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HomeMy WebLinkAbout09-5110l7, GOLDBECK WCAFFERTY & 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 CITIFINANCIAL SERVICES, INC 1111 Northpoint Drive Building 4 Suite 100 Coppell, TX 75019 vs. IN THE COURT OF COMMON PLEAS Plaintiff SANDRA K. FOOSE MARY A. MYERS Mortgagors and Record Owners 1008 Centerville Road Newville, PA 17241 Defendants OF Cumberland COUNTY CIVIL ACTION - LAW ACTION OF MORTGAGE FORECLOSURE Term Cl V,1 No. 6-'/- 5_//d CIVIL ACTION: MORTGAGE r-C!-1F!C1_0PURF 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 AQUI ABAJO. ESTA OFICINA PUEDE PROVEERE CON INFORMACION DE COMO CONSEUIR UN ABOGADO. SI USTED NO PUEDE PAGARLE A UN ABOGADO, ESTA OFICINA PUEDE PROVEERE INFORMACION ACERCA AGENCIAS QUE PUEDAN OFRECER SERVICIOS LEGAL A PERSONAS ELIGIBLE AQ UN HONORARIO REDUCIDO O GRATIS. 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.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 htip://www.phfa.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: htlp://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 8340717C. Para informacion en espanol puede communicarse con Loretta a1215-825-6344. This Action of Mortgage Foreclosure will continue unless you take action to stop it. COMPLAINT IN MORTGAGE FORECLOSURE 1. Plaintiff is CITIFINANCIAL SERVICES, INC, 1111 Northpoint Drive, Building 4 Suite 100 Coppell, TX 75019. 2. The names and addresses of the Defendants are SANDRA K. FOOSE, 1008 Centerville Road, Newville, PA 17241 and MARY A. MYERS, 1008 Centerville Road, Newville, PA 17241, who are the mortgagors and record owners of the mortgaged premises hereinafter described. 3. On July 30, 2001 mortgagors made, executed and delivered a mortgage upon the Property hereinafter described to CITIFINANCIAL SERVICES INC., which mortgage is recorded in the Office of the Recorder of Deeds of Cumberland County as Book 1729 Page 1734. 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 December 16, 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 ................................................................... Interest from 11/16/2008 through 06/30/2009 at 5.0040%.... Per Diem interest rate at $5.57 Reasonable Attorney's Fee at 5% of Principal Balance as more fully explained in the next numbered paragraph Late Charges from 12/16/2008 to 06/30/2009 ....................... Monthly late charge amount at $48.68 ................$40,595.74 ..................$1,867.22 .................. $2,029.79 ..................... $340.75 Costs of suit and Title Search ......................................................................$900.00 Title/Appraisal Fees .....................................................................................$225.00 Insurance Refund ....................................................................................... ($539.94) Deferred Interest .......................................................................................$1,634.12 $47,052.68 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 Sheriffs 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 $47,052.68, together with interest at the rate of $5.57, 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: - GOLDBECK Mc AFFERTY Mc"EVER BY: MICHAEL T. MCKEEVER, ESQUIRE ATTORNEY FOR PLAINTIFF VERIFICATION 11- 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: ; V U L 2 2 2009 #83407FC - SANDRA K. FOOSE and MARY A. MYERS 1008 Centerville Road Newville, PA 17241 EiChibitA A41_ ?HAT CERTAIN lot of ground altuate in Penn TowesNP. Cumberland County, Pennsylvania, bounded end described as tdlows: lkeGlNMING at a stake on the Wastem side of the Pine iGro m Road at the owner of land of Harry Sewem m*er, thence 75 feat in a SGUlheriy diroction along said road. to a stake at firs IM of land of Gaylord Beavers; 111e1109 160 feet in a Westerly direction along Wd Seerywa land to IN stake at the Tina of other land of the amfflorK thence 75 feat In a NoMarly direction along the g(anloW land, to a stake at the fine of lard of harry Boryarmager, thence 170 feet along the sold Bowemaeter land, to Bra Place of Begk+nlno. BEND Pert of the tract of Land conveyed to Samuel Kt Mom and Ruth A. Myers. his WOO, by deed dated August 27, 1947, and recorded in the office of the Recorder of Heeds for Cumberland County in Dead Book'C. Volume 14. Page 9. fi AND ft GM-M" hereby mortar t SraofoIW ft props my herein conveyed. q- L corn 4 *00 rCOOt) #IP 4 ,. Pa Aw molt 20 MU 5fi5 Ext hibit (B ACT 91 NOTICE DATE OF NOTICE: June 15, 2009 TAKE ACTION TO SAVE YOUR HOME FROM FORECLOSURE THIS LAW FIRM IS A DEBT COLLECTOR AND WE ARE ATTEMPTING TO COLLECT A DEBT OWED TO OUR CLIENT. ANY INFORMATION OBTAINED FROM YOU WILL BE USED FOR THE PURPOSE OF COLLECTING THE DEBT. This is an official notice that the 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 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 y u 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 any attorney in your area. The local bar association may be able to help you find a lawyer. La notificacon en adjunto es de suma importancia, pues afecta su derecho a continuer viviendo en su casa. Si no comprende el contenido de esta notification obtenga una traduccion immediatamente llamanda esta agencia (Pennsylvania Housing Finance Agency) sin cargos al numero mencionada 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. Prepared by: GOLDBECK McCAFFERTY & McKEEVER Suite 5000 - Mellon Independence Center. 701 Market Street Philadelphia, PA 19106 Fax (215) 627-7734 Date: June 15, 2009 Homeowners Name: SANDRA K. FOOSE and MARY A. MYERS Property Address: 1008 Centerville Road, NewviIIe, PA 17241 Loan Account No.: 2000510280044 Original Lender: CITIFINANCIAL SERVICES INC. Current Lender/Servicer: CITIFINANCIAL MORTGAGE CO. INC. HOMEOWNERS' EMERGENCY MORTGAGE ASSISTANCE PROGRAM YOU MAY BE ELIGIBLE FOR FINANCIAL ASSISTANCE WHICH CAN SAVE YOUR HOME FROM FORECLOSURE AND HELP YOU MAKE FUTURE MORTGAGE PAYMENTS IF YOU COMPLY WITH THE PROVISIONS OF THE HOMEOWNER'S EMERGENCY MORTGAGE ASSISTANCE ACT OF 1983 (THE "ACT"), YOU MAY BE ELIGIBLE FOR EMERGENCY MORTGAGE ASSISTANCE: * IF YOUR DEFAULT HAS BEEN CAUSED BY CIRCUMSTANCES BEYOND YOUR CONTROL, * IF YOU HAVE A REASONABLE PROSPECT OF BEING ABLE TO PAY YOUR MORTGAGE PAYMENTS, AND * IF YOU MEET OTHER ELIGIBILITY REQUIREMENTS ESTABLISHED BY THE PENNSYLVANIA HOUSING FINANCE AGENCY. TEMPORARY STAY OF FORECLOSURE - Under the Act, you are entitled to a temporary stay of foreclosure on your mortgage for thirty (30) days from the date of this Notice (plus three (3) days for mailing). During that time you must arrange and attend a "face-to-face" meeting with one of the designated consumer credit counseling agencies listed at the end of this Notice. THIS MEETING MUST OCCUR WITHIN THE NEXT (33) DAYS. IF YOU DO NOT APPLY FOR EMERGENCY MORTGAGE ASSISTANCE YOU MUST BRING YOUR MORTGAGE UP TO DATE THE PART OF THIS NOTICE CALLED "HOW TO CURE YOUR MORTGAGE DEFAULT" EXPLAINS HOW TO BRING YOUR MORTGAGE UP TO DATE. CONSUMER CREDIT COUNSELING AGENCIES - If you meet with one of the consumer credit counseling agencies listed at the end of this notice, the lender may NOT take action against you for thirty (30) days after the date of this meeting. The names addresses and telephone numbers of ted consumer credit counseling agencies for the coup in which the rois located are set desig-na 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 filed or postmarked within thirty (30) days of your fact-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 proceedings will be pursued against you if you have met the time requirements set forth above. You will be notified directly by the Pennsylvania Housing Finance Agency of its decision on your application. NOTE: IF YOU ARE CURRENTLY PROTECTEDBY THE FILING OF A PETITION IN BANKRUPTCY; THETOLLOWING PART OF THIS NOTICE IS FOR INFORMATION PURPOSES ONLY AND SHOULD NOT BE CONSIDERED AS AN ATTEMPT TO COLLECT THE DEBT. (If you have Hied bankruptcy you can still apply for Emergency Mortgage Assistance.) 