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Home My WebLink About04-0565 GOLDBECK McCAFFERTY & McKEEVER By: JOSEPH A, GOLDBECK, JR, ATTORNEY I.D. #16132 SUITE 5000 - MELLON INDEPENDENCE CENTER, 701 MARKET STREET PHILADELPHIA, PA 19106 (215) 627-1322 ATTORNEY FOR PLAINTIFF MORTGAGE ELECTRONIC REGISTRATION SYSTEMS, INC. 71 05 Corporate Drive PTX C-35 Piano, TX 75024-3632 IN THE COURT OF COMMON PLEAS OF CUMBERLAND COUNTY CIVIL ACTION - LAW Plaintiff vs. ACTION OF MORTGAGE FORECLOSURE DZEV AD BEGANOVIC MEHO BEGANOVIC Mortgagor(s) and Real Owner(s) Tenn No. 04 -S"(.. S' c.'U\-l T €..a..."r) 1 South Second Street Wonnleysburg, PA 17043 Defendant(s) CIVIL ACTION: MORTGAGE FOfItECL08URE THIS FIRM IS A DEBT COLLECTOR AND WE ARE ATTEMPTINGTO COLLECT A DEBT OWED TO OUR CLIENT. ANY INFORMATION OBTAINED FROM YOU WILL BE USED FOR THE PURPOSE OF COLLECTING THE DEBT. NOTICE You have been sued in court. If you 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 yOll 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. LEGAL SERVICES INC 8 Irvine Row Car]isle, PA 17013 717-243-9400 CUMBERLAND COUNTY BAR ASSOCIATION 2 Liberty Avenue Carlisle, PA ]7013 A-Y..!...S....Q LE HAN DEMANDADO A USTED EN LA CORTE. SI DESEA DEFENDERSECONTRA LAS QUFJAS PERESENTADAS, ES ABSOLUTAMENTE NECESSARIO QUE USTED RESPONDA DENTRO DE 20 DIAS DESPUES DE SER SERVlOO CON ESTA DEMANDA Y A VISO. PARA DEFENDERSE ES NECESSARIO QUE USTED, 0 SU ABOGAOO, REGISTRECON LA CORTE EN FORMA ESCRITA. EL PUNTO DE VISTA DE USTED Y CUALQUlER OBJECCION CONTRA LAS QUEJAS EN ESTA DEMANDA. RECUERDE: SI USTED NO REPONDE A ESTA DEMANDA, SE PUEDEPROSEGUIR CON ELPROCESO 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 PAPELA SU ABOGAOO ENSEGUIDA. 51 USTED NOTIENE UN ABOGAOO, VAYA 0 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 ABOGAOO, ESTA OFICINA PUEDE PROVEERE INFORMACION ACERCA AGENCIAS QUE PUEDAN OFRECER SERVICIOS LEGAL A PERSONAS ELIGIBLE AQ UN HONORARIO REDUCIDO 0 GRATIS. LEGAL SERVICES INC 8 Irvine Row Carlisle, PA 17013 717-243-9400 CUMBERLAND COUNTY BAR ASSOCIATION 2 Liberty Avenue Carlisle,PA 170]3 COMPLAINT IN MORTGAGE FORECLOSURE 1. Plaintiffis MORTGAGE ELECTRONIC REGISTRATION SYSTEMS, INC., 7105 Corporate Drive, PTX C-35 PIano, TX 75024-3632. 2. The name(s) and addressees) of the Defendant(s) is/are DZEV AD BEGANOVIC, I South 2nd Street, Wormleysburg, PA 17043-1303 and MEHO BEGANOVIC, I South 2nd Street, Wormleysburg, PA 17043-1303, who is/are the mortgagor(s) and real owner(s) of the mortgaged premises hereinafter described. 3. On June 21, 2002 mortgagor(s) made, executed and delivered a mortgage upon the premises hereinafter described to MORTGAGE ELECTRONIC REGISTRATION SYSTEMS, INC., which mortgage is recorded in the Office of the Recorder of Deeds of Cumberland County as Book: 1764 Page: 2212. The mortgage has not been assigned unless said assignment to the Plaintiff is hereafter mentioned. These documents are matters of public record and are incorporated herein by reference in accordance with Pennsylvania Rule of Civil Procedure 1019(g). 4. The premises subject to said mortgage is described as attached. 5. The mortgage is in default because monthly payment of principal and interest upon said mortgage due October 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 amounts are due on the mortgage: Principal Balance Interest from 09/01/2003 through 02/29/2004 at 7.1200% Per Diem interest rate at $15.58 Attorney's Fee at 5.0% of Principal Balance Late Charges from I % I /2003 to 02/29/2004 Monthly late charge amount at $26.99 Costs of suit and Title Search $79,883.08 $2,835.56 $3,994.15 $134.94 $900.00 $87,747.73 Monthly Escrow amount $130.07 $87,747.73 7. The Attorney's Fees set forth above are in conformity with the Mortgage documents and Pennsylvania law, and, will be collected in the event of a third party purchaser at Sheriff's Sale. If the Mortgage is reinstated prior to the Sale reasonable Attorney's Fees will be charged based on work actually performed. 8. 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 $87,747.73, together with il1terest at the rate of$15.58, 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: GOL ~Jt~vI~~ By: ~~~.~ GOLDBECK, JR., ESQUIRE ATTORNEY FOR PLAINTIFF VERIFICATION I, Michael D. Vestal, 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 lme 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: 1-(, -V '1 ~j) fhM Michael D. Vestal COUNTRYWIDE HOME LOANS INC. 'I L"1lal DescriptIon: ALL THAT CERTAIN TRACT OR PARCEL OF LAND AND PREMISES, SITUATE, LYING AND BEING IN THE BOROUGH OF WORMLEYSBURG IN THE COUNTY OF CUMBERLAND AND COMMONWEALTH OF PENNSYLVANIA, MORE PARTICULARLY DESCRIBED AS FOLLOWS: BEGINNING AT A POINT AT THE SOUTHEAST CORNER OF SECOND AND FERRY STREETS; THENCE IN A SOUTHERLY DIRECTION ALONG THE EASTERN LINE OF SECOND STREET THIRTY-ONE (31) FEET TO A POINT; THENCE IN AN EASTERLY DIRECTION ALONG A LINE PARALLEL WITH FERRY STREET EIGHTY-SIX (86) FEET, MORE OR LESS, TO A POINT; THENCE IN A NORTHERLY DIRECTION ALONG LANDS NOW OR LATE OF WILLIAM LIPPERT THIRTY-ONE (31) FEET TO A POINT ON THE SO\JTHERN LINE OF FERRY STREET; THENCE IN A WESTERLY (ERRONEOUSLY STATED ON PRIOR DEEDS AS EASTERLY) DIRECTION ALONG THE SOUTHERN LINE OF FERRY STREET EIGHTY-SIX (86) FEET, MORE OR LESS, TO A POINT, THE PLACE OF BEGINNING. HAVING THEREON ERECTED A SINGLE FRAME DWELLING HOUSE, KNOWN AS NO. 1 SOUTH SECOND STREET, WORMLEYSBURG, PENNSYLVANIA. BEING THE SAME PREMISES WmCH JEFFRIE A. CROSSLEY AND CRlSTEN A. CROSSLEY, HUSBAND AND WIFE, BY DEED DATED JUNE 19, 2002, GRANTED AND CONVEYED UNTO MEHO BEGANOVIC, MARRIED MAN, AND DZEV AD BEGANOVlC, SINGLE MAN, BORROWER. 1 7CJ P ""9. ft- ~ U'( ~ '- --- (J( 8 ~ -.() () p ....., >J (::,;:;I 0 - c::) ~- -'I ~ W ~ - ." '--1 ~ rq -r CD f{l :TI ,-- ..,...,p, ~ C> ~ ,] CJ ~~~ ?3~? (-j:d ;:.-.:-,-.: .(-:, .,"::::: ':"? (jl-'. ::2 '-" ~~~; JJ N -< SHERIFF'S RETURN - NOT FOUND CASE NO: 2004-00565 P COMMONTWEALTH OF PENNSYLVANIA COUNTY OF CUMBERLAND MORTGAGE ELECTRONIC REGISTRAT VS BEGANOVIC DZEVAD ET AL R. Thomas Kline ,Sheriff or Deputy Sheriff, who being duly sworn according to law, says, that he made a diligent search and inquiry for the within named DEFENDANT BEGANOVIC DZEVAD but was unable to locate Him in his bailiwick. He therefore returns the COMPLAINT - MORT FORE NOTI CE , NOT FOUND , as to the within named DEFENDANT , BEGANOVIC DZEVAD 1 SOUTH 2ND STREET WORMLEYSBURG, PA 17043 HOUSE IS VACANT AND PADLOCKED. Sheriff's Costs: Docketing Service Not found return Surcharge 18.00 11.04 5.00 10.00 .00 44.04 ? So answers.:_,,' .. .., .- . ,J .-0'_ ?::~::,.,,,,,,..,." >"",~"~.;::~,.,,, ,,:~';:",,--"~"~~-- u//~~-::.~ , .----~~~--~.-- . R. Thomas Kline Sheriff of Cumberland County ..? GOLDBECK MCCAFFERTY MCKEEVER 02/17/2004 Sworn and subscribed to before me this .:<3.A-Jt. day of :J~ :LfJDY A.D. (/), Q~ ~tary I ~ SHERIFF'S RETURN - NOT FOUND CASE NO: 2004-00565 P COMMONTWEALTH OF PENNSYLVANIA COUNTY OF CUMBERLAND MORTGAGE ELECTRONIC REGISTRAT VS BEGANOVIC DZEVAD ET AL R. Thomas Kline ,Sheriff or Deputy Sheriff, who being duly sworn according to law, says, that he made a diligent search and inquiry for the within named DEFENDANT BEGANOVIC MEHO but was unable to locate Her in his bailiwick. He therefore returns the COMPLAINT - MORT FORE NOTICE , NOT FOUND , as to the within named DEFENDANT , BEGANOVIC MEHO 1 SOUTH 2ND STREET WORMLEYSBURG, PA 17043 HOUSE IS VACANT AND PADLOCKED. Sheriff's Costs: Docketing Service Not found return Surcharge 6.00 .00 5.00 10.00 .00 21.00 -~.-"'" So answers.~,...""'. ... .,' ;;,;?;k/ -~-- '~''''<'''~~'-~ R. Thomas Kline Sheriff of Cumberland County .~..._,._-~~ GOLDBECK MCCAFFERTY MCKEEVER 02/17/2004 Sworn and subscribed to before me thi s J.. 3...c day of J~ J..o;'. 'i A. D . 1-) O-~~ p~tary GOLDBECK McCAFFERTY & McKEEVER By: JOSEPH A. GOLDBECK, JR. ATIORNEY LD. #16132 SUITE 5000 - MELLON INDEPENDENCE CENTER 701 MARKET STREET PHILADELPHIA, PA 19106-1532 (215) 627-1322 A TIORNEY FOR PLAINTIFF IN THE COURT OF COMMON PLEAS OF CUlllberland COUNTY CIVIL ACTION - LAW ACTION OF MORTGAGE FORECLOSURE MORTGAGE ELECTRONIC REGISTRATION SYSTEMS, INe. n 05 Corporate Drive PTX C-35 PIano, TX 75024-3632 Term No. 04-565 CIVIL TERM Plaintiff vs. DZEV AD BEGANOVIC MEHO BEGANOVIC 1 South Second Street Wormleysburg, PA 17043 Defendant(s) PRAECIPE TO REINSTATE COMPLAINT Kindly reinstate the Complaint in the above captioned matter. GOLDBECK, McCAFFERTY & McKEEVER ifJIt~- By Joseph A. Goldbeck, Jr., Esq. Attorney for Plaintiff 2 -;::, , -, ...0 = ?' o -n ~::~ --ri rJ1j= ~89 ~-;~6 --"-.'-1 ;:~:I:' ~,<C) (._~~rn ;,.;;.. ~:':1 . ::'\~ -.-,-. :'>J <.1' " r;-,> U1 -.J GOLDBECK McCAFFERTY & McKEEVER JOSEPH A. GOLDBECK, JR. Attorney I.D.#16132 Suite 5000 - Mellon Independence Center 701 Market Street Philadelphia, PA 19106-1532 215-627-1322 BY: Kristina G. Murtha, Esq. Attorney I.D.#61858 Attorney for Plaintiff MORTGAGE ELECTRONIC REGISTRATION SYSTEMS, INC. 7105 Corporate Drive PTX C-35 PIano, TX 75024-3632 IN THE COURT OF COMMON PLEAS OF Cumberland COUNTY V8. DZEVAD BEGANOVIC and MEHO BEGANOVIC 1 South Second Street Wormleysburg, PA 17043 No. 04-565 CIVIL TERM 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, MOTION FOR SUBSTITUTED SEE~ICE UNDER PA.R.C,P. 430(a) Plaintiff, by and through its attorney, Kristina G. Murtha, Esq., in support of its Motion for Substituted Service, represents as follows: 1. Plaintiff is the holder of a first mortgage upon the premises 1 South Second Street, Wormleysburg, PA, 17043, hereinafter, the "mortgaged premises". 2. Defendants, DZEVAD BEGANOVIC and MEHO BEGANOVIC, is/are the mortgagor and real owner of the mortgaged premises. 3. The last known address of Defendants is 108 Memorial Acres, Sunbury, PA 17801. 4. The Sheriff has been unable to effect service of the Complaint upon Defendants at their last known address after the attempt because the Defendants have moved as of March 24, 2004. 5. The following investigation was conducted in a good faith attempt to ascertain the whereabouts of Defendants. WHEREFORE, Plaintiff prays that the: Court enter the attached order allowing Plaintiff to serve the Complaint upon Defendants by posting the premises and certified and regular mail to the Defendants' last known address. /l BY: Kristina G. urtha, Esq. f ERSAL SERVICES -.- Affidavit of Good Faith Ilnvestiaation Client provided Information: File Number: CWD-3289 Attorney Firm: Goldbeck, McCafferty & McKeever File Name: Beganovic SUbject Name: Meho Beganovic Property Address: Street: 1 South 2nd Street City: Wormleysburg State: PA Phone: Zip: 17043 Skip ResuRs: Date of Birth: None Found Last Known Street: 108 Memorial Acres City: Sunbury State: PA Zip: 17801 Death Records: As of 03/02/2004, the Social Security Administration has no death record on file for Meho Beganovic Social Security Number search completed. Employment Search: Unable to verify current employer. CredRor Information: Creditors indicated the last reported address for Meho Beganovic as 108 Memorial Acres, Sunbury, PA 17801 Departmenf of Motor Vehicle Records: The Pennsylvania Department of Motor Vehicles provided no change for Meho Beganovic from 108 Memorial Acres, Sunbury, PA 17801 Public Licenses (Pilot, Real Estate, etc): Search performed provided no information. Voter Registration Information: The County Voters Registration Office has no listing for Meho Beganovic. National Postal Address Search: Has no change for Meho Beganovic from 108 Memorial Acres, Sunbury, PA 17801 Comments: 570-988-7849: listed to subject, changed to 570-473-1222. 