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Home My WebLink About08-3207GOLDBECK 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. 1000 Technology Drive MS 730 O'Fallon, MO 63368-2240 Plaintiff vs. DONNA M. BENNETT Mortgagor and Real Owner 3 Citadel Drive Camp Hill, PA 17011 Defendant Term No. 08.3x07 clvi I Fl! qtt CIVIL ACTION: MORTGAGE NOTICE FORECLOSURE 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. LEGAL SERVICES INC 8 Irvine Row Carlisle, PA 17013 717-243-9400 CUMBERLAND COUNTY BAR ASSOCIATION 2 Liberty Avenue Carlisle, PA 17013 AVISO LE HAN DEMANDADO A USTED EN LA CORTE. SI DESEA DEFENDERSE CONTRA LAS QUEJAS PERESENTADAS, ES ABSOLUTAMENTE NECESSARIO QUE USTED RESPONDA DENTRO DE 20 DIAS 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 IN THE COURT OF COMMON PLEAS OF CUMBERLAND COUNTY CIVIL ACTION - LAW ACTION OF MORTGAGE FORECLOSURE 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. LEGAL SERVICES INC 8 Irvine Row Carlisle, PA 17013 717-243-9400 CUMBERLAND COUNTY BAR ASSOCIATION 2 Liberty Avenue Carlisle, PA 17013 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: 717-243- 9400 or. 2). Call the Consumer Credit Counseling Agency at 1-800-989-2227 for free counseling. 3). Visit HUD's website www.hud.gov for Help for Homeowners Facing the Loss of Their Homes. 4). Pennsylvania Housing Finance Agency also offers other loan programs that may assist homeowners in default. Please See the PHFA website http://www.phfa.org/consumers/homeowners/real.aspx. 5). Call the Plaintiff (your lender) at and ask to speak to someone about Loss Mitigation or Home Retention options. 6). Call or contact our office to request the amount to bring the account current, or payoff the mortgage or request a Loan Workout / Home Retention Package. Call our toll free number at 1-866-413-2311 or via email at homeretention@poldbecklaw.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 66106FC. 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., 1000 Technology Drive, MS 730, O'Fallon, MO 63368-2240. 2. The names and addresses of the Defendant is DONNA M. BENNETT, 3 Citadel Drive, Camp Hill, PA 17011, who is the mortgagor and real owner of the mortgaged premises hereinafter described. 3. On June 24, 2003 mortgagors made, executed and delivered a mortgage upon the Property hereinafter described to MORTGAGE ELECTRONIC REGISTRATION SYSTEMS, INC., ACTING SOLELY AS NOMINEE FOR PRINCIPAL RESIDENTIAL MORTGAGE, INC., which mortgage is recorded in the Office of the Recorder of Deeds of Cumberland County as Book 1820, Page 5024. The mortgage has been assigned to: CITIMORTGAGE, INC. by assignment of Mortgage. Plaintiff is the real party in interest pursuant to a purchase or transfer of the mortgage obligation from the last record holder and an Assignment of Mortgage to Plaintiff has been and/or will be lodged for recording with the Recorder of Deeds in the ordinary course of business. 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 January 01, 2008 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 ..................................................................................$115,188.74 Interest from 12/01/2007 through 05/31/2008 at 5.5000% .......................$3,175.05 Per Diem interest rate at $17.36 Reasonable Attorney's Fee at 5% of Principal Balance as more fully explained in the next numbered paragraph ...................$5,759.44 Late Charges from 01/01/2008 to 05/31/2008 ............................................. $191.85 Monthly late charge amount at $38.37 Costs of suit and Title Search ......................................................................$900.00 FHA/PMI Premium ......................................................................................$141.75 Foreclosure Charges .......................................................................................$30.00 Escrow ........................................................................................................ -$339.19 $125,047.64 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 Sheriff s 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. The 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 or Act 160 of 1998. WHEREFORE, Plaintiff demands a de terns judgment in mortgage foreclosure in the sum of $125,047.64, together with interest at the rate of $17.36, per day and other expenses, costs and charges incurred by the Plaintiff which are properly chargeable in accordance with the terms of the Mortgage and Pennsylvania law until the Mortgage is paid in full, and for the foreclosure of the Mortgage and Sheriff s Sale of the Property. By: NVdkAW(. tiVl'IJPn GOLDBECK McCAFFERTY & MCKEEVER BY: MICHAEL T. MCKEEVER, ESQUIRE ATTORNEY FOR PLAINTIFF VERIFICATION I, Aaron Menne, as the representative of the Plaintiff corporation within named do hereby verify that I am authorized to and do make this verification on behalf of the Plaintiff corporation and the facts set forth in the foregoing Complaint are true and correct to the best of my knowledge, information and belief. I understand that false statements therein are made subject to the penalties of 18 Pa. C.S. 4904 relating to unsworn falsification to authorities. Date: May 14, 2008 Assistant Vice President 2297902 DONNA M. BENNETT Ey,FiditA A ? All that certain P&=el of land situate in the To%m ahip of L r All CMWt of CUmberU d, &M Mate of l?nse lvania, Y Y beiag known and des3e#quated according to a mutveY Of 8raeet ,7. Nailer, F.B. dazed lrii 7, .1970 as Lot NO. 127 on the plan of Lots kaom as "Fafit aI Plan Z?_ Cedar cliff Yta torN which Plan was =Wud by the CQMWireianstrs of Iay r A12tsxa Township on jemu ary 12, ?s$, &W its recorded in tho office of tk? et?axder of Deeds, Cumberland County, Penn Cumberland sylvania. In Plan Cumberland COUPeUmffy vatt.is, = Plan Book ?, Page 13. TAX tt'? 13-M-0-597 C4 i 00 f W W °- CD ..Z7 0 SHERIFF'S RETURN - REGULAR CASE NO: 2008-03207 P COMMONWEALTH OF PENNSYLVANIA: COUNTY OF CUMBERLAND CITIMORTGAGE INC VS BENNETT DONNA M MARK CONKLIN , Sheriff or Deputy Sheriff of Cumberland County,Pennsylvania, who being duly sworn according to law, says, the within COMPLAINT - MORT FORE was served upon BENNETT DONNA M the DEFENDANT , at 1838:00 HOURS, on the 3rd day of June 2008 at 3 CITADEL DRIVE CAMP HILL, PA 17011 DONNA BENNETT by handing to 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 15.00 Affidavit .00 Surcharge 10.00 00 L/0 y?B P ?-- Sworn and Subscibed to before me this day of , So Answers: R. Thomas Kline 06/04/2008 GOLDBECK MCCAFFERTY MCKEEVER By: Depu y eriff A. D. In the Court of Common Pleas of Cumberland County CITIMORTGAGE, INC. 1000 Technology Drive MS 730 O'Fallon, MO 63368-2240 Plaintiff vs. DONNA M. BENNETT (Mortgagor(s) and Record Owner(s)) 3 Citadel Drive Camp Hill, PA 17011 Defendant(s) PRAECIPE FOR JUDGMENT No. 08-3207 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 DONNA M. BENNETT by default for want of an Answer. Assess damages as follows: Debt Interest from 07/09/2008 to Date of Sale per diem at $17.35 Total (Assessment of Damages attached) I CERTIFY THAT FOREGOING ASSESSMENT OF DAMAGES IS FOR SPE( BE DUE IN THE COMPLAINT AND IS CALCULABLE AS A SUM CERTAIN I certify that written notice of the intention to file this praecipe was mailed or delivered is to be entered and to his attorney of record, if any, after the default occurred and at lei filing of this praecipe. A copy of the notice is attached. R.C.P. 237.1 $125,783.67 UNTS ALLEGED TO ist whom judgment to the date of the Michael T. Mc e v I Attorney for Pla f l I.D. #56129 AND NOW f `f8 Judgment is entered in favor of CITIMORTGAGE, INC. and against DONNA M. BENNE T b default for want f an Answer and damages assessed in the sum of $125,783.67 as per the above certification. A 66106FC 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 24, 2008 TO: DONNA M. BENNETT 3 Citadel Drive Camp Hill, PA 17011 In the Court of CITIMORTGAGE, INC. Common Pleas 1000 Technology Drive of Cumberland County MS 730 O'Fallon, MO 63368-2240 CIVIL ACTION - LAW Plaintiff VS. Action of DONNA M. BENNETT Mortgage Foreclosure (Mortgagor(s) and Record Owner(s)) 3 Citadel Drive Term Camp Hill, PA 17011 No. 08-3207 Defendant(s) TO: DONNA M. BENNETT 3 Citadel Drive Camp Hill, PA 17011 IMPORTANT NOTICE YOU ARE IN DEFAULT BECAUSE YOU HAVE FAILED TO ENTER A WRITTEN APPEARANCE PERSONALLY OR BY ATTORNEY AND FILE IN WRITING WITH THE COURT YOUR DEFENSES OR OBJECTIONS TO THE CLAIMS SET FORTH AGAINST YOU. UNLESS YOU ACT WITHIN TEN (10) DAYS FROM THE DATE OF THIS NOTICE, A JUDGMENT MAY BE ENTERED AGAINST YOU WITHOUT A HEARING AND YOU MAY LOSE YOUR PROPERTY OR OTHER IMPORTANT RIGHTS. YOU SHOULD TAKE THIS PAPER TO YOUR LAWYER AT ONCE. JF 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. LEGAL SERVICES INC 8 Irvine Row Carlisle, PA 17013 717-243-9400 CUMBERLAND COUNTY BAR ASSOCIATION 2 Liberty Avenue Carlisle, PA 17013 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 q w .?