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Home My WebLink About01-2423FEDERMAN AND PHELAN, LLP By: FRANK FEDERMAN, ESQUIRE IDENTIFICATION NO. 12248 ONE PENN CENTER AT SUBURBAN STATION 1617 JOHN F. KENNEDY BOULEVARD SUITE 1400 PHILADELPHIA, PA 19103-1814 (~ 5) 56_~-7ooo ATTORNEY FOR PLAINTIFF COURT OF COMMON PLEAS CIVIL DIVISION BANK OF AMERICA, NA, F/K/A NATIONS BANK, NA 101 EAST MAIN STREET, LOUISVILLE, KY 40232 Plaintiff Vo TERM BARRY L. STE1NOUR FELICIA F. STEINOUR 20 FAIRFIELD STREET, MOUNT HOLLY SPRINGS, PA 17065 CUMBERLAND COUNTY Defendant(s) CMl. ACTION - LAW COMPLAINT IN MORTGAGE FORECI,OSIIRE NOTICE **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 AND THIS DEBT WAS NOT REAFFIRMED, THIS CORRESPONDENCE IS NOT AND SHOULD NOT BE CONSTRUED TO BE AN ATTEMPT TO COLLECT A DEBT, BUT ONLY ENFORCEMENT OF A LIEN AGAINST PROPERTY. ** 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 this Complaint and Notice are served, by entering a written appearance personally or by attorney and filing in writing with the court your defenses or objections to the claims set forth against you. You are warned that if you fail to do so the case may proceed without you and a judgment may be entered against you by the court without further notice for any money claimed in the Complaint or for any other claim or relief requested by the Plaintiff. You may lose money or property or other rights important to you. YOU SHOULD TAKE THIS PAPER TO YOUR LAWYER AT ONCE. IF YOU DO NOT HAVE A LAWYER OR CANNOT AFFORD ONE, GO TO OR TELEPHONE THE OFFICE SET FORTH BELOW TO FIND OUT WHERE YOU CAN GET LEGAL HELP. CUMBERLAND COUNTY CUMBERLAND COUNTY BAR ASSOCIATION 2 LIBERTY AVENUE CARLISLE, PA 17013 (717) 249-3166 Loan #: 1592732 Plaintiff is: , BANK OF AMERICA, HA, F/K/A HAT/OHS 101 EAST MA~ STREET, BANK, HA LOUISVILLE, KY 40232 The name(s) and last known address(es) of the Defendant(s) are: BARRY L. STEINOUR FELIC/A F. STE1NOUR 20 FAIRFIELD STREET, MOUNT HOLLY SPRINGS, PA 17065 o , who/s/are the mortgagor(s) and real OWner(s) of the property hereinafter described. On 8/25/89 mortgagor(s) made, executed and delivered a mortgage upon the premises .hereinafter described to GMAC MORTGAGE CORPORATION OF PA which mortgage ~s recorded in the Office of the Recorder of CUMBERLAND County, No. 950, Page 560. By Assignment of Mortgage in Mortgage Book assigned to SOURCE ONE MORTGAGE the mortgage Recorded 1/2 7/93 Assignment is recorded in Assignment SERVICES CORPORATION whiWeas Assignment of Mort of Mortgage NATIONSBANc ,,....~g_age Recorded 9/6/o~ - Book No. 436, Page 558. Assim,,~ ..... ~v~t31(TGAGE C,.,,~...._ ~,~ the mo - the o'"'.*,,t OtMortgage Book No $~tt~2RA_TIoN Which 'art~g~ge Was assigned to mortgage and is in the process of formalizing an assignment e ~s now the legal OWner · ~'-,, rage 573 pl~amr~~a~gnment is record · -"~·w ' ed in The premises subject to said mortgage is described as attached.°fsame' of The mortgage is in default because monthly payments of principal and interest upon said mortgage Clue 11/1/00 and each month thereafter are clue and unpaid, and by the terms of said mortgage, upon default in such payments for a period of one month, the entire principal balance anti all interest due thereon are collectible forthwith. . The following amounts are due on the mortgage: Principal Balance Interest 11.86 through 10/1/00 (Per Diem $4/1/01) Attorney,s Fees Cumulative Late Char~es 8/25/89 to 4/1/01 Cost of Suit and Title Search Subtotal $43,298.84 2,170.38 2,164.00 61.49 ~SCrow Credit Deficit Subtotal TOTAL $48,244.71 0.00 e The attorney,s fees set fi $48,483.79 pennsylvania o orth above are ' Sheriff's .~o,~. L.~w., and will be ,~,,~_. ,n. .cOuforrni~n "' ":~ ~_v~ortgage doc . will be Charged. ~'~'~ ~ reinstated prior to ha attorney,s fees 8. Notice of Intention to Foreclose has been sent to Defendant(s) by Certified Mail, as required by ,Act 6 of 1974 of the Commonwealth °fPennsylvania on the date(s) set forth m the true and Correct Copy(s) of such not/ce(s) attached hereto as Exhibit "A." WHEREFORE, PLAINTIFF demands an in rem Judgment against the Defendant(s) in the $48,483.79, together with interest from 10/1/00 at the rate of $4/1/01 sum of Judgment, and other costs and charges collectible per diem to the date of sale of the mortgaged property, under the mortgage and for the foreclosure and FRANK FEDERMAN, ESQUIRE Attorney for Plaintiff February Barry Steino 20 Pai-~. - ur Mt HOlly Spgs PA 17065 Bank of 52 _ America Mort ACT 6.1 gage ~_cco~ Nov~- · ....... ~-- ORTG ~R- - PROPERs- __ Feli6~ 2 ' ~u r'a~rfield St NOTICE OF INTENTION TO FORECLosE MORTGAGE Bank o_f Ameri ca Mort gage P. O. ~ox 35140 L°uisville , KY 40232-S140 THE MORTGAGE HELD B '~oO~io[~sS) ON YOUR ~RO~~,, __ ica. Mortgage NO% ~~ ..?~, PA170~ 'ank of ~NTs m~~ERZou:n AT 29- Fairfie~ ~TER u~. Ol. o~ · ~. uo ~ SS,~ ~f ~592 4~ g D~FA'~T B~ .... ~u st, · 2409'81'~0M~~,~ - -' ~ FOR ~; FOR T~ MO~-au8~ YO,,- : ~~ oz. oz ~- zz. o~. oo ~IS j D~ZNQ~NCY A~ O~ ~eb~ua~y 26, 200Z TOT~ OELiNQ~N~ ~HE TOT~ . .... ~ OF Peb~a~. $ 2, 348.32 BRING yOr~~~~T NOW--- ~ 26, 2001 ~ WA~E .~ ~=QU~D _ 61.49 ~S ~E~, ~O_~E ~IS DEPART' OR IN O~ER YOU ~y ~E ~IS DEFA DATE OF LETTER, BY p ~ ' OF THE 2409.81 PLUs ~YING T D ~ ~D TO T~ IN TH LETTER I ~ING ITIoH E MORTG IRTy LOUIs FIED ~ PA ~ ~0~ TE 0 zn Sure NTUcKy ,uumEy ~ ~' ~%~SS ~ ~_ ~2409_ et, S ' 40232 O~ER ~E EI ICH -81, u~te 400 . , OR ~I~__, ~ ~i~__THER BY o~o~Y ~vZ~le , K~_~ ~~ ~~S~-~- =' o. BOX THIS ..