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Home My WebLink About03-3978GOLDBECK McCAFFERTY & McKEEVER BY: JOSEPH A. GOLDBECK~ JR. ATTORNEY I.D. #16132 SUITE 500 - TI~E BOURSE BLDG. 111 S. INDEPENDENCE MALL EAST PHILADELPHIA, PA 19106 (215) 627-1322 ATTORNEY FOR PLAINTIFF Ci'IlldNANCIAL SERVICES INC. 7467 New Ridge Road Suite 222 Hanover, MD 21076 Plaintiff VS. CHARLES E. LINDSEY JANET L. LINDSEY Mortgagor(s) and Real Owner(s) 1402 Rimer Highway Shippensburg, PA 17257 Defendant(s) IN THE COURT OF COMMON PLEAS OF CUMBERLAND COUNTY CIVIL ACTION - LAW ACTION OF MORTGAGE FORECLOSURE Term CIVIL ACTION: MORTGAGE FORECLOSURE THIS FIKNI IS A DEBT COLLECTOR AND WE ARE ATTEMPTINGTO COLLECT A DEBT OWED TO OUR CLIENT. ANY INFORMATION OBTAINED FROM YOU WILL BE USED FOR THE PURPOSE OF COLLECTING THE DEBT. NOTICE You have been sued in court If you w~sh to defend ag~m~t the claim~ set forth in the following pages, you must teke action within twenty (20) days after the Complaim and notice are served, by entering a walton appearance pemo~ally or by attorney and filing in vatiing with the court your defenses or objections to the claims set forth against you. You are warned that if you fail to do so the caso may proceed without you and a j udgraent may be entered against you by the Court without fu~ber notice for any.money claim in the Complaint of for any other claim or relief requested by the Plaintiff. You may lose money or propeay or other tights important to you. YOU SHOULD TAKE THIS POPER TO YOUR LAWYER AT ONCE. IF YOU DO NOT HAVE A LAWYER OR CANNOT AFFOED ONE, GO TO OR TELEPHONE THE OFFICE SET FORTH BELOW TO FIND OUT WHERE YOU CAN GET LEGAL HELP, LEGAL SERVICES INC 8 Irviue Row Carlisle, PA 17013 717-243-9400 CUMBERLAND COUNTY BAR ASSOCIATION 2 L~erty Avenue Carlisle, PA 17013 AVISO LE HAN DEMANDADO A USTED EN LA CORTE. SI DESEA DEFENDERSE CONTRA LAS QUEJAS PERESENTADAS, ES ABSOLUTAMENTE NECESSARIO QUE USTED RESPONDA DENTRO DE 20 DIAS DESPHES DE SER SERVIDO CON ESTA DEMANDA Y AVISO. PARA DEFENDERSE ES NECESSARIO QUE USTED, O SU ABOGADO, REGISTRE CON LA CORTE EN FORMA ESCRITA. EL PUNTO DE VISTA DE USTED Y CUALQUIER OBJECCION CONTRA LAS QUEJAS EN ESTA DEMANDA. RECUERDE: SI LISTED NO REPONDE A ESTA DEMANDA, SE PUEDE PROSEGUIR CON EL PROCESO SIN SU PARTIC1PACION. ENTONCES, LA COUTE PUEDE, SIN NOTIFICARIO, DECID1R A FAVOR DEL DEMANDANTE Y REQUERIRA QUE US'fED CUMPLA CON TODAS LAS PROVISIONES DE ESTA DEMANDA. POR RAZON DE ESA DECISION, ES POSS/BLE QUE USTED PUEDA PERDER DINERO, PROPIEDAD U OTROS DERECHOS IMPORTANTES. LLEVE ESTA DEMANDA A UN ABOGADO IMMEDIATEAMENTE. SI NO CONOCE A UN ABOGADO, LLAME AL "LAWYER REFERENCE SERVICE" (SERVICIO DE REF~CIA DE ABOGADOS), (215) 238-6300, LEGAL SERVICES INC 8 lIVine Row Carlisle, PA 17013 717-243-9400 CUMBERLAND COUNTY BAR ASSOCIATION 2 Liberty Avenue Carlisle, PA 17013 EXHIBIT A ACT 91 NOTICE DATE OF NOTICE: July 7, 2003 TAKE ACTION TO SAVE YOUR HOME FROM FORECLOSURE This is an official notice that the mortgage on your home is in default, and the lender intends to foreclose. Specific information about the nature of the default is provided in the attached pages. The HOMEOWNER'S MORTGAGE ASSISTANCE PROGRAM (HEMAP) may be able to help to save your home. This Notice explains how the program works. To see if HEMAP can help, you must MEET WITH A CONSUMER CREDIT COLrNSELING AGENCY WITH1N 30 DAYS OF THE DATE OF THIS NOTICE. Take this Notice with you when you meet with the Counseling Agency. The name, address and phone number of Consumer Credit Counseling Agencies serving your County are listed at the end of this Notice. If you have any questions, you may call the Pennsylvania Housing Finance Agency toll free at 1-800-342-2397. (Persons with impaired hearing can call (717) 780-1869.) This Notice contains important legal information. If you have any questions, representatives at the Consumer Credit Counseling Agency may be able to help explain it. You may also want to contact any attorney in your area. The local bar association may be able to help you find a lawyer. La nofificacion en adjunto es de suma importancia, pues afecta su derecho a continuar viviendo en su casa. Si no comprende el contenido de esta notification obtenga una traduccion immediatamente llamanda esta agencia (Pennsylvania Housing Finance Agency) sin cargos al numero mencionada arriba. Puedes ser elegible para un prestamo por el programa llamado "Homeowner's Emergency Mortgage Assistance Program" el cual puede salvar su casa de la perdida del derecho a redimir su hipoteca. Prepared by: GOLDBECK McCAFFERTY & McKEEVER Suite 500 - The Bourse Bldg. 111 S. Independence Mall East Philadelphia, PA 19106 Fax (215) 627-7734 7160 ~901 9844 4263 9428 Date: July 7, 2003 Homeowners Name: CHARLES E. LINDSEY and JANET L. LINDSEY Property Address: 1402 Ritner Highway, Shippensburg, PA 17257 Loan Account No.: 2000510299198 Original Lender: CITIFINANCIAL SERVICES INC. Current Lender/Servicer: CITIFINANCIAL SERVICES INC. HOMEOWNERS' EMERGENCY MORTGAGE ASSISTANCE PROGRAM YOU MAY BE ELIGIBLE FOR FINANCIAL ASSISTANCE WHICH CAN SAVE YOUR HOME FROM FORECLOSURE AND HELP YOU MAKE FUTURE MORTGAGE PAYMENTS IF YOU COMPLY WITH THE PROVISIONS OF THE HOMEOWNER'S EMER~ ]ENCY MORTGAGE ASSISTANCE ACT OF 1983 (THE "ACT"), YOU MAY BE ELIGIBLE FOR EMERGENCY MORTGAGE ASSISTANCE: * IF YOUR DEFAULT HAS BEEN CAUSED BY CIRCUMSTANCES BEYOND YOUR CONTROL, * IF YOU HAVE A REASONABLE PROSPECT OF BEING ABLE TO PAY YOUR MORTGAGE PAYMENTS, AND * IF YOU MEET OTHER ELIGIBILITY REQUIREMENTS ESTABLISHED BY THE PENNSYLVANIA HOUSING FINANCE AGENCY. TEMPe ~RARY STAY OF FORECLOSURE - Under the Act, you are entitled to a temporary stay of foreclosure on your mortgage for thirty (30) days from the date of this Notice. During that time you must arrange and attend a "face-to-face" meeting with one of the designated consumer credit counseling agencies listed at the end of this Notice. THIS MEETING MUST OCCUR WITHIN THE NEXT (30} DAYS. IF YOU DO NOT APPLY FOR EMERGENCY MORTGAGE ASSISTANCE, YOU MUST BRING YOUR MORTGAGE UP TO DATE. THE PART OF THIS NOTICE CALLED "HOW TO CURE YOUR MORTGAGE DEFAULT", EXPLAINS HOW TO BRING YOUR MORTGAGE UP TO DATE. CONSUMER CREDIT COUNSELING AGENCIES - If you meet with one o£ the consumer credit counseling agencies listed at the end of this notice, the lender may NOT take action against you for thirty (30) days a~er the date of this meeting. The names, addresses and telephone numbers of designated consumer credit counseling agencies for the county in which the property is located are set 2 forth at the end of this Notice. It is only necessary to schedule one face~to-face meeting. Advise your lender immediately of your intentions. APPLICATION FOR MORTGAGE ASSISTANCE - Your mortgage is in default for the reasons set forth later in this Notice (see following pages for specific information about the nature of your default.) If you have tried and are unable to resolve this problem with the lender, you have the right to apply for financial assistance from the Homeowner's Emergency Mortgage Assistance Program. To do so, you must fill out, sign and file a completed Homeowner's Emergency Assistance Program Application with one of the designated consumer credit counseling agencies listed at the end of this Notice. Only consumer credit counseling agencies have applications for the program and they will assist you in submitting a complete application to the Pennsylvania Housing Finance Agency. Your application MUST be filed or postmarked within thirty (30) days of your fact-to-face meeting. YOU MUST FILE YOUR APPLICATION PROMPTLY. IF YOU FAIL TO DO SO OR IF YOU DO NOT FOLLOW THE OTHER TIME PERIODS SET FORTH IN THIS LETTER, FORECLOSURE MAY PROCEED AGAINST YOUR HOME IMMEDIATELY AND YOUR APPLICATION FOR MORTGAGE ASSISTANCE WILL BE DENIED. AGENCY ACTION - Available funds for emergency mortgage assistance are very limited. They will be disbursed by the Agency under the eligibility criteria established by the Act. The Pennsylvania Housing Finance Agency has sixty (60) days to make a decision after it receives your application. During that time, no foreclosure proceedings will be pursued against you if you have met the time requirements set forth above. You will be notified directly by the Pennsylvania Housing Finance Agency of its decision on your application. NOTE: iIF YOU ARE CURRENTLY PROTECTED BY THE FILING OF A PETITION IN BANKRUPTCY, THE FOLLOWING PART OF THIS NOTICE IS FOR INFOR~IATION PU ~IiPOSES ONLY AND SHOULD NOT BE CONSIDERED AS AN ATTEMPT TO COLLECT THE DEBT. (If~you have filed bankruptcy you can still apply for Emergency Mortgage Assistance.) HOW TO CURE YOUR MORTGAGE DEFAULT (Bring it up to date). NATURE OF THE DEFAULT - The MORTGAGE debt held by the above lender on your property located at: 1402 Ritner Highway, Shippensburg, PA 17257 IS SERIOUSLY IN DEFAULT because: A. YOU HAVE NOT MADE MONTHLY MORTGAGE PAYMENTS for the following months and the following amounts are now past due: (a) Monthly payment from 02/17/2003 thru 7/7/2003 (6 mos. at $1,305.37/month) $7,832.22 (b) TOTAL AMOUNT REQUIRED AS OF THIS DATE $7,832.22 HOW TO CURE THE DEFAULT - You may cure the default within THIRTY (30) DAYS of the date of this notice BY PAYING THE TOTAL AMOUNT PAST DUE TO THE LENDER WHICH IS $ 7,832.22 , PLUS ANY MORTGAGE PAYMENTS AND LATE CHARGES W~IICH BECOME DUE DURING THE THIRTY (30) DAY PER/OD. Payments must be made either by cashier's check, certified check or money order made payable and sent to: CITIFINANCIAL SERVICES 1NC. 7467 New Ridge Road Suite 222 Hanover, MD 21076 IF YOU DO NOT CURE THE DEFAULT - If you do not cure the default within THIRTY (30) DAYS of the date of this Notice, the lender intends to exercise its rights to accelerate the mortgage debt. This means that the entire outstanding balance of this debt will be considered due immediately and you may lose the chance to pay the mortgage in monthly installments. If full payment of the total mount past due is not made within THIRTY (30) DAYS, the lender also intends to instruct its attorneys to start legal action to foreclose upon your