570-473-1222: Wrong number. 570-286-6152: Called possible neighbor, Janelle Leitzel. answering machine answered, no message left. 570-286-6529: Called possible neighbor, Jodi Lahr, there was no answer. Dates: As of 0 3/02/2004 Phone: On 03/02/2004, I. Patti Garrett being duly sworn according to the law, deposes and says: ed by Un' ersal Default Service. I have conducted an investigation into the whereabouts of the aboy. name 'ect. Above are the results of my investigaliion. ;zr;;:::;rt?J~t Notary Public Date: 03/02/2004 I.~~ ~dP -W,Af,lW DONNA G. WORKMAN N018ry Ftublic, State of Texas My Commission Expires Septembtr 30, 2007 329 OAKS TRAIL PlAZA . SUITE 202. GARI..AN), TEXAS 75043 OFFICE: (972) 226~8883 . FAX: (972) 226-8887 ERSAL SERVICES -.- Affidavit of Good Faithlnvestiaation Client provided Information: File Number: CWD-3289 Attorney Firm: Goldbeck, McCafferty & McKeever File Name: 6eganovic Subject Name: Dzevad Beganovic Property Address: Street: 1 South 2nd Street City: Worrnleysburg State: PA Phone: Zip: 17043 Skip Results: Last Known Street: 108 Memorial Acres City: Sunbury State: PA Date of Birth: None Found Dates: As of 03/0212004 Phone: Zip: 17801 Death Records: As of 03/02/2004, the Social Security Administration has no death record on file for Dzevad Beganovic Social Security Number search completed. Employment Search: Unable to verify current employer. Creditor Information: Creditors indicated the last reported address tor Dzevad Beganovic as 108 Memorial Acres, Sunbury, PA 17801 Department of Motor Vehicle Records: The Pennsylvania Department of Motor Vehicles provided no change for Dzevad Beganovic from 108 Memorial Acres, Sunbury, PA 17801 Public Licenses (Pilot, Real Estate, etc): Search performed provided no information. Voter Registration Information: The County Voters Registration Office has no listing for Dzevad Be~lanovic. National Postal Address Search: Has no change for Dz,~vad Beganovic from 108 Memorial Acres, Sunbury, PA 17601 Comments: 570-988-7849: Listed to subject, changed to 570-473-1222. 570-473-1222: Wrong number. 570-286-6152: Called possible neighbor, Janelle leitzel, answering machine answered, no message left. 570-286-6529: Called possible neighbor, Jodi lahr, there was no answer. On 03/02/2004, I, Patti Garrett being duly sworn according to the low, deposes and says: I am employed by Universal Default Service, I have conducted an investigation into the whereabouts o the a e name bject. Above are the results ot my investigation. ~~t No ary Public --... Date: 03/02/2004 ~~,~~I~:-". .~~!..,.!,:!. i:" '~i I\.}' .:~! ~';;i'W fill'UII" DONNA G. WORKMAN Notary Public, State of Texas My Commission Expires September 30. 2007 329 OAKS 11WL. PlAZA . SUITE 202 . GAA.I..AN>, TEXAS 75043 OFFICE: (972) 226~8883. FAX: (972) 226-8887 APR-16-200408:14 FROM:NORTHUMBERLAND SHERR 5709884496 TD:10812158256444 P: 1 PLAINTIFF: MORTGAGE ELECTRONICS REGISTRATION.., P: CASE #: 04 Cv 0565 CTY FILED: CUMBERLAND FILE DATE: 04/03/15 DATE RECEIVED: 04/03/18 ASSIGNED TO: ~ DEF LAW FIRM; GOLDBECK EXPIRES: 04/04/14 VS: DEFENDANT: BEGANOVIl;:, .--IJZEVAD.... D: ,MERO BEGANQVJ;:C: 0: ':L08 MEMORIAL ACRES D, SUNBVRY, PA. 17801 D: SHERIFF'S'RETUl<N . .___:_.___, I HEREBY CERTIFY AND RE1'T.1RN I SERVED:~.E:,'WI!E.~lrl.:!Q"~:~L_.,.' BY HANDING A TRUE AND ATTESTED COPY OF THE WITHIN: REINSTATED NOTICE AND .ID [;Q<.vi'<..E CONPEAINT /MORTGAGE FORECLOSURE PERSON SERVED: N, I I ,l 0 .. .!JjbVtA I'H PL( p,{), I S. ;:)tJ..I Sf' IJoll!1 e\ S.DUe.g- fA 11/'\ 43 DATE SERVED: ,4r 6r: 3-.:2.~I-.oW CAPACITY:.) 'T \ TIME: PLACE SERVED; COUNTY OF NORTHUMBERLAND AND STATE OF PENNA" MA.KING KNOWN UNTO : THE CONTENTS THEREOF. SO ANSwERS: ~LES S. BER~OSKI, SHERIFF :~:DEPUTY: JUfO'sky jfrJniT ~S.&J._~ , -. I HEREBY CERTIFY AND RETURN THAT r SERVED: -1'1"'...v IlE'3'ANO';IC .r. _ ~,. - _ BY HANDING A TRUE AND ATTESTED -. (~EE ~botl:) CAPACITY : COPY OF THE WITHIN: REINSTATED NOTICE AND COMPLAINT/ MORTGAGE FORECLOSURE No s'tRV'(Cf PERSON SERVED. ./ I illolle.o DATE SERVED: TIME: PLACE SERVED: COUNTy OF NORTHUMBERLAND AND STATE OF PENNA., MAKU.O KNOWN UNTO : CONTENTS THEREOF. THE rn oveJ tv / S Jr..1 Sr WorM Ity $ b..O f.. nO<fJ ~. r-e..r POfT"""D~'cc: SO ANSWERS: CHARLES S. SERKOSKI, SHERIFF BY DEPUTY:-P., 1'- I.~ fY/!t7 I BY: d-vfo ,~I'- ) . t"IJ. ""$' .~ . ~ .~. '.It} SHERIFF'S COSTS: REC #: 23146 NO. OF ATTEMPTS: DOCKET PAGE #. 04 CV 0164 ,56,1~ UJ..LLl.l.\..L.\.".\.' u L\.J:'..r.L U.f'\..l.\I - .1.\1 V 1. .t'VU1\lLJ QASE NO, 2004-00565 P COMMONTWEALTH OF PENNSYLVANIA COUNTY OF CUMBERLAND MORTGAGE ELECTRONIC REGISTRAT VS BEGANOVIC DZEVAD ET AL R. Thomas Kline ,Sheriff or Deputy Sheriff, who being duly sworn according to law, says, that he made a diligent search and inquiry for the within named DEFENDANT BEGANOVIC DZEVAD but was unable to locate Him in his bailiwick. He therefore returns the COMPLAINT - MORT FORE NOTICE , NOT FOUND , as to the within named DEFENDANT , BEGANOVIC DZEVAD 1 SOUTH 2ND STREET HOUSE IS VACANT AND PADLOCKED. WORMLEYSBURG, PA 17043 Sheriff's Costs: Docketing Service Not found return Surcharge 18.00 11.04 5.00 10.00 .00 44.04 So answers: ..' ..<~',". . ...'''-:::)" .. .- .o-.- ~"""<," :,~;;;'~~~i;.~~ R. Thomas Kline Sheriff of Cumberland County " ..-/ "'~--~ ---- GOLDBECK MCCAFFERTY MCKEEVER 02/17/2004 Sworn and subscribed to before me this day of A.D. Prothonotary U.l.J..l.:Jl\..L l' l.' u !\..cs.L UIU\J - l\JV 1 .t'VU1\Jl) CJ;..SE NO: 20"04-00565 P COMMONTWEALTH OF PENNSYLVANIA COUNTY OF CUMBERLAND MORTGAGE ELECTRONIC REGISTRAT VS BEGANOVIC DZEVAD ET AL R. Thomas Kline ,Sheriff or Deputy Sheriff, who being duly sworn according to law, says, that he made a diligent search and inquiry for the within named DEFENDANT BEGANOVIC MEHO unable to locate Her in his bailiwick. He therefore returns the but was COMPLAINT - MORT FORE NOTICE , NOT FOUND , as to the within named DEFENDANT , BEGANOVIC MEHO 1 SOUTH 2ND STREET WORMLEYSBURG, PA 17043 HOUSE IS VACANT AND PADLOCKED. Sheriff's Costs: Docketing Service Not found return Surcharge 6.00 .00 5.00 10.00 .00 21.00 ---.... So answerfl:_-" ........... ..' ,,->:.-"-~)___--,,-- _.----- _..~-::i:~".,-c... - ,",,- ..~....~~._- .,~::-~"-,-","'" ~~>---~ ..' , R. Thomas. Kline Sheriff of Cumberland County .--?> --" GOLDBECK MCCAFFERTY MCKEEVER 02/17/2004 Sworn and subscribed to before me this day of A.D. Prothonotary GOLDBECK McCAFFERTY & McKEEVER JOSEPH A. GOLDBECK, JR. Attorney I.D.#16132 Suite 5000 - Mellon Independence Center 701 Market Street Philadelphia, PA 19106-1532 215-627-1322 BY: Kristina G. Murtha, Esq. Attorney I.D.#61858 Attorney for Plaintiff MORTGAGE ELECTRONIC REGISTRATION SYSTEMS, INC. 7105 Corporate Drive PTX C-35 PIano, TX 75024-3632 IN THE COURT OF COMMON PLEAS OF Cumberland COUNTY VS. DZEVAD BEGANOVIC and MEHO BEGANOVIC 1 South Second Street Wormleysburg, PA 17043 No. 04-565 CIVIL TERM VERIFICATION I, Kristina G. Murtha, Esq., Attorney for Petitioner do hereby verify that the facts set forth in the foregoing Motion for Substituted Service are true and correct to the best of my knowledge, information and belief. I understand that false statements therein are made subject to the penalties of 18 Pa. C.S. 4904 relating to unsworn falsification to authorities. BY: '1 , urtha, Esq. GOLDBECK McCAFFERTY & McKEEVER JOSEPH A. GOLDBECK, JR. Attorney I.D.#16132 Suite 5000 - Mellon Independence Center 701 Market Street Philadelphia, PA 19106-1532 215-627-1322 BY: Kristina G. Murtha, Esq. Attorney I.D.#61858 Attorney for Plaintiff MORTGAGE ELECTRONIC REGISTRATION SYSTEMS, INC. 7105 Corporate Drive PTX C-35 PIano, TX 75024-3632" IN THE COURT OF COMMON PLEAS OF Cumberland COUNTY vs. DZEVAD BEGANOVIC and MEHO BEGANOVIC 1 South Second Street Wormleysburg, PA 17043 No. 04-565 CIVIL TERM MEMORANDUM OF LAW IN SUPPORT elF MOTION FOR SUBSTITUTED SERVICE UNDER Pa.R.C.p. 430(a) Plaintiff has filed a Complaint in 110rtgage Foreclosure against Defendants, which the Sheriff has been unable to personally serve upon Defendants. As noted in the attached Motion, Plaintiff has made a good faith attempt to ascertain Defendants' whereabouts without success. Accordingly, the Court may approve alternative means of service. See Pa.R.C.p. 430(a). CONCLUSION For reasons stated above and in the attached Motion, the Court should enter an order, allowing Plaintiff to serve the Complaint in Mortgage Foreclosure upon Defendants by posting the premises and certified mail and regular mail to the Defenda.nts' last known address. RespectfullY!~Ubmitted, GOLDBECK McCAFFERTY & McKEEVER JOSEPH A. GOLDBECK, JR. Attorney I.D.#16132 Suite 5000 - Mellon Independence Center 701 Market Street Philadelphia, PA 19106-1532 215-627-1322 BY: Kristina G. Murtha, Esq. Attorney I.D.#61858 Attorney for Plaintiff MORTGAGE ELECTRONIC REGISTRATION SYSTEMS, INC. 7105 Corporate Drive PTX C-35 PIano, TX 75024-3632 IN THE COURT OF COMMON PLEAS of Cumberland County vs. DZEVAD BEGANOVIC MEHO BEGANOVIC 1 South Second Street Wormleysburg, PA 17043 No. 04-565 CIVIL TERM CERTIFICATE OF SERVICE Kristina G. Murtha, Esq., does hereby certify that true and correct copies of the foregoing Motion for Substituted Service have been served upon the Defendants this 21" day oj' April, 2004, by first class mail, postage prepaid. BY: ~) rtha, Esq. ~-, C:-;J . .-- ~.:I >.1 .l.' i".J C) Tl --I -r [11 ::.1 ,- ;11 ~ 'i'~ C) \', u~ J , r....' MORTGAGE ELECTRONIC REGISTRATION SYSTEMS, INC., Plaintiff v. DZEV AD BEGANOVIC and MEHO BEGANOVIC, Defendants IN THE COURT OF COMMON PLEAS OF CUMBERLAND COUNTY, PENNSYL VANIA CIVIL ACTION -LAW NO. 04-0565 CIVIL TERM ORDER OF COURT AND NOW, this 28th day of April, 2004, upon consideration of Plaintiff's Motion for Substituted Service under Pa. R.C.P. 430(a), it is ordered and directed that Plaintiff may serve the Complaint in Civil Action upon Defendants Dzevad Beganovic and Meho Beganovic by (1) mailing a true and correct copy of the complaint by certified mail and regular mail, to Defendants' last known address at 108 Memorial Acres, Sunbury, PA 17801, (2) publication once in the Cumberland Law Journal and in a newspaper of general circulation in Cumberland County, Pennsylvania, and (3) posting the premises at I South Second Street, W ormleysburg, P A 17043. Joseph A. Goldbeck, Jr., Esq. Suite 500 Mellon Independence Center 701 Market Street Philadelphia, PA 19106-1532 Attorney for Plaintiff BY THE COURT, J. )> Oy~O'l ViN'vi\lASNi'~?d "N('(V) 1'1' '\rl! "':''"'''''n''' ^-l.. k), \.d.