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HomeMy WebLinkAbout99-04852I i." M?? `V ,Y R SHERIFF'S RETURN - NOT FOUND CASE NO: 1999-04852 P COMMONWEALTH OF PENNSYLVANIA: COUNTY OF CUMBERLAND GOLDSTAR FINANCIAL INC vs. DEANGELO THOMAS J ET AL R. Thomas Kline , Sheriff, who being duly sworn according to law, says, that he made a diligent search and inquiry for the within named defendant, to wit: DEANGELO THOMAS J but was unable to locate Him in his bailiwick. He therefore returns the COMPLAINT - MORT FORE NOTICE NOT FOUND as to the within named defendant DEANGELO THOMAS J DEFT. IS STILL BELEIVED TO BE RESIDING AT ADDRESS STATED, 7 ATTEMPTS WERE MADE , PAPER EXPIRED. Sheriff's Costs: So answer > Docketing 18.00 Service 11. Not Found Return 5.00 00 Surcharge 8.00 R-II omah s ATine 'S er $?T MA/TH 1E. VON ROSENSTIEL 09 20/999 Sworn and subscribed to before me this ,1 I r- day of?..? 1999 A.D. ?io?ono aryary SHERIFF'S RETURN - NOT FOUND CASE NO: 1999-04852 P COMMONWEALTH OF PENNSYLVANIA: COUNTY OF CUMBERLAND GOLDSTAR FINANCIAL INC VS. DEANGELO THOMAS J ET AL R. Thomas Kline Sheriff, who being duly sworn according to law, says, that he made a diligent search and inquiry for the within named defendant, to wit: DEANGELO MAJORIE J but was unable to locate Her in his bailiwick. He therefore returns the COMPLAINT - MORT FORE NOT FOUND , as to the within named defendant DEANGELO MAJORIE J DEFT. IS BELIVED TO BE RESIDING AT ADDRESS STATED 7 ATTEMPTS WERE MADE PAPER EXPIRED. Sheriff's Costs: So eansw;es: Docketing 6.00 Not Found Return 5.00 Affidavit .00Surcharge 8.00 $T!9-=. F? s ine, 5 ri 0ARTHA,E. VON ROSENSTIEL Sworn and subscribed to before me this .7 1 ? day of 19C?O/ A.D. ?"`d"-'Pr ono ary SHERIFF'S RETURN - NOT FOUND CASE N0: 1999-04852 P COMMONWEALTH OF PENNSYLVANIA: COUNTY OF CUMBERLAND GOLDSTAR FINANCIAL INC VS. DEANGELO THOMAS J ET AL R. Thomas Kline , Sheriff, who being duly sworn according to law, says, that he made a diligent search and inquiry for the within named defendant, to wit: SHOOP MYLES H JR but was unable to locate Him in his bailiwick. He therefore returns the COMPLAINT - MORT FORE UnmTov NOT FOUND as to the within named defendant SHOOP MYLES H JR DEFT. IS BELIEVED TO BE RESIDING AT ADDRESS STATED 7 ATTEMPTS WERE MADE, PAPER EXPIRED. Sheriff's Costs: So answers- Docket?ing 6.00 /'. Afffidavvlitt RETURN 5.00 Surcharge 8.00 R-= omas ine, 5 eri $T9-.-M 09RTHA E. gVON ROSENSTIEL 20/199 Sworn and subscribed to before me this .Z'7 !!?- day of 19A.D. ro?nono ary SHERIFF'S RETURN - OUT OF COUNTY CASE'NO: 1999-04852 P COMMONWEALTH OF PENNSYLVANIA: COUNTY OF CUMBERLAND GOLDSTAR FINANCIAL INC VS. DEANGELO THOMAS J ET AL R. Thomas Kline , Sheriff, who being duly sworn according to law, says, that he made a diligent search and inquiry for the within named defendant, to wit: UNITED STATES OF AMERICA i but was unable to locate Them in his bailiwick. He therefore deputized the sheriff of DAUPHIN County, Pennsylvania. to serve the within COMPLAINT - MORT FORE On September 20th 1999 this office was in receipt of the attached return from DAUPHIN County, Pennsylvania. Sheriff's Costs: So answers4- Docketing 6.00 ? Out of County 9.00 Surcharge 8.00 R-'f omas ine, STieriii DEP. DAUPHIN CO 23.00 5q-670U MA THA E. VON ROSENSTIEL 09/20/1999 Sworn and subscribed to before me this -r? day of 1999 A. D. T ro on ary T (?ffi?cE of t4.e S4Prfff Man' Jane Sm dcr Real Estate Deputy William T. Tully • Solicitor Dauphin County Harrisburg, Pennsvh•ania 17101 ph: (717) 255.2060 t4x: (717) 255.2889 Jack Lotwick Sheriff Commonwealth of Pennsylvania GOLDSTAR FINANCIAL INC vs County of Dauphin UNITED STATES OF AMERICA Sheriff's Return No. 1703-T - - -1999 OTHER COUNTY NO. 99-9852 Ralph G. McAllister Chict'teputy Michael W. Rinehart Assistant Chet' E ecy AND NOW: August 17, 1999 at 8:55AM served the within NOTICE & COMPLAINT IN CIVIL ACTION upon UNITED STATES OF AMERICA by personally handing C/O US ATTORNEY FOR THE MIDDLE DISTRICT to PAT WISCOUNT-RECEPT 1 true attested copy(ies) of the original NOTICE & COMPLAINT IN CIVIL ACTION and making known to him/her the contents thereof at 228 WALNUT STREET HARRISBURG, PA 17108-0000 Sworn and subscribed to before me this 23RD day of AUGUST, 1999 PROTHONOTARY So Answers, ?,eA/? Sheriff of Dauphin County, Pa. By ' , /I' Deputy She ff Sheriff's Costs: $100.00 PD 08/13/1999 RCPT NO 127037 GP/TJ In The Court of Common Pleas of Cumberland County, Pennsylvania Goldstar Financial, Inc. VS. Thomas J. DeAngelo, et. al. Serve: United States of America, c/go, 99-4852 Civil United States Attorney for the Middle D-1`sF-r-1-cT of Pennsylvania Now, 8/12/99 , 19_, I, SHERIFF OF CUMBERLAND COUNTY, PA, do hereby deputize the Sheriff of Dauphin deputation being made at the request and risk of the Plaintiff. County to execute this Writ, this ?.?4Z?rA Sheriff of Cumb land County, PA Affidavit of Service Now, within upon at by handing to a and made known to 19_, at o'clock copy of the original So answers, M. served the the contents thereof. Sheriff of Sworn and subscribed before me this _ day of 19 COSTS r SERVICE _ MILEAGE _ AFFIDAVIT r' ti County, PA DHERi?r- OOUhiy :•w uk collie FfiC H ? RRi591!RG n DUItfH0lry( 99 Al: 13 All u: y RECEIV?U Martha E. Von Rosenstiel, P.C. Martha E. Von Rosenstiel, Esquire 16 South Lansdowne Avenue P.O. Box 457 Lansdowne, PA 19050 610 623-2660 Attorney I.D.# 52634 Attorney for Plaintiff GOLDSTAR FINANCIAL, INC. COURT OF COMMON PLEAS OF 312 WEST FIRST STREET CUMBERLAND COUNTY SANFORD FL 32771 V. THOMAS J. DeANGLEO AND MAJORIE NO. 99-4852 Civil J. DeANGELO, Mortgagors and MYLES H. SHOOP, JR., Real owner 813 CAROL CIRCLE NEW CUMBERLAND, PA 17070 and UNITED STATES OF AMERICA c/o United States Attorney for the Middle District of Pennsylvania 228 Walnut Street Harrisburg, PA 17108 PRAECIPE TO REINSTATE COMPLAINT IN MORTGAGE FORECLOSURE TO THE PROTHONOTARY: Kindly reinstate the above captioned '1 Action in Mortgage Foreclosure. Martha E. on Rosenstiel Attorney for Plaintiff Dated: November 16,'/1999 ? o W C13 ?L. c of ?. : N ,)z iz _ caw rn o. W. SHERIFF'S RETURN - REGULAR CASE NO: 1999-04852 P COMMONWEALTH OF PENNSYLVANIA: COUNTY OF CUMBERLAND GOLDSTAR FINANCIAL INC VS DEANGELO THOMAS J ET AL KENNETH GOSSERT , Sheriff or Deputy Sheriff of Cumberland County, Pensylvania, who being duly sworn according to law, says, the within COMPLAINT - MORT FORE (RE was served upon SHOOP MYLES H JR the DEFENDANT , at 0018:00 HOURS, on the 13th day of December , 1999 at 813 CAROL CIRCLE NEW CUMBERLAND, PA 17070 by handing to MYLES SHOOP, JR. a true and attested copy of COMPLAINT - MORT FORE (RE together with NOTICE and at the same time directing His attention to the contents thereof. Sheriff's Costs Docketing 6.00 Service 10.54 Affidavit .00 Surcharge 8.00 .00 24.54 Sworn and Subscribed to before me this cA-49 day of A. D. =o¢nonotary So Answers: R.. Thomas Kline 01/06/2000 MARTHA VON ROSENSTEIL By: e ty r' r SHERIFF'S RETURN - OUT OF COUNTY CASE NO: 1999-04852 P COMMONWEALTH OF PENNSYLVANIA: COUNTY OF CUMBERLAND GOLDSTAR FINANCIAL INC VS DEANGELO THOMAS J ET AL R. Thomas Kline , Sheriff or Deputy Sheriff who being duly sworn according to law, says, that he made a diligent search and and inquiry for the within named DEFENDANT , to wit: DEANGELO THOMAS J but was unable to locate Him in his bailiwick. He therefore deputized the sheriff of CAMBRIA County, Pennsylvania, to serve the within COMPLAINT - MORT FORE On January 6th , 2000 this office was in receipt of the attached return from CAMBRIA Sheriff's Costs: So answer _ Docketing 6.00 Out of County .00>?l Surcharge 8.00 R'.'Thomas Kline .00 Sheriff of Cumberland County .00 14.00 01/06/2000 MARTHA VON ROSENSTIEL Sworn and subscribed to before me this ot(41 day of A. . Q r. Pr th notary ci?q % SHERIFF'S RETURN - OUT OF COUNTY CASE NO: 1999-04852 P COMMONWEALTH OF PENNSYLVANIA: COUNTY OF CUMBERLAND GOLDSTAR FINANCIAL INC VS DEANGELO THOMAS J ET AL R. Thomas Kline , Sheriff or Deputy Sheriff who being duly sworn according to law, says, that he made a diligent search and and inquiry for the within named DEFENDANT , to wit: DEANGELO MAJORIE J but was unable to locate Her in his bailiwick. He therefore deputized the sheriff of CAMBRIA County, Pennsylvania, to serve the within COMPLAINT - MORT FORE On January 6th , 2000 , this office was in receipt of the attached return from CAMBRIA Sheriff's Costs: So answer Docketing 18.00 ? Out of County 9.00 Surcharge 8.00 R. Thomas Kline Dep. Cambria Cc 42.50 Sheriff of Cumberland County .00 77.50 01/06/2000 MARTHA VON ROSENSTIEL Sworn and Lsubscribed to before me this day of O? A. i Pro h otary In The Court of Common Pleas of Cumberland County, Pennsylvania Goldstar Financial VS. Thomas J. DeAngelo, et. al. Serve: Thomas J. DeAngelo No. 99-4852 So answers, Now, 11/23/99 , 19_, I, SHERIFF OF CUMBERLAND COUNTY, PA, do hereby deputize the Sheriff of Cambria deputation being made at the request and risk of the Plaintiff. Civil County to execute this Writ, this Aod4 P Sheriff of Cumberland County, PA Affidavit of Service Now, _ Dec. 8 1999 , at 2:40 o'clock P M. served the within Complaint upon Thomas J. DeAngelo at 733Linden Ave., Johnstown, Cambria County,pa. by handing to Him, personally. a and made known to him copy of the original Complaint My costs paid by attorney for plaintiff. Sworn and subscribed before me this IV day of Cl0O the contents thereof. SherWof County, PA COSTS SERVICE $ MILEAGE AFFIDAVIT In The Court of Common Pleas of Cumberland County, Pennsylvania Goldstar Financial, Inc. VS. Thomas J. DeAngelo, et. al. Serve: Majorie J. DeAngelo No. 99-4852 Civil Now, 1 1 / 2 3 / 9 9 , 19_, I, SHERIFF OF CUMBERLAND COUNTY, PA, do hereby deputize the Sheriff of Cambria County to execute this Writ, this deputation being made at the request and risk of the Plaintiff. Sheriff of Cumberland County, PA Affidavit of Service Now, Dec. 8 1999 , at 2:40 o'clock P M, served the within Complaint upon Marjorie DeAngelo at 733 Linden Ave.,Johnstown,Cambria County,pa. by handing to Thnmac T DAA gain h„Ghnnd and made known to him copy of the original Complaint the contents thereof. So answers, Sheriffo / 1c-t County, PA COSTS Sworn and subscribed before SERVICE $ me this _ day of9`C. MILEAGE AFFIDAVIT , 00 Martha E. Von Rosenstiel, P.C Martha E. Von Rosenstiel 16 South Lansdowne Avenue P.O. Box 957 Lansdowne, PA 19050 610 62 3-2 660 Attorney I.D.# 52639 Goldstar Financial, Inc. 312 West First Street Sanford FL 32771 Attorney for Plaintiff : COURT OF COMMON PLEAS : CUMBERLAND COUNTY Plaintiff No VS. Thomas J. DeAngelo and Marjorie J. DeAngelo and Myles H. Shoop, Jr. 813 Carol Circle New Cumberland, PA 17070 and The United States of America 228 Walnut Street Harrisburg, PA 17108 Defendants 99-9852 Civil AFFIDAVIT OF SERVICE OF NOTICES PURSUANT TO RULE 3129.1 COMMONWEALTH OF PENNSYLVANIA: COUNTY OF DELAWARE SS MARTHA E. VON ROSENSTIEL, attorney for the plaintiff in the above action, hereby certifies that service of the Notice under Rule 3129.1, in the above matter was made on the defendants via certified mail, return receipt requested as evidenced by the attached postal receipts; and on all interested parties, set forth below, by regular first class mail, postage prepaid, as evidenced by the attached certificates of mailing: 1. Name and address of owners(s) or reputed owner(s) Myles H. Shoop, Jr. 813 Carol Circle New Cumberland, PA 17070 2. Name and address of defendant(s) in the judgment: Myles H. Shoop, Jr. 813 Carol Circle New Cumberland, PA 17070 Thomas J. DeAngelo 733 Linden Avenue Johnstown, PA 15902 Marjorie J. DeAngelo 733 Linden Avenue Johnstown, PA 15902 United States of America 228 Walnut Street Harrisburg, PA 17070 3. Name and address of every judgment creditor whose judgment is a record lien on the real property to be sold: Corestates Bank k/n/a First Union 510 Walnut Street Mezzanine Philadelphia, PA 19106 William C. Lambert and Carol M. Lambert P.O. Box 86 Mt. Joy, PA United States of America 228 Walnut Street Harrisburg, AP 17108 United States of America C/o Department of Justice Washington, DC 20530 United States Treasury Department P.O. Box 12051 Philadelphia, PA 19101 East Pennsboro Township 98 South Ends Street Enda, PA 9. Name and address of the last recorded holder of every mortgage of record: Sentry Consumer Discount Company 1505 Market Street Camp Hill PA 17011 5. Name and address of every other person who has any record interest in the property and whose interest may be affected by the sale: Cumberland County Domestic Relations One Courthouse Square Carlisle, PA 17013 I verify that the statements made in this affidavit are true and correct to the best of my personal knowledge or information and belief. I understand that false statements herein are made subject to the penalties of 18 Pa. C.S. Section 4904 relating to unsworn falsification to authorities. Martha E. Von Rosenstie Attorney for Plaintiff _211 POSTAL SERVICE ERTIFI ATE F NIAILIN BE USED FOR DOMESTIC AND INTERNATIONAL MAIL, DOES NOT PROVIDE FOR I NSURANCE-POSTMASTER Received From: an:f 1. _ Y•, IL- One Plow of ordinery mall addressed to: _ ?41III1n??,r?9 z?/J,,`?G.. 1{?f1_rl,,,, yt .Cr??HXd:h?P3 V Ltd. IFJN..-` 1 ??k? ?KLJ-!Zi (i?L? 1 Icy ?1 c" l3 U.S. POSTAL SERVICE CERTIFICATE OF MAILING MAY BE USED FOR DOMESTIC AND INTERNATIONAL MAIL, DOES NOT PROVIDE FOR INSURANCE-POSTMASTER Received From: , 'pJ NiAr(IHA E. nIrr.. P 0 Bolt +r_ 'yK z 2 NU0WNE, PA 00; One place of ordinary mail addressed to: 511," &'SLL e_1 V I SLVI SI- PA noki, U.S. POSTAL SERVICE CERTIFICATE OF MAILING MAY BE USED FOR DOMESTIC AND INTERNATIONAL MAIL. DOES NOT PROVIDE FOR INSURANCE-POSTMASTER Received From: IIAI'Itiil E 'rJl. !`.?%v1?rt Q?yn? P 0 -L J' ? aSJ'JrrirE, . I i5,T One pierce of ordinary mail addressed to: "1 O S F-C,?VLZ. SI Gti ,I PA Affix tee here in stamps or molar postage and poet mark. Inquire of Postmaster for current o fee. 3 J Affix fee here in stamps of meter postage anc poet mark. Inquire o Postmaster far current fee. ) Affix foe here in stamps or meter postage and poet mark. Inquire of Postmaster for current the. r U I e . rv _m V 3 m m w =APPFN CERTIFICATE OF MAILING Affix lee here in maml IC AND INTERNATIONAL M AIL, DOES NOT or meter postage ar POSTMASTER past mark, Inquire Postmaster for curre fee. kiHAE . r „ 4" C I Air fl 1^ P0 7 I ne place of ordinery mail addressed to: U ) ??rlco _ il._1 I I 1141- l( u l PS Form 3817, Mar. 1989 tp m 4. S a Z 3 e° v 0 r? I O 0 0 3 3 t. r v i• J r/ Rail 3 a 3 °'$4y a K o 3 K y^d 1 `= a 3 J r _ zv O - r ,1 L J _ .o m V' U rn < Z in v, 1 v8ey $35m? _... _ .,. Affix too here In stamps or motor postage and Post mark. Inquire of Z 293 878 128 Postmaster for current fee. US Postal Service Receipt for Certified Mail No Insurance Coverage Provided. Do not use for Intematlonal Moil rc.._ United States of America 228 Walnut Street Harrisburg, PA 17108 Affix fee hale in stamps U.S. POSTAL SERVICE CERTIFICATE F MAILING or motor mark olnquire of MAY BE USED FOR DOMESTIC AND INTERNATIONAL MAIL. DOES NOT Postmaster for current PROVIDE FOR INSURANCE-POSTMASTER tee. Received From: . 1. !i -? P 0 bC•, :.?7 1 One place of ordinary mail addressed to? I ?TN t7 7 11 M?'