HomeMy WebLinkAbout08-1864GOLDBECK McCAFFERTY & McKEEVER
BY: MICHAEL T. MCKEEVER
ATTORNEY I.D. #56129
SUITE 5000 - MELLON INDEPENDENCE CENTER
701 MARKET STREET
PHILADELPHIA, PA 19106
(866) 413-2311
W W W.GOLDBECKLAW.COM
ATTORNEY FOR PLAINTIFF
CITICORP TRUST BANK, FSB
1111 Northpoint Drive
Building 4, Suite 100
Coppell, TX 76078
Plaintiff
vs.
MICHELLE JACOME
Mortgagor and Real Owner
913 Susan Circle
Enola, PA 17025
IN THE COURT OF COMMON PLEAS
OF CUMBERLAND COUNTY
CIVIL ACTION - LAW
ACTION OF MORTGAGE FORECLOSURE
Defendant
Term 0$ _ l g& aiVi (T?rn?
CIVIL ACT N: MORTGAGE
NOTICE FCRECLOSL-RF
You have been sued in court. If you wish to defend against the claims set forth in the following pages,
you must take action within twenty (20) days after the Complaint and notice are served, by entering a written
appearance personally or by attorney and filing in writing with the court your defenses or objections to the
claims set forth against you. You are warned that if you fail to do so the case may proceed without you and a
judgment may be entered against you by the Court without further 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 rights
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 AT A REDUCED FEE OR NO FEE.
CUMBERLAND COUNTY BAR ASSOCIATION
2 Liberty Avenue
Carlisle, PA 17013
LEGAL SERVICES INC
8 Irvine Row
Carlisle, PA 17013
717-243-9400
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 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 OBJECCION CONTRA LAS QUEJAS EN ESTA
DEMANDA.
RECUERDE: SI USTED NO REPONDE A ESTA DEMANDA, SE PUEDE PROSEGUIR CON EL
PROCESO SIN SU PARTICIPACION. 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 DECISION, ES POSSIBLE QUE USTED PUEDA PERDER
DINERO, PROPIEDAD U OTROS DERECHOS IMPORTANTES.
USTED DEBE LLEVAR ESTE PAPEL A SU ABOGADO ENSEGUIDA. SI USTED NO TIENE UN
ABOGADO, VAYA O LLAME POR TELEFONO LA OFICINA FIJADA AQUI ABAJO. ESTA OFICINA
PUEDE PROVEERE CON INFORMACION DE COMO CONSEUIR UN ABOGADO.
SI USTED NO PUEDE PAGARLE A UN ABOGADO, ESTA OFICINA PUEDE PROVEERE
INFORMACION ACERCA AGENCIAS QUE PUEDAN OFRECER SERVICIOS LEGAL A PERSONAS
ELIGIBLE AQ UN HONORARIO REDUCIDO O GRATIS.
CUMBERLAND COUNTY BAR ASSOCIATION
2 Liberty Avenue
Carlisle, PA 17013
LEGAL SERVICES INC
8 Irvine Row
Carlisle, PA 17013
717-243-9400
THIS 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.
Resources available for Homeowners in Foreclosure
ACT NOW!
Even though your lender (and our client) has filed an Action of Mortgage Foreclosure against you, you
still may be able to SAVE YOUR HOME FROM FORECLOSURE.
1). Call an attorney. For referrals to a qualified attorney call either of the following numbers: or 717-
243-9400.
2). Call the Consumer Credit Counseling Agency at 1-800-989-2227 for free counseling.
3). Visit HUD's website www.hud.gov_ for Help for Homeowners Facing the Loss of Their Homes.
4). Pennsylvania Housing Finance Agency also offers other loan programs that may assist homeowners
in default. Please See the PHFA website httv://www.phfa.org/consumers/homeowners/real.aWx.
5). Call the Plaintiff (your lender) at and ask to speak to someone about Loss Mitigation or Home
Retention options.
6). Call or contact our office to request the amount to bring the account current, or payoff the mortgage
or request a Loan Workout / Home Retention Package. Call our toll free number at 1-866413-2311 or via email
at homeretention(a-)Roldbecklaw com. Call Seth at 215-825-6329 or fax 215-825-6429. The figure and/or
package you requested will be mailed to the address that you request or faxed if you leave a message with that
information. The attorney in charge of our firm's Homeowner Retention Department is David Fein who can be
reached at 215-825-6318 or Fax: 215-825-6418. Please reference our Attorney File Number of 64115FC.
Para informacion en espanol puede communicarse con Loretta al 215-825-6344.
This Action of Mortgage Foreclosure will continue unless you take action to stop it.
COMPLAINT IN MORTGAGE FORECLOSURE
Plaintiff is CITICORP TRUST BANK, FSB, 1111 Northpoint Drive, Building 4, Suite 100, Coppell,
TX 76078.
2. The names and addresses of the Defendant is MICHELLE JACOME, 913 Susan Circle, Enola, PA
17025, who is the mortgagor and real owner of the mortgaged premises hereinafter described.
3. On August 16, 2006 mortgagors made, executed and delivered a mortgage upon the Property hereinafter
described to CITICORP TRUST BANK, FSB, which mortgage is recorded in the Office of the Recorder
of Deeds of Cumberland County as Book 1963, Page 4054. The Mortgage and assignment(s) are
matters of public record and are incorporated by this reference in accordance with Pennsylvania Rule of
Civil Procedure 1019(g); which Rule relieves the Plaintiff from its obligation to attach documents to
pleadings if those documents are matters of public record.
4. The Property subject to the Mortgage is more fully described in the legal description set forth as Exhibit
"A" ("Property").
5. The mortgage is in default because the monthly payments of principal and interest are due and unpaid
for November 23, 2007 and each month thereafter and by the terms of the Mortgage, upon default in
such payments for a period of one month or more, the entire principal balance and all interest due and
other charges are due and collectible.
6. The following amounts are due to Plaintiff on the Mortgage:
Principal Balance ............................................................................
Interest from 10/23/2007 through 03/31/2008 at 9.5767% .............
Per Diem interest rate at $55.15
Reasonable Attorney's Fee at 5% of Principal Balance
as more fully explained in the next numbered paragraph .........