~' V_I,:Jcn V as : I HIV 6, tldV ~OOZ AtNLONOH1OOd 3HJ. .::10 3JI:l:!o-a3ll:l GOLDBECK McCAFFERTY & McKEEVER By: JOSEPH A. GOLDBECK, JR. AITORNEY LD. #16132 SUITE 5000 - MELLON INDEPENDENCE CENTER 701 MARKET STREET PHILADELPHIA, PA 19106-1532 (215) 627-1322 A ITORNEY FOR PLAINTIFF MORTGAGEELECTRO~C REGISTRATION SYSTEMS, INe. 7105 Corporate Drive PTX C-35 PIano, TX 75024-3632 IN THE COURT OF COMMON PLEAS OF Cumberland COUNTY CNIL ACTION - LAW Plaintiff ACTION OF MORTGAGE FORECLOSURE vs. DZEV AD BEGANOVIC MEHO BEGANOVIC I South Second Street Wormleysburg,PA 17043 Term No. 04-565 CNIL TERM Defendant( s) PRAECIPE TO REINSTATE COMPLAINT Kindly reinstate the Complaint in the above captioned matter. GOLDBECK, McCAFFERTY & McKEEVER 3't~- By Joseph A. Goldbeck, Jr., Esq. Attorney for Plaintiff o c 2~ ~~~. ~l~ ~, ..."r'.-, ..c::......-.' -ul; PC! ~ ...., = = .c- :x :> -< I en o ." .-f :r:~ nl~ r- :89 ~9 Q:d z:o om j;! :n -< ;,,- ::r. '9 '" Ul /' SHERIFF'S RETURN - REGULAR CASE NO: 2004-00565 P COMMONWEALTH OF PENNSYLVANIA: COUNTY OF CUMBERLAND MORTGAGE ELECTRONIC REGISTRAT VS BEGANOVIC DZEVAD ET AL CPL. TIMOTHY REITZ , Sheriff or Deputy Sheriff of Cumberland County, Pennsylvania, who being duly sworn according to law, was served upon says, the within COMPLAINT - MORT FORE BEGANOVIC DZEVAD the at 2046:00 HOURS, on the 5th day of May , 2004 DEFENDANT at 1 SOUTH 2ND STREET WORMLEYSBURG, PA 17043 POSTED PROPERTY AT ONE SOUTH by handing to 2ND STREET WORMLEYSBURG 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 Posting Surcharge 18.00 10.35 6.00 10.00 .00 44.35 Sworn and Subscribed to before me this /1!!::' clay of ~. ~'f A.D. r\. #I.,{J /nJP}J<", "# '- ~t:othonotary J , So Answers: r~~ R. Thomas Kline ' 05/06/2004 GOLDBECK MCCAFFERTY MCKEEVER .--::-. --;:f 1 By: I~.-/ r juty S rif SHERIFF'S RETURN - REGULAR CASE NO: 2004-00565 P COMMONWEALTH OF PENNSYLVANIA: COUNTY OF CUMBERLAND MORTGAGE ELECTRONIC REGISTRAT VS BEGANOVIC DZEVAD ET AL CPL. TIMOTHY REITZ Sheriff or Deputy Sheriff of Cumberland County,Pennsylvania, who being duly sworn according to law, says, the within COMPLAINT - MORT FORE was served upon BEGANOVIC MEHO the DEFENDANT , at 2046:00 HOURS, on the 5th day of May , 2004 at 1 SOUTH 2ND STREET WORMLEYSBURG, PA 17043 by handing to POSTED PROPERTY AT ONE SOUTH 2ND STREET WORMLEYSBURG, PA a true and attested copy of COMPLAINT - MORT FORE together with and at the same t.ime directing Her attention to the contents thereof. Sheriff's Costs: Docketing Service Posting Surcharge So Answers: 6.00 .00 6.00 10.00 .00 22.00 r~<~f,-:f:f~ R. Thomas Kline 05(06(2004 GOLDBECK MCCAFFERTY MCKEEVER ~''f . ~ f). )h., ;"..) rott'onotary A.D. By: ~~-t;:: ./ De1y"'heri~ Sworn and Subscribed to before 0:- rne this 11 ~ day of SHERIFF'S RETURN - OUT OF COUNTY CASE NO: 2004-00565 P COMMONWEALTH OF PENNSYLVANIA: COUNTY OF CUMBERLlillD MORTGAGE ELECTRONIC REGISTRAT VS BEGANOVIC DZEVAD ET AL R. Thomas Kline , Sheriff or Deputy Sheriff who being duly sworn according to law, says, that he made a diligent search and and inquiry for the within named DEFENDANT , to wit: BEGANOVIC DZEVAD but was unable to locate Him in his bailiwick. He therefore deputized the sheriff of NORTHUMBERLAND County, Pennsylvania, to serve the within COMPLAINT - MORT FORE On May 14th , 2004 , this office was in receipt of the attached return from NORTHUMBERLAND Sheriff's Costs: Docketing Out of County Surcharge Dep Northumberland So answe 18.00 9.00 10.00 58.14 .00 95.14 05/14/2004 GOLDBECK MCCAFFERTY R. Thomas-Kline Sheriff of Cumberland County MCKEEVER Sworn and subscribed to before me this 17~ day of ~ (1 A.D. ..Q,~~~. prothonotdrf / SHERIFF'S RETURN - OUT OF COUNTY CASE NO: 2004-00565 P COMMONWEALTH OF PENNSYLVANIA: COUNTY OF CUMBERLAND MORTGAGE ELECTRONIC REGISTRAT VS BEGANOVIC DZEVAD ET AL R. Thomas Kline , Sheriff or Deputy Sheriff who being duly sworn according to law, says, that he made a diligent search and and inquiry for the within named DEFENDANT , to wit: BEGANOVIC MEHO but was unable to locate Her in his bailiwick. He therefore deputized the sheriff of NORTHUMBERLAND serve the within COMPLAINT - MORT FORE County, Pennsylvania, to On May 14th , 2004 , this office was in receipt of the attached return from NORTHUMBERLAND Sheriff's Costs: Docketing Out of County Surcharge 6.00 .00 10,00 .00 .00 16.00 05/14/2004 GOLDBECK MCCAFFERTY ~.-;:?' So answe ..-~ ~ - -:: R. Thomas Kline Sheriff of Cumberland County MCKEEVER Sworn and subscribed to before me this /7/(; d f 7z _ - ay 0 ~ 141 ;)..(}D 'f A. D . ( k. 0. lM.,i(,~. A~ '--r-r'P-;othonotary ) -r-' In The Court of Common Pleas of Cumberland County, Pennsylvania Mortgage Electronic Registration Systems Inc VS. Dzevad PGganovic et al SERVE: same Now March 16, 2004 , No. 04-565 civil , I, SHERIFF OF CUMBERLAND COUNTY, P A, do hereby deputize the Sheriff of Northumberland County to execute this Writ, this deputation being made at the request and risk ofthe Plaintiff. // ~.- '" ~( r'J.."'ZL.... .'';- " -9:" . A .,....~... ~~ A "....~::,.:..~-r ~l .. Sheriff of Cum berland County, P A Now, within upon at by handing to a and made known to Sworn and subscribed before methis_dayof ,20_ Affidavit of Service ,20 , at o'clock M. served the copy of the original the contents thereof. So answers, Sheriff of County, PA COSTS SERVICE MILEAGE AFFIDA VIT $ $ In The Court of Common Pleas of Cumberland County, Pennsylvania Mortgage Electronic Registration Systems Inc VS. Dzevad Eeganovic et al Meho Beganovic / ,.'. '~,": ", 'J' "No. , "C'! 04-565 civil SERVE: Now March 16, 2004 , "<-:'.')!{i , I, SHERIFF OF CtJMBERLAND COUNTY, P A, do hereby deputize the Sheriff of Northumberland County to execute this Writ, this deputation being made at the request and risk of the Plaintiff. ~~~~~ Sheriff of Cum berland County, P A Affidavit of Service Now, ,20_, at o'clock M. served the within upon at by handing to a copy of the original and made known to the contents thereof. So answers, Sheriff of County, PA Sworn and subscribed before me this _ day of ,20_ COSTS SERVICE MILEAGE AFFIDAVIT $ $ '~ PLAINTIFF: MORTGAGE ELECTRONICS REGISTRATION... P: CASE #: 04 CV 0565 CTY FILED: CUMBERLAND FILE DATE: 04/03/15 DATE RECEIVED: 04/03/18 ASSIGNED TO: 2 DEF LAW FIRM: GOLDBECK EXPIRES: 04/04/14 VS: DEFENDANT: BEGANOVIC, DZEVAD D: MEHO BEGANOVIC D: 108 MEMORIAL ACRES D: SUNBURY, PA. 17801 D: SHERIFF'S RETURN I HEREBY CERTIFY AND RETURN I SERVED: DZEVAD BEGANOVIC BY HANDING A TRUE AND ATTESTED COPY OF THE WITHIN: REINSTATED NOTICE AND CONPLAINT /MORTGAGE FORECLOSURE PERSON SERVED: NO SERVICE MOVED AS PER PO BOX 1 S 2ND ST WORMLEYSBURG PA 17043 DATE SERVED: AS OF 03-24-04 CAPACITY: TIME: PLACE SERVED: COUNTY OF NORTHUMBERLAND AND STATE OF PENNA" MAKING KNOWN UNTO : THE CONTENTS THEREOF. SO ANSWERS: CHARLES S. BERKOSKI, SHERIFF BY DEPUTY: LUPOTSKY, MATT BY: I HEREBY CERTIFY AND RETURN THAT I SERVED: MEHO BEGANOVIC BY HANDING A TRUE AND ATTESTED COPY OF THE WITHIN: REINSTATED NOTICE AND COMPLAINT/ MORTGAGE FORECLOSURE PERSON SERVED: MOVED (SEE ABOVE) NO SERVICE DATE SERVED: CAPACITY : TIME: PLACE SERVED: COUNTY OF NORTHUMBERLAND AND STATE OF PENNA., MAKING KNOWN UNTO : CONTENTS THEREOF. THE SO ANSWERS: CHARLES S. BERKOSKI, SHERIFF BY DEPUTY: LUPOTSKY, MATT BY: I~S.~' SHERIFF'S COSTS: $ 58.14 REC #: 23146 NO. OF ATTEMPTS: 2 ~~, "il i ,J ",111.1 "Ju,,-';iiOed before me this I rHlday ofml4{ A.D. 200~ ~~:~.... PROTHONOTARY My Comm. Exp. 1 st Mon. Jan. 2006 DOCKET PAGE #: 04 cv 0164 GOLDBECK McCAFFERTY & McKEEVER BY: Joseph A. Goldbeck, Jf. Attorney LD.#16132 Suite 500 - The Bourse Bldg. III S. l11dependence Mall East Philadelphia, PA 19106 215-627 -1322 Attorney for Plaintiff MORTGAGE ELECTRONIC REGISTRATION SYSTEMS, INe. 7105 Corporate Drive PTX C.35 PIano, TX 75024-3632 IN THE COURT OF COMMON PLEAS of Cumberland County Plaintiff vs, CIVIL ACTION LAW DZEV AD BEGANOVIC MEHO BEGANOVIC (Mortgagor(s) and Record owner(s)) 1 South Second Street Wormleysburg, PA 17043 ACTION OF MORTGAGE FORECLOSURE No, 04-565 CIVIL TERM Defendant( s) ORDER FOR JUDGMENT Please enter Judgment in favor of MORTGAGE ELECTRONIC REGISTRATION SYSTEMS, INC., and against DZEV AD BEGANOVIC and MEHO BEGANOVIC 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 C'm,l.i,', i, "" - ,f$90,4M.95 C'@ '. Joseph A. Goldbecl Attorney for Plai lti I hereby certifY that the above names are correct and that the precis side ce address of the judgment creditor is MORTGAGE ELECTRONIC REGISTRATION SYSTEMS, IN . 7105 orporate Drive PTX C-35 Piano, TX 75024-3632 and that the name(s) and last known addressees) of the Defendant(s) is/are DZEV AD BEGANOVIC, 108 Memorial Acres Sunbury, PA 17801 and MEHO BEGANOVIC, 108 Memorial Acres Sunbury, PAl 780 1; GOLDBEC ERTY & McKEEVER BY: Joseph A. ' e k, Jr. Attorney for Pla\ if~ ASSESSMENT OF DAMAGES TO THE PROTHONOTARY: Kindly assess the damages in this case to he as follows: Principal Balance $79,883.08 Interest from 09/01/2003 through 07/02/2004 $4,767.48 Attorney's Pee at 5,0000% of principal balance $3,994.15 Late Charges $269.89 Costs of Suit and Title Search $900,00 Escrow Balance Deficit $650.35 ($0.00) $90,464.95 GOLDBECK McC BY: Joseph A. Gol~ ~ Attorney for Plaintift & McKEEVER v AND NOW, this $/41-.. day ofJu.li ,2004 damages are assessed as above. ,f,~J~ 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-Mili tary 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, DZEVAD BEGANOVIC, is about unknown years of age, that Defendant' s last known residence is 108 Memorial Acres, Sunbury, PA 17801, 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 wi thin the provisions of the Soldiers' and Sailors' Civil Relief Action of Congress of 1940 and its Amendments. Date: 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-Mili tary 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, MEHO BEGANOVIC, is about unknown years of age, that Defendant's last known residence is 108 Memo.rial Acres, Sunbury, PA 17801, 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 wi thin the provisions of the Soldiers' and Sailors' Civil Relief Action of Congress of 1940 and its Amendments. Date: '~ In the Court of Common Pleas of Cumberland County MORTGAGE ELECTRONIC REGISTRATION SYSTEMS, INC. 7l 05 Corporate Drive PTX C-35 Piano, TX 75024-3632 Plaintiff vs. DZEV AD BEGANOVIC MEHO BEGANOVIC (Mortgagor(s) and Record Owner(s)) I South Second Street Wormleysburg, PA 17043 No. 04-565 CIVIL TERM Defendant( s) 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 iu favor of Plaintiff and against DZEV AD BEGANOVIC and MEHO BEGANOVIC by default for want of an Answer. Assess damages as follows: $90,464.95 Debt Interest - 09/01/2003 to 07/02/2004 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 occurre~at e. t ten days prio..r to the date of the filing of this praecipe. A copy of the notice is attached. R.C.P. 237.1 ! ' . Joseph A. k, Jr. Attorney 11: > a iff W, #161~ \ . ANDNOW ~ul" P' , J..OO<{ ,Ju mentis entered in favor of MORTGAGE ELECTRONIC REdrST~TION SYSTEMS, INe. and agaiust DZEV AD BEGANOVIC and MEHO BEGANOVIC by default for want of an Answer and damages assessed in the sum of $90,464,95 as,per thjry. ove certification, n ~ Pro~'~ ~/ 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: June 14,2004 TO: MEHO BEGANOVIC 108 Memorial Acres Sunbury, PA 17801-1404 MORTGAGE ELECTRONIC REGISTRATION SYSTEMS, INC. 7105 Corporate Drive PTX C-35 PIano, TX 75024-3632 In the Court of Common Pleas of Cumberland County CIVIL ACTION - LAW Plaintiff Action of Mortgage Foreclosure vs. DZEV AD BEGANOVIC MEHO BEGANOVIC (Mortgagor(s) and Record Owner(s)) I South Second Street Wormleysburg, PA 17043 Term No, 04-565 CIVIL TERM Defendant(s) TO: MEHO BEGANOVIC 108 Memorial Acres Sunbury, PA 17801-1404 IMPORT ANT NOTTCF. YOU ARE IN DEFAULT BECAUSE YOU HAVE FAILED TO ENTER A WRITIEN APPEARANCE PERSONALLY OR BY ATIORNEY 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 TIlE DATE OF TIllS NOTICE, A JUDGMENT MAY BE ENTERED AGAINST YOU WITIlOUT A HEARING AND YOU MAY LOSE YOUR PROPERTY OR OTIlER IMPORTANT RIGHTS. YOU SHOULD TAKE TIllS PAPER TO YOUR LAWYER AT ONCE. IF YOU DO NOT HAVE A LAWYER, GO TO OR TELEPHONE THE OFFICE SET FORTII 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. LEGAL SERVICES INC 8 Irvine Row Carlisle, P A 17013 717-243-9400 CUMBERlAND COUNTY BAR ASSOCIATION 2 Liberty Avenue Carlisle, P A 17013 GOLDBECK McCAFFERTY & McKEEVER BY: Joseph A Goldbeck, Jr., Esq. Attorney for Plaintiff Suite 5000 - Mellon Independence Center. 