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Home My WebLink About99-062177 7` f i ?l U `? - Jt Mr. ?e ?'A t }} t , . a , h S ?.?:/f^'?n ?H 4 ss ? ? I i yF? l to ?t n Ny ? sk 5 _ C; ?,^ VW : } I s, x { 11 ? Z? : it ¢ t le f .? ? /yy'yy±? ?! f A t S f S Tr?M ? ? ?f. ? .T A { x? F } 0. ? } ? ' ? I;avL J r .. : 1 ? ? = f r y y u ; YI ?y r t a X t+ ? 1 ? ka. t dF ?Y SU f' : . . w . ^i Y. A f Y LAY ? . ? ? ,'; I ii ?? T y T Y i t k? ??? I V., Fs f v. 54:. ' c d f ? Z yf V i ??0 M }Cf 1 I tJ J N I FEDERMAN AND PI (ELAN By: FRANK FEDERMAN, ESQUIRE IDENTIFICATION NO. 12248 TWO PENN CENTER PLAZA, SUITE 900 PHILADELPHIA, PA 19102 [2151 563-7000 ATTORNEY FOR PLAINTIFF COURT OF COMMON PLEAS CIVIL DIVISION CONTIMORTGAGE CORPORATION ONE CONTIPARK, 338 SOUTH WARMINSTER ROAD HATBORO, PA 19040 V. Plaintiff TERM NO. 99 - to aJ 7 WILLIE C. WHITE ANNA L. WHITE 173 RIDGE 1[ILL ROAD MECHANICSBURG, PA 17055 CUMBERLAND COUNTY Defendant(s) CIVIL ACTION - LAW MORTGAGE FORECLOSURE NOTICE PLEASE RE ADVISED THAT THIS FIRM IS A DEBT COLLECTOR ATTEMPTING TO COLLECT A DEBT. ANY INFORMATION RECEIVED WILL OF USED FOR MAT PURPOSE. IF YOU HAVE PREVIOUSLY RECEIVED A DISCHARGE IN BANKRUPTCY AND THIS DEBT WAS NOT REAFFIRMED, THIS CORRESPONDENCE is NOT AND SHOULD NOT HE CONSTRUED TO BE AN ATTEMPT TO COLLECT A DEBT BUT ONLY ENFORCEMENT OF A LIEN AGAINST PROPERTY. You have been sued in Court. If you wish to defend against the claims set forth in the following Pages, you must take action within twenty (20) days after this Complaint and Notice are served, by entering a written appearance personally or by attorney and riling 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 properly or other rights important to you. YOU SHOULD TAKE TI IIS PAPER TO YOUR LAWYER AT ONCE. IF YOU DO NOT HAVE A LAWYER OR CANNOT AFFORD ONE, GO TO OR TELEPI [ONE THE OFFICE SET FORTII BELOW TO FIND OUT WHERE YOU CAN GET LEGAL IIELP. CUMBERLAND COUNTY CUMBERLAND COUNTY BAR ASSOCIATION 2 LIBERTY AVENUE CARLISLE, PA 17013 (717) 249-3100 o?, /Q/L1rt 1. Plaintiff is CONTIMORTGAGE CORPORATION ONE CONTIPARK, 338 SOUTII WARMINSTER ROAD HATBORO, PA 19040 2. The name(s) and last known address (es) of the Defendant(s) are: WILLIE C. WI IITE ANNA L„ WHITE 173 RIDGE HILL ROAD MECHANICSBURG, PA 17055 who is/are the mortgagor(s) and real owner(s) of the properly hereinafter described. 3. On 8/19/97 mortgagor(s) made, executed and delivered a mortgage upon the premises hereinafter described to PLAINTIFF which mortgage is recorded in the Office of the Recorder of CUMBERLAND County, in Mortgage Book No. 1400, Page 880. 4. The premises subject to said mortgage is described as attached. 5. The mortgage is in default because monthly payments of principal and interest upon said mortgage due 3125/99 and each month thereafter are due and unpaid, and by the terms of said mortgage, upon failure of mortgagor to make such payments after a date specified by written notice sent to Mortgagor, the entire principal balance and all interest due thereon are collectible forthwith. A copy of such notice is attached as Exhibit "A." 6. The following amounts are due on the mortgage: Principal Valance Interest 2/25/99 through 7/1/99 (Per Diem $37.64) Attorney's Pees Cumulative Late Charges 8/19/97 to 7/1/99 Cost of Suit and Title Search Subtotal $150,734.24 4,780.28 7,536.00 488.39 550.00 164,088.91 Escrow Credit Deceit Subtotal TOTAL 0.00 385.81 385.81 $164,474.72 7. The attorney's fees set forth above are in conformity with the Mortgage documents and Pennsylvania Law, and will be collected in the event of a third party purchaser at Sheriffs Sale. If the Mortgage is reinstated prior to the Sale, reasonable attorney's fees will be charged. 8. This action does not come under Act 6 of 1974 because the original mortgage amount exceeds S50,000.00. 9. The Temporary Slay as provided by the i lomeowner's Emergency Mortgage Assistance Program, Act 91 of 1983, has terminated because either: (i.) Defendant(s) have failed to meet with the Plaintiff or an authorized Credit Counseling Agency in accordance with Plaintiff's written Notice to Defendants, a true and correct copy of which is attached hereto as Exhibit "Il"; or (il.) Defendant(s) application for assistance has been rejected by the Pennsylvania Ilousing Finance Agency. 10. Pursuant to the Fair Debt Collection Practices Act, 15 U.S.C. § 1692 et seq. (1974 Defendant(s) may dispute the validity of the debt or any portion thereof. If Defendant(s) do so in writing within thirty (30) days of receipt of this pleading, Counsel for Plaintiff will obtain and provide Defendant(s) with written verification thereon, otherwise, the debt will be assumed to be valid. Likewise, if requested within thirty (30) days of receipt of this pleading, Counsel for Plaintiff will send Dcfendant(s) the name and address of the original creditor if different from above. WHEREFORE, PLAINTIFF demands an in Cam Judgment against the Defendant(s) in the sum of $164,474.72, together with interest from 7/1199 at the rate of $37.64 per diem to the date of Judgment, and other costs and charges collectible under the mortgage and for the foreclosure and sale of the mortgaged property. S ' . / I rank Federman FRANK FEDERMAN, ESQUIRE Attorney for Plaintiff ContiMortgage One ContiPark • 938 S. Warminster Road • Hatboro, P.4 19040.3430 (888) 820.3411 Asset Alanagcment Department May 25, 1999 WILLIE C WHITE 173 RIDGE HILL RD MECHANICSBURG, PA 17055 RE: ContiMortgage Loan Number: 0004244513 ACT 6 NOTICE OF INTENTION TO FORECLOSE MORTGAGE The Mortgage held by ContiMortgage (thereafter we, us or ours) IS IN DEFAULT as a result of your failure to pay your last 2 monthly installments. Late charges have also accrued to this date. The total amount now required to cure this default or, in other words, get caught up in your payments, as of the date of this letter is $3,337.68. You may cure this default within THIRTY (30) DAYS of the date of this letter by paying to us the amount of $3,337.68 plus any additional monthly payments and late charges which may fall due during this period. Such payment must be made either by cashier's check, certified check or money order, and made payable to: CONTIMORTGAGE CORPORATION P. 0. Box 13919 PHILADELPHIA, PA 19101 If you do not cure the default within THIRTY (30) DAYS, we intend to exercise our right to accelerate the mortgage payments. This means that whatever is owing on the original amount borrowed will be considered due immediately and you may lose the chance to pay off the original mortgage in monthly installments. If full payment of the amount of the default is not made within THIRTY (30) DAYS, we also intend to instruct our attorneys to start a lawsuit to foreclose your mortgaged property. If the mortgage is foreclosed, your property will be sold by the Sheriff to pay off the mortgage debt. If we refer your case to our attorneys but you cure the default before they begin legal proceedings against you, you will still have to pay the reasonable attorney's fees actually incurred, up to $50.00. However, if legal proceedings are started against you, you will have to pay the reasonable attorney's fees even if they are over $50.00. Any attorney's fees will be added to whatever you owe us, which also may include our reasonable fees. If you cure the default within the thirty (30) day period, you will not be required to pay attorney's fees. We may also sue personally for the unpaid principal balance and all other sums due under the mortgage. e rinuM an rrndnl pgrr EXHIBIT A Q rn= ContiMortgage One ContiPark • 338 S. %Varmimter Road • Hatboro, PA 19040.3430 (888) 820.3411 Asset Management Department May 25, 1999 ANNA L WHITE 173 RIDGE HILL RD MECHANICSBURG, PA 17055 RE: ContiMortgage Loan Number: 0004244513 ACT 6 NOTICE OF INTENTION TO FORECLOSE MORTGAGE The Mortgage held by ContiMortgage (thereafter we, us or ours) IS IN DEFAULT as a result of your failure to pay your last 2 monthly installments. Late charges have also accrued to this date. The total amount now required to cure this default or, in other words, get caught up in your payments, as of the date of this letter is $3,337.68. You may cure thin default within THIRTY (30) DAYS of the date of this letter by paying to us the amount of $3,337.68 plus any additional monthly payments and late charges which may fall due during this period. Such payment must be made either by cashier's check, certified check or money order, and made payable to: CONTIMORTGAGE CORPORATION P. 0. Box 13919 PHILADELPHIA, PA 19101 If you do not cure the default within THIRTY (30) DAYS, we intend to exercise our right to accelerate the mortgage payments. This means that whatever is owing on the original amount borrowed will be considered due immediately and you may lose the chance to pay off the original mortgage in monthly installments. If full payment of the amount of the default is not made within THIRTY (30) DAYS, we also intend to instruct our attorneys to start a lawsuit to foreclose your mortgaged property. If the mortgage is foreclosed, your property will be sold by the sheriff to pay off the mortgage debt. If we refer your case to our attorneys but you cure the default before they begin legal proceedings against you, you will still have to pay the reasonable attorney's fees actually incurred, up to $50.00. However, if legal proceedings are started against you, you will have to pay the reasonable attorney's fees even if they are over $50.00. Any attorney's fees will be added to whatever you owe us, which also may include our reasonable fees. If you cure the default within the thirty (30) day period, you will not be required to pay attorney's fees. We may also sue personally for the unpaid principal balance and all other sums due under the mortgage. EXHMITA ® Pontnl on rcntlM p,jw Q MUS111 ContiMortgage - One Cont)Park • 338 S. Warminster Roacl • Hatboro, PA 19090.3430 (888) 820.3411 Asset Management Department Page Two ContiMortgage Loan Number 0004244513 If you have not cured the default within the thirty(30) day period and foreclosure proceedings have begun, you still have the right to cure the default and prevent the sale at any time up to one (1) hour before the Sheriff's foreclosure sale. You may do so by paying the total amount of the unpaid monthly payments plus any late or other charges then due, as well as the reasonable attorney's fees and costs connected with the foreclosure sale (and perform any other requirements under the mortgage). A notice of the date of the Sheriff's sale will be sent to you before the sale. Of course, the amount needed to cure the default will increase the longer you wait. You may find out at any time exactly what the required payment will be by calling us at the following number: 1-888-264-4990. This payment must be in cashier's check, certified check or money order and made payable to us at the address stated above. You should realize that Sheriff's sale will end your ownership of the mortgaged property and your rights to remain in it. If you continue to live in the property after the Sheriff's sale, a lawsuit could start to evict you. You have additional rights to help protect your interest in the property. YOU HAVE THE RIGHT TO SELL THE PROPERTY TO OBTAIN MONEY TO PAY OFF THE MORTGAGE DEBT, OR TO BORROW MONEY FROM ANOTHER LENDING INSTITUTION TO PAY OFF THIS DEBT. [YOU MAY HAVE THE RIGHT TO SELL OR TRANSFER THE PROPERTY SUBJECT TO THE MORTGAGE TO A BUYER OR TRANSFEREE WHO WILL ASSUME THE MORTGAGE DEBT, PROVIDED THAT ALL THE OUTSTANDING PAYMENTS, CHARGES AND ATTORNEY'S FEES AND COSTS ARE PAID PRIOR TO OR AT THE SALE, (AND THAT THE OTHER REQUIREMENTS UNDER THE MORTGAGE ARE SATISFIED). CONTACT US TO DETERMINE UNDER WHAT CIRCUMSTANCES THIS MIGHT EXIST.) YOU HAVE THE RIGHT TO HAVE THIS DEFAULT CURED BY ANY THIRD PARTY ACTING ON YOUR BEHALF. If you cure thWE ault, the mortgage will be restored to the same position as if no lt had occurred. However, you are not entitled to this right to cure your default more than three (3) times in any calendar year. Sincerely, Collection Department Asset Management Division Regular and Enclosure LWPAACT6 ® prim"I un rrndr.l papa Certified Mail EXV{1BIT A 'Q a rA= CondMortgage - One ContiPark • 398 S. %Varminsler Road • Hatboro, PA 19040.3430 (888) 820.9411 Asset Dfanagement Department May 25, 1999 WILLIE C WHITE 173 RIDGE HILL RD MECHANICSBURG, PA 17055 Re: ContiMortgage Loan Number: 0004244513 Property Address 173 RIDGE HILL RD, MECHANICSBU, PA 17055 ACT 91 TAKE ACTION TO SAVE YOUR HOME FROM FORECLOSURE The Commonwealth of Pennsylvania 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 Agency at 1-800-342-2397. La notification en adjunto es de suma importancia, pues afecta su derecho a continuar viviendo en su casa. Si no comprende el contenido de esta notification obtenga un traduccion immediatamente llamanda esta agencia (Pennsylvania Housing Finance Agency) sin cargos al numero menionada arriba. Puedes ser elegible para un prestamo por el programs llamado. "Homeowner's Emergency Mortgage Assistance Program": el cual puede salvar su casa de la pardida del derecho a redimir su hipoteca. IMPORTANT: NOTICE OF HOMEOWNER'S EMERGENCY MORTGAGE ASSISTANCE ACT OF 1983 PLEASE READ THIS NOTICE. YOU MAY BE ELIGIBLE FOR FINANCIAL ASSISTANCE TOWARD YOUR MORTGAGE PAYMENTS Your mortgage is in serious default because you have failed to pay promptly, your last 2 monthly installments of principal and interest. The total amount of the deliquency is $3,337.68. You may be eligible to financial assistance that will prevent foreclosure on your mortgage if you comply with the provisions of the Homeowner's Emergency Mortgage Assistance Act of 1983 (the "ACT"). You may be eligible for emergency temporary assistance if your default hay been caused by circumstances beyond your control, and if you meet the eligibility requirements of the Act as determined by the Pennsylvania Housing Finance Agency. Please read all of the Notice. It contains an explanation of your rights. ® pnnml nn ferrdrd p.,;W e 4vj?E3?r 13 112t [l1= ConiiMortgage - One ContiPark • 338 S. %Varminster Road • Hatboro, P.