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Home My WebLink About99-04866 ¦ _fl f?X F. r:42' J:. Y•;C7 `j ng ?Y u? J L•y4; ';V MARK J. UDREN fi ASSOCIATES ATTORNEY FOR PLAINTIFF BY: Mark J. Udren, Esquire ATTY I.D. N01-04302 - 1040 N. KINGS HIGHWAY, SUITE 500 CHERRY HILL, NJ 08034 609-482-6900 GE Capital Mortgage Services, -COURT OF COMMON PLEAS Inc. :CIVIL DIVISION 4680 Hallmark Parkway :Cumberland County San Bernardino, CA 92407 Plaintiff V. Robert J. Holsberger, Jr. 4206 Allen Road : NO. 99- 40 ?9?D Cu 9TE?J?f?? Camp Hill, PA 17011 D Defendant(s) COMPLAINT IN 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 TAKE THIS PAPER TO YOUR LAWYER AT ONCE. IF YOU DO NOT HAVE A LAWYER OR CANNOT AFFORD ONE, GO TO OR TELEPHONE THE OFFICE SET FORTH BELOW TO FIND OUT WHERE YOU CAN GET LEGAL HELP. LAWYERS REFERRAL SERVICE Cumberland County Bar Association 2 Liberty Ave. Carlisle, PA 17013-3387 717-249-3166 or 800-990-9108 AVISO - Le han demandado a usted en la corte. Si usted quiere defender-se de estas demandas expuestas en las paginas siguientes, usted tiene I veinte (20) dias de plazo al partir de la fecha de la demanda y la notificacion. Hace falta ascentar una comparencia escrita o en persona o con un abogado y entregar a la corte en forma escrita sus defensas o sus objeciones a las demandas en contra de su persona. Sea avisado que si usted no se dafiende, la corte tomara medidas y puede continuar la demanda en contra suya sin previo aviso o notificacion. Ademas, la corte puede decidir a favor del demandante y requiere que usted cumpla con todas las provisioner de esta demands. Usted puede perder dinero o sus propiedades u otros derechos importantes para usted. E LLEVE ESTA DEMANDA A UN ABOGADO IMMEDIATAMENTE, SI NO TIENE ABOGADO 0 SI NO TIENE EL DINERO SUFICIENTE DE PAGAR TAL SERVICIO, VAYA EN PERSONA O MAKE POR TELEFONO A LA OFICINA CUYA DIRECCION SE ENCUENTRA ESCRITA ABAJO PARA AVERIGUAR DONDE SE PUEDE CONSEGUIR ASISTENCIA LEGAL. Cumberland County Bar Association 2 Liberty Ave. Carlisle, PA 17013-3387 717-249-3166 or 800-990-9108 The amount of your debt is as stated in the attached document. The name of the creditor to whom the debt is owed is as named in the attached document. Unless you notify us within 30 days after receipt of this Notice and the attached document that the validity of the stated debt, or any portion of it, is disputed, we will assume that the debt is valid. If you do notify us in writing of a dispute within the 30 day period, we will obtain verification of the debt or a copy of a judgment against you, and mail it to you. If you do not dispute the debt, it is not an admission of liability on your part. Also, upon your written request within the 30 day period, we will provide you with the name and address of the original creditor if different from the current creditor. If you notify us in writing within the 30 day period as stated above, we will cease collection of your debt, or any disputed portion of it, until we obtain the information that is required and mail it to you. Once we have mailed to you the required information, we will then continue the collection of your debt. This law firm is deemed to be a debt collector and this Notice and the attached document is an attempt to collect a debt, and any information obtained will be used for that purpose. LAW OFFICES OF MARK J. UDREN /s/ Mark J. Udren, Esquire 1040 N. Kings Highway, Suite 500 Cherry Hill, NJ 08034 (609) 482-6900 W- 1. Plaintiff is the Corporation designated as such in the caption on a preceding page. If Plaintiff -rs an assignee then it is such by virtue of the following recorded assignments: Assignor: Atlantic Regional Mortgage Corp. Assignments of Record to: GE Capital Mortgage Services, Inc. Recording Date: 5/29/98 Book: 577 Page: 866 2. Defendant(s) is the individual designated as such on the caption on a preceding page, whose last known address is as set forth in the caption, and unless designated otherwise, is the real owner(s) and mortgagor(s) of the premises being foreclosed. 3. On or about the date appearing on the Mortgage hereinafter described, at the instance and request of Defendant(s), Plaintiff (or its predecessor, hereinafter called Plaintiff) loaned to the Defendant(s) the sum appearing on said Mortgage, which Mortgage was executed and delivered to Plaintiff as security for the indebtedness. Said Mortgage is incorporated herein by reference in accordance with Pa.R.C.P. 1019 (g). The information regarding the Mortgage being foreclosed is as follows: MORTGAGED PREMISES: 632 - 634 Hummel Avenue MUNICIPALITY/TOWNSHIP/BOROUGH: Borough of Lemoyne COUNTY: Cumberland DATE EXECUTED: 7/15/97 DATE RECORDED: 7/17/97 BOOK: 1393 PAGE: 938 The legal description of the mortgaged premises is attached hereto and made part hereof. 4. Said Mortgage is in default because the required payments have not been made as set forth below, and by its terms, upon breach and failure to cure said breach after notice, all sums secured by said Mortgage, together with other charges authorized by said Mortgage itemized below, shall be immediately due. 5. After demand, the Defendant(s) continues to fail or refuses to comply with the terms of the Note as follows: (a) by failing or refusing to pay the installments of principal and interest when due in the amounts indicated below; (b) by failing or refusing to pay other charges, if any, indicated below. 6. The following amounts are due on the said Mortgage as of 8/3/99: Principal of debt due and unpaid $65,022.70 Interest at 8.375% from 4/1/99 to 8/3/99 (the per diem interest accruing on this debt is $15.13 and that sum should be added each day after 8/3/99) 1,891.25 Title Report 250.00 Court Costs (anticipated, excluding Sheriff's Sale costs) 280.00 Escrow Overdraft/ (Balance) (The monthly escrow on this account is $110.13 and that sum should be added on the first of each month after 8/3/99) (561.80) Late Charges (monthly late charge of $25.08 should be added on the fifteenth of each month after 8/3/99) 106.84 Attorneys Fees (anticipated and actual to 5% of principal) 3,251.14 TOTAL $70,240.13 7. The attorney's fee set forth above are in conformity with the mortgage documents and Pennsylvania law, and will be collected in the event of a third party purchaser at Sheriff's Sale.-.--.-If the mortgage is reinstated prior to the sale, reasonable attorney's fees will be charged in accordance with the reduction provisions of Act 6, if applicable. 8. Notice of Intention to Foreclose under Act 6 of 1974 of the Commonwealth of Pennsylvania is not required as the original principal amount exceeds the sum of $50,000.00. The notice specified by the Pennsylvania Homeowner's Emergency Mortgage Assistance Program, Act 91 of 1983, has been sent as required on the date appearing on the copy attached hereto as Exhibit "A", and Defendant(s) have failed to proceed within the time limits, or have been determined ineligible, or Plaintiff has not been notified in a timely manner of Defendant(s) eligibility. WHEREFORE, the Plaintiff demands judgment, in rem, against the Defendant(s) herein in the sum of $70,240.13, plus interest, costs and attorneys fees as more fully set forth in the Complaint, and for foreclosure and sale of the Morta ed premises. Marls J. Udren, ESQUIRE MARK J. UDREN & ASSOCIATES Attorney for Plaintiff Attorney I.D. No. 04302 60/11/99 12:19 To:21757000000000 From:MAGGIE 1-000-726-7166 Page 0/9 ALL THAT CERTAIN lot or tract of land Flt'late .i.r. Lemoyne aorcugh. Cumberland Co:uzty, IrQMSY'-vania, more I. rr.icularly decig,lelf.rd and deRcribed as gollows, to wit: 'r.ECIINN'RG at a point seventy-five (75) feet `rom rh: Su;alu:.-st -,Crnrcr of Seventy Street (formerly Lorne Stre: A and Rummel ?.venue, and Pxrending along the Southern line of III nidl Avenue in an 3astar'ly direrrion thirty-fi•je {35) feet to Lot ^.o. 19 and extending back an a•vcn width one hundred and fifty (150) l.eat to Peach Ailey, being improved by a two and one-half story =:ne aoartxent :nuildina and blue;c garage and known as number 632 a:' 536 Hummel Avenuv. BUN(. Lot No. 2C, Seci:on P, in a Plan .:f hots :cnuwn rs Plau No. :, or P.ivercon, said Plan being recorded in '.e Recnrder'e or.fice for Cumberlane- County Pennsylvania, in Deee Book j, Wmlume 1, pmge -n:. LEING THE SAME PREMISES which Ray E. :, robs and Gonna M, Jacobs, i_: u:ifa, formerly known as Donna M. Ho11ei1 ach by their Teed da..nd July °S, 1997 and which is intended to be niccrded, granteri and crjuv.yrc - unto Robert J. Holsberger, Jr. DD® PA91_NOR0106 ACT 91 NOTICE ' TAKE ACTION TO SAVE YOUR HOME FROM FORECLOSURE GE Capital Assistance Program may be able to he14FLpyhLMor0apdetta3&, Sol lowing notice to find out how the program works. A Unit of General Electric Capital Mortgage Corporation 4680 Hallmark Parkway. San Bernardino, CA 92407 If you need more information, call the Pennsylvania Housing Finance Agency at 1-800-342-2397. La Notification en adjunto as de sums. importancia, pues afecta su derecho a continuar viviendo en su casa. Si no comprende el contenido de esta notificacion obtenga una traduccion immediatamente llamando esta agencia (Pennsylvania Housing Finance Agency) sin cargos al numero mencionado arriba. Puedes ser elegible Para un prestamo por el programs llamado "Homeowners' Emergency Mortgage Assistance Program" al cual puede salvar su casa de la perdida del derecho a redimir su hipoteca. ACT 91 NOTICE IMPORTANT: NOTICE OF HOMEOWNERS' EMERGENCY MORTGAGE ASSISTANCE PROGRAM PLEASE READ THIS NOTICE. YOU MAY BE ELIGIBLE FOR FINANCIAL ASSISTANCE WHICH CAN SAVE YOUR HOME FROM FORECLOSURE AND HELP YOU MAKE FUTURE MORTGAGE PAYMENTS June 30, 1999 RE: GE CAPITAL MORTGAGE SERVICES, INC. Property Address: 632-634 HUtM7EL AVENUE, LEMOYNE PA 17043 Loan # 30880371 TO: ROBERT J HOLSBERGER JR 4206 ALLEN ROAD CAMP HILL, PA 17011 FROM: GE CAPITAL MORTGAGE SERVICES, INC. You may be eligible for financial assistance that will prevent foreclosure on your mortgage if you comply with the provisions of the Homeowners' Emergency Mortgage Assistance Act of 1983 (the "ACT"). You may be eligible for emergency temporary assistance if you default has been caused by circumstances beyond your control, you have a reasonable prospect of resuming your mortgage payments, and if you meet other eligibility requirements established by the Pennsylvania Housing Finance Agency. Please read all of this Notice. it contains an explanation of your rights. EXHIBIT A Under the Act, you are entitled to a temporary stay of foreclosure on your rt(age for thirty (30) days from the date of this Notice. During that d'Iff6"3'?rou must arrange and attend a "face-to-face" meeting with a re esentative of this lender, or with a designated consumer crefdi?,L counseling agency. The purpose of this meeting is to attempt tdfffw?