HomeMy WebLinkAbout03-3762
THE LAW OFFICES OF BARBARA A. FEIN, P .C.
Barbara A. Fein I LD. No. 53002
Kristen J. DiPaolo / LD. No. 79992
425 Commerce Drive, Suite 100
Fort Washington, PA 19034
(215) 653-7450
Attorneys for Plaintiff
FAIRBANKS CAPITAL CORP., As
Servicing Agent for TCIF REO 2, LLC,
Plaintiff,
v.
CINDY 1. BOONIE,
Defendant.
CIVIL ACTION
03-9947
0002206803
COURT OF COMMON PLEAS
CUMBERLAND COUNTY
NO. 0.3 - J '7t...')..,.,
C;CJ;[~~
NOTICE
COMPLAINT IN MORTGAGE FORECLOSURE
NOTICIA
YOU HAVE BEEN SUED IN COURT. IF YOU WISH TO DEFEND AGAINST
THE CLAIM:S SET fORTH IN THE FOLlOWING PAGES, YOU MUST TAKE
ACTION WITHIN TWENTY (20) DAYS AFfER TIllS 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 TIiAT IF yOU FAIL TO DO so THE
CASE MAY PROCEED WITHOUT YOU AND A JUDGMENT MAY BE
ENTERED AGAINST YOU BY THE COURT WITHOUT RJRTHER NOTICE
FOR ANY MONEY CLAIMED IN THE COMPLAINT OR FOR ANY OTHER
CLAIM OR RELIEF REQUESTED BY THE PLAINTIFF. YOU MAY WSE
MONEY OR PROPERTY OR OTHER RIGHTS IMPORTANT TO YOU.
YOU SHODID TAKE TillS PAPER TO YOUR LAWYER AT ONCE. IF YOU
DO NOT HAVE A LAWYER OR CANNOT AFFORD ONE, GO TO OR
TELEPHONE THE omCE SET FORTH BELOW TO FIND OUT WHERE YOU
CAN GET LEGAL HELP.
Cumberland County Cowt Administrator
4thAoor
Cumberland County Cowt House:
1 Courthouse Square
Carlisle, PA 17013
(717) 240-6200
LE HAN DEMANDADO A USTED EN LA CORlE. SI USlED QUlERE
DEFENDERSE DE ESTAS DEMANDAS EXPUESTAS EN LAS PAGINAS
SIGUIENrES, USfED TIENE (20) DlAS DEPLAZO APARrIRDE LAFECIIA
DE LADEMANDA Y LA NOTIFICACION. USTED DEBE PRESENT AR UNA
APARIENCIA ESCRITA 0 EN PERSONA 0 POR ABOGAOO Y ARCHIV AR
EN LA CORTE SUS DEFENSAS 0 SUS OBJECIONES A LAS DEMANDAS
ENCONTRA DE SU PERSONA. SEA A VISADQ QUE SI USTED NO SE
DEFIENDE, LA CORTE TOMARA MEDIDAS Y PUEDE ENTRAR UNA
ORDEN CONTRA USTED SIN PREVIO A VISO 0 NOTIFlCACION 0 POR
CUALQIER QUEIA 0 AUVIO QUE ESPEDIDO EN LA PEfICION DE
DEMANDA USTED PUEDE PERDER DINERO, SUS PROPIEDADES 0
OIROS DERECHOS IMPORTANTES PARA USTED.
LLEVE ESTA DEMANDA A UN ABOGADO INMEDIATAMENTE. SI NO
IlENE ABOGADQ 0 SI NO TIENE EL DINERO SUFlCIENTE PARA PAGAR
TAL SERVICIO, VAYA EN PERSONA 0 LLAME POR TELEFONO A LA
OFlCINA CUYA DIRECCION SE ENCUENTRA ESCRITA ABAJO PARA
A VERIGUAR OONDE USTED PUEDE CONSEGUIR ASISTENCIA LEGAL.
Cumberland County Cowt Administrator
4th Aoor
Cumberland County Court House
I Courthouse Square
Carlisle, PA 17013
(717) 240-6200
NOTICE REQUIRED UNDER THE FAIR
DEBT COLLECTION PRACTICES ACT,
15 U.S.C. ~ 1601 (AS AMENDED) AND
THE PENNSYLVANIA UNFAIR TRADE PRACTICES
ACT AND CONSUMER PROTECTION LAW,
73 PA. CON. STAT. ANN. ~ 201, ET SEQ. ("THE ACTS")
To the extent the Acts may apply, please be advised of the following:
1. The amount of the original debt is stated in the Complaint attached hereto.
2. The Plaintiff who is named in the attached Complaint and/or its loan servicing agents are
Creditors to whom the debt is owed.
3. The debt described in the Complaint attached hereto and evidenced by the copies of the
mortgage and note will be assumed to be valid by the Creditor's law firm, unless the
Debtors/Mortgagors, within thirty days after receipt ofthis notice, dispute, in writing, the
validity of the debt or some portion thereof.
4. Ifthe Debtors/Mortgagors notifY the Creditor's law firm in writing within thirty days of the
receipt of this notice that the debt or any portion thereof is disputed, the Creditor's law firm
will obtain verification of the debt and a copy of the verification will be mailed to the Debtor
by the Creditor's law firm.
5. If the Creditor who is named as Plaintiff in the attached Complaint is not the original
Creditor, and if the Debtor/Mortgagor makes written request to the Creditor's law firm within
thirty days from the receipt of this notice, the name and address of the original Creditor will
be mailed to the Debtor by the Creditor's law firm.
6. Written request should be addressed to:
THE LAW OFFICES OF BARBARA A. FEIN, P.e.
Attention: Kristen DiPaolo, Esquire
425 Commerce Drive, Suite 100
Fort Washington, PA 19034
*
THIS LETTER MAY BE CONSTRUED AS AN ATTEMPT TO COLLECT A DEBT
AND ANY INFORMATION OBTAINED WILL BE USED FOR THAT PURPOSE.
CNIL ACTION -- COMPLAINT IN MORTGAGE FORECLOSURE
I. (a) The Plaintiff, Fairbanks Capital Corp., As Servicing Agent ofTCIF REO 2,
LLC, is the holder of a mortgage as below described.
(b) Fairbanks Capital Corp., is a Corporation having been organized under the
laws of the State of Utah and having its principal place of business at 338 South Wanninster Road,
P.O. Box 1900 Hatboro, PA 19040.
(c) Fairbanks Capital Corp. is the loan servicing agent for Plaintiff, maintaining
the business records for the Plaintiff! Mortgagee in the ordinary course and scope of business.
2.
(a)
Defendant Cindy L. Boonie is an individual whose last known address is 17
Birch Street, Mechanicsburg, PA 17055.
(b) Defendant Cindy L. Boonie holds an interest in the subject property as both
a Real Owner and Mortgagor.
(c) If the above named Defendant is deceased, this action shall proceed against
the deceased Defendant's heirs, assigns, successors, administrators, personal representatives and/or
executors through their estate whether the estate is probated.
3. (a) The residential mortgage being foreclosed upon is secured by property located
at 17 Birch Street, Mechanicsburg, within Township of Silver Spring, Cumberland County,
Pennsylvania.
(b) All documents evidencing the residential mortgage have been recorded in the
Recorder of Deeds' Office in Cumberland County, Pennsylvania.
(c) The Mortgage was executed on February 22,2001 and was recorded on March
1,2001 in Mortgage Book 1674, at Page 1261.
(d) The legal description for this parcel is attached and incorporated as Exhibit
"A" (Mortgaged Premises).
(e) The herein named Plaintiff has standing to bring the instant action by virtue
of Assignments of Mortgage, duly and publicly recorded as below:
Assignor: Alliance Funding, a Division of Superior Bank, FSB
Assignee: TCIF REO 2, LLC
Recording Date: As Recorded
(Assignment) Book: As Recorded
At Page: As Recorded
(f) By virtue of Pennsvlvania Rules of Civil Procedure Rule 1147 (I) and
1019(g), and on the basis of envirorunental responsibility, Plaintiff is not obliged to append copies
of the above mentioned publicly recorded documents to this mortgage foreclosure action. These
documents are, however, appended hereto and incorporated herein by reference as Exhibit "B".
4. The mortgage is in default because the Defendants above named failed to timely
tender the monthly payment of $635.78 on January I, 2003, and thereafter failed to make the
monthly payments.
5. As authorized under the mortgage instrument, the loan obligation has been
accelerated.
6. Plaintiff seeks entry of judgment in rem on the following sums:
(a)
(b)
(c)
(d)
(e)
(f)
(g)
Principal balance of mortgage due and owing
$68,188.74
Interest due and owing at the rate of 10.625%
calculated from the default date above stated
through August 1, 2003
4,354.56
Interest will continue to accrue at the per diem
rate of$17.92 through the date on which judgment
in rem is entered in Plaintiff's favor.
Late Charges due and owing under the Note
in accordance with the Mortgage Instrument
222.53
Recoverable Balance
63.26
Other fees allowed under loan documents
14.77
Court Costs and fees as recoverable
under the mortgage terms, estimated
300.00
Attorneys' fees
Calculated as 5% of the principal balance due,
in accordance with the mortgage terms
3,409.44
TOTAL IN REM JUDGMENT SOUGHT BY PLAINTIFF
$76,553.30
7. (a) The attorneys' fees set forth as recoverable at Paragraph 6(g) are in conformity
with Pennsylvania law and the terms of the mortgage, and will be collected in the event of a third-
party purchaser at a Sheriff's Sale onlv.
(b) If the mortgage arrears are to be reinstated or paid.off prior to the Sheriff's
Sale, Plaintiffs actual attorneys' fees (calculated at counsel's hourly rate) will be charged based upon
work actually performed.
8. (a) The original principal balance of the Mortgage is more than Fifty Thousand
($50,000.00) Dollars.
(b) Under ACT 6, 41 P.S. SlOl, et seq., Plaintiff Mortgagee is not obliged to
serve Notice of its Intention to Accelerate the Mortgage by certified mailing prior to its instituting
foreclosure proceedings.
9.
(a)
The subject mortgage is governed by ACT 91 of1983 35 P.S. S l840.40lC,
et seq..
(b) Under Pennsylvania's ACT 91, Plaintiff Mortgagee is obligated to serve the
Defendants with notice of their rights under the "Homeowners Emergency Mortgage Assistance
Program", by regular mailing, prior to initiating foreclosure proceedings. The Plaintiff hereunder
served said Notice upon the defaulting borrower on April 17, 2003.
(c) The Defendant filed a timely application for financial assistance with the
Pennsylvania Housing Finance Agency, same having subsequently been denied and/or having been
deemed ineligible by that Agency.
(d) Appended hereto and incorporated herein by reference as Exhibit "C"is a copy
ofthe Denial Letter.
WHEREFORE, the Plaintiff, respectfully requests:
Entry of judgment in rem against the Defendants above named in the total
amount of$76,553.30 as stated at Paragraph 6, plus all additional interest and
late charges accruing through date of judgment entry; and
Foreclosure and Sheriff's Sale of the subject mortgaged property.
Respectfully Submitted,
THE LAW OFFICES OF BARBARA A. FEIN, P.C.
By:nl.hrYU'A-Q
Barbara A. Fein, Esquire
Attorney for Plaintiff
Attorney J.D. No. 53002
DESCRIPTION
ALL THAT CERTAIN tract of land situate in the Township of Silver Spring, Cumberland County,
Pennsylvania, bounded and described in accordance with a survey and plan thereof made by Ernest J.
Walker, Professional Engineer, dated June 23, 1968 as follows:
BEGINNING at the Northeast corner of Birch Street, 33 feet wide and 50 foot wide right-of-way;
thence extending along the East side of Birch Street North 3 degrees 15 minutes East 53.91 feet to a
corner of Lot No. 13 on the hereinafter mentioned plan of lots; thence along said lot South 86 degrees
45 minutes East 125 feet to an iron pin at a corner of Lot No. 11; thence along said lot South 3 degrees
15 minutes West 53.91 feet to a point on the Northern line of the aforesaid 50 foot wide right-of-way.
Thence along the same North 86 degrees 45 minutes West 125 feet to the point and place of beginning.
BEING Lot No. 12 on a plan of lots known as Silver Spring Development Company, which said plan
is recorded in Plan Book 5, page 30, Cumberland County Records.
Tax Parcel #38-19-1610-016
i EXHIBIT
i A
, rar-;:by CC;":i~y that this is
o' ,.".~~~ c.o.py of the
a true anti CG.. ",OJ"
Oflginal document.
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[Space Above This Un. For Recording Dota)
Prepared by: t JODY DIEHL
ACCOUNT #: 0804713600
MORTGAGE
TInS MORTGAGE ("Security Instroment") is given on FEBRUARY 22, 2001 . The mortgagor
is
CINDY L BOONIE
("Borrower").
This Security Instroment is given to
Alliance Funding, a Division of Superior Bank FSB
which is organized and existing under the laws of The United States
One Ramland Road, Orangeburg, New York 10962
("Lender"). Borrower owes Lender the principal sum of
SIXTY-EIGHT THOUSAND EIGHT HUNDRED AND NO/100 Dollam
(U.S. $ 68,800.00 ). This debt is evidenced by Borrower's note dated the same date as this Security
Instrument ("Note"), which provides for monthly payments, with the full debt, if not paid earlier, due and payable
on MARCH 01, 2031 . This Security Instrument secures to Lender: (a) the repayment of the debt
evidenced by the Note, with interest, and all renewals, extensions and modifications of the Note; (b) the payment
of all other sums, with interest, advanced under paragraph 7 to protect the security of this Security Instroment; and
(c) the perfonnance ofBoIIOwers covenants and agreements under this Security Instroment and the Note. For this
Purpose, Borrower does hereby mortgage, grant and convey to Lender the following described property located
in CUMBERLAND County, Pennsylvania:
,
, and wlwse address is
ID If this box is checked see Schedule A annexed hereto and made a part hereof.
which has the address of 17 BIRCH STREET
MECIlANICSBURG
[City)
[Streetl
,Pennsylvania 17055
[Zip Code)
("Property Address");
PENNSYLVANIA-8ingJe Family.pamdc MooJi'recIle M.. UND'ORM INSTRtJMENT
MG3039A.PAM (lilt 7/rT19f)
ALMU
FORM 3039 9/90 (pcp I 019_)
'.
Ii
,
I
EXHIBIT
f>
I
,
ALL that certain tract of land situate in the Township of Silver Spring, Cumberland County, Pennsylvania,
bounded and described in accordance with a survey and plan thereof made by Ernest J. Walter, Professional
Engineer, dated June 23, 1968 as follows:
BEGINNING at the Northeast corner of Birch Street, 33 feet wide and 50 foot wide right-of-way; thence
extending along the East side of Birch Street North 30 15' East 53.91 feetto a corner of Lot No. 13 on the
hereinafter mentioned plan lots; thence along said lot South 860 45' East 125 feet to an iron pin at a corner of
Lot No. 11; thencefllong said lot South 3015' West 53.91 feet to a point on the Northern line of the aforesaid 50
foot wide right-of-way. Thence along the same North 860 45' West 125 feet to the point and place of beginning.
BEING Lot No. 12 on a plan of Jots known as Silver Spring Development Company, which said plan is recorded
in Plan Book 5, page 30, Cumberland County Records.
