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HomeMy WebLinkAbout99-07113 M? `I / ' ?3 Y ? II ? ? f J 1? Y ?YjI {'? k ?' ? ?? ? t 1 '. I ? b?•?? ?' f ,jf?Yy }?JYA STATE OF PENNSYLVANIA, SS. COUNTY OF CUMBERLAND Robert P Ziegler 1 ----- - -- -- -°-- - --- - - - - --- Recorder of Deeds in and for said County and State do hereby certify that the Sheriff's Deed in which ---------------- ---------- Countrywide Home Loans Inc --------------------------------------------------- is the grantee 7th the same having been sold to said grantee on the _______________________________________________ day of ----__--_ June ------------------_______ A. D., l9C 2000, under and by virtue of a writ______________ Execution 17th ------------------------------------------------issued on the ------------------------------------- February 2000 day of __________________________ A. D., Pf, out of the Court of Comman Pleas of said County as of Civil 99 --------------------------------------------------------------------------------- Term, 19------- 7113 Countrywide Home Loans Inc fka Countrywide Funding Corp Number--------------, at the suit of --------------------------------------------------------------- kqainst__ Herbert W Gilsdorf it & Robyn L -------- is ------------------------------------------ duly recorded in Sheriff's Deed Book No.___ 224Page ----------- 902 IN TESTIMONY WHEREOF, I have hereunto set my hand and seal of said office this __.z.y`? ___ day of -----------5 ------------- A. D., I9 w_v_ jRecoAcr of Deeds Recorder d Deeds. camberltnd ft* C011519, ?l my Commission Expues the First MoGy o1Ian. 2002 Countrywide Home Loans Inc., In the Court of Common Pleas of F/K/A Countrywide Funding Corp. Cumberland County, Pennsylvania -vs- No. 99-7113 Civil Herbert W. Gilsdorf, Jr. and Robyn L. Gilsdorf Richard E. Smith, Deputy Sheirff, who being duly sworn according to law, says on February 29, 2000, at 4:37 o'clock P.M. he served a true copy of real Estate Writ Notice Poster and Description in the above entitled action upon one of the within named defendants to wit: Herbert W. Gilsdorf, Jr. by making known unto Herbert W. Gilsdorf, Jr, at Cumberland County Prison I IOI Claremont Road, Carlisle, Cumberland County, Pennsylvania, its contents and at the same time handing to him personally the said true and attested copies of the same. 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 copy of the pendency of the action to one of the within named defendants to wit: Herbert W. Gilsdorf, Jr by first class mail to Cumberland County Prison 1101 Claremont Road, Carlisle, Pennsylvania. This letter was mailed under the date of April 20, 2000 and never returned to the Sheriffs Office. R. Thomas Kline, Sheriff who being duly sworn according to law, says he made diligent search and inquiry for one of the wihtin named defendants to wit: Robyn L. Gilsdorf but was unable to locate her in his bailiwick after fifteen attempts. He therefore returns same not found as to Robyn Gilsdorf R. Thomas Kline, Sheirff, 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 tendency of the action to one of the within named defendants to wit: Robyn L. Gilsdorf by Certified Mail Return Receipt Requested, Restricted Delivery, Deliver To Addressee Only to 9 Briarwood Court, Camp Hill, Pennsylvania. This letter was mailed under the date of May 4,2000 and received by Robyn Gilsdorf on May 6, 2000 the return receipt card signed by Robyn Gilsdorf. Harold J. Weary Deputy Sheriff, who being duly sworn according to law, says on March 30, 2000 at 4:58 o'clock P.M. EST, he posted a copy of Real estate Writ Notice Poster and Description on the property of Herbert W. Gilsdorf, Jr. and Robyn L. Gilsdorf located at 9 Briarwood Court, Camp Hill, 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: Robyn L. Gilsdorf by first class mail to 9 Briarwood Court, Camp Hill, Pennsylvania. This letter was mailed under the date of May 8, 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 ahd been given according to law,exposed the wihtin 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 suns of $ 1.00 to Attorney Leon P. Haller for Countrywide Home Loans Inc . It being the highest bid and best price quoted for the same Countrywide I tome Loans Inc of 7101 Corporate Drive, PTX B-35, Plano, TX being the buyer in this execution paid to Sheriff R. Thomas the sutn of $ 1,176.18 it being costs. Sheriffs Costs: Docketing 30.00 Poundage 23.06 Posting Bills 15.00 Advertising 15.00 Acknowledging Decd 30.00 Auctioneer 10.00 Law Library .50 County 1.00 Mileage 24.80 Certified Mail 7.12 Levy 15.00 Surcharge 30.00 Law Journal 502.55 Patriot News 395.85 Share of Bills 24.80 Distribution of Proceeds 25.00 Sheriffs Deed 26.50 $ 1,176.18 Pd By Atty 6/26/00 Sworn and Subscribed To Before Me ri ThisO Day o f? R. Thomas Kline, Sheriff 2000,A.D. -r-71`-`t_P_? Prothonotary 41141 BY Real Estate Deputy 3D. di) O I.y C', V,,?A C/2 -7 9p/•f Zw. 9 90.2 y THE PATRIOT NEWS THE SUNDAY PATRIOT NEWS Proof of Publication IlnderRct No. 587. Rooroued Mau 16. 1929 Commonwealth of Pennsylvania, County of Dauphin) ss 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 were established March 4th, 1854, and September 181h, 1949, respectively, and all have been continuously published ever since; That the printed notice or publication which is securely attached hereto is exactly as printed and published in their regular daily and/or Sunday and Metro editions/issues which appeared on the 2nd, 9th 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 the said Company and subsequently duly recorded in the office for the Recording of Deeds in and for said County of Dauphin in fv)jscellaneous Book "M", Volume 14, Page 317. / A n /_ - PUBLICATION _ ____Vtj COPY Sworn to and subscrib d before the I 2nd day ofe 2,00A.D. Noladal seal Tarry L. Russell, Nolary Public (( Harrisburg, eauprun county OT Y PUBLIC My Commission Expires June a, 2004 Member.Pennisslo aASSbclaliondNOtaies mm(ss(on expires June 6, 2002 an I CUMBERLAND COUNTY SHERIFFS OFFICE CUMBERLAND COUNTY COURTHOUSE CARLISLE, PA. 17013 Statement of Advertising Costs To THE PATRIOT-NEWS CO., Dr. For publishing the notice or publication attached hereto on the above stated dates $ 394.35 Probating same Notary Fee(s) $ 1.50 Total $ 395.85 isher's Receipt for Advertising Cost THE PATRIOT-NEWS CO., publisher of THE PATRIOT-NEWS and THE SUNDAY PATRIOT-NEWS, newspapers of general circulation, hereby acknowledge receipt of the aforesaid notice and publication costs and certifies that the same have been duly paid. THE PATRIOT-NEWS CO. By .................................................................... SA LE#13 PROOF OF PUBLICATION OF NOTICE IN CUMBERLAND LAN JOURNAL (Under Act No. 587, approved May 16, 1929), P. L.1784 STATE OF PENNSYLVANIA : COUNTY OF CUMBERLAND : SS. Roger M. Morgenthal, Esquire, Editor of the Cumberland Law Journal, of the County and State aforesaid, being duly swom, according to law, deposes and says that the Cumberland Law Journal, a legal periodical published in the Borough of Carlisle in the County and State aforesaid, was established January 2, 1952, and designated by the local courts as the official legal periodical for the publication of all legal notices, and has, since January 2, 1952, been regularly issued weekly in the said County, and that the printed notice or publication attached hereto is exactly the same as was printed in the regular editions and issues of the said Cumberland Law Journal on the following dates, viz: APRIL 28, MAY 5,12, 2000 Affiant further deposes that he is authorized to verify this statement by the Cumberland Law Journal, a legal periodical of general circulation, and that he is not interested in the subject matter of the aforesaid notice or advertisement, and that all allegations in the foregoing statements as to time, place and character of publication are true. HEAT. ESTATE BALE