*Wt a ling must occur in the next thirty (30) days. GE Capital Mortgage Services, tar.. A Unit of General Electric Capital Mortgage Corporation if you attend a face-to-face meeting .v(ySbpnbad.e?rkkadsDarn,Rmmkit7,ICS consumer credit counseling agency identified in this notice, no further proceeding in mortgage foreclosure may take place for thirty (30) days after the date of this meeting. The name, address, and telephone number of our representative is: GE CAPITAL MORTGAGE SERVICES, INC. 625 Maryville Centre Drive St. Louis, MO 63141 1 (800) 317-4322 The names and addresses of designated consumer credit counseling agencies are shown on the attached sheet. It is only necessary to schedule one face-to-face meeting. You should advise this lender immediately of your intentions. Your mortgage is in default because you have failed to pay promptly installments of principal and interest, as required for at least sixty (60) days. The total amount of the delinquency is $1,305.32. That sum includes the following: payments due 05/01/99 through the first of this month and late charges. Your mortgage is also in default for the following reason: Unable to Contact. If you have tried and are unable to resolve this problem at or after our face-to-face meeting, you have the right to apply for financial assistance from the Homeowners' Emergency Mortgage Assistance Fund. In order to do this, you must fill out, sign and file a completed Homeowners' Emergency Assistance Application with one of the designated consumer credit counseling agencies listed on the attachment. An application for assistance may only be obtained from a consumer credit counseling agency. The consumer credit counseling agency will assist you in filling out your application and will submit your completed application to the Pennsylvania Housing Finance Agency. Your application must be filed or 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 other time periods set forth in this letter, foreclosure may proceed against your home immediately. Available funds for emergency mortgage assistance are very limited. They will be disbursed by the Agency under the eligibility criteria established by the ACT. It is extremely important that your application is accurate and complete in every respect. The Pennsylvania Housing Finance Agency has sixty (60) days to make a decision after it receives your application. During that additional time, no foreclosure proceedings will be pursued against you if you have met the time requirements set forth above. You will be notified directly by the Agency of its decision on your application. The Pennsylvania Housing Finance Agency is located at 2101 North Front t, Post Office Box 8029, Harrisburg, Pennsylvania 17105. Telephone 17) 780-3800 or 1-800-342-2397 (toll free number). Persons with im fired hearing can call 1-800-342-2397. GE Capital f n a 1 ion, you may receive ano er notice rom is lender uncteF Act 6 of 1974. That notice is called a "Not iceGBffipiftW&glyiQUVhS, Noreclose." You must read both notices, since they both exporabnGen ghtaxthatmy4P)d=?sortrave under Pennsylvania law. However, if you chocFs*H,,ttoareftereiseBycrt=oxigboa described in this notice, you cannot foreclosed upon while you* are receiving that assistance. Sincerely, 30880371 Tonika Goode-Payne,l (800) 317-4322 , Collection Department The following disclosure is required by applicable federal and state law for certain loans that we service: This communication is from a debt i. collector and is an attempt to collect a debt; any information obtained will be used for that purpose. ?_ GE Capital BE Capltal Mortgage Services, Inc. A Unit or General Electric Capital Mortgage Corporation 4680 Hallmark Parkway San Bernardino. CA 92407 HUD APPROVED COUNSELING AGENCIES PENNSYLVANIA DELAWARE COUNTY H.O.P.E. BAYFRONT NATO, INC. PHILADELPHIA COUNCIL FOR COMMUNITY 312 CHESTNUT STREET ADVANCEMENT ERIE, PA 16507 511 WELSH STREET (814) 459-2761 CHESTER, PA 19013 (215) 872 3500 COMMUNITY RESOURCES FOR INDEP 2222 FILMORE AVENUE ERIE, PA 16506 (814) 838-7222 INDIANA COUNTY COMMUNITY ACTION PROGRAM INC. 827 WATER STREET PO BOX 187 INDIANA, PA 15701 (412) 465-2657 NORTHERN TIER COMMUNITY ACTION CORPORATION 135 WEST 4TH STREET EMPORIA, PA 15834 (814) 486-1161 GREATER ERIE COMMUNITY ACTION AGENCY 18 WEST 9TH STREET ERIE, PA 16501 (814) 459-4581 ELK COUNTY HOUSING AUTHORITY 424 WATER STREET EXT. PO BOX 100 JOHNSONBURGH, PA 15845 (814) 965-2532 ASSOCIATED FAMILY SERVICES 213 CENTER STREET MEADVILLE, PA 16335 (814) 337-8457 NEW KENSINGTON C.D.C. 2513-15 FRANKFORD AVENUE PHILADELPHIA, PA 19125 (215) 427-0350 HARRISBURG FAIR HOUSING COUNCIL 1228 BAILEY STREET HARRISBURG, PA 17103 (717) 238-9540 TABOR COMMUNITY SERVICES 439 EAST KING STREET LANCASTER, PA 17602 (717) 397-5182 BOOKER T. WASHINGTON CENTER 1720 HOLLAND STREET ERIE, PA 16503 (814) 453-5744 URBAN LEAGUE OF METROPOLITAN HARRISBURG 25 NORTH FRONT STREET HARRISBURG, PA 17101 (717) 234-3253 HOUSING OPPORTUNITIES, INC 133 SEVENTH AVENUE PO BOX 9 MCKEESPORT, PA 15132 (412) 664-1590 LAWRENCE COUNTY SOCIAL SERVICES,INC. 33-39 SOUTH JEFFERSON STREET NEW CASTLE, PA 16103 (412) 658-7258 PHILADELPHIA COUNCIL FOR COMMUNITY ADVANCEMENT 100 NORTH 17TH STREET - SUITE 600 PHILADELPHIA, PA 19103 (215) 567-7803 GE Capital GE Cepdal Mortgage Services. Inc. :UGG: dilUn 46dC n46n:4: t iu ?n .v4r SB^ 6?^:d(ItlriC CA 9240„- HUD APPROVED COUNSELING AGENCIES PENNSYLVANIA (Conc) TENANTS' ACTION GROUP CENTER. FOP INDEPENDENT LIVING SW PA OF PHILADELPHIA 7110 PENN AVENUE 21 SOUTH 12TH STREET - 12TH FLOOR PITTSBURGH, PA 15208 PHILDELPHIA, PA 19107 (4121 371-7700 (215) 575-0700 TREHAD CENTER. OF NE PENNSYLVANIA HOUSING ASSOCIATION INFORMATION PROGRAM 7 LAKE AVENUE 1314 CHESTNUT STREET - SUITE 900 MONTROSE, PA 18801 PHILADELPHIA, PA 19107 (717) 278-3338 (215) 545-6010 MORTGAGORS C0U14SELED AT 658-60 NORTH WATTS STREET, PHILADELPHIA, PA 19123 NORTHWEST COUNSELING SERVICE PHILADELPHIA HOUSING 5001 NORTH BROAD STREET DEVELOP14ENT CORPORTATION PHILADELPHIA, PA 19141 1234 MARKET STREET - 10TH FLOOR (215) 549-2344 PHILADELPHIA, PA 19107 (215) 448-3137 OR (215) 448-3132 URBAN LEAGUE OF PHILADELPHIA CONSUMER CREDIT COUNSELING 4601 MARKET STREET OF WESTERN PENNSYLVANIA PHILADELPHIA, PA 19139 309 SMITHFIELD STREET - SUITE 2000 (215) 476-4040 PITTSBURGH, PA 15222 (412) 471-7584 ELDER-ADO, INC HILL COMMUNITY DEVELOPMENT CORPORTATION 320 BROWNSVILLE ROAD 2015-2017 CENTRE AVENUE PITTSBURGH, PA 15210 PITTSBURGH, PA 15219 (412) 381-6900 (412) 765-1320 - ECONOMIC OPPORTUNITY CABINET MERCER COUNTY 118 EAST NORWEGIAN STREET COMMUNITY ACTION AGENCY - POTTSVILLE, PA 17901-2921 309 OHIO STREET (717) 622-1995 , SHARON, PA 16146 (412) 342-6222 TABLELAND SERVICES, INC. WARREN FOREST COUNTY E.O.C. 131 NORTH CENTER AVENUE 1209 PENNSYLVAIA AVENUE WEST PO BOX 756 PO BOX 547 SOMERSET, PA 15501 WARREN, PA 16365 (814)445-9628 OR (814) 4-15-01-18 (81-1) 726-2400 '1tA GE Capital GE Capital Mortgage Services, Inc. A Unit of General Electric Camtal Mortgage Corporation 4680 Hallmark Parkway San Bernardino. CA 92407 HUD APPROVED COUNSELING AGENCIES PENNSYLVANIA(COnt) GARFIELD JUBLIEE ASSOCIATION, INC 5138 PENN AVENUE PITTSBURGH, PA 15224 (412) 665-5200 BERKS COMMUNITY ACTION AGENCY BUDGET COUNSELING CENTER 247 NORTH FIFTH STREET READING, PA 19601 (215) 375-7866 FAYETTE COUNTY COMMUNITY ACTION AGENCY 137 NORTH BEESON AVENUE UNIONTOWN, PA 15401 (412) 437-6050 WASHINGTON-GREENE COMMUNITY ACTION CORPORATION 315 EAST HALLAM AVENUE WASHINGTON, PA 15301 (412) 225-9550 HOUSING COUNCIL OF YORK 116 NORTH GEORGE STREET YORK, PA 17401 (717) 854-1541 COMMISSION OF ECONOMIC OPPORTUNITY OF LUZERNE COUNTY 122-213 SOUTH MAIN STREET WILKES-BARRE, PA 18701 (717) 826-0510 URBAN LEAGUE OF PITTSBURGH ONE SMITHFIELD STREET PITTSBURGH, PA 15222 (412) 261-1130 SHENANGO VALLEY URBAN LEAGUE 39 CHESTNUT STREET SHARON, PA 16146 (412) 981-5310 TRI-COUNTY PARTNERSHIP FOR INDEPENDENT LIVING 69 EAST BEAU STREET WASHINGTON, PA 15301 (412) 223-5115 CONSUMER CREDIT COUNSELING SERVICE OF LEHIGH VALLEY 3671 CRESCENT COURT EAST WHITEHALL, PA 18052 (215) 821-4011 WASHINGTON-GREENE COMMUNITY ACTON CORPORATION 22 WEST HIGH STREET WAYNESBURG, PA 15370 (412) 852-2893 GE Capital .. GECapltal Mortgage Services, Inc. A Unit of General Electric Camtal Mortgage Corporation 4680 Hallmark Parkwa/. San Bernardino. CA 92407 DDDDEMDPA91_NOR0106 ACT 91 NOTICE TAKE ACTION TO SAVE YOUR HOME FROM FORECLOSURE The Commonwealth of Pennsylvania's Homeowners' Emergency Mortgage Assistance Program may be able to help you. Read the following notice to find out how the program works. If you need more information, call the Pennsylvania Housing Finance Agency at 1-800-342-2397. La Notification en adjunto es de suma importancia, pues afecta su derecho a continuer viviendo en su Casa. Si no comprende el contenido de esta notificacion obtenga Una traduccion immediatamente llamando esta agencia (Pennsylvania Housing Finance Agency) sin cargos al numero mencionado arriba. Puedes ser elegible para un prestamo por el programa llamado "Homeowners' Emergency Mortgage Assistance Program" al cual puede salvar su Casa de la perdida del derecho a redimir su hipoteca. ACT 91 NOTICE IMPORTANT: NOTICE OF HOMEOWNERS' EMERGENCY MORTGAGE ASSISTANCE PROGRAM PLEASE READ THIS NOTICE. YOU MAY BE ELIGIBLE FOR FINANCIAL ASSISTANCE WHICH CAN SAVE YOUR HOME FROM FORECLOSURE AND HELP YOU MAKE FUTURE MORTGAGE PAYMENTS June 30, 1999 RE: GE CAPITAL MORTGAGE SERVICES, INC. Property Address: 632-634 HUMMEL AVENUE, LEMOYNE PA 17043 Loan # 30880371 TO: ROBERT J HOLSSERGER JR 632-634 HUMMEL AVENUE LEMOYNE, PA 17043 FROM: GE CAPITAL MORTGAGE SERVICES, INC. You may be eligible for financial assistance that will prevent foreclosure on your mortgage if you comply with the provisions of the Homeowners' Emergency Mortgage Assistance Act of 1983 (the "ACT"). You may be eligible for emergency temporary assistance if you default has been caused by circumstances beyond your control, you have a reasonable prospect of resuming your mortgage payments, and if you meet other eligibility requirements established by the Pennsylvania Housing Finance Agency. Please read all of this Notice. It contains an explanation of your rights. i 'C6;7 GE Capital GE Capital Mortgage Services, Inc. A Unit of General Electric Capnal aortgage Corporation 4600 Hallmark Parkway. San Bernardino. CA 92407 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 proceeding in mortgage foreclosure may take place for thirty (30) days after the date of this meeting. The name, address, and telephone number of our representative is: GE CAPITAL MORTGAGE SERVICES, INC. 625 Maryville Centre Drive St. Louis, MO 63141 1 (800) 317-4322 The names and addresses of designated consumer credit counseling agencies are shown on the attached sheet. It is only necessary to schedule one face-to-face meeting. You should advise this lender immediately of your intentions. Your mortgage is in default because you have failed to pay promptly installments of principal and interest, as required for at least sixty (60) days. The total amount of the delinquency is $1,305.32. That sum includes the following: payments due 05/01/99 through the first of this month and late charges. Your mortgage is also in default for the following reason: Unable to Contact. If you have tried and are unable to resolve this problem at or after our face-to-face meeting, you have the right to apply for financial assistance from the Homeowners' Emergency Mortgage Assistance Fund. In order to do this, you must fill out, sign and file a completed Homeowners' Emergency Assistance Application with one of the designated consumer credit counseling agencies listed on the attachment. An application for assistance may only be obtained from a consumer credit counseling agency. The consumer credit counseling agency will assist you in filling out your application and will submit your completed application to the Pennsylvania Housing Finance Agency. Your application must be filed or 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 other time periods set forth in this letter, foreclosure may proceed against your home immediately. Available funds for emergency mortgage assistance are very limited. They will be disbursed by the Agency under the eligibility criteria established by the ACT. It is extremely important that your application is accurate and complete in every respect. The Pennsylvania Housing Finance Agency has sixty (60) days o GE Capital Of CaNtal Modgage Servleer, Inc. A Unit of General Electric Capnal A10097ge Corporarion to make a decision after 4680 Hallmark Parkway. San Bernardino, CA 92407 additional time, no foreclosure Proc I your application. During that you have met the time requirements will be pursued against directly by the Agency of itsmdecision onrth above. you if You will be notified Your application. 0 GE Capital GE Lap(al morryaye Sri aces. lnc. "I'n? bN. r ? van a r c:. t 3? ? r r'e : d?'?,? r :..,. e Street post O: cN bo.? 8C,, C' I 7; North Flom rr,. _.r .rg, ?e:;nsy nnia 1710, '/1 7 780-3800 or 1-800-342-2357 (tcl? phone impaired 'nearing car. cal? 1-89C-3;.-._L34., free ramber,, Telephone iersons with in add'_Lior., rou may ecr_._i v.= anoti:er .ot'ce `tor', 974. That notice is call tr lender under Act o of ed a "Plot.oe of :ntentior- to Foreclose. You both notices, s-4:ce -aci oo ou must Pennsylvania la•e. However, ;a ti: cxp azr: rights that you now have under in this notice, ou cannot + y01;. choose to exercise... your rights described 1 °r'=c:osed upo:: wirila assistance. you are receiving that Sincerely, 30880'371 TOni3 Gcode-Payne,-' (800) 317-5322 Col lecc'or. Department The for ce follo•wi ng disclosure s re?u. red by applicab-'e tetera_ and state law rtain loans that we service: This cornmunicat.ion is from a debt collector and is an attempt 'Hill be used collect a debt.; an.