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: 1008 Centerville Road, Newville, PA 17241 IS SERIOUSLY IN DEFAULT because: A. YOU HAVE NOT MADE MONTHLY MORTGAGE PAYMENTS for the following months and the following amounts are now past due: (a) Monthly payment from 12/16/2008 thru 6/15/2009 (7 mos. at $264.51/month) $1,851.57 (b) Late charges from 12/16/2008 thru 6/15/2009 $340.76 (c) Other charges; Escrow, Inspec., NSF Checks (d) Other provisions of the mortgage obligation, if any (e) TOTAL AMOUNT REQUIRED AS OF THIS DATE: $2,192.33 HOW TO CURE THE DEFAULT - You may cure the default within THIRTY (30) DAYS of the date of this notice BY PAYING THE TOTAL AMOUNT PAST DUE TO THE LENDER WHICH IS 2 1$ , 92.33, PLUS ANY MORTGAGE PAYMENTS AND LATE CHARGES WHICH BECOME DUE DURING THE THIRTY (30) DAY PERIOD. Payments must be made either by cashier's check, certified check or money order made payable and sent to: CITIFINANCIAL MORTGAGE CO., INC. 605 Munn Road Fort Mill, SC 29715 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 brings legal proceedings against you, you will still be required to pay the reasonable attorney's fees that were actually incurred, up to $50.00. However, if legal proceedings are started 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, ou sal have the ri t to cure the default and revert the sale at an time u to one hour before the Sheriffs Sale. You ma do sob a ' the total amount then ast due lus an late or other char es then due reasonable attorney's fees and costs connected with the foreclosure sale and an other costs connected with the Sheriff s Sale as specified in writing b the lender and b rformin an other r mrements under the mortgage. 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 four (4) to 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 by contacting the lender. HOW TO CONTACT THE LENDER: Name of Lender: CITIFINANCIAL MORTGAGE CO., INC. Address: 605 Munn Road Fort Mill, SC 29715 Phone Number: 800-423-8158 Contact: Loss Mitigation Department 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 - 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 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. Contact: Loss Mitigation Department Phone Number: 800423-8158 HEMAP Consumer Credit Counseling Agencies Report last updated: 5/29/2009 7:58:33 AM CCCS of Northeastern PA 401 Laurel Street Pittston, PA 18640 570.602.2227 800.922.9537 CRAWFORD County Booker T. Washington Center 1720 Holland Sheet Erie, PA 16503 814.453.5744 CCCS of Western PA 4402 Peach Street Erie, PA 16509 888.511.2227 ext 108 888.511.2227 ext 108 Center for Family Services, Inc. 213 Center Street Meadville, PA 16335 814.3373450 Greater Erie Community Action Committee 18 West 9TH Street Erie, PA 16501 814.459.4581 Shenango Valley Urban League, Inc. 601 Indiana Avenue Farrell, PA 16121 724.981.5310 St. Martin Center 1701 Parade Street Erie, PA 16503 814.452.6113 CUMBERLAND County Adams County Interfaith Housing Authority 40 E High Street Gettysburg, PA 17325 717.334.1518 CCCS of WesWm PA 2000 Linglestown Road Harrisburg, PA 17102 888.511.2227 888.511.2227 Community Action Commission of Captial Region 1514 Derry Street Harrisburg, PA 17104 717232.9757 Loveship, inc. 2320 North 5th Street Harrisburg, PA 17110 717.232.2207 Maranatha 43 Philadelphia Avenue Waynesboro, PA 17268 717.762.3285 PHFA 211 North Front Street Harrisburg, PA 17110 717.780.3940 800.342.2397 DAUPHIN County CCCS of Western PA 2000 Linglestown Road Harrisburg, PA 17102 888.511.2227 888.511.2227 Community Action Commission of Captial Region 1514 Derry Street Harrisburg, PA 17104 717.232.9757 Loveship, Inc. 2320 North 5th Street Harrisburg, PA 17110 717232.2207 Opportunity Inc. 301 East Market Street York, PA 17403 717.424.3645 PHFA 211 North Front Street Harrisburg, PA 17110 717.780.3940 800.342.2397 DELAWARE County Acorn Housing Corporation 846 North Broad Street Philadelphia, PA 19130 215.765.1221 Advocates for Financial Independence 202 East Hinkley Avenue Ridley Park, PA 19078 215.389.2810 Page 8 of 21 C-1) OF THE TARY 2009 JUL 27 PM 2: 319 - ?-?, CUM, P? ?t 3 9a?taa Sheriffs Office of Cumberland County R Thomas Kline Sheri Ronny R Anderson Chief Deputy Jody S Smith Civil Process Sergeant Edward L Schorpp Solicitor OFFICE ;)F THE SHERIFF Q'` VC -kRY 03 r~ Citifinancial Services, Inc. i vs. Sandra K. Foose Case Number 2009-5110 SHERIFF'S RETURN OF SERVICE 08/26/2009 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: Mary A. Myers, 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 Mary A. Myers. After several attempts the complaint has expried. 08/26/2009 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: Sandra K. Foose, 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 Sandra K. Foose. After several attempts the complaint has expried. SHERIFF COST: $97.20 SO ANSWERS, August 26, 2009 R THOMAS KLINE, SHERIFF GOLDBECK WCAFFERTY & 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 CITIFINANCIAL SERVICES, INC 1111 Northpoint Drive Building 4 Suite 100 Coppell, TX 75019 Plaintiff IN THE COURT OF COMMON PLEAS OF Cumberland COUNTY CIVIL ACTION - LAW ACTION OF MORTGAGE FORECLOSURE Term No. 09-5110 vs. SANDRA K. FOOSE MARY A. MYERS 1008 Centerville Road Newville, PA 17241 Defendant(s) PRAECIPE TO REINSTATE COMPLAINT Kindly reinstate the Complaint in the above captioned matter. By. 4?Y2 J GOLDBECK McCAFFERTY & McKEEVER MICHAEL T. MCKEEVER, ESQUIRE ATTORNEY FOR PLAINTIFF FiLeD-0-FiCE OF 7Hc PROTR TARP 2 SEP -a Aft 1 f : 04 F ?WY ?tK Ao.oo Pp A`rM IS 9(oy 3O p,.Z? d3o ato I GOLDBECK McCAFFERTY & McKEEVER MICHAEL T. MCKEEVER Attorney I.D.#56129 Suite 5000 - Mellon Independence Center 701 Market Street Philadelphia, PA 19106-1532 215-627-1322 BY: David B. Fein, Esq. Attorney I.D.#82628 Attorney for Plaintiff CITIFINANCIAL SERVICES, INC 1111 Northpoint Drive Building 4 Suite 100 Coppell, TX 75019 VS. SANDRA K. FOOSE and MARY A. MYERS 1008 Centerville Road Newville, PA 17241 No. 09-5110 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. MOTION FOR SUBSTITUTED SERVICE UNDER PA.R.C.P. 430(a) Plaintiff, by and through its attorney, in support of its Motion for Substituted Service, represents as follows: Plaintiff is the holder of a first mortgage upon the premises 1008 Centerville Road, Newville, PA,,17241, hereinafter, the "mortgaged premises". 2. Defendants, SANDRA K. FOOSE and MARY A. MYERS, are the mortgagors and real owners of the mortgaged premises. Pursuant to Cumberland County Local Rule 208.3(a)(2) and/or Rule 208.3(a)(9), I, David Fein, Esquire, hereby certify that no judge has ruled on any other matters in this case. I further certify that I am not aware that the Defendant has obtained counsel. Moreover, due to the nature of this motion, it was not possible to locate or contact the Defendant to request his concurrence. IN THE COURT OF COMMON PLEAS OF Cumberland COUNTY 4. The last known address of Defendant, MARY A. MYERS, is 1008 Centerville Road, Newville, PA, 17241 as set forth in Paragraph 2 of the Complaint. The Sheriff has been unable to effect service of the Complaint upon Defendant, MARY A. MYERS, at her last known address after numerous attempts. As per the Sheriff, service was attempted at 1008 Centerville Road, Newville, PA, 17241 but there was no answer at the property. The following investigation was conducted in a good faith attempt to ascertain the whereabouts of Defendant, MARY A. MYERS. WHEREFORE, Plaintiff prays that the Court enter the attached order allowing Plaintiff to serve the Complaint upon Defendant, MARY A. MYERS, by posting the premises and certified and regular mail to the Defendant's last known address. Respectfully submitted, David B. Fein, Esq. ProVest, LLC Affidavit of Good Faith Investigation Client provided information: File Number: 83407FC Attorney Firm: GOLDBECK, MCCAFFERTY & MCKEEVER Subject Name: Mary A. Myers Property Address: Street: 1008 Centerville Road City: Newville State: PA Zip 17241 Skip Results: Date of Birth: 10/14/1949 ProVest File Number: 1663721 Last Known Dates: As of 5/28/2009 Street: 1008 Centerville Road Phone: City: Newville State: PA Zip: 17241 Death Records: As of 5/28/2009, the Social Security Administration has no death record on file for Mary A. Myers. Social Security Number Search Completed. Employment Search: Unable to verify current employer. Creditor Information: Creditors indicated the last reported address for Mary A. Myers as 1008 Centerville Road, Newville, PA 17241. Department of Motor The Pennsylvania Department of Motor Vehicles provided no change for Mary A. Myers from Vehicle Records: 1008 Centerville Road, Newville, PA 17241. Public Licenses (Pilot, Search performed provided no information. Real Estate, etc): Voter Registration The County Voters Registration Office has no listing for Mary A. Myers. Information: National Postal Has no change for Mary A. Myers from 1008 Centerville Road, Newville, PA 17241. Address Search: Military Search: There was no active military status found Comments: 717-776-5377: Number listed to Mary Myers at 1008 Centerville Road, Apartment 233, Newville, PA 17241, left message on answering machine, no response. 