HomeMy WebLinkAbout08-6342l/
MILSTEAD & ASSOCIATES, LLC
BY: Mary L. Harbert-Bell, Esquire
ID No. 80763
220 Lake Drive East, Suite 301
Cherry Hill, NJ 08002
(856) 482-1400
Beneficial Consumer Discount Company
D/B/A Beneficial Mortgage Co of
Pennsylvania
636 Grand Regency Boulevard
Brandon, FL 33510,
Attorney for Plaintiff
File: 22.09412
COURT OF COMMON PLEAS
CUMBERLAND COUNTY
Plaintiff, No.. Q? - & 3q;,
Vs. CIVIL ACTION
MORTGAGE FORECLOSURE
Jeffrey Gaver
109 Locust Street
Shippensburg, PA 17257,
and
Shirley Gaver
109 Locust Street
Shippensburg, PA 17257,
Defendants.
NOTICE
You have been sued in court. If you wish to defend against the claims set forth in
the following pages, you must take action within twenty (20) days after this
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 claimed in the complaint or for any other
claim or relief requested by the plaintiff. You may lose money or property or other
rights important to you.
YOU SHOULD TAKE THIS 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 TO FIND OUT WHERE YOU CAN GET LEGAL HELP.
Cumberland County Bar Association
32 S. Bedford Street
Carlisle, PA 17013
717-249-3166
NOTICE PURSUANT TO FAIR DEBT COLLECTION PRACTICES ACT
1. This communication is from a debt collector. This is an attempt to collect a
debt and any information obtained will be used for that purpose.
2. Unless you dispute the validity of this debt, or any portion thereof, within
30 days after receipt of this notice, the debt will be assumed to be valid by our
offices.
3. If you notify our offices in writing within 30 days of receipt of this notice
that the debt, or any portion thereof, is disputed, our offices will provide you with
verification of the debt or copy of the Judgment against you, and a copy of such
verification or judgment will be mailed to you by our offices.
MILSTEAD & ASSOCIATES, LLC
BY: Mary L. Harbert-Bell, Esquire
ID No. 80763
220 Lake Drive East, Suite 301
Cherry Hill, NJ 08002
(856) 482-1400
Beneficial Consumer Discount Company
DB/A Beneficial Mortgage Co of
Pennsylvania
636 Grand Regency Boulevard
Brandon, FL 33510,
Vs.
Plaintiff,
Jeffrey Gaver
109 Locust Street
Shippensburg, PA 17257,
and
Shirley Gaver
109 Locust Street
Shippensburg, PA 17257,
Defendants.
Attorney for Plaintiff
COURT OF COMMON PLEAS
CUMBERLAND COUNTY
No.: m p - G 31-/•2 ? ??
CIVIL ACTION
MORTGAGE FORECLOSURE
COMPLAINT IN MORTGAGE FORECLOSURE
1. Plaintiff, Beneficial Consumer Discount Company DB/A Beneficial Mortgage Co of
Pennsylvania (the "Plaintiff'), is a corporation registered to conduct business in the
Commonwealth of Pennsylvania and having an office and place of business at 636 Grand
Regency Boulevard, Brandon, FL 33510.
2. Defendants, Jeffrey Gaver and Shirley Gaver, (collectively, the "Defendants"), are
adult individuals and are the real owners of the premises hereinafter described.
3. Jeffrey Gaver, Defendant, resides at 109 Locust Street, Shippensburg, PA 17257.
Shirley Gaver, Defendant, resides at 109 Locust Street, Shippensburg, PA 17257.
4. On May 6, 2004, in consideration of a loan in the principal amount of $72,341.04, the
Defendants executed and delivered to Beneficial Consumer Discount Company DB/A
Beneficial Mortgage Co of Pennsylvania an adjustable rate note (the "Note") with interest
thereon at 10.980 percent per annum, payable as to the principal and interest in equal monthly
installments of $707.98 commencing June 6, 2004. The current interest rate is 8.18 percent per
annum.
5. To secure the obligations under the Note, the Defendants executed and delivered to
Beneficial Consumer Discount Company DB/A Beneficial Mortgage Co of Pennsylvania a
mortgage (the "Mortgage") dated May 6, 2004, recorded on March 30, 2007 in the Department
of Records in and for the County of Cumberland under Mortgage Book 1986, Page 4771.
Pursuant to Pa.R.C.P. 1019 (g) the mortgage is incorporated herein by reference.
6. The Mortgage secures the following real property (the "Mortgaged Premises"): 109
Locust Street, Shippensburg, PA 17257. A legal description of the Mortgaged Premises is
attached hereto as Exhibit "A" and made a part hereof.
7. The Defendants are in default of their obligations pursuant to the Note and Mortgage
because payments of principal and interest due July 11, 2008, and monthly thereafter are due and
have not been paid, whereby the whole balance of principal and all interest due thereon have
become due and payable forthwith together with late charges, escrow deficit (if any) and costs of
collection including title search fees and reasonable attorney's fees.
8. The following amounts are due on the Mortgage and Note:
Balance of Principal ..................................$66,842.82
Accrued but Unpaid Interest from
6/11/08 to 10/24/08
@ 8.18% per annum
($14.98 per diem) ........................................$2,037.28
Accrued Late Charges ......................................$56.60
Corporate Advance .........................................$914.50
Additional Interest Due ..................................$764.30
Title Search Fees ............................................$350.00
Reasonable Attorney's Fees ........................$1,250.00
TOTAL as of 10/24/2008 ..........................$72,215.50
Plus, the following amounts accrued after October 24, 2008:
Interest at the Rate of 8.18 per cent per annum ($14.98 per diem);
Late Charges of $28.30 per month.
