HomeMy WebLinkAbout99-07211
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GOLDBECK MCCAFFERT '?=f & MCKEEVEIZ
BY: Joseph A. Goldbeck, Jr.
Attorney I.D.it16132
Suite 500 - The Bourse Bldg.
111 S. Independence Mall East
Philadelphia, PA 1 SD 106
215-62 7-1322
Attorney for Plaint=iff
GE CAPITAL MORTGAGI? SERVS. INC. IN THE COURT OF COMMON PLEAS
4680 Hallmark Parkway
San Bernardino, CA 92407 OF CUMBERLAND COUNTY
Pla - ntiff
CIVIL ACTION - LAW
Vs.
:ACTION OF MORTGAGE FORECLOSURE
TERRY L. VOLOVSKI 7=5-ND KATHRYN N.
VOLOVSKI (Mortgagor(s) and Term
Record Owner(s)) No. 99-7211 CIVIL
334 Lowther Street
Lemoyne, PA 17043
DefE?ndant (s)
PF;-:>AECIPE TO REINSTATE COMPLAINT
Kindly reinstate the Complaint in the above captioned
matter.
GOLDBECK MCCAFFERTY & MCKEEVER
BY:
Jose Gol e k, Jr.
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SHERIFF'S RETURN - NOT FOUND
CASE NO: 1999-07211 P
COMMONTWEALTH OF PENNSYLVANIA
COUNTY OF CUMBERLAND
GE CAPITAL MORTGAGE SERVS INC
VS
VOLOVSKI TERRY L ET AL
R. Thomas Kline ,Sheriff or Deputy Sheriff, who being
duly sworn according to law, says, that he made a diligent search and
inquiry for the within named defendant, DEFENDANT
VOLOVSKI TERRY L but was
unable to locate Him in his bailiwick. He therefore returns the
COMPLAINT - MORT FORE ,
NOTICE
, NOT FOUND , as to
the within named DEFENDANT , VOLOVSKI TERRY L
ADDRESS STATED IS NOT VALID, ALTERNATE ADDRESS
NOT PROVIDED PRIOR TO EXP. DATE OF 12/30/99
Sheriff's Costs= So answe a-:
Docketing 18.00
Service 10.54
NOT FOUND RETURN 5.00 R! Thomas Kline
Surcharge 8.00 Sherif=f of Cumberland County
.00
41.54 GOLDBECK, MCCAFFERTY, MC REEVER
01/04/2000
Sworn and subscribed to before me
this '7 t? day of
Jc A. D.
((trJl?
Pr t onotary
SHERIFF'S RETURN - NOT FOUND
CASE NO: 1999-07211 P
COMMONTWEN T TFI OF PENNSYLVANIA
COUNTY OF CUMBERLAND
GE CAPITAL MORTGAGE SERVS INC
VS
VOLOVSKI TERRY L ET AL
R. Thomas Kline ,Sheriff or Deputy Sherif i, who 1=eing
duly sworn- according to law, says, that he made a diligent search ar
inquiry fo? r the within named defendant, DEFENDANT
VOLOVSKI =TFIRYN M 7=-r-it we
unable to locate Her in his bailiwick. He therefore r==tu rns t=ie
COMPLAINT - WORT FORE
NOTICE
the within named DEFENDANT
, NOT FOUND , as
, VOLOVSKI KATHRYN M
ADDRESS ST-:;ATED IS NOT VALID, ALTERNATE ADDRESS
NOT PROVIDED PRIOR TO EXPIRATION DATE OF 12/30/9.9 .
Sheriff's Costs:
Docketing 6.00
NOT FOUND RETURN 5.00
Affidavit .00
Surcharge 8.00
.00
19.00
So answe x
R.'Thomas Kline
Sheriff of Cumberlar=t d Count y
GOLDBECK, MCCAFFERTY, MCK1=--EVER
01/04/2000
Sworn and subscribed to before ma
this J -7 day of
.2ovv ZM- _ D
Pr h rotary
I HERE6Y Ci6=RTlr%, -u NT THIS
IS A TRUE AM!: _t) -:; _ T COPY
OF TFIE iN lili•).u_ Fi LED
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
GE CAPITAL MORTGAGE SERVS. INC
4680 Hallmark Parkway
San Bernardino, CA 92407
Plaintiff=
Vs.
TERRY L. VOLOVSKI AND
KATHRYN M. VOLOVSKI
(Mortgagor(s) and Real owner(s))
334 Lowther Street
Lemoyne, PA 17043
Defendant (s)
IN THE COURT OF COMMON PLEAS
OF CUMBERLAND COUNTY
CIVIL ACTION - LAW
:ACTION OF MORTGAGE FORECLOSURE
Term
Civil ACTION MORTGAGE
FORECLOSURE
If (
(?i 7 ?
THIS LAW FIRM IS A DEBT COLLECTOR AND WE ARE ATTEMPTING
TO COLLECT A DEBT OWED TO OUR CLIENT. ANY =NFORMATION
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 detend agalnot the claims set forth in the following pages,
you must take action within twenty (20) days after the 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 tc, 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 raghtn
important to you.
YOU SIIOULD TAKE 711IS PAPER TO YOUR LAWYER AT ONCE. IF YOU DO NOT HAVE A LAWYER OR CAIINOT AFFORD ONE,
GO TO OR TELEPHONE THE OFFICE SET FORTH BELOW TO FIND OUT WIIERE YOU CAN GET LEGAL KELP.
Cumberland County Oar Association
2 Liberty Avenue, Carlisle, PA
(500) 990-9108
Legal Services Inc.
5 Irvine Row, Carlisle, PA 17011
(]I]) 243-9400
A V 1 9 0
LE RAN DEMANDADO A USTED EN LA CORTE. 51 DESEA DEFEIIDERSE CONTRA LAS DUEJAS PERESENTAOAS, ES
ABSOLUCAMENTE NECESSARIO WE USTED RESPONDA DENIED DE 20 DIAS DESPUES DE SER SERVIDo CON ESTA DEMANDA Y AVISO.
PARA DEFENIIERSE ES NECESSARIO DUE USTED. 0 SU ABOCADO, REGISTRE CUN I,A CORTE Ell FORMA ESCRITA, EL PUNTO DE VISTA
DE USTED Y NAIgUIER CXWECCION CONTRA L.AS DUEJAS Ell F,STA DEMAIlDA.
RECUERDE: St USTED NO REPONDE A ESTA DEFNIDA, SE PUEDE IROSEGUIR CON EL PROCESO SIR SU PARTICIPACION.
ENTONCES. LA COUCE PUEDE, SIN NOTIFICARIO, DECIDIR A FAVOR DEL DVUNOlANTE Y REOUERI RA QUE USTED CUIIPLA CON 70DAS
LAS PROVISIONES DE ESTA DENANDA. FOR RAZOR DE ESA DECISION. ES POSSIBLE OUR LISTED PUEDA PERDER DINERO, PROPIEDAD
U MRCS DERECIIOS IMPORTANTES.
LLEVE ESTA DEMANDA A ON ADOGADO IMNF.DIATAMEInE.
0S)'
SI NO CONOCE A UN ABOGAIM. LLAME AL "LAWYER REFERENCE {$s$SII„C?IC)Y DE R_EFEREN IA DEqQABOGAI1?p
219-2I5-6100. TRW FI?I/V1 R ,-
Cumberland Cumberland County Bar As ae ion IN TwSi!?aD• y 7 plltp wp.4v$d I r$We unto
2 Liberty Avenue, Carlisle. PA,d . of o• id fill my (800) 990-91.08 r ? , ?? hmm
8 Il- Services . Inc. I 1% J
1o ?e1
B I nc Row. Carlisle. PA Iv011 ",-i?--
IYl71 243-9600 a MK?
COMPLAINT IN MORTGAGE FORECLOSURE
1. Plaintiff is GE CAPITAL MORTGAGE SERVS. INC., 4680
Hallmark Parkway, San Bernardino, CA 92407.
2. Tha name(s) and address (es) of the Defendant (a) is/are
TERRY L. VOLOVSKI, 334 Lowther Street, Lemoyne, PA 17043 and
KATHRYN M. VOLOVSKI, 334 Lowther Street, Lemoyne, PA 17043, who
is/are the mortgagor (s) and real owner (s) of the mortgaged property
hereinafter described.
3. On May 24, 1993, mortgagor(s) made, executed and
delivered a mortgage upon the premises hereinafter described to
BANK UNITED OF TEXAS FSB, which mortgage is recorded in the Office
of the Recorder of Deeds of Cumberland County in Mortgage Book
3-139, Page 7S 0. By Assignment of Mortgage dated May 24, 1993, the
mortgage was assigned to Plaintiff, which Assignment is recorded in
Assignment of Mortgage Book No. 472, Page 351. These documents are
matters of public record and are incorporated herein by reference
i n 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 April 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 3/ 1/99
through 11/30/99 at 8.000%
Per diem interest rate at $16.17
Attorney's Fee at 5%
of Principal Balance
Later Charges 4/ 1/99-11/30/99
Monthly late charge amount at $24.21
Costs of suit and Title Search
Escrow Balance Deficit
Monthly Escrow amount $98.28
$ 73,770.61
4,430.58
3,688.53
193.68
560.00
$ 82,643.40
332.42
$ 82,975.82
7. The Attorney's Fees set forth above are 1n 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. A Notice of Homeowners' Emergency Mortgage Assistance Act
of 1983 has been sent to the Defendant(s) by regular mail in
accordance with Act 91 of 1983 of the Commonwealth of Pennsylvania
on the date set forth in the true and correct copy of such notice
attached hereto as Exhibit "A". The date of the postmark on the
Notice was the same as the date of the Notice. The Defendant(s)
has/have not had the required face to face meeting within the
required time and Plaintiff has no knowledge of any such meeting
being requested by the Defendant(s) through the Plaintiff, the
Pennsylvania Housing Finance Agency, or any appropriate Consumer
Credit Counseling Agency.
WHEREFORE, Plaintiff demands judgment in mortgage foreclosure
the sum of $82,975.82, together with interest at the rate of
$16.17, 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:
GOLDBECIC FE McKEEVER
BY: Joseph A. Goldbec Jr., Esq.
Attorney for Plaintif
SEP 08 '99 03:11PM
P.2i2
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 IS Pa. C.S. 4904 relating to
unworn falsification to authorities.
Date. .. aJ J / //
File Number: 1821
SCHEDULE -CONTINUED tract or and beingCinTthe Borough of Lemoyne inn then CountyiofsCumberland andn9
Commonwealth of Pennsylvania, more particularly described as folIowa:
BEGINNING at a point on the south (southeast) aide of Lowther Street
at the western line of Lot No. 21 on the Plan of Lower Walton laid
out by the Trustees of Jeanne McCormick Estate dated October 1, 1915,
and recorded in the Office of the Recorder of Deeds of Cumberland County
in Plan Book No. 11 Page No. 104, said point being 317.8 feet went
Of the eouthweet corner of Lowther and Third Street (formerly Roasmoyne
Street) as shown on said Plan; thence southeastwardly, by line of said
Lot No. 21 now or late of Raymond Minnick 217.8 feet to the line of
Lot No. 16; thence southweetwardly by line of said Lot No. 16 on said
P
lan 50 feet to a point; thence northwestwardly by a line parallel
to the
of 217.8ifeetitodthe soLots No. 21 uthern aide n of 2 Lowther shown Street; a thence n in adistance
northeastwardly direction along the southern side of said Lowther Street
50 feet to a point, the palce of BEGINNING.
SAID lot fronting 50 feet on the southern side of Lowther Street and
extending back an even width 217.8 feet and being the eastern 50 feet
of Lot No. 22 on Plan of Lower Walton.
RAVING thereon erected a one and one-half story frame dwelling house
known and numbered as 334 Lowther Street.
BEING the same premises which Keith D. Kneller by Deed dated April 6,
1988 and recorded in the Office of the Recorder of Deeds in and for
Cumberland County, Pennsylvania, in Deed Book R, Volume 33, page 874,
granted and conveyed unto Michael J. r.Lach and Sherri L. Reach, his
wife, Grantors herein.
DD?DD!!EE?MS PA91_14OR 010 6
IM: : ACT 91 NOTICE
TO SAVE YOUR HOME FROM FORECLOSUIRI7-= G: Capita;
ana uommonweaitn of Pennsylvania's ilomeownez= s' Emergenw Mortgage
Assistance Program may be able to helpEiR1MCRii+g+[?==DYm_s.follouu=ng notice to
find out how the program works. A?.•;to•u''-•_?r<= ;,..7c-•'••:.1;,;;e ._?;ew.fr:•If you need more information, call the Pennsylvania H01-sing Finance
Agency at 1-800-342-2397.
La Notification en adjunto es de suma import-ancla, pues afecta su
derecho a continuer viviendo en su case. Si no eomprende el contenido de
esta not1ficacion obtenga una traduccion immedi it_.-ammente lla"*-a-rdo esta
agencia (Pennsylvania Housing Finance Agency) sin_.. cargos al ? umero
mencionado arriba. Puedes ser elegible pare un p=estamo por el programa
llamado "Homeowners' Emergency Mortgage Assistant-e Program" a...1 cual puede
salvar su casa de la perdida del derecho a redinri.r su hipotec-a.
ACT 91 NOTICE
IMPORTANT: NOTICE OF HOM= OWNERS'
EMERGENCY MORTGAGE ASSISTA3-- CE PROGRAM
PLEASE READ THIS NOT=-CE.
YOU MAY BE ELIGIBLE FOR F3Z:NANCIAL
ASSISTANCE WHICH CAN SAVE YOU=-Z HOME FROM
FORECLOSURE AND HELP YOU MAKE FUTURE =MORTGAGE PF35EMENTS
May 29, 1999
RE: G.E. CAPITAL MORTGAGE SERVICES, INC.
Property Address: 334 LOWTHER STREET, LEMOYNE? PA 17043
Loan # 10339133
TO: TERRY L VOLOVSKI
334 LOWTHER ST
LEMOYNE, PA 17043
FROM: G.E. Capital Mortgage Services
You may be eligible for financial assistance that -..mill prevent. foreclosure
on your mortgage if you comply with the provisions of the Hom= _wrners'
Emergency Mortgage Assistance Act of 1983 (the You ma= be eligible
for emergency temporary assistance if you default ---?zas been cawed by
circumstances beyond your control, you have a reasonable prosg-ect of
resuming your mortgage payments, and if you meet o--leer eligib-=ity
requirements established by the Pennsylvania Housirz--?q Finance Agency.
Please read all of this Notice. It contains an exL? -lanation of= your rights.
Under the Act, you arP entitled to a temporary stay of foreclosure on your
m6i1!;4age for thirty t , days from the date of this N( ce. During that
t'i you must arrange and attend a "face-to-face" meeting with a
representative of this lender, or with a designated consumer crecli
counseling agency. The purpose of this meeting is to attempt to( wwoi`k out a
repayment plan, or to otherwise settle your delinquency. This meeting must
occur= in the next thirty (301 days. CE Capital Mongace Ser vlcvs, In:,
.i C.? : ^' n'fc'4' C'i i ^.. .. o,•..,!i r.'C+IC]CE L:I:alaHC ^.
If you attend a face-to-face meeting with"tni6"3ender-+!'or•wihfi=a consumer
credit counseling agency identified in this notice, no further proceeding
in mortgage foreclosure may take place for thirty (30) days after the date
of this meeting. The name, address, and telephone number of our
representative is:
G,E. Capital Mortgage Services
625 Maryville Centre Drive
St. Louis, MO 63141
The names and addresses of designated consumer credit counseling agencies
are shown on the attached sheet. it is only necessary to schedule one
face-to-face meeting. You should advise this lender immediately of your
intentions.
Your mortgage is in default because you have failed to pay promptly
installments of principal and interest, as required for at least sixty (60)
days. The total amount of the delinquency is $1,455 - 96. That sum includes
the following: payments due 04/01/99 through the first of this month and
late charges.
Your mortgage is also in default for the following reason:
2LLNES3S OF PRINCIPAL MORTGAGOR.
2f you have tried and are unable to resolve this prcblem at or after our
face-to-face meeting, you have the right to apply for financial assistance
from the Homeowners' Emergency Mortgage Assistance Fund. In order to do
this, you must fill out, sign and file a completed Homeowners' Emergency
Assistance Application with one of the designated consumer credit
counsetling agencies listed on the attachment. An application for
assistance may only be obtained from a consumer credit counseling agency.
The consumer, credit counseling agency will assist you in filling out your
application and will submit your completed application to the Pennsylvania
Housing Finance Agency. Your application must be filed or postmarked,
within thirty (30) days of your face-to-face meeting.
St is extremely important that you file your application promptly. If you
do not do so, or if you do not follow other time periods set forth in this
letter, foreclosure may proceed against your home immediately.
Available funds for emergency mortgage assistance are very limited- They
will be disbursed by the Agency under the eligibility criteria established
by the ACT.
It is extremely important that your application is accurate and complete in
every respect. The Pennsylvania Housing Finance Agency has sixty (60) days
to make a decision after it receives your application. During that
additional time, no foreclosure proceedings will be pursued against you if
you have met the time requirements set forth above. You will be notified
directly by the Agency of its decision on your application.
The-Pennsylvania Houses ng Finance Agency iu located at 2101 North Front
Stt , Post Office E 8029, Harrisburg, Pennsylvania 7105. Telephone
Nb:173.71 780.3800 or 1-800-342-2397 (to11 free number). Persons with
impaired hearing can call 1-800-342-2397- ACE Canitai
In addition, you may receive another notice from this lender un er Act 6 of
1974. That notice is called a "Notice Foreclose. •• You must
read both notices, since they both explainvxights'- that, 'you.now-have under
Pennsylvania law. However, if you choose-to;ezercise your right described
in this notice, you cannot foreclosed upon while you are receiving that
assistance.
Sincerely, 10339133
Loan Counselor, Collection Department
1 (BOO) 344-6723
The following disclosure is required by applicable federal and state law
for certain loans that we service: This communication is from a debt
collector and is an attempt to collect a debt; any information obtained
will be used for that purpose.
ix.
a:..
GE Capital
GE Capital Monoape Services. Inc.
A t: x.: 0. LP981Ji [ L•`R f: L'C7-?:6 Ca V0fJl!v-
•:i,:Gr.,t':n:!••r.rn.:.;.
HUD APPROVED COUNSELING AGENCIES
PENNSYLVANIA
DELAWARE COUNTY H.O.P.E. BAYFRONT NATO, INC.
PHILADELPHIA COUNCIL FOR COMMUNITY 312 CHESTNUT STREET
ADVANCEMENT ERIE, PA 16507
511 WELSH STREET (814) 459-2761
CHESTER, PA 19013
(215) 872 3500
COMMUNITY RESOURCES FOR INDEP
2222 FILMORE AVENUE
ERIE, PA 16506
(814) 838-7222
HARRISBURG FAIR HOUSING COUNCIL
1228 BAILEY STREET
HARRISBURG, PA 17103
(717) 238-9540
INDIANA COUNTY COMMUNITY
ACTION PROGRAM INC.
827 WATER STREET
PO BOX 18-7
INDIANA, PA 15701
(412) 465-2657
NORTHERN TIER COMMUNITY
ACTION CORPORATION
135 WEST 4TH STREET
EMPORIA, PA 15834
(814) 486 -1161
GREATER ERIE COMMUNITY
ACTION AGENCY
18 WEST 97H STREET
ERIE, PA 16501
(814) 459-4581
ELK COUNTY HOUSING AUTHORITY
424 WATER STREET EXT.
PO BOX 10 0
JOHNSONBURGH, PA 15845
(814) 965 -2532
ASSOCIATED FAMILY SERVICES
213 CENTER STREET
MEADVILLE, PA 16335
(814) 337-8457
NEW KENSINGTON C.D.C.
2513-15 FRA4KFORD AVENUE
PHILADELPHIA, PA 19125
(215) 427-0350
TABOR COMMUNITY SERVICES
439 EAST KING STREET
LANCASTER, PA 17602
(717) 397-5182
BOOKER T. WASHINGTON CENTER
1720 HOLLAND STREET
ERIE, PA 16503
(814) 453-5744
U12BAN LEAGUE OF
METROPOLITAN HARRISBURG
25 NORTH FRONT STREET
HARRISBURG, PA 17101
(717) 234-3253
HOUSING OPPORTUNITIES, INC
133 SEVENTH AVENUE
PO BOX 9
MCKEESPORT, PA 15132
(412) 664-1590
LAWRENCE COUNTY SOCIAL SERVICES,INC.
3:3-39 SOUTH JEFFERSON STREET
NEW CASTLE, PA 16103
(412) 65B-7258
PHILADELPHIA COUNCIL FOR
COMMUNITY ADVANCEMENT
100 NORTH 17TH STREET - SUITE 600
PHILADELPHIA, PA 19103
(215) 567-7803
GE 6aoital
GE Caoilal Mengaee Services. Im
HUD APPROVED COUNSELING AGENCIES
PENNSYLVANIA (Cont)
TENANTS' ACTION GROUP CENTER FOR INDEPENDENT LIVING SW PA
OF PHILADELPHIA 7110 PENN AVENUE
21 SOUTH 12TH STREET - 12TH FLOOR PITTSBURGH, PA 15208
PHILDELPHIA, PA 19107 (412) 371-7700
(215) 575-0700
TREHAD CENTER OF NE PENNSYLVANIA
7 LAKE AVENUE
MONTROSE, PA 18801
(717) 278-3338
HOUSING ASSOCIATION INFORMATION PROGRAM
1314 CHESTNUT STREET - SUITE 900
PHILADELPHIA, PA 19107
(215) 545-6010
MORTGAGORS COUNSELED AT
658-60 NORTH WATTS STREET,
PHILADELPHIA, PA 19123
NORTHWEST COUNSELING SERVICE
5001 NORTH BROAD STREET
PHILADELPHIA, PA 19141
(215) 549-2344
URBAN LEAGUE OF PHILADELPHIA
4601 MARKET STREET
PHILADELPHIA, PA 19139
(215) 476-4040
ELDER-ADO, INC
320 BROWNSVILLE ROAD
PITTSBURGH, PA 15210
(412) 381-6900
ECONOMIC OPPORTUNITY CABINET
118 EAST NORWEGIAN STREET
POTTSVILLE, PA 17901-2921
(717) 622-1995
TABLELAND SERVICES, INC.
