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Home My WebLink About04-2115 GOLDBECK McCAFFERTY & McKEEVER By: JOSEPH A. GOLDBECK, JR. ATTORNEYI.D. #16132 SUITE 5000 - MELLON INDEPENDENCE CENTER. 701MA~KETSTREET PHILADELPHIA, PA 19106 (215) 627-1322 ATTORNEY FOR PLAINTIFF IN THE COURT OF COMMON PLEAS CITIFINANCIAL SERVICES INC. 7467 New Ridge Road Suite 222 Hanover, MD 21076 OF Cumberland COUNTY CIVIL ACTION - LAW Plaintiff vs. GWENDOLYN A. SCHOEN Mortgagor(5) and Real Owner(5) ACTION OF MORTGAGE FORECLOSURE Term No. cl./ _~/}.S (l,'uil 1€I2.n1 851 Brian Ave Eno1a, P A 17025 Defendant{s) OIVIL. ACTION: MOPlTGAGE FORt::CLOIUjqE THIS FIRM IS A DEBT COLLECTOR AND WE ARE ATTEMPTINGTO COLLECT A DEBT OWED TO OUR CLIENT. ANY INFORMATION OBTAINED FROM YOU WILL BE USED FOR THE PURPOSE OF COLLECTING THE DEBT. NOTICE You have been sued in court. !fyou wish to defend against the claims set forth in the following pages, you must take action within twenty (20) days after the Complaint and notice are served, by entering a written appearance personally or by attorney and filing in writing with the court your defenses or objections to the claims sel forth against you. You are warned that if you fail to do so the case may proceed without you and a judgment may be entered against you by the Court without further notice for any money claim in the Complaint of for any other claim or relief requested by the Plaintiff. You may lose money or property or other rights important to you. YOU SHOULD TAKE THIS PAPER TO YOUR LAWYER AT ONCE. IF YOU DO NOT HAVE A LAWYER OR CANNOT AFFORD ONE, GO TO OR TELEPHONE THE OFFICE SET FORTH BELOW. THIS OFFICE CAN PROVIDE VOU WITH INFORMATION ABOUT HIRING A LAWYER. IFYOU CANNOT AFFORD TO HIRE A LAWYER, THIS OFFICE MAY BE ABLE TO PROVIDE YOU WITH INFORMATION ABOUT AGENCIES THAT MAY OFFER LEGAL SERVICES TO ELIGIBLE PERSONS AT A REDUCED FEE OR NO FEE. LEGAL SERVICES INC 8 Irvine Row Carlisle, PA 17013 717-243-9400 CUMBERLAND COUNTY BAR ASSOCIATION 2 Liberty Avenue Carlisle, PA 17013 AVISO LE HAN DEMANDADO A USTED EN LA CORTE. SI DESEA DEFENDERSE CONTRA LAS QUFJAS PERESENTADAS, ES ABSOLUTAMENTE NECESSARIO QUE USTED RESPONDA DENTRO DE 20 DIAS DESPUES DE SER SERVIDO CON ESTA DEMANDA Y A VISO. PARA DEFENDERSE ES NECESSARIO QUE USTED, 0 SU ABOGAOO, REG ISTRE CON LA CORTE EN FORMA ESCRITA, EL PUNTa DE VISTA DE USTED V CUALQUIER OBJECCION CONTRA LAS QUEJAS EN ESTA DEMANDA. RECUERDE: SI USTED NO REPONDE A EST A DEMANDA, SE PUEDE PROSEGUlR CON EL PROCESO SIN SU P ARTICIPACION. ENTONCES, LA COUTE PUEOE, SIN NOTIFICARIO, DECIDIR A FAVOR DEL DEMANDANTE Y REQUERIRA QUE USTED CUMPLA CON TOOAS LAS PROVISIONES DE ESTA DEMANDA. POR RAZON DE ESA DECISION, ES POSSIBLE QUE USTED PUEDA PERDER DINERO, PROPIEDAD U OTROS DERECHOS IMPORTANTES. USTED DEBE LLEVAR ESTE PAPEL A SU ABOGADO ENSEGUIDA. 51 USTED NO TIENE UN ABOGADO, VA YA 0 LLAME POR TEL<;FONO LA OFICINA FlJADA AQui ABAJO. ESTA OFICINA PUEDE PROVEERC: CON INFORMACION DE COMO CONSEUIR UN ABOGADO. 51 USTED NO PUEDE PAGARLE A UN ABOGAOO, CSTA OFICINA PUEDE PROVEERE INFORMACION ACERCA AGENCIA5 QUE PUEOAN OFRECER SERVICIOS LEGAL A PERSONAS ELIGIBLE AQ UN HONORARIO REDUCIDQ 0 GRATIS. LEGAL SERVICES lNe 8 Irvine Row Carlisle, PA 17013 717-243-9400 CUMBERLAND COUNTY BAR ASSOCIATION 2 Liberty Avenue Carlisle, PA 17013 COMPLAINT IN MORTGAGE FORECLOSURE 1. Plaintiff is CITIFINANCIAL SERVICES INC., 7467 New Ridge Road, Suite 222 Hanover, MD 21076. 2. The name(s) and addressees) of the Defendant(s) is/are GWENDOLYN A. SCHOEN, 851 Brian Ave, Enola, PA 17025, who is/are the mortgagor(s) and real owner(s) of the mortgaged premises hereinafter described. 3. On August 18, 2000 mortgagor(s) made, executed and delivered a mortgage upon the premises hereinafter described to CITIFINANCIAL SERVICES INC., which mortgage is recorded in the Office of the Recorder of Deeds of Cumberland County as Book 1633 Page 663. The mortgage has not been assigned unless said assigrunent to the Plaintiff is hereafter rnentioned. These documents are rnatters of public record and are incorporated herein by reference in accordance with Permsylvania Rule of Civil Procedure 10 19(9). 4. The premises subject to said mortgage is described as attached. 5. The mortgage is in default because monthly payment of principal and interest upon said mortgage due October 06, 2003, and each month thereafter are due and unpaid, and by the terms of said rnortgage, upon default in such payments for a period of one month, the entire principal balance and all interest due thereon are collectible forthwith. 6. The following amounts are due on the mortgage: Principal Balance Interest from 09/06/2003 through 05/3112004 at 10.5000% Per Diem interest rate at $18.57 Attorney's Fee at 5.0% of Principal Balance Costs of suit and Title Search $64,567.74 $4,995.33 Title/Appraisal Fee $3,228.39 $900.00 $73,691.46 +$225.00 $73,916.46 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 ofa third party purchaser at Sheriff's Sale. If the Mortgage is reinstated prior to the Sale reasonable Attorney's Fees will be charged based on work actually performed. 8. Notice 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 of 1998 of the Cornmonwealth of Pennsylvania, on the date(s) set forth in the true and correct copy of such notice(s) attached hereto as Exhibit "A". The Defendant(s) has/have not had the required face-to-face rneeting within the required tirne and Plaintiff has no knowledge of any such rneeting being requested by the Defendant(s) through the Plaintiff, the Pennsylvania Housing Finance Agency, or any appropriate Consumer Credit Counseling Agency. WHEREFORE, Plaintiff demands an in rem judgment in mortgage foreclosure in the sum of $73,916.46, together with interest at the rate of $18.57, per day and other expenses incurred by the Plaintiff which are properly chargeable in accordance with the terms of the mortgage, and for the foreclosure and sale of the mortgaged premises. By DBE MJJ1t;!Jg~ By: JOSEPH A. GOLDBECK, JR., ESQUIRE ATTORNEY FOR PLAINTIFF VERIFICATION I, Jana Gantt, as the representative of the Plaintiff corporation within named do hereby verifY that I am authorized to and do make this verification on behalf of the Plaintiff corporation and the facts set forth in the foregoing Complaint are true and correct to the best of my knowledge, information and belief. I understand that false statements therein are made subject to the penalties of 18 Pa. C.S. 4904 relating to unsworn falsification to authorities. Date: e;~ 10-tI) ~/_. ~ J antt CI INANCIAL SERVICES INC. II ~ ~ , ;.!! " k f t , . , . ~ j , L ~ r ,. i , t r , i i ~. ~. ~ ! i 1 I I I I' ..,....~. . , =t:t"f~Ii:;.~~~ '~1~__ ~,.), ~. \S'-..... :;Dttb~ ~;.;. .':'i;'~~:~~.di:~ tJbi)l ~ 0 'J.I- MADE THE Mil .f .f....Lo'<l....tItoooaOldm...huitd...d eighty-!!.... (19651. r . . ',' - fl. ~ . JW: 21' :,il In ?9 4'~ itf.tM'IIetJr , BETWEEN G. r.:cx.GAS ~ and. AUORSY' J. PORNE.Y, his wife, 'Qf Enola, East Pennsboro _ip, CCllt>er1and Cowlty. Pennsylvani., portie. of the first port. C~S. au ~YN A. SCtfQOJ, sinqle ~n, ot HochMi~, Pennsylvanu, patty of the se<.\Jf..j part, G1Umc~ ! WlrN&8SI:T1l. that itt COMi4lf'rQticm 01 FOlfI'Y..FtXJR 'l1DJSNtV !-,,,VE IJUN:IRFD and 0(1/100--- ----------($44,500.001-. nou..r.. u. h4lOd",.u, IA. ~..";,,I "'Mr..fl< Mrebll ~/cdQI/d, I" MIid _. do h....bl/ grtU>l czM eon"ev to tAt MUd I"Ufttee .' . AU.. THA'l' cmI'AlN unit in the p~rty k:J'lc';1..ln, named nnd 'idontifiOO in ~ .Dccl..'r~tion PlM. referred to ~ow a. ....b.<x>Cl Village Condanini.... locatcll in IlMt 1'c",,-.., TOwnship, Ct.i'nberland COLtnty. Pennsylvania, whiCh has hci:'ctcfora been B~ttCld to tho prQU'isicns of the l.'nit: Proparty J\ct ot. l'-'enrisylVanu, /\ct of July 3, 19~3, P.I,. 196, by tho =rdi"'1 in tho CUi... of the Iloco<dor of Oc!cd. oC C\ltlx>rland COOnty. Pennsylvana. of a ~lanltion Croooti"'1 and ll5""bUahing Wcsb.<x>Cl Villnq<> C<.>ndanini.... dated Janl,1Ory 29, 1975, and recorded on January 29, 1975~ in Misc. Dock 213, fIDqo 283, and 8IIllOndod by a certain First ~ to Declaration c:rooti"'1 noo Ilst.,bli.hin<;/ lOasb.<x>Cl Villa9" ConOcmini... dated May 26. 1976. and rCC'Onhd on June.22. 1976, in Misc. Dook 222, page 729, ancl a certain ~ ~t to DcC'l.1.l'ation Crelltin;, ;1M Establishing W<>stWOO<l VHln9" Condanini... dotcx1 July 21. 1976. ~nd rtlCOt'd<<\ on July 26. 1976. in Misc. !lOok 223. Page 343. and . cortain 'ltIirCl _t to Dcelnrntion crooting and Establishing WastWOO<l Vill~9" ConCbnlni... d.,t<XI June 9. 1976, ~oo ro- cordoCJ on JUo.c 23, 197d, in Misc. Dook 236, Ptlgo 22$, one) Q certain Fourth Iw..-rdtcnt .~to Declar~tion =tin<;/ ~nd Eotllblishi"'1 WCst\o<lOd Villago Ccinclorrinium d.,tcx1 June 13, fo' .1978, and J:ecordcd on June 23, 1978, in Mise.. Dock 236, .PD90. 250, ~nd 0 ccrwin Firth . _t to Declaration c:reotinq ~nc1 Eotabli""i"'1 WOStWOO<l Village Condomini... dat<XI JAr1\.ln1'y 9, 1979 and recorded on January 23, 1070, in MilK:. Doc:rk 240, PoJ.qr! 884, and a ""ruin sixth lll!endlrent to """laration croati"'1 and Establishing Wosb.<x>Cl Vill_ Condan:i.nium dated March 1, 1979, ariI recorded Much 12, 1979, in Mise. Dook 241, pa:ge 836, and. a Code of ~tions of t'ICMewoocJ Villa.ge Cen1anitlium dftted JMuary. 29, 1975, and recorded on January 29, 1975, in Misc. Book 213, PiJgc! 328, and ~ by a. certwin Fu-se _e to Cv:Ja of Rogullltir.n.i of ~twoc:d ViJ.18gra CondominiuII1 ~ . dated ~y 28, 1916, and recorded on JUM: 22, 1976, in Hisc,.Dook 222, paqc 737, and Ceclaration Plan of.westwood Vill_ O:>n<Iar.ini..... dated January 29, 1375. .nd =rdod QnJanuary 29. 1975 in Plan !lOok 26, Pa9" '15. and amencle<I by . =In First /IIrcnd- ment to Declaration Plan of West\oIOO/l Villayc ~\I1l d<lte<I July 21. 197'6. and tv- oordod on July ~6. 