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Home My WebLink About01-4770GOLDBECK McCAFFERTY & McKEEVER BY: JOSEPH A. GOLDBECK, JR. ATTORNEY I.D. #16132 SUITE 500 - THE BOURSE BLDG. 111 S. INDEPENDENCE MALL EAST PHILADELPHIA, PA 19106 (215) 627-1322 ATTORNEY FOR PLAINTIFF COUNTRYWIDE HOME LOANS INC. F/K/A COUNTRYWIDE FUNDING CORP. 7105 Corporate Drive PTX B-35 Plano, TX 75024-3632 Plaintiff VS. SUN V. KARAS EDWARD W. KARAS Mortgagor(s) and Real Owner(s) 1029 Swarthmore Road New Cumberland, PA 17070 Defendant(s) IN THE COURT OF COMMON PLEAS OF Cumberland COUNTY CIVIL ACTION - LAW ACTION OF MORTGAGE FORECLOSURE Term ~ No. ~[ ~- Z/770 GIVIL ACTION: MORT~AOE FORECLOSURE 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 entering a wtitten appearance personally or by attorney and filing in writing with the coult your defenses or objections to the claims set forth against you. You are warned that if you fail to do so the case may proceed without you and a judgment may be entered against you by the Courl without further notice for any money claim in the Complaint of for any other claim or rebel requested by the Plathtiff. You may lose money or property or other rights impoltant to you, YOU SHOULD TAKE THIS POPER TO YOUR LAWYER AT ONCE. IF YOU DO NOT HAVE A LAWYER OR CANNOT AFFORD ONE, GO TO OR TELEPHONE TIIE OFFICE SET FORTH BELOW TO FIND OUT WHERE YOU CAN GET LEGAL HELP. CUMBERLAND COUNTY BAR ASSOCIATION 2 Liberty Avenue Carlisle, PA 17013 LEGAL SERVICES INC 8 Ir,fine Row Carlisle, PA 17013 717-243-9400 AVISO LE HAN DEMANDADO A USTED EN LA CORTE. SI DESEA DEFENDERSE CONTRA LAS QUEJAS PERESENTADAS, ES ABSOLUTAMENTE NECESSARIO QUE USTED RESPONDA DENTRO DE 20 DIAS DESPUES DE SER SERVIDO CON ESTA DEMANDA Y AVISO. PARA DEFENDERSE ES NECESSARIO QUE USTED, O SU ABOGADO, REGISTRE CON LA CORTE EN FORMA ESCRITA, EL PUNTO DE VISTA DE USTED Y CUALQUIER OB JECCION CONTRA LAS QUEJAS EN ESTA DEMANDA. RECUERDE: SI USTED NO REPONDE A ESTA DEMANDA, SE pUEDE PROSEGUIR CON EL PROCESO SIN SU PARTICIPACION. ENTONCES, LA COUTE PUEDE, SIN NOTIFICARIO, DECIDIR A FAVOR DEL DEMANDANTE Y REQLrERI RA QUE USTED CUMPLA CON TODAS LAS PROVISIONES DE ESTA DEMANDA. POR RAZON DE ESA DECISION, ES POSSIBLE QUE USTED PUEDA PERDER DINERO, PROPIEDAD U OTROS DERECHOS IMPORTANTES. LLEVE ESTA DEMANDA A UN ABOGADO IMMEDIATEAMENTE. SI NO CONOCE A UN ABOGADO, LLAME AL "LAWYER REFERENCE SERVICE" (SERVICIO DE REFERENCIA DE ABOGADOS), (215) 238-6300. CUMBERLAND COUNTY BAR ASSOCIATION 2 Libeay Avenue Carlisle, PA 17013 LEGAL SERVICES INC 8 Brine Row Carlisle, PA 17013 717-243-9400 COMPLAINT IN MORTGAGE FORECLOSURE 1. Plaintiffis COUNTRYWIDE HOME LOANS INC. F/K/A COUNTRYWIDE FUNDING CORP., 7105 Corporate Drive, PTX B-35 Piano, TX 75024-3632. 2. The name(s) and address(es) of the Defendant(s) is/are SUN V. KARAS, 356 Old Baltimore Pike, Newark, DE 19702 and EDWARD W. KARAS, 356 Old Baltimore Pike, Newark, DE 19702, who is/are the mortgagor(s) and real owner(s) of the mortgaged premises hereinafter described. On January 25, 1993 mortgagor(s) made, executed and delivered a mortgage upon the premises hereinafter described to BANK UNITED OF TEXAS FSB, which mortgage is recorded in the Office of the Recorder of Deeds of Cumberland County as Book 1115 Page 537. The mortgage has not been assigned unless said assignment to the Plaintiff is hereafter mentioned. The aforementioned mortgage was assigned to: COUNTRYWIDE HOME LOANS 1NC. F~UA COUNTRYWIDE FUNDING CORP. by Assignment of Mortgage dated June 08, 1995 and recorded on August 04, 1995 as Book 501 Page 186; and 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. The mortgage is in default because monthly payment of principal and interest upon said mortgage due December 01, 2000, 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 11/01/2000 through 08/31/2001 at 8.3750% Per Diem interest rate at $17.69 Attorney's Fee at 5.0% of Principal Balance Late Charges from 12/01/2000 to 08/31/2001 Monthly late charge amount at $31.38 Costs of suit and Title Search Escrow Monthly Escrow amount $146.93 $77,107.36 $5,377.76 $3,855.37 $282.41 $750.00 $87,372.90 $o.oo $87,372.90 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 Sheriff's Sale. If the Mortgage is reinstated prior to the Sale reasonable Attorney's Fees will be charged based on work actually performed. Notice of Intention 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 tree and correct copy of such notice(s) attached hereto as Exhibit "A". The Defendant(s) has/have not had the required face-to-face meeting within the required time and Plaintiff has no knowledge of any such meeting being requested by the Defendant(s) through the Plaintiff, the Pennsylvania Housing Finance Agency, or any appropriate Consumer Credit Counseling Agency. WHEREFORE, Plaintiff demands judgment in mortgage foreclosure in the sum of $87,372.90, together with interest at the rate of $17.69, per day and other expenses incurred by the Plaintiff which are properly chargeable in accordance with the terms of the mortgage, and for the foreclosure and sale of the mortgaged premises. By: Gg~I~BEC~i[ McCAFFERTY ~ McKEEVER B~. JOSEPH A. GO[OBEC~:, J}~., ESQUI ATTOK~qEY FOR PL^mTIFF VERIFICATION I, Michael Vestal, 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 tree 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 uns~'om falsification to authorities. M~chael~ Vestal Countrywide Home Loans ALL THAT CERTAIN LOT OF LAND SITUATE IN THE BOROUGH OF NEW CUMBERLAND, COUNTY OF CUMBERLAND AND STATE OF PENNSYLVANIA, BOUNDED AND DESCRIBED AS FOLLOWS, TO WIT: BEGINNING AT A POINT ON THE NORTHERLY LINE OF SWARTHMORE ROAD, SAID POINT BEING LOCATED 937.54 FEET MEASURED EASTWARDLY ALONG SAID LINE FROM THE NORTHEAST CORNER OF SWARTHMORE ROAD AND DREXEL HILLS BOULEVARD; THENCE NORTHWARDLY AT RIGHT ANGLES AND ALONG THE EASTERLY LINE OF LoT NO. 12, BLOCK "A", ON THE HEREINAFTER MENTIONED PLAN 105.00 FEET TO A POINT; THENCE NORTH 89 DEGREES 14 MINUTES EAST ALONG LINE OF LANDS NOW OR FORMERLY OF ELMER E. ZIMMERMAN, 65.00 FEET TO A POINT; THENCE SOUTHWARDLY AT RIGHT ANGLES AND ALONG THE WESTERLY LINE OF SWARTHMORE ROAD; THENCE BY THE LATTER SOUTH 89 DEGREES 14 MINUTES WEST, 65.00 FEET TO THE PLACE OF BEGINNING. BEING LOT NO. 13, BLOCK "A", ON THE PLAN OF LOTS oF SECTION I, HIGHLAND PARK HILLS AND DREXEL HILLS, SAID PLAN BEING RECORDED IN THE CUMBERLAND COUNTY RECORDER'S OFFICE IN PLAN BOOK 7, PAGE 23. HAVING THEREON ERECTED A DWELLING HOUSE, BRICK AND ~RAME BI-LEVEL,I KNOWN AND NUMBERED AS ! 029 SWARTHMORE ROAD, NEW CUMBERLAND, PENNSYLvANiAy BEING THE SAME PREMISES WHICH YONG HO Yt AND KUM HUI YI, HUSBAND A~ND WIFE BY THEIR DEED DATED JANUARY 25, 1993 AND INTENDED TO BE RECORDED IMMEDIATELy PRIOR HERETO, GRANTED AND CONVEYED UNTO EDWARD W. KARAs AND SUN UN KARAS, H ~ - .......... USBAND AND WIFe;, MORTGAGORS HERgI-N_ May 02, 2001 Sun V. Karas 1029 Swarthmore Road New Cumberlan(~ PA. 17070 EXHIBIT A Certified Mail No. Return Receipt Requested Regular Mail Countrywide Account # 3138241 Property Address: 1029 Swarthmore Road New Cumberland, PA. 17070 Current Servicer: Countrywide Home Loans, Inc. ACT 91 NOTICE TAKE ACTION TO SAVE YOUR HOME FROM : FORECLOSURE This Is an pfflclal notice that the mortqage on your home is in default, and the lender intends to foreclose. Soeclflc Information about the nature of the default Is provided in the attached oaaes. The HOMEOWNER'S EMERGENCY MORTGAGE ASSISTANCE PROGRAM (HEMAP) may be able to held to save your home. This Notice exolains how the oroeram Works. TO see If HEMAP can helD. you must MEET WITH A CONSUMER CREDIT COUNSELING AGENCY WITHIN 30 DAYS OF THE DATE OF THiS NOTICE. Take this Notice with you when you meet withr~e Counseling Agency. The names, addresses and phone numbers of Consumer Credit Counselinq Aqencies serving your County are listed at the end of this Notice. If you have any questions, you may call the PennsvIvanla Housine Finance Aaencv toll.free at 1-800-342-2397. ;Persons with Imoalred heartna can call 1-717-780-f869.1 This Notice contains important legal information. If you have any questions, representedves a{ the Consume~ Credit Counseling Agency may be able to help answer them. You may also want to cbntact an attorney in your area. The local bar association may be able to help you find a lawyer. LA NOTIFICACI~)N EN AD JUNTO ES DE SUMA IMPORTANCIA, PUES AFECTA SU DERECHO A CONTINUAR VIVIENDO EN SU CASA. SI NO COMPRENDE EL CONTENIDO DE ESTA NOTIFICACION OBTENGA UNA TRADUCCION INMEDIATAMENTE LLAMANDO ESTA AGENCIA (PENNSYLVANIA HOUSING FINANCE AGENCY) SIN CARGOS AL NOMERO MENCIONADO ARRIBA. PUEDE SER ELEGIBLE PARA UN PRr~STAMO POR EL PROGRAMA LLAMADO "HOMEOWNER'S EMERGENCY MORTGAGE ASSISTANCE PROGRAM" EL CUAL PUEDE SALVAR SU CASA DE LA PERDIDA DEL DERECHO A REDIMIR SU HIPOTECA. HOMEOWNER'S EMERGENCY MORTGAGE ASSISTANCE PROGRAM YOU MAY BE ELIGIBLE FOR FINANCIAL ASSISTANCE WHICH CAN SAVE YOUR HOME FROM FORECLOSURE AND HELP YOU MAKE FUTURE MORTGAGE PAYMENTS. IF YOU COMPLY WITH THE PROVISIONS OF THE HOMEOWNER'S EMERGENCY MORTGAGE ASSISTANCE ACT OF 1983 (THE "ACT"), YOU MAY BE ELIGIBLE FOR EMERGENCY MORTGAGE ASSISTANCE: IF YOUR DEFAULT HAS BEEN CAUSED BY CIRCUMSTANCES BEYOND YOUR CONTROL, Please wrrte your loan number on all checks and correspondence. 