131 NORTH CENTER AVENUE
PO BOX 756
SOMERSET, PA 15501
(814)445-9628 OR (814) 445-0148
PHILADELPHIA HOUSING
DEVELOPMENT CORPORTATION
1234 MARKET STREET - 10TH FLOOR
PHILADELPHIA, PA 19107
(215) 448-3137 OR (215) 448-3132
CONSUMER CREDIT COUNSELING
OF WESTERN PENNSYLVANIA
309 SMITHFIELD STREET - SUITE 2000
PITTSBURGH, PA 15222
(412) 471-7584
HILL COMMUNITY DEVELOPMENT
2015-2017 CENTRE AVENUE
PITTSBURGH, PA 15219
(412) 765-1320
MERCER COUNTY
COMMUNITY ACTION AGENCY
309 OHIO STREET
SHARON, PA 163.46
(412) 342-6222
WARREN FOREST COUNTY E.O.C.
1209 PENNSYLVAIA AVENUE WEST
PO BOX 547
WARREII, PA 16365
(814) 726 -24 00
f
GE Capita!
6E Cauifal mar40a0e Services. Ia:.
,. ur: C' i,?..7er?e: c?_:.:...... .it:17.i.'P L:•'A7fapan
HUD APPROVED COUNSELING AGENCIES
PENNSYLVANIA(Cont)
GARFIELD JUBLIEE ASSOCIATION, INC.
53.38 PENN AVENUE
PITTSBURGH, PA 15224
(412) 665-5200
URBAN LEAGUE OF PITTSBURGH
ONE SMITHFIELD STREET
PITTSBURGH, PA 15222
(412) 261-1230
BERKS COMMUNITY ACTION AGENCY
BUDGET COUNSELING CENTER
247 NORTH FIFTH STREET
READING, PA 19601
(215) 375-7866
FAYETTE COUNTY
COMMUNITY ACTION AGENCY
137 NORTH BEESON AVENUE
UNIONTOWN, PA 15401
(412) 437-6050
WASHINGTON-GREENE
COMMUNITY ACTION CORPORATION
33-5 EAST HALLAM AVENUE
WASHINGTON, PA 15301
(412) 225-9550
HOUSING COUNCIL OF YORK
13.6 NORTH GEORGE STREET
YORK, PA 17401
(717) 854-1541
COMMISSION OF ECONOMIC
OPPORTUNITY OF LUZERNE COUNTY
122-213 SOUTH MAIN STREET
WILKES-BARRE, PA 18701
(717) 826-0510
SHENANGO VALLEY URBAN LEAGUE
39 CHESTNUT STREET
SHARON, PA 16146
(412) 981-5310
TRI-COUNTY PARTNERSHIP FOR
INDEPENDENT LIVING
69 EAST BEAU STREET
WASHINGTON, PA 15301
(412) 223-5115
CONSUMER CREDIT COUNSELING
SERVICE OF LEHIGH VALLEY
3671 CRESCENT COURT EAST
WHITEHALL, PA 18052
(215) 821-4011
WASHINGTON- GREENE
COMMUNITY ACTON CORPORATION
22 WEST HIGH STREET
WAYNESBURG, PA 15370
(412) 852-2893
1
GE Capital
GE builal Mongaas Seances, Inc.
. C- s..
DDDDEMSPA91_NOR03-06
ACT 91 NOTICE
TAKE ACTION TO SAVE YOUR HOME FROM FORECLOSURE
The Commonwealth of Pennsylvania's Homeowners' Emergency Mortgage
Assistance Program may be able to help you. Read the following notice to
find out how the program works.
If you need more information, call the Pennsylvania Housing Finance
Agency at 1-800-342-2397,
La Notification en adjunto es de suma impo rtancia, pues afecta su
derecho a continua r viviendo en su casa. Si no comprende el contenido de
esta notificacion obtenga una tra duccion immediatamente llamando esta
agencia (Pennsylvania Housing Finance Agency) sin cargos al numero
mencionado arriba. Puedes ser el egible Para un prestamo por el programa
llamado "Homeowners' Emergency Mortgage Assistance Program" al cual puede
salvar su casa de la perdida del de=echo a redimir su hipoteca.
ACT 91 NOTICE
IMPORTANT: NOTICE OF HOMEOWNERS'
EMERGENCY MORTGAGE ASSISTANCE PROGRAM
PLEASE READ THIS NOTICE.
YOU MAY BE ELIGIBLE FOR FINANCIAL
ASSISTANCE WH=CFI CAN SAVE YOUR HOME FROM
FORECLOSURE AND HELP YOU MAKE FUTURE MORTGAGE PAYMENTS
May 29, 1999
RE: G.E. CAPITAL MORTGAGE SERVICES, INC.
Property Address: 334 LOWTHEIZ STREET, LEMOYNE PA 17043
Loan R 10339133
TO: KATHRYN M VOLOVSKI
334 LOWTHER ST
LEMOYNE, PA 17043
FROM: G.E. Capital Mortgage Services
You may be eligible for financial assistance that will prevent foreclosure
on your mortgage if you comply with the provisions of the Homeowners'
Emergency Mortgage Assistance Act of 1983 (the "ACT"). You may be eligible
for emergency temporary assistance if you default has been caused by
circumstances beyond your control, you have a reasonable prospect of
resuming your mortgage payments, and if you meet other eligibility
requirements established by the Pennsylvania Housing Finance Agency.
Please read all of this Notice. X t contains an explanation of your rights.
%72
I-bp
G= caaita.`
GE Caullal Mallgace 5 cln: es, IeC.
Under the Act, you are entitled to a temporary stay of foreclosure on your
mortgage for thirty (30) days from the date of this Notice. During that
time you must arrange and attend a "face-to- face" meeting with a
representative of this lender, or with a designated consumer credit
counseling agency. The purpose of this meeting is to attempt to work out a
repayment plan, or to otherwise settle your delinquency. This meeting must
occur in the next thirty (30) days,
If you attend a face-to-face meeting with this lender, or with a consumer
credit counseling agency identified in this notice, no further proceeding
in mortgage foreclosure may take place for thirty 130) days after the date
of this meeting- The name, address, and telephone number of our
representative :Ls:
G.E. Capital Mortgage Services
625 Maryville Centre Drive
St. Louis, MO 63141
The names and addresses of designated consumer credit counseling agencies
are shown on the attached sheet. It is only necessary to schedule one
face-to-face meeting. You should advise this lender immediately of your
intentions.
Your mortgage is in default because you have failed to pay promptly
installments of principal and interest, as required for at least sixty (60)
days. The total amount of the delinquency is $1,455.96. That sum includes
the following: payments due 04/01/99 through the first of this month and
late charges.
Your mortgage is also in default for the following reason:
ILLNESS OF PRINCIPAL NORTGAGOR-
If you have tried and are unable to resolve this problem at or after our
face-to-face meeting, you have the right to apply for financial assistance
from the Homeowners' Emergency Mortgage Assistance Fund. In order to do
this, you must E111 out, sign and file a completed Homeowners' Emergency
Assistance Application with one of the designated consumer, credit
counseling agencies listed on the attachment. An application for
assistance may only be obtained from a consumer credit counseling agency.
The consumer credit counseling agency will assist you in f illing out your
application and will submit your completed application to the Pennsylvania
Housing Finance Agency. Your application must be filed or postmarked,
within thirty (3 O) days of your face-to-face meeting.
It is extremely important that you file your application promptly. If you
do not do so, or if you do not follow other time periods set forth in this
letter, foreclosure may proceed against your home immediately.
Available funds for emergency mortgage assistance are very limited- They
will be disbursed by the Agency under the eligibility criteria established
by the ACT.
It is extremely important that your application is accurate and complete in
every respect. TYie Pennsylvania Housing Finance Agency has sixty (60) days
Gc Capita!
GFCapilol Mortgage Services. Inc.
A U::: ^, t •v_°9f'n' t ra_:c: L.':.'.i? C','^Y ?•5 L: [CJfdb:?
to make a decision after it receives your application. During that
additional rime, no foreclosure proceedings will be pursued against you if '
you have me-:r the time requirements set forth above. You will be notified'
directly bar the Agency of its decision on your appLication.
GE CaQi[ai
CE Walla) Mongaae Serves. L:_.
The Pennsylvania Housing Finance Agency is located at 2101 North Front
Street, Post Office Box 8029, Harrisburg, Pennsylvania 17105. Telephone
No. (717) 780-3800 or 1-800-342-2397 (toll free number) . Persons with
impaired hearing can call 1-800-342-2397.
In addition, you may receive another notice from this lender under Act 6 of
1974- That notice is called a "Notice of Intention to Foreclose." You must
read both notices, since they both explain rights that you now have under
Pennsylvania law. However, if you choose to exercise your rights described
in this notice, you cannot foreclosed upon while you are receiving that
assistance.
sincerely, 10339133
Loan Counselor, Collection Department
1 (800) 344-6723
The following disclosure is required by applicable federal and state law
for certain loans that we service: This communication is from a debt
collector and is an attempt to collect a debt; any information obtained
will be used for that purpose.
jAl
T ?
f 0.
GE Capital
GE Capital Mnrlgace Servses, Inc,
.fG+C r,.7trrVr:. ?d: •;:.t. ;c-cY,'IdrL•.•_
HUD APPROVED COUNSELING AGENCIES
PENNSYLVANIA
DELAWARE COUNTY H.O. P. E. BAYFRONT NATO, INC.
PHILADELPHIA COUNCIL FOR COMMUNITY 312 CHESTNUT T STREET
ADVANCEMENT PA 16507
511 WELSH STREET (814) 4S9-2761
CHESTER, PA 19013
(215) 872 3500
COMMUNITY RESOURCES FOR INDEP- HARRISBURG FAIR HOUSING COUNCIL
2222 FIU40RS AVENUE 1228 BAILEY STREET
ERIE, PA 16506 HARRISBURG, PA 17103
(814) 838-7222 (717) 23B-9540
INDIANA COUNTY COMMUNITY
ACTION PROGRAM INC.
B27 WATER STREET
PO BOX 187
INDIANA, PA 15701
(412) 465-2657
NORTHERN TIER COMMUNITY
ACTION CORPORATION
135 WEST 47H STREET
EMPORIA, PA 15834
(814) 486-1161
TABOR COMMUNITY SERVICES
439 EAST KING STREET
LANCASTER, PA 17602
(717) 397-5182
BOOKER T. WASHINGTON CENTER
1720 HOLLAND STREET
ERIE, PA 16503
(814) 453-5744
GREATER ERIE COMMUNITY
ACTION AGENCY
18 WEST 9T11 STREET
ERIE, PA 16501
(814) 459-4 581
ELK COUNTY HOUSING AUTHORITY
424 WATER STREET EXT.
PO BOX 100
JOHNSONBURGH, PA 15845
(814) 965-2532
ASSOCIATED FAMILY SERVICES
213 CENTER STREET
MEADVILLE, PA 16335
(814) 337-8457
NEW KENSINGTON C.D.C.
2513-15 FRANKFORD AVENUE
( PHILADELPH3=A, PA 19125
(215) 427-0350
URBAN LEAGUE OF
METROPOLITAN HARRISBURG
25 NORTH FRONT STREET
HARRISBURG, PA 17101
(717) 234-3253
HOUSING OPPORTUNITIES, INC
133 SEVENTH AVENUE
PO BOX 9
MCKEES PORT, PA 15132
(412) 664-1590
LAWRENCE COUNTY SOCIAL SERVICES, INC.
33-39 SOUTH JEFFERSON STREET
NEW CASTLE, PA 16103
(412) 658-7258
PHILADELPHIA COUNCIL FOR
COMMUNITY ADVANCEMENT
100 NORTH 17TH STREET - SUITE 600
PHILADELPHIA, PA 19103
(215) 567-7803
a:51rauita!
GE Cnoltnl Monorcr Sernces. fnc.
HUD APPROVED COUNSELING AGENCIES
PENNSYLVANIA (Cori t)
TENANTS' ACTION GROUP CENTER FOR INDEPENDENT LIVING SW PA
OF PHILADELPHIA 7110 PENN AVENUE
21 SOUTH 12TH STREET - 12TH FLOOR PITTSBURGH, PA 15208
PHILDELPHIA, PA 19107 (412) 371-7700
(215) 575-0700
TREHAD CENTER OF NE PENNSYLVANIA
7 LAKE AVENUE
MONTROSE, PA 18801
(717) 278-3338
HOUSING ASSOCIATION INFORMATION PROGRAM
1314 CHESTNUT STREET - SUITE 900
PHILADELPHIA, PA 19107
(215) 545-6010
MORTGAGORS COUNSELED AT
658-60 NORTH WATTS STREET,
PHILADELPHIA, PA 19123
NORTHWEST COUNSELING SERVICE
5001 NORTH BROAD STREET
PHILADELPHIA, PA 19141
(215) 549-2344
URBAN LEAGUE OF PHILADELPHIA
4501 MARKET STREET
PHILADELPHIA, PA 19139
(215) 476-4040
ELDER-ADO, INC
320 BROWNSVILLE ROAD
PITTSBURGH, PA 15210
(412) 381-6900
ECONOMIC OPPORTUNITY CABINET
118 EAST NORWEGIAN STREET
POTTSVILLE, PA 17901-2921
(717) 622-1995
TABLELAND SERVICES, INC.
131 NORTH CENTER AVENUE
PO BOX 756
SOMERSET, PA 15501
(814)445-9628 OR (814) 445-0148
PHILADELPHIA HOUSING
DEVELOPMENT CORPORTATION
1234 MARKET STREET - MOTH FLOOR
PHILADELPHIA, PA 19107
(215) 448-3137 OR (215) 448-3132
CONSUMER CREDIT COUNSELING
OF WESTERN PENNSYLVANIA
309 SMITHFIELD STREET - SUITE 2000
PITTSBURGH, PA 15222
.(412) 471-7584
HILL COMMUNITY DEVELOPMENT CORPORTATION
2015-2017 CENTRE AVENUE
PITTSBURGH, PA 15219
(412) 765-1320
SHARON, PA 16146
(412) 342-6222
MERCER COUNTY
COMMUNITY ACTION AGENCY
309 OHIO STREET
WARREN FOREST COUNTY E .O. C .
1209 PENNSYLVAIA AVENUE WEST
PO BOX 547
WARREN, PA 16365
(814) 726-2400
GE Capital
GE Capital Mortgage Servic s. Inc.
F Cm- .i?r^/]i HeG:: La:' .:r,?•:?l.^rpor?hon
J;:SQ F,.i l49N07
HUD APPROVED COUNSELING AGENCIES
PENNSYLVANIA(Coxit )
GARFIELD JCJBLIEE ASSOCIATION, INC -
5138 PENN AVENUE
PITTSBURGH, PA 15224
(412) 665-5200
URBAN LEAGUE OF P= TSBURGH
ONE SMITHFIELD STTrT=--ET
PITTS33URGH, PA 15:-=22
(412) 261-1130
BERKS COMMC3NITY ACTION AGENCY
BUDGET COUNSELING CENTER
247 NORTH 1= IFTH STREET
READING, PA 19601
(215) 375-7866
FAYETTE COUNTY
COMMUNITY ACTION AGENCY
137 NORTH EBEESON AVENUE
UNIONTOWN, PA 15401
(412) 437-6050
WASHINGTON -GREENE
COMMUNITY ACTION CORPORATION
315 EAST HALLAM AVENUE
WASHINGTON, PA 15301
(412) 225-9550
HOUSING COIINCIL OF YORK
116 NORTH GEORGE STREET
YORK, PA 1-7401
(717) 854-1541
COMMISSION OF ECONOMIC
OPPORTUNITY OF IAZERNE COUNTY
122-213 SOUTH MAIN STREET
WILKES-BARE2E, PA 18701
(717) 826-0510
SHENANGO VALLEY UT;- TaAN LEAGUE
39 CFIESTNUT STREET--
SHARON, PA 16146
(412) 981-5310
TRI-COUNTY PARTNETr SHIP FOR
INDEPENDENT LIVING
69 EAST BEAU STREW^?
WASHINGTON, PA 15--- ----AO1
(412) 223-5115
CONSLT NER CREDIT CC»`JNSELING
SERVICE OF LEHIGH -!ALLEY
3671 CRESCENT COUFP--= EAST
WHITEHALL, PA 18052
(215) 821-4011
WASHY VGTON-GREENE
COMMCTDIITY ACTON CC=?3-=RPORATION
22 WEST HIGH STRET?
WAYNESBURG, PA 15-.- 370
(412) 852-2893
:
d OFFICE OF T!IE FII EII!FF
.?
-
1^uwv-?
V I
y
1, l!IIC
?v DEC 1 9 39 M'99
FEW'SYi_?:ANIA
GOLDBECK McCAFFERTY St McKEEVER
BY: Joseph A. Goldbeck, Or.
Attorney I.D.#16132
Suite 500 - The Bourse Bldg.
1 11 S. Independence Mall East
Philadelphia, PA 19106
2 15-627-1322
Attorney for Plaintiff
1 HEREBY CERTIFY THAT THIS
IS A TRUE AND r;ORRECT COPY
OF THE GNGINr L FILED
GE CAPITAL MORTGAGE SERVS. INC. IN THE COURT OF COMMON PLEAS
4 680 Hallmark Parkway
San Bernardino, CA 92407 OF CUMBERLAND COUNTY
Plaintiff
Vs.
CIVIL ACTION - LAW
:ACTION OF MORTGAGE FORECLOSURE
TERRY L. VOLOVSKI AND
KATHRYN M. VOLOVSKI
(Mortgagor (s) and Real Owner (s) )
334 Lowther Street
Lemoyne, PA 17043
Defendant (s)
Term
CIVIL ACTION MORTGAGE
FORECLOSURE
q,(, " 74 ( Q't'?L
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 defend against the claims set forth in the following pages,
you must take action within twenty (20) days after the 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 nay 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 ny lose money or property or other rights
important to you.
YOU SHOULD TAKE THIS PAPER TO YOUR LAWYER AT ONCE. IF YOU ID Nor HAVE A LAWYER OR CANNOT AFFORD ONE,
GO TO OR TELEPHONE THE OFFICE SIT FORTH DELOW TO FIND OUT WHERE YOU CAN GET LEGAL HELP.
Cumberland County Bar Association
2 Liberty Avenue, Carlisle, PA
(000) 790-9108
Legal Services Inc.
8 Irvine Be.. Carlisle, PA 17013
(717) 243-9400
A V 1 S 0
LE HAN DEMANDADO A USTED EN I.A CORTE, SO DESEA DEFENDERSE COIITRA LAS QUE.TAS PERESENTADAS, ES
A13SOLUTAMEIRE NECESSARIO OUE USTED RESPONDA DENTRO DE 20 DIAS DESPUES DE SER SERVIDO CO?; ESTA DEMANDA Y AVISO.
PF.RA DEFENDERSE ES NECESSARIO QUE USTED, O SU ABOGADO, REGISTRE COIL LA CORTE EN FORMA ESCRITA, EL PLIM O DE VISTA
DE USTED Y CUALUUIER OWECCION CONTRA LAS DUEIAS Elf ESTA DEMANDA.
RENERDE: SO LISTED NO REPONDE A ESTA DEMNNA, SE PUEDE PROSEGUIR COIL EL PROCESO SIN SO PARTICIPACION.
Ebb ONCES. IA COUTE PUEDE, SIN NOTIFICARIO. DECIDIR A FAVOR DEL DERANDANTTE Y REOUERIRA CUE USTED CUMPLA CON TODAS
LAS PROVISIONES DE ESTA DEMAIIDA. FOR RA20N DE ESA DECISION, ES POSSIBLE CUE LISTED PUEDA PERDER DINERO, PROPIEDAD
U OTROS DERECNOS IMPORTALRES.
LIVE ESTA DEMAIIDA A UN ABOGADO IMfEDIATAMENIE.
SI NO CONOCE A NI ABOGADO, LLAME AL 'LAWYER REFERENCE SERVICE- ISERVICIO DE REFERENCIA DE ABOGADOS),
215-230-6100. I??'1?? df Eli f ,?.
WV)i-PY. FROM RECCM
Cumberland County Bar Association
2 Liberty Avenue, Carlisle, PA IR Toolff qr whorod, I herb unto So tVy h&W
(000) s990 - 9108 1
ervices Inc. WW ttN x141 0l r
at (.arilaie, Pi
Legal A?
B Irvine Row, Carlisle, PA 17013 a-ciq
(717) 24 3400 243-9400
COMPLAINT IN MORTGAGE FORECLOSURE
1. Plaintiff is GE CAPITAL MORTGAGE SERVS. INC., 4680
Hallmark Parkway, San Bernardino, CA 92407.
2. The name(s) and address(es) of the Defendant(s) is/are
TERRY L. VOLOVSKI, 334 Lowther Street, Lemoyne, PA 17043 and
KATHRYN M. VOLOVSKI, 334 Lowther Street, Lemoyne, PA 17043, who
is/are the mortgagor(s) and real owner (s) of the mortgaged property
hereinafter described.
3. On May 24, 1993, mortgagor (s) made, executed and
delivered a mortgage upon the premises hereinafter described to
BANK UNITED OF TEXAS FSB, which mortgage is recorded in the office
of the Recorder of Deeds of Cumberland County in Mortgage Book
1139, Page 750. By Assignment of Mort gage dated May 24, 1993, the
mortgage was assigned to Plaintiff, which Assignment is recorded in
Assignment of Mortgage Book No. 472, Page 351. 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 April 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.
The following amounts are due on the mortgage:
Principal Balance
Interest from 3/ 1/99
through 11/30/99 at 8.000%
Per diem interest rate at $16
Attorney's Fee at 5%
of Principal Balance
Late Charges 4/ 1/99-11/30 /99
Monthly late charge amount at
Costs of suit and Title Search
Esc row Balance Deficit
Monthly Escrow amount $98.28
17
$24.21
$ 73,770.61
4,430.58
3,688.53
193.68
560.00
$ 82,643.40
332.42
$ 82,975.82
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 . A Notice of Homeowners' Emergency Mortgage Assistance Act
of 1983 has been sent to the Defendant(s) by regular mail in
accordance with Act 91 of 1983 of the Commonwealth of Pennsylvania
on the date set forth in the true and correct copy of such notice
attached hereto as Exhibit "A". The date of the postmark on the
Notice was the same as the date of the Notice. The Defendant(s)
has/have not had the required face to face meeting within the
required time and Plaintiff has no knowledge of any such meeting
being requested by the Defendant (s) through the Plaintiff, the
Pennsylvania Housing Finance Agency, or any appropriate Consumer
Credit Counseling Agency.
WHEREFORE, Plaintiff demands judgment in mortgage foreclosure
the sum of $82,975.82, together with interest at the rate of
$16.17, per day and other expenses incurred by the Plaintiff which
are properly chargeable i n accordance with the terms of the
mortgage, and for the foreclosure and sale of the mortgaged
premises.
By
GOLDBECK FE McKEEVER
BY: Joseph A. Goldbec , Jr., Esq.
Attorney for Plaintif
P>?
SEP 08 '99 03:11PM
P.2i2
VERT FICATIOAT
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 3.8 Pa. C.S. 4904 relating to
unsworn falsification to authorities.
