HomeMy WebLinkAbout01-0232LAW OFFICES OF GREGORY JAVARDIAN
BY: GREGORY JAVARDIAN
ID# 55669
44 SECOND STREET PIKE
SUITE 101
SOUTHAMPTON, PA 18966
(215) 942-9690
Attorney for Plaintiff
THE CHASE MANHATTAN BANK, AS
TRUSTEE OF IMC HOME EQUITY
LOAN 1998-3 UNDER THE POOLING
AND SERVICING AGREEMENT
DATED AS OF
JUNE 1, 1998
5901 E. FOWLER AVENUE
TAMPA, FL 33617-2362
PLAINTIFF
VS.
COURT OF COMMON PLEAS
CUMBERLAND COUNTY
NO. 0 / - 0_3.? ?W
COMPLAINT IN
MORTGAGE FORECLOSURE
EDWARD M. VOGHT
CAROL B. VOGHT
340 BOSLER AVENUE
LEMOYNE, PA 17043
DEFENDANT(S)
COMPLAINT - CIVIL ACTION
NOTICE
You have been sued in Court. If you wish to defend against the claims set forth in
the following pages, you must take action within twenty (20) days after this Complaint and
notice are served, by entering a written appearance personally or by attorney and filing in
writing with the court your defense or objections to the claims set forth against you. You
are warned that if you fail to do so the case may proceed without you and a judgment may
be entered against you by the Court without further notice for any money claimed in the
complaint or for any other claim or relief requested by the Plaintiff. You may lose money or
property or other rights important to you.
YOU SHOULD TAKE THIS NOTICE TO YOUR LAWYER AT ONCE. IF YOU
DO NOT HAVE A LAWYER OR CANNOT AFFORD ONE, GO TO OR TELEPHONE
THE OFFICE SET FORTH BELOW TO FIND OUT WHERE YOU CAN GET LEGAL
HELP.
Cumberland County Bar Association
2 Liberty Avenue
Carlisle, PA 17013
717-249-3166
LAW OFFICES OF GREGORY JAVARDIAN
BY: GREGORY JAVARDIAN
ID# 55669
44 SECOND STREET PIKE
SUITE 101
SOUTHAMPTON, PA 18966
(215) 942-9690
Attorney for Plaintiff
THE CHASE MANHATTAN BANK, AS
TRUSTEE OF IMC HOME EQUITY
LOAN 1998-3 UNDER THE POOLING
AND SERVICING AGREEMENT
DATED AS OF
JUNE 1, 1998
5901 E. FOWLER AVENUE
TAMPA, FL 33617-2362
PLAINTIFF
COURT OF COMMON PLEAS
CUMBERLAND COUNTY
NO. `V - aZ 3,i ccuti tc?
COMPLAINT IN
MORTGAGE FORECLOSURE
VS.
EDWARD M. VOGHT
CAROL B. VOGHT
340 BOSLER AVENUE
LEMOYNE, PA 17043
DEFENDANT(S)
CIVIL ACTION MORTGAGE FORECLOSURE
1. The Chase Manhattan Bank, as Trustee of IMC Home Equity Loan 1998-3 Under
the Pooling and Servicing Agreement dated as of June 1, 1998 , (hereinafter
referred to as "plaintiff") is an institution, conducting business under the laws of
the Commonwealth of Pennsylvania and brings this action to foreclosure the
mortgage between Edward M. Voght and Carol B. Voght, mortgagor(s)
(hereinafter referred to as "defendant") and itself as Mortgagee by Assignment.
Said mortgage was dated January 30, 1998 and was recorded in the office of the
Recorder of Deeds and Mortgages in Cumberland county in Mortgage Book 1431,
Page 604. A copy of the mortgage is attached and made a part hereof as exhibit
`A'.
2. The Mortgage is secured by Defendant(s) Note dated January 30, 1998 in the
amount of $69,600.00 payable to Plaintiff in monthly installments with an interest
rate of 14.7%.
3. The land subject to the mortgage is:
340 Bosler Avenue, Lemoyne, PA 17043.
4. The defendant(s), Edward M. Voght and Carol B. Voght is/are the real owner(s)
of the land subject to the mortgage and the Defendants' address is : 340 Bosler
Avenue, Lemoyne, PA 17043.
5. The Mortgage is now in default due to the failure of the Defendant(s) to make
payments as they become due and owing. The following amounts are due:
Principal Balance $69,301.32
Interest to 11/16/2000 6,193.77
Accumulated Late Charges 1,115.80
NSFBPO/Inspections 347.15
Attorney Fees/Costs 3,700.00
Suspense Balance (30.78)
TOTAL $80,627.26
plus interest from 11/17/2000 at $27.91 per day, costs of suit and attorney
fees.
6. In accordance with the provisions of the Act of January 30, 1974, P.L. 13 No.
6, Section 403 (41 P.S. 403), a Notice of Intention to Foreclose is required and
the Notice of Homeowners' Emergency Mortgage Assistance was sent to
defendants November 20, 2000. The Defendant(s) have not cured the default.
WHEREFORE, Plaintiff requests the court enter judgment in Mortgage Foreclosure for
the sale of the mortgaged property in Plaintiff's favor and against the Defendant(s), in the
sum of $80,627.26 together with the interest from 11/17/2000 at $27.91 per day, costs of
suit and attorney fees.
Law offices of Gregory Javardian
BY:
fREAttomey AVARDIAN
o.55669
• NOT10
LOAN NO.005010509
cis ese?S- January 10. 1998 HARRISgU0.G•. PA 17110
treats tbNt '
040 gOSLE0. AVE.LEMOYNE,PA 17040 41 ?I
owewwt
1. BORROWER'S PROMISE TO PAY
In return f o r a Ivan am I bald recal"d. T proud" to p 4 y U.S. S 69 . 6 0 o . 00 (this amount is called
'principal'), plus butte, so the order of the Leader. lbw Leader k
ALTERNATIVE LENDING MORTGAGE CORP.
I anderstand dent the Linda mq transfer this Note. The Lender or anyone who takes this Note by transfer and who is
eatltiW to receive payramnts alder this Note is called the 'Note Holder.'
2. INI'BRFM
Imcrest will be charged m tmpaid principal until the fell amount of ptiaelpal has beeapaid. twill pay interest at a
yearty ram of 14 . 7 0 0 0 R.
The Interest rate requited by this Session 2 is the tam 1 will pay both before and after say Jefadl described In Section
6(B) of this Note.
).PAYMENTS
(A) Time and place of Payments
I will pay principal and intent by making PQy[Wdts every month.
I will make my marbly payments m the 4 t h day ofeach wosdo beginning on March 4. 1998 .Twill
make these payments every month tmhl s lams paid all of the principal and interest and my other charges described below
that I may owe ander ft Now. My monthly payments will be applied to Lowest before ptimetpal. If, on February 4.
2013 , I still owc amounts under this Nom. I will pay those Arcanum In NO on that date, which Is called the'marudty due.'
Twi6makentymocthlypaymauu 305 5TH STREET .
BAY CITY, Mt 48706
or at a different place if required by the Nom Holder.
(B) Amount of Monthly Payments 179 payments monthly of S863.38 beginning March 4. 1998
My otoatblypsymeatwiBbe Lathe amomtofU.S.5 1 payment of f 63.467.53 due on February 4. 2013
4. BORROWER'S RIGHT TO PREPAY
I have the right to make payments of pr6adpal at any time before they am due. A paymear of princpal only is known
as a'prepaymrnt." When I make a prepaymeat, I will tell the Nom Holder in "ruing that I ata doing so.
If 1 make a prepayment within the first twelve (12) months after the dam of this Now, I will be required to pay a
prepayment penalty equal m F I v e per cent r 5 . or )of the ataoaat I prepay. T will not be requisd w pay any
prepayment penalty otter twelve months after the data of ids Nom. The Now Holder will use all of my pmpaymema to
reduce the amount of principal that T owe wader this Note. U I make a partial prepayment, there will be to changes in the
due dare or in the amount of my mooWy payment unless the Now Holder agrees is writing to those changes.
S. LOAN CHARGES
If a law, which applies to, Mils loan and which sum maximumloaa charges, is finally interpreted so that the Interest of
other loan charges collected or to be collected in connection with this loan exeoxl the peracitted limits, Own: (i) any each
loan charge shalt be reduced by the amount neceuaty m reduce the charge to the Permitted limit; and (I) sty sums
already calmed from mw which exceeded pertained Ihoits will be reftdedto inc. The Note Holder aoay choose to make
this refund by reducing the principal I owe under this New or by maldog a direct pay" a, to inc. If a refund reducea
priulld, the reduction will be treated as a partial prepayment.
6. BORROWER'S FAH.URE TO PAY AS REQUIRED
(A) Use Charge for Overdue paymeam
If the Notes Holderbas nor received The %U -motto[ of my momWy payment by the and of 15 calendar days after
the due it is doe. I wilpay elan ebarge to the Nom Holder. 71meamouotofdterhmgew0l be 5.000 %ofmyoverdue
payment of pdmclpal and inarest. 1 will pay We has charge promptly but only voce m each beepsymont.
(0) Default
ME do most pay the full amount of each monibiy payment on the due it Is due, l wall be in delimit.
(C) Notice of Dda"It
If I cam )a deBWt, the Now Holder may sand me a written notice wiling me that if I do not pay the overdue aawmt by
a certain date, the Note Holder flay retptita ra to pay bo mediudy the full success of pdncpal which ben eat been. paid
and all the interest that I owe om East amoamt. Ilan dam tm rtbe at kart 30 days after the dam on which the notice it
delivered or waded to inc.
(1)) No Waller By Note Holder
Evan If, at a time whom I sat bat dsfka. the Nom Holder does eat setlnlte me to pay Immediately in fall as described
above, the Now Holder will UM have the right to do m if I am in default At a ]star thm.
(E) Payment of Note Holdees Costs and Expenses
If then Now Haider has required me to pay ltd La fall as dem-bod above, the Nom Haider wM have the eight
to be paid back by me for all of to mm anti expwes In entoming ids Nom to the extent eat pmbibtkd by applicable law.
Those avoues Laclede, for example. mammble anomeys' foas.
7. GIVING OF NOTICES
Unless applicable law requites a dH[erem aaet A my notice that meet be Stream ate under this Note will be given
by delivering it or by mailin it by am[ clan ma0 to are u the Prop" Address above or a a dlffinem address if l Stva Oe
Note Helder a notice of MY da6cz l ¦ddrms.
Any notce thatmum be gfveato then Nom Holder tmdm•ebia Nom w)H be g(vom by mdlhag ]t by tint elms mail m the
Nom Holder at the whiten stated La Sattim 3(A) above er atadiffereat address HI m given amtia of that different
address.
SJNGLE fAMMT
PAOEl OF2
Tint is NOTA 31SUMN 31 FORM
Lack MPtomort"
RR ral'm Nate bTbrv
• LOSHO. up us 10509
R. ORIAGATIONS OF PERSONS TINDER THIS NOTE.
If more than one person signs this Nom, each person is fully and personally obligated to kcap all of the promises
made in this Nom, Including the promise to pay the full amount owed. Any pants who is a guarantor, surety, or endorser of
this Note is also obligated to do these things. Any person who Uka over these obligations, Including the obligations of a
guarantor, surety or endona of this Now. is also obligated to keep all of the promises made in this Note. The Nom Holder
may enforce Its rights under this Note against each person individually or against all of us together. This me" that any
unc of us navy b: required to pay tlt or the amounts owed umh:r this Note.
t
9. WAIVERS
I and my other person who has obligations under this Nom waive the rights of presentment and notice of dishonor.