? n ?,??CtL a ke'7 2t4til, PS Form 3817, Mar. 1989 2 293 678 -?6 US Postal Service Receipt for Certified Mail to insurance coverage Provided. r. tnnnl \Ieil /CPP rPVPriAi Thomas J. DeAngelo 813 Carol Circle 17070 New Cumberland, PA Certified Fee Spedel Delivery Fee Resltldgd0elivery Fn i ate Deero Paenn epl Sloengto Dalkilif4dresseasAddross 1 TOT; s osfagei FjesJJ $ Cosh or 001e _J a c i Z 293 878 093 US Postal Service Receipt for Certified Mail Myles H. Shoop, Jr. 813 Carol Circle New Cumberland, PA 17070 Z 293 878 127 US Postal Service Receipt for Certified Mail No Insurance Coverage Provided. nru runt usn for International Mailal Niail (Se_revetrsel n Marjorie J. DeAngelo 0 313 Carol Circle 1 Jew Cumberland, PA 17070 2 p cc Carried Foe u Special Delivery Fee p Restricted 006011 Fee Return Receipt Sho-V ro - Whom a Dare Delivered . } Rehm Rece4s alb. If Adtr i TOTAL, .? Fees $'? Posonarkor Dab. ?, ^r'".? v postage $ confined Fee Special Delivery flesldcted D ivory Pbe ? `? Retum Reo 'pt Showv?'u1g tq , Whom ' D a Deliverrfd Realm Reps i' Ip Whom, Dele.BAdd' esee's J TOTAL Postage Poslmark or Dale -"? = t,: C7 7 C_7 l] Martha E. Von Rosenstiel, P.C Martha E. Von Rosenstiel 16 South Lansdowne Avenue P.O. Box 957 Lansdowne, PA 19050 610 623-2660 Attorney I.D.# 52639 Goldstar Financial, Inc. 312 West First Street Sanford FL 32771 Attorney for Plaintiff : COURT OF COMMON PLEAS : CUMBERLAND COUNTY Plaintiff No: 99-9852 Civil VS. Thomas J. DeAngelo and Marjorie: J. DeAngelo and Myles H. Shoop, Jr. 813 Carol Circle New Cumberland, PA 17070 And The United States of America 228 Walnut Street Harrisburg, PA 17108 Defendants TO THE PROTHONOTARY: PRAECIPE Enter judgment in the sum of $6,331.33 in favor of the above named plaintiff and against the above named defendants for failure to file an answer in the above action in Mortgage Foreclosure within twenty (20) days from date of service of the Civil Action, and assess damages. I hereby certify that the correct addresses of plaintiff and defendants are as follows: Plaintiff: 312 West First Street Sanford, FL 32771 Defendants: Myles H. Shoop, Jr. 813 Carol Circle New Cumberland, PA 17070 Thomas J. DeAngelo and Marjorie J. DeAngelo 733 Linden Avenue Johnstown, PA 15902 United States of America 228 Walnut Street Harrisburg, PA 17108/ Martha E. Von Rosenstie Attorney for Plaintiff a -? Martha E. Von Rosenstiel, P.C Martha E. Von Rosenstiel 16 South Lansdowne Avenue P.O. Box 457 Lansdowne, PA 19050 610 623-2660 Attorney I.D.# 52634 Attorney for Plaintiff Goldstar Financial, Inc 312 West First Street Sanford FL 32771 : COURT OF COMMON PLEAS CUMBERLAND COUNTY Plaintiff No: 99-4852 Civil Vs. Thomas J. DeAngelo and Marjorie : J. DeAngelo and Myles H. Shoop, : Jr. 813 Carol Circle New Cumberland, PA 17070 And The United States of America 228 Walnut Street Harrisburg, PA 17108 Defendants CERTIFICATION OF SERVICE OF NOTICE UNDER RULE 237.5 TO THE PROTHONOTARY: I hereby certify that the Notice undele 2X.5 was sent to all interested parties on January 11J! 2000. Martha E. Von Rosensti Attorney for Plaintiff DATED: March 27, 20 . A. Martha E. Von Rosenstiel, P.C. Martha E. Von Rosenstiel, Esquire 16 South Lansdowne Avenue P.O. Box 457 Lansdowne, PA 19050 610 623-2660 Attorney I.D. 52634 GOLDSTAR FINANCIAL, INC 312 WEST FIRST STREET SANFORD FL 32771 V. THOMAS J. DeANGLEO AND MAJORIE J. DeANGELO, Mortgagors and MYLES H. SHOOP, JR., Real Owner 813 CAROL CIRCLE NEW CUMBERLAND, PA 17070 and UNITED STATES OF AMERICA c/o United States Attorney for the Middle District of Pennsylvania 228 Walnut Street Harrisburg, PA 17108 COURT OF COMMON PLEAS OF CUMBERLAND COUNTY NO. 99-4852 Civil TO: THOMAS J. DeANGLEO AND MAJORIE J. DeANGELO and MYLES H. SHOOP, JR., 813 CAROL CIRCLE NEW CUMBERLAND, PA 17070 Date of Notice: January 13, 2000 Attorney for Plaintiff IMPORTANT NOTICE YOU ARE IN DEFAULT BECAUSE YOU HAVE FAILED TO ENTER A WRITTEN APPEARANCE PERSONALLY OR BY ATTORNEY AND FILE IN WRITING WITH THE COURT YOUR DEFENSES OR OBJECTIONS TO THE CLAIMS SET FORTH AGAINST YOU. UNLESS YOU ACT WITHIN TEN 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 'THE FOLLOWING OFFICE TO FIND U.S. POSTAL SERVICE CERTIFICATE OF MAILING MAY SE USED FOR DOMESTIC AND INTERNATIONAL MAIL. DOES NOT / PROVIDE FOR INSURANCE-POSTMASTER t Received From Y^`! =^cCNSTIEL, P.C. \ MARTHA E. I A41°,°, , .,: AVE T A P. 0. 30 ('P One piece of ordinary mail addressed to: e J. D-ANGELO 2nd MYLES H. SHOOP, JR., LI and of ASSOCIATION TUE ?013 990-9108 Von Rosenstiel for Plaintiff ' M Is, r? Martha.E. Von Rosenstiel, P.C. Martha E. Von Rosenstiel, Esquire 16 South Lansdowne Avenue P.O. Box 457 Lansdowne, PA 19050 610 623-2660 Attorney I.D.# 52634 GOLDSTAR FINANCIAL, INC 312 WEST FIRST STREET SANFORD FL 32771 V. THOMAS J. DeANGLEO AND MAJORIE J. DeANGELO, Mortgagors and MYLES H. SHOOP, JR., Real Owner 813 CAROL CIRCLE NEW CUMBERLAND, PA 17070 and UNITED STATES OF AMERICA c/o United States Attorney for the Middle District of Pennsylvania 228 Walnut Street Harrisburg, PA 17108 Attorney for Plaintiff COURT OF COMMON PLEAS OF CUMBERLAND COUNTY NO. 99-4852 PRAECIPE TO THE PROTHONOTARY: Enter judgment upon admission pursuant to Rule 1037(b) and the attached stipulation against the defendant United States of America for a judicial sale of and divestiture of all tax liens of defendant on premises 813 of Circle, New Cumberland, PA 17070, the relief of which i it ed to be due by the answer of the United States of rica t plaintiff's Complaint. Martha E. Yon Rosensti Attorney for Plaintiff ,'?AAND NOW, to wit, this 3 day of dip n { 2000, judgment is entered in favor of the plaintiff and Against the defendant United States of America for a Judicial sale of the above premises and divestiture of all tar liens of defendant United States of America thereon. k '' Pro Prothy V Martha E. Von Rosenstiel, P.C. Martha E. Von Rosenstiel, Esquire 16 South Lansdowne Avenue P.O. Box 457 Lansdowne, PA 19050 610 623-2660 Attorney I.D.# 52634 GOLDSTAR FINANCIAL, INC. 312 WEST FIRST STREET SANFORD FL 32771 V. THOMAS J. DeANGLEO AND MAJORIE J. DeANGELO, Mortgagors and MYLES H. SHOOP, JR., Real Owner 813 CAROL CIRCLE NEW CUMBERLAND, PA 17070 and UNITED STATES OF AMERICA c/o United States Attorney for the Middle District of Pennsylvania 228 Walnut Street Harrisburg, PA 17108 Attorney for Plaintiff COURT OF COMMON PLEAS OF CUMBERLAND COUNTY NO. 99-4852 STIPULATION It is hereby stipulated and agreed by and between Martha E. Von Rosenstiel, counsel for plaintiff, and the defendant, United States of America, as follows: 1. That the premises referred to in Exhibit "I" of the Complaint is owned by the defendant, Myles H. Shoop, Jr. 2. That the Federal tax lien referred to in paragraph ten (10) of the plaintiff's Complaint is junior in time to the plaintiff's mortgage set forth in paragraph four (4) of said Complaint. 3. That the mortgage being foreclosed on was executed on April 5, 1974 and recorded in Mortgage Book 576 page 358 }y ^..i9 4 Lt S] 5? I/li and assigned to Eastern Mortgage Services, Inc. via Assignment which was lodged with the Office for the Recording of Deeds of Cumberland County for recording. 4. The defendant United States of America is the holder of federal tax liens against the defendant Myles H. Shoop, Jr. as follows: Federal Tax Lien #6608 in the amount of $48,306.70 lodged with the Prothonotary of the Court of Common Pleas of Cumberland County on October 14, 1992. Federal Tax Lien #97-1833 in the amount of $65,561.56 lodged with the Prothonotary of the Court of Common Pleas of Cumberland County on April 8, 1997. 5. That the defendant, United States of America, is not indebted to the plaintiff. 6. That the defendant, United States of America, agrees to the entry in this action of a judgment in favor of the plaintiff and against the United States of America for foreclosure and sale of the mortgaged property. 7. That the aforesaid premises shall be sold at a Sheriff's sale, notice of which shall be served on the defendant, United States of America. 8. That the judicial sale of said property shall discharge the Federal lien referred to in paragraph ten (10) of said Complaint. 9. That the proceeds of sale shall be divided and distributed as the parties may be entitled. 10. That the defendant, United States of America, preserves its right of redemption as provided in Title 28, United States Code, Section 2410(c). 11. The parties to this Stipulation shall bear their own respective costs in this proceedings. Respectfully submitted, ted StNtes Attorney Joseph J. Assistant United America VON ROSENSTIEL for Plaintiff APPROVED AND SO BY THE COURT: Martha E. Von Rosenstiel, P.C. Martha E. Von Rosenstiel, Esquire 16 South Lansdowne Avenue P.O. Box 457 Lansdowne, PA 19050 610 623-2660 Attorney I.D.# 52634 GOLDSTAR FINANCIAL, INC 312 WEST FIRST STREET SANFORD FL 32771 V. THOMAS J. DeANGLEO AND MAJORIE J. DeANGELO, Mortgagors and MYLES H. SHOOP, JR., Real Owner 813 CAROL CIRCLE NEW CUMBERLAND, PA 17070 and UNITED STATES OF AMERICA c/o United States Attorney for the Middle District of Pennsylvania 228 Walnut Street Harrisburg, PA 17108 Attorney for Plaintiff COURT OF COMMON PLEAS OF CUMBERLAND COUNTY NO. 99-4852 Civil TO: THOMAS J. DeANGLEO AND MAJORIE J. DeANGELO and MYLES H. SHOOP, JR., 813 CAROL CIRCLE NEW CUMBERLAND, PA 17070 Date of Notice: January 13, 2000 IMPORTANT NOTICE YOU ARE IN DEFAULT BECAUSE YOU HAVE FAILED TO ENTER A WRITTEN APPEARANCE PERSONALLY OR BY ATTORNEY AND FILE IN WRITING WITH THE COURT YOUR DEFENSES OR OBJECTIONS TO THE CLAIMS SET FORTH AGAINST YOU. UNLESS YOU ACT WITHIN TEN 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 NOTICF. mn r **^•••-- ;emus OU DO NOT HAVE A LAWYER OR IulAll WC .f r?sliae and THE FOLLOWING OFFICE TO FIND ASSOCIATION VUE 7013 990-9108 Von Rosenstiel for Plaintiff Martha E. Von Rosenstiel, P. C. Martha E. Von Rosenstiel, Esquire 16 South Lansdowne Avenue P.O. Box 457 Lansdowne, PA 19050 610 623-2660 Attorney I.D.# 52634 GOLDSTAR FINANCIAL, INC 312 :NEST FIRST STREET SANFORD FL 32771 V. Attorney for Plaintiff COURT OF COMMON PLEAS OF CUMBERLAND COUNTY THOMAS J. DeANGLEO AND MAJORIE NO. 99-4852 Civil J. DeANGELO, Mortgagors and MYLES H. SHOOP, JR., Real Owner 813 CAROL CIRCLE NEW CUMBERLAND, PA 17070 and UNITED STATES OF AMERICA C/o United States Attorney for the Middle District of Pennsylvania 228 Walnut Street Harrisburg, PA 17108 TO: THOMAS J. DeANGLEO AND MAJORIE J. DeANGELO and MYLES H. SHOOP, JR., 813 CAROL CIRCLE NEW CUMBERLAND, PA 17070 Date of Notice: January 13, 2000 IMPORTANT NOTICE YOU ARE IN DEFAULT BECAUSE YOU HAVE FAILED TO ENTER A WRITTEN APPEARANCE PERSONALLY OR BY ATTORNEY AND FILE IN WRITING WITH THE COURT YOUR DEFENSES OR OBJECTIONS TO THE CLAIMS SET FORTH AGAINST YOU. UNLESS YOU ACT WITHIN TEN DAYS FROM THE DATE OF THIS NOTICE, A JUDGMENT MAY BE ENTERED AGAINST YOU WITHOUT A HEARING AND YOU MAY LOSE YOUR PROPERTY OR OTHER IMPORTANT RIGHTS. YOU SHOULD TAKE THIS NOTICE TO A LAWYER AT ONCE. IF YOU DO NOT HAVE A LAWYER OR CANNOT AFFORD ONE, GO TO OR TELEPHONE THE FOLLOWING OFFICE TO FIND OUT WHERE YOU CAN GET LEGAL HELP: CUMBERLAND COUNTY BAR ASSOCIATION 2 LIBERTY AVENUE CARLISLE, PA 17013 717 249-3166 OR 800 990-9108 Martha E. Von Rosenstiel Attorney for Plaintiff Martha E. Von Rosenstiel, P.C Martha E. Von Rosenstiel 16 South Lansdowne Avenue P.O. Box 457 Lansdowne, PA 19050 610 623-2660 Attorney I.D.# 52634 Attorney for Plaintiff Goldstar Financial, Inc 312 West First Street Sanford, FL 32771 Plaintiff : COURT OF COMMON PLEAS : CUMBERLAND COUNTY vs. Thomas J. DeAngelo and Marjorie : J. DeAngelo and Myles H. Shoop, : Jr. 813 Carol Circle New Cumberland, PA 17070 and The United States of America 228 Walnut Street Harrisburg, PA 17108 Defendants No: 99-4852 Civil AFFIDAVIT OF NON-MILITARY SERVICE COMMONWEALTH OF PENNSYLVANIA: SS COUNTY OF DELAWARE MARTHA E. VON ROSENST IEL, being duly sworn according to law deposes and says that the defendants are not in the Military or Naval Service of the United States or its Allies, or otherwise within the provisions of the Soldiers' and Sailors' Civil Relief Act of Congress of 1940, as amended; That Myles H. Shoop, Jr. over 21 years of age and resides at 813 Carol Circle, New Cumberland, PA 17070. That Thomas J. DeAngelo is over 21 ye of age and resides at 733 Linden Avenue, Johnstown, PA 15 That Marjorie J. DeAngelo is o r 2 years of age, and resides at 733 Linden Avenue, Johnstown A 159 2. / enstiel - Attorney E. . for Von Plaintiff to randbscrib65d me 7th Day ;ry r Public Notarial Seal Elizabeth Tronieri, Notary Public Lansdowne Boro, Delaware County My Commission Expires June 10, 2003 Member, Pennsylvania Association of Notaries V~o '? _J LAJ 10 0. PRAECIPE FOR WRIT OF EXECUTION-(MORTGAGEE FORECLOSURE) P.R.C.P. 3180-3183 & 3256 Goldstar Fianancial. Inc vs Thomas J. DeAngelo and Marjorie J. DeAngdlo, Mortgagors and Myles H. Shoop, Jr. Real Owner T-o the Proth_nctot•y: Issue writ of execution in the above matter. ?.mount Due PRACME FOE WRIT OF EXECUTION (MORTGAGE FORECLOSURE) 8- 6,331.33 Interest from 03/10/2000 LN THE COURT OF COBMON PLEAS OF CU1135LAMD COUM, PEtWnVANIA Civil 3ctio: Execution No 99-4852-Civil Judgt No dttomey jar the P!aintip' (s) Note: Plesse furnish deseiption of ] ALL THAT CERTAIN piece or parcel of land situate in New Cumberland, Cumberland County, Pennsylvania, more particularly bounded and described as follows, in accordance with survey of Michael C. DeAngelo, R.S., dated March 20, 1974, to wit: BEGINNING at an "X" cut in the sidewalk which point is 361.98 feet in a Southwesterly direction along the Northerly line of Carol Circle from the intersection of Carol Circle and Brandt Avenue; thence South 70 degrees 10 minutes 50 seconds West along the dividing line between the herein described Lot and Lot No. 9 on the hereinafter mentioned Plan of Lots a distance of 98.20 fat to a pin; thence South 19 degrees 48 minutes East along the right-of-way line with the York-Baltimore Expressway a distance of 181.69 feet to a pipe; the= North 19 degrees 10 minutes 10 seconds East along the dividing line betNieen the herein described Lot and Lot No. 7 on the hereinafter mentioned Plan of Lots, a distance of 175.64 fat to a pipe; thence along a curve to the right having a radius oT- 40 feet, an arc distance of 50 feet to the "X" cut in the sidewalk, the place of beginning. BEING Lot No. 8 on the Plan of Lots laid out by Leon Bear, and recorded in the Cumberland County Recorder's Office in Plan Book 7, page 22. HAVING thereon erected a 1-1/2 story brick dwelling house known and numbered as 813 Carol Circle. BEING Tax Parcel Number 26-23-0543-209. t> J - -? i7 lkc) d 4 Martha E. Von Rosenstiel, P.C. Martha E. Von Rosenstiel 16 South Lansdowne Avenue P.O. Box 957 Lansdowne, PA 19050 610 623-2660 Attorney I.D.