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Home My WebLink About10-7629~OLDBECK McCAFFERTY & McKEEVER SUITE SOOO - MELLON INDEPENDENCE CENTER 7O1 MARKET STREET FIi.EO-OFFICE PHILADELPHIA, PA 19106 CF TuF PROTHONOTARY (866) 413-2311 M&T BANK SB/M MANUFACTURERS AND TRADERS TRUST COMPANY 1100 Wehrle Drive Williamsville, NY 14221 Plaintiff 3 AM I I ~ 3O CUMB BLAND GNIA(~OURT OF COMMON PLEAS P E N S Y LVA OF Cumberland COUNTY vs. HARRY G. RAUDABAUGH DONNAJ.RAUDABAUGH Mortgagors and Record Owners 445 Run Road Carlisle, PA 17013 Defendants No. I b `7 ~O~ ~fVIL AGT~ObI: ~~®RTGAGE ~~oa-a ~° 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 aze served, by entering a written appeazance personally or by attorney and filing in writing with the court your defenses or objections to the claims set forth against you. You aze wazned 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 claim in the Complaint of 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 LAWYER OR CANNOT AFFORD ONE, GO TO OR TELEPHONE THE OFFICE SET FORTH BELOW. THIS OFFICE CAN PROVIDE YOU WITH INFORMATION ABOUT HIRING A LAWYER. IF YOU CANNOT AFFORD TO HIRE A LAWYER, THIS OFFICE MAY BE ABLE TO PROVIDE YOU WITH INFORMATION ABOUT AGENCIES THAT MAY OFFER LEGAL SERVICES TO ELIGIBLE PERSONS AT A REDUCED FEE OR NO FEE. CUMBERLAND COUNTY BAR ASSOCIATION 2 Liberty Avenue Carlisle, PA 17013 LEGAL SERVICES INC 8 Irvine Row Carlisle, PA 17013 717-243-9400 AVISO pa ~qam~~ t~~ ss 3~ ~~a.sa~~ Le han demandado a usted en la corte. Si usted quiere defenderse de estas demandas expuestas en las paginas siguientes, usted tiene veinte (20) dias de plazo al partir de la fecha de la demanda y la notification. Hate falta ascentar una compazencia escrita o en persona o con un abogado y entregar a la corte en forma escrita sus defensas o sus objeciones a las demandas en contra de su persona. Sea avisado que si usted no se defiende, la corte tomaza medidas y puede continuer la demanda en contra suya sin previo aviso o notification. Ademas, la corte puede decider a favor del demandante y requiere que usted cumpla con todas las provisioner de esta demanda. Usted puede perder dinero o sus propiedades u otros derechos importantes pars usted. CNIL ACTION -LAW ACTION OF MORTGAGE FORECLOSURE LLEVE ESTA DEMANDA A UN ABOGADO IMMEDIATAMENTE. SI NO TIENE ABOGADO O SI NO TIENE EL DINERO SUFICIENTE DE PAGAR TAL SERVICO. VAYA EN PERSONA O LLAME POR TELEFONO A LA OFICINA CUYA DIRECCION SE ENCUENTRA ESCRITA ABAJO PARR AVERIGUAR DONDE SE PUEDE CONSEGUIR ASISTENCIA LEGAL. SI USTED NO PUEDE PAGARLE A UN ABOGADO, ESTA OFICINA PUEDE PROVEERE INFORMACION ACERCA AGENCIAS QUE PUEDAN OFRECER SERVICIOS LEGAL A PERSONAS ELIGIBLE AQ UN HONORARIO REDUCIDO O GRATIS. CUMBERLAND COUNTY BAR ASSOCIATION 2 Liberty Avenue Carlisle; PA 17013 LEGAL SERVICES INC 8 Irvine Row Carlisle, PA 17013 717-243-9400 THIS 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. Resources available for Homeowners in Foreclosure ACT NOW! Even though your lender (and our client) has filed an Action of Mortgage Foreclosure against you, you still may be able to SAVE YOUR HOME FROM FORECLOSURE. 1). Call an attorney. For referrals to a qualified attorney call either of the following numbers: or 717- 243-9400. 2). Call the Consumer Credit Counseling Agency at 1-800-989-2227 for free counseling. 3). Visit HUD'S website www.hud.gov for Help for Homeowners Facing the Loss of Their Homes. 4). Pennsylvania Housing Finance Agency also offers other loan programs that may assist homeowners in default. Please See the PHFA website httn://www.phfa.or~/consumers/homeowners/real as~x. 5). Call the Plaintiff (your lender) and ask to speak to someone about Loss Mitigation or Home Retention options. 6). Foreclosure Resource Center: http://www.philadelyhiafed.org/foreclosure/ 7). Call or contact our office to request the amount to bring the account current, or payoff the mortgage or request a Loan Workout /Home Retention Package. Call our toll free number at 1-866-413-2311 or via email at homeretention(a,goldbecklaw.com. Call Seth at 215-825-6329 or fax 215-825-6429. The figure and/or package you requested will be mailed to the address that you request or faxed if you leave a message with that information. The attorney in charge of our firm's Homeowner Retention Department is David Fein who can be reached at 215-825-6318 or Fax: 215-825-6418. Please reference our Attorney File Number of 86771FC. Para information en espanol puede communicarse con Loretta. a1215-825-6344. This Action of Mortgage Foreclosure will continue unless you take action to stop it. COMPLAINT IN MORTGAGE FORECLOSURE Plaintiff is M&T BANK SB/M MANUFACTURERS AND TRADERS TRUST COMPANY, 1100 Wehrle Drive, Williamsville, NY 14221. 2. The names and addresses of the Defendants are HARRY G. RAUDABAUGH, 445 Run Road, Carlisle, PA 17013 and DONNA J. RAUDABAUGH, 445 Run Road, Carlisle, PA 17013, who are the mortgagors and record owners of the mortgaged premises hereinafter described. 3. On August 07, 2003 mortgagors made, executed and delivered a mortgage upon the Property hereinafter described to MANUFACTURERS AND TRADERS TRUST COMPANY, which mortgage is recorded in the Office of the Recorder of Deeds of Cumberland County as Book 1831 Page 2612. The Mortgage and Assignment(s) are matters of public record and are incorporated by this reference in accordance with Pennsylvania Rule of Civil Procedure 1019(g); which Rule relieves the Plaintiff from its obligation to attach documents to pleadings if those documents are matters of public record. 4. The Property subject to the Mortgage is more fully described in the legal description set forth as Exhibit "A" ("Property"). 5. The mortgage is in default because the monthly payments of principal and interest aze due and unpaid for Mazch 24, 2009 and each month thereafter and by the terms of the Mortgage, upon default in such payments for a period of one month or more, the entire principal balance and all interest due and other chazges are due and collectible. 