6r26/20oo · TOTDUE~ AS OF ~DUEDTE~ P.O. Box .PYPOBX~ ~PYCSTZ~ <<BARCDE>> ~WKSCAN] IF YOU HAVE A REASONABLE PROSPECT OF BEING ABLE TO PAY YOUR MORTGAGE PAYMENTS, AND IF YOU MEET OTHER ELIGIBILITY REQUIREMENTS ESTABLISHED BY THE PENNSYLVANIA HOUSING FINANCE AGENCY. AYMENT INSTRUCTIONS Make ~ur check payable to Countrywide Home Loans Wdte in any addiaonal amounts y~J are including. (if total is mom than $5000, please send certi~d check) · Don't attach your check to the payment co~pon · Don't include cerre~pandence · Don't send cash Send Correspondence to: May02,2001 Cer[ified Mail No. Return Receipt Requested Regular Mail Sun V. Karas 356 Old Baltimore Pike Newark, DE.19702 Countrywide Account # 3138241 Propen'y Address: 1029 Swarthmore Road New Cumberland, PA. 17070 Current Servicer: Countrywide Home Loans, Inc. ACT 91 NOTICE TAKE ACTION TO SAVE YOUR HOME FROM FORECLOSURE This Is an official notice that the mortaaQe on your home is in default~ and*the lender intends to foreclose. Specific information about the nature of the default Is provided In the attached Daaes. The HOMEOWNER'S EMEI~GENCY MORTGAGE ASSISTANCE PROGRAM (HEMAPI may be able to hele to save your home. This Notice explains how the Drooram works. To see if HEMAP can helo. you must MEET WITH A CONSUMER CREDIT COUNSELING AGENCY WITHIN 30 DAYS OF THE DATE OF THIS NOTICE. Take this Notice with you when you meet with the CounselinQ Aeencv. The names, addresses and ohone numbers of Consumer Credit Counselin~l A~encles servina your County are listed at the end ofthls Notice. If you have any (luestions, you may call the Pennsylvania Houslna Finance Aqency toll-free at 1.800-342-2397. (Persons with ImDalred hearine can call 1-717-780-1869.1 This Notice contains important legal information. If you have any questions, representatives at the Consumer Credit Counseling Agency may be able to help answer them. Yot~may also want to contact an attorney in your area. The local bar association may be able to help you find a lawyer. LA NOTIFICACti~N EN AD JUNTO ES DE SUMA IMPORTANClA, PUES AFECTA SU DERECHO A CONTINUAR VIVIENDO EN SU CASA. SI NO COMPRENDE EL CONTENIDO DE ESTA NOTIFICACI~)N OBTENGA UNA TRADUCCI(~N INMEDIATAMENTE LLAMANDO ESTA AGENCIA (PENNSYLVANIA HOUSING FINANCE AGENCY) SIN CARGOS AL NOMERO MENClONADO ARRIBA. PUEDE SER ELEGIBLE PARA UN PR~STAMO POR EL PROGRAMA LLAMADO "HOMEOWNER'S EMERGENCY MORTGAGE ASSISTANCE PROGRAM" EL CUAL PUEDE SALVAR SU CASA DE LA PERDIDA DEL DERECHO A REDIMIR SU HIPOTECA. HOMEOWNER'S EMERGENCY MORTGAGE ASSISTANCE PROGRAM YOU MAY BE ELIGIBLE FOR FINANCIAL ASSISTANCE WHICH CAN SAVE YOUR HOME FROM FORECLOSURE AND HELP YOU MAKE FUTURE MORTGAGE PAYMENTS. IF YOU COMPLY WITH THE PROVISIONS OF THE HOMEOWNER'S EMERGENCY MORTGAGE ASSISTANCE ACT OF 1983 (THE "ACT"). YOU MAY BE ELIGIBLE FOR EMERGENCY MORTGAGE ASSISTANCE: IF YOUR DEFAULT HAS BEEN CAUSED BY CIRCUMSTANCES BEYOND YOUR CONTROL, Pleasewr~eyoutloaanumberonallche~sandcoffesponden~ P.O. Box <<PYPOBX~ ~PYCSTZ~ <<BARCDE>> hWKSCANlq IF YOU HAVE A REASONABLE PROSPECT OF BEING ABLE TO PAY YOUR MORTGAGEPAYMENTS, AND IF YOU MEET OTHER ELIGIBIMTYREQUIREMENTS ESTABLISHED BY THE PENNSYLVANIA HOUSING FINANCE AGENCY. AYMENT INSTRUCTIONS Please Make your check payable to CountG, w~e Home Loans Write your loan number on your check or money order Write in any additional amounts you are i~luding. (If Io~1 is mom than $5C~0, please send certified check.) May 02, 2001 Edward W. Karas 1029 Swarthmore Road New Cumbedand, PA. 17070 Certified Mail No. Return Receipt Requested Regular Mail Countrywide Account # 313824~ Property Address: 1029 Swarthmore Road New Cumberland, PA. 17070 Current Servicer: Countrywide Home Loans, Inc. ACT 91 NOTICE TAKE ACTION TO SAVE YOUR HOME FROM FORECLOSURE This Is an official notice that the morteaae on your home is In defauitr and the lender intends to foreclose. Specific Information about the nature of the default is provided In the attached Daues. The HOMEOWNER'S EMERGENCY MORTGAGE ASSISTANCE PROGRAM (HEMAP} may be able to I~eb) l~o save- your home. This Notice ex~laios how the oro=rem works. To see If HEMAP can helD. you must MEET WITH A CONSUMER CREDIT COUNSEMNG AGENCY WITHIN 30 DAYS OF THE DATE OF THIS NOTICE. Take this Notice with you when you meet with the Counseling Aqency. The names, addresses and Dhone numbers of Consumer Credit Counselinu A=encles servine your County are listed at the end of this Notice. If you have any questions, you may call the Pennsylvania Housing Finance A(~encv toll-free at 1-800-342.2397. tPersons with Impaired healing can call f-717-780-f869.) This Notice contains important legal information, If you have any questions, representatives at the Consumer Credit Counseling Agency may be able to help answer them. You may also want to contact an attorney in your area. The local bar association may be able to help you find a lawyer. LA NOTIFICACI~N EN AD JUNTO ES DE SUMA IMPORTANCIA, PUES AFECTA SU DERECHO A CONTINUAR VIVIENDO EN SU CASA. SI NO COMPRENDE EL CONTENIDO DE ESTA NOTIFICACI~N OBTENGA UNA TRADUCCION INMEDIATAMENTE LLAMANDO ESTA AGENCIA (PENNSYLVANIA HOUSING FINANCE AGENCY) SIN CARGOS AL NOMERO MENCIONADO ARRIBA. PUEDE SER ELEGIBLE PARA UN PRI~STAMO POR EL PROGRAMA LLAMADO "HOMEOWNER'S EMERGENCY MORTGAGE ASSISTANCE PROGRAM" EL CUAL PUEDE SALVAR SU CASA DE LA PERDIDA DEL DERECHO A REDIMIR SU HIPOTECA. HOMEOWNER'S EMERGENCY MORTGAGE ASSISTANCE PROGRAM YOU MAY BE ELIGIBLE FOR FINANCIAL ASSISTANCE WHICH CAN SAVE YOUR HOME FROM FORECLOSURE AND HELP YOU MAKE FUTURE MORTGAGE PAYMENTS. IF YOU COMPLY WITH THE PROVISIONS OF THE HOMEOWNER'S EMERGENCY MORTGAGE ASSISTANCE ACT OF 1983 (THE "ACT"), YOU MAY BE ELIGIBLE FOR EMERGENCY MORTGAGE ASSISTANCE: IF YOUR DEFAULT HAS BEEN CAUSED BY CIRCUMSTANCES BEYOND YOUR CONTROL, Please write your loan number on all checks and correspondence. P.O. Box <<PYPOBX)) <(PYCSTZ:~ <<BARCDE>> hWKSCAN~ IF YOU HAVE A REASONABLE PROSPECT OF BEING ABLE TO PAY YOUR MORTGAGE PAYMENTS, AND IF YOU MEET OTHER ELIGIBILITY REQUIREMENTS ESTABLISHED BY THE PENNSYLVANIA HOUSING FINANCE AGENCY. AYMENT INSTRUCTIONS Please Make your check pa?able to Countrywide Home Loans Writo your loan number on your check or money order Write in any additional amounts you are including. (If total is mom than $5000, please send ced~ad check.) · Don't a[~ach your check to the payment coupon · Don't include correspondence · Don't seng cash Send Conesponbence to: May02,2001 Edward W. Karas 356 Old Baltimore Pike N~wark, DE.t 9702 Certified Mail No. Return Receipt Requested Regular Mail Countrywide Account # 3138241 Property Address: 1029 Swadhmore Road New Cumberland. PA. 17070 Current Servicer: Countrywide Home Loans. Inc. ACT 91 NOTICE TAKE ACTION TO SAVE YOUR HOME FROM FORECLOSURE This Is an official notice that the mortqaqe on your home is in default~ and the lender intends to foreclose. Specific Information about the nature of the default is provided in the attached Daues. The HOMEOWNER'S EMERGENCY MORTGAGE ASSISTANCE PROGRAM (HEMAP} may be able to held to save your home: This Notice explains how the orouram works. To see if REMAP can help, you must MEET WITH A CONSUMER CREDIT COUNSELING AGENCY WITHIN 30 DAYS OF THE DATE OF THIS NOTICE. Take this Notice with you when you meet with the Counsellnu Aqency. The names, addresses and phone numbers of Consumer Credit Counseling Auencles servlnu your County are listed at the end of this Notice. If you have any ;uestions. you mav call the Pennsylvania HousinQ Finance Auencv toll-free at 1-800-342-2397. (Persons with impaired hearinq can call 1-717-780-t869.) This Notice contains important legal information. If you have any questions, representatives at the Consumer Credit Counseling Agency may be able to help answer them. You may also want to contact an attorney in your area. The local bar association may be able to help you find a lawyer. LA NOTIFICACI~N EN ADJUNTO ES DE SUMA IMPORTANCIA, PUES AFECTA SU DERECHO A CONTINUAR VIVIENDO EN SU CASA. SI NO COMPRENDE EL CONTENIDO DE ESTA NOTIFICACI~N OBTENGA UNA TRADUCCI~N INMEDIATAMENTE LLAMANDO ESTA AGENCIA (PENNSYLVANIA HOUSING FINANCE AGENCY) SIN CARGOS AL NOMERO MENCIONADO ARRIBA. PUEDE SER ELEGIBLE PARA UN PRI~STAMO POR EL PROGRAMA LLAMADO "HOMEOWNER'S EMERGENCY MORTGAGE ASSISTANCE PROGRAM" EL CUAL PUEDE SALVAR SU CASA DE LA PERDIDA DEL DERECHO A REDIMIR SU HIPOTECA. HOMEOWNER'S EMERGENCY MORTGAGE ASSISTANCE PROGRAM YOU MAY BE ELIGIBLE FOR FINANCIAL ASSISTANCE WHICH CAN SAVE YOUR HOME FROM FORECLOSURE AND HELP YOU MAKE FUTURE MORTGAGE PAYMENTS. IF YOU COMPLY WiTH THE PROVISIONS OF THE HOMEOWNER'S EMERGENCY MORTGAGE ASSISTANCE ACT OF 1983 (THE "ACT"), YOU MAY BE ELIGIBLE FOR EMERGENCY MORTGAGE ASSISTANCE: IF YOUR DEFAULT HAS BEEN CAUSED BY CIRCUMSTANCES BEYOND YOUR CONTROL, Please write your loan number on all checks and correspondence <<ACCTX)>-~CHKDGT~ 6/26/2000 ~TOTDUE~ AS OF ~DUEDTE,) P.O. Box~PYPOBX~ <PYCSTZ~ <<BARCDE>> hWKSCAN~ IF YOU HAVE A REASONABLE PROSPECT OF BEING ABLE TO PAY YOUR MORTGAGE PAYMENTS, AND IF YOU MEET OTHER ELIGIBILITY REQUIREMENTS ESTABLISHED BY THE PENNSYLVANIA HOUSING FINANCE AGENCY. AYMENT INSTRUCTIONS Please Make your check payable to Countrywide Home Loans Write your loan number on your check or money order Wriid in any additional amounls you are indudiog (if total is more than $5000, please send certified cdeck ) · Don't attach your check 1o tbe payment coupon · Don't include correspondence · Don't send c~h TEMPORARY STAY OF FORECLOSURE - Under the Act, you are entitled to a temporary stay of foreclosure on your mortgage for thirty-five (35) days from the date of this Notice. Dudng that time you must arrange and attend a "faee-tc- face" meeting with one of the consumer credit counseling agencies listed at the end of this Notice. THIS MEETING MUST OCCUR WITHIN THE NEXT (35) DAYS. IF YOU DO NOT APPLY FOR EMERGENCY MORTGAGE AssISTANCE. YOU MUST BRING YOUR MORTGAGE UP TO DATE. THE PART OF THIS NOTICE CALLED "HOW TO CURE YOUR MORTGAGE DEFAULT" EXPLAINS HOW TO BRING YOUR MORTGAGE UP TO DATE. CONSUMER CREDIT COUNSELING AGENCIES - If you meet with one of the consumer credit counseling agencies listed at the end of this notice, the lender may NOT take action against you for thirty-five (35) days after the date of this meeting. The names, addresses and teleohone numbers of desianated consumer credit counseliee aoencies for the county in which the DrePertv is located are set forth at the end of this Notice. It is only necessap/to schedule one face- to-face meeting. Advise your lender immediately of your intentions. APPLICATION FOR MORTGAGE ASSISTANCE - Your mortgage is in default for the reasons set forth later