Date:J i- a3 q 9
?? C?? LCao-IL9?
i'i
File t.Wmber: 19321
SCHEDULE -CONTINUED
ALL THAT CERTAIN tract or parcel of land and premises, situate, lying
and being ire the Borough of Lemoyne in the County of Cumberland and
Commonwealtkm of Pennsylvania, more particularly described as follows:
BEGINNING at= a point on the south (southeast) side of Lowther Street
at the western line of Lot No. 21 on the Plan of Lower Walton laid
out by the 2xuatees of James McCormick Estate dated October 1., 1915,
and recorded in the Office of the Recorder of Deeds of Cumberland County
in Plan Books No. 1, Page No. 104, said point being 317.8 feet went
of the soutkzweat corner of Lowther and Third Street (formerly Rossmoyne
Street) as arhown on Maid Plan; thence southeastwardly by line of said
Lot No. 21 sow or late of Raymond Minnick 217.8 feet to the I-ine of
Lot No. 16; thence southweetwardly by line of said Lot No. 16 on said
Plan 50 feet to a point; thence northwestwardly by a line parallel
to the lindividing Lots No- 21 and 22 as shown on said Plan a distance
of 217.8 f:. t to the southern aide of Lowther Street; thence in a
northeastwardly direction along the southern side of said Lowther Street
50 feet to a point, the palcet of BEGINNING.
SAID lot fror ting 50 feet on the southern side of Lowther Street and
extending back an even width 217.8 feet and being the eastern 50 feet
of Lot No. 2:2 on Plan of Lower Walton.
HAVING thereon erected a one and one-half story frame dwelling house
known and numbered as 334 Lowther STreet.
BEING the same premises which Keith D. Kneller by Deed dated April 61
1988 and recorded in the office of the Recorder of Deeds in and for
Cumberland County, Pennsylvania, in Deed Book IT volume 33, page 874,
granted and =onveyed unto Michael J. Reach and Sherri L. Reach, his,
wife, Grantors herein.
106
ACT 91 NOTICE
X H I B ITE A =ON TO SAVE YOUR HOME FROM FORECLOSURE CE Capita"
The Comrr=orwealth of Pennsylvania's Homeowners' Emergency Mortgage
Assistance Program may 3ne able to helpE!9W0rMcR#A&*Nes.following notice to
find out how t3te progra=n works. ??%,rn:m^s•:': r:xc,..:: c•r. :;;;,?„c :rr•ara6rs
If you r=eed more i=rfornation, call the Pennsylvania Housing Finance
Agency at 1-Er.021-342-239-7.
La Notif=ication en adjurto es de suma importancia, pues afecta su
derecho a cormtdnuar viv=Lendo en su casa. Si no comprende e1 contenido de
esta notificacion obtenga uaa traduccion immediatamente llamando esta
agencia (Pennsylvania Housing Finance Agency) sin cargos al numero
mencionado arrziba. Puecles set elegible para un prestamo por el programa
llamado "Home=owners' Emergency Mortgage Assistance Program" al cual puede
salvar su casa de la pe=dida del derecho a redimir su hipoteca.
ACT 91 NOTICE
IMPORTANT: NOTICE OF HOMEOWNERS'
:gMERGENCY MORTGAGE ASSISTANCE PROGRAM
PLEASE READ THIS NOTICE.
YOU MAY BE ELIGIBLE FOR FINANCIAL
ASS=STANCE WHICH CAN SAVE YOUR HOME FROM
FORECLOSUR3= AND HELP YOU MAKE FUTURE MORTGAGE PAYMENTS
May 29, 1999
RE: G.E. CAPITAL MORTGAGE SERVICES, INC.
Property- Address : 334 LOWTHER STREET, LEMOYNE PA 17043
Loan # 3_ 0339133
TO: TERRY L -7C)LOVSKI
334 LOWTTIIER ST
LEMOYNE, 3RA 17043
FROM: G.E. Capital Moxz=gage Services
You may be el igible for financial assistance that will prevent foreclosure
on your mortgage if you comply with the provisions of the Homeowners'
Emergency Mortgage Assistance Act of 1983 (the "ACT") . You may be eligible
for emergency- temporary assistance if you default has been caused by
circumstances beyond your control, you have a reasonable prospect of
resuming your mortgage Qayments, and if you meet other eligibility
requirements established by the Pennsylvania Housing Finance Agency.
Please read a.12- of this Notice. It contains an explanation of your rights.
Under the Act, you are entitled to a temporary stay of foreclosure on your
md?_?age for thirty t , days from the date of this Mc :e. During that
ti4c ,'you must arrange and attend a "face-to-face" meeting with a
representative of this lender, or with a designated consumer crevd:L D/ (e
counseling agency. The purpose of this meeting is to attempt to wo xx out a
repayment plan, or to otherwise settle your delinquency. This meet dng must
occur in the next thirty (30) days. GE Capita/Martoaac Servres, Inc,
If you attend a face-to-face meeting with"th'is:'lender-"""'ar;-witti=a consumer
credit counseling agency identified in this notice, no further proceeding
in mortgage foreclosure may take place for thirty (30) days after the date
of this meeting. The name, address, and telephone number of our
representative is:
G.E. Capital Mortgage Services
625 Maryville Centre Drive
St. Louis, MO, 63141
The names and addresses of designated consumer credit counseling agencies
are shown on the attached sheet. It is only necessary to schedule one
face-to-face meeting. You should advise this lender immediately of your
intentions.
Your mortgage is in default because you have failed to pay promptly
installments of principal and interest, as required for at least sixty (60)
days. The total amount of the delinquency is $1,455.96. That sum includes
the following: payments due 04/01/99 through the first of this month and
late charges.
Your mortgage is also in default for the following reason:
ILLNESS OF PRINCIPAL MORTGAGOR.
If you have tried and are unable to resolve this problem at or after our
face-to-face meeting, you have the right to apply for financial ass stance
from the Homeowners' Emergency Mortgage Assistance Fund. In order to do
this, you must fill out, sign and file a completed Homeowners' Emergency
Assistance Application with one of the designated consumer credit
counseling agencies listed on the attachment. An application for
assistance may only be obtained from a consumer credit counseling agency.
The consumer credit counseling agency will assist you in filling out your
application and will submit your completed application to the Pennsylvania
Housing Finance Agency. Your application must be filed or postmarked,
within thirty (30) days of your face-to-face meeting-
It is extremely important that you file your application promptly. If you
do not do so, or if you do not follow other time periods set forth :in this
letter, foreclosure may proceed against your home immediately.
Available funds for emergency mortgage assistance are very limited. They
will be disbursed by the Agency under the eligibility criteria established
by the ACT.
It is extremely important that your application is accurate and complete in
every respect. The Pennsylvania Housing Finance Agency has sixty (60) days
to make a decision after it receives your application. During that
additional time, no foreclosure proceedings will be pursued against you if
you have met the time requirements set forth above. You will be not 3fied
directly by the Agency of its decision on your application.
The Pennsylvania Housi,g Finance Agency is- located at 2101 North Front
S t, Post Office 1 8029, Harrisburg, Pennsylvania 7105. Telephone
N17) 780-3800 or 1-800-342-2397 (toll free number). Persons with
impaired hearing can call 1-800-342-2397. GE ciwitZi
In addition, you may receive another notice from this lender un er Act 6 of
1974. That notice is called a "Notice G6t7PX:iM=1o)rntw,Foreclose." You must
read both notices, since they both explain -,,rights that, you•_now.have under
Pennsylvania law. However, if you chodse`toieiercise your rights described
in this notice, you cannot foreclosed upon while you are receiving that
assistance.
Sincerely, 10339133
Loan Counselor, Collection Department
1 (800) 344-6723
The following disclosure is required by applicable federal and state law
for certain loans that we service : This communication is from a debt
collector and is an attempt to collect a debt; any information obtained
will be used for that purpose.
GE Capital
GEOpilal Moaaace Sernces. Inr.
A Lla.: of 6e.9e'xi:
971v-
HUD APPROVED COUNSELING AGENCIES
PENNSYLVANIA
DELAWARE COUNTY H.O.P.E. BAYFRONT NATO, INC-
PHILADELPHIA COUNCIL FOR COMMUNITY 312 CHESTNUT STREET
ADVANCEMENT ERIE, PA 16507
511 WELSH STREET (814) 459-2761
CHESTER, PA 19013
(215) 872 3500
COMMUNITY RESOURCES FOR INDEP
2222 FILMORE AVENUE
ERIE, PA 16506
(814) 838-7222
HARRISBURG FAIR HOUSING COUNCIL
1228 BAILEY STREET
HARRISBURG, PA 17103
(717) 238-9540
INDIANA COUNTY COMMUNITY
ACTION PROGRAM INC.
827 WATER STREET
PO BOX 187
INDIANA, PA 15701
(412) 465-2657
NORTHERN TIER COMMUNITY
ACTION CORPORATION
135 WEST 4TH STREET
EMPORIA, PA 15834
(814) 486-1161
GREATER ERIE COMMUNITY
ACTION AGENCY
18 WEST 9TH STREET
ERIE, PA 16501
(814) 459-4581
ELK COUNTY HOUSING AUTHORITY
424 WATER STREET EXT.
PO BOX 100
JOHNSONBURGH, PA 15845
(814) 965-2532
ASSOCIATED FAMILY SERVICES
213 CENTER STREET
MEADVILLE, PA 16335
(814) 337-8457
NEW KENSINGTON C.D.C.
2513-15 FRANKFORD AVENUE
PHILADELPHIA, PA 19125
(215) 427-0350
TABOR COMMUNITY SERVICES
439 EAST KING STREET
LANCASTER, PA 17602
(717) 397-5182
BOOKER T. WASHINGTON CENTER
1720 HOLLAND STREET
ERIE, PA 16503
(814) 453-5744
URBAN LEAGUE OF
METROPOLITAN HARRISBURG
25 NORTH FRONT STREET
HARRISBURG, PA 17101
(717) 234-3253
HOUSING OPPORTUNITIES, INC
133 SEVENTH AVENUE
PO BOX 9
MCKEESPORT, PA 15132
(412) 664-1590
LAWRENCE COUNTY SOCSAL SERVICES,INC.
33-39 SOUTH JEFFERSON STREET
NEW CASTLE, PA 16103
(412) 658-7258
PHILADELPHIA COUNCIL FOR
COMMUNITY ADVANCEMENT
100 NORTH 17TH STREET - SUITE 600
PHILADELPHIA, PA 19103
(215) 567-7803
GE CaGFta!
GE Caoiro! Morrgace Services. lc:.
HUD APPROVED COUNSELING AGENCIES
PENNSYLVANIA (Cont)
TENANTS' ACTION GROUP CENTER FOR INDEPENDENT LIVING SW PA
OF PHILADELPHIA 7110 PENN AVENUE
2X SOUTH 12TH STREET - 12TH FLOOR PITTSBURGH, PA 25208
PHILDELPHIA, PA 19107 (412) 371-7700
(215) 575-0700
TREHAD CENTER OF NE PENNSYLVANIA HOUSING ASSOCIATION INFORMATION PROGRAM
7 LAKE AVENUE 1314 CHESTNUT STREET - SUITE 900
MONTROSE, PA 18801 PHILADELPHIA, PA 19107
(717) 278-3338 (215) 545-6010
MORTGAGORS COUNSELED AT
658-60 NORTH WATTS STREET,
PHILADELPHIA, PA 19123
NORTHWEST COUNSELING SERVICE
5001 NORTH BROAD STREET
PHILADELPHIA, PA 19141
(215) 549-2344
PHILADELPHIA HOUSING
DEVELOPMENT CORPORTATION
1234 MARKET STREET - 10TH FLOOR
PHILADELPHIA, PA 19107
(215) 448-3137 OR (215) 448-3132
URBAN LEAGUE OF PHILADELPHIA
4601 MARKET STREET
PHILADELPHIA, PA 19139
(215) 476-4040
ELDER-ADO, INC
320 BROWNSVILLE ROAD
PITTSBURGH, PA 15210
(412) 381-6900
ECONOMIC OPPORTUNITY CABINET
118 EAST NORWEGIAN STREET
POTTSVILLE, PA 17901-2921
(717) 622-1995
TABLELAND SERVICES, INC.
131 NORTH CENTER AVENUE
PO BOX 756
SOMERSET, PA 15501
(814)445-9628 OR (814) 445-0148
CONSUMER CREDIT COUNSELING
OF WESTERN PENNSYLVANIA
309 SMITHFIELD STREET - SUITE 2000
PITTSBURGH, PA 15222
(412) 471-7584
HILL COMMUNITY DEVELOPMENT CORPORTATION
2015-2017 CENTRE AVENUE
PITTSBURGH, PA 15219
(412) 765-1320
MERCER COUNTY
C014TUNITY ACTION AGENCY
309 OHIO STREET
SHARON, PA 16146
(412) 342-6222
WARREN FOREST COUNTY E.O.C.
1209 PENNSYLVAIA AVENUE WEST
PO BOX 547
WARREN, PA 16365
(814) 726-2400
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HUD APPROVED COUNSELING AGENCIES
PENNSYLVANIA(Cont)
GARFIELD JUBLIEE ASSOCIATION, INC
5138 PENN AVENUE
PITTSBURGH, PA 15224
(412) 665-5200
URBAN LEAGUE OF PITTSBURGH
ONE SMITHFIELD STREET
PITTSBURGH, PA 15222
(412) 261-1130
BERKS COMMUNITY ACTION AGENCY
BUDGET COUNSELING CENTER
247 NORTH FIFTH STREET
READING, PA 19601
(215) 375-7866
FAYETTE COUNTY
COMMUNITY ACTION AGENCY
137 NORTH BEESON AVENUE
UNIONTOWN, PA 15401
(412) 437-6050
WASHINGTON-GREENE
COMMUNITY ACTION CORPORATION
315 EAST HALLAM AVENUE
WASHINGTON, PA 15301
(412) 225-9550
HOUSING COUNCIL OF YORK
116 NORTH GEORGE STREET
YORK, PA 17401
(717) 854-1541
COMMISSION OF ECONOMIC
OPPORTUNITY OF LUZERNE COUNTY
122-213 SOUTH MAIN STREET
WILKES-BARRE, PA 18701
(717) 826-0510
SHENANGO VALLEY URBAN LEAGUE
39 CHESTNUT STREET
SHARON, PA 16146
(412) 981-5310
TRI-COUNTY PARTNERSHIP FOR
INDEPENDENT LIVING
69 EAST BEAU STREET
WASHINGTON, PA 15301
(412) 223-5115
CONSUMER CREDIT COUNSELING
SERVICE OF LEHIGH VALLEY
3671 CRESCENT COURT EAST
WHITEHALL, PA 18052
(215) 821-4011
WASHINGTON-GREENE
COMMUNITY ACTON CORPORATION
22 WEST HIGH STREET
WAYNESBURG, PA 15370
(412) 852-2893
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DDDDEMSPA91_NOR0106 ACT 91 NOTICE
TAKE ACTION TO SAVE YOUR HOME FROM FORECLOSURE
The Commonwealth of Pennsylvania's Homeowners' Emergency Mortgage
Assistance program may be able to help you. Read the following notice to
find out how the program works.
If you need more information, call the Pennsylvania Housing Finance
Agency at 1-800-342-2397.
La Notification en adjunto es de suma importancia, pues afecta su
derecho a continuar viviendo en su casa. Si no comprende el contenido de
esta notification obtenga una traduccion immediatamente llamando esta
agencia (Pennsylvania Housing Finance Agency) sin cargos al numero
mencionado arriba. Puedes ser elegible para un prestamo por el programa
llamado "Homeowners' Emergency Mortgage Assistance Program" al cual puede
salvar su casa de la perdida del derecho a redimir su hipoteca.
ACT 91 NOTICE
IMPORTANT: NOTICE OF HOMEOWNERS'
EMERGENCY MORTGAGE ASSISTANCE PROGRAM
PLEASE READ THIS NOTICE.
YOU MAY BE ELIGIBLE FOR FINANCIAL
ASSISTANCE WHICH CAN SAVE YOUR HOME FROM
FORECLOSURE AND HELP YOU MAKE FUTURE MORTGAGE PAYMENTS
May 29, 1999
RE: G.E. CAPITAL MORTGAGE SERVICES, INC.
Property Address: 334 LOWTHER STREET, LEMOYNE PA 17043
Loan # 10339133
TO: KATHRYN M VOLOVSKI
334 LOWTHER ST
LEMOYNE, PA 17043
FROM: G.E. Capital Mortgage Services
You may be eligible for financial assistance that will prevent foreclosure
on your mortgage if you comply with the provisions of the Homeowners'
Emergency Mortgage Assistance Act of 1983 (the It ha)s been may
caused by . You be
for emergency temporary assistance if you default has
circumstances beyond your control, you have a reasonable prospect of
resuming your mortgage payments, and if you meet other eligibility
requirements established by the Pennsylvania Housing Finance Agency.
Please read all of this Notice. It contains an explanation of your rights.
Gc Laoiiar
G: caciral Manoaoe Serveas, vr.:.
Under the Act, you are entitled to a temporary stay of foreclosure on your
mortgage for thirty (30) days from the date of this Notice. During that
time you must arrange and attend a "face-to-face" meeting with a
representative of this lender, or with a designated consumer credit
counseling agency. The purpose of this meeting is to attempt to work out a
repayment plan, or to otherwise settle your delinquency. This meeting must
occur in the next thirty (30) days.
If you attend a face-to-face meeting with this lender, or with a consumer
credit counseling agency identified in this notice, no further proceeding
in mortgage foreclosure may take place for thirty (30) days after the date
of this meeting. The name, address, and telephone number of our
representative is:
G.E. Capital Mortgage Services
625 Maryville Centre Drive
St. Louis, MO 63141
The names and addresses of designated consumer credit counseling agencies
are shown on the attached sheet. It is only necessary to schedule one
face-to-face meeting. You should advise this lender immediately of your
intentions.
Your mortgage is in default because you have failed to pay promptly
installments of principal and interest, as required for at least sixty (60)
days. The total amount of the delinquency is $1,455.96. That sum includes
the following: payments due 04/01/99 through the first of this month and
late charges.
Your mortgage is also in default for the following reason:
ILLNESS OF PRINCIPAL MORTGAGOR.
If you have tried and are unable to resolve this problem at or after our
face-to-face meeting, you have the right to apply for financial assistance
from the Homeowners' Emergency Mortgage Assistance Fund. In order to do
this, you must fill out, sign and file a completed Homeowners' Emergency
Assistance Application with one of the designated consumer credit
counseling agencies listed on the attachment. An application for
assistance may only be obtained from a consumer credit counseling agency.
The consumer credit counseling agency will assist you in filling out your
application and will submit your completed application to the Pennsylvania
Housing Finance Agency. Your application must be filed or postmarked,
within thirty (30) days of your face-to-face meeting.
It is extremely important that you file your application promptly. If you
do not do so, or if you do not follow other time periods set forth in this
letter, foreclosure may proceed against your home immediately.
Available funds for emergency mortgage assistance are very limited. They
will be disbursed by the Agency under the eligibility criteria established
by the ACT.
It is extremely important that your application is accurate and complete in
every respect. The Pennsylvania Housing Finance Agency has sixty (60) days
i
GE Capital
of Capitsl mortgage services. Inc.
n Us•. J U?,v: Sig fK:: /.': G':.'.? ..',tr y^r L.=Orx:a.
to make a decision after it receives your application. During that
additional time, no foreclosure proceedings will be pursued against you if
you have met the time requirements set forth above. You will be notified
directly by the Agency of its decision on your application.
QE CeuRef
Gf Capital Manaa?e : ernes,. A.a.
The Pennsylvania Housing Finance Agency is located at 2101 North Front
Street, Post Office Box 8029, Harrisburg, Pennsylvania 17105. Telephone
No. (737) 780-3800 or 1-800-342-2397 (toll free number). Persons with
impaired hearing can call 1-800-342-2397.
In addition, you may receive another notice from this lender under Act 6 of
1974. That notice is called a "Notice of Intention to Foreclose." You must
read both notices, since they both explain rights that you now have under
Pennsylvania law. However, if you choose to exercise your rights described
in this notice, you cannot foreclosed upon while you are receiving that
assistance.
Sincerely, 10339133
Loan Counselor, Collection Department
1 (800) 344-6723
The following disclosure is required by applicable federal and state law
for certain loans that we service: This communication is from a debt
collector and is an attempt to collect a debt; any information obtained
will be used for that purpose.
r
GE Lapital
GE Capital Mnttgage services, In..
F LI'l: of HUD APPROVED COUNSELING AGENCIES
PENNSYLVANIA
DELAWARE COUNTY H.O.P.E. BAYFRONT NATO, INC.
PHILADELPHIA COUNCIL FOR COMMUNITY 312 CHESTNUT STREET
ADVANCEMENT ERIE, PA 16507
511 WELSH STREET (814) 459-2761
CHESTER, PA 19013
(21S) 872 3500
COMMUNITY RESOURCES FOR INDEP
2222 FILMORE AVENUE
ERIE, PA 16506
(814) 838-7222
HARRISBURG FAIR HOUSING COUNCIL
1228 BAILEY STREET
HARRISBURG, PA 17103
(717) 238-9540
INDIANA COUNTY COMMUNITY
ACTION PROGRAM INC.
827 WATER STREET
PO BOX 187
INDIANA, PA 15701
(412 ) 465-2657
NORTHERN TIER COMMUNITY
ACTION CORPORATION
135 WEST 4TH STREET
EMPORIA, PA 15834
(814) 486-1161
GREATER ERIE COMMUNITY
ACTION AGENCY
18 WEST 9TH STREET
ERIE, PA 16501
(814) 459-4581
ELK COUNTY HOUSING AUTHORITY
424 WATER STREET EXT.
PO BOX 100
JOHNSONBURGH, PA 15845
(814) 965-2532
ASSOCIATED FAMILY SERVICES
213 CENTER STREET
MEADVILLE, PA 16335
(814) 337-8457
NEW KENSINGTON C.D.C.
2513-15 FRANKFORD AVENUE
PHILADELPHIA, PA 19125
(215) 427-0350
TABOR COMMUNITY SERVICES
439 EAST KING STREET
LANCASTER, PA 17602
(717) 397-5182
BOOKER T. WASHINGTON CENTER
1720 HOLLAND STREET
ERIE, PA 16503
(814) 453-5744
URBAN LEAGUE OF
METROPOLITAN HARRISBURG
25 NORTH FRONT STREET
HARRISBURG, PA 17101
(717) 234-3253
HOUSING OPPORTUNITIES, INC
133 SEVENTH AVENUE
PO BOX 9
MCKEESPORT, PA 15132
(412) 664-1590
LAWRENCE COUNTY SOCIAL SERVICES, INC.