6. The following amounts are due to Plaintiff on the Mortgage: Principal Balance ....................................................................................$23,803.11 Interest from 02/24/2009 through 08/31/2010 at 5.0000% .......................$1,754.28 Per Diem interest rate at $3.26 Late Chazges from 03/24/2009 to 08/31/2010 ...............................................$33.42 Reasonable Attorney's Fee .......................................................................$1.300.00 $26,890.81 7. If the Mortgage is reinstated prior to a Sheriff's Sale, the Attorney's Fees set forth above may be less than the amount demanded based on work actually performed. Plaintiff reserves the right to request additional attorney's fees if the complexity of the action results in fees in excess of the amount demanded. Further, Plaintiff will request recovery of all costs incurred in this action including, but not limited to, costs of suit, process serving and skip tracing, title seazches, recording costs and any other costs of the action in accordance with the mortgage documents and applicable law. 8. Plaintiff is not seeking a judgment of personal liability (or an "in personam"judgment) against the Defendants in this Action but reserves its right to bring a sepazate Action to establish that right, if such right exists. If Defendants have received a discharge of their personal liability in a Bankruptcy proceeding, this Action of Mortgage Foreclosure is, in no way, an attempt to re-establish the personal liability that was dischazged in Bankruptcy, but only to foreclose the Mortgage and sell the Property pursuant to Pennsylvania law. 9. Notice of Intention to Foreclose and a Notice of Homeowners' Emergency Mortgage Assistance has been sent to Defendants 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 "B". The Defendants 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 Defendants through the Plaintiff, the Pennsylvania Housing Finance Agency, or any appropriate Consumer Credit Counseling Agency. WHEREFORE, Plaintiff demands a de terris judgment in mortgage foreclosure in the sum of $26,890.81, together with interest at the rate of $3.26, per day and other expenses, costs and charges incurred by the Plaintiff which are properly chargeable in accordance with the terms of the Mortgage and Pennsylvania law until the Mortgage is paid in full, and for the foreclosure of the Mortgage and Sheriffls Sale of the Property. By: LDBEC CCAFFERT & MCKEEVER Michae ever Pa. ID 9 Gary McCafferty Pa. ID 42386 ~/ Lisa Lee Pa. ID 78020 Kristine Murtha Pa. ID 61858 David Fein Pa. ID 82628 Thomas Puleo Pa. ID 27615 Attorneys for Plaintiff ~h 6it 20032061741040 Schad~~l~ "A" NAME(S): HARRY Q. RAUDABAUC3H 8 DONNA RAUDABAUGH ALL THAT CERTAIN PARCEL OR TRACT OF LAND SITUATE IN THE 70WNSHIP OF LOWER FRANKFORO, COUNTY OF GLAND, COMMONWEALTH OF PENNSYLVANIA AND BEING THE SAME REAL PROPERTY COM/EYED TO HARRY (1. RAUDABAIJGH S DONNA RAUDABAUGH BY DEED RECORDED 7/1s~12001 AS BOOK 247 PAGE 2428 AMONG THE OFFICIAL RECORDS OF CUMBERLAND COUNTY, COMMONWEALTH OF PENNSYLVANIA. SAID DEED REFERENCE MADE HEREIN FOR A MORE FULL DESCWPTION. T8x Map ~1: 14Q5-Q421-039 H ACT 91 NOTICE DATE OF NOTICE: 08/19/2009 TAKE ACTION TO SAVE YOUR HOME FROM FORECLOSiJRE THIS LAW FIRM IS A DEBT COLLECTOR AND WE ARE ATTEMPTING TO COLLECT A DEBT OWED TO OUR CLIENT. ANY INFORMATION OBTAINED FROM YOU WII.L BE USED FOR THE PURPOSE OF COLLECTING THE DEBT. This is an official notice that the mortgage on your home is in default, and the leader intends to foreclose. Specific information about the nature of the default is provided in the attached pales. The HOMEOWNER'S MORTGAGE ASSISTANCE PROGRAM (HEMAr~ may be able to help to save your home This Notice explains how the program works To see if HEMAP can help, you must MEET WITH A CONSUMER CREDIT COUNSELING AGENCY WITHIN 33 DAYS OF THE DATE OF THIS NOTICE. Take this Notice with you when you meet with the Counseling Agency The name address and phone number of Consumer Credit Counselin~Agencies serving your County are listed at the end of this Notice. If you have andquestions you may call the Pennsylvania Housing Finance Agency toll free at 1-800-342-2397 Persons with impaired hearing can call (71?) 780-1869.) This Notice contains important legal information. If you have any questions, representatives at the Consumer Credit Counseling Agency may be able to help explain it. You may also want to contact any attorney in your area. The local bar association may be able to help you find a lawyer. La notification en adjunto es de soma importancia, pues afecta su derecho a continuer viviendo en su case. Si no comprende el contenido de esta notification obtenga una traduccion immediatamente llamanda esta agencia {Pennsylvania Housing Finance Agency) sin cargos al numero mencionada arriba. Puedes ser elegible pare un prestamo por el programs llamado "Homeowner's Emergency Mortgage Assistance Program" el coal puede salver su case de la perdida del derecho a redimir su hipoteca. Prepared by: GOLDBECK McCAFFERTY & McKEEVER Suite 5000 -Mellon Independence Center. 