~f~S TO EX~~E DE--- =~cUcky 40~n'~=~ ~DREo~' ~n140, : o o ~'~'~L~-~- ~osE m~ _ ~uu~T '"~'l'S · a= C~CE TO~)RRO~D 'AY OFF ~OPER ~u PRO ~r ~S ~'~~T C TY WILL PERTy. 0 I~EN IS NOT S~E T~E DEFA BE SOLD BY IF THE MOR DS TO STATUE WITHIN TILL ~ ~T ~E T~E S TGAGE A ~W T~IRT ro _ ~ To Foas ~s~z~p ~s FOa _ SVZT T 5 PA ~ TO EC 0 $ 0 o0 Y THE BEGIN L PAY OF LOSED, FORECLo ' ' HOWE R~SO~ EG~ F T~ YO~ VER ~LE ~ E MOR MOR TG 'ROC , IF ATT EEDI TGAG LEG O~E NGS E DE D DRO13 045 DB3 ~ PROCEED ~ , FEES AGAINST FO BT._ IF ~'Z~D AGAi~$~u~RRED, ~u, YOU P~bz'uaz~ ~, 2001 Bank of Ame. P- O. Bo- r~ca Mortgage Louisvil ~x 35140 · e, KY 40232-S140 Felicia Ste' 20 Pa~ .... ~nOur .Mt Ho~fr~eld St Bank of . S2 AcTA~6 .e~~ca Mortgage aCco wr . Mt HOlly 8D/s St THE MORTGAG NOTICE OF iNTE~ION PA 17065-1705 US · OR ELD TO ~ ~~ ~ ER~ a Mot ~0 E MOtH 17065, I LOCATE tgage UGH 1 LY PA S IN D AT · (HERE 02 01 n. 2.0~ 00 a~~~NTs OF eS~IOUs D 20 ~airf..,IN~TER ' · -~. ' ~,~ ~S9 ERA ~e,.d 2409 ~E $S81 z.43 ~T B St, · 81 TO~ .73 FO E~ ~, COMp ~ D FOR R TH U~,E ~~D ~- - ELINQr~,,. ~E MO~ E MO~u. _ YOU ~u~ ~ '~ZS 5.--~- gl . o~ .. ~ . ol On DELZNQ~NcY : ~rE c~g~_4s O~ ~eb-- ~/OT~ER FE~a~ 26, 20 TOTa r .... o 01 ~ ~L~NQ~Ncy ~ OF Febr $ 2,348 32 THE TOT~ ~0~ NO~ REQUI Uary 2 6, 2 001 61 4 9 ~~~~ YO~ pA~~s r~_ RED T __~ $ _ ' ~u ~y ~_ C~~NT, a_~~-u~ T ~ -- 2409 ~LUS ' ~ PAYI D~~ULT _ ~*'~' OF ' ~ IN _ ~E~,- C THIs pR~ - _ ~ MO~~ ..R TGAGE CO~ ~- (3 0 ) DA,.- S $ 24 09 ' -=A, CER u~XOD . ~r PA~ ~~ T ~~ OF .81. LOUI TIFI ' SUCH E~S HE THE D SVI SD C PA Mai LLE, ~ ~ECK OR ~E~ ~ ~TE C ~O~T OF n Stre ~~C~ _ MONEy ~8T BE ~GES _ OF 2 e t, Su' 4 0232 O~ER ~E E ~I~ at , 0 · I "-- 1, IF YOU DO NOT ~E TH ZSVZlle, ~_~ O~ P~_o--- P.O S~-'_ CASHIER, ~ ~u'zSE ~ WI~I WILL. BE C ~r ~m THE R N ONSI ~0 ACCELE~,~ DAYs, NG ON THE 0 ,' ~_~a¢-r WIr.r -f~OPER~v--'~ ~SO rxr ;~A~T IS NOT ~ THE DE E SOLD I~ THE ~0 ST~~. ~ NI~IN __ STI FLU By M( ~RTGAG~ LL LT T T -~~ T _ BEFOR ~ SHERI ~ IS FO~_~ ~WSUIT ~HIRTy (3n O SSu 0 PAY E WE e ~ TO .oo ssm _ o 5ossn, - DR193 - ~R, Ir Lm~,~LE AT,~ PRO -- ,a=.M -~u~ MO ~0~--- CEEDINGo . _ORTGAGR ~__ I~TGAG~n o10 -u~ PROCE] DINc ~ =~'ES "~"~T y '' IF · S , ACT OU YOU ~r N L ED AG r~,~_~RED, r~ ~' YOU WILL HAVE TO PAY T~E Ss0.00. ANy aT ITHIN ~SO I ~DED YOU ~~ ~E R W~ NO~ -- : ~- ~Or~ O~ A TO ~S t~E YOU CEEDINGs ~ ~Y ~~ TO E NON T~ MORT~AG~ C ~ OMp ~~ SEG~ ~-~N THE ~ ~ER ON~Ly FO AT , YOU ~IRTy THE MORT R THE ~Y DO TO 0 T l'u -~u ~ ~ ~'~ 0 = ~-~m ~ THE ~~T E PRO · ~EEs R ~~ER C TO~~ ~O~ $~RZFF's F ~ {RE~ CEE~NG o ~_COST~ ~SS T~~ T_ OF T~ O~Cnos . ~ER R CO~~c O~ ~PA ~E S EQUIR TED W , ~ ~D MO EME ITH ~LL ~HLY · YOU ~LIEs ~S THE F ~ ~ PA~ OF OF T~E ~HS FR S~E CO T~'~TED -- _ CO~sE - .... SHERIFF,s o,.~M THE DATR __~D BE ~Er-~ __~~T THE LON , ~'n~ ~0 o~E W ~ oF TH ~ a~PRo %uz~sn ~a ._~ou ~~ o_~ z ~o you s ~ ~OT~c~ TOL ~E~ W FI~ HE DEF EFO~ T OP ~ FREE ILL BE _ o~ AT ~~T WI _HE S~ B ~E BY ~ T LL IN E. E IN R, 1-8 ~LING Im~ E ~H, ~ 88-915_ T~E ~~LY ~LE TO . CHECK ~NT CO _COMp~ _ r~ MO , c~RTZ~ ~S~Lz AT ~ RTGAGE IED ~EC NG DEPT ~ FOL~W YOU SHO~D ~ COMp~ ~ __ K OR MONR.- - ' THIS ~ .... ING GED PR ~T A D~o~ LI~ OPER~ S~aZFF, ~-l'~ AFTER ~~~d_'l~ ~~~, ~..END YO~ ~,.---__ STATED TO EVICT YOU. '"~ ~aERIPp, ~ ~t' xm IT ~, ~?~RSHIp m~ E, A ~wo,,._ U CO~i~m THE · .ouz'l' CO~D -'"~ TO YOU ~~ ~DIT ' YOU ~ ION~ R PROp ~n~ DEBT -~uw MO ~-~'r TO O ~"~~ST I ERTy S~ ' (YOU ~Y FROM STAIN MO N THE PR T~E _ ~CT T _ ~Y ~ _~OTHE . _~Y TO _ OPERTy. ~RTGAGE ~T~E MO . ~THE RI R LE~i~ P~Y OFF ~ ~to~z,pest, ~ov~oz~t~a~ ~o a s ~.t ~o!~LL o~ mStZ~Zo~ ~E O S FEE · T~T ~ER OR a T~S TO R,.,~~ ~D ~~$ ~E E PAID p ~ING ~ 0 WILL ~F -~v~. T~I "~U~T~ GAu~-~E '-f ~-~S S . ~%~3 .... u S Y ~ ~ ~IGH ' ~-U~A ~ ~ T EXIS ~ US - ~L'TING ON v~:~vs ~ ~u~E ~ 0 ~o~ o~a~ e~~o ~o ~L ~ ~s~O~ _ T MO~ T~.. _~~R, yo~ ~_ D TO THE ~RY TRULY YO~s ~ THREE ~t,,Z ~= NOT m~t---Y~u~' PO ' N D Malinda La~ ~E~a y~ Collections Department CERTIFIED ~IL-RE~ RECEIPT REQ~ST RE~ RECEIPT NO. 7000 0600 0023 9162 6466 cc: VA/FHA/PMI No DR040 028 DB3' '"-'~OU,.,r... - ~'r'~'et: .... -"~ ~,~t::e--- ~ crt _~Zng ?C, Ho _ _the n _ on oF _P OVeme _ ~nli·.,_~ZsO ~no,..-- 21y Sp~l~_~~hwes~ ~h~ sou ~S ~he~ ook_~, Pa end ~Z~hp ~..~E [o~ mbe~end e oF Ce~e ~n ~~e o -- zOLlo~,_~Ced 0~--~' o5 s~ .... zU~Zy b~.-2'~ cumbe,~_~cs by ' S/de - et e --- - a~ng d-~. West, 15~ _n side _~ _sai~ be_~eet (35 O~ ~l~ht-of _ _ -, Nom~= _ ~mePl,, __, 105.65 -- extends_ the no~~ mlnute~ Ea = ex~en . '"weste~ _ minutes ~"ca~e~. .~= set at -- B~ING ~= t mentio___th 55 d~_._afOresai~ n Pin ~eed date ' u-Peme~ . d end Cne~y[ A Unto Ch~lstOphe~ C Sh ' Vol. 33, Page GmantOms herein. ' ugha~t and ~endy Lee Richamdson' P~SES ON: 20 F~~~ S~, ~~ ~~ S~~S, PA 17065 ' !g88 and recorded and fo~ Cumbenland the VERIFICATION B. SCOTT ARNOLD hereby states that he is V.P. of BANK OF AMERICA (KY) mortgage servicing agent for Plaintiff in this matter, that he is authorized to take this Verification, and that the statements made in the foregoing Civil Action in Mortgage Foreclosure are true and correct to the best of his knowledge, information and belief. The undersigned understands that this statement is made subject to the penalties of 18 Pa. C.S. Sec. 4904 relating to unswom falsification to authorities. DATE' B. SCOTT ARNOLO VICE PRESIDENT SHERIFF' S RETURN - REGULAR CASE NO' 2001-02423 P COMMONWEALTH OF PENNSYLVANIA' COUNTY OF CUMBERLAND BANK OF AMERICA N A VS STEINOUR BARRY L ET AL DAWN L. KELL , Sheriff or Deputy Sheriff of Cumberland County, Pennsylvania, who being duly sworn according to law, says, the within COMPI.AINT - MORT FORE was served upon the STEINOUR FELI CIA F DEFENDANT , at 1757.00 HOURS, on the 27th day of April , 2001 at 20 FAIRFIELD STREET MT HOLLY SPRINGS, PA 17065 by handing to FEI.ICIA F. STEINOUR a true and attested copy of COMPLAINT - MORT FORE together with and at the same time directing Her attention to the contents thereof. Sheriff's Costs- Docketing Service Affidavit Surcharge 6.00 .00 .00 So Answers- 10.00 R. Thomas Kline .00 16.00 04/30/2001 FRANK FEDERMAN Sworn and Subscribed to before me this /-'~',~-...'