mortgaged property.. IF THE MORTGAGE IS FORECLOSED UPON - The mortgaged property will be sold by the Sheriffto pay offthe mortgage debt. If the lender refers your case to its attorneys, but you cure the delinquency before the lender brings legal proceedings against you, you will still be required to pay the reasonable attorney's fees that were actually incurred, up to $50.00. However, if legal proceedings are started against you, you will have to pay all reasonable attorney's fees actually incurred by the lender even if they exceed $50.00. Any attorney's fees will be added to the amount you owe the lender, which may also include other reasonable costs. If you cure the default within the THIRTY (30) DAY period, you will not be required to pay attorney's fees. OTHER LENDER REMEDIES - The lender may also sue you personally for the unpaid principal balance and all other sums due under the mortgage. RIGHT TO CURE THE DEFAULT PRIOR TO SHERIFF'S SALE - If you have not cured the default within the THIRTY (30) DAY period and foreclosure proceedings have begun, you still have the right to cure the default and prevent the sale at any time up to one hour before the Sheriffs Sale. You may do so by paying the total mount then past due, plus any late or other charges then due, reasonable attorney's fees and costs connected with the foreclosure sale and any other costs connected with the Sheriff's Sale as specified in writing by the lender and by performing any other requirements under the mortgage. Curing your default in the manner set forth in this notice will restore your mortgage to the same position as if you had never defaulted. 4 EARLIEST POSSIBLE SHERIFF'S SALE DATE - It is estimated that the earliest date that such a Shefiffs Sale of the mortgaged property could be held would be approximately four (4) to six (6) months from the date of this Notice. A notice of the actual date of the Sheriff's Sale will be sent to you before the sale. Of course, the amount needed to cure the default will increase the longer you wait. You may find out at any time exactly what the required payment or action will by contacting the lender. HOW TO CONTACT THE LENDER: Name of Lender: CITIFINANCIAL SERVICES 1NC. Address: 7467 New Ridge Road Suite 222 Hanover, MD 21076 Phone Number: 888-800-5165 Fax Number: Contact Person: Loss Mitigation Department EFFECT OF SHERIFF'S SALE - You should realize that a Sheriffs Sale will end your ownership of the mortgaged property and your fight to occupy it. If you continue to live in the property after the Sheriffs Sale, a lawsuit to remove you and your furnishings and other belongings could be started by the lender at any time. ASSUMPTION OF MORTGAGE - You may sell or transfer your home to a buyer or transferee who will assume the mortgage debt, provided that all the outstanding payments, charges and attorney's fees and costs are paid prior to or at the sale and that the other requirements of the mortgage are satisfied. YOU MAY ALSO HAVE THE RIGHT: * TO SELL THE PROPERTY TO OBTAIN MONEY TO PAY OFF THE MORTGAGE DEBT OR TO BORROW MONEY FROM ANOTHER LENDING INSTITUTION TO PAY OFF THIS DEBT. BEHALF. TO HAVE THIS DEFAULT CURED BY ANY THIRD PARTY ACTING ON YOUR * TO HAVE THE MORTGAGE RESTORED TO THE SAME POSITION AS IF NO DEFAULT HAD OCCURRED, IF YOU CURE THE DEFAULT. (HOWEVER, YOU DO NOT HAVE THIS RIGHT TO CURE YOUR DEFAULT MORE THAN THREE TIMES IN ANY CALENDAR YEAR.) 5 * TO ASSERT THE NONEXISTENCE OF A DEFAULT IN ANY FORECLOSURE PROCEEDING OR ANY OTHER LAWSUIT INSTITUTED UNDER THE MORTGAGE DOCUMENTS. * TO ASSERT ANY OTHER DEFENSE YOU BELIEVE YOU MAY HAVE TO SUCH ACTION BY THE LENDER. * TO SEEK PROTECTION UNDER THE FEDERAL BANKRUPTCY LAW. Contact Person: Loss Mitigation Department Phone Number: 888-800-5165 SHERIFF'S RETURN - REGULAR CASE NO: 2003-03978 P COMMONWEALTH OF PENNSYLVANIA: COUNTY OF CUMBERLAND CITIFINANCIAL SERVICES INC VS LINDSEY CHARLES E ET AL BRYAN WARD Cumberland County, Pennsylvania, says, the within NOTICE LINDSEY CHARLES E DEFENDANT , at 0016:21 HOURS, at 129 RUSTIC DRIVE SHIPPENSBURG, PA 17257 JANET LINDSEY (WIFE- HOMEOWNER) a true and attested copy of NOTICE COMPLAINT IN MORTGAGE FORECLOSURE Sheriff or Deputy Sheriff of who being duly sworn according to law, was served upon the on the 15th day of August , 2003 by handing to together with and at the same time directing Her attention to the contents ~hereof. Sheriff's Costs: Docketing 18.00 Service 13.80 Affidavit .00 Surcharge 10.00 .00 41.80 Sworn and Subscribed to before me this 27 ~ day of _ ~n% A.D. ~r~thonotary ,/ So Answers: R. Thomas Kline 08/18/2003 GOLDBECK, MCCAFFERTY, MCKEEVER D~uty' Sheriff SHERIFF'S RETURN - REGULAR CASE NO: 2003-03978 P COMMONWEALTH OF PENNSYLVANIA: COUNTY OF CUMBERLAND CITIFINANCIAL SERVICES INC VS LINDSEY CHARLES E ET AL BRYAN WARD , Cumberland County, Pennsylvania, says, the within NOTICE LINDSEY JANET L DEFENDANT , at 0016:21 HOURS, at 1402 RITNER HIGHWAY SHIPPENSBURG, PA 17257 JANET LINDSEY (HOMEOWNER) a true and attested copy of NOTICE COMPLAINT IN MORTGAGE FORECLOSURE Sheriff or Deputy Sheriff of who being duly sworn according to law, was served upon the on the 15th day of August , 2003 129 RUSTIC DRIVE by handing to together with and at the same time directing Her attention to the contents thereof. Sheriff's Costs: Docketing 6.00 Service .00 Affidavit .00 Surcharge 10.00 .00 16.00 Sworn and Subscribed to before me this ~ day of ~-~3-3 A.D. thonotary ' So Answers: R. Thomas Kline 08/ s/2003 GOLDBECK, MCCAFFERTY, MCKEEVER By: Sheriff GOLDBECK McCAFFERTY & McKEEVER BY: Joseph A. Goldbeck, Jr. Attorney I.D: #16132 Suite 5000 - Mellon Independence Center. 70I Market Street Philadelphia, PA 19106 215-627-1322 Attorney for Plaintiff CITIFINANCIAL SERVICES INC. 7467 New Ridge Road Suite 222 Hanover, MD 21076 VS. CHARLES E. LINDSEY JANET L. LINDSEY (Mortgagor(s) and Record owner(s)) 1402 Rimer Highway Shippensburg, PA 17257 Plaintiff Defendant(s) 1N THE COURT OF COMMON PLEAS of Cumberland County CIVIL ACTION LAW ACTION OF MORTGAGE FORECLOSURE No. 03-3978 ORDER FOR JUDGMENT Please enter Judgment in favor of CITIFINANCIAL SERVICES 1NC., and against CHARLES E. LINDSEY and JANET L. L1NDSEY for failure to file an Answer in the above action within (20) days (or sixty (60) days if defendant is the United States of America) from the date of service of the Complaint, in the sum of $171,212.31. 2 ~ Joseph A. Go, Attorney for ! I hereby certify that the above names are correct and that the pi _~ctse !e_s_~d_ence address of the judgment ~ite 222 Hanover, MD 21076 and that the creditor is CITIFINANCIAL SERVICES INC. 7467 New Ridge Road ! name(s) and last known address(es) of the Defendant(s) is/are CHARLES E. LINDSEY, 1402 Rimer Highway Shippensburg, PA 17257 and JANET L. LINDSEY, 1402 Rimer GOLDBECK BY: Joseph Attorney for pensburg, PA 17257; ASSESSMENT OF DAMAGES TO THE PROTHONOTARY: Kindly assess the damages in this case to be as follows: Principal Balance $151,885.06 Interest fi'om 01/17/2003 through 10/01/2003 $10,608.00 Attorney's Fee at 5.0000% of principal balance $7,594.25 Late Charges $0.00 Costs of Suit and Title Search $900.00 Title / Appraisal Fee $225.00 ($0.00) $171,212.31 AND NOW, this day of O~k~ GOLDBECK l BY: Joseph A. ( Attorney for Plai & McKEEVER ,2003 damages are assessed as above. Pro Prothy VERIFICATION OF NON-MILITARY SERVICE The undersigned, as the representative for the Plaintiff corporation within named do hereby verify that I am authorized to make this verification on behalf of the Plaintiff corporation and that the facts set forth in the foregoing verification of Non- Military Service are true and correct to the best of my knowledge, information and belief. I understand that false statements therein are made subject to penalties of 18 Pa. C.S. 4904 relating to unsworn falsification to authorities. 1. That the above named Defendant, CHARLES E. LINDSEY, is about unknown years of age, that Defendant's last known residence is 1402 Ritner Highway, Shippensburg, PA 17257, and is engaged in the unknown business located at unknown address. 2. That Defendant is not in the Military or Naval of the United States or its Allies, provisions of the Soldiers' and Sailors' Congress of 1940 and its Amendments. Date: ~ Service or otherwise within the Civil Relief Action of VERIFICATION OF NON-MILITARY SERVICE The undersigned, as the representative for the Plaintiff corporation within named do hereby verify that I am authorized to make this verification on behalf of the Plaintiff corporation and that the facts set forth in the foregoing verification of Non- Military Service are true and correct to the best of my knowledge, information and belief. I understand that false statements therein are made subject to penalties of 18 Pa. C.S. 4904 relating to unsworn falsification to authorities. 1. That the above named Defendant, JANET about unknown years of age, that Defendant's last is 1402 Ritner Highway, Shippensburg, PA 17257, and in the unknown business located at unknown address. 2. L. LINDSEY, is known residence is engaged That Defendant is not in the Military or Naval Service of the United States or its Allies, or otherwise within the provisions of the Soldiers' and Sailors' Civil Relief Action of Congress of 1940 and its Amendments. Date: In the Court of Common Pleas of Cumberland County CITIFINANCIAL SERVICES INC. 7467 New Ridge Road Suite 222 Hanover, MD 21076 VS. CHARLES E. LINDSEY JANET L. LINDSEY (Mortgagor(s) and Record Owner(s)) 1402 Rimer Highway Shippensburg, PA 17257 Plaintiff Defendant(s) No. 03-3978 PRAECIPE FOR JUDGMENT THIS LAW FIRM IS A DEBT COLLECTOR AND WE ARE ATTEMPTING TO COLLECT A DEBT OWED TO OUR CLIENT. ANY INFORMATION OBTAINED FROM YOU WILL BE USED FOR THE PURPOSE OF COLLECTING THE DEBT. Enter the Judgment in favor of Plainfiffand against CHARLES E. LINDSEY and JANET L. LINDSEY by defaul~ for want of an Answer. Assess damages as follows: Debt $171,212.