9. Plaintiff has complied fully with Act No. 91 (35 P.S.'1680.401(c) of the 1983 Session
of the General Assembly ("Act 91 ") of the Commonwealth of Pennsylvania, by mailing to the
Defendants at 109 Locust Street, Shippensburg, PA 17257 as well as to address of residences as
listed in paragraph 3 of this document on September 22, 2008, the notice pursuant to § 403-C of
Act 91, and the applicable time periods therein have expired.
WHEREFORE, Plaintiff demands an in rem judgment against the Defendants for
foreclosure and sale of the Mortgaged Premises in the amount due as set forth in paragraph 8,
namely, $72,215.50, plus the following amounts accruing after October 24, 2008, to the date of
judgment: (a) interest of $14.98 per day, (b) late charges of $28.30 per month, (c) plus interest at
the legal rate allowed on judgments after the date of judgment, (d) additional attorney's fees (if
any) hereafter incurred, (e) and costs of suit.
MILSTEAD & ASSOCIATES, LLC
Mary L. Harbert-Bell, Esquire
Attorney for Plaintiff
VERIFICATION
I, Mary L. Harbert-Bell, hereby certify that I am an Attorney for Plaintiff and am authorized to
make this verification on Plaintiff s behalf. I verify that the facts and statements set forth in the
forgoing Complaint in Mortgage Foreclosure are true and correct to the best of my knowledge,
information and belief. This verification is made subject to the penalties of 18 Pa. C.S. ' 4904,
relating to unworn falsification to authorities.
Name: Mary L. Harbert-Bell, Esquire
Title: Attorney
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SHERIFF'S RETURN - NOT SERVED
CASE NO: 2008-06342 P
COMMONWEALTH OF PENNSYLVANIA
COUNTY OF CUMBERLAND
BENEFICIAL CONSUMER DISCOUNT
VS
GAVER JEFFREY ET AL
R. Thomas Kline , Deputy Sheriff, who being duly sworn
according to law, says, that he made a diligent search and inquiry for
the within named DEFENDANT , to wit:
GAVER JEFFREY but was
unable to locate Him in his bailiwick. He therefore returns the
COMPLAINT - MORT FORE
the within named DEFENDANT GAVER JEFFREY
216 WEST KING STREET
SHIPPENSBURG, PA 17257
PER DEFENDANT, THEY NEVER LIVED AT THIS ADDRESS.
NOT SERVED , as to
--'? - _ 3
Sheriff's Costs: So answers*
Docketing 6.00
Service .00
Affidavit .00 R. Thomas Kl' e
Surcharge 10.00 Sheriff of Cu erland County
.00
T-16.00 MILSTEAD & ASSOCIATES
11/12/2008
Sworn and Subscribed to before me
this
day of
A. D.
SHERIFF'S RETURN - NOT SERVED
CASE NO: 2008-06342 P
COMMONWEALTH OF PENNSYLVANIA
COUNTY OF CUMBERLAND
BENEFICIAL CONSUMER DISCOUNT
VS
LAVER JEFFREY ET AL
R. Thomas Kline , Deputy Sheriff, who being duly sworn
according to law, says, that he made a diligent search and inquiry for
the within named DEFENDANT to wit:
GAVER SHIRLEY
but was
unable to locate Her in his bailiwick. He therefore returns the
COMPLAINT - MORT FORE
the within named DEFENDANT , GAYER SHIRLEY
216 WEST KING STREET
NOT SERVED , as to
SHIPPENSBURG, PA 17257
PER JEFF, THEY NEVER LIVED AT THIS ADDRESS.
Sheriff's Costs: So answers-
Docketing 6.00
Service .00
Affidavit .00 R. Thomas Kli e
Surcharge 10.00 Sheriff of Cumberland County
-no
???1p?oP
16.00 0 MILSTEAD & ASSOCIATES
11/12/2008
Sworn and Subscribed to before me
this day of
A. D.
SHERIFF'S RETURN - REGULAR
CASE NO: 2008-06342 P
COMMONWEALTH OF PENNSYLVANIA:
COUNTY OF CUMBERLAND
BENEFICIAL CONSUMER DISCOUNT
VS
GAVER JEFFREY ET AL
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
GAVER JEFFREY
the
DEFENDANT , at 1010:00 HOURS, on the 7th day of November-, 2008
at 109 LOCUST STREET
SHIPPENSBURG, PA 17257
JEFFREY GAYER
by handing to
a true and attested copy of COMPLAINT - MORT FORE
together with
and at the same time directing His attention to the contents thereof.
Sheriff's Costs: So Answers:
Docketing 18.00
Service 20.00 oe .Q?
Affidavit .00
Surcharge 10.00 R. Thomas Kline
n .00
48.00 11/12/2008
MILSTEAD & ASSOCIATES
Sworn and Subscibed to By:
before me this day /Deputy Sheriff
of A. D.
SHERIFF'S RETURN - REGULAR
CASE NO: 2008-06342 P
COMMONWEALTH OF PENNSYLVANIA:
COUNTY OF CUMBERLAND
BENEFICIAL CONSUMER DISCOUNT
VS
LAVER JEFFREY ET AL
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
GAVER SHIRLEY
the
DEFENDANT , at 1010:00 HOURS, on the 7th day of November-, 2008
at 109 LOCUST STREET
SHIPPENSBURG, PA 17257
JEFFREY GAYER, HUSBAND
by handing to
a true and attested copy of COMPLAINT - MORT FORE
together with
and at the same time directing His attention to the contents thereof.