= -:1 Co c 2: I 20 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, DONNA M. BENNETT, is about unknown years of age, that Defendant's last known residence is 3 Citadel Drive Camp Hill, PA 17011, and is engaged in the unknown business located at unknown address. 2. That Defendant is not in the Military or N Allies, or otherwise within the provisions of the S Congress of 1940 and its Amendments. ce bf the United States or its ' Civil Relief Action of Date: a; c L.U Oct C isILZU n `? N 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, DONNA M. BENNETT, is about unknown years of age, that Defendant's last known residence is 3 Citadel Drive Camp Hill, PA 17011, and is engaged in the unknown business located at unknown address. 2. That Defendant is not in the Military or NavayServ#e of, fe United States or its Allies, or otherwise within the provisions of the Soldiers'/and/Sailo?'/ Civil Relief Action of Congress of 1940 and its Amendments. Date: C=LU F? u a. LL- 0 w ? U c 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. 1000 Technology Drive IN THE COURT OF COMMON PLEAS MS 730 O'Fallon, MO 63368-2240 of Cumberland County Plaintiff vs. CIVIL ACTION LAW DONNA M. BENNETT (Mortgagor(s) and Record owner(s)) 3 Citadel Drive ACTION OF MORTGAGE FORECLOSURE Camp Hill, PA 17011 Defendant(s) No. 08-3207 ORDER FOR JUDGMENT Please enter Judgment in favor of CITIMORTGAGE, INC., and against D A NNETT for failure to file an Answer in the above action within (20) days (or sixty (60) days if efenda t i e United States of America) from the date of service of the Complaint, in the sum of $125,783.67 Michael T. McKeever Attorney for Plaintiff I hereby certify that the above names are correct and that the precis resi nce ddres of the judgment creditor is CITIMORTGAGE, INC. 1000 Technology Drive MS 730 O'F on, O 6 368-2 0 and that the name(s) and last known address(es) of the Defendant(s) is/are DONNA M. BE E , 3 C' del Drive Camp Hill, PA 17011; GOLDBECK MVC,evEE & BY: Michael T. er Attorney for Pla ASSESSMENT OF DAMAGES TO THE PROTHONOTARY: Kindly assess the damages in this case to be as follows: Principal Balance $115,188.74 Interest from 12/01/2007 through $3,834.35 07/08/2008 Reasonable Attorney's Fee $5,759.44 Late Charges $268.58 Costs of Suit and Title Search $900.00 Escrow Payments Due 2 X $0.00 $0.00 FHA/PMI Premium $141.75 Foreclosure Charges $30.00 Escrow -$339.19 $125,783.67 GOLDBECK N BY: Michael T. Attorney for Ply AND NOW, this /y day of olu-? 2008 damages are assessed as above. Pro P/-thy' 1 C? C= c: r C co 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. 1000 Technology Drive MS 730 O'Fallon, MO 63368-2240 Plaintiff vs. DONNA M. BENNETT Mortgagor(s) and Record Owner(s) 3 Citadel Drive Camp Hill, PA 17011 Defendant(s) IN THE COURT OF COMMON PLEAS of Cumberland County CIVIL ACTION - LAW ACTION OF MORTGAGE FORECLOSURE No. 08-3207 PRAECIPE FOR WRIT OF EXECUTION TO THE PROTHONOTARY: Issue Writ of Execution in the above matter: Amount Due Interest from 07/09/2008 to Date of Sale per diem at $17.35 (Costs to be added) $125,783.67 CC? `a ?jri W ., xs r? C 2 - 4 h n v? o Q r Lam.. T A ? ? ' ' a o ? U °' ?U x /, IC N O y u ? d ?Qa F, o w ?a gip" wo. " M O U O "Cl N O U Q v W ¢ uo`? ? ' CD a ? a ? All that certain parcel of land situate in the Township of Lower Allen, County of Cumberland, and State of Pennsylvania, being known and designated according to a survey of Ernest J. Walker P.E. dated April 7, 1970 as Lot No. 127 on the Plan of Lots known as "Part of Plan No. 2, Cedar Cliff Manor", which Plan was approved by the Commissioners of Lower Allen Township on January 12, 1955, and in recorded in the Office of the Recorder of Deeds, Cumberland County, Pennsylvania, in Plan Book 7, Page 13 Cumberland County, Pennsylvania, in Plan Book 7, Page 13. And also being described in deed as: All that certain lot or tract of land situate in the Township of Lower Allen, County of Cumberland and State of Pennsylvania, more particularly bounded and described as follows, according to a survey of Ernest J. Walker, P.E., dated April 7, 1970, to wit: Beginning at a point on the southern side of a 50 foot wide road known as Citadel Drive, which point measured along the southern side of Citadel Drive, which point measured along the southern side of Citadel Drive is 363.95 feet west of the southwest corner of Citadel Drive and Colgate Drive, and which point is alos at the northwest corner of Lot No. 126 on Part of Plan No. 2 Cedar Cliff Manor, recorded in the Office of the Recorder of Deeds in and for Cumberland County, Pennsylvania, in Plan Book 7, Page 13; thence at right angles to Citadel Drive South 01 degree 00 minutes East along the western line of Lot No. 126 aforesaid, 125 feet to a point at an iron pin on the northern line of Lot No. 130 on Plan No. 1, Cedar Cliff Manor, recorded in the Office of the Recorder of Deeds in and for Cumberland County, Pennsylvania, in Plan Book 6, Page 33; thence South 89 degrees 00 minutes West along the northern line of Lot NO. 128 on Plan No. 1, Cedar Cliff Manor, aforesaid 70 feet to a point at the eastern line of Lot No. 128 on Plan No. 1, Cedar Cliff Manor, aforesaid; thence at right angles to Citadel Drive North 01 degree 00 minutes West along the eastern line of Lot No. 128 aforesaid 125 feet to a point at the southern side of Citadel Drive; thence North 89 degrees 00 minutes East along the southern side of Citadel Drive 70 feet to a point, the place of beginning. Having thereon erected a dwelling house known and numbered as 3 Citadel Drive. Tax parcel no: 13-23-0547-589 WRIT OF EXECUTION and/or ATTACHMENT COMMONWEALTH OF PENNSYLVANIA) COUNTY OF CUMBERLAND) N008-3207 Civil CIVIL ACTION - LAW TO THE SHERIFF OF CUMBERLAND COUNTY: To satisfy the debt, interest and costs due CITIMORTGAGE, INC Plaintiff (s) From DONNA M BENNETT 3 CITADEL DRIVE CAMP HILL, PA 17011 (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 $ 125,783.67 L.L. $0.50 Interest FROM 7/09/08 TO DATE OF SALE PER DIEM AT $17.35 Atty's Comm % Atty Paid $162.00 Plaintiff Paid Date: JULY 14, 2008 (Seal) Due Prothy $2.00 Other Costs 1z'4 4t7A?" J#A C ' R. Long, P not By: Deputy REQUESTING PARTY: Name MICHAEL T MCKEEVER, ESQ Address: 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 215-627-1322 Attorney for Plaintiff CITIMORTGAGE, INC. 1000 Technology Drive MS 730 O'Fallon, MO 63368-2240 VS. DONNA M. BENNETT (Mortgagor(s) and Record Owner(s)) 3 Citadel Drive Camp Hill, PA 17011 IN THE COURT OF COMMON PLEAS Plaintiff of Cumberland County CIVIL ACTION - LAW ACTION OF MORTGAGE FORECLOSURE Defendant(s) No. 08-3207 AFFIDAVIT PURSUANT TO RULE 3129 CITIMORTGAGE, 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: 3 Citadel Drive Camp Hill, PA 17011 1.Name and address of Owner(s) or Reputed Owner(s): DONNA M. BENNETT 3 Citadel Drive Camp Hill, PA 17011 2. Name and address of Defendant(s) in the judgment: DONNA M. BENNETT 3 Citadel Drive Camp Hill, PA 17011 3. Name and last known address of every judgment creditor whose judgment is a record lien on the property to be sold: DOMESTIC RELATIONS OF CUMBERLAND COUNTY PO Box 320 Carlisle, PA 17013 PA DEPARTMENT OF PUBLIC WELFARE - Bureau of Child Support Enforcement Health and Welfare Bldg. - Room 432 Harrisburg, PA 17105-2675 4. Name and address of the last recorded holder of every mortgage of record: SUMMIT FINANCIAL, LLC 13530 Dulles Technology Drive, Suite 600 Herndon, VA 20171 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 3 Citadel Drive Camp Hill, PA 17011 (attach separate sheet if more space is needed) I verify that the statements made in this affidavit are true and correct to the information and belief. I understand that false statements herein are made subject to relating to unsworn falsification to authorities. DATED: July 8, 2008 GOLDBECKI BY: Michael T Attorney for PI of p sonal knowledge or e tie of 18 Pa. C.S. Section 4904 TY kMcKEEVER Esq. na -n -v t t_.. ce M fT Zt.. i , _, -n -OF , , 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. 1000 Technology Drive MS 730 IN THE COURT OF O'Fallon, MO 63368-2240 COMMON PLEAS Plaintiff vs. of Cumberland County DONNA M. BENNETT CIVIL ACTION - LAW Mortgagor(s) and Record Owner(s) 3 Citadel Drive ACTION OF Camp Hill, PA 17011 MORTGAGE FORECLOSURE Defendant(s) NO. 08-3207 CERTIFICATION AS TO THE SALE OF REAL PROPERTY I, Michael T. McKeever, Esquire hereby certify that I am the attorney of record I further certify that this property is subject to Act 91 of 1983 and the Plaintiff has com) Act. the P mtiff ' this action, and l wi all th provisions of the Michael T. D Attorney for c.r ? ? ? ? ?' ? ?