'Pm 11111ient' means the tight to require the Note Holder to demand payment of amounts due. 'Notice of dishonor'
means the right to require the Note Holder to give notice to other persona that amounts due have not been paid,
10. UNIFORM SECURED NOTE
This Nom is a uniform instrument with limited variations in some jurisdictions. In addition to the protections given to
the Note Holder under this Note, a Mortgage, Deed of Treat or Security Deed (the -Security Instrument"), dated the same
date as this Note, protects the Note Holder from possible losses which might result If 1 do not keep the promises which)
make in this Note. That Security lnstnunent describes how and under what conditions I may be required to make
immediate payment in hull of all amounts I owe under this Note. Some of thou conditions are described as follows:
Transfer of the Property or a Beneficial latvsst to Borrower. If all or any pan of the Property or any
Interest in it is sold or transferred (or if a beneficial interest in Borrower Is sold or transferred ad Borrower is
not s natural person) without larder's prior written consent, Lender may, at Its option, require immediate
payment in full of all sums secured by this Security Instrument. However, this option shaft not be exercised by
Lender if exercise is prohibited by federal law as of the date of this Security Instrument.
If !.ender exercises this option. Lenda shall give Borrower notice of acceleration. The notice shall provide
a period of not less than 30 days from the date the mice is delivered or mailed within which Borrower must
pay all sums secured by this Security Instrument If Borrower fails to pay these surest prior to the expiration of
this period, Lender may invoke any remedies permitted by this Security Instrument without further notice or
demand on Borrower.
WITNESS THE HAND(S) AND SEAL(S) OF THE UNDERSIGNED.
_a 'Y ?"
"'
(scup LaVIAC 'at ?/
I can8
awrower EDWARD M. V
O
G H T
` Eerrower
O //
J
j
7
'
ISrap f,rR /[•).
A
Xth (Sttll
8orraaer C A R O L B . V O G H T
(Sign Original Only)
Without Recourse, Pay to the Order of.
this JOCh dayofJanuary .1998
ALTERN QIV LENDING MORTGAGE CORP.
D ab ra rr
Asst. Vice President
MULTESTATE MM RATRNOTE - SINGLE FAMMY - FMNA/P UNIC UMMIrM INSM 1hBN1'- FORM 3200 UM
1SGCPN--iM9D0Ml2-a3}L PAGE2 OF2
IALLOON RIAF.R TO NOTE •
EDWARD M. VOGHT
BORROWER NAME(S)! C A R O L R. V 0 G H T
NOTE DATE: 01/30/98
For a valuable consideration, receipt of which is hereby acknowledged, both Borrower end Lender agree
that this BALLOON RIDER TO NOTE ("Rider") amends that certain Promissory Note ("Note") of date shown
above. to which this Rider is attached. Borrower and lender agree that this Note shall be subject to the
following provisions, notwithstanding any provisions to the contrary contained in said Note of the Mortgage
given by Borrower to secure repayment of the Note.
BALLOON PAYMENT
This loan is payable in full at the end of fifteen (15) years. Bormweta must re pay the entire principal
balance of the loan and the unpaid interest then due. THE LENDER IS UNDER NO OBLIGATION TO
REFINANCE THE LOAN AT THAT TIME. Borrower will therefore be required to make payment out of other
assets borrower may own, or borrower will have to find a lender, which may, be the lender borrowers has
this loan with, willing to lend borrower the money at prevailing market rates, which may be considerbaly
higher or lower than the interest rate on this loan. If borrowers refinances this loan at maturity, borrower
may have to pay some or all closing costs nominally associated with a new loan, even if borrower obtains
refinancing from the same tender.
NOTICE OF MATURITY
At least nicety (90) but not more than oft hundred twenty (120) days prior to the Maturity time, Lender
moat send Borrower A notice which states the maturity date and the amount of the large balloon payment
which will he due on the maturity date (assuming all scheduled regular monthly payments due between the
date of the notice and the Maturity date are made on time).
woes S AL B??OAIL
a^nuvnCr EUWA D M. VOGHTf/
lwrrower a )6 Z6-eI NC.
CAROL B. VOC k/
.t
•
Parcel Number:
AP 01-VOGHT 0198
LN BDBOIOS09
[Space Above Mds Lice For Reeordiug Data)
MORTGAGE
CeditiEd True and Correct
Cody of the Original
THIS MORTGAGE ("Security Instrument") is given on January 30. 1998 The mortgagor is
EDWARD M. VOGHT and CAROL B. VOGT. Husband and wife
("Borrower"). This Security Instrument is given to ALTERNATIVE LENDING MORTGAGE CORP
which is organized and existing under the laws of THE STATE OF FLORIDA and whose
address is 2229 PAXTON CHURCH ROAD, HARRISBURG. PA 17110
("Lender"). Borrower owes Lender the principal sum of
Sixty Nine Thousand Six Hundred and no/100
Dollars (u.s. $ 69.600.00 ).
This debt is evidenced by Borrower's note dated the same date as this Security Instrument ("Note"), which provides for
monthly payments, with the full debt, if not paid earlier, due and payable on February 4, 2013
This Security Instrument secures to Lender: (a) the repayment of the debt evidenced by the Note, with interest, and all renewals,
extensions and modifications of the Note; (b) the payment of all other smo, with interest, advanced under paragraph 7 to
protect the security of this Security Instrument; and (c) the performance of Borrower's covenants and agreements under this
Security Instrument and the Note. For this purpose, Borrower does hereby mortgage, grant and convey to Lender the following
described property located in CUMBERLAND County, Pennsylvania:
THE LAND REFERRED TO IS LOCATED IN THE COUNTY OF CUMBERLAND, COMMONWEALTH OF
PENNSYLVANIA AND IS DESCRIBED AS FOLLOWS: SEE ATTACHED LEGAL: COMMONLY KNOWN AS: 340
BOSLER AVENUE TAX IN 12-21-0265-282
which has the address of 340 BOSLER AVE. LEMOYNE [sn«t. City].
Pennsylvania 17043 [zip Coal ("Property Address");
PENNSYLVANIA-Single Family-FNMAlFHLMC
UNIFORM INSTRUM@rT Fam 3038 BISO
t=t; t 1& AmsntlW !97 • 111111111111 Pogo 1 of a 6 6 TG Mw tlwtro 19 J
VMP MORTGAGE inM16 • IBD01621.72•]2eI n e,'
All that certain lot or piece of land situate with Improvements thereon erected, in the Borough of
Lemoyne, Cumberland County, Pennsylvania, being known as 340 Basler Avenue, more
particularly bounded and described in accordance with map of property made by Gerrit J. Betz
Associates, Inc.. Engineers and Surveyors, Shiremanstown, PA dated January 4, 1978, Dwg. No.
78113, as follows, to wit;
Beginning at a hub set on the southeast side of Basler Avenue (an 80 feet wide right of way), a
comer of lands of Lynn Leon Evinger, which beginning hub Is measured along same ninety (97)
feet from the Intersection of the southeast hub and measured along the southeast comer of 4th
Street and Basler Avenue; thence extending from said beginning hub and measured along the
southeast side of Basler Avenue, North 52 degrees 00 minutes East 30.0 feet to a hub, a corner
of lands or Harvey F. Hartman; thence extending along said lands South 38 degrees 00 minutes
East 150.0 feet to a hub set on the northwest side of Apple Alley (15 feet wide right of way);
thence extending along some South 52 degrees 00 minutes West 30.0 feet to a hub, a corner of
lands of Lynn Leon Evinger, aforesaid; thence extending along said lands North 38 degrees 00
minutes West 150.0 feet to a hub, tho first mentioned hub, and the place of beginning.
COMMONLY KNOWN AS: 340 BOSLER AVENUE TAX (DO
12.21.0265-2B2
TOGETHER WITH all the improvements now or hereafter erected on the proper and all easements, appurtenances, and
fixtures now or hereafter a part of the property. AB replacements and additions shall also be coveted by this Security
Instrument. AB of the foregoing is referred to in this Security Instrument as the "Property."
BORROWER COVENANTS that Borrower is lawfully seised of the estate hereby conveyed and has the right to mortgage,
grant and convey the Property and that the Property Is unencumbered, except for encumbrances of record. Borrower warrants
and will defend generally the title to the Property against all claims and demands, subject to any encumbrances of record.
THIS SECURITY INSTRUMENT combines; uniform covenants for national use and non-uniform covenants with limited
variations by jurisdiction to constitute a uniform security instrument covering real property.
UNIFORM COVENANTS, Borrower and Lender covenant and agree as follows:
1. Payment of Principal and Interest; Prepayment and Late Charges. Borrower shall promptly pay when due the
principal of and Interest on the debt evidenced by the Note and any prepayment and late charges due under the Note.
2. Muds for Taxes and Insurance. Subject to applicable law or to a written waiver by Lender, Borrower shall pay to
Lender on the day monthly payments are due under the Note, until the Note is paid in full, a sum ("Funds') for: (a) yearly taxes
and assessments which may attain priority over this Security Instrument as a lien on the Property; (b) yearly leasehold payments
or ground rents on the Property, if any; (c) yearly hazard or property insurance premiums; (d) yearly flood insurance premiums,
if any; (e) yearly mortgage insurance premiums, if any, and (fl any sums payable by Borrower to Lender, in accordance with
the provisions of paragraph B, in lieu of the payment of mortgage insurance premiums. These items are called "Escrow Items."
Lender may. at any time, collect and hold Funds in an amount of to exceed the maximum amount a lender for a federally
related mortgage loan may require for Borrower's escrow account under the federal Real Estate Settlement Procedures Act of
1974 as amended from time to time, 12 U.S.C. Section 2601 et seq. ("RESPA"), unless another law that applies to the Funds
sets a lesser amount. If so, Lender may, at any time, collect and hold Funds in an amount not to exceed the lesser amount.
Lender may estimate the amount of Funds due on the basis of current data and reasonable estimates of expenditures of future
Escrow Items or otherwise in accordance with applicable law.
The Funds shall be held in an institution whose deposits are insured by a federal agency, instrumentality, or entity
(including Lender, if Leader is such an institution) or in any Federal Home Loan Bank. Lender shall apply the Funds to pay the
Escrow Items. Lender may not charge Borrower for holding and applying the Funds, annually analyzing the escrow account, or
verifying the Escrow Items, unless Lender pays Borrower interest on the Funds and applicable law permits Lender to make such
a charge. However, Lender may require Borrower to pay a one-time charge for an independent real estate tax reporting service
used by Lender in connection with this loan, unless applicable law provides otherwise. Unless an agreement is made or
applicable law requires interest to be paid. Lender shall not be required to pay Borrower any interest or earnings on the Funds.
Borrower and Lender may agree in writing, however, that interest shall be paid on the Funds. Lender shall give to Borrower,
without charge, an annual accounting of the Funds, showing credits and debits to the Funds and the purpose for which each
debit to the Funds was made. The Funds are pledged as additional security for all sums secured by this Security Instrument.
If the Funds held by Lender exceed the amounts permitted to be held by applicable law, Lender shall account to Borrower
for the excess Funds in accordance with the requirements of applicable law. If the amount of the Funds held by Lender at any
time is not sufficient to pay the Escrow Items when due, lender may so notify Borrower in writing, and, in such case Borrower
shall pay to Lender the amount necessary to snake up the deficiency. Borrower shall make up the deficiency in no more than
twelve monthly payments, at Lender's sole discretion.
