HomeMy WebLinkAbout08-2030GOLDBECK McCAFFERTY & McKEEVER
BY: MICHAEL T. MCKEEVER
ATTORNEY I.D. #56129
SUITE 5000 -MELLON INDEPENDENCE CENTER
701 MARKET STREET
PHILADELPHIA, PA 19106
(866) 413-2311
WWW.GOLDBECKLAW.COM
ATTORNEY FOR PLAINTIFF
CITIMORTGAGE, INC., SB/M CITIFINANCIAL
MORTGAGE CO., INC.
1111 Northpoint Drive
Building 4, Suite 100
Coppell, TX 75019-3931
Plaintiff
vs.
TINA MARIE YOUNG
Mortgagor and Real Owner
231 Walton Street
Lemoyne, PA 17043
IN THE COURT OF COMMON PLEAS
OF CUMBERLAND COUNTY
CIVIL ACTION - LAW
ACTION OF MORTGAGE FORECLOSURE
Term CjVi I
No. Term
Defendant
CIVIL ACTION: MORTGAGE
(FORECLOSURE
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 you fail to do so the case may proceed without you and a
judgment may be entered against you by the Court without further notice for any money claim in the Complaint
of for any other claim or relief requested by the Plaintiff. You may lose money or property or other rights
important to you.
YOU SHOULD TAKE THIS PAPER TO YOUR LAWYER AT ONCE. IF YOU DO NOT HAVE A
LAWYER OR CANNOT AFFORD ONE, GO TO OR TELEPHONE THE OFFICE SET FORTH BELOW.
THIS OFFICE CAN PROVIDE YOU WITH INFORMATION ABOUT HIRING A LAWYER.
IF YOU CANNOT AFFORD TO HIRE A LAWYER, THIS OFFICE MAY BE ABLE TO PROVIDE
YOU WITH INFORMATION ABOUT AGENCIES THAT MAY OFFER LEGAL SERVICES TO ELIGIBLE
PERSONS AT A REDUCED FEE OR NO FEE.
CUMBERLAND COUNTY BAR ASSOCIATION
2 Liberty Avenue
Carlisle, PA 17013
LEGAL SERVICES INC
8 Irvine Row
Carlisle, PA 17013
717-243-9400
AVISO
LE HAN DEMANDADO A USTED EN LA CORTE. SI DESEA DEFENDERSE CONTRA LAS
QUEJAS PERESENTADAS, ES ABSOLUTAMENTE NECESSARIO QUE USTED RESPONDA DENTRO
DE 20 DIAS DESPUES DE SER SERVIDO CON ESTA DEMANDA Y AVISO. PARA DEFENDERSE ES
NECESSARIO QUE USTED, O SU ABOGADO, REGISTRE CON LA CORTE EN FORMA ESCRITA, EL
PUNTO DE VISTA DE USTED Y CUALQUIER OBJECCION CONTRA LAS QUEJAS EN ESTA
DEMANDA.
RECUERDE: SI USTED NO REPONDE A ESTA DEMANDA, SE PUEDE PROSEGUIR CON EL
PROCESO SIN SU PARTICIPACION. ENTONCES, LA COUTE PUEDE, SIN NOTIFICARIO, DECIDIR A
FAVOR DEL DEMANDANTE Y REQUERIRA QUE USTED CUMPLA CON TODAS LAS PROVISIONES
DE ESTA DEMANDA. POR RAZON DE ESA DECISION, ES POSSIBLE QUE USTED PUEDA PERDER
DINERO, PROPIEDAD U OTROS DERECHOS IMPORTANTES.
USTED DEBE LLEVAR ESTE PAPEL A SU ABOGADO ENSEGUIDA. SI USTED NO TIENE UN
ABOGADO, VAYA O LLAME POR TELEFONO LA OFICINA FIJADA AQUI ABAJO. ESTA OFICINA
PUEDE PROVEERE CON INFORMACION DE COMO CONSEUIR UN ABOGADO.
SI USTED NO PUEDE PAGARLE A UN ABOGADO, ESTA OFICINA PUEDE PROVEERE
INFORMACION ACERCA AGENCIAS QUE PUEDAN OFRECER SERVICIOS LEGAL A PERSONAS
ELIGIBLE AQ UN HONORARIO REDUCIDO O GRATIS.
CUMBERLAND COUNTY BAR ASSOCIATION
2 Liberty Avenue
Carlisle, PA 17013
LEGAL SERVICES INC
8 Irvine Row
Carlisle, PA 17013
717-243-9400
THIS FIRM IS A DEBT COLLECTOR AND WE ARE ATTEMPTING TO COLLECT
A DEBT OWED TO OUR CLIENT. ANY INFORMATION OBTAINED FROM YOU
WILL BE USED FOR THE PURPOSE OF COLLECTING THE DEBT.
Resources available for Homeowners in Foreclosure
ACT NOW!
Even though your lender (and our client) has filed an Action of Mortgage Foreclosure against you, you
still may be able to SAVE YOUR HOME FROM FORECLOSURE.
1). Call an attorney. For referrals to a qualified attorney call either of the following numbers: or 717-
243-9400.
2). Call the Consumer Credit Counseling Agency at 1-800-989-2227 for free counseling.
3). Visit HUD'S website www.hud.gov for Help for Homeowners Facing the Loss of Their Homes.
4). Pennsylvania Housing Finance Agency also offers other loan programs that may assist homeowners
in default. Please See the PHFA website ht?pt ://www.Dhfa.org/consumers/homeowners/real asnx.
5). Call the Plaintiff (your lender) at 800-422-1498 and ask to speak to someone about Loss Mitigation
or Home Retention options.
6). Call or contact our office to request the amount to bring the account current, or payoff the mortgage
or request a Loan Workout / Home Retention Package. Call our toll free number at 1-866413-2311 or via email
at homeretention@goldbecklaw.com. Call Seth at 215-825-6329 or fax 215-825-6429. The figure and/or
package you requested will be mailed to the address that you request or faxed if you leave a message with that
information. The attorney in charge of our firm's Homeowner Retention Department is David Fein who can be
reached at 215-825-6318 or Fax: 215-825-6418. Please reference our Attorney File Number of 6452417C.
Para informacion en espanol puede communicarse con Loretta al 215-825-6344.
This Action of Mortgage Foreclosure will continue unless you take action to stop it.
COMPLAINT IN MORTGAGE FORECLOSURE
1. Plaintiff is CITIMORTGAGE, INC., SB/M CITIFINANCIAL MORTGAGE CO., INC., 1111
Northpoint Drive, Building 4, Suite 100, Coppell, TX 75019-3931.
2. The names and addresses of the Defendant is TINA MARIE YOUNG, 231 Walton Street, Lemoyne, PA
17043, who is the mortgagor and real owner of the mortgaged premises hereinafter described.
3. On February 03, 2004 mortgagors made, executed and delivered a mortgage upon the Property
hereinafter described to CHAMPION MORTGAGE, A DIVISION OF KEY BANK USA, N.A., which
mortgage is recorded in the Office of the Recorder of Deeds of Cumberland County as Book 1854, Page
130. The mortgage has been assigned to: CITIFINANCIAL MORTGAGE CO., INC. by assignment of
Mortgage September 27, 2004 as Book 711, Page 4164. The Mortgage and assignment(s) are matters of
public record and are incorporated by this reference in accordance with Pennsylvania Rule of Civil
Procedure 1019(g); which Rule relieves the Plaintiff from its obligation to attach documents to pleadings
if those documents are matters of public record.
4. The Property subject to the Mortgage is more fully described in the legal description set forth as Exhibit
"A" ("Property").
5. The mortgage is in default because the monthly payments of principal and interest are due and unpaid
for December 10, 2007 and each month thereafter and by the terms of the Mortgage, upon default in
such payments for a period of one month or more, the entire principal balance and all interest due and
other charges are due and collectible.
6. The following amounts are due to Plaintiff on the Mortgage:
Principal Balance ................................ $55,051.91
....................................................
Interest from 11/10/2007 through 03/31/2008 at 10.7500% .....................$2,350.92
Per Diem interest rate at $16.44
Reasonable Attorney's Fee at 5% of Principal Balance
as more fully explained in the next numbered paragraph ...................$2,752.60
Late Charges from 12/10/2007 to 03/31/2008 .............................................$242.68
Costs of suit and Title Search ......................................................................$900.00
Suspense ....................................................................................................... -$26.90
Escrow ........................................................................................................ -$679.76
$60,591.45
7. If the Mortgage is reinstated prior to a Sheriff's Sale, the Attorney's Fees set forth above may be less
than the amount demanded based on work actually performed. The Attorney's Fees requested are in
conformity with the Mortgage and Pennsylvania law. Plaintiff is entitled to collect Attorney's fees of up
to 5% of the remaining principal balance in the event the Property is sold to a third party purchaser at
Sheriffs Sale or if the complexity of the action requires additional fees in excess of the amount
demanded in the Action.
8. Plaintiff is not seeking a judgment of personal liability (or an "in personam" judgment) against the
Defendant in this Action but reserves its right to bring a separate Action to establish that right, if such
right exists. If Defendant has received a discharge of their personal liability in a Bankruptcy proceeding,
this Action of Mortgage Foreclosure is, in no way, an attempt to re-establish the personal liability that
was discharged in Bankruptcy, but only to foreclose the Mortgage and sell the Property pursuant to
Pennsylvania law.
9. Notice of Intention to Foreclose and a Notice of Homeowners' Emergency Mortgage Assistance has
been sent to Defendant by certified and regular mail, as required by Act 160 of 1998 of the
Commonwealth of Pennsylvania, on the date(s) set forth in the true and correct copy of such notice(s)
attached hereto as Exhibit "B". The Defendant have not had the required face-to-face meeting within
the required time and Plaintiff has no knowledge of any such meeting being requested by the Defendant
through the Plaintiff, the Pennsylvania Housing Finance Agency, or any appropriate Consumer Credit
Counseling Agency.
WHEREFORE, Plaintiff demands a de terns judgment in mortgage foreclosure in the sum of $60,591.45,
together with interest at the rate of $16.44, per day and other expenses, costs and charges incurred by the
Plaintiff which are properly chargeable in accordance with the terms of the Mortgage and Pennsylvania law
until the Mortgage is paid in full, and for the foreclosure of the Mortgage and Sheriff s Sale of the Property.
