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HomeMy WebLinkAbout01-1746GOLDBECK 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 Drive PTX B-35 Plano, TX 75024-3632 Plaintiff vs. TIMOTHY K. TRAVITZ AND ANITA M. TP~AVITZ (Mortgagor(s) and Real Owner (s)) 18 S. Second Street Wormleysburg, PA 17043 Defendant(s) IN THE COURT OF COMMON PLEAS OF CUMBERLAND COUNTY CIVIL ACTION - LAW :ACTION OF MORTGAGE FORECLOSURE Term No. o,- : CIVIL ACTION: NiOR% GAGE i FORECLOSURE THIS LAW FIRM IS A DEBT COLLECTOR AND WE ARE ATTEMPTIN~ 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 Complaint and notice are sez~zed, by entering a writte~ 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 yo~ and a judgment may be entered against you by the Court without further notice for any money claimed iB the Complaint or for any other claim or relief requested by the Plaintiff. You may lose money or property or other right~ important to you YOU SHOULD TAKE THIS PAPER TO YOUR LAWYER AT ONCE. IF YOU DO NOT HAVE A LAWYER OR C3~NNOT AFFOP~D ONE, GO TO OR TELEPHONE THE OFFICE SET FORTH BELOW TO FIND OUT WHERE YOU CAN GET LEGAL HELP. Ctlu%berland County Bar Association 2 Liberty Avenue, Carlisle, PA {800) 990 9108 Legal Services Inc. 8 Irvlne ROW, Carlisle, PA 17013 (717) 243 9400 A V I S 0 LE ~AN DEMANDADO A USTED EN LA CORTE. SI DESEA DEFENDERSE CONTRA ~S QUEJAS PERESENT~AS, ES ABSOLUTAMENTE NECESSARIO QUE USTED RESPONDA DENTRO DE 20 DIAS DESPUES DE SER SERVIDO CON ESTA DE~A Y AVIBO, PARA DEFENDERSE ES NECESSARIO QUE USTED, O SU ABOGADO, REGISTRE CON LA CORTE EN FOR~ ESCRITA, EL PUNTO DE VISTA DE USTED Y CUALQUIER OBJECCION CONTRA LAS QUEJAS EN ESTA DE~A. RECUERDE: SI USTED NO REPONDE A ESTA DEM~DA, SE PUEDE PROSEGUIR CON EL PROCESO SIN SU P;~RTICIPACION. ENTONCES, L~ COUTE PUEDE, SIN NOTIFICARIO, DECIDIR A FAVOR DEL DE--DANTE Y REQUERIRA QUE USTED Cq3MPL~ CON TODA~ LAS PROVISIONES DE ESTA DEMANDA. POR RAZON DE ESA DECISION, ES POSSIBLE QUE USTED PUEDA PEP~DER DINERO, PROPIEDA/9 U OTROS DERECMOS IMPORTA~TES. LLEVE ESTA DEMANDA A UN ABOGADO IMMEDIATAMENTE. SI NO CONOCE A UN ABOGADO, LLA~E AL "LAWYER REFERENCE SERVICE" (SERVICIO DE REFERENCIA DE ABOG~DOS) , 215 238 6300 . C~mberland County Bar Association 2 Liberty Avenue, Carlisle, PA {800) 990 9108 Legal Services Inc. 8 Irvine ROW, Carlisle, PA 17013 {717) 243 9400 COMPI~AINT IN MORTGAGE FORECLOSURE 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 TIMOTHY K. TP~AVITZ, 18 S. Second Street, Wormleysburg, PA 17043 and ANITA M. TRAVITZ, 18 S. Second Street, Wormleysburg, PA 17043, who is/are the mortgagor(s) and real owner(s) of the mortgaged property hereinafter described. 3. On August 29, 1997, mortgagor(s) made, executed and delivered a mortgage upon the premises hereinafter described to BROADVIEW MORTGAGE CO., which mortgage is recorded in the Office of the Recorder of Deeds of Cumberland County in Mortgage Book 1402, Page 683. By Assignment of Mortgage dated August 29, 1997, the mortgage was assigned to Plaintiff, which Assignment is recorded in Assignment of Mortgage Book No. 559, Page 676. 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. The following amounts are due on the mortgage: Principal Balance Interest from 9/ 1/00 through 3/31/01 at 8.000% Per diem interest rate at $21.12 Attorney's Fee at 5% of Principal Balance Late Charges 10/ 1/00- 3/31/01 Monthly late charge amount at $43.64 Costs of suit and Title Search 96,347.91 4,456.32 4,817.40 261.84 560.00 Escrow Balance Credit Monthly Escrow amount $146.17 $ 106,443.47 84.32 $ 106,359.15 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. The within mortgage is insured by the Federal Housing Administration under Title II of the National Housing Act and, as such, is not subject to the provisions of Pennsylvania Act No. 91 of 1983. WHEREFORE, Plaintiff demands judgment in mortgage foreclosure the sum of $106,359.15, together with interest at the rate of $21.12, per day and other expenses incurred by the Plaintiff which are properly chargeable in accordance with the terms of the mortgage and for the foreclosure and sale of the mortgaged premises BY:GOL E~FERTY & McKEEVER ~ ~seph A. Goldbeck, Jr., Esq. Attorney for Plaintiff VERIFICATION Plaintiff authorized Plaintiff Complaint , as the representative of the corporation