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Home My WebLink About04-1706 GOLDBECK McCAFFERTY & McKEEVER By: JOSEPH A. GOLDBECK, JR. ATTORNEY I.D. #16132 SUITE 5000 - MELLON INDEPENDENCE CENTER. 701 MARKET STREET PHILADELPHIA, P A i9106 (215) 627-1322 ATTORNEY FOR PLAINTIFF IN THE COURT OF COMMON PLEAS M&T MORTGAGE CORPORATION PO Box 840 BuffalD, NY 14240-0840 OF Cumberland COUNTY Plaintiff CIVIL ACTION - LAW vs. MICHAEL A. HENRY Mortgagor(s) and Real Owner(s) ACTION OF MORTGAGE FORECLOSURE 257 Southside Drive a/k!a Lot lOA Southside Drive Newville, PA 17241 Term No. ~'I'-170fo ~ Defendant(s) OIVIl.. ACTION: MORTGAGE rOFtECLOeUfltE THIS FIRM IS A DEBT COLLECTOR AND WE ARE ATTEMPTlNGTO COLLECT A DEBT OWED TO OUR CLIENT. ANY INFORMATION OBTAINED FROM YOU WILL BE USED FOR THE PURPOSE OF COLLECTING THE DEBT. NOTICE You have been sued in court. If you wish to defend against the claims set forth in the foIlawing 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 offor any other claim or relief requested by the Plaintiff You may lose money or property or other rights important 10 you. YOU SHOULD TAKE THIS PAPER TO YOUR LAWYER AT ONCE. IF YOU 00 NOT HAVE A LAWYER OR CANNOT AFFORD ONE, GO TO OR TELEPHONE THE OFFICE SET FORTH BELOW. THIS QFFlCECAN PROVIDE YOU WITH INFORMATION ABOUT HIRING A LAWYER. IF VOU CANNOT AFFORD TO HIRE A LAWYER, THIS OFFICE MAYBE 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 Slrvine Row Carlisle,PA 17013 717-243-9400 CUMBERLAND COUNn" BAR ASSOCIA nON 2 Liberty Avenue Carlisle,PA 170]3 A-Y..LS....Q LE HAN DEMANDADO A USTED EN LA CORTE. SI DESEA DEFENDERSE CONTRA LAS QUFJAS PERESENTADAS, ES ABSOLUTAMENTE NECESSARIO QUE USTED RESPONDA DENTRO DE20 DlAS DESPUES DE SER SERVIDO CON ESTA DEMANDA Y AVISO. PARA DEFENDERSE ES NECESSARIO QUE USTED, 0 SU ABOGADO, REGISTRE CON LA CORTE EN FORMA ESCRITA, ELPUNTO DE VISTA DE USTED V CUALQUlER OBJECCION CONTRA LAS QUEJAS EN ESTA DEMANDA. RECUERDE: SI USTED NO REPONDE A ESTA DEMANDA, SE PUEDE PROSEGUlR CON EL PROCESO SIN SU PARTlCIPACION. ENTONCES, LA COUTE PUEDE. SIN NOTlFICARIO, DEClDfR A FAVOR DEL DEMANDANTE Y REQUERIRA QUE USTED CUMPLA CON TODAS LAS PROVISIONES DE ESTA DEMANDA. POR RAZON DE ESA DECISION, ES POSSIBLE QUE USTED PUEDA PERDER DINERO, PROPIEDAD U OTROS DERECHOS IMPORTANTES. USTED DEBE LLEV AR ESTE PAPEL A SU ABOGADO ENSEGUIDA. SI USTED NO TIENE UN ABOGADO, VA Y A 0 LLAME POR TELCFONO LA OFlClNA FlJADA AQui ABAJO. ESTA OFICINA PUEDE PROVEER(: CON INFORMACION DE COMO CONSEUIR UN ABOGAOO. Sf OSTED NO PUEDE PAGARLE A UN ABOGADO. (:STA OFlCINA PUEDE PROVEERE INFORMACION ACERCA AGENCIAS QUE PUEDAN OFRECER SERVICIOS LEGAL A PERSONAS ELIGIBLE AQ UN HONORARIQ REOUCIOO 0 GRATIS. LEGAL SERVICES INC S Irvine Row Carlisle, PA 17013 717-243-9400 CUMBERLAND COUNTY BAR ASSOCIATION 2 Liberty Avenue Carlisle. PA ]7013 COMPLAINT IN MORTGAGE FORECLOSURE 1. Plaintiff is M&T MORTGAGE CORPORATION, PO Box 840, Buffalo, NY 14240-0840. 2. The name(s) and address(es) of the Defendant(s) is/are MICHAEL A. HENRY, 257 Southside Drive aIkIa Lot. 10 A Southside Drive, Newville, PA 17241, who is/are the mortgagor(s) and real owner(s) of the mortgaged premises hereinafter described. 3. On May 24,2001 mortgagor(s) made, executed and delivered a mortgage upon the premises hereinafter described to M&T MORTGAGE CORPORATION, which mortgage is recorded in the Office of the Recorder of Deeds of Cumberland County as Book 1709 Page 667. The mortgage has not been assigned unless said assignment to the Plaintiff is hereafter mentioned. These documents are matters of public record and are incorporated herein by reference in accordance with Pennsylvania Rule of Civil Procedure 1019(g). 4. The premises subject to said mortgage is described as attached. 5. The mortgage is in default because monthly payment of principal and interest upon said mortgage due December 01,2003, and each month thereafter are due and unpaid, and by the terms of said mortgage, upon default in such payments for a period of one month, the entire principal balance and all interest due thereon are collectible forthwith. 6. The following amounts are due on the mortgage: Principal Balance Interest from 11/01/2003 through 04/30/2004 at 8.1250% Per Diem interest rate at $26.34 Attorney's Fee at 5.0% of Principal Balance Late Charges from 12/0112003 to 04/30/2004 Monthly late charge amount at $53.83 Costs of suit and Title Search $118,362.31 $4,793.87 $5,918.12 $280.90 Corporate Advance Escrow $900.00 $130,255.20 +$100.00 +$272.47 $130,627.67 7. The Attorney's Fees set forth above are in conformity with the Mortgage documents and Pennsylvania law, and, will be collected in the event of a third party purchaser at Sheriff's Sale. If the Mortgage is reinstated prior to the Sale reasonable Attorney's Fees will be charged based on wmk actually performed. 8. NDtice ofIntention to Foreclose and a Notice of Homeowners' Emergency Mortgage Assistance has been sent to Defendant( s) by Certified and regular mail, as required by Act 160 Df 1998 of the Commonwealth of Perm sylvania, on the date(s) set forth in the true and CDrrect copy Dfsuch notice(s) attached hereto as Exhibit "A". The Defendant(s) haslhave not had the required face-to-face meeting within the required time and Plaintiff has no knowledge of any such meeting being requested by the Defendant(s) through the Plaintiff, the Permsylvania Housing Finance Agency, or any appropriate Consumer Credit Counseling Agency. WHEREFORE, Plaintiff demands an in rem judgment in mortgage foreclosure in the sum of $130,627.67, together with interest at the rate of$26.34, per day and other expenses incurred by the Plaintiff which are properly chargeable in accordance with the terms ofthe mortgage, and for the foreclosure and sale of the mortgaged premises. By: (/tHJdr. ,1\ a. Y~if(C'~'-M~F TY & MCKEEVER[I' By: JOSEPH A. GOLDBECK, JR., ESQUIRE ATTORNEY FOR PLAINTIFF VERIFICATION I, Diana M. Robinson, Assistant Vice President, as the representative of the Plaintiff cOlporanon within named do hereby verifY that I am authorized to and do make this verification on behalf of the Plaintiff cOlporation and the facts set forth in the foregoing Complaint are true and correct to the best of my knowledge, infonnation 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: L( -I \p -0'1 AM/- Diana M. Robinson, Assistant Vice President M&T MORTGAGE COMPANY ALL TUA T CEAN 'IroCI ofl.nd situnle in Penll Towne Cumb~"lnnd Coullly, ".Pennsylvania. bounded and dcs'~ribed in accordance with a survey by Dean A ~ mith, II, . registered surveyor dated Scpfember 4, /996, a copy of which is attached to de 'd recorded at Cumberlnnd County Deed Ilook 148. Page 164. as follows: DEGINNING at nn irol] pin at corner oflnnds now or formerly of Bart Ira E. Woods and formerly of Albert Henzler; the"ce along the Innds now or formerly orBarbaral. Woods, South 30 degrees 33 minutes 56.48 se-::onds West, 890.25 feet to an iron pin in the !in orrands now or formerly of John Thumma; thence along the lands 'lOW or formerly of John Thu lOla, North 38 degrees 55 minutes 7.55 seconds West. I J 10.4 J feet to an iron pin in the line OJ lands now or formerly ofO.C. Tritt; thence along the Innd, nowortormerly ofO.C. Trill. N'1h 28 degrees 41 minutes 3.55 seconds East. 890. J 7 feet to an iron pin in the line ofJands now OJ rormerty ofG. Leroy Jones and Dorothy B. Jonc~; and formerly of William Ilrandts; thence aiOl ;~ the lands now or formerly ofG, Leroy Jones and Dorothy S, Joncs~ South 39 degrees 48 mint: es 32.74 .econds, J 137.63 feel to an iron pin allhe place of BEGINNING. CONTAINING 21.416 ac.res more 01' less, known as and numbered 2Y Southside Drive_ NewviUe, Pennsylvania 17241. TOGETHER Wilh the "-Sht of in yes", egress and regress to and from to premises I Certify this to be 'ccorc1ed In Cumberland Conty PA ~~.?"