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Home My WebLink About01-3054GOLDBECK McCAFFERTY & McKEEVER BY: Joseph A. Goldbeck, Jr. Attorney I.D.#16132 Suite 500 - The Bourse Bldg. 111 S. Independence Mall East Philadelphia, PA 19106 215-627-1322 Attorney for Plaintiff DOVENMUEHLE MORTGAGE CO. LP : IN THE COURT OF COMMON PLEAS 1501 Woodfield Road : Schaumburg, IL 60173-4982 : OF CUMBERLAND COUNTY Plaintiff : : CIVIL ACTION - LAW :ACTION OF MORTGAGE FORECLOSURE PAUL A. RHEAUME : (Mortgagor(s) and Real Owner(s)) :: No. Termo! 15 W. Factory Street : Mechanicsburg, PA 17055 : O~V~LACT~ON: MORTGAGE Defendant (s) : THIS LAW FII%M IS A DEBT COLLECTOR AND WE ARE ATTEMPTING TO COLLECT A DEBT OWED TO OUR CLIENT. ANY INFORMATION OBTAINED FROM YOU WILL BE USED FOR THE PURPOSE OF COLLECTIN~ THE DEBT. NOTICE COMPLAINT IN MORTGAGE FORECLOSURE 1. Plaintiff is DOVENMUEHLE MORTGAGE CO. LP, 1501 Woodfield Road, Schaumburg, IL 60173-4982. 2. The name(s) and address(es) of the Defendant(s) is/are PAUL A. RHEAUME, 15 W. Factory Street, Mechanicsburg, PA 17055, who is/are the mortgagor(s) and real owner(s) of the mortgaged property hereinafter described. 3. On April 21, 1994, mortgagor(s) made, executed and delivered a mortgage upon the premises hereinafter described to GMAC MORTGAGE CORP. OF PA, which mortgage is recorded in the Office of the Recorder of Deeds of Cumberland County in Mortgage Book 1209, Page 646. By Assignment of Mortgage recorded February 9, 1995, the mortgage was assigned to Plaintiff, which Assignment is recorded in Assignment of Mortgage Book No. 1474, Page 37. These documents are matters of public record and are incorporated herein by reference in accordance with Pennsylvania Rule of Civil Procedure 1019(g). 4. The premises subject to said mortgage is described as attached. 5. The mortgage is in default because monthly payments of principal and interest upon said mortgage due February 1, 2001, and each month thereafter are due and unpaid, and by the terms of said mortgage, upon default in such payments for a period of one month, the entire principal balance and all interest due thereon are collectible forthwith. 6. The following amounts are due on the mortgage: Principal Balance $ 58,958.21 Interest from 1/ 1/01 through 5/31/01 at 8.000% 1,938.00 Per diem interest rate at $12.92 Attorney's Fee at 5% of Principal Balance 2,947.91 Late Charges 2/ 1/01- 5/31/01 164.80 Monthly late charge amount at $41.20 Costs of suit and Title Search 560.00 $ 64,568.92 Escrow Balance Monthly Escrow amount $357.72 $ 64,568.92 7. The Attorney's Fees set forth above are in conformity with the Mortgage documents and Pennsylvania law, and, will be collected in the event of a third party purchaser at Sheriff's Sale. If the Mortgage is reinstated prior to the Sale reasonable Attorney's Fees will be charged based on work actually performed. 8. Notice of Intention to Foreclose and a Notice of Homeowners' Emergency Mortgage Assistance has been sent to Defendant(s) by Certified and regular mail, as required byAct 160 of 1998 of the Commonwealth of Pennsylvania, on the date(s) set forth in the true and correct copy of such notice(s) attached hereto as Exhibit "A". The Defendant(s) has/have not had the required face to face meeting within the required time and Plaintiff has no knowledge of any such meeting being requested by the Defendant(s) through the Plaintiff, the Pennsylvania Housing Finance Agency, or any appropriate Consumer Credit Counseling Agency. WHEREFORE, Plaintiff demands judgment in mortgage foreclosure the sum of $64,568.92, together with interest at the rate of $12.92, per day and other expenses incurred by the Plaintiff which are properly chargeable in accordance with the terms of the mortgage, and for the forecl?~e and sale of the mortgaged premises. /'~ / ~ /? GOLD~ECK Mc~%FFER~Yv& MCKEEVER BY:/Uoseph A. Goldbeck, Jr., Esq. Att6rney for Plaintiff VERWICATION I, Lynn Coady, as the representative of the Plaintiff corporation within named do hereby verify that I am authorized to and do make this verification on behalf of the Plainfiffcorporat/on and the facts set forth in the foregoing Complaint are true and correct to the best of my knowledge, information and belief. I understand that false statements therein are made subject to the penalties of 18 Pa. C.S. 4904 relating to unswom falsification to authorities. '~Lynn Coad~- ' x.x...~'-~ Dovenmuehle Mortgage, Inc. 200, EXHIBIT A (t) TOTKI, AI~OUNT OF (a) (b) (c) (d) and (e) Agency. Db142 SHERIFF'S RETURN - NOT FOUND CASE NO: 2001-03054 P COMMONWEALTH OF PENNSYLVANIA COUNTY OF CUMBERLAND DOVENMUEHLE MORTGAGE CO LP VS RHEAUME PAUL A R. Thomas Kline ,Sheriff or Deputy Sheriff, who being duly sworn according to law, says, that he made a diligent search and inquiry for the within named defendant, DEFENDANT RHEAUME PAI/L A but was unable to locate Him in his bailiwick. He therefore returns the COMPLAINT - MORT FORE , , NOT FOUND , as to the within named DEFENDANT , RHEAUME PAUL A ADDRESS IS VALID, BUT UNABLE TO LOCATE DEFT PRIOR TO EXPIRATION. EXPIRED 6/15/01 Sheriff'sNot Found Costs: 5.00 ~ Docketing 18.00 Service 12.40 ~ ~ if of Cumberland County Surcharge 10.00.00 ~ ~ ~e~ ~uncy 45.40 GOLDB F R V 06/22/2001 Sworn and subscribed to before me this ~ day of ~__ honorary " IS A Tf~UE/.... -c.~C FCOP¥ GOLDBECK McCAFFERTY & McKEEVER OFT':~, . BY: Joseph A. Goldbeck, Jr. Attorney I.D.#16132 Suite 500 - The Bourse Bldg. 111 S. Independence Mall East Philadelphia, PA 19106 215-627-1322 Attorney for Plaintiff DOVENMUEHLE MORTGAGE CO. LP : IN THE COURT OF COMMON PLEAS 1501 Woodfield Road : Schaumburg, IL 60173-4982 : OF CUMBERLAND COUNTY Plaintiff : : CIVIL ACTION - LAW VS. : :ACTION OF MORTGAGE FORECLOSURE PAUL A. RHEAUME : (Mortgagor(s) and Real Owner(s)) : Term 15 W. Factory Street : Mechanicsburg, PA 17055 : GIVILACTION: MORTGAGE Defendant (s) : FORECLOSURE THIS LAW FIRM IS A DEBT COLLECTOR AND WE A~E ATTEMi=TINQ TO COLLECT A DEBT OWED TO O~R CLIENT. ANY INFOHNATION OBTAINED FROM YOU WILL BE USED FOR THE PD~RPOSE OF COLLECTING THE DEBT. NOTICE ~ ~.~, ^v..... ~.~.~., ,,, TRUE COPY FROM RECORD In T~#llimo~ wi~'~l~ '" · , :~. ~ ~mo m,~ my hind --,~T,CV THAT THIS II'tEREB'/'- . · · F5 ATRUE ;~'" .' ,;.~RSCT COPY OF '[" '~ ' ' ' ":..',t. [ ..... D COMPLAINT IN MORTGAGE FORECLOSURE 1. Plaintiff is DOVENMUEHLE MORTGAGE CO. LP, 1501 Woodfield Road, Schaumburg, IL 60173-4982. 2. The name(s) and address(es) of the Defendant(s) is/are PAUL A. RHEAUME, 15 W. Factory Street, Mechanicsburg, PA 17055, who is/are the mortgagor(s) and real owner(s) of the mortgaged property hereinafter described. 3. On April 21, 1994, mortgagor(s) made, executed and delivered a mortgage upon the premises hereinafter described to GMAC MORTGAGE CORP. OF PA, which mortgage is recorded in the Office of the Recorder of Deeds of Cumberland County in Mortgage Book 1209, Page 646. By Assignment of Mortgage recorded February 9, 1995, the mortgage was assigned to Plaintiff, which Assignment is recorded in Assignment of Mortgage Book No. 1474, Page 37. These documents are matters of public record and are incorporated herein by reference in accordance with Pennsylvania Rule of Civil Procedure 1019(g). 4. The premises subject to said mortgage is described as attached. 5. The mortgage is in default because monthly payments of principal and interest upon said mortgage due February 1, 2001, and each month thereafter are due and unpaid, and by the terms of said mortgage, upon default in such payments for a period of one month, the entire principal balance and all interest due thereon are collectible forthwith. 6. The following amounts are due on the mortgage: Principal Balance $ 58,958.21 Interest from 1/ 1/01 through 5/31/01 at 8.000% 1,938.00 Per diem interest rate at $12.92 Attorney's Fee at 5% of Principal Balance 2,947.91 Late Charges 2/ 1/01- 5/31/01 164.80 Monthly late charge amount at $41.20 Costs of suit and Title Search 560.00 $ 64,568.92 Escrow Balance Monthly Escrow amount $357.72 $ 64,568.92 7. The Attorney's Fees set forth above are in conformity with the Mortgage documents and Pennsylvania law, and, will be collected in the event of a third party purchaser at Sheriff's Sale. If the Mortgage is reinstated prior to the Sale reasonable Attorney's Fees will be charged based on work actually performed. 8. Notice of Intention to Foreclose and a Notice of Homeowners' Emergency Mortgage Assistance has been sent to Defendant(s) by Certified and regular mail, as required by Act 160 of 1998 of the Commonwealth of Pennsylvania, on the date(s) set forth in the true and correct copy of such notice(s) attached hereto as Exhibit "A". The Defendant(s) has/have not had the required face to face meeting within the required time and Plaintiff has no knowledge of any such meeting being requested by the Defendant(s) through the Plaintiff, the Pennsylvania Housing Finance Agency, or any appropriate Consumer Credit Counseling Agency. WHEREFORE, Plaintiff demands judgment in mortgage foreclosure the sum of $64,568.92, together with interest at the rate of $12.92, per day and other expenses incurred by the Plaintiff which are properly chargeable in accordance with the terms of the mortgage, and for the forecl~u~e and sale of the mortgaged BY:/Uoseph A. Goldbeck, Jr., Esq. AttOrney for Plaintiff VERIFICATION I, Lynn Coady, as the representative of the Plaintiff corporation within named do hereby verify that I am authorized to and do make this verification on behalf of the Plaintiff corporation and the facts set forth in the foregoing Complaint are txue and correct to the best of my knowledge, information and belief. I understand that false statements therein are made subject to the penalties of i 8 Pa. C.S. 4904 relating to unswom falsification to authorities. Dovenmuehle Mortgage, Inc. EXHIBIT A Dh140 (f) TOTAI~ AMOUNT OF (a) (b) (c) (d) and (e) /v:jency. DL14R 0 At to~'~ey T.D.#1~132 Shire 500-"~ne Bourse ~'ilding 111 S. Independence ~.11 East Philadelphla, PA 19106 215-627-1322 BY: MICHAEL T. MCKE~VBR, ESQUIRE Attorney I.D. #56129 Attorney for Plaintiff ~UK.