~1 Interest - 01/17/2003 to 10/01/2003 Total (Assessment of Damages attached) I CERTIFY THAT FOREGOING ASSESSMENT OF DAMAGES IS FOR SPECIFIED AMOUNTS ALLEGED TO BE DUE IN THE COMPLAINT AND IS CALCULABLE AS A SUM CERTAIN FROM THE COMPLAINT. is to be entered and to his attorney of record, if any, after the default occurred filing of this praecipe. A copy of the notice is attached. R.C.P. 237.1 ~xx,~ Joseph A. Attorney I.D. #161. I certify that written notice of the intention to file this praecipe was mailed or delivered to the party against whom judgment a~tays prior to the date of the [[1~' fir' Jr. AND NOW ~-~"' 1~ ~ t~_X~ I~ment is entered in favor of I ' C TIFINANCIAL SERVICES INC. and against CHARLES E. LINDSEY and JANET L. LINDSEY by default for want of an Answer and damages assessed in the sum of $171,212.31 as per the ab~.cert, ificati~n.~ Prothonota~ - v · 10/06/2003 11:20 FAX 215 627 7734 GOLDBECK ~00S FROM YOU WILL r,, xv Gull cLiENT. ANY INFORMATION OBTAINED BE USED FOR THE PURPOSE OF COLLECTING ~ DEBT. CHARLRS E. I,INDSKy 1402 R/tho- Highway Shippe~sbu.?g, PA 17257 DATE OF THIS NOTICE: September 5, 2003 Chu'INANCIALSERVICESiNC. 7467NewRidge Road Suim222 Hanov~r, lVID21076 VS. CHARLEs E. LINDSEY lAN'ET L. LINDSEY (Martgagor(s) and Record Owner(s)) 1402 Rimer Highway Shippensburg, PA 17257 TO: CHARLes E, LINDSEy 1402 Rimer Highway Shippensbur~, PA 172~7 Plaintiff Defendant(s) In the Court of Com,-on Picas of Cumberhmd County CIVIL ACTION - LAW ACTION OF MORTGAGE FORECLOSURE Tenll No. 03-3978 IMPORTANT NOTICE, PERS,,,,Y..O,U_._-~_ _IN DF, FAULT BF~.AUSE YOU HAVE FAILED TO ENI'Ifl/. A WR. tlIF, N AP Vi~AbL¥ OK BY ATTORNEy AND FILE IN um~,-, ................ - ' PEARANC~ -,a.t.c,n~J WlIZI II'U~ COURT YOUR DI:iq/NSES OR OBIECTIOI~ TO ~ CLAIMS SET FORTH AGAINST YOU. UNLESS YOU ACT WITHIN TEN (10) DAYS FROM THE DATE O~ THIS NOTIcE, A I!JDG/vlENT MAY BE I/i'¢--rERI~ A~AINST YOU WITHOUT A HEARING AND YOU MAy LOSE YOUR PROPP_RTY OR O'rl-~R IMPORTANT RIGHTS. YOU SHOULD TAKE THIS NOTICE TO A LAWYER AT ONCE. 1~ YOU DO NOT HAVI~ A LAWYF, R OR CANNOT AFFORD ONE, C~9 TO OR 1/~.LI~PHONE THE FOLLOWINg3 OFFICE TO FIND OUT ~ YOU CAN GEl' LEGAL/.~l P: LF~_~AL SERVICES INC 71 ?-2~3-9400 CDMBERLAND COUN-P~ BAR ASSOCIATION Caflialc, PA 17013 Att~mcy for Pla~n~J~ Sui*~ $~0. The B~,se Bldg. 111 5. ladependcac~ Mall F. asr PMladelphla, pA 19106 215-627~l 322 10/06/2003 11:19 FAX 215 627 7734 GOLDBECK ~002 THIS LAW FIRM IS A DEBT COLLECTOR AND WE ARE ATTEbfPTING TO COLLECT A DEBT OWED TO OUR CLIENT. ANY I~FORMATION OBTAINED FROM YOU WILL BE USED FOR THE PURPOSE OF COLLECTING THE DEBT. CHARLES E. LINDSEY 129 Rustic Drive Shippeozburg, PA 17257 DATE OF THIS NOTICE: September 5, 2003 C£r~IN'ANCIAL SERVICES INC. 7467 New Ridge Road Suite 222 Hanover, MI) 21076 vs. CHARLES E_ LINDSEY JANET L. LINDSEY (Mortgagor(s) ~d Record Owne~(s)) 1402 ~ ~y S~pp~sb~g, PA 17257 Plaintiff the Com't of Common Plea~ of Cumberhmd County CIVIL ACTION - LAW ACTION OF MORTGAGE FORECLOSURE Terlrl No. 03-3978 TO: CHARLES E. LINDSEY 129 Ruz'dc Drive Slnipp~, PA 17257 IMPORTANT NOTICE YOU ARE IN D]~FAULT BECAUSE YOU HAVE F~'I~F~ TO EIhrI'EK A WR, lilP_~d' APPHARA~CIE PERSONALLy OR BY ATTORNEy AND F~ ~ IN WI~i'ING WITH ~ COURT YOUR DP2'/~[SF.S OR OBJECTIONS TO THE CLAIMS SET FOKTlt A~A~NST YOU. UNLESS YOU ACT WiTttlN TEN (I0) DAYS FROM THE DATE O~ THIS NOTICE, A JUIXSMENT MAY BE I~Tl~gl~) AOAINST YOU WITHOUT A I't~d~[NG AND YOU MAY LOSE YOUR PROPERTY OR OTHER IMI~RTANT RIGRTS. YOU SHOULD TAKE TH/S NOTICE TO A LAWYER A~r ONCE. IF YOU DO NOT HAVE A LAWYER OR CANNOT AFFORD ONE, CK) TO OR T~x.b-~rIONE THE FOLLOWING OFFICE TO FIND OUT ~ YOU CAN GET LEGAL I-~LP: LEi}AL SERVlC.~ INC $ Ir~,inc Row Carlisle,, PA 17013 717-243-94~0 ~ COUNTY BAR ASSOCIAT[0N 2 L~ Avmue At~'y for Ph~gff Su~ 5~0 - l~e Bourse BId~. 111 S. Independ~tce Mull E,~ Philadelphia, pA 1910G 215-627-1322 10/06/2003 11:20 FAX 215 627 7734 GOLDBECK ~004 ~o~ v,~., ~. ........ ,._~u uuK ~LIENT. ANY INFORMATION OBTAINED *,a~,~,~?t xvU WILL ISE U~EI) FOR THE PURPOSE OF COLLECTING THE JANET L. LINDSEY 1402 Rimer Highway Shippenshmg, PA 17257 DATE OF THIS NOTICE: September 5, 2003 CITII~gANCIAL SERVICES INC, 7467 New Ridge Road Suit~ 222 Hanover, MD 21076 CHARLEs E. LII~SEY IA1VET L. L]NDSEY ('l~ortgagm.(s) and 1~2 ~m~ Hi~y S~sb~g, PA 17257 Defendant(s} In the Court of Common Pleas of Cumberland County CIVIL ACTION- LAW ACTION OF MORTGAGE FORECLOSURE No. 03-3978 TO: JA.N~ T L LINDSEY 1402 Rimer Highway Shippgraburg, PA 17257 IMt'ORTANT NOTICE YOU ARE IN DEFAULT BECAUSE YOU HAVE FAILED TO E/TI'ER A WI~.IL~ APPEAIC,~C~ PF-RSONALLY OR BY ATTORNEy AND FI~E IN WRITING WiTH THE COURT YOUR DF-~I:NSES OR ORIF. CTION~ TO THE CLAIMS SET FORTH AOAINST YOU, UNLEss YOU ACT WITHIN ~ (10) DAYS FROM THI/DATE OF THIS NOTICE, A JUDGMENT MAY BE ~D AGAIIqST YOU W.rI'HOUT A HHAR.I~G A_ND YOU MAY LOSE YOUR PROPERTY OR OTHI~ llMPORTANT RIGHTS. YOU SHOULD TAI~ THIS NOTICE TO A LAWYI~ AT ONCE. IF YOU DO NOT HAVE A LAWYER OR CANNOT AFFORD ONF~ GO TO OR TELEPHONE TI'IE FOLLOWING OFFICE TO FIHD OUT WHER~ YOU CAN GET LEGAL I"I~LP: LEGAL !~ERV~CES INC 8 Irvine Row Carl/fie, PA 17013 717-243-9a00 CUMBF. I~,LAND COUNTY BAR. ASSOCIATION 2 L~.ny Aven~ Cagislc, PA 17013 Attorney for Pl~miff Sdt~ ~00- Ten Bour~ BIds, 111 $- Ind~l~nd~ Mall Falar Philaga~ga, PA 19106 2154~27-1322 10/06/2003 11:20 FAX 215 627 773A GOLDBECK ~003 TO: FROM w-,T, ,,,,-, ........ ,~..x ~-~wr~'l. ANy INFORMATION OBTAr~.n ,wu v, ,~L Ul!; U~EO FOR THE PUP-,.POSE OF COLLECTING TH~' ~'l~I'. DATE OF THIS NOTICE: September 5, 2003 JANET L. LINDSEy 129 Pamic Drive Shippen~burg, PA 17257 CITIFINANCIAL SERVICES INC, 7467 New Ridge Road Suite 222 Ha,over, MD 21076 VS. CHARLES E. LI3iDSEY JANET L. LINDsEY (Mortgagor(s) and Record Ovmer(s)) 1402 Rimer Highway Shippensburg, PA 17257 Plainff. ff Oefendant(O In the Court of Colllmo~ Pleas of Cumberlslld County CIVIL ACTION - LAW ACTION OF MORTGAGE FORECLOSURE T~..m No. 03-3978 TO; JANRT L. LINDSEY 129 Rustic Drive Shippe~bur$, PA. 17257 IMPORTANT NOTIC~ YOU ARE IN DEFAULT BECAUSE YOU HAVE p.~l~D TO ENiP~, A WlarlI/N APPEARAN~ PERSONALLY OR BY ATTORNEy AND FILE IN WR_WINO WITH TI~ COURT YOUR DEFI~ISES OR OBIF. CTIONS TO THE CLAIMS SET FORTH ACrAINST YOU. UNLESS YOU ACT WrIH~ TEN (I0) DAYS FROM THE DATE OF THIS NOTICE, A ~JDGMEN'r MAy BE I/NrEP. ED AGAINST YOU WITHOUT A HEARING AND YOU MAY LOSE YOUR PROPERTY OR OTHER IMI~RTANT RIGHt. YOU SI-IOULD TAICE THIS NOTICE TO A LAWYER AT ONCE 1F YOU DO NOT HAVE A LAWYER OR CANNOT AFFORD ONE, ~ TO OR OFFICE TO FIND OUT WHERE YOU CAN GET LEGAl. HELP: I~I/PHONE ~ FOLLOWING LEGAL SERVICES INC 8 I~ine Row C.~i~le, PA 17013 717-243-9400 C-OMB~ COUl~rr~ I~R AS~X~,TION 2 L~"o~y Argue Carlisle, PA 17013 Attome;y for 111 $. Ind~!~d~lce Mall Ph~adelghia, PA 19106 215427-132.2 Rule of Civil Procedure No. 236 - Revised CITIF1NANCIAL SERVICES INC. 7467 New Ridge Road Suite 222 Hanover, MD 21076 IN THE COURT OF COMMON PLF, AS OF Cumberland COUNTY, PENNSYLVANIA CIVIL ACTION - LAW Plaintiff VS. No. 03-3978 CHARLES E. LINDSEY JANET L. LINDSEY (Mortgagors and Record Owner(s)) 1402 Rimer Highway Shippensburg, PA 17257 Defendant(s) THIS LAW FIRM IS A DEBT COLLECTOR AND WE ARE ATTEMPTING TO COLLECT A DEBT OWED TO OUR CLIENT. ANY INFORMATION OBTAINED FROM YOU WILL BE USED FOR THE PURPOSE OF COLLECTING THE DEBT. NOTICE Notice is given that a judgment in the above-captioned matter has been entered against you. Curt Long Prothonotary Deputy If you have any questions concerning the above, please contact: Joseph A. Goldbeck, Jr. Goldbeek MeCafferty & McKeever Suite 5000 - Mellon Independence Center. 701 Market Street Philadelphia, PA 19106 215-627-1322 PRAECIPE FOR WRIT OF EXECUTION - (MORTGAGE FORECLOSURE) P.R.C.P 3180-3183 Joseph A. Goldbeck, Jr. Attorney I.D.#16132 Suite 5000 - Mellon Independence Center. 701 Market Street Philadelphia, PA 19106 215-627-1322 Attorney for Plaintiff CITIFINANCIAL SERVICES 1NC. 7467 New Ridge Road Suite 222 Hanover, MD 21076 VS. CHARLES E. LINDSEY JANET L. LINDSEY Mortgagor(s) and Record Owner(s) 1402 Rimer Highway Shippensburg, PA 17257 Plaintiff Defendant(s) IN TllE COURT OF COMMON PLEAS of Cumberland County CIVIL ACTION - LAW ACTION OF MORTGAGE FORECLOSURE No. 03-3978 PRAECIPE FOR WRIT OF EXECUTION_ TO THE PROTHONOTARY: Issue Writ of Execution in the above matter: Amount Due Interest fi.om 01/17/2003 to 10/01/2003 at 10.1280% (Costs to be added) $171~212.31 GOLDBECK Mc( BY: Joseph A. (30 Attorney for Plain & McKEEVER ~O~lST~O of 0.9~0 ~es, non .or 2m. WRIT OF EXECUTION and/or ATTACItMENT COMMONWEALTH OF PENNSYLVANIA) NO 03-3978 Civil COUNTY OF CUMBERLAND) CIVIL ACTION - LAW TO THE SHERIFF OF CUMBERLAND COUNTY: To satisfy the debt, interest and costs due CITIFINANCIAL SERVICES, INC., Plaintiff (s) From CHARLES E. LINDSEY AND JANET L, LINDSEY, (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 gamishee(s) that: (a) an attachment has been issued; (b) the garnishee(s) is enjoined from paying any debt to or for the account of the defendant (s) and from delivering any property of the defendant (s) or otherwise disposing thereof; (3) If property of the defendant(s) not levied upon an subject to attaclunent is found in the possession of anyone other than a named garnishee, you are directed to notify him/her that he/she has been added as a garnishee and is enjoined as above stated. AmountDue $171,212.31 L.L. $.50 Interest FROM 1/17/03 TO 10/1/03 AT 10.1280% Atty's Comm % Due Prothy $1.00 AttyPaid $139.80 Other Costs Plaintiff Paid Date: OCTOBER 6, 2003 (Seal) CURTIS R. LONG Prothonotary Deputy REQUESTING PARTY: Name JOSEPH A. GOLDBECK, JR., ESQUIRE Address: SUITE 5000 - MELLON INDEPENDENCE CENTER 701 MARKET STREET PHILADELPHIA, PA 19106 Attorney for: PLAINTIFF Telephone: 215-627-1322 Supreme Court ID No. 16132 Goldbeck McCafferty & McKeever BY: Joseph A. Goldbeck, Jr. Attorney'I.D. #16132 Sui;e 5000 - Mellon Independence Center. 