701 Market Street Philadelphia, PA 19106 Fax (215) 627-7734 Date: 08/18/2009 Homeowners Name: HARRY G. RAUDABAUGH and DONNA J. RAUDABAUGH Property Address: 44S,R~y,$~d Carlisle, PA 17013 Loan Account No.: ~~ Original Lender: Manufacturers and Traders Trust Company Current Lender/Servicer: M&T BANK HOMEOWNERS' EMERGENCY MORTGAGE ASSISTANCE PROGRAM YOU MAY BE ELIGIBLE FOR FINANCIAL ASSISTANCE WffiCH CAN SAVE YOUR HOME FROM FORECLOSURE AND HELP YOU AKF. FUTURF_ MORTGAGE PAYMENTS IF YOU COMPLY WITH THE PROVISIONS OF THE HOMEOWNER'S EMERGENCY MORTGAGE ASSISTANCE ACT OF 1983 E'THE "ACT"), YOU MAY BE ELIGIBLE FOR EMERGENCY MORTGAGE ASSISTANCE: * IF YOUR DEFAULT HAS BEEN CAUSED BY CIRCUMSTANCES BEYOND YOUR CONTROL, * IF YOU HAVE A REASONABLE PROSPECT OF BEING ABLE TO PAY YOUR MORTGAGE PAYMENTS, AND * IF YOU MEET OTHER ELIGIBILITY REQUIREMENTS ESTABLLSHED BY THE PENNSYLVANIA HOUSING FINANCE AGENCY. TEMPORARY STAY OF FOREC~ -Under the Act, you are entitled to a temporary stay of foreclosure on your mortgage for thirty (30) days from the date of this Notice (plus three (3) days for mailing}. During that time you must arrange and attend a "face-to-face" meeting with one of the designated consumer credit counseling agencies listed at the end of this Notice. THLS MEETING MUST OCCUR WITHIN THE NEXT (331 DAYS IF YOU DO NOT APPLY FOR EMERGENCY MORTGAGE ASSISTANCE. YOU MUST BRING YOUR MORTGAGE UP TO DATE. THE PART OF THIS NOTICE CALLED "HOW TO CURE DATE. MORTGAGE DEFAULT" EXPL•A~TS HOW TO BRING YOUR MORTGAGE UP TO CONSUMER CREDIT COUNSELING AGENCIES - If you meet with one of the consumer credit counseling agencies listed at the end of this notice, the lender may NOT take action against you for thirty (30} days after the date of this meeting. The names, addresses and telephone numbers of designated consumer credit oounseling agencies for the county in which the property is located are set forth at the end of this Notice. It is only necessary to schedule one face-to-face meeting. Advise your lender immediately of your intentions. APPLICATION FOR MORTGAGE ASSIS~ -Your mortgage is in default for the reasons set forth later in this Notice {see following pages for specific information about the nature of your default.) You have the right to apply for financial assistance from the Homeowner's Emergency Mortgage Assistance Program. To do so, you must fill out, sign and file a completed Homeowner's Emergency Assistance Program Application with one of the designated consumer credit counseling agencies listed at the end of this Notice. Only consumer credit counseling agencies have applications for the program and they will assist you in submitting a completc application to the Pennsylvania Housing Finance Agency. To temporarily stop the lender from filing a foreclosure action, your application MUST be filed or postmarked within thirty (30) days of your fact-to-face meeting with the counseling agency. YOU SHOULD FILE A HEMAP APPLICATION AS SOON AS POSSIBLE. IF YOU HAVE A MEETING WITH A COUNSELING AGENCY WITHIN 33 DAYS OF THE POSTMARK DATE OF TffiS NOTICE AND FII.E AN APPLICATION WITH PHFA WITHIN 30 DAYS OF THAT MEETING, THEN THE LENDER WILL BE TEMPORARILY PREVENTED FROM STARTING A FORECLOSURE AGAINST YOUR PROPERTY, AS EXPLAINED ABOVE, IIV THE SECTION CALLED "TEMPORARY STAY OF FORECLOSURE." YOU HAVE THE RIGHT TO FILE A HEMAP APPLICATION EVEN BEYOND THESE T1ME PERIODS. A LATE APPLICATION WII.L NOT PREVENT THE LENDER FROM STARTING A FORECLOSURE ACTION, BUT IF YOUR APPLICATION IS EVENTUALLY APPROVED AT ANY TIME BEFORE A SHERIFF'S SALE, THE FORECLOSURE WILL BE STOPPED. AGENCY ACTION -Available funds for emergency mortgage assistance are very limited, They will be disbursed by the Agency under the eligibility criteria established by the Act. The Pennsylvania Housing Finance Agency has sixty (60) days to make a decision after it receives your application. During that time, no foreclosure proceedings will be pursued against you if you have met the time requirements set forth above. You will be notified directly by the Pennsylvania Housing Finance Agency of its decision on your application. ivurr;: ~r~ xuu ..~: CURRENTLY PROTECTED BY THE FILINGOF A PETITION iN BANKRUPTCY, THE FOLLOWING PART OF THLS NOTICE IS FOR INFORMATION PURPOSES ONLY AND SHOULD NOT BE CONSIDERED AS AN ATTEMPT TO COLLECT THE DEBT. (If yon have filed bankruptcy yon can still apply for Emergency Mortgage Aas~tance.) HOW TO CURE YOUR MORTGAGE DEFAULT farina it no to date) NATiJRE OF THE DEFAULT -The MORTGAGE debt held by the above lender on your property located at: 445 Rnn Road, Carlisle, PA 17013 IS SERIOUSLY I1V DEFAEJLT because: A. YOU HAVE NOT MADE MONTHLY MORTGAGE PAYMENTS for the following months and the following amounts are now past due: (a) Monthly payment from 03!01/2009 thru 08/18/2009 3/09/2009- $221.23 4/09/2009- $243.17 5/09/2009- $233.31 6/09/2009- $239.83 7/09/2009- $239.83 8/0912009- $23b.57 Sub-Total $1,413.94 (b) Late charges (c) Other charges; Escrow, Inspec., NSF Checks {d) Other provisions of the mortgage obligation, if any (e) TOTAL AMOUNT REQUIRED AS OF THIS DATE: $1,413.94 HOW TO CURE THE DEFAULT -You may cure the default within THIRTY (30) DAYS of the date of this notice BY PAYING THE TOTAL AMOUNT PAST DUE TO THE LENDER WHICH IS so.oo. PLUS ANY MORTGAGE PAYMENTS AND LATE CHARGES WHICH BECOME DUE DURING THE THIRTY (30} DAY PERIOD. Payments must be made either by cashier's check. certified check or money order made payable and sent to• M&T BANK 1100 Wehrle Drive Williamsville, NY 14221 lF YOU DO NOT CURE THE DEFAULT - If you do not cure the default within THIRTY (30) DAYS of the date of this Notice, the lender intends to exercise its Q is to accelerate the nmrtgage debt. This means that the entire outstanding balance of this debt will be considered due immediately and you may lose the chance to pay the mortgage in monthly installments. If full payment of the total amount past due is not made within THIRTY (30) DAYS, the lender also intends to instruct its attorneys to start legal action to forecbse noon vonr mortaa~p, rai~ert~ 1(F THE MORTGAGE IS FORECLOSED UPON -The mortgaged property will be sold by the Sheriffto pay offthe mortgage debt. If the lender refers your case to its attorneys, but you cure the delinquency before the lender brings legal proceedings against you, you will still be required to pay the reasonable attorney's fees that were actually incurred, up to $50.00. However, if legal proceedings are started against you, you will have to pay all reasonable attorney's fees actually incurred by the lender even if they exceed $50.00. Any attorney's fees will be added to the amount