~ day of Deputy Sheriff ~ ~ - Pr tl~o~otary ,," ..... SHERIFF' S RETURN - REGULAR CASE NO: 2001-02423 P COMMONWEALTH OF PENNSYLVANIA: COUNTY OF CUMBERLAND BANK OF A_MERICA N A VS STEINOUR BARRY L ET AL DAWN L. KELL , Sheriff or Deputy Sheriff of Cumberland County, Pennsylvania, who being duly sworn according to law, says, the within COMPLAINT - MORT FORE was served upon STEINOUR BARRY L the DEFENDANT , at 1757-00 HOURS, on the 27th day of April , 2001 at 20 FAIRFIELD STREET MT HOLLY SPRINGS, PA 17065 by handing to FELICIA F. STEINOUR WIFE a true and attested copy of COMPLAINT - MORT FORE together with and at the same time directing Her attention to the contents thereof. Sheriff's Costs- Docketing Service Affidavit Surcharge So Answers: ... .00 10.00 R. Thomas Kline .00 31.72 04/30/2001 FRANK FEDERMAN Sworn and Subscribed to before me this ~t~'~ day of _. By- Deputy Sheriff FEDERMAN AND PHELAN By: FRANK FEDERMAN Identification No. 12248 One Penn Center at Suburban Station Suite 1400 Philadelphia, PA 19103-1814 (215) 563-7000 BANK OF AMERICA, NA, F/K/A NATIONS BANK, NA 101 EAST MAIN STREET LOUISVILLE, KY 40232 Plaintiff VS. BARRY L. STEINOUR FELICIA F. STEINOUR 20 FAIRFIELD STREET MOUNT HOLLY SPRINGS, PA 17065 Defendant(s) Attorney for Plaintiff · CUMBERLAND COUNTY · · COURT OF COMMON PLEAS · CIVIL DIVISION · NO. 2001-2423 PRAECIPE FOR JUDGMENT FOR FAILURE TO ANSWER AND ASSESSMENT OF DAMAGES TO THE PROTHONOTARY: Kindly enter judgment, in rem, in favor of the Plaimiff and against _BARRY L. STEINOUR and FELICIA F. STEINOUI~, Defendant(s), for failure to file an Ansx~er to Plaintiff's Complaint within 20 days from service thereof and for foreclosure and sale of the mortgaged premises, and assess Plaintiffs damages as follows: As set forth in Complaint Interest 10/1/00-5/30/01 TOTAL $48,483.79 $2~870.12 $51,353.91 I hereby certify that (1) the addresses of the Plaintiff and Defendant(s) are as shown above, and (2) notice has been given in accordance with Rule 237.1, copy attached. RMAN, ESQU/RE Attomey for Plaintiff DAMAGES ARE HEREBY ASSESSED AS INDICATED. **THIS FIRM IS A DEBT COLLECTOR ATYEMPTING TO COLLECT A DEBT AND ANY INFORMATION OBTAINED WILL BE USED FOR THAT PURPOSE. IF YOU HAVE PREVIOUSLY RECEIVED A DISCHARGE IN BANKRUPTCY AND THIS DEBT WAS NOT REAFFIRMED, THIS CORRESPONDENCE IS NOT AND SHOULD NOT BE CONSTRUED TO BE AN ATTEMPT TO COLLECT A DEBT, BUT ONLY ENFORCEMENT OF A LIEN AGAINST PROPERTY. ** FEDERMAN AND PHELAN Frank Federman, Esquire Identification No. 12248 One Penn Center Plaza at Suburban Station, Suite 1400 Philadelphia, PA 19103-1799 (215) 563-7000 ATTORNEY FOR PLAINTIFF BANK OF AMERICA, NA, F/K/A NATIONS BANK, NA Plaintiff vs. : COURT OF COMMON PLEAS : CIVIL DIVISION : CUMBERLAND COUNTY BARRY L. STEINOUR FELICIA F. STEINOUR :NO. 2001-2423 Defendant TO: FELICIA F. STEINOUR 20 FAIRFIELD STREET MOUNT HOLLY SPRINGS, PA17065 DATE OF NOTICE: MAY 18,2001 THIS FIRM IS A DEBT COLLECTOR ATTEMPTING TO COLLECT A DEBT. THIS NOTICE IS SENT TO YOU IN AN ATTEMPT TO COLLECT THE INDEBTEDNESS REFERRED TO HEREIN, AND ANY INFORMATION OBTAINED FROM YOU WILL BE USED FOR THAT PURPOSE. IF YOU HAVE PREVIOUSLY RECEIVED A DISCHARGE IN BANKRUPTCY, THIS CORRESPONDENCE IS NOT AND SHOULD NOT BE CONSTRUED TO BE AN ATTEMPT TO COLLECT A DEBT, BUT ONLY AS ENFORCEMENT OF LIEN AGAINST PROPERTY. IMPORTANT NOTICR You are in default because you have failed enter a written appearance personally or by attorney and file in writin~ with the court your defenses or objections to the claims set forth a~ainst you. Unless you act within ten (10) days from the date of this notice, a Judgment may be entered a~ainst you without a hearin~ 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, ~o to or telephone the followin~ office to find out where you can get legal help. CUMBERLAND COUNTY CUMBERLAND COUNTY BAR ASSOCIATION 2 LmERTY AVENUE CARLISLE, PA 17013 (717) 249-3166 Frank Federman, Esquire Attorney for Plaintiff FEDERMAN AND PHELAN, L.L.P. · Frank Federman, Esquire Identification No. 12248 One Penn Center Plaza at Suburban Station, Suite 1400 Philadelphia, PA 19103-1799 (215) 563-7000 ATTORNEY FOR PLAINTIFF BANK OF AMERICA, NA, F/K/A NATIONS BANK, NA : COURT OF COMMON PLEAS : CIVIL DIVISION VS. BARRY L. STEINOUR FELICIA F. STEINOUR : CUMBERLAND COUNTY :NO. 2001-2423 De f endant ( s ) TO: BARRY L. STEINOUR 20 FAIRFIELD STREET MOUNT HOLLY SPRINGS, PA17065 DATE OF NOTICE: MAY 18,2001 THIS FIRM IS A DEBT COLLECTOR ATTEMPTING TO COLLECT A DEBT. THIS NOTICE IS SENT TO YOU IN AN ATTEMPT TO COLLECT THE INDEBTEDNESS REFERRED TO HEREIN, AND ANY INFORMATION OBTAINED FROM YOU WILL BE USED FOR THAT PURPOSE. IF YOU HAVE PREVIOUSLY RECEIVED A DISCHARGE IN BANKRUPTCY, THIS CORRESPONDENCE IS NOT AND SHOULD NOT BE CONSTRUED TO BE AN ATTEMPT TO COLLECT A DEBT, BUT ONLY AS ENFORCEMENT OF LIEN AGAINST PROPERTY. IMPORTANT NOTICE You are in