701 Market Street Philadelphia, PA 19106 215-627-1322 Attorney for Plaintiff CITIF1NANCIAL SERVICES 1NC. 7467 New Ridge Road Suite 222 Hanover, MD 21076 VS. CHARLES E. LINDSEY JANET L. LINDSEY (Mortgagor(s) and Record Owner(s)) 1402 Rimer Highway Shippensburg, PA 17257 Plaintiff Defendant(s) 1N THE COURT OF cOMMON PLEAS of Cumberland County CIVIL ACTION - LAW ACTION OF MORTGAGE FORECLOSURI~ No. 03-3978 AFFIDAVIT PURSUANT TO RULE 3129 CIT1FINANCIAL SERVICES INC., Plaintiff in the above action, by its attorney, Joseph A. Goldbeck, Jr., Esquire, sets forth as of the date the praecipe for the writ of execution was filed the following information concerning the real property located at: 1402 Rimer Highway Shippensburg, PA 17257 1.Name and address of Owner(s) or Reputed Owner(s): CHARLES E. LINDSEY 1402 Rimer Highway Shippensburg, PA 17257 JANET L. LINDSEY 1402 Rimer Highway Shippensburg, PA 17257 2. Name and address of Defendant(s) in the judgmem: CHARLES E. LINDSEY 1402 Rimer Highway Shippensburg, PA 17257 JANET L. LINDSEY 1402 Rimer Highway Shippensburg, PA 17257 3. Name and last known address of every judgment creditor whose judgment is a record lien on the property to be sold: I DOMESTIC RELATIONS OF CUMBERLAND cOUNTY PO Box 320 Carlisle, PA 17013 PA DEPARTMENT OF PUBLIC WELFARE - Bure*[u of Child Support Enforcement Health and Welfare Bldg. - Room 432 P.O. Box 2675 Harrisburg, PA 17105-2675 FIRST SELECT CORP 5040 JOHNSON DRIVE PLEASANTON, CA 94566 GENERAL MOTORS ACCEPTANCE CORP 100 GALLERIA PKWY SU1TE 300 ATLANTA, GA 30339 4. Name and address of the last recorded holder of every mortgage of record: 5. Name and address of every other person who has any record interest in or record lien on the property and whose interest may be affected by the sale: 6. Name and address of every other person of whom the plaintiff has knowledge who has any record interest in the proper~y which may be affected by the sale. 7. Name and address of every other person of whom the plaintiff has knowledge who has any interest in the property which may be affected by the sale. ~ TENANTS/OCCUPANTS 1402 Rimer Highway Shippensburg, PA 17257 (attach separate sheet if more space is needed) I verify that the statements made in this affidavit are true and correct to the best of my personal knowledge or information and belief. I understand that false statements herein are made subject to the penalties of 18 Pa. C.S. Section 4904 relating to unsworn falsification to authorities. DATED: October L 2003 ~Y:° Jnl°eS~h°rAi~ GOLDBE Y & McKEEVER ., Esq. 03-3978 G~)LDBECK McCAFFERTY & McKEEVER BY: Joseph A. Goldbeck, Jr. Attorney I.D.#16132 Suite 5000- Mellon Independence Center 701 Market Street Philadelphia, PA 19106 215-627-1322 Attorney for Plaintiff CITIF1NANCIAL SERVICES INC. 7467NewRidge Road Suim 222 Hanover, MD21076 VS. CHARLES E. L1NDSEY JANET L. LINDSEY Mortgagor(s) and Record Owner(s) 1402 Rimer Highway Shippensburg, PA 17257 Plaintiff Defendant(si IN THE COURT OF COMMON PLEAS of Cumberland County CIVIL ACTION - LAW ACTION OF MORTGAGE FORECLOSURE Term No. 03-3978 THIS LAW FIRM IS A DEBT COLLECTOR AND WE ARE ATTEMPTING TO COLLECT A DEBT. THIS NOTICE IS SENT TO YOU IN AN ATTEMPT TO COLLECT A DEBT. ANY INFORMATION OBTAINED FROM YOU WILL BE USED FOR THAT PURPOSE. TO: NOTICE OF SHERIFF'S SALE OF REAL PROPERTY LINDSEY, CHARLES E. CHARLES E. LINDSEY 1402 Rimer Highway Shippensburg, PA 17257 Your house at 1402 Rimer Highway, Shippensburg, PA 17257 is scheduled to be sold at Sheriffs Sale on Wednesday, March 03, 2004, at 10:00 AM, in Commissioners Hearing Rm 2nd FL Courthouse to enforce the court judgment of $171,212.31 obtained by CITIFINANCIA L SERVICES INC. against you. NOTICE OF OWNER'S RIGHTS YOU MAY BE ABLE TO PREVENT THIS SHERIFF'S SAI,E To prevent this Sheriffs Sale you must take immediate action: 1. The sale will be cancelled if you pay to CITIFINANCIAL SERVICES INC., the back payments, late charges, costs and reasonable attorney's fees due. To fred out how much you must pay call: 215-627-1322 2. You may be able to stop the sale by filing a petition asking the Court to strike or open judgment, if the judgment was improperly entered. You may also ask the Court to poslpone the sale for good cause. 03-3978 3. You may also be able to stop the sale through other legal proceedings. You may need an attorney to assert your rights. The sooner you contact one, the more chance you will have of stopping the sale. (See notice below on how to obtain an attorney). YOU MAY STILL BE ABLE TO SAVE YOUR PROPERTY AND YOU HAVE OTHER RIGHTS EVEN IF THE SHERIFF'S SALE DOES NOT TAKE PLACE. 1. If the Sheriffs Sale is not stopped, your property will be sold to the highest bidder. You may find out the price bid price by calling the Sheriffof 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 tifll amount due in the sale. To find out if this has happened, you may call the Sheriff of 717-240-6390. 4. If the amount due from the Buyer is not paid to the Sheriff, you will remain the owner of the property as if the sale never happened. 5. You have a right to remain in the property until the full amount due is paid to the Sheriff and the Sheriff gives a deed to the buyer. At that time, the buyer may bring legal proceedings to evict you. 6. You may be entitled to a share of the money which was paid for your house. A schedule of distribution of the money bid for your house will be filed by the Sheriff thirty (30) days from the date of the 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 schedule of distribntion is filed. 7. You may also have other rights and defenses, or ways of getting your house back, if you act immediately after the sale. YOU SHOULD TAKE THIS PAPER TO YOUR LAWYER AT ONCE. IF YOU DO NOT HAVE A LAWYER OR CANNOT AFFORD ONE, GO TO OR TELEPHONE ]7HE OFFICE LISTED BELOW TO FIND OUT WHERE YOU CAN GET LEGAL HELP. LEGAL SERVICES INC 8 Irvine Row Carlisle, PA 17013 CUMBERLAND COUNTY BAR ASSOCIATION 2 Liberty Avenue Carlisle, PA 17013 03-3978 GOLDBECK McCAFFERTY & McKEEVER BY: .J6~eph A. Goldbeck, Jr. ~orney I.D.#16132 uite 5000- Mellon Independence Center 701 Market Street Philadelphia, PA 19106 215-627-1322 Attorney for Plaintiff CITIF1NANCIAL SERVICES 1NC. 7467 New Ridge Road Suite 222 Hanover, MD 21076 VS. CHARLES E. LINDSEY JANET L. LINDSEY Mortgagor(s) and Record Owner(s) 1402 Rimer Highway Shippensburg, PA 17257 Plaintiff De£endant(s IN THE COURT OF COMMON PLEAS of Cumberland County CWIL ACTION - LAW ACTION OF MORTGAGE FORECLOSURE Tenll No. 03-3978 THIS LAW FIRM IS A DEBT COLLECTOR AND WE ARE ATTEMPTING TO COLLECT A DEBT. THIS NOTICE IS SENT TO YOU IN AN ATTEMPT TO COLLECT A DEBT. ANY INFORMATION OBTAINED FROM YOU WILL BE USED FOR THAT PURPOSE. TO: NOTICE OF SHERIFF'S SALE OF REAL PROPERTY LINDSEY, JANET L. JANET L. LINDSEY 1402 Rimer Highway Shippensburg, PA 17257 Your house at 1402 Rimer Highway, Shippensburg, PA 17257 is scheduled to be sold at Sheriffs Sale on Wednesday, March 03, 2004, at 10:00 AM, in Commissioners Hearing Ran 2nd FL Courthouse to enforce the court judgment of $171,212.31 obtained by CITIFINANCIAL SERVICE S INC. against you. NOTICE OF OWNER'S RIGHTS yOU MAY BE ABLE TO PREVENT THIS SHERIFF'S SAI,~ To prevent this Sheriffs Sale you must take immediate action: 1. The sale will be cancelled if you pay to CITIFINANCIAL SERVICES INC., the back payments, late charges, costs and reasonable attorney's fees due. To fred out how much you must pay call: 215-627-1322 2. You may be able to stop the sale by filing a petition asking the Court to strike or open judgment, if the judgment was improperly entered. You may also ask the Court to postpone the sale for good cause. 03-3978 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 RIGHT,q EVEN IF THE SHERIFF'S SALE DOES NOT TAKE PLACE. l. If the Sheriffs Sale is not stopped, your property will be sold to the highest bidder. You may find out the price bid price by calling the Sheriffof717-240-6390. 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 Sheriffthe full amount due in the sale. To find out if this has happened, you may call the Sheriff of 717-240-6390. 4. If the amount due fi.om the Buyer is not paid to the Sheriff, you will remain the owner of the property as if the sale never happened. 5. You have a right to remain in the property until the full amount due is paid to the Sheriff and the Sheriffgives a deed to the buyer. At that time, the buyer may bring legal proceedings to evict you. 6. You may be entitled to a share of the money which was paid for your house. A schedule of distribution of the money bid for your house will be filed by the Sheriff thirty (30) days fi.om the date of the 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 Sheriff within ten (10) days after the schedule of distribution is filed. 7. You may also have other rights and defenses, or ways of getting your house back, if you act immediately after the sale. YOU SHOULD TAKE THIS PAPER TO YOUR LAWYER AT ONCE. IF YOU DO NOT HAVE A LAWYER OR CANNOT AFFORD ONE, GO TO OR TELEPHONE TIlE OFFICE LISTED BELOW TO FIND OUT WHERE YOU CAN GET LEGAL HELP. LEGAL SERVICES INC 8 Irvine Row Carlisle, PA 17013 CUMBERLAND COUNTY BAR ASSOCIATION 2 Liberty Avenue Carlisle, PA 17013 GOLDBECK McCAFFERTY & McKEEVER BY: Josep~a A. Goldbeck, Jr. Attorney I.D.#16132 Suite 5000 - Mellon Independence Center. 