?~ .. RecordeJ of Deeds A1"1'"~~ W\~,tf 1I'<iIl~i7GJ_ 1;8.1 F!:1 MBa'Mortgage'Corporation A 5ubt;."';~1' u' Md1 tlllr1c Fehruary 27, 2004 ~XH/8Ir A Michael A Hl:nry 257 South Side Dr Newville, PA 17241 IIOl\lF.;OWNER'S NA1\'JI<.:(S): Mil~hlleJ A Henry PROI'Jj;RTY ADDRESS: 257 SI)uth Side Dr Newvllle, PA J 7241 0000079741 M &1' Morl~a~c CorporlltioQ LOAN ACCT. NO.: CVRRE"'T LI<:NOf.R/SER,VICER: HOMEOWNER'S F.MF.RGENCY MORTGAGE ASSISTANCE PROGRAM YOU MAY BE ELIG/BI.F. FOR FINANCIAl. ASSIST",'1CE WHICH CAN SA iE YOIJR HOME FROM FORECLOSUIU; ANIl IlELP YOU MAKE FUTURE MORTGAf;F. PI '(MENTS IF YOU COMPI.Y WITU THE PROYISTONS OF TIIJ;; IIOMEOWNER'S EM 'R(;ENCY MORTGAGE ASSISTANCE ACT OF 19113 (THE "ACT"), YOIJ Mil. V BE ELI;IBLE FOR EMERW':NCY MORTGAGE ASSTSTANCE: It' YOUR IlEFAl'L'C HAS REE!\' CAUSED BY CIRCUMSTANCE: BEYONll YOUR CONTROL, IF YOU IIAVE A RF.ASONABLE PROSPECT OF BEING ABLE T 'PAY YOUR :WORTGAGE J~AYMENTS, AND IF YOU MJ;;ET OTIIER ELIGIBILITY REQUIREMENTS F.STABI ISITED RY TUE PENNSYLVANIA HOUSING }'INANCE AGENCY. TEMPORARY STAY OF FORECLOSURE - (Jmh:rthe Act, you areentilkd to a :mporary stay of toreclosure all your mortga~ for fhil"ty (30) days from the da(~ uf this Notice. Durirlghllt time you must arnmge and a.ttend a "tal.:L'-to-face' meeting with one of the consumer l.:n:<!it counselin agencies listed at the end ofn,j, Notice, 1'1/18 MEETING MUST OCCIlR WITlIlN THE NEXT /30) I\YS, ll' YOl) 00 NOT APPL Y FOR EMeRGENCY MORTGAGE ASSISTANCE YOU MUST B,RO' :} YOUR MORTGAGE VI'TO DATE, TUEj'MT OF THIS NOTICE CAI.I.ED"UOW TO eRE YOUR MORTGAGE DUFAULT". EXPtArNS HOW TO BRING YOUR MORTGAGE VP 1-0 DATE. CONSUMER CREDIT r.OL:'NSKLl.~G AGENCIES -- If you meet with one of the ::onsumer credit counseling agency listed at the C'He orthis notice, the lender may NOT take action flgJilst you for thirty (30) day~ <lnl..'r the- dare ofthis ml:eting. Lle names, addresses 3lld klephpm: numbers of d~ 19natcd consumer credit coullselinl! ll!.!cnCICS for the count)' in which the propqrlv is located are set fi>r!h. ,t the end of thi~ 1 BOO 774 1633. C{)(respondencr1 . po. Bill( 840, Buffalo, NY 14240-o!:S4Q' Payments - F'.O. Be_ 444. 'uNala, NY 14240..0444 Mortgage iJecQLmt inlorrTlllrlon,jtlsr oJ click IiwaY. ~.mandtmorlgage.com m1 M&fMortgage'D:>>:poration I\Sul!31cf1l'YoIMaI'Janlo; Nolie!,:. It is only neces,...ary [0 schedule one face-to-face meeting. Advis(~ YOllr lende imrm:diatelv of your intentlolls ...o\PPLICAnON FOR MORTGAGE ASSIST ~'lCE -- Your mortgage is 111 detau I [or the reasons set furlh later in this Notice (Sl~t: followmg page." fix specific mformation about the natu ~ nfyuur default.) If you have fried and are unab1c 10 n'solve this problem with the lender, you helve the T' ,ht to :apply ror financial assisl.mce from the Homc<lwnL'f's Emergency Mortgage Assistance Pm!,.rrlu To do so. you mlJst fill out, Sj61J1 and tile II completed Homeowlll.:r's Emergency Assist.ancl' Program Apf caliun with one of the dl'si!,'llated Consumer credit coum;elin,K agencies lis/cd at the end ofthis Notice. Onl} :onSUHlcr credit counseling ugcncies have applicalic.:ns for the program and Ihey will aSsIst you in sui "rlitting It COOlf11dc application to the Pennsylvama Housing Finance Agency. Your application MUST 11 filed or postmarked wIlhin thirty (30) days of your face-to-face mccr.ing. YOU MUST FILl( YOlJR APPLICATION PROMPTLY. IF YOU FAIT. TO VI SOOR IF YOU PO NOT FOl.l.OW TIlE OTHER TIME PERIODS SET FORTlllN THiS LKTTI 11. FORE(:LOSllRE MAY PROCEED AGAINST YOUR HOMF. IMMEDIATELY A:\'D YOUR AP LlCA nON FOR MORTGAGE ASSISTANCE WILL DE PI(NII':O. AGENCY ACTION - AvaiIablf~ funds for emergency mortgage assi!Sl.mce are very 100ited. They ,.viii be disbursed by the Agency under the eligibtllty criteria cSI<lbhshed by the Act. The Pen Sy1V611l11 Housing Flllance Agency has sixty (60) days Lo make a deCIsion after il receives your npP)lcat 'n, DUrln.R; that time, no foreclosure proceedings will be pursued against you if you have met the time requ emcnl.s set forth above. Yau will be noli fku directly by the Penrlsylvania Housing Finunct,: Agency ot ts decision un your applit.:ation. NOTI':: IF YOlJ ARE ClJRRIi:NTL Y PROTECTED BY THE FILING OF A PF I'(TION IN BANKRUPTCY. THE FOLLOWING PART OF THiS NOTICE IS FOR INt'{) :MAnON PURPOSES ONLY AND SHOI;LD NOT BI': CONSIDEIU:P AS AN ATTEMP' '1'0 COLLECT THE DEBT. (If you have filed bankruph:y }"{IU (';In still apply for Emergency MGrtga1l:c Msjsl.llnee.) HOW TO ClIR.E: YOUR MORTGAGE DEt'AUL T (Brio" it UP t date). ~ATURF. OF THE DEFAliL T ..-Thl: MORTGAGE debt fjcJd by the above lender I I your property located at: 257 South Side Dr ~'ewvdJe, P A 1724! IS SERIOUSL Y IN DEFAULT because; YOU HA VI1 NOT MADE MORTGAGE PAYMENTS for the follmving months and the amounts an.; now pa..~t due: Regular payments urSl.076.79 for the rnunlhs of 12/01/2003 through today'~ date: Other charges: Accrued late charges: Accrued other fees: 1)1lowing TOTAl. AMOUII;T PAST PIIK; S3.4".85 S 216_72 $ 000 53.670.57 HOWTO CtrRE TOI!: DEFAt:I.T --You may cUr~ lhcdcfatllt within THrRTY (30) )AYS orthc datI! of 'his notice BY PAYING THE TOTAL A'lfOUNT PAST DlJE TO TIlE LE.';oER WHICH IS 1 BOO n4 1633' COrnlspondBnc". P,Cl_ EloJ< 640, Buffalo, NY 14140 0840 . Payment.!. P.O Bo.... 44.4, !unllla. NY 14240-0444 Mart(Jagc aC<:(JI.'fJ/ information,lust a chell "'W/dY, www,mandlmortg<lQe.colll Pl:1 M&fMort:gage 'Corporation l\i'iIJI";i;.I;wyolW6a'* $1.1i70.57. PLUS ANY MORTG.\GE PAY~1I:NTS AND LATE CHAR(iES WHIC I DECOMI' J)(JF UURINn THE TIIIRTY ('30) DA Y PERIOD. PavmcJ1ts qmsl be made either by ~asl . (.:(jshier's ChCl.;K, certified check or money order nJ!llIs: payahle and sent to:, M&T Mortgage CorlloraUuD One FOllRtaln Plaza 17th Floor Atto: Pa:rment Procf.'Ssing BuITalo.:';Y 1420.1 Yl,)U I.:un CYfe any Qther dell-mil bY..!flkimz the foHowinl,!liefion within THIRTY (30) r \ YS urlhe ~te ofrhis letter: IFYOU DO NOT CURE TIlEm:F'AULT-Jfyou do not cure dle delimit within J IIRTY (30) DAYS of the dalr: ofthis Notice. tbe lellde'" intends to exercise its rights to accelerate the III rt,gage debt. This means that the L'Iltire outstanding halance of Ihis debt WIll be considered due immedi. .ely and yuu may lose the- chance to pay the mortgage in monthly iJl~lli!lmcnts. If full payment or the total a ount past due is not made within THIRTY (3()) OA YS, the lender aJso intend", to instruct its atrotney~ to: art legal actiQn to forecJose ullOn your mortgaged pr'oper1y. IF THE MORTGAGF. IS FORECLOSED UPON -- The mortgaged property will 'c sold by the Shentl"t(J pay orrthe mortgage debt. If the Iocmlcr refers your case to its attorneys. but you cure 11C delinquency before the lende!' hegins legal prOceedings agaim! yOll, you will still be required to pay the r ;tsonable attorney's fees that were actually incurred, up 1:0 $50.00. However, if legal proceedings aTC start d against you, you will have to pay all reasonahle attumc;/s fees actually incurred by the lender even if they I '(cced $50.00. Any attorney's fees will be added to the amount you owe the lender, whieh may also inelul ;~ other reasonable costs. If you cure the default within the TmRTY (30) DAY pcriod~ you wiD not I :~ requlrcd to pay attorney's fees. OTHER I..E,,~ER REMEDJES - The lender may also sue ynu pcrsonally for the L Ipaid principal balance and all other sums due under the nortgnge. RIGHT TO CURE THE IlF.F.4.l11.T PRIOR TO SHFRIFf'S SALE ..If you hav nol cu,"d the default within the THIRTY (30) DAY period (lnd foreclosure proceeding,\> havt' begun, you sl J have I.he right to cure the default amI prevent the sale nt any time up to one hour before the Sheriffs Sa :. You may do "'0 by pl:l.ying the total atnount then P<lsl due, plus any late or other charges then due, reasom fie nttornt:y's fees and costs crmncetcd with the foreclosure S<llc and any other costs connected with the Sher t's Sale as specified In \\-Titin~ by the lendl.'T and by performmg any olher requirements under the murtgage. t llring your default in fhe manner set forth inlhis notke will restore your mort~age to tbe sallie l'ositiv as If you bad never d~falllted, EARLIES'I' POSSIBI.F. SHERJ}'F"S SALE DATE ~- It is estimated that the clirlies date that such a Sheriff'~ Sah: ofthC' mortgaged pfOpl~rty could be- held would he appruximate1,., IU m luth.\i frum the date of this Notice. A lldlice of the actual date of the Sheriffs Sale ,..'ill be ",en' to you befo I~ the sale. or course. the amount needed to cure the default ,,,.i11 increase the Tunger you wait, You may find HIt at any tlme exactly whaf the required pa}111ellt or action will be by contacting (he lender. RQW TO CONT A~T TIi.E LEl\1JoEJl.: Na~ of Lelld~r: M~~'I' Mortgage Corporalion ~ P,o. Dux 840 Uuffalo. NY 14240 Phone NUJllh~r: (8UO) 724.1633 1 8007241633. CmT&SpOnoofll.:e. P.O. DOl( MO, Auffulo, NY 14240-0840' Payroonts - PO. BOil 444, !uffalo, NY 14740-0444 Mortgage aCI;m,'nt informali,,,,, just a click away. www_mandtrtlorll:l~e,com !1 M&fMort:gage'Corporation ,1\:';I,;)r,dlryr:JM..T[3ank F.FFECT OF SHl:.RJFF'S SALE-~ You should real!:'-J: that a Shenffs Sale w-j]J enl your ownership of the mortgaged property and your right 'II m:Cllpy it. Jfyou continue 10 live in the properl :Iller the ShL"fjft'S Su!(;, a lawsuit to remove yuu and YOUI' fUl11ishillg~ ,IUd other belongmg.<; cmdd he started l .' the lcndl.:r at any lime. ASSUMPTION OF MORTGAG}: ~- -You ~ may ur X may Qot sell 01' tran~fe your home to a hUYl'f or transferee who will assume tlw mnrlgllgl' debt, provIded that all the olltstandmg p~ ;ments, charHes and attorney's fees and costs are paid prior to Or allhe saTe and that the nthcr requirement of the murtgage are satisfied- YOU MAY ALSO HA VI( THE RIGHT: TO SEl,I. THE PROPERTY TO OBTAIN MONEY TO PAY OFF TlW MORTGAGE I ERT OR TO BORROW MONEY FROM AI\OTHF.R LFt-.;llINU INSTITUTJON TO PAY OFF THI, DEBT. TO HAVE THIS Of;FAUL"fCl!RED BY ANY Tl\lRD PARTY ACTING O'I YOUR E ~HALF. TO 11A VE THE MORTGAGF. RESTORED TO THE SAME POSITION AS IF NO OF] ,\ULT HAD OCCURRED, IF YOU Cl,.'RE THE DEFAULT. <HOWEVER, YOl! DO >JOT HAVE T IS RTCiIH TO aJRE YOUR DEFAL"LT MORE "THAN THREE TIMES IN A\lY CALENDAR YEAF TO ASSERT niL NONE"XISTEI\"CE OF A DI]iAULT IN ANY FOREcf.oSURE PRe ~EEDING {)R ANY OTHER LAWSUIT TNSTITUTED UNDER THE MORTGAGE DOCUMENTS, TO ASSERT ANY OTHER nEI'ENSE YOU BELIEVE VOL MAY HAVE TO SOCH. CUON BY THE LFI'WER. TO SeEK PROTECTION l.INn~~R l'lW FEDERAL BANK RUPTC.... LAW. Sincerely, Martha 'roth Ene: Act 91 Notice ConsulTler Crectit Counseling AgelU.;ic~ Serving. Your CouIlty LGM4 1 ROO 724 1633' CumJspond&nerl - P,O, EIox 840. ~uffalo. NY 14240-0FJ40. PflYlnents. P.O. Oox 441, :uffalo, NY 14240-0444 M()rfg.'lga OCl:O(.'fI! iflformation, juM ~ click aw"y, www.rmmdtmortRi.Ige.com r:g M&fMortgage 'Corporation i~SlbHIi;,v,-,IM48er1c natc: F bruary 27,2004 ACT 91 NOTICE TAKE ACTION TO SA IVE YOUR HOME FROl\t1: FORECLOSURE This is an official .Qotice tbat the mo'"teac:e on tour home is In default, i !ld the lender Intcnds to fureclose. Specftlc information about the natufe of the defaull -'5 provided in tbe attached P35i1:es. The HOMEOWNER'S MORTGAGE ASSISTANCE ]>HOGRAM /HErA]>) mav be ablro to help to save your home. This Notice c%plain,: how the proer; ID works. To see if REMAP ean heln. you must MEET WITH A CONSUMEr CREDIT COUNSELING AGENC\' WITHIN 30 DAYS O~'THE DATE OICTA S NOTICE. Take this Notice witb vou when you met' with the Coul1selin~ A ~~ The Dallle~ address and phmlc number of Consumer (:redit CounseHl :l A2cneies servin2 your County are listed at tbe end of this Notjc~. Uvou have any luestions. vou mav call the Pennsvlvania Housine. Finance Allene" toll free at 1-800-342 ,2397.lPersoDs with impaired hearine can can (717) 780-1869). This Notice contains important J~al inforroation. Jf you have any ( I.estfons, representatives at the Con~umer Credit Counseling A~ency may be able ,) help explain it. You may also wallt to cUDtact an attorney in your area. The local ba ~ssociation ma~i hc able to help you find a lawyer. I.A NOTIFICACI0N F:N AOJUNTO ES DE SIJMA IMPORTANC:IA, PIES AFECTA SU OERECHO A CONTINUAR VIVIENDO EN SU CASA. SI NO CO~ PREN()~: EL CONTENIDO DE ESTA NOTIFICACION ORTENGA UNA TRAlI.ICClON lNMEDIT AMENn: LLAMANDO EST A AGENCIA (PENNSY I. VAN) lHOUSING FINANCE AGENCY) SIN (:ARGOS AI. NUMERO MENCIONAD{ ARRIBA. PUEDES SER EI.KGIl'lLE PARA UN PREST AMO POR EL PHO :RAMA LLAMAI>O "HOMEOWNER'S EMERGENCY MORTGAGE ASS STANCt; PROGRAM" EL ClJAL /'lJEDE SAL V AH SlI CASA DE LA PICHI] OA DEL I)EIUiCIlO A REOIMIR SU lIIPOTECA. 1 80(.) 724 1633 . Corrnr;fJOfIcknCQ -P.O. Box 840, Bllff<ljo. NY 1424Q-0840' Pltymenfll- P.O, BOle 444, :uffalo, NY 14240-0444 Mo1tllllgC accotJnt inm,"""tiolJ, jllsl /J click Ilway. WWW.mandtmortgage,U)fn Counseling Agencies in Cumberland County . LOAN NUMBER OQ0807974I Adams Copnty Housing Authority 1J\,Q43CarJislcSI. Gt"lIysbuoc,/'.A 17~2.5 (717) 334.1518 cr:cs of Western fA 21)00 Linl(lc.~to\\'" Road II:lTTisburg,PA 17102 (717)541.1757 Community Action Comminlon of C~ptjal RtRion 1514 [Jr.rry Strc~t Ha(lisburg, PA 17104 (717)2.n-9757 Jllnandal Counsellnl!: Services of Franklin :I t W~I.hu Strecl v."ayru:,>boTl), P A J 7268 (7]7)762-328' Loveship, Inc. 2]20 North 5th SIJt:~l Hw-rl~burg.I'A f7110 (717)212-2207 Urban League of Metropolitan HbJ~ 2J07 N, 6th Slreer Harri$lwl'e. PA 1710! {717) 234-SnS w I , PoSlaQA r--- ~~;~~~;;,;;; I Restricted De'ivery Fee Il:ndo""'MnIHaqUir~<l,l~ TDI",! P~t~ge ~!~ PoStmsrk Hl!rl! "" o a- m o -ll "" ~ ~'ldl:td A U"U1} )":.';''','I!iSi,leDr !'''~',q.dh'.I',.\ 1'2.11 ; J.~lli"'~()?'i7.,l1 .~PSFz::;)l :'!1;lOO ~-tJPlember 2002 us PQstal ;'''rYI~'' Certified Mall Receipt ~~ ",,' ~ (J' 1 ~ ". ' \3 'V \) ~ "(\ ~ ~ Cv "" . '^ \I\~ "^, I:,J C; *";; '- \::J \ ,\\:3 " ' " '\ "- '< !\. . ~ ~ ~ ~~ ~ \ ~ ~._1 c _1_.- I.:' SHERIFF'S RETURN - REGULAR CASE NO: 2004-01706 P COMMONWEALTH OF PENNSYLVANIA: COUNTY OF CUMBERLAND M & T MORTGAGE CORP VS HENRY MICHAEL A RON KERR , Sheriff or Deputy Sheriff of Cumberland County,Pennsylvania, who being duly sworn according to law, says, the within COMPLAINT - MORT FORE was served upon HENRY MICHAEL A the DEFENDANT , at 1712:00 HOURS, on the 4th day of May , 2004 at 257 SOUTHS IDE DRIVE LOT lOA NEWVILLE, PA 17241 by handing to MELISSA RAKERS 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 Service Affidavit Surcharge So Answers: 05/05/2004 GOLDBBEyCK: MCCAF[l RTY Sworn and Subscribed to before _ me this 13 a.. day of ~ eputy OJ.. 0.0 f?' A.D. j-h 1';- ~~.. .