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Home My WebLink About04-2740 GOLDBECK McCAFFERTY & McKEEVER By: JOSEPH A. GOLDBECK, JR. ATTORNEY I.D. #16132 SUITE 5000 - MELLON INDEPENDENCE CENTER. 701 MARKET STREET PHILADELPHIA, PA 19106 (215) 627-1322 ATTORNEY FOR PLAINTIFF IN THE COURT OF COMMON PLEAS M&T MORTGAGE CORPORATION PO Box 840 Buffalo, NY 14240-0840 OF Cumberland COUNTY Plaintiff CIVIL ACTION - LAW vs. CASSIUS J. MULLEN DEBORAH L. MULLEN Mortgagor(s) and Real Owner(s) ACTION OF MORTGAGE FORECLOSURE 241 Old Stone House Road Carlisle, PAl 70 13 Term No.C4 _,),,'1110 e;l.JiL~ Defendant{s} CIVIL ACTION: MORTGAGE FOREClO@UFtE THIS FIRM IS A DEBT COLLECTOR AND WE ARE ATTEMPTINGTO COLLECT A DEBT OWED TO OUR CLIENT. ANY INFORMATION OBTAINED FROM YOU WILL BE USED FOR THE PURPOSE OF COLLECTING THE DEBT. NOTICE You have been sued in court. If you wish to defend against the claims set forth in the following pages, you must take action within twenty (20) days after the Complaint and notice are served, by e11lering a written appearance personally or by attorney and filing in writing with the court your defenses or objections to the claims set forth against you. You are warned that if YOll fu.il to do so the case may proceed without you and ajudg1nent may be entered against you by the Court without further notice for any money claim in the Complaint offor any other claim or relief requested by the Plaintiff You may lose money or property or other rights important to you. YOU SHOULD TAKE THIS PAPER TO YOUR LA WYER AT ONCE. IF YOU DO NOT HAVE A LAWYER OR CANNOT AFFORD ONE, GO TO OR TELEPHONE THE OFFICE SET fORTH BELOW. THIS OFFICE CAN PROVIDE YOU WITH INFORMATION ABOUT HIRING A LAWYER. IFYOU CANNOT AFFORD TO HIRE A LAWYER, THIS OFFICE MAY BE ABLE TO PROVIDE YOU WITH INFORMATION ABOUT AGENCIES THAT MAY OFFER LEGAL SERVICES TO ELIGIBLE PERSONS AT A REDUCED FEE OR NO FEE. LEGAL SERVICES INC 8 Irvine Row Carlisle,PA ]7013 7]7~243~9400 CUMBERLAND COUNTY BAR ASSaCIA TlON 2 Liberty Avenue Carlisle, PA 17013 il.U.Q LE HAN DEMANDADO A liSTED EN LA CORTE. SI DESEA DEFENDERSE CONTRA LAS QUEJAS PERESENTADAS, ES ABSOLUTAMENTE NECESSARIa QUE liSTED RESPONDA DENTRO DE 20 DIAS DESPUES DE SER SERVIDO CON ESTA DEMANDA Y A vIsa. PARA DEFENDERSE ES NECESSARIO QUE USTED, 0 SU ABOGADO, REGlSTRE CON LA CORTE EN FORMA ESCRIT A, EL PUNTO DE VISTA DE USTED Y CUALQlIIER OBJECCION CONTRA LAS QUEJAS EN EST A DEMANDA. RECUERDE; 51 liSTED NO REPONDE A EST A DEMANDA, SE PlIEDE PROSEGUlR CON EL PROCESO SIN SU P ARTICIPACION. ENTONCES, LA COUTE PUEDE, SIN NOTIFJCARIO, DECIDIR A FAVOR DEL DEMANDANTE Y REQUERlRA QUE USTED ClIMPLA CON TODAS LAS PROVISIONES DE ESTA DEMANDA. paR RAZON DE ESA DECISION, ES POSSIBLE QUE USTED PUEDA PERDER DINERO, PROPIEDAD U OTROS DERECHOS IMPORTANTES. USTED DEBE LLEV AR ESTE P APEL A SU ABOGADO ENSEGUIDA. SI USTED NO TlENE UN ABOGADO, VA Y A 0 LU\ME POR TELCFONO LA OFICINA FIJADA AQui ABAJO. ESTA OFIClNA PUEDE PROVEERC CON INFORMACION DE COMO CONSEUIR UN ABOGADO. SI USTED NO PUEDE PAGARLE A UN ABOGADQ, <;5TA OFJCINA PUEDE PROVEERE INFORMACION ACERCA AGENCIAS QUE PUEDAN OFRECER SERVICIOS LEGAL A PERSONAS ELIGIBLE AQ UN HONORARIO REDUCIDO 0 GRATIS. LEGAL SERVICES INC 8 Irvine Row Carlisle, PA ]7013 717-243-9400 CUMBERLAND COUNTY BAR ASSOCIATION 2 Liberty Avenue Carlis]e,PA 17013 COMPLAINT IN MORTGAGE FORECLOSURE 1. Plaintiff is M&T MORTGAGE CORPORATION, PO Box 840, Buffalo, NY 14240-0840. 2. The name(s) and addressees) of the Defendant(s) is/are CASSIUS J. MULLEN, 241 Old Stone House Road, Carlisle, PA 17013 and DEBORAH L. MULLEN, 241 Old Stone House Road, Carlisle, PA 17013, who is/are the mortgagor(s) and real owner(s) ofthe mortgaged premises hereinafter described. 3. On May 10, 2001 mortgagor(s) made, executed and delivered a mortgage upon the premises hereinafter described to M&T MORTGAGE CORPORATION, which mortgage is recorded in the Office ofthe Recorder of Deeds of Cumberland County as Book 1705 Page 233. The mortgage has not been assigned unless said assignment to the Plaintiff is hereafter mentioned. These documents are matters of public record and are incorporated herein by reference in accordance with Pennsylvania Rule of Civil Procedure 1019(g). 4. The premises subject to said mortgage is described as attached. 5. The mortgage is in default because monthly payment of principal and interest upon said mortgage due February 05, 2004, and each month thereafter are due and unpaid, and by the terms of said mortgage, upon default in such payments for a period of one month, the entire principal balance and all interest due thereon are collectible forthwith. 6. The following amounts are due on the mortgage: Principal Balance Interest from 01/05/2004 through 06/30/2004 at 6.5000% Per Diem interest rate at $42.12 Attorney's Fee at 5.0% of Principal Balance Late Charges from 02/05/2004 to 06/30/2004 Monthly late charge amount at $95.82 Costs of suit and Title Search $236,491.95 $7,495.57 $11,824.60 $479.12 Escrow Monthly Escrow amount $217.69 $900.00 $257,191.24 +$499.03 $257,690.27 7. The Attorney's Fees set forth above are in conformity with the Mortgage documents and Pennsylvania law, and, will be collected in the event of a third party purchaser at Sheriffs Sale. If the Mortgage is reinstated prior to the Sale reasonable Attorney's Fees will be charged based on work actually performed. 8. Notice ofIntention to Foreclose and a Notice of Homeowners' Emergency Mortgage Assistance has been sent to Defendant(s) by Certified and regular mail, as required by Act 160 of 1998 of the Commonwealth of Pennsylvania, on the date(s) set forth in the true and correct copy of such notice(s) attached hereto as Exhibit "A". The Defendant(s) haslhave not had the required face-to-face meeting within the required time and Plaintiff has no knowledge of any such meeting being requested by the Defendant(s) through the Plaintiff, the Pennsylvania Housing Finance Agency, or any appropriate Consumer Credit Counseling Agency. WHEREFORE, Plaintiff demands an in rem judgment in mortgage foreclosure in the sum of $257,690.27, together with interest at the rate of$42.12, per day and other expenses incurred by the Plaintiff which are properly chargeable in accordance with the terms of the mortgage, and for the foreclosure and sale of the mortg~ged premises. By: ~M~ GO B K McCAFFERTY & McKEEVER By' JOSEPH A. GOLDBECK, JR., ESQUIRE A ITORNEY FOR PLAINTIFF VERIFICATION I, Diana M. Robinson, Assistant Vice President, as the representative of the Plaintiff corporation within named do hereby verify that I am authorized to and do make this verification on behalf of the Plaintiff corporation and the facts set forth in the foregoing Complaint are true and correct to the best of my knowledge, information and belief. I understand that false statements therein are made subject to the penalties of 18 Pa. C.S. 4904 relating to unsworn falsification to authorities. Date: h ~(V -1J 1 lvU Diana M. 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In Cumberland County PA ~.,..~~~ ~ Recorder ofPeeds Buud705rACf .250 ::l.EtNG THE SAME PREMISES WHICH Robert R. Niemi and Donna Niemi, husband and wtfe byOeeddst;-d ~overnbef 9, 19ge. 1f1d recorded Ncvember14, 1995 in theOffjceoftheRecorderorOeedslnandforCumberlandC~tYI.F: A. In Book; 31. page <l.3, granted and conveypd, unt~ CassiU8 J, Munen and Debomh Lee MulfeJ'l, husband and \Vita M&T Mortgage Corp. k'.O. Box 1283 BLlffalo,NY 14240.12HX I1Mel1'~~ US/U4/2004 Certified No.: 7182638930r)()U37'9S836 Dchorah L Mullen 241 Old Sronc House Rd Carlislc, fA 17013 HOMEOWNERS NIUU:(S}: DItbor'ah L Mull." Cas.,y. ~ Mullen "IlOItERTY ADDRESS: 24' Old Ston. HQ"'U1 ReI c.r! '81.. PA 1''''3 l.OAN ACCT NO: 0001012". CURRlNT LENOElt/S!RVJCEIIl: Mt.T Mortgage CorporlltiCl" Ex HIS HOMEOW~ER's f.J\.IERGENC\' MORTGAGR ASSISTANCE PROGRAM 1:.... A YOU MA V-BE ruGIBLF FOR FINANC'AL ^S~IST ANCE WHICH CAN SA Vi:: YOU" nOM);: FROM !, ~ FOIUCLOSUREAM>HF.LPYOVMAKEFUTUREMORrGAGEPAYMENTS ;; IF YOU COMPLY WIDl TRE PROVISIONS OF THE HO)'JEOWNER'S F..MERGI:NCt" MORTGAGE As..l;)ISTANCI! ACT OF 1m (TH!!: "Acr'), YOU !\fAY DE ELlGIBLE FOR EI\lERGENC\' MORTGAG)!: ASSIST ANCK: IF YOtJR DEFAIIL T HAS BEEN CAUSED BY CIRCJ)MSTA:'iCF.S BEYONU YO{~Jl C()NTRO~ IF VOll HAVE .4. RltASONABLE PROSPECf OF BEING ABLE TO PI' Y YOUR MORTGAGE PAYMEN'.-S. AND IF VOl: ~tEI:T OTUER tUG[BILITY REQumEMENTS F.~TABUSI.IED BY THE PF.NHSYLVANIA IJOlTSISG FlNANC!; AGENCY, TEMYORARY STAY or rOREC.'LOS1'Rf -UndCf the Act, you an:; entitled to a tem.poral') stllyofforcclllsurc on your mortgag~ for thirty (30) daY' from the date ofthi~ Nolice, nurlng that timc you mu~d anmgc and a~end a "fal.:~.to-(ac"m(:cting with one oftlu: CO(lSUIl1~r cr~dit counscli'l{tagencicl\ listed at the end oft lis 'KoIicc. J:!1!:i MF.F.1"fNG MUST QCCUR \VlTHTN THE ,'IriIEXT (JI)) DAYS. IF YOU DO NOT APT-L Y FOR EM ERGENCY MORT{lA<lt:: ASSISTANCF... YOU MUST BRJNG YOUR MORTGAGe UP TO T>AT~. TH1:,PART OF THT~ NOTIcn CALLt':U"HOW TO CURE YOUR MORTGAGE DEFAULT'". t;XI'LAINS HOW T') ~RIN(i YOt:!f{ MORTGA(i1i UP TO DA TFL (;O;\lSUMER CRKOIT COUN~F.LJN(; AG.I!:NCIES - "yeLl l11eet with one of th~ COI'lSUlllL". credit coumcling agcncy listed IIllhc end l.)fthis notice, the lcndtr may NOT take action [lgrlinsl you fin thirty (3{ ,I duys 1I0r:r the date Uflhis meeting..T1le TUlmc::~ addre~eli /ll1d 1elcohOM Ollm"tletlj ~.f <k;si,..,nlllcd conslttner t,.Tt!dit erfln.~linQ" aaC:neles tor ~ cmmtv in wh\cb \11~ l'H'om:rty ilL I~tcd are .set forth alUle end Clflhill Notice, !I is only nccc!:>ary to scbedu1e one fu,C'-lo~(ace mecting. Advi!>l: )'Qur lendl.:r imrncdilltcly ofyolrr intenrion!'>, , BOO 724 1EiJ3 Ct;Jrre:.pondeooe . P.O. Box 840, aulfa~, NY" 14240-0840 P.}o'/MtItS'. P.O. BOil 1364. Blllfalo, NY ,424U-13()4 Uorl98g6 aooount /flfr;rmaiicn, just III click aw..y, WNW.It1&r1d1mOl1\;lage,C(Im -~-~_. ..,- ._... "_.'._""""-'-<.~_._._",", M&T Mortgage CCI[J), P.O, Box )288 Buffalo, NY 14240.128g II MarMortgllge COI'pu..atIco 1'......,,11101II_ O:S/04n004 Certified No.; 71 fl2(j3S93Qo:003795R2lJ C1..~!liu!> J Mullen 241 Old Stone H"Uf;l~ Rd CarlWe, PA 17013 KlMEO'i/NERS NANE(S): ellSwlUII oJ ....llen DebOr~ L MU1I.n PROPERTY ADDRESS: ~41 Old Stone HvUd ReI C.~lt&I.. 'A 17013 LDAN ACCT NO; 0008082119 QJRREIfT' LENDER/$EItVIC9:: _1 Mortgage COrporation HOMEOWNER'S If.MERGENCV MORTGAGE ASSISTANCE PROGRAM YOl:Mi\V DR EUGIBLE FOR FINANCIAL ^~SlSTAN("'~ \\lITCH CAN SAVR VOUR.HO~flj~ FROM FORF.CLOS1:R.... A...'lD HELP YOU MA KF. FUTURE MORTGAGI!: 'A YMENTS If YOU COMPL V WlTU 'fHE PROVIStONS 0-' THE HOMi:OWl'JRR'S EM[,RGfiNC1i' MORTCAGE ASSISTANCE ACT OF 1983 (TRF.. "ACT"\ VOU MAY BE .t:LIGIBTJF- FOK EMERGE/'ITY MORTGAGE ASSISTANCf.:: IF YOUR DE~A1JLT "AS sltEN C,-\VSED BY CIRCUMSTANC.I!:S 8P.YO~D YOUlI CONTROL, 11" YOU IIA VE A REASONABLE PROSPECT OF BEIi'olG ABLE TO PI,y YOUR MORTGAGE l"AYMENTS, A~O I"~ YOU )fEET OTHER ELtGmn.ITY REQUIRF.MESTS ESTABUSHED BY Till!. 1~El'"NSVLV ANIA nOl/SING FINANCE AGE:'\JCV. TE;rtPOR.<\.RY Sf A Y OF rOR.RCLOSL'"RE _ Untlt:r Ull': Act, y.ou un: entitled to a temporary slay offoredo~ure on your mortgage for thirty (30) da)"'l froID lite dutl\! uf Ihis Nl;l'tice_ Owing that tinte you m~t at:- m$C and attend II , 'facC-lo..fac"mccling with ~ llfthe c{)n~umcr credil cool'IScling agencies listed (it the end oft j~ Notice. .!!:!ll! j\'IEJfl'Ir\G TtfUST OCCUR WITHIN THE N~XT (31l1 DA vs. IF yoU 00 'KOT APPL Y F;)R EMF:R(j~NCY MORTOAUb ASSISTANCE. YOU MUST--.BRTNCi YOUR MORTnAGE UP TO PATE. TffF...PART OFTm1', NOTICE CALLED"HOW TO CURl! YOUR MORTGAGE DEFAt!l T". EXPLAlNS HOW Tn BRING YOUR MORTGAGE uP TO DATE. CONSUMEI{ CRF,mT COUNSELiNG AGF.NC"lES -- If)'ou meel -with om of me c(lnsumc. cmdit cou"scling agency list"" at (hc cud of this notice, tn... I~\.der may NOT toke action againsr you fm thirty (3C -' days ll.ncr the dale uf lhL~ meeting. The nIl me!. <<(ItII'cSSC!l1UH.I te!ephone numbcri of .;iesi1lnul.cd oonSUllleI ~dil CfilmselinG: all:~cies f(.lf' Ine county in which the oroPcrtv IS located an: set fl1lth at the end ufthis Nmi,"l:t Jt is only necerll3l)' to schedlll~ one Jace~to-fucl: meeting. Advise your lend.::( immediafely of your intentions. 