Late Charges from 11/23/2007 to 03/31/2008
.....$207,323.64
.........$7,697.77
........................................
Monthly late charge amount at $89.05
Cost f t d T' 1
$10,366.18
.....$445.24
s o sui an it a Search ......................................................................$900.00
Corporate Advance ......................................
..................................................$90.01
Monthly Escrow amount ...................................
..................... .$1.637.00
$228,459.84
7. If the Mortgage is reinstated prior to a Sheriff's Sale, the Attorney's Fees set forth above may be less
than the amount demanded based on work actually performed. The Attorney's Fees requested are in
conformity with the Mortgage and Pennsylvania law. Plaintiff is entitled to collect Attorney's fees of up
to 5% of the remaining principal balance in the event the Property is sold to a third party purchaser at
Sheriffs Sale or if the complexity of the action requires additional fees in excess of the amount
demanded in the Action.
8. Plaintiff is not seeking a judgment of personal liability (or an "in_personam" judgment) against the
Defendant in this Action but reserves its right to bring a separate Action to establish that right, if such
right exists. If Defendant has received a discharge of their personal liability in a Bankruptcy proceeding,
this Action of Mortgage Foreclosure is, in no way, an attempt to re-establish the personal liability that
was discharged in Bankruptcy, but only to foreclose the Mortgage and sell the Property pursuant to
Pennsylvania law.
9. Notice of Intention to Foreclose and a Notice of Homeowners' Emergency Mortgage Assistance has
been sent to Defendant by certified and regular mail, as required by Act 160 of 1998 of the
Commonwealth of Pennsylvania, on the date(s) set forth in the true and correct copy of such notice(s)
attached hereto as Exhibit "B". The Defendant have not had the required face-to-face meeting within
the required time and Plaintiff has no knowledge of any such meeting being requested by the Defendant
through the Plaintiff, the Pennsylvania Housing Finance Agency, or any appropriate Consumer Credit
Counseling Agency.
WHEREFORE, Plaintiff demands a de terns judgment in mortgage foreclosure in the sum of $228,459.84,
together with interest at the rate of $55.15, per day and other expenses, costs and charges incurred by the
Plaintiff which are properly chargeable in accordance with the terms of the Mortgage and Pennsylvania law
until the Mortgage is paid in full, and for the foreclosure of the Mortgage and Sheriff's Sale of the Property.
By: -Uk"w RkK
GOLDBECK McCAFFERTY & McKEEVER
BY: MICHAEL T. MCKEEVER, ESQUIRE
ATTORNEY FOR PLAINTIFF
VERIFICATION
I, Stanley Anya, as the representative of the Plaintiff corporation within named do hereby
verify that I am authorized to and do make this verification on behalf of the Plaintiff corporation and
the facts set forth in the foregoing Complaint are true and correct to the best of my knowledge,
information and belief. I understand that false statements therein are made subject to the penalties of
18 Pa. C.S. 4904 relating to unsworn falsification to authorities.
Date: I g
Assistant Vice President
2001809165 MICHELLE JACOME
ExhibitA
• - •
Schedule A
All THAT TRACT OR PARCEL OF LAND, situate in the Town of Perinton,
County of Monroe and State of New York, being part of Town Lot 51, Township 17,
Range 4, and more particularly known as Lot No. 5, as shown on a subdivision map
of Hickory Ridge, made by Sear, Brown, Schoenberger & Costich, Surveyors, and
filed in the Monroe County Clerk's Office in Liber 184 of Maps, at page 100 and in
Liber 185 of Maps, at Page 1.
Said Lot is located on the north side of Seibome Chase and the dimensions
of said lot are as set forth on the above referenced subdivision map of Hickory Ridge.
TOGETHER with all of the rights, privileges, easements and appurtenant
ownership interests in and to the premises previously conveyed to Hickory Ridge
Homeowners Association, Inc., by deed recorded in Monroe County Clerk's Office
in Liber 4159 of Deeds, at Page 20, and as more fully defined in the Declaration of
Covenants, Conditions and Restrictions recorded in Monroe County Clerk's Office
on the 18th day of October, 1971, in Liber 4159 of Deeds, at Page 3.
I
?(tidit ?
ACT 91 NOTICE
TAKE ACTION TO SAVE
YOUR HOME FROM
FORECLOSURE
Date: January 28, 2008
TO: Michelle Jacome
913 Susan Cir
Enola, PA 17025
THIS FIRM IS A DEBT COLLECTOR ATTEMPTING TO COLLECT A DEBT. THIS NOTICE IS
SENT TO YOU IN AN ATTEMPT TO COLLECT THE INDEBTEDNESS REFERRED TO HEREIN
AND ANY INFORMATION OBTAINED FROM YOU WILL BE USED FOR THAT PURPOSE. IF
YOU HAVE PREVIOUSLY RECEIVED A DISCHARGE IN BANKRUPTCY, THIS
CORRESPONDENCE IS NOT AND SHOULD NOT BE CONSTRUED TO BE AN ATTEMPT TO
COLLECT A DEBT, BUT ONLY ENFORCEMENT OF A LIEN AGAINST PROPERTY.
This is an official notice that the mortgage on our home is in default and the lender intends to foreclosure.
Specific information about the nature of the default is provided in the attached pages
The HOMEOWNER'S MORTGAGE ASSISTANCE PROGRAM HEMAP ma be able to help to save
your home. This Notice explains how the prog-ram works
To see if HEMAP can help, ou must MEET WITH A CONSUMER CREDIT COUNSELING AGENCY
WITHIN 33 DAYS FROM THE DATE OF THIS NOTICE. Take this Notice with You when you meet the
Counseling Agency.
The name address and hone number of Consumer Credit Counselin A encies serving our County are
listed at the end of this Notice. If ou have an uestions you ma call the Penns lvania 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 an
attorney in your area. The local bar association may be able to help you fmd a lawyer.