Parcel #38-19-1610-016
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TOGETHER WITH all the improvements now or hereafter erected on the property, and all easements,
appurtenances, and fixtures now or hereafter a part of the property. All replacements and additions shall also be
covered by this Security Instrument. All of the foregoing is referred to in this Security Instrument as the
"Property."
BORROWER COVENANTS that BolTOweris lawfully seised of the estate hereby conveyed and has the
right to mortgage, grant and convey the Property and that the Property is unencumbered, except for encumblllJlcos
of record. Borrower warrants and will defend generally the title to the Property against all claims and demands,
subject to any encumbrances of record. .
THIS SECURITY INSTRUMENT combines unifonn covenants for national use and non-uniform
covenants with limited variations by jurisdiction to constitute a unifonnsecurity instrument covering real property.
UNIFORM COVENANTS. Borrower and Lender covenant and agree as follows:
1. Payment ofPrlnefpal and Interest; Prepayment and Late Charges. Borrower shall promptly pay
when due the principal of and interest on the debt evidenced by the Note and any prepayment and late charges due
under the Note!
2. Funds for Taxes and Insurance. Subject to applicable law or to a written waiver by Lender, Borrower
shall pay to Lender on the day moDlhly payments are due under the Note, until the Note is paid in full, a sum
("Funds") for: (a) yearly taxes and assessments which may attain priority over this Security Instrument as a lien
on the Property; (b) yearly leasehold payments or ground rents on the Property, if any; (c) yearly hazard or
property insurance premiums; (d) yearly flood insurance premiums, if any; (e) yearly mortgage insurance
premiums, if any; and (1) any sums payable by Borrower to Lender, in accordance with theprovisions of paragraph
8, in lieu of the payment of mortgage insurance premiums. These items are called "Escrow Items." Lender may,
at any time, collect and hold Funds in an amount not to exceed the maximum amount a lender for a federally
related mortgage loan may require for Borrower's escrow account under the federal Real Estate Settlement
Procedures Act of1974 as amended from time to time, 12 U .S,C. Section 2601 et seq. ("RESP A"), unless another
law that applies to the Funds sets a lesser amount. If so, Lender may, at any time, collect and hold Funds in an
amount not to exceed the lesser amount. Lender may estimate the amount of Funds due on the basis of current data
and reasonable estimates of expenditures offuture Escrow Items or otherwise in accordance with applicable law.
The. Funds shall be held in an institution whose deposits are insured by a federal agency, instrumentality,
or entity (including Lender, if Lender is such an institution) or in any Federal Home Loan Bank. Lender shall apply
the Funds to pay the Escrow Items. Lendermay not charge Borrower for holding and applying the Funds, annually
analyzing the escrow account, or verifYing the Escrow Items, unless Lender pays Borrower interest on the Funds
and applicable law pennits Lender to make such a charge. However, Lender may require BOlTOwer to pay a
one-time charge for an independent real estate tax reporting service used by Lender in connection with this loan,
unless applicable law provides otherwise. Unless an agreement is made or applicable law requires interest to be
paid, Lender shall not be required to pay Borrower any interest or earnings on the Funds. Borrower and Lender
may agree in writing, however, that interest shall be paid on the Funds. Lender shall give to Borrower, without
charge, an annual accounting of the Funds, showing credits and debits to the Funds and the pwpose for which each
debit to the Funds was made. The Funds are pledged as additional security for all sums secured by this Security
Instrument.
If the Funds held by Lender exceed the amounts pennitted to be held by applicable law, Lender shall
account to Borrower for the excess Funds in accordance with the requirements of applicable law. If the amount
of the Funds held by Lender at any time is not sufficient to pay the Escrow Items when due, Lender may so notify
Borrower in writing, and, in such case Borrower shall pay to Lender the amount necessary to make up the
deficiency. Borrower shall make up the deficiency in no more than twelve monthly payments, at Lender's sole
discretion.
PENNSYLV ANIA-Sinslo Family..Pamde MItIFrtdIe Mac UNIfORM INSTRUMENT
MG3039A.PAM (IIR 711.7199)
LOAN 1D: 0804713600
ALMV FORM3039919O(pog<2of9poger}
Upon payment in full of all sums secured by this Security Instrument, Lender shall promptly refund to
Borrower any Funds held by Lender. If, under paragraph 21, Lender shall acquire or sell the Property, Lender,
prior to the acquisition or sale of the Property, shall apply any Funds held by Lender at the time of acquisition or
sale as a credit against the sums secured by this Security Instrument.
3. AppUeatlon ofPaymealll. Unless applicable Jaw provides otherwise, all payments received by Lender
under paragraphs 1 and 2 shall be applied: first, to any prepayment charges due under the Note; second, to amounts
payable under paragraph 2; third, to interest due; fourth, to principal due; and last, to any late charges due under
the Note.
4. Charges; Liens. Borrower shall pay all taxes, assessments, charges, fines and impositions attributable
to the Property which may attain priority over this Security Instrument, and leasehold payments or ground rents,
if any. Borrower shall pay these obligations in the manner provided in paragraph 2, or if not paid in that 1DlIIlJlCl',
BoIIOwer shall pay them on time dim:tly to the peISOI1 owed payment. Borrower shall promptly furnish to Lender
all notices of amounts to be paid under this paragraph. IfBoIIOwermakes these payments directly, Bol1'Ower shall
promptly furnish to Lender receipts evidencing the payments.
Borro~ shall promptly discharge any lien which has priority over this Security Instrument unless
Borrower: (a) agrees in writing to the payment of the obligation secured by the lien in a manner acceptable to
Lender; (b) contests in good faith the lien by, or defends against enforcement of the lien in, legal proceedings
which in the Lender's opinion operate to prevent the enforcement of the lien; or (c) secures from the holder of the
lien an agreement satisfactory to Lender subordinating the lien to this Security Instrument. If Lender determines
that any part of the Property is subject to a lien which may attain priority over this Security Instrument, Lender
may give BOIIOwer a notice identifying the lien. Borrower shall satisfy the Hen or take one ormore of the actions
set forth above within 10 days of the giving of notice.
5. Hazard or Property Insurance. BOl1'Ower shall keep the improvements now existing or hereafter
erected on the Property insured against loss by fire, hazards included within the term "extended coverage" and any
other hazards, including floods or flooding, for which Lender requires insurance. This insurance shall be
maintained in the amounts and for the periods that Lender requires. The insurance carrier providing the insurance
shalI be chosen by Borrower subject to Lender's approval which shall not be unreasonably withheld. IfBoIIOwer
fails to maintain coverage descn'bed above, Lender may, at Lender's option, obtain coverage to protect Lender's
rights in the Property in accordance with paragraph 7.
All insurance policies and renewals shall be acceptable to Lender and shall include a standard mortgage
clause. Lender shalI have the right to hold the policies and renewals. If Lender requires, Borrower shall promptly
give to Lender all receipts of paid premiums and renewal notices. In the event ofloss, Borrower shall give prompt
notice to the insurance carrier and Lender. Lender may make proof of loss if not made promptly by BOIIOwer.
Unless Lender and BOIIOwer otherwise agree in writing, insuranceproceeds shall be applied to restoration
or repair of the Property damaged, if the restoration or repair is economically feasible and Lender's security is not
lessened. If the restoration or repair is not economically feasible or Lender's security would be lessened, the
insurance proceeds shall be applied to the sums secured by this Security Instrument, whether or not then due. with
any excess paid to Borrower. IfBol1'Ower abandons the Property. or does not answer within 30 days a notice from
Lender that the insurance carrier has offered to settle a claim, then Lender may colIect the insurance proceeds.
Lender may use the proceeds to repair or restore the Property or to pay sums secured by this Security Instrument,
whether or not then due. The 30-day period wilI begin when the notice is given.
Unless Lender and BOIIOwer otherwise agree in writing, any application of proceeds to principal shall
not extend or postpone the due date of the monthly payments referred to in paragraphs I and 2 or change the
amount of the payments. If under paragraph 21 the Property is acquired by Lender, Borrower's right to any
insurance policies and proceeds resulting from damage to the Property prior to the acquisition shall pass to Lender
to the extent of the sums secured by this Security Instrument immediately prior to the acquisition.
PENNSYLVANIA..si. F8mi1y-J'aaa" Mltll'ndJe Mac UNIFORM INSTRUMENT
MG3I139A.PAM (IIR 7mm)
LOAN 1D: 0804713600
ALMW' mRM 31139 9190 (pogo J of9 pogw)
6. Oeeupancy, Preservation, Maintenance and Protection of the Property; Borrower's Loan
Application; Leaseholds. Borrowershall occupy ,establish,and use the Property asBorrower's principal residence
within sixty days after the execution of this Security Instrument and sball continue to occupy the Property as
Borrower's principal residence for at least one year after the date of occupancy, unless Lender otherwise agrees
in writing, which consent sball nOl be unreasonably withheld, or unless extenuating circumstances exist which are
beyond Borrower's control. llotrower sball not destroy, damage or impair the Property, allow the Property to
deteriorate, or commit waste on the Property. Borrower shall be in default if any forfeiture action or proceeding,
whether civil or criminal, is begun that in Lender's good faith judgment could result in forfeiture of the Property
or otherwise materia11y impair the lien created by this Security Instrument or Lender's security interest. Borrower
may cure such a default and reinstate, as provided in paragraph 18, by causing the action or proceeding to be
dismissed with a tuling that, in Lender's good faith determination, precludes forfeiture of the Borrower's interest
in the Property or other material impainnent of the lien created by this Security Instrument or Lender's security
interest. Borrower shall also be in default if Borrower, during the loan application process, gave materially false
or inaccurate infonnation or statements to Lender (or failed to provide Lender with any material infonnation) in
connection witS the loan evidenced by the Note, including, but not limited to, representations concerning
Borrower's occupancy of the Property as a principal residence. If this Security Instrument is on a leasehold,
Borrower shall comply 'with all the provisions of the lease. If Borrower acquires fee title to the Property, the
leasehold and the fee title sball not merge unless Lender agrees to the merger in writing.
7. Protection of Lender's Rights In the Property. If Borrower .fails to perfonn the covenants and
agreements contained in this Security Instrument, or there is a legal proceeding that may significantly affect
Lender's rights in the Property (such as a proceeding in bankruptcy, probate, for condemnation or forfeiture or to
enforce laws or regulations), then Lender may do and pay for whatever is necessary to protect the value of the
Property and Lender's rights in the Property. Lender's actions may include paying any sums secured by a lien
which has priority over this Security Instrument, appearing in court, paying reasonable attorneys' fees and entering
on the Property to make repairs. Although Lender may take action under this paragraph 7, Lender does not have
to do so.
Any amounts disbursed by Lender under this paragraph 7 shall become additional debt of Borrower
secured by this Security Instrument. Unless Borrower and Lender agree to other tenns of payment, these amounts
shall bear interest from the date of disbursement at the Note rate and sball be payable, with interest, upon notice
from Lender to Borrower requesting payment.
8. Mortgage Insurance. IfLenderrequired mortgage insurance as a condition of making the loan secured
by this Security Instrument, Borrower shall pay the premiums required to maintain the mortgage insurance in
effect. If, for any reason, the mortgage insurance coverage required by Lender lapses or ceases to be in effect,
Borrower shall pay the premiums required to obtain coverage substantially equivalent to the mortgage insurance
previously in effect, at a cost substantially equivalent to the cost to Borrower of the mortgage insurance previously
in effect, from an alternate mortgage insurer approved by Lender. If substantially equivalent mortgage insurance
coverage is not available, Borrower shall pay to Lender each month a sum equal to one-twelfth of the yearly
mortgage insurance premium being paid by Borrowerwhen the insurance coverage lapsed orceased to be in effect.
Lender will accept, use and retain these payments as a loss reserve in lieu of mortgage insurance. Loss reserve
payments may no longer be required, at the option of Lender, ifmortgage insumnce coverage (in the amount and
for the period that Lender requires) provided by an insurer approved by Lender again becomes available and is
obtained. Borrower shall pay the premiums required to maintain mortgage insurance in effect, or to provide a loss
reserve, until the requirement for mortgage insurance ends in accordance with any written agreement between
Borrower and Lender or applicable law.
9. Inspection. Lender or its agent may make reasonable entries upon and inspections of the Property.
Lender shall give Borrower notice at the time of or prior to an inspection specifying reasonable cause for the
inspection.
10. Condemnation. The proceeds of any award or claim for damages, direct or consequential, in
connection with any condemnation or other taking of any part of the Property, or for conveyance in lieu of
condemnation, are hereby assigned and shaIl be paid to Lender.
PENNSYLVANIA-Single Fomily-F_ _.M.. \JNJFORM INSTRUMENT
MG3039A.PAM (lilt 7n.719J)
LOAN ID: 0804713600
ALMX FORM 3039 919ll Cpo,., 0/9 po,..)
In the event of a total taking of the Property, the proceeds shall be applied to the sums secured by this
Security Instrument, whether or not then due, with any excess paid to Borrower. In the event of a partial taking
of the Property in which the fair market value of the Property immediately before the taking is equal to or greater
than the amount of the sums secured by this Security Instrument immediately before the taking, unless Borrower
and Lender otherwise agree in writing, the sums secured by this Security Instrument shall be reduced by the
amount of the proceeds multiplied by the following fraction: (a) the total amount of the sums secured immediately
before the taking, divided by (b) the fair market value of the Property immediately before the taking. Any balance
shall be paid to Borrower. In the event of a partial taking of the Property in which the fair marltet value of the
Property immediately before the taking is less than the amount of the sums secured immediately before the taking,
unless Borrower and Lender otherwise agree in writing or unless applicable law otherwise provides, the proceeds
shall be applied to the sums secured by this Security Instrument whether or not the sums are then due.
If the Property is abandoned by Borrower, or if, after notice by Lender to Borrower that the condemnor
offers to make an award or settle a claim for damages, Borrower fails to respond to Lender within 30 days after
the date the notice is given, Lender is authorized to collect and apply the proceeds, at its option, either to
restoration or ret>air of the Property or to the sums secured by this Security Instrument, whether or not then due.
Unless Lender and Borrower otherwise agree in writing, any application of proceeds to principal shall
not extend or postpone the due date of the monthly payments referred to in paragraphs I and 2 or change the
amount of such payments. .
11. BorrowerNotReleued; ForbearaneeBy Leader Not a Wmer. Bxtensionofthetime forpayment
or modification of amortization of the sums secured by this Security Instrument granted by Lender to any
successor in interest of Borrower sha11 not operate to release the liability of the original Borrower or Borrower's
successors in interest. Lender shall not be required to commence proceedings against any successor in interest or
refuse to extend time for payment or otherwise modify amortization of the sums secured by this Security
Instrument by reason of any demand made by the original Borrower or Borrower's successors in interest. Any
forbearance by Lender in exercising any right or remedy shall not be a waiver of or preclude the exercise of any
right or remedy.
12. SUeeeS50rs and AssllPU Bound; Joint and Several L1abUlty; Co-slguers. The covenants and
agreements of this Security Instrument shall bind and benefit the successors and assigns of Lender and Borrower,
subject to the provisions of pllllll!l'lPh 17. Borrower's covenants and agreements shall be joint and several. Any
Borrower who co-signs this Security Instrument but does not execute the Note: (a) is co-signing this Security
Instrument only to mortgage, grant and convey that Borrower's interest in the Property under the terms of this
Security Instrument; (b) is not personally obligated to pay the sums secured by this Security Instrument; and ( c)
agrees that Lender and any other Borrower may agree to extend, modify, forbear or make any accommodations
with regard to the terms of this Security Instrument or the Note without that Borrower's consent.