1976. in Plan !look 28. I'a9> 72. and .rnendod by a certain _ ~f1Illk:ul to ~lan.tion Plan of WsstwQod. VillA9fo~ Condardnium d4ted .'LItIe 16, 1978, and. ~ on June 23. 1979, in Plan 8:::lok 33, Pa9'CiJ 28, and ~ by a cortlli" "'in! l\mendnont to Ceclaration Plan of Wcsowoocl Village Coo1anini\.Ul1'dat<XI J!lnOO<Y 9. 1979, ant;! reeorded ,Jan~ 23, 1979, in Plan Soak 34, Pa9t!!! 100, ahd. ~ by Do . certain Fourth _ent to l>>claration Plan of __ Village condc:minil.llll dot<'" March 1. 197~. And recorde:l March 12. 1979. in PlM !look 35. P_ 3,. beinq t1eIIigMted on said _l.ration Plan of _twood Villaga ComQniniUl1l a. unit No. 651, SUite 123. L23'F2 in 910ck '5. &.1ilding ..9. 1<nc:IIo'n as 851 Brian Dri"", SUite 123. 1'>>o1a, C\.II'I:ler1and COUnty, Pemaylvani.. .. IlDre fully described in SIlCh Ileclaration Plan and l>>claration c:r-ting- .00 Establishin<;/ -.:wood Villa". Condanin.i\l1l. as tho ...,.. ~. of recorIl 800~31 PACE 106 (') :-~:- .') 'i ( " -r'.............. r--..: it' .' "-.... ~ ",5 set forth aboVe, including any ar,enC_ne:lits thereto, ~ with II prq:crt1or.ate undivided interest in the O:mn:>n El_nts (as clef1ned in such Dec:laraticn) ot _ lIuodrcd SOWnty-t>o 1hou~t"" Per<>!nt 1.772'). llElW part of the same prani."" wI1ich1l1e ""'.tport CmpanY. fonnarly _ lIS HIC M:)rt9~ and. P-c;a.l:ty Investors f a. Massachuset.ts bU9iness trust, by cleeCI datlid April 11, 1979, and """",rd<;d in the OUi"" of the. Recorder o~ Deeds in and for C>.m>erland COUnty, ~lvan1.a, in ~rd Book f Pagq f qrantQd and cxxweyed Unto G. [):JuqlD8 Fornoy, s1nqle nel'l.. Audrey J. ~ joins in this conveyance for the purpo8O of gronting and """""Ying any and all intenst which she hIul in the 1''''''''1108 by boinq tho wife of G. COUqlas f\mlOy. tJtI)l~ /'oW SlJDJEC't to ~clltrictions of record. 'U::lmll~ with all and sinqlililr the lDp...""..,.."ts. St:reets. AlllljlS. PaB.SGqes, ways. w.~tt:(!i, Wator-COUr:scli, Riq:hts, L1.bertioe, PrlvilGge6' HereditarrWint:B and ~, what"""",,r therct.lnto belClO9inq. or in Qny wi... apportalnin!l. and the Reversions and l-lUtUinc.1ara, Rents, Issl.l.eS and ~tj.t!ll t.hlu'eol; .md all the estate, r.tqht. title interest, pt'O(JI!!rty, clD.im and: daMod \lohat.~, of it, ~ saia Grantor, in law, equit.y, or ~tw1SG:, howsoever, of," in. and to the S!:lme and evwy plrt therI!of. \ I I I \ j 'nil!: Crl1ntco, by D.at:.'loptWlce of thi. deed, for ~ on bmalf of the Granble and Grantee's 1 (Iui.rfl, ~rBOrQl ~"Pt'C!fiIQntQ.ti\'e;. SUC<::GS8Ot's and. ^"1.gNI;, CX'.M::natltS and aqreea to pay such churq<.... for the maintef1anc\'> of repsi.. to. rep1a~ of and ~_ in I oo"nootion Iori.th tM CQmDn 1ll""""1:S as ....y be .._sed from time to t_ by the CCoI1cil , in .."""<<hn",, with tho> tmit l'roperty I\C1: of """",,ylwnia, and further covenants and I ng= t~,t the Unit ocn~ by this Oeod shall be.subject. to a __ fer all .lUlounts SO ~s5CS.cd and that, exce..opt insofar as Sections 105 and 1015 of Said Unit , Property I'ct ...y "'lieve a S1JbSeqI1Ont tJnit o.ner of liability for pri<< UllpOid asses-- I ""'flts, this """""""t shall run with and bind the land or tJnit h&rel>y ~ and all suooQCJUGnt OWM(!rS thcot"eof. I FW the said Grantor, fex' thensel"Ve$ and their St'CO"'u"'rs, do by these presents, ~nt, qrant, and aq.rce, to W1d -with tho said Grantee, .her Heirs and As"i9M, that they, the ...id Grantors, .and their SUCt'es5ors. all and 8inqular the lleroditalMn1:s and Premises heroin above cl<Iscrtbed and qrante:l or ..."tiom:! anr:i interded so to be. with thli' 1\ppurtl.."Oc'U'lCL"S, 1Jnto the uid GrMtee, her Heirs and Ass.i9!1S, .against therr:, the SH!U Ornnl:.ors and their S~~r:s. and. ~in&t. .Q.ll Bt1d reve.r;y othar l\!t'son or ,.' I\)r!tOfUl whc:mI-Joovt.'t' 1.1Wfull y claiming or to claim the t:amo or <My Part thcroof,. tJy,. ..-/' fran. or UrP..'t" it, them or AnY of than IIl1ell and will. St.l'8nX:T, as af~id, Wl\BMNt' ana tOt'"f.."V'Cr OU~. ,,, IlhW /lNJ 'ro IIOW tho ""i<l al:x>vc-deocrJbcd tJnit and the _itamontJo and Pr.",,;,ses hurcby qr~ntQd, Qr rMnHoned and int.c!lnded alO to bP., with the ~nce., unto the ...l<.l Gran_. his Heirs and ^"siqns, to and for the <'f1l.y ~ .. and hehocf of the ~id Granteo, his Heirs and' Assiqns forever. lWI:'ll fINl) SU1lJfX.'T as aforesaid. I ',iM/."\', !wt-l.UII or. "r.NN.:.~1V1Ir..;J^ ::: ~~ :~~,':~..~r.~~~:~~ ~~S~EE- .. I'~ . "" t~~'-'''''ll . ;~:2'~.IU .l'W~I'f5 ~~~7!1 ~_ ~ 5.. n n~ ~~ I: "l /r...(J'~L \_.,..,.r .................... Cum~. c..:,., ,.. . IJL I..S ....... Tn...... r.. ;:.. - ""'J.' r, .>- ("~ ~:>-':)'l.. ~~.......>................ ~~':'-...'" ,/..- ~ _.. Co. ..... col. .... ~ , I ) , &000=31 PACE. 107 J: ~~l /-r""~.JJ..,..':_ _U~_ . klloot Oid. e"",t,. Co.. ..' -t," aut ....1. Tr."."" t.., \"'1) ~ , ..~.; ~).,",...,)...- .... ::.:.r..~...%.y~co- ~'l/.......-~ 'ellMlt. <=- PIt_, Ceo" AlA .~ . l '. _.._....,.".. .' ....w~.__._... ..._...'~. ~.,......._____.......-.--....__..__ EXHIBIT ~CT 91 NOTICE DATE OF NOTICE: April 6, 2004 TAKE ACTION TO SAVE YOUR HOME FROM FORECLOSURE 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. This is an official notice that the rnortgage on your horne is in default, and the lender intends to foreclose. Specific information about the nature of the default is provided in the attached pa!l:es. The HOMEOWNER'S MORTGAGE ASSISTANCE PROGRAM (HEMAP) rnay be able to help to save your horne. This Notice explains how the prograrn works. To see if HEMAP can help, yoU must MEET WITH A CONSUMER CREDIT COUNSELING AGENCY WITHIN 30 DAYS OF THE DATE OF THIS NOTICE. Take this Notice with YOU when you meet with the Counseling Agency. The name, address and phone number of Consumer Credit Counseling Agencies serving your County are listed at the end of this Notice. If you have any questions, you rnay call the Pennsylvania Housing Finance Agency toll free at 1-800-342-2397. (Persons with impaired hearing can call (717) 780-1869.) This Notice contains important legal information. If you have any questions, representatives at the Consurner Credit Counseling Agency may be able to help explain it. You rnay also want to contact any attorney in your area. The local bar association rnay be able to help you find a lawyer. La notificacion en adjunto es de suma importancia, pues afecta su derecho a continuar viviendo en su casa. Si no cornprende el contenido de esta notification obtenga una traduccion imrnediatamente llarnanda esta agencia (Pennsylvania Housing Finance Agency) sin cargos al numero mencionada arriba. Puedes ser elegible para un prestamo por el programa llarnado "Homeowner's Ernergency Mortgage Assistance Program" el cual puede salvar su casa de la perdida del derecho a redimir su hipoteca. Prepared by: GOLDBECK McCAFFERTY & McKEEVER Suite 5000 - Mellon Independence Center. 701 Market Street Philadelphia, PA 19106 Fax (215) 627-7734 . U. '-.nlltll..~III1II"l;j. ~,.u U:l:'__U ?1bO 3901 9&4& 40b? 0054 . . , 1 Date: April 6, 2004 Homeowners Name: GWENDOLYN A. SCHOEN Property Address: 851 Brian Ave, Eno1a, PA 17025 Loan Account No.: 2000510215530 Original Lender: CITIFINANCIAL SERVICES INC. Current LenderlServicer: CITIFINANCIAL SERVICES INC. HOMEOWNERS' EMERGENCY MORTGAGE ASSISTANCE PROGRAM YOU MAY BE ELIGIBLE FOR FINANCIAL ASSISTANCE WHICH CAN SAVE YOUR HOME FROM FORECLOSURE AND HELP YOU MAKE FUTURE MORTGAGE PAYMENTS IF YOU COMPLY WITH THE PROVISIONS OF THE HOMEOWNER'S EMERGENCY MORTGAGE ASSISTANCE ACT OF 1983 (THE "ACT"), YOU MAY BE ELIGIBLE FOR EMERGENCY MORTGAGE ASSISTANCE: * IF YOUR DEFAULT HAS BEEN CAUSED BY CIRCUMSTANCES BEYOND YOUR CONTROL, * IF YOU HAVE A REASONABLE PROSPECT OF BEING ABLE TO PAY YOUR MORTGAGE PAYMENTS, AND * IF YOU MEET OTHER ELIGIBILITY REQUIREMENTS ESTABLISHED BY THE PENNSYLVANIA HOUSING FINANCE AGENCY. TEMPORARY STAY OF FORECLOSURE - Under the Act, you are entitled to a temporary stay of foreclosure on your mortgage for thirty (30) days from the date of this Notice. During that time you must arrange and attend a "face-to-face" meeting with one of the designated consurner credit counseling agencies listed at the end of this Notice. THIS MEETING MUST OCCUR WITHIN THE NEXT (30) DAYS. IF YOU DO NOT APPLY FOR EMERGENCY MORTGAGE ASSISTANCE, YOU MUST BRING YOUR MORTGAGE UP TO DATE. THE PART OF THIS NOTICE CALLED "HOW TO CURE YOUR MORTGAGE DEFAULT", EXPLAINS HOW TO BRING YOUR MORTGAGE UP TO DATE. CONSUMER CREDIT COUNSELING AGENCIES - If you meet with one of the consumer credit counseling agencies listed at the end of this notice, the lender may NOT take action against you for thirty (30) days after the date ofthis meeting. The names. addresses and telephone numbers of designated consumer credit counseling agencies for the county in which the property is located are set 2 forth lit the end of this Notice. It is only necessary to schedule one face-to-face meeting. Advise your lender irnmediatelv of your intentions. APPLICATION FOR MORTGAGE ASSISTANCE - Your mortgage is in default for the reasons set forth later in this Notice (see following pages for specific information about the nature of your default.) If you have tried and are unable to resolve this problern with the lender, you have the right to apply for financial assistance from the Homeowner's Emergency Mortgage Assistance Program. To do so, you must fill out, sign and file a completed Homeowner's Ernergency Assistance Program Application with one of the designated consumer credit counseling agencies listed at the end of this Notice. Only consumer credit counseling agencies have applications for the program and they will assist you in submitting a complete application to the Pennsylvania Housing Finance Agency. Your application MUST be filed or postmarked within thirty (30) days of your fact-to-face meeting. YOU MUST FILE YOUR APPLICATION PROMPTLY. IF YOU FAIL