33-39 SOUTH JEFFERSON STREET
NEW CASTLE, PA 16103
(412) 658-7258
PHILADELPHIA COUNCIL FOR
COMMUNITY ADVANCEMENT
100 NORTH 17TH STREET - SUITE 600
PHILADELPHIA, PA 19103
(215) 567-7803
95 Capita!
GE Caolfal Manoapa Scrncas, ma.
HUD APPROVED COUNSELING AGENCIES
PENNSYLVANIA(COnt)
TENANTS' ACTION GROUP CENTER FOR INDEPENDENT LIVING SW PA
OF PHILADELPHIA 7110 PENN AVENUE
21 SOUTH 12TH STREET - 12TH FLOOR PITTSBURGH, PA 15208
PHILDELPHIA, PA 19107 (412) 371-7700
(215) 575-0700
TREHAD CENTER OF NE PENNSYLVANIA
7 LAKE AVENUE
MONTROSE, PA 18801
(717) 278-3338
HOUSING ASSOCIATION INFORMATION PROGRAM
1314 CHESTNUT STREET - SUITE 900
PHILADELPHIA, PA 19107
(215) 545-6010
MORTGAGORS COUNSELED AT
658-60 NORTH WATTS STREET,
PHILADELPHIA, PA 19123
NORTHWEST COUNSELING SERVICE
5001 NORTH BROAD STREET
PHILADELPHIA, PA 19141
(215) 549-2344
URBAN LEAGUE OF PHILADELPHIA
4601 MARKET STREET
PHILADELPHIA, PA 19139
(215) 476-4040
ELDER-ADO, INC
320 BROWNSVILLE ROAD
PITTSBURGH, PA 15210
(412) 381-6900
ECONOMIC OPPORTUNITY CABINET
118 EAST NORWEGIAN STREET
POTTSVILLE, PA 17901-2921
(717) 622-1995
TABLELAND SERVICES, INC.
131 NORTH CENTER AVENUE
PO BOX 756
SOMERSET, PA 15501
(814)445-9628 OR (814) 445-0148
PHILADELPHIA HOUSING
DEVELOPMENT CORPORTATION
1234 MARKET STREET - 10TH FLOOR
PHILADELPHIA, PA 19107
(215) 448-3137 OR (215) 448-3132
CONSUMER CREDIT COUNSELING
OF WESTERN PENNSYLVANIA
309 SMITHFIELD STREET - SUITE 2000
PITTSBURGH, PA 15222
(412) 471-7584
HILL COMMUNITY DEVELOPMENT CORPORTATION
2015-2017 CENTRE AVENUE
PITTSBURGH, PA 15219
(412) 765-1320
MERCER COUNTY
COMMUNITY ACTION AGENCY
309 OHIO STREET
SHARON, PA 16146
(412) 342-6222
WARREN FOREST COUNTY E.O.C.
1209 PENNSYLVAIA AVENUE WEST
PO BOX 547
WARREN, PA 16365
(814) 726-2400
GE Capital
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A 6ln 5'a&;elai E:c [; r:[(..... I riroranon
-tESQ n.;Par..:; 5::: 5. •.,.. ,... :. i5 92407
HUD APPROVED COUNSELING AGENCIES
PENNSYLVANIA(COnt)
GARFIELD JUBLIEE ASSOCIATION, INC
5138 PENN AVENUE
PITTSBURGH, PA 15224
(412) 665-5200
URBAN LEAGUE OF PITTSBURGH
ONE SMITHFIELD STREET
PITTSBURGH, PA 25222
(412) 261-1130
BERKS COMMUNITY ACTION AGENCY
BUDGET COUNSELING CENTER
247 NORTH FIFTH STREET
READING, PA 19601
(215) 375-7tf66
FAYETTE COUNTY
COMMUNITY ACTION AGENCY
137 NORTH BEESON AVENUE
UNIONTOWN, PA 15401
(412) 437-6050
WASHINGTON-GREENE
COMMUNITY ACTION CORPORATION
315 EAST HALLAM AVENUE
WASHINGTON, PA 15301
(412) 225-9550
HOUSING COUNCIL OF YORK
116 NORTH GEORGE STREET
YORK, PA 17401
(717) 854-1541
COMMISSION OF ECONOMIC
OPPORTUNITY OF LUZERNE COUNTY
122-213 SOUTH MAIN STREET
WILKES-BARRE, PA 18701
(717) 826-0510
SHENANGO VALLEY URBAN LEAGUE
39 CHESTNUT STREET
SHARON, PA 16146
(412) 981-5310
TRI-COUNTY PARTNERSHIP FOR
INDEPENDENT LIVING
69 EAST BEAU STREET
WASHINGTON, PA 15301
(412) 223-5115
CONSUMER CREDIT COUNSELING
SERVICE OF LEHIGH VALLEY
3671 CRESCENT COURT EAST
WHITEHALL, PA 18052
(215) 821-4011
WASHINGTON-GREENE
COMMUNITY ACTON CORPORATION
22 WEST HIGH STREET
WAYNESBURG, PA 15370
(412) 852-2893
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GE CAPITAL MORTGAGE : IN THE COURT OF COMMON PLEAS OF
SERVICES, INC. : CUMBERLAND COUNTY, PENNSYLVANIA
V.
TERRY L. VOLOVSKI NO. 99-7211 CIVIL TERM
KATHRYN M. VOLOVSKI
(Mortgagors and Real Owners)
AND NOW, this I P day of MARCII, 2000, Plaintiffs Motion for Substitute
Service is DENIED. We will reconsider the Motion if it is accompanied by an affidavit
setting forth the nature and extent of the investigation made to determine the defendants'
whereabouts as required by Pa. R.C.P. 430(a).
By the
Kristina G. Murtha, Esquire
For the Plaintiff
Terry Volovski
Kathryn Volovski
334 Lowther Street
Lemoyne, Pa. 17043
:sld
E. Guido, J.
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MAP - 8 2001 ?
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GOLDBECK MCCAFFSRTY & MCP.BEVER
JOSEPH A. GOLDBECK, JR.
Attorney I.D.#16132
Suite 500-The Bourse Building
111 S. Independence Mall East
Philadelphia, PA 19106
215-627-1322
BY: KRISTINA G. MURTHA, ESQUIRE
Attorney I.D. #61858
Attorney for Plaintiff
GE CAPITAL MORTGAGE SERVS. INC.
4680 Hallmark Parkway
San Bernardino, CA 92407
Vs.
IN THE COURT OF COMMON PLEAS
OF CUMBERLAND COUNTY
No. 99-7211
TERRY L. VOLOVSKI
KATHRYN M. VOLOVSKI
(Mortgagors and Real Owners)
334 Lowther Street
Lemoyne, PA 17043
AND NOW, this
day of
2000,
upon consideration of the Plaintiff's Motion for Substituted
Service under Pa.R.C.P. 430(a) and it appearing to the Court that
Plaintiff's good faith efforts to ascertain the present whereabouts
of Defendants has been unsuccessful, it is,
ORDERED and DECREED:
that Plaintiff's Motion is granted and the Sheriff and/or
Plaintiff is directed to Serve the Complaint in Mortgage
Foreclosure upon Defendants by posting a copy of the Complaint upon
the premises 334 Lowther Street, Lemoyne, PA 17043, and Plaintiff
is directed to serve the Complaint by certified and regular mail to
the Defendants' last known address at 334 Lowther Street, Lemoyne,
PA 17043, and that all further service of legal papers, including
but not limited to motions, petitions and rules be made by
certified and regular mail to Defendants' last known address and
that Notice of Sheriff Sale pursuant to Pennsylvania Rule of Civil
Procedure 3129 may be made upon Defendants by sending copies of
same to Defendants' last known address by certified and regular
mail and by posting the premises.
BY THE COURT:
J.
i
GOLDBECK MCCAFFERTY & MCKEEVER
JOSEPH A. GOLDBECK, JR.
Attorney I.D.#16132
Suite 500-The Bourse Building
111 S. Independence Mall East
Philadelphia, PA 19106
215-627-1322
BY: KRISTINA G. MURTHA, ESQUIRE
Attorney I.D. d#61858
Attorney for Plaintiff
GB CAPITAL MORTGAGE SERVS. INC
4680 Hallmark Parkway
San Bernardino, CA 92407
IN THE COURT OF COMMON PLEAS
OF CUMBERLAND COUNTY
Va.
TERRY L. VOLOVSKI
KATHRYN M. VOLOVSKI
(Mortgagors and Real Owners)
334 Lowther Street
Lemoyne, PA 17043
No. 99-7211
THIS LAW FIRM IS A DEBT COLLECTOR AND WE ARE ATTE10TING TO
COLLECT A DEBT OWED TO OUR CLIENT. ANY INFORMATION OBTASNED FROM
YOU WILL BE USED FOR THE PURPOSE OF COLLECTING THE DEBT.
MOTION FOR SUBSTITUTED SERVICE
UNDER PA.R.C.P. 430(a)
Plaintiff, by and through its attorney, Kristina G.
Murtha, Esquire, in support of its Motion for Substituted Service,
represents as follows:
1. Plaintiff is the holder of a first mortgage upon the
premises 334 Lowther Street, Lemoyne, PA 17043, hereinafter, the
"mortgaged premises".
2. Defendants, TERRY L. VOLOVSKI AND KATHRYN M. VOLOVSKI,
are the mortgagors and real owners of the mortgaged premises.
3. The last known address of Defendants' is 334 Lowther
Street, Lemoyne, PA 17043 as set forth in Paragraph 2 of the Complaint.
4. The Sheriff has been unable to effect service of the
Complaint upon Defendants at their last known address after
numerous attempts.
s. The following investigation was conducted in a good faith
attempt to ascertain the whereabouts of Defendants.
WHg"FORE, Plaintiff prays that the Court enter the
attached order allowing Plaintiff to serve the complaint upon
Defendants by posting the premises and certified and regular mail
to the Defendants' last known address.
ESQIIIRS
BY: RRISTINA ,
GOLDBECEC MCCAFFERTY & MCKEEVER
JOSEPH A. GOLDBECK, JR.
Attorney I.D.#16132
Suite 500-The Bourse Building
111 S. 31ndependence Mall East
Philadelphia, PA 19106
215-627-1322
BY: KRISTINA G. MURTHA, ESQUIRE
Attorney I.D. #61858
Attorney for Plaintiff
GE CAPITAL MORTGAGE SERVS. INC.
4680 Hallmark Parkway
San Bernardino, CA 92407
: IN TER COURT OF COMMON PLEAS
OF CUMBERLAND COUNTY
No. 99-7211
VS.
TERRY L. VOLAVSKI
KATHRYN r4. VOLOVSKI
(Mortgagors and Real Owners)
334 Lowther Street
Lemoyne, PA 17043
VERIFICATION
I, IRRISTINA G. MURTHA, ESQUIRE, Attorney for Petitioner do
hereby verify that the facts set forth in the foregoing Motion for
Substituted Service 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.
4904 relating to unsworn falsification to authorities.
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GOLDBECK MCCAFFERTY & MCKEEVER
BY: Joseph A. Goldbeck, Jr.
Attorney I.D.416132
Suite 500 - The Bourse Bldg.
111 S. Independence Mall East
Philadelphia, PA 19106
215-627-1322
Attorney for Plaintiff
GE CAPITAL MORTGAGE SERVS.
4680 Hallmark Parkway
San Bernardino, CA 92407
Plaintiff
Vs.
INC. IN THE COURT OF COMMON PLEAS
OF CUMBERLAND COUNTY
TERRY L. VOLOVSKI AND
FATHRYN M. VOLOVSKI
(Mortgagor (s) and Real Owner(s))
334 Lowther Street
Lemoyne, PA 17043
Defendant(s)
CIVIL ACTION - LAW
:ACTION OF MORTGAGE FORECLOSURE
Term
CIV;L ACTION MORTGAGE
FORECLOSURE
7x l
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.
NOT I C E
You have been sued in court. If you wish to defend against the clalma set forth In the following pages,
you must take action within twenty (20) days after the Complaint and notice are served, by entering a written
appearance personally or by attorney and filing in writing with the court your defenses or objections to the
claims set forth against you. You are warned that if you fail to do so the case may proceed without you and a
judgment may be entered against you by the Court without further notice for any money claimed in the Complaint
or for any other claim or relief requested by the Plaintiff . You may lose money or property or other rights
OR CANNOT AFFORD ONE,
important to you.
WHERE YOU DO NOT
FIND ONCE. IF
CAN GETV EGAD HELP.
ET FORTH BELOW LAWYER AT
TELEPHONE THE PAPER TO YOUR
GO TO OR YOU
Cumberland County Bar Association
2 Liberty Avenue, Carlisle, PA
(800) 990-9108
Legal Services Inc.
8 Irvine Row, Carlisle, PA 17013
(717) 243-9400
A V I S O
LE HAN DEMANDADO A USTED EN LA CORTE. SI DESEA DEFENDERSE CONTRA LAS OUEJAS PERESENTADAS, ES
AFISOLUTAMENTE NECESSARIO UUE USTED RESPONDA DENTRO DE 20 DIAS DESPUES DE SER SERVIDO CON ESTA DEMANDA Y AVISO.
PARA DEFENDERSE ES NECESSARIO OUR LISTED, 0 SU AROGADO, REGISTRE C04 LA CORTE EN FORMA ESCRITA, EL PUNTO BE VISTA
DE USTED Y CUALOUIER OB.TECCION CONTRA LAS OUWAS EN ESTA DEMANDA.
RECUERDE: SI USTED NO REPONDE A ESTA DEMANDA, BE PUEDE PROSEGUIR CON EL PROCESO SIN SO PARTICIPACION.
LAS PROVIS ONES DE ESTA EDEHMANDA. T FOR RAEON OR ESAIO DECISION, DES POSSIBLE OUR USTOEDRPUEDA PERDER DINERO, PROPIEDAD
U BIROS DERECHOS IMPORTANTES.
LLEVE ESTA DEMANDA A UN ABOGADO IMMEDIATAMENTE.
SI NO CONOCE A UN ABOGADO, LLAME AL "LAWYER REFERENCE SERVICE" (SERVICIO DE REFERENCIA DE ABOGADOS),
2 15-238-6300.
Cumberland County Bar Association
2 Liberty Avenue, Carlisle, PA
(800) 990-9108
Legal Services Inc.
8 Irvine Row, Carlisle, PA 17013
(717) 243-9400
COMPLAINT IN MORTGAGE FORECLOSURE
1. Plaintiff is GE CAPITAL MORTGAGE SERVS. INC., 4680
Hallmark Parkway, San Bernardino, CA 92407.
2. The name(s) and address(es) of the Defendant(s) is/are
TERRY L. VOLOVSKI, 334 Lowther Street, Lemoyne, PA 17043 and
KATHRYN M. VOLOVSKI, 334 Lowther Street, Lemoyne, PA 17043, who
is/are the mortgagor(s) and real owner(s) of the mortgaged property
hereinafter described.
3. On May 24, 1993, mortgagor(s) made, executed and
delivered a mortgage upon the premises hereinafter described to
BANK UNITED OF TEXAS FSB, which mortgage is recorded in the Office
of the Recorder of Deeds of Cumberland County in Mortgage Book
1139, Page 750. By Assignment of mortgage dated May 24, 1993, the
mortgage was assigned to Plaintiff, which Assignment is recorded in
Assignment of Mortgage Book No. 472, Page 351. 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 April 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.
The following amounts are due on the mortgage:
Principal Balance $ 73,770.61
Interest from 3/ 1/99
through 11/30/99 at 8.000% 4,430.58
Per diem interest rate at $16.17
Attorney's Fee at 5%
of Principal Balance 3,688.53
Late Charges 4/ 1/99-11/30/99 193.68
Monthly late charge amount at $24.21
Costs of suit and Title Search 560.00
$ 82,643.40
Escrow Balance Deficit 332.42
Monthly Escrow amount $98.28
$ -82,975.82
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. A Notice of Homeowners' Emergency Mortgage Assistance Act
of 1983 has been sent to the Defendant(s) by regular mail in
accordance with Act 91 of 1983 of the Commonwealth of Pennsylvania
on the date set forth in the true and correct copy of such notice
attached hereto as Exhibit "A". The date of the postmark on the
Notice was the same as the date of the Notice. The Defendant(s)
has/have not had the required face to face meeting within the
required time and Plaintiff has no knowledge of any such meeting
being requested by the Defendant(s) through the Plaintiff, the
Pennsylvania Housing Finance Agency, or any appropriate Consumer
Credit Counseling Agency.
WHEREFORE, Plaintiff demands judgment in mortgage foreclosure
the sum of $82,975.82, together with interest at the rate of
$16.17, 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: 1
GOLDBECK FE McKEEVER
BY: Joseph A. Goldbec , jr., Esq.
Attorney for Plaintif
1 "
ss SEP 08 '99 03:11PM
VBRIF'ICATIODI
P.2/2
_ , 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 IS Pa. C.S. 4904 relating to
unworn falsification to authorities.
Date:
cZl? 4/C?i
File Number: 1821
SCHEDULE • CONTINUED
end THATngCERTAIN tract
Lemoyne inland then CountyiofsCumberland andlying
in Tthe Borough rofparcel
Commonwealth of Pennsylvania, more particularly described as follows:
BEGINNING at a point on the south (southeast) side of Lowther Street
at the western line of Lot No. 21 on the Plan of Lower Walton laid
out by the Trustees of James McCormick Estate dated October It 1915r
and recorded in the office of the Recorder of Deeds of Cumberland County
in Plan Book No. 1, page No. 104, said point being 317.8 feet west
of the southwest corner of Lowther and Third Street (formerly Rossmoyne
Street) as shown on Said Plan; thence southeastwardly by line of said
Lot No. 21 now or late of Raymond Minnick 217.8 feat to the line of
Lot No. 16; thence southwestwardly by line of said Lot No. 16 on said
Plan 50 feet to a point; thence northwestwardly by a line parallel
to the line dividing Lots No. 21 and 22 as shown on said Plan a distance
of 217.8 feet to the southern aide of Lowther Street; thence in a
northeastwardly direction along the southern side of said Lowther Street
50 feet to a point, the palce of BEGINNING.
SAID lot fronting 50 feet on the southern side of Lowther Street and
extending back an even width 217.8 feet and being the eastern 50 feet
of Lot No. 22 on Plan of Lower Walton.
HAVING thereon erected a one and one-half story frame dwelling house
known and numbered as 334 Lowther STreet.
BEING the same premises which Keith D. Kneller by Deed dated April 6,
1988 and recorded in the office of the Recorder of Deeds in and for
Cumberland County, Pennsylvania, in Deed Book H. Volume 33, page 874,
granted and conveyed unto Michael J. Reach and Sherri L. Reach, his
wife, Grantors herein.
_NOR0106
ACT 91 NOTICE
TO SAVE YOUR HOME FROM FORECLOSURE CE Capita!
??w==??ra of rennsylvania-s Homeowners' Emergency Mortgage
Assistance Program may be able to hel§E?adaimoMead'fthes.following notice to
find out how the program works. .".".:??c:,.:'_r::":;.,.; -r•„ _.y,,,,?;,,,
If you need more information, call the Pennsylvania Housing Finance
Agency at 1-800-342-2397.
La Notification en adjunto es de suma importanci.a, pues afecta su
derecho a continuar viviendo en su casa. Si no comprende el contenido de
esta notification obtenga una traduccion immediatamente llamando esta
agencia (Pennsylvania Housing Finance Agency) sin cargos al numero
mencionado arriba. Puedes ser elegible para un prestamo por el programa
llamado "Homeowners' Emergency Mortgage Assistance Program" al coal puede
salvar su casa de la perdida del derecho a redimir su hipoteca.
ACT 91 NOTICE
IMPORTANT: NOTICE OF HOMEOWNERS'
EMERGENCY MORTGAGE ASSISTANCE PROGRAM
PLEASE READ THIS NOTICE.
YOU MAY BE ELIGIBLE FOR FINANCIAL
ASSISTANCE WHICH CAN SAVE YOUR HOME FROM
FORECLOSURE AND HELP YOU MAKE FUTURE MORTGAGE PAYMENTS
4
May 29, 1999
RE: G.E. CAPITAL MORTGAGE SERVICES, INC.
Property Address: 334 LOWTHER STREET, LEMOYNE PA 17043
Loan # 10339133
TO: TERRY L VOLOVSKI
334 LOWTHER ST
LEMOYNE, PA 17043
FROM: G.E. Capital Mortgage Services
You may be eligible for financial assistance that will prevent foreclosure
on your mortgage if you comply with the provisions of the Homeowners'
Emergency Mortgage Assistance Act of 1983 (the "ACT"). You may be eligible
for emergency temporary assistance if you default has been caused by
circumstances beyond your control, you have a reasonable prospect of
resuming your mortgage payments, and if you meet other eligibility
requirements established by the Pennsylvania Housing Finance Agency.
Please read all of this Notice. It contains an explanation of your rights.
Under the Act, you arP entitled to a temporary stay of foreclosure on your
mMage for thirty % , days from the date of this Nc _e. During that
tit you must arrange and attend a "face-to-face" meeting with auc OItB(
representative of this lender, or with a designated consumer credit
counseling agency. The purpose of this meeting is to attempt to war out a
repayment plan, or to otherwise settle your delinquency. This meeting must
occur in the next thirty (30) days. GE Canilal MaflnaCn Servmes. In:.
^J _L. ,, _ Gc?c?rarc°
If you attend a face-to-face meeting k th?this lender] . further proceeding
credit counseling agency identified in this notice,
in mortgage foreclosure may take place for thirone(30)days after the date
number of our
of this meeting. The name, address, and
representative is:
G.E. Capital Mortgage Services
625 Maryville Centre Drive
St. Louis, MO 63141
The names and addresses of designated consumer credit counseling agencies
are shown on the attached sheet. It is only necessary to schedule one
face-to-face meeting. You should advise this lender immediately of your
intentions.
Your mortgage is in default because you have failed to pay promptly
installments of principal and interest, as required for at least isixty nclude(60)
days. The total amount of the delinquency is $1,455.95. That sum s
the following: payments due 04/01/99 through the first of this month and
late charges.
Your mortgage is also in default for the following reason:
ILLNESS OF PRINCIPAL MORTGAGOR.
If you have tried and are unable to resolve this problem at or after our
face-to-face meeting, you have the right to apply for financial assistance
from the Homeowners- Emergency Mortgage Assistance Fund. In order to do
this, you must fill out, sign and file a completed Homeowners- Emergency
Assistance Application with one of the designated consumer credit
counseling agencies listed on the attachment. An application
assistance may only be obtained from a consumer credit counseling agency.