Upon payment in full of all sums secured by this Security Instrument, Lender shall promptly refund to Borrower any
Funds held by Lender. If, under paragraph 21, Lender shall acquire or sell the Property, Lender, prior to the acquisition or sale
of the Property, shall apply any Funds held by Lender at the time of acquisition or sale as a credit against the sums secured by
this Security Instrument.
3. Application or Payments. Unless applicable law provides otherwise, all payments received by Lender under paragraphs
1 and 2 shall be applied; fast, to any prepayment charges due under the Note; second, to amounts payable under paragraph 2;
third, to interest due; fourth, to principal due; and last, to any late charges due under the Note.
4. Charges; Liens. Borrower shall pay all taxes, assessmeots, charges, fires and impositions attributable to the Property
which may attain priority over this Security Instrument, and leasehold payments or ground rents, if any. Borrower shall pay
these obligations in the manner provided in paragraph 2, or if not paid in that manner, Borrower shall pay them on time directly
to the person owed payment. Borrower shall promptly furnish to Lender all notices of amounts to be paid under this paragraph.
If Borrower makes these payments directly, Borrower shall promptly furnish to Lender receipts evidencing the payments.
Borrower shall promptly discharge any lien which has priority over this Security Instrument unless Borrower. (a) agrees in
writing to the payment of the obligation secured by the lien in a manner acceptable to Leader; (b) contests in good faith the lien
by, or defends against enforcement of the lien in, legal proceedings which in the Lender's opinion operate to prevent the
enforcement of the lieu or (e) secures from the holder of the lien an agreement satisfactory to Lender subordinating the lien to
this Security Instrument. If Linder determines that any part of the Property is subject to a lien which may attain priority over
this Security Instrument, Lender may give Borrower a notice identifying the lien. Borrower shall satisfy the lien or take one or
more of the actions set forth above within tO days of the giving of notice.
0®7WPM 1941m.03 r.• xm 6 Wdn
norm 3039 9190
S. Hazard or Property I • Borrower shall keep the improvements existing or hereafter erected on the
Property insured against loss by fire, hazards included within the term "extended coverage" and any other hazards, including
floods or flooding, for which Leader requires insurance. 'This insurance shall be maintained in the amounts and for the periods
that Lender requires. The insurance carrier providing the insurance shall be chosen by Borrower subject to Lender's approval
which shall not be unreasonably withheld. If Borrower falls to maintain coverage described above. Leader may, at Lender's
option, obtain coverage to protect Lender's rights in the Property in accordance with paragraph 7.
All insurance policies and renewals shall be acceptable to Lender and shall include a standard mortgage clause. Lender
shall have the right to hold the policies and renewals. If I ender requites, Borrower shad promptly give to Lender all receipts of
paid premiums and renewal notices. In the event of loss, Borrower shall give prompt notice to the insurance carrier and Lender.
Lender may make proof of loss if not made promptly by Borrower.
Unless Lender and Borrower otherwise agree in writing, insurance proceeds shall be applied to restoration or repair of the
Property damaged, if the restoration or repair is economically feasible and Lender's security is not lessened. If the restoration or
repair is not economically feasible or Lender's security would be lessened, the insurance proceeds shall be applied to the sums
secured by this Security Instrument, whether or not then duce, with any excess paid to Borrower. If Borrower abandons the
Property, or does not answer within 30 days a notice from Lender that the insurance carrier has offered to settle a claim, then
Lender may collect the insurance proceeds. Lender may use the proceeds to repair or restore the Property or to pay sutras
secured by this Security Instrument, whether or not then due. The 3D-day period will begin when the notice is given.
Unless Lender and Borrower otherwise agree in writing, any application of proceeds to principal shall not extend or
postpone the due date of the monthly payments referred to in paragraphs 1 and 2 or change the amount of the payments. If
tinder paragraph 21 the Property is acquired by Lender, Borrower's right to any insurance policies and proceeds resulting from
damage to the Property prior to the acquisition shall pass to Lender to the extent of the sums secured by this Security Instrument
immediately prior to the acquisition.
6. Occupancy, Preservation, Maintenance and Protection of the Property; Borrower's Loan Application;
Leaseholds. Borrower shall occupy, establish, and use the Property as Borrower's principal residence within sixty days after the
execution of this Security Instrument and shall continue to occupy the Property as Borrower's principal residence for at least one
year after the date of occupancy, unless Lender otherwise agrees in writing, which consent shall not be unreasonably withheld,
or unless extenuating circumstances exist which are beyond Borrower's control. Borrower shall not destroy, damage or impair
the Property, allow the Property to deteriorate, or commit waste on the Property. Borrower shall be in default if any forfeiture
action or proceeding, whether civil or criminal, is begun that in Lender's good faith judgment could result in forfeiture of the
Property or otherwise materially impair the lien created by this Security Instrument or Lender's security interest. Borrower may
cure such a default and reinstate, as provided in paragraph 18, by causing the action or proceeding to be dismissed with a ruling
that, in Lender's good faith determination, precludes forfeiture of the Borrower's interest in the Property or other material
impairment of the lien created by this Security Instrument or Lender's security interest. Borrower shall also be in default if
Borrower, daring the loan application process, gave materially false or inaccurate information or statements to Lender (or failed
to provide Lender with any material information) in connection with the loan evidenced by the Note, including, but not limited
to, representations concerning Borrower's occupancy of the Property as a principal residence. If this Security Instrument is on a
leasehold. Borrower shall comply with all the provisions of the lease. If Borrower acquires fee title to the Property, the
leasehold and the fee title shall rot merge unless Lender agrees to the merger in writing.
7. Protection or Lender's Rights in the Property. If Borrower fails to perform the covenants and agreements contained in
this Security Instrument, or there is a legal proceeding that may significantly affect Lender's rights in the Property (such as a
proceeding in bankruptcy, probate, for condemnation or forfeiture or to enforce laws or regulations), then Lender may do and
pay for whatever is necessary to protect the value of the Property and Leader's rights in the Property. Lender's actions may
include paying any sums secured by a lien which has priority over this Security histrument, appearing in court, paying
reasonable attorneys' fees and entering on the Property to make repairs. Although Lender may take action under this paragraph
7, Lender does not have to do so.
Any amounts disbursed by Lender under this paragraph 7 shall become additional debt of Borrower secured by this
Security Instrument. Unless Borrower and Lender agree to other terms of payment, these amounts shall bear interest from the
date of disbursement at the Note rate and shall be payable, with interest, upon notice from Lender to Borrower requesting
payment.
8. Mortgage Insurance. If Leader required mortgage insurance as a condition of making the loan secured by this Security
Instrument, Borrower shall pay the premiums required to maimaht the mortgage insurance in effect. If, for any reason, the
mortgage insurance coverage required by Lender lapses or ceases to be in effect. Borrower shall pay the premiums required to
obtain coverage substantially equivalent to the mortgage insurance previously In effect, at a cost substantially equivalent to the
cost to Borrower of the mortgage itrsunoce previously in effect, from an alternate mortgage insurer approved by Lender. If
substantially equivalent mortgage insurance coverage is not available, Borrower shall pay to Lender each month a sum equal to
ouetwelfth of the yearly mortgage insurance premium being paid by Borrower when the insurance coverage lapsed or ceased to
be in effect. Lender will accept, use and retain these payments as a loss reserve in lieu of mortgage Insura_ncceee..?v1LDS$ reserve
40m -SR(PA) rasor.m Paus 0 8 ?0T
06 t/ Form 3039 9190
payments may no longs be required. I option of Lender, if mortgage insuranx Age (m the amount and for the period
that Lender requires) provided by an insurer approved by Lender again Iecomer avallable and is obtained. Borrower shall pay
the premiums required to maintain mortgage wants= in effect, or to provide a loss reserve, until the requirement for mortgage
instuance ends in accordance with any written agreement between Borrower and Lender or applicable law.
9. Inspection. Lender or its agent may make reasonable entries upon and inspections of the Property. Lender shall give
Borrower notice at the time of or prior to an inspection specifying reasonable cause for the inspection.
10. Condemnation. The proceeds of any award or claim for damages, direct or consequential, in connection with any
condemnation or other taking of any part of the Property, or for conveyance in liar of condemnation, are hereby assigned and
shall be paid to Lender.
In the event of a total taking of the Property, the proceeds shall be applied to the sums attained by this Security Instrument,
whom or not then due, with any excess paid to Borrower. In the event of a partial taking of the Property in which the fair
market value of the Property immediately before the taking is equal to or greater than the amount of the sums secured by this
Security Instrument immediately before the taking, unless Borrower and Lender otherwise agree in writing, the sums secured by
this Security Instrument shall be reduced by the amount of the proceeds multiplied by the following fraction: (a) the total
amount of the sums secured immediately before the taking, divided by (b) the fair market value of the Property immediately
before the taking. Any balance shall be paid to Borrower. In the event of a partial tatting of the Property in which the fair
market value of the Property immediately before the taking is less than the amount of the sums secured immediately before the
taking, unless Borrower and Lender otherwise agree in writing or unless applicable law otherwise provides, the proceeds shall
be applied to the atoms secured by this Security Instrument whether or not the sutras are then due.
If the Property is abandoned by Borrower, or if, after notice by Leader to Borrower that the oondemoor offers to make an
award or settle a claim for damages, Borrower fails to respond to Lender within 30 days after the date the notice is given,
Lender is authorized to collect and apply the proceeds, at its option, either to restoration or repair of the Property or to the sums
secured by this Security Instrument, whether or not then due.
Unless Lender and Borrower otherwise agree in writing, any application of proceeds to principal shall not extend or
postpone the due date of the monthly payments referred to in paragraphs 1 and 2 or change the amount of such payments.
11. Borrower Not Released; Forbearance By Lender Not a Waiver. Extension of the time for payment or modification
of amortization of the sums secured by this Security Instrument granted by Lender to any successor in interest of Borrower shall
not operate to release the liability of the original Borrower or Borrower's successors in interest. ]ender shall not be required to
commence proceedings against any successor in interest or refuse to extend time for payment or otherwise modify amortization
of the sums secured by this Security Instrument by reason of any demand made by the original Borrower or Borrower's
successors in interest. Any forbearance by Lender in exercising any right or remedy shall not be a waiver of or preclude the
exercise of any right or remedy.
12. Successors and Assigns Bound; Joint and Several Liability; Co-signers. The covenants and agreements of this
Security Instrument shall bind and benefit the successors and assigns of Lender and Borrower, subject to the provisions of
paragraph 17. Borrower's covenants and agreements shah be joint and several. Any Borrower who co-signs this Security
Instrument but does not execute the Note: (a) is co-signing this Security Instrument only to mortgage, grant and convey that
Borrower's interest in the Property under the terms of this Security Instrument; (b) is not personally obligated to pay the sums
secured by this Security Instrument; and (c) agrees that Lender and any other Borrower may agree to extend, modify, forbear or
make any accommodations with regard to the terms of this Security Instrument or the Note without that Borrower's consent.
13. Loan Charges. If the loan secured by this Security Instrument is subject to a law which sets maximum loan charges,
and that law is finally interpreted so that the interest or other loan charges collected or in be collected in connection with the
loan exceed the permitted limits, then: (a) any such loan charge shall be reduced by the amount necessary to reduce the charge
to the permitted llinit; and (b) any sums already collected from Borrower which exceeded permitted limits will be refunded to
Borrower. Lender may choose to [Hake this refund by reducing the principal owed under the Note or by making a direct
payment to Borrower. If a refund reduces principal, the reduction will be treated as a partial prepayment without any
prepayment charge under the Note.
