HomeMy WebLinkAbout01-1248GOLDBECK 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. : IN THE COURT OF COMMON PLEAS
7105 Corporate Drive :
PTX B-35 : OF CUMBERLAND COUNTY
Plano, TX 75024-3632 :
Plaintiff : CIVIL ACTION - LAW
vs. :ACTION OF MORTGAGE FORECLOSURE
Term ~
DONALD M. ROBINDER D~ND :
(Mortgagor(s) and Real Owner(s) ) :
253 Bullshead Road : OtV[t ACTION: MORT~AG~
Newville, PA 17241 :
Defendant (s) : ~Um=~H--
THIS LAW FIP. M IS A DEBT COLLECTOR AND WE ARE ATTEMPTING
TO COLLECT A DEBT OWED TO OUR CLIENT. ANY INFORMATION
OBTAINED FROM YOU WILL BE USED FOR THE PURPOSE OF
COLLECTING THE DEBT.
NOTICE
YOU have been sued in court. If you wish to defen~ against the claims set forth in the following pages,
yo%l must take action within twenty (20) days after the Complaint and notice are served, by entering a written
appearance personally or by attorney and filing in writing with the court your defenses or objections to the
claims set forth against you. You are warned that if you fail to do so the case may proceed without you and a
judgment may be entered against you by the Court without further notice for any money claimed in the Complaint
or for any other claim or relief requested by the Plaintiff, You may lose money or property or other rights
important to you.
YOU SHOULD TAKE THIS PAPER TO YOUR LAWYER AT ONCE. IF YOU DO NOT HAVE A LAW~R OR CANNOT AFFORD ONE,
GO TO OR TELEPHONE THE OFFICE SET FORTH BELOW TO FIND OL~ WHERE YOU CAN GET LEGAL HELP.
Cumberland County Bar AssociaDion
2 Liberty Avenue, Carlisle, PA
(800) 990 9108
Legal Services Inc.
8 Irvine Row, Carlisle, PA 17013
(717) 243 9400
AVI S 0
LE ~ DEMA~DADO A USTED EN ~ CORTE. SI DBSBA DEFENDERSE CONTRA L~S QUEJAS PEHEEEb~fl~DAS, ES
ABSOLUT~MENTE NECESSARIO QUE USTED REEPONDA DENTR0 DE 20 DIAS DEEPUES DE SER SERVIDO CON ESTA DEMA~A Y AVISO.
PARA DEFENDERSB ES NECE$SARIO QUE USTED. 0 EU ABOGADO. REGISTRE CON LA CORTE RN FORMA ESCRITA. EL PUNTO DE VISTA
DE USTED Y CUALQ~IER OBJECCION CONTRA ~$ QUEJAE EN ESTA DRMANDA.
RECURRDE: Si UETED NO REPONDE A KSTA DEMANDA, SE PURDE EROSEGUIR CON BL RROCBSO SIN SU PARTICIPACION.
ENTONCES, LA COUTE PUEDE, SIN NOTIFICARIO, DECIDIR A FAVOR DEL DEMANDANTB ¥ HEQUEBIRA QUE HSTBD CUMPLA CON TODAS
~S PROVISIONES DE ESTA DEMANDA. POR P~AZON DE ESA DECISION, ES POSSIBLE QUE HSTED PUEDA PERDER DIN~RO, PROPIEDAD
COMPLAINT IN MORTGAGE FORECLOSURE
1. Plaintiff is COUNTRYWIDE HOME LO~NS INC., 7105 Corporate
Drive, PTX B-35, Plano, TX 75024-3632.
2. The name(s) and address(es) of the Defendant(s) is/are
DONALD M. ROBINDER, 253 Bullshead Road, Newville, PA 17241 and
MARTHA H. ROBINDER, 253 Bullshead Road, New~ille, PA 17241, who
is/are the mortgagor(s) and real owner(s) of the mortgaged property
hereinafter described.
3. On November 23, 1998, mortgagor(s) made, executed and
delivered a mortgage upon the premises hereinafter described to
INVESTAID CORP., which mortgage is recorded in the Office of the
Recorder of Deeds of Cumberland County in Mortgage Book 1503, Page
830. By Assignment of Mortgage dated November 23, 1998, the
mortgage was assigned to Plaintiff, which Assignment is recorded in
Assignment of Mortgage Book No. 596, Page 940. 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 payments of
principal and interest upon said mortgage due October 1, 2000, and
each month thereafter are due and unpaid, and by the terms of said
mortgage, upon default in such palrments 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 $ 68,428.25
Interest from 9/ 1/00
through 2/28/01 at 6.500% 2,194.20
Per diem interest rate at $12.19
Attorney's Fee at 5%
of Principal Balance 3,421.41
Late Charges 10/ 1/00- 2/28/01 133.65
Monthly late charge amount at $26.73
Costs of suit and Title Search 560.00
$ 74,737.51
Escrow Balance
Monthly Escrow amount $
$ -74,737.51
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 Sheriff's
Sale. If the Mortgage is reinstated prior to the Sale reasonable
Attorney's Fees will be charged based on work actually performed.
8. 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 true 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
the sum of $74,737.51, together with interest at the rate of
$12.19, per day and other expenses incurred by the Plaintiff which
are properly chargeable in accordance with the terms of the
mortgage, and for the foreclosure and sale of the mortgaged
premises. By: ~~ ~~/~' ?
GC~DBECKOMcCAFFERTY & McKEEVER
BY~ Joseph A. Goldbeck, Jr., Esq.
Attorney for Plaintiff
VERIFICATION
I, , as the representaEive of the
Plaintiff corporation within named do hereby verify that I am
authorized to and do make this verification on behalf of the
Plaintiff corporation and the facts set forth in the foregoing
Complaint are true and correct to the best of my knowledge,
information and belief. I understand that false statements therein
are made subject to the penalties of 18 Pa. C.S. 4904 relating to
unsworn falsification to authorities.
L~al Deserintion:
Al,l[, that certain tract ofinnd in North New, on Township, Cumberland CounW, Commonwealth of Pennsylvaula, more
particularly bounded and described as follows:
BEGI~NNI~G at a point, a corner posts, at lands now or formerly of John Hostetter; thence by lands now or fo~'merly of John
Hectetter, North 37 degrees 59 minutes 51 seconds West 203.56 feet to a corner post; thence by same South 54 degrees 05
minutes 55 seconds West 142.02 feet to a corner post; thence by same North 36 degrees 35 minutes 56 seconds West 211.27 feet
to a corner post; thence by same North 48 degrees 23 minutes 30 seconds East 316~31 feet to a corner post; thence by same
South 39 degrees 43 minutes 39 eeeonds East 267.17 feet to a corner post at the edge of an existing lane; thence by same South
46 de~rees 30 minotes 26 seconds West 99.00 feet to an iron pin; thence by same South 36 degrees 06 minutes 06 seconds East
1730.2~ feet to a post; thence by same South ~8 degrees 45 minutes 55 seconds West 83.28 feet to a curve post, the place of
BEGINNING.
CONSISTING of 2.156 acres, more or less.
PO Box 10221
VanNuys. CA 91410-0221
VanNuy$. CA 914'I0-0219
CerlJfied Mail No.
December 1,2000 Return Receipt Requested
Donald M Robinder EXHIBIT A Regular Mail
253 Bulishead Road
Newville, PA 17241-0000
Countrywide Loan # 4116736
Property Address:
253 Bullshead Road
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.
Countrywide Home Loans, Inc. (hereinafter "Countq/wide') se~ices your home loan. Your home loan is i~ serious default
because you have not made your required payments. The total amount now ~equired to reinstate your loan as of the
date of this letter is as follows:
Monthly Payments: 10/01/2000 ~ 11130/2000 ~) $534 58 $1.06g 16
Late Charges: 10/01/2000-11/30/2000 @ $2673 $53.46
Other Char~es: Uncollected Late Charges: $26.73
TOTAL DUE: $1,149.35
You may cure this default within THIRTY-FIVE (36) DAYS of the date of this letter, by paying to us the above amount of
$1,146.35, plus any additional monthly payments, late charges, fees and other applicable charges wfach may fall due
dudng this period. Such payment must be in the form of certified check, cashier's check or money ~rder, and made
payable to Count~/wide at P.O. Box 10221, Van Nuys, CA 91410q3221. 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
g~anted 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 odginal 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 of default is not made wffi3in
THIRTY-FIVE (35) DAYS, we a~so intend to immediately start a lawsuit to foreclose on your mortgaged property.
YOU MAY BE ELIGIBLE FOR FINANCIAL ASSISTANCE WHICH CAN SAVE YOUR HOME FROM FORECLOSURE
AND HELP YOU MAKE FUTURE MORTGAGE PAYMENTS.
The Commonwealth of Pennsylvania's Homeowner's Emergency Mortgage Assistance program may be able to
help you. Read the following notice to find out how the program works.
