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Home My WebLink About09-4987di GOLDBECK McCAFFERTY & McKEEVER BY: MICHAEL T. MCKEEVER ATTORNEY I.D. #56129 SUITE 5000 - MELLON INDEPENDENCE CENTER 701 MARKET STREET PHILADELPHIA, PA 19106 (866) 413-2311 WWW.GOLDBECKLAW.COM CITIMORTGAGE INC. F/K/A ASSOCIATES HOME EQUITY CDC INC. 1000 Technology Drive MS 730 O'Fallon, MO 63368-2240 Plaintiff vs. DONNA A. HARPER Record Owner SARAH G. HARPER Mortgagor HARRIET D. SPRAGLIN A/K/A HARRIET D. HARPER Record Owner and Mortgagor 221 South Penn Street Shippensburg, PA 17257 Defendants IN THE COURT OF COMMON PLEAS OF Cumberland COUNTY CIVII, ACTION - LAW ACTION OF MORTGAGE FORECLOSURE Term C, /VI i No. h I- VO7 CIVIL /ACTION: MORTGAGE FOREIfLOSURE NOTICE You have been sued in court. If you wish to defend against the claims set forth in the following pages, you must take action within twenty (20) days after the Complaint and notice are served, by entering a written appearance personally or by attorney and filing in writing with the court your defenses or objections to the claims set forth against you. You are warned that if you fail to do so the case may proceed without you and a judgment may be entered against you by the Court without further notice for any money claim in the Complaint of for any other claim or relief requested by the Plaintiff. You may lose money or property or other rights important to you. YOU SHOULD TAKE THIS PAPER TO YOUR LAWYER AT ONCE. IF YOU DO NOT HAVE A LAWYER OR CANNOT AFFORD ONE, GO TO OR TELEPHONE THE OFFICE SET FORTH BELOW. THIS OFFICE CAN PROVIDE YOU WITH INFORMATION ABOUT HIRING A LAWYER. IF YOU CANNOT AFFORD TO HIRE A LAWYER, THIS OFFICE MAY BE ABLE TO PROVIDE YOU WITH INFORMATION ABOUT AGENCIES THAT MAY OFFER LEGAL SERVICES TO ELIGIBLE PERSONS AT A REDUCED FEE OR NO FEE. CUMBERLAND COUNTY BAR ASSOCIATION 2 Liberty Avenue Carlisle, PA 17013 LEGAL SERVICES INC 8 Irvine Row Carlisle, PA 17013 717-243-9400 AVISO LE HAN DEMANDADO A USTED EN LA CORTE. SI DESEA DEFENDERSE CONTRA LAS QUEJAS PERESENTADAS, ES ABSOLUTAMENTE NECESSARIO QUE USTED RESPONDA DENTRO DE 20 DIAS DESPUES DE SER SERVIDO CON ESTA DEMANDA Y AVISO. PARA DEFENDERSE ES NECESSARIO QUE USTED, O SU ABOGADO, REGISTRE CON LA CORTE- EN FORMA ESCRITA, EL PUNTO DE VISTA DE USTED Y CUALQUIER OBJECCION CONTRA LAS QUEJAS EN ESTA DEMANDA. RECUERDE: SI USTED NO REPONDE A ESTA DEMANDA, SE PUEDE PROSEGUIR CON EL PROCESO SIN SU PARTICIPACION. ENTONCES, LA COUTE PUEDE, SIN NOTIFICARIO, DECIDIR A FAVOR DEL DEMANDANTE Y REQUERIRA QUE USTED CUMPLA CON TODAS LAS PROVISIONES DE ESTA DEMANDA. POR RAZON DE ESA DECISION, ES POSSIBLE QUE USTED PUEDA PERDER DINERO, PROPIEDAD U OTROS DERECHOS IMPORTANTES. USTED DEBE LLEVAR ESTE PAPEL A SU ABOGADO ENSEGUIDA. SI USTED NO TIENE UN ABOGADO, VAYA O LLAME POR TELEFONO LA OFICINA FIJADA AQLII ABAJO. ESTA OFICINA PUEDE PROVEERE CON INFORMACION DE COMO CONSEUIR UN ABOGADO. SI USTED NO PUEDE PAGARLE A UN ABOGADO, ESTA OFICINA PUEDE PROVEERE INFORMACION ACERCA AGENCIAS QUE PUEDAN OFRECER SERVICIOS LEGAL A PERSONAS ELIGIBLE AQ UN HONORARIO REDUCIDO O GRATIS. CUMBERLAND COUNTY BAR ASSOCIATION 2 Liberty Avenue Carlisle, PA 17013 LEGAL SERVICES INC 8 Irvine Row Carlisle, PA 17013 717-243-9400 THIS FIRM IS A DEBT COLLECTOR AND WE ARE ATTEMPTING TO COLLECT A DEBT OWED TO OUR CLIENT. ANY INFORMATION OBTAINED FROM YOU WILL BE USED FOR THE PURPOSE OF COLLECTING THE DEBT Resources available for Homeowners in Foreclosure ACT NOW! Even though your lender (and our client) has filed an Action of Mortgage Foreclosure against you, you still may be able to SAVE YOUR HOME FROM FORECLOSURE. 1). Call an attorney. For referrals to a qualified attorney call either of the following numbers: or 717- 243-9400. 2). Call the Consumer Credit Counseling Agency at 1-800-989-2227 for free counseling. 3). Visit HUD'S website www.hud.g_ov for Help for Homeowners Facing the Loss of Their Homes. 4). Pennsylvania Housing Finance Agency also offers other loan programs that may assist homeowners in default. Please See the PHFA website hqp://www.t)hfa.org/consumers/homeowners/real.aspx. 5). Call the Plaintiff (your lender) and ask to speak to someone about Loss Mitigation or Home Retention options. 6). Foreclosure Resource Center: ht :/tp /www.philadelphiafed.org,/foreclosure/ 7). Call or contact our office to request the amount to bring the account current, or payoff the mortgage or request a Loan Workout / Home Retention Package. Call our toll free number at 1-866-413-2311 or via email at homeretention@goldbecklaw.com. Call Seth at 215-825-6329 or fax 215-825-6429. The figure and/or package you requested will be mailed to the address that you request or faxed if you leave a message with that information. The attorney in charge of our firm's Homeowner Retention Department is David Fein who can be reached at 215-825-6318 or Fax: 215-825-6418. Please reference our Attorney File Number of 7717617C. Para informacion en espanol puede communicarse con Loretta al 215-825-6344. This Action of Mortgage Foreclosure will continue unless you take action to stop it. COMPLAINT IN MORTGAGE FORECLOSURE 1. Plaintiff is CITIMORTGAGE INC. F/K/A ASSOCIATES HOME EQUITY CDC INC., 1000 Technology Drive, MS 730 O'Fallon, MO 63368-2240. 2. The names and addresses of the Defendants are DONNA A. HARPER, 221 South Penn Street, Shippensburg, PA 17257 who is a record owner, SARAH G. HARPER, 221 South Penn Street, Shippensburg, PA 17257 who is a mortgagor of mortgaged premises and HARRIET D. SPRAGLIN A/K/A HARRIET D. HARPER, 110 Britton Road, Shippensburg, PA 17257, who is a record owner and mortgagor of the mortgaged premises hereinafter described. DORIS HARPER died on 03/09/2007 by operation of law title vests solely in DONNA A. HARPER, HARRIET D. SPRAGLIN A/K/A HARRIET D. HARPER, AND SARAH G. HARPER and DORIS HARPER is hereby released of liability pursuant to Pa.R.C.P. 1144. 3. On May 17, 2000 mortgagors made, executed and delivered a mortgage upon the Property hereinafter described to ASSOCIATES HOME EQUITY CONSUMER DISCOUNT COMPANY, INC., which mortgage is recorded in the Office of the Recorder of Deeds of Cumberland County as Book 1613 Page 1131. The Mortgage and assignment(s) are matters of public record and are incorporated by this reference in accordance with Pennsylvania Rule of Civil Procedure 1019(g); which Rule relieves the Plaintiff from its obligation to attach documents to pleadings if those documents are matters of public record. 4. The Property subject to the Mortgage is more fully described in the legal description set forth as Exhibit "A" ("Property"). 5. The mortgage is in default because the monthly payments of principal and interest are due and unpaid for June 01, 2008 and each month thereafter and by the terms of the Mortgage, upon default in such payments for a period of one month or more, the entire principal balance and all interest due and other charges are due and collectible. 6. The following amounts are due to Plaintiff on the Mortgage: Principal Balance ....................................................................................$68,420.77 Interest from 05/01/2008 through 06/30/2009 at 11.5900% ...................$10,547.54 Per Diem interest rate at $21.73 Reasonable Attorney's Fee at 5% of Principal Balance as more fully explained in the next numbered paragraph ...................$3,421.04 Costs of suit and Title Search ......................................................................$900.00 Delinquent Expense Total ........................................................................ .....$755.23 Servicing Fees ................................................................................................$47.00 $84,091.58 7. If the Mortgage is reinstated prior to a Sheriff's Sale, the Attorney's Fees set forth above may be less than the amount demanded based on work actually performed. The Attorney's Fees requested are in conformity with the Mortgage and Pennsylvania law. Plaintiff is entitled to collect Attorney's fees of up to 5% of the remaining principal balance in the event the Property is sold to a third party purchaser at Sheriff's Sale or if the complexity of the action requires additional fees in excess of the amount demanded in the Action. 8. Plaintiff is not seeking a judgment of personal liability (or an "in personam" judgment) against the Defendants in this Action but reserves its right to bring a separate Action to establish that right, if such right exists. If Defendants have received a discharge of their personal liability in a Bankruptcy proceeding, this Action of Mortgage Foreclosure is, in no way, an attempt to re-establish the personal liability that was discharged in Bankruptcy, but only to foreclose the Mortgage and sell the Property pursuant to Pennsylvania law. 9. Notice of Intention to Foreclose and a Notice of Homeowners' Emergency Mortgage Assistance has been sent to Defendants by certified and regular mail, as required by Act 160 of 1998 of the Commonwealth of Pennsylvania, on the date(s) set forth in the true and correct copy of such notice(s) attached hereto as Exhibit "B". The Defendants have not had the required face-to-face meeting within the required time and Plaintiff has no knowledge of any such meeting being requested by the Defendants through the Plaintiff, the Pennsylvania Housing Finance Agency, or any appropriate Consumer Credit Counseling Agency. WHEREFORE, Plaintiff demands a de terris judgment in mortgage foreclosure in the sum of $84,091.58, together with interest at the rate of $21.73, per day and other expenses, costs and charges incurred by the Plaintiff which are properly chargeable in accordance with the terms of the Mortgage and Pennsylvania law until the Mortgage is paid in full, and for the foreclosure of the Mortgage and Sheriff's Sale of the Property. By: U8U I T 4. A CLU- Z GOLDBECK McCAFFERTY & Mc + EVER BY: MICHAEL T. MCKEEVER, ESQUIRE ATTORNEY FOR PLAINTIFF y VERIFICATION I, Eddie Crespo, Assistant Vice President, as the representative of the Plaintiff corporation within named do hereby verify that I am authorized to and do make this verification on behalf of the Plaintiff corporation and the facts set forth in the foregoing Complaint are true and correct to the best of my knowledge, information and belief. I understand that false statements therein are made subject to the penalties of 18 Pa. C.S. 4904 relating to unworn falsification to authorities. Date: 6/25/09 ?2'?2? - Eddie Crespo, Assistant Vice President #77176FC - DONNA A. HARPER, DORIS A. HARPER, SARAH G. HARPER and HARRIET D. SPRAGLIN A/K/A HARRIET D. HARPER 221 South Penn Street Shippensburg, PA 17257 E..x.hibitA All that certain parcel of land situated in Shippensburg Borough, Cumberland County, Pennsylvania, and being more fully described in Deed Book 121, page 1068, et seq., recorded on May 10, 1995, among the land records of Cumberland County, Pennsylvania. AU TEAT Oertein ttad of wo and mth a framt dqoUlag houst and other itap ovemem cmcttd tbown, 4tuaute in the Rotough of 94rpm*M& Caauty of Qw and CmunoMvesft of PmM bouux and de wft od as &livwsr WWV4NWG at a feat post a tilts add tit tt prtblk 4* where it mute ft I%W of--way of the R=*9 Cam, sad opVOft lmmd Dow Or fe y Of*o John HodW Rear,; thenca ttarthWW* on the V/C t sick of saw silty; (63) fe'd po (117} bw)m to a ttRw in the saldtlie of sn i t,g pdtrate shay; tbM vveAww$ly by the eniddk of said private Y, one wed (110) fm six 0* ine6" to a, alWI:', 6 the middle of Mid alloy; thewe by it fine skeg a bamdtty fam to it fie poet, it corner on edge of the ngbt-uO ? of the said R=ding Comp, dwift d?y by the said right-O wly, tweh- (12) tbet mm " 1 s to a aeaali am dose to the fence; theme co o cwwsray V41h tC MW &MW 866 1. dot-of ,ay IWOWg Wt1W9 Mdhw rd. $t?m the lowd tree, *w huAed (100) feet to tho fence tom. the plaoc of BEGE4WG, TOGRT wig the right to u a private easy extending *keg the North side of tits p+om pd't]+" Lbe said pubije agcy wta%wdy to to watwn iii of the pnopeq 2nd tltenoe S and tiIWUgb at$et property to l Surat In ft said Romugh of M*pemburg. 71z use of this private Alley is in cow== with the use ofthe same by ode adj oinhW it, For information only, the property is commonly known as 221 South Penn Street, Shippensburg Borough, Cumberland County, Pennsylvania, and erroneously designated as 4788 Sweetbriar Drive, Harrisburg, Cumerland County in the mortgage recorded May 24, 2000 in Deed Book 1613, at page 1131, et seq. ?B REPRESENTATION OF PRINTED DOCUMENT 1120291912 c ti mortgage 06/02/09 90957 005790 HARRIET D SPRAGLIN SARAH G SPRAGLIN 110 BRITTON RD SHIPPENSBURG PA 17257-9703 7107 8381 6540 0979 7424 RE: CitiMortgage Loan #: 1120291912 ACT 91 NOTICE TAKE ACTION TO SAVE YOUR HOME FROM FORECLOSURE This is an official notice that default, and the lender intends about the nature of the default The HOMEOWNER'S EMERGENCY MORTG, able to help to save your home. works. the mortgage on your home is in to foreclose. Specific information is provided in the attached pages. 4GE ASSISTANCE PROGRAM (HEMAP) may be This Notice explains how the program To see if HEMAP can help, you must MEET WITH A CONSUMER CREDIT COUNSELING AGENCY WITHIN 33 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 may 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 Consumer Credit Counseling Agency may be able to help explain it. You may also want to contact an attorney in your area. The local bar association may be able to help you find a lawyer. LA NOTIFICACION EN ADJUNTO ES DE SUMA IMPORTANCIA, PUES AFECTA SU DERECHO A CONTINUAR VIVIENDO EN SU CASA. SI NO COMPRENDE EL CONTENIDO DE ESTA NOTIFICACION OBTENGA UNA TRADUCCION INMEDIATAMENTE LLAMANDO ESTA AGENCIA (PENNSYLVANIA HOUSING FINANCE AGENCY) SIN CARGOS AL NUMERO MENCIONADO ARRIBA. PUEDES SER ELEGIBLE PARA UN PRESTAMO POR EL PROGRAMA LLAMADO "HOMEOWNER'S EMERGENCY MORTGAGE ASSISTANCE PROGRAM" EL CUAL PUEDE SALVAR SU CASA DE LA PERDIDA DEL DERECHO A REDIMIR SU HIPOTECA. 0 a CitiMortgage, Inc. does business as Citicorp Mortgage in NM. INTERNET REPRINT REPRESENTATION OF PRINTED DOCUMENT 1120291912 c ti mortgage Page Two 06/02/09 1120291912 HOMEOWNER'S NAME(S): Harriet D Spraglin Sarah G Spraglin PROPERTY ADDRESS: 221 S. Penn St Shippensburg,PA 17257 LOAN ACCT. NO.: 1120291912 ORIGINAL LENDER: Associates Home Equity CURRENT LENDER/SERVICER: CitiMortgage, Inc. is providing this notice as lender or servicing agent for the lender. HOMEOWNER'S EMERGENCY MORTGAGE ASSISTANCE PROGRAM YOU MAY BE ELIGIBLE FOR FINANCIAL ASSISTANCE WHICH CAN SAVE YOUR HOME FROM FORECLOSURE AND HELP YOU MAKE FUTURE MORTGAGE PAYMENTS. IF YOU COMPLY WITH THE PROVISIONS OF THE HOMEOWNER'S EMERGENCY MORTGAGE ASSISTANCE ACT OF 1983 (THE "ACT"), YOU MAY BE ELIGIBLE FOR EMERGENCY MORTGAGE ASSISTANCE: * IF YOUR DEFAULT HAS BEEN CAUSED BY CIRCUMSTANCES BEYOND YOUR CONTROL, * IF YOU HAVE A REASONABLE PROSPECT OF BEING ABLE TO PAY YOUR MORTGAGE PAYMENTS, AND * IF YOU MEET OTHER ELIGIBILITY REQUIREMENTS ESTABLISHED BY THE PENNSYLVANIA HOUSING FINANCE AGENCY. TEMPORARY STAY OF FORECLOSURE-Under the Act, you are entitled to a temporary stay of foreclosure on your mortgage for thirty (30) days from the date of this Notice (plus three (3) days for mailing). During that time you must arrange and attend a "face-to-face" meeting with one of the consumer credit counseling agencies listed at the end of this Notice. THIS MEETING MUST OCCUR WITHIN THIRTY-THREE (33) DAYS OF THE DATE OF THIS NOTICE. 