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HomeMy WebLinkAbout03-6012GOLDBECK 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 MORTGAGE ELECTRONIC REGISTRATION SYSTEMS, INC. PO Box 9481 Mail Code: 22-528-1011 Gaithersburg, MD 20898-9481 Plaintiff VS. WILLIAM J. STROHM VICTORIA S. STROHM Mortgagor(s) and Real Owner(s) Three North 30th Street Camp Hill, PA 17011 Defendant(s) IN THE COURT OF COMMON PLEAS OF CUMBERLAND COUNTY CIVIL ACTION - LAW ACTION OF MORTGAGE FORECLOSURE Term No. CIVIL ACTION: MORTGAGE PORECLQ~.IRE THIS FIRM IS A DEBT COLLECTOR AND WE ARE ATTEMPTINGTO COLLECT A DEBT OVqED 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 wish to defend against the claims set forth in the following pages, you must take action within twenty (20) days afier the Complaint and notice are served, by entering a written appearance pe~ sonally or by attorney and filing in writing with the court your defenses or objectimzs to the claims set forth against you, You are warned that if you fail to do so the ease may proceed without you and a judgment may b~ entered against you by the Court without farther notice for any money claim in the Complaint of for any other claim or relief requested by the Plaintiff You may lose money or property or other fights important to you. YOU SHOULD TAKE THIS PAPER TO YOUR LAWYER AT ONCE, IF YOU DO NOT HAVE A LAWYER OR CANNOT AFFORD ONE, GO TO OR TELEPHONE THE OFFICE SET FORTH BELOW. THIS OFFICE CAN PROVIDE YOU WITH INFORMATION ABOUT HIRING A LAWYER. 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 A1 A REDUCED FEE OR NO FEE LEGAL SERVICES [NC 8 Irvthe Row Carlisle, PA 17013 717-243-9400 CUM BERLAND COUN~I3( BAR ASSOCIATION 2 Liberty Avenue Carlisle, PA 17013 AVISQ LE HAN DEMANDADO A DSTED EN LA CORTE. SI DESEA DEFENDERSE CONTRA LAS QUEJAS PERESENTADAS, ES ABSOLUTAMENTE NECESSAR[O QUE USTED RESPONDA DENTRO DE 20 DIAS DESPUES 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 OBJECC1ON CONTRA LAS QUEJAS EN ESTA DEMANDA. RECUERDE: SI USTED NO REPONDE A ESTA DEMANDA, SE PUEDE PROSEGUIR CON EL PROCESO SIN SU PARTICIPAC ION. ENTONCES, LA COUTE PUEDE, SIN NOTIFICARIO, DECIDIR A FAVOR DEL DEMANDANTE Y REQUERIRA QUE USTED CUMPLA CON TODAS LAS PROVISIONES DE ESTA DEMANDA, POR RAZON DE ESA DECIS ION, ES POSSIBLE QUE USTED PUEDA PERDER DINERO, PROPIEDAD U OTROS DERECHOS [MPORTANTES USTED DEBE LLEVAR ~STE PAPEL A SU ABOGADO ENSEGUIDA. SI USTED NO TIENE UN ABOGADO. VAYA O LLAME POR TELEFONO LA OFICINA FHADA AQUI ABA JO. ESTA OFICINA PUEDE PROVEERE CON INFORMACION DE COMO CONSEUIR UN ABOGADO. SI USTED NO PUEDE PAGARLE A UN ABOGADO, ESTA OFICINA PUEDE PROVEER[~ [NFORMACION ACERCA AGENCIAS QUE PUEDAN OFRECER SERVICIOS LEGAL A PERSONAS ELIGIBLE AQ LIN HONORARIO REDUCIDO O GRATIS. LEGAL SERVICES INC 8 Irvthe Row Carlisle, PA 17013 717-243-9400 CUMBERLAND COUNq[¥ BAR ASSOCIATION 2 Liberty Avenue Carlisle, PA 17013 COMPLAINT IN MORTGAGE FORECLOSURE Plaintiff is MORTGAGE ELECTRONIC REGISTRATION SYSTEMS, INC., PO Box 9481, Mail (~ode: 22-528-1011Gaithersburg, MD 20898-9481. The name(s) and address(es) of the Defendant(s) is/are WILLIAM J. ST. ROHM, 7 Creek Road, Camp Hill, PA 17011 and VICTORIA S. STROHM, 7 Creek Road, Camp Hill, PA 17011, who is/are the mortgagor(s) and real owner(s) of the mortgaged premises hereinafter described. On March 23, 1999 mortgagor(s) made, executed and delivered a mortgage upon the premises hereinafter described to SOURCE ONE MOTRGAGE SERVICES CORP., which mortgage is recorded in the Office of the Recorder of Deeds of Cumberland County as Book: 1530 Page: 782. The mortgage has not been assigned unless said assignment to the Plaintiff is hereafter mentioned. The aforementioned mortgage was assigned to: MORTGAGE ELECTRONIC REGISTRATION SYSTEMS, INC. by Assignment of Mortgage dated June 07, 2001 as Book#: 677 Page: 245; and these documents are matters of public record and are incorporated herein by reference in accordance with Pennsylvania Rule of Civil Procedure 1019(g). The premises subject to said mortgage is described as attached. The mortgage is in default because monthly payment of principal and interest upon said mortgage due May 01, 2003, and each month thereafter are due and unpaid, and by the terms of said mortgage, upon default in such payments for a period of one month, the entire principal balance and all interest due thereon are collectible forthwith. 6. The following amonnts are due on the mortgage: Principal Balance Interest from 04/01/2003 through 11/30/2003 at 7.5000% Per Diem interest rate at $19.53 Attorney's Fee at 5.0% of Principal Balance Late Charges from 05/01/2003 to 11/30/2003 Monthly late charge amount at $36.84 Costs of suit and Title Search Escrow Debit Delinquent Expenses O/S property Inspection Escrow Disbursements Monthly Escrow amount $227.62 $95,060.65 $4,765.32 $4,753.03 $257.88 $900.00 $105,736.88 +$556.94 +$127.70 +$40.00 -$38.51 $106,423.01 The Attorney's Fees set forth above are in conformity with the Mortgage documents and Pennsylvania law, and, will be collected in the event of a third party purchaser at Sheriff's Sale. If the Mortgage is reinstated prior to the Sale reasonable Attorney's Fees will be charged based on work actually performed. 