La noftficacion en adjunto es de surna irnportancia, pues afecta su derecho a confinuar vivielldo en su casa. Si
4116736-2 ~ ~h,~ R,~a
$1,149.35 AS OF 12/01/2000
P.O. Box 10219
Van Nuys, CA 91410-0219
II,l.,,,ll,hJ.,lllh,.Ih,,,J,l.,llhl..,lll,h.,ll,I
41 16736200011493501 14935
HUD-Approved Counseling Agencies - Pennsylvania
If you attend a face*to-face meeting with tfas lender, or w~th a consumer credd counseling agency identified in,this notice,
no further proceeding in mortgage foreclosure may take pisce for thirty (30) days after the date of this meeting. The
name, address and telephone number of our representative is: COUNTRYWIDE, 64~1 Legacy Drive, Piano, Texas
72567, Telephone Number: 1~00~69~654, Extension 756~.
The names and addresses of designated consumer credit counseling agencies are shovm on the attached sheet. It is
only necessary to schedule one face-ts-face meeting. You should advise Count~de of your intentions immediately.
If you have tried and are unable to resolve ~ problem at or after your face-to-face meeting, you have the right to apply
for financial assistance from the Homeowners' Emergency Mortgage Assistance Fund. In order to do this, you must fill
out, sign and file a completed Homeowners' Emergency Assistance Apptication with one of the designated consumer
credit counseling agencies listed on the attachment. An application for assistance may only be obtained from a
consumer credit counseling agency. The consumer credit counseling agency wi§ assist you in filling out your application
and will submit your completed application to the Pennsylvania Housing Finance Agency. Your application must be filed
or postmarked within thirly (30) days of your face-to-face meeting.
Available fands for emergency mortgage assistance are very limited. They will be disbursed by the Agency
under the eligibility criteria established by the Act
It is extremely important that you file your application promptly. If you do not do so, or if you do not follow the other time
periods set forth in this letter, foreclosure may proceed against your home immediately. It is extremely important that your
application is accurate and complete in every respect.
The Pennsylvania Housing F~nance Agency has ~xty (60) days to make a decision after it receives your application.
Dudng that ad~tional time, no foreclosure proceedings will be pursued against you if you have met the time requirements
set forth above. You will be notified directly by that Agency of its decision on you~ application.
The Pennsylvania Housing Fleance Agency is located at 2101 North Front Street, Post Office Box 8029, Hanisburg,
Pennsylvania 17105. Telephone No. 1-717-780-3800 or 1~00-342-2397 (toll free number). Persons with impaired
hearing can call 1~800-342-2397.
If the mortgage is foreclosed, your mortgaged property v~ll be sold by the Sheriff to pay off the mortgage debt. tt you
cure the default before we begin legal proceedings against you, you will still have to pay the reasonable attorney's fees
actually incurred, up to $50.00. However, if legal proceedings are started ageinst you, you wi# have to pay the reasonable
attorney's fees even if they are over $50.00. Any attorney's fees will be added to whatever you owe us, which may also
include our reasonable costs. If you cure this default within the thirb/-five day pedod, you wi# not be required to pay the
attorneys fees. YOU HAVE THE RIGHT TO REINSTATE AFTER ACCELERATION AND THE RIGHT TO ASSERT IN
THE FORECLOSURE PROCEEDING THE NON-EXISTENCE OF A DEFAULT OR ANY OTHER DEFENSE YOU
MAY HAVE TO ACCELERATION AND FORECLOSURE.
December 1,2000 Return Receipt Requested
Regular Mail
Martha H Robinder
253 Bulichead Road
Newvilie, PA 17241-0000
Countrywide Loan # 4116736
Property Address:
253 Bulishead Road
Newvilie, PA 17241-0000
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.
Count~peide Home Loans, Inc. (hereinafter "Countrywide"} services you~ home loan. Your home loan is in seheus default
because you have not made your required payments. The total amount now required to reirlstate your loan as of the
date of this ~etter is as follows:
Monthlv Payments: 10/01/2000-11/30/2008 @ $53458 $1,069.16
Late Charqes: 10/01/2000-11130/2000 @ $2673 $53.46
Other Charges: Iflncoliected Late Charges: $2673
TOTAL DUE: $1,149.35
You may cure this default within THIRTY-FIVE (35I DAYS of the date of this letter, by paying to us the above amount of
$1,149.35, plus any additional monthly payments, late charges, fees and other applicable charges which may fall due
during this period. Such payment mu~t be ill the form of certified check, cashier's check or money order, and made
payable to Counb3n~de at P.O. Box 10221, Van Nuys, CA 91410-0221. If yom' 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 fime 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 Ioall in monthly installments. If the full payment of the amount o1 default is not made within
THIRTY-FIVE (35I DAYS, we also intend to immediately start a tawsuit to foreclose on your mortgaged property.
YOU MAY BE EUGIBLE FOR FINANCIAL ASSISTANCE WHICH CAN SAVE YOUR HOME FROM FORECLOSURE
AND HELP YOU MAKE FUTURE MORTGAGE PAYMENTS.
The Commonwealth of Penllsylvania's Homeowner's Eme~ency Mortgage Assistance pro, ram may be able to
help you. Read the following notice to find out how the program works.
La notificacion en adjunto es de suma importancia, pues afecta su dead. ho a co~inuar viviendo en su casa. Si
no compreflde el conte~ido de esta notificacion obtemja una traducclen famediutamente Ilarnando a esta
age~tcia (Pennsylvania Housing Finance Agency) sin cargos al numero mencionado arriba. Usted puede ser
elegibfa para un prestamo del programa Ilamado 'Homeowner's Emergency Moltgage Assistance program' el
cua! puede salvar su casa de la perdida del de,echo a redimir su hipoteca.
You may be eligible for financial assistance that will prevent foreclosure on your mortgage if you comply wi~ the
provisions of the Homeowners' Emergency Mortgage Assistance Act of 1983 (the "Act"). You may be eligible for
emergency temporary ass/stance if your default has been caused by circ~Jmstances beyond your control, you have a
reasonable prospect of resuming your mortgage payments, and if you meet other eligibility requirements established by
the Pennsylvania HoUSing Finance Agency. Please read ali of this Notice It coatains an explanation of your rights.
Under the Act1 you are entitled to a temporary stay of foreclosure on your mortgage for thirt~ (30) days trom the date of
this Notice. Dudng that time you must arrange and attend a "face-to-face' meeting with a representafive of this lender, or
with a dss/gnated consumer credit counseling agency. The purpose of this meeting is to attempt to work out a
repayment plan, or to othew~ise settle your delinquency. This meeting must occur in the next thirty {30) days.
4116736-2 253 ~,=~.d ~o~
$1,149.35 AS OF 12/01/2000
P.O. Box 10219
Van Nuys, CA 91410-0219
II,l,,.,,fl,l.l,.lllh,,Ih.,,hl,.,lll,l.,.llhl.,,Ihl
411673620001149350114935
HUD-Approved Counseling Agencies - Pennsylvania
f you attend a face-to-face meeting wfth tfas lender, or with a consumer c~edit counseling agency ~denflfied n th s notice,
no farther proceeding in mortgage foreclosure may fake place for thirty (30) days after the date of thin meeting. The
name, address and telephone number of our represehtafive is: COUNTRYWIDE, 6400 Legacy Drive, Piano, Texas
72567, Telephone Number:. 1-800-669-6664, Extension 7fi56.
The names and addresses of designated consumer credit counseling agencies are shown on the attached sheet, ti is
only necessar/to schedule one face-to-face meeting. You should advise Countrywide of your intentions immediately.
If you have tried and are unable to resolve thin problem at or after you~ face-th-face meeting, you have Ute right to apply
for financial assisfance from the Homeowners' Emergency Mortgage Assistance Fund. In order to do thin, you m~st fill
out, sign and file a completed Homeow~em' Emergency Assistance ,~oplicagon ~ one of the designated consumer
credit counseling agencies listed on the aftachrnent. An application for escistance rnay only be obtained from a
consumer credit counseling agency. The consumer credit counseling agency will assist you in filling out your applicagou
and wilJ submit your completed appflcafion to the Pennsyivadia Houeleg Finance Agency. Your application must be filed
o~ postmarked within thirty (30) days of your face-te-face meeting.
Available funds for emergency mortgage assistance are very limited. They will be disbersnd by the Agency
under the eligibility criteria established by the Act
It is ex~'emely imporfa~t that you file your application promptly. If you do not do se, or if you do not follow the other time
periods set forth in this letter, foreclosure may proceed against your home irnmediately. It is extremely important that your
application in accurate and complete in every respect.
The Pennsylvania Housing F*mance Agency has sixty (60) days to make a decision after it receives your application.
During fllat additional time, no foreclosure proceedings wi# be pursued against you g you have met the time requirements
set forth above. You will be notified directS/by that Agency of ~ts decision on your app~afion.