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. 0 O CitiMortgage, Inc. does business as Citicorp Mortgage in NM. INTERNET REPRINT REPRESENTATION OF PRINTED DOCUMENT 1120291912 c ti mortgage Page Three 06/02/09 1120291912 CONSUMER CREDIT COUNSELING AGENCIES-If you meet with one of the consumer credit counseling agencies listed at the end of this notice, the lender may NOT take action against you for thirty (30) days after the date of this meeting. The names, addresses and telephone numbers of designated consumer credit counseling agencies for the county in which the property is located are set forth at the end of this Notice. It is only necessary to schedule one face-to-face meeting. Advise your lender immediately of your intentions. APPLICATION FOR MORTGAGE ASSISTANCE-Your mortgage is in default for the reasons set forth later in this Notice (see following pages for specific information about the nature of your default). You have the right to apply for financial assistance from the Homeowner's Emergency Mortgage Assistance Program. To do so, you must fill out, sign and file a completed Homeowner's Emergency Assistance Program Application with one of the designated consumer credit counseling agencies listed at the end of this Notice. Only consumer credit counseling agencies have applications for the program and they will assist you in submitting a complete application to the Pennsylvania Housing Finance Agency. To temporarily stop the lender from filing a foreclosure action, your application MUST be forwarded to PHFA within thirty (30) days of your face-to-face meeting with the counseling agency. YOU SHOULD FILE A HEMAP APPLICATION AS SOON AS POSSIBLE. IF YOU HAVE A MEETING WITH A COUNSELING AGENCY WITHIN 33 DAYS OF THE POSTMARK DATE OF THIS NOTICE AND FILE AN APPLICATION WITH PHFA WITHIN 30 DAYS OF THAT MEETING, THEN THE LENDER WILL BE TEMPORARILY PREVENTED FROM STARTING A FORECLOSURE AGAINST YOUR PROPERTY, AS EXPLAINED ABOVE, IN THE SECTION CALLED "TEMPORARY STAY OF FORECLOSURE". YOU HAVE THE RIGHT TO FILE A HEMAP APPLICATION EVEN BEYOND THESE TIME PERIODS. A LATE APPLICATION WILL NOT PREVENT THE LENDER FROM STARTING A FORECLOSURE ACTION, BUT IF YOUR APPLICATION IS EVENTUALLY APPROVED AT ANY TIME BEFORE A SHERIFF'S SALE, THE FORECLOSURE WILL BE STOPPED. AGENCY ACTION-Available funds for emergency mortgage assistance are very limited. They will be disbursed by the Agency under the eligibility criteria established by the Act. The Pennsylvania Housing Finance Agency has sixty (60) days to make a decision after it receives your application. During that time, no foreclosure proceeding 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 Mortgage Assistance.) u.. O Q K N O n CitiMortgage, Inc. does business as Citicorp Mortgage in NM. INTERNET REPRINT REPRESENTATION OF PRINTED DOCUMENT 1120291912 tc i mortgage Page Four 06/02/09 1120291912 HOW TO CURE YOUR MORTGAGE DEFAULT(Bring it up to date). NATURE OF THE DEFAULT-The MORTGAGE debt held by the above lender on your property located at: 221 S. Penn St„ Shippensburg, PA 17257 IS SERIOUSLY IN DEFAULT because YOU HAVE NOT MADE MONTHLY MORTGAGE PAYMENTS for the following months and the following amounts are now past due: 06/01/08 thru 06/01/09 13 @ $714.40/month O @ $0.00/late charge/month $9,287.20 Previous late charge(s) $0.00 Delinquency Expenses(s) $755.23 TOTAL AMOUNT PAST DUE: $10,,042.43 HOW TO CURE THE DEFAULT-You may cure the default within THIRTY 1;30) DAYS of the date of this notice BY PAYING THE TOTAL AMOUNT PAST DUE TO THE LENDER, WHICH IS $10,042.43, PLUS ANY MORTGAGE PAYMENTS, LATE CHARGES AND DELINQUENCY EXPENSES 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: CitiMortgage, Inc. P.O. Box 689196 Des Moines, IA 50368-9196 IF YOU DO NOT CURE THE DEFAULT-If you do not cure the default within THIRTY (30) DAYS of the date of this Notice, the lender intends to exercise its rights to accelerate the mortgage debt. This means that the entire outstanding balance of this debt will be considered due immediately and you may lose the chance to pay the mortgage in monthly installments. If full payment of the total amount past due is not made within THIRTY (30) DAYS, the lender also intends to instruct its attorneys to start legal action to foreclose upon your mortgaged property. IF THE MORTGAGE IS FORECLOSED UPON-The mortgaged property will be sold by the Sheriff to pay off the mortgage debt. If the lender refers your case to its attorneys, but you cure the delinquency before the lender begins legal proceedings against you, you will still be required to pay the reasonable attorney's fees that were actually incurred, up to $50.00. However, if legal proceedings are started CitiMortgage, Inc. does business as Citicorp Mortgage in NM. INTERNET REPRINT REPRESENTATION OF PRINTED DOCUMENT 1120291912 c ti mortgage` Page Five 06/02/09 1120291912 against you, you will have to pay all reasonable attorney's fees actually incurred by the lender even if they exceed $50.00. Any attorney's fees will be added to the amount you owe the lender, which may also include other reasonable costs. If you cure the default within the THIRTY (30) DAY period, you will not be required to pay attorney's fees. OTHER LENDER REMEDIES-The lender may also sue you personally for the unpaid principal balance and all other sums due under the mortgage. RIGHT TO CURE THE DEFAULT PRIOR TO SHERIFF'S SALE-If you have not cured the default within the THIRTY (30) DAY period and foreclosure proceedings have begun, you still have the right to cure the default and prevent the sale at any time up to one hour before the Sheriff's Sale. You may do so by paying the total amount then past due, plus any late or other charges then due, reasonable attorney's fees and costs connected with the foreclosure sale and any other costs connected with the Sheriff's Sale as specified in writing by the Curing your default in the manner set forth in this notice will restore your mortgage to the same position as if you had never defaulted. EARLIEST POSSIBLE SHERIFF'S SALE DATE-It is estimated that the earliest date that such a Sheriff's Sale of the mortgaged property could be held would be approximately six (6) months from the date of this Notice. A notice of the actual date of the Sheriff's Sale will be sent to you before the sale. Of course, the amount needed to cure the default will increase the longer you wait. You may find out at any time exactly what the required payment or action will be by contacting the lender. HOW TO CONTACT THE LENDER: Name of Lender: CitiMortgage, Inc. Address: 1000 Technology Drive O'Fallon, MO 63368-2240 Phone Number: 1-800-723-7906 Fax Number: 1-636-261-7716 Contact Person: Adam Saab Email Address: ryan.ollier@citi.com CitiMortgage, Inc. does business as Citicorp Mortgage in NM. INTERNET REPRINT REPRESENTATION OF PRINTED DOCUMENT 1120291912 c ti mortgage Page S i x 06/02/09 1120291912 EFFECT OF SHERIFF'S SALE-You should realize that a Sheriff's Sale will end your ownership of the mortgaged property and your right to occupy it. If you continue to live in the property after the Sheriff's Sale, a lawsuit to remove you and your furnishings and other belongings could be started by the lender at any time. ASSUMPTION OF MORTGAGE-Please refer to your original loan documents to determine whether or not you may sell or transfer your home 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 call the 1-800 Number above to find out whether your loan is assumable. 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 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. Enclosure: Consumer Credit Counseling Agencies, including those for your county. 090602D0001181 O O K N O .J CitiMortgage, Inc. does business as Citicorp Mortgage in NM. INTERNET REPRINT REPRESENTATION OF PRINTED DOCUMENT 1120291912 c ti mortgage 7107 8381 6540 0979 7431 06/02/09 90957 005791 HARRIET D SPRAGLIN SARAH G SPRAGLIN 221 S. PENN ST SHIPPENSBURG PA 17257 RE: CitiMortgage Loan #: 1120291912 ACT 91 NOTICE TAKE ACTION TO SAVE YOUR HOME FROM FORECLOSURE This is an official notice that the mortgage on your home is in default, and the lender intends to foreclose. Specific information about the nature of the default is provided in the attached pages. The HOMEOWNER'S EMERGENCY MORTGAGE ASSISTANCE PROGRAM (HEMAP) may be able to help to save your home. This Notice explains how the program works. To see if HEMAP can help, you must MEET WITH A CONSUMER CREDIT COUNSELING AGENCY WITHIN 33 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 may 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 Consumer Credit Counseling Agency may be able to help explain it. You may also want to contact an attorney in your area. The local bar association may be able to help you find a lawyer. LA NOTIFICACION EN ADJUNTO ES DE SUMA IMPORTANCIA, PUES AFECTA SU DERECHO A CONTINUAR VIVIENDO EN SU CASA. SI NO COMPRENDE EL CONTENIDO DE ESTA NOTIFICACION OBTENGA UNA TRADUCCION INMEDIATAMENTE LLAMANDO ESTA AGENCIA (PENNSYLVANIA HOUSING FINANCE AGENCY) SIN CARGOS AL NUMERO MENCIONADO ARRIBA. PUEDES SER ELEGIBLE PARA UN PRESTAMO POR EL PROGRAMA LLAMADO "HOMEOWNER'S EMERGENCY MORTGAGE ASSISTANCE PROGRAM" EL CUAL PUEDE SALVAR SU CASA DE LA PERDIDA DEL DERECHO A REDIMIR. SU HIPOTECA. CitiMortgage, Inc. does business as Citicorp Mortgage in NM. INTERNET REPRINT REPRESENTATION OF PRINTED DOCUMENT 1120291912 c ti mortgage Page Two 06/02/09 1120291912 HOMEOWNER'S NAME(S): Harriet D Spraglin Sarah G Spraglin PROPERTY ADDRESS: 221 S. Penn St Shippensburg,PA 17257 LOAN ACCT. NO.: 1120291912 ORIGINAL LENDER: Associates Home Equity CURRENT LENDER/SERVICER: CitiMortgage, Inc. is providing this notice as lender or servicing agent for the lender. HOMEOWNER'S EMERGENCY MORTGAGE ASSISTANCE PROGRAM YOU MAY BE ELIGIBLE FOR FINANCIAL ASSISTANCE WHICH CAN SAVE YOUR HOME FROM FORECLOSURE AND HELP YOU MAKE FUTURE MORTGAGE PAYMENTS. IF YOU COMPLY WITH THE PROVISIONS OF THE HOMEOWNER'S EMERGENCY MORTGAGE ASSISTANCE ACT OF 1983 (THE "ACT"), YOU MAY BE ELIGIBLE FOR EMERGENCY MORTGAGE ASSISTANCE: * IF YOUR DEFAULT HAS BEEN CAUSED BY CIRCUMSTANCES BEYOND YOUR CONTROL, * IF YOU HAVE A REASONABLE PROSPECT OF BEING ABLE TO PAY YOUR MORTGAGE PAYMENTS, AND * IF YOU MEET OTHER ELIGIBILITY REQUIREMENTS ESTABLISHED BY THE PENNSYLVANIA HOUSING FINANCE AGENCY. TEMPORARY STAY OF FORECLOSURE-Under the Act, you are entitled to a temporary stay of foreclosure on your mortgage for thirty (30) days from the date of this Notice (plus three (3) days for mailing). During that time you must arrange and attend a "face-to-face" meeting with one of the consumer credit counseling agencies listed at the end of this Notice. THIS MEETING MUST OCCUR WITHIN THIRTY-THREE (33) DAYS OF THE DATE OF THIS NOTICE. 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. CitiMortgage, Inc. does business as Citicorp Mortgage in NM. INTERNET REPRINT REPRESENTATION OF PRINTED DOCUMENT 1120291912 c ti mortgage Page Three 06/02/09 1120291912 CONSUMER CREDIT COUNSELING AGENCIES-If you meet with one of the consumer credit counseling agencies listed at the end of this notice, the lender may NOT take action against you for thirty (30) days after the date of this meeting. The names, addresses and telephone numbers of designated consumer credit counseling agencies for the county in which the property is located are set forth at the end of this Notice. It is only necessary to schedule one face-to-face meeting. Advise your lender immediately of your intentions. APPLICATION FOR MORTGAGE ASSISTANCE-Your mortgage is in default for the reasons set forth later in this Notice (see following pages for specific information about the nature of your default). You have the right to apply for financial assistance from the Homeowner's Emergency Mortgage Assistance Program. To do so, you must fill out, sign and file a completed Homeowner's Emergency Assistance Program Application with one of the designated consumer credit counseling agencies listed at the end of this Notice. Only consumer credit counseling agencies have applications for the program and they will assist you in submitting a complete application to the Pennsylvania Housing Finance Agency. To temporarily stop the lender from filing a foreclosure action, your application MUST be forwarded to PHFA within thirty (30) days of your face-to-face meeting with the counseling agency. YOU SHOULD FILE A HEMAP APPLICATION AS SOON AS POSSIBLE. IF YOU HAVE A MEETING WITH A COUNSELING AGENCY WITHIN 33 DAYS OF THE POSTMARK DATE OF THIS NOTICE AND FILE AN APPLICATION WITH PHFA WITHIN 30 DAYS OF THAT MEETING, THEN THE LENDER WILL BE TEMPORARILY PREVENTED FROM STARTING A FORECLOSURE AGAINST YOUR PROPERTY, AS EXPLAINED ABOVE, IN THE SECTION CALLED "TEMPORARY STAY OF FORECLOSURE". YOU HAVE THE RIGHT TO FILE A HEMAP APPLICATION EVEN BEYOND THESE TIME PERIODS. A LATE APPLICATION WILL NOT PREVENT THE LENDER FROM STARTING A FORECLOSURE ACTION, BUT IF YOUR APPLICATION IS EVENTUALLY APPROVED AT ANY TIME BEFORE A SHERIFF'S SALE, THE FORECLOSURE WILL BE STOPPED. AGENCY ACTION-Available funds for emergency mortgage assistance are very limited. They will be disbursed by the Agency under the eligibility criteria established by the Act. The Pennsylvania Housing Finance Agency has sixty (60) days to make a decision after it receives your application. During that time, no foreclosure proceeding 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 Mortgage Assistance.) CitiMortgage, Inc. does business as Citicorp Mortgage in NM. INTERNET REPRINT REPRESENTATION OF PRINTED DOCUMENT 1120291912 c ti mortgage Page Four 06/02/09 1120291912 HOW TO CURE YOUR MORTGAGE DEFAULT(Bring it up to date). NATURE OF THE DEFAULT-The MORTGAGE debt held by the above lender on your property located at: 221 S. Penn St„ Shippensburg, PA 17257 IS SERIOUSLY IN DEFAULT because YOU HAVE NOT MADE MONTHLY MORTGAGE PAYMENTS for the following months and the following amounts are now past due: 06/01/08 thru 06/01/09 13 @ $714.40/month 0 @ $0.00/late charge/month $9,287.20 Previous late charge(s) $0.00 Delinquency Expenses(s) $755.23 TOTAL AMOUNT PAST DUE: $10,042.43 HOW TO CURE THE DEFAULT-You may cure the default within THIRTY (30) DAYS of the date of this notice BY PAYING THE TOTAL AMOUNT PAST DUE TO THE LENDER, WHICH IS $10,042.43, PLUS ANY MORTGAGE PAYMENTS, LATE CHARGES AND DELINQUENCY EXPENSES 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: CitiMortgage, Inc. P.O. Box 689196 Des Moines, IA 50368-9196 IF YOU DO NOT CURE THE DEFAULT-If you do not cure the default within THIRTY (30) DAYS of the date of this Notice, the lender intends to exercise its rights to accelerate the mortgage debt. This means that the entire outstanding balance of this debt will be considered due immediately and you may lose the chance to pay the mortgage in monthly installments. If full payment of the total amount past due is not made within THIRTY (30) DAYS, the lender also intends to instruct its attorneys to start legal action to foreclose upon your mortgaged