NO. 13 Writ No. 994113 Civil 1 Countrywide Home Loans Inc., jZOgTM, Morgenthal, Editor f/k/a CountryMde Funding Corp. V5. Herbert W. Glisdorf. Jr. and Robyn L. Gilsdorf Ally.: Joseph A. Goldbeck, Jr. ALL THAT CERTAIN tract or par- cel of land and premises, situate, lying and being In dre Townsltlp of Hamp- den in the County of Cumberland and Commonwealth of Pennsylvania. snore particularly described as fol- lows: BEGINNING at a point on the east- erly line of Briarwood Court, a 50 foot wide right-of-way, whlch said point is located and referenced 340.00 feet in a southerly direction from the in- tersection of the easterly line of Brt- d 1 southerly line SWORN TO AND SUBSCRIBED before me this 12 day of MAY. 2000 LOIS E. SITYOER, W Cory Pr6..Xc CurliJa Coro, Cumbedaod Courtly, PA My Commu,io Eapiror March S, 7001 anvood court an t to Real Estate No 13 $ 1000.00 advance costs paid 02/22/00 Atty Joseph Goldbeck Assessed Valuation $ 11,000 Writ No. 99-7113 Civil Term Countrywide Home Loans Inc. F/K/A Countrywide Funding Corp. -vs- Herbert W. Gilsdorf, Jr. and Robyn L. Gilsdorf 9 Briarwood Court Camp Hill, PA Real debt $ 115,389.28 Interest 6/1/99 to 2/14/00 Fr 2/14/00 to 6/7/00 2,143.61 Atty's Fees Atty's Writ Costs 121.30 Escrow Late Charges Sheriff's Costs: Docketing 30 00 Poundage . 23 06 Posting Bills . 15.00 Advertising 15.00 Acknowledging Deed 30.00 Auctioneer 10 00 Law Library . County 50 Mileage 1.00 Certified Mail 24.80 Levy 7 12 Surcharge 15.00 Postpone sale 30.00 Out of County Legal Search Law Journal 502 55 Patriot News . 395 85 Share of Bills . 24 80 Distribution of Proceeds . 25 00 Sheriffs Deed . 26.50 TAXES SEWER 560 15 Sewer lien . 462.15 GOLDBECK McCAFFERTY & McKEEVER BY: Joseph A. Goldbeck, Jr. Attorney I.D.#16132 Suite 500 - The Bourse Bldg. 111 S. Independence Mall East Philadelphia, PA 19106 215-627-1322 Attorney for Plaintiff COUNTRYWIDE HOME LOANS INC., F/K/A COUNTRYWIDE FUNDING CORP 6400 Legacy Drive Plano, TX 75024-3632 Plaintiff VS. HERBERT W. GILSDORF JR. AND ROBYN L. GILSDORF (Mortgagor(s) and Record Owner(s)) 9 Briarwood Court Camp Hill, PA 17011 Defendant(s) IN THE COURT OF COMMON PLEAS OF CUMBERLAND COUNTY CIVIL ACTION - LAW :ACTION OF MORTGAGE FORECLOSURE Term No. 99-7113-Civil AFFIDAVIT PURSUANT TO RULE 3129 COUNTRYWIDE HOME LOANS INC., f/k/a Countrywide Funding Corp., Plaintiff in the above action, by its attorney, Joseph A. Goldbeck, Jr., 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: 9 Briarwood Court, Camp Hill, PA 17011 1. Name and address of Owner(s) or Reputed Owner(s): HERBERT W. GILSDORF JR. 9 Briarwood Court Camp Hill, PA 17011 ROBYN L. GILSDORF 9 Briarwood Court Camp Hill, PA 17011 2. Name and address of Defendant(s) in the judgment: HERBERT W. GILSDORF JR. 9 Briarwood Court Camp Hill, PA 17011 ROBYN L. GILSDORF 9 Briarwood Court Camp Hill, PA 17011 3. Name and last known address of every judgment creditor whose judgment is a record lien on the property to be sold: BUREAU OF COMPLIANCE Dept. 280946 Harrisburg, PA 17128 COMMONWEALTH OF PENNSYLVANIA DEPT. OF LABOR AND INDUSTRY TO THE USE OF THE UNEMPLOYMENT COMP. FUND 16th Floor L&I Bldg. Harrisburg, PA 17121 BEARD BRADLEE C 301 Nort 32nd Street Harrisburg, PA 17109 4. Name and address of the last recorded holder of every mortgage of record: 5. Name and address of every other person who has any record interest in or record lien on the property and whose interest may be affected by the sale: 6. Name and address of every other person of whom the plaintiff has knowledge who has any record interest in the property which may be affected by the sale. 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. (attach separate sheet if more space is needed) I verify that the statements made in this affidavit are true and correct to the best of my personal knowledge or information t..- and belief. I understand subject to the penalties unsworn falsification to DATED: February 11, 2000 that false statements herein are made of 18 Pa. C.S. Section 4904 relating to authoritieWGCK n BY: Goldbeck, Jr., Esq Al FED .C. GOLDBECK MCCAFFERTY & MCKEEVER BY: Joseph A. Goldbeck, Jr. Attorney I.D.#16132 Suite 500 - The Bourse Bldg. 111 S. Independence Mall East Philadelphia, PA 19106 215-627-1322 Attorney for Plaintiff COUNTRYWIDE HOME LOANS INC., F/K/A COUNTRYWIDE FUNDING CORP. IN THE COURT OF COMMON PLEAS 6400 Legacy Drive Plano, TX 75024-3632 OF CUMBERLAND COUNTY Plaintiff CIVIL ACTION - LAW VS. :ACTION OF MORTGAGE FORECLOSURE HERBERT W. GILSDORF JR. AND ROBYN L. GILSDORF (Mortgagor(s) Term and Record Owner(s)) No. 99-7113-Civil 9 Briarwood Court Camp Hill, PA 17011 Defendant(s) THIS LAW FIRM IS A DEBT COLLECTOR AND WE ARE ATTEMPTING TO COLLECT A DEBT. THIS NOTICE IS SENT TO YOU IN AN ATTEMPT TO COLLECT A DEBT. ANY INFORMATION OBTAINED FROM YOU WILL BE USED FOR THAT PURPOSE. NOTICE OF SHERIFF'S SALE OF REAL PROPERTY TO: HERBERT W. GILSDORF JR. 9 Briarwood Court Camp Hill, PA 17011 Your house at 9 Briarwood Court, Camp Hill, PA 17011 is scheduled to be sold at Sheriff's Sale on June 7, 2000, at 10:00 a.m., in Cumberland County, Commissioners Hearing Room, 2nd Floor, Courthouse, Carlisle, PA 17013 to enforce the court judgment of $115,389.28 obtained by COUNTRYWIDE HOME LOANS INC., f/k/a Countrywide Funding Corp. against you. To prevent this Sheriff's Sale you must take immediate action: 1. The sale will be cancelled if you pay to COUNTRYWIDE HOME LOANS INC., f/k/a Countrywide Funding Corp., the back payments, late charges, costs and reasonable attorney's fees due. To find out how much you must pay call: 215-627-1322 2. You may be able to stop the sale by filing a petition asking the Court to strike or open judgment, if the judgment was 3 improperly entered. You may also ask the Court to postpone the sale for good cause. 3. You may also be able to stop the sale through other legal proceedings. You may need an attorney to assert your rights. The sooner you contact one, the more chance you will have of stopping the sale. (See notice below 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 NOT TARE 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 price by calling the Sheriff of Cumberland County at (717) 240-6390. 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 the Sheriff of Cumberland County at (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 a right to remain in the property until the full amount due is paid to the Sheriff and the Sheriff gives a deed to the buyer. At that time, the buyer may bring legal proceedings to evict you. 6. You may be entitled to a share of the money which was paid for your house. A schedule of distribution of the money bid for your house will be filed by the Sheriff thirty (30) days from the date of the Sheriff's 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 schedule of distribution is filed. 