default because you have failed 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 CUMBERLAND COUNTY BAR ASSOCIATION 2 LIBERTY AVENUE CARLISLE, PA 17013 (717) 249-3166 Frank Federman, Esquire Attorney for Plaintiff SHERIFF' S RETURN - REGULAR "' C~SE NO' 2001-02423 P COMMONWEALTH OF PENNSYLVANIA- COUNTY OF CUMBERLAND BANK OF AMERICA N A VS STEINOUR BARRY L ET AL DAWN L. KELL , Sheriff or Deputy Sheriff of Cumberland County, Pennsylvania, who being duly sworn according to law, says, the within COMPLAINT - MORT FORE was served upon STEINOUR FELICIA F the DEFENDANT , at 1757-00 HOURS, on the 27th day of April , 2001 at 20 FAIRFIELD STREET MT HOLLY SPRINGS, PA 17065 by handing to FELICIA F. STEINOUR a true and attested copy of COMPLAINT - MORT FORE together with and at the same time directing Her attention to the contents thereof. Sheriff's Costs- Docketing 6.00 Servi ce .00 Affidavit .00 Surcharge 10.00 So Answers- R. Thomas Kline .00 16.00 04/30/2001 FRANK FEDERMAN Sworn and Subscribed to before me this day of By. Deputy Sheriff A.D. Prothonotary CASE NO- 2001-02423 p SHERIFF ' S RETURN _ REGULAR COMMONWEALTH OF PENNSYLVANIA. COUNTY OF CUMBERLAND BANK OF AMERICA N A VS STEINOUR BARRY L _ET AL DAWN L. KELL --. , Sheriff or Deputy Sheriff of Cumberland County, Pennsylvania, who being duly SWorn says, the within COMPLA___INT _ MORT FORE was served STEINOUR BARRY L ~ DEFENDANT , at 1757.00 HOURS, on the 27th day of April the at 2 0 FAIRFIELD S__TREET ~ MT HOLLY SPRINGS, PA 17065 ~ by' handing to - FELICIA F. STEINOUR WIFE a true and attested copy of COMPLAINT _ MORT FORE together with according to law, upon , 2001 and at the same time directing He~ attention to the contents thereof. Sheriff,s Costs. Docketing Service Affidavit Surcharge Sworn and Subscribed to before me this - _ day of A.D. So Answers. 18.00 3 72 "~'~'~ ~'~ · -,r ....,,,~,~ ~.~.~...,~r'..~-" ,,~,. . . oo Z0.00 ~- Thomas KZZne ~ ' .00 - o /so/aoo F~K FEDER~ By. ~-epu t y Sheriff thonotary FEDERMAN and PHELAN By: FRANK FEDERMAN /dentification No. 12248 One Penn Center at Suburban Station Suite 1400 Philadelphia, PA 19103-1814 BANK OF AMEI~CA, NA, F/K/A NATIONS BANK, NA VS. BARRY L. STEINOUR FELICIA F. STEINOUR Plaintiff Defendant(s) Attorney for Pla/nfiff ' CUMBERL~D COUNTY · Court of Common Pleas · CIVIL DIVISION · NO. 2001-2423 FRANK FEDERMAN, ESQUIRE, hereby verifies that he is attorney for the Plaintiff in the above-captioned matter, and that on information and belief, he has knowledge of the following facts, to wit: (a) that the defendant(s) is/are not in the Military or Naval Service of the United States or its Allies, or otherwise within the provisions of the Soldiers' and Sailors' Civil Relief Act of Congress of 1940, as amended (b) that defendant BARRY L. STEINOUR is over 18 years of age and resides at 20 FAIRFIELD STREET, MOUNT HOLLY SPRINGS, PA 17065. that defendant FELICIA F. STEINOUR is over 18 years of age, and resides at This statement is made subject to the penalties of 18 Pa. C.S. Section 4904 relating to unsworn falsification to authorities. Attorney for Plaintiff (Rule of Civil Procedure No. 236 - Revised) BANK OF AMERICA, NA, F/I~A NATIONS BANK, NA · CUMBERLAND COUNTY · Court of Common Pleas Plaintiff · · CIVIL DIVISION · NO. 2001-2423 Defendant(s) · VS. BARRY L. STEINOUR FELICIA F. STEINOUR Notice is given that a Judgment in the above captioned matter has been entered against you on / ' EPUTY If you have any questions concerning this matter, please contact: FRANK FEDE_RMAN ES UmE Attorney for Filing Party One Penn Center at Suburban Station Suite 1400 Philadelphia, PA 19103-1814 (215) 563-7000 **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 AND THIS DEBT WAS NOT REAFFIRMED, THIS IS NOT AND SHOULD NOT BE CONSTRUED TO BE AN ATTEMPT TO COLLECT A DEBT, BUT ONLY ENFORCEMENT OF A LIEN AGAINST PROPERTY. ** PRAECIPE FOR WR/T OF EXECUTION. (MORTGAGE FORECLOSURE) P.R.C.p. 3180-3183 BANK OF AMERICA, NA, F/K/A NATIONS BANK, NA v. Plaintiff, BARRy L. STEINOUR FELICIA F. STEINouR CUMBERLAND COUNTy No. 2001-2423 Defendant(s). : TO THE DIRECTOR OF THE OFFICE OF THE PROTHONOTARy: Issue wr/t of execution in the above matter: Amount Due Interest from 5/30/01 to 9/5/01 (per diem. $8.44) TOTAL $51,353.91 $827.29and Costs $52,181.20 ONE PENN CENTER at SUBURBAN STATION SUITE 1400 PHILADELPHIA, PA 19103 Attorney for Plaintiff Note: Please attach descr/ption °fproperty. No. beSng also known as par= of Lot No. ~ on a ~lam of lots b~ Surveyor, dated Octobe~ 25, 1975, and bearing drawSng No. 78A182 as follows:- northwestern side of Center Street (35.OO feet wide rtght-of-wa~ West, 156.50 feet to a railroad s~ike set on the northeastern st, of a 20.00 feet wide alley; thenc~ ex=ending along same, North ~ land mow o~ fomme~ly, of Lestem A. Sheaffem; =hence extending alo= same, NomCh 34 degrees 49' minutes East, 137.88 feet to an iron p~ sec on the southwestern's~de oE Fa~rE~eld Street. aEoresa~d, thence ex~end~n~ along I~he' oE same, Souc~ 55 degrees Ii m~nutes East, [04.00 EeeC to the E~rsC mentioned s~ake and piece o~ BEGINNING. ' County tm Deed Book "M", Vol. 33, Page G~antoms herein. framer amd Ch=fy1 A. July 27, 1988 and recorded in and for Cumberland ~9 gram ted amd conveyed Le~ Richardson, PREMISES ON' 20 FAIRFIELD STREET, MOUNT HOLLY SPRINGS, PA 17065 BEING Tax Parcel # 23-31-2187-48. ,..