Sheriff's Costs:
Docketing
Service
Affidavit
Surcharge
))) I QIDY 9+^?
Sworn and Subscibed to
before me this
So Answers:
6.00
.00
.00 10.00 R. Thomas Klin
.00
16.00 11/12/2008
MILSTEAD & ASSOCIATES
By.
day Deputy ffheriff
of A. D.
w.
MILSTEAD & ASSOCIATES, LLC
BY: Mary L. Harbert-Bell, Esquire
ID No. 80763
220 Lake Drive East, Suite 301
Cherry Hill, NJ 08002
(856) 482-1400 Attorney for Plaintiff
Beneficial Consumer Discount Company COURT OF COMMON PLEAS
DB/A Beneficial Mortgage Co of CUMBERLAND COUNTY
Pennsylvania
636 Grand Regency Boulevard
Brandon, FL 33510,
Plaintiff,
Vs.
Jeffrey Gaver
109 Locust Street
Shippensburg, PA 17257,
and
Shirley Gaver-
109 Locust Street
Shippensburg, PA 17257,
Defendants.
No.: 08-6342- Civil Term
PRAECIPE FOR JUDGMENT, INREM, FOR FAILURE TO
ANSWER AND ASSESSMENT OF DAMAGES
TO THE PROTHONOTARY:
Kindly enter Judgment, in rem, in favor of Plaintiff and against Jeffrey Gaver and Shirley Gaver,
Defendants, for failure to file an Answer on Plaintiff's Complaint within 20 days from service
thereof and for Foreclosure and sale of the mortgaged premises, and assess Plaintiff s damages
as follows:
As set forth in Complaint $72,215.50
Interest 10/25/08 through 12/22/08 883.82
Late Charges 56.60
Additional Corporate Advance 657.50
TOTAL $73,813.42
I hereby certify that (1) the addresses of the Plaintiff and Defendants are as shown above
and (2) that notice has been given in accordance with Rule 2 opy attached.
Mary L. Harbert-Bell, Esquire
Attorney for Plaintiff
DAMAGES ARE HEREBY ASSESSED AS INDICATED
DATE:
?? J6 3 Q atz I ?? P PR,0THON0TkkY___t_ /
MILSTEAD & ASSOCIATES, LLC
BY: Mary L. Harbert-Bell, Esquire
ID No. 80763
220 Lake Drive East, Suite 301
Cherry Hill, NJ 08002
(856) 482-1400
Attorney for Plaintiff
Beneficial Consumer Discount Company
DB/A Beneficial Mortgage Co of
Pennsylvania,
Plaintiff,
Vs.
Jeffrey Gaver
and
Shirley Gaver,
Defendants.
Our file number: 22.09412
COURT OF COMMON PLEAS
CUMBERLAND COUNTY
No.: 08-6342- Civil Term
TO: Jeffrey Gaver Shirley Gaver
109 Locust Street, 109 Locust Street,
Shippensburg, PA 17257 Shippensburg, PA 17257
DATE OF NOTICE: December 12, 2008
THIS FIRM IS A DEBT COLLECTOR ATTEMPTING TO COLLECT A DEBT. THIS
NOTICE IS SENT TO YOU IN AN ATTEMPT TO COLLECT THE INDEBTEDNESS
REFERRED TO HEREIN, AND ANY INFORMATION OBTAINED FROM YOU WILL
BE USED FOR THAT PURPOSE. IF YOU HAVE PREVIOUSLY RECEIVED A
DISCHARGE IN BANKRUPTCY, THIS CORRESPONDENCE IS NOT AND SHOULD
NOT BE CONSTRUED TO BE AN ATTEMPT TO COLLECT A DEBT, BUT ONLY AS
ENFORCEMENT OF LIEN AGAINST PROPERTY.
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
claims set forth against you. Unless you act within ten (10) days from the date of this
notice, a judgment may be entered against you without a hearing and you may lose your
property or other important rights. You should take this paper to your lawyer at once. If
you do not have a lawyer, go to or telephone the office set forth below. This office can
provide you with information about hiring a lawyer. If you cannot afford to hire a
{00020971)
Page I of 2
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lawyer, this office may be able to provide you with information about agencies that may
offer legal services to eligible persons at a reduced fee or no fee.
CUMBERLAND COUNTY BAR ASSOCIATION
32 S. BEDFORD STREET
CARLISLE, PA 17013
717-249-3166
MILSTEAD & ASSOCIATES, LLC
z??g
By: Mary L. Harbert-Bell, Esquire
ID No. 80763
Attorney for Plaintiff
(00020971)
Page 2 of 2
71
MILSTEAD & ASSOCIATES, LLC
BY: Mary L. Harbert-Bell, Esquire
ID No. 80763
220 Lake Drive East, Suite 301
Cherry Hill, NJ 08002
(856) 482-1400
Attorney for Plaintiff
Beneficial Consumer Discount Company
DB/A Beneficial Mortgage Co of
Pennsylvania,
Plaintiff,
Vs.
Jeffrey Gaver,
and
Shirley Gaver,
Defendants.
COURT OF COMMON PLEAS
CUMBERLAND COUNTY
No.: 08-6342- Civil Term
VERIFICATION OF NON-MILITARY SERVICE
Mary L. Harbert-Bell, Esquire, hereby verifies that she is attorney for the Plaintiff in the
above-captioned matter, and that on information and belief, she has knowledge of the following
facts, to wit:
1. that the defendants are not in the Military or Naval Service of the United States or its
Allies, or otherwise within the provisions of the Soldier' and Sailors' Civil Relief Act of
Congress of 1940, as amended,
2. defendant, Jeffrey Gaver, is over 18 years of age and resides at 109 Locust Street,
Shippensburg, PA 17257,
3. defendant, Shirley Gaver, is over 18 years of age and resides at 109 Locust Street,
Shippensburg, PA 17257.