LA NOTIFICACION EN ADJUNTO ES DE SUMA IMPORTANCIA, PUEDE AFECTA SU DERECHO
A CONTINUAR VIVIENDO EN SU CASA. SI NO COMPRENDE EL CONTENIDO DE ESTA
NOTIFICACION OBTENGA UNA TRADUCCION INMEDITAMENTE LLAMANDO ESTA
AGENCIA (PENNSYLVANIA HOUSING FINANCE AGENCY) SIN CARGOS AL NUMERO
MENCIONADO ARRIBA. PUEDES SER ELEGIBLE PARA UN PRESTAMO POR EL PROGRAMA
LLAMADO "HOMEOWNERS EMERGENCY MORTGAGE ASSISTANCE PROGRAM" EL CUAL
PUEDE SALVAR SU CASA DE LA PERDIDA DEL DERECHO A REDIMAR SU HIPOTECA.
FC-1700-PHS CTB ACT 91 PA Breach Rev.05/26/2005
STATEMENTS OF POLICY
HOMEOWNER'S NAME (S):
PROPERTY ADDRESS:
LOAN ACCT. NO.:
ORIGINAL LENDER:
Michelle Jacome
913 Susan Cir, Enola, PA 17025
2001809065
Citicorp Trust Bank, fsb
CURRENT LENDER/SERVICER: Citicorp Trust Bank, fsb
HOMEOWNER'S 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 EMERGENCY 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.
TEMPORARY STAY OF FORECLOSURE-Under the Act, you are entitled to a temporary stay of
foreclosure on your mortgage for thirty three (33) days from the date of this Notice. During that time you
must arrange and attend a face-to-face meeting with one of the consumer credit counseling agencies listed
at the end of this Notice. THIS MEETING MUST OCCUR WITHIN THE NEXT (33) 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 of the consumer credit
counseling agencies encies listed at the end of this notice the lender may NOT take action against you for thirty
(30) days after 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 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 a 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 face-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.
FC-1700-PHS CTB ACT 91 PA Breach Rev.05/26/2005
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: IF YOU ARE CURRENTLY PROTECTED BY THE FILING OF A PETITION IN
BANKRUPTCY, THE FOLLOWING PART OF THIS NOTICE IS FOR INFORMATION
PURPOSES ONLY AND SHOULD NOT BE CONSIDERED AS AN ATTEMPT TO COLLECT
THE DEBT.
(If you have riled 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: 913 Susan Cir, Enola, PA 17025 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: Start/End: 11/23/07 through 1/23/08 at $2001.12 for 11/23/07 then
$2001.12 for 12/23/07 then $1912.07 for 1/23/08.
Monthly Payments Plus Late Charges Accrued $5914.31
NSF: $45.00
Payoff Statement: $15.00
BPO: $0.00
Speed Pay: $0.00
Fax Payoff Statement: $30.00
Uncollected Late Charges: $89.05
Recurr PWP: $0.01
Late Fee Income: $0.00
Total Amount to Cure Default $609337
B. YOU HAVE FAILED TO TAKE THE FOLLOWING ACTIONS (Do not use if not avplicable): N/A
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 $6093.37, PLUS ANY MORTGAGE PAYMENTS AND LATE CHARGES WHICH
BECOME DUE DURING THE THIRTY (30) DAY PERIOD. As of the date of this letter, you
owe the amount specified above. Because of interest, late charges, and other charges that may vary
from day to day, the amount due on the day that you pay may be greater. Hence, if you pay the
amount shown above, an adjustment may be necessary after we receive your check, in which event
we will inform you before depositing the check for collection. For further information, write the
undersigned or call (888) 800-5165. Payments must be made either by cash cashier's check,
certified check or money order made payable and sent to Citicorp Trust Bank, fsb 4050 Regent
Blvd. MS-NIB-165 Irving, TX 75063 Attention: Department ATM. You can cure any other
default by taking the following action within THIRTY (30) DAYS of the date of this letter. (Do
not use if not applicable) N/A
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 The 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 amount past due is not
made within THIRTY (30) DAYS, the lender also intends to instruct its attorney to start legal action to
foreclosure upon your mortgage vroppML
FC-1700-PHS CTB ACT 91 PA Breach Rev.05/26/2005
IF THE MORTGAGE IS FORECLOSED UPON- The mortgaged property will be sold by the Sheriff to
pay off the mortgage debt. If the lender refers your case to its attorneys, but you cure the delinquency
before the lender begins 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 to 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 Sheriff's Sale You may do so
b paying the total amount then past due plus an late or other charges then due reasonable attorney's fees
and costs connected with the foreclosure sale and any costs connected with the Sheriff's Sale as
s ecified in writing b the lender and b performing any re uirements 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.
EARLIEST POSSIBLE SHERIFF'S SALE DATE-It is estimated that the earliest date that such a Sheriff's
Sale of the mortgage property could be held would be approximately 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 be by contacting the lender.
HOW TO CONTACT THE LENDER: Citicorp Trust Bank, fsb
4050 Regent Blvd.
Irving, TX 75063
Attn: Department ATM
MS-N1B-165
(888) 800-5165
(Fax#) 972-657-1636
EFFECT OF SHERIFF'S SALE-You should realize that a Sheriffs Sale will end your ownership of the
mortgaged property and your right to occupy it. If you continue to live in the property after the Sheriff's
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 or X may not (CHECK ONE) sell or transfer
your home to a buyer or transferee who will assume the mortgage debt, provided that all the outstanding
payments, charge and attorney's fees and cost are paid prior to or at the sale and that the other requirements
of the mortgage are satisfied.
FC-1700-PHS CTB ACT 91 PA Breach Rev.05/26/2005
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.
• TO HAVE THIS DEFAULT CURED BY ANY THIRD PARTY ACTING ON YOUR BEHALF.
• TO HAVE THE MORTGAGE RESTORED TO THE SAME POSITION AS IF NO DEFAULT HAD
OCCURRED, IF YOU CURE THE DEFAULT. (HOWEVER, YOU NOT HAVE THIS RIGHT TO
CURE YOUR DEFAULT MORE THAN THREE TIMES IN ANY CALENDAR YEAR.)
• 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.
CONSUMER CREDIT COUNSELING AGENCIES SERVING YOUR COUNTY IS ATTACHED
If this is the fast notice that you have received from this office, be advised that: You may dispute the
validity of the debt or any portion thereof. If you do so in writing within thirty (30) days from the
receipt of this letter, this firm will obtain and provide you with written verification thereof, otherwise
the debt will be assumed to be valid. Likewise if requested in writing within thirty (30) days from
receipt of this letter, the firm will send you the name and address of the original creditor if different
from above.