in this Notice (see following pages for specific information about the nature of your default.) If you have tded and are unable to resolve this problem with the lender, you have the right to apply for financial assistance from the Homeowner's Emergency Mortgage Assistance Program. To do so, you must fill out, sign and file a completed Homeowner's Emergency Assistance Program Application with one of the designated consumer credit counseling agencies listed at the end of this Notice. Only consumer credit counseling agencies have applications for the program and they will assist you in submitting a complete application to the Pennsylvania Housing Finance Agency. Your application MUST be filed or postmarked within thirty-five (35) days of your face-to*face meeting. YOU MUST FILE YOUR APPLICATION PROMPTLY. IF YOU FAIL TO DO SO OR IF YOU DO NOT FOLLOW THE OTHER TIME PERIODS SET FORTH IN THIS LETTER, FORECLOSURE MAY PROCEED AGAINST YOUR HOME IMMEDIATELY AND YOUR APPLICATION FOR MORTGAGE ASSISTANCE WILL BE DENIED. AGENCY ACTION - Available funds for emergency mortgage assistance are very limited. They will be disbursed by the Agency under the eligibility criteria established by the Act. The Pennsylvania Housing Fina_nce Agency has sixty (60) days to make a decision after it receives your application. During that time, no foreclosure proceedings will be pursued against you if you have met the time requirements set forth above. You will be notified direcfiy~y the Pennsylvania Housing Finance Agency of its decision on your application. NOTE: IF YOU ARE CURRENTLY PROTECTED BY THE FILING OF A PETITION IN BANKRUPTCY, THE FOLLOWING PART OF THIS NOTICE IS FOR INFORMATION PURPOSES ONLY AND SHOULD NOT BE CONSIDERED AS AN ATTEMPT TO COLLECT THE DEBT. (If you h~ave filed bankruptcy you can stile apply for Emergency Mortgage Assistance.) NOTICE OF INTENT TO FORECLOSE YOUR HOME LOAN IS IN DEFAULT FOR THE REASONS SET FORTH IN THIS NOTICE. YOU MUST TAKE ACTION TO SAVE YOUR HOME FROM FORECLOSURE NATURE OF THE DEFAULT - Countrywide Home Loans, Inc. (here!natter ~Countl-ywide") services your home loan. Your home loan is in serious default because you have not made your required payments. The total-amount now required to reinstate your home loan as of the date of this I~tter is as follows: Monthly Payments: $784.66 $2,812.30 Late Chames: $31.39 $156.95 Other Chames: Uncollected Late Charges: $.00 Uncollected Costs: $2,799.87 TOTAL DUE: $6,880.12 HOW TO CURE THE DEFAULT - You may cure this default within THIRTY-FIVE (35) DAYS of the date of this letter, by paying to us the above amount of $3,160.20, plus any additional monthly payments, late charges, fees and other applicable charges which may fall due during this period. Such payment must be in the form of certified check, cashier's check or money order, and made payable to Countrywide at P.O. Box 660694, Dallas, TX 75266-0694. If your check or other payment is returned to us for insufficient funds or for any other reason, you will not have cured your default. No extension of time to cure will be granted due to a returned payment. If you do not cure this default within THIRTY-FiVE (35) DAYS, we will accelerate the payments due on your home loan. This means whatever is owing on the original amount borrowed will be considered due immediately and you may lose the chance to pay off your home loan in monthly installments. If the full payment of the amount in default is not made within THIRTY-FIVE (35) DAYS, we also intend to immediately start a lawsuit to foreclose on your mortgaged propetty. IF THE MORTGAGE IS FORECLOSED UPON * If the mottgage is foreclosed, the mortgaged prope~y will be sold by the Sheriff to pay off the mortgage debt. If the default is cured before we begin legal proceedings, Countrywide will be entitled to collect the reasonable attorney's fees actually incurred, up to $50.00. However, if legal proceedings are started, Countrywide will be entitled to collect the reasonable attorney's fees even if they are over $50.00. Any attorney's fees will be added to the secured debt, which may also include our reasonable costs. If you cure the default within the THIRTY-FIVE (35) DAY period, you will not be required to pay attorney's fees. YOU HAVE THE RIGHT TO REINSTATE AFTER ACCELERATION AND RIGHT TO ASSERT IN THE FORECLOSURE PROCEEDING THE NON- EXISTENCE OF A DEFAULT OR ANY OTHER DEFENSE YOU MAY HAVE TO ACCELERATION AND FORECLOSURE, OTHER LENDER REMEDIES - The lender may also sue you personally for the unpaid principal balance and all other sums due under the mortgage. RIGHT TO CURE THE DEFAULT PRIOR TO FORECLOSURE SALE - If you have not cured the default within the THIRTY-FIVE (35) DAY period and foreclosure proceedings have begun, you still have the right to curs the default and prevent the sale at any time up to one hour before the foreclosure sale. You may do so by paying the totaJ amount then past due, plus any late or other charges then due, reasonable attorney's fees and costs connected with the foreclosure sale and any other costs connected with the foreclosure sale as specified in wdting by the lender and by pertorming any other requirements under the mortg-age. Curing your default in the manner set forth in this notice will restore your mortgage to the same position as if you had never defaulted. EARLIEST POSSIBLE FORECLOSURE SALE DATE - It is estimated that the earliest date that a foreclosure sale could be held would be approximately six (6) months frs~m the date of this letter. A notice of the date of the foreclosure Aale wil! be sent to you before the sale. You may find out at any time exactly what the required payment will be by calling us at the following number: 800469-5231. This payment must be in the form of a cashier's check, certified check or money order and made payable to us at the address stated above. If the default is cured, the mortgage will be restored to the same position as if no default had occurred. However, the defablt may not be cured more than three (3) times in any calendar year. HOW TO CONTACT THE LENDER; Name of Lender: Countn/wide Home Loans, Inc. Address: P.O. Box 1022f Van Nuys, CA 9f410-0221 Phone Number: 800-669-523f Fax Number: 1.805.577.3432 Contact Person: Christen Rocha. MS SV-34 A~tentlon: Loan Counselor EFFECT OF FORECLOSURE SALE - You should realize that a foreclosure sale will end your ownership of the mortgaged property and your right to remain in it. If you continue to live in the properly after the Shedff's sale, a lawsuit to remove you and your furnishings and other belongings could be started by Countrywide at any time, ASSUMPTION OF MORTGAGE - Contact Countrywide Home Loans for information on the possible assumability of your loan. YOU MAY ALSO HAVE THE RIGHT: TO SELL THE PROPERTY TO OBTAIN MONEY TO PAY OFF THE MORTGAGE DEBT OR TO BORROW MONEY FROM ANOTHER LENDING INSTITUTION TO PAY OFF THIS DEBT. TO HAVE THIS DEFAULT CURED BY ANY THIRD PARTY ACTING ON YOUR BEHALF. TO HAVE THE MORTGAGE RESTORED TO THE SAME POSITION AS tF NO DEFAULT HAD OCCURRED, IF YOU CURE THE DEFAULT. (HOWEVER, YOU DO NOT HAVE THIS RIGHT TO CURE YOUR DEFAULT MORE THAN THREE TIMES IN ANY CALENDAR YEAR.) AYMENT INSTRUCTIONS Please Make your check payable to Count~wibe Home Loans Wrtto your loan number on your chec~ or money Wfito in any additional amounts you are inciudiag. (If total is more than $5000, p~ease send ced~ad cbeck ) · Don't attach your chad( t0 fl~e payment coupon · Don't include correspoadence · Don't send cs~h TO ASSERT THE NONEXISTENCE OF A DEFAULT IN ANY FORECLOSURE PROCEEDING OR ANY OTHER LAWSUIT INSTITUTED UNDER THE MORTGAGE DOCUMENTS, TO ASSERT ANY OTHER DEFENSE YOU BELIEVE YOU MAY HAVE TO SUCH ACTION BY THE LENDER, TO SEEK PROTECTION UNDER THE FEDERAL BANKRUPTCY LAW, Pursuant to your home loan documents, and because the home loan is in default, Countrywide may, at its option, enter upon and conduct an inspection of the property. The purpose of this inspection is to observe the physical condition of the property, to verify that the property is occupied and/or to determine the identity of the occupant. The cost of any such inspection will be added to and become part of the secured debt as provided under the terms of the home loan documents. If you are unable to cure your default on or before June 06, 2001, Countrywide wants you to be aware of various options that may be available to you through Countrywide to prevent a foreclosure sale of your property, For example: Repayment Plan: It is possible that you may be eligible for some form of payment assistance through Countrywide. Our basic plan requires that Countrywide receive, up front, at least ~ of the amount necessap/to bdng the account current, and that the balance of the overdue amount be paid, along with the regular monthly payment, over a defined pedod of time. Other repayment plans also are available. Loan Modification: Alternatively, it is possible that the regular monthly payments can be lowered through a modification of the loan by reducing the interest rate and then adding the del!nquent payments to the current loan balance. This foreclosure alternative, however, is limited to certain loan types. Sale of Your Prooertv: Alternatively, if you are willing to sell your home in order to avoid foreclosure, it is pessible that the sale of your home can be approved through Countrywide even if your home is worth less than what is owed on it. Deed-in-Lieu: Alternatively, if your property is flee from other liens or encumbrances, and if the default is due to a sedous financial hardship which is beyond your control, you may be eligible to deed your property directly to the Noteholder and avoid the foreclosure sale. If you are interested in discussing foreclosure alternatives with Countpywide, you must contact us immediately. If you request assistance, Countrywide will determine, in its sole discretion, whether such assistance will be extended to you. In the meantime, Countrywide will pursue all of its dghts and remedies L/rider the home loan documents and as permitted by law, unless it agrees otherwise in writing. Please be advised that failure to bdng the home loan current or to enter into a written agreement as outlined above will result in the acceleration of the debt. Time is of the essence. Should you have any questions concerning this notice, please contact Count~jwide's office immediately at 800~69-5231, extension 7149. Christen Rocha Loan Counselor 800-669-5231, Extension 7149 Please be advised that this communication is from a debt collector. GOLDBECK McCAFFERTY & McKEEVER BY: Joseph A. Goldbeck, Jr. Attorney I.D.