- U Prothonotary , 18.00 8.28 .00 10.00 .00 36.28 r~~ R. Thomas Kline MCKEEVER IL- ~heriff ~ GOLDBECK McCAFFERTY & McKEEVER BY: Joseph'A. Goldbeck, Jr. AttDrney LD. #16132 Suite 500 - The Bourse Bldg. III S. Independence Mall East Philadelphia, PA 19106 215-627-1322 Attorney for Plaintiff M&T MORTGAGE CORPORATION PO Box 840 Buffalo, NY 14240-0840 IN THE COURT OF COMMON PLEAS Plaintiff of Cumberland County vs. MICHAEL A. HENRY (Mortgagor(s) and Record owner(s)) 257 Southside Drive aIkIa Lot lOA Southside Drive Newville, PA 17241 CIVIL ACTION LAW ACTION OF MORTGAGE FORECLOSURE Defendant( s) No. 04 1706 CIVIL ORDER FOR JUDGMENT Please enter Judgment in favor Df M&T MORTGAGE CORPORATION, and against MICHAEL A. HENRY for failure to file an Answer in the above action within (20) days (or sixty (60) days if defendant is the United States of America) fmm the date of service of the Compl in the sum of$131,841.61. - Joseph A. G( I .]:' Jr. Attorney for It! it LT I hereby certify that the above names are correct and that the P~iS r~sidence address Df the judgment creditor is M&T MORTGAGE CORPORATION PO Box 840 Buffalo, NY 14240-0840 and that the name(s) and last known address(es) Dfthe Defendant(s) is/are MICHAEL A. HENRY, 257 SDuthside Drive aIkIa Lot 10 A Southside Drive Newville, PA 17241; ASSESSMENT OF DAMAGES TO THE PROTHONOTARY; . Kindly assess the damages in this case to be as follows; Principal Balance $118,362.31 Interest from 11/01/2003 through 06/11/2004 $5,900.15 Attorney's Pee at 5.0000% ofpriucipal balance $5,918.12 Late Charges $388.56 Costs of Suit and Title Search $900.00 Corporate Advance Escrow $100.00 $272.4 7 $131,841.61 AND NOW, this I S'~ay of FERTY & McKEEVER BY; Joseph A ,"'db ck, Ir. A_,fu,' 'f J/..!.;U~004 damages are assessed as above. GOW""~~~ ~-ku K.~ ProProthy ~ ~ VERIFICATION OF NON-MILITARY SERVICE The undersigned, as the representative for the Plaintiff corporation within named do hereby verify that I am authorized to make this verification on behalf of the Plaintiff corporation and that the facts set forth in the foregoing verification of Non-Mili tary Service are true and correct to the best of my knowledge, information and belief. I understand that false statements therein are made subject to penalties of 18 Pa. C.S. 4904 relating to unsworn falsification to authorities. 1. That the above named Defendant, MICHAEL A. HENRY, is about unknown years of age, that Defendant' s last known residence is 257 Southside Drive a/k/a Lot 10 A Southside Drive, Newville, PA 17241, and is engaged in the unknown business located at unknown address. 2. That Defendant is not in the Military or Naval Service of the United States or its Allies, or otherwise within the provisions of the Soldiers' and Sailors' Civil Relief Action of Congress of 1940 and its Amendments. Date: In the Court of Common Pleas of Cumberland County M&T MORTGAGE CORPORATION PO Box 840 Buffal,?, NY 14240-0840 Plaintiff vs. MICHAEL A. HENRY (Mortgagor(s) and Record Owner(s)) 257 Southside Drive alkla Lot 10 A Southside Drive Newville, PAl 7241 No. 04 1706 CIVIL Defendant( s) PRAECIPE FOR JUDGMENT THIS LAW FIRM IS A DEBT COLLECTOR AND WE ARE ATTEMPTING TO COLLECT A DEBT OWED TO OUR CLIENT. ANY INFORMATION OBTAINED FROM YOU WILL BE USED FOR THE PURPOSE OF COLLECTING THE DEBT. Enter the Judgment in favor of Plaintiff and against MICHAEL A. HENRY by default for want of an Answer. Assess damages as follows: $131,841.61 Debt Interest - 11101/2003 to 06/1112004 Total (Assessment of Damages attached) I CERTIFY THAT FOREGOING ASSESSMENT OF DAMAGES IS FOR SPECIFIED AMOUNTS ALLEGED TO BE DUE IN THE COMPLAINT AND IS CALCULABLE AS A SUM CERTAIN FROM THE COMPLAINT. I certify that written notice of the intention to file this praecipe was mailed or delivered to the party against whom judgment is to be entered and to his attorney of record, if any, after the default occurred a leas ten days prior to the date of the filing of this praecipe. A copy of the notice is attached. R.C.P. 237.1 ' ! ! Joseph A. G)l Attorney fol'l:>. I.D. #16132 j' AND NOW Jl..Lt. 'J:' _ /-S ' ;;). OOt/, \ , Judg nt is entered in favor ofM&T MORTGAGE CORPORATION and against MICHAEL A. HENRY by aefault for want of an Answer and damages assessed in the sum of $ 1 3 1 ,84 1.61 as per the above certification. (1 ~ t }J - nL,') ~ Pro onomry 4 ~ THIS LAW FIRM IS A DEBT COLLECTOR AND WE ARE ATTEMPTING TO COL~ECT A DEBT OWED TO OUR CLIENT. ANY INFORMATION OBTAINED FROM YOU WILL BE USED FOR THE PURPOSE OF COLLECTING THE DEBT. DATE OF THIS NOTICE: May 25, 2004 TO: MICHAEL A. HENRY 257 Southside Drive aIkIa Lot 10 A Southside Drive Newville, P A 17241 M&T MORTGAGE CORPORATION PO Box 840 Buffalo, NY 14240-0840 In the Court of CDlnmon Pleas of Cumberland CDunty Plaintiff CNlL ACTION - LAW VS. MICHAEL A. HENRY (Mortgagor(s) and Record Owner(s)) 257 Southside Drive alkla Lot lOA Southside Drive Newville, PA 17241 ActiDn of Mortgage Foreclosure Term ND. 04 1706 CNIL Defendant(s) TO: MICHAEL A. HENRY 257 Southside Drive alk/a Lot 10 A Southside Drive Newville, PA 17241 IMPORTANT NOTTeR YOU ARE IN DEFAULT BECAUSE YOU HAVE FAILED TO ENTER A WRITTEN APPEARANCE PERSONALLY OR BY ATTORNEY AND FILE IN WRITING WITH THE COURT YOUR DEFENSES OR OBJECTIONS TO THE CLAIMS SET FORTH AGAINST YOU. UNLESS YOU ACT WITHIN TEN (10) DAYS FROM THE DATE OF THIS NOTICE, A JUDGMENT MAY BE ENTERED AGAINST YOU WITHOUT A HEARING AND YOU MAY LOSE YOUR PROPERTY OR OTHER IMPORTANT RIGHTS. YOU SHOULD TAKE THIS PAPER TO YOUR LAWYER AT ONCE. IF YOU DO NOT HAVE A LAWYER, GO TO OR TELEPHONE THE OFFICE SET FORTH BELOW. THIS OFFICE CAN PROVIDE YOU WITH INFORMATION ABOUT HIRING A LAWYER. IF YOU CANNOT AFFORD TO HIRE A LAWYER, THIS OFFICE MAY BE ABLE TO PROVIDE YOU WITH INFORMATION ABOUT AGENCIES TIIAT MAY OFFER LEGAL SERVICES TO ELIGIBLE PERSONS AT A REDUCED FEE OR NO FEE. LEGAL SERVICES INC 8 Irvine Row Carlisle, P A 17013 717-243-9400 CUMBERLAND COUNTY BAR ASSOCIATION 2 Liberty Avenue Carlisle, PA 17013 GOLDBECK McCAFFERTY & McKEEVER BY: Joseph A. Goldbeck, Jr.. Esq. Attorney for Plaintiff Suite 5000 - MelIon Independence Center. 701 Ma,xet Street Philadelphia. PA 19106 215-627-1322 ~ ~ t~ ....p c 0 (') I'-> 0 c:';> ('~ ~:::J ." F -- III .,,- lrt ~ ~::~.:. ...., () :1: :D )J n'r- :.:.::.t.: -.,fTl ~ - ~ :06 c" U1 c") ....0 ~ b :=j-r-~ ~ ;:d?~S, ~ t-: c;::-< ,::--, '? ;::)rr. ~ ::-\ --- -~... "--.!..... ~- ~ ~u W', <-- -< '-<, ...