*' ia'_ormacion obtained ed for that purposee. . w GE Capital CE Capital Mortgage Services, Inc. A Unit of General Electric Capnal Alortgage Corporation 4680 Hallmark Parkway. San Bemaroino, CA 02407 HUD APPROVED COUNSELING AGENCIES PENNSYLVANIA DELAWARE COUNTY H.O.P.E. BAYFRONT NATO, INC. PHILADELPHIA COUNCIL FOR COMMUNITY 312 CHESTNUT STREET ADVANCEMENT ERIE, PA 16507 511 WELSH STREET (814) 459-2761 CHESTER, PA 19013 (215) 872 3500 COMMUNITY RESOURCES FOR INDEP 2222 FILMORE AVENUE ERIE, PA 16506 (814) 838-7222 HARRISBURG FAIR HOUSING COUNCIL 1228 BAILEY STREET HARRISBURG, PA 17103 (717) 238-9540 INDIANA COUNTY COMMUNITY ACTION PROGRAM INC. P17 WATER STREET PO BOX 187 INDIANA, PA 15701 (412) 465-2657 NORTHERN TIER COMMUNITY ACTION CORPORATION 135 WEST 4TH STREET EMPORIA, PA 15834 (814) 486-1161 GREATER ERIE COMMUNITY ACTION AGENCY 18 WEST 9TH STREET ERIE, PA 16501 (814) 459-4581 ELK COUNTY HOUSING AUTHORITY 424 WATER STREET EXT. PO BOX 100 JOHNSONBURGH, PA 15845 (814) 965-2532 ASSOCIATED FAMILY SERVICES 213 CENTER STREET MEADVILLE, PA 16335 (814) 337-8457 NEW KENSINGTON C.D.C. 2513-15 FRANKFORD AVENUE PHILADELPHIA, PA 19125 (215) 427-0350 TABOR COMMUNITY SERVICES 439 EAST KING STREET LANCASTER, PA 17602 (717) 397-5182 BOOKER T. WASHINGTON CENTER 1720 HOLLAND STREET ERIE, PA 16503 (814) 453-5744 URBAN LEAGUE OF METROPOLITAN HARRISBURG 25 NORTH FRONT STREET HARRISBURG, PA 17101 (717) 234-3253 HOUSING OPPORTUNITIES, INC 133 SEVENTH AVENUE PO BOX 9 MCKEESPORT, PA 15132 (412) 664-1590 LAWRENCE COUNTY SOCIAL SERVICES,INC. 33-39 SOUTH JEFFERSON STREET NEW CASTLE, PA 16103 (412) 658-7258 PHILADELPHIA COUNCIL FOR COMMUNITY ADVANCEMENT 100 NORTH 17TH STREET - SUITE 600 PHILADELPHIA, PA 19103 (215) 567-7803 a GE Capital GE Capital Mortgage Services, Inc. A Unit of General Electric Capital Mortgage Corporation 4680 Hallmark Parkway San Bernardino. CA 92407 HUD APPROVED COUNSELING AGENCIES PENNSYLVANIA(COnt) TENANTS' ACTION GROUP CENTER FOR INDEPENDENT LIVING SW PA OF PHILADELPHIA 7110 PENN AVENUE 21 SOUTH 12TH STREET - 12TH FLOOR PITTSBURGH, PA 15208 PHILDELPHIA, PA 19107 (412) 371-7700 (215) 575-0700 TREHAD CENTER OF NE PENNSYLVANIA 7 LAKE AVENUE MONTROSE, PA 18801 (717) 278-3338 HOUSING ASSOCIATION INFORMATION PROGRAM 1314 CHESTNUT STREET - SUITE 900 PHILADELPHIA, PA 19107 (215) 545-6010 MORTGAGORS COUNSELED AT 658-60 NORTH WATTS STREET, PHILADELPHIA, PA 19123 NORTHWEST COUNSELING SERVICE 5001 NORTH BROAD STREET PHILADELPHIA, PA 19141 (215) 549-2344 URBAN LEAGUE OF PHILADELPHIA 4601 MARKET STREET PHILADELPHIA, PA 19139 (215) 476-4040 ELDER-ADO, INC 320 BROWNSVILLE ROAD PITTSBURGH, PA 15210 (412) 381-6900 ECONOMIC OPPORTUNITY CABINET 118 EAST NORWEGIAN STREET POTTSVILLE, PA 17901-2921 (717) 622-1995 TABLELAND SERVICES, INC. 131 NORTH CENTER AVENUE PO BOX 756 SOMERSET, PA 15501 (814)445-9628 OR (814) 445-0148 PHILADELPHIA HOUSING DEVELOPMENT CORPORTATION 1234 MARKET STREET - 10TH FLOOR PHILADELPHIA, PA 19107 (215) 448-3137 OR (215) 448-3132 CONSUMER CREDIT COUNSELING OF WESTERN PENNSYLVANIA 309 SMITHFIELD STREET - SUITE 2000 PITTSBURGH, PA 15222 (412) 471-7584 HILL COMMUNITY DEVELOPMENT CORPORTATION 2015-2017 CENTRE AVENUE PITTSBURGH, PA 15219 (412) 765-1320 MERCER COUNTY COMMUNITY ACTION AGENCY 309 OHIO STREET SHARON, PA 16146 (412) 342-6222 WARREN FOREST COUNTY E.O.C. 1209 PENNSYLVAIA AVENUE WEST PO BOX 547 WARREN, PA 16365 (814) 726-2400 GE Capital CE Capital Mortgage Services, Inc. A Unit of General Electric Capital Mortgage Corporation 4680 Hallmark Parkway, San 6ernardmo. CA 92407 HUD APPROVED COUNSELING AGENCIES PENNSYLVANIA(COAt) GARFIELD JUBLIEE ASSOCIATION, INC 5138 PENN AVENUE PITTSBURGH, PA 15224 (412) 665-5200 URBAN LEAGUE OF PITTSBURGH ONE SMITHFIELD STREET PITTSBURGH, PA 15222 (412) 261-1130 BERMS COMMUNITY ACTION AGENCY BUDGET COUNSELING CENTER 247 NORTH FIFTH STREET READING, PA 19601 (215) 375-7866 FAYETTE COUNTY COMMUNITY ACTION AGENCY 137 NORTH BEESON AVENUE UNIONTOWN, PA 15401 (412) 437-6050 WASHINGTON-GREENE COMMUNITY ACTION CORPORATION 315 EAST HALLAM AVENUE WASHINGTON, PA 15301 (412) 225-9550 HOUSING COUNCIL OF YORK 116 NORTH GEORGE STREET YORK, PA 17401 (717) 854-1541 COMMISSION OF ECONOMIC OPPORTUNITY OF LUZERNE COUNTY 122-213 SOUTH MAIN STREET WILKES-BARRE, PA 18701 (717) 826-0510 SHENANGO VALLEY URBAN LEAGUE 39 CHESTNUT STREET SHARON, PA 16146 (412) 981-5310 TRI-COUNTY PARTNERSHIP FOR INDEPENDENT LIVING 69 EAST BEAU STREET WASHINGTON, PA 15303. (412) 223-5115 CONSUMER CREDIT COUNSELING SERVICE OF LEHIGH VALLEY 3671 CRESCENT COURT EAST WHITEHALL, PA 18052 (215) 821-4011 WASHINGTON-GREENE COMMUNITY ACTON CORPORATION 22 WEST HIGH STREET WAYNESBURG, PA 15370 (412) 852-2893 V_E..R I_F I.C A_T._LQ._N ¦ Mark J. Udren, Esquire, hereby states that he is the attorney for the Plaintiff, a corporation unless designated otherwise; that he is authorized to take this Verification and does so because of the exigencies regarding this matter, and because Plaintiff must verify much of the information through agents, and because he has personal knowledge of some of the facts averred in the foregoing pleading; and that the statements made in the foregoing pleading are true and correct to the best of his knowledge, information and belief and the source of his information is public records and reports of Plaintiff's agents. The undersigned understands that this statement herein is made subject to the penalties of 18 Pa.C.S. Section 4904 relating to unsworn falsification to authorities. Mark J. Udren, ESQ IRE MARK J. UDREN & ASSOCIATES 4 0 13 N Ull n O DO 0 ?J cv , L ' `. 1 SHERIFF'S RETURN - REGULAR CASE NO: 1999-04866 P COMMONWEALTH OF PENNSYLVANIA: COUNTY OF CUMBERLAND GE CAPITAL MORTGAGE SERVICES VS. HOLSBERGER ROBERT J JR KENNETH GOSSERT , Sheriff or Deputy Sheriff of CUMBERLAND County, Pennsylvania, who being duly sworn according to law, says, the within COMPLAINT - MORT FORE was served upon HOSBERGER ROBERT J JR the defendant, at 19:45 HOURS, on the 17th day of August 1999 at 4206 ALLEN ROAD CAMP HILL, PA 17011 CUMBERLAND County, Pennsylvania, by handing to ROBERT HOLSBERGER, JR. a true and attested copy of the COMPLAINT - MORT FORE together with NOTICE and at the same time directing His attention to the contents thereof. Sheriff's Costs: So answers- Docketing 18.00 Service 8.68 !,r Affidavit .00??• Surcharge 8.00 I omas in Seri AR1K J.999REN & ASSSOC iIIS r Sworn and subscribed to before me this J$?-' day of 19A.D. 01?'n0 a`Y .- P//?? 3S.KQ 4UH2IHH EUV SaE)KW CI S ?...v??V: ! ll::: ); uZ?a I U <' aouepzooos Pup 33(auieid au , ,c s? s , au ; ?J - . ?..oqr wnu 1-: sE ase duePue 3aO . (t d? :: UT. L'-f aW'•;, .laQ :jUaLL:ne? MOSDE J aU1 2 [OWC';j .zed sab3el.I0 age? 66/87/5 v 66/t'/B w0a 97-IV8 .u ET ?['06?,GL•? dwo? zad qsa.za2ui auTpjQWC)D uT y:tzo; has SH snc I<: r- pUe sabewep aL(j yG O' U=+E'SSC [1Ue 'saSil a 113d pabeD?30W [eS OU RSG TJ37:0> .I r.J PUP y'Oa.,t3U? a:, l.3 cls r ;UT.e'[(jWOD S i 3? t:juTe-[d Q?; _Z;?Msui? up a'r-:; 0. 3...I iPWJ -20-7 6liep ?i. UZil'?2M aqU ?surpbp pup 3; .u, L, au o uvl:r- u, y _ (s) =tUepua3aQ uauibpn.F zaqua AEpurg 4dC loNof-uoNa allL OS SHDYHYO d0 lKRxsSaSSY wy amsKY ox aus7lYd 603 aaffmoaac 'dod adIoayud wld, 1. !n r.-, »6b L6 'GA' - (s) ?uepua?a0 IIGLi Kd 'ITTH dWe,7 peo_ uaTT'd 90ZV j. of agsiOH 'P :jSagOg is G dL S?.i`i ..'d d(id 1: NiiJ.dU!n 33!1u?eEd F.?un,J p11,11 quit _ /_GYZ6 7J 'oUTPIeUaag ueS 14016'71:7(j '71PJ;: Aen:,fjrd :(zeWTTpH 089V SvH'ld IJGW'WGa dr% Te?rde0 a°J 0069-Z86-609 6E080 PK '771H AIURHJ OUS a.LiAS 'xvt4HOIH sOHIY 'H 060T ZOE60 'OH 'Q'I xSSY aaTubaa 'ue2p[1 't KsrHi :EH 33I.LNIY'Id HU3 xi3N230:L1.?( sa,LYIDOssY '9 N uan 'P xavm NARK J. UDREN & ASSOCIATES BY: Nark J. Udren, Esquire ATTY I.D. NO. 04302 1040 N. KINGS HIGHWAY, SUITE 500 CHERRY HILL, NJ 08034 609-482-6900 GE Capital Mortgage Services, Inc 4680 Hallmark Parkway San Bernardino, CA 92407 Plaintiff V. Robert J. Holsberger, Jr. 4206 Allen Road Camp Hill, PA 17011 Defendant(s) ATTORNEY FOR PLAINTIFF 'COURT OF COMMON PLEAS :CIVIL DIVISION :Cumberland County MORTGAGE FORECLOSURE NO. 99-4866 civil term PRAECIPE FOR JUDGMENT FOR FAILURE TO ANSWER AND ASSESSMENT OF DAMAGES TO THE PROTHONOTARY: Kindly enter judgment in favor of the Plaintiff and against the Defendant(s) for failure to file an Answer to Plaintiff's Complaint within 20 days from service thereof and for foreclosure and sale of the mortgaged premises, and assess Plaintiff fIs damages as follows: As set forth in Complaint Interest per Complaint From 8/4/99 to 9/28/99 Late charges per Complaint From 8/15/99 to 9/28/99 Escrow payment per Complaint From 9/1/99 to 9/28/99 $70,240.13 847.28 50.16 110.13 TOTAL $7.1,242.70 I hereby certify that (1) the addresses of the Plaintiff and Defendant are as shown above, and (2) that notice has been given in accordance with Rule 237.1, a copy of which is attached hereto. =N & ASSOCIATES "Mark J. Udre , ESQUIRE Attorney for Plaintiff DAMAGES ARE HEREBY ASSESSED AS INDI D DATE: 401 yer!N PRO PROTHY M WL. N n L F.' `m a O C7% J U" U' 9 T l r 0 I -V- J NARK J. UDREN & ASSOCIATES BY: Mark J. Udren, Esquire ATTY I.D. NO. 04302 1040 N. RINGS HIGHWAY, SUITE 500 CHERRY_HILL, NJ 08034 GE Capital Mortgage Services, Inc 4680 Hallmark Parkway San Bernardino, CA 92407 Plaintiff V. Robert J. Holsberger, Jr. 4206 Allen Road Camp Hill, PA 17011 Defendant(s) DATED: September 10, 1999 TO: Robert J. Holsberger, Jr. 4206 Allen Road Camp Hill, PA 17011 ATTORNEY FOR PLAINTIFF COURT OF COMMON PLEAS CIVIL DIVISION Cumberland County NO. 99-4866 civil term 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. LAWYER REFERRAL SERVICE Cumberland County Bar Association 2 Liberty Ave. Carlisle, PA 17013-3387 717-249-3166 or 800-990-9108 NOTIFICACION_IMPORTANTE USTED SE ENCUENTRA EN ESTADO DE REBELDIA POR NO HABER TOMADO LA ACCION REQUIRIDA DE SU PARTE EN ESTE CASO. AL NO TOMAR LA ACCION DEBIDA DENTRO DE UN TERMINO DE DIEZ (10) DIAS DE ESTA NOTIFICACION, EL TRIBUNAL PODRA, SIN NECESIDAD DE COMPARARECER USTED EN CORTE O ESCUCHAR PREUBA ALGUNA, DICTAR SENTENCIA EN SU CONTRA, USTED PUEDE PERDER BIENES Y OTROS DERECHOS, IMPORTANTES. DEBE LLEVAR ESTA NOTIFICACION A UN ABOGADO IMMEDIATAMENTE SI USTED NO TIENE ABOGADO, O SI NO TIENE DINERO SUFICIENTE PARA TAL SERVICIO, VAYA EN PERSONA 0 LLAME POR TELEFONO A LA OFICINA, CUYA DIRECCION SE ENCUENTRA ESCRITA ABAJO PARR AVERIGUAR DONDE SE PUEDE CONSEGUIR ASSISTENCIA LEGAL. SERVICIO DE REFERENCIA LEGAL LAWYER REFERRAL SERVICE Cumberland County Bar Association 2 Liberty Ave. Carlisle, PA 17013-3387 717-249-3166 or 800-990-9108 NOTICE: PURSUANT TO THE FAIR DEBT COLLECTION PRACTICES ACT, THIS LAW FIRM IS DEEMED TO BE A DEBT COLLECTOR AND THIS IS AN ATTEMPT TO COLLECT A DEBT. ANY INFORMATION OBTAINED WILL BE USED FOR THAT PURPOSE. DARK J. UDREN & ASSOCIATES ATTORNEY FOR PLAINTIFF BY: Mark J. Udren, Esquire ATTY I.D. NO. 04302 1040 N. RINGS HIGHWAY, SUITE 500 CHERRY HILL, NJ 08034 609-482-6900 GE Capital Mortgage Services, Inc COURT OF COMMON PLEAS 4680 Hallmark Parkway :CIVIL DIVISION San Bernardino, CA 92407 :Cumberland County Plaintiff MORTGAGE FORECLOSURE V. Robert J. Holsberger, Jr. 4206 Allen Road NO. 99-4866 civil term Camp Hill, PA 17011 Defendant(s) PRAECIPE FOR WRIT OF EXECUTION TO THE SHERIFF: Issue Writ of Execution in the above matter: Amount due $71,247.70 Interest From September 29, 1999 2,330.02 to Date of Sale March 1, 2000 Per diem 0$15.13 (Costs to be added) 632-634 Hummel Avenue LeMOyne, PA 17043 LEGAL DESCRIPTION ATTACHED MARK J. UDREN & ASSOCIATES /tA_?? ark J. Udren, ESQUIRE ATTORNEY FOR PLAINTIFF cn s E 00 J? o z g LO c .tea' LO Q ?S O o o rn O v MARK J. UDREN 6 ASSOCIATES BY: Mark J. Udren, Esquire ATTY I.D. NO. 04302 1040 N. KINGS HIGHWAY, SUITE 500 CHERRY HILL, NJ 080.34 609-482-6900 ATTORNEY FOR PLAINTIFF GE Capital Mortgage Services, COURT OF COMMON PLEAS Inc. :CIVIL DIVISION 4680 Hallmark Parkway :Cumberland County San Bernardino, CA 92407 -MORTGAGE FORECLOSURE Plaintiff V. Robert J. Holsberger, Jr. 4206 Allen Road :NO.' 99-4866 civil term ----Camp- Hill,-PA-17011-. Defendant(s) TO: ROBERT J. HOLSBERGER, JR. 4206 Allen Road Camp Hill, PA 17011 7 NOTICE Pursuant to Rule 236 of the Supreme Court of Pennsylvania, you are hereby notified that a Judgment has been entered against you in the above proceeding as indicated below. Prothoncitary _S_ Judgment by Default Money Judgment Judgment in Replevin Judgment for Possession ; Judgment on Award of Arbitration Judgment on Verdict Judgment on Court 'Findings IF YOU HAVE ANY QUESTIONS CONCERNING THIS NOTICE PLEASE CALL. ATTORNEY Mark J. Udren, Esquire At this telephone number: 609-482--69.00 1 r MARK J. UDREN & ASSOCIATES BY: Mark J. Udren, Esquire ATTY I.D. NO. 04302 1040 N. KINGS HIGHWAY, SUITE 500 CHERRY HILL, Na 08034 GE Capital Mortgage Services, Inc. 4680 Hallmark Parkway San Bernardino, CA 92407 Plaintiff V. Robert J. Holsberger, Jr. 4206 Allen Road Camp Hill, PA 17011 Defendant(s) ATTORNEY FOR PLAINTIFF COURT OF COMMON PLEAS CIVIL DIVISION Cumberland County MORTGAGE FORECLOSURE NO. 99-4866 civil term AFFIDAVIT OF NON-MILITARY SERVICE STATE OF coet-? ( (Lt i COUNTY OF 5^, Il (QC nU SS THE UNDERSIGNED being duly sworn, deposes and says that the averments herein are based upon investigations made and records maintained by us either as,Plaintiff or as servicing agent of the Plaintiff herein and that the above Defendant(s) are not in the Military or Naval Service of the United States of America or its Allies as defined in the Soldiers and Sailors Civil Relief Act of 1940, as amended, and that the age and last known residence and employment of each Defendant are as follows: Defendant: Robert J. Holsberger, Jr. Age: Over 18 Residence: As captioned above Employment: Unknown .1, J nA a , Sworn to and sub c ibed befo a me this r. a of ?lQ?