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Ma
ry L. Harbe -Bell, Esquire
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IN THE COURT OF COMMON PLEAS OF CUMBERLAND COUNTY,
PENNSYLVANIA
Beneficial Consumer Discount Company CIVIL ACTION
DB/A Beneficial Mortgage Co of
Pennsylvania,
Plaintiff, ; NO.: 08-6342- Civil Term
Vs.
Jeffrey Gaver
and
PRAECIPE FOR WRIT OF EXECUTION
(Mortgage Foreclosure)
Shirley Gaver,
Defendants.
TO THE PROTHONOTARY OF CUMBERLAND COUNTY:
1. Directed to the Sheriff of CUMBERLAND County;
2. Against the Defendant(s) in the above-captioned matter;
3. and index this writ against the Defendant(s) as follows:
Jeffrey Gaver
Shirley Gaver
Real Property involved: 109 Locust Street
Shippensburg, PA 17257
Amount Due
Interest from 12/23/08 to 6/10/09
at $12.13 per diem (6%)
$73,813.42
TOTAL
(Costs to be added)
DATE: February 24, 2009
Respectively submitted,
Milstead & Associates, LLC
Mary L. Harbert-Bell, Esquire
Attorney for Plaintiff
220 Lake Drive East, Suite 301
Cherry Hill, NJ 08002
{00326370}
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ALL THAT CERTAIN lot of ground with the two and one half story frame
dwelling house and other necessary outbuildings thereon erected, known
as 109 Locust Street, situate in the Borough of Shippensburg, County of
Cumberland and Commonwealth of Pennsylvania, bounded and
described as follows:
BEGINNING at a point on the East side of Locust Street at corner of lot now
or formerly of Frank Robinson; thence Northwardly along Locust Street
twenty nine (29) feet to a point; thence Eastwardly along land now or
formerly of Wolf Grove and Mary E. Wolf, ninety two (92) feet ten (10)
inches to a point; thence along lot now or formerly of Rex E. Gilbert, now
or formerly marked by a fence line, Southwardly twenty nine (29) feet;
thence along said lot now or formerly of Frank Robinson, Westwardly
ninety two (92) feet ten (10) inches to the place of BEGINNING.
Being known as 109 Locust Street, Shippensburg, PA 17257
Tax Parcel Number: 34-34-2415-003
{00326370)
L
•. •
MILSTEAD & ASSOCIATES, LLC
BY: Mary L. Harbert-Bell, Esquire
ID No. 80763
220 Lake Drive East, Suite 301
Cherry Hill, NJ 08002
(856) 482-1400
Attorney for Plaintiff
Beneficial Consumer Discount Company COURT OF COMMON PLEAS
D/B/A Beneficial Mortgage Co of CUMBERLAND COUNTY
Pennsylvania,
No.: 08-6342- Civil Term
Plaintiff,
Vs. AFFIDAVIT OF SERVICE
PURSUANT TO RULE 3129.1
Jeffrey Gaver
and
Shirley Gaver,
Defendants.
STATE OF PENNSYLVANIA
COUNTY OF CUMBERLAND
Beneficial Consumer Discount Company D/B/A Beneficial Mortgage Co of
Pennsylvania, Plaintiff in the above entitled cause of action, sets forth as of the date the praecipe
for writ of execution was filed the following information concerning the real property located at
109 Locust Street, Shippensburg, PA 17257:
1. Name and address of Owners(s) or Reputed Owner(s):
Jeffrey Gaver
109 Locust Street
Shippensburg, PA 17257
Shirley Gaver
109 Locust Street
Shippensburg, PA 17257
2. Name and address of Defendant(s) in the Judgment:
Same as above
3. Name and address of every judgment creditor whose judgment is a record lien on the real
property to be sold:
None Known
{00326370}
4. Name and Address of the last recorded holder of every mortgage of record:
Beneficial Consumer Discount Company
DB/A Beneficial Mortgage Co of
Pennsylvania
(Plaintiff herein)
636 Grand Regency Boulevard
Brandon, FL 33510
MERS, Inc. acting solely as nominee for Delta
Funding Corporation
1000 Woodbury Road, P.O. Box 9009
Woodbury, NY 11797
MERS, Inc. acting solely as nominee for Delta
Funding Corporation
3300 SW 34 Avenue, Ste. 101
Ocala, FL 34474
5. Name and address of every other person who has any record lien on the property:
None Known
6. Name and address of every other person who has any record interest in the property and
whose interest may be affected by the sale:
None Known
7. Name and address of every person of whom the plaintiff has knowledge who has any
interest in the property which may be affected by the sale:
Tenant/Occupant
109 Locust Street
Shippensburg, PA 17257
Commonwealth of Pennsylvania
Department of Welfare
P.O. Box 2675
Harrisburg, PA 17105
Department of Domestic Relations
Cumberland County Courthouse
13 N. Hanover Street
Carlisle, PA 17013
I verify that the statements made in the Affidavit are true and correct to the best of my
personal knowledge or information and belief. I understand that false statements herein are
made subject to the penalties of 18 Pa. C.S. Section 4904 relating to unsworn falsification to
authorities.