-TITLE TO SAID PREMISES IS VESTED IN Barry L. Steinour and Felicia F. Steinour, his wife'-' by Deed from Christoper C. Shughart and Wendy Lee Richardson dated 8/25/89, recorded 8/28/89, in Deed Book D-34, Page 212. BANK OF AMERICA, NA, FflGA NATIONS BANK, NA · Plaintiff, BARRY L. STEINOUR . FELICIA F. STEINOUR : Defendant(s). : CUMBERL~D coUNTy COURT OF COMMON PLEAS CIVIL DIVISION NO. 2001-2423 AFFIDAVIT PURSUANT TO RULE 3129 (Affidavit No. 1) , Plaintiff in the above action, by its attorney, FRANK FEDERMAN, 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 2_0 FAIRFIELD 1. Name and address of Owner(s) or reputed Owner(s)' NAME LAST KNOWN ADDRESS (If address cannot be reasonably ascertained, please so indicate.) BARRY L. STEINOUR 20 FAIRFIELD STREET MOUNT HOLLY SPRINGS, PA 17065 FELICIA F. STEINOUR 20 FAIRFIELD STREET MOUNT HOLLY SPRINGS, PA 17065 , Name and address of Defendant(s) in the judgment: NAME LAST KNOWN ADDRESS (If address cannot be reasonably ascertained, please so indicate.) ge Same as above Name and address of every judgment creditor whose judgment is a record lien on the real property to be sold: NAME LAST KNOWN ADDRESS (If address cannot be reasonably ascertained, please so indicate.) None , Name and address of the last recorded holder of every mortgage of record: NAME LAST KNOWN ADDRESS (If address cannot be reasonably ascertained, please so indicate.) UNION FEDERAL SAVINGS BANK 1631 SOUTH ATHERTON STREET STATE COLLEGE, PA 16804-0179 Name and address of every other person who has any record lien on the property: NAME LAST KNOWN ADDRESS (If address cannot be reasonably ascertained, please so indicate.) o None 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 LAST KNOWN ADDRESS (If address cannot be reasonably ascertained, please so indicate.) e None Name and address of every other person whom the plaintiff has knowledge who has any interest in the property, which may be affected by the sale: NAME LAST KNOWN ADDRESS (If address cannot be reasonably ascertained, please so indicate.) Tenant/Occupant 20 FAIRFIELD STREET MOUNT HOLLY SPRINGS, PA 17065 Domestic Relations of Cumberland County 13 North Hanover Street Carlisle, PA 17013 Commonwealth of Pennsylvania Department of Welfare PO Box 2675 Harrisburg, PA 17105 I verify that the statements made in this affidavit are tree 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. Sec. 4904 relating to unswom falsification to authorities. June 4, 2001 ~ DATE FRANK FEDERMAN, ESQUIRE Attorney for Plaintiff FEDERMAN and PH/~LAN By: FRANK F/~DERMAN Identification No. 12248 Suite 1400 One Penn Center at Suburban Station Philadelphia, PA 19103 (2 s) s .7000 ATTORNEy FOR PLAINTIFF BANK OF AM/~R/cA, NA, F/K/A NATIONs BANK, NA v. Plaintiff, BARRy L. STEINouR FELICIA F. STEINOUR Defendant(s). CUMB/~RLAND COUNTy COURT OF COMMON PLeAs CIV/L DIVISION NO. 2001-2423 FRANK FEDERMAN, ESQUIRE, hereby ver/fies that he is attorney for the Plaintiff in the ab°ye-captioned matter, anti that the premises are not subject to the provisions of Act 91 because it is: (X) an FHA mortgage ( ) non-owner OCcupied ( ) vacant () Act 91 procedures have been fulfilled This certification is made subject to the penalties of 18 Pa. C.S. Section 4904 relating to unsworn falsification to authorities. FED Attorney for Plaintiff BANK OF AMERICA, NA, F/K/A NATIONS BANK, Plaintiff, NA BARRy L. STEINOUR FELICIA F. STEINOUR Defendant(s). CUMBERLAND COUNTY No. 2001-2423 June 4, 2001 TO: BARRY L. STEINO~ FELICIA F. STEINOUR 20 FAIRFIELD STREET MOUNT HOLLY SPRINGS, PA 17065 **THIS FIRM IS A DEBT COLLECTOR ATTEMPT~G TO COLLECT A DEBT AND ANY 1NFO~TiON OBTAINED WILL BE USED FOR THAT PURPOSE. IF YOU HAVE PREVIOUSLY RECEIVED A DISCHARGE IN BANKRUPTCY AND THIS DEBT WAS NOT RE~F~ED' 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 20 FAIRFIELD STREETMOUNT HOLLY SPRINGS, PA 17065is scheduled to be sold at the Sheriff's Sale on SEPTEMBER 5, 2001 at 10:00 a.m. in thc Cumber/and County Courthouse, South Hanover Street, judgment obtained by B.__ANK O.F AME Carlisle, PA 17013, to enforce the court against you. If the Sheriff's sale is R/CA_ NA F/K/A NATIONS BAN NA (the mort a e Sheriff's Sale. Y 1 be rchst~d for tric DEr'r~,,-,.~:.-g ~g ¢) ,--~vtt~e,~ 5, 2001 NOTICE OF OWNER,S RIGHTS To prevent this Sheriff's Sale, you must take immediate action: 1. The sale will be cancelled if you pay to the mortgagee the back payments, late charges, costs and reasonable attorney's fees due. call: ~ To find out how much you must pay, you may 2. You may be able to stop thc sale by filing a petition asking thc Court to strike or open thc judgment, if thc judgment was improperly entered. You may also ask thc Court to postpone thc sale for good cause. 3. You may also be able to stop thc sale through other legal proceedings. You may need an attorney to assert your fights. The sooner you contact one, the more chance you will have of stopping the sale. (See notice on page two on how to obtain an attorney.) 1. If the Sheriffs Sale is not stopped, your property wil~be sold to the highest bidder. You may find out the price bid by calling f_215) 563-700~0. 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 (717) 240-6390. 4. If the mount due fi'om 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 fight to remain in the property until the full mount due is paid to the Sheriff and the Sher/ff gives a deed to the buyer. At that time, the buyer may br/ng legal proceedings to evict yotl. 6. You may be entitled to a share of the money which was paid for your house. A schedule of distribution of the money bid for your house will be filed by the Sheriff 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 w/thin ten (10) days after the distribution is filed. 