1 800 724 1633 Co/(f/.f/potlQfflC9 . P.O. Bo:oc 840, Qutfalo, NV 1424o-G84G PaymMt$ - P _0. Box 1.3eA, Bull'alo, NY 14240-13tU ~"ge ~UI'It InromliltlD1l,Just a r;Jick iIW.y. www,manalmort!1ege.C(lm ArpUCA nON FOR :\fOR'fGAGF. ASSlST AKCJ - Yl,KI( mortgage is ill default for the rcB.'" "'06 ~I fmth later in lhis Notice (:s<:e follo\ling; p6ges f[lr spccilic information abOUI tile oature of your defaull.) Ifym hll\lt tried and arc I.mahle tu te.wlvc this problem with thIlllender, you hove the right to apply fur financial as:!lista '_CtI frum the Homcnwn<<'s P,mcrgcncy Murtgl\gc Allsl.!Ol.ancc Program. To do so, you must fill out, siJ!1l1nd fil( II completed Homcowner'!\Bmerllcncy Assistance PtubOfam Application with one oftbe dedgnatcd CDn.J:IUrncr cledil coun!.eling ~genciC's li~ed ac the mt.I ofthi!l Notir.:e. Only consumer credit coun!>eling ag(;Jlcies have applicati:IlI> ({lr the pmgnlnl and thcy will as~jst you in submitting a complt'te application to thc Pennsylvilnia Ho~in!l Finance Agency. Your application MUST be filed ur pootmarkcd within thirty (30) days of your face-tu-face meclil,g. YUU ~ fiLE YOUR APPLI(;ATION PROMfT1- Y. IF YOU "'AIL TO DO SO OR IF VOU 00 NOT FOLLOW 11fE OTHi:R TIME PERIODS SET FORTH IN THIS LETTER, rOREcLOSI-RE !\t.-4.Y PKOCF.:F.D AGAL'lST YOL"R HOME IMMEDIATELY ANn YOUR APPLICATION FOl: !\fORl"GAGE ASSTSTANCE WILL BE DENtED. AGP.N'CY ACTION - Available fUllds for cmcrsency mortga,ge IIs!>islwlce are very limited, The '{ will be di:d>urscd by me AgalCY under the eligibility critr;:ria cl'i.tablished by the Act, Thl.' PC1lfll!.ylvania Ilou!>ing Fin:mce Agmcy ha! sixty (60) days to make" decision after it rtecives y()llr appJ ication. During that time, no furccl(l~'lrc proceeding" will be pursued ugainstyou ifyutl havc nlCt the time reqllircmcnb;!let forth above. You will be ndfictJ directly by the Pennsylv.ania Hou~ing Pinance Agency Onts oecisiOllll1l your application. NOTE: JF YOU ARE CURRF.~TLY PROTECTED BY THE FILING OF A pETITION U. BANKRUPTCY, nut POLLOWING PART OF TIllS NOTICF.IS FOR INFORMATlUr- J"URPOSES ONLY AND SHOULD NOT BF. CONSIDf.RF..D AS AN ATTEMPT TO COU.ECT TilE DEBT. ([f}'OU have filed bankruptry )Iou can still apply for F.mrrgency Murtgage ^~!li'ShlDce.) now TO CllRE YOUR MORTGAGI!: DEFAULT (lI.rlRl it up to dAte), ~AnTRR OF 'HIE DKf'AULT --The MORTOAGI:: doot h~ld hy the above lender on YOlll fX'l::erty lo,:atcd It: 241 Old Stane HOuse Ad c.rltsle. PA 17013 IS SERTOlJSL Y IN DEFAtJL TbCciUSC: YOU HA YE NOT MADI!. MORTGAGE PA YMEJl.jS for thc foHowing months. and thl' following amounq are nowll<ltit due: Regular p~yment. of $1~1e,.S 'or th. MOnthS Of 02/05/2004 thrcugn 'today's date: Othllr chal"gl!lll: -'Ccrued I-lIIt1! Char-ges: Accrued Othur emu-yes iOTAL AMOUNT PAST CUI; . . . . ~lt1!o.12 3Ei8,34 ZQ.OQ . :>1'4,58 IJOW TO ClIRE: THF. D~FAUr.T .~Youmay cure the default within nIlRTV {3D) DAYS uI the d",~ ofthi~ notice BY PAYING TH~ TOTAl. AMOUNT PAST DUE TO THE LEN'DER, WHKU rs ~ 10294,56, PLUS ANY MORTGAGE PAYMEi"\TS ANn LATE CHARCES WHICH BECOME DeE DURING THE THIRTY (0) DAY PERIOD. r9vmcllt~ mUllt be made either bveash. cushicr'schcck. cenilit'd check ormonev QrQt:r me-de !lQVllbltl and sent to: 1\1&1" Martgage Corporaikln On~ Foun'ain "I~z. I 7th ,.'Ioor Attll: Paymen. Proceninu: BufIalo. W 14Z03 You can cure (lrw other d.eflllllt bv takjnQ' the fulloWUIll. action with in THlRTV (301 DAYS ufth: dElte ofthi" letter: U' YOU no NOT CURF.THE DEFAIJJ..,]'-lf)'(.Iu do not ctlle the default within TlIIR]"Y (3';) DAYS urlhe date of thiN "':otice,'he lender in'end, to cnrtl~ ft! ril:kt510 accelerate the mortp&1" debt. This lTIC;lnsthat the entire ollt!>landing bll1ance ofthis debt \\.'ill he con!>idtae-d due in1ll1cdimly and yoOu may lose th~ ~haOl': to pay the mortgage in mOJ'uhly imluI1T1~Is_ If full po)'ment oftbe lotalrnnounl pa!>.t due i:!l nul made with l THIRTY (30) DAYS. the lentlcl also intends to in5U"ucl its attorney:. to start kgBI action to fOTffICl511 .pOD yo- Lr mortR,llaed propert}., 1800724 1~J ComlspD(Xl'flllce - P,O. 80l( 940, Buffalo. NY 14240..0840 Payroonts - P,O_ 8QIl: 1364, !iIJrralo,I-jY 14240-1384 I.#orl{J8ge lJCCGunl infotFnalion,jusr " t;/lek ~WDy, www_mlldmort~.(:Om IF 'tHB MORTGAGt Ul FOREC.LOSF.n UPON - The mOl1gagcd prOpe1ty wjU be !iotd by tll: Sberiffto payoff thl# mortgage debt. If the lQ1der ~fcrs}'Qur CalC to its ItUOrnCYll, but you cure the delinquency bd:'l'e the lender lxgiJl~ legal proceeding!'! against you, you will !\till be ~qu~rcd to peythe reilwl\ll,blc attomey'sfeo:$ that were actually incurred,. up lio $50.00. However, if Ic@al proceeding! arc started ag:llil1~ you, you will hB're: to pay ~ll rea50nablt C1Uurncy"fccl actually irll;:ul'1"Cd by the lender even !fthcy c:xceed SSfI.OO. Any .ll.lh)1ne,', fees will be added [(I the anll"1lll you owe the lender, which may aiM> incluc1c: l)('herrcu~u.)I\Il!'ll., costs. Ifyqu cl.re-Ihe dtt.ull within Ih. TInRTY (30) DAV pmo4, you wid Rol be nqulred to pay atrorne-y's fea. OTHF.R LI!:NVER RF.MEDIES _ The L:n.der may also Sl~ you personally for the unpaid prine .)a1 balance:md all other !;urns clue under tilt mon:~age, RlGHT 'TO ClJRE TUft DEFAULT PRIOR TO SHl;Ii....FS SALE - If you have: not cured lhedefuult wilflin the THIRIY (30) DA V period and foreclosure proceeding&' have begun, you still have the right u, cure the def:lUlt and pnm~n[ lllC :laic at any time up w ooc hour before the 9heriW,Salc. YOl.I may do so by payin!; thtllot211 amnunt then pa,sl dli(:, J1lu.!: any late or other charges then due, reasonahle auomcy'sfces and cos.m oonM'lted with the fOfecloouR: sIllc and any other colollll1 cu~tcd with th" Slu:riff'!\.Sale as specified in writing, by th, londer and by performing IIny other rciluircmcnts l,lJlder the IU<'lltgagc, Curing )'nn)' default In t~ manner ~ .tort. i.. this noli~ "ill nslore }'our morllage t~ the t2111e po!llion If~ ffyc>u had .n'er dcflnllltd, R^RLlE.ST POSSTRT.E SHERIFf'S SALE DA TE -- It is C8timalc:d that the carli/;St dute that I.Jch a Sheriff",sSale nflhc mortgaged property oo\lld be: held wOllldbe approximately 10 months from Ihe date oflldll Notice, A notice ofth!: actual date: of the Sheriff'sSa1c win he 5cnt to)'tlll bc:forc: the "ale, OfCOI.I'Oie. \he an Junt ncedcro to cum the default will increase the: longer yuu wait You may lind O\It at any time e~actly what lhc i'cquiTed plt}'1ttent or action will be by contacting dl'C lender, HOW TO CONTACT THE LF.NDER: N"ame of r.ellde.-: I\l&T Mortgatl;c CGt'poration Addr,,": P.O. &1: 840 Buffal9, I''"\-" 14140 Phone Number. (800) '24~1633 Et-t'ECT OF SE:lERIFF'SSAL~ _ Yuu ilhould rellliu that a Sh,eriff'IISalc will end yo1.11' (Jwnc "jhijl oftlle mortgaged property and your righll0 occupy it_ If you cont.lllue to live in the property after the ShcritrsSalc. it L:lwsuit to remove you and your fumishinglllUld other belonging" could be !1aftcd by the lender I.: any time_ ASS.UMP1'10N OF MORTGAGE _ You __ lDay or.! RIa)' not ~~Il nrtnmsfer your home 10 a buyer or lJOln:>fcrcc who will as!ioUme t.he lllortgllge debt, provided tlllH all the outlltllnding p"ymellts, eharg;:s and att~y's feel> and com. arc pBid priiJr lO or at the .<::alc and tha; the other requirement.. oftbe mortgage ;u'e ,.tidied. LOU MI\ Y ALSO HA. VI; TU~ RIGHT: TO SELL THE PROI'Ef{TYTO OBTAiN MONDY TO I"AV Off THE: MORTGAGE nEBTeR TO BORROW ~IONEY fROM ANOTHF.R LENDING INSTlTUl10N TO PAY OFI: THIS DEBT. TO HA VIi THIS DEPAUL T CURED BY ANY 'THIRD PARTY ACnKfi ON YOUR BEHALF. TO HAVJ': THE MORTGAGE RESTORED TO THE SAME POSITION A..C; IF NO DEFAUl.l HAD OCCURRED, If YOCCURF. THE DEFAULT, (HOWEVER, YOU DO NOT HAVE THJS RBHT TO CURE YOUR. DEFAW.T MORE THAN TIJREE TIMES TN ANY CALENDAR YllAR:,) TO ASSERT THF NONEXJSTENCE OF A DEFAULT IN ANY fOttECLOSURF. PROCEEL:JNG OR ANY OTHER LA WSl1lT INSTITUTED UNDER THE MORTGAGE DOCUMENTS, TO ASSIJRT ANY OTHER DF:FENSE YOUBELIEVTI YotTMAY HAVE TO SUCH ACTIC''I.j BY THE L~NOER. TO SEEK PROTCCTJQN UNDER THE FEDERAL BANKRUPTCY LAW. Sincerely, ~- ~'}1, Ru,ssellM. AIi:!i!iiJr. Collections Manager Ene: Act 91 Notice Cons,.mer Credit COUllM:liog: A~encics Serving Your County 1 BO()7.24 1633 CctTo~1UJ -P.O, B0ll84{1. BlItraIo, NY H240-W4C P'IIym"U', P.O. 8C1llC 1304, 9,"alo, NY 1424l).1M4 Mottg.ge lICcoont Infonnallon,just a dick away. www~IIg.,eom ACT 91 NOTICE TAKE ACTION TO SAVE YOUR HOME FROM FORECLOSURE T.hb hllln offld.1 notice th.t the mor1ur:. on "uur "ollie" In d~ri,d'. and th~ lender h:lk!lds tu foredolc. SpedOc; inform.don about 'he nature of ttte default Is provided in the attAched J!!IU. The UOMFAlWNKR'S MORTGACE ASSISTANCE PROGRAM (HEMAP) mAV be abh' to belD to lave vour hOmf. Thts Notlc:c cIDI.ln. how th~ orollram work&. To w ifllltMAP nn 1I~ln. ~u mutt Mltl!:C WITH A CONSIJMER CUDIT COUNSE::,!NG AGItNCY WI1HJN 30 DAVS OF TInt DATE OF THIS NOTICE. Take ...hl.. Notice- .th -you wh""t yo. mHt "".lth the Counsclin!! A2~nC'V. The Dam~ .ddn. tnd ohon. number f)(C.nsumer Cndit CnunaelinJl' Aeendl!s Icnine. tmul' County are lilted at t~ end nfthlJ Nottct. Uvoa bve .nv quelfhms. V<lP mn uU the PenlllJvlvaqia ::reullln. Flnaocr- AUCDt.\' ..n free H' 1-800....142.~13'7,lret'$flnll wltl) irtmairllld belrioll UIl call (717l ~;'iIt::lW1 This Notice (on~IM importllll Illgal1nformatloll. If you have any quelt1(ms, rellfe'sel.latives at the CmllSumu Credit COIIDqRC Agent:y 1111,. be IIble to bdp ~xpbin It. Yo. may .Iso war'i tu conlad an atturneytn YOl6r IIrea. The IoclIl bill' association may he able 10 help you fiad . ;ll"'yer. LA NOTIFlCA(:[ON EN AO.fUl\;'TO ES DE SUJ\-lA IJ\.fPORTANCIA. PUES A~'ECT ^ SU DERF.CRO A CONTINUAR VlVIKl'iDO f,NSU CASA. SI NO COMPREN'Dl. EL CONTENJDO DE ESiA SOTIPICACION OBTI!:N"GA UNA TRADUCCION INMEDIT AMENTE LLA.l\f ^ rmo EST 1\ AGENCIA (pT.NNSYLVANJA HOUSING FlNANe.!!: AGENCY) SIN CARGOS AI., NUMERO M~NCIONADO ARRIBA. PUF.O[,S SER ELEGlB'.E PARA L"N PRESTAMO POR EL PROCRAMA LLk'fADO "HOMEOWNER'S EMERG~CY MORTGAGE .\SSISTAN(.'E pn{)(~.tUI"EL CUAL PUti:DE SAT.VAK SU CASA DE LA l.'ERnmA m:L DF.RECHO A RI!:DIMIRSU ::([POTECA, 1801)7241Ei33 CCIi1ll$Ir;Jr/denctl . P.O. BoxMtl, 9ur1"alo, NV 14240-0840 Piljm<<1t~. P.O. Pc<< 1364, B ,tfalo, NY 14240-1384 lWortpag& accounr Infomlation,ju$l 8 (JfIcIc away. WW'o'I.mandlmcl1Qll9',QOm Homeowners' Emergency Assistance Progr:l.m CUMBERLAND COUNTY CCCS of Western Pennsylvania. Inc. 2000 Lirtglestown Road Harrisburg, P A 17102 (717) 541-1757 Urban League ofMetropoJitan JJarrisburg N_ 6th Street Harrisburg, PA 17101 (717) 234-5925 FAX (717) 234-9459 Community Attion Comm ofthc Capital Regwn 1514 Derry Street Harrisburg, PA 17104 (717) 232-9757 FAX (717) 234-2227 "'",,""....' Financial Counseling Scrvj{;es of Franklin 31. We,t 3,d Street Wa)1le>boro, P A 1726~ (717) 762-3285 YWCA ofCarli3le 301 Ii Street C.rlisle, PA 17013 (717) 243-3818 FAX (717) 731-95S9 Adams County Housing Alnhority 139-14:1 Carlisle 5t GoUysbu'g, rA 17325 (717)334-1518 FAX (717) 334-8326 ~~ ~I~~~~i fE:"trol FDa) 0 Yes CERTIFIED Mil. Cl NI.-n"C><1r 71826389306003795829 7180 6389 3060 0379 5829 .,UU.!JI.nl:Jf....."(:f.~.[......J.. .. . A. ~~III~r~: IDA1~~cH"'1!" "r' --IAg.."l)B_ RI!l~ei\'ec 8~: ,::e.u., 'ri,l' CI!t..,/y) c. OrJ.'(Y7.'/1- X~Q(),'lklJ{d(..,,--.. DO~JlJ~ A LCf.J..':[R ..." c..- l#r A.iICTe,l,"dt..n. iT..., O. A~~r~8sec ~ Addreu ~"_",.....,,..\>~ '''''..'c',,"., ~"""'J S.C"".", ....d-..... ,-"a. '....~I 'Floor ._{P.o.... il"M ci....;,i 73800011092819 C..,iu, J Mullen Debora 1 L Mullen 241 Dill Slone HOlls. Rd Carll.lI:, PA 17013 .'. i"';" -'~'1iP..~... . ~ (:) q 1 '" ~ , " r.....) <= C) Crt C:J - .1~-' -n ~ ~ 0 " ..... 8 0 - ;""f;~ ~ , r- b :"'1 f:r. ::.