By:_ UWT wk?w
GOLDBECK McCAFFERTY & Mc EEVER
BY: MICHAEL T. MCKEEVER, ESQUIRE
ATTORNEY FOR PLAINTIFF
VERIFICATION
I, Stanley Anya, as the representative of the Plaintiff corporation within named do hereby
verify that I am authorized to and do make this verification on behalf of the Plaintiff corporation and
the facts set forth in the foregoing Complaint are true and correct to the best of my knowledge,
information and belief. I understand that false statements therein are made subject to the penalties of
18 Pa. C.S. 4(904 relating to unsworn falsification to authorities.
Date: ) L7" ??
5001982217 TINA MARIE YOUNG
E.xhibit.A
Exhibit A
LEGAL DESCRIPTION
ALL THAT CERTAIN LOT OR GROUND SITUTEIN THE BOROUGH OF
LEMOYNE, FORMERLY LOWER ALLEN TOWNSHIP, COUNTY OF
CUMBERLAND AND STATE OF PENNSYLVANIA, BOUNDED AND DESCRIBED
AS FOLLOWS, TO WIT:
BEGINNING AT A POINT ON THE NORTHERN LINE OF WALTON STREET
AT THE EASTERN LINE OF LOT NO. 63 ON THE HEREINAFTER
MENTIONED PLAN OF LOTS; THENCE NORTHWARDLY ALONG THE LINE
OF SAID LOT TWO HUNDRED (200) FEET TO A POINT; THENCE
EASTWARDLY PARALLEL WITH WALTON STREET ONE HUNDRED (100)
FEET TO THE WESTERN LINE OF LOT NO. 65 ON SAID PLAN; THENCE
SOUTHWARDLY BY SAID LOT TWO HUNDRED (200) FEET TO WALTON
STREET, AND THENCE WESTWARDLY ALONG WALTON STREET ONE
HUNDRED (100) FEET TO THE PLACE OF BEGINNING.
EXCEPTING THEREFROM THAT CERTAIN PIECE OR PARCEL OF LAND
SITUATE IN THE BOROUGH OF LEMOYNE (FORMERLY LOWER ALLEN
TOWNSHIP), CUMBERLAND COUNTY, PENNSYLVANIA, BEING MORE
PARTICULARLY BOUNDED AND DESCRIBED AS FOLLOWS, TO WIT:
BEGINNING AT AN IRON PIN ON THE NORTHERN SIDE OF.WALTON
STREET AT THE DIVIDING LINE BETWEEN LOTS NOS. 64A AND 64B
ON THE HEREINAFTER MENTIONED PLAN OF LOTS; THENCE ALONG
SAID DIVIDING LINE, NORTH 31 DEGREES EAST, A DISTANCE OF
TWO HUNDRED (200) FEET TO AN IRON PIN; THENCE NORTH 59
DEGREES EAST, A DISTANCE OF FIFTY (50) FEET TO AN IRON PIN
AT THE DIVIDING LINE BETWEEN LOTS NOS. 64B AND 65 ON THE
HEREINAFTER MENTIONED PLAN; THENCE ALONG THE NORTHERN SIDE
OF WALTON STREET, SOUTH 59 DEGREES WEST, A DISTANCE OF
FIFTY (50) FEET TO AN IRON PIN, THE POINT OR PLACE OF
BEGINNING. CONTAINING TEN THOUSAND (10,000) SQUARE FEET AND
BRING LOT NO. 64B ON THE FINAL SUBDIVISION PLAN FOR DICE L.
A14D PAULINE E. YOUNG DATED NOVEMBER 8, 1989.
ADDRESS: 231. WALTON ST.; LEMOYNR, PA 17043.
?hifi. it (B
ACT 91 NOTICE
TAKE ACTION TO SAVE
YOUR HOME FROM
FORECLOSURE
Date: February 12, 2008
TO: Tina Marie Young
231 Walton St
Lemoyne, PA 17043
THIS FIRM IS A DEBT COLLECTOR ATTEMPTING TO COLLECT A DEBT. THIS NOTICE IS
SENT TO YOU IN AN ATTEMPT TO COLLECT THE INDEBTEDNESS REFERRED TO HEREIN
AND ANY INFORMATION OBTAINED FROM YOU WILL BE USED FOR THAT PURPOSE. IF
YOU HAVE PREVIOUSLY RECEIVED A DISCHARGE IN BANKRUPTCY, THIS
CORRESPONDENCE IS NOT AND SHOULD NOT BE CONSTRUED TO BE AN ATTEMPT TO
COLLECT A DEBT, BUT ONLY ENFORCEMENT OF A LIEN AGAINST PROPERTY.
This is an official notice that the mortgage on our home is in default and the lender intends to foreclosure.
Specific information about the nature of the default is provided in the attached pages
The HOMEOWNER'S MORTGAGE ASSISTANCE PROGRAM HEMAP may be able to hel to save
your home. This Notice explains how the program works
To see if HEMAP can help, ou must MEET WITH A CONSUMER CREDIT COUNSELING AGENCY
WITHIN 33 DAYS FROM THE DATE OF THIS NOTICE. Take this Notice with you when you meet the
Counseling Agency.
The name address and hone number of Consumer Credit Counseling Agencies serving our Coun are
I-q
listed at the end of this Notice. If You have an uestions you may call the Pennsylvania Housin Finance
Agency toll free at 1-800-342-2397 (Persons w
ith impaired hearing can call (717) 780-1869).
This Notice contains important legal information. If you have any questions, representatives at the
Consumer Credit Counseling Agency may be able to help explain it. You may also want to contact an
attorney in your area. The local bar association may be able to help you find a lawyer.
LA NOTIFICACION EN ADJUNTO ES DE SUMA IMPORTANCIA, PUEDE AFECTA SU DERECHO
A CONTINUAR VIVIENDO EN SU CASA. SI NO COMPRENDE EL CONTENIDO DE ESTA
NOTIFICACION OBTENGA UNA TRADUCCION WMEDITAMENTE LLAMANDO ESTA
AGENCIA (PENNSYLVANIA HOUSING FINANCE AGENCY) SIN CARGOS AL NUMERO
MENCIONADO ARRIBA. PUEDES SER ELEGIBLE PARA UN PRESTAMO POR EL PROGRAMA
LLAMADO "HOMEOWNERS EMERGENCY MORTGAGE ASSISTANCE PROGRAM" EL CUAL
PUEDE SALVAR SU CASA DE LA PERDIDA DEL DERECHO A REDIMAR SU HIPOTECA.
FC-1700-PHS CTB ACT 91 PA Breach
Rev.05/26/2005
STATEMENTS OF POLICY
HOMEOWNER'S NAME (S): Tina Marie Young
PROPERTY ADDRESS: 231 Walton St, Lemoyne, PA 17043
LOAN ACCT. NO.: 5001982217
ORIGINAL LENDER: Citifmancial Mortgage Company, Inc.
CURRENT LENDER/SERVICER: Citifinancial Mortgage Company, Inc.
HOMEOWNER'S EMERGENCY MORTGAGE ASSISTANCE PROGRAM
YOU MAY BE ELIGIBLE FOR FINANCIAL ASSISTANCE WHICH CAN SAVE YOUR HOME
FROM FORECLOSURE AND HELP YOU MAKE FUTURE MORTGAGE PAYMENTS
IF YOU COMPLY WITH THE PROVISIONS OF THE HOMEOWNER'S EMERGENCY MORTGAGE
ASSISTANCE ACT OF 1983 (THE "ACT"), YOU MAY BE ELIGIBLE FOR EMERGENCY MORTGAGE
ASSISTANCE.
• IF YOUR DEFAULT HAS BEEN CAUSED BY CIRCUMSTANCES BEYOND YOUR CONTROL,
• IF YOU HAVE A REASONABLE PROSPECT OF BEING ABLE TO PAY YOUR MORTGAGE
PAYMENTS, AND
• IF YOU MEET OTHER ELIGIBILITY REQUIREMENTS ESTABLISHED BY THE
PENNSYLVANIA HOUSING FINANCE AGENCY.
TEMPORARY STAY OF FORECLOSURE-Under the Act, you are entitled to a temporary stay of
foreclosure on your mortgage for thirty three (33) days from the date of this Notice. During that time you
must arrange and attend a face-to-face meeting with one of the consumer credit counseling agencies listed
at the end of this Notice. THIS MEETING MUST OCCUR WITHIN THE NEXT (33) DAYS IF YOU
DO NOT APPLY FOR EMERGENCY MORTGAGE ASSISTANCE YOU MUST BRING YOUR
MORTGAGE UP TO DATE. THE PART OF THIS NOTICE CALLED "HOW TO CURE YOUR
MORTGAGE DEFAULT" EXPLAINS HOW TO BRING YOUR MORTGAGE UP TO DATE.
CONSUMER CREDIT COUNSELING AGENCIES-If you meet with one of the consumer credit
counseling agencies listed at the end of this notice the lender may NOT take action against you for thirty
30 days after the date of this meetine The names addresses and telephone numbers of designated
consumer credit counseling agencies encies for the coup or which the pro is located are set forth at the end
of this Notice. It is only necessary to schedule one face-to-face meeting. Advise your lender immediately
of your intentions.
APPLICATION FOR MORTGAGE ASSISTANCE-Your mortgage is in a default for the reasons set forth
later in this Notice (see following pages for specific information about the nature of your default.) If you
have tried and are unable to resolve this problem with the lender, you have the right to apply for financial
assistance from the Homeowner's Emergency Mortgage Assistance Program. To do so, you must fill out,
sign and file a completed Homeowner's Emergency Assistance Program Application with one of the
designated consumer credit counseling agencies listed at the end of this Notice. Only consumer credit
counseling agencies have applications for the program and they will assist you in submitting a complete
application to the Pennsylvania Housing Finance Agency. Your application MUST be filed or postmarked
within thirty (30) days of your face-to-face meeting.
YOU MUST FILE YOUR APPLICATION PROMPTLY. IF YOU FAIL TO DO SO OR IF YOU
DO NOT FOLLOW THE OTHER TIME PERIODS SET FORTH IN THIS LETTER,
FORECLOSURE MAY PROCEED AGAINST YOUR HOME IMMEDIATELY AND YOUR
APPLICATION FOR MORTGAGE ASSISTANCE WILL BE DENIED.