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. Il* YOU DO NOT I-IA~ A LAWYER OR CANNOT AFFORD ONE, GO TO OR TELEPHONE THE OFFICE LISTED BELOW TO FIND OUT WHERE YOU CAN GET LEGAL HELP. CUMBERL~D COUNTY ATTORNEY RE~~ CUMBERL~D COUNTY BAR ASSOCIATION 2 LIBERTY AVENUE CUMBERLAND COUNTY COURTHOUSE CARLISLE, PA 17013 (717) 249-3166 (800) 990-9108 AI..~ th,ab cer~~ t~a~t o~ ~a~ BEGINNING a~ . · o. 7~A182, no~=hwes=~~ . (~5.00 . on oE ~h , West, ~ _d~ of Centep _ing stake an lght-of_wa . of 56150 f~e= to .Street, South d alon~ =he Y ) · a ~O.oo f ..... a ~allroad .e. - ~ SOuthwe - ._. _xnubes · O0 f o. sa ' mentioned stake and Place Coun=y in Deed Book "H", Vol. 33, Page Unto Ch~is=O~he G~anto~s h~ein. P~SES ON- 20 F~~~ S~, MO~ HO~ SP~NGS, B~NG Tax Cramer and Chary1 A. Le~ Richardson, Che PA 17065 · TITLE TO SAID PREN[ISES IS VESTED by Deed ~~%.~o .v ~bTED tN S~ t Stei /n Dc~ Bo-u n ~., ~er ~. Shugh~ and Wend~ Lc- ~:-- n~ur ~d Fei/cia F. S~cinour, his wife'-- ~ 2 l_. n da~ed 8/5/89, recorded 8/28/89, PLAINTIFF AglqOAVi~ O1~ SrltV~Cr I~A~K Olr A~ERICA, r~A, Ir/K/A nA~Or~S DEFENDANT(S) BARRY L. STEINO~ ""' FELICIA F. STEINOUR SERVE FELICIA F. STEINOUR AT 20 FAIRFIELD STREET MOUNT HOLLY SPRINGS, PA 17065 CUMBERLAND COUNTY No.2001-2423 Type of Action - Notice of Sheriff's Sale Sale Date: SEPTEMBER 5, 2001 Served and made known to , , ,- SERVED ' ~~ ,Defendant, on the_~_~ day of 200j at °7, oc', o,clock Fro., at .. . of Pennsylvania, in the manner descr/bed below: , Commonwealth ---~ Defendant personally served. _Adult family member with whom Defendant(s) reside(s). Relationsh/p is ----__Adult in charge ofDefendant(s),s residence who refused to give name or r~~' --------Manager/Clerk of place of lodging in which Defendant(s) res/de(s). -----__Agent or person in charge °fDefendant(s)'s office or usual place of business. ----___ Other: ------~ an officer of said Defendant(s),s company. Description: . .,~t . ~ ne~gnt ~ Weight ~ Ra,,~ true and correct copy of the N6tice ~f,~c, om~_eten_t adult, being duly swo · the address indicated above. ~ in the manner as senti a~c~°~d_m__.g to. law,.dep.ose and state that I personally handed o.,~ -*~cm, ~ssuea in the captioned case on the date and at Nolari~l Seal Swor~ to Stacy L Heefner Notary Public and subscribed before e this _(~ day ~ Boro, Franklin County My Commi~io~ ~of ~-~~, 20 ~ I Expir~u~. 5, 2ooe Nota ' 0~;/./~ On thc ...... day of ~, 200__, at-----------__ o'clock .__.rn., Defendant NOT FOUND because: --~-_ Moved -~ Unknown__~ No Answer Other: ~ Vacant Sworn to and subscribed before me th/s day of' ------ ~--___, 200 Notary: --' Frank Federman, Esquire. I.D. No. 12248 One Penn Center at Suburban Station 1617 John F. Kennedy Boulevard, Suite 1400 Philadelphia, PA 19103-1814 (215) 563-7000 By: PLAINTIFF DEFENDANT(S) AFFIDAVIT OF SERVICE BANK OF AMERICA, NA, F/K/A NATIONS BANK, NA BARRY L. STEINOUR FELICIA F. STEINOUR SERVE BARRY L. STE/NOUR AT 20 FAIRFIELD STREET MOUNT HOLLY SPRINGS, PA 17065 CUMBERLAND COUNTY No.2001-2423 Type of Action - Notice of Sheriff's Sale Sale Date: SEPTEMBER 5, 2001 SERVED Served and made known to ~~.', N o ~ ~ ., Defendant, on the_ / ~ 06~ day of - _,o'clock .m.,at ~O ' of Pe~sylva~a, h the ~~er described below: _, 200._[, _, Commonwealth ~_Defendant personally served. ~Adult family member with whom Defendant(s) reside(s). Relatiomhip is __~__Adult in charge of Defendant(s)'s residence who refused to give name or relationship. Manager/Clerk of place of lodging in which Defendant(s) reside(s). ~Agent or person in charge of Defendant(s)'s office or usual place of business. an officer of said Defendant(s)'s company. ~__ Other: a true and correct c that I personally handed the address indicated above, case on the date and at bSe~o°r~ ~°eat~idsS~ ;day of_t~{tL , t . . Notary: I'~ 2~ -~.,,; ~ ' '- v, NOT SERVED On the ~.._ day of _, 200.___, at_ o'clock _._.m., Defendant NOT FOUND because: ____._ Mewed ._____. Unknown_____. No Answer ~ Vacant Other: Sworn to and subscribed before me this_ _ day of _, 200 · Notary: '- By: ~Attorney for Plaintiff Frank Federman, Esquire - I.D. No. 12248 One Penn Center Suburban Station, Suite 1400 Philadelphia, PA 19103 (215) 563-7000 Bank of America, NA, f/k/a Nations Bank, NA VS Barry L. Steinour and Felicia F. Steinour In The Court of Common Pleas of Cumberland County, Pennsylvania Writ No. 2001-2423 Civil Term R. Thomas Kline, Sheriff, who being duly sworn according to/aw, states this writ is returned STAYED pursuant to instructions from Attorney Frank Federrnan. Sheriffs Costs: Docketing Surcharge 30.00 Posting Handbills 30.00 Law Library 15.00 Prothonotary .50 Share of Bills 1.00 Mileage 25.66 Levy 3.90 Advertising 15.00 Certified Mail 15.00 Poundage 2.29 Postpone Sale 15.85 Law Journal Patriot News 381.65 272.28 $808.13 paid by attorney 8/31/01 Sworn and subscribed to before me This_________ day of Prothonotary 2001, A.D. So Answers. R. Thomas Kline, Sheriff e e BANK OF AMERICA, NA, F/K/A NATIONS BANK, NA Plaintiff, V. BARRy L. STEINOUR FELICIA F. STEIN'OUR Defendant(s). CUMBERLAND COUNTy COURT OF COMMON PLEAS CI~L DMSION NO. 2001-2423 ' AFFIDAVIT PURSUIT TO RULE 3129 (Affidavit No. 1) BANK OF AMERICA. NA- F/K/A NATI attorney, , Plaintiff in the ab,, ...... ;- - .. ,~,-,~-m, sets tortn as of the date t .