701 Market SWeet Philadelphia, PA 19106 215-627-1322 Attorney for Plaintiff CITIFINANCIAL SERVICES 1NC. 7467 New Ridge Road Suite 222 Hanover, MD 21076 Plaintiff VS. CHARLES E. L1NDSEY JANET L. LINDSEY Mortgagor(s) and Record Owner(s) 1402 Rimer Highway Shippensburg, PA 17257 Defendant(s) IN THE COURT OF COMMON PLEAS of Cumberland County CIVIL ACTION - LAW ACTION OF MORTGAGE FORECLOSURE No. 03-3978 CERTIFICATE OF SERVICE. PURSUANT TO Pa.R.C.P. 3129.2 (e) (2) Joseph A. Goldbeck, Jr., Esquire, Attorney for Plaintiff, hereby certifies that service on the Defendants of the Notice of Sheriff Sale was made by: ............... ~ ~ tcony of return attached). ~} Personal Service by tl~e ~nerlrr's L/illc~ __ . x r Certified mail by Joseph A. Goldbeck, Jr. (original green Postal return receipt attached). Certified mail by Sheriffs Office. Ordinary mail by Joseph A. Goldbeck, Jr., Esquire to Attorney for Defendant(s) of record (proof of mailing attached). Acknowledgment of Sheriffs Sale by Attorney for Defendant(s) (proof of acknowledgment attached). Ordinary mail by Sheriffs Office to Attorney for Defemtant(s) of record. IF SERVICE WAS ACCOMPLISHED BY COURT ORDER. ( ) Premises was posted by Sheriffs Office/competent adult (copy of return attached). ( ) Certified Mail & ordinary mail by Sheriffs Office (copy °f return attached)' ( ) Certified Mail & ordinary mail by Joseph A. Goldbeck, Jr. (original receipt(s) for Certified Mail attached). Pursuant to the Affidavit under Rule 3129 (copy attached), service on all lienholders (if any) has been made by ordinary mail by Joseph A. Goldbeck, Jr., Esquire (copies of proofs of mailing attached). The undersigned understands that the statements herein are subject to the penalties provided by 18 P.S. Section 4904. espegtful~ s_ubn~itt ed, A~rrney for Plaintiff Citifinancial Services Inc. VS Charles E. Lindsey and Janet L. Lindsey In The Court of Common Pleas of Cumberland County, Pennsylvania Writ No. 2003-3978 Civil Term Robert Bitner, Deputy Sheriff, who being duly sworn according to law, states that on December 03, 2003 at 4:04 o'clock PM, he served a true copy of the within Real Estate Writ, Notice and Description, in the above entitled action, upon the within named defendants, to wit: Charles E. Lindsey and Janet L. Lindsey,. by making known unto Charles Lindsey, personally and adult in charge for Janet Lindsey, at 129 Rustic Drive, Shippensburg, Cumberland County, Pennsylvania, its contents and at the same time handing to him personally the said true and correct copy of the same. Gerald Worthington, Deputy Sheriff, who being duly sworn according to law, states that on January 13, 2004 at 11:09 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 Charles E. Lindsey and Janet L. Lindsey located at 1402 Ritner Highway, Shippensburg, 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 Sheriffmailed a notice of the pendency of the action to the within named defendant, to wit: Charles E. Lindsey, by regular mail to his last known address of P.O. Box 458, Shippensburg, PA 17257. This letter was mailed under the date of January 16, 2004 and never returned to the Sherift's Office. 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 mmled a notice of the pendency of th, action to the within named defendant, to wit: Janet L. Lindsey, by regular mail to her last known address of 129 Rustic Drive, Shippensburg, PA 17257. This letter was mailed under the date of January 12, 2004 and never returned to the Sheriff's Office. Sworn and subscribed to before me This _ day of 2004, A.D. Prothonotary R. Thomas Klin~, Sherif GOLDBECK McCAFFERTY & McKEEVER BY~ Joseph A. Goldbeck, Jr. Attorney I.D.#16132 Suite 5000 - Mellon Independence Center 701 Market Slreet philadelphia, PA 19106 215-627-1322 Attorney for Plaintiff C1TIFINANCIAL SERVICES INC. 7467 New Ridge Road Suite 222 Hanover, MD 21076 Plaintiff VS. CHARLES E. LINDSEY JANET L. LINDSEY Mortgagor(s) and Record Owner(s) 1402 Ritner Highway Shippensburg, PA 17257 Defendant(s) IN THE coURT OF COMMON PLEAS of Cumberland County CIVIL ACTION - LAW ACTION OF MORTGAGE FORECLOSURE Term No. 03-3978 _AFFIDAVIT pURSUANT TO RULE 3129. CITIFINANCIAL SERVICES INC., Plaintiff in the above action, by its attorney, Joseph A. Goldbeck, Jr., Esquire, · . . . . . ' real property sets forth as of the date the praec~pe for the writ of execution was filed the follounng reformation concerning the located at: 1402 Rimer Highway Shippensburg, PA 17257 l.Name and address of Owner(s) or Reputed Owner(s): CHARLES E. LINDSEY 1402 Rimer Highway Shippeosburg, PA 17257 JANET L. LINDSEY 1402 Rimer Highway Shippensburg, PA 17257 2. Name and address of Defendant(s) in the judgment: CHARLES E. LINDSEY 1402 Ritner Highway Shippansburg, PA 17257 JANET L. LINDSEY 1402 Rimer Highway Shippensburg, PA 17257 3. Name'and last known address of every judgment creditor whose judgment is a record lien on the property to be sold: DOMESTIC RELATIONS OF CUMBERLAND coUNTY PO Box 320 Carlisle, PA 17013 PA DEPARTMENT OF PUBLIC WELFARE - Bureau of Child Support Enforcement Health and Welfare Bldg. - Room 432 P.O. Box 2675 Harrisburg, PA 17105-2675 FIRST SELECT CORP 5040 JOHNSON DRIVE PLEASANTON, CA 94566 GENERAL MOTORS ACCEPTANCE CORP 100 GALLERIA PKWY SUITE 300 ATLANTA, GA 30339 4. Name and address of the last recorded holder of every mortgage of record: 5. Name and address of every other person who has any record interest in or record lien on the property and whose interest may be affected by the sale: 6. Name and address of every other person of whom the plaintiff has knowledge who has any record interest in the property which may be affected by the sale. 7. Name and address of every other person of whom the plaintiff has knowledge who has any interest in the property which may be affected by the sale. TENANTS/OCCUPANTS 1402 Rimer Highway Shippensburg, PA 17257 (attach separate sheet if more space is needed) I verify that the statementS made in this affidavit are true and correct to the best of my personal knowledge or information and belief. I understand that false statements here~n are made subject to the penalties of 18 Pa C S Sectton 4904 relating to unswom falsification to authorities. DATED: February 24, 2004 B~ Joseph A. Goldbeck, Jr., Esq. AttOrney for Plaintiff CITIF1NANCIAL SERVICES, 1NC., Plaimiff V. CHARLES E. LINDSEY and JANET L. LINDSEY,: Defendants : IN THE COURT OF COMMON PLEAS OF CUMBERLAND COUNTY, PENNSYLVANIA CIVIL ACTION - LAW NO. 03-3978 CIVIL TERM ORDER OF COURT AND NOW, this 13th day of May, 2004, upon consideration of the Exceptions of Third Party Purchaser, Central Penn Property Services, Inc., to Proposed Schedule of Distribution, a hearing is scheduled for Thursday, July 22, 2004, at 1:30 p.m., in Courtroom No. 1, Cumberland County Courthouse, Carlisle, Pennsylvania. BY THE COURT, ~rank Federman, Esq. Federman & Phelan, LLP 1617 JFK Blvd. Suite 1400 Philadelphia, PA 19103-1814 /Joseph A. Goldbeck, Jr., Esq. Goldbeck, McCafferty & McKeever 111 S. Independence Mall East Suite 500 Philadelphia, PA 19106 Attorney for Plaintiff v~aharles E. Lindsey net L. Lindsey 1402 Ritner Highway Shippensburg, PA 17257 Defendants, pro se o~ephen M. Hladik, Esq. 425 W. Main Street P.O. Box 0029 Lansdale, PA 19446-0029 Attorney for Central Penn Property Services, Inc. Cumberland County Sheriff's Office - Cumberland County Tax Claim Bureau ~/~ivian Coy 200 Airport Road Shippensburg, PA 17257 Tax Collector :rc CITIFINANCIAL : SERVICES, 1NC., : Plaintiff CHARLES E. LINDSEY and JANET L. LINDSEY, Defendants IN THE COURT OF COMMON PLEAS OF CUMBERLAND COUNTY, PENNSYLVANIA CIVIL ACTION - LAW NO. 03-3978 CIVIL TERM ORDER OF COURT AND NOW, this 25th day of May, 2004, upon consideration of the attached letter from Edward L. Schorpp, Esq., Solicitor for Cumberland County Sheriff's Office, the hearing previously scheduled for July 22, 2004, regarding the Exceptions of Third Party Purchaser, Central Penn Property Services, Inc., to Proposed Schedule of Distribution, is rescheduled to Wednesday, July 28, 2004, at 1:30 p.m., in Courtroom No. 1, Cumberland County Courthouse, Carlisle, Pennsylvania. BY THE COURT, J~/wesley Oler~Jr~, 't~ t~ . j. Frank Federman, Esq. Federman & Phelan, LLP 1617 JFK Blvd. Suite 1400 Philadelphia, PA 19103-1814 Joseph A. Goldbeck, Jr., Esq. Goldbeck, McCafferty & McKeever 111 S. Independence Mall East Suite 500 Philadelphia, PA 19106 Attorney for Plaintiff Charles E. Lindsey Janet L. Lindsey 1402 Ritner Highway Shippensburg, PA 17257 Defendants, pro se Stephen M. Hladik, Esq. 425 W. Main Street P.O. Box 0029 Lansdale, PA 19446-0029 Attorney for Central Penn Property Services, Inc. Edward L. Schorpp, Esq. Ten East High Street Carlisle, PA 17013 Solicitor for Cumberland County Sheriff's Office Cumberland County Tax Claim Bureau Vivian Coy 200 Airport Road Shippensburg, PA 17257 Tax Collector :rc M,~RTSON DEARDORFF ~/'ILLIAMS ,:~ OTTO MDW&O INI~ORi~TION · ADVICE · ADVOCACY TEN EAST HIGlt STREET CARLISLE. PENNSYLVANIA 17013 TELEPHONE (717) 243 3341 FACSIMILE (717) 243-1850 INTERNET www. mdwo.com May 24, 2004 ATTORNEYS & COUNSELLORS AT LAW WILLIAM F. MARTSON JOHN B. FOWLER II1 EDWARD L $CHORPP DANIEL K. DEARDORFF THOMAS J. WILLIAMS* IVO V. Otto III GEORGE B. FkLLER JR.* CARL C. RISCH DAVID A. FITZSIMONS DAVID R. GALLOWAY ANTHONY T. LUCIDO CHRISTOPHER E. RICE STEVEN J, SHANAHAN *BOARD CERTIFIED CIVIL TRIAL SPECIAL[ST Honorable J. Wesley Oler, Jr. Cumberland County Courthouse One Courthouse Square Carlisle, PA 17013 Citifinancial Services, Inc. v. Charles E. Lindsey and Janet L. Lindsey Civil Term No. 03-3978 Our File No. 10282.1 Dear Judge Oler: I write to you in my capacity as Solicitor to the Cumberland County SherifFs Office to request that the July 22, 2004, heating in the above mentioned :matter be i'escheduled for either the afternoon of July 28, 2004, or July 29, 2004. All of the necessaJ:y parties have agreed to reschedule the heating so long as the heating is rescheduled for a date before August 5, 2004. We appreciate your cooperation in allgwing this matter to be rescheduled. Very truly yours, MARTSON DEAtU)ORFF WILLIAMS & OTTO Edward L. SchOtpp ELS/em cc: Frank Federman, Esquire Joseph A. Goldbeck, Jr., Esquire Mr. Charles E. Lindsey Ms. Janet L. Lindsey Stephen M. Hladik, Esquire Cumberland County Tax Claim Bureau Vivian Coy, Tax Collector INFORMATION ADVICE ADVOCACY su cITIFINANCIAL SERVICES, INC., Plaintiff v CHARLES E. LINDSEY and JANET L. LINDSEY, DefendantS IN THE cOURT OF cOMMON PLEAS OF CUMBERLAND cOUNTY, PENNSYLVANIA CIVIL ACTION - LAW 03-3978 CIVIL TERM IN RE: EXCEPTIONS ORDER OF cOURT AND NOW, this 28th day of July, 2004, upon consideration of the Exceptions of Third Party Purchaser, Central Penn Property Services, Inc., to Proposed Schedule of Distribution, and following a hearing, the record is declared closed, and the matter is taken under advisement. Pursuant to a request <Df counsel in the person of Stephen M. Hladik, Esquire, on behalf of Central Penn Property Services, Inc., the exceptant is afforded a period of 14 days from today'S date within which to file an additional memorandum in support of its position. The Cumberland County Sheriff is afforded a period of 14 days thereafter within which to respond to the said brief. By the Court, esley Ole~L) Jr', Edward L. Schorpp, Esquire Ten East High Street Carlisle, PA 17013 solicitor for Cumberland County Sheriff's office ~tephen M. Hladik, Esquire 425 W. Main Street P.O. Box 0029 Lansdale, PA 19446-0029 Sheriff :mae STEPHEN M. HLADIK, ESQUIRE ATTORNEY I.D. NO. 66287 Kerns, Pearlstine, Onorato & Fath, LLP 425 W. Main Street P.O. Box 0029 Lansdale, PA 19446-0029 215-855-4165 Attorney for Central Penn Property Services, Inc. CITIFINANCIAL SERVICES, INC., Plaintiff, V. CHARLES E. LINDSEY and JANET L. LINDSEY Defendants. COURT OF COMMON PLEAS CUMBERLAND COUNTY No. 03-3978 _PRAEClE TO WITHDRAW EXCEPTION~ TO THE PROTHONOTARY: Kindly withdraw the Exceptions to Sheriff's Distributions filed by Central Penn Property Services, Inc. in the above-captioned matter. Kerns, Pea~//, Qnorato & Fath, LLP s/ tephen ~.