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Home My WebLink About01-6071 FEDERMAN AND PHELAN, LLP By: FRANK FEDERMAN, ESQUIRE IDENTIFICATION NO. 12248 ONE PENN CENTER AT SUBURBAN STATION 1617 JOHN F. KENNEDY BOULEVARD SUITE 1400 PHILADELPHIA, PA 19103-1814 £215) 563-7000 COUNTRYWDE HOME LOANS, INC. 7105 CORPORATE DRIVE PLANO, TX 75024 ATTORNEY FOR PLAINTIFF COURT OF COMMON PLEAS CiVIL DiVISION Plaintiff LINDA S. MATEER JESSICA L. MANSBERGER 223 RENO STREET NEW CUMBERLAND, pA 17070 TERM CUMBERLAND COUNTY Defendant(s) CIVIL ACTION - LAW .COMPLAINT IN MORTGAGE FORECLOSURE NOTICE **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 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 have been sued in Court. If you wish to defend against the claims set forth in the following pages, you must take action within twenty (20) days after this Complaint and Notice are served, by entering a written appearance personally or by attorney and filing in writing with the court your defenses or objections to the claims set forth against you. You are warned that if you fail to do so the case may proceed without you and a judgment may be entered against you by the court without further notice for any money claimed in the Complaint or for any other claim or relief requested by the Plaintiff. You may lose money or property or other fights 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 Loan #: 9909949 IF THIS IS THE FIRST NOTICE THAT YOU HAVE RECEIVED FROM THIS OFFICE, BE ADVISED THAT: 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 WR/TING 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. THE LAW DOES NOT REQUIRE US TO WAIT UNTIL THE END OF THE THIRTY (30) DAY PERIOD FOLLOWING FIRST CONTACT WITH YOU BEFORE SUING YOU TO COLLECT THIS DEBT. EVEN THOUGH THE LAW PROVIDES THAT YOUR ANSWER TO THIS COMPLAINT IS TO BE FILED IN THIS ACTION WITHIN TWENTY (20) DAYS, YOU MAY OBTAIN AN EXTENSION OF THAT TIME. FURTHERMORE, NO REQUEST WILL BE MADE TO THE COURT FOR A JUDGMENT UNTIL THE EXPIRATION OF THIRTY (30) DAYS AFTER YOU HAVE RECEIVED THIS COMPLAINT. HOWEVER, IF YOU REQUEST PROOF OF THE DEBT OR THE NAME AND ADDRESS OF THE ORIGINAL CREDITOR WITHIN THE THIRTY (30) DAY PERIOD THAT BEGINS UPON YOUR RECEIPT OF THIS COMPLAINT, THE LAW REQUIRES US TO CEASE OUR EFFORTS (THROUGH LITIGATION OR OTHERWISE) TO COLLECT THE DEBT UNTIL WE MAIL THE REQUESTED INFORMATION TO YOU. YOU SHOULD CONSULT AN ATTORNEY FOR ADVICE CONCERNING YOUR RIGHTS AND OBLIGATIONS IN THIS SUIT. Plaintiff is COUNTRYWIDE HOME LOANS, INC. 7105 CORPORATE DRIVE PLANo, TX 75024 The name(s) and last known address (es) of the Defendant(s) are: LINDA S. MATEER JESS/CA L. MANSBERGER 223 RENO STREET NEW CUMBERLAND, PA 17070 who is/are the mortgagor(s) and real owner(s) of the property hereinafter described. On 2/22/01 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. 1675, Page 850. The premises subject to said mortgage is described as attached. The mortgage is in default because monthly payments of principal and interest upon said mortgage due 6/1/01 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." The following amounts are due on the mortgage: Principal Balance Interest 5/1/01 through 9/1/01 (Per Diem $14.11) Attorney's Fees Cumulative Late Charges 2/22/01 to 9/1/01 Cost of Suit and Title Search Subtotal $61,573.24 1,749.64 3,078.00 69.45 ~50 00 $67,020.33 Escrow Credit Deficit 300.00 Subtotal _0.00 ($ 300.00) TOTAL $66,720.33 The attorney's fees set forth above are in conformity with the Mortgage documents and Pennsylvania Law, and will be collected in the event ora third party purchaser at Sheriffs Sale. If the Mortgage is reinstated prior to the Sale, reasonable attorney's fees will be charged. This action does not come under Act 6 of 1974 because the original mortgage amount exceeds $50,000.00. The Combined Notice has been sent to the Defendant(s) by regular and certified mail as required by 35 P.S. § 1680.403c on the date(s) set forth in the true and correct copy of such notice(s) attached hereto as Exhibit "A." 10. 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 tree and correct copy of which is attached hereto as Exhibit "A"; or (ii.) Defendant(s) application for assistance has been rejected by the Pennsylvania Housing Finance Agency. WHEREFORE, PLAINTIFF demands an in rem Judgment against the Defendant s in th $66,720.33, together with interest fi-om 9/1/01 a* *~ ...... ~ ~, ........ (). e sum of - ,-,- -,~,~ m,~,~.l i per ulem to the 0ate 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 Count HOME LOANS July 31, 2001 Jessica L Mansberger 223 Reno Street New Cumberland, PA 17070-O000 Cedffied Mail NO. Return Receipt Requested Regular Mail Account No.: 9909949 Property Address: 223 Reno Street New Cumberland, PA 17070-0000 Current Servicer: Countrywide Home Loans Servicing LP ACT 91 NOTICE TAKE ACTION TO SAVE YOUR HOME FROM FORECLOSURE This is n offl Iai n i t the mrt a It r I In del ult nd the lend r intends to f reclose. S clRclnf rmatlonabo thennt reoft uitl rOvlded in the ttached es. The HOMEOWNER'S EMERGENCY MORTGAGE ASSI T N E PROGRAM HEMAP ma be able to h I to save ourh me, Thl Notl Iai howt ro ramw rk . TO ifHEMAPca h I m ME TW H ONS ER RE ITC UNSELINGAGEN YWITHIN30 DAYS OF THE DATE OF HIS NOT . T thl N It wh n oum twlththeCounselin A enc. The names addre s a hum f n u r It C n elin A ncl s arvin our aunt are Ii t ntth e d fthl · It t um c IlthePenns Iv ni Housln Fin rice A nc t I'-fr 1- 42- . rea withm al h tin ancall 1-717-780-1869 This Notice contains important legal Infotmntlon. if you have any questions, representatives at the Consumer Credit Counseling Agency may be able to help answer them. You may also want to contact an attorney in your area. The lOCal bar assOCiation may be able to help you find a lawyer. LA NOTIFICACI(~N EN ADJUI%q'O ES DE SUMA IMPORTANCIA, PDES AFECTA SU DERECHO A CONTINUAR VIVIENDO EN SU CASA. SI NO COMPRENDE EL CONTENIDO DE ESTA NOTIFICACI(~N ODTENGA UNA TRADUCCION INMEDIATAMENTE LLAMANDO ESTA AGENCIA (PENNSYLVANIA HOUSING FINANCE AGENCY) SIN CARGOS AL NOMERO MENCIONADO ARRIBA. PUEDE SER ELEGIBLE PARA UN PRE~STAMO PaR EL PROGRAMA LLAMADO "HOMEOWNER'S EMERGENCY MORTGAGE ASSISTANCE PROGRAM" EL CUAL PUEDE SALVAR SU CASA DE LA PERDIDA DEL DERECHO A REDIMIR SU HIPOTECA. HOMEOWNER'S EMERGENCY MORTGAGE ASSISTANCE PROGRAM YOU MAY BE ELI IDLE FOR FINANCIAL A I TAN E WHI H AN SAVE y UR HOME FROM FORECLOSURE ~ REM RT AGE PAYMENT . IF YOU COMPLY WITH THE PROVISIONS OF THE HOMEOWNER'S