within named do hereby verify that I am to and do make this verification on behalf of the corporation and the facts set forth in the foregoing 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:=~ Leeal Descriution: ALL THAT CERTAIN lot of ground situate in the Borough of Wormleysburg, Cumberland County, Pennsylv~nin, boUnded and described as Follows, to wit: BEGINNING at the southwest corner of Second Street and First Alley; thence extending along SeCond Street in a southerly direction 65 feet to property now or formerly of Sadie Zarker; thence extending along the property now or formerly of Sadie Zarker in a westerly direction, 130 feet to an alley; thence extending along said Alley in a northerly direction 65 feet to First Alley; thence extending along First Alley in a easterly direction 130 feet to Second Street, the place of BEGINNING. HAVING THEREON ERECTED a two and one-half story house known and numbered as 18. S Second Street, Wormleysburg, Pennslyvania, and on the rear, a one story bungalow. UNDER and SUBJECT, nevertheless, to easements, restrictions, reservations, conditions and rights of way of record or visible upon inspection of said premises. BEING the same premises which Richard J. Drag and Jayne M. Drag, his wife, by Deed dated June 28, 1996 and reeorded July 5, 1996 in the Cumberland County Recorder of Deeds Office in Book 142, Page 350, granted and conveyed unto ICeuneth A. Homer and Diane A. Homer, husband and wife. The said Kenneth A. Homer and Diane A. Homer having divorced and are now single persons. The said Diane .A. Homer having resumed her malden name and is now known as Diane A. SHERIFF'S RETURN - REGULAR CASE NO: 2001-01746 P COMMONWEALTH OF PENNSYLVANIA: COUNTY OF CUMBERLAND COUNTRYWIDE HOME LOANS INC VS TRAVITZ TIMOTHY K ET AL DAWN KELL , Cumberland County, Pennsylvania, says, the within COMPLAINT - MORT PORE TRAVITZ TIMOTHY K DEPENDANT , at 0015:48 HOURS, at 18 S SECOND ST WORMLEYSBURG, PA 17043 ANITA M. TRAVITZ a true and attested copy of COMPLAINT - MORT FORE NOTICE Sheriff or Deputy Sheriff of who being duly sworn according to law, was served upon on the 28th day of March by handing to the 2001 together with and at the same time directing Her attention to the contents thereof. Sheriff's Costs: Docketing 18.00 Service 9.92 Affidavit .00 Surcharge 10.00 .00 37.92 Sworn and Subscribed to before me this //~ day of Of~/~ ~/ A.D. ~z~othonotary t , . So Answers: R. Thomas Kline' 03/30/200 GOLDBECK, MCCAFFERTY,MCKEEEVER By: Deputy Sheriff SHERIFF'S CASE NO: 2001-01746 P COMMONWEALTH OF PENNSYLVANIA: COUNTY OF CUMBERLAND COUNTRYWIDE HOME LOANS INC VS TRAVITZ TIMOTHY K ET AL RETURN - REGULAR DAWN KELL Cumberland County, Pennsylvania, who being duly says, the within COMPLAINT - MORT FORE was TP~AVITZ ANITA M DEFENDANT , at 0015:48 at 18 S SECOND ST WORMLEYSBURG, PA 17043 ANITA M. TP~AVITZ a true and attested copy of NOTICE HOURS, Sheriff or Deputy Sheriff of sworn according to law, served upon the on the 28th day of March , 2001 COMPLAINT by handing to MORT FORE together with and at the same time directing Her attention to the contents thereof. Sheriff's Costs: Docketing 6.00 Service .00 Affidavit .00 Surcharge 10.00 .00 16.00 Sworn and Subscribed to before me this ~ ~ day of ~ ~2~3/ A.D. ~r6thonotary ~ So Answers: R. Thomas Kline 03/30/2001 GOLDBECK, MCCAFFERTY, MCKEEVER Deputy Sheriff (Rule of Civil Procedure No. 236) - Revised IN THE COURT OF COMMON PLEAS OF CUMBERLAND COUNTY, CIVIL ACTION - LAW Countrywide Home Loans, Inc. , Plaintiff Vs. : NO. 01-1746 Timothy K. Travitz Anita M. Travitz , Defendants PENNSYLVANIA Notice is given that a Judgment in the above captioned matter has been entered against you on June /.Z.u~ , 2001. contact: If you have any questions concerning this matter please Joseph,. ~?X~eck, Jr. Attor~y f~ Plaintiff **THIS FIRM IS A DEBT COLLECTOR ATTEMPTING TO COLLECT A DEBT AND ANY INFORIW3%TION 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 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. 