~.R MORTC4t~E CO. LP : IN 'r~ COURT OF C0~40N P~.R~S 1501 Woodfield Road .- Schaumburg, IL 60173-4982 : OF CUMBERLAND COQNTY : vs : NO. 01-3054 Civil Term : PAUL A. RHEAU~E : (Mortgagor and Real Owner) : 15 W. Factory Street : Mecb~-icsburg, PA 17055 : ,,o., this of OOl. upon consideration of the Plaintiff' s Notion for Substituted Service --~er Pa.R.C.P. 430(a) and it appearing to the Court that Plaintiff's good faith efforts to ascertain the present whereabouts of Defendant has been unsuccessful, it is, ORD~U~ and DECREED: that Plaintiff's Notion is granted and the Sheriff and/or Plaintiff is directed to Serve the Co~plaint in Mortgage Foreclosure upon Defendant by posting a copy of the Co~plaint upon1 the premises 15 W. Factory Street, Me~-hs-icsbur~, PA 17055 and Plaintiff is directed to serve the Coe~laint by certified and regular mail to the Defendant's last known address of 15 W. Factor~ Street, Mechanicsbur~, PA 17055 and that all further service of lt4~al l~rs, including l~t not lim~tt~l to ~tions, ~titions ~ rules be made by certified and regular mail to Defendant's last k-own address and that Notice of Sheriff Sale pursuant to Pennsylvania Rule of Civil Procedure 3129 may be made upon Defendants by sending copies of same to Defendant's last known address by certified and regular mail and by posting the premises. GOLDB~CK MCCAF~TY & ~C~EVBR JOSEPH A. GOLDBECK, JR. Attorney I.D.#16132 Suite 500-The Bourse Building 111 S. Independence Mall East Philadelphia, PA 19106 215-627-1322 BY: MICHaeL T. ~us~EVER, ESQUIRE Attorney I.D. #56129 Attorney for Plaintiff DO~u~HLE MORTC~AGE CO. LP : IN -r~ COURT OF C0~40~ PLEAS 1501 Woodfield Road : Schaumbur~, IL 60173-4982 : OF ~uMB~RLAND vs : No. 01-3054 Civil Tea PAUL A. ~g~UM~ : (~ortga~or and Real Owner) : 15 W. Factory Street : Machanicsburg, PA 17055 THIS ~ F]~ TS A ~ C]OT.T.~ ~ J~ ~ ATT~Fi~&~ TO ~ION ~R S~TI~ ~ PA.R.C.P. 4~0~a) Plaintiff, ~ ~ thr~h its atto~, Mic~el T. McKe~r, Es~i~, in eu~ of its ~tion for S~stitut~ Se~ice, ~pres~ts as roll,s: 1. Plaintiff is the holder of a first ~rtgage u~ the pr~ses 15 W. Facto~ Steer, Mec~ics~, PA 17055, ~]-~ter, the ~ga~ pr~ses-. 2. ~fen~t, PA~ A. ~, is the ~rt~agor ~ ~ ~er of the ~rtgag~ pr~ses. 3. ~ las~ ~ a~ss of ~f~t is 15 W. Facto~ Steer, ~c~nic~, PA 17055 as set fo~h in Para~aph 2 of the C~laint. 4. The Sheriff has been -~=hle to effect service of the Complaint upon Defendant at his last known address after numerous atteu~ts. 5. The following investigation was conducted in a good faith attempt to ascertain the whereabouts of Defendant. ~H~-~FOP~, Plaintiff prays that the Court enter the attached order allowing Plaintiff to serve the Coe~laint upon Defe,~nt by posting the premises and certified and regular mail to the Defendant's last known address. BY: ~RI~ ~OLDBECK MCCAFFERTY & JOSEPH A. ~OLDBECK, Attorney I.D.#16132 Suite 500-The Bourse Building 111 S. I~ependence Mall East Philadell)hia, PA 19106 215-627-1322 BY: MICHAEL T. MCAJ~Ev~, ESQUI~ Attorney I.D. #56129 Attorney for Plaintiff DOV~N~VKH,.R MORTC, A~E CO. LP : IN '~'~t~ COURT OF C0l~q0N PLEAS 1501 Woodfield Road : Sc~, IL 60173-4982 : 0F ~~ ~ vs : No. 01-3054 Civil Tem PA~ A. ~ : (~gagor ~d Real ~er) : 15 W. Facto~ Steer : ~chn-[c~, PA 17055 : I, MICH~J~L T. Mu~EVEH, ESQUIRE, Attorney for Petitioner do hereby verify that the facts set forth in the foregoing Motion for Substituted Service are true and correct to the best of my knowledge, information and belief. I up~erstand that false statements therein are made subject to the penalties of 18 Pa. C.S. 4904 relating to unsworn falsification to authorities. BIw: MI(~ ~. Mu~EV~H, ESQUIRE GOLDB~CK HCCAFF~TY & MCEBEvm~ JOSEPH A. GOLDBECK, JR. Attorney I.D.#16132 Suite 500-The Bourse Building 111 S. I~epe~ence Mall East Philadelphia, PA 19106 215-627-1322 BY: MIC~aRr. T. HCK~,cv~r., ESQ~I~ Attorney I.D. #56129 Attorney for Plaintiff DOV~E~V~m.R MOHTC~a/~E CO. LP : IN TH~ CO~T OF ~N 1501 Wo(x]field R~d : Sc~, IL 60173-4982 : OF va : No. 01-3054 Civil PA~ A. ~ : (Mortgagor ~ ~eal ~r) : 15 W. Facto~ St~t : Mec~ics~, PA 17055 : CEHTIFICAT~ OF S~HVI~ MIDOL T. ~A~V=K, Esquire, do hereby certify that true and collect copies of the the foregoing Notion for Substituted Service have been served upon the Def~-~-~t this 16 day of July, 2001, by first class mail, postage pre~aid. BY. MICHAEL T. ~OLDBECK MCCAF~KTY & Me,EVER JOSEPH A. GOLDBECK, JR. Attorney I.D.#16132 Suite 500-The Bourse Building 111 S. Independence Mall East Philadelphia, PA 19106 215-627-1322 BY: MICHaeL T. MC~EVER, ESQUIRE Attorney I.D. #56129 Attorney for Plaintiff DOV~u~m.e MORTC~R CO. LP : IN TH~ COURT OF C0~)N PLEAS 1501 Woodfield Road : Sc~, IL 60173-4982 : 0F cu~ ~ ~ : No. 01-3054 C~vil ~m : PA~ A. ~ : (Mortga~r ~ R~I ~er) : 15 W. Facto~ St~t Mec~cs~, PA 17055 : M~ORAI~]M OF LAW IN -~PPORT OF MOT!O~ FOR SUB~TZ-~-u-£~o SERVIC~ T~ Pa.R.C.P. 430(a} PZaintiff has filed a Coe~lalnt ~n Mortgage Foreclosure against Defendant which the Sheriff has been unable to personally serve upon Defendant. As noted in the attached Motion, Plaintiff has made a good faith attempt to ascertain Defe~-t's whereabouts without success. Accordingly, the Court may approve alternative means of service. See Pa.R.C.P. 430(a). For reasons stated above and in the attached Notion, the Court should enter an order allowing Plaintiff to serve the C~laint in Mortgage Foreclosure u~on Defendant by postin~ the premises and certified mail and recjular mall to the Defeudant's last known a~dress. Respectfully submitted, PLAYERS NATIONAL LOCATOR AFFIDAVIT OF GOOD FAITH INVESTIGATION Loan Number: DOV-0001 Attorney Firm: GOLDBECK, MCCAFFERTY & MCKEEVER Casa Number: Subject: PAUL A RHEAUME A.K.A.: None Property Address: 15 W. FACTORY STREET MECHANICSBURG, PA 17055 Last Known Address: 15 W. FACTORY STREET MECHANICSBURG, PA 17055 Last Known Number: (717) 760-7573 Michael K Gross, being duly sworn according to law, deposes and says: 1. I am employed in the capacity of President for Players National Locator. 2. On 05/24/2001, I conducted an investigation into the whereabouts of the above named defendant(s). The results of my investigation are as follows: CREDIT INFORMATION - A. SOCIAL SECURITY NUMBER: - - B. EMPLOYMENT SEARCH: Unable to locate a good employer for Paul. C. INQUIRY OF CREDITORS: The creditors Indloated that Paul fe living at 15 W Factory Street, Mechanloaburg, Pa. 17055 with a home phone number of 717-766-7073. INQUIRY OF TELEPHONE COMPANY - A. DIRECTORY ASSISTANCE SEARCH: The home phone number for Paul Rheaume la 717~766-7573 registered at 15 W Factory 8treat, Mechenicaburg, Pa. 17055. Called the home number and spoke with Paul who confirmed he fe living at this address. INQUIRY OF NEIGHBORS - N/A INQUIRY OF POST OFFICE - A. NATIONAL ADDRESS UPDATE: Aa of May 21, 2001 the National Change of Addrsae (NCOA) has no change for Paul from last known address. MOTOR VEHICLE REGISTRATION - A. MOTOR VEHICLE & DMV OFFICE: The Pennaylvanla Department of Drivers Llcenalng has Paul lieted at lsat known addrsae. OTHER INQUIRIES - A. DEATH RECORDS: Aa of May 21, 2001 the 8oclal Security Adminlatration has no death record on file for Paul A Rhasume under hie social ascurity number. B. PUBLIC LICENSES ( PILOT, REAL ESTATE. ETC. ): · Nons Found . C. COUNTY VOTER REGISTRATION: The Cumberland County Voters Registration Office haa Paul Iiated at last known addmms. OTHER SEARCHES - Social aecurlty number provided was verlflsd. ADDITIONAL INFORMATION ON SUBJECT- A. DATE OF BIRTH: 12/6t ~ Krisline M. Scott, Notary Public Sa ' dand om to be m eo 5/24 . ~nE~xpi~ [/ Players National Locator 113 01d State Road, Suite 104 St. Louis, MO 63021 --v Phone: (636) 230-9922 Fax: (636) 230-0556 ~UL 1~ 2001 I~:50 FR CUMBERLPJ~D CO SHERIFF?l? 240 F::,3~? Ta 9121562??'?'34 P.02/02 C. AS~ ~O: ~001-030S4 iD CODN'I~ O~' L-"UN~EI:tY.~D DOVENMUEHLE MORTGAGE CO LP VS RHEAUME ..PAUL A R. Thomas Kline ,Sheriff or Deputy Sheriff, who'being duly sworn according to law, says, that he made a diligent search and inquiry for the within named defendant, DEFENDANT ~HEAUME PAUL A hu= was unable to locate Him in his bailiwick. He therefore returns the COMPLAINT - MORT FORE , , NOT FOUND , as to the within named D~FENDANT , P, HEAUME PAUL A ADDRESS IS __VALID, BUT UNABLE TO LOCATE DEFT PRIOR TO EXPIRATION. EXPIRED 6/15/01 Sheriff's Costs: Docketing 18.00 Service 12.40 tot Pound Surcharge 10.00 ~he~i~f o~ Cumberland County .00 4~.40 C4DLDBECK MCCAFFERTY & MCKEEVER Sworn and subscribed to before me ~-his day of A.D. Prothonotary · :~ TOTAL PP,~E.I~?. ** 07/11/2001 WED 12:27 [TX/R][ NO 6952] (~002 GOLDBECK McCAFFERTY & McKEEVER BY: Joseph A. Goldbeck, Jr. Attorney I.D.#16132 Suite 500 - The Bourse Bldg. 111 S. Independence Mall East Philadelphia, PA 19106 215-627-1322 Attorney for Plaintiff DOVENMUEHLE MORTGAGE CO. LP : IN THE COURT OF COMMON PLEAS 1501 Woodfield Road : Schaumburg, IL 60173-4982 : OF CUMBERLAIqD COUNTY Plaintiff : CIVIL ACTION - LAW VS. : :ACTION OF MORTGAGE FORECLOSURE PAUL A. P~HEAUME (Mortgagor(s) : and Record Owner(s)) : Term 15 W. Factory Street : No. 01-3054 (Civil Term) Mechanicsburg, PA 17055 : Defendant(s) PRAECIPE TO REINSTATE COMPLAINT Kindly reinstate the Complaint in the above captioned matter. GOLDBECK MCCAFFERTY & MCKEEVER BY: ~~, Jose Jr. Joseph A. Goldbeck, Jr. Attorney I.D.