8. The within mortgage is insured by the Federal Housing Administration under Title II of the National Housing Act and, as such, is not subject to the provisions of Pennsylvania Act No. 91 of 1983. WHEREFORE, Plaintiff demands judgment in mortgage foreclosure in the sum of $106,423.01, together with interest a't the rate of $19.53, per day and other expenses incurred by the Plaintiff which are properly chargeable in accordance with the terms of the mortgage, and for the foreclosure and sale of the mortgaged premises. By: VERIFICATION · I, Lisa Dounelly as the representative of the Plaintiff corporation within named do hereby verify that I am authorized to and do make this verification on behalf of the Plaintiff corporation and the facts set forth in the foregoing Complaint are tree and correct to the best of my knowledge, information and belief. I understand that false statements therein are made subject to the penalties of 18 Pa. C.S. 4904 relating to unswom falsification to authorities. Date: onnelly CITIMORTGAGE INC. Conestoga Title Inauranoe Campany Legal description of the lend: ALL THAT CERTAIN Irauff o. lot of land situate in the Borough of Camp Hill, Cumberland County, Pennsylvania, more parflcul ,~rty bounded and described as follows, to wit: BEGINNING at a point on tl'e eastern line of 30th Street, said point being by same measured in a northeasterly direction 90 feet from the point on the western terminus of the arc of a cure having a radius of 20 feet connecting the eastern line of 30th Street with the northern line of Market S~eet; thence North 02 degrees 4~ minutes East along said eastern line of 30th Street., a distance ot 50 feet toe point on same; thence., outh 87 degrees 14 minutes East along the line of adjoiner between Lots Nos. 1 and 2 on the hereinafter mentioned plan of lots, a distance of 150 feet to a point on the western line of lands now ol late of Raymond A. Fo~gie et ux., thence South 02 degrees 45 minutes West, aong the said westen line of lands, a distance of 25 feet to a concrete monument; thence North 87 degrees 14 minutes West along the northern line of lands now or late of Charles R. Newkam, et ux., a distance )f70 feet to a point; thence south 02 degrees 45 minutes West along the western line of said lands o1 Newkam, a distance of 25 feet to a point; thence North 87 degrees 14 minutae West along the nor hem line of lands now or ~te AJlen B, Reynolds, et ux., a distance of 80 feet tO a point on the easter~ line of 30th Street, the point and place of BEGINNING, BEING Lot No. 2 on the Suadivision Plan of a tract i~or Katherine W. Ward and recorded in Plan Book 23, page 83, Cumbedand (~unty records. HAVING-'[HEREON EREC -ED a single family dwelling known and numbered as 3 North 30th Street, Camp Hill, Pennsylvania. . . .....:-_..,, =. ... . · , . . ~ BEING the samepremisee Nhida Davis H. Householder and Stephanie Householder, hie wife, by their deed ;fated October 2 1987 and recorded in the Cumberland County Recorder of Deeds Office ~ B~ok Z..32, .page 259, granted and conveyed unto William C. Haverstock and Terry L. Haverstock, urantom herein. Pareel ~01-21-0273.302 i Premium Amount $781.30 Endorsements $150.00 SHERIFF'S RETURN - REGULAR CASE NO: 2003-06012 p COMMONWEALTH OF PENNSYLVANIA: COUNTY OF CUMBERLD2WD MORTGAGE ELECTRONIC REGISTRATI VS STROHM WILLIAM J ET AL GERALD WORTHINGTON Sheriff or Deputy Sheriff of Cumberland County, Pennsylvania, who being duly sworn according to law, says, the within COMPLAINT - MORT FORE was served upon STROHM WILLIAM J the DEFENDANT at 7 CREEK ROAD at 1605:00 HOURS, on the 26th day of November , 2003 CAMP HILL, PA 17011 WILLIAM J STROHN a true and attested copy of COMPLAINT by handing to - MORT FORE together with and at the same time directing His attention to the contents thereof. Additional Comments 3 NORTH 30TH STREET CAMP HILL IS VACANT. Sheriff's Costs: Docketing 18.00 Service 19.32 Affidavit .00 Surcharge 10.00 .00 47.32 Sworn and Subscribed to before me this ~ - day of ~tc' ~ 2dO_5 A.D. 'Prothonotary / / So Answers: R. Thomas Kline 12/01/2003 GOLDBECK MCCAFFERTY MCKEEVER By: DepUty ~iff SHERIFF'S RETURN - REGULAR CASE NO: 2003-06012 p COMMONWEALTH OF PENNSYLVA/~IA: COUNTy OF CUMBERLA/~D MORTGAGE ELECTRONIC REGISTP~ATI VS STROHM WILLIA~M J ET AL GEP~ALD WORTHINGTON , Sheriff or Deputy Sheriff of Cumberland County, Pennsylvania, who being duly SWorn according to law, says, the within COMPLAINT - MORT FORE was served upon STROHM VICTORIA S DEFENDANT , at at 7 CREEK ROAD CANP HILL, PA 17011 WILLIAM j STROHM ~605:00 HOURS, the on the _26t_h day of November~, by handing to 2003 a true and attested copy of COMPLAINT _ MORT FORE together with and at the same time directing His attention to the Additional Comments - 3 NORTH 3OTH STREET CAJ~p HILL IS VACANT. contents thereof. Sheriff,s Costs: Docketing Service Affidavit Surcharge 6.00 .00 .00 10.00 .00 Sworn and Subscribed to before me this ~3 ~ day of · :-zuLnonotary ~ / So Answers: R. Thomas Kline 12/01/2003 GOLDBECK MCCAFFERTY MCKEEVER By: Deputy~ ~ GOLDBECK McCAFFERTY & McKEEVER BY: Joseph A. Goldbeck, Jr. Attorney I.D. # 16132 Suite 500 The Bourse Bldg. l 11 S. Independence Mall East Philadelphia, PA 19106 215-627-1322 Attorney for Plaintiff MORTGAGE ELECTRONIC REGISTRATION SYSTEMS, INC. PO Box 9481 Mail Code: 22-528-1011 Gaithersburg, MD 20898-9481 Plaintiff VS. WILLIAM J. STROHM VICTORIA S. STROHM (Mortgagor(s) and Record owner(s)) Three North 30th Street Camp Hill, PA 17011 Defendant(s) IN THE COURT OF COMMON PLEAS of Cumberland County CIVIL ACTION LAW ACTION OF MORTGAGE FORECLOSURE No. 03-6012 CIV1L TERM ORDER FOR JUDGMENT Please enter Judgment in favor of MORTGAGE ELECTRONIC REGISTRATION SYSTEMS, 1NC., and against WILLIAM J. STROHM and VICTORIA S. STROHM for failure to file an Answer in the above action within (20) days (or sixty (60) days if defendant is the Unite~tates of America) from the date of service of the Complaint, in the sum of $107,576.89. Joseph A. G Attomey for ~l~tiff \ ' I hereby certify that the above names are correct and that the ~cise residence address of the judgment\ creditor is MORTGAGE ELECTRONIC REGISTRATION SYSTEMS, INC. PO Box 9481 Mail Code: 22-528- 1011 Gaithersburg, MD 20898-9481 and that the name(s) and last known address(es) of the Defendant(s) is/are WILLIAM J. STROHM, 7 Creek Road Camp Hill, PA 17011 and VICTORIA S. STROHM, 7 Creek Road Camp Hill, PA 17011; ASSESSMENT OF DAMAGES TO THE PROTHONOTARY: Kindly assess the damages in this case to be as follows: Principal Balance $95,060.65 Interest ffom04/01/2003through 01/02/2004 $5,390.28 Attorney's Fee at 5.0000% of principal balance $4,753.03 Late Charges $331.56 Costs of Suit and Title Search $900.00 Escrow Balance Deficit Escrow Debit Delinquent Expenses O/S property inspection Escrow Disbursements $455.24 $556.94 $127.70 $40.00 $-38.51 $107,576.89 AND NOW, this day of J~-'~ GOLDBI ~ ~ & BY: Jose ~h~$,Doldl ck, Jr. Attorney 3r 'h~intif3 ,2004 damages are assessed as above. McKEEVER 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, WILLIAM J. STROHM, is about unknown years of age, that Defendant's last known residence is 7 Creek Road, Camp Hill , PA 17011, and is engaged in the unknown business located at unknown address. 