111 S. Independence Mall East Philadelphia, PA 19106 (215) 627-1q22 ATTORNEY FOR PLAINTIFF Countrywide Ho~e Loans, Inc. 7105 Corporate Drive, PTX B-35 Plano, TX 75024-3632 Vs. Timothy K. Travitz 18 S. 2nd Street Wormleysburg, PA 17043 CUMBERLAND COUNTY COURT OF COMMON PLEAS : CIVIL DIVISION : NO 01-1746 Anita M. Travitz 18 S. 2nd Street Wormleysburg, PA 17043 PRAECIPE FOR JUDGMENT FOR FAILURE TO ANSWER ARD A~SESSB~NT OF DAMAGES TO THE PROTHONOTARY: Kindly enter judgment in favor of the Plaintiff and against Timothy K. Travitz a~d Anita M. Travltz, 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 - 4/1/01 - 6/8/01 Late Charges Escrow Debit TOTAL $106,359.15 $ 1,457.28 $ 130.92 $ 438.51 $108,385.86 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. ~eph~Goldbeck, Jr. ~torn~ for Plaintiff DAMAGES ARE HEREBY ASSESSED AS INDICATED. DATE: PRO PROTHY u 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 names and last kno~ addresses of the Defendants is: Timot~ K. Travitz, 18 S. 2nd Street, Wo~leysburg, PA 17043 ~ita M. Travitz, 18 S. 2nd Street, Wo~leysburg, PA 17043 ~for Plaintiff TO: ANITA M. TRAVITZ 18 S. Second Street Wormleysburg, PA 17043 COUNTRYWIDE HOME LOANS INC. 7105 Corporate Drive : PTX B-35 : Plano, TX 75024-3632 : Plaintiff vs. : TIMOTHY K~ TRAVITZ AND ANITA M. TRAVITZ : (Mortgagor(s)) : (Record 0whet(s)) : 18 S. Second Street : Wormleysburg, PA 17043 : Defendant(s) : IN THE COURT OF COMMON PLEAS OF CUMBERLAND COUNTY CIVIL ACTION - LAW ACTION OF MORTGAGE FORECLOSURE Term No. 01-1746 THIS LAW FIRM IS A DEBT COLLECTOR AND WE ARE ATTEMPTING TO COLLECT A DEBT OWED TO OUR CLIENT. AL'Y INFORMATION OBTAINED FROM YOU WILL BE USED FOR THE PURPOSE OF COLL~CTIN~ THE DEBT. TO: ANITA M. TRAVITZ 18 S. Second Street Wormleysburg, PA 17043 DATE OF THIS NOTICE: April 18, 2001 IMPORTANT NOTICE YOU ARE IN DEFAULT BECAUSE YOU HAVE FAILED TO ENTER A WRITTEN APPEARANCE PERSONALLY OR BY ATTORNEY AND FILE IN WRITING WITH THE COURT YOUR DEFENSES OR OBJECTIONS TO THE CLAIMS 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 CAiTNOT 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) 990-9108 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 TO: TIMOTHY K. TRAVITZ 18 S. Second Street Wormleysburg, PA 17043 COUNTRYWIDE HOME LOANS INC. 7105 Corporate Drive PTX B-35 Plano, TX 75024-3632 Plaintiff VS. TIMOTHY K. TRAVITZ AND ANITA M. TRAVITZ (Mortgagor (s)) (Record Owner(s)) 18 S. Second Street Wormleysburg, PA 17043 Defendant(s) IN THE COURT OF COMMON PLEAS OF CUMBERLAND COUNTY CIVIL ACTION - LAW ACTION OF MORTGAGE FORECLOSURE Term No. 01-1746 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 COLLECTIN~ THE DEBT. TO: TIMOTHY K. TRAVITZ 18 S. Second Street Wormleysburg, PA 17043 DATE OF THIS NOTICE: April 18, 2001 IMPORTANT NOTICE YOU ARE IN DEFAULT BECAUSE YOU HAVE FAILED TO ENTER A WRITTEN APPEARANCE PERSONALLY OR BY ATTORNEY AND FILE IN WRITING WITH THE COURT YOUR DEFENSES OR OBJECTIONS TO THE CLAIMS 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) 990-9108 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 Suite 500-The Bourse Bldgo 111 S. Independence Mall East Philadelphia, PA 19106 (215) 627-1322 Countrywide Home Loans, Inc. Vs. Timothy K. Travitz Anita M. Travitz ATTORNEY FOR PLAINTIFF COURT OF COMMON PLEAS CIVIL DIVISION No. 01-1746 CUMBERLAND COUNTY VERIFICATION OF NON-MILITARY SERVICE 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 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) years of age, 17043. that defendant Timothy K. Travitz, is over 18 and resides at 18 S. 2nd Street,Wormleysburg, PA (c) that defendant Anita M. Travitz, is over 18 years of age, and resides at 18 S. 2nd Street, Wormleysburg, PA 17043. This statement is made subject to the penalties of 18 Pa. C.S. Section 4904 relating to unsworn falsification to authorities. June 8, 2001 ~tO~PrHneA~GOLDBECK, JR. y~for Plaintiff PRAECIPE FOR WRIT OF EXECUTION - (MORTGAGE FORECLOSURE) P.R.C.P. 3180-3183 Countrywide Home Loans, Inc. Plaintiff : COURT OF COMMON PLEAS : CUMBERLAND COUNTY, PA VS. = NO: 01-1746 Timothy K. Travitz Anita M. Travitz Defendants : PRAECIPE FOR WRIT OF EXECUTION (MORTGAGE FORECLOSURE) TO THE OFFICE OF THE PROTHONOTARY: Issue writ of execution in the above matter: Amount Due $108,385.86 Interest from 6/8/01 to sale date $ at $17.82 per diem Total $ and Costs 111 S. Independence Mall East Philadelphia, PA 19106 Attorney for Plaintiff Note: Please attach description of property. 