#16132 Suite 500 - The Bourse Bldg. 111 S. Independence Mall East Philadelphia, PA 19106 215-627-1322 Attorney for Plaintiff DOVENMUEHLE MORTGAGE CO. LP : IN THE COURT OF COMMON PLEAS 1501 Woodfield Road : Schaumburg, IL 60173-4982 : OF CUMBERLAND COUNTY : Term PAUL A. RHEAUME (Mortgagor(s) : No. 01-3054 (Civil Term) and Record Owner(s)) : 15 W. Factory Street : Mechanicsburg, PA 17055 : CERTIFICATE OF SERVI~ JOSEPH A. GOLDBECK, JR. ESQUIRE hereby certifies that on August 10, 2001 he did serve upon Defendant(s) PAUL A. P, HEAUME a true and correct copy of the above-captioned Complaint by certified and regular mail in accordance with the Court Order dated July 23, 2001. The undersigned understands that the statements herein and subject to the penalties provided by 18 P.S. Section 4904. Respectf~~d, JOSEPH A. GOLDBECK, JR. ESQUIRE SHERIFF'S RETURN - REGULAR CASE NO: 2001-03054 p COMMONWEALTH OF PENNSYLVANIA: COUNTY OF CUMBERLAND DOVENMUEHLE MORTGAGE CO LP VS RHEAUME PAUL A BRIAN BARRICK , Sheriff or Deputy Sheriff of Cumberland County, Pennsylvania, who being duly sworn according to law, says, the within COMPLAINT - MORT FORE was served upon PJ{EAUME PAUL A the DEFENDANT , at 2112:00 HOURS, on the 8th day of August , .2001 at 15 W FACTORY ST MECHANICSBURG, PA 17055 by handing to PROPERTY POSTED AT 15 W FACTORY ST MECHANICSBURG a true and attested copy of COMPLAINT - MORT FORE together with and at the same time directing ~is attention to the contents thereof. Sheriff,s Costs: So Answers: Docketing 18.00 Service 5.85 Posting 6.00 Surcharge 10.00 R. Thomas Kline .00 39.85 08/09/2001 GOLDBECK MCCAFFERTY & MCKEEVER Sworn and Subscribed to before By: me this /J~ day of Deputy Sheriff ~..o~,~ ~oO! A.D. P~othonotary' in the Court of Common Pleas of Cumberland County DOVENMUEHLE MORTGAGE CO. LP 1501 Woodfield Road Schaumburg. 1L 60173-4082 Plaintiff PAUL A. RHEAUME (Mortgagor(s) and Record Owner(s)) 15 W. Factory Street No. 01-3054 Civil Term Mechanicsburg. PA 17055 Defendant(s} PRAECIPE FOR JUDGMENT 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. Enter tile .ludgment in favor of Plaintiff and against PAUL A. RHEAUME by default for want of an Answer. Assess damages as follows: $77,101.56 Debt htterest - 01/01/2001 to 09/19/2002 Total (Assessment of Damages attached) I CERTIFY THAT FOREGOING ASSESSMENT OF DAMAGES IS FOR SPECIFIED AMOUNTS ALLEGED TO BE DUE IN THE COMPLAINT AND IS CALCULABLE AS A SUM CERTAIN FROM THE COMPLAINT. I ceftin' thai written nolice of the intention to file this praecipe was mailed or delivered to the party against whom judgment is to be entered and to his attorney of record, if any, after the default occurred and at least ten days prior to the date of the filing of this praecipe. A copy of the notice is attached. R.C.P. 237.1 /~ ~ Joseph A. Go~l~ck,~r./ Attorney for I~l~ntit-q ] I.D. #16132 v ~/ AN D NOW °'~--~ ~ '~,~o~t~ , Judgment is entered in favor of DOVENMUEHLE MORTGAGE CO. LP and against PAUL A.~tEAUME by default for want of an Answer and damages assessed in tile sum nf $77,101.56 as per the above certification. Prothonotary /,z~~ GOLDBECK McCAFFERTY & McKEEVER BY: Joseph A. Goldbeck, Jr. Attorney I.D. #16132 Suite 500 - The Bourse Bldg. I 11 S. Independence Mall East Philadelphia, PA 19106 215-627-1322 Attorney tbr Plaintiff' DOVENMUEHLE MORTGAGE CO. LP 1501 Woodfield Road IN THE COURT OF COMMON PLEAS Schaumburg, 1L 60173-4982 Plaintiff of Cumberland County VS. PAUL A. RHEAUME CIVIL ACTION LAW (Mortgagor(s) and Record owner(s)) 15 W. Factor), Streel Mechanicsburg, PA 17055 ACTION OF MORTGAGE FORECLOSURE Defendant(s) No. 01-3054 CivilTerm ORDER FOR JUDGMENT Please enter Judgment in favor of DOVENMUEHLE MORTGAGE CO. LP, and against PAUL A. RHEAUME for failure to file an Answer in the above action within (20) days (or sixty (60) days if defendant is the United States of America) from the date of service of the Complaint, in the sum of $77,101.56. I hereby cerlify that the above names are correct and that the precise residence address of the judgraent creditor is DOVENMUEHLE MORTGAGE CO. LP 1501 Woodfield Road Schaumburg. IL 60173-4982 and that the name(s) and last known address(es) of the Defendant(s) is/are PAUL A. RHEAUME, 15 W. Factory Street Mechanicsburg, PA 17055: GOLDBECK ?,TY & McKEEVER BY: Joseph A. ~ldbe~ Jr. Attorney for Pla'lhtiff \ ASSESSMENT OF DAMAGES TO TH E PROTHONOTARY: Kindly assess the damages in this ease to be as follows: Principal Balance $58,958.21 h'Llerest from 01/01/2001 through $8,087.92 0~) ~ ] q ~2002 Attorney's Fee at 5.0000% of principal $2,947.91 balance I..a[e ('harges $824.00 Costs of Suit and Title Search $560.00 Escrow Balance Deficit $5.723.52 ($o.oo) $77,101.56 GOLDBECK M~qAFF: FY & McKEEVER BY: Joseph A. (~dbecl Attorney for Plai'dtiff AND NOW. this 093 day of ~ ,2002 damages are assessed as above. Pro Prothy VERIFICATION OF NON-MILITARY SERVICE The undersigned, as the representative for the Plaintiff corporation within named do hereby verify that I am authorized to make this verification on behalf of the Plaintiff corporation and that the facts set forth in the foregoing verification of Non- Military Service are true and correct to the best of my knowledge, information and belief. I understand that false statements therein are made subject to penalties of 18 Pa. C.S. 4904 relating to unsworn falsification to authorities. 1. That the above named Defendant, PAUL A. RHEAUME, is about unknown years of age, that Defendant's last known residence is 15 W. Factory Street, Mechanicsburg, PA 17055, and is engaged in the unknown business located at unknown address. 2. That Defendant is not in the Military or Naval Service of the United States or its Allies, or otherwise within the provisions of the Soldiers' and Sailors' Civil Relief Action of Date:Congress of 1940 and its Amendments. ~ / ~ TO: PAUL A. RHEAUME 15 W. Factory Street Mechanicsburg, PA 17055 DOv~NMUEHLE MORTGAOE CO. LP 1501 Woodfleld Road : IN THE COURT OF CO~ON PLEAS Schau~burg, IL 60173-4982 : Plaintiff : OF CUMBERLAND PAUL A. PJ{EAUME (Mortgagor(s)) : CIVIL ACTION - LAW (Record Owner(s)) : 15 W. Factory Street : ACTION OF MORTC4%OE FORECLOSURB Mechanicsburg, PA 17055 : Defendant(s) : Term : No. 01-3054 (Civil Term) : THIS LAW Fi~M IS A DBBT COLLECTOR AND W~ AR~ ATT~PTIN~ TO COLLECT A DEBT OWED TOO~IRCLIENT. ANY IN~O~TIONOBTAIN~DFROMYO~WILL BE USeD FOR TH~ P~POSE OF COLLECTIN~ ~a DEBT. TO: PAUL A. RHEAUME 15 W. Factory Street Mechanicsburg, PA 17055 DATE OF THIS NOTICE: August 31, 2001 IMPORTANT_NOTICE YOU ARE IN DEFAULT BECAUSE YOU HAVE FAILED TO ENTER A WRITTEN APPEARANCE PERSONALLY OR BY ATTORNEY AND FILE IN WRITING WITH THE COURT YOUR DEFENSES OR OBJECTIONS TO THE CLAIMS SET FORTH AGAINST YOU. UNLESS YOU ACT WITHIN TEN (10) DAYS FROM THE DATE OF THIS NOTICE, A JUDGMENT MAY BE ENTERED AGAINST YOU WITHOUT A HEARING AND YOU MAY LOSE YOUR PROPERTY OR OTHER IMPORTANT RIGHTS. YOU SHOULD TAKE THIS NOTICE TO A LAWYER AT ONCE. IF YOU DO NOT HAVE ALAWYER OR CANNOT AFFORD ONE, GO TO OR TELEPHONE THE FOLLOWING OFFICE TO FIND OUT WHERE YOU CAN GET LEGAL HELP: Cumberland County Bar Association 2 Liberty Avenue, Carlisle, PA (800) 990-9108 BY: Joseph A. ~oldbeck, Jr., Esq. Attorney for Plaintiff Suite 500 - The Bourse Bldg. 111 S. Independence Mall East Philadelphia, PA 19106 215-627-1322 TO: TIM COLGAN-ESQ THE WILEY GROUP I South Baltimore Street Dillsburg, PA 17019 DOVENMUEHLE MORTGAGE CO. LP 1501 Woodfield Road : IN TH~ COURT OF CO~ON PLEAS Schaumburg, IL 60173-4982 : Plaintiff : OF CUMBERI~%NDCOUNTY PAUL A. RHEAUME (Mortgagor(s)) : CIVIL ACTION - LAW (Record Owner(s)) : 15 W. Factory Street : ACTION OF MORTGAGE FORBCLOSUI~E Mechanicsburg, PA 17055 Defendant (s) : Term : No. 01-30S4 (Civil Term) THiS LAW FII~ IS A DEBT COLLECTOR A~D W~ A~E ATT~TIN~ TO COLLECT A DEBT OWED TO OUR CLI~. ANY INFOrmATION OBTAIWED FI~0~ YOU W~LL BE U~D FOR THE PURPOSE OF COLLECTIN~ THE DEBT. TO: TIM COLGAN-ESQ THE WILEY GROUP 1 South Baltimore Street Dillsburg, PA 17019 DATE OF THIS NOTICE: August 31, 2001 IMPORTAI~TNOTICE YOU ARE IN DEFAULT BECAUSE YOU HAVE FAILED TO ENTER A WRITTEN APPEARANCE PERSONALLY OR BY ATTORNEY AIgD 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 ALAWYER OR CANNOT AFFORD ONE, GO TO OR TELEPHONE THE FOLLOWING OFFICE TO FIND OUT WHERE YOU CAN GET LEGAL HELP: Cumberland County Bar Association 2 Liberty Avenue, Carlisle, PA {800) 990-9108 ,., _,4. otdt J. BY: Joseph A. Goldbeck, Jr., Esq. Attorney for Plaintlff Suite 500 - The Bourse Bldg. 111 S. Independence Mall East Philadelphia, PA 19106 215-627-1322 ~rn Rule of Civil Procedure No. 236 - Revised IN THE COURT OF COMMON PLEAS OF Cumberland COUNTY, PENNSYLVANIA CIVIL ACTION - LAW DOVENMUEHLE MORTGAGE CO. LP 1501 Woodfield Road Scha umburg, IL 60173-4982 Plaintiff No. 01-3054 Civil Term VS. PAUL A. RHEAUME (Mortgagors and Record Owner(s)) 15 W. Factory Street Mechanicsburg, PA 17055 Defendant(s) THIS LAW FIRM IS A DEBT COLLECTOR AND WE ARE ATTEMPTING TO COLLECT A DEBT OWED TO OUR CLIENT. ANY INFORMATION OBTAINED FROM YOU WILL BE USED FOR THE PURPOSE OF COLLECTING THE DEBT. NOTICE Notice is given that a .iudgment in the above-captioned mat~er has been entered against you. Curt Long Prothonotary By: Deputy If yon have any questions concerning the above, please contact: Joseph A. Goldbeck, Jr. Goldbeek MeCafferty & MeKeever Suite 500 - The Bourse Bldg. 111 S. Independence Mall East Philadelphia, PA 19106 215-627-1322 PRAECIPE FOR WRIT OF EXECUTION- (MORTGAGE FORECLOSURE) P.R.C.P 3180-3183 Joseph A. Goldbeck, Jr. Attorney I.D.#16132 Suite 500 - Tile Bourse Bldg. I I 1 S. Independence Mall East Philadelphia. PA 10106 215-627-1322 Attorney ft,]' Plaintiff DOVENMUEHLE MORTGAGE CO. LP 1501 Woodfield Road Schaumburg, IL 00173-4982 IN THE COURT OF COMMON PLEAS Plaintiff vs. of Cumberland County PAUL A. RHEAUME CIVIL ACTION- LAW Mortgagor(s) and Record Owner{s) 15 W, Factor.,,' Street ACTION OF MORTGAGE FORECLOSURE Mecbanicsburg, PA [7055 Defendant(s) No, 01-3054 Civil Teml PRAECIPE FOR WRIT OF EXECUTION TO THE PROTHONOTARY: Issue Writ of Execotion itl tile above matter: Amount Due $77,101.56 Interest from 01/01/2001 to 09/I 9/2002 at 8.0000% (Costs to be added1 ~I~Z~ a~ a ~n~ ~ t~ ~thern lin~ of ~aC~ory S~r~et, said ~int ml~ey; th.ncc S~h 71 ~ee~ 33 Mlnv~aa ~a~ ol~ 8mld ~tho~n 1~ o~ ~lgel, 3~., ~thmcn flAvx~ t~r~ er~t~ a 2~ eco~ gca~ ~elll~ and 4e~ach~ fc~ gat~e TAX PA~CBL WRIT OF EXECUTION and/or ATTACHMENT COMMONWEALTH OF PENNSYLVANIA) NO 01-.t0S4 Civil COUNTY OF CUMBERLAND) CIVIL ACTION - LAW TO THE SHERIFF OF CUMBERLAND COUNTY: To satisfy the debt, interest and costs due Dovenmuehle Mortgage Co. LP IS01 Woodfield Road, Schaumburg, IL 60173-4982 Plaintiff(s) From Paul A. Rheaurae IS W. Factory Street Meehaniesburg, PA 170SS (I) You are directed to levy upon the property of the defendaut (s)and to sell SEE LEGAL DESCRIPTION. (2) You are also directed to anach the property ofthe defendant(s) not levied upon in the possession of GARNISHEE(S) as follows: and to notify the garnishee(s) that: (a) an anachmnnt has been issued; (b) the garnishee(s) is enjoined fi'om paying any debt to or for the account of the defendant (s) and from delivering any property of the defendant (s) or otherwise disposing thereof; (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$77101.S6 L.L.