-1 19040.3430 (888) 820.3411 Asset Nfanagement Department May 25, 1999 ANNA L WHITE 173 RIDGE HILL RD MECHANICSBURG, PA 17055 Re: ContiMortgage Loan Number: 0004244513 Property Address 173 RIDGE HILL RD, MECHANICSBU, PA 17055 ACT 91 TAKE ACTION TO SAVE YOUR HOME FROM FORECLOSURE The Commonwealth of Pennsylvania 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 Agency at 1-800-342-2397. La notificacion en adjunto es de suma importancia, pues afecta su derecho a continuar viviendo en su casa. Si no comprende el contenido de esta notificacion obtenga un traduccion immediatamente llamanda esta agencia (Pennsylvania Housing Finance Agency) sin cargos al numero menionada arriba. Puedes ser elegible para un prestamo por el programa llamado. "Homeowner's Emergency Mortgage Assistance Program": el cual puede salvar su casa de la pardida del derecho a redimir su hipoteca. IMPORTANT: NOTICE OF HOMEOWNER'S EMERGENCY MORTGAGE ASSISTANCE ACT OF 1983 PLEASE READ THIS NOTICE. YOU MAY BE ELIGIBLE FOR FINANCIAL ASSISTANCE TOWARD YOUR MORTGAGE PAYMENTS Your mortgage is in serious default because you have failed to pay promptly, your last 2 monthly installments of principal and interest. The total amount of the deliquency is $3,337.68. You may be eligible to financial assistance that will prevent foreclosure on your mortgage if you comply with the provisions of the Homeowner's Emergency Mortgage Assistance Act of 1983 (the "ACT"). You may be eligible for emergency temporary assistance if your default has been caused by circumstances beyond your control, and if you meet the eligibility requirements of the Act as determined by the Pennsylvania Housing Finance Agency. Please read all of the Notice. It contains an explanation of your rights. ® Pru"nl ,n model p.jw EXHIBIT B "" w 0 ContiMortgage - One Conti Park • 338 S. Warminster Road • Hatboro. PA 19010.3.150 (888) 820.3411 Asset Management Department Page Two May 25, 1999 ContiMortgage Loan Number 0004244513 Under the Act, you are entitled to a temporary stay of foreclosure on your mortgage for thirty (30) days from the date of this Notice. During that time you have the right to arrange a "face-to-face" meeting with a representative of this lender, or with a designated consumer credit counseling agency. The purpose of that meeting is to attempt to work out a repayment plan or otherwise settle your delinquency. That 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 agent identified in this Notice, no further proceedings in mortgage foreclosure may take place for thirty (30) days after the date of that meeting. The name, address and telephone number of our representative is; ContiMortgage, COLLECTION DIVISION 3, P. O. Box 13919 Philadelphia, PA, 19101, 1-888-264-4990. The name(s), and address(es) of (a) designated consumer credit counseling agency(ies) is(are): SEE ATTACHED LIST It is only necessary to schedule one face-to-face meeting. You should advise this lender immediately of your intentions. If you have tried and are unable to resolve this problem at or after your face-to-face meeting, you have the right to apply for financial assistance from the Homeowner's Emergency Mortgage Assistance Fund. In order to do this, you must fill out, sign and file a completed Homeowner's Emergency Assistance Application with the Pennsylvania Housing Finance Agency. The consumer credit counseling agency will assist you in filling out your application. It must be postmarked within thirty (30) days of your face- to-face meetimg. You must either mail your application to the Pennsylvania Housing Finance Agency, or you must file it at the office of one of the designated consumer credit counseling agencies listed. The Pennsylvania Housing Finance Agency is located at 2101 North Front Street, P. O. Box 8029, Harrisburg, PA 17105, phone number 717-780-3800 or 800-342-2397 (toll free number). An application for assistance may be obtained from this lender, from a consumer credit counseling agency, or directly from the Pennsylvania Housing Finance Agency. It is extremely important that you file your application promptly. If you do not do so, or if you do not follow the other time periods set forth in this letter, foreclosure may proceed against your home immediately. Available funds for emergency mortgage assistance are very limited. They will be distributed by the Agency under the eligibility criteria established by the ACT. ® Pnnnl an rrnAnl pater. 13 Q EXH?B,T fl ContiMortgage - One Conti Park • 338 S. Warminster Road Hathoro, PA 190.10-3430 (888)820.3411 Asset Management Department Page Three May 25, 1999 ContiMortgage Loan Number 0004244513 It is extremely important that your application is accurate and complete in every respect. The counseling agency will help you to fill out the application. The Pennsylvania Housing Finance Agency has sixty (60) days to make a decision after it receives your application. During that additional time, no foreclosure proceedings will be pursued against you if you have met the time requirements set forth above. You will be notified directly by the Agency of its decision on your application. In addition, you will receive another notice from this lender under Act 6 of 1974. That notice is called a "Notice Of Intention To Foreclose". You must read both notices, since both explain rights that you now have under Pennsylvania law. However, if you choose to exercise your rights described in this notice, we cannot foreclose upon you during that time. Also, if you receive financial assistance from Pennsylvania Housing Finance Agency, your home cannot be foreclosed upon while you are receiving that assistance. Sincerely, Collection Department Asset Management Division Regular and Certified Mail Enclosure LWPAACT91 EXN?g?T ? ® haunt on re"tint p.iKr. Pennsylvania Housing Finance Agency Homeowner's Emergency Mortgage Assistance Program Consumer Credit Counseling Agencies (Rev. 5/99) Lymming•r:lintan Counties Commission For Community Action (STEP) 2138 Lincoln Street P. O. Box 1328 W(ll(amepor PA 17703 (370) 326-0587 FAX (570) 32:•2197 CCCS of Ntor_heasarn PA 201 Basin SCeet Willimu (S 0) 323.662 PA 17703 FAX (570) 323.8626 (,, n y CLINTON CO CCCS of Northeasara P.1 1631 S Atherma St Suits 100 State College, P.A. 16801 (814) 238-3668 FAX (814) 238-3669 COLUMBIA COUNTY CCCS of Northeastern Penmvlvan(a 31 W. Starker St eet 1400 AbuWAa Executive Park Suite 1127 Clarks 1 Winces-Barre. PA 18702 (570) 537Summi.9163 t. or r ( (800) 18411 922.9537 (S70) 821-0837 or (800) 922.9537 (570) FAX (570) 821.1785 F.' -C (5 10) 587.913 49135 Commission on Economics Opportunity of Luzern County 163 Amber Lane Wilkes•Barre, PA 18702 (570) 826-0510 or (800) 822-0339 FAX (570) 829.1665--CALL BEFORE FAXING (570) 455-4994 HAZELTON F,jLX (570) 455.5631-CALL BEFORE FA-X32XG (570) 8364090 TUNML-%"OCK Booker T. Washington Center 1720 Holland Street Erie, PA 16503 (814) 453.3744 FAX (814) 453-57 49 John F. Kennedy Center, Inc. 2021 East 20th Street Erie, PA 16510 (814) 898-0400 FAX (814) 898- 1243 CCCS of Western Pennsylvania, inc. 2000 L.iaglestown Road Harrisburg, PA 17102 (717) 541.1751 Urban League of Jletropolitaa Harrisburg N. 6th Street Harrisburg, PA 17101 (717) 234.3925 FAY (717) 234.9459 CRAWFORD COLNTY Greaur Erie Community Aeon Committee 18 West 9th Street Erie, PA 16301 (814) 4594581 FAX (814) 456-0161 Shenango valley Urban League, Inc 601 Indiana Avenue Farrell PA 161-41 (412)981.5310 Cum UA.ND COVYCY Financial Counseling Serrices of Franklin 31 West 3rd Street Waynesboro. PA 17268 (717)762.3285 YWCA of Carlisle 301 G Street Carlisle, PA 17013 (717) 243.3818 FrLY (717) 731.9589 Community Acton Comm of the Capital Region 1514 Derry Street Harrisburg, P.S. 17104 (717) 232.9757 FAX (717) 234.2227 Adams County Housing Author(ry 139-143 Carisle St Gettysburg, PA 17325 (717)334.1518 a FA.'C (717) 334-8326 EXHIBIT v PENNSYLVANIA BULLETIN, VOL. 29, NO. 23. JUNE S. 1949 1 5:Y ALL THAT CERTAIN tract of land situated in the. Township of Silver Spring, County of Cumberland and Commonwealth of Pennsylvania, bounded and described as follows: BEGINNING at s point in the center line of Township Road T-377 locally known as Ridge Hill Bond; thence by property now or fo=nerly of John R. Hair south 14 degrees 25 minutes east 25.02 feet to a stake in the ultimate right-of-way line of Township Road T-577; thence continuing along land of Hair south 14 degrees 25 minutes east 229.20 feet to a stake; thence by land of Shaffer Trucking Company south 73 degrees 35 minutes 30 seconds west 200.0 feat to a stake;' thence by lands of Pearl Beam north 14 degrees 24 minutes 41 seconds west 228.90 feet to a stake in the ultimate right-of-way of Township Road T-577; thence continuing along lands of`Pearl Beam north 14 degrees 24 minutes 41 seconds west 25.02 feet to a point in the center line of Township Road T-577; thence by said center line north 73 degrees 30 minutes east 200.0 feet to a point in said center line, the place of BEGINNING. BEING the same premises which EARL L. BEAM, by dead dated August 1, 1977 and recorded in the Office of the Recorder of Deeds for Cumberland County in Deed Book I, volume 27, Page 270, granted and conveyed to EARL L. BEAM and KATHY A. BEAM, his wife, grantors heroin. PREMISES: 173 RIDGE RILL. ROAD n # ?x ' ;,71 VERIFICATION NANCY RAMSEY hereby states that she is FORECLOSURE COORDINATOR of CONTIMORTGAGE MORTGAGE CORPORATION mortgage servicing agent for Plaintiff in this matter, that he/she is authorized to take this Verification, and that the statements made in the foregoing Civil Action in Mortgage Foreclosure arc true and correct to the best of his/her knowledge, information and belief. The undersigned understands that this statement is made subject to the penalties of 18 Pa. C.S. Sec. 4904 relating to unswom falsification to authorities. n ? Q DATE 0 J nc ) j V V ? ?l'" aoot•?a^r,l-? enid Klu:•J Mid ctrl 0016 Nr s NVl3Hd aNN NVViU'Za3d SHERIFF'S RETURN - NOT FOUND CASE NO: 1999-06217 P COMMONWEALTH OF PENNSYLVANIA: COUNTY OF CUMBERLAND CONTIMORTGAGE CORPORATION VS. WHITE WILLIE C R. Thomas Kline , Sheriff, who being duly sworn according to law, says, that he made a diligent search and inquiry for the within named defendant, to wit: WHITE WILLIE C but was unable to locate Him in his bailiwick. He therefore returns the COMPLAINT - MORT FORE NOTICE NOT FOUND , as to the within named defendant WHITE WILLIE C HOUSE IS VACANT DID NOT LEAVE FORWARDING W/P.O. RETURN NOT FOUND AS PER ATTY, 10/13/99. Sheriff's Costa: So answerer .?A Docketing 18.00 Service 4.96 Not Found Return 5.00??? _ Surcharge 8.00 7TM $35.96 1014 1999 PHELAN Sworn and subscribed to before me this -iYV- day of ?U c.. 19 q9 A.D. SHERIFF'S RETURN - NOT FOUND CASE NO: 1999-06217 P CGMMONWEALTH OF PENNSYLVANIA: COUNTY OF CUMBERLAND CONTIMORTGAGE CORPORATION VS. WHITE WILLIE C R. Thomas Kline Sheriff, who being duly sworn according to law, says, that he made a diligent search and inquiry for the within named defendant, to wit: WHITE ANNA L but was unable to locate Her in his bailiwick. He therefore returns the COMPLAINT - MORT FORE NOTICE NOT FOUND , as to the within named defendant WHITE ANNA L HOUSE IS_VACANT, LEFT NO FORWARDING WITH P.O. RETURN NOT FOUND AS PER ATTORNEY, 10/13/99. Sheriff's Costs: So answe Docketing 6.00 Not Found Return 5.00 Affidavit .00 Surcharge 8.00 IAA $19.00 FE ER 1999 PHELAN Sworn and subscribed to before me this AS"' day of (.r_f,,_ 19 9Or A.D. FEDERMAN AND PHELAN By: FRANK FEDERMAN. ESQUIRE IDENTIFICATION NO. 12248 TWO PENN CENTER PLAZA, SUITE 900 PHILADELPHIA, PA 19102 (215, 563-7000 CONTIMORTGAGE CORPORATION ONE CONTIPARK, 338 SOUTH WARMINSTER ROAD HATBORO, PA 19040 V. Plaintiff ATTORNEY FOR PLAINTIFF COURT OF COMMON PLEAS CIVIL DIVISION TERM WILLIE C. WHITE ANNA L. WHITE 173 RIDGE HILL ROAD M-ECHANICSBURG, PA 17055 Defendant(s) NO. 9A (oat 7 CUMBERLAND COUNTY CIVIL ACTION • LAW MORTGAGE FORECLOSURE NOTICE PLEASE BE ADVISED THAT THIS FIRM IS A DEBT COLLECTOR ATTEMPTING TO COLLECT A DEBT. ANY INFORMATION RECEIVED WILL BE USED FOR THAT PURPOSE. IF YOU HAVE PREVIOUSLY RECEIVED A DISCHARGE IN BANKRUPTCY AND THIS DEBT WAS NOT REAFFIRMED, THIS CORRESPONDENCE IS NOT AND SHOULD NOT BE CONSTRUED TO BE AN ATTEhIIT TO COLLECT A DEBT BUT ONLY ENFORCEMENT OFA LIEN AGAINST PROPERTY. You have been sued in Court. If you wish to defend against the claims set forth in the following pages, you must take action within twenty (20) days after this Complaint and Notice are served, by entering a written appearance personally or by attorney and riling 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 properly or other rights important to you. YOU SHOULD TAKE THIS PAPER TO YOUR LAWYER AT ONCE. IF YOU DO NOT HAVE A LAWYER OR CANNOT AFFORD ONE, GO TO OR TELEPHONE THE OFFICE SET FORTH BELOW TO FIND OUT WHERE YOU CAN GET LEGAL HELP. CUMBERLAND COUNTY CUMBERLAND COUNTY BAR ASSOCIATION 2 LIBERTY AVENUE CARLISLE, PA 17013 (717) 249-3166 TRUE DOPY FROM REOORD In TSWIMI N Mod, I M alb M 0 trod and the sad d wN CCo(A d CAMIlL L g4- hanonowy We hereby certify the vrlthin to be a true and Cato t copy of the +.lgmal filed of rocord FFO%:R%1AN AND PHFLAN 1. Plaintiff is CONTIMORTGAGE CORPORATION ONE CONTIPARK, 338 SOUTH WARMINSTER ROAD HATBORO, PA 19040 2. The name(s) and last known address (es) of the Defendant(s) are: WILLIE C. WHITE ANNA L. WHITE 173 RIDGE HILL ROAD MECHANICSBURG, PA 17055 who is/are the mortgagor(s) and real owner(s) of the property hereinafter described. 3. On 8/19/97 mortgagor(s) made, executed and delivered a mortgage upon the premises hereinafter described to PLAINTIFF which mortgage is recorded in the Office of the Recorder of CUMBERLAND County, in Mortgage Book No. 1400, Page 880. 4. The premises subject to said mortgage is described as attached. 5. The mortgage is in default because monthly payments of principal and interest upon said mortgage due 3/25/99 and each month thereafter are due and unpaid, and by the terms of said mortgage, upon failure of mortgagor to make such payments after a date specified by written notice sent to Mortgagor, the entire principal balance and all interest due thereon are collectible forthwith. A copy of such notice is attached as Exhibit "A." 6. The following amounts are due on the mortgage: Principal Balance $150,734.24 Interest 4,780.28 2/25/99 through 7/1/99 (Per Diem $37.64) Attorney's Fees 7,536.00 Cumulative Tale Charges 488.39 8119/97 to 7/1/99 Cost of Suit and Title Search 550.00 Subtotal 164,088.91 Escrow Credit 0.00 Deficit 385.81 Subtotal 385.81 TOTAL $164,474.72 7. The attorney's fees set forth above are in conformity with the Mortgage documents and Pennsylvania Law, and will be collected in the event of a third party purchaser at Sheriff's Sale. If the Mortgage is reinstated prior to the Sale, reasonable attorney's fees will be charged. 8. This action does not come under Act 6 of 1974 because the original mortgage amount exceeds $50,000.00. 9. The Temporary Stay as provided by the Homeowner's Emergency Mortgage Assistance Program, Act 91 of 1983, has terminated because either: (i.) Defendant(s) have failed to meet with the Plaintiff or an authorized Credit Counseling Agency in accordance with Plaintiff's written Notice to Defendants, a true and correct copy of which is attached hereto as Exhibit "B"; or (ii.) Defendant(s) application for assistance has been rejected by the Pennsylvania Housing Finance Agency. 10. Pursuant to the Fair Debt Collection Practices Act, 15 U.S.C. § 1692 et seq. (1977), Defendant(s) may dispute the validity of the debt or any portion thereof. If Defendant(s) do so in writing within thirty (30) days of receipt of this pleading, Counsel for Plaintiff will obtain and provide Defendant(s) with written verification thereof, otherwise, the debt will be assumed to be valid. Likewise, if requested within thirty (30) days of receipt of this pleading, Counsel for Plaintiff will send Defendant(s) the name and address of the original creditor if different from above. WHEREFORE, PLAINTIFF demands an in MM Judgment against the Defendant(s) in the sum of 5164,474.72, together with interest from 7/1/99 at the rate of $37.64 per diem to the date of Judgment, and other costs and charges collectible under the mortgage and for the foreclosure and sale of the mortgaged property. /s/ Frank Federman FRANK FEDERMAN, ESQUIRE Attorney for Plaintiff ContiMortgage - One ContiPark • 338 S. Warminster Road • Hatboro, PA 19040.3490 (888) 820.3411 Asset lfanagement Department May 25, 1999 WILLIE C WHITE 173 RIDGE HILL RD MECHANICSBURG, PA 17055 RE: ContiMortgage Loan Number: 0004244513 [ASE MORTGAGE The Mortgage held by ContiMortgage (thereafter we, us or ours) IS IN DEFAULT as a result of your failure to pay your last 2 monthly installments. Late charges have also accrued to this date. The total amount now required to cure this default or, in other words, get caught up in your payments, as of the date of this letter is $3,337.68. You may cure this default within THIRTY (30) DAYS of the date of this letter by paying to us the amount of $3,337.68 plus any additional monthly payments and late charges which may fall due during this period. Such payment must be made either by cashier's check, certified check or money order, and made payable to: CONTIMORTGAGE CORPORATION P. 0. Box 13919 PHILADELPHIA, PA 19101 If you do not cure the default within THIRTY (30) DAYS, we intend to exercise our right to accelerate the mortgage payments. This means that whatever is owing on the original amount borrowed will be considered due immediately and you may lose the chance to pay off the original mortgage in monthly installments. If full payment of the amount of the default is not made within THIRTY (30) DAYS, we also intend to instruct our attorneys to start a lawsuit to foreclose your mortgaged property. If the mortgage is foreclosed, your property will be sold by the Sheriff to pay off the mortgage debt. If we refer your case to our attorneys but you cure the default before they