Very truly yours,
Phelan Hallinan & Schmieg, LLP
On Behalf of Citifinancial Mortgage Company, Inc.
?y? 4L
By' --Z -
Francis S. limn, Esquire
PHS: gpd
Cc: Citicorp Trust Bank, fsb
Attn: Department ATM Account No.: 2001809065
Mailed by 0 Class Mail and by Certified Mail No: 7007 2680 0001 3588 5226
FC-1700-PHS CTB ACT 91 PA Breach
Rev.05/26/2005
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SHERIFF'S RETURN - REGULAR
CASE NO: 2008-01864 P
COMMONWEALTH OF PENNSYLVANIA:
COUNTY OF CUMBERLAND
CITICORP TRUST BANK FSB
VS
JACOME MICHELLE
KENNETH GOSSERT Sheriff or Deputy Sheriff of
Cumberland County,Pennsylvania, who being duly sworn according to law,
says, the within COMPLAINT - MORT FORE was served upon
JACOME MICHELLE the
DEFENDANT at 0014:02 HOURS, on the 10th day of April 2008
at 913 SUSAN CIRCLE
ENOLA, PA 17025 by handing to y
IVAN GARCIA FATHER IN LAW
a true and attested copy of COMPLAINT - MORT FORE together with
and at the same time directing His attention to the contents thereof.
Sheriff's Costs:
Docketing
Service'
Affidavit
Surcharge
18.00
15.00
.00
10.00
.00
43.00
So Answers:
-R Thomas Kline
04/11/2008
SRL
Sworn and Subscibed to By:
before me this day
of A.D.
GOLDBECK WCAFFERTY & WKEEVER
BY: MICHAEL T. MCKEEVER, ESQ.
ATTORNEY I.D. #56129
SUITE 5000 - MELLON INDEPENDENCE CENTER
701 MARKET STREET
PHILADELPHIA, PA 19106-1532
(215) 627-1322
ATTORNEY FOR PLAINTIFF
CITICORP TRUST BANK, FSB
1111 Northpoint Drive
Building 4, Suite 100
Coppell, TX 76078
Plaintiff
VS.
MICHELLE JACOME
(Mortgagor and Record Owner)
913 Susan Circle
Enola, PA 17025
Defendant(s)
IN THE COURT OF COMMON PLEAS
OF CUMBERLAND COUNTY
CIVIL ACTION - LAW
ACTION OF MORTGAGE
FORECLOSURE
Term
No. 08-1864
PRAECIPE TO SUBSTITUTE LEGAL DESCRIPTION
Kindly substitute the attached legal description in place of the legal description attached to
Plaintiff s complaint.
Respectfully submitted,
GOLDBECK, McCAFFERTY & McKEEVER
By: NIA 1-'
Michael T. McKeever, Esquire
Attorney for Plaintiff
V
Chesapeake Settlement Services LLC
PROPERTY REPORT AS OF 8/1512046 5:57:34 PM
ORDER NUMWk 5154421
CUS MSR NAME MICHELLE JACOME
APPL"TION Na W34427814_PROPRP7 0
ALLTHAT CERTAIN PARCEL OF LAND IN THE TOVIMSHIP OF EAST PENNS130RO*
CUMBERLAND COUNTY, COMMONWEALTH OF PA, AS MORE FULLY DESCRIBED IN
BOOK 261 PAGE 2680 IDS 09-140838-278, BEING KNOWN AND 13ESIGNATED AS LOT
NO. 121, FINAL SUBDIVISION PLAN FOR LOGANS RUN, PHASE IV, FILED IN PLAT
GOOK PLAN BOOK 82 AT PAGE 27.
BEING THE SAME PROPERTY CONVEYED BY FEE SIMPLE DEED FROM CHARTER
HOMES BUILDING COMPANY, A PENNSYLVANIA CORPORATION, RECORD OWNER
AND VILLAGE HOME BUILDERS, INC., A PENNSYLVANIA CORPORATION. EQUITABLE
OWNER TO MICHELLE M. JACOME , DATED 0112812004 RECORDED ON 02RW2004
IN BOOK 281 PAGE 2880 IN CUMBERLAND COUNTY RECORDS, COMMONWEALTH OF
PA,
THIS PROPERTY AND JUDGMENT REPORT MAY NOT SET FORTH LIENS FOR CHILD
SUPPORTARREARAGES. SUCH LIENS FOR CHILD SUPPORTARREARAGES MAY
HAVE PRIORITY OVER THE INSURED MORTGAGE.
TOTAL CONSIDERATION IS $193,961.00.
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In the Court of Common Pleas of Cumberland County
CITICORP TRUST BANK, FSB
1111 Northpoint Drive
Building 4, Suite 1.00
Coppell, TX 76078
vs.
MICHELLE JACOME
(Mortgagor(s) and Record Owner(s))
913 Susan Circle
Enola, PA 17025
Plaintiff
Defendant(s)
PRAECIPE FOR JUDGMENT
No. 08-1864
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 MICHELLE JACOME by default for want of an Answer.
Assess damages as follows:
Debt
Interest from 05/14/2008 to Date of Sale
Total
(Assessment of Damages attached)
$233,910.62
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 and at least ten days prior to the date of the
filing of this praecipe. A copy of the notice is attached. R.C.P. 237.1
Michael T. McKeever
Attorney for Plaintiff
I.D. #56129
AND NOW Mau 1T , 0200,2 , Judgment is entered in favor of
CITICORP TRUST BANK, FSBafid against MICHELLE JACOME by default for want of an Answer and damages
assessed in the sum of $233,910.62 as per the above certification.
Pro onotary
64115FC
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: May 1, 2008
TO:
MICHELLE JACOME
913 Susan Circle
Enola, PA 17025
CITICORP TRUST BANK, FSB
1111 Northpoint Drive
Building 4, Suite 100
Coppell, TX 76078
vs.
MICHELLE JACOME
(Mortgagor(s) and Record Owner(s))
913 Susan Circle
Enola, PA 17025
TO: MICHELLE JACOME.