14. Notices. Any notice to Borrower provided for in this Security Instrument shall be given by delivering it or by mailing
it by fast class mail unless applicable taw requires use of another method. The notice shall be directed to the Property Address
or any other address Borrower designates by notice to Lender. Any notice to Lender shall be given by fast class mail to
Lender's address stated herein or any other address Leader designates by notice to Borrower. Any notice provided for in this
Security Instrument shall be deemed to have been given to Borrower or Lender when given as provided in this paragraph.
15. Governing Law; Severability. This Security Insentient shall be governed by federal law and the law of the
jurisdiction in which the Property is located. In the event that any provision or clause of this Security Instrument or the Note
conflicts with applicable law, such conflict shall not affect other provisions of this Security Instrument or the Note which can be
given effect without the conflicting provision. To this end the provisions of this Security Instnunent and the Note are declared
to be severable.
16. Borrower's Copy. Borrower shall be given one conformed copy of the Note and of this Security instrument.
400 -6RIPAi ta+imm P".406 CW Form 3039 Stan
•
17. Transfer of the Property or a Beneficial Intaxst in Borrower. If all or any part of the Property or any interest in it
is sold or transferred (or if a beneficial interest in Borrower is sold or transferred and Borrower is not a natural person) without
Lender's prior written consent, Leader may, at its option, use immediate payment in full of all sums secured by this
Security Inant>mmt. However, this option shall not be exereised y Lender if exercise is prohibited by federal law as of the data
of this Scratchy Instru®ent.
If Leader exercises this option, Leader shall give Borrower notice of acceleration. The notice shall provide a period of not
less than 30 days from the date the notice is delivered or mailed within which Borrower must pay all sums secured by this
Security fasnumeat. If Borrower fails to pay these sums prior to the expiration of this period, Lender may invoke any remedies
permitted by this Security Instrument without further notice or demand on Borrower.
18. Borrower's Right to Reinstate. If Borrower meets certain conditions, Borrower shall have the right to have
enforcement of this Security Instrument discontinued at any time prior to the earlier of. (a) 5 days (or such other period as
applicable law may specify for reinstatement) before sale of the Property pursuant to any power of We contained in this
Security Instrument; or (b) entry of a judgment enforcing this Security Instrument. Those conditions are that Borrower: (a) pays
Lender all sums which then would be due under this Security Instrument and the Note as if no acceleration had occurred; (b)
cares any default of any other covenants or agreements; (c) pays all expenses incurred is enforcing this Security Instrument,
including, but not limited to, reasonable attorneys' fees; and (d) takes such action as Larder may reasonably require to assure
that the lien of this Security Instrument, Lender's rights in the Property and Borrower's obligation to pay the sums secured by
this Security Instrument shall continue unchanged. Upon reinstatement by Borrower, this Security Instrument and the
obligations secured hereby shall remain fully effective as if no acceleration had occurred. However, this right to reinstate shall
not apply in the case of acceleration under paragraph 17.
19. Sale of Note-, Change of Loan Servicer. The Note or a partial interest in the Note (together with this Security
Instrument) may be sold one or more times without prior notice to Borrower. A sale may result in a change in the entity (known
as the 'Loan Servicer") that collects monthly payments due under the Note and this Security Instrument. There also may be one
or more changes of the Loan Servicer unrelated to a sale of the Note. If there is a chance of the Loan Servicer, Borrower will be
given written notice of the change in accordance with paragraph 14 above and applicable law. The notice will state the name and
address of the new Loan Servicer and the address to which payments should be made. The notice will also contain any other
information required by applicable law.
20. Hazardous Substances. Borrower shall not cause or permit the presence, use, disposal, storage, or release of any
Hazardous Substances on or in the Property. Borrower shall not do, nor allow anyone else to do, anything affecting the
Property that is in violation of any Environmental Law. The preceding two sentences shall not apply to the presence, use, or
storage on the Property of small quantities of Hazardous Substances that are generally recognized to be appropriate to normal
residential uses and to mainteoacce of the Property.
Borrower shall promptly give Lender written notice of any investigation, claim, demand, lawsuit or other action by any
governmental or regulatory agency or private party involving the Property and any Hazardous Substance or Environmental Law
of which Borrower has actual knowledge. If Borrower learns, or is notified by any governmental or regulatory authority, that
any removal or other remediation of any Hazardous Substance affecting the Property is necessary, Borrower shall promptly take
all necessary remedial actions in accordance with Environmental Law.
As used in this paragraph 20, "Hazardous Substances" are those substances defined as toxic or hazardous substances by
Environmental Law and the following substances: gasoline, kerosene, other flammable or toxic petroleum products, toxic
pesticides and herbicides, volatile solvents, materials containing asbestos or formaldehyde, and radioactive materials. As used in
this paragraph 20, "Environmental Law' means federal laws and laws of the jurisdiction where the Property is located that
relate to health, safety or environmental protection.
NON-UNIFORM COVENANT'S. Borrower and Lender further covenant and agree as follows:
21. Acceleration; Remedies. Lender shall give notice to Borrower prior to acceleration following Borrower's breach
of any covenant or agreement in this Security Instrument (but not prior to acceleration under paragraph 17 unless
applicable law provides otherwise). Lender shall notify Borrower of, among other things: (a) the default; (b) the action
required to cure the default; (c) when the default must be cured; and (d) that failure to cure the default as specified may
result in acceleration of the sums secured by this Security Instrument, foreclosure by judicial proceeding and sale of the
Property. Lender shall farther inform Borrower of the right to reinstate after acceleration and the right to assert in the
foreclosure proceeding the non-existence of a default or any other defense of Borrower to acceleration and foreclosure. If
the default is sot cared as specified, I.ender, at its option, may require immediate payment in full of all sums secured by
this Security Instrument without further demand and may foreclose this Security Instrument by judicial proceeding.
Lender shall be entitled to collect all expenses incurred in pursuing the remedies provided in this paragraph 21,
including, but not limited to; attorneys' fees and costs of title evidence to the extent permitted by applicable law.
22. Release. Upon payment of all sums secured by this Security Instrument, this Security Instrument and the estate
conveyed shall terminate and become void. After such occurrence, Lender shall discharge and satisfy this Security Instrument
without charge to Borrower. Borrower shall pay any recordation costs.
23. Waivers. Borrower, to the extent permitted by applicable law, waives and releases any error or defects in proceedings
to enforce this Security Instrument, and hereby waives the benefit of any present or future laws providing for stay of execution,
extension of time, exemption from attachment, levy and sale, and homestead exemption.
24. Reinstatement Period. Borrower's time to reinstate provided in paragraph 18 shall extend to one hour prior to the
commencement of bidding at a sheriffs sale or other sale pursuant to this Security Instrument.
25. Purchase Money Mortgage. If any of the debt secured by this Security Instrument is lent to Borrower to acquire title
to the Property, this Security Instrument shall be a purchase money mortgage.
26. Interest Rate After Judgment. Borrower agrees that the interest rate payable after a judgment is entered on the Note
or in an action of mortgage foreclosure shall be the rate payable from tints to time under the Note.
wars:
®®6R(PAt M4101.03 n.aa a a a v Form 3039 9190
• 0
27. Rlden to this Security In'struntent. If one or more riders are executed by Borrower and recorded together with this
Security Instrument, the covenants and agreements of each such rider shall be incorporated into and shall amend and supplement
the covenants and agreements of this Security Instrument as if the rider(s) were a part of this Security Instrument.
[Check applicable box(es)]
Adjustable Rate Rider Condominium Rider ED 1-4 Pamily Rider
Graduated Payment Rider Planned Unit Development Rider Biweekly Payment Rider
Balloon Rider Rate Improvement Rids Second Horne Rider
VA Rider Other(s) [specify] ATTACHED LEGAL
BY SIGNING BELOW, Borrower accepts and agrees to the terms and covenants contained in this Security Instrument and
in any rider(s) executed by Borrower and recorded with it.
Witnesses: 0on eMdi?TH 7 E??Q M. VOGHT
ur
G T
Q . G> CAROL B. VOG Tt U -Borrower
LB RT C. DAILEY
(Seal)
-Borrower
Cetiiffcate of Residence
(Seal)
-Bomwer
I, Debra L. Kerr , do hereby certify that the correct address of
the within-named mortgagee is 2229 PAXTON CHURCH ROAD, HARRISBURG. PA 17110
Witness my hand this 30th day of Janua y 8
Debra err Agent of Mortgagee
COMMONWEALTH OF PENNSYLVANIA, DAUPHIN County as:
On this, the 30th day of January 1998 , before me, the undersigned officer,
personally appeared EDWARD M. VOGHT and CAROL B. VOGHT
known to rue (or satisfactorily proven) to be the
persons whose names are subscribed to the within instrument and acknowledged that they
executed the same for the purposes herein contained.
IN WITNESS WHEREOF. I hereunto set my hand and official seal. 0.4-14 L? .7
My Commission Expires: ALBERT C. DAILEY
==M tt'=2 "w I NOTARY PUBLIC
t W 2a, not Title of officer
®m ea(PA) teawof m Member, Penna*anla Association of Notadeaoa. 6 or a Form 3039 9190
ACT 91 NOTICE
TAKE ACTION TO SAVE
YOUR HOME FROM
FORECLOSURE
November 20, 2000
TO: EDWARD M. VOGHT CAROL B. VOGHT
340 BOSLER AVENUE 340 BOSLER AVENUE
LEMOYNE, PA 17043 LEMOYNE, PA 17043
THIS FIRM IS A DEBT COLLECTOR ATTEMPTING TO COLLECT A DEBT. THIS NOTICE IS
SENT TO YOU IN AN ATTEMPT TO COLLECT THE INDEBTEDNESS REFERRED TO HEREIN
AND ANY INFORMATION OBTAINED FROM YOU WILL BE USED FOR THAT PURPOSE. IF
YOU HAVE PREVIOUSLY RECEIVED A DISCHARGE IN BANKRUPTCY, THIS
CORRESPONDENCE IS NOT AND SHOULD NOT BE CONSTRUED TO BE AN ATTEMPT TO
COLLECT A DEBT, BUT ONLY ENFORCEMENT OF A LIEN AGAINST PROPERTY.
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 30 DAYS OF THE DATE OF THIS NOTICE. Take this Notice with you when you meet 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 NOTIFICION EN ADJUNTO ES DE SUMA IMPORTANCIA, PUES AFECTA SU DERECHO A
CONTINUAR VIVIENDO EN SU CASA. IS NO COMPRENDE EL CONTENIDO DE ESTA
NOTIFICACION OBTENGA UNA TRADUCCION INMEDIATAMENTE LLAMANDO ESTA
AGENCIA (PENNSYLVANIA HOUSING FINANCE AGENCY) SIN CARGOS AL NUMERO
MENCIONADA ARRIBA. PUEDES SER ELEGIBLE PARA UN PRESTAMO POR EL PROGRAMA
LLAMADO "HOMEOWNERS EMERGENCY MORTGAGE ASSISTANCE PROGRAM" EL CUAL
PUEDA SALVAR SU CASA DE LA FERDIDA DEL DERECHO A REDIMAR SU HIPOTECA.