begin legal proceedings against you, you will still have to pay the reasonable attorney's fees actually incurred, up to $50.00. However, if legal proceedings are started against you, you will have to pay the reasonable attorney's fees even if they are over $50.00. Any attorney's fees will be added to whatever you owe us, which also may include our reasonable fees. If you cure the default within the thirty (30) day period, you will not be required to pay attorney's fees. We may also sue personally for the unpaid principal balance and all other sums due under the mortgage. ® rmm .n trmim p.p,r EXHIBIT A Q >s dL'E><A ContiMortgage - One ContiPark • 938 S. Warminster Road • Hatboro, PA 19040.3430 (888) 820.3411 Asset Nfanagement Department May 25, 1999 ANNA L WHITE 173 RIDGE HILL RD MECHANICSBURG, PA 17055 RE: ContiMortgage Loan Number: 0004244513 6 MORTGAGE The Mortgage held by ContiMortgage (thereafter we, us or ours) IS IN DEFAULT as a result of your failure to pay your last 2 monthly installments. Late charges have also accrued to this date. The total amount now required to cure this default or, in other words, get caught up in your payments, as of the date of this letter is $3,337.68. You may cure this default within THIRTY (30) DAYS of the date of this letter by paying to us the amount of $3,337.68 plus any additional monthly payments and late charges which may fall due during this period. Such payment must be made either by cashier's check, certified check or money order, and made payable to: CONTIMORTGAGE CORPORATION P. 0. Box 13919 PHILADELPHIA, PA 19101 If you do not cure the default within THIRTY (30) DAYS, we intend to exercise our right to accelerate the mortgage payments. This means that whatever is owing on the original amount borrowed will be considered due immediately and you may lose the chance to pay off the original mortgage in monthly installments. If full payment of the amount of the default is not made within THIRTY (30) DAYS, we also intend to instruct our attorneys to start a lawsuit to foreclose your mortgaged property. If the mortgage is foreclosed, your property will be sold by the Sheriff to pay off the mortgage debt. If we refer your case to our attorneys but you cure the default before they begin legal proceedings against you, you will still have to pay the reasonable attorney's fees actually incurred, up to $50.00. However, if legal proceedings are started against you, you will have to pay the reasonable attorney's fees even if they are over $50.00. Any attorney's fees will be added to whatever you owe us, which also may include our reasonable fees. If you cure the default within the thirty (30) day period, you will not be required to pay attorney's fees. We may also sue personally for the unpaid principal balance and all other sums due under the mortgage. ® rrlNbl m rrnrlm mjwr EXHIBIT'q 'Q 0 Conti Mortgage One ContiPark • 338 S. %Varminster Road • Hatboro, PA 19040$430 (888) 820-3411 Asset Management Department Page Two ContiMortgage Loan Number 0004244513 If you have not cured the default within the thirty(30) day period and foreclosure proceedings have begun, you still have the right to cure the default and prevent the sale at any time up to one (1) hour before the Sheriff's foreclosure sale. You may do so by paying the total amount of the unpaid monthly payments plus any late or other charges then due, as well as the reasonable attorney's fees and costs connected with the foreclosure sale (and perform any other requirements under the mortgage). A notice of the date of the Sheriff's sale will be sent to you before the sale. Of course, the amount needed to cure the default will increase the longer you wait. You may find out at any time exactly what the required payment will be by calling us at the following number: 1-888-264-4990. This payment must be in cashier's check, certified check or money order and made payable to us at the address stated above. You should realize that Sheriff's sale will end your ownership of the mortgaged property and your rights to remain in it. If you continue to live in the property after the Sheriff's sale, a lawsuit could start to evict you. You have additional rights to help protect your interest in the property. YOU HAVE THE RIGHT TO SELL THE PROPERTY TO OBTAIN MONEY TO PAY OFF THE MORTGAGE DEBT, OR TO BORROW MONEY FROM ANOTHER LENDING INSTITUTION TO PAY OFF THIS DEBT. (YOU MAY HAVE THE RIGHT TO SELL OR TRANSFER THE PROPERTY SUBJECT TO THE MORTGAGE TO A BUYER OR TRANSFEREE WHO WILL ASSUME THE MORTGAGE DEBT, PROVIDED THAT ALL THE OUTSTANDING PAYMENTS, CHARGES AND ATTORNEY'S FEES AND COSTS ARE PAID PRIOR TO OR AT THE SALE, (AND THAT THE OTHER REQUIREMENTS UNDER THE MORTGAGE ARE SATISFIED). CONTACT US TO DETERMINE UNDER WHAT CIRCUMSTANCES THIS MIGHT EXIST.] YOU HAVE THE RIGHT TO HAVE THIS DEFAULT CURED BY ANY THIRD PARTY ACTING ON YOUR BEHALF. If you cure the default the mortgage will be restored to the same position as it no cetau entitled to this right to cure your in any calendar year. Sincerely, Collection Department Asset Management Division Regular and Certified Mail Enclosure LWPAACT6 ® Pnn,nl nn mulyd p1wr occurred. However, you are not t more than three (3) times ExH?Brr A ,Q ContiMortgage One ContiPark • 338 S. Warminster Road • Hatboro, PA 19040.3430 (888) 820.3411 Asset Management Department May 25, 1999 WILLIE C WHITE 173 RIDGE HILL RD MECHANICSBURG, PA 17055 Re: ContiMortgage Loan Number: 0004244513 Property Address 173 RIDGE HILL RD, MECHANICSBU, PA 17055 ACT 91 TAKE ACTION TO SAVE YOUR HOME FROM FORECLOSURE The Commonwealth of Pennsylvania 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 Agency at 1-800-342-2397. La notification en adjunto es de suma importancia, pues afecta su derecho a continuar viviendo en su casa. Si no comprende el contenido de esta notification obtenga un traduccion immediatamente llamanda esta agencia (Pennsylvania Housing Finance Agency) sin cargos al numero menionada arriba. Puedes ser elegible para un prestamo por el programa llamado. "Homeowner's Emergency Mortgage Assistance Program": el cual puede salvar su casa de la pardida del derecho a redimir su hipoteca. IMPORTANT: NOTICE OF HOMEOWNER'S EMERGENCY MORTGAGE ASSISTANCE ACT OF 1983 PLEASE READ THIS NOTICE. YOU MAY BE ELIGIBLE FOR FINANCIAL ASSISTANCE TOWARD YOUR MORTGAGE PAYMENTS Your mortgage is in serious default because you have failed to pay promptly, your last 2 monthly installments of principal and interest. The total amount of the deliquency is $3,337.68. You may be eligible to financial assistance that will prevent foreclosure on your mortgage if you comply with the provisions of the Homeowner's Emergency Mortgage Assistance Act of 1983 (the "ACT"). You may be eligible for emergency temporary assistance if your default has been caused by circumstances beyond your control, and if you meet the eligibility requirements of the Act as determined by the Pennsylvania Housing Finance Agency. Please read all of the Notice. It contains an explanation of your rights. ® hunnl an r,nd,d pips O EXM?B'T 6 Q rAw ContiMortgage - One ContiPark • 338 S. Warminster Road • Hatboro, PA 190403430 (888) 820.3411 Asset Management Department May 25, 1999 ANNA L WHITE 173 RIDGE HILL RD MECHANICSBURG, PA 17055 Re: ContiMortgage Loan Number: 0004244513 Property Address 173 RIDGE HILL RD, MECHANICSBU, PA 17055 ACT 91 TAKE ACTION TO SAVE YOUR HOME FROM FORECLOSURE The Commonwealth of Pennsylvania 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 Agency at 1-800-342-2397. La notification en adjunto es de suma importancia, pues afecta su derecho a continuar viviendo en su casa. Si no comprende el contenido de esta notification obtenga un traduccion immediatamente llamanda esta agencia (Pennsylvania Housing Finance Agency) sin cargos al numero menionada arriba. Puedes ser elegible para un prestamo por el programa llamado. "Homeowner's Emergency Mortgage Assistance Program": el cual puede salvar su casa de la pardida del derecho a redimir su hipoteca. IMPORTANT: NOTICE OF HOMEOWNER'S EMERGENCY MORTGAGE ASSISTANCE ACT OF 1983 PLEASE READ THIS NOTICE. YOU MAY BE ELIGIBLE FOR FINANCIAL ASSISTANCE TOWARD YOUR MORTGAGE PAYMENTS Your mortgage is in serious default because you have failed to pay promptly, your last 2 monthly installments of principal and interest. The total amount of the deliquency is $3,337.68. You may be eligible to financial assistance that will prevent foreclosure on your mortgage if you comply with the provisions of the Homeowner's Emergency Mortgage Assistance Act of 1983 (the "ACT"). You may be eligible for emergency temporary assistance if your default has been caused by circumstances beyond your control, and if you meet the eligibility requirements of the Act as determined by the Pennsylvania Housing Finance Agency. Please read all of the Notice. It contains an explanation of your rights. EXHjgjI B ® PnmM nn ntItIM P-IM, 'Q ContiMortgage One ContiPark • 338 S. Warminster Road • Hatboro, Ba 190.10.3430 (888) 820.3411 Asset Management Department Page Two May 25, 1999 ContiMortgage Loan Number 0004244513 Under the Act, you are entitled to a temporary stay of foreclosure on your mortgage for thirty (30) days from the date of this Notice. During that time you have the right to arrange a "face-to-face" meeting with a representative of this lender, or with a designated consumer credit counseling agency. The purpose of that meeting is to attempt to work out a repayment plan or otherwise settle your delinquency. That 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 agent identified in this Notice, no further proceedings in mortgage foreclosure may take place for thirty (30) days after the date of that meeting. The name, address and telephone number of our representative is; ContiMortgage, COLLECTION DIVISION 3, P. O. Box 13919 Philadelphia, PA, 19101, 1-888-264-4990. The name(s), and address(es) of (a) designated consumer credit counseling agency(ies) is(are): SEE ATTACHED LIST It is only necessary to schedule one face-to-face meeting. You should advise this lender immediately of your intentions. If you have tried and are unable to resolve this problem at or after your face-to-face meeting, you have the right to apply for financial assistance from the Homeowner's Emergency Mortgage Assistance Fund. In order to do this, you must fill out, sign and file a completed Homeowner's Emergency Assistance Application with the Pennsylvania Housing Finance Agency. The consumer credit counseling agency will assist you in filling out your application. It must be postmarked within thirty (30) days of your face- to-face meetimg. You must either mail your application to the Pennsylvania Housing Finance Agency, or you must file it at the office of one of the designated consumer credit counseling agencies listed. The Pennsylvania Housing Finance Agency is located at 2101 North Front Street, P. O. Box 8029, Harrisburg, PA 17105, phone number 717-780-3800 or 800-342-2397 (toll free number). An application for assistance may be obtained from this lender, from a consumer credit counseling agency, or directly from the Pennsylvania Housing Finance Agency. It is extremely important that you file your application promptly. If you do not do so, or if you do not follow the other time periods set forth in this letter, foreclosure may proceed against your home immediately. Available funds for emergency mortgage assistance are very limited. They will be distributed by the Agency under the eligibility criteria established by the ACT. EXHIBIT B Q ® Ir"unt m unclad p..per rri'EQ71 Con6Mortgage - One ContiPark • 938 S. Warminster Road • Hatboro, PA 19040.3490 (888) 8203411 Asset Management Department Page Three May 25, 1999 ContiMortgage Loan Number 0004244513 It is extremely important that your application is accurate and complete in every respect. The counseling agency will help you to fill out the application. The Pennsylvania Housing Finance Agency has sixty (60) days to make a decision after it receives your application. During that additional time, no foreclosure proceedings will be pursued against you if you have met the time requirements set forth above. You will be notified directly by the Agency of its decision on your application. In addition, you will receive another notice from this lender under Act 6 of 1974. That notice is called a "Notice Of Intention To Foreclose,, You must read both notices, since both explain rights that you now have under Pennsylvania law. However, if you choose to exercise your rights described in this notice, we cannot foreclose upon you during that time. Also, if you receive financial assistance from Pennsylvania Housing Finance Agency, your home cannot be foreclosed upon while you are receiving that assistance. Sincerely, Collection Department Asset Management Division Regular and Certified Mail Enclosure LWPAACT91 { EXyA1g1T B :t. 0 hired on reode d paper t Pennsylvania Housing Finance Agency Homeowner's Emergency Mortgage Assistance Program Consumer Credit Counseling Agencies (Rev. 5/99) Lycoming-Clintan Cauncies Commission For Community Aron (STEP) 2138 Lincoln Street P. 0. Box 1328 Wtlliamspor PA 17703 (370) 326-0sa7 FAX (5,0) 322-2 197 CCCS of Yor4eastern PA 201 Bain Street WlUiamsport P.A. 17703 (370)323.6627 FAX (5.0) 323.6626 CT.LvrON COL-YIN CCCS ofNorheasten PA 1631 S Atherma St Suits 100 State call*". PA 16a01 (814) 238-3668 FAX (814) 2384669 COLLNMrA COM%-ff CCCS of Vor_4easten PeaaeVIVania 31 W. Market Suet 1400 Abington Execndve Parts POB U- Suite 1 W[ikas-Barre. PA 18702 Clarks Summit. PA U411 (870) 821-0837 or (800) 922.9537 (570) 587.9163 or (800) 922.953- FAX (570) 821-1785 FA.'C(570)587.913469135 Commission on Economics Oppor=ity of Luzern County 163 Amber Lane Wilkes-Barre, PA 18702 (570) 826-0510 or (800) 822-0359 FAX (370) 829.1665-CALL BEFORE FA ONG (570) 455.4994 °LTON FA.C (570) 435.5631-CALL BEFORE F.A-WG (370) 836.4090 TLNr=LA.N'MOCK Booker T. Washington. Center 1720 Holland Street Erie, PA 16503 (814) 453.5744 FAX (814) 453.5749 John F. Kennedy Center. Inc. 2021 East 20th Street Ere. PA 16510 (814) 898-04CO FAX (814) 898.1243 CCCS of Western Pennsylvania. Inc. 2000 Ling!estown Road Harrisburg. PA 17102 (717)541.1757 Urban Lague of S(e=politan Harrsburg N. 6th Seeet Hsrrsburg, PA 17101 (717) 234-5925 FAX (717) 234.9459 CRAWFORD COMNrY Greater Erie Community,lc=on Committee 18 West 914 Stint Ere, PA 16501 (814) 459-1581 FAX (814) 456-0161 Shenaaggaa Valley Urban League. Inc 6011adlaaa Avenue Far-e0. PA 161^1 (412) 981.5310 CUNMERLAMD COUNTY Fiaandal Counseling SerAces of Fanklin 31 West 3rd Street Waynesboro. PA 17268 (717) 762-3255 YWCA of Carlisle 301 G Scat Carlisle. PA 17013 (717) 243.3818 FAX (7 M 731.95a9 Community Ae%jcn Comrn of the Capital Region 1514 Derry Street Harrshurj, PA 17104 (717) 232.9757 FAX IT, L ) 234.2227 Adams Count/ Hcusinz Authori 139-143 Carlisle St Gettysburg. PA 17325 (711) 334.1518 PA.Y (717) 3344326 EXHIBIT PENNSYLVANIA BULLETIN, VCL. 29, NO. 23. NNE S, 1999 ALL THAT CERTAIN tract of land situated In the Township of Silver Spring, County of Cumberland and Commonwealth of Pennsylvania, bounded and described as follows: BEGINNING at a point in the center line of Township Road T-577 locally known as RLdgo Hill Road; thence by property now or formerly of John R. Hair south 14 degrees 25 minutes east 25.02 feet to a stake in the ultimate right-of-way line of Township Road T-577; thence continuing along land of Hair south 14 degrees 25 minutes east 229.20 feet to a stake; thence by land of Shaffer Trucking Company south 73 degrees 35 minutes 30 seconds west 200.0 feat to a stake;' thence by lands of Pearl Beam north 14 degrees 24 minutes 41 seconds west 228.90 feat to a stake in the ultimate right-of-way of Township Road T-577; thence continuing along lands of Pearl Beam north 14 degrees 24 minutes 41 seconds west 25.02 fact to a point in the center line of Township Road T-577; thence by said center lino north 73 degraen 30 minutes east 200.0 feet to a point in said center line, the place