TO DO SO OR IF YOU DO NOT FOLLOW THE OTHER TIME PERIODS SET FORTH IN THIS LETTER, FORECLOSURE MAY PROCEED AGAINST YOUR HOME IMMEDIATELY AND YOUR APPLICATION FOR MORTGAGE ASSISTANCE WILL BE DENIED. AGENCY ACTION - Available funds for emergency mortgage assistance are very limited. They will be disbursed by the Agency under the eligibility criteria established by the Act. The Pennsylvania Housing Finance Agency has sixty (60) days to make a decision after it receives your application. During that tirne, no foreclosure proceedings will be pursued against you if you have met the time requirements set forth above. You will be notified directly by the Pennsylvania Housing Finance Agency of its decision on your application. NOTE: IF YOU ARE CURRENTLY PROTECTED BY THE FILING OF A PETITION IN BANKRUPTCY, THE FOLLOWING PART OF THIS NOTICE IS FOR INFORMATION PURPOSES ONLY AND SHOULD NOT BE CONSIDERED AS AN ATTEMPT TO COLLECT THE DEBT. (If you have fIled bankruptcy you can still apply for Emergency Mort2ageAssistance.) HOW TO CURE YOUR MORTGAGE DEFAULT (Brine it up to date), NATURE OF THE DEFAULT - The MORTGAGE debt held by the above lender on your property located at: 851 Brian Ave, Enola, PA 17025 IS SERIOUSLY IN DEFAULT because: A. YOU HAVE NOT MADE MONTHLY MORTGAGE PAYMENTS for the following months and the following amounts are now past due: 3 (a) Monthly payment from 10/06/2003 thru 4/6/2004 (7 rnos. at $556.05/rnonth) $3,892.35 (b) Late charges (c) Other charges; Escrow, Inspec., NSF Checks (d) Other provisions of the mortgage obligation, if any (e) TOTAL AMOUNT REQUIRED AS OF THIS DATE: $3,892.35 HOW TO CURE THE DEFAULT - You may cure the default within THIRTY (30) DAYS ofthe date of this notice BY PAYING THE TOTAL AMOUNT PAST DUE TO THE LENDER WHICH IS $ 3.892.35 ,PLUS ANY MORTGAGE PAYMENTS AND LATE CHARGES WHICH BECOME DUE DURING THE THIRTY (30) DAY PERIOD. Payments must be made either by cashier's check, certified check or money order made payable and sent to: CITIFINANCIAL SERVICES INC. 7467 New Ridge Road Suite 222 Hanover, MD 21076 IF YOU DO NOT CURE THE DEFAULT - If you do not cure the default within THIRTY (30) DAYS of the date of this Notice, the lender intends to exercise its riehts to accelerate the morteaee debt. This means that the entire outstanding balance ofthis debt will be considered due irnmediately and you may lose the chance to pay the mortgage in monthly installments. If full payment of the total amount past due is not made within THIRTY (30) DAYS, the lender also intends to instruct its attorneys to start legal action to foreclose upon vour morteaeed property. IF THE MORTGAGE IS FORECLOSED UPON - The mortgaged property will be sold by the Sheriff to payoff the mortgage debt. If the lender refers your case to its attorneys, but you cure the delinquency before the lender brings legal proceedings against you, you will still be required to pay the reasonable attorney's fees that were actually incurred, up to $50.00. However, iflegal proceedings are started against you, you will haye to pay all reasonable attorney's fees actually incurred by the lender even if they exceed $50.00. Any attorney's fees will be added to the amount you owe the lender, which may also include other reasonable costs. If vou cure the default within the THIRTY (30) DAY period. vou will not be required to pav attornev's fees. OTHER LENDER REMEDIES - The lender may also sue you personally for the unpaid principal balance and all other sums due under the mortgage. RIGHT TO CURE THE DEFAULT PRIOR TO SHERIFF'S SALE - If you have not cured the default within the THIRTY (30) DAY period and foreclosure proceedings have begun, you still have the right to cure the default and prevent the sale at any tirne up to one hour before the Sheriffs Sale. You may do so by paving the total amount then past due, plus anv late or other charges then due, reasonable attorney's fees and costs connected with the foreclosure sale and any other costs connected with the Sheriffs Sale as specified in writing by the lender and by performing any other requirements 4 under'the rnortgage. Curing your default in the manner set forth in this notice will restore your ~ortgage to the same position as if you had never defaulted. EARLIEST POSSIBLE SHERIFF'S SALE DATE - It is estirnated that the earliest date that such a Sheriff's Sale ofthe mortgaged property could be held would be approximately four (4) to six (6) months from the date ofthis Notice. A notice of the actual date ofthe Sheriff's Sale will be sent to you before the sale. Of course, the amount needed to cure the default will increase the longer you wait. You may find out at any time exactly what the required payment or action will by contacting the lender. HOW TO CONTACT THE LENDER: Name of Lender: CITIFINANCIAL SERVICES INC. Address: 7467 New Ridge Road Suite 222 Hanover, MD 21076 Phone Number: 888-800-5165 Fax Number: Contact Person: Loss Mitigation Department EFFECT OF SHERIFF'S SALE - You should realize that a Sheriff's Sale will end your ownership of the mortgaged property and your right to occupy it. If you continue to live in the property after the Sheriff's Sale, a lawsuit to remove you and your furnishings and other belongings could be started by the lender at any tirne. ASSUMPTION OF MORTGAGE - You may sell or transfer your horne to a buyer or transferee who will assume the mortgage debt, provided that all the outstanding payments, charges and attorney's fees and costs are paid prior to or at the sale and that the other requirements of the mortgage are satisfied. YOU MAY ALSO HAVE THE RIGHT: * TO SELL THE PROPERTY TO OBTAIN MONEY TO PAY OFF THE MORTGAGE DEBT OR TO BORROW MONEY FROM ANOTHER LENDING INSTITUTION TO PAY OFF THIS DEBT. * TO HAVE THIS DEFAULT CURED BY ANY THIRD PARTY ACTING ON YOUR BEHALF. * TO HAVE THE MORTGAGE RESTORED TO THE SAME POSITION AS IF NO DEFAULT HAD OCCURRED, IF YOU CURE THE DEFAULT. (HOWEVER, YOU DO NOT 5 HAVE THIS RIGHT TO CURE YOUR DEFAULT MORE THAN THREE TIMES IN ANY CALENDAR YEAR.) * TO ASSERT THE NONEXISTENCE OF A DEFAULT IN ANY FORECLOSURE PROCEEDING OR ANY OTHER LAWSUIT INSTITUTED UNDER THE MORTGAGE DOCUMENTS. * TO ASSERT ANY OTHER DEFENSE YOU BELIEVE YOU MAY HAVE TO SUCH ACTION BY THE LENDER. * TO SEEK PROTECTION UNDER THE FEDERAL BANKRUPTCY LAW. Contact Person: Loss Mitigation Department Phone Number: 888-800-5165 6 PENNSYLVANIA HOUSING FINANCE AGENCY HOMEOWNER'S EMERGENCY MORTGAGE ASSISTANCE PROGRAM CONSUMER CREDIT COUNSELING AGENCIES CUMBERLAND COUNTY CCCS OF WESTERN PENNSYLVANIA INe. 2000 Linglestown Road Harrisburg, P A 171 02 (717) 541-1757 URBAN LEAGUE OF METROPOLITAN HARRISBURG 2107 N. 6th Street Harrisburg, PA 17101 (717) 234-5925 FAX (717) 234-9459 COMMUNITY ACTION COMM OF THE CAPITAL REGION 1514 Derry Street Harrisburg, P A 17104 (717) 232-9757 FAX 234-2227 FINANCIAL COUNSELING SERVICES OF FRANKLIN 31 West 3rd Street Waynesboro, PA 17268 (717) 762-3285 YWCA OF CARLISLE 301 G Street Carlisle, PA 17013 (717) 243-3818 FAX (717)731-9589 ADAMS COUNTY HOUSING AUTHORITY 139-143 Carlisle Street Gettysburg, P A 17325 (717) 334-1518 FAX (717)334-8326 , , "".j <..:.-., C) ~ "CI. t-:, -q _k.;._ AJ ~ ~ I 0) ,;! :\l 'C', . r; > ......... tI( ~ ( - I ...... "l '<l () () ~ ~ ; I ...0 -() , }.J G.) '""'-J fi' ~ SHERIFF'S RETURN - NOT FOUND CASE NO: 2004-02115 P COMMONTWEALTH OF PENNSYLVANIA COUNTY OF CUMBERLAND CITIFINANCIAL SERVICES INC VS SCHOEN GWENDOLYN A R, Thomas Kline ,Sheriff or Deputy Sheriff, who being duly sworn according to law, says, that he made a diligent search and inquiry for the within named DEFENDANT SCHOEN GWENDOLYN A but was unable to locate Her in his bailiwick. He therefore returns the COMPLAINT - MORT FORE the within named DEFENDANT 851 BRIAN AVENUE ENOLA, PA 17025 851 BRIAN AVENUE ENOLA IS VACANT. Sheriff's Costs: Docketing Service Not Found Surcharge 18.00 10.35 5.00 10.00 .00 43.35 Sworn and subscribed to before me this } AT day Of~ ;)VVlj A.D. ()", ...- 0 'M';P1---".fJL Pr~otary'-r'J , NOT FOUND , as to , SCHOEN GWENDOLYN A . //~~,...?;:/,...---, -,,- ,~ ," R. Thoma; Klle Sheriff of Cumberland County GOLDBECK MCCAFFERTY MCKEEVER OS/25/2004 SHERIFF'S RETURN - REGULAR CASE NO: 2004-02115 P COMMONWEALTH OF PENNSYLVANIA: COUNTY OF CUMBERLAND CITIFINANCIAL SERVICES INC VS SCHOEN GWENDOLYN A ROBERT BITNER , Sheriff or Deputy Sheriff of Cumberland County, Pennsylvania, who being duly sworn according to law, says, the within COMPLAINT - MORT FORE was served upon SCHOEN GWENDOLYN A the DEFENDANT , at 2050:00 HOURS, on the 24th day of May , 2004 at 616 ERFORD ROAD CAMP HILL, PA 17011 by handing to GWENDOLYN SCHOEN 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: 6.00 10.35 .00 10.00 .00 26.35 ~P--C:r.",~.~ R. Thomas ~~ " OS/25/2004 GOLDBECK MCCAFFERTY MCKEEVER me this /.,4-1- day of B~W~if Sworn and Subscribed to before ~ ,J.ov-i A.D. ( j Y /L () 7'J..,.( i-" -1-1 m;;- ~ Prothonotary' I ' o GOLDBECK McCAFFERTY & McKEEVER BY: Joseph A. Goldbeck, Jr. Attorney LD. #16132 Suite 500 - The Bourse Bldg. III S.independence Mall East Philadelphia, PA 19106 215-627-1322 Attorney for Plaintiff CITIFINANCIAL SERVICES INe. 7467 New Ridge Road Suite 222 Hanover, MD 21076 IN THE COURT OF COMMON PLEAS of Cumberland Connty Plaintiff vs. CIVIL ACTION LAW GWENDOLYN A. SCHOEN (Mortgagor(s) and Record owner(s)) 851 Brian Ave Enola, P A 17025 ACTION OF MORTGAGE FORECLOSURE Defendant( s) No. 04-2115 CIVIL TERM ORDER FOR JUDGMENT Please enter Judgment in favor of CITIFINANCIAL SERVICES INC., and against GWENDOLYN A. SCHOEN for failure to file an Answer in the above action within 20) days (or sixty (60) days if defendant is the United States of America) from the date of service of the Compla in the sum of$74,510.70. I hereby certify that the above names are correct and that the pr is r i ence address of the judgment creditor is CITIFINANCIAL SERVICES INC. 7467 New Ridge Road S' 222 Hanover, MD 21076 and that the name(s) and last known addressees) of the Defendant(s) is/are GWENDOLYN A. SCHOEN, 616 Erford Road CampHiII,PA 17011; FERTY & McKEEVER eck, Jr. VERIFICATION OF NON-MILITARY SERVICE The undersigned, as the representative for the Plaintiff corporation within named do hereby verify that I am authorized to make this verification on behalf of the Plaintiff corporation and that the facts set forth in the foregoing verification of Non- Military Service are true and correct to the best of my knowledge, information and belief. I understand that false statements therein are made subject to penalties of 18 Pa. C.S. 4904 relating to unsworn falsification to authorities. 