_ ,• : ? - .. ? ? ?? ? 08-3207 r? 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. 1000 Technology Drive MS 730 O'Fallon, MO 63368-2240 Plaintiff VS. DONNA M. BENNETT Mortgagor(s) and Record Owner(s) 3 Citadel Drive Camp Hill, PA 17011 Defendant(s Term No. 08-3207 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: BENNETT, DONNA M. DONNA M. BENNETT 3 Citadel Drive Camp Hill, PA 17011 Your house at 3 Citadel Drive, Camp Hill, PA 17011 is scheduled to be sold at Sheriff s Sale on Wednesday, December 10, 2008, at 10:00 AM, in Commissioners Hearing Rm 2nd FL Courthouse to enforce the court judgment of $125,783.67 obtained by CITIMORTGAGE, 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 CITIMORTGAGE, 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. IN THE COURT OF COMMON PLEAS of Cumberland County CIVIL ACTION - LAW ACTION OF MORTGAGE FORECLOSURE 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. 08-3207 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. LEGAL SERVICES INC 8 Irvine Row Carlisle, PA 17013 717-243-9400 CUMBERLAND COUNTY BAR ASSOCIATION 2 Liberty Avenue Carlisle, PA 17013 .° 08-3207 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: 717-243-9400 or. 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 blip://www.phfa.orp,/consumers/homeowners/real.aspx. 5). Call the Plaintiff (your lender) at and ask to speak to someone about Loss Mitigation or Home Retention options. 6). Call or contact our office to request the amount to bring the account current, or payoff the mortgage or request a Loan Workout / Home Retention Package. Call our toll free number at 1-866-413-2311 or via email at homeretentionaa,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 66106FC. Para informacion en espanol puede communicarse con Loretta a1215-825-6344. rya -0a.7 C- mra, c Wy 77 GOLDBECK McCAFFERTY & McKEEVER 66106FC BY: Michael T. McKeever CF: 05/21/2008 Attorney I.D.#56129 Suite 5000 - Mellon Independence Center SD: 12/10/2008 701 Market Street $125,783.67 Philadelphia, PA 19106-1532 215-627-1322 Attorney for Plaintiff CITIMORTGAGE, INC. 1000 Technology Drive MS 730 O'Fallon, MO 63368-2240 vs. Plaintiff IN THE COURT OF COMMON PLEAS DONNA M. BENNETT Mortgagor(s) and Record Owner(s) 3 Citadel Drive Camp Hill, PA 17011 Defendant(s) of Cumberland County CIVIL ACTION - LAW ACTION OF MORTGAGE FORECLOSURE Term No. 08-3207 CERTIFICATE OF SERVICE PURSUANT TO Pa.R.C.P. 3129.2 (c) (2) Michael T. McKeever, Esquire, Attorney for Plaintiff, hereby certifies that service on the Defendants of the Notice of Sheriff Sale was made by: QQ 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. Respectfully submitted, BY: Michael T. McKeever, Esquire Attorney for Plaintiff 0: U- o ao ^ ~ o OJ °o r ???' °?hl U, E?ja ? i°2 83.1 N J V C OJ N K 8 U. sl`;l-.. = s a e C O E c >iJ \ir1 O `tYN O Q , 4?F4A +[IIV11 O O .? ?.. > r - CL 3i m h b 4 v ro 3 N O Q., b'b (L m ? 4S ? J Q E R LLJ m r W m r 0) " ? .e g E to o? ?n U U?o ° m ??O? a 0 ? ? ' o c Z W d ?' 01N LL O : U J W O J_ O 0 QmC F- Q °c?- Q a- 0 W O Z W`? z? O V E 7UA+? ? ? ix - Q Z ? N y Z p p i a s a so -2a5 V N a ? o lL ~? O " ???? K m D aa ? 0 ?' 2? E o Zz? :F 2 m E 0) :3 wU $ U 000 ce 000.0 Q m 07 a- DO == M to - Z F- co a E? 2 lu lu ? 2 m a g rz uj IL C,4 a a ? RR W0ccWQT m Q z E? W?? o f zO?p2? r N c7 Sri to f? 06 0 a 0 a m 0 C F a Q 7 co O N O m O a? io N ?. O C 3 O ? O 1m ` U Z LL W ti m LL Z 0 o z 0 a cep D vvJl-Lir Citimortgage, Inc. In the Court of Common Pleas of VS Cumberland County Pennsylvania Donna M. Bennett Writ No. 2008-3207 Civil Tenn Michael Barrick, Deputy Sheriff, who being duly sworn according to law, states that on September 20, 2008 at 1153 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: Donna M. Bennett, by making known unto Donna M. Bennett personally, at 3 Citidel Drive, Camp Hill, Cumberland County, Pennsylvania its contents and at the same time handing to her personally the said true and correct copy of the same. Robert Bitner, Deputy Sheriff, who being duly sworn according to law, states that on October 11, 2008 at 0840 hours, he posted a true copy of the within Real Estate Writ, Notice, Poster and Description, in the above entitled action, upon the property of Donna M. Bennett, located at 3 Citadel Drive, Camp Hill, 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: Donna M. Bennett, by regular mail to her last known address of 3 Citadel Drive, Camp Hill, PA 17011. This letter was mailed under the date of October 7, 2008 and never returned to the Sheriffs Office. So Answers: R. Thomas Kline, Sheriff BI't/n GOLDBECK McCAFFERTY & MCKEEVER BY: Michael T. McKeever Attorney I.b.#56129 Suite 5000 - Mellon Independence Center 701 Market Street Philadelphia, PA 19106 215-825-6320 Attorney for Plaintiff CITIMORTGAGE, INC. 1000 Technology Drive MS 730 OTallon, MO 63368-2240 Plaintiff IN THE COURT OF COMMON PLEAS of Cumberland County CIVIL ACTION - LAW VS. DONNA M. BENNETT Mortgagor(s) and Record Owner(s) ACTION OF MORTGAGE FORECLOSURE 3 Citadel Drive Camp Hill, PA 17011 Defendant(s) AFFIDAVIT PURSUANT TO RULE 3129 Term No. 08-3207 CITIMORTGAGE, 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: 3 Citadel Drive Camp Hill, PA 17011 1.Name and address of Owner(s) or Reputed Owner(s): DONNA M. BENNETT 3 Citadel Drive Camp Hill, PA 17011 2. Name and address of Defendant(s) in the judgment: DONNA M. BENNETT 3 Citadel Drive Camp Hill, PA 17011 3. Name and last known address of every judgment creditor whose judgment is a record lien on the property to be sold: DOMESTIC RELATIONS OF CUMBERLAND COUNTY PO Box 320 Carlisle, PA 17013 PA DEPARTMENT OF PUBLIC WELFARE - Bureau of Child Support Enforcement Health and Welfare Bldg. - Room 432 Harrisburg, PA 17105-2675 4. Name and address of the last recorded holder of every mortgage of record: SUMMIT FINANCIAL, LLC 13530 Dulles Technology Drive, Suite 600 Herndon, VA 20171 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 3 Citadel Drive Camp Hill, PA 17011 (attach separate sheet if more space is needed) I verify that the statements made in this affidavit are true and correct to the best of my personal knowledge or information and belief. I understand that false statements herein are made subject to the penalties of 18 Pa. C.S. Section 4904 relating to unswom falsification to authorities. DATED: November 7, 2008 GOLDBECK McCAFFERTY & McKEEVER BY: Michael T. McKeever, Esq. Attorney for Plaintiff c o .w Y f. „7 e ?: Citimortgage, Inc. VS Donna M. Bennett In the Court of Common Pleas of Cumberland County Pennsylvania Writ No. 2008-3207 Civil Term Michael Barrick, Deputy Sheriff, who being duly sworn according to law, states that on September 20, 2008 at 1153 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: Donna M. Bennett, by making known unto Donna M. Bennett personally, at 3 Citidel Drive, Camp Hill, Cumberland County, Pennsylvania its contents and at the same time handing to her personally the said true and correct copy of the same. Robert Bitner, Deputy Sheriff, who being duly sworn according to law, states that on October 11, 2008 at 0840 hours, he posted a true copy of the within Real Estate Writ, Notice, Poster and Description, in the above entitled action, upon the property of Donna M. Bennett, located at 3 Citadel Drive, Camp Hill, 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: Donna M. Bennett, by regular mail to her last known address of 3 Citadel Drive, Camp Hill, PA 17011. This letter was mailed under the date of October 7, 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 30.00 Poundage 22.04 Posting Handbills 15.00 Advertising 15.00 Law Library .50 Prothonotary 2.00 Mileage 32.00 Levy 15.00 Surcharge 20.00 Postpone Sale 40.00 Law Journal 473.00 Patriot News 444.71 Share of Bills 14.92 qb 4 9.' 