-) - Cl) 0 - -,", "Q. ~ -~1 ~') n -, --C.... -" "- c.) u"C SHERIFF'S RETURN - REGULAR CASE NO: 2004-02740 P COMMONWEALTH OF PENNSYLVANIA: COUNTY OF CUMBERLAND M&T MORTGAGE CORPORATION VS MULLEN CASSIUS J ET AL BRYAN WARD , Sheriff or Deputy Sheriff of Cumberland County,Pennsylvania, who being duly sworn according to law, says, the within COMPLAINT - MORT FORE was served upon MULLEN CASSIUS J the DEFENDANT , at 1510:00 HOURS, on the 14th day of July 2004 at 473 E NORTH STREET CARLISLE, PA 17013 by handing to CASSIUS MULLEN a true and attested copy of COMPLAINT - MORT FORE together with and at the same time directing His attention to the contents thereof. Sheriff's Costs: Docketing Service Affidavit Surcharge So Answers: 18.00 3.70 .00 10.00 .00 31.70 .~~~ R. Thomas Kline 07/19/2004 GOLDBECK MCCAFFERTY Sworn and Subscribed to before By: MCKEEVER IJ.-j Sheriff me this ,;ll-* day of ....., C);'--"7 rJ,./Jt}Y. A. D. ~o~01:o't(~~yl ~ SHERIFF'S RETURN - REGULAR CASE NO: 2004-02740 P COMMONWEALTH OF PENNSYLVANIA: COUNTY OF CUMBERLAND M&T MORTGAGE CORPORATION VS MULLEN CASSIUS J ET AL BRYAN WARD Sheriff or Deputy Sheriff of Cumberland County, Pennsylvania, who being duly sworn according to law, says, the within COMPLAINT - MORT FORE was served upon MULLEN DEBORAH L the DEFENDANT at 1530:00 HOURS, on the 14th day of July , 2004 at 241 OLD STONE HOUSE ROAD CARLISLE, PA 17013 by handing to DEBORAH MULLEN a true and attested copy of COMPLAINT - MORT FORE together with and at the same time directing Her attention to the contents thereof. Sheriff's Costs: Docketing Service Affidavit Surcharge So Answers: 6.00 3.70 .00 10.00 .00 19.70 ~g~~~?~ R. Thomas Kline 07/19/2004 GOLDBECK MCCAFFERTY MCKEEVER Sworn and Subscribed to before By: ~sL&l me this d/..r day of CZ1 :l..uo'l A . D . -<n-- () )n:u,., ~ -Prothonotary , GOLDBECK McCAFFERTY & McKEEVER BY: Josepl;) A. Goldbeck, Jr. Attorney J.D. #16132 Suit~ 500 - The Bourse Bldg. III S. Independence Mall East Philadelphia, P A 19106 215-627-1322 Attorney for Plaintiff M&T MORTGAGE CORPORATION PO Box 840 Buffalo, NY 14240-0840 IN THE COURT OF COMMON PLEAS Plaintiff of Cumberland County vs. CASSIUS J. MULLEN DEBORAH 1.. MULLEN (Mortgagor(s) and Record owner(s)) 241 Old Stone House Road Carlisle, PA 17013 CIVIL ACTION LAW ACTION OF MORTGAGE FORECLOSURE Defendant( s) No. 04-2740 ORDER FOR JUDGMENT Please enter Judgment in favor of M&T MORTGAGE CORPORATION, and against CASSIUS J. MULLEN and DEBORAH L. MULLEN for failure to file an Answer in the above action within (20) days (or sixty (60) days if defendant is the United States of America) from the date of service ofthe Complaint, in the sum of$261,958.28. Joseph A. Goldbeck Attorney for Plainti I hereby certifY that the above names are correct and that the precise rMidence address of the judgment creditor is M&T MORTGAGE CORPORATION PO Box 840 Buffalo, NY 14240-0840 and that the name(s) and last known address(es) of the Defendant(s) is/are CASSIUS J. MULLEN, 241 Old Stone House Road Carlisle, PA 17013 and DEBORAH L. MULLEN, 241 Old Stone House Road Carlisle, PA 17013; ASSESSMENT OF DAMAGES TO THE P~OTHONOTARY' Kindly assess the damages in this case to be as follows, Principal Balance Interest from 0110512004 through 0911712004 Attorney's Fee at 5.0000% of principal balance Late Charges Costs of Suit and Title Search Escrow AND NOW, this X{".>c..~y of ~ e.~ $236,491.95 $10,823.05 $11,824.60 $766.58 $900.00 $1,152.10 ($0.00) $261,958.28 ;yf .~ GOLDBW BY, Joseph A. Attorney for Pl. Y & McKEEVER , 2004 damages are assessed as above. ,C~-iMJ 1~6 VERIFICATION OF NON-MILITARY SERVICE The undersigned, as the representative for the Plaintiff corporation within named do hereby verify that I am authorized to make this verification on behalf of the Plaintiff corporation and that the facts set forth in the foregoing verification of Non-Mili tary Service are true and correct to the best of my knowledge, information and belief. I understand that false statements therein are made subject to penalties of 18 Pa. C.S. 4904 relating to unsworn falsification to authorities. 1. That the above named Defendant, CASSIUS J. MULLEN, is about unknown years of age, that Defendant's last known residence is 241 Old Stone House Road, Carlisle, PA 17013, and is engaged in the unknown business located at unknown address. 2. That Defendant is not in the Military or Naval Service of the United States or its Allies, or otherwise wi thin the provisions of the Soldiers' and Sailors' Civil Relief Action of Congress of 1940 and its Amendments. Date: VERIFICATION OF NON-MILITARY SERVICE The undersigned, as the representative for the Plaintiff corporation within named do hereby verify that I am authorized to make this verification on behalf of the Plaintiff corporation and that the facts set forth in the foregoing verification of Non-Mili tary Service are true and correct to the best of my knowledge, information and belief. I understand that false statements therein are made subject to penalties of 18 Fa. C.S. 4904 relating to unsworn falsification to authorities. 1. That the above named Defendant, DEBORAH L. MULLEN, is about unknown years of age, that Defendant's last known residence is 241 Old Stone House Road, Carlisle, PA 17013, and is engaged in the unknown business located at unknown address. 2. That Defendant is not in the Military or Naval Service of the United States or its Allies, or otherwise wi thin the provisions of the Soldiers' and Sailors' Civil Relief Action of Congress of 1940 and its .Amendments. Date: In the Court of Common Pleas of Cumberland County M&T MORTGAGE CORPORATION PO Box 840' Buffalo, NY 14240-0840 Plaintiff vs. CASSIUS J, MULLEN DEBORAH L. MULLEN (Mortgagor(s) and Record Owner(s)) 241 Old Stone House Road Carlisle, PA 17013 No, 04-2740 Defendant(s) PRAECIPE FOR JUDGMENT THIS LAW FIRM IS A DEBT COLLECTOR AND WE ARE ATTEMPTING TO COLLECT A DEBT OWED TO OUR CLIENT. ANY INFOR.IVlATION OBTAINED FROM YOU WILL BE USED FOR THE PURPOSE OF COLLECTING THE DEBT. Enter lhe Judgment in favor ofPJaintiff aIld against CASSIUS J. MULLEN and DEBORAH L. MULLEN by default for want of an Answer, Assess damages as follows: $261,958.28 Debt Interest - 0110512004 to 09/1712004 Total (Assessment of Damages attached) I CERTIFY THAT FOREGOING ASSESSMENT OF DAMAGES IS FOR SPECIFIED AMOUNTS ALLEGED TO BE DUE IN THE COMPLAINT AND IS CALCULABLE AS A SUM CERTAIN FROM THE COMPLAINT. 1 certify that written notice of the intention to file this praecipe was mailed or delivered to the party against whom judgment is to be entered and to his attorney of record, if any, after lhe default occurred and at Je dllYs prior to lhe date of lhe filing of this praecipe, A copy oflhe notice is attached. R,C-P, 237,J Joseph A Goldb Attorney for PIa !.D, #16132 I ANDNOW S;P.rr+-::t;;l. , ":J..(')CJJ ,Judgmentis nteredinfavorofM&T MORTGAGE CORPORATI~ ~d against CASSIUS J, MULLEN And DEBORAH L. MULLEN by default for want of an Answer aIld damages assessed in lhe sum of $26] ,958.28 as per lhe abovn:j~-",'~ K ' ~ ~onotary - (f THIS LAW FIRM IS A DEBT COLLECTOR AND WE ARE ATTEMPTING TO COLLECT A DEBT OWED TO OUR CLIENT. ANY INFORMATION OBTAINED :(fROM YOU WILL BE USED FOR THE PURPOSE OF COLLECTING THE DEBT. DATE OF THIS NOTICE: August 4,2004 TO: CASSIUS J. MULLEN 241 Old Stone House Road Carlisle, P A 17013 M&T MORTGAGE CORPORATION PO Box 840 Buffalo, NY 14240-0840 In the Court of Common Pleas of Cumberland County Plaintiff CIVIL ACTION - LAW vs. CASSIUS J. MULLEN DEBORAH L. MULLEN (Mortgagor(s) and Record Owner(s)) 241 Old Stone House Road Carlisle, P A 17013 Action of Mortgage Foreclosure Term No. 04-2740 Defendant(s} TO: CASSIUS J. MULLEN 241 Old Stone House Road Carlisle, P A 17013 IMPORT ANT NOTICF. YOU ARE IN DEFAULT BECAUSE YOU HAVE FAILED TO ENTER A WRITTEN APPEARANCE PERSONALLY OR BY ATTORNEY AND FILE IN WRITING WITH TIlE COURT YOUR DEFENSES OR OBJECTIONS TO TIlE CLAIMS SET FORTH AGAINST YOU. UNLESS YOU ACT WITHIN TEN (10) DAYS FROM TIlE DATE OF THIS NOTICE, A JUDGMENT MAY BE ENTERED AGAINST YOU WITHOUT A HEARlNG AND YOU MAY LOSE YOUR PROPERTY OR OTHER IMPORTANT RIGHTS. YOU SHOULD TAKE THIS PAPER TO YOUR LAWYER AT ONCE. IF YOU DO NOT HAVE A LAWYER, GO TO OR TELEPHONE THE OFFICE SET FORTIl BELOW. THIS OFFICE CAN PROVIDE YOU WITIl INFORMATION ABOUT HIRING A LAWYER. IF YOU CANNOT AFFORD TO HIRE A LAWYER. THIS OFFICE MAY BE ABLE TO PROVIDE YOU WITH INFORMATION ABOUT AGENCIES TIlAT MAY OFFER LEGAL SERVICES TO ELIGIBLE PERSONS AT A REDUCED FEE OR NO FEE. LEGAL SERVICES INC 8 lrvine Row Carlisle, PA 17013 717-243-9400 CUMBERLAND COUNTY BAR ASSOCIATION 2 Liberty Avenue Carlisle, PA 17013 GOLDBECK McCAFFERTY & McKEEVER BY: Joseph A. Goldbeck, Jr.. Esq. Attorney for Plaintiff Suite 5000 ~ Mellon Independence Center. 70 I Market Street Philadelphia, PA 19106 215-627-1322 TillS LAW FIRM IS A DEBT COLLECTOR AND WE ARE ATTEMPTING TO COLLECT A DEBT OWED TO OUR CLIENT. ANY INFORMATION OBTAINED FROM YOU WILL BE USED FOR THE PURPOSE OF COLLECTING THE DEBT. DATE OF THIS NOTICE: August 4,2004 TO: DEBORAH L. MULLEN 241 Old Stone House Road Carlisle, P A 17013 M&T MORTGAGE CORPORATION PO Box 840 Buffalo, NY 14240-0840 In the Court of Common Pleas of Cumberland County Plaintiff ClVIL ACTION - LAW VS. CASSIUS J. MULLEN DEBORAH L. MULLEN (Mortgagor( s) and Record Owner( s)) 241 Old Stone House Road Carlisle, P A 17013 Action of Mortgage Foreclosure Term No. 04-2740 Defendant(s} TO: DEBORAH L. MULLEN 241 Old Stone House Road Carlisle, P A 17013 .IMPORT ANT NOTWR YOU ARE IN DEFAULT BECAUSE YOU HAVE FAILED TO ENTER A WRITTEN APPEARANCE PERSONALLY OR BY ATTORNEY AND FILE IN WRITING WIlli THE COURT YOUR DEFENSES OR OBJECTIONS TO THE CLAIMS SET FORTH AGAINST YOU. UNLESS YOU ACT WITHIN TEN (10) DAYS FROM THE DATE OF THIS NOTICE, A JUDGMENT MAY BE ENTERED AGAINST YOU WITHOUT A HEARING AND YOU MAY LOSE YOUR PROPERTY OR OTHER IMPORTANT RIGHTS. YOU SHOULD TAKE THIS PAPER TO YOUR LAWYER AT ONCE. IF YOU DO NOT HAVE A LAWYER, GO TO OR TELEPHONE THE OFFICE SET FORTH BELOW. THIS OFFICE CAN PROVIDE YOU WITH INFORMATION ABOUT HIRING A LAWYER. IF YOU CANNOT AFFORD TO HIRE A LAWYER, THIS OFFICE MAY BE ABLE TO PROVIDE YOU WITH INFORMATION ABOUT AGENCIES THAT MAY OFFER LEGAL SERVICES TO ELIGIBLE PERSONS AT A REDUCED FEE OR NO FEE. LEGAL SERVICES INC 8 Irvine Row Carlisle, PA 17013 717-243-9400 CUMBERLAND COUNTY BAR ASSOCIATION 2 Liberty A venue Carlisle, PA 17013 GOLDBECK McCAFFERTY & McKEEVER BY; Joseph A. Goldbe<;k, Jr., Esq. Attorney for Plaintiff Suite 5000 - Mellon Independence Center. 70 I Market Street Philadelphia, PA 19106 215-627-1322 >r:J0"'9- ~\t:-~6 _, D r ~ ~ -tJ 3 ~ ~ p- v ~ (,v b ("" +.- f= -.r- ,_.J ;"1 t,) , .~ ,'..-' - PRAECIPE FOR WRIT OF EXECUTION - (MORTGAGE FORECLOSURE) P.R.C.P 3180-3183 Jo~eph A. Goldbeck, Jr. AdorneyI.D.#16132 Suite 500 - The Bourse Bldg. III S. Independence Mall East Philadelphia, PA 19106 215-627-1322 Attorney for Plaintiff M&T MORTGAGE CORPORATION PO Box 840 Buffalo, NY 14240-0840 IN THE COURT OF COMMON PLEAS Plaintiff vs. of Cumberland County CASSIUS J. MULLEN DEBORAH L. MULLEN Mortgagor(s) and Record Owner(s) 241 Old Stone House Road Carlisle, P A 17013 CIVIL ACTION - LAW ACTION OF MORTGAGE FORECLOSURE Defendant(s) No. 04-2740 PRAECIPE FOR WRIT OF EXECUTION TO THE PROTHONOTARY: Issue Writ of Execution in the above matter: Amount Due $261,958.28 Interest from 01105/2004 to 09/17/2004 at 6.5000% (Costs to be added) OOWBOCK ~~( & MoK>iliV'" BY: Joseph A. GolL r. Attorney for Plainti ~ \ \ R\ 'v) ~';;:)..~ ~ M":!'-I(,%~ ;s: \", .:-... 'J'.-~" ../\ r"l "') '~f)( I':::; C:, "".) ('J , , ,:-.,... j 0;:J () () () lfi '- Dt-~ 1 c.; r, -t- j ~ ~ vJ ~ ~ ~ 't~~ Q r.::i. -.J j (:::lJ. ~ z ~ 8 ... ~ ~ ..... " 'V;' ;. s: - 13 ~ t oil ~ ..... u~ ~3!"''O Z ;;2 -ez~~ ~ 1: ..:;~ m", 0 ~ co::::: 0 0 0 Z....lO<>:", ~ ill ..:.:::~ '.;:j :.!"",- o~ gz ~~"E&o ....s: u .s o(l~::8~f1 " '" o 0 t'- o ij .0 _ OO8~M ;":0 0 ....:J U 0....... ..... 8 -eo.. .Io.o.c:Q~p..'"';' U ~ . o:i:r: ~ - ... ~ Q)..g ~~ r--.. S <;' u ...... 0tB '" ;(! ::8....l "0.. ~: ~~5:.a~ " ;g ... 