of BEGINNING. BEING the same premises which EARL L. BEAM, by dead dated August 10 1977 and recorded in the Office of the Recorder of Deeds for Cumberland County in Deed Book I, Volume 27, Page 270, granted and conveyed to EARL L. BEAM and FATHY A. BEAM, his wife, grantors herein. PREMISES: 173 RIDGE HILL ROAD VERIFICATION NANCY RAMSEY hereby states that she is FORECLOSURE COORDINATOR of CONTIMORTGAGE MORTGAGE CORPORATION mortgage servicing agent for Plaintiff in this matter, that hc1she is authorized to take this Verification, and that the statements made in the foregoing Civil Action in Mortgage Foreclosure are true and correct to the best of his/her knowledge, information and belief. The undersigned understands that this statement is made subject to the penalties of 18 Pa, C.S. Sec. 4904 relating to unswom falsification to authorities. n nn Q DATE: V ' h "1 7 ?l OFF".F r Tui run(!FF ( ^J Oct I 1 2 Crn;d I:;U: j l:::t i COS ,-; r.; Wl Nd GNV NUS3O3d FEDERMAN AND PHELAN By: FRANK FEDERMAN, ESQUIRE IDENTIFICATION NO. 12248 TWO PENN CENTER PLAZA, SUITE 900 PHILADELPHIA, PA 19102 (215) 563-7000 CONTIMORTGAGE CORPORATION ONE CONTIPARK, 338 SOUTH WARMINSTER ROAD HATBORO, PA 19040 V. Plaintiff WILLIE C. WHITE ANNA L. WHITE 173 RIDGE HILL ROAD MECHANICSBURG, PA 17055 Defendant(s) TERM NO. 99 -- laaI7 l'rutCW 1 CUMBERLAND COUNTY CIVIL ACTION • LAW MORTGAGE FORECLOSURE NOTICE PLEASE BE ADVISED TIIAT TIIIS FIRM IS A DEBT COLLECTOR ATTEAIPTING TO COLLECT A DEBT. ANY INFORMATION RECEIVED WILL BE USED FOR THAT PURPOSE. IF YOU IIAVE PREVIOUSLY RECEIVED A DISCHARGE IN BANKRUPTCY AND THIS DEBT WAS NOT REAFFIRMED, THIS CORRESPONDENCE IS NOT AND SIIOULD NOT BE CONSTRUED TO BE AN ATTEMPT TO COLLECT A DEBT BUT ONLY ENFORCEMENT OF A WEN AGAINST PROPERTY. You have been sued in Court. If you wish to defend against the claims set forth in the following pages, you must take action within twenty (20) days after this Complaint and Notice are served, by entering a written appearance personally or by attorney and riling in writing with the court your defenses or objections to the claims set forth against you. You are warned that if you fail to do so the case may proceed without you and a judgment may be entered against you by the court without further notice for any money claimed in the Complaint or for any other claim or relief requested by the Plaintiff. You may lose money or property or other rights important to you. YOU SHOULD TAKE THIS PAPER TO YOUR LAWYER AT ONCE. IF YOU DO NOT HAVE A LAWYER OR CANNOT AFFORD ONE, GO TO OR TELEPHONE THE OFFICE SET FORTH BELOW TO FIND OUT WHERE YOU CAN GET LEGAL HELP. CUMBERLAND COUNTY CUMBERLAND COUNTY BAR ASSOCIATION 2 LIBERTY AVENUE CARLISLE, PA 17013 (717) 249-3106 TRUE COPY FROM REOORD oil i Gytlllgfly tlhero. I Iti" Vol flat ON bw :•d tM d t?rd LOUR r CarlieMQ,.P? t:+s t3q ?? ,??I?? ATTORNEY FOR PLAINTIFF COURT OF COMMON PLEAS CIVIL DIVISION We hereby certify the wilh!n to bo a true and ca rc;ct copy of the *riginal Nod of record FEDERMAN AND PHELAN 1. Plaintiff is CONTIMORTGAGE CORPORATION ONE CONTIPARIC338 SOUTH WARMINSTER ROAD HATBORO, PA 19040 2. The name(s) and last known address (es) of the Defendant(s) are: WILLIE C. WHITE ANNA L. WHITE 173 RIDGE HILL ROAD MECHANICSBURG, PA 17055 who is/are the mortgagor(s) and real owner(s) of the property hereinafter described. 3. On 8/19/97 mortgagor(s) made, executed and delivered a mortgage upon the premises hereinafter described to PLAINTIFF which mortgage is recorded in the Office of the Recorder of CUMBERLAND County, in Mortgage Book No. 1400, Page 880. 4. The premises subject to said mortgage is described as attached. 5. The mortgage is in default because monthly payments of principal and interest upon said mortgage due 3/25/99 and each month thereafter are due and unpaid, and by the terms of said mortgage, upon failure of mortgagor to make such payments after a date specified by written notice sent to Mortgagor, the entire principal balance and all interest due thereon are collectible forthwith. A copy of such notice is attached as Exhibit "A." 6. The following amounts are due on the mortgage: Principal Balance 5150,734.24 Interest 4,780.28 2/25/99 through 7/1/99 (Per Diem 537.64) Attorney's Fees 7,536.00 Cumulative Late Charges 488.39 8/19/97 to 7/1/99 Cost of Suit and Title Search 550.00 Subtotal 164,088.91 Escrow Credit 0.00 Deficit 385.81 Subtotal 385.81 TOTAL $164,474.72 7. The attorney's fees set forth above are in conformity with the Mortgage documents and Pennsylvania Law, and will be collected in the event of a third party purchaser at Sheriff's Sale. If the Mortgage is reinstated prior to the Sale, reasonable attorney's fees will be charged. 8. This action does not come under Act 6 of 1974 because the original mortgage amount exceeds $50,000.00. 9. The Temporary Stay as provided by the Homeowner's Emergency Mortgage Assistance Program, Act 91 of 1983, has terminated because either: (i.) Defendant(s) have failed to meet with the Plaintiff or an authorized Credit Counseling Agency in accordance with Plaintiff's written Notice to Defendants, a true and correct copy of which is attached hereto as Exhibit "B"; or (ii.) Defendant(s) application for assistance has been rejected by the Pennsylvania Housing Finance Agency. 10. Pursuant to the Fair Debt Collection Practices Act, 15 U.S.C. § 1692 et seq. (1977), Defendant(s) may dispute the validity of the debt or any portion thereof. If Defendanl(s) do so in writing within thirty (30) days of receipt of this pleading, Counsel for Plaintiff will obtain and provide Defendant(s) with written verification thereof, otherwise, the debt will be assumed to be valid. Likewise, if requested within thirty (30) days of receipt of this pleading, Counsel for Plaintiff will send Defendant(s) the name and address of the original creditor if different from above. WHEREFORE, PLAINTIFF demands an jg [SID Judgment against the Defendant(s) in the sum of $164,474.72, together with interest from 7/1/99 at the rate of $37.64 per diem to the date of Judgment, and other costs and charges collectible under the mortgage and for the foreclosure and sale of the mortgaged property. A// Frank Federman FRANK FEDERMAN, ESQUIRE Attorney for Plaintiff PiSe 0 ContiMortgage - One Contii'aik • 338 S. Warminster Road • Hatboro, PA 19040.3430 (888) 820.3411 Asset Management Department May 25, 1999 WILLIE C WHITE 173 RIDGE HILL RD MECHANICSBURG, PA 17055 RE: ContiMortgage Loan Number: 0004244513 The Mortgage held by ContiMortgage (thereafter we, us or ours) IS IN DEFAULT as a result of your failure to pay your last 2 monthly installments. Late charges have also accrued to this date. The total amount now required to cure this default or, in other words, get caught up in your payments, as of the date of this letter is $3,337.68. You may cure this default within THIRTY (30) DAYS of the date of this letter by paying to us the amount of $3,337.68 plus any additional monthly payments and late charges which may fall due during this period. Such payment must be made either by cashier's check, certified check or money order. and made oavable to: CONTIMORTGAGE CORPORATION P. 0. Box 13919 PHILADELPHIA, PA 19101 If you do not cure the default within THIRTY (30) DAYS, we intend to exercise our right to accelerate the mortgage payments. This means that whatever is owing on the original amount borrowed will be considered due immediately and you may lose the chance to pay off the original mortgage in monthly installments. If full payment of the amount of the default is not made within THIRTY (30) DAYS, we also intend to instruct our attorneys to start a lawsuit to foreclose your mortgaged property. If the mortgage is foreclosed, your property will be sold by the Sheriff to pay off the mortgage debt. If we refer your case to our attorneys but you cure the default before they begin legal proceedings against you, you will still have to pay the reasonable attorney's fees actually incurred, up to $50.00. However, if legal proceedings are started against you, you will have to pay the reasonable attorney's fees even if they are over $50.00. Any attorney's fees will be added to whatever you owe us, which also may include our reasonable fees. If you cure the default within the thirty (30) day period, you will not be required to pay attorney's fees. We may also sue personally for the unpaid principal balance and all other sums due under the mortgage. EXHIBIT A 12t ® Mrunl nn rrn dnl p.µxr rAm ContiMortgage One ContiPark • 338 S. Warminster Road • Hatboro, PA 19040.3430 (888) 820.3411 Asset Management Department May 25, 1999 ANNA L WHITE 173 RIDGE HILL RD MECHANICSBURG, PA 17055 RE: ContiMortgage Loan Number: 0004244513 ACT 6 NOTICE OF INTENTION TO FORECLOSE MORTGAGE The Mortgage held by ContiMortgage (thereafter we, us or ours) IS IN DEFAULT as a result of your failure to pay your last 2 monthly installments. Late charges have also accrued to this date. The total amount now required to cure this default or, in other words, get caught up in your payments, as of the date of this letter is $3,337.68. You may cure this default within THIRTY (30) DAYS of the date of this letter by paying to us the amount of $3,337.68 plus any additional monthly payments and late charges which may fall due during this period. Such payment must be made either by cashier's check, certified check or money order, and made payable to: CONTIMORTGAGE CORPORATION P. O. Box 13919 PHILADELPHIA, PA 19101 If you do not cure the default within THIRTY (30) DAYS, we intend to exercise our right to accelerate the mortgage payments. This means that whatever is owing on the original amount borrowed will be considered due immediately and you may lose the chance to pay off the ' original mortgage in monthly installments. If full payment of the amount of the default is not made within THIRTY (30) DAYS, we also intend to instruct our attorneys to start a lawsuit to foreclose your mortgaged property. If the mortgage is foreclosed, your property will be sold by the Sheriff to pay off the mortgage debt. If we refer your case to our attorneys but you cure the default before Krt ?; they begin legal proceedings against you, you will still have to pay 4 the reasonable attorney's fees actually incurred, up to $50.00. However, if legal proceedings are started against you, you will have to pay the reasonable attorney's fees even if they are over $50.00. Any attorney's fees will be added to whatever you owe us, which also may include our reasonable fees. If you cure the default within the thirty (30) day period, you will not be required to pay attorney's fees. We may also sue personally for the unpaid principal balance and all other sums due under the mortgage. ExHiairA 121. ® Pnnml an rtnrial n qvr I '* Con6M' ortgage - One ContiPark • 338 S. Warminster Road - Hatboro, P.a 19040.3430 (888) 820-3411 Asset Management Department Page Two ContiMortgage Loan Number 0004244513 If you have not cured the default within the thirty(30) day period and foreclosure proceedings have begun, you still have the right to cure the default and prevent the sale at any time up to one (1) hour before the Sheriff's foreclosure sale. You may do so by paying the total amount of the unpaid monthly payments plus any late or other charges then due, as well as the reasonable attorney's fees and costs connected with the foreclosure sale (and perform any other requirements under the mortgage). A notice of the date of the Sheriff's sale will be sent to you before the sale. Of course, the amount needed to cure the default will increase the longer you wait. You may find out at any time exactly what the required payment will be by calling us at the following number: 1-888-264-4990. This payment must be in cashier's check, certified check or money order and made payable to us at the address stated above. You should realize that Sheriff's sale will end your ownership of the mortgaged property and your rights to remain in it. If you continue to live in the property after the Sheriff's sale, a lawsuit could start to evict you. You have additional rights to help protect your interest in the property. YOU HAVE THE RIGHT TO SELL THE PROPERTY TO OBTAIN MONEY TO PAY OFF THE MORTGAGE DEBT, OR TO BORROW MONEY FROM ANOTHER LENDING INSTITUTION TO PAY OFF THIS DEBT. [YOU MAY HAVE THE RIGHT TO SELL OR TRANSFER THE PROPERTY SUBJECT TO THE MORTGAGE TO A BUYER OR TRANSFEREE WHO WILL ASSUME THE MORTGAGE DEBT, PROVIDED THAT ALL THE OUTSTANDING PAYMENTS, CHARGES AND ATTORNEY'S FEES AND COSTS ARE PAID PRIOR TO OR AT THE SALE, (AND THAT THE OTHER REQUIREMENTS UNDER THE MORTGAGE ARE SATISFIED). CONTACT US TO DETERMINE UNDER WHAT CIRCUMSTANCES THIS MIGHT EXIST.] YOU HAVE THE RIGHT TO HAVE THIS DEFAULT CURED BY ANY THIRD PARTY ACTING ON YOUR BEHALF. If you cure the default, the mortgage will be restored to the same position as if no default had occurred. However, you are not entitled to this right to cure your in any calendar year. Sincerely, Collection Department Asset Management Division Regular and Certified Mail Enclosure LWPAACT6 ® PrImn m marled pip<r more than three (3) times ExkAIB1T A 'Q PII= Conti Mortgage . , * One ContiPark • 338 S. lVarminster Road • Hatboro, PA 19040.3.130 (888)820.3411 Asset Management Department May 25, 1999 WILLIE C WHITE 173 RIDGE HILL RD MECHANICSBURG, PA 17055 Re: ContiMortgage Loan Number: 0004244513 Property Address 173 RIDGE HILL RD, MECHANICSSU, PA 17055 ACT 91 TAKE ACTION TO SAVE YOUR HOME FROM FORECLOSURE The Commonwealth of Pennsylvania 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 Agency at 1-800-342-2397. La notificacion en adjunto es de suma importancia, pues afecta su derecho a continuar viviendo en su casa. Si no comprende el contenido de esta notificacion obtenga un traduccion immediatamente llamanda esta agencia (Pennsylvania Housing Finance Agency) sin cargos al numero menionada arriba. Puedes ser elegible para un prestamo por el programa llamado. "Homeowner's Emergency Mortgage Assistance Program": el cual puede salvar su casa de la pardida del derecho a redimir su hipoteca. IMPORTANT: NOTICE OF HOMEOWNER'S EMERGENCY MORTGAGE ASSISTANCE ACT OF 1983 PLEASE READ THIS NOTICE. YOU MAY BE ELIGIBLE FOR FINANCIAL ASSISTANCE TOWARD YOUR MORTGAGE PAYMENTS Your mortgage is in serious default because you have failed to pay promptly, your last 2 monthly installments of principal and interest. The total amount of the deliquency is $3,337.68. You may be eligible to financial assistance that will prevent foreclosure on your mortgage if you comply with the provisions of the Homeowner's Emergency Mortgage Assistance Act of 1983 (the "ACT"). You may be eligible for emergency temporary assistance if your default has been caused by circumstances beyond your control, and if you meet the eligibility requirements of the Act as determined by the Pennsylvania Housing Finance Agency. Please read all of the Notice. It contains an explanation of your rights. ® pONnI on rentled piprr Condffortgage - One ContiPark • 338 S. Warminster Road • Hatboro, PA 19040.3430 (888) 820.3411 Asset Ntanagement Department May 25, 1999 ANNA L WHITE 173 RIDGE HILL RD MECHANICSBURG, PA 17055 Re: ContiMortgage Loan Number: 0004244513 Property Address 173 RIDGE HILL RD, MECHANICSSU, PA 17055 ACT 91 TAKE ACTION TO SAVE YOUR HOME FROM FORECLOSURE The Commonwealth of Pennsylvania 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 Agency at 1-800-342-2397. La notificacion en adjunto es de suma importancia, pues afecta su derecho a continuar viviendo en su casa. Si no comprende el contenido de esta notificacion obtenga un traduccion immediatamente llamanda esta agencia (Pennsylvania Housing Finance Agency) sin cargos al numero menionada arriba. Puedes ser elegible para un prestamo por el programs llamado. "Homeowner's Emergency Mortgage Assistance Program": el cual puede salvar su casa de la pardida del derecho a redimir su hipoteca. IMPORTANT: NOTICE OF HOMEOWNER'S EMERGENCY MORTGAGE ASSISTANCE ACT OF 1983 PLEASE READ THIS NOTICE. YOU MAY BE ELIGIBLE