# 52639 Goldstar Financial, Inc 312 West First Street Sanford FL 32771 Attorney for Plaintiff : COURT OF COMMON PLEAS : CUMBERLAND COUNTY Plaintiff No VS. Thomas J. DeAngelo and Marjorie: J. DeAngelo and Myles H. Shoop,: Jr. 813 Carol Circle New Cumberland, PA 17070 and The United States of America 228 Walnut Street Harrisburg, PA 17108 Defendants 99-9852 Civil AFFIDAVIT OF NOTICE PURSUANT TO RULE 3129.1 COMMONWEALTH OF PENNSYLVANIA: COUNTY OF DELAWARE SS MARTHA E. VON ROSENSTIEL, attorney for the 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 813 Carol Circle, New Cumberland, PA 17070: 1. Name and address of owners(s) or reputed owner(s) Myles H. Shoop, Jr. 813 Carol Circle New Cumberland, PA 17070 2. Name and address of defendant(s) in the judgment: Myles H. Shoop, Jr. 813 Carol Circle New Cumberland, PA 17070 Thomas J. DeAngelo 733 Linden Avenue Johnstown, PA 15902 Marjorie J. DeAngelo 733 Linden Avenue Johnstown, PA 15902 United States of America 228 Walnut Street Harrisburg, PA 17070 3. Name and address of every judgment creditor whose judgment is a record lien on the real property to be sold: Corestates Bank k/n/a First Union 510 Walnut Street Mezzanine Philadelphia, PA 19106 William C. Lambert and Carol M. Lambert P.O. Box 86 Mt. Joy, PA United States of America 228 Walnut Street Harrisburg, PA 17108 United States of America C/o Department of Justice Washington, DC 20530 United States Treasury Department P.O. Box 12051 Philadelphia, PA 19101 East Pennsboro Township 98 South Enda Street Enda, PA 9. Name and address of the last recorded holder of every mortgage of record: Sentry Consumer Discount Company 1505 Market Street Camp Hill PA 17011 5. Name and address of every other person who has any record lien on the property: 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: NONE 7. Name and address of every other person of whom plaintiff has knowledge who has any interest in the property which may be affected by the sale: Cumberland County Domestic Relations One Courthouse Square Carlisle, PA 17013 I verify that the statements made in this affidavit are true and correct to the best of my personal knowledge or information and belief. I understand that false statem s herein are made subject to the penalties of 18 Pa. C.S. Sec on 9 9 relating to unsworn falsification to authorit'es. Martha E. Von Rosenstiel Attorney for Plaintiff ? L - _ ?`i O MARTHA E. VON ROSENSTIEL, P.C. ATTORNEY AT LAW 16 SOUTH LANSDOWNE AVENUE P.O. BOX 457 LANSDOWNE , PA 19050 PHONE(610)623-2660 FAX 610 623-2745 March 9, 2000 Cumberland County Domestic Relations One Courthouse Square Carlisle, PA 17013 RE: NOTICE OF SALE OF REAL PROPERTY: 813 Carol Circle, New Cumberland, PA 17070 Amount of Judgment: $ 6,331.33 Date of Judgment: March 9, 2000 Court Term and Number: Court of Common Pleas of Cumberland County, Docket#k 99-4852 Civil Plaintiff: Goldstar Financial, Inc. Defendants: Thomas J. DeAngelo and Marjorie J. DeAngelo and Myles H. Shoop, Jr. and the United States of America Dear Sir or Madam: Please be advised that the property and improvements, if any, located at and known as 813 Carol Circle New Cumberland, PA, 17070 will be sold by the Sheriff of Cumberland County on June 7, 2000 at 10:00 a.m. in the Cumberland County Court House, One Court House Square, Carlisle, PA 17013. This property and improvements are being sold pursuant to a judgment entered as indicated above in favor of the above named plaintiff, and against the above named defendants. The name of the owner, real owner, and reputed owner of the aforementioned property is Myles H. Shoop, Jr. A schedule of distribution will be filed by the Sheriff on a date specified by the Sheriff no later than 30 days after said sale, and distribution will be made in accordance with the schedule unless exceptions are filed thereto within ten (10) days after the date of the filing of said s ule. You should check with the Sheriff's Office by calli 7 240-6391 to determine the actual date of the filing of th ch ule. S?Frcerel/ yours, Martha E. Von Rosenstiel MARTHA E. VON ROSENSTIEL, P. C. ATTORNEY AT LAW 16 SOUTH LANSDOWNE AVENUE P.O. 80X 457 LANSDOWNE , PA 19050 PHONE(610)623-2660 FAX 610 623-2745 March 9, 2000 Sentry Consumer Discount Company 1505 Market Street Camp Hill PA 17011 RE: NOTICE OF SALE OF REAL PROPERTY: 813 Carol Circle, New Cumberland, PA 17070 Amount of Judgment: $ 6,331.33 Date of Judgment: March 9, 2000 Court Term and Number: Court of Common Pleas of Cumberland County, Docket# 99-4852 Civil Plaintiff: Goldstar Financial, Inc. Defendants: Thomas J. DeAngelo and Marjorie J. DeAngelo and Myles H. Shoop, Jr. and the United States of America Dear Sir or Madam: Please be advised that the property and improvements, if any, located at and known as 813 Carol Circle New Cumberland, PA, 17070 will be sold by the Sheriff of Cumberland County on June 7, 2000 at 10:00 a.m. in the Cumberland County Court House, One Court House Square, Carlisle, PA 17013. This property and improvements are being sold pursuant to a judgment entered as indicated above in favor of the above named plaintiff, and against the above named defendants. The name of the owner, real owner, and reputed owner of the aforementioned property is Myles H. Shoop, Jr. A schedule of distribution will be filed by the Sheriff on a date specified by the Sheriff no later than 30 days after said sale, and distribution will be made in accordance with the schedule unless exceptions are filed thereto within ten (10) days after the date of the filing of said schedule. You should check with the Sheriff's Office by calling 240-6391 to determine the actual date of the filing of the ed e. SinXrely yylurs, rtha E. Von Rosenstiel MARTHA E. VON ROSENSTIEL, P.C. ATTORNEY AT LAW 16 SOUTH LANSDOWNE AVENUE P.O. BOX 457 LANSDOWNE , PA 19050 PHONE(610)623-2660 FAX 610 623-2745 March 9, 2000 East Pennsboro Township 98 South Enda Street Enda, PA RE: NOTICE OF SALE OF REAL PROPERTY: 813 Carol Circle, New Cumberland, PA 17070 Amount of Judgment: $ 6,331.33 Date of Judgment: March 9, 2000 Court Term and Number: Court of Common Pleas of Cumberland County, Docket# 99-4852 Civil Plaintiff: Goldstar Financial, Inc. Defendants: Thomas J. DeAngelo and Marjorie J. DeAngelo and Myles H. Shoop, Jr. and the United States of America Dear Sir or Madam: Please be advised that the property and improvements, if any, located at and known as 813 Carol Circle New Cumberland, PA, 1707C will be sold by the Sheriff of Cumberland County on June 7, 2000 at 10:00 a.m. in the Cumberland County Court House, One Court House Square, Carlisle, PA 17013. This property and improvements are being sold pursuant to a judgment entered as indicated above in favor of the above named plaintiff, and against the above named defendants. The name of the owner, real owner, and reputed owner of the aforementioned property is Myles H. Shoop, Jr. A schedule of distribution will be filed by the Sheriff on a date specified by the Sheriff no later than 30 days after said sale, and distribution will be made in accordance with the schedule unless exceptions are filed thereto within ten (10) days after the date of the filing of sai schedule. You should check with the Sheriff's Office by cal 'n 717 240-6391 to determine the actual date of the filing of e s edule. ncer,gly yours, MARTHA E. VON ROSENSTIEL, P.C. ATTORNEY AT LAW 16 SOUTH LANSDOWNE AVENUE P.O. BOX 457 LANSDOWNE , PA 19050 PHONE(610)623-2660 FAX 610 623-2745 March 9, 2000 United States Treasury Department P.O. Box 12051 Philadelphia, PA 19101 RE: NOTICE OF SALE OF REAL PROPERTY: 813 Carol Circle, New Cumberland, PA 17070 Amount of Judgment: $ 6,331.33 Date of Judgment: March 9, 2000 Court Term and Number: Court of Common Pleas of Cumberland'County, Docket# 99-4852 Civil Plaintiff: Goldstar Financial, Inc. Defendants: Thomas J. DeAngelo and Marjorie J. DeAngelo and Myles H. Shoop, Jr. and the United States of America Dear Sir or Madam: Please be advised that the property and improvements, if any, located at and known as 813 Carol Circle New Cumberland, PA, 17070 will be sold by the Sheriff of Cumberland County on June 7, 2000 at 10:00 a.m. in the Cumberland County Court House, One Court House Square, Carlisle, PA 17013. This property and improvements are being sold pursuant to a judgment entered as indicated above in favor of the above named plaintiff, and against the above named defendants. The name of the owner, real owner, and reputed owner of the aforementioned property is Myles H. Shoop, Jr. A schedule of distribution will be filed by the Sheriff on a date specified by the Sheriff no later than 30 days after said sale, and distribution will be made in accordance with the schedule unless exceptions are filed thereto within ten (10) days after the date of the filing of said schedule. You should check with the Sheriff's office by calling 717 240-6391 to determine the actual date of the filing of the sic le. Sin(;?rely /fours rtha E. Von Rosenstiel MARTHA E. VON ROSENSTIEL, P.C. ATTORNEY AT LAW 16 SOUTH LANSDOWNE AVENUE P.O. BOX 457 LANSDOWNE , PA 19050 PHONE(610)623-2660 FAX 610 623-2745 March 9, 2000 United States of America C/o Department of Justice Washington, DC 20530 RE: NOTICE OF SALE OF REAL PROPERTY: 813 Carol Circle, New Cumberland, PA 17070 Amount of Judgment: $ 6,331.33 Date of Judgment: March 9, 2000 Court Term and Number: Court of Common Pleas of Cumberland County, Docket# 99-4852 Civil Plaintiff: Goldstar Financial, Inc. Defendants: Thomas J. DeAngelo and Marjorie J. DeAngelo and Myles H. Shoop, Jr. and the United States of America Dear Sir or Madam: Please be advised that the property and improvements, if any, located at and known as 813 Carol Circle New Cumberland, PA, 17070 will be sold by the Sheriff of Cumberland County on June 7, 2000 at 10:00 a.m. in the Cumberland County Court House, One Court House Square, Carlisle, PA 17013. This property and improvements are being sold pursuant to a judgment entered as indicated above in favor of the above named plaintiff, and against the above named defendants. The name of the owner, real owner, and reputed owner of the aforementioned property is Myles H. Shoop, Jr. A schedule of distribution will be filed by the Sheriff on a date specified by the Sheriff no later than 30 days after said sale, and distribution will be made in accordance with the schedule unless exceptions are filed thereto within ten (10) days after the date of the filing of said schedule. You should check with the Sheriff's Office by calling 17 240-6391 to determine the actual date of the filing of the Jule. / Sir ,?o6reX ypdl-s, Martha E. Von Rosenstiel MARTHA E. VON ROSENSTIEL, P.C. ATTORNEY AT LAW 16 SOUTH LANSDOWNE AVENUE P.O. BOX 457 LANSDOWNE , PA 19050 PHONE(610)623-2660 FAX 610 623-2745 March 9, 2000 United States of America 228 Walnut Street Harrisburg, PA 17108 RE: NOTICE OF SALE OF REAL PROPERTY: 813 Carol Circle, New Cumberland, PA 17070 Amount of Judgment: $ 6,331.33 Date of Judgment: March 9, 2000 Court Term and Number: Court of Common Pleas of Cumberland County, Docket# 99-4852 Civil Plaintiff: Goldstar Financial, Inc. Defendants: Thomas J. DeAngelo and Marjorie J. DeAngelo and Myles H. Shoop, Jr. and the United States of America Dear Sir or Madam: Please be advised that the property and improvements, if any, located at and known as 813 Carol Circle New Cumberland, PA, 17070 will be sold by the Sheriff of Cumberland County on June 7, 2000 at 10:00 a.m. in the Cumberland County Court House, One Court House Square, Carlisle, PA 17013. This property and improvements are being sold pursuant to a judgment entered as indicated above in favor of the above named plaintiff, and against the above named defendants. The name of the owner, real owner, and reputed owner of the aforementioned property is Myles H. Shoop, Jr. A schedule of distribution will be filed by the Sheriff on a date specified by the Sheriff no later than 30 days after said sale, and distribution will be made in accordance with the schedule unless exceptions are filed thereto within ten (10) days after the date of the filing of said schedule. You should check with the Sheriff's Office by calling 717 240-6391 to determine the actual date of the filing of the schedule. Since y ours artha E. Von Rosenstiel MARTEA E. VON ROSENSTIEL, P. C. ATTORNEY AT LAW 16 SOUTH LANSDOWNE AVENUE P.O. BOX 457 LANSDOWNE , PA 19050 PHONE(610)623-2660 FAX 610 623-2745 March 9, 2000 William C. Lambert and Carol M. Lambert P.O. Box 86 Mt. Joy, PA RE: NOTICE OF SALE OF REAL PROPERTY: 813 Carol Circle, New Cumberland, PA 17070 Amount of Judgment: $ 6,331.33 Date of Judgment: March 9, 2000 Court Term and Number: Court of Common Pleas of Cumberland County, Docket# 99-4852 Civil Plaintiff: Goldstar Financial, Inc. Defendants: Thomas J. DeAngelo and Marjorie J. DeAngelo and Myles R. Shoop, Jr. and the United States of America Dear Sir or Madam: Please be advised that the property and improvements, if any, located at and known as 813 Carol Circle New Cumberland, PA, 17070 will be sold by the Sheriff of Cumberland County on June 7, 2000 at 10:00 a.m. in the Cumberland County Court House, One Court House Square, Carlisle, PA 17013. This property and improvements are being sold pursuant to a judgment entered as indicated above in favor of the above named plaintiff, and against the above named defendants. The name of the owner, real owner, and reputed owner of the aforementioned property is Myles H. Shoop, Jr. A schedule of distribution will be filed by the Sheriff on a date specified by the Sheriff no later than 30 days after said sale, and distribution will be made in accordance with the schedule unless exceptions are filed thereto within ten (10) days after the date of the filing of said schedule. You should check with the Sheriff's Office by calling 717 240-6391 to determine the actual date of the filing of the schedule. Sinc,'ely ours, rtha E. Von Rosenstiel MARTHA E. VON ROSENSTIEL, P.C. ATTORNEY AT LAW 16 SOUTH LANSDOWNE AVENUE P.O. BOX 457 LANSDOWNE , PA 19050 PHONE(610)623-2660 FAX 610 623-2745 March 9, 2000 Corestates Bank k/n/a First Union 510 Walnut Street Mezzanine Philadelphia, PA 19106 RE: NOTICE OF SALE OF REAL PROPERTY: 813 Carol Circle, New Cumberland, PA 17070 Amount of Judgment: $ 6,331.33 Date of Judgment: March 9, 2000 Court Term and Number: Court of Common Pleas of Cumberland County, Docket# 99-4852 Civil Plaintiff: Goldstar Financial, Inc. Defendants: Thomas J. DeMgelo and Marjorie J. DeAngelo*and Myles H. Shoop, Jr. and the United States of America Dear Sir or Madam: Please be advised that the property and improvements, if any, located at and known as 813 Carol Circle New Cumberland, PA, 17070 will be sold by the Sheriff of Cumberland County on June 7, 2000 at 10:00 a.m. in the Cumberland County Court House, One Court House Square, Carlisle, PA 17013. This property and improvements are being sold pursuant to a judgment entered as indicated above in favor of the above named plaintiff, and against the above named defendants. The name of the owner, real owner, and reputed owner of the aforementioned property is Myles H. Shoop, Jr. A schedule of distribution will be filed by the Sheriff on a date specified by the Sheriff no later than 30 days after said sale, and distribution will be made in accordance with the schedule unless exceptions are filed thereto within ten (10) days after the date of the filing of said schedule. You should check with the Sheriff's Office by calling 717 240-6391 to determine the actual date of the filing of the schedule. Since y ouurs, rtha osenstiel ?, ? C1'. (_ ?: 'j?? ' J $L ? i i ?? ?1'. 