EMERGENCY MORTGAGE ASSISTANCE ACT OF 1983 (THE "ACT"), YOU MAY BE ELIGIBLE FOR EMERGENCY MORTGAGE ASSISTANCE: IF YOUR DEFAULT HAS BEEN CAUSED BY CIRCUMSTANCES BEYOND YOUR COHTROL, IF YOU HAVE A REASONABLE PROSPECT OF BEING ABLE TO PAY YOUR MORTGAGE PAYMENTS, AND IF YOU MEET OTHER ELIGIBILITy REQUIREMENTS ESTABLISHED BY THE PENNSYLVANIA HOUSING FINANCE AGENCY. Jessma L Mansberger 9909949-1 Pa Reno Street P.O. Box 660694 Dallas, TX 75266~0694 II'.I,I,I-,LI,II-,II.II..II.I,I.,I.II,I.,I.I.i,ii 990994910001123460112346 $1,123.46 As OF September 4, 2001 EXHIBITA Counbywide HOME LOANS Send CorrespOndence to: PO Box 10221 Van Nuys, CA 914tO*O22t July 31, 2001 Linda S Mateer 223 Reno Street New Cumberland, PA 17070-0000 Certified Mall NO, Return Receipl Requested Regular Mail Account No.: 9909949 Property Address: 223 Reno Street New Cumberland. PA 17070-0000 ACT 91 NOTICE TAKE ACTION TO SAVE YOUR HOME FROM FORECLOSURE This is an official nOtl th t the mort on r home I in d auif nd the I nder int rids t forecl se. S ifl Intormatlon a ut t ute t uifls vi inthe tracheal e . Th H MEOWNER' M RG N YM RT A EA TAN EPRO RAM HE AP ma e bi t h I to save ur ThsNotl I h wthe r mw rk . To see if HEMAP c n h I u m t M ET WITH N MER REDIT COUN LING AGENCY WITHIN 30 DAYSOFTHEDATEOFTHi N TI E. 1' k th N t wit uwhen o wifhtheCounselln A eric . Then mes ad re and n num f ne r if ouns lin A nclesservln our Coun are list et t end this N If h u t n u all the Penn Ivanla Housln Finan e A eric t I-f tl "-2 7. P r n Wthlm I h rin an 111-717.7 1869. This Notice contains Important legal Information. If you have any questions, representatives at the Consumer Credit Counseling Agency may be able to help answer them. You may also want to contact an attorney in your area. The lOcal her aaaocletlon may he able to help you find a lawyer. LA NOTIFICACK~N EN ADJUNTO ES DE SUMA IMPORTANClA, PUES AFECTA SU DERECHO A CONTINUAR VIVIENDO EN SU CASA. SI NO COMPRENDE EL CONTENIDO DE ESTA NOTIFICACION OBTENGA UNA TRADUCCI{~N INMEDIATAMENTE LLAMANDO ESTA AGENCIA (PENNSYLVANIA HOUSING FINANCE AGENCY) SIN CARGOS AL Nt)MERO MENCIONADO ARRIBA. PUEDE SER ELEGIBLE PARA UN PRI~STAMO POR EL PROGRAMA LLAMAOO "HOMEOWNER'S EMERGENCY MORTGAGE ASSISTANCE PROGRAM" EL CUAL PUEDE SALVAR SU CASA DE LA PERDIGA DEL DERECHO A REDIMIR SU RIPOTECA. HOMEOWNER'S EMERGENCY MORTGAGE ASSISTANCE PROGRAM YOU MAY BE ELIGIBLE F R FINANCIAL A SI TAN E WHICH CAN SAVE YOUR HOME FROM FORECLOSURE AND HELP YOU MAKEF TU EM RI' A EPAYMEN . IF YOU COMPLY WITH THE PROVISIONS OF THE HOMEOWNER'S EMERGENCY MORTGAGE ASSISTANCE ACT OF 1983 (THE "ACT"), YOU MAY BE ELIGIBLE FOR EMERGENCY MORTGAGE ASSISTANCE: IF YOUR DEFAULT HAS BEEN CAUSED BY CIRCUMSTANCES BEYOND YOUR CONTROL, IF YOU HAVE A REASONABLE PROSPECT OF BEING ABLE TO PAY YOUR MORTGAGE PAYMENTS, AND IF YOU MEET OTHER ELIGIBILITY REQUIREMENTS ESTABLISHED BY THE PENNSYLVANIA HOUBING FINANCE AGENCY. P.O. Box 660694 Dallas, TX 75266-0694 II,-I,I,I,.,I,I,II,,,IL.II.,,,II.I,h,,L,II.I.,,I,,i,,i,ii 990994910001123460112346 $1,123.46 AS OF September 4, 2001 EXHIBITA TEMPORARY STAY OF FORECLOSUI3T - Under the Act, you are entitled to a temporary stay of foreclosure on your mortgage for lhitty-bve (35) days from the date of this Notice. During that time you must arrange and attend a 'face-to- lace" meefing with one of the consumer credit counseling agencies lisled at the end Of this Notice. THIS MEETING ~M_U. ST oCCUR WITHIN THE NEXT (351 DAYS-. IF YOU DO NOT APPLy FOR EMERGENCY MORTGA[;~ ASSIS_T~.N....E.._Y(~U_MU T BRING YO R MORTGAGE UP TO DATE T TO C. URE YOUR MORTGAGE DEFAULT" ~ ~1~.2,,^, ¥,-.~ HE P~F TH~$ NO~ICE CAI I ED "HOV~ EXP.,.,,..~ .,~.~ .~ D.ING YOUR MORTGA(~E UP TO DATE - ~ C~ONSUMER CREDIT COUNSEL NG AGENC ;~ - If you meet with one of th~ rn · - . listed at the end of th s notic ~ . - ...... nsume credit counselln a enc~es e, the lender may NOT take action against you for th dy-five (35 da,,s aher .A ~g_ ? ~. c°u~ntY in wh~-ht he ~)-roDertv is located are set f°~h~at the eed (,if Ibis NoI;,;,~ It is only necessa~ to schedule ~ne' ia~- to-lace meeting. Advise your lender Lmmediat~elE of your intentions. APPLICATION FOR MORTGAGE ASSISTANC;E - Your mortgage is n default for the reasons set fodh later in his ~oiioe (see following pages for specific informai~on about the nature of your defaul ) you have tried and are unable Io resolve this problem with the lender, you have the right to apply for financial assistance from the Homeowner,s Emergency Modgage Assistance Program. TO do SO, you must fill out, sign and file a completed Homeowner's Emergency Assistance Program Application with one of the designated consumer credit counseling agencies Iisfed at me end of this Notice. Only consumer credit counseling agencies have applications for the program and they wil~ assist you in submilting a complete application to the Pennsylvania Housing Finance Agency. Your application MUST be filed <~r postmarked within thidy-five (35) days ot your face-to-face meeting. YOU MI)S.T. F LE YOUR APPLICATION PROMPTLY. IF YOU FAIL TO DO SO OR IF YOU DO NOT FOLLOW THE OTHER TIME PERIODS SET FORTH IN THIS LETTER, FORECLOSURE MAY PROCEED AGAINST YOUR HOME iMMEDIATELY AND YOUR APPLICATION FOR MORTGAGE ASSISTANCE WILL BE DENIED. _A~ENCY ACTION _ Available funds for emergency modgage assistance are very limited. They will be disbursed by the Agency under the eligibility criteria established by the Act. The Pennsylvania Housing Finance Agency has sixty 160) days to make a decision after it receives your application. During that 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 Pennsylvania Hous ng Finance Agency of its decision on your application. NOTE: IF YOU ARE CURRENTLY PROTECTED BY THE FILING OF A PETITION IN BANKRUPTCY, THE FOLLOWING PART OF THIS NOTICE IS FOR INFORMATION PURPOSES ONLY AND SHOULD NOT BE CONSIDERED AS AN A3-rEMPT TO COLLECT THE DEBT. (If you have filed bankruptcy you can still apply for Emergency Mortgage Assistance.) NOTICE OF INTENT TO FORECLOSE YOUR HOME LOAN IS IN DEFAULT FOR THE REASONS SET FORTH IN '13'llS NOTICE. YOU MUST TAKE ACTION TO SAVE YOUR HOME FROM FORECLOSURE NATURE _. OF THE DEFAULT - CountryWide Home Loans ~ervlcino LP. (hereinafter "Countrywide'*) services your home loan. Your home loan is in serious default because you have not made your required payments. The {otal amount now required to reinstate your home loan as of the date of this letter is as follows: IViOn~ p~: $538,57 L~te C~har~: $23.16 $ ! ,077 14 ()lher