FOR FINANCIAL ASSISTANCE TOWARD YOUR MORTGAGE PAYMENTS Your mortgage is in serious default because you have failed to pay promptly, your last 2 monthly installments of principal and interest. The total amount of the deliquency is $3,337.68. You may be eligible to financial assistance that will prevent foreclosure on your mortgage if you comply with the provisions of the Homeowner's Emergency Mortgage Assistance Act of 1983 (the "ACT"). You may be eligible for emergency temporary assistance if your default has been caused by circumstances beyond your control, and if you meet the eligibility requirements of the Act as determined by the Pennsylvania Housing Finance Agency. Please read all of the Notice. It contains an explanation of your rights. EXHIBIT B ® Pnwat "n r,adM pyv, 0 rAw ContiMortgage - One ContiPark - 338 S. Warminster Road - Hatboro, PA 190403430 (888) 820.3411 Asset Management Department Page Two May 25, 1999 ContiMortgage Loan Number 0004244513 Under the Act, you are entitled to a temporary stay of foreclosure on your mortgage for thirty (30) days from the date of this Notice. During that time you have the right to arrange a "face-to-face" meeting with a representative of this lender, or with a designated consumer credit counseling agency. The purpose of that meeting is to attempt to work out a repayment plan or otherwise settle your delinquency. That 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 agent identified in this Notice, no further proceedings in mortgage foreclosure may take place for thirty (30) days after the date of that meeting. The name, address and telephone number of our representative is; ContiMortgage, COLLECTION DIVISION 3, P. O. Box 13919 Philadelphia, PA, 19101, 1-888-264-4990. The name(s), and address(es) of (a) designated consumer credit counseling agency(ies) is(are): SEE ATTACHED LIST It is only necessary to schedule one face-to-face meeting. You should advise this lender immediately of your intentions. If you have tried and are unable to resolve this problem at or after your face-to-face meeting, you have the right to apply for financial assistance from the Homeowner's Emergency Mortgage Assistance Fund. In order to do this, you must fill out, sign and file a completed Homeowner's Emergency Assistance Application with the Pennsylvania Housing Finance Agency. The consumer credit counseling agency will assist you in filling out your application. It must be postmarked within thirty (30) days of your face- to-face meetimg. You must either mail your application to the Pennsylvania Housing Finance Agency, or you must file it at the office of one of the designated consumer credit counseling agencies listed. The Pennsylvania Housing Finance Agency is located at 2101 North Front Street, P. O. Box 8029, Harrisburg, PA 17105, phone number 717-780-3800 or 800-342-2397 (toll free number). An application for assistance may be obtained from this lender, from a consumer credit counseling agency, or directly from the Pennsylvania Housing Finance Agency. It is extremely important that you file your application promptly. If you do not do so, or if you do not follow the other time periods set forth in this letter, foreclosure may proceed against your home immediately. Available funds for emergency mortgage assistance are very limited. They will be distributed by the Agency under the eligibility criteria established by the ACT. IS r,u"nt on ,rndnl pip" EXNJB1T 6 Q MW Contiffortgage One ContiPark a 998 S. Warminster Road • Hatboro, P.a 19040.3490 (888) 820.3411 Asset %tanagement Department Page Three May 25, 1999 ContiMortgage Loan Number 0004244513 It is extremely important that your application is accurate and complete in every respect. The counseling agency will help you to fill out the application. The Pennsylvania Housing Finance Agency has sixty (60) days to make a decision after it receives your application. During that additional time, no foreclosure proceedings will be pursued against you if you have met the time requirements set forth above. You will be notified directly by the Agency of its decision on your application. In addition, you will receive another notice from this lender under Act 6 of 1974. That notice is called a "Notice Of Intention To Foreclose" You must read both notices, since both explain rights that you now have under Pennsylvania law. However, if you choose to exercise your rights described in this notice, we cannot foreclose upon you during that time. Also, if you receive financial assistance from Pennsylvania Housing Finance Agency, your home cannot be foreclosed upon while you are receiving that assistance. Sincerely, Collection Department Asset Management Division Regular and Certified Mail Enclosure LWPAACT91 EXN?g?T B ® rnnnnl on rardnl paper. rAw Pennsylvania Housing Finance Agency Homeowner's Emergency Mortgage Assistance Program Consumer Credit Counseling Agencies (Rev. 5199) L o a C CLLVrON CO L-,VN zli =Las CO a For r Commua mm(asiae ir? Acton (STEP) 2138 L1z=tzj Snlet CCCS of Nor-heastarn P.4L 1631 S Atherton St P. O. Box o: 13 3:9 Suits 100 W(Iliamspor PA 17703 State College. PA 16801 (570) 3_6-0sd7 (814) 238-3668 FAX (5,0) 322.2197 FAX (814) 2384669 CCCS of Norhesstera PA 201 Benin Stmoc P.% 17703 11 y ?82 S FAX (570) 3234628 COLInMIA C0L1TY CCCS of'4orheaetarn Penaevlveni2 31 W. Market Se eac 1400 Abington Exw4tive Park POS Ur' PA 18702 W!Ika•Bara Suite 1 18411 Clarks Sum=it-. PA . (570)821-0837 or(800)922.9537 .9163 or (8(8C0) 9 (570)58"7.9163 22.95J7 _JS FA9 (570) 5a-'-9l3-U2135 FAX (570) 821.1785 Commisaion on Economics Oppor-aalty of Luvuae Count? 163 Amber Lane Wilkss•Barte. PA 18702 (570) 826-0510 or (800) 822-0339 FA''C (570) 829.1665-CALL BEFORE FA-XVG (570) 438-4994 HAZELTON FAX (570) 489.5631--CAL.L BEFORE F-A'G.`1G (570) $364090 TL^-nriA.r-:LOCK Booker T. Washington Canter 1720 Holland Sreet Erie, PA 16503 (814) 453.5744 FAX (814) 433.5749 John F. Kennedy Center, Inc. 2021 East 20th Street Erie, PA 16510 (814) 898-04CO FAX (814) 898.1243 CCCS of Westara Pennsylvania. Inc. 2000 Liag!estown Road Harrisburg, PA 17102 (71) 841.1757 Urban League of M*Iropolitaa Harr-mburj N. 6th Street Har^.sburg, PA 17101 (717) 234-5923 FAX (717) 234.9459 CRAWFORD COLN'rY Greater Erie Community Arlon Co===t-ae 18 West 9th Street Erie, PA 16501 (814) 4594581 FAX (814) 456-0161 Shenanggaa Valley Urban League. Irc 601 Lndlana Avenue Farrell. PA 16121 (412) 981.5310 CUMEERL1.`(D COL.N-N Financial Counseling Ser/ices of Frsrtklin 31 West 3rd Street Waynesboro. PA 17268 (717) 762-3295 YWCA of Carlisle 301 G Street Carlisle, PA 17013 (717) 243.3819 FAX (717) 731.9589 Community Acton Comm of the Capital Region 1514 Dery Street Hamsburt, PA 17104 (717) 2329757 FAX (7,1-,) 234.2227 Ld- Carlisle otuing Authority Cattysburg, PA 17325 (717) 334-1519 F.kv, (717) 3344325 EXHIBIT 6 PENNSYLVANIA BUUXnN, VOL 29. NO. 23, NNE S. 1999 ALL THAT CERTAIN tract of land situated in the Townshipp of Silver Spring, County of Cumberland and Commonwealth of PannaylvaniA, bounded and described as followa: BEGINNING at a point in the cantor line of Township Road T-577 locally known as Aldge Hill Road; thance by property now or formerly of John R. Hair south 14 degrees 25 minutes east 25.02 feet to a stake in the ultimate right-ot-way line of Township Road T-577; thence continuing along land of Hair mouth 14 degrees 25 minutes east 229.20 fast to a stake; thence by land of Shaffer Trucking Company south 73 dagroem 35 minutes 30 eaconds went 200.0 fast to a atakof thence by lands of Pearl Seam north 14 degrees 24 minutes 41 seconds west 228.90 foot to a stake in the ultimate right-of-way of Township Road T-577; thence continuing along lands of Pearl Beam north 14 degrees 24 minutes 41 seconds west 25.02 feet to a point in the canter line of Township Road T-577; thence by said center line north 73 dsgraes 30 minutes eaat 200.0 feet to a point in said center line, the place of BEGINNING. BEING the same premises which EARL L. BEAM, by dead dated August 1, 1977 and recorded in the Office of the Recorder of Deeds for Cumberland County in Deed Hook I, Volume 27, Page 270, granted and conveyed to EARL L. BEAM and KATHY A. BEAM, his wife, grantors herein. PREHISES: 173 RIDGE HILL ROAD VERIFICATION NANCY RAMSEY hereby states that she is FORECLOSURE COORDINATOR of CONTIMORTGAGE MORTGAGE CORPORATION mortgage servicing agent for Plaintiff in this matter, that he/she is authorized to take this Verification, and that the statements made in the foregoing Civil Action in Mortgage Foreclosure are true and correct to the best of his/her knowledge, information and belief. The undersigned understands that this statement is made subject to the penalties of 18 Pa. C.S. Sec. 4904 relating to unsworn falsification to authorities. nn DATE: I ?''?1 ?r n, d'CI:iOF .pEpI,.E OCT 1 2 to P11'99 ., r• C-0OL•u3^ (fit%? CLC?d ?iaUV? U:I ? 1 .' rr?n3Ndaa?r?.;?, PRAECIPE FOR WRIT OF EXECUTION - (MORTGAGE FORECLOSURE) P.R.C.P.3180-3183 Contlmorigage Corporation Cumberland County Plaintiff, V. No. 99-6217 Civil Term Willie C. While Anna L. White Defendant(s). TO THE DIRECTOR OF THE OFFICE OF THE PROTHONOTARY: Issue writ of execution in the above matter: Amount Due Interest from 1/11/00 - 6/7/00 (per diem - $28.24) $171.814.52 $4,179.52 and Costs $175.994.04 TOTAL FRA K FEDE[ A , ESQUIRE TWPENN CENTL?R PLAZA SUITE 900 PHILADELPHIA, PA 19102 Attorney for Plaintiff Note: Please attach description of property.No. N .n M Y ?. N A M G a? a Y) -oa «N a N 93 Q aMa ci G F wa oz? a? a a Ul OV U? ?W F? ?O U a •a° U eo e`°o 0 0 0 U w 3g z O wo O? w y 0t w o U? a N ? ~ M E4 ?. N M ? a ?-1 a ? 3 C t? ^' Y ? M C LEO Y 8 ?q a 3Ma ? Q ,;r . rq t? ALL THAT CERTAIN tract of land situated in the Township of Silver Spring, County of Cumberland and Commonwealth of Pennsylvania, bounded and described as follows: BEGINNING at a point in the center line of Township Road T-577 locally known as Ridge Hill Road; thence by property now or formerly of John R. Hair South 14 degrees 25 minutes East 25.02 feet to a stake in the ultimate right-of-way line of Township Road T-577; thence continuing along land of Hair South 14 degrees 25 minutes East 229.20 feet to a stake; thence by land of Shaffer Trucking Company South 73 degrees 35 minutes 30 seconds West 200.0 feet to a stake; thence by lands of Pearl Beam North 14 degrees 24 minutes 41 seconds West 228.90 feet to a stake in the ultimate right-of-way of Township Road T-577; thence continuing along lands of Pearl Beam North 14 degrees 24 minutes 41 seconds West 25.02 feet to a point in the center line of Township Road T- 577; thence by said center line North 73 degrees 30 minutes East 200.0 feet to a point in said center line, the place of BEGINNING. TAX PARCEL //38-18-1344-034 TITLE TO SAID PREMISES IS VESTED IN Willie C. White and Anna L. White, his wife by Deed from Earl L. Beam and Kathy A. Beam, his wife, dated 12/22/93, recorded 12/27/93, in Deed Book S-36, Page 494. -0:6! w m v? V ` S e't ?J Q I r Nj° 00; ?? ? ??0 0 ?' CT rv) i x kr t 17 Contlmortgage Corporation Plaintiff, CUMBERLAND COUNTY V. COURT OF COMMON PLEAS Willie C. White CIVIL DIVISION Anna L. White Defendant(s). NO. 99-6217 Civil Term AFFIDAVIT PURSUANT TO RULE 3129 (Affidavit No. 1) Contimortenee Corporation, Plaintiff in the above action, by its attorney, FRANK FEDERMAN, ESQUIRE, sets forth as of the date the Praccipc for the Writ of Execution was filed the following information concerning the real property located at 173 Ridge Hill Road. Mechanicsburg, PA 17055. 1. Name and address of Owner(s) or reputed Owner(s): NAME LAST KNOWN ADDRESS (If address cannot be reasonably ascertained, please so indicate.) Willie C. White 331 Los Altos Way Apartment 102 Altamonte Springs, FL 32714-3287 Anna L. White 331 Los Altos Way Apartment 102 Altamonte Springs, FL 32714-3287 2. Name and address of Defendant(s) in the judgment: NAME LAST KNOWN ADDRESS (If address cannot be reasonably ascertained, please so indicate.) Same as above 3. Name and address of everyjudgment creditor whose judgment is a record lien on the real property to be sold: NAME LAST KNOWN ADDRESS (If address cannot be reasonably ascertained, please so indicate.) None 4. 5. 6. Name and address of the last recorded holder of every mortgage of record: NAME LAST KNOWN ADDRESS (if address cannot be reasonably ascertained, please so indicate.) None Name and address of every other person who has any record lien on the property: NAME LAST KNOWN ADDRESS (if address cannot be reasonably ascertained, please so indicate.) None Name and address of every other person who has any record interest in the property and whose interest may be affected by the sale: NAME LAST KNOWN ADDRESS (if address cannot be reasonably ascertained, please so indicate.) None 7. Name and address of every other person whom the plaintiff has knowledge who has any interest in the property which may be affected by the sale: NAME LAST KNOWN ADDRESS (if address cannot be reasonably ascertained, please so indicate.) Tenant/Occupant Domestic Relations of Cumberland County 173 Ridge Hill Road Mechanicsburg, PA 17055 13 North Hanover Street Carlisle, PA 17013 1 verify that the statements made in this affidavit arc true and correct to the best of my personal knowledge or information and belief. I understand that false statements herein arc made subject to the penalties of 18 Pa. C.S. Sec. 4904 relating to unswom falsification to authorities. febmarv 16.2000- DATE r K FED'RMAy ,ESQUIRE Att mey for Plaind t G ? ?7 l r?? to N ?! ra ["t CID V FEDERMAN and PHELAN By: FRANK FEDERMAN Identification No. 12248 Suite 900 Two Penn Center Plaza Philadelphia, PA 19102 (215) 563-7000 Contimortgage Corporation Plaintiff, V. Willie C. White Anna L White Defendant(s). ATTORNEY FOR PLAINTIFF CUMBERLAND COUNTY COURT OF COMMON PLEAS CIVIL DIVISION NO. 99-6217 Civil Term CERTIFICATION FRANK FEDERMAN, ESQUIRE, hereby verifies that he is attorney for the Plaintiff in the above-captioned matter, and that the premises arc not subject to the provisions of Act 91 because it is: () an FHA mortgage () non-owner occupied O vacant (X) Act 91 procedures have been fulfilled This certification is made subject to the penalties of 18 Pa. C.S. Section 4904 relating to unswom falsification to authorities. F K FEDERMA* ESQUIRE Attorney for PI ' (tiff ,r OI ? ' l^, (r . t C.: . ; t i ( J,,, )::? r? r?, t N ?f (C, T '?,; ;?] ?? ?y 1_, Y r Contimortgage Corporation CUMBERLAND COUNTY Plaintiff, V. No. 99.6217 Civil Term Willie C. White Anna L. White Defendant(s). February 16, 2000 TO: Willie C. White Anna L. White 331 Los Altos Way Apartment 102 Altamonte Springs, I'L 32714-3287 "THIS FIRM IS A DEBT COLLECTOR ATTEMPTING TO COLLECT A DEBT AND ANY INFORMATION OBTAINED WILL BE USED FOR THAT PURPOSE. IF YOU HAVE PREVIOUSLY RECEIVED A DISCHARGE IN BANKRUPTCY AND THIS DEBT WAS NOT REAFFIRMED, THIS IS NOT AND SHOULD NOT BE CONSTRUED TO BE AN ATTEMPT TO COLLECT A DEBT, BUT ONLY ENFORCEMENT OF A LIEN AGAINST PROPERTY." Your house (real estate) at 173 Ridge Hill Road. Mechanicsburg, PA 17055, is scheduled to be sold at the Sheriffs Sale on June 7. 2000 at 10:00 a.m. in the Cumberland County Courhtouse , South Hanover Street, Carlisle, PA 17013, to enforce the court judgment obtained by Contimortgage Corporation (the mortgagee) against you. If the Sheriffs sale is postponed, the property will be relisted for the Sheriffs Sale. NOTICE. OF OWNER'S RIGHTS YOU MAY BE ABLE TO PREVENT THIS SHERIFF'S SALE To prevent this Sheriffs Sale, you must take immediate action: The sale will be cancelled if you pay to the mortgagee the back payments, late charges, costs and reasonable attorney's fees due. To find out how much you must pay, you may call: (215) 563-7000. 2. You may be able to stop the sale by filing a petition asking the Court to strike or open the judgment, if the judgment was improperly entered. You may also ask the Courtto 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.) 1. If the Sheriffs Sale is not stopped, your property will be sold to the highest bidder. You may find out the price bid by calling (215) 563-7000. 