Mary L. Harbert-Bell, Esquire
Attorney for Plaintiff
Date: February 24, 2009
{00326370}
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146
MILSTEAD & ASSOCIATES, LLC
BY: Mary L. Harbert-Bell, Esquire
ID No. 80763
220 Lake Drive East, Suite 301
Cherry Hill, NJ 08002
(856) 482-1400
Beneficial Consumer Discount Company
D/B/A Beneficial Mortgage Co of
Pennsylvania,
Plaintiff,
Vs.
Jeffrey Gaver,
and
Shirley Gaver,
Defendants.
TAKE NOTICE:
Attorney for Plaintiff
COURT OF COMMON PLEAS
CUMBERLAND COUNTY
No.: 08-6342- Civil Term
NOTICE OF SHERRFF'S SALE OF
REAL PROPERTY PURSUANT
TO PA.R.C.P.3129
Your house (real estate) at 109 Locust Street, Shippensburg, PA 17257, is scheduled to
be sold at sheriff's sale on June 10, 2009 at 10:00 am in the Commissioner's Hearing Room,
Cumberland County Courthouse, Carlisle, PA 17013 to enforce the Court Judgment of
$73,813.42 obtained by Beneficial Consumer Discount Company D/B/A Beneficial Mortgage Co
of Pennsylvania.
NOTICE OF OWNER'S RIGHTS
YOU MAY BE ABLE TO PREVENT THIS SHERIFF'S SALE
To Prevent this Sheriff's Sale you must take immediate action:
1. The Sale will be cancelled if you pay to Milstead & Associates LLC, Attorney for
Plaintiff, back payments, late charges, costs and reasonable attorney's fees due. To find out how
much you must pay, you may call 856-482-1400.
2. You may be able to stop the Sale by filing a petition asking the court to strike or open
the Judgment, if the Judgment was improperly entered. You may also ask the Court to postpone
the Sale for good cause.
3. You may also be able to stop the Sale through other legal proceedings. You may need
an attorney to assert your rights. The sooner you contact one, the more chance you will have of
stopping the Sale. (See notice on following page on how to obtain an attorney).
{00326370)
4
YOU MAY STILL BE ABLE TO SAVE YOUR PROPERTY AND YOU HAVE OTHER
RIGHTS EVEN IF THE SHERIFF'S SALE DOES TAKE PLACE.
1. If the Sheriff's Sale is not stopped, your property will be sold to the highest bidder.
You may find out the bid price by calling Milstead & Associates at 856-482-1400.
2. You may be able to petition the Court to set aside the Sale if the bid price was grossly
inadequate compared to the market value of your property.
3. The Sale will go through only if the Buyer pays the Sheriff the full amount due on the
Sale. To find out if this has happened you may call Milstead and Associates at 856-482-1400.
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 on a date
specified by the Sheriff not later than thirty days after the 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.
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 YOU LAWYER AT ONCE. IF YOU DO NOT
HAVE A LAWYER OR CANNOT AFFORD ONE, GO TO OR TELEPHONE THE OFFICE
LISTED BELOW TO FIND OUT WHERE YOU CAN GET LEGAL HELP.
Cumberland County Bar Association
32 S. Bedford Street
Carlisle, PA 17013
717-249-3166
22.09412
{00326370}
..
ALL THAT CERTAIN lot of ground with the two and one half story frame
dwelling house and other necessary outbuildings thereon erected, known
as 109 Locust Street, situate in the Borough of Shippensburg, County of
Cumberland and Commonwealth of Pennsylvania, bounded and
described as follows:
BEGINNING at a point on the East side of Locust Street at corner of lot now
or formerly of Frank Robinson; thence Northwardly along Locust Street
twenty nine (29) feet to a point; thence Eastwardly along land now or
formerly of Wolf Grove and Mary E. Wolf, ninety two (92) feet ten (10)
inches to a point; thence along lot now or formerly of Rex E. Gilbert, now
or formerly marked by a fence line, Southwardly twenty nine (29) feet;
thence along said lot now or formerly of Frank Robinson, Westwardly
ninety two (92) feet ten (10) inches to the place of BEGINNING.
Being known as 109 Locust Street, Shippensburg, PA 17257
Tax Parcel Number: 34-34-2415-003
{00326370}
WRIT OF EXECUTION and/or ATTACHMENT
COMMONWEALTH OF PENNSYLVANIA)
COUNTY OF CUMBERLAND)
N008-6342 Civil
CIVIL ACTION - LAW
TO THE SHERIFF OF CUMBERLAND COUNTY:
To satisfy the debt, interest and costs due BENEFICIAL CONSUMER DISCOUNT COMPANY
DB/A BENEFICIAL MORTGAGE CO OF PENNSYLVANIA Plaintiff (s)
From JEFFREY GAVER AND SHIRLEY GAVER
(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$73,813.42
L.L.$.50
Interest FROM 12/23/08 TO 6/10/09 AT $12.13 PER DIEM (6%)
Atty's Comm % Due Prothy $2.00
Atty Paid $215.00
Plaintiff Paid
Date: FEBRUARY 25, 2009
(Seal)
REQUESTING PARTY:
Other Costs
14
tA I'.
iC'Gtis R. L r ono
By:
Deputy
Name MARY L. HARBERT-BELL, ESQUIRE
Address: 220 LAKE DRIVE EAST, SUITE 301, CHERRY HILL, NJ 08002
Attorney for: PLAINTIFF
Telephone: 856482-1400
Supreme Court ID No. 80763
MILSTEAD & ASSOCIATES, LLC
BY: Mary L. Harbert-Bell, Esquire
ID No. 80763
220 Lake Drive East, Suite 301
Cherry Hill, NJ 08002
(856) 482-1400
Attorney for Plaintiff
neneuciai %-onsumer Ulscouni t-ompany ju/ s/A uuuKl Vr uummuIV
Beneficial Mortgage Co of Pennsylvania, CUMBERLAND COUN
Plaintiff,
Vs.