1 1 C_. ? - ? J .? -7 i ... C> Martha E. Von Rosenstiel, P.C. Attorney for Plaintiff Martha E. Von Rosenstiel 16 South Lansdowne Avenue P.O. Box 457 Lansdowne, PA 19050 610 623-2660 Attorney I.D.# 52634 : COURT OF COMMON PLEAS Goldstar Financial, Inc. : CUMBERLAND COUNTY 312 West First Street Sanford FL 32771 Plaintiff : NO: 99-4852 Civil VS. Thomas J. DeAngelo and Marjorie : J. DeAngelo and Myles H. Shoop, : Jr. 813 Carol Circle New Cumberland, PA 17070 and The United States of America 228 Walnut Street Harrisburg, PA 17108 Defendants AFFIDAVIT OF NOTICE PURSUANT TO RULE 3129.1 COMMONWEALTH OF PENNSYLVANIA: COUNTY OF DELAWARE SS MARTHA E. VON ROSENSTIEL, attorney for the 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 813 Carol Circle, New Cumberland, PA 17070: 1. Name and address of owners(s) or reputed owner(s) Myles H. Shoop, Jr. 813 Carol Circle New Cumberland, PA 17070 2. Name and address of defendant(s) in the judgment: Myles H. Shoop, Jr. 813 Carol Circle New Cumberland, PA 17070 Thomas J. DeAngelo 733 Linden Avenue Johnstown, PA 15902 Marjorie J. DeAngelo 733 Linden Avenue Johnstown, PA 15902 United States of America 228 Walnut Street Harrisburg, PA 17070 3. Name and address of every judgment creditor whose judgment is a record lien on the real property to be sold: Corestates Bank k/n/a First Union 510 Walnut Street Mezzanine Philadelphia, PA 19106 William C. Lambert and Carol M. Lambert P.O. Box 86 Mt. Joy, PA United States of America 228 Walnut Street Harrisburg, PA 17108 United States of America C/o Department of Justice Washington, DC 20530 United States Treasury Department P.O. Box 12051 Philadelphia, PA 19101 East Pennsboro Township 98 South Ends Street Ends, PA 4. Name and address of the last recorded holder of every mortgage of record: Sentry Consumer Discount Company 1505 Market Street Camp Hill PA 17011 5. Name and address of every other person who has any record lien on the property: 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: NONE 7. Name and address of every other person of whom plaintiff has knowledge who has any interest in the property which may be affected by the sale: Cumberland County Domestic Relations One Courthouse Square Carlisle, PA 17013 I verify that the statements made in this aff idavit are true and correct to the best of my personal knowledge or information and belief. I understand that false statements herein are made subject to the penalties of 18 Pa. C.S. Section 4904 relating to unsworn falsification to authorities. -,----7 M6rtha E. Von o? senstiel Attorney for Plaintiff .1 Martha E. Von Rosenstiel, P.C Martha E. Von Rosenstiel 16 South Lansdowne Avenue P.O. Box 457 Lansdowne, PA 19050 610 623-2660 Attorney I.D.# 52634 Goldstar Financial, Inc 312 West First Street Sanford, FL 32771 Attorney for Plaintiff : COURT OF COMMON PLEAS : CUMBERLAND COUNTY Plaintiff VS. Thomas J. DeAngelo and Marjorie : J. DeAngelo and Myles H. Shoop, : Jr. 813 Carol Circle New Cumberland, PA 17070 and The United States of America 228 Walnut Street Harrisburg, PA 17108 Defendants No: 99-4852 Civil THIS IS AN ATTEMPT TO COLLECT A DEBT ANY INFORMATION OBTAINED WILL BE USED FOR THAT PURPOSE NOTICE OF SHERIFF'S SALE OF REAL PROPERTY TO: Thomas J. DeAngelo and Marjorie J. DeAngelo 733 Linden Avenue Johnstown, PA 15902 Myles H. Shoop, Jr. 813 Carol Circle New Cumberland, PA 17070 United States of America 228 Walnut Street Harrisburg, PA 17108 Your house and/or real estate at 813 Carol Circle, New Cumberland, PA 17070 is scheduled to be sold at Sheriff's Sale on September 6, 2000 at 10:00 a.m. to enforce the court judgment of $6,331.33 obtained by Goldstar Financial, Inc. against you. NOTICE OF OWNERS RIGHTS V YOU MAY BE ABLE TO PREVENT THIS SHERIFF'S SALE To prevent this Sheriff's Sale you must take IMMEDIATE action: 1. The sale will be cancelled if you pay to Goldstar Financial, Inc. the back payments, late charges, costs and reasonable attorney's fees due. To find out how much you must pay, you may call 610 623-2660. 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 contact an attorney to assert your rights. The sooner you contact one, the more chance you will have of stopping the sale. (See notice on page two on how to obtain an attorney) YOU MAY STILL BE ABLE TO SAVE YOUR PROPERTY AND YOU HAVE OTHER RIGHTS EVEN IF THE SHERIFF'S SALE DOES TAKE PLACE. 1. If the Sheriff's Sale is not stopped, your property will be sold to the highest bidder. You may find out the bid price by calling 610 623-2660. 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 in the sale. To find out if this has happened you may call 610 623-2660. 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. S. 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 on a date to be announced by the Sheriff. This schedule will state who will be r receiving that money. The money will be paid out in accordance with this schedule unless exceptions (reasons why the proposed distribution is wrong) are filed with the Sheriff within ten (10) days after the Schedule of Distribution is posted. 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. COURT ADMINISTRATOR 4' FLOOR CUMBERLAND COUNTY COURT HOUSE CARLISLE, PA 17013 Telephone: 717 240-6200 CLAIM FOR EXEMPTION To the Sheriff: I, the above named defendant, claim exemption of property from levy or attachment: (1) From my real property in my possession which has been .levied upon, (a) I desire that my $300.00 statutory exemption be set-aside in kind (specify real property to be set-aside in kind) : I request a prompt court hearing to determine the exemption. Notice of the hearing should be given to me at (Address) (Telephone Number) I verify that the statements made in this Claim for Exemption are true and correct. I understand that false statements herein are made subject to the penalties of 18 Pa. C.S. Section 4904 relating to unsworn falsification to authorities. Date: Signature THIS CLAIM TO BE FILED WITH THE OFFICE OF THE SHERIFF CUMBERLAND COUNTY COURT HOUSE ONE COURT HOUSE SQUARE CARLISLE, PA 17013 717 240-6391 I MARTHA E. VON ROSENSTIEL, P.C. ATTORNEY AT LAW 16 SOUTH LANSDOWNE AVENUE P.O. BOX 457 LANSDOWNE , PA 19050 PHONE(610)623-2660 FAX 610 623-2745 March 9, 2000 TO: Thomas J. DeAngelo & Marjorie J. DeAngelo 733 Linden Avenue Johnstown, PA 15902 RE: NOTICE OF SALE OF REAL PROPERTY: 813 Carol Circle, New Cumberland, PA 17070 Amount of Judgment: $ 6,331.33 Date of Judgment: March 9, 2000 Court Term and Number: Court of Common Pleas of Cumberland County, Docket# 99-4852 Civil Plaintiff: Goldstar Financial, Inc. Defendants: Thomas J. DeAngelo and Marjorie J. DeAngelo and Myles H. Shoop, Jr. and the United States of America Dear Mr. and Mrs. DeAngelo: Please be advised that the property and improvements, if any, located at and known as 813 Carol Circle, New Cumberland, PA, 17070 will be sold by the Sheriff of Cumberland County on September 6, 2000 at 10:00 a.m. in the Cumberland County Court House, One Court House Square, Carlisle, PA 17013. This property and improvements are being sold pursuant to a judgment entered as indicated above in favor of the above named plaintiff, and against the above named defendants. The name of the owner, real owner, and reputed owner of the aforementioned property is Myles H. Shoop, Jr. A schedule of distribution will be filed by the Sheriff on a date specified by the Sheriff no later than 30 days after said sale, and distribution will be made in accordance with the schedule unless exceptions are filed thereto within ten (10) days after the date of the filing of said schedule. You should check with the Sheriff's office by calling 717 240-6391 to determine the actual date of the filing of the schedule. Sincerely yours, Martha E. Von Rosenstiel MARTHA E. VON ROSENSTIEL, P. C. ATTORNEY AT LAW 16 SOUTH LANSDOWNE AVENUE P.O. BOX 457 LANSDOWNE , PA 19050 PHONE(610)623-2660 FAX 610 623-2745 March 9, 2000 TO: Myles H. Shoop, Jr. 813 Carol Circle New Cumberland, PA 17070 RE: NOTICE OF SALE OF REAL PROPERTY: 813 Carol Circle, New Cumberland, PA 17070 Amount of Judgment: $ 6,331.33 Date of Judgment: March 9, 2000 Court Term and Number: Court of Common Pleas of Cumberland County, Docket# 99-4852 Civil Plaintiff: Goldstar Financial, Inc. Defendants: Thomas J. DeAngelo and Marjorie J. DeAngelo and Myles H. Shoop, Jr. and the United States of America Dear Mr. Shoop: Please be advised that the property and improvements, if any, located at and known as 813 Carol Circle New Cumberland, PA, 17070 will be sold by the Sheriff of Cumberland County on September 6, 2000 at 10:00 a.m. in the Cumberland County Court House, One Court House Square, Carlisle, PA 17013. This property and improvements are being sold pursuant to a judgment entered as indicated above in favor of the above named plaintiff, and against the above named defendants. The name of the owner, real owner, and reputed owner of the aforementioned property is Myles H. Shoop, Jr. A schedule of distribution will be filed by the Sheriff on a date specified by the Sheriff no later than 30 days after said sale, and distribution will be made in accordance with the schedule unless exceptions are filed thereto within ten (10) days after the date of the filing of said schedule. You should check with the Sheriff's Office by calling 717 240-6391 to determine the actual date of the filing of the schedule. Sincerely yours, Martha E. Von Rosenstiel MARTHA E. VON ROSENSTIEL, P. C. ATTORNEY AT LAW 16 SOUTH LANSDOWNE AVENUE P.O. BOX 457 LANSDOWNE , PA 19050 PHONE(610)623-2660 FAX 610 623-2745 March 9, 2000 TO: United States of America 228 Walnut Street Harrisburg, PA 17108 RE: NOTICE OF SALE OF REAL PROPERTY: 813 Carol Circle, New Cumberland, PA 17070 Amount of Judgment: $ 6,331.33 Date of Judgment: March 9, 2000 Court Term and Number: Court of Common Pleas of Cumberland County, Docket# 99-4852 Civil Plaintiff: Goldstar Financial, Inc. Defendants: Thomas J. DeAngelo and Marjorie J. DeAngelo and Myles H. Shoop, Jr. and the United States of America Dear Sir or Madam: Please be advised that the property and improvements, if any, located at and known as 813 Carol Circle New Cumberland, PA, 17070 will be sold by the Sheriff of Cumberland County on September 6, 2000 at 10:00 a.m. in the Cumberland County Court House, One Court House Square, Carlisle, PA 17013. This property and improvements are being sold pursuant to a judgment entered as indicated above in favor of the above named plaintiff, and against the above named defendants. The name of the owner, real owner, and reputed owner of the aforementioned property is Myles H. Shoop, Jr. A schedule of distribution will be filed by the Sheriff on a date specified by the Sheriff no later than 30 days after said sale, and distribution will be made in accordance with the schedule unless exceptions are filed thereto within ten (10) days after the date of the filing of said schedule. You should check with the Sheriff's office by calling 717 240-6391 to determine the actual date of the filing of the schedule. Sincerely yours, Martha E. Von Rosenstiel K. M Z W F . W F Z Z w Z O Z L El -zt L) U 2 ' 1 Z F In 19 d L OZ FO 6 ?p .<E.. , U G. •-.w. <d . . . t r A Martha E. Von Rosenstiel, P.C. Attorney for Plaintiff Martha E. Von Rosenstiel, Esquire 16 South Lansdowne Avenue P.O. Box 457 Lansdowne, PA 19050 610 623-2660 Attorney I.D.# 52634 GOLDSTAR FINANCIAL, INC. COURT OF COMMON PLEAS OF 312 WEST FIRST STREET CUMBERLAND COUNTY SANFORD FL 32771 V. THOMAS J. DeANGELO AND MAJORIE NO G 7 /r/?? o? ('?V J. DeANGELO, Mortgagors and MYLES H. SHOOP, JR., Real Owner 813 CAROL CIRCLE NEW CUMBERLAND, PA 17070 and UNITED STATES OF AMERICA C/o United States Attorney for the Middle District of Pennsylvania 228 Walnut Street Harrisburg, PA 17108 CIVIL ACTION - MORTGAGE FORECLOSURE You have been sued in court. If you wish to defend against the claims set forth in the following pages, you must take action within twenty (20) days after this complaint and notice are served, by entering a written appearance personally or by attorney and filing in writing with the court your defenses or objections to the claims set forth against you. You are warned that if you fail to do so the case may proceed without you and a judgment may be entered against you by the court without further notice for any money claimed in the complaint or for any other claim or relief requested by the plaintiff. You may lose money or property or other rights important to you. YOU SHOULD TARE THIS PAPER TO YOUR LAWYER AT ONCE. IF YOU DO NOT HAVE A LAWYER OR CANNOT AFFORD ONE, GO TO OR TELEPHONE THE OFFICE 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 or 1 800 990 9108 .d, Attorney for Plaintiff FINANCIAL, INC. COURT OF COMMON PLEAS OF 312 WEST FIRST STREET CUMBERLAND COUNTY SANFORD FL 32771 Martha E. Von Rosenstiel, P.C. Martha E. Von Rosenstiel, Esquire 16 South Lansdowne Avenue P.O. Box 457 Lansdowne, PA 19050 610 623-2660 Attorney I.D.# 52634 GOLDSTAR V. THOMAS J. DeANGELO AND MAJORIE NO. J. DeANGELO, Mortgagors and MYLES H. SHOOP, JR., Real Owner 813 CAROL CIRCLE NEW CUMBERLAND, PA 17070 and UNITED STATES OF AMERICA c/o United States Attorney for the Middle District of Pennsylvania 228 Walnut Street Harrisburg, PA 17108 CIVIL ACTION - MORTGAGE FORECLOSURE 1. Plaintiff is Goldstar Financial, Inc. a corporation organized and existing under the laws of the United States of America with corporate offices at 312 West First Street, Sanford FL 32771. 2. Defendants, Thomas J. DeAngelo and Marjorie J. DeAngelo, are the mortgagors and Myles H. Shoop, Jr. is the real owner, of premises 813 Carol Circle, New Cumberland, PA 17070, hereinafter described, whose last known address is the same as above. 3. The United States of America is made a defendant herein by virtue of certain federal tax liens, hereinafter described, r .1 r A . , which stand against the defendant Myles H. Shoop, Jr., pursuant to 28 U.S.C. Section 2410. 4. Plaintiff brings this action in mortgage foreclosure against defendants, mortgagors and real owners, to foreclose a j certain indenture of mortgage made, executed and delivered by the above named defendants, mortgagors to First Pennsylvania Banking and Trust Company on April 5, 1974, which mortgage is recorded in the office for the Recording of Deeds of Cumberland County in Mortgage Book 576 page 358, secured on premises 813 Carol Circle, New Cumberland, PA 17070, a true and correct description of which is attached hereto as Exhibit I. 5. Corestates Bank f/k/a, First Pennsylvania Banking and Trust Company assigned the said mortgage to Eastern Mortgage Services, Inc., by written assignment which was lodged with the Office for the Recording of Deeds of Cumberland County for recording. 6. Eastern Mortgage Services, Inc., assigned the said mortgage to Goldstar Financial, Inc., by written assignment which has been lodged with the Office for the Recording of Deeds of Cumberland County. 7. On September 15, 1976 title to the mortgaged premises was transferred from Thomas J. DeAngelo and Marjorie J. DeAngelo to Myles H. Shoop, Jr. by Deed which was recorded on September 15, 1976 in the Office for the Recording of Deeds of Cumberland County in Deed Book U-26 page 388. 