FC-1700-PHS CTB ACT 91 PA Breach Rev.05/26/2005
AGENCY ACTION-Available funds for emergency mortgage assistance are very limited. They will be
disbursed by the Agency under the eligibility criteria established by the Act. The Pennsylvania Housing
Finance Agency has sixty (60) days to make a decision after it receives your application. During that time,
no foreclosure proceedings will be pursued against you if you have met the time requirements set forth
above. You will be notified directly by the Pennsylvania Housing Finance Agency of its decision on your
application.
NOTE: IF YOU ARE CURRENTLY PROTECTED BY THE FILING OF A PETITION IN
BANKRUPTCY, THE FOLLOWING PART OF THIS NOTICE IS FOR INFORMATION
PURPOSES ONLY AND SHOULD NOT BE CONSIDERED AS AN ATTEMPT TO COLLECT
THE DEBT.
(If you have filed bankruptcy you can still apply for Emergenev MartoavP Aawleto+...n
HOW TO CURE YOUR MORTGAGE DEFAULT Brig it Lip to date).
NATURE OF THE DEFAULT-The MORTGAGE debt held by the above lender on your property located
at: 231 Walton St, Lemoyne, PA 17043 IS SERIOUSLY IN DEFAULT because:
A. YOU HAVE NOT MADE MONTHLY MORTGAGE PAYMENTS for the following months and the
following amounts are now past due: Start/End: 12/10/07 through 2/10/08 at $723.10 for 12/10/07 then
$723.10 for 1/10/08 then $673.10 for 2/10/08.
Monthly Payments Plus Late Charges Accrued $2119.30
NSF: $0.00
Inspections: $0.00
BPO: $0.00
Speed Pay: $0.00
Uncollected Credit Insurance: $0.00
Uncollected Late Charges: $92.68
Taxes: $0.00
Late Fee Income: $0.00
Total Amount to Cure Default $2211.98
B. YOU HAVE FAILED TO TAKE THE FOLLOWING ACTIONS (Do not use if not applicable): N/A
HOW TO CURE THE DEFAULT-You may cure the default within THIRTY (30) DAYS of the
date of this notice BY PAYING THE TOTAL AMOUNT PAST DUE TO THE LENDER,
WHICH IS $2211.98, PLUS ANY MORTGAGE PAYMENTS AND LATE CHARGES WHICH
BECOME DUE DURING THE THIRTY (30) DAY PERIOD. As of the date of this letter, you
owe the amount specified above. Because of interest, late charges, and other charges that may vary
from day to day, the amount due on the day that you pay may be greater. Hence, if you pay the
amount shown above, an adjustment may be necessary after we receive your check, in which event
we will inform you before depositing the check for collection. For further information, write the
undersigned or call (800) 422-1498. Payments must be made either by cash cashier's check.
certified check or money order made payable and sent to Citifinancial Mortgage Co anInc.
4050 Regent Blvd MS-N1B-165 Irving TX 75063 Attention: Department ATM. You can cure
any other default by taking the following action within THIRTY (30) DAYS of the date of this
letter. (Do not use if not applicable N/A
IF YOU DO NOT CURE THE DEFAULT-If you do not cure the default within THIRTY (30) DAYS of
the date of this Notice, the lender intends to exercise its rights to accelerate the mort a e debt. The means
that the entire outstanding balance of this debt will be considered due immediately and you may lose the
chance to pay the mortgage in monthly installments. If full payment of the total amount past due is not
made within THIRTY (30) DAYS, the lender also intends to instruct its attorney to start legal action to
foreclosure upon your
mortgage property
FC-1700-PHS CTB ACT 91 PA Breach
Rev.05/26/2005
IF THE MORTGAGE IS FORECLOSED UPON- The mortgaged property will be sold by the Sheriff to
pay off the mortgage debt. If the lender refers your case to its attorneys, but you cure the delinquency
before the lender begins legal proceedings against you, you will still be required to pay the reasonable
attorney's fees that were actually incurred, up to $50.00. However, if legal proceedings are started against
you, you will have to pay all reasonable attorney's fees actually incurred by the lender even if they exceed
$50.00. Any attorney's fees will be added to the amount to the lender, which may also include other
reasonable costs. If you cure the default within the THIRTY (30) DAY period you will not be required to
pay attorney's fees.
OTHER LENDER REMEDIES-The lender may also sue you personally for the unpaid principal balance
and all other sums due under the mortgage.
RIGHT TO CURE THE DEFAULT PRIOR TO SHERIFF'S SALE-If you have not cured the default
within the THIRTY (30) DAY period and foreclosure proceedings have begun, you still have the right to
cure the default and prevent the sale at any time 0 to one hour before the Sheriff's Sale You may do so
b paykg the total amount then past due plus an late or other char es then due reasonable attorney's fees
and costs connected with the foreclosure sale and an other costs connected with the Sheriff's Sale as
specified in writing by the lender and by performing any other requirements under the mortgage Curing
your default in the manner set forth in this notice will restore your mortgage to the same position as if you
had never defaulted.
EARLIEST POSSIBLE SHERIFF'S SALE DATE-It is estimated that the earliest date that such a Sheriff's
Sale of the mortgage property could be held would be approximately SIX (6) MONTHS from the date of
this Notice. A notice of the actual date of the Sheriff's Sale will be sent to you before the sale. Of course,
the amount needed to cure the default will increase the longer you wait. You may find out at any time
exactly what the required payment or action will be by contacting the lender.
HOW TO CONTACT THE LENDER: Citifinancial Mortgage Company, Inc.
4050 Regent Blvd.
Irving, TX 75063
Attn: Department ATM
MS-N1B-165
(800) 422-1498
(Fax#) 972-657-1636
EFFECT OF SHERIFF'S SALE-You should realize that a Sheriff's Sale will end your ownership of the
mortgaged property and your right to occupy it. If you continue to live in the property after the Sheriff's
Sale, a lawsuit to remove you and your furnishings and other belongings could be started by the lender at
any time.
ASSUMPTION OF MORTGAGE-You may or X may not (CHECK ONE) sell or transfer
your home to a buyer or transferee who will assume the mortgage debt, provided that all the outstanding
payments, charge and attorney's fees and cost are paid prior to or at the sale and that the other requirements
of the mortgage are satisfied.
FC-1700-PHS CTB ACT 91 PA Breach Rev.05/26/2005
YOU MAY ALSO HAVE THE RIGHT:
• TO SELL THE PROPERTY TO OBTAIN MONEY TO PAY OFF THE MORTGAGE DEBT OR TO
BORROW MONEY FROM ANOTHER LENDING INSTITUTION TO PAY OFF THIS DEBT.
• TO HAVE THIS DEFAULT CURED BY ANY THIRD PARTY ACTING ON YOUR BEHALF.
• TO HAVE THE MORTGAGE RESTORED TO THE SAME POSITION AS IF NO DEFAULT HAD
OCCURRED, IF YOU CURE THE DEFAULT. (HOWEVER, YOU NOT HAVE THIS RIGHT TO
CURE YOUR DEFAULT MORE THAN THREE TIMES IN ANY CALENDAR YEAR.)
• TO ASSERT THE NONEXISTENCE OF A DEFAULT IN ANY FORECLOSURE PROCEEDING
OR ANY OTHER LAWSUIT INSTITUTED UNDER THE MORTGAGE DOCUMENTS.
• TO ASSERT ANY OTHER DEFENSE YOU BELIEVE YOU MAY HAVE TO SUCH ACTION BY
THE LENDER
• TO SEEK PROTECTION UNDER THE FEDERAL BANKRUPTCY LAW.
CONSUMER CREDIT COUNSELING AGENCIES SERVING YOUR COUNTY IS ATTACHED
If this is the first notice that you have received from this office, be advised that: You may dispute the
validity of the debt or any portion thereof. If you do so in writing within thirty (30) days from the
receipt of this letter, this firm will obtain and provide you with written verification thereof; otherwise
the debt will be assumed to be valid. Likewise if requested in writing within thirty (30) days from
receipt of this letter, the firm will send you the name and address of the original creditor if different
from above.
Very truly yours,
Phelan Hallinan & Schmieg, LLP
On Behalf of Citifmancial Mortgage Company, Inc.
By:
Francis S. linan, Esquire
PHS: gpd
Cc: Citifinancial Mortgage Company, Inc.
Attn: Department ATM Account No.: 5001982217
Mailed by I' Class Mail and by Certified Mail No: 7007 2680 0001 3588 6599
FC-1700-PHS CTB ACT 91 PA Breach Rev.05/26/2005
06 is
j
?i
O
SHERIFF'S RETURN - REGULAR
CASE NO: 2008-02030 P
COMMONWEALTH OF PENNSYLVANIA:
COUNTY OF CUMBERLAND
CITIMORTGAGE INC
VS
YOUNG TINA MARIE
TIMOTHY BLACK , Sheriff or Deputy Sheriff of
Cumberland County,Pennsylvania, who being duly sworn according to law,
says, the within COMPLAINT - MORT FORE was served upon
YOUNG TINA MARIE the
DEFENDANT
, at 1345:00 HOURS, on the 2nd day of April , 2008
at 231 WALTON STREET
LEMOYNE, PA 17043 by handing to
KATIE ADAMS, ROOMMATE, ADULT IN CHARGE
a true and attested copy of COMPLAINT - MORT FORE together with
and at the same time directing Her attention to the contents thereof.
Sheriff's Costs:
Docketing 18.00
Service 16.00
Affidavit .00
Surcharge 10.00
.00
41 Io1aF ? 44.00
Sworn and Subscibed to
before me this
of
So Answers:
R. Thomas Kline
04/03/2008
GOLDBECK MCCAFFERTY MCKEEVER
By:
day eputy Sheriff
A. D.
In the Court of Common Pleas of Cumberland County
CITIMORTGAGE, INC., S/B/M CITIFINANCIAL
MORTGAGE CO., INC.
1111 Northpoint Drive
Building 4, Suite 100
Coppell, TX 75019-3931
Plaintiff
vs.
TINA MARIE YOUNG
(Mortgagor(s) and Record Owner(s))
231 Walton Street
Lemoyne, PA 17043
No. 08-2030
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 in favor of Plaintiff and against TINA MARIE YOUNG by default for want of an Answer.
Assess damages as follows:
$61,166.85
Debt
Interest from 05/06/2008 to Date of Sale
Total
(Assessment of Damages attached)
I CERTIFY THAT FOREGOING ASSESSMENT OF DAMAGES IS FOR SPECIF ED AM NTS ALLEGED TO
BE DUE IN THE COMPLAINT AND IS CALCULABLE AS A SUM CERTAIN F O TH COMPLAINT.