The consumer credit counseling agency will assist you in filling out your
application and will submit your completed application to the Pennsylvania
Housing Finance Agency. Your application must be filed or postmarked,
within thirty (30) days of your face-to-face meeting.
It is extremely important that you file your application promptly. If you
do not do so, or if you do not follow other time periods set forth in this
letter, foreclosure may proceed against your home immediately.
Available funds for emergency mortgage assistance are very limited. They
will be disbursed by the Agency under the eligibility criteria established
by the ACT.
It is extremely important that your application is accurate and complete in
every respect. The Pennsylvania Housing Finance Agency has sixty (60) days
to make a decision after it receives your application. During that
( additional time, no foreclosure proceedings will be pursued against you if
you have met the time requirements set forth above. You will be notified
directly by the Agency of its decision on your application.
The-.Pennsylvania Housing Finance Agency is located at 2101 North Front
S , Post Office E 8029, Harrisburg, Pennsylvani: 7105. Telephone
N17) 780-3800 or 1-800-342-2397 (toll free number). Persons with
impaired hearing can call 1-800-342-2397. GE
CaOltal
In addition, you may receive another notice from this lender under Act 6 of
1974. That notice is called a "Notice CbElplritntitiorrritos,Foreclose . " You must
read both notices, since they both explain_rights.that'you:now -h•,ave under
Pennsylvania law. However, if you choose`to,ezercise-your rights described
in this notice, you cannot foreclosed upon while you are receiving that
assistance.
Sincerely, 10339133
Loan Counselor, Collection Department
1 (800) 344-6723
The following disclosure is required by applicable federal and state law
for certain loans that we service: This communication is from a debt
collector and is an attempt to collect a debt; any information obtained
will be used for that purpose.
GE Capital
GE Caplt it Moripaae Services. Inc.
A LY!:.' f; L^.9P'1' C'f °:.: ,,.+: f. ^.2 LOIppIJ1?C'
JftOr.JBnl.7". FJ:•.: J.]...-..?..... - ?•i ?: w?i
HUD APPROVED COUNSELING AGENCIES
PENNSYLVANIA
DELAWARE COUNTY H.O.P.E. BAYFRONT NATO, INC.
PHILADELPHIA COUNCIL FOR COMMUNITY 312 CHESTNUT STREET
ADVANCEMENT ERIE, PA 16507
511 WELSH STREET (814) 459-2761
CHESTER, PA 19013
(215) 872 3500
COMMUNITY RESOURCES FOR INDEP.
2222 FILMORE AVENUE
ERIE, PA 16506
(814) 838-7222
INDIANA COUNTY COMMUNITY
ACTION PROGRAM INC.
827 WATER STREET
PO BOX 187
INDIANA, PA 15701
(412) 465-2657
NORTHERN TIER COMMUNITY
ACTION CORPORATION
135 WEST 4TH STREET
EMPORIA, PA 15834
(814) 486-1161
GREATER ERIE COMMUNITY
ACTION AGENCY
18 WEST 9TH STREET
ERIE, PA 16501
(814) 459-4581
ELK COUNTY HOUSING AUTHORITY
424 WATER STREET EXT.
PO BOX 100
JOHNSONBURGH, PA 15845
(814) 965-2532
ASSOCIATED FAMILY SERVICES
213 CENTER STREET
MEADVILLE, PA 16335
(814) 337-8457
NEW KENSINGTON C.D.C.
2513-15 FRANKFORD AVENUE
PHILADELPHIA, PA 19125
(215) 427-0350
HARRISBURG FAIR HOUSING COUNCIL
1228 BAILEY STREET
HARRISBURG, PA 17103
(717) 238-9540
TABOR COMMUNITY SERVICES
439 EAST KING STREET
LANCASTER, PA 17602
(717) 397-5182
BOOKER. T. WASHINGTON CENTER
1720 HOLLAND STREET
ERIE, PA 16503
(814) 453-5744
URBAN LEAGUE OF
METROPOLITAN HARRISBURG
25 NORTH FRONT STREET
HARRISBURG, PA 17101
(717) 234-3253
HOUSING OPPORTUNITIES, INC
133 SEVENTH AVENUE
PO BOX 9
MCKEESPORT, PA 15132
(412) 564-1590
LAWRENCE COUNTY SOCIAL SERVICES,INC.
33-39 SOUTH JEFFERSON STREET
NEW CASTLE, PA 16103
(412) 658-7258 - _"
PHILADELPHIA COUNCIL FOR
COMMUNITY ADVANCEMENT
100 NORTH 17TH STREET - SUITE 600 --+
PHILADELPHIA, PA 19103
(215) 567-7803
,
i. Y
i
GE Capital
6I Caosfal Mortgage Services. Ir.:.
HUD APPROVED COUNSELING AGENCIES
PENNSYLVANIA(Cont)
TENANTS' ACTION GROUP CENTER FOR INDEPENDENT LIVING SW PA
OF PHILADELPHIA 7110 PENN AVENUE
21 SOUTH 12TH STREET - 12TH FLOOR PITTSBURGH, PA 15208
PHILDELPHIA, PA 19207 (412) 371 -7700
(215) 575-0700
TREHAD CENTER OF NE PENNSYLVANIA HOUSING ASSOCIATION INFORMATION PROGRAM
7 LAKE AVENUE 1314 CHESTNUT STREET - SUITE 900
MONTROSE, PA 18801 PHILADELPHIA, PA 19107
(717) 278-3338 (215) 545 -6010
MORTGAGORS COUNSELED AT
658-60 NORTH WATTS STREET,
PHILADELPHIA, PA 19123
NORTHWEST COUNSELING SERVICE
5001 NORTH BROAD STREET
PHILADELPHIA, PA 19141
(215) 549-2344
PHILADELPHIA HOUSING
DEVELOPMENT CORPORTATION
1234 MARKET STREET - 10TH FLOOR
PHILADELPHIA, PA 19107
(215) 448-3137 OR (215) 448-3132
URBAN LEAGUE OF PHILADELPHIA
4601 MARKET STREET
PHILADELPHIA, PA 19139
(215) 476-4040
ELDER-ADO, INC
320 BROWNSVILLE ROAD
PITTSBURGH, PA 15210
(412) 381-6900
ECONOMIC OPPORTUNITY CABINET
118 EAST NORWEGIAN STREET
POTTSVILLE, PA 17901-2921
(717) 622-1995
TABLELAND SERVICES, INC.
131 NORTH CENTER AVENUE
PO BOX 756
SOMERSET, PA 15501
(814)445-9628 OR (814) 445-0148
CONSUMER CREDIT COUNSELING
OF WESTERN PENNSYLVANIA
309 SMITHFIELD STREET - SUITE 2000
PITTSBURGH, PA 15222
(412) 471-7584
HILL COMMUNITY DEVELOPMENT CORPORTATION
2015-2017 CENTRE AVENUE
PITTSBURGH, PA 15219
(412) 765-1320
MERCER COUNTY
COMMUNITY ACTION AGENCY
309 OHIO STREET
SHARON, PA 16146
(412) 342 -6222
WARREN FOREST COUNTY E.O.C.
1209 PENNSYLVAIA AVENUE WEST
PO BOX 547
WARREN, PA 16365
(814) 726-2400
GE Capital
6E L'ooilal MOrraaoe services. Mc.
HUD APPROVED COUNSELING AGENCIES
PENNSYLVANIA (Cont)
GARFIELD JUBLIEE ASSOCIATION, INC
5138 PENN AVENUE
PITTSBURGH, PA 15224
(412) 665-5200
URBAN LEAGUE OF PITTSBURGH
ONE SMITHFIELD STREET
PITTSBURGH, PA 15222
(412) 261-1130
BERKS COMMUNITY ACTION AGENCY
BUDGET COUNSELING CENTER
247 NORTH FIFTH STREET
READING, PA 19601
(215) 375-7866
FAYETTE COUNTY
COMMUNITY ACTION AGENCY
137 NORTH BEESON AVENUE
UNIONTOWN, PA 15401
(412) 437-6050
WASHINGTON-GREENE
COMMUNITY ACTION CORPORATION
315 EAST HALLAM AVENUE
WASHINGTON, PA 15301
(412) 225-9550
HOUSING COUNCIL OF YORK
116 NORTH GEORGE STREET
YORK, PA 17401
(717) 854-1541
COMMISSION OF ECONOMIC
OPPORTUNITY OF LUEERNE COUNTY
122-213 SOUTH MAIN STREET
WILKES-BARRE, PA 18701
(717) 826-0510
SHENANGO VALLEY URBAN LEAGUE
39 CHESTNUT STREET
SHARON, PA 16146
(412) 981-5310
TRI-COUNTY PARTNERSHIP FOR
INDEPENDENT LIVING
69 EAST BEAU STREET
WASHINGTON, PA 15301
(412) 223-5115
CONSUMER CREDIT COUNSELING
SERVICE OF LEHIGH VALLEY
3671 CRESCENT COURT EAST
WHITEHALL, PA 18052
(215) 821-4011
WASHINGTON-GREENE
COMMUNITY ACTON CORPORATION
22 WEST HIGH STREET
WAYNESBURG, PA 15370
(412) 852-2893
,
GE Capital
GE Caaltal ManMaae Services. Inc.
..,':wand'
DDDDEMSPA91_NOR0106
ACT 91 NOTICE
TAKE ACTION TO SAVE YOUR HOME FROM FORECLOSURE
The Commonwealth of Pennsylvania's Homeowners' Emergency Mortgage
Assistance Program may be able to help you. Read the following notice to
find out how the program works.
If you need more information, call the Pennsylvania Housing Finance
Agency at 1-800-342-2397.
La Notification en adjunto es de suma importancia, pues afecta su
derecho a continuar viviendo en su casa. Si no comprende el contenido de
esta notification obtenga una traduccion immediatamente llamando esta
agencia (Pennsylvania Housing Finance Agency) sin cargos a1 numero
mencionado arriba. Puedes ser elegible para un prestamo por el programa
llamado "Homeowners' Emergency Mortgage Assistance Program" al cual puede
salvar su casa de la perdida del derecho a redimir su hipoteca.
ACT 91 NOTICE
IMPORTANT: NOTICE OF HOMEOWNERS'
EMERGENCY MORTGAGE ASSISTANCE PROGRAM
PLEASE READ THIS NOTICE.
YOU MAY BE ELIGIBLE FOR FINANCIAL
ASSISTANCE WHICH CAN SAVE YOUR HOME FROM
FORECLOSURE AND HELP YOU MAKE FUTURE MORTGAGE PAYMENTS
May 29, 1999
RE: G.E. CAPITAL MORTGAGE SERVICES, INC.
Property Address: 334 LOWTHER STREET, LEMOYNE PA 17043
Loan # 10339133
TO: KATHRYN M VOLOVSKI
334 LOWT14ER ST
LEMOYNE, PA 17043
FROM: G.E. Capital Mortgage Services
You may be eligible for financial assistance that will prevent foreclosure
on your mortgage if you comply with the provisions of the Homeowners'
Emergency Mortgage Assistance Act of 1983 (the "ACT"). You may be eligible
for emergency temporary assistance if you default has been caused by
circumstances beyond your control, you have a reasonable prospect of
resuming your mortgage payments, and if you meet other eligibility
requirements established by the Pennsylvania Housing Finance Agency.
Please read all of this Notice. It contains an explanation of your rights.
,.3iN?
GE caorra
G'CaaitalMatloace Scrvrses. If.:.
Under the Act, you are entitled to a temporary stay of foreclosure on your
mortgage for thirty (30) days from the date of this Notice. During that
time you must arrange and attend a "face-to-face" meeting with a
representative of this lender, or with a designated consumer credit
counseling agency. The purpose of this meeting is to attempt to work out a
repayment plan, or to otherwise settle your delinquency. This meeting must
occur in the next thirty (30) days.
If you attend a face-to-face meeting with this lender, or with a consumer
credit counseling agency identified in this notice, no further proceeding
in mortgage foreclosure may take place for thirty (30) days after the date
of this meeting. The name, address, and telephone number of our
representative is:
G.E. Capital Mortgage Services
625 Maryville Centre Diive
St. Louis, MO 631y1
The names and addresses of designated consumer credit counseling agencies
are shown on the attached sheet. It is only necessary to schedule one
face-to-face meeting. You should advise this lender immediately of your
intentions.
Your mortgage is in default because you have failed to pay promptly
installments of principal and interest, as required for at least sixty (60)
days. The total amount of the delinquency is $1,455.96. That sum includes
the following: payments due 04/01/99 through the first of this month and
late charges.
Your mortgage is also in default for the following reason:
ILLNESS OF PRINCIPAL MORTGAGOR.
If you have tried and are unable to resolve this problem at or after our
face-to-face meeting, you have the right to apply for financial assistance
from the Homeowners' Emergency Mortgage Assistance Fund. In order to do
this, you must fill out, sign and file a completed Homeowners' Emergency
Assistance Application with one of the designated consumer credit
counseling agencies listed on the attachment. An application for
assistance may only be obtained from a consumer credit counseling agency.
The consumer credit counseling agency will assist you in filling out your
application and will submit your completed application to the Pennsylvania
Housing Finance Agency. Your application must be filed or postmarked,
within thirty (30) days of your face-to-face meeting.
It is extremely important that you file your application promptly. If you
do not do so, or if you do not follow other time periods set forth in this
letter, foreclosure may proceed against your home immediately.
Available funds for emergency mortgage assistance are very limited. They
will be disbursed by the Agency under the eligibility criteria established
by the ACT.
It is extremely important that your application is accurate and complete in
every respect. The Pennsylvania Housing Finance Agency has sixty (60) days
?l.'i14y
GE capita!
Gf Capl ial Mangayc Services. Inc.
Sx,
to make a decision after it receives your application. During that
additional time, no foreclosure proceedings will be pursued against you if
you have met the time requirements set forth above. You will be notified
directly by the Agency of its decision on your application.
GE Capital
aE caoital mamas Services. us.
The Pennsylvania Housing Finance Agency is located at 2101 North Front
Street, Post Office Box 8029, Harrisburg, Pennsylvania 17105. Telephone
No. (717) 780-3800 or 1-800-342-2397 (toll free number). Persons with
impaired hearing can call 1-800-342-2397.
In addition, you may receive another notice from this lender under Act 6 of
1974. That notice is called a "Notice of Intention to Foreclose." You must
read both notices, since they both explain rights that you now have under
Pennsylvania law. However, if you choose to exercise your rights described
in this notice, you cannot foreclosed upon while you are receiving that
assistance.
10339133
Sincerely,
Loan Counselor, Collection Department
1 (800) 344-6723
The following disclosure is required by applicable federal and state law
for certain loans that we service: This communication is from a debt
collector and is an attempt to collect a debt; any information obtained
will be used for that purpose.
/ml,
.
GE Ca0ilal
GECapital Mortgage Serv¢s. In..
HUD APPROVED COUNSELING AGENCIES
PENNSYLVANIA
DELAWARE COUNTY H.O.P.E. BAYFRONT NATO, INC.
PHILADELPHIA COUNCIL FOR COMMUNITY 312 CHESTNUT STREET
ADVANCEMENT ERIE, PA 16507
511 WELSH STREET (814) 459-2761
CHESTER, PA 19013 -
(215) 872 3500
COMMUNITY RESOURCES FOR INDEP
2222 FILMORE AVENUE
ERIE, PA 16506
(814) 838-7222
HARRISBURG FAIR HOUSING COUNCIL
1228 BAILEY STREET
HARRISBURG, PA 17103
(717) 238-9540
INDIANA COUNTY COMMUNITY
ACTION PROGRAM INC.
827 WATER STREET
PO BOX 187
INDIANA, PA 15701
(412) 465-2657
NORTHERN TIER COMMUNITY
ACTION CORPORATION
135 WEST 4TH STREET
EMPORIA, PA 15834
(814) 486-1161
GREATER ERIE COMMUNITY
ACTION AGENCY
18 WEST 9TH STREET
ERIE, PA 16501
(814) 459-4581
ELK COUNTY HOUSING AUTHORITY
424 WATER STREET EXT.
PO BOX 100
JOHNSONBURGH, PA 15845
(814) 965-2532
ASSOCIATED FAMILY SERVICES
213 CENTER STREET
MEADVILLE, PA 16335
(814) 337-8457
NEW KENSINGTON C.D.C.
2513-15 FRANKFORD AVENUE
PHILADELPHIA, PA 19125
(215) 427-0350
TABOR COMMUNITY SERVICES
439 EAST KING STREET
LANCASTER, PA 3.7602
(717) 397-5182
BOOKER T. WASHINGTON CENTER
1720 HOLLAND STREET ,
ERIE, PA 16503
(814) 4 53 -5744
URBAN LEAGUE OF
METROPOLITAN HARRISBURG
25 NORTH FRONT STREET
HARRISBURG, PA 17101
(717) 234-3253
HOUSING OPPORTUNITIES, INC
133 SEVENTH AVENUE
PO BOX 9
MCKEESPORT, PA 15132
(412) 664-1590
LAWRENCE COUNTY SOCIAL SERVICE:
33-39 SOUTH JEFFERSON STREET
NEW CASTLE, PA 16103
(412) 658-7258
PHILADELPHIA COUNCIL FOR
COMMUNITY ADVANCEMENT
100 NORTH 17TH STREET - SUITE
PHILADELPHIA, PA 19103
(215) 567-7803
TENANTS' ACTION GROUP
OF PHILADELPHIA
21 SOUTH 12TH STREET -
PHILDELPHIA, PA 19107
(215) 575-0700
CE L'apitaf
GE 6anital Atanuapa services. tn..
HUD APPROVED COUNSELING AGENCIES
PENNSYLVANIA(COnt)
CENTER FOR INDEPENDENT LIVING SW PA
7110 PENN AVENUE
12TH FLOOR PITTSBURGH, PA 15208
(412) 371-7700
TREHAD CENTER OF NE PENNSYLVANIA
7 LAKE AVENUE
MONTROSE, PA 18801
(717) 278-3338
NORTHWEST COUNSELING SERVICE
5001 NORTH BROAD STREET
PHILADELPHIA, PA 19141
(215) 549-2344
URBAN LEAGUE OF PHILADELPHIA
4601 MARKET STREET
PHILADELPHIA, PA 19139
(215) 476-4040
ELDER-ADO, INC
320 BROWNSVILLE ROAD
PITTSBURGH, PA 15210
(412) 381-6900
ECONOMIC OPPORTUNITY CABINET
118 EAST NORWEGIAN STREET
POTTSVILLE, PA 17901-2921
(717) 622-1995
TABLELAND SERVICES, INC.
131 NORTH CENTER AVENUE
PO BOX 756
SOMERSET, PA 15501
(814)445-9628 OR (814) 445-0148
HOUSING ASSOCIATION INFORMATION PROGRAM
1314 CHESTNUT STREET - SUITE 900
PHILADELPHIA, PA 19107
(215) 545-6010
MORTGAGORS COUNSELED AT
658-60 NORTH WATTS STREET,
PHILADELPHIA, PA 19123
PHILADELPHIA HOUSING
DEVELOPMENT CORPORTATION
1234 MARKET STREET - 10TH FLOOR
PHILADELPHIA, PA 19107
(215) 448-3137 OR (215) 448-3132
CONSUMER CREDIT COUNSELING
OF WESTERN PENNSYLVANIA
309 SMITHFIELD STREET - SUITE 2000
PITTSBURGH, PA 15222
(412) 471-7584
HILL COMMUNITY DEVELOPMENT CORPORTATION
2015-2017 CENTRE AVENUE
PITTSBURGH, PA 15219
(412) 765-1320
MERCER COUNTY
COMMUNITY ACTION AGENCY
309 OHIO STREET
SHARON, PA 16146
(412) 342-6222
WARREN FOREST COUNTY E.O.C.
1209 PENNSYLVAIA AVENUE WEST
PO BOX 547
WARREN, PA 16365
(814) 726-2400
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GE Capitai
VE Capital mortgage services, Inc,
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HUD APPROVED COUNSELING AGENCIES
PENNSYLVANIA(Cont)
GARFIELD JUBLIEE ASSOCIATION, INC. URBAN LEAGUE OF PITTSBURGH
5138 PENN AVENUE ONE SMITHFIELD STREET
PITTSBURGH, PA 15224 PITTSBURGH, PA 15222
(412) 665-5200 (412) 261-1130
BERKS COMMUNITY ACTION AGENCY
BUDGET COUNSELING CENTER
247 NORTH FIFTH STREET
READING, PA 19601
(215) 375-7866
SHENANGO VALLEY URBAN LEAGUE
39 CHESTNUT STREET
SHARON, PA 16146
(412) 981-5310
FAYETTE COUNTY
COMMUNITY ACTION AGENCY
137 NORTH BEESON AVENUE
UNIONTOWN, PA 15401
(412) 437-6050
WASHINGTON- GREENE
COMMUNITY ACTION CORPORATION
315 EAST HALLAM AVENUE
WASHINGTON, PA 15301
(412) 225-9550
HOUSING COUNCIL OF YORK
116 NORTH GEORGE STREET
YORK, PA 17401
(717) 854-1541
COMMISSION OF ECONOMIC
OPPORTUNITY OF LUZERNE COUNTY
122-213 SOUTH MAIN STREET
WILKES-BARRE, PA 18701
(717) 826-0510
TRI-COUNTY PARTNERSHIP FOR
INDEPENDENT LIVING
69 EAST BEAU STREET
WASHINGTON, PA 15301
(412) 223-5115
CONSUMER CREDIT COUNSELING
SERVICE OF LEHIGH VALLEY
3671 CRESCENT COURT EAST
WHITEHALL, PA 18052
(215) 821-4011
WASHINGTON- GREENE
COMMUNITY ACTON CORPORATION
22 WEST HIGH STREET
WAYNESBURG, PA 15370
(412) 852-2893
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MAR 2 8 20000
GOLDBECK McCAFFERTY & McKEEVER
BY: KRISTINA G. MURTHA, ESQ.
ATTORNEY IDN 61858
Suite 500 - The Bourse Bldg.
111 S. Independence Mall East
Philadelphia, PA 19106
215-627-1322
Attorney for Plaintiff
GE CAPITAL MORTGAGE
SERVS. INC.,
Plaintiff
VS.
TERRY L. VOLOVSKI AND
KATHRYN M. VOLOVSKI,
Defendants
IN THE COURT OF COMMON PLEAS
OF CUMBERLAND COUNTY
CIVIL ACTION - LAW
ACTION OF MORTGAGE FORECLOSURE
No. 99-7211 CIVIL
ORDER
AND NOW, this ? ?? day of 2000, upon
consideration of Plaintiff's Motion for Reconsideration, end BeFendants' ,
-aWit is hereby
ORDERED this Court's Order of March 10, 2000 be and is hereby VACATED and
Plaintiff shall be permitted to served the complaint in Mortgage Foreclosure upon Defendants
by posting a copy of the Complaint upon the premises at 334 Lowther Street, Lemoyne, PA
17043, and mailing same regular and certified mail to Defendants' last known address of 334
Lowther Street, Lemoyne, PA 17043, and that all further service of legal papers, including
motions, petition the Notice of Sheriffs Sale, pursuant to Pa.R.C.P. 3129 may be made
upon Defendants by sending copies of same to Defendants last known address by certified
and regular mail.