2. That Defendant is not in the Military or Naval Service of the United States or its Allies, or otherwise within the provisions of the Soldiers' and Sailors' Civil Relief Action of Congress of 1940 and its Amendments. 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, VICTORIA S. STROHM, is about unknown years of age, that Defendant's last known residence is 7 Creek Road, Camp Hill , PA 17011, and is engaged in the unknown business located at unknown address. 2. That Defendant is not in the Military or Naval Service of the United States or its Allies, or otherwise within the provisions of the Soldiers' and Sailors' Civil Relief Action of Congress of 1940 and its Amendments. Date: f~ ~ In the Court of Common Pleas of Cumberland County MORTGAGE ELECTRONIC REGISTRATION SYSTEMS, 1NC. PO,Box 9481 Mail Code: 22-528-1011 Gaithersburg, MD 20898-9481 VS. WILLIAM J. STROHM VICTORIA S. STROHM (Mortgagor(s) and Record Owner(s)) Three North 30th Street Camp Hill, PA 17011 Plaintiff Defendant(s) No. 03-6012 CIVIL TERM 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 Plaintiff and against WILLIAM J. STROHM and VICTORIA S. STROHM by default for want of an Answer. Assess damages as follows: Debt $107,576.89 Interest - 04/01/2003 to 01/02/2004 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. I certify that written notice of the intention to file this praecipe was mailed or delivered to the party against whom judgment is to be entered and to his attorney of record, if any, after the default occurred a~lea~n days prior to the date of the filing of this praecipe. A copy of the notice is attached. R.C.P. 237.1 Jo~'t~ Jr.sep ~/~eck, Atton ~'~ for 1~ ~intiff MORTGAGE EN?E~TI~O~NI~C/~R~IO~N SYSTEMS, ~g~a'i #nsS~ 'A~dj~7t~I~I~dd ~71~;rp~fA S. STROHM by default for want of an Answer and damages assessed in the s}~ of $107,576.89 as per the abga?~ certification. 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. DATE OF THIS NOTICE: December 17, 2003 TO: VICTORIA S. STROHM Three North 30th S~'eet Camp Hill, PA 17011 MORTGAGE ELECTRONIC REGISTRATION SYSTEMS, INC. PO Box 9481 Mail Code: 22-528-1011 Gaithersburg, MD 20898-9481 Plaintiff VS. WILLIAM J. STROHM VICTORIA S. STROHM (Mortgagor(s) and Record Owner(s)) Three North 30th Street Camp Hill, PA 17011 Defendant(s) IN THE COURT OF COMMON PLEAS of Cumberland County CIVIL ACTION - LAW ACTION OF MORTGAGE FORECLOSURE Terln No. 03-6012 CIVIL TERM TO: VICTORIA S. STROHM Three Noffit 30th Street Camp Hill, PA 17011 IMPORTANT NOTICE YOU ARE IN DEFAULT BECAUSE YOU HAVE FAILED TO ENTER A WRITTEN APPEARANCE PERSONALLY OR BY ATTORNEY AND FILE IN WRITING WI'IH THE COURT YOUR DEFENSES OR OBJECTIONS TO ~ CLAIMS SET FORTH AGAINST YOU. UNLESS YOU ACT W1THIN TEN (10) DAYS FROM ~ DATE OF THIS NOTICE, A JUDGMENT MAY BE ENTERED AGAINST YOU WITHOUT A HEARING AND YOU MAY LOSE YOUR PROPERTY OR OTHER IMPORTANT RIGHTS. YOU SHOULD TAKE THIS NOTICE TO A LAWYER AT ONCE. IF YOU DO NOT HAVE A LAWYER OR CANNOT AFFORD ONE, GO TO OR TELEPHONE THE FOLLOWING OFFICE TO FIND OUT WHERE YOU CAN GET LEGAL HELP: LEGAL SERVICES INC 8 h'vine Row Carlisle, PA 17013 717-243-9400 CUMBERLAND COUNTY BAR ASSOCIATION 2 Liberty Avenue Carlisle, PA 17013 Attorney for Plaintiff Suite 5000 - Mellon Independence Center 701 Market St~t Philadelphia, PA 19106 215-627-1322 ~R 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. DATE OF THIS NOTICE: December 17, 2003 TO: WILLIAM J. STROHM Three North 30th Slxeet Camp Hill, PA 17011 MORTGAGE ELECTRONIC REGISTRATION SYSTEMS, INC. PO Box 9481 Mail Code: 22-528-1011 Gaithersburg, MD 20898-9481 Plaintiff VS. WILLIAM J. STROHM VICTORIA S. STROHM (Mortgagor(s) and Record Owner(s)) Three North 30th Street Camp Hill, PA 1701 ! Defendant(s) IN THE COURT OF COMMON PLEAS of Cumberland County CIVIL ACTION - LAW ACTION OF MORTGAGE FORECLOSURE No. 03-6012 CIVIL TERM TO: WILLIAM J. STROHM Three North 30th Street Camp Hill, PA 17011 IMPORTANT NOTICE YOU ARE IN DEFAULT BECAUSE YOU HAVE FAILED TO ENTER A WRITI'EN APPEARANCE PERSONALLY OR BY ATTORNEY AND FILE IN WRITING WITH THE COURT YOUR DEFENSES OR OBJECTIONS TO THE CLAIMS SET FORTH AGAINST YOU. UNLESS YOU ACT WITHIN TEN (10) DAYS FROM THE DATE OF THIS NOTICE, A JUDGMENT MAY BE ENTERED AGAINST YOU WITHOUT A HEARING AND YOU MAY LOSE YOUR PROPERTY OR OTHER IMPORTANT RIGHTS. YOU SHOULD TAKE THIS NOTICE TO A LAWYER AT ONCE. IF YOU DO NOT HAVE A LAWYER OR CANNOT AFFORD ONE, GO TO OR TELEPHONE THE FOLLOWING OFFICE TO FIND OUT WHERE YOU CAN GET LEGAL HELP: LEGAL SERVICES INC 8 Irvine Row Carlisle, PA 17013 717-243-9400 CUMBERLAND COUNTY BAR ASSOCIATION 2 Liberty Avenue Carlisle, PA 17013 Attorney for Plaintiff Suite 5000 Mellon Independence Center 701 Market Stre~ Philadelphia, PA 19106 215427-1322 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. DATE OF THIS NOTICE: December 17, 2003 TO: VICTORIA S. STROHM 7 Creek Road Camp Hill, PA 17011 MORTGAGE ELECTRONIC REGISTRATION SYSTEMS, INC. PO Box 9481 Mail Code: 22-528-1011 Gaithersburg, MD 20898-9481 VS. WILLIAM J. STROHM VICTORIA S. STROHM (Mortgagor(s) and Record Owner(s)) Three