2 p' $1124.17 V - So Answers. ., -A&0 R. Thomas Kline, Sheriff BY Real Estate Se •geant C- Gp1lq Zp -? Plaintiff Defendant(s) IN THE COURT OF COMMON PLEAS of Cumberland County CIVIL ACTION - LAW ACTION OF MORTGAGE FORECLOSURE No. 08-3207 AFFIDAVIT PURSUANT TO RULE 3129 Goldbeck McCafferty & McKeever BY: Michael T. McKeever Attorney I.1). #56129 Suite 5000 - Mellon Independence Center 701 Market Street Philadelphia, PA 19106 215-627-1322 Attorney for Plaintiff CITIMORTGAGE, INC. 1000 Technology Drive MS 730 O'Fallon, MO 63368-2240 VS. DONNA M. BENNETT (Mortgagor(s) and Record Owner(s)) 3 Citadel Drive Camp Hill, PA 17011 CITIMORTGAGE, 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: 3 Citadel Drive Camp Hill, PA 17011 l.Name and address of Owner(s) or Reputed Owner(s): DONNA M. BENNETT 3 Citadel Drive Camp Hill, PA 17011 2. Name and address of Defendant(s) in the judgment: DONNA M.BENNETT 3 Citadel Drive Camp Hill, PA 17011 3. Name and last known address of every judgment creditor whose judgment is a record lien on the property to be sold: DOMESTIC RELATIONS OF CUMBERLAND COUNTY PO Box 320 Carlisle, PA 17013 PA DEPARTMENT OF PUBLIC WELFARE - Bureau of Child Support Enforcement Health and Welfare Bldg. - Room 432 Harrisburg, PA 17105-2675 4. Name and address of the last recorded holder of every mortgage of record: SUMMIT FINANCIAL, LLC f 13530 Dulles Technology Drive, Suite 600 Herndon, VA 20171 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 3 Citadel Drive Camp Hill, PA 17011 (attach separate sheet if more space is needed) I verify that the statements made in this affidavit are true and correct to the b t of p onal knowledge or information and belief. I understand that false statements herein are made subject to"Je pe tie f I8 Pa. C.S. Section 4904 relating to unworn falsification to authorities. DATED: July 8, 2008 GOLDBECK McC RTY McKEEVER BY: Michael T. M Keever, Esq. Attorney for PI ' iff 08-3207 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. 1000 Technology Drive MS 730 O'Fallon, MO 63368-2240 VS. DONNA M. BENNETT Mortgagor(s) and Record Owner(s) 3 Citadel Drive Camp Hill, PA 17011 IN THE COURT OF COMMON PLEAS of Cumberland County Plaintiff CIVIL ACTION - LAW ACTION OF MORTGAGE FORECLOSURE Defendant(s Term No. 08-3207 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: BENNM, DONNA M. DONNA M. BENNETT 3 Citadel Drive Camp Hill, PA 17011 Your house at 3 Citadel Drive, Camp Hill, PA 17011 is scheduled to be sold at Sheriffs Sale on Wednesday, December 10, 2008, at 10:00 AM, in Commissioners Hearing Rm 2nd FL Courthouse to enforce the court judgment of $125,783.67 obtained by CITIMORTGAGE, 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 CITIMORTGAGE, 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. 08-3207 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 We 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. LEGAL SERVICES INC 8 Irvine Row Carlisle, PA 17013 717-243-9400 CUMBERLAND COUNTY BAR ASSOCIATION 2 Liberty Avenue Carlisle, PA 17013 08-3207 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: 717-243-9400 or. 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 hiip://www.phfa.org/consumers/homeowners/real.Mpx. 5). Call the Plaintiff (your lender) at and ask to speak to someone about Loss Mitigation or Home Retention options. 6). Call or contact our office to request the amount to bring the account current, or payoff the mortgage or request a Loan Workout / Home Retention Package. Call our toll free number at 1-866-413-2311 or via email at 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 66106FC. Para informacion en espanol puede communicarse con Loretta a1215-825-6344. All that certain parcel of land situate in the Township of Lower Allen, County of Cumberland, and State of Pennsylvania, being known and designated according to a survey of Ernest J. Walker P.E. dated April 7, 1970 as Lot No. 127 on the Plan of Lots known as "Part of Plan No. 2, Cedar Cliff Manor", which Plan was approved by the Commissioners of Lower Allen Township on January 12, 1955, and in recorded in the Office of the Recorder of Deeds, Cumberland County, Pennsylvania, in Plan Book 7, Page 13 Cumberland County, Pennsylvania, in Plan Book 7, Page 13. And also being described in deed as: All that certain lot or tract of land situate in the Township of Lower Allen, County of Cumberland and State of Pennsylvania, more particularly bounded and described as follows, according to a survey of Ernest J. Walker, P.E., dated April 7, 1970, to wit: Beginning at a point on the southern side of a 50 foot wide road known as Citadel Drive, which point measured along the southern side of Citadel Drive, which point measured along the southern side of Citadel Drive is 363.95 feet west of the southwest corner of Citadel Drive and Colgate Drive, and which point is alos at the northwest corner of Lot No. 126 on Part of Plan No. 2 Cedar Cliff Manor, recorded in the Office of the Recorder of Deeds in and for Cumberland County, Pennsylvania, in Plan Book 7, Page 13; thence at right angles to Citadel Drive South 01 degree 00 minutes East along the western line of Lot No. 126 aforesaid, 125 feet to a point at an iron pin on the northern line of Lot No. 130 on Plan No. 1, Cedar Cliff Manor, recorded in the Office of the Recorder of Deeds in and for Cumberland County, Pennsylvania, in Plan Book 6, Page 33; thence South 89 degrees 00 minutes West along the northern line of Lot NO. 128 on Plan No. 1, Cedar Cliff Manor, aforesaid 70 feet to a point at the eastern line of Lot No. 128 on Plan No. 1, Cedar Cliff Manor, aforesaid; thence at right angles to Citadel Drive North 01 degree 00 minutes West along the eastern line of Lot No. 128 aforesaid 125 feet to a point at the southern side of Citadel Drive; thence North 89 degrees 00 minutes East along the southern side of Citadel Drive 70 feet to a point, the place of beginning. Having thereon erected a dwelling house known and numbered as 3 Citadel Drive. Tax parcel no: 13-23-0547-589 WRIT OF EXECUTION and/or ATTACHMENT COMMONWEALTH OF PENNSYLVANIA) C017NTY OF CUMBERLAND) N008-3207 Civil CIVIL ACTION - LAW TO THE SHERIFF OF CUMBERLAND COUNTY: To satisfy the debt, interest and costs due CITIMORTGAGE, INC Plaintiff (s) From DONNA M BENNETT 3 CITADEL DRIVE CAMP HILL, PA 17011 (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 $ 125,783.67 L.L. $0.50 Interest FROM 7/09/08 TO DATE OF SALE PER DIEM AT $17.35 Atty's Comm % Atty Paid $162.00 Plaintiff Paid Due Prothy $2.00 Other Costs Date: JULY 14, 2008 (Seal) REQUESTING PARTY: Name MICHAEL T MCKEEVER, ESQ Address: SUITE 5000-MELLON INDEPENDENCE CENTER 701 MARKET STREET PHILADELPHIA, PA 19106 Attorney for: PLAINTIFF Telephone: 215-627-1322 Supreme Court ID No. 56129 C is R. Lon o notary By: Deputy Real Estate Sale #56 On August 28, 2008 the Sheriff levied upon the defendant's interest in the real property situated in Lower Allen Township, Cumberland County, PA Known and numbered as 3 Citadel Drive, Camp Hill more fully described on Exhibit "A" filed with this writ and by this reference 9 incorporated herein. G Date: August 28, 2008 By: A Real Es Sergeant CJ ?j 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: October 31, November 7 and November 14, 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. -1.1 c- Marie SWORN'TO AND SUBSCRIBED before me this 14 day of November.. 2008 C Notary NOTARIAL SEAL DEBORAH A COLLINS Notary Public CARLISLE BORO, CUMBERLAND COUNTY My Commission Expires Apr 28, 2010 MOM MOOM N Writ No. 2008-3207 Civil Citimortgage, Inc. vs. Donna M. Bennett Atty.: Michael McKeever All that certain parcel of land situ- ate in the Township of Lower Allen, County of Cumberland, and State of Pennsylvania, being known and designated according to a survey of Ernest J. Walker P.E. dated April 7, 1970 as Lot No. 127 on the P of as *Port of Plan No. 2, awmame,whtch Plan was approved by the Gomagcrs of Lower Allen Te s itp on January 12, 1955, and in recorded in the Office of the Recorder of Deeds, Cumberland County, Pennsylvania, in Plan Book 7, Page 13 Cumberland County, Pennsylvania, in Plan Book 7, Page 13. And also being described in deed as: All that certain lot or tract of land situate in the Township of Lower Al- len, County of Cumberland and State of Pennsylvania, more particularly bounded and described as follows, according to a survey of Ernest J. Walker, P.E., dated April 7, 1970, to wit: teguuung at a point on the south- ern side of a 50 foot wide road known as Citadel Drive, which point measured along the southern side of Citadel Drive, which point meas- ured along the southern side of Citadel Drive is 363.95 feet west of the southwest corner of Citadel Drive and Colgate Drive, and which point is alos at the northwest corner of Lot No. 126 on Part of Plan No. 2 Cedar Cliff Manor, recorded in the Office of the Recorder of Deeds in and for Cumberland County, Pennsylvania, in Plan Book 7, Page 13; thence at right angles to Citadel Drive South 01 degree 00 minutes East along the western line of Lot No. 126 aforesaid, 125 feet to a point at an iron pin on the northern line of Lot No. 130 on Plan No. 1, Cedar Cliff Manor, re- corded in the Office of the Recorder of Deeds in and for Cumberland