0 o~ WRIT OF EXECUTION - P.R.C.P. 3180-3183 Countrywide Home Loans, Inc. Plaintiff (MORTGAGE FORECLOSURE) and RULE 2357 COURT OF COMMON PLEAS CUMBERLAND COUNTY, PA NO: 01-1746 WRIT OF EXECUTION (MORTGAGE FORECLOSURE) Vs. Timothy K. Travitz Anita M. Travitz Defendants TO T~E SHERIFF OF CUMBERLAND COUNTY, PENNSYLVANIA To satisfy the judgment, interest and costs in the above matter, you are directed to levy upon and sell the following described property (specifically described property below): Premises: 18 S. 2nd Street, Wormleysburg, PA 17043 (see attached legal d~scription) Amount Due Interest from 6/8/01 to Date of Sale at $17.82 per diem Total $108,385.86 $ $ Plus Costs as endorsed Clerk ALL THAT CERTAIn lot of ground situate in the Borough of Wormleysburg, Cumberland County, Pennsylvania, bounded and described as follows, to-wit: BEGINNING at the southwest comer of Second Street and First Alley; thence extending along Second Street in a southerly direction 65 feet to property now or formerly of Sadie Zarker; thence extending along the property now or formerly of Sadie Zarker in a westerly direction, 130 feet to an alley; thence extending along said Alley in a northerly direction 65 feet to First Alley; thence extending along First Alley in an easterly direction 130 feet to Second Street, the place of BEGINNING. Having erected thereon a two and one-half story house known and numbered as 18 Second Street, Wormleysburg, Pennsylvania, and on the rear, a one story bungalow Tax Parcel #47-20-1858-071 Being known as 18 S. Second Street, Wormleysburg, PA 17043 Countrywide Home Loans, Inc. Plaintiff Vs. Timothy K. Travitz Anita M. Travitz Defendants : CUMBERLAND COUNTY : COURT OF COMMON PLEAS : CIVIL DIVISION : NO. 01-1746 A~FIDAVIT PURSUANT TO RULE 3129.1 Co~ntrywide Nome 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 18 S. 2nd Street, Wormleysbur~, PA 17043. Name Timothy K. Travitz Anita M. Travitz 2. Name and address of Name SA~ AS ~mOVE 3. None 4. Name and address of owner(s) or reputed owner (s): Address (if address cannot be reasonably ascertained, please so indicate) 18 S. 2nd Street Wormleysburg, PA 17043 18 S. 2nd Street Wor~leysburq. PA 17043 defendant(s) in the judgment: Address (if address cannot be reasonably ascertained, please so indicate 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 Cor~. Address (if address cannot be reasonably ascertained, please so indicate) 5105-H Jonestow~ Road Colonial ~arrisbu~g, PA 1712 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 COURT OF COMMON PLEAS Countrywide Home Loans, Vs. Timothy K. Travitz Anita M. Travitz Inc, CUMBERLAND COUNTY CIVIL DIVISION NO. 01-1746 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: (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. § 4904 relating to unsworn falsification to authorities. GOLDBECK McCAFFERTY & McKEEVER By: Joseph A. Goldbeck, Jr. Attorney I.D. #16132 Suite 500 - The Bourse Bldgo 111 S. Independence Mall East Philadelphia, PA 19106 (215) 627-1322 ATTOP_NEY FOR PLAINTIFF Countrywide Home Loans, Inc. Plaintiff Vs. : ~ERLAND COUNTY : COURT OF COMMON PLEAS : CIVIL DIVISION Timothy K. Travitz Anita M. Travitz Defendant(s) : N0.01-1746 NOTICE OF SHERIFF'S SAI.E OF RRAI. ESTATE TO: Anita M. Travitz 18 S. 2nd Street Wormleysburg, PA 17043 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 18 S. 2nd Street, Wormleysburq, PA 17043. is scheduled to be sold at the Sheriff's Sale on Se~t,mher 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 $108,385.86 obtained by Co~,~trywide Ho~e Loans. Inc. (the mortgagee) against you. NOTICE OF OWNER'S RIGHTS YOU MAY BE ~RLE TO PRRVENT THIS SHRRIFF'S SAT,E 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: (215) 627-1322 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 HAY STILL BE ARLE TO SAVE YOUR PROPERTY AND YOU F~VE OTHER RIGHTS EVEN IF T~ S~ERIFF'S SALE DOES TAKE P~,ACE. 1. If the Sheriff's Sale sold to the highest bidder. calling C215) 627-1322. is not stopped, your property will be You may find out the price bid by 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. #16132 Suite 500 - The Bourse Bldg. 111 S. Independence Mall East Philadelphia, PA 19106 C215) 627-13~2 ATTORNEY FOR PLAINTIFF Countrywide Home Loans, Inc. Plaintiff Vs. : CUMBERLAND COUNTY : COURT OF COMMON PLEAS : CIVIL DIVISION Timothy K. Travitz Anita M. Travitz Defendant(s) : N0.01-1746 NOTICE OF SHERIFF'S