(--s) /1 199 . Notaty 'Public Name: A Title: Company: .?? 4\!N E!fR P^ES TLEV -mm. ion 1 J AI r v Pubic - r ,.:r-,i0 _ i ?'brncrdno (_CU ty Comm. kzpiros r:w 6.1999 i psi dad." cn o- ci NZ C.) LL 6' . N ii= J W ry ,. H O L i7 p - g O cn U so e r MARE J. UDRBN & ASSOCIATES ATTORNEY FOR PLAINTIFF BY: Mark J. Udren, Esquire ATTY I.D. NO. 04302 1040 N. ICINGS HIGHWAY, SUITE 500 CHERRY HILL, NJ 08034 609-482-6900 GE Capital Mortgage Services, Inc :COURT OF COMMON PLEAS 4680 Hallmark Parkway :CIVIL DIVISION San Bernardino, CA 92407 :Cumberland County Plaintiff MORTGAGE FORECLOSURE V. Robert J. Holsberger, Jr. 4206 Allen Road 99-4866 civil term Camp Hill, PA 17011 Defendant(s) AFFIDAVIT PURSUANT TO RULE 3129.1 GE Capital Mortgage Services, Inc., Plaintiff in the above action, by its attorney, Mark J. Udren, ESQ., sets forth as of the date the Praecipe for the Writ of Execution was filed the following information concerning the real property located at: 632 - 634 Hummel Avenue, Lemoyne, PA 17043 1. Name and address of owner (s) or reputed Owner(s): Name Address ROBERT J. HOLSBERGER, JR. 4206 ALLEN RD., CAMP HILL, PA 17011 2. Name and address of Defendant(s) in the judgment: Name Address SAME AS ##1 ABOVE 3. Name and address of every judgment creditor whose judgment is a record lien on the real property to be sold: Name Address NONE 4. Name and address of the last recorded holder of every mortgage of record: Name Address Plaintiff herein. See Caption above. 5. Name and address of every other person who has any record lien on the property: Name Address NONE 6. Name and address of every other person who has any record interest in the property and whose interest may be affected by the sale: Name Address REAL ESTATE TAX DEPT. 1 COURTHOUSE SQ., CARLISLE, PA 17013 Domestic Relations Section 13 N. HANOVER ST., CARLISLE, PA 17013 7. Name and address of every other person of whom the plaintiff has knowledge who has any interest in the property which may be affected by the sale: Name Address Tenants/Occupants 632 - 634 Hummel Avenue, Lemoyne, PA 17043 I verify that the statements made in this affidavit are true and correct to the best of my personal knowledge or information and belief. I understand that false statements herein are made subject to the penalties of 18 Pa.C.S. sec. 4904 relating to unsworn falsification to authorities. DATED: September 28, 1999 MARK J. UDREN & ASSOCIATES k--, M k J. Udren, ESQ. Attorney for Plaintiff N C! O a Oa c: N j ma ' L C~.) o cwi C-' v a v I MARK J. UDREN & ASSOCIATES ATTORNEY FOR PLAINTIFF BY: Mark J. Udren, Esquire ATTY I.D. NO. 04302 1040 N. RINGS HIGHWAY, SUITE 500 CHERRY HILL, NJ 08034 609-482-6900 GE Capital mortgage Services, Inc COURT OF COMMON PLEAS 4680 Hallmark Parkway :CIVIL DIVISION San Bernardino, CA 92407 :Cumberland County Plaintiff -MORTGAGE FORECLOSURE V. :NO. 99-4866 civil term Robert J. Holsberger, Jr. 4206 Allen Road Camp Hill, PA 17011 Defendant(s) DATE: September 28, 1999 TO: ALL PARTIES IN INTEREST AND CLAIMANTS NOTICE OF SHERIFF'S SALE OF- REAL PROPERTY OWNER(S): ROBERT J. HOLSBERGER, JR. PROPERTY: 632 - 634 Hummel Avenue Lemoyne, PA 17043 Improvements: RESIDENTIAL DWELLING The above captioned property is scheduled to be sold at the Cumberland County Sheriff's Sale on March .l,_20.00, at 10:00 AM, at the COMMISSIONERS HEARING ROOM, 2ND FLOOR, COURTHOUSE, CARLISLE, PA. Our records indicate that you may hold a mortgage or judgment on the property which will be extinguished by the sale. You may wish to attend the sale to protect your interests. A Schedule of Distribution will be filed by the Sheriff on a date specified by the Sheriff not later that 30 days after sale. Distribution will be made in accordance with the schedule unless exceptions are filed thereto within 10 days after the filing of the schedule. Y N C7 b U o ?? 0? C7 1 ? d c» C,1?,G U ,_,. ?7 ur i : N ? W Q %p 4 O Q ALL THAT CERTAIN LOT OR TRACT OF LAND LOCATED IN THE BOROUGH OF LEMOYNE, CUMBERLAND COUNTY, PENNSYLVANIA, BOUNDED AND DESCRIBED AS FOLLOWS: BEGINNING AT A POINT SEVENTY FIVE (75) FEET FROM THE SOUTHEAST CORNER OF SEVENTY STREET (FORMERLY LORNE STREET) AND HUMMEL AVENUE, AND EXTENDING ALONG THE SOUTHERN LINE OF A HUMMEL AVENUE IN AN EASTERLY DIRECTION THIRTY FIVE (35) FEET TO LOT NO. 19 AND EXTENDING BACK AN EVEN WIDTH ONE HUNDRED AND FIFTY (150) FEET TO PEACH ALLEY, BEING IMPROVED BY A TWO AND ONE HALF STORY FRAME APARTMENT BUILDING AND BLOCK GARAGE KNOWN AND NUMBERED AS 632 AND 634 HUMMEL AVENUE. BEING KNOWN AS 632-634 HUMMEL AVENUE PROPERTY TAX PARCEL NO. 12-22-0824-167 TITLE TO SAID PREMISES IS VESTED IN ROBERT J. HOLSBERGER, JR. BY DEED FROM RAY E. JACOBS AND HIS WIFE, DONNA M. JACOBS, FORMERLY KNOWN AS DONNA M. HOLLENBACH, DATED 7/15/1997 AND RECORDED 7/17/1997 IN DEED BOOK 161 PAGE 160 CNJ Uti C: LL 4 N ?. F' O S' U aN i MARK J. UDREN & ASSOCIATES BY: Mark J. Udren ATTY I.D. NO. 04302 1040 N. KINGS HIGHWAY, SUITE 500 CHERRY HILL, NJ 08034 856-482-6900 GE Capital Mortgage Services, Inc. 4680 Hallmark Parkway San Bernardino, CA 92407 Plaintiff ATTORNEY FOR PLAINTIFF COURT OF COMMON PLEAS CIVIL DIVISION Cumberland County V. Robert J. Holsberger, Jr. 4206 Allen Road Camp Hill, PA 17011 Defendant(s) :NO. 99-4866 civil term AFFIDAVIT OF SERVICE PURSUANT TO Pa.R.C.P.RULE 3129.1 Plaintiff, by its/his/her Attorney, Mark J. Udren, Esquire, hereby verifies that: 1. A copy of the Notice of Sheriff fIs Sale, a true and correct copy of which is attached hereto as Exhibit "A", was sent to every recorded lienholder and every other interested party known as of the date of the filing of the Praecipe for the Writ of Execution, on the date(s) appearing on the attached Certificates of Mailing. 2. A Notice of Sheriff s Sale was sent to Defendant(s) by regular mail and certified mail on the date appearing on the attached Return Receipt, which was signed for by Defendant(s) on the date specified on the said Return Receipt. Copies of the said Notice and Return Receipt are attached hereto as Exhibit "B". 3. If a Return Receipt is not attached hereto, then service was by personal service on the date specified on the attached Return of Service, attached hereto as Exhibit "B". 4. If service was by Order of Court, then proof of compliance with said order is attached hereto as Exhibit IIBI'. All Notices were served within the time limits set forth by Pa Rule C.P. 3129. This Affidavit is made subject to the penalties of 18 Pa.C.S. Section 4904 relating to unsworn falsification to authorities. Dated: January 27, 2000 MARK J. UDREN & ASSOCIATES BY A"/ _ M rk J. Udren, Esquire Attorney for Plaintiff MARK J. UDREN & ASSOCIATES ATTORNEY FOR PLAINTIFF BY: Mark J. Udren, Esquire ATTY I.D. NO. 04302 1040 N. KINGS HIGHWAY, SUITE 500 CHERRY HILL, NJ 08034 609-482-6900 GE Capital Mortgage Services, Inc = COURT OF COMMON PLEAS 4680 Hallmark Parkway CIVIL DIVISION San Bernardino, CA 92407 Cumberland County Plaintiff MORTGAGE FORECLOSURE V. Roberti. Holsberger, Jr. 4206 Allen Road NO. 99-4866 civil term Camp Hill, PA 17011 Defendant(s) AMENDED AFFIDAVIT PURSUANT TO RULE 3129.1 GE Capital Mortgage Services, Inc., Plaintiff in the above action, by its attorney, Mark J. Udren, ESQ., sets forth as of the date the Praecipe for the Writ of Execution was filed the following information concerning the real property located at: 632 - 634 Hummel Avenue, Lemoyne, PA 17043 1. Name and address of Owner(s) or reputed Owner(s): Name Address ROBERT J. HOLSBERGER, JR. 4206 ALLEN RD., CAMP HILL, PA 17011 2. Name and address of Defendant(s) in the judgment: Name Address SAME AS #1 ABOVE 3. Name and address of every judgment creditor whose judgment is a record lien on the real property to be sold: Name Address NATIONSBANC MORTGAGE CORP. 101 EAST MAIN ST., SUITE 400, P.O. BOX 3514 O, LOUISVILLE, KY 40232-5140 4. Name and address of the last recorded holder of 'every mortgage of record: Name Address Plaintiff herein. See Caption above. 5. Name and address of every other person who has any record lien on the property: Name Address NONE 6.- Name and address of every other person who has any record interest in the property and whose interest may be affected by the sale: Name Address REAL ESTATE TAX DEPT. 1 COURTHOUSE SQ., CARLISLE, PA 17013 Domestic Relations Section LOWER ALLEN TOWNSHIP AUTHORITY COMMONWEALTH OF PA. DEPT. OF REVENUE 13 N. HANOVER ST., CARLISLE, PA 17013 120 LIMEKILN RD., NEW CUMBERLAND, PA 17070 BUREAU OF COMPLIANCE, DEPT. 280946, HARRISBURG, PA 17128-0946 7. Name and address of every other person of whom the plaintiff has knowledge who has any interest in the property which may be affected by the sale: Name Address Tenants/Occupants 632 - 634 Hummel Avenue, Lemoyne, PA 17043 I verify that the statements made in this affidavit are true and correct to the best of my personal knowledge or information and belief. I understand that false statements herein are made subject to the penalties of 18 Pa.C.S. sec. 4904 relating to unsworn falsification to authorities. MARK J. UDREN ASSOCIATES DATED: JANUARY 27, 2000 Mark J. Udren, ESQ. Attorney for Plaintiff r, , MARK J. UDREN & ASSOCIATES BY: Mark J. Udren, Esquire ATTY I.D. NO. 04302 1040 N. KINGS HIGHWAY, SUITE 500 CHERRY HILL, Na 08034 609-482-6900 GE Capital Mortgage Services, Inc. 4680 Hallmark Parkway San Bernardino, CA 92407 Plaintiff V. ATTORNEY FOR PLAINTIFF COURT OF COMMON PLEAS CIVIL DIVISION Cumberland County NO. 99-4866 civil term 4206 Allen Road Camp Hill, PA-17011 Defendant(s) t DATE: October 29, 1999 TO: ALL PARTIES IN INTEREST AND CLAIMANTS NOTICE OF SHERIFF'S SALE OF-REAL-PROPERTY OWNER(S): ROBERT J HOLSBERGER JR. PROPERTY: 632 - 634 Hummel Avenue Lemoyne, PA 17043 Improvements: RESIDENTIAL DWELLING The above captioned property is scheduled to be sold at the Cumberland County Sheriff's Sale on March-l,---2.0-00, at 10:00 AM, at the COMMISSIONERS HEARING ROOM 2ND FLOOR COURTHOUSE CARLISLE PA. Our records indicate that you may hold a mortgage or judgment on the property which will be extinguished by the sale. You may wish to attend the sale to protect your interests. A Schedule of Distribution will be filed by the Sheriff on a date specified by the Sheriff not later that 30 days after sale. Distribution will be made in accordance with the schedule unless exceptions are filed thereto within 10 days after the filing of the schedule. EXH!P" A K l i l : tt ? s E NN S ? u- a 0 c a .r; ?.,, ... ._,..r JAYS ?:' m ' O C d g I F r ? a 9 r m n I. U % I € i IL ) i t J I A 2 a (. ? LL \ ell LL a N JPp :? - 118 LL X d¢ ?s 3 ( 11. D&1 ?. . 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N_ > o ? ¢ m° = LLo .y.t? N gm 98 ? ?? m m? 3 ?ccp ? popm g?BB gg UQ?? SU ? 9g :QC U iR 5 y ?a ?i m m p m q m& a E 3 ? ¢ -¢95w o LL L A 0 E E? m C T y a 0 4 U? a ?1 / J '? ? m _ U'p l 0 E c iQTo o 8 . ? a ' n N KU / wZ- e IS ,[ N y .1 Z m l 0 d ?d1 ? : a? YO i d PC ) o. ? L . m? v m $ ? v LL z ?? ? g em W N9 m Yd ?N 20 p ?' 9 Eah mQ? m C a co v :n 1 n w rn o a ' 1°-:7 = O J jieW ajgejunoood joj m 2 LL O LL a GE Capital Mortgage Services Inc. -vs- Robert J. Holsberger, Jr. In the Court of Common Pleas of Cumberland County, Pennsylvania No 1999-4866 Civil R. Thomas Kline, Sheriff, who being duly sworn according to law says this writ, is returned Stayed. Sheriff's Costs: Docketing Poundage Posting Bills Advertising Mileage Certified Mail Levy Surcharge County Law Library Postpone Sale Law Journal Patriot News Share of Bills 30.00 11.97 15.00 15.00 17.98 .69 15.00 16.00 1.00 .50 40.00 223.55 198.68 25.08 $ 610.45 Pd By Atty 5/31/00 Swom and Subscribed To Before Me This_ Day ofOd"'a. - 2000, A.D. Pr th notary R. Thomas Kline, Sheriff By Real Estate Deputy ? S° ?y? ,? 