STATEMENTS OF POLICY
HOMEOWNER'S NAME(S): EDWARD M. VOGHT & CAROL B. VOGHT
PROPERTY ADDRESS: 340 BOSLER AVENUE, LEMOYNE, PA 17043
LOAN ACCT. NO.: 1605955
ORIGINAL LENDER ALTERNATIVE LENDING MORTGAGE CORP.
CURRENT LENDER/SERVICER: CITIFINANCIAL MORTGAGE COMPANY SERVICING
AGENT FOR THE CHASE MANHATTAN BANK, AS
TRUSTEE OF IMC HOME EQUITY LOAN TRUST ET AL
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 you mortgage for thirty (30) days from the date of this Notice. During that time you must
arrange and attend a face-to-face meeting with one of the consumer credit counseling agencies listed at the
end of this Notice. THIS MEETING MUST OCCUR WITHIN THE NEXT (30) DAYS. IF YOU DO
NOT APPLY FOR EMERGENCY MORTGAGE ASSISTANCE, YOU MUST BRING YOUR
MORTGAGE UP TO DATE, THE PART OF THIS NOTICE CALLED "HOW TO CURE YOUR
MORTGAGE DEFAULT" EXPLAINS HOW TO BRING YOUR MORTGAGE UP TO DATE.
CONSUMER CREDIT COUNSELING AGENCIES -If You meet with one of the consumer credit
counseling agencies listed at the end of this notice the lender may NOT take action against you for thirty
(30) days after the date 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). If you
have tried and are unable to resolve this problem with the lender, you have the right to apply for financial
assistance from the Homeowner's Emergency Mortgage Assistance Program. To do so, you must fill out
sign and file a completed Homeowner's 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. Your application MUST be filed or postmarked
within thirty (30) days of your face-to-face meeting.
YOU MUST FILE YOUR APPLICATION PROMPTLY. IF YOU FAIL TO DO SO OR IF YOU DO
NOT FOLLOW THE OTHER TIME PERIODS SET FORTH IN THIS LETTER, FORECLOSURE MAY
PROCEED AGAINST YOUR HOME IMMEDIATELY AND YOUR APPLICATION FOR MORTGAGE
ASSISTANCE WILL BE DENIED.
AGENCY ACTION- Available funds for emergency mortgage assistance are very limited. They will be
disbursed by the Agency under the eligibility criteria established by the Act. The Pennsylvania Housing
Finance Agency has sixty (60) days to make a decision after it receives your application. During that 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 Agency of its decision on you
application.
NOTE; IF YOU ARE CURRENTLY PROTECTED BY THE FILING
OF A PETITION IN BANKRUPTCY, THE FOLLOWING PART OF THIS NOTICE IS FOR
INFORMATION PURPOSE 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)
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: 340 BOSLER AVENUE, LEMOYNE, PA 17043 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: 5/4/00 thru 11/4/00 at $863.38 per month.
Monthly Payments Plus Late Charges Accrued: $7,159.46
NSF: $40.00
Insurance: $0.00
Other: $162.20
Property Inspection: $9.95
BPO: $135.00
Attorney fees: $50.00
(Suspense) ($30.78)
TOTAL AMOUNT TO CURE DEFAULT $7,525.83
B. YOU HAVE FAILED TO TAKE THE FOLLOWING ACTIONS (Do not use if not applicable):
N/A
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 $7,525.83
PLUS ANY MORTGAGE PAYMENTS AND LATE CHARGES WHICH BECOME DUE DURING
THE THIRTY (30) DAY PERIOD. Payment must be made either by cashier's check, certified check or
money order made payable and sent to: CITIFINANCIAL MORTGAGE COMPANY, 5901 E. FOWLER
AVENUE, TAMPA, FL 33617, ATTN: GENAIR BOYNES.
You can cure any other default by taking the following action within THIRTY (30) DAYS of the date of
this letter. (Do not use if not applicable) N/A.
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 attorney to start legal action to
foreclosure upon Your mortgage property.
IF THE MORTGAGE IS FORECLOSED UPON- The mortgage property will be sold by the Sheriff to pay
off the mortgage debt. If the lender refers your case to its attorney, 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 against you, you will
have to pay all reasonable attorneys' fees actually incurred by the lender even if they exceed $50.00. Any
attorney's fees will be added to the amount to 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 Sheriffs Sale as
specified in writing by the lender and by performing any other requirements 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 mortgage 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-
CITIFINANCIAL MORTGAGE COMPANY
5901 EAST FOWLER AVENUE
TAMPA, FL 33617
ATTN: GENAIR BOYNES
TEL. NO. 1-800-776-2211 EXT. 2325
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- You _ may or XX may not (check one) sell or transfer your
home to a buyer or transferee who will assume the mortgage debt, provided that all the outstanding
payments, charge and attorney's fees and cost are paid prior to or at the sale 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.
CONSUMER CREDIT COUNSELING AGENCIES SERVING YOUR COUNTY IS ATTACHED.
Very truly yours,
f . 4
O EY?O L NDER
NOTICE PURSUANT TO FAIR DEBT COLLECTION PRACTICES ACT
****s*??r**r***s?*s?*r**t•a?*?**•**?*r*st*x*«r?sr•*?«+rs*?*r?wt******+*?
This is an attempt to collect a debt and any information obtained will be used for
the purpose.
2. Unless you dispute the validity of this debt, or any portion thereof, within thirty
(30) days after receipt of this notice, the debt will be assumed to be valid by our
offices.
3. If you notify our offices in writing within thirty (30) days of receipt of this notice
that the debt, or any portion thereof, is disputed, our offices will provide you with
verification of the debt or copy of the judgment against you, and a copy of such
verification or judgment will be mailed to you by our offices.
4. If you notify our offices in writing within thirty (30) days of receipt of this notice,
our offices will provide you with the name and address of the original creditor, if
different from the current creditor.
PENNSYLVANIA HOUSING FINANCE AGENCY
HOMEOWNER'S EMERGENCY MORTGAGE ASSISTANCE PROGRAM
CONSUMER CREDIT COUNSELING AGENCIES
CUMBERLAND COUNTY
CCCS of Western Pennsylvania, Inc. Financial Counseling Services of Franklin
2000 Linglestown Road 31 West 3rd Street
Harrisburg, PA 17102 Waynesboro, PA 17268
(717) 541-1757 (717) 762-3285
Urban League of Metropolitan Harrisburg YMCA of Carlisle
N. 6 h Street 301 G Street
Harrisburg, PA 17101 Carlisle, PA 17013
(717) 234-5925 (717) 243-3818
FAX (717) 234-9459. FAX (717) 731-9589
Community Action Comm of the Capital
Region
1514 Derry Street
Harrisburg, PA 17104
(717) 232-9757
FAX (717) 234-2227
Adams County Housing Authority
139-143 Carlisle Street
Gettysburg, PA 17325
(717) 334-1518
FAX (717) 334-8326
PENNYLSVANIA BULLETIN, VOL. 29, NO. 23, JUNE 5, 1999
VERIFICATION
The undersigned hereby states that the statements made in the foregoing
pleading are true and correct to the best of his/her knowledge, information
and belief. The undersigned understands that the statements therein made
are made subject to the penalties of 18 Pa.C.S. Section 4904, relating to
unworn falsification to authorities.
// _?
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SHERIFF'S RETURN - REGULAR
CASE NO: 2001-00232 P
COMMONWEALTH OF PENNSYLVANIA:
COUNTY OF CUMBERLAND
CHASE MANHATTAN BANK ETC
VS
VOGHT EDWARD M ET AL
ROBERT L. FINK
, Sheriff or Deputy Sheriff of
Cumberland County,Pennsylvania, who being duly sworn according to law,
says, the within COMPLAINT - MORT FORE was served upon
VOGHT EDWARD M
the
DEFENDANT , at 0016:10 HOURS, on the 16th day of January 2001
at 340 BOSLER AVENUE
LEMOYNE, PA 17043 by handing to
CAROL VOGHT
a true and attested copy of COMPLAINT - MORT FORE together with
NOTICE
and at the same time directing Her attention to the contents thereof.
Sheriff's Costs:
Docketing 18.00
Service 9.92
Affidavit .00
Surcharge 10.00
.00
37.92
Sworn and Subscribed to before
41-
mmee this 2Y day of
1 A.D.
000 ?
Cy? ?• D0r .,?
Crbthonotary
So Answers:
/ P
R. Thomas Kline
01/16/2001
GREGORY JAVARDIAN
By?X
Depu y Sher3?f
SHERIFF'S RETURN - REGULAR
CASE NO: 2001-00232 P
COMMONWEALTH OF PENNSYLVANIA:
COUNTY OF CUMBERLAND
CHASE MANHATTAN BANK ETC
VS
VOGHT EDWARD M ET AL
ROBERT L. FINK
Sheriff or Deputy Sheriff of
Cumberland County,Pennsylvania, who being duly sworn according to law,
says, the within COMPLAINT - MORT FORE was served upon
VOGHT CAROL B
the
DEFENDANT at 0016:10 HOURS, on the 16th day of January 2001
at 340 BOSLER AVE
LEMOYNE, PA 17043 by handing to
CAROL VOGHT
a true and attested copy of COMPLAINT - MORT FORE together with
NOTICE
and at the same time directing Her attention to the contents thereof.
Sheriff's Costs:
Docketing 6.00
Service .00
Affidavit .00
Surcharge 10.00
.00
16.00
Sworn and Subscribed to before
me his dY c_ day of
all
Prothonotary
So Ans/veers
R. Thomas Kline
01/16/2001
GREGORY JAVARDIAN
By : -?
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epu `gFier
LAW OFFICES OF GREGORY JAVARDIAN
By: GREGORY JAVARDIAN, ESQUIRE
IDENTIFICATION NO. 55669
44 SECOND STREET PIKE, SUITE 101
SOUTHAMPTON, PA 18966
(215) 942-9690
THE CHASE MANHATTAN BANK, AS
TRUSTEE OF IMC EQUITY LOAN 1998-
3 UNDER THE POOLING AND
SERVICING AGREEMENT DATED AS
OF JUNE 1, 1998
5901 E. FOWLER AVENUE
TAMPA, FL 33617-2362
VS.
EDWARD M. VOGHT
CAROL B. VOGHT
340 BOSLER AVENUE
LEMOYNE, PA 17043
COURT OF COMMON PLEAS
CUMBERLAND COUNTY
No.: 00-232 CIVIL
PRAECIPE FOR JUDGMENT FOR FAILURE TO
ANSWER AND ASSESSMENT OF DAMAGES
TO THE PROTHONOTARY:
Kindly enter judgment in favor of the Plaintiff and against EDWARD M. VOGHT and
CAROL B. VOGHT, Defendant(s) for failure to file an Answer to Plaintiffs Complaint within
20 days from service thereof and for foreclosure and sale of the mortgaged premises, and assess
Plaintiffs damages as follows:
As Set forth in Complaint $80,627.26
Interest 3, 014 .28
11/17/00 to 3/5/01
TOTAL $83,641.54
I hereby certify that (1) the addresses of the Plaintiff and Defendant(s) are as
shown above, and (2) that notice has been given in accordance with ]Rule 237.1, copy attached.
ARDIAN, ESQUIRE
Damages are hereby assessed as indicated.