//~-~'~1~ Attorney ~)_r. TCentr~ Penn Property Services, Inc. STEPHEN M. HLADIK, ESQUIRE ATTORNEY I.D. NO. 66287 ADAM L. KAYES, ESQUIRE ATTORNEY I.D. NO. 86408 Kerns, Pearlstine, Onorato & Fath, LLP 425 W. Main Street P.O. Box 0029 Lansdale, PA 19446-0029 215-855-4165 Attorney for Central Penn Property Services, Inc. ClTIFINANCIAL SERVICES, INC., : Plaintiff, V. CHARLES E. LINDSEY and JANET L. LINDSEY Defendants. COURT OF COMMON PLEAS CUMBERLAND COUNTY No. 03-3978 .CERTIFICATE OF SERVICE_ I, Stephen M. Hladik, Esquire, hereby certify that I served a true and correct copy of Central Penn Property Services, Inc.'s Praecipe to Withdraw Exceptions on the following by United States First Class mail, postage pre-paid on August 13, 2004: Edward L. Schorpp, Esquire Martson Deardorf Williams & Otto Ten East High Street Carlisle, PA 17013 Mr. & Mrs. Charles E. Lindsey P.O. Box 458 Shippensburg, PA 17257-0458 Dated: Michael T. McKeever, Esquire Goldbeck, McCafferty & McKeever Mellon Independence Center, Suite, 500 701 Market Street Philadelphia, PA 19106-'5~ ~;tephen M. H~dik, Esquire 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 Central Penn Property Services Inc is the grantee the same having been sold to said grantee on the 3rd day of March A.D., 2004, under and by virtue ora writ Execution issued on the 6th day of oct, A.D., 2003, out of the Court of Common Pleas of said County as of Civil Term, 2003 Number 3978, at the suit of Citifinancial Serv Inc against Charles E Lindsey & Janet L is duly recorded in Sheriff's Deed Book No. 262, Page 3377. 1N TESTIMONY WHEREOF, I have hereunto set my hand and seal of said office this 02 ~ ~ day of Zg~~corder of Deeds Citifinancial Services Inc. VS Charles E. Lindsey and Janet L. Lindsey In The Court of Common Pleas of Cumberland County, Pennsylvania Writ No. 2003-3978 Civil Term Robert Bitner, Deputy Sheriff, who being duly sworn according to law, states that on December 03, 2003 at 4:04 o'clock PM, he served a true copy of the within Real Estate Writ, Notice and Description, in the above entitled action, upon the within named defendants, to wit: Charles E. Lindsey and Janet L. Lindsey, by making known unto Charles Lindsey, personally and adult in charge for Janet Lindsey, at 129 Rustic Drive, Shippensburg, Cumberland County, Pennsylvania, its contents and at the same time handing to him personally the said true and correct copy of the same. Gerald Worthington, Deputy Sheriff, who being duly sworn according to law, states that on January 13, 2004 at 11:09 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 Charles E. Lindsey and Janet L. Lindsey located at 1402 Ritner Highway, Shippensburg, 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: Charles E. Lindsey, by regular mail to his last known address of P.O. Box 458, Shippenshurg, PA 17257. This letter was mailed under the date of January 16, 2004 and never remmed to the Sheriff's Office. 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 Sheriffmailed a notice of the pendency of the action to the within named defendant, to wit: Janet L. Lindsey, by regular mail to her last known address of 129 Rustic Drive, Shippensburg, PA 17257. This letter was mailed under the date of January 12, 2004 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 ~otice 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 3, 2004 at 10:00 o'clock A.M. He sold the same for the sum of $75,901.00 to Central Penn Property Services, Inc. It being the highest bid and best price received fbr the same, Central Penn Property Services, Inc. of 100 South 7th Street, Akron, PA 1'7501, being the buyers in this execution, paid to Sheriff R. Thomas Kline the sum of $81,363.96. Sheriff's Costs: Docketing $30.00 Poundage 1518.02 Posting Bills 15.00 Goldbeck McCafferty & McKeever B.Y: Joseph A. Goldbeck, Jr. Attorney I.D. #16132 Suite 5000 - Mellon Independence Center. 701 Market Street Philadelphia, PA 19106 215-627-1322 Attorney for Plaintiff CITIF1NANCIAL SERVICES INC. 7467 New Ridge Road Suite 222 Hanover, MD 21076 VS. CHARLES E. LINDSEY JANET L. LINDSEY (Mortgagor(s) and Record Owner(s)) 1402 Ritner Highway Shippensburg, PA 17257 Plaintiff Defendant(s) 1N THE COURT OF COMMON PLEAS of Cumberland County CIVIL ACTION - LAW ACTION OF MORTGAGE FORECLOSURE No. 03-3978 AFFIDAVIT PURSUANT TO RULE 3129 CITIFINANCIAL SERVICES INC., Plaintiff in the above action, by its attorney, Joseph A. Goldbeck, Jr., Esquire, sets forth as of the date the praecipe for the writ of execution was filed the following information concerning the real property located at: 1402 Rimer Highway Shippensburg, PA 17257 1.Name and address of Owner(s) or Reputed Owner(s): CHARLES E. LINDSEY 1402 Rimer Highway Shippensburg, PA 17257 JANET L. LINDSEY 1402 Rimer Highway Shippensburg, PA 17257 2. Name and address of Defendant(s) in the judgment: CHARLES E. LINDSEY 1402 Rimer Highway Shippensburg, PA 17257 JANET L. LINDSEY 1402 Rimer Highway Shippensburg, PA 17257 3. Name and last known address of every judgment creditor whose judgment is a record lien on the property to be sold: DOMESTIC RELATIONS OF CUMBERLAND COUNTY PO Box 320 Carlisle, PA 17013 PA DEPARTMEN~ OF PUBLIC WELFAI~E - Bureau of Child Support Enforcement Health and WElfare Bldg. - Room 432 P.O. Box 2675 Harrisburg, PA 17105-2675 FIRST SELECT CORP 5040 JOHNSON DRIVE PLEASANTON, CA 94566 GENERAL MOTORS ACCEPTANCE CORP 100 GALLERIA PKWY SUITE 300 ATLANTA, GA 30339 4. Name and address of the last recorded holder of every mortgage of record: 5. Name and address of every other person who has any record interest in or record lien on the property and whose interest may be affected by the sale: 6. Name and address of every other person of whom the plaintiff has knowledge who has any record interest in the property which may be affected by the sale. 7. Name and address of every other person of whom the plaintiff has knowledge who has any interest in the property which may be affected by the sale. TENANTS/OCCUPANTS 1402 Rimer Highway Shippensburg, PA 17257 (attach separate sheet if more space is needed) I verify that the statements made in this affidavit are true and correct to the best of my pemonal knowledge or information and belief. I understand that false statements herein are made subject to the penalties of 18 Pa. C.S. Section 4904 relating to unswom falsification to authorities. DATED: October 1, 2003 GOLDBEC~M~ ~ & McKEEVER BY: Joseph AG' i~ecl~ Jr., Esq. Attorney for Pl~nqif~ / 03-3978 3. You may also be able to stop the sale through other legal proceedings. You may need an attorney to assert your rights. The sooner you contact one, the more chance you will have of stopping the sale. (See notice below on how to obtain an attorney). YOU MAY STILL BE ABLE TO SAVE YOUR PROPERTY AND YOU HAVE OTHER RIGHTS EVEN IF THE SHERIFF'S SALE DOES NOT TAKE PLACE. 1. If the Sheriffs Sale is not stopped, your property will be sold to the highest bidder. You may find out the price bid price by calling the Sheriff of 717-240-6390. 2. You may be able to petition the Court to set aside the sale if the bid price was grossly inadequate compared to the value of your property. 3. The sale will go through only if the buyer pays the Sheriff the full amount due in the sale. To f'md out if this has happened, you may call the Sheriff of 717-240-6390. 4. If the amount due from the Buyer is not paid to the Sheriff, you will remain the owner of the property as if the sale never happened. 5. You have a right to remain in the property until the full amount due is paid to the Sheriff and the Sheriff gives a deed to the buyer. At that time, the buyer may bring legal proceedings to evict you. 6. You may be antitled to a share of the money which was paid for your house. A schedule of distribution of the money bid for your house will be filed by the Sheriff thirty (30) days from the date of the 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 schedule of distribution is filed. 7. You may also have other rights and defenses, or ways of getting your house back, if you act immediately after the sale. YOU SHOULD TAKE THIS PAPER TO YOUR LAWYER AT ONCE. IF YOU DO NOT HAVE A LAWYER OR CANNOT AFFORD ONE, GO TO OR TELEPHONE THE OFFICE LISTED BELOW TO FIND OUT WHERE YOU CAN GET LEGAL HELP. LEGAL SERVICES INC 8 Irvine Row Carlisle, PA 17013 CUMBERLAND COUNTY BAR ASSOCIATION 2 Liberty Avenue Carlisle, PA 17013 Advertising 15.00 Acknowledging Deed 30.00 Auctioneer 10.00 Law Library .50 Prothonotary 1.00 Mileage 27.60 Levy 15.00 Surcharge 30.00 Law Journal 204.95 Patriot News 232.51 Share of Bills 29.32 Distribution of Proceeds 25.00 Sheriffs Deed 39.50 $ 2,223.40 Swom and subscribed to before me S~o Ar~wers: This ~/~/- dayof ~r" ll(~on~t~y R. Thomas Kline, Sheriff 2004, A.D. Real Esta~t Deputy PA DEPARTMEN~ OF PUBLIC WELF.AP~E - Bureau of Child Support Enforcement Health and Wqlfare Bldg. - Room 432 P.O. Box 2675 Harrisburg, PA 17105-267b FIRST SELECT CORP 5040 JOHNSON DRIVE PLEASANTON, CA 94566 GENERAL MOTORS ACCEPTANCE CORP 100 GALLERIA PKWY SUITE 300 ATLANTA, GA 30339 4. Name and address of the last recorded holder of every mortgage of record: 5. Name and address of every other person who has any record interest in or record lien on the property and whose interest may be affected by the sale: 6. Name and address of every other person of whom the plaintiff has knowledge who has any record interest in the property which may be affected by the sale. 7. Name and address of every other person of whom the plaintiff has knowledge who has any interest in the property which may be affected by the sale. TENANTS/OCCUPANTS 1402 Rimer Highway Shippensburg, PA 17257 (attach separate sheet ii! more space is needed) I verify that the statements made in this affidavit are true and correct to the best of my personal knowledge or information and belief. I understand that false statements herein are made subject to the penalties of 18 Pa. C.S. Section 4904 relat'mg to unsworn falsification to authorities. DATED: October 1, 2003 GOLDBE~Y & McKEEVER BY: Joseph A.