I certify that written notice of the intention to file this praecipe was mailed or delivered t pa against whom judgment
is to be entered and to his attorney of record, if any, after the default occurred and at lea t t da s rior to the date of the
filing of this praecipe. A copy of the notice is attached. R.C.P. 237.1
Michael T. Mc
Attorney for ainti
I.D. #56129
AND NOW Mom CQA , CZ009 , Judgment is entered in favor of
CITIMORTGAGE, INC., SB/M TIFINANCIAL MORTGAGE CO., INC. and against TINA MARIE YOUNG by default
for want of an Answer and damages assessed in the sum of $61,166.85 as per t 'above certification. a . _ 7
Pr thonotary
64524FC
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: April 23, 2008
TO:
TINA MARIE YOUNG
231 Walton Street
Lemoyne, PA 17043
CITIMORTGAGE, INC., S/B/M CITIFINANCIAL MORTGAGE
CO., INC.
1111 Northpoint Drive
Building 4, Suite 100
Coppell, TX 75019-3931
VS.
TINA MARIE YOUNG
(Mortgagor(s) and Record Owner(s))
231 Walton Street
Lemoyne, PA 17043
TO: TINA MARIE YOUNG
231 Walton Street
Lemoyne, PA 17043
Plaintiff
Defendant(s)
In the Court of
Common Pleas
of Cumberland County
CIVIL ACTION - LAW
Action of
Mortgage Foreclosure
Term
No. 08-2030
IMPORTANT NOTICE
YOU ARE IN DEFAULT BECAUSE YOU HAVE FAILED TO ENTER A WRITTEN APPEARANCE PERSONALLY
OR BY ATTORNEY AND FILE IN WRITING WITH THE COURT YOUR DEFENSES OR OBJECTIONS TO THE CLAIMS SET
FORTH AGAINST YOU. UNLESS YOU ACT WITHIN TEN (10) DAYS FROM THE DATE OF THIS NOTICE, A JUDGMENT
MAY BE ENTERED AGAINST YOU WITHOUT A HEARING AND YOU MAY LOSE YOUR PROPERTY OR OTHER
IMPORTANT RIGHTS. YOU SHOULD TAKE THIS PAPER TO YOUR LAWYER AT ONCE. IF YOU DO NOT HAVE A
LAWYER, GO TO OR TELEPHONE THE OFFICE SET FORTH BELOW. THIS OFFICE CAN PROVIDE YOU WITH
INFORMATION ABOUT HIRING A LAWYER. IF YOU CANNOT AFFORD TO HIRE A LAWYER, THIS OFFICE MAY BE
ABLE TO PROVIDE YOU WITH INFORMATION ABOUT AGENCIES THAT MAY OFFER LEGAL SERVICES TO ELIGIBLE
PERSONS AT A REDUCED FEE OR NO FEE.
CUMBERLAND COUNTY BAR ASSOCIATION
2 Liberty Avenue
Carlisle, PA 17013
LEGAL SERVICES INC
8 Irvine Row
Carlisle, PA 17013
717-243-9400
Michael T. McKeever
GOLDBECK McCAFFERTY & McKEEVER
BY: Michael T. McKeever, Esq.
Attorney for Plaintiff
Suite 5000 - 701 Market Street.
Philadelphia, PA 19106 215-825-6318
VERIFICATION OF NON-MILITARY SERVICE
The undersigned, as the representative for the Plaintiff
corporation within named do hereby verify that I am authorized
to make this verification on behalf of the Plaintiff corporation
and that the facts set forth in the foregoing verification of
Non-Military Service are true and correct to the best of my
knowledge, information and belief. I understand that false
statements therein are made subject to penalties of 18 Pa. C.S.
4904 relating to unsworn falsification to authorities.
1. That the above named Defendant, TINA MARIE YOUNG, is
about unknown years of age, that Defendant's last known
residence is 231 Walton Street, Lemoyne, PA 17043, and is
engaged in the unknown business located at u n wn address.
2. That Defendant is not in the Mil'tar or Naval Service
of the United States or its Allies, or otgerwise within the
provisions of the Soldiers' and Sailors' iv'1 elief Action of
Congress of 1940 and its Amendments.
Date:
GOLDBECK McCAFFERTY & McKEEVER
BY: Michael T. McKeever
Attorney I.D. #56129
Suite 5000 - Mellon Independence Center
701 Market Street
Philadelphia, PA 19106
215-627-1322
Attorney for Plaintiff
CITIMORTGAGE, INC., S/B/M CITIFINANCIAL
MORTGAGE CO., INC.
1111 Northpoint Drive
Building 4, Suite 100
Coppell, TX 75019-3931
Plaintiff
VS.
TINA MARIE YOUNG
(Mortgagor(s) and Record owner(s))
231 Walton Street
Lemoyne, PA 17043
Defendant(s)
IN THE COURT OF COMMON PLEAS
of Cumberland County
CIVIL ACTION LAW
ACTION OF MORTGAGE FORECLOSURE
No. 08-2030
ORDER FOR JUDGMENT
Please enter Judgment in favor of CITIMORTGAGE, INC., S/B/M ITIF CIAL MORTGAGE
CO., INC., and against TINA MARIE YOUNG for failure to file an Answ in th ab e action within (20) days
(or sixty (60) days if defendant is the United States of America) from the d e of s rvi e of the Complaint, in the
sum of $61,166.85.
Michael T. McKee,
Attorney for Plainti
I hereby certify that the above names are correct and that the preci elide e address of the judgment
creditor is CITIMORTGAGE, INC., SB/M CITIFINANCIAL MORTG CO., C. 1111 Northpoint Drive
Building 4, Suite 100 Coppell, TX 75019-3931 and that the name(s) an lajs? n ow dress(es) of the
Defendant(s) is/are TINA MARIE YOUNG, 231 Walton Street Lemoyne, 170 ;
GOLDBECK Mc ERTY & McKEEVER
BY: Michael T. Mc ever
Attorney for Plainti
ASSESSMENT OF DAMAGES
TO THE PROTHONOTARY:
Kindly assess the damages in this case to be as follows:
Principal Balance $55,051.91
Interest from 11/10/2007 through $2,926.32
05/05/2008
Reasonable Attorney's Fee $2,752.60
Late Charges $242.68
Costs of Suit and Title Search $900.00
Escrow Payments Due 5 X $0.00 $0.00
Suspense -$26.90
Escrow -$679.76
$61,166.85
GOLDBECK MICA TY & McKEEVER
BY: Michael T. McKeev r
Attorney for Plaintiff
AND NOW, this wand day of MQy 2008 damages ar'6assessed as above.
A 94
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'n
Rule of Civil Procedure No. 236 - Revised
IN THE COURT OF COMMON PLEAS
OF Cumberland COUNTY, PENNSYLVANIA
CIVIL ACTION - LAW
CITIMORTGAGE, INC., S/B/M CITIFINANCIAL MORTGAGE CO., INC.
1 111 Northpoint Drive
Building 4, Suite 100
Coppell, TX 75019-3931
Plaintiff
vs.
No. 08-2030
TINA MARIE YOUNG
(Mortgagors and Record Owner(s))
231 Walton Street
Lemoyne, PA 17043
Defendant(s)
THIS LAW FIRM IS A DEBT COLLECTOR AND WE ARE ATTEMPTING TO COLLECT A DEBT
OWED TO OUR CLIENT. ANY INFORMATION OBTAINED FROM YOU WILL BE USED FOR THE
PURPOSE OF COLLECTING THE DEBT.
NOTICE
Notice is given that a judgment in the above-captioned matter has been entered against you.
Curt Long
Prothonotary
By:
7- opety
If you have any questions concerning the above, please contact:
5?aa/og
Michael T. McKeever
Goldbeck McCafferty & McKeever
Suite 5000 - Mellon Independence Center
701 Market Street
Philadelphia, PA 19106
215-627-1322
PRAECIPE FOR WRIT OF EXECUTION - (MORTGAGE FORECLOSURE)
P.R.C.P 3180-3183
Michael T. McKeever
Attorney I.D.#56129
Suite 5000 - Mellon Independence Center
701 Market Street
Philadelphia, PA 19106
215-627-1322
Attorney for Plaintiff
CITIMORTGAGE, INC., S/B/M CITIFINANCIAL
MORTGAGE CO., INC.
1111 Northpoint Drive
Building 4, Suite 100
Coppell, TX 75019-3931
Plaintiff
VS.
TINA MARIE YOUNG
Mortgagor(s) and Record Owner(s)
231 Walton Street
Lemoyne, PA 17043
IN THE COURT OF COMMON PLEAS
of Cumberland County
CIVIL ACTION - LAW
ACTION OF MORTGAGE FORECLOSURE
No. 08-2030
Defendant(s)
PRAECIPE FOR WRIT OF EXECUTION
TO THE PROTHONOTARY:
Issue Writ of Execution in the above matter:
Amount Due
Interest from
05/06/2008 to Date of
Sale at 10.7500%
(Costs to be added)
GOLDBECK McCA]
BY: Michael T. McK
Attorney for Plaintiff
$61,166.85
& McKEEVER
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ALL THAT CERTAIN LOT OR GROUND SITUTEIN THE BOROUGH OF
LEMOYNE, FORMERLY LOWER ALLEN TOWNSHIP, COUNTY OF
CUMBERLAND AND STATE OF PENNSYLVANIA, BOUNDED AND DESCRIBED
AS FOLLOWS, TO WIT:
BEGINNING AT A POINT ON THE NORTHERN LINE OF WALTON STREET AT
THE EASTERN LINE OF LOT NO. 63 ON THE HEREINAFTER MENTIONED
PLAN OF LOTS; THENCE NORTHWARDLY ALONG THE LINE OF SAID LOT
TWO HUNDRED (200) FEET TO A POINT; THENCE EASTWARDLY PARALLEL
WITH WALTON STREET ONE HUNDRED (100) FEET TO THE WESTERN LINE
OF LOT NO. 65 ON SAID PLAN; THENCE SOUTHWARDLY BY SAID LOT TWO
HUNDRED (200) FEET TO WALTON STREET, AND THENCE WESTWARDLY
ALONG WALTON STREET ONE HUNDRED (100) FEET TO THE PLACE OF
BEGINNING.