#16132 Suite 500 - The Bourse Bldg. 111 S. Independence Mall East Philadelphia, PA 19106 215-627-1322 Attorney for Plaintiff COUNTRYWIDE HOME LOANS INC. F/KfA COUNTRYWIDE FUNDING CORP. 7105 Corporate Drive PTX B-35 Plano, TX 75024-3632 Plaintiff VS. SUN V. KARAS EDWARD W. KARAS Mortgagor(s 1029 Swarthmore Road New Cumberland, PA 17070 IN THE COURT OF COMMON PLEAS of Cumberland County CIVIL ACTION - LAW ACTION OF MORTGAGE FORECLOSURE Term No. 01-4770 CERTIFICATE OF SERVICE PURSUANT TO Pa. ILC.P. 404 Joseph A. Goldbeck, Jr., Esquire, hereby certifies that a tree and correct copy of the above-captioned Complaint in Mortgage Foreclosure was served upon Defendant(s) by certified mail on August 29, 2001 3, Se~4ceType CERllFIED MAIL __ ~¥e~ edt~: KARAS, sUN V. 356 Old Baltimore Pike Newark, DE 19702 ~. s~r~ ~ A~ent 2. A~cle Number "~4. Restr~'~d Deltvery? (Extra Fee) [] Yes -- 1, AriSe Addressed to: KARAS, EDWARD W. EDWARD W; KARAS 356 Old Baltimore Pike Newark, DE 19702 L NDER: at tornev~-~ SUite '"~zadelphia, ~'~ Mall ~9. C°Unt~de He. Lo~ 7105 CO~orat)=t~, ~lan°~s ~X 75~3~3 S~ V. Karas 356 Old Balt~ Newark, DE 1~ ~ike Edward W. Ka: 356 Old ~alt~ Newark, DE I ~ike 0~ ~ CO~_ NO 01.4770 ~N TO THE PROTHF:~ ~_J~D_G~N~ - - Kindly Jud~ ~~J - un,ted Stat~j~~, D~= ~e b~ foreclosure ~rlca) ~4~zn 20 ~Zendant~alnti¢¢ damages as ~' of thez~ the ~s (otL~ot f~.% a~d interesl-O~plai~t ~s, a~d ~ the co~U~t Late Ch,' ' 10/26.._ SSess Escrow ' /u4 a~tiff,s rot TOT~ $87,372 I her~t= ~ 62._03 Defendants ~at (1) ~ ~J~ accordance ~.above the ad~ ~Ched. ~otlce ~l~inti ~ "~ be ~ ff precise re the a~ - Drive, PT~% the %°L? ~ame.~ , - ' lti~_ ke, '~_ na~ Co~_ he TO: COLLE(?. V~IRM Is.4 DI~ ~o~ ~?~ o~' co~SF~o~ ~ ~E DEBT. EDw~ W. ~S DATE 356 Old ~al~ore P~e OF ~IS NOTICE: SePtember 19, 2~1 Newark, DE 19702 COUNTRYwiDE HOME LOANs INC COUNTRYwIDE FUNDING CORp ' F/K/A 7105 Corporate Drive · PTX B-35 Piano, TX 75024-3632 VS. sun v. KARAs EDWARD W. KARAS (Mortgagor(s) and Record Owner(s)) 1029 Swarthmore Road New Cumber/and, PA 17070 Plaintiff EDWARD W. KARAs 356 Old Baltimore Pike Newark, DE 19702 Defendant(x) IN THE COURT OF COMMON PLEAS °f Curaberland County CIVIL ACTION. LAW ACTION OF MORTGAGE FOP~CLosURE No. 0~4770 YOU ARE IN DEFA,- ~ -- ~ANT NOw~o~ PERSONALLy OR ~"~ BECAUSE y~ BY A~O~y '~ ~ V~ED To 3B~CTIONs TO THE CL ~ FILE ~ ~G E~R A ~N ~p~cE ;ROM ~ DATE ~ ~S SET FOR~ a~ ..... ~ ~ CO~T YO~ DEFUSES ~v ~1~ NOTICE, A '~T YOU. ~ESS YOU A~ OR [E~G ~ YOU ~y LOSE YO~ PROPERW OR B~ E~ AGA ~- ~ ~ ~N (I 0) DAYs ~ ~S NOTICE TO A LA FFO~ O~ ~R AT ~ST YOU ~O~ A O~R ~ORT~ ~G~s. , ? ' ~ omc~ ~o ~ ~ o~ C~ot k~,~d;~ ~ ~'~ UUT ~ YOU C~ Attorney for Pla~~'~'~' ar. Esq. TO: THIS LA W FIRM i OR TH~ PU~ INFon~.-MPTING ~ -~ ~ ~'~10 TO T~G T~ D~BT' s~ v. ~ DATE OF T~S NOTICE: 356 ola Balt~o~ P~e SeP~mber 19, 2001 Newark, DE 19702 COUNTRYWiDE HOME LOANs IN¢ F/K/A COUNTRYWiDE FUNDING CORP. ' 7105 Corporate Drive PTX B-35 Piano, TX 75024-3632 SUN V. KARA/s' EDWARD W. KARAS (Mortgagor(s) and Record Owner(s)) 1029 Swarthmore Road New Cumberland, PA 17070 Plaintiff TO: SUN V./(ARAs 356 Old Baltimore Pike Newark, DE 19702 Defen%(s) /N THE COpU~L[2/ COMMON of Curnberland County CML ACT/ON. LAW ACTION OF MORTGAGE FORECLOSURE Term No. 0~-4770 FROM THE DATE OF THIS NOTICE, ~tEAR1NG AND YOU '- A J~DGME1y MAy BE ENTERED ~ MAy LOSE YOUR ROPERT, OR 0 AGAINST YOU WITHouT 33(E THIS NOTICE To A LAWYER A'PO TIeR ·FORD ONE, GO TO OR TEL" ..... NCE. F YO" ~- IMI~ORTANT RiGH,~_ A ;ET LEGAL HELP: ~rnONE tTE FOLL'~t~ L~O.~NOT HAVE A ~._YoU SHOULD , '.a t/AND OuT xln-.,~ GAL ERVi~s ¥¥ ~lJ~ YOU CA~ ~ e w [NC Suite 500. The Boule Bldg. 111 S. Independence Mall East TO: THIS LA Vt/ COLLECT. _~4 IS A FRoaa ,,,~_.~ ~ DEBT OWF~ '~ rOU ~IL rOw~ W. ~ DATE OF ~S NOTICE: September 19, 2001 1029 SW~ore Road Ne~ C~bcrl~d' PA 17070 7105 Corporate Drive '~'~ CORp. A PTx B-35 Plano, TX 75024-3632 EDwAp~ W. (Mortgagor(s) and Owner., ~o"~warthm°re Roaa *,~w ~berl~d, PA ~7070 Plaintiff TO: Defendant(s) 1029 Swarthmore Road New Ccanberland, PA 17070 N °fCumberland County CIVIL ACTION. LAW ACTION OF MORTGAG FOP~CLOSb~ ~ Term No. 01-4770 You ARE ~soN iN D~FAUL -IMPORT ALL~ OR ~ r ~Cavs ~TNo ~CT~ Y a~O E You ~CE OHS TO ~ ~Y ~ ~s ~o O~s ~ ~ .~ z~l~ NO '~ ~USE ~ ~2~z~'l ..... ~ YOU VFo~ TICE TO A ~a~-~O~PROPER~- ~BEE~ A~.~ "~h ~ass~no~ ~ u~FICE TO r~ k~kf~c~ - '~u O~ u~~ C~OT 5~g_~,o,~ ~c "~ YOU C~ THIS LAW FIRM IS A DEBT COLLECTOR AND WE ARE ATTEMPTING TO COLLECT A DEBT OWED TO OUR CLIENT. ANY INFORMATION OBTAINED FROM YOU WILL BE USED FOR THE PURPOSE OF COLLECTING THE DEBT. TO: SUN V. KARAS 1029 Swarthmore Road New Cumberland, PA 17070 DATE OF THIS NOTICE: September 19, 2001 COUNTRYWIDE HOME LOANS 1NC. F/FdA COUNTRYWIDE FUNDING CORP. 7105 Corporate Drive PTX B-35 Plano, TX 75024-3632 VS. SUN V. KARAS EDWARD W. KARAS (Mortgagor(s) and Record Owner(s)) 1029 Swarthmore Road New Cumberland, PA 17070 Plaintiff Defendant(s) IN THE COURT OF COMMON PLEAS of Cumberland County CIVIL ACTION ~ LAW ACTION OF MORTGAGE FORECLOSURE Term No. 01-4770 TO: SUN V. KARAS 1029 Swarthmore Road New Cumberland, PA 17070 IMPORTANT NOTICE YOU ARE IN DEFAULT BECAUSE YOU HAVE FAILED TO ENTER A WRIITEN APPEARANCE PERSONALLY OR BY ATTORNEY AND FILE IN WRITING WITH TH~ 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 JUDGIVIENT MAY BE ENTERED AGAINST YOU WITHOUT A HEARING AND YOU MAY LOSE YOUR PROPERTY OR OTHER IMPORTANT RIGHTS. YOU SHOULD TAKE THIS NOTICE TO A LAWYER AT ONCE. IF YOU DO NOT HAVE A LAWYER OR CANNOT AFFORD ONE, GO TO OR TELEPHONE THE FOLLOWING OFFICE TO FIND OUT WHERE YOU CAN GET LEGAL HELP: BG~VER Attorney for Plaintiff Suite 500 - The Bourse Bldg. I 11 S. Indc*pendence Mall East Philadelphia, PA 19106 215-627-132 GOLDBECK McCAFFERTY & McKEEVER By: Joseph A. Goldbeck, Jr. Attorney I.D. #16132 Suite 500 - The Bourse Bldg. 111 S. Independence Mall East Philadelphia, PA 19106 ATTORNEY FOR PLAINTIFF Countrywide Home Loans, Inc. f/k/a Countrywide Funding Corp. 7105 Corporate Drive, PTX B-35 Plano, TX 75024-3632 Vs. Sun V. Karas 356 Old Baltimore Pike Newark, DE 19702 : CUMBERLAND COUNTY : COURT OF COMMON PLEAS : CIVIL DIVISION : NO 01-4770 Edward W. Karas 356 Old Baltimore Pike Newark, DE 19702 PRAECIPE FOR JUDG~4ENT FOR FAILURE TO ANSWER AND ARSESmM~T OF DAMAGER TO THE PROTHONOTARY: Kindly enter judgment in favor of the Plaintiff and against Sun v. Karas and Edward W. Karas, Defendants for failure to file an Answer to Plaintiff's Complaint within 20 days (or 60 days if defendant is the United States of America) from the date of service of the complain and for foreclosure and sale of the mortgaged premises, and assess Plaintiff's damages as follows: As set forth in Complaint Interest - 9/1/01 - 10/26/01 Late Charges Escrow Debit TOTAL $87,372.90 $ 990.64 $ 62.76 $88,720.16 I hereby certify that (1) the addresses of the Plaintiff and Defendants are as shown above, and (2) that notice has been given in accordance with Rule 237.1, copy attached. Jos~ A. Gq~lbeck, Jr. Att~ney fo~ Plaintiff DAMAGES ARE HEREBY ASSESSED AS INDICaTeD. ~ PRO PROT I hereby certify that the above names are correct and that the precise residence address of the jud~ent creditor is 7105 Co,orate Drive, PTX B-35, Plano, TX 75024-3632 and that the names and last kno~ addresses of the Defendants are: Sun V. Karas, 356 Old Baltimore Pike, Newark, DE 19702 Edward W. Karas, 356 Old Baltimore Pike, Newark, DE 19702 CT_HIS LAW FIRM IS A DEBT COLLECTOR AND WE ARE OLLECT A DEBT OWED TO OUR CLIENT. ANY INFO ATTEMPTING TO FROM YOU WILL BE USED FOR THE PURPOSE OF COLLECTING THE DEBT. ]~[ATION OBTA/NED TO: DATE OF TI~S NOTICE: September 19, 2001 EDWARD W. KARAs 356 Old Baltimore Pike Newark, DE 19702 COUNTRYWIDE HOME LOANs INc. COUNTRYWIDE FUNDING CORp F/K/A 7105 Corporate Drive ' PTX B-35 Piano, TX 75024-3632 VS. sUN v. KARAs EDWARD W. KARAs (Mortgagor(s) and Record Owner(s)) 1029 Swarthmore Road New Cumber/and, PA ! 7070 Plaintiff TO: EDWARD W. KARAs 356 Old Baltimore Pike Newark, DE 19702 Defendant(s) IN THE COURT OF COMMON PLEAs of Cumberland County CIVIL ACTION. LAW ACTION OF MORTGAGE FORECLOSURE Term No. 01-4770 PERSONALLy ~u,~.~ YOU HAVE~ ENTER A wRrrrEN APPEARANCE HEARiN~= ~'~e u~" /HIS NOTICE, A "n~,~3~A~-S~T YOU. UNLEss YOU ar~ .... DEFENSEs OR A~ YOU MAY LOSE YO~ PROPER~ OR A~n~l rOU ~O~ A T~ ~IS NOTICE TO A LAiR A DO NOT ~ A LAiR OR C~OT ~FO~ O~, GO TO OR ~e ...... T ONCE. ~ yO~~R ~ORT~ ~G~s. YOU SHOED GET LEGAL HELP: ~vnONE ~E FOLLO~G OFFICE TO F~ O~ ~ YOU C~ R uomey £or Plaintiff Suite 500. The Bouv~e Bldg. ! l 1 S. Independence Mall East Philadelphia, PA 19106 215427-1322 THIS LAW FIRM IS A DEBT COLLECTOR AND WE ARE ATTEMPTING TO COLLECT A DEBT OWED TO OUR CLIENT. ANY INFORMATION OBTAINED FROM YOU WILL BE USED FOR THE PURPOSE OF COLLECTING THE DEllT. DATE OF THIS NOTICE: September 19, 2001 TO: SUN V. KARAs 356 Old Baltimore Pike Newark, DE ! 