Jeffrey Gaver
and
Shirley Gaver
, Defendants.
NO.: 08-6342- Civil Term
AFFIDAVIT PURSUANT )[0
Pa.R.C.P. 3129.2
COMMONWEALTH OF PENNSYLVANIA
COUNTY OF CUMBERLAND
SS:
I, Mary L. Harbert-Bell, Esquire, being duly sworn according to law upon my oath,
depose and say,
1. On April 2, 2009, a copy of the Notice of Sheriff s Sale of Real Propertwas served
on the defendant by certified mail, returned receipt requested. Copies of the sign certified
cards are attached hereto and made a part hereof as Exhibit "A".
2. On April 1, 2009 & May 8, 2009, a notice of Sheriff's Sale was served upon lien
holders of record and interested parties by ordinary mail. A copy of the certificate Of mailing is
attached hereto and made a part hereof as Exhibit "B".
Dated: June 9, 2009
Mary L. Harbert-Bell, Esquire
Attorney ID No. 80763
Milstead and Associates, LLC
{00352821}
Art -Number-`- ---------
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i• A+tide Add ?Yes C
ressed to:
JefrreY Gaver
109 Locust Street
e r
ShPPensbur
g, PA 17257
22.0 412
PAW
pS Forth 38i 1, Januar
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aon?estic Retum Receipt
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i Article Addressed to: ' OYes
Shirley Gaver
109 Locust Street
Shippensbwg, PA 17257
22.09412
9,412
PAW
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FILE D-- Oi-R!C'E
OF THE R' OAPY
2609 JUN 1 1 FM Z: 4 4
..-.
PC?J'';;Yo1,rkP'-I;iA,
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 BENEFICIAL C D C DBA BENEFICIAL MTG CO OF PA is the grantee
the same having been sold to said grantee on the I OTH day of JUNE A.D., 2009, under and by virtue of
a writ Execution issued on the 25TH day of FEB, A.D., 2009, out of the Court of Common Pleas of said
County as of Civil Term, 2008 Number 6342, at the suit of BENEFICIAL C D C DBA BENEFICIAL
MTG CO OF PA against JEFFREY GAVER & SHIRLEY is duly recorded as Instrument Number
200923824.
IN TESTIMONY WHEREOF, I have hereunto set my hand
and seal of said office this 9 day of
A.D. OZO6 9
Recorder of Deeds
TW&AU C1 W43. Cumba(and County, C&,WW, PA
* L'a mWm E*bu to Fht Monday of Jan. 2010
In the Court of Common Pleas of
Cumberland County, Pennsylvania
Writ No. 2008-6342 Civil Term
Beneficial Consumer Discount Company, d/b/a Beneficial Mortgage Company of
Pennsylvania
VS
Jeffrey Gaver and Shirley Gaver
William Cline, Deputy Sheriff, who being duly sworn according to law, states that
on March 13, 2009 at 1830 hours, he served a true copy of the within Real Estate Writ,
Notice and Description, in the above entitled action, upon the within named defendants,
to wit: Jeffrey Gaver and Shirley Gaver, by handing both to Jeffrey Gaver, personally, at,
214 East Orange Street, Apartment A, Shippensburg, Cumberland County, Pennsylvania
its contents and at the same time handing to him personally the said true and correct copy
of the same.
Dennis Fry, Deputy Sheriff, who being duly sworn according to law, states that on
April 9, 2009 at 1630 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 Jeffrey Gaver
and Shirley Gaver, located at, 109 Locust Street, Shippensburg, Cumberland County
Pennsylvania, according to law.
Thomas Kline, Sheriff, who being duly sworn according to law, states he served
the above Real Estate Writ, Notice, Poster and Description in the following manner: The
Sheriff mailed a notice of the pendency of the action to the within named defendants, to
wit: Jeffrey Gaver and Shirley Gaver, by regular mail to their last known address 214
East Orange Street, Apartment A, Shippensburg, PA 17257. This letter was mailed under
the date of April 2, 2009 and never returned to the Sheriffs Office
R. Thomas Kline, Sheriff, who being duly sworn according to law, states that
after due and legal notice had been given according to law, he exposed the within
described premises at public venue or outcry at the Courthouse, Carlisle, Cumberland
County, Pennsylvania on June 10, 2009 at 10:00 o'clock A.M. He sold the same for the
sum of $1.00 to Attorney Mary Harbert-Bell, on behalf of Beneficial Consumer Discount
Company, D/B/A Beneficial Mortgage Co of Pennsylvania of 636 Grand Regency Blvd,
Brandon, FL 33510 being the buyer in this execution, paid to Sheriff R. Thomas Kline
the sum of $ 902.48
Sheriff's Costs:
Docketing
Poundage 30.00
Posting Bills 17.70
Advertising 15.00
Acknowledging Deed 15.00
Auctioneer 48.00
Law Library 10.00
Prothonotary .50
Milage 2.00
36.00
Levy
Surcharge
Law Journal
Patriot News
Share of Bills
Distribution of Proceeds
Sheriff's Deed
15.00
30.00
355.00
238.35
15.43
25.00
49.50
902.48 ? V/46 9
So Answers,
R. Thomas Kline, eriff
By ?.