County, Pennsylvania, in Plan Book 6, Page 33; thence South 89 degrees 00 minutes West along the northern line of Lot NO. 128 on Plan No. 1, Cedar Cliff Manor, aforesaid 70 feet to a point at the eastern line of Lot No. 128 on Plan No. 1, Cedar Cliff Manor, aforesaid; thence at right angles to Citadel Drive North 01 degree 00 minutes West along the eastern line of Lot No. 128 aforesaid 125 feet to a point at the southern side of Citadel Drive; thence North 89 degrees 00 minutes Est along the sesxdw= aide of Citadel Drive 70 feet to a point, the place of beginning. Having thereon erected a dwelling house known and numbered as 3 Citadel Drive. Tax parcel no.: 13-23-0547-589. -- ",e Patriot-News Co. 812 Market St. Harrisburg, PA 17101 Inquiries - 717-255-8213 CUMBERLAND COUNTY SHERIFFS OF CUMBERLAND COUNTY COURT HOUSE thfPatriot-d(ws 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 Joseph A. Dennison, being duly sworn according to law, deposes and says: That he is the Assistant 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: 10/29/08 11/05/08 11/12/08 Sworn to and c ibed before e t s 2 ay of November, 2008 A.D. / ( Notary Public COMMONWEALTH OF PENNSYLVANIA Notarial seal SWft L. KWOF, Notary PU1* My?C fl ExpkE*VW w Nov 26, 2011 Member, Pennsylvania AssodaWn of Notaries Real Estate Sale No. 56 Writ No. 2008-3207 Civil Term Citimortgage, Inc. VS Donna M. Bennett Attorney Michael McKeever LEGAL DESCRIPTION All that certain parcel of land situate in the Township of Lower Allen, County of Cumberland, and State of Pennsylvania, being known and designated according to a survey of Ernest J. Walker P.E. dated April 7, 1970 as Lot No. 127 on the Plan of Lots known as "Part of Plan No. 2, Cedar Cliff Manor", which Plan was approved by the Commissioners of Lower Allen Township on January 12, 1955, and in recorded in the Office of the Recorder of Deeds, Cumberland County, Pennsylvania, in Plan Book 7, Page 13 Cumberland County, Pennsylvania, in Plan Book 7, Page 13. And also being described in deed as: All that certain lot or tract of land situate in the Township of Lower Allen, County of Cumberland and State of Pennsylvania, more particularly bouWed and described as follows, according to a survey of Ernest L Wall=, P E., dated April 7, 1970, to wit: Beginning at a point on the swxhern side of a 50 foot wide road known as Citadel Drive, which point measured along the southern side of Citadel Drive, which point measured along the southern side of Citadel Drive is 363.95 feet west of the southwest comer of Citadel Drive and Colgate Drive, and which point is also at the northwest comer of Lot No. 126 on Pats of Plan No. 2 Cedar Cliff Manor, recorded in the office of the Recorder of Deeds in and for Cumberland County, Pennsylvania, in Plan Book 7, Page 13; thence at right angles to Citadel Drive South 01 degree 00 minutes East along the western line of Lot No. 126 aforesaid, 125 feet to a point at an iron pin on the northern line of Lot No. 130 on Plan No-1, Cedar Cliff Manor, recorded in the Office of the Recorder of Deeds in and for Cumberland County, Pennsylvania, in Plan Book 6, Page 33; thence South 89 degrees 00 minutes West along the northern line of Lot NO. 128 on Plan No. 1, Cedar Cliff Manor, aforesaid 70 feet to a point at the eastern line of Lot No. 128 on Plan No.l, Cedar Cliff Manor, aforesaid; thence at right angles to Citadel Drive North 01 degree 00 minutes West along the eastern line of Lot No. 128 aforesaid 125 feet to a point at the southern side of Citadel Drive; thence North 89 degrees 00 minutes East along the southern side of Citadel Drive 70 feet to a point, the place of beginning. Having thereon erected a dwelling house known and numbered as 3 Citadel Drive. Tax parcel no: 13-23-0547-589 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 19106-1532 215-627-1322 Attorney for Plaintiff CITIMORTGAGE, INC. 1000 Technology Drive MS 730 O'Fallon, MO 63368-2240 Plaintiff vs. DONNA M. BENNETT Mortgagor(s) and Record Owner(s) 3 Citadel Drive Camp Hill, PA 17011 Defendant(s) IN THE COURT OF COMMON PLEAS of Cumberland County CIVIL ACTION - LAW ACTION OF MORTGAGE FORECLOSURE No. 08-3207 PRAECIPE FOR WRIT OF EXECUTION TO THE PROTHONOTARY: Issue Writ of Execution in the above matter: Amount Due Interest from 03/28/2009 to Date of Sale per diem at $17.35 (Costs to be added) Q+ W ? N O O ? op ? ??pa„ ?w ?`M,, U ? U ,fib ? 3 0 d O O s?+ M ti Q u Q ti) U UWa H 4 S G H i U v ? y U N y U M y O d ? ?pd.N i c?, ? r P+ N F?^o w °o a- V Y V) y -b4 o ° a o O 000 a ? -o F _ .y Michael T. McKeever Attorney I.D. #56129 Suite 5000 - Mellon Independence Center 701 Market Street Philadelphia, PA 19106-1532 215-627-1322 Attornev for Plaintiff CITIMORTGAGE, INC. 1000 Technology Drive MS 730 O'Fallon, MO 63368-2240 vs. DONNA M. BENNETT Mortgagor(s) and Record Owner(s) 3 Citadel Drive Camp Hill, PA 17011 Plaintiff Defendant(s) IN THE COURT OF COMMON PLEAS of Cumberland County CIVIL ACTION - LAW ACTION OF MORTGAGE FORECLOSURE NO. 08-3207 CERTIFICATION AS TO THE SALE OF REAL PROPERTY I, Michael T. McKeever, Esquire hereby certify that I am the attorney of record for the A tiff in this action, and I further certify that this property is subject to Act 91 of 1983 and the Plaintiff has complied i all the provisions of the Act. Michael T. Attorney fi ?= f ' •?? .:?? (t1 rtn ; ?: ;, a ?? r?r?? ?_ ? , ,,. ,? ??. , ._., --ca `?? ? ? .: ?. , ' ? ?,? ? ? . s 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 Attomey for Plaintiff CITIMORTGAGE, INC. 1000 Technology Drive MS 730 O'Fallon, MO 63368-2240 IN THE COURT OF COMMON PLEAS Plaintiff vs. DONNA M. BENNETT (Mortgagor(s) and Record Owner(s)) 3 Citadel Drive Camp Hill, PA 17011 Defendant(s) of Cumberland County CIVIL ACTION - LAW ACTION OF MORTGAGE FORECLOSURE No. 08-3207 AFFIDAVIT PURSUANT TO RULE 3129 CITIMORTGAGE, 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: 3 Citadel Drive Camp Hill, PA 17011 1.Name and address of Owner(s) or Reputed Owner(s): DONNA M. BENNETT 3 Citadel Drive Camp Hill, PA 17011 2. Name and address of Defendant(s) in the judgment: DONNA M.BENNETT 3 Citadel Drive Camp Hill, PA 17011 3. Name and last known address of every judgment creditor whose judgment is a record lien on the property to be sold: PA DEPARTMENT OF PUBLIC WELFARE - Bureau of Child Support Enforcement Health and Welfare Bldg. - Room 432 Harrisburg, PA 17105-2675 DOMESTIC RELATIONS OF CUMBERLAND COUNTY PO Box 320 Carlisle, PA 17013 4. Name and address of the last recorded holder of every mortgage of record: SUMMIT FINANCIAL, LLC 13530 Dulles Technology Drive, Suite 600 Herndon, VA 20171 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 3 Citadel Drive Camp Hill, PA 17011 (attach separate sheet if more space is needed) I verify that the statements made in this affidavit are true and correct to the best of my er nal knowledge or information and belief. I understand that false statements herein are made subject to the penal es f 1 Pa. C.S. Section 4904 relating to unsworn falsification to authorities. DATED: March 27, 2009 GOLDBECK McC FFERTY & McKEEVER BY: Michael T. cKeever, Esq. Attorney for P intiff s . 'J C73 l G 08-3207 r 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. 1000 Technology Drive MS 730 O'Fallon, MO 63368-2240 vs. DONNA M. BENNETT Mortgagor(s) and Record Owner(s) 3 Citadel Drive Camp Hill, PA 17011 IN THE COURT OF COMMON PLEAS of Cumberland County Plaintiff CIVIL ACTION - LAW ACTION OF MORTGAGE FORECLOSURE Term No. 08-3207 Defendants THIS LAW FIRM IS A DEBT COLLECTOR AND WE ARE ATTEMPTING TO COLLECT A DEBT. THIS NOTICE IS SENT TO YOU IN AN ATTEMPT TO COLLECT A DEBT. ANY INFORMATION OBTAINED FROM YOU WILL BE USED FOR THAT PURPOSE. NOTICE OF SHERIFF'S SALE OF REAL PROPERTY TO: BENNETT, DONNA M. DONNA M. BENNETT 3 Citadel Drive Camp Hill, PA 17011 Your house at 3 Citadel Drive, Camp Hill, PA 17011 is scheduled to be sold at Sheriffs Sale on Wednesday, September 02, 2009, at 10:00 AM, in Commissioners Hearing Rm 2nd FL Courthouse to enforce the court judgment of $125,783.67 obtained by CITIMORTGAGE, 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 CITIMORTGAGE, 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 tiling 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. 08-3207 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. 8. You may contact the Foreclosure Resource Center: http://www.philadelphiafed.org/foreclosure/ 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 717-243-9400 CUMBERLAND COUNTY BAR ASSOCIATION 2 Liberty Avenue Carlisle. PA 17013 08-3207 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: 717-243-9400 or. 2). Call the Consumer Credit Counseling Agency at 1-800-989-2227 for free counseling. 