7. You may also have other rights and defenses, or ways of getting your house back, if you act immediately after the sale. YOU SHOULD TAKE THIS PAPER TO YOUR LAWYER AT ONCE. IF YOU DO NOT HAVE A LAWYER OR CANNOT AFFORD ONE, GO TO OR TELEPHONE THE OFFICE LISTED BELOW TO FIND OUT WHERE YOU CAN GET LEGAL HELP. Cumberland County Bar Association 2 Liberty Avenue, Carlisle, PA (800) 990-9108 Legal SOrviees Inc. 8 Irvine Row, Carlisle, PA 17013 (717) 243-9400 ALL THAT CERTAIN tract or parcel of land and premises., situate, lying and being In the Townrhip of Ilampden in the County of Cumberland and CommonwealLh of Pennsylvania, more particularly derlcribp-d an follows; BEGINNING at a point on the easterly line of Briarwood Court, a 50 foot wide right-of•way, which sald point iu"IOdaT-ed and referenced 340.00 feet in a southerly direction from the intersection of the easterly lire of Nriarwood Court and the southerly line of Briarwood Lana, also a 50 foot wide right-of-way, and which said point of beginning in also located at the intersection of the easterly line of Briarwood Court and tine dividing line between Lot Non. 31 and 32 on tine Plan of Lots known an Countryside, Section (A1; thence, from said point of beginning along the dividing line between Lot Non. 31 and 32, north 74 degrees 37 minuten cant, a distance of 118.00--feet to a point on the dividing line betwern'Lot Non. 32 and 25; thence, from aaid,point along the dividing line between Lot Nos. 24, 25 and 32, soutW5 degrees 23 minutes cant, a distance of 65.06 feet to a point on the dividing line between Lot Non. 32 and„33; thence, from said point along tine dividing lime between Lot Nos. 32 and 33, south GO degrees 30 minutes went, a distance of 93.02 feet to a point on a col-de-sac which in located at the southerly end of Briarwood Court; thence, from said point along a curve to the left with a radius of 50.00 feet, a distance of 47.02 feet to a point on the easterly line of Briarwood Court; thence, from said point along tbe-pasterly line of Briarwood Court, north 15 degreen 23 minutes went, a distance of 57.00 feet to a point, the point and place of BEGINNING. BEING Lot No. 32 on the Plan of Lots known an .Countryside, Section (A), prepared by Charles N. Junkina, Registered Surveyor, dated December 4, 1973 and recorded in the Office of the Recorder of Deeds of Cumberland County on April 11, 1974, in Plan Book 25, Page f,. HAVING thereon erected a dwelling house being known and numbered an premises. 9 Driarwood Cou fit, Camp Rill. Pennsylvania. Sl)n•IF.CP to 'covenantr, recorded on November 30, 1973 in the office of the Recorder of Deeds of Cumberland County in Misc. Hook 207, page 59 and to all other covenants and restrictions of record. UNDPR AND SUBJECT nevertheler,s to an easement or right-of-way La Pe_nnnylvanla Power and LighL Company for the construction or oractinn of electrical utiliLier, on the aforesaid property, either under or above ground, IMPROVEMENTS consist of a residential dwelling. BEING PREMISES: 9 Briarwood Court, Camp Hill, pA 17011 SOLD as the property of HERBERT W. GILSDORF JR. and ROBYN L. GILSDORF TAX PARCEL 1110-19-1596-121 WRIT OF EXECUTION and/or ATTACHMENT COMMONWEALTH OF PENNSYLVANIA) COUNTY OF CUMBERLAND) NO. 99-7113 CIVIL 19 CIVIL ACTION - LAW TO THE SHERIFF OF Cumberland COUNTY: To satisfy the debt, interest and costs due Countrywide Home Loans Inc., F/K/A Countrywide Funding Corp 6400 Legacy Drive Plano TX 75024-3632 PLAINTIFF(S) Herbert W. Gilsdorf Jr. and Robyn L. Gilsdorf 9 Briarvood Court Cantu Hilt PA 17011 DEFENDANT(S) (1) You are directed to levy upon the property of the defendant(s) and to 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 defendant(s) notlevieduponan subjectto attachment is found in the possession of anyoneother than a named garnishee, you are directed to notify him/herthat he/she has been added as agarnishee and is enjoined as above stated. Amount Due $115,389.28 Interest 6/1/99 to 2/14/00 L.L. $•50 Due Frothy $1.00 Atty's Comm % Other Costs Atty Paid 121 An Plaintiff Paid Date: FPhrnary117. 2nnn CurFic R- Tnng Prothonotary, Civil Division REQUESTING PARTY: Name Joseph A. Goldbeck, Jr. Address: Suite 500 - The Bourse Bldg. 111 S. Independence Mall East Philadelplda, PA 3:92:06 Attorney for: Plaintiff Telephone:(215) 627-1322 Supreme Court ID No. 16112 by: ?IU /? JF?f?Cc Deputy REAL ESTATE SALE No• 1? 0 ?n rthe sheriff levied upon the defendams Interest in the real property situated in 42, Cumberland County, Pa., known and numbered as: a4mlp- and more fully described on Exhibit "A" filed will) t? this writ and by this reference incorporated herein. D'Ito: z4 By' OG?Illis-? Ils'Jj iJ r,- IN THE COURT OF COMMON PLEAS OF CUMBERLAND COUNTY COUNTRYWIDE HOME LOANS INC., F/K/A COUNTRYWIDE FUNDING CORP. 6400 Legacy Drive Plano, TX 75024-3632 Plaintiff VS. HERBERT W. GILSDORF JR. AND ROBYN L. GILSDORF (Mortgagor(s) and Record Owner(s)) Term 9 Briarwood Court No. 99-7113-Civil Camp Hill, PA 17011 Defendant(s) PRAECIPE FOR JUDGMENT THIS LAW FIRM IS A DEBT COLLECTOR AND WE ARE ATTEMPTING TO COLLECT A DEBT OWED TO OUR CLIENT. ANY INFORMATION OBTAINED FROM YOU WILL BE USED FOR THE PURPOSE OF COLLECTING THE DEBT. Enter Judgment in favor of Plaintiff and against HERBERT W. GILSDORF JR. and ROBYN L. GILSDORF by default for want of an Answer. (g) Assess damages as follows: Debt Interest 6/ 1/99 to 2/14/00 $ 115,389.28 Total $ (Assessment of Damages attached) I CERTIFY THAT THE FOREGOING ASSESSMENT OF DAMAGES IS FOR SPECIFIED AMOUNTS ALLEGED TO BE DUE IN THE COMPLAINT AND IS CALCULABLE AS A SUM CERTAIN FROM THE COMPLAINT. I certify that written notice of the intention to file this praecipe was mailed or delivered to the party against whom judgment is to be entered and to his attorney of record, if any, after the default occurred and at least ten days prior to the date of the filing of this pr ec' e./ A I¢dpy of the notice is attached. R.C.P. 237.1 M /' 1( I n Jos LA. GoYdb k, Jr. Atto ney for P1 intiff I.D. #16132 AND NOW " -) entered in favor o COUNTRYWIDE HOME LOANS Corp., and against HERBERT W. GILSDORF JR. for want of an Answer and damages assessed FIFTEEN THOUSAND THREE HUNDRED EIGHTY NINE ($115,389.28), as per the above certificat 229 , Judgment is INC., f/k/a Countrywide Funding and ROBYN L. GILSDORF by default in the sum of ONE HUNDRED DOLLARS AND 28 CENTS Lon. Prothonotary G ,-.. !{ i.. .; , _ tom, .;.? u r?: ?? F+ i i GOLDBECK McCAFFERTY & McKEEVER BY: Joseph A. Goldbeck, Jr. Attorney I.D.#16132 Suite 500 - The Bourse Bldg. 111 S. Independence Mall East Philadelphia, PA 19106 215-627-1322 Attorney for Plaintiff COUNTRYWIDE HOME LOANS INC., IN THE COURT OF COMMON PLEAS F/K/A COUNTRYWIDE FUNDING CORP. 6400 Legacy Drive OF CUMBERLAND COUNTY Plano, TX 75024-3632 Plaintiff CIVIL ACTION - LAW VS. :ACTION OF MORTGAGE FORECLOSURE HERBERT W. GILSDORF JR. AND Term ROBYN L. GILSDORF (Mortgagor(s) No. 99-7113-Civil and Record Owner(s)) 9 Briarwood Court Camp Hill, PA 17011 Defendant(s) ORDER FOR JIIDGMENT Please enter Judgment in favor of COUNTRYWIDE HOME LOANS INC., f/k/a Countrywide Funding Corp., and against HERBERT W. GILSDORF JR. and ROBYN L. GILSDORF for failure to file an Answer in the above action within (20) days (or sixty (60) days if defendant is the United States of America) from the date of service of the Complaint, in the sum of ONE HUNDRED FIFTEEN THOUSAND THREE HUNDRED EIGHTY NINE DOLLARS AND 28 CENTS ($115,389.28). Jo p A. Go eck, Jr. At orney for Plaintiff I hereby certify that the above names are correct and that the precise residence address of the judgment creditor is 6400 Legacy Drive, Plano, TX 75024-3632 and that the name(s) and last known address(es) of the Defendant(s) is/are HERBERT W. GILSDORF JR., 9 Briarwood Court, Camp Hill, PA 17011; ROBYN L. GILS RF, 9 Briarwood Court, Camp Hill, PA 17011 GO K McC FERTY & Mc VER BY Joseph A. Goldbeck, r. Attorney for Plaintiff ?- ?, -- - _? ??: . =? =- ? ?; , ,? , ? f? ?? ASSESSMENT OF DAMAGES TO THE PROTHONOTARY: Kindly assess the damages in this case to be as follows: Principal balance $ 101,978.12 Interest from 61 1/99 through 2/14/00 6,666.72 Attorney's Fee at 5% of principal balance 5,098.91 Late Charges 343.80 Costs of Suit and Title Search 560.00 $ 114,647.55 Escrow Balance Deficit 741.73 $$ 115, 389.28 A ISIIAA- GOLD cCA FERTY & Mc VER BY: s ph A. Goldbeck, Jr. Attorney for Plaintiff AND NOW, this /7 day of lz- i damages are assessed as above. , 2000 Pro Prothy ??G -? --, - - .