70 I 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: June 14, 2004 TO: DZEV AD BEGANOVIC 108 Memorial Acres Sunbury, PA 17801-1404 MORTGAGE ELECTRONIC REGISTRATION SYSTEMS, INC. 7105 Corporate Drive PTX C-35 Piano, TX 75024-3632 In the Court of Common Pleas of Cumberland County CIVIL ACTION - LAW Plaintiff Action of Mortgage Foreclosure vs. DZEV AD BEGANOVIC MEHO BEGANOVIC (Mortgagor(s) and Record Owner(s)) I South Second Street Worrnleysburg, PA 17043 Term No. 04-565 CIVIL TERM Defendant{s} TO: DZEV AD BEGANOVIC 108 Memorial Acres Sunbury, PA 17801-14043 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 TIlE CLAIMS SET FORTIl 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 OTIlER 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 FORTIl BELOW. THIS OFFICE CAN PROVIDE YOU WITH INFORMATION ABOUT HIRING A LAWYER. IF YOU CANNOT AFFORD TO HIRE A LAWYER, TIllS OFFICE MAY BE ABLE TO PROVIDE YOU WITIl INFORMATION ABOUT AGENCIES TIlAT MAY OFFER LEGAL SERVICES TO ELIGIBLE PERSONS AT A REDUCED FEE OR NO FEE. LEGAL SERVICES lNC 8 Irvine Row Carlisle, PA 17013 717-243-9400 CUMBERLAND COUNTY BAR ASSOCIATION 2 Liberty Avenue Carlisle, P A 17013 GOLDBECK McCAFFERTY & McKEEVER BY: Joseph A. Goldbeck, Jr., Esq. Attorney for Plaintiff Suite 5000 - Mellon Independence Center. 70 I 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: June 14,2004 TO: MEHO BEGANOVIC 1 South 2nd Street Wormleysburg, PA 17043-1303 MORTGAGE ELECTRONIC REGISTRATION SYSTEMS, INC. 7105 Corporate Drive PTX C-35 PIano, TX 75024-3632 In the Court of Common Pleas of Cumberland County CIVIL ACTION. LAW Plaintiff Action of Mortgage Foreclosure vs. DZEV AD BEGANOVIC MEHO BEGANOVIC (Mortgagor(s) and Record Owner(s)) 1 South Second Street Wormleysburg, P A 17043 Term No. 04-565 CIVIL TERM D~fendant(s) TO: MEHO BEGANOVIC 1 South 2nd Street Wonnleysburg, PA 17043-1303 IMPORTANT NOTWR 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 ELIGffiLE PERSONS AT A REDUCED FEE OR NO FEE. LEGAL SERVICES INC 8 Irvine Row Carlisle, PA 17013 717-243-9400 CUMBERLAND COUNTY BAR ASSOCIA nON 2 Liberty Avenue Carlisle, P A 17013 GOLDBECK McCAFFERTY & McKEEVER BY: Joseph A. Goldbeck, Jr., Esq. Attorney for Plaintiff Suite 5000 ~ Mellon Independence Center. 70 I 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: June 14, 2004 TO: DZEV AD BEGANOVIC I South 2nd Street Wormleysburg, PA 17043.1303 MORTGAGE ELECTRONIC REGISTRATION SYSTEMS, INC. 7105 Corporate Drive PTX C.35 Piano, TX 75024-3632 In the Court of Common Pleas of Cumberland County CIVIL ACTION - LAW Plaintiff Action of Mortgage Foreclosure vs, DZEV AD BEGANOVIC MEHO BEGANOVIC (Mortgagor(s) and Record Owner(s)) I South Second Street Wonnleysburg, PA 17043 Term No. 04-565 CIVIL TERM Defendant(s) TO: DZEV AD BEGANOVIC 1 South 2nd Street Wormleysburg, PA 17043-1303 IMPORT A NT NOTJc.R YOU ARE IN DEFAULT BECAUSE YOU HAVE FAILED TO ENTER A WRlTIEN APPEARANCE PERSONALLY OR BY ATIORNEY AND FILE IN WRITING WIlli THE COURT YOUR DEFENSES OR OBJECTIONS TO THE CLAIMS SET FORlli 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 ELIGffiLE PERSONS AT A REDUCED FEE OR NO FEE. LEGAL SERVICES INC 8 hvine Row Carlisle, PA 17013 717-243-9400 CUMBERLAND COUNTY BAR ASSOCIA nON 2 Liberty Avenue Carlisle, PA 17013 GOLDBECK McCAFFERTY & McKEEVER BY: Joseph A. Goldbeck, Jr., Esq. Attorney for Plaintiff Suite 5000 ~ Mellon Independence Center. 70 I Market Street Philadelphia, PA 19106 215-627-1322 t "J:,J ~ ~ tt- ifL ..() . () ~ ...... l; 0 ~ () ~ t.....) ~ <;.::..:> 0 ..0 (JJ .'C',',:> ~-- -n ...0 W c_ --j Qr - r-- (:: -r" ~ r;~,]] ~ 0- 1 I ." W Cl , (:1 -,-, ;r~; .. ~.:jM C.) ;-., ."" '.0 .'. MORTGAGE ELECTRONIC REGISTRATION SYS1EMS, INC., IN THE COURT OF COMMON PLEAS OF CUMBERLAND COUNTY, PENNSYL VANIA Plaintiff v. CIVIL ACTION - LAW DZEV AD BEGANOVIC and MEHO BEGANOvtC, Defendants NO. 04-0565 CIVIL TERM ORDER OF COURT AND NOW, this 28th day of April, 2004, upon consideration of Plaintiff's Motion for Substituted Service under Pa. R.C,P. 430(a), it is ordered and directed that Plaintiff may serve the Complaint in Civil Action upon Defendants Dzevad Beganovic and Meho Beganovic by (1) mailing a true and correct copy of the complaint by certified mail and regular mail, to Defendants' last known address at 108 Memorial Acres, Sunbury, PA 17801, (2) publicatiOJlonce in the Cgmberland Law Journal ~ in a ~ewspaper of general circulation in Cumberland County, Pennsylvania, and (3) posting the premises at 1 South Second Street, Wormleysburg, PA 17043. BY THE COURT, [}Loot J esley oi!:)/ 1." Jose A. Goldbeck, Jr., Esq. S . e 500 ellon Independence Center 701 Market Street Philadelphia, PA 19106-1532 Attorney for Plaintiff Pre ( PROOF OF PUBLICATION State of Pennsylvania, County of Cumberland Tammy Shoemaker, Customer Care Sales manager, of The Sentinel, of the County and State aforesaid, being duly sworn, deposes and says that THE SENTINEL, a newspaper of general circulation in the Borough of Carlisle, County and State aforesaid, was established December 13th, 1881, since which date THE SENTINEL has been regularly issued in said County, and that the printed notice or publication attached hereto is exactly the same as was printed and published in the regular editions and issues of THE SENTINEL on the following date(s): May 18,2004 COPY OF NOTICE OF PUBLICATION ,~T~OF ~ C ,VANIA W . , . . NO. 01 IlHf gML11!RM l'i- .. .Ml'l'IClfiM~N.;l.q!I" 'MOAT /C AI! " STEMS. INt., i'Ufi#~1' va. . llZI!\' ~,M~, MOIlTBA!OQIi\$ANP REAL OWNE " '07"'.. '" .9:: ~_liIlIHallHANOVIC. , , -1)0' 1((:', ........1iiiIknown a~. . I tI1dl_~,~.We , .~~""~Mr,l, t.~I ~~..~QOLI, THE . '1'00....= " B'B _6' ........ -. 1'lt!;GtSTRATION qsv. ~~ ~~ ~w~a - l,'oii/ OICommonP I>tcu_ Counlyto \. '."~n~:\I .1 ~OIVlL TEAM.j,.:.mlll!'lill 'Jli(laKlo to ra'_ (.1 !1'..LI, ,>nyourproparty"",*,,Ifli>OI!ll~ ^==fu"utf;:It~043, whe...., YO,urJ1'?P~~~_Ily~ j,', I'" ,-.q "'.' .If,,"'" ""'<i.'.: ."',",,.~' ~< ~h;,~'r, ,..~. . "t''(: ..' ,.~ ill., ni Affiant further deposes that he/ she is not interested in the subject matter of the aforesaid notice or advertisement, and that all allegations in the foregoing statement as to time, place and charadeI' of ~::;~N4 Sworn to artd subscribed before me this 19 day of May, 2004 . ~!!d~ My commission expires: NOTARIAl SEAl. JACQUEUNE M. WORLEY, Notary Public Carlisle, Cumberland County My Commlsslon Expires Jan, 10,2005 PROOF OF PUBLICATION OF NOTICE IN CUMBERLAND LAW JOURNAL (Under Act No. 587, approved May 16, 1929), P. L.I 784 STATEOFPENNSYLVANIA : ss. COUNTY OF CUMBERLAND : Lisa Marie Coyne, Esquire, Editor of the Cumberland Law Journal, of the County and State aforesaid, being duly swom, according to law, deposes and says that the Cumberland Law Joumal, a legal periodical published in the Borough of Carlisle in the County and State aforesaid, was established January 2, 1952, and designated by the local courts as the official legal periodical for the publication of all legal notices, and has, since January 2, 1952, been regularly issued weekly in the said County, and that the printed notice or publication attached hereto is exactly the same as was printed in the regular editions and issues of the said Cumberland Law Journal on the following dates, Viz MAY 21, 2004 Affiant further deposes that he is authorized to verify this statement by the Cumberland Law Journal, a legal periodical of general circulation, and that he is not interested in the subject matter of the aforesaid notice or advertisement, and that all allegations in the foregoing statements as to time, place and character of publication are true. c 'l'L Y__ Li a Marie Coyne, Edi or TO AND SUBSCRIBED before me this day of MAY, 2004 ~A~.IL. kdo"'-/ .~-- ~m~L SEAL ;- I: LOIS E. SNYDER, Notary Public Carlisle Boro, Cumberland CoIIdy My Commission Expires Man:h 5. 2005 ., CUMBERLAND LAW JOURNAL NOTICE In the Court of Common Pleas of Cumberland County. Pennsylvania Civil Action-Law No. 04-0565-Civil Term MORTGAGE ELECTRONIC REGISTRATION SYSTEMS. INC.. PLAINTIFF vs, DZEVAD BEGANOVlC and MEHO BEGANOVIC. MORTGAGORS AND REAL OWNERS. DEFENDANTS NOTICE OF ACTION IN MORTGAGE FORECLOSURE TO: DZEVAD BEGANOVIC and MEHO BEGANOVIC. MORTGA, GORS AND REAL OWNERS. De- fendants. whose last known ad~ dresses are 108 Memorial Acres, Sunbury, PA ]780] and] South Second Street. Worrnleysburg, PA 17043 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, You are hereby notified that PlaJn~ tiff, MORTGAGE ELEC1RONlC REG- ISTRATION SYSTEMS. INC" has filed a Mortgage Foreclosure Complaint endorsed W1th a Notice to Defend, against you in the Court of Common Pleas of Cumberland County. Penn~ sylvania. docketed to NO. 04-0565 CML TERM, wheretn Plaintiff seeks to foreclose on the mortgage secured on your property located, 1 South Second Street. WormJeysburg, PA 17043. whereupon your property would be sold by the Sheriff of Cumberland County. NOTICE YOU HAVE BEEN SUED IN COURT. If you wish to defend against the claims set forth in the notice above, you must take action within twenty (20) days after this Complaint and NoUce are served, by entering a written appearance personally or by attorney and filing in writing with the Court your de- fenses or objections to the claims set forth against you. You are warned that if you fail to do so the case may proceed without you and a Judgment may be entered against you by the Court without further notice for any money claimed in the Complaint or for any other claim or relief requested by the Plaintiff. You may lose money or property or other rights important to you. YOU SHOULD TAKE THIS PA- PER TO YOUR LAWYER AT ONCE, IF YOU DO NOT HAVE A LAWYER GO TO OR TELEPHONE THE OF- FICE SET FORTH BELOW. THIS OFFICE CAN PROVIDE YOU WITH THE INFORMATION ABOUT HIR- ING A LAWYER. IF YOU CANNOT AFFORD TO HIRE A LAWYER. THIS OFFICE MAY BE ABLE TO PRO. VIDE YOU WITH INFORMATION ABOUT AGENCIES THAT MAY OF- FER LEGAL SERVICES TO ELI- GIBLE PERSONS AT A REDUCED FEE OR NO FEE, LEGAL SERVICES INC. B Irvine Row Carlisle. PA 17013 (717) 243-9400 4 . CUMBERLAND LAW JOURNAL CUMBERLAND COUNIY BAR ASSOCIATION 32 South Bedford Street CarU.Ie, PA 17013 (717) 249-3l66 JOSEPH A. GOLDBECK. JR GOLDBECK McCAFFER1Y & McKEEVER P.C, Attorneys for Plaintiff Mellon Independence Center 701 Market Street Suite 5000 Philadelphia, PA 19106-1532 (215) 627-1322 May 21 5 I.