property. IF THE MORTGAGE IS FORECLOSED UPON-The mortgaged property will be sold by the Sheriff to pay off the mortgage debt. If the lender refers your case to its attorneys, but you cure the delinquency before the lender begins legal proceedings against you, you will still be required to pay the reasonable attorney's fees that were actually incurred, up to $50.00. However, if legal proceedings are started CitiMortgage, Inc. does business as Citicorp Mortgage in NM. INTERNET REPRINT REPRESENTATION OF PRINTED DOCUMENT 1120291912 c ti mortgage Page Five 06/02/09 1120291912 against you, you will have to pay all reasonable attorney's fees actually incurred by the lender even if they exceed $50.00. Any attorney's fees will be added to the amount you owe the lender, which may also include other reasonable costs. If you cure the default within the THIRTY (30) DAY period, you will not be required to pay attorney's fees. OTHER LENDER REMEDIES-The lender may also sue you personally for the unpaid principal balance and all other sums due under the mortgage. RIGHT TO CURE THE DEFAULT PRIOR TO SHERIFF'S SALE-If you have not cured the default within the THIRTY (30) DAY period and foreclosure proceedings have begun, you still have the right to cure the default and prevent the sale at any time up to one hour before the Sheriff's Sale. You may do so by paying the total amount then past due, plus any late or other charges then due, reasonable attorney's fees and costs connected with the foreclosure sale and any other costs connected with the Sheriff's Sale as specified in writing by the Curing your default in the manner set forth in this notice will restore your mortgage to the same position as if you had never defaulted. EARLIEST POSSIBLE SHERIFF'S SALE DATE-It is estimated that the earliest date that such a Sheriff's Sale of the mortgaged property could be held would be approximately six (6) months from the date of this Notice. A notice of the actual date of the Sheriff's Sale will be sent to you before the sale. Of course, the amount needed to cure the default will increase the longer you wait. You may find out at any time exactly what the required payment or action will be by contacting the lender. HOW TO CONTACT THE LENDER: Name of Lender: Address: Phone Number: Fax Number: Contact Person: Email Address: CitiMortgage, Inc. 1000 Technology Drive O'Fallon, MO 63368-2240 1-800-723-7906 1-636-261-7716 Adam Saab ryan.ollier@citi.com CitiMortgage, Inc. does business as Citicorp Mortgage in NM. INTERNET REPRINT REPRESENTATION OF PRINTED DOCUMENT 1120291912 c ti mortgage Page Six 06/02/09 1120291912 EFFECT OF SHERIFF'S SALE-You should realize that a Sheriff's Sale will end your ownership of the mortgaged property and your right to occupy it. If you continue to live in the property after the Sheriff's Sale, a lawsuit to remove you and your furnishings and other belongings could be started by the lender at any time. ASSUMPTION OF MORTGAGE-Please refer to your original loan documents to determine whether or not you may sell or transfer your home 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 call the 1-800 Number above to find out whether your loan is assumable. 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 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. Enclosure: Consumer Credit Counseling Agencies, including those for your county. 090602D0001184 O O 4 N O CitiMortgage, Inc. does business as Citicorp Mortgage in NM. INTERNET REPRINT XXXXXXXXXXXXXXXXXXXX 06/18/09 SARAH HARPER DONNA A HARPER 221 S. PENN ST SHIPPENSBURG PA 17257 RE: CitiMortgage Loan #: 1120291912 ACT 91 NOTICE TAKE ACTION TO SAVE YOUR HOME FROM FORECLOSURE This is an official notice that the mortgage on your home is in default, and the lender intends to foreclose. Specific information about the nature of the default is provided in the attached pages. The HOMEOWNER'S EMERGENCY MORTGAGE ASSISTANCE PROGRAM (HEMAP) may be able to help to save your home. This Notice explains how the program works. To see if HEMAP can help, you must MEET WITH A CONSUMER CREDIT COUNSELING AGENCY WITHIN 33 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 may 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 Consumer Credit Counseling Agency may be able to help explain it. You may also want to contact an attorney in your area. The local bar association may be able to help you find a lawyer. LA NOTIFICACION EN ADJUNTO ES DE SUMA IMPORTANCIA, PUES AFECTA SU DERECHO A CONTINUAR VIVIENDO EN SU CASA. SI NO COMPRENDE EL CONTENIDO DE ESTA NOTIFICACION OBTENGA UNA TRADUCCION INME.DIATAMENTE LLAMANDO ESTA AGENCIA (PENNSYLVANIA HOUSING FINANCE AGENCY) SIN CARGOS AL NUMERO MENCIONADO ARRIBA. PUEDES SER ELEGIBLE PARA UN PRESTAMO POR EL PROGRAMA LLAMADO "HOMEOWNER'S EMERGENCY MORTGAGE ASSISTANCE PROGRAM" EL CUAL PUEDE SALVAR SU CASA DE LA PERDIDA DEL DERECHO A REDIMIR SU HIPOTECA. Page Two 06/18/09 1120291912 HOMEOWNER'S NAME(S): Harriet D Spraglin Sarah G Spraglin PROPERTY ADDRESS: 221 S. Penn St Shippensburg,PA 17257 LOAN ACCT. NO.: 1120291912 ORIGINAL LENDER: Associates Home Equity CDC CURRENT LENDER/SERVICER: CitiMortgage, Inc. is providing this notice as lender or servicing agent for the lender. HOMEOWNER'S EMERGENCY MORTGAGE ASSISTANCE PROGRAM YOU MAY BE ELIGIBLE FOR FINANCIAL ASSISTANCE WHICH CAN SAVE YOUR HOME FROM FORECLOSURE AND HELP YOU MAKE FUTURE MORTGAGE PAYMENTS. IF YOU COMPLY WITH THE PROVISIONS OF THE HOMEOWNER'S EMERGENCY MORTGAGE ASSISTANCE ACT OF 1983 (THE "ACT"), YOU MAYBE 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 (plus three (3) days for mailing). During that time you must arrange and attend a "face-to-face" meeting with one of the consumer credit counseling agencies listed at the end of this Notice. THIS MEETING MUST OCCUR WITHIN THIRTY-THREE (33) DAYS OF THE DATE OF THIS NOTICE. 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. Page Three 06/18/09 1120291912 CONSUMER CREDIT COUNSELING AGENCIES-If you meet with one of the consumer credit counseling agencies listed at the end of this notice, the lender may NOT take action against you for thirty (30) days after the date of this meeting. The names, addresses and telephone numbers of designated consumer credit counseling agencies for the county in which the property is located are set forth at the end of this Notice. It is only necessary to schedule one face-to-face meeting. Advise your lender immediately of your intentions. APPLICATION FOR MORTGAGE ASSISTANCE-Your mortgage is in default for the reasons set forth later in this Notice (see following pages for specific information about the nature of your default). You have the right to apply for financial assistance from the Homeowner's Emergency Mortgage Assistance Program. To do so, you must fill out, sign and file a completed Homeowner's Emergency Assistance Program Application with one of the designated consumer credit counseling agencies listed at the end of this Notice. Only consumer credit counseling agencies have applications for the program and they will assist you in submitting a complete application to the Pennsylvania Housing Finance Agency. To temporarily stop the lender from filing a foreclosure action, your application MUST be forwarded to PHFA within thirty (30) days of your face-to-face meeting with the counseling agency. YOU SHOULD FILE A HEMAP APPLICATION AS SOON AS POSSIBLE. IF YOU HAVE A MEETING WITH A COUNSELING AGENCY WITHIN 33 DAYS OF THE POSTMARK DATE OF THIS NOTICE AND FILE AN APPLICATION WITH PHFA WITHIN 30 DAYS OF THAT MEETING, THEN THE LENDER WILL BE TEMPORARILY PREVENTED FROM STARTING A FORECLOSURE AGAINST YOUR PROPERTY, AS EXPLAINED ABOVE, IN THE SECTION CALLED "TEMPORARY STAY OF FORECLOSURE". YOU HAVE THE RIGHT TO FILE A HEMAP APPLICATION EVEN BEYOND THESE TIME PERIODS. A LATE APPLICATION WILL NOT PREVENT THE LENDER FROM STARTING A FORECLOSURE ACTION, BUT IF YOUR APPLICATION IS EVENTUALLY APPROVED AT ANY TIME BEFORE A SHERIFF'S SALE, THE FORECLOSURE WILL BE STOPPED. AGENCY ACTION-Available funds for emergency mortgage assistance are very limited. They will be disbursed by the Agency under the eligibility criteria established by the Act. The Pennsylvania Housing Finance Agency has sixty (60) days to make a decision after it receives your application. During that time, no foreclosure proceeding 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 Mortgage Assistance.) Page Four 06/18/09 1120291912 HOW TO CURE YOUR MORTGAGE DEFAULT(Bring it up to date). NATURE OF THE DEFAULT-The MORTGAGE debt held by the above lender on your property located at: 221 S. Penn St„ Shippensburg, PA 17257 IS SERIOUSLY IN DEFAULT because YOU HAVE NOT MADE MONTHLY MORTGAGE PAYMENTS for the following months and the following amounts are now past due: 06/01/08 thru 06/01/09 13 @ $714.40/month 0 @ $0.00/late charge/month $10,052.43 Previous late charge(s) $0.00 Delinquency Expenses(s) $755.23 TOTAL AMOUNT PAST DUE: $10,042.43 HOW TO CURE THE DEFAULT-You may cure the default within THIRTY (30) DAYS of the date of this notice BY PAYING THE TOTAL AMOUNT PAST DUE TO THE LENDER, WHICH IS $10,042.43, PLUS ANY MORTGAGE PAYMENTS, LATE CHARGES AND DELINQUENCY EXPENSES 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: CitiMortgage, Inc. P.O. Box 689196 Des Moines, IA 50368-9196 IF YOU DO NOT CURE THE DEFAULT-If you do not cure the default within THIRTY (30) DAYS of the date of this Notice, the lender intends to exercise its rights to accelerate the mortgage debt. This means that the entire outstanding balance of this debt will be considered due immediately and you may lose the chance to pay the mortgage in monthly installments. If full payment of the total amount past due is not made within THIRTY (30) DAYS, the lender also intends to instruct its attorneys to start legal action to foreclose upon your mortgaged property. IF THE MORTGAGE IS FORECLOSED UPON-The mortgaged property will be sold by the Sheriff to pay off the mortgage debt. If the lender refers your case to its attorneys, but you cure the delinquency before the lender begins legal proceedings against you, you will still be required to pay the reasonable attorney's fees that were actually incurred, up to $50.00. However, if legal proceedings are started Page Five 06/18/09 1120291912 against you, you will have to pay all reasonable attorney's fees actually incurred by the lender even if they exceed $50.00. Any attorney's fees will be added to the amount you owe the lender, which may also include other reasonable costs. If you cure the default within the THIRTY (30) DAY period, you will not be required to pay attorney's fees. OTHER LENDER REMEDIES-The lender may also sue you personally for the unpaid principal balance and all other sums due under the mortgage. RIGHT TO CURE THE DEFAULT PRIOR TO SHERIFF'S SALE-If you have not cured the default within the THIRTY (30) DAY period and foreclosure proceedings have begun, you still have the right to cure the default and prevent the sale at any time up to one hour before the Sheriffs Sale. You may do so by paying the total amount then past due, plus any 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 Curing your default in the manner set forth in this notice will restore your mortgage to the same position as if you had never defaulted. EARLIEST POSSIBLE SHERIFF'S SALE DATE-It is estimated that the earliest date that such a Sheriffs Sale of the mortgaged property could be held would be approximately six (6) months from the date of this Notice. A notice of the actual date of the Sheriffs Sale will be sent to you before the sale. Of course, the amount needed to cure the default will increase the longer you wait. You may find out at any time exactly what the required payment or action will be by contacting the lender. HOW TO CONTACT THE LENDER: Name of Lender: ChiMortgage, Inc. Address: 1000 Technology Drive O'Fallon, MO 63368-2240 Phone Number: 1-800-723-7906 Fax Number: 1-636-261-7716 Contact Person: Adam Saab Email Address: ryan.ollier@citi.com Page Six 06/18/09 1120291912 EFFECT OF SHERIFF'S SALE-You should realize that a Sheriffs 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 Sheriffs Sale, a lawsuit to remove you and your furnishings and other belongings could be started by the lender at any time. ASSUMPTION OF MORTGAGE-Please refer to your original loan documents to determine whether or not you may sell or transfer your home 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 call the 1-800 Number above to find out whether your loan is assumable. 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 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. Enclosure: Consumer Credit Counseling Agencies, including those for your county. 090618D0006219 0 FILED--0,-Fi ,`E OF THE PRY ?-T,0: ? OTARY 2009 JUL 23 AM 11: 8 5-6 0j, ,?lP#" aad3so Sheriffs Office of Cumberland County R Thomas Kline Sheriff Ronny R Anderson Chief Deputy Jody S Smith Civil Process Sergeant Edward L Schorpp Solicitor x OFFICE OF THE S?,ERIFF r tl ?) `? I E -IF THE 'P' X99 A.!.11G 12 A I{, 'D: Citimortgage Inc vs. Harriet D. Spraglin Case Number 2009-4987 SHERIFF'S RETURN OF SERVICE 07/21/2009 R. Thomas Kline, Sheriff who being duly sworn according to law states that he made a diligent search and inquiry for the within named defendant, to wit: Donna A. Harper, but was unable to locate her in his bailiwick. He therefore deputized the Sheriff of Dauphin County, PA to serve the within Complaint In Mortgage Foreclosure according to law. 07/22/2009 Dauphin County Return: And now, July 30, 2009 I, Jack Lotwick, Sheriff of Dauphin County, Pennsylvania, do hereby certify and return, that I made diligent search and inquiry for Donna A. Harper the defendant named in the within Complaint in Mortgage Foreclosure and that I am unable to find her in the County of Dauphin and therefore return same NOT FOUND. The defendant is currently incarcerated at SCI-Muncy BOX 180 Route 405 Muncy, PA 17756. ? 07/24/2009 03:37 PM - R. Thomas Kline, Sheriff, who being duly sworn according to law, states that he made a diligent search and inquiry for the within named defendant to wit: Donna A. Harper, but was unable to locate her in his bailiwick. He therefore returns the within Complaint in Mortgage Foreclosure as not founc as to the defendant Donna A. Harper. Per Harriet Spraglin at 110 Britton Road Shippensburg, PA 17257 the defendnat Donna A. Harper is current incarcerated at SCI-Muncey BOX 180 Route 405 Muncy, PA 17756. 07/24/2009 03:20 PM - Mark Conklin, Deputy Sheriff, who being duly sworn according to law, states that on July 24, 2009 at 1520 hours, he served a true copy of the within Complaint in Mortgage Foreclosure, upon the within named defendant, to wit: Hariet D. Spraglin a/k/a Harriet D. Harper, by making known unto Harriet Spraglin herself personally, defendant at 110 Britton Road Shippensburg, Cumberland County, Pennsylvania 17257 its contents and at the same time handing to her personally the said true and correct copy of the same. Alternate address requested for service at 221 South Penn Street Shippensburg, PA 17257 is vacant. 