- WRIT OF EXECUTION and/or ATTACHMENT COMMONWEALTH OF PENNSYL VANIA) COUNTY OF CUMBERLAND) TO THE SHERIFF OF CUMBERLAND COUNTY: To satisfy the debt, interest and costs due M & T MORTGAGE CORPORATION, Plaintiff(s) NO 04-1706 Civil CIVIL ACTION - LAW From MICHAEL A. HENRY (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 gamishee(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) Ifproperty of the defendant(s) not levied upon an subject to attachment is found in the possession of anyone other than a named garnishee, you are directed to notify himlher that he/she has been added as a garnishee and is enjoined as above stated. Amount Due $131,841.61 Interest FROM 11/1/03 TO 6/11/04 AT 8.1250% L.L. $.50 Atty's Conun % Atty Paid $118.28 Plaintiff Paid Date: JUNE 15, 2004 Due Prothy $1.00 Other Costs CURTIS R. LONG (Seal) Prothon~ry p Cyy; _____ _ By: .A/J~I. ., '(CIVZ<.F" Deputy REQUESTING PARTY: Name JOSEPH A. GOLDBECK, JR., ESQUIRE Address: SUITE 500 - THE BOURSE BLDG. 111 S. INDEPENDENCE MALL EAST PHILADELPHIA, PA 19106 Attorney for: PLAINTIFF Telephone: 215-627-1322 Supreme Court ID No. 16132 PRAECIPE FOR WRIT OF EXECUTION - (MORTGAGE FORECLOSURE) P.R.C.P 3180-3183 -' Joseph :... Goldbeck, Jr. AttorneyLD.#16132 Suite 500 - Tbe Bourse Bldg. III S. Independence Mall East Philadelphia, P A 19106 215-627-1322 Attorney for Plaintiff M&T MORTGAGE CORPORATION PO Box 840 Buffalo, NY 14240-0840 IN THE COURT OF COMMON PLEAS Plaintiff vs. of Cumberland County MICHAEL A. HENRY Mortgagor(s) and Record Owner(s) 257 Southside Drive a/k/a Lot 10 A Soutbside Drive Newville, PA 17241 CIVIL ACTION - LAW ACTION OF MORTGAGE FORECLOSURE Defendant(s) No. 04 1706 CIVIL PRAECIPE FOR WRIT OF EXECUTION TO THE PROTHONOTARY: Issue Writ of Execution in the above matter: Amount Due $131,841.61 Interest from 11/01/2003 to 06/11/2004 at 8.1250% (Costs to be added) GOLDBECK FERTY & McKEEVER BY: Josepb A.d'eck, Jr. Attorney for P,," \\ ?CJ P ( ~ fk- ~ 'f-. Y I"l -,...." ~~ ( "6,. ::::: ~""'~ ~ !L ';'0 ~ f'"" .v, J-.> '-l D ~ iv 0 '\}OCO'\}D . ~;J) , "'00::- ... ..,~(~ , :.::~ '" 2 () ..J;..- -n ,~.~~-.:. ::;:i _._ fi:ij;] -"in (~~ )~ cr' ~-~,~ ;:3 :::'~r':.6 , ':~I ~ '. ~:o -< ~"'9. . ~ '"to o () J:~ -- 1-...l ~ D ~ ~ ...o~ " > .~ ~ z '" 0 0 ~ -< ~ " .... " ., :=:::-9 ,.. > ..:i ~ ~ ~ dol . '<n - ~"'" " 00 '" I>.; E- ~ ~ u~ ~:!l~", " " z ~ :><~c55 ~ ~ ~i::: ~CQ::::::o ::;::"",- ,.,lo 0 ~o-<;;;: ., ;; ...:.4~ .~ o/j~::E;::~ >::;:: .....9 " .5 ~ lJ.l'Eo~ " '" -::;:: o ij ..0- tO~~M 0-_ .,,1>.; CQ~A.."""" UO 0 :r:,,~-< ,.. z - ~ dol Cl) ~ ci~ U . " 0 o<B a;:g u -<~,.,lo.. ~.... :::::~ c...... ~ ~ 00 ....l "d etI ~ >, ~f-<o"'O\D "t"- .... tJ > ~ ~ U I fr..&tA E--O ';i!~~~ " -< '" E: '" ,,- "'E- ~~ "'" ~8]""gN tJ :r: ~ " ~ " 0 ~g; E- o ... "'''' ~V)~] ~ u '"@"r=z .... 0 8< ~.~ en p.. Zo 0 - 000 .,6 -. ::E '" ..0"- U ::E 00" I>.; ~UJ::: t::." .... ., E- o .~ U c3 == "d ::E ~ ., ~,s ,.. ::E " ~ ~ 0 r/J t"- on N ALL TtlAT QEIlTAlN tract ofltml ,il\late in Penn Tawnab!p. CumIMdInd County, P_syIvtM, bounded and dellCri~ in lClCOrdanae with << survey by Dean A. Smith. n. realaterw lul'Yeyor ~ted September 4. 1996. a copy ofwbich is an&chlld to 4_ ncor.5wllt Cum'*1l1l1d County Deed 800\1;'148, Pap lISt as t\)\Iows: BOOlNI'IING lit an iton pin at corner ofland. now or 1btn'\el'1y otBar\Jua B. Woodt IIId formerly of AIbcn Hatzler; thence along th,lend, now Of fon:netly ofBarbIra E. Waod&, South 30 de~ 33 minutes 56.48 ICICOnds W"" 890.:lS feet to an Iron plll ulllle n.. oflllldt now or tbnncrly oUobn Thumma; tbomce aloll3 JM 1&IId, now or fQm1erty otJohn TlIIIlI'lIM, North 38 <learee- 55 mil\\ltn 7.5S IOCOt\Cls WOIt. 111041 f~ tt) ,n ll'Qn pin In tile tine oflaMt lIOWor fOl'lMlly ofO.C. Tritt; tbeneo alona tho lands now ur fonnect)' oro.C. Tritt. North 28 ___ 4' 1l1lnut.. 3.S5 MC<Jnd& ))all, 890.11 ,",IIC> IIlllron pin in am. line oflll)(\l now or formerly 0'0. Ltroy Jo_and Oo..,thy B. Jono. and fonnelly of William Brandts; thence along tM \ands now or formerly o(G. Leroy Jones Ind Oorothy B. Jones., South 39 ol.- 'Ill minut.. n.7" cec:ondc, 1137.63 feet to an Iron pin at tile pla.eo ofBEGlNNING. CONTAlNtNG %1,416 lIlll'tS more Of less, knowa 1$ lIlld nUlllbonld 25'1 Sauthtlde Drive, Newvillo, Pennsylvania 17241. Goldbeck McCafferty & McKeever BY: Ja,;eph A. Goldbeck, Jr. A\:t6rney I.D. #16132 Suite 500 - The Bourse Bldg. III S. Independence Mall East Philadelphia, PA 19106 215-627-1322 Attorney for Plaintiff M&T MORTGAGE CORPORATION PO BDX 840 Buffalo, NY 14240-0840 IN THE COURT OF COMMON PLEAS Plaintiff of Cwnberland County vs. MICHAEL A. HENRY (Mortgagor(s) and Record Owner(s)) 257 Southside Drive a/k1a Lot lOA Southside Drive Newville, PA 17241 CIVIL ACTION - LAW ACTION OF MORTGAGE FORECLOSURE Defendant( s) No. 04 1706 CIVIL AFFIDAVIT PURSUANT TO RULE 3129 M&T MORTGAGE CORPORATION, Plaintiff in the above action, by its attorney, Joseph A. Goldbeck, Jr., Esquire. sets forth as of the date the praecipe for the writ of execution was filed the following information concerning the real property located at: 257 Southside Drive a/k/a Lot lOA Southside Drive Newville, PA 17241 l.Name and address ofOwner(s) or Reputed Owner(s): MICHAEL A. HENRY 257 Southside Drive a!k/a Lot lOA Southside Drive Newville, PA 17241 2. Name and address of Defendant(s) in the judgment: MICHAEL A. HENRY 257 Southside Drive a/k/a Lot 10 A Southside Drive Newville, PA 17241 3. Name and last known address of every judgment creditor whose judgment is a record lien on the property to be sold: DOMESTIC RELATIONS OF CUMBERLAND COUNTY PO Box 320 Carlisle, PA 17013 P A DEPARTMENT OF PUBLIC WELFARE - Bureau of Child Support Enforcement Health and Welfare Bldg. - Room 432 P.O. Box 2675 Harrisburg, P A 17105-2675 4. Name and address of the last recorded holder of every mortgage of record: 5. Naxr", and address of every other person who has any record interest in or record lien on the property and whose interest !'lay 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 257 Southside Drive a/kla Lot 10 A Southside Drive Newville, PA 17241 (attach separate sheet if more space is needed) I verify that the statements made in this affidavit are true and correct to the best of my personal knowledge or information and belief. I understand that false statements herein are made subject to the penalties of 18 Pa. C.S. Section 4904 relating to unsworn falsification to authorities. GOLDBECK FERTY & McKEEVER BY: Joseph A '.< olib Ie, Jr., Esq. Attorney for P\"lti ~ DATED: June II, 2004 " r-> 0 t.......... (::;? ~ -r, (.:...:: .~ :r: -rl , ~.. ("l1f...::;; ;.L-. .-Ocq (J1 :~d'1' 'c :-.4 C) - l~ :.!~ ::-,.. ~':~ ("~; c~,~ ,'n C~ ~j ~,~.t :-'.t] $;" -'.. 04 1706 CIVIL GOLDBECK McCAFFERTY & McKEEVER ,< BY: Joseph A. Goldbeck, Jr. AttorneyI.D.#16132 Suite 5000- Mellon Independence Center 701 Market Street Philadelphia, P A 19106 215<627-1322 Attorney for Plaintiff M&T MORTGAGE CORPORATION PO Box 840 Buffalo, NY 14240-0840 IN THE COURT OF COMMON PLEAS Df Cumberland County Plaintiff vs. CIVIL ACTION - LAW MICHAEL A. HENRY Mortgllgor(s) and Record Owner(s) ACTION OF MORTGAGE FORECLOSURE 257 Southside Drive aIkIa Lot lOA Southside Drive Newville, PA 17241 Term No. 04 1706 CIVIL Defendant( s) THIS LAW FIRM IS A DEBT COLLECTOR AND WE ARE ATTEMPTING TO COLLECT A DEBT. THIS NOTICE IS SENT TO YOU IN AN ATTEMPT TO COLLECT A DEBT. ANY INFORMATION OBTAINED FROM YOU WILL BE USED FOR THAT PURPOSE. NOTICE OF SHERIFF'S SALE OF REAL PROPERTY TO: HENRY, MICHAEL A. MICHAEL A. HENRY 257 Southside Drive a/k1a Lot 10 A Southside Drive Newville, PA 17241 Your house at 257 Southside Drive alkfa Lot lOA Southside Drive, Newville, P A 17241 is scheduled to be sold at Sheriffs Sale on Wednesday, December 08,2004, at 10:00 AM, in Commissioners Hearing Rm 2nd FL Courthouse to enforce the court judgment of$131,841.61 obtained by M&T MORTGAGE CORPORATION 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 M&T MORTGAGE CORPORATION. the back payments, late charges, costs and reasonable attorney's fees due. To find out how much you must pay call: 215-627-1322 2. You may be able to stop the sale by filing a petition asking the Court to strike or open judgment, if the judgment was improperly entered. You may also ask the Court to postpone the sale for good cause. 