913 Susan Circle
Enola, PA 17025
Plaintiff
Defendant(s)
In the Court of
Common Pleas
of Cumberland County
CIVIL ACTION - LAW
Action of
Mortgage Foreclosure
Term
No. 08-1864
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 PAPER TO YOUR LAWYER AT ONCE. IF YOU DO NOT HAVE A
LAWYER, 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 AT A REDUCED FEE OR NO FEE.
CUMBERLAND COUNTY BAR ASSOCIATION
2 Liberty Avenue
Carlisle, PA 17013
LEGAL SERVICES INC
8 Irvine Row
Carlisle, PA 17013
717-243-9400
Michael T. McKeever
GOLDBECK McCAFFERTY & McKEEVER
BY: Michael T. McKeever, Esq.
Attorney for Plaintiff
Suite 5000 - 701 Market Street.
Philadelphia, PA 19106 215-825-6318
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, MICHELLE JACOME, is
about unknown years of age, that Defendant's last known
residence is 913 Susan Circle, Enola, PA 17025, 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:
GOLDBECK McCAFFERTY & McKEEVER
BY: Michael T. McKeever
Attorney I.D. #56129
Suite 5000 - Mellon Independence Center
701 Market Street
Philadelphia, PA 19106
215-627-1322
Attorney for Plaintiff
CITICORP TRUST BANK, FSB
1111 Northpoint Drive
Building 4, Suite 100
Coppell, TX 76078
VS.
MICHELLE JACOME
(Mortgagor(s) and Record owner(s))
913 Susan Circle
Enola, PA 17025
IN THE COURT OF COMMON PLEAS
Plaintiff
of Cumberland County
CIVIL ACTION LAW
ACTION OF MORTGAGE FORECLOSURE
Defendant(s)
No. 08-1864
ORDER FOR JUDGMENT
Please enter Judgment in favor of CITICORP TRUST BANK, FSB, and against MICHELLE JACOME
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 $233,910.62.
Michael T. McKeever
Attorney for Plaintiff
I hereby certify that the above names are correct and that the precise residence address of the judgment
creditor is CITICORP TRUST BANK, FSB 1111 Northpoint Drive Building 4, Suite 100 Coppell, TX 76078 and
that the name(s) and last known address(es) of the Defendant(s) is/are MICHELLE JACOME, 913 Susan Circle
Enola, PA 17025;
T - WU
GOLDBECK McCAFFERTY & McKEEVER
BY: Michael T. McKeever
Attorney for Plaintiff
• ASSESSMENT OF DAMAGES
TO THE PROTHONOTARY:
Kindly assess the damages in this case to be as follows:
Principal Balance
Interest from 10/23/2007 through
05/13/2008
Reasonable Attorney's Fee
Late Charges
Costs of Suit and Title Search
Escrow Payments Due 2 X $859.93
Corporate Advance
Escrow
$207,323.64
$11,250.59
$10,366.18
$623.34
$900.00
$1,719.86
$90.01
$1,637.00
$233,910.62
GOLDBECK McCAFFERTY & McKEEVER
BY: Michael T. McKeever
Attorney for Plaintiff
AND NOW, this 141k day of 2008 damages are assessed as above.
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Rule of Civil Procedure No. 236 - Revised
IN THE COURT OF COMMON PLEAS
OF Cumberland COUNTY, PENNSYLVANIA
CIVIL ACTION - LAW
CITICORP TRUST BANK, FSB
1111 Northpoint Drive
Building 4, Suite 100
Coppell, TX 76078
Plaintiff
vs.
MICHELLE JACOME
(Mortgagors and Record Owner(s))
913 Susan Circle
Enola, PA 17025
Defendant(s)
No. 08-1864
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
By: - lat'71c'
If you have any questions concerning the above, please contact: 61,4102
Michael T. McKeever
Goldbeck McCafferty & 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
Michael T. McKeever
Attorney I.D.#56129
Suite 5000 - Mellon Independence Center
701 Market Street
Philadelphia, PA 19106
215-627-1322
Attorney for Plaintiff
CITICORP TRUST BANK, FSB
1111 Northpoint Drive
Building 4, Suite 100
Coppell, TX 76078
vs.
MICHELLE JACOME
Mortgagor(s) and Record Owner(s)
913 Susan Circle
Enola, PA 17025
IN THE COURT OF COMMON PLEAS
Plaintiff
of Cumberland County
CIVIL ACTION - LAW
ACTION OF MORTGAGE FORECLOSURE
No. 08-1864
Defendant(s)
PRAECIPE FOR WRIT OF EXECUTION
TO THE PROTHONOTARY:
Issue Writ of Execution in the above matter:
Amount Due
Interest from
05/14/2008 to Date of
Sale at 9.5767%
(Costs to be added)
$233,910.62
Ut sj T. u uQ j ,)
GOLDBECK McCAFFERTY & McKEEVER
BY: Michael T. McKeever
Attorney for Plaintiff
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ALL THAT CERTAIN lot or piece of land situate in East Pennsboro Township,
Cumberland County, Commonwealth of Pennsylvania, more particularly bounded and
described as follows, to wit:
BEGINNING at a point on the northern dedicated right-of-way line of Susan Circle at the
dividing line of Lot #120 and Lot #121; thence by the northern right-of-way line of Susan
Circle South sixty-two degrees fifty-five minutes fifty-three seconds West (South 62
degrees 55 minutes 53 seconds West), eighty and zero hundredths (80.00) feet to a point
at the dividing line of Lot #122 and Lot #121; thence by line of Lot #122 North twenty-
seven degrees four minutes seven seconds West (North 27 degrees 04 minutes 07 seconds
West), one hundred and zero hundredths (100.00) feet to a point at the dividing line of
Lot #123 and Lot #121; thence by line of Lot #123 North sixty-two degrees fifty-five
minutes fifty-three seconds East (North 62 degrees 55 minutes 53 seconds East), eighty
and zero hundredths (80.00) feet to a point at the dividing line of Lot #120 and Lot #121;
thence by line of Lot #120 South twenty-seven degrees four minutes seven seconds East
(South 27 degrees 04 minutes 07 seconds East), one hundred and zero hundredths
(100.00) feet to a point at the northern right-of-way line of Susan Circle, the place of
BEGINNING.