0 ~-e" . .;., ..... .0 ~ ....; a.s ~ ~ " U I fr-frJ. 0..... 1ZI ,-.IJJ .~ S " - 0 ~ot -jJ 0 :Eg]~~ z~ E- 2o~:s!~ ot: "':: "" on .:a ~ <>: "'~oou ... .. ~~ 0 0 lZI ~ 00....... ~6 a:.~ lZI c... u ::8 ~o"'.". 0.. .00- U ~N "''''- ~ E- ... - - 0 u c3 == d(j 6 ~ ..... ::8 ES Tract NO.1; All that certain traot of lll!1cl situa.t~ in Middlesex Township, CUmberland County, Pennsylvania, more particularly bounded and described in accoreianee with a survey by Thomas A. Neff, ~.S., dated September II, 1975, and revised December 26, 1975, as follows. 13E<UNNING at an i>:on pin on the eastern dedicatecl right of way line o~ Legislative Route 21026, said iron pin being at the southwest oomer of other l~d of John Durrman, IIII thenoe along the saatern declioated right of way line of Legislative Route 21028, North 44 degrees 38 minutes West 125.35 feet to a point; thenoa along a curve to the right with a radius of 25 feet, an arc distance of 38.93 feet to a pOint on the eastern side of a propOSed 50 foot street; thence along the eastern side of a proposed 50 foot street, North 44 clegrees 35 minutes 20 seoonds East 269.30 feet to an iron pinl thence South 45 degrees 24 minutes 40 seconds Bast 150 feet to an iron pinl thence along the western line of other propsrty of John Durrman, III, South 44 degrees 35 minutes 20 e~conds West 296 feet to an iron p1n on the easee:rn dediollted right of way line of Legislative Route 21028, the plaoe of BEGINNING. OONTAIN~NG 1.012 lIares and being Lot No. 3A on the revised SUbdivision plan for Linden Hall Farms, recorded in the Cumberland County Reco~der of Deeds Office in Plan Book 27, Page 92. ONDER AND SUBJECT, nevertheless, to the conditions and restrictions more partieulllrly set forth in Deed Book .S., Volume 26, Page 554. - . TRAC'1'. 1IO. 2. ALL that certain tract of land dt:ullte i.n Middlesex Township, CUmberland County, p~n.yl~ania, bounded and described according to a sUX'VSy dated ,JUly 24, 1972, by Thom~ A. Neff, R8giste2;"ed SurveY02;", as follows. ~ BEGINNING at an iron pin lit th.. ell.stern line of Le!il'bllltive Route 21028 (50 feet w1de,. and having an existing right of way w1dth of 33 feet), which said beginning point is situated South 44 degr~es 38 minutes Sast a distance of 594.04 feat fram the corner of property of paul W. Musselman; thence form said beginning po1nt by other property of Evelyn S. Roberts the following three courses and dist:ances. (1) North 44 degrees 35 minutes 20 saconds East 296.00 feet to an iron pin; (2) South 45 degrees 24 minutes 40 seconds East 296.00 feet to an iron pin; (3) South 44 degrees 35 minutes 20 seconds West 296.00 feet to an iron pin on the property line and 25 feet distant from the oenter line of Legislative Route 21028; thence by saicl property line 25 feet distant from ehe oenter line of Legislaeive Rouee 21028 North 4S degrees 24 minutes 40 seconds West 296.00 feet to an iron pin, the place of BBGINNING. CONTAINING 2.011 aores. ONDER AND SOBJECT, nevercheless, to the conditions and r..crictione more particularly eet forth in Peed Book .W." Volume 24, Page 358. ....--..-"j... ~~~_..- WRIT OF EXECUTION and/or ATTACHMENT COMMONWEALTH OF PENNSYL VANIA) COUNTY OF CUMBERLAND) TO THE SHERIFF OF CUMBERLAND COUNTY: To satisfy the debt, interest and costs due M&T MORTGAGE CORPORATION Plaintiff (s) From CASSIUS J. MULLEN AND DEBORAH L. MULLEN NO 04-2740 Civil CIVIL ACTION - LAW (I) You are directed to levy upon the property of the defendant (s)and to sell SEE LEGAL DESCRIPTION (2) You are also directed to attach the property of the defendant(s) not levied upon in the possession of GARNISHEE(S) as follows: and to notify the gamishee(s) that: (a) an attachment has been issued; (b) the garnishee(s) is enjoined from paying any debt to or for the account of the defendant (s) and from delivering any property of the defendant (s) or otherwise disposing thereof; (3) If property of the defendant( s) not levied upon an subjectto attachment is found in the possession of anyone other than a named garnishee, you are directed to notify himlher that he/she has been added as a garnishee and is enjoined as above stated. Amount Due $261,958.28 Interest FROM 1/5/04 TO 9/17/04 AT 6.5000% Arty's Comm % Arty Paid :1/33. I/O Plainti/Haid Date: SEPTEMBER .22, 2004 L.L. $.50 Due Prothy $1.00 Other Costs CURTIS R. LONG (Seal) ProthonotaIT By: -A n4J' .P. 7J{mA;~ Deputy REQUESTING PARTY: Narne JOHN A. GOLDBECK, JR., ESQUIRE Address: SillTE 500 - THE BOURSE BLDG. 111 S.INDEPENDENCE MALL EAST PHILADELPHIA, PA 19106 Attorney for: PLAINTIFF Telephone: 215-627-1322 Supreme Court ID No. 16132 Goldbeck McCafferty & McKeever BY: Joseph A. Goldbeck, Jr. A'tlorney J.D. #16132 Suite 500 - The Bourse Bldg.. III S. Independence Mal! East Philadelphia, PA 19106 215-627-1322 Attorney for Plaintiff M&T MORTGAGE CORPORATION PO Box 840 Buffalo, NY 14240-0840 IN THE COURT OF COMMON PLEAS Plaintiff of Cumberland County vs. CASSIUS J. MULLEN DEBORAH L. MULLEN (Mortgagor(s) and Record Owner(s)) 241 Old Stone House Road Carlisle, PA 17013 CIVIL ACTION - LAW ACTION OF MORTGAGE FORECLOSURE Defendant( s) No. 04-2740 AFFIDAVIT PURSUANT TO RULE 3129 M&T MORTGAGE CORPORATION, Plaintiff in the above action, by its attorney, Joseph A. Goldbeck, Jr., Esquire, sets forth as of the date the praecipe for the writ of execution was filed the following information concerning the real property located at: 241 Old Stone House Road Carlisle, P A 17013 I.Name and address ofOwner(s) or Reputed Owner(s): CASSIUS J. MULLEN 241 Old Stone House Road Carlisle, PA 17013 DEBORAH L. MULLEN 241 Old Stone House Road Carlisle, PA 17013 2. Name and address ofDefendant(s) in the judgment: CASSIUS 1. MULLEN 241 Old Stone House Road Carlisle, P A 17013 DEBORAH L. MULLEN 241 Old Stone House Road Carlisle, PA 17013 3. Name and last known address of every judgment creditor whose judgment is a record lien on the property to be sold: DOMESTIC RELATIONS OF CUMBERLAND COUNTY PO Box 320 Carlisle, PA 17013 I' A DEPARTMENT OF PUBLIC WELFARE - Bureau of Child Support Enforcement Health and Welfare Bldg. - Room 432 P.O. Box 2675 Harrisburg,PA 17105-2675 4. Name and address of the last recorded holder of every mortgage of record: WAYPOINTBANK 1300 CAMP HILL MALL CAMP HILL,PA 17011 5. Name and address of every other person who has any record interest in or record lien on the property and whose interest may be affected by the sale: 6. Name and address of every other person of whom the plaintiff has knowledge who has any record interest in the property which may be affected by the sale. 7. Name and address of every other person of whom the plaintiff has knowledge who has any interest in the property which may be affected by the sale. TENANTSIOCCUP ANTS 241 Old Stone House Road CarlisI", P A 17013 (attach separate sh"et if more space is needed) I veritY that the statements made in this affidavit are true and correct to the best of my personal knowledge or information and belief I understand that false statements herein are made subject to the penalties of 18 Pa. e.s. Section 4904 relating to unsworn falsification to authorities. GOLDBECK BY: Joseph A. Go Attorney for Plain fT DATED: September 17, 2004 04-2740 GOLDBECK McCAFFERTY & McKEEVER BY: Joseph A. Goldbeck, Jr. Attorney 1.D.#16132 Suite 5000- Mellon Independence Center 701 Market Street Philadelphia, P A 19106 215-627-1322 Attorney for Plaintiff M&T MORTGAGE CORPORATION PO Box 840 Buffalo, NY 14240-0840 IN THE COURT OF COMMON PLEAS of Cumberland County Plaintiff vs. CIVIL ACTION - LAW CASSIUS 1. MULLEN DEBORAH L. MULLEN Mortgagor(s) and Record Owner(s) ACTION OF MORTGAGE FORECLOSURE 241 Old Stone House Road Carlisle, PAl 7013 Term No. 04-2740 Defendant( s) THIS LAW FIRM IS A DEBT COLLECTOR AND WE ARE ATTEMPTING TO COLLECT A DEBT. THIS NOTICE IS SENT TO YOU IN AN ATTEMPT TO COLLECT A DEBT. ANY INFORMATION OBTAINED FROM YOU WILL BE USED FOR THAT PURPOSE. NOTICE OF SHERIFF'S SALE OF REAL PROPERTY TO: MULLEN, CASSIUS J. CASSIUS .J. MULLEN 241 Old Stone House Road Carlisle, P A 17013 Your house at 241 Old Stone House Road, Carlisle, PA 17013 is scbeduled to be sold at Sheriffs Sale on Wednesday, March 02, 2005, at 10:00 AM, in Commissioners Hearing Rm 2nd FL Courthouse to enforce the court judgment of $261,958.28 obtained by M&T MORTGAGE CORPORATION against you. NOTICE OF OWNER'S RIGHTS YOU MAY BE ABLE TO PREVENT THIS SHERIFF'S SALE To prevent this Sheriffs Sale you must take immediate action: 1. The sale will be cancelled if you pay to M&T MORTGAGE CORPORATION, the back payments, late charges, costs and reasonable attorney's fees due. To fmd out how much you must pay call: 215-627-1322 2. You may be able to stop the sale by filing a petition asking tbe Court to strike or open judgment, if the judgment was improperly entered. You may also ask the Court to postpone the sale for good cause. 04-2740 3. You may also be able to stop the sale through other legal proceedings. You may need an attorney to assert your rights. The sooner you contact one, the more chance you will have of stopping the sale. (See notice below on how to obtain an attorney). YOU MAY STILL BE ABLE TO SAVE YOUR PROPERTY AND YOU HAVE OTHER RIGHTS EVEN IF THE SHERIFF'S SALE DOES NOT TAKE PLACE. 1. If the Sheriffs Sale is not stopped, your property will be sold to the highest bidder. You may find out the price bid price by calling the Sheriff of717-240-6390. 2. You may be able to petition the Court to set aside the sale if the bid price was grossly inadequate compared to the value of your property. 3. The sale will go through only if the buyer pays the Sheriff the full amount due in the sale. To fmd out if this has happened, you may call the Sheriffof717-240-6390. 4. If the amount due from the Buyer is not paid to the Sheriff, you will remain the owner of the property as if the sale never happened. 5. You have a right to remain in the property until the full amount due is paid to the Sheriff and the Sheriff gives a deed to the buyer. At that time, the buyer may bring legal proceedings to evict you. 6. You may be entitled to a share of the money which was paid for your house. A schedule of distribution of the money bid for your house will be filed by the Sheriff thirty (30) days from the date of the Sheriffs Sale. This schedule will state who wiJI be receiving that money. The money will be paid out in accordance with this schedule unless exceptions (reasons why the proposed distribution is wrong) are filed with the Sheriff within ten (10) days after the schedule of distribution is filed. 7. You may also have other rights and defenses, or ways of getting your house back, if you act immediately after the sale. YOU SHOULD TAKE THIS PAPER TO YOUR LAWYER AT ONCE. IF YOU DO NOT HAVE A LAWYER OR CANNOT AFFORD ONE, GO TO OR TELEPHONE THE OFFICE LISTED BELOW TO FIND OUT WHERE YOU CAN GET LEGAL HELP. LEGAL SERVICES lNC 8 Irvine Row Carlisle, PA 17013 CUMBERLAND COUNTY BAR ASSOCIATION 2 Liberty Avenue Carlisle, P A 17013 04-2740 GOLDBECK McCAFFERTY & McKEEVER BY: Joseph A. Goldbeck, Jr. AttomeyI.D.#16132 Suite 5000- Mellon Independence Center 701 Market Street Philadelphia, P A 19106 215-627-1322 Attomey for Plaintiff M&T MORTGAGE CORPORATION PO Box 840 Buffalo, NY 14240-0840 IN THE COURT OF COMMON PLEAS of Cumberland County Plaintiff vs. CIVIL ACTION - LAW CASSIUS J. MULLEN DEBORAH L. MULLEN Mortgagor(s) and Record Owner(s) ACTION OF MORTGAGE FORECLOSURE 241 Old Stone House Road Carlisle, P A 17013 Term No. 04-2740 Defendant(s) THIS LAW FIRM IS A DEBT COLLECTOR AND WE ARE ATTEMPTING TO COLLECT A DEBT. THIS NOTICE IS SENT TO YOU IN AN ATTEMPT TO COLLECT A DEBT. ANY INFORMATION OBTAINED FROM YOU WILL BE USED FOR THAT PURPOSE. NOTICE OF SHERIFF'S SALE OF REAL PROPERTY TO: MULLEN. DEBORAH L DEBORAH L. MULLEN 241 Old Stone House Road Carlisle, P A 17013 Your house at 241 Old Stone House Road, Carlisle, P A 17013 is scheduled to be sold at Sheriffs Sale on Wednesday, March 02, 2005, at 10:00 AM, in Conunissioners Hearing Rm 2nd FL Courthouse to enforce the court judgment of$261,958.28 obtained by M&T MORTGAGE CORPORATION against you. NOTICE OF OWNER'S RIGHTS YOU MAY BE ABLE TO PREVENT THIS SHERIFF'S SALE To prevent this Sheriffs Sale you must take inunediate action: 1. The sale will be cancelled if you pay to M&T MORTGAGE CORPORATION, the back payments, late charges, costs and reasonable attomey's fees due. To find out how much you must pay call: 215-627-1322 2. You may be able to stop the sale by filing a petition asking the Court to strike or open judgment, if the judgment was improperly entered. You may also ask the Court to postpone the sale for good cause. 