__,,*~ he Praec~pe for the Writ of Execution was filed the following information concerning the real property located at 20 FAIRFIELD 1. Name and address of Owner(s) or reputed Owner(s): NAME LAST KNOWN ADDRESS (/f address cannot be reasonably ascertained, please so indicate.) BARRY L. STEINOUR 20 FAIRFIELD STREET MOUNT HOLLY SPRINGS, PA 17065 FELICIA F. STEINOUR 20 FAIRFIELD STREET MOUNT HOLLY SPRINGS, PA 17065 Name and address of Defendant(s) in the judgment: NAME LAST KNOWN ADDRESS (/f address cannot be reasonably ascertained, p/ease so indicate.) Same as above Name and address of every judgment creditor whose judgment is a record lien on the real property to be sold: NAME LAST KNOWN ADDRESS (If address cannot be reasonably ascertained, please so indicate.) None , e Name and address of the last recorded holder of every mortgage of record' NAME LAST KNOWN ADDRESS (If address cannot be reasonably ascertained, please so indicate.) UNION FEDERAL SAVINGS BANK 1631 SOUTH ATHER~ON STREET STATE COLLEGE, PA 16804-0179 Name and address of every other person who has any record lien on the property: NAME LAST KNOWN ADDRESS (If address cannot be reasonably ascertained, please so indicate.) 0 None 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 LAST KNOWN ADDRESS (If address cannot be reasonably ascertained, please so indicate.) e None Name and address of every other person whom the plaintiff has knowledge who has any interest in the property, which may be affected by the sale: NAME LAST KNOWN ADDRESS (If address cannot be reasonably ascertained, please so indicate.) Tenant/Occupant 20 FAIRFIELD STREET MOUNT HOLLY SPRINGS, PA 17065 Domestic Relations of Cumberland County 13 North Hanover Street Carlisle, PA 17013 Commonwealth of Pennsylvania Department of Welfare PO Box 2675 Harrisburg, PA 17105 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 lB Pa. C.S. Sec. 4904 relating to unswom falsification to authorities. June4, 2001 ~y~ ¢~7.~/t.~__ ~ DATE FRANK FEDERMAN, ESQUIRE Attorney for Plaintiff BANK OF AMERICA, NA, FfI~A NATIONS BANK, NA : Plaintiff, : BARRY L. STEINOUR FELICIA F. STEINO~ Defendant(s). CUMBERLAND COUNTY No. 2001-2423 June 4, 2001 TO' BARleY L. STEINOUI~ FELICIA F. STEINOUP- 20 FAIRFIELD STREET MOUNT HOLLY SPR3NGS, PA 17065 **THIS FIRM IS A DEBT COLLECTOR ATTEMPTING TO COLLECT A DEBT AND ANY INFORMATION oBTAINED WILL BE USED FOP- THAT PURPOSE. IF YOU HAVE PREVIOUSLY RECEIVED A DISCHARGE IN BANKRUPTCY AND THIS DEBT WAS NOT REAFFIRMED, THIS IS NOT AND SHOULD NOT BE CONSTRUED TO BE AN ATrEMPT TO COLLECT A DEBT, BUT ONLY ENFORCEMENT OF A LIEN AGAINST PR. OPEP-TY.** Your house (real estate) at 20 FAIRFIELD STREETMOUNT HOLLY SPRINGS, PA 17065is scheduled to be sold at the Sheriffs Sale on SEPTEMBER 5, 2001 at 10:00 a.m. in the Cumberland County Courthouse, South Hanover Street, Carlisle, PA 17013, to enforce the court (the mortgagee) judgment obtained by against you. If the Sheriff's sale is postponed, the property will be relisted for the DECEMBER 5, 2001 Sheriff' s Sale. NOTICE OF OWNER'S RIGHTS YOU MAY BE ABLE TO PREVENT THIS SHERIFF'S SALE To prevent this Sheriffs Sale, you must take i_mmediate action~ 1. The sale will be cancelled if you pay to the mortgagee the back payments, late charges, costs and reasonable attorney's fees due. To find out how much you must pay, you may call: (215) 563-7000~.. 2. You may be able to stop the sale by filing a petition asking the Court to strike or open the judgment, if the judgment was improperly entered. You may also ask the Court to postpone the sale for good cause. 3. You may also be able to stop the sale through other legal proceedings. You may need an attomey to assert your fights. 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 ItAVE OTHER RIG}ITS EVEN IF TI-IE SI-IERIFF'S SAI~E DOES TAKE PLACE. 1. If the Sheriffs Sale is not stopped, your property will, be sold to the highest bidder. You may find out the price bid by calling (215) 563-7000. 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 (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 fight to remain in the property until the full amount due is paid to the Sheriff and the Sheriff gives a deed to the buyer. At that time, the buyer may bring legal proceedings to evict you. 6. You may be entitled to a share of the money which was paid for your house. A schedule of distribution of the money bid for your house will be filed by the Sheriff 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 distribution is filed. 7. You may also have other fights 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 WItERE YOU CAN GET LEGAL HELP. CUMBERLAND COUNTY ATTORNEY REFERRAL CUMBERLAND COUNTY BAR ASSOCIATION 2 LIBERTY AVENUE CUMBERLAND COUNTY COURTHOUSE CARLISLE, PA 17013 (717) 249-3166 (800) 990-9108 A~ tln~ certain tract o~ ~and ~,t:~ t~e ~mP~ovem~nts,~t~ereon Fal~ieZd Street .~th the northwestern side of Center S:ree~ Borough of Nt. Holly Springs, Cumberland County, Pennsylvania, being also known as part oE Lot No. 3 on a pIan of lots b7 Phillip A. and ~dith A. ~arner, recorded in Cu~berIand County Plan Book 4, Page 23, and being mo~e tully bounded and described accordance ~i~h a plan o5 survey by Stephen G. Fisher, West, 156.50 feet to a railroad spike set on the northeastern s~de land now o? fomme?ly, of Lestem A. Sheaffer; thence extending along BEGINNING. " BEING the same premises which Ricky L. Crane.