North 30th Street Camp Hill, PA 17011 Plaintiff In the Court of Common Pleas of Cumberland County CIVIL ACTION - LAW ACTION OF MORTGAGE FORECLOSURE No. 03-6012 CIVIL TERM Defendant(s) TO: VICTORIA S. STROItM 7 Creek Road Camp Hill, PA 17011 IMPORTANT NOTICE YOU ARE 1N DEFAULT BECAUSE YOU HAVE FAILED TO ENTER A WRIT fEN APPEARANCE PERSONALLY OR BY ATTORNEY AND FILE IN WRITING WITH THE COURT YOUR DEFENSES OR OBJECTIONS TO THE CLAIMS SET FORTH AGAINST YOU. UNLESS YOU ACT WITHIN TEN (10) DAYS FROM THE DATE OF THIS NOTICE, A JUDGMENT MAY BE ENTERED AGAINST YOU W1THOUT A HEARING AND YOU MAY LOSE YOUR PROPERTY OR OTHER IMPORTANT RIGHTS. YOU SHOULD TAKE THIS NOTICE TO A L3.WYER AT ONCE. IF YOU DO NOT HAVE A LAWYER OR CANNOT AFFORD ONE, GO TO OR TELEPHONE THE FOLLOWING OFFICE TO FIND OUT WHERE YOU CAN GET LEGAL HELP: LEGAL SERVICES INC 8 Irvine Row Carlisle, PA 17013 717-243-9400 CUMBERLAND COUNTY BAR ASSOCIATION 2 Liberty Avenue Carlisle, PA 17013 GOLI~BECK MeCAFFERTY & McKEEV~R BY: Joseph A. Goldbeck, Jr., Esq. Attorney for Plaintiff Suite 5000 - Mellon Independence Center 701 Market Street Philadelphia, PA 19106 215-627-1322 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. DATE OF THIS NOTICE: December 17, 2003 TO: WILLIAM J. STROHM 7 Creek Road Camp Hill, PA 17011 MORTGAGE ELECTRONIC REGISTRATION SYSTEMS, INC. PO Box 9481 Mail Code: 22-528-1011 Gaithersburg, MD 20898-9481 VS. WILLIAM J. STROHM VICTORIA S. STROHM (Mortgagor(s) and Record Owner(s)) Three North 30th Street Camp Hill, PA 17011 Plaintiff In the Court of Common Pleas of Cumberland County CIVIL ACTION - LAW ACTION OF MORTGAGE FORECLOSURE No. 03-6012 CIVIL TERM Defendant(s) TO: WILLIAM J. STROHM 7 Creek Road Camp Hill, PA 17011 IMPORTANT NOTICE YOU ARE IN DEFAULT BECAUSE YOU HAVE FAILED TO ENTER A WRITTEN APPEARANCE PERSONALLY OR BY ATTORNEY AND FILE IN WRITING WITH THE COURT YOUR DEFENSES OR OBJECTIONS TO THE CLAIMS SET FORTH AGAINST YOU. UNLESS YOU ACT WITHIN TEN (10) DAYS FROM THE DATE OF THIS NOTICE, A JUDGMENT MAY BE ENTERED AGAINST YOU WITHOUT A HEARING AND YOU MAY LOSE YOUR PROPERTY OR OTHER IMPORTANT RIGHTS. YOU SHOULD TAKE THIS NOTICE TO A LAWYER AT ONCE. Ii~ YOU DO NOT HAVE A LAWYER OR CANNOT AFFORD ONE, GO TO OR TELEPHONE THE FOLLOWING OFFICE TO FIND OUT WHERE YOU CAN GET LEGAL HELP: LEGAL SERVICES INC 8 lrvine Row Carlisle, PA 17013 717-243-9400 CUMBERLAND COUNTY BAR ASSOCIATION 2 Liberty Avenue Carlisle, PA 17013 GOLDBECK McCAFFERTY & McKEEVER BY: Joseph A. Goldbeck, Jr., Esq. Attorney for Plaintiff Suite 5000 - Mellon Independence Center 701 Market Street Philadelphia, PA 19106 215-627-1322 Rule of Oivil Procedure No. 236 - Revised 1N THE COURT OF COMMON PLEAS OF Cumberland COUNTY, PENNSYLVANIA CIVIL ACTION - LAW MORTGAGE ELECTRONIC REGISTRATION SYSTEMS, 1NC. PO Box 9481 Mail Code: 22-528-1011 Gaithersburg, MD 20898-9481 Plaintiff VS. No. 03-6012 CIVIL TERM WILLIAM J. STROHM VICTORIA S. STROHM (Mortgagors and Record Owner(s)) Three North 30th Street Camp Hill, PA 17011 Defendant(s) THIS LAW FIRM IS A DEBT COLLECTOR AND WE ARE ATTEMPTING TO COLLECT A DEBT OWED TO OUR CLIENT. ANY INFORMATION OBTAINED FROM YOU WILL BE USED FOR THE PURPOSE OF COLLECTING THE DEBT. 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. Goldbeck McCafferty & McKeever Suite 500 - The Bourse Bldg. 111 S. Independence Mall East Philadelphia, PA 19106 215-627-1322 il. ~ PRAECIPE FOR WRIT OF EXECUTION - (MORTGAGE FORECLOSURE) P.R.C.P 3180-3183 Joseph A. Goldbeck, Jr. Attorney I.D.#16132 Suite 500 - The Bourse Bldg. 111 S. Independence Mall East Philadelphia, PA 19106 215-627-1322 Attorney for Plaintiff MORTGAGE ELECTRONIC REGISTRATION SYSTEMS, INC. PO Box 9481 Mail Code: 22-528-1011 Gaithersburg, MD 20898-9481 Plaintiff VS. IN THE COURT OF COMMON PLEAS of Cumberland County CIVIL ACTION LAW WILLIAM J. STROHM VICTORIA S. STROHM Mortgagor(s) and Record Owner(s) Three North 30th Street Camp Hill, PA 17011 Defendant(s) ACTION OF MORTGAGE FORECLOSURE No. 03-6012 CIVIL TERM PRAECIPE FOR WRIT OF EXECUTION TO THE PROTHONOTARY: Issue Writ of Execution in the above matter: Amount Due Interest from 04/01/2003to 01/02/2004 at 7.5000% (Costs to be added) GOLDBECK BY: Joseph Attorney for $107,576.89 ~ TY & McKEEVER i ~l'fl~eqk, Jr. ~ti~ ~, ALL THAT CERTAIN TRACT OR LOT OF LAND SITUATE IN THE BOROUGH OF CAMP HILL, CUMBERLAND COUNTY, PENNSYLVANIA, MORE PARTICULARLY BOUNDED AND DESCRIBED AS FOLLOWS, TO WIT: BEGINNING AT A POINT ON THE EASTERN LINE OF 30TM STREET, SAID POINT BEING BY SAME MEASURED 1N A NORTHEASTERLY DIRECTION 90 FEET FROM THE POINT ON THE WESTERN TERMINUS OF THE ARC OF A CURE HAVINGA RADiUS OF 20 FEET CONNECTING THE EAST LINE OF 30TM STREET WITH THE NORTHERN LINE OF MARKET STREET; THENCE NORTH 02 DEEGREES 45 MINUTES EAST ALONG SAID EASTERN LINE OF 30TM STREET, A DISTANCE OF 50 FEET TO A POINT ON SAME, THENCE SOUTH 87 DEGREES 14 MINUTES EAST ALONG THE LINE OF ADJOINER BETWEEN LOTS NOS. 1 AND 2 ON THE HEREINAFTER MENTIONED PLAN OF LOTS, A DISTANCE OF 150 FEET TO A POINT ON THE WESTERN LINE OF LANDS NOW OR LATE OF RAYMOND A. FORGIE, ET UX, THENCE SOUTH 02 DEGREES 45 MINUTES WEST, ALONG THE SAID WESTERN LiNE OF LANDS, A DISTANCE OF 25 FEET TO A CONCRETE MONUMENT; THENCE NORTH 87 DEGREES 14 MINUTES WEST ALONG THE NORTHERN LINE OF LANDS NOW OR LATE OF CHARLES R. NEWKAM, ET UX, A DISTANCE OF 70 FEET TO A POINT; THENCE SOUTH 02 DEGREES 45 MINUTES WEST ALONG THE WESTERN LINE OF SAID LANDS OF NEWKAM, A DISTANCE OF 25 FEET TO A POINT; THENCE NORTH 87 DEGREES 14 MINUTES WEST ALONG THE NORTHERN LINE OF LANDS NOW OR LATE ALLEN B. REYNOLDS, ET UX, A DISTANCE OF 80 FEET TO A POINT ON THE EASTERN LINE OF 30TM STREET, THE POINT AND PLACE OF BEGINNING. WRIT OF EXECUTION and/or ATTACHMENT COMMONWEALTH OF PENNSYLVANIA) NO 03-6012 Civil COUNTY OF CUMBERLAND) CIVIL ACTION - LAW TO THE SHERIFF OF CUMBERLAND COUNTY: To satisfy the