Char_gas: Uncollected Late Charges: $46.32 Uncollected Costs: TOTAL DUE: - St,t23.46 PAYMENT INSTRUCTION_S Please EXHIBITA _HOW TO CURE THE DEFAULT - YOU may cure this default within THIRTY*FIVE (35) DAYS of the date ol this letler by paying to us the above amount of $1,123.46, plus any a~:litional moofh~y payments, lute charges, tees and other applicable charges which may fall due during this peri(x~, SUCh payment must be in the form of certified check, cashier's check or money order, and made payable to Countrywide at P.O. Box 660694, Dallas, TX 75266-0694 If your check or other paymeof is relurned to us for insufficienl funds or for any other reason, you will not have cured your default. No extension of time to cure will be granted due to a returned payment. If you do not cure this default within THIRTY*FIVE (35) DAYS, we will accelerate lhe payments due on your home loan This means whatever is owing on the original amount borrowed wil~ be considered due immediately and you may lose lhe chance to pay off your home loan in monthly installments. If the full payment of the amount in detault is not made within THIRTY-FIVE (35} DAYS, we also intend to immediately stad a lawsuit to foreclose on your mortgaged prOpedy IF THE MORTGAGE IS FORECLOSED UPON - If the mortgage is foreclosed, he mortgaged property will be sold by the Sherift to pa~ ott the mortga-~ debt. If t~e~-defaull is cured before we begin legal proceedings, Countrywide will be eofitled to ColJecl the reasonable attorney's fees actually incurred, up to $50~00 However. if legal proceedings are started, Counlrywide will be entilled to colleof the reasonable attorney's fees even if they are over $50 O0 Any ~torney's fees will be a~ded to the secured debt, which may also include our reasonable costs. If you cure the default within the THIRTY-FIVE (35) DAY period, you will not be required to pay attorney's fees. YOU HAVE THE RIGHT TO REINSTATE AFTER ACCELERATION AND RIGHT TO ASSERT IN THE FORECLOSURE PROCEEDING THE NON- EXISTENCE OF A DEFAULT OR ANY OTHER DEFENSE YOU MAY HAVE TO ACCELERATION AND FORECLOSURE. OT~HER LENDER REMEDiE_S _ The lender may also sue you personally for the unpaid principal balance and all other sums due under the mortgage, RI~G. HT TO CURE THE DEFA[,JLT PRIOR TO FORECLOSURE S~,~ ~ _ If you have not cured the default within Ihe THIRTY*FIVE (35) DAY period and foreclosure proceedings have begun, you slill have the right lo cure the default and prevent the sale at any lime up to one hour before the foreclosure safe. You may do so by paying the total amount then past due, plus any late or other charges then due, reasonable attorney's fees and costs connected with the foreclosure sale and any other costs connected with the foreclosure sale as specified in writing by the lender and by pertorming any other requirements under the mortgage. Curing your default in the manner set forth in this notice will restore your mortgage to the same position as If you had Ilever defaulted. EARLIEST POSSIBLE FORECLOSURE SALE DAY:=- It is estimated that the earliest d t could be held WOuld be approximately six (6) months fr-om the date o this eiter A notice of~eRt~h~a~a~!°,rLec osure sate sale wil~ be sent to you before the sale. You may find out at any time exactly what lhe required payment will be by carling us at the following number: 1-800-669-6654. This payment must be in the form of a cashier's check, cedified check or money order and made payable to us at the address stated above, if Ihe default is cured the modgage will be reslored to the same position as if no default had occurred. However, the default may not be cured more than three times in any caleodar year. HOW TO CONTACT THE LENDER: _Hame of Lender: Countrywide Home Loans Servicing LP ~,ddres~; P. O. Box 10221 Van Nuys, CA 91410-0221 Phone N~mb~_ r; 1-800-669-6654 Contact Persqq; Melanle Carrillo, MS SV-34 Attention: Loan Counselor EFFECT OF FORECLOSURE S~,~ ~= - You should realize that a foreclosure sale will end your ownership of tile mortgaged property and your right to remain in it. If you continue to rive in the properly after the Sheriff's sale, a lawsuit to remove you and your furnishings and other belongings could be started by Cotlnlrywlde at any time ~MPTION OF~MORTGAGF - Contact Countrywide Home Loans for information on the possible assumability yOU MAY ALSO 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 TO HAVE THIS DEFAULT CURED BY ANY THIRD PARTy ACTING ON YOUR BEHALF. TO RAVE THE MORTGAGE RESTORED TO THE SAME POSITION AS IF NO DEFAULT HAD OCCURRED, IF YOU CURE THE DEFAULT (HOWEVER, YOU DO NOT HAVE THIS RIGHT TO CURE YOUR DEFAULT MORE THAN THREE TIMES IN ANY CALENDAR YEAR.) TO ASSERT THE NONEXISTENCE OF A DEFAULT IN ANY FORECLOSURE PROCEEDING OR ANY OTHER LAWSUIT INSTITUTED UNDER THE MORTGAGE DOCUMENTS, TO ASSERT ANY OTHER DEFENSE YOU BELIEVE YOU MAY HAVE TO SUCH ACTION BY THE LENDER TO SEEK PROTECTION UNDER THE FEDERAL BANKRUPTCY LAW. Pursuant ~o your home loan documents, and because the home loan is in default, Countrywide may, at its option enler upon and conduct an inspection of the property. The purpose of this inspection is to observe the physical COndition of lhe propefly, to verify that the properly is OCCupied an(t/or Io determine the irlentily of the occupant The COSl of any Such inspection will be added to anrl become part of the secured debt as provided under the terms ol the home loan EXHIBITA If you are unable to cure your default on or before September 4, 2001, Countrywide wants you to be aware of various options that may be available to you through CountP/wide to prevent a foreclosure sale of our o eft : · ~ecntiPa~: lt ,s possible that you may be eligible for some torm ot pa ment as Ysi P P y Forexamp,~ P equates that CountrywMe receive, up front at least ~ f Y stance through Countrywide , o the amount necessary to bring the account current, and that the balance of the overdue amount be paid, along with the regular monthly payment, over defined period of time Other repayment plans also are available, a .Loan Modificati~q: A~ternatively, it is possible that the regular monthly payments can be lowered through a modification ct the loan by reducing the interest tale and then adding the delinquent payments to the current roan balance This foreclosure alternative, however, is limited to certain loan types, Sa~le of~You_r_p~: Alternatively, if you are willing to sell your home in order to avoid foreclosure, it is possible that the sale of