9702 COUNTRYWIDE HOME LOANs INC. F/FdA COUNTRYWIDE FUNDING CORP. 7105 Corporate Drive PTX B-35 Piano, TX 75024-3632 VS. SUN V. KARAs EDWARD W. KARAs (Mortgagor(s) and Record Owner(s)) 1029 Swarthmore Road New Cumberland, PA 17070 Plaintiff IN THE COURT OF COMMON PLEAS of Cumberland County CIVIL ACTION . LAW ACTION OF MORTGAGE FORECLOSURE Term No. 01-4770 Defendant(s) TO: SUN V. KARAs 356 Old Baltimore Pike Newark, DE 19702 NoTicE YOU ARE 1N DEFAULT BECk'USE YOU Iq_AVE FAILED T-O PERSONALLY OR BY ATTORNEy AND FILE IN ENTER A WRFI'i'EN APPEARANCE OBJECTIONs TO THE CLAIMs WRITING WITH THE COURT YOUR DEFENSES OR SET FORTH AGAINST YOU. UNLEss YOU ACT W1TI-fiN TEN (10) DAYS FROM THE DATE OF THIS NOTICE, A JUDGMENT MAy BE ENTERED AGAINST YOU WITHOUT A HEARING AND YOU MAy LOSE YOUR PROPERTY OR OTHER IMPORTANT RIGHTS. YOU SHOULD TAKE THIS NOTICE TO A LAWYER AT ONCE. IF YOU DO NOT HAVE A LAWYER OR CANNOT AFFORD ONE, GO TO OR TELEPHONE THE FOLLOWING OFFICE TO FIND OUT WHERE YOU CAN GET LEGAL HELP: AL ERVICES Suite 500 - The Bourse Bldg. 111 S. Independence Mall East Philadelphia, PA 19106 215-627-1322 THIS LAW FIRM IS A DEBT COLLECT A COLLECTOR AND WE ARE ATTEMPTING TO DEBT OWED TO OUR CLIENT. ANy INFORMATION OBTAINED FROM YOU WILL BE USED FOR THE PURPOSE OF COLLECTING THE DEBT. TO: DATE OF THIS NOTICE: September 19, 200~ ~DW.~V~D W. ~aO.S 1029 Swarthmote Road New CUmber/and, PA 17070 COUNTRYWIDE HOME LOANs INc. F/K/A COUNTRYWIDE FUNDING CORP. 7105 Corporate Drive PTX B-35 Piano, TX 75024-3632 Plaintiff SUN V. KARA;s' EDWARD W. KARAs (Mortgagor(s) and Record Owner(s)) 1029 Swarthmore Road New Cumberland, PA 17070 Defendant(s) TO: EDWARD W. KARAs 1029 Swarthmore Road New Cumberland, PA 17070 IN THE COURT OF COMMON PLEAS °f Cumberland County CIVIL ACTION ~ LAW ACTION OF MORTGAGE FORECLosURE Term No. 01-4770 You ARE tN IMPORTANT NOTICE DEFAULT BECAUSE YOU HAVE FAILED TO PERSONALLy OR BY ATTORNEy AND FILE OBJECTIONs TO THE IN WRITING ENTER A WR/TTEN APPEARANCE WITH THE COURT YOUR DEFENSES EROM THE DATE CLMMs SET FoRTH AGArNST YOU. UNLESS YOU AcT WITH]N TEN (10) DA~SR OF THIS NOTICE, A S~DGM~NT HEARrNG AND YOU MAy LOSE YOUR MAy BE ENTERED AGAINST TA~ THiS NOTICE ~O ^ L^W~R A~PR°PERTY OR OT~R X~ORTANT paGHTYS°U WrmouT A AFFORD ONE, GO TO O" '"~- ONCE IF YO .... GET LEGAL HELP: ~'LLOWING OFFICE 'rr~ ~.~ ~w r P_kR OR CAN-No ~x ~LEPHoNE THE F'~* --- '..,t~ DO NOT HAVE A LA'','''~-¥OU SHOULD g~,~f°~BA~O~o~ '" "'~' OUT W~RE YOU C~ GAL ERVICES Suite 500. The Bourse Bldg. 111 S. Independence Mall East Philadalphia, PAlgl06 215-627-132 THIS LAW FIRM IS A DEBT COLLECTOR AND WE ARE ATTEMPTING TO COLLECT A DEBT OWED TO OUR CLIENT. ANY INFORMATION OBTAINED FROM YOU WILL BE USED FOR THE PURPOSE OF COLLECTING THE DEBT. TO: DATE OF THIS NOTICE: September 19, 200~ sUN v. KARAs ! 029 Swarthraore Road New Cumber/and, PA ! 7070 COUNTRYWIDE HOME LOANs INc. F/K/A COUNTRYWIDE FUNDING CORP. 7105 Corporate Drive PTX B-35 Piano, TX 75024-3632 VS. sUN ¥. KARAS EDWARD W. KARAs (Mortgagor(s) and Record Owner(s)) 1029 Swarthmore Road New Cumber/and, PA 17070 TO: Plaintiff Defendant(a) 1029 Swarthraore Road New Cumberland, PA 17070 IN THE COURT OF COMMON PLEAs of Cumberland County CIV/L ACTION. LAW ACTION OF MORTGAGE FORECLOSURE Terra No. 01-4770 You ARE IN IMPORTANT NOTICE DEFAULT BECAusE YOU H. AVE FA/LED TO PERSONALLy OR BY ATTORNEy AND FILE IN OBJECTIONs TO THE ENTER A WRITTEN APPEARANCE WRITING WITH THE COURT YOUR DEFENSEs CLAIMs SET FORTH AGAINST YOU. UNLEss OR FROM THE DATE OF THIS NOTICE, A JUDGMENT YOU ACT WITtIINTEN (10) DAYs HE~u~rNG ~ YOU M~¥ LOSE YOUR M~¥ BE ENTERED AG, XINST YOU WrmOUT A TAKE THIS NOTICE TO A LA PROPERTY OR OTHER IMPORTANT RIGHTs. AFFORD ONE, GO TO OR TELWYER AT ..O~N~CE~ 1F YOU DO YOU SHOULD GET LEGAL HELP: EPHONE THE FOLLoxxrrxT .... _NOT HAVE A LAWYER r,r, ~O~VrVB~^SSOC~,nON "~J 'OVVlCE TO FIND O,'~ ---- us~ ~ANNOT u s WHERE YOU CAN GAL ERVICE$ IN B EVER tmmey for Plaintiff Suite 500 - The Bourse Bldg. 111 S. Indegendence Mall East Philadelphia, PA 19106 215~627-132 GOLDBECK, MCCAFFERTY & MCKEEvER By: Joseph A. Goldbeck, Jr. Attorney I.D. #16132 Suite 500-The Bourse Bldg. 111 S. Independence Mall East Philadelphia, PA 19106 Countrywide HOme Loans, Inc. f/k/a Countrywide Funding Corp. Vs. ATTORNEy FOR PLAINTIFF COURT OF COMMON PLEAs CIVIL DIVISION Sun V. Karas Edward W. Karas No. 01~4770 CUMBERLAND COUNTy Pa. C.S. Section 4904 authorities. JOSEPH A. GOLDBE~K, JR he is attorney for the Plaintiff'' ESQUIRE, hereby, verifies that and that on information and belief, he has knowledge of the following facts, to wit: in the above-captioned matter, (a) that the defendants are not in the Military or Naval Service of the United States or its Allies, or otherwise within the provisions of the Soldiers, and Sailors, Civil Relief Act of Congress of 1940, as amended. (b) that defendant 8un V. Earas, is OVer 18 years of age, and resides at 356 Old Baltimore Pike, Newark, DE 19702. (c) that defendant Edward W. Karas, is Over 18 years of age, and resides at 356 Old Baltimore Pike, Newark, DE 19702. This statement is made subject to the penalties of 18 relating to unsworn falsification to October 29, 2001 (Rule of Civil Procedure No. 236) - Revised IN T~E COURT OF COM){ON PLEAS OF CD'~BERLAND COUNTy, PENNSYLVANIA CIVIL ACTION ~ LAW Countrywide Home Loans, Inc. f/k/a Countrywide Fundin9 Corp. , Plaintiff Vs. Sun V. Karas Edward W. Karas , Defendants : NO. 01-4770 Notice is 9iVen that a Judgment in the above captioned matter has been entered against you on ~ / 2001. ~°~:~PUTY COntact: If you have any questions COncerning this matter please **THIS FIRM IS A DEBT COLLECTOR ~v~USLy RECEIVED ~_USED FOR THAT PURPoS . mCHARGE IN BANKR-- E IF YOU AND SHOULD NOT BE CONSTRUED TO BE ANATTEMpT TO COLLECT A DEBT, UPTcy, THIS IS NOT BUT ONLy ENFORCEMENT OF A LIEN AGAINST PROPERTy. ** PRAECIPE FOR WRIT OF EXECUTION - (MORTGAGE FORECLOSURE) P.R.C.P. 3180-3183 Countrywide Home Loans, Inc. f/k/a Countrywide Funding Corp. Plaintiff Vs. Sun V. Karas Edward W. Karas Defendants : COURT OF COMMON PLEAS : CUMBERLAND COUNTY, PA : NO: 01-4770 : PEAECIPE FOR WRiT OF EXECUTION (MORTGAGE FORECLOSURE) TO THE OFFICE OF THE PROTHONOTARY: Issue writ of execution in the above matter: Amount Due Interest from 10/26/01 at $14.58 per diem Total $88,720.16 to sale date $ and Costs 111 S. Independence Mall East Philadelphia, PA 19106 Attorney for Plaintiff Note: Please attach description of property. ALL THAT CERTAIN lot of land situate in the borough of New Cumberland, County of Cumberland and State of Pennsylvania, bounded and described as follows, to wit: BEGINNING at a point on the northerly line of Swarthmore Road, said point being located 937.54 feet measured Eastwardly along said line from the Northeast comer of Swarthmore Road and Drexel Hills Boulevard; thence Northwardly at right angles and along the Easterly line of Lot No. 12, Block "A", on the hereinafter mentioned Plan 105.00 feet to a point; thence North 89 degrees 14 minutes East along line of lands now or formerly of Elmer E. Zimmerman, 65.00 feet to a point; thence southwardly at right angles and along the Westerly line of Swanlimore Road; thence by the latter south 89 degrees 14 minutes West, 65.00 feet to the place of BEGINNING. Tax Parcel #26-24-0809 Being known as 1029 Swarthmore Road, New Cumberland, PA 17070 Countrywide Ho~e Loans, Inc. Countrywide Funding Corp. Plaintiff Vs. f/k/a : CUMBERLAND COUNTY : COURT OF COMMON PLEAS : CIVIL DIVISION Sun V. Karas Edward W. Karas : NO. 01-4770 Defendants AFFIDAVIT p%TRSUANT TO RULE 3129.1 Count _rywlde Home Loans. Inc. f/k/a Count _rywide Fund{hq Corp., Plaintiff in the above action, by its attorney, Joseph 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 1029 Swarthm~re Road. New Ckunber]~n~. PA 17070. Name and address of owner(s) or reputed owner (s): Name Address (if address cannot be reasonably ascertained, please so indicate) 356 Old Baltimore Pike 356 Old Baltimore Pike Name and address of defendant(s) in the judgment: Name Address (if address cannot be reasonably ascertained, please so indicate) 3. Name and address of every judgment creditor whose judgment is a record lien on the real property to be sold: Name Address (if address cannot be reasonably ascertained, please so indicate) Name and address mortgage of record: Name of the last recorded holder of every Address (if address cannot be reasonably ascertained, please so indicate) Gateway Square. Ste. 107 Memh~nicshurq. PA 17055 5. Name and address of every other person who has any record lien on the property: Name Address (if address cannot be reasonably ascertained, please so indicate) o Name and address of every other person who has any record interest in the property and whose interest may be affected by the sale: Name Address (if address cannot be reasonably ascertained, please so indicate) Cumberland County Dept. of Domestic Relatio.. Carlisle. PA 17013 Pa Dept. of Public Welfare Bureau of Child Support Enforcement Health and Welfare Bldg. Harrisburg. PA 17105 Room43~ 7 o Name and address of every other person of whom the plaintiff has knowledge that has any interest in the property that may be affected by the sale: Name Address (if address cannot be reasonably ascertained, please so indicate) 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. #4904 relating to unsworn falsification to authorities. October 29, 2001 Attor~y for~aintiff GOLDBECK, MCCAFFERTY & MCKEEVER By: Joseph A. Goldbeck, Jr. Attorney I.D. #16132 Suite 500-The Bourse Bldg. 111 S. Independence Mall East Philadelphia, PA 19106 ATTORNEY FOR PLAINTIFF COURT OF COMMON PLEAS Countrywide Home Loans, Inc. f/k/a Countrywide Funding Corp. Vs. Sun V. Karas Edward W. Karas CUMBERLAND COUNTY CIVIL DIVISION NO. 01-4770 JOSEPH A. GOLDBECK, JR., ESQUIRE, hereby states that he is the attorney for the Plaintiff in the above captioned matter and that the premises are not subject to the provisions of Act 91 because it is: ( ) ( ) ( ) (x) an FHA Mortgage non-owner occupied vacant Act 91 procedures have been fulfilled This certification is made subject to the penalties of 18 Pa. C.S. § 4904 relating to unsworn falsification to authorities. Joseph'. Go~eck,.Jr. -- Attor~ for~laintlff GOLDBECK McCAFFERTY & McKEEVER By: Joseph A. Goldbeck, Jr. Attorney I.D. #16132 Suite 500 - The Bourse Bldg. 111 S. Independence Mall East Philadelphia, PA 19106 ATTORNEY FOR PLAINTIFF Countrywide Home Loans, Inc. Countrywide Funding Corp. Plaintiff Vs. f/k/a : CUMBERLAND COUNTY : COURT OF COMMON PLEAS : CIVIL DIVISION Sun V. Karas Edward W. Karas ~ N0.01-4770 Defendants NOTICE OF SHERIFF'S SALE OF REAL ESTATE TO: Sun V. Karas 356 Old Baltimore Pike Newark, DE 19702 THIS FIRM IS A DEBT COLLECTOR ATTEMPTING TO COLLECT A DEBT AND ANY INFORMATION OBTAINED WILL BE USED FOR THAT PURPOSE. IF YOU HAVE PREVIOUSLY RECEIVED A DISCHARGE IN BANKRUPTCY, THIS IS NOT AND SHOULD NOT BE CONSTRUED TO BE AN ATTEMPT TO COLLECT A DEBT, BUT ONLY ENFORCEMENT OF A LIEN AGAINST PROPERTY. Your house (real estate) at 1029 Swarthn~re Road, New Cumberland. PA 17070, is scheduled to be sold at the Sheriff's Sale on ~ at 10:00 a.m., in Cumberland County, Cumberland County Courthouse, Commissioners Hearing Room, 2nd Floor, Carlisle, PA 17013 to enforce the court judgment of ~ obtained by Count _r_vwlde ~om~ Loan~. In~. f/k/~ Count _r~n~ide Funding Corp_. (the mortgagee) against you. NOTICE OF OWNER'S RI~T~ YOU MAY BE ABLE TO PR~"~'~NT THIS ~DTFF'S S~?.