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GOLDBECK McCAFFERTY & McKEEVER
BY: KRISTINA G. MURTHA, ESQ.
ATTORNEY ID# 61858
Suite 500 - The Bourse Bldg.
111 S. Independence Mall East
Philadelphia, PA 19106
215-627-1322
Attorney for Plaintiff
GE CAPITAL MORTGAGE IN THE COURT OF COMMON PLEAS
SERVS. INC.,
OF CUMBERLAND COUNTY
Plaintiff
VS.
CIVIL ACTION - LAW
ACTION OF MORTGAGE FORECLOSURE
TERRY L. VOLOVSKI AND
KATHRYN M. VOLOVSKI,
No. 99-7211 CIVIL
Defendants
PLAINTIFF'S MOTION FOR RECONSIDERATION
GE Capital Mortgage Services, Inc., Plaintiff in the above action, by its attorney,
Kristina G. Murtha, Esquire, hereby moves for reconsideration of this Honorable Court's
Order of March 10, 2000, and in support thereof states:
1. On November 30, 1999, following a default in the mortgage payments by Terry L.
and Kathryn M. Volovski, (hereinafter "Defendants"), GE Capital Mortgage Services, Inc.,
(hereinafter "Plaintiff") filed its complaint in mortgage foreclosure, under the above caption.
2. Plaintiff, being unable to serve Defendants personally, pursuant to
Pa.R.C.P.402(a)(1), filed a Motion for Substituted Service, pursuant to Pa.R.C.P. 430(a). A
true and correct copy of the Motion is incorporated by reference and is attached hereto as
Exhibit A.
3. In Plaintiff's Motion, Plaintiff requested it be permitted to serve by posting the
premises and mailing the Complaint to Defendants at the last known address, via certified
and regular mail.
4. Attached to Plaintiff's Motion was an Affidavit of Good Faith Investigation. In that
Affidavit, it was averred that Plaintiffs representative had conducted an investigation as
follows:
a. Credit Information (inquiry of creditors and employment search);
b. Telephone Company (Directory Assistance search);
C. Inquiry of neighbors;
d. Inquiry of Post Office;
e. Inquiry of Motor Vehicle & DMV offices;
f. Inquiry of Social Security Administration; and
g. Inquiry of Voter Registration.
5. On or about March 13, 2000, Plaintiff received a copy of an Order of Court, entered
by Your Honor, in which Plaintiff's Motion for Substituted Service was denied. A true and
correct copy of the Order of Court is incorporated by reference and is attached hereto as
Exhibit B.
6. In the Order, it was noted that the Motion would be reconsidered if accompanied by
an affidavit relating to the inquiry made.
7. Plaintiff is unsure why the copy of the Motion forwarded to Your Honor was not
accompanied by the Affidavit. Plaintiff's copy in its file contains the Affidavit, and, upon
information and belief, the copy forwarded to the Court was also accompanied by the Order.
8. In the interests of judicial economy, Plaintiff is requesting reconsideration of its
Motion for Substituted Service. A true and correct copy of the Affidavit requested by Your
Honor is attached hereto separately as Exhibit C.
WHEREFORE, Plaintiff respectfully requests Your Honor strike the Order of March
10, 2000, and enter a new order, permitting service by c
Defendants' last known address and posting of the premix
Respectfully s
KRISTINA
ATTORNEY]
Goldbeck McCafferty & McKeever
A Professional Corporation
BY: KRISTINA G. WRTHA, ESQUIRE
Attorney I.D. # 61858
Suite 500 - The Bourse Bldg.
111 S. Independence Mall East
Philadelphia, PA 19106
215-627-1322
Attorney for Plaintiff
GE CAPITAL MORTGAGE SERVS. INC.
4680 Hallmark Parkway
San Bernardino, CA 92407
Plaintiff
VS.
TERRY L. VOLOVSKI
KATHRYN VOLOVSKI
(Mortgagors and Record Owners)
334 Lowther Street
Lemoyne, PA 17043
IN THE COURT OF COMMON PLEAS
OF CUMBERLAND COUNTY
NO. 99-7211
Defendants
VERIFICATION
Kristina G. Murtha, Esquire, hereby states that she is the attorney for Plaintiff hercin, and
that all of the facts set forth within the attached Motion for Reconsideration are true and correct
to best of her knowledge, information and belief. The undersigned understands that the foregoing
statements are made subject to the penalties of 18 P.S. Section
Attorney
ESQUntE
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GOLDBECK MCCAFFERTY & MCKREVER
PROFESSIONAL CORPORATION
ATriORNEYS AT LAW
SUITE 500 THE 130MME BUILDING
111 S. INDEPENDENCE MALL EAST
PHILADELPHIA, PA 19106
(215) 627-1322 FAX (215) 627-7734
Ta,ePh A. GolGhack. Zr.
Gary R. MGCafhrfy
Michael T. McNwar
Date: 3 -?
Prothonotary's Office
Cumberland county courthouse
Carlisle, PA 17013
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RE: Docks Number: 99-7211
GE Capital vs. Volovski
Dear Sir or Madam:
Enclosed find please an original and a copy of Plai.ntiEf's
Motion for Substituted Service. Kindly file and return a time
stamped copy to our office in the enclosed self addressed stamped
envelope.
KGM/dms
Enclosures
cc: Terry L. Volovski
Kathryn M. Volovski
Ken Thompson
#10339133
1
GOLDBECK MCCAFFERTY & MCKEEVER
JOSEPH A. GOLDBECK, JR.
Attorney I.D.#16132
Suite 500-The Bourse Building
111 S. Independence Mall East
Philadelphia, PA 19106
215-627-1322
BY: KRISTINA G. MURTHA, ESQUIRE
Attorney I.D. #61858
Attorney for Plaintiff
GH CAPITAL MORTGAGE SERVS. INC
4680 Hallmark Parkway
San Ber'naX inO, CA 92407
Vs.
TERRY L. VOLOVSKI
KATERYN M. VOLOVSKI
(Mortgagors and Real Owners)
334 Lowther Street
Lemoyne, PA 17043
IN THE COURT OF COMMON PLEAS
OF CUMBERLAND COUNTY
No. 99-7211
ORDER
AND NOW, this day of 2000,
upon consideration of the Plaintiff's Motion for Substituted
Service under Pa.R.C.P. 430(a) and it appearing to the Court that
Plaintiff's good faith efforts to ascertain the present whereabouts
of Defendants has been unsuccessful, it is,
ORDERED and DECREED:
that Plaintiff's Motion is granted and the Sheriff and/or
Plaintiff is directed to Serve the Complaint in Mortgage
Foreclosure upon Defendants by posting a copy of the Complaint upon
the premises 334 Lowther Street, Lemoyne, PA 17043, and Plaintiff
is directed to serve the Complaint by certified and regular mail to
the Defendants' last known address at 334 Lowther Street, Lemoyne,
PA 17043, and that all further service of legal papers, including
but not limited to motions, petitions and rules be made by
certified and regular mail to Defendants' last known address and
that Notice of Sheriff Sale pursuant to Pennsylvania Rule of Civil
Procedure 3129 may be made upon Defendants by sending copies of
same to Defendants' last known address by certified and regular
mail and by posting the premises.
BY THE COURT:
J.
GOLDBECK MCCAFFERTY & MCREEVER
JOSEPH A. GOLDBECK, JR.
Attorney I.D.#16132
Suite 500-The Bourse Building
Ill S. Independence Mall East
Philadelphia, PA 19106
215-627-1322
BY: RRISTINA G. MURTHA, ESQUIRE
Attorney E.D. #61858
Attorney for Plaintiff
GE CAPITAL MORTGAGE SERVS. INC. IN THE COURT OF COMMON PLEAS
4680 Hallmark Parkway
San Bernardino, CA 92407 OF CUMBERLAND COUNTY
VS. No. 99-7211
TERRY L. VOLOVSRI
KATHRYN M. VOLOVSBI
(Mortgagors and Real Owners)
334 Lowther Street
Lemoyne, PA 17043
VERIFICATION
I, ERISTIN& G. MURTHA, ESQUIRE, Attorney for Petitioner do
hereby verify that the facts set forth in the foregoing Motion for
Substituted Service 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 3.8 Pa. C.S.
4904 relating to unsworn falsification to authorities.
GOLDBECK MCCAFFERTY & KCKSSVER
JOSEPH A. GOLDBECK, JR.
Attorney I.D.#16132
Suite 500-The Bourse Building
111 S. Independence Mall East
Philadelphia, PA 19106
215-627-1322
BY: KRISTINA G. MURTHA, ESQUIRE
Attorney Y.D. #61858
Attorney for Plaintiff
GE CAPITAL MORTGAGE SERVS. INC
4680 Hallmark Parkway
San Bernardino, CA 92407
Vs.
TERRY L. VOLOVSKI
KATHRYN M. VOLOVSKI
(Mortgagors and Real Owners)
334 Lowther Street
Lemoyne, PA 17043
IN THE COURT OF COMMON PLEAS
OF CUMBERLAND COUNTY
No. 99-7211
THIS LAIN FIRM IS A DEBT COLLECTOR AIA) WE ARE AMWM3TINC TO
COLLECT A DEBT OWED TO OUR CLIENT. ANY IIIFORFRITION OB'AILM FROM
YOU FALL BE USED FOR THE PURPOSE OF COLLECTING THE DEBT.
MOTION FOR SUBSTITOTED SERVICE
UNDER PA.R.C_P. 430(a)
Plaintiff, by and through its attorney, Kristina G.
Murtha, Esquire, in support of its Motion for Substituted Service,
represents as follows:
1. Plaintiff is the holder of a first mortgage upon the
premises 334 Lowther Street, Lemoyne, PA 17043, hereinafter, the
"mortgaged premises"
2. Defendants, TERRY L. VOLOVSKI AND KATHRYN M. VOLOVSKI,
are the mortgagors and real owners of the mortgaged premises.
3. The last )mown address of Defendants' is 334 Lowther
Street, Lemoyne, PA 17043 as set forth in Paragraph 2 of the CoWlaint.
4. The Sheriff has been unable to effect service of the
Complaint upon Defendants at their last known address after
numerous attempts.
5. The following investigation was conducted in a good faith
attempt to ascertain the whereabouts of Defendants.
WEMaFORS, Plaintiff prays that the Court enter the
attached order allowing Plaintiff to serve the complaint upon
Defendants by posting the premises and certified and regular mail
to the Defendants' last known address. n
BY: RRISTMA,. /MLft2T", ESQUIRE
GOLDBECK MCCAFFERTY & MCK29VER
JOSEPH A. GOLDBECK, JR.
Attorney I.D.#16132
Suite 500-The Bourse Building
111 S. Independence Mall Bast
Philadelphia, PA 19106
215-627-1322
BY: KRISTINA G. MURTHA, 13SQUIRE
Attorney I.D. #61858
Attorney for Plaintiff
GE CAPITAL, MORTGAGE SERVS. INC
4660 Hallmark Parkway
San Bernardino, CA 92407
Vs.
TERRY L. VOLOVSKI
KATHRYN Id. VOlOVSKI
(Mortgagors and Real Owners)
334 Lowther Street
Lemoyne, PA 17043
IN THE COURT OF COMMON PLEAS
OF CUMBEMr.mm COUNTY ---.--
No. 99-7211
Plaintiff has filed a Complaint in Mortgage Foreclosure
against Defendants which the Sheriff has been unable to
personally serve upon Defendants. As noted in the attached
Motion, Plaintiff has made a good faith attempt to ascertain
Defendants' whereabouts without success. Accordingly, the Court
may approve alternative means of service. See Pa.R.C.P. 430(a).
For reasons stated above and in the attached Motion,
the Court should enter an order allowing Plaintiff to serve the
Complaint in Mortgage Foreclosure upon Defendants by posting the
premises and certified mail and regular mail to the Defendants,
last known address.
Respectful;
KRISTM
PLAYERS NATIONAL LOCATOR
AFFIDAVIT OF GOOD FAITH INVESTIGATION
Loan Number: GCMS-0368
Attorney Firm: GOLDBECK, MCCAFFERTY & MCKEEVER
Case Number. '
Subject: TERRY L & KATHRYN VOLOVSKI
A.K.A.: KATHRYN M FULLER
Last Known Address: 334 LOWTHER STREET
LEMOYNE, PA 17043--- ---- -
Last Known Number. ( ) -
Michad :; Coss, being duly swom according to law, deposes and says:
1. I am employed in the capacity of President for Players National Locator.
2. On 01113/2000, I conducted an investigation into the whereabouts of the above named
defendant(s). The results of my investigation are as follows:
CREDIT INFORMATION -
A. SOCIAL SECURITY NUMBER: - -
B. EMPLOYMENT SEARCH:
Unable to locate a good employer for Terry or Kathryn.
C. INQUIRY OF CREDITORS:
Creditors Indicated that Terry and Kathryn are using an address of 334 Lowther Street, Lemoyne,
PA 17043 with no valid home number.
INQUIRY OF TELEPHONE COMPANY -
A. DIRECTORY ASSISTANCE SEARCH:
Directory assistance does not have a listing for Terry or Kathryn.
INQUIRY OF NEIGHBORS -
We were unable to contact a neighbor to verify an address for Terry or Kathryn.
INQUIRY OF POST OFFICE -
A. NATIONAL ADDRESS UPDATE:
As of January 6, 2000 the National Change of Address (NCOA) does not have a change for Terry
or Kathryn from the last known address.
MOTOR VEHICLE REGISTRATION -
A. MOTOR VEHICLE & DMV OFFICE:
The Pennsylvania Department of Drivers Licensing has Terry and Kathryn listed at the last known
address.
OTHER INQUIRIES -
A. DEATH RECORDS:
As of January 6, 2000 the Social Security Administration does not have a death record in the
name Terry L or Kathryn M Volovski andfor a.k.a: s under their social security numbers.
B. PUBLIC LICENSES (PILOT, REAL ESTATE, ETC.):
None found.
C. COUNTY VOTER REGISTRATION:
The County Voters Registration Office has Terry and Kathryn listed at the last known address.
OTHER SEARCHES -
The social security numbers provided have been verified.
ADDITIONAL INFORMATION ON SUBJECT-
A. DATE OF BIRTH:
Terry -1950
Kathryn - June 1951
AFFIANT Michael K Gross
.. ..
- and swom to before me o 01/13/2000 " NOTARY SEi,L"
Kristine F1. Scott, Plotary Public
SI. Louis County, State of 1lrssouri
Aty Cmnmission Exprs.-, 91212002
44 A
PUBLIC
Players National Locator 16201 Westwoods Business Park Drive St. Louis, MO 63021
Phone: (314) 230-9922 Fax. (314) 230-0558
SHERIFF'S RETURN - NOT FOUND
CASE NO: 1999-07211 P
'COMMONTWEALTH OF PENNSYLVANIA
COUNTY OF CUMBERLAND
GE CAPITAL MORTGAGE SERVE INC
VS
V';LOVSKI TERRY L ET AL
R. Thomas Kline Sheriff or Deputy Sheriff, who being
duly sworn according to law, says, that he made a diligent search and
inquiry for the within named defendant, DEFENDANT
__ VOLOVSKI TERRY L
..but was'----
unable to locate Him in his bailiwick. He therefore returns the
COMPLAINT - MORT FORE
NOTICE
, NOT FOUND , as to
the within named DEFENDANT VOLOVSKI TERRY L
ADDRESS STATED IS NOT VALID, ALTERNATE ADDRESS
NOT PROVIDED PRIOR TO EXP. DATE OF 12130/99
Sheriff's Costs:
Docketing 18.00
Service 10.54
NOT FOUND RETURN 5.00
Surcharge. 8.00
.00
41.54
So answe
R! Thomas K11ne
Sheriff of Cumberland County
GOLDBECK, MCCAFFERTY, MCKEEVER
01/04/2000
• Sworn and subscribed to before me
this day of
A. D.
Prothonotary
0
SHERIFF'S RETURN - NOT FOUND
CASE NO: 1999-07211 P
'tOMMONTWEALTH OF PENNSYLVANIA
COUNTY OF CUMBERLAND
GE CAPITAL MORTGAGE SERVS INC
VS
VOLOVSKI TERRY L ET AL
R. Thomas Kline ,Sheriff or Deputy Sheriff, who being
duly sworn according to law, says, that he made a diligent search and
inquiry for the within named defendant, DEFENDANT
VOLOVSKI KATHRYN M
-----.----but- was
unable to locate Her in his bailiwick
COMPLAINT - MORT FORE ,
He therefore returns the
NOTICE
NOT FOUND , as to
the within named DEFENDANT , VOLOVSKI KATHRYN M
ADDRESS STATED IS NOT VALID, ALTERNATE ADDRESS
NOT PROVIDED PRIOR TO EXPIRATION DATE OF 12/30/99 .
Sheriff's Costs: So answ
Docketing 6.00
NOT FOUND RETURN 5.00
Affidavit .00 R. 'Thomas Kline
surcharge 8.00 Sheriff of Cumberland County
.00
19.00 GOLDBECK, MCCAFFERTY, MCKEEVER
01/04/2000
Sworn and subscribed to before me
_ ......... ....
SHERIFF'S DEPARTMENT
SHERIFF SERVICE INSTRUCTIONS
:1.
vs
6. AOORESS (Slreef or
e..SPECIAL INSTR --
UCTIONS OR OTHER INFORMA17ON THAT WILL ASSIST IN EXPEONIN
of
1 m area muss be compl-F
111 S. Independence Mall
SHERIFF'S DEPARTMENT
SHERIFF SERVICE INSTRUCTIONS
TYPE OF
WTI t o. nuuneaa W. AParlmeM Ne.. GIy. E7orO.Iwp.. SW[e a00 ZIP 6000)
3g7YT M7 sng&r, 12n owie, f /)JL/3
7. INDICATE UNUSUAL SERVICE: ? DEPUTIZE ? REGISTERED MAIL: ? OTHER:
ATTORNEY OR ORIGINATOR USE ONLY SHERIFFS USE ONLY
S. SPECIAL INSTRUCTIONS OR OTHER INFORMATION THAT WILL ASSIST IN EXPEDITING SERVICE:
9. SIGNATURE 01 ATTO NEY 10. TELEPHONE NUMBER 11. DATE
(215) 627-1322
12. ADDRESS f: ATT ROR_O R (This area must be wmpleted)
Suite 500 - T e Bourse BldNATO ., ill S. Independence Mall East, Philadelphia, PA 19106
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GOLDBECK MCCAFFERTY & MCKEEVER
JOSEPH A. GOLDBECK, JR.
Attorney I.D.#16132
Suite 500-The Bourse Building
111 S. Independence Mall East
Philadelphia, PA 19106
215-627-1322
BY: RRISTINA G. MURTHA, ESQUIRE
Attorney I.D. #61858
Attorney for Plaintiff
GE CAPITAL MORTGAGE SERVS. INC. IN THE COURT OF COMMON PLEAS
4680 Hallmark Parkway
San Bernardino, CA 92407 OF CUMBERIJUM COUNTY
Vs.
TERRY L. VOLOVSKI
KATHRYN M. VOLoVSRI
(Mortgagors and Real owners)
334 Lowther Street
Lemoyne, PA 17043
No. 99-7211
CERTIFICATE OF SERVICE
RRISTINA G. MURTHA, Esquire, do hereby certify that true
and correct copies of the the foregoing Motion for Substituted
Service have been served upon the Defendants this pf&Z day of
1,?,-C- Gk 2000, by first class mail, postage prepaid.
g1LWZ _ ?.
BY:
ESQUIRE
II
GE CAPITAL MORTGAGE : IN THE COURT OF COMMON PLEAS OF
SERVICES, INC. : CUMBERLAND COUNTY, PENNSYLVANIA
V.
TERRY L. VOLOVSKI : NO. 99-7211 CIVIL TERM
KATHRYN M. VOLOVSKI
(Mortgagors and Real Owners)
AND NOW, this 10 day of MARCH, 2000, Plaintiffs Motion for Substitute
Service is DENIED. We will reconsider the Motion if it is accompanied by an affidavit
setting forth the nature and extent of the investigation made to determine the defendants'
whereabouts as required by Pa. R.C.P. 430(a).
By the
Edward E.
Kristina G. Murtha, Esquire
For the Plaintiff
Terry Volovski
Kathryn Volovski
334 Lowther Street
Lemoyne, Pa. 17043
:sld
In T, si .. i h. r ur,tj rat my hand
and fit) seal u, sai Court at Carlide, Pa.
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PLAYERS NATIONAL LOCATOR
AFFIDAVIT OF GOOD FAITH INVESTIGATION
Loan Number. GCMS-0368
Attorney Firm: GOLDBECK, IMCCAFFERTY & MCKEEVER
Case Number. '
Subject: TERRY L & KATHRYN VOLOVSKI
A.K.A.: KATHRYN M FULLER
Last Known Address: 334 LOWTHER STREET
- - LEMOYNE, PA 17043- .-
Last Known Number. ( ) -
Michac::: --:oss, being duly swom according to law, deposes and says:
1. 1 am employed in the capacity of President for Players National Locator.
2. On 01/13/2000, 1 conducted an investigation into the whereabouts of the above named
defendant(s). The results of my investigation are as follows:
CREDIT INFORMATION -
A. SOCIAL SECURITY NUMBER: - -
B. EMPLOYMENT SEARCH:
Unable to locate a good employer for Terry or Kathryn,
C. INQUIRY OF CREDITORS:
Creditors Indicated that Terry and Kathryn are using an address of 334 Lowther Street, Lemoyne,
PA 17043 with no valid horse number.
INQUIRY OF TELEPHONE COMPANY -
A. DIRECTORY ASSISTANCE SEARCH:
Directory assistance does not have a listing for Terry or Kathryn.
INQUIRY OF NEIGHBORS -
We were unable to contact a nelghborto verify an address for Terry or Kathryn.
INQUIRY OF POST OFFICE -
A. NATIONAL ADDRESS UPDATE:
As of January 6, 2000 the National Change of Address (NCOA) does not have a change forTerry
or Kathryn from the last known address.
MOTOR VEHICLE REGISTRATION -
A. MOTOR VEHICLE & DMV OFFICE:
The Pennsylvania Department of Drivers Licensing has Terry and Kathryn listed at the last known
address.