717-776-6715: Called possible relative, Ryan Myers, there was no answer. 717-776-5933: Spoke with neighbor, Madalyn Cornman, stated does not know defendant. On 5/28/2009, I, Tonya Hardin being duly sworn according to the law, deposes and says: I am employed by ProVest, LLC. I have conducted an investigation into the whereabouts of the above named subject. Above are the results of my investigation. AfCiant Nam o ya Ha subscribed A,rtcl Svrorn to tore me, x) f Notary Public Date: 5/28/2009 i my COSAss 9iV t0xpp1 C f . NOWONW2t 2011 Sheriffs Office of Cumberland County R Thomas Kline Sheri Ronny R Anderson Chief Deputy Jody S Smith Civil Process Sergeant Edward L Schorpp ?QUy,,tr of ?umbcrf??rb OFFICE OF THE SHERIFF --amnancial Services, Inc. VS. Sandra K. Foose Case Number 2009-5110 SHERIFF'S RETURN OF SERVICE 08/26/2009 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: Mary A. Myers, 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 Mary A. Myers. After several attempts the complaint has expried. 08/26/2009 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: Sandra K. Foose, 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 Sandra K. Foose. After several attempts the complaint has expried. SHERIFF COST: $97.20 SO ANSWERS August 26, 2009 R THOMAS KLINE, SHERIFF coo?? ? - R7 GOLDBECK WCAFFERTY & McKEEVER MICHAEL T. MCKEEVER Attorney I.D.#56129 Suite 5000 - Mellon Independence Center 701 Market Street Philadelphia, PA 19106-1532 215-627-1322 BY: David B. Fein, Esq. Attorney I.D.#82628 for Plaintiff CITIFINANCIAL SERVICES, INC 1111 Northpoint Drive Building 4 Suite 100 Coppell, TX 75019 vs. SANDRA K. FOOSE and MARY A. MYERS 1008 Centerville Road Newville, PA 17241 VERIFICATION IN THE COURT OF COMMON PLEAS OF Cumberland COUNTY No. 09-5110 Attorney for Petitioner do hereby verify that the facts set forth in the foregoing Motion for Substituted Service are true and correct to the best of my knowledge, information and belief. I understand that false statements therein are made subject to the penalties of 18 Pa. C.S. 4904 relating to unsworn falsification to authorities. c BY: David 9' Fein, Esq. GOLDBECK McCAFFERTY & McKEEVER MICHAEL T. MCKEEVER Attorney I.D.#56129 Suite 5000 - Mellon Independence Center 701 Market Street Philadelphia, PA 19106-1532 215-627-1322 BY: David B. Fein, Esq. Attorney I.D.#82628 Attorney for Plaintiff CITIFINANCIAL SERVICES, INC 1111 Northpoint Drive Building 4 Suite 100 Coppell, TX 75019" IN THE COURT OF COMMON PLEAS OF Cumberland COUNTY vs. SANDRA K. FOOSE and MARY A. MYERS 1008 Centerville Road Newville, PA 17241 No. 09-5110 MEMORANDUM OF LAW IN SUPPORT OF MOTION FOR SUBSTITUTED SERVICE UNDER Pa.R.C.P. 430(a) Plaintiff has filed a Complaint in Mortgage Foreclosure against Defendant, MARY A. MYERS, which the Sheriff has been unable to personally serve upon Defendant, MARY A. MYERS. As noted in the attached Motion, Plaintiff has made a good faith attempt to ascertain Defendant's whereabouts without success. Accordingly, the Court may approve alternative means of service. See Pa.R.C.P. 430(a). CONCLUSION For reasons stated above and in the attached Motion, the Court should enter an order allowing Plaintiff to serve the Complaint in Mortgage Foreclosure upon Defendant, MARY A. MYERS, by posting the premises and certified mail and regular mail to the Defendant's last known address. Respectfully submitted, David B. Fein, Esq. GOLDBECK WCAFFERTY & McKEEVER MICHAEL T. MCKEEVER Attorney I.D.#56129 Suite 5000 - Mellon Independence Center 701 Market Street Philadelphia, PA 19106-1532 215-627-1322 BY: David B. Fein, Esq. Attorney I.D.#82628 Attorney for Plaintiff CITIFINANCIAL SERVICES, INC 1111 Northpoint Drive Building 4 Suite 100 Coppell, TX 75019 vs. SANDRA K. FOOSE MARY A. MYERS 1008 Centerville Road Newville, PA 17241 CERTIFICATE OF SERVICE of Cumberland County No. 09-5110 does hereby certify that true and correct copies of the foregoing Motion for Substituted Service have been served upon the Defendant, MARY A. MYERS, this/3day ofoa?Le , 2009, by first class mail, postage prepaid. MARY A. MYERS 1008 Centerville Road Newville, PA 17241 IN THE COURT OF COMMON PLEAS BY: David B. Fein, Esq 74 THE P? D'' . 4 -lTAAY 2009 OCT 15 A 8, 2 2 CUh?? J1' < <?, Sheriffs Office of Cumberland County R Thomas Kline Sheriff Ronny R Anderson Chief Deputy Jody S Smith Civil Process Sergeant Edward L Schorpp Solicitor Citifinancial Services, Inc. vs. Sandra K. Foose Fli_f_F-'.ly `mss n L'i f-4C 1„,, ,.dS i 2059 G' ",'F i 4 Fi 1 3: C3 CL L: Case Number 2009-5110 SHERIFF'S RETURN OF SERVICE 09/23/2009 11:53 AM - Noah Cline, Deputy Sheriff, who being duly sworn according to law, states that on September 23, 2009 at 1153 hours, he served a true copy of the within Complaint in Mortgage Foreclosure, upon the within named defendant, to wit: Sandra K. Foose, by making known unto Amy Stigers, daughter of defendant at 604 3rd Street Enola, Cumberland County, Pennsylvania 17025 its contents and at the same time handing to her personally the said true and correct copy of the same. 10/06/2009 06:10 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: Mary A. Myers at 150 5th Street, Apt. 3A, New Cumberland, Cumberland County, Pennsylvania but was unable to locate her in his bailiwick, a new address was given by co-defendant's daughter as 1008 Centerville Road, Newville, Cumberland County, Pennsylvania, but despite nine attempts at service the Complaint has exipred, he therefore returns the within Complaint as not found as to the defendant, Mary A. Myers. SHERIFF COST: $89.90 SO ANSWERS, October 07, 2009 R THOMAS KLINE, SHERIFF -?,? Deputy Sheri ocT,62oa961 s CITIFINANCIAL SERVICES, INC 1111 Northpoint Drive Building 4 Suite 100 Coppell, TX 75019 vs. SANDRA K. FOOSE and MARY A. MYERS 1008 Centerville Road Newville, PA 17241 IN THE COURT OF COMMON PLEAS OF Cumberland COUNTY 09-5110 ORDER AND NOW, this ?? (6 day of Qt. 2009, upon consideration of the Plaintiffs Motion for Substituted Service under Pa.R.C.P. 430(a) and it appearing to the Court that Plaintiffs good faith efforts to ascertain the present whereabouts of Defendant, MARY A. MYERS, have been unsuccessful, it is, ORDERED and DECREED: that Plaintiffs Motion is granted and the Sheriff and/or Plaintiff is directed to Serve the Complaint in Mortgage Foreclosure upon Defendant, MARY A. MYERS, by posting a copy of the Complaint upon the premises 1008 Centerville Road, Newville, PA, 17241, and Plaintiff is directed to serve the Complaint by certified and regular mail to the Defendants' last known address at 1008 Centerville Road, Newville, PA, 17241, and that all further service of legal papers, including but not limited to motions, petitions and rules be made by certified and regular mail to Defendant's last known address and that Notice of Sheriff Sale pursuant to Pennsylvania Rule of Civil Procedure 3129 may be made upon Defendant, MARY A. MYERS, by sending copies of same to Defendant's last known address by certified and regular mail and by posting the premises. BY THE COURT: I ue Distribution list: Michael T. McKeever, Esquire, Suite 5000 - Mellon Independence Center, 701 Market Street, Philadelphia, PA 19106-1532 /MARY A. MYERS, 1008 Centerville Road Newville, PA 17241 COP ? ?