13. Loan Charges. If the l()an secured by this Security Instrument is subjectto a law which sets maximum
loan charges. and that law is finally interpreted so that the interest or other loan charges collected or to be coJlected
in connection with the loan exceed the permitted limits, then: (a) any such loan charge shall be reduced by the
amount necessary to reduce the charge to the per mined limit; and (b) any awns already collected from Borrower
which exceeded permitted limits will be refunded to Borrower. Lender may choose to make this refund by
reducing the principal owed under the Note or by making a direct payment to Borrower. If a refund reduces
principal, the reduction will be treated as a partial prepayment without any prepayment charge under the Note.
PENNSYLV ANlA-SinaIc FlllIily-F...1e _Ie Moo UNIFORM INSTIlUMENT
MGJ03M.PAM (lilt 7127M)
LOAN ID: 0804713600
AIMY FORM 30399/90 (pop 5 of9poges)
14. Notices. Any notice to Borrowerprovided for in this Security Instrument shall be given by delivering
it or by mailing it by first class mail unless applicable law requires use of another method. The notice shall be
directed to the Property Address or any other address Borrower designates by notice to Lender. Any notice to
Lender shall be given by first class mail to Lender's address stated herein or any other address Lender designates
by notice to Borrower. Any notice provided for in this Security Instrument shall be deemed to have been given
to Borrower or Lender when given as provided in this paragraph.
15. GovernlngLaw; Severability. This Security Instrument sha11 be governed by federal law and the law
of the jurisdiction in which the Property is located. In the event that any provision or clause of this Security
Instrument or the Note conflicts with applicable law, such conflict shall not affect other provisions of this Security
Instrument or the Note which can be given effect without the conflicting provisiOn. To this end the provisions of
this Security Instrwnent and the Note are declared to be severable.
16. Borrower's Copy. Borrower shall be given one confonned copy of the Note and of this Security
Instrument.
17. Transfer of the Property or a Beneficial Interest in Borrower. If all or any part of the Property
or any interest ill it is sold or transferred (orif a beneficial interest in Borrower is sold or transfetred and Borrower
is not a natural person) without Lender's prior written consent, Lender may, at its option, mJUire immediate
payment in full of all suins secured by this Security Instrument. However, this option sha11 not be exercised by
Lender if exercise is prohibited by federal law as of the date of this Security Instrument.
IfLenderexercises this option, Lender shall give Borrowernoticeof acceleration. The notice shal1 provide
a period of not less than 30 days &om the date the notice is delivered or mailed within which Bonower must pay
all sums secured by this Security Instrwnent. If Borrower fails to pay these sums prior to the expiration of this
period, Lender may invoke any remedies pennitted by this Security Instrument without further notice or demand
on Borrower.
18. Borrower's RIght to RelDstate. IfBonower meets certain conditions, Borrower shall have the right
to have enforcement of this Security Instrument discontinued at any time prior to the earlier of: (a) 5 days (or such
other period as appliCable law may specify for reinstatement) before sale of the Property pursuant to any power
of sale contained in this Security Instrument; or (b) entry of ajudgment enforcing this Security Instrument. Those
conditions are that Borrower: (a) pays Lender all sums which then would be due under this Security Instrument
and the Note as if no acceleration had occurred; (b) cures any default of any other covenants or agreements; ( c)
pays all expenses incurred in enforcing this Security Instrument, including, but not limited to, reasonable attorneys'
fees; and (d) takes such action as Lender may reasonably require to assure that the lien of this Security Instrument,
Lender's rights in the Property and Borrower's obligation to pay the sums secured by this Security Instrument shall
continue unchanged. Upon reinstatementby Borrower,this Security Instrument and the obligations secured hereby
shall remain fully effective as ifno acceleration had occurred. However, this right to reinstate shall not apply in
the case of acceleration under paragraph 17.
19. Sale of Note; CbangeofLoan Servicer. The Note ora partial interest in the Note (together with this
Security Instrument) may be sold 0lIe or more times without prior notice to Borrower. A sale may result in a
change in the entity (known as the "Loan Servicer") that collects monthly payments due under the Note and this
Security Instrument. There also may be one or more changes of the Loan Serviccr unrelated to a sale of the Note,
If there is a change of the Loan Servicer, Borrower will be given written notice of the change in accordance with
paragraph 14 above and applicable law. The notice will state the name and address of the new Loan Servicer and
the address to which payments should be made. The notice will also contain any other infonnation required by
applicable law.
20. Hazardous Substances. Borrower shall not cause or permit the presence, use, disposal, storage, or
release of any Hazardous Substances on or in the Property. Borrower sha11 not do, nor allow anyone else to do,
anything affecting the Property that is in violation of any Environmental Law. The preceding two sentences shall
not apply to the presence, use, or storage on the Property of small quantities of Hazardous Substances that are
generally recognized to be appropriate to nonnal residential uses and to maintenance of the Property.
PENNSYLVANIA.SingI. F..."y.F..... _Ie M.tcUNlFORMlNSTRUMENT
MG3039A.PAM tlIR 'f1.7/99)
LOAN ID: 0804713600
AUtZ Ii'ORM 3039 9190 (pogo 6 of9 pogo)
Borrower shall promptly give Lenderwritlen notice of any investigation, claim, demand, lawsuit or other
action by any governmental or regulatory agency or private party involving the Property and any Hazardous
Substance or Environmental Law of which Borrower has actual knowledge. If Borrower learns, or is notified by
any governmental or regulatory authority, that any removal or other remediation of any Hazardous Substance
affecting the p[v~ is necessary, Borrower shall promptly take all necessary remedial actions in accordance with
Environmental Law.
As used in this paragraph 20, "Hazardous Substances" are those substances defined as toxic or hazardous
substances by Environmental Law and the following substances: gasoline, kerosene, other flammable or toxic
petroleum products, toxic pesticides and herbicides, volatile solvents, materials containing asbestos or
formaldehyde, and radioactive matllria1s. AB used in this paragraph 20, "Environmental Law" means federal laws
and laws of the jurisdiction where the Property is located that re1ate to health, safety or environmental protection.
NON.UNIFORM COVENANTS. Borrower and Lender further covenant and agree as follows:
21. Acceleration; Remedies, Lender shaD give notice to Borrower prior to acceleration following
Borrower's breach of any covenaut or agreement in this Security Instrument (but not prior to acceleration
under paragra'jlb 17 unless appUcable law provides otberwlse), Lender sball notIfY Borrower of, among
other things: (a) the default; (b) the action required to cure the default; (c) when the default must be cured;
and (d) that faDure to cure the default as specified may result In acceleration of the sums secured by this
Security Instrument, forclosure by judicial Proceedlnll and saleoftheProperty.Lender sbaD further Inform
Borrower of the right to rejllltate after acceleration and the right to assert In the foreclosure proc:eedJng
the non-existence of a default or auy other defense of Borrower to acceleration and foreclosure. If the
default Is not cured as specified, Lender at Its option may require Immedlate payment In full of all sums
secured by this Security Instrument without further demaud and may foreclose tbls Security Instrument
by judicial proceeding. Lender shall be entitled to coUeet all e:xpeDses Incnrred In pursuing the remedies
provided in this paragrapb 21, including, but not limited to, attorneys' fees and costs of title evidence to the
extent permitted by applicable law.
22. Release. Upon payment of allsums secured by this Security Instrument, this Security Instrument and
the estate conveyed shall terminate and become void. After such occurrence, Lender shall discharge and satisfY
this Security Instrument without charge to Borrower. Borrower shall pay any recordation costs.
23. Waivers. Borrower,to the extent pennitted by applicable law, waives and releases any error or defects
in proceedings to enforce this Security Instrument, and hereby waives the benefit of any present or future laws
providing for stay of execution, extension of time, exemption from attachment, levy and sale, and homestead
exemption.
24. Reinstatement Period. Borrowel's time to reinstate provided in paragraph 18 shaH extend to one hoUl'
prior to the commencement of bidding at a sheriff's sale or other sale pursuant to this Security Instrument.
25. Purchase Money Mortgage. If any of the debt secured by this Security Instrument is lent to Borrower
to acquire title to the Property, this Security Instrument shall be a purchase money mortgage.
26. Interest Rate After Judgment. Borrower agrees that the inleIeSt rate payable after a judgment is
entered on the Note or in an action of mortgage foreclosure shall be the rate payable from time to time under the
Note.
27. Riders to tbls Security Instrument. If one or more riders are executed by BolTOwer and recorded
together with this Security Instrument, the covenants and agreements of each such rider shall be incorporated into
and shall amend and supplement the covenants and agreements of this Security Instrument as if the rider(s) were
a part of this Security Instrument.
PENNSYLVANJA.S;ngJ. Punily-r...1e at_Ie Moc \JNIFOllM 1NS'llt\JMENT
MGJ039A.PAM (lIR 7m",>
LOAN 1D:0804713600
ALNA FOllM3f39mo(pop7o/9..,.,J
I
[Check applicable box(es)J
[il Adjustable Rate Rider
o
o
[il
Balloon Rider
Graduated Payment Rider
o Condominium Rider
o
o
o 1-4 Family Rider
Planned Unit Development Rider 0 Biweekly Payment Rider
o Seoond Home Rider
Other(s) [specify] ADDENDUM(S)
Rate Improvement Rider
BY SIGNING BELOW. Borrower accepts and agrees to the terms and covenants contained in this
'ty Instrument and in any ride.r(s) executed by Borrower and recorded with it
u ~ll:
~d'~W\i .
CINDiYLBOONIE
(Seal)
BOITOWer
(Seal)
Borrower
(Seal)
Bonower
(Seal)
Bonower
(Seal)
Borrower
(Seal)
Borrower
PIlNNSYLVANIA-SbosJe 'amny.,_. M_1e MatllNIFOllM INSTRUMENT
MG383'A.PAM (JIR 7/2?M)
LOAN 10:0804713600
ALNB JOIIM 303!1_ (PO.. 801' pagel)
COMMONWEALTH OF PE YLV ANIA,
<:::::J. On Ibis, the ';+~ day of
_ -y uel::?,re:-
to be the pezson(s) whose name(s)
subscribed tothewitbinins1rumentandacknowledged
that~ executed the same for the purposes herein contained.
e..~r{o..iCiU~ty sa:.
before me, ~W~
the undersigned officer, personally appeared
known to me (or satisfactorily proven)
IN WITNESS WHEREOF, I hereunto set my hand an
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\. ' ' ': .;~. . ;
i . MY Co,.,m;f;6I'df1I4!~~pt,:.~,~. ;
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My Conunission expires:
Title of Officer
AFTER RECORDING RETURN TO:
SUPERIOR BANK FSB
ONE RAMllAND ROAD
ORANCEBURG, NY 10962
ATTN: RECORDED DOCUMENTS DEPT.
PENNSYLVANlA.slJll!. _Iy-r..... _ Mac lJl'IIFORM INSTRUMENT
MG3039A.PAM f!IR 7""M)
LOAN 10:0804713600
ALNC FORM 303' 9190 (pogo' .f9 poga)
Received: 6/10/03 8:08AM;
->,; Page3
Jun-lcr.Z003 Oa:46am Fram-
pennSYlvJ=a
Housing Fin;;::ce Agency
I
. '-, POOl/OO! H22
Homeowners' Emergency
Mortgage Assilitance Loan Progralll
~~ 2101 Nonh Front Str't!t:l. P.O. B~ 15106
Harrisburg. PA 17105-5106
Ct)rresn{JJldent!e~ 21()1 North F1'Orlt Srrlter. P.O. Box /$530
Harrisburg. PA.17105.55JO
(717) 780-3940 '.800-342.217 FAX(717) 780 -3995
TTY(717) 78o.J869
510612003
FAIRBANK~
PO BOX 65 ~O
SALT LAKE ITY, UT. 84165
SUBJECT:
CINDY BOONIE
17 BIRCH ST
MECHANICSBURG, PA. 17050
S.S. II: 99~97-2379
Loan #: 2206803
Your app i~alion for a HOMEOWNERS' EMERGENCY MORTGAGE ASSISTANCE LOAN
has beer :lENIED pursuant to Acl91 of 1983, 35 P.S. Section 1680.401-C et seq. andlor
Agenc:y GUidelines 12 pA Code Section 31.201 et seq. for the followin9 reasons:
DELETED IN LENDER'S COpy
You may be antitled to an appeal hearing ~ you disagree with our decision. We must receive a
~ request for a hearing w~hin fifteen (15) days of the postmark dale of Ihis letter. (Appeal
requests must be in writing; a verbal request is not acceptable.) The hearing may be conducted
by a lelephone conference call; therefore, you must include yourlelephone number. Requests
for hearing' musl slate the reason(s) Ihat a hearing is requested and must be senl first cless.
registered or certified mail to: Chief Counsel- Hearing Request, f'HFNHEMAp, 2101 North
Front Stre,,-, P.O. Box 15628, Harrisburg, f'ennsylvania, 17105-5628. The Agenc:y will a\tempt
to schedule ttle hearing within thirty (30) days after the request is received. When sending your
appeal, ple.~e be sure to print YOLlr name legibly and inClude your social security number,
You have a light to be represented by an attomey in connection with your appeal. If you cannot
afford an at.mey you may be eligible for Legal Services representation. You can contact a
L.egal Serv.,~. representadve through the foUowing loll free number: 1-800-732-3545. f'lea.e
be aware tllat scheduling an appeal hearing does not necessarHy stay foreclosure proceedings,
DISCL.OSLRE OF USE OF INFORMATION OBTAINED FROM OUTSIDE SOURCE:
1. Oisclo..", inapplicable.
The Federal Equal Cred~ Opportunl1y Act prohibits cred~ors from discriminating against credtt
"ppllcants on the bll$is of race. color, religion. natlona' origin, sex. marital Slalus. age (provided
that the app ieant has Ihe capacity to enler into a binding contract); becau.e all or part of the
applicant's i ,corne derives from any public assistance program; or because the applicant has in
good fa~h > 'ereised any righl under the Consumer Cred~ Protection Act. The Federal Agenc:y
Ihatadmin oters compliance with this law concerning this creditor is the Federal Trade
Commission, Equai Cred~ Opportunity, Washington, D.C.
Sincerely.
THE PENNSYLVANIA HOUSING FINANCE AGENCY
Homeowners' Emergency Mortgage Assistance Program
~
.
J
EXHIBIT
C
HPREJECT
VERIFICATION
The undersigned, an officer of Fairbanks Capital Corp., the instant Plaintiff, or its
servicing agent. being authorized to make this Verification on behalf of Plaintiff, hereby
verifies that the facts set forth in the foregoing Complaint in Mortgage Foreclosure are taken
from the records maintained by persons supervised by the undersigned who maintain the
business records of the Mortgage held by Plaintiff in the ordinary course of business and that
those facts are true and correct to the best of the knowledge, information and belief of the
undersigned.
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: "'611 \ t) ~
N'~~"'Y ~ ~
Title Foreclosure Supervisor
Company: Fairbanks Capital Corp.