debt, interest and costs due MORTGAGE ELECTRONIC REGISTRATION, Plaintiff (s) From Vv'ILLIAM J. STROHM AND VICTORIA S. STROHM (1) You are cFxrected 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 $107,576.89 L.L. $,50 Interest FROM 4/1/03 TO 1/2/04 AT 7.5000% Atty's Corem % Due Prothy $1.00 AttyPaid $145.32 Other Costs Plaintiff Paid Date: JANUARY 6, 2004 (Seal) REQUESTING PARTY: Name JOSEPH A. GOLDBECK, JR., ESQUIRE Address: SUITE 500 - THE BOURSE BLDG. 111 S. INDEPENDENCE MALL EAST PHILADELPHIA, PA 19106 Attorney for: PLAINTIFF Telephone: 215-627-1322 Supreme Court ID No. 16132 CURTIS R. LONG Prothonotary Deputy Goldbeck McCafferty & McKeever BY. Joseph A. Goldbeck, Jr. Attorney I.D. #16132 Suite 500 The Bourse Bldg. 1 l 1 S. Independence Mall Fast Philadelphia, PA 19106 215-62%l 322 Attorney for Plaintiff MORTGAGE ELECTRONIC REGISTRATION SYSTEMS, [NC. PO Box 9481 Mail Code: 22-528-1011 Gaithersburg, MD 20898-9481 Plaintiff VS. WILLIAM J. STROHM VICTORIA S. STROHM (Mortgagor(s) and Record Owner(s)) Three North 30th Street Camp Hill, PA 17011 Defendant(s) 1N THE COURT OF COMMON PLEAS of Cumberland County CWIL ACTION - LAW ACTION OF MORTGAGE FORECLOSURE No. 03-6012 CIVIL TERM AFFIDAVIT PURSUANT TO RULE 3129 MORTGAGE ELECTRONIC REGISTRATION SYSTEMS, 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: Three North 30th Street Camp Hill, PA 17011 1.Name and address of Owner(s) or Reputed Owner(s): WILLIAM J. STROHM 7 Creek Road Camp Hill, PA 17011 VICTORIA S. STROHM 7 Creek Road Camp Hill, PA 17011 2. Name and address of Defendant(s) in the judgment: WILLIAM J. STROHM 7 Creek Road Camp Hill, PA 17011 VICTORIA S. STROHM 7 Creek Road Camp Hill, PA 17011 3. Name and last known address of every judgment creditor whose judgment is a record lien on the property to be sold: DOMESTIC RELATIONS OF CUIvlBERLAND 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 HELEN J. PINES 48 W. ALLEN STREET MECHANICSBURG, PA 17055 4. Name and address of the last recorded holder of every mortgage of record: OLD KENT BANK 38 FOUNTAIN SQUARE PLAZA CINN, PA 45263 GREAT AMERICAN CAPITAL CORP 151 KALMUS DRIVE SUITE 130 COSTA MESA, CA 92626 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 Three North 30th Street Camp Hill, PA 17011 (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: January 2, 2004 Attorney for ~lltmtiff 03-6012 CIVIL TERM GOLDBECK McCAFFERTY & McKEEVER BY: Joseph A. Goldbeck, Jr. Attorney I.D.#16132 Suite 5000- Mellon Independence Center 701 Market Street Philadelphia, PA 19 106 215-627-1322 Attorney for Plaintiff MORTGAGE ELECTRONIC REGISTRATION SYSTEMS, INC. PO Box 9481 Mail Code: 22-528-1011 Gaithersburg, MD 20898-9481 Plaintiff VS. WILLIAM J. STROHM VICTORIA S. STROHM Mortgagor(s) and Record Owner(s) Three North 30th Street Camp Hill, PA 17011 IN THE COURT OF COMMON PLEAS of Cumberland County CIVIL ACTION - LAW ACTION OF MORTGAGE FORECLOSURE Term No. 03-6012 CIVIL TERM 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: STROHM, WILLIAM J. WILLIAM J, STROHM 7 Creek Road Camp Hill, PA 17011 Your house at Three North 30th Street, Camp Hill, PA 17011 is scheduled to be sold at Sheriffs Sale on Wednesday, June 09, 2004, at 10:00 AM, in Commissioners Hearing Ran 2nd FL Courthouse to enforce the court judgment of $107,576.89 obtained by MORTGAGE ELECTRONIC REGISTRATION SYSTEMS, INC. against you. NOTICE OF OWNER'S RIGHTS YOU MAY BE ABLE TO PREVENT THIS SHERIFF'S SALE To prevent this Sheriff's Sale you must take immediate action: 1. The sale will be cancelled if you pay to MORTGAGE ELECTRONIC REGISTRATION SYSTEMS, 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 03-6012 CIVIL TERM 2. You may be able to stop the sale by filing a petition asking the Court to strike or open judgment, if the judgment was improperly entered. You may also ask the Court to postpone the sale for good cause. 3. You ~nay 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 yon 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. I. If the Sherifl~s Sale is not stopped, your property will be sold to the highest bidder. You may find out the price bid price by calling the Sheriff of 717-240-6390. 2. You may be able to petition the Court to set aside the sale if the bid price was grossly inadequate compared to the value of your property. 3. The sale will go through only if the buyer pays the Sheriff the full amount due in the sale. To find out if this has happened, you may call the Sheriff of 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 Sheriff within ten (10) days after the schedule of distribution is filed. 7. You may also have other rights and defenses, or ways of getting your house back, if you act immediately after the sale. YOU SHOULD TAKE THIS PAPER TO YOUR LAWYER AT ONCE. IF YOU DO NOT HAVE A LAWYER OR CANNOT AFFORD ONE, GO TO OR TELEPHONE THE OFFICE LISTED BELOW TO FIND OUT WHERE YOU CAN GET LEGAL HELP. LEGAL SERVICES ][NC 8 Irvine Row Carlisle, PA 17013 CUMBERLAND COUNTY BAR ASSOCIATION 2 Liberty Avenue Carlisle, PA 17013 03-6012 CIVIL TERM '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 Pla/ntiff MORTGAGE ELECTRONIC REGISTRATION SYSTEMS, 1NC. PO Box 9481 Mail Code: 22-528~1011 Gaithersburg, MD 20898-948 l Plaintiff VS. WILLIAM J. STROHM VICTORIA S. STROHM Mortgagor(s) and Record Owner(s) Three North 30th Street Camp Hill, PA 17011 IN THE COURT OF COMMON PLEAS of Cumberland County CIVIL ACTION - LAW ACTION OF MORTGAGE FORECLOSURE Term No. 03-6012 CIVIL TERM 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: STROHM, VICTORIA S. VICTORIA $. $TROHM 7 Creek Road Camp Hill, PA 17011 Your house at Three North 30th Street, Camp Hill, PA 17011 is scheduled to be sold at Sheriff's Sale on Wednesday, June 09, 2004, at 10:00 AM, in Commissioners Hearing Rm 2nd FL Courthouse to enforce the court judgment of $107,576.89 obtained by MORTGAGE ELECTRONIC REGISTRATION SYSTEMS, INC. against you. NOTICE OF OWNER'S RIGHTS YOU MAY BE ABLE TO PREVENT THIS SHERIFF'S SALE To prevent this Sheriff's Sale you must take immediate action: 1. The sale will be cancelled if you pay to MORTGAGE ELECTRONIC REGISTRATION SYSTEMS, 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 03-6012 CIVIL TERM 2. You may be able to stop the sale by filing a petition asking the Court to strike or open judgment, if the.judgment was improperly entered. You may also ask the Court to postpone the sale for good cause. 