~ To prevent this Sheriff's Sale, you must take immediate action: The sale will be cancelled if you pay to the mortgagee the Back payments, late charges, costs and reasonable attorneys Fees due. To find out how much you must pay, you may call: o YOU may be able to stop the sale by filing a petition asking the Court to strike or open the judgment, if the judgment was improperly entered. You may also ask the Court to postpone the sale for good cause. 3. You may also be able to stop the sale through other legal proceedings. You may need an attorney to assert your rights. The sooner you contact one, the more chance you will have of stopping the sale. (See notice on page two on how to obtain an attorney.) YOU MAY STILL BE ~RT.~ TO SAVE YOUR PROPERTY AND YOU HAVE OTHE~ RIGHTS EVEN IF THE SHERIFF'S SALE DOES TAKE PLACE. 1. If the Sheriff's Sale is not stopped, your property will be sold to the highest bidder. You may find out the price bid by calling ~- 2. You may be able to petition the Court to set aside the sale if the bid price was grossly inadequate compared to the value of your property. 3. The sale will go through only if the buyer pays the Sheriff the full amount due in the sale. To find out if this has happened, you may call the Sheriff's office at (717] 240-6390. 4. If the amount due from the Buyer is not paid to the Sheriff, you will remain the owner of the property as if the sale never happened. 5. You have the right to remain in the property until the full amount due is paid to the Sheriff and the Sheriff gives a deed to the buyer. At this 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 proposed schedule of distribution of the money bid for your house will be prepared by the Sheriff within 30 days of the 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 posting of the Schedule of Distribution. 7. You may also have other rights and defenses, or ways of getting your home back, if you act immediately after the sale. YOU SHOULD TAKE THIS PAPER TO YOUR LAWYER AT ONCE. IF YOU DO NOT HAVE A LAWYER OR CANNOT AFFORD ONE, GO TO OR TELEPHONE THE OFFICE LISTED BELOW TO FIND OUT WHERE YOU CAN GET LEGAL HELP. Cumberland County Bar Association 2 Liberty Avenue Carlisle, PA 17103 (800) 990-9108 Legal Services, Inc. 8 Irvine Row Carlisle, PA 17103 (717) 243-9400 Goldbeck, McCafferty & McKeever BY: Joseph A. Goldbeck,, Jr. Attorney I.'D. #161~2 Suite 500 - Th~ Bourse Bldg. 111 S. Independence Mall East Philadelphia, PA 19106 215-627-1322 Attorney for Plaintiff Countrywide Home Loans, Inc. f/k/a Countrywide Funding Corp. 7105 Corporate Drive, PTX B-35 Plano, TX 75024-3632 Plaintiff Vs. Sun V. Karas Edward W. Karas 1029 Swarthmore Road New Cumberland, PA 17070 Defendants IN THE COURT OF COMMON PLEAS OF C,m£f~4~ COUNTY CIVIL ACTION - LAW ACTION OF MORTGAGE FORECLOSURE TERM No. 01-4770 CERTIFICATE OF SERVICE PURSUANT TO Joseph A. Goldbeck, Jr., Esquire, Attorney for Plaintiff, hereby certifies that service on the Defendants of the Notice of Sheriff Sale was made by: ( ) Personal Service by the Sheriff,s Office/competent adult (copy of return attached). (Certified mail by Joseph A. Goldbeck, Jr. attached). (original green Postal return receipt ( ) Certified mail by Sheriff,s Office ( ) Ordinary mail by Joseph A. Goldbeck, Jr., Esquire to Attorney for Defendant(s) of record (proof of mailing attached). ( ) Acknowledgement of Sheriff,s Sale by Attorney for Defendant(s) (proof of acknowledgement attached). ( } Ordinary mail by Sheriff,s Office to Attorney for Defendant(s) of record. IF SERVICE WAS ACCOMPLISHED BY COURT ORD . ( ) Premises was pOSted b ..... ~ --ER ( . . y onerlrr s office~ ~ d~ ) Certified Mall & ordinary mall by Sheri ( ) ' ' ?~P (copy of return attached) ea(Certified of return attached). Mail & ordinary mail by Joseph A. Goldbeck, Jr. (original receipt(s) for Ycertified Mail attached). Pursuant to the Affidavit under Rule 3129 (copy attached), service on all lienholders (if any) has been made by ordinary mail by Joseph A. Goldbeck, Esquire (copies of proofs of mailing attached). Jr., The undersigned understands that the statements herein are subject to the penalties provided by 18 P.S. Section 4904. Attor~y for Pl bmitted, ~rty & McKeever )ldbeck, Jr. [intiff Countr~ide .Ho~e Loans, Inc. Countrywide Funding Corp. Plaintiff Vs. Sun V. Karas Edward W. Karas f/k/a : CUMBERLAND COUNTY : COURT OF COMMON PLEAS : CIVIL DIVISION Defendants : NO. 01-4770 ~ Vj Ka~a~ A F nAV o SUA 9.1 Plaintiff in the above action, by its attorney, Joseph 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 1029 Swa~thm~r~ Roa,'~ N~W~i~i~~70' 1. Name and address of owner(s) or reputed Owner (s): Name Address (if address cannot be reasonably ascertained, please so indicate) 2. Name and address of defendant(s) in the judgment: Name Address (if address Cannot be reasonably ascertained, please so indicate) ~ame and address of every judgment creditor whose judgment is a record lien on the real property to be sold: Name Address (if address cannot be reasonably ascertained, please so indicate) Name and address mortgage of record: Name Realty of the last recorded holder of every Address (if address Cannot be reasonably ascertained, please so indicate) o. Non~ ~ame an~ address of every other person who has any record lien' 6n the property: Name Address (if address cannot be reasonably ascertained, please so indicate) Name and address of every other person who has any record interest in the property and whose interest may be affected by the sale: Name Chnnherland County Dept. Dome.tic Address (if address cannot be reasonably ascertained, please so indicate) Pa Dept. of P~thli~ Welfar~ Bureau of Child Rupport Enforcem~n;~ 7 o ~arllsle, PA 1701~ HarrisBurg. PA 17105 Name and address of every other person of whom the plaintiff has knowledge that has any interest in the property that may be affected by the sale: Name Address (if address cannot be reasonably ascertained, please so indicate} 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. #4904 relating to unsworn falsification to authorities. October 29, 2001 ~°sep~'G°l~k, Jr. Attor~y for~aintiff 2. Article Number 3. Service Type CERTIFIED MAIL 4. Restricted Delivery? (Extra Fee) [] Yes 1. Article Addressed to: C. Signature [] Addressee D. Is delivery address different from it em'*"f'F- [] Yes If YES, enter delivery address below: [] NO KARAS, SUN V. SUN V. KARAS 356 Old Baltimore Pike Newark, DE 19702 RE:GoLDBECK MCCAFFERIY &MCKEEVER PS Form 3811, .~ofil 2001 · '21 'ArticleN~n~b~r ~-~----= 3. Setv~c~'ype CERTIFIED MAIL 4. 'Re~stri, ct?'d Delivery? (Extra Fee) EDWARD W. KARAS 356 Old Baltimore Pike Newark, DE 19702 , SENDER: Domestic Return Receipt C. ~gnature x SENDER: Do~ Return Receipt 7160 d~u~ 9844 5198u,,"""9 TO-' KARAS, SLr[q. V. SUN V. KARA$ · 356 Old Baltimore Pike Newark, DE 19702 SENDER: GOLDBECK MCCAFFERTY & MCKEt October 29, 2001 REFERENCE: KARAS, SUN V. / CWD-1383 - Cumberland PS Form 3800, June 2000 RETURN Postage RECEIPT Certified Fee SERVICE Return Receipt Fee Total Postage & Fees Restricted Delivery US Postal Service i Re.c.,e, ipt for, i Certified Mall ~ ao~ct [] AddreSsee } No Insurance Coverage Provided Do Not Use for Intema0one] Mail r~No 71~0 3901 9844 ~;198 9002 KARAS, EpWARD .W. EDWARD W. KARA$ 356 Old Baltimore Pike Newark, DE 19702 SENDER: REFERENCE: GOLDBECK MCCAFFERTY & MCKE: October 29, 2001 KARAS, SUN V. / CWD-1383 - Cumberland PS Form 3800, June 2000 RETURN Postage RECEIPT Certified Fee SERVICE Return Receipt Fee Total Postage & Fees Restricted Delivery US Postal Service POST Receipt for Certified Mail No Insurance Coverage provided Do Not Use for International M~il STATE OF PENNSYLVANIA, } C_~UNTY OF CUMBERLAND ss. I, Robert P Ziegler .............................................................................. Recorder of Deeds in and for said County and State do'hereby certify that thc Sheriff's Deed in which ................ Secretary of Veterans Affairs .................................................................................... ~ thc grantee the same having been sold to said grantee on thc .......... .~.~L ........... ..................... day of March 2002 ........................................ A. D., ." ..... , under and by virtue of a writ .............. Execution ~ s t ................................................ [~ued on the ..................................... Nov dayof ........... A.D., 2001 ..... , out of the Court of Conunan Pleas of said County'aS of 2001 ' 4770 . Countrywide Home Loan Number ............. ,, at thc smt of ............ · ~ s Inc fka Countrywide F · . Sun V Karas & Edwar~ W ................................... aga,nst ..................................................... duly t~cotxled in Sheriff's Dc~d Book No ........ _2_5_0_ _, Page 4897 IN TESTIMONY WHEREOF, I have hereunto set my hand and seal of said office this .