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SHERIFF'S RETURN - REGULAR
CASE NO: 2003-03762 P
COMMONWEALTH OF PENNSYLVANIA:
COUNTY OF CUMBERLAND
FAIRBANKS CAPITAL CORP
VS
BOONIE CINDY L
RICHARD SMITH
, Sheriff or Deputy Sheriff of
Cumberland County,Pennsylvania, who being duly sworn according to law,
says, the within COMPLAINT - MORT FORE
was served upon
BOONIE CINDY L
the
DEFENDANT
, at 1750:00 HOURS, on the 19th day of August
2003
at 17 BIRCH STREET
MECHANICSBURG, PA 17055
by handing to
CINDY L. BOONIE
a true and attested copy of COMPLAINT - MORT FORE
together with
NOTI CE
and at the same time directing Her attention to the contents thereof.
Sheriff's Costs:
Docketing
Service
Affidavit
Surcharge
18.00
6.90
.00
10.00
.00
34.90
So?~ ~~t:~
R. Thomas Kline
08/20/2003
BARBARA FEIN
Sworn and Subscribed to before By:
a-
me this ':(7~ day of
Of':...J- .206l3 A. D.
n ~ (2 7Jv/iLu ~
p~otary .
THE LAW OFFICES OF BARBARA A. FEIN, P.e.
Barbara A. Fein, Esquire / J.D. No. 53002
Kristen D. Little, Esquire / J.D. No. 79992
425 Commerce Drive, Suite 100
Fort Washington, P A 19034
(215) 653-7450
Attorneys for Plaintiff
FAIRBANKS CAPITAL CORP., As
Servicing Agent for TCIF REO 2, LLC,
Plaintiff,
COURT OF COMMON PLEAS
CUMBERLAND COUNTY
v.
NO. 03-3762 Civil Term
CINDY 1. BOONIE,
Defendant.
PRAECIPE FOR JUDGMENT FOR F AlLURE TO ANSWER
AND FOR ASSESSMENT OF DAMAGES
Kindly enter judgment for $89,693.30 in favor of the Plaintiff, Fairbanks Capital Corp., As
Servicing Agent of TCIF REO 2, LLC, and against the Defendant, Cindy 1. Boonie for failure to
file an Answer to Plaintiff's Complaint in Mortgage Foreclosure within twenty (20) days from
service thereof and assess Plaintiff's damages as follows and calculated from those set forth in the
Complaint.
Principal balance of mortgage $68,188.74
Interest due and owing at the rate of 10.625% calculated
from the default date through August 22, 2005
17,794.56
Late Charges due and owing under the Note in
accordance with the Mortgage Instrument
222.53
Recoverable Balance
Other fees allowed under loan documents
63.26
Attorneys' fees
14.77
TOTAL IN REM JUDGMENT TO BE ENTERED
3,409.44
$89,693.30
/
TOTAL IN REM JUDGMENT TO BE ENTERED
$89,693.30
THE LAW OFFICES OF BARBARA A. FEIN, P.C.
BY:
~-Q,
Barbara A. Fein, Esquire
AND NOW, judgment is entered in favor of the Plaintiff, Fairbanks Capital Corp., As
Servicing Agent ofTCIF REO 2, LLC and against the Defendant, Cindy 1. Boonie, and damages
are assessed as above in the swn of$89,693.30.
hnL~
THE LAW OFFICES OF BARBARA A. FEIN, P.e.
Barbara A. Fein, Esquire / I.D. No. 53002
Kristen D. Little, Esquire / I.D. No. 79992
425 Commerce Drive, Suite 100
Fort Washington, PA 19034
(215) 653-7450
Attorneys for Plaintiff
FAIRBANKS CAPITAL CORP., As
Servicing Agent for TCIF REO 2, LLC,
Plaintiff,
COURT OF COMMON PLEAS
CUMBERLAND COUNTY
v.
NO. 03-3762 Civil Term
CINDY BOONIE,
Defendant.
AFFIDAVIT OF NON-MILITARY SERVICE
COMMONWEALTH OF PENNSYL VANIA
COUNTY OF MONTGOMERY
s.s.:
THE UNDERSIGNED being duly sworn, deposes and says that the averments herein are
based upon investigations made and records maintained by us either as Plaintiff or as servicing
agent of the Plaintiff herein named and that the above named Defendant is not in the Military or
Naval Service of the United States of America or its Allies as defined under the Soldiers and
Sailors Civil Relief Act of 1940, as amended, and that the age and last known residence and
employment of the Defendant are as follows:
Defendant
Age
Residence
Employment
Cindy Boonie
Over 18
17 Birch Street, Mechanicsburg, P A 17055
Unknown
Sworn to and s::s \fed
before me this ~
daYOf_~:r< ,2005.
r _/~ i\'(\(A~ ~JkP
Notary Public
~~'
NAME: '~,
TITLE: Limit Si ng Officer
COMPANY: GMAC Mortgage Corporation
Notarial Seal
Brenda Staehle. Notary Public
Pert<aSie Twp., Bucks County 2006
My commiseion Expires Mar, 11. . I
~nnl,,jV8nI8 AssocIation Of Notanes
Mf:!l'Mt:>errco y'
THE LAW OFFICES OF BARBARA A. FEIN, P .C.
Barbara A. Fein, Esquire / I.D. No. 53002
Kristen D. Little, Esquire / I.D. No. 79992
425 Commerce Drive, Suite 100
Fort Washington, PA 19034
(215) 653-7450
Attorneys for Plaintiff
FAIRBANKS CAPITAL CORP., As
Servicing Agent for TCIF REO 2, LLC,
Plaintiff,
COURT OF COMMON PLEAS
CUMBERLAND COUNTY
v.
NO. 03-3762 Civil Term
CINDY L. BOONIE,
Defendant.
CERTIFICATION OF MAILING OF NOTICE UNDER PA. RCP RULE 237.1
The undersigned hereby certifies that a written Notice ofIntention to File a Praecipe for the
Entry of Default Judgment was mailed to the Defendant andlor to their legal counsel of record, if
any, after the default occurred and at least ten (I 0) days prior to the date of the filing of the Praecipe.
Said Notice was sent on the date set forth in the appended copy of the Notice, sent as stated.
Cindy L. Boonie
17 Birch Street,
Mechanicsburg, P A 17055
Dated: August 1,2005
THE LAW OFFICES OF BARBARA A. FEIN, P.C.
BY:
Barbara A. Fein, Esquire
Attorney for Plaintiff
Attorney I.D. No. 53002
THE LAW OFFICES OF BARBARA A. FEIN, P.c.
Barbara A. Fein, Esquire / LD. No. 53002
Kristen D. Little, Esquire / LD. No. 79992
425 Commerce Drive, Suite 100
Fort Washington, PA 19034
(215) 653-7450
Attorneys for Plaintiff
File No. 03-9947
FAIRBANKS CAPITAL CORP., As
Servicing Agent for TCIF REO 2, LLC,
Plaintiff,
COURT OF COMMON PLEAS
CUMBERLAND COUNTY
v.
NO. 03-3762 Civil Term
CINDY 1. BOONIE,
Defendant.
NOTICE OF INTENTION TO TAKE DEFAULT UNDER PA. RCP RULE 237.1
IMPORTANT NOTICE
You are in default because you have failed to enter a written appearance personally or by
attorney and file in writing with the court your defenses or objections to the claims set forth against
you. Unless you act within ten days from the date of this notice, a Judgment may be entered against
you without a hearing and you may lose your property or other important rights.
Lawyer Referral Service (717) 249-3166
Cumberland County Bar Association (800) 990-9108
32 South Bedford Street
Carlisle, P A 17013
NOTIFICACION IMPORTANTE
Usted se encuentra en estado de rebeldia por no haber tornado la accion requirida de su parte en este
case. Al no tornar la accion debida dentro de un termino de diez (10) dias de la fecha de esta
notificacion, el tribuna podra, sin necesidad de cornpararecerusted in corte 0 escucharpreuba alguna,
dictar sentencia en su contra. Usted puede perder bienes y otros derechos irnportantes. Debe Ilevar
esta notificacion a un abogado immediatamente. Si usted no tiene abogado 0 si no tiene dinero
suficiente para tal servicio, vaya en persona 0 Ilame por telefono a la oficina cuya direccion se
encuentra escrita abajo para averiguar donde se puede conseguir assitencia legal:
Lawyer Referral Service (717) 249-3166
Cumberland County Bar Association (800) 990-9108
32 South Bedford Street
Carlisle, P A 17013
Date of Notice: August 1,2005
PERSONS SERVED:
Cindy 1. Boonie
17 Birch Street,
Mechanicsburg, P A 17055
THE LAW OFFICES OF BAR.B.ARA. A. FEIN, P ,C.
BY:
6tJJ..b(jJ~ Q
Batbara A Fein, Esquire
Attorney for Plaintiff
Attorney 1.D. No. 53002
U.S. POSTAL SERVICE
CERTIFICATE OF MAILING
. ix'..ree..!feceinttarnps
or meler POstage WId
past IMrie;. InQuire.,
Postmaster for CUrrent
fee.
MAy BE USED FOR DOMESTIC AND INTERNATIONAL MAIL, DOES NOT
PROVIDE FOR INSURANCE-POSTMASTER
Roo,;,,, From THE LAW OFFICES Of
~ 4l) ~~:: ~';:~~~
-
~".
One piece of Ordinal)' mail addressed to:
.,
';.-.,
l)'
1. Boonie
1 7 Birch Street
Mechanicsburg, P A 17055
r
.. :!115
,~"
PS Form 3817, January 2001
THE LAW OFFICES OF BARBARA A. FEIN, P.e.
Barbara A. Fein, Esquire / J.D. No. 53002
Kristen D. Little, Esquire / J.D. No. 79992
425 Commerce Drive, Suite 100
Fort Washington, PA 19034
(215) 653-7450
Attorneys for Plaintiff
FAIRBANKS CAPITAL CORP., As
Servicing Agent for TCIF REO 2, LLC,
Plaintiff,
COURT OF COMMON PLEAS
CUMBERLAND COUNTY
v.
NO. 03-3762 Civil Term
CINDY 1. BOONIE,
Defendant.
I, Barbara A. Fein, Esquire, Attorney for the Plaintiff, Fairbanks Capital Corp., As Servicing
Agent ofTCIF REO 2, LLC, hereby certifY that the Plaintiff's correct address is 3815 South West
Temple, Salt Lake City, UT 84115, and the last known address of each Defendant is as below.
Cindy 1. Boonie
17 Birch Street,
Mechanicsburg, P A 17055
CERTIFICATION OF ADDRESS
THE LAW OFFICES OF BARBARA A. FEIN, P.C.
BY:
---..> O-Lb~.Q
Barbara A. Fein, Esquire
Attorney for Plaintiff
THE LAW OFFICES OF BARBARA A. FEIN, P.C.
Barbara A. Fein, Esquire / I.D. No. 53002
Kristen D. Little, Esquire / J.D. No. 79992
425 Commerce Drive, Suite 100
Fort Washington, PA 19034
(215) 653-7450
Attorneys for Plaintiff
FAIRBANKS CAPITAL CORP., As
Servicing Agent for TCIF REO 2, LLC,
Plaintiff,
COURT OF COMMON PLEAS
CUMBERLAND COUNTY
v.
NO. 03-3762 Civil Term
CINDY 1. BOONIE,
Defendant.
I, Barbara A. Fein, Esquire, Attorney for the Plaintiff, Fairbanks Capital Corp., As Servicing
Agent ofTCIF REO 2, LLC, hereby certifY that I have served a true and correct copy of the appended
mortgage foreclosure pleadings/papers upon the foIlowing parties at the last known address and/or
upon an attorney of record, as noted:
Cindy 1. Boonie
17 Birch Street,
Mechanicsburg, P A 17055
CERTIFICATE OF SERVICE
THE LAW OFFICES OF BARBARA A. FEIN, P.C.
r-'
BY: OJl:o..LA
Barbara A. Fein, Esquire
Attorney for Plaintiff
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OFFICE OF THE PROTHONOTARY
COURT OF COMMON PLEAS
Cumberland County Court House
I Courthouse Square
Carlisle, P A 17013
CURT LONG, PROTHONOTARY
TO: Cindy 1. Boonie
17 Birch Street, Mechanicsburg, P A 17055
FAIRBANKS CAPITAL CORP., As
Servicing Agent for TCIF REO 2, LLC,
Plaintiff,
COURT OF COMMON PLEAS
CUMBERLAND COUNTY
v.
NO. 03-3762 Civil Term
CINDY 1. BOONIE,
Defendant.
NOTICE
Pursuant to Rule 236 of the Supreme Court of Pennsylvania, you are hereby notified that a
judgment has been entered against you in the above captioned proceeding as indicate below.
OTARY
[XX] Judgment by Default entered
IF YOU HAVE ANY QUESTIONS CONCERNING THIS NOTICE, PLEASE CALL:
BARBARA A. FEIN, ESQUIRE AT (215) 653-7450.
THE LAW OFFICES OF BARBARA A. FEIN, P.C.
Barbara A. Fein, Esquire / l.D. No. 53002
Kristen D. Little, Esquire / l.D. No. 79992
425 Commerce Drive, Suite 100
Fort Washington, PA 19034
(215) 653-7450
Attorneys for Plaintiff
03-9947
FAIRBANKS CAPITAL CORP., As
Servicing Agent for TCIF REO 2, LLC
Plaintiff,
COURT OF COMMON PLEAS
CUMBERLAND COUNTY
v.
NO. 03-3762 Civil Term
CINDY 1. BOONIE,
Defendant.
AFFIDAVIT OF SERVICE
I, Dionne Winstead, Paralegal to Barbara A. Fein, Esquire, Attorney for the Plaintiff,
FAIRBANKS CAPITAL CORP., As Servicing Agent for TCIF REO 2, LLC, hereby certifY that I
have served a true and correct copy of the Notice of Sheriff Sale on the Defendant, CINDY 1.
BOONIE on September 8, 2005, by certified mail, postage pre-paid, and evidenced by the return
receipt executed by the Defendant, CINDY 1. BOONIE, originals of which are attached hereto.
THE LAW OFFICES OF BARBARA A. FEIN, P.C.
BY:
Sworn to before me this
,2005.
~
NOTARIAL SEAL
JOAN BERNSTEIN. Notary Public
Upper Dublin Twp., Montgomery County
My Commission Exoires December 26, 2005
. Complete ~ems 1, 2, and 3. Also complete
Ilem 4 ff Restricted Delivary is desired.
. Prinl your name and address on Ihe reverse
so that we can return the card to you.
. Attach Ihls card 10 Ihe back of Ihe mallplace,
or on Ihe fronl ff space permits.
1. Article Addressed to:
ciildy L. Boonie
17 Birch snet.
Mechanicsburg, FA 17055
2. ArtidI: Number
(II8nofer from -1sbeI)
PS Form 3811, February 2004 I\l" ') )
o Agent
o Add_
,eop?,
DYes
DNa
3. SeNlce Type
~lfIed Mall 0 Exprose Mall
~ Registered 0 Return Receipt lor M..ch."dioo
o Insured Mall 0 C.O.D.
4. RestrIcted Delivery? (Extra Fee) 0 Yes
7005 1160 DODD 9712 6647
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102595-Q2-M-1540
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COMMONWEALTH OF PENNSYLVANIA
COUNTY OF CUMBERLAND
FAIRBANKS CAPITAL CORP., As
Servicing Agent for TCIF REO 2, LLC,
Plaintiff,
COURT OF COMMON PLEAS
NO. 03-3762 Civil Term
v.
CINDY 1. BOONIE,
Defendant.