3. You may also be able to stop the sale through other legal proceedings. You may need an attorney to assert your rights. The sooner you contact one, the more chance you will have of stopping the sale. (See notice below on how to obtain an attorney). YOU MAY STILL BE ABLE TO SAVE YOUR PROPERTY AND YOU HAVE OTHER RIGHTS EVEN IF THE SHERIFF'S SALE DOES NOT 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 fi~ll amount due in the sale. To find out if this has happened, you may call the Sheriffof 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 Shariff 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 thc money bid for your house will be filed by the Sheriff thirty (30) days from the date oftha 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 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 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 Secretary of Housing & Urban Dev is the grantee the same having been sold to said grantee on the 9th day of Aug A.D., 2004, under and by virtue of a writ Execution issued on the 6th day of Jan, A.D., 2004, out of the Court of Common Pleas of said County as of Civil Term, 2003 Number 6012, at the suit ofMtg Elec Ree Systems Inc against William J Strohm & Victoria S is duly recorded in Sheriff's Deed Book No, 264, Page 3009. IN TESTIMONY WHEREOF, I have hereunto set my hand day of and seal of said office this , A.D2004 Recorder of Deeds Mortgage Electronic Registration Systems, Inc. VS William J. Strohm and Victoria S. Strohm In The Court of Common Pleas of Cumberland County, Pennsylvania Writ No. 2003-6012 Civil Term Cpl. Michael Barrick, Deputy Sheriff, who being duly swom according to law, states that on February 18, 2004 at 8:40 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: William J. Strohm and Victoria S. Strohm, by making known unto William J. Strohrn, personally and husband of Victoria S. Strohm, at 7 Creek Road, Camp Hill, Cumberland County, Pennsylvania, its contents and at the same time handing to him personally the said true and correct copy of the same. Cpl. Michael Barrick, Deputy Sheriff, who being duly sworn according to law, states that on April 06, 2004 at 7:56 o'clock P.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 William J. Strohm and Victoria S. Strohm located at 3 North 30th Street, Camp Hill, 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 defendants, to wit: William J. Strohm and Victoria S. Strohm, by regular mail to their last known address of 7 Creek Road, Camp Hill, PA 17011. These letters were mailed under the date of April 06, 2004 and never returned to the Sheriffs 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 June 9, 2004 at 10:00 o'clock A.M. He sold the same for the sum of $1.00 to Attorney Joseph Goldbeck for Secretary of Housing & Urban Development, His Successors and Assigns. It being the highest bid and best price received for the same, Secretary of Housing & Urban Development, His Successors and Assigns of 100 Penn Square East, 10th Floor, Wanamaker Building, Philadelphia, PA 19106, being the buyer in this execution, paid to SheriffR. Thomas Kline the sum of $807.31. Sheriff's Costs: Docketing $30.00 Poundage 15.83 Posting Bills 15.00 Advertising 15.00 Acknowledging Deed 30.00 Auctioneer 10.00 Law Library .50 Prothonotary 1.00 Mileage 21.39 Levy 15.00 Surcharge 30.00 Law Journal 256.10 Patriot News 270.97 Share of Bills 29.02 Distribution of Proceeds 25.00 Sheriffs Deed 42.50 $ 807.31 Swom and subscribed to before me This jO & day of ~ Prollaonotary So Answers: R. Thomas Kline. Sheriff BY ,~j ~)]t Real Estate~eputy Goldbeck McCaffei~y & McKeever BY: Joseph A. Goldbeck, Jr. Attorney I.D. #16132 Suite 500 - The Bourse Bldg. 111 S. Independence Mall East Philadelphia, PA 19106 215-627-1322 Attorney for Plaintiff MORTGAGE ELECTRONIC REGISTRATION SYSTEMS, INC. PO Box 9481 Mail Code: 22-528-1011 Gaithersburg, MD 20898-9481 Plaintiff VS. WILLIAM J. STROHM VICTORIA S. STROHM (Mortgagor(s) and Record Owner(s)) Three North 30th Street Camp Hill, PA 170I 1 Defendant(s) IN THE COURT OF COMMON PLEAS of Cumberland County CIVIL ACTION - LAW ACTION OF MORTGAGE FORECLOSURE No. 03-6012 CIVIL TERM AFFIDAVIT PURSUANT TO RULE 3129 MORTGAGE ELECTRONIC REGISTRATION SYSTEMS, 1NC., 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: Three North 30th Street Camp Hill, PA 17011 1 .Name and address of Owner(s) or Reputed Owner(s): WILLIAM J. STROHM 7 Creek Road Camp Hill, PA 17011 VICTORIA S. STROHM 7 Creek Road Camp Hill, PA 17011 2. Name and address of Defendant(s) in the judgment: WILLIAM J. STROHM 7 Creek Road Camp Hill, PA 17011 VICTORIA S. STROHM 7 Creek Road Camp Hill, PA 17011 3. Name and last known address of every judgment creditor whose judgment is a record lien on the property to be sold: 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. - P~oom 432 P.O. Box 2675 Harrisburg, PA 1'7 105-2675 HELEN J. PINES 48 W. ALLEN STREET MECHANICSBURG, PA 17055 4. Name and address of the last recorded holder of every mortgage of record: OLD KENT BANK 38 FOUNTAIN SQUARE PLAZA CINN, PA 45263 GREAT AMERICAN CAPITAL CORP 151 KALMUS DRIVE SUITE 130 COS I'A MESA, CA 92626 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/OCC[JPANTS Tkree North 30th Street Camp Hill, PA 17011 (attach separate sheet if more space is needed) I verify that the statements made in this affidavit are tree and correct to the best of my personal knowledge or information and belief. 