8. Plaintiff alleges each and every term, condition and covenant in the aforesaid mortgage, and hereby incorporates them + , herein by reference thereto. r 9. The aforesaid mortgage is in default in that the defendants, mortgagors and real owner have failed to make payment of the monthly installments of principal and interest in accordance with the terms of the mortgage, for the month of June, 1998 and each month thereafter, up to and including the present time. 10. The following is an itemized statement of the amount due plaintiff under the terms of the aforesaid mortgage: Principal $ 3,044.76 Interest from 05/01/98 to 06/30/99 at $ 0.72 per diem $ 306.72 Accrued Late charges from 04/05/74 to 06/15/99 at $10.66 per month $ 138.58 Escrow balance $ (1,514.75) Monthly inspections from 06/01/98 to 06101199 at $15.00 per month $ 195.00 Reasonable Attorney's fee $ 800.00 Title information certificate $ 325.00 Photostats and postage $ 35.00 Notarizations $ 10.00 Total $ 3,340.31 11. The defendant United States of America is the holder of a federal tax liens against the defendant Myles H. Shoop, Jr., Real Owner, as follows: Federal Tax Lien #6608 in the amount of $48,306.70 lodged with the Prothonotary of the Court of Common Pleas of Cumberland County on October 14, 1992. Federal Tax Lien #97-1833 in the amount of $65,561.56 lodged with the Prothonotary of the Court of Common Pleas of Cumberland County on April 8, 1997. 12. The above liens, lodged by the District Director of the Internal Revenue Service at Harrisburg, Pennsylvania, are against Myles H. Shoop, Jr., defendant, and real owner herein. z , A 13. A judicial sale of the premises is intended. 14. Plaintiff sent to defendants, mortgagors and real owner A on April 16, 1999 a Notice and Warning of Intention to Foreclose (copies attached hereto as Exhibit II). To date, defendants have not made payments as required. 15. Plaintiff sent to defendants Notice of Homeowners, Emergency Assistance Act of 1983 advising them of their rights under the statue (copies attached as Exhibit III). To date the defendants have neither made payment nor indicated that they have taken any steps to avail themselves of the financial assistance made through this legislation within the time established by this statute. 16. Pursuant to the Fair Debt Collection Practices Act, 15 U.S.C. 1692 et seq. (1977), defendants may dispute the validity of the debt or any portion thereof. If defendants do so in writing within thirty (30) days of receipt of this pleading, counsel for Plaintiff will obtain and provide defendants with written verification thereof; otherwise, the debt will be assumed to be valid. Likewise, if requested within thirty (30) days of receipt of this pleading, counsel for Plaintiff will send defendants the name and address of the original creditor if different from above. WHEREFORE, plaintiff demands judgment for $3,340.31., plus per diem interest at $0.72 from 06/30/99 to the date of judgment plus monthly late charges of $10.66 from 06/15/99 to the date of judgment plus monthly inspections of $15.00 from 06/01/99 to the date of judgment and escrow advances of $287.62 per month from t + r 06/01/99 to the date of judgment forecl sure and sale of the mortgaged premises plus costs hereon. Martha E. o osenstiel Attorney for Plaintiff EMS# 1670000412 Our File# 6348 VERIFICATION I verify that the statements made in the foregoing Complaint are true and correct. I understand that false statements herein are made subject to penalties of 18 Pa.C.S. Section 4904 relating to unsworn falsification to authorities. BY: TITLE: DATED ;.?/ ? / ?/ A ALL THAT CERTAIN piece or parcel of land situate in New Cumberland, Cumberland County, Pennsylvania, more particularly bounded and described as follows, in accordance with survey of Michael C. DeAngelo, R.S., dated March 20, 1974, to wit: BEGINNING at an "X" cut in the sidewalk which point is 361.98 feet in a Southwesterly direction along the Northerly line of Carol Circle from the intersection of Carol Circle and Brandt Avenue; thence South 70 degrees 10 minutes 50 seconds West along the dividing line between the herein described Lot and Lot No. 9 on the hereinafter mentioned Plan of Lots a distance of 98.20 feet to a pin; thence South 19 degrees 48 minutes East along the right-of-way line with the York-Baltimore Expressway a distance of 181.69 feet to a pipe; thence North 19 degrees 10 minutes 10 seconds East along the dividing line between the herein described Lot and Lot No. 7 on the hereinafter mentioned Plan of Lots, a distance of 175.64 feet to a pipe; thence along a curve to the right having a radium of 40 feet, an arc distance of 50 feet to the "X" cut in the sidewalk, the place of beginning. BEING Lot No. 8 on the Plan of Lots laid out by Leon Bear, and recorded in the Cumberland County Recorder's Office in Plan Book 7, page 22. HAVING thereon erected a 1-1l2 story brick dwelling house known and numbered as 813 Carol Circle. BEING Tau Parcel Number 26.23-0543-209. Date: April 16, 1999 Certified Mail/RRR TO: Myles H. Shoop, Jr. 813 Carol Circle New Cumberland, PA 17070 RE: Mortgaged Premises 813 Carol Circle New Cumberland, PA 17070 Loan #1670000412 This company is the holder of the FIRST MORTGAGE (AND NOTE) on the above premises, or is the mortgage service agent for such holder (Hereinafter referred to as we, us or ours). DEFAULT Monthly payments at $554.00 p/m from 06/01/98 to 04/01/99 THE MORTGAGE IS IN SERIOUS $ 6,648.00 Late charges at $10.66 p/m from 06116198 to 04/16/99 Suspense $ 127.92 ($ 129.25 ) The total amount now required to cure this default, or in other words cret caught up in Your payments as of the date of this letter is $ 6,646.67 THIRTY (30) DAYS of the date during this period. Such payment must be made either by cash, cashier's check, certified check or money order, and paid at or sent to: Eastern Capital Markets, 2700 Westhall Lane, Suite 240, Maitland, FL 32751 Attn: Faith Fritz. If you do not cure the default within THIRTY (30) DAYS, we This means that whatever is owing on the original amount borrowed will be considered due immediately and you may lose the chance to pay off the original mortgage in monthly installments. If full payment of the amount of default is not made within THIRTY (30) DAYS, we also intend to instruct our attorneys to start a lawsuit to foreclose your mortaacred property. If the mortaacte is „ay uLL mane morrgave geoc. it we reter your case to our attorneys, but you cure the default before they begin legal proceedings against you, you will still have to pay the reasonable attorney's fees, actually incurred, up to $50.00. However, if legal proceedings are started against you, you will have to pay the reasonable attorney's fees even if they are over $50.00. Any attorney's fees will be added to whatever you owe us, which may also include our reasonable costs. If you cure We may also sue you personally for the unpaid principal balance and all other sums due under the mortgage. If you have not cured the default within the thirty day period and foreclosure proceedings have begun, you still have the right to other requirements under the mortgage). It is estimated that the earliest date that such sheriff's sale could be held would be approximately one hundred and fifty (150) days from the date of this letter. A notice of the date of the sheriff's sale will be sent to you before the sale. of course, the amount needed to cure the default will increase the longer you wait. You may find out at any time exactly what the required payments will be by calling the following number: 888 225-9911. The payment must be in cash, cashiers check, certified check or money order and made payable to us at the address previously stated. You should realize the a sheriff's sale will end your ownership of the mortgaged property and your right to remain in it. If you continue to live in the property after the sheriff's sale, a lawsuit could be started to evict you. You have additional rights to help protect your interest in the property. YOU HAVE THE RIGHT TO SELL THE PROPERTY TO OBTAIN MONEY TO PAY OFF THE MORTGAGE DEBT, OR TO BORROW MONEY FROM ANOTHER LENDING INSTITUTION TO PAY OFF THIS DEBT. YOU MAY HAVE THE RIGHT TO SELL OR TRANSFER THE PROPERTY SUBJECT TO THE MORTGAGE TO A BUYER OR TRANSFEREE WHO WILL ASSUME THE MORTGAGE DEBT, PROVIDED THAT ALL THE OUTSTANDING PAYMENTS, CHARGES AND ATTORNEY'S FEES AND COSTS ARE PAID PRIOR TO OR AT THE SALE (AND THAT THE OTHER REQUIREMENTS UNDER THE MORTGAGE ARE SATISFIED). CONTACT US TO DETERMINE UNDER WHAT CIRCUMSTANCES THE RIGHT MIGHT EXIST. YOU HAVE THE RIGHT TO HAVE THIS DEFAULT CURED BY ANY THIRD PARTY ACTING ON YOUR BEHALF. If you cure the default, the mortgage will be restored to the naa occurred. However, you are not entitled to this right to cure your default more than three times in any calendar year. r Sincerely yours, Martha E. Von Rosenstiel for Eastern Mortgage Services Date : April 16 , 1999 Certified Mail/RRR NOTICE OF INTENTION TO FORECLOSE MORTGAGE AND ACCELERATE LOAN BALANCE UNDER SECTION 403 OF PENNSYLVANIA ACT NO. 6 OF 1974 TO: Thomas J. DeAngelo 813 Carol Circle New Cumberland, PA 17070 RE: Mortgaged Premises 813 Carol Circle New Cumberland, PA 17070 Loan #1670000412 This company is the holder of the FIRST MORTGAGE (AND NOTE) on the above premises, or is the mortgage service agent for such holder (Hereinafter referred to as we, us or ours). DEFAULT THE MORTGAGE IS IN SERIOUS Monthly payments at $554.00 p/m from 06/01/98 to 04/01/99 $ 6,648.00 Late charges at $10.66 p/m from 06116198 to 04/16/99 $ 127.92 Suspense ($ 129.25 The total amount now required to cure this default, or in other words, get caught up in your payments as of the date of this letter is $ 6,646.67 THIRTY (30) DAYS of the date during this period. Such payment must be made either by cash, cashier's check, certified check or money order, and paid at or sent to: Eastern Capital Markets, 2700 Westhall Lane, Suite 240, Maitland, FL 32751 Attn: Faith Fritz. If you do not cure the default within THIRTY (30) DAYS, we intend to exercise our right to accelerate the mortgage payments. This means that whatever is owing on the original amount borrowed will be considered due immediately and you may lose the chance to pay off the original mortgage in monthly installments. If full payment of the amount of default is not made within THIRTY (30) DAYS, we also intend to instruct our attorneys to start a lawsuit pay off the mortgage debt. If we refer your case to our + attorneys, but you cure the default before they begin legal proceedings against you, you will still have to pay the reasonable attorney's fees, actually incurred, up to $50.00. However, if legal proceedings are started against you, you will have to pay the reasonable attorney's fees even if they are over $50.00. Any attorney's fees will be added to whatever you owe us, which may also include our reasonable costs. If You cure tl,c A-F-...1? ....-L_- -?- -I"-, _ We may also sue you personally for the unpaid principal balance and all other sums due under the mortgage. If you have not cured the default within the thirty day period and foreclosure proceedings have begun, you still have the right to UUiicr reuuiremencs unaer the mortcraa-1. It is estimated that the earliest date that such sheriff's sale could be held would be approximately one hundred and fifty (150) days from the date of this letter. A notice of the date of the sheriff's sale will be sent to you before the sale. of course, the amount needed to cure the default will increase the longer you wait. You may find out at any time exactly what the required payments will be by calling the following number: 888 225-9911. The payment must be in cash, cashiers check, certified check or money order and made payable to us at the address previously stated. You should realize the a sheriff's sale will end your ownership of the mortgaged property and your right to remain in it. If you continue to live in the property after the sheriff's sale, a lawsuit could be started to evict you. You have additional rights to help protect your interest in the property. YOU HAVE THE RIGHT TO SELL THE PROPERTY TO OBTAIN MONEY TO PAY OFF THE MORTGAGE DEBT, OR TO BORROW MONEY FROM ANOTHER LENDING INSTITUTION TO PAY OFF THIS DEBT. YOU MAY HAVE THE RIGHT TO SELL OR TRANSFER THE PROPERTY SUBJECT TO THE MORTGAGE TO A BUYER OR TRANSFEREE WHO WILL ASSUME THE MORTGAGE DEBT, PROVIDED THAT ALL THE OUTSTANDING PAYMENTS, CHARGES AND ATTORNEY'S FEES AND COSTS ARE PAID PRIOR TO OR AT THE SALE (AND THAT THE OTHER REQUIREMENTS UNDER THE MORTGAGE ARE SATISFIED). CONTACT US TO DETERMINE UNDER WHAT CIRCUMSTANCES THE RIGHT MIGHT EXIST. YOU RAVE THE RIGHT TO HAVE THIS DEFAULT CURED BY ANY THIRD PARTY ACTING ON YOUR BEHALF. If You cure the default, the mortgage will be restored to the not entitled to this right to cur-u occu. , are e yourrdefaultomorerthanuthree times in any calendar year. Sinc sly ours, Martha Von Rosenstiel for Eastern Mortgage Services Date: April 16, 1999 Certified Mail/RRR NOTICE OF INTENTION TO FORECLOSE MORTGAGE AND ACCELERATE LOAN BALANCE UNDER SECTION 403 OF PENNSYLVANIA ACT NO 6 OF 1974 TO: Marjorie J. DeAngelo 813 Carol Circle New Cumberland, PA 17070 RE: Mortgaged Premises 813 Carol Circle New Cumberland, PA 17070 Loan #1670000412 This company is the holder of the FIRST MORTGAGE (AND NOTE) on the above premises, or is the mortgage service agent for such holder (Hereinafter referred to as we, us or ours). As of the date of this notice, THE MORTGAGE IS IN SERIOUS DEFAULT because you have not made the monthly Payments as lis and/or for other reasons as indicated below: Monthly payments at $554.00 p/m from 06/01/98 to 04/01/99 $ 6,648.00 Late charges at $10.66 p/m from 06/16/98 to 04/16/99 $ 127.92 Suspense ($ 129.25 ) The total amount now required to cure this default, or in other words, get caught up in your payments as of the date of this letter is $ 6,646.67 THIRTY (30) DAYS of the date during this period. Such payment must be made either by cash, cashier's check, certified check or money order, and paid at or sent to: Eastern Capital Markets, 2700 Westhall Lane, Suite 240, Maitland, FL 32751 Attn: Faith Fritz. If you do not cure the default within THIRTY (30) DAYS, we intend to exercise our right to accelerate the mortgage pavments. This means that whatever is owing on the original amount borrowed will be considered due immediately and you may lose the chance to pay off the original mortgage in monthly installments. If full payment of the amount of default is not made within THIRTY (30) DAYS, we also intend to instruct our attorneys to start a lawsuit to foreclose your mortgaged property. If the mortgage is foreclosed your mortoacied orooerty may be sold by the Sheriff to pay off the mortcracre debt. If we refer your case to our attorneys, but you cure the default before they begin legal proceedings against you, you will still have to pay the reasonable attorney's fees, actually incurred, up to $50.00. However, if legal proceedings are started against you, you will have to pay the reasonable attorney's fees even if they are over $50.00. Any attorney's fees will be added to whatever you owe us, which may also include our reasonable costs. If you