~ i~ecl~ Jr., Esq. Attomey for PI~itY~ / 03-3978 GOLDBECK McCAFFERTY & MCK~EVER 4 BY: Joseph A. Goldbeck, Jr. Attomey I.D.#16132 Suite 5000- Mellon Independence Center 701 Market Street Philadelphia, PA 19106 215-627-1322 Attorney for Plaintiff CIT1F1NANCIAL SERVICES 1NC. 7467 New Ridge Road Suite 222 Hanover, MD 21076 Plaintiff vs. CHARLES E. LINDSEY JANET L. LINDSEY Mortgagor(s) and Record Owner(s) 1402 Ritner Highway Shippensburg, PA 17:257 IN THE COURT OF COMMON PLEAS of Cumberland County CiVIL ACTION - LAW ACTION OF MORTGAGE FORECLOSURE Term No. 03-3978 Defendant(s) THIS LAW FIRM IS A DEBT COLLECTOR AND WE ARE ATTEMPTING TO COLLECT A DEBT. THIS NOTICE IS SENT TO YOU IN AN ATTEMPT TO COLLECT A DEBT. ANY INFORMATION OBTAINED FROM YOU WILL BE USED FOR THAT PURPOSE. NOTICE OF SHERIFF'S SALE OF REAL PROPERTY TO: L1NDSEY, CHARLES E. CHARLES E. LINDSEY 1402 Ritner Highway Shippensburg, PA 17257 Your house at 1402 Ri~er Highway, Shippensburg, PA 17257 is scheduled to be sold at Sheriffs Sale on Wednesday, March 03, 2004, at 10:00 AM, in Commissioners Hearing Pan 2nd FL Courthouse to enforce the court judgment of $171,212.31 obtained by CITIFINANCIAL SERVICES 1NC. against you. NOTICE OF OWNER'S RIGHTS YOU MAY BE ABLE TO PREVENT THIS SHERIFF'S SALE To prevent this Sheriffs Sale you must take immediate action: 1. The sale will be cancelled if you pay to CITIFINANCIAL SERVICES INC., the back payments, late charges, costs and reasonable attorney's fees due. To find out how much you must pay call: 215-627-1322 2. You may be able to stop the sale by filing a petition asking the Court to strike or open judgment, if the judgment was improperly entered. You may also ask the Court to postpone the sale for good cause. 03-3978 3. You may also be able to stop the sale through other legal proceedings. You may need an attorney to assert your rights. The sooner you contact one, the more chance you will have of stopping the sale. (See notice below on how to obtain an attorney). YOU MAY STILL BE ABLE TO SAVE YOUR PROPERTY AND YOU HAVE OTHER RIGHTS EVEN IF THE SHERIFF'S SALE DOES NOT TAKE PLACE. 1. If the Sheriffs Sale is not stopped, your property will be sold to the highest bidder. You may find out the price bid price by calling the Sheriff of 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 araotmt due in the sale. To fred out if this has happened, you may call the Sheriff of 717-240-6390. 4. If the amount due from the Buyer is not paid to the Sheriff, you will remain the owner of the property as if the sale never happened. 5. You have a right to remain in the property until the full amount due is paid to the Sheriff and the Sheriff gives a deed to the buyer. At that time, the buyer may bring legal proceedings to evict you. 6. You may be entitled to a share of the money which was paid for your house. A schedule of distribution of the money bid for your house will be filed by the Sheriffthirty (30) days from the date of the 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 afier the schedule of distribution is filed. 7. You may also have other rights and defenses, or ways of getting your house back, if you act immediately atter the sale. YOU SHOULD TAKE THIS PAPER TO YOUR LAWYER AT ONCE. IF YOU DO NOT HAVE A LAWYER OR CANNOT AFFORD ONE, GO TO OR TELEPHONE THE OFFICE LISTED BELOW TO FIND OUT WI-IERE YOU CAN GET LEGAL HELP. LEGAL SERVICES [NC 8 Irvine Row Carlisle, PA 17013 CUMBERLAND COUNTY BAR ASSOCIATION 2 Liberty Avenue Carlisle, PA 17013 GOLDBECK McCAFFERTY & McKEEVER BY: Joseph A. Goldbeck, Jr. Attorney I.D.#16132 ' Suite 5000- Mellon Independence Center 701 Market Street Philadelphia, PA 19106 215-627-1322 Attorney for Plaintiff CITIF1NANCIAL SERVICES INC. 7467 New Ridge Road Sui~ 222 Hanover, MD 21076 Plaintiff vs. CHARLES E. LINDSEY JANET L. LINDSEY Mortgagor(s) and Record Owner(s) 1402 Ritner Highway Shippensburg, PA 17257 IN THE COURT OF COMMON PLEAS of Cumberland County CIVIL ACTION - LAW ACTION OF MORTGAGE FORECLOSURE Term No. 03-3978 Defendant(s) THIS LAW FIRM IS A DEBT COLLECTOR AND WE ARE ATTEMPTING TO COLLECT A DEBT. THIS NOTICE IS SENT TO YOU IN AN ATTEMPT TO COLLECT A DEBT. ANY INFORMATION OBTAINED FROM YOU WILL BE USED FOR THAT PURPOSE. NOTICE OF SHERIFF'S SALE OF REAL PROPERTY TO: LINDSEY, JANET L. JANET L. LINDSEY 1402 Rimer Highway Shippensburg, PA 17257 Your house at 1402 Rimer Highway, Shippensburg, PA 17257 is scheduled to be sold at Sheriffs Sale on Wednesday, March 03, 2004, at 10:00 AM, in Commissioners Hearing Rm 2nd FL Courthouse to enfome the court judgment of $171,212.31 obtained by CITIF1NANCIAL SERVICES INC. against you. NOTICE OF OWNER'S RIGHTS YOU MAY BE ABLE TO PREVENT THIS SHERIFF'S SALE To prevent this Sheriffs Sale you must take immediate action: 1. The sale will be cancelled if you pay to CIT1FINANCIAL SERVICES 1NC., the back payments, late charges, costs and reasonable attorney's fees due. To fred out how much you must pay call: 215-627-1322 2. You may be able to stop the sale by filing a petition asking the Court to strike or open judgment, if the judgment was improperly entered. You may also ask the Court to postpone the sale for good cause. 03-3978 3. You may also be able to stop the sal~ t~ou~ other legal proceedings. You may need an attorney to assert your rights. The sooner you contact one, the more chance you will have of stopping the sale. (See notice below on how to obtain an attorney). YOU MAY STILL BE ABLE TO SAVE YOUR PROPERTY AND YOU HAVE OTHER RIGHTS EVEN IF THE SHERIFF'S SALE DOES NOT TAKE PLACE. 1. If the Sheriffs Sale is not stopped, your property will be sold to the highest bidder. You may find out the price bid price by calling the Sheriffof717-240-6390. 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 properly. 3. The sale will go through only if the buyer pays the Sheriff the full mount due in the sale. To find out if this has happened, you may call the Sheriff of 717-240-6390. 4. If the amount due from the Buyer is not paid to the Sheriff, you will remain the owner offue property as if the sale never happened. 5. You have a right to remain in the property until the full amount due is paid to the Sheriff and the Sheriffgives 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 Sheriffthirty (30) days from the date of the Sheriff's Sale. This schedule will state who will be receiving that money. The money will be paid out in accordance with this schedule unless exceptions (reasons why the proposed distribution is wrong) are filed with the Sheriffwithin ten (10) days after the schedule of distribution is filed. 7. You may also have other rights and defenses, or ways of getting your house back, if you act immediately after the sale. YOU SHOULD TAKE THIS PAPER TO YOUR LAWYER AT ONCE. IF YOU DO NOT HAVE A LAWYER OR CANNOT AFFORD ONE, GO TO OR TELEPHONE THE OFFICE LISTED BELOW TO FIND OUT WHERE YOU CAN GET LEGAL HELP. LEGAL SERVICES INC 8 Irvine Row Carlisle, PA 17013 CUMBERLAND COUNTY BAR ASSOCIATION 2 Liberty Avenue Carlisle, PA 17013 and of B~O, WRIT OF EXECUTION and/or ATTACHMENT COMMONWEALTH OF PENNSYLVANIA~ "~ NO 03-3978 Civil COUNTY OF CUMBERLAND) CIVIL ACTION - LAW TO THE SHERIFF OF CUMBERLAND COUNTY: To satisfy the debt, interest and costs due CITIFINANCIAL SERVICES, INC., Plaintiff (s) From CHARLES E. LINDSEY AND JANET L. LINDSEY, (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 delivering any property of the defendant (s) or otherwise disposing thereof; (3) If property of the defendant(s) not levied upon an subject to attachment is found in the possession of anyone other than a named garnishee, you are directed to notify him/her that he/she has been added as a garnishee and is enjoined as above stated. Amount Due $171,212.31 Interest FROM 1/17/03 TO 10/1/03 AT 10.1280% Atty's Corem % Atty Paid $139.80 Plaintiff Paid Date: OCTOBER 6, 2003 (Seal) L.L. $.50 Due Prothy $1.00 Other Costs CURTIS R. LONG Prothono~;~ Deputy REQUESTING PARTY: Name JOSEPH A. GOLDBECK, JR., ESQUIRE Address: SUITE 5000 - MELLON INDEPENDENCE CENTER 701 MARKET STREET PHILADELPHIA, PA 19106 Attorney for: PLAINTIFF Telephone: 215-627-1322 Supreme Court ID No. 16132 Real Estate Sale # 24 On November 13, 2003 the sherifflevied upon the defendant's interest in the real property situated in Southampton Township, Cumberland County, PA Known and numbered as 1402 Ritner Highway, Shippensburg, more fully described on Exhibit "A" filed with this writ and by this reference incorporated herein. Date: November 13, 2003 Real Estat~ Deputy THE PATRIOT NEWS THESUNDAY PATRIOT NEWS Proof of Publication Under Ac~ No. 587, &opmved May 16, 1929 Commonwealth of Pennsylvania, County of Dauphin} ss Michael Morrow, being duly sworn according to law, deposes and says: That he is the Controller of The Patriot News Co., a corporation organized and existing under the laws of the Commonwealth of Pennsylvania, with its principal office and place of business at 812 to 818 Market Street, in the City of Harrisburg, County of Dauphin, State of Pennsylvania, owner and publisher of The Patriot-News and The Sunday Patriot-News newspapers of general cimulation, 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 on the 20th and 27th day(s) of January and the 3rd day(s) of February 2004. 