EXCEPTING THEREFROM THAT CERTAIN PIECE OR PARCEL OF LAND
SITUATE IN THE BOROUGH OF LEMOYNE (FORMERLY LOWER ALLEN
TOWNSHIP), CUMBERLAND COUNTY, PENNSYLVANIA, BEING MORE
PARTICULARLY BOUNDED AND DESCRIBED AS FOLLOWS, TO WIT:
BEGINNING AT AN IRON PIN ON THE NORTHERN SIDE OF WALTON STREET
AT THE DIVIDING LINE BETWEEN LOTS NOS.64A AND 64B ON THE
HEREINAFTER MENTIONED PLAN OF LOTS; THENCE ALONG SAID DIVIDING
LINE, NORTH 31 DEGREES EAST, A DISTANCE OF TWO HUNDRED (200) FEET
TO AN IRON PIN; THENCE NORTH 59 DEGREES EAST, A DISTANCE OF FIFTY
(50) FEET TO AN IRON PIN AT THE DIVIDING LINE BETWEEN LOTS NOS. 64B
AND 65 ON THE HEREINAFTER MENTIONED PLAN; THENCE ALONG THE
NORTHERN SIDE OF WALTON STREET, SOUTH 59 DEGREES WEST, A
DISTANCE OF FIFTY (50) FEET TO AN IRON PIN, THE POINT OR PLACE OF
BEGINNING. CONTAINING TEN THOUSAND (10,000) SQUARE FEET AND
BEING LOT NO. 64B ON THE FINAL SUBDIVISION PLAN FOR DICE L. AND
PAULINE E. YOUNG DATED NOVEMBER 8, 1989.
ADDRESS: 231 WALTON STREET; LEMOYNE, PA 17043
TAX PARCEL NO: 12-22-0820-003
Michael T. McKeever
Attorney I.D. #56129
Suite 5000 - Mellon Independence Center
701 Market Street
Philadelphia, PA 19106
215-627-1322
Attorney for Plaintiff
CITIMORTGAGE, INC., S/B/M CITIFINANCIAL
MORTGAGE CO., INC.
1111 Northpoint Drive
Building 4, Suite 100
Coppell, TX 75019-3931
Plaintiff
vs.
TINA MARIE YOUNG
Mortgagor(s) and Record Owner(s)
231 Walton Street
Lemoyne, PA 17043
Defendant(s)
IN THE COURT OF
COMMON PLEAS
of Cumberland County
CIVIL ACTION - LAW
ACTION OF
MORTGAGE FORECLOSURE
NO. 08-2030
CERTIFICATION AS TO THE SALE OF REAL PROPERTY
I, Michael T. McKeever, Esquire hereby certify that I am the attorney of rec d f r the Plaintiff in this action, and
I further certify that this property is subject to Act 91 of 1983 and the Plaintiff has c pl ed with all the provisions of the
Act.
Michael T. D
Attorney for
n ?
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Go*fdbeck McCafferty & McKeever
BY: Michael T. McKeever
Attorney I.D. #156129
Suite 5000 - Mellon Independence Center
701 Market Street
Philadelphia, PA 19106
215-627-1322
Attorney for Plaintiff
CITIMORTGAGE, INC., S/B/M CITIFINANCIAL
MORTGAGE CO., INC.
1111 Northpoint Drive
Building 4, Suite 100
Coppell, TX 75019-3931
Plaintiff
vs.
TINA MARIE YOUNG
(Mortgagor(s) and Record Owner(s))
231 Walton Street
Lemoyne, PA 17043
Defendant(s)
AFFIDAVIT PURSUANT TO RULE 3129
No. 08-2030
CITIMORTGAGE, INC., S/B/M CITIFINANCIAL MORTGAGE CO., INC., Plaintiff in the above action, by its
attorney, Michael T. McKeever, Esquire, sets forth as of the date the praecipe for the writ of execution was filed the
following information concerning the real property located at:
231 Walton Street
Lemoyne, PA 17043
1.Name and address of Owner(s) or Reputed Owner(s):
TINA MARIE YOUNG
231 Walton Street
Lemoyne, PA 17043
2. Name and address of Defendant(s) in the judgment:
TINA MARIE YOUNG
231 Walton Street
Lemoyne, PA 17043
3. Name and last known address of every judgment creditor whose judgment is a record lien on the property to be sold:
PA DEPARTMENT OF PUBLIC WELFARE - Bureau of Child Support Enforcement
Health and Welfare Bldg. - Room 432
Harrisburg, PA 17105-2675
DOMESTIC RELATIONS OF CUMBERLAND COUNTY
PO Box 320
Carlisle, PA 17013
IN THE COURT OF COMMON PLEAS
of Cumberland County
CIVIL ACTION - LAW
ACTION OF MORTGAGE FORECLOSURE
4. Name and address of the last recorded holder of every mortgage of record:
5. Name and address of every other person who has any record interest in or record lien on the property and whose interest
may be affected by the sale:
6. Name and address of every other person of whom the plaintiff has knowledge who has any record interest in the property
which may be affected by the sale.
7. Name and address of every other person of whom the plaintiff has knowledge who has any interest in the property which
may be affected by the sale.
TENANTS/OCCUPANTS
231 Walton Street
Lemoyne, PA 17043
(attach separate sheet if more space is needed)
I verify that the statements made in this affidavit are tJethe the est f my rsonal knowledge or
information and belief. I understand that false statements hereict to the enalt' s f 18 Pa. C.S. Section 4904
relating to unsworn falsification to authorities.
DATED: May 21, 2008
cC FERTY & McKEEVER
c eever, Esq.
nff
C0
r?j
co i,#
08-2030
GOLDBECK McCAFFERTY & McKEEVER
BY: Michael T. McKeever
Attorney I.D.#56129
Suite 5000- Mellon Independence Center
701 Market Street
Philadelphia, PA 19106
215-825-6318
Attorney for Plaintiff
CITIMORTGAGE, INC., SB/M CITIFINANCIAL
MORTGAGE CO., INC.
1111 Northpoint Drive
Building 4, Suite 100
Coppell, TX 75019-3931
Plaintiff
vs.
TINA MARIE YOUNG
Mortgagor(s) and Record Owner(s)
231 Walton Street
Lemoyne, PA 17043
Defendant(s,
Term
No. 08-2030
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: YOUNG, TINA MARIE
TINA MARIE YOUNG
231 Walton Street
Lemoyne, PA 17043
Your house at 231 Walton Street, Lemoyne, PA 17043 is scheduled to be sold at Sheriffs Sale on
Wednesday, September 03, 2008, at 10:00 AM, in Commissioners Hearing Rm 2nd FL Courthouse to
enforce the court judgment of $61,166.85 obtained by CITIMORTGAGE, INC., S/B/M CITIFINANCIAL
MORTGAGE CO., INC. against you.
NOTICE OF OWNER'S RIGHTS
YOU MAY BE ABLE TO PREVENT THIS SHERIFF'S SALE
IN THE COURT OF COMMON PLEAS
of Cumberland County
CIVIL ACTION - LAW
ACTION OF MORTGAGE
FORECLOSURE
To prevent this Sheriffs Sale you must take immediate action:
08-2030
1. The sale will be cancelled if you pay to CITIMORTGAGE, INC., S/B/M CITIFINANCIAL
MORTGAGE CO., INC., the back payments, late charges, costs and reasonable attorney's fees due. To find
out how much you must pay call our office at 215-825-6329 or 1-866-413-2311.
2. You may be able to stop the sale by filing a petition asking the Court to strike or open judgment, if
the judgment was improperly entered. You may also ask the Court to postpone the sale for good cause.
3. You may also be able to stop the sale through other legal proceedings.
4. You may need an attorney to assert your rights. The sooner you contact one, the more chance you
will have of stopping the sale. (See notice below on how to obtain an attorney).
YOU MAY STILL BE ABLE TO SAVE YOUR PROPERTY AND YOU HAVE OTHER RIGHTS
EVEN IF THE SHERIFF'S SALE DOES NOT TAKE PLACE.
1. If the Sheriffs Sale is not stopped, your property will be sold to the highest bidder. You may find
out the price bid price by calling the Sheriff of 717-240-6390.
2. You may be able to petition the Court to set aside the sale if the bid price was grossly inadequate
compared to the value of your property.
3. The sale will go through only if the buyer pays the Sheriff the full amount due in the sale. To find
out if this has happened, you may call the Sheriff of 717-240-6390.
4. If the amount due from the Buyer is not paid to the Sheriff, you will remain the owner of the
property as if the sale never happened.
5. You have a right to remain in the property until the full amount due is paid to the Sheriff and the
Sheriff gives a deed to the buyer. At that time, the buyer may bring legal proceedings to evict you.
6. You may be entitled to a share of the money which was paid for your house. A schedule of
distribution of the money bid for your house will be filed by the Sheriff within thirty (30) days from the
date of the Sheriffs Sale. This schedule will state who will be receiving that money. The money will be
paid out in accordance with this schedule unless exceptions (reasons why the proposed distribution is
wrong) are filed with the Sheriff within ten (10) days after the schedule of distribution is filed.
7. You may also have other rights and defenses, or ways of getting your house back, if you act
immediately after the sale.
YOU SHOULD TAKE THIS PAPER TO YOUR LAWYER AT ONCE. IF YOU DO NOT HAVE A
LAWYER OR CANNOT AFFORD ONE, GO TO OR TELEPHONE THE OFFICE LISTED BELOW TO
FIND OUT WHERE YOU CAN GET LEGAL HELP.
CUMBERLAND COUNTY BAR ASSOCIATION
2 Liberty Avenue
Carlisle, PA 17013
LEGAL SERVICES INC
8 Irvine Row
Carlisle, PA 17013
717-243-9400
r
08-2030
Resources available for Homeowners in Foreclosure
ACT NOW!
Even though your lender (and our client) has filed an Action of Mortgage
Foreclosure against you, you still may be able to SAVE YOUR HOME FROM
FORECLOSURE.
1). Call an attorney. For referrals to a qualified attorney call either of the
following numbers: or 717-243-9400.
2). Call the Consumer Credit Counseling Agency at 1-800-989-2227 for free
counseling.
3). Visit HUD'S website www.hud.gov for Help for Homeowners Facing the
Loss of Their Homes.
4). Pennsylvania Housing Finance Agency also offers other loan programs that
may assist homeowners in default. Please See the PHFA website
hqp://www.phfa.org,/consumers/homeowners/real.aspx.
5). Call the Plaintiff (your lender) at 800-422-1498 and ask to speak to someone
about Loss Mitigation or Home Retention options.