1. That the above named Defendant, GWENDOLYN A. SCHOEN, is about unknown years of age, that Defendant's last known residence is 616 Erford Road, Camp Hill, PA 17011, 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 Amendme Date: In the Court of Common Pleas of Cumberland County CITIFINANCIAL SERVICES INC. 7467 New Ridge Road Suite 222 Hanover, MD 21076 Plaintiff vs. GWENDOLYN A. SCHOEN (Mortgagor(s) and Record Owner(s)) 851 Brian Ave Enola, P A 17025 No. 04-2115 CIVIL TERM Defendant(s) PRAECIPE FOR JUDGMENT THIS LAW FIRM IS A DEBT COLLECTOR AND WE ARE ATTEMPTING TO COLLECT A DEBT OWED TO OUR CLIENT. ANY INFORMATION OBTAINED FROM YOU WILL BE USED FOR THE PURPOSE OF COLLECTING THE DEBT. Enter the Judgment in favor of Plaintiff and against GWEN DOL YN A. SCHOEN by default for want of an Answer. Assess damages as follows: $74,510.70 Debt Interest - 09/06/2003 to 07/02/2004 Total (Assessment of Damages attached) I CERTIFY THAT FOREGOING ASSESSMENT OF DAMAGES IS FOR SPECIFIED AMOUNTS ALLEGED TO BE DUE IN THE COMPLAINT AND IS CALCULABLE AS A SUM CERTAIN FROM THE COMPLAINT. I certify that written notice of the intention to file this praecipe was mailed or delivered to the party against whom judgment is to be entered and to his attorney of record, if any, after the default occurr . st ten days prior to the date of the filing of this praecipe. A copy of the notice is attached. R.C.P. 237.1 AND NOW , ,J gment is entered in favor of CITIFINANCIAL SERVICES INe. and against GWENDOLYN A. SCHOEN by default for want of an Answer and damages assessed in the sum of$74,51 0.70 as per the above certification. Prothonotary THIS LAW FIRM IS A DEBT COLLECTOR AND WE ARE ATTEMPTING TO COLLECT A DEBT OWED TO OUR CLIENT. ANY INFORMATION OBTAINED FROM YOU WILL BE USED FOR THE PURPOSE OF COLLECTING THE DEBT. DATE OF THIS NOTICE: June 14,2004 TO: GWENDOLYN A. SCHOEN 616 Erford Road Camp Hill, PA 17011 CITIFINANCIAL SERVICES INC. 7467 New Ridge Road Suite 222 Hanover, MD 21076 In the Court of Common Pleas of Cumberland County CIVIL ACTION - LAW Plaintiff vs. GWENDOLYN A. SCHOEN (Mortgagor(s) and Record Owner(s)) 851 Brian Ave Enola, PAl 7025 Action of Mortgage Foreclosure Term No. 04-2115 CIVIL TERM Defendant{s} TO: GWENDOLYN A. SCHOEN 616 Erford Road Camp Hill, PA 17011 IMPORTANT NOTICE YOU ARE IN DEFAULT BECAUSE YOU HAVE FAILED TO ENTER A WRITTEN APPEARANCE PERSONALLY OR BY ATTORNEY AND FILE IN WRITING WITH THE COURT YOUR DEFENSES OR OBJECTIONS TO THE CLAIMS SET FORTH AGAINST YOU. UNLESS YOU ACT WITHIN TEN (10) DAYS FROM THE DATE OF THIS NOTICE, A JUDGMENT MAY BE ENTERED AGAINST YOU WITHOUT A HEARING AND YOU MAY LOSE YOUR PROPERTY OR OTHER IMPORTANT RIGHTS. YOU SHOULD TAKE THIS PAPER TO YOUR LAWYER AT ONCE. IF YOU DO NOT HAVE A LAWYER, GO TO OR TELEPHONE THE OFFICE SET FORTH BELOW. THIS OFFICE CAN PROVIDE YOU WITH INFORMATION ABOUT HIRING A LAWYER. IF YOU CANNOT AFFORD TO HIRE A LAWYER, THIS OFFICE MAY BE ABLE TO PROVIDE YOU WITH INFORMATION ABOUT AGENCIES THAT MAY OFFER LEGAL SERVICES TO ELIGIBLE PERSONS AT A REDUCED FEE OR NO FEE. LEGAL SERVICES INC 8 Irvine Row Carlisle, P A 17013 717-243-9400 CUMBERlAND COUNTY BAR ASSQCIA nON 2 Liberty Avenue Carlisle, PA 17013 GOLDBECK McCAFFERTY & McKEEVER BY: Joseph A. Goldbeck, Jr., Esq. Attorney for Plaintiff Suite 5000 - Mellon Independence Center. 701 Market Street Philadelphia, PA 19106 215-627-1322 THIS LAW FIRM IS A DEBT COLLECTOR AND WE ARE ATTEMPTING TO COLLECT A DEBT OWED TO OUR CLIENT. ANY INFORMATION OBTAINED FROM YOU WILL BE USED FOR THE PURPOSE OF COLLECTING THE DEBT. , DATE OF THIS NOTICE: June 14, 2004 TO: GWENDOLYN A. SCHOEN 851 Brian Ave Enola, PA 17025 CITIFINANCIAL SERVICES INC. 7467 New Ridge Road Suite 222 Hanover, MD 21076 In the Court of Common Pleas of Cumberland County CIVIL ACTION - LAW Plaintiff vs. GWENDOLYN A. SCHOEN (Mortgagor(s) and Record Owner(s)) 851 Brian Ave Enola, PAl 7025 Action of Mortgage Foreclosure Term No. 04-2115 CIVIL TERM Defendant(s) TO: GWENDOLYN A. SCHOEN 851 Brian Ave Enola, P A 17025 IMPORT ANT NOTICF, 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 MAYBE ENTERED AGAINST YOU WITHOUT A HEARING AND YOU MAY LOSE YOUR PROPERTY OR OTHER IMPORTANT RIGHTS. YOU SHOULD TAKE THIS PAPER TO YOUR LAWYER AT ONCE. IF YOU DO NOT HAVE A LAWYER, GO TO OR TELEPHONE THE OFFICE SET FORTH BELOW. THIS OFFICE CAN PROVIDE YOU WITH INFORMATION ABOUT HIRING A LAWYER. IF YOU CANNOT AFFORD TO HIRE A LAWYER, THIS OFFICE MAY BE ABLE TO PROVIDE YOU WITH INFORMATION ABOUT AGENCIES THAT MAY OFFER LEGAL SERVICES TO ELIGIBLE PERSONS AT A REDUCED FEE OR NO FEE. LEGAL SERVICES INC 8 Irvine Row Carlisle, PA 17013 717-243.9400 CUMBERLAND COUNTY BAR ASSOCIA nON 2 Liberty Avenue Carlisle, PA 17013 GOLOBECK McCAFFERTY & McKEEVER BY: Joseph A Goldbeck, Jr., Esq. Attorney for Plaintiff Suite 5000 - Mellon Independence Center. 701 Market Street Philadelphia, PA 19106 215-627-1322 Rule of C~vi1 Procedure No. 236 - Revised , CITIFINANCIAL SERVICES INe. 7467 New Ridge Road Suite 222 Hanover, MD 21076 GWENDOLYN A. SCHOEN (Mortgagors and Record Owner(s)) 851 Brian Ave Enola, PA 17025 IN THE COURT OF COMMON PLEAS OF Cumberland COUNTY, PENNSYL VANIA CIVIL ACTION - LAW Plaintiff No. 04-2115 CIVIL TERM vs. Defendant( s) THIS LAW FIRM IS A DEBT COLLECTOR AND WE ARE ATTEMPTING TO COLLECT A DEBT OWED TO OUR CLIENT. ANY INFORMATION OBTAINED FROM YOU WILL BE USED FOR THE PURPOSE OF COLLECTING THE DEBT. NOTICE Notice is given that a judgment in the above-captioned matter has been entered against yon. Curt Long Prothonotary By: ~ ~~t--r (J Deputy If you have any questions concerning the above, please contact: Joseph A. Goldbeck, Jr. Goldbeck McCafferty & McKeever Suite 500 - The Bourse Bldg. I I I S. Independence Mall East Philadelphia, PA 19106 215-627-1322 ~ 1 ~ ~ ~' ~ U\ U ~(\ ~ () w U t..l ~ ....\ \ ~ ~ ~ -'q,-" '-;"'1" ";'- ."j."' ~ ~ ~ o \";; ,....> c.:..' c.;.) ;- <- c:oO r-::; , -.J :~- , , ~ -,'J c."" -!.:.; J;-" ,~ ->.-. ('J -1'1 c-) c:.' ..... :1:-:0 rr\j -:9,18 i"S 1-, :~I~i ~:;1}~ .;~ "j -~ o PRAECIPE FOR WRIT OF EXECUTION - (MORTGAGE FORECLOSURE) P.R.C.P 3180-3183 Joseph A. Goldbeck, Jr. Attorney~.D.#16132 Suite 500 - The Bourse Bldg. III S. Independence Mall East Philadelphia, PA 19106 215-627-1322 Attomey for Plaintiff CITIFINANCIAL SERVICES INC. 7467 New Ridge Road Suite 222 Hanover, MD 21076 IN THE COURT OF COMMON PLEAS Plaintiff of Cumberland County vs. CIVIL ACTION - LAW GWENDOLYN A. SCHOEN Mortgagor(s) and Record Owner(s) 851 Brian Ave Enola, PA 17025 ACTION OF MORTGAGE FORECLOSURE Defendant( s) No. 04-2115 CIVIL TERM PRAECIPE FOR WRIT OF EXECUTION TO THE PROTHONOTARY: Issue Writ of Execution in the above matter: Amount Due $74,510.70 Ioterest from 09/06/2003 to 07/02/2004 at 10.5000% (Costs to he added) ~ ~ ~ \ '" ,,~: ~ "" ~\~ '\ ~ ~ ~ ~ '~j \ \ b\ ~ ~ o ~11 \ ;'J t ~ ~ .......... . . ~ ~ J~ t ~ ~ ~ ^(\ "" <> ~ , \ 0- ~ c... l..,j ~ "', i"-...j ~ C) l:? -Ij c_ __~ c.:: ::r: -f" r-- rni~c.'t -om ~ :J.2't."J ~;J~; :C? :~? ~'~: _ ~;~: n', >~ c) ~9., "\.) z ~ 0 .. .... " rol ~ .... > ... U -;;;- P ~ . ~ i!:i z'"5' " bIl '" =- U~ ~:s!~'" ~Z <Jl ~ ~ ~ ~ ~t U!:Q=O ~ [Eo ^<=l ~OCl:l- ~o rol ~ ~::S'" u '" -'d s oll~ -gj ....~ .... U." "N .....s " '" ~ Cf.:I 5 > 0 o 1;j .<:>- co8<~ "'0 . (.) -( r- .,,'" .t:O=P-4"7 i32:u ~ -<" - .... s - .. ~ 0 ~ C';S~ r--- o 0 <Jl .; ~""~-< ~i 0- ~~il:E~ "u... ... > "O'C ~ . >> ~ I fr~:6 ~~o ~ ... ~ ~ '" -< " -= e -.... ~ O";i;'~o i:l:i~ " 0 :?18]"'gN <"';'~ Q 'Coo = 0" 0.;:: .::.:IV) =-= g Zo ~ ... " (<5-< u~u:ilf <!;o ~bIl role ..... J's - Ou ~ ~gj, =- ~<Jl- Z~ 015 .... - - .... u " - ::s ~ t.:I u ~ i5 =- ALL THAT .CERI'AIN unit in the property ~!!"l'. Mlt'll!d nnd idontifiod in the Occl.:Jr,;ltion Plan, ~et<orredto below a. I*iIst"""'" vl.llage condanini.... locat<!d in Eaot Pcnnoboro Township, CUI'I'lbeX'land COO.'1ty, PannsYlvania, which IUJ.s hat'ctoforo boon l;;ul;mittcd to tho prdvision.q of the lnie Property Act ot. PenriliylVll.nia, J\Ct of July 3, 1963, P.I.. 196, by tho recording in too CUice of tI><o Rocorclcr of /l<:!cOg of ~"'tix>rlond County, Pennsylvania, of a ~cla.ration ~tinq and Est.:Jbl1shing Wcstwc:od Villo9C:' Condcxninium dated JanuDry 29, 1975, and recordt."Cl on January 29, 1975', in Misc. nook 213. Vnge 293, Mil ~ by a certain Fi~.t ~ to Occlaration C<C<lting and Est.,bliohing West~ Village Con6omJ.nium doted Ma~ 28. 1976. and r=I'tl€d on .1"",,' 22. 1976. in Misc. Dool< 222. page 729, and . certllin 5<!Ccncl ~t to Docl,r.tion Crecting and Est<>bUshJ.ng W<lst~ Village Condan.inium clotcc1 July 21, 1~76, and """'rded on July 26. 1976, in Misc. Dook 22], PL\\JC 343, and II certai.n Third I\rrcndmont to Dcclnrntion <;:rooting and Establishing _t~ Vill'g<! condcrn.lni.... d.,tcd Juno 9, 1978. and ro- cordoc1 on JU.IO 23, 197t!, in Misc. Dook 236, P.L'lgo 225, Clncl a ccrb:lin Fouz"th J\m,:ncltCflt <':'to Oeelin:~tiQn Crci1ting .nod Establishing Wcstwol:'4 Villilga COrlGlca1'inium d."1tcd June 13, ~' .1978, and 2::C!COrdcd on ,J~ 23, 1978, in Misc. Dock 2361 . PAge , 250, ~ncl (1 ccrt..1in Firth . 