PRAECIPE TO ISSUE WRIT OF EXECUTION
(MORTGAGE FORECLOSURE)
TO THE PROTHONOTARY:
Kindly issue a Writ of Execution in the above matter, directed to the Sheriff of Cumberland County, against
Cindy 1. Boonie, Defendant, and real property situated at 17 Birch Street, Township of Silver Spring, Cumberland
County, Pennsylvania 17055.
AMOUNT DUE
$89,693.30
INTEREST FROM August 22, 2005
Through December 7, 2005
18,994.03
SUBTOTAL
$108,687.33
COSTS TO BE ADDED
THE LAW OFFICES OF BARBARA A. FEIN, P.C.
BY: 1JCUil{){ (j '--~/"'I
Barbara A. Fein, Esq#re
Attorney J.D. No. 53002
425 Commerce Drive, Suite 100
Fort Washington, PA 19034
(215) 653-7450
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WRIT OF EXECUTION andlor ATTACHMENT
COMMONWEALTH OF PENNSYL VANIA)
COUNTY OF CUMBERLAND)
NO 03-3762 Civil
CIVIL ACTION - LAW
TO THE SHERIFF OF CUMBERLAND COUNTY:
To satisfy the debt, interest and costs due FAIRBANKS CAPITAL CORP., AS SERVICING
AGENT FOR TCIF REO 2, LLC, Plaintiff (s)
From CINDY L. BOONIE
(1) You are directed to levy upon the property of the defendant (s)and to sell SEE LEGAL
DESCRIPTION
(2) You are also directed to attach the property of the defendant(s) not levied upon in the possession
of
GARNISHEE(S) as follows:
and to notify the garnishee(s) that: (a) an attachment has been issued; (b) the garnishee(s) is enjoined from
paying any debt to or for the account of the defendant (s) and from dehvering any property of the defendant
(s) or otherwise disposing thereof;
(3) If property of the defendant(s) not levied upon an subject to attachment is found in the possession
of anyone other than a named garnishee, you are directed to notify him/her that helshe has been added as a
garnishee and is enjoined as above stated.
Amount Due $89,693.30
L.L. $.50
Interest FROM 8122105 THROUGH 1217105 - $18,994.03
Atty's Comm %
Atty Paid $116.90
Plaintiff Paid
Date: AUGUST 30, 2005
Due Prothy $1.00
Other Costs
(Seal)
By:
Deputy
REQUESTING PARTY:
Name BARBARA A. FEIN, ESQUIRE
Address: 425 COMMERCE DRIVE, SUITE 100
FORT WASHINGTON, PA 19034
Attorney for: PLAINTIFF
Telephone: 215-653-7450
Supreme Court ID No. 53002
THE LAW OFFICES OF BARBARA A. FEIN, P.C.
Barbara A. Fein, Esquire I J.D. No. 53002
Kristen D. Little, Esquire I J.D. No. 79992
425 Commerce Drive, Suite 100
Fort Washington, PA 19034
(215) 653-7450
Attorney for Plaintiff
File No.03-9947
FAIRBANKS CAPITAL CORP., As
Servicing Agent for TCIF REO 2, LLC,
Plaintiff,
COURT OF COMMON PLEAS
CUMBERLAND COUNTY
NO. 03-3762 Civil Term
v.
CINDY 1. BOONIE,
Defendant.
AFFIDAVIT UNDER P A. RCP RULE 3129
Fairbanks Capital Corp., As Servicing Agent of TCIF REO 2, LLC, Plaintiff in the above
captioned mortgage foreclosure action, sets forth as of the date the praecipe for the Writ of Execution
was filed, the following information concerning the real property located at 17 Birch Street,
Mechanicsburg, Township of Silver Spring, Cumberland County, Pennsylvania, was true and correct
to the best of its knowledge, information and belief.
1. Name and address of each Owner and/or Reputed Owner:
Cindy 1. Boonie
17 Birch Street, Mechanicsburg, P A 17055
2. Name and address of each Defendant named in the judgment:
Cindy 1. Boonie
17 Birch Street, Mechanicsburg, P A 17055
3. Name and last known address of every judgment creditor whose judgment is a record lien
on the real property to be sold:
None
4. Name and address of the last recorded holder of every mortgage of record:
Fairbanks Capital Corp., As Servicing Agent ofTCIF REO 2, LLC, Plaintiff
3815 South West Temple, Salt Lake City, UT 84115
5. Name and address of every other person or entity which has any record lien on the property:
None
6. Name and address of every other person or entity which has any record interest in the
property and whose interest may be affected by the sale:
Cumberland County Tax Claim Bureau
1 Courthouse Square
Carlisle, P A 17103
Silver Spring Township Authority
6415 Rear Carlisle Pike,
Mechanicsburg, P A 17050
PA American Water Co.
852 Wesley Drive,
Mechanicsburg, PA 17055
Tax Collector: Debra Basehore Wiest
269 Woods Drive
Mechanicsburg, P A 17050
Accounts Receivable Mgmt
PO Box 129
Thorofare, NJ 08086-0129
AT and T Wireless
PO Box 129
Newark, NJ 07101
Bank West INC
PO Box 998
Pierre, SD 57501
Blockbuster
Ste 325
6560 Carlisle Pike
Mechanicsburg, P A 17050
Capital One
PO Box 26094
Glen AIlen, VA 23260
Capital One Bank
PO Box 85167
Richmond, VA 23285
CB and T
Research Department
PO Box 105555
Atlanta, GA 30348-5555
Central P A Oral
220 Cumberland Parkway
Suite 6
Mechanicsburg, P A 17055
Credit Plus Collection Service
2491 Paxton Street
Harrisburg, PA 17110-1010
Credit Protection Association
13355 Noel Road
Dallas, TX 75240
CW Fritz Co
418 Oak Street
Lemoyne, P A 17043
D Justice Thomas A. Placey
104 S Sporting Hill Road
Mechanicsburg, P A 17050
Dr Chris Turnpaugh
6103 Carlisle Pike
Mechanicsburg, PA 17050
Emerge MasterCard
PO Box 105667
Atlanta, GA 30348-5667
Fingerhut Corporation
Cardholder Services
16 Mcleland Road
St Cloud, MN 56303-2198
First National Bank
585 Pilot Road
Las Vegas, NY 89119-3619
First South Bank
1450 Reidville Road
Spartanburg, SC 29301
FM Oppel
145 S Enola Drive
Enola, P A 17025
Freedom Card
PO Box 105555
Atlanta, GA 30348-5555
Giant Food Stores LLC
PO Box 9200
Boston, MA 02209
GMAC Mortgage Corp
500 Enterprise Rd Suite 150
Horsham, P A 19044
HB Taxrnasters
90 Christina Road
New Castle, DE 19720-3118
HBCS
PO Box 15804
Wilmington, DE 19850-5804
Holy Spirit Hospital
503 N 21 st Street
Camp Hill, PA 17011
Household Bank
PO Box 80084
Salinas, CA 93912
IC System Inc
444 Highway 96 East
PO Box 64437
St Paul, MN 55164-0437
James R Gingrich Memorials
568 N Union Street
Middletown, P A 17057
JTH Tax Services LLC
Delinquent Tax Collector
PO Box 327
Mechanicsburg, P A 17055
Kwan Won MD PC
3810 Trindle Road
Camp Hill, P A 17011
Lenk Contracting
Attn. Tanuny Lenk
924 W Trindle Road
Mechanicsburg, P A 17055
Magisterial District Justice
109 Spring Hill Road
Mechanicsburg, P A 17050
Marlin Intergrated
PO Box 8529
Philadelphia, PA 19101-8529
National City Proc
90 Riverdale Rd
Riverdale , NJ 07457
NCO Financial Systems Inc
PO Box 41457
Philadelphia, PA 19101-1457
New Kingstown Auto
Carlisle Pike
Orchard Bank
PO Box 19266
Portland, OR 97280-0266
P A Housing Finance Agency
211 N Front St.,
PO Box 15206
Harrisburg,PA 17105
Peerless Credit Services Inc
PO Box 518
Middletown, P A 17057
Penn Fuel Gas Inc
40 Roadway Drive
Carlisle, P A 17013
Pinnacle Health Hospitals
PO Box 1286
Harrisburg, PA 17108-1286
Progressive
PO Box 7247-0311
Philadelphia, P A 19170-000 I
Quantum Imag and Thera Assoc
PO Box 2226
York, PA 17405-2226
Quantum Imaging and Threap
Billing Office I A93
2527 Cranberry Highway
Wareham, MA 02571-5010
RJM Acquisitions LLC
575 Underhill Blvd Ste 224
Syosset, NY 11791
Seventh Avenue
1112 7th Avenue
Monroe, WI 53566-1364
Sherman Acquisition LP
Resurgent Capital Svcs
PO Box 10587
Greenville, SC 29603-0587
Telecheck Corporate Offices
5251 Wesheirner
Houston, TX 77056
Tru Green Chernlawn
5350 Jaycee Avenue
Harrisburg, PA 17112-4904
US Air Federal Care
1453 Beers School Road
Coraopolis, PA 15108
us Airways Federal Credit Union
PO Box 1289
Moon Twp, PA 15108
WS Carey Electric
1781 Main Street
Lisbum
Mechanicsburg, P A 17055
York Waste Silver Spring
PO Box 1401
York, PA 17405-0126
7. Name and address of every other person of whom the Plaintiffhas knowledge who may have
an interest in the property which may be affected by the sale:
Tenant/Occupant
17 Birch Street
Mechanicsburg, P A 17055
Cumberland County Domestic Relations
13 N. Hanover Street
Carlisle, PA 17013
Commonwealth of Pennsylvania
Department of Welfare
P.O. Box 2675
Harrisburg, P A 17105
Commonwealth of Pennsylvania
Department of Revenue
Inheritance Tax Division
Bureau of Compliance
LCB Clearance/Sheriff
ATTN: Terry Quigley
Department #280946
Harrisburg, P A 17128
The Internal Revenue Service
Special Procedures Branch
Federated Investors Tower
Thirteenth Fl., Suite 1300
1001 Liberty Ave.
Pittsburgh, PA 15222
I verify that the statements made in this Affidavit are true and correct to the best of my
personal knowledge, 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.
Date: August 26, 2005
THE LAW OFFICES OF BARBARA A. FEIN, P.C.
BY:
/J.---'--'
Barbara A. Fein, Es ire
Attorney for Plaint" f
Attorney J.D. No. 53002
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THE LAW OFFICES OF BARBARA A. FEIN, P.e.
Barbara A. Fein, Esquire I J.D. No. 53002
Kristen D. Little, Esquire I J.D. No. 79992
425 Commerce Drive, Suite 100
Fort Washington, P A 19034
(215) 653-7450
Attorney for Plaintiff
File No.03-9947
FAIRBANKS CAPITAL CORP., As
Servicing Agent for TCIF REO 2, LLC,
Plaintiff,
COURT OF COMMON PLEAS
CUMBERLAND COUNTY
NO. 03-3762 Civil Term
v.
CINDY 1. BOONIE,
Defendant.
NOTICE OF SHERIFF'S SALE OF REAL PROPERTY
TO: Cindy 1. Boonie
17 Birch Street,
Mechanicsburg, P A 17055
Your house at 17 Birch Street, Township of Silver Spring, Cumberland County, Pennsylvania is
scheduled to be sold by the Cumberland County Sheriff's Department on December 7, 2005 at the
Cumberland County Court House, I Courthouse Square, Carlisle, Pennsylvania, to enforce the Court
judgment of$89,693.30 obtained by Plaintiff, Fairbanks Capital Corp., As Servicing Agent ofTCIF
REO 2, LLC, against you.
NOTICE OF OWNERS' RIGHTS
YOU MAY BE ABLE TO PREVENT THIS SHERIFF'S SALE
To prevent this Sheriff's Sale, you must take immediate action:
I. This sale will be canceled if you pay to Plaintiff Mortgagee the back payments, late
charges, costs and reasonable attorneys' fees due. To find out how much you must pay, you may call
Dionne Winstead at (215) 653-7450.
2. You may be able to stop the sale by filing a petition asking the Court to strike or open
the Judgment, if the judgment was improperly entered. You may also ask the Court to postpone the
sale for good cause.
3. You may also be able to stop the sale through other legal proceedings.
You may need an attorney to assert your rights. The sooner you contact one, the more chance
you will have of stopping the sale. (See notice below on how to obtain an attorney).
YOU MAY STILL BE ABLE TO SAVE YOUR PROPERTY AND
YOU HAVE OTHER RIGHTS EVEN IF THE SHERIFF'S SALE DOES TAKE PLACE.
1. If the Sheriff's Sale is not stopped, your property wiIl be sold to the highest bidder.
You may find out the price bid by calling Dionne Winstead at (215) 653-7450, or by calling the
Cumberland County Sheriff's Department at (717) 240-6390.
2. You may be able to petition the Court to set aside the sale ifthe bid price was grossly
inadequate compared to the value of your property.
3. The sale will go through only ifthe buyer pays the Sheriff the full amount bid in the
sale. To find out if this has happened, you may call Dionne Winstead at (215) 653-7450, or by
calling the Cumberland County Sheriffs Department at (717) 240-6390.
4. If the amount due from the buyer is not paid to the Cumberland County Sheriff, you
will remain the owner of the property as if the sale had never happened.
5. You have the right to remain in the property until the full amount due is paid to the
Sheriff and the Sheriff gives a deed to the buyer. At that time, the buyer may bring legal proceedings
to evict you.
6. You may be entitled to a share of the money which was paid for your house. A
schedule of distribution of the money bid for your house will be filed by the Cumberland County
Sheriff on or about thirty (30) days from the date of Sheriffs Sale. This schedule will state who will
be receiving that money. The money will be paid out in accordance with this schedule unless
exceptions (reasons why the proposed distribution is wrong) are filed with the Sheriffwithin ten (10)
days after the distribution sheet is posted.
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. IFYOUDONOTHAVE
A LAWYER. GO TO OR TELEPHONE THE OFFICE SET FORTH BELOW. THIS OFFICE
CAN PROVIDE YOU WITH INFORMATION ABOUT HIRING ALA WYER. IF YOU CANNOT
AFFORD TO HIRE A LAWYER. THIS OFFICE MAY BE ABLE TO PROVIDE YOU WITH
INFORMATION ABOUT AGENCIES THAT MAY OFFER LEGAL SERVICES TO ELIGIBLE
PERSONS AT A REDUCED FEE OR NO FEE.
Cumberland County Court Administrator
4th Floor
Cumberland County Court House
I Courthouse Square
Carlisle, P A 17013
(717) 240-6200
,
,
ALL that certain tract of land siluale in the Township of Silver Spring, Cumberland County, Pennsylvania,
bounded and described in accordance with a survey and plan thereof made by Ernest J. Walter, Professional
Engineer, dated June 23, 1968 as follows:
BEGINNING at the Northeast corner of Birch Street, 33 feel wide and 50 fool wide right-at-way; thence
extending along the East side of Birch Street North 30 15' East 53.91 feet to a corner of Lot No. 13 on the
hereinafter mentioned plan lots; thence along said lot Soulh 860 45' East 125 teet to an iron pin at a corner of
Lot No. 11; thence il1on9 said lot South 30 15' West 53.91 feel to a point on the Northern line of the aforesaid 50
fool wide right-of-way. Thence along Ihe same North 860 45' West 125 feet to the point and place of beginning.
BEING Lot No. 12 on a plan of lots known as Silver Spring Developmenl Company. which said plan is recorded
in Plan Book 5, page 30, Cumberland County Records.