04-2740 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 stopptllg the sale. (See notice below on how to obtain an attorney). YOU MAY STU,L BE ABLE TO SAVE YOUR PROPERTY AND YOU HAVE OTHER RIGHTS EVEN IF THE SHERIFF'S SALE DOES NOT TAKE PLACE. I. If the Sheriff's Sale is not stopped, your property will be sold to the highest bidder. You may find out the price bid price by calling the Sheriff of717-240-6390. 2. You may be able to petition the Court to set aside the sale if the bid price was grossly inadequate compared to the value of your property. 3. The sale will go through only if the buyer pays the Sheriff the full amoUllt due in the sale. To find out if this bas happened, you may call the Sheriff oPI7-240-6390. 4. If the amoUllt due from the Buyer is not paid to the Sheriff, you will remain the owner of the property as jf the sale never happened. 5. You have a right to remain in the property Ulltil the full amoUllt due is paid to the Sheriff and the Sheriff gives a deed to the buyer. At that time, the buyer may bring legal proceedings to evict you. 6. You may be entitled to a share of the money which was paid for your house. A schedule of distribution of the money bid for your house will be filed by the Sheriff thirty (30) days from the date of the Sheriff's Sale. This scbedule 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 (l0) days after the schedule of distribution is filed. 7. You may also have other rights and defenses, or ways of getting your house back, if you act immediately after the sale. YOU SHOULD TAKE THIS PAPER TO YOUR LAWYER AT ONCE. IF YOU DO NOT HAVE A LAWYER OR CANNOT AFFORD ONE, GO TO OR TELEPHONE THE OFFICE LISTED BELOW TO FIND OUT WHERE YOU CAN GET LEGAL HELP. LEGAL SERVICES INC 8 Irvine Row Carlisle, P A 17013 CUMBERLAND COUNTY BAR ASSOCIATION 2 Liberty Avenue Carlisle, PA 17013 GOLDBECK McCAFFERTY & McKEEVER BY: Joseph A. Goldbeck, Jr. Attorney 1.0. #16132 Suite 5000 - Mellon Independence Center 701 Market Street Philadelphia, PA 19106 215-627-1322 Attorney for Plaintiff M&T MORTGAGE CORPORATION PO Box 840 Buffalo, NY 14240-0840 Plaintiff Ys. CASSIUS J. MULLEN DEBORAH L. MULLEN (Mortgagor(s) and Record owner(s)) 241 Old Stone House Road Carlisle, PA 17013 IN THE COURT OF COMMON PLEAS of Cumberland County No. 04-2740 PRAECIPE TO SATISFY JUDGMENT TO THE PROTHONOTARY: Kindly Satisfy the Judgment in the above captioned matter upon payment of your costs only. fJIt~ JOSEPH A. GOLDBECK, JR., ESQUIRE () r-.,) 4::) ~ c C:;) <"" ..J::'" -003 z :2 mrn 0 rn~ 2;Tl <:: Z():.., N -om Cf.) ,,~ . C..:> :09 ~.<': 0... :<t:. ::;J~ ~() -0 ~-ri :Jl: 0("5 :i>O c...> am c: z .. -4 )> =< :.0 -< 11/19/2004 16:28 FAX 215 627 7734 ~ CUMBERLAND SO GOLDBECK GOLDBECK McCAFFERTY & McKEEVER A PROFESSIONAL CORPORATION SUITE 5000 - MELLON INDEPENDENCE CENTER 701 MARKIOT STREET PHILADELPHIA, PA 19106-1532 (215) 627-1322 FAX (215) 627-7734 JOSEf'H A. GOlDl:lEC"'. JR. GARY E. MCCAFFERTY MICHAEl. T. McKI:EVER / November 19, 2004 R. Thomas Kline SHERIFF OF CUMBERlAND COUNTY Sheriffs Office 1 Courthouse Square Carlisi.., PA 17013 Cumberland RE: M&T MORTGAGE CORPORATION vs. CASSIUS J. MULLEN and DEBORAH L MULLEN Term No. 04-2740 n ~::~ Propertv address: 241 Old Sfone House Road Carl;s/e, PA 17013 Sheriff's Sale Date: March 02, 2005 );,. Dear Sir/Madam: Kindly stay the Sheriff's Sale with reference to the above-captioned matter and return any unused costs. I collected $236,491.95 ;n Drinc;",,1 towards my clienfs debt Thank you for your cooperation. CjilRrJ:> fh'J~1ECK. JR. JAG/51 /1/);//6>1 - ;& lur m...oC and. Jf I ':>UO. - or~J~ uJ,e.i.J to /JaA:lj; . i depos / I -10 ,A tt Mrtli[ r;D I at be d - 1m 001 ", l.;.-.:,;' Co,:) ..r.:- ::;r'<- C} ""<It;: ~~ ---I :)~ -" flle'_:';: i"1'1 C.J t t.,) -'r, i~lr;:~ ,..) :,,-1 f> ~~:'/ ~< r" (.,.) .~-r::.i =;,r. c~, o Q'l WRIT OF EXECUTION and/or ATTACHMENT COMMONWEALTH OF PENNSYLVANIA) COUNTY OF CUMBERLAND) NO 04-2740 Civil CIVIL ACTION - LAW TO THE SHERIFF OF CUMBERLAND COUNTY: To satisfy the debt, interest and costs due M&T MORTGAGE CORPORATION Plaintiff (s) From CASSIUS J. MULLEN AND DEBORAH L. MULLEN (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 $261,958.28 Interest FROM 1/5/04 TO 9/17/04 AT 6.5000% Atty's Comm % Atty Paid j I)J. l<'() Plaintiffpaid Date: SEPTEMBER 22, 2004 L.L. $.50 Due Prothy $1.00 Other Costs CURTIS R. LONG (Seal) prothon~ Bv: I'.l...-o..tJ Q .7lzeo/J"r. r-- Deputy REQUESTING PARTY: Name JOHN A. GOLDBECK, JR., ESQIDRE Address: SIDTE 500 - THE BOURSE BLDG. 111 S. INDEPENDENCE MALL EAST PHILADELPHIA, PA 19106 Attorney for: PLAINTIFF Telephone: 215-627-1322 Supreme Court ID No. 16132 WRIT OF EXECUTION and/or ATTACHMENT COMMONWEALTH OF PENNSYLVANIA) COUNTY OF CUMBERLAND) NO 04-2740 Civil CIVIL ACTION - LAW TO THE SHERIFF OF CUMBERLAND COUNTY: To satisfy the debt, interest and costs due M&T MORTGAGE CORPORATION Plaintiff(s) From CASSIUS J. MULLEN AND DEBORAH L. MULLEN (I) You are directed to levy upon the property of the defendant (s)and to sell SEE LEGAL DESCRIPTION (2) You are also directed to attach the property of the defendant(s) not levied upon in the possession of GARNISHEE(S) as follows: and to notify the gamishee(s) that: (a) an attachment has been issued; (b) the gamishee(s) is enjoined from paying any debt to or for the account of the defendant (s) and from delivering any property of the defendant (s) or otherwise disposing thereof; (3) Ifproperty of the defendant(s) not levied upon an subject to attachment is found in the possession of anyone other than a named garnishee, you are directed to notify himlher that he/she has been added as a garnishee and is enjoined as above stated. Amount Due $261,958.28 Interest FROM 1/5/04 TO 9/17/04 AT 6.5000% L.L. $.50 Atty's Comm % AttyPaid 1/33.'IP Plaintiff Paid Date: SEPTEMBER 22, 2004 Due Prothy $1.00 Other Costs CURTIS R. LONG (Seal) ProthO~ ~y: OA. 0 ~~ ~.Ilf7/' <.r Deputy REQUESTING PARTY: Name JOHN A. GOLDBECK, JR., ESQUIRE Address: SUITE 500 - THE BOURSE BLDG. 111 S.INDEPENDENCE MALL EAST PHILADELPHIA, PA 19106 Attorney for: PLAINTIFF Telephone: 215-627-1322 Supreme Court ID No. 16132 ':'-.~ !' I :~;tu:.l... .' ,----.. 40 ~ ,2...~' i WRIT OF EXECUTION and/or ATTACHMENT COMMONWEALTH OF PENNSYLVANIA) COUNTY OF CUMBERLAND) NO 04-2740 Civil CIVIL ACTION - LAW TO THE SHERIFF OF CUMBERLAND COUNTY: To satisfy the debt, interest and costs due M&T MORTGAGE CORPORATION Plaintiff (s) From CASSIUS J. MULLEN AND DEBORAH L. MULLEN (1) You are directed to levy upon the property of the defendant (s)and to sell SEE LEGAL DESCRIPTION (2) You are also directed to attach the property of the defendant(s) not levied upon in the possession of GARNISHEE(S) as follows: and to notify the gamishee(s) that: (a) an attachment has been issued; (b) the garnishee(s) is enjoined from paying any debt to or for the account of the defendant (s) and from delivering any property of the defendant (s) or otherwise disposing thereof; (3) Ifproperty of the defendant(s) not levied upon an subject to attachment is found in the possession of anyone other than a named garnishee, you are directed to notify him/her that he/she has been added as a garnishee and is enjoined as above stated. Amount Due $261,958.28 Interest FROM 1/5/04 TO 9/17/04 AT 6.5000% Ally's Comm % Ally Paid j /31. 'If) Plaintiff Paid Date: SEPTEMBER 22, 2004 L.L. $.50 Due Prothy $1.00 Other Costs CURTIS R. LONG (Seal) ProthO~ ~ --...J!y: (J/l 0 -~. "/l1U rt.-~ Deputy REQUESTING PARTY: Name JOHN A. GOLDBECK, JR., ESQUIRE Address: SUITE 500 - THE BOURSE BLDG. 111 S. INDEPENDENCE MALL EAST PHILADELPHIA, PA 19106 Attorney for: PLAINTIFF Telephone: 215-627-1322 Supreme Court lD No. 16132 '- !,~r.:d ,.-"J~~ ~ "~.}J ~....'.~. t-i:~. ,; - .:.,....:.,ij WRIT OF EXECUTION and/or ATTACHMENT COMMONWEALTH OF PENNSYLVANIA) COUNTY OF CUMBERLAND) NO 04-2740 Civil CIVIL ACTION - LAW TO THE SHERIFF OF CUMBERLAND COUNTY: To satisfy the debt, interest and costs due M&T MORTGAGE CORPORATION Plaintiff (s) From CASSIUS J. MULLEN AND DEBORAH L. MULLEN (I) 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 himiher that he/she has been added as a garnishee and is enjoined as above stated. Amount Due $261,958.28 Interest FROM 1/5/04 TO 9/17/04 AT 6.5000% L.L. $.50 Atty's Comm % Due Prothy $1.00 Other Costs Atty Paid .$ /31. 'If) Plaintiff Paid Date: SEPTEMBER 22, 2004 CURTIS R. LONG (Seal) Prothonotary ,-By: a1)~D _Q. ~/l/J.;r,;--- Deputy REQUESTING PARTY: Name JOHN A. GOLDBECK, JR., ESQUIRE Address: SUITE 500 - THE BOURSE BLDG. 111 S. INDEPENDENCE MALL EAST PHILADELPHIA, PA 19106 Attorney for: PLAINTIFF Telephone: 215-627-1322 Supreme Court ID No. 16132 ::::~ WRIT OF EXECUTION and/or ATTACHMENT COMMONWEALTH OF PENNSYLVANIA) COUNTY OF CUMBERLAND) NO 04-2740 Civil CIVIL ACTION - LAW TO THE SHERIFF OF CUMBERLAND COUNTY: To satisfy the debt, interest and costs due M&T MORTGAGE CORPORATION Plaintiff (s) From CASSIUS J. MULLEN AND DEBORAH L. MULLEN (I) 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 $261,958.28 Interest FROM 1/5/04 TO 9/17/04 AT 6.5000% L.L. $.50 Ally's Comm % Due Prothy $1.00 Other Costs Ally Paid !$IJ:J. Vl> Plaintiffpaid Date: SEPTEMBER 22, 2004 CURTIS R. LONG (Seal) Prothonotary '-.By' An., 0 - P. 7l{-# ~ r. r-- Deputy REQUESTING PARTY: Name JOHN A. GOLDBECK, JR., ESQIDRE Address: SIDTE 500 - THE BOURSE BLDG. 111 S. INDEPENDENCE MALL EAST PHILADELPHIA, PA 19106 Attorney for: PLAINTIFF Telephone: 215-627-1322 Supreme Court ID No. 16132 "<. -~~ ~:," ';'" '-''', :f~:. o' , , .- ') -..' j' t'(:~:(..j 'J \i', Pd~ WRIT OF EXECUTION and/or ATTACHMENT COMMONWEALTH OF PENNSYLVANIA) COUNTY OF CUMBERLAND) NO 04-2740 Civil CIVIL ACTION - LAW TO THE SHERIFF OF CUMBERLAND COUNTY: To satisfy the debt, interest and costs due M&T MORTGAGE CORPORATION Plaintiff (s) From CASSIUS J. MULLEN AND DEBORAH L. MULLEN (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 himlher that he/she has been added as a garnishee and is enjoined as above stated. Amount Due $261,958.28 Interest FROM 1/5/04 TO 9/17/04 AT 6.5000% Atty's Comm % Atty Paid .:113:1.110 Plaintiff Paid Date: SEPTEMBER 22, 2004 L.L. $.50 Due prothy $1.00 Other Costs CURTIS R. LONG (Seal) prothon~ .-By: ~ D >? /72~/J.4/L ~ Deputy REQUESTING PARTY: Name JOHN A. GOLDBECK, JR., ESQUIRE Address: SUITE 500 - THE BOURSE BLDG. 111 S. INDEPENDENCE MALL EAST PHILADELPHIA, PA 19106 Attorney for: PLAINTIFF Telephone: 215-627-1322 Supreme Court ID No. 16132 < F~ C~::f.'f Fr'C~~~iJ ~f) '-I ~;ff~~~.:~ r', ~:::.'H'",>: _.: :;, -. ...._ ------- WRIT OF EXECUTION and/or ATTACHMENT COMMONWEALTH OF PENNSYLVANIA) COUNTY OF CUMBERLAND) TO THE SHERIFF OF CUMBERLAND COUNTY: To satisfy the debt, interest and costs due M&T MORTGAGE CORPORATION Plaintiff (s) From CASSIUS J. MULLEN AND DEBORAH L. MULLEN NO 04-2740 Civil CIVIL ACTION - LAW (I) You are directed to levy upon the property of the defendant (sland 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 himlher that he/she has been added as a garnishee and is enjoined as above stated. Amount Due $261,958.28 Interest FROM 1/5/04 TO 9/17/04 AT 6.5000% L.L. $.50 Arty's Conun % Arty Pajd :J /3J .l./f) Plaintiff Paid Date: SEPTEMBER 22, 2004 Due Prothy $1.00 Other Costs CURTIS R. LONG (Seal) prothona By: 'Jh..