The Pennsylvania Housing Finance Agency in located at 2101 North Front Sb-eet, Post Office Box 8029, Harrisburg,
Pennsylvania 17105. Telephone No. 1-717~78C~3800 or 1-800-342-2397 (fa# free number). Persons ~ impelled
hearing can call 1-800-342-2397.
If the mortgage is foreclosed, your mortgaged property will be sold by the Sheriff to pay off the mortgage debt. If you
cure the default before we beg~n legal proceedings against you, you will s~li have to pay the reasonable attorney's fees
actually incurred, up to $50.00. However, if legal proceedings are started against you, you will have to pay the reasonable
attorney's fees even if they are over $50,00. Any attorney's fees will be added to whatever you owe ~s, which may also
include our reasonable costs. If you cure this defadit within the thirty*five day period, you wfli not be reqel~ed to pay the
attorney's fees. YOU HAVE THE RIGHT TO REINSTATE AFTER ACCELERATION AND THE RIGHT TO ASSERT IN
THE FORECLOSURE PROCEEDING THE NON-EXISTENCE OF A DEFAULT OR ANY OTHER DEFENSE YOU
MAY RAVE TO ACCELERATION AND FORECLOSURE.
SHERIFF'S RETURN - NOT SERVED
CASE NO: 2001-01248 P
COMMONWEALTH OF PENNSYLVANIA
COUNTY OF CUHBERLAND
COUNTRYWIDE HOME LOANS INC
VS
ROBINDER DONALD M ET AL
R. Thomas Kline , Sheriff , who being duly sworn
according to law, says, that he made a diligent search and inquiry for
the within named DEPENDANT to wit:
ROBINDER MARTHA H but was
unable to locate Her in his bailiwick. He therefore returns the
COMPLAINT - MORT FORE
NOTICE
NOT SERVED , as to
the within named DEFENDANT , ROBINDER MARTHA H
DEFENDANT IS DECEASED.
Sheriff's Costs: So answers: ~ ~
Docketing 6.00 ~f/
NOT SE RVED RETURN 5.C, 0 ~~~
Affidavit .00 .
Surcharge 10.00 SHERIFF OF CUMBERLAND COUNTY
.00
'IF. 0U~--GOLDBECK, HCCAFFERTY, MCKEEVER
03/12/2001
Sworn and subscribed to before me
this 2~ ~ day of ~/b~-J--~
~2z~3 i A.D.
ProthOnotary '
SHERIFF'S RETURN - REGULAR
CASE NO: 2001-01248 P
COMMONWEALTH OF PENNSYLV/~NIA:
COUNTY OF CUMBERLAND
COUNTRYWIDE HOME LOANS INC
VS
ROBINDER DONALD M ET AL
DAWN L KELL Sheriff or Deputy Sheriff of
Cumberland County, Pennsylvani&, who being duly sworn according to law,
says, the within COMPLAINT - MORT FORE was served upon
ROBINDER DONALD M the
DEFENDANT , at 0014:29 HOURS, on the 9th day of March ~ 2001
at 253 BULLSHEAD ROAD
NEWVILLE, PA 17241 by handing to
DONALD M. ROBINDER
a true and attested copy of COMPLAINT - MORT PORE together with
NOTICE
and at the same time directing His attention to the contents thereof.
Sheriff's Costs: So Answers:
Service 8 68 "-"~~'~..~,~= ~
Affidavit 00
Surcharge 10 00 R. Thomas Kline
00
36 ~8 03/12/2001
GOLDBECK, MCCAFFERTY, MCKEEVER
Sworn and Subscribed to before By: ~~. ~
me this 2~; ~ day of Deputy Sheriff
~othonotary '
GOLDBECK McCAFFERTY & MCKEEVER ~'REBYCERTIFYTHATTHIS
BY: Joseph A. soldbeck, Jr. 18 ATRUE AND CORRECT COPY
At t orney I.D. # 16132 OF THE ORIGINAL FILED
Suite 500 - The Bourse Bldg.
111 S. Independence Mall East
Philadelphia, PA 19106
215-627-1322
Attorney for Plaintiff
COUNTRYWIDE HOME LOANS INC. : IN THE COURT OF COMMON PLEAS
7105 Corporate Drive :
PTX B-35 : OF CUMBERLAND COUNTY
Plans, TX 75024-3632 :
Plaintiff : CIVIL ACTION - LAW
:
vs. :ACTION OF MORTGAGE FORECLOSURE
DONALD M. ROBINDER /LND : Term
MARTHA H. ROBINDER : NO.O~--/,,~ C,O'~ L~7--~
(Mortgagor(s) and Real Owner(s)) :
253 Bullshead Road : ~%V%L ACTiOn4; MORTGAGE
Newville, PA 17241 :
Defendant (s) : l-t;,=~, ,--
THIS LAW FIRM IS A DEBT COLLECTOR AND WE ARE ATTEMPTING
TO COLLECT A DEBT OWED TO OUR CLIENT. ANY INFORMATION
OBTAINED FROM YOU WILL BE USED FOR THE PURPOSE OF
COLLECTING THE DEBT.
NOTICE
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 Co~mplaint and notice are served, by entering a written
appearance personally or by attorney and filing in writing with the court your defenses or objections to the
claims set forth againsc you. You are waIned that if you fail to do so the case may proceed without you and a
judgment may be entered against you by the Court without further notice for any money claimed in the Complaint
or for any other claim or relief requested by the Plaintiff. You may lose ,~ne¥ or property or other rights
important to you.
YOU SHOULD TAKE THIS PAPER TO YOUR LAWYER AT ONCE. IF YOU DO NOT ~AUR A LAWYER OR CANNOT AFFORD ONE,
GO TO OR TELEPHONE THE OFFICE SET FORT~ BELOW TO FIND OUT W~ERE YOU CAN GET LEGAL HELP.
Cumberland County Bar ASSOCiation
2 Liberty Avenue, Carlisle, PA
/800) 990-9108
Legal Services Inc.
8 Irvine Row, Carlisle, PA 17013
(717) 243-9400
AVISQ
LE FIAN DE~AbTDADO A USTED EN L~ CORTE. SI DESE~ DEFENDERSE COA~fP, A I~S QUEJAS PEREEEN~ADAS, ES
ABSOLUTAMENTE NECESS~JEIO QUE USTED RESPONDA DENTRO DE 20 DIAS DESPUES DR SER SERVIDO CON ESTA DEMANDA y AVISO.
PkRA DEFENDERSE ES NECESSARIO QUE USTED, 0 SUABOG~JDO, REGISTRE CON LA CORTE EN FOP34AEECRITA, EL PUNTS DE VISTA
DE USTED Y CUALQUIER OBJECCION CONTRA LAS QUEJAS EN ESTA DF24ANDA.
RECUERDE: SI USTED NO REPONDE A ESTA DEMANDA, SE PUEDE PROS~GUIR CON EL PROCESS SIN SU PARTICIFACION.
ENTONCES, LA COUTE PUEDE, SIN NOTIFICARIO, DECIDIR A FAVOR DEL DEMA~ANTE Y REQURRIRAQURUSTEDC~3MPLACONTODAS
L~S PROVISIONES DE ESTA DESk, NbA. PORRAZON DE ESA DECISION, ER POSSIBLE QUE USeD PURDA PERDER DINERS, PROPIEDAD
U OTROS DERECROS IMPORT~TES.
LLEVE ESTA DEMJ~NDA A UN A~ADO I~94EDIATAMENTE.
SI NO CONOCE A UN~OGILDO, LLAME AL "LAWYER REFERENCE SERVICE" (SERVICIO DE REFERENCIA DE ABOGADOS),
215 238 6300.
~oo) ~s-~o~ Iff T~Y,atmm~, I bel'e ume set my Im~
~ ~,~EFiEBY CERTIFY THAT THIS
IS ATRUE AND CORRECT COPY
COMPLAINT IN MORTGAGE FOREOLOS~.THE ORIGINAL FILED
1. Plaintiff is COUNTRYWIDE HOME LOANS INC., 7105 Corporate
Drive, PTX B-35, Plano, TX 75024-3632.
2. The name(s) and address(es) of the Defendant(s) is/are
DONALD M. ROBINDER, 253 Bullshead Road, Newville, PA 17241 and
M3~RTHA H. ROBINDER, 253 Bullshead Road, Newville, PA 17241, who
is/are the mortgagor(s) and real owner(s) of the mortgaged property
hereinafter described.