Parcel #38-19-1610-016
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THE LAW OFFICES OF BARBARA A. FEIN, P.e.
Barbara A. Fein, Esquire / I.D. No. 53002
Kristen D. Little, Esquire / LD. No. 79992
Jacqueline F. McNally / J.D. No. 201332
425 Commerce Drive, Suite 100
Fort Washington, PA 19034
(215) 653-7450
Attorneys for Plaintiff
FAIRBANKS CAPITAL CORP., As
Servicing Agent for TCIF REO 2, LLC,
Plaintiff,
COURT OF COMMON PLEAS
CUMBERLAND COUNTY
NO. 03-3762 Civil Term
v.
CINDY 1. BOONIE,
Defendant.
PLAINTIFF'S PETITION TO CONTINUE
SHERIFF'S SALE ON REAL PROPERTY
I. The Plaintiff, Select Portfolio Servicing Inc. fi'kla Fairbanks Capital Corp. as
Servicing Agent for TCIF REO 2, LLC filed its Complaint in Mortgage Foreclosure on real property
situated at 17 Birch Street, Township of Silver Spring, Cumberland, against the Defendant Cindy
1. Boorne on August 4, 2003. Judgment in rem was entered against the Defendant, Cindy 1. Boonie,
in the above captioned mortgage foreclosure action on August 22,2005.
2. The Plaintiff initially scheduled its Sheriff's Sale of the said real property with the
Cumberland County Sheriffs Department for December 7, 2005. See Exhibit "A"; Notice of
Sheriffs Sale.
3. On or about September 22, 2005, Cindy 1. Boonie filed a Voluntary Petition under
Chapter 13 ofthe United States Bankruptcy Code in The United States District Court for the Middle
District of Pennsylvania, Harrisburg, under Case No. 05-06491.
4. As a result of the circumstances set forth above, the Plaintiffwas obliged to continue
the initially scheduled Sheriff's Sale to January 4,2006.
5. Tbe Defendant's Bankruptcy case was dismissed by Court Order on November 15,
2005. See Exhibit "B"; Dismissal Order.
6. Further review ofthe case has revealed that service of the with the Writ of Execution
and Notice of Sheriff's Sale was effectuate on September 28, 2005, and was in violation of the
Automatic Stay invoked by the aforesaid Bankruptcy filing. See Exhibit "C"; Affidavit of Service.
7. Plaintiff to requests this Honorable Court grant Plaintiff's Petition to Continue the
Sheriff's Sale from January 4,2006 to March 8, 2006 so that it might now have the opportunity to
reserve Writ of Execution and Notice of Sheriff's Sale.
8. The continuance sought by the PlaintiffwiIl in no way prejudice the Defendant.
WHEREFORE, the Plaintiff respectfully requests that this Honorable Court will continue the
Sheriff's Sale of the subject real property until March 8, 2006, without further advertising costs or
notice and that it will further direct the Sheriff to announce said continuance at the upcoming Sale.
Respectfully Submitted,
THE LAW OFFICES OF BARBARA A. FEIN, P.C.
Barbara A Fein, Esquire
Attorney for Plaintiff
BY:
THE LAW OFFICES OF BARBARA A. FEIN, P.e.
Barbara A. Fein, Esquire / J.D. No. 53002
Kristen D. Little, Esquire / 1.0. No. 79992
425 Commerce Drive, Suite 100
Fort Washington, PA 19034
(215) 653-7450
Attorney for Plaintiff
File No.D3-9947
FAIRBANKS CAPITAL CORP., As
Servicing Agent for TCIF REO 2, LLC,
Plaintiff,
COURT OF COMMON PLEAS
CUMBERLAND COUNTY
NO. 03-3762 Civil Term
v.
CINDY L. BOONIE,
Defendant.
NOTICE OF SHERIFF'S SALE OF REAL PROPERTY
TO: Cindy 1. Boonie
17 Birch Street,
Mechanicsburg, P A 17055
Your house at 17 Birch Street, Township of Silver Spring, Cumberland County, Pennsylvania is
scheduled to be sold by the Cumberland County Sheriffs Department on December 7, 2005 at the
Cumberland County CourtHouse, 1 Courthouse Square, Carlisle, Pennsylvania, to enforce the Court
judgment of$89,693.30 obtained by Plaintiff, Fairbanks Capital Corp., As Servicing Agent ofTCIF
REO 2, LLC, against you.
NOTICE OF OWNERS' RIGHTS
YOU MAY BE ABLE TO PREVENT THIS SHERIFF'S SALE
To prevent this Sheriff's Sale, you must take immediate action:
1. This sale will be canceled if you pay to Plaintiff Mortgagee the back payments, late
charges, costs and reasonable attorneys' fees due. To find out how much you rnust pay, you may call
Dionne Winstead at (215) 653-7450.
2. You may be able to stop the sale by filing a petition asking the Court to strike or open
the Judgment, if the judgment was improperly entered. You may also ask the Court to postpone the
sale for good cause.
3 . You may also be able to stop the sale through other legal proceedings.
Y ournayneed an attorney to assert your rights. The sooner you contact one, the more chance
you will have of stopping the sale. (See notice below on how to obtain an attorney).
YOU MAY STllL BE ABLE TO SAVE YOUR PROPERTY AND
YOU HAVE OTHER RIGHTS EVEN IF THE SHERIFF'S SALE DOES TAKE PLACE.
1. If the Sheriff's Sale is not stopped, your property will be sold to the highest bidder.
You may find out the price bid by calling Dionne Winstead at (215) 653-7450, or by calling the
Cwnberland County Sheriff's Department 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 bid in the
sale. To find out if this has happened, you may call Dionne Winstead at (215) 653-7450, or by
calling the Cumberland County Sheriff's Department at (717) 240-6390.
u
4. If the amount due from the buyer is not paid to the Cumberland County Sheriff, you
will remain the owner of the property as if the sale had never happened.
5. You have the right to remain in the property until the full amount due is paid to the
Sheriff and the Sheriff gives a deed to the buyer. At that time, the buyer may bring legal proceedings
to evict you.
6. You may be entitled to a share of the money which was paid for your house. A
schedule of distribution of the money bid for your house will be filed by the Cumberland County
Sheriff on or about thirty (30) days from the date of Sheriffs Sale. This schedule will state who will
be receiving that money. The money will be paid out in accordance with this schedule unless
exceptions (reasons why the proposed distribution is wrong) are filed with the Sheriffwithin ten (1 0)
days after the distribution sheet is posted.
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7. You may also have otherrights 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 LA WYBR, GO TO OR TELEPHONE THE OFFICE SET FORTH BELOW. THIS OFFICE
CAN PROVIDE YOU WITH INFORMATION ABOUT HIRING ALA WYER. IF YOU CANNOT
AFFORD TO HIRE A LAWYER. THIS OFFICE MAY BE ABLE TO PROVIDE YOU WITH
INFORMATION ABOUT AGENClES THAT MAY OFFER LEGAL SERVICES TO ELIGIBLE
PERSONS AT A REDUCED FEE OR NO FEE.
Cumberland County Court Administrator
4th Floor
Cumberland County Court House
1 Courthouse Square
Carlisle, P A 17013
(717) 240-6200
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ALL that certain tract of land situate in the Township of Silver Spring, Cumberland County, Pennsylvania,
bounded and described in accordance with a survey and plan thereof made by Ernest J, Walter, Professional
Engineer, daled June 23, 1968 as follows:
BEGINNING at the Northeast corner of Birch Street, 33 feet wide and 50 loot wide right-aI-way; thence
extending along the East side of Birch Street North 30 15' East 53.91 leet to a corner of Lot No. 13 on the
hereinafter mentioned plan lots; thence along said lot South 8So 45' East 125 feet to an iron pin at a corner of
Lot No. 11; thencefllong said lot South 30 15' West 53.91 feet to a point on the Northern line of the aforesaid 50
foot wide right-of-way. Thence along the same North 860 45' West 125 feet to the point and place of beginning,
BEING Lot No. 12 on a plari of lots known as Silver Spring Development Company, which said plan is recorded
in Plan Book 5. page 30, Cumberland County Records,
Parcel #38-19-1610-016
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IN THE UNITED STATES BANKRUPTCY COURT
FOR THE MIDDLE DISTRICT OF PENNSYLVANIA
IN RE:
CINDY L. BOONlE,
Debtor
CHAPTER 13
CASE NO: 1-05.bk-06491
GMAC MORTGAGE CORPORATION,
successor in interest to Fairbanks
Capital Corp.,
Movant
v.
11 U.S.c. S 130m)
CINDY 1. BOONIE,
Respondent
CHARLES J. DeHART, III, TRUSTEE,
Additional Respondent
ORDER
Upon consideration of GMAC Mortgage Corporation, successor in interest to Fairbanks
Capital Corp.' Motion to Dismiss, it is hereby ordered that upon failure of Debtor to file an
answer within the time allowed, appear or otherwise respond to the Motion of the above Movant
to Dismiss the Debtor's Chapter 13 Bankruptcy Case with a prospective Bar, it is hereby
ORDERED AND DECREED that:
The Debtor's Chapter 13 Bankruptcy is DISMISSED.
GMAC Mortgage Corporation, successor in interest to Fairbanks Capital Corp. May
proceed with its December 7, 2005 Cumberland County Sheriff Sale of the property located at 17
Birch Street, Township of Silver Spring, Mechanicsburg, Cumberland County, P A, under Docket
Number 03-3762; and
IT IS FURTHER ORDERED that the Respondent/Debtor, Cindy L. Boonie, is barred
from refiling for a period not to exceed one-hundred eighty (180) days from the date of this
order.
By tl1e Com1,
~i1t~~
This electronic order is signed and filed on the same date.
2
Dated: November 15, 2005
---
Fairbanks Capital Corp, as Servicing
Agent for rCIF RE02, LLC
VS
Cindy 1. Boonie
The Court of Common Pleas of
Cumberland County, Pennsylvania
Writ No. 2003-3762 Civil Term
Richard E. Smith, Deputy Sheriff, who being duly sworn according to law, states
that on Sept. 28, 2005 at 8:54 o'clock PM, he served a true copy of the within Real Estate
Writ, Notice of Sheriff's Sale and Description, in the above entitled action, upon the
within named defendant, to wit: Cindy 1. Boonie, by making known unto Cindy 1.
Boonie, personally, at 17 Birch Street, Mechanicsburg, Cumberland County,
Pennsylvania, its contents and at the same time handing to her personally the said true
and correct copy of the same.
Douglas Ruzanski, Deputy Sheriff, who being duly sworn according to law, states
that on October 13,2005 at II :30 o'clock A.M., he posted a true copy of the within Real
Estate Writ, Notice, Poster and Description, in the above entitled action, upon the
property of Cindy 1. Boonie located at 17 Birch Street, Mechanicsburg, Pennsylvania,
according to law.
R. Thomas Kline, Sheriff: who being duly sworn according to law, states 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 the within named
defendant, to wit: Cindy 1. Boonie, by regular mail to her last known address of 17
Birch Street, Mechanicsburg, P A 17055. This letter was mailed under the date of
October 06, 2005 and never returned to the Sheriff's Office.
Sworn and subscribed to before me
s..~rs /.:,~.
,;.-~~...nr.......c -1~
, ,
This _ day of
Prothonotary
R. Thomas Kline, Sheriff
" -L.
2005, A.D.
VERIFICATION
Barbara A. Fein, Esquire, hereby states that she is the Attorney for the Plaintiff in this action,
that she is authorized to make this Aftidavit, and that the statements made in the foregoing Plaintiffs
Petition to Continue Sheriff's Foreclosure Sale on Real Property are true and correct to the best of
her knowledge, information and belief.
The undersigned understands that this statement herein is made subject to the penalties of 18
Pa. C.S.A. Section 4904 relating to unsworn falsification to authorities.
Dated: December 29,2005
THE LAW OFFICES OF BARBARA A. FEIN, P.e.
BY:
Barbara A. Fein, Esquire
Attorney for Plaintiff
Attorney J.D. No. 53002
CU-t0J.LC) .
THE LAW OFFICES OF BARBARA A. FEIN, P.C.
Barbara A. Fein, Esquire I J.D. No. 53002
Kristen D. Little, Esquire I J.D. No. 79992
Jacqueline F. McNally / J.D. No. 201332
425 Commerce Drive, Suite 100
Fort Washington, PA 19034
(215) 653-7450
Attorneys for Plaintiff
FAIRBANKS CAPITAL CORP., As
Servicing Agent for TCIF REO 2, LLC,
Plaintiff,
COURT OF COMMON PLEAS
CUMBERLAND COUNTY
NO. 03-3762 Civil Term
v.
CINDY 1. BOONIE,
Defendant.
PLAINTIFF'S MEMORANDUM OF LAW
IN SUPPORT OF ITS PETITION TO CONTINUE
THE SHERIFF'S SALE OF REAL PROPERTY
Pennsvlvania Rule of Civil Procedure Rule 3129.3 (b) specifically provides that:
If the sale is stayed, continued or postponed or adjourned to a date
certain within one hundred days of the scheduled sale, and public
announcement thereof, including the new sale date, is made to the
bidders assembled at the time and place originaIly fixed for the sale,
no new notice shall be required, but there may be only one such stay,
continuance, postponement or adjournment without new notice.
Further, Rule 3129.3 (a) provides that new notice need not be given under Rule 3129 (2) if a special
order of Court stays, continues, postpones or adjourns a Sheriff's Sale.
In the instant case, the Sheriff's Sale of Real Property was initially scheduled by Plaintifffor
December 7, 2005, and was continued to January 4,2006. The Plaintiff must now seek an Order of
Court to further continue the Sheriffs Sale that it may comply with the notice requirements set forth
at Rule 3129 (c) (3).
The defendant(s) (is/are) in no way prejudiced by the instant Petition for Continuance.
WHEREFORE, the PlaintiffrespectfuIlyrequests that this Honorable Court will continue the
Sheriff's Sale of the subject real property until March 8, 2006, without further advertising costs or
notice and that it will further direct the Sheriffto announce said continuance at the upcoming Sale.
Respectfully Submitted,
THE LAW OFFICES OF BARBARA A. FEIN, P .C.
BY:
wA-U
Barbara A. Fein, Esquire
Attorney for Plaintiff
THE LAW OFFICES OF BARBARA A. FEIN, P.C.
Barbara A. Fein, Esquire / J.D. No. 53002
Kristen D. Little, Esquire / J.D. No. 79992
Jacqueline F. McNally / I.D. No. 201332
425 Commerce Drive, Suite 100
Fort Washington, PA 19034
(215) 653-7450
Attorneys for Plaintiff
FAIRBANKS CAPITAL CORP., As
Servicing Agent for TCIF REO 2, LLC,
Plaintiff,
COURT OF COMMON PLEAS
CUMBERLAND COUNTY
NO. 03-3762 Civil Term
v.
CINDY 1. BOONIE,
Defendant.
CERTIFICATE OF SERVICE
I, Barbara A. Fein, Esquire, counsel for the Plaintiff, Fairbanks Capital Corp., As Servicing
Agent ofTCIF REO 2, LLC, hereby certifY that a true and correct copy of the foregoing Petition to
Continue the Sheriffs Sale was sent by first class mail, postage pre-paid, to the following, on
December 29,2005:
Cindy 1. Boonie
17 Birch Street
Mechanicsburg, P A 17055
FEIN, P.C.
BY:
~().