~ I (") c ...., ,~ ~2 ~ -i ~CI>-:~ , or I"" ;Sr? (:1(~ ::-::::f.; C')n :"<:C:"1 ,. (=: I C::l " --.... (~-"? c~. ~;~2 PRAECIPE FOR WRIT OF EXECUTION - (MORTGAGE FORECLOSURE) PRC.P 3180-3183 Joseph A. Goldbeck, Jr, . AttorneyI.D.#16132 Suite 500 - The Bourse Bldg. III S. Independence Mall East Philadelphia, P A 19106 215.627-1322 Attorney for Plaintiff MORTGAGE ELECTRONIC REGISTRATION SYSTEMS, INC. 7105 Corporate Drive PTX C-35 Piano, TX 75024.3632 IN THE COURT OF COMMON PLEAS of Cumberland County Plaintiff vs. CIVIL ACTION - LAW DZEV AD BEGANOVIC MEHO BEGANOVIC Mortgagor(s) and Record Owner(s) I South Second Street Wormleysburg, P A 17043 ACTION OF MORTGAGE FORECLOSURE No, 04-565 CIVIL TERM Defendant( s) PRAECIPE FOR WRIT OF EXECUTION TO THE PROTHONOTARY: Issue Writ of Execution in the above matter: Amount Due $90,464,95 Interest from 09/01/2003 to 07/0212004 at 7.1200% (Costs to be added) GOLDBECK McC BY: Joseph A. Go c' MID"., 'm "'"\] 00 ..: r"'I ~ ~~ "-J:;:: f-<:;:: do E 2: u "u... f-<<n0 'Df-< ~~ '0 ~u r"'I := f-< =s <Ii' ::E ~ 00 >- 00 z o .... f-< 22 f-< 00 G ~0 u25 Z o ~ f-< U "-J -i "-J "-J ~ " f-< ~ o ::E ~- Cr': I---::~ H1S-~J u..--. ..-c) t~:::!..::: 6~) 'T,,_ 0....- u.;o.... ...;.;..!lU II:!:: }-- LI_ o ("') :::r: "- c:> I _J ::~) --, ~ C:.:-,; C":':'> '" ~ ~ ~ ~ ')::;' ] V M "'u~-"'" ~~o~?2 ;>--- 10- OO]CIJ~ ~~ ~]~~ ""~8e:' '-" ~ "'d (\) ;:I ~.c:oS:::v:l.o .co ~...c ~ ~ffi~]] "-J::E ~- ~ N on p- Q 15 6 z o .... f-< ~ u~ r"'I.. :>< ... r"'I ~ ...,S o ii ~f-<~ ~ '" ~Ef o ... ... 0 r"'I6 Il. .... U r"'I ~ Il. "::;1t= ..::j'E u ,_ " '" "'- '<l,,", - ~ c3~ ,;>, -< a il 0 ~~ ..., ... .. .. ~ . <;IJ .. on '" ~::EWJ'-O I:.i.c:o..... 0 ~oc;,;:; ~~~-~ COU<M ... eel I=: ~ "7 Q,l d.) .g Q~ r:- =...r::1c:.E~ C':I~ & p.. , ~ I (1) v::e: ~O]~N ~o_....... <n :.2 i1~u:i~ Q,l ...... ........ "'''- '<l"'_ '0 (.:I - -40 , , " -f-~ - ~ , " ~ '- ~ , , - , <:::1:.1;; -.j - , ~ - ::: - , ~~~ , ~ aJ0 , - - , a '::r 'Cl'0 ~ \) -Q \) 8 l() '-Q ':r ~ \) to 1\ () 0 N) 0 "- 0 ~ o ~ SJ. k! ~ , uj . ~o:.ry ~ ~~~ -- ~ "t ~ rt:::z. f"4 &~ ry J f"C) _. ~ , I G 1 J4 vi ~ J uJ Gj - ~ 0- 0- rt V, -t - -=tI- '~ 3 ~ Lellal Description: ALL THAT CERTAIN TRACT OR PARCEL OF LAND AND PREMISES, SITUATE, LYING AND BEING IN THE BOROUGH OF WORMLEYSBURG IN THE COUNTY OF CUMBERLAND AND COMMONWEALTH OF PENNSYLVANIA, MORE P ARTlCULARL Y DESCRIBED AS FOLLOWS: BEGINNING AT A POINT AT THE SOUTHEAST CORNER OF SECOND AND FERRY STREETS; THEtiCE IN A SOUTHERLY DIRECTION ALONG THE EASTERN LINE OF SECOND STREET THIRTY-oNE (31) FEET TO A POINT; THENCE IN AN EASTERLY DIRECTION ALONG A LINE PARALLEL WITH FERRY STREET EIGHTY-SIX (86) FEET, MORE OR LESS, TO A POINT; THENCE IN A NORTHERLY DIRECtION ALONG LANDS NOW OR LATE OF WILLIAM LIPPERT THIRTY-ONE (31) FEET TO A POINT ON THE SOUTHERN LINE OF FERRY STREET; THENCE IN A WESTERLY (ERRONEOUSLY STATED ON PRIOR DEEDS AS EASTERLY) DIRECTION ALONG THE SOUTHERN LINE OF FERRY STREET EIGHTY-SIX (86) FEET, MORE OR LESS, TO A POINT, THE PLACE OF BEGINNING. HAVING THEREON ERECTED A SINGLE FRAME DWELLING HOUSE, KNOWN AS NO. 1 SOUTH SECOND STREET, WORMLEYSBURG, PENNSYLVANIA. BEING THE SAME PREMISES WIDCH JEFFRIE A. CROSSLEY AND CRlSTEN A. CROSSLEY, HUSBAND AND WIFE, BY DEED DATED JlJNE 19, 2002, GRANTED AND CONVEYED UNTO MEHO BEGANOVIC, MARRIED MAN, AND DZEV AD BEGANOVIC, SINGLE MAN, BORROWER. 1 WRIT OF EXECUTION and/or ATTACHMENT COMMONWEALTH OF PENNSYLVANIA) COUNTY OF CUMBERLAND) NO 04-565 Civil CIVIL ACTION ~ LAW TO THE SHERIFF OF CUMBERLAND COUNTY: To satisfy the debt, interest and costs due MORTGAGE ELECTRONIC REGISTRATION SYSTEMS, INC., Plaintiff (s) From DZEV AD BEGANOVIC AND MEHO BEGANOVIC (I) You are directed to levy upon the property of the defendant (sland to sell SEE LEGAL DESCRIPTION (2) You are also directed to attach the property of the defendant(s) not levied upon iu 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 defendaut (s) and from delivering any property of the defendant (s) or otherwise disposing thereof; (3) Ifproperty of the defendaut(s) not levied upon an subject to attachmeut is found in the possessiou of anyone other than a named garnishee, you are directed to notify himlher that he/she has been added as a garnishee and is eujoined as above stated. Amount Due $90,464.95 Iuterest FROM 911/03 TO 7/2/04 AT 7.1200% L.L. $.50 Arty's Comm % Due Prothy $1.00 Other Costs Arty Paid $324.53 Plaintiffpaid Date: JULY 8, 2004 CURTIS R. LONG (Seal) Prothonotary \",J3y: ~O/?J. P. 77fJl.4,., ,.~. Deputy REQUESTING PARTY: Name JOSEPH A. GOLDBECK, JR., ESQIDRE Address: SIDTE 500 - THE BOURSE BLDG. 111 S. INDEPENDENCE MALL EAST PHILADELPHIA, PA 19106 Attorney for: PLAINTIFF Telephone: 215-627-1322 Supreme Court ID No. 16132 Goldbeck McCafferty & McKeever BY: Joseph A. Goldbeck, Jr. Attorney 1.0. '116132 Suite 500 - The Bourse Bldg. III S. Independence Mall East Philadelphia, P A 19106 215-627-1322 Attorney for Plaintiff MORTGAGE ELECTRONIC REGISTRATION SYSTEMS, INe. 7105 Corporate Drive PTX C-35 Piano, TX 75024-3632 IN THE COURT OF COMMON PLEAS of Cumberland County Plaintiff vs. CIVIL ACTION . LAW DZEV AD BEGANOVIC MEHO BEGANOVIC (Mortgagor(s) and Record Owner(s)) 1 South Second Street Wormleysburg, PA 17043 ACTION OF MORTGAGE FORECLOSURE Defendant( s) No. 04-565 CIVIL TERM AFFIDAVIT PURSUANT TO RULE 3129 MORTGAGE ELECTRONIC REGISTRATION SYSTEMS, INe., 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 followiug information concerning the real property located at: I South Second Street Wormleysburg, PA 17043 I.Name and address ofOwner(s) or Reputed Owner(s): DZEV AD BEGANOVIC 108 Memorial Acres Sunbury, PA 17801 MEHO BEGANOVIC 108 Memorial Acres Sunbury, P A 17801 2. Name and address ofDefeudant(s) in the judgment: DZEV AD BEGANOVIC 108 Memorial Acres Suubury, P A 1780 I MEHO BEGANOVIC 108 Memorial Acres Sunbury, PA 17801 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 P A DEPARTMENT OF PUBLIC WELFARE - Bureau of Child Support Enforcemeut Health and Welfare Bldg. - Room 432 P.O. Box 2675 Harrisburg, P A 17105-2675 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/OCCUP ANTS I South Second Street W ormleysburg, P A 17043 (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. GOLDBECK BY: Joseph A. Gc ^_fu,'wr~ ' DATED: July 2,2004 ~-~' ~.; s::-=: o -q c..... c_~ :-t rr,X r" ~a8 ,'),.C '3h.> ;. .j, '''',:0 ~~':';'(J ,jm I ....) -< I co -r, -'"- (...1 , .GOLDBECK McCAFFERTY & McKEEVER BY: Joseph A. Goldbeck, Jr. Attorney LD,#16132 Suite 5000 - Mellon Independence Center 70 I Market Street Philadelphia, PA 19106.1532 215-627-1322 Attorney for Plaintiff MORTGAGE ELECTRONIC REGISTRATION SYSTEMS, INC. n 05 Corporate Drive PTX C-35 Piano, TX 75024-3632 IN THE COURT OF COMMON PLEAS of Cumberland County Plaintiff CIVIL ACTION - LAW vs. DZEV AD BEGANOVIC MEHO BEGANOVIC Mortgagor(s) and Record Owner(s) ACTION OF MORTGAGE FORECLOSURE I South Second Street Wonnleysburg, PA 17043 Term No. 04.565 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: BEGANOVIC, DZEV AD DZEVAD BEGANOVIC I South Second Street Wormleysbuyg, P A 17043 Your house at I South Second Street, W ormleysburg, P A 17043 is scheduled to be sold at Sheriffs Sale on Wednesday, December 08,2004, at 10:00 AM, in Commissioners Hearing Rm 2nd FL Courthouse to enforce the court judgment of $90,464.95 obtaiued by MORTGAGE ELECTRONIC REGISTRATION SYSTEMS, 1Ne. 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: I. The sale will be cancelled if you pay to MORTGAGE ELECTRONIC REGISTRATION SYSTEMS, 1Ne., the back payments, late charges, costs and reasonable attorney's fees due. To find out how much you must pay call: 215-627.1322 . 2. You may be able to stop the sale by filing a petition asking the Court to strike or openjudgmeut, 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. I, 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 caIling the Sheriff of717-240-6390, 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 of717-240-6390. 4, If the amouut 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 mouey 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 mouey will be paid out in accordance with this schedule unless exceptions (reasons why the proposed distribution is wrong) are filed with the Sheriffwithiu 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, P A 17013 CUMBERLAND COUNTY BAR ASSOCIATION 2 Liberty Avenue Carlisle, PA 17013 "" <= c.:) o -n .-< ~n iI~ ~~ fIl .1'-,- ~~~.: ; -~~ ::!:~ t.~~~ , c. c: ,--. I C1 -" ~. (" ~5~ 04-565 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 Plaintiff MORTGAGE ELECTRONIC REGISTRATION SYSTEMS, INC. 71 05 Corporate Drive PTX C-35 Piano, TX 75024.3632 IN THE COURT OF COMMON PLEAS of Cumberland County Plaintiff CIVIL ACTION - LAW vs. DZEV AD BEGANOVIC MEHO BEGANOVIC Mortgagor(s) and Record Owner(s) ACTION OF MORTGAGE FORECLOSURE I South Second Street W onnleysburg, PAl 7043 Term No. 04-565 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: BEGANOVIC. DZEV AD DZEVAD BEGANOVIC 108 Memorial Acres Sunbury, P A 17801 Your house at 1 South Second Street, W ormleysburg, P A 17043 is scheduled to be sold at Sheriffs Sale on Wednesday, December 08, 2004, at 10:00 AM, in Commissioners Hearing Rm 2nd FL Courthouse to enforce the court judgment of $90,464.95 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: I. 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 fmd out how much you must pay call: 215.627-1322 04-565 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 postpoue 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. I, If the Sheriff's Sale is not stopped, your property will be sold to the highest bidder. You may fiud out the price bid price by calling the Sheriff of717-240-6390. 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 fmd out ifthis has happened, you may call the Sheriff of717.240-6390. 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 iu the property until the full amouut due is paid to the Sheriff and the Sheriff gives a deed to the buyer. At that time, the buyer may bring legal proceedings to evict you, 6. You may be entitled to a share of the money which was paid for your house. A schedule of distribution of the money bid for your house will be filed by the Sheriff thirty (30) days from the date of the Sheriff's Sale. This schedule will state who will be receiving that money. The money will be paid out iu accordance with this schedule unless exceptions (reasons why the proposed distributiou 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 ASSOCIA nON 2 Liberty Avenue Carlisle, PA 17013 (-) '" ...":.;. C':.. C) -n :-:.1 fii:n ,. -':jfT1 :rJO !;* :"if't'l :, ~~: ~ ( C' Ie; I c::, ~1 Co.) GOLDBECK McCAFFERTY & McKEEVER BY: Joseph A. Goldbeck, Jr. Attorney I.D.