your home can be approved through Countrywide even if your home is WOdh less than what on it. is OWed Deed-~in-Lie[~: Alternatively, if your propedy is free from Other liens or encumbrances, and if the default is due to a serious financial hardship which is beyond your control, you may be eligible to deed your properly directly 1o the Noteholder and avoid the foreclosure sale. If you are interested in discussing foreclosure alternatives with Countrywide, you must contact us immediately, ti you request assistance Countrywide will determine, in its sole discretion, Whelher Such assistance Will be extended to you. in the rfleamime, Countrywide will pursue all of its rights and remedies under the home loan documents and as permitted by law, unless it agrees otherwise in writing. Please be advised that failure to bring the home loan current or to enter inlo a written agreement as outlined above will resull in the acceleration of the debt. Time is of the essence Should you have any questions concerning this notice, please contact Coumrywide's office ~mmediately at 1-800-669~6654, extension 7556. Melanie Carrillo Loan Counselor t-800-669.8654, extension 7556 Please be advised that this communicalion is trom a debt collector EXHIBITA PENNSYLVANIA HOUSING FIN,4aNCE AGENCY HOMEOWNER'S EMERGENCY ASSISTANCE PROGRAM CONSUMER CREDIT COUNSELING AGENCIES (REv. s/00) Lycoming-Clinton Counties Commision for Community Action (STEP) 2138 Lincoln Street P O Box ]328 Wi0iamsport, PA 17703 (570) 326-0587 FAX (570) 322-2197 CCCS of Northeastern PA 201 Basin Street Willian~porl, PA 17703 (570) 323-6627 FAX (570) 323-6626 3I W Market Street POB 1127 Wilkes-Bm-re. PA 18702 (570) 821-0837 or (800) 922-9537 FAX (570) 821 - 1785 Commission on Economics Opportunity of Luzeme County I63 Amber Lane Wilkes-Barre. PA 18702 {$70) 326-0510 or (800) 822-0359 FAX (570) 829-1665--(Call Before Foxing) (570) 4554994 Hazeltown FAX (570) 455-563 l--(Call Before Foxing) (570) 8364090 Tunkhannock Booker T. Washington Center 1720 Holland Center Erie, PA 16503 (814) 453-5744 FAX (814) 5749 John F. Kennedy Center, Inc. 2021 Eat 20ta Street Erie, PA 16510 (g 14) 898-0400 F3X (814) 898-1243 CCCS of Western Pennsylvania, [nc. 2000 Lthglestown Road Harrisburg, PA 17102 (717) 541-1757 CLINTON CO UNT.~Y COLUMBIA CO L~-rY CRAWFORD CO~.ZNTY C I~IBERLAND 0 ~NTY Urban League of Metropolitan Hamsburg N. 6~ S~'eet Harrisburg, PA 17101 (717) 234-5925 F,,LX (717) 234-9459 Community Action Corem of the Capital Region 1514 Derry Street Harrisburg. PA 17104 (717) 232-9757 FAX (717) 234-2227 CCCS of Northeastern PA 1631 South Atherton St., Suite 100 Sta~e College. PA 16801 (814) 238-3668 FAX (gl4) 2384669 1400 Abington Executive Park Suit~ 1 Cio'ks Summit, PA 18411 (570) 587-9163 or (800) 922-9537 F.~'((570) 587-9134-9135 Greater Erie Communiw Action Committee 18 West 9~ Street Erie, PA 16501 (814)4594581 FAX (814) 456-0161 Shenango Valley Urban League, Inc. 60l Indiana Avenue Farrall, PA 16121 (412) 981-5310 Financial Counseling Services of Franklin 31 West 3'~ Street Wa.vnesboro, PA [ 7268 (7 l 7) 762-3285 YWCA of Caxlisle 301 "G" Street Carlisle, PA 17013 (717) 243-3818' FAX 1717) 73 [-9589 Adams County Housing Authority 139-143 Carlisle St. Gettysburg, PA 17325 (717) 334-1518 FAX 334-8326 PENNSYLVANIA BULLETIN, VOL. 29, NO. 23. gU'NE 5, 1999 EXHIBITA LEGal, ~E~RIPTION All that certain lot or piece of ground with the buildings and improvements thereon erected, being known as 223 Reno Street, New Cumberland Borough, Cumberland county, and being further described on that certain Deed dated 2/22/01 and recorded 3/1/01 in the Office of the Recorder of Deeds in CUMBERLAND County in Deed Book No.240, Page 303. Parcel No. 25-25-0006-256 BEING known as: 223 RENO STREET NEW CUMBERLAND, PA 17070 VERIFICATION BRAN'DON SC1UMBATo hereby states that he is VICE PRESIDENT of COUNTRYWIDE HOME LOANS, INC. mortgage servicing agent for Plaintiff in th/s matter, that he is authorized to take this Verification, and that the statements made in the foregoing Civil Action in Mortgage Fore¢losur~ are hue and correct to the best of}tis lmowledge, 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. DATE: FEDERMAN AND PHELAN By: Frank Federman, Esquire Atty. I.D. No.: 12248 One Penn Center at Suburban Station Suite 1400 Philadelphia, PA 19103-1814 (215) 563-7000 Attorney for Plaintiff COUNTRYWIDE HOME LOANS, INC. Plaintiff LINDA S. MATEER JESSICA L. MANSBERGER Defendant(s) Court of Common Pleas CUMBERLAND County No. 01-6071 CIVIL PRAECIPE TO SUBSTITUTE LEGAL DESCRIPTION TO THE PROTHONOTARY: Kindly substitute the attached legal description for the legal description originally filed with the complaint in the instant matter. Date Frank Federman Attorney for Plaintiff P~oper~ Ad~¥ess: 22;3 Reno Street, New Cumberland, PA 17070 Lenal DeseriDtion: County: Cumberland ALL THAT CERTAIN TRACT OR PARCEL OF LAND AND PREMISF, S, SITUATE, LYING AND BEING IN THE BOROUGH OF NEW CUMBERLAND IN THE COUNTY OF CUMBERLAND AND COMMONWEALTH OF PENNSYLVANIA, MORE PARTICULARLY DESCRIBED AS FOLLOWS: BEGINNING AT A POINT ON THE SOUTHEAST CORNER OF RENO AND TAYLOR AVENUE; THENCE SOUTHWARDLY ALONG SAID RENO STREET 16 1/2 FEET TO THE DIVIDING LINE OR WALL ON PROPERTY NOW OR LATE OF D.Y. LENHART; THENCE EASTWARDLY ALONG SAID DIVIDING LINE AND AT RIGHT ANGLES WITH RENO STREET 140 FEET TO THE LINE OF CEDAR AVENUE; THENCE NORTHWARDLY ALONG SAID CEDAR AVENUE AND PARALLEL WITH RENO STREET 16 1/2 FEET TO TAYLOR AVENUE; THENCE WESTWARDLY ALONG THE LINE OF SAID TAYLOR AVENUE 140 FEET TO THE POINT OR PLACE OF BEGINNING. HAVING THEREON ERECTED A FRAME DWELLING HOUSE KNOWN AND NUMBERED AS 223 RENO STREET. BEING THE SAME PREMISES WHICH RIGHARD LEHMAN AND BARBARA L. LEHMAN, H/W, BY THEIR DEED DATED FEBRUARY 22, 2001, AND ABOUT TO BE RECORDED HEREWITH IN THE OlrFICE OF THE RECORDER OF DEEDS OF CUMBERLAND COUNTY, PENNSYLVANIA, GRANTED AND CONVEYED UNTO LINDA S. MATEER AND JESSICA L. MANSBERGER, MORTGAGORS HEREIN. SHERIFF'S CASE NO: 2001-06071 P COMMONWEALTH OF PENlqSYLVANIA: COUNTY OF CUMBERLAND COUNTRYWIDE HOME LOANS INC VS MATEER LINDA S RETUP~N OUT OF COUNTY R. Thomas Kline duly sworn according to and inquiry for the within named DEFENDANT MATEER LINDA S but was unable to locate Her in his deputized the sheriff of DAUPHIN serve Sheriff or Deputy Sheriff who being law, says, that he made a diligent search and to wit: bailiwick. County, He therefore Pennsylvania, the wiShin COMPLAINT - MORT FORE to On November 13th , 2001 