cure the default within the thirty day oeriod, you will not be required to pay attorney's fees. We may also sue you personally for the unpaid principal balance and all other sums due under the mortgage. If you have not cured the default within the thirty day period and foreclosure proceedings have begun, you still have the right to other requirements under the mortaaae). It is estimated that the earliest date that such sheriff's sale could be held would be approximately one hundred and fifty (150) days from the date of this letter. A notice of the date of the sheriff's sale will be sent to you before the sale. Of course, the amount needed to cure the default will increase the longer you wait. You may find out at any time exactly what the required payments will be by calling the following number: 888 225-9911. The payment must be in cash, cashiers check, certified check or money order and made payable to us at the address previously stated. You should realize the a sheriff's sale will end your ownership of the mortgaged property and your right to remain in it. If you continue to live in the property after the sheriff's sale, a lawsuit could be started to evict you. You have additional rights to help protect your interest in the property. YOU HAVE THE RIGHT TO SELL THE PROPERTY TO OBTAIN MONEY TO PAY OFF THE MORTGAGE DEBT, OR TO BORROW MONEY FROM ANOTHER LENDING INSTITUTION TO PAY OFF THIS DEBT. YOU MAY HAVE THE RIGHT TO SELL OR TRANSFER THE PROPERTY SUBJECT TO THE MORTGAGE TO A BUYER OR TRANSFEREE WHO WILL ASSUME THE MORTGAGE DEBT, PROVIDED THAT ALL THE OUTSTANDING PAYMENTS, CHARGES AND ATTORNEY'S FEES AND COSTS ARE PAID PRIOR TO OR AT THE SALE (AND THAT THE OTHER REQUIREMENTS UNDER THE MORTGAGE ARE SATISFIED). CONTACT US TO DETERMINE UNDER WHAT CIRCUMSTANCES THE RIGHT MIGHT EXIST. YOU HAVE THE RIGHT TO HAVE THIS DEFAULT CURED BY ANY THIRD PARTY ACTING ON YOUR BEHALF. If you cure the default, the mortgage will be restored to the - - ---? u° ?? .., uc,-ault naa occurred. However, you are not entitled to this right to cure your d ault more than three times in any calendar year. S' cer y yours, Martha E. Von Rosenstiel for Eastern Mortgage Services ACT 91 NOTICE TAKE ACTION TO SAVE YOUR HOME FROM FORECLOSURE THE COMMONWEALTH OF PENNSYLVANIA'S HOMEOWNER'S EMERGENCY MORTGAGE ASSISTANCE PROGRAM MAY BE ABLE TO HELP YOU READ THE FOLLOWING NOTICE TO FIND OUT HOW THE PROGRAM WORKS. Ifyou need more information, call the Pennsylvania Housing Financing Agency at 1-800-342.2397. La notification en adjucto es de suma importaneia, pues afecta su dmcho a continuar viviendo ea su casa. Si no comprende el conlenido de esla notification obtenga una traduccion immediatamente Ilamanda esta'ageneia (Pennsylvania Housing Finance Agency) sin cargos aI numero memionado arriba. Puedes ser elegible Para un prestarno por el programa Ilamado :Homeowner's Emergency Mortgage Assistance Pm&=" el cual puede salvar su casa de In perdida del derecho a redimir so hipoteca. IMPORTANT: NOTICE. OF HOMEOWNERS' EMERGENCY MORTGAGE ASSISTANCE PROGRAM PLEASE READ THIS NOTICE. "".. , LENDER "`. Martha E. Von Rosenstiel, P.C. 16 South Lansdowne Avenue P.O. Box 457 Lansdowne, PA 19050 610 623-2660 ACT 91 NOTICE TARE ACTION TO SAVE YOUR HOME FROM FORECLOSURE The Commonwealth of Pennsylvania's Homeowner's Emergency Mortgage Assistance Program may be able to help you. Read the following notice to find out how the program works. If you need more information call the Pennsylvania Housing Finance Agency at 1(800) 342-2397. La notificacion en adjunto es de suma importancia, pues afecta su derecho a continuar viviendo en su casa. Si no comprende el contenido de esta notificacion obtenga una traduccion immediatamente llamanda esta agencia (Pennsylvania Housing Finance Agency) sin cargos al numero mencionado arriba. Puedes ser elegible para un prestamo por el programa llmando "Homeowner's Emergency Mortgage Assistance Program" el cual puede salvar su casa de la perdida del derecho a redimir su hipoteca. IMPORTANT: NOTICE OF HOMEOWNERS' EMERGENCY MORTGAGE ASSISTANCE ACT OF 1983 PLEASE READ THIS NOTICE. MAY BE- ELIGIBLE FOR FINANCIAL ASSISTANCE WHICH CAN SAVE YOUR HOME FROM FORECLOSURE AND HELP MARIE FUTURE MORTGAGE PAYMENTS DATE: April 16, 1999 ACCOUNT# 1670000412 TO: Myles H. Shoop 813 Carol Circle New Cumberland, PA 17070 FROM: Martha E. Von Rosenstiel, Esquire Attorney for Eastern Mortgage Services Inc. Under the Act, you are entitled to a temporary stay of foreclosure on your mortgage for thirty (30) days from the date of this Notice. During that time you must arrange and attend a "face-to-face" meeting with a representative of this lender, or with a designated consumer credit counseling agency. The purpose of this meeting is to attempt to work out a repayment plan, or to otherwise settle your delinquency. This meeting must occur in the next thirty 30 days. If you attend a face-to-face meeting with this lender, or with a consumer credit counseling agency identified in this notice, no further proceedings in mortgage foreclosure may take place for thirty (30) days after the date of the meeting. The name, address and telephone number of the representative is: Ms. Faith Fritz Eastern Capital Markets 2700 Westhall Lane Ste 240 Maitland, FL 32751 407 475-0433 The name(s) and addresses) of designated consumer credit counseling agencies are: SEE ATTACHED LIST It is only necessary to schedule one face-to-face meeting. You should advise this lender immediately of your intentions. Your mortcaoe is in serious default because you have failed to pay promptly installments of principal and interest, as required, for a period of at least sixty (60) days. The total amount of the delinquency is $6,646.67. This sum includes the following: Monthly payments 06/01/98 through 04/ at $554.00 per month Late charges through 04/15/99 Suspense TOTAL AMOUNT DUE If you have tried and are unable problem at or after your face-to-face 01/99 $ 6,648.00 $ 127.92 $ (129.25) $ 6,646.67 to resolve this meeting, you have the right to apply for financial assistance from the Homeowners' Emergency Mortgage Assistance Fund. In order to do this, you must fill out, sign and file a completed Homeowners' Emergency Assistance Application with one of the designated consumer credit counseling agencies listed above. An application for assistance may only be obtained from a consumer credit counselling agency. The consumer credit counseling agency will assist you in filling out your application and will submit your completed application to the Pennsylvania Housing Finance Agency. Your application must be filed or postmarked, within thirty (30) days of your face to face meetinc. It is extremely important that you file your application promptly. If you do not do so, or if you do not follow the other time periods set forth in this letter, foreclosure may proceed against your home immediately. Available funds for emergency mortgage assistance are very limited. They will be disbursed by the Agency under the eligibility criteria established by the Act. Pennsylvania Housing Finance Agency has sixty (60) days to make a decision after it receives your application. During that additional time, no foreclosure proceedings will be pursued against you if you have met the time requirements set forth above. You will be notified directly by that Agency of its decision on your application. THE PENNSYLVANIA HOUSING FINANCE AGENCY is located at: 2101 North Front Street P.O. Box 8029 Harrisburg, PA 17105 (717) 780-3800 or 1 (800) 342-2397 (toll free number) Persons with impaired hearing can call 1 (800) 342-2397. In addition you may receive another notice from this lender under Act 6 of 1974. This notice is called a "Notice of intention to Foreclosure". You must read both notices, since they both explain rights that you now have under Pennsylvania law. However, if you choose to exercise your rights described in this notice, you cannot be foreclosed upon while you are receiving that assistance. Sincerely yours, Inc. MarthA gF/ on Ro'senstiel Attorney for Eastern Mortgage Services 1736 STATEMENTS OF POLICY ,J Commission on Economics Opportunity of Luzern County 163 Amber Lane Wilkes-Barre, PA 18702 (570) 826-0510 or (800) 822.0359 FAX (570) 829-1665-Call Before Faxing (717) 455.4994 Hazelton FAX (717) 455-5631-Call Before Fazing (717) 836.4090 3lmkhannock CRAWFORD COUNTY Booker T. Washington Center 1720 Holland Stmt Erie, PA 16503 (814) 453.5744 FAX (814) 453.5749 John F. Kennedy Center, Inc 2021 East 20th Street Erie, PA 16510 (814) 898-0400 FAX (814) 898.1243 CCCS of Western Pennsylvania, Inc. 2000 Linglestown Road Harrisburg, PA 17102 (717) 641.1757 Greater Erie Community Action Committee 18 West 9th Street Erie, PA 16501 (814) 4594581 FAX (814) 456-0161 Shenango Valley Urban Lasgue, Inc. 6011'ndiana Avenue Farrell, PA 16121 (412)981.5310 CUMBERLAND COUNTY Financial Counseling Services of Franklin 31 West 3rd Street Waynesboro, PA 17268 (717) 762-3285 YWCA of Carlisle 301 G Street Carlisle, PA 17013 (717)243.3818 FAX (717) 731.9689 Urban League of Metropolitan Harrisburg N. 6th Street Harrisburg, PA 17101 (717) 2345925 FAX (717) 234.9459 Community Action Comm of the Capital Region 1514 Derry Street Harrisburg, PA 17104 (717) 232.9757 FAX (717) 2342227 CCCS of Western Pennsylvania, Inc. 2000 I.(nglestown Road Harrisburg, PA 17102 (717) 641.1757 FAX (717) 731-9589 Community Action Commission of the Capital Region 1614 Derry Street Harrisburg, PA 17104 (717) 232.9757 FAX (717) 234.2227 Acorn Housing Corporation 846 North Broad Street Philadelphia, PA 19130 (215) 765.1221 FAX (215) 765-1427 CCCS of Delaware Valley 1515 Market Street-Suite 1325 Philadelphia, PA 19107 (215) 563.5665 FAX (215) 864.2666 Media Fellowship House 302 S. Jackson Street Media, PA 19063 (610) 565-0846 Northwest Counseling Service 6001 North Broad Street Philadelphia, PA 19141 (215) 3247500 FAX (215) 324-8753 RACE 167 W. Allegheny Ave, 2nd Floor Philadelphia, PA 19140 (215) 426-8025 FAX (215) 426 9122 Community Housing Counselor, Inc. P. O. Box 244 Kennett Square, PA 19348 (610) 444.3682 FAX (610) 444.8243 PENNSYLVANIA BULLETIN, VOL 29, NO. 14, APRIL 3, ION Adams County Housing Authority 139-143 Carlisle St Gettysburg, PA 17325 (717) 3341518 FAX (717) 334.8326 DAUPB3N COUNTY Urban orth 6th of ettropolitan Harrisburg Harrisburg, PA 17101 (717) 2345925 FAX (717) 234.9459 DELAWARE COUNTY 1 1 f F 7 I F, F Fi E 4 F F C 1 2 C (I 7 .1 F' r 3 S 2 f F F ACT 91 NOTICE TAKE ACTION TO SAVE YOUR ROME FROM FORECLOSURE THE COMMONWEALTH OF PENNSYLVANIA'S HOMEOWNER'S EMERGENCY MORTGAGE ASSTSTANCE PROGRAM MAY BE ABLE TO HELP YOU READ THE FOLLOWING NOTICE TO FIND OUT HOW THE PROGRAM WORKS. Ifyou need more information, call the Pennsylvania Housing Financing Agency at 1-800-342.2397. La notification en adjucto es de suma importaneia, pua alecta su derecho a continuer viviendo en su case. Si no comprende el eontenido de esta nodficacion obtenga una traduccion immediatamente Ilamanda esta'agencia (Pennsylvania Housing Finance Agency) sin cargos al numero mencionado arriba. Puedes ser elegible pars un presumo per el programa llamado :Homeowner's Emergency Mortgage Assistance Program" el cual puede salvar su casa de la perdida del derecho a redimir su hipoteca. IMPORTANT: NOTICE OF HOMEOWNERS' EMERGENCY MORTGAGE ASSISTANCE PROGRAM PLEASE READ THIS NOTICE. 'I unoa ?•• Martha E. Von Rosenstiel, P.C. 16 South Lansdowne Avenue P.O. Box 457 Lansdowne, PA 19050 610 623-2660 ACT 91 NOTICE TARE ACTION TO SAVE YOUR HOME FROM FORECLOSURE The Commonwealth of Pennsylvania's Homeowner's Emergency Mortgage Assistance Program may be able to help you. Read the following notice to find out how the program works. If you need more information call the Pennsylvania Housing Finance Agency at 1(800) 342-2397. La notificacion en adjunto es de suma importancia, pues afecta su derecho a continuar viviendo en su casa. Si no comprende el contenido de esta notificacion obtenga una traduccion immediatamente llamanda esta agencia (Pennsylvania Housing Finance Agency) sin cargos al numero mencionado arriba. Puedes ser elegible Para un prestamo por el programs llmando "Homeowner's Emergency Mortgage Assistance Program" el cual puede salvar su casa de la perdida del derecho a redimir su hipoteca. IMPORTANT: NOTICE OF HOMEOWNERS' EMERGENCY MORTGAGE ASSISTANCE ACT OF 1983 PLEASE READ THIS NOTICE. MAY BE* ELIGIBLE FOR FINANCIAL ASSISTANCE WHICH CAN SAVE YOUR HOME FROM FORECLOSURE AND HELP MARE FUTURE MORTGAGE PAYMENTS DATE: April 16, 1999 ACCOUNT## 1670000412 TO: Thomas J. DeAngelo 813 Carol Circle New Cumberland, PA 17070 FROM: Martha E. Von Rosenstiel, Esquire Attorney for Eastern Mortgage Services Inc. Under the Act, you are entitled to a temporary stay of foreclosure on your mortgage for thirty (30) days from the date of this Notice. During that time you must arrange and attend a "face-to-face" meeting with a representative of this lender, or with a designated consumer credit counseling agency. The purpose of this meeting is to attempt to work out a repayment plan, or to otherwise settle your delinquency. This meeting must occur in the next thirty 30 days. If you attend a face-to-face meeting with this lender, or with a consumer credit counseling agency identified in this notice, no further proceedings in mortgage foreclosure may take place for thirty (30) days after the date of the meeting. The name, address and telephone number of the representative is: Ms. Faith Fritz Eastern Capital Markets 2700 Westhall Lane Ste 240 Maitland, FL 32751 407 475-0433 The name(s) and addresses) of designated consumer credit counseling agencies are: SEE ATTACHED LIST It is only necessary to schedule one face-to-face meeting. You should advise this lender immediately of your intentions. Your mortgage is in serious default because you have failed to pay promptly installments of principal and interest, as required, for a period of at least sixty (60) days. The total amount of the delinquency is $6,646.67. This sum includes the following: Monthly payments 06101198 through 04/ at $554.00 per month Late charges through 04/15/99 Suspense TOTAL AMOUNT DUE If you have tried and are unable problem at or after your face-to-face 01/99 $ 6,648.00 $ 127.92 $ (129.25) $ 6,646.67 to resolve this meeting, you have problem at or after your face-to-face meeting, you have the right to apply for financial assistance from the Homeowners' Emergency Mortgage Assistance Fund. In order to do this, you must fill out, sign and file a completed Homeowners' Emergency Assistance Application with one of the designated consumer credit counseling agencies listed above. An application for assistance may only be obtained from a consumer credit counselling agency. The consumer credit counseling agency will assist you in filling out your application and will submit your completed application to the Pennsylvania Housing Finance Agency. Your application must be filed or postmarked, within thirty (30) days of your face to face meeting. It is extremely important that you file your application promptly. If you do not do so, or if you do not follow the other time periods set forth in this letter, foreclosure may proceed against your home