2. You may be able to petition the Court to set aside the sale if the bid price was grossly inadequate compared to the value of your property. 3. The sale will go through only if the buyer pays the Sheriff the full amount due in the sale. To find out if this has happened, you may call (717) 240-6390. 4. If the amount due from the Buyer is not paid to the Sheriff, you will remain the owner of the property as if the sale never happened. 5. You have the right to remain in the property until the full amount due is paid to the Sheriff and the Sheriff gives a deed to the buyer. At that time, the buyer may bring legal proceedings to evict you. 6. You may be entitled to a share of the money which was paid for your house. A schedule of distribution of the money bid for your house will be filed by the Sheriff within 30 days of 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 the 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. CUMBERLAND COUNTY ATTORNEY REFERRAL CUMBERLAND COUNTY BAR ASSOCIATION 2 LIBERTY AVENUE CUMBERLAND COUNTY COURTHOUSE CARLISLE, PA 17013 (717) 249-3166 (800)990.9108 DESCRIPTION ALL THAT CERTAIN tract of land situated in the Township of Silver Spring, County of Cumberland and Commonwealth of Pennsylvania, bounded and described as follows: BEGINNING at a point in the center line of Township Road T-577 locally known as Ridge Hill Road; thence by property now or formerly of John R. Hair South 14 degrees 25 minutes East 25.02 feet to a stake in the ultimate right-of-way line of Township Road T-577; thence continuing along land of Hair South 14 degrees 25 minutes East 229.20 feet to a stake; thence by land of Shaffer Trucking Company South 73 degrees 35 minutes 30 seconds West 200.0 feet to a stake; thence by lands of Pearl Beam North 14 degrees 24 minutes 41 seconds West 228.90 feet to a stake in the ultimate right-of-way of Township Road T-577; thence continuing along lands of Pearl Beam North 14 degrees 24 minutes 41 seconds West 25.02 feet to a point in the center line of Township Road T- 577; thence by said center line Notch 73 degrees 30 minutes East 200.0 feet to a point in said center line, the place of BEGINNING. TAX PARCEL //38-18.1344-034 TITLE TO SAID PREMISES IS VESTED IN Willie C. White and Anna L. White, his wife by Deed from Earl L. Beam and Kathy A. Beam, his wife, dated 12/22/93, recorded 12/27/93, in Deed Book S-36, Page 494. r: tY f .. ? ?1•?J ,llt) : tom. tl ,.r tL r.. 1 e- FF.DERMAN AND PHELAN By: FRANK FEDERMAN, ESQUIRE IDENTIFICATION NO. 12248 TWO PENN CENTER PLAZA, SUITE 900 PHILADELPHIA, PA 19102 (215) 563-7000 Contimortgage Corporation V. Willie C. White Anna L.White ATTORNEY FOR PLAINTIFF COURT OF COMMON PLEAS CIVIL DIVISION NO.99-6217 Civil Cumberland COUNTY AFFIDAVIT OF SERVICE OF NOTICE OF SHERIFF'S SALE PURSUANT TO P.R.C.P., 404(2)/403 FRANK FEDERMAN, ESQUIRE, Attorney for Plaintiff, hereby certifies that service of the Notice of Sheriff's Sale was made by sending a true and correct copy by certified mail to Defendant, Anna L.White at331 Los Altos Way Apt. 102 Altamonte Springs, F1.32714-3287 which notice of Sheriff's Sale was received by Defendant,Anna L. White on February 22, 2000 as evidenced by the attached return receipt. The undersigned understands that this statement is made subject to the penalties of 18 PA C.S. s 4904 relating to unsworn falsification to authorities. , -ESQUIRE Date: March 2, 2000 I,e I 1/ 19/2000 Willie & Anna White Federman & Phelan I D # 12248 Two Pen Center Plaza Suite 900 Phila., Pa. 19102-1799 Attwnq for Plaintiff ( Conti Mongagc Corp) C/O Frank Federman. Esaire: Once again we are sending you a copy of a legal doc. releasing the property At 173 Ridge Hill Road Mechanics, Pa. 17055, Silver Spring Township Cumberland County back to Conti Mortgage Corp. This is a legal Doc. Signed And dated by a license Notary Public who term don't expire until Juno 10, 2003. This Doc. Give your "Plaintiff" the right bylaw to sell this property for the amount The amount that was due on the property at the time that this document Was drawn up. Which at that time was S 154,889.00. What over the mortgage company Get over that amount; belongs to the Mortgage Company, If they want your company to eat That money up is their problem. This document was dated back on 9/13/99. Tho mortgage Company received this notice ten days later. Giving them the right to sell the property. They Didn't need an attorney to get them permission to sell that property. They already had that right. So your attorney foe is Conti Mortgage Corporation's Bill. Mr. Frank Federman; that property belong to Conti Mortgage and what over they want you to Do with it is up to them. As of September 13, 1999 the document released my wife and myself From the ownership of this property and gave the mortgage company the rightful ownership. For the records of the Court of Common Pleas, Civil Division Cumberland COUNTY # 99-6217- CIVIL TERM. (PleaSo kmp a copy ofthia lerler and Jowmmt wih the cloud to the property of" 173 Ridsu Ilill Road - Meohanlabur& Pa. Silm SprinS Townfiip - Cumberland Couray ") CUMBERLAND COUNTY couKr HOUSE: CAMBIA-,, PA. 17013 Conti Mortgage Co. 338 it drurinster Road 1larsboro, Pa. 1911411-3430 11111le C. 11111ite Anna L. 119hlte 173 Ridge !Hill Road Jkchanicshurg, P« 171155 1 1{9111e C. 111dife, tmd:lmnr L. White: Due to reasons that 1ve both are disable and elite to the reason Nrrtf 1ve both ure unable to work or hold any position that is pertaining to work.: lid had to stop worlring the job that we were working (it the tittle we obtain this mortgage dire to serious burly injury and illness that disallowed us to shake enough looney to coyer the mortgage note, we hearty sign this pr•operti' which is located «t: 17.5 R!rlge Hill /load _fllech. Pit 17055 Silver.S'pring Township Cumberland County Back to the mortgage holder, which is chiller!, Conti tllortgage C'ompahil' 338 fl'arminster Roud Ilulsboro, I'll. 19010-3430 Signature Sighudrrre?,.?? Ze /date././ Sirnutrrrc p"ifn? s?l%???:l'Iyi ?,,,;I/.?i (Sea!) , I:[glliP.!7;L:n F:d i.;;Jun^ ICI, :;uUJ ,...r flan, n ' This is done due to the reason that i r %cdu nrrlr)n};er'nlfirWf`trl?lrry' the nutrtgages, which is higher than both ojour disability annuity combines. We rnnderstand rhrrt Isle on•e Conti Mortgage Co. S1.50.0011 .00 and inn 1997 this property airs appraise «t S1 NRIa10. all. We understand that there is it profit to be aurde oljtre pruperrv Ina we fire ashing Jor none. i{ c cull' reckad that our gruel Jinidr uunre is clc«rcrl Jruur the drjurdt undJirrrclusing nutrtgfigc uJler the pruperrv lens been soh! ord the S15n,lIfliG ll/l has been paid. By .%egtring this NOTE release us,jronr this property courplelely and give Conti Morigage the right to sell this property and retain their rnonfes that is due to then. Thd, NOTE also releases u, ftont the upkeep of this property and makes Conti b/orfguge reeponsihle for tte upkeep of this properV..Such as cutting the grass and any other maintenance that is needed. FEDERMAN AND PHELAN By: FRANK FEDERMAN Identification No. 12248 Two Penn Center Plaza - Suite 900 Philadelphia, PA 19102 (215) 563-7000 Contimortgage Corporation One Contipark, 338 South Warminster Road Hatboro, PA 19040 Plaintiff VS. Willie C. White Anna L. White 331 Los Altos Way, Apartment 102 Altamonte Springs, FL 32714-3287 Defendant(s) Attorney for Plaintiff : Cumberland COUNTY : COURT OF COMMON PLEAS : CIVIL DIVISION :NO. 99-6217-CIVIL TERM PRAECIPE FOR JUDGMENT FOR FAILURE- TO ANSWER AND ASSESSMENT OF DAMAGES TO THE PROTHONOTARY: Kindly entcrjudgmcnt in favor of the Plaintiff and against Willie C. White and Anna L. White, Defendant(s), for failure to file an Answer to Plaintiffs Complaint within 20 days from service thereof and for foreclosure and sale of the mortgaged premises, and assess Plaintiffs damages as follows: As set forth in Complaint Interest 7/1/99 to 1/l l/00 $164,474.72 7$ ,339.80 TOTAL $171,814.52 I hereby certify that (1) the addresses of the Plaintiff and Defendant(s) arc as shown above, and (2) notice has been given in accordance with Rule 237. 1, copy attached. 1?4" h&'w [tiy FRANK FEDERMAN, ESQUIRE Attorney for Plaintiff DAMAGES ARE HEREBY ASSESSED AS INDICATED. DATE: 1?. -')6oO / PRO PROTI --TIIIS FIRM IS A DEBT ('01.1.E(-rOR ATTEMPTING TO ('OI.LI:(-r A DEBT AND ANY INFORMATION OBTAINED WILL RE USED FOR TIIAT P('RPOSE. IF YOU ILWE PRF.%'101'SI.Y RE('F:n'F.I) A DIS('IIAR(;E IN IIANKRPPT(.Y AND TIILS DEBT WAS NOT RFAFFIR\IEI). TII IS ('ORRESPONDF.N('E IS NOT AND SIIOCLD NOT BE CONSTRUED TO BE AN ATTEMPT TO COLLECT A DEBT, BUT ONI.Y F.NFOR('F.S(ENT OF A I.IF.N A(LUNST PROPERTI'. •. 1 O ui5 r'• b N °_- n a o 0 FEDERMAN AND PHELAN Frank Federman, Esquire Identification No. 12248 Two Penn Center Plaza Suite 900 Philadelphia, PA 19102-1799 (215) 563-7000 CONTIMORTGAGE CORPORATION Plaintiff Vs. WILLIE C. WHITE ANNA L. WHITE Defendant(s) TO: WILLIE C. WHITE 331 LOS ALTOS WAY, ALTAMONTE SPRINGS, ATTORNEY FOR PLAINTIFF COURT OF COMMON PLEAS . CIVIL DIVISION CUMBERLAND COUNTY NO. 99-6217-CIVIL TERM APARTMENT 102 FL 32714-3287 DATE OF NOTICE: DECEMBER 27. 1999 THIS FIRM IS A DEBT COLLECTOR ATTEMPTING TO COLLECT A DEBT. ANY INFORMATION WE OBTAIN WILL BE USED FOR THAT PURPOSE. IF YOU HAVE PREVIOUSLY RECEIVED A DISCHARGE IN BANKRUPTCY, THIS CORRESPONDENCE IS NOT AND SHOULD NOT BE CONSTRUED TO BE AN ATTEMPT TO COLLECT A DEBT, BUT ONLY ENFORCEMENT OF A LIEN AGAINST PROPERTY. You are in default because you have failed enter a written appearance personally or by attorney and file in writing with the court your defenses or objections to the claims set forth against you. Unless you act within ten (10) days from the date of this notice, a Judgment may be entered against you without a hearing and you may lose your property or other important rights. You should take this notice to a lawyer at once. If you do not have a lawyer or cannot afford one, go to or telephone the following office to find out where you can get legal help: CUMBERLAND COUNTY CUMBERLAND COUNTY BAR ASSOCIATION 2 LIBERTY AVENUE CARLISLE, PA 17013 (717) 239.3166 Frank Federman, Esquire Attorney for Plaintiff ? • ?? ? a > ? .. ? ? ? ? f: ? _ ;, { ._ ? ?+ F . ? 1 FEDERMAN AND PHELAN Frank Federman, Esquire Identification No. 12248 Two Penn Center Plaza Suite 900 Philadelphia, PA 19102-1799 (215) 563-7000 CONTIMORTGAGE CORPORATION Plaintiff VS. WILLIE C. WHITE ANNA L. WHITE Defendant TO: ANNA L. WHITE 331 LOS ALTOS WAY, ALTAMONTE SPRINGS, ATTORNEY FOR PLAINTIFF COURT OF COMMON PLEAS . CIVIL DIVISION . CUMBERLAND COUNTY . NO. 99-6217-CIVIL TERM APARTMENT 102 FL 32714-3287 DATE OF NOTICE: DECEMBER 27. 1999 THIS FIRM IS A DEBT COLLECTOR ATTEMPTING TO COLLECT A DEBT. THIS NOTICE IS SENT TO YOU IN AN ATTEMPT TO COLLECT THE -INDEBTEDNESS REFERRED TO HEREIN, AND ANY INFORMATION OBTAINED FROM.YOU WILL BE USED FOR THAT PURPOSE. You are in default because you have failed enter a written appearance personally or by attorney and file in writing with the court your defenses or objections to the claims set forth against you. Unless you act within ten (10) days from the date of this notice, a Judgment may be entered against you without a hearing and you may lose your property or other important rights. You should take this notice to a lawyer at once. If you do not have a lawyer or cannot afford one, go to or telephone the following office to find out where you can get legal help: CUMBERLAND COUNTY CUMBERLAND COUNTY BAR ASSOCIATION 2 LIBERTY AVENUE CARLISLE, PA 17013 (717)249.3166 Frank Federman, Esquire Attorney for Plaintiff k C) FEDERMAN and PHELAN By: FRANK FEDERMAN Idcntificalion No. 12248 Suite 900 Two Penn Center Plaza Philadelphia, PA 19102 (215) 563-7000 Attorney for Plaintiff Conlimortgage Corporation Plaintiff VS. Willie C. White Anna L. White Defendant(s) : Cumberland COUNTY : Court of Common Pleas : CIVIL DIVISION : NO. 99-6217-CIVIL TERM VERIFICATION OF NON-MILITARY SERVICE FRANK FEDERMAN, ESQUIRE, hereby verifies that he is attorney for the Plaintiff in the above-captioned matter, and that on information and belief, he has knowledge of the following facts, to wit: (a) that the defendant(s) is/are not in the Military or Naval Service of the United States or its Allies, or otherwise within the provisions of the Soldiers' and Sailors' Civil Relief Act of Congress of 1940, as amended (b) that defendant Willie C. While is over 18 years of age and resides at 331 Los Altos Way, Apartment 102, Altamonte Springs, FI.32714-3287. (c) that defendant Anna L. White is over 18 years of age, and resides at 331 Los Altos Way, Apartment 102, Altamonte Springs, FL 32714-3287. This statement is made subject to the penalties of 18 Pa. C.S. Section 4904 relating to unswom falsification to authorities. -&&jj myww FRANK FEDERMAN Attorney for Plaintiff i a 9?j ?. '457 4 v? 0 ?S Y 1 J (Rule of Civil Procedure No. 236 - Revised) Contimortgage Corporation : Cumberland COUNTY Plaintiff : Court of Common Pleas VS. : CIVIL DIVISION Willie C. White :NO. 99-6217-CIVIL TERM Anna L. White Defendant(s) Notice is given that a Judgment in the above captioned matter has been entered against you on January 14 .2000. By? DEPUTY If you have any questions concerning this matter, please contact: FRANK FEDERMAN, ESOUIRE Attorney for Filing Party SUITE 900 TWO PENN CENTER PLAZA PHILADELPHIA. PA 19102 (215) 563-7000 "THIS FIRM IS A DEBT COLLECTOR ATTEMPTING TO COLLECT A DEBT AND ANY INFORMATION OBTAINED WILL BE USED FOR THAT PURPOSE. IF YOU HAVE PREVIOUSLY RECEIVED A DISCHARGE IN BANKRUPTCY AND THIS DEBT WAS NOT REAFFIRMED, THIS IS NOT AND SHOULD NOT BE CONSTRUED TO BE AN ATTEMPT TO COLLECT A DEBT, BUT ONLY ENFORCEMENT OF A LIEN AGAINST PROPERTY. •• .. LLi n s f s ?? fill '- o n 'b9.. 235 SOUTH 13TH STREET PHILADELPHIA, PA 19107 Mil"Iphla PHONE: 12161648-7400 Aucwwn d B*R FAX: 215.985.0169 1`14,awm l 1'ncr, 4rvcn Seedcea ro..tofeeeloruL Inc. AFFIDAVIT OF SERVICE ' 331 Los Altos Way Apartment 0102 Altamonte Spr9s FL 32/714-3287 Court of Common Pleas Type of Service Notice of Real Estate ;ale SERVE BY: March 13, 2000 Accepted y: Served and made known tW i I 1 i e C. white / ? _yr li?a on the day of o'clock, M,I lommonwealth of Pennsylvania, in the manner described below: Defendant(s) personally served. Adult family member with whom said Defendantle) reside(s). Relationship Is ' Adult In charge of Dofendant's residence who refused to give name or relationship Manager/Clerk of placing of lodging in which Defendant(s) reside(s). _ Agent or person In charge of Defendant's office or usual place of business. Posted Other DESCRIPTION AGE -HEIGHT ?WEIGHT ??? RACE SEX G ------- On the day of 19_, at o'clock, _M., Defendant not found: Moved Unknown No Ans Vacant Other DEPUTIZED SERVICE Now, this day of , 19__, I do County to serve this _Surrii and make return therof and arcordirlt7 to Lana. hereby deputize the Sheriff of _^Complaint Other By (Competent Adult) County Shoriff's Check 2 **;I Special Instructions rrt Routine 1 of ,'_ Process Serve(' being duly sworn according to law, deposes and says that he/she Is process tamer herein names; and that the facts herein set forth above are true and correct to the best of their knowledge, Information and belief. Sheriff _ Process Server Competent Adl Law Firr?oderman 3 Plrr,lArl -?--- Attorney's Namrf rank 17 edermarl, I sguii Address Su i tf_• 900 Iwo Pr ? l l l l Phhiiladelp-tia PA 1910:' _ Telephone fs! E,6 d- Identification 0 IM Philadelphia Atom. of ProNulontl Process fivvo, Row t Forl-' l It i r i t. r•nt?r•r Pint,; ? CC INC. Da t•: PRO PR( 1UIWr 7, :000 DATE Sworn to & subscribed, day of a..I T 235 SOUTHa13TH STREET PHILADELPHIA, PA 19107 Philadelphia PHONE: 1215) 548.7400 A"isth,n a( FAX: 216.985.0169 Pn*vl rui Priem Saturn AFFIDAVIT OF SERVICE - ST _. ,1 _f ; 331 Los Altos, Way Apartment 0102 Altamonte Sprgs FL 32'14-3287 Court of Common Fleas Type cl` Service Floti,.C, of -Rual Estate Sale SERVE BY: March 1.4. 2000 rLXo3: ?srved and made known tbll_i_ 1_3_e C : W h i t Accept /w/l1ip.