-s eyLULi Lcc 2639 OCT 19' A' H C: 19 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 CITIFINANCIAL SERVICES, INC 1111 Northpoint Drive Building 4 Suite 100 Coppell, TX 75019 Plaintiff vs. SANDRA K. FOOSE MARY A. MYERS 1008 Centerville Road Newville, PA 17241 Defendant(s) Term No. 09-5110 PRAECIPE TO REINSTATE COMPLAINT Kindly reinstate the Complaint in the above captioned matter. IN THE COURT OF COMMON PLEAS OF Cumberland COUNTY CIVIL ACTION - LAW ACTION OF MORTGAGE FORECLOSURE GOLDBECK, McCAFFERTY & McKEEVER By Michael T. McKeever, Esq. Attorney for Plaintiff RLED-WICE OF THE PROTHONOTARY 2009 OCT 26 PM 2* 28 ? jo. oo PO A-n`P W-f sDa gso 0* a3a!Qs Sheriffs Office of Cumberland County R Thomas Kline Sheriff Ronny R Anderson Chief Deputy Jody S Smith Civil Process Sergeant Edward L Schorpp Solicitor ?4?;gyp at +?umb?r??? OFFICE OF THE $kERIFF FILED-OrPPE OF Tt'E P,) 1 I L?•DTAP.Y 2009 GCT 29 Ali !G: 17 Citifinancial Services, Inc. vs. Sandra K. Foose Case Number 2009-5110 SHERIFF'S RETURN OF SERVICE 10/27/2009 09:05 PM - William Cline, Deputy Sheriff, who being duly sworn according to law, states that on October 27, 2009 at 2105 hours, he served a true copy of the within Complaint in Mortgage Foreclosure, upon the within named defendant, to wit: Mary A. Myers, pursuant to order of court by posting the premises located at 1008 Centerville Road Newville, Cumberland County, Pennsylvania 17241 with a true and correct copy according to law. SHERIFF COST: $44.80 October 28, 2009 SO ANSWERS, R THOMAS KLINE, SHERIFF By 44te Deputy Sheriff 4? 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 CITIFINANCIAL SERVICES, INC 1111 Northpoint Drive Building 4 Suite 100 Coppell, TX 75019 vs. SANDRA K. FOOSE and MARY A. MYERS Mortgagor(s) 1008 Centerville Road Newville, PA 17241 Defendant(s) CERTIFICATE OF SERVICE IN THE COURT OF COMMON PLEAS OF Cumberland COUNTY CIVIL ACTION - LAW ACTION OF MORTGAGE FORECLOSURE Term No. 09-5110 MICHAEL T. MCKEEVER ESQUIRE hereby certifies that on I [ )- O h he did serve upon Defendant MARY A. MYERS a true and correct copy of the above-captioned Complaint by certified and regular mail in accordance with the Court Order dated October 16, 2009. The undersigned understands that the statements herein and subject to the penalties provided by 18 P.S. Section 4904. Respectfully submitted, GOLDBECK McCAFFERTY & MCKEEVER BY: MICHAEL T. MCKEEVER ESQUIRE FILED--OFFICE OF THE I P2O .CNOTARY 2009 NOV -4 PM 12: 56 t ?! a MAY 19 2010 CTTIFINANCIAL SERVICES,INC 111 I Northpoint Drive Building 4 Suite 100 Coppell, TX 75019 IN THE COURT OF COMMON PLEAS OF Cumberland COUNTY VS. N 09-5110 C ~' SANDRA K. FOOSE and MARY A. MYERS -~~; 1008 Centerville Road ~'~' • %_-°' ,_ - .,-c Newville, PA 17241 t'' ~:. ,~,a :'r:: C~ C ~'~ i ORDER ~ ~. ~-.~ AND NOW, this ~~ day of N~py 2010, upon consideration of the Plaintx~Ps "' u~: Motion for Substituted Service under Pa.R.C.P. 430(aj and it appearing to the Court that Plaintiffs good faith efforts to ascertain the present whereabouts of Defendant, SANDRA K. F'OOSE, have been unsuccessful, it is, ORDERED and DECREED: that Plaintiffs Motion is granted and the Sheriffand/or Plaintiff is directed to Serve the Notice of Sheriffs Sale upon Defendant, SANDRA K. FOOSE, by posting a copy of the Notice upon the premises 1008 Centerville Road, Newville, PA, 17241, and Plaintiff is directed to serve the Notice of Sheriff Sale by certified and regulaz mail to the Defendant's last known address at 150 5~` Street, Apartment 3A, New Cumberland, PA 17070, and that all further service of legal papers, including but not limited to motions, petitions and rules be made by certified and regular mail to Defendant's last known address and that Notice of Sheriff Sale pursuant to Pennsylvania Rule of Civil Procedure 3129 may be made upon Defendant, SANDRA K. FOOSE, by sending copies of same to Defendant's last known address by certified and regular mail and by posting the premises. BY THE COURT: J. Dom~' stribution list: /I1~ichael T. McKeever, Esquire, Suite 5000 -Mellon Independence Center, 701 Market Street, P ladelphia, PA 19106-1532 ANDR.A K. FOOSE, 150 5th Street, Apartment 3A New Cumberland, PA 17070 s'~aol ro wry] ~_l -r7 _~ ~=e ~ -'~ c~ ~` ~? f -., =~} "~- r'; ; ;-- i 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 IN THE COURT OF COMMON PLEAS CITIFINANCIAL SERVICES, INC 1111 Northpoint Drive Building 4 Suite 100 Coppell, TX 75019 Plaintiff vs. SANDRA K. FOOSE MARY A. MYERS Mortgagor(s) and Record Owner(s) 1008 Centerville Road Newville, PA 17241 Defendant(s) 83407FC CF: 07/21/2009 SD: 07!07!2010 $48,235.96 of Cumberland County CNIL ACTION -LAW ACTION OF MORTGAGE FORECLOSURE CERTIFICATE OF SERVICE PURSUANT TO Pa.RC.P. 3129.2 (c) (2) Term No. 09-5110 n C N .-. ~_~ ~. o ~1 ~ ~=~ rr~ c~_ ._. ~~ ~: ~ ~ -~ " ~ - Y ___ ~ . c.. .__ >r ~ _;,> c~ =-c 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. ~j Premises was posted by~,.~he~r~s~6ffiee/competent adult (copy of return attached). ( ) Certified Mail & ordinary mail by Sheriffs Office (copy of return attached). ¢~j Certified Mail & ordinary mail by Michael T. McKeever (original receipt(s) for Certified Mail attached). ( ) Published in accordance with court order (copy of publication attached). Pursuant to the Affidavit under Rule 3129 (copy attached), service on all lienholders (if any) has been made by ordinary mail by Michael T. McKeever, Esquire (copies of proofs of mailing attached). The undersigned understands that the statements herein are subject to the penalties provided by 18 P.S. Section 4904. Respectfully submitte ~~ f~~ r BY: Keith G Halite Legal Secretary o ~~ o N°° N 6) ~~~~ E ~ d N ~~~~~ ~a d ~ LL m OD 0 L b e ~ Q ~+ > '~~ o - m ~n o $ ~ ~ C r O ~/ ` ~ C • E w m i ~ ` a ~~ ,- • , ~ . R ~L am a _~ m ~~ iL ~ ran U ~~~~ d ot- ai~~~a ~g~ ~' U ~~ x~~,~.t-b. Eo u' Q.~Q <`. `05 a°o ~ a H m ti m ZU~ a A ZO ~ c ~ a° H~Z o n a. 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C !q W Q `o ~ a m ~g vYotj~dN QUoY..~M ~WO~Wu7 mmaQp~ mpW Qm ~.~tig.~a zO~o=as cs rn ~ a .- E z' Y O ° _°~ z ~ ~' a c N U .m o° m z v O .. ~ ~ T ~ ~ ~ r a ~ U ~ W O Q ~ Z Q C"7 ~ n = O a T a Q c '~ ~ ~ ~ v ~ ~ Y U c G ~^- ~ Z Q ~ ~ o ~ O r i Q ~ .: Q d °~ U? m E ~ ~ U y 7 ~ ~ r Z N (h ~ d i:: ~ ~ .. 4/ 7 ,: ; i C f~ ~ a v a m 0 a d E m z a a ~ ~ 'a 00 a E b z'~ ~~ m ,~ Sm E~ ~~ z $ ~ ~ ~ m ~~ c 0 II. C O b A fa `o .~ C m a m O a U o 0 N N 0 (O O ai m N ~ ~ W N ~ c C o c r ~ Q U ~ a ~ Q o ~ ~ N ~ ~ ~' ~ W ~ ~ ~ m V O ~ ~ Y ~ ~ p u°. ~ Z d ~ ~ rcr ~ s 2oe~ ~, CTTIFINANCIAL SERVICES, INC 1111 Northpoint Drive Building 4 Suite 100 Coppell, TX 75019 vs. SANDRA K. FOOSE and MARY A. MYERS 1008 Centerville Road Newville, PA 17241 IN THE COURT OF COMMON PLEAS OF Cumberland COUNTY 09-5110 ORDER AND NOW, this /~e'~-day of 009, upon consideration of the Plaintiffs Motion for Substituted Service under Pa.R.C.P. 430(a) and it appearing to the Court that Plaintiffs good faith efforts to ascertain the present whereabouts of Defendant, MARY A. MYERS, have been unsuccessful, it is, ORDERED and DECREED: that Plaintiffs Motion is granted and the Sheriff and/or Plaintiff is directed to Serve the Complaint in Mortgage Foreclosure upon Defendant, MARY A. MYERS, by posting a copy of the Complaint upon the premises 1008 Centerville Road, Newville, PA, 17241, and Plaintiff is directed to serve the Complaint by certified and regular mail to the Defendants' last known address at 1008 Centerville Road, Newville, PA, 17241, and that all further service of legal papers, including but not limited to motions, petitions and rules be made by certified