-_ ;`= ,- ?': - =_i -• : s ?.: ?.., -;;; L_ ` `_ ? -7 ? r_? :_J TO: ROBIN L. GILSDORF 9 Briarwood Court Camp Hill, PA 17011 COUNTRYWIDE HOME LOANS INC., F/K/A COUNTRYWIDE FUNDING CORP. IN THE COURT OF COMMON PLEAS 6400 Legacy Drive Plano, TX 75024-3632 OF CUMBERLAND COUNTY Plaintiff Vs. CIVIL ACTION - LAW HERBERT W. GILSDORF JR. AND ROBYN L. GILSDORF (Mortgagor(s)) ACTION OF MORTGAGE FORECLOSURE (Record Owner(s)) 9 Briarwood Court Term Camp Hill, PA 17011 No. 99-7113-CIVIL Defendant(s) THIS LAW FIRM IS A DEBT COLLECTOR AND WE ARE ATTEMPTING TO COLLECT A DEBT OWED TO OUR CLIENT. ANY INFORMATION OBTAINED FROM YOU WILL BE USED FOR THE PURPOSE OF COLLECTING THE DEBT. TO: ROBIN L. GILSDORF 9 Briarwood Court Camp Hill, PA 17011 DATE OF THIS NOTICE: December 30, 1999 IMPORTANT NOTICE YOU ARE IN DEFAULT BECAUSE YOU HAVE FAILED TO ENTER A WRITTEN APPEARANCE PERSONALLY OR BY ATTORNEY AND FILE IN WRITING WITH THE COURT YOUR DEFENSES OR OBJECTIONS TO THE CLAIMS SET FORTH AGAINST YOU. UNLESS YOU ACT WITHIN TEN (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 Bar Association 2 Liberty Avenue, Carlisle, PA (800) 990-9108 /s/ J0,4enli -. ( dbech. ifr. GOLDBECK MCCAFFERTY & MCKEEVER BY: Joseph A. Goldbeck, Jr., Esq. Attorney for Plaintiff Suite 500 - The Bourse Bldg. 111 S. Independence Mall East Philadelphia, PA 19106 215-627-1322 TO: HERBERT W. GILSDORF JR. 9 Briarwood Court Camp Hill, PA 17011 COUNTRYWIDE HOME LOANS INC., F/K/A COUNTRYWIDE FUNDING CORP. 6400 Legacy Drive Plano, TX 75024-3632 Plaintiff VS. HERBERT W. GILSDORF JR. AND ROBYN L GILSDORF (Mortgagor(s)) (Record Owner(s)) 9 Briarwood Court Camp Hill, PA 17011 De f endant (a) IN THE COURT OF COMMON PLEAS OF CUMBERLAND COUNTY CIVIL ACTION - LAW ACTION OF MORTGAGE FORECLOSURE Term No. 99-7113-CIVIL THIS LAW FIRM IS A DEBT COLLECTOR AND WE ARE ATTEMPTING TO COLLECT A DEBT OWED TO OUR CLIENT. ANY INFORMATION OBTAINED FROM YOU WILL BE USED FOR THE PURPOSE OF COLLECTING THE DEBT. TO: HERBERT W. GILSDORF JR. 9 Briarwood Court Camp Hill, PA 17011 DATE OF THIS NOTICE: December 30, 1999 IMPORTANT NOTICE YOU ARE IN DEFAULT BECAUSE YOU HAVE FAILED TO ENTER A WRITTEN APPEARANCE PERSONALLY OR BY ATTORNEY AND FILE IN WRITING WITH THE COURT YOUR DEFENSES OR OBJECTIONS TO THE CLAIMS SET FORTH AGAINST YOU. UNLESS YOU ACT WITHIN TEN (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 Bar Association 2 Liberty Avenue, Carlisle, PA (800) 990-9108 /a/ J0.4en4 -'4. CoCdbech. I GOLDBECK McCAFFERTY & MCKEEVER BY: Joseph A. Goldbeck, Jr., Esq. Attorney for Plaintiff Suite 500 - The Bourse Bldg. 111 S. Independence Mall East Philadelphia, PA 19106 215-627-1322 VERIFICATION OF NON-MILITARY SERVICE The undersigned, as the representative for the Plaintiff corporation within named do hereby verify that I am authorized to make this verification on behalf of the Plaintiff corporation and that the facts set forth in the foregoing verification of Non- Military Service are true and correct to the best of my knowledge, information and belief. I understand that false statements therein are made subject to penalties of 9 Pa. C.S. 4904 relating to unsworn falsification to authorities. 1. That the above named Defendant, ROBYN L. GILSDORF, is about unknown years of age, that Defendant's last known residence is 9 Briarwood Court, Camp Hill, PA 17011 and is engaged in the unknown business located at unknown address. 2. That Defendant is 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 Action of Congress of 1940 and its Amendments. Date: dv,,? (,) - A 4442602 - GILSDORF,ROBYN L. x VERIFICATION OF NON-MILITARY SERVICE The undersigned, as the representative for the Plaintiff corporation within named do hereby verify that I am authorized to make this verification on behalf of the Plaintiff corporation and that the facts set forth in the foregoing verification of Non- Military Service are true and correct to the best of my knowledge, information and belief. I understand that false statements therein are made subject to penalties of 18 Pa. C.S. 4904 relating to unsworn falsification to authorities. 1. That the above named Defendant, HERBERT W. GILSDORF JR., is about unknown years of age, that Defendant's last known residence is 9 Briarwood Court, Camp Hill, PA 17011 and is engaged in the unknown business located at unknown address. 2. That Defendant is 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 Action of Congress of 1940 and its Amendments. Date: 4442602 - GILSDORF JR.,HERBERT W. ?!? ?.?,? i:: ?.. ?- J L -'" n J ? ? ?? ? ? ? ? ? ?. ?_? I PRAECIPE FOR WRIT OF EXECUTION - (MORTGAGE FORECLOSURE) P.R.C.P 3180-3183 Joseph A. Goldbeck, Jr. Attorney I.D.#16132 Suite 500 - The Bourse Bldg. 111 S. Independence Mall East Philadelphia, PA 19106 215-627-1322 Attorney for Plaintiff COUNTRYWIDE HOME LOANS INC., F/K/A COUNTRYWIDE FUNDING CORP 6400 Legacy Drive Plano, TX 75024-3632 Plaintiff VS. HERBERT W. GILSDORF JR. AND ROBYN L. GILSDORF (Mortgagor(s) and Record Owner(s)) 9 Briarwood Court Camp Hill, PA 17011 Defendant(s) IN THE COURT OF COMMON PLEAS OF CUMBERLAND COUNTY CIVIL ACTION - LAW :ACTION OF MORTGAGE FORECLOSURE Term No. 99-7113-Civil PRAECIPE FOR WRIT OF EXECUTION TO THE PROTHONOTARY: Issue Writ of Execution in the above matter: Amount Due Interest from 61 1199 to 2/14/00 at 9.250% $ 115.389.28 (Costs to be added) $ Jotop A. G ldb ck, Jr. Atrney for Plaintiff i ' ?.. '" . _. ?': iV ?? L. _) - _ U v \Vl? i ?l b z N H ? ? Fa w 4-4 p U) O a 0 u W O U ?£ fl; i (14 C) w a 0 0 01 1 o OaM rn U a yE? H Wv Aar Nt` HO 0H $4 0 NOfdr E? 14 W '1 Pu £ •ri W U1 0 r6 O? (x W O O .? b ?I N 1 3 H F 0 H U) 9 E U W W b1 ? '?r Er O ? ? ul 41 CD z O 3 U 61% 3 W N O O U) C N U H ?l N rn la •? W O 41 •? W a a 01-NW H }'. O1.1 N .Ci E' H\ W Nw?a v• tj -Wa z ?awor: we '"' OUwU xa- OmU w err ALL THAT CERTAIN tract or parcel of land arid premises, situate, lying and being in the Township of Hlampden in the County of Cumberland and Commonwealth of Pennsylvania, more particularly described as follows: BEGINNING at a point on the easterly line of Briarwood Court, a 50 foot wide right-of-way, which said point is"lodaEed and referenced 340.00 feet in a southerly direction from the intersection of the easterly line of Briarwood Court and the southerly line of Briarwood Lane, also a 50 foot wide right-of-way, and which said point of beginning is also located at the intersection of the easterly line of Briarwood Court and tire dividing line between Lot Nov. 31 and 32 on the Plan of Lots known as Countryside, Section (A); thence, from said point of beginning along the dividing line between Lot Nov. 31 and 32, north 74 degrees 37 minutes east, a distance of 110.0D.-feet to a point on the dividing line between'Lot Nos. 32 and 25; thence, from said.point along the dividing line between Lot Nos. 24, 25 and 32, 9outhgl5 degrees 23 minutes east, a distance of 85.06 feet to a point on the dividing line between Lot Nos. 32 and„33; thence, from said point along the dividing line between Lot Nos. 32 and 33, south 68 degrees 30 minutes went, a distance of 93.82 feet to a point on a cul-de-sac which is located at the southerly end of Briarwood Court; thence, from said point along a curve to the left with a radiuu of 50.00 feet, a distance of 47.02 feet to a point on the easterly line of Briarwood Court; thence, from raid point along the.,eaeCerly line of Briarwood Court, north 15 degrees 23 minutes west, a distance of 57.08 feet to a point, the point arid place of BEGINNING. BEING Lot No. 32 on the Plan of Lots known as Countryside, Section (A), prepared by Charles W. Junkins, Registered Surveyor, dated December 4, 1973 and recorded in the Office of the Recorder of Deeds of Cumberland Courty on April 11, 1974, in Plan Book 25, Page 6. HAVING thereon erected a dwelling (rouse being known and numbered as premises 9 Briarwood Court, Camp Nill, Pennsylvania. C? SUBJECT to covenants recorded on November 30, 1973 iri-.the?_' office of the Recorder of Deeds of Cumberland County in-Miec.cr Book 207, Page 59 and to all other covenants and restrictions'' of record. UNDER AND SUBJECr nevertheless to an easement or right--of-yiay to Pennsylvania Power arid Light Company for the construction ok_ erection of electrical utilities on the aforesaid property„-.either under or above ground. IMPROVEMENTS consist of a residential dwelling. BEING PREMISES: 9 Briarwood Court, Camp Hill, PA 17011 SOLD as the property of HERBERT W. GILSDORF JR. and ROBYN L. GILSDORF TAX PARCEL #10-19-1596-121 GOLDBECK McCAFFERTY & McKEEVER BY: Joseph A. Goldbeck, Jr. Attorney I.D.