OTHER INQUIRIES -
A. DEATH RECORDS:
As of January 6, 2000 the Soclal Security Administration does not have a death record in the
name Terry L or Kathryn M Volovski and/or a.k.a: s under their social security numbers.
B. PUBLIC LICENSES (PILOT, REAL ESTATE, ETC.):
Nonefound.
C. COUNTY VOTER REGISTRATION:
The County Voters Registration Office has Terry and Kathryn listed at the last known address.
OTHER SEARCHES -
The social security numbers provided have been verified.
ADDITIONAL INFORMATION ON SUBJECT -
A. DATE OF BIRTH:
Terry -1950•
Kathryn -June 1951
AFFIANT Michael K Gross
scli and sworn to before me o 0111312000 "NOTARY Nota S a "
Kristine lit. Scoll, ryPublic
?/? /?, SL Louis County. Stale of Missouri
p?•s 91212002
f/ My Commission E'sr
Players National Locator 16201 Westwoods Business Park Drive St. Louis, MO 63021
Phone: (314) 230-9922 Fax: (314) 230.0558
GOLDBECK McCAFFERTY & McKEEVER
BY: KRISTINA G. MURTHA, ESQ.
ATTORNEY IDN 61858
Suite 500 - The Bourse Bldg.
I 1 I S. Independence Mall East
Philadelphia, PA 19106
215-627-1322
Attorney for Plaintiff
GE CAPITAL MORTGAGE IN THE COURT OF COMMON PLEAS
SERVS. INC.,
OF CUMBERLAND COUNTY
Plaintiff
CIVIL ACTION - LAW
VS.
TERRY L. VOLOVSKI AND
KATHRYN M. VOLOVSKI,
ACTION OF MORTGAGE FORECLOSURE
Defendants
H
No. 99-7211 CIVIL
PLAINTIFF'S MEMORANDUM OF LAW
IN SUPPORT OF MOTION FOR RECONSIDERATION
L FACTS
The facts are more fully set forth in the Motion for Reconsideration, which is
incorporated by reference. Briefly, this honorable Court apparently received a copy of
Plaintiff's Motion for Substituted Service which did not contain the Affidavit of Good Faith
Investigation. However, the inquiry was performed, and Plaintiff has attached to the instant
Motion for Reconsideration a copy of the Motion for Substituted Service containing the
Affidavit, as well as a separate copy of the Affidavit.
II. LEGAL ARGUMENT
Motions for reconsideration are addressed to the sound discretion of the trial court.
Moore v. Moore, 634 A.2d 163, 166 (Pa. 1993), other citations omitted. In Moore the court
affirmed the principal that a "trial court always has the authority to reconsider its own
judgment." Id. at 167.
In the instant matter, it appears the Court's copy of the Motion for Substituted Service
did not attach the Affidavit of Good Faith Investigation. However, the investigation was
performed, and this honorable Court has now been made aware of this fact.
If the instant Motion for Reconsideration is granted, there will be no prejudice to any
party, as the Defendants will be apprised of the instant motion, and can object to same.
Moreover, the underlying Motion for Substituted Service is being sought in order to utilize
the methods most likely to apprise Defendants of the ongoing action, and thereby afford them
the greatest likelihood of notice, pursuant to the Rules of Court.
Plaintiff, having made diligent inquiry as to the whereabouts of Defendants, has filed
with its Motion for Substituted Service an Affidavit of Good Faith Investigation. In that
Affidavit, the address of Defendants was confirmed by creditors, telephone records, the
National Address Update service of postal authorities, Pennsylvania Depart of Drivers
Licensing and the Philadelphia County Voters Registration Office. Accordingly, there is
little chance that a mailing to that address, via certified and regular mail, would fail to reach
Defendants. Moreover, this is also the address of the property being foreclosed, and
therefore the address for posting; the posting will provide additional notice to Defendants.
Therefore, the harm to Defendants in allowing service via certified and regular mail to
Defendants' last known address and posting of the premises, and not requiring publication, is
minimal.
Conversely, the harm to Plaintiff is the instant motion for reconsideration is not
granted would be an increase in cost and a loss of time in the foreclosure action. Plaintiff
respectfully suggests this penalty is not warranted by what is most likely a simple error in
copying the motion.
Accordingly, Plaintiff respectfully requests this honorable Court reconsider its order,
in light of the facts and the underlying equities of the situation.
III. CONCLUSION
Plaintiff
For these and all the foregoing reasons, it is respectfully requested this honorable
Court reconsider its Order of March 10, 2000, strike this Order, and permit Plaintiff to
effect substituted service, pursuant to Pa.R.C.P. 430(a), by certified and regular mail to
Defendants' last known address and posting of the premises.
ssq.
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SHERIFF'S RETURN - REGULAR
CASE NO: 1999-07211 P
COMMONWEALTH OF PENNSYLVANIA:
COUNTY OF CUMBERLAND
GE CAPITAL MORTGAGE SERVS INC
VS
VOLOVSKI TERRY L ET AL
SHANNON SUNDAY , Sheriff or Deputy Sheriff of
Cumberland County, Pensylvania, who being duly sworn according to law,
says, the within REINSTATED COMPLAINT was served upon
the
VOLOVSKI TERRY L
DEFENDANT , at 0018:44 HOURS, on the 27th day of April 2000
at 334 LOWTHER STREET
LEMOYNE, PA 17043 by handing to
POSTED PROPERTY AT ABOVE ADDRESS
a true and attested copy of REINSTATED COMPLAINT together with
MORTGAGE FORECLOSURE W/NOTICE
and at the same time directing His attention to the contents thereof.
Sheriff's Costs:
Docketing 18.00
Service 9.30
Posting 6.00
Surcharge 10.00
.00
43.30
Sworn and Subscribed to before
me this 41 day of
A. D.
:7m?" ic,
rr thonotar
So Answers:
R. Thomas Kline
04/28/2000
GOLDBECK, MCCAFFERTY, MCKEEVER
By: Deputy Sheriff
ti SHERIFF'S RETURN - REGULAR
CASE NO: 1999-07211 P
COMMONWEALTH OF PENNSYLVANIA:
COUNTY OF CUMBERLAND
GE CAPITAL MORTGAGE SERVS INC
VS
VOLOVSKI TERRY L ET AL
SHANNON SUNDAY
Cumberland County, Pensylvai
says, the within RIENSTATED
VOLOVSKI KATHRYN M
DEFENDANT , at 0018:44
at 334 LOWTHER STREET
-1 Sheriff or Deputy Sheriff of
Zia, who being duly sworn according to law,
COMP MORT-FORE was served upon
the
HOURS, on the 27th day of April , 2000
LEMOYNE, PA 17043 by handing to
POSTED PROPERY AT ABOVE ADDRESS
a true and attested copy of RIENSTATED COMP MORT-FORE together with
NOTICE
and at the same time directing His attention to the contents thereof.
Sheriff's Costs:
Docketing
Posting Property
Affidavit
Surcharge
So Answers:
6.00
6.00 ?!/GO?-?'ZAire2
.00 i
10.00 R. Thomas Kline
.00
22.00 04/28/2000
GOLDBECK, MCCAFFERTY & MCKEEVE
Sworn and Subscribed to before
me this day of
'TK,,, oztiyU A. D.
P o honotary
By: ?riq nnWIL I-M.
Deputy Sheriff
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
GE CAPITAL MORTGAGE SERVS. INC
4680 Hallmark Parkway
San Bernardino, CA 92407
VS.
TERRY L. VOLOVSKI AND KATHRYN M
VOLOVSKI (Mortgagor(s) and
Record owner(s))
334 Lowther Street
Lemoyne, PA 17043
IN THE COURT OF COMMON PLEAS
OF CUMBERLAND COUNTY
Term
No. 99-7211 CIVIL
CERTIFICATE OF SERVICE
JOSEPH A. GOLDBECK, JR. ESQUIRE hereby certifies that on May
4, 2000 he did serve upon Defendant(s) TERRY L. VOLOVSKI and
KATHRYN M. VOLOVSKI a true and correct copy of the above-
captioned Complaint by certified and regular mail in accordance
with the Court Order dated March 31, 2000. The undersigned
understands that the statements herein and subject to the
penalties provided by 18 P.S. Section 4904.
Respectful ub d,
i
JOSEPH A. GOLDBECK, JR. ESQUIRE
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IN THE COURT OF COMMON PLEAS OF CUMBERLAND COUNTY
GE CAPITAL MORTGAGE SERVS. INC.
4680 Hallmark Parkway
San Bernardino, CA 92407
Plaintiff
VS.
TERRY L. VOLOVSKI AND KATHRYN M.
VOLOVSKI (Mortgagor(s) and
Record Owner(s))
334 Lowther Street
Lemoyne, PA 17043
Defendant(s)
Term
No. 99-7211 CIVIL
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 TERRY L. VOLOVSKI and
KATHRYN M. VOLOVSKI by default for want of an Answer.
(X) Assess damages as follows:
Debt $ 87.901.22
Interest 3/ 1/99 to 7/31/00
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 filin6 oq this pr ecipe!? A copy of the
notice is attached. R.C.P. 237.1 //__II n / 1
Josefih A. Goldb ck, Jr.
Att ney for P1 intiff
I.D. #16132
AND NOW _OfA I
entered in favor of
VOLOVSKI and KATHRYN
damages assessed in
DOLLARS AND 22 CENTS
"-tom c2 , 2(')en l
sE CAPITAL MORTGAGE SERVS. INC.,
M. VOLOVSKI by default for want
:he sum of EIGHTY SEVEN THOUSAND
($87,901.22), as per the above
Judgment is
and against TERRY L.
of an Answer and
NINE HUNDRED ONE
certification.
r6thonotary
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
GE CAPITAL MORTGAGE SERVS. INC
4680 Hallmark Parkway
San Bernardino, CA 92407
Vs.
TERRY L. VOLOVSKI AND KATHRYN M
VOLOVSKI (Mortgagor (s) and
Record Owner(s))
334 Lowther Street
Lemoyne, PA 17043
IN THE COURT OF COMMON PLEAS
OF CUMBERLAND COUNTY
Term
No. 99-7211 CIVIL
CERTIFICATE OF SERVICE
JOSEPH A. GOLDBECK, JR. ESQUIRE hereby certifies that on May
4, 2000 lie did serve upon Defendant(s) TERRY L. VOLOVSKI and
KATHRYN M. VOLOVSKI a true and correct copy of the above-
captioned Complaint by certified and regular mail in accordance
with the Court Order dated March 31, 2000. The undersigned
understands that the statements herein and subject to the
penalties provided by 18 P.S. Section 4904.
Respectful ub d,
JOSEPH A. GOLD BECK, JR. ESQUIRE
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
GE CAPITAL MORTGAGE SERVS- INC
4680 Hallmark Parkway
San Bernardino, CA 92407
Plaintiff
vs.
TERRY L. VOLOVSKI AND KATHRYN M.
VOLOVSKI (Mortgagor(s) and
Record Owner(s))
334 Lowther Street
Lemoyne, PA 17043
Defendant(s)
IN THE COURT OF COMMON PLEAS
OF CUMBERLAND COUNTY
CIVIL ACTION - LAW
:ACTION OF MORTGAGE FORECLOSURE
Term
No. 99-7211 CIVIL
ORDER FOR JUDGMENT
Please enter Judgment in favor of GE CAPITAL MORTGAGE SERVS.
INC., and against TERRY L. VOLOVSKI and KATHRYN M. VOLOVSKI 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 o EIGHTY
SEVEN THOUSAND NINE HUNDRED ONE DOLLARS AND 22 C NTS
($87,901.22) . / \ i _ n /n
At 2: Y forlglai
I hereby certify that the above names are correct and that
the precise residence address of the judgment creditor is 4680
Hallmark Parkway, San Bernardino, CA 92407 and that the name(s)
and last known address(es) of the Defendant(s) is/are T RY L.
VOLOVSKI, 334 Lowther Street, Lemoyne/\PA 17043; WATHR M.
VOLOVSKI, 334 Lowther Street, Lemovnel. IPA 117U-4- II A
BY T-Todkph A. Goldb ck, Jr.
Attorney for Plaintiff-
L. 1Y
ASSESSMENT OF DAMAGES
TO THE PROTHONOTARY:
Kindly assess the damages in this case to be as follows:
Principal balance
Interest from 3/ 1/99 through 7/31/00
Attorney's Fee at 5% of principal balance
Late Charges
Costs of Suit and Title Search
Escrow Balance Deficit
$ 73,770.61
8,376.06
3,688.53
387.36
560.00
$ 86,782.56
1,118.66
$ 87,901.22
UUL E' MCCAF ERTY &
By Jo ph A. oldbeck
Attorney for Plaintiff
AND NOW, this day of 2000
damages are assessed as above.
Pro Prothy
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, TERRY L. VOLOVSKI, is
about unknown years of age, that Defendant's last known residence
is 334 Lowther Street, Lemoyne, PA 17043 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:
10339133 - VOLOVSKI,TERRY L.
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, KATHRYN M. VOLOVSKI, is
about unknown years of age, that Defendant's last known residence
is 334 Lowther Street, Lemoyne, PA 17043 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: W, 0, -
10339133 - VOLOVSKI, KATHRYN M.
1
r1
TO: TERRY L. VOLOVSKI
334 Lowther Street
Lemoyne, PA 17043
GE CAPITAL MORTGAGE SERVS. INC.
4680 Hallmark Parkway
San Bernardino, CA 92407
Plaintiff
Vs.
TERRY L. VOLOVSKI AND KATHRYN M.
VOLOVSKI (Mortgagor(s))
(Record Owner(s))
334 Lowther Street
Lemoyne, PA 17043
Defendant(s)
IN THE COURT OF COWON PLEAS
OF CUMBERLAND COUNTY
CIVIL ACTION - LAW
ACTION OF MORTGAGE FORECLOSURE
Term
No. 99-7211 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: TERRY L. VOLOVSKI
334 Lowther Street
Lemoyne, PA 17043
DATE OF THIS NOTICE: May 26, 2000
IMPORTANT NOTICE
YOU ARE IN DEFAULT BECAUSE YOU HAVE FAILED TO ENTER A WRITTEN
APPEARANCE PERSONALLY OR BY ATTORNEY AND FILE IN WRITING WITH THE COURT
YOUR DEFENSES OR OBJECTIONS TO THE CLAIMS SET FORTH AGAINST YOU. UNLESS
YOU ACT WITHIN TEN (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/ ode h. -14. UdLch. Jr.
GOLDBECK McCAFFERTY & MCKEHVER
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: KATHRYN M. VOLOVSKI
334 Lowther Street
Lemoyne, PA 17043
GE CAPITAL MORTGAGE SERVS. INC.
4680 Hallmark Parkway
San Bernardino, CA 92407
Plaintiff
VS.
TERRY L. VOLOVSKI AND KATHRYNI
VOLOVSKI (Mortgagor(s))
(Record Owner(s))
334 Lowther Street
Lemoyne, PA 17043 Defendant(s)
IN THE COURT OF COMMON PLEAS
OF CUMBERLAND COUNTY
CIVIL ACTION - LAW
ACTION OF MORTGAGE FORECLOSURE
Term
No. 99-7211 CIVIL
THIS LAW FIRM IS A DEBT COLLECTOR AND WE ARE ATTEMPTING TO COLLECT A
NG THE MATION OBTAINED FROM YOU WILL BE USED
CLIENT. ANY
DEBT OWED TO OUR FOR THE PURPOSE O DEBT.
TO: KATHRYN M. VOLOVSKI
334 Lowther Street
Lemoyne, PA 17043
DATE OF THIS NOTICE: May 26, 2000
IMPORTANT NOTICE
YOU ARE IN DEFAULT BECAUSE YOU HAVE FAILED TO ENTER A WRITTEN
APPEARANCE PERSONALLY OR BY ATTORNEY AND FILE IN WRITING WITH THE COURT
YOUR DEFENSES OR OBJECTIONS TO THE CLAIMS SET FORTH AGAINST YOU. UNLESS
YOU ACT WITHIN TEN (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
C tolWech
/s/ i/oaeu rc
GOLDBECK 24CCAPPERTY & 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
. ,fir a:.:.r",a=!
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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
GE CAPITAL MORTGAGE SERVS. INC
4680 Hallmark Parkway
San Bernardino, CA 92407
Plaintiff
VS.
TERRY L. VOLOVSKI AND KATHRYN M
VOLOVSKI (Mortgagor(s) and
Record owner(s))
334 Lowther Street
Lemoyne, PA 17043
Defendant(s)
: IN THE COURT OF COMMON PLEAS
OF CUMBERLAND COUNTY
CIVIL ACTION - LAW
:ACTION OF MORTGAGE FORECLOSURE
Term
No. 99-7211 CIVIL
PRAECIPE FOR WRIT OF EXECUTION
TO THE PROTHONOTARY:
Issue Writ of Execution in the above matter:
Amount Due
Interest from 3/ 1/99 to
7/31/00 at 8.000%
$ 87.901.22
(Costs to be added) 114 KU
Jo p A. Gol beck, r.
At ey for Plaintiff
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ALL THAT CERTAIN tract or parcel of land and premises, situate, lying and
being in the Borough of Lemoyne in the County of Cumberland and
Commonwealth of Pennsylvania, more particularly described as follows:
BEGINNING at a point on the south (southeast) side of Lowther Street at
the western line of Lot No. 21 on the Plan of Lower Walton lain out by the
Trustee of James McCormick Estate dated October 1, 1915, and recorded
in the Office of the Recorder of Deeds of Cumberland County in Plan Book
No. 1, Page No. 104, said point being 317.8 feet vest of the southwest
corner of Lowther and Third Street (formerly Rossmoyne Street) as shown
on said Plan; thence southeasterly by line of said Lot No. 21 now or late of
Raymond Minnick 217.8 feet to the line of Lot No. 16; thence
southwestwardly by line of said Lot No. 16 on said Plan 50 feet to a point;
thence northwestwardly by a line parallel to the line dividing Lots No. 21 and
22 as shown on said Plan a distance of 217.8 feet to the southern side of
Lowther Street; thence in a northeastwardly direction along the southern
side of said Lowther Street 50 feet to a point, the Place of BEGINNING.
SAID LOT fronting 50 feet on the southern side of Lowther Street and
extending back an even width 217.8 feet and being the eastern 50 feet of
Lot No. 22 on Plan of Lower Walton.
HAVING thereon erected a one and one-half story frame dwelling house
known and numbered as 334 Lowther Street.
IMPROVEMENTS consist of a residential dwelling.
BEING PREMISES: 334 Lowther Street, Lemoyne, PA 17043
SOLD as the property of TERRY L. VOLOVSKI and KATHRYN M
VOLOVSKI
TAX PARCEL #12-22-0822-220
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
GE CAPITAL MORTGAGE SERVS. INC.
4680 Hallmark Parkway
San Bernardino, CA 92407
Plaintiff
Vs.
TERRY L. VOLOVSKI AND KATHRYN M
VOLOVSKI (Mortgagor(s) and
Record Owner(s))
334 Lowther Street
Lemoyne, PA 17043
IN THE COURT OF COMMON PLEAS
OF CUMBERLAND COUNTY
CIVIL ACTION - LAW
:ACTION OF MORTGAGE FORECLOSURE
Term
No. 99-7211 CIVIL
Defendant(s)
AFFIDAVIT PURSUANT TO RULE 3129
GE CAPITAL MORTGAGE SERVS. INC., 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:
334 Lowther Street, Lemoyne, PA 17043
1. Name and address of owner (s) or Reputed Owner(s):
TERRY L. VOLOVSKI
334 Lowther Street
Lemoyne, PA 17043
KATHRYN M. VOLOVSKI
334 Lowther Street
Lemoyne, PA 17043
2. Name and address of Defendant (a) in the judgment:
TERRY L. VOLOVSKI
334 Lowther Street
Lemoyne, PA 17043
KATHRYN M. VOLOVSKI
334 Lowther Street
Lemoyne, PA 17043
3. Name and last known address of every judgment creditor whose
judgment is a record lien on the property to be sold:
4. Name and address of the last recorded holder of every mortgage
of record:
PROVIDENT BANK OF MARYLAND
114 E. Lexington Street
Baltimore, MD 21203-1661
HOUSEHOLD REALTY CORPORATION
26 Gateway Drive, Suite 107
Mechanicburg, PA 17055
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: July 31, 2000 a", ?"GOI K MICA•FERTY KEENER
BY: Jos ph A. Golbeck, JxI., Esq.
Attorney for Plaintiff
V
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
GE CAPITAL MORTGAGE SERVS. INC.
4680 Hallmark Parkway IN THE COURT OF COMMON PLEAS
San Bernardino, CA 92407
Plaintiff OF CUMBERLAND COUNTY
Vs.
TERRY L. VOLOVSKI AND KATHRYN M. :ACTION
VOLOVSKI (Mortgagor(s) and
Record Owner(s))
334 Lowther Street
Lemoyne, PA 17043
Defendant(s)
CIVIL ACTION - LAW
OF MORTGAGE FORECLOSURE
Term
No. 99-7211 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.
TO NOTICE OF SHERIFF'S SALE OF REAL PROPERTY
:
TERRY L. VOLOVSKI
334 Lowther Street
Lemoyne, PA 17043
Your house at 334 Lowther Street, Lemoyne, PA 17043 is
scheduled to be sold at Sheriff's Sale on December 6, 2000, at
10:00 a.m., in Cumberland County, Commissioners Hearing Room, 2nd
Floor, Courthouse, Carlisle,-PA 17013 to enforce the court
judgment of $87,901.22 obtained by GE CAPITAL MORTGAGE SERVS.
INC. against you.
To prevent this Sheriff's Sale you must take immediate
action:
1. The sale will be cancelled if you pay to GE CAPITAL MORTGAGE
SERVS. INC., 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'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.
LLmberland county Bar Association
2 Liberty Avenue, Carlisle, PA
(000) 990-9108
Legal Services Inc.
B Irvine Row, Carlisle, PA 17017
(717) 241.9400
:1
GOLDBECK McCAFFERTY & McKEEVER
BY: Joseph A. Goldbeck, Jr.
Attorney I.D.1116132
Suite 500 - The Bourse Bldg.
111 S. Independence Mall East
Philadelphia, PA 19106
215-627-1322
Attorney for Plaintiff
GE CAPITAL MORTGAGE SERVS. INC.
4680 Hallmark Parkway
San Bernardino, CA 92407
Plaintiff
Vs.
TERRY L. VOLOVSKI AND KATHRYN M.