SALE OF RRAI. ESTATE TO: Timothy K. Travitz 18 S. 2nd Street Wormleysburg, PA 17043 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 18 S. 2nd Street. Wormleysburg. PA 17043, is scheduled to be sold at the Sheriff's Sale on Sept-~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 $108,385.86 obtained by Co,,~trywide ~me Loa~s, Inc. (the mortgagee) against you. NOTICE OF OWNER'S RIGHTS YOU MAY BE ARLE TO P~RVENT THIS SHRRIFF'S SA?.E 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: (215) 627-1322 2 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 ARLE TO SAVE YOUR PROPERTY AND YOU ~AVE OTHER RIGHTS EVEN IF THE SHERIFF'S SALE DOES TAK~ 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 Sherif~ 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 AFFORDONE, 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 ~. Goldbeck, Jr. Attorney I.D.#16132 Suite 50° - The Bourse Bldg. 111 S. Independence Mall East Philadelphia, PA 19106 215-627-1322 Attorney for Plaintiff COUNTRYWIDE HOME LOANS INC. 7105 Corporate Drive PTX B-35 Plano, TX 75024-3632 Plaintiff VS, TIMOTHY K. TRAVITZ AND ANITA M. TRAVITZ 18 S. Second Street Wormleysburg, PA 17043 Defendants : IN THE COURT OF COMMON PLEAS OF CUMBERLAND COUNTY : CIVIL ACTION - LAW : ACTION OF MORTGAGE FORECLOSURE Term No. 01-1746 C~RTIFICATE OF SERVIC~ PURSUA/~T 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 ma~y: Personal Service bY the Sheriff's Office/ ....... (copy of return attached).~¢ Certified mail by Joseph A. Goldbeck, Jr. (original green Postal return receipt attached). 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) of acknowledgment attached). Ordinary mail by Sheriff's Office to Attorney for Defendant(s) record. IF S~RVIC~ 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). ( ) (proof of 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). The undersigned understands that the statements herein are subject penalties provided by 18 P.S. Section 4904. Re ~~sukml~ed, BY: ~o~eph A. ~el~eck, Jr. Att~ey for P~aintiff to the -I p~oH u~oqs~uo£ H-S0IS (a~o~pu~ os as~aid XIq~uos~a~ aq ~ouu~o ssa~pp~ ~) ssaxppv A~SAS ~o ~@pIoq p~p~om~ 2S~I ~q] ~o 'daoo AgI~SH pIoqssnoH (s~oypu! os ~s~Id XIq~uos~@a ~q ~ouu~o ss~pp~ ~!) ss~pp~ :paoo~ go ss~pp~ pu~ :pios aq o~ A~mado~d IWem ag~ uo ueII p~ooa~ ~ s! ~uamBpn~ asoqm ~o~Tpa=o ~uamBpn[ A~Aa go ssampp~ pu~ ~m~N -p (a~o!puI os aseaid AIq~uos~a~ aq ~ouu~o ssa~pp~ ~y) ssa~pp~ amen :~uau~Spn[ aq~ uI (s)~u~puagap ~o ss~pp~ pu~ ~x~S pu~ 'S 8I AIq~uos~ ~q ~ouu~u ss~pp~ ~) :(s) ~su~o p~2nd~ ~o (s)m~u_~o ~o ss~pp~ pu~ ~meN 'I 9~AI-I0 'OR : HOISIAIG ~IAIO : SYH~6 ~OI'~IOD &O ~HD. OD : X,T/,,T. DOD (Lk~k~HH~_D : 'SA ~T~UT~I~ 'm~I 'sn.o~ s~o~ I00~ '8 's~!~!~oq~n~ o~ uo!~PmI~!sI~~ u~o~sun o~ 6uy~PIg~ 5065# 'S'D 'Pd 8I ~o sg!~I~ugd 9q~ o~ ~mg[qns 9p~m 9~ u!~@q s~ugm@~e~s @sI~~ ~q~ pue~s~gpun I '~!Igq pu~ uo!~m~o~u! ~o ~6p@IxOU~ I~UOS~gd Xm ~o ~sgq 9q~ o~ ~9~o~ pu~ an/~ a~ ~!A~p!~ syq~ u! ap~m s~u~ma~s ~qq ~q~ X~I~A I (~oypuy os ~se@id Xiq~uose~ sq ~ouu~m ss~zppe ~!) ss~zpp~ :~I~S ~q~ Aq p~o~e ~q Acm ~eq~ A~doxd oq~ uT ~s~x~uT Au~ s~q ~q~ ~6p~ImouM seq ~T~UT~Id ~q~ moqm ~o uosx~d xsq~o A~As ~o ss~xpp~ pu~ ~m~N .£ 5L9~ xo~ '0'6 ~IOLT ~a 'sTsTTam~ 0~ xo~ '0'~ (s~D!pu! os ss~Id AIq~uos~ aq ~ouu~m ss~xpp~ ~!) ss~pp~ :~I~S ~q~ Xq p~3o~ ~q X~m ~s~uI ~soq~ pu~ X~sdo~d ~q~ u! ~s~3u! '9 (~o!pu! os ~s~id 'p~u!~qi~os~ XIqwuos~ sq ~ouu~m ss~pp~ ~!) ss~pp~ p~oD~ ~ S~q Oq~ uos~d ~q~o /~A~ ~o Ss~pp~ pu~ ~m~N 'S STATE OF PENNSYLVANIA, / COUNTY OF CUMBERLAND I ss. Robert P Ziegler I ............................................................................ Recorder of Deeds in and for said County and State do'he~-'by certify that the Sheriff's Deed in which __~.0_ujlt_r.Y-w_i_4_e__H-°-m--e_-L_°-a--n.s_-I-n-~ ................................................... is the grant~ the same having been sold to said grantee on the ........................... _5_c_.h_ ............... day of September 2001 ........................................ A. D., 7 ...... under and by virtue of a writ .............. Execution ................................................ issu6d on thc ....... .l~b_ day of June A.D. 2001 ............................... ~ out o~ the Court of Comman Pleas ot said County as of Civil .................................................................................. Term, 2 0._0_1_ _ _ Number .... JJ_~_~_ ..... , at the suit of _ __ _C_ _o_u_n.t_r_~y_i_d_e___lt_o_m_e_ __L_o_a_n__s__I_n__c ............................ alnst Timothy K & Anita M Travitz duly recordexl in Sberff's D~ Book No. ___2_4_8_ ...... , Page 4285 IN TESTIMONY WHEREOF, I have hereunto set my hand and seal of said office this ........... day of ...... -~-~ .............. A. D.,;k'~ .~__{___ __ Re~rd~ of Countrywide Home Loans, Inc. VS Timothy K. Travitz and Anita M. Travitz In The Court of Common Pleas of Cumberland County, Pennsylvania Writ No. 2001-1746 Civil Term Michael Barrick, Deputy Sheriff, who being duly swom according to law, states on July 10, 2001 at 10:16 o'clock A.M., EDST, he served a tree copy of the within Real Estate Writ, Notice, Poster and Description, in the above entitled action, upon one of the within named defendants, to wit: Timothy K. Travitz, by making known unto Timothy Travitz, at The Lemoyne Borough Office, Market Street, Lemoyne, Cumberland County, Pennsylvania 17043 its contents, and at the same time handing to him personally the said true and attested copy of the same. Michael Barrick, Deputy Sheriff, who being duly sworn according to law, states on July 10, 2001 at 9:58 o'clock A.M., EDST, he served a true copy of the within Real Estate Writ, Notice, Poster and Description, in the above entitled action, upon one of the within named defendants, to wit: Anita M. Travitz, by making known unto Anita Travitz, at 18 South 2nd Street, Wormleysburg, Cumberland County, Pennsylvania 17043 its contents, and at the same time handing to her personally the said true and attested copy of the same. Michael Barrick, Deputy Sheriff, who being duly sworn according to law, states on July 10, 2001 at 9:58 o'clock A.M., EDST, he posted a true copy of the within Real Estate Writ, Notice, Poster and Description, in the above entitled action upon the property of Timothy K. Travitz and Anita Travitz, located at 18 South 2nd Street, Wormleysburg, Cumberland County, Pennsylvania, according to law. R. Thomas Kline, Sheriff, who being duly sworn according to law, states that he served the above Real Estate Writ, Notice, Poster and Description in the following manner: The Sheriff mailed a pendency of the action to one of the within named defendants, to wit: Timothy K. Travitz, by regular mail to his last known address of 18 South 2na Street, Wormleysburg, PA 17043. This letter was mailed under the date of July 13, 2001 and never returned to the Sheriff's Office. R. Thomas Kline, Sheriff, who being duly sworn according to law, states that he served the above Real Estate Writ, Notice, Poster and Description in the following manner: The Sheriff mailed a pendency of the action to one of the within named defendants, to wit: Anita M. Travitz, by regular mail to her last known address of 18 South 2nd Street, Wormleysburg, PA 17043. This letter was mailed under the date of July 13, 2001 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 September 5, 2001 at 10:00 o'clock A.M., E.D.S.T., and sold the same for the sum of $30,000.00 to Attorney Scott A. Dietterick (for Attorney Joseph Goldbeck) for Countrywide Home Loans, Inc.. It being highest bid and best price received for the same, Countrywide Home Loans, Inc. of 7105 Corporate Drive, PTX B 35, Plano, TX 75032, being the buyer in this execution, paid Sheriff R. Thomas Kline the sum of $1,430.74. Sheriff's Costs: Docketing $ 30.00 Poundage 600.00 Posting Handbills 15.00 Advertising 15.00 Acknowledging Deed 30.00 Auctioneer 10.00 Law Library .50 Prothonotary 1.00 Mileage 20.80 Certified Mail 2.41 Levy 15.00 Surcharge 30.00 Law Journal 204.95 Patriot News 178.92 Share of Bills 25.66 Distribution of Proceeds 25.00 Sheriff's Deed 26.50 $1,230.74 paid by attorney 10-05-01 Sworn and subscribed to before me This ~ day of ~ 2001, A.D. So Answer si... ~. R. Thomas Kline, Sheriff Ely Real Estate Deputy ~30 TITLE REPORT THE PREMISES ENDORSED HEREON ARE SUBJECT TO THE FOLLOWING ITEMS, WHICH WILL BE EXCEPTED IN THE POLICY UNLESS SATISFACTORY EVIDENCE PERMITTING THEIR REMOVAL IS PRODUCED. SHERIFF SALE NO. 53 Held Wednesday, September 5, 2001 Date: September 5, 2001 TAXES: Receipts for all taxes for the years 1998 to 2000 inclusive. Taxes for the