immediately. Available funds for emergency mortgage assistance are very limited. They will be disbursed by the Agency under the eligibility criteria established by the Act. Pennsylvania Housing Finance to make a decision after it During that additional time, will be pursued against you requirements set forth above directly by that Agency of i application. Agency has sixty (60) days receives your application. no foreclosure proceedings if you have met the time . You will be notified is decision on your THE PENNSYLVANIA HOUSING FINANCE AGENCY is located at: 2101 North Front Street P.O. Box 8029 Harrisburg, PA 17105 (717) 780-3800 or 1 (800) 342-2397 (toll free number). Persons with impaired hearing can call 1 (800) 342-2397. In addition you may receive another notice from this lender under Act 6 of 1974. This notice is called a "Notice of Intention to Foreclosure". You must read both notices, since they both explain rights that you now have under Pennsylvania law. However, if you choose to exercise your rights described in this notice, you cannot be foreclosed upon while you are receiving that assistance. Sincerely yours, Inc. MartH3-8! Von Rosenstiel Attorney for Eastern Mortgage Services 1736 STATEMENTS OF POLICY Commission on Economics Opportunity of Lucerne County 163 Amber Lane Wilkes-Barre, PA 18702 (570) 826-0510 or (800) 822-0359 FAX (570) 829.1665-Call Before Faring (717) 455.4994 Hstelton FAX (717) 455.5631-Call Before Fazing (717) 836.4090 7Ymkhaamck CRAWFORD COUNTY Booker T. Washington Center 1720 Holland Street Erie, PA 16503 (814) 453-5744 FAX (814) 453.5749 John F. Kennedy Center, Inc 2021 East 20th Stmt Erie, PA 16510 (814) 898-0400 FAX (814) 898.1243 Greater Erie Community Action Committee 18 West 9th Street Erie, PA 16501 (814) 459-4581 FAX (814) 456-0161 Sheooago Valley Urban League, Inc. 601lndiana Avenue Farrell, PA 16121 (412)981.6310 CUMBERLAND COUNTY CCCS of Western Pennsylvania, Inc. 2000 L.inglestown Road Harrisburg, PA 17102 (717) 541.1757 Urban League of Metropolitan Harrisburg N. 6th Street Harrisburg, PA 17101 (717) 2345925 FAX (717) 234.9459 Community Action Comm of the Capital Region 1514 Derry Stmt Harrisburg, PA 17104 (717) 232.9757 FAX (717) 2342227 Fioencial Counseling Services of Franklin 31 West 3rd Street Wayne bore, -3285 17268 YWCA of Carlisle 301 G Street Carlisle, PA 17013 (717) 243.3818 FAX(717)731-9689 Adsms County Housing Authority 139.143 Carlisle St Gettysburg, PA 17325 (717) 3341518 FAX(717)334-8326 DAUPHIN COUNTY CCCS of Western Peonylvania, Inc. Urban League of Metropolitan Harrisburg 2000 Linglestown Road 2107 North 6th Street Harrisburg, PA 17102 Harrisburg, PA 17101 (717) 541-1757 (717) 2345925 FAX (717) 731.9589 FAX (717) 234-9459 Community Action Commission of the Capital Region 1514 Derry Stmt Harrisburg, PA 17104 (717) 232.9757 FAX (717) 234.2227 DELAWARE COUNTY Acorn Housing Corporation 846 North Broad Street Philadelphia, PA 19130 (215) 765-1221 FAX (215) 765.1427 CCCS of Delaware Valley 1515 Market Street-Suite 1325 Philadelphia, PA 19107 (215) 563-5665 FAX (215) 8642666 Media Fellowship House 302 S. Jackson Stmt Media, PA 19063 (610) 565-0846 Northwest Counseling Serra 5001 North Broad Street Philadelphia, PA 19141 (215) 3247500 FAX (215) 324-8753 RACE 167 W. Allegheny Ave, 2nd Floor Philadelphia, PA 19140 (215)426.8025 FAX (215) 426-9122 Community Housing Counselor, Inc. P. 0. Box 244 Kennett Square, PA 19348 (610) 444-0682 FAX (610) 444.8243 PENNSYLVANIA SULLEnN, VOL. 29, NO. 14, APRIL 3. 1444 F F 7 I F E -4 F 'F 7 .1 4 F r 7 } N 2 F A F ACT 91 NOTICE TAKE ACTION TO SAVE YOUR HOME FROM FORECLOSURE THE COMMONWEALTH OFPENNSYLVANIA'S HOMEOWNER'S EMERGENCY MORTGAGE ASSISTANCE PROGRAM MAY BE ABLE TO HELP YOU READ THE FOLLOWING NOTICE TO FIND OUT HOW THE PROGRAM WORKS. Ifyou need more information, call the Pennsylvania Housing Financing Agency at 1-800-341.2397. La notification an adjuao es de suma importartcia, puns alecta su derecho a continuar viviendo an su cam Si no comprende el contenido de esta notification obtenga una traduceion immediatamrnte Ilamanda esta agencia (Pennsylvania Housing Finance Ag=cy) sin cargos al nu hero mencionado mriba. Puedes ser elegibie Para un prestamo por et programa Ilamado :Homeowner's Emergency Mortgage Assistance Program" el cual puede salvar su casa de la perdida del derecho a redimir su hipoteea. IMPORTANT: NOTICE OF HOMEOWNERS' EMERGENCY MORTGAGE ASSISTANCE PROGRAM PLEASE READ THIS NOTICE. v LJ 'R 'i L[NOER ?? Martha E. Von Rosenstiel, P.C. 16 South Lansdowne Avenue P.O. Box 457 Lansdowne, PA 19050 610 623-2660 ACT 91 NOTICE TARE ACTION TO SAVE YOUR HOME FROM FORECLOSURE The Commonwealth of Pennsylvania's Homeowner ,s Emergency Mortgage Assistance Program may be able to help you. Read the following notice to find out how the program works. If you need more information call the Pennsylvania Housing Finance Agency at 1(800) 342-2397. La notificacion en adjunto es de suma importancia, pues afecta su derecho a continuar viviendo en su casa. Si no comprende el contenido de esta notificacion obtenga una traduccion immediatamente llamanda esta agencia (Pennsylvania Housing Finance Agency) sin cargos al numero mencionado arriba. Puedes ser elegible para un prestamo por el programs llmando "Homeowner's Emergency Mortgage Assistance Program" el cual puede salvar su casa de la perdida del derecho a redimir su hipoteca. IMPORTANT: NOTICE OF HOMEOWNERS, EMERGENCY MORTGAGE ASSISTANCE ACT OF 1983 PLEASE READ THIS NOTICE. MAY BE ELIGIBLE FOR FINANCIAL ASSISTANCE WHICH CAN SAVE YOUR HOME FROM FORECLOSURE AND HELP MARE FUTURE MORTGAGE PAYMENTS DATE: April 16, 1999 ACCOUNT# 1670000412 TO: Majorie J. DeAngelo 813 Carol Circle New Cumberland, PA 17070 FROM: Martha E. Von Rosenstiel, Esquire Attorney for Eastern Mortgage Services Inc. Under the Act, you are entitled to a temporary stay of foreclosure on your mortgage for thirty (30) days from the date of this Notice. During that time you must arrange and attend a "face-to-face" meeting with a representative of this lender, or with a designated consumer credit counseling agency. The purpose of this meeting is to attempt to work out a repayment plan, or to otherwise settle your delinquency. This meeting must occur in the next thirty 30 days. If you attend a face-to-face meeting with this lender, or with a consumer credit counseling agency identified in this notice, no further proceedings in mortgage foreclosure may take place for thirty (30) days after the date of the meeting. The name, address and telephone number of the representative is: Ms. Faith Fritz Eastern Capital Markets 2700 Westhall Lane Ste 240 Maitland, FL 32751 407 475-0433 The name(s) and addresses) of designated consumer credit counseling agencies are: SEE ATTACHED LIST It is only necessary to schedule one face-to-face meeting. You should advise this lender immediately of your intentions. Your mortgage is in serious default because you have failed to pay promptly installments of principal and interest, as required, for a period of at least sixty (60) days. The total amount of the delinquency is $6,646.67. This sum includes the following: Monthly payments 06/01/98 through 04/01/99 at $554.00 per month $ 6,648.00 Late charges through 04/15/99 $ 127.92 Suspense $ (129.25) TOTAL AMOUNT DUE $ 6,646.67 If you have tried and are unable to resolve this problem at or after your face-to-face meeting, you have circumstances beyond your control you have a reasonable the right to apply for financial assistance from the Homeowners' Emergency Mortgage Assistance Fund. In order to do this, you must fill out, sign and file a completed Homeowners' Emergency Assistance Application with one of the designated consumer credit counseling agencies listed above, An application for assistance may only be obtained from a consumer credit counselling agency. The consumer credit counseling agency will assist you in filling out your application and will submit your completed application to the Pennsylvania Housing Finance Agency. Your application must be filed or postmarked, within thirty (30) days of Your face to face meeting. It is extremely important that you file your application promptly. If you do not do so, or if you do not follow the other time periods set forth in this letter, foreclosure may proceed against your home immediately. Available funds for emergency mortgage assistance are very limited. They will be disbursed by the Agency under the eligibility criteria established by the Act. Pennsylvania Housing Finance Agency has sixty (60) days to make a decision after it receives your application. During that additional time, no foreclosure proceedings will be pursued against you if you have met the time requirements set forth above. You will be notified directly by that Agency of its decision on your application. THE PENNSYLVANIA HOUSING FINANCE AGENCY is located at: 2101 North Front Street P.O. Box 8029 Harrisburg, PA 17105 (717) 780-3800 or 1 (800) 342-2397 (toll free number). Persons with impaired hearing can call 1 (800) 342-2397. In addition you may receive another notice from this lender under Act 6 of 1974. This notice is called a "Notice of Intention to Foreclosure". You must read both notices, since they both explain rights that you now have under Pennsylvania law. However, if you choose to exercise your rights described in this notice, you cannot be foreclosed upon while you are receiving that assistance. Sincerely yours, Inc. ha Von Rosenstiel ney for ern Mortgage Services 1736 STATEMENTS OF POLICY /// Commission on Economics opportunity of Luteme County Amber Lane Wilkes-Barre, PA 18702 (570) 826-0510 or (800) 822-0359 FAX (570) 829-1665--CaU Before Faring (717) 455-4994 Harahan FAX (717) 455-5631-Call Before Faring (717) 836.4090 Tunkhannock CRAWFORD COUNTY Booker T. Washington Center 1720 Holland Stmt Erie, PA 16503 (814)453.5744 FAX (814) 453-5749 Jahn F. Kennedy Center, Inc 2021 East 20th Street Erie, PA 16510 (814) 898-0400 FAX (814) 898-1243 Greater Erie Community Action Committee 18 West 9th Street Erie, PA 16501 (814)459.4581 FAX (814) 456-0161 Shenango Valley Urban League, Inc. 601 Indiana Avenue Farrell, PA 16121 (412) 981.5310 CUMBERLAND COUNTY Financial Counseling Services of Franklin CCCS of Western Pennsylvania, Inc. 2000 Linglestown Road Harrisburg, PA 17102 (717) 541-1757 Urban League of Metropolitan Harrisburg N. 6th Street Harrisburg, PA 17101 (717)234.5925 FAX (717)234.9459 Community Action Comm of the Capital Region 1514 Derry Street Harrisburg, PA 17104 (717) 232.9757 FAX (717) 2342227 CCCS of Western Pennsylvania, Inc. 2000 Linglastown Road Harrisburg. PA 17102 (717) 541-1757 FAX (717) 731-9589 31 West 3rd Street Waynesboro, PA 17268 (717) 762-3285 YWCA of Carlisle 301 G Stmt Carlisle, PA 17013 (717) 243.3818 FAX (717) 731.9589 Adams County Housing Authority 139-143 Carlisle St Gettysburg, PA 17325 (717)334.1518 FAX (717) 334-8326 DAUPHIN COUNTY Urban League of Metropolitan Harrisburg 2107 North 6th Street Harrisburg, PA 17101 (717) 234.5925 FAX (717) 234.9459 Community Action Commission of the Capital Region 1514 Derry Street Harrisburg, PA 17104 (717) 232.9757 FAX (717) 234-2227 DELAWARE COUNTY Acorn Housing Corporation 846 North Broad Philadelphia, PAPA S19 treet 130 (215) 765-1221 FAX (215) 765-1427 CCCS of Delaware Valley 1515 Philade phis. PAA119t107ite 1325 (215) 563-5665 FAX (215) 8642666 Media Fellowship House 302 S. Jackson Street Media. PA 19063 (610) 565-0846 Northwest Counseling Service 5001 North Broad Street Philadelphia, PA 19141 (215)324-7500 FAX (215) 324.8753 RACE 167 W. Allegheny Ave, 2nd Floor Philadelphia, PA 19140 (215) 426-8025 FAX (215) 426.9122 Community Housing Counselor, Inc. P. O. Bo: 244 Kennett Square, PA 19348 (610) 444-0682 FAX (610) 444.8243 I 1 F 1 3 I I F F E •4 F F C C 7 Il ( F r 1 F PENNSYLVANIA SULLEnN, VOL 29, NO. 14, APRIL 9. 199a Martha E. Von Rosenstiel, P.C Martha E. Von Rosenstiel 16 South Lansdowne Avenue P.O. Box 457 Lansdowne, PA 19050 610 623-2660 Attorney I.D.# 52634 Goldstar Financial, Inc 312 West First Street Sanford FL 32771 Plaintiff No: 99-4852 Civil VS. Thomas J. DeAngelo and Marjorie : J. DeAngelo and Myles H. Shoop, : Jr. 813 Carol Circle New Cumberland, PA 17070 and The United States of America 228 Walnut Street Harrisburg, PA 17108 Defendants SUPPLEMENTAL AFFIDAVIT OF SERVICE OF NOTICES PURSUANT TO RULE 3129.1 COMMONWEALTH OF PENNSYLVANIA: COUNTY OF DELAWARE Attorney for Plaintiff : COURT OF COMMON PLEAS : CUMBERLAND COUNTY SS MARTHA E. VON ROSENSTIEL, attorney for the plaintiff in the above action, hereby certifies that service of the Notice under Rule 3129.1, in the above matter was made on the defendants via certified mail, return receipt requested as evidenced by the attached postal receipts; 1. Name and address of owners(s) or reputed owner(s) Myles H. Shoop, Jr. 813 Carol Circle New Cumberland, PA 17070 i 2. Name and address of defendant (s) in the judgment: Myles H. Shoop, Jr. 813 Carol Circle New Cumberland, PA 17070 Thomas J. DeAngelo 733 Linden Avenue Johnstown, PA 15902 Marjorie J. DeAngelo 733 Linden Avenue Johnstown, PA 15902 United States of America 228 Walnut Street Harrisburg, PA 17070 I verify that the statements made in this affidavit are true and correct to the best of my personal knowledge or information and belief. I understand that false statements herein are made subject to the penalties of 18 Pa. C.S. Section 4904 relating to unsworn falsification to authorities. j Attoryfey for Plaintiff p p m .a ? POStaga m p QMIRao Fee M p P.lum Receipt Fee (EngMammtt Requeao ) p C Ra.tww OM." Fee IEnoooxn.nt R"UI W) G TblSI POO-O. 6 Fee. O 9 n a Z Postage a Comfieo Fee 7 T Return Rxtlpt Fee (Emotstmem Rec,um d) RMlecteo DMIN" Fee (Emonernant Requtreo) O Told Postage 6 Fete S tat CIN M cr K C3 C3 a r- . i S u1 I I rMM-M postage A as Cooke Fee O eturn Recmpt Fee R m (Emo,.mot RegVeaol CM Rsnncteo DM,V.ry Fes O (Em.aeroent Requute) CM Toto Postage S Fags S lpl Pnnt Clea m cr Ny POI Ir L O t tats. tlPj . . M1 I I lil lll I RAJ 1. O M1 s+1 -0 Postage Cemlieo Fee O m Return Rsc.pl Fee t7 IEnecgement ReOwmol O Reeteciw oao *, Fee C3 IEneonement PKuireal O Ttl postage F. D d . S e . Ir O M1 _ i " 1300 ? m s 3 d w ¢ U 000 ti U ¢ 5 fi d U C ei d I m N 'n o i y r? o$mooE I U'-L_ Tm N V C ? ^ aT°Eo= Ly ? mm FL $ ata F ^ E0.,6 m ? C ES?cA?c v m ? u u o .- ¢ m ?? E O?D E°TL?c m oy co'o drY o U . a N ¢ `o LL n c 3 -u 4 rn ¦ Complete Items 1, 2, and 3, Also eompleW/ item 4 If Restricted De9very IS desired. • Print your name and address on the reverse so that we can return the card to you, ¦ Attach this card to the back of the mailpiece, or on the front if space permits, t sZAtltlresaec to: Form 3811; JuIY 1999 Domestic _ ? Receipt *2595-99-M•17e9 ¦ Comple item te Items 1. 2. and ?? 4 if • Restricted Dollvery Is dealomplate Fd Yourn , ame and address on the reverse • Attrtchtthis can return the card to You. or r n the f card t Pathe ce back of the mailplece, rant its permits. 1. Mw. i Form A. Received 6y- s ien ure D. Is delivery add dlaxerlf I1 YES, enterdelivery adore Cis") B. Date of Delivery ?? F 0 Agent Adtlresyes item 1? ? Yea below: ? No I 7 ? `^W' r 47 3. Service Z 0 Certified Mail 0 Registered Express Mail Return C3 insured Recei t f Merchandl D P or al ? PYOOm$-vicelebeg vl]d 4. Restneten e ey7 --- eel ? _ 999 ? _ ? vas , Domestic Return Receipt 102595.99.