-f< .F? 77zr/l/J.n~ Deputy REQUESTING PARTY: Name JOHN A. GOLDBECK, JR., ESQUIRE Address: SUITE 500 - THE BOURSE BLDG. 111 S. INDEPENDENCE MALL EAST PHILADELPHIA, PA 19106 Attorney for: PLAINTIFF Telephone: 215-627-1322 Supreme Court ID No. 16132 .~~' ''':'''~l..';' "'-'.'f"';,", i:' (.~r',':'~'~{ '"'1'J ;, "j ~(' . n.. ' '.\ ~":'~."~W' ~ ~.e:.,...~~.A.Jp::J- , Goldbeck McCafferty & McKeever BY: Joseph A. Goldbeck:, Jr. Attorney J.D. #16132 Suite 500 - The Bourse Bldg. 111 S. Independence Mall East Philadelphia, PA 19106 215-627-1322 Attorney for Plaintiff M&T MORTGAGE CORPORATION PO Box 840 Buffalo, NY 14240-0840 IN THE COURT OF COMMON PLEAS Plaintiff of Cumberland County vs. CASSIUS 1. MULLEN DEBORAH L. MULLEN (Mortgagor(s) and Record Owner(s)) 241 Old Stone House Road Carlisle, PA 17013 CIVIL ACTION - LAW ACTION OF MORTGAGE FORECLOSURE Defendant(s) No. 04-2740 AFFIDAVIT PURSUANT TO RULE 3129 M&T MORTGAGE CORPORATION, Plaintiff in the above action, by its attorney, Joseph A. Goldbeck, Jr., Esquire, sets forth as of the date the praecipe for the writ of execution was filed the following infonnation concerning the real property located at: 241 Old Stone House Road Carlisle, PA 17013 I.Name and address of Owner(s) or Reputed Owner(s): CASSIUS J. MULLEN 241 Old Stone House Road Carlisle, PA 17013 DEBORAH 1.. MULLEN 241 Old Stone House Road Carlisle, PA 17013 2. Name and address ofDefendant(s) in the judgment: CASSIUS J. MULLEN 241 Old Stone House Road Carlisle, P A 17013 DEBORAH 1.. MULLEN 241 Old Stone House Road Carlisle, PA 17013 3. Name and last known address of every judgment creditor whose judgment is a record lien on the property to be sold: DOMESTIC RELATIONS OF CUMBERLAND COUNTY PO Box 320 Carlisle, P A 17013 P A DEPARTMENT OF PUBLIC WELFARE - Bureau of Child Support Enforcement Health and Welfare Bldg. - Room 432 P.O. Box 2675 Harrisburg, P A 17105-2675 4. Name and address of the last recorded holder of every mortgage of record: WAYPOINTBANK 1300 CAMP HILL MALL CAMP HILL, PA 17011 5. Name and address of every other person who has any record interest in or record lien on the property and whose interest may be affected by the sale: 6. Name and address of every other person of whom the plaintiff has knowledge who has any record interest in the property which may be affected by the sale. 7. Name and address of every other person of whom the plaintiff has knowledge who has any interest in the property which may be affected by the sale. GOLDBECK c BY: Joseph A. G Attorney for Plain TENANTS/OCCUPANTS 241 Old Stone House Road Carlisle, P A 17013 (attach separate sheet if more space is needed) I verify that the statements made in this affidavit are true and correct to the best of my personal knowledge or information and belief. I understand that false statements herein are made subject to the penalties of 18 Pa. C.S. Section 4904 relating to unsworn falsification to authorities. DATED: September 17, 2004 I 04-2740 GOLDBECK McCAFFERTY & McKEEVER BY: Joseph A. Goldbeck, Jr. Attorney I.D.#16132 Suite 5000- Mellon Independence Center 701 Market Street Philadelphia, P A 19106 215-627-1322 Attorney for Plaintiff M&T MORTGAGE CORPORATION PO Box 840 Buffalo, NY 14240-0840 IN THE COURT OF COMMON PLEAS of Cumberland County Plaintiff VS. CIVIL ACTION - LAW CASSIUS J. MULLEN DEBORAH L. MULLEN Mortgagor(s) and Record Owner(s) ACTION OF MORTGAGE FORECLOSURE 241 Old Stone House Road Carlisle, PA 17013 Term No. 04-2740 Defendant( s THIS LAW FIRM IS A DEBT COLLECTOR AND WE ARE ATTEMPTING TO COLLECT A DEBT. THIS NOTICE IS SENT TO YOU IN AN ATTEMPT TO COLLECT A DEBT. ANY INFORMATION OBTAINED FROM YOU WILL BE USED FOR THAT PURPOSE. NOTICE OF SHERIFF'S SALE OF REAL PROPERTY TO: MULLEN. CASSIUS J. CASSIUS .I. MULLEN 241 Old Stone House Road Carlisle, P A 17013 Your house at 241 Old Stone 1I0use Road, Carlisle, P A 17013 is scheduled to be sold at Sheriff, Sale on Wednesday, March 02,2005, at 10:00 AM, in Commissioners Hearing Rm 2nd FL Courthouse to enforce the court judgment of $261 ,958.28 obtained by M&T MORTGAGE CORPORATION against you. NOTICE OF OWNER'S RIGHTS YOU MAY BE ABLE TO PREVENT THIS SHERIFF'S SALE To prevent this Sheriffs Sale you must take immediate action: 1. The sale will be cancelled if you pay to M&T MORTGAGE CORPORATION, the back payments, late charges, costs and reasonable attorney's fees due. To find out how much you must pay call: 215-627.1322 2. You may be able to stop the sale by filing a petition asking the Court to strike or open judgment, if the judgment was improperly entered. You may also ask the Court to postpone the sale for good cause. I 04-2740 3. You may also be able to stop the sale through other legal proceedings. You may need an attorney to assert your rights. The sooner you contact one, the more chance you will have of stopping the sale. (See notice below on how to obtain an attorney). YOU MAY STILL BE ABLE TO SAVE YOUR PROPERTY AND YOU HAVE OTHER RIGHTS EVEN IF THE SHERIFF'S SALE DOES NOT TAKE PLACE. 1. If the Sheriffs Sale is not stopped, your propeny will be sold to the highest bidder. You may find out the price bid price by calling the Sheriff 0017-240-6390. 2. You may be able to petition the Court to set aside the sale if the bid price was grossly inadequate compared to the value of your property. 3. The sale will go through only if the buyer pays the Sheriff the full amoWlt due in the sale. To fmd out if this has happened, you may call the Sheriff 0017-240-6390. 4. If the amount due from the Buyer is not paid to the Sheriff, you will remain the owner of the property as if the sale never happened. 5. You have a right to remain in the property until the full amount due is paid to the Sheriff and the Sheriff gives a deed to the buyer. At that time, the buyer may bring legal proceedings to evict you. 6. You may be entitled to a share of the money which was paid for your house. A schedule of distribution of the money bid for your house will be filed by the Sheriff thirty (30) days from the date of the Sheriff's Sale. This schedule will state who will be receiving that money. The money will be paid out in accordance with this schedule unless exceptions (reasons why the proposed distribution is wrong) are filed with the Sheriff within ten (10) days after the schedule of distribution is filed. 7. You may also have other rights and defenses, or ways of getting your house back, if you act immediately after the sale. YOU SHOULD TAKE THIS PAPER TO YOUR LAWYER AT ONCE. IF YOU DO NOT HAVE A LAWYER OR CANNOT AFFORD ONE, GO TO OR TELEPHONE THE OFFICE LISTED BELOW TO FIND OUT WHERE YOU CAN GET LEGAL HELP. LEGAL SERVICES INC 8 Irvine Row Carlisle, PA ]7013 CUMBERLAND COUNTY BAR ASSOCIATION 2 Liberty Avenue Carlisle, PA ]7013 04-2740 I GOLDBECK McCAFFERTY & McKEEVER BY: Joseph A. Goldbeck, Jr. AttomeyI.D.#I6132 Suite 5000- Mellon Independence Center 701 Market Street Philadelphia, P A 19106 215-627-1322 Allomey for Plaintiff M&T MORTGAGE CORPORATION PO Box 840 Buffalo, NY 14240-0840 IN THE COURT OF COMMON PLEAS of Cumberland County Plaintiff vs. CIVIL ACTION - LAW CASSIUS 1. MULLEN DEBORAH L. MULLEN Mortgagor(s) and Record Owner(s) ACTION OF MORTGAGE FORECLOSURE 241 Old Stone House Road Carlisle, PA 17013 Term No. 04-2740 Defendant( s THIS LAW FIRM IS A DEBT COLLECTOR AND WE ARE ATTEMPTING TO COLLECT A DEBT. THIS NOTICE IS SENT TO YOU IN AN ATTEMPT TO COLLECT A DEBT. ANY INFORMATION OBTAINED FROM YOU WILL BE USED FOR THAT PURPOSE. NOTICE OF SHERIFF'S SALE OF REAL PROPERTY TO: MULLEN. DEBORAH L DEBORAH L. MULLEN 241 Old Stone House Road Carlisle, PA 17013 Your house at 241 Old Stone House Road, Carlisle, P A 17013 is scheduled to be sold at Sheriffs Sale on Wednesday, March 02, 2005, at 10:00 AM, in Commissioners Hearing Rm 2nd FL Courthouse to enforce the court judgment of$261,958.28 obtained by M&T MORTGAGE CORPORATION against you. NOTICE OF OWNER'S RIGHTS YOU MAY BE ABLE TO PREVENT THIS SHERIFF'S SALE To prevent this Sheriff's Sale you must take immediate action: l. The sale will be cancelled if you pay to M&T MORTGAGE CORPORATION, the back payments, late charges, costs and reasonable attomeis fees due. To find out how much you must pay call: 215-627-1322 2. You may be able to stop the sale by filing a petition asking the Court to strike or open judgment, if the judgment was improperly entered. You may also ask the Court to postpone the sale for good cause. t 04-2740 , 3. You may also be able to stop the sale through other legal proceedings. You may need an attorney to assert your rights. The sooner you contact one, the more chance you will have of stopping the sale. (See notice below on how to obtain an attorney). YOU MAY STILL BE ABLE TO SAVE YOUR PROPERTY AND YOU HAVE OTHER RIGHTS EVEN IF THE SHERIFF'S SALE DOES NOT TAKE PLACE. I. If the Sheriffs Sale is not stopped, your property will be sold to the highest bidder. You may find out the price bid price by calling the Sheriff of717-240-6390. 2. You may be able to petition the Court to set aside the sale if the bid price was grossly inadequate compared to the value of your property. 3. The sale will go through only if the buyer pays the Sheriff the full amount due in the sale. To find out if this has happened, you may call the Sheriffof717-240-6390. 4. If the amount due from the Buyer is not paid to the Sheriff, you will remain the owner of the property as if the sale never happened. 5. You have a right to remain in the property until the full amount due is paid to the Sheriff and 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 ofthe money bid for your house will be filed by the Sheriff thirty (30) days from the date of the Sheriffs Sale. This schedule will state who will be receiving that money. The money will be paid out in accordance with this schedule unless exceptions (reasons why the proposed distribution is wrong) are filed with the Sheriff within ten (10) days after the schedule of distribution is filed. 7. You may also have other rights and defenses, or ways of getting your house back, if you act immediately after the sale. YOU SHOULD TAKE THIS PAPER TO YOUR LAWYER AT ONCE. IF YOU DO NOT HAVE A LAWYER OR CANNOT AFFORD ONE, GO TO OR TELEPHONE THE OFFICE LISTED BELOW TO FIND OUT WHERE YOU CAN GET LEGAL HELP. LEGAL SERVICES INC 8 Irvine Row Carlisle, PA 17013 CUMBERLAND COUNTY BAR ASSOCIATION 2 Liberty Avenue Carlisle, P A 17013 Plaintiff IN THE COURT OF COMMON PLEAS Jospeh A. Goldbeck, Jr. Attorney I.D. #16132 Suite 500 - The Bourse Bldg. III S. Independence Mall East Philadelphia, PA 19106 215-627-1322 Attorney for Plaintiff M&T MORTGAGE CORPORATION PO Box 840 Buffalo, NY 14240-0840 vs. CASSIUS J. MULLEN DEBORAH L. MULLEN Mortgagor(s) and Record Owner(s) 241 Old Stone House Road Carlisle, PA 17013 of Cumberland County CIVIL ACTION - LAW Defendant(s) ACTION OF MORTGAGE FORECLOSURE NO. 04-2740 CERTIFICATION AS TO THE SALE OF REAL PROPERTY I, Joseph A. Goldbeck, Jr., Esquire hereby certify that I am the attorney of record for the Plaintiff in this action, and I further CCJ1ify that this propc11y is subject to Act 91 of 1983 and thc Plaintiff has complicd with all the provisions of the Act. SHORT DESCRIPTION IMPROVEMENTS consist of a residential dwelling. BEING PREMISES: 241 Old Stone House Road Carlisle, PA 17013 SOLD as the property of CASSIUS J. MULLEN and DEBORAH L. MULLEN TAX PARCEL #21-08-0571-009; 21-08-0571-015 , SHORT DESCRIPTION IMPROVEMENTS consist of a residential dwelling. BEING PREMISES: 241 Old Stone House Road Carlisle, PA 17013 SOLD as the property of CASSIUS J. MULLEN and DEBORAH L. MULLEN TAX PARCEL #21-08-0571-009; 21-08-0571-015 SHORT DESCRIPTION IMPROVEMENTS consist of a residential dwelling. BEING PREMISES; 241 Old Stone House Road Carlisle, PA 17013 SOLD as the property of CASSIUS J. MULLEN and DEBORAH L. MULLEN TAX PARCEL #21-08-0571-009; 21-08-0571-015 SHORT DESCRIPTION IMPROVEMENTS consist of a residential dwelling. BEING PREMISES: 241 Old Stone House Road Carlisle, PA 17013 SOLD as the property of CASSIUS J. MULLEN and DEBORAH L. MULLEN TAX PARCEL #21-08-0571-009; 21-08-0571-015 SHORT DESCRIPTION IMPROVEMENTS consist of a residential dwelling. BEING PREMISES: 241 Old Stone House Road Carlisle, PA 17013 SOLD as the property of CASSIUS J. MULLEN and DEBORAH L. MULLEN TAX PARCEL #21-08-0571-009; 21-08-0571-015 Traet. '0. 