attached return from DAUPHIN this office was in receipt of the Sheriff's Costs: Docketing Out of County Surcharge Dep Dauphin Co 18.00 9.00 10.00 29.25 .00 66.25 n/13/2001 FEDERMA_N & PHELAN R/ Thdmas Kline Sheriff of Cumberland County Sworn and subscribed to before me this ~L ~ day of ~ j A.D. Pro{honorary / SHERIPF ~ S R~TURN ~ REGULAR CASE NO: 2001-06071 P COMMONWEALTH OF PENNSYLVANIA: COUNTY OF CUMBERLAND COUNTRYWIDE HOME LOANS INC VS MATEER LINDA S GERALD WORTHINGTON Sheriff or Deputy Sheriff of Cumberland County, Pennsylvania, who being duly sworn according to law, says, the within COMPLAINT - MORT FORE was served upon MANSBERGER JESSICA L the DEFENDANT at 1900:00 HOURS, on the 30th day of October at 223 RENO STREET 2001 NEW CUMBERLAND, PA 17070 by handing to ANTHONY B93LXTON, BOYFRIEND a true and attested copy of COMPLAINT - MORT FORE together with and at the same time directing His attention to the contents thereof. Sheriff's Costs: Docketing 6.00 Service 11.05 Affidavit .00 Surcharge 10.00 .00 27.05 Sworn and Subscribed to before me this day of A.D. Prothonotary So Answers: R. Thomas Kline 11/13/2001 FEDERMAN a PHELAN ' Depu-t Y S~eriff Mary Jane Snyder Real Estate Deputy William T. Tully Solicitor Dauphin County Harrisburg, Pennsylvania 17101 ph: (717) 255-2660 fax: (717) 255-2889 Jack Lotwick Sheriff J. Daniel Basile Chief Deputy Michael W. Rinehart Assistant Chief Deputy Commonwealth of PennsyNania : COUNTRYWIDE HOME LOANS, INC vs County of Dauphin : MATEER LINDA S. Sheriff's Return No. 3137-T - - -2001 OTHER COUNTY NO. 01-6071 I, Jack Lotwick, Sheriff of the County of Dauphin, State of Pennsylvania, do hereby certify and return, that I made diligent search and inquiry for MATEER LINDA S. the DEFENDANT named in the within COMPLAINT IN MORTGAGE FORECLOSURE and that I am unable to find him/her in the County of Dauphin, and therefore return same NOT FOUND, November 7, 2001 NEED A BETTER ADDRESS NO SUCH NUMBER ON LAKE DRIVE IN MIDDLETOWN OR IN HARRISBURG Sworn and subscribed to efore me this 7TH da~f NO~EMBER, PROTHONOTARY 2001 SO Answers, Sheriff of Dauphin County, Pa. By Deputy Sheriff Sheriff's Costs:S29.25 PD 11/01/2001 RCPT NO 156147 In.The Court of Common Pleas of Cumberland County, Penmsylvania Countrywide Home Loans Inc. Linda S. Mateer et al SERVE: same No. 01 6071 civil How, October' 31, 2001 , I, SHERIFF OF CUMBERLAND COUNT'Y, PA, do hereby deputize the Sheriff of Dauphin County to execute thi s Writ, this deputation being made at the request and risk of the Plaintiff. SheriffofCumberland County, PA within Affidav/t of Service ,20 ,at o'clock __ M. served the upon at by handing to and made known copy of the original So arlswers, the contents thereof. Sworn and subscribed before me this., day of ,20 Sheriffof COSTS SERVICE MILEAGE AFFIDAVIT County, PA FEDERMAN AND PHELAN BY: FRANK FEDERMAN, ESQUIRE Identification No. 12248 1617 John F. Kennedy Boulevard Suite 1400 Philadelphia, PA 19103 - 1814 .Tnnn COUNTRYWIDE HOME LOANS, INC. Plaintiff VS. LINDA S. MATEER JESSICA L. MANSBERGER Defendants Attorney for Plaintiff COURT OF COMMON PLEAS CIVIL DIVISION Cumberland County No. 01-6071 CIVIL TERM PRAECIPE TO REINSTATE CIVIL ACTION/MORTGAGE FORECLOSURE TO THE PROTHONOTARY: Kindly reinstate the Civil Action in with reference to the above captioned matter. Mortgage Foreclosure Date: November 20, 2001 Attorney for Plaintiff MXM,SVC DEPT SHERIFF'S RETURN - OUT OF COUNTY CASE NO: 2001-06071 P COMMONWEALTH OF PENNSYLVANIA: COUNTY OF CUMBERLAND COUNTRYWIDE HOME LOANS INC VS MATEER LINDA S R. Thomas Kline , Sheriff or Deputy Sheriff who being duly sworn according to law, says, that he made a diligent search and and inquiry for the within named DEFENDANT , to wit: MATEER LINDA S but was unable to locate Her in his bailiwick. deputized the sheriff of DAUPHIN County, serve the within COMPLAINT - MORT FORE He therefore Pennsylvania, to On December llth , 2001 , this office was in receipt of the attached return from DAUPHIN Sheriff's Costs: Docketing Out of County Surcharge Dep Dauphin Co 18.00 9.00 10.00 29.25 .00 66.25 12/11/2001 FEDERM3tN & PHELAN RI Thomas Kline Sheriff of Cumberland County Sworn and subscribed to before me this /2 ~ day of ~ A.D. Prothonotary' In The Court of Common Pleas of Cumberland County, Pennsylvania Countrywide Home Loans Inc. VS. Linda S. Mateer et al SERVE: Linda S. Mateer NO. 01 6071 civil NOW, November 27, 2001 , I, SHERIFF OF CUMBERLAND COUNT'Y, PA, do hereby deputize the Sheriff of Dautmin County to execute this Writ, this deputation being made at the request and risk of the Plaintiff. Sheriff of Cumberland County, PA within Affidavit of Service ,20__,at o'clock M. served the upon at by handing to and made known to copy of the original So answers, the contents thereof. Sworn and subscribed before me this __ day of ,20 Sheriff of County, PA COSTS SERVICE MILEAGE AFFIDAVIT FEDERMAN AND PHELAN By: FRANK FEDERMAN Identification No. 12248 Attorney for Plaintiff ONE PENN CENTER AT SUBURBAN STATION 1617 JOHN F. KENNEDY BLVD., SUITE 1400 PHILADELPHIA, PA 19103-1814 (215) 563-7000 COUNTRYWIDE HOME LOANS, INC. 7105 CORPORATE DRIVE PLANO, TX 75024 Plaintiff, LINDA S. MATEER JESSICA L. MANSBERGER Defendant(s). CUMBERLAND COUNTY COURT OF COMMON PLEAS CIVIL DIVISION NO. 01-6071 CIVIL PRAECIPE FOR JUDGMENT FOR FAILURE TO ANSWER AND ASSESSMENT OF DAMAGES TO THE PROTHONOTARY: Kindly enter judgment in favor of the Plaintiff and against LINDA S. MATEER and JESSICA L. MANSBERGER, 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 Plaintiff's damages as follows: As set forth in Complaint Interest from 9/2/01 to 1/21/02 TOTAL $66,720.33 $2,003.62 $68,723.95 I hereby certify that (1) the addresses of the Plaintiff and Defendant(s) are as shown above, and (2) that notice has been given in accordance with Rule 237.1, copy attached. FRANK FEDERMAN, ESQUIRE Attorney for Plaintiff DAMAGES ARE HEREBY ASSESSED AS INDICATED. · FEDERMANAND PHELAN Frank Federman, Esquire Identification No. 12248 One Penn Center Plaza at Suburban Station, Suite 1400 Philadelphia, PA 19103-1799 (215) 563-7000 ATTORNEY FOR PLAINTIFF COUNTRYWIDE HOME LOANS, Plaintiff VS. INC. : COURT OF COMMON PLEAS : CIVIL DIVISION : CUMBERLAND COUNTY LIN-DA S. MATEER JESSICA L. MANSBERGER : NO.01-6071 CIVIL Defendant TO: JESSICA L. MANSBERGER 223 RENO STREET NEW CUMBERLAND, PA 17070 DATE OF NOTICE: DECEMBER 27, 2001 THIS FIRM IS A DEBT COLLECTOR ATTEMPTING T~_~I~LECT A DEBT. THIS NOTICE IS SENT TO YOU IN AN ATTEMPT ~~jTHE INDEBTEDNESS REFERRED TO HEREIN, D~RID ~ INFOR~OBTAINED FROM YOU WILL BE USED FOR THAT PURPOSE. IF YOU H~VE PREVIOUSLY RECEIVED A DISCHARGE IN BkNKRUPTCY, THIS CORRESPONDENCE IS NOT ~dgD SHOULD NOT BE CONSTRUED TO BE AN ATTEMPT TO COLLECT A DEBT, BUT ONLY AS ENFORCEMENT OF LIEN AGAINST PROPERTY. OR N I 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 FEDERM3LND. ND PHELAN, L.L.P. Frank Federman, Esquire Identification No. 12248 One Penn Center Plaza at Suburban Station, Suite 1400 Philadelphia, PA 19103-1799 (215) 563-7000 ATTOP/qEY FOR PLAINTIFF COUNTRYWIDE HOME LOANS, Plaintiff VS. LINDA S. MATEER JESSICA L. MANSBERGER INC. : COURT OF COMMON PLEAS : CIVIL DIVISION : CUMBERLAND COUNTY : NO. 01-6071 CIVIL Defendant (s) TO: LINDA S. MATEER 111 LAKE DRIV~ MIDDLETOWN, PA 17057 DATE OF NOTICE: DECEMBER 27. 