3. On November 23, 1998, mortgagor(s) made, executed and
delivered a mortgage upon the premises hereinafter described to
INVESTAID CORP., which mortgage is recorded in the Office of the
Recorder of Deeds of Cumberland County in Mortgage Book 1503, Page
830. By Assignment of Mortgage dated November 23, 1998, the
mortgage was assigned to Plaintiff, which Assignment is recorded in
Assignment of Mortgage Book No. 596, Page 940. 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 payments of
principal and interest upon said mortgage due October 1, 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 $ 68,428.25
Interest from 9/ 1/00
through 2/28/01 at 6.500% 2,194.20
Per diem interest rate at $12.19
Attorney's Fee at 5%
of Principal Balance 3,421.41
Late Charges 10/ 1/00- 2/28/01 133.65
Monthly late charge amount at $26.73
Costs of suit and Title Search 560.00
$ 74,737.51
Escrow Balance
Monthly Escrow amount $
$ 74,737.51
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 Sheriff's
Sale. If the Mortgage is reinstated prior to the Sale reasonable
Attorney's Fees will be charged based on work actually performed.
8. 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 true 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
the sum of $74,737.51, together with interest at the rate of
$12.19, 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. ~A~
By: ~ ~
Mc~EVER
BY~ Joseph A. Goldbeck, Jr., Esq.
Attorney for Plaintiff
VERIFICATION
I, , 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: J///O/
Leanl DeSCription:
Al~!. that certain tract of land in North Newton Township, Cumberland Counly, CommonWealth of Pennsylvan~ more
particularly bonded and described as follows:
BEGI~NI~qG at° point, a corner posts, at lands now or formerly of John Heetetter; thence by lands now or fo.rmerly of John
Hectettor, North 37 degrees 39 minn~s S1 seconds West 203.S6 feet to 8 corner post; thence by see South S4 degrees OS
minutes SS seCOnds West 142.02 feet to a corner post; thence by same North 36 degrees 35 minutes S6 Seconds West 211.27 feet
to a corner post; thence by same North 48 degrees 23 mlnu~s 30 seconds East 316.31 feet to a corner POSt; thanee by same
South 39 degrees 43 ~inutes 39 seconds East 267.17 feet to a corner post at the edge of an existing lane; thence by same Sooth
46 degrees 30 minUtes 26 Seconds '*Vest 99.00 feet to an iron pin; thence by same South 36 degrees 06 minUtes 06 seconds East
1730.25 feet too post; thenee by same South ~8 degrees 45 ml*~utes 55 seConds West 83.28 feet to a curve post, the place of
BEGINNING.
CONSISTING of 2.156 acres, more or less.
P.O Box 10221
Van Nuys, CA 91410-0221
Send payments to:
P.O. Box 10219
Van Nuys, CA 91410-0210
Cellffied Mail No.
December 1, 2000 Refum Receipt Requested
Donald M Robinder ExHIBiT A Reguiar Mall
253 Builshead Road
Newville, PA 17241~)000
Countxywide Loan # 4116736
Propan'y Add~ess:
253 Bullohead Road
Newville, PA 17241~)000
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.
Counbywide Home Loans, Inc. (herefaattef 'Cou~de') se~ices you~ home loan. Your home loan is i~ serious default
because you have not made your required payments. The total amount now required to leinstete your loan as of the
date of ~ letter is as follows:
Monthly Payments: 10/01/2000 - 11/30/2000 (~ $534.58 $1,0~9.16
Lat. e Cl~arqes: 10/01/2000 - 11/30/2000 @ $26.73 $53~46
Otiler (~ha~qes: Uncollected Late Charges: $26.73
TOTAL DUE: $1,149.3.5
YOU may cu~e this deteult within THIRTY-FIVE (35) DAYS of the date of this letter, by paying to us the above amount of
$1,149.35, plus any addi~onal mon~ payments, late charges, fees and other applicable charges wflinh may fall due
during this period. Such payment must be in the fo~rn of cer~ed check, cashier's check (~ money order, and made
payable to Count~vide at P.O. Box 10221, Van Nuys, CA 91410~0221. If your check or other payment is retemed to us
for insufficient funds or for any other reason, you will not have cured you~ default. No extension of ltme to cure will be
g~-anted due to a retsmed payment.
If you do not cure this default wi~in THIRTY-FIVE (35) DAYS, we v~l accelerate the payments dee on your hame loan.
Th~ means whatever is owing on the original amount borrowed wi~ be considered due immediately and you may lose the
chance to pay off you~ home loan in monthly lostelirnents, If the full payment of the amount of default is not made within
THIRTY-FIVE (36") DAYS, we a~o intend to immediately start a iswsu~t to foreclose on your mortgaged property.
YOU MAY BE ELIGIBLE FOR FINANCIAL ASSISTANCE WHICH CAN SAVE YOUR HOME FROM FORECLOSURE
AND HELP YOU MAKE FUTURE MORTGAGE PAYMENTS,
agencfa (Pennsylvania Housing Finance Agency) sin cargos al numero menctenado aniba. Usted puede set
4116736-2 2~ ~lr~ Ro~
$1,149.35 AS OF 12/01/2000
P.O. BOX 10219
Van Nuys, CA 91410-0219
II,l...,ll,h,h.lllh,,Ih..,hh.llM.,,.llhh.,Ihl
411673620001149350114935
HUD-Approved Counseling Agencies - Pennsylvania
If you attend a face-to-face meeting with this lender, or with a consumer credif counseling agency identified in.thle notice,
no farther proceeding in mortgage foreclosure may take place for thkty (30) days afrer the date of this meeting. The
name, add,ess and telephone number of our representative is: COUNTRYWIDE, 6400 Legacy Drive, pfano, Texas
72567, Telephone Number: 1-800669-6654, Extension 7556.
The names and addresses of designated cer~',~Jmer credit counsellog agencies are shown on the attached sheet_ It is
o~y necessary to schedule one face-to-face meeting. You should advise Country.de of your intenf~ons immediately.
If you have ~ied and are unable to resolve lille problem at or after you~ face-re-face meeting, you have the Hght fa apply
far financial assistance f~om the Homeowners' Emergency Mmtgege Assistance Fund. In order to do this, you must fili
~ sign arid file a completed Homeowners' Emergency Assistance Application with one of the designated consumer
credit counseling agencies listed on the attachment. An application for assistance may only be obtained from a
consumer eredit counseang agency. The consumer credit counseling agency w~l assist you in Ming out you~ application
and will submit your completed application to the Pennsylvania HoUSing F'mance Agency. Your application must be flied
or postmarked within thirty (30) days of you~ face-to-face meeting.
Available funds for emergency mortgage assistance are very Ibnited. They will be disbursed by the Agency
u~der the eligibility criteria established by the Act
It is ex'gemely important that you file your application promptly. If you do not do so, or if you (fo not follow the other time
periods set forth in this letter, foreclosure may proceed against your home immediately, it ~s extremely important that your
application is ac<;u~ate and complete in every respecL
The Pennsyivanfa Housing Finance Agency has sixty (60) days to make a decision after It receives youg application.
During that additional time, no foreclosure proceedings ~11 be pursued against you if you have met the time requirements
set forth above. You will be notified directiy by that Agency of its decision on your application.
The Pennsylvania HOUSing Finance Agency is located at 2t0t North Front Sb-eet, Post Office Box 8029, Harrisburg,
Pennsylvania 17105. Telephone No. 1-717-780-3800 or 1-800-342-2397 (toil bee number), persons with impaired
hearing can call 1 q}00-342-2397.
If the morlgage is foreclosed, your mortgaged property will be sold by the Sheriff to pay off the mor{gage debt. If you
cure the default befere we begin legal proceedings against you, you wi# still have to pay the reasonable attorney's fees
actual~ incun-ed, up to $50.00. However, if legal proceedings are shorted against you, you wi!J have to pay the reasonable
aifomey's fees even if they are over $50.00. Any aifomey's fees will be added to whatever you owe us, which may also
inciude our reasonable costs, if you cum this defauJt wi~in the thir¥five day pedod, you wi~ nut be required to pay the
aifomey's fees. YOU HAVE THE RIGHT TO REINSTATE AFTER ACCELERATION AND THE RIGHT TO ASSERT IN
THE FORECLOSURE PROCEEDING THE NON-EXISTENCE OF A DEFAULT OR ANY OTHER DEFENSE YOU
MAY HAVE TO ACCELERATION AND FORECLOSURE.
P,O. Box
VanN~/¥s~CA9,41~0219 EXHIBrF A certified Mail N0.
December 1,2000 Ream Recent Requ~ed
Regular Mail
253 ~l~ed Road
C~e L~ ~ 4116736
Prope~
253 Bull~ad Road
NOTICE OF INTENT TO FORECLOSE
YOUR HOME LOAN IS IN DEFAULT FOR THE REASONS SET FORTH IN THIS NOTICE.
YOU MUST TAKE AC~ON TO SAVE YOUR HOME FROM FORECLOSURE.
Co~de Home Loa~, I~. (h~e~a~ ~de~ ~c~ yo~ home loan. Y~ home ~an ~ ~ ~ de~
TOTAL DUE: $1,1~.35
Y~ may c~e ~ ~ ~ THIRd. NE (35) DAYS of ~e date of ~ Jeffer, by pa~ng to ~ ~ able amo~ of
$~,149~5,
If you do ~t ~e ~ de~uE ~n THIR~-FI~ (35) DAYS, ~ ~ acclimate ~ pa~ d~ ~ yo~ ho~ ~.