04 1706 CIVIL 3. You may also be able to stop the sale through other legal proceedings. You may need an attorney to assert yoUr rights. The sooner you contact one, the more chance you will have of stopping the sale. (See notice below on how to obtain an attorney). YOU MAY STILL BE ABLE TO SAVE YOUR PROPERTY AND YOU HAVE OTHER RIGHTS EVEN IF THE SHERIFF'S SALE DOES NOT TAKE PLACE. I. If the Sheriff's Sale is not stopped, your property will be sold to the highest bidder. You may find out the price bid price by calling the Sheriff of717-240-6390. 2. You may be able to petition the Court to set aside the sale if the bid price was grossly inadequate compared to the value of your property. 3. The sale will go through only if the buyer pays the Sheriff the full amount due in the sale. To find out if this has happened, you may call the Sheriff of717-240-6390. 4. If the 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 he entitled to a share of the money which was paid for your house. A schedule of distribution of the money bid for your house will be filed by the Sheriff thirty (30) days from the date of the Sheriff's Sale. This schedule will state who will be receiving that money. The money will be paid out 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, P A 17013 CUMBERLAND COUNTY BAR ASSOCIATION 2 Liberty Avenue Carlisle, PA 17013 c..., -.>;'" '" <~ c:.;c;. ...- r. <;..~ o " :;:1 F;iF~ -r;f-n :'.i<;J ':J.)'l ::J~,. ._~':?~~ , ::l ("' " ~?~ - - (5 GOLDBECK McCAFFERTY & McKEEVER BY: Joseph A. Goldbeck, Jr. Attorney I.D.#16132 Suite 5000 - Mellon Independence Center 701 Market Street Philadelphia, PA 19106-1532 215-627-1322 Attorne for Plaintiff M&T MORTGAGE CORPORATION PO Box 840 Buffalo, NY 14240-0840 MT -0277 IN THE COURT OF COMMON PLEAS of Cumberland County Plaintiff vs. CIVIL ACTION - LAW MICHAELA. HENRY Mortgagor(s) and Record Owner(s) ACTION OF MORTGAGE FORECLOSURE Term No. 04 1706 CIVIL 257 Southside Drive aJk/a Lot lOA Southside Drive Newville, PA 17241 Defendant( s) CERTIFICATE OF SERVICE. PURSUANT TO Pa.R.C.P. 3129.2 ~ Joseph A. Goldbeck, Jr., Esquire, Attorney for Plaintiff, hereby certifies that service on the Defendants of the Notice of Sheriff Sale was made by: ~ Personal Service by the Sheriffs Office/eem.t>",t\.ltl ..dtilt (copy of return attached). ( ) Certified mail by Joseph A. Goldbeck, Jr. (original green Postal return receipt attached). ( ) Certified mail by Sheriffs Office. ( ) Ordinary mail by Joseph A. Goldbeck, Jr., Esquire to Attorney for Defendant(s) of record (proof of mailing attached). ( ) Acknowledgment of Sheriffs Sale by Attorney for Defendant(s) (proof of acknowledgment attached). ( ) Ordinary mail by Sheriffs Office to Attorney for Defend.ant(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 Joseph A. Goldbeck, Jr. (original receipt(s) for Certified Mail attached). Pursuant to the Affidavit under Rule 3129 (copy attached), service on all lienholders (if any) has been made by ordinary mail by Joseph A. Goldbeck, Jr., Esquire (copies of proofs of mailing attached). The undersigned understands that the statements herein are subject to the penalties provided by 1 Section 4904. 11.bO 3'tl1 CW46 3626 03&& TO: HENRY, MICHAEL A. MICHAEL A. HENRY 257 Southside Drive aJkJa Lot 10 A Soutbside Drive Newville, P A 17241 SENDER: GOLDBECK MCCAFFERTY & MCKEEVER June 11, 2004 REFERENCE: HENRY, MICHAEL A.I MT-0277 12/08/04 - Cumberland PS Form 3800 June 2000 RETURN Postage RECEIPT Certified Fee SERVICE Return Receipt Fee Restricted Delivery Total Postage & Fees -. , ~~. US Postal Service PO'&~MARK'QR'~~E Receipt for \ .~, .~ Certified Mail ." :;,. .' No Insurance Coverage Provided Do Not Use for International Mail ~_ _____.w ._____.__ _ .__________ ~__ -.------- ---------.--------.-.----._- AFFIX POSTAGE TO MAIL PIECE TO COVER FIRST ClASS POSTAGE, CERTIFIED FEE, RETURN RECEIPT FEE AND CHARGES FOR ANY SELECTED OPTIONAL SERVICES. 1. Detach the form 3811, Domestic return receipt by tear- ing left to nght across perf. Attach to mall piece by peeling back the adhesive strips and affiXing to front of mailpiece if space permits Otherwise affix to back of mailplece. 2. If you do not want the receipt postmarked, stick the article # label to the right of the return address, date receipt and retain the receipt. 3. If you want this receipt postmarked, slip the 3800 receipt between the return receipt, and the mallpiece, and slide the edge of the receipt to the gummed edge of adhesive. This will hold the receipt in place to present to your mallcenter, or post office service window. (SEE IllUSTRATION) , H1 ....1 ,.. ... .......~ol.JM,.....1llIo..I DnldO DQI LI,IISlgmlntlh'klllnglbull" WI1IPOUIlSOlIIl,onl,lnc 1581Sollth,.'..,onRdSuIlI1l0 hUbrool,C"'t2028-4112 - Ycu Ann NMle ,n MM1.... .'254 QIy, 81m. 12346 1.lIf o ...---...... D.vid o. 0011 Lega' Segment Narketlng Manager Welz Poetal SoluUon., Inc. 1588 South Minion Rd. 81.111.110 Fallbrook. CA 92028-4112 4. Enter fees for the services requested in the appropriate spaces on the front of this receipt. 5. Save this receipt and present it if you make an inquiry. ....~.~......r~~.i~.T~~...... . ......~. 'H1"ln~rrr""HIr'fIlIlfIllI1iIlUlI UI1H1111 r 1['1 ~ \ 0' ~ --.\ .-l .~ r 0\ 4>- CJ.) IV ...... i (1) -' ...... (0 <Xl ~ (J) tf;\ ...... ...... ...... ...... 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", 'T1 \.1 , } . lIlli, :~, t,' :-c I ,{ ~ tn :~'-: ';~: Ihlla ,- ~:"O : '0 ~;....) , ',; rn 'j '. ~~ JU'. r ~I ,- 'J-.! ~ ''"~ <C1C) idffl .~ ..): ~::~ c) 111_1 I " I I 4 I dlll~ I I cg i w ~ ! ... m ~~S:8 ---!!oS 5"3;0 Q.j>>::So::J -~-1:!3 ::7'~[O . CA (1) ....... ~~ 3: ~ s:a 5. ()~ - (1) to ::l - () ~ <1l - Q ~ ~Ro i~S: nr ~ ooof{ -;oml1- ~:~-< ~ ii';1 '0 ~!:: ~ .. - " 3 ~ 000 i t) ~ '" '" " :i'~ n 0 -0 (, ~ .. " .-. ~ :.g ') ~ ~ ~. :1 .. '" ~. ... ) ~~ q." ~l ~. ..~ ~ "" -' ,', ../i )" ~:: ~ to t~J ~~ : · i '2,;;} 3:: '!!!,~ 5'': ~~ M & T Mortgage Corporation VS Michael A. Henry In The Court of Common Pleas of Cumberland County, Pennsylvania Writ No. 2004-1706 Civil Term Jason Vioral, Deputy Sheriff, who being duly sworn. according to law, states that on September 08,2004 at 7:28 o'clock PM, he served a trll(: copy of the within Real Estate Writ, Notice of Sheriffs Sale and Description, in the above entitled action, upon the within named defendant, to wit: Michael A. Henry, by making known unto Michael A. Henry, personally, at 257 Southside Dr. a!k/a Lot lOA Southside Dr., Newville, Cumberland County, Pennsylvania, its contents and at the same time handing to him personally the said true and correct copy of the same. Richard Smith, Deputy Sheriff, who being duly sworn according to law, states that on October 08,2004 at 1:51 o'clock P.M., he posted a true copy of the within Real Estate Writ, Notice, Poster and Description, in the above entitled action, upon the property of Michael A. Henry located at 257 Southside Drive, a!k/a Lot lOA Southside Drive, Newville, 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: Michael A. Henry, by regular mail to his last known address of 257 Southside Dr. a/k/a Lot lOA Southside Drive, Newville, PA 17241. This letter was mailed under the date of October 06, 2004 and never returned to the Sheriffs Office. Sworn and subscribed to before me ?rJllllfs: .