µ..a9 CI E+PISMS Mail 0 Retum Receipt for Merchandise ? C.O.D. V? (Extra Feel ? Yes A. Received by !Plea!- ni a Agent ,oss mem9nt (lyn It" 17 ? Yea If YES, enter delivery address below: ? No v. service Type 0 Certified Mail O Registered 13 Insuied Mail 4. Restdcted Deliver Qd •;` ?t' ;_ ?. :? . , _. -1:', ._.. J?;, t..: ?. - .. ?? -? - 1'ii =i ' _-? > :? ? t.? Goldstar Financial -vs- Thomas J. DeAngelo and Majorie J. Deangelo and Myles H. Shoop and The United States of America In the Court of Common Pleas of Cumberland County, Pennsylvania No.1999-4852 Civil R. Thomas Kline, Sheriff, who being duly sworn according to law, says this writ is returned STAYED. Sheriff's Costs: Docketing 30.00 Poundage 18,70 Advertising 15.00 Posting Bills 15.00 Law Library .50 County 1.00 Mileage 21.08 Certified Mail ,80 Levy 15.00 Postpone Sale 20.00 Surcharge 40.00 Out of county 18.00 Dauphin County 25.50 Cambria County 43.25 Share of Bills 23.53 Law Journal 302.60 Patriot News 288.30 _ $ 878.26 Sworn and subscribed to before me This Y 4?- day of 2000, A.D. r thonotary Pd By Arty 08/31/00 1SV-W" ?OP R. Thomas Kline, Sheriff BY 9L z-4- Real Estate Deputy ti ?. IOoSo'l Martha E. Von Rosenstiel, P.C. Attorney for Plaintiff Martha E. Von Rosenstiel 16 South Lansdowne Avenue P.O. Box 457 Lansdowne, PA 19050 610 623-2660 Attorney I.D.# 52634 : COURT OF COMMON PLEAS Goldstar Financial, Inc. : CUMBERLAND COUNTY 312 West First Street Sanford FL 32771 Plaintiff No: 99-4852 Civil Vs. Thomas J. DeAngelo and Marjorie J. DeAngelo and Myles H. Shoop, Jr. 813 Carol Circle New Cumberland, PA 17070 and The United States of America 228 Walnut Street Harrisburg, PA 17108 Defendants AFFIDAVIT OF NOTICE PURSUANT TO RULE 3129.1 COMMONWEALTH OF PENNSYLVANIA: COUNTY OF DELAWARE SS MARTHA E. VON ROSENSTIEL, attorney for the 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 813 Carol Circle, New Cumberland, PA 17070: 1. Name and address of owners(s) or reputed owner(s) Myles H. Shoop, Jr. 813 Carol Circle New Cumberland, PA 17070 2. Name and address of defendant(s) in t<ie judgment: Myles H. Shoop, Jr. 813 Carol Circle New Cumberland, PA 17070 Thomas J. DeAngelo 733 Linden Avenue Johnstown, PA 15902 Marjorie J. DeAngelo 733 Linden Avenue Johnstown, PA 15902 United States of America 228 Walnut Street Harrisburg, PA 17070 3. Name and address of every judgment creditor whose judgment is a record lien on the real property to be sold: Corestates Bank k/n/a First Union 510 Walnut Street Mezzanine Philadelphia, PA 19106 William C. Lambert and Carol M. Lambert P.O. Box 86 Mt. Joy, PA United States of America 228 Walnut Street Harrisburg, PA 17108 United States of America C/o Department of Justice Washington, DC 20530 United States Treasury Department P.O. Box 12051 Philadelphia, PA 19101 East Pennsboro Township 98 South Enda Street Enda, PA 4. Name and address of the last recorded holder of every mortgage of record: Sentry Consumer Discount Company 1505 Market Street Camp Hill PA 17011 r S. Name and address of every other person who has any record lien on the property: 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: NONE 7. Name and address of every other person of whom plaintiff has knowledge who has any interest in the property which may be affected by the sale: Cumberland County Domestic Relations One Courthouse Square Carlisle, PA 17013 I verify that the statements made in this affidavit are true and correct to the best of my personal knowledge or information and belief. I understand that false statements herein are made subject to the penalties of 18 Pa. C.S. Section 490 relating to unsworn falsification to authorities. Martha E. Von o?tiel / Attorney for Plaintiff Martha E. Von Rosenstiel, P.C Martha E. Von Rosenstiel 16 South Lansdowne Avenue P.O. Box 457 Lansdowne, PA 19050 610 623-2660 Attorney I.D.# 52634 Goldstar Financial, Inc 312 West First Street Sanford, FL 32771 Attorney for Plaintiff : COURT OF COMMON PLEAS : CUMBERLAND COUNTY Plaintiff No: VS. Thomas J. DeAngelo and Marjorie J. DeAngelo and Myles H, Shoop, Jr. 813 Carol Circle New Cumberland, PA 17070 and The United States of America 228 Walnut Street Harrisburg, PA 17108 Defendants 99-4852 Civil THIS IS AN ATTEMPT TO COLLECT A DEBT ANY INFORMATION OBTAINED WILL BE USED FOR THAT PURPOSE NOTICE OF SHERIFF'S SALE OF REAL PROPERTY TO: Thomas J. DeAngelo and Marjorie J. DeAngelo 733 Linden Avenue Johnstown, PA 15902 Myles H. Shoop, Jr. 813 Carol Circle New Cumberland, PA 17070 United States of America 228 Walnut Street Harrisburg, PA 17108 Your house and/or real estate at 813 Carol Circle, New Cumberland, PA 17070 is scheduled to be sold at Sheriff's Sale on September 6, 2000 at 10:00 a.m. to enforce the court judgment of $6,331.33 obtained by Goldstar Financial, Inc. against you. NOTICE OF OWNERS RIGHTS M YOU MAY BE ABLE TO PREVENT THIS SHERIFF'S SALE To prevent this Sheriff's Sale you must take IMMEDIATE action: 1. The sale will be cancelled if you pay to Goldstar Financial, Inc. the back payments, late charges, costs and reasonable attorney's fees due. To find out how much you must pay, you may call 610 623-2660. 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 contact an attorney to assert your rights. The sooner you contact one, the more chance you will have of stopping the sale. (See notice on page two on how to obtain an attorney) YOU MAY STILL BE ABLE TO SAVE YOUR PROPERTY AND YOU HAVE OTHER RIGHTS EVEN IF THE SHERIFF'S SALE DOES TAKE PLACE. 1. If the Sheriff's Sale is not stopped, your property will be sold to the highest bidder. You may find out the bid price by calling 610 623-2660. 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 in the sale. To find out if this has happened you may call 610 623-2660. 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 on a date to be announced by the Sheriff. This schedule will state who will be I N CLAIM FOR EXEMPTION To the Sheriff: I, the above named defendant, claim exemption of property from levy or attachment: (1) From my real property in my possession which has been levied upon, (a) I desire that my $300.00 statutory exemption. be set-aside in kind (specify real property to be set-aside in kind) : I request a prompt court hearing to determine the exemption, Notice of the hearing should be given to me at (Address) (Telephone Number) I verify that the statements made in this Claim for Exemption are true and correct. I understand that false statements herein are made subject to the penalties of IS Pa. C.S. Section 4904 relating to unsworn falsification to authorities. Date: Signature THIS CLAIM TO BE FILED WITH THE OFFICE OF THE SHERIFF CUMBERLAND COUNTY COURT HOUSE ONE COURT HOUSE SQUARE CARLISLE, PA 17013 717 240-6391 MARTHA E. VON ROSENSTIEL, P.C. ATTORNEY AT LAW 16 SOUTH LANSDOWNE AVENUE P.O. BOX 457 LANSDOWNE , PA 19050 PHONE(610) 623-2660 FAX 610 623-2745 March 9, 2000 TO: Thomas J. DeAngelo & Marjorie J. DeAngelo 733 Linden Avenue Johnstown, PA 15902 RE: NOTICE OF SALE OF REAL PROPERTY: 813 Carol Circle, New Cumberland, PA 17070 Amount of Judgment: $ 6,331.33 Date of Judgment: March 9, 2000 Court Term and Number: Court of Common Pleas of Cumberland County, Docket# 99-4852 Civil Plaintiff: Goldstar Financial, Inc. Defendants: Thomas J. DeAngelo and Marjorie J. DeAngelo and Myles H. Shoop, Jr. and the United States of America Dear Mr. and Mrs. DeAngelo: Please be advised that the property and improvements, if any, located at and known as 813 Carol Circle, New Cumberland, PA, 17070 will be sold by the Sheriff of Cumberland County on September 6, 2000 at 10:00 a.m. in the Cumberland County Court House, One Court House Square, Carlisle, PA 17013. This property and improvements are being sold pursuant to a judgment entered as indicated above in favor of the above named plaintiff, and against the above named defendants. The name of the owner, real owner, and reputed owner of the aforementioned property is Myles H. Shoop, Jr. A schedule of distribution will be filed by the Sheriff on a date specified by the Sheriff no later than 30 days after said sale, and distribution will be made in accordance with the schedule unless exceptions are filed thereto within ten (10) days after the date of the filing of said schedule. You should check with the Sheriff's Office by calling 717 240-6391 to determine the actual date of the filing of the schedule. Sincerely yours, Martha E. Von Rosenstiel S MARTHA E. VON ROSENSTIEL, P. C. ATTORNEY AT LAW 16 SOUTH LANSDOWNE AVENUE P.O. BOX 457 LANSDOWNE , PA 19050 PHONE(610)623-2660 March 9, 2000 TO: Myles H. Shoop, Jr. 813 Carol Circle New Cumberland, PA 17070 FAX 610 623-2745 RE: NOTICE OF SALE OF REAL PROPERTY: 813 Carol Circle, New Cumberland, PA 17070 Amount of Judgment: $ 6,331.33 Date of Judgment: March 9, 2000 Court Term and Number: Court of Common Pleas of Cumberland County, Docket# 99-4852 Civil Plaintiff: Goldstar Financial, Inc. Defendants: Thomas J. DeAngelo and Marjorie J. DeAngelo and Myles H. Shoop, Jr. and the United States of America Dear Mr. Shoop: Please be advised that the property and improvements, if any, located at and known as 813 Carol Circle New Cumberland, PA, 17070 will be sold by the Sheriff of Cumberland County on September 6, 2000 at 10:00 a.m. in the Cumberland County Court House, One Court House Square, Carlisle, PA 17013. This property and improvements are being sold pursuant to a judgment entered as indicated above in favor of the above named plaintiff, and against the above named defendants. The name of the owner, real owner, and reputed owner of the aforementioned property is Myles H. Shoop, Jr. A schedule of distribution will be filed by the Sheriff on a date speciied by the Sheriff no later than 30 days after said sale, and distribution will be made in accordance with the schedule unless exceptions are filed thereto within ten (10) days after the date of the filing of said schedule. You should check with the Sheriff's Office by calling 717 240-6391 to determine the actual date of the filing of the schedule. Sincerely yours, Martha E. Von Rosenstiel F MARTHA E. VON ROSENSTIEL, P.C. ATTORNEY AT LAW 16 SOUTH LANSDOWNE AVENUE P.O. BOX 457 LANSDOWNE , PA 19050 PHONE(610)623-2660 FAX 610 623-2745 March 9, 2000 TO: United States of America 228 Walnut Street Harrisburg, PA 17108 RE: NOTICE OF SALE OF REAL PROPERTY: 813 Carol Circle, New Cumberland, PA 17070 Amount of Judgment: $ 6,331.33 Date of Judgment: March 9, 2000 Court Term and Number: Court of Common Pleas of Cumberland County, Docket# 99-4852 Civil Plaintiff: Goldstar Financial, Inc. Defendants: Thomas J. DeAngelo and Marjorie J. DeAngelo and Myles H. Shoop, Jr. and the United States of America Dear Sir or Madam: Please be advised that the property and improvements, if any, located at and known as 813 Carol Circle New Cumberland, PA, 17070 will be sold by the Sheriff of Cumberland County on September 6, 2000 at 10:00 a.m. in the Cumberland County Court House, One Court House Square, Carlisle, PA 17013. This property and improvements are being sold pursuant to a judgment entered as indicated above in favor of the above named plaintiff, and against the above named defendants. The name of the owner, real owner, and reputed owner of the aforementioned property is Myles H. Shoop, Jr. A schedule of distribution will be filed by the Sheriff on a date specified by the Sheriff no later than 30 days after said sale, and distribution will be made in accordance with the schedule unless exceptions are filed thereto within ten (10) days after the date of the filing of said schedule. You should check with the Sheriff's Office by calling 717 240-6391 to determine the actual date of the filing of the schedule. Sincerely yours, Martha E. Von Rosenstiel APP-3-2000 09:21R FROM: 70:17172406573 P;7 NEON ALL THAT CERTAIN piece or parcel of land situate in New Cumberland, Cumberland County, Pennsylvania, more particularly bounded and described as follows, in accordance with survey of Michacl C. DeAngelo, R.S., dated Match 20, 1974, to wit: BEGINNING at an 'X' cut in the sidewalk which point is 361.98 feet in a Southwesterly direction along the Northerly line of Carol Circle from the intersection of Carol Circle and Brandt Avenue; thence South 70 degrees 10 minutes 50 seconds West along the dividing line between the herein described Lot and Lot No. 9 on the hereinattcr mentioned Plan of lots a distance of 98.20 feet to a pin; thence South 19 degrees 48 minutes East along the right-of-way line with the York-Baltimore Expressway a distance of 181.69 feet to a pipe; thence North 19 degrees 10 minutes 10 seconds East along the dividing line bet%4een the herein described Lot and Lot No. 7 on the bereinafter mentioned Plan of Lots, a distance of 175.64 feet to a pipe; thence along a curve to the right having a radius of 40 feet, an arc distance of 50 feet to the 'X' cut in the sidewalk, the place of beg-inning. BEING Lot No. 8 on the Plan of Lots laid out by Leon Bear, and recorded in the Cumberland County Recorder's Office in Plan Book 7, page 22. HAVING thereon erected a 1-1/2 story brick dwelling house known and numbered as 813 Carol Circle. BEING Tax Parcel Number 26-23-0543-209. a WRIT OF EXECUTION and/or ATTACHMENT COMMONWEALTH OF PENNSYLVANIA) NO. 99-4852 CIVIL Q? Term COUNTY OF CUMBERLAND) CIVIL ACTION - LAW TO THE SHERIFF OF Cumberland COUNTY: To satisfy the debt, interest and costs due Goldsstar Financial, Inc. from ThCrms J Anglen and Mainrie T neAngeln, Mnrt•gagats and M i-s H shnnn T ,Real Owner 813 Carol Circle New C +m 1 and PA 17070 and United Sates of America c/o United States Attornev fnr the mi AA1c ..a n....__.., .._ . _. upon the property of the defendant(s) and to sell See Legal Description (2) You are also directed to attach the property of the defendant(s) not levied upon in the possession of GARNISHEE(S) as follows: and to notify the garnishee(s) that: (a) an attachment has been issued; (b) the garnishee(s) is/are enjoined from paying any debt to or for the account of the defendant(s) and from delivering any property of the defendant(s) or otherwise disposing thereof; (3) I(property of thedefendant(s) not levied upon an subject to attachment isfound in the possessionof anyoneother than a named garnishee, you are directed to notify him/herthat he/she has been added as a garnishee and is enjoined as above stated. Amount Due $6,331.33 L.L. $.50 Interest from 3/10/00 Due Prothy $1.00 Atty's Comm Atty Paid $323.20 Plaintiff Paid Date: April 3, 2000 Curtis R. Long Prothonotary, Civil Division REQUESTING PARTY: Other Costs --by/?//JQ?w n / ///77/l YEy Deputy Name Martha E. Von Rosenstiel Address: 16 South Lansdowne Avenue P.0.Box 457 Lansdowne, PA 19050 Attorney for:Plaintif f Telephone: 610-623-2660 Supreme Court ID No. 52634 REAL ESTATE SALE No-3Y 1-s? 9--2-6 n the sheriff levied upon the defendants Interest in the real property situated In jlks,, L-?A2? Cumberland County, Pa., known and numbered as:S'13? x]42 and more `w,i escribed on Exhibit "A" filed with this writ and by this reference incorporated herein. gate: By: i qn ?I S 8d j -4A ca GB M