2001 ~ THIS FIRM IS A DEBT COLLECTOR ATTEMPT OLLECT A DEBT. THIS NOTICE IS SENT TO YOU IN AN ATTEMPT'T~ COLLECT THE INDEBTEDNESS REFERRED TO HEREIN, AND ANY INFORMATION OBTAINED FROM YOU 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 AS ENFORCEMENT OF LIEN AGAINST PROPERTY. I~ORTANTNOTICE 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 FEDERMAN and PHELAN By: FRANK FEDERMAN Identification No. 12248 ONE PENN CENTER AT SUBURBAN STATION 1617 JOHN F. KENNEDY BLVD., SUITE 1400 PHILADELPHIA, PA 19103-1814 (215) 563-7000 COUNTRYWIDE HOME LOANS, INC. 7105 CORPORATE DRIVE Plaintiff, LINDA S. MATEER JESSICA L. MANSBERGER Defendant(s). ATTORNEY FOR PLAINTIFF CUMBERLAND COUNTY COURT OF COMMON PLEAS CIVIL DIVISION NO. 01-6071 CIVIL VERIFICATION OF NON-MILITARY SERVICE FRANK FEDERMAN, ESQUIRE, hereby verifies that he is attorney for the Plaintiffin 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 LINDA S. MATEER is over 18 years of age and resides at, 111 LAKE DRIVE, MIDDLETOWN, PA 17057. (c) that defendant JESSICA L. MANSBERGER is over 18 years of age, and resides at, 223 RENO STREET, NEW CUMBERLAND, PA 17070. This statement is made subject to the penalties of 18 Pa. C.S. Section 4904 relating to unswom falsification to authorities. FRANK FEDERMAN, ESQUIRE Attorney for Plaintiff (Rule of Civil Procedure No. 236) - Revised IN THE COURT OF COMMON PLEAS OF CUMBERLAND COUNTY, PENNSYLVANIA CIVIL ACTION - LAW COUNTRYWIDE HOME LOANS, INC. 7105 CORPORATE DRIVE Plaintiff, LINDA S. MATEER JESSICA L. MANSBERGER Defendant(s). CUMBERLAND COUNTY COURT OF COMMON PLEAS : CIVIL DIVISION : NO. 01-6071 CIVIL Notice is given that a Judgment in the above-captioned matter has been entered against you on DEPUTY If you have any questions concerning this matter, please contact: FRANK FEDERMAN, ESQUIRE Attomey for Plaintiff ONE PENN CENTER AT SUBURBAN STATION 1617 JOHN F. KENNEDY BLVD., SUITE 1400 PHiLADELPHIA, PA 19103-1814 (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 CORKESPONDENCENDENCE IS NOT AND SHOULD NOT BE CONSTRUED TO BE AN ATTEMPT TO COLLECT A DEBT, BUT ONLY ENFORCEMENT OF A LIEN AGAINST PROPERTY.** PRAECIPE FOR WRIT OF EXECUTION - (MORTGAGE FORECLOSURE) P.1LC.P. 3180-3183 COUNTRYWIDE HOME LOANS, INC. Plaintiff, LINDA S. MATEER JESSICA L. MANSBERGER Defendant(s)· No. 01-6071 CIVIL TO THE DIRECTOR OF THE OFFICE OF THE PROTHONOTARY: Issue writ of execution in the above matter: Amount Due Interest from 1/22/02 to 6/5/02 (per diem -11.30) TOTAL $68,723.95 $1,514.20 $70,238.15 and Costs FRANK'FEDERM~N, E~QU~IRE One Penn Center at Suburban Station 1617 John F. K~medy Boulevard, Suite 1400 Philadelphia, PA 19103-1814 Attorney for Plaintiff Note: Please attach description of property.No. Property. Ad.ess: 2?.3 Reno Street. New Cumberland, PA [?070 County.: Cumberland Leant Descriotion: ALL THAT CERTAIN TRACT OR PARCEL OF L,.~'qD .AND PREMISES, SITUATE, LYING AND BEING IN THE BOROUGH OF NEW CUMBERLAND IN THE COUNTY OF CUMBERLAND AND COMB, IONN~EALTH OF PENNSYLVANIA. MORE PARTICULARLY DESCRIBED AS FOLLOWS: BEGINNING AT A POINT ON THE SOUTHEAST CORNER OF RENO .-~ND TAYLOR AVENUE; THENCE SO~ARDLY ALONG SAID RENO STREET 16 1/2 FEET TO THE DIVIDING LiNE OR WALL ON PROPERTY NOW OR LATE OF D.Y. LE,'~HART; THENCE EASTWARDLY ALONG SAID DIVIDING LINE AND AT RIGHT ANGLES WITH RENO STREET 140 FEET TO THE LINE OF CEDAR AVE,'~UE; THENCE NORTt-I~/ARDLY SAID CEDAR AVENUE ..~¥D PARALLEL WITH RENO STREET 16 1/2 FEET TO TAYLOR AVENUE; THENCE WESTWARDLY ALONG THE LINE OF SAID TAYLOR AVENUE bio FEET TO THE POINT OR PLACE OF BEGINNING. HAVING THEREON ERECTED A FIL~ME DWELLING HOUSE KNOWN AND NUMBERED AS 223 RENO STREET. BEING THE SAME PREMISES WHICH RIGHARD LEHMAaN AND BARBARA L LEHMAN, H/W, BY THEIR DEED DATED FEBRUARY 22, 2001, AND ABOUT TO BE RECORDED HEREWITH IN THE OFFICE OF THE RECORDER OF DEEDS OF CUMBEILLAND COUNTY, PENNSYLVANIA, GR.-~NTED AND CONVEYED UNTO LINDA S. MATEER ,-~'~1) JESSICA L. MANSBERGER. MORTGAGORS HEREIN. COUNTRYWIDE HOME LOANS, INC. : : Plaintiff, : LINDA S. MATEER : JESSICA L. MANSBERGER : Defendant(s). : CUMBERLAND COUNTY COURT OF COMMON PLEAS CIVIL DIVISION NO. 01-6071 CIVIL AFFIDAVIT PURSUANT TO RULE 3129 (Affidavit No. 1) COUNTRYWIDE HOME LOANS~ INC., Plaintiff in the above action, by its attorney, FRANK FEDERMAN, ESQUIRE, sets forth as of the date the Praeeipe for the Writ of Execution was filed the following information concerning the real property located at ,223 RENO STREET, NEW CUMBERLAND, PA 17070. 1. Name and address of Owner(s) or reputed Owner(s): Name Last Known Address (if address cannot be reasonably ascertained, please indicate) LINDA S. MATEER 111 LAKE DRIVE MIDDLETOWN, PA 17057 JESSICA L. MANSBERGER 223 RENO STREET NEW CUMBERLAND, PA 17070 2. Name and address of Defendant(s) in the judgment: LINDA S. MATEER 111 LAKE DRIVE MIDDLETOWN, PA 17057 JESSICA L. MANSBERGER 223 RENO STREET NEW CUMBERLAND, PA 17070 3. Name and last known address of every judgment creditor whose judgment is a record lien on the real property to be sold: Sanle Last Known Address (if address cannot be reasonably ascertained, please indicate) None. 4. Name and address of last recorded holder of every mortgage of record: Nanle Last Known Address (if address cannot be reasonably ascertained, please indicate) None. 5. Name and address of every other person who has any record lien on the property: Salne Last Known Address (if address cannot be reasonably ascertained, please indicate) None. 6. Name and address of every other person who has any record interest in the property and whose interest may be affected by the sale. Name Last Known Address (if address cannot be reasonably ascertained, please indicate) None. 