Barbara A. Fein, Esquire
Attorney for Plaintiff
Attorney LD. No. 53002
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U.S. POSTAL SERVICE
CERTIFICATE OF MAILING
MAY BE USED FOR DOMESTIC AND INTERNATIONAL MAll, DOES NOT
PROVIDE FOR INSURANCE-POSTMASTER
Received Frorr . _
"nilE l..J.Ni OFFiCES OF BARBARA A. FEiN, f::(
4:::5 COMMEF:CE DRIVE, SUITe 100
FnRT WA~HINGmN PA 1Q034
Cindy L. Boonie
17 Birch Street
Mechanicburg, P A 17055
PS Form 3817, January 2001
-
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fri
4
Affix fee here in stamps
or.meler pOstage and
p'ostmark.lflquire,of
postmaster for current
',fel3
,
.
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TIlE LAW OFFICES OF
BARBARA A. FEIN, P.C.
425 Commerce Drive, Suite 100
FortWashington,PA 19034
NEW JERSEY OFFICE
Barbara A. Fein, Esquire
Kristen D. Little, Esquire
Jacqueline F. McNally, Esquire
Phone: (215) 653-7450
Fax: (215) 653-7454
20000 Horizon Way, Suite 900
Mount Laurel, NJ 08054-4318
Members of Pennsylvania
and New Jersey Bars
Direct E-mail: DionneW@lobaf.com
Direct Phone Ex!. 130
Phone: (856) 596-5552
Fax: (856) 596-5589
File Noo 03-9947
December 29,2005
Cindy 1. Boonie
17 Birch Street
Mechanicburg, PA 17055
RE: Fairbanks Capital COJ;p.. as servicing agent for TCIF REO 2.LLC v. Cindv 1. Boonie
Cumberland County Court of Common Pleas No. 03-3762 Civil Term
Petition to Continue Sheriff's Sale of Real Property
situated at 17 Birch Street, Mechanicsburg
Dear Ms. Boonie:
Enclosed please find a true and correct copy of the Plaintiffs Petition to Continue the Sheriff's
Sale of Real Property as well as the supporting Memorandum of Law and proposed Order of the
Court to be presented to the Motion court Presiding judge as the Court may deem practicable.
This Petition has been brought to the Motion Court of Cumberland County, and expedited action
has been requested.
Sincerely,
By:b0L60LL0
Barbara A. Fein, Esquire
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IN THE COURT OF COMMON PLEAS
CUMBERLAND COUNTY, PENNSYLVANIA
'Y
DEe 3 0 200~f.'\
FAIRBANKS CAPITAL CORP., As
Servicing Agent for TCIF REO 2, LLC,
Plaintiff,
NO. 03-3762 Civil Term
v.
CINDY 1. BOONIE,
Defendant.
ORDER
AND NOW, this 3otl. dayof :vu",.-LG\
, 20 el~' , upon consideration
of the Plaintiff, Fairbanks Capital Corp., As Servicing Agent of TCIF REO 2, LLC's Petition to
Continue the Sheriffs Sale on Real Property situated at 17 Birch Street, Township of Silver Spring,
Cumberland, and after notice of the filing of said Petition having been sent to each Defendant at
hislher last known address, it is hereby
ORDERED that the Cumberland County Sheriffs Sale ofthe aforementioned real property
be continued to March 8, 2006, at the location previously noticed on all parties without further
advertising or notice necessary; and it is further
ORDERED that the Cumberland County Sheriff announce said continuance at the Sheriffs
Sale on January 4,2006.
J.
COf: e~ {'la,I.,,( h,
(,ro~'t &o~' <
Ba..rloa,.... J'j., Fe,.
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OS ::130 gOal
i"\"IC";:'. . ',:..:.' :rJl :l0
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:]8!~:.1(:: -{Elli:!
THE LAW OFFICES OF BARBARA A. FEIN, P .C.
Barbara A. Fein, Esquire / LD. No. 53002
Kristen D. Little, Esquire / J.D. No. 79992
Jacqueline F. McNally, Esquire / J.D. No 201332
Suite 100, 425 Commerce Drive
Fort Washington, PA 19034
(215) 653-7450
Attorney for Plaintiff
F AIRBANKS CAPITAL CORP., As
Servicing Agent for TCIF REO 2, LLC,
Plaintiff,
COURT OF COMMON PLEAS
CUMBERLAND COUNTY
v.
NO. 03-3762 Civil Term
CINDY 1. BOONIE,
Defendant.
CERTIFICATION OF NOTICES OF SALE TO LIENHOLDERS
I, Dionne Winstead to Barbara A. Fein, Esquire, attorney for Plaintiff, hereby certifY that
upon information and belief, diligent efforts have been made to ide:ntifY all persons/entities having
mortgages, judgments, liens, or other interest in the subject premis(~s of the foreclosure proceeding,
and that such persons/entities have been sent Notices of Sheriff's Sale (attached hereto as Exhibit
"A") and that said Notices were duly served upon them in accordlmce with Pennsylvania Rule of
Civil Procedure Rule 3129. (Proof of mailing with a postmark date of January 5, 2006 is appended
hereto and incorporated herein by reference as Exhibit "B").
I declare under penalty of peIjury that the foregoing is true and correct.
January 9,2006
FFICES OF BARBARA A. FEIN, P.C.
BY:
/ .. . '\ f r,l t2.
. ..J . <>-'-~'t .
Dionne Winstead, parlllegal "
. to Barbara A. Fein, Esquire
Attorney for Plaintiff
THE LAW OFFICES OF
BARBARA A. FEIN, p.e.
425 Commerce Drive, Suite 100
Fort Washington, P A 19034
NEW JERSEY OFFICE
20000 Horizon Way, Suite 900
Mount Laurel, NJ 08054-4318
Barbara A. Fein, Esquire
Kristen D. Little, Esquire
Phone: (215) 653-7450
Fax: (215) 653-7454
Phone: (856) 596-5552
Fax: (856) 596-5589
Members of Pennsylvania
and New Jersey Bars
Direct E-mail: dionnew@lobaf.com
Direct Phone Ex!. 130
File No. 03-9947
January 4,2006
NOTICE OF CUMBERLAND COUNTY SHERIFF'S SALE
TO: All Parties in Interest and Claimants
Improvements:
Residential Dwelling
OWNER:
Cindy 1. Boonie
Cumberland County
Court of Common Pleas
No. 03-3762 Civil Term
PROPERTY: 17 Birch Street
Township of Silver Spring
County of Cumberland, P A 17055
Please be advised that the above captioned property (and any improvements thereon) is scheduled to be sold by
the Cumberland County Sheriff's Department on March 8, 2006 at the Cumberland County Court House, 1
Courthouse Square, Carlisle, Pennsylvania. This sale is scheduled pursuant to a judgment entered in the amount
of$89,693.30 in the Court of Common Pleas for Cumberland County.
Our records indicate that you may hold a mortgage or judgment on the property which may be extinguished
(removed) by the sale. You may wish to attend the sale to protect your interests.
A schedule of distribution will be filed by the Sheriff on a date specified by the Sheriff not later than thirty (30)
days after the sale. Distribution will be made in accordance with the schedule unless exceptions are filed thereto
within ten (10) days after the filing of the schedule. You may call the Cumberland County Sheriff's Department
at (717) 240-6390 for the date on which the distribution schedule will be posted.
Sincerely,
THE LAW OFFICES OF BARBARA A. FEIN, P.C.
Barbara A. Fein, Esquire
Attorney for Plaintiff
.
.
BY:
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ALL that certain tract of land situate in the Township of Silver Spring, Cumberland County, Pennsylvania,
bounded and described in accordance with a survey and plan thereof made by Ernest J. Walter, Professional
Engineer, dated June 23, 1968 as follows:
BEGINNING at the Northeast corner of Birch Street, 33 feet wide and 50 foot wide right-of-way; thence
extending alonglhe East side of Birch Street North 3. 15' East 53.91 feet to a corner of Lot No. 13 on the
hereinafter mentioned plan lots; thence along said lot South 86' 45' East 125 :feet to an iron pin at a corner of
Lot No. 11; thence jllong said lot South 3. 15' West 53.91 feet to a point on the Northern line of the aforesaid 50
foot wide right-of-way. Thence along the same North 86' 45' West 125 feel to the point and place of beginning.
BEING Lot No. 12 on a plari of lots known as Sliver Spring Development Company, which said plan is recorded
in Plan Book 5, page 30, Cumberland County Records.
Parcel #38-19-1610-016
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C) ::<
COMMONWEALTH OF PENNSYLVANIA
COUNTY OF CUMBERLAND } SS:
I, Robert P. Ziegler, Recorder of Deeds in and for said County and State do hereby certify that
the Sheriff's Deed in which TCIF RE02 LLC is the grantee the same having been sold to said grantee on
the 8th day of March A.D., 2006, under and by virtue of a writ Execution issued on the 30th day of Aug,
A.D., 2005, out of the Court of Common Pleas of said County as of Civil Term, 2003 Number 3762, at
the suit of Fairbanks Capital Com agent for TCIF REO 2 LLC against Cindy L Boonie is duly recorded
in Deed Book No. 273, Page 3683.
IN TESTIMONY WHEREOF, I have hereunto set my hand
&9-1l:
and seal of said office this
day of
~ ,A.D. ;)&0 ~
ecorder 0 eds
EJcPno Ite '= ~:2yC:J:- ~
,
Fairbanks Capital Corp, as Servicing
Agent for TCIF RE02, LLC
VS
Cindy 1. Boonie
The Court of Common Pleas of
Cumberland County, Pennsylvania
Writ No. 2003-3762 Civil Term
Richard E. Smith, Deputy Sheriff, who being duly sworn according to law, states
that on Sept. 28, 2005 at 8:54 o'clock PM, he served a true copy of the within Real Estate
Writ, Notice of Sheriff's Sale and Description, in the above entitled action, upon the
within named defendant, to wit: Cindy L. Boorne, by making known unto Cindy L.
Boonie, personaIly, at 17 Birch Street, Mechanicsburg, Cumberland County,
Pennsylvania, its contents and at the same time handing to her personally the said true
and correct copy of the same.
Douglas Ruzanski, Deputy Sheriff, who being duly sworn according to law, states
that on October 13, 2005 at 11 :30 o'clock A.M., he posted a true copy of the within Real
Estate Writ, Notice, Poster and Description, in the above entitled action, upon the
property of Cindy L. Boonie located at 17 Birch Street, Mechanicsburg, Pennsylvania,
according to law.
R. Thomas Kline, Sheriff, who being duly sworn according to law, states 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 the within named
defendant, to wit: Cindy 1. Boonie, by regular mail to her last known address of 17
Birch Street, Mechanicsburg, P A 17055. This letter was mailed under the date of
October 06, 2005 and never returned to the Sheriff's Office.
R. Thomas Kline, Sheriff, who being duly sworn according to law, states that
after due and legal notice had been given according to law, he exposed the within
described premises at public venue or outcry at the Courthouse, Carlisle, Cumberland
County, Pennsylvania on March 08, 2006 at 10:00 o'clock A.M. He sold the same for the
sum of $1.00 to Attorney Barbara Fein for TCIF RE02, LLC. It being the highest bid
and best price received for the same, TCIF RE02, LLC of 500 Enterprise Road, Suite
150, Horsham, PA 19044, being the buyer in this execution, paid to SheriffR. Thomas
Kline the sum of$825.93.
Sheriff's Costs:
Docketing
Poundage
Posting Bills
Advertising
Acknowledging Deed
Auctioneer
$30.00
15.80
15.00
15.00
30.00
10.00
,
Law Library
Prothonotary
Mileage
Certified Mail
Levy
Surcharge
Postage
Postpone Sale
Law Journal
Patriot News
Share of Bills
Distribution of Proceeds
Sheriff's Deed
.50
1.00
19.20
3.49
15.00
20.00
.74
20.00
257.00
287.81
20.89
25.00
39.50
$ 825.93
Sworn and subscribed to before me
2006, A.D.
So Answers:
r~~~~
R. Thomas Kline, Sheriff
BYJOfti )vvul1
Real Estate S rgeant
~~
30' /TO
,:{U
c.t 5".5'1/1 1
~. '1111!
,
.
.
;
THE LAW OFFICES OF BARBARA A. FEIN, P.C.
Barbara A. Fein, Esquire / I.D. No. 53002
Kristen D. Little, Esquire / J.D. No. 79992
425 Commerce Drive, Suite 100
Fort Washington, PA 19034
(215) 653-7450
Attorney for Plaintiff
File No.03-9947
FAIRBANKS CAPITAL CORP., As
Servicing Agent for TCIF REO 2, LLC,
Plaintiff,
COURT OF COMMON PLEAS
CUMBERLAND COUNTY
NO. 03-3762 Civil Term
v.
CINDY 1. BOONIE,
Defendant.
AFFIDAVIT UNDER P A. RCP RULE 3129
Fairbanks Capital Corp., As Servicing Agent ofTCIF REO 2, LLC, Plaintiff in the above
captioned mortgage foreclosure action, sets forth as of the date the praecipe for the Writ of Execution
was filed, the following information concerning the real property located at 17 Birch Street,
Mechanicsburg, Township of Silver Spring, Cumberland County, Pennsylvania, was true and correct
to the best of its knowledge, information and belief.
1. Name and address of each Owner and/or Reputed Owner:
Cindy 1. Boonie
17 Birch Street, Mechanicsburg, P A 17055
2. Name and address of each Defendant named in the judgment:
Cindy 1. Boonie
17 Birch Street, Mechanicsburg, P A 17055
3. Name and last known address of every judgment creditor whose judgment is a record lien
on the real property to be sold:
None
4. Name and address of the last recorded holder of every mortgage of record:
Fairbanks Capital Corp., As Servicing Agent ofTCIF REO 2, LLC, Plaintiff
3815 South West Temple, Salt Lake City, UT 84115
5. Name and address of every other person or entity which has any record lien on the property:
None
6. Name and address of every other person or entity which has any record interest in the
property and whose interest may be affected by the sale:
Cumberland County Tax Claim Bureau
1 Courthouse Square
Carlisle, PA 17103
Silver Spring Township Authority
6415 Rear Carlisle Pike,
Mechanicsburg, P A 17050
P A American Water Co.