1\rroidll.,.",e to Oeeliu:ation creating ~nd Bstctblishinq wast~ Villag') Conc1cminium dated Januc"\ry 9, 1979 and ~c:Ied on January 23, 1070, in Misc. nook 240, P.:agt!! 884, and a cerUin Sixth 1Itrendrrtont to o.clar.tiem croaUng .nd P:st<>bllshJ.nq Wostlo<JOCl Village Condaninium dated Moreh 1. 1979. and ~e<:orded March 12, 1979. in Misc. Dool< 241, Pa9C 836, and a Cod.a of Regulations of lm~ Village Condc.minium diJted January' 29, 1975. and reeor<l<!d on January 29, 1975, in Misc. Iloak 21J, Pag<! 328, and IlIT'<:l1<lcd by a cerb:1in Fi.se Ami)ndrront to Ct1:la of Roqulllti,'n.s of Wost\<<XXJ Villacp CondcJninil,.Qll . .. dab><! May 28. 1976. and ~=rdcd on June 22. 1976. in Misc. ,Dool< 222. I'ag" 737, and Ce<:l.aration Plan of ' West"""'" Village O:>n<\a'I'.inium dated January 29. D75. and ~~'COrded em ,January 29, 1975 in Plan Dool< 26, pago15. and amended by . certain First I\rr<:!nd- """'t to Veelaration Plan of west~ Villa\/<, Condaninium dated July 21. 1976. and re- oordcd on July ~6. 1976. in Plan !look 28, pago 72, and ...,nd<:<l by a certain Sc<:ond ~t to De<:18J:ation Plan of Wesbo<>Od Vil14g., Condaninium 4,_ .June 16. 1978. and recorded on .June 23, 1978, in Plan D::Iok 331 Pa9'Gl 28, and aroonded by a ccrtltin 'Ihird ~nt to teclarotion plan of Wcot~ Villa9C Co<<laninium'dotad January 9. 1979. and r""-"">"ded January 23. 1979. in Plan Book 34. Pa<Je 100. .hd _ by. . certain Fourth Amendtrent to o.clarotion Plan of Wesbo<>Od Villa9'O COndcminium dated >larch I. 197~. and rucorded Morel> 12. 1979. in Plan !look 35. P..... 3,- being <'esign.,ted on said Dec1&".tion Plan Of w..st~ Vil1a9" COndaninium a. Unit No. 851, Suite 123, t.23'F2 in Block '5. a.ildinq'19, knc:ron .. 851 Brian 0.-1"". SUite 123. E>lola, C\Irl;IQr1Ancl eountr. P9Msylvania. as = fully _ibed in .uch Doclaration Plan and Doclaration creating and Establishing _bo:tOd VUlagor 00n<lanin.i1llt. a. the ...... appears of rocord as .at forth abov$. including any ...."el"ent. thereto. '1"llGF.l'HER Wit!! a prq;>orti""..te undivided interest in t!!e CGmI10n Elements (as defined in such Oecluation) of seven IIUndred SOventy-two 'IttouBal'>\lths Percent (.772\'. WRIT OF EXECUTION and/or ATTACHMENT COMMONWEALTH OF PENNSYLVANIA) COUNTY OF CUMBERLAND) NO 0 4-2115 Civil CIVIL ACTION - LAW TO THE SHERIFF OF CUMBERLAND COUNTY: To satisfy the debt, interest and costs due CITlFINANCIAL SERVICES INC Plaintiff (s) From GWENDOLYN A. SCHOEN, 851 BRIAN AVENUE, ENOLA, P A 17025 (I) You are directed to levy upon the property of the defendant (s)and to sel1 REAL ESTATE LOCATED AT: 851 BRIAN AVENUE, ENOLA, PA 17025 (2) You are also directed to attach the property of the defendant(s) not levied upon in the possession of GARNISHEE(S) as fol1ows: 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 fonnd 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 $74,510.70 Interest FROM 9/6/03 TO 7/2/04 AT 10.5000% Atty's Comm L.L..50 % Due Prothy $1.00 Other Costs Atty Paid $151.70 Plaintiff Paid Date: 7/8/04 CURTIS R. LONG (Seal) "1/'1 /Oq Prothonotary I J By: fr<.t,,-- -n?~~ Deputy f REQUESTING PARTY: Name JOSEPH A. GOLDBECK, JR Address: SillTE 500 - THE BOURSE BLDG 111 S. INDEPENDENCE MALL EAST PHILADELPIDA, PA 19106 Attorney for: PLAINTIFF Telephone: (215) 627-1322 Supreme Court ID No. 16132 Go]dbeck McCafferty & McKeever BY: Joseph A. Goldbeck, Jr. Attorooy I.D. #]6132 Suite 500 - The Bourse Bldg. .. 11] S. Independence Mall East Philadelphia, PA ]9106 215-627-1322 Attorney for Plaintiff CITIFINANCIAL SERVICES INC. 7467 New Ridge Road Suite 222 Hanover, MD 2]076 IN THE COURT OF COMMON PLEAS of Cumberland County Plaintiff vs. CIVIL ACTION - LAW GWENDOLYN A. SCHOEN (Mortgagor(s) and Record Owner(s)) 85] Brian Ave Enola, P A ] 7025 ACTION OF MORTGAGE FORECLOSURE Defendant(s) No. 04-2115 CIVIL TERM AFFIDAVIT PURSUANT TO RULE 3129 CITIFINANCIAL SERVICES INC., Plaintiff in the above action, by its attorney, Joseph A. Goldbeck, Jr., Esquire, sets forth as of the date the praecipe for the writ of execution was filed the following information concerning the real property located at: 851 Brian Ave Enola, P A 17025 l.Name and address ofOwner(s) or Reputed Owner(s): GWENDOLYN A. SCHOEN 616 Erford Road Camp Hill, PA 17011 2. Name and address ofDefendant(s) in the judgment: GWENDOLYN A. SCHOEN 616 Erford Road Camp Hill, PA 17011 3. Name and last known address of every judgment creditor whose judgment is a record lien on the property to be sold: DOMESTIC RELATIONS OF CUMBERLAND COUNTY PO Box 320 Carlisle, PA 17013 PA DEPARTMENT OF PUBLIC WELFARE - Bureau ofCbild Support Enforcement Health and Welfare Bldg. - Room 432 P.O. Box 2675 Harrisburg, PA 17105-2675 EAST PENNSBORO TOWNSHIP 98 S. ENOLA DRIVE ENOLA, PA 17025 WESTWOOD VILLAGE CONDOMINIUM P.O. BOX 233 HUMMELSTOWN, P A 17036 4. Name and address of the last recorded holder of every mortgage of record: 5. Name and address of every other person who has any record interest in or record lien on the property and whose interest may be affected by the sale: 6. Name and address of every other person of whom the plaintiff has knowledge who has any record interest in the property which may be affected by the sale. 7. Name and address of every other person of whom the plaintiff has knowledge who has any interest in the property which may be affected by the sale. TENANTS/OCCUP ANTS 851 Brian Ave Enola, P A 17025 (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 nnderstand that false statements herein are made subject to the penalties of 18 Pa. C.S. Section 4904 relating to nnsworn falsification to authorities. GOLDBECK Me TY & McKEEVER BY: Joseph A. G,,)c ,ed<, Jr., Esq. Attorney for Plair' f DATED: July 2, 2004 o c: ,..., = = .r:- c_ f~ I -.l , ~~~! -~'. ,.. ~- o -n ::;:l -,-~ fI'\r -C1 (0 -::;")0 (~6 "' I~. :::.~ ;~)-d c-,,..() /,-)Cn ':~.j c.....) J.- .~ 04-2115 CIVIL TERM GOLDBECK McCAFFERTY & McKEEVER BY: Joseph A. Goldbeck, Jr. Attorney I.D.#16132 Suite 5000- Mellon Independence Center 701 Market Street Philadelphia, P A 19106 215-627-1322 Attomey for Plaintiff CITIFINANCIAL SERVICES INC. 7467 New Ridge Road Suite 222 Hanover, MD 21076 IN THE COURT OF COMMON PLEAS of Cumberland County Plaintiff CIVIL ACTION - LAW vs. GWENDOLYN A. SCHOEN Mortgagor(s) and Record Owner(s) ACTION OF MORTGAGE FORECLOSURE 851 Brian Ave Enola, P A 17025 Term No. 04-2115 CIVIL TERM Defendant(s) THIS LAW FIRM IS A DEBT COLLECTOR AND WE ARE ATTEMPTING TO COLLECT A DEBT. THIS NOTICE IS SENT TO YOU IN AN ATTEMPT TO COLLECT A DEBT. ANY INFORMATION OBTAINED FROM YOU WILL BE USED FOR THAT PURPOSE. NOTICE OF SHERIFF'S SALE OF REAL PROPERTY TO: SCHOEN, GWEN DOL YN A. GWENDOLYN A. SCHOEN 616 Erford Road Camp Hill, PA 17011 Your house at 851 Brian Ave, Enola, P A 17025 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$74,510.70 obtained by CITIFINANCIAL SERVICES INe. against you. NOTICE OF OWNER'S RIGHTS YOU MAY BE ABLE TO PREVENT THIS SHERIFF'S SALE To prevent this Sheriffs Sale you must take immediate action: 1. The sale will he cancelled if you pay to CITlPINANCIAL SERVICES INe., the back payments, late charges, costs and reasonable attorney's fees due. To find out how much you must pay call: 215-627-1322 2. You may be able to stop the sale by filing a 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. 04-2115 CIVIL TERM 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 attomey). YOU MAY STILL BE ABLE TO SAVE YOUR PROPERTY AND YOU HAVE OTHER RIGHTS EVEN IF THE SHERIFF'S SALE DOES NOT TAKE PLACE. I. If the Sheriffs Sale is not stopped, your property will be sold to the highest bidder. You may find out the price bid price by 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 amonnt due in the sale. To fmd out if this has happened, you may call the Sheriff of7 17-240-6390. 4. If the amonnt 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 thirty (30) days from the date of the Sheriffs Sale. This schedule will state who will be receiving that money. The money will be paid out in accordance with this schedule unless exceptions (reasons why the proposed distribution is wrong) are filed with the Sheriff within ten (10) days after the schedule of distribution is filed. 7. You may also have other rights and defenses, or ways of getting your house back, if you act immediately after the sale. YOU SHOULD TAKE THIS PAPER TO YOUR LAWYER AT ONCE. IF YOU DO NOT HAVE A LAWYER OR CANNOT AFFORD ONE, GO TO OR TELEPHONE THE OFFICE LISTED BELOW TO FIND OUT WHERE YOU CAN GET LEGAL HELP. LEGAL SERVICES INC 8 Irvine Row Carlisle, PA 17013 CUMBERLAND COUNTY BAR ASSOCIATION 2 Liberty Avenue Carlisle, PA 17013 ..-::' ;~;. '.1"' " (I; : -<' -~' , '..- "'- ~7l. ~(> .- ( c'" f~: ...., (~:> C'~ ~- ( ...... f::::; o -n .-1 ~~ \1CT"1 _,,'.r-. ;') '7' -",() ;3,~ "},,: JJ --< I -.l :u ....x: (,,) GOLDBECK McCAFFERTY & McKEEVER BY: Joseph A. Goldbeck, Jr. Attomey I.D.#16132 Suite 5000 - Mellon Independence Center 701 Market Street Philadelphia, PA 19106-1532 215-627-1322 Attomey for Plaintiff CITIFINANCIAL SERVICES INC. 7467 New Ridge Road Suite 222 Hanover, MD 21076 IN THE COURT OF COMMON PLEAS of Cumberland County Plaintiff CIVIL ACTION - LAW vs. GWENDOLYN A. SCHOEN Mortgagor(s) and Record Owner(s) ACTION OF MORTGAGE FORECLOSURE 851 Brian Ave Enola, P A 17025 Term No. 04-2115 CIVIL TERM Defendant(s) THIS LAW FIRM IS A DEBT COLLECTOR AND WE ARE ATTEMPTING TO COLLECT A DEBT. THIS NOTICE IS SENT TO YOU IN AN ATTEMPT TO COLLECT A DEBT. ANY INFORMATION OBTAINED FROM YOU WILL BE USED FOR THAT PURPOSE. NOTICE OF SHERIFF'S SALE OF REAL PROPERTY TO: SCHOEN, GWENDOLYN A. GWENDOLYN A. SCHOEN 851 Brian Ave Enola, PA 17025 Your house at 851 Brian Ave, Enola, P A 17025 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$74,51O.70 obtained by CITIFINANCIAL SERVICES INC. against you. NOTICE OF OWNER'S RIGHTS YOU MAY BE ABLE TO PREVENT THIS SHERIFF'S SALE To prevent this Sheriffs Sale you must take immediate action: 1. The sale will be cancelled if you pay to CITIFINANCIAL SERVICES INC., the back payments, late charges, costs and reasonable attorney's fees due. To fmd out how much you must pay call: 215-627-1322 2. You may be able to stop the sale by filing a petition asking the Court to strike or open judgment, if the judgment was improperly entered. You may also ask the Court to postpone the sale for good cause. 