BEING Lot #121 on the Final Subdivision Plan for Logans Run, Phase IV, recorded in
Plan Book 82, Page 27.
TAX PARCEL #: 09-14-0836-278
MUNICIPALITY: EAST PENNSBORO TOWNSHIP
PROPERTY ADDRESS: 913 SUSAN CIRCLE, ENOLA, PA 17025
Goldbeck McCafferty & McKeever
BY: Michael T. McKeever
Attorney I.D. #56129
Suite 5000 - Mellon Independence Center
701 Market Street
Philadelphia, PA 19106
215-627-1322
Attorney for Plaintiff
CITICORP TRUST BANK, FSB
1111 Northpoint Drive
Building 4, Suite 100
Coppell, TX 76078
vs.
MICHELLE JACOME
(Mortgagor(s) and Record Owner(s))
913 Susan Circle
Enola, PA 17025
IN THE COURT OF COMMON PLEAS
Plaintiff
of Cumberland County
CIVIL ACTION - LAW
ACTION OF MORTGAGE FORECLOSURE
Defendant(s)
No. 08-1864
AFFIDAVIT PURSUANT TO RULE 3129
CITICORP TRUST BANK, FSB, Plaintiff in the above action, by its attorney, Michael T. McKeever, 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:
913 Susan Circle
Enola, PA 17025
1.Name and address of Owner(s) or Reputed Owner(s):
MICHELLE JACOME
913 Susan Circle
Enola, PA 17025
2. Name and address of Defendant(s) in the judgment:
MICHELLE JACOME
913 Susan Circle
Enola, PA 17025
3. Name and last known address of every judgment creditor whose judgment is a record lien on the property to be sold:
PA DEPARTMENT OF PUBLIC WELFARE - Bureau of Child Support Enforcement
Health and Welfare Bldg. - Room 432
Harrisburg, PA 17105-2675
DOMESTIC RELATIONS OF CUMBERLAND COUNTY
PO Box 320
Carlisle, PA 17013
4. Name and address of the last recorded holder of every mortgage of record:
0,40
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
913 Susan Circle
Enola, PA 17025
(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: May 13, 2008 U"&U:T-LWUX?1
GOLDBECK McCAFFERTY & McKEEVER
BY: Michael T. McKeever, Esq.
Attorney for Plaintiff
m
cr,
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?T
Michael T. McKeever
Attorney I.D. #56129
Suite 5000 - Mellon Independence Center
701 Market Street
Philadelphia, PA 19106
215-627-1322
Attorney for Plaintiff
CITICORP TRUST BANK, FSB
1111 Northpoint Drive
Building 4, Suite 100
Coppell, TX 76078
vs.
MICHELLE JACOME
Mortgagor(s) and Record Owner(s)
913 Susan Circle
Enola, PA 17025
Plaintiff
Defendant(s)
IN THE COURT OF
COMMON PLEAS
of Cumberland County
CIVIL ACTION - LAW
ACTION OF
MORTGAGE FORECLOSURE
NO. 08-1864
CERTIFICATION AS TO THE SALE OF REAL PROPERTY
I, Michael T. McKeever, Esquire hereby certify that I am the attorney of record for the Plaintiff in this action, and
I further certify that this property is subject to Act 91 of 1983 and the Plaintiff has complied with all the provisions of the
Act.
uNa-u ' -
Michael T. McKeever
Attorney for plaintiff
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08-1864
GOLDBECK McCAFFERTY & McKEEVER
BY: Michael T. McKeever
Attorney I.D.#56129
Suite 5000- Mellon Independence Center
701 Market Street
Philadelphia, PA 19106
215-825-6318
Attorney for Plaintiff
CITICORP TRUST BANK, FSB
1111 Northpoint Drive
Building 4, Suite 100
Coppell, TX 76078
VS.
MICHELLE JACOME
Mortgagor(s) and Record Owner(s)
913 Susan Circle
Enola, PA 17025
IN THE COURT OF COMMON PLEAS
of Cumberland County
Plaintiff
CIVIL ACTION - LAW
ACTION OF MORTGAGE
FORECLOSURE
Term
No. 08-1864
Defendants
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: JACOME, MICHELLE
MICHELLE JACOME
913 Susan Circle
Enola, PA 17025
Your house at 913 Susan Circle, Enola, PA 17025 is scheduled to be sold at Sheriffs Sale on
Wednesday, September 03, 2008, at 10:00 AM, in Commissioners Hearing Rm 2nd FL Courthouse to
enforce the court judgment of $233,910.62 obtained by CITICORP TRUST BANK, FSB 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 CITICORP TRUST BANK, FSB, the back payments, late
charges, costs and reasonable attorney's fees due. To find out how much you must pay call our office at
215-825-6329 or 1-866-413-2311.
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.
J
08-1864
3. You may also be able to stop the sale through other legal proceedings
4. 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 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 within 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.
CUMBERLAND COUNTY BAR ASSOCIATION
2 Liberty Avenue
Carlisle, PA 17013
LEGAL SERVICES INC
8 Irvine Row
Carlisle, PA 17013
717-243-9400
4
08-1864
Resources available for Homeowners in Foreclosure
ACT NOW!
Even though your lender (and our client) has filed an Action of Mortgage
Foreclosure against you, you still may be able to SAVE YOUR HOME FROM
FORECLOSURE.
1). Call an attorney. For referrals to a qualified attorney call either of the
following numbers: or 717-243-9400.
2). Call the Consumer Credit Counseling Agency at 1-800-989-2227 for free
counseling.
3). Visit HUD'S website www.hud.gov for Help for Homeowners Facing the
Loss of Their Homes.
4). Pennsylvania Housing Finance Agency also offers other loan programs that
may assist homeowners in default. Please See the PHFA website
htip://www.phfa.oriz/consumers/homeowners/real.awx.
5). Call the Plaintiff (your lender) at and ask to speak to someone about Loss
Mitigation or Home Retention options.
6). Call or contact our office to request the amount to bring the account current,
or payoff the mortgage or request a Loan Workout / Home Retention Package. Call our
toll free number at 1-866-413-2311 or via email at homeretentionggoldbecklaw com.