852 Wesley Drive,
Mechanicsburg, P A 17055
Tax CoIlector: Debra Basehore Wiest
269 Woods Drive
Mechanicsburg, P A 17050
Accounts Receivable Mgmt
PO Box 129
Thorofare, NJ 08086-0129
AT and T Wireless
PO Box 129
Newark, NJ 07101
Bank West INC
PO Box 998
Pierre, SD 57501
,
Blockbuster
Ste 325
6560 Carlisle Pike
Mechanicsburg, P A 17050
Capital One
PO Box 26094
Glen Allen, VA 23260
Capital One Bank
PO Box 85167
Richmond, VA 23285
CB and T
Research Department
PO Box 105555
Atlanta, GA 30348-5555
Central P A Oral
220 Cumberland Parkway
Suite 6
Mechanicsburg, P A 17055
Credit Plus Collection Service
2491 Paxton Street
Harrisburg, P A 1711 0-1 01 0
Credit Protection Association
13355 Noel Road
Dallas, TX 75240
CW Fritz Co
418 Oak Street
Lemoyne, P A 17043
D Justice Thomas A. Placey
104 S Sporting HiIl Road
Mechanicsburg, P A 17050
Dr Chris Turnpaugh
6103 Carlisle Pike
Mechanicsburg, P A 17050
Emerge MasterCard
PO Box 105667
Atlanta, GA 30348-5667
Fingerhut Corporation
Cardholder Services
16 Mcleland Road
St Cloud, MN 56303-2198
First National Bank
585 Pilot Road
Las Vegas, NY 89119-3619
First South Bank
1450 Reidville Road
Spartan burg, SC 29301
PM Oppel
145 S Enola Drive
Enola, P A 17025
Freedom Card
PO Box 105555
Atlanta, GA 30348-5555
Giant Food Stores LLC
PO Box 9200
Boston, MA 02209
GMAC Mortgage Corp
500 Enterprise Rd Suite 150
Horsham, P A 19044
HB Taxrnasters
90 Christina Road
New Castle, DE 19720-3118
HBCS
PO Box 15804
Wilmington, DE 19850-5804
Holy Spirit Hospital
503 N 21st Street
Camp Hill, P A 17011
Household Bank
PO Box 80084
Salinas, CA 93912
IC System Inc
444 Highway 96 East
PO Box 64437
St Paul, MN 55164-0437
James R Gingrich Memorials
568 N Union Street
Middletown, P A 17057
JTH Tax Services LLC
Delinquent Tax Collector
PO Box 327
Mechanicsburg, PA 17055
KwanWon MDPC
3810 Trindle Road
Camp Hill, PA 17011
Lenk Contracting
Attn. Tammy Lenk
924 W Trindle Road
Mechanicsburg, PA 17055
Magisterial District Justice
109 Spring Hill Road
Mechanicsburg, P A 17050
Marlin Intergrated
PO Box 8529
Philadelphia, PA 19101-8529
National City Proc
90 Riverdale Rd
Riverdale , NJ 07457
NCO Financial Systems Inc
PO Box 41457
Philadelphia, PA 19101-1457
New Kingstown Auto
Carlisle Pike
Orchard Bank
PO Box 19266
Portland, OR 97280-0266
P A Housing Finance Agency
211 N Front St.,
PO Box 15206
Harrisburg,P A 17105
Peerless Credit Services Inc
PO Box 518
Middletown, PA 17057
Penn Fuel Gas Inc
40 Roadway Drive
Carlisle, P A 17013
Pinnacle Health Hospitals
PO Box 1286
Harrisburg, PA 17108-1286
Progressive
PO Box 7247-0311
Philadelphia, PA 19170-0001
Quantum Imag and Thera Assoc
PO Box 2226
York, PA 17405-2226
Quantum Imaging and Threap
Billing Office / A93
2527 Cranberry Highway
Wareham, MA 02571-5010
RJM Acquisitions LLC
575 Underhill Blvd Ste 224
Syosset, NY 11791
Seventh Avenue
1112 7th Avenue
Monroe, WI 53566-1364
Sherman Acquisition LP
Resurgent Capital Svcs
PO Box 10587
Greenville, SC 29603-0587
Telecheck Corporate Offices
5251 Wesheimer
Houston, TX 77056
Tru Green Chemlawn
5350 Jaycee Avenue
Harrisburg, P A 17112-4904
US Air Federal Care
1453 Beers School Road
Coraopolis, PA 15108
US Airways Federal Credit Union
PO Box 1289
Moon Twp, PA 15108
WS Carey Electric
1781 Main Street
Lisburn
Mechanicsburg, P A 17055
York Waste Silver Spring
PO Box 1401
York, PA 17405-0126
7. Name and address of every other person of whom the Plaintiffhas knowledge who may have
an interest in the property which may be affected by the sale:
Tenant/Occupant
17 Birch Street
Mechanicsburg, P A 17055
Cumberland County Domestic Relations
13 N. Hanover Street
Carlisle, PA 17013
Commonwealth of Pennsylvania
Department of Welfare
P.O. Box 2675
Harrisburg, P A 17105
Commonwealth of Pennsylvania
Department of Revenue
Inheritance Tax Division
Bureau of Compliance
LCB Clearance/Sheriff
ATTN: Terry Quigley
Department #280946
Harrisburg, PA 17128
The Internal Revenue Service
Special Procedures Branch
Federated Investors Tower
Thirteenth Fl., Suite 1300
1001 Liberty Ave.
Pittsburgh, PA 15222
I verifY that the statements made in this Affidavit are true and correct to the best of my
personal knowledge, 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.
~
Date: August 26, 2005
THE LAW OFFICES OF BARBARA A. FEIN, P.C.
BY:
frL IM< q,;,=.
Barbara A. Fein, Es 're
Attorney for Plain .
Attorney LD. No. 53002
.
THE LAW OFFICES OF BARBARA A. FEIN, P .C.
Barbara A. Fein, Esquire / J.D. No. 53002
Kristen D. Little, Esquire / I.D. No. 79992
425 Commerce Drive, Suite 100
Fort Washington, PA 19034
(215) 653-7450
Attorney for Plaintiff
File No.03-9947
FAIRBANKS CAPITAL CORP., As
Servicing Agent for TCIF REO 2, LLC,
Plaintiff,
COURT OF COMMON PLEAS
CUMBERLAND COUNTY
NO. 03-3762 Civil Term
v.
CINDY 1. BOONIE,
Defendant.
NOTICE OF SHERIFF'S SALE OF REAL PROPERTY
TO: Cindy 1. Boonie
17 Birch Street,
Mechanicsburg, P A 17055
Your house at 17 Birch Street, Township of Silver Spring, Cumberland County, Pennsylvania is
scheduled to be sold by the Cumberland County Sheriff's Department on December 7, 2005 at the
Cumberland County Court House, 1 Courthouse Square, Carlisle, Pennsylvania, to enforce the Court
judgment of$89,693.30 obtained by Plaintiff, Fairbanks Capital Corp., As Servicing Agent ofTCIF
REO 2, LLC, against you.
4
"
NOTICE OF OWNERS' RIGHTS
YOU MAY BE ABLE TO PREVENT THIS SHERIFF'S SALE
To prevent this Sheriff's Sale, you must take immediate action:
1. This sale will be canceled if you pay to Plaintiff Mortgagee the back payments, late
charges, costs and reasonable attorneys' fees due. To find out how much you must pay, you may call
Dionne Winstead at (215) 653-7450.
2. You may be able to stop the sale by filing a petition asking the Court to strike or open
the Judgment, if the judgment was improperly entered. You may also ask the Court to postpone the
sale for good cause.
3 . You may also be able to stop the sale through other legal proceedings.
You may need an attorney to assert your rights. The sooner you contact one, the more chance
you will have of stopping the sale. (See notice below on how to obtain an attorney).
YOU MAY STILL BE ABLE TO SAVE YOUR PROPERTY AND
YOU HAVE OTHER RIGHTS EVEN IF THE SHERIFF'S SALE DOES TAKE PLACE.
1. If the Sheriff's Sale is not stopped, your property will be sold to the highest bidder.
You may find out the price bid by calling Dionne Winstead at (215) 653-7450, or by calling the
Cumberland County Sheriff's Department 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 bid in the
sale. To find out if this has happened, you may caIl Dionne Winstead at (215) 653-7450, or by
calling the Cumberland County Sheriff's Department at (717) 240-6390.
4. If the amount due from the buyer is not paid to the Cumberland County Sheriff, you
will remain the owner of the property as if the sale had never happened.
5. You have the right to remain in the property until the full amount due is paid to the
Sheriff and the Sheriff gives a deed to the buyer. At that time, the buyer may bring legal proceedings
to evict you.
6. You may be entitled to a share of the money which was paid for your house. A
schedule of distribution of the money bid for your house will be filed by the Cumberland County
Sheriff on or about thirty (30) days from the date of Sheriff's Sale. This schedule will state who wiIl
be receiving that money. The money will be paid out in accordance with this schedule unless
exceptions (reasons why the proposed distribution is wrong) are filed with the Sheriffwithin ten (10)
days after the distribution sheet is posted.
..
'.
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. IFYOUDONOTHA VB
A LAWYER. GO TO OR TELEPHONE THE OFFICE SET FORTH BELOW. THIS OFFICE
CAN PROVIDE YOU WITH INFORMATION ABOUT HIRING ALA WYER. IF YOU CANNOT
AFFORD TO HIRE A LAWYER. THIS OFFICE MAY BE ABLE TO PROVIDE YOU WITH
INFORMATION ABOUT AGENCIES THAT MAY OFFER LEGAL SERVICES TO ELIGffiLE
PERSONS AT A REDUCED FEE OR NO FEE.
Cumberland County Court Administrator
4th Floor
Cumberland County Court House
1 Courthouse Square
Carlisle, P A 17013
(717) 240-6200
r.........,;'
<
" ....
,
,
ALL that certain tract of land situate in the Township of Silver Spring, Cumberland County, Pennsylvania,
bounded and described in accordance with a survey and plan thereot made by Ernest J. Walter, Professional
Engineer, dated June 23, 1968 as follows:
BEGINNING at the Northeast comer of Birch Street, 33 feet wide and 50 toot wide right-at-way; thence
extending along the East side of Birch Street North 30 15' East 53.91 teet to a comer of Lot No. 13 on the
hereinafter mentioned plan 101$; thence along said lot South aso 45' East 125 feet to an iron pin at a corner of
Lot No. 11; thence f1long said lot South 30 15' West 53,91 teet to a point on the Northern line of the aforesaid 50
fool wide right-of-way. Thence along the same North 860 45' West 125 teet to the point and place of beginning.
BEING Lot No. 12 on a plan of lots known as Silver Spring Development Company, which said plan 15 recorded
in Plan Book 5, page 30, Cumberland County Records.
Parcel #38-19-1610-016
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WRIT OF EXECUTION and/or ATTACHMENT
COMMONWEALTH OF PENNSYLVANIA)
COUNTY OF CUMBERLAND)
NO 03-3762 Civil
CIVIL ACTION - LAW
TO THE SHERIFF OF CUMBERLAND COUNTY:
To satisfy the debt, interest and costs due FAIRBANKS CAPITAL CORP., AS SERVICING
AGENT FOR TCIF REO 2, LLC, Plaintiff (s)
From CINDY L. BOONIE
(I) You are directed to levy upon the property of the defendant (s)and to sell SEE LEGAL
DESCRIPTION
(2) You are also directed to attach the property of the defendant(s) not levied upon in the possession
of
GARNISHEE(S) as follows:
and to notify the garnishee(s) that: (a) an attachment has been issued; (b) the garnishee(s) is enjoined from
paying any debt to or for the accoWlt of the defendant (s) and from delivering any property of the defendant
(s) or otherwise disposing thereof;
(3) Ifproperty of the defendant(s) not levied upon an subject to attachment is fOWld in the possession
of anyone other than a named garnishee, you are directed to notify himlher that he/she has been added as a
garnishee and is enjoined as above stated.
Amount Due $89,693.30 L.L. $.50
Interest FROM 8/22/05 THROUGH 12/7/05 - $18,994.03
Atty's Connn %
Atty Paid $116.90
PlaintifIPaid
Date: AUGUST 30, 2005
Due Prothy $1.00
Other Costs
(Seal)
By:
Deputy
REQUESTING PARTY:
Name BARBARA A. FEIN, ESQmRE
Address: 425 COMMERCE DRIVE, SmTE 100
FORT WASHINGTON, PA 19034
Attorney for: PLAINTIFF
Telephone: 215-653-7450
Supreme Court ID No. 53002
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Real Estate Sale #41
On September 06, 2005 the Sherifflevied upon the
defendant's interest in the real property situated in
Silver Spring Township, Cumberland County, PA
Known and numbered as 17 Birch Street,
Mechanicsburg, more fully described on Exhibit "A"
filed with this writ and by this reference incorporated herein.
Date: September 06, 2005
By:0~~
Real Estate Sergeant
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THE PATRIOT NEWS
THE SUNDAY PATRIOT NEWS
Proof of Publication
Under Act No. 587, Approved May 16, 1929
Commonwealth of Pennsylvania, County of Dauphin} ss
Joseph A. Dennison, being duly sworn according to law, deposes and says:
That he is the Assistant Controller of The Patriot News Co., a cOIporation organized and existing under the
laws of the Commonwealth of Pennsylvania, with its principal office and place of business at 812 to 818 Market
Street, in the City of Harrisburg, County of Dauphin, State of Pennsylvania, owner and publisher of The Patriot,
News and The Sunday Patriot,News newspapers of general circulation, printed and published at 812 to 818 Market
Street, in the City, County and State aforesaid; that The Patriot-News and The Sunday Patriot,News were
established March 4th, 1854, and September 18th, 1949, respectively, and all have been continuously published ever
since;
That the printed notice or publication which is securely attached hereto is exactly as printed and published
in their regular daily and/or Sunday! Metro editions which appeared in the 25th day(s) of October and the 1st and
8th day(s) of November 2005. That neither he nor said Company is interested in the subject matter of said printed
notice or advertising, and that all of the allegations of this statement as to the time, place and character of
publication are true; and
That he has personal knowledge of the facts aforesaid and is duly authorized and empowered to verify this
statement on behalf of The Patriot-News Co. aforesaid by virtue and pursuant to a resolution unanimously passed
and adopted severally by the stockholders and board of directors of the said Company and subsequently duly
recorded in the office for the Recording of Deeds in and for said County of Dauphin in Miscellaneous Book "M".
Volume 14, Page 317.
PUBLICATION
COPY
Sworn to
NOTARY UBLIC
My commission expires June 6, 2006
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CUMBERLAND COUNTY SHERIFFS OFFICE
CUMBERLAND COUNTY COURTHOUSE
CARLISLE, PA. 17013
.
PROOF OF PUBLICATION OF NOTICE
IN CUMBERLAND LAW JOURNAL
(Under Act No. 587, approved May 16, 1929), P. L.l784
COMMONWEALTH OF PENNSYLVANIA
ss.
COUNTY OF CUMBERLAND
Lisa Marie Coyne, 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 foIlowing dates,
VIZ:
October 14,21,28,2005
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.
o AND SUBSCRIBED before me this
day of October. 2005
NOT ARI L SEAL
lOIS E. SNYDER, Notary Public
Carlisle Bora, Cumberland County
My Commission Expires March 5, 2009
-. -.T......IIM& 110.41
Writ No. 2003-3762 Civil
Fairbanks Capllal Corp.,
As servicing Agent for TCIF
REO 2. LLC
vs.
Cindy L. Boonle
Atty.: Barbara A. Fein
AlL that certain tract ofland situ.
ate In the Township of Silver Spring.
Cumberland County. Pennsylvan1a.
bounded and described 1n accor-
dance with a survey and plan thereof
made by Ernest J. Walter. Profes-
sional Engineer. dated June 23,
1968 as follows:
BEGINNING at the Northeast
corner of Birch Street, 33 feet wide
and 50 foot wide rlght-of.way:
thence extending along the East side
of Birch Street North 3. IS' East
53.91 feet to a comer of Lot No. 13
on the hereinafter mentioned plan
lots: thence along said lot South 86.
45' East 125 feet to an Iron pin at a
corner of Lot No. II; thence along
said lot South 3. 15' West 53.91 feet
to a point on the Northern line of
the aforesald 50 foot wide rlgbt'of-
way. Thence along the same North
86. 45' West 125 feet to the point
and place of beglnnlng.
BEING Lot No. 12 on a plan of
Jots lmown as Silver Spring Devel-
opment Company, which said plan
1s recorded in Plan Book 5. page
3D, Cumberland County Records.
Parcel #38-19-1610-016.