8 L 7 C MARK J. UDREN S, ASSOCIATES BY: Mark J. Udren, Esquire ATTY I.D. NO. 04302 1040 N. KINGS HIGHWAY, SUITE 500 CHERRY HILL, NJ 08034 609-482-6900 ATTORNEY FOR PLAINTIFF GE Capital Mortgage Services, Inc.COURT OF COMMON PLEAS 4680 Hallmark Parkway :CIVIL DIVISION San Bernardino, CA 92407 :Cumberland County Plaintiff MORTGAGE FORECLOSURE V. Robert J. Holsberger, Jr. 4206 Allen Road .NO. 99-4866 civil term Camp Hill, PA 17011 Defendant(s) AFFIDAVIT PURSUJ)N;' TO RULE 3129.1 GE Capital Mortgage Services, Inc.:, 'Plaintiff in the above action, by its attorney, Mark J. Udren, ESQ., sets forth as of the date the Praecipe for the Writ of Execution was filed tAe following information: concerning the real property locaf.ed at: 632 - 634 Hummel-Avenue, Lemoyne, PA 17043 1. Name and address of Owner (s) or reputed owner (s) Name Address ROBERT J. HOLSBERGER, JR. 4206 ALLEN RD., CAMP HILL, PA 17011 2. Name and address of Defendant(s) in the judgment:: Name Address SAME AS #1 ABOVE 3. Name and address of every judgment -creditor whose judgment is a record lien on the real property to be sold: Name Address NONE 4. Name and address of the last recorded holder of every mortgage of record: Name Address Plaintiff herein. See Caption above. 5. Name and address of every other person who has any record lien on the property: Name Address NONE 6. Name and address of every other person who has any record interest in the property and whose interest may be affected by the sale: Name Address REAL ESTATE TAX DEPT. 1 COURTHOUSE SQ., CARLISLE, PA 17013 Domestic Relations Section 13 N. HANOVER ST., CARLISLE, PA 17013 7. Name and address of every other person of whom the plaintiff has knowledge who has any interest in the property which may be affected by the sale: Name Address Tenants/Occupants 632 - 634 Hummel Avenue, Lemoyne, PA 17043 I verify that the statements made in this affidavit are true and correct to the best of my personal knowledge or information and belief. I understand that false statements herein are made subject to the penalties of 18 Pa.C.S. sec. 4904 relating to unsworn falsification to authorities. ;MARK J. UDREN & ASSOCIATES DATED: September 28, 1999 A-, M rk J. Udren, ESQ. Attorney for Plaintiff s MARK J. UDREN & ASSOCIATES ATTORNEY FOR PLAINTIFF BY: Mark J. Udren, Esquire ATTY I.D. NO. 04302 1040 N. KINGS HIGHWAY, SUITE 500 CHERRY HILL, NJ 08034 609-482-6900 GE Capital Mortgage Services, Inc :COURT OF COMMON PLEAS 4680 Hallmark Parkway :CIVIL DIVISION San Bernardino, CA 92407 :Cumberland County Plaintiff MORTGAGE FORECLOSURE V. :NO. 99-4866 civil term Robert J. Holsberger, Jr. 4206 Allen Road Camp Hill, PA 17011 Defendant(s) DATE: September 28, 1999 TO: ALL PARTIES IN INTEREST AND CLAIMANTS NOTICE OF?SHERIFF'S SALE OF_.RE4L. PROPERTY OWNER(S): ROBER)F J. HOLSBERGER, JR. PROPERTY: 632 - 634 Hummel Avenue Lemoyne, PA 17043 Improvements: RESIDENTIAL DWELLING The above captioned property is scheduled to be sold at the Cumberland County Sheriff's Sale on March_1,_20.00, at 10:00 AM, at the COMMISSIONERS HEARING ROOM, 2ND FLOOR, COURTI(OUSE, CARLISLE, PA. Our records indicate that you may hold a mdrtgage or judgment on the property which will be extinguished by the sale. You may wish to attend the sale to protect your interests. A Schedule of Distribution will be filed by the Sheriff, on a date specified by the Sheriff not later that 30 days after sale. Distribution will be made in accordance with the schedule unless exceptions are filed thereto within 10 days after the filing of the schedule. ALL THAT CERTAIN LOT OR TRACT OF LAND LOCATED IN THE BOROUGH OF LEMOYNE, CUMBERLAND COUNTY, PENNSYLVANIA, BOUNDED AND DESCRIBED AS FOLLOWS: BEGINNING AT A POINT SEVENTY FIVE (75) FEET FROM THE SOUTHEAST CORNER OF SEVENTY STREET (FORMERLY LORNE STREET) AND HUMMEL AVENUE, AND EXTENDING ALONG THE SOUTHERN LINE OF A HUMMEL AVENUE IN AN EASTERLY DIRECTION THIRTY FIVE (35) FEET TO LOT NO. 19 AND EXTENDING BACK AN EVEN WIDTH ONE 'HUNDRED AND FIFTY (150) FEET TO PEACH ALLEY, BEING IMPROVED BY.A TWO AND ONE HALF STORY FRAME APARTMENT BUILDING AND BLOCK GARAGE KNOWN AND NUMBERED AS 632 AND 634 HUMMEL AVENUE. BEING KNOWN AS 632-634 HUMMEL AVENUE PROPERTY TAX PARCEL NO. 12-22i-0824-167 TITLE TO SAID PREMISES IS VESTED IN ROBERT J. HOLSBERGER, JR. BY DEED FROM RAY E. JACOBS AND HIS WIFE, DONNA M. JACOBS, FORMERLY KNOWN AS DONNA M. HOLLENBACH, .DATED 7/15/1997 AND RECORDED 7/17/1997 IN DEED BOOK 161 PAGE 160 o, WRIT OF EXECUTION and/or ATTACHMENT COMMONWEALTH OF PENNSYLVANIA) NO. 99-4866 CIVIL Term COUNTY OF CUMBERLAND) CIVIL ACTION - LAW TO THE SHERIFF OF Cumberland COUNTY: To satisfy the debt, interest and costs due GE Capital Mortgage ervices Inc from Robert J. Holsberger, Jr., a 06 Allen Road amn Hi ii PA 17071 DEFENDANT(S) (1) You are directed to levy upon the property of the defendant(s) and to sell-see legal description (2) You are also directed to attach the property of the defendant(s) not levied upon in the possession of GARNISHEE(S) as follows: and to notify the garnishee(s) that: (a) an attachment has been issued; (b) the garnishee(s) is/are enjoined from paying any debt to or for the account of the defendant(s) and from delivering any property of the defendant(s) or otherwise disposing thereof; (3) 11property of thedefendant(s) not levied upon an subject to attachment isfound in the possession of anyoneother than a named garnishee, you are directed to notify hinvhe r that he/she has been added as a garnishee and is enjoined as above stated. Amount Due $71,247.70 L.L._$.50 Interestfrom 9/29/99 to date of Sale DueProlhy 51.00 Atty'sComm/1/00 (per diym $15.13) $2,330.02 Ally Paid $106.68 Plaintiff Paid Date: October 21, 1999 REQUESTING PARTY: Name Mark J. Udren, Esq. Address: 1040 Hallmark Parkway Curtis R. Long Prothonotary, Civil Division by:0.l?lf?assna,r, Deputy Suite 500, Cherry Hill, NJ 08034 Attorney for: Plaintif Telephone: 609-482-6900 Supreme Court ID No. 04302 _ Cut m• ?- aG 9 4 9 the sheriff Ivied upon tf;e c!cf?--:: Interest In the real property situatef? in Cumberland County, Pa., knov;n end rumbered as: /A-&& ' = and more fully desc;rii,Od on Exhibit f•slod w" this writ and by this rei.;rcnce incorporated f {.;rein. PIP.: e/4?C. 992 ray VIfty'Al/,S) '•.N3d 664 Wd K h IZ 130 ?n di?L+3HS ihl :lU 37[!30 PROOF OF PUBLICATION OF NOTICE IN CUMBERLAND LAW JOURNAL (Under Act No. 587, approved May 16, 1929), P. L.1784 STATE OF PENNSYLVANIA : COUNTY OF CUMBERLAND : ss. Roger M. Morgenthal, Esquire, Editor of the Cumberland Law Journal, of the County and State aforesaid, being duly swom, according to law, deposes and says that the Cumberland Law Journal, a legal periodical published in the Borough of Carlisle in the County and State aforesaid, was established January 2, 1952, and designated by the local courts as the official legal periodical for the publication of all legal notices, and has, since January 2, 1952, been regularly issued weekly in the said County, and that the printed notice or publication attached hereto is exactly the same as was printed in the regular editions and issues of the said Cumberland Law Journal on the following dates, viz: JANUARY 21, 28, FEBRUARY 4, 2000 Afffant further deposes that he is authorized to verify this statement by the Cumberland Law Journal, a legal periodical of general circulation, and that he is not interested in the subject matter of the aforesaid notice or advertisement, and that all allegations in the foregoing statements as to time, place and character of publication are true. REAL ESTATE BALE NO. 8 Writ No. 99-4866 Civil /?- GE Capital Mortgage Services Inc. Rog M. Morgenthal, Editor VS. Robert J. Holsberger,Jr. SWORN TO AND SUBSCRIBED before me this Atty.: Mark J. Udren _Aday of FEBRUARY- 2000 ALL THAT CERTAIN lot or tract of land located In the Borough of Le- moyne, Cumberland County. Penn- sylvanfa. bounded and described as ?C 4 J ?? 2 w follows: TJntar.i BEGINNING at a point seventy NOTARIAL SEAL five (75) feet from the southeast cor- LNotory Pubtk ner of Seventy Street (formerly Lorne e Boro. Cvmbo,l,,d County, PA SVeet) and Hummel Avenue, and ex- m-O Eapro, Mmrch 5 2001 tending along the southern line of a , Hummel Avenue in an easterlydimc- unn IhRfv Ave (.,j, .,I fret to Lot No. 19 PROOF OF PUBLICATION OF NOTICE IN CUMBERLAND LAW JOURNAL (Under Act No. 587, approved May 16, 1929), P. L.1784 STATE OF PENNSYLVANIA : SS. COUNTY OF CUMBERLAND : Roger M. Morgenthal, Esquire, Editor of the Cumberland Law Journal, of the County and State aforesaid, being duly swom, according to law, deposes and says that the Cumberland Law Journal, a legal periodical published in the Borough of Carlisle in the County and State aforesaid, was established January 2, 1952, and designated by the local courts as the official legal periodical for the publication of all legal notices, and has, since January 2, 1952, been regularly issued weekly in the said County, and that the printed notice or publication attached hereto is exactly the same as was printed in the regular editions and issues of the said Cumberland Law Journal on the following dates, viz: JANUARY 21, 28, FEBRUARY 4, 2000 Afffant further deposes that he is authorized to verify this statement by the Cumberland Law Journal, a legal periodical of general circulation, and that he is not interested in the subject matter of the aforesaid notice or advertisement, and that all allegations in the foregoing statements as to time, place and character of publication are true. REAL ESTATE BALE NO. B Writ No. 89-4866 Civil GE Capital mortgage services Inc. Rog. M. Morgenthal, Editor VS. Robert J. Holsberger, Jr. Atty.: Mark J. Udren ALL THAT CERTAIN lot or tract of land located in the Borough of Le. moyne, Cumberland County, Penn- sylvania, bounded and described as follows: BEGINNING at a point seventy five (75) feet from the southeast cor- ner of Seventy Street (formerly Lome Street) and Hummel Avenue, and ex- tending along the southern line of a Hummel Avenue to an easterly dtrec- tlon thirty five (35) feet to Lot No. 19 and extending back an even width one hundred and fifty (150) feet to Peach Alley, being Improved by a two and one half story frame apartment building and block garage known and numbered as 632 and 634 Hum- mel Avenue. BEING KNOWN AS 632-634 HUMMELAVENUE. PROPERTY TAX PARCEL NO. 12- 22-0824.167, TITLE TO SAID PREMISES IS VESTED IN Robert J. Holsbergec Jr. by deed from Ray E. Jacobs and his wife. DOnnaM.Jacobs, fomwdyknown as Donna M. Hollenbach, dated 7/15/1997 and recorded 7/ 17/ 1997 In Deed Book 161 Page 160. SWORN TO AND SUBSCRIBED before me this 4 day of FEBRUARY. 2000 NOTARIAL SEAL LOIS E. SNYDER. Notary Pubtk COrlklo aoro, Cumbudond County, PA My COlnm.uiOn Expirt. March 5, 2001 TIE PATRIOT NEWS THE SUNDAY PATRIOT NEWS Proof of Publication _UnderRbt No. 587, Roomued Mau 1&1929 Commonwealth of Pennsylvania, County of Dauphin) so Frank J. Epfer being duly sworn according to law, deposes and says: That he Is the Controller of THE PATRIOT-NEWS CO., a corporation organized and existing under the laws of the Commonwealth of Pennsylvania, with its principal office and place of business at 812 to 818 Market Street, In the City of Harrisburg, County of Dauphin, State of Pennsylvania, owner and publisher of THE PATRIOT-NEWS and THE SUNDAY PATRIOT-NEWS newspapers of general circulation, printed and published at 812 to 818 Market Street, in the City, County and State aforesaid; that THE PATRIOT-NEWS and THE SUNDAY PATRIOT-NEWS were established March 4th, 1854, and September 181h, 1949, respectively, and all have been continuously published ever since; That the printed notice or publication which is securely attached hereto is exactly as printed and published In their regular daily and/or Sunday and Metro editionsiissues which appeared on the 25th day of January and the tat and 8th day(s) of February 2000. That neither he nor said Company Is Interested in the subject matter of said printed notice or advertising, and that all of the allegations of this statement as to the time, place and character of publication are true; and That he has personal knowledge of the facts aforesaid and is duly authorized and empowered to verify this statement on behalf of The Patriot-News Co. aforesaid by virtue and pursuant to a resolution unanimously passed and adopted severally by the stockholders and board of directors of the said Company and subsequently duly recorded in the office for the Recording of Deeds in and for said County of Dauphin in Miscellaneous Book "M", Volume 14, Page 317. PUBLICATION COPY SALE08 this A.D. Notarial Seal 1,(19r,9( Terry L. Russell, Notary Public NOT RY PUBLIC Hamsburg, Dauphin County My Commission Expires June 6, 2002 Member, Pennsylvania Association ol Nscommission expires June 6, 2002 CUMBERLAND COUNTY SHERIFFS OFFICE COURTHOUSE CARLISLE, PA. 17013 Statement of Advertising Costs To THE PATRIOT-NEWS CO., Dr. For publishing the notice or publication attached hereto on the above stated dates $ 197.18 Probating same Notary Fee(s) $ 1.50 Total $ 198.68 sher•a Receipt for Advertising Cost er of THE PATRIOT-NEWS and THE SUNDAY PATRIOT-NEWS, newspapers of general iceipt of the aforesaid notice and publication costs and certifies that the same have THE PATRIOT-NEWS CO. By.. MARK J. UDREN & ASSOCIATES BY: Mark J. Udren, Esquire ATTY I.D. NO. 04302 1040 N. KINGS HIGHWAY, SUITE 500 CHERRY HILL, NJ 08034 856-482-6900 GE Capital Mortgage Services,Inc. 4680 Hallmark Parkway San Bernardino, CA 92407 Plaintiff V. Robert J. Holsberger, Jr 4206 Allen Road Camp Hill, PA 17011 Defendant(s) ATTORNEY FOR PLAINTIFF COURT OF COMMON PLEAS CIVIL DIVISION Cumberland County MORTGAGE FORECLOSURE NO. 99-4866 civil term PRAECIPE TO =ISSUE WRIT OF EXECUTION TO THE SHERIFF: Reissue Writ of Execution in the above matter: Amount due $71,2.4220 Interest From September-29.,_1-999 _13,.4.6.5_.1.0 to Date of Sale March-6_,_20-02 Per diem 0-$15.13 (Costs to be added) $ UZMhrk),T K J. UDREN & ASSOCIATES . en , ESQUIRE ATTORNEY FOR-PLAINTIFF •rv l:"Y1 sari, na t, }Z !:a;e (? x ;ya "pa ?,.yn. :? 