~___~_ ..... day ..... Countrywide Home Loans, Inc. f/k/a Countrywide Funding Corp. VS Sun V. Karas and Edward W. Karas In The Court of Common Pleas of Cumberland County, Pennsylvania Writ No. 2001-4770 Civil Term R. Thomas Kline, Sheriff, who being duly swom according to law, states that he served the within Real Estate Writ, Notice and Description in the following manner: The Sheriff mailed a notice of the pendency of the action by Certified Mail, Return Receipt Requested, Restricted Delivery, Deliver to Addressee Only to one of the within named defendants, to wit, Sun V. Karas, to her last known address of 356 Old Baltimore Pike, Newark, DE 19702. This letter was mailed under the date of November 6, 2001. Sun V. Karas received the letter on an unknown date (post office did not record date on return receipt card). Return receipt card was returned to the Cumberland County Sheriff's Office on November 16, 2001 signed by Sun V. Karas. R. Thomas Kline, Sheriff, who being duly sworn according to law, states that he served the within Real Estate Writ, Notice and Description in the following manner: The Sheriffmailed a notice of the pendency of the action by Certified Mail, Return Receipt Requested, Restricted Delivery, Deliver to Addressee Only to one of the within named defendants, to wit, Edward W. Karas, to his last known address of 356 Old Baltimore Pike, Newark, DE 19702. This letter was mailed under the date of November 6, 2001. Edward W. Karas received the letter on an unknown date (post office did not record date on return receipt card). Return receipt card was returned to the Cumberland County Sheriff's Office on November 16, 2001 signed by Edward W. Karas. Timothy Reitz, Deputy Sheriff, who being duly sworn according to law, states that on January 04, 2002 at 1:55 o'clock P.M., E.S.T., he posted a true copy of the within Real Estate Writ, Notice, Poster and Description, in the above entitled action, upon the property of Sun V. Karas and Edward W. Karas located at 1029 Swarthmore Road, New Cumberland, Pennsylvania, according to law. R. Thomas Kline, Sheriff, who being duly sworn according to law says he served the above Real Estate Writ, Notice, Poster and Description in the following manner: The Sheriff mailed a notice of the pendency of the action to one of the within named defendants to wit: Sun V. Karas, by regular mail to his last known address of 356 Old Baltimore Pike, Neward, DE 19702. This letter was mailed under the date of January 18, 2002 and never returned to the Sheriff's Office. R. Thomas Kline, Sheriff, who being duly sworn according to law says he served the above Real Estate Writ, Notice, Poster and Description in the following manner: The Sheriff mailed a notice of the pendency of the action to one of the within named defendants to wit: Edward W. Karas, by regular mail to his last known address of 356 Old Baltimore Pike, Newark, DE 19702. This letter was mailed under the date of January 18, 2002 and never returned to the Sheriff's Office. R. Thomas Kline, Sheriff, who being duly sworn according to law, says that after due and legal notice had been given according to law, exposed the within described premises at public venue or outcry at the Courthouse, Carlisle, Cumberland County, Pennsylvania on March 6, 2002 at 10:00 o'clock A.M., EST. He sold the same for the sum of $1.00 to Attorney Joseph Goldbeck for Secretary of Veterans Affairs. It being the highest bid and best price received for the same, Secretary of Veterans Affairs of 5000 Wissahickon Ave., Philadelphia, PA 19144, being the buyer in this execution paid Sheriff R. Thomas Kline the sum of $694.90, it being costs. Sheriff's Costs: Docketing $30.00 Poundage 13.63 Advertising 15.00 Posting Handbills 15.00 Acknowledging Deed 30.00 Auctioneer 10.00 Law Library .50 Prothonotary 1.00 Mileage 11.05 Certified Mail 15.42 Levy 15.00 Surcharge 30.00 Legal Search Law Journal 218.90 Patriot News 212.70 Share of Bills 24.20 Distribution of Proceeds 25.00 Sheriff's Deed 27.50 $694.90 Sworn and subscribed to before me This 0/~ day of {)tm,4a 2002, A.D. (~.~ /~_ ~_fi~,.~, ! Prothonotary R. Thomas Kline, Sheriff By Real ~state Deputy Countrywide Home Loans, Inc. f/k/a Countrywide Funding Corp. Vs. Plaintiff : CUMBERLAND COUNTY : COURT OF COMMON PLEAS : CIVIL DIVISION Sun V. Karas Edward W. Karas : NO. 01-4770 Defendants AFFIDAVIT PURSUANT TO RULE 3129.1 Count _rywide Home Loans. Inc. f/k/a Count _r~wide F~nding~Corp., Plaintiff in the above action, by its attorney, Joseph 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 1029 Swar~hm~re Road. New ~m~erland. PA 17070. Name Name and address of owner(s) or reputed owner (s): Address (if address cannot be reasonably ascertained, please so indicate) 356 Old Baltimore Pike Newark. DE 19702 ~dward W. Karas 356 Old Baltlmore Pike Newark. DE 19702 2 o Name and address of defendant(s) in the judgment: Name Address (if address cannot be reasonably ascertained, please so indicate) 3. Name and address of every judgment creditor whose judgment is a record lien on the real property to be sold: Name Address (if address cannot be reasonably ascertained, please so indicate) Name and address of the last recorded holder of every mortgage of record: Name Household Realty Corp. Address (if address cannot be reasonably ascertained, please so indicate) 25 Gateway Drive Gateway S_~uare. Ste. 107 Mechanicshurq. PA 17055 5 o Name and address of every other person who has any record lien on the property: Name Address (if address cannot be reasonably ascertained, please so indicate) Name and address of every other person who has any record interest in the property and whose interest may be affected by the sale: Name Address (if address cannot be reasonably ascertained, please so indicate) Ctm~erland County Dept. Domestic Relation. Pa Dept. of Public Welfar0 Bureau of Ch41d Rupport Rnforcemen], 7o Carlisle. PA 17013 Health and Welfare Bldg. Room 43~ Harrisburg. PA 17105 Name and address of every other person of whom the plaintiff has knowledge that has any interest in the property that may be affected by the sale: Name Address {if address cannot be reasonably ascertained, please so indicate) 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. #4904 relating to unsworn falsification to authorities. October 29, 2001 Attor~y for~aintiff GOLDBECK McCAFFERTY & McKEEVER By: Joseph A. Goldbeck, Jr. Attorney I.D. #16132 Suite 500 - The Bourse Bldg. 111 S. Independence Mall East Philadelphia, PA 19106 Countrywide Home Loans, Inc. f/k/a Countrywide Funding Corp. Vs. Plaintiff ATTORNEY FOR PLAINTIFF CUMBERLAND COUNTY COURT OF COMMON PLEAS CIVIL DIVISION Sun V. Karas Edward W. Karas Defendants : NO.01-4770 TO: NOTICE OF S~FRIFF'S SALE OF REAL ESTAu'I,; Sun V. Karas 356 Old Baltimore Pike Newark, DE 19702 THIS FIRM IS A DEBT COLLECTOR ATTEMPTING TO COLLECT A DEBT AND ANY INFORMATION OBTAINED WILL BE USED FOR THAT PURPOSE. IF YOU HAVE PREVIOUSLY RECEIVED A DISCHARGE IN BANKRUPTCY, THIS IS NOT AND SHOULD NOT BE CONSTRUED TO BE AN ATTEMPT TO COLLECT A DEBT, BUT ONLY ENFORCEMENT OF A LIEN AGAINST PROPERTY. Your house (real estate) at 1029 Swar~hmore Road, Ne~ Cumberland. PA 17070. is scheduled to be sold at the Sheriff,s Sale on ~ at 10:00 a.m., in Cumberland County, Cumberland County Courthouse, Commissioners Hearing Room, 2nd Floor, Carlisle, PA 17013 to enforce the court judgment of ~ obtained by (the mortgagee) against you. NOTICE OF OW'N-RR,S RIGI~TR YOU~4Ay BE ABLE TO PRR"v'ENT THIS SH.:~IFF,R SAL. To prevent this Sheriff's Sale, you must take immediate action: 1. The sale will be cancelled if you pay to the mortgagee the Back payments, late charges, costs and reasonable attorneys Fees due. To find out how much you must pay, you (215) 627-132~ may call: 2. You may be able to stop the sale by filing a petition asking the Court to strike or open the judgment, if the judgment was improperly entered. You may also ask the Court to postpone the sale for good cause. 3. You may also be able to stop the sale through other legal proceedings. You may need an attorney to assert your rights. The sooner you contact one, the more chance you will have of stopping the sale. (See notice on page two on how to obtain an attorney.) 1. If the Sheriff's Sale is not stopped, your property will be sold to the highest bidder. You may find out the price bid by calling (215) 627-1322. 2. You may be able to petition the Court to set aside the sale if the bid price was grossly inadequate compared to the value of your property. 3. The sale will go through only if the buyer pays the Sheriff the full amount due in the sale. To find out if this has happened, you may call the Sheriff's office at (7171 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 the right to remain in the property until the full amount due is paid to the Sheriff and the Sheriff gives a deed to the buyer. At this 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 proposed schedule of distribution of the money bid for your house will be prepared by the Sheriff within 30 days of the 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 posting of the Schedule of Distribution. 