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 Dau~~ok "M", Volume 14, Page 317. PUBLICATION COPY Sworn to and subscribed befor~ rr~/'tl~s 23rd dayIFebr.~'r~004 A.D. S A L E #24 I .- -.---- RBAL F..~TATE ~ALIE No. E4 Ci~ O~ Han~sburg, Oauplainvv.my ,v l _ ~/_ _'. ~. ] . W~1,2~4~ . M~CommisslonExpiresJune6,2006 [ NO'PARY PUBLIC iVember,~A.oda~,onOfNolafl~ly commission expires June 6, 2006 CUMBERLAND COUNTY SHERIFFS OFFICE CUMBERLAND COUNTY COURTHOUSE CARLISLE, PA. 17013 U;$, Rou~ I1 at ~'imer~eti~a ~t~ 'l~ 1~ip ~ :32~ ~ 19 ~ 31 $ 232.51 ~ 4~ ~ ~ ~39,~ f~ ~ Publisher's Receipt for Advertising Cost · nt~ n~)~o ~ imat~ , publisher of The Patriot-News and The Sunday Patriot-News, newspapers of general ~'~.10~s~m~tv/'~am receipt of the aforesaid notice and publieation eosts and certifies that tho same have ~ls~q/~ ._.NF~__ 4½ ~ 3 j mi~a~~ e ~~ofO~S. By .................................................................... ~st 155.00 f~t to a ~tik tie point a~d place of CO~I~TIN6 of 0.910 ~ ~ o~ I~ss. Statement of Advertising Costs To THE PATRIOT-NEWS CO., Dr. For publishing the notice or publication attached hereto on the above stated dates Total PROOF OF PUBLICATION OF NOTICE IN CUMBERLAND LAW JOURNAL (Under Act No. 587, approved May 16, 1929), P. L. 1784 STATE OF PENNSYLVANIA : COUNTY OF CUMBERLAND : SS. 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 Janua .fy 2, 1952, and designated by the local courts as the official legal periodical for the publication of all legal notices, and has, since January 2, 1952, been regularly issued weekly in the said County, and that the printed notice or publication attached hereto is exactly the same as was printed in the regular editions and issues of the said Cumberland Law Journal on the following dates, viz: JANUARY 16, 23, 30, 2004 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 tree. RE~L E~TATE ~LE NO. 24 Writ No. 2003-3978 Civil Citiflnanclal Services Inc. VS. Charles E. Llndsey and Janet L. Lindsey Atty.: Joseph Goldbeck ALL that tract of ground situate in Southampton Township, Cumber- land County, Pennsylvania, more particularly bounded and described as follows: BEGINNING at a nail in the cen- terline of U.S. Route 11 at its inter- section with Township Road T-320; thence over the centerllne of Town- ship Road T-320 South 19 degrees 31 minutes 54 seconds East 185.00 feet to a railroad spike; thence along Lot No. 8 on subdivision plan for abe Coyn ditor SWORN TO AND SUBSCRIBED before me this 30 day of JANUARY 2004 · N o~A~ll:t, lO/l~y SEA L ff LOIS E, SNYDER, Nota~'/Public Carlisle Bom, Cumberland County My Commission Expires March $, 2005 Citifinancial Services Inc. Charles E. Lindsey and Janet L. Lindsey Atty,; Joseph Goldbeck ALL that tract of ground situate in Southampton Township, Cumber- land County, Pennsylvania, more particularly bounded and described as follows: BEGINNING at a nail in the cen- terline of U.S. Route 11 at its inter- section with Township Road thence over the centerline of Town- ship Road T 320 South 19 degrees 31 minutes 54 seconds East 185.00 feet to a railroad spike; thence Lot No. 8 on subdivision plan for William and Mary Craig North 71 degrees 33 minutes 49 seconds East 239.65 feet Ipassing through a pin on line set 14.02 feet from the aforesaid railroad spike) to an iron pin; thence aiong Lot NO. 10 subdi~sion plan of William and Mary Craig North 41 degrees 31 minutes 25 seconds West 231.32 feet to a nail in the centerline of U.S. Route l 1 /passing through a pin on line set 25.63 feet from the aforesaid centerline nail); thence over the centerline of U.S. R~ute 11 South 61 degrees 13 minutes 06 seconds West 155.00 feet to a mall, the point and place of BEGINNING. CONSISTING of 0.910 acres, more or less. SWORN TO AND 30 day of LOIS E. SNYD Carlisle Bom, C My Commission E AMENDED SCHEDULE OF DISTRIBUTION SALE NO. 24 Date Filed: April 27, 2004 Writ No. 2003-3978 Civil Term Citifinancial Services Inc. VS Charles E. Lindsey and Janet L. Lindsey Sale Date: Buyer: Bid Price: March 3, 2004 Central Penn Property Services, Inc. $75,901.00 Real Debt: $171,212.31 Interest: 12,210.07 Attorney Costs: 139.80 Total: $183,562.18 · DISTRIBUTION: Receipts: Cash on account (11/13/03): Cash on account (03/03/04): Cash on account (03/19/04): $ 1,500.00 10,000.00 71,363.96 Total Receipts: $82,863.96 Disbursements: Sherift~s Costs Legal Search State Transfer Tax Local Transfer 'Fax Cumberland County Tax Claim Bureau Vivian Coy, Tax Collector Attorney Joseph Goldbeck Citifinancial Services, Inc. $ 2,223.40 200.00 1,872.47 1,872.47 2,581.16 437.26 1,500.00 72,177.20 Total Disbursements: Balance for distribution: ($82,863.96) 0.00 So Answers: R. Thomas Kline Sheriff SCHEDULE OF DISTRIBUTION SALE NO. 24 Date Filed: April 2, 2004 Writ No. 2003-3978 Civil Term Citifinancial Services Inc. VS Charles E. Lindsey and Janet L. Lindsey Sale Date: Buyer: Bid Price: March 3, 2004 Central Penn Property Services, Inc. $75,901.00 Real Debt: $171,212.31 Interest: 12,210.07 Attorney Costs: 139.80 Total: $183,562.18 DISTRIBUTION: Receipts: Cash on account (11/13/03): $ 1,500.00 Cash on account (03/03/04): 10,000.00 Cash on account (03/19/04): 71,363.96 Total Receipts: $82,863.96 Disbursements: Sherifl?s Costs Legal Search State Transfer 'Tax Local Transfer Tax Cumberland Coumy Tax Claim Bureau Attorney Joseph Goldbeck Citifinancial Services, Inc. $ 2,223.40 200.00 1,872.47 1,872.47 2,581.16 1,500.00 72,614.46 Total Disbursements: Balance for distribution: ($82,863.96) 0.00 So Answers: R. Thomas Kline Sheriff TITLE REPORT THE PREMISES ENDORSED HEREON ARE SUBJECT TO THE FOLLOWING ITEMS, WHICH WILL BE EXCEPTED IN THE POLICY UNLESS SATISFACTORY EVIDENCE PERMITTING THEIR REMOVAL IS PRODUCED. SHERIFF SALE NO. 24 Held Wednesday, March 3, 2004 Date: March 3, 2004 TAXES: Receipts for all taxes for the years 2001 to 2003 inclusive. Taxes for the current year 2004. WATER RENT: SEWER RENT Company assumes no liability for private supply of water or sewer. Receipts to be produced if services are lienable. MECHANICS' AND Possible unfiled Mechanics Liens and Municipal Claims. MUNICIPAL CLAIMS MORTGAGES: Listed Under Other Exceptions Below. JUDGMENTS: Listed Under Other Exceptions Below. INSTRUMENTS TO BE PRODUCED: Deed from Cumberland County Sheriff to dated ,2004, and recorded ,2004, in Cumberland County Deed Book , Page RECITAL: Being the same premises which William S. Craig and Mary T. Craig, husband and wife, by deed dated December 23, 1985 recorded December 24, 1985 in the Office of the Recorder of Deeds in and for Cumberland County, at Carlisle Pennsylvania. in Deed Book "Q," Volume 31, Page 893, granted and conveyed to Charles E. Lindsey and Janet L. Lindsey, husband and wife. OTHER EXCEPTIONS: 1. The identity and legal competency of parties at the closing of this title should be established to the satisfaction of the closing attorney acting for this Company. 2. Rights or claims of parties in possession, if any, other than the owner. 3. Unrecorded easements, discrepancies or conflicts in boundary lines, shortage in area and encroachments which an accurate and complete survey would disclose. 4. Payment of State and local Real Estate Transfer Taxes, if required. 5. Public and private rights in the roadbed of U.S. Route No. 11 and Township Road T- 320. Mortgage in the amount of $147,159.00 given by Charles E. Lindsey and Janet L. Lindsey to CitiFinancial Services, Inc. dated April 2, 2002 and recorded April 5, 2002 in Mortgage Book 1754 Page 3402. Complaint in mortgage foreclosure filed by CitiFinancial Services, Inc. as Plaintiff against Charles E. Lindsey and Janet L. Lindsey as Defendants in the Office of the Prothonotary of Cumberland County on August 14, 2003 to File No. 2003-3978. Default judgment in the amount of $171,212.31 entered October 6, 2003. 7. Delinquent real estate taxes turned over to the Cumberland County Tax Claim Bureau in the amount of $2,564.04 as of the date of this report. District Justice judgment in the amount of $4,146.45 entered by Sears Roebuck & Company as Plaintiff against Charles E. Lindsey as Defendant in the Office of the Prothonotary of Cumberland County on June 12, 2000 to File No. 2000-3551. Said judgment may be a lien on the subject premises in the event of a divorce of the pa~'tes. Default judgment in the amount of $26,127.00 entered by General Motors Acceptance Corporation as Plaintiff against Charles E. Lindsey, Sr., and Janet L. Lindsey as Defendants in the Office of the Prothonotary of Cumberland County on September 25, 2000 to File No. 2000-6503. 10. Rights granted to the Pennsylvania Electric Company by instrument recorded February 6, 1986 in Miscellaneous Record Book 314, Page 125. 11. Under and subject to Building Conditions, Easements and Restrictions as shown on or set forth on the Plan recorded in Plan Book 48, Page 85. 12. Building and Use Restrictions imposed by deed of William S. Craig and Mary T. Craig, recorded in Deed Book "Q," Volume 31, Page 893. 13. Rights granted to Pennsylvania Electric Company by instrument recorded February 6, 1986 in Miscellaneous Record Book 314, Page 122. 14. Rights granted to the United Telephone Company of Pennsylvania by instrument recorded June 9, 1986 in Miscellaneous Record Book 318, Page 700. 15. Rights granted to American Telegraph and Telephone Company of Pennsylvania by instrument recorded April 9, 1940 in Miscellaneous Record Book 70, Page 523. 16. Satisfactory evidence to be produced that proper notice was given to the holders of all liens and encumbrances intended to be divested bY subject Sheriff Sale. 17. Satisfactory evidence to be produced that the advertisement of the property for sale was sufficient despite any reference to improvements on the premises. 14. Real estate taxes accruing on and after July 1, 2004 not yet due and payable. It is to be noted that no search of Domestic Relations Records has been made to determine support arrearages regarding House Bill 1412, Act 58 of 1997, nor has any search been made for environmental liens in Federal District Court. Note: T hi ~ T~t~eY~eApgoertnsth i11 not be~- ~r binding until countersigned by an authorized signatory.