-1 lc?? K{ II G r If the day of ep- ei ?3 / o'clock, M., :ommonwealth of Pennsylvania, In the manner described below: Defendant(s) personally served. W 1, N Adult family fnombsr. vithi tam said Defendant(s) reddels), Relationship le\ 'enq J/ Adult In charge of D4fendisk fesldence who refused to give name or relationship s? n?NRYF, cf Manager/Clark of pl}?Ing of IDFQIng in which Defendant(s) resides). r `£ D C Copy Agent or person In charge of [?endant's office or usual place of business. s1 URN Posted !? Other DESCRIPTION AGE HEIGHT ?61EI(,w ??v L r+riCt?? y' EX act. ^..ee?sa??=a?__,¢-.^._. xr.. c. _.. .. _..zcar sa._. _._..-r_?...c rc_ _xR??_ _. _:.-_e >r e.•. ecz-aavaem On thr• -; dgrr °r- Defendant ir5t found: d 4?ERMA?vA?!`'1(-k , vacant ,()thc•r ?iTT!rRJN?pEY fllF 7 aaxvz_:_ =a.?.:._-_eo._.-ce-_____....:_,__eca. c eyS.. 3rria ?_z7:In _.c.e aa: ,-c: c:c cav r.«e c: cetx :a=s Luc DEPUTIZED 01ERl'1CE Now, this .__._. day of 1''+.-_ I ,I,: i)r^I .;ti .ic^PUtize, ).he I if! of _-County t?, ?ervtthis' _ ;Utnfnorls _,_-i om,'lalnt - OLIlt- and make return therr:f and ,ac.ura;n7 lc L.s,w. - Ely (Corroet.ent Adu1L) +y» Spacial In ,tructions a,.s Rout.ino I of ME OF SERVER ocess Sere-•r \S..w, orn to III subscribed 11fors me this b i d l di l " day of? e ng u y sworn accor ng t aw, „f BByBf?? HlrOhf` 1 rn° Of was and aye that he/she Is process carver herein name;; and r @,c met" t 979 I the fads herein set forth above are true and correct to the beet of o i knowledge, Information and belle(. nu 'f OF ,v A1.hNT,f Fi tt 1 .111C-• Process Server? iff 61 ' (r Competent Ad t r , rFlrm. de IIn aI I Ph,?It1;I -' ATTEST' le Date trney'sNamJ PRO PROTHY tress sphone e''' Identification DATE ' 00 Philadelphia Aaaac, of Prvfeaalonal Proaau Sams Rea t 5 1 `c?t x %r! i ^ „s c N a x . j t CI CW) 4 i 3 ,.;eq . 7l 4 i 1 'TT IM y tt yy, , M:v z i r t't:r z, -te : r ! ,.".., V AFFIDAVIT OF SERVICE PLAINTIFF Contimortgage Corporation DEFENDANT(S) Willie C. White Anna L. White SERVE AT 331 Los Alton Way Apartment 102 Altamonte Springs, FL 327143287 SERVED Cumberland County No.99-6217 Civil Term Type of Action - Notice of Sheriff's Sole Sale Date: June 7, 2000 Served and made known to Defendant, on? the day of ? '200,0 o'. ?/L ?. Commonwealth at?% o'cloc., at le-, ? of Pennsylvania, in the manner described below: Defendant personally served. Adult family member with whom Defendant(s) reside(s). Relationship is Adult in charge of Defendant(s)'s residence who refused to give name or rely nship. Manager/Clerk of place of lodging in which Defendant(s) reside(s). Agent or person in charge of Defendant(s)'s office or usual place of business. an officer of said Defendant(s)'s company. Other: Description: Age Height a Weight Race 7 'Ses a Other 1, a competent adult, being duly sworn according to law, depose and state that I personally handed a true and correct copy of the Notice of Sheriffs Sale in the manner as set forth herein, issued in the captioned case on the date and at the address indicated above, ,,..u.___.. Sworn to and before me this of Notary,_ On the Moved Other: I w..trtC. 20Z! ," ATLANTIC DOD PC /. BY: /IZ it%LClln`r ?L lftc7?? / NOTSERVED day of 1 , 200_, at Unknown _ No Answer Sworn to and subscribed before me this _ day of .200 _ Notary: By: Attorney for Plaintiff Frank Federman. Esquire - I.D. No. 12248 Two Penn Center Plaza, Suite 900 Philadelphia, PA 19102 (215)563.7000 o'clock _.m.. Defendantl4OT FOUND because: _ Vacant ti W``' R N a- ?y F ? Z 11 CJ r L AFFIDAVIT OF SERVICE PLAINTIFF Contimortgage Corporation DEFENDANT(S) Willie C. White Aaoa L. White SERVE AT 331 Los Altos Way Apartment 102 Altamonte Springs, FL 32714-3287 SERVED Cumberland County No.99-6217 Civil Term Type of Action - Notice of Sheriff's Sale Sale Date: June 7, 2000 Served and made known to X :/Zhl' , Defendant, on the 70//- day of 200r) at o'clock m., at Z, /,4 . 7`t /1..7 9 mmonwealth of Pennsylvania, in the manner described below: ?C_c4? Defendant personally served. Adult family member with whom Defendant(s) reside(s). Relationship is Adult in charge of Defendant(s)'s residence who refused to give name or relationship. Manager/Clerk of place of lodging in which Defendant(s) reside(s). Agent or person in charge of Defendant(s)'s office or usual place of business. an officer of said Defendant(s)'s company. Other. Description: Age5J?f4 Height" Weight( RaceEyV'c'C_7 Other I, , a competent adult, being duly sworn according to law, depose and state that I personally handed a true and correct copy of the Notice of Sheriffs Sale in the manner as set forth herein, issued in the captioned case on the date and at the address indicated above. Sworn to and t before me this of Notary: On the day of Moved _ Unknown _ No Answer Other: Sworn to and subscribed before me this _ day of 200 Notary: By: Attorney for Plaintiff Frank Federman, Esquire - I.D. No. 12218 Two Penn Center Plaza, Suite 900 Philadelphia, PA 19102 (215)563.7000 NOTSERVED at o'clock _.m., DefendantliOT FOUND because: _ Vacant P qp N cm, t f T S Cp O IN THE COURT OF COMMON PLEAS OF CUMBERLAND COUNTY, PENNSYLVANIA CONTIMORTGAGE CORPORATION Plaintiff CIVIL DIVISION VS. No. 99-6217 CIVIL WILLIE C. WHITE ANNA L. WHITE Defendants AFFIDAVIT OF SERVICE PURSUANT TO RULE 3129 COMMONWEALTH OF PENNSYLVANIA SS: CUMBERLAND COUNTY I, FRANK FEDERMAN, ESQ., attorney for CONTIMORTGAGE CORPORATION, hereby verify that on FEBRUARY 18. 2000, true and correct copies of the Notice of Sheriffs Sale were served by certificate of mailing to the recorded lienholder(s), and any known interested party, see Exhibit "A" attached hereto, and the Notice of Sale was sent to defendant(s) on FEBRUARY 18, 2000 by first class mail and certified mail return receipt requested, see Exhibit "B" attached hereto. FRANK F DERMAN, ESQUIRE Attorney for Plaintiff Date: April 28, 2000 I z 110 gad w Q O {p e' 4. (; d a S? ? Y L' z<o l 0 V A p 3 `o ? u? tn 0 o a 3 C z 4 W I n t ?. ? " > z ? t a , ~ 3 .? ? = V • • Li vv j g ? ?z Qz n z ? u z wn = m U ? ty 4 z ? a f•? r - oc z `off N M R h •O 1_ 00 D` O ? N M R h - SENDER: 1 also wish to receive the t cletce Mm at nyy / py ?O'r• Rnv¢lW Dear Idb wlrq emvkee (for an extra !eel: . . ml? n W Wdees on en I of dM loan W that w tan mwn Ilw .V ( ( • Much eve km b"f w d dv m.bra. w W M bn A Wb• doe, W M ,a ](1 Restricted Delivery : • TN RWIn R•Ce•1 wd enaw to wlwe"eritle wait deKwed W4 r a den Oobwnd f`M... .?...t....t.. 1w t.. AMU L. WHITE 331.1!36-ALTOS VAT AP8ZUW 102 A1.TA?I M. SPtt1=i• Fl. 32714-3287 p ?? r. P 973 738 685 X CERTIFIED 7. Date of Delivery / PSPORMpts1t7t1"ember 19164 1 1 11 11 if !1 II 11 uoingspclnec}trn,rtPcetpt SENDER: 1 also wish to recopy the • rl.a eo.„rVO w wlr'•0•' Re1b,rwd D~r Idbwirq services (for an extra feel • PM1 pI w ad adios on e• r•grp der twnl W dui M ran rerun dr cord b pu. • ul.dl er ra,n b a tray a dr mrMu. w m dv o.a / e•et eon na d.int Restricted Delivery • TV* Reeen±ceq wa Now b wlwn"erode wY deMeed •n: n. dd• d@W%vd DOfISUtt oostmasler 101 lee. t3rc{e X.. to: 41 I WILIJW C.- MMITL 331 WS ALTOS NAY at ATARVJW 102 AI.TAF'3) n •aPR1m. n 32714-0287 ,p7. or PSF 3811 M5 . t P 973 738 684 i. Service type X CERTIFIED Date of r ) 0 Domestic Return F E xt VUCr[O L[lrvln. S CE P AECE!PT W CE ilxr/F?rF[•rin W.n(;lrr -0 0 SE A rruE P:tiikE Uq ?tE+ - TMM4 SENT TO: IZT ro.... iuu . r_ . L!.llt::. P dTE. M1 AP.:; TT ?:\T :v. a 4A K [ PS FORM 3800 US Postal Service Receipt for Certified Mail P :rut - nEruar, _ Ln aCCEwT POSTAWK ON GATE a[:rxcrro atu.[w RD SERVICE CtnT+CDnE•MTWUn2[rr • rovE rcswt .rants w SENT TO: Ror roux. iwrrowE rta m r Af4*4 1'. r?pc 1j, m 331 Ta•:, A T'G" :AY r Cr Ars: tai tn? r c Ai.LC Qt1l!?./lTg SiRI;iCS, Ft. 32-0,14 3217 WIK PS FORM 3800 US Postal Service Receipt for Certified Mail i ?I S? N L 7 L11 >- Q ?l? r. 7L' C) U . 1 STATE OF PENNSYLVANIA, t COUNTY OF CUMBERLAND J SS. Robert P Ziegler I? -----------------------------------------------------------------------------_ Recorder of Deeds in and for said County and State do hereby certify that the Sheriff's Deed in which ---------------- Mark D 6 Julie A Carpenter ---------------------------•-------------------------------------------------------- is the grantee the same having been sold to said grantee on the ---- Zl:h___________ day of -----------June ----------------------- A. D,, 1Sx2000 _' under and by virtue of a writ______________ Execution 22nd -------------------------------°---- issued on the ------------------------------°----- February 2000 day of ------- --------- A. D., t'?_____, out of the Court of Comman Pleas of said County as of ------------ Civil ----------• -------------------------------------------------- Term, 19- 99------ Number ------ 6217___ at the suit of __Cont[mortgapte Core_______________________________________ W111ia ------- against ------------°--- C -° 6 -- Anna ------ L -- Whi-----t-e --------------° u 466 duly recorded in Sheriff's Deed Book No. ___ 225 _ ___, Page ------------ IN TFSTBIONY IVHEREOF, I have hereunto set my hand and seal of said office this _-_day _??4C? Rew er of Deeds IeW- Btewlw d D" Qt idirbW 00 try (ltrlhfs, PA w Cow" L*M tlM fltM *Wq M Jea, 20 Contimortgage Corporation In the Court of Common Pleas of -vs- Cumberland County, Pennsylvania Willie C. White and Anna L White No. 1999 6217 Civil R. Thomas Kline, Sheriff, who being duly sworn according to law, says on March 29, 2000 at 3:25 o'clock P.M. EST, he posted a copy of Real Estate Writ Notice Poster and Description in the above entitled action on the property of Willie C. White and Anna L. White located at 173 Ridge Hill Road, Mechanicsburg, Cumberland County, Pennsylvania according to law. R. Thomas Kline, Sheriff who being duly sworn according to law, says he served the above Real Estate Writ Notice Poster and Description in the following manner: The Sheriff mailed a notice of the pendency of the action to one of the within named defendants to wit: Willie C. White by First Class Mail to his last know address 331 Los Altos Way, Apt 102, Altamonte Springs, Fl. This letter was mailed under the date of March 30, 2000 and never returned to the Sheriffs Office. R. Thomas Kline, Sheriff, who being duly sworn according to law, says he served the above Real Estate Writ Notice Poster and Description in the following manner: The Sheriff mailed a notice of the pendency of the action to one of the wihtin named defendants to wit: Anna L. White by First Class Mail to her last known address 331 Los Altos Way Apt 102, Altamonte Springs, Fl. This letter was mailed under the date of March 30, 2000 and never returned to the Sheriffs Office. R. Thomas Kline, Sheriff, who being duly sworn according to law, says that after due and legal notice had been given according to law, exposed the within described premises at public venue or outcry at the Court House, Carlisle, Cumberland County, Pennsylvania on June 7, 2000 at 10:00 o'clock A.M. EDST, and sold the same for the sum of $ 90,000.00 to Mark D. & Julie A. Carpenter. It being the highest bid and best price received for the same Mark D. & Julie Carpenter of 174 Ridge Hill Road, Mechanicsburg being the buyers in this execution paid to sheriff R. Thomas Kline the sum of $ 95,554.20, it being bid price plus costs. Sheriffs Costs Docketing 30.00 Poundage 1,800.00 Posting Bills 15.00 Advertising 15.00 Acknowledging Deed 30.00 Auctioneer 10.00 Law Library .50 County 1.00 Mileage 3.72 Certified Mail 1.01 Levy 15.00 Surcharge 30.00 Legal Search 200.00 Law Journal 274.70 Patriot News 234.53 Share of Bills Distribution of Proceeds Sheriff's Deed Sworn and Subscribed To Before Me 24.80 25.00 26.50 $ 2,736.76 Pd By Purchaser 6/28/00 This .tyI`= Day of So an- 2000,A. D. +VR. Thomas Kline, Sheriff I'Mothonotary By P ?•at_ Real Estate Deputy Vo ?o ?X:? Cfe.291er1 SCHEDULE OF DISTRIBUTION SALE 4 31 DATE FILED July 7, 2000 Writ No. 1999-6217 Civil Term Contimortgage Corporation -vs- Willie C. White and Anna L. White 173 Ridge Hill Road Mechanicsburg, PA Date of Sale June 7, 2000 Buyer Mark D. & Julie A. Carpenter Bid Price $ 90,000.00 Real Debt $171,814.52 Interest fr 1/I1/00-6/7/00 4,179.52 Writ Costs 126.96 $176,121.00 DISTRIBUTION Amount Collected 95,554.20 Sheriff's Costs 2,536.76 Legal Search 200.00 Transfer Taxes Local 1,777.10 Transfer Taxes State 1,777.10 Tax Claim Bureau 1,700.64 Silver Spring Authority 298.92 Credit Writ No. 1999-6217 with 87,263.68 Refund to Attorney advance costs $ 1000.00 R. Thomas Kline, Sheriff ByI2Q.1..?,.C 4*,-eZe' Real Estate Deputy TITLE REPORT THE PREMISES ENDORSED HEREON ARE SUBJECT TO THE FOLLOWING ITEMS, WHICH WILL BE EXCEPTED IN THE POLICY UNLESS SATISFACTORY EVIDENCE PERMITTING THEIR REMOVAL IS PRODUCED. SHERIFF SALE NO. 31 Held Wednesday, June 7, 2000 Date: June 7, 2000 TAXES: Receipts for all taxes for the years 1997 to 1999 inclusive. Taxes for the current year 2000. WATER RENT: Company assumes no liability for private supply of water or sewer. SEWER RENT Receipts to be produced if services are lienable. MECHANICS' AND Possible unfiled Mechanics Liens and Municipal Claims. MUNICIPAL CLAIMS MORTGAGES: Listed Under Other Exceptions Below. JUDGMENTS: Listed Under Other Exceptions Below. INSTRUMENTS TO BE PRODUCED: Deed from Cumberland County Sheriff to dated , 2000, and recorded , 2000, in Cumberland County Deed Book Page RECITAL: Being the same premises which Earl L. Beam and Kathy A. Beam, his wife, by deed dated December 22, 1993 and recorded December 27, 1993 in the Office of the Recorder of Deeds in and for Cumberland County, at Carlisle, Pennsylvania, in Deed Book "S", Volume 36, Page 494 granted and conveyed to Willie C. White and Anna L. White, his wife. OTHER EXCEPTIONS: I. The identity and legal competency of parties at the closing of this title should be established to the satisfaction of the closing attorney acting for this Company. 2. Rights or claims of parties in possession, if any, other than the owner. 3. Unrecorded easements, discrepancies or conflicts in boundary lines, shortage in area and encroachments which an accurate and complete survey would disclose. 4. Payment of State and lo_al Real Estate Transfer Taxes, if required. 5. Public and private rights in the roadbed of Township Road T-577, known as Ridge Hill Road, dedicated 25 feet from the centerline pursuant to the portion of the plan of Ridge Hill Estates, Section A. recorded in Deed Book "U", Volume 25, Page 903. 6. Conditions, easements and restrictions shown on or set forth on Plan of Section A, Ridge Hill Estates, recorded in Cumberland County Deed Book "U", Volume 25 , Page 903. 7. Mortgage in the amount of S155,200.00 given by Willie C. White and Anna L. White to Conti mortgage Corporation dated August 19, 1997 and recorded August 21, 1997 in I\, ,, Mortgage Book 1400, Page 880. Complaint in Mortgage Foreclosure filed on October 11, 1999 in the Office of the Prothonotary to Number 99-6217 by Contimortgage Corporation as plaintiff against Willie C. White and Anna L. White. Judgment entered January If, 2000 in the amount of $171,814,52. 8. Judgment in the amount of $4,954.61 entered by the Commonwealth of Pennsylvania, Bureau of Compliance its plaintiff against Willie C. White and Anna L. White and Anna's Sub and Pizza as defendants on April 25, 2000 in the Office of the Prothonotary to file number 2000-2566. 9. Satisfactory evidence to be produced that proper notice was given to the holders of all liens and encumbrances intended to be divested by subject Sheriff Sale. Specifically, the docket refect% no notification being given to the Commonwealth of Pennsylvania, Bureau of Compliance. 10. Satisfactory evidence to be produced that the advertisement of the property for sale is satisfactory in spite of the absence of any reference to the improvements on the subject property. 