#16132 Suite 5000 . Mellon Independence Center 701 Market Street Philadelphia, PA 19106-1532 215-627-1322 Attorney for Plaintiff MORTGAGE ELECTRONIC REGISTRATION SYSTEMS, INC, 71 05 Corporate Drive PTX C.35 Piano, TX 75024-3632 IN THE COURT OF COMMON PLEAS of Cumberland County Plaintiff CIVIL ACTION . LAW vs. DZEV AD BEGANOVIC MEHO BEGANOVIC Mortgagor(s) and Record Owner(s) ACTION OF MORTGAGE FORECLOSURE I South Second Street W onnleysburg, PAl 7043 Term No, 04-565 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: BEGANOVIC, MEHO MEHO BEGANOVIC 1 South Second Street Wormleysburg, PA 17043 Your house at 1 South Second Street, W onnleysburg, P A 17043 is scheduled to be sold at Sheriffs Sale on Wednesday, December 08, 2004, at 10:00 AM, in Commissioners Hearing Rm 2ud FL Courthouse to euforce the court judgment of$90,464,95 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 jmmediate 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: 2] 5-627-1322 2. You may be able to stop the sale by tiling a petition asking the Court to strike or open judgment, if the judgment was improperly eutered. 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 mOTe chance you will have of stopping the sale, (See notice below on how to obtaiu 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 Sheriffs Sale is uot stopped, your property will be sold to the highest bidder. You may fiud out the price bid price by calling the Sheriff of717.240.6390. 2. You may be able to petition the Court to set aside the sale ifthe bid price was grossly inadequate compared to the value of your property. 3, The sale will go through only 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 of717-240-6390. 4. If the amount due from the Buyer is not paid to the Sheriff, you will remain the owner ofthe property as if the sale never happened. 5. You have a right to remain in the property uutil the full amount due is paid to the Sheriff and the Sheriff gives (l deed to the buyer. At that time, the huyer 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 yonr house will be filed by the Sheriff thirty (30) days from the date of the Sheriffs Sale. This schedule will state \vho 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 SheritI within ten (10) days after the schedule of distribution is tiled, 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, P A 17013 CUMBERLAND COUNTY BAR ASSOCIATION 2 Liberty Aveuue Carlisle, PA 17013 -... "., '=:;) (::-;;;0 ~- r___ C~: ,-- I CO CJ -r; ..., I-n ~~;~ ~-) 1.. ~:j ~-~ -":;-" -q ~5f;~ _. ~- ~:) ::,;:-..: 04-565 CIVIL TERM ~BECK McCAFFERTY & McKEEVER BY: Joseph A. Goldbeck, Jr. Attorney I.D.#16l32 Suite 5000. Mellon Independence Center 701 Market Street Philadelphia, P A 19106 215-627.1322 Attorney for Plaintiff MORTGAGE ELECTRONIC REGISTRATION SYSTEMS, INC. 7105 Corporate Drive PTX C-35 Piano, TX 75024-3632 IN THE COURT OF COMMON PLEAS of Cumberland County Plaintiff CIVIL ACTION - LAW vs. DZEV AD BEGANOVIC MEHO BEGANOVIC Mortgagor(s) and Record Owner(s) ACTION OF MORTGAGE FORECLOSURE I South Second Street Wormleysburg, PA 17043 Term No. 04-565 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: BEGANOVIC. MEHO MEHO BEGANOVIC 108 Memorial Acres Sunbury, P A 17801 Your house at I South Second Street, W ormleysburg, P A 17043 is scheduled to be sold at Sheriffs Sale ou Wednesday, December 08, 2004, at 10:00 AM, in Commissioners Hearing Rm 2nd FL Courthouse to enforce the court judgment of $90,464.95 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 reasouable attorney's fees due. To fiud out how much you must pay call: 215.627.1322 04-565 CIVIL TERM , 2. You may be able to stop the sale by filing a petitiou 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. I. If the Sheriff's Sale is not slopped, your property will be sold to the highest bidder. You may fmd out the price bid price by calling the Sheriff of717-240.6390, 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 of717-240-6390. 4. If the amouut due from the Buyer is not paid to the Sheriff, you will remain the owuer of the property as if the sale never happened. 5. You have a right to remain in the property until the full amouut 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 distributiou of the money bid for your house will be filed by the Sheriff thirty (30) days from the date of the Sheriff's Sale. This schedule will state who will be receiving that money. The money will be paid out in accordance with this schedule unless exceptions (reasons why the proposed distribution is wrong) are filed with the Sheriff within ten (10) days after the schedule of distribution is filed. 7, You may also have other rights and defenses, or ways of getting your house back, if you act immediately after the sale, YOU SHOULD TAKE THIS PAPER TO YOUR LAWYER AT ONCE, IF YOU DO NOT HAVE A LAWYER OR CANNOT AFFORD ONE, GO TO OR TELEPHONE THE OFFICE LISTED BELOW TO FIND OUT WHERE YOU CAN GET LEGAL HELP. LEGAL SERVICES INC 8 Irvine Row Carlisle, PA 17013 CUMBERLAND COUNTY BAR ASSOCIATION 2 Liberty Avenue Carlisle, PA 17013 '" .:..:::.:;. ~~ o " (~ c r--- I c:; :? r11-;D. r'~, -n,";,,' ~-'1 \.......i ., I Orl ~:;~] :': ~ ) ;.-,.n ~-:l t.' ~ C) :~~ GOLDBECK McCAFFERTY & McKEEVER BY; Joseph A. Goldbeck, Jr. Attorney I.D.#16132 Suite 5000 - Mellon Independence Center 701 Market Street Philadelphia, PA 19106-1532 215-627-1322 Attorney for Plaintiff MORTGAGE ELECTRONIC REGISTRATION SYSTEMS, INC. 7105 Corporate Drive PTX C-35 PIano, TX 75024-3632 CWD-3289 IN THE COURT OF COMMON PLEAS of Cumberland County CIVIL ACTION -LAW Plaintiff vs. ACTION OF MORTGAGE FORECLOSURE DZEV AD BEGANOVIC MEHO BEGANOVIC Mortgagor(s) and Record Owner(s) Term No. 04-565 CML TERM 1 South Second Street Wormleysburg, PA 17043 Defendant(s) CERTIFICATE OF SERVICE PURSUANT TO Pa.R.C.P. 3129.2 (e) (2) Joseph A. Goldbeck, Jr., Esquire, Attorney for Plaintiff, hereby certifies that service on the Defendants of the Notice of Sheriff Sale was made by: ( ) Personal Service by the Sheriffs Office/competent adult (copy of return attached). ( ) Certified mail by Joseph A. Goldbeck, Jr. (original green Postal return receipt attached). ( ) Certified mail by Sheriffs Office. ( ) Ordinary mail by Joseph A. Goldbeck, Jr., Esquire to Attorney for Defendant(s) of record (proof of mailing attached). ( ) Acknowledgment of Sheriffs Sale by Attorney for Defendant(s) (proof of acknowledgment attached). ( ) Ordinary mail by Sheriffs Office to Attorney for Defendant(s) of record. IF SERVICE WAS ACCOMPLISHED BY COURT ORDER. " Premises was posted by Sheriffs Office/oompi,ut ~d\At (copy of return attached). ( ) Certified Mail & ordinary mail by Sheriffs Office (copy of return attached). ~ Certified Mail & ordinary mail by Joseph A. Goldbeck, Jr. (original receipt(s) for Certified Mail attached). Pursuant to the Affidavit under Rule 3129 (copy attached), service on all lienholders (if any) has been made by ordinary mail by Joseph A. Goldbeck, Jr., Esquire (copies of proofs of mailing attached). , i I o o " &.0 ~:"" 0' (A. (X- ~-- I.' 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VS Dzevak Beganovic and Meho Beganovic In The Court of Common Pleas of Cumberland County, Pennsylvania Writ No. 2004-565 Civil Term Bryan Ward, Deputy Sheriff, who being duly sworn according to law, states that on September 13,2004 at 3:43 o'clock PM, he served a true copy of the within Real Estate Writ, Notice of Sheriffs Sale and Description, in the above entitled action, upon the within named defendant, to wit: Dzevak Beganovic, by posting the premises located at 1 South Second Street, W ormleysburg, P A 17043 with a true and correct copy of the within Real Estate Writ, Notice of Sale and Description, pursuant to order of court, according to law. Shannon Shertzer, Deputy Sheriff, who being duly sworn according to law, states that on September 14, 2004 at 5:01 o'clock PM, he served a true copy of the within Real Estate Writ, Notice of Sheriffs Sale and Description, in the above entitled action, upon the within named defendant, to wit: Meho Beganovic, by posting the premises located at 1 South Second Street, Wormleysburg, PA 17043 with a true and correct copy ofthe within Real Estate Writ, Notice of Sale and Description, pursuant to order of court, according to law. Ron Hoover, Deputy Sheriff, who being duly sworn according to law, states that on October 07,2004 at 2:34 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 Dzevak Beganovic and Meho Beganovic located at 1 South Second Street, Wormleysburg, Pennsylvania, according to law. R. Thomas Kline, Sheriff, who being duly sworn according to law, states he served the above Real Estate Writ, Notice, Poster and Description in the following manner: The Sheriff mailed a notice of the pendency of the action to the within named defendant, to wit: Dzevak Beganovic, by regular mail to his last known address of 108 Memorial Acres, Sunbury, P A 17801. This letter was mailed under the date of October 06,2004 and returned to the Sheriffs Office on October 12,2004 as "Attempted, Not Known. " R. Thomas Kline, Sheriff, who being duly sworn according to law, states he served the above Real Estate Writ, Notice, Poster and Description in the following manner: The Sheriff mailed a notice of the pendency of the action to the within named defendant, to wit: Meho Beganovic, by regular mail to her last known address of 1 South Second Street, W ormleysburg, PAl 7043. This letter was mailed under the date of October 06, 2004 and returned to the Sheriffs Office on October 13, 2004 as "Moved, Left No Address, Unable to Forward." Sworn and subscribed to before me Prothonotary ~~~< ~~ R. Thomas Kline, ~~riff. ~~~ This _ day of 2004, A.D. GOLDBECK McCAFFERTY & McKEEVER BY: Joseph A. Goldbeck, Jr. Attorney 1.D.#16132 Suite 5000 - Mellon Independence Center 701 Market Street Philadelphia, PA 19106-1532 215-627-1322 Attorney for Plaintiff MORTGAGE ELECTRONIC REGISTRATION SYSTEMS, INC. 7105 Corporate Drive PTX C-35 PIano, TX 75024-3632 IN THE COURT OF COMMON PLEAS of Cumberland County Plaintiff CIVIL ACTION - LAW vs. ACTION OF MORTGAGE FORECLOSURE DZEV AD BEGANOVIC MEHO BEGANOVIC Mortgagor(s) and Record Owner(s) Term No. 04-565 CIVIL TERM 1 South Second Street W onnleysburg, P A 17043 Defendant( s) SUPPLEMENTAL 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: 1 South Second Street Wormleysburg, PA 17043 l.Name and address ofOwner(s) or Reputed Owner(s): DZEV AD BEGANOVIC 1 South Second Street Wormleysburg, PA 17043 MEHO BEGANOVIC 108 Memorial Acres Sunbury, PA 17801 2. Name and address ofDefendant(s) in the judgment: DZEV AD BEGANOVIC 1 South Second Street Wormleysburg, PA 17043 MEHO BEGANOVIC 108 Memorial Acres Sunbury, PA 17801 3. Name and last known address of every judgment creditor whose judgment is a record lien on the property to be sold: Cumberland County Adult Probation 1 Courthouse SO Carlisle, P A 17013-3387 DOMESTIC RELATIONS OF CUMBERLAND COUNTY PO Box 320 Carlisle, P A 17013 P A DEPARTMENT OF PUBLIC WELFARE - Bureau of Child Support Enforcement Health and Welfare Bldg. - Room 432 P.O. Box 2675 Harrisburg, PA 17105-2675 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 plaintiffhas knowledge who has any interest in the property which may be affected by the sale. TENANTS/OCCUPANTS 1 South Second Street Wonnleysburg, PA 17043 (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. I DATED: November 4,2004 rOO) 1"'..., .