1 understand that false statements herein are made subject to the penalties of 18 Pa. C.S. Section 4904 relat'mg to unswom falsification to authorities. DATED: January 2, 2004 GOLDBECK BY: Joseph Attorney for & McKEEVER ~'1'~¢ ck Jr,, Esq. ~intiff 03-6012 CIVIL TERM GOLDBECK McCAFFERTY & McKEEVER BY: Joseph A. Goldbeck, Jr. Attorney ID.#16132 Suite 5000- Mellon Independence Center 701 Market Street Philadelphia, PA 19106 215-627-1322 Attorney for Plaintiff MORTGAGE ELECTRONIC REGISTRATION SYSTEMS, 1NC. PO Box 9481 Mail Code: 22-528-1011 Gaithersburg, MD 20898-9481 Plaintiff VS. WILLIAM J. STROHM VICTORIA S. STROHM Mortgagor(s) and Record Owner(s) Three North 30th Street Camp Hill, PA 17011 IN THE COURT OF COMMON PLEAS of Cumberland County CIVIL ACTION - LAW ACTION OF MORTGAGE FORECLOSURE Term No. 03-6012 CIVIL TERM 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. TO: NOTICE OF SHERIFF'S SALE OF REAL PROPERTY STROHM, WILLIAM J. WILLIAM J, STROHM 7 Creek Road Camp Hill, PA 17011 Your house at Three North 30th Street, Camp Hill, PA 17011 is scheduled to be sold at SheritTs Sale on Wednesday, June 09, 2004, at 10:00 AM, in Commissioners Hearing Rm 2nd FL Courthouse to enforce the court judgment of $107,576.89 obtained by MORTGAGE ELECTRONIC REGISTRATION SYSTEMS, 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 MORTGAGE ELECTRONIC REGISTRATION SYSTEMS, 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 03-6012 CIV1L TERM 2. You may be able to stop the sale by filing a petition asking the Court to strike or open judgment, if the judgment was improperly entered. You may also ask the Court to postpone the sale for good cause. 3. You may also be able to stop the sale through other legal proceedings. You may need an attorney to assert your rights. The sooner you contact one, the more chance you will have of stopping the sale. (See notice below on how to obtain an attorney). YOU MAY STILL BE ABLE TO SAVE YOUR PROPERTY AND YOU HAVE OTHER RIGHTS EVEN IF THE SHERIFF'S SALE DOES NOT 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 amotmt 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 Sheriff within ten (10) days after the schedule of distribution is filed. 7. You may also have other rights and defenses, or ways of getting your house back, if you act immediately after the sale. YOU SHOULD TAKE THIS PAPER TO YOUR LAWYER AT ONCE. IF YOU DO NOT HAVE A LAWYER OR CANNOT AFFORD ONE, GO TO OR TELEPHONE THE OFFICE LISTED BELOW TO FIND OUT WHERE YOU CAN GET LEGAL HELP. LEGAL SERVICES INC 8 Irvine Row Carlisle, PA 17013 CUMBERLAND COUNTY BAR ASSOCIATION 2 Liberty Avenue Carlisle, PA 17013 03-6012 CIVIL TERM GOLDBECK McCAFFERTY & McKEEVER BY: Joseph A. Goldbeck, Jr. Attorney I.D.#16132 Suite 5000- Mellon Independence Center 701 Market Street Philadelphia, PA 1910O 215-627-1322 Attorney tbr Plaintiff MORTGAGE ELECTRONIC REGISTRATION SYSTEMS, INC. PO Box 9481 Mail Code: 22-528-1011 Gaithersburg, MD 20898-9481 Plaintiff vs. WILLIAM J. STROHM VICTORIA S. STROHM Mortgagor(s) and Record Owner(s) Three North 30th Street Camp Hill, PA I7011 IN THE COURT OF COMMON PLEAS of Cumberland County CIVIL ACTION - LAW ACTION OF MORTGAGE FORECLOSURE Term No. 03-6012 CIVIL TERM 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: STROHM, VICTORIA S. VICTORIA $. $TROHM 7 Creek Road Camp Hill, PA 17011 Your house at Three North 30th Street, Camp Hill, PA 17011 is scheduled to be sold at Sheriffs Sale on Wednesday, June 09, 2004, at 10:00 AM, in Commissioners Heating Rm 2nd FL Courthouse to enforce the court judgment of $107,576.89 obtained by MORTGAGE ELECTRONIC REGISTRATION SYSTEMS, 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 MORTGAGE ELECTRONIC REGISTRATION SYSTEMS, 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 03-6012 CIVIL TERM 2. You may be able to stop the sale by filing a petition asking the Court to strike or openjudgment, 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 tt~rough 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 SherifPs Sale is not stopped, your property will be sold to the highest bidder. You may End 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 tltrough only if the buyer pays the Sheriff the full amount due in the sale. To ftnd 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 Sheriff's Sale. This schedule will state who will be receiving that money. The money will be paid out in accordance with this schedule unless exceptions (reasons why the proposed distribution is wrong) are filed with the Sheriff within ten (10) days after the schedule of disthbution 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 ALL THAT CERTAiN TRACT OR LOT OF LAND SITUATE IN THE BOROUGH OF CAMP HILL, CUMBERLAND COUNTY, PENNSYLVANIA, MORE PARTICULARLY BOUNDED AND DESCRIBED AS FOLLOWS, TO WIT: BEGINNING AT A POINT ON THE EASTERN LINE OF 30TM STREET, SAID POINT BEiNG BY SAME MEASURED IN A NORTHEASTERLY DIRECTION 90 FEET FROM THE POINT ON THE WESTERN TERMINUS OF THE ARC OF A CURE HAV1NGA RADIUS OF 20 FEET CONNECTING THE EAST LINE OF 30TM STREET WITH THE NORTHERN LINE OF MARKET STREET; THENCE NORTH 02 DEEGREES 45 MINUTES EAST ALONG SAID EASTERN LINE OF 30TM STREET, A DISTANCE OF 50 FEET TO A POINT ON SAME, THENCE SOUTH 87 DEGREES 14 MINUTES EAST ALONG THE LiNE OF ADJOINER BETWEEN LOTS NOS. 1 AND 2 ON THE HEREiNAFTER MENTIONED PLAN OF LOTS, A DISTANCE OF 150 FEET TO A POiNT ON THE WESTERN LINE OF LANDS NOW OR LATE OF RAYMOND A. FORGIE, ET UX, THENCE SOUTH 02 DEGREES 45 MINUTES WEST, ALONG THE SAID WESTERN LINE OF LANDS, A DISTANCE OF 25 FEET TO A CONCRETE MONUMENT; THENCE NORTH 87 DEGREES 14 MINUTES WEST ALONG THE NORTHERN LiNE OF LANDS NOW OR LATE OF CHARLES R. NEWKAM, ET UX, A DISTANCE OF 70 FEET TO A