$.S0 Interest FROM 01/01/2001 TO 9/19/2002 AT 8.0000% Ar~y's Comm % Due Prothy :$1.00 Am/Paid $1S?.2S Other Costs Plaintiff Paid Date: September 23, 2002 CURTIS R. LONG Prothonotary Deputy REQUESTING PARTY: Name Joseph A. Goldbeek, Jr. Address: Suite S00 - The Bourse Bldg. I I I S. Independence Mall East Philadelphia, PA 19106 Attorney for: Plaintiff Telephone: 21S-627-1322 Supreme Court [D No. 16132 UNITED STATES BANKRUPTCY COURT FOR THE MIDDLE DISTRICT OF PENNSYLVANIA-HARRISBURG : Chapler 13 In re: : : Bankruptcy Case No. 1-01-05473 PAUL A. RI-IEAUME, : : Debtor. : STIPULATED ORDER RESOLVING MOTION FOR RELIEF FROM THE AUTOMATIC STAY, WITH RESPECT TO REAL PROPERTY AND IMPROVEMENTS LOCATED AT 15 WEST FACTORY STREET, MECHANICSBURG, PENNSYLVANIA ! 7055, FILED ON BEHALF OF DOVENMUEHLE MORTGAGE, INC. Dovenmuehle Mortgage. Inc. ("DMI"). mtd Paul A. Rheaume (tire"Debtor"), by and through their respcclive undersigned counsel, having settled all issues related to the Motion for Relief from the Aulomatic Stay with Respect to Real Property and Improvements Located at 15 Wes! Factory Street. Mechanicsburg, Pennsylvania 17055. Filed on Bchalfof Dovenmuehle Mortgage, Inc. (the "Motion"l. hereby slipulate as follows: I. DMI is the holder of thc recorded first Mortgage againsl the Debtor's foregoing real properly and improvements Ihcreon (the "PropeO.v"). 2. Subsequent to commencement of this case, Ibc Debtor has defaulted in the paymen! of regular monthly mortgage payments, and the post-petition arrearages, as of February 14, 2002, inclusive oflale charges of $23.32 for each IaPc payment, total $3,309.40, plus costs and attorneys fees of S800.00. 09/18/2002 WED 19:16 [TX/RX NO 7086] ~002 3. For the foregoing masons, DMI is entitled to relief from the automatic stay; provided, that the Debtor has offered to cure the foregoing posl-pelition arrearage amounts, and to remain current in future mortgage payments, as follows: a. Payment of the total post-petition arrearages in the amount of $4.209.40 as follows: $2,472.00 upon execution ofthis Stipulated Order, $824.03 on February 20, 2002, the regular March mortgage payment of $824.03 on March 6, 2002, and $893.28 on or before Mareh 20, 2002; b. Upon entry ofthis Order, tim~'ly payment ofall fulure regular monthly mortgage payments to DMI pursuanl lo the Debtors' Note and Mortgage. If all of the' foregoing payments are made when due, DM! shall forbear from proceeding to foreclosure and sale of the Property. lfany of the foregoing payments required by Paragraphs 3.a and 3.b is received by DMI more than fifteen I 15) calendar days past the due date therefor, then DMI shall file a Certificate of Default with the Court. and forward copies thereof to Ihe Debtor and Debxor's counsel. Iflhe Debtor fails Io cure the defaull cited in Ihe Certificate of Default within ten days of the filing lhereof, then DMI shall be free to proceed with foreclosure and sale of the Property. at its option, without further order ofthis Court. 4. The parties have evidenced their consem Io the temps of this Stipulated Order by the signatures oflheir respective counsel affixed below and request Ihat the Court enter this Stipulated Order. Timothy ]. Attorney for Debtor Auomey for Dovenmuehle Mortgage. Inc. IT IS SO ORDERED. 09/18/2002 WED IS:J6 [TX/RX NO 7086] ~003 BY THE COURT: Hon. Rober~ Woodside Chie£U.$. Bankruptcy Judge Done this 4th day of Apr11, 2002 09/18/2002 WED 15:16 [TX/RX NO 7086] ~004 UNITED STATES BANKRUFTCY COURT FOR THE M]DDI~ DISTRICT OF PENNSYLVANIA-HARRISBURG : Chapter 13 In re: : : B~mkruptcy Ca,~ No. 1-01-05473 PAUL A. I~IEAUME, : : : Debtor. : TRUSTEE'$ CONSENT TO ._ STIPULATED ORDER RESOLVING MOTION FOR RELIEF FROM THE AUTOMATIC STAY, WITH RESPECT TO ILEAL PROPERTY AND IMPROVEMEI'~fS LOCATED AT 1~ WEST FACTORY STREET, MECHANICSBURG, PENNSYLVANIA 17055, FILF~D ON' BF~HALF OF DOVENMII~UI.g. MORT~A~R: Charles J. DeI-Iart, HI, the Chapter 13 Trustee in the above-captioned case. hereby consents to the foregoing Order, filed with the Court on February 20, 2002. Respectfully submilted, . · J. D iIn' ' : '"'Chffpier 13 Trustee P.O. Box 410 Hununelatown, PA 17036 FILED T, -- Mt: __ A.M.- RM c rk, J~-~ Pa~,u -p~v. Cour~ 09/18/2002 WED 15:16 [TX/RX NO 7086] ~005 ([oldbeck McCafferty & McKeever BY: Joseph A. Goldbeck, Jr. Attorney I.D. #16132 Suite 500 - The Bourse Bldg. 111 S. Independence Mall East Philadelphia, PA 10106 215-627-1322 Attorney for Plaintiff DOVENMUEHLE MORTGAGE CO. LP 1501 Woodfield Road IN THE COURT OF COMMON PLEAS Schaumburg, IL 60173-4982 Plainti fl' of Cumberland County YS. PAUL A. RHEAUME CIVIL AC;rlON - LAW (Mortgagorls) and Record Owner(s}} 15 W. Factor)' Street Mechanicsburg. PA 17055 ACTION OF MORTGAGE FORECLOSURE Defendant{s) No. 01-3054 Civil Term AFFIDAVIT PURSUANT TO RULE 3129 DOVENMUEHLE MORTGAGE CO. LP, Plaintiffin the above action, by its attorney, Joseph A. Goldbeck, Jr., Esquire, sets forth as of tile date the praecipe for the writ of execution was filed the following information concerning the real property located al: 15 W. Factory S~'eet Mechanicsburg, PA 17055 I.Name and address of Owner(s) or Reputed Owner(s): PAUL A. RHEAUME 15 W. Factory Street Mechanicsburg, PA 17055 2. Name and address of Defendant(s) in the judgment: PAUL A. RHEAUME 15 W. FactoD, Street Mechanicsborg, PA 17055 3. Name and last known address of every judgment creditor whose judgment is a record lien on the property to be sold: PA DEPARTMENT OF PUBLIC WELFARE - Bureau of Child Support Enforcement Health and Welfare Bldg. - Room 432 P.O. Box 2675 Harrisburg. PA 17105-2675 DOMESTIC RELATIONS OF CUMBERLAND COUNTY PO Box 320 Carlisle. PA 17013 BENEFICIAL CONSUMER DISCOUNT CO. 4910 Carlisle Pike, Suite 104 Mechanicsburg, PA 17055 BENEFICIAL CONSUMER DISCOUNT CO. 061 Weigel Drive Elmhurst, IL 60126 4. Name aud address of the last recorded holder of every mortgage of record: PENNSYLVANIA HOUSING FINANCE AGENCY 2101 N. Front Street Harrisburg. PA 5. Name and address of every other person who has any record interest in or record lien on the property and whose interest may be affected by the sale: 6. Name and address of every other person of whom the plaintiffhas knowledge who has any record interest in the property which may be affected by the sale. 7. Name anti address o£every other person of whom the plaintiffhas knowledge who has any interest in the property which may be affected by tile sale. TIM COLGAN-ESQ The Wiley Group I South Baltimore Slxeet Drillsburg, PA 17019 (attach sepal'ale sheet if nlore space is needed) I veri~, that the slatements made in this affidavit are true and correct to the best of my personal knowledge or information and beliel: I understand that false statements herein are made subject to the penalties of 18 Pa. C.S. Section 4904 relating to unsworn falsification to authorities. DATED: September 19, 2002 Attorney for Plaintiff 01-3054 Civil Term GOLDBECK MeCAFFERTY & MeKEEVER BY: Joseph A. Goldbeck, Jr. Anomey I.D.#16132 Suite 500 - The Bourse Bldg. I I I S. Independence Mall East Philadelphia~ PA 19106 215-627-1322 AtXomey for Plah~liff DOVENMI ! EHLE MORTGAGE CO. LP 1501 Woodfield Road IN THE COURT OF COMMON PLEAS Schaumburg. IL 60173-4982 of Cumberland County Plaintiff vs. CIVIL ACTION - LAW PAUL A. RIIEAUME Mortgagor(s) and Record Owner(s) ACTION OF MORTGAGE FORECLOSURE 15 W. Factory Street Mechanicsburg. PA 17055 Term No. 01-3054 Civil Term Defendant(s] THIS LAW FIRM IS A DEBT COLLECTOR AND WE ARE ATTEMPTING TO COLLECT A DEBT. THIS NOTICE IS SENT TO YOU IN AN ATTEMPT TO COLI,ECT A DEBT. ANY INFORMATION OBTAINED FROM YOU WILL BE USED FOR THAT PURPOSE. NOTICE OF SHERIFF'S SALE OF REAL PROPERTY TO: RI :'~ ~ME.P^LILA. PAUL A. RHEAUME 15 W. Factory Street Mcchanicsburg, PA 17055 Your house at 15 W. Factory Street, Mechanicsburg, PA 17055 is scheduled to be sold at Sheriffs Sale on Wednesday. March 05, 2003, at 10:00 AM, in Commissioners Hearing Rm 2nd FL Courthouse to enforce the court judgment of $77,101.56 obtained by DOVENMUEHLE MORTGAGE CO. LP against yOLL NOTICE OF OWNER'S RIGHTS YOU MAY BE ABLE TO PREVENT THIS SHERIFF'S S~,!-I~ To prevent this Sheriffs Sale you must take immediate action: I. The sale will be cancelled ifyou pay to DOVENMUEHLE MORTGAGE CO. LP, the back paymems, late charges, costs and reasonable attorney's fees due. To find out how much you must pay call: 215-627-1322 2. You may be able to stop the sale by filing a petition asking the Court to slrike or open judgment, if the judgment was improperly entered. You nmy also ask the Court to postpone the sale for good cause. 01-3054 Civil Term 3. You may also be able to stop the sale through other legal proceedings. You may need an attorney to assert your rights. The sooner you contact one, the more chance you will have of slopping the sale. (See notice below on how to obtain an attorney). YOU MAY STILL BE ABLE TO SAVE YOUR PROPERTY AND YOU HAVE OTHER RIGHT£ EVEN IF THE SHERIFF'S SALE DOES NOT TAKE PLACE_ I. If the Sheriff's Sale is not stopped, your property will be sold to the highest bidder. You may find out the price bid price by calling the Sheriffof 717-240-6390. 2. You may be able to petition the Court to set aside the sale if the bid price was grossly inadequate compared lo the value of your properly. 3. TILe sale will go through only if the buyer pays the Sheriffthe full amount due in the sale. To find out if this has ha@pened, you may call the Sheriffof 717-240-6390. 