3. You may also be able to stop the sale through other legal proceedings. You may need an attomey 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 attomey). YOU MAY STILL BE ABLE TO SAVE YOUR PROPERTY AND YOU HAVE OTHER RIGHTS EVEN IF THE SHERIFF'S SALE DOES NOT TAKE PLACE. 1. If the Sheriff's Sale is not stopped, your property will be sold to the highest bidder. You may fmd out the price bid price by calling the Sheriff of717-240-6390. 2. You may be able to petition the Court to set aside the sale if the bid price was grossly inadequate compared to the value of your property. 3. The sale will go through only if the buyer pays the Sheriff the full amonnt due in the sale. To fmd out if this bas happened, you may call the Sheriffof717-240-6390. 4. If the amount due from the Buyer is not paid to the Sheriff, you will remain the owner of the property as if the sale never happened. 5. You have a right to remain in the property until the full amount due is paid to the Sheriff and the Sheriff gives a deed to the buyer. At that time, the buyer may bring legal proceedings to evict you. 6. You may be entitled to a share of the money which was paid for your house. A schedule of distribution of the money bid for your house will be filed by the Sheriff 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 flled 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, jfyou act immediately after the sale. YOU SHOULD TAKE THIS PAPER TO YOUR LAWYER AT ONCE. IF YOU DO NOT HAVE A LAWYER OR CANNOT AFFORI) ONE, GO TO OR TELEPHONE THE OFFICE LISTED BELOW TO FIND OUT WHERE YOU CAN GET LEGAL HELP. LEGAL SERVICES INC 8 Irvine Row Carlisle, PA 17013 CUMBERLAND COUNTY BAR ASSOCIATION 2 Liberty Avenue Carlisle, PA 17013 r!.;; (;.l f- ~~~: :::::. Q -, '" ~~ (') ., .-, ::1:'11 fI1 f"-;:~ :RF3 e-') .l.. -:;-1 ~T~ ~~j 2j ~~; r'n -j .> "::':1 -, C- t,:. ..... I --.J -'D -..., (,) Jospeh A. Goldbeck, Jr. Attorney J.D. #16132 Suite 500 - The Bourse Bldg. III S. Independence Mall East Philadelphia, PA 19106 215-627-1322 Attorney for Plaintiff CITIFINANCIAL SERVICES INC. 7467 New Ridge Road Suite 222 Hanover, MD 21076 Plaintiff IN THE COURT OF COMMON PLEAS vs. of Cumberland County GWENDOLYN A. SCHOEN Mortgagor(s) and Record Owner(s) 851 Brian Ave Enola, P A 17025 CIVIL ACTION - LAW Defendant( s) ACTION OF MORTGAGE FORECLOSURE NO. 04-2115 CIVIL TERM CERTIFICATION AS TO THE SALE OF REAL PROPERTY I, Joseph A. Goldbeck, Jr., Esquire hereby certify that I am the attorney of record for the Plaintiff in this action, and I further certify that this property is subject to Act 91 of 1983 and the Plaintiff has complied with all the provisions of the Act. ~ , 'e) Joseph A. GO" , ' . r. Attorney for I l~ ltif . V ~ C) ~-- .-< "--, c,:) ~= c_ c: ,- Q " ::J rli::-D f'-- ~,~~!1 ,.>....,7 '~;~(LJ '-'f. ;5:::1'j ~"..C) ~.'"- [n ~._; ~D < -.J ,. Co.) 1'-" GOLDBECK McCAFFERTY & McKEEVER ,BY: JosephA. Goldbeck, Jr. Attorney I.D.#16132 Suite 5000 - Mellon Independence Center 701 Market Street Philadelphia, PA 19106-1532 215-627-1322 Attorne for Plaintiff CITIFINANCIAL SERVICES INC. 7467 New Ridge Road Suite 222 Hanover, MD 21076 CIMD-0264 IN THE COURT OF COMMON PLEAS of Cumberland County Plaintiff CIVIL ACTION - LAW vs. ACTION OF MORTGAGE FORECLOSURE GWENDOLYN A. SCHOEN Mortgagor(s) and Record Owner(s) Term No. 04-2115 CIVIL TERM 851 Brian Ave Enola, P A 17025 Defendant( s) CERTIFICATE OF SERVIC]~ PURSUANT TO Pa.R.C.P. 3129.2 (tlill 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/ctlRIJ.'TtilM i1~ Itt (copy of return attached). ( ) Certified mail by Joseph A. Goldbeck, Jr. (original green Postal return receipt attached). ( ) Certified mail by Sheriffs Office. ( ) Ordinary mail by Joseph A. Goldbeck, Jr., Esquire to Attorney for Defendant(s) of record (proof of mailing attached). ( ) Acknowledgment of Sheriffs Sale by Attorney for Defendant(s) (proof of acknowledgment attached). ( ) Ordinary mail by Sheriffs Office to Attorney for Defendant(s) of record. IF SERVICE WAS ACCOMPLISHED BY COURT ORDER. ( ) Premises was posted by Sheriffs Office/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). (X~ I If ~t ...>0 t · '1' i[~ I :;:: I ~ I ~ I :: I ~ I . .. 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Schoen In The Court of Common Pleas of Cumberland County, Pennsylvania Writ No. 2004-2115 Civil Term Bryan Ward, Deputy Sheriff, who being duly sworn according to law, states that on September 15, 2004 at 8:38 o'clock PM, he served a true: copy of the within Real Estate Writ, Notice of Sheriffs Sale and Description, in the above entitled action, upon the within named defendant, to wit: Gwendolyn A Schoen, by making known unto Marc Schoen, husband of Gwendolyn A Schoen, at 616 Erford Road, Camp Hill, Cumberland County, Pennsylvania, its contents and at the same time handing to him personally the said true and correct copy of the same. Ron Hoover, Deputy Sheriff, who being duly sworn according to law, states that on October 07,2004 at 3:10 o'clock P.M., he posted a true GOPy of the within Real Estate Writ, Notice, Poster and Description, in the above entitled action, upon the property of Gwendolyn a. Schoen located at 851 Brian Ave., Enola, 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: Gwendolyn A Schoen, by regular mail to her last known address of 616 Erford Road, Camp Hill, P A 17011. This letter was mailed under the date of October 06, 2004 and never returned to the Sheriffs Office. Sworn and subscribed to before me This _ day of So Answers: ~~~f~ BY (,J~ ' J~ Real Estat eputy 2004, AD. Prothonotary GOLDBECK McCAFFERTY & McKEEVER , 'BY: Joseph A. Goldbeck, Jr. Attorney LD.#16132 Suite 5000 - Mellon Independence Center 701 Market Street Philadelphia, PA 19106 215-627-1322 Attorney for Plaintiff CITIFINANCIAL SERVICES INe. 7467 New Ridge Road Suite 222 Hanover, MD 21076 IN THE COURT OF COMMON PLEAS of Cumberland County Plaintiff CNIL ACTION - LAW vs. GWENDOLYN A. SCHOEN Mortgagor(s) and Record Owner(s) ACTION OF MORTGAGE FORECLOSURE 851 Brian Ave Enola, P A 17025 Term No. 04-2115 CNIL TERM Defendant( s) AFFIDAVIT PURSUANT TO RULE 3129 CITlFINANCIAL SERVICES INC., Plaintiff in the above action, by its attorney, Joseph A. Goldbeck, Jr., Esquire, sets forth as of the date the praecipe for the writ of execution was filed the followitlg information concerning the real property located at: 851 Brian Ave Enola, P A 17025 l.Name and address ofOwner(s) or Reputed Owner(s): GWENDOLYN A. SCHOEN 616 Erford Road Camp Hill, PA 17011 2. Name and address ofDefendant(s) in the judgment: GWENDOLYN A. SCHOEN 616 Erford Road Camp Hill, PA 17011 3. Name and last known address of every judgment creditor whose judgment is a record lien on the property to be sold: DOMESTIC RELATIONS OF CUMBERLAND COUJ'Il"TY 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, PA 17105-2675 EAST PENNSBORO TOWNSHIP 98 S. ENOLA DRIVE ENOLA, P A 17025 WESTWOOD VILLAGE CONDOMINIUM P.O. BOX 233 HUMMELSTOWN, P A 17036 4. Name and address of the last recorded holder of every mortgage of record: 5. Name and address of every other person who has any record interest in or record lien on the property and whose interest may be affected by the sale: 6. Name and address of every other person of whom the plaintiff has knowledge who has any record interest in the property which may be affected by the sale, 7. Name and address of every other person of whom the plaintiffhas knowledge who has any interest in the property which may be affected by the sale. TENANTS/OCCUPANTS 851 Brian Ave Enola, P A 17025 (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. DATED: November 1, 2004 (-) /'-,." ~-,~ C..:.J 0 c,~.;) - -'1'1 ,~ :;.t~ --, , C) "r ....;;: fli :fJ \ , roo .., I -rJ rn r': ,l:.-' ~';JQ '.. . ] ~ -p .:.,C J;~: ~~;) -,~ ~;:: ~!~ -.... :~O :z: N (5 ill ....-I :i~ -< .z::- :~ <::) .. .. COMMONWEALTH OF PENNSYLVANIA COUNTY OF CUMBERLAND }SS: 04- :l /15' I, Robert P. Ziegler, Recorder of Deeds in and for said County and State do hereby certif that the Sheriffs Deed in which Citifinancial Serv Inc is the grantee the same having been sold to sai grantee on the 8th day ofDec AD., 2004, under and by virtue of a writ Execution issued on the th day ofJnly. AD., 2004, out of the Court of Common Pleas of said County as of Civil Term, 2004 N ber 2115, at the suit ofCitifinancial Serv Inc against Gwendolvn A Schoen is duly recorded in She ffs Deed Book No. 267, Page 492. IN TESTIMONY WHEREOF, I have hereunto s '7l and seal of said office this , A.D20o.t my hand day of Record r of Deeds !leconlot My ,e..- Elcpi1lO lhoo FnI ,CIrftIII,M lllJon.IlOIlIl " Citifinancial Services, Inc. VS Gwendolyn A. Schoen In The Court of Common Pleas of Cumberland County, Pennsylvania Writ No. 2004-2115 Civil Term Bryan Ward, Deputy Sheriff, who being duly sworn according to law, states that on September 15,2004 at 8:38 o'clock PM, he served a true copy of the within Real Estate Writ, Notice of Sheriffs Sale and Description, in the above entitled action, upon the within named defendant, to wit: Gwendolyn A. Schoen, by making known unto Marc Schoen, husband of Gwendolyn A. Schoen, at 616 Erford Road, Camp Hill, Cumberland County, Pennsylvania, its contents and at the same time handing to him personally the said true and correct copy of the same. Ron Hoover, Deputy Sheriff, who being duly sworn according to law, states that on October 07, 2004 at 3: 10 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 Gwendolyn a. Schoen located at 851 Brian Ave., Enola, 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: Gwendolyn A. Schoen, by regular mail to her last known address of 616 Erford Road, Camp Hill, P A 17011. 