DATE: 1' 1WK.l // cZV1 6tti j K. %4ol(/
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PRO PROTHY ??//
TTdE CHASE MANHATTAN BANK, AS
TRUSTEE OF IMC HOME EQUITY LOAN
1998-3 UNDER THE POOLING AND
SERVICING AGREEMENT DATED AS OF
JUNE t, t998
Plaintiff
V.
EDWARD M. VOGHT
CAROL B. VOGHT
Defendants
TO: EDWARD M. VOGHT
CAROL B. VOGHT
DATE OF NOTICE: 2/22101
In The Court of Common Pleas
Cumberland County
No. 00-232 CV
NOTICE, RULE 237.1
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 se
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 notice to a lawyer at once. If you do not
have a lawyer or cannot afford one, go to or telephone the following office to find out
where you can get legal help.
Cumberland Bar Association
Lawyer Reference Servi
2 Liberty Aveiro
Carlisle, PA 17.
(717) 249-3166
Gregory Javardian, Esquire
44 Second Street Pike, Suite 101
Southampton, Pa 18966
(215) 942-9690
Attorney for Plaintiff
Usted se encuentra on estado de rebeldia por no haber tomado la accion requiida de su
pane en este caso. Al no tomar la accion debida dentro de Lin termino de diez (10) dias de
esta notificacion, el tribunal podra, sin necesidad de compararecer usted en torte o
escuchar prueba alguna, dictar sentencia en so contra, Listed puede perder bienes y otros
derechos importantes. Debe Ilevar esta notificacion a Lin abogado inmiediatemente si
Listed no tiene abogado, o si no time dinero sufrciente para tal servicio, vaya en persona o
llame por telpfono a la ofrcina, cuya direction se encuentra escrita abajo para averiguar
donde se puede conseguir assistencia legal.
"NOTICE PURSUANT TO FAIR DEBT COLLECTION PRACTICES ACT
THIS IS AN ATTEMPT TO COLLECT A DEBT AND ANY INFORMATION OBTAINED
WILL BE USED FOR THAT PURPOSE"
LAW OFFICES OF GREGORY JAVARDIAN
By: GREGORY JAVARDIAN, ESQUIRE
IDENTIFICATION NO. 55669
44 SECOND STREET PIKE, SUITE 101
SOUTHAMPTON, PA 18966
(215) 942-9690
THE CHASE MANHATTAN BANK, AS
TRUSTEE OF IMC EQUITY LOAN 1998-
3 UNDER THE POOLING AND
SERVICING AGREEMENT DATED AS
OF JUNE 1, 1998
vs.
EDWARD M. VOGHT
CAROL B. VOGHT
COURT OF COMMON PLEAS
CUMBERLAND COUNTY
No.: 00-232 CIVIL
VERIFICATION OF NON-MILITARY SERVICE
GREGORY JAVARDIAN, ESQUIRE, hereby verifies that he is attorney for the
Plaintiff in the above-captioned matter, and that on information and belief, he has knowledge of
the following facts, to wit:
(a) Defendant(s), EDWARD M. VOGHT and CAROL B. VOGHT, is/are 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 Act of Congress of 1940, as amended.
(b) Defendant, EDWARD M. VOGHT, is over 18 years of age, and resides at
340 BOSLER AVENUE, LEMOYNE, PA 17043.
(c) Defendant, CAROL B. VOGHT, is over 18 years of age, and resides at 340
BOSLER AVENUE, LEMOYNE, PA 17043.
(d) Plaintiff, THE CHASE MANHATTAN BANK, AS TRUSTEE OF IMC
EQUITY LOAN 1998-3 UNDER THE POOLING AND SERVICING AGREEMENT DATED
AS OF JUNE 1, 1998, is an institution conducing business under the Laws of the
Commonwealth of Pennsylvania with an address of 5901 E. FOWLER AVENUE, TAMPA, FL
33617-2362.
This statement is made subject to the penalties of 18 Pa. C.S. Section 4904
relating to unworn falsification to authorities.
G O ARDIAN, ESQUIRE
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COMMONWEALTH OF PENNSYLVANIA
COUNTY OF CUMBERLAND
THE CHASE MANHATTAN BANK, AS
TRUSTEE OF IMC HOME EQUITY
LOAN 1998-3 UNDER THE POOLING
AND SERVICING AGREEMENT
DATED AS OF JUNE 1, 1998
3815 SOUTH WEST TEMPLE
SALT LAKE CITY, UT 84115
COURT OF COMMON PLEAS
CUMBERLAND COUNTY
01
No.: AO-232 CIVIL
vs.
EDWARD M. VOGHT
CAROL B. VOGHT
340 BOSLER AVENUE
LEMOYNE, PA 17043
PRAECIPE FOR WRIT OF EXECUTION
MORTGAGE FORECLOSURE
TO THE PROTHONOTARY:
Kindly issue Writ of Execution in the above matter.
Amount Due
Interest from 3/5/01 to Date of Sale
@ $13.74 per diem
Subtotal
(Costs to be added)
$83,641.54
Z? ?--
GREGORY T/IVAkDIAN, ESQUIRE
Attorney fo laintiff
I.D. #55669
1310 Industrial Boulevard
1st Floor, Suite 101
Southampton, PA 18966
(215) 942-9690
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ALL THAT CERTAIN lot or piece of land situate with improvements thereon erected, in the
Borough of Lemoyne, Cumberland County, Pennsylvania, being known as 340 Bosler Avenue, more
particularly bounded and described in accordance with a map of property by Gerrit J. Betz
Associates, Inc., Engineers and Surveyors, Shiremanstown, PA, dated January 4, 1978, Dwg. No.
78113, as follows, to wit:
BEGINNING at a hub set on the southeast side of Bosler Avenue (an 80 feet wide right-of-way), a
corner of lands now or formerly of Lynn Leon Evinger, which beginning hub is measured along
same ninety (90) feet from the intersection of the southeast corner of 0 Street and Bosler Avenue;
thence extending from said beginning hub and measured along the southeast side of Bosler Avenue,
North 52 degrees 00 minutes East, 30.0 feet to a hub, a corner of lands now or formerly of Harvey F.
Hartman; thence extending along said lands, South 38 degrees 00 minutes East 150.0 feet to a hub
set on the northwest side of Apple Alley (15 feet wide right-of-way); thence extending along same
South 52 degrees 00 minutes West 30.0 feet to a hub, a comer of lands now or formerly of Lynn
Leon Evinger, aforesaid; thence extending along said lands North 38 degrees 00 minutes West,
150.0 feet to a hub, the first mentioned hub, and the place of beginning.
UNDER AND SUBJECT to restrictions, easements and conditions of prior record.
BEING the same premises which Ljubisa M. Stankovic and Mir ana Stankovic, his wife, by Deed
dated February 4, 1998 and recorded February 11, 1998 in the Office of the Recorder of Deeds in
and for Cumberland County in Deed Book 171, Page 1149, granted and conveyed unto Edward M.
Voght and Carol B. Voght, his wife.
PARCEL No. 12-21-0265-282.
WRIT OF EXECUTION and/or ATTACHMENT
COMMONWEALTH OF PENNSYLVANIA)
COUNTY OF CUMBERLAND)
NO 01-232 Civil
CIVIL ACTION - LAW
TO THE SHERIFF OF CUMBERLAND COUNTY:
To satisfy the debt, interest and costs due THE CHASE MANHATTAN BANK, AS TRUSTEE
OF IMC HOME EQUITY LOAN 1998-3 UNDER THE POOLING AND SERVICING
AGREEMENT DATED AS OF JUNE 1, 1998, Plaintiff (s)
From EDWARD M. VOGHT AND CAROL B. VOGHT
(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 $83,641.54
L.L. $.50
Interest FROM 3/5/01 TO DATE OF SALE @ $13.74 PER DIEM
Atty's Comm % Due Prothy $1.00
Atty Paid $125.92
Other Costs
Plaintiff Paid
Date: NOVEMBER 29, 2006
(Seal)
Curtis X. Long, Pro otary
By:
Deputy
REQUESTING PARTY:
Name GREGORY JAVARDIAN, ESQUIRE
Address: 1310 INDUSTRIAL BOULEVARD
1' FLOOR, SUITE 101
SOUTHAMPTON, PA 18966
Attorney for: PLAINTIFF
Telephone: 215-942-9690
Supreme Court ID No. 55669
I HE CHASE MANHATTAN BANK, AS
TRUSTEE OF IMC HOME EQUITY LOAN
1998-3 UNDER THE POOLING AND
SERVICING AGREEMENT DATED AS OF
JUNE 1, 1998
VS.
EDWARD M. VOGHT
CAROL B. VOGHT
COURT OF COMMON PLEAS
CUMBERLAND COUNTY
of
No.:AB-232 CIVIL
AFFIDAVIT PURSUANT TO RULE 3129.1
Plaintiff in the above action sets forth as of the date the Praecipe for the Writ of Execution
was filed the following information concerning the real property located at 340 BOSLER AVENUE,
LEMOYNE, PA 17043:
1. Name and address of Owner(s) or reputed Owner(s):
Name
Last Known Address (if address cannot be
reasonably ascertained, please indicate)
EDWARD M. VOGHT
CAROL B. VOGHT
340 BOSLER AVENUE
LEMOYNE, PA 17043
340 BOSLER AVENUE
LEMOYNE, PA 17043
2. Name and address of Defendant(s) in the judgment:
EDWARD M. VOGHT
340 BOSLER AVENUE
LEMOYNE, PA 17043
CAROL B. VOGHT
340 BOSLER AVENUE
LEMOYNE, PA 17043
3. Name and last known address of every judgment creditor whose judgment is a record lien on the
real property to be sold:
Name
Last Known Address (if address cannot be
reasonably ascertained, please indicate)
None.
4. Name and address of last recorded holder of every mortgage of record:
Name
Last Known Address (if address cannot be
reasonably ascertained, please indicate)
Plaintiff.
5. Name and address of every other person who has any record lien on the property:
Name
Last Known Address (if address cannot be
reasonably ascertained, please indicate)
None.
6. Name and address of every other person who has any record interest in the property and whose
interest may be affected by the sale.
Name
Last Known Address (if address cannot be
reasonably ascertained, please indicate)
Cumberland County Domestic Relations
Cumberland County Tax Claim Bureau
Dept. of Public Assistance
PA Department of Public Welfare
Bureau of Child Support Enforcement
13 N. Hanover Street
Carlisle, PA 17013
1 Courthouse Square
Carlisle, PA 17013-3387
33 Westminster Drive, P.O. Box 599
Carlisle, PA 17013-0599
Health and Welfare Building - Room 432
P.O. Box 2675
Harrisburg, PA 17105-2675
9. 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:
Name Last Known Address (if address cannot be
reasonably ascertained, please indicate)
Tenants/Occupants 340 BOSLER AVENUE
LEMOYNE, PA 17043
I verify that the statements made in this affidavit are true and correct to the best of my
knowledge, information and belief. I understand that false statements herein are subject to the
penalties of 18 Pa. C.S.A. 4904 relating to unsworn falsification to authorities.
J? ??
GREGORY V IAN, ESQUIRE
Attorney fo lain 'ff
November 17, 2006
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LAW OFFICES OF GREGORY JAVARDIAN
By: GREGORY JAVARDIAN, ESQUIRE
IDENTIFICATION NO. 55669
1310 INDUSTRIAL BOULEVARD
I ST FLOOR, SUITE 101
SOUTHAMPTON, PA 18966
(215) 942-9690
THE CHASE MANHATTAN BANK, AS
TRUSTEE OF IMC HOME EQUITY LOAN
1998-3 UNDER THE POOLING AND
SERVICING AGREEMENT DATED AS OF
JUNE 1, 1998
COURT OF COMMON PLEAS
CUMBERLAND COUNTY
01
No.: 98-232 CIVIL
VS.