3). Visit HUD'S website www.hud. ov for Help for Homeowners Facing the Loss of Their Homes. 4). Pennsylvania Housing Finance Agency also offers other loan programs that may assist homeowners in default. Please See the PHFA website http://www.phfa.org/consumers/homeowners/real.aspx. 5). Call the Plaintiff (your lender) at and ask to speak to someone about Loss Mitigation or Home Retention options. 6). Call or contact our office to request the amount to bring the account current, or payoff the mortgage or request a Loan Workout / Home Retention Package. Call our toll free number at 1-866-413-2311 or via email at 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 Courtenay Dunn who can be reached at 215-825-6311 or Fax: 215-825- 6411. Please reference our Attorney File Number of 66106FC. Para infonnacion en espanol puede communicarse con Loretta a] 215-825-6344. WRIT OF EXECUTION and/or ATTACHMENT COMMONWEALTH OF PENNSYLVANIA) COUNTY OF CUMBERLAND) NO 08-3207 Civil CIVIL ACTION - LAW TO THE SHERIFF OF CUMBERLAND COUNTY: To satisfy the debt, interest and costs due CITIMORTGAGE, INC., Plaintiff (s) From DONNA M. BENNETT (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 $125,783.67 L.L. Interest from 3/28/09 to Date of Sale per diem at $17.35 Atty's Comm % Due Prothy $2.00 Atty Paid $1,307.67 Other Costs to be Added Plaintiff Paid Date: 3/30/09 Curtis R4,rothon ary (Seal) By: Deputy REQUESTING PARTY: Name: MICHAEL T. MCKEEVER, ESQUIRE Address: GOLDBECK McCAFFERTY & McKEEVER SUITE 5000 - MELLON INDEPENDENCE CENTER 701 MARKET STREET PHILADELPHIA, PA 19106-1532 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 66106FC CF: 05/21/2008 SD: 09/02/2009 $125,783.67 CITIMORTGAGE, INC. 1000 Technology Drive MS 730 O'Fallon, MO 63368-2240 vs. DONNA M. BENNETT Mortgagor(s) and Record Owner(s) 3 Citadel Drive Camp Hill, PA 17011 IN THE COURT OF COMMON PLEAS of Cumberland County Plaintiff Defendant(s) CERTIFICATE OF SERVICE PURSUANT TO Pa.R.C.P. 3129.2 (c) (2) Term No. 08-3207 Michael T. McKeever, 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 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. Respectfullyn sut?tted, l- BY: Michael T. McKeever, Esquire Attorney for Plaintiff CIVIL ACTION - LAW ACTION OF MORTGAGE FORECLOSURE a rn (o C 00 Ji l l 0 y i r. QW C t -Q N N j, O u t -0 (t !1 4 .LNG O m __ C? rA ( ?Qsir,e? N O O O C E - c 7 m N U/ ? V a ? T 'C CL % 4. ts '* _ t E 0 a c ffi z _ a ? o E R W 0) j°j ?: E E cc ce a i ° 00110 jW? u-) O o j CL to U) U _j U) ii p n in '6 Q O O ~ _1 0 Q C Z r w W ? .: ttz at U O E v w o ?E w r- < C-4 Z0) O `o 010 U Q O C V C) c, c, a ~ } 1i=* F mn co - F a UOt?_ Q w y t !)I - x wz O Hp C go$ d= Q? a 00000 00 LO cn ? 00 ? amii 0- v i z ?MU g a O a ffi t D U) W Q -a c~n ?xo jREC14 cc? `ZQ ? oow M c6 Z9 5p=07 r (V c7 cl tv (O f? CD :3 c d a c 0 a 0 C T F- T .c d E 0 V N O N CD a N /U- ti M co a. rn O O N O O O w co m ?o c 7 O U c ro E U U LL O co L z z w m Q z z O 0 u c)I- (Ls USPS - Track & Confirm Search Resehs Page 1 of I Labei/Receipt Number: 7111 4342 3630 0056 8433 Track & Confirm Status: Delivered Enter Label/Receipt Number. Your item was delivered at 9:40 am on April 18, 2009 in MECHANICSBURG, PA 17055. A proof of delivery record may be available through your local Post Office for a fee. Additional information is stored in files offline. A request to restore this information has been submitted and is currently pending. StteN4P Customer Service Forms GOAsenices careers. Copyright* 2009 USPS. All Rights Reserved. No FEAR Act EEO Data FOIA Privacy Policy Terru of Use ? i Customer Gat Business b+t„-I/tr1r r-nfrml em; ,ienc rnm/PTCTntPrne-.tWPh/Tnte.rT.ahe.]Tnmtirv.do 8/6/2009 Direct Query - Intranet `Track/Confirm - Intranet Items Inquiry Item Number: 1.11 4342 3630 0056 8433 This item was delivered on 04/18/2009 at 09:40 Signature: A ?L4 Address: Y y l AGA \ _- ^ pp L-A ( Eraer'Request Ty Pe and Item Number'! Quick Search r Extensive Search C Explanation of Quick and Extensive 5earcha-q Submit Version 1.0 Inquire on multiple items. Go to the Product Tracking System Home Page. Page 1 of 1 https://pts.usps.gov/pts/imageView.do 8/10/2009 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. 1000 Technology Drive MS 730 OTallon, MO 63368-2240 Plaintiff IN THE COURT OF COMMON PLEAS of Cumberland County CIVIL ACTION - LAW VS. DONNA M. BENNETT Mortgagor(s) and Record Owner(s) 3 Citadel Drive Camp Hill, PA 17011 ACTION OF MORTGAGE FORECLOSURE Term No. 08-3207 Defendant(s) AFFIDAVIT PURSUANT TO RULE 3129 CITIMORTGAGE, 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: 3 Citadel Drive Camp Hill, PA 17011 1.Name and address of Owner(s) or Reputed Owner(s): DONNA M. BENNETT 3 Citadel Drive Camp Hill, PA 17011 2. Name and address of Defendant(s) in the judgment: DONNA M. BENNETT 3 Citadel Drive Camp Hill, PA 17011 3. Name and last known address of every judgment creditor whose judgment is a record lien on the property to be sold: DOMESTIC RELATIONS OF CUMBERLAND COUNTY PO Box 320 Carlisle, PA 17013 PA DEPARTMENT OF PUBLIC WELFARE - Bureau of Child Support Enforcement Health and Welfare Bldg. - Room 432 Harrisburg, PA 17105-2675 4. Name and address of the last recorded holder of every mortgage of record: SUMMIT FINANCIAL, LLC 13530 Dulles Technology Drive, Suite 600 Herndon, VA 20171 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 3 Citadel Drive Camp Hill, PA 17011 (attach separate sheet if more space is needed) I verify that the statements made in this affidavit are true and correct to the best of my personal knowledge or information and belief. I understand that false statements herein are made subject to the penalties of 18 Pa. C. S. Section 4904 relating to unworn falsification to authorities. DATED: August 17, 2009 l- GOLDBECK McCAFFERTY & McKEEVER BY: Michael T. McKeever, Esq. Attorney for Plaintiff OF THE 2009 AUG 19 PM 1: 4 4 Cl3t? ,,"juNiY PEi•`,5`+Er JH COMMONWEALTH OF PENNSYLVANIA COUNTY OF CUMBERLAND ISS: I, Robert P. Ziegler, Recorder of Deeds in and for said County and State do hereby certify that the Sheriff's Deed in which CITIMORTGAGE INC is the grantee the same having been sold to said grantee on the 2ND day of SEPT A.D., 2009, under and by virtue of a writ Execution issued on the 30TH day of MARCH, A.D., 2009, out of the Court of Common Pleas of said County as of Civil Term, 2008 Number 3207, at the suit of CITIMORTGAGE INC against DONNA M[ BENNETT is duly recorded as Instrument Number 200934139. IN TESTIMONY WHEREOF, I have hereunto set my hand and seal of said office this A.D. ;L- G f f day of `' Recorder of Deeds Sheriffs Office of Cumberland County R Thomas Kline` Sher Ronny R Anderson Chief Deputy Jody S Smith Civil Process Sergeant Edward L Schorpp Solicitor CITIMORTGAGE, Inc. vs. Donna M Bennett Y?y?tti'•s, 09 ?ari:i???tt ?{G r1t r4 -r 11LED-'-OFr ICE CF Tt Y,c F A i i 1-NIOTAW 20090("T-5 A1411:04 ?i•?r? ?J?J t y Case Number 2008-3207 SHERIFF'S RETURN OF SERVICE 06/25/2009 03:33 PM - Gerald Worthington, Deputy Sheriff, who being duly sworn according to law, states that on 6/25/09 at 1532 hours, he posted a true copy of the within Real Estate Writ, Notice, Poster and Description, in the above entitled action, upon the property of Donna M. Bennett, located at, 3 Citadel Drive, Camp Hill, Cumberland County, Pennsylvania according to law. 08/10/2009 Noah Cline, Deputy Sheriff, who being duly sworn according to law, states that on 8/10/09 at 2001 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: Donna M. Bennett, by making known unto, Donna M. Bennett, personally, at, 6219 Stanford Court, Mechanicsburg, Cumberland County, Pennsylvania its contents and at the same time handing to her personally the said true and correct copy of the same. 09/03/2009 R. Thomas Kline, Sheriff, who being duly sworn according to law, states that after due and legal notice had been given according to law, he exposed the within described premises at public venue or outcry at the Courthouse, Carlisle, Cumberland County, Pennsylvania on September 2, 2009 at 10:00 o'clock A.M. He sold the same for the sum of $1.00 to Attorney Michael McKeever, on behalf of, CITIMORTGAGE, Inc, of, 5280 Corporate Drive, Mail Code 3103, Frederick, MD, 21703, being the buyer in this execution, paid to Sheriff R. Thomas Kline the sum of $ 1,058.84 SHERIFF COST: $1,058.84 ? September 10, 2009 i0113161t 9rv SO ANSWERS, R THOMAS KLINE, SHERIFF 00 al? 1- u? ?iJ vv ?l?Z r., -? ? ? J Y S? Goldbeck McCafferty & McKeever BY: Mi; hael T' McKeever Attorney I.D. #56129 Suite 5000 - Mellon Independence Center 701 Market Street Philadelphia, PA 19106-1532 215-627-1322 