07/24/2009 R. Thomas Kline, Sheriff, who being duly sworn according to law, states that he made a diligent search and inquiry for the within named defendant to wit: Sarah G. Harper, but was unable to locate her in his bailiwick. He therefore returns the within Complaint in Mortgage Foreclosure as not found as to the ? defendant Sarah G. Harper. Per Harriet Spraglin the defendant Sarah G. Harper is located at Green Ridge Nursing Home. An exact address is not available. Request for service at 221 South Penn Street Shippensburg, PA 17257 is vacant. SHERIFF COST: $131.00 August 11, 2009 R THOMAS K , SH IFF Deputy Sheriff CAMI'Ltg Of thef?h,rr-. ab-& SP%der Mary JaneDepu Real Estate William T. Tully Solicitor W Dauphin County Harrisburg, Pennsylvania 17101 ph: (717) 780-6590 fax: (717) 255-2889 Charles E. Sheaffer Chief Deputy Michael W. Rinehart Assistant Chief Deputy Jack Lotwick Sheriff Commonwealth of Pennsylvania County of Dauphin CITIMORTGAGE INC. ET AL VS DONNA A HARPER Sheriff s Return No. 2009-T-2103 OTHER COUNTY NO. 20094987 I, Jack Lotwick, Sheriff of the County of Dauphin, State of Pennsylvania, do hereby certify and return, that I made diligent search and inquiry for DONNA A HARPER the DEFENDANT named in the within COMPLAINT IN MORTGAGE FORECLOSURE and that I am unable to find him/her in the County of Dauphin, and therefore return same NOT FOUND, JULY 30, 2009. DEFT IS CURRENTLY IN SCI MUNCY Sworn and subscribed to before me this 31 ST day of July, 2009 11??- Al NOTARIAL SEAL MARY JANE SNYDER, Notary Publi Highspire, Dauphin County M Commission Expires Set 1, 2010 So Annsswers,( Sheriff of Dapphin 2oa4ty, '?. r5y ,r?-v - Depu Sheriff Deputy: KIMBERLY BARTO Sheriffs Costs: $47.25 7/28/2009 GOLDBECK McCAFFERTY & McKEEVER BY: MICHAEL T. MCKEEVER ATTORNEY I.D. #56129 SUITE 5000 - MELLON INDEPENDENCE CENTER 701 MARKET STREET PHILADELPHIA, PA 19106-1532 (215) 627-1322 ATTORNEY FOR PLAINTIFF IN THE COURT OF COMMON PLEAS OF Cumberland COUNTY CIVIL ACTION - LAW ACTION OF MORTGAGE FORECLOSURE CITIMORTGAGE INC. F/K/A ASSOCIATES HOME EQUITY CDC INC. 1000 Technology Drive MS 730 O'Fallon, MO 63368-2240 Plaintiff vs. DONNA A. HARPER SARAH G. HARPER HARRIET D. SPRAGLIN A/K/A HARRIET D. HARPER 221 South Penn Street Shippensburg, PA 17257 Defendant(s) PRAECIPE TO REINSTATE COMPLAINT Kindly reinstate the Complaint in the above captioned matter. Term No. 09-4987 By. / ? lA sr bins d ?C? GOLDBECK McCAFFERTY & McKEEVER MICHAEL T. MCKEEVER, ESQUIRE ATTORNEY FOR PLAINTIFF CAF THI- } 1 _, Y 11 1 2009 AUG 2 I FM 12* 59 PEN!g, SYWANLA +10.00 PrI ATT`/ co,2Ayalo ET* aaq 5179 GOLDBECK WCAFFERTY & WKEEVER BY: MICHAEL T. MCKEEVER ATTORNEY I.D.#56129 SUITE 5000 - MELLON INDEPENDENCE CENTER 701 MARKET STREET PHILADELPHIA, PA 19106-1532 (215) 627-1322 ATTORNEY FOR PLAINTIFF IN THE COURT OF COMMON PLEAS OF Cumberland COUNTY CIVIL ACTION - LAW ACTION OF MORTGAGE FORECLOSURE Term No. 09-4987 ? By: 7?klA CITIMORTGAGE INC. F/K/A ASSOCIATES HOME EQUITY CDC INC. 1000 Technology Drive MS 730 O'Fallon, MO 63368-2240 Plaintiff vs. DONNA A. HARPER SARAH G. HARPER HARRIET D. SPRAGLIN A/K/A HARRIET D. HARPER 221 South Penn Street Shippensburg, PA 17257 Defendant(s) PRAECIPE TO REINSTATE COMPLAINT Kindly reinstate the Complaint in the above captioned matter. GOLDBECK McCAFFERTY & MCKEEVER MICHAEL T. MCKEEVER, ESQUIRE ATTORNEY FOR PLAINTIFF QP 7, :i Sheriffs Office of Cumberland County R Thomas Kline Sheriff Ronny R Anderson Chief Deputy Jody S Smith Civil Process Sergeant ,?4ti?dr o! icsirtbrrt1p4? OFCii.EUF T. ;??FttFF `r1 E OF THE M"' 2009 SEP -1 Pali 9.41 iTy Edward L Schorpp Solicitor Citimortgage Inc Case Number vs. Harriet D. Spraglin 2009-4987 SHERIFF'S RETURN OF SERVICE 08/29/2009 09:20 AM - R. Thomas Kline, Sheriff, who being duly sworn according to law, states that on August 29, 2009 at 0920 hours this Complaint in Mortgage Foreclosure upon defendant Sarah G. Harper is returned not served. Sarah G. Harper is unable to accept service her power of attorney is Crystal Caraway 2247 N 4th Street Harrisburg, PA 17102. SHERIFF COST: $38.80 August 31, 2009 SO ANSWERS, R THOMAS KLINE, SHERIFF GOLDBECK WCAFFERTY & McKEEVER BY: MICHAEL T. MCKEEVER ATTORNEY I.D. 456129 SUITE 5000 - MELLON INDEPENDENCE CENTER 701 MARKET STREET PHILADELPHIA, PA 19106-1532 (215) 627-1322 ATTORNEY FOR PLAINTIFF CITIMORTGAGE INC. F/K/A ASSOCIATES HOME EQUITY CDC INC. 1000 Technology Drive MS 730 O'Fallon, MO 63368-2240 Plaintiff IN THE COURT OF COMMON PLEAS OF Cumberland COUNTY CIVIL ACTION - LAW ACTION OF MORTGAGE FORECLOSURE vs. DONNA A. HARPER SARAH G. HARPER HARRIET D. SPRAGLIN A/K/A HARRIET D. HARPER 221 South Penn Street Shippensburg, PA 17257 Defendant(s) PRAECIPE TO REINSTATE COMPLAINT Kindly reinstate the Complaint in the above captioned matter. Term No. 09-4987 By: GOLDBECK McCAFFERTY & McKEEVER MICHAEL T. MCKEEVER, ESQUIRE ATTORNEY FOR PLAINTIFF OF THE PP"' "'NOTARY 2009 SEP 21 {' ' 1: ia9 CK? 3`lSavg ? - ?Z 3 o gz7 Sheriffs Office of Cumberland County R Thomas Kline ALEQ-'til.-± IvC Sheriff Or THE sf? S RY vita at?rat?yrM Ronny R Anderson ?'? r1? c ???? ?? 22 All 10: 4 0 Chief Deputy , - Jody S Smith C 'f Civil Process Sergeant OFFICE OP THE SHERIFF Edward L Schorpp Solicitor Citimortgage Inc vs. Harriet D. Spraglin Case Number 2009-4987 SHERIFF'S RETURN OF SERVICE 08/25/2009 R. Thomas Kline, Sheriff who being duly sworn according to law states that he made a diligent search and inquiry for the within named defendant, to wit: Donna A. Harper, but was unable to locate her in his bailiwick. He therefore deputized the Sheriff of Lycoming County, PA to serve the within Complaint In Mortgage Foreclosure according to law. 09/17/2009 09:15 AM - Lycoming County Return: And now September 17, 2009 at 0915 hours I, Charles T. Brewer, Sheriff of Lycoming County, Pennsylvania, do herby certify and return that I served a true copy of the within Complaint, upon the within named defendant, to wit: Donna A. Harper by making known unto herself personally, at SCI Muncy P.O. BOX 180 Muncy, PA 17756 its contents and at the same time handing to her personally the said true and correct copy of the same. SHERIFF COST: $37.00 September 21, 2009 SO ANSWERS, R THOMAS KLINE, SHERIFF Sheriffs Office of Cumberland County R Thomas Kline Sheri Ronny R Anderson Chief Deputy TF l -A 0V 2Cr1 v'L -, "' 1 E' 11 Jody S Smith Civil Process Sergeant Edward L Schorpp Solicitor OFF :'P, OF Fk-F -- =RIFF C i 1 1` Citimortgage Inc vs. I Case Number Harriet D. Spraglin 2009-4987 SHERIFF'S RETURN OF SERVICE 09/21/2009 R. Thomas Kline, Sheriff who being duly sworn according to law states that he made a diligent search and inquiry for the within named defendant, to wit: Crystal Caraway c/o Sarah G. Harper, but was unable to locate him in her bailiwick. He therefore deputized the Sheriff of Dauphin County, PA to serve the within Complaint In Mortgage Foreclosure according to law. 10/06/2009 09:35 AM - Dauphin County Return: And now October 6, 2009 at 0935 hours I, Jack Lotwick, Sheriff of Dauphin County, Pennsylvania, do herby certify and return that I served a true copy of the within Complaint in Mortgage Foreclosure, upon the within named defendant, to wit: Crystal Caraway c/o Sarah G. Harper by making known unto Crystal Caraway herself personally, at The Dauphin County Sheriffs Office Front and Market Streets Harrisburg, PA 17102 its contents and at the same time handing to her personally the said true and correct copy of the same. SHERIFF COST: $37.00 October 09, 2009 SO ANSWERS, ^-.rte R THOMAS KLINE, SHERIFF In the Court of Common Pleas of Cumberland County CITIMORTGAGE INC. F/K/A ASSOCIATES HOME EQUITY CDC INC. 1000 Technology Drive MS 730 OTallon, MO 63368-2240 Plaintiff vs. DONNA A. HARPER SARAH G. HARPER HARRIET D. SPRAGLIN A/K/A HARRIET D. HARPER (Mortgagor(s) and Record Owner(s)) 221 South Penn Street Shippensburg, PA 17257 Defendant(s) PRAECIPE FOR JUDGMENT No. 09-4987 THIS LAW FIRM IS A DEBT COLLECTOR AND WE ARE ATTEMPTING TO COLLECT A DEBT OWED TO OUR CLIENT. ANY INFORMATION OBTAINED FROM YOU WILL BE USED FOR THE PURPOSE OF COLLECTING THE DEBT. Enter the Judgment in favor of Plaintiff and against DONNA A. HARPER, SARAH G. HARPER and HARRIET D. SPRAGLIN A/K/A HARRIET D. HARPER by default for want of an Answer. Assess damages as follows: $87,025.13 Debt Interest from 11/13/2009 to Date of Sale per diem at $21.73 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 and at least ten days prior to the date of the filing of this praecipe. A copy of the notice is attached. R.C.P. 237.1 Michael T. McKeever Attorney for Plaintiff I.D. #56129 AND NOW l d? , Judgment is entered in favor of CITIMORTGAGE INC. /K/A ASSOCIATES HOME EQUITY C INC. and against DONNA A. HARPER, SARAH G. HARPER and HARRIET D. SPRAGLIN A/K/A HARRIET D. HARPER by default for want of an Answer and ages assessed in the sum of $87,025.13 as per the above certification. ro onotary , Rule of Civil Procedure No. 236 - Revised IN THE COURT OF COMMON PLEAS OF Cumberland COUNTY, PENNSYLVANIA CIVIL ACTION - LAW CITIMORTGAGE INC. F/K/A ASSOCIATES HOME EQUITY CDC INC. 1000 Technology Drive MS 730 O'Fallon, MO 63368-2240 Plaintiff No. 09-4987 vs. DONNA A. HARPER SARAH G. HARPER HARRIET D. SPRAGLIN A/K/A HARRIET D. HARPER (Mortgagors and Record Owner(s)) 221 South Penn Street Shippensburg, PA 17257 Defendant(s) THIS LAW FIRM IS A DEBT COLLECTOR AND WE ARE ATTEMPTING TO COLLECT A DEBT OWED TO OUR CLIENT. ANY INFORMATION OBTAINED FROM YOU WILL BE USED FOR THE PURPOSE OF COLLECTING THE DEBT. NOTICE Notice is given that a judgment in the above-captioned matter has been entered against you. Curt Long Prothonotary By: Deputy If you have any questions concerning the above, please contact: Michael T. McKeever Goldbeck McCafferty & McKeever Suite 5000 - Mellon Independence Center 701 Market Street Philadelphia, PA 19106 215-627-1322 77176FC 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. TO: DONNA A. HARPER HARPER, DONNA A 221 South Penn Street Shippensburg,PA 17257 CITIMORTGAGE INC. F/K/A ASSOCIATES HOME EQUITY CDC INC. 1000 Technology Drive MS 730 O'Fallon, MO 63368-2240 Plaintiff VS. DONNA A. HARPER SARAH G. HARPER HARRIET D. SPRAGLIN A/K/A HARRIET D. HARPER (Mortgagor(s) and Record Owner(s)) 221 South Penn Street Shippensburg, PA 17257 Defendant(s) TO: DONNA A. HARPER 221 South Penn Street Shippensburg, PA 17257 DATE OF TFUS NOTICE: October 27, 2009 In the Court of Common Pleas of Cumberland County CIVIL ACTION - LAW Action of Mortgage Foreclosure Term No. 09-4987 IMPORTANT NOTICE YOU ARE IN DEFAULT BECAUSE YOU HAVE FAILED TO ENTER A WRITTEN APPEARANCE PERSONALLY OR BY ATTORNEY AND FILE IN WRITING WITH THE COURT YOUR DEFENSES OR OBJECTIONS TO THE CLAIMS SET FORTH AGAINST YOU. UNLESS YOU ACT WITHIN TEN (10) DAYS FROM THE DATE OF THIS NOTICE, A JUDGMENT MAY BE ENTERED AGAINST YOU WITHOUT A HEARING AND YOU MAY LOSE YOUR PROPERTY OR OTHER IMPORTANT RIGHTS. YOU SHOULD TAKE THIS PAPER TO YOUR LAWYER AT ONCE. IF YOU DO NOT HAVE A LAWYER, GO TO OR TELEPHONE THE OFFICE SET FORTH BELOW. THIS OFFICE CAN PROVIDE YOU WITH INFORMATION ABOUT HIRING A LAWYER. IF YOU CANNOT AFFORD TO HIRE A LAWYER, THIS OFFICE MAY BE ABLE TO PROVIDE YOU WITH INFORMATION ABOUT AGENCIES THAT MAY OFFER LEGAL SERVICES TO ELIGIBLE PERSONS AT A REDUCED FEE OR NO FEE. CUMBERLAND COUNTY BAR ASSOCIATION 2 Liberty Avenue Carlisle, PA 17013 LEGAL SERVICES INC 8 Irvine Row Carlisle, PA 17013 717-243-9400 Michael T. McKeever GOLDBECK McCAFFERTY & MCKEEVER BY: Michael T. McKeever, Esq. Attorney for Plaintiff Suite 5000 - 701 Market Street. Philadelphia, PA 19106 215-825-6318 77176FC 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. TO: SARAH G. HARPER HARPER, SARAH G. 221 South Penn Street Shippensburg, PA 17257 DATE OF THIS NOTICE: October 27, 2009 CITIMORTGAGE INC. F/K/A ASSOCIATES HOME EQUITY CDC INC. 1000 Technology Drive MS 730 O'Fallon, MO 63368-2240 Plaintiff VS. DONNA A. HARPER SARAH G. HARPER HARRIET D. SPRAGLIN A/K/A HARRIET D. HARPER (Mortgagor(s) and Record Owner(s)) 221 South Penn Street Shippensburg, PA 17257 Defendant(s) TO: SARAH G. HARPER 221 South Penn Street Shippensburg, PA 17257 In the Court of Common Pleas of Cumberland County CIVIL ACTION - LAW Action of Mortgage Foreclosure Term No. 09-4987 IMPORTANT NOTICE YOU ARE IN DEFAULT BECAUSE YOU HAVE FAILED TO ENTER A WRITTEN APPEARANCE PERSONALLY OR BY ATTORNEY AND FILE IN WRITING WITH THE COURT YOUR DEFENSES OR OBJECTIONS TO THE CLAIMS SET FORTH AGAINST YOU. UNLESS YOU ACT WITHIN TEN (10) DAYS FROM THE DATE OF THIS NOTICE, A JUDGMENT MAY BE ENTERED AGAINST YOU WITHOUT A HEARING AND YOU MAY LOSE YOUR PROPERTY OR OTHER IMPORTANT RIGHTS. YOU SHOULD TAKE THIS PAPER TO YOUR LAWYER AT ONCE. IF YOU DO NOT HAVE A LAWYER, GO TO OR TELEPHONE THE OFFICE SET FORTH BELOW. THIS OFFICE CAN PROVIDE YOU WITH INFORMATION ABOUT HIRING A LAWYER. IF YOU CANNOT AFFORD TO HIRE A LAWYER, THIS OFFICE MAY BE ABLE TO PROVIDE YOU WITH INFORMATION ABOUT AGENCIES THAT MAY OFFER LEGAL SERVICES TO ELIGIBLE PERSONS AT A REDUCED FEE OR NO FEE. CUMBERLAND COUNTY BAR ASSOCIATION 2 Liberty Avenue Carlisle, PA 17013 LEGAL SERVICES INC 8 Irvine Row Carlisle, PA 17013 717-243-9400 Michael T. McKeever GOLDBECK McCAFFERTY & McKEEVER BY: Michael T. McKeever, Esq. Attorney for Plaintiff Suite 5000 - 701 Market Street. Philadelphia, PA 19106 215-825-6318 77176FC 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. TO: HARRIET D. SPRAGLIN A/K/A HARRIET D. HARPER SPRAGLIN, HARRIET D. A/K/A HARPER, HARRIET D. 221 South Penn Street Shippensburg, PA 17257 CITIMORTGAGE INC. F/K/A ASSOCIATES HOME EQUITY CDC INC. 1000 Technology Drive MS 730 O'Fallon, MO 63368-2240 Plaintiff VS. DONNA A. HARPER SARAH G. HARPER HARRIET D. SPRAGLIN A/K/A HARRIET D. HARPER (Mortgagor(s) and Record Owner(s)) 221 South Penn Street Shippensburg, PA 17257 Defendant(s) TO: HARRIET D. SPRAGLIN A/K/A HARRIET D. HARPER 221 South Penn Street Shippensburg, PA 17257 DATE OF THIS NOTICE: October 27, 2009 In the Court of Common Pleas of Cumberland County CIVIL ACTION - LAW Action of Mortgage Foreclosure Term No. 09-4987 IMPORTANT NOTICE YOU ARE IN DEFAULT BECAUSE YOU HAVE FAILED TO ENTER A WRITTEN APPEARANCE PERSONALLY OR BY ATTORNEY AND FILE IN WRITING WITH THE COURT YOUR DEFENSES OR OBJECTIONS TO THE CLAIMS SET FORTH AGAINST YOU. UNLESS YOU ACT WITHIN TEN (10) DAYS FROM THE DATE OF THIS NOTICE, A JUDGMENT MAY BE ENTERED AGAINST YOU WITHOUT A HEARING AND YOU MAY LOSE YOUR PROPERTY OR OTHER IMPORTANT RIGHTS. YOU SHOULD TAKE THIS PAPER TO YOUR LAWYER AT ONCE. IF YOU DO NOT HAVE A LAWYER, GO TO OR TELEPHONE THE OFFICE SET FORTH BELOW. THIS OFFICE CAN PROVIDE YOU WITH INFORMATION ABOUT HIRING A LAWYER. IF YOU CANNOT AFFORD TO HIRE A LAWYER, THIS OFFICE MAY BE ABLE TO PROVIDE YOU WITH INFORMATION ABOUT AGENCIES THAT MAY OFFER LEGAL SERVICES TO ELIGIBLE PERSONS AT A REDUCED FEE OR NO FEE. CUMBERLAND COUNTY BAR ASSOCIATION 2 Liberty Avenue Carlisle, PA 17013 LEGAL SERVICES INC 8 Irvine Row Carlisle, PA 17013 717-243-9400 Michael T. McKeever GOLDBECK McCAFFERTY & McKEEVER BY: Michael T. McKeever, Esq. Attorney for Plaintiff Suite 5000 - 701 Market Street. Philadelphia, PA 19106 215-825-6318 77176FC 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. TO: DONNA A. HARPER HARPER, DONNA A SCI Muncy P.O. Box 180 Inmate# OP1907 Muncy, PA 17756 CITIMORTGAGE INC. F/K/A ASSOCIATES HOME EQUITY CDC INC. 1000 Technology Drive MS 730 O'Fallon, MO 63368-2240 Plaintiff VS. DONNA