4 1 I ? 1 1 I b ?. MARK J. UDREN & ASSOCIATES BY: Mark J. Udren, Esquire ATTY I.D. NO. 04302 1040 N. KINGS HIGHWAY, SUITE 500 CHERRY HILL, Na 08034 856-482-6900 GE Capital Mortgage Services, Inc 4680 Hallmark Parkway San Bernardino, CA 92407 Plaintiff V. Robert J. Holsberger, Jr 4206 Allen Road Camp Hill, PA 17011 Defendant(s) ATTORNEY FOR PLAINTIFF :COURT OF COMMON PLEAS :CIVIL DIVISION :Cumberland County =MORTGAGE FORECLOSURE 'NO. 99-4866 civil term C E R T I F I C A T E Mark J. Udren, Esquire, hereby states that he is the attorney for the Plaintiff in the above-captioned matter and that the premises are not subject to the provisions of Act 91 because it is: ( ) An FHA insured mortgage ( ) Non-owner occupied ( ) Vacant ( X ) Act 91 procedures have been fulfilled. ( ) Over 24 months delinquent. This certification is made subject to the penalties of 18 Pa. C.S. Sec. 4904 relating to unsworn falsification to authorities. & ASSOCIATES Mark J. Udr-Lsn, ESQUIRE ATTORNEY FOR PLAINTIFF ?" G1 I_ CIO l MARK J. U'DREN & ASSOCIATES BY: Mark J. Udren, Esquire ATTY I.D. NO. 04302 1040 N. KINGS HIGHWAY, SUITE 500 CHERRY HILL, NJ 08034 856-482-6900 ATTORNEY FOR PLAINTIFF GE Capital Mortgage Services,Inc. :COURT OF COMMON PLEAS 4680 Hallmark Parkway :CIVIL DIVISION San Bernardino, CA 92407 :Cumberland County Plaintiff MORTGAGE FORECLOSURE V. Robert J. Holsberger, Jr. 'NO. 99-4866 civil term 4206 Allen Road Camp Hill, PA 17011 Defendant(s) AFFIDAVIT PURSUANT TO RULE 3129.1 GE Capital Mortgage Services, Inc., Plaintiff in the above action, by its attorney, Mark J. Udren, ESQ., sets forth as of the date the Praecipe for the Writ of Execution was filed the following information concerning the real property located at: 632 - 634 Hummel Avenue, Lemoyne, PA 17043 1. Name and address of Owner(s) or reputed Owner(s): Name Address Robert J. Holsberger, Jr. 4206 Allen Road, Camp Hill, PA 17011 2. Name and address of Defendant(s) in the judgment: Name Address SAME AS #1 ABOVE 3. Name and address of every judgment creditor whose judgment is a record lien on the real property to be sold: Name Address Nationsbanc Mortgage Corp. 101 E. Main St., Suite 400 PO BOX 35140, Louisville, KY 40232-5140 4. Name and address of the last recorded holder of every mortgage of record: Name Address Plaintiff herein. See Caption above. S. Name and address of every other person who has any record lien on the property: Name Address NONE 6. Name and address of every other person who has any record interest in the property and whose interest may be affected by the sale: Name Address Lower Allen Twnp. Authority Real Estate Tax Dept Domestic Relations Section Commonwealth of PA, Department of Revenue 120 Limekiln Road, New Cumberland, PA 17070 1 Courthouse Sq., Carlisle, PA 17013 13 N. Hanover St., Carlisle, PA 17013 Bureau of Compliance, Dept. 280946 Harrisburg, PA 17128-0946 7. Name and address of every other person of whom the plaintiff has knowledge who has any interest in the property which may be affected by the sale: Name Address Tenants /Occupants 632 - 634 Hummel Avenue, Lemoyne, PA 17043 I verify that the statements made in this affidavit are true and correct to the best of my personal knowledge or information and belief. I understand that false statements herein are made subject to the penalties of 18 Pa.C.S. sec. 4904 relating to unsworn falsification to authorities. MARK \J., REN & ASSOCIATES DATED: October 24, 2001 - a k J. Udre ESQ. Attorney for Plaintiff 4? ?Y :: F s , . ,??T i?• -_ % r l , CJ j 1 ?' 1 \\ ? 11?J L. :.1 ft L: _- ?? 1 J (? ^? ? 'kARK J. UDREN & ASSOCIATES BY: Mark J. Udren, Esquire ATTY I.D. NO. 04302 1040 N. RINGS HIGHWAY, SUITE 500 CHERRY HILL, NJ 08034 856-482-6900 GE Capital Mortgage Services, Inc. 4680 Hallmark Parkway San Bernardino, CA 92407 Plaintiff V. Robert J. Holsberger, Jr 4206 Allen Road Camp Hill, PA 17011 Defendant(s) ATTORNEY FOR PLAINTIFF :COURT OF COMMON PLEAS :CIVIL DIVISION :Cumberland County MORTGAGE FORECLOSURE NO. 99-4866 civil term NOTICF--OF-SHERIFF- _SALE-OF REAL PROPERTY TO: Robert J. Holsberger, Jr. 4206 Allen Road Camp Hill, PA 17011 Your house (real estate) at 632 - 634 Hummel Avenue, Lemoyne, PA 17043 is scheduled to be sold at the Sheriff's Sale on March 6, 2002, at 10:00 AM in the Cumberland County Courthouse, 1 Courthouse Square, Carlisle, PA , to enforce the court judgment of $71,247.70, obtained by Plaintiff above (the mortgagee) against you. If the sale is postponed, the property will be relisted for the Next Available Sale. NOTICE-OF-OWNER'S RIGHTS YOU MAY BE ABLESO--P1tE_V NT THIS SHERIFF! SSALE To prevent this Sheriff's Sale, you must take immediate-action : 1. The sale will be cancelled if you pay to the mortgagee the back payment, late charges, costs and reasonable attorney's fees. To find out how much you must pay, you may call: 1855) 482-6940_ 2. You may be able to stop the sale by filing a petition asking the Court to strike or open the judgment, if the judgment was improperly entered. You may also ask the Court to postpone the sale for good cause. 3. You may also be able to stop the sale through other legal proceedings. You may need an attorney to assert your rights. The sooner you contact one, the more chance you will have of stopping the sale. (see notice on page two on how to obtain an attorney.) YOU MAY STILL BE ABLE-- TO-- SAVE-Y-O.UR-PROPERT-Y-AND-Y-O-U-HAVE-=HER-RIGMS EVEN IF THE SHERIFF'S -SALE- DOES-TAKE-PLACE-.. 1. If the Sheriff's Sale is not stopped, your property will be sold to the highest bidder, You may find out the price bid by calling 856-482-6900. 2. You may be able to petition the Court to set aside the sale if the bid price was grossly inadequate compared to the value of your property. 3. The sale will go through only if the buyer pays the Sheriff the full amount due in the sale. To find out if this has happened, you may call 856-482-6900. 4. If the amount due from the Buyer is not paid to the Sheriff, you will remain the owner of the property as if the sale never happened. 5. You have the right to remain in the property until the full amount due is paid to the Sheriff and the Sheriff gives a deed to the buyer. At that time, the buyer may bring legal proceedings to evict you. 6. You may be entitled to a share of the money which was paid for your house. A schedule of distribution of the money bid for your house will be filed by the Sheriff within 30 days after the sale. This schedule will state who will be receiving that money. The money will be paid out in accordance with this schedule unless exceptions (reasons why the proposed distribution is wrong) are filed with the Sheriff within ten (10) days after Schedule of Distribution is filed. 7. You may also have other rights and defenses, or ways of getting your home back, if you act immediately after the sale. YOU SHOULD TAKE THIS PAPER TO YOUR LAWYER AT ONCE. IF YOU DO NOT HAVE A LAWYER OR CANNOT AFFORD ONE, 00 TO OR TELEPHONE THE OFFICE LISTED BELOW TO FIND OUT WHERE YOU CAN GET LEGAL HELP. LAWYER REFERRAL SERVICE Cumberland County Bar Association 2 Liberty Ave. Carlisle, PA 17013-3387 717-249-3166 or 800-990-9108 ASSOCIATION DE LICENCIDADOS DE FILADELFIA Cumberland County Bar Association 2 Liberty Ave. Carlisle, PA 17013-3387 717-249-3166 or 800-990-9108 7 J _ ?1 n P.; ?I C `, U = 1(L - ALL THAT CERTAIN LOT OR TRACT OF LAND LOCATED IN THE BOROUGH OF LEMOYNE, CUMBERLAND COUNTY, PENNSYLVANIA, BOUNDED AND DESCRIBED AS FOLLOWS : - - - ----- - - ---- -- BEGINNING AT A POINT SEVENTY FIVE (75) FEET FROM THE SOUTHEAST CORNER OF SEVENTY STREET (FORMERLY LORNE STREET) AND HUMMEEL AVENUE, AND EXTENDING ALONG THE SOUTHERN LINE OF A HUMMEL AVENUE IN AN EASTERLY DIRECTION THIRTY FIVE (35) FEET TO LOT NO. 19 AND ..-.EXT.END.ING-BACK_AN- .EVEN- WIDTH.-ONE-i HUNDRED-AND_F IFTY_.(15 0 )._-FEET... O PEACH ALLEY, BEING IMPROVED BY:A TWO AND ONE HALF STORY FRAME APARTMENT BUILDING AND BLOCK GARAGE KNOWN AND NUMBERED AS 632 AND 634 HUMMEL AVENUE. 1 , BEING KNOWN AS 632-634 HUMMEL AVENUE PROPERTY TAX PARCEL NO. 12-22r0824-167 . TITLE TO SAID PREMISES IS VESTED IN ROBERT J. HOLSBERGER, JR. BY DEED FROM RAY E. JACOBS AND HIS WIFE, DONNA M. JACOBS, FORMERLY KNOWN AS DONNA M. HOLLENBACH, :DATED 7/15/1997 AND RECORDED 7/17/1997 IN DEED BOOK 161 PAGE 160 1JOCKet for Vase: " + uctuaseNo() + " (^ + Lk:t . . Bankruptcy Docket Report 100-00831 (Harrisburg) HOLSBERGER, ROBERT J, JR Docket items entered between 01/01/1931 and 07/16/2001 Ffling Date No Docket Entry 02/29/00 1 VOLUNTARY PETITION under chapter 13 [EOD 02/29100] [BMM] 02/29/00 2 NOTICE of intent to dismiss case unless missing documents are filed: due by 03115100 Re: Item # 1. [Complied] [EOD 02/29/00] [BMM] 03/10/00 3 Schedules, Statements, Plan & Summary and all missing documents Re: Item # 2. (EOD 03/13/00] [KZ] 03/27/00 4 CERTIFICATE of Mailing of Notice of 341 Meeting. Objections to the plan are due 15 days after meeting held. [EOD 03/27/00] [CA] 05115100 5 341 meeting held. [EOD 05115100] [CA] 05/31/00 6 ORDER Confirming Plan [EOD 05/31/00] PC] 08/21/00 7 MOTION for relief from stay G.E. CAPITAL MORTGAGE SERVICES FEE PD. $75.00 #561310-CG [Disposed] [EOD 08/21/00] [JC] REQUEST for admission [EOD 08/21/00] PC] CERTIFICATE OF NON-CONCURRENCE [EOD 08/21/00] [JC] 08/21/00 8 ORDER that answers aredue on 09/11/00 Re: Item # 7. [EOD 08/21/00] [JC] 08/28/00 9 CERTIFICATE of service Re: Item # 8. [EOD 08/28/00] PC] 09/05/00 10 ANSWER by DEBTOR Re: Item # 7. [EOD 09/06/00] [JC] 09/11/00 11 CORRESPONDENCE SETTING HEARING on 11/01/00 at 09:00 A.M. at FED.BLDG. , BKRPTCY CTRM.(3RD FLR.), THIRD & WALNUT STS., HARRISBURG,PA. 17108 Re: Item # 10. [EOD 09/13/001 [JG] 10/06/00 12 REAFFIRMATION AGREEMENT between Debtor and PENNSYLVANIA STATE EMPLOYEES CREDIT UNION [EOD 10/06/001 [JC] 11/01/00 13 PROCEEDING MEMO re hearing not held. Rescheduled by counsel to November 16, 2000 at 2:00 p.m. Attorney Winneg to renotice. Re: Item # 10. [EOD 11/01/00] PG] 11/06/00 14 CORRESPONDENCE SETTING HEARING FOR NOVEMBER 16, 2000 AT 2:00 P.M., FILED BY MOVANT Re: Item # 7. [EOD 11/06/00] PC] 11/16/00 15 PROCEEDING MEMO: phone conference not held. Stipulation to be filed. Re: Item # 7. [EOD 11/16/001 [JG] 01/16/01 16 STIPULATION by PARTIES (REQUESTED ORIGINAL SIGNATURE OF COUNSEL FOR THE DEBTOR) Re: Item # 7. [EOD 01/16/01] PC] ORDER approving stipulation Re: Item # 7. [EOD 03/08/01 ] PC] 04/03/01 17 APPLICATION to employ RAY DAVIS AND JACK GAUGHEN, REALTOR [Disposed] [EOD 04104/011 PC] 04/12/01 18 ORDER Approving Employment Re: Item # 17. [EOD 04/12/011 PC] 04/16/01 19 MOTION for relief from stay NATIONSBANC MORTGAGE CORPORATION FEE PD. $75.00 #568646-BR [EOD 04/16/011 [JC] CERTIFICATE OF NON-CONCURRENCE [EOD 04/16/011 PC] .../nPacer7ExecThis=docket&puid=00995298847&case_no=2000-00831 &office= I &DktTypt07/ 17/2001 V + Ukt I ypeE,xpan(I(m.g!0ktI ype) + -) Page 2 of 2 04/16/01 20 ORDER that answers aredue on 05/07/01 Re: Item # 19. [EOD 04/16/01] [JC] 04/23/01 21 CERTIFICATE of service Re: Item # 20. [EOD 04/23/011 [KZ] 04/23/01 22 ANSWER by Debtor/Respondent Re: Item # 19. (EOD 04/23/011 [SM] 05/09/01 23 CORRESPONDENCE from Movant requesting matter be listed for telephone conference. Re: Item # 19. [EOD 05110/011 [JG] 05111101 24 CORRESPONDENCE SETTING PHONE CONFERENCE on 06/27/01 at 04:00 P.M. at FED.BLDG., BKRPTCY CTRM.