~.. ""l (; ( ::> "I I ~ ...'~ .", :;:-:j (" ) , ..." ........:; rJ I r"~ -0 ~~~ - J '-J '. C) '~1 (") ~ -~ -r:; -';', , -n -T1 J , C') , ~, ( ~~ , ;'11 r'J ; ~l;e. ( ""~, - :,J !~0 .-< , . COMMONWEALTH OF PENNSYLVANIA COUNTY OF CUMBERLAND }SS: 0'1- 5,~ I, Robert P. Ziegler, Recorder of Deeds in and for said County and State do hereby ce ify that the Sheriffs Deed in which Secretary of Housing & Urban Dev is the grantee the same havin been sold to said grantee on the 8th day of Dec A.D., 2004, under and by virtue of a writ Execution issu d on the 8th day of July, A.D., 2004, out of the Court of Common Pleas of said County as of Civil Te , 2004 Number 565, at the suit ofMtg Electronic Reg Systems Inc against Dzevak Be anovic & Meh is duly recorded in Sheriffs Deed Book No. 267, Page 1820. IN TESTIMONY WHEREOF, I have hereunto set y hand ,,d- and seal of said office this / day of ,PA Jon. 2001I " Mortgage Electronic Registration Systems, Inc. VS Dzevak Beganovic and Meho Beganovic In The Court of Common Pleas of Cumberland County, Pennsylvania Writ No. 2004-565 Civil Term Bryan Ward, Deputy Sheriff, who being duly sworn according to law, states tha on September 13,2004 at 3:43 o'clock PM, he served a true copy of the within Real Estate Writ, Notice of Sheriffs Sale and Description, in the above entitled action, upon the within named defendant, to wit: Dzevak Beganovic, by posting the premises locate at I South Second Street, Wormleysburg, PA 17043 with a true and correct copy of the within Real Estate Writ, Notice of Sale and Description, pursuant to order of court, according to law. Shannon Shertzer, Deputy Sheriff, who being duly sworn according to law, stat that on September 14,2004 at 5:01 o'clock PM, he served a true copy of the within Rea Estate Writ, Notice of Sheriffs Sale and Description, in the above entitled action, upon the within named defendant, to wit: Meho Beganovic, by posting the premises located a I South Second Street, W ormleysburg, P A 17043 with a true and correct copy of the within Real Estate Writ, Notice of Sale and Description, pursuant to order of court, according to law, Ron Hoover, Deputy Sheriff, who being duly sworn according to law, states that on October 07, 2004 at 2:34 o'clock P.M., he posted a true copy of the within Real Estat Writ, Notice, Poster and Description, in the above entitled action, upon the property of Dzevak Beganovic and Meho Beganovic located at I South Second Street, Wormleysburg, Pennsylvania, according to law. R. Thomas Kline, Sheriff, who being duly swom according to law, states he served the above Real Estate Writ, Notice, Poster and Description in the following manner: The Sheriff mailed a notice of the pendency of the action to the within named defendant, to wit: Dzevak Beganovic, by regular mail to his last known address of 108 Memorial Acres, Sunbury, P A 1780 I. This letter was mailed under the date of October 06,2004 and returned to the Sheriffs Office on October 12, 2004 as "Attempted, Not Known. II R. Thomas Kline, Sheriff, who being duly sworn according to law, states he served the above Real Estate Writ, Notice, Poster and Description in the following manner: The Sheriff mailed a notice of the pendency of the action to the within named defendant, to wit: Meho Beganovic, by regular mail to her last known address of I South Second Street, W ormleysburg, PAl 7043, This letter was mailed under the date of October 06, 2004 and returned to the Sheriffs Office on October \3,2004 as "Moved, Left No Address, Unable to Forward." . 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 December 8, 2004 at 10:00 o'clock A.M. He sold the same for the sum of$1.00 to Attomey Joseph Goldbeck for Secretary of Housing and Urban Development, His Successors and Assigns. It being the highest bid and best price received for the same, Secretary of Housing and Urban Development, His Successors and Assigns of 100 Penn ,> Square East, lOth Floor Wanamaker Building, Philadelphia, P A 19106 being the buyer n this execution, paid to Sheriff R. Thomas Kline the sum of $762.05. Sheriffs Costs: Docketing Poundage Posting Bills Advertising Acknowledging Deed Auctioneer Law Library Prothonotary Mileage Levy Surcharge Posting Law Journal Patriot News Share of Bills Distribution of Proceeds Sheriffs Deed $ $30.00 14.94 15.00 15.00 30.00 10.00 .50 1.00 23.68 15.00 30.00 12.00 237.50 232.51 30.42 25.00 39.50 762.05 Swom and subscribed to before me t:> --( This~dayof'~~" 'J 2005,A,D.\..kl1, ()~ ~ P othonotary ~~~ i ~~f't:~ R. Thomas Kline, Sheriff ByJ(Jd IAXA~ ,-/-L Real Est~6e;;~v" vP Jo1J0 p'O Ue... I H 7 '1 r/2ev /t6$'39 Goldbeck McCafferty & McKeever BY: Joseph A. Goldbeck, Jr. Attorney 1.D. #16132 Suite 500 - The Bourse Bldg. III S. Independence Mall East Philadelphia, PA 19106 215-627-1322 Attorney for Plaintiff MORTGAGE ELECTRONIC REGISTRATION SYSTEMS, lNC, 7105 Corporate Drive PTX C-35 Plana, TX 75024.3632 IN THE COURT OF COMMON EAS of Cumberland County Plaintiff vs. CIVIL ACTION. LAW DZEV AD BEGANOVIC MEHO BEGANOVIC (Mortgagor(s) and Record Owner(s)) I South Second Street Wormleysburg, PA 17043 ACTION OF MORTGAGE FORECL SURE Defendant( s) No. 04.565 CIVIL TERM AFFIDAVIT PURSUANT TO RULE 3129 MORTGAGE ELECTRONIC REGISTRATION SYSTEMS, INC" Plaintiff in the above aclion, by its att mey, Joseph A. Goldbeck, Jf., Esquire, sets forth as of the date the praecipe for the writ of execution was tiled the follow g information concerning the real property located at: I South Second Street Wonnleysburg, PA 17043 1 ,Name and address of Owner(s) or Reputed Owner(s): DZEV AD BEGANOVIC 108 Memorial Acres Sunbury, PA 17801 MEHO BEGANOVIC 108 Memorial Acres Sunbury, PA 17801 .'J Nnme and address of Defendant(s) in thejl1dgment: DZEV AD BEGANOVIC 108 Memorial Acres Snnbury. PA 1780 I MEHO BEGANOVIC lOR Memorial Acres Sunbury, P A 1780 I .1. N;ont, ~Hld Insl knO\V11 ;:Iddress of every judgment creditor ,vhose judgment is a record hen on the prnpl'!"t:... 10 be sol DOMESTIC RELATIONS OF CUMBERLAND COUNTY PO Box 320 Carlisle, I' A 1 7013 P A DEPARTMENT OF PUBLIC WELFARE. Bureau of Child Support Enforceme Health and Welfare Bldg. - Room 432 P.O. Box 2675 Harrisburg, PA 17105-2675 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 whos 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 th 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 prope y which may be affected by the sale. TENANTS/OCCUP ANTS I South Second Street Wormleysburg, PA 17043 (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 knowledg or information and belief. I understand that false statements herein are made subject to the penalties of 18 Pa. C,S, Sec ion 4904 relating to unsworn falsification to authorities. GOLDBECK BY: Joseph A. G Attorney for Plai DATED: July 2,2004 ~ 04-565 CIVIL TE M I GOLDBECK McCAFFERTY & McKEEVER BY: Joseph A Goldbeck, Jr. Attorney I.D,#16132 Suite 5000. Mellon Independence Center 701 Market Street Philadelphia, P A 19106 215-627-1322 Attorney for Plaintiff MORTGAGE ELECTRONIC REGISTRATION SYSTEMS, INe. 7105 Corporate Drive PTX C-35 Piano, TX 75024.3632 IN THE COURT OF COMMON PLEA of Cumherland County Plaintiff CIVIL ACTION - LAW vs. DZEV AD BEGANOVIC MEHO BEGANOVIC Mortgagor(s) and Record Owner(s) ACTION OF MORTGAGE FORECLOSURE 1 South Second Street W ormleysburg, PAl 7043 Term No. 04-565 CIVIL TERM Defendant( s THIS LAW FIRM IS A DEBT COLLECTOR ANn WE ARE ATTEMPTIN(; 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: 8FGANOVIC, DZEVAD DZEVAD BEGANOVIC Ill8 Memorial Acres Sunbury, P A 1780 I Your house at 1 South Second Street. Wonnleysburg, PA 17043 is scheduled to be sold at Sheriffs Sale on Wednesday, December 08, 2004, at 10:00 AM, in Commissioners Hearing Rm 2nd FL Courthouse to enforce the court judgment of$90,464,95 obtained by MORTGAGE ELECTRONIC REGISTRATION SYSTEMS, INC, against you, NOTICE OF OWNER'S RIGHTS YOU MAY BE ABLF, TO PREVENT THIS SHERIFF'S SAI,E To prevent this Sheriffs Sale you must take immediate action: l. The sale will be cancelled if you pay to MORTGAGE ELECTRONIC REGISTRATION SYSTEMS, INC., the back payments, late charges, c.osts and reas01lable ntt(lmC'y's fees due, To tind ouf how much you must pay call: 215.627-1322 . 04-565 CIVIL TE M 2, You may be able to stop the sale by filing a petition asking the Court to strike or open judgme , 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. Yau may need an attorney to assert your rights. The sooner you contact one, the more chance y u will have of stopping the sale, (See notice below on how to obtain an attorney). YOU MAY STILL BE ABLE TO SAVE YOUR PROPERTY AND YOU HAVE OTHER RIGHT 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 fin out the price bid price by calling the Sheriff of717-240-6390, 2. You may be able to petition the Court to set aside the sale if the bid price was grossly lnadequat 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 fin out if this has happened, you may call the Sheriff of717-240-6390, 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 uever 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 huyer. At that t1me, the buyer mClY hring leg<ll proceedings f() evict YOll, 6. You may be entitled to a share of the money \vhich 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 t SheritTs Sale. This schedule \v'ill slate v.ho \vill be receiving that mouey. The money \v1l1 be paid out in accordance with this schedule unless exceptions (reasons why the propnsed distrihutloll is \\Tnng) ;lre filed with the Sheriff within teu (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 inunediately 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 TlIE OFFICE IISTFD BElOW TO FIND OUT WHERF VOU CAN (;FT T FGAL HELP, LEGAL SERVICES lNC 8 Irvine Row Carlisle, PA 17013 CUMBERLAND COUNTV BAR ASSOCIATION 2 Liberty Avenue Cnrlisk P.,\ 170 I" .. . GOLDBECK McCAFFERTY & McKEEVER BY: Joseph A. Goldbeck, Jr. Attorney I.D.