you owe the lender, which may also include other reasonable costs. ff you cure the default within the THIRTY (30] DAY period. you wlll not be reauired to pav attorney's fees. OTHER LENDER REMEDIES -The lender may also sue yvu personally for the unpaid principal balance and all other sums due under the mortgage. RIGHT TO C[JRE THE DEFAULT PRIOR TO SHERIFF'S SALE - If you have not cured the default within the THIRTY (30) DAY period and foreclosure proceedings have begun, you still have the ri¢ht to cure the default and yrevent the sale at env time up to one hour before the Sheriffs Sale You may do so by paying the total amount then nest due plus env late or other charges #hen due. reasonable attornev's fees and costs connected with the foreclosure le and any other costs cannPCted v~nth the Sheriffs Sale as specified in writing by the lender and by_ m `ng~y_ other req ri q under the mort~e. Curing your default in the manner set forth in this notice will restore your mortgage to the stnm position as if you had never defaulted. EARLIEST POSSIBLE SHERIFFS SALE DATE - It is estimated that the earliest date that such a Sheriffs Sale of the mortgaged property could be held would he approximately four (4) to six l~ months from the date of this Notice. A notice of the actual date of the Sheriffs Sale will be sent to you before the sale. Of course, the amount needed to cure the default will increase the longer you wait. You may find out at any time exactly what the required payment or action will by contacting the lender. HOW TO CONTACT THE LENDER: Name of Lender: M&T BANK Address: 1100 Wehrle Drive Williamsville, NY 14221 Phone Number: 716-630-4912 Fax Number• Contact Person: Lindsey Pohl EFFECT OF SHERIFF'S SALE -You should realize that a Sheriff's Sale will end your ownership of the mortgaged property and your right to occupy it. If you continue to live in the property after the Sheriffs Sale, a lawsuit to remove you and your furnishings and other belongings could be started by the lender at any time. ASSUMPTION OFMORTGAGE -You may sell or transfer your home to a buyer or transferee who will assume the mortgage debt, provided that all the outstanding payments, charges and attorney's foes and costs are paid prior to or at the sale and that the other requirements of the mortgage are satisfied. YOU MAY ALSO HAVE THE RIGHT• * TO SELL THE PROPERTY TO OBTAIN MONEY TO PAY OFF THE MORTGAGE DEBT OR TO BORROW MONEY FROM ANOTHER LENDING IlVSTTTUTION TO PAY OFF THIS DEBT. * TO HAVE THIS DEFAULT CURED BY ANY THIRD PARTY ACTING ON YOUR BEHALF. * TO HAVE THE MORTGAGE RESTORED TO THE SAME POSITION AS IF NO DEFAULT HAD OCCURRED, IF YOU CURE THE DEFAULT. (HOWEVER, YOU DO NOT HAVE THIS RIGHT TO CURE YOUR DEFAULT MORE THAN THREE TIMES IN ANY CALENDAR YEAR) * TO ASSERT THE NONEXISTENCE OF A DEFAULT IN ANY FORECLOSURE PROCEEDING OR ANY OTHER LAWSUIT INSTITUTED UNDER THE MORTGAGE DOCUMENTS. * TO ASSERT ANY OTHER DEFENSE YOU BELIEVE YOU MAY HAVE TO SUCH ACTION BY THE LENDER. * TO SEEK PROTECTION UNDER THE FEDERAL BANKRUPTCY LAW. Contact Person: Lindsey Pahl Phone Number. 716-630-4912 HEMAP Consumer Credit Counseling Agencies Pat loaf updaterk 12r13I20081:fi2A1 PM tyaera-Cleda Co Coarar io Coma Adbrt 2138 Li-coMr Siroet PA. Bmt 3688 YYianraport, PA 1770.9 57D.328.056T CCCSd1IMael~en PA 2000 lJrrpbetpartr I~ciaQ timie6urp, PA 17102 666.511.?227 8668112227 OOLUM8IA County Amartcot CredB Campatk~ ir~rrte 212 Bonrk#HaneNon Hwy Naacapeck, PA 18835 866A88.6617 CCC3 of Nortlreaatern AA 4011.araN 3tred PMbba, PA 18640 570.602?227 800.822.9637 CRAYYFORD County BooioerT.INmhln~tan Canlar 1720 tloNand 8lreet Erb, PA 1ti603 814A63.b744 l+t+CB of 1iYaair+rrr PA 440Q Peach Stroet Erie, PA 18609 886811.2717 axt 108 866.511.2227 and 108 Carder for Famgy S~rrvicee, krc 213 Carder Street Maedvie, PA 18395 eu.a37.eaw st'nabr t.rie Qormararpy Aatloa Comndtbo 18 Wad 9Ttf 8ked Erie, PA 18601 814A59A581 BbwNrrpo Vil(ay tbban w9w. Ina BD1 kltiena Arerare Farrell PA 18121 724.981.6310 St. ttiarttn Qatar 1701 Parade Street Erie, PA 16803 814A52.8113 CU~IBERLAtitD Cou Addae CouaQr irrterfallh tiooalap AuAtaxlty 40 E FNyh 8treef C3st[yeburg, PA 17325 717.334.1fi18 Caearaudgi Aatlon Coaanbeloa of Capital Reaae 1514 Deily Street F1anlsbtRQ, PA 17104 717292.9757 2320 Nt~rYr fiN Street Ffarrieburp, PA 17110 T17~ 43 Phiede~irla Avaare 1Mayneatroro, PA 17288 717.782.3285 PNFA 211 North Front 3treat liarrlebrap, PA 17110 717.78D~10 800.342.2587 DauPHU~ cowry txCS dYreatera PA 2000 LJn~siaen IZaad Haaiiburp, PA 17102 888811.2227 888.611.2227 Communl~i Aceboa Coarnrkston o1 Captlel iiesOoa 1514 DMry Strad HarrbpYrp, PA 17104 717.Z32.87$T ~- ?.320 NorYi bth 9beet limhburp. PA 17110 717.232.2207 Qpporturrily Ina 301 East Markel Strad Yak, PA 17405 711.424.3843 PHFA 211 North Front Street HanbDury. PA 17110 717.780.3940 eoo.34223e7 DELAWARE county Acorn Howbg Corporattoa 848 trar6r Broad 8treat PhiadetpFte, PA 1x'130 218.788.1221 Page 7 of 19 HE~IIAP Consumer Credi~E Counseling Agencies >rs< updsted:12129120081d;2'~41 PM Adroo.a. for Ftnandal ~s» ctr..ar caar~t4- Improti,a~.nt Prejtet 2172 t~ ~ Avaesre 412 Averw d the 3talas ~ Park, PA 19078 PO BOUt 541 210.389.2810 Chasbr, PA 18016 Aasarfotrt Crate Cwrnsrlryl ka~s 810.878.8863 175 86att+nnd Averpas Biven~llad ~ ~~ Bulb 1 Dhmrt ~~ Wayne, PA 19087 1920 Soo6120~ 8lteat 810.9712210 Phitds~Ftis, PA 19146 888.212A741 216.396.3611 Aneerbut CnrQl Cownelr-p lAStl4dt ' FOB t:DCC 5 28.628 DakelD Street 1201 Went Olrwy Avarere Norrlebwn, PA 19401 Phisldeblrb, PA 19141 810.9712210 215.