THIR~ (3~ DAYS, we a~o ~tend to imme~ate~ s~ a la~ to [me~ on y~r moP.ged pr~.
YOU ~Y BE E~IB~ FOR FISCAL ASS~T~CE WHICH CAN SAVE YOUR HOME FROM FORECLOSURE
AND HELP YOU MAKE FUTURE MORTGAGE PAYMENTS.
~ ~ ~ adju~ es de su~ ~, ~ a~ su de~ a ~fi~r v~o en su ~sa. Si
c~l ~e ~ar su ~a ~ la ~a del de~ a ~ir su hi~.
4116736-2 2~ e.,~h~,~ ;,~
$1,149.35 AS OF 12/01/2000
P.O. Box 10219
Van Nuys, CA 91410-0219
II,l,,,,,ll,h,l.,lllh.ll,,.,I,l.,lll.l,..llhl.. Jhl
411673620001149350114935
HUD-Approved Counseling Agencies - Pennsylvania
If you aifend a face-fo-face meeting with this lender, or watt a consumer credit counseling agency identified il;~thts notice,
no ftather proceeding in mortgage fofec~oonre may take place for thirty (30) days alter the dale of this meeting, The
name, address and tetephane number of our mpreseutative ~s: COUNTR'Y~NIDE, 6400 Legacy Drive, Piano, Texas
72567, Telephone Number:. 1-800-6696654, Extcms/on 7556.
The names and addresses of designated consumer credit cou~selin~ agencies are shown on the alfached sheet. It is
only neoessary to schedule one tace-to-face meeting. You should advise Countq/wide of your intentions immediately.
If you have t~ed and are unable to resnive this problem at or alter your face-fa-face meeting, you have the tight to appty
for financial assistance from the Homeowners' Emergency Mortgage Assistance Fund. In order to do this, yon must ~
out, sign and file a compleled Homeownem' Emergency Assistance App#cation with one of the designated consumer
credit counsel/ag agencies listed on the attachment. An applicalian for assistance may only be obtained from a
consumer credit counseileg agency. The consumer credit counseling agency vail assist you in fi~ing out your apptcation
and w~i submit your completed app~cafion to the Pennsylvania Housing F-~tance Agency. Your appacafion must be filed
or postmarked wtihle tblrly (30) days of your' face-to-face meeting.
Available funds for eme~mtcy mortgage assistance are very limited. They will be disbursed by the Agency
under the eligibility ctlterta established by the Act
It is extremely important that you file your application promptly. If you do not do so, or if you do not follow lite outer time
periods set fodh in ~ letter, foreclosure may proceed against your home immediately, tt is extremely important that your
application is accurate and complete le ever/respect.
The Pennsylvania HOUSing tm~nance Agency has sixty (60) days to make a decision alter ti receives yotw spplication.
During that additional time, no foreclos~e p¢oceedinga MI be pursued against you if you have met the time requirements
set fmffi above. You will be nof~ed direcity by that ^gency of tis decision on your application.
The Pennsylvania Honsfag Finance Agency is located at 2101 North Front Slreet, Post Office Box 8029, Hamsbu~g,
pennsylvania 17105. Telephone No. 1-717-760-3800 or 1-800-342~2397 (toil free number). Persons wffh impaired
hearing can call 1-800-342~2397.
If the mortgage is foreclosed, your mortgaged property wi'Il be sold by the Sheriff to pay off the mo~ge debL if you
cure the det~auit before we begin legal proceedfags against you, you vail slffl have th pay the reasonable attorney's fees
astualiy incun-ed, up to $50.00. However, if legal proceedings are started against you, you Will have to pay the reasonable
attorney's fees even if they are over $50.00. Any attorney's fees wiJl be added to whatever you owe us, which may also
include om reasonable costs, if you cure thle default within the thirty*five day period, you wilt not be required to gay the
attorney's fees. YOU HAVE THE RIGHT TO REJNSTATE AFTER ACCELERATION AND THE RIGHT TO ASSERT IN
THE FORECLOSURE PROCEEDING THE NON-EXISTENCE OF A DEFAULT OR ANY OTHER DEFENSE YOU
MAY HAVE TO ACCELERATION AND FORECLOSURE.
(Rule of Civil Procedure No. 236) Revised
IN THE COURT OF COMMON PLEAS OF CUMBERLARD COUNTY, PENNSYLVANIA
CIVIL ACTION - LAW
Countrywide Home Loans, Inc.
, Plaintiff
Vs. : NO. 01-1248~Civil Term
Donald M. Robinder
, Defendant(s)
Notice is given that a Judgment in the above captioned
matter has been entered against you on May /~ , 2001.
If you have any questions concerning this matter please
contact: ~h ~G
Jo oldbeck, Jr.
At~rne~ for Plaintiff
**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 RE CONSTRUED TO BE ANATTEMPT TO COLLECT A DEBT, BUT ONLY
ENFORCEMENT OF A LIEN AGAINST PROPERTY. **
GOLDBECK McCAFFERTY & McKEEVER
By: Joseph A. Goldbeck, Jr.
Attorney I.D. #16132
Suite 500 - The Bourse Bldg. ATTORNEY FOR PLAINTIFF
111 S. Independence Mall East
Philadelphia, PA 19106
(215) 627-]322
Countrywide Home Loans, Inc. : CUMBERLAND COUNTY
7105 Corporate Drive, PTX Bo35 : COURT OF COMMON PLEAS
Plano, TX 75024-3632
Vs. : CIVIL DIVISION
Donald M. Robinder : NO 01-1248~Civil Term
253 Bullshead Road
Newville, PA 17241
Martha H. Robinder (Deceased)
PRAECIPE FOR JUDGMENT FOR FAILURE TO
ANSWRR AND ASSESS~D~T OF DAMAGES
TO THE PROTHONOTARY:
Kindly enter judgment in favor of the Plaintiff and against
Donald M. Robinder, Defendant 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 $75,744.14
Interest - 3/1/01 - 5/15/01 $ 926.44
Late Charges $80.19
Escrow Debit ~
TOTAL $75,744.14
I hereby certify that (1) the addresses of the Plaintiff and Defendant ar,
as shown above, and (2) that notice has been given in accordance with Rule
237.1, copy attached.
PRO PROTHY ~
I hereby certify that the above names are correct and that the
precise residence address of the judgment creditor is 7105 Corporate Drive,
PTX B-35, Plano, TX 75024-3632 and that the name and last known address of
the Defendant is:
Donald M. Robinder,
253 Bullshead Road, Newville, PA 17241
Martha H. Robinder (Deceased)
TO: DONALD M. ROBINDER
253 Bullshead Road
New~ille, PA 17241
COUNTRYWIDE HOME LOA~S INC.
7105 Corporate Drive : IN THE COURT OF COMMON PLEAS
PTX B-35 :
Plano, TX 75024-3632 : OF CUMBERLAND COUNTY
Plaintiff :
vs~ : CIVIL ACTION - LAW
DONALD M. ROBINDER AND MARTHA H. :
ROBINDER (Mortgagor(s)) : ACTION OF MORTGAGE FORECLOSURE
(Record Owner(s)) :
253 Bullshead Road : Term
Newville, PA 17241 : No. 01~1248 CIVIL TERM
Defendant(s)
THIS LAW FIRM IS A DEBT COLLECTOR AND WE ARE ATTEMPTING TO COLLECT A
DEBT OWED TO OUR CLIENT. ANY INFOPd~ATION OBTAINED FROM YOU WILL BE USED
FOR THE PURPOSE OF COLLECTING THE DEBT.
TO: DONALD M. ROBINDER
253 Bullshead Road
Newville, PA 17241
DATE OF THIS NOTICE: March 30, 2001
IMPORTANT NOTICE
YOU ARE IN DEFAULT BECAUSE YOU HAVE FAILED TO ENTER A WRITTEN
APPEARANCE PERSONALLY OR BY ATTORNEY AND PILE IN WRITING WITH THE COURT
YOUR DEFENSES OR OBJECTIONS TO THE CLAIMS SET FORTH AGAINST YOU. UNLESS
YOU ACT WITHIN TEN (10) DAYS FROM THE DATE OF THIS NOTICE, A JUDGMENT
MAY BE ENTERED AGAINST YOU WITHOUT A HEARING AND YOU MAY LOSE YOUR
PROPERTY OR OTHER IMPORTANT RIGHTS. YOU SHOULD TAKE THIS NOTICE TO A
LAWYER AT ONCE. IF YOU DO NOT HAVE A LAWYER OR CANNOT AFFORD ONE, GO TO
OR TELEPHONE THE FOLLOWING OFFICE TO FIND OUT WHERE YOU CAN GET LEGAL
HELP:
Cumberland County Bar Association
2 Liberty Avenue, Carlisle, PA
(800) 990-91108
GOLDBECK McCAFFERTY & McKEEVER
BY: Joseph A. Goldbeck, Jr., Esq.