and regular mail to Defendant's last known address and that Notice of Sheriff Sale pursuant to Pennsylvania Rule of Civil Procedure 3129 may be made upon Defendant, MARY A. MYERS, by sending copies of same to Defendant's last known address by certified and regular mail and by posting the premises. BY THE COURT: Distribution list: Michael T. McKeever, Esquire, Suite 5000 -Mellon Independence Center, Philadelphia, PA 19106-1532 701 Market Street, MARY A. MYERS, 1008 Centerville RoadNewville, PA 17241 ~y~b t'~..,. ~%'~~'~~ i~3" y~~~--3s'~~ "~~-~ ~'^-~~ {=,~~ iS°~ iu~i~i:E"ti~~y~ ~`•'s";ti3~1~ i iii~~ ~.j``;d.r-,~re,'i ~i~~ 1Hf~T adi;{ } i tr= .Y !1i VKVil G1 ~:4jl H~~~~ ~" y-~ ~ vim. ._... .. :'.fir ~ 9 2010.., .......... .... : _:~..:_ . .. CITIFINANCIAL SERVICES, INC 1111 Northpoint Drive Building 4 Suite 100 Coppell, TX 75019 vs. SANDRA K. FOOSE and MARY A. MYERS 1008 Centerville Road Newville, PA 17241 IN THE COURT OF COMMON PLEAS OF G~mberland COCJNTY 09-5110 ORDER AND.NOW, thisa?p'l~-day of /~y,/ 2010, upon consideration of the Plaintiffs lviotion for Substituted Service under Pa.RC.P. 430(a) and it appearing to the Court that Plaintiffs good faith efforts to ascertain the present whereabouts of Defendant, SANDRA IC FOOSE, have been unsuccessful, it is, ORDERED and DECREED: that Plaintiffs Motion is granted and the Sheriff andlor Plaintiff is directed to Serve the Notice of Sheriff s Sale upon Defendant, SANDRA K. FOOSE, by posting a copy of the Notice upon the premises 1008 Centerville Road, Newville, PA, 17241, and Plaintiff is duected to,serve the Notice of Sheriff Sale by certified and regular mail to the Defendant's last known address at 150 5'~ Street, Apartment 3A, New Cumberland, PA 17070, and that all furdter service of legal papers, including but not limited to motions, petitions and rules be made by certified and regular mail to Defendant's last known address and that Notice of Sheti$ Sale pwrsuant to Pennsylvania Rule of Civil Procedure 3129 may be made upon Defendant, SANDRA K. FOOSE, by sending copies of same to Defendant's last known address by certified and regular mail and by posting the premises. BY THE COURT: r J. Distribution list: Michael T. McKeever, Esquire, Suite 5000 -Mellon Independence Center, 701 Market Street, Philadelphia, PA 19106-1532 SANDRA K. FOOSE,150 5th Street, Apartment 3A New Cumberland, PA 17070 Form 3877 Domestic USPS Firm Mailing Book Name and Address of Sender: Permit Number Sequence Number JOSEPH A GOLDBECK JR 3829A MELLON INDEPENDENCE CENT 701 MARKET ST STE 5000 Ascent - MAC v7.90. 8.10.K PHILADELPHIA, PA 19106 ---- - -- ----------------------------------------------------------- Piece ID Article R Delivery Address ------- SS -------- Fee ---------- Postaqe ----------------------------- Value Sender ---------- Charges Addressee Name Type Insur./Register Due Total 834075F6-02 71114342363000907843 FOOSE, SANDRA R. C 2.80 0.49 9.34 150 5th Street, Apartment 3A ERR 1.10 New Cumberland, PA 17070 83907MM6-02 71114342363000907850 MYERS, MARY A. C 2.80 0.44 4.34 150 5th Street, Apartment 3A ERR 1.10 New Cumberland, PA 17070 83407MM6-02.0171114342363000907867 MYSRS, MARY A_ C 2 80 0 44 - 1008 Centerville Road ERR . 1.10 . _ »... ~ !h „~ +~ ~,~'°. 4.34 Newville, PA 17291 „ ` ~ .t i ~, - ,,, ~ `, i ' ~ t .l 83407SF6-02.0171119342363000907874 FOOSE, SANDRA K_ C 2.80 0.44 } i ;~~'1 4.34 1008 Centerville Road ERR 1.10 ~ Newville, PA 17241 'd ` . _..u.-.~r~ 79604DH6-30 71114342363000907881 DAWN M. HIGGINS C 2.BD 0.44 4.34 351W. Schuylkill Road, Suite 1 ERR 1.10 Pottstown, PA 19465 79604DH6-30.0271114342363000907909 DAWN M. HIGGINS C 2.80 0.44 4.34 158 HUDSON DRIVE ERR 1.10 PHOENIXVILLE, PA 19460 94779WD7-06 71114342363000907911 DIPAOLO III, WILLIAM C 2.60 0.94 4.34 _ 4305 Wren Place ERR 1.10 Wexford, PA 15090 99779WD7-06.0171114342363000907928 DIPAOLO III, WILLIAM C 2.80 0.44 4.34 833 Southern Avenue ERR 1.10 '~ Pittsburgh, PA 15211 Page Totals: 8 31.20 3.52 ---------------- - --- 34.72 Cumulative Totals: 16 62.40 7.04 69.44 Page 2 IN TAE COMMON PLEAS COURT OF CUMBERLAND COUNTY PENNSYLVANIA CIT7FII~iANCIAL SERVICES, INC.; at aeQ. PWatlli(PetiBoner) V. SANDRA K;. FOOSL 4 MARY A. MYItRS; et aL Dekndant (Respondent) CASE aed/or DOCKET Na: 09-5110 SlterHPs Sak Data II6J0?JZ010 AFFIDAVIT OF SERVICE Coa:phiat 3ammans J Otter. NOTICE OF SEIERIFFB SALE OF REAL PROPERTY I, RYAN MARKS, ' that I am dghteen yearn of age or olds and tfiat I am not a patty to the a,ctiaa nor as emp[oyoe nor relative of a party ,and that I saved sad made known to the pagan saved. MARY A MYERS; et al. the above prooess on the 25 day of May, 2010, at 10:10 o`clock,l'M, at 1008 Centerville Road New+rn'1{e, PA 17241, Coumy of Cumbalaad, Commonvrea{th of Pennsylvania: Manner of Sarvica By posting a copy of the origins{ process on the most public part of the property pursuant to an ordrx of covet Service was attempted as the following datrsltimes: -- 2) 3) Commonvrcald~ of Pennsylvan{a ) SS: Cpurty of Cumbd9end ) Beta+e me; tae ~ notary p~{le, ~ may. p~~X aPP~ S to me known, who being duly sworn according to taw, deposes the fo{lowing: [ aazay swear or si~rm that tae &ds set fortis in the faregoing Affidavit of Service azz true and correct. Subscr{bed and swam Ito beef-o~re/me (signunee of Aunt) this ,~ day of _,~~-~' 20_~. Fde Number.83407FC Notary Public YJWU 7111tMS A.1tMaeta ~tops•~.:~ ~~• 2Q~13 IN T13E COMMON PLEAS COURT OF COUNTY PENNSYLVANIA CITIFINANCIAL SERVICES, INC.; et seq. PlaintHl' (Petitioner) Y. SANDRA IG FOOSE & MARY A. MYERS; et aL Defeodaat (Respondent} CASE and/or DOCKET No.: 09-SI I O SherlB's Sale Dates 06~0?IZOIO AFFIDAVIT OF SERVICE CaQpWat Saasmom d Other: NOTICE OF SHERIFF'S SALE OF REAL PROPERTY I. RYAN MARKS, oatify ttvg 1 am eighteen years of age or older and that I am nar a parry m the action nor an employee nor relative of a party . and drat 1 sawed aad made laatwn to the person served, SANARA IC FCfOSE ; et eL die above process on the 25 day of May, 2010, at 14:10 o'clock, PM, at 1008 Cmtuville Road Newville, PA 17241, County of Cranberland, Commatwealth of Peartsylvaaia: Iilaaeer otService: By posting a copy of the original pnocrss on the most public part of the property pursuant bD an order of court Semee was attempted on the foilawing dateslthnes: Commanwaalth of Pennsylvania County of Cumbatand 2) SS: 3) _ Before me, the rmdasignod notary pubti~ this day. personally, appeared ~.~(d.~'1 M~~ to me known, who being duly sworn accadiag to laws deposes the fol[owing: 1 hereby swaer or tilt the facia set forth in the foregoing ail'idavit of Service arc true and oornxt. Of AffISirt~ File Number:83407PC BIId Sworn D Or1e 1 dais day of 20 t a Natmy Public LTIi DF PH10~11Lyp ~* No01tW !oN 'hrsM A, plhlpyy~ 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 CITIFINANCIAL SERVICES, INC 1111 Northpoint Drive Building 4 Suite 100 Coppell, TX 75019 Plaintiff IN THE COURT OF COMMON PLEAS of Cumberland County CIVIL ACTION -LAW vs. SANDRA K. FOOSE MARY A. MYERS Mortgagor(s) and Record Owner(s) ACTION OF MORTGAGE FORECLOSURE Term No. 09-5110 1008 Centerville Road Nevwille, PA 17241 Defendant(s) SUPPLEMENTAL AFFIDAVIT PURSUANT TO RULE 3129 CITIFINANCIAL SERVICES, 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: 1008 Centerville Road Newville, PA 17241 1.Name and address of Owner(s) or Reputed Owner(s): SANDRA K. FOOSE 150 5th Street, Apartment 3A New Cumberland, PA 17070 MARY A. MYERS 1008 Centerville Road Newville, PA 17241 2. Name and address of Defendant(s) in the judgment: SANDRA K. FOOSE 150 5th Street, Apartment 3A New Cumberland, PA 17070 MARY A. MYERS 1008 Centerville Road Newville, PA 17241 3. Name and last known address of every judgment creditor whose judgment is a record lien on the property to be sold: SHIPPENSBURG/SOUTHAMPTON MANOR LP C/O David A. Baric 19 West South Street Carlisle, PA 17013 BUREAU OF COMPLIANCE Department 280946 Hamsburg, PA 17128 COMMONWEALTH OF PA, DEPT. OF REVENUE Bureau of Compliance P.O. Box 2$1230 Harrisburg, PA 17128 PA DEPARTMENT