&W.8755 888212.8741 Mrwign FMwroltl Counee[IrtB itrriees fiernrarrtset: BattMsant 5598 Wayne Avenue 176 Trdatd Avenue ~ C Suile ~° Plrilade~lrlt, PA 19144 Wayne, PA 19067 216.848.3104 267.228.7903 IfA>:t: 800+490.3039 187 W. ANglrsny Avsrure Anterieart [ltd Cr+oas o- CAestsr 2nd Fl 1728 6dparnord Avenue PhledetEllis, PA 19140 Chester, PA 19013 ~6,~~r 610,874.1484 Nauekg PaetnarahtF d Charier t:aonl~r APM 41 WadtanaasltrAw 2147 Nalh 86dh Sttoet goserirglosrrr, PA 19595 Phi.datpli, PA 18122 810.618.15?2 216.235.8788 Madlt t-Ntowstdp Nouee Camel ltiuit Cometrunily Court Ina 302 Soulr Jackson Shed 5218 Neater Street Marls, PA 79083 Ptt9ads~1lb, PA 19131 810.565.0494 215.877.1137 CCCS o/ Ddnren ~~ ~ ~ eetrke 5001 North Broad Sheet 280 North Prcwidanca t4oad Pltladdpiria, PA 19141 Media, PA 19063 216.3'dM1.7600 216.683.5865 ~~ CCCB of Dafsvrare 1NMy Two Bala Pbza 790 E ti4srlwt S7. 9r~ 900 Bulb 170, Manilro0 Holding PNtitdabtlit, PA 19004 Wteat Chester, PA 193~t 810.880.8887 216.683.5686 Pl+ls Cow~el For Conasunlty Advsarrt t.~CB d Oatrrwte ~ 100 North 178r 3keat 1808 Wehut Sheet Sole 800 70th Floor Ptidr~irb, PA 19103 Ptrtsdalptlis, PA 19107 216.687.7809 219Fi69.6886 800.990.4N3 Pepe 8 d 19 HE~-P Consumer Credit Counseling Agencies Report fad updrhd:12FZ3/20081:82:41 PM t,raa4 ~ of PMlade~ria late f~cc sheet loth Floor PhNadalphta, PA 19108 215.985.3220 ELK COfffttr i~lorUrersr Tlar'tanarunlgrAafien Corp, PA. Hat 389 1351±Yed 481 strati Emporium, PA 16834 814.488,1181 ERR: C4ttfffh- f3ooioerT. Wrurlrinpten CaMw 1720 tio8artd Sbrtat Erie, PA 18500 814.453b744 CCCB of 1f~r PA 4402 Peach Sheet Erie, PA 18809 88611.2227 ext 108 888.611.2227 axt 108 tineaMr t.ria Commurdgr Aotlon Csmsr~tea 18 West 8TH Street Erie, PA 18501 814A88.4581 8t. ilAarrir Cerrfier 1701 Parode Street Erie, PA 14603 814.4628113 lfgfop for MrsMewertd~n 1107 Payne Avenue Erle, PA 1880.9 814.874.0064 800.836.9890 FAYETTE Couni)I Aellorr fiottaie~ trrc 425 8th Avenue sidle 850 PBfsbtuyir, PA 13219 412.281.2102 800.792.2801 CorAanwdgr Aatbtr soulnaiaet 54 Ead Groerw 8tnaet Wsynea0W8, PA 13970 724.8522893 Fsyatb Co. ComrnunKy AtAWn Apenay, fnc. 108 NoNrBseeon Avvxa~s Unionlovvrr, PA 15401 724A37r4050 800.427.NF0 Ta6Wered sar~i0ea fnG 536 Eaet Mdn Strsd 8omerast, PA 15501 814.445.9828 80D.452A148 FOREST YltatrerFfofesE Cetrrwea Eoaearaic Cppar6rmtiar L:otrrre8 1208 Pemeylvarda Ave, Vlhhrt P.O. Box 547 YVar-en, PA 16385 814.728.2400 FRANKLN COarNy Adenrs teuntfr fnlerflMBk NoastnEludhgltlr 40 E High Sheet C4at~rsbug, PA 17325 717.334.1818 Arnetfgn Red Crane -1[tu1oYM' Cf~ 629 Carlela Street Hanover, PA 17331 717.837.3788 Ct:CB oflMeefent PA 2000 Li~ileebr~n Road Harristxtrp, PA 171ffi 888.811.2227 688.511.2227 Ct5<:5 of 1Nesbam PA 55 Cbver Hf1 Road Daliaalown, PA 17313 888.511.2227 868.511.2227 Cnrrtnrueflfr AeHort Curnrniesfon a/CaFfW R~ploe 1514 Deny steal HarrYtwtp, PA 17104 717.232.9757 CCCS oft#raaisem PA 1 Norih Bala Stprna ffi Garden Canter Drive (~rearnburp, PA 18601 868.811.2227 886.511.2227 lAararralha 43 Phirdelpftla Avwrw iMayneobpq, PA 17288 717.742.3286 Pepe 9 Of 19 SHERIFF'S OFFICE OF CUMBERLAND COUNTY Ronny R Anderson F11 ED-0 WE Sheriff Jody S Smith 27 } AM : Chief Deputy Richard W Stewart $MKM NO Crjwi x '?? ;iI 1 .r;i1i t''1 Solicitor M & T Bank Case Number vs. 2010-7629 Harry G. Raudabaugh (et al.) SHERIFF'S RETURN OF SERVICE 12/15/2010 Ronny R. Anderson, Sheriff, who being duly sworn according to law, states that on December 15, 2010 at 1000 hours this Complaint in Mortgage Foreclosure upon defendant Harry G. Raudabaugh is returned not served per request from Attorney Charles E. Petrie. Deputies were advised, Harry G. Raudabaugh has filed bankruptcy under case number 1:09-bk-0471 1 -MDF. 12/17/2010 10:45 AM - Valerie Weary, Deputy Sheriff, who being duly sworn according to law, states that on December 17, 2010 at 1045 hours, she served a true copy of the within Complaint in Mortgage Foreclosure, upon the within named defendant, to wit: Donna J. Raudabaugh, by making known unto herself personally, at The Mount Holly Springs Post Office, 16 W. Pine Street, Mount Holly Springs, Cumberland County, Pennsylvania 17065 its contents and at the same time handing to her personally the said true and correct copy of the same. VA ERIE WEARY, DEPUTY SHERIFF COST: $74.60 December 21, 2010 SO ANSWERS, RON R ANDERSON, SHERIFF GOLDBECK McCAFFERTY & McKEEVER SUITE 5000 - MELLON INDEPENDENCE CENTER 701 MARKET STREET PHILADELPHIA, PA 19106-1532 (215) 627-1322 ATTORNEY FOR PLAINTIFF M&T BANK SB/M MANUFACTURERS AND TRADERS TRUST COMPANY 1100 Wehrle Drive Williamsville, NY 14221 Plaintiff vs. HARRY G. RAUDABAUGH DONNA J.RAUDABAUGH 445 Run Road Carlisle, PA 17013 Defendant(s) Term No. 10-7629 C7 N ? O Q PRAECIPE TO REINSTATE COMPLAINT rv Kindly reinstate the Complaint in the above captioned matter. IN THE COURT OF COMMON PLEAS OF Cumberland COUNTY O =-n r'n -a rn ?o o , --+c:) s -n O T Q \^.) ?rn D GO CK CCAFFERT & MCKEEVER Michael Mc 6129 Gary McCafferty Pa. ID 42386 Lisa Lee Pa. ID 78020 Kristina Murtha Pa. ID 61858 David Fein Pa. ID 82628 Thomas Puleo Pa. ID 27615 Attorneys for Plaintiff * 5s 16- 'N' 66 y7a CIVIL ACTION - LAW ACTION OF MORTGAGE FORECLOSURE SHERIFF'S OFFICE OF CUMBERLAND COUNTY Ronny R Anderson Sheriff Jody S Smith Chief Deputy Richard W Stewart Solicitor M & T Bank vs. Harry G. Raudabaugh (et al.) d FILED-OFFICE THE F C I !j "t, C'r ? !:, J 2 4. n: k u Li ?? Case Number 2010-7629 SHERIFF'S RETURN OF SERVICE 01/19/2011 02:15 PM - Gerald Worthington, Deputy Sheriff, who being duly sworn according to law, states that on January 19, 2011 at 1415 hours, he served a true copy of the within Complaint in Mortgage Foreclosure, upon the within named defendant, to wit: Harry G. Raudabaugh, by making known unto himself personally at The Cumberland County Prison, 1101 Claremont Road, Carlisle, Cumberland County, Pennsylvania 17015 its contents and at the same time handing to him personally the said true and correct copy of the same. SHERIFF COST: $33.40 January 20, 2011 GERALD WORTHING N, DEPUTY SO ANSWERS, RON R ANDERSON, SHERIFF McCABE, WEISBERG AND CONWAY, P.C. BY: TERRENCE J. McCABE, ESQUIRE - ID # 16496 MARC S. WEISBERG, ESQUIRE - ID # 17616 EDWARD D. CONWAY, ESQUIRE - ID # 34687 MARGARET GAIRO, ESQUIRE - ID # 34419 ANDREW L. MARKOWITZ, ESQUIRE - ID # 28009 