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 after due and legal notice had been given according to law, he exposed the within described premises at public venue or outcry at the Courthouse, Carlisle, Cumberland County, Pennsylvania on December 8, 2004 at 10:00 o'clock A.M. He sold the same fo the sum of$1.00 to Attorney Joseph Goldbeck for Citifinancial Services Inc. It being t e highest bid and best price received for the same, Citifinancial Services Inc. of 1111 Northpoint Drive, Building 4, Suite 100, Coppell, TX 75019-3931 being the buyer in t s execution, paid to SheriffR. Thomas Kline the sum of$1,272.29. Sheriff's Costs: Docketing Poundage Posting Bins Advertising Acknowledging Deed Auctioneer Law Library Prothonotary Mileage Levy Surcharge $30.00 24.95 15.00 15.00 30.00 10.00 .50 1.00 22.20 15.00 20.00 Law Journal Patriot News Share of Bills Distribution of Proceeds Sheriff's Deed 530.45 463.27 30.42 25.00 39.50 $ 1272.29 Sworn and subscribed to before me ~~~ ThiSLdaYOf~ ' ~ . .. . UOO~ K,line, Sheriff 2005, A.D. ( , _ f1 ,~ . ~' ,/ j r , /l ro onotary BY Vtl6U-~delV\.,lCJ.-\ Real Estat eputy ,t ,.jV , v ,~J v.V 3 ,>t) , 3 n'1 I. ';, '..J<.. G t, / Ru.-. i()941~ Goldbeck McCafferty & McKeever BY: Joseph A. Goldbeck, Jr. Attorney J.D. #16132 Suite 500 - The Bourse Bldg. 111 S. Independence Mall East Philadelphia, PA 19106 215-627-1322 Attorney for Plaintiff CITIFINANCIAL SERVICES INC. 7467 New Ridge Road Suite 222 Hanover, MD 21076 IN THE COURT OF COMMON EAS of Cumberland County Plaintiff vs. CIVIL ACTION - LAW GWENDOLYN A. SCHOEN (Mortgagor(s) and Record Owner(s)) 851 Brian Ave Enola, P A 17025 ACTION OF MORTGAGE FOREC OSURE Defendant(s) No. 04-2115 CIVIL TE AFFIDAVIT PURSUANT TO RULE 3129 CITIFINANC1AL SERVICES INe., Plaintiff in the above action, by its attorney, Joseph A. Goldbeck, r., Esquire, sets forth as of the date the praecipe for the writ of execution was filed the following information concerning the eal properly located at: 851 Bnan Ave EilLlia, Pi.. 17025 l.Namc and address ofOwner(s) or Reputed Owner(s): GWENDOLYN A. SCHOEN 616 Erford Road Camp Hill, PA 17011 2 N(1me (Inn ar1.dre~::: nfDefenrhl1lt(s) in the judgment: (,\1TNDOLY'l A. SCHOE"l 616 Erf'mI Road Comp Hdl, PA 17011 ~:~- c .S( .;:~ :..~ ::~J o f~ J. Ni1f11e and last kno~vn address ofe\'ery judgment creditor whose judgment is a record lien on the property to e sold: I JOM FSTIC RELA TrONS OF Cl JMBERLAND COUNTY PO BI':'; _~:20 Carlisle, PA 17013 p, DEP..\RTMENT OF PUBLIC WELL\RE - Bureau of Child Support Enforceme t Health and Welfare Bldg, - Room 432 1',0, Box 2675 ILni:-.J!lil.:,'_ PA 17105-2G7S EAST pENNSBORO TOWNSHIP 98 S, ENOLA DRIVE ENOLA,PA 17025 ""' c-..:-:> c:;.. ~ o ., .'=c: ,:;:':: f -.J :::;1 di:!J r- '"Clrn ~'no () L ::~_:1 ~--::J i-:") ;i) -"'." ,~ ) :;'"'jrn ~~~ "~::. C,..) WESTWOOD VILLAGE CONDOMINIUM P.O. BOX 233 HUMMELSTOWN, P A 17036 4. Name and address of the last recorded holder of every mortgage of record: 5. Name and address of every other person who has any record interest in or record lien on the property and whos interest may be affected by the sale: 6. Name and address of every other person of whom the plaintiff has knowledge who has any record interest in t 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 prop rty which may be affected by the sale. TENANTS/OCCUP ANTS 851 Brian Ave Enola, P A 17025 (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 knowle ge or information and belief. 1 understand that false statements herein are made subject to the penalties of 18 Pa. C.S. ection 4904 relating to unsworn falsification to authorities. DATED: July 2, 2004 TY & McKEEVER fe k\. r'q, GOLDBECK Mc BY: J0Scph A. (i{ Attorney for Plai t 0 ,..., = 0 c: = -n --~ .r- Q~r? L.. ::;:l c:: fliP! r-- :) I ~~ (;) -< --.J () r,::.: ....-1 ...,..--r, -:-; "'" -"- --r. ,~ ...:' 3:: ~r~ ~i; (, C .'- yc+ =2 "') ~;:J 0 .< I 04-2115 CIVIL IE I GOLDBECK McCAFFERTY & McKEEVER BY: Joseph A. Goldbeck, Jr. Attorney 1.0.#16132 Suite 5000- Mellon Iodependence Center 701 Market Street Philadelphia, P A 19106 215-627-1322 Attorney for Plaintiff CITIFINANCIAL SERVICES INC. 7467 New Ridge Road Suite 222 Hanover, MD 21076 IN THE COURT OF COMMON PLE S of Cumberland County Plaintiff CIVIL ACTION - LAW vs. GWENDOLYN A. SCHOEN Mortgagor(s) and Rccord Owner(s) ACTION OF MORTGAGE FORECLOSURE 851 Brian Ave Enola, P A 17025 Q ,-- Term '-"1,~::' No. 04-2115 CIVIL TE~' (:ii', Defendant(s ~::.: ;'.""" THIS LAW FIRM IS A DEBT COLLECTOR AND WE ARE ATTEMPTING -to;o., COLLECT A DEBT. THIS NOTICE rs 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: SCHOEN, C;WENDOL YN A, GWENDOLYN A. SCHOEN 616 Elford Road Camp H,J!, PA 17011 Your house at 85] Brian Ave, Enola, PA ] 7025 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 $74,51 0.70 obtained by C!TIFINANCIAL SERVICES INe. against yo NOTICE OF OWNER'S RIGHTS YOll .I\:!A Y BE ABLE TO PREVENT THIS SHEJHFF'S SALE To prevent this Sheriffs Sale you must take immediate action: 1, The sale \\'ill hc cancelled if you pay to CITIFINANCIAL SERVICES I:--IC.. the back payme, ts, late charges, costs and reasonable attorney's fees due. To hnd 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 COllrt to strike or openjudgm t, if the judgment \vas improperly entered. Yau may also J.sk the Court to postpone the sale for good cause ,,-, C::;l' => -L- e_ ,f;,; I --.J o -" ---l ::r.:n nl._~ ,-- 7Jl;" '''0 'JrS ~~~!i~ ::.'~r-rl '-.,..... " ..) .< , 04-2115 CIVIL IE 3. You may also be able to stop the sale through other legal proceedings. You may need an attorney to assert your rights. The sooner you contact one, the more chance y u will have of stopping the sale. (See notice below on how to obtain an attorney). YOU MAY STILL BE ABLE TO SAVE YOUR PROPERTY AND YOU HAVE OTHER RIGHT EVEN IF THE SHERIFF'S SALE DOES NOT TAKE PLACE. I. If the Sheriffs Sale is not stopped, your property will be sold to the highest bidder. You may fi d out the price bid price by calling the Sheriff of 717-240-6390. 2. You may be able to petition the Court to set aside the sale if the bid price was grossly inadequ e 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 d out if this has happened, you may call the Sheriffof717-240-6390. 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 t e Sheriff gives a deed to the buyer. At that time, the buyer may bring legal proceedings to evict you. 6. You may be entitled to a share of the money which was paid for your house. A schedule of distribution of the money bid for your house will be filed by the Sheriff thirty (30) days from the date the Sheriffs Sale. This schedule will state who will be receiving that money. The money will be paId out' accordance with this schedule unless exceptions (reasons why the proposed distribution is wrong) are led 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 BELO TO FIND OUT WHERE YOU CAN GET LEGAL HELP, LEGAL SERVICES INC 8 Irvine Row Carlisle, I' A 17013 CUMBERLAND COUNTY BAR ASSOCIATION 2 Liberty Avenue Carlisle,PA 17013 SHORT DESCRIPTION IMPROVEMENTS consist of a residential dwelling. BEING PREMISES: 851 Brian Ave Enola, PA 17025 SOLD as the property of GWENDOLYN A. SCHOEN TAX PARCEL #09-12-2992-00IA-U985 1-5 WRIT OF EXECUTION an~/or ATTACHMENT COMMONWEALTH OF PENNSYLVANIA) COUNTY OF CUMBERLAND) NO 0 4-2115 Civil CIVIL ACTION - LAW TO THE SHERIFF OF CUMBERLAND COUNTY: To satisfy the debt, interest and costs due CITlFINANCIAL SERVICES INC Plaintiff (s) From GWENDOLYN A. SCHOEN, 851 BRIAN AVENUE, ENOLA, PA 17025 (I) You are directed to levy upon the property ofthe defendant (s)and to sell REAL ESTATE LOCATED AT: 851 BRIAN AVENUE, ENOLA, PA 17025 (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 fr m paying any debt to or for the acconnt of the defendant (s) and from delivering any property of the defen ant (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 him/her that he/she has been added a a garnishee and is enjoined as above stated. Amount Due $74,510.70 Interest FROM 9/6/03 TO 7/2/04 AT 10.5000% Atty's Comm L.L..50 % Due Prothy $1.00 Other Costs Atty Paid $151.70 Plaintiff Paid Date: 7/8/04 CURTIS R. LONG (Seal) 7 I '1 /oq By: C1 REQUESTING PARTY: Name JOSEPH A. GOLDBECK, JR Address: SUITE 500 - THE BOURSE BLDG 111 S. INDEPENDENCE MALL EAST PHILADELPHIA, PA 19106 Attorney for: PLAINTIFF Telephone: (215) 627-1322 Supreme Court 1D No. 16132 Real Estate Sale #09 On August 20,2004 the Sheriff levied upon the defendant's interest in the real property situated in East Pennsboro Township, Cumberland County, P A Known and numbered as 851 Brian Ave., Enola, more fully described on Exhibit "A" Date: August 20, 2004 By: d~, k/J, Real Estate Deputy % a::> ~ ~\ filed with this writ and by this reference incorporated herein. ( I '1/\ l ^ S !l H :3 d -l';"f^ f;') 1.1; ":(' Z ,:j lis ..H. 8 lnr Ai!,,' ;;liUI~: ..." " ) :u l :,;jjO " REAL ESTATE SALE No. 09 Writ No. 2004-2115 Civil Term CltlfjnanciaJ Services, Inc. Vs Gwendolyn A. Schoen Ally: Joseph Goldbeck DESCRIPTION . AlL 11lA:r CElU'A1N unit in the property known, named and identilied in the Declan1ion Plan, refem:d to belG:i, as Westwood Village Condominium locatid in East Pennsboro Townsbip, Comberland County, PellIl8)'lvani~ which bas beretofore been submitted to the provisions