4. It' Ihe 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. Yoa have a right to remain in the properly until the full amount due is paid to the Sheriffand the Sheriff gives a deed to the buyer. At that time, the buyer may bring legal proceedings to evict you. 6. Yoa may be enlitled to a share ofthe money which was paid for your house. A schedule of dislributioa oflhe money bid for your house will be filed by the Sheriffthirly (30) days from the date of the Sheriffs 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 w 1L Ihe Sherit'f within ten (10) days after the schedule of distributinn is filed. 7. You may also have other rights and defenses, or ways of getting your house back. ifyou act iuunedialely 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 OU'F WHERE YOU CAN GET LEGAL HELP. CUMBERLAND COUNTY BAR ASSOCIATION 2 Liberty Avenue Carlisle, PA 17013 LEGAL SERVICES INC 8 Irvine Row Carlisle, PA 17013 Jospeh A. Goldbeck..Ir. Attorney I.D. #16132 Suite 500 - The Bourse Bldg. 111 S. Independence Mall East Philadelphia. PA [9106 215-627-1322 Attorney for Plaintiff DOVENM[JEHkE MORTGAGE CO. LP 1501 Woodfield Road Schaumburg. IL 60173-4982 Plaintiff IN THE COURT OF vs. COMMON PLEAS PAUL A. RHEAUME Mortgagor(s) and Record Owner(s) of Cumberland County 15 W. Factory Street Mechanicsburg. PA 17055 CIVIL ACTION - LAW Defendant(s) ACTION OF MORTGAGE FORECLOSURE NO. 01-3054 Civil Term CERTIFICATION AS TO THE SALE OF REAL PROPERTV I, Joseph A. Goldbeck, Jr., Esquire hereby certify that I am the attorney of record for the Plaintiff in this action, and I further certify that this properly is subject to Act 91 of 1983 and the Plaintiffhas complied with all the provisions of the Act. Joseph A. Goldbe~Jr. ~' ' Attorney for plaingqf i ~aau~ i~ . ~th~ate~Zy di~ctl~ t~ h~dc~ sixty (2~.~) ~eet cna e~th~d~ ~er o~ Fac~o~ Sb~ee~ a~ ~cket S~reet; thence o~ ~c~ C. ~ dia~an~ oe ~e h~ted n~ne~ .... (~9.16) fees te ~ hub ~ U~e not~e~ ~ne o~ a ~i:~een (~5.~) f~t ~lde alley; thence S~h 7~ d~reea 33 mLnu~ea ~e: al~ said ~cthetn line alley a distance b: aixty~e (6Z.~) feet to n hub; bhence ~reh 18 d~cees 27 mLnutea ~et ak~ the eastern ~ine of lends n~ or ~o~rly of ~n H. ~igel, Jr., a distance o~ ~e h~c~ nineteen (119.~) E~- -- - ~ld ~thecn l~n~ oC rac:~ ~---- ... ~ceea 33 minuteo ~ae el~g ~t~tha (~-83J E~h t~].[~"~ a u~s~anc~ ~ ~lfty-[our a~ eighty-three ~ a~ n~F~ as 15 ~t Facto~ Seceet. ~Ltl~ a~ tl~hts of ray o~ TAX PARCEL ~ 19-22-0519-083 PROPBRTY ADDRBSS: 15 W. Facto~ St~ct, Mcchanicsburg, PA 17055 IMPROVEMENTS: A residential dweUing. SOLD AS THB PROPBRTY OF: PAUL A. ~AUMB In the Court of Common Pleas of Cumberland County DOVENMUEHLE MORTGAGE CO. LP 1501 Woodfield Road 5chaumburg, IL 60173-4982 Plaintiff vs. PAUL A. RHEAUME (Mortgagor(s) and Record Owner(s)) 15 W. Factory. Street No. 01-3054 Civil Term Mechanicsburg. PA 17055 Defendant(s) PRAECIPE FOR JUDGMENT 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. Enter the Judgment iii favor of Plaintiffand against PAUL A. RHEAUME by default for want of an Answer. Assess damages as follows: Debt $77,101.56 Interest - 01/01./2-001 to 09/19/2002 Total (Assessment of Damages attached) I CERTIFY THAT FOREGOING ASSESSMENT OF DAMAGES IS FOR SPECIFIED AMOUNTS ALLEGED TO BE DUE IN THE COMPLAINT AND IS CALCULABLE AS A SUM CERTAIN FROM THE COMPLAINT. I certify that wriuen ~otice of the intention to file this praecipe was mailed or delivered to Ihe party against whom judgment is to be entered and to his attorney of record, if any, after the default occurred and at least ten days prior to the date of the filing of this praecipe. A copy of the notice is attached. R.C.P. 237.1 Joseph A. Gop~ck,Vr./ Attorney for ~l~.qntiffl / I.D. #16132 AND NOW . , Judgment is entered in favor of DOVENMUEHLE IVlORTGAGE CO. LP and against PAUL A. R. HEAUME by defaull for want of an Answer and damages assessed in the sum o f $77, I 01 .$6 as per the above cerli fication. Protbonotar7 UNITED STATES BANKRUPTCY COURT FOR THE MIDDLE DISTRICT OF PENNSYLVANIA-HARRISBURG : Chapter 13 In re: : : Bankruptcy Case No. 1-01-05473 PAUL A. RHEAUME, : . Debtor. : STIPULATED ORDER RESOLVING MOTION FOR RELIEF FROM THE AUTOMATIC STAY, WITH RESPECT TO REAL PROPERTY AND IMPROVEMENTS LOCATED AT 15 WEST FACTORY STREET, MECHANICSBURG, PENNSYLVANIA 17055, FILED ON BEHALF OF DOVENMUEHLE MORTGAGE, INC. Dovenmuehle Mortgage. Inc. CDMI"), and Paul A. Rheaume (the "Debtor"), by and through their respeclive undersigned counsel, having settled all issues related to the Motion for Relief from Ibc Automatic Stay with Respect lo Real Property and Improvements Located at 15 West Factory Streel. Mechanicsburg, Pennsylvania 17055, Filed on Behal£of Dovenmuehle Mortgage, Inc. (the "Molion"). hereby stipulate as follows: I. DMI is the holder of the recorded first Motlgage agains! the Debtor's foregoing real property and improvements Ihereon (the "Property"). 2. Subsequent to commencement ol'thJs case, the Deblor has defauhed in thc paymenl of regular monthly mortgage paymenls, and tile post-pelhion arrearages, as of February 14, 2002, inclusive o£1ate charges o1'S23.32 for each linc payment, total $3,309.40, plus costs and attorneys fees of SS00.00. 09/18/2002 WED 15:16 rTx/Rx Nn 7flssI ~flo2 3. For the foregoing reasons, DMI is entitled to relief from the automatic stay; provided, that the Debtor bas offered to cure the foregoing post-petition arrearage amounts, and to remain current in future mortgage payments, as follows: a. Payment of the total post-petition arrearages in the amount of $4209.40 as follows: $2,472.00 upon execution ofthis Stipulated Order, $824.03 on February 20, 2002, the regular March mortgage payment of $824.03 on March 6, 2002, and $893.28 on or before March 20, 2002; b. Upon entry ofthis Order. timely payment ofall future regular monthly mortgage payments to DMI pursuant to Ihe Debtors' Note and Mortgage. If all of the' foregoing payments are made when due, DMI shall forbear from proceeding to foreclosure and sale of the Properly. If any of the foregoing payments required by Paragraphs 3.a and 3.b is received by DMI more than fifteen (15) calendar days pas! the due date therefor, then DMI shall file a Certificate of Default with the Coati, and fonvard copies thereo£ to Ihe Deblor and Debtor's counsel. Iflhe Debtor fails lo cure the del;suit ciled in the Cerfificale of Defaull within ten days of thc filing thereof, then DMI shall be free to proceed with foreclosure attd sale of the Properly. at its option, without further order of this Court. 4. The parlies have evidenced Iheir consent Io the temts of Ibis Stipulated Order by the signatures of their respective counsel affixed below and request that the Court enler this Stipulated Order. "Debtor" Allom¢.v for Deblor Atlm'ney for Dovenmuehle Mortgage. Inc. IT IS SO ORDERED. 09/18/2002 WED 15:16 [TX/R~ NO 7086] ~003 BY THE COURT: : Hon. Robert Woodsid. Chief U.S. Bankruptcy Judge Done this 4th day of April, 2002 FILED 09/18/2002 WED 16:16 [TX/RX NO 7086] ~004 UNITED STATES BANKRUPTCY COURT FOR THE MlDDLE DISTRICT OF PENNSYLVANIA-HARRISBURG : Chapter 13 In re: : : Bankruptcy Caso No, 1-01-05473 FAUL A, I~IEAUME, : , : · Debtor. : TRUSTEE'S CONSENT TO STIPULATED ORDER RESOLVING MOTION FOR RELIEF FROM THE AUTOMATIC STAY, WITH RESPECT TO REAL PROPERTY AND IMPROVEMENTS LOCATED AT 1~ WEST FACTORY STREET, MECHANICSBURG, PENNSYLVANIA 17055~ NFI.~F~ ON R~HA!.~' OF DOVENMUI~M!.V. MORT(~=A/'~=~: INC Charles J. De. Hart, HI, the Chapter 13 Trustee in the above-captioned case, hereby consents to the foregoing Order, filed with the Court on February 20, 2002. Respectfully submitted, · / · '"Clffpt~ ]3 Tmsto~ P.O. Box 410 Hunm~el~-'town, PA 17036 - rJyE_ __A.M.. 09/18/2002 WED 15:16 [TX/RX NO 7088] ~OOS : c.:o~-E~ MCC~.,FF~"r¥ & MC~EV~. Attorney I.D.~16132 Suite 500-~e ~rse ~flding 111 S. In~ndence ~1 East Philadelphia, PA 19106 215-627-1322 1501 W~field R~d /~ ~/ Schau~, IL 60173-4982 /~ :~/ OF ~ ~ No. ~1-3054 Civil Te~ PA~ A. ~ : (Mo~ga~r ~d Real ~er) 15 W. Facto~ Steer : Mec~ics~, PA 17055 : day of 001, upon consideration of the Plaintiff's Motion for Substituted Service under Pa.R.C.P. 430(a) and it appearing to the Court that Plaintiff's good faith efforts to ascertain the present whereabouts of Defendant has been unsuccessful, it is, ORDE~ and DECREED: that Plaintiff's Motion is 9ranted and the Sheriff and/or Plaintif f is directed to Serve the ComDlaint in Mortgage Foreclosure upon Defendant by posting a uopy of the Cou~laint upon the prem/ses~15 W. Factory Street, Mechanicsburg, PA 17055 and Plaintiff is directed to serve the Co~lalnt by certified and regular mail to the Defendant's last known address of~15 W. Factory Street, Mechanicsbur~, PA 17055 and that all further service of l~jal papers, including but not limited to motions, petitions and rules b~ made by certified and regular mail to Defendant's last known address and that Notice of Sheriff Sale pursuant to Pennsylvania Rule of Civil Procedure 3129 may be made upon Defendants by sending copies of sa~ to Defendant's last known address by certified and regular mail and by posting the premises. BY TH~ COURT: Joseph A. Goldbeck, Jr. Attorney I.D.#16132 Suite 500 - The Bourse Bldg. 111 S. Independence Mall Bast Philadelphia, PA 19106 215-627-1322 Attorney for Plaintiff DOVENMUEHLE MORTGAGE CO. LP : IN THB COURT OF COMMON PLEAS 1501 Woodfield Road : Schaumburg, IL 60173-4982 : OF CUMBERL~ COUlTTY VS. : Term PAUL A. RHEAUME ..