EDWARD M. VOGHT
CAROL B. VOGHT
NOTICE OF SHERIFF'S SALE OF REAL PROPERTY
TO: EDWARD M. VOGHT
CAROL B. VOGHT
340 BOSLER AVENUE
LEMOYNE, PA 17043
Your house (real estate) at 340 BOSLER AVENUE LEMOYNE PA 17043, is scheduled to
be sold at Sheriffs Sale on MARCH 7. 2007 at 10:00 A.M., in the Cumberland County Courthouse,
1 Courthouse Square, Carlisle, PA 17013, to enforce the court judgment of $83,641.54, obtained by
THE CHASE MANHATTAN BANK, AS TRUSTEE OF IMC HOME EQUITY LOAN 1998-3
UNDER THE POOLING AND SERVICING AGREEMENT DATED AS OF JUNE 111998,
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 the mortgagee the back payments, late charges,
costs and reasonable attorney's fees due. To find out how much you must pay, you may call: f215)
942-9690.
2. You may be able to stop the sale by filing a petition asking the Court to strike or open the
judgment, if the judgment was improperly entered. You may also ask the Court to postpone the sale
for good cause.
3. You may also be able to stop the sale through other legal proceedings.
You may need an attorney to assert your rights. The sooner you contact one, the more chance
you will have of stopping the sale. (See notice 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 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 by calling (215) 942-9690.
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 Gregory Javardian, Esquire at (215) 942-9690.
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 the 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. 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.
7. You may also have other rights and defenses, or ways of getting your home back, if you
act immediately after the sale.
YOU SHOULD TAKE THIS PAPER TO YOUR LAWYER AT ONCE. IF YOU DO NOT
HAVE A LAWYER OR CANNOT AFFORD ONE, GO TO OR TELEPHONE THE OFFICE
LISTED BELOW TO FIND OUT WHERE YOU CAN GET LEGAL HELP.
CUMBERLAND COUNTY BAR ASSOCIATION
32 S. BEDFORD STREET
CARLISLE, PA 17013
TELEPHONE: (717) 249-3166
(800) 990-9108
ALL THAT CERTAIN lot or piece of land situate with improvements thereon erected, in the
Borough of Lemoyne, Cumberland County, Pennsylvania, being known as 340 Bosler Avenue, more
particularly bounded and described in accordance with a map of property by Gerrit J. Betz
Associates, Inc., Engineers and Surveyors, Shiremanstown, PA, dated January 4, 1978, Dwg. No.
78113, as follows, to wit:
BEGINNING at a hub set on the southeast side of Bosler Avenue (an 80 feet wide right-of-way), a
corner of lands now or formerly of Lynn Leon Evinger, which beginning hub is measured along
same ninety (90) feet from the intersection of the southeast corner of 0 Street and Bosler Avenue;
thence extending from said beginning hub and measured along the southeast side of Bosler Avenue,
North 52 degrees 00 minutes East, 30.0 feet to a hub, a corner of lands now or formerly of Harvey F.
Hartman; thence extending along said lands, South 38 degrees 00 minutes East 150.0 feet to a hub
set on the northwest side of Apple Alley (15 feet wide right-of-way); thence extending along same
South 52 degrees 00 minutes West 30.0 feet to a hub, a corner of lands now or formerly of Lynn
Leon Evinger, aforesaid; thence extending along said lands North 38 degrees 00 minutes West,
150.0 feet to a hub, the first mentioned hub, and the place of beginning.
UNDER AND SUBJECT to restrictions, easements and conditions of prior record.
BEING the same premises which Ljubisa M. Stankovic and Mir ana Stankovic, his wife, by Deed
dated February 4, 1998 and recorded February 11, 1998 in the Office of the Recorder of Deeds in
and for Cumberland County in Deed Book 171, Page 1149, granted and conveyed unto Edward M.
Voght and Carol B. Voght, his wife.
PARCEL No. 12-21-0265-282.
r
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1..,1W OFFICES OF GREGORY JAVARDIAN
By: GREGORY JAVARDIAN, ESQUIRE
IDENTIFICATION NO. 55669
1310 INDUSTRIAL BOULEVARD
1ST FLOOR, SUITE 101
SOUTHAMPTON, PA 18966
(215) 942-9690
THE CHASE MANHATTAN BANK, AS
TRUSTEE OF IMC HOME EQUITY
LOAN 1998-3 UNDER THE POOLING
AND SERVICING AGREEMENT
DATED AS OF JUNE 1, 1998
COURT OF COMMON PLEAS
CUMBERLAND COUNTY
No.: 01-232 CIVIL
vs.
EDWARD M. VOGHT
CAROL B. VOGHT
AFFIDAVIT OF SERVICE PURSUANT TO RULE 3129.1
I hereby certify that I have sent copies of the Notice of Sheriff Sale to the Defendants'
certified and regular United States mail and all lien holders or judgment creditors of record as
required by Pa.R.C.P. by first class United States mail, postage prepaid, on the date set forth below.
(See attached Exhibit "A").
Cumberland County Domestic Relations
13 N. Hanover Street
Carlisle, PA 17013
Cumberland County Tax Claim Bureau
1 Courthouse Square
Carlisle, PA 17013-3387
Dept. of Public Assistance
33 Westminster Drive, P.O. Box 599
Carlisle, PA 17013-0599
Tenants/Occupants
340 BOSLER AVENUE
LEMOYNE, PA 17043
EDWARD M. VOGHT
340 BOSLER AVENUE
LEMOYNE, PA 17043
CAROL B. VOGHT
340 BOSLER AVENUE
LEMOYNE, PA 17043
PA Department of Public Welfare
Bureau of Child Support Enforcement
Health and Welfare Building - Room 432
P.O. Box 2675
Harrisburg, PA 17105-2675
/?--
GREGORY,4/AVAADIAN, ESQUIRE
5-1 Dated: ! 44
Attorney for Plai iff
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November 17, 2006
NOTICE OF SHERIFF'S SALE
OF REAL PROPERTY
TO: ALL PARTIES IN INTEREST AND CLAIMANTS
OWNER(S): EDWARD M. VOGHT and CAROL B. VOGHT
PLAINTIFF/SELLER: THE CHASE MANHATTAN BANK, AS TRUSTEE OF IMC
HOME EQUITY LOAN 1998-3 UNDER THE POOLING
AND SERVICING AGREEMENT DATED AS OF lI ENE 1,
1998
DEFENDANT(S): EDWARD M. VOGHT and CAROL B. VOGHT
PROPERTY: 340 BOSLER AVENUE
LEMOYNE, PA 17043
CUMBERLAND C.C.P. NO. 00-232 CIVIL
The above captioned property is scheduled to be sold at Sheriffs Sale on MARCIJ 7 _:2007 at
10:00 A.M., in the Cumberland County Courthouse, 1 Courthouse Square, Carlisle, PA l 013. You
may hold a judgment on the property, which may be extinguished by the sale. You may wish to
attend the Sheriff's Sale to protect your interest.
A schedule of distribution will be filed by the Sheriff on a date specified by the Sheriff not
later than 30 days after sale. Distribution will be made in accordance with the schedule unless
exceptions are filed thereto within 10 days after the filing of the schedule.
' Sincerely,
Gregory av an, Esquire
Law Offices of Gregory Javardian
1310 Industrial Boulevard
1 st Floor, Suite 101
Southampton, PA 18966
(215) 942-9690
r,? ?` 7
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The Chase Manhattan Bank, as Trustee In the Court of Common Pleas of
Of IMC Home Equity Loan 1998-3 Under Cumberland County, Pennsylvania
The Pooling and Servicing Agreement Writ No. 2006-232 Civil Term
Dated as of June 1, 1998
VS
Edward M. Voght and Carol B. Voght
Cpl. Richard Smith, Deputy Sheriff, who being duly sworn according to law, states that on
December 14, 2006 at 1847 hours, he served a true copy of the within Real Estate Writ, Notice and
Description, in the above entitled action, upon the within named defendants, to wit: Edward M.
Voght and Carol B. Voght, by making known unto Carol Voght, personally and wife of Edward M.
Voght, at 340 Bosler Ave., Lemoyne, Cumberland County, Pennsylvania its contents and at the
same time handing to her personally the said true and correct copy of the same.
Gerald Worthington, Deputy Sheriff, who being duly sworn according to law, states that on
January 19, 2007 at 1332 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 Edward M. Voght and Carol B.
Voght located at 340 Bosler Ave., Lemoyne, Cumberland County, Pennsylvania according to law.
R. Thomas Kline, Sheriff, who being duly sworn according to law, states he served the
above Real Estate Writ, Notice, Poster and Description in the following manner: The Sheriff
mailed a notice of the pendency of the action to the within named defendants, to wit: Edward M.
Voght and Carol B. Voght, by regular mail to their last known address of 340 Bosler Ave.,
Lemoyne, PA 17043. These letters were mailed under the date of January 16, 2007 and never
returned to the Sheriffs Office.
R. Thomas Kline, Sheriff, who being duly sworn according to law, states this writ is
returned STAYED per letter of request from Attorney Gregory Javardian.
Sheriffs Costs:
Docketing 30.00
Poundage 19.53
Advertising 15.00
Posting Bills 15.00
Law Library .50
Prothonotary 1.00
Mileage 28.46
Certified Mail 4.64
Levy 15.00
Surcharge 30.00
Postpone Sale 20.00
Law Journal 401.00
Patriot News 399.59
Share of Bills 16.83
$ 996.25 V G`a Jd 7.
So s rs:
R. Thomas Kline, Sheriff
B J/v- f
Real Estate ergeant
V I ?'Df 603I
dv-
/9y6 61
t
THE CHASE MANHATTAN BANK, AS
TRUSTEE OF IMC HOME EQUITY LOAN
1998-3 UNDER THE POOLING AND
SERVICING AGREEMENT DATED AS OF
JUNE 1, 1998
COURT OF COMMON PLEAS
CUMBERLAND COUNTY
of
No.: W-232 CIVIL
vs.
EDWARD M. VOGHT
CAROL B. VOGHT
AFFIDAVIT PURSUANT TO RULE 3129.1
Plaintiff in the above action sets forth as of the date the Praecipe for the Writ of Execution
was filed the following information concerning the real property located at 340 BOSLER AVENUE.
LEMOYNE, PA 17043:
1. Name and address of Owner(s) or reputed Owner(s):
Name
Last Known Address (if address cannot be
reasonably ascertained, please indicate)
EDWARD M. VOGHT
CAROL B. VOGHT
340 BOSLER AVENUE
LEMOYNE, PA 17043
340 BOSLER AVENUE
LEMOYNE, PA 17043
2. Name and address of Defendant(s) in the judgment:
EDWARD M. VOGHT
340 BOSLER AVENUE
LEMOYNE, PA 17043
CAROL B. VOGHT
340 BOSLER AVENUE
LEMOYNE, PA 17043
3. Name and last known address of every judgment creditor whose judgment is a record lien on the
real property to be sold:
Name
Last Known Address (if address cannot be
reasonably ascertained, please indicate)
None.
4. Name and address of last recorded holder of every mortgage of record:
Name
Last Known Address (if address cannot be
reasonably ascertained, please indicate)
Plaintiff.