HEIDI R. SPIVAK, ESQUIRE - ID # 74770 KEVIN T. MCQUAIL, ESQUIRE - ID # 307169 CHRISTINE L. GRAHAM - ID # 309480 123 South Broad Street, Suite 2080 Philadelphia, Pennsylvania 19109 (215) 790-1010 M&T BANK S/B/M/ MANUFACTURERS & TRADERS TRUST COMPANY PLAINTIFF -v -- cN d COURT OF COMMON PLEAS OF CUMBERLAND COUNTY NO.: 10-7629 v. HARRY G. RAUDABAUGH DONNA J.RAUDABAUGH MORTGAGE FORECLOSURE DEFENDANTS ENTRY OF APPEARANCE TO THE PROTHONTARY: Kindly enter the appearance of McCabe, Weisberg & Conway, P.C. as counsel in the above referenced action on behalf, of Plaintiff, M&T BANK S/B/M/ MANUFACTURERS & TRADERS TRUST COMPANY. Andrew L. Markowitz, Esquire Attorney for Plaintiff, M&T Bank Date: April 4, 2011 s/b/m/ Manufacturers & Traders Trust Company. Attorneys for Plaintiff McCABE, WEISBERG AND CONWAY, P.C. BY: TERRENCE J. McCABE, ESQUIRE - ID # 16496 MARC S. WEISBERG, ESQUIRE - ID # 17616 EDWARD D. CONWAY, ESQUIRE - ID # 34687 MARGARET GAIRO, ESQUIRE - ID # 34419 ANDREW L. MARKOWITZ, ESQUIRE - ID # 28009 HEIDI R. SPIVAK, ESQUIRE - ID # 74770 KEVIN T. MCQUAIL, ESQUIRE - ID # 307169 CHRISTINE L. GRAHAM - ID # 309480 Attorneys for Plaintiff 123 South Broad Street, Suite 2080 Philadelphia, Pennsylvania 19109 (215) 790-1010 M&T BANK SB/M/ MANUFACTURERS & TRADERS TRUST COMPANY COURT OF COMMON PLEAS OF CUMBERLAND COUNTY PLAINTIFF NO.: 10-7629 V. HARRY G. RAUDABAUGH DONNA J.RAUDABAUGH MORTGAGE FORECLOSURE DEFENDANTS CERTIFICATE OF SERVICE I, ANDREW L. MARKOWITZ, Esquire, attorney for Plaintiff, hereby certify that a true and correct copy Plaintiff s Entry of Appearance was served on the below parties on the 4" day of April, 2011 by the United states mail, first class: Harry G. Raudabaugh Donna J. Raudabaugh 445 Run Road Carlisle, PA 17013 DATE: April 4, 2011 ANDREW L. MARKOWITZ, ESQUI 553-9A- GOLDBECK McCAFFERTY & McKEEVER BY: Michael T. McKeever, Esquire Attorney I.D.#56129 Suite 5000 - Mellon Independence Center = r, `= - 701 Market Street mcaa _ s• r m72 Philadelphia, PA 19106-1532 = -am 215-627-1322 a., c Attorney for Plaintiff a _ ?,• -n M&T BANK SB/M MANUFACTURERS AND TRADERS TRUST COMPANY 1100 Wehrle Drive Williamsville, NY 14221 vs. HARRY G RAUDABAUGH DONNA J.RAUDABAUGH Mortgagor and Record Owner 445 Run Road Carlisle, PA 17013 zC) ;mac IN THE COURT OF COMMl§PLBr AS :9M --{ of Cumberland County -? CIVIL ACTION - LAW Plaintiff ACTION OF MORTGAGE FORECLOSURE Defendant(s) WITHDRAWAL OF APPEARANCE TO THE PROTHONOTARY: Term No. 10-7629 Kindly withdraw my appearance on behalf of Plaintiff, M&T BANK S/B/M MANUFACTURERS AND TRADERS TRUST COMPANY, in the above captioned matter. GOLDBECK McCAFFERTY & McKEEVER BY: ichael T. McKeever, Esquire Date: ?_ l McCABE, WEISBERG AND CONWAY, P.C. BY: TERRENCE J. McCABE, ESQUIRE - ID # 16496 MARC S. WEISBERG, ESQUIRE - ID # 17616 EDWARD T ). CONWAY, ESQUIRE - ID # 34687 MARGARI T GAIRO, ESQUIRE - ID # 34419 123 South Broad Str:et, Suite 2080 Philadelphia, Penns: lvania 19109 (215) 790-1010 M&T BANK S/B/A MANUFACTURES AND TRADERS TRUST wOMPANY Pb tintiff v. HARRY G. RAUDI AUG14 -AND- DONNA J. RAUDE BAUGH D fendants Attorneys for Plaintiff CUMBERLAND COUNTY COURT OF COMMON PLEAS Number 10-7629 ASSESSMENT OF DAMAGES AND ENTRY OF JUDGMENT TO THE PROTHON )TARY: n, C, v' E :77 r1l 7 - ri Y ` Kindly enter judgment by default in favor of Plaintiff and against Defendants in the above-captioned matter for failure to answer ( 'omplaint as required by Pennsylvania Rules of Civil Procedure and assess damages as follows: Principei Interest 'rom 09/01/10 to 04/29/11 $ 26,890.81 $ 410.76 Total $ 27,301.57 TERRENCE J. McCABE, ESQUIRE MARC S. WEISBERG, ESQUIRE} EDWARD D. CONWAY, ESQUIRE aC?? 134 Q MARGARET GAIRO, ESQUIRE Attorneys for Plaintiff 12- lwmr Y 7 Nu1?ce MPa kecl AND NOW, this day of , 2011, Judgment is entered in favor of Plaintiff, M&T BANK SB/M MAN, 'FACTURES AND TRADERS TRUST COMPANY, and against Defendants, HARRY G. RAUDBAUGH and ' 1ONNA J. RAUDABAUGH, and damages are assessed in the amount of $27,301.57, plus interest and costs. BY EPROTHONOTARY: McCABE, WEISBERG AND CONWAY, P.C. BY: TERRENCE J. McCABE, ESQUIRE - ID # 16496 MARC S. V'EISBERG, ESQUIRE - ID # 17616 EDWARD I). CONWAY, ESQUIRE - ID # 34687 MARGARET GAIRO, ESQUIRE - ID # 34419 123 South Broad Street, Suite 2080 Philadelphia, Pennsylvania 19109 (215) 790-1010 M&T BANK SBM1 MANUFACTURES AND TRADERS TRUST COMPANY Plaintiff V. HARRY G. RAUDBAUGH -AND- DONNA J. RAUDA BAUGH D. -fendants Attorneys for Plaintiff CUMBERLAND COUNTY COURT OF COMMON PLEAS Number 10-7629 AFFIDAVIT OF NON-MILITARY SERVICE COMMONWEALTH OF PENNSYLVANIA: COUNTY OF PHILADELPHIA: SS. The undersigned, being duly sworn according to law, deposes and says that the Defendants, HARRY G. RAUDBAUGH and DONNA J. RAUDABAUGH, are not in the Military or Naval Service of the United States or its Allies, or otherwise v ithin the provisions of the Soldiers' and Sailors' Civil Relief Act of Congress of 1940 as amended; and that the Defendants, HARRY G. RAUDBAUGH and DONNA J. RAUDABAUGH, are over eighteen (18) years of age, and reside as follows: HARRY G. RAUDBAUGH 445 Run Road Carlisle, Pennsylvania 17013 16 Allandale Drive Rochester, New York 14624 1101 Claremont Rd Carlisle, Pennsylvania 17015 SWORN AND SUBSCRIBED BEFORE ME THIS 29th DAY OF April_ 2011 COM 1?^^?A?T?