11. Real estate taxes accruing on and after July 1, 2000 not yet due and payable. It Is to be noted that no search of Domestic Relations Records has been made to determine support arrearages regarding House Bill 1412, Act 58 of 1997, nor has any search been made for environmental liens in Federal District Court. Robert G. Frey, Agent Note: This Title Report shall not be va ' or until countersigned by an authorized sig or . '. REAL ESTATE SALE NO. 31 Writ No. 99.6217 Civil Contimortgage Corporation, va. Willie C. White and Anna L White Atty.: Frank Federman DESCRIFJ)ON situated in the Township of silver Spring, County of Cuthberland and Commonwealth of Pennsylvania, bounded and described as follows: BEGINNING at a point in the cen. ter line of Township Road T•57710- cally known as Ridge Hill Road: thence by property now or formerly of John R. Hair South 14 degrees 25 minutes East 25.02 feet to a stake in the ultimate right,of-way line of Town- ship Road T•577; thence continuing along land of Hair South 14 degrees 25 minutes East 229.20 feet to a stake; thence by land of Shaffer Trucking Company South 73 degrees 35 minutes 30 seconds West 200.0 feet to a stake; thence by lands of Pearl Beam North 14 degrees 24 min- uses 41 seconds West 228.90 feet to a stake in the ultimate right-of-way of Township Road T-577; thence continuing along lands of Pearl Beam North 14 degrees 24 minutes 41 sec. onds West 25.02 feet to a point in the center line of Township Road T-577; thence by said center line North 73 degrees 30 minutes East 200.0 feet to a Point In said center line, the place of BEGINNING. TAX PARCEL #38.18.1344.034. .'ITTLE TO SAID PREMISES IS VESTED IN Willie C. White and Anna L White, his wife by Deed from Earl L. Beam and Kathy A. Beath, his wife. dated 12/22/93. recanted 12/27/93. In Deed Book S-36, Page 494. i Contimorteage Corporation Plaintiff, CUMBERLAND COUNTY v. COURT OF COMMON PLEAS Willie C. While CIVIL DIVISION Anna L. While Defendant(s). NO. 99-6217 Civil Term AFFIDAVIT PURSUANT TO RULE 3129 (Affidavit No. 1) Contimorteaee Corporation, Plaintiff in the above action, by its attorney, FRANK FEDERMAN, ESQUIRE, sets forth as of the date the Praecipe for the Writ of Execution was filed the following information concerning the real property located at 173 Ridge Hill Road, Mechanicsburg, PA 17055. 1. Name and address of Owner(s) or reputed Owner(s): NAME LAST KNOWN ADDRESS (If address cannot be reasonably ascertained, please so indicate.) Willie C. White 331 Los Altos Way Apartment 102 Altamonte Springs, FL 32714-3287 Anna L. White 331 Los Altos Way Apartment 102 Altamonte Springs, FL 32714-3287 2. Name and address of Defendant(s) in the judgment: NAME LAST KNOWN ADDRESS (If address cannot be reasonably ascertained, please so indicate.) Same as above 3. Name and address of everyjudgment creditor whose judgment is a record lien on the real property to be sold: NAME LAST KNOWN ADDRESS (If address cannot be reasonably ascertained, please so indicate.) None 4. Name and address of the last recorded holder of every mortgage of record: NAME LAST KNOWN ADDRESS (If address cannot be reasonably ascertained, please so indicate.) None 5. Name and address of every other person who has any record lien on the property: NAME LAST KNOWN ADDRESS (If address cannot be reasonably ascertained, please so indicate.) None 6. Name and address of every other person who has any record interest in the property and whose interest may be affected by the sale: NAME LAST KNOWN ADDRESS (If address cannot be reasonably ascertained, please so indicate.) None 7. Name and address of every other person whom the plaintiff has knowledge who has any interest in the property which may be affected by the sale: NAME LAST KNOWN ADDRESS (If address cannot be reasonably ascertained, please so indicate.) Tenant/Occupant 173 Ridge Hill Road Mechanicsburg, PA 17055 Domestic Relations of 13 North Hanover Street Cumberland County Carlisle, PA 17013 I verify that the statements made in this affidavit are true and correct to the best of my personal knowledge or information and belief. I understand that false statements herein arc made subject to the penalties of 18 Pa. C.S. Sec. 4904 relating to unswom falsification to authorities. Stn.wt a/1,? February 16, 2000 DATE 4Att K FED RMA , ESQUIRE yfor Plaint r Contlmortgage Corporation Plaintiff, V. Willie C. White Anna L. White Defendant(s). CUMBERLAND COUNTY No. 99-6217 Civil Term February 16, 2000 TO: Willie C. White Anna L. White 331 Los Altos Way Apartment 102 Altamonte Springs, FL 32714-3287 "THIS FIRM IS A DEBT COLLECTOR ATTEMPTING TO COLLECT A DEBT AND ANY INFORMATION OBTAINED WILL BE USED FOR THAT PURPOSE. IF YOU HAVE PREVIOUSLY RECEIVED A DISCHARGE IN BANKRUPTCY AND THIS DEBT WAS NOT REAFFIRMED, THIS IS NOT AND SHOULD NOT BE CONSTRUED TO BE AN ATTEMPT TO COLLECT A DEBT, BUT ONLY ENFORCEMENT OF A LIEN AGAINST PROPERTY." Your house (real estate) at 173 Ridge Hill Road, Mechanicsburg, PA 17055, is scheduled to be sold at the Sheriffs Sale on June 7.2000 at 10:00 a.m. in the Cumberland County Courhtouse, South Hanover Street, Carlisle, PA 17013, to enforce the courtjudgment obtained by Contimortange Corporation (the mortgagee) against you. If the Sheriffs sale is postponed, the property will be relisted for the Sheriffs Sale. NOTICE. OF OWNER'S RIGHTS YOU MAY BE ABLE TO PREVENT THIS SHERIFF'S SALE To prevent this Sheriffs Sale, you must take immediate action: 1. The sale will be cancelled if you pay to the mortgagee the back payments, late charges, costs and reasonable attorney's fees due. To find out how much you must pay, you may call: (215) 563-7000. 2. You may be able to stop the sale by filing a petition asking the Court to strike or open the judgment, if the judgment was improperly entered. You may also ask the Courtto 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 attomey.) 1. If the Sheriffs Sale is not stopped, your property will be sold to the highest bidder. You may find out the price bid by calling (215) 563-7000. 2. You may be able to petition the Court to set aside the sale if the bid price was grossly inadequate compared to the value of your property. 3. The sale will go through only if the buyer pays the Sheriff the full amount due in the sale. To find out if this has happened, you may call (717) 240-6390. 4. If the amount due from the Buyer is not paid to the Sheriff, you will remain the owner of the property as if the sale never happened. 5. You have the right to remain in the property until the full amount due is paid to the Sheriff and the Sheriff gives a deed to the buyer. At that time, the buyer may bring legal proceedings to evict you. 6. You may be entitled to a share of the money which was paid for your house. A schedule of distribution of the money bid for your house will be filed by the Sheriff within 30 days of 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 the 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. CUMBERLAND COUNTY ATTORNEY REFERRAL CUMBERLAND COUNTY BAR ASSOCIATION 2 LIBERTY AVENUE CUMBERLAND COUNTY COURTHOUSE CARLISLE, PA 17013 (717) 249-3166 (800) 990-9108 I DESCRIPTION ALL THAT CERTAIN tract of land situated in the Township of Silver Spring, County of Cumberland and Commonwealth of Pennsylvania, bounded and described as follows: BEGINNING at a point in the center line of Township Road T-577 locally known as Ridge Hill Road; thence by property now or formerly of John R. Hair South 14 degrees 25 minutes East 25.02 feet to a stake in the ultimate right-of-way line of Township Road T-577; thence continuing along land of Hair South 14 degrees 25 minutes East 229.20 feet to a stake; thence by land of Shaffer Trucking Company South 73 degrees 35 minutes 30 seconds West 200.0 feet to a stake; thence by lands of Pearl Beam North 14 degrees 24 minutes 41 seconds West 228.90 feet to a stake in the ultimate right-of-way of Township Road T-577; thence continuing along lands of Pearl Beam North 14 degrees 24 minutes 41 seconds West 25.02 feet to a point in the center line of Township Road T- 577; thence by said center line North 73 degrees 30 minutes East 200.0 feet to a point in said center line, the place of BEGINNING. TAX PARCEL //38-18-1344-034 TITLE TO SAID PREMISES IS VESTED IN Willie C. White and Anna L. White, his wife by Deed from Earl L. Beam and Kathy A. Beam, his wife, dated 12/22/93, recorded 12/27/93, in Deed Book S-36, Page 494. ?P-'! WRIT OF EXECUTION and/or ATTACHMENT COMMONWEALTH OF PENNSYLVANIA) NO. 99-6217 CIVIL fg{ Term COUNTY OF CUMBERLAND) CIVIL ACTION - LAW TO THE SHERIFF OF Cumberland COUNTY: To satisfy the debt, interest and costs due Contimortgage Corporation PLAINTIFF(S) from Willie C. White and Anna L. White, 331 Los Altos Way Apartment 102, Altamonte Springs, F1 32714-3287 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) If property of the detendant(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 hinvhe r that he/she has been added as a garnishee and Is enjoined as above stated. AmounlDue $171,814.52 from 1/11/00 - 7 00 Interest -$4T179.51-and Coots Any's Comm Ally Feld $126.96 Plaintiff Paid Dale: February 22, 2000 REQUESTING PARTY: Name Frank Federman, F.sq. Address: Two Penn Center Plaza Suite 900 Philadelphia, PA 19102 Aftorneyfor: Plaintiff Telephone: 215-563-700 Supreme Court ID No. - 12248 LL _ $.50 Due Prothy $1.00 Other Costs Curtis R. Long Prothonotary, Civil Division Deputy REAL ESTATE SALE No.31 Interest in the real property situated in ? --dI °su a W4 Cumberland County, Pa., known and nurnbrrod as- L7- &4 '0' .C and morn fully cescribad on E:xhilult "A" Wed .vi!„ PJLI this writ and by this reference incorporated horein. Q gate: /r?--w-rt By, i THE PATRIOT NEWS THE SUNDAY PATRIOT NEWS Proof of Publication Commonwealth of Pennsylvania, County of Dauphin) as Michael Morrow being duly sworn according to law, deposes and says: That he is the Assistant Controller of THE PATRIOT-NEWS CO., a corporation organized and existing under the laws of the Commonwealth of Pennsylvania, with its principal office and place of business at 812 to 818 Market Street, In the City of Harrisburg, County of Dauphin, State of Pennsylvania, owner and publisher of THE PATRIOT-NEWS and THE SUNDAY PATRIOT-NEWS newspapers of general circulation, printed and published at 812 to 818 Market Street, in the City, County and State aforesaid; that THE PATRIOT-NEWS and THE SUNDAY PATRIOT-NEWS wore established March 41h, 1854, and September 18th, 1949, respectively, and all have boon continuously published over since. That the printed notice or publication which is securely attached hereto is exactly as printed and publishua In their regular dally and/or Sunday and Metro editions/issues which appeared on the 2nd, 91h and 16th day(s) of May 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 tho said Company and subsequently duly recorded In the office for the Recording of Deeds in and for said County Qf Dauphin inliscollaneous Book 'M', Volume 14, Pago 317. I f )' / , _ PUBLICATION COPY SALE#31 Sworn to and subscribed 2nd daypl June2tl00 A.D. Terry L, Russell, it Menteer, Pennsykarxe AS W W twn of Nctarief expires Juno 6, 2002 CUMBERLAND COUNTY SHERIFFS OFFICE CUMBERLAND COUNTY COURTHOUSE CARLISLE, PA. 17013 Statement of Advertising Costs M" ¢ % 1Nd as To THE PATRIOT-NEWS CO., Dr. M" d as For publishing the notice or publication attached n a s hereto on the above stated dates $ 233.03 new or Probating same Notary Foo(s) $ 1.50 in the Total $ 234.53 Liaher's Receipt for Advertising Cost lishor of THE PATRIOT-NEWS and THE SUNDAY PATRIOT-NEWS, newspapers of general o receipt of the aforesaid notice and publication costs and certifies that the soma have THE PATRIOT-NEWS CO. By .................................................................... hence in trm 27 o a Male hip Rad d Hurl wond. r Sne ul sm roa n In yW center line, the plxe of 6EGIAh NG TAXPARC[Lp&itima- t. TIRE 10 5, D PREMISES IS %LSTTO Ly lgRk C. Hh, and Anna L R1dte, hi' aih, h lked l Earl L Ream and Kathy A. Bean his xile, dated 1212219.1 recorded 121 2719], In Eked R" S•36. Page 991. PROOF OF PUBLICATION OF NOTICE IN CUMBERLAND LAW JOURNAL (Under Act No. 587, approved May 16, 1929), P. L.1784 STATE OF PENNSYLVANIA : COUNTY OF CUMBERLAND : SS. Roger M. Morgenthal, Esquire, Editor of the Cumberland Law Journal, of the County and State aforesaid, being duly sworn, according to law, deposes and says that the Cumberland Law Journal, a legal periodical published in the Borough of Carlisle in the County and State aforesaid, was established January 2, 1952, and designated by the local courts as the official legal periodical for the publication of all legal notices, and has, since January 2, 1952, been regularly issued weekly in the said County, and that the printed notice or publication attached hereto is exactly the same as was printed in the regular editions and issues of the said Cumberland Law Journal on the following dates, viz: APRIL 28, MAY 5, 12, 2000 Afliant 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. 11tAI, ESTATE SM.E NO. al Writ No. 06.6217 Civil Contimortgage Corporation va. Willie C. white and Anna L. While Ally.: Frank Federman DESCR,PnON ALL Situated in TtheETrnmship of Silver Sprung, County of Cumberland and Commonwealth of Pennsylvania, bounded and described as follows: BEGINNING at a point in the cen• ter line of Township Road T•577 to- calFl known as Ridge HW Road; thence by property now or formerly of john K Hair South 14 degrees 25 rmnules East 25.02 feel to a stake in the ulumale rtghil•of•uay line of Town. Ship Road T•577: thence continuing along land of flair South 14 degrees 25 minutes East 220.20 feet to a slake: thence by land of Shaffer Tricking Company South 73 degrees 35 minutes 30 seconds West 200.0 feel to a stake: thence by lands of Pearl Beam North 14 degrees 24nun• ules 41 seconds Nest 228.00 feel to a slake in the ultimate righll•of.way of Township Road T•577: thence continuing along lands of Pearl Beam North 14 degrees 24 nu»uies 41 sec• onds West 25.02 fret to a point In the center line of Township Raid T•577; thence by said center line North 73 degrees 30 nanules East 200.0 feet 10 a point In said center line, the place of BEGINNING. TAX PARCEL 038.18.1344.034. TITLE TO SAID PREMISES IS VESTED IN willle C. White and Anna 4 white. Ills wife by Deed from Earl L, Beam and R.alhyA. learn, his wife, dated 12/22/03, reran ed 12/27/93. In Deed Book S•36, Page 494, Rog M. Morgenthal, Editor SWORN TO AND SUBSCRIBED before me this --12 day of MAY. 2000 1.045 E. SNYDER, Notary PubIK Carlisle Soto, Cumberland County, PA My Commission E.pres March S, 2001 4 1 , l% Real Estate No 31 $ 1000.00 Advance Costs Paid 03/01/00 Atty Frank Federman Assessed Valuation $ 11,730 Writ No. 1999-6217 Civil Contimortgage Corporation .vs. Willie C. White and Anna L. White 173 Ridge Hill Road Mechanicsburg, PA Real Debt $ 171,814.52 Interest fr 1/11/00-6/7/00 4,179.52 Atty's Fees Atty's Writ Costs 126.96 Escrow Late Charges Sheriffs Costs Docketing 30.00 Poundage 1,800.00 Posting Bills 15.00 Advertising 15.00 Acknowledging Deed 30.00 Auctioneer 10.00 Law Library .50 County 1.00 Mileage 3.72 Certified Mail 1.01 Levy 15.00 Surcharge 30.00 Postpone Sale Out of County Legal Search 200.00 Law Journal 274.70 Patriot News 234.53 Share of Bills 24.80 Distribution of Proceeds 25.00 Sheriffs Deed 26.50 TAXES Tax Claim Bureau 1,700.64 Silver Spring Township Authority 298.92 FEDERMAN AND PHELAN By: FRANK FEDERMAN, ESQUIRE IDENTIFICATION NO. 12248 ONE PENN CENTER AT SUBURBAN STATION 1617 JOHN F. KENNEDY BLVD., SUITE 1400 PHILADELPHIA, PA 19103-1814 (215) 501-7nOn ATTORNEY FOR PLAINTIFF COURT OF COMMON PLEAS CIVIL DIVISION CONTIMORTGAGE CORPORATION CUMBERLAND COUNTY V. NO. 99-6217 WILLIE C. WHITE ANNA L. WHITE PRAMPF. TO MARK JUDGMENT SATISFIF.n TO THE OFFICE OF JUDICIAL SUPPORT: Kindly mark the Judgment which was entered on JANUARY 11, 2000, against WILLIE C. WHITE and ANNA L. WHITE, Defendant(s), in the amount of S171,814.52, satisfied, upon payment of your costs only. FRANK FED RMAN, ESQUIRE Attorney for Plaintiff March 2, 2001 :: ?; ?? : . `?> ?,, - ' ?? rv "" ,,,_ gg ? E f `? g qgg++ 3?.;. ? ', ` ? ?? ? ". ` ??. }Y ? _ 31 ?# ?; .,: r ;F `", S. .-' - ' it ` {: : ' ' . . : ?. ? ".: .: ? ? 1. y. ? ? ` 1 ' : E: :? t.:. .?. ? ` 1 ;i: C.'' ? 7 i . 1 t) ?? >i