#16132 Suite 500 - The Bourse Bldg. 111 S. Independence Mall East Philadelphia, PA 19106 215-627-1322 Attorney for Plaintiff COUNTRYWIDE HOME LOANS INC., F/K/A COUNTRYWIDE FUNDING CORP 6400 Legacy Drive Plano, TX 75024-3632 Plaintiff VS. HERBERT W. GILSDORF JR. AND ROBYN L. GILSDORF (Mortgagor(s) and Record Owner(s)) 9 Briarwood Court Camp Hill, PA 17011 IN THE COURT OF COMMON PLEAS OF CUMBERLAND COUNTY CIVIL ACTION - LAW :ACTION OF MORTGAGE FORECLOSURE Term No. 99-7113-Civil Defendant(s) AFFIDAVIT PURSUANT TO RULE 3129 COUNTRYWIDE HOME LOANS INC., f/k/a Countrywide Funding Corp., Plaintiff in the above action, by its attorney, Joseph A. Goldbeck, Jr., 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: 9 Briarwood Court, Camp Hill, PA 17011 1. Name and address of Owner(s) or Reputed Owner(s) : HERBERT W. GILSDORF JR. 9 Briarwood Court Camp Hill, PA 17011 ROBYN L. GILSDORF 9 Briarwood Court Camp Hill, PA 17011 2. Name and address of Defendant(s) in the judgment: HERBERT W. GILSDORF JR. . 9 Briarwood Court Camp Hill, PA 17011 ROBYN L. GILSDORF 9 Briarwood Court Camp Hill, PA 17011 3. Name and last known address of every judgment creditor whose # ° judgment is a record lien on the property to be sold: BUREAU OF COMPLIANCE i' Dept. 280946 Harrisburg, PA 17128 COMMONWEALTH OF PENNSYLVANIA DEPT. OF LABOR AND I' INDUSTRY TO THE USE OF THE UNEMPLOYMENT COMP. FUND 16th Floor L&I Bldg. Harrisburg, PA 17121 BEARD BRADLEE C 301 Nort 32nd Street Harrisburg, PA 17109 4. Name and address of the last recorded holder of every mortgage of record: 5. Name and address of every other person who has any record interest in or record lien on the property and whose interest may be affected by the sale: 6. Name and address of every other person of whom the plaintiff has knowledge who has any record interest in the property which may be affected by the sale. 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. (attach separate sheet if more space is needed) I verify that the statements made in this affidavit are true and correct to the best of my personal knowledge or information and belief. I understand that false statements herein are made subject to the penalties of 18 Pa. C.S. Section 4904 relating to unsworn falsification to authorities DATED: February 11, 2000 GqiJb CK McCA ERTY & McKEEV BY: J ep A. Goldbeck, Jr., Esq Attorney for Plaintiff . ? _: ; : , , i ,_ ,_ : : .... ,=_? - ; ;. , , ,_ .: :, ._ GOLDBECK McCAFFERTY & McKEEVER BY: Joseph A. Goldbeck, Jr. Attorney I.D.#16132 Suite 500 - The Bourse Bldg. 113- S. Independence Mall East Philadelphia, PA 19106 215 - 627-1322 Attorney for Plaintiff COUNTRYWIDE HOME LOANS INC., F/K/A COUNTRYWIDE FUNDING CORP. 6400 Legacy Drive Plano, TX 75024-3632 Plaintiff VS. HERBERT W. GILSDORF JR. AND ROBYN L. GILSDORF (Mortgagor(s) and Record Owner(s)) 9 Briarwood Court Camp Hill, PA 17011 Defendant(s) TO : IN THE COURT OF COMMON PLEAS OF CUMBERLAND COUNTY CIVIL ACTION - LAW :ACTION OF MORTGAGE FORECLOSURE Term No. 99-7113-Civil THIS LAW FIRM IS A DEBT COLLECTOR AND WE ARE ATTEMPTING TO COLLECT A DEBT. THIS NOTICE IS SENT TO YOU IN AN ATTEMPT TO COLLECT A DEBT. ANY INFORMATION OBTAINED FROM YOU WILL BE USED FOR THAT PURPOSE. NOTICE OF SHERIFF'S SALE OF REAL PROPERTY HERBERT W. GILSDORF JR. 9 Briarwood Court Camp Hill, PA 17011 Your house at 9 Briarwood Court, Camp Hill, PA 17011 is scheduled to be sold at Sheriff's Sale on June 7, 2000, at 10:00 a. m ., in Cumberland County, Commissioners Hearing Room, 2nd Floor, Courthouse, Carlisle, PA 17013 to enforce the court judgment of $115,389.28 obtained by COUNTRYWIDE HOME LOANS INC., f/3--/ a Countrywide Funding Corp. against you. NOTICE OF OWNER'S RIGHTS YOU MAY BE ABLE TO PREVENT THIS SHERIFF'S SALE To prevent this Sheriff's Sale you must take immediate act ion: 1. The sale will be cancelled if you pay to COUNTRYWIDE HOME LOANS INC., f/k/a Countrywide Funding Corp., the back payments, late charges, costs and reasonable attorney's fees due. To find out how much you must pay call: 215-627-1322 2. You may be able to stop the sale by filing a petition asking the Court to strike or open judgment, if the judgment was improperly entered. You may also ask the Court to postpone the sale for good cause. 3. You may also be able to stop the sale through other legal proceedings. You may need an attorney to assert your rights. The sooner you contact one, the more chance you will have of stopping the sale. (See notice below on how to obtain an attorney). 1. If the Sheriff Is Sale is not stopped, your property will be sold to the highest bidder. You may find out the price bid price by calling the Sheriff of Cumberland County at (717) 240-6390. 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 the Sheriff of Cumberland County at (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 a right to remain in the property until the full amount due is paid to the Sheriff and the Sheriff gives a deed to the buyer. At that time, the buyer may bring legal proceedings to evict you. 6. You may be entitled to a share of the money which was paid for your house. A schedule of distribution of the money bid for your house will be filed by the Sheriff thirty (30) days from the date of the Sheriff Is 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 schedule of distribution is filed. 7. You may also have other rights and defenses, or ways of getting your house back, if you act immediately after the sale. YOU SHOULD TAKE THIS PAPER TO YOUR LAWYER AT ONCE. IF YOU DO NOT HAVE A LAWYER OR CANNOT AFFORD ONE, GO TO OR TELEPHONE THE OFFICE LISTED BELOW TO FIND OUT WHERE YOU CAN GET LEGAL HELP. Cumberland County Bar Association 2 Liberty Avenue, Carlisle, PA (800) 990-9108 Legal Services Inc. 8 Irvine ROV, Carlisle, PA 17013 (717) 293-9400 GOLDBECK McCAFFERTY & McKEEVER BY: Joseph A. Goldbeck, Jr. Attorney I.D.#16132 Suite 500 - The Bourse Bldg. 111 S. Independence Mall East Philadelphia, PA 19106 215-627-1322 Attorney for Plaintiff COUNTRYWIDE HOME LOANS INC., F/K/A COUNTRYWIDE FUNDING CORP. 6400 Legacy Drive Plano, TX 75024-3632 Plaintiff IN THE COURT OF COMMON PLEAS OF CUMBERLAND COUNTY CIVIL ACTION - LAW VS. :ACTION OF MORTGAGE FORECLOSURE HERBERT W. GILSDORF JR. AND ROBYN L. GILSDORF (Mortgagor(s) Term : No. 99-Term Civil and Record Owner(s)) 9 Briarwood Court Camp Hill, PA 17011 THIS LAW FIRM IS A DEBT COLLECTOR AND WE ARE ATTEMPTING TO COLLECT A DEBT. THIS NOTICE IS SENT TO YOU IN AN ATTEMPT TO COLLECT A DEBT. ANY INFORMATION OBTAINED FROM YOU WILL BE USED FOR THAT PURPOSE. NOTICE OF SHERIFF'S SALE OF REAL PROPERTY TO: ROBYN L. GILSDORF 9 Briarwood Court Camp Hill, PA 17011 Your house at 9 Briarwood Court, Camp Hill, PA 17011 is scheduled to be sold at Sheriff's Sale on June 7, 2000, at 10:00 a.m., in Cumberland County, Commissioners Hearing Room, 2nd Floor, Courthouse, Carlisle, PA 17013 to enforce the court judgment of $115,389.28 obtained by COUNTRYWIDE HOME LOANS INC., f/k/a Countrywide Funding Corp. against you. To prevent this Sheriff's Sale you must take immediate action: 1. The sale will be cancelled if you pay to COUNTRYWIDE HOME LOANS INC., f/k/a Countrywide Funding Corp., the back payments, late charges, costs and reasonable attorney's fees due. To find out how much you must pay call: 215-627-1322 2. You may be able to stop the sale by filing a petition asking the Court to strike or open judgment, if the judgment was improperly entered. You may also ask the Court to postpone the sale for good cause. 3. You may also be able to stop the sale through other legal proceedings. You may need an attorney to assert your rights. The sooner you contact one, the more chance you will have of stopping the sale. (See notice below 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 NOT TARE 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 price by calling the Sheriff of Cumberland County at (717) 240-6390. 