OF PUBLIC WELFARE -Bureau of Child Support Enforcement Health and Welfaze Bldg. -Room 432 Harrisburg, PA 17105-2675 DOMESTIC RELATIONS OF CUMBERLAND COUNTY PO Box 320 Carlisle, PA 17013 CAPITAL ONE BANK USA NA 15000 Capital One Drive Richmond, VA 23238 CAPITAL ONE BANK USA NA C/O JAMES C. WARMBRODT 436 Seventh Avenue Suite 1400 Pittsburgh, PA 15219 4. Name and address of the last recorded holder of every mortgage of record: 5. Name and address of every other person who has any record interest in or record lien on the property and whose interest may be affected by the sale: 6. Name and address of every other person of whom the plaintiff has knowledge who has any record interest in the property which may be affected by the sale. 7. Name and address of every other person of whom the plaintiff has knowledge who has any interest in the property which may be affected by the sale. TENANTS/OCCUPANTS 1008 Centerville Road Newville, PA 17241 (attach separate sheet if more space is needed) I verify that the statements made in this affidavit are true and correct to the best of my personal lrnowledge 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: June 15, 2010 GOLDBECK McC c -FERTY~EVER BY: Keith C. Halili Legal Secretary SHERIFF'S OFFICE OF CUMBERLAND Ronny R Anderson Sheriff Jody S Smith Chief Deputy Richard W Stewart Solicitor .r COUNTY C ILL rOFF1CE J /y O TAA pE Citifinancial Services, Inc. vs. Sandra K. Foose (et al.) Case Number 2009-5110 SHERIFF'S RETURN OF SERVICE 04/06/2010 02:45 PM - Ronald Hoover, Deputy Sheriff, who being duly sworn according to law, states that on 4/6/10 at 1446 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 Sandra K. Foose and Mary A. Myers, located at, 1008 Centerville Road, Newville, Cumberland County, Pennsylvania according to law. 04/27/2010 06:12 PM - 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: Sandra K. Foose, 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, Sandra K. Foose, defendant does not reside at 1008 Centerville Road, Newville, PA or 150 5th Street, Apt 3A, New Cumberland, PA, where defendant moved from and did not leave a forwarding address. 04/30/2010 02:08 PM - 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: Mary M. Myers, but was unable to locate in his bailiwick. He therefore returns the within Real Estate Writ, Notice of Sale and Description as NOT FOUND as to the defendant, Mary A. Myers, defendant could not be located at address provided prior to expiration date of 5/2110, deputies believe defendant is home but is avoiding Sheriffs Service. 05/28/2010 Property sale postponed to 7/7/2010. 07107/2010 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 July 7, 2010 at 10:00 o'clock A.M. He sold the same for the sum of $1.00 to Attorney Michael McKeever, on behalf of CITIFINANCIAL, Inc., 1111 Northpoint Drive, Bldg 4, Suite 100, Coppell, TX 75019, being the buyer in this execution, paid to Sheriff Ronny R. Anderson, the sum of 834.63 SHERIFF COST: $834.63 SO ANSWERS, October 11, 2010 RON R ANDERSON, SHERIFF a.60 pd _ ?e (?i Cou?itySuite She?n'f. iFlaacil. Inc, e Goldbe& McCafferty & McKeever BY: Mickel T.-McKeever Attorney I.D. #56129 Suite 5000 - Mellon Independence Center 701 Market Street Philadelphia, PA 19106 215-627-1322 Attorney for Plaintiff CITIFINANCIAL SERVICES, INC 1111 Northpoint Drive Building 4 Suite 100 Coppell, TX 75019 vs. SANDRA K. FOOSE MARY A. MYERS (Mortgagor(s) and Record Owner(s)) 1008 Centerville Road Newville, PA 17241 IN THE COURT OF COMMON PLEAS Plaintiff of Cumberland County CIVIL ACTION - LAW ACTION OF MORTGAGE FORECLOSURE Defendant(s) No. 09-5110 AFFIDAVIT PURSUANT TO RULE 3129 CITIFINANCIAL SERVICES, 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: 1008 Centerville Road Newville, PA 17241 EName and address of Owner(s) or Reputed Owner(s): SANDRA K. FOOSE 150 5th Street, Apartment 3A New Cumberland, PA 17070 MARY A. MYERS 1008 Centerville Road Newville. PA 17241 2. Name and address of Defendant(s) in the judgment: SANDRA K. FOOSF 150 5th Street, Apartment 3A New Cumberland, PA 17070 MARY A. MYERS 1008 Centerville Road Newville. PA 17241 3. Name and last known address of every judgment creditor whose judgment is a record lien on the property to be sold: SHIPPENSBURG/SOUTHAMPTON MANOR LP C'O David A. Baric ly West South Street 'Carlisle, PA 17013 BUREAU OF COMPLIANCE Department 280946 Harrisburg, PA 17128 COMMONWEALTH OF PA, DEPT. OF REVENUE Bureau of Compliance P.O. Box 281230 Harrisburg, PA 17128 PA DEPARTMENT OF PUBLIC WELFARE - Bureau of Child Support Enforcement Health and Welfare Bldg. - Room 432 Harrisburg, PA 17105-2675 DOMESTIC RELATIONS OF CUMBERLAND COUNTY PO Box 320 Carlisle, PA 17013 4. Name and address of the last recorded holder of every mortgage of record: 5. Name and address of every other person who has any record interest in or record lien on the property and whose interest may be affected by the sale: 6. Name and address of every other person of whom the plaintiff has knowledge who has any record interest in the property which may be affected by the sale. 7. Name and address of every other person of whom the plaintiff has knowledge who has any interest in the property which may be affected by the sale. TENANTS/OCCUPANTS 1008 Centerville Road Newville, PA 17241 (attach separate sheet if more space is needed) I verify that the statements made in this affidavit are true and correct to the b st o my personal knowledge or information and belief. I understand that false statements herein are made subject to ie nalties of 18 Pa_ C.S. Section 4904 relating to unsworn falsification to authorities. DATED: December 7 2009 GOLDBEC/?N,/IcKeeve. RTY & McKEFVER BY: MicharEsq. Attorney fo 09-5110 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 CITIFINANCIAL SERVICES, INC 111 I Northpoint Drive Building 4 Suite 100 Coppell, TX 75019 Plaintiff vs. SANDRA K. FOOSE MARY A. MYERS Mortgagor(s) and Record Owner(s) 1008 Centerville Road Newville, PA 17241 Defendant(s Term No. 09-5110 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 I O: FOOSE, SANDRA K. SANDRA K. FOOSE 150 5th Street, Apartment 3A New Cumberland, PA 17070 Your house at 1008 Centerville Road, Newville, PA 17241 is scheduled to be sold at Sheriff's Sale on Wednesday, June 02, 2010, at 10:00 AM, in Commissioners Hearing Rm 2nd FL Courthouse to enforce the court judgment of `648,235.96 obtained by CITIFINANCIAL SERVICES. INC against you. NOTICE OF OWNER'S RIGHTS YOU MAY BE ABLE TO PREVENT THIS SHERIFF'S SALE To prevent this Sheriffs Sale you must take immediate action: I. The sale will be cancelled if you pay to CITIFINANCIAL SERVICES, INC. the back payments. late charges, costs and reasonable attorney's fees due. To find out how much you must pay call our office at 215-825-6329 or 1-866-413-23 11. IN THE COURT OF COMMON PLEAS of Cumberland County CIVIL ACTION - LAW ACTION OF MORTGAGE FORECLOSURE 2. You may be able to stop the sale by filing a petition asking the Court to strike or open judgment. if the judgment was improperly entered. You may also ask the Court to postpone the sale for good cause. 09-5110 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 Sheriff s Sale is not stopped, your property will be sold to the highest bidder. You may find out the price bid price by calling the Sheriff of 717-240-6390. 2. You may be able to petition the Court to set aside the sale if the bid price was grossly inadequate compared to the value of your property. 3. The sale will go through only if the buyer pays the Sheriff the full amount due in the sale. To find out if this has happened, you may call the Sheriff of 717-240-6390. 4. If the amount due from the Buyer is not paid to the Sheriff, you will remain the owner of the property as if the sale never happened. 