1: All, that certain traot of l~d situate in Kiddie.ex '1'ownship, CUmbs/:'l/lnd County, penna)'l vania ,UlOl:'e parl::l.cularly bounded.nd desoribed in aocordanoe with a survey b1 Thomas A. Neff. ~.S., dated September 11, 1975, and revised Deoember 26. 1975( all follows. BEGINNING ..I: lilt iron pin on the eaetern dedicated X'ight of way line of Legislative :Route 21028. Ilaid i1:on pin being at the southwest CQrner of other land of John DuX'rman, IXI, thence along the eastern dedioated right of way line of Legislative :Routs 21028, North 44 degreell 38 minutes Weat 125.35 feet to a pointl thence along /I curve to the right with /I radius of 25 feet, an arO distance of 38.93 feet to a point on the eastern side of II proposed SO foot street; thenoe along the eastern side of a proposed so foot street, North 44 degrees 35 minutes 20 seconds East 269.30 feet to an iron ~iltl thence South {S degl:'ees 24 minutes 40 seconds Bast laO feet to an iron pin, thance along the western line of other property of John Durrman, %ll, South 44 degrees 35 minutes 20 seoonds West 29. feet to an iron pin on the eastern dedicated right of way line of Legislative Route 21029, the place of BEGINN!NG. CONTAtN!NG 1.012 acrell and being Lot Mo. 3A on the revised SUbdivision plan for Linden Hall Farms, recorded in the CUmberland County Reco~der of Deeds Office in Plan Book 27, Page 92. tINDER 1\ND SUBJECT, nevertheless, to l;'he conditions and restrictions more psX'ticularly set forth in Deed Boo~ "S., Volume ~~., . Pag.. 554. - . TlUl.CT fO. 2. ALL that C1el:'tain traot of land situate in Middlesex Townsh p, CUmberland County, Panneylvania. bounded and described according to e lltU:'Vey dated July 24, 1972, by '1'l10111~ A. Neff, Registered Surveyor, as follOWS' ~ BEGINNING at an iron pin at the eastern line of toeg:!.slat:!."e Route 21028 (50 feet w:!.de" and having an edsting right of ..s.y width of 33 feet), which sa.id beginning point is situated South 44 degrees 38 mi~utes East a distance of 594.04 femt from the corner of property of Paul W. Mugllelma~; chence form said beginning point by other prop&rty of Evelyn S. Roberts tbe ~ollowing three oourses and distances, (1) North 44 degrees 35 m:l.nutes 20 seco~ds East 296.00 feet to an iron pin; (2) South 4S degrees 24 minutes 40 seconds East 29..00 feet to an iron pin; (3) South 44 degrees 35 minutes 20 seoonds Wellt 29&.00 feet to an iron pin on the property line and 25 feet distant from the center line Of Legislative Route 21028; thence by said property line 25 feet distant from the center line of Legislative Route 21029 North 45 de~eee 24 minutes 40 seconds West 29G.00 feet to an iron pin, the place of !lBGINNING. CONTAIN%NG 2.011 aores. ONDER ~ SUBJECT, nevertheless, to the conditions and restricHons more particlIlarly set forth in need Soak "W",' Volume 24, Page 3$8. .."~_.t. T Traet 11'0. 1, All that eertdn traot of lllDd situate in M:l.ddlesex Township, CUmbsl:'land County, Pemuoylvan:l.a, UlO:I:'e particularly bounded. aad dascribed in aoc:ordanoll with a survey by Thomas A. Neff, R.S., dated Septemb8:1:' 11, 1~75, and revised Deoember 26, 1975,' .11 follOWS. BE<UNNtNG at an i.\"on pin on the ea. tam <lfldicated ri'iTht of way line of Legislative Route 21026, sai"- iron pin bein'iT at the Ifouth..est oorne:!:' of other land of John Pul:rm&n, UI I thence along the eastern dedioated right of way line of Legislative Route 21028, North 44 degrees 36 minutes West 125.35 feet to a pointl thence along a ourve to the ri'iTht with a l:'adius of 25 feet. an a:!:'c dietanee of 36.93 feet to a point on the eastern side of a proposed 50 foot street; thence along the eastern side of a proposed 50 foot atraet, NOl:th 44 degl:'ees 35 minutss 20 seconds East 26'.30 feet to an iron ~~nl thence South 45 deg~ees 24 min~te. 40 seconds Bast 150 feet to an ~ron pin, th~e8 alon'iT the western line of other p~operty of John Purrman, llX, South 44 de~rees 35 minutes 20 aecendS West 296 feet eo an ~ron pin on the eastern dedioated right of way line of Le~islative Route 21028, the place of BEQINNING. CONTAINU'!G ;1..012 aor'illl and baing Lot No. 3A on th.. rltvised ~division plan for Linden Hall Farms, recorded in the ~mberland County Rfilco,der of Deeds OffiCI! in Plan Book 27, Page 92. . tINDER AND SUBJECT, nevar~hel<!!sll. to thlll oonditions and restrictions more pal:'ticularly set forth in Deed Book "S., Volume .~!, . P-se 554. - . TRACT fO. 2. JILL that oerUin tl:8.ot of land situate in Middlesex 'Z'ownsh ~, CUmbarland Co1l.ll.ty, pannsylv.",ia, bounded and desoribltd aecoxding to I!l sw:'\'<I!Y dated Ju.l,y 24. 1972, by Thorn"" A. Neff, Registered surveyor, as follows. ~ BEGINNING at an iron pin at the eastern line of LegiSlative Route 21028 (50 feet wide" and having an existing right of way width of 33 feet), which said beginnin~ point is situated South 44 <legrees 38 minutes mast a distance of 5'4.04 feat ~rom the corner of propel:ty of ~aul W. Mulfselma~; thenoe form said b.gi~ng point by other property of Evelyn $. Roberts the following threa courses and dilltanoes. (1) }qorth 44 degrees 35 minutes 20 seconds East 296.00 feet to an iron pin; (2) South 4S degrees 24 minutes 40 seoonds East 296.00 feet to an iron pin; (3) South 44 degreos 3S minutes 20 seoonds West 296.00 feet to an iron pin on.the propel:ty line and 25 feet distant from the ollnter line of Legislstive Route 21028/ thence by said propel:ty line 25 feet distant from the cantel: line of Legislative Route 21028 NOl:'th 4S degrees 24 minutes 40 seoonds West 296.00 feet to an iron pin, the place of ElKGtNNtNG. CON'l'AIN%NG 2.011 Ml:'elil. ONDER AND SUBJEcr, nevertheless, to the conditions and restrictions more particularly set forth in Oeed Book "W",' Volume 24, Page 358. .._"--~-j.... T Tract lITo. 1. All that certain tract of lll!!1d situate ~n Mid.:Uesex '1'Q\flUIhip, Cumberland County, pennsylvania, more parl::l.cu;l.ar:ty bounded. ancl described in accordance witll a survey :by Thomas A. Neff, R.S., dated september 11, 1~75, and revised December 26, t975; .. follows I BEGINNING at an iron pin on the eastern dedicated right of way line of LGgielative Route ~102a, said iron pin baing at the southwest corner of other land of John OUrrman, XXI, thance along the e..tern dedicated right of way line of LegiSlative Rout. 2J.029, North 44 degrees 39 minutes West 125.35 feet to a point I thence dong a curve to the right with a radiul!. of 25 feet, lU1 arc distance of 39.~3 feet to II point on the eastern side of a proposed 50 foot street; thence along the eastern side of a proposed 50 foot street, North 44 de~ees 35 minutes ao seoonds Sast 26'.30 feet to an iron pinl thence South 45 ~~grees. 24 ~inutes 40 seconds Dast 150 feet to an iron pin, thAnce along the ~estern line of other property of John Durrman, XIl, South 44 degrees 3S minutes 20 seoonds West 296 feet to an iron pin on the eastern dGldicllted right of way line of Le9"illlal::l.ve Route 21028, the plaoe of BEGINNING. OONTAlNANG 1.012 acres and being Lot No. 3A on the revise~ ~bdivision plan for Linden Hall Farms, reco~ed in the CUmberland county RecoJ;',der of Deeds Offictl! in 1'lIIn Boole 27, Page ~2. . ONDER AND SUBJEcr. nevertheless, to ibe conditions and restrictions more particularly set forth in Deed Sook .S., VOlume . . ..~~,. 1'..g.. 554. - . TRACT liO. 2. ALL that certain traot of land IIituate in Midd1&selC Township, Cumberland County, pannsy1van:l.a, bounded and desoribtl!d according to a sUX'Vey dated July 24, 1972, bY'I'bomlilS A. Neff, Registaxed Surveyol:', as follows. ... BEGINNING at an iron pin at the> ..astern line of Leg1s1ative Route 21028 (SO feet wide,. and having an existing ri!iht of ws.y width of 33 feet), which said beginning point iEl situated South 44 degrees 38 mi~utes East a distance of 594.04 feet from the corner of property of ~aul W. Musselman; chence form said beginning point by other prop_rty of Evelyn S. Roberts the following three courses and distances. (1) North 44 degrees 35 mil\utes 20 seconds East 296.00 feet to an iron pin; (2) South 4S degrees 24 minutes 40 seoonds East 296.00 feet to an 1ron pin; (3) South 44 degreGs 3S minutes 20 seconds West 296.00 feet to an iron pin on the property line and 25 feet distant from the oenter line of Legislative Route 21028; thenoe by said property line 25 feet distant from the centex line of Legielative Route 21028 North 4S degrees 24 minutes 40 seoonds Weet 296.00 feet to an iron pin, the place of !lllGmNING. CO~XNING 2.011 aores. UNDER AND SttBJECT, nevertheless, to the conditions and restriotions more particularly set forth in Peed Sook "W.,' Volume 24, 1>age 358. --~j. ~~:-.- Traet )10. 1, All thll.t certain traot of lZl!1d dl:uate in M:iddlellex TO\ftUIhip,CUmberlllnd. County, Pennsylvania, mo:re part:l.cularly ))ounded Md d.scribed. in aQcordanee with a lIurvey br Thomas A. Neff, ~.S., dated September 11, 1915, and revised Oecember 26. 1"5,' as followsl 13EGtNNXNG ..I: an U'on pin on the eaet..:m dedicated right of wer.y line of Legislative Rout:e 21026, said ix-on pin being at thll southwest aorner of other land of John ~t'lnII1t. UI, thenoe along the eastern dedioated right of way line of Legislative Route 21028, North 44 degrees 36 minutes West 125.35 feet to a point I thenoe along a curve to the right with a radius of 25 feet. an arc d1l1tMee of 36.93 feet to .. point: on the eastern side of a proposed 50 foot street; theMe along the eastern side of a proposed 50 foot street, North 44 del1:t:ells 35 minutes 20 seoonds masc 269.30 feet to an iron pin; thenoe South 4S degrees 24 minutes 40 seconds Bast 150 feet to an iron pin, theucs along the ~stern line of other property of John Dur~n. XIX, South 44 dagrGes 3S minutes 20 aeoonds West 296 feet to an iron pin on the eastern dedioated right of way line of Legislative Route 2102B, the place of BEGINNING. CONTAINItlG 1.012 acres and being Lot No. 3A on the revised SUbdivision plan for Linden Hall Farms. recorded in the Cumberland County Reeo~der of Oeeds Office in Plan Book 27, Page 92. ONDER AND SUBJECT, nevertheless, to the oonditions and restriotions more particularly set forth in Deed Book .S., Volume ~l1, . p...se 554. - . ~CT NO. 2. At.L that oertain tract of l..nd situate in Middlesex Township, CUmberland County, Penn.yl~ania. bounded and described lloco2:dinSJ to a S1U'V'ey dated oJUJ.y 24, J.972. by Thom.,a A. Neff, Registered Surveyor, aa followe, ~ BBGIN'NINa at an iron pin at the eastern line of Le<;lis1"I::1"e Route 21028 (50 feet wide,. and having an existing right of way width of 33 feet), whieb B.id beginning point is situated South 44 degrees 38 minutes Sast a distanoe of 594.04 feet from the corner of property of J?aul W. Musselman; thence form add begiMing point by other l?=perty of E"elyn S. Roberts tM following three courses and distanoes, (1) North 44 degrees 35 minutes 20 seconds East 296.00 feet to an iron pin; (2) South 45 degrees 24 minutes 40 seoonds East: 296.00 feet to an iron pin; (3) South 44 degrees 35 minutes 20 sllconda West 296.00 feet to an iron pin on the property line and 25 feet distant from the oenter line of LegiSlative Route 21028; thenoe by said property line 25 feet distant from the center line of Legislative Route 21028 North 4S degrees 24 minutes 40 seconds Weet 29S.00 feet to an iron pin, the place of l!ll:G:tNN:tNG. CONTAINtNG 2.011 aoree. UNDER AND SUBJECT, neverthelees. to the conditions and reliltr:l.etions more particularlY set forth in Peed Book "1'1.,' Volume 24, Page 358. '.'