7. You may also have other rights and defenses, or ways of getting your home back, if you act immediately after the sale. YOU SHOULD TAKE THIS PAPER TO YOUR LAWYER AT ONCE. IF YOU DO NOT HAVE A LAWYER OR CANNOT AFFORD ONE, GO TO OR TELEPHONE THE OFFICE LISTED BELOW TO FIND OUT WHERE YOU CAN GET LEGAL HELP. Cumberland County Bar Association 2 Liberty Avenue Carlisle, PA 17103 (800) 990-9108 Legal Services, Inc. 8 Irvine Row Carlisle· PA 17103 (717) 243-9400 GOLDBECK McCAFFERTY & McKEEVER By: Joseph A. Goldbeck, Jr. Attorney I.D. #16132 Suite 500 - The Bourse Bldg. 111 S. Independence Mall East Philadelphia, PA 19106 (215~ 627-1322 countrywide Home Loans, Inc. f/k/a Countrywide Funding Corp. Vs. Plaintiff ATTORNEY FOR PLAINTIFF : CUMBERLAND COUNTY : COURT OF COMMON PLEAS : CIVIL DIVISION Sun V. Karas Edward W. Karas : N0.01-4770 Defendants NOTICE OF SHERIFF'S SALE OF REAL ESTATE TO: Edward W. Karas 356 Old Baltimore Pike Newark, DE 19702 THIS FIRM IS A DEBT COLLECTOR ATTEMPTING TO COLLECT A DEBT AND ANY INFORMATION OBTAINED WILL BE USED FOR THAT PURPOSE. IF YOU HAVE PREVIOUSLY RECEIVED A DISCHARGE IN BANKRUPTCY, THIS IS NOT AND SHOULD NOT BE CONSTRUED TO BE AN ATTEMPT TO COLLECT A DEBT, BUT ONLY ENFORCEMENT OF A LIEN AGAINST PROPERTY. Your house (real estate) at 1029 Swarthmore Road. New C,~m~erland. PA 17070. is scheduled to be sold at the Sheriff's Sale on ~ at 10:00 a.m., in Cumberland County, Cumberland County Courthouse, Commissioners Hearing Room, 2nd Floor, Carlisle, PA 17013 to enforce the court judgment of ~ obtained by Count_rywide Hom~ Loans. Inc. f/k/a Count_rywide Funding Corp. (the mortgagee) 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: 1. The sale will be cancelled if you pay to the mortgagee the Back payments, late charges, costs and reasonable attorneys Fees due. To find out how much you must pay, you may call: (21B~ 627-1322 2. You may be able to stop the sale by filing a petition asking the Court to strike or open the judgment, if the judgment was improperly entered. You may also ask the Court to postpone the sale for good cause. 3. You may also be able to stop the sale through other legal proceedings. You may need an attorney to assert your rights. The sooner you contact one, the more chance you will have of stopping the sale. (See notice on page two on how to obtain an attorney.) YOU MAY STILL BE ABLE TO SAVE YOUR PROPERTY AND YOU HAVE OTHER RI~RTS EVEN IF TRE SHERIFF'S SALE DOES TAKE PLACE. 1. If the Sheriff's Sale is not stopped, your property will be sold to the highest bidder. You may find out the price bid by calling (215) 627-1322. 2. You may be able to petition the Court to set aside the sale if the bid price was grossly inadequate compared to the value of your property. 3. The sale will go through only if the buyer pays the Sheriff the full amount due in the sale. To find out if this has happened, you may call the Sheriff's office at (7171 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 the right to remain in the property until the full amount due is paid to the Sheriff and the Sheriff gives a deed to the buyer. At this 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 proposed schedule of distribution of the money bid for your house will be prepared by the Sheriff within 30 days of the 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 posting of the Schedule of Distribution. 7. You may also have other rights and defenses, or ways of getting your home back, if you act immediately after the sale. YOU SHOULD TAKE THIS PAPER TO YOUR LAWYER AT ONCE. IF YOU DO NOT HAVE A LAWYER OR CANNOT AFFORD ONE, C~D TO OR TELEPHONE THE OFFICE LISTED BELOW TO FIND OUT WHERE YOU CAN GET LEGAL HELP. Cumberland County Bar Association 2 Liberty Avenue Carlisle, PA 17103 (800) 990-9108 Legal Services, Inc. 8 Irvine Row Carlisle, PA 17103 (717) 243-9400 WRIT OF EXECUTION and/or ATTACHMENT COMMONWEALTH OF PENNSYLVANIA) COUNTY OF CUMBERLAND) TO THE SHERIFF OF Cumber[and COUNTY: from NO. 01-4770 CIVIL I~X TEt%'vl CIVIL ACTION - LAW To satisfy the debt, interest and costs due Countrywide Hcme Loans, Inc. f/k/a Countrywide Funding Corp. PLAINTIFF(S) Sun V. Karas and Edward W. Karas, 356 Old Baltimore Pike, Newark, DE 19702 DEFENDANT(S) (1) You are directed to levy upon the properly of the defendant(s) and to sell See Leqal Description (2) You are also directed to attach the properly 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/are enjoined from paying any debt to or for the account of the defendant(s) and from delivering any properly of the defendant(s) or otherwise disposing thereof; (3) If property o! lhe defendant(s) not levied upon an subject to attachment is found in the possession of anyone other than a named garnishee, you are directed Io notify him/her lhat he/she has been added as a garnishee and is enjoined as above stated. Amount Due $88,720.16 frcm 10/26/01 to sale date at $14.58 Interest .... _,__ Atty's Corem % Arty Paid S72. O0 Plaint~f Paid Due Prothy Other Costs $.50 Date: Nov~nber 1, 2001 REQUESTING PARTY: Name Joseph A. Goldbeck, Jr., Esq. Address: Suite 500 - The Bourse Bldg. 111 o. i~l ~ lid~nc~ ,-~.,-.~ Philadelphia, PA 19106 Plaintiff 215-627-1322 16132 Attorney for: Telephone: Supreme Court ID No. Curtis R. Long Prothonotary, Civil Division Deputy REAl.: ESTATE SALE No. ~,/ On November 06, 2001, the sheriff levied upon the defendant's interest in the real property situated in New Cumberland Borough, Cumberland County, PA, known and numbered as 1029 Swarthmore Road, New Cumberland, and more fully described on Exhibit "A" filed with this writ and by this reference incorporated herein. Date: November 06, 2001 [1 Estat43Deputy THE PATRIOT NEWS THE SUNDAY PATRIOT NEWS Proof of Publication UnderAct No. 587, Approved May 16, 1929 Commonwealth of Pennsylvania, County of Dauphin} ss Michael Morrow being duly sworn according to law, deposes and says: That he is the Asst. Controller of The Patriot News Co., a corporation organized and existing under the laws of the Commonwealth of Pennsylvania, with its principal office and place of business at 812 to 818 Market Street, in the City of Harrisburg, County of Dauphin, State of Pennsylvania, owner and publisher of The Patriot-News and The Sunday Patriot-News newspapers of general cimulation, printed and published at 812 to 818 Market Street, in the City, County and State aforesaid; that The Patriot-News and The Sunday Patriot-News were established March 4th, 1854, and September 18th, 1949, respectively, and all have been continuously published ever since; That the printed notice or publication which is securely attached hereto is exactly as printed and published in their regular daily and/or Sunday/ Metro editions which appeared on the 29th day(s) of January and the 5th and 12th day(s) of February 2002. That neither he nor said Company is interested in the subject matter of said printed notice or advertising, and that all of the allegations of this statement as to the time, place and character of publication are true; and That he has personal knowledge of the facts aforesaid and is duly authorized and empowered to verify this statement on behalf of The Patriot-News Co. aforesaid by virtue and pursuant to a resolution unanimously passed and adopted severally by the stockholders and board of directors of the said Company and subsequently duly recorded in the office for the Recording of Deeds in and for said Cou~ous Book "M", Volume 14, Page 317. PUBLICATION ' COPY ~vnrn fn .... he=Hrih~=rl~l'~fnr= m~ this 22nd dav,-of FeJ;~uary 2002 A.D. S A L E #24TenyL RusNdl,lc ",I Harrisbu rg, O~ u~i n ColJrav._. /,~3~/~-~ ~-~-."'3/., ~/. ~ ~,~/~.//-~.--..~.f~.-c-~(~~ ~ ~J I M'y Col~sslort Expires June 6, 200E I NC~I-ARY PUBLIC Mant)er, Pennsylvania A~ocation o~ Notan~l~y commission expires June 6, 2002 CUMBERLAND COUNI'Y SHERIFFS OFFICE CUMMBERLAND COUNTY COURTHOUSE CARLISLE, PA. 17013 Statement of Advertising Costs To THE PATRIOT-NEWS CO., Dr. For publishing the notice or publication attached hereto on the above stated dates Probating same Notary Fee(s) Total $ 21 1.20 $ 1.5O $ 212.70 Publisher's Receipt for Advertising Cost The Patriot News Co., publisher of The Patriot-News and The Sunday Patriot-News, newspapers of general circulation, hereby acknowledge receipt of the aforesaid notice and publication costs and certifies that the same have been duly paid. PROOF OF PUBLICATION OF NOTICE IN CUMBERLAND LAW JOURNAL (Under Act No. 587, approved May 16, 1929), P. L.1784 STATE OF PENNSYLVANIA : : COUNTY OF CUMBERLAND : SS. Roger M. Morgenthal, Esquire, Editor of the Cumberland Law Journal, of the County and State aforesaid, being duly sworn, according to law, deposes and says that the Cumberland Law Journal, a legal periodical published in the Borough of Carlisle in the County and State aforesaid, was established January 2, 1952, and designated by the local courts as the official legal periodical for the publication of all legal notices, and has, since January 2, 1952, been regularly issued weekly in the said County, and that the printed notice or publication attached hereto is exactly the same as was printed in the regular editions and issues of the said Cumberland Law Journal on the following dates, viz: JANUARY 25, FEBRUARY 1, 8, 2002 Affiant further deposes that he is authorized to verify this statement by the Cumberland Law Journal, a legal periodical of general circulation, and that he is not interested in the subject matter of the aforesaid notice or advertisement, and that all allegations in the foregoing statements as to time, place and character of publication are true. R.~AL ~TAT~ 8A.L~ NO. 24 Writ No. 2001-4770 Civil Countrywide Home Loans. Inc. f/k/a Countrywide Funding Corp. Sun V. Karas and Atty.: Joseph Goldbeck ALL THAT CERTAIN lot of land situate in the borough of New Cum- berland, County of Cumberland and State of Pennsylvania. bounded and described as follows, to wit: BEGINNING at a point on the northerly line of Swarthinore Road, said point bein4~ located 937.54 feet measured Eastwardly along said line from the Northeast corner of Swarth- SWORN TO AND SUBSCRIBED before me this 8 day of FEBRUARY, 2002 bio'.:_-,- ,/t i NOTARIAL SEq- ~ I S VO R, Pub I j GOLDBECK t4cCAFFERTY & McKEEVER BY: Joseph A. Goldbeck, Jr. Attorney I.D. #16132 Suite 500 -The Bourne Bldg. 111 S. Independence Mall Mast Philadelphia, PA 19106 215-627-1322 Attorney for Plaintiff COUNTRYWIDE HOME LOANS INC. F/K/A COUNTRYVVIDE FUNDING CORP. 7105 Corporate Drive PTX B-35 Piano, TX 75024-3632 VS. Plaintiff SUN V. KARAS EDWARD W. KARAS {Mortgagor(s) and Record owner{s)) 1029 Swarthmore Road New Cumberland, PA 17070 IN THE COURT OF COMMON PLEAS of Cumberland County No. 01-4770 PRAECIPE TO SATISFY JUD~qENT TO THE PROTHONOTARY: Kindly Satisfy the Judgment in the above captioned matter upon payment of your costs only. JR., ESQUIRE