6). Call or contact our office to request the amount to bring the account current,
or payoff the mortgage or request a Loan Workout / Home Retention Package. Call our
toll free number at 1-866-413-2311 or via email at homeretentionggoldbecklaw.com.
Call Seth at 215-825-6329 or fax 215-825-6429. The figure and/or package you
requested will be mailed to the address that you request or faxed if you leave a message
with that information. The attorney in charge of our firm's Homeowner Retention
Department is David Fein who can be reached at 215-825-6318 or Fax: 215-825-6418.
Please reference our Attorney File Number of 64524FC.
Para informacion en espanol puede communicarse con Loretta al 215-825-6344.
WRIT OF EXECUTION and/or ATTACHMENT
COMMONWEALTH OF PENNSYLVANIA)
COUNTY OF CUMBERLAND)
NO 08-2030 Civil
CIVIL ACTION - LAW
TO THE SHERIFF OF CUMBERLAND COUNTY:
To satisfy the debt, interest and costs due CITIMORTGAGE, INC., s/b/m CITIFINANCIAL
MORTGAGE CO., INC., Plaintiff (s)
From TINA MARIE YOUNG
(1) You are directed to levy upon the property of the defendant (s)and to sell SEE LEGAL
DESCRIPTION.
(2) You are also directed to attach the property of the defendant(s) not levied upon in the possession
of
GARNISHEE(S) as follows:
and to notify the garnishee(s) that: (a) an attachment has been issued; (b) the garnishee(s) is enjoined from
paying any debt to or for the account of the defendant (s) and from delivering any property of the defendant
(s) or otherwise disposing thereof;
(3) If property of the defendant(s) not levied upon an subject to attachment is found in the possession
of anyone other than a named garnishee, you are directed to notify him/her that he/she has been added as a
garnishee and is enjoined as above stated.
Amount Due $61,166.85 L.L.$ 0.50
Interest from 5/06/08 to Date of Sale at 10.7500%
Atty's Comm % Due Prothy $2.00
Atty Paid $163.00 Other Costs to be added
Plaintiff Paid
Date: 5/22/08
OEM:
4
othonotary(Seal) By:
Deputy
REQUESTING PARTY:
Name: MICHAEL T. MCKEEVER, ESQUIRE
Address: GOLDBECK MCCAFFERTY & MCKEEVER
SUITE 5000-MELLON INDEPENDENCE CENTER
701 MARKET STREET
PHILADELPHIA, PA 19106
Attorney for: PLAINTIFF
Telephone: 215-627-1322
Supreme Court ID No. 56129
GOLDBECK McCAFFERTY & McKEEVER
BY: Michael T. McKeever
Attorney I.D.#56129
Suite 5000 - Mellon Independence Center
701 Market Street
Philadelphia, PA 19106-1532
215-627-1322
64524FC
CF: 03/31/2008
SD: 09/03/2008
$61,166.85
CITIMORTGAGE, INC., SB/M CITIFINANCIAL
MORTGAGE CO., INC.
1111 Northpoint Drive
Building 4, Suite 100
Coppell, TX 75019-3931
Plaintiff
vs.
TINA MARIE YOUNG
Mortgagor(s) and
Record Owner(s)
231 Walton Street
Lemoyne, PA 17043
Defendant(s)
CERTIFICATE OF SERVICE
PURSUANT TO Pa.R.C.P. 3129.2 (c) (2)
Term
No. 08-2030
Michael T. McKeever, Esquire, Attorney for Plaintiff, hereby certifies that service on the
Defendants of the Notice of Sheriff Sale was made by:
?ex s?.?. Q so ?• ??y?a? .
04 Personal Service by the Sheriffs Office/
( ) Certified mail by Michael T. McKeever (original green Postal return receipt attached).
( ) Certified mail by Sheriffs Office.
( ) Ordinary mail by Michael T. McKeever, 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/competent adult (copy of return attached).
( ) Certified Mail & ordinary mail by Sheriffs Office (copy of return attached).
( ) Certified Mail & ordinary mail by Michael T. McKeever (original receipt(s) for Certified
Mail attached).
( ) Published in accordance with court order (copy of publication attached).
Pursuant to the Affidavit under Rule 3129 (copy attached), service on all lienholders (if any) has been
made by ordinary mail by Michael T. McKeever, Esquire (copies of proofs of mailing attached).
The undersigned understands that the statements herein are subject to the penalties provided by 18 P.S.
Section 4904.
IN THE COURT OF COMMON PLEAS
of Cumberland County
CIVIL ACTION - LAW
ACTION OF MORTGAGE FORECLOSURE
Respectfully submitted,
BY: Michael T. McKeever, Esquire
Attorney for Plaintiff
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GOLDBECK McCAFFERTY & McKEEVER
BY: Michael T. McKeever
Attorney I.D.#56129
Suite 5000 - Mellon Independence Center
701 Market Street
Philadelphia, PA 19106
215-825-6320
Attorney for Plaintiff
CITIMORTGAGE, INC., SB/M CTTIFINANCIAL
MORTGAGE CO., INC.
1111 Northpoint Drive
Building 4, Suite 100
Coppell, TX 75019-3931
Plaintiff
vs.
TINA MARIE YOUNG
Mortgagor(s) and Record Owner(s)
231 Walton Street
Lemoyne, PA 17043
Defendant(s)
AFFIDAVIT PURSUANT TO RULE 3129
Term
No. 08-2030
CITIMORTGAGE, INC., SB/M CITIFINANCIAL MORTGAGE CO., INC., Plaintiff in the above action, by its
attorney, Michael T. McKeever, Esquire, sets forth as of the date the praecipe for the writ of execution was filed the
following information concerning the real property located at:
231 Walton Street
Lemoyne, PA 17043
I.Name and address of Owner(s) or Reputed Owner(s):
TINA MARIE YOUNG
231 Walton Street
Lemoyne, PA 17043
2. Name and address of Defendant(s) in the judgment:
TINA MARIE YOUNG
231 Walton Street
Lemoyne, PA 17043
3. Name and last known address of every judgment creditor whose judgment is a record lien on the property to be sold:
IN THE COURT OF COMMON PLEAS
of Cumberland County
CIVIL ACTION - LAW
ACTION OF MORTGAGE FORECLOSURE
PA DEPARTMENT OF PUBLIC WELFARE - Bureau of Child Support Enforcement
Health and Welfare Bldg. - Room 432
Harrisburg, PA 17105-2675
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DOMESTIC RELATIONS OF CUMBERLAND COUNTY
PO Box 320
Carlisle, PA 17013
4. Name and address of the last recorded holder of every mortgage of record:
5. Name and address of every other person who has any record interest in or record lien on the property and whose interest
may be affected by the sale:
6. Name and address of every other person of whom the plaintiff has knowledge who has any record interest in the property
which may be affected by the sale.
7. Name and address of every other person of whom the plaintiff has knowledge who has any interest in the property which
may be affected by the sale.
TENANTS/OCCUPANTS
231 Walton Street
Lemoyne, 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 unworn falsification to authorities.
DATED: July 30, 2008
GOLDBECK McCAFFERTY & McKEEVER
BY: Michael T. McKeever, Esq.
Attorney for Plaintiff
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Citimortgage, Inc., s/b/m Citifinancial
Mortgage Co., Inc.
VS
Tina Marie Young
In the Court of Common Pleas of
Cumberland County, Pennsylvania
Writ No. 2008-2030 Civil Term
Shawn Harrison, Deputy Sheriff, who being duly sworn according to law, states that on June
14, 2008 at 1321 hours, he served a true copy of the within Real Estate Writ, Notice and
Description, in the above entitled action, upon the within named defendant, to wit: Tina Marie
Young, by making known unto Katherine Adams, adult roommate of Tina Marie Young, at 231
Walton Street, Lemoyne, Cumberland County, Pennsylvania its contents and at the same time
handing to her personally the said true and correct copies of the same.
Michelle Gutshall, Deputy Sheriff, who being duly sworn according to law, states that on
July 22, 2008 at 2107 hours, she posted a true copy of the within Real Estate Writ, Notice, Poster
and Description, in the above entitled action, upon the property of Tina Marie Young located at 231
Walton Street, Lemoyne, Cumberland County, 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: Tina Marie
Young by regular mail to her last known address of 231 Walton Street, Lemoyne, PA 17043. This
letter was mailed under the date of July 15, 2008 and never returned to the Sheriffs Office.
R. Thomas Kline, Sheriff, who being duly sworn according to law, states this writ is
returned STAYED per letter of request from Attorney Michael McKeever.
Sheriff's Costs:
Docketing
Poundage
Posting Bills
Advertising
Law Library
Prothonotary
Mileage
Levy
Surcharge
Postpone sale
Law Journal
Patriot News
Share of bills
30.00
1,101.04
15.00
15.00
.50
2.00
32.00
15.00
20.00
20.00
365.00
436.85
17.64
Total Costs
$2,070.03 ? )0j 1 (, l o r 9-
So Answers:
R. Thomas Kline, Sheriff
BY
Real Estate rgeant
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Ct2 4
a is qs'/
` Gpldbeck McCafferty & McKeever
BY: Michael T. McKeever
Attorney I.D. #56129
Suite 5000 ' Mellon Independence Center
701 Market Street
Philadelphia, PA 19106
215-627-1322
Attorney for Plaintiff
CITIMORTGAGE, INC., SB/M CITIFINANCIAL
MORTGAGE CO., INC.
1111 Northpoint Drive
Building 4, Suite 100
Coppell, TX 75019-3931
VS.
TINA MARIE YOUNG
(Mortgagor(s) and Record Owner(s))
231 Walton Street
Lemoyne, PA 17043
Plaintiff
Defendant(s)
AFFIDAVIT PURSUANT TO RULE 3129
No. 08-2030
CITIMORTGAGE, INC., SB/M CITIFINANCIAL MORTGAGE CO., INC., Plaintiff in the above action, by its
attorney, Michael T. McKeever, Esquire, sets forth as of the date the praecipe for the writ of execution was filed the
following information concerning the real property located at:
231 Walton Street
Lemoyne, PA 17043
1.Name and address of Owner(s) or Reputed Owner(s):
TINA MARIE YOUNG
231 Walton Street
Lemoyne, PA 17043
2. Name and address of Defendant(s) in the judgment:
TINA MARIE YOUNG
231 Walton Street
Lemoyne, PA 17043
3. Name and last known address of every judgment creditor whose judgment is a record lien on the property to be sold:
PA DEPARTMENT OF PUBLIC WELFARE - Bureau of Child Support Enforcement
Health and Welfare Bldg. - Room 432
Harrisburg, PA 17105-2675
DOMESTIC RELATIONS OF CUMBERLAND COUNTY
PO Box 320
Carlisle, PA 17013
IN THE COURT OF COMMON PLEAS
of Cumberland County
CIVIL, ACTION - LAW
ACTION OF MORTGAGE FORECLOSURE
4. Name and address of the last recorded holder of every mortgage of record:
5. Name and address of every other person who has any record interest in or record lien on the property and whose interest
may be affected by the sale:
6. Name and address of every other person of whom the plaintiff has knowledge who has any record interest in the property
which may be affected by the sale.