Real t
o Coordinator
L
(3 N
.2. " a .
s-D /- J-.
yP= [rv a.,-k-, dae-
C12. *770G87
,,-2j
MILSTEAD & ASSOCIATES, LLC
BY: Mary L. Harbert-Bell, Esquire
ID No. 80763
220 Lake Drive East, Suite 301
Cherry Hill, NJ 08002
(856) 482-1400
Attorney for Plaintiff
Beneficial Consumer Discount Company
DB/A Beneficial Mortgage Co of
Pennsylvania,
Plaintiff,
Vs.
Jeffrey Gaver
and
Shirley Gaver,
Defendants.
STATE OF PENNSYLVANIA
COUNTY OF CUMBERLAND
COURT OF COMMON PLEAS
CUMBERLAND COUNTY
No.: 08-6342- Civil Term
AFFIDAVIT OF SERVICE
PURSUANT TO RULE 3129.1
Beneficial Consumer Discount Company DB/A Beneficial Mortgage Co of
Pennsylvania, Plaintiff in the above entitled cause of action, sets forth as of the date the praecipe
for writ of execution was filed the following information concerning the real property located at
109 Locust Street, Shippensburg, PA 17257:
1. Name and address of Owners(s) or Reputed Owner(s):
Jeffrey Gaver
109 Locust Street
Shippensburg, PA 17257
Shirley Gaver
109 Locust Street
Shippensburg, PA 17257
2. Name and address of Defendant(s) in the Judgment:
Same as above
3. Name and address of every judgment creditor whose judgment is a record lien on the real
property to be sold:
None Known
X6370}
4. Name and Address of the last recorded holder of every mortgage of record:
Beneficial Consumer Discount Company
D/B/A Beneficial Mortgage Co of
Pennsylvania
(Plaintiff herein)
636 Grand Regency Boulevard
Brandon, FL 33510
MERS, Inc. acting solely as nominee for Delta
Funding Corporation
1000 Woodbury Road, P.O. Box 9009
Woodbury, NY 11797
MERS, Inc. acting solely as nominee for Delta
Funding Corporation
3300 SW 34 Avenue, Ste. 101
Ocala, FL 34474
5. Name and address of every other person who has any record lien on the property:
None Known
6. Name and address of every other person who has any record interest in the property and
whose interest may be affected by the sale:
None Known
7. Name and address of every person of whom the plaintiff has knowledge who has any
interest in the property which may be affected by the sale:
Tenant/Occupant
109 Locust Street
Shippensburg, PA 17257
Commonwealth of Pennsylvania
Department of Domestic Relations
Cumberland County Courthouse
13 N. Hanover Street
Carlisle, PA 17013
Department of Welfare
P.O. Box 2675
Harrisburg, PA 17105
I verify that the statements made in the Affidavit are true and correct to the best of my
personal knowledge or information and belief. I understand that false statements herein are
made subject to the penalties of 18 Pa. C.S. Section 4904 relating to unsworn falsification to
authorities.
Mary L. Harbert-Bell, Esquire
Attorney for Plaintiff
Date: February 24, 2009
16370}
MILSTEAD & ASSOCIATES, LLC
BY: Mary L. Harbert-Bell, Esquire
ID No. 80763
220 Lake Drive East, Suite 301
Cherry Hill, NJ 08002
(856) 482-1400
Beneficial Consumer Discount Company
D/B/A Beneficial Mortgage Co of
Pennsylvania,
Plaintiff,
Vs.
Jeffrey Gaver,
and
Shirley Gaver,
Defendants.
TAKE NOTICE:
Attorney for Plaintiff
COURT OF COMMON PLEAS
CUMBERLAND COUNTY
No.: 08-6342- Civil Term
NOTICE OF SHERRIF'S SALE OF
REAL PROPERTY PURSUANT
TO PA.R.C.P.3129
Your house (real estate) at 109 Locust Street, Shippensburg, PA 17257, is scheduled to
be sold at sheriff's sale on June 10, 2009 at 10:00 am in the Commissioner's Hearing Room,
Cumberland County Courthouse, Carlisle, PA 17013 to enforce the Court Judgment of
$73,813.42 obtained by Beneficial Consumer Discount Company D/B/A Beneficial Mortgage Co
of Pennsylvania.
NOTICE OF OWNER'S RIGHTS
YOU MAY BE ABLE TO PREVENT THIS SHERIFF'S SALE
To Prevent this Sheriff's Sale you must take immediate action:
1. The Sale will be cancelled if you pay to Milstead & Associates LLC, Attorney for
Plaintiff, back payments, late charges, costs and reasonable attorney's fees due. To find out how
much you must pay, you may call 856-482-1400.
2. You may be able to stop the Sale by filing a petition asking the court to strike or open
the Judgment, if the Judgment was improperly entered. You may also ask the Court to postpone
the Sale for good cause.
3. You may also be able to stop the Sale through other legal proceedings. You may need
an attorney to assert your rights. The sooner you contact one, the more chance you will have of
stopping the Sale. (See notice on following page on how to obtain an attorney).
{00326370)
YOU MAY STILL BE ABLE TO SAVE YOUR PROPERTY AND YOU HAVE OTHER
RIGHTS EVEN IF THE SHERIFF'S SALE DOES TAKE PLACE.
1. If the Sheriff's Sale is not stopped, your property will be sold to the highest bidder.
You may find out the bid price by calling Milstead & Associates at 856-482-1400.
2. You may be able to petition the Court to set aside the Sale if the bid price was grossly
inadequate compared to the market value of your property.