5. You have a right to remain in the property until the full amount due is paid to the Sheriff and the Sheriff gives a deed to the buyer. At that time, the buyer may bring legal proceedings to evict you. 6. You may be entitled to a share of the money which was paid for your house. A schedule of distribution of the money bid for your house will be filed by the Sheriff within thirty (30) days from the date of the Sheriff's Sale. This schedule will state who will be receiving that money. The money will be paid out in accordance with this schedule unless exceptions (reasons why the proposed distribution is wrong) are filed with the Sheriff within ten (10) days after the schedule of distribution is filed. 7. You may also have other rights and defenses, or ways of getting your house back, if you act immediately after the sale. You may contact the Foreclosure Resource Center: http:/,/www.philadelphiafed,org,'foi-e closure/ YOU SHOULD TAKE THIS PAPER TO YOUR LAWYER AT ONCE. IF YOU DO NOT HAVE A LAWYER OR CANNOT AFFORD ONE, GO 7 0 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 , 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. 09-5110 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.go_v 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 homeretentionagoldbecklaw.coin. 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 83407FC. Para informacion en espanol puede communicarse con Loretta al 215-825-6344. ALL THAT CERTAIN lot or ground situate in Penn Township, Cumberland County, Pennsylvania, bounded and described as follows: BEGINNING at a stake on the Western side of the Pine Grove Road at the comer of land of Harry Bowermaster, thence 75 feet In e Southerly direction along said road. to a stake at the line of land of Gaylord Seavers; thence 150 feet In a Westerly direction along said Searvers land to a stake at the line of other land of the grantors; thence 75 feet in a Northerly direction along the grantors land to a stake at the line of land of Harry Bowermaster; thence 170 feet along the said Bowermaster land, to the Placo of Beginning. BEING THE SAME PREMISES BY DEED FROM RUTH A. MYERS, A SINGLE PERSON DATED 04/07/00 AND RECORDED 04/18/00 IN BOOK 219 PAGE 565 GRANTED AND CONVEYED UNTO MARY A. MYERS AND SANDRA K. FOOSE, SINGLE PERSONS. BEING KNOWN AS 1008 CENTERILLE ROAD, NEWVILLE PA 17241 TAX PARCEL NO: 31-29-2522-012 09-5110 G7LDIBECK 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 z CITIFINANCIAL SERVICES, INC 1111 Northpoint Drive Building 4 Suite 100 Coppell, TX 75019 Plaintiff IN THE COURT OF COMMON PLEAS of Cumberland County CIVIL ACTION - LAW vs. SANDRA K. FOOSE MARY A. NIYERS Mortgagor(s) and Record Owner(s) 1008 Centerville Road Newville, PA 17241 ACTION OF MORTGAGE FORECLOSURE Defendant(s Term No. 09-5110 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: MYERS, MARY A. MARY A. MYERS 1008 Centerville Road Newville, PA 17241 Your house at 1008 Centerville Road. Ne xville. PA 17241 is scheduled to be sold at Sheriff's Sale on Wednesday, June 02, 2010, at 10:00 AM, in Commissioners Hearing Rm 2nd FL Courthouse to enforce the court judgment of $48;235.96 obtained by CITIFINANCIAL SERVICES. INC against you. NOTICE OF OWNER'S RIGHTS YOU MAY BE ABLE TO PREVENT THIS SHERIFF'S SALE To prevent this Sheriffs Sale you must take immediate action: 1. The sale will be cancelled if you pay to CITIFINANCIAL SERVICES. INC. the back payments. late charges, costs and reasonable attorney's fees due. To fin&out how much you must pay call our office at 215-825-6329 or 1-866-413-2311 . 2. You may be able to stop the sale by tiling a petition asking the Court to strike or open judgment, if the judgment was improperly entered. You may also ask the Court to postpone the sale for =ood cause. 09-5110 3. You may also be able to stop the sale through other legal proceedings 4. You may need an attorney to assert your rights. The sooner you contact one, the more chance you will have of stopping the sale. (See notice below on how to obtain an attorney). YOU MAY STILL BE ABLE TO SAVE YOUR PROPERTY AND YOU HAVE OTHER RIGHTS EVEN IF THE SHERIFF'S SALE DOES NOT TAKE PLACE. 1. If the Sheriffs Sale is not stopped, your property will be sold to the highest bidder. You may find out the price bid price by calling the Sheriff of 717-240-6390. 2. You may be able to petition the Court to set aside the sale if the bid price was grossly inadequate compared to the value of your property. 3. The sale will go through only if the buyer pays the Sheriff the full amount due in the sale. To find out if this has happened, you may call the Sheriff of 717-240-6390. 4. If the amount due from the Buyer is not paid to the Sheriff, you will remain the owner of the property as if the sale never happened. 5. You have a right to remain in the property until the full amount due is paid to the Sheriff and the Sheriff gives a deed to the buyer. At that time, the buyer may bring legal proceedings to evict you. 6. You may be entitled to a share of the money which was paid for your house. A schedule of distribution of the money bid for your house will be filed by the Sheriff within thirty (30) days from the date of the Sheriffs Sale. This schedule will state who will be receiving that money. The money will be paid out in accordance with this schedule unless exceptions (reasons why the proposed distribution is wrong) are filed with the Sheriff within ten (10) days after the schedule of distribution is filed. 7. You may also have other rights and defenses, or ways of getting your house back, if you act immediately after the sale. 8. You may contact the Foreclosure Resource Center: http://www.philadelphiafed.or,/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 09-5110 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.coin. 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 83407FC. Para infonnacion en espanol puede communicarse con Loretta al 215-825-6344. . . , ALL THAT CERTAIN lot or ground situate in Penn Township, Cumberland County, Pennsylvania, bounded and described as follows: BEGINNING at a stake on the Western side of the Pine Grove Road at the comer of land of Harry Bowermaster, thence 75 feet In e Southerly direction along said road. to a stake at the line of land of Gaylord Seavers; thence 150 feet In a Westerly direction along said Searvers land to a stake at the line of other land of the grantors, thence 75 feet in a Northerly direction along the grantors land to a stake at the line of land of Harry Bowermaster; thence 170 feet along the said Bowermaster land, to the Placo of Beginning. BEING THE SAME PREMISES BY DEED FROM RUTH A. MYERS, A SINGLE PERSON DATED 04/07/00 AND RECORDED 04/18/00 IN BOOK 219 PAGE 565 GRANTED AND CONVEYED UNTO MARY A. MYERS AND SANDRA K. FOOSE, SINGLE PERSONS. BEING KNOWN AS 1008 CENTERILLE ROAD, NEWVILLE PA 17241 TAX PARCEL NO: 31-29-2522-012 WRIT OF EXECUTION and/or ATTACHMENT COMMONWEALTH OF PENNSYLVANIA) NO 09-5110 Civil COUNTY OF CUMBERLAND) CIVIL ACTION - LAW TO THE SHERIFF OF CUMBERLAND COUNTY: To satisfy the debt, interest and costs due CITIFINANCIAL SERVICES, INC., Plaintiff (s) From SANDRA K. FOOSE and MARY A. MYERS (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 $48,235.96 L.L. $.50 Interest from 12/8/09 to Date of Sale per diem at $5.57 -- To be Determined Atty's Comm % Due Prothy $2.00 Atty Paid $370.90 Other Costs Plaintiff Paid Date: 12/10/09 (Seal) REQUESTING PARTY: Name: MICHAEL T. McKEEVER, ESQUIRE Address: GOLDBECK McCAFFERTY & McKEEVER SUITE 5000 - MELLON INDEPENDNECE CENTER 701 MARKET STREET PHILADELPHIA, PA 19106 Attorney for: PLAINTIFF i Telephone: 215-627-1322 Supreme Court ID No. 56129 On March 22, 2010 the Sheriff levied upon the defendant's interest in the real property situated in Penn Township, Cumberland County, PA, Known and numbered, 1008 Centerville Road, Newville, more fully described on Exhibit "A" filed with this writ and by this reference incorporated herein. Date: March 22, 2010 B: Real Estate oordinator S I -Z d 11 330 01 v ?1 3T S 3144 ? i J .. PROOF OF PUBLICATION OF NOTICE IN CUMBERLAND LAW JOURNAL (Under Act No. 587, approved May 16, 1929), P. L.1784 COMMONWEALTH OF PENNSYLVANIA . ss. COUNTY OF CUMBERLAND : Lisa Marie Coyne, Esquire, Editor of the Cumberland Law Journal, of the County and State aforesaid, being duly sworn, according to law, deposes and says that the Cumberland Law Journal, a legal periodical published in the Borough of Carlisle in the County and State aforesaid, was established January 2, 1952, and designated by the local courts as the official legal periodical for the publication of all legal notices, and has, since January 2, 1952, been regularly issued weekly in the said County, and that the printed notice or publication attached hereto is exactly the same as was printed in the regular editions and issues of the said Cumberland Law Journal on the following dates, viz: April 16, April 23, and April 30, 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. isa Marie Coyne, itor SWORN TO AND SUBSCRIBED before me this -30 day of April. 