7. Name and address of every other person of whom the plaintiff has knowledge who has any interest in the property which
may be affected by the sale.
TENANTS/OCCUPANTS
231 Walton Street
Lemoyne, PA 17043
(attach separate sheet if more space is needed)
sonal knowledge or
I verify that the statements made in this affidavit are true and correct tVe
information and belief. I understand that false statements herein are made subjef 18 Pa. C.S. Section 4904
relating to unswom falsification to authorities.
DATED: May 21, 2008
GOLDBECK McKEEVER
BY: Michael T. Attorney fof
Pla
08-2030
GOLDBECK McCAFFERTY & MCKEEVER
BY" Michael T. McKeever
Attorney I.D.#56129
Suite 5000- Mellon Independence Center
701 Market Street
Philadelphia, PA 19106
215-825-6318
Attorney for Plaintiff
CITIMORTGAGE, INC., SB/M CTTIFINANCIAL
MORTGAGE CO., INC.
1111 Northpoint Drive
Building 4, Suite 100
Coppell, TX 75019-3931
Plaintiff
vs.
TINA MARIE YOUNG
Mortgagor(s) and Record Owner(s)
231 Walton Street
Lemoyne, PA 17043
Defendant(s
Term
No. 08-2030
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: YOUNG, TINA MARIE
TINA MARIE YOUNG
231 Walton Street
Lemoyne, PA 17043
Your house at 231 Walton Street, Lemoyne, PA 17043 is scheduled to be sold at Sheriffs Sale on
Wednesday, September 03, 2008, at 10:00 AM, in Commissioners Hearing Rm 2nd FL Courthouse to
enforce the court judgment of $61,166.85 obtained by CITIMORTGAGE, INC., SB/M CITIFINANCIAL
MORTGAGE CO., INC. against you.
NOTICE OF OWNER'S RIGHTS
YOU MAY BE ABLE TO PREVENT THIS SHERIFF'S SALE
IN THE COURT OF COMMON PLEAS
of Cumberland County
CIVIL ACTION - LAW
ACTION OF MORTGAGE
FORECLOSURE
To prevent this Sheriffs Sale you must take immediate action:
08-2030
1. • The sale will be cancelled if you pay to CITIMORTGAGE, INC., SB/M CITIFINANCIAL
MORTGAGE CO., INC., the back payments, late charges, costs and reasonable attorney's fees due. To find
out how much you must pay call our office at 215-825-6329 or 1-866-413-2311.
2. You may be able to stop the sale by filing a petition asking the Court to strike or open judgment, if
the judgment was improperly entered. You may also ask the Court to postpone the sale for good cause.
3. You may also be able to stop the sale through other legal proceedings.
4. You may need an attorney to assert your rights. The sooner you contact one, the more chance you
will have of stopping the sale. (See notice below on how to obtain an attorney).
YOU MAY STILL BE ABLE TO SAVE YOUR PROPERTY AND YOU HAVE OTHER RIGHTS
EVEN IF THE SHERIFF'S SALE DOES NOT TAKE PLACE.
1. If the Sheriffs Sale is not stopped, your property will be sold to the highest bidder. You may find
out the price bid price by calling the Sheriff of 717-240-6390.
2. You may be able to petition the Court to set aside the sale if the bid price was grossly inadequate
compared to the value of your property.
3. The sale will go through only if the buyer pays the Sheriff the full amount due in the sale. To find
out if this has happened, you may call the Sheriff of 717-240-6390.
4. If the amount due from the Buyer is not paid to the Sheriff, you will remain the owner of the
property as if the sale never happened.
5. You have a right to remain in the property until the full amount due is paid to the Sheriff and the
Sheriff gives a deed to the buyer. At that time, the buyer may bring legal proceedings to evict you.
6. You may be entitled to a share of the money which was paid for your house. A schedule of
distribution of the money bid for your house will be filed by the Sheriff within thirty (30) days from the
date of the Sheriffs Sale. This schedule will state who will be receiving that money. The money will be
paid out in accordance with this schedule unless exceptions (reasons why the proposed distribution is
wrong) are filed with the Sheriff within ten (10) days after the schedule of distribution is filed.
7. You may also have other rights and defenses, or ways of getting your house back, if you act
immediately after the sale.
YOU SHOULD TAKE THIS PAPER TO YOUR LAWYER AT ONCE. IF YOU DO NOT HAVE A
LAWYER OR CANNOT AFFORD ONE, GO TO OR TELEPHONE THE OFFICE LISTED BELOW TO
FIND OUT WHERE YOU CAN GET LEGAL HELP.
CUMBERLAND COUNTY BAR ASSOCIATION
2 Liberty Avenue
Carlisle, PA 17013
LEGAL SERVICES INC
8 Irvine Row
Carlisle, PA 17013
717-243-9400
08-2030
Resources available for Homeowners in Foreclosure
ACT NOW!
Even though your lender (and our client) has filed an Action of Mortgage
Foreclosure against you, you still may be able to SAVE YOUR HOME FROM
FORECLOSURE.
1). Call an attorney. For referrals to a qualified attorney call either of the
following numbers: or 717-243-9400.
2). Call the Consumer Credit Counseling Agency at 1-800-989-2227 for free
counseling.
3). Visit HUD'S website www.hud.gov for Help for Homeowners Facing the
Loss of Their Homes.
4). Pennsylvania Housing Finance Agency also offers other loan programs that
may assist homeowners in default. Please See the PHFA website
h_ptt ://www. hp fa.org/consumersihomeowners/real aspx.
5). Call the Plaintiff (your lender) at 800-422-1498 and ask to speak to someone
about Loss Mitigation or Home Retention options.
6). Call or contact our office to request the amount to bring the account current,
or payoff the mortgage or request a Loan Workout / Home Retention Package. Call our
toll free number at 1-866-413-2311 or via email at homeretention(a.goldbecklaw.com.
Call Seth at 215-825-6329 or fax 215-825-6429. The figure and/or package you
requested will be mailed to the address that you request or faxed if you leave a message
with that information. The attorney in charge of our firm's Homeowner Retention
Department is David Fein who can be reached at 215-825-6318 or Fax: 215-825-6418.
Please reference our Attorney File Number of 64524FC.
Para informacion en espanol puede communicarse con Loretta a1215-825-6344.
ALL THAT CERTAIN LOT OR GROUND SITUTEIN THE BOROUGH OF
LEMOYNE, FORMERLY LOWER ALLEN TOWNSHIP, COUNTY OF
CUMBERLAND AND STATE OF PENNSYLVANIA, BOUNDED AND DESCRIBED
AS FOLLOWS, TO WIT:
BEGINNING AT A POINT ON THE NORTHERN LINE OF WALTON STREET AT
THE EASTERN LINE OF LOT NO. 63 ON THE HEREINAFTER MENTIONED
PLAN OF LOTS; THENCE NORTHWARDLY ALONG THE LINE OF SAID LOT
TWO HUNDRED (200) FEET TO A POINT; THENCE EASTWARDLY PARALLEL
WITH WALTON STREET ONE HUNDRED (100) FEET TO THE WESTERN LINE
OF LOT NO. 65 ON SAID PLAN; THENCE SOUTHWARDLY BY SAID LOT TWO
HUNDRED (200) FEET TO WALTON STREET, AND THENCE WESTWARDLY
ALONG WALTON STREET ONE HUNDRED (100) FEET TO THE PLACE OF
BEGINNING.
EXCEPTING THEREFROM THAT CERTAIN PIECE OR PARCEL OF LAND
SITUATE IN THE BOROUGH OF LEMOYNE (FORMERLY LOWER ALLEN
TOWNSHIP), CUMBERLAND COUNTY, PENNSYLVANIA, BEING MORE
PARTICULARLY BOUNDED AND DESCRIBED AS FOLLOWS, TO WIT:
BEGINNING AT AN IRON PIN ON THE NORTHERN SIDE OF WALTON STREET
AT THE DIVIDING LINE BETWEEN LOTS NOS.64A AND 64B ON THE
HEREINAFTER MENTIONED PLAN OF LOTS; THENCE ALONG SAID DIVIDING
LINE, NORTH 31 DEGREES EAST, A DISTANCE OF TWO HUNDRED (200) FEET
TO AN IRON PIN; THENCE NORTH 59 DEGREES EAST, A DISTANCE OF FIFTY
(50) FEET TO AN IRON PIN AT THE DIVIDING LINE BETWEEN LOTS NOS. 64B
AND 65 ON THE HEREINAFTER MENTIONED PLAN; THENCE ALONG THE
NORTHERN SIDE OF WALTON STREET, SOUTH 59 DEGREES WEST, A
DISTANCE OF FIFTY (50) FEET TO AN IRON PIN, THE POINT OR PLACE OF
BEGINNING. CONTAINING TEN THOUSAND (10,000) SQUARE FEET AND
BEING LOT NO. 64B ON THE FINAL SUBDIVISION PLAN FOR DICE L. AND
PAULINE E. YOUNG DATED NOVEMBER 8, 1989.
ADDRESS: 231 WALTON STREET; LEMOYNE, PA 17043
TAX PARCEL NO: 12-22-0820-003
WRIT OF EXECUTION and/or ATTACHMENT
k
COMMONWEALTH OF PENNSYLVANIA)
COUNTY OF CUMBERLAND)
NO 08-2030 Civil
CIVIL ACTION - LAW '
TO THE SHERIFF OF CUMBERLAND COUNTY:
To satisfy the debt, interest and costs due CITIMORTGAGE, INC., s/b/m CITIFINANCIAL
MORTGAGE CO., INC., Plaintiff (s)
From TINA MARIE YOUNG
(1) You are directed to levy upon the property of the defendant (s)and to sell SEE LEGAL
DESCRIPTION.