5. Name and address of every other person who has any record lien on the property:
Name
Last Known Address (if address cannot be
reasonably ascertained, please indicate)
None.
6. Name and address of every other person who has any record interest in the property and whose
interest may be affected by the sale.
Name
Last Known Address (if address cannot be
reasonably ascertained, please indicate)
Cumberland County Domestic Relations
Cumberland County Tax Claim Bureau
Dept. of Public Assistance
PA Department of Public Welfare
Bureau of Child Support Enforcement
13 N. Hanover Street
Carlisle, PA 17013
1 Courthouse Square
Carlisle, PA 17013-3387
33 Westminster Drive, P.O. Box 599
Carlisle, PA 17013-0599
Health and Welfare Building - Room 432
P.O. Box 2675
Harrisburg, PA 17105-2675
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:
Name Last Known Address (if address cannot be
reasonably ascertained, please indicate)
Tenants/Occupants 340 BOSLER AVENUE
LEMOYNE, PA 17043
I verify that the statements made in this affidavit are true and correct to the best of my
knowledge, information and belief. I understand that false statements herein are subject to the
penalties of 18 Pa. C.S.A. 4904 relating to unsworn falsification to authorities.
GREGORY V IAN, ESQUIRE
Attorney fo lain ff
November 17, 2006
LAW OFFICES OF GREGORY JAVARDIAN
By: GREGORY JAVARDIAN, ESQUIRE
IDENTIFICATION NO. 55669
1310 INDUSTRIAL BOULEVARD
I ST FLOOR, SUITE 10 1
SOUTHAMPTON, PA 18966
(215) 942-9690
THE CHASE MANHATTAN BANK, AS
TRUSTEE OF IMC HOME EQUITY LOAN
1998-3 UNDER THE POOLING AND
SERVICING AGREEMENT DATED AS OF
JUNE 1, 1998
COURT OF COMMON PLEAS
CUMBERLAND COUNTY
61
No.: A9-232 CIVIL
VS.
EDWARD M. VOGHT
CAROL B. VOGHT
NOTICE OF SHERIFF'S SALE OF REAL PROPERTY
TO: EDWARD M. VOGHT
CAROL B. VOGHT
340 BOSLER AVENUE
LEMOYNE, PA 17043
Your house (real estate) at 340 BOSLER AVENUE, LEMOYNE, PA 17043, is scheduled to
be sold at Sheriffs Sale on MARCH 7, 2007 at 10:00 A.M., in the Cumberland County Courthouse,
1 Courthouse Square, Carlisle, PA 17013, to enforce the court judgment of $83,641.54, obtained by
THE CHASE MANHATTAN BANK, AS TRUSTEE OF IMC HOME EQUITY LOAN 1998-3
UNDER THE POOLING AND SERVICING AGREEMENT DATED AS OF JUNE 111998,
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 the mortgagee the back payments, late charges,
costs and reasonable attorney's fees due. To find out how much you must pay, you may call: 215
942-9690.
2. You may be able to stop the sale by filing a petition asking the Court to strike or open the
judgment, if the judgment was improperly entered. You may also ask the Court to postpone the sale
for good cause.
3. You may also be able to stop the sale through other legal proceedings.
r
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 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 by calling (215) 942-9690.
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 Gregory Javardian, Esquire at (215) 942-9690.
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 the 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. 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.
7. You may also have other rights and defenses, or ways of getting your home back, if you
act immediately after the sale.
YOU SHOULD TAKE THIS PAPER TO YOUR LAWYER AT ONCE. IF YOU DO NOT
HAVE A LAWYER OR CANNOT AFFORD ONE, GO TO OR TELEPHONE THE OFFICE
LISTED BELOW TO FIND OUT WHERE YOU CAN GET LEGAL HELP.
CUMBERLAND COUNTY BAR ASSOCIATION
32 S. BEDFORD STREET
CARLISLE, PA 17013
TELEPHONE: (717) 249-3166
(800) 990-9108
ALL THAT CERTAIN lot or piece of land situate with improvements thereon erected, in the
Borough of Lemoyne, Cumberland County, Pennsylvania, being known as 340 Bosler Avenue, more
particularly bounded and described in accordance with a map of property by Gerrit J. Betz
Associates, Inc., Engineers and Surveyors, Shiremanstown, PA, dated January 4, 1978, Dwg. No.
78113, as follows, to wit:
BEGINNING at a hub set on the southeast side of Bosler Avenue (an 80 feet wide right-of-way), a
corner of lands now or formerly of Lynn Leon Evinger, which beginning hub is measured along
same ninety (90) feet from the intersection of the southeast corner of 0 Street and Bosler Avenue;
thence extending from said beginning hub and measured along the southeast side of Bosler Avenue,
North 52 degrees 00 minutes East, 30.0 feet to a hub, a corner of lands now or formerly of Harvey F.
Hartman; thence extending along said lands, South 38 degrees 00 minutes East 150.0 feet to a hub
set on the northwest side of Apple Alley (15 feet wide right-of-way); thence extending along same
South 52 degrees 00 minutes West 30.0 feet to a hub, a corner of lands now or formerly of Lynn
Leon Evinger, aforesaid; thence extending along said lands North 38 degrees 00 minutes West,
150.0 feet to a hub, the first mentioned hub, and the place of beginning.
UNDER AND SUBJECT to restrictions, easements and conditions of prior record.
BEING the same premises which Ljubisa M. Stankovic and Mirjana Stankovic, his wife, by Deed
dated February 4, 1998 and recorded February 11, 1998 in the Office of the Recorder of Deeds in
and for Cumberland County in Deed Book 171, Page 1149, granted and conveyed unto Edward M.
Voght and Carol B. Voght, his wife.
PARCEL No. 12-21-0265-282.
WRIT OF EXECUTION and/or ATTACHMENT
COMMONWEALTH OF PENNSYLVANIA)
COUNTY OF CUMBERLAND)
NO 01-232 Civil
CIVIL ACTION - LAW
TO THE SHERIFF OF CUMBERLAND COUNTY:
To satisfy the debt, interest and costs due THE CHASE MANHATTAN BANK, AS TRUSTEE
OF IMC HOME EQUITY LOAN 1998-3 UNDER THE POOLING AND SERVICING
AGREEMENT DATED AS OF JUNE 1, 1998, Plaintiff (s)
From EDWARD M. VOGHT AND CAROL B. VOGHT
(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 $83,641.54
L.L. $.50
Interest FROM 3/5/01 TO DATE OF SALE @ $13.74 PER DIEM
Atty's Comm % Due Prothy $1.00
Atty Paid $125.92
Plaintiff Paid
Other Costs
Date: NOVEMBER 29, 2006
(Seal)
REQUESTING PARTY:
Name GREGORY JAVARDIAN, ESQUIRE
Address: 1310 INDUSTRIAL BOULEVARD
1" FLOOR, SUITE 101
SOUTHAMPTON, PA 18966
Attorney for: PLAINTIFF
U
Curtis WLong, Pro ary
By:
Deputy
Telephone: 215-942-9690
Supreme Court ID No. 55669
Real Estate Sale # 71
On December 4, 2006 the Sheriff levied upon the
defendant's interest in the real property situated in
Lemoyne Borough, Cumberland County, PA
Known and numbered as 340 Bosler Ave.,
CVQ
Lemoyne, more fully described on Exhibit "A" r ova
filed with this writ and by this reference incorporated herein.r
Date: December 4, 2006 By: r?
v ?
Real Es to Sergeant
che Patriot-Xrws
Now you know
P. O. BOX 2265
HARRISBURG, PA 17105
(717) 255-8237
BILL TO: Cumberland County Sheriffs Office
Cumberland County Court House
Carlisle, PA 17013
ACCT. #
2260
DUPLICATE BILL
01/24/07
01/31/07
02/07/07
Net Cost
Of Ad
Sheriff Sale 71 9.46 $14.01 $ 132.53
Sheriff Sale 71 9.46 $14.01 $ 132.53
Sheriff Sale 71 9.46 $14.01 $ 132.53
Notary Fee I I I I I 1 I $2.00
TOTAL DUE FOR THIS SALE:
$ 399.59
JLC
.
THE PATRIOT NEWS
THE SUNDAY PATRIOT NEWS
Proof of Publication
Under Act No. 587, Approved May 16, 1929
Commonwealth of Pennsylvania, County of Dauphin) ss
Joseph A. Dennison, being duly sworn according to law, deposes and says:
That he is the Assistant Controller of The Patriot News Co., a corporation organized and existing under the
laws of the Commonwealth of Pennsylvania, with its principal office and place of business at 812 to 818 Market
Street, in the City of Harrisburg, County of Dauphin, State of Pennsylvania, owner and publisher of The Patriot-
News and The Sunday Patriot-News newspapers of general circulation, printed and published at 812 to 818 Market
Street, in the City, County and State aforesaid; that The Patriot-News and The Sunday Patriot-News were
established March 4th, 1854, and September 18th, 1949, respectively, and all have been continuously published ever
since;
That the printed notice or publication which is securely attached hereto is exactly as printed and published
in their regular daily and/or Sunday/ Metro editions which appeared in the 24th and 31st day(s) of January and
the 7th day(s) of February 2007. That neither he nor said Company is interested in the subject matter of said
printed notice or advertising, and that all of the allegations of this statement as to the time, place and character of
publication are true; and
That he has personal knowledge of the facts aforesaid and is duly authorized and empowered to verify this
statement on behalf of The Patriot-News Co. aforesaid by virtue and pursuant to a resolution unanimously passed
and adopted severally by the stockholders and board of directors of the said Company and subsequently duly
recorded in the office for the Recording of Deeds in and for said County of Dauphin in Miscellaneous Book "M",
Volume 14, Page 317.
PUBLICATION
COPY
SALE#71
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Sworn to and s ibed b meCOMMO WEALTH OF this 26th day rua
Notadal Seal
Terry L. Russell, Notary P fic
City Of Harris rg, Daup ' unty
y Commiss a Expirc J? n 6, 201 00 ri
P.
NOTAXKY PUBLIC
CUMBERLAND COUNTY SHERIFF'S OFFICE
CUMBERLAND COUNTY COURTHOUSE
CARLISLE, PA. 17013
PROOF OF PUBLICATION OF NOTICE
IN CUMBERLAND LAW JOURNAL
(Under Act No. 587, approved May 16, 1929), P. L.1784
STATE 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 26, February 2 and February 9, 2007
Affiant further deposes that he is authorized to verify this statement by the Cumberland
Law Journal, a legal periodical of general circulation, and that he is not interested in the subject
matter of the aforesaid notice or advertisement, and that all allegations in the foregoing
statements as to time, place and character of publication are true.
REAL ESTATE DALE NO. 71
Writ No. 2001-232 Civil
The Chase Manhattan Bank, as
Trustee of IMC Home Equity Loan
1998-3 Under the Pooling and
servicing Agreement Dated
as of June 1, 1998
VS.
Edward M. Voght and
Carol B. Voght
Atty.: Gregory Javardian
ALL THAT CERTAIN lot or piece
of land situate with improvements
thereon erected, in the Borough of
Lemoyne, Cumberland County,
Pennsylvania, being known as 340
Boller Avenue. more particularly
J
(-'L#Marie Coyne, E for
SWORN TO AND SUBSCRIBED before me this
9 day of February, 2007
{` f) -j r T SEAL -
Lo,,,S r J` Crn, NVary Public
0 ; i .. v,rc, u t:la ri ,r . COunlY
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