-, his wife, by their deed dated In ~he Office of the Reco~dem of Deeds County ~n Deed Book'"M" Vol 33 Page and for Cumberland PREMISES ON' 20 FAIRFIELD STREET, MOUNT HOLLY SPRINGS, PA 17065 BEING Tax Parcel ,,* 23-31-2157-45. · TITLE TO SAID PREMISES IS VESTED IN Barry L. Steinour and Felicia F. Steinour, his wife"- by Deed from Christoper C. Shughart and Wendy Lee Richardson dated 8/25/89, recorded 8/28/89 in Deed Book D-34, Page 212. ' WRIT OF EXECUTION and/or ATTACHMENT ! ~ ; . : ; , . . COMMONWEALTH" OF PENNSYLVANIA) NO. 01-2423 CIVIL 1~D( TERM COUNTY OF CUMBERLAND) CIVIL ACTION - ~W TO THE SHERIFF OF O~nber!_and COUNTY' To satisfy the debt, interest and costs due Ba_nk of America, NA, F/K/A Nations Bank, NA PLAINTIFF(S) from Barry L. Steinour and Felicia F. Steinour, 20 Fairfield Street, Mount Holly Springs, PA 17065 DEFENDANT(S) (1) You are directed to levy upon the property of the defendant(s) and to sell See Legal Description (2) You are also directed to attach the property of the defendant(s) not levied upon in the possession of GARNISHEE(S) as follows' and to notify the garnishee(s~~ that' (a) an aitachment has been issued; (b) the garnishee(s) is/are enjoined from paying any debt to or lor the account of the defendant(s) and from delivering any property, of the def~n~da.nt.{s) or, pther~ise disposing -. ... thereol' (3) If property of the defendant(s) not levied upon an subject to attachment is found in the possession of anyone other than a named garnishee, you are directed to notify him/her that he/she has been added as a garnishee and is enjoined as above stated. Amount Due $51,353.91 L.L. from 5/30/01 to 9/5/01 Interest (~-,er di~'~-.. - $8 _- 44 ) $R27.29 and costs Due Prothy Atty's Corem % Other Costs Atty Paid $119 · 72 $,50 $~.00 Plaintiff Paid Date: June 8, 2001 REQUESTING PARTY' Name Address: Attorney for: Telephone: Curtis R. Prothonotary, Civil Division Frank Fede~man, Esq. One Penn Center at Sub_urban Station, Suite 1400 Philadelphia, PA 19103 Pla~_qtiff 215-563-7000 Supreme Coud ID No. 12248 REAL ESTATE SA. LE No, ~~ On- O~c,~~../~ ~ oo I the sheriff leviecl upon t~ Irllerest in the real property situated in ~__~~~.~ ~ County, Pa., known and numbered as:~O ~ a~'mo~ fully de~c. ribed on Exhibit "A" filed 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: Affiant further deposes that he is authorized to verify this statement by the Cumberland Law Journal, a legal periodical of general circulation, and that he is not interested in the subject matter of the aforesaid notice or advertisement, and that all allegations in the foregoing statements as to time, place and character of publication are true. REAL ES?&T2 ~ NO. 25 Writ No. 2001-2423 Civil Bank of America, NA, F/K/A Nations Bank, NA VS. Barry L. Steinotu- and Felicia F. Steinor Atty.- Frank Federman ALL that certain tract of land with the improvements thereon erected situate at the intersection of the southwestern side of Fairfield Street with the northwestern side of Cen- ter Street, Borough of Mt. Holly Springs, Cumberland County, Penn- sylvania, being also known as part of Lot No. 3 on a plan of lots by Phil- lin/~ and Edith A. Warner. recorded SWORN TO AND SUBSCRIBED before me this _ 3 _day of_ AUGUST, 2001 THE PATRIOT NEWS THESUNDAY PATRIOT NEWS Proof of Publication Under Act No. 587, Approved May 16, 1929 Commonwealth of Pennsylvania, County of Dauphin} ss James L. Clark being duly sworn according to law, deposes and says: That he is the Acounts Receivable Manager of The Patriot News Co., a corporation organized and existing under the laws of the Commonwealth of Pennsylvania, with its principal office and place of business at 812 to 818 Market Street, in the City of Harrisburg, County of Dauphin, State of Pennsylvania, owner and publisher of Patriot-New~ and~ 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 Sunda Patri - established March 4th, 1854, and September 18th, 1949_ rest,,-,.-,,.-, .......... Y ot News were ever since; , r- .... ,,=,y, =,u aH nave Peen continuously published 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 Volume 14, Page 317. Mis.~llaneous Book "M", PUBLICATION COPY ...................................... :~:,'..~ ..................... S~worn to and auhnnrih,ar~ _ ~ .... "'~r ...... ~ .......... S A L E #25 , - - .... :~'~n~' ;,'~st day 9YAu u. sC,E'001 A D i Nm~ sm / g · · I ~m4,burg, O.u~Pm County .. .. · .'. Idy Cernmilslon Ex, res june 6. ~~~~ ....... , ~ O-F/A R Y PUBLIC IVlember, Pennsylvania Assocation et Nelar~ commission expires June 6, 2002 ..:. CUMBERLAND COUNTY SHERIFFS OFFICE CUMBERLAND COUNTY COURTHOUSE CARLISLE, PA. 17013 Statement of Advertising Costs To THE PATRIOT-NEWS CO., Dr. For publishing the notice or publication attached hereto on the above stated dates $ 270 78 Probating same . Total Notary Fee(s) $ 1.50 $ 272.28 Publisher's Receipt for Advertising Cost The Patriot News Co., publisher of T___he Patriot-News~and ~_.i~..~[~y_~_~[l~[~., newspapers of general circulation, hereby acknowledge receipt of the aforesaid notice and publication costs and certifies that the same have been duly paid. IN THE COURT OF COMMON PLEAS OF CUMBERL~D COUNTY, PENNSYLVANIA BANK OF AMERICA, NA, F/K/A NATIONS BANK, NA 101 EAST MAIN STREET LOUISVILLE, KY 40232 VS. No.' 2001-2423 BARRY L. STE/NOUR FELICIA F. STEINO~ 20 FAIRFIELD STREET MOUNT HOLLY SPRINGS, PA 17065 TO THE PROTHONOTARY K/ndly mark the judgment that was entered in the above captioned matter on MAY 31, 2001 vacated upon payment of your costs only. Frank Federman, Esquire Attorney for Plaintiff August 31, 2001