+ ?PENFIBYLVANIA NOTARIAL SEAL Ernest Caldwell-Notary Public City of Philadelphia, Philadelphia County MY COMMISSION EXPIRES MAR. 25, 2015 DONNA J.RAUDABAUGH 445 Run Road Carlisle, Pennsylvania 17013 25 Horseshoe Road Carlisle, Pennsylvania 17015 104 November Drive, Apt. 6 Camp Hill, Pennsylvania 17011 TERRENCE J. McCABE, ESQUIRE MARC S. WEISBERG, ESQUIRE EDWARD D. CONWAY, ESQUIRE MARGARET GAIRO, ESQUIRE Attorneys for Plaintiff McCABE, WEISBERG AND CONWAY, P.C. BY: TERRENC",, J. McCABE, ESQUIRE - ID # 16496 MARC S. WEISBERG, ESQUIRE - ID # 17616 EDWARD D. CONWAY, ESQUIRE - ID # 34687 MARGARET GAIRO, ESQUIRE - ID # 34419 123 South Broad Street, Suite 2080 Philadelphia, Pennsylvania 19109 (215) 790-1010 M&T BANK SB/M MANUFACTURES AND TRADERS TRUST COMPANY Plaintiff V. HARRY G. kAUDBAUGH -AND- DONNA J.RAUDABAUGH Defendants Attorneys for Plaintiff COURT OF COMMON PLEAS CUMBERLAND COUNTY Number 10-7629 CERTIFICATION The undersigned hereby certifies that he is the attorney for Plaintiff, being duly sworn according to law, deposes and says that he deposited in the United States Mail a letter notifying the Defendants that judgment would be entered against them vithin ten (10) days from the date of said letter in accordance with Rule 237.5 of the Pennsylvania Rules of Civil Procedure. Copies of said letters are attached hereto and marked as Exhibit "A". SWORN AND SUBSCRIBED BEFORE ME THIS _29th_ DAY OF April_ _, 2011 NOTARY PUBLIC TERRENCE J. McCABE, ESQUIRE MARC S. WEISBERG, ESQUIRE EDWARD D. CONWAY, ESQUIRE MARGARET GAIRO, ESQUIRE Attorneys for Plaintiff COpMONWEALTH OF PENN5YLVANIA NOTARIAL SEAL Ln?e;s Caldwell-Notary Public iladelphia,Philadelphia County ISSION EXPIRES MAR. 25, 2015 VERIFICATION The undersigned attorney hereby certifies that he/she is the Attorney for the Plaintiff in the within action, and that he/she is authorized to make this verification and that the foregoing facts based on the information from the Plaintiffs representative, who is out of jurisdiction and not available to sign this verification at this time, are true and correct to the best of iis/her knowledge, information and belief and further states that false statements herein are made subject to the p,nalties of 18 PA.C.S. §4904 relating to unsworn falsification to authorities. TERRENCE J. McCABE, ESQUIRE MARC S. WEISBERG, ESQUIRE EDWARD D. CONWAY, ESQUIRE MARGARET GAIRO, ESQUIRE Attorneys for Plaintiff 86771FC THIS LAW FIRM IS A DEBT COLLECTOR AND WE ARE ATTEMPTING TO COLLECT A DEBT OWED TO OUR CLIENT. ANY INFORMATION OBTAINED FROM YOU WILL BE USED FOR THE PURPOSE OF COLLECTING THE DEBT. DATE OF THIS NOTICE: February 9, 2011 TO: HARRY G. RA IJDABAUGH RAUDABAUGA, HARRY G. 445 Run Road Carlisle, PA 174 :3 M&T BANK S/B/M b ANUFACTURERS AND TRADERS TRUST COMPANY 1100 Wehrle Drive Williamsville, NY 142 11 Plaintiff VS. HARRY G RAUDAB. ,UGH DONNA J. RAUDAB. IUGH (Mortgagor(s) and Rec ord Owner(s)) 445 Run Road Carlisle, PA 17013 Defendant(s) TO: HARRY G. RAUDABAUGH 445 Run Road CXh, 61 k A In the Court of Common Pleas of Cumberland County CIVIL, ACTION - LAW Action of Mortgage Foreclosure Term No. 10-7629 Carlisle, PA 17031 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 PAPER TO YOUR LAWYER AT ONCE. IF YOU DO NOT HAVE A LAWYER, GO TO OR TELEPHONE THE OFFICE SET FORTH BELOW. THIS OFFICE CAN PROVIDE YOU WITH INFORMATION ABOUT HIRING A LAWYER IF YOU CANNOT AFFORD TO HIRE A LAWYER, THIS OFFICE MAY BE ABLE TO PROVIDE i'OU WITH INFORMATION ABOUT AGENCIES THAT MAY OFFER LEGAL SERVICES TO ELIGIBLE PERSONS A A REDUCED FEE OR NO FEE. CUMBI tI.AND COUNTY BAR ASSOCIATION 211berty Avam Carlisle, .'A 17013 LEGAL `.- ERVICES INC 8 Inure .k-ow Carlisle, ?A 17013 717-243 7400 By: A 1Y ??A allz- G CK MC AFFERTY & MCKEEVER Mic ael McKeev Pa. ID 56129 Gary McCafferty Pa. ID 42386 Lisa Lee Pa. ID 78020 Kristina Murtha Pa. ID 61858 David Fein Pa. ID 82628 Thomas Puleo Pa. ID 27615 Jill P. Jenkins Pa. ID 306588 215-825-6360 Attorneys for Plaintiff 86771FC THIS LAW FIRM IS A DEBT COLLECTOR AND WE ARE ATTEMPTING TO COLLECT A DEBT OWED TO OUR CLIENT. ANY INFORMATION OBTAINED FROM YOU WILL BE USED FOR THE PURPOSE OF COLLECTING THE DEBT. DATE OF THIS NOTICE: February 9, 2011 TO: HARRY G. RAtJDABAUGH RAUDABAUGfI, HARRY G. 16 Allendale Dri !e Rochester, NY 1 X624 M&T BANK SB/M N'. ANUFACTURERS AND TRADERS TRUST COMPANY 1100 Wehrle Drive Williamsville, NY 142.1 Plaintiff VS. HARRY G RAUDAB..UGH DONNA J. RAUDAB UGH (Mortgagor(s) and Rec-')rd Owner(s)) 445 Run Road Carlisle, PA 17013 Defendant(s) In the Court of Common Pleas of Cumberland County CIVIL ACTION - LAW Action of Mortgage Foreclosure Term No. 10-7629 TO: HARRY G. RAUDABAUGH 16 Allandale Drive Rochester, NY 14624 IMPORTANT NOTICE YOU ARE IN DEFAULT BECAUSE YOU HAVE FARM 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 RAPORTANT RIGHTS. YOU SHOULD TAKE THIS PAPER TO YOUR LAWYER AT ONCE. IF YOU DO NOT HAVE A LAWYER, GO TO OR TELEPHONE THE OFFICE SET FORTH BELOW. THIS OFFICE CAN PROVIDE YOU WITH INFORMATION ABOUT HIRING A LAWYER IF YOU CANNOT AFFORD TO HIRE A LAWYER, THIS OFFICE MAY BE ABLE TO PROVIDE 707` WITH INFORMATION ABOUT AGENCIES THAT MAY OFFER LEGAL SERVICES TO ELIGIBLE PERSONS K,' A REDUCED FEE ORNO FEE. CUMBE ,LAND COUNtY BAR ASSOCIATION 2 L il" Avenue Cariisle, ? A 17013 LEGAL SERVICES INC 8 Irvine Pow Carlisle, I?A 17013 717-243-9400 By: GOL B- K M AFF'ERTY & MCKEEVER Mic el McKee er Pa. ID 56129 Gary McCafferty Pa. ID 42386 Lisa Lee Pa. ID 78020 Kristina Murtha Pa. ID 61858 David Fein Pa. ID 82628 Thomas Puleo Pa. ID 27615 AH P. Jenkins Pa. ID 306588 ? 215-825-6360 Attorneys for Plaintiff 86771FC THIS LAW FIRM IS A DEBT COLLECTOR AND WE ARE ATTEMPTING TO COLLECT A DEBT OWED TO OUR CLIENT. ANY INFORMATION OBTAINED FROM YOU WILL BE USED FOR THE PURPOSE OF COLLECTING THE DEBT. DATE OF THIS NOTICE: February 9, 20111 TO: HARRY G RAUDABAUGH RAUDABAUG) 4 HARRY G. 1101 Claremont Rd Carlisle, PA 170 5 M&T BANK SB/M MANUFACTURERS AND TRADERS TRUST COMPANY 1100 Wehrle Drive Williamsville, NY 142"',1 Plaintiff VS. HARRY G RAUDABJ -UGH DONNA 1 RAUDARt .UGH (Mortgagor(s) and Record Owner(s)) 445 Run Road Carlisle, PA 17013 Defendant(s) TO: HARRY G RAUDABAUGH 1101 Claremont Rd Carlisle, PA 1701 Y In the Court of Common Pleas of Cumberland County CIVIL ACTION - LAW Action of Mortgage Foreclosure Term No. 10-7629 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 EIGHTS. YOU SHOULD TAKE THIS PAPER TO YOUR LAWYER AT ONCE. IF YOU DO NOT HAVE A LAWYER, GO TO OR TELEPHONE THE OFFICE SET FORTH BELOW. THIS OFFICE CAN PROVIDE YOU WITH INFORMATION ABOUT HIRING A LAWYER. IF YOU