Call Seth at 215-825-6329 or fax 215-825-6429. The figure and/or package you
requested will be mailed to the address that you request or faxed if you leave a message
with that information. The attorney in charge of our firm's Homeowner Retention
Department is David Fein who can be reached at 215-825-6318 or Fax: 215-825-6418.
Please reference our Attorney File Number of 64115FC.
Para informacion en espanol puede communicarse con Loretta a1215-825-6344.
WRIT OF EXECUTION and/or ATTACHMENT
COMMONWEALTH OF PENNSYLVANIA)
COUNTY OF CUMBERLAND)
NO 08-1864 Civil
CIVIL ACTION - LAW
TO THE SHERIFF OF CUMBERLAND COUNTY:
To satisfy the debt, interest and costs due CITICORP TRUST BANK, FSB, Plaintiff (s)
From MICHELLE JACOME
(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 $233,910.62 L.L.$ 0.50
Interest from 5/14/08 to Date of Sale at 9.5767%
Atty's Comm % Due Prothy $2.00
Atty Paid 5162.00 Other Costs to be added
Plaintiff Paid
Date: 5/14/08
rothonotary
(Seal) By:
REQUESTING PARTY:
Name: MICHAEL T. MCKEEVER, ESQUIRE
Address: GOLDBECK MCCAFFERTY & MCKEEVER
SUITE 5000-MELLON INDEPENDENCE CENTER
701 MARKET STREET
PHILADELPHIA, PA 19106
Attorney for: PLAINTIFF
Telephone: 215-627-1322
Deputy
Supreme Court ID No. 56129
Citicorp Trust Bank
VS
Michelle Jacome
In The Court of Common Pleas of
Cumberland County, Pennsylvania
Writ No. 2008-1864 Civil Term
R. Thomas Kline, Sheriff, who being duly sworn according to law, states this writ
is returned STAYED per letter of request from Attorney Michael McKeever.
Sheriff s Costs:
Docketing
Poundage
Levy
Law Library
Prothonotary
Mileage
Surcharge
So Answers:
;i
-000 10
R. Thomas Kline, Sheriff
I
BY - j t .
Real Estate S geant
30.00
76.50
15.00
.50
2.00
14.00
20.00
$158.00
C k_ 6 V S4 .2)
w
Plaintiff
Defendant(s)
IN THE COURT OF COMMON PLEAS
of Cumberland County
CIVIL ACTION - LAW
ACTION OF MORTGAGE FORECLOSURE
No. 08-1864
AFFIDAVIT PURSUANT TO RULE 3129
Goldbeck McCafferty & McKeever
BY: Michael T. McKeever
Attorney I.D. #56129
Suite 5000 - Mellon Independence Center
701 Market Street
Philadelphia, PA 19106
215-627-1322
Attorney for Plaintiff
CITICORP TRUST BANK, FSB
1111 Northpoint Drive
Building 4, Suite 100
Coppell, TX 76078
VS.
MICHELLE JACOME
(Mortgagor(s) and Record Owner(s))
913 Susan Circle
Enola, PA 17025
CITICORP TRUST BANK, FSB, Plaintiff in the above action, by its attorney, Michael T. McKeever, 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:
913 Susan Circle
Enola, PA 17025
1.Name and address of Owner(s) or Reputed Owner(s):
MICHELLE JACOME
913 Susan Circle
Enola, PA 17025
2. Name and address of Defendant(s) in the judgment:
MICHELLE JACOME
913 Susan Circle
Enola, PA 17025
3. Name and last known address of every judgment creditor whose judgment is a record lien on the property to be sold:
PA DEPARTMENT OF PUBLIC WELFARE - Bureau of Child Support Enforcement
Health and Welfare Bldg. - Room 432
Harrisburg, PA 17105-2675
DOMESTIC RELATIONS OF CUMBERLAND COUNTY
PO Box 320
Carlisle, PA 17013
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
913 Susan Circle
Enola, PA 17025
(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: May 13, 2008 Uffl&u I ?"
GOLDBECK McCAFFERTY & McKEEVER
BY: Michael T. McKeever, Esq.
Attorney for Plaintiff
/'
08-1864
GOLDBECK McCAFFERTY & MCKEEVER
BY: Michael T. McKeever
AttoAiey I.D.#56129
Suite 5000- Mellon Independence Center
701 Market Street
Philadelphia, PA 19106
215-825-6318
Attorney for Plaintiff
CITICORP TRUST BANK, FSB
1111 Northpoint Drive
Building 4, Suite 100
Coppell, TX 76078
Plaintiff
vs.
MICHELLE JACOME
Mortgagor(s) and Record Owner(s)
913 Susan Circle
Enola, PA 17025
Defendant(s;
Term
No. 08-1864
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: JACOME, MICHELLE
MICHELLE JACOME
913 Susan Circle
Enola, PA 17025
Your house at 913 Susan Circle, Enola, PA 17025 is scheduled to be sold at Sheriffs Sale on
Wednesday, September 03, 2008, at 10:00 AM, in Commissioners Hearing Rm 2nd FL Courthouse to
enforce the court judgment of $233,910.62 obtained by CITICORP TRUST BANK, FSB 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 CITICORP TRUST BANK, FSB, the back payments, late
charges, costs and reasonable attorney's fees due. To find out how much you must pay call our office at
215-825-6329 or 1-866-413-2311.
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.
IN THE COURT OF COMMON PLEAS
of Cumberland County
CIVIL ACTION - LAW
ACTION OF MORTGAGE
FORECLOSURE
08-1864
3. You may also be able to stop the sale through other legal proceedings.
4. 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 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 within 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.
CUMBERLAND COUNTY BAR ASSOCIATION
2 Liberty Avenue
Carlisle, PA 17013
LEGAL SERVICES INC
8 Irvine Row
Carlisle, PA 17013
717-243-9400
08-1864
Resources available for Homeowners in Foreclosure
ACT NOW!
Even though your lender (and our client) has filed an Action of Mortgage
Foreclosure against you, you still may be able to SAVE YOUR HOME FROM
FORECLOSURE.