POINT; THENCE SOUTH 02 DEGREES 45 MINUTES WEST ALONG THE WESTERN LINE OF SAID LANDS OF NEWKAM, A DISTANCE OF 25 FEET TO A POINT; THENCE NORTH 87 DEGREES 14 MINUTES WEST ALONG THE NORTHERN LINE OF LANDS NOW OR LATE ALLEN B. REYNOLDS, ET UX, A DISTANCE OF 80 FEET TO A POINT ON THE EASTERN LINE OF 30TM STREET, THE POINT AND PLACE OF BEGINNING. WRIT OF EXECUTION and/or ATTACHMENT COMMONWEALTH OF PENNSYLVANIA) NO 03-6012 Civil COUNTY OF CUMBERLAND) CIVIL ACTION - LAW TO THE SHERiI~F OF CUMBERLAND COUNTY: To satisfy the debt, interest and costs due MORTGAGE ELECTRONIC REGISTRATION, Plaintiff (s) From WILLIAM J. STROHM AND VICTORIA S. STROHM (I) You are directed to levy upon the property of the defendant (s)and to sell SEE LEGAL DESCRIPTION. (2) You are also d/xected 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 b~en 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 $107,576.89 L.L. $.50 Interest FROM 4/1/03 TO 1/2/04 AT 7.5000% Atty's Corem % Due Prothy $1.00 Atty Paid $145.32 Other Costs Plaintiff Paid Date: JANUARY 6, 2004 (SeaD REQUESTING PARTY: Name JOSEPH A. GOLDBECK, JR., ESQUIRE Address: SUITE 500 - THE BOURSE BLDG. 111 S. INDEPENDENCE MALL EAST PHILADELPHIA, PA 19106 Attorney for: PLAINTIFF Telephone: 215-627-1322 Supreme Court ID No. 16132 CURTIS R. LONG Prothonotary Deputy TR JE COPY FROM RECORD Real Estate Sale # 01 On February 12, 2004 the sheriff levied upon the defendant's interest in the real property situated in The Camp Hill Borough, Cumberland County, PA Known and numbered as 3 North 30th Street, Camp Hill, more fully described on Exhibit "A" filed with this writ and by this reference incorporated herein. Date: February 12, 2004 By: ,~, ~ ~ (~,~ i[3 Real Estate Deputy 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 Jottrnal, 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 ail 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: AP1LIL 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 ail allegations in the foregoing statements as to time, place and character of publication are true. Writ No. 2003-6012 Civil Mortgage Electronic Registration Systems, Inc. William J. Strohm and Victoria S. Strohm Atty.: Joseph Goldbeck ALL THAT CERTAIN tract or lot of land situate in the Borough of Camp Hill, Cumberland County, Pennsyl- vania, more particularly bounded and described as follows, to wit: BEGINNING at a point on the eastern l~ne of 30th Sweet, said point being by same measured in a nort~h- easterly direction 90 feet from the point on the western terminus of the arc of a cure having a radius of 20 feet connecting the east line of 30th Street with the northern line of Mar- ket Street; thence North 02 degrees 45 minutes East along said eastern line of 30th Street, a distance of 50 / ~trs~ ' ynp, Editor SW~R?fi/TO AND SUBSCRIBED before me this L/'30 day of APRIL 2004_ LOIS E. SNYDER, Notary Public Carlisle Bore, Cumberland County My Commission Expires March 5, 2005 Victo~a S, Strohrn Alty,: Joseph Galdheck ALL THAT CERTAIN tract or lot of land situate in the Borough of Camp Hill, Cumberland CounW, Pennsyl- vania, more particularly hounded and described as follows, to wlt: BEGINNING at a point on the eastern line of 30th SWeet, said point being by same measured in a north- easterly direction 90 feet from the point on the western terminus of the arc of a cure having a radius of 20 feet connecting the east line of 30th Street with the northern line of Mar- ket Street; thence North 02 degrees tine of 30th Street, a distance of 50 feet to a point on same, thence South 87 degrees 14 minutes East along the line of adjoiner between Lots Nos, 1 and 2 on the hereinafter men- tioned plan of lois, a distance of 150 feet to a point on the western line of lands now or late of Raymond A, Forgie et ux, thence South 02 de- grees 45 minutes West, along the said western line of lands, a dis- tance of 25 feet to a concrete monu- ment; thence North 87 degrees 14 minutes West along the northern line of lands now or late of Charles R. Newkam, et ux, a distance of 70 feet to a point; thence South 02 degrees 45 minutes West along the western line of said la~,ds of Newkam, a distance of 25 feet to a point; thence North 87 degrees 14 min- utes West along the northern line of lands now or late Allen B. Reynolds, et ux, a distance of 80 feet to a point on the eastern line of 30th Street, the point and place of beginning. _ ',../~0 _day 05 LOIS fi. SNYDER, b Carlisle Boro, Cumt~ My Commission Expire~ THE PATRIOT NEWS THE SUNDAY PATRIOT NEWS Proof of Publication UnderAct No. 587, Approved 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 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 on the 27th day(s) of April and the 4th and 11th day(s) of May 2004. That neither he nor said Company is interested in the subject matter of said pdnted notice or advertising, and that all of the aUegations 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 severaUy 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 Copn)/y c~ DauJ~hjn in Miscellaneous Book "M', vo,_ - PUBLICATION ............. ~._~ _......,._,.;,.....;~ ............................... cop v sworn to and su , d_ day , May 4 I 'rem/L Rus~ll, Nolor? ~bli¢ I ~' I~1-~'~""~['~x'[ ~ ~y at ~-mmsuurg, u~,l~, ,x NOTARY P UBLIC Member, Pennavlva~a~leolal~nolNotarle, My co~mJssioR expires June 6, 2~ CUMBER~ND ~ SHERIF~ OFFICE CUMBERED ~ ~SE CARLISLE, PA. 17013 Statement of Advertising Costs To THE PATRiOT-NEWS CO., Dr, For publishing the notice or publication attached hereto on the above stated dates Total $ 270.97 Publisher's Receipt for Advertising Cost t.~ 3. publisher of The Patriot-News and The Sunday Patriot-News, newspapers of general ge receipt of the aforesaid notice and publication costs and certifies that the same have ~ O~ By ....................................................................