~~___',J.. --T- Tract No.1, All that certain traot of bnd a.l.l:ual:e :La Middlesex 'I'Q1mShip, CUmb&X'land. eounty, PeMsyJ.van:La, mol."e part:icularJ.y bounded <<t1d d.sodbed in aoeordanee with II survey :by Thomaa A. Neff, ~:S., dated September 11, 1975, and ~v:l.sed December 26. :1.975,' as follows. JEGtNNXNG al: an iron pin on the eastern dedicated ri~ht of way line of Legislatl....... Roul:e 2:1.026, said it'on pin bein~ at the southwest cot'nl!r of other land of John Dur~. tII, thence along the eastern dedioated right of way line of Lesislat:l.V$ Rout. 21028, North 44 degrees 36 minutes West 125.35 feet to a pointl thence along a eurve to the right with a radius of 25 feet, an arc distanoe of 38.93 feet to a point on the eastern side of a proposed 50 foot street; thence along the eastern side of a propos.a 50 foot atr..et, North 44 d.egreea 35 minutes ::0 seconds Sast 2~'.30 feet to an iron ~in; thence Sou~h 45 degrees 24 lninl.ltes 40 seconds Dast lS0 feet to an il'ol1 l'inl thane.. along th.. western line of other p%operty of John Durrman, II!, South 44 degrses 3S minutes 20 seconds West 296 feet to an iron pin on the eastern dedicated right of way line of Legislative Route 21028, the plaoe cf BEGINNING. CONTAINING ;1..012 acres and being Lot Mo. 3A on the revised DUbdivision plan for Linden Hall Farms, recorded in the CUmberland County Reoo~der of Oeeds Office in Plan Book 27, Page 92. ONIlIi1R AND SUBJECT, nevertheless, to t'hlll conditions and restriotions more particularly set forth in Deed Sook .S., Volume :;!~, Pllse 554. - . TlU!.CT fl:). 21 ALL that Qertain tt'Zlct of land l!Iitu<<te in Middles.lC 'l.'ownsh p, CUmberland County, pennsylvania, bounded .nel desClribed according to a sUJ:'II'ey dat.d July 24, 1972, by 'I'nom..,a A. Neff, Registered Surveyor, as follOWS. ~ BBGINNING at an iron pin at th.. eutern line of Legislativ. Rou.t.. 21028 (50 f....t wid.." and having an existing right of way width of 33 feet), whieh said beginning point ia ".l.tuat..d South 44 deg%ees 38 minutes Sast a distanoe of 594.04 feet f~om the corner of property of Paul W. Musselmal:ll thence form ..aid beginning point .by other prol'"lrt:y of Evelyn S. Robelrt:s th.. following three couraes and distance." (1) North 44 deg:r:eell 35 llIinutea 20 seconds mast 296.00 feet to an iron pin; (2) SOuth 4S degrees 24 minutes 40 seconda East 296.00 feet to an i%on pin; (3) South 44 degrees 35 minutes 20 seeond.s West 296.00 feet to an iron pin on the property linl!> and 2S feet distant from t.he center line of LegiSlative Route 21028; thence by said property linl!> 25 feet distant from th.. center line of ~e9islative Route 21028 North 45 degrees 24 minutes 40 seconds Weet ~96.00 feet to an iron pin, the place of BEGINNING. CONTAINING 2.011 acres. ~BR ANO SUBJECT, nevertheless, to tne Clond.itions and restrictions more particularly set forth in Oeed Sook 'w.,' Volume 24, l?age 358. - ---______.J '~ --- SHERIFF'S DEPARTMENT COUNTY SHERIFF SERVICE INSTRUCTIONS PLAINTIFFISI COURT NUMBER M&T MORTGAGE CORPORATION 04-2740 DEFENDANTISI TYPE OF WRIT OR COMPLAINT CASSIUS J. MULLEN and DEBORAH L. MULLEN NOTICE OF SALE I SERV) NAME OF INDIVIDUAL. COMPANY, CORPORATION, ETC., TO SERVICE DEBORAH L. MULLEN ADDRESS (Street or Road, Apartment No., City, Boro, Twp., State and ZIP Code) 241 Old Stone House Road, Carlisle, PA 17013 AT SPECIAL INSTRUCTIONS OR OTHER INFORMATION THAT WILL ASSIST IN EXPEDITING SERVICE: PLEASE SERVE THE ABOVE DEFENDANT OR PERSON IN CHARGE SIGNATURE OF ATTORNEY TELEPHONE NUMBER DATE Ja;eph ..A. (Jaldieck, Jr. (215) 627-1322 September 17,2004 ADDRESS OF ATTORNEY GOLDBECK McCAFFERTY & McKEEVER Suite 500 - The Bourse Bldg. 111 S. Independence Mall East Philadelphia, PA 19106 f . 04-2740 GOLDBECK McCAFFERTY & McKEEVER BY: Joseph A. Goldbeck, Jf. Attorneyl.D.#16l32 Suile 5000- Mellon Independence Center 701 Market Street Philadelphia, P A 19106 215-627-1322 Attorney for Plaintiff M&T MORTGAGE CORPORATION PO Box 840 Buffalo, NY 14240-0840 IN THE COURT OF COMMON PLEAS of Cumberland County Plaintiff vs. CIVIL ACTION - LAW CASSIUS J. MULLEN DEBORAH L. MULLEN Mortgagor(s) and Record Owner(s) ACTION OF MORTGAGE FORECLOSURE 241 Old Stone House Road Carlisle, P A 17013 Term No. 04-2740 Defendant(s THIS LAW FIRM IS A DEBT COLLECTOR AND WE ARE ATTEMPTING TO COLLECT A DEBT. THIS NOTICE IS SENT TO YOU IN AN ATTEMPT TO COLLECT A DEBT. ANY INFORMATION OBTAINED FROM YOU WILL BE USED FOR THAT PURPOSE. NOTICE OF SHERIFF'S SALE OF REAL PROPERTY TO: MULLEN. DEBORAH L. DEBORAH L. MULLEN 241 Old Stone House Road Carlisle, P A 17013 Your house at 241 Old Stone House Road, Carlisle, PA 17013 is scheduled to be sold at Sheriffs Sale on Wednesday, March 02,2005, at 10:00 AM, in Commissioners Hearing Rm 2nd FL Courthouse to enforce the court judgment of $261 ,958.28 obtained by M&T MORTGAGE CORPORATION against you. NOTICE OF OWNER'S RIGHTS YOU MAY BE ABLE TO PREVENT THIS SHERIFF'S SALE To prevent this Sheriffs Sale you must take immediate action: l. The sale will be cancelled if you pay to M&T MORTGAGE CORPORATION, the back payments, late charges, costs and reasonable attorney's fees due. To find out how much you must pay call: 215-627-1322 2. You may be able to stop the sale by filing a petition asking the Court to strike or open judgment, if the judgment was improperly entered. You may also ask the Court to postpone the sale for good cause. f 04-2740 3. You may also be able to stop the sale through other legal proceedings. You may need an attorney to assert your rights. The sooner you contact one, the more chance you will have of stopping the sale. (See notice below on how to obtain an attorney). YOU MAY STILL BE ABLE TO SAVE YOUR PROPERTY AND YOU HAVE OTHER RIGHTS EVEN IF THE SHERIFF'S SALE DOES NOT TAKE PLACE. I. If the Sheriffs Sale is not stopped, your property will be sold to the highest bidder. You may find out the price bid price by calling the Sheriff of7l7-240-6390. 2. You may be able to petition the Court to set aside the sale if the bid price was grossly inadequate compared to the value of your property. 3. The sale will go through only if the buyer pays the Sheriff the full amount due in the sale. To fmd out if this has happened, you may call the Sheriff of7I7-240-6390. 4. If the amount due from the Buyer is not paid to the Sheriff, you will remain the owner of the property as if the sale never happened. 5. You have a right to remain in the property until the full amount due is paid to the Sheriff and the Sheriff gives a deed to the buyer. At that time, the buyer may bring legal proceedings to evict you. 6. You may be eutitled to a share of the money which was paid for your house. A schedule of distributiou of the mouey bid for your house will be filed by the Sheriff thirty (30) days from the date of the Sheriffs Sale. This schedule will state who will be receiving that money. The money will be paid out in accordance with this schedule unless exceptions (reasons why the proposed distribution is wrong) are filed with the Sheriff within ten (10) days after the schedule of distribution is filed. 7. You may also have other rights and defenses, or ways of getting your house back, if you act immediately after the sale. YOU SHOULD TAKE THIS PAPER TO YOUR LAWYER AT ONCE. IF YOU DO NOT HAVE A LAWYER OR CANNOT AFFORD ONE, GO TO OR TELEPHONE THE OFFICE LISTED BELOW TO FIND OUT WHERE YOU CAN GET LEGAL HELP. LEGAL SERVICES INC 8 Irvine Row Carlisle, PA 17013 CUMBERLAND COUNTY BAR ASSOCIATION 2 Liberty Avenue Carlisle, PA 17013 SHERIFF'S DEPARTMENT COUNTY SHERIFF SERVICE INSTRUCTIONS PLAINTIFFISI M&T MORTGAGE CORPORATION COURT NUMBER 04-2740 DEFENDANTISI CASSIUS J. MULLEN and DEBORAH L. MULLEN TYPE OF WRIT OR COMPLAINT NOTICE OF SALE y NAME OF INDIVIDUAL. COMPANY. CORPORATION. ETC., TO SERVICE CASSIUS J. MULLEN ADDRESS (Street or Road, Apartment No., City, Bora, Twp., State and ZIP Code) 241 Old Stone House Road, Carlisle, PA 17013 AT SPECIAL INSTRUCTIONS OR OTHER INFORMATION THAT Will ASSIST IN EXPEDITING SERVICE: PLEASE SERVE THE ABOVE DEFENDANT OR PERSON IN CHARGE SIGNATURE OF ATTORNEY TELEPHONE NUMBER DATE Jojeph A. {jo!dlm/', Jr. (215) 627-1322 September 17, 2004 ADORE SS OF ATTORNEY GOLDBECK McCAFFERTY & McKEEVER Suite 500 - The Bourse Bldg. 111 S. Independence Mall East Philadelphia, PA 19106 : 04-2740 , 1 GOLDBECK McCAFFERTY & McKEEVER BY: Joseph A. Goldbeck, Jr. Attorney l.D.#16132 Suite 5000- Mellon Independence Center 701 Market Street Philadelphia, P A 19106 215-627-1322 Attorney for Plaintiff M&T MORTGAGE CORPORATION PO Box 840 Buffalo, NY 14240-0840 IN THE COURT OF COMMON PLEAS of Cumberland County Plaintiff vs. CIVIL ACTION - LAW CASSIUS 1. MULLEN DEBORAH L. MULLEN Mortgagor(s) and Record Owner(s) ACTION OF MORTGAGE FORECLOSURE 241 Old Stone House Road Carlisle, P A 17013 Term No. 04-2740 Defendant(s THIS LAW FIRM IS A DEBT COLLECTOR AND WE ARE ATTEMPTING TO COLLECT A DEBT. THIS NOTICE IS SENT TO YOU IN AN ATTEMPT TO COLLECT A DEBT. ANY INFORMATION OBTAINED FROM YOU WILL BE USED FOR THAT PURPOSE. NOTICE OF SHERIFF'S SALE OF REAL PROPERTY TO: MULLEN, CASSIUS J. CASSIUS J. MULLEN 241 Old Stone House Road Carlisle, PA 17013 Your house at 241 Old Stone House Road, Carlisle, P A 17013 is scheduled to be sold at Sheriffs Sale on Wednesday, March 02, 2005, at 10:00 AM, in Commissioners Hearing Rm 2nd FL Courthouse to enforce the court judgment of$261,958.28 obtained byM&T MORTGAGE CORPORATION against you. NOTICE OF OWNER'S RIGHTS YOU MAY BE ABLE TO PREVENT THIS SHERIFF'S SALE To prevent this Sheriffs Sale you must take immediate action: I. The sale will be cancelled if you pay to M&T MORTGAGE CORPORATION, the back payments, late cbarges, costs and reasonable attorney's fees due. To find out how much you must pay call: 215-627-1322 2. You may be able to stop the sale by filing a petition asking the Court to strike or open judgment, if the judgment was improperly entered. You may also ask the Court to postpone the sale for good cause. . 04-2740 3. You may also be able to stop the sale through other legal proceediogs. You may need an attorney to assert your rights. The sooner you contact one, the more chance you will have of stopping the sale. (See notice below on how to obtain an attorney). YOU MAY STILL BE ABLE TO SAVE YOUR PROPERTY AND YOU HAVE OTHER RIGHTS EVEN IF THE SHERIFF'S SALE DOES NOT TAKE PLACE. I. If the Sheriffs Sale is not stopped, your property will be sold to the highest bidder. You may fmd out the price bid price hy calling the Sheriff of717-240-6390. 2. You may be able to petition the Court to set aside the sale if the bid price was grossly inadequate compared to the value of your property. 3. The sale will go through only if the buyer pays the Sheriff the full amount due in the sale. To fmd out if this has happened, you may call the Sheriff of717-240-6390. 4. If the amount due from the Buyer is not paid to the Sheriff, you will remain the owner of the property as if the sale never happened. 5. You have a right to remain in the property until the full amount due is paid to the Sheriff and the Sheriff gives a deed to the buyer. At that time, the buyer may bring legal proceedings to evict you. 6. You may be entitled to a share ofthe money which was paid for your house. A schedule of distribution of the money bid for your house will be filed by the Sheriff thirty (30) days from the date of the Sheriffs Sale. This schedule will state who will be receiving that money. The money will be paid out in accordance with this schedule unless exceptions (reasons why the proposed distribution is wrong) are filed with the Sheriff within ten (10) days after the schedule of distribution is filed. 7. You may also have other rights and defenses, or ways of getting your house back, if you act immediately after the sale. YOU SHOULD TAKE THIS PAPER TO YOUR LAWYER AT ONCE. IF YOU DO NOT HAVE A LAWYER OR CANNOT AFFORD ONE, GO TO OR TELEPHONE THE OFFICE LISTED BELOW TO FIND OUT WHERE YOU CAN GET LEGAL HELP. LEGAL SERVICES lNC 8 Irvine Row Carlisle, P A 17013 CUMBERLAND COUNTY BAR ASSOCIATION 2 Liberty Avenue Carlisle, PA 17013