of the Unit Property Act of Pennsylvania, Act of July 3, 1963, Pi. 196, by the recording in the Office of the ReronIer of ile<ds of Cumberland County. Pennsylvania, of a Declaration Creating and Establishing Westwood Village Coodominiom dated Janoary 29, 1975, andrec<mled on Janoary 29, 1975, io Misc. Book 213, )'age 283, and amended by a certain FJISt Amendmeot to Declaration Creating and Establishing Westwood Village Condominiom dated M>y 28, 1976,and rec<mled on June 22, 1976. in Misc. Book 222, Page 729, and a certain Seroml iI_dmen, 10 Declaration Creating and Establishing Westwood Village Condominiom , dated July 21, 1976. and reconled on July 26, 1976, in Misc. Book 223, Page 343. and a certain Third Amendment to Declaration Creating and Establishing Westwood Village Condominium dated Jone 9, 1978, ,\1d recorded on 1une 23, 1978, io Mise. Book 236. Page 225, and a certain Fonrtb Amendment to Declan1ion Creating and Establishing Westwood Village Condominium dated June 13, 1978, and recorded on June 23, 1978. in Misc. Book 236, Page 250, and ,certain Efth Amendment to Declan1ion Creating and Establishing Westwood Village Condominiom dated Janoary 9, 1979 and recoI1Ied on Janoary 23, 1979, in Misc. Book 240. Page 884, and , certain Sinh Amendment to Declan1ion Cleating and, Establishing Westwood Village Condominium dated MaIcb 1, 1979, and rec<mled MaIcb 12, 1979, in Misc. Book 241, Page 836, and a Code of . Regulations of Westwood Village Condominium dated Jannary 29, 1975, and rec<mled on Janoary 29, 1975, in Misc. Book 213, Page 328. and amended by a certain FJISt Amendment to Code of Regulations of Westwood Village Condominiom, dated May 28, 1976. and rec<mled on June 22, 1976, in Misc. Book 222. )'age 737, and Decbastion Plan of Westwood Village Condominium dated Jannary 29, 1975, and rec<mled on January 29, 1975 in Plan Book 26, )'age 15. and amended by a certain FlfSt Amendment to Decbastion Plan of Westwood VIiJJlge Condomininm dated July 2], 1976, and rec<mled on July 26, 1976, in Plan Book 28, Page 72, and amended by a certain Second Amendment to Declaration Plan of Westwood Village Condominium dated June 16, 1978, and rec<mled on Jtine 23, J978, in Plan Book 33. )'age 28, and amended by a certain Third Amendment to DeclMation Plan of Westwood V~lage Condominium. dated Janoary 9, ,1979, and re- corded Janoary 23, 1979, in Plan Book 34, Page , 100, and amended by a certain Fonrtb Amendment to Declan1ion Plan of Westwood Vill>ge Condominium dated March 1. 1979, and recorded MaIcb 12, 1979. in Plan Book 35, Page 3, being designated on said DecillJation Plan of Westwood Village Condominium as Unit No. 85], Snite 123. 123-1'2 in .Block #5, Building jj<), ]mown as 851 Brian Drive, Soite 123, Enol~ Comberland Coonly, Pennsylvania, as more folly described in such Declaratioo Plan and Declaration Creating and Establishing Westwood V1l1age Condominium. as the same aP.JlWS of ,JtCjmI as set forth above, incloding any laniet1dments thereto, TOGE11IER with . II I proportionate. ondivided ~ in the Common ; , Elements (as defined in such Decbastion) of Seven Hondred Seventy-two Thousandths Percent (.772%). THE PATRIOT NEWS THE SUNDAY PATRIOT NEWS Proof of Publication Under Act No. 587, Approved May 16, 1929 Commonwealth of Pennsylvania, Connty of Dauphin} ss Michael Morrow, being duly sworn according to law, deposes and says: That he is the Controller of The Patriot News Co., a corporation organized and existing under the la s of the Commonwealth of Pennsylvania, with its principal office and place of business at 812 to 818 Market Stre t, in the City of Harrisburg, County of Dauphin, State of Pennsylvania, owner and publisher of The Patriot-News d The Sunday Patriot-News newspapers of general circulation, printed and published at 812 to 818 Market Street, i the City, County and State aforesaid; that The Patriot-News and The Snnday Patriot-News were established Mar 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 pu ished in their regular daily and/or Sunday! Metro editions which appeared on the 19th and 26th day(s) of October Id the 2nd day(s) of November 2004. That neither he nor said Company is interested in the subject matter of said p inted notice or advertising, and that all of the allegations of this statement as to the time, place and character of pu lication are true; and That he has personal knowledge of the facts aforesaid and is duly authorized and empowered to ver y this statement on behalf of The Patriot-News Co. aforesaid by virtue and pursuant to a resolution unanimously p sed and adopted severally by the stockholders and board of directors of the said Company and subsequently dul recorded in the office for the Recording of Deeds in and for said County of Dauphin in Miscellaneous Book 'M", Volume 14, Page 317. COPY SALE#9 Sworn to and subscribed befor NOlARlAL SEAl Teuy l. Russell, Nolary Oly of Harrisburg, Doup . My Commission Expires June 6, 20CllS1 Mernb.r,P.nnsylvanlaA..oel..tM,f~iEsion explres June 6, 2006 PUBLICATION REAL J:5TATI: aAU: NVo 08' ;:'It .2004-2115 IvI'T_ Cltlllnan I Servlce&, Inc. v. lynA._ Ally: ph Goldbeck DESCRII'TlON f CUMBERLAND COUNTY SHERIFFS OFFICE CUMBERLAND COUNTY COURTHOUSE CARLISLE, PA. 17013 AlL nw: CflUAlN unit in the JlIOP"IY . knOwn. named and identified in the Declaration Plan. rete=! '" bel... " W_ood vill>ge Condominium locate<! in East Pennsbmu Township, Cumberl3nd Cmmty. Pennsytvama. which has heretofore been submitted to the provisions of the Unit_,Act of Pennsylv.mi~ Act ofluly 3. 1<)6). PL. 196, by the recooIing in the Office of the R<oonler of , Deeds of Cuinhelhnd County, Pennsylvania, of a ~~oo CreaIing aod ~Iisbiogw':"mt Publisher's Receipt for Advertising Cost ~~e~., publisher of The PatrIot-News and The Sunday PatrIOt-News, newspapers ofgener circulation, hereby acknowledge receipt of the aforesaid notice and publication costs and certifies that the been duly paid, Statement of Advertising Costs To THE PATRIOT-NEWS CO. For publishing the notice or publication attached hereto on the above stated dates 463.27 arne have By....,..................... '.",........,........' ..,....',..,..... . Condom1n1umdatedMarch 1. 1979, and recorded March 12. 1979. in Misc. Book 241, Page 836. and a Code of Regulations of Westwood VUlage Condominium dated Janu- ary 29, 1975. and recorded on Jan- uary 29, 1975. in Misc. Book 213, Page 328. and amended by a cer- tain First Amendment to Code of Regulations of Westwood Village I CondominJurn, dated May 28, 1976. and recorded on June 22. 1976, in Misc. Book 222. Page 737. and Declaration Plan of Westwood Vil- lage Condominium dated January 29. 1975. and recorded on Janu- ary 29 1975 in Plan Book 26, Page' 15. and amended by a certain First Amendment to Declaration Plan of Westwood Village Condominium dated July 21. 1976. and recorded on July 26, 1976, In Plan Book 28. Page 72, and amended by a certain I Second Amendment to Declaration I Plan of Westwood Village. Condo- I minium dated June 16, 1978. and recorded on June 23. 1978. in Plan Book 33, Page 28. and amended by a certain Third Amendment to Decla- ration Plan of Westwood Village Con- dominium dated JanuIDy 9, 1979, and recorded January 23, 1979, in Plan Book 34. Page 100, and amend- ed by a certain Fourth Amendment to Declaration Plan of Westwood VUlage Condominium dated March 1, 1979, and recorded March 12, 1979, In Plan Book 35. Page 3, be- ing designated on said Declaration Plan of Westward Village Condomin~ iurn as DnJt No. 851. Suite 123, L23- F2 In Block #5, Building #9. known as 851 Brian Drive, Suite 123, Eno~ la, Cumberland County. Pennsylva- nia. as more fully described in such Declaration Plan and Declaration Creating and EstabHshingWestwood Village Condominium. as the same appears of record as set forth above. including any amendments thereto, TOGETHER with a proportionate un- divided interest in the Common El- ements (as defined in such Declara- tion) of Seven Hundred Seventy~two Thousandths Percent (,772%). REAL ESTATE SALE NO. 9 Writ No. 2004-21l5 Civil Citlfinanclal Services, Inc. vs. Gwendolyn A. Schoen Atty.: Joseph Goldbeck ALL THAT CERTAIN unJt in the property known, named and identi- fied in the Declaration Plan, referred to below as Westwood Village Con- I dominium located in East Pennsboro : Township, Cumberland County. Pennsylvania, which has heretofore been submitted to the provisions of the DnJt Property Act of pennsylva- nla, Act of July 3. 1963. P.L. 196, by the recording in the Office of the Recorder of Deeds of Cumberland County, Pennsylvania. of a Decla~ ration Creating and Establishing Westwood Village Condominium dated January 29. 1975. and re- corded' on January 29, 1975, in Misc. Book 213, Page 283, and amended by a certain First Amend~ ment to Declaration Creating and Establishing Westwood Viliage Con- dominJurn dated May 28. 1976. and , recorded on June 22, 1976. 1n Misc. Book 222. Page 729, and a certain ! Second Amendment to Declaration L Creating and Establishing Westwood ( Village Condominium dated July 21. ] 976. and recorded on July 26, , 1976. In Misc. Book 223. Page 343, i and a certain Third Amendment to Declamation Creating and Establish- ing Westwood Village Condominium dated June 9, 1978, and recorded on June 23. 1978, in Misc. Book 236, Page 225, and a certain Fourth Amendment to Declaration Creating and Establishfng Westwood Village Condominium dated June 13. 1978. and recorded on June 23. ] 978. in MIsc. Book 236. Page 250, and a certain Firth Amendment to Decla- ration Creating and Establishing Westwood Village Condominium dated January 9, 1979 and recorded on January 23, 1070, in Misc. Book 240, Page 884. and a certain Sixth Amendment to Declaration Creating and Establishing Westwood Village \ \ \