Attorney for Plaintiff
Suite 500 - The Bourse Bldg.
111 S. Independence Mall East
Philadelphia, PA 19106
215-627-1322
GOLDBECK, MCCAFFERTY & MCKEEVER
By: Joseph A. Goldbeck, Jr.
Attorney I.D. #16132 ATTORNEY FOR PLAINTIFF
Suite 500-The Bourse Bldg.
111 S. Independence Mall East
Philadelphia, PA 19106 COURT OF COMMON PLEAS
(2~5) 627-1322 CIVIL DIVISION
Countrywide Home Loans, Inc.
Vs. No. 01-1248-Civil Term
Donald M. Robinder CUMBERLAND COUNTY
Martha H. Robinder (Deceased)
VERIFICATION OF NON-MILITARY SEEVICE
JOSEPH A. GOLDBECK, JR., ESQUIRE, hereby verifies that he is
attorney for the Plaintiff in the above-captioned matter, and that on
information and belief, he has knowledge of the following facts, to
wit:
(a) that the defendant is not in the Military or Naval
Service of the United States or its Allies, or otherwise within the
provisions of the Soldiers' and Sailors' Civil Relief Act of Congress
of 1940, as amended.
(b) that defendant Donald M. Robinder, is over 18 years of
age, and resides at 253 Bullshead Road,Newville, PA 17241.
This statement is made subject to the penalties of 18 Pa.
C.S. Section 4904 relating to unsworn falsification to authorities.
J~oPr~.'GOLDBECK, JR. for Plaintiff
May 16, 2001
Countrywide Home Loans, Inc. : CUMBERLAND COUNTY
: COURT OF COMMON PLEAS
Plaintiff : CIVIL DIVISION
Vs.
Donald M. Robinder
Martha H. Robinder (Deceased) = NO. 01-1248-Civil Term
Defendant(s)
A~FIDAVIT PURSUANT TO RULE 3129.1
Co,~n~rywide H~m~ Lo~ns. Inc., 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
253 Bullshead Road, Newville. PA 17241.
1. Name and address of owner(s) or reputed owner (s):
Name Address (if address cannot be reasonably
ascertained, please so indicate)
Donald M. Robinder 253 Bullshead Road
Newville, PA 17241
Martha H. Robinder (Deceased)
2. Name and address of defendant(s) in the judgment:
Name Address (if address cannot be reasonably
ascertained, please so indicate)
SA~4~ A~ AmOVE
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)
4. Name and address of the last recorded holder of every mortgage of
record:
Name Address (if address cannot be reasonably
ascertained, please so indicate)
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)
6. Name and address of every other person who has any record
interest in the property and whose interest may be affected by the
sale:
Name Address (if address cannot be reasonably
ascertained, please so indicate)
~,mherl~d Co~,nt~y Dept. of P.O. Box 320
Domestic Relations Carlisle, PA 17013
Pa Dept. of P~,hlic Welfare ~ealt~ ~d Welfare Bldg. Room 432
Bureau of Child Support Enforc-ment P.O. Box 2675
Harrisburg, PA 17105
Co~onwealth of PA 6=h Floor, Strawberry Square
Bureau of Indivldual Tax Dept. 280601
Inheritance Tax Division Harrisburg, PA 17128
Att= Jo~ Murph~
Internal Revenue Service 13~h Floor, Ste. 1300
Federated Investors Tower 1001 Liberty Avenue
Pittsburgh. PA 15222
Dept. of P~hlic Welfare P.O. Box 8486
PPL Casualty Unit Willow Oak BuildiD~g
Estate Recovery Program Harrisburg, PA 17105-8486
7. 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.
May 16, 2001 ~
JJ~ph~oldbeck, Jr.
At~rne}~for Plaintiff
GOLDBECK, MCCAFFERTY & MCKEEVER
By: Joseph A. Goldbeck, Jr.
Attorney I.D. #16132 ATTORNEY FOR PLAINTIFF
Suite 500-The Bourse Bldg.
111 S. Independence Mall East
Philadelphia, PA 19106 COURT OF COMMON PLEAS
(215) 627-1322
Countrywide H~ne Loans, Inc. CUMBERLAND COUNTY
CIVIL DIVISION
Vs. NO. 01-1248-Civil
Term
Donald M. Robinder
Martha H. Robinder (Deceased)
CERTIFICATION
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:
( ) 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.
GOLDBECK McCAFFERTY & McKEEVER
By: Joseph A. Goldbeck, Jr.
Attorney I.D. #16132
Suite 500 - The Bourse Bldg. ATTORNEY FOR PLAINTIFF
111 S. Independence Mall East
Philadelphia, PA 19106
(215) 627-1322
Countrywide Home Loans, Inc. : CUMBERLAND COUNT"f
: COURT OF COMMON PLEAS
Plaintiff : CIVIL DIVISION
Vs.
Donald M. Robinder
Martha H. Robinder (Deceased) : NO.01-1248-Civil Term
Defendant(s)
NOTICE OF S~RRIFF'S SALE OF R~AT, ESTATE
TO: Donald M. Robinder
253 Bullshead Road
Newville, PA 17241
THIS FIRM IS A DEBT COLLECTOR ATTEMPTING TO COLLECT A DEBT
AND ~ INFORMATION OBTAINED WILL BE USED FOR THAT PURPOSE.
IF YOU HAVE PREVIOUSLY RECEIVED A DISCHA=RGE IN BA/qKRUPTCY,
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 253 Bullshead Road, New~ille, PA
~ is scheduled to be sold at the Sheriff's Sale on S~t-~her 5.
2001 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 $75.744.14 obtained by Co,,ntr~ide H~e Loans. Inc.
{the mortgagee) against you.
NOTICE OF OW1TER'S RIGHTS
YOU MAY BE ~RL~ TO P~R1~ENT THIS S~RRIFF'S SAT.R
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:
(215) 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 ~mLE TO SAVE YOUR PROPERTY AND YOU ~AVE OTHER RIGHTS
EVEN IF THE SHERIFF'S SAT.E DOES TA~R PT.~CE.
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 (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
PRAECIPE FOR WRIT OF EXECUTION - (MORTGAGE FORECLOSURE)
P.R.C.P. 3180-3183
Countrywide Home Loans, Inc. .. COURT OF COMMON PLEAS
Plaintiff .- CUMBERLAND COUNTY, PA
Vs. : NO: 01-1248-Civil Term
Donald M. Robinder : PRAECIPE FOR WRIT OF EXECUTION
Martha H. Robinder (Deceased) (MORTGAGE FORECLOSURE)
Defendant(s)
TO THE OFFICE OF THE PROTHONOTARY:
Issue writ of execution in the above matter:
Amount Due $75,744.14
Interest from 5/15/01 to sale date $ and Costs
at $12.45 per diem
Total $
111 S. Independence Mall East
Philadelphia, PA 19106
Attorney for Plaintiff
Note: Please attach description of property.
ALL THAT CERTAIN tract of land situate in North Newton Township, Cumberland
County, Commonwealth of Pennsylvania, more particularly bounded and described as
follows:
BEGINNING at a point, a comer post, at lands now or formerly of John Hostetter; thence
by lands now or formerly of John Hostetter, North 37 degrees 59 minutes 51 seconds
West 203.56 feet to a comer post; thence by same South 54 degrees 05 minutes 55
seconds West 142.02 feet to a comer post; thence by same North 36 degrees 35 minutes
56 seconds West 211.27 feet to a comer post; thence by same North 48 degrees 23
minutes 30 seconds East 316.31 feet to a comer post; thence by same South 39 degrees
43 minutes 39 seconds East 267.17 feet to a comer post at the edge of an existing lane;
thence by same South 46 degrees 30 minutes 26 seconds West 99.00 feet to an iron pin;
thence by same South 36 degrees 06 minutes 06 seconds East 173.25 feet to a post;
thence by same South 58 degrees 45 minutes 55 seconds West 83.28 feet to a comer post,
the place of BEGINNING.
Tax parcel #30-08-0593-038
GOLD~ECK ~cCAFFERTY & 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.
7105 Corporate Drive : IN THE COURT OF COMMON PLEAS
PTX B-35 :
Plano, TX 75024-3632 : OF CUMBERLAND COUNTY
Plaintiff :
vs. : CIVIL ACTION - LAW
DONALD M. ROBINDER AND :
MARTHA H. ROBINDER : ACTION OF MORTGAGE FORECLOSURE
253 Bullshead Road :
Newville, PA 17241 : Term
Defendant : No. 01-1248 CIVIL TERM
CERTIFICATE OF SERVICE
PURSUANT TO Pa.R.C.P. 3129.2(c) (2)
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).
(W) Certified mail by Joseph A. Goldbeck, Jr. (original green Postal
return receipt attached) ~D Ro~D~
( ) 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).