(2) You are also directed to attach the property of the defendant(s) not levied upon in the possession
of
GARNISHEE(S) as follows:
and to notify the garnishee(s) that: (a) an attachment has been issued; (b) the garnishee(s) is enjoined from
paying any debt to or for the account of the defendant (s) and from delivering any property of the defendant
(s) or otherwise disposing thereof;
(3) If property of the defendant(s) not levied upon an subject to attachment is found in the possession
of anyone other than a named garnishee, you are directed to notify him/her that he/she has been added as a
garnishee and is enjoined as above stated.
Amount Due $61,166.85
L.L.$ 0.50
Interest from 5/06/08 to Date of Sale at 10.7500%
Atty's Comm %
Atty Paid $163.00
Plaintiff Paid
Date: 5/22/08
(Seal)
REQUESTING PARTY:
Due Prothy $2.00
Other Costs to be added
rothonota
By:
Name: MICHAEL T. MCKEEVER, ESQUIRE
Address: GOLDBECK MCCAFFERTY & MCKEEVER
SUITE 5000-MELLON INDEPENDENCE CENTER
701 MARKET STREET
PHILADELPHIA, PA 19106
Attorney for: PLAINTIFF
Telephone: 215-627-1322
Supreme Court ID No. 56129
Deputy
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Real Estate Sale #5%.
On May 29, 2008 the Sheriff levied upon the
defendant's interest in the real property situated in
Lemoyne Borough, Cumberland County, PA
Known and numbered as 231 Walton Street, Lemoyne
more fully described on Exhibit "A"
filed with this writ and by this reference
incorporated herein.
Date: May 29, 2008 By:
Real Est to Sergeant
PROOF OF PUBLICATION OF NOTICE
IN CUMBERLAND LAW JOURNAL
(Under Act No. 587, approved May 16, 1929), P. L.1784
COMMONWEALTH OF PENNSYLVANIA
: ss.
COUNTY OF CUMBERLAND :
Lisa Marie Coyne, Esquire, Editor of the Cumberland Law Journal, of the County and
State aforesaid, being duly sworn, according to law, deposes and says that the Cumberland Law
Journal, a legal periodical published in the Borough of Carlisle in the County and State aforesaid,
was established January 2, 1952, and designated by the local courts as the official legal
periodical for the publication of all legal notices, and has, since January 2, 1952, been regularly
issued weekly in the said County, and that the printed notice or publication attached hereto is
exactly the same as was printed in the regular editions and issues of the said Cumberland Law
Journal on the following dates,
viz:
July 18, July 25, and August 1, 2008
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.
Coyne,
SWORN TO AND SUBSCRIBED before me this
i day of August, 2008
Notary
NOTARIAL SEAL
DEBORAH A COLLINS
Notary Public
CARLISLE BORO, CUMBERLAND COUNTY
My Commission Expires Apr 28, 2010
Writ No. 2008-2030 Civil
Citimortgage, Inc. s/b/m
Citifinancial Mortgage Co., Inc.
VS.
Tina. Marie Young
Atty.: Michael McKeever
ALL THAT CERTAIN lot or ground
situate in the Borough of Lemoyne,
formerly Lower Allen Township,
County of Cumberland and State
of Pennsylvania, bounded and de-
scribed as follows, to wit:
BEGINNING at a point on the
northern line of Walton Street at the
eastern line of Lot No. 63 on the here-
inafter mentioned plan of lots; thence
northwardly along the line of said lot
two hundred (200) feet to a point;
thence eastwardly parallel with Wal-
ton Street one hundred (100) feet to
the western line of Lot No. 65 on said
plan; thence southwardly by said
lot two hundred (200) feet to Walton
Street, and thence westwardly along
Walton Street one hundred (100) feet
to the place of beginning.
EXCEPTING therefrom that cer-
tain piece or parcel of land situate
in the Borough of Lemoyne (formerly
Lower Allen Township), Cumberland
County, Pennsylvania, being more
particularly bounded and described
as follows, to wit:
BEGINNING at an iron pin on
the northern side of Walton Street
at the dividing line between Lots
Nos. 64A and 64B on the hereinafter
mentioned plan of lots; thence along
said dividing line, North 31 degrees
East, a distance of two hundred (200)
feet to an iron pin; thence North 59
degrees East, a distance of fifty (50)
feet to an iron pin at the dividing line
between Lots Nos. 64B and 65 on the
hereinafter mentioned plan; thence
along the northern side of Walton
Street, South 59 degrees West, a
distance of fifty (50) feet to an iron
pin, the point or place of beginning.
Containing ten thousand (10,000)
square feet and being Lot No. 64B on
the final subdivision plan for Dice L.
and Pauline E. Young dated Novem-
ber 8, 1989.
ADDRESS: 231 WALTON STREET,
LEMOYNE, PA 17043.
TAX PARCEL NO: 12-22-0820-
003.
the Patriot-News Co.
812 Market St.
Harrisburg, PA 17101
Inquiries - 717-255-8292
CUMBERLAND COUNTY SHERIFFS OF
CUMBERLAND COUNTY COURT HOUSE
the Patriot News
Now you know
CARLISLE PA 17013
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 J. 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 date(s) indicated below. 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
This ad ran on the date(s) shown below:
07/23/08
1
07/30/08
08/06/08
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Atswdobn of Notes.
Reel Extele Sale No. 52
Writ No. 2008-2030 CM Term
ClHmortgege, Inc..sbhn
Citiflnancial Mortgage Co., Inc.
VS
Tina Marls Young
Attorney Michael McKeever
LEGAL DESCRIPTION
ALL THAT CERTAIN LOT OR GROUND
SITUTEIN THE BOROUGH OF LEMOYNE,
FORMERLY LOWER ALLEN TOWNSHIP,
COUNTY OF CUMBERLAND ANDSTATE
OF PENNSYLVANIA, BOUNDED
ANDDESCRIBED AS FOLLOWS, TO WIT:
BEGINNING AT A POINT- ON THE
NORTHERN LINEOF WALTON STREET AT
THE EASTERN LINEOF LOT NO. 63 ON
THE HEREINAFTER MENTIONED PLANOF
LOTS; THENCE NORTHWARDLY ALONG
THE LINEOF SAID LOT TWO HUNDRED
(200) FEET TO A POINT; THENCE
EASTWARDLY PARALLEL WITH WALTON
STREET ONEHUNDRED (100) FEET TO
THE WESTERN LINEOF LOT NO. 65 ON
SAID PLANTHEICE SOUTHWARDLY BY
SAID LOT TWO HUNDRED (200) FEET TO
WALTON STREET, ANDTHENCE
WESTWARDLY ALONG WALTON STREET
ONEHUMRM (100) FEET TO THE PLACE
OF BEGINNING.
EXCEPTING THERE FROM THAT CERTAIN
PIECE OR PARCEL OF LANDSITUATE IN
THE BOROUGH OF
LEMOYNE (FORMERLY LOWER ALLEN
TOWNSHIP), CUMBERLAND COUNTY,
PENNSYLVANIA, BEING MORE
PARTICULARLY BOUNDED
ANDDESCRIBED AS FOLLOWS, TO WIT:
BEGINNING AT AN IRON PINON THE
NORTHERN SIDEOF WALTON STREET AT
THE DIVIDING LINEBETWEEN LOTS
NOS.64A AND64B ONTHE HEREINAFTER
MENTIONED PLANOF LOTS; THENCE
ALONG SAID DIVIDING LINE, NORTH 31
DEGREES EAST, A DISTANCE OF TWO
HUNDRED (200) FEET TO AN IRON
PDMIENCE NORTH 59 DEGREES EAST, A
DISTANCE OF FIFTY (50) FEET TO AN
IRON PINAT THE DIVIDING
LINEBETWEEN LOTS NOS. 64B AND65 ON
THE HEREINAFTER _ MENTIONED
PLANTHENCE ALONG THE NORTHERN
SIDEOF WALTON STREET, SOUTH 59
DEGREES WEST, A DISTANCE OF FIFTY
(50) FEET TO AN IRON PIN, THE POINT OR
PLACE OF BEGINNING.' CONTAINING
TENTHOUSAND (10,000) SQUARE FEET
ANDBEING LOT NO. 64B ON THE FINAL
SUBDMSION PLANFOR DICE L.
ANDPAULINE E. YOUNG DATED
NOVEMBER 8,1989.
ADDRESS: 231 WALTON STREET;
LEMOYNE, PA 17043
TAX PARCEL NO. 12-22-0820-003
GOLDBECK McCAFFERTY & McKEEVER
BY: Michael T. McKeever
Attorney I.D. #56129
Suite 5000 - Mellon Independence Center
701 Market Street
Philadelphia, PA 19106
215-825-6312
Attornev for Plaintiff
CITIMORTGAGE, INC., SB/M
CITIFINANCIAL MORTGAGE CO., INC.
1111 Northpoint Drive
Building 4, Suite 100
Coppell, TX 75019-3931
Plaintiff
VS.
IN THE COURT OF COMMON PLEAS
OF CUMBERLAND COUNTY
No. 08-2030
TINA MARIE YOUNG
231 Walton Street
Lemoyne, PA 17043
Defendant
PRAECIPE TO SATISFY JUDGMENT
TO THE PROTHONOTARY:
Kindly Satisfy the Judgment in the above captioned matter upon payment of your costs
only.
? 3 4wP KLA
MICHAEL T. McKEEVER, ESQUIRE
c
CIO
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mp
GOLDBECK McCAFFERTY & McKEEVER
BY: Michael T. McKeever
Attorney I.D. #56129
Suite 5000 Mellon Independence Center
701 Market Street
Philadelphia, PA 19106-1532
215-825-6321
Attorney for Plaintiff
CITIMORTGAGE, INC., SB/M
CITIFINANCIAL MORTGAGE CO., INC.
1111 Northpoint Drive
Building 4, Suite 100
Coppell, TX 75019-3931
Plaintiff
VS.
TINA MARIE YOUNG
231 Walton Street
Lemoyne, PA 17043
IN THE COURT OF COMMON
PLEAS
OF CUMBERLAND COUNTY
No. 08-2030
Defendant
PRAECIPE TO SETTLE. DISCONTINUE AND END
TO THE PROTHONOTARY:
Kindly mark the above case Settled, Discontinued and Ended upon payment of your costs
only.
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MICHAEL T. MCKEEVER, ESQUIRE
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