3. The Sale will go through only if the Buyer pays the Sheriff the full amount due on the
Sale. To find out if this has happened you may call Milstead and Associates at 856-482-1400.
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 on a date
specified by the Sheriff not later than thirty days after the 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.
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 YOU LAWYER AT ONCE. IF YOU DO NOT
HAVE A LAWYER OR CANNOT AFFORD ONE, GO TO OR TELEPHONE THE OFFICE
LISTED BELOW TO FIND OUT WHERE YOU CAN GET LEGAL HELP.
Cumberland County Bar Association
32 S. Bedford Street
Carlisle, PA 17013
717-249-3166
22.09412
{00326370}
ALL THAT CERTAIN lot of ground with the two and one half story frame
dwelling house and other necessary outbuildings thereon erected, known
as 109 Locust Street, situate in the Borough of Shippensburg, County of
Cumberland and Commonwealth of Pennsylvania, bounded and
described as follows:
BEGINNING at a point on the East side of Locust Street at corner of lot now
or formerly of Frank Robinson; thence Northwardly along Locust Street
twenty nine (29) feet to a point; thence Eeswardly along land now or
formerly of Wolf Grove and Mary E. Wolf, ninety two (92) feet ten (10)
inches to a point; thence along lot now or formerly of Rex E. Gilbert, now
or formerly marked by a fence line, Southwardly twenty nine (29) feet;
thence along said lot now or formerly of Frank Robinson, Westwardly
ninety two (92) feet ten (10) inches to the place of BEGINNING.
Being known as 109 Locust Street, Shippensburg, PA 17257
Tax Parcel Number: 34-34-2415-003
{00326370)
Real Estate Sale # 84
On February 27, 2009 the Sheriff levied upon the
defendant's interest in the real property situated in
Borough of Shippensburg, Cumberland County, PA
Known and numbered as 109 Locust Street, Shippensburg,
More fully described on Exhibit "A" filed
with this writ and by this reference incorporated herein.
Date: February 27, 2009
By:
C'C-?-LP Y
L
r
ty
G
G
G
r?
s'j ??
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
This ad ran on the date(s) shown below:
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
Real Estate Oda No. 84
!'rrlt No. 3000.0942 Civil Term
BaneffoW Consumer Discount
o3ompany, dAWa Beneficial
Mortgage Cc of Pennsylvania
. VS
Jeffrey Gaver and
Shirley Gaver
Attorney Mary. Harbert-Bell
LEGAL DESCRIPTION
ALL THAT CERTAIN lot of ground with the
two and one half story frame dwelling house and
other necessary outbuildings thereon erected,
known as 10914Dcust Street, situate in the
Borough of Sbippensburg, County of
Cumberland and Commonwealth of
Pennsylvania, bounded and described as
follows:
BEG]NNING at a point on the Fast side of
Locust Street at corner of lot now or frrmerly of
Frank Robinson; than Northwardly Long
Locust Street twenty nine (29) feet to a point;
thence Fastwatdly along land now or formerly
of Wolf Grove and Mary E. Wolf, ninety two
92) feet ten (10) inches to a.point; thence along
lot now or formerly, of Rex 13. Gilbert, norr or
fmaaiy,merkod by a fence I?o, Southwady
twenty nine (29) feet; thence along said lof now
or formerly of Frank Robinson, Westwardly
ninety two (92) feet ten (10) inches to the place
04/24/09
14e Patriot News
Now you know
05/01/09
05/08/09
Sworn
before
f May, 2009 A.D.
Notary Public
C DNWEALTH OF PENNSYLVANIA
Notarial Seal
Sherrie L Kisrw, NoWy pLft
Re* bosvo a l09 Locust Street, CorOrvnb&4 E ft Nov. 1
city
Vii, !9117237
Tax parcel Number: 34-34.2413003 Member. Pennaylvanla Aasoolation or Noterw
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:
May 1, May 8, and May 15, 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.
REAL ESTATE SALE NO. 84
Writ No. 2008-6342 Civil
Beneficial Consumer Discount
Company, d/b/a Beneficial
Mortgage Co. of Pennsylvania
VS.
Jeffrey Gaver and
Shirley Gaver
Atty.: Mary Harbert-Bell
ALL THAT CERTAIN lot of ground
with the two and one half story frame
dwelling house and other necessary
outbuildings thereon erected, known
as 109 Locust Street, situate in the
Borough of Shippensburg, County
of Cumberland and Commonwealth
of Pennsylvania, bounded and de-
scribed as follows:
BEGINNING at a point on the East
side of Locust Street at corner of lot
now or formerly of Frank Robinson;
thence Northwardly along Locust
Street twenty nine (29) feet to a point;
thence Eastwardly along land now
or formerly of Wolf Grove and Mary
E. Wolf, ninety two (92) feet ten (10)
inches to a point; thence along lot
a Marie Coyne, Editor
SWO TO AND SUBSCRIBED before me this
15 day of May 2009
??LIAA440(2
Notary
now or formerly of Rex E. Gilbert,
now or formerly marked by a fence
line, Southwardly twenty nine (29)
feet; thence along said lot now or for-
merly of Frank Robinson, Westwardly
ninety two (92) feet ten (10) inches to
the place of BEGINNING.
Being known as 109 Locust
Street, Shippensburg, PA 17257.
Tax Parcel Number: 34-34-2415-
003.
NOTARIAL SEAL
DEBORAH A COLLINS
Notary Public
CARLISLE BORO, CUMBERLAND COUNTY
My Commission Expires Apr 28, 2010