(Mortgagor(s) : No. 01-3054 Civil Term) and Record Owner(s)') : 15 W. Factory Street '.' _ M~chanicsburg, PA-17055 CERTIFICATE OF SERVIC~ .' JOSEPH A. GOLDBECK,.JR. ESQUIRE hereby certifie~ that o'n August 10, 2001 he did serve upon Defendant(s) PAUL A. RHEAUME a true and correct.copy of the above-captioned Complaint by certified and regular mail in accordance with the Court Order dated July 23, 2001. The undersigned understands that the statements herein and subject to the penalties provided by 18 P.S. Section 4904. Respectf~~d, JOSEPH A. GOLDBECK, JR. ESQUIRE SHERIFF'S RETURN - REGULAR CASE NO: 2001-03054 P COMMONWEALTH OF PENNSYLVANIA: COUNTY OF CUMBERLAND DOVENMTJEHLE MORTGAGE CO LP VS RHEAUME PAUL A BRIAN BARRICK , Sheriff or Deputy Sheriff of Cumberland County,Pennsylvania, who being duly sworn according to law, says, the within COMPLAINT - MORT FORE was served upon RHEAUNE PAUL A the DEFENDANT , at 2112:00 HOb-RS, on the 8th day of August , 2001 at 15 W FACTORY ST MECHANICSBURG, PA 17055 by handing to PROPERTY POSTED AT 15 W FACTORY ST MECHANICSBURG a true and attested copy of COMPLAINT - MORT FORE together with and at the same time directing His attention to the contents thereof. Sheriff's Costs: So Answers: Service 5.85 Posting 6.00 Surcharge 10.00 R. Thomas Kline .00 39.85 08/09/2001 GOLDBECK MCCAFFERTY & MCKEEVE~/~ Sworn and Subscribed to before By: ~ ~ ~~ me this day of Deputy Sheriff A.D. Prothonotary TO: PAUL A. RHEAUME 15 W. Factory Street Mechanicsburg, PA 17055 DOVEN~Tu~EHLE MORTGAGE CO. LP 1501 Woodfield Road : IN THE COURT OF CO~ON PLEAS Schaumburg, IL 60173-4982 : Plaintiff : OF CUMBERLAND COUNTY PAUL A. RHEAUME (Mortgagor(s)) : CIVIL ACTION - LAW (Record Owner(s)) : 15 W. Factory Street : ACTION OF MORTGAGE FORBCLOSURE Mechanicsburg, PA 17055 : Defendant(s) : Term : No. 01-3054 (Civil Term) THIS LAW FII~ IS A DEBT COLLECTOR ~ ~N APsE A~'F~PTIN~ TO COLLECT A DEBT OWeD TO OUR CLIENT. ~ INFOI~ATION OBTAINED FROM YOU WILL BE USeD FOR TH~ PURPOSE OF COLLECTI~ TH~ DEBT. TO: PAUL A. RHEAUME 15 W. Factory Street Mechanicsburg, PA 17055 DATE OF THIS NOTICE: AuguHt 31, 2001 IMPORTANT NOTICE YOU ARE IN DEFAULT BECAUSE YOU HAVE FAILED TO ENTER A WRITTEN APPEARANCE PERSONALLY OR BY ATTORNEY AND FILE IN WRITING WITH THE COURT YOUR DEFENSES OR OBJECTIONS TO THE CLAIMS SET FORTH AGAINST YOU. UNLESS YOU ACT WITHIN TEN (10) DAYS FROM THE DATE OF THIS NOTICE, A JUDGMENT MAY BE ENTERED AGAINST YOU WITHOUT A HEARING AND YOU MAY LOSE YOUR PROPEETY OR OTHER IMPORTANT RIGHTS. YOU SHOULD TAKE THIS NOTICE TO A LAWYEE 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 Ear Association 2 Liberty Avenue, Carlisle, PA (800) 990-9108 BY: Joseph A. Ooldbeck, Jr., Esq. Attorney for Plaintiff Suite 500 - The Bourse Bldg. 111 S. Independence Mall East Philadelphia, PA 19106 215-627-1322 TO: TIM COLGAN-ESQ THE WILEY GROUP i South Baltimore Street Dillsburg, PA 17019 DOVENMUEHLE MORTGAGE CO. LP 1501 Woodfield Road : IN THE COURT OF CO~4ON PLEAS Schaumburg, IL 60173-4982 : Plaintiff : OF CUMBERLAND COUNTY VS. : PAUL A. RHEAUME (Mortgagor(s)) : CIVIL ACTION - LAW (Record Owner(s)) : 15 W. Factory Street : ACTION OF MORTgAgE FORECLOSURE Mechanicsburg, PA 17055 : Defendant(s) : Term : No. 01-3054 (Civil Term) : THIS LAW FIE IS A DEBT COLLECTOR AND WE ARE ATT~MPTIN~ TO COLLECT A DEBT OWED TO OUR CLIENT. ANY INFO~TION OBTAINS) FROM YOU WILL BH UHND FOR wal PUI~POSE OF COLLHCTIN~ THE DEBT. TO: TIM COLGAN-ESQ THE WILEY GROUP 1 South Baltimore Street Dillsburg, PA 17019 DATE OF THIS NOTICE: August $1, 2001 IMPORTANT NOTICE YOU ARE IN DEFAULT BECAUSE YOU HAVE FAILED TO ENTER A WRITTEN APPEARANCE PERSONALLY OR BY ATTORNEY AND FILE IN WRITING WITH THE COURT YOUR DEFENSES OR OBJECTIONS TO THE CLAIMS SET FORTH AGAINST YOU. UNLESS YOU ACT WITHIN TEN (10) DAYS FROM THE DATE OF THIS NOTICE, A JUDGMENT MAY BE ENTERED AGAINST YOU WITHOUT A HEARING AND YOU MAY LOSE YOUR PROPERTY OR OTHER IMPORTANT RIGHTS. YOU SHOULD TAKE THIS NOTICE TO A LAWYER AT ONCE. IF YOU DO NOT HAVE A LAWYER OR CANNOT AFFORD ONE, GO TO OR TELEPHONE THE FOLLOWING OFFICE TO FIND OUT WHERE YOU CAN GET LEGAL HELP: Cumberland County Bar Association 2 Liberty Avenue, Carlisle, PA (800) 990-9108 ~OLDBRCK McCAFF~I~TY & M~KEEV~R BY: Joseph A. ~oldbeck, Jr., Esq. Attorney for Plaintiff Suite 500 - The Bourse Bldg. 111 S. Independence Mall East Philadelphia, PA 19106 215-627-1322 Rnle of Civil Procedure No. 236 - Revised IN THE COURT OF COMMON PLEAS OF Cumberland COUNTY, PENNSYLVANIA CIVIL ACTION - LAW DOVENMUEHLE MORTGAGE CO. LP 1501 Woodfield Road Schaumburg, IL 60173-4982 Plaintiff No. 01-3054 Civil Term YS. PAUL A. RHEAUME (Mortgagors and Record Owner(s)) 15 W. Factory Streel Mechanicsburg, PA 17055 Defendant(s) THIS LAW FIRM IS A DEBT COLLECTOR AND WE ARE ATTEMPTING TO COLLECT A DIt. BT OWED TO OUR CLIENT. ANY INFORMATION OBTAINED FROM YOU WILL BE USED FOR THE PURPOSE OF COLLECTING THE DEBT. NOTICE Notice is g~ven that a judgment in the above-captioned mat~er has been entered against you. Curt Long Prothonotary By: Deput3' If you have any questions concerning the above, please contact: Joseph A. Goldbeck, Jr. Goldbeek MeCafferty & MeKeever Suite 500 - The Bourse Bldg. 111 S. Independence Mall East Philadelphia, PA 19106 215-627-1322 GOLDBECK McCAFFERTY & McKEEVER BY: Joseph A. Goldbeck, Jr. Attorney I.D. #16132 Suite 500 - The Bourse Bldg. I I 1 S. Independence Mall East Philadelphia, PA 19106 215-627-1322 Attorney for Plaintiff DOVENMUEHLE MORTGAGE CO. LP 1501 Woodfield Road IN THE COURT OF COMMON PLEAS Scha umburg, IL 60173-4982 Plaintiff of Cumberland County VS. PAUL A. RHEAUME CIVIL ACTION LAW (Mortgagor(s) and Record owner(s)) 15 W. Factory Stree[ Mechanicsburg, PA 17055 ACTION OF MORTGAGE FORECLOSURE Defendant(s) No. 01-3054 Civil Term ORDER FOR JUDGMENT Please enter Judgment in favor of' DOVENMUEHLE MORTGAGE CO. LP, and against PAUL A. RHEAUME for lhilure to file an Answer in the above action within (20) days (or sixty (60) days if defendant is the United Slates of America) from the date of service of the Complaint, in the sum of $77,101.56. Joseph A. Goldbe~r. Attorney for Plainfi~ I hereby certify that thc above names are correct and that the precise residence address of the judgraent creditor is DOVENMUEHLE MORTGAGE CO. LP 1501 Woodfie]d Road Schaumburg, IL 60173-4982 and that the name(s) and last known address(es) of the Defendant(s) is/are PAUL A. RI.-IEAUME, 15 W. Factory Street Mechanicsburg, PA 17055; GOLDBECK ~[TY & McKEEVER BY.' Joseph A. 9~ldbe~ Jr. Attorney for Pla~tiff ASSESSMENT OF DAMAGES TO THE PROTHONOTARY: Kindly assess the damages in this case to be as follows: Principal Balance $58,958.21 luteres! from 01/01/2001 through $8,087.92 00/19/2002 Attorney's Fee at 5.0000% of principal $2,947.91 balance Late Charges $824.00 Costs of Suit and Title Search $560.00 Escrnv,, Balance Deficit $5,723.52 ($0.00) $77,101.56 GOLDBECK R BY: Joseph A. qqdbeck] ~r. Atlorney for Pla~ltiff ~ AND NOW, this day of ,2002 damages are assessed as above. Pm Pmthy VERIFICATION OF NON-MILITARY SERVICE The undersigned, as the representative for the Plaintiff corporation within named do hereby verify that I am authorized to make this verification on behalf of the Plaintiff corporation and that the facts set forth in the foregoing verification of Non- Military Service are true and correct to the best of my knowledge, information and belief. I understand that false statements therein are made subject to penalties of 18 Pa. C.S. 4904 relating to unsworn falsification to authorities. 1. That the above named Defendant, PAUL A. RHEAUME, is about unknown years of age, that Defendant's last known residence is 15 W. Factory Street, Mechanicsburg, PA 17055, and is engaged in the unknown business located at unknown address. 2. That Defendant is not in the Military or Naval Service of the United States or its Allies, or otherwise within the provisions of the Soldiers' and Sailors' Civil Relief Action of Congress of 1940 and its Amendments. ~ / ~ Date: Goldbeck McCaft~rty & McKeever BY: Joseph A. Goldbeck, Jr. Attorney I.D. #16132 Suite 500 - The Bourse Bldg. 111 S. Independence Mall East Philadelphia, PA 19106 215-627-1322 Attorney for Plaintiff DOVENMUEHLE MORTGAGE CO. LP 1501 Woodfield Road IN THE COURT OF COMMON PLEAS Schaumburg, IL 60173-4982 Plaintiff of Cumberland County VS. PAUL A. RHEAUME CIVIL ACTION - LAW (Mortgagor(s) and Record Owner(s)) 15 W. Factory Street Mechanicsburg. PA 17055 ACTION OF MORTGAGE FORECLOSURE Defendant(s) No. 01-3054 Civil Term AFFIDAVIT PURSUANT TO RULE 3129 DOVENMUEHLE MORTGAGE CO. LP. Plaintiffin the above action, by its attorney, Joseph A. Goldbeck, Jr., Esqoire, sets forth as of lhe dale Ihe praecipe for the writ of execution was filed the following information concerning the r~al property located at: 15 W. Factory Street Mechanicsburg, PA 17055 l.Name and address of Owner(s) or Reputed Owner(s1: PAUL A. RHEAUME 15 W. Factory Street Mechanicsburg, PA 17055 2. Name and address of Defendant(s) in the judgment: PAUL A. RHEAUME 15 W. Factory Street Mechanicsburg. PA 17055 3. Name and last k~owu address of every judgment creditor whose judgment is a record lien on the property to be sold: PA DEPARTMENT OF PUBLIC WELFARE - Bureau of Child Snpport Enforcement Health and Welfare Bldg. - Room 432 P.O. Box 2675 Harrisburg, PA 17105-2675 DOMESTIC RELATIONS OF CUMBERLAND COUNTY PO Box 320 Carlisle. PA 17013 BENEFICIAL CONSUMER DISCOUNT CO. 4910 Carlisle Pike, Suite 104 Mechanicsburg, PA 17055 BENEFICIAL CONSUMER DISCOUNT CO. 961 Weigel Drive EInthurst, IL 60126 4. Name and address of the last recorded holder of every mortgage of record: PENNSYLVANIA HOUSING FINANCE AGENCY 2101 N. Front S~eet Harrisburg. PA 5. Name and address of every other person who has any record interest in or record lien on the property and whose interest may be affected by the sale: 6. Name and address of every other person of whom the plaintiff has knowledge who has any record interest in the property which may be affected by the sale. 7. Name and address of every other person of xvhom the plaintiff has knowledge who has any interest in the property which may be affected by Ihe sale. TIM COLGAN-ESQ The Wiley Group I South Baltimore S~'eet Drillsburg, PA 17019 (attach separate sheet if more space is needed) I verify that tile slatements made in this affidavit are true and correct to the best of my personal knowledge or inforomtion and belief. 1 understand that false statements herein are made subject to the penalties of 18 Pa. C.S. Section 4904 relating to unsworn falsification to authorities. GOLDBECK McKEEVER BY: Joseph A. ~agldbeck,.Jr., Esq. ARorney for Plaintiff 01-3054 Civil Term GOLDBECK McCAFFERTY & McKEEVER BY: Joseph A. Goldbeck, Jr. ARomey I.D.