(3RD FLR.), THIRD & WALNUT STS., HARRISBURG,PA. 17108 Re: Item# 19. [EOD05/11/01] [JC] 06/14/01 25 CERTIFICATE OF DEFAULT Re: Item # 16. [EOD 06/14/01] [JC] 06/26/01 26 ORDER granting relief from stay Re: Item # 7. [EOD 061261011 [JC] 06/27/01 27 PROCEEDING MEMO: phone conference not held -stipulation to be filed. Re: Item # 19. [EOD 06/27/011 [CL] CER Service enter Transaction Receipt 07/16/2001 11:5 PA og n: mu 1 '1 ent 'ode: escr piton: oc et ase um er: ?? a e Pages: ?? 'ost:?? Need help? Try the PACER User's Guide OPacer Scrvice Center /nPacer?ExecThis=docket&puid=00995298847&case_no=2000-00831 &office=1 &DktTyp 07/17/2001 MARK J. UDREN & ASSOCIATES BY: Mark J. Udren ATTY I.D. NO. 04302 1040 N. KINGS HIGHWAY, SUITE 500 CHERRY HILL, NJ 08034 856-482-6900 GE Capital Mortgage Services, Inc. 4680 Hallmark Parkway San Bernardino, CA 92407 Plaintiff ATTORNEY FOR PLAINTIFF COURT OF COMMON PLEAS CIVIL DIVISION Cumberland County V. Robert J. Holsberger, Jr. 4206 Allen Road Camp Hill, PA 17011 Defendant(s) NO. 99-4866 civil term AFFIDAVIT OF SERVICE PURSUANT TO Pa.R.C.P.RULE 3129.1 Plaintiff, by its/his/her Attorney, Mark J. Udren, Esquire, hereby verifies that: 1. A copy of the Notice of Sheriff's Sale, a true and correct copy of which is attached hereto as Exhibit "A", was sent to every recorded lienholder and every other interested party known as of the date of the filing of the Praecipe for the Writ of Execution, on the date(s) appearing on the attached Certificates of Mailing. 2. A Notice of Sheriff's Sale was sent to Defendant (s) by regular mail and certified mail on the date appearing on the attached Return Receipt, which was signed for by Defendant(s) on the date specified on the said Return Receipt. Copies of the said Notice and Return Receipt are attached hereto as Exhibit "B". 3. If a Return Receipt is not attached hereto, then service was by personal service on the date specified on the attached Return of Service, attached hereto as Exhibit "B". 4. If service was by Order of Court, then proof of compliance with said Order is attached hereto as Exhibit "B". All Notices were served within the time limits set forth by Pa Rule C.P. 3129. ' This Affidavit is made subject to the penalties of 18 Pa.C.S. Section 4904 relating to unsworn falsification to authorities. Dated: February 13, 2002 MARK J. UDREN & ASSOCIATES BY: Mark J. Udren, Esquire Attorney for Plaintiff MARK J. UDREN & ASSOCIATES ATTORNEY FOR PLAINTIFF BY: Mark J. Udren, Esquire ATTY I.D. NO. 04302 1040 N. KINGS HIGHWAY, SUITE 500 CHERRY HILL, NJ 08034 856-482-6900 GE Capital Mortgage Services,Inc. 'COURT OF COMMON PLEAS 4680 Hallmark Parkway :CIVIL DIVISION San Bernardino, CA 92407 :Cumberland County Plaintiff =MORTGAGE FORECLOSURE V. Robert J. Holsberger, Jr. 'NO. 99-4866 civil term 4206 Allen Road Camp Hill, PA 17011 Defendant(s) AMENDED AFFIDAVIT PURSUANT TO RULE 3129.1 GE Capital Mortgage Services, Inc., Plaintiff in the above action, by its attorney, Mark J. Udren, ESQ., sets forth as of the date the Praecipe for the Writ of Execution was filed the following information concerning the real property located at: 632 - 634 Hummel Avenue, Lemoyne, PA 17043 1. Name and address of owner(s) or reputed Owner(s): Name Address Robert J. Holsberger, Jr. 4206 Allen Road, Camp Hill, PA 17011 2. Name and address of Defendant(s) in the judgment: Name Address SAME AS #1 ABOVE 3. Name and address of every judgment creditor whose judgment is a record lien on the real property to be sold: Name Address Nationsbanc Mortgage Corp. 101 E. Main St., Suite 400 PO BOX 35140, Louisville, KY 40232-5140 Jolanta Bonasera 632 Hummel Ave., Lemoyne, PA 17043 Lower Allen Twnp. Authority 120 Limekiln Road, New Cumberland, PA 17070 4. Name and address of the last recorded holder of every mortgage of record: Name Address Plaintiff herein. See Caption above. 5. Name and address of every other person who has any record lien on the property: Name Address Borough of Lemoyne 665 Market St., Lemoyne, PA 17043 6. Name and address of every other person who has any record interest in the property and whose interest may be affected by the sale: Name Address Real Estate Tax Dept Domestic Relations Section Commonwealth of PA, Department of Revenue 1 Courthouse Sq., Carlisle, PA 17013 13 N. Hanover St., Carlisle, PA 17013 Bureau of Compliance, Dept. 280946 Harrisburg, PA 17128-0946 7. Name and address of every other person of whom the plaintiff has knowledge who has any interest in the property which may be affected by the sale: Name Address Tenants/Occupants 632 - 634 Hummel Avenue, Lemoyne, PA 17043 I verify that the statements made in this affidavit are true and correct to the best of my personal knowledge or information and belief. I understand that false statements herein are made subject to the penalties of 18 Pa.C.S. sec. 4904 relating to unsworn falsification to authorities. DATED: February 18, 2002 MARK J. UDREN & ASSOCIATES Mark J. Udren, ESQ. Attorney for Plaintiff MARK J. UDREN & ASSOCIATES BY: Mark J. Udren, Esquire ATTY I.D. NO. 04302 1040 N. KINGS HIGHWAY, SUITE 500 CHERRY HILL, NJ 08034 856-482-6900 GE Capital Mortgage Services, Inc. 4680 Hallmark Parkway San Bernardino, CA 92407 Plaintiff V. Robert J. Holsberger, Jr. 4206 Allen Road Camp Hill, PA 17011 Defendant(s) DATE: November 1, 2001 ATTORNEY FOR PLAINTIFF COURT OF COMMON PLEAS CIVIL DIVISION Cumberland County NO. 99-4866 civil term TO: ALL PARTIES IN INTEREST AND CLAIMANTS NOTICE OF SHERIFF'S SALE Oy--REAL-RQRzRTY OWNER(S): ROBERT J. HOLSBERGER, JR PROPERTY: 632 - 634 Hummel Avenue, Lemoyne, PA 17043 Improvements: RESIDENTIAL DWELLING The above captioned property is scheduled to be sold at the CumbAzL=d County Sheriff's Sale on Marsh 6 2002, at 10:00 AM, at the CUMBERLAND COUNTY COURTHOUSE, 1 COURTHOUSE SQUARE, CARLISLE, PA. Our records indicate that you may hold a mortgage or judgment on the property which will be extinguished by the sale. You may wish to attend the sale to protect your interests. A Schedule of Distribution will be filed by the Sheriff on a date specified by the Sheriff not later that 30 days after sale. Distribution will be made in accordance with the schedule unless exceptions are filed thereto within 10 days after the filing of the schedule. 7 IT ?'? r m?? p $ Cy O $ ryLL y F E B E ? O d $ fi ? F ppQ y 9 bLL fp ? V ?+`E$ V E U i pB ? 4? KI rR 6 S F ¦ EEEE ? R F x > 7 ? ? fi $ n? n= m.0 1 > yy i K g p 2, a ??? ac . nE g pfi ? E m vx ? ? g g W m 4 OS y 1'S f >V W b p O I Q° ? W ? . w Q ? z NN 0 o co Z a^ 6 w Mr Z ` a° n N m = oa .? w 9 J z W m a w ?F n = n w=rc o w ¢? to g m 7 z O =j aN = yy r 3:0 LL> o:, ° f?Qt?i V V^ OC N =no n WO a NNim = F- w co LL= O j. - s 4Q Uatl f 9? 0ww $ a oo za Ow ? ?n z?Z ¢$ a i rn 00 ?4 'am-O °MO a ?: DO 0 g sm -6 00 ? . WD OR . ¢O Oa Wm cj ¢a E ;j It NJ 1 - LL7 NrZ Q? b0 Zd it Ir 0, W 1 W y 1- W Z r O W $ f.-U WQQ OI- O W W W O W KU ON Ua' HJ JZ zo m V _d w w w b p U w 2 O a o c? mNa w Ox S'i Q UQ Er m ? c ?a E$N _8 z s m N t h C N ( p n m Oi N M Q b F J T 10 a b LL n L !L co CL W W? i UQ? ?O. i' ifn 41 I'!A": N s E2 i l M °a ° .1 Fo ?0 ' 5 k?y C Q ? E?7 ? p RRA"' m y F @{ tltltltl @ % s g ,^ C ., l1 i! i a ^, ng F 1 m ° ?G9 a? ?5 f1 IL N ? N C K ? a `N FiLi • Han B e ` ? . ' . f ? 19 ? ''. ? ... T ?G =t E o ry va- m a ? •? K ?r it s L) EU N ? ???? o 4 y a 7 ? = g a m a i LO io 'FJ uJ u p d E S Ny [N 7• Q E J Ltl 0 OJ ao 00 W _ `o d '0 f m .5 -6-4 Sm Eo _ U E ?E rn m Z o @N qg c m rn? m? a av `o c 8Nm mNaS? z ° ? U oq =? gy Win' c Eoy Za? 7 r N t?1 Q N m A m m ? N M Q N u F22 3 C a C O CL m m `o 5 `m 3 CL FT a 9 0 CL 0 U m a N f I v mm 2 a LL n I LL m a. STATE OF PENNSYLVANIA, t COUNTY OF CUMBERLAND f ss' Robert P Ziegler I, ------ ----- ------------ ----- ----------------- Recorder of Dads in and for said County and State do`hereby certify that the Sheriff's Deed in which ---------------- Federal Home Loan Mtg Corp ---------- -- -_ ----°--------° ------------------------------------ isthe grants the same having been sold to said grantee on the _ 5 th------ ----------------------------------° day of ----------June -"---------------------- A. D., under and by virtue of a writ______________ -.--Execution 29th -----------------issued on the------------------------------- day of -----ct --------------------- A. D. 01 , ----- , out of the Court of Comman Pleas of said County as of Civil ------------------------------------------------ 1999 --------------------------------- Term,: '----- tal Mtg Serv Inc Nuntber___ 4866 ___________- atehesuit of____ GE _--- CAp --- iRobert J Holsberger Jr -- against ---------------------------------------------------- duly recorded inSherifCsDeed Book No5------------ Page -- ---------. 1811 IN TESTIMONY WHEREOF, I have hereunto set my h d and seal of said office this * K -- day of ___ /1 M _ ? Recorder GE Capital Mortgage Services, Inc. VS Robert J. Holsberger, Jr. In The Court of Common Pleas of Cumberland County, Pennsylvania Writ No. 1999-4866 Civil Term Douglas Donsen, Deputy Sheriff, who being duly swom according to law, states that on November 05, 2001 at 7:35 o'clock P.M., EST, he served a true copy of the within Real Estate Writ, Notice and Description, in the above entitled action, upon one of the within named defendants, to wit: Robert J. Holsberger, Jr., by making known unto Robert J. Holsberger, Jr. personally, at 4206 Allen Road, Camp Hill, Cumberland County, Pennsylvania, its contents and at the same time handing to him personally the said true and correct copy of the same. Timothy Reitz, Deputy Sheriff, who being duly swom according to law, states that on January 04, 2002 at 1:38 o'clock P.M., E.S.T., he posted a true copy of the within Real Estate Writ, Notice, Poster and Description, in the above entitled action, upon the property of Robert J. Holsberger, Jr., located at 632-634 Hummel Ave., Lemoyne, PA 17043, Pennsylvania, according to law. R. Thomas Kline, Sheriff, who being duly swom according to law says he served the above Real Estate Writ, Notice, Poster and Description in the following manner: The Sheriff mailed a notice of the pendency of the action to one of the within named defendants to wit: Robert J. Holsberger, by regular mail to his last known address of 4206 Allen Road, Camp Hill, PA 17011. This letter was mailed under the date of January 18, 2002 and never returned to the Sheriff's Office. R. Thomas Kline, Sheriff, who being duly sworn according to law, says that after due and legal notice had been given according to law, exposed the within described premises at public venue or outcry at the Court House, Carlisle, Cumberland County, Pennsylvania, on June 5'2002 at 10:00 o'clock A.M. He sold the same for the sum of $1.00 to Attorney Mark Udren for Federal Home Loan Mortgage Corporation. It being the highest bid and best price received for the same, Federal Home Loan Mortgage Corporation of8200 Jones Branch Drive, McLean, VA 22102, being the buyer in this execution paid Sheriff R. Thomas Kline, the sum of $685.52, it being costs. Sheriffs Costs: Docketing $30.00 Poundage 13.44 Posting Bills 15.00 Advertising 15.00 Acknowledging Deed 30.00 Auctioneer 10.00 Prothonotary 1.00 Service 19.50 Certified Mail 4.18 Levy 15.00 Surcharge 20.00 Postpone Sale 20.00 Law Journal Patriot News Share of Bills Distribution of Proceeds Sheriffs Deed 209.60 203.10 24.20 25.00 30.50 $685.52 paid by attorney 6/24/02 Sworn and subscribed to before me So Answers: Thisjj t-- dayof(? 4_ r4o? R. Thomas Kline, Sheriff 2002, A.D. r thonotary BY-J, Real Estate Deputy 1. 