~A ~ ~~~ This _ day of Prothonotary R. Thomas Kline, Sheriff BY00c1 ~ Real Estate eputy 2004, A.D. GOLDBECK McCAFFERTY & McKEEVER BY: Joseph A. Goldbeck, JI. Attorney I.D.#16132 Suite 5000 - Mellon Independence Center 701 Market Street Philadelphia, P A 19106 215-627-1322 Attorney for Plaintiff M&T MORTGAGE CORPORATION PO Box 840 Buffalo, NY 14240-0840 IN TIlE COURT OF COMMON PLEAS of Cumberland County Plaintiff vs. CNIL ACTION - LAW MICHAEL A. HENRY Mortgagor(s) and Record Owner(s) ACTION OF MORTGAGE FORECLOSURE 257 Southside Drive a/kIa Lot 10 A Southside Drive Newville, P A 17241 Term No. 04 1706 CNIL Defendant(s) AFFIDAVIT PURSUANT TO RULE 3129 M&T MORTGAGE CORPORATION, Plaintiff in the above action, by its attorney, JosephA. Goldbeck, Jr., Esquire, sets forth as of the date the praecipe for the writ of execution was filed Ithe following information concerning the real property located at: 257 Southside Drive a/k/a Lot 10 A Southside Drive Newville, P A 17241 l.Name and address ofOwner(s) or Reputed Owner(s): MICHAEL A. HENRY 257 Southside Drive a/k/a Lot 10 A Southside Drive Newville, PA 17241 2. Name and address ofDefendant(s) in the judgment: MICHAEL A. HENRY 257 Southside Drive a/k/a Lot lOA Southside Drive Newville, PA 17241 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 P.O. Box 2675 Harrisburg, P A 17105-2675 4. Name and address of the last recorded holder of every mortgage of record: 5. Name and address of every other person who has any record interest in or record lien on the property and whose interest may be affected by the sale: 6. Name and address of every other person of whom the plaintiff has knowledge who has any record interest in the property which may be affected by the sale. 7. Name and address of every other person of whom the plaintiff has knowledge who has any interest in the property which may be affected by the sale. TENANTS/OCCUPANTS 257 Southside Drive a/k/a Lot 10 A Southside Drive Newville, PA 17241 (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. e.S. Section 4904 relating to unsworn falsification to authorities. DATED: November 2,2004 n r-v C c::.:> 0 t...? . . ..J::"" " L~; 7 :-I fl C) _1:: --r J , -..:: rn-J " r-' () I ~Bm \,"-, ~- n6 ::;)C ( '""T') -r ~>. ~,~,'~~ :Ji: (5 :D :_:~o .:.::-~ N (3m ___-l J;! -< .z:;- :~:J 0 ..< M & T Mortgage Corporation VS Michael A. Henry In The Court of Common Pleas of Cumberland County, Pennsylvania Writ No. 2004-1706 Civil Tenn Jason Vioral, Deputy Sheriff, who being duly sworn according to law, states that on September 08,2004 at 7:28 o'clock PM, he served a true copy ofthe within Real Estate Writ, Notice of Sheriffs Sale and Description, in the above entitled action, upon the within named defendant, to wit: Michael A. Henry, by making known unto Michael A. Henry, personally, at 257 Southside Dr. aJk!a Lot lOA Southside Dr., Newville, Cumberland County, Pennsylvania, its contents and at the same time handing to him personally the said true and correct copy ofthe same. Richard Smith, Deputy Sheriff, who being duly sworn according to law, states that on October 08, 2004 at 1:51 o'clock P.M., he posted a true copy of the within Real Estate Writ, Notice, Poster and Description, in the above entitled action, upon the property of Michael A. Henry located at 257 Southside Drive, aJk!a Lot lOA Southside Drive, Newville, 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: Michael A. Henry, by regular mail to his last known address of257 Southside Dr. aJk!a Lot lOA Southside Drive, Newville, P A 17241. This letter was mailed under the date of October 06, 2004 and never returned to the Sheriff's Office. R. Thomas Kline, Sheriff, who being duly sworn according to law, states that he returns the within writ as STAYED per instructions from Attorney Joseph Goldbeck. Sheriff's Costs: Docketing Poundage Advertising Posting Bills Law Library Prothonotary Mileage Levy Surcharge 30.00 12.77 15.00 15.00 .50 1.00 17.76 15.00 20.00 Law Journal Patriot News Share of Bills 242.15 251.74 30.42 $651.34 Sworn and subscribed to before me This : 'i "" day of Uu.e~ 2004, A.D. \~"'JJ.l' (), fUd~L1.J pr honotary ~ So Answers: /~#-14 R. Thomas Kline, Sheriff BY doc Real Estat \.' ':..n..l(.I~ , ~ !~1'3jJ . " Goldbeck McCafferty & McKeever BY: Joseph A. Goldbeck, Jr. AttDmey I.D. #16132 Suite 500 - The Bourse Bldg. III S. Independence Mall East Philadelphia, P A 19106 215-627-1322 AttDmey for PlaintitT M&T MORTGAGE CORPORATION PO Box 840 Buffalo, NY 14240-0840 IN THE COURT OF COMMON PEAS Plaintiff of Cumberland CDunty vs. MICHAEL A. HENRY (Mortgagor(s) and Record Owner(s)) 257 Southside Drive alkla Lot lOA Southside Drive Newville, PA 17241 CIVIL ACTION - LAW ACTION OF MORTGAGE FOREC OSURE Defendant( s) No. 04 1706 CIVIL AFFIDAVIT PURSUANT TO RULE 3129 M&T MORTGAGE CORPORATION. Plaintiff in the above action, by its attorney, Joseph A. Goldbe ,Jr., Esquire, sets forth as of the date the praecipe for the writ of execution was filed the following information conce ing the real property located at: 257 Southside Drive a1kJa Lot lOA Souths ide Drive Newville, PA 17241 l.Name and address ofOwner(s) or Reputed Owner(s): MICHAEL A. HENRY 257 Southside Drive a1kJa Lot 10 A Southside Drive Newville, PA 17241 2. Name and address of Defendant(s) in the judgment: MICHAEL A HENRY 257 Southside Drive a/kJa Lot 10 A Southside Drive Newville, PA 17241 3. Name and last known address of every judgment creditor whose judgment is a record lien on the property t be sold: DOMESTIC RELATIONS OF CUMBERLAND COUNTY PO Box 320 Carlisle, P A 17013 P A DEPARTMENT OF PUBLIC WELFARE - Bureau of Child Support Enforce ent Health and Welfare Bldg. - Room 432 P.O. Box 2675 Harrisburg, PA 17105-2675 4. Name and address of the last recorded holder of every mortgage of record: - , *'. , 5. Name and address of every other person who has any record interest in or record lien on the property and whose i terest 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 roperty which may be affected by the sale. 7. Name and address of every other person of whom the plaintiff has knowledge who has any interest in the prope which may be affected by the sale. TENANTS/OCCUP ANTS 257 Southside Drive aikla Lot 10 A Southside Drive Newville, PA 17241 (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 knowled information and belief. I understand that false statements herein are made subject to the penalties of 18 Pa. C.S. S relating to unsworn falsification to authorities. or tion 4904 DATED: June 11, 2004 04 1706 CIVI GOLDBECK McCAFFERTY & McKEEVER BY: Ioseph A. Goldbeck, Ir. Attorney I.D.