A. HARPER SARAH G. HARPER HARRIET D. SPRAGLIN A/K/A HARRIET D. HARPER (Mortgagor(s) and Record Owner(s)) 221 South Penn Street Shippensburg, PA 17257 Defendant(s) DATE OF THIS NOTICE: October 27, 2009 In the Court of Common Pleas of Cumberland County CIVIL ACTION - LAW Action of Mortgage Foreclosure Term No. 09-4987 TO: DONNA A. HARPER SCI Muncy P.O. Box 180Inmate# OP1907 Muncy, PA 17756 IMPORTANT NOTICE YOU ARE IN DEFAULT BECAUSE YOU HAVE FAILED TO ENTER A WRITTEN APPEARANCE PERSONALLY OR BY ATTORNEY AND FILE IN WRITING WITH THE COURT YOUR DEFENSES OR OBJECTIONS TO THE CLAIMS SET FORTH AGAINST YOU. UNLESS YOU ACT WITHIN TEN (10) DAYS FROM THE DATE OF THIS NOTICE, A JUDGMENT MAY BE ENTERED AGAINST YOU WITHOUT A HEARING AND YOU MAY LOSE YOUR PROPERTY OR OTHER IMPORTANT RIGHTS. YOU SHOULD TAKE THIS PAPER TO YOUR LAWYER AT ONCE. IF YOU DO NOT HAVE A LAWYER, GO TO OR TELEPHONE THE OFFICE SET FORTH BELOW. THIS OFFICE CAN PROVIDE YOU WITH INFORMATION ABOUT HIRING A LAWYER. IF YOU CANNOT AFFORD TO HIRE A LAWYER, THIS OFFICE MAY BE ABLE TO PROVIDE YOU WITH INFORMATION ABOUT AGENCIES THAT MAY OFFER LEGAL SERVICES TO ELIGIBLE PERSONS AT A REDUCED FEE OR NO FEE. CUMBERLAND COUNTY BAR ASSOCIATION 2 Liberty Avenue Carlisle, PA 17013 LEGAL SERVICES INC 8 Irvine Row Carlisle, PA 17013 717-243-9400 Michael T. McKeever GOLDBECK MCCAFFERTY & McKEEVER BY: Michael T. McKeever, Esq. Attorney for Plaintiff Suite 5000 - 701 Market Street. Philadelphia, PA 19106 215-825-6318 77176FC 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. TO: HARRIET D. SPRAGLIN A/K/A HARRIET D. HARPER SPRAGLIN, HARRIET D. A/K/A HARPER, HARRIET D. 110 Britton Road Shippensburg, PA 17257 CITIMORTGAGE INC. F/KJA ASSOCIATES HOME EQUITY CDC INC. 1000 Technology Drive MS 730 O'Fallon, MO 63368-2240 Plaintiff VS. DONNA A. HARPER SARAH G. HARPER HARRIET D. SPRAGLIN A/KJA HARRIET D. HARPER (Mortgagor(s) and Record Owner(s)) 221 South Perm Street Shippensburg, PA 17257 Defendant(s) TO: HARRIET D. SPRAGLIN A/K/A HARRIET D. HARPER 110 Britton Road Shippensburg, PA 17257 DATE OF THIS NOTICE: October 27, 2009 In the Court of Common Pleas of Cumberland County CIVIL ACTION - LAW Action of Mortgage Foreclosure Term No. 09-4987 IMPORTANT NOTICE YOU ARE IN DEFAULT BECAUSE YOU HAVE FAILED TO ENTER A WRITTEN APPEARANCE PERSONALLY OR BY ATTORNEY AND FILE IN WRITING WITH THE COURT YOUR DEFENSES OR OBJECTIONS TO THE CLAIMS SET FORTH AGAINST YOU. UNLESS YOU ACT WITHIN TEN (10) DAYS FROM THE DATE OF THIS NOTICE, A JUDGMENT MAY BE ENTERED AGAINST YOU WITHOUT A HEARING AND YOU MAY LOSE YOUR PROPERTY OR OTHER IMPORTANT RIGHTS. YOU SHOULD TAKE THIS PAPER TO YOUR LAWYER AT ONCE. IF YOU DO NOT HAVE A LAWYER, GO TO OR TELEPHONE THE OFFICE SET FORTH BELOW. THIS OFFICE CAN PROVIDE YOU WITH INFORMATION ABOUT HIRING A LAWYER. IF YOU CANNOT AFFORD TO HIRE A LAWYER, THIS OFFICE MAY BE ABLE TO PROVIDE YOU WITH INFORMATION ABOUT AGENCIES THAT MAY OFFER LEGAL SERVICES TO ELIGIBLE PERSONS AT A REDUCED FEE OR NO FEE. CUMBERLAND COUNTY BAR ASSOCIATION 2 Liberty Avenue Carlisle, PA 17013 LEGAL SERVICES INC 8 bvine Row Carlisle, PA 17013 717-243-9400 Michael T. McKeever GOLDBECK McCAFFERTY & McKEEVER BY: Michael T. McKeever, Esq. Attorney for Plaintiff Suite 5000 - 701 Market Street. Philadelphia, PA 19106 215-825-6318 77176FC 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. TO: SARAH G. HARPER HARPER, SARAH G. Green Ridge Village 210 Big Spring Road Newville, PA 17241 CITIMORTGAGE INC. F/K/A ASSOCIATES HOME EQUITY CDC INC. 1000 Technology Drive MS 730 O'Fallon, MO 63368-2240 Plaintiff VS. DONNA A. HARPER SARAH G. HARPER HARRIET D. SPRAGLIN A/KIA HARRIET D. HARPER (Mortgagor(s) and Record Owner(s)) 221 South Penn Street Shippensburg, PA 17257 Defendant(s) TO: SARAH G. HARPER Green Ridge Village 210 Big Spring Road Newville, PA 17241 DATE OF THIS NOTICE: October 27, 2009 In the Court of Common Pleas of Cumberland County CIVIL ACTION - LAW Action of Mortgage Foreclosure Term No. 09-4987 EYWORTANT NOTICE YOU ARE IN DEFAULT BECAUSE YOU HAVE FAILED TO ENTER A WRITTEN APPEARANCE PERSONALLY OR BY ATTORNEY AND FILE IN WRITING WITH THE COURT YOUR DEFENSES OR OBJECTIONS TO THE CLAIMS SET FORTH AGAINST YOU. UNLESS YOU ACT WITHIN TEN (10) DAYS FROM THE DATE OF THIS NOTICE, A JUDGMENT MAY BE ENTERED AGAINST YOU WITHOUT A HEARING AND YOU MAY LOSE YOUR PROPERTY OR OTHER IMPORTANT RIGHTS. YOU SHOULD TAKE THIS PAPER TO YOUR LAWYER AT ONCE. IF YOU DO NOT HAVE A LAWYER, GO TO OR TELEPHONE THE OFFICE SET FORTH BELOW. THIS OFFICE CAN PROVIDE YOU WITH INFORMATION ABOUT HIRING A LAWYER. IF YOU CANNOT AFFORD TO HIRE A LAWYER, THIS OFFICE MAY BE ABLE TO PROVIDE YOU WITH INFORMATION ABOUT AGENCIES THAT MAY OFFER LEGAL SERVICES TO ELIGIBLE PERSONS AT A REDUCED FEE OR NO FEE. CUMBERLAND COUNTY BAR ASSOCIATION 2 Liberty Avenue Carlisle, PA 17013 LEGAL SERVICES INC 8 Irvine Row Carlisle, PA 17013 717-243-9400 Michael T. McKeever GOLDBECK McCAFFERTY & McKEEVER BY: Michael T. McKeever, Esq. Attorney for Plaintiff Suite 5000 - 701 Market Street. Philadelphia, PA 19106 215-825-6318 77176FC 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. TO: SARAH G. HARPER HARPER, SARAH G. 2247 North 4th Street Harrisburg, PA 17102 CITIMORTGAGE INC. F/K/A ASSOCIATES HOME EQUITY CDC INC. 1000 Technology Drive MS 730 O'Fallon, MO 63368-2240 Plaintiff VS. DONNA A. HARPER SARAH G. HARPER HARRIET D. SPRAGLIN A/KJA HARRIET D. HARPER (Mortgagor(s) and Record Owner(s)) 221 South Perm Street Shippensburg, PA 17257 Defendant(s) TO: SARAH G. HARPER 2247 North 4th Street Harrisburg, PA 17102 DATE OF THIS NOTICE: October 27, 2009 In the Court of Common Pleas of Cumberland County CIVIL ACTION - LAW Action of Mortgage Foreclosure Term No. 09-4987 IWORTANT NOTICE YOU ARE IN DEFAULT BECAUSE YOU HAVE FAILED TO ENTER A WRITTEN APPEARANCE PERSONALLY OR BY ATTORNEY AND FILE IN WRITING WITH THE COURT YOUR DEFENSES OR OBJECTIONS TO THE CLAIMS SET FORTH AGAINST YOU. UNLESS YOU ACT WITHIN TEN (10) DAYS FROM THE DATE OF THIS NOTICE, A JUDGMENT MAY BE ENTERED AGAINST YOU WITHOUT A HEARING AND YOU MAY LOSE YOUR PROPERTY OR OTHER IMPORTANT RIGHTS. YOU SHOULD TAKE THIS PAPER TO YOUR LAWYER AT ONCE. IF YOU DO NOT HAVE A LAWYER, GO TO OR TELEPHONE THE OFFICE SET FORTH BELOW. THIS OFFICE CAN PROVIDE YOU WITH INFORMATION ABOUT HIRING A LAWYER. IF YOU CANNOT AFFORD TO HIRE A LAWYER, THIS OFFICE MAY BE ABLE TO PROVIDE YOU WITH INFORMATION ABOUT AGENCIES THAT MAY OFFER LEGAL SERVICES TO ELIGIBLE PERSONS AT A REDUCED FEE OR NO FEE. CUMBERLAND COUNTY BAR ASSOCIATION 2 Liberty Avenue Carlisle, PA 17013 LEGAL SERVICES INC 8 Irvine Row Carlisle, PA 17013 717-243-9400 Michael T. McKeever GOLDBECK McCAFFERTY & McKEEVER BY: Michael T. McKeever, Esq. Attorney for Plaintiff Suite 5000 - 701 Market Street. Philadelphia, PA 19106 215-825-6318 77176FC 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. TO: SARAH G. HARPER HARPER, SARAH G. 110 Britton Road Shippensburg, PA 17257 CITIMORTGAGE INC. F/K/A ASSOCIATES HOME EQUITY CDC INC. 1000 Technology Drive MS 730 O'Fallon, MO 63368-2240 Plaintiff VS. DONNA A. HARPER SARAH G. HARPER HARRIET D. SPRAGLIN A/K/A HARRIET D. HARPER (Mortgagor(s) and Record Owner(s)) 221 South Penn Street Shippensburg, PA 17257 Defendant(s) TO: SARAH G. HARPER 110 Britton Road Shippensburg, PA 17257 DATE OF THIS NOTICE: October 27, 2009 In the Court of Common Pleas of Cumberland County CIVIL ACTION - LAW Action of Mortgage Foreclosure Term No. 09-4987 IlYWORTANT NOTICE YOU ARE IN DEFAULT BECAUSE YOU HAVE FAILED TO ENTER A WRITTEN APPEARANCE PERSONALLY OR BY ATTORNEY AND FILE IN WRITING WITH THE COURT YOUR DEFENSES OR OBJECTIONS TO THE CLAIMS SET FORTH AGAINST YOU. UNLESS YOU ACT WITHIN TEN (10) DAYS FROM THE DATE OF THIS NOTICE, A JUDGMENT MAY BE ENTERED AGAINST YOU WITHOUT A HEARING AND YOU MAY LOSE YOUR PROPERTY OR OTHER IMPORTANT RIGHTS. YOU SHOULD TAKE THIS PAPER TO YOUR LAWYER AT ONCE. IF YOU DO NOT HAVE A LAWYER, GO TO OR TELEPHONE THE OFFICE SET FORTH BELOW. THIS OFFICE CAN PROVIDE YOU WITH INFORMATION ABOUT HIRING A LAWYER. IF YOU CANNOT AFFORD TO HIRE A LAWYER, THIS OFFICE MAY BE ABLE TO PROVIDE YOU WITH INFORMATION ABOUT AGENCIES THAT MAY OFFER LEGAL SERVICES TO ELIGIBLE PERSONS AT A REDUCED FEE OR NO FEE. CUMBERLAND COUNTY BAR ASSOCIATION 2 Liberty Avenue Carlisle, PA 17013 LEGAL SERVICES INC 8 Irvine Row Carlisle, PA 17013 717-243-9400 Michael T. McKeever GOLDBECK McCAFFERTY & McKEEVER BY: Michael T. McKeever, Esq. Attorney for Plaintiff Suite 5000 - 701 Market Street. Philadelphia, PA 19106 215-825-6318 77176FC 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: October 27, 2009 TO: DONNA A. HARPER HARPER, DONNA A. 2247 North 4th Street Harrisburg, PA 17110 CITIMORTGAGE INC. F/K/A ASSOCIATES HOME EQUITY CDC INC. 1000 Technology Drive MS 730 O'Fallon, MO 63368-2240 Plaintiff VS. DONNA A. HARPER SARAH G. HARPER HARRIET D. SPRAGLIN A/K/A HARRIET D. HARPER (Mortgagor(s) and Record Owner(s)) 221 South Penn Street Shippensburg, PA 17257 TO: DONNA A. HARPER 2247 North 4th Street Harrisburg, PA 17114 Defendant(s) In the Court of Common Pleas of Cumberland County CIVIL ACTION - LAW Action of Mortgage Foreclosure Term No. 09-4987 MORTANT NOTICE YOU ARE IN DEFAULT BECAUSE YOU HAVE FAILED TO ENTER A WRITTEN APPEARANCE PERSONALLY OR BY ATTORNEY AND FILE IN WRITING WITH THE COURT YOUR DEFENSES OR OBJECTIONS TO THE CLAIMS SET FORTH AGAINST YOU. UNLESS YOU ACT WITHIN TEN (10) DAYS FROM THE DATE OF THIS NOTICE, A JUDGMENT MAY BE ENTERED AGAINST YOU WITHOUT A HEARING AND YOU MAY LOSE YOUR PROPERTY OR OTHER IMPORTANT RIGHTS. YOU SHOULD TAKE THIS PAPER TO YOUR LAWYER AT ONCE. IF YOU DO NOT HAVE A LAWYER, GO TO OR TELEPHONE THE OFFICE SET FORTH BELOW. THIS OFFICE CAN PROVIDE YOU WITH INFORMATION ABOUT HIRING A LAWYER. IF YOU CANNOT AFFORD TO HIRE A LAWYER, THIS OFFICE MAY BE ABLE TO PROVIDE YOU WITH INFORMATION ABOUT AGENCIES THAT MAY OFFER LEGAL SERVICES TO ELIGIBLE PERSONS AT A REDUCED FEE OR NO FEE. CUMBERLAND COUNTY BAR ASSOCIATION 2 Liberty Avenue Carlisle, PA 17013 LEGAL SERVICES INC 8 Irvine Row Carlisle, PA 17013 717-243-9400 Michael T. McKeever_ GOLDBECK McCAFFERTY & McKEEVER BY: Michael T. McKeever, Esq. Attorney for Plaintiff Suite 5000 - 701 Market Street. Philadelphia, PA 19106 215-825-6318 VERIFICATION OF NON-MILITARY SERVICE The undersigned, as the representative for the Plaintiff corporation within named do hereby verify that I am authorized to make this verification on behalf of the Plaintiff corporation and that the facts set forth in the foregoing verification of Non-Military Service are true and correct to the best of my knowledge, information and belief. I understand that false statements therein are made subject to penalties of 18 Pa. C.S. 4904 relating to unsworn falsification to authorities. 1. That the above named Defendant, DONNA A. HARPER, is about unknown years of age, that Defendant's last known residence is SCI Muncy P.O. Box 180 Inmate# OP1907, Muncy, PA 17756, 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: 11/12/2009 in A (J(_ 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, SARAH G. HARPER, is about unknown years of age, that Defendant's last known residence is 221 South Penn Street, Shippensburg, PA 17257, 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: 11/12/2009 M N ( T 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, HARRIET D. SPRAGLIN A/K/A HARRIET D. HARPER, is about unknown years of age, that Defendant's last known residence is 110 Britton Road, Shippensburg, PA 17257, 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: 11/12/2009 /)) /)-.v K__ GOLDBECK McCAFFERTY & McKEEVER BY: Michael T. McKeever Attorney I.D. #56129 Suite 5000 - Mellon Independence Center 701 Market Street Philadelphia, PA 19106 215-627-1322 Attorney for Plaintiff CITIMORTGAGE INC. F/K/A ASSOCIATES HOME EQUITY CDC INC. 1000 Technology Drive MS 730 O'Fallon, MO 63368-2240 Plaintiff vs. IN THE COURT OF COMMON PLEAS of Cumberland County CIVIL ACTION LAW DONNA A. HARPER SARAH G. HARPER HARRIET D. SPRAGLIN A/K/A HARRIET D. HARPER (Mortgagor(s) and Record owner(s)) 221 South Penn Street Shippensburg, PA 17257 Defendant(s) ACTION OF MORTGAGE FORECLOSURE No. 09-4987 ORDER FOR JUDGMENT Please enter Judgment in favor of CITIMORTGAGE INC. F/K/A ASSOCIATES HOME EQUITY CDC INC., and against DONNA A. HARPER, SARAH G. HARPER and HARRIET D. SPRAGLIN A/K/A HARRIET D. HARPER 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 Complaint, in the sum of $87,025.13. mmc? Michael T. McKeever Attorney for Plaintiff I hereby certify that the above names are correct and that the precise residence address of the judgment creditor is CITIMORTGAGE INC. F/K/A ASSOCIATES HOME EQUITY CDC INC. 1000 Technology Drive MS 730 O'Fallon, MO 63368-2240 and that the name(s) and last known address(es) of the Defendant(s) is/are DONNA A. HARPER, SCI Muncy P.O. Box 180 Inmate# OP1907 Muncy, PA 17756, SARAH G. HARPER, 221 South Penn Street Shippensburg, PA 17257 and HARRIET D. SPRAGLIN A/K/A HARRIET D. HARPER, 110 Britton Road Shippensburg, PA 17257; GOLDB CK McCAFFERTY & McKEEVER BY: Michael T. McKeever Attorney for Plaintiff ASSESSMENT OF DAMAGES TO THE PROTHONOTARY: Kindly assess the damages in this case to be as follows: Principal Balance Interest from 05/01/2008 through 11/12/2009 Reasonable Attorney's Fee Late Charges Costs of Suit and Title Search Escrow Payments Due 0 X $0.00 Delinquent Expense Total Servicing Fees $68,420.77 $13,481.09 $3,421.04 $0.00 $900.00 $0.00 $755.23 $47.00 $87,025.13 GOLD ECK McCAFFERTY & McKEEVER BY: Michael T. McKeever Attorney for Plaintiff AND NOW, this 17A.. day of 1000 , 2009 damages are assessed as above. Prothy `'?^ 0 R T1 V17 PH2:23 $ly.ov ?? I?.Ld., 0-led soss7y M141 tE- Ma L Ll?( GOLDBECK McCAFFERTY & McKEEVER BY: Michael T. McKeever Attorney I.D.#56129 Suite 5000 -Mellon Independence Center 701 Market Street Philadelphia, PA 19106-1532 215-627-1322 i~_._..; ~ ,,~~.. ZG;D F~3 26 Pi ~~ 27 77176FC CF: 07/23/2009 SD: 03/03/2010 $87,025.13 CITIMORTGAGE INC. F/K/A ASSOCIATES HOME EQUITY CDC INC. 1000 Technology Drive MS 730 O'Fallon, MO 63368-2240 Plaintiff vs. DONNA A. HARPER SARAH G. HARPER HARRIET D. SPRAGLIN A/K/A HARRIET D. HARPER Mortgagor(s) and DONNA A. HARPERRecord Owner(s) 221 South Penn Street Shippensburg, PA 17257 Defendant(s) 1N THE COURT OF COMMON PLEAS of Cumberland County CIVIL ACTION -LAW ACTION OF MORTGAGE FORECLOSURE Term No. 09-4987 CERTIFICATE OF SERVICE PURSUANT TO Pa.R.C.P. 3129.2 (c) (2) Michael T. McKeever, Esquire, Attorney for Plaintiff, hereby certifies that service on the Defendants of the Notice of Sheriff Sale was made by: Personal Service by the Sheriffs Office/competent adult (copy of return attached). ( ) Certified mail by Michael T. McKeever (original green Postal return receipt attached). ( ) Certified mail by Sheriffs Office. ( ) Ordinary mail by Michael T. McKeever, Esquire to Attorney for Defendant(s) of record (proof of mailing attached). ( ) Acknowledgment of Sheriffs Sale by Attorney for Defendant(s) (proof of acknowledgment attached). ( ) Ordinary mail by Sheriffs Office to Attorney for Defendant(s) of record. IF SERVICE WAS ACCOMPLISHED BY COURT ORDER. ( ) Premises was posted by Sheriffs Office/competent adult (copy of return attached). ( ) Certified Mail & ordinary mail by Sheriff s Office (copy of return attached). ( ) Certified Mail & ordinary mail by Michael T. McKeever (original receipt(s) for Certified Mail attached). ( ) Published in accordance with court order (copy of publication attached). Pursuant to the Affidavit under Rule 3129 (copy attached), service on all lienholders (if any) has been made by ordinary mail by Michael T. McKeever, Esquire (copies of proofs of mailing attached). 