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 the Sheriff of Cumberland County at (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 a right to remain in the property until the full amount due is paid to the Sheriff and the Sheriff gives a deed to the buyer. At that time, the buyer may bring legal proceedings to evict you. 6. You may be entitled to a share of the money which was paid for your house. A schedule of distribution of the money bid for your house will be filed by the Sheriff thirty (30) days from the date of the Sheriff's 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 schedule of distribution is filed. 7. You may also have other rights and defenses, or ways of getting your house back, if you act immediately after the sale. YOU SHOULD TAKE THIS PAPER TO YOUR LAWYER AT ONCE. IF YOU DO NOT HAVE A LAWYER OR CANNOT AFFORD ONE, GO TO OR TELEPHONE THE OFFICE LISTED BELOW TO FIND OUT WHERE YOU CAN GET LEGAL HELP. Cumberland County Bar Association 2 Liberty Avenue, Carlisle, PA (800) 990-9108 3- -?. A. Legal Services Inc. 8 Irvine Rov, Carlisle, PA 11013 (717) 243 -9J 00 ,. _ _ _ _. ? ? ?:= ;__ ?; _ - - _. -, , ': ? L L 1 1 ) L. `-) . L? &eY . iu - GOLDBECK McCAFFERTY & McKEEVER Joseph A. Goldbeck, Jr. Attorney I.D.#16132 Suite 500 - The Bourse Bldg. 111 S. Independence Mall East Philadelphia, PA 19106 215-627-1322 Attorney for Plaintiff COUNTRYWIDE HOME LOANS INC., F/K/A COUNTRYWIDE FUNDING CORP 6400 Legacy Drive Plano, TX 75024-3632 IN THE COURT OF COMMON PLEAS OF CUMBERLAND COUNTY CIVIL ACTION - LAW Plaintiff VS. HERBERT W. GILSDORF JR. AND ROBYN L. GILSDORF (Mortgagor(s) and Record Owner(s)) 9 Briarwood Court Camp Hill, PA 17011 Defendant(s) :ACTION OF MORTGAGE FORECLOSURE Term No. 99-7113-Civil CERTIFICATION AS TO THE SALE OF REAL PROPERTY I, Joseph A. Goldbeck, Jr., Esquire hereby certify that I am the attorney of record for the Plaintiff in this action, and I further certify that this property is not subject to Act 91 of 1983 insofar as it is an FHA insured loan. a ?A tom' dhml? 04, Jo pl A. Gold eck, Jr. At rney for aintiff 4. <.v` t .?.. .lti 7 _ I"^ l .. '?? Lt_ ?7 .) ALL TBAT CERTAIN tract or parcel of land and premises, situate, lying and being in the Township of llampden in the County of Cumberland and Commonwealth of Pennsylvania, more particularly described as follows: BEGI14NING at a point on the easterly line of Briarwood Court, a 50 foot wide right-of-way, which said point is-locaE6d and referenced 340.00 feet in a southerly direction from the intersection of the easterly line of Briarwood Court and the southerly line of Briarwood Lane, also a 50 foot wide right-of-way, and which said point of beginning is also located at the intersection of the easterly line of Briarwood Court and the dividing line between Lot Nos. 31 and 32 on the Plan of Lots known as Countryside, Section (A); thence, from said point of beginning along the dividing line between Lot Nos. 31 and 32, north 74 degrees 37 minutes east, a distance of 118.00-feet to a point on the dividing line between'Lot Nos. 32 and 25; thence, from said point along the dividing line between Lot Nos. 24, 25 and 32, soutW5 degrees 23 minutes east, a distance of 85.06 feet to a point on the dividing line between Lot Nos. 32 and„33; thence, from said point along the dividing line between Lot Nos. 32 and 33, south 68 degrees 30 minutes west, a distance of 93.82 feet to a point on a cul-de-sac which is located at the southerly end of Briarwood Court; thence, from said point along a curve to the left with a radius of 50.00 feet, a distance of 47.02 feet to a point on the easterly line of Briarwood Court; thence, from said point along the,*p,=erly line of Briarwood Court, north 15 degrees 23 minutes west, a distance of 57.00 feet to a point, the point and place of BEGINNING. BEING Lot No. 32 on the Plan of Lots known as Countryside, Section (A), prepared by Charles W. Junkins, Registered Surveyor, dated December 4, 1973 and recorded in the Office of the Recorder of Deeds of Cumberland Courty on April 11, 1974, in Plan Book 25, Page 6. HAVING thereon erected a dwelling house being known and numbered as premises 9 Briarwood Court, Camp hill, Pennsylvania. «, SUBJECT to covenants recorded on November 30, 1973 in the Office of the Recorder of Deeds of Cumberland County in Misc. Book 207, Page 59 and to all other covenants and restrictions of record. UNDER AND SUBJECT nevertheless to an easement or right-of-way to Pennsylvania Power and Light Company for the construction or erection of electrical utilities on the aforesaid property, either under or above ground. - t - _ _ _::-:' ,._ ; _ - -- - C ' a U -it_ :? =i c, !? GOLDBECK MaCAFFERTY & MCKEEVER BY: Joseph A. Goldbeck, Jr. Attorney I.6.#16132 Suite 500 - The Bourse Bldg. 111 S. Independence Mall East Philadelphia, PA 19106 215-627-1322 Attorney for Plaintiff COUNTRYWIDE HOME LOANS INC., F K A COUNTRYWIDE FUNDING CORP. 6400 Legacy Drive Plano, TX 75024-3632 Plaintiff VS. HERBERT W. GILSDORF JR. AND ROBYN L GILSDORF (Mortgagor(s) and Record Owner(s)) (Record Owner(s)) IN THE COURT OF COMMON PLEAS • OF CUMBERLAND COUNTY CIVIL ACTION - LAW ACTION OF MORTGAGE FORECLOSURE Term 9 Briarwood Court No. 99-7113-Civil Camp Hill, PA 17011 Defendant(s) CERTIFICATE OF SERVICE PURSUANT TO Pa.R C P 3129.2 (c) (2) Joseph A. Goldbeck, Jr., Esquire, Attorney for Plaintiff, hereby certifies that service on the Defendants of the Notice of Sheriff Sale was made by: (/ `) Personal Service by the Sheriff's Office/eff*9 return attached) . HE98Af C,ISOGRF 2121) 00 EP_ P` `- (copy of ( ) Certified mail by Joseph A. Goldbeck, Jr. (ori9 green gree oster return receipt attached). n P Postal ( x) Certified mail by Sheriff's Office.kosrN L-C-1CdD01LF.51+10O. ( ) Ordinary mail by Joseph A. Goldbeck, Jr., Esquire to Attorney for Defendant(s) of record (proof of mailing attached). ( ) Acknowledgment of Sheriff's Sale by Attorney for Defendant(s) (proof of acknowledgment attached). ( ) Ordinary mail by Sheriff's Office to Attorney for Defendant(s) of record. IF SERVICE WAS ACCOMPLISHED BY COURT ORDER. ( ) Premises was posted by Sheriff's Office/competent adult (copy of return attached). ( ) Certified Mail & ordinary mail by Sheriff's Office (copy of return attached). ( ) Certified Mail & ordinary mail by Joseph A. Goldbeck, Jr. (original receipt(s) for Certified Mail attached). Pursuant to the Affidavit under Rule 3129 (copy attached), service on all lienholders (if any) has been made by ordinary mail by Joseph A. Goldbeck, Jr., Esquire (copies of proofs of mailing attached). The undersigned understands that the statements herein are subject to the penalties provided by 18 P.S. Section 4904. Re p ct 1 su i GO K McCAF TY & MCKEE E BY' - eph A. Goldbeck, Jr. At orney for Plaintiff For Accountable Mail fA 4 ..:vw=-.w:rrL- ? N A W N _ O tp W V 1 a n" OI CA W N S ,q c Y1 g 3 .. A vm ?~ m tt-. > ?... r.. µ ?? Do r im W V! m b -. . . n mT " ` d ? F+ H p Y ® e3 n.•ap n nZ x?..S ?aO rP°'? r t c'? • ? ?? [ N' n s s a.m e ?? a CA co m ¢ O H M - ? .. • x m H '1 m HID m J r-I m r7 ? a m Do N T m o gg n N A _ _ __ ^ y 5 n n C m n o - . ' o m rt 6 •? m a o n' m 03 m3Ba- o _ y m _ - - ° °m "mCa m an?3oo? o r0 i= ' _? gq m og ?2fo: nS ?9 f) .. p lid sa 56 m? S Sb S ^ Bin^? s mc s q O ?0 •.? Ram cC ( O 'J °?m?oo= p. j N 4 e W C• pwm ? S 0? 4, CD a c .?. .. .. ?v z3 w6? _?pgmn _ _ t l p o q .. - " m?1 J { f oa . y Y 0 D o ` p • e? a_ ° o ; ' a t1 3 -O _ ? . .?v?yo ,__? m •t N , _?. ? 04, MHz ? . ~I 0 0 -+ 'ik• 01 O W c af = _ ? =o : ? nd N ?? ? pg °m0 $ 1 3 3 '?N ? 