1). Call an attorney. For referrals to a qualified attorney call either of the
following numbers: or 717-243-9400.
2). Call the Consumer Credit Counseling Agency at 1-800-989-2227 for free
counseling.
3). Visit HUD's website www.hud.gov for Help for Homeowners Facing the
Loss of Their Homes.
4). Pennsylvania Housing Finance Agency also offers other loan programs that
may assist homeowners in default. Please See the PHFA website
http://www.phfa.orgjconsumers/homeowners/real.gvx.
5). Call the Plaintiff (your lender) at and ask to speak to someone about Loss
Mitigation or Home Retention options.
6). Call or contact our office to request the amount to bring the account current,
or payoff the mortgage or request a Loan Workout / Home Retention Package. Call our
toll free number at 1-866-413-2311 or via email at homeretentionggoldbecklaw.com.
Call Seth at 215-825-6329 or fax 215-825-6429. The figure and/or package you
requested will be mailed to the address that you request or faxed if you leave a message
with that information. The attorney in charge of our firm's Homeowner Retention
Department is David Fein who can be reached at 215-825-6318 or Fax: 215-825-6418.
Please reference our Attorney File Number of 64115FC.
Para informacion en espanol puede communicarse con Loretta al 215-825-6344.
ALL THAT CERTAIN lot or piece of land situate in East Pennsboro Township,
CurAberland County, Commonwealth of Pennsylvania, more particularly bounded and
described as follows, to wit:
BEGINNING at a point on the northern dedicated right-of-way line of Susan Circle at the
dividing line of Lot #120 and Lot #121; thence by the northern right-of-way line of Susan
Circle South sixty-two degrees fifty-five minutes fifty-three seconds West (South 62
degrees 55 minutes 53 seconds West), eighty and zero hundredths (80.00) feet to a point
at the dividing line of Lot #122 and Lot #121; thence by line of Lot #122 North twenty-
seven degrees four minutes seven seconds West (North 27 degrees 04 minutes 07 seconds
West), one hundred and zero hundredths (100.00) feet to a point at the dividing line of
Lot #123 and Lot #121; thence by line of Lot #123 North sixty-two degrees fifty-five
minutes fifty-three seconds East (North 62 degrees 55 minutes 53 seconds East), eighty
and zero hundredths (80.00) feet to a point at the dividing line of Lot #120 and Lot #121;
thence by line of Lot #120 South twenty-seven degrees four minutes seven seconds East
(South 27 degrees 04 minutes 07 seconds East), one hundred and zero hundredths
(100.00) feet to a point at the northern right-of-way line of Susan Circle, the place of
BEGINNING.
BEING Lot #121 on the Final Subdivision Plan for Logans Run, Phase IV, recorded in
Plan Book 82, Page 27.
TAX PARCEL #: 09-14-0836-278
MUNICIPALITY: EAST PENNSBORO TOWNSHIP
PROPERTY ADDRESS: 913 SUSAN CIRCLE, ENOLA, PA 17025
WRIT OF EXECUTION and/or ATTACHMENT
COMMONWEALTH OF PENNSYLVANIA)
COUNTY (1F CUMBERLAND)
NO 08-1864 Civil
CIVIL ACTION - LAW
TO THE SHERIFF OF CUMBERLAND COUNTY:
To satisfy the debt, interest and costs due CITICORP TRUST BANK, FSB, Plaintiff (s)
From MICHELLE JACOME
(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 $233,910.62 L.L.$ 0.50
Interest from 5/14/08 to Date of Sale at 9.5767%
Atty's Comm % Due Prothy $2.00
Atty Paid $162.00 Other Costs to be added
Plaintiff Paid
Date: 5/14/08
-72
Prothonotary
(Seal) By:
REQUESTING PARTY:
Name: MICHAEL T. MCKEEVER, ESQUIRE
Address: GOLDBECK MCCAFFERTY & MCKEEVER
SUITE 5000-MELLON INDEPENDENCE CENTER
701 MARKET STREET
PHILADELPHIA, PA 19106
Attorney for: PLAINTIFF
Deputy
Telephone: 215-627-1322
Supreme Court ID No. 56129
Real Estate Sale #46
On May 21, 2008 the Sheriff levied upon the
defendant's interest in the real property situated in
East Pennsboro Township, Cumberland County, PA
Known and numbered as 913 Susan Circle, Enola
more fully described on Exhibit "A"
filed with this writ and by this reference
incorporated herein.
Date: May 21, 2008 By:
Real E ate Sergeant
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GOLDBECK McCAFFERTY & MCKEEVER `
BY: Michael T. McKeever
Attorney I.D. #56129
Suite 5000 - Mellon Independence Center
701 Market Street
Philadelphia, PA 19106-1532
215-627-1322
Attorney for Plaintiff
CITICORP TRUST BANK, FSB
1111 Northpoint Drive
Building 4, Suite 100
Coppell, TX 76078
VS.
MICHELLE JACOME
913 Susan Circle
Enola, PA 17025
TO THE PROTHONOTARY::
IN THE COURT OF COMMON PLEAS
OF CUMBERLAND COUNTY
Plaintiff
No. 08-1864
Defendant
PRAECIPE TO VACATE JUDGMENT
Kindly vacate the judgment upon payment of your costs only.
_4?
MICHAEL T. MCKEEVER, ESQUIRE
rte"
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00
GOLDBECK McCAFFERTY & McKEEVER 41
BY: Michael T. McKeever
Attorney I.D. #56129
Suite 5000 - Mellon Independence Center
701 Market Street
Philadelphia, PA 19106-1532
215-825-6321
Attorney for Plaintiff
CITICORP TRUST BANK, FSB
1111 Northpoint Drive
Building 4, Suite 100
Coppell, TX 76078
VS.
MICHELLE JACOME
913 Susan Circle
Enola, PA 17025
IN THE COURT OF COMMON PLEAS
Plaintiff
OF CUMBERLAND COUNTY
No. 08-1864
Defendant
PRAECIPE TO DISCONTINUE AND END
TO THE PROTHONOTARY:
Kindly mark the above case Discontinued and Ended upon payment of your costs only.
MICHAEL T. MCKEEVER, ESQUIRE
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