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G • m d g -, ~ ~• ~ C ~ v ~ W ~ ~ ro~ ~ x e ~m LL ~~ ~ ° ~ ' ~ o . ~ ~ a ~ ~ ~ . ~ ~_° o ~ ~ Z z d F- ~ ~ U ~ ~ Q ~ ~ ~ }x~ a ~ A a6 LL ~ O b W b ~ a~~w Z C7 m j o^oo ~ a ~ Q E ~ Z m ~ ~ Sg E »- ~ m U o Z p~ t„~ ~ o , `o ~ ~ O~ ~. a0 O ~ U p' ~ i m c ~ ~°~ a 4 ~ V a Z mo ~ 7 ? a 0 o ~UOw~~ $ ~ L L O ~o ~ a W~ m ^^^^ ° Z c g o ~ ~ p- a U~om -~ ~Um ~ ~ U Z c~3~Q U~U a ~~ `op a ~ ~~ a ~ c W o a w z ~, a' o ~a ~ a w o e tt-- a ~ a `° N YoW ¢<30~C-~M ~~~w m ~~ in {{~ T ~J O ~~ Z v ,~ = _ E- Z Q ~ p = ~ ~ CV @7 ~ U7 fQ 1~ 00 ~ 1- 1 c 0 a c 0 a m `o c L Y H Ea U `o a 0 0 N m h. a~`o M 0 a 0 0 N M O M O c0 as (O C 7 O V v c m t U U LL m h ti ti Q w n. a Q Q Q Z Z O ucnn.a~ SHERIFF'S OFFICE OF CUAABERLAND COUNTY Ronny R Anderson Sheriff titi14 ai. ~u+ra,~ Jody S Smith ~~ ~~ ~' Chief Deputy * , ~;;' :' Edward L Schorpp ' ~ -~~~"~'~"' SO/!ClfOr 4FFlGE O?` r+~ S~RlFF Citimortgage Inc vs. Harriet D. Harper Case Number 2009-4987 SHERIFF'S RETURN OF SERVICE 01/14/2010 Timothy Black, Deputy Sheriff, who being duly sworn according to law, states that on 12/28/09 at 1355 hours, he served a true copy of the within Real Estate Writ, Notice and Description, in the above entitled action, upon the within named defendant, to wit: Harriet D. Spraglin, by making known unto, Harriet D. Spraglin, personally, at, 110 Britoon Road, Shippensburg, Cumberland County, Pennsylvania its contents and at the same time handing to her personally the said true and correct copy of the same. 01/14/2010 Shawn Harrison, Deputy Sheriff, who being duly sworn according to faw, states that on 1211$/09 at 1955 hours, he posted a true copy of the within Real Estate Writ, Notice, Paster and Description, in the above entitled action, upon the property of Harriet D. Harper, a/k/a Harriet D. Harper, Sarah G. Harper, Donna A. Harper, located at, 221 South Penn Street, Shippensburg, Cumberland County, Pennsylvania according tc law. 09/14!2010 Ronny R. Anderson, Sheriff, who being duly sworn according to law, states that he made a diligent search and inquiry for the within named defendant to wit: Sarah G. Harper, but was unable to locate her in his bailiwick. He therefore returns the within Real Estate Writ, Notice of Sale and Description as NOT FOUND as to the defendant Sarah G. Harper, per Grandaughter Marian Rideout, stated to deputies that defendant is deceased. :~; c«atty5i,te Sr~rtrt, Taz~•.dt, Irc. ProVest -Affidavit Page 77 of 94 uiiitiiuniii IN THE COMMON PLEAS COURT OF CUMBERLAND COUNTY PENNSYLVANIA CITIMORTGAGE INC. F/K/A ASSOCIATES HOME EQUITY CDC INC.; et seq. Plaintiff (Petitioner) CASE and/or DOCKET No.: 09-4987 Sherltl's Sale Date: 03/03/2010 V. DONNA A. HARPER ; et aL Defendant (Respondent) AFFIDAVIT OF SERVICE Complaint ~ Summons ~ OWer: NOTICE OF SHERIF'F'S SALE OF REAL PROPERTY I, MATTHEW PSILLAS, certify that I am eighteen years of age or older and that I am not a party to the action nor an employee nor relative of a parry ,and that I served and made known to the person served, DONNA A. HARPER ; ct al. the above process on the 25 day of November, 2009, at 1: l2 o'clock, PM, at SCI CAMBRIDGE SPRINGS -451 FULLERTON AVENUE -INMATE # OPI907 CAMBRIDGE SPRINGS, PA 16403 ,County of Cumberland, Commonwealth of Pennsylvania: Manner of Service: J By handing a copy to the Defendant(s) Description: Approximate Age 66-70 Height ~ Weight 12~ Race BLACK Sex FEMALE Hair GREY Military Status: ~ No ~ Yes Branch: Commonwealth of Pennsylvania ) SS: County of Cumberland ) Before me, the undersigned notary public, this day, personally, appeared J-r vVl-"" p~ ~sl I l.~ll.s to me known, who being duly sworn according to law, deposes the following: [ hereby sw a facts set forth in the foregoing Affidavit of Service are true and correct. Subscribed and sworn to before me (Signature of Affiant) this ~ day of D~.e- , 20~_. File Number. 77176FC Notary Public i ~`?:~,,,,,.^,+Y'. i~. li•t„ ~l~f ,^^lt 1'F-.ii ~//++~~ F'tyt(~:c. . Y~iiW1~i~~LS~11 !twit:.,-Li~l:tJ VC3rty ~fi' iC.il!!;~~i4fi ~ ~;)im~; %4ti`;i!iCer ~, cl:~:i9 http s://www.provest.us/psoffice/UnderProcess.aspx?RequestID=21 b49772-18bb-4f18-8 Se... 12! 1 /2009 GOLDBECK McCAFFERTY & McKEEVER By: Michael McKeever Attorney I.D. #56129 Suite 5000 -Mellon Independence Center 701 Market Street Philadelphia, PA 19106 (215)825-6303 Attorney for Plaintiff CITIMORTGAGE INC. F/K/A ASSOCIATES HOME EQUITY CDC INC. Plaintiff vs. DONNA A. HARPER, SARAH G. HARPER and HARRIET D. SPRAGLIN A/K/A HARRIET D. HARPER Mortgagor(s) and Record Owner(s) 221 South Penn Street Shippensburg, PA 17257 Defendant(s) IN THE COURT OF COMMON PLEAS OF Cumberland COUNTY CNIL ACTION -LAW ACTION OF MORTGAGE FORECLOSURE Term No. 09-4987 SUGGESTION OF DEATH It is respectfully suggested that Defendant SARAH G. HARPER is deceased, having departed this life on December 10, 2009. Accordingly, as Defendants owned the property which is the subject of this Action of Mortgage Foreclosure as Joint Tenants with the Right of Survivorship, by operation of law, title vests solely in DONNA A. HARPER and HARRIET D. SPRAGLIN A/K/A HARRIET D. HARPER. GOLDBECK McCAFFERTY & McKEEVER BY: Michael McKeever Attorney for Plaintiff GOLDBECK McCAFFERTY & McKEEVER BY: Michael T. McKeever Attorney I.D.#56129 Suite 5000 -Mellon Independence Center 701 Market Street Philadelphia, PA 19106-1532 215-627-1322 Attorney for Plaintiff CITIMORTGAGE INC. F/K/A ASSOCIATES HOME EQUITY CDC INC. 1000 Technology Drive MS 730 O'Fallon, MO 63368-2240 Plaintiff vs. DONNA A. HARPER SARAH G. HARPER HARRIET D. SPRAGLIN A/K/A HARRIET D. HARPER Mortgagor(s) and DONNA A. HARPERRecord Owner(s) 221 South Penn Street Shippensburg, PA 17257 Defendant(s) Term No. 09-4987 SUPPLEMENTAL AFFIDAVIT PURSUANT TO RULE 3129 CITIMORTGAGE INC. F/K/A ASSOCIATES HOME EQUITY CDC INC., Plaintiff in the above action, by its attorney, Michael T. McKeever, Esquire, sets forth as of the date the praecipe for the writ of execution was filed the following information concerning the real property located at: 221 South Penn Street Shippensburg, PA 17257 1.Name and address of Owner(s) or Reputed Owner(s): DONNA A. HARPER SCI Cambridge Springs Inmate# OP1907 451 Fullerton Avenue Cambridge Springs, PA 16403 SARAH G. HARPER 221 South Penn Street Shippensburg, PA 17257 IN THE COURT OF COMMON PLEAS of Cumberland County CIVIL ACTION -LAW ACTION OF MORTGAGE FORECLOSURE HARRIET D. SPRAGLIN A/K/A HARRIET D. HARPER 110 Britton Road Shippensburg, PA 17257 2. Name and address of Defendant(s) in the judgment: DONNA A. HARPER SCI Cambridge Springs Inmate# OP1907 451 Fullerton Avenue Cambridge Springs, PA 16403 SARAH G. HARPER 221 South Penn Street Shippensburg, PA 17257 HARRIET D. SPRAGLIN A/K/A HARRIET D. HARPER 110 Britton Road Shippensburg, PA 17257 3. Name and last known address of every judgment creditor whose judgment is a record lien on the property to be sold: PA DEPARTMENT OF PUBLIC WELFARE -Bureau of Child Support Enforcement Health and Welfare Bldg. -Room 432 Harrisburg, PA 17105-2675 DOMESTIC RELATIONS OF CUMBERLAND COUNTY PO Box 320 Cazlisle, PA 17013 NCO PORTFOLIO MGN/ASSIGN OF MRNA c/o Jorge M. Pereira 101 North Cedar Crest Boulevard Allentown, PA 18104 CUMBERLAND COUNTY ADULT PROBATION 1 Courthouse Square Carlisle, PA 17013 4. Name and address of the last recorded holder of every mortgage of record: 5. Name and address of every other person who has any record interest in or record lien on the property and whose interest may be affected by the sale: 6. Name and address of every other person of whom the plaintiff has knowledge who has any record interest in the property which may be affected by the sale. 7. Name and address of every other person of whom the plaintiff has knowledge who has any interest in the property which may be affected by the sale. COMMONWEALTH OF PENNSYLVANIA DEPARTMENT OF REVENUE INHERITANCE TAX DIVISION 1131 Strawberry Square 6th Floor Harrisburg, PA 17128 INTERNAL REVENUE SERVICE -SPECIAL PROCEDURES BRANCH 1001 Liberty Avenue Thirteenth Floor, Suite 1300 Pittsburgh, PA 15222 DEPARTMENT OF PUBLIC WELFARE ESTATE RECOVERY PROGRAM P.O. Box 8486, Willow Oak Building Harrisburg, PA 17105-8486 CRYSTAL H. CARRAWAY 2247 NORTH FOURTH STREET HARRISBURG, PA 17110 SAMUEL V. HARPER 305 FARMINGTON DRIVE SHIPPENSBURG, PA 17257 TENANTS/OCCUPANTS 221 South Penn Street Shippensburg, PA 17257 (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: February 25, 2010 v - ~ GOLDBECK McCAFF TY & McKEEVER BY: Keith C. Halili Legal Secretary SHERIFF'S OFFICE OF CUMBERLAND COUNTY . Ronny R Anderson ~1i.,~(}-+''t''',,,,~ Sheriff ~~ '°~~-~•- Jody S Smith ~° '"d Chief Deputy ~'~ ~ ~ ~~3R t ~ ~ 9+ L Edward L Schorpp ~(, Solicitor (;~''~~~-~~~.~."d~'} r.~'~h'V?}( ~I'ti~~L~ Citimortgage Inc vs. Case Number Harriet D. Harper (et al.) 2009-4987 SHERIFF'S RETURN OF SERVICE 01/14/2010 Timothy Black, Deputy Sheriff, who being duly sworn according to law, states that on 12/28/09 at 1355 hours, he served a true copy of the within Real Estate Writ, Notice and Description, in the above entitled action, upon the within named defendant, to wit: Harriet D. Spraglin, by making known unto, Harriet D. Spraglin, personally, at, 110 Britoon Road, Shippensburg, Cumberland County, Pennsylvania its contents and at the same time handing to her personally the said true and correct copy of the same. 01/14/2010 Shawn Harrison, Deputy Sheriff, who being duly sworn according to law, states that on 12/18/09 at 1955 hours, he posted a true copy of the within Real Estate Writ, Notice, Poster and Description, in the above entitled action, upon the property of Harriet D. Harper, a/k/a Harriet D. Harper, Sarah G. Harper, Donna A. Harper, located at, 221 South Penn Street, Shippensburg, Cumberland County, Pennsylvania according tc law. 01/14/2010 Ronny R. Anderson, Sheriff, who being duly sworn according to law, states that he made a diligent search and inquiry for the within named defendant to wit: Sarah G. Harper, but was unable to locate her in his bailiwick. He therefore returns the within Real Estate Writ, Notice of Sale and Description as NOT FOUND as to the defendant Sarah G. Harper, per Grandaughter Marian Rideout, stated to deputies that defendant is deceased. 03/03/2010 Ronny R. Anderson, 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 March 3, 2010 at 10:00 o'clock A.M. He sold the same for the sum of $1.00 to Attorney Micheal McKeever, on behalf of ,being the buyer in this execution, paid to Sheriff Ronny R. Anderson, the sum of $ SHERIFF COST: $1,131.19 April 14, 2010 SO ANSWERS, RON R ANDERSON, SHERIFF ~ ~Q~e~ ~~o ~~ 5 ~~ l~ V"~ ~[ jZS~ ~-~~~ ~aS Goldbeck McCafferty & McKeever BY: Michael T. McKeever Attorney I.D. #56129 Suite 5000 -Mellon Independence Center 701 Market Street Philadelphia, PA 19106 215-627-1322 Attorney for Plaintiff CITIMORTGAGE INC. F/K/A ASSOCIATES HOME EQUITY CDC INC. 1000 Technology Drive MS 730 O'Fallon, MO 63368-2240 Plaintiff vs. DONNA A. HARPER SARAH G. HARPER HARRTF:T D. SPRAGLIN A/K/A HARRIET D. HARPER (Mortgagor(s) and Record Owner(s)) 221 South Penn Street Shippensburg, PA 17257 Defendant(s) IiV THE COURT OF COMMON PLEAS of Cumberland County CNIL ACTION -LAW ACTION OF MORTGAGE FORECLOSURE No. 09-4987 AFFIDAVIT PURSUANT TO RULE 3129 CITIMORTGAGE INC. F/K/A ASSOCIATES HOME EQUITY CDC INC., Plaintiff in the above action, by its attorney, Michael T. McKeever, Esquire, sets forth as of the date the praecipe for the writ of execution was filed the following information concerning the real property located at: 221 South Penn Street Shippensburg, PA 17257 1.Name and address of Owner(s) or Reputed Owner(s): DONNA A. HARPER SCI Muncy P.O. Box 180 Inmate# OP1907 Muncy, PA 17756 SARAH G. HARPER 221 South Penn Street Shippensburg, PA 17257 HARRIET D. SPRAGLIN A/K/A HARRIET D. HARPER 110 Britton Road Shippensburg, PA 17257 2. Name and address of Defendant(s) in the judgment: DONNA A. HARPER SCI Muncy P.O. Box 180 Inmate# OP 1907 Muncy, PA 17756 SARAH G. HARPER 221 South Penn Street Shippensburg, PA 17257 ` HARRIET D. SPRAGLIN A/K/A HARRIET D. HARPER 110 Britton Road Shippensburg, PA 17257 3. Name and last known address of every judgment creditor whose judgment is a record lien on the property to be sold: DOMESTIC RELATIONS OF CUMBERLAND COUNTY PO Box 320 Carlisle, PA 17013 PA DEPARTMENT OF PUBLIC WELFARE -Bureau of Child Support Enforcement Health and Welfare Bldg. -Room 432 Harrisburg, PA 17105-2675 4. Name and address of the last recorded holder of every mortgage of record: 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. COMMONWEALTH OF PENNSYLVANIA DEPARTMENT OF REVENUE INHERITANCE TAX DIVISION 1131 Strawberry Square 6th Floor Harrisburg, PA 17128 INTERNAL REVENUE SERVICE -SPECIAL PROCEDURES BRANCH 1001 Liberty Avenue Thirteenth Floor, Suite 1300 Pittsburgh, PA 15222 DEPARTMENT OF PUBLIC WELFARE ESTATE RECOVERY PROGRAM P.O. Box 8486, Willow Oak Building Harrisburg PA 17105-8486 TENANTS/OCCUPANTS 221 South Penn Street Shippensburg PA 17257 CRYSTAL H. CARRAWAY 2247 NORTH FOURTH STREET HARRISBURG, PA 17110 SAMUEL V. HARPER 305 FARMINGTON DRIVE SHIPPENSBURG, PA 17257 (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 12, 2009 c~rnc~ GOLDBECK McCAFFERTY & McKEEVER BY: Michael T. McKeever, Esq. Attorney for Plaintiff 09-4987 GOLDBECK McCAFFERTY & McKEEVER BY: Michael T. McKeever Attorney I.D.#56129 Suite 5000- Mellon Independence Center 701 Market Street Philadelphia, PA 19106 215-825-6318 Attorney for Plaintiff CITIMORTGAGE INC. F/K/A ASSOCIATES HOME EQUITY CDC INC. 1000 Technology Drive MS 730 O'Fallon, MO 63368-2240 Plaintiff vs. DONNA A. HARPER SARAH G. HARPER HARRIET D. SPRAGLIN A/K/A HARRIET D. HARPER Mortgagor(s) and HARPER, DONNA A.Record Owner(s) 221 South Penn Street Shippensburg, PA 17257 Defendants; IN THE COURT OF COMMON PLEAS of Cumberland County CNIL, ACTION -LAW ACTION OF MORTGAGE FORECLOSURE Term No. 09-4987 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: I-IARPER, DONNA A DONNA A. HARPER 221 South Penn Street Shippensburg, PA 17257 Your house at 221 South Penn Street, Shippensburg, PA 17257 is scheduled to be sold at Sheriff s Sale on Wednesday, March 03, 2010, at 10:00 AM, in Commissioners Hearing Rm 2nd FL Courthouse to enforce the court judgment of $87,025.13 obtained by CITIMORTGAGE INC. F/K/A ASSOCIATES HOME EQUITY CDC 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: 09-4987 1. The sale will be cancelled if you pay to CITIMORTGAGE INC. F/K/A ASSOCIATES HOME EQUITY CDC INC., the back payments, late charges, costs and reasonable attorney's fees due. To fmd out how much you must pay call our office at 215-825-6329 or 1-866-413-2311. 2. You may be able to stop the sale by filing a petition asking the Court to strike or open judgment, if the judgment was improperly entered. You may also ask the Court to postpone the sale for good cause. 