# 16132 Suite 500 - The Bourse Bldg. I 11 S. Independence Mall East Philadelphia, PA 19106 215-627-1322 Attomey for Plaintiff DOVENMUEHLE MORTGAGE CO. LP 1501 Woodfield Road IN THE COURT OF COMMON PLEAS Schaumburg, IL 60173-4982 of Cumberland County Plaintiff vs. CIVIL ACTION - LAW PAUL A. RHEAUME Mortgagor(s) and Record Owner(s) ACTION OF MORTGAGE FORECLOSURE 15 W. Factory Street Mechanicsburg, PA 17055 Term No. 01-3054 Civil Term Defendant(s THIS LAW FIRM IS A DEBT COLLECTOR AND WE ARE ATTEMPTING TO COLLECT A DEBT. THIS NOTICE IS SENT TO YOU lb/AN ATTEMPT TO COLLECT A DEBT. ANY INFORMATION OBTAINED FROM YOU WILL BE USED FOR THAT PURPOSE. NOTICE OF SHERIFF'S SALE OF REAL PROPERTY TO: RHFAUME. PAUL A. PAUL A. RHEAUME 15 W. Factory Street Mechanicsburg, PA 17055 Your house at 15 W. Factory Street, Mechanicsburg, PA 17055 is scheduled to be sold at Sheriff's Sale on Wednesday, March 05, 2003, at 10:00 AM, in Commissioners Hearing Rm 2nd FL Courthouse to entbrce the court judgment of $77.101.56 obtained by DOVENMUEHLE MORTGAGE CO. LP against you. NOTICE OF OWNER°S RIGHTS YOU MAY BE ABLE TO PREVENT THIS SHERIFF'S S.~I.I~. '1'o prevent this Sheriff's Sale you must take in,nediate action: I. The sale will be cancelled if you pay to DOVEN'MUEHLE MORTGAGE CO. LP, the back payments. [nle charges, costs and reasonable attorney's fees due. To find out how much you must pay call: 215-627-1322 2. You may be able to stop the sale by filing a petition asking the Com't to strike or open judgment, it' the.luclgment was improperly entered. You may also ask the Court to poslpone Ihe sale for good cause. 01-3054 Civil Term 3. You may also be able to stop the sale through other legal proceedings. You may need an attorney to assert your rights. The sooner you contact one. the more chance you will have of stopping the sale. (See notice below on how to obtain an attorney). YOU MAY STILL BE ABLE TO SAVE YOUR PROPERTY AND YOU HAV~ OTHER RIGHTS EVEN IF THE SHERIFF'S SALE DOES NOT TAK~ PLACE. I. If the Sheriffs Sale is uot stopped, your properly will be sold to the highest bidder. You may find out the price bid price by calling the Sheriffof 717-240-6390. 2. Yoz~ may be able to petition the Court to set aside the sale if the bid price was grossly inadequate compared to tile value of your property. 3. The sale will go through only if the buyer pays the Sheriff the full amount due in the sale. To find out if this has happened, you may call the SheriffofTI7-240-6390. 4. If tile 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 a right to remain in the property until the full amount duc is paid to the Sheriff and the Sheriffgives 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 distributinn of the money bid for your house will be filed by the Sheriff thirty (30) days from the date of the Sheriffs Sale. This schedule will state who will be receiving thai money. The money will be paid out in accordance with this schedule unless egceptions (reasons why the proposed distribution is wrong) are filed with tile Sheriff within len (10) days after Ihe schedule of distribution is filed. 7. Yot~ may also have other rights and defenses, or ways of gelting your house back, if you act inunediately after the sale. YOU SHOULD TAKE THIS PAPER TO YOUR LAWYER AT ONCE. IF YOU DO NOT HAVE A LAWYER OR CANNOT AFFORD ONE, GO TO OR TELEPHONE THE OFFICE LISTED BELOW TO FIND OUT WHERE YOU CAN GET LEGAL HELP. CUMBERLAND COUNTY BAR ASSOCIATION 2 Liberty Avenue Carlisle, PA 17013 LEGAL SERVICES INC' 8 Irvine Row Carlisle, PA 17013 PRAECIPE FOR WRIT OF EXECUTION - (MORTGAGE FORECLOSURE) P.R.C.P 3180-3183 Joseph A. Goldbeck? Jr. Attorney I.D.#16132 Suite 500 - The Bourse Bldg. l 11 S. Independence Mall East Philadelphia, PA Iql06 215-627-1322 Attorney for Plaintiff DOVENMUEHLE MORTGAGE CO. LP 1501 Woodfield Road Schaumburg, IL 60173-4982 IN THE COURT OF COMMON PLEAS Plaintiff vs. of Cumberland County PAUL A. RHEAUME CIVIL ACTION - LAW Mortgagor(s) and Record Owner(s) 15 W. Factory Street ACTION OF MORTGAGE FORECLOSURE Meehanicsburg, PA 17055 Defendant(s) No. 01-3054 Civil Term PRAECIPE FOR WRIT OF EXECUTION TO THE PROTHONOTARY: Issue Writ of Execution in the above matter: Amount Due $77,101.56 Interest from 01/01i2001 to 09/19/2002 at 8.0000% (Costs to be added) GOLDBECK Mc cKEEVER BY: Joseph A. Gold~eek, Jr[ I Attorney for Plaintiff ~/ WRIT OF EXECUTION - (MORTGAGE FORECLOSURE) P.R.C.P. 3180-3183 AND Rule 3257 DOVENMUEHLE MORTGAGE CO. LP 1501 Woodfield Road Schaumburg, IL 60173-4982 In the Court of Common Pleas of Cumberland County VS. PAUL A. RHEAIIME 15 W. Factory Street No. 01-3054 Civil Term Mecbanicsburg. PA 17055 WRIT OF EXECUTION (MORTGAGE FORECLOSURE) Commonwealth of Pennsylvania: County of Cumberland To the Sheriff of Cumberland County,.Pennsylvanla To satis~, the judgment, interest and costs in the above matter you are directed to levy upon and sell the following described property: PREMISES: 15 W. Factory Street Mechanicsburg, PA 17055 See Exhibit "A" attached AMOUNT DUE $77,101.5fi Interest From 01/01/200 I Through 09/I 9/2002 (Cosmtobe added) Dated: Prothonotary, Common Pleas Court of Cumberland County, Pennsylvania Deputy Jospeh A. Goldbeck, Jr. Attorney I.D. #16132 Suite 500 - The Bourse Bldg. 111 S. Independeoce Mall East Philadelphia, PA 19106 215-627-1322 Attorney tbr Plaintiff DOVENMUEHLE MORTGAGE CO. LP 1501 Woodfield Road Sehaumburg. IL 60173-4982 Plaintiff IN THE COURT OF vs. COMMON PLEAS PAUL A. RHEAUME of Cumberland County Mortgagor(s) and Record Owner(s) 15 W. Factory Street CIVIL ACTION - LAW Mechanicsburg, PA 17055 Defendant(s) ACTION OF MORTGAGE FORECLOSURE NO. 01-3054 Civil Term CERTIFICATION AS TO THE SALE OF REAL PROPERTY l, Joseph A. Goldbeck, Jr., Esquire hereby certify that I am the attorney of record for the Plaintiffin this action, and I further certit~ that this property is subject to Act 91 of 1983 and the Plaintiffhas complied with all the provisions of the Act. Joseph A. Gol r. Attorney for plain~i'ff a~ 8~ate og Pen~eylv~la, ~re ~rti~larly ~o~ a~ ~escri~ ~l~z~ at 4 ~nt ~ t~ ~che~n ~ne o[ F~to~y ~treet, aai~ ~n~ (119.16} ~eet to ~ hub ~ the northe~ ~t~ o~ a f~fteeo (15.~) Ille~ a ~Latance b~ aLxhy-~e (61.~) teeC ~o a hob; thence ~rth 27 m/nutem West ak~ the eaote~ ~ine o~ len~a n~ or ;u~rly o~ 3~n H. ~lgel, 3r,, n ~L~tance ot ~e h~t~ nineheen (1~9.~) [~C ~o a h~ ~ the ~ ~uthecn l~n~ ot F~CC~ Strut a distance o~ ~y-/our a~ cindy-three ~g~Chu (~.83~ [~t Lo a h~, the ~ln2 a~ Place ot ~I~ING. RAVl~ ther~ ec~b~ a 2~ ICO~ tra~ ~elX~ and de~ach~ fci~ I ~iti~ aM rl~hta o~ vaF o~ cecoS. TAX PARCEL ~ l ~-22-0~ 1 ALl, THAT eD~i, Azifjl-r&et or pit:Ca.), of land altust:a o~ the sao~h aide o; teat t n ~ a ucg, County o~ i Y . nd described as £~m the aouth~ee~t cot-net of ractecy Street and f4arket Street: thence (119.16) x u ~a~' te )~ hub on Ute nocchern ~lna oJ~ a ~lfbeen (15,00} foot Vida alley: thencs So~:h 71 d4~gcees 33 Minutes Hesb along said floc~hs~n line al]ay a distance b~' sixty-one (61.00) fee[: to s hub; bhence 14or~h .I.8 decjcsea t~tgel0 ~r., a dl~tanca o~ one hundred nina~een (119.00) fee: C _mm.t, hscn .line of ~acCocy 8t:t'eet; theflce Notch 71 "~"'r--- '~'~ ' °La hub on the ,; .~.s,ee~ a stat&nee of ~Lfi:y-lEoUr and eighty-three hvfldcedtha (54.83! Ee~t Lo a hub, the point and P/ace o~ RAVTNG thereon erected a 211 eco~, frame rivalling and del:nehe~ france g&rt~Ja ~ and nta~be~'~ aa 15 ~eat eacto~,y Street. I IAqD&R ANO ZU~ISCT~ rmverthalaaa, to sase~r, en[:a, restrictions, resecvatl~xta, cofldit~cflo and tl~.hta of ray o£ racotd. TAX PARCI~L # 19-22-05 ! ~-083 PROPBRTY ADDRB$S: ! 5 W. Factory Street, Mechanicsburg, PA 17055 lMPROVB]%4]~NTS: A residential dwelling. SOLD AS THY PROPERTY OF: PAUL A. RN£AUMB i ~ 8rate o~ ~ylv~n, ~re ~;~l~larly ~u~ and Oescr~ ~L~ maaur~ i~ a ~th~aeecly d/recei~ t~ hundr~ aLxky (2~.~) ~r~ the a~th~t ~er o~ racto~ 6b~ee a~ ~rket Street; ~hence ~th (339.~6] ~eee eo ~ h~ ~n U~e noc:he~ ~ine ota ~een (35.~) :~t vide illeg; ~hence S~h 7~ d~ceea 33 minu~ea Wea~ al~ aa~d ~c:hecn line 27 ;inures Neat a[~ the eaate~ ~/ne o~ lands n~ or ~o~tly ~]ge~, 3r., a dl~tance o~ ~e h~c~ n~ne~een (119.~) E~t to a h~ ~ the ~thern line o~ ~acte~ 8treat; th~ North 71 ~cees 33 flAVl~ ther~ er~t~ a 2~ .to~ Loam ~ell/~ and de~aah~ fca~ garage ~ a~ n~c~ as 15 ~at ~actoW S~reet. I ~Ltl~ i~ rL~hta o~ ray o~ rea~, TAX PAKC~L ~ ~ ~-~2-0~ ] Dovenmuehle Mortgage Co. LP In The Court of Common Pleas of VS Cumberland County, Pennsylvania Paul A. Rheaume Writ No. 2001-3054 Civil Term R. Thomas Kline, Sheriff, who being duly swom according to law, states this writ is returned STAYED pursuant to instructions from Attorney Joseph Goldbeck. Sheriff's Costs: Docketing 30.00 Surcharge 20.00 Advertising 15.00 Posting Bills 15.00 Law Library .50 Prothonotary 1.00 Mileage 13.80 Levy 15.00 Certifi~ Mail 1.63 Law Journal 260.75 Patriot News 263.20 Poundage 40.00 Share of Bills 25.21 $ 70 E.09 paid by attorney 03/07/03 Sworn and subscribed to before me This /3 ~- dayof R. Thomas Kline, Prothonotary Real Estate Deputy Goldbeck McCafferty & McKeever BY: Joseph A. Goldbeck, Jr. Attorney I.D. #16132 Suite 500 - The Bourse Bldg. 111 S. Independence Mall East Philadelphia, PA 19106 215-627-1322 Attorney for Plaintiff DOVENMUEHLE MORTGAGE CO. LP 1501 Woodfield Road IN THE COURT OF COMMON PLEAS Schaumburg, IL 60173-4982 Plaintiff of Cumberland County VS. PAUL A. RHEAUME CIVIL ACTION - LAW (Mortgagor(s) and Record Owner(s)) 15 W. Factory Street Meehanicsburg, PA 17055 ACTION OF MORTGAGE FORECLOSURE Defendant(s) No. 01-3054 Civil Term AFFIDAVIT PURSUANT TO RULE 3129 DOVENMUEHLE MORTGAGE CO. LP, Plaintiff in the above action, by its attorney, Joseph A. Goldbeck, Jr., Esquire, sets forth as of the date the praecipe for the writ of execution was filed the following information concerning the real property located al: 15 W. Factory Street Mechanicsburg, PA 17055 I.Name and address of Owner(s) or Reputed Ownerlsl: PAUL A. RHEAUME 15 W. Factory Slreet Mechauicsburg, PA 17055 2. Name and address of Defendantls) in the judgment: PAUL A. RHEAUME 15 W. Factory Street Mechanicsburg. PA 17055 3. Name and last kuown address of every judgment creditor whose judgment is a record lien on the property to be sold: PA DEPARTMENT OF PUBLIC WELFARE - Bureau of Child Support Enforcement Health and Welfare Bldg. - Room 432 P.O. Box 2675 Harrisburg, PA 17105-2675 DOMESTIC RELATIONS OF CUMBERLAND COUNTY PO Box 320 Carlisle, PA 17013 BENEFICIAL CONSUMER DISCOUNT CO. 4910 Carlisle Pike, Suite 104 Mechanicsburg, PA 17055 BENEFICIAL CONSUMER DISCOUNT CO. 961 Weigel Drive Elmhurst, IL 60126 4. Name and address of the last recorded holder of every mortgage of record: PENNSYLVANIA HOUSING FINANCE AGENCY 2101 N. Front Street Harrisburg, PA 5. Name and address of every other person who has any record interest in or record lien on the properly and whose interest may be affected by the sale: 6. Name and address of every other person of whom the plaintiff has knowledge who has any record interest in the property which may be affected by the sale. 7. Name and address of every other person of whom the plaintiff tuts knowledge who has any interest in the property which may be affected by the sale. TIM COLGAN-ESQ The Wiley Group I South Baltimore Street Drillsburg, PA 17019 (attach separate sheet if more space is needed) I verity that the statements made in this affidavit are true and correct to the best of my personal knowledge or information and beliel: I understand that false statements herein are made subject to the penalties of 18 Pa. C.S. Section 4904 relating to unsworn falsification to authorilies. GOLDBECK McKEEVER BY: Joseph A. ~,i~dbeckJr., Esq. Attorney for Plaintiff 01-3054 Civil Term GOLDBECK McCAFFERTY & MeKEEVER BY: Joseph A. Goldbeck, Jr. Attorney I.D.