Attorney for Plaintiff CITIMORTGAGE, INC. 1000 Technology Drive MS 730 O'Fallon, MO 63368-2240 vs. DONNA M. BENNETT (Mortgagor(s) and Record Owner(s)) 3 Citadel Drive Camp Hill, PA 17011 Plaintiff Defendant(s) IN THE COURT OF COMMON PLEAS of Cumberland County CIVIL ACTION - LAW ACTION OF MORTGAGE FORECLOSURE No. 08-3207 AFFIDAVIT PURSUANT TO RULE 3129 CITIMORTGAGE, 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: 3 Citadel Drive Camp Hill, PA 17011 L Name and address of Owner(s) or Reputed Owner(s): DONNA M. BENNETT 3 Citadel Drive Camp Hill, PA 17011 2. Name and address of Defendant(s) in the judgment: DONNA M. BENNETT 3 Citadel Drive Camp Hill, PA 17011 3. Name and last known address of every judgment creditor whose judgment is a record lien on the property to be sold: PA DEPARTMENT OF PUBLIC WELFARE - Bureau of Child Support Enforcement Health and Welfare Bldg. - Room 432 Harrisburg, PA 17105-2675 DOMESTIC RELATIONS OF CUMBERLAND COUNTY PO Box 320 Carlisle, PA 17013 4. Name and address of the last recorded holder of every mortgage of record: SUMMIT FINANCIAL, LLC 13530 Dulles Technology Drive, Suite 600 Herndon, VA 20171 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 3 Citadel Drive Camp Hill, PA 17011 (attach separate sheet if more space is needed) I verify that the statements made in this affidavit are true and correct to the best of my er nal knowledge or information and belief. I understand that false statements herein are made subject to the penal es f 1 Pa. C.S. Section 4904 relating to unsworn falsification to authorities. DATED: March 27. 2009 GOLDBECK McC FFERTY & McKEEVER BY: Michael T. cKeever, Esq. Attorney for P aintiff 08-3207 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., 1000 Technology Drive MS 730 O'Fallon, MO 63368-2240 vs. DONNA M. BENNETT Mortgagor(s) and Record Owner(s) 3 Citadel Drive Camp Hill, PA 17011 IN THE COURT 017 COMMON PLEAS of Cumberland County Plaintiff CIVIL ACTION - LAW ACTION OF MORTGAGE FORECLOSURE Term No. 03-3207 Defendants THIS LAW FIRM IS A DEBT COLLECTOR AND WE ARE ATTEMPTING TO COLLECT A DEBT. THIS NOTICE IS SENT TO YOU IN AN ATTEMPT TO COLLECT A DEBT. ANY INFORMATION OBTAINED FROM YOU WILL BE USED FOR THAT PURPOSE. NOTICE OF SHERIFF'S SALE OF REAL PROPERTY TO: BENNETT, DONNA M. DONNA M. BENNETT 3 Citadel Drive Camp Hill, PA 17011 Your house at 3 Citadel Drive, Camp Hill, PA 17011 is scheduled to be sold at Sheriffs Sale on Wednesday, September 02, 2009, at 10:00 AM, in Commissioners Hearing Rm 2nd FL Courthouse to enforce the court judgment of $125,783.67 obtained by CITIMORTGAGE, INC. aeainst 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 CITIMORTGAGE, 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. 08-3207 3. You may also be able to stop the sale tlfl-ough 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. 8. You may contact the Foreclosure Resource Center: http://www.philadelphiafed.org/foreclosure,/ 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 717-243-9400 CUMBERLAND COUNTY BAR ASSOCIATION 2 Liberty Avenue Carlisle. PA 17013 08-3207 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: 717-243-9400 or. 2). Call the Consumer Credit Counseling Agency at 1-800-98'9-2227 for free counseling. 3). Visit HUD'S website www.hud.gov for Help for Homeowners Facing the Loss of Their Homes. 4). Pennsylvania Housing Finance Agency also offers other loan programs that may assist homeowners in default. Please See the PHFA website http://www.phfa.org/consumers/homeowners/real.aspx. 5). Call the Plaintiff (your lender) at and ask to speak to someone about Loss Mitigation or Home Retention options. 6). Call or contact our office to request the amount to bring the account current, or payoff the mortgage or request a Loan Workout / Home Retention Package. Call our toll free number at 1-866-413-2311 or via email at homeretentionggoldbecklaw.com. Call Seth at 215-825-6329 or fax 215-825-6429. The figure and/or package you requested will be mailed to the address that you request or faxed if you leave a message with that information. The attorney in charge of our firm's Homeowner Retention Department is Courtenay Dum-i who can be reached at 215-825-6311 or Fax: 215-825- 6411. Please reference our Attorney File Number of 66106FC. Para infonnacion en espanol puede communicarse con Loretta al 215-825-6344. All that certain parcel of land situate in the Township of Lower Allen, County of Cumberland, and State of Pennsylvania, being known and designated according to a survey of Ernest J. Walker P.E. dated April 7, 1970 as Lot No. 127 on the Plan of Lots known as "Part of Plan No. 2, Cedar Cliff Manor", which Plan was approved by the Commissioners of Lower Allen Township on January 12, 1955, and in recorded in the Office of the Recorder of Deeds, Cumberland County, Pennsylvania, in Plan Book 7, Page 13 Cumberland County, Pennsylvania, in Plan Book 7, Page 13. And also being described in deed as: All that certain lot or tract of land situate in the Township of Lower Allen, County of Cumberland and State of Pennsylvania, more particularly bounded and described as follows, according to a survey of Ernest J. Walker, P.E., dated April 7, 1970, to wit: Beginning at a point on the southern side of a 50 foot wide road known as Citadel Drive, which point measured along the southern side of Citadel Drive, which point measured along the southern side of Citadel Drive is 363.95 feet west of the southwest corner of Citadel Drive and Colgate Drive, and which point is alos at the northwest corner of Lot No. 126 on Part of Plan No. 2 Cedar Cliff Manor, recorded in the Office of the Recorder of Deeds in and for Cumberland County, Pennsylvania, in Plan Book 7, Page 13; thence at right angles to Citadel Drive South 01 degree 00 minutes East along the wester line of Lot No. 126 aforesaid, 125 feet to a point at an iron pin on the northern line of Lot No. 130 on Plan No. 1, Cedar Cliff Manor, recorded in the Office of the Recorder of Deeds in and for Cumberland County, Pennsylvania, in Plan Book 6, Page 33; thence South 89 degrees 00 minutes West along the northern line of Lot NO. 128 on Plan No. 1, Cedar Cliff Manor, aforesaid 70 feet to a point at the eastern tine of Lot No. 128 on Plan No. 1, Cedar Cliff Manor, aforesaid; thence at right angles to Citadel Drive North 01 degree 00 minutes West along the eastern line of Lot No. 128 aforesaid 125 feet to a point at the southern side of Citadel Drive; thence North 89 degrees 00 minutes East along the southern side of Citadel Drive 70 feet to a point, the place of beginning. Having thereon erected a dwelling house known and numbered as 3 Citadel Drive. Tax parcel no: 13-23-0547-589 BEING KNOWN AS 3 CITADEL DRIVE, CAMP HILL PA 17011 WRIT OF EXECUTION and/or ATTACHMENT COMMONWEALTH OF PENNSYLVANIA) NO 08-3207 Civil COUNTY OF CUMBERLAND) CIVIL ACTION - LAW TO THE SHERIFF OF CUMBERLAND COUNTY: To satisfy the debt, interest and costs due CITIMORTGAGE, INC., Plaintiff (s) From DONNA M. BENNETT (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 $125,783.67 L.L. Interest from 3/28/09 to Date of Sale per diem at $17.35 Atty's Comm % Due Prothy $2.00 Arty Paid $1,307.67 Other Costs to be Added Plaintiff Paid Date: 3/30/09 (Seal) 12-P kx urtis R. g, Protho tary By: Deputy REQUESTING PARTY: Name: MICHAEL T. McKEEVER, ESQUIRE Address: GOLDBECK McCAFFERTY & McKEEVER SUITE 5000 - MELLON INDEPENDENCE CENTER 701 MARKET STREET PHILADELPHIA, PA 19106-1532 Attorney for: PLAINTIFF Telephone: 215-627-1322 Supreme Court ID No. 56129 Real Estate Sale # On May 4, 2009 the Sheriff levied upon the defendant's interest in the real property situated in Lower Allen Township, Cumberland County, PA Known and numbered as 3 Citidel Drive, Camp Hill, more fully described on Exhibit "A" filed with this writ and by this reference incorporated herein. Date: May 4, 2009 By: l Rea state Coordinator ??I The Patriot-News Co. 812 Market St. Harrisburg, PA 17101 Inquiries - 717-255-8213 CUMBERLAND COUNTY SHERIFFS OF CUMBERLAND COUNTY COURT HOUSE CARLISLE PA 17013 the Patriot News Now you know THE PATRIOT NEWS THE SUNDAY PATRIOT NEWS Proof of Publication Under Act No. 587, Approved May 16, 1929 Commonwealth of Pennsylvania, County of Dauphin) s:s Marianne Miller, being duly sworn according to law, deposes and says: That she is a Staff Accountant 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 she 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 she 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: 07/24/09 Sworn to and sutrscribed before me this?l4 ay f August, 2009 A.D. r' Notary Public COMMONWEALTH OF PE=NNSYLVANIA Notarial Seal Sherrie