3. You may also be able to stop the sale through other legal proceedings 4. You may need an attorney to assert your rights. The sooner you contact one, the more chance you will have of stopping the sale. (See notice below on how to obtain an attorney). YOU MAY STILL BE ABLE TO SAVE YOUR PROPERTY AND YOU HAVE OTHER RIGHTS EVEN IF THE SHERIFF'S SALE DOES NOT TAKE PLACE. 1. If the Sheriffs Sale is not stopped, your property will be sold to the highest bidder. You may find out the price bid price by calling the Sheriff of 717-240-6390. 2. You may be able to petition the Court to set aside the sale if the bid price was grossly inadequate compared to the value of your property. 3. The sale will go through only if the buyer pays the Sheriff the full amount due in the sale. To fmd out if this has happened, you may call the Sheriff of 717-240-6390. 4. If the amount due from the Buyer is not paid to the Sheriff, you will remain the owner of the property as if the sale never happened. 5. You have a right to remain in the property until the full amount due is paid to the Sheriff and the Sheriff gives a deed to the buyer. At that time, the buyer may bring legal proceedings to evict you. 6. You may be entitled to a share of the money which was paid for your house. A schedule of distribution of the money bid for your house will be filed by the Sheriff within thirty (30) days from the date of the Sheriffs Sale. This schedule will state who will be receiving that money. The money will be paid out in accordance with this schedule unless exceptions (reasons why the proposed distribution is wrong) are filed with the Sheriff within ten (10) days after the schedule of distribution is filed. 7. You may also have other rights and defenses, or ways of getting your house back, if you act immediately after the sale. 8. You may contact the Foreclosure Resource Center: http•//www philadelphiafed org,/foreclosure/ YOU SHOULD TAKE THIS PAPER TO YOUR LAWYER AT ONCE. IF YOU DO NOT HAVE A LAWYER OR CANNOT AFFORD ONE, GO TO OR TELEPHONE THE OFFICE LISTED BELOW TO FIND OUT WHERE YOU CAN GET LEGAL HELP. CUMBERLAND COUNTY BAR ASSOCIATION 2 Liberty Avenue Carlisle, PA 17013 LEGAL SERVICES INC 8 Irvine Row Carlisle, PA 17013 09-4987 717-243-9400 09-4987 Resources available for Homeowners in Foreclosure ACT NOW! Even though your lender (and our client) has filed an Action of Mortgage Foreclosure against you, you still may be able to SAVE YOUR HOME FROM FORECLOSURE. 1). Call an attorney. For referrals to a qualified attorney call either of the following numbers: or 717-243-9400. 2). Call the Consumer Credit Counseling Agency at 1-800-989-2227 for free counseling. 3). Visit HUD'S website www.hud.gov for Help for Homeowners Facing the Loss of Their Homes. 4). Pennsylvania Housing Finance Agency also offers other loan programs that may assist homeowners in default. Please See the PHFA website http://www.nhfa.org/consumers/homeowners/real aspx. 5). Call the Plaintiff (your lender) at and ask to speak to someone about Loss Mitigation or Home Retention options. 6). Call or contact our office to request the amount to bring the account current, or payoff the mortgage or request a Loan Workout /Home Retention Package. Call our toll free number at 1-866-413-2311 or via email at homeretention(a,~oldbecklaw com. Call Seth at 215-825-6329 or fax 215-825-6429. The figure and/or package you requested will be mailed to the address that you request or faxed if you leave a message with that information. The attorney in charge of our firm's Homeowner Retention Department is David Fein who can be reached at 215-825-6318 or Fax: 215-825-6418. Please reference our Attorney File Number of 77176FC. Para informacion en espanol puede communicarse con Loretta a1215-825-6344. All that certain parcel of land situated in Shippensburg Borough, Cumberland County, Pennsylvania, and being more fully described in Deed Book 121, page 1068, et seq., recorded on May 10, 1995, among the land records of Cumberland County, Pennsylvania. ALL THAT certain tract of ground with a frame dwelling house and other improvements erected, thereon, situate in the Borough of Shippensburg, County of Cumberland and Commonwealth of Pennsylvania, bounded and described as follows: BEGINNING at a fence post a the end of a public alley where it meets the right-of--way of the Rending Company, and opposite land now or formerly of the John Hosfeld Estate; thence northwardly on the West side of said alley; sixty-three(63) feet seven(07)inches to a stake in the middle of an intersecting private alley; thence westwardly by the middle of said private alley, one hundred ten (110) feet six (06) inches to a stake in the middle of said alley; thence southwardly by a line along a boundary fence to a fence post,a corner on the edge of the right-of--way of the said Reading Company; thence eastwardly by the said right-of--way , twelve(12) feet seven(07) inches to a small locust tree close to the fence; thence continuing eastwardly with the said fence along the right-of--way turning slightly northward from the locust tree, one hundred (100) feet to the fence post, the place of BEGINNING TOGETHER with the right to use a private alley extending along the North side of the property from the said public alley westwardly to the western limit of the property and thence along and through other property to Penn Street in the Borough of Shippensburg. The use of this private alley is in common with the use of the same by others adjoining it. For information only, the property is commonly known as 221 South Penn Street, Shippensburg Borough, Cumberland County, Pennsylvania, and erroneously designated as 4788 Sweetbrier Drive, Harrisburg, Cumerland County in the mortgage recorded May 24, 2000 in Deed Book 1613, at page 1131, et seq. TAX PARCEL NO: 33-34-2415-173 BEING KNOWN AS: 221 South Penn Street, Shippensburg, PA 17257 BEING the same premises which Sarah G. Harper and Harriet D. Harper by Deed dated 10127/05 and recorded 11/1/OS in Book 271 Page 3569 granted and conveyed unto Harriet D. Harper, Doris A. Harper (deceased) and Donna A. Harper All that certain parcel of land situated in Shippensburg Borough, Cumberland County, Pennsylvania, and being more fully described in Deed Book 121, page 1068, et seq., recorded on May 10, 1995, among the land records of Cumberland County, Pennsylvania. ALL THAT certain tract of ground with a frame dwelling house and other improvements erected, thereon, situate in the Borough of Shippensburg, County of Cumberland and Commonwealth of Pennsylvania, bounded and described as follows: BEGINNING at a fence post a the end of a public alley where it meets the right-of--way of the Rending Company, and opposite land now or formerly of the John Hosfeld Estate; thence northwardly on the West side of said alley; sixty-three(63) feet seven(07)inches to a stake in the middle of an intersecting private alley; thence westwardly by the middle of said private alley, one hundred ten (110) feet six (06) inches to a stake in the middle of said alley; thence southwardly by a line along a boundary fence to a fence post,a corner on the edge of the right-of--way of the said Reading Company; thence eastwardly by the said right-of--way , twelve(12) feet seven(07) inches to a small locust tree close to the fence; thence continuing eastwardly with the said fence along the right-of--way turning slightly northward from the locust tree, one hundred (100) feet to the fence post, the place of BEGINNING TOGETHER with the right to use a private alley extending along the North side of the property from the said public alley westwardly to the western limit of the property and thence along and through other property to Penn Street in the Borough of Shippensburg. The use of this private alley is in common with the use of the same by others adjoining it. For information only, the property is commonly known as 221 South Penn Street, Shippensburg Borough, Cumberland County, Pennsylvania, and erroneously designated as 4788 Sweetbrier Drive, Harrisburg, Cumerland County in the mortgage recorded May 24, 2000 in Deed Book 1613, at page 1131, et seq. TAX PARCEL NO: 33-34-2415-173 BEING KNOWN AS: 221 South Penn Street, Shippensburg, PA 17257 BEING the same premises which Sarah G. Harper and Harriet D. Harper by Deed dated 10/27/05 and recorded 11/1/OS in Book 271 Page 3569 granted and conveyed unto Harriet D. Harper, Doris A. Harper (deceased) and Donna A. Harper 09-4987 GOLDBECK McCAFFERTY & McKEEVER BY: Michael T. McKeever Attorney I.D.#56129 Suite 5000- Mellon Independence Center 701 Market Street Philadelphia, PA 19106 215-825-6318 Attorney for Plaintiff CITIMORTGAGE INC. F/K/A ASSOCIATES HOME EQUITY CDC INC. 1000 Technology Drive MS 730 O'Fallon, MO 63368-2240 Plaintiff vs. DONNA A. HARPER SARAH G. HARPER HARRiF.T D. SPRAGLIN A/K/A HARRIET D. HARPER Mortgagor(s) and HARPER, DONNA A.Record Owner(s) 221 South Penn Street Shippensburg, PA 17257 Defendants; IN THE COURT OF COMMON PLEAS of Cumberland County CNIL ACTION -LAW ACTION OF MORTGAGE FORECLOSURE Term No. 09-4987 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: IIARPER, SARAH G. SARAH G. HARPER 221 South Penn Street Shippensburg PA 17257 Your house at 221 South Penn Street, Shippensburg, PA 17257 is scheduled to be sold at Sheriffs Sale on Wednesday, March 03, 2010, at 10:00 AM, in Commissioners Hearing Rm 2nd FL Courthouse to enforce the court judgment of $87,025.13 obtained by CITIMORTGAGE INC. F/K/A ASSOCIATES HOME EQUITY CDC 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: 09-4987 1. The sale will be cancelled if you pay to CITIMORTGAGE INC. F/K/A ASSOCIATES HOME EQUITY CDC INC., the back payments, late charges, costs and reasonable attorney's fees due. To fmd out how much you must pay call our office at 215-825-6329 or 1-866-413-2311. 2. You may be able to stop the sale by filing a petition asking the Court to strike or open judgment, if the judgment was improperly entered- You may also ask the Court to postpone the sale for good cause. You may also be able to stop the sale through other legal proceedings. 4. You may need an attorney to assert your rights. The sooner you contact one, the more chance you will have of stopping the sale. (See notice below on how to obtain an attorney). YOU MAY STILL BE ABLE TO SAVE YOUR PROPERTY AND YOU HAVE OTHER RIGHTS EVEN IF THE SHERIFF'S SALE DOES NOT TAKE PLACE. 1. If the Sheriffs Sale is not stopped, your property will be sold to the highest bidder. You may find out the price bid price by calling the Sheriff of 717-240-6390. 2. You may be able to petition the Court to set aside the sale if the bid price was grossly inadequate compared to the value of your property. 3. The sale will go through only if the buyer pays the Sheriff the full amount due in the sale. To fmd out if this has happened, you may call the Sheriff of 717-240-6390. 4. If the amount due from the Buyer is not paid to the Sheriff, you will remain the owner of the property as if the sale never happened. 5. You have a right to remain in the property until the full amount due is paid to the Sheriff and the Sheriff gives a deed to the buyer. At that time, the buyer may bring legal proceedings to evict you. 6. You may be entitled to a share of the money which was paid for your house. A schedule of distribution of the money bid for your house will be filed by the Sheriff within thirty (30) days from the date of the Sheriffs Sale. This schedule will state who will be receiving that money. The money will be paid out in accordance with this schedule unless exceptions (reasons why the proposed distribution is wrong) are filed with the Sheriff within ten (10) days after the schedule of distribution is filed. 7. You may also have other rights and defenses, or ways of getting your house back, if you act immediately after the sale. 8. You may contact the Foreclosure Resource Center: http•//www philadelphiafed org/foreclosure/ YOU SHOULD TAKE THIS PAPER TO YOUR LAWYER AT ONCE. IF YOU DO NOT HAVE A LAWYER OR CANNOT AFFORD ONE, GO TO OR TELEPHONE THE OFFICE LISTED BELOW TO FIND OUT WHERE YOU CAN GET LEGAL HELP. CUMBERLAND COUNTY BAR ASSOCIATION 2 Liberty Avenue Carlisle, PA 17013 LEGAL SERVICES INC 8 Irvine Row Carlisle, PA 17013 717-243-9400 09-4987 Resources available for Homeowners in Foreclosure ACT NOW! Even though your lender (and our client) has filed an Action of Mortgage Foreclosure against you, you still may be able to SAVE YOUR HOME FROM FORECLOSURE. 1). Call an attorney. For referrals to a qualified attorney call either of the following numbers: or 717-243-9400. 2). Call the Consumer Credit Counseling Agency at 1-800-989-2227 for free counseling. 3). Visit HUD'S website www.hud.gov for Help for Homeowners Facing the Loss of Their Homes. 4). Pennsylvania Housing Finance Agency also offers other loan programs that may assist homeowners in default. Please See the PHFA website http://www.phfa.org/consumers/homeowners/real aspx. 5). Call the Plaintiff (your lender) at and ask to speak to someone about Loss Mitigation or Home Retention options. 6). Call or contact our office to request the amount to bring the account current, or payoff the mortgage or request a Loan Workout /Home Retention Package. Call our toll free number at 1-866-413-2311 or via email at homeretention(a~goldbecklaw com. Call Seth at 215-825-6329 or fax 215-825-6429. The figure and/or package you requested will be mailed to the address that you request or faxed if you leave a message with that information. The attorney in charge of our firm's Homeowner Retention Department is David Fein who can be reached at 215-825-6318 or Fax: 215-825-6418. Please reference our Attorney File Number of 77176FC. Para informacion en espanol puede communicarse con Loretta a1215-825-6344. All that certain parcel of land situated in Shippensburg Borough, Cumberland County, Pennsylvania, and being more fully described in Deed Book 121, page 1068, et seq., recorded on May 10, 1995, among the land records of Cumberland County, Pennsylvania. ALL THAT certain tract of ground with a frame dwelling house and other improvements erected, thereon, situate in the Borough of Shippensburg, County of Cumberland and Commonwealth of Pennsylvania, bounded and described as follows: BEGINNING at a fence post a the end of a public alley where it meets the right-of--way of the Rending Company, and opposite land now or formerly of the John Hosfeld Estate; thence northwardly on the West side of said alley; sixty-three(63) feet seven(07)inches to a stake in the middle of an intersecting private alley; thence westwardly by the middle of said private alley, one hundred ten (110) feet six (06} inches to a stake in the middle of said alley; thence southwardly by a line along a boundary fence to a fence post,a corner on the edge of the right-of--way of the said Reading Company; thence eastwardly by the said right-of--way , twelve(12) feet seven(07) inches to a small locust tree close to the fence; thence continuing eastwardly with the said fence along the right-of--way turning slightly northward from the locust tree, one hundred (100) feet to the fence post, the place of BEGINNING TOGETHER with the right to use a private alley extending along the North side of the property from the said public alley westwardly to the western limit of the property and thence along and through other property to Penn Street in the Borough of Shippensburg. The use of this private alley is in common with the use of the same by others adjoining it. For information only, the property is commonly known as 221 South Penn Street, Shippensburg Borough, Cumberland County, Pennsylvania, and erroneously designated as 4788 Sweetbriar Drive, Harrisburg, Cumerland County in the mortgage recorded May 24, 2000 in Deed Book 1613, at page 1131, et seq. TAX PARCEL NO: 33-34-2415-173 BEING KNOWN AS: 221 South Penn Street, Shippensburg, PA 17257 BEING the same premises which Sarah G. Harper and Harriet D. Harper by Deed dated 10127!05 and recorded 1'1/1/OS in Book 271 Page 3569 granted and conveyed unto Harriet D. Harper, Doris A. Harper (deceased) and Donna A. Harper 09-4987 GOLDBECK McCAFFERTY & McKEEVER BY: Michael T. McKeever Attorney I.D.