#16132 Suite 5000 - Mellon Independence Center 70 I Market Street Philadelphia, PA 19106-1532 215.627.1322 Attorney for Plaintiff MORTGAGE ELECTRONIC REGISTRATION SYSTEMS, INC. 71 05 Corporate Drive PTX C-35 Plano, TX 75024.3632 IN THE COURT OF COMMON PLEA of Cumberland County Plaintiff CIVIL ACTION - LAW vs. DZEV AD BEGANOVIC MEHO BEGANOVIC Mortgagor(s) and Record Owner(s) ACTION OF MORTGAGE FORECLOSURE I South Second Street Wormleysburg, P A 17043 Term No. 04.565 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 OBT AINED FROM YOU WILL BE USED FOR THAT PURPOSE. NOTICE OF SHERIFF'S SALE OF REAL PROPERTY TO: BEGANOVIC. MEHO MEHO BEGANOVIC I South Second Street W ormleysburg, P A 17043 Your house at I South Secoud Street, Wormleysburg, PA 17043 is scheduled to be sold al Sheriffs Sale on Wednesday, December 08,2004, at 10:00 AM, in Commissioners Hearing Rm 2nd FL Courthouse to enforce the court judgment of $90,464.95 obtained by MORTGAGE ELECTRONIC REGISTRATION SYSTEMS, INe. 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, INe., the back payments, late charges, costs and reasonable attorney's fees due, To find out how much you must pay call: 215-627.1322 ~ 2. You may be able to stop the sale by filing a petitiou asking the Court to strike or open judgmen 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 y 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 Sheriffs Sale is not stopped, your property will be sold to the highest bidder. You may fin out the price bid price by calling the Sheriff 01717-240.6390, 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 fin out if this has happened, you may call the Sheriff 01717-240-6390, 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 dee,d to the buyer. At that time, the buyer may bring legal proceedings to eVld 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 th 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, Yau 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, P A 17013 CUMBERLAND COUNTY BAR ASSOCIATION 2 Liberty Avenue Carlisle, PAl 70 13 .' SHORT DESCRIPTION IMPROVEMENTS consist of a residential dwelling. BEING PREMISES: 1 South Second Street I'Jormleysburg, l'A 17043 SOLD as the property of DZEV AD BEGANOVIC and MEHO BEGANOVIC TAX PARCEL #47-20.1858 ,. WRIT OF EXECUTION and/or ATTACHMENT COMMONWEALTH OF PENNSYLVANIA) COUNTY OF CUMBERLAND) NO 04-565 Civil CIVIL ACTION ~ LAW TO THE SHERIFF OF CUMBERLAND COUNTY: To satisfy the debt, interest and costs due MORTGAGE ELECTRONIC REGISTRATION SYSTEMS, INC., Plaintiff (s) From DZEV AD BEGANOVIC AND MEHO BEGANOVIC (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 fro paying any debt to or for the account of the defendant (s) and from delivering any property of the defenda t (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 himlher that he/she has been added as a garnishee and is enjoined as above stated. Amount Due $90,464.95 Interest FROM 9/1103 TO 7/2/04 AT 7.1200% LL $.50 Atty's Comrn % Atty Paid $324.53 Plaintiff Paid Date: JULY 8, 2004 Due Prothy $1.00 Other Costs CURTIS R. LONG (Seal) Deputy 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 Real Estate Sale #27 On August 31, 2004 the Sheriff levied upon the defendant's interest in the real property situated in Wormleysburg Borough, Cumberland County, P A Known and numbered as I South Second Street, Wormleysburg, more fully described on Exhibit "A" filed with this writ and by this reference incorporated herein. Date: August 31, 2004 By:J (}~j,(LtJl Real Estate Deputy ,,1 'jV ,\1>.- SlHnd I, . . - '.~ \J 'J 1 (\ r 1- lZ <2 , , c lnr ij , j,~~' J.1I\~'"" i.J ",;JJU ceJ ~ i Attachment To Statement Of Value Re: Real Estate Transfer Tax Exemption for Property Foreclosed in e Name of Mortgage Electronic Recording Systems, Ine. ("MERS" Address: 1 South Second Street W ormlevsburg, P A 17043 MIN: #1000157-0001 031836-4 Docket # 04-565 CIVIL TERM Michael T. McKeever, Esquire hereby attests that he is an attorney acting on behalf of both MERS and COUNTRYWIDE HOME LOANS INC. ("Servicer"), and that the following statements are true to the best of his/her knowledge, information and belief: 1. That the Servicer is the beneficial owner of the mortgage and that MERS is acting as its agent; 2. That the Servicer is a member of MERS; 3. That the mortgage identification number (MIN) provided above is in fact the MIN that was assigned to the mortgage that was foreclosed on, Name:~"W\C'~ Michael T. McKeever, Esq. Date: December 22, 2004 REAL-ESTATESALENo.27 ' . Writ,No. 200i 56S _ . Clvlltenn",.: . Mortgage E!eclronlc ReglSlnitlOn Systems, Inc. . , :"'" .Va ";', , Ozwal(.SeganO,;Ic and '. , Meho 8egenovlc " . Atty: J=h Goldbeck . :'l:,~;.~~;' }ql~r;; ..;., AIL THAT" lllIa or paiceI of bind . and premises;! ":!YjI!( and1he ~~ I . aI the F."... line of Seco 1liQly':;'" ~ feet 10 a 'poin!; 1hel)ce ilL:an, EastJifdil.aioh along _ line pmIIeI with Fciry Streeteigbty-six(86) feet, more or lesS, to_point; " tbence in _ IlOItbcdy directj"", along Janas now or late of WiIliam.Lippett thirty-one (31) feet 10 _ e point on !he """""'" line of Feny Stteet; thence in a westedy (emmeoosIy staled on prior deeds as easterly) ~llII a10ng the soulhemline ofFeny Stree! ei8Jrty-six (86) feet, more or lesS, 10 _ point, the PIace of BEGINNING., . , HAVING llIEREON erected _ single frame dwelling bo~,'known as No. 1 South Second SlIeet, WonnIeysbmg, Penosjlvania. BEING TIlE SAME premises which Jeffrie A. Crossley and Cr.isten A. Crossley, bosband and .wife, by Deed dated June 19,2002, granted and conveyed IlIltl' Moho Beganovic, manied man. and DzevadBegllIlOvic, single man. borrower. REAL ESTATE SALE NO. 27 Writ No. 2004.565 Civil Mortgage Electronic Registration Systems. Inc. vs. Dzevad Beganovic and Meho Beganovic Atty.: Joseph Goldbeck Legal DescIiption: ALL TIiAT CERTAIN tract or par- cel of land and premises. situate, lying and being in the Borough of Wormleysburg in the County of Cumberland and Commonwealth of Pennsylvania: more particularly de- scIibed as follows: BEGINNING at a point at the southeast corner of Second and Feny Streets; thence in a southerly direction along the eastern line of Second Street thirty-one (31) feet to a point: thence in an easterly direc- tion along a line parallel with Feny Street eighty-six (86) feet. more or less, to a point; thence in a north- erly direction along lands now or late ofWiIliam Lippert thirty.one (31) feet to a point on the southern line of Fer- I)' Street; thence in a westerly (er- roneously stated on pIior deeds as easterly) direction along the south- ern line of Ferry Street eighty. six (86) feet, more or less. to a point, the place of Beginning. HAVING TIIEREON ERECTED a single frame dwelling house, known as No. 1 South Second Street, Worm- leysburg. Pennsylvania. BEING the same premises which JeffIie A. Crossley and CIisten A. Crossley, husband and wife, by deed dated June 19. 2002, granted and conveyed unto Meho Beganovic, marIied man and Dzevad Begano- vic, single man. borrower. . 04- 5(p6 - THE PATRIOT NEWS THE SUNDAY PATRIOT NEWS Proof of Publication Under Act No. 587, Approved May 16, 1929 Commonwealth of Pennsylvania, County of Dauphin} ss 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 19th and 26th day(s) of October and the 2nd day(s) of November 2004. That neither he nor said Company is interested in the subject matter of said printed notice or advertising, and that all of the allegations of this statement as to the time, place and character of publication are true; and That he has personal knowledge of the facts aforesaid and is duly authorized and empowered to verify this statement on behalf of The Patriot -News Co. aforesaid by virtue and pursuant to a resolution unanimously passed and adopted severally by the stockholders and board of directors of the said Company and subsequently duly recorded in the office for the Recording of Deeds in and for said County of Dauphin in Miscellaneous Book "M", Volume 14, Page 317. PUBLICATION COPY SALE#27 REAL ESTATE SALE No. 27 Writ No. 2004-565 Civil Term Mortgage Electronic RegiStration Systems, Inc. Vs Dzevak Beganovic and Meho Beganovic Atty: Joseph Goldbeck DESCRIPTION AIL THAT CERTAIN tract or parcel of land and premises, situate, lying and being in the Borough of Wormleysburg in the County of Cumberland and _ Commonwealth of Pennsylvania, more particularly described as follows: BEGINNING at a point at the southeast corner of Second and Ferry Streets; thence in a southerly direction along the Eastern line of Second Street thirty-one (31) feet to a point; thence in an Easterly direction along a line parallel with Ferry Street eighty-six (86) feet, more or less, to a point; thence in a northerly direction along lands now or late of William Lippert thirty-one (31) feet to a been duly pard. Sworn to and subscribed . - - .. -... 17th day of L NOTARIAL SEAL Terry L. Russell, Notary City of Harrisburg, Dauphin y Commission Expires June 6, 2006 NOTARt. PUBLIC Member, PonnsylvanlaAssoclalionc Nytarl o ssion expires June 6, 2006 CUMBERLAND COUNTY SHERIFFS OFFICE CUMBERLAND COUNTY COURTHOUSE CARLISLE, PA. 17013 Statement of Advertising Costs To THE PATRIOT -NEWS CO. For publishing the notice or publication attached hereto on the above stated dates Publisher's Receipt for Advertising Cost {sher of The Patriot -News and The Sunday Patriot -News, newspapers of general edge receipt of the aforesaid notice and publication costs and certifies that the same have 232.51 By PROOF OF PUBLICATION OF NOTICE IN CUMBERLAND LAW JOURNAL (Under Act No. 587, approved May 16, 1929), P. L.1784 STATE OF PENNSYLVANIA : ss. COUNTY OF CUMBERLAND : Lisa Marie Coyne, Esquire, Editor of the Cumberland Law Journal, of the County and State aforesaid, being duly sworn, according to law, deposes and says that the Cumberland Law Journal, a legal periodical published in the Borough of Carlisle in the County and State aforesaid, was established January 2, 1952, and designated by the local courts as the official legal periodical for the publication of all legal notices, and has, since January 2, 1952, been regularly issued weekly in the said County, and that the printed notice or publication attached hereto is exactly the same as was printed in the regular editions and issues of the said Cumberland Law Journal on the following dates, viz: OCTOBER 8, 15, 22, 2004 Affiant further deposes that he is authorized to verify this statement by the Cumberland Law Journal, a legal periodical of general circulation, and that he is not interested in the subject matter of the aforesaid notice or advertisement, and that all allegations in the foregoing statements as to time, place and character of publication are true. REAL ESTATE SALE NO. 27 Writ No. 2004-565 Civil Mortgage Electronic Registration Systems, Inc. vs. Dzevad Beganovic and Meho Beganovic Atty.: Joseph Goldbeck Legal Description: ALL THAT CERTAIN tract or par- cel of land and premises, situate, lying and being in the Borough of Wormleysburg in the County of Cumberland and Commonwealth of Pennsylvania; more particularly de- scribed as follows: BEGINNING at a point at the southeast corner of Second and Ferry Streets; thence in a southerly direction along the eastern line of Second Street thirty-one (31) feet to 1 a point; thence in an easterly direc- tion along a line parallel with Ferry Lisa Mari Coyne, Editor WORN TO AND SUBSCRIBED before me this 22 day of OCTOBER 2004 NIMML SEAL LOIS E. SNYDER, Notary Public Carlisle Boro, Cumberland County My Commission Expires March 5, 2005