( ) Acknowledgment of Sheriff's Sale by Attorney for Defendant(s) (proof
of acknowledgment attached).
( ) Ordinary mail by Sheriff's Office to Attorney for Defendant(s) of
record.
IF SERVICE WAS ACCOMPLISHED BY COURT ORDER.
( ) Premises was posted by Sheriff's Office/competent adult (copy of
return attached).
( ) Certified Mail & ordinary mail by Sheriff's Office (copy of return
attached).
( ) Certified Mail & ordinary mail by Joseph A. Goldbeck, Jr. (original
receipt(s) for Certified 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,
Jr., Esquire (copies of proofs of mailing attached). that~!stateme ~
The undersigned understands the herein are subject to the
penalties provided by 18 P.S. Secti~904./
t. BG~~~.submitted,
GO ~AFFERTY & McKEEVER
A. Goldbeck, Jr.
~3rney r Plaintiff
7106 4575 1294 3042 8853
T .DONALD M EO;:tlNE~ER
O '
25:5 Bullshead Road,
Newville, PA 17241
CUMBEi~LAND
SENDER:
GOLDBECK MCCAFFERTY & MCKEEVER -
May 95, ~998
REFERENCE:
ROBINDER,DONALD M. /
CWD-1070
pS Form 3800, June 200~I/-
5/01
RETURN Postage
RECEIPT Certified Fee
SERVICE
Return Receipt Fee
Restricted Delivery
Total Postage & Fees .~- ....
US Postal Service , ¢, \
Receipt for .)'; i¢~"
Certified Mail ',~! },, ,,}""~
NO Insurance Coverage Provided
AFFIX POSTAGE TO MAIL PIECE TO COVER FIRST CLASS
POSTAGE. CERTIFIED FEE, ~RETURN RECEIPT FEE ANU
CHARGES FOR ANY SELECTED OP FIONAL FiERV)CES
RE~oBINDER,DONAUD M./CWD-qO?O 9/S/O'ls?OE~: C;OLP~'ICCAFF£ffTY&MCKE:EYER-MayIS,'~99~
PS FoTm 3Bll, June 2000 Domestic Return Receipt
· PRINT YOUR NAME, ADDRESS AND ZIP CODE ~3ELOW ·
~,,,lll,h,,,,llll,,,,ll,,,,I,I,hl,,,,lll,l,,,tl,,I
GOLDBECK McCAFFERTY & McKEEVER
SUITE 500 ~ THE BOURSE BUILDING
111 SOUTH INDEPENDENCE MALL EAST
PHILADELPHIA PA 19106~2519
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.
7105 Corporate prive : IN THE COURT OF COMMON PLEAS
PTX B-35 : /-- ~
Plano, TX 75024-3632 : OF~.~__R_R_R_R_R_R_R_R_R~OUNTY
Plaintiff : CIVIL ACTION - LAW
:
rs. :ACTION OF MORTGAGE FORECLOSURE
:
DONALD M. ROBINDER AND MARTHA H. : Term
ROBINDER (Mortgagor(s) and : No. 01-1248 CIVIL TERM
Record Owner(s)) :
253 Bullshead Road :
Newville, PA 17241 :
Defendant(s) :
SUGGESTION OF DEATH
It is respectfully suggested that Defendant MARTHA H.
ROBINDER is deceased, having departed this life on December 27,
2000. Accordingly, the title vests soley in DONALD M. ROBINDER.
Attorney for Plaintiff
qountrywide Home Loans, Inc. = CU~BERLAi~D COD1TI"I
= COURT OF COMMON PLEAS
Plaintiff = CIVIL DIVISION
Vs.
Donald M. Robinder
Martha H. Robinder (Deceased) = NO. 01-1248-Civil Term
Defendant{s)
5~p~¢~I~LA~FIDAVIT PURSUANT TO RULE 3129.1
Co~ntrywide Home Lo~ns. Inc., 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
253 Bullshead Road, Newville. PA 17241.
1. Name and address of owner(s) or reputed owner (s):
Name Address (if address cannot be reasonably
ascertained, please so indicate)
Donald M. Robi~der 253 Bullshead Roa~
Newville, PA 17241
Martha H. Robinder (Deceased)
2. Name and address of defendant(s) in the judgment:
Name Address (if address cannot be reasonably
ascertained, please so indicate)
SA~ AS AmOVE
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)
4. Name and address of the last recorded holder of every mortgage of
record:
Name Address (if address cannot be reasonably
ascertained, please so indicate)
None
5. ~ame 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)
6. Name and address of every other person who has any record
interest in the property and whose interest may be affected by the
sale:
Name Address (if address cannot be reasonably
ascertained, please so indicate)
~,mherland Co~,nty Dept. of P.O. Box 320
Domestic Relations Carlisle. FA 17013
Pa D~t. of P~hlic Welfare Health and Welfare Bldg. Room 432
Bureau of Child S%%~ort Enforc.m.nt P.O. Box 2675
Harrisburg, PA 17105
Commonwealth of PA 6th Floor. Strawberry Square
Bureau of Individual Tax Dept. 280601
IDheritance Tax Division ~arrisburg. PA 17128
Att: John Murphy
Internal Revenue Service 13=~ Floor, Ste. 1300
Federated Investors Tower 1001 Liberty Avenue
PittsburgB. PA 15222
Dept. of P~hllc Welfare P.O. Box 8486
PPL Casualty Unit Willow Oak Building
Estate Recovery Program Harrisburg, PA 17105-8486
CI~SP,-N~.. cio 6%,~ ~e~C' ~..~. f4'- 1q3~1-
7. 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 relatin9 to unsworn falsification to
authorities.
May 16, 2001 ~
JJ~phd~oldbeck, Jr.
A~brne~/for Plaintiff
Countrywide Home Loans, Inc. In The Court of Common Pleas of
Cumberland County, Pennsylvania
VS Writ No. 2001-1248 Civil Term
Donald M. Robinder and Martha H.
Robinder (deceased)
R. Thomas Kline, Sheriff, who being duly sworn according to law, states this writ
is returned STAYED pursuant to instructions from Attorney Joseph A. Goldbeck, Jr.
Sheriff's Costs:
Docketing 30.00
Surcharge 20.00
Posting Handbills 15.00
Law Library .50
Prothonotary 1.00
Share of Bills 25.66
Mileage 17.78
Levy 15.00
Advertising 15.00
Certified Mail 2.39
Poundage 11.92
Postpone Sale
Law Journal 228.20
Patriot News 225.60
$608.05 paid by attorney
09-20-01
Sworn and subscribed to before me So .A~..~.,wef.~:
This !~- day of(~d~,
'~ ' R. Thomas Kline, Sheriff
2001, A.D.~ ~ ~
BY
Prothonotary Retil Estate Deputy
Countrywide Home Loans, Inc. = CU~ERLAND COUN~
= CO~-RT OF COMMON PLEAS
Plaintiff = CIVIL DIVISION
Vs.
Donald M. Robinder
Martha H. Robinder (Deceased) = NO. 01-1248-Civil Term
Defendant(s)
AFFIDAVIT Pb-RSU~=NT TO RULE 3129.1
Co~ntr~ide ~me Loans, Inc., 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
253 Bullshead Road. Newville. PA 17241.
1. Name and address of owner(s) or reputed owner (s):
Name Address (if address cannot be reasonably
ascertained, please so indicate)
Donald M. Robinder 253 Bullshead Roa~
Newville. PA 17241
Martha H. RobiDder (Deceased)
2. Name and address of defendant(s) in the judgment:
Name Address (if address cannot be reasonably
ascertained, please so indicate)
SA~ A~ AROVE
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)
4. Name and address of the last recorded holder of every mortgage of
record:
Name Address (if address cannot be reasonably
ascertained, please so indicate)
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)
6. Name and address of every other person who has any record
interest in the property and whose interest may be affected by the
sale:
Name Address (if address cannot be reasonably
ascertained, please so indicate)
~,mherl~nd Co~ty Dept. of P.O. Box 320
Domestic Relations Carlisle, PA 17013
Pa Dept. of P~,hlic Welfare Health ~nd Welfare Bl~g, Roo~ 432
Bureau of Child Support Enforc.ment P.O. Box 2675
Harrisburg. PA 17105
Commonwealth of PA 6th Floor, Strawberry Square
Bureau of Individual Tax Dept. 280601
IDheritance Tax Division Harrisburg, PA 17128
Att: Job~ Murphy
Internal Revenue Service 13th Floor, Ste. 1300
Federated Investors Tower 1001 Liberty Avmnue
Pittsburgh. PA 15222
Dept. of P~,hlic Welfare P.O. Box 8486
PPL Casualty Unit Willow Oak Building
Estate Recovery Program Harrisburg, PA 17105-8486
7. 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.
J ~oldbeck, Jr.
A t~brne~/for Plaintiff
GOLDBECK McCAFFERTY & McKEEVER
By: Joseph A. Goldbeck, Jr.