#16132 Sintc 500 - The Bourse Bldg. I 11 S. Independence Mall East Pbiladclphia, PA 19106 215-627-1322 AUomey for Plaintiff DOVENMUEHLE MORTGAGE CO. LP 1501 Woodfield Road IN THE COURT OF COMMON PLEAS Schaumburg, IL 60173-4982 of Cumberland County Plaintiff vs. CIVIL ACTION - LAW PAUL A. RHEAUME Mortgagor(s) and Record Owner(s) ACTION OF MORTGAGE 15 W. Factory Street FORECLOSURE Mec lanicsburg. PA 17055 Term No. 01-3054 Civil Term Defendant(al Tills LAW FIRM IS A DEBT COLLECTOR ANn WE ARE ATTEMPTING TO COLLECT A DEBT. THIS NOTICE IS SENT TO YOI_I IN AN ATTEMPT TO COLLECT A DEBT. ANY INFORMATION OBTAINED FROM YOU WILL BE USED FOR THAT PURPOSE. NOTICE OF SHERIFF'S SALE OF REAL PROPERTV TO: r,:III!.AOM E, P^UL A. PAUL A, RHEAUME 15 W. Factory Street Mechanicsburg. PA 17055 Your house at 15 W. Factory Street, Meclvanicsburg, PA 17055 is scheduled to be sold at Sheriffs Sale on Wednesday, March 05, 2003, al 10:00 AM, in Conunissioners Hearing Rm 2nd FL Courthouse to enforce the conrt iudgment of $77.101.56 obtained by DOVENMUEHLE MORTGAGE CO you. ' , LP against NOTICE OF OWNER'S RIGHTS YOU MAY BE ABLE TO PREVENT THIS SHERIFF'S SAl.l~. To preveot this Sheriffs Sale you must take immediate action: I. The sate ,.'.'ill be cancelled if you pay to DOVENMUEHLE MORTGAGE CO. LP, the back paymeuts, late cbarges, costs and reasonable attorney's fees due. To find out how much you must pay call: '~ 5 t:97 99 - .-o_ -13__ 2. Yoa may by able lo stop the sale by filing a petition asking the Courl to strike or open judgreent, if the jndgmcnt was improperly entered. You may also ask tho Court to postpone the sale for good cause. 01-3054 Civil Term 3. You may also be able to stop the sale through other legal proceedings. You may need an attorney to assert your rights. The sooner you contact one, the more chance you will have ofs opping the sale. (See notice below on how to obtain an attorney). YOU MAY STILL BE ABLE TO SAVE YOU'R PROPERTY AND YOU HAVE OTHER RIGHTS EVEN IF THE SHERIFF'S SALE DOES NOT 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 price by calling the Sheriff of 717-240-6390. 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 properly. 3. The sale will go through only if the buyer pays the Sheriff the full amount due in the sale. To find out if this has happened, you may call the Sheriffof 717-240-6390. 4. If the amount due front the Buyer is not paid to the Sheriff, you will remain the owner of the propet~ as if the sale never happened. 5. You have a right to remain in the property until the full amount due is paid to the Sheriff and the Sheriff gives a deed to the buyer. At 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 Sheriffthirty (30) days from the date of the Sheriff's 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 schedule of distribution is filed. 7. You may also have other rights and defenses, or ways ofgelting your house back, if you act inm~ediateiy after the sale. YOU SHOULD TAKE THIS PAPER TO YOUR LAWYER AT ONCE. IF YOU DO NOT HAVE A LAWYER OR CANNOT AFFORD ONE, GO TO OR TELEPHONE THE OFFICE LISTED BELOW TO FIND OUT WHERE YOU CAN GET LEGAL HELP. CUMBERLAND COUNTY BAR ASSOCIATION 2 Liberty Avenue Carlisle, PA 17013 LEGAL SERVICES INC 8 Irvine Row Carlisle, PA 17013 ~l~l~ a~ a ~int ~ t~ ~uthern line o: Fa ~1~ ~aaur~ i~ a ~th~aeerlv al .... · . ~tory Street, aal6 of a ft~teen (15.~) f~t ~ide · ~]ey a dll~ance b~ sixty~e (6~.~) ~eet ~o a hub~ ~henc~ ~c~b 27 m~nut~s ~at ako~ the e~e~ ~lne of lands n~ o~ ~o~ly ~gel~ ~.~ a d~tanc~ o~ ~e h~d~ nineteen ~tha (M.83} ~e'~r~r~ a oistahce of f~Ety-~ouc a~ ei~Se_a~°ng flAVl~ ther~ er~k~ a 2~ eCo~ fca~ ~elll~ and dm~aeh~ fcm~ garage ~ti~ 4~ cL~ht, o~ ~y o~ teton, TAX PARCEL ~ 19-22-0~ I ~-013 WRIT OF EXECUTION and/or ATTACHMENT COMMONWEALTH OF PENNSYLVANIA) NO 01-3054 Civil COUNTY OF CUMBERLAND) CIVIL ACTION - LAW TO THE SHERIFF OF CUMBERLAND COUNTY: To satisfy the debt, interest and costs due Dovenmuehle Mortgage Co. LP 1.501 Woodfield Road, Sehaumburg, IL 6017.3-4982 Plaintiff(s) From Paul A. Rheaume 15 W. Factory Street Mechanicsburg, PA 170S5 (I) You are direeted to levy upon the property of the defendant (s)and to sell SEE LEGAL DESCRIPTION. (2) You are also directed to attach the property ofthe defendant(s) not levied upon in the possession of GARNISHEE(S) as follows: and to notify the garnishee(s) that: (a) an attachment has been issued; (b) the garnishee(s) is enjoined from paying any debt to or for the account of the defendant (s) and from delivering any property of the defendant (s) or otherwise disposing thereof; (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 DueS77101.56 L.L.$.50 Interest FROM 01/01/2001 TO 9/19/2002 AT 8.0000% Atty's Corem % Due Prothy $1.00 At~ Paid $157.25 Other Costs Plaintiff Paid Date: September 2.t, 2002 CURTIS IL LONG Prothonotary Deputy ' REQUESTING PARTY: Name Joseph A. Goldbeek, Jr. Address: Suite SO0 - The Bourse Bldg. I I 1 S. Independence Mall East Philadelphia, PA 19106 Atlorne¥ for: Plaintiff Te]epbone: 21S-627-1322 Supreme Court 113 No. 16132 Real Estate Sale # 12 On October 29, 2002 the sheriff levied upon the defendant's interest in the real property situated in Mechanicsburg Borough, Cumberland County, PA known and numbered as 15 West Factory Street, Mechanicsburg, more fully described on Exhibit "A" filed with this writ and by this reference incorporated herein. Date: October 29, 2002 By: Real L~tate Deputy PROOF OF PUBLICATION OF NOTICE IN CUMBERLAND LAW JOURNAL (Under Act No. $87, approved May 16, 1929), P. L.1784 STATE OF PENNSYLVANIA : : SS. COUNTY OF CUMBERLAND: Lisa Marie Coyne, 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 Sanuary 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: SANUARY 31, FEBRUARY 7, 14, 2003 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 am true. Writ No. 2001-3054 Civil _ Dovanmuehle Mortgage Co. LP ./~.//I~l~a Marie Coyne.]~itor VS. Paul A. Rheaume Atty.: ,Joseph Goldbeck '-SWORN TO AND SUBSCRIBED before me this ALL THAT CERTAIN tract or par_ 14 day o f ~.~r,~,~. eel of land situate on the south side of West Factory Btreet. 4th Ward. In the Borough of Mechanlcsburg. "? . County of Cumberland and State of Pennsylvania. more particularly - bounded and described as follows: BEGINNING at a point on the ~ "../"'~'~: .. ' ',?..~.!~ southern line of Factory Street, said :' ;' ' ' '.' ...,~ poi., ~i,,g meas.red i. a .o.th- westerly direction two hundred sixty [260.00} feet from the southwest corner of Facto~ Street and Mar- ket Street; thence south 21 degrees 25 minutes East along iht' western line of lands now or formerly of Aaron C. Kappa distance of one btm- dred nineteen and sixteen hun- dredths (119.16) feet to a hub on the northern line of a fifteen (15.00] THE PATRIOT NEWS THESUNDAY PATRIOT NEWS Proof of Publication Under,a~ No. 587, Approved May16,1929 Commonwealth of Pennsylvania, County of Dauphin} as JOSEPH A. DENNISON being duly sworn according to law, deposes and says: That he is the Asst. Controller of The Patriot News Co., a corporation organized and existing under the laws of the Commonwealth of Pennsylvania, with its principal office and place of business at 812 to 818 Market Street, in the City of Harrisburg, County of Dauphin, State of Pennsylvania, owner and publisher of ~ an T P tri -N newspapers of general cimulafion, printed and published at 812 to 818 Market Street, in the City, County and State aforesaid; that The Patriot-News and The Sunday Patriot-News were established March 4th, 1854, and September 18th, 1949, respectively, and all have been continuously published ever since; That the printed notice or publication which is securely attached hereto is exactly as printed and published in their regular daily and/or Sunday/ Metro editions which appeared on the 28th day(s) of January and the 4th and 11th day(s) of February 2003. 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 Miscellaneous Book 'M", Volume 14, Page 317. COPY S orn to and subs~il~ before this 14th ~b~ry 2003 A.D S A L E #12 Notar~Se~ y' / / .a~/.' J ' Tally L Russell. N(Xa~y Pul31ic - MyCommissk~E~rasJune6.2006 I N~TARY PUBLIC ' Mamb~.Penns~'a~aAsa3amionO~No~.tas My commission expires June 6, 2006 CUMBERLAND COUNTY SHERIFFS OFFICE CUMBERI.N~D COUN3Y COURTHCXJSE 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 $ 261.45 Probating same Notary Fee(s) $ 1.75 Total $ 263.20 Publisher's Receipt for Advertising Cost The Patriot News Co., publisher of ~and ' - newspaparc of general circulation, hereby acknowledge receipt of the aforesaid notice and publication costs and certifies that the same have been duly paid.