00 Lro .' i.,@ j9e5? MARK J. UDREN & ASSOCIATES ATTORNEY FOR PLAINTIFF BY: Mark J. Udren, Esquire ATTY I.D. NO. 04302 1040 N. KINGS HIGHWAY, SUITE 500 CHERRY HILL, NJ 08034 856-482-6900 GE Capital Mortgage Services, Inc.' COURT OF COMMON PLEAS 4680 Hallmark Parkway :CIVIL DIVISION San Bernardino, CA 92407 :Cumberland County Plaintiff MORTGAGE FORECLOSURE V. Robert J. Holsberger, Jr. *NO. 99-4866 civil term 4206 Allen Road Camp Hill, PA 17011 Defendant(s) AFFIDAVIT PURSUANT TO RULE 3129.1 GE Capital Mortgage Services, Inc., Plaintiff in the above action, by its attorney, Mark J. Udren, ESQ., sets forth as of the date the Praecipe for the Writ of Execution was filed the following information concerning the real property located at: 632 - 634 Hummel Avenue, Lemoyne, PA 17043 1. Name and address of Owner (s) or reputed Owner(s): Name Address Robert J. Holsberger, Jr. 4206 Allen Road, Camp Hill, PA 17011 2. Name and address of Defendant (s) in the judgment: Name Address SAME AS #1 ABOVE 3. Name and address of every judgment creditor whose judgment is a record lien on the real property to be sold: Name Address Nationsbanc Mortgage Corp. 101 E. Main St., Suite 400 PO BOX 35140, Louisville, KY 40232-5140 4. Name and address of the last recorded holder of every mortgage of record: Name Address Plaintiff herein. See Caption above. S. Name and address of every other person who has any record lien on the property: Name Address NONE 6. Name and address of every other person who has any record interest in the property and whose interest may be affected by the sale: Name Address Lower Allen Twnp. Authority Real Estate Tax Dept. Domestic Relations Section Commonwealth of PA, Department of Revenue 120 Limekiln Road, New Cumberland, PA 17070 1 Courthouse Sq., Carlisle, PA 17013 13 N. Hanover St., Carlisle, PA 17013 Bureau of Compliance, Dept. 280946 Harrisburg, PA 17128-0946 7. Name and address of every other person of whom the plaintiff has knowledge who has any interest in the property which may be affected by the sale: Name Address Tenants/Occupants 632 - 634 Hummel Avenue, Lemoyne, PA 17043 I verify that the statements made in this affidavit are true and correct to the best of my personal knowledge or information and belief. I understand that false statements herein are made subject to the penalties of 18 Pa.C.S. sec. 4904 relating to unsworn falsification to authorities. MARK J. REN & ASSOCIATES DATED: October 24, 2001 L i a k J. Udre ESQ. Attorney for Plaintiff MARK J. UDREN & ASSOCIATES ATTORNEY FOR PLAINTIFF BY: Mark J. Udren, Esquire ATTY I.D. NO. 04302 1040 N. KINGS HIGHWAY, SUITE 500 CHERRY HILL, NJ 08034 856-482-6900 GE Capital Mortgage Services, 'COURT OF COMMON PLEAS Inc. :CIVIL DIVISION 4680 Hallmark Parkway ::Cumberland County San Bernardino, CA 92407 MORTGAGE FORECLOSURE Plaintiff V. Robert J. Holsberger, Jr. NO. 99-4866 civil term 4206 Allen Road Camp Hill, PA 17011 Defendant(s) NOTICE OF SHERIFFS SALE OF REAL PROPERTY TO: Robert J. Holsberger, Jr. 4206 Allen Road Camp Hill, PA 17011 Your house (real estate) at 632 - 634 Hummel Avenue, Lemoyne, PA 17043 is scheduled to be sold at the Sheriff's Sale on March 6, 2002, at 10:00 AM in the Cumberland County Courthouse, 1 Courthouse Square, Carlisle, PA , to enforce the court judgment of $71,247.70, obtained by Plaintiff above (the mortgagee) against you. If the sale is postponed, the property will be relisted for the Next Available Sale. NOTICE OI? OWNER'S RIGHTS YOU MAY qV__hQT.E TO -M VENT THIS SH RTFF'C S 7 To prevent this Sheriff's sale, you must take immediate actiQ= 1. The sale will be cancelled if you pay to the mortgagee the back payment, late charges, costs and reasonable attorney's fees. To find out how much you must pay, you may call: 18561 aez-F9oo, 2. You may be able to stop the sale by filing a petition asking the Court to strike or open the judgment, if the judgment was improperly entered. You may also ask the Court to postpone the sale for good cause. 3. You may also be able to stop the sale through other legal proceedings. You may need an attorney to assert your rights. The sooner you contact one, the more chance you will have of stopping the sale. (See notice on page two on how to obtain an attorney.) YOU MAYSTILL-B E_ABLE_TO_SAVE YOUR PROPERTY 1AND_YD-U BAVE OSHER-RI.GHM EYEN IF THE_SHERIFF! S- -,SALE--DOES-TAKE,-PLACE-.-1. If the Sheriff's sale is not stopped, your property will be sold to the highest bidder. You may find out the price bid by calling 856-482-6900. 2. You may be able to petition the Court to set aside the sale if the bid price was grossly inadequate compared to the value of your property. 3. The sale will go through only if the buyer pays the Sheriff the full amount due in the sale. To find out if this has happened, you may call 856-482-6900. 4. If the amount due from the Buyer is not paid to the Sheriff, you will remain the owner of the property as if the sale never happened. 5. You have the right to remain in the property until the full amount due is paid to the Sheriff and the Sheriff gives a deed to the buyer. At that time, the buyer may bring legal proceedings to evict you. 6. You may be entitled to a share of the money which was paid for your house. A schedule of distribution of the money bid for your house will be filed by the Sheriff within 30 days after the sale. This schedule will state who will be receiving that money. The money will be paid out in accordance with this schedule unless exceptions (reasons why the proposed distribution is wrong) are filed with the Sheriff within ten (10) days after Schedule of Distribution is filed. 7. You may also have other rights and defenses, or ways of getting your home back, if you act immediately after the sale. YOU SHOULD TAKE THIS PAPER TO YOUR LAWYER AT ONCE. IF YOU DO NOT HAVE A LAWYER OR CANNOT AFFORD ONE, GO TO OR TELEPHONE THE OFFICE LISTED BELOW TO FIND OUT WHERE YOU CAN GET LEGAL HELP. LAWYER REFERRAL SERVICE Cumberland County Bar Association 2 Liberty Ave. Carlisle, PA 17013-3387 717-249-3166 or 800-990-9108 ASSOCIATION DE LICENCIDADOS DE FILADELFIA Cumberland County Bar Association 2 Liberty Ave. Carlisle, PA 17013-3387 717-249-3166 or 800-990-9108 ALL THAT CERTAIN LOT OR TRACT OF LAND LOCATED IN THE BOROUGH OF LEMOYNE, CUMBERLAND COUNTY, PENNSYLVANIA, BOUNDED AND DESCRIBED AS FOLLOWS: --- BEGINNING AT A POINT SEVENTY FIVE (75) FEET FROM THE SOUTHEAST CORNER OF SEVENTY STREET (FORMERLY LORNE STREET) AND HUMMEL AVENUE, AND EXTENDING ALONG THE SOUTHERN LINE OF A HUMMEL AVENUE IN AN EASTERLY DIRECTION THIRTY FIVE (35) FEET TO LOT NO. 19 AND - _.EXTEND.ING_BACK_AN_ -EVEN-. WIDTH_ONE_;HUNDRED_AND_FIFT.Y_-CIS 0)_ F EET. TO .._... PEACH ALLEY, BEING IMPROVED BY:A TWO AND ONE HALF STORY FRAME APARTMENT BUILDING AND BLOCK GARAGE KNOWN AND NUMBERED AS 632 AND 634 HUMMEL AVENUE. i BEING KNOWN AS 632-634 HUMMEL AVENUE i PROPERTY TAX PARCEL NO. 12-22x0824-167 . TITLE TO SAID PREMISES IS VESTED IN ROBERT J. HOLSBERGER, JR. BY DEED FROM RAY E. JACOBS AND HIS WIFE, DONNA M. JACOBS, FORMERLY KNOWN AS DONNA M. HOLLENBACH, ;DATED 7/15/1997 AND RECORDED 7/17/1997 IN DEED BOOK 161 PAGE 160 I i • WRIT OF EXECUTION and/or ATTACHMENT COMMONWEALTH OF PENNSYLVANIA) NO. 99-4866 CIVIL 1 TES COUNTY OF CUMBERLAND) CIVIL ACTION -LAW TO THE SHERIFF OF Cumberland -COUNTY: To satisfy the debt, interest and costs due GE Capital Mortgage Services INc PLAINTIFF(S) from Robert J. Holsbe er, Jr., 4206 Allen Road, Camp Hill, PA 17011 (1) You are directed to levy upon the property of the defendant(s) and to sell See Legal Description (2) You are also directed to attach the property of the defendant(s) not levied upon in the possession of GARNISHEE(S) as follows: and to notify the gamishee(s) that: (a) an attachment has been issued; (b) the gamishee(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) 11properiyof the defendant(s) not levied upon an subject to attachment is found in the Possession of anyone other 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 $71,247.70 Interest fran 9/29/99 to date of sale 3/6/02 Atty's Comm Ally Paid _ Plaintiff Paid Date: ztcber 99, 90 n REQUESTING PARTY: Name -Mark J Udren,__Esg• _ Address: 1040 N Kings Hig_tnaav, Suite._500 _Cherry_Bdl ,__NJ_ 08034_ Attorney for: plaintiff _ Telephone: x .6_482-6490_ Supreme Court ID No. _pg302____ L.L. Due Prothy $1 nn Other Costs Curtis R Long Prothonotary, ,CC?ivil Division `yCLLr1q G / ' /i-rnw Dep agL ESTATE SALE coo. ?y On November 01, 2001, the sheriff levied upon the defendant's interest in the real property situated in Borough of Lemoyne, Cumberland County, PA, known and numbered as 632-634 Hummel Avenue, Lemoyne, and more fully described on Exhibit "A" filed with this writ and by this reference incorporated herein. Date: November 01, 2001 , C. W ?E !°? By:`nn 10 - `,-// 0 __ V_? tVI C?M Real Estate Deputy CM 9R RM PROOF OF PUBLICATION OF NOTICE IN CUMBERLAND LAW JOURNAL (Under Act No. 587, approved May 16, 1929), P. L.1784 STATE OF PENNSYLVANIA : ss. COUNTY OF CUMBERLAND : Roger M. Morgenthal, Esquire, Editor of the Cumberland Law Journal, of the County and State aforesaid, being duly sworn, according to law, deposes and says that the Cumberland Law Journal, a legal periodical published in the Borough of Carlisle in the County and State aforesaid, was established January 2, 1952, and designated by the local courts as the official legal periodical for the publication of all legal notices, and has, since January 2, 1952, been regularly issued weekly in the said County, and that the printed notice or publication attached hereto is exactly the same as was printed in the regular editions and issues of the said Cumberland Law Journal on the following dates, viz: JANUARY 25, FEBRUARY 1, 8, 2002 Affiant further deposes that he is authorized to verify this statement by the Cumberland Law Journal, a legal periodical of general circulation, and that he is not interested in the subject matter of the aforesaid notice or advertisement, and that all allegations in the foregoing statements as to time, place and character of publication are true. REAL ESTATE BALK NO. 16 Writ No. 1999-4866 Civil GE Capital Mortgage Services Inc. VS. Robert J. Holsberger. Jr. Atty.: Mark J. Udren ALL THAT CERTAIN lot or tract of land located in the Borough of Lemoyne. Cumberland County, Penn- sylvania. bounded and described as follows: BEGINNING at a point seventy five (75) feet from the southeast corner of Seventy Street (formerly Lome Street) and Hummel Avenue, and extending along the southern line of a Hummel Avenue In an east- Roger M. Morgenthal, Editor SWORN TO AND SUBSCRIBED before me this 8 day of FEBRUARY. 2002 LOIS E. SY(DER, NaL,ry Nub0.; Cad'sfa Ecin. C0.:^:wrd County wty c? f en;- ylcs h177 i 5.2015 THE PATRIOT NEWS THE SUNDAY PATRIOT NEWS Proof of Publication Under Act No. 587, Approved May 16, 1929 Commonwealth of Pennsylvania, County of Dauphin) as Michael Morrow being duly sworn according to law, deposes and says: That he is the Asst. Controller of The Patriot News Co., a corporation organized and existing under the laws of the Commonwealth of Pennsylvania, with its principal office and place of business at 812 to 818 Market Street, in the City of Harrisburg, County of Dauphin, State of Pennsylvania, owner and publisher of The Patriot-News andJJ1g Sunday Patriot-News newspapers of general circulation, printed and published at 812 to 818 Market Street, in the City, County and State aforesaid; that The Patriot-News and The Sunday Patriot-News were established March 41h, 1854, and September 18th, 1949, respectively, and all have been continuously published ever since; That the printed notice or publication which is securely attached hereto is exactly as printed and published In their regular daily and/or Sunday/ Metro editions which appeared on the 29th day(s) of January and the 5th and 12th day(s) of February 2002. That neither he nor said Company is interested in the subject matter of said printed notice or advertising, and that all of the allegations of this statement as to the time, place and character of publication are true; and That he has personal knowledge of the facts aforesaid and is duly authorized and empowered to verify this statement on behalf of The Patriot-News Co. aforesaid by virtue and pursuant to a resolution unanimously passed and adopted severally by the stockholders and board of directors of the said Company and subsequently duly recorded in the office for the Recording of Deeds in and for said County of Dauphin in Miscellaneous Book "M", Volume 14, Page 317. 1 8 _ PUBLICATION COPY SALE#14 22nd cldiv of No18rWseal / Vruary 2002 A.D. Terry L.1119601, NO%IY Pubeo? /GZ ,js Harrlaburg DBUWen Ceumy /' Mycommissimi2xiairssJunaa,2002 N ARY PUBLIC Member, PennOyNenla Association of Notenea My commission expires June 6, 2002 CUMBERLAND COUNTY SHERIFFS OFFICE .' L CUMMBERLAND COUNTY COURTHOUSE . CARLISLE, PA. 17013 * . M' Statement of Advertising Costs tctouadkwed b d w To THE PATRIOT-NEWS CO., Dr. F xi e uffolllo or publishing the notice or publication attached my-ft (75) tea ( SM11111 Shat hereto on the above stated dates $ 201.60 mmelAvea and Yoe of a Hammel Probating same Notary Fee(s) $ 1.50 m atirtydt (31) Total $ 203.10 -bat, im la h cw ?' Publisher's Receipt for Advertising Cost odtpt88e k6eam publisher of Th umotelAvmue. e Patriot-Newcand The Sunday Patriot-N gwsue, newspapers of general and Arame, receipt of the aforesaid notice and publication costs and certifies that the same have 24824167. 11128 to Kidlnpeodea Is VUW In Robot J. Hoiftlitar. 7^-!•j'' dud livin IscoM, formerly Jknmm as I)aam M. o11tnbach, dated 7113/1997 and retarded 7117/I99nn Decd amok 161 Page 160. By ....................................................................