VOLOVSKI (Mortgagor(s) and
Record Owner(s))
334 Lowther Street
Lemoyne, PA 17043
Defendant(s)
IN THE COURT OF COMMON PLEAS
OF CUMBERLAND COUNTY
CIVIL ACTION - LAW
:ACTION OF MORTGAGE FORECLOSURE
Term
No. 99-7211 CIVIL
THIS LAW FIRM IS A DEBT COLLECTOR AND WE ARE ATTEMPT
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:
KATHRYN M. VOLOVSKI
334 Lowther Street
Lemoyne, PA 17043
Your house at 334 Lowther Street, Lemoyne, PA 17043 is
scheduled to be sold at Sheriff's Sale on December 6, 2000, at
10:00 a.m., in Cumberland County, Commissioners Hearing Room, 2nd
- Floor, Courthouse, Carlisle, PA 17013 to enforce the court
judgment of $87,901.22 obtained by GE CAPITAL MORTGAGE SERVS.
INC. 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
action:
1. The sale will be cancelled if you pay to GE CAPITAL MORTGAGE
SERVS. INC., 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
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GOLDBECK McCAFFERTY & McKEEVER
Joseph A. Goldbeck, Jr.
Attorney I.D.#1 6132
Suite 500 - The Bourse Bldg.
111 S. Independence Mall East
Philadelphia, PA 19106
215-627-1322
Attorney for Plaintiff
GE CAPITAL MORTGAGE SERVS. INC. IN THE COURT OF COMMON PLEAS
4680 Hallmark Parkway
San Bernardino, CA 92407 OF CUMBERLAND COUNTY
Plaintiff
vs. :ACTION
TERRY L. VOLOVSKI AND KATHRYN M.
VOLOVSKI (Mortgagor(s) and
Record Owner(s))
334 Lowther Straet
Lemoyne, PA 17043
Defendant(s)
CIVIL ACTION - LAW
OF MORTGAGE FORECLOSURE
Term
No. 99-7211 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 subject to Act 91 of 1983
and the Plaintiff has complied with all the provisions of the
Act.
Jos hI . Gol eck,
Att, n y for Taint
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GOLDBECK McCAFFERTY & McKEEVER
BY: Joseph A. Goldbeck, Jr.
Attorney I.D.416132
Suite 500 - The Bourse Bldg.
111 S. Independence Mall East
Philadelphia, PA 19106
215-627-1322
Attorney for Plaintiff
GE CAPITAL MORTGAGE SERVS. INC.
4680 Hallmark Parkway
San Bernardino, CA 92407
Plaintiff
VS.
TERRY L. VOLOVSKI AND KATHRYN M.
VOLOVSKI (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
334 Lowther Street No. 99-7211 CIVIL
Lemoyne, PA 17043
Defendant(s)
CERTIFICATE OF SERVICE
PURSUANT TO Pa.R.C.P. 3129.2(c)(2)
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Joseph A. Goldbeck, Jr., Esquire, Attorney for Plaintiff, hereby
certifies that service on the Defendants of the Notice of Sheriff Sale was
mad by:
() Personal Service by the Sheriff's Office/ (copy of
return attached).
( ) Certified mail by Joseph A. Goldbeck, Jr. (original green Postal
return receipt attached).
( ) Certified mail by Sheriff's Office.
( ) 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.
(x ) Premises was posted by Sheriff's Office/fib-ederlt (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 yj subject to the
penalties provided by 18 P.S. Section 49011. n
GOL?¢ECK MdCAFF RTY & M¢KE'E
BY: oseph A. ldbeck,yJr.
Att rney for Plaintiff
P 96.9 031 411
TO:
KATHRYN M.VOLOVSKI
334 Lowther Street
Lemoyne, PA 17043
SENDER: GOLDBECK MCCAFFERTY 6 MCKEEVER • JUIV 31, 2000
REFERENCE: VOLOVSKI,TERRY L. / GCMS-0368
12/ 6/00 - CUMBERLAND
F.
RETURN
RECEIPT
SERVICE
I TWI P.?, "F.
US Postal Service
Receipt for
Certified Mail
40 Insurance Coverage Providec
Do not use for International Mail
:TMARK OR DATE
f
To: •P 969 031 410
TERRY L. VOLOVSKI
334 Lowther Street
Lemoyne, PA 17043
SENDER: GOLDBECK MCCAFFERTY 6 MCKEEVER •JUIy 31, 2000
REFERENCE: VOLOVSKI,TERRY L. / GCMS-0368
12/ 6/00 -CUMBERLAND
c« FPP
RETURN nPe?n RP??q F«
RECEIPT
SERVICE
I TaW PaUp "Fw
US Postal Service
Receipt for
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No Insurance Coverage Providec
Do not use for Intenational Mail
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GE Capital Mortgage Servs. Inc. In the Court of Common Pleas of
-vs- Cumberland County, Pennsylvania
Terry L. Volovski and Kathryn M. No. 1999-7211 Civil
Volovski
Richard E. Smith, Deputy Sheriff, who being duly sworn according to law, says on August 17, 2000
at 6:07 o'clock P.M. EDST, he served a true copy of Real estate Writ Notice and Description in the
above entitled action upon one of the within named defendants to wit: Terry L. Voiovski by making
known unto Terry Volovski at 404 41h Street, New Cumberland, Cumberland County, Pennsylvania, its
contents and at the same time handing to him personally the said true and attested copies of the same.
Richard E. Smith Deputy Sheriff who being duly sworn according to law, says on August 17, 2000
at 6:07 o'clock P.M. EDST, he served a true copy of real Estate Writ Notice and Description in the
above entitled action upon one of the within named defendants to wit: Kathryn M. Volovski by making
known unto Terry Volovski husband at 404 4a' Street, New Cumberland, Cumberland County, its
contents and at the same time handing to him personally the said true and attested copies of the same.
Brian M. Barrick, Deputy Sheriff who being duly sworn according to law, says on October 9, 2000 at
6:40 o'clock P.M. EDST, he [posted a copy of real Estate Writ Notice Poster and Description on the
property of Terry Voiovski and Kathryn Volovski located at 334 Lowther Street, Lemoyne, 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: Terry L. Volovski by regular mail
to his last known address 404 4u` Street, New Cumberland, Pa. This letter was mailed under the date of
October 10, 2000 and never returned to the Sheriff's Office.
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 pendency of the action to one of the within named defendants to wit: Kathryn Volovski by regular
mail to her last known address 404 4'h Street, New Cumberland, Pa. This letter was mailed under the
date of October 10, 2000 and never returned to the Sheriff s Office.
R. Thomas Kline, Sheriff
Real Estate Deputy
GOLDBECK McCAFFERTY & MCKEEVER
BY: Joseph A. Goldbeck, Jr.
Attorney I.D.416132
Suite 500 - The Bourse Bldg.
111 S. Independence Mall East
Philadelphia, PA 19106
2 15 -627 -1322
Attorney for Plaintiff
GE CAPITAL MORTGAGE SERVS. INC
4 680 Hallmark Parkway
San Bernardino, CA 92407
Plaintiff
Vs.
TERRY L. VOLOVSKI AND KATHRYN M
VOLOVSKI (Mortgagor(s) and
Record Owner(s) )
334 Lowther Street
Lemoyne, PA 17043
Defendant(s)
IN THE COURT OF COMMON PLEAS
OF CUMBERLAND COUNTY
CIVIL ACTION - LAW
:ACTION OF MORTGAGE FORECLOSURE
Term
No. 99-7211 CIVIL
AFFIDAVIT PURSUANT TO RULE 3129
GE CAPITAL MORTGAGE SERVS. INC., 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:
334 Lowther Street, Lemoyne, PA 17043
1. Name and address of Owner(s) or Reputed Owner(s) :
TERRY L. VOLOVSKI
334 Lowther Street
Lemoyne, PA 17043
KATHRYN M. VOLOVSKI
334 Lowther Street
Lemoyne, PA 17043
2. Name and address of Defendant(s) in the judgment:
TERRY L. VOLOVSKI
334 Lowther Street
Lemoyne, PA 17043
KATHRYN M. VOLOVSKI
334 Lowther Street
Lemoyne, PA 17043
3. Name and last known address of every judgment creditor whose
judgment is a record lien on the property to be sold:
4. Name and address of the last recorded holder of every mortgage
of record:
PROVIDENT BANK OF MARYLAND
114 E. Lexington Street
Baltimore, MD 21203-1661
HOUSEHOLD REALTY CORPORATION
26 Gateway Drive, Suite 107
Mechanicburg, PA 17055
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: July 31, 2000
GO K KEEVER
BY: Jos ph Esq.
Attorney for Plaintiff
,A
STATE OF PENNSYLVANIA, i
COUNTY OF CUMBERLAND j ss.
1, ------
Robert p Ziegler
Recorder of
Deeds in and for said County and State do hereby certify that the Sheriff's Deed in which ----------------
Secretary of Veterans Affairs
-------- ------- '
------------------------------------------------ is the grantee
the same having been sold to said grantee on the 6th
------------------ ___ day of
--------------------------
December 2000
----------- --------------------------- A. D.,' ------, under and by virtue of a writ--------------
Execution 2nd
------------------------------------------------issued on the -- ---- --
-------------------------
August 2000__
day of __________________________ A. D., _, out of the Court of Comman Pleas of said County as of
Civil
------------------------------°----- -- 1999
----------------------------------------- Term,
Number ___ 7211 _______ at the suit of G _ E __ CApital Mtg Serv Inc
_______________ _
TErry L Volovski & Kathryn M
----------- -- against-- '
277 1140
duly recorded in Sheriffs Deed Book No -------------- Page ___________.
IN TESTIMONY WHEREOF, I have hereunto
set my hand and seal of said office this ___Y -___-_ day
of ------ ? i----------------------- A. D.,,9_e2a?,/
- - Recorder of Deeds
GE Capital Mortgage Servs. Inc.
-vs-
Terry L. Volovski and Kathryn M.
Volovski
in the Court of Common Pleas of
Cumberland County, Pennsylvania
No. 1999-7211 Civil
Richard E. Smith, Deputy Sheriff, who being duly sworn according to law, says on August 17, 2000
at 6:07 o'clock P.M. EDST, he served a true copy of Real estate Writ Notice and Description in the
above entitled action upon one of the within named defendants to wit: Terry L. Volovski by making
known unto Terry Volovski at 404 4`h Street, New Cumberland, Cumberland County, Pennsylvania, its
contents and at the same time handing to him personally the said true and attested copies of the same.
Richard E. Smith Deputy Sheriff who being duly sworn according to law, says on August 17, 2000
at 6:07 o'clock P.M. EDST, he served a true copy of real Estate Writ Notice and Description in the
above entitled action upon one of the within named defendants to wit: Kathryn M. Volovski by making
known unto Terry Volovski husband at 404 4th Street, New Cumberland, Cumberland County, its
contents and at the same time handing to him personally the said true and attested copies of the same.
Brian M. Barrick, Deputy Sheriff who being duly sworn according to law, says on October 9, 2000 at
6:40 o'clock P.M. EDST, he [posted a copy of real Estate Writ Notice Poster and Description on the
property of Terry Volovski and Kathryn Volovski located at 334 Lowther Street, Lemoyne, 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: Terry L. Volovski by regular mail
to his last known address 404 4`h Street, New Cumberland, Pa. This letter was mailed under the date of
October 10, 2000 and never returned to the Sheriff s Office.
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 pendency of the action to one of the within named defendants to wit: Kathryn Volovski by regular
mail to her last known address 404 4`h Street, New Cumberland, Pa. This letter was mailed under the
date of October 10, 2000 and never returned to the Sheriffs Office.
R. Thomas Kline, Sheriff, who being duly swom according to law, says that after due and legal
notice had been given according to law, exposed the above described premises at public venue or outcry
at Court House, Carlisle, Cumberland County, Pennsylvania, on December 6, 2000 and sold the same
for the sum of $ 1.00 to Attorney Jill Winkea for The Secretary of Veterans Affairs, his successors and
assigns. It being the highest bid and best price received for the same. The Secretary of Veterans Affairs
his successors and assigns of 5000 Wissahickon Avenue, Philadelphia, PA being the buyer in this
execution paid to Sheriff R. Thomas Kline the sum of $ 861.50 it being costs.
Sheriff's Costs:
Docketing 30.00
Poundage 17.09
Posting Bills 15.00
Advertising 15.00
Acknowledging Deed 30.00
Auctioneer 10.00
Law Library .50
County 1.00
Mileage 20.46
Certified Mail 1.60
Levy 15.00
Surcharge 30.00
Law Journal 311.90
Patriot News 288.30
Share of Bills 23.15
Distribution of Proceeds 25.00
Sheriff's Deed 27.50
$ 861.50 pd by atty
01/12/01
Sworn and Subscribed To Before Me
This-JS'r4Day oqL?? olcv/
A.D. 71 t?2P« 0.,?
P othonotary
7
So an ??
R. Thomas Kline, Sheriff
By //
Real Estate Deputy
P-
I.S'U 3114.9
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ice. iv6 ??y
GOLDBECK Mc 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
GE CAPITAL MORTGAGE SERVS. INC
4680 Hallmark Parkway
San Bernardino, CA 92407
Plaintiff
Vs.
TERRY L. VOLOVSKI AND KATHRYN M.
VOLOVSKI (Mortgagor(s) and
Record Owner(s))
334 Lowther Street
Lemoyne, PA 17043
Defendant(s)
IN THE COURT OF COMMON PLEAS
OF CUMBERLAND COUNTY
CIVIL ACTION - LAW
:ACTION OF MORTGAGE FORECLOSURE
Term
No. 99-7211 CIVIL
AFFIDAVIT PURSUANT TO RULE 3129
GE CAPITAL MORTGAGE SERVS. INC., 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:
334 Lowther Street, Lemoyne, PA 17043
1. Name and address of owner (s) or Reputed Owner(s):
TERRY L. VOLOVSKI
334 Lowther Street
Lemoyne, PA 17043
KATHRYN M. VOLOVSKI
334 Lowther Street
Lemoyne, PA 17043
2. Name and address of Defendant (s) in the judgment:
TERRY L. VOLOVSKI
334 Lowther Street
Lemoyne, PA 17043
KATHRYN M. VOLOVSKI
334 Lowther Street
Lemoyne, PA 17043
3. Name and last known address of every judgment creditor whose
judgment is a record lien on the property to be sold:
4. Name and address of the last recorded holder of every mortgage
of record:
PROVIDENT BANK OF MARYLAND
114 E. Lexington Street
Baltimore, MD 21203-1661
HOUSEHOLD REALTY CORPORATION
26 Gateway Drive, Suite 107
Mechanicburg, PA 17055
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
alties of 18 Pa. C.S. Section 4904 relating to
ion to authorities.
00 Lk",
*pph ICA FERTY KEEVER
BY: Goldbeck, Esq.
Attorney for Plaintiff
GOLDBECK McCAFFERTY & McKEEVER
BY: Joseph A. Goldbeck, Jr.
Attorney I.D.1116132
Suite 500 - The Bourse Bldg.
111 S. Independence Mall East
Philadelphia, PA 19106
215-627-1322
Attorney for Plaintiff
GE CAPITAL MORTGAGE SERVS. INC.
4680 Hallmark Parkway
San Bernardino, CA 92407
Plaintiff
Vs.
TERRY L. VOLOVSKI AND KATHRYN M
VOLOVSKI (Mortgagor(s) and
Record Owner(s))
334 Lowther Street
Lemoyne, PA 17043
Defendant(s)
IN THE COURT OF COMMON PLEAS
OF CUMBERLAND COUNTY
CIVIL ACTION - LAW
:ACTION OF MORTGAGE FORECLOSURE
Term
No. 99-7211 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
TO:
TERRY L. VOLOVSKI
334 Lowther Street
Lemoyne, PA 17043
Your house at 334 Lowther Street, Lemoyne, PA 17043 is
scheduled to be sold at Sheriff's Sale on December 6, 2000,
10:00 a.m., in Cumberland County, Commissioners Hearing Room,
Floor, Courthouse, Carlisle, PA 17013 to enforce the court
judgment of $87,901-.22 obtained by GE CAPITAL MORTGAGE SERVS.
INC. against you.
To prevent this Sheriff's Sale you must take immediate
action:
at
2nd
1. The sale will be cancelled if you pay to GE CAPITAL MORTGAGE
SERVS. INC., 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
,, r,
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'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 i.f 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.
Cum erland County Oar Association
7 Liberty Avenue, Carlisle, PA
(800) 990-9108
Legal Services Inc.
I Irvine Re.. Carlisle, PA 17013
(717) 243-9400
GOLDBECK McCAFFERTY & McKEEVER
BY: Joseph A. Goldbeck, Jr.
Attorney I.D.416132
Suite 500 - The Bourse Bldg.
111 S. Independence Mall East
Philadelphia, PA 19106
215-627-1322
Attorney for Plaintiff
GE. CAPITAL MORTGAGE SERVS. INC.
4680 Hallmark Parkway IN THE COURT OF COMMON PLEAS
San Bernardino, CA 92407
Plaintiff OF CUMBERLAND COUNTY
Vs. CIVIL ACTION - LAW
TERRY L. VOLOVSKI AND KATHRYN M. :ACTION OF MORTGAGE FORECLOSURE
VOLOVSKI (Mortgagor(s) and
Record Owner(s)) Term
334 Lowther Street No. 99-7211 CIVIL
Lemoyne, PA 17043
Defendant(s)
THIS LAW FIRM IS A DEBT COLLECTOR AND WE ARE ATTEMPT,
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.
TO:
NOTICE OF SHERIFF'S SALE OF REAL PROPERTY
KATHRYN M. VOLOVSKI
334 Lowther Street
Lemoyne, PA 17043
Your house at 334 Lowther Street, Lemoyne, PA 17043 is
scheduled to be sold at Sheriff's Sale on December , 6;-2000, at -
10:00 a.m., in Cumberland County, Commissioners Hearing Room, 2nd
Floor, Courthouse, Carlisle, PA -17013 to enforce the court
judgment of $87,901.22--obtained by GE CAPITAL MORTGAGE SERVS. -
INC. 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
action:
1. The sale will be cancelled if you pay to GE CAPITAL MORTGAGE
SERVS. INC., 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'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 Dar Association
2 Liberty Avenue, Carlisle, PA
(800) 990-9108
Legal Services Inc.
8 Irvine Rov, Carlisle, PA 17013
(717) 241-9400
1'I
' WRIT OF EXECUTION and/or ATTACHMENT
COMMONWEALTH OF PENNSYLVANIA)
COUNTY OF CUMBERLAND) NO. 99-7211
CIVIL ACTION t? Term
TO THE SHERIFF OF Cumberland
COUNTY:
To satisfy the debt, interest and costs due GE Can; rat
Terry L. Volovski and Kathryn M. Volovski (mortgagor(s) and Record Owner(s))
334, Lowther Street, Lemoyne, PA 17043
(1) You are directed to levy upon the property of the detendant(s) and to sell See Legal Descr'pttion(S)
(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
; .
thereof; any Property of the defendant(s) or otherwise disposing
(3) IfProperty of the defendant(s) not levieduponan subjectfoa"achment is found in the possession of anyoneother
-1
than a named garnishee, you are directed tonotify hinuherthat he/she has been added as a garnishee and Is enjoined as above
stated. -
Amount Due_ S87 901 ?2
Interest L.L. 50
Attys Comm- %
Ally Paid $197.84
Plaintiff Paid
Date: AllgL 000
REQUESTING PARTY:
Name Joseph A Goldbeck Jr Esg
Address: Suite 500 -The Bourse Bldg.
ttt
Philadelphia PA 19106
Attorney for: Plaintiff
Telephone: 215-627-1322
Supreme Court ID No. 1 6132
Due Prothy $1.00
Other Costs
Curtis R. Long -
Prothonotary, Civil Division
?bV: /IOir. o
Deputy
:n?.S art:
REAL ESTATE SALE No. 'q
till ?er?
the sheriff levied upon the defendants
interest in the real property situated
C, 61
Cumberland County, Pa., known and numbered as:3aaiz,,??
and more full; described on Exhibit "A" filed with
this writ and by this reference incorporated herein.
'late: °rro gY'
d
THE PATRIOT NEWS
THE SUNDAY PATRIOT NEWS
Proof of Publication
Under Ad No. 587, Approved May 16, 1929
Commonwealth of Pennsylvania, County of Dauphin) ss
James L. Clark being duly sworn according to law, deposes and says:
That he is the Acounts Receivable Manager 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
Markel 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 dally and/or Sunday/ Metro editions which appeared on the 31st day of October and the 7th and 14th
day(s) of November 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 Miscel aneous Book "M",
Volume 14, Page 317.
PUBLICATION .................................. ..........................................
COPY
SALE #9
Sworn to and subobefore re m his 1st day f Dec ber 2000 A.D.
NotariTerry L. Russels ?_
Harrisburg, DaN TARYPUBLIC
My commission Ex 02
Member, Pennsylvania Aolau y commission expires June 6, 2002
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 $ 286.80
Probaling same Notary Fee(s) $ 1.50
Total $ 288.30
Dublisher's Receipt for Advertising Cost
)ublisher of The Patriot-News and The Sunday Patriot-News, newspapers of general
receipt of the aforesaid notice and publication costs and certifies that the same have
By.....
been duly paid.
PROOF OF PUBLICATION OF NOTICE
IN CUMBERLAND LAW JOURNAL
(Under Act No. 587, approved May 16, 1929), P_ L.1784
STATE OF PENNSYLVANIA :
COUNTY OF CUIIIBERLAND :
SS.
Roger M. Morgenthal, Esquire, Editor of the Cumberland Law Journal, of the County
and State aforesaid, being duly sworn, according to law, deposes and says that the Cumberland
Law Journal, a legal periodical published in the Borough of Carlisle in the County and State
aforesaid, was established January 2, 1952, and designated by the local courts as the official legal
periodical for the publication of all legal notices, and has, since January 2, 1952, been regularly
issued weekly in the said County, and that the printed notice or publication attached hereto is
exactly the same as was printed in the regular editions and issues of the said Cumberland Law
Journal on the following dates,
viz:
OCTOBER 27, NOVEMBER 3, 10, 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.
REAL ESTATE BALE NO.
Wnt No. 1999.7211 Civil
GE Capital Mortgage Servs. Inc.
VS.
Terry L. VOlovskl and
Kathryn M. Volovskl
Atty.: Joseph A. Goldbeck. Jr.
ALL THAT CERTAIN tract or par-
cc] of land and premises, situate.
lying and being In the Borough of
i Lemoyne In the County of
Cumberland and Commonwealth of
i Pennsylvania, more particularly de-
scribed as follows:
BEGINNING at a point on the
south (southeast) side of Lowther
Street at the western line of Lot No.
21 on the Plan of L %V r Walton lain
R rer M. Morgenthal, Editor
SWORN TO AND SUBSCRIBED before me this
10 day of NOVEMBER. 2000
NOTARIAL SEAL
LOS E. SNYDe!. Notary Pubic
Coriivis Boro, Cumberland County, PA
My CcmmiWon Expires Mor li 5, 2001