#56129 Suite 5000- Mellon Independence Center 701 Market Street Philadelphia, PA 19106 215-825-6318 Attorney for Plaintiff CITIMORTGAGE INC. F/K/A ASSOCIATES HOME EQUITY CDC INC. 1000 Technology Drive MS 730 O'Fallon, MO 63368-2240 Plaintiff vs. DONNA A. HARPER SARAH G. HARPER HARRIET D. SPRAGLIN A/K/A HARRIET D. HARPER Mortgagor(s) and HARPER, DONNA A.Record Owner(s) 221 South Penn Street Shippensburg, PA 17257 Defendants; IN THE COURT OF COMMON PLEAS of Cumberland County CNIL, ACTION -LAW ACTION OF MORTGAGE FORECLOSURE Term No. 09-4987 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: SPRAGLIN, HARRIET D. A/K/A HARPER, HARRIET D. HARRIET D. SPRAGLIN A/K/A HARRIET D. HARPER 221 South Penn Street Shippensburg, PA 17257 Your house at 221 South Penn Street, Shippensburg, PA 17257 is scheduled to be sold at Sheriff s Sale on Wednesday, March 03, 2010, at 10:00 AM, in Commissioners Hearing Rm 2nd FL Courthouse to enforce the court judgment of $87,025.13 obtained by CITIMORTGAGE INC. F/K/A ASSOCIATES HOME EQUITY CDC 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: 09-4987 1. The sale will be cancelled if you pay to CITIMORTGAGE INC. F/K/A ASSOCIATES HOME EQUITY CDC INC., the back payments, late charges, costs and reasonable attorney's fees due. To fmd out how much you must pay call our office at 215-825-6329 or 1-866-413-2311. 2. You may be able to stop the sale by filing a petition asking the Court to strike or open judgment, if the judgment was improperly entered. You may also ask the Court to postpone the sale for good cause. 3. You may also be able to stop the sale through other legal proceedings 4. You may need an attorney to assert your rights. The sooner you contact one, the more chance you will have of stopping the sale. (See notice below on how to obtain an attorney). YOU MAY STILL BE ABLE TO SAVE YOUR PROPERTY AND YOU HAVE OTHER RIGHTS EVEN IF THE SHERIFF'S SALE DOES NOT TAKE PLACE. 1. If the Sheriffs Sale is not stopped, your property will be sold to the highest bidder. You may find out the price bid price by calling the Sheriff of 717-240-6390. 2. You may be able to petition the Court to set aside the sale if the bid price was grossly inadequate compared to the value of your property. 3. The sale will go through only if the buyer pays the Sheriff the full amount due in the sale. To fmd out if this has happened, you may call the Sheriff of 717-240-6390. 4. If the amount due from the Buyer is not paid to the Sheriff, you will remain the owner of the property as if the sale never happened. 5. You have a right to remain in the property until the full amount due is paid to the Sheriff and the Sheriff gives a deed to the buyer. At that time, the buyer may bring legal proceedings to evict you. 6. You may be entitled to a share of the money which was paid for your house. A schedule of distribution of the money bid for your house will be filed by the Sheriff within thirty (30) days from the date of the Sheriffs Sale. This schedule will state who will be receiving that money. The money will be paid out in accordance with this schedule unless exceptions (reasons why the proposed distribution is wrong) are filed with the Sheriff within ten (10) days after the schedule of distribution is filed. 7. You may also have other rights and defenses, or ways of getting your house back, if you act immediately after the sale. 8. You may contact the Foreclosure Resource Center: http://www.philadelphiafed.ore/foreclosure/ YOU SHOULD TAKE THIS PAPER TO YOUR LAWYER AT ONCE. IF YOU DO NOT HAVE A LAWYER OR CANNOT AFFORD ONE, GO TO OR TELEPHONE THE OFFICE LISTED BELOW TO FIND OUT WHERE YOU CAN GET LEGAL HELP. CUMBERLAND COUNTY BAR ASSOCIATION 2 Liberty Avenue Carlisle, PA 17013 LEGAL SERVICES INC 8 Irvine Row Carlisle, PA 17013 09-4987 717-243-9400 09-4987 Resources available for Homeowners in Foreclosure ACT NOW! Even though your lender (and our client) has filed an Action of Mortgage Foreclosure against you, you still may be able to SAVE YOUR HOME FROM FORECLOSURE. 1). Call an attorney. For referrals to a qualified attorney call either of the following numbers: or 717-243-9400. 2). Call the Consumer Credit Counseling Agency at 1-800-989-2227 for free counseling. 3). Visit HUD'S website www.hud.~ov for Help for Homeowners Facing the Loss of Their Homes. 4). Pennsylvania Housing Finance Agency also offers other loan programs that may assist homeowners in default. Please See the PHFA website http://www.phfa. org_Iconsumers/homeowners/real . aspx. 5). Call the Plaintiff (your lender) at and ask to speak to someone about Loss Mitigation or Home Retention options. 6). Call or contact our office to request the amount to bring the account current, or payoff the mortgage or request a Loan Workout /Home Retention Package. Call our toll free number at 1-866-413-2311 or via email at homeretention(a,~oldbecklaw.com. Call Seth at 215-825-6329 or fax 215-825-6429. The figure and/or package you requested will be mailed to the address that you request or faxed if you leave a message with that information. The attorney in charge of our firm's Homeowner Retention Department is David Fein who can be reached at 215-825-6318 or Fax: 215-825-6418. Please reference our Attorney File Number of 77176FC. Para informacion en espanol puede communicarse con Loretta a1215-825-6344. All that certain parcel of land situated in Shippensburg Borough, Cumberland County, Pennsylvania, and being more fully described in Deed Book 121, page 1068, et seq., recorded on May 10, 1995, among the land records of Cumberland County, Pennsylvania. ALL THAT certain tract of ground with a frame dwelling house and other improvements erected, thereon, situate in the Borough of Shippensburg, County of Cumberland and Commonwealth of Pennsylvania, bounded and described as follows: BEGINNING at a fence post a the end of a public alley where it meets the right-of--way of the Rending Company, and opposite land now or formerly of the John Hosfeld Estate; thence northwardly on the West side of said alley; sixty-three(63) feet seven(07)inches to a stake in the middle of an intersecting private alley; thence westwardly by the middle of said private alley, one hundred ten (110) feet six (06) inches to a stake in the middle of said alley; thence southwardly by a line along a boundary fence to a fence post,a corner on the edge of the right-of--way of the said Reading Company; thence eastwardly by the said right-of--way , twelve(12) feet seven(07) inches to a small locust tree close to the fence; thence continuing eastwardly with the said fence along the right-of--way turning slightly northward from the locust tree, one hundred (100) feet to the fence post, the place of BEGINNING TOGETHER with the right to use a private alley extending along the North side of the property from the said public alley westwardly to the western limit of the properly and thence along and through other property to Penn Street in the Borough of Shippensburg. The use of this private alley is in common with the use of the same by others adjoining it. For information only, the property is commonly known as 221 South Penn Street, Shippensburg Borough, Cumberland County, Pennsylvania, and erroneously designated as 4788 Sweetbriar Drive, Harrisburg, Cumerland County in the mortgage recorded May 24, 2000 in Deed Book 1613, at page 1131, et seq. TAX PARCEL NO: 33-34-2415-173 BEING KNOWN AS: 221 South Penn Street, Shippensburg, PA 17257 BEING the same premises which Sarah G. Harper and Harriet D. Harper by Deed dated 10/27/05 and recorded 1111/OS in Book 271 Page 3569 granted and conveyed unto Hamet D. Harper, Doris A. Harper (deceased) and Donna A. Harper • WRIT OF EXECUTION and/or ATTACHMENT COMMONWEALTH OF PENNSYLVANIA) NO 09-4987 Civil COUNTY OF CUMBERLAND) CIVIL ACTION -LAW TO THE SHERIFF OF CUMBERLAND COUNTY: To satisfy the debt, interest and costs due CITIMORTGAGE, INC. F/K/A ASSOCIATES HOME EQUITY CDC, INC., Plaintiff (s) From DONNA A. HARPER, SARAH G. HARPER, HARRIET D. SPRAGLIN A/WA HARRIET D. HARPER (1) You are directed to levy upon the property of the defendant (s)and to sell SEE LEGAL DESCRIPTION . (2) You are also directed to attach the property of the defendant(s) not levied upon in the possession of GARNISHEE(S) as follows: and to notify the garnishee(s) that: (a) an attachment has been issued; (b) the garnishee(s) is enjoined from paying any debt to or for the account of the defendant (s) and from delivering any property of the defendant (s) or otherwise disposing thereof; (3) If property of the defendant(s) not levied upon an subject to attachment is found in the possession of anyone other than a named garnishee, you are directed to notify him/her that he/she has been added as a garnishee and is enjoined as above stated. Amount Due $87,025.13 L.L. $.50 Interest FROM 11/13/2009 TO DATE OF SALE PER DIEM AT $21.73 Atty's Comm % Due Prothy $2.00 Atty Paid $392.80 Other Costs Plaintiff Paid Date: NOVEMBER 17, 2009 R. Long, Prothonotary (Seal) BY: .~ Q.10~ REQUESTING PARTY: Name MICHAEL T. MCKEEVER, ESQUIRE Address: GOLDBECK MCCAFFERTY &MCKEEVER SUITE 5000 - MELLON INDEPENDENCE CENTER 701 MARKET STREET PHILADELPHIA, PA 19106 Attorney for: PLAINTIFF Deputy Telephone: 215-627- l 322 Supreme Court ID No. 56129 On November 25 2009 the Sheriff levied upon the defendant's interest in the real property situated in Shippensburg Borough, Cumberland County, PA, Known and numbered 221 South Penn Street, Shippensburg, more fully described on Exhibit "A" filed with this writ and by this reference incorporated herein. Date: November 25, 2009 By. ,~. `~ ,~ r l~ Real Estate Coordinator ~~.: f, ~ -a ~~~.~ -~ .~n_:3 ,~' ~~ ,.^; ~. A: .' \1~~ PROOF OF PUBLICATION OF NOTICE IN CUMBERLAND LAW JOURNAL (Under Act No. 587, approved May 16, 1929), P. L.1784 COMMONWEALTH OF PENNSYLVANIA COUNTY OF CUMBERLAND ss. Lisa Marie Coyne, Esquire, Editor of the Cumberland Law Journal, of the County and State aforesaid, being duly sworn, according to law, deposes and says that the Cumberland Law Journal, a legal periodical published in the Borough of Carlisle in the County and State aforesaid, was established January 2, 1952, and designated by the local courts as the official legal periodical for the publication of all legal notices, and has, since January 2, 1952, been regularly issued weekly in the said County, and that the printed notice or publication attached hereto is exactly the same as was printed in the regular editions and issues of the said Cumberland Law Journal on the following dates, viz: January 22 January 29 and February 5 2010 Affiant further deposes that he is authorized to verify this statement by the Cumberland Law Journal, a legal periodical of general circulation, and that he is not interested in the subject matter of the aforesaid notice or advertisement, and that all allegations in the foregoing statements as to time, place and character of publication are true. ,~-- L' a Marie Coyne, Editor SWORN TO AND SUBSCRIBED before me this 5 day of February, 2010 ~J / ~ C2~ .. _ Notary ..... NOTAR3AL SEAL ~~ DEEORt~.H A COLLINS NoiQry Public C.ARLISL E 3080, C:U;r!Ci_RLAND COUNTY n My ~..~mr,:,i~sion Expires Apr 28, 2010 wit No. aoo9-a9s~ civil Citimortgage Inc vs. Harriet D. Spraglin a/k/a Harriet D. Hazper Sarah G. Hazper Donna A. Harper Crystal Caraway c/o Sarah G. Hazper Atty: Michael McKeever All that certain parcel of land situated in Shippensburg Borough, Cumberland County, Pennsylvania, and being more fully described in Deed Book 121, page 1068, et seq., recorded on May 10, 1995, among the land records of Cumberland County, Pennsylvania. ALL THAT certain tract of ground with a frame dwelling house and other improve- ments erected, thereon, situate in the Borough of Shippensburg, County of Cumberland and Commonwealth of Pennsylvania, bounded and de- scribed as follows: BEGINNING at a fence post a the end of a public alley where it. meets the right-of-way of the Rending Company, and opposite land now or formerly of the John Hosfeld Estate; thence northwardly on the West side of said alley; sixty-three(63) feet seven(07)inches to a stake in the middle of an intersecting Private al- ley; thence westwardly by the middle of said private alley, one hundred ten (110) feet six (06) inches to a stake in the middle of said alley; thence southwazdly by a line along a bound- ary fence to a fence post,a corner on the edge of the right-of-way of the said Reading Company; thence eastwazdly by the said right-of-way, twelve(12) feet seven(07) inches to a small locust tree close to the fence; thence continuing eastwazdly with the said fence along the right-of-way turning slightly northward from the locust tree, one hundred (100) feet to the fence post, the place of BE- GINNING. TOGETHER with the right to use a private alley extending along the North side of the property from the said public alley westwardly to the western limit of the property and thence along and through other prop- erty to Penn Street in the Borough of Shippensburg. The use of this private alley is in common with the use of the same by others adjoining it. For information oniy, the property is commonly known as 221 South Penn Street, Shippensburg Borough, Cumberland County, Pennsylva- nia. and erroneously designated as 4788 Sweetbriaz Drive, Harrisburg, Cumerland County in the mortgage recorded May 24, 2000 in Deed Book 1613, at page 1131, et seq. TAX PARCEL NO: 33-34-2415- 173. BEING KNOWN AS: 221 South Penn Street, Shippensburg, PA 17257. COMMONWEALTH OF PENNSYLVANIA COUNTY OF CUMBERLAND SS: I, Robert P. Ziegler, Recorder of Deeds in and for said County and State do hereby certify that the Sheriff s Deed in which CITIMORTGAGE INC is the grantee the same having been sold to said grantee on the 3RD day of MARCH A.D., 2010, under and by virtue of a writ Execution issued on the 17TH day of NOV, A.D., 2009, out of the Court of Common Pleas of said County as of Civil Term, 2009 Number 4987, at the suit of CITIMORTGAGE INC against DONNA A HARPER & SARAH G HARPER & HARRIET D HARPER & HARRIET D SPRAGLIN is duly recorded as Instrument Number 201009445. IN TESTIMONY WHEREOF, I have hereunto set my hand _. and seal of said office this ,rf day of A.D. ~1~ ~ ~ ~_ ~~,~~~~ , ecorder of Deeds Reooraarato~,dmbedrieoarMx d~ ~t Ny C,ortimi~bn E~ins tla Fiat Ya~r at,hn. 2aN