L. Kisner, Notary Pubic City Of Harrisburg, Daulphin County My Commission EVires Nov. 26, 2011 07/31/09 08/07/09 Member, Pennsylvania Association of Notaries sale MD. 6 Writ No. 20011,41247 Chrll TWM CfTWMQAQE, Inc. vs. Donna M Tne t Atty: Michael cKon. w All that certain parcel of land situate in the Township of : L wer Allen, ' County of Cumberland, and State of Pennsylvania; being known and designated`according to a survey of lamest L WaikerP.E. dated April, 7,1970 as Lot No. 1Z7 on the Plan of iota known as "Part of Plan No: 2, Cedar Cliff Mama", which Plan was apWmd,by tbe.Commimioo? of Power Alien lbvmship on JaWary, 12,195 , and in recorded in the. Office of the Recorder of Deeds, Cumberland County, Penmsyl in Plan Book 7, Page 13 Cum land County, Pennsylvania, In Phm Book 7, Page 13. And also being described in deed as; AD ft certain lot or tract of land situate in the Township of Lower Allen, County of Cumberland and State of Pennsylvania, more,?,patticularly bounded and &scribed as follows, according to a survey of Ernest J. Walker, .B.,, dated April 7, 1970, to wit: Beginning at a point on the southern side of a 501aot wide road known as Citadel Drive, which point measured along the southern side of Citadel Drive, which point measured along the southern side of Citadel Drive is 363.95 feet west of the sonthweat corw'ae; Clhxil Drive and Colgate Dd and which.pomrt is" at the northwest comer of Lot No. 126 00 Part of Plan No. 2 Cedar Cliff Maoot, recorded in the Office of the Recmder of Dieds in and for Cumberland County, Peamyivnaia, in Plan Boole 7, Page 13; thence at right 040 to OUM Derive Soup 01 degree OD rubintt Elan along the western line of Lot Nq,126,aforts9A 125 fat a Point at an iron pin on the nort tern be of Lot No. 130 on Plan No. 1, Ceder Cliff 'Maw,, recorded in the Office of the Iiww wderv of &Z in area for Cumberland County, PftWylvan*, in , Plan Book 6, Page 33; thence South 89 degrees 00 minutes Woo along the northern line of Lm NO. 128, on Plan No. 1, Cedar Cliff Manor, aforesaid 70 feat to a point at the eastern line of Lot No. 128 on Plan No. 1. Cedar Cliff Mallet aforesaid; thence at right angles to Citadel Drive Nardi 01 degree 00 minutes West along the eastern line of Lot No. 128 aforesaid 125 feet to a point at the southern side of Citadel Drive; the= North 89 degrees 00 minutes East along the southern side of Citadel Drive 70 feet to a point, the phase of beginning. Having thereon erected a dwelling house known and qum4m'ed as 3 Citadel Drive. Tax parcel ®o: 13.WW-5119 MfNCi KNOWN AS, 3 C MM DRM CAMP HPLLPA 17011 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 24, July 31 and August 7, 2009 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, SWORNTO AND SUBSCRIBED before me this ,=daf Au ust 2009 Notary NOTARIAL SEAL DEBORAH A COLLINS Notary Public CARLISLE BORO, CUMBERLAND COUNTY My Commission Expires Apr 28, 2010 REAL ESTATE SALE NO. 6 Writ No. 2008-3207 Civil Citimortgage, Inc. VS. Donna M. Bennett Atty.: Michael McKeever All that certain parcel of land situ- ate in the Township of Lower Allen, County of Cumberland, and State of Pennsylvania, being known and designated according to a survey of Ernest J. Walker P. E. dated April 7, 1970 as Lot No. 127 on the Plan of Lots known as "Part of Plan No. 2, Cedar Cliff Manor", which Plan was approved by the Commissioners of Lower Allen Township on January 12, 1955, and in recorded in the Office of the Recorder of Deeds, Cumberland County, Pennsylvania, in Plan Book 7, Page 13 Cumberland County, Pennsylvania, in Plan Book 7, Page 13. And also being described in deed as: All that certain lot or tract of land situate in the Township of Lower Al- len, County of Cumberland and State of Pennsylvania, more particularly bounded and described as follows, according to a survey of Ernest J. Walker, P.E., dated April 7, 1970, to wit: Beginning at a point on the southern side of a 50 foot wide road known as Citadel Drive, which point measured along the southern side of Citadel Drive, which point mea- sured along the southern side of Citadel Drive is 363.95 feet west of the southwest corner of Citadel Drive and Colgate Drive, and which point is alos at the northwest corner of Lot No. 126 on Part of Plan No. 2 Cedar Cliff Manor, recorded in the Office of the Recorder of Deeds in and for Cumberland County, Pennsylvania, in Plan Book 7, Page 13; thence at right angles to Citadel Drive South 01 degree 00 minutes East along the western line of Lot No. 126 aforesaid, 125 feet to a point at an iron pin on the northern line of Lot No. 130 on Plan No. 1, Cedar Cliff Manor, re- corded in the Office of the Recorder of Deeds in and for Cumberland County, Pennsylvania, in Plan Book 6, Page 33; thence South 89 degrees 00 minutes West along the northern line of Lot NO. 128 on Plan No. 1, Cedar Cliff Manor, aforesaid 70 feet to a point at the eastern line of Lot No. 128 on Plan No. 1, Cedar Cliff Manor, aforesaid; thence at right angles to Citadel Drive North 01 degree 00 minutes West along the eastern line of Lot No. 128 aforesaid 125 feet to a point at the southern side of Citadel Drive; thence North 89 degrees 00 minutes East along the southern side of Citadel Drive 70 feet to a point, the place of beginning. Having thereon erected a dwelling house known and numbered as 3 Citadel Drive. Tax parcel no: 13-23-0547-589. BEING KNOWN AS 3 CITADEL DRIVE, CAMP HILL PA 17011. KML LAW GROUP,P.C. Suite 5000 -BNY Independence Center u 701 Market Street � = HO N C TA r; Philadelphia, PA 19106 2313 OCT 15 0111: 13 215-627-1322 Attorney for Plaintiff CUMBERLAND COUNTY PENNSYLVANIA CITIMORTGAGE, INC. IN THE COURT OF COMMON PLEAS 1000 Technology Drive MS 730 OF Cumberland COUNTY O'Fallon,MO 63368-2240 vs. Term No. 08-3207 DONNA M. BENNETT Mortgagor(s) and Record Owner(s) 3 Citadel Drive Camp Hill, PA 17011 PRAECIPE TO SATISFY JUDGMENT TO THE PROTHONOTARY: Kindly mark the judgment in the above matter satisfied of record. By: KML LAW GROUP,P.C. Michael McKeever Pa. ID 56129 Jay E.Kivitz Pa.ID 26769 Lisa Lee Pa.ID 78020 Thomas Puleo Pa.ID 27615 (David Fein Pa. ID 82628 Jill P.Jenkins Pa. ID 306588 Alyk L.Oflazian Pa.ID 312912 Salvatore Filippello,Attorney ID 313897 Attorneys for Plaintiff OVA q.stp3/ a/ (IA 75` 37 aquFn1 KML LAW GROUP, P.C. Suite 5000- BNY Independence Center 701 Market Street Philadelphia, PA 19106 215-825-6321 Attorney for Plaintiff CITIMORTGAGE, INC. 1000 Technology Drive IN THE COURT OF COMMON PLEAS MS 730 O'Fallon, MO 63368-2240 OF Cumberland COUNTY vs. DONNA M. BENNETT Term Mortgagor(s) and Record Owner(s) No. 08-3207 3 Citadel Drive Camp Hill, PA 17011 CERTIFICATION OF SERVICE I hereby certify that a true and correct copies of Plaintiffs Praecipe to Satisfy Judgment was sent by first class mail,postage pre-paid, upon the following on the date listed below: DONNA M. BENNETT 6219 Stanford Ct. Mechanicsburg, PA 17050 By: `' 2317 KML LAW ! OUP,P.C. Angela M. Smith—Legal Assistant asmith @kmllawgroup.com 215-825-6325 (Direct Phone) 215-627-7734(Main Fax) Date: 10/1/2013 KML LAW GROUP P.C. ' Suite 5000—BNY Mellon Independence Center ;; }1 701 Market Street 5 }: S 3 Philadelphia, PA 19106-1532 ;t it OCT 215-627-1322 1 'LAND COU T t PENH CITIMORTGAGE, INC. 1000 Technology Drive IN THE COURT OF COMMON PLEAS MS 730 O'Fallon, MO 63368-2240 OF CUMBERLAND COUNTY Plaintiff vs. DONNA M. BENNETT No. 08-3207 (Mortgagor(s) and Record owner(s)) 3 Citadel Drive Camp Hill, PA 17011 Defendant(s) PRAECIPE TO DISCONTINUE AND END TO THE PROTHONOTARY: Kindly mark the above case Discontinued and Ended. KML LAW GROUP,P.C. F/K/A GOLDBECK McCAFFERTY&McKEEVER By: - Michae McKeever Pa.ID 56129 Jay E.Kivitz Pa.ID 26769 Lisa Lee Pa.ID 78020 T Puleo Pa. ID 27615 avid Fein Pa.ID 82628 Jill P.Jenkins Pa.ID 306588 Alyk L.Oflazian Pa.ID 312912 Salvatore Filippello,Attorney ID 313897 Attorneys for Plaintiff KML LAW GROUP, P.C. Suite 5000—BNY Mellon Independence Center 701 Market Street Philadelphia, PA 19106 (215) 627-1322 Attorney for Plaintiff CITIMORTGAGE, INC. Plaintiff IN THE COURT OF COMMON vs. PLEAS OF CUMBERLAND COUNTY DONNA M. BENNETT (Mortgagor(s) and Record Owner(s)) CIVIL ACTION - LAW Defendant(s) ACTION OF MORTGAGE FORECLOSURE No. 08-3207 CERTIFICATE OF SERVICE Angela M. Smith,hereby certifies that he/she did serve true and correct copies of Praecipe to Discontinue and End and all supporting papers attached hereto upon Defendant, by first class mail, postage pre-paid, on 19_91y DONNA M. BENNETT 6219 Stanford Ct Mechanicsburg, PA 17050 KML LAW GROUP,P.C. F/K/A GOLD:ECK McCAFFERTY : McKEEVER B : Y A fa M. Smith, Legal Assistant asmith @kmllawgroup.com 215-825-6325 (Direct Phone)