2 m 1 1 I I 1 oSs?:s m t S • P 970 938 239 TO: ROBYN L. GILSDORF 9 Briarwood Court Camp Hill, PA 17011 GOLDBECK MCCAFFERTY 6 MCKEEVER -Fen ruary 11.2000 SENDER: REFERENCE: GILSD0RFJR.,HER8ERTW./CWD-0522 6/ 7/00 - CUMBERLAND i PS FORM 3800 SEPTEMBER 1995 Fa.upF G,IiFE Fw RETURN n n ,Fw RECEIPT SERVICE RwvNwDwMY _ Ta PoWW WFwF '? US Postal Service POSTMARK R QAT Receipt for MNR K Certified Mail No Insurance Coverage Provktad Do not use for Intemallonal Mail p 97 0. 937 398 TO: HERBERT W. GILSDORF JR. i 9 BriarW00d Court i Camp Hill, PA 17011 f i DOLOBECK MCfAFFERTY6MCKEEVER.February tl, 2001 SENDER: REFERENCE: GILSDORF JR.,HERBERTW./CWp.p522 G/ 7/00 - CUMBERLAND , ee ?AM. SEPTEMBER 1995 D?,uM Fw RETURN F. n. ; Fw RECEIPT T" P~ FF US Postal Service POSrrAAORO Receipt for ( Certified Mail 7•: ? 2sii9 No insurance Coverage Provided Do not use for intemalionBl Mall I o` E I I I 4ya`E^S _ rm mN ¢ fi • F r.HoE S ? :: EE I a v m viLL • •• M O b • F . ' • O 4 voo o uiLL •??• F M O• ... V . .o -fj X ? ? r F F •• :a.? t s ` _rm. $ Loy W _ a ° ` `? 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Smith, Deputy Sheirff, who being duly sworn according to law, says on February 29, 2000, at 4:37 o'clock P.M. he served a true copy of real Estate Writ Notice Poster and Description in the above entitled action upon one of tlue within named defendants to wit: Herbert W. Gilsdorf, Jr. by making known unto Ilerbert W. Gilsdorf, Jr, at Cumberland County Prison 1101 Claremont Road, Carlisle, Cumberland County, Pennsylvania, its contents and at the same time handing to him personally the said true and attested copies of the same. 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 copy of the pendency of the action to one of the within named defendants to wit: Herbert W. Gilsdorf, Jr by first class mail to Cumberland County Prison 1101 Claremont Road, Carlisle, Pennsylvania. This letter was mailed under the date of April 20, 2000 and never returned to the Sheriffs Office. R. Thomas Kline, Sheriff who being duly sworn according to law, says he made diligent search and inquiry for one of the wihtin named defendants to wit: Robyn L. Gilsdorf but was unable to locate her in his bailiwick after fifteen attempts. He therefore returns same not found as to Robyn Gilsdorf R. Thomas Kline, Sheirff, 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 tendency of the action to one of the within named defendants to wit: Robyn L. Gilsdorf by Certified Mail Return Receipt Requested, Restricted Delivery, Deliver To Addressee Only to 9 Briarwood Court, Camp Hill, Pennsylvania. This letter was mailed under the date of May 4,2000 and received by Robyn Gilsdorf on May G, 2000 the return receipt card signed by Robyn Gilsdorf. Harold J. Weary Deputy Sheriff, who being duly sworn according to law, says on March 30, 2000 at 4:58 o'clock P.M. EST, he posted a copy of Real estate Writ Notice Poster and Description on the property of Herbert W. Gilsdorf, Jr. and Robyn L. Gilsdorf located at 9 Briarwood Court, Camp Hill, 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: Robyn L. Gilsdorf by first class mail to 9 Briarwood Court, Camp Hill, Pennsylvania. This letter was mailed under the date of May 8, 2000 and never returned to the Sheriffs Office. So answers-r.41 % R. Thomas Kline, Sheriff By Real L;tate Deputy GOLDBECK McCAFFERTY & McKEEVER BY: Joseph A. Goldbeck, Jr. Attorney I.D.#16132 Suite 500 - The Bourse Bldg. 111 S. Independence Mall East Philadelphia, PA 19106 215-627-1322 Attorney for Plaintiff COUNTRYWIDE HOME LOANS INC., F/K/A COUNTRYWIDE FUNDING CORP 6400 Legacy Drive Plano, TX 75024-3632 Plaintiff IN THE COURT OF COMMON PLEAS OF CUMBERLAND COUNTY CIVIL ACTION - LAW :ACTION OF MORTGAGE FORECLOSURE VS. HERBERT W. GILSDORF JR. AND ROBYN L. GILSDORF (Mortgagor(s) and Record Owner(s)) 9 Briarwood Court Camp Hill, PA 17011 Defendant(s) Term No. 99-7113-Civil SUPPLEMENTAL AFFIDAVIT PURSUANT TO RULE 3129 COUNTRYWIDE HOME LOANS INC., f/k/a Countrywide Funding Corp., Plaintiff in the above action, by its attorney, Joseph A. Goldbeck, Jr., 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: 9 Briarwood Court, Camp Hill, PA 17011 1. Name and address of owner (s) or Reputed Owner(s): HERBERT W. GILSDORF JR. 9 Briarwood Court Camp Hill, PA 17011 ROBYN L. GILSDORF 9 Briarwood Court Camp Hill, PA 17011 2. Name and address of Defendant(s) in the judgment: HERBERT W. GILSDORF JR. 9 Briarwood Court Camp Hill, PA 17011 ROBYN L. GILSDORF 9 Briarwood Court Camp Hill, PA 17011 3. Name and last known address of every judgment creditor whose judgment is a record lien on the property to be sold: BUREAU OF COMPLIANCE Dept. 280946 Harrisburg, PA 17128 COMMONWEALTH OF PENNSYLVANIA DEPT. OF LABOR AND INDUSTRY TO THE USE OF THE UNEMPLOYMENT COMP. FUND 16th Floor L&I Bldg. Harrisburg, PA 17121 BEARD BRADLEE C 301 Nort 32nd Street Harrisburg, PA 17109 UNEMPLOYMENT COMPENSATION FUND 16th Floor L & I Building Harrisburg, PA 17121 CUMBERLAND COUNTY ADULT PROBATION 1 Courthouse Square Carlisle, PA 17013-3387 4. Name and address of the last recorded holder of every mortgage of record: 5. Name and address of every other person who has any record interest in or record lien on the property and whose interest may be affected by the sale: 6. Name and address of every other person of whom the plaintiff has knowledge who has any record interest in the property which may be affected by the sale. 7. Name and address of every other person of whom the plaintiff est in the property which may be has knowledge who has any inter affected by the sale. (attach separate sheet if more space is needed) I verify that the statements made in nothis affidavit are true and correct to the best of my personal that false statements herein are made and belief. I understand subject to the penalties of 18 Pa. C.S. ?104 relating to unsworn falsification to authorities.( /i DATED: May 5, 2000 GOLDBECK McCAF ERTY & McKEEVh BY: Joseph A. Gold ck, Jr., EgQ• Attorney for plaintiff Cam` .. - n.!ij0 ,r r • r Lli_ S O O U 0 GOLDBECK McCAFFERTY & McKEEVER BY: Joseph A. Goldbeck, Jr. Attorney I.D.#16132 Suite 500 - The Bourse Bldg. 111 S. Independence Mall East Philadelphia, PA 19106 215-627-1322 Attorney for Plaintiff COUNTRYWIDE HOME LOANS INC., F/K/A COUNTRYWIDE FUNDING CORP 6400 Legacy Drive Plano, TX 75024-3632 Plaintiff VS. IN THE COURT OF COMMON PLEAS OF CUMBERLAND COUNTY CIVIL ACTION - LAW :ACTION OF MORTGAGE FORECLOSURE HERBERT W. GILSDORF JR. AND vl 711.3 ROBYN L. GILSDORF (Mortgagor (s) and Real owner(s)) :CIVIL ACTION: MORTGAGE 9 Briarwood Court 'FORECLOSURE Camp Hill, PA 17011 Defendant(s) THIS LAW FIRM IS A DEBT COLLECTOR AND WE ARE ATTEMPTING TO COLLECT A DEBT OWED TO OUR CLIENT. ANY INFORMATION OBTAINED FROM YOU WILL BE USED FOR THE PURPOSE OF COLLECTING THE DEBT. N O T I C E You have been sued in court. If you wish to tlefend against the claims set forth i tnteringwia9written you moat take action within twenty (20) days after the complaint and notice are served, by appearance personally or by attorney and filing in writing with the court your defenses or objections to the nst. that rned are You ou fail judgmentemay behentered against you by the court without further oti a fthe case or any money claimed inhthe complaint claims or for any other claim or relief requested by the Plaintiff. You may lose money or property or other rights important to you. NOT GO TO OR YOU SHOULD TAKE IS PER O YOUR NE THE OFFICE SET FOR N BELOW YE FIND OUT WHERE IF YOYO CAN GET VLEGAL?RELP. OR CANNOT AFFORD 0 Cumberland County CBar arlisle,PA 2 Liberty Avenue, (600) 990-9108 Legal Services Inc. e Irvine Row, Carlisle, PA 11013 (717) 243-9400 A V I S O LE HAN DEMMR)ADO A LISTED EN LA CORTE. 