2010 Notary NOTARIAL SEAL DEBORAH A COLUNS Notary Public FrCARMLI,SLE BOROUGH. CUMBERL 8020C0UNTy ommission Eores APB Writ No. 2009-5110 Civil Citifinancial Services, Inc. vs. Sandra K. Foose Mary A. Myers Atty: Michael McKeever ALL THAT CERTAIN lot or ground situate in Penn Township, Cumber- land County, Pennsylvania, bounded and described as Follows: BEGINNING at a stake on the Western side of the Pine Grove Road at the comer of land of Harry Bower- master, thence 75 feet In a Southerly direction along said road. to a stake at the line of land of Gaylord Seavers; thence 150 feet In a Westerly direc- tion along said Searvers land to a stake at the line of other land of the grantors; thence 75 feet in a North- erly direction along the grantors land to a stake at the line of land of Harry Bowermaster; thence 170 feet along the said Bowermaster land, to the Plaeo of Beginning. BEING the same premises by deed from Ruth A. Myers, a single person dated 04/07/00 and recorded 04/18/00 in Book 219 Page 565 granted and conveyed unto Mary A. Myers and Sandra K. Foose, single persons. BEING KNOWN AS 1008 CEN- TERILLE ROAD, NEWVILLE PA 17241. TAX PARCEL NO: 31-29-2522- 012. 'A `!4 A i irjdt y The Patriot-News Co. 2020 Technology Pkwy Suite 300 Mechanicsburg, PA 17050 Inquiries - 717-255-8213 CUMBERLAND CO. SHERIFFS OFFICE CUMBERLAND COUNTY COURT HOUSE CARLISLE PA 17013 ZhePatriot-News Now you know THE PATRIOT NEWS THE SUNDAY PATRIOT NEWS Proof of Publication Under Act No. 587, Approved May 16, 1929 Commonwealth of Pennsylvania, County of Dauphin) ss Marianne Miller, being duly sworn according to law, deposes and says: That she is a Staff Accountant of The Patriot News Co., a corporation organized and existing under the laws of the Commonwealth of Pennsylvania, with its principal office and place of business at 812 to 818 Market Street, in the City of Harrisburg, County of Dauphin, State of Pennsylvania, owner and publisher of The Patriot-News and The Sunday Patriot-News newspapers of general circulation, printed and published at 812 to 818 Market Street, in the City, County and State aforesaid; that The Patriot-News and The Sunday Patriot-News were established March 4th, 1854, and September 18th, 1949, respectively, and all have been continuously published ever since; That the printed notice or publication which is securely attached hereto is exactly as printed and published in their regular daily and/or Sunday/ Metro editions which appeared on the date(s) indicated below. That neither she nor said Company is interested in the subject matter of said printed notice or advertising, and that all of the allegations of this statement as to the time, place and character of publication are true; and That she has personal knowledge of the facts aforesaid and is duly authorized and empowered to verify this statement on behalf of The Patriot-News Co. aforesaid by virtue and pursuant to a resolution unanimously passed and adopted severally by the stockholders and board of directors of the said Company and subsequently duly recorded in the office for the Recording of Deeds in and for said County of Dauphin in Miscellaneous Book "M", Volume 14, Page 317. Writ No. 2009-5110 Civil Term This ad ran on the date(s) shown below: Cititinanciat Services, Inc. 04116110 vs. Sandra K. Foose i 04123110 Mary A. Myeq Atty: Michael McKeever - 04/30110 ALL THAT CERTAIN lot or ground situate Jr_ in Penn Township, Cumberland County, Pennsylvania, bounded and described as follows: BEGINNING at a stake on the Western side of the Pine Grove Road at the comer of land of Sworn t nd -sililscribed before me this 18 day of May, 2010 A. D. Harry Bowermaster, thence 75 feet In a Southerly direction along said road. to a stake at the line >* of land of Gaylord Seavers; thence 150 feet In 11 a Westerly direction along said Searvers land to a stake at the line of other land of the grantors; Notary Public thence 75 feet in a Northerly direction along the gramorslandtoastake atthefine ofland ofHarry COMMONWEALTH OF PENNSYLVANIA Bowermaster; thence 170 feet along the said Bowetmaster land, to the Placo of Beginning. Notarial Seal BEING THE SAME PREMISES BY DEED Sherrie L Klww, Notary Public FROM RUTH A. MYERS, A SINGLE PERSON MY Lower L CommissloPaxtonrt Expires Dauphin County MY Nov. 26, 2011 DATED 04/07/00 AND RECORDED 04/18/00 Member, Pennsyivanla Association of Notaries IN BOOK 219 PAGE 565 GRANTED AND CONVEYED UNTO MARY A. MYERS AND SANDRA K. FOOSE, SINGLE PERSONS. BEING KNOWN AS 1008 CENTERILLE ROAD, NEWVU.LE PA 17241, TAX PARCEL NO: 31-29-2522-012 COMMONWEALTH OF PENNSYLVANIA COUNTY OF CUMBERLAND ISS: I, Robert P. Ziegler, Recorder of Deeds in and for said County and State do hereby certify that the Sheriff's Deed in which Citifinancial Inc is the grantee the same having been sold to said grantee on the 7th day of July A.D., 2010, under and by virtue of a writ Execution issued on the l Oth day of December, A.D., 2009, out of the Court of Common Pleas of said County as of Civil Term, 09 Number 5110, at the suit of Sandra K Foose & Mary A Myers against Citifinanical Inc is duly recorded as Instrument Number 201029005. IN TESTIMONY WHEREOF, I have hereunto set my hand and seal of said office this day of (9d4- A.D. -? n of Deeds d?Cunbe?endCanty. CeeW PA the R9 Monday d Jan. 2014 f,. KML LAW GROUP, P.C. `;iw Suite 5000—BNY Mellon Independence Center .? , d' ©� 701 Market Street Philadelphia, PA 19106-1532 28'3 SEP 26 AM f0: 29 215-627-1322 CITIFINANCIAL SERVICES, INC �E NS Y' VANIAd 1111 Northpoint Drive IN THE COURT OF COMMON PLEAS Building 4 Suite 100 Coppell, TX 75019 OF CUMBERLAND COUNTY Plaintiff vs. SANDRA K. FOOSE No. 09-5110 MARY A. MYERS (Mortgagor(s) and Record owner(s)) 1008 Centerville Road Newville, PA 17241 Defendant(s) PRAECIPE TO DISCONTINUE AND END TO THE PROTHONOTARY: Kindly mark the above case Discontinued and Ended without prejudice upon payment of your costs only. KML LAW GROUP,P.C. F/K/A GOLDBECK McCAFFERTY& McKEEVER By: Michael McKeever P 56129 Jay E.Kivitz Pa.ID 7 9 Lisa Lee Pa.ID 78020 Thomas Puleo Pa.ID 27615 David Fein Pa.ID 82628 Jill P.Jenkins Pa.ID 306588 Alyk L.Oflazian Pa.ID 312912 Salvatore Filippello,Attorney ID 313897 Attorneys for Plaintiff KML LAW GROUP,P.C. Suite 5000—BNY Mellon Independence Center 701 Market Street Philadelphia, PA 19106 (215) 627-1322 Attorney for Plaintiff CITIFINANCIAL SERVICES, INC Plaintiff IN THE COURT OF COMMON vs. PLEAS OF CUMBERLAND COUNTY SANDRA K. FOOSE MARY A. MYERS CIVIL ACTION - LAW (Mortgagor(s) and Record Owner(s)) ACTION OF MORTGAGE Defendant(s) FORECLOSURE No. 09-5110 CERTIFICATE OF SERVICE Angela M.S mith, hereby certifies that he/she did serve true and correct copies of Praecipe to Discontinue and End and all supporting papers attached hereto upon Defendant,by first class mail, postage pre-paid, on a� /� SANDRA K. FOOSE SANDRA K. FOOSE 150 5th Street, Apartment 3A 1008 Centerville Road New Cumberland, PA 17070 Newville, PA 17241 MARY A. MYERS MARY A. MYERS 1008 Centerville Road 150 5th Street, Apartment 3A Newville, PA 17241 New Cumberland,PA 17070 KML LAW GROUP,P.C. F/K/A GOLDBECK McCAFFERT Mc EVER By: An a M.S mith , Legal Assist t asmith @kmllawgroup.com 215-825-6325 (Direct Phone)