current year 2001. WATER RENT: SEWER RENT Company assumes no liability for private supply of water or sewer. Receipts to be produced if services are lienable. MECHANICS' AND Possible unfiled Mechanics Liens and Municipal Claims. MUNICIPAL CLAIMS MORTGAGES: Listed Under Other Exceptions Below. JUDGMENTS: Listed Under Other Exceptions Below. INSTRUMENTS TO BE PRODUCED: Deed from Cumberland County Sheriff to dated ,2001, and recorded ,2001, in Cumberland County Deed Book , Page RECITAL: BEING the same promises which Kenneth A. Homer and Diane A. Homer by deed dated August 15, 1997 recorded September 2, 1997 in the Office of the Recorder of Deeds in and for Cumberland County in Carlisle, Pennsylvania in Deed Book 163, Page 75 granted and conveyed to Timothy K. Travitz and Anita M. Travitz, husband and wife. OTHER EXCEPTIONS: 1. The identity and legal competency of parties at the closing of this title should be established to the satisfaction of the closing attorney acting for this Company. 2. Rights or claims of parties in possession, if any, other than the owner. 3. Unrecorded easements, discrepancies or conflicts in boundary lines, shortage in area and encroachments which an accurate and complete survey would disclose. 4. Payment of State and local Real Estate Transfer Taxes, if required. 5. Public and private rights in the roadbed of Second Street, First Alley, and in an un-named alley. Mortgage in the amount of $99,765.00 given by Timothy K. Travitz and Anita M. Travitz, husband and wife to Broadview Mortgage Company dated August 29, 1997 recorded September 2, 1997 in Mortgage Book 1402, Page 683. Assigned to Country Wide Home Loans, Inc. by instrument dated August 29, 1997 recorded September 2, 1997 in Miscellaneous Record book 559, Page 676. Complaint in Mortgage Foreclosure filed by Country Wide Home Loans, Inc. as Plaintiff against Timothy K. Travitz and Anita M. Travitz in the Office of the Prothonotary of Cumberland County to file number 2001-1746. Defanlt judgment in the amount of $108,385.86 entered on June 13, 2001. Mortgage in the amount of $10,000.00 given by Timothy K. Tmvitz and Anita M. Travitz, husband and wife, to Household Realty Corporation dated August 19, 1999 and recorded August 26, 1999 in Mortgage Book 1566, Page 781. 8. Satisfactory evidence to be produced that proper notice was given to the holders of all liens and encumbrances intended to be divested by subject Sheriff Sale. 9. Real estate taxes accruing on and after January 1, 2002 not yet due and payable. It is to be noted that no search of Domestic Relations Records has been made to determine support arrearages regarding House Bill 1412, Act 58 of 1997, nor has any search been made for environmental liens in Federal District Court. REAL ESTATE SALE NO. 53 Writ No. 2001-1746 Cl'al Countrywide Home Loans. Inc. vs. Timothy IC Travitz and Anita M. Tra~tz Arty,: Joseph A. Goldbeck, Jn ALL THAT CERTAIN lot of ground situate in the Borough of Wormleys- burg. Cumberland County, Pennsyl- vania, hounded and described as follows, to-wit: BEGINNING at the southwest comer of Second Street and First Al- ley; thence extending along Second Street in a southerly direction 65 feet to property now or formerly of Sadie Zarker; thence extending a.Iong the property now or formerly of Sadie Zarker in a westerly direc- tion, 130 feet to an alley; thence extending along said Alley in a north- erly direction 65 feet to First Alley: thence extending along First Alley ,'in an easterly direction 130 feet to Second Street. the place of BEGIN- NING. Having erected thereon a two and one-half story house known and numbered as 18 Second Street, Wormleysburg. Pennsylvania. and on the rear, a one story bungalow. Tax Parcel #47-20-1858-071. Being knov, m as 18 S. Second Street, lVormlsysburg. PA 17043. Countrywide Home Loans, In~. Plaintiff Vs. Timothy K. Trav~tz Anita M. Travitz Defendants : CUMBERLAND COUNTY : COURT OF COMMON PLEAS : CIVIL DIVISION : NO. 01-1746 AFFIDAVIT PURSUANT TO RULE 3129.1 Co~,ntrywide Hnme Loa~s. Inc., Plaintiff in the above action, by its attorney, Joseph Golclbeck, 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 18 S. 2nd Street. Wormleysburq. PA 17043. Name Ti~nthy K. Travitz Anita M. Travitz 2. Name and address of owner(s) or reputed owner (s): Address (if address cannot be reasonably ascertained, please so indicate) 18 S. 2nd Street Wormleysburq. PA 17043 18 S. 2nd Street Worm]eysburg. PA 17043 Name and address of defendant(s) in the judgment: Name Address (if address cannot be reasonably ascertained, please so indicate) SA~. AS ~ROVE 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 Cor~. Address (if address cannot be reasonably ascertained, please so indicate) 5105-~ Joneetown Road Colonlal ~arrisburg. PA 1712 Name and address of e~ery ~ther 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) ~,~herland Co~nty Dept. of D~mestic Relations P.O. Box 320 Carlisle. PA 17013 Pa Dept. of P~,hlic Welfare Bureau of Child Support Enforc,~ent Health and Welfare Bldg. Room 432 P.O. Box 2675 Harrisburg, PA 17105 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. June 8, 2001 Att~ney6~or Plaintiff 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. Plaintiff Vs. : CUMBERLA/qD COUNTY : COURT OF COMMON PLEAS : CIVIL DIVISION Timothy K. Travitz Anita M. Travitz Defendant(s) : NO.01-1746 NOTICE OF SHERIFF'S SAI,E OF RRAI, ESTATE TO: Anita M. Travitz 18 S. 2nd Street Wormleysburg, PA 17043 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 18 S. 2nd Street, Wormleysburg. PA 17043, is scheduled to be sold at the Sheriff's Sale on SeptemBer 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 $108,385.86 obtained by Co~ntrywide Home Loans, Inc. (the mortgagee) against you. NOTICE OF OWNER'S RI~4TS YOU MAY BE ABLE TO P~RVENT THIS SHERIFF'S SAr.E 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: (215) 627-1322 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 6.o 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 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 (2151 627-1B22. 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 (7]7) 240-6B90. 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 ALL THAT CERTAIn lot of ground situate in the Borough of Wormleysburg, Cumberland County, Pennsylvania, bounded and described as follows, to-wit: BEGINNING at the southwest comer of Second Street and First Alley; thence extending along Second Street in a southerly direction 65 feet to property now or formerly of Sadie Zarker; thence extending along the property now or formerly of Sadie Zarker in a westerly direction, 130 feet to an alley; thence extending along said Alley in a northerly direction 65 feet to First Alley; thence extending along First Alley in an easterly direction 130 feet to Second Street, the place of BEGINNING. Having erected thereon a two and one-half story house known and numbered as 18 Second Street, Wormleysburg, Pennsylvania, and on the rear, a one story bungalow Tax Parcel #47-20-1858-071 Being known as 18 S. Second Street, Wormleysburg, PA 17043 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: 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 tree. RYAL ESTATE SAL~ NO. ~$ Writ No. 2001 1746 Civil Countrywide Home LOa~ls, Inc. VS. Timothy K. Travltz and Anita M. Trav-ltz Atty.: Joseph A. Goldbeck. Jr. ALL THAT CERTAIN lot of ground situate in the Borough of Wormleys- burg. Cumberland County. PermsyL vania, bounded and described as follows, to-wit: BEGINNING at the southwest corner of Second Street and Flrst Al- ley; thence extending along Second Street in a southerly direction 65 .lee&to ~ro~ertv ~_ow or forira:rlv of Rog~/iVi~t0~''~- SWORN TO AND SUBSCRIBED before me this 3 day of AUGUST. 2001 THE 'PATRIOT NEWS THE SUNDAY PATRIOT NEWS Proof of Publication Under Act No. 587, Approved May 16, 1929 Commonwealth of Pennsylvania, County of Dauphin} ss 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 Miscel~neous Book "M", Volume 14, Page 317. ~ / PUBLICATION ....................................... .......................................... COPY Sworn to and subscribed bef.~r~"~this 21st.,~ of/A~t 2001 A.D. S A L E #53 NotadalSeal J/ ~ / . // ~ C~ E~ ~ ~, ~ ~TA~Y PUBLIC ~ CUMBERLAND COUNTY SHERIFFS OFFICE CUMBERLAND COUNTY COUFrrHOUSE 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 $ 177.42 $ 1.5O $ 178.92 Publisher's Receipt for Advertising Cost o., publisher of The Patriot-News end The Sunday Patriot-News. newspapers of general ,Ige receipt of the aforesaid notice and publication costs and certifies that the same have