51 DESEA DEFENDERSE CONTRA LAS QUEJAS PERESENTADAS, ES ABSOLUTAMENTE NECESSARIO QUE USTED RESPONDA DENTRO BE 20 DIAS DESPUES DE SER SERVIDO CON ESTA DEMANDA Y AVISO. PARA DEFENDERSE ES NECESSARIO QUE LISTED, O SU ABOGADO, REGISTRE CON LA CORTE EN FORMA ESCRITA, EL PUNTO BE VISTA DE USTED Y CUALOUIER OBJECCION CONTRA LAS OUEJAS EN ESTA DEMANDA. RECUERDE: SI USTED NO REPONDE A ESTA OENANDA. SE PUEDE PROSECUIR CON EL PROCESO SIN SU PARTICIPACION. REOUER ENTONCES LA COME PUEDE, SIN NOTIFICARIO, DECIDIR A FAVOR DEL DEMANDANTE Y IRA QUE LISTED CUMPLA CON DAS STED PUEDA PERDE0. DIIlERO, PROPIEDAD V,DERECHOS IISTA DNTMEANDA POR RAZON DE ESA DECISION. ES POSSIBLE Q U OTROS US LISTED LLEV-c ESTA DEMANDA A UN ABOGADO IMMEDIATAMEYIE. SI NO CONOCE A UN ABOCADO, LLA.NE AL "LARYER REFEI 215-238-6300. Cumberland County Bar Association 2 Liberty Avenue. Carlisle, PA (S 00) 990-9108 Legal Services Inc a Irvine Row, isle, PA 170:3 (717) 243.9400 1 COMPLAINT IN MORTGAGE FORECLOSURE 1. Plaintiff is COUNTRYWIDE HOME LOANS INC., F/K/A COUNTRYWIDE FUNDING CORP., 6400 Legacy Drive, Plano, TX 75024-3632. 2. The name (s) and address (es) of the Defendant (s) is/are HERBERT W. GILSDORF JR., 9 Briarwood Court, Camp Hill, PA 17011 and ROBYN L. GILSDORF, 9 Briarwood Court, Camp Hill, PA 17011, who is/are the mortgagor (s) and real owner (s) of the mortgaged property hereinafter described. 3. On June 23, 1995, mortgagor(s) made, executed and delivered a mortgage upon the premises hereinafter described to PROVIDENT MORTGAGE CORP., T/A CONSOLIDATED MORTGAGE CORP., which mortgage is recorded in the office of the Recorder of Deeds of Cumberland County in Mortgage Book 1268, Page 1123. By Assignment of Mortgage dated June 23, 1995, the mortgage was assigned to Plaintiff, which Assignment is recorded in Assignment of Mortgage Book No. 498, Page 907. These documents are matters of public record and are incorporated herein by reference in accordance with Pennsylvania Rule of Civil Procedure 1019(g). 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 July 1, 1999, and each month thereafter are due and unpaid, and by the terms of said mortgage, upon default in such payments for a period of one month, the entire principal balance and all interest due thereon are collectible forthwith. 6. The following amounts are due on the mortgage: Principal Balance Interest from 61 1/99 through 11/30/99 at 9.250% Per diem interest rate at $25 Attorney's Fee at 5% of Principal Balance Late Charges 7/ 1/99-11/30/99 Monthly late charge amount at Costs of suit and Title Search Escrow Balance Deficit Monthly Escrow amount $208.36 84 $42.92 $ 101,978.12 4,702.88 5,098.91 214.60 560.00 $ 112,554.51 116.65 $ 112,671.16 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 based on work actually performed. 8. The within mortgage is insured by the Federal Housing Administration under Title II of the National Housing Act and, as such, is not subject to the provisions of Pennsylvania Act No. 91 of 1983. WHEREFORE, Plaintiff demands judgment in mortgage foreclosure the sum of $112,671.16, together with interest at the rate of $25.84, per day and other expenses incurred by the Plaintiff which are properly chargeable in accordance with the terms of the mortgage, and for the foreclosure and sale of the mortgaged premises. By: GOLDBECK M C 1cKEEVER BY: Joseph of b c, Jr., Esq. Attorney for Plaintif APR 07 !99 11:16AM GOLDBECK MCCAFFERTY (215)6277734 P.22 VERIFICATION I, , as the representative of the Plaintiff corporation within named do hereby verify that I am authorized to and do make this verification on behalf of the Plaintiff, corporation and the facts set forth in the foregoing Complaint are true and correct to the best of my knowledge, information and belief. I understand that false statements therein are made subject to the penalties of 18 Pa. C.S unsworn falsification to authorities. Date: / 7 4904 relating to d u LEGAL DESCR=PTION ALL ?BAT CER?AIii tractor parcel of land and premises, nituate, lying and being in the Township of Hampden in the Carciculf Cumberland and Commonwealth or Pennsylvania, more p - described an follows: Court, BEGINNING at a point on the easterly line ot_Briarwood a 50 Coot wide right-of-way, which said point is located and rly referenced 340.00 feet in a sl i r-heof BdirectionCfrom and the intersection of the easterly southerly lisle of Briarwood Lane, also a 50 foot wide right-of-way, and which said point of beginning is also located at the intersection of the easterly line of Briarwood Court and klnowniasdCountryside, Sect on %A); tl nce,3from said ppoint foteots beginning along the dividing 1 1 ne between Lot Nos. 31 and 32, .north 74 degrees 37 minutes east, a distance of 118.OD.,feenceo a point on the dividing theediberween't viding Nbetweos. 24, 25 from , ecuoint along and 322; oupJW5 :degrees 21 minutes east, a distance of 85.0 feet a point on intdividing theline dividingelinetbetween2LotdNOS. thence, , from said po 32 and 33, south 68 degrees 30 minutes west, a distance of 93.82 south feet to a point on a t, thencec fwhi in rom saidlpointdalongha curveetoy end of Briarwood Coul distance of 47.02 feet s to the left with a radius of 50. 06 feet, a point on the easterly line 1 ineiOfwBrdiarCourt; wood Court north 15 said point along s we terlc> 0f Y degrees 23 minutes west, a di s t ante of 57.08 feet to a point, the point and place of BEGINIING. BEING Lot No. 32 on the Plan of Lots known as Registered Surveyor, , Section (A), prepared by Char l e s W. Junkins Regi dated December 4, 1973 and recorded in the OfficeiofP he RReco ecorder of Deeds of Cumberland Courty on %pril 11, 1974, 25,. Page 6. mviw thereon erected a dwellingusPennsylvanian and numbered as premises 9 Briarwood Court , Camp Hill, SUBJ ,,CT to covenants recorded on November office of the Recorder of Deeds of Cumberland Rook 207, Page 59 and to all other covenants of record. UNDER AND SUBJECT nevertheless to an for the construction or to Pennsylvania Power and Light Company erection of electrical utilities on the under or above ground. BEING the same premises c+tsich Harry E. Whipkey, single man, by his deed to be recorded simultaneously herewith, in the Office of the Recorder of Deeds of Cumberland County, granted and conveyed unto Herbert W. Gilsdorf, J r _ and Robyn L. Gilsdorf. 1 1 +' v 30, 1973 in the county in Misc. and restrictions easement or right-of-way aforesaid property, either , sJ i ,. a 'f 1 ? UC wL; - S O U N .17 ,n2 C43 %. 4?-) cY. rq \ ? ? W SHERIFF'S RETURN - REGULAR % CASE NO: 1999-07113 P COMMONWEALTH OF PENNSYLVANIA: COUNTY OF CUMBERLAND COUNTRWIDE HOME LOAS INC VS. GILSDORF HERBERT W JR ET AL HAROLD WEARY , Sheriff or Deputy Sheriff of CUMBERLAND County, Pennsylvania, who being duly sworn according to law, says, the within COMPLAINT - MORT FORE was served upon GILSDORF HERBERT W JR the defendant, at 18:42 HOURS, on the 2nd day of December 1999 at 9 BRIARWOOD COURT CAMP HILL, PA 17011 CUMBERLAND County, Pennsylvania, by handing to HERBERT GILSDORF, JR a true and attested copy of the COMPLAINT - MORT FORE together with NOTICE and at the same time directing His attention to the contents thereof. Sheriff's Costs: So an Docketing 18.00 Service 9.30 Affidavit .00 / Surcharge 8.00 omas ine, eri $35 0-1OLDB CK, MCCAFFERTY, MCKEEVER 06/1999 by epu " S er?LL - Sworn and subscribe to before me this /c/ tr_ day of A. D. ro ono ary ' CASE NO: 1999-07113 P SHERIFF'S RETURN - REGULAR COMMONWEALTH OF PENNSYLVANIA: COUNTY OF CUMBERLAND COUNTRWIDE HOME LOAS INC VS. GILSDORF HERBERT W JR ET AL HAROLD WEARY , Sheriff or Deputy Sheriff of CUMBERLAND County, Pennsylvania, who being duly sworn according to law, says, the within COMPLAINT - MORT FORE was served upon GILSDORF the defendant, at 18:42 HOURS, on the 2nd day of December 1999 at 9 BRIARWOOD COURT CAMP HILL, PA 17011 CUMBERLAND County, Pennsylvania, by handing to HERBERT GILSDORF, JR. a true and attested copy of the COMPLAINT - MORT FORE together with NOTICE and at the same time directing His attention to the contents thereof. Sheriff's Costs: So answers: Docketing 6.00 /® Service .00 Affidavit .00 Surcharge 8.00 omas ine, eri $r4.0012OLDBEC , MC-C-A7F/FERTY, MCKEEVER by lc? Lp?PUL.y J? 5 err- Sworn and subscribed to before me this /Ytt? day o L 1,9 &1 rd A.D. aft ( l ?L? . cFi tQ oGi "W ocnonocar