (39) degrees twenty-two (22) minutes East, a distance of fifty (50) feet along edge of East Street to a stake on the edge of said street; thence South forty-nine (49) degrees fifty-one (51) minutes twenty (20) seconds West, a distance of ninety (90) feet along South Street to a stake and comer of lands now or formerly of Norman D. Kuhn, et ux; thence North thirty-nine (39) degrees twenty-two (22) minutes West, a distance of fifty (50) feet along lands now or formerly of Norman D. Kuhn et ux, to a stake and comer of lands now or formerly of J.W. Odell; thence North forty-nine (49) degrees fifty-one (51) minutes twenty (20) seconds East, a distance of ninety (90) feet along lands now or formerly of J. W. Odell to an iron pipe at the edge of East Street and corner of lands now or formerly of J.W. Odell and place of BEGINNING. SAID description being in accordance with survey of Thomas A. Neff, Registered Surveyor, dated October 14, 1966. TRACT NO. 2 - ALL THAT CERTAIN tract of land situate in the BOROUGH OF MOUNT HOLLY SPRINGS, Cumberland County, Pennsylvania, bounded and described as follows, pursuant to a survey by Thomas A. Neff, Registered Surveyor, on October 14, 1966: BEGINNING at a stake the intersection of the northern line of South Street and the eastern line of a public alley; thence by the eastern line of said alley, North thirty-nine (39) degrees twenty- two (22) minutes West, fifty (50) feet to a stake; thence by land now or formerly of J.W. Odell, North forty-nine (49) degrees fifty-one (51) minutes twenty (20) seconds East, eighty-seven and eighty-one one-hundredths (87.81) feet to a stake; thence South thirty-nine (39) degrees twenty two (22) minutes East, fifty (50) feet to a stake on the northern line of South Street; thence by the northern line of said street, South forty-nine (49) degrees fifty-one (51) minutes twenty (20) seconds West, eighty-seven and eighty-one one-hundredths (87.81) feet to the place of BEGINNING. BEING the same premises which James R. Baughman and Doris L. Baughman, his wife, by Deed bearing date the 2"d day of may, 1994, and recorded in the Office of the Recorder of Deeds in and for Cumberland County, Pennsylvania, on the I I' day of May, 1994, in Record Book 105, page 182, granted and conveyed unto Alfred C. Sheaffer and Ovetta L. Sheaffer, his wife. TAX MAP (23) 32-2336-113 BEING known as 14 East Street, Mount Holly Springs, PA 17065 WRIT OF EXECUTION and/or ATTACHMENT COMMONWEALTH OF PENNSYLVANIA) NO. 99-4715 CIVIL TERM COUNTY OF CUMBERLAND) CIVIL ACTION • LAW TO THE SHERIFF OF Cumberland COUNTY: To satisfy the debt, interest and costs due IMC Mortgage Company from Alfred C. Sheaffer and Ovetta L. Sheaffer, 14 Fast Street, Mount Holly Springs, PA 17065 (1) You are directed to levy upon the property of the defendant(s) and to sell See Legal Description (2) You are also directed to attach the property of the defendant(s) not levied upon in the possession of as follows: and to notify the garnishee(s) that: (a) an attachment has been issued; (b) the garnishee(s) is/are enjoined from paying any debt to or for the account of the defendant(s) and from delivering any property of the defendant(s) or otherwise disposing thereof; (3) If properlyof thedefendant(s) not levied upon an subject to attachment isfound inthe possessionof anyone other than a named garnishee, you are directed to notify him/her that he/she has been added as a garnishee and is enjoined as above stated. Amount Due $84,694.97 from to date o sale Interest @ $1'A Q9 per rtiAm Atty's Comm % L. L. Due Prothy _ $1 .00 Other Costs Atty Paid $226.65 Plaintiff Paid Date: November 17, 2000 REQUESTING PARTY: Curtis R. Lon Prothonotary, Civil Division Deputy Name r;r,.garv Tavarrii an Esq. Address: 44 Semnrl Street Pike, Ruit-p 101 Attorney for: PInintiff Telephone: 915-949-9690 Supreme Court ID No. 55669 ,??yr,.,Qs•- 2a. ? the sheriff levied upon the defenoaoW interest in the real property situated in 4tA 4 --A gaauie- Cumberland County, Pa., known and numbered as: 1Y AT ano more fuily described on Exhibit "A" filed with ;i this writ and by this reference incorporated herein. -A./ THE PATRIOT NEWS THE SUNDAY PATRIOT NEWS Proof of Publication Under Act No. 587, Approved May 16, 1929 Commonwealth of Pennsylvania, County of Dauphin) ss Michael Morrow being duly sworn according to law, deposes and says: That he is the Asst. 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 4th, 1854, and September 181 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/ Metro editions which appeared on the 30th day(s) of January and the 6th and 13th day(s) of February 2001. 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 directors of the said Company and subsequently duly recorded in the office for the Recording of Deeds in and for said CFur ty of Dapphin in Miscellaneous Book "M", Volume 14, Page 317. 0 I1 PUBLICATION COPY SA LE #6 ,.,?.._..-REAL ESTATE SALE N0.6 <Wrk CIVNTorm 6 pvOrm 111111c; ill~ Coll"" Its p.. -` AMW C. Saueer ............ u.w... ... a?. r......... Sworn to and snhsn' Notadal Sul Terry L. Russell, Notary a Harrisburg, Dauphin County My Commbslon Expires June 6, 200 Member, Pennsylvania AmoalAten of Notaries CUMBERLAND COUNTY SHERIFFS OFFICE CUMBERLAND COUNTY COURTHOUSE CARLISLE, PA. 17013 rte this 27th d5y flf bbruary 2001 A.D. _ / h70TARY PUBLIC My commission expires June 6, 2002 , Statement of Advertising Costs ands To THE PATRIOT-NEWS CO., Dr. East For publishing the notice or publication attached fifty, hereto on the above stated dates $ 336.15 nnc Probating same Notary Fee(s) $ 1.50 (20) Total $ 337.65 1Ct Publisher's Receipt for Advertising Cost n) ins publisher of The Patriot-News and The Sunday Patriot-News, newspapers of general of receipt of the aforesaid notice and publication costs and certifies that the same have By .................................................................... 'AIN trail of land , %IOLNT H011) t1', Pennechania, ies, puouanl to a islered sumvior. ,pY IanMion of the d the eastern line j e eastern line ul , to Idegreesnsann- 0 feet to a slaFr; , - ,. OJeII. Iy of I.W. !S filh-one' 011 " htr+ecrn i - '7-., a a ) feet to a f y M 139) degrees p{ry 150) feet Is a -- rg svect thence 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 sworn, according to law, deposes and says that the Cumberland Law Journal, a legal periodical published in the Borough of Carlisle in the County and State aforesaid, was established January 2, 1952, and designated by the local courts as the official legal periodical for the publication of all legal notices, and has, since January 2, 1952, been regularly issued weekly in the said County, and that the printed notice or publication attached hereto is exactly the same as was printed in the regular editions and issues of the said Cumberland Law Journal on the following dates, viz: JANUARY 19, 26, FEBRUARY 2, 2001 Affiant further deposes that he is authorized to verify this statement by the Cumberland Law Journal, a legal periodical of general circulation, and that he is not interested in the subject matter of the aforesaid notice or advertisement, and that all allegations in the foregoing statements as to time, place and character of publication are true. REAL ESTATE BALE NO. 6 Writ No. 1999- 4715 Civil IMC Mortgage Company VS. Alfred C. Sheaffer and Ovella L. Sheaffer Ally.: Gregory Javardian TRACT NO. 1-ALL THAT CER- TAIN tract of ground with the hn- provemenls thereon erected situate in the BOROUGH OF MOUNT HOLLY SPRINGS, Cumberland County. Pennsylvania. bounded and described as follows: BEGINNING at an Iron pipe at I comer of lands now or formerly of j J.W. Odell and edge of East Street: thence South thirty-nine (39) de- grees twenty-two (22) minutes East. 1 a distance of fifty (50) feet along edge of East Street to a stake on the edge of said street: thence South forty- p nine (49) degrees fifty-one (51) min- utes twenty (20) seconds West, a I distance of ninety (90) feet along i South Street to a stake and comer of lands now or formerly of Norman D. Kuhn, et ux: thence North thirty- nine (39) degrees twenty-two (22) minutes West, a distance of fifty (50) feet along lands now or formerly of Norman D. Kuhn et Lilt, to a stake and comer of lands now or formerly of J.W. Odell: thence North forty- nine (49) degrees fifty-one (51) min- utes twenty (20) seconds East. a distance of ninety (90) feet along lands now or formerly of J. W. Odell to an iron pipe at the edge of East Street and corner of lands now or fomterly of J.W. Odell and place of BEGINNING. SAID description bc- Ing in accordance with survey of Thomas A. Neff. Registered Sur- veyor. dated October 14, 1966. Q- 2-Al I T,an-r 11.. Roger M. Morgenthal, Editor SWORN TO AND SUBSCRIBED before me this 2 day of FEBRUARY. 2001 NOTAkInr S[At, V LOIS E. SNYOER, rbrory public Codisle Uoro, C w berlond County, PA My Commission Exf iron Morth S, 2001 ,, t ti J TAIN tract of land situate in the BOROUGH OF MOUNT HOLLY SPRINGS. Cumberland County, Pennsylvania, bounded and de- scribed as follows, pursuant to a survey by Thomas A. Neff, Regis- tered Surveyor, on October 14, 1966: BEGINNING at a slake the in- tersection of the northern line of South Street and the eastern line of a public alley: thence by the east- ern line of said alley. North thirty- nine (39) degrees twenty-two (22) --" _ - +---- --_ -?vr. minutes West. fifty (50) feet to a stake: thence by land now or for- merly of J.W. Odell. North forty-nine (49) degrees fifty-one (511 minutes twenty (20) seconds East, eighty- seven and eighty-one one-hun- dredths (87.81) feet to a stake: thence South thirty-nine (39) de- grecs twenty two (22) minutes East. fifty (50) feel to a stake on the norlh- em line of South Street: thence by the northern line of said street. South forty-nine (49) degrees fifty- one (51) minutes twenty (20) sec- onds West, eighty-seven and eighty- one one-hundredths (87.81) feel to the place of BEGINNING. BEING the same premises which James R. Baughman and Doris L. Baughman, his wife, by Deed bear- ing date the 2nd day of May. 1994. and recorded in the Office of the Recorder of Deeds in and for Cumberland County. Pennsylvania, on the 11th day of May. 1994, in Record Book 105, page 182. granted and conveyed unto Alfred C. Sheaffer and Ovelta L. Sheaffer. his wife. TAX MAP (23) 32-2336-113. BEING known as 14 East Street. Mount Holly Springs. PA 17065. 1 t