7. Name and address of every other person of whom the plaintiffhas knowledge who has any interest in the property which may be affected by the sale: Name Last Known Address (if address cannot be reasonably ascertained, please indicate) Tenant/Occupant 223 RENO STREET NEW CUMBERLAND, PA 17070 Domestic Relations of Cumberland County 13 North Hanover Street Carlisle, PA 17013 Commonwealth of Pennsylvania Department of Welfare PO Box 2675 Harrisburg, PA 17105 I verify that the statements made in this affidavit are tree and correct to the best of my personal knowledge or information and belief. I understand that false statements herein are made subject to the penalties of 18 Pa. C.S. Sec. 4904 relating to unsworn falsification to authorities. January 21, 2002 DATE FRANK FEDERMAN, ESQUIRE Attorney for Plaintiff FEDERMAN and PHELAN By: FRANK FEDERMAN Identification No. 12248 ONE PENN CENTER AT SUBURBAN STATION 1617 JOHN F. KENNEDY BLVD., SUITE 1400 PHILADELPHIA, PA 19103-1814 (215) 563-7000 COUNTRYWIDE HOME LOANS, INC. Plaintiff, LINDA S. MATEER JESSICA L. MANSBERGER Defendant(s). ATTORNEY FOR PLAINTIFF CUMBERLAND COUNTy COURT OF COMMON PLEAS CIVIL DMSION NO. 01-6071 CIVIL _CERTIFICATION FRANK FEDERMAN, ESQUIRE, hereby verifies that he is attorney for the Plaintiff in the above-captioned matter, and that the premises are not subject to the provisions of Act 91 because it is: ( ) an FHA mortgage ( ) non-owner occupied ( ) vacant (X) Act 91 procedures have been fulfilled This certification is made subject to the penalties of 18 Pa. C.S. Section 4904 relating to unsworn falsification to authorities. F~qk FED~MAN, E~QUIRE Attorney for Plaintiff COUNTRYWIDE HOME LOANS, INC. Plaintiff, LINDA S. MATEER JESSICA L. MANSBERGER Defendant(s). TO: LINDA S. MATEER 111 LAKE DRIVE MIDDLETOWN, PA 17057 CUMBERLAND COUNTY No. 01-6071 CIVIL January21,2002 JESSICA L. MANSBERGER 223 RENO STREET NEW CUMBERLAND, PA 17070 **THIS FIRM IS A DEBT COLLECTOR ATTEMPTING TO COLLECTA DEBTAND ANY INFORMATION OBTAINED WILL BE USED FOR THAT PURPOSE. IF YOU HA VE PREVIOUSLY RECEIVED A DISCHARGE IN B,4NKRUPTCY 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 ~ 223 RENO STREET~ NEW CUMBERLAND~ PA 17070~ is scheduled to be sold at the Sheriffs Sale on JUNE 5~ 2002 at 10:00 a.m. in the Cumberland County Courthouse, South Hanover Street, Carlisle, PA 17013, to enforce the court judgment of 68~723.95 obtained by COUNTRYWIDE HOME LOANS, INC. (the mortgagee) against you. In the event the sale is continued, an announcement will be made at said sale in compliance with Pa.R.C.P., Rule 3129.3. 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. You may be able to stop the sale by filing a petition asking the Court to strike or open the judgment, if the judgment was improperly entered. You may also ask the Court to postpone the sale for good cause. You may also be able to stop the sale through other legal proceedings. You may need an attorney to assert your fights. The sooner you contact one, the more chance you will have of stopping the sale. (See notice on page two on how to obtain an attorney.) YOU MAY STILL BE ABLE TO SAVE YOUR PROPERTY AND YOU HAVE OTHER RIGHTS EVEN IF THE SHERIFF'S SALE DOES TAKE PLACE. 1. If the 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 Sheriffthe 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 Sheriffwithin 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 Sheriffwithin 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 ~oper~/Address: ?,~ Reno Street. New Cumberland. PA 17070 Count: Cumberland Legal Descriotion: ALL THAT CERTAIN TRACT OR PARCEL OF LA2~D ..V'~D PREMISES, SITUATE, LYING A,~D BEING IN THE BOROUGH OF NEW CUMBERLAND IN TIlE COUNTY OF CUMBERLAND AND COM3,1ON~/EALTH OF PENNSYLVANIA. MORE PARTICULARLY DESCRIBED AS FOLLOWS: BEGINNING AT A POINT ON THE SOUTHEAST CORNER OF RENO AND TAYLOR AVENUE; THENCE SOUTHWARDLY ALONG SAID RENO STREET 16 I/2 FEET TO THE DIVIDI~IG LL'qE OR WALL ON PROPERTY NOW OR LATE OF D.Y. LENHART; THENCE EASTWARDLY ALONG SAiD DIVIDING LLNE AND AT RIGHT ANGLES WITH RENO STREET 140 FEET TO THE LINE OF CEDAR AVE,~E; THENCE NORTHWARDLY ALONG SAID CEDAR AVENUE ,.~ND PARALLEL WITH RENO STREET 16 I~ FEET TO TAYLOR AVENUE; THENCE WESTWARDLY ALONG THE LINE OF SAID TAYLOR AVENUE 140 FEET TO THE POINT OR PLACE OF BEGINNING. HAVING THEREON ERECTED A FRAME DWELLING HOUSE KNOWN AND NUMBERED AS ?~3 RENO STREET. BEING THE SAME PREMISES WHICH RIGHARD LEHMAN ~aND BARBARA L LEHMAN, H/W, BY THEIR DEED DATED FEBRUARY 22., 2001, AiND ABOUT TO BE RECORDED HEREWITH IN THE OFFICE OF THE RECORDER OF DEEDS OF CUMBERLAi"~D COUNTY, PENNSYLVANLA, GRAi'~I'ED AND CON~EYED UNTO LINDA S. MATEER AI~D JESSICA L. MANSBERGER, MORTGAGORS HEREIN. Countrywide Home Loans, Inc. VS Linda S. Mateer and Jessica L. Mansberger In The Court of Common Pleas of Cumberland County, Pennsylvania Writ No. 2001-6071 Civil Term R. Thomas Kline, Sheriff, who being duly sworn according to law, states this writ is returned STAYED pursuant to instructions from Attorney Frank Federman. Sheriff's Costs: Docketing 30.00 Surcharge 30.00 Posting Handbills Law Library .50 Prothonotary 1.00 Share of Bills Mileage 11.04 Levy 15.00 Out of County 9.00 Dauphin County 29.25 Advertising Certified Mail Poundage 2.52 Law Journal Patriot News $128.31 paid by attorney 3-18-02 This ,20 ~ day of ~ R. Thomas Kline, Sheriff 2002, A.D. ~ Q. ~t~.~. ~ Prothonotary Real Estt{te~)eputy COUNTRYWIDE HOME LOANS, INC. Plaintiff, V. LINDA S. MATEER JESSICA L. MANSBERGER Defendant(s). CUMBERLAND COUNTY COURT OF COMMON PLEAS CIVIL DIVISION NO. 01-6071 CIVIL AFFIDAVIT PURSUANT TO RULE 3129 (Affidavit No. 1) COUNTRYWIDE HOME LOANS, INC., 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 ,223 RENO STREET~ NEW CUMBERLAND~ PA 17070. 