CANNOT AFFORD TO HIRE A LAWYER, THIS OFFICE MAY BE ABLE TO PROVIDE -'OU WITH INFORMATION ABOUT AGENCIES THAT MAY OFFER LEGAL SERVICES TO ELIGIBLE PERSONS AT A REDUCED FEE ORNO FEE. CUMBE.,LAND COUNTY 13AR ASSOC7ATTON 2 Liberty 4venue Cadisle, k 17013 LEGALERVICESINC 8 Irvioe 1,)w Cadisle, :-,A 17013 717-243-0400 c By: /dAA?? GO BECK CCAFTERTY & MCKEEVER Mic ael McKeever Pa. ID 56129 Gary McCafferty Pa. ID 42386 Lisa Lee Pa. ID 78020 Kristina Murtha Pa. ID 61858 David Fein Pa. ID 82628 Thomas Puleo Pa. ID 27615 Jill P. Jenkins Pa. ID 306588 215-825-6360 Attorneys for Plaintiff 86771FC THIS LAW FIRM IS A DEBT COLLECTOR AND WE ARE ATTEMPTING TO COLLECT A DEBT OWED TO OArJR CLIENT. ANY INFORMATION OBTAINED FROM YOU WILL BE USED FOR THE PURPOSE OF COLLECTING THE DEBT. DATE OF THIS NOTICE: February 9, 2011 TO: DONNA J. RAOJDABAUGH RAUDABAUG-1, DONNA J. 445 Rim Road Carlisle, PA 17013 M&T BANK SB/M.N"ANUFACTURERS AND TRADERS TRUST COMPANY 1100 Wehrle Drive Williamsville, NY 142 t 1 Plaintiff VS. HARRY G RAUDAB..UGH DONNA J. RAUDAB :UGH (Mortgagor(s) and Re( ord Owner(s)) 445 Run Road Carlisle, PA 17013 Defendant(s) TO: DONNA J. RAUDABAUGH 445 Run Road Carlisle, PA 170-1 In the Court of Common Pleas of Cumberland County CIVIL ACTION - LAW Action of Mortgage Foreclosure Term No. 10-7629 B PORTANT NOTICE YOU ARE IN I)EFAULT 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 kIGHTS. YOU SHOULD TAKE THIS PAPER TO YOUR LAWYER AT ONCE. IF YOU DO NOT HAVE A LAWYER, GO TO OR TELEPHONE THE OFFICE SET FORTH BELOW. THIS OFFICE CAN PROVIDE YOU WITH INFORMATION ABOUT HIRING A LAWYER IF YOU CANNOT AFFORD TO HIRE A LAWYER, THIS OFFICE MAY BE ABLE TO PROVIDE YOU WITH INFORMATION ABOUT AGENCIES THAT MAY OFFER LEGAL SERVICES TO ELIGIBLE PERSONS A:, .'A A REDUCED FEE OR NO FEE. CUMBER2L WD COUNTY BAR ASSOCIATION 2lh" .Avenue Carlisle, !'A 17013 LEGAL SBRVICI;.S INC 8Irvine Ruw Carlisle, i,A 17013 717-243.9400 ` By: ?/111 r GO B C CCAFFERTY & MCKEEVER Michael Mc Bever Pa. ID 56129 Gary McCafferty Pa. ID 42386 Lisa Lee Pa. ID 78020 Kristina Murtha Pa. ID 61858 David Fein Pa. ID 82628 Thomas Puleo Pa. ID 27615 Jill P. Jenkins Pa. ID 306588 215-825-6360 Attorneys for Plaintiff 86771FC THIS LAW FIRMS IS A DEBT COLLECTOR AND WE ARE ATTEMPTING TO COLLECT A DEBT OWED TO OUR CLIENT. ANY INFORMATION OBTAINED FROM YOU WILL BE USED FOR THE PURPOSE OF COLLECTING THE DEBT. DATE OF THIS NOTICE: February 9, 2011 TO: DONNA J. RAk JDABAUGH RAUDABAUGA, DONNA J. 25 Horseshoe RA:ad Carlisle, PA 17015 M&T BANK SB/M N ANUFACTURERS AND TRADERS TRUST COMPANY 1100 Wehrle Drive Williamsville, NY 14221 Plaintiff VS. HARRY G RAUDAB. iUGH DONNA J. RAUDAB AUGH (Mortgagor(s) and Rec<)rd Owner(s)) 445 Run Road Carlisle, PA 17013 Defendant(s) TO: DONNA J. RATT)ABAUGH 25 Horseshoe Road Carlisle, PA 17015 In the Court of Common Pleas of Cumberland County CIVIL ACTION - LAW Action of Mortgage Foreclosure Terra No. I 0-7629 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 PAPER TO YOUR LAWYER AT ONCE. IF YOU DO NOT HAVE A LAWYER, GO TO OR TELEPHONE THE OFFICE SET FORTH BELOW. THIS OFFICE CAN PROVIDE YOU WITH INFORMATION ABOUT HIRING A LAWYER. IF YOU CANNOT AFFORD TO HIRE A LAWYER, THIS OFFICE MAY BE ABLE TO PROVIDE *.OU WITH INFORMATION ABOUT AGENCIES THAT MAY OFFER LEGAL SERVICES TO ELIGIBLE PERSONS A'.. A REDUCED FEE OR NO FEE. CUMBEJ AM COUNTY BAR ASSOCIATION 2 LibcM Avenue Cadisk, PA 17013 LEGAL SERVICES INC 8 Irvine F.ow Carlisle, 'A 17013 717-243-1400 By: GO DB CK 1? C R & MCI FEVER Michael McKee r Pa. ID 56129 Gary McCafferty Pa. ID 42386 Lisa Lee Pa. ID 78020 Kristina Murtha Pa. ID 61858 David Fein Pa. ID 82628 Thomas Puleo Pa. ID 27615 Jill P. Jenkins Pa. ED 3065881/ 215-825-6360 Attorneys for Plaintiff 86771FC TEAS LAW FIRM IS A DEBT COLLECTOR AND WE ARE ATTEMPTING TO COLLECT A DEBT OWED TO OUR. CLIENT. ANY INFORMATION OBTAINED FROM YOU WILL BE USED FOR THE PURPOSE OF COLLECTING THE DEBT. DATE OF THIS NOTICE: February 9, 2011 TO: DONNA J. RATTDABAUGH RAUDABAUG?i DONNA J. 104 November Drive, Apt-6 Camp Hill, PA 17011 M&T BANK SB/N 4 MANUFACTURERS AND TRADERS TRUST COMPANY 1100 Wehrle Drive Williamsville, NY 142 21 Plaintiff VS. HARRY G RAUDAB. iUGH DONNA J. RAUDAB HUGH (Mortgagor(s) and Record Owner(s)) 445 Run Road Carlisle, PA 17013 Defendant(s) TO: DONNA I RAUDABAUGH 104 November Drive, ApL6 Camp Hill, PA 17011 In the Court of Common Pleas of Cumberland County CIVIL ACTION - LAW Action of Mortgage Foreclosure Term No. 10-7629 IMPORTANT NOTICE YOU ARE IN DEFAULT BECAUSE YOU HAVE FARED 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 '2- 4TERFD AGAINST YOU WITHOUT A HEARING AND YOU MAY LOSE YOUR PROPERTY OR OTHER IMPORTANT -RIGHTS. YOU SHOULD TAKE THIS PAPER TO YOUR LAWYER AT ONCE. IF YOU DO NOT HAVE A LAWYER, GO TO OR TELEPHONE THE OFFICE SET FORTH BELOW. THIS OFFICE CAN PROVIDE YOU WITH INFORMATION ABOU T HIRING A LAWYER IF YOU CANNOT AFFORD TO HIRE A LAWYER, THIS OFFICE MAY BE ABLE TO PROVIDE lOU WITH INFORMATION ABOUT AGENCIES THAT MAY OFFER LEGAL SERVICES TO ELIGIBLE PERSONS A f A REDUCED FEE OR NO FEE. CUMBE'21 APED COUNTY BAR ASS00ADON 2 Liberty Avenue Carlisle, a'A 17013 LEGAL ERVICES INC a hvine tow Carlisle, ?A 17013 717-243 9400 By: GOL E M+era. R & MCKEEVER Michael McKee56129 Ga ry McCafferty Pa. ID 42386 Lisa Lee Pa. ID 78020 Kristina Murtha Pa. ID 61858 David Fein Pa. ID 82628 Thomas Puleo Pa. ID 27615 Jill P. Jenldns Pa. ID 306588 ?? 215-825-6360 Attorneys for Plaintiff David -D. Buell 1Prothonotary Office of the Prothonotary Cumberland County, Pennsylvania xyrkS. Sofionage, ESQ Solicitor - 9 CIVIL TERM ORDER OF TERMINATION OF COURT CASES AND NOW THIS 28TH DAY OF OCTOBER, 2014, AFTER MAILING NOTICE OF INTENTION TO PROCEED AND RECEIVING NO RESPONSE —THE ABOVE CASE IS HEREBY TERMINATED WITH PREJUDICE IN ACCORDANCE WITH PA R.C.P.230.2. BY THE COURT, DAVID D. BUELL PROTHONOTARY One Courthouse Square • Suite100 • CarCisfe, 1'A • Phone 717 240-6195 • Ta.� 717 240-6573