Attorney I.D. #16132
Suite 500 The Bourse Bldg. ATTORNEY FOR PLAINTIFF
111 S. Independence Mall East
Philadelphia, PA 19106
(215) 627-1322
Countrywide Home Loans, Inc. : CIR4~ERLAND COUNTY
: COURT OF COMMON PLEAS
Plaintiff : CIVIL DIVISION
Vs.
Donald M. Robinder
Martha H. Robinder (Deceased) : NO.01-1248-Civil Term
Defendant(s)
NOTICE OF SHERIFF'S SAI,E OF RRAT, ESTATE
TO: Donald M. Robinder
253 Bullshead Road
New~ille, PA 17241
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 253 Bullshead Road, New~zille, PA
~ is scheduled to be sold at the Sheriff's Sale on Se4~t~ml~er 5,
2001 at 10:00 a.m., in Cumberland County, Cumberland County Courthouse,
Commissioners Hearing Room, 2n~ Floor, Carlisle, PA 17013 to enforce the
court judgment of $75,744.14 obtained by Co~,ntrywide Home Loans, Inc.
(the mortgagee) against you.
NOTICE OF OWNER'S RIGHTS
YOU MAY BE ARLE TO PR~7~ENT THIS SHERIFF'S SA?.E
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:
(215) 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 ~AVE OTHER RIGHTS
EVEN IF T~E SHERIFF'S SAI,E DOES TA~E 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 (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 0m, GO TO OR TELEPHO~ THE OFFICE LISTED
BELOW TO FIND OUT W~ERE 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
ALL THAT CERTAIN tract of land situate in North Newton Township, Cumberland
County, Commonwealth of Pennsylvania, more particularly bounded and described as
follows:
BEGINNING at a point, a comer post, at lands now or formerly of John Hostetter; thence
by lands now or formerly of John Hostetter, North 37 degrees 59 minutes 51 seconds
West 203.56 feet to a comer post; thence by same South 54 degrees 05 minutes 55
seconds West 142.02 feet to a comer post; thence by same North 36 degrees 35 minutes
56 seconds West 211.27 feet to a comer post; thence by same North 48 degrees 23
minutes 30 seconds East 316.31 feet to a comer post; thence by same South 39 degrees
43 minutes 39 seconds East 267.17 feet to a comer post at the edge of an existing lane;
thence by same South 46 degrees 30 minutes 26 seconds West 99.00 feet to an iron pin;
thence by same South 36 degrees 06 minutes 06 seconds East 173.25 feet to a post;
thence by same South 58 degrees 45 minutes 55 seconds West 83.28 feet to a comer post,
the place of BEGINNING.
Tax pamel #30-08-0593-038
WRIT OF EXEcuTION and/or ATTACHMENT
COMMONWEALTH OF PENNSYLVANIA) NO. 01-1248 CIVIL 1~~X TE~n
COUNTY OF CUMBERLAND) CIVIL ACTION - LAW
TO THE SHERIFF OF Cumber'la~d COUNTY:
To satisfy the debt, interest and costs due Countrywide Home T,oans, Tnc,
PLAINTIFF(S)
from Donald M. Robinder and Martha H. Robinder, 253 Bullshead Road, Newville, PA 17241
DEFENDANT(S)
(1) You are directed to levy upon the propedy of the defendant(s) and to sell See ~eaal 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/are enjoined from paying any
debt to or for the account of the defendant(s) and' from deiivering any propedy of lhe defendant(s) or otherwise disposing
thereof;
(3) If property of the defendant(s) not levied upon an subject to attachment is found in the possess on 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 $75,744.14 L.L. $.50
fr~n 5/15/01 to sale date at
Interest $12.45 pez diem Due Pr0thy $1.00
Atty's Comm % Other Costs
A~y Paid $129.68
Plaintiff Paid
Date: May 18, 2001 Curtis R. Long
Prothonotary, Civil Division
Deputy
REQUESTING PARTY:
Name Joseph A. Goldbeck, Jr.
Suite 500 - The Sourse slog.
Address: 111 S. Ind~epe, nd,,=nc
Philadelphia, PA 19106
Attorney for: Plaintiff _
Telephone: 214-627-1322
Supreme Court ID No. 16132
REAL ESTATE SALE
..,,, /'~o.~. ~. :3, ,2.00/ th(. ,,~erm ~evied upon the Ome~,~
interest in the rea~ r~,~- ~?*,' ~'~dn_r ~ ~~~~
Cumberland County, ~ ¢~ ~meered as: 2~.~ ~~ ~
~~ and mo,~ ~JN &~~ Exhibit "A" filed with
this writ and by this refere,, :,'ated herein.
THE PATRIOT NEWS
THESUNDAY PATRIOT NEWS
Proof of Publication
Under Act No. 587, Approved May 16, 1929
Commonwealth of Pennsylvania, County of Dauphin} ss
James L, Clark being duly sworn according to law, deposes and says:
That he is the Acounts Receivable Manager of The Patriot News Co., a corporation organized and existing
under the laws of the Commonwealth of Pennsylvania, with its principal office and place of business at 812 to 818
Market Street, in the City of Harrisburg, County of Dauphin, State of Pennsylvania, owner and publisher of The
Patriot-News and The Sunday Patriot-News newspapers of general circulation, printed and published at 812 to 818
Market Street, in the City, County and State aforesaid; that The Patriot-News and The Sunday Patriot-News were
established March 4th, 1854, and September 18th, 1949, respectively, and all have been continuously published
ever since;
That the printed notice or publication which is securely attached hereto is exactly as printed and published in
their regular daily and/or Sunday/ Metro editions which appeared on the 24th and 31st day(s) of July and the 7th
day(s) of August 2001. That neither he nor said Company is interested in the subject matter of said printed notice
or advertising, and that all of the allegations of this statement as to the time, place and character of publication are
true; and
That he has personal knowledge of the facts aforesaid and is duly authorized and empowered to verify this
statement on behalf of The Patriot-News Co. aforesaid by virtue and pursuant to a resolution unanimously passed and
adopted severally by the stockholders and board of directors of the said Company and subsequently duly recorded in
the office for the Recording of Deeds in and for said County of Dauphin in Mi~t~ellaneous Book "M",
Volume14, Page317. .~.?.. !..
PUBLICATION ..................................... ?~.) ........./"~'"L'~L ,. ...............
CO PY Sworn to and subscribed befort~ m~ t, ai~21st~y ~(~.g~'st 2001 A.D.
S A L E #17 NoiarlalSeal
Herrlsl3utg. Dauohtn Co~t~//-/~E/ c~ .~../.~/,~'/~--.-c~c...~ ~
My Coi'nmta$i~l Expires June 6, 2002 NOTARY PUBLIC
· & Mem'~er, P~nsy~vania A~octatlo~ct Ne~l~commission expires June 6, 2002
CUMBERLAND COUNTY SHERIFFS OFFICE
CUMBERLAND COUNTY COURTHOUSE
CARLISLE, PA. 17013
~m~. Statement of Advertising Costs
I Em, ely. To THE PATRIOT-NEWS CO., Dr.
For publishing the notice or publication attached
hereto on the above stated dates $ 224.10
Probating same Notary Fee(s) $ 1.50
Total $ 225.60
Publisher's Receipt for Advertising Cost
mimes publisher of The Patriot-News and The Sunday Patriot-News, newspapers of general
~{,k~l,~Lge receipt of the aforesaid notice and publication costs and certifies that the same have
been duly paid.
By ....................................................................
PROOF OF PUBLICATION OF NOTICE
IN CUMBERLAND LAW JOURNAL
(Under Act No. 587, approved May 16, 1929), P. L.1784
STATE OF PENNSYLVANIA :
: SS.
COUNTY OF CUMBERLAND :
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:
JULY 20, 27, AUGUST 3, 2001
Affiant further deposes that he is authorized to verify this statement by the Cumberland
Law Journal, a legal periodical of general circulation, and that he is not interested in the subject
matter of the aforesaid notice or advertisement, and that all allegations in the foregoing
statements as to time, place and character of publication are true,
REAL E~TAT~ ~ALE NO. 17
Writ No. 2001-1248 Civil RogertM. Morgenthal, Editor
Countx-jwide Home Loans, Inc.
vs. SWORN TO AND SUBSCRIBED before me this
Donald M. Robinder and , 3 day of AUGUST, 2001
Martha H. Roblnder (Deceased)
ALL THAT CERTAIN tract of land
situate In North Newton Township,
Cumberla~td County, Commonwealth
of Pennsylvania, more particularly "-
bounded and described as foaows:
post, at lands now or formerly of
John Hoatetter; thence by lands
now or formerly of John Hostetter,
North 37 degrees 59 minutes 51
onds We-st 203.56 feet to a corner
post; thence by same South 54 de-
mama, 0,5 mlaaut~a 55 ~nds ~h~st