1. Name and address of Owner(s) or reputed Owner(s): Name Last Known Address (if address cannot be reasonably ascertained, please indicate) LINDA S. MATEER JESSICA L. MANSBERGER 111 LAKE DRIVE MIDDLETOWN, PA 17057 223 RENO STREET NEW CUMBERLAND, PA 17070 2. Name and address of Defendant(s) in the judgment: LINDA S. MATEER 111 LAKE DRIVE MIDDLETOWN, PA 17057 JESSICA L. MANSBERGER 223 RENO STREET NEW CUMBERLAND, PA 17070 3. Name and last known address of every judgment creditor whose judgment is a record lien on the real property to be sold: Nanle None. Last Known Address (if address cannot be reasonably ascertained, please indicate) 4. Name and address of last recorded holder of every mortgage of record: Name None. Last Known Address (if address cannot be reasonably ascertained, please indicate) 5. Name and address of every other person who has any record lien on the property: Name Last Known Address (if address cannot be reasonably ascertained, please indicate) None. 6. Name and address of every other person who has any record interest in the property and whose interest may be affected by the sale. Name None. Last Known Address (if address cannot be reasonably ascertained, please indicate) 7. Name and address of every other person of whom the plaintiff has knowledge who has any interest in the property which may be affected by the sale: Name Tenant/Occupant Domestic Relations of Cumberland County Commonwealth of Pennsylvania Department of Welfare Last Known Address (if address cannot be reasonably ascertained, please indicate) 223 RENO STREET NEW CUMBERLAND, PA 17070 13 North Hanover Street Carlisle, PA 17013 PO Box 2675 Harrisburg, PA 17105 I verify that the statements made in this affidavit are true and correct to the best of my personal knowledge or information and belief. I understand that false statements herein are made subject to the penalties of 18 Pa. C.S. Sec. 4904 relating to unsworn falsification to authorities. January 21, 2002 DATE FRANK FEDERMAN, ESQUIRE Attorney for Plaintiff COUNTRYWIDE HOME LOANS, INC. Plaintiff, ¥. LINDA S. MATEER JESSICA L. MANSBERGER Defendant(s). TO: LINDA S. MATEER 111 LAKE DRIVE MIDDLETOWN, PA 17057 CUMBERLAND COUNTY No. 01-6071 CIVIL January21,2002 JESSICA L. MANSBERGER 223 RENO STREET NEW CUMBERLAND, PA 17070 **THIS FIRM IS A DEBT COLLECTOR ATTEMPTING TO COLLECT A DEBT AND ANY [NFORMATION OBTAINED WILL BE USED FOR THAT PURPOSE. IF YOU HA VE 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 ~ 223 RENO STREET~ NEW CUMBERLAND~ PA 17070~ is scheduled to be sold at the Sheriffs Sale on JUNE 5~ 2002 at 10:00 a.m. in the Cumberland County Courthouse, South Hanover Street, Carlisle, PA 17013, to enforce the court judgment of 68~723.95 obtained by COUNTRYWIDE HOME LOANS~ INC. (the mortgagee) against you. In the event the sale is continued, an announcement will be made at said sale in compliance with Pa.R.C.P., Rule 3129.3. NOTICE OF OWNER'S RIGHTS YOU MAY BE ABLE TO PREVENT THIS SHERIFF'S SALE To prevent this SherifCs Sale, you must take immediate action: The sale will be cancelled if you pay to the mortgagee the back payments, late charges, costs and reasonable attorney's fees due. To find out how much you must pay, you may call: (215) 563-7000. You may be able to stop the sale by filing a petition asking the Court to strike or open the judgment, if the judgrnent was improperly entered. You may also ask the Court to postpone the sale for good cause. You may also be able to stop the sale through other legal proceedings. You may need an attorney to assert your rights. The sooner you contact one, the more chance you will have of stopping the sale. (See notice on page two on how to obtain an attorney.) YOU MAY STILL BE ABLE TO SAVE YOUR PROPERTY AND YOU HAVE OTHER RIGHTS EVEN IF THE SHERIFF'S SALE DOES TAKE PLACE. 1. If the Sheriff's Sale is not stopped, your property will be sold to the highest bidder. You may find out the price bid by calling (215) 563-7000. 2. You may be able to petition the Court to set aside the sale if the bid price was grossly inadequate compared to the value of your property. 3. The sale will go through only if the buyer pays the Sheriffthe 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 Sheriffwithin 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 Property Address: 223 Reno Street New Cumberland. PA 17070 Legal Description: County.: Cumberland ALL THAT CERTAIN TRACT OR PARCEL OF LA.ND ..~ND PREMISES, SITUATE, LYING AND BEING IN THE BOROUGH OF NEW CUMBERLAND IN THE COUNTY OF CUMBERLA,ND AND COM?,'IO?O~EALTH OF PENNSYLVANIA. MORE PARTICULARLY DESCRIBED AS FOLLOWS: BEGINNING AT A POINT ON THE SOUTHEAST COR2qER OF RENO AND TAYLOR AVENUE; THENCE SOU'THWARDLY ALONG SAID RENO STREET 16 I12 FEET TO THE DIVIDING LINE OR WALL ON PROPERTY NOW OR LATE OF D.Y. LENTIART; THENCE EASTWARDLY ALONG SAID DIVIDING LINE A,'qD AT RIGHT ANGLES WITH RENO STREET 140 FEET TO THE LINE OF CEDAR AVENUE; THENCE NORTHWARDLY .~LONG SAID CEDAR AVENUE .~'qD PAIL~,LLEL WITH RENO STREET 16 I~ FEET TO TAYLOR AVENUE; THENCE WESTWARDLY ALONG THE LINE OF SAID TAYLOR AVENUE 140 FEET TO THE POINT OR PLACE OF BEGINNING. HAVING THEREON ERECTED A FRAME DWELLING HOUSE ~NOWN AND NUMBERED AS 223 RENO STREET. BEING THE SAME PREMISES WHICH RIGHARD LEHMAN A~ND BARBARA L LEHMAN, H/M/, BY THEIR DEED DATED FEBRUARY 22, 2001, AND ABOUT TO BE RECORDED HEREWITH IN THE OFFICE OF THE RECORDER OF DEEDS OF CUMBERLAND COUNTY, PENNSYLVANIA, GRANTED &ND CONVEYED UNTO LINDA S. MATEER AND JESSICA L. MANSBERGER. MORTGAGORS HEREIN. · . WRIT OF EXECUTION and/or ATTACHMENT COMMONWEALTH OF PENNSYLVANIA) NO 01-6071 Civil COUNTY OF CUMBERLAND) CIVIL ACTION - LAW TO THE SHERIFF OF CUMBERLAND COUNTY: To satisfy the debt, interest and costs due COUNTRYWIDE HOME LOANS, INC., PLANTIFF(S) From LINDA S. MATEER, 111 LAKE DRIVE MIDDLETOWN, PA 17057 AND JESSICA L. MANSBERGER, 223 RENO STREET, NEW CUMBERLAND, PA 17070 (1) You are directed to levy upon the property of the defendant(s) and to sell SEE LEGAL DESCRIPTION (2) You are also cFtrected 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 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 defendant(s) not levied upon an subject to attachment is found in the possession of anyone other than a named garnishee, you are directed to notify him/her that he/she has been added as a garnishee and is enjoined as above stated. Amount Due $68, 723.95 L.L. $.50 Interest FROM 1/22/02 TO 6/5/02 (PER DIEM - 11.30) $1,514.20 AND COSTS Due Prothy $1.00 Other Costs Atty's Comm % Atty Paid $231.55 Plaintiff Paid Date: FEBRUARY 4, 2002 REQUESTING PARTY: Name FRANK FEDERMAN, ESQUIRE CURTIS R. LONG Prothonotary, Civil Division Address: ONE PENN CENTER AT SUBURBAN STATION 1617 JOHN F. KENNEDY BOULEVARD, SUITE 1400 PHILADELPHIA, PA 19103-1814 Attorney for: PLAINTIFF Telephone: 215-563-7000 Supreme Court ID No. 12248 REAL ESTATE SALE No. iq On February 7, 2002, the sheriff levied upon the defendant's interest in the real property situated in New Cumberland Borough, Cumberland County, PA, known and numbered as 223 Reno $Reet, New Cumberland, and more fully described on Exhibit "A" filed with this writ and by this reference incorporated herein. Date: February 7, 2002 t~ea sta eputy