#16132 Suite 5000- Mellon Independence Center 701 Market Sll'eet Philadelphia, P A 19106 215-627-1322 Attorney for Plaintiff M&T MORTGAGE CORPORATION PO Box 840 Buffalo, NY 14240-0840 IN THE COURT OF COMMON PLE of Cumberland County Plaintiff vs. CIVIL ACTION - LAW MICHAEL A. HENRY Mortgagor(s) and Record Owner(s) ACTION OF MORTGAGE FORECLOSURE 257 Southside Drive alkla Lot 10 A Southside Drive Newville,PA 17241 Teml No. 04 1706 CIVIL Defendant( s THIS LAW FIRM IS A DEBT COLLECTOR AND WE ARE ATTEMPTING TO COLLECT A DEBT. THIS NOTICE IS SENT TO YOU IN AN ATTEMPT TO COLLECT A DEBT. ANY INFORMATION OBTAINED FROM YOU WILL BE USED FOR THAT PURPOSE. NOTICE OF SHERIFF'S SALE OF REAL PROPERTY TO: HENRY, MICHAEL A. MICHAEL A. HENRY 257 Southside Drive alkla Lot 10 A Southside Drive Newville, P A 17241 Your house at 257 Southside Drive alkla Lot 10 A Southside Drive, Newville, PA 17241 s scheduled to be sold at Sheriff's Sale on Wednesday, December 08,2004, at 10:00 AM, in Commi sioners Hearing Rm 2nd FL Courthouse to enforce the court judgment of$131,841.61 obtained by M&T MORTGAGE CORPORATION 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 M&T MORTGAGE CORPORATION, the bac payments, late charges, costs and reasonable attorney's fees due. To tind out how much you mus pay call: 215-627-1322 2. You may be able to stop the sale by filing a petition asking the Court to strike or open dgment, if the judgment was improperly entered. You may also ask the Court to postpone the sale for goo cause. SHORT DESCRIPTION IMPROVEMENTS consist of a residential dwelling. BEING PREMISES; 257 Southside Drive a/k/a Lot 10 A Southside Drive Newville, PA 17241 SOLD as the property of MICHAEL A. HENRY TAX PARCEL #3l-13-0ll2-010A WRIT OF EXECUTION and/or ATTACHMENT COMMONWEALTH OF PENNSYL VANIA) COUNTY OF CUMBERLAND) TO THE SHERIFF OF CUMBERLAND COUNTY: To satisfy the debt, interest and costs due M & T MORTGAGE CORPORATION, Plaintiff (,) NO 04-1706 Civil CIVIL ACTION - LAW From MICHAEL A. HENRY (1) You are directed to levy upon the property of the defendant (,)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 defendan (s) or otherwise disposing thereof; (3) Ifproperty of the defendant(s) not levied upon an subject to attachment is found in the possession of anyone other than a named garnishee, you are directed to notify himlher that he/she has been added as a garnishee and is enjoined as above stated. Amount Due $131,841.61 L.L. $.50 Interest FROM 11/1/03 TO 6/11/04 AT 8.1250% Atty's Comm % Atty Paid $118.28 Plaintiff Paid Date: JUNE 15, 2004 Due Prothy $1.00 Other Costs CURTIS R. LONG (Seal) B: Deputy REQUESTING PARTY: Name JOSEPH A. GOLDBECK, JR., ESQillRE Address: SillTE 500 - THE BOURSE BLDG. 111 S. INDEPENDENCE MALL EAST PHILADELPHIA, PA 19106 Attorney for: PLAINTIFF Telephone: 215-627-1322 Supreme Court ill No. 16132 Real Estate Sale #2 I On August 27,2004 the SheriffIevied upon the defendant's interest in the real property situated in Penn Township, Cumberland County, P A Known and numbered as 257 Southside Dr. a!kJa Lot 10 A Southside Dr., Newville, more fully described on Exhibit "A" filed with this writ and by this reference incorporated herein. Date: August 27,2004 By: Jt of j / jvu.iU; Real Est~ Deputy e evil evil c:;:l @ liVil YU;'/',:,' HJd 110, 'Pi DE 01 91 NOr Alhilvv ~::'j,' :~._ .Jrln~ ;Jr~'~ . ",J REAL ESTATE SALE No. 21 Writ No. 2004-1706 CMITeon M &T_"'Ortga~:CorpOratlon MlCh.el A. Henry AUy: Joseph .Goldtieck oesCRlPTION ALL.THAr CERTAINillllCt of land situate in _Pel)ll-Township, Cumberland. Coonly, PeIlnsylvam., bounded and described in accotdanl:e wilh a survey by Dean A. Smith, n. registeredslll've)'or,daIed Septen1ber4, 1996, a i oopyofwbidt.is atllIChed to deedreconied at i Combeda1ld County J)eed Book 14ll,Page 164, as fulhlws:. ,.:- .'.... .. . BEGINNINGs, an inm pin at comer of lands now . or f01ltJedy of Barlwa E. Woods and f01ltJedy . of AIbelI !lmzIer; 1hence along the Iand$ ,now orJotmedy of Barlwa E. Woods, .South30 degtees31 mjnotes 56.4ll seconds West, .890.25 feet to aninmpin in the line of lands now ; prformerlyof JoIn\ Thomma; thence along the lands now or.furmerly of John Thumma. North 18 dejpees 55 minotes 7.55 seconds West, lIIO.41 -feel ,to an iron pin in the line of land$now or fonnerly of O.c. Tritt; thence mong the lands now or formerly of O.C.Tritt; North 28 degrees 41 . minu1:os 1.55.eoonds Eas~ 8'!f).l7 feel to an iron .pin in the.line of laJlds now or formerly of G. Leroy .JoneS and DoroIhy B. Jones and fonnerly ofW~ Brandts; thence along the lands now or formerly of G.Leroy Jones andDorotby B. Jones, _ South 39 degrees 4ll minutes 12.74 seconds. 1137 .61 feet to an inm pin at the place of BEGJNNJNG. CONTAJNlNG 21.416 acres more or less, ' known as and nwnbered 257 Sootbside Drive, Newville, Pennsylvania 17241. . "~. REAL ESTATE SALE NO. 21 Writ No. 2004-1706 Civil M & T Mortgage Corporation vs. Michael A. Henry Atty.: Joseph Goldbeck ALL THAT CERTAIN tract of land situate in Penn Township. Cumber- land County, Pennsylvania, bounded and described in accordance wlth a survey by Dean A. Smlth, II, regis- tered surveyor dated September 4, 1996, a CDPy of which is attached to deed recorded at Cumberland County Deed BDDk 148, Page 164, as follows: BEGINNING at an iron pin at comer of lands now or formerly of Barbara E. Woods and formerly of Albert Hertzler: thence along the lands now or formerly of Barbara E. Woods. South 30 degrees 33 mln- utes 56.48 seconds West, 890.25 feet tD an iron pin in the line oflands now or formerly of John Thumma: thence along the lands now or for- merly of John Thumma, North 38 degrees 55 mlnutes 7.55 seconds West, 1110.41 feet to an iron pin in the line of lands now or formerly of O.C. Tritt: thence along the lands now or formerly of O.C. Tritt, North 28 degrees 41 minutes 3.55 seconds East, 890.17 feet to an iron pin in the line Df lands now or formerly G. Leroy Jones and Dorothy B. Jones and formerly of William Brandts: thence along the lands now or for- merly of G. Leroy Jones and Dor- othy B. Jones, South 39 degrees 48 minutes 32.74 seconds, 1137- .63 feet to an iron pin at the place of BEGINNING. CONTAINING 21.416 acres mDre or less, known as and numbered 257 Southside Drive, Newville, Pennsyl- vania 17241. . ~ I IGOLDBECK McCAFFERTY & McKEEVER IBY: Joseph A. Goldbeck, Jr. IAttorney I.D. #16132 Suite 5000 Mellon Independence Center 701 Market Street Philadelphia, PA 19106-1532 215-627-1322 Attorney for Plaintiff I IM&T MORTGAGE CORPORATION PO Box 840 'Buffalo, NY 14240-0840 IN THE COURT OF COMMON PLEAS Plaintiff of Cumberland County VS. IMICHAEL A. HENRY iIMortgagor(s) and Record owner(s)) 257 Soulhside Drive a/kla Lol10 A Southside Drive Newville, PA 17241 No. 04 1706 CIVIL PRAECIPE TO SETTLE, DISCONTINUE AND END o THE PROTHONOTARY: Kindly mark the above case Settled, Discontinued and Ended upon ayment of your costs only. jjlIt~ .. JOSEPH A. GOLDBECK, JR., ESQUIRE (.;~ <..--:) ...<'~, .t~.- ,...., ~ ,:::::.') ..J' ->,.~ ,,>,"', -'I~ c:.> "";'\ --~ I (J", OLDBECK McCAFFERTY & McKEEVER Y: Joseph A. Goldbeck, Jr. ttomey 1.0. #16132 uite 5000 - Mellon Independence Center 01 Market Street hiladelphia, PA 19106 . 15-627-1322 Attorney for Plaintiff f.1&T MORTGAGE CORPORATION PO Box 840 l3uffalo, NY 14240-0840 Plaintiff vs. ~ICHAEL A. HENRY IMortgagor(s) and Record owner(sl) 1257 Southside Drive alkla Lot 10 A Southside Drive Newville, PA 17241 IN THE COURT OF COMMON PLEAS of Cumberland County No. 04 1706 CIVIL PRAECIPE TO SATISFY JUDGMENT o THE PROTHONOTARY: Kindly Satisfy the Judgment in the above captioned matter upon ayment of your costs only. !fJIt~ JOSEPH A. GOLDBECK, JR., ESQUIRE ~, ,:;:~ .;::::.';1 <:,..l' (~) -n ~:;:. ':::-.i>~ -.. \ (..f', . , -..-'-' -